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 Bob Aroclor 1254 most common aroclor detected in caulking and paints (plasticizer for chemical resistance)

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 The last update for PCBs in the Agency’s Integrated Risk Information System (addressing human health) was in 1997 (see http://www.epa.gov/ncea/iris/subst/0294.htm). Detailed references to the health effects of PCBs can be found on the EPA website at: http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/effects.htm

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. 45% of public schools constructed between 1950s and 1970s.

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

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

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 - Reporting limits 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 http://www.epa.gov/epawaste/hazard/tsd/pcbs 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 http://www.epa.gov/pcb 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