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PCBs in Building Materials

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

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PCBs in Building Materials

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  1. PCBs in Building Materials • Kim Tisa, PCB Coordinator - US EPA Region 1 • Environmental Business Council – Connecticut Chapter March 30, 2011

  2. 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

  3. PCBs Chemical Properties • Attractive Properties to Industry • Low flammability • Fire resistant • Chemical stability • Electrical insulating properties • Durability • Resistant to degradation • Softener and plasticizer

  4. 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 PCBs in Industrial Applications

  5. U.S. Industrial Use of PCBs

  6. Uses of Aroclor by Type

  7. 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

  8. Why the Concern - Regulatory Courtesy of Weston & Sampson

  9. 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

  10. 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

  11. 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.

  12. Renovation/DemolitionConsiderations Do I need to look for PCBs If I find PCBs, is my site regulated under TSCA What are my cleanup options

  13. 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

  14. Source RemovalPCBBulk Product Waste • Caulk removal • Strip out • Paint removal • Abrasives • Chemicals • Hydroblast

  15. Management in Place • Not acceptable for PCBbulk product waste (§ 761.62) • May be acceptable for surrounding materials (§ 761.61) • Possible short-term interim measure • Consultation with EPA • Sampling may be required

  16. PCBRemediation WasteOptions Self-Implementing Option– § 761.61(a) Performance-Based Option- § 761.61(b) Risk-Based Option - § 761.61(c)

  17. Adjacent Surfaces PCB Remediation Waste • Grind/cut out areas of contamination beyond “source material” • Encapsulation • Clean non-porous

  18. CTDEP Caulk Guidance

  19. Caulk Guidance, cont’d.

  20. Excluded PCB Products • Must meet all criteria under § 761.3 • May be left in place without further restrictions/requirements

  21. ANALYTICAL CONSIDERATIONS AND PITFALLS

  22. Chain Of Custody • Analytical and extraction requirements • 2) Expected concentration range • 3) Required reporting limits • 4) Special Instructions Methods Concentration Range Required Detection Limits Lab Instructions

  23. 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

  24. 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

  25. 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

  26. 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

  27. 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

  28. 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

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