PCBs in Building Materials. John Gorman Jim Haklar USEPA
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1 PCBs in Building Materials John Gorman Jim Haklar USEPA
2 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
3 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
4 PCBs
5 PCBs Non-flammable Chemically stable High boiling point Electrical insulating properties
6 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
7 EPA Regulatory & Guidance Levels for PCBs Substance Manufactured Materials (such as caulk, oil) Air in Elementary Schools Air in Pre-Kindergarten/Kindergarten Dust Soil PCB Concentration 50 parts per million 300 nanograms/cubic meter* 100 nanograms/cubic meter* 10 micrograms/100 cubic centimeters 1 part per million
8 PCBs in Building Materials Primary Sources Caulk Fluorescent light ballasts Paint Mastic Secondary Sources Contaminated building materials
9 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
10 PCBs in Building Materials - Caulk Used as a seal around Windows Doorframes Masonry Joints Gaps
11 PCBs in Building Materials - Universe Caulk 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
12 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.
13 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.
14 PCBs in Building Materials - Ballasts
15 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
16 PCBs in Schools Air Monitoring Pre-remediation results as high as 4957 ng/m 3 in classroom air Public Health Levels of PCBs in School Indoor Air* Age 1-<2 2-<3 3-<6 6-<12 Elementary School Concentration (ng/m 3 ) 12-<15 Middle School 15-<19 High School 19+ Adult *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
17 The PCB FLB Universe Building Type Number of Buildings that May Have PCBcontaining FLBs in Number of PCBcontaining FLBs in Number of Leaking PCBcontaining FLBs in Daycares 4, , ,315 Hospitals , ,843 Primary and Secondary Schools 11,078 1,310, ,730 Public Housing 70, , ,590 Other Public and Commercial Buildings All Public and Commercial Buildings 259,411 19,291,377 14,510, ,089 21,934,994 16,499,077 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 Draft, deliberative 17
18 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
19 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
20
21 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
22 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 Bulk Product Waste Disposal Options PCB Bulk Product Waste (a) Performance Based Disposal (b) Disposal in Solid Waste Landfills (c) Risk Based Disposal Disposal in TSCA Approved / RCRA Subtitle C facilities No interaction with EPA Disposal in facility permitted, licensed, or registered by State as a municipal or nonmunicipal nonhazardous waste landfill No interaction with EPA EPA Can make riskbased disposal decision (but cannot leave these kinds of materials in place) Requires interaction with EPA 23
24 Remediation Waste Cleanup & Disposal Options PCB Remediation Waste (a) Self Implementing Cleanup Option (b) Performance Based Disposal Option (c) Risk Based Cleanup & Disposal Can send < 50 ppm to municipal landfill All PCB Remediation Waste goes to a TSCA facility Can potentially send < 50 ppm to municipal landfill Requires interaction with EPA No interaction with EPA Requires interaction with EPA 24
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 (a) waste < 50 ppm 2. Risk-based option (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. 25
26 PCBs in Building Materials Recommended Actions Replace old lighting systems Optimize ventilation Control dust cleaning BMPs Air monitoring
27 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
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