Voorlichting en instructie op het gebied van Arbo, VCA - RVR
Transcript of Voorlichting en instructie op het gebied van Arbo, VCA - RVR
PCBs in Building Materials
• What are PCBs
• Sources of PCBs in Building Materials
• Regulatory Requirements
• Levels of PCBs Found
• Removal & Clean-up Standards
• Recommended Actions & Best Management
Practices
PCBs
• PCBs are chlorinated hydrocarbons
• Manufactured from 1929 until their
manufacture was banned in 1979
• Vary in consistency from thin, light-colored
liquids to yellow or black waxy solids
PCBs
• PCBs were used in hundreds of industrial
and commercial applications including:
– electrical, heat transfer, and hydraulic
equipment;
– as plasticizers in paints, plastics, and rubber
products;
– in pigments, dyes, and
– carbonless copy paper
EPA Regulatory & Guidance
Levels for PCBs Substance
PCB Concentration
Manufactured Materials (such as caulk,
oil)
50 parts per million
Air in Elementary Schools 300 nanograms/cubic meter*
Air in Pre-Kindergarten/Kindergarten 100 nanograms/cubic meter*
Dust 10 micrograms/100 cubic centimeters
Soil 1 part per million
PCBs in Building Materials
• Primary Sources
– Caulk
– Fluorescent light ballasts
– Paint
– Mastic
• Secondary Sources
– Contaminated building materials
PCBs – Regulatory Requirements
• PCBs are regulated under the Toxic
Substances Control Act (TSCA)
– Generally regulated if concentration is >50 ppm
– Some uses are authorized
– Regulated at concentrations < 50 ppm for spills
and contaminated surfaces
PCBs in Building Materials -
Caulk
• Used as a seal around
– Windows
– Doorframes
– Masonry
– Joints
– Gaps
PCBs in Building Materials -
Caulk
• Universe
– Buildings constructed between 1950 and 1979
– Buildings renovated between 1950 and 1979
• Major Health Concern
– Elevated level of PCBs in indoor air
– PCBs found at levels above 100,000 ppm in
caulk
PCBs in Building Materials -
Ballasts
• PCBs are contained within the light ballasts'
capacitors and in the ballasts' potting
material.
• Until the late 1970s, PCBs were commonly
used as insulators in electrical equipment
because they have high tolerance to heat, do
not burn easily, and are non-explosive.
PCBs in Building Materials -
Ballasts
• Intact, operational ballasts where low level
PCBs remain in the ballasts and potting
material may not pose a health risk or
environmental hazard
• However, as they age, the ballasts degrade
• Capacitors in ballasts can have pure PCBs.
PCBs in Building Materials -
Ballasts
• After typical life expectancy exceeded,
ballast failure rates increase significantly
• All of the pre-1979 ballasts in lighting
fixtures that are still in use are now far
beyond this life expectancy
PCBs in Schools – Air
Monitoring • Pre-remediation results as high as 4957 ng/m3 in classroom
air
• Public Health Levels of PCBs in School Indoor Air*
Age 1-<2 2-<3 3-<6 6-<12
Elementary
School
12-<15
Middle
School
15-<19
High
School
19+
Adult
Concentration
(ng/m3)
70 70 100 300 450 600 450
*Assuming a background scenario of no significant PCB contamination in building
materials and average exposure from other sources, these concentrations should keep
total exposure below the reference dose of 20 ng PCB/kg-day
The PCB FLB Universe
Draft, deliberative
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1 Pre-1980 buildings, fluorescent lighting, no major lighting retrofit based on 2003 Department of Energy survey data, Census data and NCES data 2 Assumes 17% of total FLBs (PCB and non-PCB) 3 Assumes 75% leak in 2017
Building Type
Number of Buildings
that May Have PCB-
containing FLBs in
2017 1
Number of PCB-
containing FLBs in 2017
2
Number of Leaking PCB-
containing FLBs in 2017 3
Daycares 4,714 278,277 209,315
Hospitals 471 387,996 291,843
Primary and
Secondary
Schools
11,078 1,310,497 985,730
Public Housing 70,415 666,847 501,590
Other Public and
Commercial
Buildings
259,411 19,291,377 14,510,599
All Public and
Commercial
Buildings 346,089 21,934,994 16,499,077
PCBs in Building Materials –
Other Sources
• Some paints contain PCBs
– Fire retardant
– Water and chemical resistance
– Anti-fouling
• Adhesives and mastics
• Window glazing
• Insulation and vapor barriers
• Roofing and siding materials
PCBs in Building Materials –
• If sampling finds PCBs > 50 ppm in
primary sources– must be removed and
disposed as TSCA waste
• PCB Bulk v. Remediation Waste
Regulation of PCB Waste
• Caulk / Paint If > 50 ppm PCB Bulk Product Waste
Definition of Bulk Product Waste (761.3)
Disposal options for Bulk Product Waste (761.62)
• Use of such material is unlawful; must be removed & disposed
of
• May be disposed of in municipal landfills at any concentration
If state allows & landfill is able / willing to accept it
If < 50 ppm not PCB Bulk Product Waste
Regulation of PCB Waste
• Building Material If removed and disposed of at the same time as the > 50 ppm
caulk:
May all be managed as Bulk Product Waste (2012 Reinterpretation)
If remaining in place after caulk is removed:
PCB Remediation Waste if contaminated by PCB source > 50 ppm
Definition of PCB Remediation Waste (761.3)
Cleanup & Disposal options for PCB Remediation Waste
(761.61)
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Disposal in facility
permitted, licensed,
or registered by
State as a
municipal or non-
municipal non-
hazardous waste
landfill
PCB Bulk
Product Waste
§761.62(a)
Performance Based
Disposal
§ 761.62(b)
Disposal in Solid
Waste Landfills
§ 761.62(c)
Risk Based
Disposal
No interaction with
EPA
Disposal in TSCA
Approved / RCRA
Subtitle C facilities
No interaction with
EPA
Requires
interaction with
EPA
EPA Can make risk-
based disposal
decision
(but cannot leave
these kinds of
materials in place)
Bulk Product Waste Disposal Options
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PCB Remediation
Waste
§761.61(a)
Self Implementing
Cleanup Option
§ 761.61(b)
Performance Based
Disposal Option
§ 761.61(c)
Risk Based Cleanup
& Disposal
Requires interaction
with EPA
Can send
< 50 ppm to
municipal landfill
No interaction with
EPA
All PCB Remediation
Waste goes to a
TSCA facility
Requires interaction
with EPA
Can potentially send
< 50 ppm to
municipal landfill
Remediation Waste Cleanup & Disposal Options
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Additional Points about Remediation Waste
• Once PCB Bulk Product Waste is removed, any remaining building material
with PCBs > 1 ppm is subject to the cleanup and disposal requirements for
PCB Remediation Waste
• There are two ways for PCB Remediation Waste to go to a municipal
landfill, both require EPA involvement
1. Self-implementing option 761.61(a) – waste < 50 ppm
2. Risk-based option 761.61(c) – any concentration that is supported by a no
unreasonable risk finding
• Unlike Bulk Product Waste, Remediation Waste may be managed in place
using a risk-based approach
Including encapsulation, establishing cleanup levels > 1 ppm, etc.
PCBs in Building Materials –
Recommended Actions
• Replace old lighting systems
• Optimize ventilation
• Control dust – cleaning BMPs
• Air monitoring
PCBs in Building Materials –
Cleaning BMPs
• Use a wet or damp cloth or mop to clean surfaces
• Use vacuums with high efficiency particulate air
(HEPA) filters
• Do not sweep with dry brooms; minimize the use
of dusters near areas with caulk
• Maintain good hygiene - wash children’s hands
with soap and water often, particularly before
eating