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PCBs in Caulk in Older Buildings Steps to Safe Renovation and Abatement of Buildings That

Have PCB-Containing Caulk Abatement Step 1: Prepare an Abatement Strategy 

Abatement Step 1: Prepare an Abatement 

Strategy 

Based on the results of the sampling plan, an abatement 

strategy should be developed. This strategy may require 

assistance from your Regional PCB Coordinator and state 

environmental and health agencies. 

Classification of Removed Materials with PCBs 

Abatement Prioritization 

Notifications to EPA May Be Required Prior to Starting a

Project 

Classification of Removed Materials with PCBs 

If you are removing PCB-containing caulk (bulk product waste) or removing the surrounding 

PCB-contaminated building materials (remediation waste), you will need to determine your 

disposal option prior to commencing the abatement activity because you may be required to 

notify EPA before you begin work. 

Descriptions and details on these disposal options are discussed in Abatement Step 3. Some 

of these procedures have requirements for notification and certification; these are described 

under "Notifications" below. 

Abatement Prioritization 

Abatement activities should be prioritized based on 

the information collected during the building 

material characterization and classification steps, 

and based on the following priority drivers: 

PCB Concentrations and Condition -- 

Materials with the highest PCB 

concentrations should receive a high 

priority, as they pose the greatest potential 

for direct exposure and release of PCBs to indoor air. A release of PCB contaminants 

into the air, or off-gassing, is especially likely in locations with direct sunlight. 

Compared to other building materials, caulk will generally have the highest 

concentrations of PCBs. Caulk with lower concentrations that is not intact and is 

peeling, brittle, cracking or visibly deteriorating also has a high potential for release of 

PCBs and also poses a potential to contaminate sand or soil or to be ingested. 

Accessibility -- Materials contaminated with PCBs 

Table of Contents 

Introduction 

Facts About PCBs in Caulk 

Steps to Safe Renovation 

and Repair Activities 

How to Test for PCBs and 

Characterize Suspect 

Materials 

Steps to Safe PCB 

Abatement Activities 

Summary of Tools and 

Methods for Caulk Removal

Materials with the highest 

PCB concentrations should 

receive a high priority, as 

they pose the greatest 

potential for direct exposure 

and release of PCBs to indoor 

air.

Polychlorinated Biphenyls (PCBs)

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/guide-sect4a.htm

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that are easily accessible by building occupants 

should receive a higher priority when evaluating the need for removal because of the 

potential for direct exposure. Note that, in addition to the accessibility of the 

contaminated material to the abatement workers, the accessibility rating should take 

into account the potential for building occupants to contact PCB-containing building 

material directly (dermal or ingestion) or indirectly via the air handling system 

(inhalation). 

Occupancy -- PCB-containing materials in locations that have a higher rate of 

occupancy should receive a higher priority when evaluating the need for removal 

because of the increased potential for direct exposure. However, consideration should 

be given to the need for the safe, continued use of portions of the building during 

removal and clean-up activities. For example, conducting the abatement in phases 

could allow for partial occupancy of a building. The phasing sequence should consider 

the physical layout of the building to determine if the removal and clean-up areas and 

occupied spaces are sufficiently separated. 

Interim Measures -- In some 

cases, interim maintenance 

measures, such as temporary 

encapsulation (i.e., covering 

materials with plastic and 

securing with duct tape), can 

reduce or eliminate exposure 

to PCB-containing building 

materials until they can be 

scheduled for abatement. As 

noted above, PCB-containing 

caulk typically has the highest 

PCB concentrations and will be 

given a higher priority for 

removal over other building 

materials. Masonry, wood, 

brick, and other building 

materials contaminated with 

PCBs typically contain lower concentrations of PCBs. Thus, these PCB-contaminated materials 

typically pose a lower potential for exposure than caulk and should be dealt with accordingly. 

Notifications to EPA May Be Required Prior to Starting a Project 

Depending on the method you choose for disposal of contaminated wastes and cleanup 

debris, you may be required to submit documentation to and obtain approval from EPA prior 

to starting your removal or abatement project. Please see Abatement Step 3 for your 

disposal options. 

Abatement Plan

An Abatement Plan (including a cleanup plan) should be prepared prior to commencing any 

actions at a building. The self-implementing procedures for removal or abatement of PCBcontaminated building materials (i.e., PCB remediation waste), require that an Abatement 

Plan be prepared [40 CFR 761.61(a)(3)(C)] and submitted as part of the notification and 

certification requirements described in "Notifications and Certifications" below. The plan must 

include a description of the removal and abatement schedule, disposal technology, and 

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approach. The cleanup approach described in the plan should identify the proposed cleanup 

levels, removal and abatement procedures, verification sampling procedures, waste storage 

and handling procedures, and disposal options. The plan also must also contain options and 

contingencies to be used if unanticipated higher concentrations or wider distributions of PCBs 

are found, or other obstacles force changes in the cleanup approach. 

Notifications and Certifications for Remediation Waste (40 CFR part 761.61(a)(3)) 

When conducting abatement activities for PCB-contaminated building materials by the selfimplementing procedures or risk-based disposal option under 40 CFR part 761.61(c), you 

must submit the appropriate notifications to the EPA, as described below. 

Self-Implementing Procedure -- At least 30 days prior to removal and abatement of 

building materials contaminated with PCBs using the self-implementing procedure, the 

person in charge of the cleanup or building owner must notify the following people of the 

planned action in writing: 

The EPA Regional Administrator 

The Director of the state or tribal environmental protection agency, and 

The Director of the county or local environmental protection agency where the 

cleanup will be conducted. 

Within 30 calendar days of receiving the notification, the EPA Regional Administrator will 

respond in writing approving of the self-implementing cleanup, disapproving of the selfimplementing cleanup, or requiring additional information. If the EPA Regional Administrator 

does not respond within 30 calendar days of receiving the notice, it may be assumed that the 

plan is complete and acceptable and the cleanup may proceed according to the submitted 

plan. Once cleanup is underway, any changes from the notification must be provided to the 

EPA Regional Administrator in writing no less than 14 calendar days prior to implementation 

of the change. 

Risk-Based Disposal Approval -- To sample, cleanup, or dispose of building materials 

contaminated with PCBs in a manner other than described under 40 CFR part 761.61 (a) you 

must submit and application to EPA under the risk-based disposal option, an application must 

be submitted to EPA. Each application must contain the information described in the 

notification requirements outlined in 40 CFR part 761.61(a)(3). EPA may request other 

information necessary to evaluate the application. EPA will issue a written decision on each 

application for a risk-based method, and will approve an application if EPA finds that the 

method will not pose an unreasonable risk of injury to health or the environment. It is 

recommended that you contact your Regional PCB Coordinator to discuss the necessary 

requirements under the risk-based option. 

Previous page: Steps to Safe PCB Abatement Activities

Next page: Abatement Step 2: Conduct Removal and Abatement Activities

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You are here: EPA Home Wastes Hazardous Waste Polychlorinated Biphenyls (PCBs)

PCBs in Caulk in Older Buildings Steps to Safe Renovation and Abatement of Buildings That

Have PCB-Containing Caulk Abatement Step 2: Conduct Removal and Abatement Activities 

Abatement Step 2: Conduct Removal and 

Abatement Activities 

The removal and abatement procedures for building materials 

such as masonry, wood, and bricks that were contaminated 

with or contain PCBs should be determined based on the 

building material classification, described in the section on the 

building characterization and sampling plan. When caulk with 

PCB concentrations equal to or greater than 50 ppm is 

removed, it must be disposed in accordance with the methods 

provided in 40 CFR 761.62 and described in Abatement Step 3. 

Factors to Consider when Selecting Appropriate Tools 

and Methods 

Typical Tools and Methods for Removal Activities 

Protective Measures 

Suggested Work Area Decontamination Methods 

The following subsections provide an overview of various tools and methods available for 

removal and abatement of caulk and related building materials. Generally tools should be 

selected that minimize dust and heat. 

Factors to Consider when Selecting Appropriate Tools and Methods 

To select the most appropriate tools, it is important to evaluate the location and accessibility 

of the caulk. Material properties are an important consideration for choosing the right tool to 

remove old caulk. Check whether the caulk is hard and brittle (aged and weather-exposed 

caulks, frequently seen in exterior areas) or elastic and soft (primarily in areas protected 

from sunlight and weather, and located indoors). Furthermore, the material and condition of 

the adjoining structures (smooth or rough joint faces) play a role in the selection of tools. 

The most frequently encountered materials of adjoining structures include concrete, 

sandstone, bricks, polystyrene (with plaster layer), wood, and metals (e.g., window frames). 

The anticipated dust and heat generation plays an 

important role in selecting the right tools and 

methods for removal. If your tools or work methods 

generate high heat (temperatures exceeding 212° 

F.), there is the risk that the PCBs may be released 

into the air, and workers or building occupants may 

breathe in PCB gases. More comprehensive 

protective measures are necessary for methods that 

generate moderate to heavy amounts of dust or heat. 

Table of Contents 

Introduction 

Facts About PCBs in Caulk 

Steps to Safe Renovation 

and Repair Activities 

How to Test for PCBs and 

Characterize Suspect 

Materials 

Steps to Safe PCB 

Abatement Activities 

Summary of Tools and 

Methods for Caulk Removal

More comprehensive 

protective measures are 

necessary for methods that 

generate moderate to heavy 

amounts of dust or heat.

Polychlorinated Biphenyls (PCBs)

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/guide-sect4b.htm

Last updated on Wednesday, October 20, 2010

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Typical Tools and Methods for Removal Activities 

Manual tools are primarily used for smaller joint lengths or when the joints are difficult to 

access for structural reasons. The summary of suggested tools and methods page provides a 

summary of the typical manual tools and methods used for removal activities. Advantages of 

manual processes compared to electromechanical methods include a lower volume of fine 

dust, the absence of heat development, and consequently, lower expenditures for personal 

and environmental protection. Utility knives are particularly suitable for manual processes, 

provided the caulk is not too hard or brittle. Soft caulk, especially indoors and in external 

areas without weather or sun exposure, can be quickly and efficiently removed with a utility 

knife. Hard or brittle caulk is mainly found in exterior areas, especially in places with sun 

exposure. Hard or brittle caulk may have to be broken or chiseled out with ripping chisels, 

crowbars, hammers, and chisels. Depending on the condition of the caulk and the 

surrounding materials, the joint faces can be reworked by shaving and scraping with a putty 

knife, scraper, or wire brush. 

Electromechanical tools have ergonomic advantages over most manual methods. 

Electromechanical tools are better suited for projects with many joints and semi-soft to hard 

and brittle caulk. Electrical joint cutters with rotating blades (also known as oscillating 

knives) have proven especially useful in these situations. Generally, electromechanical 

procedures generate higher volumes of dust and more heat, which requires more complex 

protective measures (personal and environmental protection) than manual methods. Some 

electromechanical tools may have limited applications (e.g., jigsaw) or are unsuitable 

because they produce significant amounts of dust or high heat. The summary of suggested 

tools and methods page provides a summary of the typical electromechanical tools and 

methods used for removal activities. 

Typically, joint faces have to be cleaned after the removal of the old caulk to install the new, 

high-quality caulking. The removal of the caulk containing PCBs should be as complete as 

possible, with no visible residue remaining. The selection of tools and methods for 

cleaning/reworking joint faces is primarily based on structural requirements and 

consideration of protective measures. Additionally, the material properties of the adjoining 

structures must be taken into account to ensure that the joint faces are not damaged. Tools 

with beating, striking, or pronounced abrasive effects are not suitable for working on 

sensitive adjoining structures, such as limestone, plaster-covered insulation, wood, or metal 

parts. 

An effective method to treat joint faces is dry ice blasting, which is primarily reserved for 

major restoration projects because of the complex protective measures it requires. In the 

case of smooth, non-porous surfaces such as metal (e.g., unpainted window frames), glass, 

ceramic materials, or tiles, that are not to be removed and disposed of, the surface should 

first be cleaned with a rag dipped in solvent (e.g., acetone). When working with solvents, you 

should observe protective measures such as, the use of solvent-resistant gloves, increased 

air exchange with sufficient fresh air supply, compliance with workplace limit values, and 

measures to prevent fire and explosion. In addition, used solvent and/or cleaning rags may 

be subject to regulation under federal or authorized state hazardous waste regulations. 

Data from individual restoration projects have shown that PCBs spread from the caulk into 

adjoining structures (e.g., brick, wood, or concrete) over time. Consequently, it is highly 

likely that the material adjoining the PCB-containing caulk at the joint face is contaminated. 

In many cases of caulk contaminated with PCBs at > 1,000 ppm, several millimeters of the 

adjoining concrete contained PCB contamination in a concentration range of several hundred 

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to several thousand parts per million. As previously discussed, the adjoining materials 

contaminated with PCBs are typically characterized as PCB Remediation Wastes and must be 

handled in accordance with 40 CFR part 761.61. Refer to Abatement Step 3 for more 

information. 

Under certain situations, it may be more practical to separate PCB-contaminated parts of the 

building materials from adjacent PCB-free materials in the area of the joint faces. This can be 

done with electromechanical tools such as circular saws or slot mills with diamond blades or 

with maximum pressure blasting methods. In such cases, the material separation should 

include sufficient safety spacing from the non-contaminated building parts, and suitable 

measures to contain the dust volume and retain the blasting materials. 

Protective Measures 

Occupational Protective Measures 

Protective Measures for Third Parties and the Environment 

Heating, Ventilating and Air Conditioning (HVAC) 

Communications about the Job and Site Security 

The need for protective measures primarily depends on the volume of dust generated by the 

particular work method. To limit protective measures needed, it is best to select tools and 

methods that generate the lowest possible dust volume. Protective measures should provide 

for direct personal protection (workers), protection of building users and third parties (e.g. 

passers-by), and safeguard the potential for spreading PCB contamination (crosscontamination) to surrounding areas of the abatement project. 

An integral step in implementing protective 

measures is to assign a containment area for each 

distinct abatement area. The containment area size 

and construction should be proportionate to the 

activities that will be conducted (i.e., amount of 

dust generation expected). Containment structures 

should be constructed within the containment area 

at each location where abatement is performed and 

in a manner that prevents airborne dust from spreading outside the abatement area. For 

example, a containment structure can be constructed of poly sheeting draped over existing 

building features and/or support frames built specifically for the containment area. The 

containment area should be maintained under negative air pressure by installing an induced 

draft fan equipped with High Efficiency Particulate Air (HEPA) filters to prevent dust particles 

from being carried out of the containment area. The filtered exhaust from the fan should be 

routed outside the containment area and vented outside of the building. When significant 

dust may be produced by the abatement activities, dust monitoring outside the containment 

structures may be warranted. 

Dust aspiration techniques can be used to reduce the amount of dust created from 

tools/methods that can generate higher dust volumes, such as grinders, cutters, saws, and 

slot mills as identified on the summary of suggested tools and methods page. These 

techniques are efficient methods for reducing the amount of dust that can spread through the 

containment area, and can significantly reduce the amount of dust in the breathing zone of 

the worker using the tool. Affixing a dust collector nozzle (connected to an industrial vacuum 

with HEPA filters) to the working end of the electromechanical tool is an example of a dust 

aspiration technique. The figure below illustrates examples of dust aspiration techniques. 

An integral step in 

implementing protective 

measures is to assign a 

containment area for each 

distinct abatement area.

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Source: Rex, G.B., www.pcbinschools.org, accessed July 2009.

Examples of Dust Aspiration Techniques at the Point of Generation

Occupational Protective Measures -- his section discusses measures for protecting 

workers from exposure to PCB gases and dust. Depending on the selection of tools, PCB 

gases and dust are likely to be released to air when working on an abatement project. 

Therefore, workers should use suitable protective measures (personal protection gear) when 

working with dust-generating methods or tools. These protection measures should prevent 

PCBs from getting into the body through inhalation, ingestion, and/or by absorption through 

exposed skin. 

The following protective measures are generally applicable, and should be considered when 

handling materials containing PCBs: 

Gloves and skin protection -- Chemicalresistant gloves and Tyvec coveralls are the 

standard personal protective equipment 

(PPE). Chemical-resistant gloves made of 

nitrile butadiene rubber (NBR) are 

particularly protective. Pay particular 

attention to the type of gloves and how long 

gloves can be used when working with 

solvents (e.g. for cleaning non-porous 

surfaces). Only certain gloves are suitable 

for working with particular solvents, and 

how long gloves can be used with that 

solvent (breakthrough time) differs. 

Eye protection -- All workers should wear safety 

glasses or protective goggles for all removal, 

abatement, and sampling activities. 

Respiratory protection -- Consider using an airpurifying respirator (OSHA/NIOSH approved) with 

combination organic vapor and HEPA cartridges when 

working with dust generating activities or solvents. 

Worker hygiene -- Eating, drinking, and smoking should be prohibited in the work 

site. For work involving dust generation, showers and separate changing cabins for 

work clothing and everyday clothing should be provided. 

Read about OSHA standards for personal protective equipment. 

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Protective Measures for Third Parties and the 

Environment -- To protect third parties and the 

environment during abatement projects, it is 

important to prevent PCB-contaminated dust from 

contaminating the immediate surroundings (i.e. 

adjoining rooms for interior projects and directly 

adjoining areas of exterior projects). PCBs can stay 

in the environment for long periods of time, and can 

be a source of exposure to building occupants. 

Consider the following protective measures for third 

parties and the environment when handling materials containing PCBs: 

Adequately construct a containment area to minimize the spread of PCB dust to other 

surrounding areas and to make sure proper control requirements are followed (i.e., 

removal of used PPE prior to exiting the control area). 

Properly store removed PCB-contaminated materials, directly at the place of removal. 

Materials should be placed in tightly-locking, stable containers, for example fiber 

drums or polyethylene buckets with polyethylene lining. 

Regularly clean the work area, including tools and machinery, with an industrial 

vacuum and HEPA filter and/or mopping to remove particles. 

Properly dispose of contaminated protective clothing (gloves and protective suits), 

filters of aspiration devices, and cleaning aids in the containment area. 

In addition to these generally applicable protective measures, consider conducting air 

sampling in the vicinity of the containment area to assess whether PCB-contaminated dust is 

escaping the containment area and impacting nearby clean areas. The air sampling should be 

conducted the procedures discussed in the section on testing and characterizing suspect 

materials. When determining if air sampling should be conducted during abatement activities, 

consider the following: 

amount of dust generated by the activities 

location of abatement activities 

duration of dust-generating activities 

size of the area being remediated 

concentration of PCBs in the material being remediated 

effectiveness of the containment area structure 

Heating, Ventilating and Air Conditioning (HVAC) -- The HVAC system should be shut 

down and remain off until PCB abatement is complete. If this is not possible, isolation of the 

abatement area from the HVAC system should be implemented. During the preliminary 

assessment of the extent of PCB contamination, sampling should be conducted in all 

areas/rooms/units serviced by the HVAC system to determine the spread of contamination, 

and sampling results should be noted in the cleanup plan. 

Hire contractors who specialize in cleaning ventilation systems to clean HVAC systems. These 

contractors have specialized tools and training to ensure thorough cleanup. It is important to 

remember that not all ventilation system ducts can be cleaned. For example, some ducts are 

lined with fiberglass or other insulation (which, if damaged during cleaning, can release 

fiberglass into living areas). Also, flexible ductwork frequently has a porous inner surface 

and, in most cases, cannot be economically cleaned. For this reason, the ductwork should be 

discarded and replaced after the ventilation system is cleaned. 

If it is determined that the HVAC system can be cleaned, it should be cleaned early in the 

abatement process. Once cleaned, the HVAC system should be sealed at all openings to 

To protect third parties and 

the environment during 

abatement projects, it is 

important to prevent PCBcontaminated dust from 

contaminating the immediate 

surroundings.

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prevent potential recontamination. At a minimum, when approaching a ventilation system 

constructed of non-porous materials, ventilation contractors should: 

Perform a walk-through of the structure to establish a specific plan for 

decontamination of the ventilation system. 

Follow safety and health procedures, in accordance with OSHA regulations and 

guidelines and other applicable state or local worker safety and health regulations, to 

protect workers and others in the vicinity of the structure during the decontamination 

process. 

Communications About the Job and Site Security -- Clear communication with all 

affected groups (e.g., building occupants, workers, building owners, and community 

members) is necessary to create a safe working environment. Site security measures should 

also be implemented to prevent unauthorized access to the containment areas. Read about 

specific security measures and suggested notification. 

Suggested Work Area Decontamination Methods 

Following the abatement activity and break down of the containment area, the entire area 

should be vacuumed with an industrial HEPA vacuum and wiped with wet rags to remove any 

dust from surfaces within the area. All wastes collected or created (e.g., used rags) should be 

placed in a container or wrapped in plastic, and transported to the disposal storage area. 

Then, conduct a visual inspection of the decontaminated area to determine if additional 

decontamination is warranted (i.e., if the area is still dusty). The HEPA vacuum should also 

be decontaminated or disposed of. 

After the decontamination is considered complete, collect wipe samples from surfaces within 

the subject area. Collect a sufficient number of wipe samples within the subject area to 

ensure that the area was fully decontaminated. The number and location of samples should 

be determined in accordance with 40 CFR 761 Subpart O (bulk wastes and porous surfaces) 

or Subpart P (non-porous surfaces), with a minimum of three samples collected from each 

type of Bulk PCB Remediation Wastes. You should collect samples from horizontal surfaces 

where dust is most likely to accumulate. 

The subject area is considered sufficiently decontaminated if conducted in accordance with 40 

CFR 761.79. If the standard of 10μg/100 cm2 is not met for all of the wipe samples, 

additional decontamination procedures must be performed within the entire subject area and 

additional wipe samples must be collected. These procedures will be repeated until the 

10μg/100 cm2 standard has been achieved. 

Previous page: Abatement Step 1: Prepare an Abatement Strategy

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You are here: EPA Home Wastes Hazardous Waste Polychlorinated Biphenyls (PCBs)

PCBs in Caulk in Older Buildings Steps to Safe Renovation and Abatement of Buildings That

Have PCB-Containing Caulk Abatement Step 3: Handling, Storing, and Disposing of Wastes 

Abatement Step 3: Handling, Storing, and 

Disposing of Wastes 

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? 

The disposal of PCB-containing caulk is regulated under 40 CFR 761.62. Under this provision, 

the removed caulk 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 

caulk 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-containing caulk may be disposed of in nonhazardous waste landfills as permitted by states. Disposal under this option does not 

require you to obtain approval from EPA. However, check state regulations which may 

prohibit or limit disposal of PCB-containing caulk in solid waste landfills. 

Risk-based option. The risk-based option allows for a site-specific evaluation of 

whether caulk may be disposed of in a manner other than under the performance 

based disposal option or the solid waste disposal landfill option. Disposal of caulk 

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)) 

Table of Contents 

Introduction 

Facts About PCBs in Caulk 

Steps to Safe Renovation 

and Repair Activities 

How to Test for PCBs and 

Characterize Suspect 

Materials 

Steps to Safe PCB 

Abatement Activities 

Summary of Tools and 

Methods for Caulk Removal

Polychlorinated Biphenyls (PCBs)

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/guide-sect4c.htm

Last updated on Wednesday, April 21, 2010

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NOTE: 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. 

How Do I Dispose of My Other PCB-Contaminated Building Materials? 

The disposal of masonry, wood, bricks, and other building materials contaminated with PCBs 

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 selfimplementing 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 selfimplementing 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)). 

Disposal Facilities 

See a listing of TSCA approved disposal facilities. 

Abatement Step 3: Handling, Storing, and Disposing of Wastes | Polychlorinated Bipheny... Page 2 of 3

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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

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Abatement Step 3: Handling, Storing, and Disposing of Wastes | Polychlorinated Bipheny... Page 3 of 3

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/guide-sect4c.htm 11/14/2011