Demolition of PCB-Impacted Buildings BASMAA Webinar March 21, 2019 - - PowerPoint PPT Presentation

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Demolition of PCB-Impacted Buildings BASMAA Webinar March 21, 2019 - - PowerPoint PPT Presentation

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Demolition of PCB-Impacted Buildings BASMAA Webinar March 21, 2019 Carmen D. Santos PCB Coordinator, U.S. EPA R9 EPA R9 Land Division TSCA PCB Cleanup Program TSCA: Toxic Substances Control Act EPA R9 Land Division - RCRA Branch Nicole

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SLIDE 1

Demolition of PCB-Impacted Buildings

BASMAA Webinar

March 21, 2019

Carmen D. Santos PCB Coordinator, U.S. EPA R9

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SLIDE 2

EPA R9 Land Division TSCA PCB Cleanup Program

TSCA: Toxic Substances Control Act

EPA R9 Land Division - RCRA Branch Nicole Moutoux, Assistant Director

RCRA Corrective Action Office Steve Armann, Manager Carmen Santos, PCB Coordinator TSCA PCB Cleanup Program RCRA Issues

  • 1. Permits Office

Barbara Gross, Manager

  • 2. Underground Storage

Tanks Steve Linder, Manager

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EPA R9 Presentation What is it about?

Demolition of PCB-impacted buildings built between 1950 and 1979 (1980)

  • Applicable PCB regulations
  • Identification of PCBs in the buildings and removal
  • Waste segregation and disposal
  • Measures to protect human health and the environment

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SLIDE 4

EPA R9 Presentation Goals

  • Raise awareness of TSCA PCB regulations
  • PCB regulations applicable to demolition - Examples
  • Share what EPA R9 may need from you

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SLIDE 5

Roles & Responsibilities: EPA R9 / Building Owner

EPA R9 - General

  • Protect human health and the

environment

  • Return cleanup sites (e.g.,

demolition sites) to beneficial use

  • Provide technical/regulatory

assistance

  • Identify resources
  • Approve cleanup plans
  • Determine if additional actions

necessary

Building Owner - General

  • Understand and follow

applicable PCB regulations and

  • ther federal state/local

regulations

  • Remove PCBs from building

before full demolition

  • Clean up soils; clean up, protect

storm water drains

  • Engineering controls/land use

restrictions, if necessary

  • Protect human health and

environment by doing the above

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Key Messages #1

  • PCBs - persistent, bioaccumulative, toxic chemicals
  • Cancer and non-cancer effects
  • Toxic Substances Control Act PCB regulations - 40 CFR 761
  • Several applicable to demolition PCB-impacted buildings
  • PCB regulations have prohibitions, restrictions, and requirements for:
  • Manufacturing
  • Processing
  • Distribution in commerce
  • Use
  • Storage
  • Disposal
  • Marking
  • Recordkeeping

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SLIDE 7

Key Messages #2

  • EPA regulates PCBs ≥ 50 ppm and < 50 ppm In discussing

demolition sites we focus attention on requirements for:

  • Sampling
  • Site cleanup
  • Decontamination
  • Disposal, but
  • Consider all applicable requirements
  • TSCA PCB regulations not delegated
  • EPA R9 partners with state/local agencies and industry

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Key Messages #3

  • Demolition sites and process
  • Overarching Goal – Be protective of human health / environment
  • Notify EPA about PCBs
  • Conduct PCB removal steps in sequence that is protective
  • Follow applicable PCB regulations and state/local regulations

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40 CFR 761, Examples of Applicable Requirements Demolition PCB-Impacted Buildings

  • Applicability, 761.1 and 761.2
  • Definitions, 761.3
  • PCB remediation waste, 761.61
  • PCB bulk product waste, 761.62

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40 CFR 761, Examples of Applicable Requirements Demolition PCB-Impacted Buildings

  • Disposal requirements, 761.60
  • Storage for disposal, 761.65
  • Decontamination, 761.79
  • 761 Subpart C and Subpart K
  • Use authorizations and exclusions, 761.20 and 761.30

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EPA Extraction and Laboratory Methods Demolition PCB-Impacted Buildings

  • PCB Extraction Methods
  • EPA Method 3540C, Soxhlet (preferred)
  • EPA Method 3550C, Ultrasonic
  • PCB Analytical Method
  • EPA Method 8082A

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EPA Resources #1

  • EPA PCB national website:
  • www.epa.gov/pcbs
  • Specific pages: e.g., Learn (guidance), Building Materials, Cleanup
  • PCB Facility Approval Streamlining Toolbox (PCB FAST), EPA

Publication, EPA530-F-17-002, May 2017

  • October 2012: Reinterpretation of PCB bulk product waste
  • Sampling Porous Surfaces, EPA Region 1 SOP, May 2011

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EPA Resources #2

  • PCBs in Building Materials, Q/A, EPA July 28, 2015
  • Practical Actions for Reducing Exposure to PCBs in Schools

and Other Buildings, EPA Fact Sheet, July 28, 2015

  • PCB Question and Answer Manual, EPA 2014
  • PCB Site Revitalization Guidance Under the Toxic Substances

Control Act, November 2005

  • Call EPA Region 9 PCB Coordinator – 415.972.3360

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SLIDE 14

Examples of PCB Applications

  • High Intensity discharge lamps
  • Electrical equipment
  • Caulk and sealants
  • Adhesives / mastics
  • Thermal insulation (e.g., felt, foam)
  • Floor finishes and tiles
  • Ceiling tiles
  • Fire Retardants
  • Tank coatings

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SLIDE 15

Full Demolition PCB-Impacted Buildings Built or Renovated Between 1950 and 1979 (1980)

Indoor Air Primary Sources (e.g., caulk, paint, PCB light ballasts) Secondary Sources (e.g., substrates like concrete, carpets) Dust

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Why remove PCBs from building before demolition?

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SLIDE 16

Before Full Demolition Why Remove PCBs from Building?

  • PCBs - persistent, bioaccumulative, toxic chemicals
  • Cancer and non-cancer effects
  • Buildings built or renovated between 1950 and 1979 (1980)
  • Sources PCB contamination to: soils, storm water, and surface

water (e.g., San Francisco Bay)

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Before Full Demolition Why Remove PCBs from Building?

  • Buildings built or renovated between 1950 and 1979 (1980)
  • Impacts to surface water
  • E.g., San Francisco Bay impacted by PCBs - TMDL
  • SF Bay sediments – reduce PCBs to an average of 1 ug/kg

(microgram/kilogram) (based on fish consumption)

  • 1 ug/kg = 0.001 milligram/kilogram

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Before Full Demolition Why Remove PCBs from Building?

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Full Demolition of PCB-Impacted Buildings

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1950 – 1979 Potentially widespread use of PCB-containing materials Pre- Demolition

  • Survey building
  • Sample building

materials (e.g., caulk), substrates (e.g., concrete)

  • Sample soils

and storm drains

  • Clean, protect

storm drains

  • Remove PCBs

from building After Above Ground Demolition Remove contaminated soils, sample soils after removal; resample storm drains and reclean if needed

Actions to Reduce PCB Exposures and Impacts

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Building Demolition Examples of PCB Wastes

  • PCB Bulk Product Wastes – e.g., caulk, paint, Galbestos
  • Non-liquid wastes derived from manufactured products

containing PCBs

  • Currently contain PCBs ≥ 50 ppm
  • Regulatory definition in 40 CFR 761.3
  • PCB Remediation Wastes – e.g., soils, sediments, concrete
  • Contamination due to liquid PCB spills or releases or migration

from PCB-containing materials

  • Regulatory definition in 40 CFR 761.3

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SLIDE 21

Building Demolition Examples of PCB Wastes

  • Other PCB wastes – also see 40 CFR 761.60
  • PCB Liquids – e.g., transformer mineral oil ≥50 ppm
  • PCB Articles – e.g., transformers, capacitors

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EPA Regulations PCB Bulk Product Waste Disposal

  • Performance-based option, 40 CFR 761.62(a)
  • No EPA approval needed
  • Other options
  • Municipal Solid Waste Landfill, 40 CFR 761.62(b)
  • No EPA approval needed
  • May not be able to use in California
  • Risk-based 40 CFR 761.62(c)
  • EPA approval needed
  • No unreasonable risk determination by EPA

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SLIDE 23

EPA Regulations PCB Remediation Waste Cleanup and Disposal

  • Self-Implementing Cleanup, 40 CFR 761.61(a)
  • Prescribed sampling / cleanup levels / disposal
  • Notification to EPA, 30-day EPA response
  • Disposal options
  • Risk-based Cleanup, 40 CFR 761.61(c)
  • Not prescribed sampling, cleanup levels, disposal
  • Unreasonable risk determination by EPA
  • EPA approval of application needed to implement
  • Schedule sufficient time for EPA approval
  • Performance-based Disposal, 40 CFR 761.61(b) – Disposal only

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EPA Regulations Decontamination Standards and Procedures

40 CFR 761.79 contains:

  • Performance-Based Standards
  • Self-Implementing Procedures
  • Alternative Decontamination Procedures, 40 CFR 761.79(h)
  • EPA approval needed
  • Disposal requirements for decontamination waste

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EPA’s Reinterpretation of PCB Bulk Product Waste

  • What is it?
  • EPA Policy Memo – October 24, 2012
  • How can it be helpful if applied to demolition of PCB-

impacted buildings?

  • Abatement plan recommended
  • Designation of the combined PCB-containing material and

contaminated substrate as PCB bulk product needs to be made ahead of removal and disposal

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Pre-Demolition Steps (Recommended)

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1 Survey Building Materials and Substrates 2 Sample Materials; Substrates (Pilot Studies) 2a Sample Soils and Storm Drain Sediments 3 Waste Segregation and Disposal Plan

(Notification/Application for PCB Cleanup)

3a Cleanup Plan for Soils and Storm Drains 3b Air Dust Monitoring Plan 4 Remove PCBs from Building, Air-Dust Monitoring

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SLIDE 27

Post-Above Ground Demolition Steps (Recommended)

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1 Clean up Soils Contaminated with PCBs 1a Air-Dust Monitoring

2 Soil Cleanup Verification Sampling

  • 2a. Storm Drains Resample, Reclean, Protect

3 Complete Disposal PCB Wastes Offsite 4 Reuse/Recycling Non-PCB Materials 5 PCB Cleanup Completion & Disposal Report

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Examples PCB Cleanup – Building Demolition

Mixed Land Use Including Residential

Example #1

PCB Findings – Building Survey, Pilot Studies, and Sampling

  • 9-Story concrete building, 1972
  • Caulk - up to 22,0o0 ppm
  • Sediments - storm water drains,

up to 270 ppm

  • Soils – up to 11 ppm
  • EPA risk-based approval 761.61(c)
  • PCB cleanup goal 0.24 ppm
  • First step – 3 to 5 storm drains

cleaned up, protective measures

  • Air dust monitoring - PCB

removal

Example #2

PCB Findings – Building Survey, Pilot Studies, and Sampling

  • 2-Story concrete building, 1960s
  • Caulk – up to 307,000 ppm
  • Sediments – storm water drains,

up to 2.76 ppm

  • Soils – up to 0.77 ppm
  • EPA risk-based approval 761.61(c)
  • PCB cleanup goal 0.24 ppm
  • First step – 3 to 5 storm drains

cleaned up, protective measures

  • Air dust monitoring - PCB

removal

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Examples #1 & 2 - Sequence PCB Removal

  • After Building Survey - Pilot Studies (Substrate Sampling)
  • Extent of substrate contamination
  • Where does substrate meet cleanup goal?
  • Before Full Above Ground Demolition
  • Removed PCB caulk together with adjacent contaminated concrete
  • EPA PCB bulk product reinterpretation applied
  • After Full Above Ground Demolition
  • Contaminated soils removed via excavation, cleanup verification

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Example #3 Exterior Metal Panels with Rubber Gaskets

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Example #3 – Exterior Metal Panels on Building

  • 14-Story Building, 1962
  • Exterior 4’ by 8’ metal panels on two sides of the building on

Floors 2 through 14

  • Panels contained mounting frame with rubber gasket
  • Rubber gaskets - PCBs up to 1,100 ppm
  • Caulk in contact with panel mounting frame and gasket - PCBs up

to 140,000 ppm

  • Metal panels removed from building before demolition

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Example #3 – Exterior Metal Panels on Building

  • Building owner wanted to recycle metal panels
  • Panel surfaces contaminated – source PCBs in gaskets/caulk
  • EPA approved alternative decontamination procedure, 40

CFR 761.79(h)

  • Metal panels decontaminated to ≤10 micrograms/sq cm
  • Decontaminated panels sent to recycler
  • Caulk and gaskets disposed of as PCB bulk product waste

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Conclusion

  • Demolition sites and process
  • Overarching Goal – Be protective of human health / environment
  • Notify EPA about PCBs
  • Conduct PCB removal steps in sequence that is protective
  • Follow applicable PCB regulations and other federal,

state/local regulations

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How can our PCB Cleanup Program help you?

  • EPA R9’s TSCA PCB Cleanup Program
  • Main Goal: Protect human health and the environment
  • PCB FAST and other resources
  • How can we help you?
  • Schedule a call or meeting with EPA R9 about your demolition project
  • Share findings of pre-demolition activities (e.g., building surveys,

pilot studies [substrate], sampling, types of wastes)

  • Seek EPA R9 guidance on cleanup of soils and storm drains
  • Consider applicable green remediation best management practices

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SLIDE 35

PCB Questions or Issues?

Carmen D. Santos Regional PCB Coordinator U.S. EPA Region 9 75 Hawthorne Street San Francisco, California 94105 Voice: 415.972.3360 Email: santos.carmen@epa.gov

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