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. 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

5. 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

6. Uses of Aroclor by Type Bob
Aroclor 1254 most common aroclor detected in caulking and paints (plasticizer for chemical resistance)

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
The last update for PCBs in the Agency’s Integrated Risk Information System (addressing human health) was in 1997 (see Detailed references to the health effects of PCBs can be found on the EPA website at:

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

12. 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

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 Removal PCB Bulk Product Waste
Caulk removal
Strip out
Paint removal
Abrasives
Chemicals
Hydroblast

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

16. PCB Remediation Waste Options
Self-Implementing Option– § (a)
Performance-Based Option- § (b)
Risk-Based Option - § (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 - 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

25. EPA Activities to Date http://www.epa.gov/epawaste/hazard/tsd/pcbs
September (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)

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

31. Contacts and PCB Info http://www.epa.gov/pcb Kimberly Tisa – EPA
Gary Trombly – CTDEP
Caulk Hotline: