Managing PCBs in the Pacific Northwest and Alaska | Region 10 | US EPA

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Managing PCBs in the Pacific Northwest and Alaska

Contact Us

Michelle Mullin (mullin.michelle@epa.gov)
PCB Coordinator, 206-553-1616

Dave Bartus (bartus.dave@epa.gov)
Cleanup, PCB Radioactive Waste
206-553-2804

Linda Meyer (meyer.linda@epa.gov)
Landfills, 206-553-6636

Kelly McFadden (mcfadden.kelly@epa.gov)
Manager, 206-553-1679

On this page:

Light ballasts, caulk, and paint

How do I dispose of light ballasts?

How do I test my building for PCBs?

How do I manage caulk and paint with PCBs?

Once you've confirmed the presence of PCBs in your building, you should remove the paint and/or caulk and send it to a solid waste landfill. Follow the regulations at 40 CFR 761.65(b) (Storage for disposal) (PDF) (12 pp, 181K). Any storage for disposal, including on-site storage, must be conducted in accordance with the applicable requirements of 761.65.

Ongoing use is not authorized. If you cannot remove the product immediately, or if you have questions regarding the removal process, please contact Michelle Mullin (mullin.michelle@epa.gov) at 206-553-1616 to discuss your cleanup and removal options.

Please see our Steps to Safe Renovation and Repair Activities to learn about some of the precautionary measures and to follow the best work practices when conducting a repair or renovation in older building where PCB-containing caulk are present.

What are the procedures for cleaning up caulk and paint?

What are the options for cleanup and disposal of PCB bulk product waste?

What is bulk product waste?

  • PCB Bulk product waste is a waste that is derived from manufactured products containing PCBs in a non-liquid form where the concentration is ≥50 ppm PCBs.
  • PCB bulk product waste includes caulk, paint and plastics.
  • Refer to 40 CFR 761.3 (Definitions) for the complete PCB bulk product waste definition.
  • For additional information, see page 92 of the PCB Question & Answer Manual (PDF) (134 pp, 476K).

Bulk product waste should be cleaned up according to 40 CFR 761.62, which provides storage and disposal options that do not require EPA oversight and approval. However, in the event you cannot immediately dispose of the product or comply with the regulations, you must apply for a risk-based disposal approval. PCB bulk product waste may be disposed of in one of three ways by adhering to the appropriate regulatory requirements in 761.62:

  1. 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.
  2. Disposal in solid waste landfills
    Certain PCB bulk product waste, such as PCB-containing caulk, even if the concentration of PCBs in the caulk is >50 ppm, may be disposed of in non-hazardous waste landfills permitted by States. Disposal under this option does not require you to obtain approval from EPA, but does require notification of the landfill prior to the first shipment.
  3. Risk-based option
    The risk-based option allows for a site-specific, risk-based 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 based on a finding that the disposal will not present an unreasonable risk of injury to health or the environment.

Is there a Renovation, Repair, and Painting (RRP) or certified contractor program?

  • No, the RRP program only applies to lead-based paint hazards.

Can I offset the cost of PCB removal in my building?

Removal and disposal of PCBs can often be integrated with energy efficiency projects, helping to achieve gains in environmental protection and long-term cost savings. States offer rebates for window, lighting and insulation (caulk) replacement. Additionally, replacing these items will lead to energy savings and reduced utility bills. Below are some currently available (as of August 2014) financial incentive programs:

Additional rebate information:

Many building upgrade projects can simultaneously remove chemical pollutants and improve energy efficiency- thereby improving occupant health while reducing operational costs. For more information, see EPA's Basic Steps to Using the Energy Savings Plus Health Guidelines.

Is there specific guidance for schools?

Questions?

For questions about managing PCBs in light ballasts, caulk, and paint, please contact:

  • Michelle Mullin (mullin.michelle@epa.gov)
    Region 10 PCB Coordinator, 206-553-1616
  • Molly Finn (finn.molly@epa.gov)
    PCBs in caulk, 703-347-8785
  • Robert Courtnage (courtnage.robert@epa.gov)
    PCB in light ballasts, 202-566-1081
  • Amy Hensley (hensley.amy@epa.gov)
    Sampling and analysis, 703-305-5084

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Remediation waste (non-building materials)

What is PCB remediation waste?

  • Generally, PCB remediation waste is waste contaminated with PCBs from a spill, release, or other unauthorized disposal of PCBs.
  • PCB remediation wastes include soil, gravels, concrete, buildings, and other man-made structures etc.
  • The complete definition is more detailed. Please see 40 CFR 761.3 (Definitions) for the full definition.
  • For additional questions regarding to PCB Remediation Waste please see, page 71 of the PCB Question & Answer Manual (PDF) (134 pp, 476K).

What are the cleanup and disposal options for PCB remediation waste?

PCB regulations include three options for management of PCB remediation waste:

  1. Self-implementing cleanup and disposal
    The self-implementing option links 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 regulatory option vary based on the type of contaminated material and concentration of PCBs in the materials, among other things. Cleanup and disposal under this option requires you to notify EPA. Region 10 expects that most sites will fall under the self–implementing guidelines.

    Region 10 self-implementing approvals will include a checklist of the regulations, which you must adhere to. Review this checklist prior to submitting your application to reduce delays in the approval process:
  2. Performance-based disposal
    Performance-Based Disposal can be used at any size site, and in situations where PCB concentrations are unknown, and testing is not feasible. Facilities can assume that PCB concentrations are 500 ppm or greater, remove all PCBs from site, and dispose the contaminated materials in either a TSCA chemical waste landfill or TSCA incinerator, through a TSCA-approved alternate disposal method, under the TSCA-regulated decontamination procedures, or in a facility with a coordinated approval issued under TSCA. EPA notification and approval is not required. You are required to follow all regulations in 40 CFR 761.61(b), as well as any manifest, transportation and storage for disposal requirements that may apply in addition to 761.61(b).
  3. Risk-based cleanup and disposal
    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. Disposal of PCB remediation waste under this option requires you to obtain an approval from EPA based on a finding that the disposal will not present an unreasonable risk of injury to health or the environment.

    If your site is excluded from the self-implementing regulations, and you are not following the performance-based guidelines, you may apply for a risk-based cleanup and disposal:

Am I required to comply with greener cleanup practices for my cleanup site?

EPA encourages the compliance with greener cleanup practices for all cleanup projects, and includes adherence to the ASTM Standard Guide to Greener Cleanups as a condition of its cleanup approvals.

Greener cleanup is the practice of incorporating options that minimize the environmental impacts of cleanup actions in order to incorporate practices that maximize environmental and human benefit. Region’s 10 Clean & Green Policy supports greener cleanup by promoting sustainable technologies and practices in our cleanup programs in order to conserve energy and help our citizens save money.

Learn more about greener cleanups:

Region 10 PCB cleanup sites:

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PCBs in used oil

How do I dispose of my used oil?

Related information:

If you are disposing of used oil from multiple or anonymous sources, you should ensure that the oil is not contaminated with PCBs prior to transporting for disposal. Laboratory analysis is the only way to know if the oil is contaminated with PCBs.

What used oil is regulated by the TSCA PCB regulations?

  • Any used oil that contains quantifiable levels of PCBs.

How do I test my used oil?

Can I recycle my used oil with PCBs?

No, used oil contaminated with PCBs must be disposed at an incinerator, a high efficiency boiler, a chemical waste landfill or alternate destruction method pursuant to 40 CFR 761.60.

Is used oil contaminated with PCBs considered PCB remediation waste?

  • No.

What do I do if my oil is contaminated with PCBs?

  • If used oil is contaminated with PCBs at a concentration greater than or equal to 50 ppm at the point of generation, the used oil is regulated for disposal.
  • If any PCBs at a concentration of 50 ppm or greater have been added to the container or equipment, then the total container contents must be considered as having a PCB concentration of 50 ppm or greater for purposes of complying with the disposal requirements of this part.
  • Used oil that contains PCBs with an original source concentration of 50 ppm or greater must be must be disposed at an incinerator, a high efficiency boiler, a chemical waste landfill, or alternate destruction method pursuant to 40 CFR 761.60. See list of commercially permitted PCB disposal companies.
  • Manifest, storage, and record keeping must be followed for authorized disposal.
  • You are responsible for ensuring full compliance with regulation 40 CFR 761.20 (Prohibitions and exceptions).

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PCB storage, disposal, and transportation

How do I dispose of an x-ray machine?

X-ray equipment must be disposed of through a commercial x-ray company or recycler to ensure proper disposal. You should ensure that disposal follows all state rules regarding handling and disposal of radioactive material and radiation-producing equipment. Information by state can be found below:

Old machines (pre 1978) may contain PCBs in the capacitors, wiring insulation, etc. If machines contain PCBs at concentrations 50 ppm or greater, the PCB Items must be disposed of at a TSCA authorized facility.

I have PCB household waste - what are the rules?

PCB Household waste is waste that is composed of materials generated by consumers in their homes including unwanted or discarded non-commercial vehicles (prior to shredding), household items, and appliances or appliance parts. Bulk or commingled liquid PCB wastes at concentrations of ≥50 ppm, demolition and renovation wastes, and industrial or heavy duty equipment with PCBs are not household wastes. For a full definition see 40 CFR 761.3 Definitions.

Household waste can be disposed of in a state-permitted municipal landfill or non-hazardous waste landfill as described in 40 CFR 761.63 (PCB household waste storage and disposal).

For additional questions regarding to PCB household waste please see, page 107 of the PCB Question & Answer Manual (PDF) (134 pp, 476K).

What are the guidelines for recycling concrete?

PCB contaminated concrete is considered PCB bulk remediation waste. Any person disposing of concrete on which PCBs have been spilled must do so in accordance with 40 CFR 761.61 (PCB remediation waste). Non-contaminated concrete may be recycled.

Do I need an EPA identification number to transport or dispose of PCB waste?

All generators must have a TSCA ID. Generators can either use their assigned RCRA ID, or if a RCRA ID is not already assigned, request one from EPA. In some circumstances generators may use the generic TSCA ID, "40 CFR PART 761"

Any generator, commercial storer, transporter, or disposer of PCB waste (other than generators exempt from notification regulation as described in 40 CFR 761.25 (c)(1) (Prohibitions and exeptions) must notify EPA of PCB waste handling activities by using the notification procedures and form as described in 40 CFR 761.205 (Notification of PCB waste activity). EPA will confirm the EPA ID number of facilities and will only assign EPA ID number to facilities that do not have one. EPA ID numbers will be mailed by EPA Headquarters.

Who may use the generic "40 CFR PART 761" ID number?

40 CFR 761.205(c)(1) and (c)(2) explain that generators of PCB waste do not need to notify EPA and receive a unique EPA ID unless their PCB waste activities include:

  • Using, owning, servicing or processing PCBs or PCB Items only if they own or operate a PCB storage facility subject to the storage requirements of 761.65 (b) or (c).

Generators exempted from notifying EPA under 761.206(c)(2) can use the generic ID "40 CFR PART 761" on manifests, records and reports, unless the generator elects to use an EPA ID previously assigned to them under RCRA by EPA or a state.

Where is the form to fill out to receive an EPA ID number?

I have a cleanup site, demolition project or other waste generation procedure and I’ll be storing waste on site temporarily- what are the rules?

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