PCBs in Building Materials:

A Consultant Perspective

Robert L. May Jr.

January 6, 2011

2

Outline ● Background

● Reactions

● Building Materials

● Remediation Process

● Consultant Challenges

● Cost Analysis

● Case Study

Background

4

What Are PCBs? ● Polychlorinated biphenyls

● A group of man-made chemicals

209 congeners which is any single, unique

chemical compound in the PCB category

Different degradability

Potential Toxicity varies

9 Homologs which are subcategories of

PCB congeners having equal numbers of chlorine

PCBs are very stable

No known natural sources of PCBs

Nearly everybody has traces in body Commonly known to be used in electrical equipment, industrial processes, and

manufacturing

Common Trade Name: Aroclor (16 types)

Banned from production in 1979

● Non-polar/hydrophobic

Do not easily dissolve in water

Binds strongly to sediment particles

Fat soluble and stored in an organism's fatty tissue

dep.state.ct.us/wst/pcb/pcbindex.htm www.epa.gov/pcb/ www.trwnews.net/isdioxindangerous.htm

1

3’

2’1’

54

3

2

4’5’

1

3’

2’1’

54

3

2

4’5’

1

3’

2’1’

54

3

2

4’5’

Structure of Polychlorinated Biphenyl

5

Brief History ● 1881: First Synthesis

● 1914: Measurable amount in bird feathers

● 1927: PCBs first manufactured in Alabama (Swann)

● 1929 PCBs were domestically manufactured

● 1930’s: First worker health problems & studies

● 1935: Monsanto bought Swann

● 1947: GE began using PCBs in electrical equipment

● 1950’s: Toxicity of PCBs of concern but not fully acted on

● 1960’s: Increasing awareness of PCB hazards

● 1968: 1300 Japanese residents ate rice contaminated with PCBs

● 1970’s: Increased study into PCBs toxicity

● 1970’s: Government gets involved

● 1979: EPA issues final regulations banning manufacture of PCBs

● Late 1980’s: Companies cleanup and stop using PCBs

● Early 90’s: EPA declares PCB carcinogens, endocrine disruptors, and reproductive toxins

● 2000: United Nations Environment Program committee ban on PCBs

● 2009: Guidance for Caulking related to schools

● 2010: Advanced Notice of pending Rule Changes (6 Public Meetings Held)

Adapted from: “Lake Michigan Mass Balance Study - PCB Modeling Report” Ronald Rossmann, Editor, EPA-600/R-04/167 December 2006

Reactions

7

Harvard Study ● July 2004 – HSPH Press Release

● 24 Buildings Tested

● 1/3 or 8 of 24 Exceeded 50 ppm PCB

● Up to 33,000 ppm PCB

● Caulk Unrecognized and Widespread Source of PCBs

● Recommends Routine Testing of Caulk

Robert F. Herrick, Michael D. McClean, John D. Meeker, Lisa K.

Baxter, George A. Weymouth. “An Unrecognized Source of PCB

Contamination in Schools and Other Buildings.” Environmental

Health Perspectives. 2004, 112 (10), 1051.

8

Boston Globe – Sept. 2009

9

Regulations

● PCBs in caulking and sealant materials was never authorized by EPA for use

Use is not authorized

Highly unlikely to be authorized

● EPA 40 CFR part 761 (

761)

Marking

Manufacture

Processing

Distribution

Use

Storage

Disposal

10

Federal Response to PCBs

● EPA Region 2 response Nov 3, 2005

No visual differences between PCB and non-PCB caulk

Testing “may be advisable”

“use of PCBs in caulking...has never been authorized... because it is illegal and the potential for exposure is significant, PCB containing caulk must be removed upon discovery.”

Remediation and disposal covered under current regulations (40 CFR part 761)

● EPA Released guidance documents

in 2009

11

Federal Response to PCBs So What is EPA telling the Public?

● Focus has been toward guidance for Schools Many Fact Sheets and Guidance Documents Available from EPA

● Guidance suggests testing air in school buildings Public Health Levels for PCB established by EPA.

● EPA suggests that removal of PCB caulking should occur during renovations or repairs for buildings built or renovated between 1950 and 1978. In order to know if PCBs present will require testing

● Test caulking if damaged, such as peeling brittle, cracking or visibly deteriorating and properly remove if PCBs present at “significant levels” A significant level would be at regulated concentration of 50 ppm or

greater

● EPA is planning to study PCBs over next two years to develop further recommendations

12

Media Coverage ● URI Chafee Social Science Center Building in Kingston

Campus, URI News Bureau 2000

● Harvard Study, Boston Globe 2004

● UMASS Amherst Science Building, Daily New Hampshire Gazette 2006

● New Bedford H.S. Standard Times 2006

● Doherty Memorial H.S., Worcester Telegram & Gazette Corp 2009

● Berkshire Community College, Berkshire Eagle 2009

● Crompton Park Pool Worcester Telegram & Gazette Corp 2010

● Lexington Estabrook School, Boston Globe 2010

● CT Technical Schools Tested 2010, New Haven Register

● New York, EPA Pilot Study, Three Schools Elevated PCB air levels, West Side Spirit 2010

*source: www.pcbinschools.org

PCBs in Building Materials

14

Properties of PCBs

Low Flammability

Chemically Stable

Fire Resistant

Electrical Insulator

Softener and Plasticizer

Durable and resistant to

degradation

15

PCB Uses

U.S. Industry Use of

PCBs (1929-1975)

1.2 Million Pounds

Capacitors and

Transformers (>75% of

total usage)

Plasticizer (<10% of total

usage)

Miscellaneous Industrial

Applications >2% of total

usage

Sourec EPA, January 30, 1997.

16

PCB Uses Commercial Use of PCBs

Although no longer commercially produced in the United States, PCBs may be present

in products and materials produced before the 1979 PCB ban. Products that may

contain PCBs include:

● Transformers and capacitors

● Other electrical equipment including voltage regulators, switches, re-closers, bushings, and electromagnets

● Oil used in motors and hydraulic systems

● Old electrical devices or appliances containing PCB capacitors

● Fluorescent light ballasts

● Cable insulation

● Thermal insulation material including fiberglass, felt, foam, and cork

● Adhesives and tapes

● Oil-based paint

● Caulking

● Plastics

● Carbonless copy paper

● Floor finish

17

Suspect Building Materials

Remediation Process

19

Remediation Decision Tree

Source-www.epa.gov

20

Remediation Steps 1. Identify suspect PCB material

Physical inspection

Identify pre-1980 construction

Review of architecture plans

Review construction and remodeling history

2. Sample and Test Suspect materials

Adjacent material

Air

Soil

3. Determine exposure level How often people interact with material?

How could people interact with material?

4. Determine method to minimize exposure Removal

Barrier

5. Disposal Verify PCB material left is below allowable concentration

Unregulated waste

Regulated waste

21

1. Identify Suspect material

22

2. Sampling ● Types of Samples:

Building material (ex. Caulk, paint, etc...)

Wipe

Soil

Air

● All adjacent surfaces potentially impacted by PCB Product

● Discrete sample

● Composite sample Combination of up to 9 discrete samples

Increases throughput

If <1/x of goal then all samples pass

● All potentially impacted and adjacent materials

23

2. Sampling

● Bulk Source Materials Containing ≥50 ppm

PCBs are regulated.

● Materials containing less than 50 ppm PCBs,

must determine if an “Excluded PCB Product”

as defined in

761.3 below.

The products or source of the products containing

< 50 ppm concentration PCBs were legally

manufactured, processed, distributed in commerce,

or used before October 1, 1984.

24

2. Testing ● Extraction

EPA Method 3500B/3540C

Soxhlet

● Analyze the extracted material

EPA Method 8082

● Air Sampling

EPA Method TO-4A or TO-10A

Aroclor – All or Specific

Homologs - 9

Congener – 209

EPA may specify detection limits

<0.1 micrograms/cubic meter

<0.05 micrograms/cubic meter

whale.wheelock.edu/bwcontaminants/analysis.

html

25

3. Exposure Determination

● Frequency

How often there is potential contact?

● Duration

How long is the contact?

● Occupancy

High

Low

26

3. Exposure Determination ● Condition of material

● Amount of material

● Path of exposure

● Environmental conditions

27

4. Removal Considerations ● EPA has three methods:

A. Performance-based

B. Self-implementing

C. Risk-based

● PCB bulk product waste “material” Solids

≥50 ppm PCBs at time of designation as waste

● PCB remediation waste “material” Waste as result of spill, release, or unauthorized disposal

No concentration set in definition

● Method depends on: Exposure evaluation and project intent

Concentration of PCBs in material

Time for completion

28

4A. Self-Implementing (§761.61a) ● Design cleanup procedure and submit to EPA

● Requires site characterization (

761 subpart N)

● Notify EPA 30 days prior to cleanup

● Cleanup levels for continued use (uncapped) Bulk PCB remediation waste and Porous surfaces

High occupancy ≤1ppm PCBs (>6.7 hrs/week)

Low occupancy ≤25ppm PCBs (<6.7 hrs/week)

Nonporous surfaces High occupancy 10 g/100 cm2 PCBs (>16.8 hrs/week)

Low occupancy 100 g/100 cm2 PCBs (<16.8 hrs/week)

Liquids

761.79(b)(1) &

761.79(b)(2)

Disposed according to approved plan

● Must verify cleanup

761 subpart O

● Records must be maintained for 5 years post cleanup

29

4B. Performance-Based (§761.61b) ● Follow prescriptive procedures from EPA

● No notification or approval required BUT... EPA reviews waste manifests & may ask questions if they

see PCB waste on the manifest

● Cleanup levels not specified Generally <1 ppm PCBs for unrestricted use

● Disposal TSCA approved

Chemical waste landfill

Incinerator

Decontamination method

Alternate method

State permitted landfill accepting PCB waste

● Records must be maintained for 3 years post cleanup

30

4C. Risk-Based (§761.61c) ● Other than self-implementing or performance-based

Sampling

Cleanup

If Planning to leave regulated concentrations of PCBs in place in any manner must file Risk Based Plan.

● Perform site characteristics and data

● Notify EPA in writing

● Include proposed methods

Must show:

1. No unreasonable risk of injury to health

2. No unreasonable risk to environment

Can include encapsulation

EPA will issue decision

31

5. Disposal

● Verification

Sampling

Analysis

Reports

● All data must be organized so that EPA can

review

● Reports kept on file

32

5. Disposal ● Any material ≥50 ppm PCBs

PCB bulk product waste (

761 subpart 62)

Disposal options TSCA approved

– Chemical waste landfill

– Incinerator

– Decontamination method

– Alternate method

State permitted landfill accepting PCB waste

Does not require EPA approval - generally

● Adjacent material <50 ppm PCBs PCB remediation waste (

761 subpart 61)

Disposal options {above options}

EPA approved method based on work plan – Must obtain EPA approval

33

General Specifications

Consultant Challenges

35

Consultant Challenges

● EPA does not mandate by regulation testing of

material.

● Each site is treated by EPA as a unique site

with potentially different requirements for

containment, post cleaning standards, post

verification and introduction of wipe and air

sampling for clearance.

● Client’s can be reluctant to test since not

mandated by EPA prior to renovation or

demolition unlike asbestos.

36

Consultant Challenges

● Project planning for renovation EPA has

indicated in guidance should be tested.

● Testing early enough in the process to be able

to plan and budget for work ends up requiring

potential interim sampling of air and wipe and

possible interim measures until such time as

materials are removed.

● If it is determined that PCB found inside

building in air or wipes, reactions of school

could be publically criticized.

37

Consultant Challenges

● Consultant must be knowledgeable of the process and familiar with current EPA positions.

● Consultant should suggest pro-active steps to assist schools and other clients in the process.

● For schools this should include full disclosure of intent to sample with public transparency with regard to results and findings.

● Sequence testing work such that decisions and knowledge of risk can be determined early in the process.

38

Consultant Challenges ● Prepare the clients for the time frames and cost

associated with all the testing steps. Source Materials

Adjacent Materials

Air and Wipe

● Prepare the clients for the time frames and allowances for EPA review and need for likely changes of Plans under 761.61(a).

● Discuss cost implications with client of the entire process and remediation. The costs for PCB Remediation and required post verification are more costly than similar building material contaminants such as asbestos.

39

Consultant Challenges

● PCBs in building materials is newer area of concern

being addressed in the market. As such contractors,

and consultants may not all be on same page

depending on their experience.

● Take part and stay on top of what is happening in the

industry.

● Look into local requirements and sensitivity to the

topic where work is being performed.

● Some states have different requirements and many

local communities are more sensitive from media

coverage.

Cost Analysis

41

PCB Cost Implications

● Identification and testing for PCBs in building

materials

Must use Soxhlet method (EPA Region 1)

● More costly than current methods

Our cost ~$100/sample (5 day)

● Must test adjacent substrates

Wipes, chips, and bulk

Chips difficult to collect

Must decontaminate between samples

● Preparation of plan for submission to EPA for self-

implementing or risk-based remediation projects

42

Contractor Costs

● Presently still new market area so costs can be

significantly unpredictable

● Example

Received 4 bids for same project

Bid 1 - $70,000

Bid 2 - $83,000

Bid 3 - $350,000

Bid 4 - $489,000

(awarded)

43

Factors Affecting Cost

● Containment procedures

Similar to asbestos

Even required for exterior removal to control dust emissions

● Labor intensive

Cut and remove caulk and scarify or remove adjacent substrates

Cost range $30-$50/LF

Cleaning

Critical piece

● Disposal

44

Disposal Costs

● Non-TSCA Waste

<50 ppm PCBs

$1,200 to $1500 for 30 yard trailer

Plus $75 to $100 per ton

● TSCA Waste

>50 ppm PCBs

$3,500 to $3,800 for 30 yard trailer

Plus $175 to $200 per ton

Case Study

46

Case Study – Overview ● Project to demolish existing school buildings

Darling Library

Baxter Building

● A consultant tested for PCBs after project bid but prior to full demolition

● Mixed PCBs results

Extreme highs and lows

Tests showed almost all caulking on both buildings >50 ppm PCBs

West Elevation: Baxter Building. North Elevation: Darling Library (left) and Baxter

Building (right) showing connector.

47

Case Study – First Step ● Fuss & O’Neill requested to assist with removal of caulking to

facilitate demolition

● Buildings needed to be demolished before start of school

About 2 months

● Prior Consultant sampling needed further characterization

Possible cross contamination of samples

● Caulk in both buildings was resampled

Proper decontamination was performed

Also sampled adjacent porous surfaces to determine PCB concentration

● Results

Many areas contained no PCB caulking

Darling Library had no PCB caulking

Allowed demolition

48

Case Study – Plan Development ● Client decided to have work bid

Plan developed including bid specifications

● Plan

Initially self implementing remediation plan

Submission required 30 days for EPA to review

Requested waiver of 30 days from EPA

EPA response

Allow work to be done as performance based removal

Removal must be verified using

761 subpart O

No plan submitted to EPA

Goal of PCB removal

Allow unrestricted use so demolition debris could be used as fill

PCB concentration was required to be reduced to <1 ppm PCBs

49

Case Study – Removal ● Bids received

Company selected to perform work

● Work on exterior was performed on enclosed lifts Control dust emissions

● Materials adjacent to caulk cut or removed Brick, concrete, and limestone

Whole sections for some structures

Disposed of as TSCA waste >50 ppm PCBs

● Samples Verification samples collected every 5 linear feet (

761 subpart O)

Four samples were composited to decrease analysis cost

Several locations failed initial verification sampling Additional removal of adjacent substrates was performed

● Contractor tried using cleaning product Capsur® to wash surfaces where cutting had occurred Used due to extreme depths into substrate not observed in initial

sampling

Resulted in passing verification samples

Did not require further cutting into substrates in most locations

● Next slide shows some of the locations after removal

50

Case Study – Pictures

51

Case Study – Results ● Soil adjacent to buildings also had elevated PCB content and

was removed.

● All waste disposed as TSCA regulated waste containing >50 ppm PCBs as required under a performance based removal project.

● Demolition schedule was essentially maintained and buildings were demolished.

52

Contact

● Fuss & O’Neill, EnviroScience, LLC

50 Redfield Street

Boston, MA 02122

(617) 282-4675

317 Iron Horse Way

Providence, RI 02908

(401) 861-3070