The New Jersey Department of Environmental Protection (DEP) has issued a proposed “Guidance for the Sampling and Analysis of Concrete Designated for Recycling” that some recyclers fear could increase the cost of concrete recycling in the state to the point where it could severely curtail or even kill of the industry.
Under the proposal, concrete from sites that are under DEP oversight because of contamination of any kind would be subject to testing before being sent to a recycling center. Concrete for disposal would not have to be tested. As almost any site could be viewed as having DEP oversight, the proposal is far reaching.
According to William Turley, executive director, Construction Materials Recycling Association (CMRA) and associate publisher of Construction & Demolition Recycling, the guidance states that after the demolition of a structure or consolidation of concrete from roadway repairs, the material must be tested for PCBs and PAHs (Polycyclic Aromatic Hydrocarbons) while still on the site. In some situations other contaminants must be tested for, including TCLP metals, VOCs, Dioxins and furans. Then the material must stay on the site until the test results are complete, which recycles worry could take weeks.
“Obviously, besides the added testing costs, leaving the material sit on the site for that long is not economically or logistically feasible for the demolition contractor or the owner of the site,” says Turley.
The reason behind the proposed guidance is a recent incident where PCB-contaminated material processed from an old automobile plant in New Jersey was found in reused concrete. The material was not used for the usual roadbase or related product, but instead made it to some residential sites where residential customers could come in contact with the material without a concrete or asphalt surface over it.
“Recycled aggregates in general were developed to economically place these types of materials back into roads and building slabs,” says one New Jersey recycler. “They were never intended to be utilized in areas where residential customers might leave them in exposed situations without a concrete or asphalt cap.”
The recycler points out that there is no way the state’s landfills could handle the millions of tons of material that will be sent to them if the guidance becomes rule, and that redevelopment costs will increase exponentially if demolition materials once recycled now cost $75 per ton to dispose of.
Particularly galling to the recyclers and demolition contractors affected by this proposed rule is the fact that DEP did not notify any of them about the proposed rule. Hence, DEP received no comments from industry about the proposal, even though several common sense ideas could achieve the same goals as what DEP is trying to gain, according to Turley. The CMRA and many recyclers will be providing comments to the DEP by the end of October, and other actions are being considered.