Disposal and Remediation Options Under the PCB Mega Rule

August 1999
ELR 10459
James A. Vroman

Editors' Summary: On June 29, 1998, EPA published its PCB Mega Rule, a comprehensive revision of TSCA regulations that govern the remediation and disposal of PCB-contaminated material. The PCB Mega Rule affords the regulated community the option of remediating such material under self-implementing provisions or developing risk-based site-specific remedial measures that generally require Agency approval.

This Article examines the PCB Mega Rule, focusing particular attention on the provisions that address the disposal of PCB-contaminated waste resulting from spills and similar events and on the self-implementing provisions that address the remediation of PCB-contaminated porous surfaces. The Article compares the regulations applicable to such niaterials both before and after the promulgation of the PCB Mega Rule and concludes with an evaluation of the Mega Rule's benefits and shortcomings.

Mr. Vroman is a partner at the Chicago law firm of Jenner & Block. For the last 13 years, he has concentrated his practice in environmental law. He received his J.D. from the University of Illinois in 1977.

Article File