PCB Certification-Tradebe 06152017.pdf

PDF 232 KB Posted

Attached to
RFP 63-26 Removal and Disposal of Hazardous Waste
Solicitation number
BD-26-1206-40000-40000-129945
Issued by
Suffolk County, Massachusetts

About this file

This is a PCB Certification document issued by Tradebe Treatment and Recycling, LLC for the Massachusetts Bay Transportation Authority (MBTA) regarding the proper handling and disposal of hazardous waste materials. The certification, dated July 11, 2024, confirms that waste materials generated by the MBTA at 275 Dorchester Avenue in South Boston, Massachusetts contain no PCBs and comply with TSCA (Toxic Substances Control Act) regulations under 40 CFR 761. The document certifies that materials have been properly packaged according to Tradebe's policies and procedures and are stable for handling and transportation under normal conditions. The certification is executed by Christine Lentini, Manager of Hazardous Materials for the MBTA, who verifies that the waste stream meets EPA anti-dilution provisions and contains intact, non-leaking TSCA-exempt ballasts, with the waste classified as floor wash water regulated under TSCA 40 CFR 761 as PCB Remediation Waste.

The MBTA indemnifies Tradebe Treatment and Recycling, LLC and any disposal outlets used by Tradebe from all liability associated with transportation, handling, and disposal of the certified materials. This certification document supports the broader RFP 63-26 for removal and disposal of hazardous waste across MBTA properties, which seeks contractor proposals for emergency response and scheduled services covering petroleum products, antifreeze, PCBs, and miscellaneous hazardous materials at 28 designated facilities. The certification demonstrates the MBTA's compliance with federal EPA regulations and establishes Tradebe as a qualified disposal facility capable of managing the agency's hazardous waste streams in accordance with regulatory requirements.

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Tradebe Treatment and Recycling, LLC

PCB Certification

The Environmental Protection Agency published its "anti-dilution" provision 40 CFR 761.1(b), which effects the disposal of Polychlorinated Biphenyl (PCBs). The provision states: "No provision specifying a PCB concentration may be avoided as a result of any dilution, unless otherwise specifically provided". Thus, in general, materials are required to be disposed of according to their original concentration.

Any waste stream that is detected with a PCB concentration will be managed as off spec. All containers of the waste stream will be managed as TSCA waste unless otherwise certified by

If there are other waste received that could be associated as TSCA waste, please alert Tradebe's Customer Service Personnel.

Generator Name: MBTA Phone:617-429-4119 Address: 275 Dorchester Avenue City: South Boston State: MA Waste Stream Number:

(Please have a Company Representative who performs "waste determination" from where the waste was generated certify the following.)

I, Christine Lentini , am an authorized representative of the above named (Print Name)

Generator. For the waste stream mentioned above I do hereby certify the following:

The waste contains no PCB's. This has been verified by:

Manufacturer's labeling Analytical (If verified by analytical please attach)

Contains intact NON-leaking TSCA Exempt ballasts

The resulting PCB concentration (<50ppm) is not a result of dilution, or leaks and spills of PCBs in concentrations equal to or greater than 50ppm. Therefore the waste should not be managed as a TSCA waste. (Analytical must be provided to show current PCB levels)

The containers of waste were generated from multiple sources, therefore only containers that contain

PCBs greater or equal to 50ppm are TSCA regulated. (Due to Tradebe's Policy containers that contain PCB's in a concentration of >30ppm (>25ppm at Norlite) will be rejected to an alternate facility).

The containers of waste were generated from a single source. Therefore all of the containers generated from the same source (i.e. tank clean out) will be managed as TSCA waste regardless of the PCB value.

The TSCA containers will be rejected back to the generator or to an alternate facility.

X If the above choices do not describe your waste please use this space: Floor wash water regulated under TSCA 40 CFR 761 as PCB Remediation Waste.

This document certifies that the above listed material(s) have been properly packaged in accordance to Tradebe Treatment and Recycling, LLC (Tradebe) policies and procedures. We further certify that the material(s) is/are stable for handling and transportation under normal conditions. As indicated by my signature below, the above listed company indemnifies Tradebe Treatment and Recycling, LLC and any disposal outlets used by Tradebe of any and all liability associated with the transportation, handling, and disposal of the materials listed above.

Name (Print ): Christine Lentini Title: Manager of Hazardous Materials

Authorized Signature: Date: 7/11/2024 rev. 6/15/2017

The Environmental Protection Agency published its "anti-dilution" provision 40 CFR 761.1(b), which effects the disposal of Polychlorinated Biphenyl (PCBs). The provision states: "No provision specifying a PCB concentration may be avoided as a result o...

File details come from the government source that posted it. Updated .