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Does your Lead-Based Paint waste also contain PCB's?
According to TSCA, some lead-based paint formulations produced up until 1975 also contained significant amounts of PCB's (>10,000 ppm). TSCA's limit is 50 ppm for PCB's. Disposing of lead-based paint waste by treating the lead content by fixation with caustic followed by disposal in a landfill does not address the PCB content. TSCA's rule states that any lead paint chip (even one as small as a flake) that contains PCB greater than the disposal standard contaminates the entire shipment. It doesn't matter if it's a 55 gallon drum or a dumpster load of waste. The entire container is considered to be the concentration that the smallest portion exhibits.
PCB's were added to improve the covering ability of the paint. PCB's were also added to improve the elasticity characteristics of the paint to prevent cracking.
Most consultants that are involved with military or federal cleanup sites know to automatically ask for PCB analysis along with their Pb testing.
Do they know something you don't know?
Be safe, Analyze your samples for PCB's as well as Lead before you dispose of your lead-based paint waste. |