Kim Tisa Regulatory Perspective

Regulatory Perspective
Kim Tisa
PCB Coordinator
U.S. EPA Region 1

PCBs in Building Materials
Kim Tisa, PCB Coordinator
US EPA Region 1

CURRENT REGULATIONS
40 CFR Part 761
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.
1998 Amendments

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

Uses of Aroclor by Type
Current Uses (since 1970) 1221 1232 1242 1248 1254 1260 1268
Capacitors X X X
Transformers X X
Heat transfer
X
Hydraulic/lubricants
Hydraulic fluids X X X X X
Vacuum pumps X X
Gas-transmission turbines X X
Plasticizers
Rubbers X X X X X X
Synthetic resins X X X X
Carbonless paper X X
Miscellaneous
Adhesives X X X X X X
Wax extenders X X
Dedusting agents X
Inks X X
Cutting oils X
Pesticide extenders X
Sealants and caulking
compounds
X

Issues
The use of PCBs in non-liquid manufactured building products
at >/= 50 ppm 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.

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

Source Removal
PCB Bulk Product Waste
Caulk removal
–Strip out
Paint removal
–Abrasives
–Chemicals
–Hydroblast
**761.62**

Adjacent Surfaces
PCB Remediation Waste
Grind/cut out areas
of contamination
beyond “source
material”
Encapsulate porous
surfaces
Clean non-porous
** 40 CFR 761.61 **

Management in Place
Not acceptable for PCB bulk product
waste (§ 761.62)
May be acceptable for surrounding
materials (§ 761.61)
Possible short-term interim measure
– Consultation with EPA
– Sampling may be required

Excluded PCB Products
Must meet all criteria under § 761.3
May be left in place without further
restrictions/requirements
State Requirements may require
removal

PROJECT CONSIDERATIONS

Establish DQOs
DATA QUALITY
Analytical program with adequate QA/QC
samples is critical
Laboratory Requirements
– Extraction/Analytical Methods
(3510, 3540C, 8082)
– Reporting Limits

Activities to Date
September 2009 (caulk guidance)
– http://www.epa.gov/epawaste/hazard/tsd/pcbs (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)
December 2010 (ballast guidance)
– http://www.epa.gov/epawaste/hazard/tsd/pcbs

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

NEW CHANGES
April 2010 ANPRM PCB Uses
Federal Register Notice
Vol. 77, No. 40
Wednesday, February 29, 2012
– Management of Demolition Debris
30 day comment

Contacts and PCB Info
Kimberly Tisa – USEPA Region 1 PCB
Coordinator
617-918-1527
tisa.kimberly@epa.gov
Caulk Hotline: 888-835-5372
http://www.epa/gov/pcb
http://www.epa.gov/region1/cleanup/pcbs
/index.html