Demolition of PCB-Impacted Buildings BASMAA WebinarMarch 21, 2019Carmen D. SantosPCB Coordinator, U.S. EPA R9

EPA R9 Land Division TSCA PCB Cleanup ProgramTSCA: Toxic Substances Control Act

EPA R9 Land Division - RCRA BranchNicole Moutoux, Assistant Director

RCRA Corrective Action OfficeSteve Armann, ManagerCarmen Santos, PCB Coordinator

TSCA PCB Cleanup Program RCRA Issues

1. Permits OfficeBarbara Gross, Manager2. Underground Storage

TanksSteve Linder, Manager

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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

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EPA R9 Presentation Goals

• Raise awareness of TSCA PCB regulationso PCB regulations applicable to demolition - Examples

• Share what EPA R9 may need from you

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Roles & Responsibilities: EPA R9 / Building Owner

EPA R9 - General• Protect human health and the

environment• Return cleanup sites (e.g.,

demolition sites) to beneficial use

• Provide technical/regulatory assistance

• Identify resources• Approve cleanup plans • Determine if additional actions

necessary

Building Owner - General• Understand and follow

applicable PCB regulations and other federal state/local regulations

• Remove PCBs from building before full demolition

• Clean up soils; clean up, protect storm water drains

• Engineering controls/land use restrictions, if necessary

• Protect human health and environment by doing the above

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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 Manufacturingo Processingo Distribution in commerceo Useo Storageo Disposalo Markingo Recordkeeping

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Key Messages #2

• EPA regulates PCBs ≥ 50 ppm and < 50 ppm In discussing demolition sites we focus attention on requirements for:o Samplingo Site cleanupo Decontaminationo Disposal, buto Consider all applicable requirements

• TSCA PCB regulations not delegated

• EPA R9 partners with state/local agencies and industry

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Key Messages #3

• Demolition sites and processo 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

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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

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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

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EPA Extraction and Laboratory Methods Demolition PCB-Impacted Buildings

• PCB Extraction Methodso EPA Method 3540C, Soxhlet (preferred)

o EPA Method 3550C, Ultrasonic

• PCB Analytical Methodo EPA Method 8082A

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EPA Resources #1

• EPA PCB national website:o www.epa.gov/pcbso 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

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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

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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 coatings14

Full Demolition PCB-Impacted Buildings Built or Renovated Between 1950 and 1979 (1980)

IndoorAir

Primary Sources (e.g., caulk,

paint, PCB light ballasts)

Secondary Sources

(e.g., substrates like concrete,

carpets)

Dust

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Why remove PCBs from building before demolition?

Before Full DemolitionWhy 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)

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Before Full DemolitionWhy 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

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Before Full DemolitionWhy Remove PCBs from Building?

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Full Demolition of PCB-Impacted Buildings

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1950 – 1979

Potentially widespread use of PCB-containing materials

Pre-Demolition

- Survey building- Sample building materials (e.g., caulk), substrates (e.g., concrete) - Sample soils and storm drains - Clean, protect storm drains- Remove PCBs from building

After Above Ground

DemolitionRemove contaminated soils, sample soils after removal; resample storm drains and reclean if needed

Actions to Reduce PCB Exposures and Impacts

Building DemolitionExamples 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 ppmo 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

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Building DemolitionExamples 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

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EPA RegulationsPCB 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

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EPA RegulationsPCB 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

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EPA RegulationsDecontamination 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

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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

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Pre-Demolition Steps (Recommended)

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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

Post-Above Ground Demolition Steps(Recommended)

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1 Clean up Soils Contaminated with PCBs1a Air-Dust Monitoring

2 Soil Cleanup Verification Sampling2a. Storm Drains Resample, Reclean, Protect

3 Complete Disposal PCB Wastes Offsite

4 Reuse/Recycling Non-PCB Materials

5 PCB Cleanup Completion & Disposal Report

Examples PCB Cleanup – Building DemolitionMixed Land Use Including Residential

Example #1PCB Findings – Building Survey, Pilot Studies, and Sampling• 9-Story concrete building, 1972 • Caulk - up to 22,0o0 ppm • Sediments - storm water drains,

up to 270 ppm • Soils – up to 11 ppm • EPA risk-based approval 761.61(c)• PCB cleanup goal 0.24 ppm • First step – 3 to 5 storm drains

cleaned up, protective measures • Air dust monitoring - PCB

removal

Example #2 PCB Findings – Building Survey, Pilot Studies, and Sampling• 2-Story concrete building, 1960s• Caulk – up to 307,000 ppm• Sediments – storm water drains,

up to 2.76 ppm• Soils – up to 0.77 ppm • EPA risk-based approval 761.61(c)• PCB cleanup goal 0.24 ppm• First step – 3 to 5 storm drains

cleaned up, protective measures• Air dust monitoring - PCB

removal

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Examples #1 & 2 - Sequence PCB Removal

• After Building Survey - Pilot Studies (Substrate Sampling)o Extent of substrate contaminationo Where does substrate meet cleanup goal?

• Before Full Above Ground Demolitiono Removed PCB caulk together with adjacent contaminated concreteo EPA PCB bulk product reinterpretation applied

• After Full Above Ground Demolitiono Contaminated soils removed via excavation, cleanup verification

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Example #3Exterior Metal Panels with Rubber Gaskets

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Example #3 – Exterior Metal Panels on Building

• 14-Story Building, 1962 • Exterior 4’ by 8’ metal panels on two sides of the building on

Floors 2 through 14

• Panels contained mounting frame with rubber gasketo Rubber gaskets - PCBs up to 1,100 ppmo Caulk in contact with panel mounting frame and gasket - PCBs up

to 140,000 ppm

• Metal panels removed from building before demolition

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Example #3 – Exterior Metal Panels on Building

• Building owner wanted to recycle metal panels

• Panel surfaces contaminated – source PCBs in gaskets/caulk• EPA approved alternative decontamination procedure, 40

CFR 761.79(h) o Metal panels decontaminated to ≤10 micrograms/sq cm

• Decontaminated panels sent to recycler

• Caulk and gaskets disposed of as PCB bulk product waste

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Conclusion

• 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 other federal,

state/local regulations

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How can our PCB Cleanup Program help you?

• EPA R9’s TSCA PCB Cleanup Program

o Main Goal: Protect human health and the environment

o PCB FAST and other resources

• How can we help you?

o Schedule a call or meeting with EPA R9 about your demolition project

o Share findings of pre-demolition activities (e.g., building surveys,

pilot studies [substrate], sampling, types of wastes)

o Seek EPA R9 guidance on cleanup of soils and storm drains

o Consider applicable green remediation best management practices

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PCB Questions or Issues?

Carmen D. SantosRegional PCB Coordinator

U.S. EPA Region 975 Hawthorne Street

San Francisco, California 94105

Voice: 415.972.3360Email: santos.carmen@epa.gov

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