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 Moutoux, Assistant Director RCRA Corrective Action Office 1. Permits Office Steve Armann, Manager Barbara Gross, Manager Carmen Santos, PCB Coordinator 2. Underground Storage Tanks Steve Linder, Manager RCRA Issues TSCA PCB Cleanup Program 2
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 3
EPA R9 Presentation Goals • Raise awareness of TSCA PCB regulations o PCB regulations applicable to demolition - Examples • Share what EPA R9 may need from you 4
Roles & Responsibilities: EPA R9 / Building Owner EPA R9 - General Building Owner - General • Protect human health and the • Understand and follow environment applicable PCB regulations and other federal state/local • Return cleanup sites (e.g., regulations demolition sites) to beneficial use • Remove PCBs from building before full demolition • Provide technical/regulatory assistance • Clean up soils; clean up, protect storm water drains Identify resources • • Engineering controls/land use • Approve cleanup plans restrictions, if necessary • Determine if additional actions • Protect human health and necessary environment by doing the above 5
Key Messages #1 • PCBs - persistent, bioaccumulative, toxic chemicals o Cancer and non-cancer effects • Toxic Substances Control Act PCB regulations - 40 CFR 761 o Several applicable to demolition PCB-impacted buildings • PCB regulations have prohibitions, restrictions, and requirements for: o Manufacturing o Processing o Distribution in commerce o Use o Storage o Disposal o Marking o Recordkeeping 6
Key Messages #2 • EPA regulates PCBs ≥ 50 ppm and < 50 ppm In discussing demolition sites we focus attention on requirements for: o Sampling o Site cleanup o Decontamination o Disposal, but o Consider all applicable requirements • TSCA PCB regulations not delegated • EPA R9 partners with state/local agencies and industry 7
Key Messages #3 • Demolition sites and process o 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 8
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 9
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 10
EPA Extraction and Laboratory Methods Demolition PCB-Impacted Buildings • PCB Extraction Methods o EPA Method 3540C, Soxhlet (preferred) o EPA Method 3550C, Ultrasonic • PCB Analytical Method o EPA Method 8082A 11
EPA Resources #1 • EPA PCB national website: o www.epa.gov/pcbs o 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 12
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 13
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 14
Full Demolition PCB-Impacted Buildings Built or Renovated Between 1950 and 1979 (1980) Why remove Primary Sources PCBs from (e.g., caulk, building before paint, PCB light ballasts) demolition? Secondary Sources Dust (e.g., substrates like concrete, carpets) Indoor Air 15
Before Full Demolition Why Remove PCBs from Building? • PCBs - persistent, bioaccumulative, toxic chemicals o Cancer and non-cancer effects • Buildings built or renovated between 1950 and 1979 (1980) o Sources PCB contamination to: soils, storm water, and surface water (e.g., San Francisco Bay) 16
Before Full Demolition Why Remove PCBs from Building? • Buildings built or renovated between 1950 and 1979 (1980) o 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 17
Before Full Demolition Why Remove PCBs from Building? 18
Full Demolition of PCB-Impacted Buildings Actions to Reduce PCB Exposures and Impacts Pre- Demolition After Above - Survey building Ground 1950 – 1979 Demolition - Sample building materials (e.g., Remove caulk), substrates contaminated Potentially (e.g., concrete) soils, sample soils widespread use of after removal; - Sample soils PCB-containing resample storm and storm drains materials drains and - Clean, protect reclean if needed storm drains - Remove PCBs from building 19
Building Demolition Examples of PCB Wastes • PCB Bulk Product Wastes – e.g., caulk, paint, Galbestos o Non-liquid wastes derived from manufactured products containing PCBs o Currently contain PCBs ≥ 50 ppm o Regulatory definition in 40 CFR 761.3 • PCB Remediation Wastes – e.g., soils, sediments, concrete o Contamination due to liquid PCB spills or releases or migration from PCB-containing materials o Regulatory definition in 40 CFR 761.3 20
Building Demolition Examples of PCB Wastes • Other PCB wastes – also see 40 CFR 761.60 o PCB Liquids – e.g., transformer mineral oil ≥50 ppm o PCB Articles – e.g., transformers, capacitors 21
EPA Regulations PCB Bulk Product Waste Disposal • Performance-based option, 40 CFR 761.62(a) o No EPA approval needed • Other options o Municipal Solid Waste Landfill, 40 CFR 761.62(b) • No EPA approval needed • May not be able to use in California o Risk-based 40 CFR 761.62(c) • EPA approval needed • No unreasonable risk determination by EPA 22
EPA Regulations PCB Remediation Waste Cleanup and Disposal • Self-Implementing Cleanup, 40 CFR 761.61(a) o Prescribed sampling / cleanup levels / disposal o Notification to EPA, 30-day EPA response o Disposal options • Risk-based Cleanup, 40 CFR 761.61(c) o Not prescribed sampling, cleanup levels, disposal o Unreasonable risk determination by EPA o EPA approval of application needed to implement o Schedule sufficient time for EPA approval • Performance-based Disposal, 40 CFR 761.61(b) – Disposal only 23
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) o EPA approval needed • Disposal requirements for decontamination waste 24
EPA’s Reinterpretation of PCB Bulk Product Waste • What is it? o EPA Policy Memo – October 24, 2012 • How can it be helpful if applied to demolition of PCB- impacted buildings? o Abatement plan recommended o Designation of the combined PCB-containing material and contaminated substrate as PCB bulk product needs to be made ahead of removal and disposal 25
Pre-Demolition Steps (Recommended) 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 26
Post-Above Ground Demolition Steps (Recommended) 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 27
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