Dating pcb spills
The reinterpretation allows 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 following diagram highlights these changes to the definitions.
As more buildings were discovered to have PCB contamination, it was also discovered that sometimes PCBs leach from those PCB manufactured products into attached porous building materials.
EPA has received many requests to address difficulties the regulated community faces when disposing of this waste properly.
This distinction is important as it determines the appropriate cleanup requirements and disposal options.
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