March 2014 – Can PCB-Containing Paint Be Completely Removed From My Building?

In short, probably not, but there is some good news. CRETE performed a PCB paint removal pilot test on a concrete warehouse building. The purpose of the test was to assess the most cost-effective approach to demolition of the building. Abrasive blasting of concrete interior and exterior walls was performed using three blast media: sand, soda, and dry ice. Diamond grinding was also performed. Baseline (concrete plus paint) PCB concentrations at the test locations ranged between 200 mg/kg and 4,600 mg/kg. PCB removal percentages ranged from 40 to 99% but final PCB concentrations indicated that all of the treated concrete would still require landfill disposal, including some concrete that still exceeded the 50 mg/kg TSCA threshold.

Fortunately, EPA recently issued a TSCA reinterpretation (September 2013) that allows disposal of building debris with PCB-containing paint and sealants as PCB Bulk Product Waste at a Subtitle D landfill. The PCB-containing paints and sealants can have TSCA-level concentrations and disposal is allowed as long as the average PCB concentration of the debris is below the TSCA threshold of 50 mg/kg and compliant with the Dangerous Waste Regulations. That’s good news if you are planning to demolish a structure. If you’re going to retain the structure, check for PCB soil contamination due to leaching from the paint and develop an encapsulation approach in accordance with EPA regulations since you probably won’t be able to cost-effectively remove it.

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