EPA & PCBS in Window Caulk
The EPA issued a PCB Bulk Product Waste Determination in October 2012 to clarify the disposal of PCB contaminated building materials that had been located adjacent to, or been contaminated by, PCB caulk. EPA is now allowing caulk and/or associated building materials waste that contains greater than or equal to (>/=) 50ppm to be disposed as PCB Product Waste. Caulk and/or associated building materials as PCB product waste may be disposed of in non-hazardous waste landfills permitted by States. Disposal under this option does not require that the generator obtain approval from EPA, but does require notification of the landfill prior to the first shipment.
Caulk containing PCBs at levels > 50 ppm is not authorized for use under the PCB regulations and must be removed. Caulk containing PCBs at levels < 50 ppm may remain in place. PCBs in caulk are also known to contaminate adjacent building material (e.g., masonry, wood, concrete) and soil surrounding the building. When caulks and associated contaminated building materials are removed together, waste will be considered PCB Product Waste. If the associated building materials are removed separately from the caulk, the building waste is considered PCB Remediation Waste, which can be cumbersome and significantly more expensive than PCB Product Waste disposal The Agency has been playing catch-up on this issue for the last several years, but now seems to have settled on best practices for the identification and control of PCBs in caulk. Check out their “Steps to Safe PCB Abatement Activities” website to get a better understanding of EPA expectations during building renovations if PCBs are present. EEA now offers a PCB Awareness Training program that incorporates the EPA and OSHA requirements to assist building owners and abatement contractors who may be handling PCB-containing or PCB-contaminated building materials during planned renovation or repair activities or planned PCB abatement efforts in older buildings. The full day awareness training course is designed to provide information on steps that should be considered for projects intended to remove and dispose of known or suspected PCB-containing caulk, associated building materials and other PCB wastes. We’re also proud to announce that EEA has been selected to host an EPA-sponsored Healthy Homes Practitioner course on May 15 & 16 in our Buffalo Office. This will be the last official presentation by Joe Laquatro, Cornell University, of the National Center for Healthy Homes (NCHH) curriculum, before he retires. A limited number of tuition waiver scholarships are available by contacting EEA. Asbestos consultants (or wannabee air techs/project monitors) should also note that we have added two project monitor certification sessions in May and June in Buffalo and Rochester, respectively. Get ready for the 2013 construction season, check out the dates here. Here’s what’s right around the corner: Asbestos Supervisor/Contractor Certification, April 15-19, Buffalo Lead Renovator Certification Initial, April 15, Buffalo Lead Abatement Worker Certification, April 17-18, Rochester Asbestos Inspector Certification, April 22-24, Buffalo Lead Risk Assessor Recertification, April 24, Rochester Lead Abatement Supervisor, April 29-May2, Rochester Be well!