PCBs in the Built · PDF file... Therminol & Askarel Peak production of PCBs in US in 1970, 85 millions lbs. of Aroclors Only 130 of the 209 congeners were used in commercial products

Copyright © 2013 EMSL Analytical, Inc.

PCBs in the Built Environment Advanced Environmental Workshop

Significant Code Issues

Robert J. DeMalo, M.Sc. EMSL Analytical, Inc.

December 13, 2013


What Are PCB’s?

Polychlorinated Biphenyls (PCBs) are a group

of man-made aromatic chemicals

Chlorine (Cl) atoms replace the Hydrogen (H)

atoms in the biphenyl ring

There are 209 PCB Congeners, based on the

number and position of the Cl atoms on the

biphenyl ring structure

Aroclors manufactured by Monsanto were

identified using a standardized 4 digit number

system, i.e., Aroclor 1254

The first two digits indicate the type of mixture

(# of C atoms) and the last 2 digits the ~ % Cl

by weight; Aroclor 1254 = 54% Chlorine


What Are PCB’s?

CAS No. 1336-36-3

Complex Chemical Mixtures

Monsanto only US producer

1.4 billion lbs.. produced

>50 of 209 different congeners were

used in an Aroclor mixture

PCBs manufactured in the US from the

late 1920’s to 1979


PCB History

1929 – Approximate date for manufacturing to begin

1937 – Harvard conference on PCB toxicity

1978 – EPA “PCBs Marking and Disposal”

1979 – EPA “PCBs; Manufacturing, Processing, Distribution in Commerce and Use Bans”

1987 to 1999 – EPA regulations expanded and modified.

1999 – EPA “Use Authorization for and Distribution in Commerce of Non-Liquid Polychlorinated Biphenyls; Notice of Availability; Partial Reopening of the Comment Period”

2009 – EPA “Guidance to Communities on PCBs in Caulk of Buildings Constructed or Renovated Between 1950 and 1978” 2010 - EPA PCB Light Fixture Ballast Management Guidance


PCB History

In the US, 99% of all PCBs were manufactured by Monsanto Chemical Co. in

AL & IL under the trade names Aroclor, Therminol & Askarel

Peak production of PCBs in US in 1970, 85 millions lbs. of Aroclors

Only 130 of the 209 congeners were used in commercial products

PCB production also occurred in Austria, China, Czechoslovakia, France,

Germany, Italy, Japan, the former Soviet Union, Spain & UK

1976 (under 40 CFR 761) The Toxic Substances Control Act (TSCA)

implemented restrictions & prohibitions regarding PCB manufacture, use &

disposal

TSCA established ban on production of PCBs effective July 1979, with

distribution in commerce banned after 1984

Common time frame for uses in many building materials is between 190 to

1978

There is currently no requirement for a building owner or property manager to

conduct air or bulk sampling to determine if PCBs are present or being

released


Chemically Very Stable

High Dielectric and Coolant Fluids

Provides Thermal and Chemical Stability to Plastics High solubility in hydrocarbons Very low solubility in water Low vapor pressure Resistance to acids and bases Chemical inertness under most

circumstances

PCB Properties

Aroclor 1248 - Circa 1956


NLPCB Uses – 1999 Federal Register

Vol. 64, No. 237, 69358

PCBs were used in a variety of products including:

Surface coatings

Insulating Materials (foam, felt)

Pesticides

Caulking & grout

Oil-based paints

Plasticizers

Fluorescent lighting ballasts

Electrical equipment

(transformers, capacitors,

etc.)

Hydraulic fluids

Inks & Dyes

Lubricants & cutting oils

Flame retardants

Adhesives & mastics

Commercial products are categorized into 3 basic types:

Closed applications

Partially closed applications

Open applications


Importance of Building Age


Health Effects

PCB exposures have been associated, both directly and indirectly,

with a number of acute and chronic health effects:

Skin – Chloracne rash/nail deformities

Immune System – Decreased antibody production, increase

susceptibility to disease

Reproductive System – increased spontaneous abortion, low birth

weight

Hepatic Effects – Liver disease

Nervous System – Abnormal reflexes, memory, IQ

Endocrine System – Enlargement of the thyroid gland

Probable Human Carcinogen (IARC Group 1) – Retrospective Epi

studies

Similar Toxicity as Dioxin – 12 PCB congeners assigned toxic

equivalency factors (TEFs)

* New evidence for chronic diseases such as diabetes,

cardiovascular disease and hypertension


Exposure Pathways

Exposures to PCBs in the built environment are complex

Can occur via inhalation of PCB vapors (failed fluorescent lighting ballasts,

caulking) and contaminated particles (disturbance, gross removal)

Largely dependent on the condition of the PCB containing materials,

presence/absence of impermeable coatings, air temp, ventilation

dynamics and air flow rates

Ingestion

Can be both public and occupational

Small children, hand to mouth behavior

Occupational hygiene

Dermal absorption

ACGIH designates PCB with “Skin” notation

Potential for significant contribution to overall exposure by cutaneous

route, mucous membranes and the eyes


Regulations

1976 (under 40 CFR 761) The Toxic Substances Control Act (TSCA)

implemented restrictions & prohibitions regarding PCB manufacture, use &

disposal

TSCA established ban on production of PCBs effective July 1979, with

distribution in commerce banned after 1984

There is currently no requirement for a building owner or property manager to

conduct air or bulk sampling to determine if PCBs are present or being

released

TSCA does require that waste disposal materials be characterized for PCBs

If PCB containing building materials are identified in a building or soil, specific

actions are required based on the following criteria:

Concentration of PCBs present

Classification as either “PCB bulk products waste” or “PCB remediation

waste”

Location of the PCB containing material

Extent of any additional contamination that may have occurred to

surrounding or adjacent buildings


Regulations

Regulations

PCB Bulk Product Wastes § 761.62

Waste derived from manufactured product containing PCBs in a non-

liquid state in which concentration is ≥50 ppm (mg/kg)

Examples include but are not limited to:

non-liquid bulk waste from demolition of buildings and other man-

made structures manufactured, coated or serviced with PCBs.

PCB containing wastes from the shredding of autos, household

appliances or industrial appliances

Plastics, rubber parts, applied dried paints, varnishes, waxes,

coatings, sealants, caulking, adhesives, paper, Galbestos,

insulation, felts, fabrics, gaskets

Fluorescent light ballasts in the potting material


Regulations

Regulations

The use of PCBs in building products at ≥50 ppm (mg/kg) (Bulk Product

Waste) is prohibited under TSCA and is classified as an unauthorized use

and must be removed

There is no specified timeline from the point of discovery to the time of

remediation within the federal regs

Manufactured products containing PCBs have been found in many buildings

and structures

Caulk can contain PCBs at very high levels - %

The PCBs in caulk has been shown to migrate to adjacent materials (air,

soil, masonry)

Renovation procedures can increase exposures to workers and building

residents


Regulations

Regulations – 10/24/2012 EPA Re-interpretation

Can treat contaminated

substrates “coated or

services” with PCB Bulk

Product Waste as BPW as

long as:

No other sources of PCBs on

or in substrate

Substrate is “coated or

serviced” with PCB BPW at

the time of designation for

disposal (i.e. didn’t remove

the caulk or paint)


September 2009

EPA Publishes Guidance

Documents on PCBs in

Caulking Material

September 2009


EPA Guidance

Focused on Schools Due to Greater Risk to Children

and Publicity from a Boston Study about a High

Percentage of Schools with PCBs in Caulk

Contaminated Soil

Contaminated Dust in School

Elevated Levels in Air

Potential Problem in Commercial and Residential

Buildings with Caulk Installed from 1950 to 1978


EPA Guidance – Reduce Exposure

Improve Ventilation by Opening Windows and Using or Installing Fans Where Possible

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 Filters

Do Not Sweep With Dry Brooms; Minimize the Use of Dusters

Wash Children’s Hands With Soap and Water Often, Particularly Before Eating

Wash Children’s Toys Frequently

Wash Hands With Soap and Water After Cleaning, and Before Eating or Drinking


EPA Guidance

Testing

Test the Air for PCBs (Testing Dust May Also be Prudent)

Search for Source of Elevated Levels

Assess Contamination of HVAC System

Design Caulk Removal Process to Protect Students

Evaluate Deteriorated Caulk


Sampling Building Materials for PCBs


Public Elementary School

Built 1965

Major Addition 1980

≈ 40,000 Square Feet

Plans for A ≈ 45,000 Square Foot Addition 2011 / 2012

≈ $32,5000,000


Pre-Construction PCB Sampling

A Two Step Process

1. Identify the PCB Source Material (Caulk, etc)

2. Determine the Extent to which Adjacent Materials

are Contaminated


Sampling “Instruments”











1980 Construction

No PCBs Were Detected in Samples Collected


Sampling Choices & Analytical Methods

Air Samples

Occupational Exposure Limits (OELs)

Risk Based Concentration Assessments in

Schools and Residential Properties

Bulk Samples

Caulk

Construction Material

Soil

Debris


Sampling Choices & Analytical Methods

Air Samples

TO-10A / TO-4A

NIOSH 5503

Bulk Samples (SW-846 Method 8082)

Caulk Prep EPA SW-846 3540C

Construction Material 3540C

Soil 3550B

Debris 3540C or 3550B


Extraction Using Soxhlets


Extraction Using Sonication


GC/ECD

Gas Chromatograph with

Dual Electron Capture Detectors (GC-ECD)


Important Considerations

Laboratory Selection

Use Certified/Accredited Laboratory (ISO 17025)

in the State where the Work is Being Performed

Used Experienced Laboratories

Caulk and Ballasts are not Typical Matrices

and may Require Specialized Handling and

Skill Sets / Experience

Low Level Air Samples Challenge the Lab’s

Lower Reporting Limit


Analytical Challenges

Method Uses the Sum of 5 Key Peaks

RL Versus MDL

At the Reporting Limit (RL)Only 2 or 3 Peaks may be

Present (ideally all 5 are present)

Increases False Positives

Poor Quantitation

Positive Results at or Near the Reporting Limit May

be Less Reliable


Air Sampling

Method Selection

NIOSH Method 5503

Pump and Florisil Sorbent Tube with Swinnex

Detection Limit 35 ng/m3 Based on 1 LPM for

24 Hour Air Sampling


Air Samples – TO-10A Low Volume


Taking Air Samples

Method Selection

EPA TO-4A (high volume)

Use with Flows 200 to 280 L/min

For Measurements up to 24 Hours

TE-PNY1123 PUF Sampler, Semi-Volatile Organic Sampler


Calibrating Pumps

Bios-Defender High Flow

Field Rotameter


PCB Assessments

The Same Approaches than an Industrial Hygienist

uses for Exposure Assessments can be used to

Evaluate the PCBs in School and Offices.


PCB Ballasts


ACM Wiring


PCBs in Indoor Air

EPA Maximum Values


School Caulking

2010 – Pilot Study in New York Schools

3 Schools Tested

EPA Guidance Levels Air 300 ng/m3 Kindergarten Air 100 ng/m3

Settled Dust 10 ug/100cm2

Soil 1 PPM

Air Throughout School Exceeded Guidance Levels

Dust Levels were Below Guidance Levels

Soil Levels Exceeded Guidance Levels

http://schools.nyc.gov/Offices/SCA/Reports/EPA

http://schools.nyc.gov/Offices/SCA/Reports/EPA


NYC School Pilot Study Air Sample Results


References


Acknowledgements

Ed VandenBosche, CIH, CSP

Life Seeds, Inc.

Baltimore, MD

Bill Rath

Industrial Health & Safety Consultants, Inc.

Woodbridge, CT

Scott Van Etten, CIH

EMSL Analytical, Inc.

Cinnaminson, NJ

Ed Gerdts, CIH, CSP, LEED AP

TRC Environmental Corp.

New York, NY


Thank You!

Questions?

Robert J. DeMalo, M.Sc.

Senior Vice President, Laboratory Services & Business

Development

200 Route 130 N

Cinnaminson, NJ 08077

856-303-2502

[email protected]

www.emsl.com

mailto:[email protected]

http://www.emsl.com/