PCBs in Building Materials

John Gorman

Jim Haklar

USEPA

PCBs in Building Materials

• What are PCBs

• Sources of PCBs in Building Materials

• Regulatory Requirements

• Levels of PCBs Found

• Removal & Clean-up Standards

• Recommended Actions & Best Management

Practices

PCBs

• PCBs are chlorinated hydrocarbons

• Manufactured from 1929 until their

manufacture was banned in 1979

• Vary in consistency from thin, light-colored

liquids to yellow or black waxy solids

PCBs

PCBs

• Non-flammable

• Chemically stable

• High boiling point

• Electrical insulating properties

PCBs

• PCBs were used in hundreds of industrial

and commercial applications including:

– electrical, heat transfer, and hydraulic

equipment;

– as plasticizers in paints, plastics, and rubber

products;

– in pigments, dyes, and

– carbonless copy paper

EPA Regulatory & Guidance

Levels for PCBs Substance

PCB Concentration

Manufactured Materials (such as caulk,

oil)

50 parts per million

Air in Elementary Schools 300 nanograms/cubic meter*

Air in Pre-Kindergarten/Kindergarten 100 nanograms/cubic meter*

Dust 10 micrograms/100 cubic centimeters

Soil 1 part per million

PCBs in Building Materials

• Primary Sources

– Caulk

– Fluorescent light ballasts

– Paint

– Mastic

• Secondary Sources

– Contaminated building materials

PCBs – Regulatory Requirements

• PCBs are regulated under the Toxic

Substances Control Act (TSCA)

– Generally regulated if concentration is >50 ppm

– Some uses are authorized

– Regulated at concentrations < 50 ppm for spills

and contaminated surfaces

PCBs in Building Materials -

Caulk

• Used as a seal around

– Windows

– Doorframes

– Masonry

– Joints

– Gaps

PCBs in Building Materials -

Caulk

• Universe

– Buildings constructed between 1950 and 1979

– Buildings renovated between 1950 and 1979

• Major Health Concern

– Elevated level of PCBs in indoor air

– PCBs found at levels above 100,000 ppm in

caulk

PCBs in Building Materials -

Ballasts

• PCBs are contained within the light ballasts'

capacitors and in the ballasts' potting

material.

• Until the late 1970s, PCBs were commonly

used as insulators in electrical equipment

because they have high tolerance to heat, do

not burn easily, and are non-explosive.

PCBs in Building Materials -

Ballasts

• Intact, operational ballasts where low level

PCBs remain in the ballasts and potting

material may not pose a health risk or

environmental hazard

• However, as they age, the ballasts degrade

• Capacitors in ballasts can have pure PCBs.

PCBs in Building Materials -

Ballasts

PCBs in Building Materials -

Ballasts

• After typical life expectancy exceeded,

ballast failure rates increase significantly

• All of the pre-1979 ballasts in lighting

fixtures that are still in use are now far

beyond this life expectancy

PCBs in Schools – Air

Monitoring • Pre-remediation results as high as 4957 ng/m3 in classroom

air

• Public Health Levels of PCBs in School Indoor Air*

Age 1-<2 2-<3 3-<6 6-<12

Elementary

School

12-<15

Middle

School

15-<19

High

School

19+

Adult

Concentration

(ng/m3)

70 70 100 300 450 600 450

*Assuming a background scenario of no significant PCB contamination in building

materials and average exposure from other sources, these concentrations should keep

total exposure below the reference dose of 20 ng PCB/kg-day

The PCB FLB Universe

Draft, deliberative

17

1 Pre-1980 buildings, fluorescent lighting, no major lighting retrofit based on 2003 Department of Energy survey data, Census data and NCES data 2 Assumes 17% of total FLBs (PCB and non-PCB) 3 Assumes 75% leak in 2017

Building Type

Number of Buildings

that May Have PCB-

containing FLBs in

2017 1

Number of PCB-

containing FLBs in 2017

2

Number of Leaking PCB-

containing FLBs in 2017 3

Daycares 4,714 278,277 209,315

Hospitals 471 387,996 291,843

Primary and

Secondary

Schools

11,078 1,310,497 985,730

Public Housing 70,415 666,847 501,590

Other Public and

Commercial

Buildings

259,411 19,291,377 14,510,599

All Public and

Commercial

Buildings 346,089 21,934,994 16,499,077

PCBs in Building Materials –

Other Sources

• Some paints contain PCBs

– Fire retardant

– Water and chemical resistance

– Anti-fouling

• Adhesives and mastics

• Window glazing

• Insulation and vapor barriers

• Roofing and siding materials

PCBs in Building Materials –

• If sampling finds PCBs > 50 ppm in

primary sources– must be removed and

disposed as TSCA waste

• PCB Bulk v. Remediation Waste

Regulation of PCB Waste

• Caulk / Paint If > 50 ppm PCB Bulk Product Waste

Definition of Bulk Product Waste (761.3)

Disposal options for Bulk Product Waste (761.62)

• Use of such material is unlawful; must be removed & disposed

of

• May be disposed of in municipal landfills at any concentration

If state allows & landfill is able / willing to accept it

If < 50 ppm not PCB Bulk Product Waste

Regulation of PCB Waste

• Building Material If removed and disposed of at the same time as the > 50 ppm

caulk:

May all be managed as Bulk Product Waste (2012 Reinterpretation)

If remaining in place after caulk is removed:

PCB Remediation Waste if contaminated by PCB source > 50 ppm

Definition of PCB Remediation Waste (761.3)

Cleanup & Disposal options for PCB Remediation Waste

(761.61)

23

Disposal in facility

permitted, licensed,

or registered by

State as a

municipal or non-

municipal non-

hazardous waste

landfill

PCB Bulk

Product Waste

§761.62(a)

Performance Based

Disposal

§ 761.62(b)

Disposal in Solid

Waste Landfills

§ 761.62(c)

Risk Based

Disposal

No interaction with

EPA

Disposal in TSCA

Approved / RCRA

Subtitle C facilities

No interaction with

EPA

Requires

interaction with

EPA

EPA Can make risk-

based disposal

decision

(but cannot leave

these kinds of

materials in place)

Bulk Product Waste Disposal Options

24

PCB Remediation

Waste

§761.61(a)

Self Implementing

Cleanup Option

§ 761.61(b)

Performance Based

Disposal Option

§ 761.61(c)

Risk Based Cleanup

& Disposal

Requires interaction

with EPA

Can send

< 50 ppm to

municipal landfill

No interaction with

EPA

All PCB Remediation

Waste goes to a

TSCA facility

Requires interaction

with EPA

Can potentially send

< 50 ppm to

municipal landfill

Remediation Waste Cleanup & Disposal Options

25

Additional Points about Remediation Waste

• Once PCB Bulk Product Waste is removed, any remaining building material

with PCBs > 1 ppm is subject to the cleanup and disposal requirements for

PCB Remediation Waste

• There are two ways for PCB Remediation Waste to go to a municipal

landfill, both require EPA involvement

1. Self-implementing option 761.61(a) – waste < 50 ppm

2. Risk-based option 761.61(c) – any concentration that is supported by a no

unreasonable risk finding

• Unlike Bulk Product Waste, Remediation Waste may be managed in place

using a risk-based approach

Including encapsulation, establishing cleanup levels > 1 ppm, etc.

PCBs in Building Materials –

Recommended Actions

• Replace old lighting systems

• Optimize ventilation

• Control dust – cleaning BMPs

• Air monitoring

PCBs in Building Materials –

Cleaning BMPs

• 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 near areas with caulk

• Maintain good hygiene - wash children’s hands

with soap and water often, particularly before

eating