Abatement Step 3: Handling, Storing, and Disposing of Wastes
Table of Contents
After removal and breakdown of materials within the containment area, all materials to be disposed of should be contained (e.g., wrapped in poly sheeting or placed in a drum) and immediately transported to a designated storage area. Disposal methods are determined based on the regulatory material classification, as previously discussed in Abatement Step 1. All applicable provisions for storing, packaging, transporting, manifesting, recordkeeping and disposing in the PCB regulations must be adhered to.
- How Do I Dispose of My PCB-Containing Caulk?
- How Do I Dispose of My Other PCB-Contaminated Building Materials?
- How Do I Dispose of My Cleanup Debris?
- Disposal Facilities
How Do I Dispose of My PCB-Containing Caulk and Attached Building Materials??
The disposal of PCB-containing caulk and any attached PCB-containing building materials is regulated under 40 CFR 761.62. . (Note: If your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB bulk product waste.) Under this provision, the removed caulk and building materials must be disposed of using one of the following four methods for this type of material (PCB Bulk Product Waste):
Performance-based disposal. The performance-based option allows for disposal of PCB bulk product waste in a TSCA incinerator; a TSCA chemical waste landfill; a RCRA hazardous waste landfill; under a TSCA approved alternate disposal method; under the TSCA regulated decontamination procedures; or in a facility with a coordinated approval issued under TSCA. Disposal under this option does not require you to obtain approval from EPA.
Disposal in solid waste landfills. PCB bulk product waste may be disposed of in non-hazardous waste landfills as permitted by states. Disposal under this option does not require you to obtain approval from EPA. However, EPA recommends that you check state regulations which may prohibit or limit disposal of PCB bulk product waste in solid waste landfills. EPA also recommends that you determine prior to shipment that the landfill is willing and able to accept the PCB waste. Anyone sending PCB bulk product waste to a non-hazardous waste landfill permitted by a state must send written notice to the landfill prior to shipment of the waste stating that the waste contains PCBs at greater than 50 ppm (see 40 CFR 761.62(b)(4)(ii)). This guidance document does not replace or supersede any (sampling) requirements that the receiving facility may deem necessary to determine acceptance of the waste into its facility. Additionally, this guidance does not supersede state requirements which may be more stringent than those mandated by the federal government for management of this debris
Risk-based option. The risk-based option allows for a site-specific evaluation of whether PCB bulk product waste may be disposed of in a manner other than under the performance based disposal option or the solid waste disposal landfill option. Disposal of PCB bulk product waste under this option requires you to obtain approval from EPA, and requires you to demonstrate that the disposal will not present an unreasonable risk of injury to health or the environment.
Disposal as daily landfill cover or road bed. (40 CFR 761.62(d))
NOTES: Re-sampling of caulk waste is not necessary for a Performance-based disposal, disposal in a solid waste landfill or disposal as a daily landfill cover or road bed but may be necessary when implementing the Risk-based disposal option. However, sampling methods described in 761.62 were not designed for waste caulk material. Consult your Regional PCB Coordinator for alternative methods if you select this disposal option.
If PCB Caulk has been Removed, How Do I Dispose Remaining PCB-Contaminated Building Materials?
The disposal of masonry, wood, bricks, and other building materials contaminated with PCBs from which PCB caulk has been removed and is disposed of separately from the surrounding building material is regulated under 40 CFR 761.61. There are three options for management of these types of materials (PCB Remediation Wastes):
Self-implementing cleanup and disposal. The self-implementing option links determining cleanup levels with the expected occupancy rates of the area or building where the contaminated materials are present. The disposal requirements for the self-implementing option vary based on the type of contaminated material and concentration of PCBs in the materials, among other things. Contact your PCB Regional coordinator if you elect to use this disposal option.
Performance-based disposal. The performance-based option allows for disposal or decontamination of the contaminated materials in a TSCA chemical waste landfill; a TSCA incinerator; through a TSCA approved alternate disposal method; under the TSCA regulation's decontamination procedures; or in a facility with a coordinated approval issued under TSCA. Disposal under this option does not require you to obtain an approval from EPA.
Risk-based cleanup and disposal. The risk-based option allows for a site-specific evaluation of whether the PCB-contaminated building materials may be cleaned up or disposed of in a manner other than the alternatives provided under the self-implementing or the performance based disposal options. Disposal of these materials under this option requires you to obtain approval from EPA and demonstrate that the disposal will not present an unreasonable risk of injury to health or the environment.
How Do I Dispose of My Cleanup Debris?
Wastes generated during the cleanup activities previously described in the section, " Leave the Work Area Clean" must also be properly disposed of. Non-liquid cleaning materials and PPE waste at any concentration, including rags, mops, gloves, Tyvec suits, and similar materials resulting from cleanup activities must be disposed of in an appropriate waste facility (state municipal solid waste, state non-municipal non-hazardous waste, federal hazardous waste landfill, or a federally approved PCB disposal facility -- see 761.61(a)(5)(v)). Waste water produced during the job from mopping, wet cleaning, or misting may be regulated for disposal. If you know the concentration of PCBs in waste water, follow the decontamination procedures for water at 40 CFR part 761.61(a)(4)(iv). Otherwise, assume the waste water to be regulated and dispose of the water in a TSCA approved facility (40 CFR part 761.61(b)(1)).
To find a solid waste disposal facility that will accept PCB-containing caulk, please contact your state environmental agency.
Previous page: Abatement Step 2: Conduct Removal and Abatement Activities