Loureiro Engineering Associates, Inc. 100 Northwest Drive, Plainville, CT

Transcription

1 New Strategies and Demands For Hazardous Materials Management Loureiro Engineering Associates, Inc. 100 Northwest Drive, Plainville, CT

2 Overview History and Uses Current Regulatory Perspective Demands Changing Regulatory Perspective Disposal Requirements Strategies Characterization Management Disposal

3 History Late 1920 s - First manufactured by Anniston Ordnance Company, in Anniston, Alabama (later changed to Swann Chemical Company, later acquired by Monsanto) US production peaked at 85,000,000 pounds Toxic Substances Control Act (TSCA) generally bans the manufacture, processing, distribution in commerce, and use of PCBs after EPA issues first set of effluent standards EPA issued final regulations banning the manufacture of PCBs after a 3-year phase-out period.

4 History 1979 Present Production of PCBs in the United States is generally banned Use of PCB-containing materials still in service is restricted Discharge of PCB-containing effluents is prohibited Disposal of materials contaminated by PCBs is regulated Import or export of PCBs is only permitted through an exemption granted from EPA

5 Commonly Understood Uses Transformers, Capacitors, Electrical Switches Heat Transfer and Hydraulic Fluids Cable Insulation Carbonless Copy Paper Fluorescent Light Ballasts

6 Other Uses Oil-based paint Caulk Plastics Inks Adhesives

7 Industry Uses ( )

8 PCBs in Caulk Buildings built or renovated between 1940? and 1978? (literature dates vary) PCBs may be present in the caulk used in windows, door frames, masonry columns and other masonry building materials PCBs may be present at 100,000 parts per million (ppm) or higher PCBs migrate to porous substrates (concrete and brick) The link between PCBs in caulk and exposures to PCBs in the air or dust is not well understood.

9 Caulking

10 PCBs in Paint PCBs were a common additive for water and chemical resistance, durability, and elasticity (chlorinated rubber paint) Added to paints at concentrations around 5 to 10 % Aroclor 1254 plasticizer of choice for chemical resistance Used on Furnaces and other high heat environments Industrial machinery Masonry walls Exterior walls (metal and transite panels)

11 Paint PCBs >1,000 ppm

12 Current Regulatory Perspective 40 CFR Part PCBs in Building Materials at 50 ppm is not an AUTHORIZED USE (i.e. unpermitted) However 40 CFR Part 761 DOES NOT create an affirmative obligation to test for the presence of PCBs Maintaining PCBs 50 ppm in Building Materials Constituents a Violation of TSCA?

13 Continued First Assume PCBs were manufactured, processed and distributed in accordance with TSCA If 50 ppm: Prohibited Use Leave it alone Test indoor air (building is to remain) Remove it (renovation or demolition), removal and disposal is regulated and potentially confusing If >1 < 50 ppm: Excluded PCB Product Use authorization not needed TSCA does not apply 40 CFR part 761 does not apply

14 Remember the Masonry Wall Masonry Surface 1 ppm PCBs (PCB Remediation Waste if Removed) Caulking 50 ppm PCBs (PCB Bulk Product Waste if Removed) 40 CFR 761.3

15 What is the Difference? The Caulk is considered the PCB containing product The Wall was impacted by the release/spill/unauthorized use of the PCB containing product Same applies for Paint it is a PCB containing product

16 A Potential Change February 29, 2012 Federal Register EPA Seeks Comments to proposed reinterpretation - PCB bulk product and PCB remediation waste PCB bulk product waste: non liquid bulk wastes or debris from the demolition of buildings and other man-made structures manufactured, coated, or serviced with PCBs. PCB remediation waste: waste containing PCBs as a result of a spill, release, or other unauthorized disposal.leaching may be considered a release of PCBs

17 The Proposed Change A building material (i.e., substrate) coated or serviced with PCB bulk product waste (e.g., caulk, paint, mastics, sealants) at the time of disposal to be managed as a PCB bulk product waste Results in: Potential acceleration of removal Elimination of multiple disposal streams during renovation/demolition

18 Disposal Requirements 2 Categories of Waste PCB Bulk Product Waste and PCB Remediation Waste Remember: PCB bulk product waste: non liquid bulk wastes or debris from the demolition of buildings and other man-made structures manufactured, coated, or serviced with PCBs. PCB remediation waste: waste containing PCBs as a result of a spill, release, or other unauthorized disposal.leaching may be considered a release of PCBs So: PCB-containing Caulk and PCB Containing Paint are considered PCB bulk product waste if the concentration of PCBs in either is >50 ppm The substrate is a PCB remediation waste if it contains PCBs at >1 ppm

19 PCB Bulk Product Waste Disposal Requirements 40 CFR Performance-based disposal: Disposal in a TSCA incinerator, a TSCA chemical waste landfill, a RCRA hazardous waste landfill, under a TSCA approved alternate disposal method, under the TSCA regulated decontamination procedures; or in a facility with a coordinated approval issued under TSCA. Does not require approval from EPA. Disposal in solid waste landfills: Certain PCB bulk product waste (caulk) may be disposed of in non-hazardous waste landfills permitted by States. Does not require approval from EPA, but does require notification of the landfill prior to the first shipment. Risk-based option: The risk-based option allows for a sitespecific, risk-based evaluation of an alternative disposal method. Requires approval from EPA based on a finding that the disposal will not present an unreasonable risk of injury to health or the environment.

20 PCB Remediation Waste Disposal Requirements 40 CFR Self-implementing cleanup and disposal: Disposal requirements for the self-implementing regulatory option vary based, among other things, on the type of contaminated material and concentration of PCBs in the materials. Requires notification to Regional PCB Coordinator, does not require EPA approval. Performance-based disposal: Disposal in a TSCA incinerator, a TSCA chemical waste landfill, a RCRA hazardous waste landfill, under a TSCA approved alternate disposal method, under the TSCA regulated decontamination procedures; or in a facility with a coordinated approval issued under TSCA. Does not require approval from EPA. Risk-based cleanup and disposal: The risk-based option allows for a site-specific, risk-based evaluation of an alternative disposal method. Requires approval from EPA based on a finding that the disposal will not present an unreasonable risk of injury to health or the environment.

21 Characterization Strategies Sampling - Gather Representative Data Caulk and paint potential PCB bulk products Sills, jambs, underlayment, siding potential PCB remediation wastes Integrate with HBM survey Integrate removal with renovation/demolition Demolition segregate assemblies rather than separate (painted masonry) Renovation remove window, sill, jamb versus sash replacement Watch for developments on reinterpretation

22 Management Strategies Paints and Caulk Removal Media blast (beads, water, sand, etc.) Chemical stripping Scarification Encapsulation Caulk: Bond breaker tape and silicone caulk Porous Surfaces: Epoxy Paint Wall assemblies: False walls

23 Disposal of PCB Wastes Disposal market is fluid No Disposal Facilities in CT or MA Disposal Costs PCB Bulk Product Waste ± 50% PCB Remediation Waste Transportation Costs are most significant Cost benefit analysis Removal of Bulk Product and Segregated Disposal Disposal of Assembly

24 Questions

25 Resources EPA Main Page on PCBs EPA compendium on matters related to PCBs in caulk al.htm EPA site discussing disposal options for PCB waste =1638 CT DEEP Main Page on PCBs posal.aspx Disposal options reference Commercially permitted PCB disposal facilities