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Showing posts with label Environmental Protection Agency. Show all posts
Showing posts with label Environmental Protection Agency. Show all posts
We have discussed this case in our asbestos refresher classes and slowly but surely it is getting resolved. Paul Mancuso of Utica, New York was ordered to pay back $17,972.68 it cost the Environmental Protection Agency (EPA) to clean up toxic piles of asbestos that were illegally dumped in a rural Herkimer County field. On Tuesday, December 28, the prosecutor, Assistant U.S. Attorney Craig Benedict, said it is satisfying to know that Paul Mancuso will have to pay some financial penalty for what he has done. “We’re pleased that the judge has found Paul Mancuso responsible for repaying the taxpayers of the United States for money expended to clean up the asbestos that was illegally dumped as a result of the Mancusos’ criminal activities,” Benedict said.
Part 2 of the "Killer In The Attic" articles from AOL News discussed the story of 71 year-old William Cawlfield, who has mesothelioma. Mr. Cawlfield lives in a two-story red-brick farmhouse in Pueblo, Colorado that had been his family's home for more than a century. When he was 15 years old Mr. Cawlfield helped his father install Zonolite insulation in the attic. In addition, Mr Cawlfield also said "I used to play up there and kept my toys and a bunch of books because it was like a sand pile where I could hide things,..." He had no knowledge that the material contained asbestos.
Last month, Cawlfield stood outside his family's home watching a specially trained asbestos-removal experts wearing respirators and dressed head to toe in Tyvek carefully remove the Zonolite insulation from inside. He was paying $15,000 to have them do so. The reason he was doing this was testing conducted by the Environmental Protection Agency's (EPA) Denver regional office found that high levels of the lethal tremolite fibers were released from the Zonolite insulation that was spread between the rafters in its attic. EPA inspectors concluded that the almost-invisible asbestos-containing dust from the Zonolite sifted though the light fixtures and switches, ceiling fans and the seams of dried-out joint tape. Copies of the reports from EPA (that AOL News obtained) determined that some of the levels of asbestos recorded in the house exceeded the maximum number of lethal fibers that the Occupational Safety and Health Administration (OSHA) says is too dangerous for workers.
Unfortunately, EPA continues to not provide any guidance to the asbestos abatement industry on how to handle this material and continues to rely on its website as the only source of information on this dangerous situation.
Image via WikipediaIn the July 2010 issue of Indoor Environment Connections, Mr. Tom Scarlett writes about the Environmental Protection Agency (EPA) issuing a draft report that concludes that inhaling formaldehyde is definitely a human carcinogen. Formaldehyde is widely used in products and can be found in many indoor environments, like the temporary trailers that the Federal Emergency Management Agency (FEMA) bought. It has been widely published that those temporary trailers had such significant levels of formaldehyde in the indoor air they could not use them as temporary housing for the Hurricane Katrina victims. In addition, the new study also linked increased incidence of asthma to formaldehyde exposure. Needless to say EPA's determination will cause increased regulation of formaldehyde in air. The next steps for this report is for it to be reviewed by an expert panel convened by the National Academy of Sciences. EPA will then use the review and any comments from the public to complete the Health Assessment for Formaldehyde.
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:
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?
Today is the 40th Birthday of Earth Day. To celebrate the occasion, the Environmental Protection Agency's (EPA) Lead Based Paint (finalized in April 2008) regulation goes into effect today. The regulation we are talking about is the Renovation, Repair and Painting (RRP) rule. The purpose of this rule is prevent lead poisoning of children. Starting today anyone who is paid to perform work that disturbs paint in housing and child-occupied facilities built before 1978, including all general contractors, maintenance staff, and special trade contractors (such as painters, plumbers, carpenters, and electricians), are required to be trained on lead-safe work practices (become certified renovators), requires the firms to be EPA-certified, and requires the use of lead-safe work practices. In addition, the regulation requires the firms to keep records for three years of reports certifying that lead-based paint is not present, records relating to the distribution of the lead pamphlet, signed and dated opt-out clauses, and documentation of compliance with RRP. These regulations do not apply if the firm obtained a signed statement from the owner (known as the opt-out provision) or the work is considered a minor repair and maintenance activitiy that disturb six square feet or less of paint per room inside, or 20 square feet or less on the exterior of a home or building. The rule require firms performing renovations must ensure that:
All individuals performing activities that disturb painted surfaces are either certified renovators or have been trained by a certified renovator.
A certified renovator is assigned to each renovation and performs all of the certified renovator responsibilities.
All renovations use lead safe work practices.
Pre-renovation education requirements are performed, such as distribution of the Renovate Right pamphlet.
Violators of this regulation can face penalties of up to $32,500 per violation, per day. Needless to say if you have not taken this training and applied for EPA certification you cannot perform renovation work on housing or child-occupied facilities until you get your certification. EPA has up to 90 days after receiving a complete request for certification to approve or disapprove the application. EPA has said "it does not intend to take enforcement actions against firms who applied for firm certification before April 22 and are just waiting for their paperwork." EPA also said "they anticipate that all applications filed before April 22 will be reviewed by June." Based on EPA's website they estimate there are 129,000 to 150,000 trained certified renovators by today. It would seem those certified renovators are going to be very busy.
On March 8, 2010, the Environmental Protection Agency (EPA) released a detailed technical assessment of the first phase of the dredging operations on the polychlorinated biphenyl (PCB)-contaminated sediment in the upper Hudson River. This assessment, along with General Electric's assessment, are being submitted to the panel of independent scientific experts for review. In addition, to the report being submitted to the scientific panel, EPA is also soliciting comments from the public that will also be submitted to the panel. The first phase of this project is being used as a test run for the far larger phase 2 of this project, which EPA hopes to start in 2011. The technical report is 185 pages and covers a number of operations and discusses problems and recommended changes to reduce PCB air emissions and water resuspensions. Needless to say EPA feels that the operation can be done successfully with a few changes and GE has some major issues with the process because of the PCB resusensions. It will be interesting to see what the panel has to say.
On May 15, 2009, the Environmental Protection Agency (EPA) announced the start of dredging operations on the upper Hudson River. The goal of this project is to remove approximately 113,000 kilograms of polychlorinated biphenyls (PCBs) from the river by 2015. General Electric Company’s (GE) Fort Edward and Hudson Falls plants legally released the PCBs into the river from 1944-1997. GE is conducting the dredging and related work under the terms of a November 2006 consent decree, after EPA ordered GE to dredge the tainted sediment from the river and dispose of it. The Hudson River covering a 200 mile stretch is the largest superfund site in the United States.
The Good – the ultimate goal of this dredging operation is to restore the health of the river, to enhance regional tourism and commercial opportunities, and improve commercial and recreational fishing in the Hudson River between Fort Edward and Albany currently prevented by the PCB contamination. The Hudson River dredging plan is based on a previous successful PCB dredging project along Lake Champlain in Plattsburgh, NY. The plan includes daily water sampling downstream from the dredging operations, these sampling results must average below 500 parts per trillion of PCBs, which is the same as the drinking water standard, for dredging operations to continue. On August 5, 2009 dredging operations stopped because sampling results exceeded the standard. A review of the operations called for enhanced engineering controls. The enhanced engineering controls allowed dredging operations to resume on August 11, 2009. There have been no reported problems since.
The Bad – transporting the PCB sediment to its eventual resting place in Texas will take a 2,000 mile trip through a number of states. The PCB-sediment will be dewatered in Fort Edward packed onto a 81-car train and tightly wrapped in heavy-duty plastic. EPA deemed rail travel as the safest method of transporting the soil. The national rail traffic will determine the ultimate route of the train and it will take about five days to get to Texas. The Lone Star Chapter of the Sierra Club notes in their release dated February 11, 2009, “that an environmental impact statement has not been prepared for the proposed rail shipment. The shipment poses a potential for serious accident hazards in or near dozens of urban areas and states through which trains would pass. One major rail accident could lead to a catastrophic contamination event if drums were breached and highly concentrated PCBs were released.” According to The Saratogian article “Hudson River PCBs en route to West Texas”; the Federal Railroad Administration’s safety data, 726 accidents involving trains carrying hazardous materials occurred in 2008, more than half of those in the rail yard. Everything from a slight bump in a rail yard to a major derailment qualifies as an “accident” in that report. Examples of the type of derailments covered by the report include, the 2 that occurred within 24-hours of each other on September 26 & 27, 2009 in Montana and Wyoming. These derailments involved minimal spillage and the cars remained erect. While other derailments like the one that occurred on January 22, 2002 that caused a toxic cloud of anhydrous ammonia near the town of Minot in North Dakota, still have an effect on the people who live there, even years later. That derailment required the digging up of 97,000 tons of contaminated soil and 25,000 square feet of river ice and more than 1,000 people affected according to USA Today. An Environmental Impact Statement would at least look at the possible consequences of a derailment and try to anticipate a derailment that would be catastrophic.
The Ugly – the final resting place for the estimated 2.65 million cubic feet of PCB-contaminated sediment is Waste Control Specialists (WCS) in Andrews, Texas. Rural Andrews County, Texas is a desolate desert county just over the New Mexico border and consists of 1500 square miles and a population of about 14,000 people. Andrews, the only incorporated city in the county, has a history more than a decade long of hazardous waste disposal. A study commissioned by the town and performed by the professors at Texas Tech University determined that hazardous waste disposal was a suitable industry for the city and county, because the red-bed clay found there is a natural impermeable liner and the area where WCS located their site does not overlap the Ogallala Aquifer. WCS as an EPA permitted toxic waste facility accepted the first load of PCB sediment on June 28, 2009. Prompting a backlash, from the people in the area, regarding the feasibility of dumping the PCB-contaminated sediment at the WCS facility. The Lone Star Chapter of the Sierra Club wrote a letter to the EPA Administrator Lisa Jackson urging a halt to the shipping of the PCB wastes to Texas. Is it a case of “not in my backyard” (NIMBYism)? Maybe not, there seems to be a disagreement on whether the WCS facility is over or close enough to the Ogallala Aquifer (a sensitive underground water resource). The claims range from 14 feet to 500 feet to the nearest water table. The Ogallala Aquifer stretches from South Dakota to Texas and is the largest aquifer in North America. It seems that the concerns of the Lone Star Chapter of the Sierra Club may be justified. It seems that EPA should have checked to make sure how close this waste facility actually was to the Aquifer.
Like all hazardous material/waste situations, cleaning up the problem brings up many questions some good, some bad, and some downright ugly. However, if we ask the questions and we look at the problems carefully and thoroughly, we can eventually solve these problems to the satisfaction of all concerned and involved.
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