Technical Guidance for Determining the
Presence of Manufactured PCB Products in
Buildings and Other Structures
United States Environmental Protection Agency
SEPTEMBER 2023
EPA-530-R-23-015
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Preface
Manufactured polychlorinated biphenyl (PCB) products, are manufactured products containing PCBs in a non-liquid
state. The United States Environmental Protection Agency (EPA) has prepared this technical guidance as a resource
to assist property owners or operators, their contractors, and analytical labs in determining the presence of
manufactured PCB products containing PCBs at concentrations greater than or equal to (>) 50 parts per million
(ppm) in buildings or other structures that are in use or planned for renovation or demolition. Certain sections of
this technical guidance, such as those pertaining to the development of sampling plans, sample collection
procedures, or analytical methods may also help inform environmental contractors and analytical laboratories hired
by property owners and operators that are assessing a building or other structure.
In this technical guidance, the EPA presents a statistically-based sampling approach that can be used, along with
records and documentation, to potentially determine the presence of PCBs in concentrations > 50 ppm within a
building or other structure. Please note that, if desired, this guidance, with the necessary modifications, can be
applied to determine the presence of manufactured PCB products at a threshold other than 50 ppm. This document
will use the general term "buildings" to include "other structures." This document is a companion to EPA's Fact
Sheet on PCBs in Building Materials (Reference 1).
The use of manufactured PCB products containing PCBs at concentrations > 50 ppm is not authorized under the
Toxic Substances Control Act (TSCA) and the federal PCB regulations at Title 40 of the Code of Federal Regulations
(CFR) part 761. If manufactured PCB products containing > 50 ppm PCBs are found in buildings, they must be
removed and disposed of as PCB bulk product waste in accordance with 40 CFR 761.62. Additionally, PCB-
contaminated substrate in contact with manufactured PCB products containing > 50 ppm PCBs may be regulated for
cleanup and disposal.
Property owners or operators are responsible for complying with TSCA and the PCB regulations, including by
managing and disposing of regulated PCBs in accordance with applicable requirements. In addition to these federal
requirements, property owners or operators are also responsible for determining and complying with all other
applicable federal, state, and local requirements. Individuals are encouraged to consult with their state or local
environmental officials regarding any additional requirements that may apply.
This document is not intended to address building equipment containing liquid PCBs, such as fluorescent light
ballasts and electrical equipment, or cleanup and disposal of contamination from spills or releases of liquid PCBs.
Instead, please refer to the following:
• PCB regulations at 40 CFR part 761
• PCB spill cleanup and disposal guidance documents available on EPA's website at https://www.epa.gov/pcbs
Disclaimer
This document and two companion worksheets do not impose any legally binding requirements or obligations on
EPA, states, or the regulated community, nor do they release any party from liability for any violation of TSCA or its
implementing regulations. A property owner or operator may use the guidance provided in these materials to assess
whether a building potentially contains manufactured PCB products. Discussion in this document of what users
"should" or "need to" or "have to" do are not statements of legal obligation but, rather, technical instruction on
how to follow the approaches described in this document. This document and two companion worksheets may not
apply to a particular situation based upon the circumstances, and they do not preclude the use of other approaches.
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Use of these materials does not guarantee that manufactured PCB products are not present in a building, nor does it
create a defense against a violation under TSCA if that occurs.
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Contents
Preface 2
Disclaimer 2
I. PCB-Containing Materials 5
II. Determine Potential Presence of Manufactured PCB Products in the Building 6
Review Building Records 6
Compile an Inventory 7
III. Building Fate 8
Demolition and Disposal 8
Renovation or Continued Use 9
IV. Building Material Characterization Sampling Plan 11
Composite Sampling 13
Outdoor PCB Contamination & Potential Migration Considerations 14
V. Sample Collection Procedures 14
Bulk solid samples 14
Non-porous surface samples 14
Porous surface samples 15
Indoor air samples 15
VI. Analytical Methods for Building Materials 15
Sample Preparation 16
Sample Extraction 17
Extract Cleanup 18
VII. Handling, Storing, and Disposing of Wastes 18
VIII. Regional PCB Coordinators 18
IX. References 19
X. Appendix A - Example Blank Worksheets 21
XI. Appendix B - Example Building Scenario 29
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I. PCB-Containing Materials
Note: All references are listed in Section IX (References) as well as linked throughout the text of this document.
Although PCBs are no longer commercially manufactured in the United States, EPA believes that there was
widespread use of manufactured PCB products during building construction and renovation activities occurring
between 1950 and 1979. In addition to manufactured PCB products, which contain PCBs in a non-liquid state,
equipment containing liquid PCBs, such as fluorescent light ballasts, may be present in buildings constructed or
renovated during this period.
Manufactured PCB products may be found throughout a building. For example, applied paints and caulks around
windows and doors and within expansion joints have been frequently identified as manufactured PCB products.
There may be an increased likelihood for the presence of manufactured PCB products in certain areas of a building,
such as boiler rooms or other areas subject to high heat. The location and PCB concentrations of manufactured PCB
products within a building can vary by material type and from item to item within materials of the same type. Even
when manufactured PCB product is removed or replaced, PCB residues may be left behind and contaminate porous
(e.g., concrete, brick) and non-porous (e.g., metal surfaces, smooth glazed ceramics) substrate materials that were
in contact with the manufactured PCB product. These PCB residues may even migrate from the substrate materials
previously contaminated by manufactured PCB products into newly installed replacement materials. The purpose of
this technical guidance is to provide a resource to assist property owners or operators in determining if
manufactured PCB products may be present in a building or structure and developing a building material
characterization sampling plan to test such materials. The use of manufactured PCB products containing PCBs at
concentrations > 50 ppm is not authorized under the Toxic Substances Control Act (TSCA) and the federal PCB
regulations at 40 CFR part 761. If manufactured PCB products containing > 50 ppm PCBs are found in buildings, they
must be removed and disposed of as PCB bulk product waste in accordance with 40 CFR 761.62.
The table below lists potential PCB-containing material types that may be present in buildings. This list includes
materials frequently identified to be manufactured PCB product and equipment containing liquid PCBs, but it is not
intended to be comprehensive. Other material types not listed here may contain PCBs based on their form or
function or year and place of manufacture and installation.
Materials Potentially Containing Non-Liquid
PCBs
Materials Potentially Containing Liquid PCBs
Paint, varnishes, lacquers
Electrical equipment such as transformers or
capacitors
Non-conducting materials in electrical cables
(such as plastic and rubber)
Fluorescent light ballasts (which may contain
liquid PCBs in the capacitor and non-liquid PCBs
in the potting material)
Rubber and felt gaskets
Oil-filled electrical cable
Coal-tar enamel coatings (e.g., pipe coating) and
rust inhibitor coatings
Hydraulic equipment
Insulation material (including fiberglass, felt,
foam, and cork)
Heat transfer equipment
Adhesives and tapes
Extrusion fluids
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Caulk and grout (including putty, silicon,
window glazing, and bitumen)
Rubber isolation mounts, foundation
mounts, and pipe hangers
Plastic applications (including vinyl and PVC)
Galbestos siding
Mastics
Acoustic ceiling and floor tiles
Joint material (between structural joints on
buildings, parking lot/sidewalk pads, etc.)
Asphalt roofing and tar paper
Synthetic resins and floor varnish
Sprayed-on fireproofing
If there is reason to suspect manufactured PCB products are present in building materials and the building is in use,
there are several steps that may reduce potential exposure to building occupants until the building is fully
characterized and any identified manufactured PCB products are abated. EPA's "PCB in Building Materials" website
(Reference 2) provides information to property owners or operators on managing PCBs found in building materials
to help minimize potential exposures to building occupants.
If there is reason to suspect liquid PCB use within building equipment, the equipment should be checked for leaks
and the surrounding areas (e.g., concrete, steel surfaces) should be checked to determine if there is any evidence,
such as visible staining, that the areas may have been impacted from the leaks. The use of building equipment
containing liquid PCBs, such as fluorescent light ballasts and electrical equipment, and the cleanup and disposal of
contamination from spills or releases of liquid PCBs, are regulated under the PCB regulations at 40 CFR part 761 but
are not addressed in this document. The reader should consult the appropriate resources mentioned in the Preface.
II. Determine Potential Presence of Manufactured PCB Products in
the Building
There is no visual standard for determining if manufactured PCB products are present in a building or structure, and
a visual assessment alone is insufficient to determine the presence of PCBs. To determine if such products are
present, sampling and laboratory analysis for PCBs are necessary. A property owner or operator may wish to
consider the following steps in deciding whether to conduct testing, determine what types of materials to test, and
develop a testing program.
Review Building Records
EPA recommends that the process of evaluating a building for the potential presence of manufactured PCB products
begin with a review of historical records related to the construction, renovation, and maintenance of the building
(e.g., caulk replacement, window replacement, stripping and repainting of surfaces). The property owner or
operator may have documentation indicating that a specific material type within the building is not a manufactured
PCB product or that the entire building itself does not contain manufactured PCB products. As noted above, EPA
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believes that there was widespread use of manufactured PCB products during building construction and renovation
activities occurring between 1950 and 1979. PCB production was banned in 1979 by TSCA (with some products and
processes excluded from the ban by regulation), so available information showing that a building was constructed in
the 1990s, for example, is a good indication that it likely would not contain manufactured PCB products.
Use of historical records related to building construction, renovation, or maintenance may include information
about the types of materials used and may help identify building materials or areas of the building that do or do not
contain manufactured PCB products. For example, records may indicate that all of the older electrical cables in a
building have been replaced with modern PCB-free electrical cables. Alternatively, if records indicate that only a
portion of the older electrical cables have been replaced, then the property owner or operator could exclude the
newer wiring from the inventory of materials that may contain PCBs, described below. Even if records indicate that a
potential manufactured PCB product, such as caulk, was previously replaced, residual PCBs from the original
material could be present in surrounding substrates (e.g., concrete, brick), which could then contaminate the
replacement material. In such a case, the property owner or operator may consider including the replacement
material in the inventory of materials that may contain PCBs.
Compile an Inventory
In cases where the property owner or operator does not have any historical building records, or such records do not
clearly indicate whether or not a specific material type is a manufactured PCB product, EPA recommends developing
an inventory of each material type that the property owner or operator believes may contain PCBs.
EPA recommends performing an inspection of the building to look for suspected manufactured PCB products. The
number of discrete items or square or linear feet of each material type present (e.g., the number of gaskets or the
amount of caulk) and the location of each material type inside or exterior to the building should be determined by
the inspection and noted on the inventory.
When compiling an inventory of suspected manufactured PCB product material types, consideration should be given
to variances within a material type. For example, a building may contain various colors of paint or caulk within
different areas (e.g., north, south, east, and west), different rooms, or on different floors, each with the potential to
contain PCBs. Variation of other attributes, such as the condition of the materials (e.g., plasticity, degradation,
brittleness, friability) should be considered. Note that PCBs in products such as paint and caulk can be
heterogeneously distributed. A single building painted in the same color on all four exterior walls may show
significant variation in PCB concentrations from wall to wall or even within the same wall (Reference 3). Therefore,
varying PCB concentrations may be found within the same color of paint on the same wall.
Additionally, coatings applied to a surface over a specific area such as a wall (e.g., paint) or linearly to seal cracks
(e.g., caulk), are examples of building materials that can be difficult to divide into individual, discrete items. Paint
coverage may vary depending on the surface and application; however, one gallon of paint, as a rule of thumb,
covers approximately 400 square feet. A property owner or operator may use other square footage values if
supporting information is available. Using 400 square feet as an example, a property owner or operator may choose
to treat every 400 square feet of similarly colored painted surface as one item when developing the number of
painted items in the inventory. This does not mean a sample is recommended for every 400 square feet; however, it
does mean that one may estimate the number of individual items available for sampling as the entire square footage
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of painted surfaces divided by 400. For sampling of linear items such as caulk, EPA recommends using every 10 linear
feet of similar color caulk as one item when determining the total number of caulk items in the inventory.
III. Building Fate
Once historical records are reviewed, visual inspection(s) performed, and an inventory developed, EPA recommends
that the property owner or operator develop a building material characterization sampling plan that reflects the
current and/or future use plan for the building. There are generally two paths that a property owner or operator
may face: demolition and disposal, or renovation and continued use.
Demolition and Disposal
If the property owner or operator is planning to demolish the building and dispose of the resulting waste and does
not have records clearly indicating that the building is unlikely to contain manufactured PCB products at regulated
levels (i.e., > 50 ppm), then sampling is recommended to determine whether protective measures, such as worker
protection, are needed during demolition, to facilitate recycling of materials that do not contain or are not
contaminated with PCBs (provided other contaminants, such as asbestos and lead-based paint, are not present), and
to ensure PCB wastes are properly disposed of and controls are put in place to prevent a release of PCBs to the
environment (References 4, 5, and 6). Alternatively, instead of sampling, the property owner or operator could
choose to assume inventoried suspected manufactured PCB products contain > 50 ppm PCBs and are regulated for
disposal as PCB bulk product waste under § 761.62. Property owners or operators are responsible for complying
with TSCA and the PCB regulations, including by properly managing and disposing of regulated PCBs, and for
complying with any other applicable federal, state, and local requirements.
If the property owner or operator conducts sampling, they should test all inventoried suspected manufactured PCB
product material types present in the building (see Section IV - Building Material Characterization Sampling Plan). If
the material contains > 50 ppm PCBs, it is regulated for disposal as a PCB bulk product waste (see §§ 761.3 and
761.62). The property owner or operator should also consider whether the material to which the manufactured PCB
product containing > 50 ppm PCBs is attached (i.e., substrate), such as wood, masonry, or brick, is regulated for
cleanup and disposal, as PCBs may have leached into or onto those substrates from the manufactured PCB product.
If the property owner or operator intends to remove and dispose of the manufactured PCB products assumed or
tested to contain > 50 ppm PCBs together with any contaminated building substrates, they may designate and
dispose of all the substrate materials coated or serviced with manufactured PCB products as a PCB bulk product
waste without further testing of the substrate even if the manufactured PCB product becomes separated from the
contaminated building substrates during demolition. The property owner or operator should document the decision
to designate building materials as PCB bulk product waste at the time of designation for disposal (e.g., within the
building demolition plan). For more information, see Reference 7.
If, however, the manufactured PCB products containing > 50 ppm PCBs are no longer present or are no longer
attached to the adjacent substrate at the time of designation for disposal (e.g., PCB-containing caulk or paint has
already been removed from the substrate prior to the start of demolition), or if the property owner or operator
intends to recycle the substrate, the substrate should be tested to determine if PCBs have leached into or onto the
substrate. The extent of migration into the depths of the substrate and laterally away from the previously attached
manufactured PCB product should be determined by sampling for the purposes of disposal or recycling. If PCBs are
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present in the substrate, such that it meets the definition of a PCB remediation waste at § 761.3, it is subject to the
cleanup and disposal requirements at § 761.61.
Additional Considerations - Dust and Stormwater Control
It is important to consider dust monitoring and control during demolition projects where manufactured PCB
products are present to protect third parties and the environment. Regulatory requirements for the control of dust
generated during demolition operations can arise from local or county ordinances or codes, state regulations, some
federal regulations, and construction general permits issued by the EPA or states, see Reference 6. Additionally,
EPA's 2022 Construction General Permit (CGP) contains PCB-specific requirements for certain building demolition
activities. The CGP is a National Pollutant Discharge Elimination System (NPDES) permit issued under the authority of
the Clean Water Act and associated regulations that regulates stormwater discharges from construction activities in
those areas where EPA is the NPDES permitting authority. Such requirements include implementation of controls to
minimize the exposure of PCB-containing building materials to precipitation and storm water (CGP Section 3.2). The
CGP Fact Sheet (Reference 8) details a variety of controls that can be implemented to minimize the potential
discharge of PCBs from demolition activities including constructing a containment area, covering the ground, and
using tools that minimize heat and dust generation (pages 86-88 of the CGP Fact Sheet). Because these
requirements are site specific, it is important to work closely with local and state environmental regulators as well as
with any office that issues a demolition permit (if the project is located in an area where such permits are required),
to determine the applicable requirements for the control of dust. For additional information, see Reference 6.
Renovation or Continued Use
If the property owner or operator is planning to renovate or continue to use the building and does not have records
clearly indicating that the building is unlikely to contain manufactured PCB products at regulated levels (i.e., > 50
ppm), then sampling is recommended to determine whether protective measures are needed during renovation
activities, and to ensure PCB wastes are properly disposed of and controls are put in place to prevent a release of
PCBs to the environment (References 4 and 5). Alternatively, instead of sampling, the property owner or operator
could choose to assume inventoried suspected manufactured PCB products contain > 50 ppm PCBs and are
regulated for disposal as PCB bulk product waste under § 761.62. In this case, all manufactured PCB products
assumed to contain > 50 ppm PCBs must be removed from the building and disposed of in accordance with § 761.62.
Property owners or operators are responsible for complying with TSCA and the PCB regulations, including by
properly managing and disposing of regulated PCBs, and for complying with any other applicable federal, state, and
local requirements.
If the property owner or operator conducts sampling, they should test all inventoried suspected manufactured PCB
product material types present in the building (see Section IV - Building Material Characterization Sampling Plan).
Material that contains > 50 ppm is unauthorized for use and must be removed and disposed of as PCB bulk product
waste under § 761.62. Depending upon the extent of such building materials identified, the property owner or
operator may need to prioritize removal of manufactured PCB product building materials based on building
occupancy, PCB concentration levels within the materials, location of the materials, and accessibility to building
occupants and exposure risk. When removing manufactured PCB products in a phased approach, it may be
necessary to install temporary controls to prevent releases from phases not yet addressed. For more information,
see References 4 and 5.
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If manufactured PCB products are assumed or tested to contain > 50 ppm PCBs, the property owner or operator
should determine if PCBs migrated from these materials to the surrounding porous and/or non-porous substrates
and may require mitigation during renovation or for continued use of the building. The property owner or operator
should test the substrate to determine if PCBs have leached into or onto the substrate to determine the extent of
migration into the depths of the substrate and laterally away from the manufactured PCB product. If PCBs are
present in the substrate, such that it meets the definition of a PCB remediation waste as defined at § 761.3, the
substrate is regulated for cleanup and disposal in accordance with § 761.61, or alternatively, may be removed with
the PCB-containing building material and disposed of as a PCB bulk product waste in accordance with § 761.62 (see
Reference 7).
If removal of manufactured PCB products assumed or tested to contain > 50 ppm PCBs and contaminated substrates
is not feasible when the materials are identified in a building, the property owner or operator should work with the
EPA Regional PCB Coordinator (see Section VII - Regional PCB Coordinators) to develop a plan to protect building
occupants and manage such materials, along with any surrounding PCB-contaminated substrates, until they can be
removed and disposed of in accordance with the PCB regulations.
Additional Considerations - HVAC
To help minimize potential exposures to PCB during building renovation, the HVAC system should be shut down and
remain off until PCB abatement is complete. Abatement areas should be isolated from the HVAC system. Consider
restoring the cleanliness of the building HVAC system using the latest Air Conditioning Contractors of
America/American National Standards Institute (ACCA/ANSI) standards to remove buildup of particulate and debris
which may adversely impact the indoor environment and performance of the system. Consider hiring contractors
who specialize in cleaning ventilation systems, as they have specialized tools and training to ensure thorough
cleanup. It is important to remember that not all ventilation system ducts can be cleaned. For example, some ducts
are lined with fiberglass or other insulation, which can release fiberglass into building areas if damaged during
cleaning. Also, flexible ductwork frequently has a porous inner surface and, in most cases, cannot be economically
cleaned. For this reason, such ductwork should be discarded and replaced after the ventilation system is cleaned.
For additional information, see Reference 5.
Additional Considerations - Dust and Stormwater Controls
When working on a renovation or repair job where manufactured PCB products are present, appropriate controls
should be put in place to minimize spreading dust during the renovation and/or repair activity. The work area should
be protected by constructing a containment area whenever potentially hazardous material is disturbed and could
generate dust. For additional information related to dust control during renovation activities, see Reference 4.
EPA's 2022 Construction General Permit (CGP) contains PCB-specific requirements for certain construction activities.
For example, if exterior building renovation is planned, the CGP may require implementation of controls to minimize
the exposure of PCB-containing building materials to precipitation and storm water (CGP Section 3.2). The CGP Fact
Sheet details a variety of controls that can be implemented to minimize the potential discharge of PCBs from
demolition activities that may be useful controls. For example, constructing a containment area, covering the
ground, using tools that minimize heat and dust, and many more BMPs are listed in pages 86-88 of the Fact Sheet.
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Additional Considerations - Pre- and Post-Abatement Sampling
The property owner or operator should determine if indoor air and/or wipe testing prior to and/or after abatement
is warranted. This may be necessary to address concerns about building occupant exposure via the inhalation
pathway based on building construction details and features, cleaning practices, or the location of the identified
manufactured PCB products. Additionally, such sampling can help determine if the controls put in place to prevent
releases of PCBs during renovation were effective. Samples collected prior to abatement provide a site-specific
baseline for comparison, which can be particularly useful at sites where manufactured PCB products are being
removed in phases.
Wipe sampling can identify PCBs in settled dust, and air testing can determine if PCBs are present in indoor air. Each
building is unique, which means that many factors should be considered when deciding whether and how to collect
indoor dust and air samples. These factors include site-specific conditions, steps already implemented to address
PCB sources, available technical resources, and public or building user concerns.
If the building is a school, the air test results may be compared to the Exposure Levels for Evaluating PCBs in Indoor
School Air found at Reference 9. The Exposure Levels for Evaluating PCBs in Indoor School Air should not be used to
estimate occupational exposure associated with non-school buildings or other sites or residential exposure. Property
owners or operators may consider developing building-specific risk-based criteria for use at non-school buildings or
other sites, or at schools where operational times are not typical (e.g., adults and children are in school more than
6.5 to 8 hours per day and/or 180-185 days per year).
For more information on safe PCB abatement and renovation activities, see References 4 and 5.
IV. Building Material Characterization Sampling Plan
Property owners or operators should develop a building material characterization sampling plan (sampling plan) to
characterize inventoried suspected manufactured PCB product and/or substrates contaminated through contact
with manufactured PCB product. Sampling plans should be robust enough to ensure that sufficient samples are
collected of each suspected manufactured PCB product material type and the adjacent substrate to determine if
PCBs are present. Applicable PCB regulations for managing and disposing of these materials may vary depending
upon the PCB concentrations found.
In 2013, EPA issued a Technical Guidance for Determining the Presence of Polychlorinated Biphenyls (PCBs) at
Regulated Concentrations on Vessels (Ships) to be Reflagged ("Ship Guidance") (Reference 10). The Ship Guidance
describes the development of a statistically-based sampling plan using an inventory of potential manufactured PCB
product material categories found on a ship. EPA recommends that a property owner or operator consider using the
statistical approach to developing a sampling plan outlined in the Ship Guidance to determine the number and
distribution of samples to collect from each inventoried suspected manufactured PCB product material type in a
building. The statistical approach described below, based on the Ship Guidance, is provided as a resource to assist a
property owner or operator with the development of a sampling plan for both discrete items such as gaskets and
non-discrete items such as paint or caulk. Property owners or operators may consider using other sampling
approaches to determine the presence of manufactured PCB products; EPA recommends statistically-based or
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otherwise robust approaches. Reference 11 provides additional information on selecting sampling designs for new
data collections.
The statistical framework used in the Ship Guidance is that of "acceptance sampling." In an "acceptance sampling"
approach, items are considered in batches or lots. For the purposes of sampling suspected manufactured PCB
product in a building, each category of suspected manufactured PCB product listed in the building inventory would
be considered a separate lot. Examples of suspected manufactured PCB product categories include, but are not
limited to, the items listed in the table provided in Section I of this document. The lot size is the sampling frame for a
manufactured PCB product category, and it includes every item in that manufactured PCB product category that
might contain PCBs; for example, the number of individual rubber gaskets found in the building would be the lot size
for the rubber gasket category. A subset of the items in that manufactured PCB product category would be sampled
and tested. The number of items to be sampled is the sample size. The sampling plan would consist of individual
plans for each manufactured PCB product category listed in the building inventory that cannot be omitted from
testing based on the building's records or some other information. Each manufactured PCB product category will
have its own sample size in the sampling plan based on the manufactured PCB product category (lot) size, the level
of statistical risk selected in the acceptance sampling approach, and the total number of manufactured PCB product
categories to be tested. In the language of acceptance sampling, the sample size for each manufactured PCB product
category is developed by selecting the probability for rejecting the manufactured PCB product category. This is done
by selecting a > 90%, > 95%, or > 99% probability of testing at least one item in the manufactured PCB product
category that fails the test (i.e., contains PCBs above the desired threshold specification (e.g., 50 ppm, 1 ppm, or
other concentration) if the true underlying proportion of PCB contaminated items is > 10%, > 5%, or >1%. The
threshold specification is independent of the statistical assurance level used for the testing (i.e., the specification will
not change the number of samples recommended for the material category to achieve the selected confidence
levels). The Ship Guidance provides tables which have been adapted for use in this document to determine the
number of samples to collect from each manufactured PCB product category depending on the selected
probabilities and the total number of manufactured PCB product categories in the inventory to be tested. The
building owner can select the degree of confidence that they desire to achieve. That level of confidence will
correlate with the number of samples needed to reach that level of confidence. EPA recommends a property owner
or operator consider the use of the building when selecting the degree of confidence. For example, if a building will
be undergoing renovation for reuse as a residential space, a higher degree of confidence (e.g., 99%/l%) may be
considered. For additional background on this acceptance sampling approach, see Appendix II of the Ship Guidance.
The property owner should distribute the number of samples required for the manufactured PCB product category
across the number of locations where the material is present in the building (e.g., number of rooms). The property
owner or operator can determine if the manufactured PCB product category is present such that samples may be
evenly distributed across that manufactured PCB product category or, for non-discrete items such as painted
surfaces, proportionally to the painted surface area present in different areas within the building for that
manufactured PCB product category. There may be areas where the manufactured PCB product is inaccessible and
cannot be sampled; these items are different from omitted items which are not sampled because they are shown
through documentation to not contain PCBs. When selecting the sampling locations, if a selected location is known
to be inaccessible for sampling, then the building owner or operator may randomly select another sample location.
The number of inaccessible areas or items will not impact the number of samples recommended in the sampling
frame.
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The Ship Guidance describes how a sampling plan is developed using worksheets that walk a user through
determining how many samples are needed for each suspect manufactured PCB product category identified on a
ship. EPA has revised these worksheets for use in developing a building sampling plan. The revised worksheets are in
Appendix A of this guidance, and an example of these worksheets used on a hypothetical building inventory is in
Appendix B. Excel spreadsheets that mirror these worksheets are available at EPA's PCBs in Building Materials
website. The spreadsheets are provided as a tool to assist in calculating the number of samples needed for a
suspected manufactured PCB product category in a building.
EPA recommends that all sampling activities be conducted according to the requirements of a project-specific
quality assurance/quality control (QA/QC) project plan. This plan should ensure that data of appropriate quality and
quantity are available for their intended decision-making purposes. For additional information on developing Quality
Assurance (QA) Project Plans, see Reference 15.
Composite Sampling
EPA recognizes that this statistical framework may result in the need to collect a relatively large number of samples
to maintain a certain level of confidence in the result. In those cases, compositing of samples could be reasonably
applied for certain material categories to limit the sampling costs incurred without compromising the degree of
confidence resulting from the sampling.
Only material categories where multiple similar samples can be mixed and thoroughly homogenized should be used
for composite sampling. Paint and caulk are the two material categories that EPA envisions being used in composite
sampling. Different material categories (e.g., paints and caulks) or dissimilar materials within the same category
(e.g., caulks of different colors) should not be composited together into one sample. However, EPA recognizes that
there may be instances where it is difficult to separate colors when collecting a composite sample (e.g., multiple
layers of different color paint on a surface). In such cases, sampling results should note that the samples represent
multiple layers of paint.
In addition to the ability of samples from the material category to be mixed and homogenized, there are three other
considerations for composite sampling:
• EPA recommends that no more than 9 samples (of the same material) be combined into one composite
sample.
• The QA/QC project plan associated with composite samples should specify the practical quantification
limit (PQL) to be achieved for the resulting data from a composite sample to be acceptable for use.
• When evaluating the results, EPA recommends that the result for each individual sample added to the
composite be assumed to be the concentration of the composite sample multiplied by the number of
individual samples. For example, if 9 individual samples were combined into one composite sample, and the
analytical result of the composite sample is 12 ppm, then all 9 individual samples should be assumed to be
108 ppm (9 samples x 12ppm). This is a conservative approach, which does not reflect the true statistical
probability of even one of the samples reaching the upper bound (108 ppm in the case of the example
above). However, this conservative approach fits the purpose of this guidance, which is to determine the
presence of manufactured PCB products in a building.
Composite sampling is discussed further in Section V.
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Outdoor PCB Contamination & Potential Migration Considerations
Property owners or operators should be aware of the potential for ground surfaces surrounding buildings to become
contaminated with PCBs originating from manufactured PCB products, particularly from exterior paints, caulks, and
other sealants. In general, although not in all cases, PCB concentrations are highest in ground surfaces closest to the
building. Stormwater and surface water runoff may transport PCBs to storm sewers or nearby surface water features
(Reference 6). Property owners or operators should consider sampling nearby ground surfaces (e.g., soil, asphalt,
concrete), runoff pathways, and sediment in storm sewers to determine if exterior manufactured PCB products have
impacted those areas. 40 CFR part 761, subpart N provides a method which may be used for sampling such areas or
for assessing the sufficiency of existing sampling data.
V. Sample Collection Procedures
For the various sample types listed below, sufficient sample volume should be collected to ensure the laboratory can
measure the concentrations of PCBs at levels required by the PCB cleanup and disposal regulations at 40 CFR part
761, with additional volume available for laboratory QA/QC requirements. EPA recommends that the property
owner or operator contact the laboratory to discuss the necessary requirements for each sample type.
Bulk solid samples
Bulk solid samples include such materials as caulks and paints or soils which are adjacent to a building where
exterior manufactured PCB products were present. Bulk solid sampling typically includes removing a small portion of
the potentially contaminated material for analytical testing. For example, a caulk sample would be the quantity of
caulk needed by the laboratory for analytical testing. Only the caulk should be included in the final sample and not
other adjacent substrate materials, such as wood or concrete, which may skew the sample analysis results. Section
V.C. of the Ship Guidance (Reference 10) contains sample collection procedures for various categories of non-liquid
suspected manufactured PCB products such as paint and caulk.
To composite individual samples of paint and caulk, identify which individual samples will be grouped into one
composite sample. Compositing should be done by the laboratory rather than in the field. Additional information on
composite sampling is provided in Section IV above. Sample preparation is discussed further in Section VI.
A property owner or operator may wish to save extra material from each of the individual samples that were
combined into the original composite sample should testing of the individual samples be desired. For example, if a
composite sample result exceeds the desired threshold criteria (e.g., 50 ppm), the individual samples that comprised
the composite sample could be tested to determine which individual samples exceed the threshold criteria.
When soil samples are collected, consider whether the PCBs are on the soil surface or if they could be located
deeper in the soil. An example of when PCBs might be on the soil surface would be if fragments of weathered
caulking from the exterior of the building were deposited on undisturbed soil surfaces. Alternatively, PCBs could be
located deeper in the soil, in locations such as landscaping areas where the soil surface has been disturbed or where
new soil has been added. PCBs may also be located at deeper depths in poor drainage areas where surface water,
soils, and sediments collect.
Non-porous surface samples
14
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If the surface being sampled is smooth and impervious, such as a metal substrate that was adjacent to a caulk seam,
a wipe sample can be collected to determine if the surface is contaminated with PCBs. A standard wipe test, as
specified in § 761.123, uses a 10 centimeter (cm) by 10 cm template (or equivalent template that equals 100 cm2) to
outline the sample area and a gauze pad or glass wool that has been saturated with hexane to collect the sample.
The hexane-saturated wipe is used to thoroughly swab the area inside the 100 cm2 template. Care must be taken to
assure proper use of the sampling template, as the sample results will be based on the 100 cm2 sample area (i.e.,
micrograms (ng) per 100 cm2). 40 CFR part 761, subpart P provides sample site selection procedures which may be
used for large, nearly flat surfaces and for small or irregularly shaped surfaces.
Porous surface samples
Because PCBs can migrate into substrate materials that are porous surfaces (e.g., brick, masonry, concrete, or
wood), surface wipe sampling is not adequate to characterize the PCB concentration of porous surfaces. Instead,
core samples of the top 0.5 to 2 cm of the porous surface should be collected on a bulk basis (i.e., ppm). For these
porous surface samples, an adequate sample (as determined by the laboratory) should be removed for analysis.
Tools such as chisels, drills, and saws can be used to collect the sample, taking care to minimize dust generation
(References 4, 5, 13).
The samples should be collected from the top 0.5 cm to 2 cm of the surface closest to the likely source of PCB
contamination. For porous surfaces where the likely source of PCB contamination has been removed, such as
masonry with open joints where caulk was located adjacent to bricks, sampling should be focused on the brick
surfaces to which caulk was previously attached. Alternatively, consider removing the bricks which were located
adjacent to the manufactured PCB product materials and disposing of them as PCB remediation waste.
A Standard Operating Procedure (SOP) suitable for collection of a porous matrix sample for PCB analysis is available
at the link found at Reference 12.
For additional information on how to test for PCBs and characterize suspect materials, see Reference 13.
Indoor air samples
Samples should be collected, extracted, and analyzed by EPA Method TO-4A or TO-10A (Reference 14). Sufficient
sample volumes, as referenced in the EPA Methods, should be collected to provide a minimum laboratory reporting
limit for Total PCBs that is below the risk-based indoor air level appropriate to the use and exposure scenarios for
the building. While these are accepted analytical methods to measure PCBs in indoor air samples, there is no
broadly accepted sample design protocol for collecting PCB samples in indoor air. Accordingly, EPA is unable to
provide a generic recommendation on indoor air sample design due to the many different building-specific
situations encountered in designing a sampling plan. Development of an air sampling plan should endeavor to be as
representative as circumstances allow and factor in site-specific conditions, which EPA believes property owners or
operators are best positioned to identify in consultation with their EPA Regional PCB Coordinator.
VI. Analytical Methods for Building Materials
In this section, EPA provides an overview of the EPA methods for PCB analysis suitable for determining the presence
of PCBs in various building materials. Some of the information will be more relevant to owners/operators and other
15
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information to their contractors and labs performing the sample collection, preparation, and analysis. This section is
not meant to be comprehensive, and EPA references the appropriate source or method in each relevant section.
For analysis of samples, only laboratories that follow approved EPA analytical methodology and that have QA/QC
management programs should be used. Some states maintain publicly available databases of laboratories accredited
for specific analytical methods. For more information, see Reference 15.
The EPA SW-846 publication, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, specifies the
maximum allowed time from the point of collection to extraction and analysis of organic samples. After a sample
collection, the laboratory will extract the PCBs from the collected sample. After a sample has been collected, there
are no sample holding time limits prior to extraction for any of the PCB sample matrices listed in SW-846 (Reference
16, Table 4-1).
EPA recommends the use of Methods TO-4A orTO-lOA for air samples (Reference 14).
All samples should be analyzed by EPA SW-846 Method 8082A (Reference 17) for Aroclors 1016, 1221, 1232, 1242,
1248, 1254, 1260, 1262, 1268 and reported as Total PCBs (PCBtot). Please see Method 8082A in SW-846 for a
complete discussion on applying this analysis to PCB congeners.
Clean Water Act Method 1668C may be used with approval from EPA to quantify the 209 PCB congeners should it be
preferred based on the formulation of PCBs present in the material being analyzed per § 761.1(b)(2). This method is
not one of the determinative methods in the PCB regulations, but it may be appropriate in certain situations. This
method has very low detection limits and is more likely to experience laboratory background contamination which
could lead to data interpretation problems. The validation study for Method 1668C also does not include soil or
sediment matrices and does not identify how to report total PCBs. For use on matrices other than water, biosolids,
and tissue, the method requires verification of precision and recovery by running tests on a reference matrix. The
reference matrix must simulate, as closely as possible, the sample matrix under test (see also 40 CFR Part 761,
Subpart Q). For more information, see Reference 18.
In general, EPA SW-846 Method 8082A recommends that both extracts from solid samples and aqueous samples for
PCB analysis be analyzed within 40 days of extraction; however, PCBs are very stable in a variety of matrices and
Method 8082A notes that this timeframe is a recommendation. EPA recommends that property owners or operators
and their environmental consultants discuss this with the laboratory to meet the lab's requirements on the timeline
from sample collection to extraction and analysis.
Sample Preparation
For samples of materials such as paint and caulk, laboratories often require advanced notification of the sample
submission for laboratory preparation. The laboratory should adequately homogenize solid samples for analysis by
chopping, grinding, or cutting the sample into small pieces to increase the surface area available for extraction. If
compositing samples, the laboratory should ensure that the composite sample is equally representative of all the
individual samples being composited (i.e., equal parts by mass of each individual sample are used to make up the
composite sample).
16
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Paint and caulk textures can vary from dry and flaky samples to samples that remain pliable and are not easily
homogenized for analysis. Use the most effective technique possible for sample homogenization to achieve the
desired particle size.
Flexible Caulks and Paints
Approaches for homogenization of flexible paints or flexible caulks, to help make the sample amenable to grinding,
include:
• cutting or shredding
• adding anhydrous sodium sulfate to the sample
• cold temperature techniques such as freeze drying, dry ice-assisted grinding, liquid nitrogen shatter
box mills, or cryomilling.
Such homogenization techniques can be used in lieu of or in addition to the use of a mortar and pestle or other
grinding technique (Reference 19 - Section 7.1.4; Reference 20 - Section 8.1.2.4).
Dry Caulks and Paints
Dry, brittle caulk and dry paint can be treated similarly for sample homogenization. Grinding by using a mortar and
pestle is a commonly used technique (Reference 20 - Section 8.1.2.4).
Sample Extraction
EPA has no specified holding time limit for solid samples to be extracted for PCB analysis. However, EPA
recommends that the property owner or operator consult with the laboratory to meet the laboratory's
requirements for the timeline from sample collection to extraction.
EPA recommends the use of EPA SW-846 Method 3540C - Soxhlet Extraction (Reference 19). Method 3541 -
Automated Soxhlet Extraction (Reference 23). Method 3545A- Pressurized Fluid Extraction (Reference 24). and
Method 3546 Microwave Extraction (Reference 25). for the chemical extraction of PCBs from solid samples.1 The
PCB regulations also allow for Method 3550C (Reference 21) for wipe samples only. In addition, other extraction
methods may be used, if they are validated under Subpart Q of 40 CFR part 761.
Note that Method 3540C requires the use of methylene chloride or 10:1 toluene/methanol as the extraction solvent
for all materials other than soils/sediments or aqueous sludge samples. The property owner or operator should also
be aware that Method 3540C for solid samples can be problematic for many laboratories, either because this
extraction method is not done regularly, or because the material does not work well in the extraction. As a result,
laboratories often have to implement corrective actions or method modifications to improve efficacy. Therefore,
before testing, EPA recommends that the property owner or operator discuss these issues with the intended
laboratory to ensure it can perform this PCB extraction on solid samples to meet QA/QC objectives and
requirements. Methods TO-4A and TO-10A provide extraction methods for air samples (Reference 14). All air
samples should be extracted within one week after collection and stored at < 4°C until extracted.
1 On 29 August 2023, EPA finalized regulatory changes that include expanding the available options for extraction and determinative methods used to
characterize PCB wastes (88 FR 59662, https://www.federalreKister.Kov/docyments/2023/08/29/2023-17708/alternate-pcb-extraction-methods-and-
amendments-to-pcb-cleanup-and-disposal-reKulations).
17
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Extract Cleanup
Many of the solid material categories contain contaminants that can cause interference during the analysis. PCB
extracts often need to undergo a cleanup method to remove these contaminants. This is dependent on the
analytical method chosen to detect and quantify PCBs. For some analytical methods, the extraction method alone
may be sufficient and additional cleanup steps may not be required. Other analytical methods may require
additional cleanup steps. EPA SW-846 Method 3600C provides general guidance on the selection of cleanup
methods that are appropriate for PCBs (Reference 22). These include Method 3630C (Silica Gel Cleanup), Method
3620C (Florisil Cleanup for the separation of analytes from interfering compounds through chromatographic
techniques), and Method 3665A (Sulfuric Acid/Permanganate Cleanup for extract solvent exchange and acidic
treatment). Methods TO-4A and TO-lOA include sample cleanup steps for PCBs in ambient air (Reference 14).
Ml, 11 and ling. Storing, and Dispo.sinv. of Wastes
Manufactured PCB products and PCB impacted substrates generated during demolition or renovation activities may
be disposed of as PCB bulk product wastes or PCB remediation wastes, depending on the type of waste. Additional
information on how to dispose of these materials can be found under Abatement Step 3 at Reference 5.
VIII. Regional PCB Coordinators
Please consult with your EPA Regional PCB Coordinator should you have additional questions. A list of Regional PCB
Coordinators for your location may be found here: EPA PCB Program Contacts.
18
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IX. References
1. EPA Fact Sheet: PCBs in Building Materials - Determining the Presence of Manufactured PCB Products in
Building Materials or Other Structures, https://www.epa.gov/ocbs/ocbs-building-materials-determining-
presence-manufactured-pcb-products-buildings-or-other
2. EPA PCB in Building Materials Main Website: https://www.epa.gov/pcbs/polvchlorinated-biphenvls-pcbs-
building-materials
3. NVL Labs (2013), Rainier Commons Work Plan, https://www.epa.gov/sites/default/files/2017-
12/documents/pcb-rainier-commons-work-plan-rev072013.pdf
4. Steps to Safe Renovation and Repair Activities: https://www.epa.gov/pcbs/steps-safe-renovation-and-
repair-activities
5. Steps to Safe PCB Abatement Activities: https://www.epa.gov/pcbs/steps-safe-pcb-abatement-activities
6. Managing Stormwater and Dust at Demolition Sites: https://www.epa.gov/large-scale-residential-
demolition/managing-stormwater-and-dust-demolition-sites
7. Polychlorinated Biphenyl (PCB) Guidance Reinterpretation: https://www.epa.gov/pcbs/polvchlorinated-
biphenvl-pcb-guidance-reinterpretation
8. 2022 Construction General Permit (CGP) - Fact Sheet
https://www.epa.gov/svstem/files/documents/2022-01/2022-cgp-final-fact-sheet.pdf
9. Exposure Levels for Evaluating PCBs in Indoor School Air: https://www.epa.gov/pcbs/exposure-levels-
evaluating-polvchlorinated-biphenvls-pcbs-indoor-school-air
10. Technical Guidance for Determining the Presence of Polychlorinated Biphenyls (PCBs) at Regulated
Concentrations on Vessels (Ships) to be Reflagged: https://www.epa.gov/pcbs/polvchlorinated-biphenvls-
pcbs-ships#TechGuidance
11. Resources for Planning New Data Collections: https://www.epa.gov/ouality/resources-planning-new-
data-collections#sam
12. Standard Operating Procedure for Sampling Porous Surfaces for Polychlorinated Biphenyls (PCBs):
https://www.epa.gov/pcbs/standard-operating-procedure-sampling-porous-surfaces-polvchlorinated-
biphenvls-pcbs
13. How to Test for PCB and Characterize Suspect Materials: https://www.epa.gov/pcbs/how-test-pcbs-and-
characterize-suspect-materials
14. Test Methods for PCBs in Buildings: https://www.epa.gov/pcbs/polvchlorinated-biphenvls-pcbs-building-
materials#Test-Methods
15. Guidance for Quality Assurance Project Plans, EPA QA/G-5: https://www.epa.gov/ouality/guidance-
16. Chapter Four of the SW-846 Compendium: Organic Analytes: https://www.epa.gov/hw-sw846/chapter-
four-sw-846-compendium-organic-analvtes
17. SW-846 Test Method 8082A: Polychlorinated Biphenyls (PCBs) by Gas Chromatography
https://www.epa.gov/hw-sw846/sw-846-test-method-8082a-polvchlorinated-biphenvls-Pcbs-gas-
chromatggraehy
18. Method 1668C- Chlorinated Biphenyl Congeners in Water, Soil, Sediment, Biosolids, and Tissue by
HRGC/HRMS https://www.epa.gov/sites/production/files/2015-09/documents/method 1668c 2010.pdf
19. SW-846 Test Method 3540C: Soxhlet Extraction: https://www.epa.gov/hw-sw846/sw-846-test-method-
3540c-soxhlet-extraction
19
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20. Standard Practice for Preparation of Dried Paint Samples by Hotplate or Microwave Digestion for
Subsequent Lead Analysis, ASTM E1645-21. https://www.astm.org/el645-21.html
21. SW-846 Test Method 3550C: Ultrasonic Extraction: https://www.epa.gov/hw-sw846/sw-846-test-method-
3550c-ultrasonic-extraction
22. SW-846 Test Method 3600C: Cleanup: https://www.epa.gov/hw-sw846/sw-846-test-method-3600c-
cleanup
23. SW-846 Test Method 3541: Automated Soxhlet Extraction: https://www.epa.gov/hw-sw846/sw-846-test-
method-354l-a»tomated-soxhlet-extraction
24. SW-846 Test Method 3545A: Pressurized Fluid Extraction (PFE): https://www.epa.gov/esam/method-
3545a-sw-846-pressurized-fluid-extraction-pfe
25. SW-846 Test Method 3546: Microwave Extraction: https://www.epa.gov/hw-sw846/sw-846-test-method-
3546-microwave-extraction
20
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X. Appendix A - Example Blank Worksheets
Worksheet Instructions
General: Excel spreadsheets that mirror these worksheets are available at EPA's PCBs in Building
Materials website. These spreadsheets do much of the calculation referenced in the instructions below,
including sample size determination in lieu of using the tables from the Ship Guidance, found here. For
any assistance in modifying the Excel tools for a scenario outside the categories or limits here, please
contact the Office of Resource Conservation and Recovery PCB Team at ORCRPCBsgepa.gov.
Sampling Plan Cover Sheet - General information and conclusion proportion/probabilities
a. Complete the Building/Project Name, Owner, Date of Construction, Persons Developing the
Sampling Plan, and Date the Sampling Plan was Completed.
b. Determine the Desired Conclusion, 'X', which is the threshold specification (e.g., 50 ppm, 1 ppm, or
other). The threshold specification is independent of the statistical assurance level used for the
testing (i.e., the specification will not change the number of samples recommended for the material
category to achieve the selected confidence levels).
c. Decide on the Conclusion Probability, 'Y', which is the probability that the sampling plan will detect
PCBs in concentrations > 'X' (e.g., 90%, 95%, or 99%).
d. Decide on the Conclusion Proportion, 'Z', which is the underlying proportion of items that could
contain PCBs in concentrations > 'X' ppm. Used in conjunction with Conclusion Probability to
determine the number of samples needed to meet the following desired conclusion: "The
probability that this sampling plan would detect PCBs in concentrations > 'X' is at least 'Y' if the true
underlying proportion of materials containing them were greater than or equal to 'Z' (e.g., 10%, 5%,
or 1%).
1. Sampling Plan Worksheet 1 - Identify Categories Omitted from Testing:
a. This worksheet is intended to help you quickly eliminate categories from needing sampling where
there is available data or information about the PCB content of every item in that category.
Categories where some items may have PCBs and others may not are evaluated on Worksheet 2.
b. List all of the inventoried suspect manufactured PCB product categories present in the building and
check off the types that are determined to be omitted from sampling based on the reasons listed in
Columns A-D (e.g., records show some materials in the building recently tested negative for PCBs).
In the tables, manufactured PCB product is referred to as MPP. The categories in the example tables
below are examples of common building materials and may not reflect the categories for a
particular sampling site.
c. Count the number of categories (rows) that do not have a checkmark. That is the number of suspect
manufactured PCB product categories to test (NCT). The spreadsheet that accompanies this
guidance will calculate the NCT for you, but this value should be verified for accuracy.
2. Sampling Plan Worksheet 2 - Items That May Contain PCBs:
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This worksheet is intended to refine the suspect manufactured PCB product categories to eliminate
discrete items that are documented not to have PCBs from the need to sample (e.g., PCBs not
detected in existing analytical samples).
In Column E, list the total number of items in each suspect manufactured PCB product category. For
non-discrete material types inventoried in linear or square feet, convert to a discrete number of
items based on the supporting information for coverage of material (e.g., 1 gallon of paint covers
400 ft2; a property owner may choose to treat every 400 square feet of similarly colored painted
surface as one item of paint when developing the discrete number of painted items in the
inventory).
If any of the items in Column E can be omitted from sampling (e.g., using existing analytical
samples), write that number in Column F.
If any items in Column E can be omitted due to documented year and place of manufacture or
installation, write that number in Column G.
Subtract Columns F and G from E to determine the size of the population of items in each suspect
manufactured PCB product category that may contain PCBs above the desired threshold
concentration. The number in Column H is the size of the sampling frame (i.e., the lot size for a
manufactured PCB product category which includes every item in that manufactured PCB product
category that might contain PCBs) and the size of the population from which testing will occur. This
column is calculated automatically by the accompanying spreadsheet.
3. Sampling Plan Worksheet 3 - Calculate Sample Sizes to Support Conclusion:
a. Divide H by E and record the ratio in Column I. This is the proportion of items in the suspect
manufactured PCB product material category for which there is no available data or information
about the PCB content of the items.
b. In Column J, use Tables 11-1 to 11-14 from the Ship Guidance to determine the number of samples
based on the NCT from Sampling Plan Worksheet 1. The tables from the Ship Guidance include
calculations for NCT up to 14, and the Excel spreadsheet will calculate the sample size for NCT up to
18. The sample sizes corresponding to a Y% conclusion probability and 1% conclusion proportion are
entered in Column J. If the sample size noted in the table is "ALL," then write "ALL" in Column J. If
the sample size in the table exceeds the number in Column E, then write "ALL" in Column J and test
all of the items. This indicates that for that suspect manufactured PCB product material category, all
items should be tested (i.e., census testing). If the coversheet in the spreadsheet tool is completed
with the conclusion probability and the conclusion proportion, spreadsheet column J will
automatically update with the sample size based on the statistical distribution.
c. Multiply the number in Column J by the number in Column I. If the result is a whole number, record
it in Column K. If the result is not a whole number, round it up to the next whole number and record
it in Column K. (This is the step that gives credit for results already obtained via available data or
information for the suspect manufactured PCB product material category. The only items that
remain to be tested are those for which there is no available data or information about the PCB
content of the items in the suspect manufactured PCB product material category.)
4. Sampling Plan Worksheet 4 - Revise Sample Sizes Downward Due to Censuses:
b.
c.
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In order to account correctly for sampling uncertainty in multiple suspect manufactured PCB
product categories, the worksheets make a statistical correction for testing across multiple suspect
manufactured PCB product categories and to provide the desired level of confidence. The NCT is
reduced by the number of suspect manufactured PCB product categories where all items should be
tested.
Column L identifies those suspect manufactured PCB product categories where all items will be
tested. Enter a checkmark here if J is "ALL" or if K > H or if K is close enough to H that you wish to
test all items in H to reduce the number of suspect manufactured PCB product categories for
sampling (NCS). Column L in the spreadsheet will auto-populate with an "X" if K=H.
The NCS is the NCT minus the number of suspect manufactured PCB product Categories for Census
Testing (NCC = number of checkmarks in Column L). Column M then uses the resulting NCS and Ship
Sampling Table II- "NCS" to determine the final sample size for the suspect manufactured PCB
product category. This column is automatically calculated in the spreadsheet based on a statistical
distribution.
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Sampling Plan Cover Sheet
Building/Project Name:
Owner:
Date of Construction:
Persons Developing the Sampling Plan:
Date the Sampling Plan Was Completed:
Desired Conclusion: "The probability that this sampling plan would detect PCBs > X ppm is at least(select a
value for probability: e.g., 90%, 95%, or 99%) if the true underlying proportion of materialscontaining them
were greater than or equal to (select a proportion: e.g., 10%, 5%, or 1%)."
Write the Conclusion Probability here (e.g., 90%, 95%, or 99%): Y
Write the Conclusion Proportion here (e.g., 10%, 5%, or 1%): Z
24
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Sampling Plan Worksheet 1 - Identify Categories Omitted from Testing
Omitted from PCB Testing
In each row, place a checkmark in columns A-D if appropriate.
There is
noneof
this
material
in the
building.
Every item is
documented to
have PCB
concentrations
-------
Sampling Plan Worksheet 2 - Items That May Contain PCBs > X ppm
Not Omitted from PCB Testing
Cross Out Rows That Have A Checkmark on Worksheet #1
Population:
Total number
of items in
this suspect
MPP category
in the building.
Number that
aredocumented
to have PCB
concentrations
-------
Sampling Plan Worksheet 3 - Calculate Sample Sizes to Support Conclusion
Sample Size for PCB Testing
Cross Out Rows That Have A Checkmark on Worksheet #1
Proportion of items in this
suspect MPP category for
which results are not
currently known
(1 = H/E)
Sample SizeBased
on NCT
(Ship Guidance
Table ll-NCT starts
on page 90)
Preliminary expected
number of suspect MPP
items that will need to be
tested
(K = J x 1)
Suspect MPP Category
1
J
K
Paint, varnishes, lacquers
Non-conducting materials in
electrical cables
Rubber/felt gaskets
Coal-tar enamel coatings and
rust inhibitor coatings
Insulation material including
fiberglass, felt, foam, and cork
Adhesives and tapes
Caulking and grout
Rubber isolation mounts,
foundationmounts, and
pipe
hangers
Plastic applications (vinyl and
PVC)
Galbestos siding
Mastics
Acoustic ceiling and floor tiles
Structural joint material
Asphalt roofing and tar paper
Synthetic resins and floor
varnish
Sprayed on fireproofing
Other materials
Copy Number of Categories to Test (NCT) from Worksheet 1:
27
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Sampling Plan Worksheet 4 - Revise Sample Sizes Downward Due to Censuses
Sample Size for PCB Testing
Cross Out Rows That Have a Checkmark on Worksheet
#1
Enter a checkmark here if J is "ALL" or if K > H
Sample sizebased on
or if K is close enough to H that you wish to
NCS
test all items in H to reduce thenumber of
(Ship Guidance Table
suspect MPP categories for sampling (NCS)
ll-NCS)
Suspect MPP Category
L
M
Paint, varnishes, lacquers
Non-conducting materials in electrical
cables (such as plastic and rubber)
Rubber gaskets
Felt gaskets
Coal-tar enamel coatings (e.g., pipe
coating) and rust inhibitor coatings
Insulation material including fiberglass,
felt, foam, and cork (not including
electrical cable insulation, but including
sound deadening felt)
Adhesives and tapes
Caulking and grout (including putty,
silicon, window glazing, and bitumen)
Rubber isolation mounts, foundation
mounts, and pipe
hangers
Plastic applications (including vinyl and
PVC)
Galbestos siding
Mastics
Acoustic ceiling and floor tiles
Structural joint material
Asphalt roofing and tar paper
Synthetic resins and floor varnish
Sprayed on fireproofing
Other materials
Copy Number of suspect MPP Categories to Test (NCT) from Worksheet 1:
Count the checkmarks in column L
The sum of checkmarks is the Number of suspect MPP Categories for Census Testing (NCC):
Subtract NCC from NCT; this is the Number of suspect MPP Categories to Sample (NCS):
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XI. Appendix B - Example Building Scenario
A property owner plans to renovate a multiroom and multilevel building. The property owner wishes to determine
the presence of manufactured PCB products by testing. The building owner is interested in knowing whether PCBs
are present greater than or equal to a threshold of 50 ppm.
Step 1 - Review Building Records
A review of the building history and available building records show that the building was constructed in 1960 and
underwent renovations in certain areas in the late 1980s.
Step 2 - Compile Inventory
The property owner performs a walkthrough of the building to conduct a visual inspection and develops an
inventory that identifies all building materials that could potentially be manufactured PCB product (Table 1) or could
be contaminated from contact with PCB containing material. In the tables, manufactured PCB product and
potentially contaminated product are referred to as "MPP." The suspect manufactured PCB product categories are
grouped by those materials that were evaluated to be similar and likely to be homogenous based on available
information. The inventory columns provide additional descriptive information for each suspect manufactured PCB
product category including color, number of rooms containing the material, approximate total quantities of the
material by the individual number of units (discrete), in total linear feet, or total square footage. The inventory also
notes whether enough information is available in the building records to confidently exclude the suspect
manufactured PCB product category from the need to sample (e.g., known post-1979 manufacture).
Table 1 - Building #101 Inventory
Susoect manufactured
or contaminated PCB
oroduct Category
Color
Floor
Number
of Rooms
Approximate
Total Quantity
Units
Documented
Post-1979
Manufacture.
Installation, or
not present
(Exclude)
Suspended Ceiling Tile A
White
Multiple
14
1475
Sq Ft
No
Gypsum Wall Board A
White
Multiple
19
6359
Sq Ft
No
Carpet Mastic
Brown
Multiple
8
3239
Sq Ft
No
Thermal System
Insulation
Yellow
Multiple
12
25
Discrete
No
Spray-On Insulation
Beige
Multiple
11
2903
Sq Ft
No
Vinyl Floor Tile
Gray
Multiple
17
5556
Sq Ft
Yes
Mastic
Gray
Multiple
17
3276
Sq Ft
No
Paint
Beige
Multiple
65
24,800
Sq Ft
No
Covebase
Black
Multiple
22
53
Sq Ft
Yes
Suspended Ceiling Tile B
White
Multiple
42
16645
Sq Ft
Yes
Replacement Window
Caulking
White
Multiple
38
1441
Lin Ft
No
29
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Flue Connector
White
2nd
2
15
Discrete
No
Adhesive
Light
Green
Multiple
7
832
Sq Ft
No
Sink Undercoating A
Tan
Multiple
2
6
Discrete
No
Suspended Ceiling Tile C
White
2nd
4
701
Sq Ft
No
Sink Undercoating B
Gray
Multiple
4
16
Sq Ft
Yes
Fire Stop Caulk
Red
Multiple
3
135
Lin Ft
No
Gypsum Wall Board B
White
Multiple
16
2532
Sq Ft
Yes
Expansion Joint Caulking
Gray
Multiple
25
455
Lin Ft
No
Dust Seam Sealant
Gray
3 rd
1
3
Sq Ft
Yes
The property owner also created a table (Table 2) to provide additional descriptive information on the inventoried
suspect manufactured PCB product categories. This table contains information that can be used to perform a
conversion of linear or square foot inventoried suspect manufactured PCB product categories to represent discrete
items for the purposes of sampling. It also provides descriptive information on the adjacent substrate materials.
Table 2 - Material Descriptive Information
Material Catego
Material Description
Substrate Ty
Suspended Ceiling Tile A
4 ft2 square tile
-
Gypsum Wall Board A
Standard 4' x 8' Wallboard
-
Carpet Mastic
Assume 200 ft2 per gallon coverage
Concrete
Thermal System Insulation
Mudded pipe joint insulation
Metal
Spray-On Insulation
Assume 200 ft2 per insulation kit
Concrete
Vinyl Floor Tile
9" dark gray with white streaks
Concrete
Mastic
Assume 30 ft2 per gallon coverage
Concrete
Paint
Oil Based (400 ft2 coverage per gallon)
Concrete
Covebase
4" black (original)
Concrete
Suspended Ceiling Tile B
4 ft2 Deep Fissures
-
Replacement Window
Caulking
Metal casing to Concrete (assume 10
linear ft per discrete item)
Metal and Concrete
Flue Connector
Duct Seam Sealant
Metal
Adhesive
Assume 100 ft2 per gallon coverage
Concrete
Sink Undercoating A
Metal sink to formica counter
Metal to Formica
Suspended Ceiling Tile C
8 ft2 tile
-
Sink Undercoating B
Metal sink to soapstone counter
Metal to Soapstone
Fire Stop Caulk
Metal doorframes (assume 10 linear
ft per discrete item)
Metal
Gypsum Wall Board B
Newer, type 2
-
Expansion Joint Caulking
Concrete Masonry Unit (CMU) to CMU
(assume 10 linear ft per discrete item)
Concrete
30
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Dust Seam Sealant
Metal ductwork
Metal
Step 3 - Develop Sampling Plan
The property owner decides to perform statistical acceptance sampling. The property owner desires that the
probability that the sampling plan will detect PCBs is at least 95% if the true underlying proportion of materials
containing them were greater than or equal to 5%. The property owner determines the number of samples needed
from each suspect manufactured PCB product category to achieve that desired conclusion using the worksheets
presented in Appendix A and the Sample Sizes for Sampling Plans Tables from the Ship Guidance (Appendix II.F).
Step 4 - Determine Distribution of Samples and Perform Testing
Table 3 presents the sample sizes determined from the worksheets versus the number of adjusted individual items
in the suspect manufactured PCB product category calculated in Column E of worksheet 2. The property owner
should distribute the number of samples required for the suspect manufactured PCB product category across the
number of locations where the material is present in the building (e.g., number of rooms). Using the Suspended
Ceiling Tile in Table 3 as an example, if the 14 rooms each contain an equal number of tiles, the 77 samples can be
equally distributed between the 14 rooms (77 4-14 = ~ 6 samples per room).
Table 3 - Sample Size per Suspect manufactured PCB product Category
Suspect manufactured PCB
product Category
Number
of
Rooms
Approximate
Total
Quantity
Units
Adjusted
Individual
Items
Number of
Samples
from
Worksheets
Floor
Suspended Ceiling Tile A
14
1475
Sq Ft
184
77
Multiple
Gypsum Wall Board A
19
6359
Sq Ft
199
77
Multiple
Carpet Mastic
8
3239
Sq Ft
16
16
Multiple
Thermal System Insulation
12
25
Discrete
25
25
Multiple
Spray-On Insulation
11
2903
Sq Ft
15
15
Multiple
Mastic
17
3276
Sq Ft
109
77
Multiple
Paint
65
24,800
Sq Ft
62
53
Multiple
Replacement Window
Caulking
38
1441
Lin Ft
144
77
Multiple
Flue Connector
2
15
Discrete
15
15
2nd
Adhesive
7
832
Sq Ft
8
8
Multiple
Sink Undercoating A
2
6
Discrete
6
6
Multiple
Suspended Ceiling Tile C
4
701
Sq Ft
88
62
2nd
Fire Stop Caulk
3
135
Lin Ft
14
14
Multiple
Expansion Joint Caulking
25
455
Lin Ft
46
40
Multiple
31
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Sampling Plan Cover Sheet
Building/Project Name: Building #101
Owner: James Shew
Date of Construction: 1960
Persons Developing the Sampling Plan: ABC Consultants
Date the Sampling Plan Was Completed: October 2021
Desired Conclusion: "The probability that this sampling plan would detect PCBs > 50 ppm is at Ieast95% if the
true underlying proportion of materials containing them were greater than or equal to 5%."
Write the Conclusion Probability here: (e.g., 90%, 95%, or 99%): 95%
Write the Conclusion Proportion here: (e.g., 1%, 5%, or 10%): 5%
32
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Sampling Plan Worksheet 1 - Identify Categories Omitted from Testing
The property owner lists the inventoried suspect manufactured PCB product categories from Table 1 and, in Column
C, checks off the types that the property owner has determined to exclude from sampling based on building records.
Omitted from PCB Testing
In each row, check one (A-D) if appropriate
Every item can be
Every item can
There is
noneof this
material in
the
building.
Every item is
documented
assumed to have PCB
concentrations
either be
documented or
to have PCB
concentrations
< 50 ppm due to
documented yearand
assumed to have
PCB
<50 ppm.
place of manufacture
or installation.
concentrations
<50 ppm.
Suspect MPP Category
A
B
C
D
Suspended Ceiling Tile A
Gypsum Wall Board A
Carpet Mastic
Thermal System Insulation
Spray-On Insulation
Vinyl Floor Tile
V
Mastic
Paint
Covebase
V
Suspended Ceiling Tile B
V
Replacement Window Caulking
Flue Connector
Adhesive
Sink Undercoating A
Suspended Ceiling Tile C
Sink Undercoating B
V
Fire Stop Caulk
Gypsum Wallboard B
V
Expansion Joint Caulking
Dust Seam Sealant
V
Count the number of categories (rows) that do not have a checkmark. That is the Number of suspect MPP
Categories to Test (NCT). Copy it into the appropriate location on Worksheet 3. 14 (NCT)
33
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Sampling Plan Worksheet 2 - Items That May Contain PCBs
In Column E, the property owner lists the total number of items in each suspect manufactured PCB product
category. For non-discrete suspect manufactured PCB product categories where the total number of items listed in
Table 1 were in linear or square feet, the example shows the calculation made to convert to a discrete number of
items based on the information presented in Table 2. Because none of the suspect manufactured PCB product
categories listed can be further eliminated from sampling based on available PCB information (Columns F & G), the
total number of items is carried over to Column H.
Not Omitted from PCB Testing
Rows That Have No Checkmark on Worksheet #1
Number that
can be
Sampling Frame:
assumed to
Total number of
have PCB
items in this suspect
Number that
concentrations
MPP category that
are
< 50 ppm
cannot be
Population: Total
documented to
due to
documented or
number of items in this
have PCB
documented
assumed to have
suspect MPP category
concentrations
year and
PCB
in the building.
<50 ppm
place of
concentrations <50
manufacture
ppm.
or
(H = E - F - G)
installation.
Suspect MPP Category
E
F
G
H
Suspended Ceiling Tile A
1475 ft2 t- 4 ft2/tile = 184
184
Gypsum Wall Board A
6359 ft2 ¦+ 32 ft2/board = 199
199
Carpet Mastic
3239 ft2 ¦+ 200 ft2 = 16
16
Thermal System Insulation
25
25
Spray-On Insulation
2903 ft2 + 200 ft2 = 15
15
Mastic
3276 ft2 ¦+ 30 ft2 = 109
109
Paint
24,800 ft2 t- 400 ft2 = 62
62
Replacement Window Caulking
1441 ft ¦+ 10 ft = 144
144
Flue Connector
15
15
Adhesive
832 ft2 ¦+ 100 ft2 = 8
8
Sink Undercoating A
6
6
Suspended Ceiling Tile C
701 ft2 ¦+ 8 ft2 = 88
88
Fire Stop Caulk
135 ft 10 ft = 14
14
Expansion Joint Caulking
455 ft + 10 ft = 46
46
34
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Sampling Plan Worksheet 3 - Calculate Sample Sizes to Support Conclusion
In Column I, the proportion of total items where PCB presence is unknown could be adjusted if some of the
materials from Worksheet 2 would have been further eliminated from sampling consideration based on available
PCB information. Since no such adjustment could be made, the proportion is 1 (or 100% of total items have
unknown PCB content).
In Column J, the property owner uses Tables 11-1 to 11-14 from the Ship Guidance Appendix ll-F to determine the
number of samples based on the Number of Categories to Test (NCT) from Sampling Plan Worksheet 1. For NCT =
14, Table 11-14 is used and the sample sizes corresponding to a 95% conclusion probability and 5% conclusion
proportion are entered in Column J. Because the proportion in Column I is 1, the same sample size is carried through
to Column K. Note that the sample size from Table 11-14 is larger than the total number of material items available
for some material types like the spray on-insulation (i.e., Column K is greater than Column H). This indicates that for
that material type, all items should be tested (i.e., census testing).
Sample Size for PCB Testing
Cross Out Rows That Have A Checkmark on Worksheet #1
Proportion of items in this
95%/5% Sample
Preliminary expected
suspect MPP category for
SizeBased on
number of suspect MPP
which results are not
NCT = 14
items that will need to be
currently known
(Ship Guidance
tested
(1 = H / E)
Table 11-14)
(K = J x 1)
Suspect MPP Category
1
J
K
Suspended Ceiling Tile A
184/184 = 1
85
85
Gypsum Wall Board A
199/199 = 1
85
85
Carpet Mastic
16/16 = 1
28
28
Thermal System Insulation
25/25 = 1
28
28
Spray-On Insulation
15/15 = 1
28
28
Mastic
109/109 = 1
85
85
Paint
62/62 = 1
42
42
Replacement Window Caulking
144/144 = 1
85
85
Flue Connector
15/15 = 1
28
28
Adhesive
8/8 = 1
28
28
Sink Undercoating A
6/6 = 1
28
28
Suspended Ceiling Tile C
88/88 = 1
67
67
Fire Stop Caulk
14/14 = 1
28
28
Expansion Joint Caulking
46/46 = 1
42
42
Copy Number of Categories to Test (NCT) from Worksheet 1: 14
35
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Sampling Plan Worksheet 4 - Revise Sample Sizes Downward Due to Censuses
In order to account correctly for sampling uncertainty in multiple categories of materials, the Worksheet 4
instructions have the property owner make a correction for testing across multiple categories and to provide the
desired level of confidence. The NCT is reduced by the number of suspect manufactured PCB product categories
where all items should be tested. Column L identifies those suspect manufactured PCB product categories where all
items will be tested. The Number of Categories to Sample is the NCT (14) minus the number of census testing
categories (7). Column M then uses the NCS of 7 and Table 11-7 in the Ship Guidance to determine the sample size
for the category.
Sample Size for PCB Testing
Deleted Rows That Have A Checkmark on Worksheet
#1
Enter a checkmark here if J is "ALL" or if K > H or if
Sample sizebased
K is close enough to H that you wish to test all
on NCS = 7
items in H to reduce the number of suspect MPP
(Ship Guidance
categories for sampling (NCS)
Table 11-7)
Suspect MPP Category (Discrete Units)
L
M
Suspended Ceiling Tile A (184)
77
Gypsum Wall Board A (199)
77
Carpet Mastic (16)
V
16
Thermal System Insulation (25)
V
25
Spray-On Insulation (15)
V
15
Mastic (109)
77
Paint (62)
53
Replacement Window Caulking (144)
77
Flue Connector (15)
V
15
Adhesive (8)
V
8
Sink Undercoating A (6)
V
6
Suspended Ceiling Tile C (88)
62
Fire Stop Caulk (14)
V
14
Expansion Joint Caulking (46)
40
Total Samples: 562
Copy Number of Categories to Test (NCT) from Worksheet 1: 14
Count the checkmarks in column L; the sum is the Number of Categories for Census Testing (NCC): 7
Subtract NCC from NCT; this is the Number of Categories to Sample (NCS): 7
36
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