1. PCBs in Building Materials Michelle Mullin June 3, 2015

2. Presentation Outline I.Background II.Procedures for Investigation & Cleanup III.Questions

4. What are building materials? Paint Caulk Fluorescent Light Ballasts Other

5. What is this talk focusing on? PCBs in caulk and paint – identification and disposal Indoor environment guidance is under re- development. Check EPA website in a few months for updates FLBs are also important to manage appropriately, but ▫are currently allowed as long as non-leaking ▫Are nearing end of-life, leaks are inevitable- consider replacing ▫Guidance for proper disposal is straightforward see www.epa.gov/pcbs

6. Why Are Caulk and Paint so Important? R10 has found at least 6 recent sites through catch basin monitoring. ▫PCB concentrations up to 350,000 ppm in paint and caulk on exterior surfaces. ▫PCBs in bulk product at concentrations >50ppm are unauthorized for continued use ▫PCBs from building materials are clearly shedding from the building into the catch basins, which often drain to waterways Nationally, there are many waters listed for PCB impairments and many fish advisories due to PCBs in fish tissue. About 50% of Superfund sediment sites have PCBs as a principal contaminant. (About 70% have PCBs and PAHs.) ▫Primary exposure pathway to PCBs is ingestion Washington State's Chemical Action Plan (CAP) on PCBs identifies PCBs in caulk and paint as the second largest source of PCBs ▫87 metric tons of PCBs in WA, with 160 kg/yr released to the environment. ▫A Washington Ecology report focused on the Puget Sound Basin estimates 59 metric tons of PCBs are in building sealants in that area with about 110 kg released annually. Other regions have found PCBs in building materials as ongoing sources impacting water quality. ▫A study of buildings within the greater San Francisco Bay area found PCBs in 88% of the caulk samples tested; 40% of the samples contained >50 ppm PCBs, and 20% > 10,000 ppm PCB. ▫Data also suggest a correlation between PCB levels observed in the water with construction activity.

7. Toxicity Potential human health effects: ▫Cancer ▫Immune system suppression ▫Liver damage ▫Endocrine disruption ▫Damage to the reproductive and nervous systems Primary exposure pathway is ingestion

8. What are we talking about, exactly? Primarily used between 1950 and 1980 PCBs added as a plasticizer in caulking and paint to make it last longer. Used to seal joints between bricks and around windows EPA study indicates that caulk may contain up to 30% PCBs

9. WARNING! Not just in the original product… PCBs in caulk and paint move into other materials: ▫Indoor air and dust ▫Adjacent wood, cement, brick ▫Soil outside building ▫On-site and off-site catch basin sediments

11. Regulation of PCBs  PCB Regulations can be found in 40 CFR 761 (www.ecfr.gov)  A few key points:  Regulations prohibit the use of PCBs at greater than 50 ppm in caulk, paint and other non-liquid products, including continued use of products already in place  Proper classification and disposal of renovation and demolition wastes containing PCBs is required under TSCA regulations  Regulations regarding PCB use, clean-up, and disposal can be complicated - consult your EPA Regional PCB Coordinator  Michelle Mullin (mullin.michelle@epa.gov, 206-553-1616)mullin.michelle@epa.gov

12. Current Best Practices for Minimizing PCB Exposures- Step 0.5 First Steps: If your building was built or renovated between 1950 and 1979, there are several steps you can take to reduce potential exposure until it can be determined with certainty if PCBs are present:  Ensure ventilation systems are operating as designed  Clean frequently to reduce dust and residue inside buildings  Use a wet or damp cloth or mop to clean surfaces  Use vacuums with high-efficiency particulate air (HEPA) filters  Do not sweep with dry brooms; minimize the use of dusters  Wash children's hands with soap & water often, particularly before eating  Wash children's toys often  Wash hands with soap and water after cleaning

13. Follow a Plan! http://www.epa.gov/pcbsincaulk/guide/index.htm Step 1

14. Testing for PCBs – Step 1 PCBs in Caulk and Paint There may be many different kinds of caulks, sealants, window glazing in a building Each color of paint, and underlying layers may have different concentrations of PCBs Testing to identify the source(s)

15. Follow a Plan! http://www.epa.gov/pcbsincaulk/guide/index.htm Step 2

16. Testing for PCBs – Step 2 PCBs in Materials Adjacent to PCB Caulk  If the material is porous (wood, brick, concrete) experienced technicians will follow protocols to collect samples of material  Use EPA’s Standard Operating Procedure for Sampling Porous Surfaces for PCBs http://www.epa.gov/region1/cleanup/pcbs /pdfs/484692.pdf http://www.epa.gov/region1/cleanup/pcbs /pdfs/484692.pdf  Often requires power tools, dust control is needed Testing to identify the source(s)

17. Follow a Plan! http://www.epa.gov/pcbsincaulk/guide/index.htm Step 3

18. Testing for PCBs – Step 3 PCBs in Soil and catch basin sediments  If exterior caulk/sealants/paint with PCBs are present  Professional technicians collect soil from multiple locations near building to identify areas that may need remediation  Sample the catch basin sediments to determine disposal pathway Testing to identify extent of waste

19. Follow a Plan! http://www.epa.gov/pcbsincaulk/guide/index.htm Step 1 Step 4

20. Abatement- Step 4  PCB-containing caulk, paint and other known primary source materials should be removed from the building as soon as practicable – ongoing use is unauthorized  Encapsulants are not effective for caulk with levels above a few hundred ppm in the long term  Removal must be performed by qualified contractors and steps taken to minimize the spread of dusts and vapors  Workers must take appropriate steps to minimize exposures to them and others during renovation and clean-up activities

21. Disposal– PCB Bulk Product Waste  Overview- See 40 CFR 76.62  Dispose at a TSCA approved incinerator, chemical waste landfill, or hazardous waste landfill  761.62(b) allows disposal of caulk, dried applied paint and some other materials to be disposed in a solid waste landfill.  Must provide notice to disposer at least 15 days in advance  Must maintain records for 3 years  Seek EPA approval for risk-based disposal under 761.62(c)

22. Abatement and Disposal– PCB Remediation Waste Regulations: 40 CFR 761.61 Generally Applies to items and surfaces contaminated by PCBs, not manufactured with PCBs in them- such as soil, surfaces coated in PCB dust, substrates that were attached to PCB bulk product, etc. Cleanup occurs either under Self-Implementing plans, Performance based plans, or Risk-based plans. Self-Implementing http://www.epa.gov/region1/cleanup/pcbs/pdfs/484694.pdf http://www.epa.gov/region1/cleanup/pcbs/pdfs/484694.pdf Cleanup levels are based on occupancy and the use of institutional controls. <1 ppm for unrestricted use 100 ppm is the highest allowable concentration, for low occupancy sites with use restrictions Performance Based All PCBs are removed and disposed at an incinerator or Chemical Waste Landfill Risk Based Seek EPA approval for special circumstances

23. Bulk Product or Remediation Waste? What about the concrete and brick the caulk and paint are attached to? If, at the time the product is designated as a waste, it is still attached to the substrate- the entirety of the substrate and product can be considered bulk product waste and disposed accordingly. If the designation as a PCB bulk product waste is NOT made at the time it was determined to be a waste, and the caulk becomes detached from the substrate, the underlying substrate may be considered remediation waste.

24. Recap 0.5 Implement BMPs 1.Test caulk 2.Test material surrounding caulk 3.Test other materials like soil and catch basins 4.Abate and dispose- a.If demolishing building with no soil or sediment contamination, designate it all as bulk product and dispose in a landfill with no EPA oversight, following 761.62 regulations b.If anything else is contaminated, or you are blasting paint, removing caulk piece-meal, contact EPA PCB Bulk Product (caulk and paint) with concentrations >50ppm are unauthorized for continued use and MUST be removed

25. Last Thoughts All buildings are different, and no one-size-fits-all approach for assessing and managing PCBs has been found Our knowledge about PCBs in indoor environments is still evolving- Keep aware of future changes in guidelines, best practices, and regulations Effective communication with stakeholders is important Building assessment and remediation can be costly – effective planning is important Energy Efficiency Grants and Loans may help offset costs, and encourage action where a facility might otherwise be reluctant ▫Database for State Initiatives and Renewables Efficiencies: www.dsireusa.org www.dsireusa.org

27. Thank you Michelle Mullin PCB Coordinator, Region 10 U.S. Environmental Protection Agency Mullin.michelle@epa.gov 206-553-1616 www.epa.gov/region10/pcb.html

28. Additional Resources U.S. EPA. PCBs in caulk- Guide with flow chart http://www.epa.gov/pcbsincaulk/guide/ Database of State Incentives for Renewables and Efficiency http://www.dsireusa.org U.S. EPA. PCBs in Caulk in Older Buildings http://www.epa.gov/pcbsincaulk/ U.S. EPA. PCBs in Caulk – Frequently Asked Questions http://www.epa.gov/pcbsincaulk/pdf/caulk-faqs.pdf U.S. EPA. PCB-Containing Fluorescent Light Ballasts (FLBs) in School Buildings; A Guide for School Administrators and Maintenance Personnel http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/ballasts.htm U.S. EPA. Public Health Levels for PCBs in Indoor School Air http://epa.gov/pcbsincaulk/maxconcentrations.htm U.S. EPA. Current Best Practices for PCBs in Caulk Fact Sheet – Interim Measures for Assessing Risk and Taking Action to Reduce Exposures http://www.epa.gov/pcbsincaulk/caulkinterim.htm U.S. EPA. Current Best Practices for PCBs in Caulk Fact Sheet – Removal and Clean-Up of PCBs in Caulk and PCB-Contaminated Soil and Building Materials http://www.epa.gov/pcbsincaulk/caulkremoval.htm

29. Additional Resources U.S. EPA. Current Best Practices for PCBs in Caulk Fact Sheet – Testing in Buildings http://www.epa.gov/pcbsincaulk/caulktesting.htm U.S. EPA. How to Test for PCBs and Characterize Suspect Materials http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/guide-sect3.htm U.S. EPA. Steps to Safe Renovation and Abatement of Buildings that Have PCB-Containing Caulk http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/index.htm U.S. EPA. Contractors: Handling PCBs in Caulk During Renovation http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/caulkcontractors.htm U.S. EPA. Management, Cleanup, and Disposal of PCB Wastes http://www.epa.gov/epawaste/hazard/tsd/pcbs/index.htm U.S. EPA. Fact Sheets for Schools and Teachers About PCB-Contaminated Caulk http://www.epa.gov/pcbsincaulk/caulkschoolkit.htm U.S. EPA. PCBs in Schools Research http://www.epa.gov/pcbsincaulk/caulkresearch.htm CDC-ATSDR. Toxicological Profile for Polychlorinated Biphenyls (PCBs). http://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=142&tid=26 U.S. EPA Standard Operating Procedures for Sampling Porous Surfaces for Polychlorinated Biphenyls (PCBs) http://www.epa.gov/region1/cleanup/pcbs/pdfs/484692.pdf U.S. EPA Self-Implementing Cleanup and Disposal Checklist for PCB Remediation Waste http://www.epa.gov/region1/cleanup/pcbs/pdfs/484692.pdf