You are here: EPA Home Wastes Hazardous Waste Polychlorinated Biphenyls (PCBs) PCBs in Caulk in Older Buildings Steps to Safe Renovation and Abatement of Buildin g s 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

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Classification of Removed Materials with PCBs Abatement Prioritization Notifications to EPA May Be Re quired Prior to Starting a Project



### Classification of Remove d Materials with PCBs

If you are removing PCB-containing caulk (bul k product waste) or removing the surrounding PCB-contaminated building materials (remediation waste), you will need to determine your disposal option prior to commencing the abatem ent 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 noti fication 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 co ncentrations that is not intact and is peeling, brittle, cracking or visibly deterior ating also has a high potential for release of PCBs and also poses a potential to contam inate 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) htt p : // www.e p a. g ov / e p awaste / hazard / tsd /p cbs /p ubs / caulk /g uide /g uide-sect4a.htm Last u p dated on Monda y, November 14

, 2011 

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4a.htmthat are easily accessible by building occupants should receive a higher priority when eval uating 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 work ers, the accessibility rating should take into account the potential for building o ccupants to contact PCB-containing building material directly (dermal or ingestion) or indirectly via the air handling system (inhalation).

Occupancy -- PCB-containing materials in locati ons that have a higher rate of occupancy should receive a higher priority when evaluating th e need for removal because of the increased potential for dire ct 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 exampl e, conducting the abatement in phases could allow for partial occupancy of a buildin g. The phasing sequence should consider the physical layout of the building to dete rmine 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 Ma y Be Required Prior to Starting a Project

Depending on the method you choose for disp osal of contaminated wastes and cleanup debris, you may be required to submit document ation 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 reme diation 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 "Notificat ions and Certifications" below. The plan must include a description of the removal and ab atement schedule, disp osal technology, and 

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4a.htmapproach. The cleanup approach described in the plan should identify the proposed cleanup levels, removal and abatement procedures, veri fication 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 (40CFR 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 notificati ons 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 en vironmental protection agency where the cleanup will be conducted.

Within 30 calendar days of receiving the no tification, the EPA Regional Administrator will respond in writing approving of the self-implementing cleanu p, disapproving of the selfimplementing cleanup, or requiring additional information. If the EPA Regional Administrator does not respond within 30 calendar days of re ceiving the notice, it ma y be assumed that the plan is complete and acceptable and the clea nup 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 th an 14 calendar days prior to implementation of the change.

Risk-Based Disposal Approval -- To sample, cleanup, or di spose of building materials contaminated with PCBs in a mann er other than described under 40CFR part 761.61 (a) you must submit and application to EPA under the ri sk-based disposal option, an application must be submitted to EPA. Each application must contain the information described in the notification requirem ents 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 ap prove an application if EPA finds that the method will not pose an unreasonable risk of injury to health or th e 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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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4a.htmYou are here: EPA Home Wastes Hazardous Waste Polychlorinated Biphenyls (PCBs) PCBs in Caulk in Older Buildings Steps to Safe Renovation and Abatement of Buildin g s 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 br icks 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 Select ing 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 fa ces) play a role in the selection of tools. The most frequently encountered materials of adjoining structur es include concrete, sandstone, bricks, polystyrene (with plaster la yer), wood, and metals (e.g., window frames).

The anticipated dust and heat generation plays an important role in select ing 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) htt p : // www.e p a. g ov / e p awaste / hazard / tsd /p cbs /p ubs / caulk /g uide /g uide-sect4b.htm Last u p dated on Wednesda y, October 20

, 2010 

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4b.htm

### Typical Tools and Methods for Removal Activities

Manual tools are primarily used for smaller join t lengths or when the joints are difficult to access for structural reasons. The summa ry 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 electromechani cal methods include a lower volume of fine dust, the absence of heat development, and co nsequently, 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 ex posure, can be quickly and effi ciently 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 chis eled 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 an d 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 th ese situations. Generally, electromechanical procedures generate higher vo lumes of dust and more heat, which requires more complex protective measures (personal and environmen tal protection) than manual methods. Some electromechanical tools may have limited app lications (e.g., jigsaw) or are unsuitable because they produce significant amounts of du st or high heat. The summary of suggested tools and methods page provides a summary of the typi cal electromechanical tools and methods used for removal activities.

Typically, joint faces have to be cleaned after th e 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 remainin g. The selection of tools and methods for cleaning/reworking joint faces is primaril y based on structural requirements and consideration of protective measures. Additiona lly, the material properties of the adjoining structures must be taken into account to ensu re that the joint faces are not damaged. Tools with beating, striking, or pronounced abrasi ve effects are not suitable for working on sensitive adjoining structures, such as limeston e, plaster-covered insulation, wood, or metal parts.

An effective method to treat joint faces is dr y ice blasting, which is primarily reserved for major restoration projects because of the comp lex 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 meas ures 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 a ddition, used solvent and/or cleaning rags may be subject to regulation under federal or au thorized state hazardou s waste regulations.

Data from individual restoration projects have shown that PCBs spread from the caulk into adjoining structures (e.g., brick, wood, or co ncrete) over time. Conseq uently, it is highly likely that the material adjoin ing the PCB-containing caulk at the joint face is contaminated. In many cases of caulk contaminated with PC Bs at > 1,000 ppm, several millimeters of the adjoining concrete contained PCB contamination in a concentration range of several hundred 

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4b.htmto several thousand parts per million. As pr eviously discussed, the adjoining materials contaminated with PCBs are typically characte rized as PCB Remediation Wastes and must be handled in accordance with 40CFR part 761.61 . Refer to Abatement Step 3 for more information.

Under certain situations, it may be more practi cal 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 circul ar 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 no n-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 depe nds on the volume of dust generated by the particular work method. To limitprotective measures needed, it is best to select tools and methods that generate the lowe st possible dust volume. Protec tive measures should provide for direct personal protection (workers), protec tion of building users and third parties (e.g. passers-by), and safeguard the potential for spreading PCB contamination (crosscontamination) to surrounding ar eas 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 fr om spreading outside th e abatement area. For example, a containment structure can be construc ted 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 ne gative air pressure by installing an induced draft fan equipped with High Efficiency Particul ate 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 th e 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 vo lumes, 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 th e amount of dust that can spread through the containment area, and can significantly reduce th e amount of dust in the breathing zone of the worker using the tool. Affixing a dust collec tor nozzle (connected to an industrial vacuum with HEPA filters) to the working end of the el ectromechanical tool is an example of a dust aspiration technique. The figure below illustra tes 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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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4b.htmSource: Rex, G.B., www.pcbinschools.org, accessed July 2009.
Examples of Dust Aspiration Tech niques 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 protecti ve measures (personal protection gear) when working with dust-generating methods or tools. These protection measures should prevent PCBs from getting into the body through inhala tion, 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 certai n 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 shou ld 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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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4b.htmProtective 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 prot ective measures for third parties and the environment when ha ndling materials containing PCBs:

Adequately construct a containm ent 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 mate rials, directly at the place of removal. Materials should be placed in tightly-lock ing, stable containers, for example fiber drums or polyethylene buckets with polyethylene lining. Regularly clean the work area, including t ools and machinery, with an industrial vacuum and HEPA filter and/or mopping to remove particles. Properly dispose of contamin ated protective clothing (gloves and protective suits), filters of aspiration devices, and clea ning aids in the containment area.

In addition to these generally applicable pr otective measures, consider conducting air sampling in the vicinity of the containment ar ea to assess whether PCB-contaminated dust is escaping the containment area and impacting ne arby clean areas. The air sampling should be conducted the procedures discussed in the sect ion 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 cont ainment area structure

Heating, Ventilating and Ai r Conditioning (HVAC) -- The HVAC system should be shut down and remain off until PCB abatement is comple te. 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 ve ntilation 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 (whi ch, if damaged during cleaning, can release fiberglass into living areas). Also, flexible du ctwork frequently has a porous inner surface and, in most cases, cannot be economically cl eaned. 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 sy stem should be sealed at all openings to 

### To protect third parties and the environment during abatement projects, it isimportant to prevent PCBcontaminated dust from contaminating the immediate surroundings. 

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4b.htmprevent potential recontamination. At a mini mum, when approaching a ventilation system constructed of non-porous material s, ventilation contractors should:

Perform a walk-through of the structur e 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 loca l 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 workin g environment. Site secu rity measures should also be implemented to prevent unauthorized access to the containment areas. Read about specific security measures and suggested notification

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### Suggested Work Area Decontamination Methods

Following the abatement activity and break down of the containment ar ea, the entire area should be vacuumed with an industrial HEPA vacuum and wiped with we t rags to remove any dust from surfaces within the ar ea. 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 deco ntaminated 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 suff icient number of wipe sample s within the subject area to ensure that the area was fully decontaminated . The number and location of samples should be determined in accordance with 40CFR 761 Subpart O (bulk wastes and porous surfaces) or Subpart P (non-porous surfaces), with a mi nimum of three samples collected from each type of Bulk PCB Remediation Wastes. You shou ld 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 en tire 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 AbatementStrategy

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- 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, reco rdkeeping 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 40CFR 761.62 . Under this provision, the removed caulk must be disposed of using on e 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 chemic al 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 fo r 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. (40CFR 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) htt p : // www.e p a. g ov / e p awaste / hazard / tsd /p cbs /p ubs / caulk /g uide /g uide-sect4c.htm Last u p dated on Wednesda y, A p ril 21

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4c.htmNOTE: Re-sampling of caulk waste is not nece ssary 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 ot her building materials contaminated with PCBs is regulated under 40CFR 761.61 . There are three options for ma nagement 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 materi als are present. The disposal requirements for the selfimplementing option vary based on th e type of contaminated material and concentration of PCBs in the materials, among other things. Contact your PCB Regional coordinator if you elec t to use this disposal option.

Performance-based disposal . The performance-based option allows for disposal or decontamination of the contaminated materi als in a TSCA chemical waste landfill; a TSCA incinerator; through a TSCA approv ed alternate disposal method; under the TSCA regulation's decontamination procedur es; or in a facility with a coordinated approval issued under TSCA. Disposal under th is 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 th e alternatives provid ed under the selfimplementing or the performance based dispos al 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 concentratio n, including rags, mops, gloves, Tyvec suits, and similar materials resulting from cleanu p activities must be disposed of in an appropriate waste facility (state municipal solid waste, stat e non-municipal non-hazardous waste, federal hazardous waste landfill, or a federally appr oved PCB disposal facility -- see 761.61(a)(5) (v)). Waste water produced duri ng the job from mopping, wet cleaning, or misting may be regulated for disposal. If you know the concen tration of PCBs in waste water, follow the decontamination procedures for water at 40CFR part 761.61(a)(4)(iv) . Otherwise, assume the waste water to be regulated and dispose of the water in a TSCA approved facility (40CFR part 761.61(b)(1) ).



### Disposal Facilities

See a listing of TSCA approved disposal facilities

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11/14/2011 http ://www.e p a. g ov/e p awaste/hazard/tsd/ p cbs/ p ubs/caulk/ g uide/ g uide-sect4c.htmTo find a solid waste disposal facility that will accept PCB-containing caulk, please contact your state environmental agency

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