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TSCA Interpretation for PCB Waste Containers from EPA

TSCA Interpretation for PCB Waste Containers from EPA

March 14, 2005

Stephen Hammond, P.E.
Director
Division of Solid & Hazardous Materials
NYS Department of Environmental Conservation

Dear Mr. Hammond:

This is in response to your letter of February 22, 2005 concerning the Toxic Substances Control Act (TSCA) and how it pertains to PCB waste, PCB containers and the uniform hazardous waste manifest. Your inquiry requests confirmation of your understanding of how to complete the manifest when shipping PCB waste in containers.

You are correct in your understanding that in completing Box 13 of the manifest, Total Quantity, that you only need to include the weight of the waste contained in the PCB Container or PCB Article Container; not the weight of the container and the waste. [Note: PCB Transformers, Capacitors and other PCB Articles are not considered PCB Containers or PCB Article Containers and their total weight (carcass and internal fluid) must be included in Box 13]. You are also correct in your understanding that you are not required to indicate the method of disposal in Box 13. This has no bearing on total quantity. Lastly, when reporting PCB weight in Box 13, gallons is not the correct unit of measurement. The weight must be reported in kilograms.

Sincerely,

Maria J. Doa, Ph.D.
Director
National Program Chemicals Division
Office of Prevention, Pesticides and Toxic Substances
US Environmental Protection Agency


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