1. PCBs: Real World Considerations
Overview of the Regulations
(What are the rules?)

2. The Current PCB Regulations 40 CFR Part 761
Section 6(e) of the Toxic Substances Control Act of 1976 (TSCA)
Generally bans manufacture, processing, distribution in commerce, and PCB use after 1978
Provides exceptions if EPA finds “no unreasonable risk of injury to health or the environment”
Most exceptions take form as authorizations, which include conditions such as location restrictions, repair restrictions, and concentration limits (e.g., light ballasts)
1998 amendments increased flexibility to the management of PCBs at a Site, including cleanup and disposal options (no snickering, please)

3. Regulatory Considerations
PCB regulations include owners and/or operators of PCB-contaminated property where the PCB contamination exceeds allowable concentrations
50 ppm for bulk product wastes, for example
TSCA authority not delegated to any state
EPA and state regulations both apply
Some states have their own PCB statutes
Connecticut is notable in New England (CGS 22a-463 through 469)

4. The regulatory categories in a nutshell…
General PCB Regulatory Categories
Unauthorized Use – Open systems with PCBs ≥50 mg/kg
Excluded PCB Products – Open systems with PCBs <50 mg/kg
Authorized Use – Closed, intact, non-leaking system ?
Classic Example - Authorized Use
40 CFR
Unauthorized or Excluded ??
Lines of evidence
Data clustered or spread out
Multiple layers yes/no
Time, date, concentration
Do your data show PCBs? Start your risk communication! 4

5. PCB Bulk Product Waste (761.62)
Bulk Product Waste Represents an Unauthorized Use
Open systems with PCBs ≥50 mg/kg
Examples include –
Caulk (heavy emphasis in EPA guidance)
Applied dried paints
Varnishes
Other coatings or sealants
Galbestos (a profiled metal sheeting with asbestos felt on both sides coated with either bitumen or polyester resin) 5

6. TRC School Caulk and Glazing Data Example
So why the earlier question marks??
TRC School Caulk and Glazing Data Example
Total PCBs (mg/kg)
1. Do your research Collect your data See where you stand. 6

7. PCB Remediation Waste (761.3)
Bulk product waste impacts to adjacent surfaces
Other mechanisms (inter-media transfer)
Any concentration material w/total PCBs > 1 ppm associated with an unauthorized source
Examples include –
Brick, window frames with PCB caulk*
Concrete masonry units with PCB paint*
Dust in HVAC systems
* - PCB Bulk Product Waste materials 7

8. Excluded PCB Product (761.3)
Must meet all criteria under § 761.3
Technically, it could be any total PCB concentration < 50 ppm…but expect to prove it with concentrations approaching 50 ppm
Examples include –
Just about any manufactured product
Watch for dilution…more on this later
May be left in place without further restrictions/requirements
State requirements may require removal (e.g., Connecticut).
Excluded PCB Product if less than 50 ppm total PCBs when manufactured 8

9. Regulatory Framework for Building Materials - 3 “bins”
PCB Bulk Product Waste
761.3
761.50(b)(4)
PCB Remediation Waste
761.50(b)(3)
Excluded PCB Product
≥ 50 ppm total PCBs
One valid sample will do to gain entry
Obligations begin
Any concentration material w/total PCBs > 1 ppm when associated with BPW over 50 ppm
Unauthorized source (typical in building context)
Example - PCB Bulk Product Waste source
< 50 ppm total PCBs
Lines of evidence
Origin, dilution, coverage
Unauthorized use
Must be removed
Note Oct. 24, 2012 reinterpretation
Unauthorized disposal
Investigate/remediate
Not regulated for removal
Management plan?
Federal regulations - Proper handling/disposal covered by existing regs.
EPA expects compliance during demolition or renovation.
No requirement to test otherwise.
However, characterization is the key to determining compliance/applicability.
Guidance – Established regulatory pathway, but confusing, hence guidance.
State regulations - No corresponding regulations in Maine at this time.
FYI…Connecticut regulations are in place and enforceable.
Remediation process for buildings - Means and methods are evolving, driven by on-going research and project experience. Ross Hartman will address this next.
1. Do your research Collect your data See where you stand. 9

10. Key New Guidance Documents
September (Caulk Guidance)
Fact sheets
Q and As
Schools Information Kit
Renovation/Abatement of Buildings with PCB-Containing Caulk
Public Health Levels for PCBs in Indoor Air for Schools
Not limited to that application
Discussed earlier in the presentation 10

11. Key New Guidance Documents - cont.
Mitigation and Exposure Assessment Research on Building Sources
Recently Issued Four Part Series
TRC experts served as peer reviewers
December 2010 (Ballast Guidance) 11

12. NEW CHANGES April 2010 ANPRM PCB Uses Federal Register
Management of Demolition Debris
30 day comment…more on this later. 12

13. EPA Recommendations For buildings built between 1950 and 1978
Minimize exposure (e.g., ventilation, cleaning)
Take care when renovating
Take care when abating
If you think you may have a problem…
Test for elevated air levels
Test for source of air contamination (duct systems, deteriorating caulk)
The Bottom Line –
No so fast eager beaver! 13

14. Any questions before we move on?

15. PCBs: Real World Considerations Practical Assessment and Remediation
(What can we do about it?)
Adapted from R. Hartman, Triumvirate, and E. Plimpton/D. Sullivan, TRC Environmental Corp.

16. Risk Communication Entry Due diligence (property transfer)
Renovation, repair, and/or demolition
Risk evaluation request
Investigation
Building survey (air, bulk, wipe, soil)
Material sampling (not limited to caulk)
Evaluate data/categorize materials
Remediation
Establish goals
Focus on removal and disposal
Regulatory oversight (Get to know Kim!!)
Exit/Closure
Remedial action reporting
Management in place (where needed)
Long-term restriction/O&M
Entry Event
INVESTIGATE
survey
sample
evaluate
categorize
document
REMEDIATE
plan
notify*
implement
CLOSE OUT
report
manage*
restrict*
* when applicable
Risk Communication 16

17. 17

18. Regulatory Pathways for Remediation
Enter the Matrix…
PCB Waste/
Disposal Category
Regulatory Pathways for Remediation
Self-implementing
Performance-based
Risk-based
Other
Manage in place
Bulk product waste
(b)(4)
761.62
N/A
761.62(a) disposal
Incineration
TSCA landfill
RCRA landfill
Alt. Disp. Approval
Decontamination
761.62(c) disposal
Manner other than prescribed
Approved by RA
b, d
Solid waste landfill disposal
Leach test ?
Notify Landfill
Daily cover/ road base
Temporary, otherwise no way
Remediation waste
761.3
761.50(b)(3)
761.61
761.61(a)
Notification
Prescriptive
30 day approval
Clean-up criteria
Disposal criteria
Occupancy criteria
RA can demand more!
761.61(b)
No EPA notification
Notify facility
Remove ALL PCBs
Disposal at TSCA approved facility
If unsuccessful, resort to other tracks (61a, 61c)
Submit documentation per 61a content
761.61(c)
Requires RA approval
Extensive information requirements
Risk assessment
All COCs
All media
Decontamination
Visual standards and/or wipe for confirming non-porous surfaces
Can be technically challenging
Alternatives require EPA approval
Viable option
Capping
Deed Restrict.
Management plan?
Marking?
Monitoring?
Excluded PCB product
Licensed permitted landfill
Case specific
No reg. req.
Choice of unpleasant options.
The devil and the deep blue sea.
Remediation is determined by:
Project type
Material impacted (e.g., porous /non-porous)
Regulatory pathway (voluntary/required)
Acceptable endpoints
“…no one can be told what the Matrix is. You have to see it for yourself.” - Morpheus

19. Cautionary
Wife of Bath 19

20. Illustration of Concepts – Characterization Examples
inter-media transfer
homogeneous paint areas
non-porous
Looks consistent, but is it?
porous
multiple
layers
If the paint is dirty, what of the brick?
direct/indirect vent system impacts

21. Sources, Sorption and Sinks, and Other Questions
Fluorescent Ballasts
ACM wire wrap on fixtures ?
Lead paint?
SORPTION
Any Surface
SINKS
Carpeting, Cushions
Is it safe? 21

22. Lets talk about the Federal Register Notice for PCB Bulk Product vs
Lets talk about the Federal Register Notice for PCB Bulk Product vs. Remediation Waste (Vol. 77, No. 40 /Wednesday, February 29, 2012) The reinterpretation published October 24, 2012 allows building material “coated or serviced” with PCB Bulk Product Waste to be managed as such when designated for disposal

23. Any questions before we move on?

24. PCBs are…
P = Painful
C = Costly
B = But…manageable

25. Don’t let the guidance fool you
It is not a given that if any caulking tests positive for PCBs, that all caulking in the building is impacted, regardless of EPA’s emphasis on caulking
Concentrations of PCBs in caulking can easily vary one to two orders of magnitude because of mixing ratios 25

26. Manage the expectations
Once the PCB ballasts and caulking are removed from the building, the PCB levels in indoor air will not drop immediately…..NO!
Desorption will take time 26

27. Dollars and sense…
Scarifying, removal and disposal ~ $45.00/square foot, assuming open access and roughly 4,000 sf
Substrate cutting, removal and disposal ~ $60/linear foot, assuming unimpeded access, limited staging
400 sq. ft. of negative pressure containment ~$1,300
Removal of 3 to 6 inches of adjacent brick ~$3 to $5/lf 27

28. Project Approach Contractor & Consultant Relationship
A collaborative effort
Interior or exterior
Typically projects are multifaceted (lights, caulking, soil)
Contractor Work Plan (required for EPA approval)
SOPs
Contractor-specific details of work
Decontamination of tools & equipment
Health & Safety (OSHA 40 hr) 28

29. Remedial Techniques – Physical & Mechanical
Removal of Caulking – proper tools and equipment
Removal to substrate (no visual remnants)
Pliability
Collection of all flaking and removed caulking (proper controls)
Substrate – dependent on concentrations and porosity
Engineering controls (containment systems) 29

30. Remedial Techniques – Chemical
Capsur – most common, aqueous-based
Existing concentrations must be at manageable levels
Effectiveness can be questionable based on porosity of impacted material
Adds time and analysis
Avoids removal of additional building materials 30

31. Encapsulation
What comes first when restoring? Caulking or Encapsulation?
Sikaguard & Sherman Williams – still researching
Rolling vs. spray applicator (dependent on substrate)
Color or clear
Deed restriction – future remediation 31

32. Interior Cleaning Sounds so easy…. Sequence and approach to room
Univents and air ducts?
Hepa Vac
Wet wipe - industrial cleaning agents
Exchange of air
Great care in approach to cleaning – cross contamination 32

33. Remedial Techniques – Soil
Soil Excavations
Typically cumbersome excavations
Staging of materials (roll-off containers) - labeling
Great care in cross-contamination (low detection limits)
Direct bulk removal, transportation & disposal
Managing waste appropriately
Removal of 1 ton of PCB contaminated soil (includes excavation, transportation, and disposal) ~ $400/ton 33

34. Site Restoration & Disposal
Re-installation of PCB-free caulking
Products made in the USA
Managing PCB appropriately
Difference between bulk & remediation waste
Proper labeling 34

35. } Shoot, Ready, Aim! Pre-planning vs. Discovery Project Triangle
Forewarned is forearmed - control
Change orders – avoid or minimize
Regulatory “greeting cards” – avoid
“Emerging guidance clause” – active area
Project Triangle
Speed
Quality
Cost
Communicate
Building occupants – your clients
Fact sheets, meetings – don’t overwhelm }
What are your priorities?
1. Do your research.
2. Collect your data.
3. See where you stand.

36. Questions? Dave Sullivan
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