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EBC Connecticut Chapter Program:

Managing PCB Impacted


Building Materials

Welcome
John Figurelli
Chair, EBC Connecticut Chapter
Team Leader
Weston & Sampson

Environmental Business Council of New England


Energy Environment Economy

Introduction
Malcolm Beeler, LEP
Program Chair & Moderator
Senior Project Manager
Weston & Sampson

Environmental Business Council of New England


Energy Environment Economy

EPA Building Materials Risk


Assessment
Malcolm Beeler, LEP
Senior Project Manager
Weston & Sampson

Environmental Business Council of New England


Energy Environment Economy

PCBs in Building Materials


Risk Assessment for Building Materials
and Work Place Exposures

Risk Assessment for Building Materials

Applicability
EPA Exposure/Dose Model
Use Beyond Schools
Alternative Indoor Air Action Levels

Risk Assessment for Building Materials


Applicability
Initial Testing to Determine Potential Risk
Real Estate Transactions
Employee Questions
No Building Materials Sampled

Caveat - Planning
Are the Data Appropriate
What if Action Level Exceeded
What if Less Than Action Level

Risk Assessment for Building Materials


EPA PCB Exposure Estimation Tool
Version 1.1, October 2, 2009

Assumes Background/Home Exposures


Indoor Air and Dust, Soil, Diet

Adds School Exposures


Indoor Air and Dust, Soil

Focus on Adult Exposures

Risk Assessment for Building Materials


Concentration
(mg/kg or ng/m3)

Dose
(ng/kg-day)

% RfD

Indoor Dust

0.22/0.22

0.032/0.019

0.16/0.10

Soil

0.05/0.05

0.009/0

0.05/0

6.9/0

0.972/0

4.9/0

0.5/0.5

0.022/0

0.11/0

Dermal Absorption

0.004/0

0.02/0

Diet

2.0/-

10/-

3.04/0.277

15.2/1.4

Media

Indoor Air
Outdoor Air

Total
Notes:

Background/School Environment
Concentrations are those assumed by the EPA Model
Dose are those assuming adult exposures in a home or school environment
% RFD is the percentage of the Reference Dose of 20 ng/kg-day
Indoor Air Concentration of 450 ng/m3 will lead to dose at RfD

Risk Assessment for Building Materials


Background Home and School Exposures
Dose is <17% RfD
Diet and Inhalation of Indoor
Diet Indoor Air Home
Air Major Contributors
Other
Majority is
Indoor Air at School
10%

4.7%

Indoor Air
School

84.7%

0.4%

Risk Assessment for Building Materials


Application Beyond Schools
Background or Home Concentrations are
Researched and Reviewed

Exposure Models are Researched and


Reviewed
Diet Dose Based Upon 1997
FDA Data
Background Dose is
Well Established

Risk Assessment for Building Materials


Application Beyond Schools
Site-Specific Value for Indoor Dust
Ingestion Exposure

Negligible

10%
4.7%

Dermal Absorption

Site-Specific Value for Soil


84.7%

Potential Headache

Site-Specific Value for Outdoor Air

0.4%

Risk Assessment for Building Materials


Application Beyond Schools
Site-Specific Indoor Air
10%
4.7%

Sampling: TO-10a
Analysis: EPA Method 680

84.7%

NIOSH Method

Number and Locations for Sampling

DQO Process

0.4%

Important

Risk Assessment for Building Materials


Application Beyond Schools
Problem: Determine
Site-Specific Indoor Air
Decision: Risk
Inputs: Data for Dose Assessment Model
Boundaries: Temporal and Spatial
Decision Rule: Use of Data
Decision Errors/Quality Requirements

Risk Assessment for Building Materials


Modification of Exposure Model
Days at School (185)
Determine Site-Specific Value
for Days Worked and Where
Days at Work (230)1
Hours Worked (40, all indoors)

Indoor Air Action Level 366 ng/m3


1

Based upon US Department of Labor Statistics

Risk Assessment for Building Materials


Average Weight of Workers
EPA Model (71.8 kg or 158 lbs.)

Determine Site-Specific Value


Change Model (81.9 kg or 180 lbs.)1

Indoor Air Action Level 420 ng/m3


Assuming Work Place Hours
1

Assumes 50% Male and 50% Female Work Force of Average Weight According to CDC

Risk Assessment for Building Materials


Concentration
(mg/kg or ng/m3)

Dose
(ng/kg-day)

% RfD

Indoor Dust

0.22/0.22

0.027/0.023

0.14/0.12

Soil

0.05/0.05

0.009/0

0.05/0

6.9/0

0.909/0

4.6/0

0.5/0.5

0.022/0

0.11/0

Dermal Absorption

0.004/0.003

0.02/0.02

Diet

2.0/-

10/-

2.971/0.026

14.9/0.13

Media

Indoor Air
Outdoor Air

Total
Notes:

Background or Home/Work Environment


Concentrations are those modified for a Work Place Model (Time Adjustment Only)
Dose are those assuming adult exposures in a home or work environment
% RFD is the percentage of the Reference Dose of 20 ng/kg-day
Indoor Air Concentration of 366 ng/m3 will lead to dose at RfD

Risk Assessment for Building Materials


Background Home and Work Exposures
Dose is still <17% RfD
Diet and Indoor Air still Major Contributors
Adjusted Time at Work
Diet
Body Weight EPA Assumption
10%

Nearly 20% Decrease in


Action Level

Indoor Air
Work
85.0%

4.6% Indoor

0.6%

Other

Air

Risk Assessment for Building Materials


Takeaways
Understand Data Inputs and Model

Collect Appropriate Data


Modify Model for
Site-Specific Information
Plan for Outcomes

Thank You

Analytical Methods
Jim Occhialini
Vice President
Alpha Analytical

Environmental Business Council of New England


Energy Environment Economy

Managing PCB Impacted


Building Materials
Analytical Methods
Eversource Energy
Berlin, Connecticut
10/20/2016

Jim Occhialini
Alpha Analytical

What is TPH?
PCB Chemistry
Traditional Analytical
Options
GC / LRMS Analysis
Concluding Remarks

23

Cl--3

--Cl

Cl--5

Poly Chlorinated - Biphenyls

PCB Chemistry Overview


2 phenyl groups connected by a single bond and having 1 -10 chlorine
atoms on the rings
10 possible positions leads to 209 possible combinations
209 individual PCB compounds CONGENERS

PCBs can also be grouped according to the # of chlorine atoms


Level (or Degree) of chlorination
10 HOMOLOGS (Homologues)
25

Chlorinated Biphenyls by Homolog


Empirical
Formula
C12 H10
C12 H9Cl
C12 H8Cl2
C12 H7Cl3
C12 H6Cl4
C12 H5Cl5
C12 H4Cl6
C12 H3Cl7
C12 H2Cl8
C12 H1Cl9
C12 Cl10

Molecular # Isomers
Weight
154.1
1
188.0
3
222.0
12
256.0
24
289.9
42
323.9
46
357.8
42
391.8
24
425.8
12
459.7
3
493.7
1

Monochlorobiphenyls
Dichlorobiphenyls
Trichlorobiphenyls
Tetrachlorobiphenyls
Pentachlorobiphenyls
Hexachlorobiphenyls
Heptachlorobiphenyls
Octachlorobiphenyls
Nonochlorobiphenyls
Decachlorobiphenyl
26

Aroclors
Monsanto trade name
Technical grade mixtures of congeners, made by batch chlorination
of biphenyl

Nine Aroclors:
1221, 1232, 1242/1016, 1248,

1254, 1260, 1262, 1268

Analysis of PCBs
Preparative stage
Extraction
TSCA
Soxhlet, Method 3540
Sonication Method 3550
Determinative stage
Instrumental analysis

28

Traditional PCB Analytical Options


Aroclor analysis
Gas chromatography w/electron capture detection (GC-ECD)
Common methods EPA 8082, 608
Aroclors only*

Congener and/or homolog analysis


Gas chromatography / high resolution mass spectrometry (GC/HRMS)
Common methods EPA 1668

Full 209 congener list, subsets & homologs

29

Analysis of PCB Aroclors by GC-ECD


Qualitative analysis (identifying aroclors present)
GC retention time
Chromatographic pattern recognition
Identification of unique Aroclor peaks
Specific peak ratios

Challenges
Mixtures, multi component analytes
Alteration of aroclor pattern in environment (i.e. weathering)
Some physical degradation, biological transformation

Quantitative issues:
Total PCBs by summation of aroclors?
Other ECD-sensitive compounds can interfere
30

Aroclors by Method 8082


AR 1242

AR 1248

AR 1254

Qualitative ID

**

AR 1242

AR 1254

**

Weathered Sediment

32

PCB Congeners/Homologs by GC / HRMS


Mass spectrometer provides qualitative certainty
Extremely sensitive
Dilutions required for contaminated samples

More costly than aroclor analysis

33

There is Another Way


PCB analysis by GC / LRMS
LRMS vs HRMS?

GC / LRMS applications
When you need more than aroclors
Contaminated sites, sediments and/or complex PCB matrix
Passive sampling

Homolog series
Cl1 through Cl10
Total PCB

Congeners
All 209, NOAA 18/22 list, or project specific subsets
34

PCB Analysis by GC/LRMS


Applicable matrices
Air, water, soil, sediment, & tissue

Sensitivity
Homologs
Aqueous: RL 0.5 ng/L
Soil/Sediment/Tissue: RL 0.4 ug/Kg

Congeners
Aqueous: RL 0.5 ng/L
Soil/Sediment/Tissue: RL 0.4 - 0.04 ug/Kg
Co-eluters
35

PCB Analysis by GC/LRMS - History


Method 625 (acid / base-neutral extractables, SVOCs)
PCB aroclors listed as potential analytes

Method 680
Adopts / modifies the approach introduced in Method 625
Method was not widely used at the time

NOAA Technical Memorandum NMFS-NWFSC-59, 2004


Replaces earlier document utilizing GC-ECD

Method 8270, performance based, modified


EPA currently working on a LRMS congener method
36

Quahog Quantitation Aroclor Analysis

Sample

Aroclor Quant 2,100 ug/Kg


Aroclor 1254

37
20.0

24.0

28.0

32.0

36.0

Quahog Quantitation LRMS Homolog Analysis


Cl 3 = 37%

Cl 4 = 34%

I.S.

Cl 5 = 20%
Cl 6 = 8%

Cl 7 = 1%

I.S.

Total PCB 6,200 ug/Kg

38
20.0

24.0

28.0

32.0

36.0

Tissue Sample: GC-ECD Aroclor Analysis

Technical Chlordane

39

Tissue Sample: GC-LRMS Analysis

No chlordane interference

40

The reverse is also true


PCBs can interfere
with PESTICIDE
analysis by Method
8081
False positives

41

Simultaneous Determination of Aroclors from


GC/LRMS Congener Analysis
Concept: tentative information
Line of evidence, compare w/historical data

Utilize the same approach as aroclors by GC-ECD


Subject to the same uncertainties due to weathering etc.
Aroclors NOT determined using literature values of aroclor
congener composition

Single sample extract


Eliminates multiple aliquot analysis variability
42

Analysis of Building- Related Materials


Caulking & paints
Can be difficult matrix
Potential for high concentrations
Concrete & bricks
Sealers

Surfaces
Wipe testing, 100 CM2
All of the above soxhlet extraction

44

PCBs in Air
Some considerations:

Vapor phase & particulate borne


Sampling method includes both sources

Lesser chlorinated congeners potentially overrepresented


Total PCBs used for inhalation evaluation
Requirement to meet regulatory or programmatic guidance

45

Air Sampling for PCBs


TO-4
PUF cartridge, high volume
sampler
TO-10
PUF cartridge, personal sampling
pump
Homologs, congeners & aroclors(?)

In Summary
Choose the right method for your application
Logistics
Aroclor analysis can have a lot of uncertainty
Homolog analysis ideal for total PCB determination
Congeners ideal for risk assessment & PCB fingerprinting
For the right application, LRMS can be an attractive option
Get regulatory approval if required
47

Questions?
Jim Occhialini
jocchialini@alphalab.com
(508) 380-8618

48

Remediation Case Studies


Clare Olesen
Regional Project Manager
AES Remedial Contracting

Environmental Business Council of New England


Energy Environment Economy

Considerations Bidding PCB Work:


Scope of Work Self Implementation Plan approved by EPA.
Design Specifications
Developing a SIP and obtaining approval requires more time
up front but saves time and money during execution
Bidding with an approved SIP will generate the most
comprehensive and competitive bids
Work will be performed with less delays and change orders if
SIP is in place prior to the start of work
An approved SIP may allow for simpler clearances after
substrate removal saving time and money in the field
A Contractors Work Plan is required to be submitted and will
ensure the contractor understands the scope and
requirements

Considerations Bidding PCB Work:


Disposal considerations
Most plans indicate that PCB >50 PPM shall be disposed of
as PCB Bulk Product Waste
PCB Bulk Product Waste is a non-hazardous material and if
disposed of in accordance with 761.62 does not require
hazardous waste manifests or labeling
If the waste doesnt pass a TCLP, as required by disposal
facilities, then it will go as remediation waste by default since
US Ecology does not differentiate ($$) between PCB BPW
and PCB Remediation Waste even though by definition PCB
>50 PPM is Bulk Product Waste
When removing PCB caulk only without substrate it will
usually fail TCLP
Unit pricing should be included in the bid for disposal for
PCB Remediation disposal

Scope of Work PCB Bulk Product Removal 762.62 (a) Performance


Based
Design Considerations
When all PCB Bulk product and contaminated substrate will be
removed this approach is appropriate
This does not require a notification to EPA
Sampling to delineate extent of contamination must be thorough
This approach is often most useful for demolition
Disposal considerations
Same as disposal under a SIP
Any Excluded Product (<50 PPM) and associated substrate must be
disposed of in compliance with CTDEEP regulations (>1 PPM PCB)
Consultant must clearly explain reasoning of declaring material as
Excluded Product in the inspection

Public

Higher Education Campus

The project included PCB Bulk Product Waste (caulk 53.4


PPM to 93,700 PPM) and various substrates (Concrete
Block, Brick removal 3 to 6).
Excluded Product (caulk <50 PPM original source range
1.23 PPM to 21.1 PPM) with no substrate contamination
All interior work was performed in full negative pressure
containment and all exterior caulk was performed in
regulated area with HEPA equipped tools
All Clearances were performed on substrates with sampling
every 5 LF of caulk line

Interior Abatement

Exterior removal

Occupied Facility

Project 1 Caulk and Substrate Removal


ACM and PCB
Challenges
The building was fully occupied
Post remediation sampling was time consuming
Failure rates on concrete block substrates required multiple
additional substrate removals
Additional materials were identified during work on site
Clean demolition was occurring simultaneously on the site which
caused concern of the occupants
Tracking PCB Bulk Product/ACM Waste Stream versus CT
Regulated/ACM Waste Stream
Time delay for clearance sample collection and analysis
Clearance substrate samples higher than initial inspection
samples

Project 1 Caulk and Substrate Removal


ACM and PCB

Solutions/Suggestions
Informational meetings to inform the occupants of the scope of work and
protections in place
Including a full time hygienist on site to ensure safety, communication of
information and rapid response to changing conditions more immediate
clearance scheduling
Full time dust monitoring to provide real time feedback to address concerns
Contractor developed color coded drawings and matching stickers to
delineate waste stream as it was transported from the work area to the
appropriate disposal container.
A less restrictive clearance sampling scheme could have been included in
the SIP to expedite clearances or a pre-verification plan could have limited
the length of disruption of the occupied building.
If clearance samples are unexpectedly high there could be interference from
other sources. I.E. paint on the substrate could have >1 PPM PCB that is
not associated with the contamination from the >50 PPM PCB Caulk
(Source) material. Consider this when designing SIP.

Windows to remain
Caulk and substrate
removed

Saw Muzzle Shroud

Replacement
Windows

Project 2 Paint Lead and PCB

Water Treatment Plant Renovation


Scope of Work

The project included PCB Bulk Product Waste (caulk) and


various substrates (Concrete, Brick) Excluded Product,
Encapsulation, Painted Equipment (PCB & Lead Paint)
removal/disposal, PCB/Lead Paint spot stripping and surface
removal (ceilings/walls)
Paint often contains PCB and Lead at regulated levels. OSHA
must be followed for any amount of lead. All painted
equipment/piping was identified to contain both PCB and Lead.
Painted equipment is difficult to analyze by TCLP to determine
disposal streams
Disposal of combination RCRA (Lead Hazardous Waste) and
TSCA (PCB Remediation Waste) is very expensive requiring
burial in enclosed containers (i.e. a Connex)

PCB CAULK
Caulk/backer
removal from
expansion joint to
be encapsulated

Caulk and Substrate to be


removed prior to complete
demolition

Project 2 Paint Lead and PCB

Spot Paint Stripping


Paint stripping was required to install new connections to existing
piping. Removal was performed using chemical strippers (Peel
Away) and the area was sealed overnight and then manually
removed from the surface. The waste was containerized in drums
and labeled as TSCA and RCRA hazardous waste until analysis
could be performed.
The waste included PPE and containment materials. Since TCLP
for lead includes the entire waste stream the waste could be
analyzed for Lead by TCLP for disposal. The PCB TCLP cannot
be a mixed stream so was assumed to be Remediation Waste.
The waste passed the TCLP for Lead (< 5mg/L) and could be
disposed of as PCB Remediation Waste greatly reducing the cost
of disposal and removing the RCRA transportation and labeling
requirements.

PCB AND LEAD PAINT

Strip wall paint

Spot strip pipe and


Component removal

Spot strip paint


Painted component removal

Project 2 Paint Lead and PCB

Wall Paint Stripping


Wall was found to be at State Regulated levels (30 45 PPM
PCB) and also containing Lead Based Paint. The substrate at the
walls were tested prior to the paint stripping and found to have no
contamination which expedited the work and clearances.
Disposal options included TSCA or non-TSCA with PCB
containing paint depending on TCLP testing.
Removal method would include stripping media and water in the
waste stream. The water had to be maintained below a certain
threshold to allow for acceptance at the landfill. The waste and
media were vacuumed and drummed in the containment and
staged on site for disposal.
The waste material was TCLP tested for and was below the
threshold for lead (<5 mg/L). It was scheduled to be disposed of
at Turnkey as non-TSCA Excluded Product waste.

Project 2 Paint Lead and PCB

Ceiling Paint Stripping

The ceiling paint was 5,800 PPM. This paint was on an aluminum
corrugated deck that was scheduled to remain. The deck had a factory
applied primer that was not PCB. The primer could not be removed
without damage to the metal deck. Ideally a NACE 2 clearance is
required for stripping of metal substrate. In this case alternate clearance
was required with guidance from EPA.
Disposal options included combination TSCA and RCRA or some
combination non-RCRA or non-TSCA depending on TCLP testing.
Removal method would include stripping media and water in the waste
stream. The water had to be maintained below a certain threshold to
allow for acceptance at the landfill. The waste and media were
vacuumed and drummed in the containment and staged on site for
disposal.
The waste material was TCLP tested for and was below the threshold for
lead (<5 mg/L). It was scheduled to be disposed of at Turnkey as nonTSCA Excluded Product waste.

Project 2 Paint Lead and PCB

Painted Equipment
Equipment painted with Lead and PCB containing paint can be
managed as whole components.
Disposal options included combination TSCA and RCRA or some
combination non-RCRA or non-TSCA depending on TCLP testing
if feasible.
Recycling could be an option if it is cost effective to strip the
components of paint to a NACE II clearance level. This may be an
option where a large quantity requires stripping and a
containment can be maintained on site over time to perform the
stripping. This option depends on available space at the work site,
current recycling pricing and the type of metal substrate. (baked
on finishes are not feasible, cast iron piping difficult to strip, stell
structure is easier to strip clean).

TCLP TESTING LEAD AND PCB

Metal components with paint containing PCB and Lead can be TCLP
Tested in accordance with Method 1311.
A minimum of 100g of material should be collected such as painted
nuts and bolts from the equipment.
Typically these components will pass for both constituents.
If the RCRA (Lead) requirements can be alleviated by testing it will
reduce the disposal costs.
Painted equipment, even if it passes TCLP for PCB typically cannot
be disposed of at Turnkey due to their size and will still be sent
To US Ecology as PCB Remediation/PCB Bulk Product Waste.

TCLP SAMPLING FOR DISPOSAL

Caulk 1780 PPM PCB

PCB/SUBSTRATE PASSES TCLP


This waste can
be disposed of
at Turnkey.
Disposal
TCLP Caulk /Substrate = None Detected requires a 15
day notification
and inspection
and sampling
data

TCLP Caulk only = 59 ug/L


CAULK ALONE FAILS TCLP
Failed TCLP will be disposed of at
TSCA facility US Ecology MI as there
Is no PCB Bulk Product disposal
Option without TCLP testing

TRIPS AND TRICKS


1. Some XRFs can be set to test for chlorine content to pre-screen for
potential PCB content but is not sensitive enough to indicate the
level of PCB rather may assist in segregating positives and
potential negatives.
2. Since the regulation does not require sampling for PCB the inspector
can assume the materials are >50 PPM PCB Bulk Product and abate
accordingly. Informally known as the Not Know Method. This may
alleviate substrate removal and a more costly renovation. However
the caulk cant be tested for disposal and will go at the same cost as
PCB Remediation Waste. This may be particularly useful when the
renovation is very limited and a requirement to remove additional
materials and/or substrates is undesirable.
3. Sampling the waste stream wherever possible prior to bidding can
provide more accurate bids with less change orders. Particularly
when there is RCRA TSCA combination waste.
4. Requesting a Contractors Work Plan even if it is not required can
help manage expectations and clarify the work prior to the start.
5. Disposal of the three combined wastes RCRA/TSCA/RACM is very
expensive. It is best to develop a way to segregate at least one
constituent or TCLP test lead and/or PCB.

Waste: Storing, Labeling and Disposal


1. Excluded PCB material that is <1 PPM and <50 PPM is regulated by
CTDPH. There is no hazard waste labeling or hazard manifesting for
this material. The Contractor is responsible for providing disposal
tracking that meets CTDEEP requirements. A notation on the
manifest can include Excluded PCB if desired.
2. PCB Remediation Waste must meet the requirements of 761 Sub Part
C Labeling and Marking, Sub Part J - Records and Reports and
Sub Part K - Waste Disposal Records.
3. PCB Bulk Product Waste disposed of in compliance with 761.62 (b)
Solid Waste Landfills is NOT subject to the labeling, records and
recording requirements in Subparts C, J and K. {761.61 b(6)}. The
specifications should reflect these different requirements.
4. Disposal of PCB Bulk Product Waste (Other than TSCA facility)
requires a fifteen day notification to the disposal facility as well as
TCLP analysis and inspection data.
5. Cleanup wastes such as; non liquid cleaning materials, PPE, rags,
gloves, booties and similar can be disposed of in the same types of
facilities as PCB Bulk Product waste. 40 CFR 761.61 (a) 5 (v) A (1-3).
6. PCB Bulk Product Waste can be stored up to 180 days on site with
specific protections. I.E. soil or debris piles if they are protected to
prevent wind dispersal, liners to prevent leachate etc. See
761.65(a)9.

AES Remedial Contracting, LLC


SBE/WBE CTDAS Certified Contractor

Contact Information:

Telephone: 860-620- 1791


E-Mail:

clare@aesremedial.com

Web Site: www.aesremedial.com

Recent Developments and


Lessons Learned
Ross Hartman
Executive Vice President
Strategic Environmental Services, Inc.

Environmental Business Council of New England


Energy Environment Economy

New Hampshire Office:


88 Pricilla Lane
Auburn, NH

PCB Lessons Learned


Remediation

Corporate Office:
362 Putnam Hill Rd.
Sutton, MA
Connecticut Office:
158 Middletown Ave
New Haven, CT

Waste Approach

Identify Outlet Based On Waste


Classification
BPW
Excluded Product
Remediation Waste
Soil differs greatly from BPW

Establish Waste Profile

Samples (bulk or TCLP)

Obtain Approvals

Questions may be asked about


other hazards in material

Recent Events That Could Be Useful

Paint
Scrap Metal Recovery Ovens Transformers
Smelters No known approved facilities
Paint On Wood (Mills)

Recent Events That Could Be Useful

Lawsuits have been become widespread


Presents Critique of Work
Standard Of Care
Waste Outlets
Property Transactions Peer Reviews

Bowen Field
New Haven

Bradley Airport- Hartford, CT

Several Consultants Involved


Modifications to Approach

Thank you

Networking Break

CTDEEP Regulatory
Perspective
Lori Saliby
Supervising Environmental Analyst
CT DEEP

Environmental Business Council of New England


Energy Environment Economy

Connecticut Department of
Energy and Environmental Protection

PCBs in Building Materials

EBC Connecticut Chapter


October 20, 2016
Lori Saliby, Supervising Environmental Analyst
Department of Energy and Environmental Protection
Storage Tank and PCB Enforcement Unit

Connecticut Department of Energy and Environmental Protection

PCB in Building Materials


PCBs in building materials are regulated both
federally and at the state level.

Name
U.S. EPA regulates these materials pursuant to
Title
the Toxic Substances Control Act (TSCA).
Email
Phone
Web
CT Department of Energy and Environmental
Protection (DEEP) regulates them pursuant to
statute.
Connecticut Department of Energy and Environmental Protection

Federal PCB Regulatory Requirements


40 CFR 761
No persons may use any PCB, or any PCB Item
regardless of concentration, in any manner
other than in a totally enclosed manner within
the United States unless authorized

Connecticut Department of Energy and Environmental Protection

Connecticut PCB Statutory Requirements


22a-465 Use of PCB in closed systems.
An item, product or material containing the compound
PCB may be manufactured for sale, sold for use or used if
the compound PCB is used in a closed system as a
dielectric fluid for an electric transformer or capacitor.

Connecticut Department of Energy and Environmental Protection

Connecticut PCB Statutory Requirements


22a-467 Disposition of PCB regulated.
For purposes of this section, "dispose" means to
incinerate or treat the compound PCB or any item,
product or material containing the compound PCB, or to
discharge, deposit, inject, dump or place the compound
PCB or any item, product or material containing the
compound PCB into or on land or water so that such
compound, item, product or material enters the
environment, is emitted into the air, or is discharged
into any waters, including groundwaters.
Connecticut Department of Energy and Environmental Protection

What are we talking about?


Caulk

Windows
Expansion Joints

Paint
Glaze
Fireproofing

Soundproofing
Roofing
Flooring
Clear Sealant

Wood floors such as school gyms


Stone such as slate flooring

Connecticut Department of Energy and Environmental Protection

PCB in Window Caulk & Joints


Joints

Glazing

Caulk

Connecticut Department of Energy and Environmental Protection

Which caulk is likely to contain PCBs?

Ballasts
Commonly Used

Marked
Heat puts PCBs
into the air and
becomes absorbed
by other materials
Fires & Spills

Connecticut Department of Energy and Environmental Protection

Why does it matter?

Connecticut Department of Energy and Environmental Protection

What do we do?
DEEP has developed a guidance table in conjunction with EPA
Region 1
compares remediation and disposal options for caulking
material contaminated with PCBs and associated substrates;
although specific to caulk, the table can generally be applied
to other building materials that contain PCBs;
in many cases, state and federally regulated PCB
contaminated building materials are found in conjunction with
one another;
characterization of building materials should be consistent
with the requirements of 40 CFR 761 as well as Connecticut
requirements.
Connecticut Department of Energy and Environmental Protection

CONNECTICUT DEEP CAULK GUIDANCE


DISCLAIMER: THIS CHART IS NOT INTENDED TO REPLACE THE CT DEEP STATUTES OR THE PCB REGULATIONS UNDER 40 CFR PART 761.

Caulk 50 parts per million (ppm) PCBs


(EPA)

Caulk < 50 ppm PCBs


(CT DEEP) (1)

Renovation
Substrate

Remove all caulk 50 ppm

Remove caulk > 1 ppm 49 ppm

Test, and if > 1 ppm, clean up per


40 CFR 761.61 and 761.62 (2)

Test, and if > 1 ppm, seal/encapsulate substrate as


interim measure and obtain annual exemption per
CGS 22a-466 or remove all substrate with > 1 ppm.

Nonrenovation

Remove all caulk 50 ppm and dispose in accordance with 40 CFR


761.62

Substrate

Test, and if > 1 ppm, clean up per


40 CFR 761.61 and 761.62 (2)

Encapsulate/seal any caulk > 1 ppm and


< 50 ppm, have a plan to address at later date, and
perform annual monitoring for effectiveness of
encapsulant.
DEEP recommends removal as soon as possible.
Test, and if > 1 ppm have plan to address at later
date.

Full
demolition

Remove caulk 50 ppm and dispose in accordance with


761.62

Substrate

If building substrate is >1 ppm, remove with caulk and dispose in


accordance with 40 CFR 761.62;

a RCRA hazardous waste landfill

a TSCA-approved disposal facility

a solid waste landfill permitted under 40 CFR Part 258 (RCRA title
D) (for CT facilities, a special waste authorization may be required);

facilities permitted to manage non-hazardous waste subject to 40


CFR 257.5 -257.30

40 CFR

Remove caulk < 50 ppm

If substrate > 1 ppm - 49 ppm, dispose at:

A solid waste landfill permitted under RCRA


title D (for CT facilities, a special waste
authorization may be required);

Bulky waste landfill (for CT facilities, a special


waste authorization may be required);

facilities permitted to manage non-hazardous


waste subject to 40 CFR 257.5 -257.30

a RCRA hazardous waste landfill

(1) Caulk < 50 ppm PCBs which meets the definition of an Excluded PCB Product at 40 CFR 761.3, is generally regulated by CT DEEP pursuant to CGS.
Caulk that does not meet the criteria for an Excluded PCB Product may be regulated under 40 CFR Part 761 as a PCB Remediation Waste (EPA).
An example of a PCB Remediation Waste would be replacement caulk that was installed in 1990 and was contaminated by contact with a PCB-contaminated
substrate where the original caulk was 50 ppm PCBs. Cleanup of PCB Remediation Waste would be regulated under 40 CFR 761.61.
(2) Under the October 24, 2012 PCB Bulk Product Waste Reinterpretation, building substrates may be disposed of with attached caulk as a PCB bulk product
waste in accordance with 761.62. Building substrates remaining in place (after caulk/substrate removal) are classified as a PCB remediation waste and
regulated for cleanup under 761.61.

Interim Measures
Must be protective of dermal contact and air.
EPA Guidance Levels for Air:
<3years old Was 70ng/m3 Now 100ng/m3
3-<6 years Was 100ng/m3 Now 200ng/m3
6-<12 years Was 300ng/m3 Still 300ng/m3
12-<15 yrs Was 450 ng/m3 Now 500ng/m3
15-<19 yrs Was 600ng/m3 Still 600ng/m3
19+ years
Was 450 ng/m3 Now 500ng/m3
Connecticut Department of Energy and Environmental Protection

PCB Program Staff


Lori Saliby
Supervisor

(860) 424-3329
lori.Saliby@ct.gov

Gary Trombly
PCB Coordinator

(860) 424-3486
gary.Trombly@ct.gov

Janet Kwiatkowski
Environmental Analyst 2

(860) 424-3330
janet.kwiatkowski@ct.gov

Connecticut Department of Energy and Environmental Protection

Questions and Discussion

Connecticut Department of Energy and Environmental Protection

Solid Waste Management Issues Facing Connecticut


Moderator: Malcolm Beeler, Weston & Sampson
Panelists:
Ross Hartman, Strategic Environmental Services
Jim Occhialini, Alpha Analytical
Clare Oleson, AES Remedial Services
Lori Saliby, CT DEEP

Environmental Business Council of New England


Energy Environment Economy

EBC Connecticut Chapter Program:

Managing PCB Impacted


Building Materials