The following post is provided by our guest author, Graham Crockford from TRC Environmental Corporation.

PCBs were domestically manufactured from 1929 until their manufacture was banned in the United States in 1979. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications resulting in legacy PCB issues at older manufacturing facilities. Some applications included electrical, heat transfer, sealing vacuum furnaces, hydraulic equipment (e.g., stamping presses); as well as plasticizers in paints, plastics, and rubber products.

As market conditions and business needs change, the manufacturing sector is often faced with the need to expeditiously retrofit or expand manufacturing operations in certain locations, while needing to decommission manufacturing operations in others. Decommission or retrofitting of these older manufacturing facilities often result in the identification of legacy PCB issues which can be costly and time consuming to manage. On October 24, 2012, the USEPA issued the finalized PCB Bulk Product Waste Reinterpretation memorandum which allows for more straightforward and quicker removal and disposal of PCB-contaminated building materials.

Previous Interpretation - Under the previous interpretation, PCB remediation waste is waste containing PCBs as a result of a spill or release (date and concentration limits apply), e.g., PCB-contaminated soil, sediments, and concrete. Prior to reinterpretation, remediation waste was subject to stricter disposal requirements, such as disposal in TSCA chemical waste landfills; however, PCB bulk product waste was held to a different standard for disposal. PCB bulk product waste is derived from products manufactured to contain PCBs in a non-liquid state at 50 ppm or greater. Typical examples of bulk products are caulk, paint, and sealants. Because the cleanup and disposal requirements for PCB remediation waste and bulk product waste are different, the requirements to manage and dispose of these materials was complicated and costly.

October 24, 2012 Reinterpretation – The USEPA reinterpretation means that the disposal options for masonry are the same as for the attached PCB caulk and ensure that building materials contaminated with PCBs have disposal options that remain protective while being more efficient and straightforward. The reinterpretation allows building material “coated or serviced” with PCB bulk product waste at the time of designation for disposal to be managed as a PCB bulk product waste rather than PCB remediation waste. This distinction is important as it can provide greater flexibility for determining appropriate cleanup requirements and disposal options for demolition materials. An illustration of the significance of this reinterpretation is found at the USEPA’s PCB Guidance Reinterpretation website. This reinterpretation was developed to allow for accelerated cleanups of PCB-contaminated building material by providing a more straightforward path for disposal pursuant to the PCB regulations.