PCBs in Building Materials

PCBs in Building MaterialsPCBs in Building Materials

Kim Tisa, PCB Coordinator - US EPA Region 1Kim Tisa, PCB Coordinator - US EPA Region 1 Environmental Business Council – Connecticut ChapterEnvironmental Business Council – Connecticut Chapter

March 30, 2011March 30, 2011

Formulating PCBs into AroclorsFormulating PCBs into Aroclors (1016, 1221, 1232, 1242, 1248, 1254, (1016, 1221, 1232, 1242, 1248, 1254,

1260, 1262, 1268)1260, 1262, 1268) Monsanto was only Monsanto was only

US producer US producer Only about 130 of Only about 130 of

the 209 congeners the 209 congeners were used in were used in commercial commercial formulationsformulations

>50 different >50 different congeners were used congeners were used in an Aroclor mixturein an Aroclor mixture

Range from oily Range from oily liquids to waxy solids liquids to waxy solids at room temperatureat room temperature

Last two digit = % Last two digit = % Chlorine by massChlorine by mass

PCBs Chemical PropertiesPCBs Chemical Properties

– Attractive Properties to IndustryAttractive Properties to IndustryLow flammabilityLow flammabilityFire resistantFire resistantChemical stabilityChemical stabilityElectrical insulating propertiesElectrical insulating propertiesDurability Durability Resistant to degradationResistant to degradationSoftener and plasticizerSoftener and plasticizer

PCBs in Industrial ApplicationsPCBs in Industrial Applications

TransformersTransformers CapacitorsCapacitors Hydraulic fluidsHydraulic fluids Oil-based paintsOil-based paints Fluorescent light Fluorescent light

ballastsballasts Lubricating & cutting Lubricating & cutting

oilsoils Floor finishesFloor finishes Fire retardantsFire retardants

Thermal Insulation Thermal Insulation materials (foam, felt)materials (foam, felt)

Caulking & groutCaulking & grout PVC coatings for PVC coatings for

electrical wire & electrical wire & componentscomponents

Carbonless copy Carbonless copy paperpaper

Inks and dyesInks and dyes Adhesives/masticAdhesives/mastic

U.S. Industrial Use of PCBs U.S. Industrial Use of PCBs

PCB UsePCB Use Pounds (mil)Pounds (mil) % of Total% of Total

CapacitorsCapacitors 630630 50.350.3

TransformersTransformers 335335 26.726.7

Plasticizer usesPlasticizer uses 115115 9.29.2

Hydraulics/lubricantsHydraulics/lubricants 8080 6.46.4

Carbonless copy paperCarbonless copy paper 4545 3.63.6

Heat Transfer fluidsHeat Transfer fluids 2020 1.61.6

Petroleum additivesPetroleum additives 11 0.10.1

Miscellaneous usesMiscellaneous uses 2727 2.22.2

TotalsTotals 1,2531,253 100100

Uses of Aroclor by TypeUses of Aroclor by Type

What are the human health What are the human health effects from PCBs?effects from PCBs?

Acute (short-term) – Irritation/burning of eyes, face, Acute (short-term) – Irritation/burning of eyes, face, and chloracneand chloracne

Chronic (long-term) – Liver disorders, reproductive Chronic (long-term) – Liver disorders, reproductive effects, developmental effects, and probably cancereffects, developmental effects, and probably cancer

PCBs also have numerous well-documented health PCBs also have numerous well-documented health effects, including cancer, for animals. effects, including cancer, for animals.

EPA - PCBs a probable human carcinogenEPA - PCBs a probable human carcinogen

Why the Concern - RegulatoryWhy the Concern - Regulatory

Courtesy of Weston & Sampson

CURRENT REGULATIONSCURRENT REGULATIONS

Section 6(e) of the Toxic Substances Control Act Section 6(e) of the Toxic Substances Control Act of 1976 (TSCA) generally bans the manufacture, of 1976 (TSCA) generally bans the manufacture, processing, distribution in commerce, and use ofprocessing, distribution in commerce, and use of PCBs after 1978, but provides for exceptions PCBs after 1978, but provides for exceptions based on an EPA finding of “no unreasonablebased on an EPA finding of “no unreasonable risk of injury to health or the environment.” risk of injury to health or the environment.”

Most of the exceptions take the form of Most of the exceptions take the form of authorizations, which include conditions, suchauthorizations, which include conditions, such as location restrictions, repair restrictions, andas location restrictions, repair restrictions, and concentration limits.concentration limits.

40 CFR Part 76140 CFR Part 761

REGULATORY CONSIDERATIONSREGULATORY CONSIDERATIONS

PCB regulations include owners and/or operators PCB regulations include owners and/or operators of PCB-contaminated property where the PCB of PCB-contaminated property where the PCB contamination exceeds allowable concentrations contamination exceeds allowable concentrations under the regulationsunder the regulations

TSCA authority has not been delegated to any of TSCA authority has not been delegated to any of the states, thus both EPA and state regulations the states, thus both EPA and state regulations will applywill apply

IssuesIssues

The use of PCBs in building products is prohibited under TSCA. The use of PCBs in building products is prohibited under TSCA.

Manufactured products containing PCBs have been found in Manufactured products containing PCBs have been found in many buildings and structuresmany buildings and structures

Caulk typically contains PCBs at very high levels - %Caulk typically contains PCBs at very high levels - %

The PCBs in the caulk migrate to a limited extent to The PCBs in the caulk migrate to a limited extent to surrounding materials (air, soil, masonry).surrounding materials (air, soil, masonry).

Typical renovation procedures can increase exposures to Typical renovation procedures can increase exposures to workers and building residents, including children.workers and building residents, including children.

Renovation/DemolitionRenovation/DemolitionConsiderationsConsiderations

Do I need to look for PCBsDo I need to look for PCBs

If I find PCBs, is my site regulated If I find PCBs, is my site regulated under TSCAunder TSCA

What are my cleanup optionsWhat are my cleanup options

PCBs in Building MaterialsPCBs in Building Materials

Bulk Product Waste (761.62)Bulk Product Waste (761.62)examples: caulk, applied dried paints, varnishes, other examples: caulk, applied dried paints, varnishes, other similar coatings or sealants, Galbestossimilar coatings or sealants, Galbestos

Performance-based disposalPerformance-based disposal

Disposal in Solid Waste LandfillDisposal in Solid Waste Landfill

Risk-based Disposal ApprovalRisk-based Disposal Approval

Daily Cover/RoadbedDaily Cover/Roadbed

Source RemovalSource RemovalPCBPCB Bulk Product WasteBulk Product Waste

Caulk removalCaulk removal– Strip outStrip out

Paint removalPaint removal– AbrasivesAbrasives– ChemicalsChemicals– HydroblastHydroblast

Management in PlaceManagement in Place

Not acceptable for Not acceptable for PCBPCB bulk product bulk product waste waste (§ 761.62)(§ 761.62)

May be acceptable for surrounding May be acceptable for surrounding materials (§ 761.61)materials (§ 761.61)

Possible Possible short-term interim measureshort-term interim measure– Consultation with EPAConsultation with EPA– Sampling may be requiredSampling may be required

PCBPCB Remediation WasteRemediation WasteOptionsOptions

Self-Implementing Option– § 761.61(a)

Performance-Based Option- § 761.61(b)

Risk-Based Option - § 761.61(c)

Adjacent Surfaces Adjacent Surfaces PCB Remediation WastePCB Remediation Waste

Grind/cut out areas Grind/cut out areas of contamination of contamination beyond “source beyond “source material”material”

EncapsulationEncapsulation

Clean non-porousClean non-porous

CTDEP Caulk GuidanceCTDEP Caulk Guidance

Caulk Guidance, cont’d.Caulk Guidance, cont’d.

Excluded PCB ProductsExcluded PCB Products

Must meet all criteria under § 761.3Must meet all criteria under § 761.3

May be left in place without further May be left in place without further restrictions/requirementsrestrictions/requirements

ANALYTICAL CONSIDERATIONS ANALYTICAL CONSIDERATIONS AND PITFALLSAND PITFALLS

1) Analytical and extraction requirements

2) Expected

concentration range

3) Required reporting limits

4) Special Instructions

Chain Of CustodyChain Of Custody

Concentration RangeRequired Detection

Limits

Lab Instructions

Methods

Quality Assurance/ Quality ControlQuality Assurance/ Quality Control

A properly planned analytical program with A properly planned analytical program with adequate QA/QC samples is criticaladequate QA/QC samples is critical

QA/QC Program should include:QA/QC Program should include: Field and Lab Duplicates Field and Lab Duplicates Method blanksMethod blanks Temperature blanksTemperature blanks Field Blanks and MS/MSDs Field Blanks and MS/MSDs Laboratory PEs – similar matricesLaboratory PEs – similar matrices

COMMUNICATION ISSUESCOMMUNICATION ISSUES

Project RequirementsProject Requirements

– MethodsMethods

• Sample extraction methods – Soxhlet extraction preferredSample extraction methods – Soxhlet extraction preferred• Extraction by sonication not preferred Extraction by sonication not preferred

– Inefficient, low PCB concentrationsInefficient, low PCB concentrations– Not applicable/appropriate to all matricesNot applicable/appropriate to all matrices– Not allowed under many state QA programsNot allowed under many state QA programs

• Alternative techniques require correlation study Alternative techniques require correlation study – – – Subpart QSubpart Q

-- Reporting limitsReporting limits

EPA Activities to DateEPA Activities to Date September 2009 (caulk guidance)

(fact sheets, Q’s and A’s, and a Schools Information Kit)

Steps to Safe Renovation and Abatement of Buildings that have PCB-Containing Caulk

Developed public health levels for PCBs in indoor air for schools

Conducting research on mitigation and exposures assessment on PCB sources in buildings (ORD)

ANPR - use and distribution in commerce of certain classes of PCBs and PCB items and certain other areas of the PCB regulations under the Toxic Substances Control Act

December 2010 (ballast guidance)

http://www.epa.gov/epawaste/hazard/tsd/pcbs

EPA RecommendationsEPA Recommendations

For buildings built between 1950 and 1978For buildings built between 1950 and 1978

– Minimize exposure (e.g. ventilation, cleaning)Minimize exposure (e.g. ventilation, cleaning)– Take care when renovatingTake care when renovating– Take care when abatingTake care when abating

If you think you may have a problemIf you think you may have a problem

– Test for elevated air levelsTest for elevated air levels– Test for source of air contaminationTest for source of air contamination

Evaluate duct systemsEvaluate duct systems Sample deteriorating caulkSample deteriorating caulk

Renovation and Abatement Renovation and Abatement BrochureBrochure

Information for contractors and building Information for contractors and building owners for characterizing, remediating, and owners for characterizing, remediating, and disposing of PCB-contaminated building disposing of PCB-contaminated building materials (e.g., masonry, wood, or brick), materials (e.g., masonry, wood, or brick), soils or sand, and caulk when conducting a soils or sand, and caulk when conducting a renovation/repair or abatement projectrenovation/repair or abatement project

Contacts and PCB InfoContacts and PCB Info Kimberly Tisa – EPA Kimberly Tisa – EPA

617-918-1527617-918-1527 tisa.kimberly@epa.gov

Gary Trombly – CTDEP Gary Trombly – CTDEP 860-424-3486860-424-3486

gary.trombly@ct.gov

Caulk Hotline: 888-835-5372Caulk Hotline: 888-835-5372

http://www.epa.gov/pcb