Future Environment Designs Training Center specializes in asbestos, indoor air quality, industrial hygiene, and occupational safety training programs. We offer New York State asbestos and mold certification courses. We design, develop, and maintain the various indoor air quality, asbestos, and safety programs that are Keeping Your Employees Safe.
In addition, to sponsoring this video to assist with Keeping Your Family Safe by being aware about Poly-Chlorinated Biphenyls (PCBs). We want you to be aware that New York Communities for Change is calling on the New York City Board of Education to test all schools for possible PCB contamination and devise an aggressive plan for remediation. After watching the video click on the title to learn more about New York Communities for Change's demand.
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?
Wednesday April 21, 2010 at 5 PM, Mr. Kristen Panella, CSP of New York Institute of Technology will be discussing "Recent Compliance Issues with PCBs - Lessons Learned." The meeting is a joint dinner with the Long Island American Society of Safety Engineers and the Metro Chapter of the American Industrial Hygiene Association. It is being held at the Hicksville-On The Border, 1401 Broadway Mall, Hicksville, NY 11801.
Mr. Panella is the Dir. of the Dep. of Environmental Health and Safety at New York Institute of Technology (NYIT). Kristen has over 11 years of professional experience in the environmental health and safety field. With a background in geology and environmental management he has worked on numerous EPA Superfund sites as well as emergency hazardous material spill cleanup sites. Kristen joined NYIT as the Dir. of EH&S over 4 years ago and is accountable for all environmental health and safety issues that face their three campuses. His primary focus is on asbestos, lead and mold projects, hazardous waste disposal, medical waste disposal, the proper operation of the onsite wastewater treatment plant and OSHA related issues. Kristen is also utilizing his real world expertise to conduct classes in the Environmental Technology Masters and Continuing Education Programs. He is an active member of AIHA, ASSE, CSHEMA, SEHSA and NYIT’s Radiation Safety Committee, Animal Care Committee, Biosafety Committee and Sustainable Global Community. Join us for dinner and a great presentation. Registration and Networking will begin at 5 PM. Dinner @ 6 PM
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.
Prompted by the Daily News, NYS Education Department tested several city schools for Polychlorinated Biphenyls (PCBs) in caulk and found six of the nine schools tested positive. However, only one of the schools tested positive for PCBs in the air. As we learned at the Professional Abatement Contractors of New York (PACNY) meeting a few months ago, the NYS Education Department was already requiring new projects impacting window caulk in buildings built between 1950 and 1977 to evaluate the caulk and submit a remediation plan for addressing the caulk (http://www.emsc.nysed.gov/facplan/HealthSafety/PCBinCaulkProtocol-070615.html).
According to the Agency for Toxic Substances & Disease Registry (ATSDR), PCBs may reasonably be expected, and probably can cause cancer of the liver or biliary tract. The Environmental Protection Agency (EPA) classifies PCBs as a Group B2 Probable Human Carcinogen and International Agency for Research on Cancer (IARC) classifies PCBs as a Group 2A, probably carcinogenic to humans. Some animal studies showed that animals that ate small amounts of PCBs in food over several weeks or months developed health effects such as: anemia; acne-like skin conditions; and liver, stomach, and thyroid gland injuries. Human studies, in particular women who were exposed to relatively high levels of PCBs in the workplace or ate large amounts of fish contaminated with PCBs, showed these women had babies that weighed slightly less than babies from women who did not have these exposures. The studies also showed babies born to women who ate PCB-contaminated fish had abnormal responses in tests of infant behavior. According to ATSDR, some of these behaviors, such as problems with motor skills and a decrease in short-term memory, lasted for several years. Other studies suggest that the immune system was affected in children born to and nursed by mothers exposed to increased levels of PCBs. There are no reports of structural birth defects caused by exposure to PCBs or of health effects of PCBs in older children. If you wanted to know if you were exposed to PCBs there are blood tests that can be done. However, everyone has some level of PCBs in their body due to environmental exposure.
There are several websites to get information on this issue which is starting to be recognized by schools, government, and the public. EPA's website has a section on PCBs in caulk: http://www.epa.gov/pcb/pubs/caulk.htm#content. Dr. Daniel Lefkowitz was one of the presenters at the PACNY conference and his website would like to see mandatory testing of caulk in schools is: http://www.pcbinschools.org/. Dr. Daniel Lefkowitz found PCB in the caulk at the school his children went to.
EPA's Region 2 is recommending that samples taken of caulk or soil that will be analyzed for PCBs should use a Soxhlet extraction method (an example of this would be EPA method 3540C) using toluene as a solvent. The extraction should then be purified with concentrated sulfuric acid (similar to EPA method 3665A) and purified with florosil (similar to EPA method 3620B). The purified extraction would then be analyzed by gas chromatography with an electron capture detector (similar to EPA method 8082). The results are to be reported in total PCBs in parts per million (ppm). If the results exceed 50 ppm then those materials are regulated.
If you determine you have PCBs in the caulk or soil you should contact EPA's Region 2 coordinator Mr. Jim Hattler (732-906-6817). Mr. Hattler is willing to assist facility owners in developing a plan on the handling of any materials determined to contain PCBs. He has emphasized that these materials may not need to be removed, but would like to ensure that any clean-ups address all materials containing PCBs (caulk, soil, or its migration into other building materials). EPA is currently in an assistance mode on this matter and is currently developing a guidance document to assist facility owners. EPA's website includes a specific section on PCBs (http://www.epa.gov/pcb/).
Remember when taking samples of PCBs you have to protect yourself from both inhalation and dermal exposures. The OSHA Permisible Exposure Limit (PEL) for PCBs is based on chlorodiphenyl 42% or 52 % chlorine (Table Z-1 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9992). The PEL for chlorodiphenyl (42% chlorine) is 1 milligram per cubic meter or chlorodiphenyl (54% chlorine) is 0.5 milligram per cubic meter. Analysis methods for personal air samples are NIOSH 5503 or OSHA PV2088. OSHA recommends that you wear rubber gloves that will not absorb PCBs and consider using goggles or a face shield (if using a full mask air purifying respirator (APR) the goggles or face shield are not needed) and a rubber apron. Avoid personal contamination by not touching your face while wearing gloves. If you get PCBs in your eyes, irrigate your eyes immediately. If you get PCBs on your skin, wash the skin wth soap and water immediately. The recommended respiratory protection would be a full mask APR utilizing a duo cartridge with protection for organic vapors and having P100 filters. For more information on chlorodiphenyl (54% chlorine) you can visit the National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards (http://www.cdc.gov/niosh/npg/npgd0126.html).
As we previously discussed, I was attending the 12th Annual PACNY Environmental Conference. It was an excellant conference that brought out some new developments in the Abatement Industry. Mr. Christopher Alonge, PE of the New York State Department of Labor, was one of the presenters that most people were anxious to hear from and as usual he did not disappoint the attendees. What has become standard practice at this event Mr. Alonge gave those present some food for thought. First, Mr. Alonge announced a new Petition for an Asbestos Variance Form (SH 752) and the possible release sometime in 2008 of two new variances; "Mechanical fastening of items/components or systems - penetrating through non-friable ACM - Not considered an Asbestos Project" and "Small & Minor Size Asbestos Disturbance Cleanup Projects - to be used for cleanup of all types asbestos disturbances". This new Variance form should be on the DOL website this month (the form is currently on our discussion board website at (http://groups.google.com/group/fed-forum/web/new-petition-for-an-asbestos-variance-form-sh-752). Mr. Alonge also announced a new guidance document (v2.0) that should be on the website in the next few months that will have 120 new questions/answers added. Mr. Alonge is also in the process of working on a new ICR56 that will incorporate some Fire & Life Safety Issues (because of lessons learned at the Deutsche Bank Building tragedy) some examples include the use of fire retardant sheathing, negative air disconnect switch, and maintaining existing fire protection systems.
Another interesting presenter was Thomas V. Roberts, RA from NYS Education Department. Mr. Roberts informed us that NYSED developed "Protocols for Addressing Polychlorinated Biphenyls (PCBs) in Caulking Materials in School Buildings" in June 2007 (http://www.emsc.nysed.gov/facplan/HealthSafety/PCBinCaulkProtocol-070615.html). This protocol is recommending that any school buildings constructed or renovated between 1950 and 1977 and undergoing current renovation or demolition, be evaluated prior to the renovation work to determine whether they contain caulk that is contaminated with PCBs. NYSED would require a PCB abatement plan be submitted with the renovation or demolition drawings addressing the potential environmental and public health concerns in abateing the caulk. If plans are submitted without the PCB evaluation, the plans will be rejected.
Maureen Cox, NYS DOL Director of Safety & Health, presented that DOL has seen a 12% increase in penalties collection this past year and would like to see Senate Bill 372 known as Successor Legislation, pass. The point of this legislation would be to prevent the owners of an asbestos abatement company from closing their business to avoid fines and then open under a new company to continue to do abatement work. The legislation would also increase the penalties and fines issued under the Industrial Code Rule 56.
PACNY introduced the PACNY Asbestos Proficiency Initiative, the purpose of this initiative is to create a certification that will be administered by PACNY that will establish another level of certification specifically for Project Monitors, Supervisors, and Project Designers. To be able to take the computer based certification exam, which will be offered through Slyvan Learning Centers, the individual must show three years of DOH 2832s. The exam will be given in two parts, part 1 will be a 50 question closed book exam and part 2 will be an open book scenario-based questions. PACNY Proficiency Certification (PPC) will require the accumulation of 20 hours of certification maintenance each year and the taking of a refresher exam also at the Slyvan center.
The conference as always was very interesting and exhibit had the usual suppliers Grayling Industry showing off the New Larger Pop-up Decon meeting NYS DOL requirements, and Cole Stanton from Fiberlock Technologies who discussed the revision to the use of chemical tools to the S520 standard from IICRC. IICRC stands for the The Institute of Inspection, Cleaning, and Restoration Certification which publishes the S520 Standard and Reference Guide for Professional Mold Remediation. The new standard which should be out before the end of 2008, basically says that unique circumstances may arise allowing the consideration of antimicrobial coatings, or biocides.
The event is usually held at Turning Stone Casino and it appears that next year's event will be around the same time, we hope to see you there next year.
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