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Work at this site was performed under an AOC between the client and USEPA Region III. PCBs were detected in soil and concrete and on steel in four (4) locations. Based on PCB Mega-Rule requirements, two (2) areas (concrete) were determined to be low occupancy and two (2) areas (soil and steel) were determined to be high occupancy. Appropriate clean-up standards for each area were therefore applied. AGES staff negotiated with USEPA, developed the scope of project work, and oversaw implementation of the project.

Within the low-occupancy basement of another on-site building, PCBs were detected in a limited area in concrete at concentrations exceeding 25 mg/kg. In this area, AGES staff oversaw the application of a chemical cleaning to extract PCBs from the concrete. After the application, the chemical extraction was vacuumed into 55-gallon drums and the concrete was re-tested. Based on immunoassay kit testing and laboratory results, PCB concentrations were less than 25 mg/kg and no further action was required.
Within the low-occupancy basement of one (1) on-site building, PCBs were detected in concrete at concentrations exceeding 100 mg/kg. AGES staff oversaw scarification of the floor with a dustless concrete scabbling system. Based on screening with immunoassay kits, PCB concentrations still exceeded 25 mg/kg (the specified action level) even after multiple scabbling passes. Based on these results, a portion of the floor was removed with a jackhammer. Upon removal of the floor, the basement area flooded with groundwater. After discussions with USEPA, the area was backfilled with gravel and covered with a concrete floor. The concrete floor was then painted with two (2) contrasting colors in accordance with the PCB Mega-Rule.
PCBs were detected in wipe samples collected from a network consisting of hundreds of feet of buried steel drainlines at concentrations less than the low occupancy action level. However, because the drainlines discharged to a nearby river, the client opted for clean-up to the most stringent high occupancy standard. AGES staff oversaw cleaning of the drainlines via jet-washing, detergent cleaning and chemical cleaning. After multiple rounds of cleaning, wipe samples indicated that PCBs had been effectively removed from the lines.
AGES staff oversaw the excavation of over 150 cubic yards of PCB-affected soil from three (3) areas of the site. Laboratory samples were collected to confirm that applicable action levels had been achieved. In the field, AGES staff used immunoassay test kits to screen samples in the field resulting in rapid completion of field work with no re-mobilizations.
Extensive negotiations with USEPA to ensure the project met PCB Mega-Rule requirements in a cost-effective manner.
Used field immunoassay test kits to guide field work in both soil and concrete, which decreased the number of lab samples and eliminated costly re-mobilizations.
By applying site-specific data, use-specific action levels were used, which limited the scope of remedial work.
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