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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
Gary Trombly – CTDEP
860-424-3486
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