The requirements for PCB wastes in "storage for disposal" differ from the requirements for PCB wastes in "temporary storage for disposal." PCB wastes stored in laboratories can be considered "storage".  (See "Storage for Disposal" and "Temporary Storage for disposal" in Section 3 for more information.)

Storage for disposal

This presents a summary of the requirements for PCB wastes stored in laboratories for disposal -- not temporarily stored for disposal.

PCB wastes must be sent to a disposal facility within nine months of the date the waste began accumulating.

PCB waste containers in labs must be marked with the PCB warning and with the date accumulation began. Additionally, the entrance to the laboratory must be marked with the PCB warning or, as an alternative, laboratory personnel may mark the fume hood or storage cabinet where the waste is stored.

PCB waste containers stored in labs must be inspected for leaks every 30 days. A written log of the inspections must be maintained.

PCB waste containers must be in a 6 inch containment pan to meet the TSCA requirements applicable to a "storage for disposal" area. For example, storage of PCB waste in laboratory fume hoods meets all the requirements of a "storage for disposal" area if the waste are placed in a containment pan with 6 inch sides.

PCB wastes in labs must be in DOT specification containers.

PCB wastes (liquids) in labs should be segregated based on concentration: 50 ppm to 500 ppm PCBs in one container, >500 ppm PCBs in a separate container. Dilution may not be used to avoid the TSCA regulations. Thus, the concentration of PCBs in the container must be considered to be equal to the highest PCB concentration of wastes added to the container.

Temporary storage for disposal

"Temporary storage for disposal" is not the best option for storage of PCB waste in laboratories due to the 30 day limit and the 500 ppm concentration limit.