MANAGING PCBs IN BUILDINGS Agency Interaction AGENCY INTERACTIONS - - PDF document

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MANAGING PCBs IN BUILDINGS

Agency Interaction

AGENCY INTERACTIONS

• Do you routinely test for PCBs?

– There are currently no regulatory requirements for a building owner to test building materials for PCBs – Once known, action is required – Example (2012) UMass Lederle Center – EPA recommendations for schools: consider testing indoor air first

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AGENCY INTERACTIONS

• Indoor air sampling – compare

results to?

• School targets exist, but application

to other buildings discouraged

AGENCY INTERACTIONS

• Your building product has PCBs

>50 ppm

– Must be removed down to < 1ppm – Non-porous surfaces to < 10ug/m3

• What about substrate?

– With the product can be managed as PCB Bulk Product – Separate from the product must be PCB Remediation waste

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AGENCY INTERACTIONS SAMPLING

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SAMPLING REMEDIATION

• Three Options

–Self-Implementing Approach by 761.61(a) –Performance Based Approach by 761.61 (b) –Risk Based Approach by 761.61(c)

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REMEDIATION

• Self-Implementing Approach by

761.61(a)

– Intended for small to moderate projects, no SW or SED – Requires Notification to EPA, state and local environmental agencies – Includes cleanup levels for wastes, non- porous surface and porous surfaces – 30-day presumptive approval from EPA, BUT…

REMEDIATION

• Cleanup Levels

– High Occupancy

• <1 ppm or < 10 ppm w/cap
• <10 ug/m3 for non-porous surfaces

– Low Occupancy

• <25 ppm or < 50 ppm w/fence and sign or
• <100 ppm w/cap
• <100 ug/m3 for non-porous surfaces

– Cap minimum 6” asphalt or concrete or 10” soil

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REMEDIATION

• Self-Implementing Approach by

761.61(a)

– EPA Region 1 Checklist

REMEDIATION

• Performance Based Approach by

761.61 (b) (Remediation) or 761.62 (Bulk Product)

– Notification not required to perform work – Cleanup <1 ppm, verify using Subpart O – All Performance Based Remediation Wastes must go to TSCA approved facility (landfill or incinerator) – Performance Based Bulk Product Wastes may go to solid waste facility, if facility can take it

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REMEDIATION

• Risk Based Approach by 761.61(c)

(Remediation waste) or 762.61(c)

– Request submitted to EPA for approval – Must include description of sampling, risk basis, proposed abatement, storage, disposal, verification, same notification contents as for Self-Implementing Approach – Requires written approval (= TIME) back from EPA before work can start

REMEDIATION

• Risk Based Approach by 761.61(c)

(Remediation waste) or 762.61(c)

– See EPA Region 1 Checklist

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REMEDIATION

• Verification

REMEDIATION

• Verification

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REMEDIATION

• Verification

– Subpart O?

REMEDIATION

• Monitoring

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REMEDIATION

• Managing Waste

– Storage 761.65(c) (9)

• None for liquids
• 180 days for product and remediation waste
• Must be lined, covered and secure

– Transportation & Disposal

• DOT rules (49 CFR Part 172) apply
• Know your disposal facility and start profile

approval process early

• Mixed PCB/ACM waste complications
• Don’t forget all that other

“stuff”

–Analytical procedures –QA/QC requirements –Reporting –Records retention

REMEDIATION

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REMEDIATION

• Can we ever leave it behind once we

know it is there?

– Yes for excluded product (must meet all the criteria) – No for PCB bulk product waste – Maybe for surrounding materials – Possible for short term measures if EPA approves and O&M assured.

Managing PCBs in Building, Suggested References

• Literature Review of Remediation Methods for PCBs

in Buildings (2012) : EPA/600/R-12/034

• EPA PCBs in Caulk Web Site

http://www.epa.gov/pcbsincaulk/

• EPA Risk Based Cleanup Checklist

http://www.epa.gov/region1/cleanup/pcbs/pdfs/49 1978.pdf

• EPA Self Implementing Cleanup Checklist

http://www.epa.gov/region1/cleanup/pcbs/pdfs/48 4694.pdf

• AIHA White Paper “PCBs in the Built

Environmenthttps: www.aiha.org/government- affairs/WhitePapers/PCBs%20in%20Constructi

• n%20White%20Paper%20FINAL%209-26-

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