1. Building Survey and Bulk Material Sampling Techniques, Analysis of PCB Analytical Data For Building Materials, and Design of PCB Investigation Programs David M. Sullivan, LSP, CHMM TRC Environmental Corporation Lowell, Massachusetts

2. The Problem  1.5 million pounds of PCBs produced in the US (1925-1978). – Dielectric fluids – Performance enhancers for a variety of building materials  Governmental, public, and school buildings particularly affected. – Half of all concrete and masonry buildings (1955-1975) have actionable concentrations of PCBs. – Includes half of all US educational buildings (1946-1969)  Vaporization of PCBs to indoor air spaces.  School Buildings - A typical school has a greater occupancy than an office building for a given unit of floor space.

3. Historic Caulk Data 1348 samples 10,000 ppm PCB 1,000 –10,000 ppm PCB ND – 1,000 ppm PCB *Source: Kohler et al, 2005 Environmental Science and Technology, 2005, 39, 1967- 1973

4. TRC School Caulk and Glazing Data

5. Other Materials of Concern  PCB Ballasts  Coal-tar enamel coatings  Processed cork gasket  Dried paint  Fiberglass insulation  Rubber parts (gaskets)  Laminate adhesive  Mastics Ballast Release Tarry Coating in Univent

6. Building Materials PCB Data TRC Data PCB Ballasts1,000,000 Tarry Coating255 Processed Cork19.3 Paint718 Fiberglass- Rubber Gaskets28.5 Laminate Adhesive230 Mastics230 All data in mg/kg total PCBs EPA Data* PCB Ballasts- Tarry Coating1,264 Processed Cork6,400 Paint97,000 Fiberglass39,160 Rubber Gaskets84,000 Laminate Adhesive- Mastics- All Data in mg/kg total PCBs *Source: Federal Register, Dec. 10, 1999

7. Building Surveys  Well-developed protocols exist for surveying buildings for hazardous materials.  Recommend PCB investigations extend beyond the present focus on caulking.  Investigate building history prior to survey.  Modification of typical sampling techniques sometimes required.  Risk evaluation sampling (air sampling) often enters the picture.

8. Materials Sampling  Air Sampling – EPA recommends TO-4A (high volume) or TO-10A (low volume)  Wipe Sampling – ASTM Methodology §761.123  Bulk Materials – EPA presently focused on caulks and glazing, but realm of target materials is expanding.

9. Multiple School Investigation Findings  PCB detections in air and wipe samples correlated with high PCB concentrations in caulks and glazings, but not always.  Other source materials beyond caulking.  Date of construction not always a reliable predictor of PCB concentrations. – Renovation history needs to be taken into account.

10. Regulatory Implications  Risk Evaluation – EPA Public Health Levels for PCBs in School Indoor Air assume a background scenario (e.g., no significant PCB levels in building materials) – Recommend indoor air sampling first – Focus on caulks alone may miss significant reservoirs of PCBs in indoor building materials  Renovation/Demolition – Owner obligated to determine proper disposal – Owner must remove all identified PCB Bulk Product Wastes - not authorized under EPA regulations – Owner must properly dispose of PCB-contaminated materials

11. Concluding Remarks  Growing awareness – EPA guidance documents have raised awareness of the issue. – There is strong resistance from the regulated community to these regulations…compliance is expensive. – The guidance is new and misunderstood.  Not just caulk – Caulks can exhibit very high concentrations of PCBs. – Numerous potential PCB sources in building interiors. – Addressing only caulks may not solve indoor air issues or properly characterize waste materials during demolition

12. Concluding Remarks  Existing guidance and regulations not necessarily in synch – Regulations demand removal of PCBs in “open systems” when greater than 50 parts per million (ppm). – 50 ppm is not necessarily indicative of the potential for indoor air concentrations greater than public health guidelines.  EPA Advanced notice of public rule making. – Increase thresholds for Excluded PCB products (easier compliance). – Change the “use authorization” – limit/eliminate removal driver.  Work closely with your regional PCB coordinator – Keep the program focused on risk to the extent allowed. – Optimize HVAC before conducting air sampling. – Focus on the high value targets for removal and ventilation.

13. Thank You TRC Environmental Corporation