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PCB Chemical Action Plan(CAP)
Holly Davies, PhD First I’m going to talk about why we have focused on PBTs and how we use CAPs to address them. Then I’m going to talk about the PCB CAP in particular.
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What’s a CAP? Chemistry Monitoring Sources Laws and Regulations
Plan that identifies, characterizes, and evaluates uses and releases of a PBT and recommends actions to protect human health and the environment Chemistry Monitoring Sources Laws and Regulations Health effects Policy Options Human Wildlife Economic analysis Recommendations
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Process for Preparing CAPs
Plan and collect information with different programs within Ecology and DOH External advisory committee Develop draft recommendations Public review and comment on draft CAP Final recommendations/Final CAP Implementation
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Legacy Sources/Uses (pre-1979 TSCA)
EPA PCB Inspection Manual EPA PCB Inspection Manual Different definitions of sources and pathways KLIF EPA EPA
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Current Generation Inadvertent generation Combustion Pigments and dyes
Titanium dioxide Other Combustion
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Pathways Surface runoff/stormwater Air deposition WWTP
Industrial discharges Seattle Post-Intelligencer “The Zone”
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PCB Priorities Source Legacy reservoir of PCBs
Annual releases of PCBs (kg/yr) Potential exposure pathways and concerns Is the release controlled? Priorities Historic uses transformers kg < 2 Accidental spills, which are identified and cleaned up. Yes large capacitors 20 metric tons 10 to 80 lamp ballasts metric tons 400 to 1,500 Continual release of lower concentrations, with high concentrations released when the ballast fails. In school buildings as part of energy efficiency improvements. small capacitors 1-35 metric tons 3 to150 Disposal in landfills from a variety of old appliances. caulk 87 metric tons 160 Continual release of lower concentrations into the air, with high concentrations released when materials are disturbed. No Remodeling and demolition, especially in schools. Current generation pigments and dyes N/A 0.02 to 31a Continual release of lower concentrations, with higher concentrations released during recycling. Identify and promote safer alternatives. other inadvertent generation 900 Concerns about both continual releases and potential large releases. Identify processes and products first and then identify and promote safer alternatives.
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PCB CAP Recommendations
1. Survey and assess PCB-containing lamp ballasts in schools and other public buildings. Encourage replacement with more energy efficient PCB-free fixtures. 2. Develop and promote Best Management Practices (BMPs) for containment of PCB-containing materials in buildings currently in use and those slated for demolition. 3. Assess schools and other public buildings for the presence of PCB-containing building materials. 4. Learn more about what products contain PCBs and promote the use of processes that don’t inadvertently generate PCBs. 5. Survey owners of historic electrical equipment. 6. Expand environmental monitoring to identify any new areas requiring cleanup. 7. Conduct a public educational campaign. 8. Conduct a study on which PCB congeners are present in Washington residents. Slide is here for completeness, but I won’t read it.
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