On February 26 of 2024, the EPA’s new rules regarding PCB remediation became effective.
Among these changes is the addition of several new extraction methods for analyzing PCB waste. It also includes various notification, verification and recordkeeping requirements. A more detailed summary of the changes can be reviewed using the following link:
Perhaps the most impactful change impacting the cost of remediation is in the area of disposal. PCB remediation can be done under a Self-Implementing Plan (SIP), Risk-Based or Performance-Based. The Self-Implementing and Risk-Based options both require work plans to be submitted to and approved by EPA, but they allowed the use of RCRA Subtitle C landfills for solid PCB remediation with at found concentrations > 50 ppm and Subtitle D landfills for at found concentrations < 50 ppm. Performance-based cleanups, which do not involve EPA workplan approval, required all PCB-contaminated media with an original source > 50 ppm to be disposed at TSCA-permitted facilities, of which there are only a few, thereby increasing the cost. This new rule opens up the option to dispose of solids at RCRA Subtitle C facilities, thereby serving to increase possible outlets and decrease costs.
In practical terms it will still take time for various Subtitle C facilities to amend their permits to allow themselves to accept PCB remediation waste from Performance-Based cleanups, and others may still elect not to for company policy and liability purposes or local regulations.
These options are not available for liquid waste as landfilling is not permitted for PCB liquid waste. Oil, water and electrical equipment require special handling, which includes dichlorination and/or incineration, depending on the concentrations, which are based on levels of 50 and 500 ppm, respectively.
AWT is a full-service site remediation, decontamination and waste disposal contractor who has been in business and remediating PCBs in all types of media since 1982. Our staff remain on top of these regulations and incorporate them into our approach to projects. Our crews have specialized training, and we have all the necessary licenses and insurance to perform this type of work. Our goal is to partner with consultants and work under your oversight to effectively and safely remediate your clients’ sites.