EPA Looking at PCB Levels in Caulk
June 7, 2010
Please coordinate with your facilities and/or environmental health and safety staff to complete this short survey about PCBs at your college or university. In order to respond to a request for information from the Environmental Protection Administration on PCBs in buildings, we need data from your institution to better understand the potential impact. The deadline for the anonymous survey is Friday, June 11.
On April 7, the U.S. EPA published an Advanced Notice of Proposed Rulemaking (ANPRM) entitled Reassessment of Use Authorizations for PCBs. Most of the ANPRM proposes measures to more strictly regulate PCBs and accelerate the phase-out of PCB equipment and other uses that are currently authorized. If this proposal becomes law, EPA may require colleges and universities to perform another round of testing and disposal of capacitors, transformers, and other electrical equipment, depending on the specific requirements of the final rule. If your institution has already disposed of most electrical equipment and articles that contain PCBs, a new phase-out will not have much impact.
The ANPRM also addresses the emerging issue of PCBs in caulk, as well as PCBs discovered in paint, mastic, and other unusual places. PCBs have been found in exterior caulk in university buildings in the Northeast and Midwest, and in secondary school buildings in New York City. EPA rules do not "authorize" PCBs in caulk (or paint, mastic, etc.) at concentrations greater than 50 parts per million (ppm), so-when it is discovered-building owners are obligated to immediately remove it and clean adjacent surfaces and soil to 1 ppm. While the health and environmental risks of PCB-containing caulk are not clear, a building cleanup can easily exceed $100,000. Because of the difficulty and cost of immediate removal, some institutions have instead negotiated consent agreements with EPA. PCBs assuredly exist in the caulk of some non-educational buildings, and may exist in other areas of the U.S.
NACUBO and others in the higher education community have formed a workgroup to draft an ANPRM comment letter, due on July 6. The letter is likely to focus on PCBs in caulk because of its potential financial impact. In particular, the ANPRM proposes to authorize PCBs in caulk, and the workgroup supports this. Because so little testing has been done, few campuses know the potential extent of the financial impact of finding PCBs in building caulk. It could be great, so this ANPRM may be an important opportunity for all institutions to encourage EPA to adopt a risk-based approach to safely manage and remove PCB-containing caulk over a reasonable period of time.
Please plan to help in two ways:
- Within a few weeks, NACUBO and the working group will advertise a survey (primarily through the Campus Safety, Health, and Environmental Management Association) to be completed anonymously, to assess the impact of this rule on colleges and universities. Please plan to participate, or forward it to the most appropriate environmental health and safety professional on your campus.
- NACUBO will send the community comment letter for colleges and universities. NACUBO asks that member institutions submit letters of support. Please plan to comment.
View the complete ANPRM here.
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