Pioneer has been involved with the assessment, remediation, and successful closure of numerous former die casting facilities which are notorious for their often significant amounts of PCB contamination and the complex regulatory issues related to PCB cleanups. One such project was completed at an historical die casting site that was impacted with PCBs at concentrations greater than 300 ppm. Pioneer evaluated existing data from other consultants that had previously attempted to get approval from the USEPA and conducted our own supplemental assessment to better delineate the site’s contaminant conditions. Based on the combined results and our understanding of the regulatory and practical considerations, a hybrid approach to closure was developed.
Pioneer prepared the necessary USEPA reports including the PCB Self-Implementing Cleanup Application, PCB Risk-Based Remedial Action Plan, and Notification of PCB Cleanup Activities documentation. This information outlined the proposed approach to allow PCBs with concentrations less than 300 ppm to remain in-place in areas designated as “Low Occupancy” and capped with engineered barriers (concrete pavement) while only the limited areas of higher PCB impacts were required to be disposed of as a RCRA hazardous waste. However, given the intended future uses and redevelopment plan for the site, a portion of the property was also designated as “High Occupancy” which required cleanup to a more stringent standard. The more comprehensive assessment of the contaminant conditions, creative yet appropriate application of the TSCA regulations, and negotiation with federal regulators resulted in approvals of the required plans and reports. Pioneer directed the approved remediation activities and submitted the completion reports to USEPA. The reports were subsequently approved and formal closure was granted.