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

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Presentation on theme: "PCBs: Real World Considerations Overview of the Regulations (What are the rules?)"— 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 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) Bulk Product Waste 5

6 TRC School Caulk and Glazing Data Example Total PCBs (mg/kg) 6 1. Do your research. 2. Collect your data. 3. See where you stand.

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 RemediationWaste * - PCB Bulk Product Waste materials 7

8 Excluded PCB Product (761.3)  Must meet all criteria under §  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 ¤ ¤ (b)(4) PCB Remediation Waste ¤ ¤ (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? 1. Do your research. 2. Collect your data. 3. See where you stand. 9

10 Key New Guidance Documents  September 2009 (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)  ballasts.htm 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 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 Entry Event INVESTIGATE survey sample evaluate categorize document REMEDIATE plan notify* implement CLOSE OUT report manage* restrict* * when applicable 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 Risk Communication 16

17 17

18 Enter the Matrix… “…no one can be told what the Matrix is. You have to see it for yourself.” - Morpheus PCB Waste/ Disposal Category Regulatory Pathways for Remediation Self-implementingPerformance-basedRisk-basedOtherManage in place Bulk product waste ¤ (b)(4) ¤ N/A (a) disposal - Incineration - TSCA landfill - RCRA landfill - Alt. Disp. Approval - Decontamination (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 ¤ ¤ (b)(3) ¤ (a) Notification Prescriptive 30 day approval Clean-up criteria Disposal criteria Occupancy criteria RA can demand more! (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 (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 ¤ N/A Licensed permitted landfill Management plan? Case specific No reg. req.

19 Cautionary Wife of Bath 19

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

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

22 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 23 Any questions before we move on?

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

25  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 Don’t let the guidance fool you 25

26  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 Manage the expectations 26

27  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 Dollars and sense… 27

28  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) Project Approach 28

29  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 Remedial Techniques – Physical & Mechanical 29  Engineering controls (containment systems)

30  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 Remedial Techniques – Chemical 30

31  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 Encapsulation 31

32  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 Interior Cleaning 32

33  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 Remedial Techniques – Soil 33  Removal of 1 ton of PCB contaminated soil (includes excavation, transportation, and disposal) ~ $400/ton

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

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

36 36 Questions? Dave Sullivan P: | E:

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