Frequent Questions

What treatment is required for polychlorinated biphenyls (PCBs) prior to land disposal?

The Resource Conservation and Recovery Act does not prescribe specific polychlorinated biphenyl (PCB) treatment technologies. PCBs are generally regulated by the Toxic Substances Control Act (TSCA). For further information on their regulations, we recommend that you contact the TSCA Hotline at (202) 554-1404.

The LDR requirements only apply to those hazardous wastes subject to 40 CFR Part 268.  PCBs are not defined as hazardous wastes in Part 261 and therefore not subject to Part 268 (Memo, Weddle to Verde; May 18, 1984 (RCRA Online #12235)). 

When land disposing a hazardous waste, the waste must first meet the land disposal restrictions (LDR) treatment standards (40 CFR §268.40). Some LDR treatment standards also require treatment for underlying hazardous constituents (UHCs). PCB is one such UHC. Total PCBs (the sum of all PCB isomers, or all Aroclors) must be treated to a concentration of 0.10 mg/l in wastewaters and 10 mg/kg for nonwastewaters (§268.48). There is no specific treatment technology required for meeting these concentration standards. Soil exhibiting the toxicity characteristic solely because of the presence of metals (D004-DO11) and containing PCBs do not have to meet the LDR treatment standards if:  

-- the waste contains halogenated organic compounds in total concentration less than 1,000 mg/kg; and 
-- the waste meets the LDR treatment standards for D004-D011 or for contaminated soil (Section 268.49).

However, PCB-containing dielectric fluid and the electronic equipment which holds such fluid are exempt from RCRA Subtitle C regulation if the material satisfies two criteria (§261.8).  First, the PCB wastes must be regulated under the TSCA standards in Part 761.  Second, only the PCB wastes that exhibit the toxicity characteristic (TC) for waste codes D018 through D043 may qualify for the exemption (Monthly Call Center Report Question, September 1996 (RCRA Online #14014)).

When PCBs are present in hazardous waste, both RCRA and TSCA regulations may apply to the waste. However, when the regulations conflict, the stricter regulation applies (Memo, Lowrance to Wassersug; September 22, 1989 (RCRA Online #11470)).
 
This guidance document is available in the RCRA Online database at the following URL: https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm
 
In addition, it is important to note that this guidance represents clarification of the Federal regulations. Most states are authorized to implement the Federal regulations. We recommend that you also contact your state's implementing agency to acquire additional information on the regulation of PCBs. The Office of Resource Conservation and Recovery (ORCR) has compiled a complete list of phone numbers and waste program Web sites maintained by EPA Regional offices and state environmental agencies to help users locate the appropriate agency within their states. This compilation is found at the following URL: www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies

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