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PCBs: Real World Considerations

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Presentation on theme: "PCBs: Real World Considerations"— Presentation transcript:

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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