possible changes to epa's interpretation of pcb contaminated building materials
The EPA is proposing to reinterpret its position regarding the status of PCB contaminated building materials under the definition of PCB bulk product waste and is seeking comments on this proposal. The picture below graphically summarizes what they are proposing. The official reinterpretation with a complete description is also available on line with the Federal Register.
Dec-Tam has been participating in the Environmental Business Council of NE's PCB subcommittee which has reviewed these proposed changes and has submitted them to the EPA for comment. In general, the reinterpretation is supported by Dec-Tam and most on the subcommittee with some clarification being needed on certain topics. Overall these measures should result in faster project approvals and lower disposal fees for certain jobs since disposal at a TSCA facility can sometimes be two to five times greater than non TSCA facilites. This would also save space in these TSCA facilites for waste that really needs to be there. It would also be helpful if PCB bulk product wastescould be accepted in state landfills such as Massachusetts that have total PCB limits that are low. Here are the EBC of NE's PCB Subcommittee's comments on this proposed reinterpretation that were submitted to the EPA. Have questions on the physical remediation process from a contractor's viewpoint, or a project you would like to discuss? Please feel free to contact Dec-Tam at 978-470-2860.
Where you may find PCBs
- Caulking, Paints, Sealants
- Roofing Materials
- Expansion Joints
- Capacitors, Transformers
- Machinery, Furnaces
- Masonry Walls
Depending on the type of materials containing PCBs and its location, we may use any combination of the following methods to satisfy EPA requirements:
- Direct Bulk Removal
- Sand, Bead, Water Blasting
- Grinding Or Scarification
- Chemical Wash (CAPSUR)®
- Major University - Cambridge MA – In graduate housing units, Dec-Tam removed 27,500 linear feet of PCB caulking around windows. Adjacent contaminated building materials and soil were also remediated.
- Major University - Kingston, RI – In a 6 story academic building, PCB caulking and ½ inch of perimeter window masonry was removed duringduring a window replacement project.
- Retail Developer - Worcester MA – To prepare for the demolition of a parking garage, 150,000 linear feet of paint stripes containing PCBs wereremoved.
- Public School System – 10,000 sq. ft. of floor paint was remediated at 3 different elementary schools by scarifying and blastracing ½” ofconcrete floor.