EPA is proposing a reinterpretation of its position regarding Polychlorinated Biphenyl (PCB) contaminated building materials. The reinterpretation is specifically addressing the definitions of bulk product waste (e.g., PCB contaminated caulk or paint) and remediation waste (e.g., PCB contaminated masonry or concrete). This distinction is important as it determines the appropriate cleanup requirements and disposal options. The reinterpretation being proposed in this notice would allow building material (i.e., substrate) “coated or serviced” with PCB bulk product waste (e.g., caulk, paint, mastics, sealants) at the time of disposal to be managed as a PCB bulk product waste, even if the PCBs have migrated from the overlying bulk product waste into the substrate. The below diagram highlights these proposed changes to the definitions.
The reinterpretation will impact the highlighted segments of the following documents:
- Contractors Handling PCBs in Caulk During Renovation
- PCB Caulk Abatement Steps 1 – 3
- Example Decision Flowchart for Classifying Suspect Building Materials
- Polychlorinated Biphenyl (PCB) Site Revitalization Guidance Under the Toxic Substance Control Act (TSCA)
To learn more about the proposed reinterpretation, see the Federal Register Notice – PCBs Bulk Product v. Remediation Waste – (February 29, 2012).
This is a request for comment on a reinterpretation of guidance, not as part of a rule making. The comment period is from February 29, 2012 to March 30, 2012.
You can submit your comments by emailing either:
- EPA docket (Attention Docket ID No. EPA-HQ-RCRA-2011-0847)
- Email address: ORCRPCBs@epa.gov
See Federal Register notice for additional submission options.
Original posting from EPA found HERE.
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Original posting from EPA found HERE.
