What is PCB Remediation Waste?
PCB remediation waste is waste containing PCBs from a spill, release or other unauthorized disposal of PCBs, depending on the concentration of the source of PCBs, the date of release, the current PCB concentration in the materials, and whether the original source was authorized for use. The complete definition of PCB remediation waste can be found in Title 40 of the Code of Federal Regulations (CFR) in section 761.3. PCB remediation waste can include the following:
- Other man-made structures
What are the Cleanup and Disposal Options for PCB Remediation Waste?
The PCB regulations include three options for management of PCB remediation waste. They can be found in 40 CFR part 761.
- Self-implementing cleanup and disposal (40 CFR section 761.61(a))
The self-implementing option links cleanup levels with the expected occupancy rates of the area or building where the contaminated materials are present.
Along with some other factors, the disposal requirements for the self-implementing regulatory option vary based on the type of contaminated material and concentration of PCBs in the materials. You must notify EPA if you intend to utilize the self-implementing option.
Consider using Tool 3, TSCA Self-Implementing PCB Cleanups Checklist, on page 29 of the PCB Facility Approval Streamlining Toolbox (PCB FAST).
For sampling porous surfaces, the Standard Operating Procedure linked below describes how to sample both hard and soft porous surfaces:
- Standard Operating Procedure for Sampling Porous Surfaces for PCBs
- Performance-based disposal (40 CFR section 761.61(b))
Through this option, facilities:
- Dispose of contaminated non-liquid materials in a Toxic Substance Control Act (TSCA) chemical waste landfill,
- Dispose of contaminated non-liquid materials in a TSCA incinerator,
- Dispose of contaminated non-liquid materials in a TSCA-approved alternate disposal method,
- Decontaminate non-liquid contaminated material under TSCA-regulated decontamination procedures, or
- Dispose of non-liquid contaminated materials in a facility with a coordinated approval issued under TSCA
Section 761.61(b) only addresses disposal of PCB remediation waste. EPA notification and approval is not required under this option, however, you are encouraged to contact your Regional PCB Coordinator with questions. Facilities are required to follow any manifesting, transportation and storage requirements that may apply. Performance based disposal may be used for sites of any size.
If someone were to avail themselves of performance based disposal under section 761.61(b), but leave materials on-site > 1 ppm, they would still have TSCA obligations for those remaining materials.
- Risk-based cleanup and disposal (40 CFR section 761.61(c))
The risk-based option allows for a site-specific approval to sample, cleanup, or dispose of PCB remediation waste in a manner other than the self-implementing or the performance-based disposal options.
This option requires you to obtain an approval from EPA based on a finding that the proposal will not present an unreasonable risk of injury to health or the environment.
Consider using Tool 4, TSCA Risk-Based PCB Cleanups Checklist, provided in the PCB Facility Approval Streamlining Toolbox (PCB FAST) on page 39.
PCB Facility Approval Streamlining Toolbox (PCB FAST)
The PCB Facility Approval Streamlining Toolbox (PCB FAST) is designed to help Responsible Parties (RPs) and regulators, whenever possible, reduce delays, improve communication, and increase efficiency in the cleanup and disposal of PCBs at a site. PCB FAST focuses on establishing a collaborative working relationship between EPA and the RPs and providing tools to be used by RPs to prepare adequate and appropriate cleanup notifications and applications. The Toolbox includes guidance, process flow maps, and checklists to facilitate streamlined cleanup processes. These resources can be customized to meet each site or Region’s needs.
PCB FAST includes the following tools that may be accessed by the above link:
- Tool 1: Initial Discussion with Responsible Party Checklist
- Tool 2: PCB Sites Cleanup Framework
- Tool 3: TSCA Self‐Implementing PCB Cleanups Checklist – 61(a)
- Tool 4: TSCA Risk‐Based PCB Cleanups Checklist – 61(c)
PCB Spill Cleanup Policy Guidance Manuals
The PCB Spill Cleanup Policy is intended for fresh spills of liquid PCBs. The Policy is referenced in 40 CFR 761 Subpart G. The PCB Spill Cleanup Policy is an enforcement policy, not a regulation.
In addition to other applicability limitations found in 40 CFR section 761.120, this policy only applies to spills less than 72 hours old. The use of the methods in this guidance manuals is an option, not a requirement.
If the reader has any questions about the interpretation or applicability of the Policy, the reader should contact the Regional PCB Coordinator in the EPA Region where the spill occurred.