PCBs in Building Materials
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
Kim Tisa, PCB Coordinator - US EPA Region 1
Environmental Business Council – Connecticut Chapter
March 30, 2011
Formulating PCBs into Aroclors
(1016, 1221, 1232, 1242, 1248, 1254,
1260, 1262, 1268)
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Monsanto was only
US producer
Only about 130 of
the 209 congeners
were used in
commercial
formulations
>50 different
congeners were used
in an Aroclor mixture
Range from oily
liquids to waxy solids
at room temperature
Last two digit = %
Chlorine by mass
PCBs Chemical Properties
– Attractive Properties to Industry
 Low flammability
 Fire resistant
 Chemical stability
 Electrical insulating properties
 Durability
 Resistant to degradation
 Softener and plasticizer
PCBs in Industrial Applications
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Transformers
Capacitors
Hydraulic fluids
Oil-based paints
Fluorescent light
ballasts
Lubricating & cutting
oils
Floor finishes
Fire retardants
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Thermal Insulation
materials (foam,
felt)
Caulking & grout
PVC coatings for
electrical wire &
components
Carbonless copy
paper
Inks and dyes
Adhesives/mastic
U.S. Industrial Use of PCBs
PCB Use
Pounds (mil)
% of Total
Capacitors
630
50.3
Transformers
335
26.7
Plasticizer uses
115
9.2
Hydraulics/lubricants
80
6.4
Carbonless copy paper
45
3.6
Heat Transfer fluids
20
1.6
Petroleum additives
1
0.1
Miscellaneous uses
27
2.2
1,253
100
Totals
Uses of Aroclor by Type
Current Uses (since 1970)
Capacitors
1221
1232
X
1242
X
Transformers
X
Heat transfer
X
Hydraulic/lubricants
 Hydraulic fluids

Vacuum pumps
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Gas-transmission turbines
Plasticizers
 Rubbers
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Synthetic resins
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Carbonless paper
Miscellaneous
 Adhesives
X
X
X
X
1254
1260
1268
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
1248
X
X
X
X
X
X
X
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Wax extenders
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Dedusting agents
X
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Inks
X
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Cutting oils
X
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Pesticide extenders
X
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Sealants and caulking
compounds
X
X
X
X
X
What are the human health
effects from PCBs?
Acute (short-term) – Irritation/burning of eyes, face,
and chloracne
Chronic (long-term) – Liver disorders, reproductive
effects, developmental effects, and probably cancer
PCBs also have numerous well-documented health
effects, including cancer, for animals.
EPA - PCBs a probable human carcinogen
Why the Concern - Regulatory
Courtesy of Weston & Sampson
CURRENT REGULATIONS
Section
6(e) of the Toxic Substances Control Act
of 1976 (TSCA) generally bans the manufacture,
processing, distribution in commerce, and use of
PCBs after 1978, but provides for exceptions
based on an EPA finding of “no unreasonable
risk of injury to health or the environment.”
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Most of the exceptions take the form of
authorizations, which include conditions, such
as location restrictions, repair restrictions, and
concentration limits.
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40 CFR Part 761
REGULATORY CONSIDERATIONS
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PCB regulations include owners and/or operators
of PCB-contaminated property where the PCB
contamination exceeds allowable concentrations
under the regulations
TSCA authority has not been delegated to any of
the states, thus both EPA and state regulations
will apply
Issues
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The use of PCBs in building products is prohibited under TSCA.
Manufactured products containing PCBs have been found in
many buildings and structures
Caulk typically contains PCBs at very high levels - %
The PCBs in the caulk migrate to a limited extent to
surrounding materials (air, soil, masonry).
Typical renovation procedures can increase exposures to
workers and building residents, including children.
Renovation/Demolition
Considerations
 Do
I need to look for PCBs
 If
I find PCBs, is my site regulated
under TSCA
 What
are my cleanup options
PCBs in Building Materials
Bulk Product Waste (761.62)
examples: caulk, applied dried paints, varnishes, other
similar coatings or sealants, Galbestos
 Performance-based
 Disposal
in Solid Waste Landfill
 Risk-based
 Daily
disposal
Disposal Approval
Cover/Roadbed
Source Removal
PCB Bulk Product Waste
 Caulk
removal
–Strip out
 Paint
removal
–Abrasives
–Chemicals
–Hydroblast
Management in Place
 Not
acceptable for PCB bulk product
waste (§ 761.62)
 May
be acceptable for surrounding
materials (§ 761.61)
 Possible
short-term interim measure
– Consultation with EPA
– Sampling may be required
PCB Remediation Waste
Options
Self-Implementing Option– § 761.61(a)
Performance-Based Option- § 761.61(b)
Risk-Based Option - § 761.61(c)
Adjacent Surfaces
PCB Remediation Waste
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Grind/cut out areas
of contamination
beyond “source
material”
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Encapsulation
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Clean non-porous
CTDEP Caulk Guidance
Caulk Guidance, cont’d.
Excluded PCB Products
 Must
 May
meet all criteria under § 761.3
be left in place without further
restrictions/requirements
ANALYTICAL CONSIDERATIONS
AND PITFALLS
Chain Of Custody
1) Analytical and
extraction
requirements
Methods
2) Expected
concentration range
3) Required reporting
limits
4) Special Instructions
Required Detection
Limits
Concentration
Range
Lab Instructions
Quality Assurance/ Quality Control
A properly planned analytical program with
adequate QA/QC samples is critical
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QA/QC Program should include:
 Field and Lab Duplicates
 Method blanks
 Temperature blanks
 Field Blanks and MS/MSDs
 Laboratory PEs – similar matrices
COMMUNICATION ISSUES
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Project Requirements
– Methods
•
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Sample extraction methods – Soxhlet extraction preferred
Extraction by sonication not preferred
– Inefficient, low PCB concentrations
– Not applicable/appropriate to all matrices
– Not allowed under many state QA programs
•
Alternative techniques require correlation study
– – Subpart Q
- Reporting limits
EPA Activities to Date
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September 2009 (caulk guidance)
(fact sheets, Q’s and A’s, and a Schools Information Kit)
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Steps to Safe Renovation and Abatement of Buildings that have PCBContaining Caulk
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Developed public health levels for PCBs in indoor air for schools
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Conducting research on mitigation and exposures assessment on
PCB sources in buildings (ORD)
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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 Recommendations
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For buildings built between 1950 and 1978
– Minimize exposure (e.g. ventilation, cleaning)
– Take care when renovating
– Take care when abating
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If you think you may have a problem
– Test for elevated air levels
– Test for source of air contamination
 Evaluate duct systems
 Sample deteriorating caulk
Renovation and Abatement
Brochure
Information for contractors and building
owners for characterizing, remediating, and
disposing of PCB-contaminated building
materials (e.g., masonry, wood, or brick),
soils or sand, and caulk when conducting a
renovation/repair or abatement project
Contacts and PCB Info
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
Kimberly Tisa – EPA
617-918-1527
tisa.kimberly@epa.gov
Gary Trombly – CTDEP
860-424-3486
gary.trombly@ct.gov
Caulk Hotline: 888-835-5372
http://www.epa.gov/pcb