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 1
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/m 3 • What about substrate? – With the product can be managed as PCB Bulk Product – Separate from the product must be PCB Remediation waste 2
AGENCY INTERACTIONS SAMPLING 3
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) 4
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/m 3 for non-porous surfaces – Low Occupancy • <25 ppm or < 50 ppm w/fence and sign or • <100 ppm w/cap • <100 ug/m 3 for non-porous surfaces – Cap minimum 6” asphalt or concrete or 10” soil 5
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 6
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 7
REMEDIATION • Verification REMEDIATION • Verification 8
REMEDIATION • Verification – Subpart O? REMEDIATION • Monitoring 9
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 REMEDIATION • Don’t forget all that other “stuff” – Analytical procedures – QA/QC requirements – Reporting – Records retention 10
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 on%20White%20Paper%20FINAL%209-26- 13.pdf 11
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