Remediation Projects with PCB Self-Implementing Cleanup Plans - PowerPoint Presentation

Remediation Projects with PCB Self-Implementing Cleanup Plans Georgia Brownfields ConferenceBy Wanda Farmer, REMApril 23, 2019 1

PCB Information for the Layman What are PCBsCliff Notes on PCBsWhere to find information on PCBsHow to handle PCBs Health and Safety 2

Former Textile Mill Former Textile Mill Built in 1929 Operated until the mid-1990sRemediation Project to develop into multi use Recreational and Residential/Commercial SpacePCBs identified in multiple, discreet areas at surface and subsurface.PCB hot spot identified during removal of pump house and vault system 3

Understanding PCB’s US PCB manufacture banned in 1979PCBs hang around for a l-o-n-g timeYou have most likely been exposed to PCBsLong term, repeated PCB exposure linked to Skin lesions and other adverse dermal effectsImmune and neurological system problems Reproductive and endocrine system issueProbable cancer causing effectsRegulated under Toxic Substances Control Act (TSCA) 4

PCB’s UNDER TSCA PCB’s managed/disposed based on concentrationSoil and Sediment Limits≤ 50 ppm is non-haz (only specified landfills though)>50 ppm is Haz -Waste (must be approved HW Landfill)50 to 500 ppm can be HW landfilled> 500 ppm must be incineratedWater Limits≤ 0.5 ug /L is not TSCA restricted 0.5 to 3.0 ug /L can be disposed at approved WW treatment facility > 3.0 ug /L must be incinerated If water has contacted media with >50 ppm PCB it must be incinerated due to “guilt by association.” 5

PCB’s UNDER TSCA (more)TSCA Sampling Methods for PCBsGeneral analysis method is referenced as 8082A TSCA approved Extraction methods are 3540C (Soxhlet) or 3550C (Sonication)Both methods are ancient (dating back to the 1970’s)Many labs can now use extraction method 3546 (microwave) where 30+ samples can be completed simultaneously in 28 minutes However, sadly, TSCA rules do not allow use of the more efficient, cost effective, and accurate methods available today TSCA PCB rules are necessary but can also be implementation “ dinosaurs” that can complicate all aspects of analysis and management 6

PCB’s UNDER TSCA (still more!)PCB Contaminated Site Clean-up Challenges Roll-offs must be cleaned and wipe tested (better line them!)If PCB water was in a frac. tank, the tank must be deconnedAny thing (yes, anything, think about it) contacting PCBs is contaminated and must be decontaminated if possible or disposed as PCB waste Container cleanup standard is 10 ppb on a wipe testPlant matter on site (grass, under brush, scrub trees, trees) is treated the same way as soil because of “guilty by association” 7

TSCA INFORMATION LINKS TSCA Facility Approval Guidance Toolbox https://www.epa.gov/sites/production/files/2017-06/documents/06072017_final_pcbfast_toolbox_508compliant.pdf 8 TSCA Approved PCB Disposal Facilities https://www.epa.gov/pcbs/list-polychlorinated-biphenyl-pcb-disposal-facilities-and-approvals-technology-type-and-epa EPA Guidance on Remedial Actions for Superfund Sites with PCB Contamination PCB Question and Answer Manual https :// www.epa.gov/pcbs/polychlorinated-biphenyl-pcb-question-and-answer-manual-and-response-comment-documents A Framework for Streamlining PCB Site Cleanup Approvals

EPA SCREENING VALUESEPA Regional Screening Levels (RSLs) help identify risk EPA Risk factors vary by media and exposure settingDefault to one, one-millionth of statistical predicted risk levelsIndustrial risk factor is based on 8-hr/day exposureReducing skin contact, ingestion, and inhalation risk is key 9

HASP SPECIFIED PPE Nitrile GlovesWaterproof Boots Boot CoversTyvek Coveralls 10

What Will it look like?Shown here, Dale is sporting a spiffy Tyvek coverall, white, still being acceptable at this point in the season. Accessorizing the Tyvek are delightful yellow boot covers, blue nitrile gloves under outer chem-gloves with a matching hardhat by SCS. This is going to be all the rage this fall with the anticipated cooler weather.11 The Wonderful World of PCBs

DECON – It’s Only Right HereDecon in isolated discrete areas of siteEquipment contacting the PCB is decontaminated in place following contact Limited exposure potential because of minimal personnel and vehicle contact Decon or disposal of tools and PPE as appropriatePortable supply of decon water adequateRelatively small amounts of decon water generated for possible collection, disposalMinimal PPE disposal 12

DECON – It’s Everywhere!! Oh noDecon: What about when the whole site is contaminated?Sourcing large amounts of decon cleaner and water?Ensuring all site personnel are properly protected?Cleaning up people, trucks, heavy equipment?What do you do with all that decon water?How is all the decon water managed?How do you keep the site from getting all muddy?What concentrations will have to be handled and how? Can it be filtered, reused, left onsite, disposed offsite? Making sure no “campfires” using site brush . . . 13

DECON – It’s Everywhere!Scaring the subcontractors (upping the cost) Communicating effectively through:Site Specific Media Management Plan (MMP)Site Specific Health and Safety Plan (HASP)Pre-Planning meetings and Contractor Orientation Ongoing Site MonitoringBetter planning for reduced time in deconPlanning to minimize decon time for trucksStaging site decon pads and roads Stagger scheduling of personnel as possible Good Housekeeping of Stored and Disposed PPE Effective tracking of personnel and vehicle ingress and egress 14

CONTAMINATED SITE TIME CONSIDERATIONSEst. Productivity cost for PPE procedures Additional breaks: ≈20 min/dayBathroom/Water breaks: ≈10 min/dayDon/Doff/Decon: ≈20 min/day ≈7 – 10% total Est. Productivity cost for Vehicle DeconStandard Vehicle: ≈10 min/vehicleTracked Vehicle: ≈30 min/vehicle 15

WHAT YOU ARE GOING FOR16 https://player.vimeo.com/video/153396696?title=0&byline=0&portrait=0&autoplay=1

QUESTIONS….. 17 49 Star American Flag – Printed at the Bleachery 1959