pcbs: real world considerations overview of the regulations (what are the rules?)
TRANSCRIPT
PCBs: Real World Considerations
Overview of the Regulations(What are the rules?)
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)
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)
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!
?Classic Example - Authorized Use
40 CFR 761.30Unauthorized or Excluded ??Unauthorized or Excluded ??
?
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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
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TRC School Caulk and Glazing Data Example
<1
<10
<20
<30
<40
<50
<10
00
>10
000
50
100
150
200
250N
um
ber
of
Sam
ple
s(T
ota
l =
40
6)
So why the earlier question marks??
Total PCBs (mg/kg)
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1. Do your research. 2. Collect your data. 3. See where you stand.
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
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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
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Regulatory Framework for Building Materials - 3 “bins”
PCB Bulk Product Waste¤761.3¤761.50(b)(4)
PCB Remediation Waste¤761.3¤761.50(b)(3)
Excluded PCB Product¤761.3
≥ 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.
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Key New Guidance Documents
September 2009 (Caulk Guidance) http://www.epa.gov/epawaste/hazard/tsd/pcbs 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
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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)
http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/ballasts.htm
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NEW CHANGES
April 2010 ANPRM PCB Uses
Federal Register Management of Demolition Debris 30 day comment…more on this later.
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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!
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Any questions before we move on?
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.
Entry Event
INVESTIGATEsurveysample
evaluatecategorizedocument
REMEDIATEplan
notify*implement
CLOSE OUTreport
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
Com
mun
icati
on
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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 RemediationSelf-implementing Performance-based Risk-based Other Manage in place
Bulk product waste¤ 761.3761.50(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
761.62 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
761.79 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¤ 761.3
N/A N/A N/A Licensed permitted landfill
• Management plan?
• Case specific• No reg. req.
Cautio
nary
Wife of Bath19
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
multiplelayers
Sources, Sorption and Sinks, and Other Questions
SOURCEFluorescent Ballasts
SINKSCarpeting, Cushions
SORPTIONAny Surface
Lead paint?
ACM wire wrap on fixtures ?
Is it safe?
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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
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Any questions before we move on?
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PCBs are…
P = Painful
C = Costly
B = But…manageable
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
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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
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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…
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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
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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
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Engineering controls (containment systems)
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
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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
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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
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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
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Removal of 1 ton of PCB contaminated soil (includes excavation, transportation, and disposal) ~ $400/ton
Re-installation of PCB-free caulking
Products made in the USA
Managing PCB appropriately
Difference between bulk & remediation waste
Proper labeling
Site Restoration & Disposal
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Shoot, Ready, Aim!
Pre-planning vs. Discovery
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.
