The U.S. Environmental Protection Agency has been taking a closer look at polychlorinated biphenyls, or PCBs, and their use in older buildings. PCB molecules are man-made organic chlorine compounds made up of carbon, hydrogen and chlorine atoms. Until their ban in 1979 by the Toxic Substances Control Act, they were used in building materials because they were odorless, non-flammable, and chemically stable. They also had good insulating properties and a range of consistencies. The EPA has reinterpreted its position regarding PCB-contaminated building materials as it relates to bulk and remediation waste. By understanding the EPA’s reinterpretation, Portland demolition contractors can take appropriate abatement steps to keep workers and project sites safe.
The Problem with PCBs on Portland Demolition Sites
PCBs are considered toxic and don’t break down readily and may change in composition when released into the environment. They may cycle between the air, soil and water for extended periods. PCBs can also be carried long distances and found in areas that were far from where they were released. The compounds may also enter the food chain when they accumulate in leaves, parts of plants above the ground, and when bioaccumulated in animals.
The EPA’s PCB Reinterpretation
The EPA’s reinterpretation regarding PCBs concerns the definitions of bulk waste and remediation waste. Demolition companies in Portland familiar with the distinctions will be better equipped to follow the recommended cleanup requirements and disposal options.
The EPA’s original interpretation stated that building materials contaminated by the migration of PCBs from bulk waste products, such as contaminated caulk, were considered remediation waste. The reinterpretation modified the guidance, specifying that only contaminated building materials from which the contaminated bulk product was removed is remediation waste. Under the reinterpretation, the distinction regards whether the contaminated bulk product is still attached to the building material.
Before the reinterpretation, for example, the EPA classified contaminated masonry and concrete surrounding contaminated caulk as remediation waste. The contaminated caulk was bulk product waste. The reinterpretation states that materials that become PCB-contaminated because of their proximity to contaminated bulk products may also be treated as bulk products. As a result, the changes simplify the removal of PCBs from buildings and lower associated costs.
It’s important to note that the reinterpretation only applies if the original contaminated bulk product is still adhering to the contaminated abutting material when it’s designated for disposal. If the designation doesn’t occur before removing the bulk product, the abutting contaminated materials are considered remediation waste. The reinterpretation also clarifies the term “excluded PCB products” to include materials with PCB concentrations of less than 50 parts per million. The burden of demonstrating the regulatory exclusion applies to the party seeking the exclusion, such as an Oregon demolition contractor.
Safe PCB Abatement
The EPA recommends creating and implementing an abatement plan that documents when Oregon demolition specialists designate a structure for disposal and its condition before separating PCB-containing materials rather than sample the debris after demolition activities.
Abatement activities apply when a demolition contractor undertakes a PCB-abatement activity or finds PCBs after testing the air or building materials. The goal of abatement activities is to make the work area safer during abatement and make the building safer after a project’s completion.
1. Prepare a Strategy
- Classifying PCB-contaminated materials: Determine the type of PCB waste you’re removing and your disposal options before starting an abatement activity as you might need to notify the EPA of your findings.
- Prioritizing abatement activities: Use the information collected during building material classification and characterization steps to prioritize abatement activities.
- Notifying the EPA of findings: Depending on the cleanup and disposal methods you choose, you may need to notify the EPA of the removal or abatement project. It is a good idea to prepare an abatement and cleanup plan before commencing any actions.
2. Implement Abatement and Removal Activities
- Select the appropriate tools: Consider the condition and properties of contaminated materials and adjoining structures prior to selecting removal tools and methods. Also, keep anticipated dust levels and heat generation in mind to reduce the risk of PCB exposure.
- Employ protective measures: The volume of dust produced by a removal method helps determine the need for protective measures. These measures include personal protection for workers, protecting building users and passersby, and preventing cross-contamination to surrounding areas by assigning containment areas.
- Use appropriate decontamination methods: You may need to collect samples from the containment areas to determine if decontamination is complete.
3. Handle, Store and Dispose of Waste Appropriately
- Containment and transportation: After removing and breaking down materials in an affected area, they must be contained and transported to a designated storage area.
- Disposal: Disposal methods are determined by the regulatory material’s classification. Demolition companies in Oregon must adhere to storage, packaging, transportation, manifesting, recordkeeping, and disposal provisions.
4. Document Preparation and Maintenance
Contractors should document field activities daily during an abatement project, as well as prepare an abatement report after the completion of remedial activities. The types of documentation that a contractor should complete include:
- Field notes
- Transportation, treatment and disposal certifications
- Abatement reports
While the effects of PCBs are not completely understood, the EPA is conducting additional research to better assess the magnitude of the toxins and identify the best long-term solutions to reduce exposure. Because Elder Demolition is committed to safety, we will stay abreast of the latest developments and go the extra mile to keep our workers, the public and the environment healthy.