PCBs in Paint
    Topic posted February 23, 2010 by MSAMember, last edited January 19, 2012 
    3573 Views, 17 Comments
    PCBs in Paint

    We've been requested to do a lot of PCB testing in paints recently, especially at utility plants.  Some of these paints contain well over 50 ppm PCBs, some well into the percent level.  While there is an exemption in New York State for disposal of building materials that contain lead-based paint, there is no such exemption for PCB-containing wastes.  This results in some significant disposal costs.

    Has anyone else come across this issue and seen any solutions?



    • jessedphillips

      Wow.  I didn't even know this was a problem.  Would it be cheaper to abate the paint in place and then perform the demolition? 

    • McCarthy

      Like Jesse, we've not been testing paint for PCBs at Utility plants or other regulated waste inspections related to planned demolition.  Pre-demolition regulated waste inspections are statutorily required in our state (MN), but to the best of my knowledge regulators have not requested this testing, although the regulations PCB-containing list of potential sources notes: "including, but not limited to", so I guess the doors open.

      We have historically wipe tested walls at utility plants and found PCBs, but attributed these to airborne deposition.  There is also the recent discussion related to caulking.  I guess I would like to know more about whether the walls are "washed" or deconned before the chip samples are collected.  Even then, would the paint become contaminated interstitially / chemically due to airborne exposures?  Lead paint samples are also often collected near windows where condensation has caused bubbling and easier this an area where the PCB containing paint is more prevalent due to proximity to the caulk?

      I would also like to hear where others are at on this interesting topic.  Anyone getting direction from regulators?

    • MSA

      We do not believe that this is surface contamination from airborne contaminants.  We suspect that it was put into the paint during manufacturing.

      Regarding the caulk, we are seeing some samples with PCB concentrations will into the tens of percent.  Not sure why but if they were looking for an additive that would absorb the sun's heat, thus protect the caulk, PCBs could likely do it.

    • McCarthy

      "we suspect it was put into the paint during manufacturing"

      Has research yielded any confirmation of this suspicion or was the addition of PCBs to paints possibly a trade secret?

      Seems like a question for MaxEng - he digs this historic stuff.

    • Emily B

      I concur with the idea that PCBs were used in manufacturing.  I do decomissioning/pre-demo work on manufacturing plants, and we find it a lot in bright colored paints, like the yellows and reds used on railings and bollards.  Our sampling process is actually to collect chips and run them for PCBs and lead (as opposed to wipe sampling) and this has yielded significant PCB results.  Our reasoning for PCB sampling of this paint is related to paint "ingredients" rather than exposure of the area to PCB deposition.

      We then consider the paint a regulated material for special handling and disposal.  It definitely gets pricy, but that's usually why we're doing the survey and sampling ahead of the demo, to help estimate the disposal quantity and cost.

    • McCarthy

      Sorry.  I should have just googled it.  Many easy hits confirming that it was an ingredient in the paint and how it is regulated under TSCA. 

    • Plato

      Although PCBs were historically added to some industrial paints, this research found that low levels of PCBs were produced by the manufacturing process for certain pigments, including green.

    • MaxEng

      The proper way to analyze samples for purposes of disposal decisions on demolition wastes is typically NOT to analyze samples of the paint per se, but rather to analyze representative samples of the material that has been painted.  (This is unless the paint has flaked off, in which case you need to analyze the paint flakes.)  This approach has been blessed by RCRA staff for disposal of lead-paint coated materials, but the same rationale does not apply here.  TSCA treats the paint itself as a regulated material.

      (Edited to correct my earlier goofball misinterpretation of the PCB bulk product waste definition contained in the TSCA Megarule, 40 CFR 761.3.)

    • Plato

      First, I would be very careful trying to rationalize environmental regulations.  Second, RCRA is not TSCA.  You can find out more about PCB handing and disposal under TSCA at But casual reading at the EPA website will not make you a TSCA expert.

      The following two questions are in the January 2009 Version Revisions to the PCB Q and A Manual (

      3Q: I need to dispose of a painted metal surface. There is no reason to believe that the paint contains PCBs, but it is suspected that the surface may have been exposed to PCBs in the past by virtue of its location. How do I determine its status for disposal?

      A: If the paint contains PCBs that were added during its manufacture, the painted surface is PCB bulk product waste. If the paint contains PCBs that it absorbed as a result of a spill, the painted surface is PCB remediation waste.

      4 Q: Can paint chips from the surface be analyzed to demonstrate that a painted metal surface is unregulated disposal?

      A: Analyzing a bulk sample of paint removed from the surface will establish whether the paint contains PCBs, but will not establish whether the PCBs were added to the paint during manufacture or whether they were absorbed into the painted surface as a result of a spill. If you suspect that PCBs have spilled on the surface, it might be useful to wipe sample the surface before taking a bulk sample of the paint.

      Also of interest:

      Connecticut Environmental Consulting Firm Pays Fine for PCB Violations 10/01/2009(!OpenDocument)

      Hamden, Conn. environmental consulting firm will pay a $23,212 fine for violating federal regulations covering the storage and handling of polychlorinated biphenyls (PCBs).  According to EPA, Facility Support Services, LLC (FSS), failed to conduct proper soil sampling, resulting in PCB contaminated soils being recycled and potentially released back into the environment rather than being treated or disposed of properly.

      • MaxEng

        Plato - a couple of thoughts.  First, where do you draw the line between "rationalization" and "interpretation?"  I think we as consultants owe our clients some thought relative to regulatory interpretation, with backup from experienced legal counsel.  With that said, upon re-reading of the "bulk product waste" definition, I now agree with you - the paint itself is regulated from a TSCA perspective.

    • MSA

      Thanks, Plato.  So it appears that the building demolition wastes may now be subject to TSCA as well as solid waste and RCRA regulations.   Some of the samples we are seeing are nuts, like in the hundreds of thousands or even millions of parts per billion PCBs (single isomers) in the paint.  These are in industrial sites.  Makes you wonder what else is out there is we really start looking.

    • jessedphillips

      See below.   

    • jessedphillips

       Take 2 - the first post didn't take:

      I'm writing a proposal for conducing a survey in part of an industrial facility prior to its renovation wherein we'll be sampling not only for asbestos and lead based paint, but also for PCBs in paint.  So I'd like your input on the industry standard for sampling. 

      Which of the following best represents your approach:

      1. One sample per homogeneous area (e.g. one sample of the red paint, one of the green, one blue, etc.),
      2. A certain number of samples per unit area per homogeneous area (e.g. 3 samples per 1,000 square feet per red area, etc.),
      3. A mimimum number of samples with additional over a certain unit area per homogeneous area (e.g. start with 3 samples and collect another sample for every 1,000 square feet over the original 1,000 square feet [for 4,500 sf, you'd collect 5 in this case).

      I'll run Method SW-846 8082.  Since I'm posting already, what sample size is acceptable: fingernail size piece...more?


    • MaxEng

      Jesse:  I'd recommend first that you carefully read 40 CFR 761.61, PCB Remediation Waste.  Then, after spending awhile relieving the subsequent nausea, re-evaluate whether you really want to know whether the paint contains PCBs.

      If the answer remains yes, I'd suggest screening by collecting a few randomly-collected paint squares from each of the "homogeneous areas."  As to sample size, you need to find out what mass of paint the lab needs in order to provide results that will allow you to make a determination whether the PCB concentration is above or below 1 ppm (the regulatory threshold for 761.61 applicability).

      Realize that if the screening indicates you're above 1 ppm, then more sampling will likely be required by the TSCA staff, who will need to be notified of your activities (see 761.61(a)(3)).

      I'd also suggest not taking my word for any of this, but to also get opinions from others.

      TSCA -- what an ill-conceived law.  Made sense for regulation of transformers in use and when disposed, but makes no sense whatsoever for dealing with residual contamination at industrial sites.  It's expensive, complicated and illogical.  I'd ask all EPs to voice their displeasure with it to EPA.

      • TomL


        There has been a very large movement in EPA Region 1 & 2 to reinvigorate the PCB issue with a focus on the “PCB in caulk” issue. It's becoming a larger issue that is slowly creeping eastward as well as re-invigorating the issue in general.

        Max is correct in that the EPA regs were really written for "liquid" PCBs (transformers and other industrial applications). But any material that is more than 50 PPM PCB that is not on the "approved use" list in 40 CFR Part 761 was supposed to be removed from use. That's everything over 50ppm PCB as the regs is written. From paints, to caulks/putties to asphaltic materials like floor tile's a wide array. This also includes the substrates to which these products are applied to. If leaching has occurred, they need to be addressed as well. There are no federal requirement to test, but if you do and it's over 50 ppm and it ends up in the wrong landfill, it can be a significant problem if caught. That's why many that know they have PCBs do test; it's a real waste mangment issue. You should always consult with your Regional EPA PCB coordinator on these issues, or State/Local program folks of the same stripe. There are work plan approvals and a wide variety of issues that you need to be aware of.

        The EPA has come up with a flow chart for the "caulk" issue:

        Many of the colored flow chart items will take you to an array of EPA web pages on this issue. There's much to learn here if this is an issue for you.

        I've also attached a PDF of a brief article I wrote on this topic for Environmental Information Association. You might find it of value. You're welcome to pass the article along as-is. But I do retain rights on the article contents; so no re-use without approval. Thanks.

        Hope this helps some.

    • lavajumper


      Having become somehow immersed in TSCA (SIPP Cleanup mainly) in the last two years (a welcome break from asbestos though), I would recommend that you call the USEPA TSCA Regional Administrator.  They are a great source of information, and are usually very receptive of you trying to understand and guiding you.  I have been dealing with the Region 5 RA since starting it, and it has greatly helped me understand what I need to do.  So far I have one TSCA SIPP completed, and another very much in the thick of it.  Good luck, and please keep us updated.  I do a lot of facility decomissioning as well, and am very interested in this.  Hope that helps.


    • Woody

      Our 1st load of steel with paint containing less than 500 ppm PCB'S will be arriving next week if all goes as scheduled. Transformer Salvage Inc. will be running the steel thru an EPA approved and State of North Carolina permitted metals recovery oven designed to burn PCB contaminated (<500) Transformers. We were approached by a vendor doing work in upstate NY at a site there about handling this steel. We contacted EPA region 4  in Atlanta and inquired about processing this material in our oven. According to them there is not a problem processing this material in our machine as long as we follow the rules for burning contaminated equipment. This process allows for the steel to be recycled after it is burned vs landfilling it in an approved PCB landfill. If you have any questions please notify us.