Fed Reg Dev - EPA Seeking Comment On Re-classifying PCB-Contaminated Building Materials Slated For Disposal
As reported by Larry Schnapf in his Environmantal Issues in Business Transactons LinkedIn
publication, EPA is considering changing the classification of building
materials contaminated with PCBs from those sources to steamline
cleanup and disposal of PCB-contaminated caulk in schools and other
disposal and cleanup requirements for PCB-contaminated building
materials depends on if the material is classified as "PCB bulk product
waste" or "PCB remediation waste".
bulk product waste includes non-liquid bulk wastes or debris from the
demolition of buildings and other man-made structures manufactured,
coated, or serviced with PCBs.' Thus, paint, caulk, mastics, sealants,
masonry, wood, metals, and other building materials that are purposely
coated with PCB-containing caulk are regulated as PCB bulk product waste
if the building materials contains PCBs at concentrations > 50 ppm.
40 CFR § 761.62, PCB bulk product waste must be disposed of in one of
three ways: performance-based disposal; disposal in solid waste
landfills; or risk-based disposal approval.
disposal of PCB remediation waste is regulated under 40 CFR § 761.61.
There are three options for management of PCB remediation waste:
Self-implementing cleanup and disposal, Performance-based disposal and
Risk-based cleanup and disposal..
proposed reinterpretation would specify that the classification of
building material contaminated by the migration of PCB would depend on
whether the PCB bulk product is still attached to the building
materials. Building material (substrate) that is “coated or serviced''
with PCB bulk product waste (e.g., caulk, paint, mastics, sealants) at
the time of disposal would be managed as a PCB bulk product waste.
However, if the PCB bulk product waste that contaminated the substrate
has been removed from the building material at the time of disposal, the
substrate would be considered a PCB remediation waste.