PRODUCT ACCEPTANCE & COMPLIANCE

PreTox Systems, when used correctly, comply with all current applicable federal, state, and local regulations.

SEE WHAT THE EPA HAS TO SAY ABOUT PRETOX SYSTEM

To ensure that there were no regulatory barriers to the use of PreTox System, NexTec, Inc. sought the approval of the EPA. While the EPA will not endorse specific products, it will render an interpretation of applicable regulations.

Comments and Copy of Letter from EPA:

In the early stages of PreTox development, NexTec, Inc. was known as Progressive Technologies, Inc. To ensure that there were no regulatory barriers to the use of the PreTox System, NexTec, Inc. sought the approval of the EPA. While the EPA will not endorse specific products, it will render an interpretation of applicable regulations. As you can see in the letter from the EPA, if a waste passes the TCLP test, it is non-hazardous for disposal, regardless of removal process. The PreTox System is part of the removal process. The EPA goes on to say, "that wastes must continue to pass the TCLP test". The PreTox System is the superior choice for lead paint removal because it prevents lead leachibility indefinitely.

The EPA, in the letter goes on to say, "CERCLA liability is independent of any hazardous waste determination that may be made". This means that CERCLA (Superfund) liability is inescapable, no matter where your waste is landfilled.

Finally the EPA states, "for the purposes of hazardous waste generation, the term "generator" may refer to both the paint abatement contractor and to the owner of a building or a superstructure and they are considered "co-generators" of the waste. A generator of a waste has joint and several unlimited liabilities under CERCLA (Superfund). Does that get your attention?

Certainly, it makes more sense to generate a non-hazardous waste in all situations. It's the right thing to do for the environment and for your company.

SAFETY PRECAUTIONS WHEN APPLYING PRODUCT - CONSULT MSDS

PreTox 2000 Fast Dry

PreTox 2000FD contains flammable solvents. Ensure that adequate ventilation and personal protective equipment compatible with solvent coatings are used during application and curing.

PreTox 7000 Paint Stripper

Safety goggles and butyl rubber or neoprene gloves are recommended. Maintain adequate ventilation in confined areas. If misting is expected use NIOSH approved organic vapor chemical cartridge respirator.

PreTox 2000 Demolition

PreTox 2000 Demo contains combustible solvents. Ensure that adequate ventilation and personal protective equipment compatible with solvent coatings is used during application and curing.

PreTox 8000 Paint Stripper Blast Enhancer

WASTE SAMPLING PROCEDURES In order to insure accurate results form the TCLP test, correct sample procedures must be followed.

Segregation of Waste streams:
To insure the proper samples are taken from a given waste stream, it is important that the waste stream remains separated from any other material.
Sampling Procedure:
Samples must be taken at random and be representative of the entire waste stream. Small samples should be taken from various locations in the waste pile. Never pull sample from top of pile, as this will not provide an accurate sample. Entire sample pulled from pile should weigh about 4 pounds. Then thoroughly mix entire sample together and split into four with a shovel or mechanical splitter. Minimum samples collected is four, but may require more with a larger job. Please check with your lab for proper amount of sample needed.
Before placing sample into containers, split each of the four samples in half. Send one half of each sample to the lab and retain the rest (4 to lab and 4 retained by contractor), in the event further testing is required.
Each sample must be properly labeled and appropriate chain of custody forms filled out. Secure the sample with tape over top and down sides.The label must be placed over the tape. This is important to insure the sample is not contaminated between site and laboratory. Please be sure the label contains company name, location, date and under what condition the sample was taken.
A field book should be kept with each sample number, including location maps, waste stream characteristics, and any other pertinent information about the sample and project to insure compliance.

The above procedures are presented as guidelines for the obtaining of waste samples, Other methods that insure a uniform sample is taken, can be used at the discretion of the the contractor for testing. The EPA requires well documented techniques for waste sampling and collection. Additional information can be obtained through the EPA manual SW-846 or ASTM standard D75. For further assistance, please call a NexTec, Inc. representative 1-800-338-8296.

APPLICATION OPTIMIZATION TESTING

By obtaining a control sample and testing PreTox application rates prior to starting a project, the application of PreTox can be optimized. The following represents an example of the optimization procedure:

Locate four areas that can be segregated from each other so that independent samples can be collected. Area should be large enough to generate enough waste for a TCLP test, typically 300 grams. For abrasive blasting, 4 square feet is usually adequate.
Cover each succeeding area with 10, 20, and 30 wet mils, respectively. In some special cases, a different range of mil thickness may be appropriate when recommended by NexTex, Inc. technical services.
Allow to dry thoroughly.
Remove coating from each test area with chosen method i.e.: abrasive blasting, needle gun, etc. Collect each independent sample following EPA or ASTM sampling protocol and send to an accredited lab for TCLP testing.
When test results are received, choose the application rate that achieved a BDL (below detectable limits) result or rate that was closest to BDL and add 5 wet mils. This will be the recommended, optimum application rate.

FIRST DAY BLASTING TESTING:

Three identical samples are needed, two to send to the lab and the other for you to retain. Sample bottle must be full. Please fill out the label for each bottle and the chain of custody form completely.