Clearing Contaminants

Navigating the Complex Cleanup Requirements of PCBs

While discussions about emerging contaminants have taken much of the focus from polychlorinated biphenyls (PCBs), they continue to exist today in electrical equipment and older construction materials, such as caulks and paints. The utilization of PCBs continues despite the United States Environmental Protection Agency (EPA) declaration in 1978 that prohibited most applications of the contaminant.

A prevalent misconception in the industry is that PCB concentrations from discharges below 50 parts per million (EPA’s acceptable level for authorized use) do not necessitate federal coordination. However, various factors—the date of discharge, the source material concentrations, and the distinction between authorized and unauthorized uses—must be considered to accurately determine the regulatory framework needed to manage associated impacts.

Langan’s team of PCB experts is frequently called upon to tackle complex PCB issues and guide clients through federal and state regulatory programs. Recently, the team improved another consultant’s efforts to remediate PCB levels on a site, reducing levels from 50 parts per million to less than one part per million. Working with the property owner who acquired a former industrial site where building structures had been demolished and debris was redistributed, Langan delineated and addressed the remaining PCB impacts, reducing them to less than one part per million—the acceptable cleanup level according to the Toxic Substances Control Act. By collaborating with the state and federal regulatory agencies, Langan also negotiated a reduced sampling frequency. The team provided significant cost savings and successfully closed the site by incorporating proposed features as engineering controls.

When PCB-related issues arise at a site, it’s important for the property owner to engage a consultant who is well-versed in relevant regulations and understands the level of work required. Building an experienced, collaborative team is key to successfully remediating an impacted site and avoiding inadequate characterization and disposal practices, which could lead to discharges, fines, or increased liabilities.

Brandi Gray, LSRP, is a Senior Project Manager with over 20 years of experience in environmental consulting focused primarily on commercial and industrial projects. Her expertise includes New Jersey Industrial Site Recovery Act and Spill Act projects, storage tank closures, environmental due diligence, and expert witness testimony. Brandi has also played an integral part in New Jersey external stakeholder groups to establish and update various New Jersey guidance documents.