I am tracking demolition waste from several structures that were removed to make room for my current LEED project. These structures contain several reports stating materials such as lead, PCBs, and asbestos. Most gov websites claim that PCBs are not considered a hazardous material if it is below a certain concentration. The owner of the facilities specifically denied that PCB testing occur during the demolition survey. Therefore much of the demolition waste was treated as hazardous materials (40% or roughly 4000 tons of demo waste) and was not able to be recycled with the rest of the structure.
Am I in the right to classify this ~4000 tons as hazardous material and not track it with the rest of my Construction Waste Management materials?