3. Renovation

This section is based on renovation work subject to article 13 of the Statutory Order on Waste (Ministry of the Environment, 2012) (see Section 7, Waste Management). Renovations do not necessarily comprise abatement of excessive PCB exposure levels in indoor air (see Section 2, Remediation).

The section describes the renovation process form the building owner’s perspective. The basic planning steps range from the early stage where suspected PCB contamination is confirmed until the renovation is implemented. The process is described as a typical sequence of events involving certain stages, but other sequences exist.

The provisions in the Statutory Order on Waste (Ministry of the Environment, 2012), including screening, mapping, and notification of waste are described in SBi Guidelines 241, Survey and Assessment of Building-Related PCBs (Andersen, 2015).

Renovating old buildings containing PCBs will generate waste, which must be separated and classified. Waste containing PCBs must be separated out from recoverable CDW. Separating out materials containing PCBs will often be done before or in connection with the removal of building materials and structures. How this renovation process evolves will, for example, depend on:

the quantity of PCBs in building materials,
the location of PCB-contaminated materials,
the type, condition, and function of the building.

Methods for removing PCBs are described in Section 5.1, Physical Removal. Renovation may also include other interventions than physical removal (see Section 2.2, Principles of Remediation, and Section 5, Remediation Methods).

Costs associated with separating out PCB from CDW must be viewed in relation to the financing of the building, its future function, and lifespan. If the building is demolished, waste containing PCBs must also be separated out.

Special considerations in relation to the working environment, user protection, and the outside environment will, in part, determine the method and cost of removing materials containing PCBs. This applies to the individual interventions and to the project as a whole (e.g., waste disposal).

The duties of building owners relative to safety and waste management in a building contaminated by PCBs are described in Section 6, Protecting People and the Environment and Section 7, Waste Management.

The duties of other actors, including quality assurance, are not described in detail, but are subject to best management practice in the trade, to Bekendtgørelse om kvalitetssikring af byggearbejder (Statutory Order on Quality Assurance of Construction Work) (Ministry of Business Affairs, 2010), and to Vejledning om kvalitetssikring i byggeriet (Guidelines on Quality Assurance in Construction Work) (Ministry of Transport and Housing, 2001).

3.1 Key Elements of the Renovation Process

Table 10 compares typical phases in a renovation process with the activities necessary when the renovation generates PCB-contaminated waste. The phases shown exemplify a process description based on the ABR89 phase model (bips, 2006).

Identification, investigation, and assessment of PCBs in the building are described in SBi Guidelines 241, Survey and Assessment of Building-Related PCBs (Andersen, 2015) and this part of the process is integral to the phases of initiation and programme.

Table 10. Key elements of a renovation project generating PCB-contaminated waste.

Phases	PCB-specific activities	PCB-specific results
Initiation	Building owner: – learns that the building is suspected of PCB contamination due to its construction year or due to renovation activities carried out during the period 1950–1977. – engages expert	Completed screening form
Initiation	– engages expert
Programme	Expert: – implements a visual inspection and preliminary and follow-up mapping of PCBs in materials to be removed from the building. – assesses the extent of the problem and prepares possible renovation strategies and financial estimates. – assesses how to remove the contaminated materials or building parts and consults local authority guidelines on separating out and classifying materials containing PCBs.	CDW notified, and mapping report(s) attached to the notification
	Building owner: – considers plan for maintenance and renovation, future function of the building, mitigation effect on the operations of the building, safety issues, preparing behavioural guidelines for occupants or staff in the building (if applicable). – assesses whether to implement an investigation of indoor air (see Section 2, Remediation and SBi Guidelines 241, Survey and Assessment of Building-Related PCBs (Andersen, 2015)).
Proposals	Building owner: – makes decision in principle on methods of separating out, e.g., based on the extent of the PCB problem, the future operational function of the building, and estimated costs.	Decision in principle
	– if required, draws up plan for rehousing occupants.	Rehousing plan
	Expert draws up mitigation project proposal.	Project proposal
	Building owner approves project proposal.	Project proposal approved
Project	Expert draws up detailed renovation project, including plan for risk management.	Key project
Invitation to tender	Expert prepares tender material with specific requirements for handling health and safety issues, waste, and the outside environment.	Tender material
Invitation to tender	Building owner offers for tender and selects contractor.	Contract
Operational planning	Contractor plans abatement in detail.	Work and time schedule
Operational planning	Building owner applies for building permission and notifies waste to the local authority.	Application for building permission and notification of CDW
Execution	Contractors start renovation work.
Execution	Building owner checks the renovation work carried out. Often, an expert will supervise the work on behalf of the building owner.	Monitoring documentation
Occupancy	Documentation on specific issues relative to future renovation or demolition work and PCBs is completed.

3.2 Planning

When the occurrence of PCB in a building facing renovation has been confirmed, the ensuing work may generate waste containing PCBs. According to the Statutory Order on Waste, PCB-contaminated material removed from buildings during renovation must be sorted, classified (as hazardous waste, waste suitable for landfill, incineration, or recovery), and PCBs must be separated out from materials for recovery (see Section 3.2.3, Waste Containing PCBs and Section 7, Waste Management).

Consideration should therefore be given to the following:

Follow-up mapping of PCB contamination in the building, including the extent and type of contamination
Renovation methods for physically removing, modifying, or encapsulating PCBs
Waste handling
Cost estimation

Furthermore, the presence of PCBs may necessitate investigations into whether PCB exposure levels in the building’s indoor air are excessive and whether renovation work may result in elevated PCB exposure levels in the indoor air.

If there are internal caulked joints with excessive PCB content, there will very likely be a problem with PCBs in the indoor air (see SBi Guidelines 241, Survey and Assessment of Building-Related PCBs, 1 PCBs – properties and applications (Andersen, 2015)). External caulked joints containing PCBs might complicate exterior re-insulation work, as the joints will be located inside the new climate envelope and new insulation. In this way, they may contribute to penetration of PCBs to the indoor air. Furthermore, materials may be contaminated by PCBs, thus complicating later renovation or demolition.

When establishing a new ventilation system, attention should be given to any changes in pressure and whether this might affect sources and indoor air (see Section 5.6, Ventilation).

When covering balconies in buildings with exterior grout containing PCBs, consideration must be given to the possible consequences of altered airflow to avoid PCB penetrating to the indoor climate, and possible contamination of materials.

Removal of PCB and handling PCB-contaminated waste should be considered an integral part of removal and management of any other environmentally harmful substances in the building. A screening should therefore be conducted by the building owner and, if relevant, a follow-up mapping of other problematic substances (such as lead and asbestos). Screening may be done using the year of construction, renovation history, and choice of materials.

3.2.1 Mapping

When renovating, screening and mapping should have been conducted of the entirety or part of the building in question. Building owners have a duty to observe article 13 of the Statutory Order on Waste (Ministry of the Environment, 2012). This is described in Section 7, Waste management and in SBi Guidelines 241, Survey and Assessment of Building-Related PCBs, 3 Surveys prior to renovation or demolition (Andersen, 2015).

When the initial mapping with chemical analyses of PCBs in material samples confirms suspected PCB contamination, a follow-up mapping procedure is performed to provide an overview of the extent of the contamination. The mapping will be based on the building materials identified as the primary sources of the PCB contamination together with the secondary and tertiary sources relevant to the renovation in question. It may be that the renovation of wet rooms in a block of flats is necessary, in which case building materials with PCB content used in wet rooms would be the focus of attention (see SBi Guidelines 241, Survey and Assessment of Building-Related PCBs, 5 Mapping the building materials (Andersen, 2015)). There should be clarity as to which PCB-contaminated materials to remove from the building, so that the handling of waste can be conducted appropriately (see Section 3.2.3, Waste Containing PCBs).

If, during a visual inspection, fluorescent light ballasts with capacitors potentially containing PCBs are discovered, it is advisable to either remove the capacitors or determine that they do not contain PCBs. The Danish EPA recommends that capacitors or ballasts containing PCBs be replaced (Danish EPA, 2015) because they might leak PCBs. Likewise, the Danish EPA (2015) recommends that fluorescent light ballasts from the period 1950–1986 be not stored or reused without investigating whether the ballasts contain capacitors with PCBs.

The Danish EPA has published guidelines on handling fluorescent light ballasts with capacitors containing PCBs (Danish EPA, 2015) (see SBi Guidelines 241, Survey and Assessment of Building-Related PCB, 5.2.4 PCB in capacitors (Andersen, 2015)).

If signed contracts are based on AB92 (Ministry of Housing and Transport,1992), the tender material must contain information about previous investigations (e.g., contamination). If the information supplied in the tender material is found to be inadequate, building owners may have to pay a contractor for the extra work involved. PCBs are considered a significant risk which may have a considerable economic bearing demolition processes.

3.2.2 Strategy for Renovating Buildings Containing PCBs

Consideration should be given to methods of removing the PCB-contaminated materials as well as methods of separating out PCBs from generated waste suitable for recovery.The choices should accommodate concerns relating to the working environment, protecting building occupants, and the exterior environment.

The evaluation of methods for the removal of materials containing PCBs include rough estimates of:

costs associated with each of the renovation strategies outlined (including follow-up mapping of materials to be removed from the building)
the time associated with realising the renovation strategies outlined
implications for building occupants, including an assessment of which parts of the building should be vacated and for how long

To outline relevant strategies for removal of materials containing PCBs and the associated financial estimates, the evaluation should address the structural conditions and the location of PCBs in the building (see SBi Guidelines 241, Survey and Assessment of Building-Related PCBs, 5 Mapping the building materials (Andersen, 2015)). Depending on the specific case, it might be relevant to consider the following questions:

Are facade structures light- or heavy-weight?
Are some of the PCB sources concealed behind panels, flashings, partition walls, or floors?
What types of ceiling or floor finishes exist and are they easy to remove?
How are power cables and ventilation ducts placed?
Which materials adjoin the PCB-containing caulk or other primary PCB sources – wood, clay tiles, or concrete?
How many metres of caulk or grout require removal?
Is it possible to cut out materials adjacent to caulked or grouted joints?
What is the size of the surface area that requires cleaning?
Is there any exterior caulk containing PCB that needs removing?
Are there any fluorescent light ballasts with capacitors that might contain PCBs?
What are the costs of handling and disposing of the PCB-contaminated waste?

When removing building materials containing PCBs, renovation work will usually also comprise other environmentally harmful substances, typically lead. The choice of method will therefore be conditional on several issues, including:

The extent and character of the contamination of floor finish, walls, and other surface areas
Wall thickness and cut-out distance when removing concrete and clay tiles from contaminated caulked joints, windows, etc.
Removing tiles, paving, etc.
Use of PPE, including periods of occupancy, limited working hours, etc.– Measures to limit the spreading of PCBs to the surrounding environments (e.g., containment tunnels, partition walls, and ventilation systems)
Production of PCB-contaminated waste during renovation work (e.g., sand from sandblasting and rubble form manual trimming)
Collection and handling of renovation waste
Possibilities of ongoing control of the renovation work carried out.

When comparing the methods, it is worth remembering that high-pressure blasting will only clean to a limited depth while cleaning to greater depths requires milling or physical removal of large structural parts.

Furthermore, please note:

Accumulation of waste products when removing PCBs in multi-storey residential buildings may result in critical structural loads.
Physical removal of large parts of the structure may be critical to static properties and bracing the structure may be required prior to removal.

3.2.3 Waste Containing PCBs

According to the Statutory Order on Waste, PCB-contaminated material removed from buildings must be sorted, classified, and PCBs must be separated out from recoverable materials. Both private actors and waste-generating enterprises have a duty to separate out hazardous waste, waste containing PCBs, and sealed insulating glazing units (see Section 7.3, Sorting Construction and Demolition Waste with PCBs).

Materials are classified based on the measured PCB concentrations and in accordance with local authority guidelines on disposal. The local authority decides whether the waste is hazardous, suitable for recovery, for incineration, or for landfill (see Section 7.4, Classifying Waste).

In consultation with the local authority, early in the process the building owner will have to assess which materials to remove PCBs from and which technique to apply when removing or cleaning the materials. Once the waste has been classified, the weight of the building materials in each class must be assessed. This is an integral part of notifying the waste to the local authority (see SBi Guidelines 241, Survey and Assessment of Building-Related PCBs, 3 Surveys prior to renovation or demolition (Andersen, 2015)). Hazardous waste with a PCB content larger than 50 mg/kg is classified separately (see Section 7, Waste Management).

It may be a very resource-intensive and complicated task to separate out PCB-containing paint from painted materials, for example. This is true regardless of whether the paint containing PCBs is a primary, secondary, or tertiary source. Working environmental considerations and for the protection of the outside environment may influence choices made. Methods for physically removing PCB-containing materials are described in Section 5.1, Physical Removal.

3.2.4 Financial Estimates

The evaluation of methods for the removal of PCBs includes rough estimates of:

costs associated with each of the PCB removal strategies outlined, including full mapping of materials to be removed from the building
the time factor associated with realising the strategies outlined for PCB management
implications for building occupants, including an assessment of which parts of the building should be vacated and for how long.

Rough estimates of costs associated with each of the renovation strategies outlined are drawn up.

The following factors may have economic implications for the removal of material containing PCBs and for waste management:

costs associated with waste separation, including making the working environment safe
concealed deposits of PCB-contaminated materials
time associated with waste separation
implications for building occupants (if applicable)
special concerns for neighbours and the surrounding environment.

Additionally, an assessment is made of the costs associated with managing and disposing of the PCB-contaminated waste.

3.2.5 Experience-based Price Estimates

Experience-based price estimates have been collected from several Danish cases during the period 2010–13, involving the handling of building-related PCBs (Grontmij & COWI,2014). Data from demolitions, renovations, or conversions were collected from interventions to abate excessive concentrations of PCBs in indoor air. The experience-based price estimates include all contractor costs associated with removal of specific building parts containing PCBs and the implementation of the project, including the disposal of PCB-contaminated waste, health and safety measures, clean-up, etc. Furthermore, the estimates obtained also include the costs of reconstructing affected building parts, such as fitting new windows and doors as part of the abatement intervention.

Practical Tasks

Data has been obtained on a series of practical tasks, including the removal of caulk, brickwork and concrete work, windows and doors, floor finishes, paint and wallpaper, and encapsulation using silicate coating. Unit prices for individual work processes vary greatly. For most work processes, there is a satisfactory correlation between unit price and quantity, but other issues are believed to have a considerable effect on unit prices. Issues such as tender framework,type, and size of the project, and quantities and occurrences of other environmentally harmful substances in the building. In addition to these, there are physical conditions, access to the workplace, the quality of the preliminary work done by the building owner; including the preparation of preliminary investigations and tender material, as well as measures concerning the building occupants if the building is not vacated while the work is being carried out (Grontmij & COWI, 2014).

There are examples of quotations for milling, sandblasting, or steel re-jetting for stripping paint on concrete containing PCBs. Price levels and quantities of waste varied considerably (Olsen & Olesen, 2015).

3.2.6 Risk Management

The following risks should be considered in the planning phase when renovating a building containing PCBs:

Presence of significant quantities of unforeseen levels of PCB contamination (e.g., concealed in the structure)
Incidents with implications for the health and safety of staff working at the site as well as for residents in and around the building
Critical delays in the schedule
Any kind of extraordinary cost critical to the budget.

It is advisable to prepare a list of all conceivable critical incidents with an assessment of the likelihood of individual incidents occurring and the consequences arising from these incidents.

A list of critical incidents should also contain a brief plan for how to mitigate such incidents and their effects (see Introduktion til Risikostyring i Byggeriet – erfaringer og anbefalinger (Introduction to Risk Management in the Construction Sector) (Falk, 2006)).

3.3 Evaluating the Draft Design

Renovating a building containing PCBs can be extensive, expensive, and time-consuming. The building owner should make a systematic assessment as to how the renovation fits into the overall plans the owner might have for the property.

Several issues should be assessed:

Long-term plans for the building. Renovation activities are assessed based on maintenance and renovation plans envisaged for the building, including its energy performance.
Building functions relative to present and future applications. In the case of institutions, an assessment must be made as to whether the present configuration of the building will meet future requirements for activities. If the building is a school, this might relate to specialist subject rooms, group rooms, an introductory school attendance department, or the location of school-based care facilities (SFO), for example.– The potential effect of a renovation on the function of the building. Will the renovation involve rendering the building non-operational for a shorter or longer period? The time used by staff and other occupants must be considered. All renovation activities will involve some degree of operational loss, and this should be an integral part of the decision-making process.

3.4 Choice of Renovation Method

The Guidelines cannot offer universal recommendations for any single ‘correct’ solution. The building owner must make a judgement relative to the specific circumstances. As for waste management, the building owner must, in consultation with the local authority, determine the need and requirements for separating out PCBs from CDW.

Building owners should base their choice of method on a systematic comparison of the pros and cons of possible solutions. In this regard, it is important to bring the building occupant perspective into account too.

Renovation work will not usually be limited to dealing with PCBs but will also involve other environmentally harmful substances (typically lead). Apart from physical removal (e.g., PCB-containing caulk and associated secondary sources), decisions must be made about the necessity to strip out materials with contaminated surface areas such as wall paint, which must be removed from the building. The choice of method is therefore dependant on several issues, including:

The extent and character of the contamination of floor finish, walls, and other surface areas
Wall thickness and cut-out distance when removing concrete and clay tiles from contaminated caulked joints, windows, etc.
The removal of tiles, paving, etc.
The use of PPE, including period of occupancy, limited working hours, etc.
Measures to limit the emission of PCBs to surrounding environments (e.g., containment tunnels, partition walls, and ventilation systems)
The production of PCB-contaminated waste during renovation work (e.g., sand from sandblasting and rubble form manual trimming)
Collection and handling of renovation waste
Possibilities of ongoing control of the renovation work carried out.

Furthermore, please note:

The accumulation of waste products when removing PCBs in multi-storey residential buildings may result in critical structural loads
the physical removal of large parts of the structure may be critical to static properties and bracing the structure may be required prior to removal.

Possible solutions should then be compared to the priorities and assessments identified by the building owner in connection with evaluation of the items listed in Section 3.3, Evaluating the Draft Design. Methods for removing and cleaning up PCBs are reviewed in Section 5, Remediation Methods, where alternative remediation methods are outlined. The renovation solution may imply solutions which will not necessarily remove materials containing PCBs and encapsulation may be required.

Based on an overall assessment, the owner must decide which renovation strategy to implement or whether the costs relative to the building’s future function might favour demolition instead.

3.5 Tendering Process

Once the building owner has identified a solution which, at the draft design level, addresses the renovation solution and time schedule, a project proposal is prepared. The project proposal should specifically reflect the priorities clarified by the building owner in the preceding process. Involved parties should consider dividing the project into phases in which the acute problems are solved while also enabling the building owner to spread costs over several years. The project proposal should include an economic calculation for the overall project.

Based on the approved project proposal, a main project with accompanying tender material is outlined in accordance with applicable guidelines for tendering, including special conditions relative to the management of health and safety issues, waste, and the outside environment.

The tender material should define and delimit the part processes integral to the renovation solution. The task can be implemented as several subcontracts and methods, processes, and materials should therefore be described separately to match a prospective division into subcontracts. Steps must be taken to ensure that any such division will support and be compatible with the chosen renovation strategy.

Specific requirements concerning the execution should be clearly stated in the tender material:

Health and safety aspects.
Waste separation, including disposal of contaminated waste.
The prevention of the spread of PCBs to the outside environment.
Adequate screening relative to other premises and buildings in continued operation, including reducing noise and dust nuisance.
Access to the construction site.– Access to existing premises and buildings operational while the work is being done.
Collecting potentially PCB-contaminated dust from the removal of building materials containing PCBs (e.g., the tooling of concrete, clay tiles, or timber).
Exit clean-up before the building is put into operation again.

Requirements are incorporated into the tender material, preferably with specifications of submission format, etc.

3.6 Project Planning and Execution

A renovation project involving management of PCBs is planned and executed according to the same principles applicable to any construction or renovation project. The building owner should draw up a plan for rehousing occupants. This plan could be an integral part of the communication plan and should form the basis of dialogue with occupants to reach practical and useful solutions.

Building owners have a duty to contribute to compliance with health and safety legislation when planning and executing renovations involving materials containing PCBs. Consequently, the building owner is responsible for drawing up a Health and Safety Plan, PSS, and for coordinating the work.

Careful layout of the workplace is necessary to optimise the working environment, to mitigate the risk of spreading PCBs to the outside environment, to make provisions for occupants in adjacent rooms or buildings, and to ensure that the renovation process proceeds rationally. This is described in Section 6, Protecting People and the Environment.

Pursuant to article 13 of the Statutory Order on Waste, the building owner must notify the local authority prior to commencing abatement interventions (Ministry of the Environment, 2012) (see SBi Guidelines 241, Survey and assessment of building-related PCBs, (Andersen, 2015)).

Contractors commence the work and do the following:

Establish a construction site including the required environmental facilities for separating and storing waste and protective measures to ensure health and safety
Check PCB-contaminated materials and areas (e.g., for adequate labelling)
Remove environmentally harmful substances including PCBs and separate out PCB-contaminated waste
Implement the renovation and continue separating out PCB-contaminated waste
Dispose of waste in accordance with classification and local authority guidelines.3.7 Control and Documentation

3.7 Control and Documentation

Contractors must document the work performed on a rolling basis. The building owner or their adviser should prepare a plan for assuring, controlling, and documenting the quality of the work on a current basis. The building owner should ensure that this plan is effective by conducting an ongoing documented inspection of the work being carried out.

In addition to the usual procedures for quality assurance in construction work, the type and quantity of PCB-contaminated building materials for landfill, destruction, or controlled recovery must be identified, calculated, and notified.

It is advisable that the contracting enterprise document the specific PPE used during the process. Filter changes should be part of the documentation regarding fresh-air supply systems and to large ventilation systems filtrating exhaust air to the surrounding environment. These and similar requirements are incorporated into the tender material, preferably with specifications of submission format, etc.

Generally, the rules of the Danish WEA and the Danish EPA must be complied with (see Section 6, Protecting People and the Environment and Section 7, Waste Management).

Project supervisors and consultants have a duty to describe special risks and other issues relevant to health and safety when dealing with building-related PCBs (see Section 6.1.1, Operators’ Duties). Project supervisors must, for example, describe issues relative to structures and design solutions relevant to the future use and maintenance of the PCB-renovated building. This documentation should be part of the overall technical documentation for the building.

Accuracy and care are vital to the actual renovation work, both to optimise the working environment and to mitigate the spreading of PCB into the surrounding environment.

3.8 Communicating with Occupants and Other Involved Parties

It is important to keep occupants informed during all project phases. Information is basis for avoiding mythmaking, as is actively involving occupants, establishing a constructive dialogue regarding rehousing, and the solving the practical problems arising from the renovation work. Staff should feel confident about staying in their workplaces both regarding their mental working environment and being able to carry out their jobs. It should always be clear to occupants to whom they should turn if they have further questions.Apart from informing occupants at joint meetings, a representative person or group can be appointed to receive detailed information and work as an intermediary for the occupants. Such a solution would be sensible for large renovation projects lasting for lengthy periods. A time schedule should, as far as possible, be presented and resubmitted in the event of later changes. It may also be necessary to inform neighbours and others in the local area.

Documentation and/or operational guidelines for using the building may be necessary. If primary PCB sources have been removed (such as external caulked joints), there may be secondary and tertiary sources not included in the renovation which will need managing later. Furthermore, choices might have to be made as to encapsulating materials containing PCBs, for example. If that is the case, it may be relevant to hold meetings with building occupants where specific solutions and the background for choosing them can be explained in detail. Guidelines for occupants should be published in written form.

Documentation and/or guidelines should be kept together with other specifications significant to operating and maintaining the building.