Spring 2010 Future Focus Posted

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Future Environment Designs has posted its Spring 2010 newsletter finalizing our coverage of the revisions to the New York City asbestos regulation Title 15.  This issue we discuss the changes to the work procedures/practices.

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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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New Lead Paint Regulation Goes Into Effect - Happy Earth Day!

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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.
• Recordkeeping requirements are met.

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. 

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Long Island ASSE/Metro NY AIHA Joint Meeting to Discuss PCBs

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

EPA Submits Final Report on First Phase of Hudson River Dredging

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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.

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