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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
?
Classic Example - Authorized Use
Unauthorized or Excluded ??
?
Unauthorized or Excluded ??
40 CFR 761.30
Do your data show PCBs? Start your risk communication!
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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
Bulk Product Waste
asbestos felt on both sides coated with
either bitumen or polyester resin)
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TRC School Caulk and Glazing Data Example
250
(Total = 406)
Number of Samples
200
150
100
50
0
<1
<10
<20
<30
<40
<50 <1000 >1000
Total PCBs (mg/kg)
1. Do your research.
2. Collect your data.
3. See where you stand.
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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
PCB
RemediationWaste
 Examples include –


Brick, window frames with PCB caulk*
Concrete masonry units with PCB paint*

Dust in HVAC systems
* - 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
Excluded PCB Product
if less than 50 ppm
total PCBs when
manufactured
 State requirements may require
removal (e.g., Connecticut).
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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)
≥ 50 ppm total PCBs
Any concentration material < 50 ppm total PCBs
w/total PCBs > 1 ppm when
 Lines of evidence
associated with BPW over 50 ppm
 Origin, dilution,
 Unauthorized source
coverage
(typical in building
context)
 Example - PCB Bulk
Product Waste source
 One valid sample will
do to gain entry
 Obligations begin
 Unauthorized use
 Must be removed
 Note Oct. 24, 2012
reinterpretation
1. Do your research.
Excluded PCB Product
¤761.3
 Unauthorized disposal
 Investigate/remediate
2. Collect your data.
 Not regulated for
removal
 Management plan?
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?
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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
REMEDIATE
plan
notify*
implement
 Renovation, repair, and/or demolition
 Risk evaluation request
Risk Communication
INVESTIGATE
survey
sample
evaluate
categorize
document
Entry
 Due diligence (property transfer)
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!!)
* when
applicable
CLOSE OUT
report
manage*
restrict*
Exit/Closure
 Remedial action reporting
 Management in place (where needed)
 Long-term restriction/O&M
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Enter the Matrix…
PCB Waste/
Disposal Category
Regulatory Pathways for Remediation
Self-implementing
N/A
Bulk product waste
¤ 761.3761.50(b)(4)
¤ 761.62
Performance-based
Risk-based
Other
761.62(a) disposal
761.62(c) disposal
761.62 b, d
-
- Manner other
than prescribed
- Approved by RA
- Solid waste
landfill disposal
- Leach test ?
- Notify Landfill
- Daily cover/ road
base
Incineration
TSCA landfill
RCRA landfill
Alt. Disp. Approval
Decontamination
Remediation waste
761.61(a)
761.61(b)
761.61(c)
761.79
¤ 761.3
¤ 761.50(b)(3)
¤ 761.61
•
•
•
•
•
•
•
•
•
•
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
• Requires RA
approval
• Extensive
information
requirements
• Risk assessment
• All COCs
• All media
Decontamination
• Visual standards
and/or wipe for
confirming nonporous surfaces
• Can be
technically
challenging
• Alternatives
require EPA
approval
N/A
N/A
Licensed permitted
landfill
Excluded PCB
product
¤ 761.3
Notification
Prescriptive
30 day approval
Clean-up criteria
Disposal criteria
Occupancy
criteria
• RA can demand
more!
N/A
Manage in place
Temporary,
otherwise no
way
•
•
•
•
Viable option
Capping
Deed Restrict.
Management
plan?
• Marking?
• Monitoring?
• Management
plan?
• Case specific
• No reg. req.
“…no one can be told what the Matrix is. You have to see it for yourself.” - Morpheus
Wife of Bath
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Illustration of Concepts – Characterization Examples
inter-media
transfer
homogeneous
paint areas
non-porous
porous
Looks
consistent,
but is it?
multiple
layers
If the paint is
dirty, what of
the brick?
direct/indirect
vent system
impacts
Sources, Sorption and Sinks, and Other Questions
SOURCE
Fluorescent Ballasts
Lead paint?
ACM wire wrap
on fixtures ?
SORPTION
Any Surface
SINKS
Carpeting,
Cushions
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
Any questions before we move on?
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PCBs are…
P = Painful
C = Costly
B = But…manageable
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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
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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
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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
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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)
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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)
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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
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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
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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
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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
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Site Restoration & Disposal
 Re-installation of PCB-free caulking
 Products made in the USA
 Managing PCB appropriately
 Difference between bulk & remediation
waste
 Proper labeling
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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
What are your priorities?
 Communicate

Building occupants – your clients

Fact sheets, meetings – don’t overwhelm
1. Do your research.
2. Collect your data.
3. See where you stand.
Questions?
Dave Sullivan
P: 978-656-3565 | E: [email protected]
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