AGA March 2018 Request for PCB Interpretive Guidance for Managing PE Plastic Pipe

Policy March 30, 2018

In March 2018, AGA submitted a request to the EPA Office of Resource Conservation and Recovery (ORCR) for an interpretive letter confirming that high- and medium-density polyethylene is a "non-porous surface" as defined in the PCB regulations (40 CFR §761.3) for purposes of wipe sampling for waste profiling under 40 CFR §761.60 and decontamination under 40 CFR §761.79. The requested action will remove regulatory uncertainty, preserve PCB landfill space for materials that pose an unreasonable risk, encourage recycling, and reduce regulatory burdens on the energy sector. The request is based on an extensive scientific study conducted by NYSEARCH.

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