PCBs are Everywhere?

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It feels like lately, everywhere I turn I find a new article or seminar discussing polychlorinated biphenyl (PCB) issues.  In the Metropolitan New York Chapter of American Industrial Hygiene Association's newsletter I learned that the Environmental Protection Agency (EPA) is currently holding a series of public meetings for the purpose of “Advance Notice of Proposed Rulemaking on the EPA potential reassessment of PCB use authorizations” (follow link from the title of this article for more information).  Even on this blog I have written several posts on PCBs (see my most recent post on 4/6/10).  Back in April, I attended the joint meeting of the New York Metro Chapter of the AIHA and the Long Island chapter of the American Society of Safety Engineers (see post on 4/20/10). Mr. Kristen Panella of New York Institute of Technology gave a very good presentation on dealing with the Environmental Protection Agency (EPA) regarding transformers containing PCBs. The main points of the presentation were:

• EPA does not allow “placard” transformers (meaning the transformer has pyranol on the label or placard) to be registered after 1998.  EPA’s reason for this is that General Electric’s pyranol transformers contain 50% PCBs be weight.
• These placard transformers are required to be removed. The penalty is $24,000 for not removing them.
• The removal process is a costly and very delicate process because any spill of the PCB oil makes the project a remediation (spill clean-up) having different requirements.

Then in the April 2010 issue of Indoor Environment Connections, Ronald Smith and Vincent Daliessio of EMSL wrote an article on “PCB in Caulk: A New/Old Indoor Contaminant” (http://www.ieconnections.com/pdfs/newsletter/2010/IEC-04-2010.pdf on page 18).  The main points from this article were:

• PCB-tainted caulk with concentrations of 50 parts per million (ppm) or more can cause owners of buildings (including schools, etc.) to face EPA fines of $3,000 and $25,000 per day until the material is removed.
• EPA regulations do not require schools to test for PCBs but EPA is encouraging schools to conduct air testing where PCB use is suspected.  This recommendation is inconsistent with other indoor air quality programs (i.e., asbestos or lead) that would first require identifying or testing to confirm the presence of the material prior to an air sampling regimen.  I suspect the reasoning for this is; unlike with asbestos or lead, if the school finds PCBs in the caulk above 50 ppm they are required to remove it, as per the above point.
• There are a number of exposure guidelines and standards for chlorodiphenyl (54% chlorine in PCBs) in air:
• ACGIH – TLV is 500 ug/m3
• OSHA – PEL is 500 ug/m3
• NIOSH – REL is 1 ug/m3
• NYC Department of Health and Mental Hygiene – Action Level is 0.5 ug/m3
• EPA – Risk-Based Concentrations (RBCs) is 0.0043 ug/m3
• Testing of caulk for PCBs is a unique method and should be discussed with your laboratory.  PCB air testing uses two methods, recognized by the EPA, TO-4A (high volume air) and TO-10A(low volume air).  EPA does not recognize NIOSH method 5503.

In addition, two recent EPA Region 2 news releases were also regarding PCBs.  On this blog, we have been following the dredging operations on the Hudson River.  EPA’s news release on April 26, 2010 announced that EPA agreed to pay the additional costs incurred by the towns of Halfmoon and Waterford to draw water from the Troy system until November 2012 because both towns used the Hudson River as their source of drinking water.  Some of the samples taken at the Thompson Island monitoring station were reported to have exceeded EPA’s drinking water standard of 500 parts per trillion (ppt) for PCBs, during dredging operations and off-season high river flows.  The second EPA region 2 news release was on April 30, 2010 and it too, discussed PCBs. PCBs are one of the contaminants they are investigating in the Gowanus Canal Superfund Site in New York City.

Even though Congress and EPA banned and phased out in 1979 all PCBs, we are still working on preventing further damage and cleaning up the old damage done to the environment are these future employment opportunities?

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