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PCBs in Building Materials

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)

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

Transformers

Capacitors

Hydraulic fluids

Oil-based paints

Fluorescent light ballasts

Lubricating & cutting oils

Floor finishes

Fire retardants

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

Totals 1,253 100

Uses of Aroclor by Type

Current Uses (since 1970) 1221 1232 1242 1248 1254 1260 1268

Capacitors X X X

Transformers X X

Heat transfer X

Hydraulic/lubricants

Hydraulic fluids X X X X X

Vacuum pumps X X

Gas-transmission turbines X X

Plasticizers

Rubbers X X X X X X

Synthetic resins X X X X

Carbonless paper X X

Miscellaneous

Adhesives X X X X X X

Wax extenders X X

Dedusting agents X

Inks X X

Cutting oils X

Pesticide extenders X

Sealants and caulking compounds

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.”

Most of the exceptions take the form of authorizations, which include conditions, such as location restrictions, repair restrictions, and concentration limits. 40 CFR Part 761

REGULATORY CONSIDERATIONS

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

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

Disposal in Solid Waste Landfill

Risk-based Disposal Approval

Daily 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 Grind/cut out areas

of contamination beyond “source material”

Encapsulation

Clean non-porous

CTDEP Caulk Guidance

Caulk Guidance, cont’d.

Excluded PCB Products

Must meet all criteria under § 761.3

May be left in place without further restrictions/requirements

ANALYTICAL CONSIDERATIONS

AND PITFALLS

1) Analytical and

extraction

requirements

2) Expected

concentration range

3) Required reporting

limits

4) Special Instructions

Chain Of Custody

Concentration

Range Required Detection

Limits

Lab Instructions

Methods

Quality Assurance/ Quality Control

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

QA/QC Program should include:

Field and Lab Duplicates

Method blanks

Temperature blanks

Field Blanks and MS/MSDs

Laboratory PEs – similar matrices

COMMUNICATION ISSUES

Project Requirements

–Methods

• 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 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 Recommendations

For buildings built between 1950 and 1978

– Minimize exposure (e.g. ventilation, cleaning)

– Take care when renovating

– Take care when abating

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

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

PCBs in Building Materials

Kim Tisa, PCB Coordinator - US EPA Region 1

Environmental Business Council – Connecticut Chapter

March 30, 2011