The Resource Conservation and Recovery Act (RCRA) governs the transportation and disposal of materials excavated from environmental cleanups in the United States, including PPG’s chromium sites. The 1976 legislation gives the U.S. Environmental Protection Agency (USEPA) the authority to control hazardous waste from its point of origin to the point of final disposal, otherwise known as “cradle to grave.”

Before an environmental excavation begins, samples of the materials to be excavated are submitted to state certified laboratories so that the materials can be classified to determine how they will be transported and disposed. Materials classified as “hazardous,” as defined in the Code of Federal Regulations (CFR), Title 40, Part 261, are required to be placed in licensed facilities specifically designed to receive such waste. Materials not meeting this definition can be classified as “non-hazardous” and can be placed in municipal or other landfills, which are also subject to strict federal and state requirements.

Transportation of the materials, regardless of classification and point of disposal, must comply with U.S. Department of Transportation Hazardous Materials regulations as detailed in 49 CFR. Trucks and railroads, the two primary transporters, are required to participate in USEPA’s hazardous waste manifest system, which tracks hazardous waste from the time it leaves the point of origin until it reaches off-site waste management facilities. “Generators” of hazardous waste, such as PPG, are responsible for tracking their material through the manifest system. This means PPG must sign the manifest for each load of hazardous waste before it leaves one of the PPG sites, including a description of the material and its weight. When the transportation company and the ultimate disposal facility take possession of the waste material they must each sign the same document that was signed by PPG as the generator. The manifest is then returned to PPG for safekeeping, which completes the “cradle to grave” cycle.

Approximately 80 percent of the more than 1 million tons of soil and debris excavated at the Garfield Avenue Group sites since June 30, 2010, have been classified as hazardous and placed at licensed facilities in New Jersey, Michigan, Ohio, Pennsylvania and Canada. A combination of trucks and trains transport PPG’s hazardous materials. Non-hazardous materials from PPG sites are transported by trucks and placed at licensed facilities in New Jersey, Michigan and Pennsylvania.