OOOR94101
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     	 PCB Q & A MANUAL 	
An EPA TSCA assistance document designed to provide  the regulated
    community with Agency interpretations to  frequently posed
                           questions.*
                           Prepared by:

                         OPERATIONS BRANCH
                   CHEMICAL MANAGEMENT DIVISION
            OFFICE OF POLLUTION PREVENTION AND  TOXICS
                           1994 EDITION
* This publication is an informal document,  and  persons are
directed to the PCB final rules at Title 40  of the  Code of
Federal Regulations part 761  (40 CFR part  761) except where
otherwise noted for specific  legal requirements.  This document
provides information on the regulatory requirements for
polychlorinated biphenyls that have been reflected  in.final
regulations published through December 31, 1990.  Any past
versions of this document either final or  in draft  form are now
obsolete.
                    U S. Environmental Protection Agency
                    Region 5, Library (PL-12J)
                    77 West Jackson Boulevarjj, 12tn Floor
                    Chicago, IL  60604-3590

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                           --FOREWORD--

The PCB Q & A Manual has been prepared to assist the user in
answering frequently asked questions on the PCB regulations.  It
is a quick source of information that will be updated as new
rules and policies become final.  The looseleaf style and
pagination within chapters will facilitate updating as needed.
Each time a new chapter is added, a new table of contents and a
new alphabetical list of chapters will also be generated.  All
persons to whom EPA has sent the PCB Q & A Manual will
automatically receive updates with instructions to add and/or
replace pages already in the binder.  Please complete the
following Update Request Form and mail this entire page to:
Environmental Assistance Division (7408),  Environmental
Protection Agency, 401 M St. S.W., Washington, DC 20460, or call
the TSCA Assistance Information Service at 202-554-1404 to
receive the PCB Q & A Manual Updates and Revisions.
                       -  PCB Q &  A MANUAL  -
                       Update Request Form

FACILITY:	
STREET ADDRESS:	
CITY:	STATE :	ZIP:
ATTENTION:	

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                        TABLE OF CONTENTS

Introduction	i
History of the PCB Regulations	iii
PCBs in the Workplace	ix
Regional PCB Branch Offices	xiv
CHAPTER i

     I.
Transformers

A.  NonRailroad
B.  Railroad
    II.  Capacitors
   III.

    IV.

     V.

    VI.

   VII.

  VIII.


    IX.

     X.

    XI.

   XII.

  XIII.

   XIV.

    XV.

   XVI.

  XVII.

 XVIII.

   XIX.
         A.
         B.
    Large
    Small
Heat Transfer and Hydraulic Systems

Natural Gas Pipelines

Electromagnets, Switches, and Voltage Regulators

Circuit Breakers, Reclosers, and Cable

Research and Development

Microscopic Mounting Medium, Immersion Oils, Optical
Liquids

Carbonless Copy Paper

Excluded PCB Products

Recycled PCBs and Excluded Manufacturing Processes

PCB Storage Requirements

PCB Disposal Requirements

PCB Spill Cleanup Policy

Recordkeeping and Reporting

PCB Testing Procedures

Import and Export

PCB Transformer Fire Related Requirements

PCB Notification and Manifesting Rule
     Appendix I - Code of Federal Regulations
     Appendix II - Commercially Permitted PCB Disposal Companies

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                  ALPHABETICAL LIST OF CHAPTERS

 *
CHAPTER:

     Appendices

    II.  Capacitors

     A. Large
     B. Small

    IX.  Carbonless Copy Paper

    VI.  Circuit Breakers, Reclosers,  and Cable

     V.  Electromagnets, Switches, and Voltage Regulators

     X.  Excluded PCB Products

   III.  Heat Transfer and Hydraulic Systems

  XVII.  Import and Export

  VIII.  Microscopic Mounting Medium,  Immersion Oils,  Optical
         Liquids

    IV.  Natural Gas Pipelines

  XIII.  PCB Disposal Requirements

   XIX.  PCB Notification and Manifesting Rule

   XIV.  PCB Spill Cleanup Policy

   XII.  PCB Storage Requirements

   XVI.  PCB Testing Procedures

 XVIII.  PCB Transformer Fire Related  Requirements

    XV.   Recordkeeping and Reporting

    XI.   Recycled PCBs and Excluded Manufacturing Processes

   VII.   Research and Development

     I.   Transformers

         A.   NonRailroad
         B.   Railroad

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                         -  INTRODUCTION -
The term PCB is an acronym for polychlorinated biphenyl.  PCBs
are produced by attaching one or more chlorine atoms to a
biphenyl molecule.  As one of the most stable organic compounds
known, their properties made them useful as dielectric fluid in
various types of electrical equipment and heat transfer systems.

Monsanto Corporation was the principal manufacturer of PCBs for
use as a fire-resistant or nonflammable insulating fluid in
electrical and heat transfer equipment.  In 1977, Monsanto
voluntarily ceased production of PCBs because of widespread
environmental concerns about the chemical.

PCBs were sold under the trade name "Aroclor."  However,
companies that used PCBs in the manufacture of transformers and
capacitors, and for other uses, often used other trade names.
Common trade names for PCBs include the following:
COMMON TRADE NAMES

Aroclor        Chlorinol      Fenclor        Nonflammable Liquid
Arochlor B     Chlorphen      Hyvol          Phenoclor
ALC            Clophen        Inclor         Pydraul
Apirolio       Clorinol       Inerteen       Pyralene
Asbestol       Diaclor        Keneclor       Pyranol
ASK            DK             Kenneclor      Pyroclor
Askarel*       Dykanol        Magvar         Saf-T-Kuhl
Adkarel        EEC-18         MCS 1489       Santotherm
Capacitor 21   Elemex         No-Flamol      Santovac 1 and 2
Chlorextol     Eucarel        Nepolin

*Askarel is also the generic term used for nonflammable
insulating liquid in transformers and capacitors.

"Askarel" PCBs are chemical mixtures containing many different
PCB congeners.  They have a heavy, liquid, oil-like consistency,
and weigh 10 to 15 pounds per gallon.  They are very stable,
exhibit low water solubility, low vapor pressure, low
flammability, high heat capacity, low electrical conductivity,
and have a favorable dielectric constant for use in electrical
equipment.

When PCBs were manufactured as dielectric fluid for transformers,
they were often mixed with certain organic solvents such as
chlorinated benzenes.  Therefore, the dielectric fluids present
in the electrical transformers containing PCBs are usually not
pure PCB.  The presence of these other chemicals influences the
physical/chemical properties of the Askarel fluid.

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PCBs are also produced as byproducts and process impurities in
certain chemical manufacturing processes.   They may vary from a
single isomer to a variety of congeners and display different
physical and chemical properties, depending on the number of
isomers and the degree of chlorination (the number of chlorine
atoms attached to the biphenyl molecule).   PCBs with fewer
chlorine atoms are, in general, less persistent, more water
soluble, and more flammable than PCBs with more chlorine atoms.
HEALTH EFFECTS

PCBs are toxic and persistent.   Available laboratory animal
studies indicate an oncogenic potential whose degree varies with
exposure.  Epidemiological data are not now adequate to confirm
or negate oncogenic potential in humans.  Further epidemiological
research is needed to correlate human and animal data.  However,
EPA finds no evidence to suggest that the animal data would not
predict an oncogenic potential in humans.

PCBs can enter the body through the lungs, gastrointestinal
tract,  and skin.  They circulate throughout the body and are
Stored in the body's fatty tissue.  EPA finds that PCB exposure
may cause negative reproductive effects and developmental
toxicity in humans.  Available data show that some PCBs have the
ability to alter reproductive processes in mammals,  sometimes
even at doses that do not cause other signs of toxicity.  Animal
data and limited available data on humans suggest that prenatal
exposure to PCBs can result in various degrees of developmental
effects.  Postnatal effects have been demonstrated on immature
animals, following exposure to PCBs prenatally and via breast
milk.

In some cases, chloracne may occur in humans exposed to PCBs.
Severe cases of chloracne are painful and disfiguring, and may be
persistent.  Although the effects of chloracne are reversible,
EPA considers these effects to be significant.  For more
information on the health effects of PCBs, The Response to
Comments on the Health Effects of PCBs submitted by the Chemical
Manufacturers Association and the Edison Electric Institute is
available from the TSCA Assistance Information Service at 202-
554-1404.

In addition to the toxic effects related to exposure to PCBs
alone,  EPA is very concerned about the toxicity of the chemicals
produced when PCBs are involved in fire-related incidents.  These
chemicals include polychlorinated dibenzofurans (PCDFs) and
polychlorinated dibenzo-p-dioxins (PCDDs), both of which are
believed to be much more toxic than PCBs themselves.  Toxico-
logical effects of these chemicals include embryotoxicity,
teratogenicity, reproductive effects, and oncogenicity.  Other
compounds of toxicological significance may also be produced and

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released from fires  involving PCB equipment.  For further
information on ttte health effects of dioxins, The Ambient Water
Quality Criteria For 2.3,7,8-Tetrachlorodibenzo-p-dioxin is
available from the TSCA Assistance Information Service at 202-
554-1404.
ENVIRONMENTAL EFFECTS

Certain PCB congeners are among the most stable chemicals known
and decompose very slowly once they are released into the
environment.  They remain in the environment and are taken up and
stored in the fatty tissue of organisms.  EPA has concluded that
PCBs can be concentrated in freshwater and marine organisms.
Available data show that PCBs affect the productivity of
phytoplankton and the composition of phytoplankton communities.
PCBs also cause deleterious effects on environmentally important
freshwater invertebrates and impair reproductive success in birds
and mammals.

PCBs are toxic to fish at very low exposure levels and can
adversely affect their survival rate and reproductive success.
The literature shows that various sublethal physiological effects
on bone development and reproductive organs are attributed to
exposure to PCBs.  Phytoplankton are the primary food source
directly or indirectly of all sea organisms.  Also, phytoplankton
are a major source of oxygen in the atmosphere.  The transfer of
PCBs up the food chain from phytoplankton to invertebrates, fish,
and mammals can result in human exposure through consumption of
PCB-containing food sources.
                -  HISTORY OF THE PCB REGULATIONS  -
In recognition of the risks associated with PCBs and their
widespread distribution throughout the environment, in 1976, the
United States Congress enacted the Toxic Substances Control Act
(TSCA),  which banned with limited exceptions the manufacture,
processing, distribution in commerce, and use of PCBs other than
in a "totally enclosed manner".  Section 6(e)  of TSCA also
required EPA to promulgate regulations for the proper disposal of
PCBs and develop clear and adequate warnings and instructions
with respect to their processing, distribution in commerce, use
and disposal.  Section 16 of TSCA provides for penalties up to
$25,000 a day per violation of section 6(e)  of the Agency's PCB
regulations.

PCB marking and disposal regulations were published in the
Federal Register on February 17,  1978 (43 FR 7150).  The PCB "Ban
Rule" (Federal Register May 31, 1979) included provisions banning

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the manufacture, processing, distribution in commerce, and use of
PCBs which became effective on July 2, 1979 (44 FR 31514).

The May 31, 1979 Rule:

     •    Designated all intact, nonleaking capacitors,
          electromagnets and transformers, other than railroad
          transformers, as "totally enclosed," which allowed
          their use without restrictions or conditions;

     •    Established a 50 ppm PCB regulatory cutoff for
          manufacturing, processing, distribution in commerce,
          and use; and

     •    Authorized the use of PCBs under specific conditions
          and time constraints for 11 activities.  These
          activities were:

          •    Servicing transformers (other than railroad
               transformers),
               Use in and servicing of railroad transformers,
               Use in and servicing of mining equipment,
               Use in heat transfer systems,
               Use in hydraulic systems,
               Use in carbonless copy paper,
               Use in pigments,
               Use in and servicing of electromagnets,
               Use in natural gas pipelines,
               Use in small quantities for research and
               development, and
          •    Use as a mounting medium in microscopy.

The Environmental Defense Fund  (EDF) challenged several
provisions of the May 1979 rule, and in October of 1980, the U.S.
Court of Appeals for the District of Columbia ruled that there
was insufficient evidence in the record to support several
provisions of the May 1979 rule.  Specifically, the Court struck
down the classification of transformers, capacitors, and
electromagnets as "totally enclosed," and the regulatory cutoff
at 50 ppm for the manufacture, processing, distribution in
commerce, and use of PCBs.  The 11 use authorizations contained
in the May 1979 rule remained in effect.  EPA, EDF, and certain
industry representatives filed a joint motion seeking a stay of
the Court's mandate until further rulemaking could be completed.
The Court granted the stay.

On August 25, 1982, EPA issued a final rule governing the use and
servicing of electrical equipment containing PCBs  (47 FR 37342).
This final rule was issued as a result of the Court's decision to
strike down the May 1979 rule's classification of transformers,
capacitors, and electromagnets as "totally enclosed."  In the
August 25, 1982 rule, EPA authorized the use of electrical

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equipment containing PCBs with certain conditions and
restrictions intended to minimize human and environmental
exposures to PCBs.

On October 21, 1982, EPA issued part one of a two-part rule to
address the 50 ppm regulatory cutoff (47 FR 46980) .   This final
rule addressed closed and controlled waste manufacturing
processes.  EPA submitted a plan to the Court on November 1,
1982, that requested a further extension of the- stay of mandate
for the 50 ppm cutoff and presented plans for the completion of
the rulemaking on this issue.  (The October 21, 1982 rule was
superseded later by the "Uncontrolled PCB's Rule" issued on July
10, 1984.)

In addition to issuing rules as a result of the Court decision in
October 1980, EPA also promulgated an amendment to the Use
Authorization for Railroad Transformers which originally appeared
in the May 1979 rule.  On January 3, 1983, EPA published a final
rule amending and extending the use authorization for PCB
railroad transformers (48 FR 124).

On March 30, 1983, EPA promulgated a procedural change in the
approval process for mobile and non-unique disposal facilities
(48 FR 13181).  The authority for granting or denying approval of
these facilities was transferred from the regions to EPA
headquarters.

On July 10, 1984, several rulings were made final.  One rule
addressed individual and class petitions for exemption from the
prohibition against the manufacture, processing, and distribution
in commerce of PCBs  (49 FR 28154).   The use of small quantities
of PCBs for use in research and development was authorized
indefinitely.

On July 10, 1984, EPA also issued an amendment to the October 21,
1982 rule  (49 FR 28172).  This "Uncontrolled PCB's Rule"
completed part two of EPA's earlier 1982 rulemaking regulatory
cutoff for PCBs,  which was overturned in the 1980 Court decision.
This rule excluded additional processes from regulation based
upon EPA's determination that these processes do not present an
unreasonable risk of injury to human health or to the
environment.  Among other things, the rule permitted the
manufacturing,  processing,  distribution in commerce, and use of
inadvertently generated PCBs and recycled PCBs under limited
circumstances.   This amendment replaced the terms "Closed
Manufacturing Process" and "Controlled Waste Manufacturing
Process" with "Excluded Manufacturing Process."  PCBs with
concentrations below 50 ppm,  under certain conditions and
restrictions, were authorized for use in hydraulic and heat
transfer fluid and in the compressors and liquid of  natural gas
pipeline systems.

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On November 8, 1984, a final rule was issued that revised the
definition of "Totally Enclosed Manner" (49 FR 44634).   It
changed from "any manner that will ensure that any exposure of
human beings or the environment to any concentration of PCBs will
be insignificant, that is, not measurable or detectable by any
scientifically acceptable method" to "any manner that will ensure
no exposure of human beings or the environment to any
concentration of PCBs."

The "PCB Transformer Fires Rule" was published on July 17, 1985
(50 FR 29170).  This final rule amended portions of the August
25, 1982 electrical equipment rule by placing additional
restrictions and conditions on the use of PCB Transformers
(electrical transformers containing 500 ppm or greater PCBs).
This rule prohibited the use of higher secondary voltage  (480
volts and above) network PCB Transformers in or near commercial
buildings after October 1, 1990.  By October 1, 1990,  it required
the installation of enhanced electrical protection on lower
secondary voltage network PCB Transformers and radial PCB
Transformers in use in or near commercial buildings.  It
prohibited further installation of PCB Transformers in or near
commercial buildings after October 1, 1985 and required the
registration by December 1, 1985 of all PCB Transformers with
fire response personnel and building owners.  Further,  the ruling
required, by December 1, 1985, the marking of the exterior of all
PCB Transformer locations and the removal of all stored
combustibles located near PCB Transformers.

This rule also required owners of PCB Transformers involved in
fire-related incidents to immediately notify the National
Response Center and to take measures as soon as possible to
contain any potential releases of PCBs or incomplete combustion
products to water.

A clarification of the July 17, 1985 rule was published on
December 31, 1986  (51 FR 47241).  It addressed the following
areas of the regulation:

          the PCB Transformer registration requirement,
          the requirement for the removal of stored combustibles,
          the requirement to notify the National Response Center
          of fire-related incidents,
          the definition of commercial building,
          the status of mineral oil transformers found to have
          over 500 ppm PCBs,
          the ban on the installation of PCB Transformers in or
          near commercial buildings,
          the requirement for labelling of exterior access to PCB
          Transformer locations.
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The PCB Spill Cleanup Policy was published on April 2, 1987  (52
FR 10688) .   The Policy establishes methods of cleanup and cleanup
levels of spills containing PCBs at concentrations of 50 ppm or
greater.  EPA uses the Policy standards to determine the adequacy
of cleanup for penalty purposes.  It specifies cleanup of PCBs to
different levels depending on the spill location, the potential
for exposure to residual PCBs remaining after the cleanup, the
concentration of the PCBs initially spilled and the nature and
size of the population potentially at risk of exposure.  The
Policy imposes the most stringent requirements on areas where
there is the greatest potential for human exposure to spilled
PCBs; less stringent requirements where the type and degree of
contact present lower potential exposure; and even less stringent
requirements where there is little potential for any direct human
exposure.

While the Policy applies to the majority of spill situations, it
does provide for exceptional situations that may require
additional cleanup or less stringent standards at the discretion
of the EPA regional office.

On June 27, 1988, EPA published final amendments to the
"Uncontrolled PCBs Rule" (Federal Register July 10, 1984) which
excluded additional materials containing less than 50 ppm PCBs
from regulation  (53 FR 24206).   The amendments did the following:
1) eliminated the requirement that maintenance workers wear
VitonR elastomer gloves  when servicing heat  transfer and
hydraulic systems; 2) allowed the use of and distribution in
commerce of certain equipment and materials that have been
adequately decontaminated in accordance with the applicable PCB
spill cleanup policies in effect at the time of the cleanup;
3) maintained the 3 parts per billion  (ppb)  water discharge limit
from paper processing mills or allowed an equivalent mass-based
limitation for water discharges to be met; 4) prohibited the
burning for fuel of oil containing 2 to 49 ppm PCBs in
nonindustrial boilers and furnaces; and 5) excluded from the ban
on processing, distribution in commerce, and use certain products
containing less than 50 ppm PCBs.  Remaining prohibitions on PCBs
less than 50 ppm are as a dust control agent, sealant, coating,
inert ingredient in pesticides or herbicides, road oiling agent,
use as a rust preventative, and use as a fuel in nonindustrial
boilers and furnaces.  Readers should consult with their State
Department of Environmental Quality or equivalent to determine if
there are any additional regulations the State may have for PCBs
less than 50 ppm.  A document titled "Summary of State PCB
Management Programs" is available through the TSCA Assistance
Information Service  (202-554-1404).

On July 19, 1988, EPA published amendments (53 FR 27322) to the
"PCB Transformer Fires Rule" (Federal Register July 17, 1985).
The amendments include:   1) modifying the enhanced electrical
protection provision for nonsidewalk lower secondary voltage

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network PCS Transformers; 2) prohibiting the use, as of October
1, 1993, of all lower secondary voltage network PCB Transformers
located in sidewalk vaults; 3) allowing the installation of PCB
Transformers in or near a commercial building only for
reclassification or emergency purposes; 4)  allowing the use under
certain limited conditions of an alternate label (other than ML)
on the exterior of PCB Transformer locations; and 5)  setting up a
schedule of compliance for mineral oil transformers thought to be
PCB contaminated (i.e., 50-499 ppm) and later determined to be a
PCB Transformer (i.e., a 500 ppm).

The 1985 PCB Transformer Fires Rule regulated the use of
transformers in an attempt to reduce fire-related risks posed by
the use of these transformers.  After publication of the August
21, 1987 proposed amendment to the PCB Transformer Fires Rule, ,
EPA received comments indicating that complete deenergization of
the transformer would not be necessary to prevent transformer
rupture.  The comment stated that deenergization of the faulted
phase  (partial deenergization) would be sufficient to prevent
transformer rupture.  After further review, EPA determined that
partial deenergization may be acceptable electrical protection
for low voltage radial PCB transformers under some circumstances.

By final rule dated November 26,  1990  (55 FR 49043) EPA amended
the regulations concerning enhanced electrical protection
requirements for low voltage radial transformers containing PCBs
and extended the deadline for compliance for these types of
transformers to February 25, 1991.   This rule did not alter any
other enhanced electrical protection requirements.   It provided
that partial deenergization, i.e.,  deenergizing only the faulted
phase(s) in a low voltage radial transformer, may,  in some
circumstances, be equivalent to total deenergization of such
transformers in the event of a high current fault.   This rule
states that partial deenergization will be equivalent to total
deenergization only if the transformer configuration and
associated safety factors demonstrate that partial deenergization
is consistent with EPA's goals of avoiding fault related
failures,  tank rupture, and fires in PCB Transformers.  Owners
and operators of low voltage radial transformers in or near
commercial buildings who wish to utilize partial deenergization
are required to install this type of electrical protection using
good engineering practices.

There had been increasing concern on the part of Congressional
oversight committees about certain aspects of EPA's disposal
program for polychlorinated biphenyl (PCB)  wastes.   In
particular, the most frequently cited concerns were:   (1) the
lack of an effective tracking system that would track PCB wastes
in a "cradle-to-grave" fashion; and (2) the lack of sufficient
oversight of the activities and qualifications of the PCB waste
brokers and other intermediate storers who may store the PCB
wastes owned by others.

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The PCB Notification and Manifesting rule published on December
21, 1989  (54 FR 52716) adds to the TSCA disposal regulations a
PCB waste tracking system based on the RCRA model for the
tracking of hazardous wastes.  At the heart of the tracking
system are the requirements that PCB waste handlers  (disposers,
commercial storers, transporters, and generators with PCB storage
areas) notify EPA of their PCB waste activities, and use the RCRA
Uniform Manifest in connection with their shipments of regulated
PCB wastes.

Second, this rule adds to the existing PCB storage facility
standards a requirement that certain commercial storers of PCB
wastes obtain written approvals from the EPA Regional
Administrators.  The issuance of these commercial storer
approvals is conditioned on an evaluation of the applicant's
qualifications to engage in the business of PCB waste storage,
and the submission of closure plans and proof of financial
responsibility for proper closure of PCB storage areas.

In addition, the rule includes additional recordkeeping and
reporting requirements that will complete the PCB waste tracking
function, as well as facilitate EPA's enforcement of the PCB
disposal regulations.
On November 2, 1990  (55 FR 46470) EPA proposed a rule which
addresses the method by which permits issued under 40 CFR Part
761 are to be revoked or suspended.  The criteria and procedures
for suspensions and revocations, proposed in the PCB Permit
Revocation Rule, will apply to those approvals required by the
1989 Notification and Manifesting rule, as well as to the
disposal approvals which are currently required by the
regulations.  At the time of publication of this document, the
Permit Revocation rule had not been published in final form.


                    - PCBs IN THE WORKPLACE -


There are Occupational Safety and Health Administration (OSHA)
regulations governing PCBs in the workplace.  OSHA has in place
two 8-hour time-weighted averages  (TWAs) for chlorodiphenyl.  For
chlorodiphenyl containing 42 percent chlorine,  the TWA is 1.0
mg/m3 of workplace air.  For chlorodiphenyl containing 54 percent
chlorine, the TWA is 0.5 mg/m3 of workplace air.  An employee's
exposure to PCBs in any 8-hour workshift of a 40-hour week cannot
exceed these concentrations.  Further, employers are required to
ensure a safe workplace under OSHA regulations.  If specific
standards are not applicable, this general requirement for a safe
workplace would apply.
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The National Institute for Occupational Safety and Health (NIOSH)
recommends a more stringent air standard for worker exposure of
1. 0 /xg/m3 .

EPA's rules do not directly regulate workers, but the rules do
restrict or prohibit certain PCB activities and reduce the amount
of PCBs in the workplace.  Therefore, as a result of EPA's PCB
rules the number of workers exposed to PCBs has been dramatically
reduced.  EPA rules prohibit PCB Transformer rebuilding (except
for railroad transformers) that involves removal of the
transformer's coil.  Prohibitions have terminated activities that
could result in the major long-term occupational exposure to high
concentrations of PCBs.  However, worker exposure can still occur
as a result of PCB spills and authorized servicing operations for
PCB Transformers.
PROTECTIVE CLOTHING

The type of protective clothing that should be worn when working
with PCBs depends on the individual circumstances.  Protective
clothing and equipment for workers is intended to prevent skin
and eye contact and to control respiratory exposure.

In any operation where workers may come into contact with PCBs,
protective clothing impervious to PCBs should be worn.  Gloves,
boots, overshoes, and bib-type aprons that cover boot tops should
be provided, when necessary.

Nonporous gloves and boots and heavy overalls can usually protect
the skin.  For major spill cleanup activities, a full suit of
nonporous clothing may be appropriate.  Also, nonporous aprons
can be effective in reducing contamination of worker clothing.
The following tables rate comparable materials used to protect
against dermal exposure to PCBs.
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               COMPARATIVE TABLES ON MATERIALS USED
            TO PROTECT AGAINST DERMAL EXPOSURE TO PCBs

   *Table 1. Recommendations for Protection Against Aroclor
             1254 Undiluted and Paraffin Oil
Highly Recommended    Recommended            Not Recommended


Viton               Teflon*3'c                Surgical rubber
Viton SF            Polyvinyl alcohol        Polyethylene
Vitrile             Nitrileb
                    Neoprene
                    Saranex*3
                    Butylb
   *Table 2. Recommendations for Protection Against Aroclor
             1254 in Trichlorobenzene:  a 58 percent Arochlor
             1254a
Highly Recommended     Recommended           Not Recommended
Vitrol                Teflon                 Saranex
Viton SF              Nitrile                Butyl
                      Polyvinyl alcohol      Neoprene
                      Vitrile                Polyethylene
                                             Surgical rubber
     a-   "Highly Recommended" materials showed no breakthrough
          in 24 hours.  Breakthrough time was 8 to 24 hours for
          the "Recommended" category.  Breakthrough time was less
          than 8 hours for the "Not Recommended" category.  These
          recommendations assume comparable thickness, thus are
          based on normalized breakthrough times.

     "•   Investigators noticed what appeared to be defects in
          both Butyl and Saranex-laminated tyvek and nitrile; in
          one Teflon thumb, penetration appeared to occur through
          a seam.

     c•   Teflon is not highly recommended because when it is
          flexed, as it would be when worn, permeation sometimes
          takes place due to physical defects which flexing
          produces.

     *From the EPA/OTS TSCA Public Files; Versar, Inc. OPTS 62017
     PCBs Controlled Wastes Communication N 23 File.

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        *BREAKTHROUGH TIMES  FOR VARIOUS  PROTECTIVE GARMENT
                    MATERIALS EXPOSED TO PCBs
TYPE OF MATERIAL            THICKNESS (mils)         TIME (min)
Homogeneous.  nonbonded
Butyl rubber                     22                    2.5
Neoprene rubber latex            23                    0.5
Nitrile rubber latex              8                    1.0
Nitrile rubber milled            12                    0.8
Polyethylene, medium density      2                    0.6
Poly(vinyl alcohol),
  unsupported                    15                    0.3
Surgical rubber latex             8                    #
Teflon, crumpled                  2                    #
Teflon, noncrumpled               2                   60.0
Viton elastomer                  10                    0.3
Coated, bonded**
Butyl-coated nylon***            15                    3
Polyethylene-coated
  Tyvek                           5
  Tyvek toward H20
  Polyethylene toward H2O
Polyethylene-coated nylon         4                    0.5
Poly(vinyl chloride)-coated
  nylon                          10                    0.5
     *   From the EPA/OTS TSCA Public Files; Versar Inc. OPTS
         62017 PCB Controlled Wastes File.  Weeks and McLeod
         1980.

     **  These are also referred to as composite or multilayered
         materials.

     *** Mil C-12189

     #   Testing was not performed.
                               xn

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           EYE PROTECTION/RESPIRATORY EXPOSURE CONTROL

     Eye protection (chemical safety goggles, face shields with
     goggles or safety glasses with side shields)  should be worn
     during any operation in which PCBs are present.  If liquid
     or solid PCBs contact the eyes, they should be irrigated
     immediately with large quantities of water and then a
     physician or other responsible medical personnel should
     examine them.

     Respiratory exposure control (whether individual protection
     or workplace control) is most relevant for long-term
     production operations or major spills, when concentrations
     of airborne PCBs may exceed the recommended occupational
     exposure limit.  PCB Transformer spills can pose respiratory
     problems when solvents, such as trichlorobenzene, are mixed
     with PCBs.  Small spills, such as capacitor failures, seldom
     pose respiratory problems, but protection should be provided
     for incidents in confined areas.  The following chart
     outlines the National Institute for Occupational Safety and
     Health (NIOSH)  recommendations for respiratory protection
     from PCBs.  EPA also recommends the use of dust masks
     (surgical type) for use during soil cleanup.

                   *Respirator Selection Guide
Concentration of PCBs
Respiratory Type Approved
Under Provisions of 30 CFR 11
Greater than 1.0 cubic m
or Emergency (entry into
areas of unknown
concentration)
 (1)  Self-contained breathing
     apparatus with full
     facepiece operated in
     pressure-demand or
     other positive
     pressure mode.

(2)  Combination Type C
     supplied air respirator
     with full facepiece
     operated in pressure-
     demand or other positive
     pressure mode and an
     auxiliary self-contained
     breathing apparatus
     operated in pressure demand
     or other positive pressure
     mode.
     *Source:  NIOSH Recommendation USDHEW 1977
                              Xlll

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                   REGIONAL PCB BRANCH OFFICES
USEPA Region I   (ME, NH, VT, MA, RI, CT)

Pesticides and Toxic
Substances Branch  (ATC)
John F. Kennedy  Federal Bldg.
Boston, MA  02203
(617-565-3257)
USEPA Region II   (NY, NJ, PR, VI)

Pesticides and Toxic
Substances Branch  (MS-105)
2890 Woodbridge Ave.
Edison, NJ  08837
(908-906-6817)
USEPA Region III   (PA, DE, MD, VA, WV, DC)

Toxics and Pesticides Branch
841 Chestnut Bldg.
Philadelphia, PA   19107
(215-597-7668)
USEPA Region IV   (KY, TN, NC, SC, GA, AL, MS, FL)

Pesticides and Toxic
Substances Branch
345 Courtland St. N.E.
Atlanta, GA  30365
(404-347-1033)
USEPA Region V   (OH, IN, IL, MN, WI, MI)

Pesticides and Toxic
Substances Branch  (SP-14J)
77 West Jackson Blvd.
Chicago, IL  60604
(312-886-7061)
                               xiv

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USEPA Region VI   (AR,  LA,  OK,  TX,  MM)

Pesticides  and Toxic
Substances  Branch  (6T-PT)
1445 Ross Avenue
Suite 1200
Dallas, TX  75202-2733
(214-655-7290)
USEPA Region VII   (IA,  KS,  MO,  NE)

Toxics and Pesticides Branch  (TOPE)
726 Minnesota Avenue
Kansas City, KS   66101
(913-551-7394)
USEPA Region VIII   (ND,  SD, MT, WY,  UT,  CO)

Pesticides and Toxic
Substances Branch
One Denver Place
Suite 500
999 18th Street
Denver, CO  80202-2466
(303-293-1686)
USEPA Region IX   (CA, NV, AZ, HI, Guam)

Pesticides and Toxic
Substances Branch  (A-4-4)
75 Hawthorne St.
San Francisco, CA  94105
(415-744-1094)
USEPA Region X   (WA, OR, ID, AK)

Pesticides and Toxic
Substances Branch  (AT-083)
1200 6th Avenue
Seattle, WA  98101
(206-553-7369)
                                xv

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                             CHAPTER I
                              PART A
                           TRANSFORMERS
                           (NONRAILROAD)
Manufacturing  (page  1-3)

Processing  (page  1-4)

Distribution in Commerce  (Sale  of  Transformers)  (page 1-4)

Exemptions  to Manufacture,  Process,  and Distribute
  PCBs in Commerce  (page  1-6)

Marking/Labeling  (page  1-6)

Phaseout Requirements  (page 1-7)

Use Conditions  (page I-10)

      (1)  PCB Transformer Emergency  Installations  (page 1-10)
      (2)  PCB Transformer Reclassification Installations
          (page I-11)
      (3)  Electrical Protection Requirements  (page 1-12)
      (4)  Registration  Requirements  (page  1-13)
      (5)  Combustible Materials (page  1-15)
      (6)  Inspections  (page 1-16)
      (7)  Leaking PCB Transformers (page 1-17)
      (8)  Fire-Related  Incidents  (page  1-17)
      (9)  Discovery  of  a  Mineral Oil PCB Transformer (page  I-18)

Servicing and Reclassification  Conditions  (page  1-20)

Storage for Reuse  (page 1-22)

Storage for Disposal (page  1-22)

Disposal (page 1-23)

Recordkeeping (page  1-25)

Spills (page 1-26)

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PART A

                         -  TRANSFORMERS -
     Transformers are used to raise and lower voltage.  As
     voltage is transmitted from a generating facility through
     transmission and distribution systems, it may be raised or
     lowered a number of times depending on the technical
     configuration of the system and the varying voltage
     requirements of the customer.

     A large transformer may be several times the size of an
     automobile and contain hundreds or even thousands of gallons
     of oil or other dielectric fluid.  Such transformers are
     typically located in generating facilities or substations.
     However, the vast majority of transformers are considerably
     smaller.

     Between the extremely large transformers used to transmit
     power and the extremely small overhead transformers used to
     bring power into homes, there are numerous transformers of
     assorted size and voltage ratings used to adjust voltage to
     the requirements of all types of commercial and industrial
     customers.  Prior to EPA's regulations of PCBs, when these
     transformers were located indoors, fire codes often
     encouraged the use of PCBs as an insulating fluid.

     Today, for purposes of regulation, EPA classifies
     transformers into three basic categories - "PCB," "PCB-
     Contaminated," and "Non-PCB."  A "PCB Transformer" is one
     which contains 500 parts per million  (ppm) or greater PCBs.
     A "PCB-Contaminated Transformer" is one which contains 50-
     499 ppm PCBs.  And finally, a "Non-PCB Transformer" contains
     less than 50 ppm PCBs.

     EPA also categorizes transformers by their type, location,
     and secondary voltage.  As these various categories of
     transformers are regulated to different degrees, it is
     important to know the type of transformer in question.

Ql:  Do transformers have to be tested to determine their PCB
     concentration?  If not, how can I determine the equipment's
     classification?

Al:  The regulations do not require that these types of equipment
     be tested to determine the PCB concentration in their fluid.
     However, in the absence of a test, certain assumptions must
     be made about the equipment.   For example, if the nameplate
     indicates that the equipment contains PCB dielectric fluid
     (see table of trade names on p.i), or, if there is any
     reason to believe that the equipment at one time contained
     PCB dielectric fluid,  or,  if there is no nameplate on the

                               1-1

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     equipment or other information to indicate the type of
     dielectric fluid, then the equipment must be assumed to be a
     PCB Transformer  (500 ppm or greater).   Transformers which
     are known to contain mineral oil dielectric fluid and whose
     PCB concentration is unknown, must be assumed to be PCB-
     Contaminated Electrical Equipment (50-499 ppm) and must be
     treated as such.  However, if the PCB concentration has ever
     been known or if a person has reason to know the
     concentration equalled or exceeded 500 ppm PCBs, the
     transformer must be treated as a PCB Transformer.  These
     "assumption rules" effectively apply to all regulatory
     requirements relating to the equipment including:  use and
     servicing, leaks and spills, sale for reuse, storage for
     disposal, and disposal.

Q2:  Can screening tests, such as Clor-n-Oil™, be used to
     determine the PCB concentration of a transformer?  If so,
     can "Certified Non-PCB" labels be used to classify
     transformers based upon a screen test?

A2:  Currently, the regulations do not require that any
     particular testing method be utilized when determining the
     PCB concentration in transformers.  However, because EPA
     does not recognize the results of such field concentration
     screening tests for purposes of classifying transformers,
     transformer owners should prudently scrutinize PCB testing
     options, as there are significant differences in the
     integrity and accuracy of various testing methods.  It
     should be noted that, in most situations, EPA will utilize
     laboratory gas-chromatography (GC) testing to determine PCB
     concentrations during facility inspections.  EPA recommends
     that owners of electrical equipment choose testing methods,
     and practice sampling procedures, which are analytically
     accurate, reproducible, assure quality control, and are
     certifiable.

     The use of non-PCB labels is unregulated by EPA.  That is to
     say, there are no prohibitions or requirements to place non-
     PCB labels on transformers.  However,  if non-PCB labels are
     used to indicate the classification of equipment, then
     owners should be able to provide documentation such as test
     results or manufacturer's letters along with historic
     service records which will substantiate the non-PCB
     classification.  A criminal action could be pursued for
     someone intentionally using non-PCB labels on known or
     assumed PCB Items.

Q3:  Can I batch test oil samples from several transformers and
     classify each unit based upon one test result?

A3:  The only place in the regulations where "batch testing" is
     allowed is under testing procedures for disposal of PCBs
     [761.60(g) ].  It is only owners or users of mineral oil

                               1-2

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     dielectric fluid electrical equipment who may take advantage
     of the batch testing provision.  However, batch testing to
     classify equipment for continued use of PCBs is also
     allowable provided that known or assumed dilution does not
     take place. That is, mineral oil that is assumed or known to
     contain 50 ppm or greater PCBs must not be mixed with
     mineral oil that is known or assumed to contain less than 50
     ppm PCBs to reduce the concentration of PCBs in the batch.
     While there is no requirement to individually test mineral
     oil transformers, if test results of the drained carcass(es)
     show a concentration of greater than 500 ppm PCBs,
     that/those transformer(s) tested as a batch must be treated
     as a PCB  (>500 ppm) and the batch tested oil must be treated
     as containing greater than 500 ppm PCBs for purposes of
     disposal.

Q4:  Many pole-mounted distribution transformers have no
     information on their nameplate indicating that they do, in
     fact, contain mineral oil dielectric fluid.  Without this
     nameplate information, am I required to assume that these
     units are "PCB" classification (500 ppm or greater)?

A4:  The regulations allow "oil-filled" electrical equipment
     whose PCB concentration is unknown to be assumed less than
     500 ppm (PCB-Contaminated, 50-499 ppm).   EPA has received
     numerous comments from the electric utility industry and
     others indicating that significant numbers of pole-mounted
     utility distribution transformers have no nameplate
     information stating the type of "oil" in the unit.  In the
     absence of this direct indication, the owner may still make
     the assumption of "PCB-Contaminated" if the purchase record,
     or manufacturer's literature or other specific
     documentation, identifies the transformer as oil-filled, or
     if manufacturer's nameplate codes correlate with oil-filled
     status.  However, in the absence of direct nameplate
     information or secondary documentation,  any such transformer
     must be considered as "PCB" unless tested and proved
     otherwise.
     MANUFACTURING

     The manufacture of PCBs, regardless of concentration, for
     any use including transformers is prohibited without an EPA
     exemption  [TSCA section 6(e) and 761.20(b)].

Q5:  Most of the transformers our facility purchases today
     indicate "Non-PCB" on the equipment's nameplate.  Does this
     mean that companies can still manufacture transformers with
     15, 20, or even 30 ppm PCBs in the oil?

A5:  No.  The manufacture of transformers containing any PCBs 2
     ppm or greater is prohibited.

                               1-3

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     PROCESSING

     The processing of PCBs, 50 ppm or greater, for use in
     transformers is prohibited without an EPA exemption
     [761.20 (c)].  However, PCBs at concentrations less than 50
     ppm may be processed for use in transformers  (under specific
     conditions) in accordance with the definition of "Excluded
     PCB Products"  [see 761.3 for specific examples].  Also, PCBs
     at any concentration may be processed  (i.e., prepared and/or
     packaged for distribution in commerce) for purposes of
     disposal in accordance with the requirements of 761.60
     [761.20(c) (2)] .

     DISTRIBUTION IN COMMERCE (Sale of Transformers)

     The distribution in commerce of PCBs, 50 ppm or greater, for
     use in transformers is prohibited without an EPA exemption
     [761.20(c)].  However, PCBs at concentrations less than 50
     ppm may be distributed in commerce' for use in transformers
     (under specific conditions) in accordance with the
     definition of  "Excluded PCB Products"  [761.3] .  Also, PCBs
     at any concentration may be distributed in commerce for
     purposes of disposal in accordance with the requirements of
     761.60  [761.20 (c) (2)].  Disposal, in this context,  means the
     termination of the useful life of the PCB or PCB-
     Contaminated Transformer.

     The distribution in commerce (sale)  of transformers which
     contain PCBs in concentrations of 50 ppm or greater  (known
     or assumed) for purposes of reuse is allowed provided:

          •    the transformer was originally sold for use before
               July 1, 1979;

          •    the transformer is intact and nonleaking at the
               time of sale; and

          •    no PCBs are introduced into the transformer.
Q6:  Does this mean that I can sell a PCB or PCB-Contaminated
     Transformer?

A6:  Yes.  If the transformer was originally sold for use before
     July 1, 1979, and is now being sold for reuse   (i.e.,
     continued use).  Also, the transformer must be totally
     enclosed, intact and nonleaking.  EPA recommends that the
     buyer be advised that he is purchasing a PCB or PCB-
     Contaminated Transformer.

Q7:  What does intact and nonleaking mean?
                               1-4

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A7:  Intact and nonleaking means that the transformer is
     structurally sound with all fluid intact and there are no
     PCBs on the external surface of the transformer.

Q8:  Can I sell drained PCB-Contaminated Transformer carcasses
     {known or assumed 50-499 ppm) to a rebuilder for reuse as
     parts in repair and remanufacturing activities?

A8:  No.  Selling drained 50-499 ppm carcasses for reuse is an
     unauthorized distribution in commerce of PCBs and is
     prohibited without an EPA exemption.  On the other hand,
     non-PCB carcasses  (less than 50 ppm) can be sold for reuse
     (under specific conditions) in accordance with the
     definition of  "Excluded PCB Products"  [761.3].

Q9:  Can I sell drained PCB-Contaminated Transformer carcasses
     (known or assumed 50-499 ppm) to a scrap or salvage dealer
     for metals recovery?

A9:  Yes.  The sale of drained 50-499 ppm carcasses for scrapping
     or salvaging is generally considered distribution in
     commerce for purposes of disposal and is allowed with
     certain limitations.  To qualify as disposal, the scrapping
     practice must be one which will "...terminate the useful
     life of PCBs or PCB Items"  [761.3]; or, in other words, will
     destroy any residual PCBs found in the drained carcasses.
     Salvaging aimed at reclamation of the metals found in the
     case and coil generally constitutes disposal, because any
     residual PCBs are destroyed by the high temperatures
     employed in the smelting process.  However, where salvaging
     merely consists of disassembling the drained equipment to
     obtain parts for reuse in other equipment, the useful life
     of the equipment has not been fully terminated and thus is
     not considered disposal.  In sum, the scrapping/salvaging of
     50-499 ppm drained equipment is unregulated to the extent
     that:  (1)  the carcass has been drained of all free-flowing
     liquid, (2)  scrapping practices do not result in leaks,
     spills, or other uncontrolled discharges of PCBs,  and  (3)
     any PCB-contaminated components are not reintroduced into
     commerce.

Q10: Can I export drained PCB-Contaminated Transformers for
     recovery of metal?

A10: No.  PCB-Contaminated Transformers may not be exported for
     recovery of metal since this is considered disposal unless
     they have been reclassified to non-PCB status,  i.e.,  to <50
     ppm.  Section 761.20 (c)  permits distribution in commerce for
     purposes of disposal,  although this exception refers to
     domestic disposal only.   PCB-Contaminated Transformers may
     be reclassified to the non-PCB status and then exported for
     purposes of disposal if the transformer meets the definition
     of "Excluded PCB Products".  (See Chapter X for further

                               1-5

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explanation of this definition.)  The process of
reclassification is discussed below under "Servicing and
Reclassification Conditions."

EXEMPTIONS TO MANUFACTURE. PROCESS. AND DISTRIBUTE PCBs IN
COMMERCE

Exemptions to manufacture, process, and distribute in
commerce PCBs may be granted only by rulemaking on a case-
by-case basis.  The EPA Administrator may set terms and
conditions for an exemption and may grant an exemption for
not more than one year.  EPA interim procedural rules for
processing and distribution in commerce exemptions describe
the required content of processing and distribution in
commerce exemptions petitions and the procedures EPA follows
in rulemaking on exemption petitions.  Those rules were
published in the Federal Register of May 31, 1979  (44 FR
31558) and are codified at 40 CFR 750.30 through 750.41.
MARKING/LABELING

All PCB Transformers must be marked in accordance with EPA
marking and labeling requirements  [761.40].  All
marks/labels must comply with EPA marking formats which
specify size, color, and design  [761.45].

     •    All PCB Transformers  (500 ppm or greater) must be
          marked individually with the mark ML (PCB label)
           [761.40(a)(2) and  (c)(1)].

     •    The marking of PCB-Contaminated Transformers  (50-
          499 ppm)  is not required  [761.40(a)(2)].  If an
          owner chooses to mark a PCB-Contaminated
          Transformer, it is recommended that the PCB mark
          ML not be used.

     •    Transport vehicles loaded with one or more PCB
          Transformers  (500 ppm or greater) must be marked
          on each end and each side with the mark ML (PCB
         • label) [761.40(b)].

     •    All marks/labels must be placed in a position on
          the exterior of the transformer so that the mark
          can be easily seen by persons inspecting the
          transformer  [761.40(h)].
PCB Transformer locations must also be marked/labeled  in
accordance with 761.40(j).

     •    As of December 1, 1985, the vault door, machinery
          room door, fence  (including a chain-linked fence),

                          1-6

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          hallway, or other means of access  (other than
          grates and manhole covers) to a PCB Transformer
          must be marked with the mark ML (PCB label)
           [761.40(j) (1)] .

A mark other than the mark ML may be used to identify a PCB
Transformer in certain circumstances/locations, provided all
of the following conditions are met:

     •    The program using such an alternative mark was
          initiated prior to August 15, 1985, and can be
          substantiated with documentation
           [761.40(j) (2) (i)] .

     •    Prior to August 15, 1985, coordination between the
          transformer owner and the primary fire department
          occurred, and the primary fire department knows,
          accepts, and recognizes what the alternative mark
          means, and that this can be substantiated with
          documentation [761.40 (j) (2) (ii)] .

     •    The EPA Regional Administrator in the appropriate
          region was informed in writing of the use of the
          alternative mark by October 3, 1988 and was
          provided with documentation that the program began
          before August 15, 1985, and documentation that
          demonstrates that prior to that date the primary
          fire department knew, accepted, and recognized the
          meaning of the mark, and included this information
          in the firefighting training  [761.40(j)(2)(iii)].

     •    The Regional Administrator approved in writing the
          use of an alternative mark within 30 days of
          receipt of the documentation of a program
           [761.40(j) (2) (iv)] .
PHASEOUT REQUIREMENTS

     •    After October 1, 1985, the use and storage for
          reuse of PCB Transformers (500 ppm or greater)
          that pose an exposure risk to food or feed is
          prohibited  [761.30(a)(1)].   It is the owner's
          responsibility to determine whether a PCB
          Transformer poses an exposure risk to food or
          feed.

     •    After October 1, 1985, the installation of PCB
          Transformers in or near commercial buildings is
          prohibited.  However, as of September 1, 1988, PCB
          Transformers may be installed in or near
          commercial buildings in an "Emergency Situation"
          or "For Purposes of Reclassification" in

                          1-7

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accordance with 761.30(a)(1)(iii)(B) and  (C) and
(D) .

In or near a commercial building means inside, on,
or within 30 meters of a nonindustrial, non-
substation building.  Commercial buildings are
accessible to the public as well as employees.
Examples include schools, hospitals, office
buildings, stores, apartment buildings, churches,
and transportation terminals and stations.

Emergency installations, in or near a commercial
building, was permitted until October 1, 1990.
However, the use of any PCB Transformer installed
on such an emergency basis is permitted only for
one year from the date of installation or until
October 1, 1990, whichever is earlier
[761.30(a) (1) (iii) (B) (2)] .

Also, installation of a retrofilled PCB
Transformer, in or near a commercial building, was
permitted for reclassification purposes until
October 1, 1990.  However, the use of a
retrofilled PCB Transformer installed for
reclassification purposes is limited to 18 months
after installation or until October 1, 1990,
whichever is earlier [761.30(a)(1)(iii)(C)(2)(i)].
(Note:  Retrofilled mineral oil PCB Transformers
may be installed in or near a commercial building
for reclassification purposes indefinitely after
October 1, 1990.)

Also, as of October 1,  1990, the use of network
PCB Transformers with higher secondary voltages
(480 volts or greater,  including 480/277 volt
systems) in or near commercial buildings is
prohibited.   In addition, network PCB Transformers
with higher secondary voltages which are removed
from service in accordance with this requirement
must either be retrofilled and reclassified or
placed into storage for disposal or disposed of
[761.30(a) (1) (ii)] .

Lower secondary voltage  (below 480 volts) network
PCB Transformers  (not located in sidewalk vaults)
may be used in or near commercial buildings beyond
October 1, 1990 provided:   (1) they are equipped
with electrical protection as specified under
761.30(a)(1)(iv)(A)  by October 1, 1990  (see
Electrical Protection Requirements); or  (2)  in
lieu of electrical protection, the transformers
must be registered in writing with the appropriate
EPA Regional Administrator by October 1, 1990.

                1-8

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                (See Registration Requirements on page 1-14.)
               Subsequently, those PCS Transformers which the
               owner chooses to "register" versus equip with
               electrical protection must be removed from service
               by October 1, 1993  [761.30(a)(1)(iv)(B)].

          •    As of October 1, 1990, all higher secondary
               voltage radial PCB Transformers, in use in or near
               commercial buildings, that have .not been removed
               from service, must be equipped with electrical
               protection to avoid transformer ruptures caused by
               high current faults  [761.30 (a) (1(iv)] .

          •    As of February 25, 1991 all lower secondary
               voltage radial PCB Transformers, located in or
               near commercial buildings, that have not been
               removed from service, must be equipped with
               electrical protection to detect sustained high
               current faults and provide for the complete
               deenergization of the transformer or the faulted
               phase of the transformer  [761.30(a)(1)(iv)(E)].

          •    Finally, as of October 1,  1993,  all lower
               secondary voltage (below 480 volts) network PCB
               Transformers located in sidewalk vaults in or near
               commercial buildings must be removed from service
                [761.30(a)(I) (iv)(D)].

Qll: Should a person consider catastrophic failure, such as
     ruptures, explosions,  or fire when trying to determine
     whether a PCB Transformer poses an exposure risk to food or
     feed?

All: One must consider the location of a specific PCB Transformer
     in relation to food or feed products, and all other
     available information.  If there is a reasonable possibility
     of contact between PCBs and food or feed,  the transformer
     must be considered a risk.  In evaluating the exposure risk,
     it is useful to consider a hypothetical situation in which
     PCBs are discharged in any way from the transformer, such as
     through a. rupture or a leak.   The question to be asked is
     whether contact between food or feed and PCBs is reasonably
     possible.  PCB Items that are located adjacent to or above
     food or feed products pose an exposure risk,  unless there is
     secondary containment or another physical  structure that
     prevents discharges from contaminating the food or feed.

     For purposes of determining if a transformer poses exposure
     risks to food or feed, it is not necessary to consider rare
     events.  The standard to be applied is a reasonable
     possibility of contamination of food or feed by PCBs.
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Q12: The phaseout requirements indicate that certain types of PCB
     Transformers must be removed from service by a specific
     date.  Can a PCB Transformer be retrofilled and reclassified
     to meet this phaseout requirement?

A12: Yes.  A PCB Transformer that has been retrofilled and
     reclassified to PCB-contaminated or non-PCB status in
     accordance with the PCB regulations meets the requirement
     for phaseout of a PCB Transformer.  However, for practical
     purposes, PCB Transformer owners must allow sufficient time
     for proper reclassification to reach at least the PCB-
     contaminated status by the phaseout date.


     USE CONDITIONS

     PCB and PCB-Contaminated Transformers (other than in
     railroad locomotives and self-propelled railroad cars) may
     be used for the remainder of their useful lives subject to
     the following conditions:

     1) PCB Transformer EMERGENCY INSTALLATIONS:  Installation of
     a PCB Transformer in or near a commercial building was
     permitted when done in accordance with the definition of
     "Emergency Situation" [761.3] including:

          •    Those who install PCB Transformers in or near a
               commercial building in an emergency situation must
               maintain documentation to support the reason for
               the emergency installation.  This documentation
               must be completed within 30 days after
               installation of the PCB Transformer and maintained
               at the owner's facility  [761.30(a) (1) (iii) (B) (1) .
               The documentation must include:  the type of
               transformer that requires replacement,  the type of
               transformer that must be used for replacement, the
               date of the transformer failure, the date of
               subsequent replacement, the type of transformer
               installed as a replacement, and a statement
               describing actions taken to locate a non-PCB or
               PCB-Contaminated Transformer replacement
               [761.30(a) (1)  (iii) (B) (1) (i) through  (vi)] .

          •    Such emergency installation was permitted until
               October 1, 1990, and the use of any PCB
               Transformer installed on such an emergency basis
               is permitted for 1 year from the date of
               installation or until October 1, 1990,  whichever
               was earlier [761.30(a)(1)(iii)(B)(2)].

          •    PCB Transformers installed for emergency purposes
               may be subsequently reclassified; however, the
               transformer must be effectively reclassified to a

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          non-PCB or PCB-contaminated status within 1 year
          after installation or by October 1, 1990,
          whichever was earlier because the transformer was
          initially installed in an emergency situation
          [761.30(a) (1) (iii) (B) (3)] .

     NOTE: Owners who installed PCB Transformers in
     emergency situations between October 1, 1985 and
     September 1, 1988 were required to notify the Regional
     Administrator in writing by October 3, 1988 of such
     installation.
2) PCB Transformer RECLASSIFICATION INSTALLATIONS:
Installation of a retrofilled PCB Transformer in or near a
commercial building for reclassification purposes is
permitted when it is done in accordance with the following:

     •    Those who install PCB Transformers in or near a
          commercial building for reclassification purposes
          must maintain on the owner's premises, completed
          within 30 days of installation, the following
          information:  the date of installation, the type
          of transformer installed, the PCB concentration
          (if known) at the time of installation, and the
          retrofill and reclassification schedule
          [761.30(a)(1)(iii)(C)(1)3 .

The installation of retrofilled PCB Transformers in or near
commercial buildings for purposes of reclassification was
permitted only until October 1,  1990, with the following
exceptions:

The use of a retrofilled PCB Transformer (a PCB Transformer
that has been drained and refilled to lower its PCB
concentration) installed in or near a commercial building
for reclassification purposes was limited to 18 months after
installation or until October 1,  1990, whichever is earlier
[761.30(a) (1) (iii) (C) (2) (i)] .

     •    Retrofilled mineral oil PCB Transformers may be
          installed in or near a commercial building for
          reclassification purposes indefinitely after
          October 1, 1990 [761.30 (a)  (1) (iii) (C)  (2) (ii)] .   (A
          retrofilled mineral oil PCB Transformer is a
          mineral oil transformer that was required to be
          assumed to contain between 50 and 499 ppm PCBs,
          but was tested and found to contain 500 or more
          ppm, and which was subsequently drained and
          refilled to lower its PCB concentration.)

     •    Once a retrofilled transformer has been installed
          in or near a commercial building for

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          reclassification purposes, it must be tested 3
          months after installation to ascertain the
          concentration of PCBs.  If the PCB concentration
          is below 50 ppm, the transformer can be
          reclassified as a non-PCB Transformer.  If the PCB
          concentration is between 50 and 500 ppm, the
          transformer can be reclassified as a PCB-
          Contaminated Transformer.  If the PCB
          concentration remains at 500 ppm or greater, the
          entire process must be either repeated until the
          transformer has been reclassified to a non-PCB or
          PCB-Contaminated Transformer or the transformer
          must be removed from service.   The
          reclassification process must be completed by
          October 1, 1990 and adhere to the requirements of
          761.30(a)(2)(v) or the transformer must be removed
          from service [761.30(a) (L) (iii) (C) (2) (iii)] .

     NOTE: Owners who installed PCB Transformers in or near
     a commercial, building for reclassification purposes
     between October 1,  1985 and September 1,  1988 were
     required to notify the Regional Administrator in
     writing by October 3, 1988 of such installation.

3) ELECTRICAL PROTECTION REQUIREMENTS:  As of October 1,
1990, all higher secondary voltage radial PCB Transformers,
in use in or near commercial buildings,  and lower secondary
voltage network PCB Transformers (below 480 volts) in or
near commercial buildings (not located in sidewalk vaults)
that have not been removed from service, must be equipped
with electrical protection to avoid transformer ruptures
caused by high current faults.  As of February 25, 1991, all
lower secondary voltage radial PCB Transformers^ in use in
or near commercial buildings, must also be equipped with
electrical protection to avoid transformer ruptures caused
by high current faults [761.30(a)(1)(iv)].   The following
types of electrical protection devices are to be used:

     •    Current-limiting fuses or other equivalent
          technology must be used to detect sustained high
          current faults and provide for complete
          deenergization of the transformer (within several
          hundredths of a second in the case of higher
          secondary voltage radidl PCB Transformers and
          within tenths of a second in the case of lower
          secondary voltage network PCB Transformers) before
          transformer rupture occurs.   The installation,
          setting,  and maintenance of current-limiting fuses
          or other equivalent technology to avoid PCB
          Transformer ruptures from sustained high current
          faults must be completed in accordance with good
          engineering practices  [761.30(a)(1)(iv)(A)].
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          •    All lower secondary voltage network PCB
               Transformers  (below 480 volts) in or near
               commercial buildings  (not located in sidewalk
               vaults) which have not been equipped with
               electrical protection by October 1, 1990  (as
               specified above) must either be removed from
               service for disposal or reclassified in accordance
               with 761.30(a)(2)(v) by October 1, 1993
                [761.30(a)(1)(iv)(B)].

          •    As of February 25, 1991 all lower secondary
               voltage radial PCB Transformers must be equipped
               with electrical protection, such as current-
               limiting fuses or other equivalent technology, to
               detect sustained high current faults and provide
               for the complete deenergization of the transformer
               or complete deenergization of the faulted phase of
               the transformer within several hundredths of a
               second.  The installation, setting, and
               maintenance of such electrical protection must be
               completed in accordance with good engineering
               practices  [761.30(a) (1) (iv) (E) ] .

          •    As of October 1, 1990, all higher secondary
               voltage radial PCB Transformers (480 volts and
               above, including 480/277 volt systems), in use in
               or near commercial buildings, were required to be
               equipped with protection to avoid transformer
               ruptures caused by sustained low current faults
                [761.30(3)(1)(v)].

Q13: What is the difference between a network and a radial
     transformer?

A13: Network transformers are hooked up in parallel systems so
     that if one transformer fails another transformer will pick
     up the load.  A radial transformer is hooked up in a single
     line method, and if that transformer fails,  the load is not
     picked up by another transformer.

Q14: Why did EPA require phaseout without the option of enhanced
     electrical protection of network PCB Transformers in or near
     commercial buildings with high secondary voltages while
     requiring electrical protection on radial transformers?

A14: EPA determined that network PCB Transformers with higher
     secondary voltages are particularly likely to be involved in
     serious fire-related incidents  (i.e., those that involve
     smoke spread into buildings).   Therefore, EPA has placed
     more stringent regulatory measures and controls on these
     transformers.
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     4) REGISTRATION REQUIREMENTS:  As of December 1, 1985, all
     PCB Transformers in use  (including PCB Transformers in
     storage for reuse) were required to be registered with fire
     response personnel with primary jurisdiction  (that is, the
     fire department or fire brigade which would normally be
     called upon for the initial response to a fire involving the
     equipment)  [761.30(a) (1) (vi)] .  Information required to be
     provided to fire response personnel includes:

          •    The location of the PCB Transformer(s) including:
               the address(es) of the building(s) and the
               physical location(s) of the PCB Transformer(s) on
               the building site(s); and, for outdoor PCB
               Transformers, the location of the outdoor
               substation  [761.30(a)(1)(vi)(A)].

          •    The principal constituent of the dielectric fluid
               in the transformer(s) (e.g., Askarel PCBs, mineral
               oil, or silicone oil) [761.30(a)(I) (vi)(B)].

          •    The name and telephone number of the person to
               contact in the event of a fire involving the
               equipment  [761.30(a)(1)(vi)(C)].

Q15: Do PCB Transformers being stored for disposal have to be
     registered with the Fire Department?

A15: No not under TSCA.  The requirement to register transformers
     with fire response personnel is specifically a "use
     condition."  PCB Transformers which have been removed from
     service and are being stored for disposal do not require
     registration.  Those transformers in storage for reuse,
     however, must be registered with fire response personnel.

     As of December 1, 1985, PCB Transformers in use in or near
     commercial buildings were required to be registered with
     building owners.  For PCB Transformers located in commercial
     buildings, PCB Transformer owners were required to register
     the transformers with the building owner of record.  For PCB
     Transformers located near commercial buildings, PCB
     Transformer owners were required to register the
     transformers with all owners of buildings located within 30
     meters of the PCB Transformer(s)  [761.30(a) (1) (vii)] .
     Information required to be provided to building owners by
     PCB Transformer owners includes but is not limited to:

          •    The specific location of the PCB Transformer(s)
                [761.30(a)(1)(vii)(A)].

          •    The principal constituent of the dielectric fluid
               in the transformer(s) (e.g., Askarel PCBs, mineral
               oil, or silicone oil) [761.30(a) (1) (vii) (B)] .
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          •    The type of transformer  installation (e.g.,  •
               208/120 volt network,  280/120  volt  radial,  208
               volt radial, 480 volt  network,  480/277  volt
               network, 480 volt  radial,  480/277 volt  radial)
                [761.30(a)(1)(vii)(C)].

     As of October 1, 1990, owners  of lower secondary  voltage
     network PCB Transformers  in  use  in or near commercial
     buildings but not located in sidewalk vaults,  which have not
     been equipped with electrical  protection as specified under
     761.30(a)(1)(iv)(A), must register in writing those
     transformers with the EPA Regional Administrator  in the
     appropriate region  [761.30 (a) (1) (iv) (C)] .  The information
     required to be provided in writing to the Regional
     Administrator includes:

          •    The specific location  of the PCB Transformer(s)
                [761.30(a)(1)(iv)(C)(1)].

          •    The address(es) of the building(s)  and  the
               physical location  of the PCB Transformer(s)  on the
               building site(s)  [761.30(a)(1)(iv)(C)(2)].

          •    The identification number(s) of the PCB
               Transformer(s)  [761.30(a)(1)(iv)(C)(3)].

     This registration and disposal option is in lieu  of
     providing "electrical protection"  as specified under
     761.30 (a) (l)-(iv) (A) .  Consequently,  these lower secondary
     voltage network  PCB Transformers must be removed  from
     service by October 1, 1993  [761.30(a)(1)(iv)(B)].

     5) COMBUSTIBLE MATERIALS:  As  of December 1,  1985,
     combustible materials include, but are not limited  to,
     paints, solvents, plastics,  paper, and sawn wood  must not be
     stored within a  PCB Transformer  enclosure  (i.e.,  in a
     transformer vault or in a partitioned area housing  a
     transformer); within 5 meters  of a transformer enclosure,
     or, if unenclosed  (unpartitioned) , withi-n 5 meters  of a  PCB
     Transformer [761.30 (a) (1) (viii)] .

Q16: Does the 5-meter distance requirement apply vertically as
     well as laterally?

A16: EPA does not require the  removal of  stored combustibles
     within a 5-meter vertical distance provided that  there is a
     continuous permanent ceiling overhead and/or.,  floor  below.
     However, if the  floor, for example,  is made of metal  grates,
     an electrical fault could still  ignite combustibles below,
     and consequently the 5-meter distance in this  situation
     would apply.
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Q17: Would items such as a wooden desk, wooden benches, and other
     materials used in an office setting be considered stored
     combustibles and have to be moved at least 5 meters from a
     PCB Transformer?

A17: No.  Since these materials are used on a day-to-day basis,
     they would not be considered "stored combustibles" and
     consequently are not required to be moved.  Office equipment
     stored as surplus would be considered stored combustibles.

Q18: If a PCB Transformer is surrounded by a chain-link fence, is
     the transformer considered "enclosed" for purposes of the
     stored combustibles requirement?

A18: No.  A PCB Transformer surrounded by a chain-link fence is
     not considered "enclosed" for the purpose of this
     requirement, and therefore, combustible materials must not
     be stored within 5 meters of the transformer.  The reason
     for this is that a chain-link fence would not provide a
     barrier to prevent an electrical fault or a transformer fire
     from potentially reaching nearby combustible materials.  On
     the other hand, a PCB Transformer surrounded by 2- to 3-hour
     fire-resistant walls would be reasonably protected from
     controllable or less severe fires.

Q19: Does the combustible materials requirement apply to a PCB
     Transformer which has been placed into storage for disposal?

A19: No.  The combustible materials requirement is specifically a
     PCB Transformer "use condition."  Combustible materials do
     not have to be removed from close proximity to a PCB
     Transformer which is being stored for disposal.

     6) INSPECTIONS:  A visual inspection of each PCB Transformer
     (500 pptn or greater) in use or stored for reuse shall be
     performed at least once every 3 months.  These inspections
     may take place any time during the 3 months:  January-March,
     April-June, July-September, and October-December as long as
     there is a minimum of 30 days between inspections.  The
     visual inspection must include investigation for any leak or
     dielectric fluid on or around the transformer.  The extent
     of the visual inspections will depend on the physical
     constraints of each transformer installation and should not
     require an electrical shutdown of the transformer being
     inspected  [761.30(a)(1)(ix)].

     A reduced visual inspection frequency of at least once every
     12 months applies to PCB Transformers that utilize either of
     the following risk reduction measures.  These inspections
     may take place any time during the calendar year as long as
     there is a minimum of 180 days between inspections
     [761.30(a)(1)(xiii)].   PCB Transformers which may be
     inspected annually versus quarterly include:

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     •    PCB Transformers which have impervious, undrained,
          secondary containment capacity of at least 100
          percent of the total dielectric fluid volume of
          all transformers so contained
           [761.30(a)(1)(xiii)(A)].

     •    PCB Transformers which have been tested and found
          to contain less than 60,000 ppm -PCBs (after 3
          months of in-service use if the transformer has
          been serviced for purposes of reducing the PCB
          concentration)  [761.30(a)(1)(xiii)(B) ].

Records of inspection and maintenance history shall be
maintained at least 3 years after disposing of the
transformer and shall be made available for inspection, upon
request by EPA  [761.30(a)(1)(xii)].  Such records shall
contain the following information for each PCB Transformer
[761.30(a)(1)(xii)(A) through (H)]:

     •    Its location.

     •    The date of each visual inspection and the date
          that leak was discovered, if different from the
          inspection date.

     •    The person performing the inspection.

     •    The location of any leak(s).

     •    An estimate of the amount of dielectric fluid
          released from any leak.

     •    The date of any cleanup, containment, repair, or
          replacement.

     •    A description of any cleanup,  containment, or
          repair performed.

     •    The results of any containment and daily
          inspection required for uncorrected active leaks.

7) LEAKING PCB TRANSFORMERS:  If a PCB Transformer is found
to have a leak which results in any quantity of PCBs running
off or about to run off the external surface of the
transformer, then the transformer must be repaired or
replaced to eliminate the source of the leak.  In all cases,
any leaking material must be cleaned up and properly
disposed of according to disposal requirements of 761.60.
Cleanup of the released PCBs must be initiated as soon as
possible,  but in no case later than 48 hours of its
discovery.  Until appropriate action is completed, any
active leak of PCBs must be contained to prevent exposure of
humans or the environment and inspected daily to verify

                          1-17

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containment of the leak.  Trenches, dikes, buckets, and pans
are examples of proper containment measures  [761.30(a) (1) (x) ]
Cleanup should be done in accordance with the PCB Spill
Cleanup Policy.  See Chapter XIV.

8) FIRE-RELATED INCIDENTS:  If a PCB Transformer is involved
in a fire-related incident, the owner of the transformer
must immediately report the incident to the National
Response Center (toll-free 1-800-424-8802; in Washington,
D.C. 202-426-2675).  A fire-related incident is defined as
any incident involving a PCB Transformer which involves the
generation of sufficient heat and/or pressure (by any
source) to result in the violent or non-violent rupture of a
PCB Transformer and the release of PCBs.  Information must
be provided regarding the type of PCB Transformer
installation involved in the fire-related incident  (e.g.,
high or low secondary voltage network transformer, high or
low secondary voltage simple radial system, expanded radial
system, primary selective system, primary loop system, or
secondary selective system or other systems) and the readily
ascertainable cause of the fire-related incident  (e.g., high
current fault in the primary or secondary or low current
fault in secondary).

The owner of the PCB Transformer must also take measures as
soon as practically and safely possible to contain and
control any potential releases of PCBs and incomplete
combustion products into water  [761.30(a)(1)(xi)].  These
measures include,  but are not limited to:

     •    The blocking of all floor drains in the vicinity
          of the transformer  [761.30 (a)  (1) (xi) (A)] .

     •    The containment of water runoff  [761.30(a) (1) (xi)
          (B)] .

     •    The control and treatment (prior to release) of
          any water used in subsequent cleanup operations
          [761.30(a)(1)(xi)(C)].

9) DISCOVERY OF A MINERAL OIL PCB TRANSFORMER:  In the event
a mineral oil transformer, assumed to contain less than 500
ppm of PCBs as provided in 761.3, is tested and found to be
contaminated at 500 ppm or greater PCBs  ("PCB Transformer"),
the unit is subject to all the requirements for PCB
Transformers in 40 CFR part 761 and efforts must be
initiated immediately to bring the transformer into
compliance in accordance with the following schedule
 [761.30(a)(1)(xv)(A) through  (J)]:

     •    Report fire-related incidents, effective
          immediately after discovery.
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Mark/label the PCB Transformer within 7 days after
discovery.

Mark/label the vault door, machinery room door,
fence, hallway, or other means of access to the
PCB Transformer within 7 days after discovery.

Register the PCB Transformer in writing with fire
response personnel with primary jurisdiction and
with the commercial building owner, within 30 days
of discovery.

Install electrical protective equipment on a
radial PCB Transformer and a non-sidewalk vault,
lower secondary voltage network PCB Transformer in
or near a commercial building within 18 months of
discovery or by October 1, 1990, whichever is
later.  NOTE: This section of the regulation was
amended in the Federal Register of November 26,
1990  (55 FR 49043) to indicate the February 25,
1991 deadline for installing electrical protection
on lower secondary voltage radial PCB Transformers
as indicated at 761.30(a)(1)(iv)(E).

Remove a non-sidewalk vault,  lower secondary
voltage network PCB Transformer in or near a
commercial building, if electrical protective
equipment is not installed, within 18 months of
discovery or by October 1, 1993, whichever is
later.

Remove a lower secondary voltage network PCB
Transformer located in a sidewalk vault in or near
a commercial building, within 18 months of
discovery or by October 1, 1993, whichever is
later.

Retrofill and reclassify a high secondary voltage
radial PCB Transformer or a lower or higher
secondary voltage network PCB Transformer, located
in other than a sidewalk vault in or near a
commercial building, within 18 months or by
October 1, 1990, whichever is later (lower
secondary voltage PCB Transformers by February 25,
1991 -- see NOTE above).   This is an option in
lieu of installing electrical protective equipment
on a radial or lower secondary voltage network PCB
Transformer located in other than a sidewalk vault
or of removing a higher secondary voltage network
PCB Transformer or a lower secondary voltage
network PCB Transformer,  located in a sidewalk
vault, from service.
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          Retrofill and reclassify a lower secondary voltage
          network PCB Transformer, located in a sidewalk
          vault, in or near a commercial building within 18
          months or by October 1, 1993, whichever is later.
          This is an option in lieu of installing electrical
          protective equipment or removing the transformer
          from service.

          Retrofill and reclassify a higher secondary
          voltage network PCB Transformer, located in a
          sidewalk vault, in or near a commercial building
          within 18 months or by October 1, 1990, whichever
          is later.  This is an option in lieu of other
          requirements.
SERVICING AND RECLASSIFICATION CONDITIONS

The processing of PCB and PCB-Contaminated Transformers is
limited to servicing activities.  These servicing activities
include:  draining and refilling, topping off, repairing,
and retrofilling for reclassification  [761.30(a)(2)].

the processing and distribution in commerce of PCBs, 50 ppm
or greater, for purposes of servicing and repairing a
customer's equipment is prohibited without an EPA exemption
[761.30(a)(2)(vii)].   However, an exemption is not required
to service your own PCB or PCB-Contaminated Transformer with
the PCB or PCB-contaminated fluid you already own, in
accordance with the regulations.  Also, you can service a
customer's transformers if you use non-PCB or PCB-free
fluid; and, you are allowed to refill a customer's
transformers with the same fluid that came out of the
transformers, regardless of PCB concentration.

The processing (servicing) of non-PCB Transformers with non-
PCB fluids and/or components is allowed without restriction.

A PCB Transformer may be reclassified to a PCB-contaminated
or non-PCB Transformer by draining, refilling, and otherwise
servicing the unit.  In order to be reclassified, the
transformer's dielectric fluid must contain less than 500
ppm PCB (for conversion to PCB-contaminated level) or less
than 50 ppm PCB (for conversion to non-PCB level) after a
minimum of 3 months of inservice use subsequent to the last
servicing conducted for the purposes of reducing the PCB
concentration in the transformer.  Inservice means that the
transformer is used electrically under loaded conditions
that raise the temperature of the dielectric fluid to at
least 50° Centigrade.  The Director of the Chemical
Management Division may grant, without further rulemaking,
approval for the use of alternative methods that simulate
the loaded conditions of inservice use [761.30(a) (2) (v)] .

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Q20: How long do I have to keep the transformer fluid at 50°C?

A20: The regulations do not give a specific amount of time for
     keeping the temperature at 50°C, but the intent of the
     regulation is to simulate the normal use of a transformer.
     For example, if during normal use, a transformer reaches
     50°C on Tuesdays and Thursdays for an hour per day, that is
     how long the transformer should be at 50°C to reclassify the
     transformer.

     NOTE:  EPA is has proposed alternative methods of
     reclassification for both PCB and PCB-Contaminated
     Transformers in the Federal Register of November 18, 1993
     (58 FR 60970) .

     The following conditions also apply to service activities:

          •    Removing the coil from a PCB Transformer  (500 ppm
               or greater) is prohibited [761.30(a) (2) (ii)] .

          •    PCB-Contaminated Transformers may be serviced
               (including rebuilding) only with dielectric fluid
               containing less than 500 ppm PCB
               [761.30(a) (2) (i)] .

          •    PCBs, 50 ppm or greater, removed during servicing
               must be either reused as dielectric fluid or
               disposed of in accordance with EPA requirements
               [761.30(a)(2)(ill)].

          •    PCBs from PCB Transformers must not be mixed with
               or added to dielectric fluid from PCB-Contaminated
               Transformers [761.30(a)  (2) (iii)] .

          •    If dielectric fluid containing less than 500 ppm
               PCBs is mixed with fluid containing 500 ppm or
               greater PCBs, then the resulting mixture must not
               be used as dielectric fluid in any electrical
               equipment.  The entire mixture must be considered
               to be greater than 500 ppm PCBs and must be
               disposed of in an incinerator that meets EPA
               requirements [761.30(a)(2)(iv)].

          •    Any dielectric fluid containing 50 ppm or greater
               PCBs used for servicing transformers must be
               stored in accordance with the storage for disposal
               requirements [761.30(a)(2)(vi)].
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     STORAGE FOR REUSE

     Transformers containing PCBs at any concentration may be
     stored for reuse.  While there are no time limitations on
     this storage, transformers 50 ppm or greater (known or
     assumed) which are stored for reuse should be in a condition
     suitable for reuse.  Equipment that is not suitable for
     reuse will be considered improperly disposed of.  Units that
     are in storage for reuse are considered by EPA to be "in-
     service" for purposes of the regulations.  Also, as of
     October 1, 1985, the storage for reuse of PCB Transformers
     (500 ppm or greater) that pose an exposure risk to food or
     feed is prohibited  [761.30(a)(1)(i)].


Q21: How long can I keep a "burned-out" or "nonfunctional"
     transformer in storage for reuse if I plan on repairing it
     and using it later?

A21: EPA does not require nonfunctional transformers (regardless
     of PCB concentration) to be placed into "storage for
     disposal" if you intend to repair and reuse the item.
     However, EPA may have grounds to enforce against lengthy
     "storage for reuse" of equipment which is not reasonably
     expected to be placed back into service.   The owner should
     be able to demonstrate good faith compliance with the intent
     of the storage for disposal requirements and complete any
     required servicing or repairs within a reasonable amount of
     time.  Any item that is damaged and cannot be repaired for
     regulatory or technical reasons must be disposed of or
     placed into storage for disposal.


     STORAGE FOR DISPOSAL

     All PCB and PCB-Contaminated Transformers must be dated when
     placed into storage for disposal  [761.65(c)(8)] and must be
     removed from storage and disposed of within one year
     [761.65(a)].

     The facility used to store PCB and PCB-Contaminated
     Transformers must comply with the "storage for disposal"
     requirements [761.65(b)(1)].  See the chapter titled "PCB
     Storage Requirements" for specific requirements.

     Non-leaking PCB and PCB-Contaminated Transformers may be
     stored temporarily by the generator in an area that does not
     comply with the requirements for a PCB storage facility for
     up to 30 days from the date of their removal from service
     for disposal, provided that a notation is attached to each
     transformer indicating the dates the equipment was removed
     from service [761.65(c) (1) (i)], and placed into storage for
     disposal  [761.65(c) (8)] .

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Leaking PCB and PCB-Contaminated Transformers which are
placed in PCB Containers that comply with DOT specifications
 [761.65 (c) (6)] with sufficient sorbent materials to absorb
any liquid PCBs, may also be temporarily stored by the
generator for up to 30 days provided that a notation is
attached to the container indicating the dates the
transformer was removed from service  [761.65 (c) (1) (ii)], and
placed into storage for disposal  [761.65(c)(8)].   Each
container or drum used to store leaking PCB Items must be
marked in accordance with EPA marking and labeling
requirements  [761.40(a) (1) ] .

Nonleaking and structurally undamaged PCB-Contaminated
Transformers, that have not been drained of free-flowing
dielectric fluid, may also be stored on pallets next to a
PCB storage facility which meets the requirements for
storage for disposal.   This type of storage is permitted
only when the storage facility has immediately available
unfilled storage space equal to 10 percent of the volume of
the equipment stored outside the facility.  The equipment
stored outside the facility must be inspected for leaks
weekly [761.65(c)(2)], and a notation must be attached to
each unit indicating the date the equipment was removed from
service [761.65(c)(1)] and placed into storage for disposal
 [761.65(c)(8)].

Commercial storers now must seek approval to operate and
demonstrate financial responsibility for closure of the
facility under the new provisions of the Notification and
Manifesting Rule which was published in the Federal Register
on December 21,  1989.   See Chapters XII and XIX for further
details on commercial storage facility approvals and other
aspects of the Notification and Manifesting Rule.

DISPOSAL

PCB Transformers (500 ppm or greater)  must be disposed of as
follows:

     •    In an incinerator that complies with 40 CFR
          761.70.

     •    In a chemical waste landfill which complies with
          761.75 provided that:  the transformer is first
          drained of all free-flowing liquid,  filled with
          solvent,  allowed to stand for at least  18 hours
          and then drained thoroughly.  PCB liquids that are
          removed shall be disposed of by incineration under
          761.60(a).  Solvents may include kerosene,  xylene,
          toluene and other solvents in which PCBs are
          readily soluble.  Precautionary measures should be
          taken, however,  that the solvent flushing
          procedure is conducted in accordance with

                          1-23

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          applicable safety and health standards as required
          by Federal or State regulations
          [761.60(b) (1) (i) (B)] .

     •    The PCB liquids that are removed, including the
          flushing solvent, must be disposed of in an
          incinerator that complies with 40 CFR 761.70, or
          by an alternative EPA approved and permitted
          disposal method in accordance with 761.60(e).

PCB-Contaminated Transformers (50-499 ppm PCBs) shall be
disposed of as follows:

     •    By draining all free-flowing liquid from the
          transformer and disposing of the liquid in an
          incinerator that complies with 40 CFR 761.70; or,
          in a chemical waste landfill that complies with
          761.75, if information is provided to the owner or
          operator of the chemical waste landfill that shows
          that the waste does not exceed 500 ppm PCBs and is
          not an ignitable waste as described in
          761.75(b) (8) (iii); or, in an approved high
          efficiency boiler that complies with
          761.65(a) (2) (iii); or, by an alternative EPA
          approved and permitted disposal method that
          complies with 761.60(e) [ (761.60(b) (4)] .

The disposal of the drained contaminated equipment carcass
is not regulated  [761.60(b)(5)(ii)]; however, drained PCB-
Contaminated Transformer carcasses cannot be sold
(distributed in commerce) for use as parts and components in
repair or rebuilding activities.  (See Distribution in
Commerce.)

Non-PCB Transformers  (less than 50 ppm PCB) may be disposed
of with the following considerations:

     •    There are no PCB disposal requirements for non-PCB
          Transformers.  However, certain reuse restrictions
          apply to the less than 50 ppm PCB fluid.   Waste
          oil with any detectable concentration of PCBs
          cannot be used as a sealant, coating, or dust
          control agent  [761.20(d) ] ; and also,  can only be
          burned for energy recovery in specific combustion
          facilities described in 761.20(e)(1).  See the
          chapter on "Disposal" for a detailed discussion of
          the disposal of non-PCB waste oils.
                          1-24

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RECORDKEEPING

The Notification and Manifesting Rule  (FR December 21, 1990)
adopts additional recordkeeping and reporting requirements
at 761.180(a) and  (b) to complete the tracking system for
PCB wastes.  The rule requires that the manifests themselves
be retained as records by waste handlers, and it requires
reporting to EPA in the event of irregularities in the
transport of regulated wastes.  These reports depend largely
on information derived from particular manifests.

Three of_the waste tracking reports are modeled after their
RCRA counterparts.  The rule requires "Exception Reports" to
be filed with EPA whenever a generator has not received
verification of delivery of PCB waste within 45 days.  Also,
a "Discrepancy Report" is required of storage or disposal
facilities in those cases where the waste' actually delivered
to them does not correspond exactly with the types and
quantities described on the manifest.  Third, an
"Unmanifested Waste Report" is required of disposers or
storers in those instances in which waste arrives at a
facility unaccompanied by a required manifest.  All of these
reports may be thought of as "red flags" to EPA of possible
disposal violations.  They provide the means for generators
and disposers to "enforce" the day-to-day workings of the
manifest system for EPA.

The rule adds one additional reporting requirement for which
there is no counterpart under RCRA.  This requirement is the
"One-year Exception Report," intended to bolster EPA's
ability to enforce the requirement under TSCA regulations
that limits storage of PCBs prior to disposal to no more
than one year.  Information on when items of PCB waste were
removed from service for disposal is included with the
manifests that accompany the waste from generation to
disposal.  Disposers are required to certify the date of
disposal of PCB waste manifested to them, and in the event
more than one year has elapsed since the PCBs were removed
from service for disposal, a report must be filed with EPA.

Finally, the rule adds several amendments to the existing
PCB recordkeeping provisions that concern the Annual
Document requirements for the users, storers, and disposers
of PCBs.  The most significant of these amendments is the
requirement that each disposer and commercial storer of PCB
waste submit by July 15 of each year an annual report, which
is a summary of the previous calendar year's PCB activity at
the facility.  The report will be submitted to the
appropriate EPA Regional Administrator.  See Chapter XV,
Recordkeeping and Reporting, for further details on the
recordkeeping requirements under the Notification and
Manifesting Rule.
                          1-25

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Testing data, inventories, servicing and reclassification
records, spill reports, and disposal records should be
maintained for all PCB and PCB-Contaminated Transformers.
Specific types and quantities of PCB's [761.180(a)]  form the
basis of an Annual Document Log which must be prepared each
year and maintained for at least 3 years after the facility
ceases using or storing PCBs and PCB Items in quantities
prescribed in section 761.180(a).  Annual Records (manifests
and certificates of disposal) shall be maintained for the
same period.  The Annual Document for 1989 shall cover the
period  from January 1, 1989 to February 5, 1990 (the
effective date of the final rule).  See Chapter XV,
"Recordkeeping and Reporting" for a detailed discussion of
Annual Records.
SPILLS

Spills, leaks, and other uncontrolled discharges where the
release results in any quantity of PCBs running off or about
to run off the external surface of a PCB or PCB-Contaminated
Transformer is considered improper disposal of PCBs.  The
PCB Spill Cleanup Policy provides specific cleanup measures
which, if followed explicitly, create a presumption against
enforcement for penalties or further cleanup.  See the
chapter on "PCB Spill Cleanup Policy" for specific measures.

PCB spills involving 1 Ib. or more of pure PCBs (generally 1
pint of Askarel) must be reported to the National Response
Center at (800) 424-8802.  Spills of 10 Ibs.  or more of pure
PCBs  (generally a gallon) must be reported to the
appropriate regional EPA office.  Failure to notify the NRC
under CERCLA can lead to civil penalties under Section 109
or, under Section 103, criminal fines and imprisonment.  Any
spill should be reported when people or animals can come
into direct and uncontrolled contact with PCBs.

Measures must immediately be taken to control the spread of
the spill.  Any threats to water should be given highest
priority.  Water and other complicated spills should be
cleaned up by trained personnel to levels set by the
appropriate EPA Regional Administrator.  Organizations that
frequently handle PCBs should develop spill contingency
plans and conduct training for dealing with spills.

Once a spill is contained, cleanup measures can begin.  EPA
requires cleanup of PCBs to different levels depending on
spill location, the potential for exposure to residual PCBs
remaining after cleanup, the concentration of PCBs initially
spilled, and the nature and size of the population
potentially at risk of exposure.  While the PCB Spill
Cleanup Policy applies to the majority of situations,
exceptional circumstances may require additional cleanup at

                          1-26

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     the direction of the EPA regional office.  A detailed
     description of the specific reporting, cleanup,
     recordkeeping, and post-cleanup sampling requirements is
     found in the chapter on "PCB Spill Cleanup Policy."

     Other minor weeping from PCB or PCB-Contaminated Transformer
     bushings and seams, not covered by the spill policy, is
     still considered improper disposal of PCBs and compels
     responsible parties to take actions to rectify the exposure
     of humans and the environment to PCBs.

Q22: Do records and/or spill reports have to be kept for all PCB
     or PCB-Contaminated Transformers which rupture?

A22: The PCB Spill Cleanup Policy specifies certain recordkeeping
     requirements when a PCB or PCB-Contaminated Transformer
     ruptures or spills.  See the chapter on "PCB Spill Cleanup
     Policy" for specific spill recordkeeping requirements.
                              1-27

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                             CHAPTER I
                              PART B
                           TRANSFORMERS
                            (RAILROAD)
Manufacturing  (page  1-29)

Processing  (page  1-29)

Distribution in Commerce  (Sale of Railroad  Transformers)
(page 1-29)

Exemptions to Manufacture, Process, and Distribute
  PCBs in Commerce  (page  1-31)

Marking/Labeling  (page 1-31)

Use and Performance  Requirements  (page 1-32)

Servicing and Reclassification Conditions  (page  1-32)

Storage for Reuse  (page 1-33)

Storage for Disposal  (page 1-33)

Disposal (page 1-33)

Spills (page 1-32)
                               1-28

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PART B

                      RAILROAD TRANSFORMERS

     EPA defines railroad transformers (in the same manner as
     nonrailroad transformers) in three basic categories --
     "PCB," "PCB-contaminated," and "Non-PCB."  Also, the
     "assumption rules" discussed earlier in this chapter  (see
     page 1-1) apply to untested railroad transformers.  The
     following conditions and restrictions apply to PCBs in
     transformers in railroad locomotives or railroad self-
     propelled cars (railroad transformers).


     MANUFACTURING

     The manufacture of PCBs, regardless of concentration,  for
     use in railroad transformers is prohibited without an EPA
     exemption [TSCA section 6(e) and 761.20(b)].


     PROCESSING

     The processing of PCBs, 50 pptn or greater, for use in
     railroad transformers is prohibited without an EPA exemption
     [TSCA section 6(e) and 761.20(c)].  However, PCBs at
     concentrations less than 50 ppm may be processed for use in
     railroad transformers  (under specific conditions) in
     accordance with the definition of "Excluded PCB Products"
     [761.3].   Also, PCBs at any concentration may be processed
     (i.e., prepared and/or packaged for distribution in
     commerce) for purposes of disposal [TSCA section 6(e)  and
     761.20(c)(2)].


     DISTRIBUTION IN COMMERCE (Sale of Railroad Transformers)

     The distribution in commerce of PCBs, 50 ppm or greater, for
     use in railroad transformers is prohibited without an EPA
     exemption [761.20(c)].  However,  PCBs at concentrations less
     than 50  ppm may be distributed in commerce for use in
     railroad transformers  (under specific conditions) in
     accordance with the definition of "Excluded PCB Products"
     [761.3] .   Also, PCBs at any concentration may be distributed
     in commerce for purposes of disposal in accordance with the
     requirements of 761.60 [761.20(c)(2)].  Disposal, in this
     context,  means the termination of the
     useful life of the PCB or PCB-contaminated railroad
     transformer.

     The distribution in commerce (sale)  of railroad transformers
     which contain PCBs in concentrations of  50 ppm or greater
     (known or assumed) for purposes of reuse is allowed only if:

                              1-29

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          •    the unit was originally sold for use before
               July 1, 1979;

          •    the unit is intact and nonleaking at the time of
               sale; and

          •    no PCBs are introduced into the unit.


Q24: Does this mean that I can sell a PCB or PCB-contaminated
     railroad transformer?

A24: Yes.  If the railroad transformer was originally sold for
     use before July 1, 1979, and is now being sold for resale or
     reuse (i.e., continued use).  Also, the railroad transformer
     must be intact and nonleaking.  EPA recommends that the
     buyer be advised that he is purchasing a PCB or PCB-
     contaminated unit.

Q25: What does intact and nonleaking mean?

A25: Intact and nonleaking means that the railroad transformer
     has all fluid intact and there are no PCBs on the external
     surface of the equipment.

Q26: Can I sell drained PCB-contaminated railroad transformers
     (known or assumed 50-499 ppm)  to a scrap or salvage dealer
     for metals recovery?

A26: Yes.  The sale of drained 50-499 ppm carcasses for scrapping
     or salvaging is generally considered distribution in
     commerce for purposes of disposal and is allowed with
     certain limitations.  To qualify as disposal, the scrapping
     practice must be one which will "...terminate the useful
     life of PCBs or PCB Items"  [761.3]; or, in other words, will
     destroy any residual PCBs found in the drained carcasses.
     Salvaging aimed at reclamation of the metals found in the
     case and coil generally constitutes disposal, because any
     residual PCBs are destroyed by the high temperatures
     employed in the smelting process.  However, where salvaging
     consists of disassembling the drained equipment to obtain
     parts for reuse in other equipment, the useful life of the
     equipment has not been fully terminated and thus is not
     considered disposal.  In sum,  the scrapping/salvaging of 50-
     499 ppm drained equipment is unregulated to the extent that:
     (1) scrapping practices do not result in leaks,  spills, or
     other uncontrolled discharges of PCBs, and  (2) any PCB-
     contaminated components are not reintroduced into commerce.
                               1-30

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EXEMPTIONS TO MANUFACTURE. PROCESS. AND DISTRIBUTE PCBs  IN
COMMERCE

Exemptions to manufacture, process, and distribute in
commerce PCBs in railroad transformers may be granted  only
by rulemaking on a case-by-case basis.  The EPA
Administrator may set terms and conditions for an exemption
and may grant an exemption for not more than one year.   EPA
interim procedural rules for processing and distribution in
commerce exemptions describe the required content of
processing and distribution in commerce exemptions petitions
and the procedures EPA follows in rulemaking on exemption
petitions.  Those rules were published in the Federal
Register of May 31, 1979  (44 FR 31558) and are codified  at
40 CFR 750.30 through 750.41.
MARKING/LABELING

All PCB railroad transformers  (500 ppm or greater) must be
marked in accordance with EPA marking and labeling
requirements  [761.40].  All marks/labels must comply with
EPA marking formats which specify size, color, and design
[761.45].

     •    All PCB railroad transformers (500 ppm or greater)
          must be marked individually with the Mark ML (PCB
          label) [761.40{a)(2) and  (c)(l)].

     •    The marking of PCB-contaminated railroad
          transformers  (50-499 ppm) is not required
          [761.40(c)(1)].

     •    Transport vehicles loaded with one or more PCB
          Transformers  (500 ppm or greater) must be marked
          on each end and each side with the mark ML (PCB
          label) [761.40(b)].

     •    All marks/labels must be placed in a position on
          the exterior of the transformer and/or transport
          vehicle so that the mark can be easily seen by
          persons inspecting the transformer  [761.40(h)].

PCB Transformer locations must also be marked/labeled in
accordance with 761.40(j).

     •    As of December 1, 1985, the vault door, machinery
          room door, fence, hallway, or other means of
          access (other than grates and manhole covers) to a
          PCB Transformer must be marked with the mark ML
          (PCB label)  [761.40(j(1)].
                          1-31

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     As of July I, 1986, the use of railroad transformers
     containing dielectric fluids with a PCB concentration
     greater than 1,000 ppm was prohibited  [761.30(b)(1)(vi)].

Q27: What should be done if a railroad organization discovers
     that an inservice railroad transformer contains over 1,000
     ppm PCBs today?

A27: The continued use of railroad transformers containing over
     1,000 ppm PCBs was prohibited in 1986.  Consequently, if a
     railroad transformer were discovered today as containing
     more than 1,000 ppm PCBs, the owner/operator of the
     transformer would be out of compliance with the regulations.
     The Regional EPA Administrator should be contacted
     immediately, and steps should be taken to bring the
     equipment into compliance as soon as possible.

     The concentration of PCBs in the dielectric fluid contained
     in railroad transformers must be measured:

          •    Immediately upon completion of any authorized
               servicing of a railroad transformer conducted for
               the purpose of reducing the PCB concentration in
               the dielectric fluid in the transformer
               [761.30(b)(1)(vii)(A)]; and, between 12 and 24
               months after each servicing
               [761.30(b)(1)(vii)(B)].

          •    The data obtained as a result of the above
               servicing shall be retained until January 1, 1991
               [761.30(b)(1)(vii)(C)].
     SERVICING AND RECLASSIFICATION CONDITIONS

     The processing of PCB and PCB-contaminated railroad
     transformers is limited to servicing activities.  These
     servicing activities include:  draining and refilling,
     topping off, repairing, and retrofilling for
     reclassification [761.30(a)(2)].

          •    Railroad transformers may be serviced only with
               dielectric fluid containing less than 1,000 ppm
               PCBs  [761.30(b) (2)  (iii)]; except, if the coil is
               removed from the casing of a railroad transformer
               (e.g., the transformer is rebuilt), the railroad
               transformer may not be refilled with dielectric
               fluid containing a PCB concentration greater than
               50 ppm [761.30(b)(2)(i)].
                               1-32

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      •    Dielectric  fluid may be  filtered through activated
          carbon or otherwise industrially processed  for  the
          purpose of  reducing the  PCB concentration in  the
          fluid  [761.30(b)(2)(iv)].

      •    Any PCB dielectric fluid that is used to service
          PCB railroad transformers  (500 ppm or greater)
          must be stored  in accordance with the storage for
          disposal requirements at 761.65 .[761.30(b)(1)(v)].

A PCB railroad transformer may be  converted to a PCB-
Contaminated Transformer  or to a non-PCB Transformer  by
draining, refilling,  and/or Otherwise servicing the railroad
transformer.  In order to be reclassified, the railroad
transformer's dielectric  fluid must  contain less than 500-
ppm PCBs for conversion to PCB contaminated status, or  less
than  50 ppm PCBs for  conversion to non-PCB status after a
minimum of three months of inservice use subsequent to  the
last  servicing conducted  for the purpose of reducing  the  PCB
concentration in the  transformer  [761.30(b)(2)(vii)].
STORAGE FOR REUSE

The storage for reuse conditions for PCB and PCB-
contaminated railroad transformers are identical to the
storage for reuse conditions for nonrailroad transformers as
outlined earlier in this chapter.  (See page 1-22.)
STORAGE FOR DISPOSAL

The storage for disposal requirements for PCB and PCB-
contaminated railroad transformers are identical to the
storage for disposal requirements for nonrailroad
transformers as outlined earlier in this chapter.   (See page
1-22.)
DISPOSAL

The disposal requirements for PCB and PCB-contaminated
railroad transformers are identical to the disposal
requirements for nonrailroad transformers as outlined
earlier in this chapter.  (See page 1-23.)

SPILLS

Spills from railroad transformers are treated the same as
spills from non-railroad transformers.  Please see the
earlier discussion of spills in this chapter (See page I-
26) .
                          1-33

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                       CHAPTER II
                       CAPACITORS
                        A. LARGE

Manufacturing  (page 11-3}

Processing  (page II-3)

Distribution in Commerce  (Sale of Large  PCB  Capacitors)
   (page II-3)

Exemptions  to Manufacture, Process, and  Distribute  PCBs  in
 Commerce  (page II-4)

Marking/Labeling  (page  II-4)

Phaseout Requirements  (page II-5)

Use Conditipns  (page II-6)

Servicing Conditions  (page II-6)

Capacitors  That Pose an Exposure Risk to Food or  Feed
   (page II-6)

Storage for Reuse (page II-7)

Storage for Disposal  (page 11-7}

Disposal (page II-8)

Recordkeeping  (page II-8)

Spills (page II-9)

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                          - CAPACITORS -

     Capacitors are defined at 40 CFR 761.3 in two basic
     categories--"small" and  "large."  A  "small capacitor" is
     defined as containing less than 1.36 kilograms  (3 Ibs.) of
     dielectric fluid.  A  "large capacitor" is defined as
     containing 1.36 kilograms  (3 Ibs.) or more of dielectric
     fluid.  The  following assumptions may be used if the actual
     weight of the dielectric fluid is unknown.

     •    A capacitor whose total volume  is less than 1,639 cubic
          centimeters  (100 cubic inches) may be considered to
          contain less than 1.36 kilograms  (3 Ibs.) of dielectric
          fluid.

     •    A capacitor whose total volume  is more than 3,278 cubic
          centimeters  (200 cubic inches) must be considered to
          contain more than 1.36 kilograms  (3 Ibs.) of dielectric
          fluid.

     •    A capacitor whose total volume is between 1,639 and
          3,278 cubic centimeters may be considered to contain
          less than 1.36 kilograms (3 Ibs.) of dielectric fluid
          if the total weight of the capacitor is less than 4.08
          kilograms (9 Ibs.).


Ql:  Our rural utility has discovered numerous small capacitors
     in phase converters (commonly referred to as "add-a-phases")
     which are utilized in various applications, specifically on
     farm irrigation systems.  In most cases,  these add-a-phase
     type units contain several small, independent capacitors
     (less than 3 Ibs. each) banded together within a single
     housing compartment.  Does EPA classify capacitors such as
     these as small, individual capacitors, or must the combined
     volume of the small capacitors be totaled and treated as one
     large capacitor?

Al:  Capacitors are classified according to the weight of fluid
     in each individual unit, not by the total weight of a group.
                               II-l

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PART A

                        LARGE CAPACITORS

     Large PCB Capacitors are used extensively by electric
     utilities and other various industries.   Large capacitors
     are commonly used to improve the voltage and power factor of
     electric power systems.  Virtually all capacitors
     manufactured prior to 1978  were filled with PCB dielectric
     fluids generically known as "Askarels."   (See the
     "Introduction" chapter for a list of "Common Trade Names.")
     These "Askarel" dielectric  fluids generally range from 75-
     100 percent PCB concentration.  After July 1, 1979,  the
     manufacture of capacitors using these PCB dielectric fluids
     (Askarels)  was prohibited.

     Large PCB Capacitors are classified based upon voltage
     ratings [761.3] .   A large capacitor that is rated for
     operation at 2,000 volts (A.C. or B.C.)  or above is termed a
     "large, high-voltage capacitor," while a large capacitor
     that is rated for operation below 2,000  volts is termed a
     "large, low-voltage capacitor."  Most TSCA requirements for
     large PCB Capacitors are identical for both with the
     exception of certain marking/labeling requirements which
     vary depending upon "high"  or "low" voltage.   Also,  the use
     of PCB-contaminated Capacitors has not been phased out.

     After October 1,  1988,  the  use of large  PCB Capacitors is
     prohibited unless the capacitor is used within a restricted
     access area [761.30(1)].  Large PCB Capacitors which are
     located in certain "restricted-access" areas may be used for
     the remainder of their useful life. There are basically two
     types of "restricted-access" areas which are acceptable for
     the continued use of large  PCB Capacitors beyond October 1,
     1988: (1)  restricted-access electrical substations,  and
     (2) contained and restricted-access indoor installations.

     A "restricted-access electrical substation" is an outdoor,
     fenced, or walled-in facility that restricts public access
     and is used in the transmission or distribution of electric
     power.  Release of PCBs from capacitors  in these substations
     beyond the confines of the  substations are extremely
     limited.  Outdoor, fenced or walled-in suburban locations
     that perform R&D activities on large capacitors but do not
     transmit or distribute electric power are still considered
     to be restricted access areas.

     A "contained and restricted-access indoor installation"
     restricts public access and has an adequate roof, walls, and
     floor to contain any release of PCBs within the indoor
     location.   Release of PCBs  in these facilities also presents
     very limited exposure potential.


                              II-2

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The majority of large PCB Capacitors which are not in a
restricted-access location are primarily found on utility
poles throughout electric service areas.  The exposure risks
associated with these capacitors vary due to their
widespread use.  These capacitor installations are used in
residential neighborhoods, industrial areas, rural areas,
public areas  (such as shopping centers, schools, etc.), and
near waterways.  Because of their location, these PCB
Capacitors have a greater potential for exposing humans,
animals, and the environment during their use than do other
large PCB Capacitors; therefore, their use was prohibited as
of October 1, 1988  [761.30(1)].
MANUFACTURING

The manufacture of PCBs, regardless of concentration, for
use in large capacitors is prohibited without an EPA
exemption  [761.20(b)].
PROCESSING

The processing of PCBs, 50 ppm or greater, for use in large
capacitors is prohibited without an EPA exemption  [761.20(c)
and (4)].  However, PCBs at any concentration may be
processed (i.e., prepared and/or packaged for distribution
in commerce) for purposes of disposal  [761.20 (c) (2)] .
DISTRIBUTION IN COMMERCE (Sale of Large PCB Capacitors)

The distribution in commerce of PCBs, 50 ppm or greater, for
use in large capacitors is prohibited without an EPA
exemption  [761.20 (c)] .   PCBs at any concentration may be
distributed in commerce for purposes of disposal
[761.20(c)(2)].  Disposal,  in this context, means the
termination of the useful life of the PCB or PCB-
Contaminated Capacitors.

The distribution in commerce (sale)  of large capacitors
which contain PCBs in concentrations of 50 ppm or greater
for purposes of reuse is allowed provided:

     •    the capacitor was originally sold for use before
          July 1, 1979;

     •    the capacitor is intact and nonleaking at the time
          of sale;  and

     •    no PCBs are introduced into the capacitor.
                          II-3

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Q2:  Does this mean that I can sell a PCB Capacitor?

A2:  Yes, if the capacitor was originally sold for use before
     July 1, 1979, and is now being sold for continued use.
     Also, the capacitor must be intact and nonleaking.  EPA
     recommends that the buyer be advised that he is purchasing a
     PCB Capacitor.  The capacitor must be marked in accordance
     with 761.40.

Q3:  What does intact and nonleaking mean?

A3:  Intact and nonleaking means that the capacitor is
     structurally sound with all fluid intact and there are no
     PCBs on the external surface of the capacitor.


     EXEMPTIONS TO MANUFACTURE. PROCESS. AND DISTRIBUTE PCBs IN
     COMMERCE

     Exemptions to manufacture, process, and distribute in
     commerce PCB Capacitors or PCB dielectric fluids for use in
     PCB Capacitors may be granted only by rulemaking on a case-
     by-case basis.  The EPA Administrator may set terms and
     conditions for an exemption and may grant an exemption for
     not more than one year.  EPA interim procedural rules for
     processing and distribution in commerce exemptions describe
     the required content of processing and distribution in
     commerce exemption petitions and the procedures EPA follows
     in rulemaking on exemption petitions.  Those rules were
     published in the Federal Register of May 31, 1979  (44 FR
     31558) and are codified at 40 CFR 750.30 through 750.41.


     MARKING/LABELING

     All large PCB Capacitors must be marked in accordance with
     EPA marking and labeling requirements  [761.40].  All
     marks/labels must comply with EPA marking formats which
     specify size, color, and design  [761.45].

          •    All PCB large, high-voltage capacitors which are
               in service  (including stored for reuse) must be
               marked individually with the mark ML (PCB label) .

          •    All PCB large, high-voltage capacitors and
               equipment containing a large high-voltage
               capacitor must be marked individually with the
               mark ML (PCB label)  at the time of removal from
               use if not already marked  [761.40(a)(3) and  (4)].
                               II-4

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          •    PCB large, low-voltage capacitors are not required
               to be marked while in service, but must be marked
               at the time of removal from use  [761.40(a)(5)].

          •    All marks/labels must be placed in a position on
               the exterior of the capacitor so that the marks
               can be easily seen by persons inspecting the
               capacitor(s)  [761.40(h)].


     PHASEOUT REQUIREMENTS

          •    After October 1, 1988, the use and storage for
               reuse of PCB large, high- and low-voltage
               capacitors which pose an exposure risk to food or
               feed is prohibited [761.30(1)].

          •    After October 1, 1988, the use of all PCB large,
               high- and low-voltage capacitors is prohibited
               unless the capacitor is used within a restricted
               access electrical substation or in a contained and
               restricted-access indoor installation.  A
               contained and restricted-access indoor
               installation must have adequate roof, walls, and
               floor to contain any release of PCBs within the
               indoor location [761.30(1)].  Examples are
               manufacturing facilities and commercial building
               vaults.

Q4:  Can large PCB Capacitors be used for the remainder of their
     useful life provided they are located in a restricted access
     electrical substation?

A4:  Yes. However, if the location of the PCB Capacitors within
     the substation still poses an exposure risk to food or feed,
     the continued use of these units was prohibited after
     October 1, 1988.


Q5:  Can large PCB Capacitors be used for the remainder of their
     useful life if they are located in an electrical power
     plant?                     *

A5:  Only if the power plant is a restricted access building and
     has adequate roof, walls, and floors which would contain any
     release of PCBs within the power plant.
                               II-5

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     USE CONDITIONS

     Large PCB Capacitors may be used for the remainder of their
     useful lives only in accordance with the phaseout
     requirements of 761.30(1).  Non-PCB Capacitors are
     unregulated for use.

          •    Inspections;  No recorded maintenance inspections
               are required for large PCB Capacitors.  However,
               ruptures, leaks, and other uncontrolled discharges
               from PCB Capacitors are considered improper
               disposal of PCBs, and should be cleaned up in
               accordance with the PCB Spill Cleanup Policy.


     SERVICING CONDITIONS

     Since there is no specific authorization for servicing lage
     PCB Capacitors their servicing is prohibited without an EPA
     exemption.


     CAPACITORS THAT POSE AN EXPOSURE RISK TO FOOD OR FEED

     The use and storage for reuse of large PCB Capacitors that
     pose an exposure risk to food or feed became prohibited
     after October 1, 1988 [761.30(1)(1)].

Q6:  Should a person consider catastrophic failure,  such as
     ruptures, explosions, or fire when trying to determine
     whether a large PCB Capacitor poses an exposure risk to food
     or feed?

A6:  One must consider the location of a specific PCB Capacitor
     in relation to food or feed products,  and all other
     available information.   If there is a reasonable possibility
     of contact between PCBs and food or feed as a result of a
     discharge, the capacitor must be considered a risk.  In
     evaluating the exposure risk, it is useful to consider a
     hypothetical situation in which PCBs are discharged in any
     way from the capacitor,  such as through a rupture or a leak.
     The question to be asked is whether contact between food or
     feed and PCBs is reasonably possible.   PCB Capacitors that
     are located adjacent to or above food or feed products pose
     an exposure risk,  unless there is secondary containment or J
     another physical structure that prevents PCB discharges from
     contaminating the food or feed.  The standard to be applied
     is a reasonable possibility of contamination of food or feed
     by PCBs.
                               II-6

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     STORAGE FOR REUSE

     Large capacitors containing PCBs in any concentration may be
     stored for reuse provided the storage does not pose an
     exposure risk to food or feed.  There are no time
     limitations on this storage; however, the large PCB
     Capacitors which are being stored for reuse must be in a
     condition suitable for reuse, and the owner of the
     capacitors should be able to demonstrate a reasonable need
     to store spare capacitors.  Large PCB Capacitors stored for
     reuse must be stored in a restricted access electrical
     substation or other restricted access indoor installation.
     Capacitors stored for reuse are considered by EPA to be "in
     service" for purposes of the regulations.  These capacitors
     must be handled as in use capacitors and all requirements
     including marking, recordkeeping, and disposal remain the
     same.
     STORAGE FOR DISPOSAL

     All large PCB Capacitors must be dated when placed into
     storage for disposal and must be removed from storage and
     disposed of within one year  [761.65(a)].

Q7:  Does each large PCB Capacitor in storage for disposal have
     to be dated, or would a storage log or list indicating these
     dates be sufficient?

A7:  Each PCB Article, including individual PCB Capacitors, must
     be dated on the article when placed into storage for
     disposal [761.65(c)(8)].  Consequently, the mere listing of
     dates on a storage log or list is not sufficient.

     The facility used to store large PCB Capacitors for disposal
     must comply with the "storage for disposal" requirements
     [761.65(b)(1)].   See Chapter XII on "PCB Storage
     Requirements" for specific requirements.

     Nonleaking large PCB Capacitors may be stored temporarily by
     the generator in an area that does not comply with the
     requirements for a PCB storage facility for up to 30 days
     from the date of their removal from service for disposal,
     provided  that a notation is attached to each capacitor
     indicating the date the capacitor was removed from service
     [761.65(c)(1)(i)] and placed into storage for disposal
     [761.65(c) (8)] .

     Leaking PCB Capacitors which are placed in PCB Containers
     that comply with DOT specification  [761.65(c)(6)]  with
     sufficient  sorbent materials to absorb any liquid PCBs,  may
     also be temporarily stored by the generator for up to 30

                              II-7

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     days provided that a notation is attached to the container
     indicating the date the capacitor was removed from service
     [761.65 (c) (1) (ii)] and placed into storage for disposal
     [761.65 (c) (8)] .   Each container or drum used to store
     leaking PCB Capacitors must be marked in accordance with EPA
     marking and labeling requirements [761.40(a)(1)].

     Nonleaking and structurally undamaged PCB large,  high-
     voltage capacitors may also be stored for more than 30 days
     on pallets next to a PCB storage facility which meets the
     requirements for storage for disposal.   This type of storage
     is permitted only when the storage facility has immediately
     available unfilled storage space equal  to 10 percent of the
     volume of capacitors and equipment stored outside the
     facility.  The capacitors stored outside the facility must
     be inspected for leaks weekly [761.65(c) (2)],  and a notation
     must be attached to each capacitor indicating the date the
     capacitor was removed from service [761.65(c)(1)]  and placed
     into storage for disposal  [761.65(c)(8)].  If a weekly
     visual inspection reveals a capacitor is leaking,  having the
     required available space within the storage area allows
     immediate containment of the leak by moving the capacitor
     into the storage area.


     DISPOSAL

     Large PCB Capacitors must be disposed of as follows:

          •    In an incinerator that complies with 40 CFR
               761.70.

          •    By an alternative EPA approved and permitted
               method in accordance with 761.60(e).


     RECORDKEEPING

     Owners or operators of facilities which use or store 50 or
     more large PCB Capacitors shall develop and maintain records
     on the disposition of the PCB Capacitors [761.180 (a)] .
     These records shall consist of  (1) the Annual Records and
     (2) the Annual Document Log which must be prepared each year
     by the facility and must be maintained for at least 3 years
     after the facility ceases using or storing PCBs and PCB
     Items in the prescibed quantities.  See Chapter XV,
     "Recordkeeping and Reporting" for a detailed discussion of
     Annual Document Logs and Annual Records.

Q8:  In my records, must I convert the weight of each PCB
     Capacitor to kilograms?


                               II-8

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A8:  Yes, the weight of PCB Capacitors is required to be
     converted to kilograms using the total weight of the PCB
     Capacitor and its contents.

Q9:  Do I have to keep written inspections for PCB Capacitors?

A9:  Except for capacitors temporarilly stored outside a storage
     facility, no recorded maintenance inspections are required
     for PCB Capacitors.  However, ruptures,  leaks, and other
     uncontrolled discharges from PCB Capacitors are considered
     improper disposal of PCBs.

     SPILLS

     Spills, leaks, and other uncontrolled discharges where the
     release results in any quantity of PCBs running off or about
     to run off the external surface of a large PCB Capacitor is
     considered improper disposal of PCBs.  The PCB Spill Cleanup
     Policy provides specific cleanup measures which, if followed
     explicitly, create a presumption against enforcement for
     penalties or further cleanup under TSCA.  See Chapter XIV on
     "PCB Spill Cleanup Policy"  for specific measures.

     PCB Spills involving 1 Ib.  or more of PCBs (generally 1 pint
     of Askarel) must be reported to the National Response Center
     (NRC)  at (800) 424-8802.  Spills involving 10 Ibs.  or more
     of PCBs  (generally 1 gallon of Askarel)  must also be
     reported to the appropriate regional EPA office.  Failure to
     notify the NRC under CERCLA can lead to civil penalties
     under Section 109 or, under Section 103, criminal fines and
     imprisonment.  Any spill should be reported when people or
     animals can come into direct and uncontrolled contact with
     PCBs.

     Measures must immediately be taken to control the spread of
     the spill.   Any threats to water should be given highest
     priority.  Water and other complicated spills should be
     cleaned up by trained personnel to levels set by the
     appropriate EPA Regional Administrator.   Organizations who
     frequently handle PCBs should develop spill contingency
     plans and conduct training for dealing with spills.

     Once a spill is contained,  cleanup measures can begin.  EPA
     requires cleanup of PCBs to different levels depending on
     spill location, the potential for exposure to residual PCBs
     remaining after cleanup, the concentration of PCBs initially
     spilled, and the nature and size of the population
     potentially at risk of exposure.  While the PCB spill
     cleanup policy applies to the majority of situations,
     exceptional circumstances may require additional cleanup at
     the direction of the EPA regional office.  A detailed
     description of the specific reporting,  cleanup,

                              II-9

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     recordkeeping, and post-cleanup sampling requirements is
     found in Chapter XIV on "PCB Spill Cleanup Policy."

     Other minor weeping from PCB Capacitor bushings and seams
     not covered by the spill policy is still considered improper
     disposal of PCBs and the provisions of the PCB Spill Cleanup
     Policy should be followed.

Q10: Do records and/or spill reports have to be kept for all PCB
     Capacitors which rupture?

A10: The PCB Cleanup Policy specifies certain recordkeeping when
     a PCB Capacitor ruptures or spills.  See the chapter on "PCB
     Spill Cleanup Policy" for specific spill recordkeeping.
                              11-10

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                     CAPACITORS
                      B. SMALL

Manufacturing  (page  11-12)

Processing  (page 11-12)

Distribution in Commerce  (Sale of Small  PCB  Capacitors)
  (page 11-12)

Marking/Labeling (page  11-13)

Use Conditions  (page 11-13)

Storage for Reuse  (page 11-13)

Storage for Disposal (page 11-13)

Disposal  (page 11-14)

Spills (page 11-14)
                       11-11

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PART B
                         SMALL CAPACITORS

     Small capacitors are those which contain less than 3 Ibs. of
     dielectric fluids.   They commonly contain between 0.1 and
     0.6 pound of PCBs and are used in fluorescent light
     ballasts, household appliances, and industrial equipment.
     In most applications, the equipment containing the small
     capacitor in its circuitry cannot function without it.

     Since these capacitors contain small quantities of
     dielectric fluid and significant amounts of absorbent
     material such as paper, and because many of these capacitors
     are encapsulated, large amounts of PCBs are not released
     from these capacitors during their use in appliances or
     other equipment containing small capacitors.  Therefore,
     exposure risks to humans,  food, feed,  water, or the
     environment from the use of these capacitors are generally
     low.  EPA has determined that the use of small capacitors
     containing PCBs is not unreasonable because of their low
     risk compared with the benefits from the use of millions of
     pieces of electronic equipment and consumer products;
     billions of dollars in replacement costs; and the lack of
     practical cost-effective risk reduction measures.
     MANUFACTURING

     The manufacture of PCBs, regardless of concentration, for
     use in small capacitors is prohibited [761.20(b)].
     PROCESSING

     The processing of PCBs, 50 ppm or greater, for use in small
     capacitors is prohibited without an EPA exemption
     [761.20 (c)] .   PCBs in any concentration may be processed
     (i.e., prepared and/or packaged for distribution in
     commerce) for purposes of disposal in accordance with the
     requirements of 761.60 [761.20(c)(2)  and  (4)].
     DISTRIBUTION IN COMMERCE (Sale of Small PCS Capacitors)

     The distribution in commerce of PCBs, 50 ppm or greater, for
     use in small capacitors is prohibited without an EPA
     exemption [761.20 (c)] .   PCBs at any concentration may be
     distributed in commerce for purposes of disposal in
     accordance with the requirements of 761.60 [761.20(c) (2) and
     (4)].   Disposal means the termination of the useful life of
     the PCB or PCB-Contaminated Capacitors.
                              11-12

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The distribution in commerce  (sale) of a small PCB Capacitor
for reuse or resale is allowed provided:

     •    the small capacitor was originally sold for use
          before July 1, 1979;

     •    the small capacitor is intact and nonleaking at
          the time of sale; and

     •    no PCBs are introduced into the small capacitor.


MARKING/LABELING

Small PCB Capacitors are not required to be marked or
labeled while in service or when removed from service for
disposal.

However, as of January 1, 1979, all PCB Equipment containing
a small PCB Capacitor was to be marked at the time of
manufacture with the statement:  "This equipment contains
PCB Capacitor(s)."  The mark was to be the same size as the
mark ML [761.40(d)].

Each small capacitor used in alternating circuits and each
fluorescent bulb manufactured between July 1, 1978 and July
1, 1998 that does not contain PCBs must be marked by the
manufacturer."No PCBs"  [761.40(g)].
USE CONDITIONS

EPA has not placed any restrictions on the use of small PCB
Capacitors.
STORAGE FOR REUSE

There are no restrictions or limitations on the storage for
reuse of small PCB Capacitors provided that the capacitors
are in a condition suitable for reuse.
STORAGE FOR DISPOSAL

There are no time restrictions or storage requirements on
the storage for disposal of small PCB Capacitors provided
that they are intact and nonleaking  [761.60(b)(6)].
However, a PCB Container (e.g., drum) which contains leaking
small PCB Capacitors must be marked, dated, and placed into
proper storage in accordance with the regulatory
requirements for a "PCB Container," and must be removed from

                         11-13

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storage and disposed of within one year  [761.65(a)].  Also,
any small PCB Capacitor owned by any person, who
manufactures, or at any time manufactured, PCB Capacitors or
PCB Equipment and acquired the PCB Capacitor in the course
of such manufacturing, must be stored in accordance with
761.65(b).
DISPOSAL

Small PCB Capacitors and Equipment containing small PCB
Capacitors may be disposed of as municipal solid waste
 [761.60(b) (2) (ii)], except that any small PCB Capacitor
owned by any person who manufactures or at any time
manufactured PCB Capacitors or PCB Equipment and acquired
the PCB Capacitors in the course of such manufacturing must
be disposed of as follows  [761.60(b)(2)(iv)]:

     •    In an incinerator that complies with 40 CFR
          761.70.

     •    By an alternative EPA approved and permitted
          method.

EPA recommends that where several small PCB Capacitors are
gathered together in drums or containers, that the disposal
method be determined by the combined amount of PCBs in the
several capacitors.  That is, if 3 Ibs. or more of PCBs are
contained in the several small capacitors, the Agency
recommends that the several small capacitors be disposed of
in accordance with the requirements for large capacitors.
Also, EPA encourages users of large amounts of small PCB
Capacitors to institute voluntary collection programs to
dispose of the small capacitors in PCB Incinerators.
 [Readers are advised to contact their PCB Regonal
Coordinator for the policy on the disposal of large numbers
of small capacitors.]
SPILLS

Spills, leaks, and other uncontrolled discharges where the
release results in any quantity of PCBs running off or about
to run off the external surface of a small PCB Capacitor is
considered improper disposal of PCBs.  The PCB Spill Cleanup
Policy provides specific cleanup measures which, if followed
explicitly, create a presumption against enforcement for
penalties or further cleanup.  See the chapter on "PCB Spill
Cleanup Policy" for specific measures.
                         11-14

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Other minor weeping from PCB Capacitor bushings and seams
not covered by the spill policy is still considered improper
disposal of PCBs and it is recommended that the provisions
of the Spill Cleanup Policy be followed.
                          11-15

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                           CHAPTER  III
                        HEAT TRANSFER AND
                        HYDRAULIC SYSTEMS
Manufacturing  (page III-l)

Processing  (page III-l)

Distribution in Commerce  (Sale of Heat Transfer  & Hydraulic
  Systems)  (page III-2)

Exemptions to Manufacture, Process, and Distribute  PCBs  in
  Commerce  (page III-2)

Marking/Labeling (page III-2)

Use and Servicing Conditions  (page III-3)

Storage for Reuse  (page III-4)

Storage for Disposal  (page III-4)

Disposal  (page III-4)

Recordkeeping  (page III-5)

Spills (page III-5)

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         - HEAT TRANSFER AND HYDRAULIC SYSTEMS  -
PCBs were manufactured for use in heat transfer  (Therminol-
66) and hydraulic  (Pydraul) systems that were utilized in a
variety of industries until 1972.  Heat transfer systems,
containing PCB fluids, were used in the inorganic chemical,
organic chemical, plastics and synthetics, and petroleum
refining industries.  The aluminum, copper, iron, and steel
forming industries used hydraulic systems with commercial
Aroclor PCB fluids.  High PCB levels apparently remained in
some systems until at least 1979.  In addition, some unknown
quantity of unused PCB fluids was probably kept by
facilities after production ceased in 1972 and was used for
topping-off hydraulic and heat transfer systems.

Under section 6(e)(2) of TSCA, EPA may authorize the use of
PCBs if the Agency finds that the use will not present an
unreasonable risk to human health or the environment.  EPA
has authorized the use of PCBs in heat transfer and
hydraulic systems at concentrations less than 50 ppm  (under
specific conditions) for the remainder of their useful lives
[761.30(d) and (e)].

Numerous substitutes for PCBs have been used in heat
transfer and hydraulic systems to lower the PCB
concentration levels to less than 50 ppm.  Included among
the chemical compounds used in non-PCB substitutes for
hydraulic fluid are phosphate esters, water/glycol
solutions, and water/oil emulsions.  In addition, various
non-PCB heat transfer fluids are available.  These include
modified esters,  synthetic hydrocarbons, polyaromatic
compounds, partially hydrogenated and mixed terphenyls, and
blends of diphenyls.
MANUFACTURING

The manufacture of PCBs, regardless of concentration, for
use in heat transfer and hydraulic systems is prohibited
without an EPA exemption [761.20(b)].
PROCESSING

The processing of PCBs, 50 ppm or greater, for use in heat
transfer and hydraulic systems is prohibited without an EPA
exemption [761.20(c)].  PCBs at concentrations less than 50
ppm may be processed for use in heat transfer and hydraulic
systems (under specific conditions)  in accordance with the
definition of "Excluded PCB Products" [761.3].   Also, PCBs
at any concentration may be processed (i.e.,

                         III-l

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prepared or packaged for distribution in commerce) for
purposes of disposal [761.20(c) (2) ].
DISTRIBUTION IN COMMERCE (Sale of Heat Transfer & Hydraulic
Systems)

The distribution in commerce (sale) of a heat transfer or
hydraulic system for reuse or resale which is contaminated
with PCBs (50 ppm or greater) is prohibited without an EPA
exemption [761.20(c)].  However, PCBs at any concentration
may be distributed in commerce for purposes of disposal
[761.20(c)(2)].  Disposal means the termination of the
useful life of the heat transfer or hydraulic system
[761.60(a) and (b)(3)].
EXEMPTIONS TO MANUFACTURE. PROCESS. AMD DISTRIBUTE PCBs IN
COMMERCE

Exemptions to manufacture, process, and distribute in
commerce PCBs in heat transfer and hydraulic systems or PCB
fluids for use in heat transfer and hydraulic systems may be
granted only by rulemaking on a case-by-case basis.  The EPA
Administrator may set terms and conditions for an exemption
and may grant an exemption for not more than one year.  EPA
interim procedural rules for processing and distribution in
commerce exemptions describe the required content of
processing and distribution in commerce exemptions petitions
and the procedures EPA follows in rulemaking on exemption
petitions.  Those rules were published in the Federal
Register of May 31, 1979  (44 FR 31558) and are codified at
40 CFR 750.30 through 750.41.
All heat transfer and hydraulic systems with PCB
concentrations of 50 ppm or greater must be marked in
accordance with EPA marking and labeling requirements
[761.40] .   All marks/labels must comply with EPA marking
formats which specify size, color, and design  [761.45].  All
marks/labels must be placed in a position on the exterior of
the system so that the mark/label can be easily read by
persons inspecting or servicing the system  [761.40(h)].  The
use of a heat transfer or hydraulic system with PCB
concentrations of 50 ppm or greater became unlawful after
July 1, 1984.
                         III-2

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USE AND SERVICING CONDITIONS

In 1979, EPA authorized the continued use of PCBs in
concentrations of 50 ppm or greater in heat transfer and
hydraulic systems in conjunction with a required retrofill
program.  These use authorizations expired on July 1, 1984.
EPA assumed that the conditions of those use authorizations,
which required retrofilling all contaminated systems with
non-PCB fluids, would reduce the PCB concentration levels in
all of those systems to below 50 ppm by July 1, 1984.

When the 50 ppm regulatory cutoff was overturned in 1984  (as
a consequence of EOF v. EPA),  the status of reducing PCB
concentrations in heat transfer and hydraulic systems to
less than 50 ppm was unclear.   The July 10, 1984 ruling
authorized the continued use of heat transfer and hydraulic
systems with PCB concentrations less than 50 ppm (under
specific conditions) for the remainder of their useful
lives.  However, the use of heat transfer and hydraulic
systems with PCB concentrations of 50 ppm or greater became
unlawful after July 1, 1984.

As of July 1, 1984, intentionally manufactured PCBs at
concentrations less than 50 ppm may be used in heat transfer
and hydraulic systems for the remainder of their useful
lives if the following requirements are met:

     •    Each owner of a heat transfer or hydraulic system
          that ever contained 50 ppm or greater PCBs was
          required to test his/her system for its PCB
          concentration by no later than November 1, 1979,
          and retest the system at least annually thereafter
          [761.30(d) and (e) ] .

     •    Within 6 months of a test indicating the system's
          fluid contains 50 ppm or greater PCBs, the system
          must be drained of PCBs and refilled with non-PCB
          fluid containing less than 50 ppm PCB [761.30(d)
          and  (e)].

     •    All subsequent required annual retests must be
          performed at least 3 months after the most recent
          fluid refilling.   Then, when a test shows that the
          PCB concentration in the system is less than 50
          ppm, further testing is no longer required
          [761.30(d) and (e)].

     •    After November 1, 1979, no heat transfer system
          that was used in the manufacture or processing of
          any food, drug, cosmetic or device, as defined in
          Section 201 of the Federal Food, Drug, and       *
                         III-3

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               Cosmetic Act, could contain transfer fluid with 50
               ppm or greater PCBs [761.30(d)(3)].

          •    Servicing, including topping-off, heat transfer
               and hydraulic systems with fluids containing PCS
               concentrations 50 ppm or greater is prohibited
               [761.30(d) and (e)].

          •    All testing data must be retained for 5 years
              •after the heat transfer or hydraulic system
               reaches less than 50 ppm PCBs [761.30(d)&(e)].

Ql:  Do VitonR elastomer gloves  still  have to be provided by
     system owners and worn by system maintenance personnel?

Al:  EPA has concluded that the VitonR glove  requirement  is not
     necessary to protect against any unreasonable risks
     presented by the continued use of authorized (less than 50
     ppm) heat transfer and hydraulic systems.   Consequently, EPA
     amended the July 10, 1984 rule in the Federal Register of
     June 27, 1988, by deleting the VitonR glove requirements
     from the use authorizations.  The use of impermeable gloves
     to prevent dermal contact with PCB containing fluids may be
     warranted, but the choice of such protection will be
     dependent upon such factors as duration of exposure,
     concentration of PCBs, and the permeability of the glove
     material.
     STORAGE FOR REUSE

     The continued use and storage for reuse of heat transfer and
     hydraulic systems containing 50 ppm or greater PCBs is
     prohibited without an EPA exemption [761.20(a)].

     EPA has not placed any restrictions on the storage for reuse
     of non-PCB  (less than 50 ppm) heat transfer and hydraulic
     systems.
     STORAGE FOR DISPOSAL

     EPA has not placed any restrictions on the storage for
     disposal of non-PCB (less than 50 ppm) heat transfer and
     hydraulie systems.
     DISPOSAL

     EPA has not placed any restrictions on the disposal of non-
     PCB (less than 50 ppm) heat transfer and hydraulic systems.
     However, non-PCB fluids  (2-49 ppm) generated from the

                              III-4

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draining of a non-PCB heat transfer or hydraulic system can
only be burned for energy recovery in accordance with EPA
restrictions on burning used oils as outlined under
761.20(e)(3).  See the chapter on "Excluded PCB Products"
for a detailed discussion on burning non-PCB used oils.
RECORDKEEPING

Each owner of a heat transfer or hydraulic system that ever
contained PCBs at concentrations of 50 ppm or greater must
maintain all servicing and retrofill records as well as all
PCB testing data for 5 years after the PCB concentration in
the system was reduced to less than 50 ppm  [761.30(d)(5) and
 (e) (5)] .

Records should be maintained pursuant to 761.180 for all PCB
liquids  (50 ppm or  greater) which are drained from heat
transfer and hydraulic systems for disposal.  In addition,
all owners of heat transfer and hydraulic systems who at one
time have stored at least 45 kilograms (99.4 pounds) of PCB
liquids in PCB Containers must develop and maintain Annual
Document Logs and Annual Records for each calendar year
 [761.180(a)].  See Chapter XV, "Recordkeeping and Reporting",
for a detailed discussion of Annual Document Logs and Annual
Records.
SPILLS

Spills, leaks, and other uncontrolled discharges where the
release results in any quantity of PCBs ay concentrations of
50 ppm or greater running off or about to run off the
external surface of a heat transfer or hydraulic system is
considered improper disposal of PCBs.  The PCB Spill Cleanup
Policy provides specific cleanup measures which, if followed
explicitly, create a presumption against enforcement of
penalties of further cleanup.  See the chapter on "PCB Spill
Cleanup Policy" for specific measures.

Other minor weeping from heat transfer and hydraulic systems
with PCB concentrations 50 ppm or greater is still
considered improper disposal of PCBs and it is recommended
that the provisions of the Spill Cleanup Policy be followed.
                         III-5

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                            CHAPTER IV






                      NATURAL GAS  PIPELINES








Manufacturing  (page  IV-1)



Processing  (page  IV-1)



Distribution in Commerce  (page  IV-1)



Use Conditions  (page  IV-2)



Marking/Labeling  (page IV-2)



Storage for Disposal  (page  IV-2)



Disposal  (page IV-3)



Air Compressors  (page IV-4)



Reuse of Pipe at  Less than  50 ppm  PCBs  (page  IV-4)

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                - NATURAL GAS PIPELINES  -
PCB contamination in natural gas pipeline air compressors,
natural gas compressors, and natural gas pipeline liquids  is
believed to have occurred through several sources.  The
major sources of contamination are thought to be:
lubricating oils  (Turbinol) used in the natural gas air
compressors; "fogging" of the pipe lines with an oil vapor
to minimize the entrainment of dust and other particles  in
the pipeline system and migration of PCBs from contaminated
lines into other systems.  By the 1960s, fogging of
pipelines was virtually nonexistent due to improved dry
filters and the replacement of cast iron pipe with welded
steel pipes.  PCBs have not been used as lubricating oils  in
compressors since the 1970s.  Note:  EPA continues to
develop guidance for the practical use and disposal of PCB
contaminated pipelines.  The Federal Register should be
reviewed for any new information regading pipelines and
related facilities.
MANUFACTURING

The manufacture of PCBs, regardless of concentration, for
use in natural gas pipelines is prohibited without an EPA
exemption  [761.20(b)].
PROCESSING

The processing of PCBs, 50 ppm or greater, for use in
natural gas pipelines is prohibited without an EPA exemption
[761.20 (c)].  However, PCBs at concentrations less than 50
ppm may be processed for use in natural gas pipelines  (under
limited specific conditions) in accordance with the
definition of "Excluded PCB Products"  [761.3].  Also, PCBs
at any concentration may be processed  (i.e., prepared and/or
packaged for distribution in commerce) for purposes of
disposal in accordance with the requirements of 761.60
[761.20(c) (2)] .
DISTRIBUTION IN COMMERCE

The distribution in commerce of PCBs, 50 ppm or greater, for
use in natural gas pipelines is prohibited without an EPA
exemption  [761.20 (c)].  However, pipes and other reusable
materials from natural gas pipelines historically with PCB
concentrations less than 50 ppm may be distributed in
commerce for reuse (under specific conditions)  in accordance
with the definition of "Excluded PCB Products"  [761.3].

                          IV-1

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However, EPA reommends that any such pipe should not be used
in connection with water supply sources, drainage ditches,
or in other circumstances where food or feed could become
contaminated.  While such applications may not violate TSCA,
they may result in potential civil liability for damages for
the supplier or violations of other Federal or State
regulations.  PCBs at any concentration may be distributed
in commerce for purposes of disposal in accordance with the
requirements of 761.60 [761.20(c)  (2) ] .
USE CONDITIONS

EPA has determined that the use of PCBs in natural gas
pipeline compressors  (compressors used for the transmission
of gas) and in the liquid found in natural gas pipelines at
concentrations of less than 50 ppm (not as a result of
dilution) does not present an unreasonable risk to human
health or the environment.  Therefore, EPA has authorized
the continued use of PCBs at concentrations less than 50 ppm
in natural gas pipeline compressors and liquids indefinitely
[761.30(i)], provided that the compressors and the pipelines
are marked/labeled in accordance with EPA marking
requirements  [761.45(a)].
MARKING/LABELING

Natural gas pipeline compressors and pipelines which are
contaminated with PCBs, regardless of concentration, must be
marked/labeled in compliance with EPA marking requirements
[761.30(i)] .  All marks/labels must comply with EPA marking
formats which specify size, color, and design [761.45].  All
marks/labels must be placed in a position on the compressor
so that the mark can be easily read by persons inspecting or
servicing the compressor  [761.40(h)].
STORAGE FOR DISPOSAL

Liquids and/or solids  (e.g., rags, dirt, debris, etc.)
contaminated with PCBs  (50 ppm or greater) must be placed
into proper containers  for storage for disposal.  All PCB
waste  (50 ppm or greater) generated from natural gas
pipelines  (such as used pipe, liquids contaminated with PCBs
and solids/debris contaminated with PCBs) must be stored in
accordance with EPA storage requirements under 761.65.
The above PCB Articles  (used pipe) and PCB Containers
(liquids and/or solids) 50 ppm or greater must be dated when
placed into storage for disposal  [761.65(c)(8)] and must be
removed from storage and disposed of within one year
[761.65(a)].

                          IV-2

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The facility used to store PCB waste  (50 ppm or greater)
generated from natural gas pipelines must comply with the
storage for disposal requirements under 761.65(b)(1).  See
the chapter on "PCB Storage Requirements" for specific
requirements.

Nonleaking PCB Articles may be stored temporarily by the
generator in an area that does not comply with the
requirements for a PCB storage facility for up to 30 days
from the date of their removal from service for disposal,
provided that a notation is attached to each article
indicating the dates the article was removed from service
[761.65(c) (1) (i)], and placed into storage for disposal
[761.65(c) (8)] .
DISPOSAL

All PCB waste  (50 ppm or greater) including used pipe,
condensate, and other liquids and solids contaminated with
PCBs at levels 50 ppm or greater, must be disposed of in
accordance with EPA disposal requirements under 761.60.

All condensate removed from the pipe is liquid PCBs and must
be disposed of according to its concentration.  At
concentrations less than 50 ppm, liquid PCBs are not
regulated for disposal under TSCA unless such PCBs are
diluted to circumvent disposal regulations  [761.1(b).
Disposal of condensate containing less than 50 ppm PCB
(undiluted) is regulated under RCRA.  Liquid PCBs in
concentrations between 50 and 500 ppm must be incinerated,
disposed of in a TSCA chemical waste landfill, a high
efficiency boiler, or by an alternative disposal method
[761.60(a)(1), (4) and (e) ].

Pipeline is regarded as a "PCB Article" as defined under
761.3.  It must be disposed of according to its
concentration of PCBs under 761.60(b)(5).   Accordingly,
removed pipe with PCB concentrations greater than 500 ppm
must be disposed of in a TSCA incinerator, a TSCA chemical
waste landfill, or by an alternative disposal method
[761.60(e)].  Pipeline with concentrations greater than 500
ppm may not be abandoned.  Any pipe with a PCB concentration
between 50 and 500 ppm is not regulated for disposal after
all free flowing liquid has been removed.   This means that
the pipe can be either abandoned in place, disposed of in a
municipal waste landfill, or smelted for recycling.
                          IV-3

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     AIR COMPRESSORS

     PCBs were used in lubricating oils that were added to air
     compressors in the 1970s and early 1980s.  These air
     compressors were used to start natural gas compressors and
     consisted of separate piping and receiver tanks as part of
     the system.  The air compressor system is regarded by EPA
     for regulatory purposes as distinct from the natural gas
     compressor itself.

     EPA views the PCB contamination in air compressor system
     piping and receiving tanks as PCB contamination that results
     because of a spill from or in proximity to a PCB Item.
     Accordingly, if the spill is cleaned up pursuant to EPA
     regional standards, the use of the pipes and tanks would be
     authorized under 761.20 (c) (5).  Otherwise the contamination
     constitutes an unauthorized use.
     REUSE OF PIPE AT LESS THAN 50 PPM PCBs

     The reuse of natural gas pipe at less than 50 ppm PCBs is
     conditioned on the assumption that the three caveats in the
     definition of"Excluded PCB Products" (section 761.3) are
     met.   These are that the products or source of the products
     containing less than 50 ppm PCBs were (1)  legally
     manufactured, processed, distributed in commerce, or used
     before October 1, 1984, (2)  legally manufactured, processed,
     distributed in commerce, or used pursuant to authority
     granted by EPA regulation, by exemption petition, by
     settlement agreement, or pursuant to other Agency-approved
     programs, and (3) not the result of dilution, or leaks or
     spills of PCBs at concentrations over 50 ppm.

QA:  Once it is determined that the natural gas pipe I own is
     less than 50 ppm PCBs, and not as a result of dilution, may
     I sell this pipe for another use?

Al:  Yes,  if it has been determined that the pipe was
     historically contaminated with less than 50 ppm PCBs or
     reduced to less than 50 ppm PCBs through an authorized
     process.  If the pipeline system has an interconnection with
     another pipeline system that has been contaminated at 50 ppm
     or greater, the pipeline is presumed to have PCB
     contamination as a result of dilution and may not be reused.
     If this is the case, the pipeline company has two options:
     (1) decontaminate the pipeline pursuant to a consent decree
     or (2) obtain an approval for an alternate disposal
     technology permit.  If it is determined that the pipe may be
     sold for another use under the TSCA regulations, you are not
     relieved of any additional requirements under other Federal
     or State statutes.  For example, if the pipe were to be used

                               IV-4

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as conduits for drinking water they would have to be cleaned
to a level of non-detect according to the provisions of the
Safe Drinking Water Act.
                         IV-5

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                            CHAPTER V
                          ELECTROMAGNETS
                           SWITCHES AND
                        VOLTAGE REGULATORS
Manufacturing  (page V-l)

Processing  (page V-l)

Distribution in Commerce  (Sale of Electromagnets,  Switches,  and
  Voltage Regulators)  (page V-2)

Exemptions to Manufacture, Process, and Distribute PCBs  in
  Commerce  (page V-3)

Marking/Labeling  (page V-4)

Phaseout Requirements  (page V-4)

Use Conditions  (page V-4)

Servicing and Reclassification Conditions  (page V-4)

Storage for Reuse  (page V-8)

Storage for Disposal  (page V-8)

Disposal (page V-9)

Recordkeeping  (page V-10)

Spills  (page V-ll)

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  - ELECTROMAGNETS.  SWITCHES,  AND VOLTAGE REGULATORS -
Electromagnets are primarily used over conveyer belts to
remove iron from nonmagnetic commodities.  Electromagnets
designed to contain PCBs are used in areas such as coal
mines, coal preparation plants, and coal-fired generating
stations.

Voltage regulators and switches  (including sectionalizers
and motor starters) are used by electric utilities and
industry to control, transmit, and distribute electric power
efficiently.  Almost all of this electrical equipment is
mineral oil-filled and not designed to contain PCB
dielectric fluid.  However, many voltage regulators,
switches, and also electromagnets have become contaminated
with PCBs through historic maintenance and servicing
activities.  In addition, voltage regulators are
particularly susceptible to PCB contamination as they often
contain a small PCB starter capacitor which, if it leaks or
ruptures, is likely to contaminate the regulator's mineral
oil dielectric fluid.

Electromagnets, switches, and voltage regulators which
contain mineral oil dielectric fluid are not required to be
tested for PCBs.  It is very important to note, however,
that oil-filled electromagnets, switches, and voltage
regulators, whose PCB concentration is unknown, must be
assumed to be PCB-Contaminated Electrical Equipment (50-499
ppm) and must be treated as such.  This "assumption rule"
effectively applies to all regulatory requirements relating
to the equipment including: use and servicing, leaks and
spills, sale for reuse, storage for disposal, and disposal.
MANUFACTURING

The manufacture of PCBs, regardless of concentration, for
use in electromagnets, switches, and voltage regulators is
prohibited without an EPA exemption [761.20(b)].
PROCESSING

The processing of PCBs, 50 ppm or greater, for use in
electromagnets, switches, or voltage regulators is
prohibited without an EPA exemption [761.20 (c)] .   However,
PCBs at concentrations less than 50 ppm may be processed for
use in electromagnets, switches, and voltage regulators
(under specific conditions) in accordance with the
definition of "Excluded PCB Products"  [761.3].  Also, PCBs
at any concentration may be processed (i.e.,  prepared and/or

                          V-l

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     packaged for distribution in commerce)  for purposes of
     disposal [761.20(c)(2)].


     DISTRIBUTION IN COMMERCE (Sale of Electromagnets. Switches.
     and Voltage Regulators)

     The distribution in commerce of PCBs, 50 ppm or greater, for
     use in electromagnets, switches, and voltage regulators is
     prohibited without an EPA exemption  [761.20 (c)].  However,
     PCBs at concentrations less than 50 ppm may be distributed
     in commerce for use in electromagnets,  switches, and voltage
     regulators (under specific conditions)  in accordance with
     the definition of "Excluded PCB Products"  [761.3].   Also,
     PCBs at any concentration may be distributed in commerce for
     purposes of disposal  [761.20(c) (2)].  Disposal means the
     termination of the useful life of the PCB or PCB-
     contaminated electromagnet, switch, or voltage regulator.

     The distribution in commerce (sale) of electromagnets,
     switches, and voltage regulators which contain PCBs in
     concentrations of 50 ppm or greater  (known or assumed) for
     purposes of reuse or resale is allowed provided:

          •    the unit was originally sold for use before
               July 1,  1979;

          •    the unit is intact and nonleaking at the time of
               sale; and

          •    no PCBs are introduced into the unit.

Ql:  Does this mean that I can sell a PCB or PCB-contaminated
     voltage regulator, switch, or electromagnet?

Al:  Yes.  If the equipment was originally sold for use before
     July 1, 1979, and is now being sold for reuse or resale
     (i.e., continued use).  Also, the unit must be intact and
     nonleaking.  EPA recommends that the buyer be advised that
     he is purchasing a PCB or PCB-contaminated unit.

Q2:  What does intact and nonleaking mean?

A2:  Intact and nonleaking means that the equipment is
     structurally sound with all fluid intact and there are no
     PCBs on the external surface of the equipment.

Q3:  Can I sell drained PCB-contaminated voltage regulators
     and/or switch carcasses  (known or assumed  50-499 ppm) to a
     rebuilder for reuse as parts in repair and remanufacturing
     activities?
                               V-2

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A3:  No.  Selling drained  (50-499 ppm) carcasses for reuse is an
     unauthorized distribution in commerce of PCBs and is
     prohibited without an EPA exemption.  On the other hand,
     non-PCB carcasses  (less than 50 ppm) can be sold for reuse
     (under specific conditions)  in accordance with the
     definition of "Excluded PCB Products" [761.3] .

Q4:  Can I sell drained PCB-contaminated voltage regulators
     and/or switch carcasses (known or assumed -50-499 ppm) to a
     scrap or salvage dealer for metals recovery?

A4:  Yes.  The sale of drained (50-499 ppm)  carcasses for
     scrapping or salvaging is generally considered distribution
     in commerce for purposes of disposal and is allowed with
     certain limitations.  To qualify as disposal,  the scrapping
     practice must be one which will "...terminate the useful
     life of PCBs or PCB Items"  [761.3]; or,  in other words, will
     destroy any residual PCBs found in the drained carcasses.
     Salvaging aimed at reclamation of the metals found in the
     case and coil generally constitutes disposal,  because any
     residual PCBs are destroyed by the high temperatures
     employed in the smelting process.  However, where salvaging
     consists of disassembling the drained equipment to obtain
     parts for reuse in other equipment, the useful life of the
     equipment has not been fully terminated and thus is not
     considered disposal.  In sum, the scrapping/salvaging of 50-
     499 ppm drained equipment is unregulated to the extent that:
     (1) scrapping practices do not result in leaks, spills, or
     other uncontrolled discharges of PCBs,  and  (2)  any PCB-
     contaminated components are not reintroduced into commerce.


     EXEMPTIONS TO MANUFACTURE. PROCESS. AND DISTRIBUTE PCBs IN
     COMMERCE

     Exemptions to manufacture, process, and distribute in
     commerce PCBs in electromagnets, switches, and voltage
     regulators may be granted only by rulemaking on a case-by-
     case basis.  The EPA Administrator may set terms and
     conditions for an exemption and may grant an exemption for
     not more than one year.  EPA interim procedural rules for
     processing and distribution in commerce exemptions describe
     the required content of processing and distribution in
     commerce exemptions petitions and the procedures EPA follows
     in rulemaking on exemption petitions.  Those rules were
     published in the Federal Register of May 31, 1979 (44 FR
     31558)  and are codified at 40 CFR 750.30 through 750.41.
                               V-3

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MARKING/LABELING

Marking/labeling of electromagnets, switches, and voltage
regulators, regardless of PCB concentration, is not
required.
PHASEOUT REQUIREMENTS

After October 1, 1985, the use and storage for reuse of any
PCB electromagnet  (500 ppm or greater) which poses an
exposure risk to food or feed is prohibited   [761.30(h)(1)].
It is the owner's responsibility to determine whether the
electromagnet poses an exposure risk to food or feed.
USE CONDITIONS

PCB and PCB-contaminated electromagnets, switches, and
voltage regulators may be used for the remainder of their
useful lives.  No recorded maintenance inspections are
required for PCB or PCB-contaminated electromagnets,
switches, or voltage regulators.
SERVICING AND RECLASSIFICATION CONDITIONS

The processing of PCB and PCB-contaminated electromagnets,
switches, and voltage regulators is limited to servicing
activities.  These servicing activities include: draining
and refilling, topping off, repairing, and retrofilling for
reclassification  [761.30(h) (2)].  Note:  In the Federal
Register of Novemeber 18, 1993  (58 FR 60970) EPA proposed
amendments to the reclassification provisions for this type
of equipment.

The processing and distribution in commerce of PCBs, 50 ppm
or greater, for purposes of servicing and repairing a
customer's equipment is prohibited without an EPA exemption
[761.30(h) (2) (vii)] .  However, an exemption is not required
to service your own PCB or PCB-contaminated electromagnet,
switch, or voltage regulator with the PCB or PCB-
contaminated fluid you already own, in accordance with the
regulations.  Also, you can service a customer's unit if you
use non-PCB or PCB-free fluid; and, you are allowed to
refill a customer's unit with the same fluid that came out
of the unit, regardless of PCB concentration.

The processing  (servicing) for non-PCB electromagnets,
switches, and voltage regulators with non-PCB fluids and/or
components is allowed without restriction.
                          V-4

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     A PCB electromagnet, switch, or voltage regulator may  be
     reclassified to a PCB-contaminated or non-PCB unit by
     draining, refilling, and otherwise servicing the unit.  In
     order to reclassify, the unit's dielectric  fluid must
     contain less than 500 ppm PCB  (for conversion to PCB-
     contaminated level) or  less than  50 ppm PCB  (for conversion
     to non-PCB level) after a minimum of 3 months of in-service
     use subsequent to the last servicing conducted  for the
     purposes of reducing the PCB concentration  in the unit.   In-
     service means that the  unit is used electrically under
     loaded conditions  [761.30(h)(2)(v)].

     The following conditions also apply to service  activities:

          •    Removing the  coil from  PCB electromagnets,
               switches, or  voltage regulators  (500  ppm or
               greater) is prohibited  [761.30(h)(2)(i)].

          •    PCB-contaminated electromagnets,  switches, and
               voltage regulators may  be serviced  (including
               rebuilding) only with dielectric  fluid containing
               less than 500 ppm PCB  [761.30(h) (2) (ii)] .

          •    PCBs, 50 ppm  or greater, removed  during servicing
               must be either reused as dielectric fluid or
               disposed of in accordance with EPA requirements
               [761.30(h) (2) (iii)] .

          •    PCBs from PCB electromagnets, switches, and
               voltage regulators must not be mixed  with or added
               to dielectric fluid from PCB-contaminated
               electromagnets, switches, and voltage regulators
               [761.30(h)(2)(iii)].

          •    If dielectric fluid containing less than 500 ppm
               PCBs is mixed with fluid containing 500 ppm  or
               greater PCBs, then the  resulting mixture must not
               be used as dielectric fluid in any electrical
               equipment.  The entire  mixture must be considered
               to be greater than 500  ppm PCBs and must be
               disposed of in an incinerator that meets EPA
               requirements  [761.30(h)(2)(iv)].

          •    Any dielectric fluid containing 50 ppm or greater
               PCBs used for servicing electromagnets, switches,
               or voltage regulators must be stored  in accordance
               with the storage for disposal requirements [761.30
               (h) (2) (vi)] .

Q5:  Is an electromagnet, switch, or voltage regulator required
     to reach 50° Centigrade during the 90-day in-service period
     for proper reclassification?

                               V-5

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A5:  No.  Unlike transformers, there is no 50° Centigrade
     requirement for reclassification of these types of equipment
     [761.30(h)(2)(v)].

Q6:  Do electromagnets,  switches, and voltage regulators have to
     be tested to determine their PCB concentration?  If not, how
     can I determine the equipment's classification?

A6:  The regulations do not require that these types of equipment
     be tested to determine the PCB concentration in their fluid.
     However, in the absence of a test, certain assumptions
     should be made about the equipment.  For example, if the
     nameplate indicates that the equipment contains PCB
     dielectric fluid, or, if there is any reason to believe that
     the equipment at one time contained PCB dielectric fluid,
     or, if there is no nameplate on the equipment, then the
     equipment must be assumed to be PCB (500 ppm or greater).
     Electromagnets, switches, and voltage regulators which
     contain mineral oil dielectric fluid and whose PCB
     concentration is unknown, must, be assumed to be PCB-
     Contaminated Electrical Equipment  (50-499 ppm) and must be
     treated as such.  These "assumption rules" effectively apply
     to all regulatory requirements relating to the equipment
     including: use and servicing, leaks and spills, sale for
     reuse, storage for disposal, and disposal.

Q7:  Can screening tests, such as Clor-n-Oil™, be used to
     determine the PCB concentration of an electromagnet, switch,
     or voltage regulator?  If so, can  "Certified Non-PCB" labels
     be used to classify electromagnets, switches, or voltage
     regulators based upon a screen test?

A7:  Currently, the regulations do not require that any
     particular testing method be utilized when determining the
     PCB concentration in electromagnets, switches, or voltage
     regulators.  However, owners of these types of equipment
     should prudently scrutinize PCB testing options, as there
     are significant differences in the integrity and accuracy of
     various testing methods.  It should be noted that, in most
     situations, EPA will utilize laboratory gas-chromatography
     (GC) testing to determine PCB concentrations during facility
     inspections.  EPA recommends that owners of electrical
     equipment choose testing methods, and practice sampling
     procedures, which are analytically accurate, reproducible,
     assure quality control, and are certifiable.  EPA does not
     recognize the results of field screening test kits.

     The use of non-PCB labels is unregulated by EPA.  That is to
     say, there are no prohibitions or requirements to place non-
     PCB labels on electromagnets, switches, or voltage
     regulators.  However, if non-PCB labels are used to indicate
     the classification of equipment, then owners should be able

                               V-6

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     to provide documentation such as test results or
     manufacturer's letters along with historic service records
     which will substantiate the non-PCB classification.  A
     criminal action could be persued for someone intentionally
     using non-PCB labels on known or assumed PCB Items.

Q8:  Can I batch test oil samples from several electromagnets,
     switches, and/or voltage regulators and classify each unit
     based upon one test result?

A8:  The only place in the regulations where "batch testing" is
     specifically allowed is under testing procedures for
     disposal of PCBs [761.60(g) ] .   However, batch testing to
     classify equipment for continued use of PCBs is also
     allowable provided that dilution does not take place.  That
     is, mineral oil that is assumed or known to contain 50 ppm
     or greater PCBs must not be mixed with mineral oil that is
     known or assumed to contain less than 50 ppm PCBs to reduce
     the concentration of PCBs in the batch.  It should also be
     noted that while batch testing is allowed, it does not
     relieve the owner from any regulatory requirements if an
     individual unit unknowingly contains a higher concentration
     of PCBs than was detected in the batch test.

Q9:  Many mineral oil-filled voltage regulators and switches have
     no information on their nameplate indicating that they do,
     in fact, contain mineral oil dielectric fluid.  Without this
     nameplate information, am I required to assume that these
     units are "PCB" classification (500 ppm or greater)?

A9:  The regulations allow "oil-filled", electrical equipment
     whose PCB concentration is unknown to be assumed less than
     500 ppm  (PCB-contaminated, 50-499 ppm).  EPA has received
     numerous comments from the electric utility industry and
     others indicating that significant numbers of mineral oil-
     filled voltage regulators and switches have no nameplate
     information about their dielectric fluid.   In the absence of
     this information, one could interpret the regulations to
     require that these units be assumed "PCB"  instead of "PCB-
     contaminated."  However, almost all voltage regulators and
     switches are,  in fact, mineral oil-filled and not designed
     to use PCB dielectric fluid.   Consequently, it is reasonable
     to assume that voltage regulators and switches are "oil-
     filled" unless: (1)  the nameplate indicates that the
     equipment contains PCB dielectric fluid, or (2)  if there is
     any reason to believe that the equipment at one time
     contained PCB dielectric fluid.
                               V-7

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     STORAGE FOR REUSE

     Voltage regulators and switches containing PCBs at any
     concentration may be stored for reuse.  There are no time
     limitations on this storage; however, voltage regulators
     and/or switches  (50 ppm or greater) which are stored for
     reuse must be in a condition suitable for reuse.  These
     units are considered by EPA to be in-service for purposes of
     the regulations.

     Electromagnets containing PCBs at any concentration may also
     be stored for reuse indefinitely provided that they are in a
     condition suitable for reuse; except that, the storage for
     reuse of a PCB electromagnet which poses an exposure risk to
     food or feed is prohibited after October 1, 1985.

Q10: How long can I keep a "burned-out" or "nonfunctional"
     electromagnet, switch, or voltage regulator in storage for
     reuse if I plan on repairing it and using it later?

A10: EPA does not require nonfunctional electromagnets, switches,
     or voltage regulators (regardless of PCB concentration) to
     be placed into "storage for disposal" if you intend to
     repair and reuse the item.  However, EPA may have grounds to
     enforce against lengthy "storage for reuse" of equipment
     which is not reasonably expected to be placed back into
     service.  In other words,  while there are no explicit
     requirements for, or restrictions on, the storage for reuse
     of equipment which can be repaired, the owner should be able
     to demonstrate good faith compliance with the intent of the
     storage for disposal requirements and complete any required
     servicing or repairs within the same one year limitation
     associated with PCB disposal.


     STORAGE FOR DISPOSAL

     All PCB and PCB-contaminated electromagnets, switches, and
     voltage regulators must be dated when placed into storage
     for disposal  [761.65(c)(8)]  and must be removed from storage
     and disposed of within one year [761.65(a)].

     The facility used to store PCB and PCB-contaminated
     electromagnets, switches,  and/or voltage regulators must
     comply with the "storage for disposal" requirements  [761.65
     (b)(1)].  See the chapter on "PCB Storage Requirements" for
     specific requirements.

     Nonleaking PCB and PCB-contaminated electromagnets,
     switches,  and voltage regulators may be stored temporarily
     by a generator in an area that does not comply with the
     requirements for a PCB storage facility for up to 30 days

                               V-8

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from the date of their removal from service for disposal
provided that a notation is attached to each unit indicating
the dates the equipment was removed from service
[761.65(c) (1)], and placed into storage for disposal
[761.65(c)(8)].

Leaking PCB and PCB-contaminated electromagnets, switches,
and voltage regulators which are placed in appropriate PCB
Containers  [761.65 (c) (6)] with sufficient sorbent materials
to absorb any liquid PCBs, may also be temporarily stored
for up to 30 days provided that a notation is attached to
the container indicating the dates the equipment was removed
from service  [761.65 (c) (1) (ii)], and placed into storage for
disposal  [761.65(c)(8)].  Each container or drum used to
store leaking PCB Items must be marked in accordance with
EPA marking and labeling requirements  [761.40  (a) (1)] .

Nonleaking and structurally undamaged PCB-contaminated
electromagnets, switches, and voltage regulators that have
not been drained of free-flowing dielectric fluid may also
be stored temporarily on pallets next to a PCB storage
facility which meets the requirements for storage for
disposal.  This type of storage is permitted only when the
storage facility has immediately available unfilled storage
space equal to 10 percent of the volume of the equipment
stored outside the facility.  The equipment stored outside
the facility must be inspected for leaks weekly
[761.65(c) (2)], and a notation must be attached to each unit
indicating the dates the equipment was removed from service
[761.65 (c) (1)] and placed into storage for disposal  [761.65
(c) (8)] .
DISPOSAL

PCB electromagnets, switches, and voltage regulators must be
disposed of as follows:

     •    In an incinerator that complies with 40 CFR
          761.70.

     •    In a chemical waste landfill provided that all
          free-flowing liquid PCBs have been thoroughly
          drained from the equipment.  The PCB liquids that
          are removed  (including any flushing solvent) must
          be disposed of in an incinerator that complies
          with 40 CFR 761.70, or by an alternative EPA
          approved and permitted method in accordance with
          761.60 (e) .

PCB-contaminated electromagnets, switches, and voltage
regulators must be disposed of as follows:

                          V-9

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          •    By draining all free-flowing liquid from the
               equipment and disposing of the liquid in an
               incinerator that complies with 40 CFR 761.70, in a
               chemical waste landfill that complies with 761.75,
               in an approved high efficiency boiler that
               complies with 761.60(a) (2) (iii),  or by an
               alternative EPA approved and permitted method that
               complies with 761.60(e).   The disposal of the
               drained equipment carcass is not regulated [761.60
               (b) (5) (ii)] .   (See Distribution in Commerce.)

     Non-PCB electromagnets, switches, and voltage regulators
     (less than 50 ppm PCB)  may be disposed of with the following
     considerations:

          •    There are no PCB disposal requirements for non-PCB
               electromagnets,  switches, and voltage regulators.
               However, certain reuse restrictions apply to the
               less than 50 ppm PCB fluid.   Waste oil with any
               detectable concentration of PCBs cannot be used as
               a sealant, coating, or dust control agent
               [761.20(d)];  and also, can only be burned for
               energy recovery in specific combustion facilities
               described in 761.20(e)(1).  See the Chapter XIII
               on "PCB Disposal Requirements" for a detailed
               discussion of the disposal of non-PCB waste oils.

Qll: Do PCB electromagnets,  switches, and voltage regulators have
     to be filled with a solvent for 18 hours and redrained
     before transporting the carcass to a chemical waste
     landfill?

All: No.  Unlike PCB Transformers, there is no requirement to
     fill and flush PCB electromagnets,  switches, or voltage
     regulators with solvent prior to disposal of the drained
     carcass in a chemical waste landfill.   However, owners of
     PCB Equipment should take appropriate steps to insure that
     all free-flowing liquid PCBs have been extracted from the
     carcass.
     RECORDKEEPING

     Testing data, inventories, servicing and reclassification
     records, spill reports, and disposal records should be
     maintained for all PCB and PCB-contaminated electromagnets,
     switches, and voltage regulators.  Under specific quantity
     guidelines,  [761.180(a)]  records are required to be kept to
     form the basis of an Annual Document Log and Annual Record
     which must be prepared each year and maintained for at least
     3 years after the facility ceases using or storing PCBs and
     PCB Items.  Disposers and commercial storers of all PCB and

                               V-10

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PCB-contaminated electromagnets, switches, and voltage
regulators are required to keep records pursuant to
761.180(b).  See Chapter XV, "Recordkeeping and Reporting"
for a detailed discussion of other recordkeeping
requirements.
SPILLS

Spills, leaks, and other uncontrolled discharges where the
release results in any quantity of PCBs running off or about
to run off the external surface of a PCB or PCB-contaminated
electromagnet, switch, or voltage regulator is considered
improper disposal of PCBs.  The PCB Spill Cleanup Policy
provides specific cleanup measures which, if followed
explicitly, create a presumption against enforcement for
penalties or further cleanup.  See the chapter on "PCB Spill
Cleanup Policy" for specific measures.

PCB spills involving 1 Ib. or more of PCBs (generally 1 pint
of Askarel) must be reported to the National Response Center
(NRC) at (800) 424-8802.  Spills involving 10 Ibs.  or more
of PCBs (generally 1 gallon of Askarel) must be reported to
the appropriate Regional EPA office.  Failure to notify the
NRC under CERCLA can lead to penalties under Section 109 or,
under Section 103, criminal fines and imprisonment.  Any
spill should be reported when people or animals can come
into direct and uncontrolled contact with PCBs.

Measures must immediately be taken to control the spread of
the spill.   Any threats to water should be given highest
priority.   Water and other complicated spills should be
cleaned up by trained personnel to levels set by the
appropriate EPA Regional Administrator.  Organizations that
frequently handle PCBs should develop spill contingency
plans and conduct training for dealing with spills.

Once a spill is contained, cleanup measures can begin.  EPA
requires cleanup of PCBs to different levels depending on
spill location, the potential for exposure to residual PCBs
remaining after cleanup, the concentration of PCBs initially
spilled, and the nature and size of the population
potentially at risk of exposure.  While the PCB Spill
Cleanup Policy applies to the majority of situations,
exceptional circumstances may require additional cleanup at
the discretion of the EPA regional office.  A detailed
description of the specific reporting, cleanup,
recordkeeping, and post-cleanup sampling requirements is
found in the chapter on "PCB Spill Cleanup Policy."

Other minor weeping from PCB or PCB-contaminated equipment
capacitor bushings and seams, not covered by the spill

                          V-ll

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     policy, is still considered improper disposal of PCBs and
     compels responsible parties to take actions to rectify the
     exposure of humans and the environment to PCBs.

Q12: Do records and/or spill reports have to be kept for all PCB
     or PCB-contaminated electromagnets, switches, or voltage
     regulators which rupture?

A12: The PCB Spill Cleanup Policy specifies certain recordkeeping
     when a PCB or PCB-contaminated electromagnet, switch, or
     voltage regulator ruptures or spills.   See the chapter on
     "PCB Spill Cleanup Policy" for specific spill recordkeeping.
                               V-12

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                            CHAPTER VI
                         CIRCUIT BREAKERS
                       RECLOSERS AND CABLE
Manufacturing  (page VI-1)

Processing  (page VI-1)

Distribution in Commerce  (Sale of Circuit Breakers,  Reclosers,
  and Cable)  (page VI-2)

Exemptions to Manufacture, Process, and Distribute  PCBs  in
  Commerce  (page VI-3)

Marking/Labeling  (page VI-3)

Use Conditions  (page VI-4)

Servicing and Reclassification Conditions  (page VI-4)

Storage for Reuse  (page VI-7)

Storage for Disposal  (page VI-7)

Disposal (page VI^8)

Recordkeeping  (page VI-9)

Spills (page VI-10)

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       - CIRCUIT BREAKERS.  RECLOSERS.  AND CABLE -
Circuit breakers, reclosers, and cable are used primarily by
electric utilities in the transmission and distribution of
eiectric power to protect other equipment in the electric
power system from damage caused by electrical faults.
Circuit breakers, reclosers, and cable are types of oil-
filled electrical equipment generally not designed to
contain PCBs.  However, available data indicate that a small
percentage of this electrical equipment does in fact contain
PCBs resulting from past servicing and manufacturing
practices.

One very important difference between circuit breakers,
reclosers, and cable is that they are not required to be
"assumed" PCB-Contaminated Electrical Equipment as are other
untested, oil-filled units such as transformers and voltage
regulators whose PCB concentration is unknown.  That is to
say, circuit breakers, reclosers, and cable have
specifically been excluded from the "Assumption Rule"
[761.3].  It is important to note, however, that if circuit
breakers, reclosers, or cable are 50 ppm or greater PCBs,
then all regulatory requirements relating to the equipment
including leaks and spills, storage for disposal, and
disposal apply.
MANUFACTURING

The manufacture of PCBs, regardless of concentration, for
use in circuit breakers, reclosers, and cable is prohibited
without an EPA exemption [761.20(b)].
PROCESSING

The processing of PCBs, 50 ppm or greater, for use in
circuit breakers, reclosers, or cable is prohibited without
an EPA exemption  [761.20(c) ] .   However, PCBs at
concentrations less than 50 ppm may be processed for use in
circuit breakers, reclosers, and cable (under specific
conditions) in accordance with the definition of "Excluded
PCB Products"  [761.3].  Also,  PCBs at any concentration may
be processed  (i.e., prepared and/or packaged for
distribution in commerce)  for purposes of disposal
[761.20(c)(2)].
                         VI-1

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     DISTRIBUTION IN COMMERCE (Sale of Circuit Breakers.
     Reclosers, and Cable)

     The distribution in commerce of PCBs, 50 ppm or greater, for
     use in circuit breakers, reclosers, and cable is prohibited
     without an EPA exemption [761.20(c) ]  .  However, PCBs at
     concentrations less than 50 ppm may be distributed in
     commerce for use in circuit breakers, reclosers, and cable
     (under specific conditions) in accordance -with the
     definition of "Excluded PCB Products" [761.3].  Also, PCBs
     at any concentration may be distributed in commerce for
     purpose of disposal  [761.20(c)(2)].  Disposal, means the
     termination of the useful life of the PCB or PCB-
     contaminated circuit breaker, recloser,  or cable.

     The distribution in commerce  (sale) of circuit breakers,
     reclosers, and cable which already contain PCBs in
     concentrations of 50 ppm or greater for purposes of reuse is
     allowed provided:

          •    the unit was originally sold for use before
               July 1, 1979;

          •    the unit is intact and nonleaking at the time of
               sale; and

          •    no PCBs are introduced into the unit.

Ql:  Does this mean I can sell a PCB or PCB-contaminated circuit
     breaker, recloser, or cable?

Al:  Yes.  If the equipment was originally sold for use before
     July 1, 1979, and is now being sold for reuse  (i.e.,
     continued use).  Also, the unit must be intact and
     nonleaking.  EPA recommends that the buyer be advised that
     he is purchasing a PCB or PCB-contaminated unit.

Q2:  What does intact and nonleaking mean?

A2:  Intact and nonleaking means that the equipment is
     structurally sound with all fluid intact and there are no
     PCBs on the surface of the equipment.

Q3:  Can I sell drained PCB-contaminated circuit breakers and/or
     recloser carcasses to a rebuilder for reuse as parts in
     repair and remanufacturing activities?

A3:  No. Selling drained 50-499 ppm carcasses for reuse as parts
     is an unauthorized distribution in commerce of PCBs and is
     prohibited without an EPA exemption.  On the other hand,
     non-PCB carcasses  (less than 50 ppm) can be sold for reuse


                              VI-2

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     (under specific conditions) in accordance with the
     definition of "Excluded PCB Products" [761.3].

Q4:  Can I sell drained PCB-contaminated circuit breakers and/or
     recloser carcasses to a scrap or salvage dealer for metals
     recovery?

A4:  Yes.  The sale of drained 50-499 ppm carcasses for scrapping
     or salvaging is generally considered distribution in
     commerce for purposes of disposal and is allowed with
     certain limitations.  To qualify as disposal, the scrapping
     practice must be one which will "...terminate the useful
     life of PCBs or PCB Items" [761.3]; or,  in other words, will
     destroy any residual PCBs found in the drained carcasses.
     Salvaging aimed at reclamation of the metals found in the
     case and coil generally constitutes disposal, because any
     residual PCBs are destroyed by the high temperatures
     employed in the smelting process.  However, where salvaging
     consists of disassembling the drained equipment to obtain
     parts for reuse in other equipment, the useful life of the
     equipment has not been fully terminated and thus is not
     considered disposal.  In sum,  the scrapping/salvaging of 50-
     499 ppm drained equipment is unregulated to the extent that:
     (1) scrapping practices do not result in leaks, spills, or
     other uncontrolled discharges of PCBs, and (2) any PCB-
     contaminated components are not reintroduced into commerce.


     EXEMPTIONS TO MANUFACTURE. PROCESS. AND DISTRIBUTE PCBs IN
     COMMERCE

     Exemptions to manufacture^ process, and distribute in
     commerce PCBs in circuit breakers, reclosers, and cable may
     be granted only by rulemaking on a case-by-case basis.  The
     EPA Administrator may set terms and conditions for an
     exemption and may grant an exemption for not more than one
     year.  EPA interim procedural rules for processing and
     distribution in commerce exemptions describe the required
     content of processing and distribution in commerce
     exemptions petitions and the procedures EPA follows in
     rulemaking on exemption petitions.  Those rules were
     published in the Federal Register of May 31,  1979 (44 FR
     31558)  and are codified at 40 CFR 750.30 through 750.41.


     MARKING/LABELING

     Marking/labeling of circuit breakers, reclosers, and cable,
     regardless of PCB concentration, is not required.
                              VI-3

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USE CONDITIONS

PCB and PCB-contaminated circuit breakers, reclosers, and
cable may be used for the remainder of their useful lives.
No recorded maintenance inspections are required for PCB or
PCB-contaminated circuit breakers, reclosers, or cable.
However, ruptures, leaks, and other uncontrolled discharges
from PCB or PCB-contaminated circuit breakers, reclosers,
and cable are considered improper disposal of PCBs.
SERVICING AND RECLASSIFICATION CONDITIONS

Processing of PCB and PCB-contaminated circuit breakers,
reclosers, and cable is limited to servicing activities.
These servicing activities include: draining and refilling,
topping off, repairing, and retrofilling for
reclassification  [761.30(m)(1)].  Circuit breakers,
reclosers, and cable may be serviced (including rebuilding)
only with dielectric fluid containing less than 50 ppm PCB.

A PCB circuit breaker or recloser may be reclassified to a
PCB-contaminated or non-PCB unit by draining, refilling, and
otherwise servicing the unit.   In order to reclassify, the
unit's dielectric fluid must contain less than 500 ppm PCB
(for conversion to PCB-contaminated level) or less than 50
ppm PCB (for conversion to non-PCB level) after a minimum of
3 months of -in-service use subsequent to the last servicing
conducted for the purposes of reducing the PCB concentration
in the unit.  In-service means that the unit is used
electrically under loaded conditions [761.30(m)(1)].
                              t
The following conditions also apply to service activities:

     •    Removing the coil from PCB circuit breakers or
          reclosers (500 ppm or greater) is prohibited
          [761.30(m)(1)].

     •    PCBs from PCB circuit breakers, reclosers, and
          cable must not be mixed with or added to
          dielectric fluid from PCB-contaminated circuit
          breakers, reclosers, and cable  [761.30(m)(1)].

     •    If dielectric fluid containing less than 500 ppm
          PCBs is mixed with fluid containing 500 ppm or
          greater PCBs, then the resulting mixture must not
          be used as dielectric fluid in any electrical
          equipment.  The entire mixture must be considered
          to be greater than 500 ppm PCBs and must be
          disposed of in an incinerator that meets
          EPA requirements [761.30(m) (1)], or by an
          alternative EPA approved and permitted method.

                          VI-4

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          •    Mineral oil from circuit breakers, reclosers, and
               cable must not be mixed with mineral oil from
               other electrical equipment, such as transformers
               and voltage regulators, whose PCB concentration is
               unknown.  If dielectric fluid from untested, oil-
               filled circuit breakers, reclosers, or cable is
               collected in a common container with dielectric
               fluid from other oil-filled electrical equipment,
               the entire contents of the container must be
               treated as PCBs at a concentration of at least 50
               ppm, unless all of the fluid from the other oil-
               filled electrical equipment has been tested and
               shown to contain less than 50 ppm PCBs
                [761.60(g)(1)(i)].

Q5:  Our facility periodically drains oil-filled circuit
     breakers, reclosers, and cable, brought in for servicing,
     into drums and/or bulk tanks.  From time to time, an
     untested transformer or voltage regulator is also brought in
     for servicing and the oil from these units is drained into
     the same drums and/or storage tanks.  These drums/tanks are
     always batch tested for PCBs and the contents are then
     reused in servicing oil-filled circuit breakers, reclosers,
     and cable, or disposed of based upon the PCB test result.
     Is there anything wrong with this type of mixing and batch
     testing?

A5:  Yes.  What you have in this scenario is unauthorized
     "dilution" of PCBs.  The regulations do allow mixing and
     batch testing under certain conditions.  However, the mixing
     of untested oil from circuit breakers, reclosure, and cable
     with untested transformer and regulator oil for batch
     testing is prohibited.  If these dielectric fluids are
     collected in a common container, then the entire mixture
     must be treated as 50 ppm or greater PCBs even if a batch
     test resulted in less than 50 ppm.  Consequently, the
     mixture could not be reused in servicing oil-filled circuit
     breakers, reclosers, and cable, and the entire mixture must
     be stored for disposal and disposed of as.containing PCBs at
     a concentration of 50 ppm or greater.

Q6:  Is a circuit breaker or recloser required to reach 50°
     Centigrade during the 90-day in-service period for proper
     reclassification?

A6:  No.  Unlike transformers,  there is no 50° Centigrade
     requirement for reclassification of these types of equipment
     [761.30(m)(1)].
                              VI-5

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Q7:  Can screening tests, such as Clor-n-Oil™, be used to
     determine the PCB concentration of circuit breakers,
     reclosers, or cable?  If so, can "certified non-PCB" labels
     be used to classify these units based upon a screen test?

A7:  Currently, the regulations do not require that any
     particular testing method be utilized when determining the
     PCB concentration in circuit breakers, reclosers, or cable.
     However, owners of these types of equipment should prudently
     scrutinize PCB testing options, as there are significant
     differences in the integrity and accuracy of various testing
     methods.  It should be noted that, in most situations, EPA
     will utilize laboratory gas-chromatography (GC)  testing to
     determine PCB concentrations during facility inspections.
     EPA recommends that owners of electrical equipment choose
     testing methods, and practice sampling procedures, which are
     analytically accurate, reproducible, assure quality control,
     and are certifiable.  EPA does not recognize results of
     field screening test kits for classifying PCB equipment.

     The use of non-PCB labels is unregulated by EPA.  That is to
     say, there are no prohibitions or requirements to place non-
     PCB labels on circuit breakers, reclosers, or cable.
     However, if non-PCB labels are used to indicate the
     classification of equipment, then owners should be able to
     provide documentation such as test results or manufacturer's
     letters along with historic service records which will
     substantiate the non-PCB classification.  Criminal action
     could be pursued for someone intentionally using non-PCB
     labels on PCB or PCB-contaminated items.

Q8:  Can I batch test oil samples from several circuit breakers
     or reclosers and classify each unit based upon one test
     result?

A8:  The only place in the regulations where "batch testing" is
     specifically allowed is under testing procedures for
     disposal of PCBs [761.60(g)].  However, batch testing to
     classify equipment for continued use of PCBs is also
     allowable provided that dilution does not take place.  That
     is, mineral oil that is assumed or known to contain 50 ppm
     or greater PCBs must not be mixed with mineral oil that is
     known or assumed to contain less than 50 ppm PCBs to reduce
     the concentration of PCBs in the batch.  It should also be
     noted that while batch testing is allowed, it does not
     relieve the owner from any regulatory requirements if an
     individual unit is discovered to contain a higher
     concentration of PCBs than was detected in the batch test.
                               VI-6

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     STORAGE FOR REUSE

     Circuit breakers, reclosers, and cable containing PCBs at
     any concentration may be stored for reuse.  There are no
     time limitations on this storage; however, circuit breakers,
     reclosers, and cable (50 ppm or greater) which are stored
     for reuse must be in condition suitable for reuse.  These
     units are considered by EPA to be in-service for purposes of
     the regulations.
                     *•
Q9:  How long can I keep a "burned-out" or "nonfunctional" PCB or
     PCB-contaminated circuit breaker or recloser in storage for
     reuse if I plan on repairing it and using it later?

A9:  It is not required that nonfunctional equipment be placed
     into "storage for disposal" if there is a possibility of
     repair.  However, EPA may have grounds to enforce against
     lengthy "storage for reuse" of equipment which is not
     reasonably expected to be placed back into service.  In
     other words, while there are no explicit requirements for,
     or restrictions on,  the storage for reuse of equipment which
     can and may be repaired, the owner should be able to
     demonstrate good faith compliance with the intent of the
     storage for disposal requirements and complete any required
     servicing and/or repairs within a reasonable timeframe.


     STORAGE FOR DISPOSAL

     All PCBs and PCB-contaminated circuit breakers,  reclosers,
     and cable must be dated when placed into storage for
     disposal [761.65(c)(8)]  and must be removed from storage and
     disposed of within one year [761.65(a)].

     The facility used to store PCB and PCB-contaminated circuit
     breakers,  reclosers,  and/or cable must comply with the
     "storage for disposal"  requirements [761.65(b)(1)].  See the
     chapter on "PCB Storage Facilities" for specific
     requirements.

     Nonleaking PCB and PCB-contaminated circuit breakers,
     reclosers,  and cable may be stored temporarily by a
     generator in an area that does not comply with the
     requirements for a PCB storage facility for up to 30 days
     from the date  of their removal from service for disposal
     provided that  a notation is attached to each unit indicating
     the dates the  equipment was removed from service
     [761.65 (c) (1) (i)],  and placed into storage for disposal
     [761.65(c) (8)] .

     Leaking PCB and PCB-contaminated circuit breakers,
     reclosers,  and cable  which are placed in appropriate PCB

                              VI-7

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Containers  [761.65(c)(6)]  with sufficient sorbent materials
to absorb any liquid PCBs, may also be temporarily stored by
a generator for up to 30 days provided that a notation is
attached to the container indicating the dates the equipment
was removed from service  [761.65(c)(1)], and placed into
storage for disposal [761.65(c)(8)].   Each container or drum
used to store leaking PCB Items must be marked in accordance
with EPA marking and labeling requirements [761.40(a)(1)].
Nonleaking and structurally undamaged PCB-contaminated
circuit breakers, reclosers, and cable that have not been
drained of free-flowing dielectric fluid may be stored
temporarily on pallets next to a PCB storage facility which
meets the requirements for storage for disposal.  This type
of storage is permitted only when the storage facility has
immediately available unfilled storage space equal to 10
percent of the volume of the equipment stored outside the
facility.  The equipment stored outside the facility must be
inspected for leaks weekly  [761.65(c)(2)], and a notation
must be attached to each unit indicating the dates the
equipment was removed from service [761.65(c) (1)] and placed
into storage for disposal [761.65  (c)(8)].  If a weekly
visual inspection reveals a piece of equipment is leaking,
having the required available space within the storage area
allows immediate containment of the leak by moving the
equipment into the storage area.
DISPOSAL

PCB circuit breakers, reclosers, and cable must be disposed
of as follows:

     •    In an incinerator that complies with 40 CFR
          761.70.

     •    In a chemical waste landfill provided that all
          free-flowing liquid PCBs have been thoroughly
          drained from the equipment.  The PCB liquids that
          are removed (including any flushing solvent) must
          be disposed of in an incinerator that complies
          with 40 CFR 761.70, or by an alternative EPA
          approved and permitted method in accordance with
          761.60(e).

PCB-contaminated circuit breakers, reclosers, and cable must
be disposed of as follows:

     •    By draining all free-flowing liquid from the
          equipment and disposing of the liquid in an
          incinerator that complies with 40 CFR 761.70, in a
          chemical waste landfill that complies with 761.75,
          in an approved high efficiency boiler that
          complies with 761.60(a) (2) (iii), or by an

                          VI-8

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               alternative EPA approved and permitted method that
               complies with 761.60(e).  The disposal of the
               drained equipment carcass is not regulated  [761.60
                (b) (5) (ii)] ; however, the sale or trade of the
               drained carcass for reuse as parts or in
               rebuilding is regulated.  (See Distribution in
               Commerce.)

     Non-PCB circuit breakers, reclosers, and cable  (less than 50
     ppm PCB) may be disposed of with the following
     considerations:

          •    There are no PCB disposal requirements for non-PCB
               circuit breakers, reclosers, and cable.  However,
               certain reuse restrictions apply to the less than
               50 ppm PCB fluid.  Waste oil with any detectable
               concentration of PCBs cannot be used as a sealant,
               coating, or dust control agent [761.20(d)]; and
               also, can only be burned for energy recovery in
               specific combustion facilities described in
               761.20 (e) (1) .  See the chapter on "PCB Disposal
               Requirements" for a detailed discussion of the
               disposal of non-PCB waste oils.

Q10: Do PCB circuit breakers, reclosers, and cable have to be
     filled with a solvent for 18 hours and redrained before
     transporting the carcass to a chemical waste landfill?

A10: No.  Unlike PCB Transformers, there is no requirement to
     fill and flush PCB circuit breakers, reclosers, and cable
     with solvent prior to disposal of the drained carcass in a
     chemical waste landfill.  However, owners of PCB Equipment
     should take appropriate steps to insure that all free-
     flowing liquid PCBs have been extracted from the carcass.


     RECORDKEEPING

     Testing data, inventories, servicing and reclassification
     records, spill reports,  and disposal records should be
     maintained for all PCB and PCB-contaminated circuit
     breakers,  reclosers, and cable.  Under specific quantity
     guidelines,  [761.180(a)] records are required to be kept to
     form the basis of an Annual Document Log and Annual Record
     which must be prepared each year and maintained for at least
     3 years after the facility ceases using or storing PCBs and
     PCB Items.  See Chapter XV, "Recordkeeping and Reporting"
     for a detailed discussion of other recordkeeping
     requirements.
                              VI-9

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     SPILLS

     Spills, leaks, and other uncontrolled discharges where the
     release results in any quantity of PCBs running off or about
     to run off the external surface of a PCB or PCB-contaminated
     circuit breaker, recloser, or cable is considered improper
     disposal of PCBs.  The PCB Spill Cleanup Policy provides
     specific cleanup measures which, if followed explicitly,
     create a presumption against enforcement for penalties or
     further cleanup.  See the chapter on "PCB Spill Cleanup
     Policy" for specific measures.

     PCB spills involving 1 Ib. or more of PCBs (generally 1 pint
     of Askarel) must be reported to the National Response Center
     (NRC)  at (800)424-8802.  Spills involving 10 Ibs. or more of
     PCBs must be reported to the appropriate regional EPA
     office.  Failure to notify the NRC under CERCLA can lead to
     civil penalties under Section 109 or, under Section 103,
     criminal fines and imprisonment.  Any spill should be
     reported when people or animals can come into direct and
     uncontrolled contact with PCBs.

     Measures must immediately be taken to control the spread of
     the spill.   Any threats to water should be given highest
     priority.  Water and other complicated spills should be
     cleaned up by trained personnel to levels set by the
     appropriate EPA Regional Administrator.  Organizations that
     frequently handle PCBs should develop spill contingency
     plans and conduct training for dealing with spills.

     Once a spill is contained, cleanup measures can begin.  EPA
     requires cleanup of PCBs to different levels depending on
     spill location, the potential for exposure to residual PCBs
     remaining after cleanup, the concentration of PCBs initially
     spilled, and the nature and size of the population
     potentially at risk of exposure.  While the PCB Spill
     Cleanup Policy applies to the majority of situations,
     exceptional circumstances may require additional cleanup at
     the discretion of the EPA regional office.  A detailed
     description of the specific reporting,  cleanup,
     recordkeeping, and postcleanup sampling requirements is
     found in the chapter on "PCB Spill Cleanup Policy."

     Other minor weeping from PCB or PCB-contaminated equipment
     bushings and seams not covered by the spill policy is still
     considered improper disposal of PCBs and compels responsible
     parties to take actions to rectify the exposure of humans
     and the environment to PCBs.

Qll: Do records and/or spill reports have to be kept for all PCB
     or PCB-contaminated circuit breakers, reclosers, or cable
     which rupture and/or spill?

                              VI-10

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All: The PCB Spill Cleanup Policy specifies specific
     recordkeeping when a PCB or PCB-contaminated circuit
     breaker, recloser, or cable ruptures or spills.  See the
     chapter on "PCB Spill Cleanup Policy" for specific spill
     recordkeeping.
                              VI-ll

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                      CHAPTER VII


                RESEARCH AND DEVELOPMENT



Manufacturing  (page VII-1)

Processing  (page VII-1)

Distribution in Commerce  (page VII-1)

Exporting  (page VII-1)

Exemptions to Manufacture, Process, Distribute  in
Commerce, and Export PCBs  (page VII-2)

Use Conditions  (page VII-2)

Marking/Labeling  (page VII-3)

Storage for Disposal  (page VII-4)

Disposal (page VII-4)

Recordkeeping and Reporting Requirements  (page  VII-5)

Spills  (page VII-5)

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               -RESEARCH AND DEVELOPMENT-
PCBs are used  in toxicological and environmental testing.
They are also  used  in analytical chemistry as  "reference
standards" for the  analysis of unknown compounds that may
contain PCBs.

EPA determined that there are no substitutes for PCBs for
the continuation of important health, environmental, and
analytical research and that substitutes for PCBs in these
applications will not be developed in the future.
Therefore, there is a unique need for exemptions to
manufacture, process, distribute in commerce,  and export
PCBs in small  quantities for research and development.
MANUFACTURING

The manufacture of PCBs for the purpose of research and
development is prohibited without an EPA exemption
 [761.20(b)].   (Note:  EPA has granted exemptions to
manufacture PCBs in small quantities for research and
development.)
PROCESSING

The processing of PCBs for the purpose of research and
development is prohibited without an EPA exemption
 [761.20 (c)3 •   (Note:  EPA has granted exemptions to process
PCBs in small quantities for research and development.)
DISTRIBUTION IN COMMERCE

The distribution in commerce of PCBs for the purpose of
research and development is prohibited without an EPA
exemption  [761.20 (c)] .   (Note:  EPA has granted exemptions
to distribute in commerce PCBs in small quantities for
research and development.)
EXPORTING

The export of PCBs for the purpose of research and
development is prohibited without an EPA exemption
[761.20(b)&(c)].  (Note:  EPA has granted exemptions to
export PCBs in small quantities for research and
development.)
                         VII-1

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EXEMPTIONS TO MANUFACTURE. PROCESS. DISTRIBUTE IN COMMERCE.
AND EXPORT PCBs

Section 6(e)(3)(B) of TSCA provides that any person may
petition the Administrator for an exemption from the
prohibition against the manufacture, processing, and
distribution in commerce of PCBs.  The Administrator may by
rule grant an exemption if the Administrator finds that " (i)
an unreasonable risk to health or the environment would not
result, and  (ii) good faith efforts have been made to
develop a chemical substance which does not present an
unreasonable risk of injury to health or the environment and
which may be substituted for such polychlorinated biphenyl."
The Administrator may set terms and conditions for an
exemption and may grant an exemption for not more than one
year.

EPA's Interim Procedural Rules for Processing and
Distribution in Commerce Exemptions describe the required
content of processing and distribution in commerce exemption
petitions and the procedures EPA follows in rulemaking on
exemption petitions.  Those rules were published in the
Federal Register of May 31, 1979 (44 FR 31514) and are
codified at 40 CFR 750.30 through 750.41.

The class exemption on processing and distribution in
commerce includes all persons or business entities which
process and distribute in commerce PCBs in accordance with
the definition of "small quantities for research and
development"  [761.30 (j)] .  EPA also places the following
terms and conditions on the class 'exemption:

     •    All processors and distributors must maintain
          records of their PCB activities for a period of 5
          years.

     •    Any person or company that expects to process or
          distribute in commerce 100 grams  (.22 Ib.) or more
          PCBs for research and development in 1 year must
          report to EPA and identify the sites of PCB
          activities and the quantity of PCBs to be
          processed and distributed in commerce.
USE CONDITIONS

PCBs may be used in small quantities for the purpose of
research and development indefinitely provided the use is in
accordance with the following definition:

     •    "Small Quantities for Research and Development"
          means any quantity of PCBs (1) that is originally

                         VII-2

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               packaged in one or more hermetically sealed
               containers of a volume of no more than five  (5.0)
               milliliters, and (2) that is used only for
               purposes of scientific experimentation or
               analysis, or chemical research on, or analysis of
               PCBs, but not for research or analysis for the
               development of a PCB product.

     As published in the Federal Register on March 30, 1983  (48
     FR 13184),  research and development on disposal methods
     using PCBs constitutes disposal and is regulated using the
     disposal section of the PCB regulations (40 CFR 761.60).
     Failure to obtain prior approval from EPA to conduct
     disposal research and development is a violation of the PCB
     disposal regulations.

Ql:  I have just received a package of PCBs for research and
     development purposes.  How should I store the hermetically
     sealed containers until use?

Al:  There are no storage requirements for hermetically sealed
     packages of PCBs that will be used for research and
     development.   As long as the hermetically sealed containers
     have not been opened, they may be stored for future use
     indefinitely.  However, once the seal has been broken on a
     container,  the small quantity of PCBs must be used for their
     intended purpose in a timely fashion.  Any residual PCB
     wastes, including contaminated containers and lab
     instruments,  must be stored for disposal in accordance with
     EPA requirements.

Q2:  Is there a limit on the number of hermetically sealed 5
     milliliter containers that can be used?

A2:  No, one may use as many as necessary to conduct the research
     and development activity.


     MARKING/LABELING

     All hermetically sealed containers containing small
     quantities of PCBs for research and development must be
     marked/labeled in accordance with EPA marking requirements
     for PCB Containers [761.40(a)  (1)] .

     In addition,  if sealed containers are stored in a package,
     then the package must be marked/labeled in accordance with
     EPA marking requirements for PCB Article Containers
     [761.40(a)(9)].
                              VII-3

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     STORAGE FOR DISPOSAL

     Any PCB waste generated from the use of small quantities of
     PCBs for research and development  (i.e., contaminated
     containers and lab instruments) must be stored for disposal
     in a facility which complies with EPA storage for disposal
     requirements  [761.65(b) (1)] .

     However, PCB waste from research and development can also be
     stored temporarily by the generator for up to 30 days in an
     area that does not comply with the requirements for a PCB
     storage facility provided that the following conditions are
     met:

          •    PCB waste must be placed in an appropriate PCB
               Container/drum  [761.65(c)(6)]  with sufficient
               sorbent materials to absorb any liquid PCBs.

          •    The PCB Container/drum must be marked/labeled in
               accordance with EPA marking requirements
               [761.40(a)(1)].

          •    A notation must be attached to the PCB
               Container/drum indicating the date the first PCB
               waste was placed into the container/drum for
               disposal  [761.65(c) (1)] .

          •    Within 30 days, all PCB waste within the
               container/drum must either be transferred to a
               storage facility which meets the requirements for
               storage for disposal [761.65(b)(1)], or to an EPA
               approved and permitted PCB disposal facility.

Q3:  From time to time, our lab wishes to return PCB analytical
     standards to our supplier because of overshipment and/or the
     delivery of incorrect standards.  Can these standards be
     returned and used by another company or must unused
     standards be disposed of as PCB waste?

A3:  The class exemption to process and distribute in commerce
     small quantities of PCBs for research and development would
     also apply in this situation and allow the return of
     standards to suppliers for processing and use by another
     company.  The standards must be packaged in hermetically
     sealed containers of a volume of no more than 5 milliliters.
     DISPOSAL

     PCB wastes  (50 ppm or greater) generated from research and
     development activities such as used PCB standards,
     contaminated containers, and contaminated lab instruments

                              VII-4

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must be disposed of in accordance with EPA disposal
requirements under 761.60.  Debris from a spill may be
disposed of in a 761.60 incinerator or a 761.75 chemical
waste landfill  [761.60(a)(4)].
RECORDKEEPING AND REPORTING REQUIREMENTS

The class exemption to process and distribute in commerce
small quantities of PCBs for research and development
includes the following recordkeeping/reporting requirements:

     •    All processors and distributors must maintain
          records of their PCB activities for a period of 5
          years.

     •    Any person or. company that expects to process or
          distribute in commerce 100 grams (.22 Ib.) or more
          PCBs for research and development in 1 year must
          report to EPA and identify the sites of PCB
          activities and the quantity of PCBs to be
          processed and distributed in commerce.
SPILLS

Spills, leaks, and other uncontrolled discharges resulting
in the release of any quantity of PCBs (50 ppm or greater)
is considered improper disposal of PCBs.   The PCB Spill
Cleanup Policy provides specific cleanup measures which, if
followed explicitly, create a presumption against
enforcement for penalties or further cleanup.  See the
chapter on "PCB Spill Cleanup Policy" for specific measures.
                         VIl-5

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                      CHAPTER VIII
                      MICROSCOPIC
                    MOUNTING MEDIUM
                     IMMERSION OILS
                    OPTICAL LIQUIDS
Manufacturing, Processing, and Distribution in Commerce
(page VIII-2)

Use Conditions (page VIII-2)

Disposal  (page VIII-2)

Spills  (page VIII-2)

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-MICROSCOPIC MOUNTING MEDIUM.  IMMERSION OILS.  OPTICAL LIQUIDS-
   PCBs are reported to be an ideal mounting medium for light
   microscopy primarily because of their stability, refractive
   index, viscosity, and thermoplastic properties.  In the
   past, the principal users have been mineralogists and
   chemical microscopists employed in chemical laboratories
   such as:  police crime-laboratories, museum conservation
   laboratories, industrial laboratories, where contaminant
   particles in drugs, food, and plastics are identified, and
   in laboratories studying environmental contaminants.  PCBs *
   are used in art and historic conservation as a mounting
   medium to preserve specimens permanently and in the
   preservation of small environmental, forensic, and
   industrial contaminant particles.

   Although mounting media exist with refractive indices and
   viscosities similar to PCBs, these media reportedly discolor
   in time.  At this time, there are no adequate substitutes
   for PCBs in the preparation of permanent slides.

   PCBs are useful as microscope immersion oils in medical
   research.  Small amounts of PCB immersion oils are useful in
   cancer studies in which fluorescence microscopy is used.
   The technique used in immersion microscopy involves placing
   a drop of immersion oil on the coverslip of the slide and
   lowering the objective lens of the microscope until it just
   touches the oil.

   PCB immersion oil has the lowest fluorescence of any
   currently available formulation, and this property is
   particularly important in fluorescence microscopy where the
   immersion oil must not fluoresce and therefore will not
   compete with the fluorescence of the specimen under
   analysis.  There appears to be no other suitable alternate
   material with the desirable low auto-fluorescence,  low
   dispersion, and high refractive index of PCBs.

   Scientists in the fields of space, communications,  and
   defense-related research use .02 cc to 4 liters of PCBs in
   certain specialized optical applications including use in
   fiber optic connectors.  These PCBs are contained in optical
   equipment where they exist in a permanent or semi-permanent
   state.

   It is believed there are no adequate substitutes for PCBs as
   optical liquids in space, communications, defense-related
   research projects, and other specialized optical uses, such
   as the use of PCBs in tunable light receivers.  There are
   relatively few compounds with as high a refractive index as
   PCBs and none that also has the long-term stability.

                            VIIl-l

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An example of an optical use of PCBs, where their use is
essential, is the use of PCBs with tunable light receivers
for the analysis of light from a solar telescope.  PCBs are
necessary in these light receivers because of their
stability and ability to transmit light better in the blue
and green regions of the spectrum, where starlight is
transmitted, than other potential substitute fluids.
MANUFACTURING. PROCESSING. AND DISTRIBUTION IN COMMERCE

The manufacture, processing, and distribution in commerce of
PCBs for use as a mounting medium, immersion oil in
fluorescence microscopy, and optical liquid are permitted
only for persons who are granted an exemption under TSCA
section 6(e)(3)(B).
USE CONDITIONS

PCBs may be used as a permanent microscopic mounting medium,
an immersion oil in fluorescence microscopy, and an optical
liquid in a manner other than a totally enclosed manner
indefinitely  [761.30(k), (n),  (o)].
DISPOSAL

All PCB waste resulting from the use of PCBs in
concentrations 50 ppm or greater as a mounting medium,
immersion oil, and/or optical liquid must be disposed of in
accordance with EPA disposal requirements  [761.60].
SPILLS

Spills, leaks, and other uncontrolled discharges resulting
in the release of any quantity of PCBs  (50 ppm or greater)
is considered improper disposal of PCBs.  The PCB Spill
Cleanup Policy provides specific cleanup measures which,  if
followed explicitly, create a presumption against
enforcement for penalties or further cleanup.  See the
chapter on "PCB Spill Cleanup Policy" for specific measures
                         VIII-2

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                       CHAPTER IX






                 CARBONLESS COPY PAPER






Overview  (page IX-1)



Manufacturing  (page IX-l)



Processing  (page IX-1)



Distribution in Commerce  (page IX-1)

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                -CARBONLESS COPY PAPER-
OVERVIEW

Prior to 1971, some carbonless copy paper was made with ink
containing PCBs.  There does not appear to be a way to
distinguish PCB carbonless copy paper from non-PCB
carbonless copy paper except by dates or o'ther indications
on unused inventories.  A large portion of the PCB copy
paper that has not been destroyed is probably in files.  An
enormous undertaking would be required of both business and
government to purge existing files of PCB carbonless copy
paper.  As the amount of PCB on each sheet of paper is
extremely small, EPA has concluded that the continued use of
carbonless copy paper does not present an "unreasonable
risk" and has authorized the continued use of existing PCB
copy paper.
MANUFACTURING

The manufacture of PCBs for use in carbonless copy paper is
prohibited without an EPA exemption [761.20(b)].
PROCESSING

The processing of PCBs for use in carbonless copy paper is
prohibited without an EPA exemption [761.20(c)].
DISTRIBUTION IN COMMERCE

The distribution in commerce of PCBs for use in carbonless
copy paper is prohibited without an EPA exemption
[761.20(c)].
                          IX-1

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                       CHAPTER X






                 EXCLUDED PCB PRODUCTS






Used Oil  (page X-2)



Investment Casting Waxes  (page X-6)



Electrical Equipment Components  (page X-6)

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                 -EXCLUDED PCB PRODUCTS-
In the Federal Register of July 10, 1984  (49 FR 28172), EPA
published the  "Uncontrolled PCBs" rule.  This final rule was
a result of  the  "EDF v. EPA" lawsuit in which the
Environmental Defense Fund  (EDF) challenged EPA's general  50
parts per million  (ppm) regulatory cutoff for PCBs.  This
challenge was successful and on October 30, 1980, the U.S.
District Court of Appeals found that there was not
substantial  evidence to support EPA's original decision to
exclude generally from regulation all materials containing
PCBs at concentrations less than 50 ppm.  Consequently, EPA
undertook the regulation of very low concentration PCBs
(less than 50 ppm).

The 1984 "Uncontrolled PCBs" rule among other things,
regulated manufacturing processes generating low
concentration PCBs in other than "closed" and "controlled
waste" processes.  On the date the rule became effective,
the Court lifted its stay in the EDF lawsuit, which had the
effect of banning any activity involving any quantifiable
level of PCBs unless that activity was specifically
excluded, exempted, or authorized by regulation.  The
practical effect of the Court's action was to make illegal
many activities which were neither anticipated nor evaluated
during the rule's development and which presented no
unreasonable risk to health or the environment.

Consequently, on June 27, 1988 (53 FR 24206), EPA published
in the Federal Register a set of amendments to the 1984 PCB
"Uncontrolled Rule."  These amendments have excluded the
majority of  low-level PCB activities (less than 50 ppm) from
regulation.  In other words, many low-level PCB activities
which became prohibited with the "Uncontrolled PCBs" rule
have returned to unregulated status.

The amendments to the 1984 rule include a generic exclusion
for products containing less than 50 ppm PCBs using the new
term "Excluded PCB Products" (761.3).   Generally,  the
processing, distribution in commerce,  and use of "Excluded
PCB Products" is now unregulated.   "Excluded PCB Products"
are defined as PCBs which appear at concentrations less than
50 ppm in products including,  but not limited to,
inadvertently generated PCBs (see 761.l(f)), PCB
contaminated products (e.g., investment casting waxes), PCB
contaminated recycled fluids and equipment,  and used oils,
provided that:

     •    The products were legally manufactured,  processed,
          distributed in commerce,  or used before October 1,
          1984.

                          X-l

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     •    The products were legally manufactured, processed,
          distributed in commerce, or used pursuant to
          authority granted by EPA by regulation, by
          exemption, by settlement agreement, or pursuant to
          other agency-approved programs.

     •    The resulting PCB concentration (< 50 ppm) is not
          a result of any dilution.

NOTE:  This rule does not affect land application practices
involving sewage sludge or other nonhazardous solid wastes
which contain PCBs at concentrations less than 50 ppm.
These activities are regulated under other EPA programs.

EPA adopted the generic exclusion for "Excluded PCB
Products" based upon the Agency's determination that the
use, processing, and distribution in commerce of these
products with less than 50 ppm PCB contamination will not
generally present an unreasonable risk to health or the
environment.  However, EPA is aware that some product uses
and processing, particularly the burning and recycling of
used oil, may present unique exposure and risk considera-
tions.
USED OIL - History

Under the PCB "Uncontrolled Rule," there was considerable
confusion regarding the status of used oil containing less
than 50 ppm PCBs.  In the earlier 1979 "PCB Ban Rule", used
non-PCB oil (less than 50 ppm) was unregulated except for
its reuse as a dust suppressant, sealant, or coating which
was prohibited at any detectable PCB level.  However, with
the overturning of the general 50 ppm regulatory cutoff by
the EDF v. EPA decision, activities (use, processing, or
distribution in commerce) involving less than 50 ppm PCBs
became prohibited on October 1, 1984,  unless specifically
authorized, exempted, or excluded by regulation.  Prior to
publication of the PCB "Uncontrolled Rule" amendments, EPA
had specifically authorized only three reuses of oil
products with less than 50 ppm PCBs:

     •    The reuse of dielectric fluids  (as dielectrics).

     •    The reuse of hydraulic and heat transfer fluids
           (as hydraulic and heat transfer fluids).

     •    The reuse of waste oil as a feedstock by
          manufacturers of asphalt roofing materials under
          the conditions set out in the definition of
          "Recycled PCBs" processes.
                          X-2

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Therefore, other activities involving the use, processing,
or distribution in commerce of used oil with any
quantifiable PCB concentration (2 ppm or greater) became
prohibited.
USED OIL - Current

The processing, distribution in commerce, 'and use of low-
level used oils (2-49 ppm) is generally excluded from
regulation under the definition of "Excluded PCB Products."
This exclusion does not, however, affect the existing
prohibitions on the use of waste oil containing any
detectable level of PCBs as a dust suppressant, sealant, or
coating.  It is important to note that low-level used oil
activities consisting solely of "disposal" are not
prohibited.  This "unregulated disposal" status does not
mean that EPA has authorized the indiscriminate dumping or
burning of used oil containing less than 50 ppm PCBs.  It
should be stressed that the PCB regulations define
"Disposal" in terms of acts which "complete or terminate the
useful life of PCBs."  In this context, the Agency considers
that used oil activities such as recycling for use and/or
burning in a manner that does not destroy or "terminate the
useful life of PCBs" in fact constitutes reuse or processing
of PCBs and consequently became prohibited under the PCB
"Uncontrolled Rule."  Used oil (2-49 ppm) could be burned
for energy recovery, but only in combustion units which
accomplish PCB destruction.  Burning PCBs, even at low-level
concentrations, in combustion units which do not accomplish
PCB destruction may volatilize the PCBs and potentially
create an additional point source of toxic products such as
polychlorinated dibenzofurans (PCDFs).   The burning of used
oil (2-49 ppm)  is allowed only if the following marketing,
burning, testing,  and recordkeeping requirements are met:

1)  MARKETING:   Owners and operators of facilities which
process and/or distribute in commerce for energy recovery
used oil containing any detectable level of PCBs are
referred to as "Marketers" of used oil fuels.  Used oil
containing any detectable level of PCBs may be marketed only
to:

     •    qualified incinerators defined in 40 CFR 761.3,

     •    other marketers identified in 40 CFR 279, or

     •    burners identified under 40 CFR 761.20(e) (1) (iii) .

2)  BURNING:  Owners and operators of facilities which burn
used oil containing any detectable level of PCBs are
referred to as "Burners" of used oil fuels.  Used oil

                          X-3

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containing any detectable level of PCBs may be burned for
energy recovery only in:

     •    an incinerator approved under the provisions of
          761.70, or

     •    a high efficiency boiler which complies with the
          criteria of 761.60(a)(2)(iii)(A), and for which
          the operator  (burner) has given written notice to
          the EPA Regional Administrator in accordance with
          the requirements under 761.60(a)  (2) (iii) (B) , or

     •    an incinerator approved under Section 3005(c) of
          RCRA, or

     •    burners identified in 40 CFR 279.61(a)(1)  and (2).

In addition, before a burner accepts from a marketer the
first shipment of used oil fuel containing detectable PCBs
(2-49 ppm), he must provide the marketer a one-time written
and signed notice certifying that:

     •    he has complied with any notification requirements
          applicable to "Qualified Incinerators"  (761.3) or
          to "Burners" regulated under 40 CFR Part 279; and

     •    he will burn the used oil only in a combustion
          facility identified in 761.20(e)(1).

3)  TESTING:  Used oil to be burned for energy recovery is
presumed to contain detectable levels of PCBs unless the
marketer obtains analysis (testing)  or other information
documenting that the used oil fuel does not contain
detectable levels of PCBs.

     •    The person who first claims that a used oil fuel
          does not contain detectable PCBs is subject to the
          requirement to obtain analysis or other
          information to support this claim.

     •    Testing to determine the PCB concentration in used
          oil may be conducted on individual samples, or in
          accordance with the batch testing procedures
          described in 761.60(g)(2).

     •    Other information documenting that used oil fuel
          does not contain detectable levels of PCBs may
          consist of either personal, special knowledge of
          the source and composition of the used oil, or a
          certification from the person generating the used
          oil claiming that the oil contains no detectable
          PCBs  (i.e., <2 ppm).

                          X-4

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     4)   RECORDKEEPING:  The following recordkeeping
     requirements apply to the testing, marketing, and burning of
     used oil fuels.

          •    The marketer who first claims that used oil fuel
               contains no detectable PCBs must include copies of
               the analysis or other information documenting his
               claim among the records required to be kept under
               40 CFR 279.72 and 279.74.

          •    Burners must include a copy of each
               761.20 (e)  (3) (ii) certification notice that he
               sends to a marketer among the records required to
               be kept under 40 CFR 279.65 and 279.66.

          •    A marketer must include a copy of each
               certification notice relating to transactions
               involving PCB-containing used oil among the
               records required to be kept under 40 CFR 279.74
               and 279.75.

Ql:  My facility regularly accumulates used oil containing low-
     level PCBs.  What options do I have for getting rid of these
     waste oils?

Al:  Some of the options available for waste oils containing low-
     level PCB contamination (less than 50 ppm) include but are
     not limited to:

     1)   Disposal in a "Qualified Incinerator" (761.3).
     2)   Disposal by an alternative EPA approved and permitted
          method such as "chemical detoxification."
     3)   Servicing and/or reuse in electrical equipment as a
          dielectric fluid  (if originally a dielectric fluid).
     4)   Servicing and/or reuse in heat transfer and hydraulic
          systems (if originally heat transfer and hydraulic
          fluid).

Q2:  From time to time our facility sells and/or gives away waste
     oils we've accumulated to other parties.  It is unknown
     whether these waste oils contain any PCBs or exactly what
     these waste oils are used for.  Our facility isn't
     responsible for how these waste oils are used or
     burned...are we?

A2:  First,  the waste oils your facility is selling/giving away
     must be presumed to contain detectable levels of PCBs unless
     the oil is tested or otherwise certified not to contain
     detectable PCBs.  Also, if the waste oils being sold or
     given to other parties are being used in prohibited
     activities, your facility is possibly involved in improper
     distribution in commerce (marketing)  of PCBs.  The marketing

                               X-5

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     of low-level PCB waste oils is a regulated activity and
     imposes specific recordkeeping and certification
     requirements of the marketer.

Q3:  Can a facility burn its own non-PCB (2-49 ppm) waste oils?

A3:  Yes, provided the facility uses a high efficiency boiler or
     other combustion system that complies with the definition of
     "Qualified Incinerators" (761.3).  If it is unclear whether
     a boiler or incinerator meets the requirements, the facility
     should contact their Regional EPA Office and provide
     information on their system which EPA will evaluate on a
     case-by-case basis.
     INVESTMENT CASTING WAXES

     EPA examined the facts surrounding past uses of PCBs as a
     wax extender, as well as the circumstances of residual low
     levels of PCB contamination in the stocks of reclaimed
     waxes.  EPA determined that the further use, processing, and
     distribution in commerce of these waxes will not present an
     unreasonable risk to health or the environment.  In the 1988
     amendments to the PCB "Uncontrolled Rule," investment
     casting waxes were included among the class of "Excluded PCB
     Products."  Activities involving these waxes are now
     generally excluded from TSCA regulation provided they
     contain less than 50 ppm PCBs [761.3].
     ELECTRICAL EQUIPMENT COMPONENTS

     The "Electrical Equipment Rule" (August 25,  1982 47 FR
     37342) authorized indefinitely the use of many types of
     "Non-PCB" (less than 50 ppm) electrical equipment.  These
     authorizations include: transformers, voltage regulators,
     capacitors,  electromagnets, switches, circuit breakers,
     reclosers, and cable.  For each of these categories, the
     "Electrical Equipment Rule" authorized use at the less than
     50 ppm level without any corresponding use conditions
     restricting that use.  In other words, as long as no fluids
     50 ppm or greater PCBs are introduced into such equipment,
     there are no restrictions on the servicing of this
     equipment, including its rebuilding.  Also,  intact "Non-PCB"
     electrical equipment is free from any requirement to obtain
     exemptions from the processing and distribution in commerce
     bans under TSCA.  Thus, this equipment is essentially free
     from TSCA regulation.

     Since the promulgation in 1979 of the PCB ban rule, drained,
     obsolete transformers  (formerly containing less than 50 ppm
     PCBs)  may be disposed of as salvage.  Although described as

                               X-6

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a form of unregulated disposal, a qualification on
permissible salvage operations is that they must bring about
the termination of the useful life of PCBs and PCB Items.
So, salvaging which accomplishes metals recovery through the
smelting of transformer components qualifies as "disposal"
under TSCA if the PCBs are eliminated by the smelting
process.

EPA has determined that recycling activities involving
equipment components with PCB concentrations less than 50
ppm do not present any significantly greater risks than
other activities connected with the unrestricted use and
servicing of "Non-PCB" electrical equipment.

Based upon this evaluation, EPA included "Non-PCB" equipment
components (when generated by authorized rebuilding or
salvaging) within the exclusion for "Excluded PCB Products."
These components may now be freely incorporated into other
electrical equipment, or distributed in commerce for the
purpose of reuse in electrical equipment provided the
components comply with the definition of "Excluded PCB
Products."
To summarize:

     •    Electrical equipment with PCB contamination less
          than 50 ppm may be dismantled (processed)  and the
          components reused in repair and rebuilding
          activities provided the components comply with the
          definition of "Excluded PCB Products" (761.3).

     •    Electrical equipment with PCB contamination less
          than 50 ppm may also be sold (distributed in
          commerce) to be dismantled (processed)  for reuse
          in repair and rebuilding activities provided the
          components comply with the definition of "Excluded
          PCB Products" (761.3).

     •    Drained electrical equipment with PCB
          contamination less than 500 ppm may be scrapped or
          salvaged for metals recovery as a method of
          unregulated disposal provided that: (1)  these
          practices do not result in spills or uncontrolled
          discharges of PCBs, and (2) these practices must
          bring about the termination of the useful life of
          PCBs or PCB Items.
          Drained electrical equipment with PCB
          contamination 50-499 ppm (known or assumed)  may
          not be dismantled (processed)  for the purpose of

                          X-7

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reusing the equipment components to repair or
rebuild other electrical equipment.

Drained electrical equipment with PCB
contamination 50-499 ppm (known or assumed)  may
not be sold or traded (distributed in commerce)
for the purpose of reusing the equipment
components to repair or rebuild other electrical
equipment.
                X-8

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                       CHAPTER XI
                     RECYCLED PCBS
                      AND EXCLUDED
                MANUFACTURING PROCESSES
Recycled PCBs  (page XI-1)

Excluded Manufacturing Processes  (page XI-2)

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       -RECYCLED PCBs AND EXCLUDED MANUFACTURING PROCESSES-
     The 1984 PCB  "Uncontrolled Rule" allowed the manufacture,
     processing, distribution in commerce, and use of certain
     PCBs  (less than 50 ppm) under the definitions of "Recycled
     PCBs" and  "Excluded Manufacturing Processes."
     RECYCLED PCBs

     EPA has concluded that excluding low-level PCB materials
     involved in certain recycling processes would not present an
     unreasonable risk to health or the environment.   EPA
     included within the definition of "recycled PCBs" two
     industries:  1) paper and pulp manufacturers, and 2)
     manufacturers of asphalt roofing materials.  Processes which
     recycle PCBs in paper products and asphalt roofing materials
     must meet the following requirements:

          •    There are no detectable concentrations of PCBs in
               asphalt roofing material products leaving the
               processing site.

          •    The concentration of PCBs in paper products
               leaving any manufacturing site processing paper
               products, or in paper products imported into the
               United States, have an annual average of less than
               25 ppm, and not exceeding a 50 ppm maximum at any
               given time.

          •    The release of PCBs at the point at which
               emissions are vented to ambient air must be less
               than 10 ppm.

          •    The amount of Aroclor PCBs added to water
               discharged from an asphalt roofing processing site
               must at all times be less than 3 micrograms per
               liter  (/ig/L) for total Aroclors  (roughly 3 parts
               per billion).  Water discharges from the
               processing of paper products must at all times be
               less than 3 micrograms per liter (^ig/L) for total
               Aroclors (roughly 3 ppb),  or comply with the
               equivalent mass-based limitation.

Ql:  Does the 3 parts per billion (ppb)  discharge limit for pulp
     and paper mills apply only to direct discharges?

Al:  Yes, the discharge limit for pulp and paper mills applies
     only to direct discharges.  It does not apply to paper mills
     that discharge into publicly owned treatment works (POTWs).


                               XI-1

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          Disposal of any other process wastes at
          concentrations of 50 ppm or greater must be in
          accordance with 761.60.
EXCLUDED MANUFACTURING PROCESSES

The 1984 PCB "Uncontrolled Rule" also amended the PCB
regulations by replacing the definitions of "Closed
Manufacturing Process" and "Controlled Waste Manufacturing
Process" with a generic exclusion now defined as "Excluded
Manufacturing Processes."  This established limits for PCB
releases in products, air emissions, water effluents, and
wastes.  In sum, EPA has prescribed a generic exclusion to
manufacture, process, distribute in commerce,  and use
inadvertently generated PCBs in accordance with the
definition of "Excluded Manufacturing Process" provided
that:

     •    PCBs in products leaving the manufacturing site
          are limited to an annual average of less than 25
          ppm, and not exceeding a 50 ppm maximum at any
          given time.

     •    Where the product is detergent bars, PCB
          concentrations in the product are limited to less
          than 5 ppm.

     •    PCBs added to water discharges from the
          manufacturing site are limited to less than 100
          micrograms per resolvable gas chromatographic peak
          per liter of water discharged.

     •    Releases of PCBs in air emissions are limited to
          less than 10 ppm at the point where emissions are
          vented.

     •    Disposal of any other process wastes at
          concentrations of 50 ppm or greater must be in
          accordance with 761.60.
                          XI-2

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                      CHAPTER XII






                PCB STORAGE REQUIREMENTS






PCB Storage For Disposal Facilities  (page XII-3)



Storage Options  (page XII-5)



Marking/Labeling  (page XII-6)



Handling Equipment  (page XII-6)



Inspections  (page XII-7)



Storage Containers  (page XII-7)



Storage Management  (page XII-9)

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               -PCB STORAGE REQUIREMENTS-
Storage of PCBs became regulated in 1979 with the
promulgation of the  "PCB Ban Rule."  Since those earliest
PCB regulations, the storage requirements for PCBs have
remained virtually unchanged but for a very few amendments
found in the 1982 "Electrical Equipment Rule."  However, the
improper storage of  PCBs remains one of the most frequent
areas of non-compliance based upon EPA inspection reports
from regional EPA offices.

Complying with the storage requirements for PCBs involves:

     •    Establishing a proper storage facility for PCBs.

     •    Utilizing proper containers for PCB storage.

     •    Managing PCB storage in accordance with marking,
          recordkeeping, and inspection requirements.

     •    Understanding which PCBs and PCB Items require
          storage and the various storage options which are
          available.

     •    Removal from storage and disposal of PCBs and PCB
          Items within the 1-year disposal time limitation.

PCB storage requirements apply to those PCBs and PCB Items
with PCB concentrations of 50 ppm or greater (or PCBs less
than 50 ppm as a result of dilution from 50 ppm or greater
material) including those PCBs and PCB Items which EPA
requires to be assumed to be 50 ppm or greater.  Generally,
PCB storage requirements apply to PCBs and PCB Items which
have been removed from service and designated for disposal.
However, PCB storage requirements also apply to any PCB
liquids  (50 ppm or greater)  in PCB Containers which are
being stored for authorized servicing of electrical
equipment.  PCB and PCB-Contaminated Electrical Equipment
being stored for reuse (stock)  is considered by the Agency
to be "in-service" and does not require storage in a PCB
storage facility.

The new Notification and Manifesting Rule adopts an approval
process for commercial PCB waste storers.  The term
"commercial storer" is defined broadly to mean any facility
that stores PCB wastes generated by others,  or that brokers
waste generated during electrical equipment servicing.

The rule allowed commercial storers a 180-day period of
interim approval (from February 5,  1990 to August 2,  1990),
within which they must have applied for approvals from their

                         XII-1

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     EPA Regional Administrators (or from the Director, CMD/OPPT
     for approval of commercial storage areas at disposal
     facilities approved by Headquarters).

     The issuance of a final storage approval will follow a
     review of the environmental compliance history of the
     company and its principals and key employees.  The Regional
     Administrator must be satisfied that the applicant is
     qualified to engage in the commercial  storage business.
     Also, applicants will be required to submit acceptable
     closure plans and demonstrate their financial responsibility
     for closure.  The requirement to demonstrate one's financial
     responsibility can generally be satisfied by one or more of
     the financial assurance mechanisms described in current RCRA
     regulations for hazardous waste facilities.  Finally,
     applicants will be required to certify their compliance with
     the TSCA storage facility standards,  and to estimate the
     maximum quantities of PCB waste that will be handled at the
     facility.

Ql:  Is electrical equipment being stored for "repair" considered
     "in use" or "removed from service" by EPA?

Al:  In the opening paragraph to the "Storage and Disposal"
     subpart of the PCB regulations (761.60), it is indicated
     that the regulations do not require "...removal of PCBs and
     PCB Items from service earlier than would normally be the
     case."  It is very important to understand that the term
     "removed from service," when used in the regulations,
     specifically means that PCBs and PCB Items have been
     designated for disposal to terminate or end the useful life
     which they were originally designed for.  In fact, it is the
     policy of the agency that once a PCB Item has been "removed
     from service" for disposal, it cannot  be placed back "in
     service" for continued use including repairing the item for
     further use.

     There has been considerable misunderstanding of the term
     "removed from service" by those in the regulated community,
     especially electric utilities that for years have considered
     electrical equipment being "changed out" and brought in from
     their system to be repaired, serviced, or placed back into
     stock for reuse as being "removed from service."  This is
     not what EPA means when the regulations refer to PCB Items
     being "removed from service."  To the  contrary, EPA
     considers electrical equipment being stored for repair
     and/or reuse to be just as "in use" as those on-line units
     being actively used within the electric system.

     On the other hand, questions have been raised about the
     continued legality of storing nonfunctional electrical
     equipment indefinitely for repair when the owner or user of

                              XII-2

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the equipment has no intention of actually repairing the
equipment or does not complete repairs within a reasonable
amount of time.  Such indefinite storage of equipment which
may ultimately be disposed of thwarts the intent of the 1-
year restriction on storage for disposal.  EPA promulgated
the storage for disposal requirements in the 1978 "Marking
and Disposal" Rule due to the concern that long-term storage
could lead to deterioration of PCB Containers and PCB
Articles and result in the release of PCBs'.  Consequently,
the agency may enforce against lengthy "storage for reuse"
of equipment which is not reasonably expected to be placed
back into service.
PCB STORAGE FOR DISPOSAL FACILITIES

Establishing a PCB storage facility which meets the criteria
listed under 761.65(b) does not necessarily require
tremendous expense, space, or technical engineering.  In
fact, many facilities which store small quantities of PCBs
and PCB Items are able to set up a designated PCB storage
area involving minimal space and expense but which complies
with all regulatory requirements.  On the other hand, some
facilities have need of larger, more elaborate PCB storage
facilities to meet the greater volume of PCBs and PCB Items
being processed and stored for disposal.  In either case,
owners or operators of facilities used for the storage of
PCBs and PCB Items shall comply with the following
requirements:

     •    The facility shall have adequate roof and walls to
          prevent rainwater from reaching the stored PCBs
          and PCB Items [761.65(b)(1)(i)].

     •    The facility shall have an adequate floor which
          has continuous curbing with a minimum 6-inch high
          curb.  The floor and curbing must provide a
          containment volume equal to at least two times the
          internal volume of the largest PCB Article or PCB
          Container stored therein or 25 percent of the
          total internal volume of all PCB Articles or PCB
          Containers stored therein, whichever is greater
          [761.65(b) (l) (ii)] .

     •    The facility shall have no drain valves, floor
          drains, expansion joints,  sewer lines, or other
          openings that would permit liquids to flow from
          the curbed area [761.65(b)(1)(iii)].

     •    The facility shall have floors and curbing
          constructed of continuous smooth and impervious
          materials,  such as portland cement concrete or

                         XII-3

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               steel, to prevent or minimize penetration of PCBs
               [761.65(b)(1)(iv)].

          •    The facility shall not be located at a site that
               is below the 100-year flood water elevation
               [761.65(b) (1) (v)] .

Q2:  Can PCBs be stored for disposal without having to set up a
     "PCB storage facility"?

A2:  The regulations include optional storage methods for PCBs
     such as "30-day temporary storage" by a generator and
     "pallet storage." (See Storage Options.)  However, in all
     cases where PCBs 50 ppm or greater (known or assumed) are
     stored for disposal for more than 30 days, a PCB storage
     facility is necessary.  Liquid PCBs 500 ppm or above may not
     be stored temporarily.

Q3:  Does a facility have to construct a special building
     specifically for PCB storage or can a portion of an existing
     building be used to properly store PCBs?

A3:  EPA does not require the construction of a separate building
     for proper storage of PCBs and PCB Items.  It is allowable
     to use an existing structure to act as a PCB storage
     facility provided all of the criteria of 761.65(b) are met.
     Also, the use of an entire building (whether new or
     existing)  solely for the storage of PCBs is not specifically
     required.  A designated area within the building reserved for
          PCB storage is permissible; however, in those instances
          where only a portion of a building is being used as a
     PCB  storage facility, that area should be clearly marked
     and  segregated from other activities within the structure.

Q4:  Do owners and users of PCBs have to pour expensive concrete
     floors and curbing to meet the criteria for a PCB storage
     facility,  or are other less expensive options available?

A4:  The PCB regulations specifically mention "adequate floors"
     and "continuous curbing" in the requirements for PCB storage
     facilities.  However, EPA has generally allowed flexibility
     in this area such as the use of a stock tank or metal box to
     meet the "berming" criteria requirement for a proper PCB
     storage facility.  These optional "berms" must be
     constructed of smooth impervious materials and must meet the
     minimum 6-inch height and volume requirements under
     761.65(b)(1)(ii).  Also, a stock tank or metal box must not
     have any drains, seams, or other openings that would permit
     liquids to flow from the containment area.
                              XII-4

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STORAGE OPTIONS

As mentioned earlier, the regulations outline two options
for storing PCBs in areas other than a  "PCB storage
facility."  These two storage options are often referred to
as "30-day temporary storage" and  "pallet storage."

"Thirty-day temporary storage"  [761.65(c)(1)] allows the
generator to store certain PCB Items in an area that does
not comply with the requirements for a PCB storage facility
for up to 30 days from the date of their removal from
service for disposal provided that a notation is attached  to
the PCB Item or PCB Container indicating the date the  item
was removed from service for disposal.  PCB Items which can
be stored under this 30-day temporary storage option
include:

     •    Nonleaking PCB Articles and PCB Equipment
          [761.65(c)(1)(i)].

     •    Leaking PCB Articles and PCB Equipment if the PCB
          Items are placed in a nonleaking PCB Container
          that contains sufficient sorbent materials to
          absorb any liquid PCBs remaining in the PCB  Items
          [761.65(c) (1) (ii)] .

     •    PCB Containers containing nonliquid PCBs such as
          contaminated soil,  rags, and debris [761.65(c)(1)
          (iii)J.

     •    PCB Containers containing liquid PCBs at a
          concentration between 50 and 500 ppm,  provided a
          Spill Prevention, Control, and Countermeasure Plan
          has been prepared for the temporary storage  area
          in accordance with 40 CFR 112.  In addition, each
          container must bear a notation that indicates that
          the liquids in the drum do not exceed 500 ppm PCB
          [761.65(c)(1)(iv)].

Another storage option outlined in the PCB regulations is
often referred to as "pallet storage."  Pallet storage
allows certain PCB Items to be stored temporarily on pallets
next to a PCB storage facility that meets the requirements
of 761.65(b)(1).  However,  pallet storage is permitted only
when the PCB storage facility has immediately available
unfilled storage space equal to 10 percent of the volume of
the PCB Items being stored on pallets next to the facility
[761.65 (c) (2)] .   PCB Items which can be stored under this
"pallet storage" option include:

     •    Nonleaking and structurally undamaged PCB large,
          high-voltage capacitors, and

                         XII-5

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          •    PCB-Contaminated Electrical Equipment (known or
               assumed 50-500 ppm) that have not been drained of
               free-flowing dielectric fluid [761.65 (c) (2)] .

     These PCB Items must be checked weekly when stored outside
     the facility and leaking PCB Items must be placed inside the
     storage area.

Q5:  Is the 30-day temporary storage option available for
     commercial storage and disposal facilities?

A5:  No. Temporary storage applies only to generators of PCB
     waste items since they are the only ones who have access to
     the PCB Items immediately after their removal from service
     for disposal.

Q6:  Does temporary storage provide generators of PCB waste with
     an additional 30 days to the 1-year storage and disposal
     time limitation?

A6:  No.  Thirty-day temporary storage is included in the total
     1-year storage and disposal time limitation.

Q7:  Is pallet storage allowed for a facility that doesn't have a
     PCB storage facility?

A7:  No. Pallet storage is only allowed when located next to a
     PCB storage facility that meets the requirements of
     761.65(b)(1).

Q8:  Does pallet storage have to be indoors?(

A8:  No, provided that the PCB Capacitors and/or PCB-Contaminated
     Electrical Equipment being stored for disposal are on
     pallets located adjacent to the building which houses the
     PCB storage facility.


     MARKING/LABELING

     All PCB storage areas including the "PCB storage facility"
     as well as "30-day temporary storage" and "pallet storage"
     areas must be marked/labeled in accordance with the EPA
     marking requirement at 761.40(a)(10).


     HANDLING EQUIPMENT

     Any movable equipment that is used for handling PCBs and PCB
     Items in the PCB storage facility, and that comes in direct
     contact with PCBs, shall not be removed from the storage
     facility area unless it has been decontaminated by swabbing

                              XII-6

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the surfaces that have contacted PCBs with a solvent that
meets the criteria of 761.79(a).  The solvent may be reused
for decontamination until it contains 50 ppm PCBs.  The
solvent and any nonliquid PCBs that result from the
decontamination must then be disposed of in accordance with
761.60(a) and 761.60(a)(4) respectively.
INSPECTIONS

All PCB Articles and PCB Containers in the PCB storage
facility must be inspected for leaks at least once every 30
days.  Any leaking PCB Articles and PCB Containers and their
contents shall be transferred immediately to properly marked
nonleaking containers.  Any spilled or leaked materials
shall be immediately cleaned up, using sorbents and/or other
adequate means, and the PCB-Contaminated materials and
residues shall be disposed of in accordance with PCB
disposal requirements  [761.65(c) (5) ] .

Any PCB Capacitors and PCB-Contaminated Electrical Equipment
stored adjacent to the PCB storage facility on pallets must
be inspected for leaks weekly [761.65 (c) (2)] .
STORAGE CONTAINERS

Containers used for the storage of PCBs (known or assumed 50
ppm or greater) shall comply with the shipping container
specifications of the Department of Transportation  (DOT).

Containers approved under TSCA at 761.65(c)(6) for the
storage of liquid PCBs include:

     •    DOT-5 steel drum without removable head

     •    DOT-SB steel drum without removable head

     •    DOT-6D overpack with DOT-2S or DOT-2SL molded
          polyethylene containers

     •    DOT-17E single trip steel drum without removable
          head

Containers approved for the storage of nonliquid PCBs
include:

     •    DOT-5 steel drum without removable head

     •    DOT-5B steel drum without removable head

     •    DOT-17C single trip steel drum with removable head

                         XII-7

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     As an alternate, containers larger than those specified in
     DOT specifications 5, 5B, or 17C may be used for nonliquid
     PCBs if the containers are designed and constructed in a
     manner that will provide as much protection against leaking
     and exposure to the environment as the DOT specification
     containers, and are of the same relative strength and
     durability as the DOT specification containers
     [761.65(c)(6)].

     Storage containers for liquid PCBs can be larger than the
     containers listed above  (i.e.,  bulk storage tanks)  provided
     that:

          •    The containers are designed, constructed, and
               operated in compliance with Occupational Safety
               and Health Standards  [29 CFR 1910.106] for
               flammable and combustible liquids
                [761.65(c)(7)(i)].

          •    Before using these containers/bulk tanks for
               storing PCBs, the design of the containers must be
               reviewed to determine the effect on the structural
               safety of the containers that will result from
               placing liquids with the specific gravity of PCBs
               into the containers  [761.65 (c) (7) (i)]  .

          •    Owners or operators of any facility using these
               containers/bulk tanks shall prepare and implement
               a Spill Prevention Control and Countermeasure
                (SPCC) Plan  [761.65(c)(7)(ii)].

Q9:   Can I use a storage container for PCB waste other than those
     specifically referenced in 761.65 (c) (6)?

A9:   Yes.  The PCB regulations, as currently written, essentially
     require the use of the "Cadillac" of 55-gallon drums for PCB
     containment, shipment, and storage.  The design
     specifications and engineering criteria used in the
     manufacture of these drums are, in DOT'S opinion, not really
     necessary, given the physical and chemical properties of
     PCBs.  Therefore, EPA will defer to the expertise of DOT as
     far as testing drums is concerned, and would allow the use
     of an alternate drum if it has been demonstrated to DOT'S
     satisfaction that the alternate container will protect
     against leaking and exposure to the environment of PCBs.

Q10: The regulations define a PCB Transformer as containing 500
     ppm or greater PCBs.  However,  there is no specific PCB
     level mentioned under the definition of a  "PCB Container."
     Has EPA established a regulatory PCB level for PCB
     Containers in relation to marking/labeling, storage, and
     recordkeeping?

                              XII-8

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A10: Yes.  The term "PCB Container" as found under the marking,
     storage, disposal, and recordkeeping sections of the TSCA
     regulations, specifically applies to drums, bulk tanks, and
     other containers  (defined under 761.3) containing PCBs in
     concentrations of 50 ppm or greater.  This 50 ppm regulatory
     level applies to  "PCB Article Containers" as well.

     Prior to disposal, an undrained PCB Container with PCB
     concentrations at 50 ppm or greater shall be stored in a PCB
     storage facility.  Unless decontaminated, a PCB Container
     containing PCBs in concentrations of 50 ppm or greater shall
     be disposed of in accordance with 761.60 (c) .   For a PCB
     Container to be decontaminated, it must be flushed three
     times with a solvent containing less than 50 ppm PCBs.  The
     solubility of PCBs in the solvent must be 5 percent or more
     by weight.   Each rinse shall use a volume of normal diluent
     equal to approximately 10 percent of the PCB Container
     capacity.  The solvent may be reused for decontamination
     until it contains 50 ppm PCB  [761.79(a)].  The solvent shall
     then be disposed of as liquid PCBs in accordance with
     761.60(a).   Nonliquid PCBs resulting from decontamination
     procedures shall also be disposed of in accordance with
     761.60(a)(4).
     STORAGE MANAGEMENT

     PCB storage management goes beyond simply setting up a PCB
     storage area and using proper DOT drums.  To effectively
     store PCBs and PCB Items in accordance with federal PCB
     regulations, a facility must also develop and maintain
     appropriate storage practices and storage records.

     PCB storage must be managed so that PCB Articles and PCB
     Containers can be located by the date they entered storage.
     To accomplish this, all PCB Articles and PCB Containers must
     be dated on the article or container when they are placed in
     the "PCB Storage Facility" [761.65 (c) (8)] .    Attaching dates
     to PCB Articles and PCB Containers applies to "30-day
     temporary storage" and "pallet storage" as well.

     Owners or operators of facilities which store PCBs and PCB
     Items must establish and maintain records on the storage and
     disposition of PCBs in accordance with 761.180(b).  (See
     chapter XV, on "Recordkeeping and Reporting," for a detailed
     discussion of PCB storage records.)   For PCB Containers,
     these records should include:  container contents, PCB
     concentration (ppm),  the container's total volume, unique
     identification number, date placed in transport for
     disposal, and date disposed of, if known.  These records
     will form the basis of a required "Annual Records" to be
     prepared by the facility, and therefore the information

                              XII-9

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     should be carefully logged and maintained for future need.
     If a facility is utilizing "bulk" storage of PCBs in
     containers/bulk tanks larger than 55-gallon DOT drums, the
     facility must also maintain records for each batch of PCBs
     added to the containers.  These records must include the
     quantity of the batch and the date the batch was added to
     the container.  The records shall also include the date,
     quantity, and disposition of any batch of PCBs removed from
     the container [761.65(c) (8) ] .

     Finally, PCB storage must be managed so that PCB Articles
     and PCB Containers stored for disposal are removed from
     storage and disposed of within 1 year from the date the
     articles were removed from service for disposal or the first
     batch of PCBs was placed in the container for storage for
     disposal.

Qll: The regulations indicate that PCBs must be disposed of
     within 1 year.  How long can PCBs be stored for disposal
     prior to shipment to the final disposal site?

All: The PCB regulations require the disposal of PCBs within the
     1-year disposal deadline.  EPA has adopted a written policy
     (TSCA Compliance Program Policy No. 6-PCB-6) which provides
     that a generator delivering PCB waste to a disposal facility
     later than 90 days before the end of 1-year disposal
     deadline will be held liable if the disposal facility cannot
     dispose of the waste in time.   If the generator delivers the
     waste with 90 days or more remaining in the 1-year deadline,
     the disposer is responsible for disposing of the material
     before the deadline.  The disposer will share in any
     liability if he does not dispose of PCB waste within 90 days
     from the date it is received at the disposal facility.  In
     sum, the generator has 9 months of the 1-year disposal
     timeframe to store PCBs and transport those PCBs to the
     final disposition site.

Q12: As a generator of PCB waste,  our facility regularly
     contracts a disposal "broker"  to pick up and transport our
     PCB waste to a PCB disposal site.  Normally, these "brokers"
     will transport our PCB waste to their facility for storage
     and consolidation with PCB waste from other generators.  How
     long can our PCB waste be stored by a broker?

A12: A disposal "broker" is merely an extension of the generator
     in terms of the 1-year disposal deadline.  That is, the
     generator remains liable if the disposal "broker" fails to
     deliver the PCB waste to the disposal site in time for the
     waste to be disposed of within the 1-year deadline.  In sum,
     EPA places the responsibility for delivering PCB waste to a
     disposal facility at least 90 days before the 1-year
     deadline on the generator of the waste and does not allow

                              XII-10

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additional time for PCB waste to be processed and/or stored
by disposal brokers or commercial storage facilities.
                        XII-11

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                           CHAPTER XIII

                    PCB DISPOSAL  REQUIREMENTS


PCB Liquids with Concentrations of  500 ppm  or Greater
(page XIII-1)

Mineral Oil Dielectric Fluid and  Other Liquids  (50-499  ppm PCB)
(page XIII-1)

Nonliquid PCBs  (50 ppm or Greater)  (page XIII-2)

PCB Transformers  (500 ppm or Greater  PCB)  (page  XIII-2)

PCB Capacitors  (page XIII-2)

Large, High- or Low-Voltage PCB Capacitors  (page XIII-3)

Small PCB Capacitors  (page XIII-3)

PCB-Contaminated Electrical Equipment  (50-499 ppm  PCB)
(page XIII-3)

PCB Containers  (page XIII-3)

PCB Hydraulic Machines  (page XIII-4)

Other PCB Articles  (page XIII-4)

Dredged Materials and Municipal Sewage Treatment Sludge
(page XIII-4)

Spills (page XIII-5)

Alternative Disposal Methods (page  XIII-5)

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             - PCB DISPOSAL REQUIREMENTS -
Disposal of PCBs became regulated in 1978 with the
promulgation of the "PCB Marking and Disposal" Rule.  In
this final Rule, EPA prescribed various disposal
requirements for PCBs and PCB Items, and also established
the 500 parts per million (ppm) regulatory cutoff for the
disposal of PCBs.  In the "PCB Ban Rule" published in the
Federal Register on May 31,  1979 (44 FR 31514), the
regulatory cutoff for PCBs was changed from 500 to 50 ppm.
In that same Federal Register. EPA published its "anti-
dilution" provision [40 CFR 761.1(b)] which effect the
disposal of 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.
PCB LIQUIDS WITH CONCENTRATIONS OF 500 PPM OR GREATER

All PCB liquids and industrial sludges with PCB
concentrations of 500 ppm or greater must be disposed of in
a TSCA incinerator that complies with 761.70  [761.60(a)(1)]
or by an alternate method permitted under 761.60(e).
MINERAL OIL DIELECTRIC FLUID AND OTHER LIQUIDS  (50-499 ppm
PCB) - 761.60(a)(2) and (3)

Mineral oil dielectric fluid from PCB-contaminated
electrical equipment containing a PCB concentration of 50-
499 ppm (known or assumed) and liquids other than mineral
oil dielectric fluid containing a PCB concentration of 50-
499 ppm, must be disposed of in one of the following:

     •    In a TSCA incinerator that complies with 761.70.

     •    In a chemical waste landfill that complies with
          761.75 if information is provided to the owner or
          operator of the chemical waste landfill that shows
          that the mineral oil dielectric fluid does not
          exceed 500 ppm PCB and is not an ignitable waste
          as described in 761.75(b) (8) (iii) .   (NOTE:  After
          July 8, 1987 land disposal of liquid hazardous
          wastes containing 50 ppm or greater PCB is
          prohibited under the Land Disposal Reduction
          Program of RCRA, unless an exemption is granted.)

     •    In a high efficiency boiler that complies with
          761.60(a) (2) (iii) (A) .

                        XIII-1

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          By an alternative EPA approved method that
          complies with 761.60(e), such as chemical
          detoxification, biological treatment, and physical
          separation.
NONLIOUID PCBs (50 ppm OR GREATER) - 761.60(a)(4)

Nonliquid PCBs at concentrations of 50 ppm or greater in the
form of contaminated soil, rags, or other debris must be
disposed of in one of the following:

     •    In an incinerator that complies with 761.70.

     •    In a chemical waste landfill that complies with
          761.75.  (NOTE:  Except as provided in
          761.75(b) (8)  (ii),  liquid PCBs shall not be
          processed into nonliquid forms to circumvent the
          high temperature incineration requirements of
          761.60(a).

          By an alternate method permitted under 761.60 (e) .

PCS TRANSFORMERS (500 ppm OR GREATER PCB) - 761.60(b) (1)

PCB Transformers with PCB concentrations 500 ppm or greater
must be disposed of in accordance with either of the
following:

     •    In an incinerator that complies with 761.70.

     •    In a chemical waste landfill that complies with
          761.75 provided that the transformer is first
          drained of all free-flowing liquid, filled with
          solvent,  allowed to stand for at least 18 hours,
          and then drained thoroughly.  PCB liquids and
          solvents that are removed shall be incinerated in
          accordance with 761.60(a).  Solvents may include
          kerosene, xylene,  toluene, and other solvents in
          which PCBs are readily soluble (5% or more).

     . By an alternate method permitted under 761.60(e).
PCB CAPACITORS - 761.60(b)(2)

The disposal of any capacitor shall comply with the
following requirements unless it is known from label or
nameplate information, manufacturer's literature, or
chemical analysis  (test results) that the capacitor does not
contain PCBs.
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LARGE. HIGH- OR LOW-VOLTAGE PCS CAPACITORS -
761.60(b) (2) (iii)

Any large, high- or low-voltage capacitor which contains 500
ppm or greater PCBs must be disposed of in an incinerator
that complies with 761.70 or through an alternate method
permitted under 761. 60 (e).
SMALL PCS CAPACITORS - 761.60(b)(2)(ii)

Intact, nonleaking PCB small capacitors may be disposed of
as municipal solid waste except that manufacturers who at
any time manufactured PCB small capacitors or equipment
containing a PCB small capacitor must dispose of PCB small
capacitors in an incinerator that complies with 761.70.
Small capacitors that are not intact or are leaking must be
incinerated.  EPA recommends that disposers of large
quantities of small PCB capacitors dispose of them in a
TSCA-approved incinerator.  Readers are advised to check
with their Regional PCB Coordinator to determine the
specific regional policy on disposal of small capacitors.
PCB-CONTAMINATED ELECTRICAL EQUIPMENT (50-499 DPm PCB) -
761.60(b)(4)

PCB-contaminated electrical equipment, except capacitors,
with PCB contamination 50-499 ppm shall be disposed of by
draining all free-flowing liquid from the electrical
equipment and disposing of the liquid in accordance with
761.60(a)(2) or (3).  The disposal of the drained carcass is
not regulated.

Capacitors that contain 50-499 ppm PCBs must be disposed of
in an incinerator that complies with 761.70 or in a chemical
waste landfill that complies with 761.75.
PCB CONTAINERS - 761.60(c)

Unless decontaminated in accordance with 761.79, PCB
Containers with PCB concentrations of 500 ppm or greater
must be disposed of in one of the following:

     •    In an incinerator that complies with 761.70.

     •    In a chemical waste landfill that complies with
          761.75 provided that if there are PCBs in a liquid
          state, the PCB Container shall first be drained
          and the PCB liquid disposed of in accordance with
          761.60(a)(2)  or (3).

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PCB Containers that used to contain PCB concentrations less
than 500 ppm may be disposed of as municipal solid wastes,
provided that the container is drained of any liquid PCBs
and any liquid PCBs in concentrations 50 ppm or greater are
disposed of in accordance with 761.60(a)(2)  or (3).   The
container must also be emptied of any PCB solids 50 ppm or
greater, and the solids disposed of in accordance with
761.60(a)(4).
PCB HYDRAULIC MACHINES - 761.60(b)(3)

PCB hydraulic machines containing PCBs at concentrations of
50 ppm or greater such as die casting machines may be
disposed of as municipal solid waste or salvage provided
that the machines are drained of all free-flowing liquid and
the liquid is disposed of in accordance with 761.60(a) (2) or
(3).  If the PCB liquid contains 1000 ppm or greater, then
the hydraulic machine must be flushed prior to disposal with
a solvent containing less than 50 ppm PCB and the solvent
disposed of in accordance with 761.60(a).
OTHER PCB ARTICLES - 761.60(b)(5)

Other PCB Articles with PCB concentrations at 500 ppm or
greater must be disposed of in one of the following:

     •    In an incinerator that complies with 761.70.

     •    In a chemical waste landfill that complies with
          761.75, provided that all free-flowing liquid PCBs
          have been thoroughly drained from any articles
          before the articles are placed in the chemical
          waste landfill and that the drained liquids are
          disposed of in an incinerator that complies with
          761.70.

Other PCB Articles with PCB concentrations at 50-499 ppm
must be disposed of by draining all free-flowing liquid from
the article and disposing of the liquid in accordance with
761.60(a)(2) or  (3).  The disposal of the drained article is
not regulated.
DREDGED MATERIALS AND MUNICIPAL SEWAGE TREATMENT SLUDGE

All dredged materials and municipal sewage treatment sludge
with PCB concentrations of 50 ppm or greater must be
disposed of in an approved incinerator or j.n an approved
chemical waste landfill, or by an approved alternative
method.

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SPILLS

Spills are included within the definition of "Disposal" at
761.3.  Spills of PCBs at 50 ppm or greater are illegal
disposal.  PCBs that result from the cleanup of spills must
be stored for disposal and disposed of according to the
applicable regulations  [761.60(d)(1) and  (2)].
ALTERNATIVE DISPOSAL METHODS - 761.60(e)

Any person who is required to incinerate any PCBs and PCB
Items as discussed in this chapter, and who can demonstrate
that an alternative method of destroying PCBs and PCB Items
exists and that this alternative method can achieve a level
of performance equivalent to 761.70 incinerators or high
efficiency boilers as provided in 761.60(a)(2) and  (3), may
submit a written request to either the Regional
Administrator or the Director of the Chemical Management
Division  (CMD) for an exemption from the incineration
requirements of 761.70 or 761.60.  Requests for approval of
alternate methods that will be operated in more than one
region must be submitted to the Director of CMD except for
research and development involving less than 500 pounds of
PCB material.  Requests for approval of alternate methods
that will be operated in only one region must be submitted
to the appropriate Regional Administrator.  The applicant
must show that his method of destroying PCBs will not
present an unreasonable risk of injury to health or the
environment.  On the basis of such information and any
available information, the Regional Administrator or the
Director of CMD may, in his discretion, approve the use of
the alternate method if he finds that the alternate disposal
method provides PCB destruction equivalent to disposal in a
761.70 incinerator or a 761.60 high efficiency boiler and
will not present an unreasonable risk of injury to health or
the environment.  Any approval must be stated in writing and
may contain such conditions and provisions as the Regional
Administrator or the Director of CMD deems appropriate.  The
person to whom such waiver is issued must comply with all
limitations contained in such determination.

Guidance documents for submitting alternate disposal method
applications are available from the Operations Branch (7404)
at EPA Headquarters in Washington,  D.C.
                         XIII-5

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                           CHAPTER XIV


                     PCB SPILL CLEANUP POLICY


Scope of the Policy  (page XIV-3)

Key Definitions  (page XIV-5)

PCB Spill Reporting Requirements  (page XIV-8)

Determination of Spill Boundaries  (page XIV-9)

Cleanup, Recordkeeping, and Testing Requirements  (page XIV-9)

Small, Low-Concentration Spills  (page XIV-9)

Large, Low-Concentration Spills and High-Concentration Spills
  (page XIV-12)

Excluded Spills  (page XIV-16)

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              - PCS SPILL CLEANUP POLICY -
EPA promulgated regulations on the disposal of PCBs in the
Federal Register on February 17, 1978 and May 31, 1979.
These early PCB regulations broadly defined the term
"disposal" to include accidental as well as intentional
releases of PCBs into the environment.   Under these
regulations, EPA considers intentional, as well as
unintentional, spills, leaks, and other uncontrolled
discharges of PCBs at concentrations of 50 parts per million
or greater to be "improper disposal" of PCBs.  When PCBs are
improperly disposed of as a result of a spill of a material
containing 50 ppm or greater PCBs, EPA has the authority to
compel persons to take actions to rectify damage and/or
cleanup contamination resulting from the spill.

For many years now, EPA standards for the cleanup of spilled
PCBs have been established at the EPA Regional Office level.
Each region established PCB spill cleanup standards in the
form of general guidelines and then applied the general
guidelines on a case-by-case basis for specific spill
situations.  Owners of spilled PCBs were required to meet
these standards or face potential penalties for improper
disposal of PCBs.

In establishing PCB spill cleanup standards on a regional
basis, EPA has experienced inconsistency in the general
guidelines and their application to spills from region to
region.  For certain spill situations,  EPA Regional Offices
have required cleanup only to 50 ppm PCBs.  In other spill
situations, regions have required cleanup to preexisting
background levels,  or to the limit of detection of PCBs.
Most recently, EPA Regional Offices have applied the "lowest
practicable level"  guidelines set up in the January 27,
1984, decision on "General Electric v.  U.S.E.P.A."  However,
the agency has experienced several areas of difficulty in
applying the "lowest practicable level" approach to all PCB
spills.  First,  the guideline is subject to, and has
resulted in, disparate interpretations.  Second,  the term
"lowest practicable level" cannot be easily applied by the
regulated community without guidance from EPA,  potentially
resulting in delays in cleanup and prolonged exposures to
humans and more widespread environmental contamination.
Finally, the owner of PCBs may disagree with the EPA
Regional Office's interpretation of the "lowest practicable
level" standard.   This may occur when the EPA Regional
Office interpretation would require more stringent and
costly measures than the owner believes are warranted.
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When addressing the subject of PCB spills, EPA has
emphasized two very important ingredients.  First, the
timely cleanup of PCB spills.  And second, establishing
prudent, yet practicable, numerical criteria standards for
PCB spills cleanup.  Since 1982, EPA has had in place
requirements for timely cleanup of certain PCB spills 50 ppm
or greater.  In the final PCB Electrical Equipment Rule
published August 25, 1982, EPA required the initiation of
spill cleanup from a PCB Transformer (500 ppm or greater)
within 48 hours of spill discovery.  However, the issue of
timely cleanup of PCB spills from sources other than PCB
Transformers (i.e., PCB Capacitors, PCB-Contaminated
Electrical Equipment, etc.) was not addressed; and,  the PCB
Electrical Equipment Rule did not establish final cleanup
standards for PCB spills.

Even though EPA did not finalize a PCB spill cleanup policy
in 1982, the Agency has continued to evaluate available
information on the risks posed by spilled PCBs and the costs
associated with cleanup to various levels.  EPA recognized
that setting a nationwide PCB spill cleanup policy was a
desirable goal and in the winter of 1984 produced a draft
TSCA Compliance Monitoring Program Policy covering PCB spill
cleanup.  Although the 1984 draft was never officially
released, members of the press and the public acquired and
reviewed the draft policy.  The Environmental Defense Fund
(EDF), National Resources Defense Council (NRDC), Edison
Electric Institute  (EEI), Chemical Manufacturers Association
(CMA), and National Electrical Manufacturers Association
(NEMA), among others, were principal reviewers of the 1984
draft policy.  On May 17, 1985, EDF, NRDC, EEI, CMA, and
NEMA submitted to EPA an alternative PCB spill cleanup
policy for consideration by the Agency.  EPA viewed this
alternative cleanup policy  (referred to as the "Consensus
Agreement") as a framework for completing its nationwide PCB
spill cleanup policy and evaluated the Consensus Agreement
as a source of information in developing the Agency's own
policy.  The Agency and the Consensus Group shared two
general principles about the appropriate framework for a
nationwide PCB spills cleanup policy:  (1) that the policy
should establish requirements designed to be effective in
the large majority of spill situations; and,  (2) that the
risks posed by residual contamination  (PCBs remaining after
cleanup) vary depending upon the potential for human
exposures.

Because of the tremendous variety of PCB spill situations,
developing a nationwide cleanup policy which incorporated
timely cleanup with prudent numerical cleanup standards
while at the same time maintaining a format that was
practicable in areas of cost and implementation for the
regulated community proved to be a very complicated and

                         XIV-2

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time-consuming task for the Agency.  Consequently, EPA has
developed its National PCB Spill Cleanup Policy based upon
what the Consensus Group and others have indicated are the
more "typical" and thus most common types of PCB spills, as
well as the costs associated with cleanup following these
most common types of spills.  Typical PCB spills involve the
limited release of PCBs during the course of EPA authorized
activities such as: the use of electrical equipment (e.g.,
transformers and capacitors), the servicing of electrical
equipment, and the storage for disposal of PCBs.

In establishing the cleanup policy for typical PCB spills,
EPA recognized that the risks posed by spills of PCBs vary,
depending upon the spill location and the amount of PCBs
spilled.  Therefore, the PCB Spill Cleanup Policy now
requires cleanup of PCBs to different levels depending upon
spill location, the potential for exposure to residual PCBs
remaining after cleanup, the concentration of the PCBs
initially spilled, and the nature and size of the population
potentially at risk of exposure.  Thus, the policy applies
the most stringent requirements for PCB spill cleanup to
areas where there is the greater potential for human
exposures to spilled PCBs.  The policy applies less
stringent requirements for cleanup of PCB spills in areas
where the type and degree of contact present lower potential
exposures.  Finally, even less stringent requirements apply
to areas where there is little potential for any direct
human exposure.
SCOPE OF THE POLICY

The PCB Spill Cleanup Policy establishes requirements for
the cleanup of spills resulting from the release of
materials containing PCBs at concentrations of 50 ppm or
greater including materials which EPA requires to be assumed
50 ppm or greater (i.e., untested mineral oil dielectric
fluid).   The policy became effective on May 4, 1987, and
applies only to spills which occur after that date.
Existing spills which occurred prior to May 4, 1987 are
excluded from the policy and are to be cleaned up in
accordance with requirements established at the discretion
of EPA,  usually through its Regional offices.

In addition, EPA excluded certain PCB spills from the policy
based upon location.  PCB spills which contaminate surface
water, drinking water, sewers, animal grazing lands, and
vegetable gardens are excluded from the final cleanup
standards in the policy because these spills, due to their
location, potentially pose significantly greater exposure
risks to humans than those "typical" spills around which the
policy has been developed.  For these "excluded" spills, the

                         XIV-3

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     responsible party shall report the spill to the Regional EPA
     Office and clean up the spill in accordance with site-
     specific requirements established by the EPA Regional
     Office.  For all other PCB spills, EPA generally expects the
     final cleanup standards of the policy to apply.  In sum:

          •    EPA's PCB Spill Cleanup Policy went into effect
               May 4, 1987.

          •    The policy applies to all PCB spills in
               concentrations 50 ppm or greater (known or
               assumed) which occur after May 4, 1987, except for
               certain "excluded" spills which occur in higher
               risk locations.

          •    "Excluded" spills are those which contaminate
               surface water,  drinking water, sewers,  animal
               grazing lands,  and vegetable gardens.  The cleanup
               levels found in the PCB Spill Cleanup Policy do
               not automatically apply to these spills.  These
               spills must be reported to the appropriate EPA
               Regional Office no later than 24 hours after
               discovery and cleaned up in accordance with site-
               specific requirements as established by the
               Regional EPA Office.  These spills are subject to
               all measures to minimize environmental
               contamination in the policy.

Ql:  Why does EPA refer to these new cleanup requirements as
     "policy" instead of "regulations"?

Al:  It is important to note that the PCB Spill Cleanup Policy is
     an EPA policy statement which applies to existing
     "spill/improper disposal" regulations.  That is to say, when
     a PCB spill occurs,  under existing regulations, "improper
     disposal" has taken place.  The PCB Spill Cleanup Policy
     provides a nationwide set of uniform reporting, cleanup, and
     recordkeeping standards which, if followed precisely,
     creates a presumption against both enforcement action for
     penalties and for further cleanup under TSCA.  It is not a
     regulatory requirement that a PCB spill be cleaned up in
     accordance with the spill policy; however, if a responsible
     party wants EPA to presume that the responsible party should
     not receive penalties from EPA 'for improper disposal due to
     a PCB spill, the PCB Spill Cleanup Policy must be precisely
     followed.
                              XIV-4

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     KEY DEFINITIONS

     The following are a few of the key definitions found in the
     PCS Spill Cleanup Policy.  All of the definitions listed in
     the policy are not discussed here.  Responsible parties
     should refer to 40 CFR Part 761.123 for a detailed list of
     all definitions found in the policy.

          •    "Spill" - The term as used in the policy means
               both intentional and unintentional spills, leaks,
               and other uncontrolled discharges where the
               release results in any quantity of PCBs running
               off or about to run off the external surface of
               the equipment or other PCB source, as well as the
               contamination resulting from those releases.  The
               policy applies to spills of 50 ppm or greater
               PCBs.  The concentration of PCBs spilled is
               determined by the PCB concentration in the
               material spilled as opposed to the concentration
               of PCBs in the material onto which the PCBs were
               spilled.  Where a spill of untested mineral oil
               occurs, the oil is presumed to contain greater
               than 50 ppm, but less than 500 ppm PCBs, and is
               subject to the relevant requirements of the
               policy.

Q2:  The spill policy defines "spill" by including the word
     "leak" in the definition.  Does this mean that all minor
     "leaks" from electrical equipment must be cleaned up in
     accordance with the spill policy?

A2:  No.  The spill policy only applies to leaks where "...the
     release results in any quantity of PCBs running off or about
     to run off the external surface of the equipment."  EPA has
     differentiated between these types of "migrating" leaks
     which have or are about to contaminate other materials.  The
     policy does not apply to minor seepage ("weeps")  from
     electrical equipment bushings or coverplates.  However, it
     is important to understand that a minor leak of this type is
     still considered "improper disposal" of PCBs and must be
     controlled,  repaired,  and cleaned up by authorized servicing
     of electrical equipment if the responsible party wishes to
     continue to use or store for reuse the electrical equipment
     and avoid improper disposal penalties from EPA.

          •    "Low-concentration PCBs" - This term means PCBs
               that are tested and found to contain less than 500
               ppm PCBs or those PCB-containing materials which
               EPA allows to be assumed to be at concentrations
               below 500 ppm (i.e., untested mineral oil
               dielectric fluid).   Consequently, a "low-
               concentration" spill as referred to in the policy

                              XIV-5

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               is a spill of material containing PCBs in
               concentrations of 50-499 ppm,  including spills of
               untested mineral oil which must be assumed to be
               50-499 ppm.

          •    "High-concentration PCBs" - This term means PCBs
               that contain 500 ppm or greater PCBs, or those
               materials which EPA requires to be assumed to
               contain 500 ppm or greater PCBs in the 'absence of
               testing.  Consequently, a "high-concentration"
               spill as referred to in the policy is a spill of
               material containing PCBs in concentrations of 500
               ppm or greater, including spills of material which
               must be assumed to be 500 ppm or greater  (e.g., an
               untested transformer with no nameplate).

          •    "Outdoor electrical substations" - Outdoor
               electrical substations are outdoor, fenced-off,
               and restricted access areas used in the
               transmission and/or distribution of electrical
               power.  For purposes of the spill policy, outdoor
               electrical substations are defined as being
               located at least 0.1 kilometer  (km) from a
               residential/commercial area.  Outdoor electrical
               substations which are located less than 0.1 km
               from a residential/commercial area are considered
               to be residential/commercial areas.

Q3:  If a PCB spill occurs in an outdoor electrical substation
     located more than 0.1 kilometer from a residential/
     commercial building but less than 0.1 kilometer from the
     residential/commercial property boundary line, should the
     spill be cleaned up as an outdoor electrical substation
     spill or a residential/commercial spill?

A3:  EPA has established that when determining which spills fall
     under the cleanup requirements for "outdoor electrical
     substations," versus the more stringent cleanup requirements
     for "residential/commercial areas," the responsible party
     shall measure the 0.1 kilometer distance  "...from the actual
     site of the spill to the edge of the building where people
     live or reside, or work."


          •    "Double wash/rinse" - The double wash/rinse
               procedural performance standard applied in the
               policy means a minimum requirement to cleanse
               solid surfaces two times with an appropriate
               solvent or other material in which PCBs are at
               least 5 percent soluble  (by weight).  A volume of
               PCB-free fluid sufficient to cover the
               contaminated surface completely must be used in

                              XIV-6

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               each wash/rinse.  The wash/rinse requirement does
               not mean the mere spreading of solvent or other
               fluid over the surface, nor does the requirement
               mean the once-over wipe with a soaked cloth.
               Precautions must be taken to contain any runoff
               resulting from the cleansing and to dispose
               properly of wastes generated during the cleansing.

Q4:  Can liquid cleaners and/or detergents be used throughout the
     double wash/rinse procedure, or must more conventional
     solvents such as kerosene be used?

A4:  The spill policy allows the use of "other materials" in the
     double wash/rinse procedure provided that PCBs are at least
     5 percent soluble by weight in the material.  Currently, EPA
     has very little information on the effectiveness of
     utilizing various detergents and cleaners in PCB spills
     cleanup.  The Agency is most interested in receiving input
     in this area and encourages those in the regulated oommunity
     to submit relevant data pertaining to various detergents and
     other cleanup materials.

          •    "Standard wipe test" - For spills of high
               concentration PCBs and large,  low-concentration
               spills, the policy requires cleanup of solid
               surfaces to numerical surface standards and
               sampling by a standard wipe test to verify that
               the numerical standards have been met.  This
               definition constitutes the minimum requirements
               for an appropriate wipe-testing protocol.  A
               standard-size template (10 centimeters by 10
               centimeters)  will be used to delineate the area of
               cleanup; the wiping medium will be a gauze pad or
               glass wool of known size which has been saturated
               with hexane.   It is important that the wipe be
               performed very quickly after the hexane is exposed
               to air.

          •    "Spill area" - This means the area of soil on
               which visible traces of the spill can be observed
               plus a buffer zone of 1 foot beyond the visible
               traces.  Any surface or object (e.g., concrete
               sidewalk or automobile) within the visible traces
               area, or on which visible traces of the spilled
               material are observed, is included in the spill
               area.  This area represents the minimum area
               assumed to be contaminated by PCBs in the absence
               of precleanup sampling data and is thus the
               minimum area which must be cleaned.
                              XIV-7

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          •    "Spill boundaries" - This term means the actual
               area of contamination as determined by postcleanup
               verification sampling, or by precleanup sampling
               to determine actual spill boundaries.  EPA can
               require additional cleanup when necessary to
               decontaminate all areas within the spill
               boundaries to the levels required in the policy.

Q5:  What is the difference between the "spill area" and the
     "spill boundaries"?

A5:  The "spill area" is simply that area where traces of the
     spilled material can be seen plus a 1-foot buffer zone.  The
     "spill boundaries" on the other hand means the actual area
     of contamination and includes contamination that might not
     be visible with the naked eye.


     PCS SPILL REPORTING REQUIREMENTS

     EPA has established two basic reporting requirements for PCB
     spills under the TSCA spill policy.  In addition, reporting
     may also be required under the Clean Water Act (CWA) or
     Comprehensive Environmental Response Compensation and
     Liability Act (CERCLA).   For example, under the CERCLA
     National Contingency Plan, all spills involving 1 pound or
     more of PCB material must currently be reported to the
     National Response Center  (NRC) at 1-800-424-8802.  The
     reporting requirements found in the PCB Spill Policy are
     designed to be consistent with existing reporting
     requirements found in other regulatory acts.  Simply stated,
     only those PCB spills occurring in certain high-risk areas,
     or PCB spills involving a significant volume of PCBs
     spilled, are required to be reported under the TSCA PCB
     Spill Cleanup Policy.  These are:

          •    All PCB spills, 50 ppm or greater, which
               contaminate surface waters, sewers and sewer
               treatment plants, private or public drinking water
               sources, animal grazing lands, and vegetable
               gardens must be reported to the appropriate EPA
               Regional Office of Pesticides and Toxic Substances
               (see page xiv of this document) in the shortest
               possible time after discovery, but in no case
               later than 24 hours after discovery.

          •    All PCB spills, 50 ppm or greater, involving 10
               pounds or more of PCBs  (generally 1 gallon of
               Askarel) must be reported to the appropriate EPA
               Regional Office of Toxics and Pesticides in the
               shortest possible time after discovery but in no
               case later than 24 hours after discovery.

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Q6:  When the spill policy refers to 10 pounds or more of PCBs,
     is the requirement to report a spill of 10 pounds or more of
     PCB containing material  (i.e., oil and PCBs), or 10 pounds
     or more of actual PCBs on a dry-weight basis?

A6:  The reporting requirement specified in the PCB spill policy
     only requires "...spills of 10 pounds of pure PCBs or more
     by weight to be reported."

     NOTE:  As of August 14, 1989, EPA changed the reportable
     quantity for PCBs to 1 Ib. under the CERCLA National
     Contingency Plan, so that spills of 1 Ib. or more of PCBs
     must be reported to the National Response Center.  The PCB
     Spill Cleanup Policy has not been revised to reflect this
     change.  Consequently, a 1 Ib. or greater PCB spill must be
     reported to the NRC but not to EPA.  A PCB spill of 10 Ibs.
     or more must be reported to the appropriate Regional
     Administrator.
     DETERMINATION OF SPILL BOUNDARIES

     For spills where there are insufficient visible traces yet
     there is evidence of a leak or spill, the boundaries of the
     spill are to be determined by testing the area for PCBs
     using a statistically based sampling scheme.  (See
     Sampling/Testing Requirements.)
     CLEANUP. RECORDKEEPING. AND TESTING REQUIREMENTS

     The PCB Spill Cleanup Policy establishes four categories of
     PCB spills:  (1)  small, low-concentration spills, (2)  large,
     low-concentration spills,  (3)  high-concentration spills, and
     (4) excluded spills.  As discussed earlier,  EPA recognized
     that the risks posed by spills of PCBs vary, depending upon
     the spill location and the amount of PCBs spilled.
     Therefore,  the spill policy requires cleanup of PCBs to
     different levels depending upon spill location, the
     potential for exposure to residual PCBs remaining after
     cleanup, the concentration of PCBs initially spilled, and
     the nature and size of the population potentially at risk of
     exposure.  The following is a general overview of the
     various cleanup, recordkeeping, and testing requirements
     found in the policy.  Responsible parties should refer to 40
     CFR 761.125 and 761.130 for detailed information.
     SMALL.  LOW-CONCENTRATION SPILLS

     Small,  low-concentration spills are spills of materials
     containing 50-499 ppm PCBs and which involve less than 1

                              XIV-9

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     pound of PCBs by weight or less than 270 gallons of untested
     mineral oil.   These spills are considered to be the most
     typical and most common types of spills and usually involve
     smaller quantities of low-level PCBs.  Consequently, EPA has
     established a basic "performance standard" for proper
     cleanup of spills of this type and requires specific records
     and statements of certification to be documented and
     maintained by the responsible party.

          •    CLEANUP REQUIREMENTS:

               (1)  All contaminated solid surfaces must be
                    double washed/rinsed.
               (2)  Any contaminated indoor, residential surfaces
                    must be cleaned to 10 micrograms per 100
                    square centimeters (10 /xg/100 cm2) .
               (3)  All soil within the spill area  (i.e., visible
                    traces plus a 1 lateral foot buffer) must be
                    excavated and the ground be restored to its
                    original configuration by back-filling the
                    area with clean soil  (i.e., less than 1 ppm).
               (4)  The above cleanup must be completed within 48
                    hours of discovery of the spill.

Q7:  Is "wipe testing" required following cleanup of a solid
     surface involved in a "small, low-concentration" spill?

A7:  The only instance in which wipe testing would be required
     after cleanup of a small, low-concentration spill is if PCB
     contamination of an indoor, residential surface occurred.
     This type of solid surface would have to be wipe tested
     after cleanup and shown to contain no greater than 10 /ig/100
     cm2 of residual  PCB contamination.   All other solid surfaces
     could simply be double washed/rinsed with no wipe testing
     required.

Q8:  Is there a minimum depth requirement when excavating soil
     within the spill area?

A8:  Due to the wide variety of ground media from one area of the
     country to another, EPA has placed no specific depth
     requirement in the performance standard for cleanup of
     small, low-concentration spills.  Responsible parties should
     review each spill on a case-by-case basis and excavate soil
     to a reasonable depth based upon the type of soil and
     visible traces of spilled material.

Q9:  The spill policy requires the excavated area be restored to
     its original configuration by back-filling the area with
     clean soil less than 1 ppm PCBs.  Does back-fill soil have
     to be tested for PCBs prior to being used?


                              XIV-10

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A9:  No. EPA does not require soil to be used for back-filling to
     be tested and proven less than 1 ppm.  Responsible parties
     should simply use soil which, to the best of their
     knowledge, contains no PCB contamination.

Q10: Can cleanup of an untested mineral oil spill be delayed to
     first test the mineral oil and determine if the spill is in
     fact 50 ppm or greater?

A10: Untested mineral oil which must be assumed to contain 50-499
     ppm PCBs can be tested to determine the actual PCB
     concentration.  However, the PCB Spill Cleanup Policy does
     not provide for additional "testing time" which would delay
     initiation of the cleanup of a small, low-concentration
     spill beyond the 48-hour requirement.

Qll: Are there any instances in which the initiation of cleanup
     of a small, low-concentration spill may be delayed beyond 48
     hours?

All: Yes. Initiation of cleanup may be delayed beyond 48 hours in
     case of circumstances including but not limited to: civil
     emergency, adverse weather conditions, lack of access to the
     site, and emergency operating conditions.  The occurrence of
     a spill on a weekend or overtime costs are not acceptable
     reasons for delay.

          •    RECORDKEEPING AND CERTIFICATION REQUIREMENTS:

               At the completion of cleanup of a small, low-
               concentration spill, the responsible party or
               appropriate agent must document the cleanup with
               records and certification of decontamination.  The
               records and certification must be maintained for a
               period of 5 years.   The records and certification
               must include the following:

                (1)  The source of the spill (e.g., type of
                    equipment).
                (2)  The date and time the spill occurred {actual
                    or estimated).
                (3)  The date and time cleanup was completed or
                    terminated.
                (4)  The nature and duration of why initiation of
                    cleanup was beyond the 48-hour requirement.
                (5)  A brief description of the spill location.
                (6)  Precleanup sampling data used to determine
                    spill boundaries if there were insufficient
                    visible traces.
                (7)  A brief description of any solid surfaces
                    which were double washed/rinsed and the
                    methods used.

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           (8)  The approximate depth of soil excavation and
               the amount of soil removed.
           (9)  A certified statement signed by the
               responsible party (e.g., facility manager or
               foreman) stating that the cleanup
               requirements have been met and that the
               information contained in the records is true
               to the best of his/her knowledge.
LARGE. LOW-CONCENTRATION SPILLS AND HIGH-CONCENTRATION
SPILLS OF ANY QUANTITY

The next two categories of PCB spills established in the PCB
Spill Cleanup Policy are large, low-concentration spills and
high-concentration spills of any amount of PCBs.

Large, low-concentration spills are spills of materials
containing 50-499 ppm PCBs and which involve more than 1
pound of PCBs by weight or more than 270 gallons of untested
mineral oil.  These spills involve larger quantities of low-
level PCBs and thus present more widespread contamination
and a greater risk of potential exposure to humans.

High-concentration spills are spills of materials containing
PCBs in concentrations of 500 ppm or greater.  PCB spills of
these higher level concentrations, in any quantity, present
a more significant risk of exposure to humans.

Because of the greater risk of potential exposure to humans
from large, low-concentration spills and all high-
concentration spills, EPA requires more stringent and
detailed numerical cleanup standards for these types of
spills.  Numerical cleanup standards are based upon the
spill location with the most stringent requirements applied
to PCBs spilled in residential/commercial/unrestricted
access rural areas.  The spill policy allows for less-
stringent numerical cleanup standards for PCBs spilled in
industrial and other restricted-access areas such as utility
power plants.  And finally, the least stringent numerical
cleanup standards apply to PCB spills in outdoor electrical
substations.

In order to simplify the PCB Spill Cleanup Policy to the
extent possible, EPA structured the policy so that the
cleanup, recordkeeping, and testing requirements for "large,
low-concentration spills" and "high-concentration spills"
are identical.  The following is a brief overview of these
requirements based upon spill location.  Responsible parties
should refer to 40 CFR 761.125 for detailed requirements and
standards.

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        • IMMEDIATE REQUIREMENTS:

          The following four actions must be taken as quickly as
          possible and within no more than 24 hours  (48 hours for
          PCB Transformer spills) after discovery of the spill.

          (1)  Report the spill to the NRC if 1 pound or more of
               pure PCBs were spilled, and to the EPA Regional
               Office if 10 Ibs. or more of pure PCBs were
               spilled.
          (2)  Effectively cordon off and restrict access to the
               spill area plus a 3-foot buffer, and place clearly
               visible signs advising persons to avoid the area.
          (3)  Record and document the spill area noting the
               extent and center of all visible traces.  If there
               are no visible traces, contact the EPA Regional
               Office for guidance in completing a statistical
               sampling of the spill area to determine spill
               boundaries.
          (4)  Initiate cleanup of all visible traces on solid
               surfaces and initiate excavation of any visibly
               contaminated soil.

Q12: Are there any instances in which the "immediate
     requirements" for large, low-concentration and high-
     concentration spills may be delayed beyond 24 hours?

A12: Yes. The above immediate requirements (2), (3), and (4) may
     be delayed beyond 24 hours in case of circumstances
     including but not limited to: civil emergency, adverse
     weather conditions, lack of access to the site, and
     emergency operating conditions.  The occurrence of a spill
     on a weekend or overtime costs are not acceptable reasons
     for delay.

          •    CLEANUP REQUIREMENTS - OUTDOOR ELECTRICAL
               SUBSTATIONS:

               (1)  Contaminated solid surfaces must be cleaned
                    to a level not exceeding PCB concentrations
                    of 100 /xg/100 cm2.
               (2)  Contaminated soil must be excavated to 25 ppm
                    PCBs,  or to 50 ppm PCBs provided that a
                    notice indicating the 50 ppm PCB level is
                    visibly placed in the area.

          •    CLEANUP REQUIREMENTS - OTHER RESTRICTED ACCESS
               AREAS:

               (1)  Contaminated solid surfaces must be cleaned
                    to either 10 /-ig/100 cm2 or  100  /ig/100 cm2
                    depending upon whether the contaminated

                             XIV-13

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                    surface is indoors or outdoors, high-contact
                    or low-contact, impervious or nonimpervious.
                    Responsible parties should refer to 40 CFR
                    761.125 for a detailed description of final
                    numerical cleanup standards.
               (2)  Contaminated soil must be excavated to 25 ppm
                    PCBs.

          •    CLEANUP REQUIREMENTS - NONRESTRICTED ACCESS AREAS:

               (1)  Contaminated furnishings, toys, and other
                    easily replaceable household items must be
                    disposed of in accordance with disposal
                    requirements under 40 CFR 761.60 and replaced
                    by the responsible party.
               (2)  Contaminated solid surfaces must be cleaned
                    to either 10 pig/100 cm2  or 100  pig/100 cm2
                    depending on whether the contaminated surface
                    is indoors or outdoors,  high-contact or low-
                    contact ,  impervious or nonimpervious.
                    Responsible parties should refer to 40 CFR
                    761.125 for a detailed description of final
                    numerical cleanup standards.
               (3)  Contaminated soil must be excavated to 10 ppm
                    PCBs provided the soil is excavated to a
                    minimum depth of 10 inches.  The excavated
                    soil must be replaced with clean soil less
                    than 1 ppm PCBs and the site restored to its
                    original configuration.

Q13: Does a "high-concentration" or "large,  low-concentration"
     spill in a nonrestricted access area always require
     excavating the contaminated soil to a minimum depth of 10
     inches?

A13: No. Excavation of the soil may be terminated before reaching
     a 10-inch depth provided there are no detectible PCBs at the
     level of termination  (i.e., less than 1 ppm).   In other
     words, excavation must continue until:   (1) there are no
     detectible PCBs at the level of termination, or  (2) there is
     not greater than 10 ppm contamination at a minimum  10-inch
     depth, or (3) excavation must continue beyond 10-inch depth
     if necessary to achieve the minimum 10 ppm cleanup  standard.

Q14: Is there a minimum quantity level for required cleanup of a
     "high-concentration" PCB spill?

A14: No. High-concentration spills  (500 ppm or greater) must be
     cleaned up in accordance with the PCB Spill Cleanup Policy
     regardless of the quantity spilled.  Even spills from small,
     unregulated items such as PCB small capacitors are


                              XIV-14

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     considered improper disposal and should be cleaned up in
     accordance with the spill policy.

Q15: Is there a time limit on the final cleanup of "large, low-
     concentration" and "high-concentration" spills?

A15: Although the spill policy requires certain "immediate"
     actions, as described above, EPA has not placed a time limit
     on completion of cleanup since the time required will vary
     from case to case.  However, EPA expects cleanup to be
     achieved promptly in all cases and will consider the
     promptness of completion in determining whether a
     responsible party made good faith efforts to clean up in
     accordance with the policy.


          •    RECORDKEEPING REQUIREMENTS:

               At the completion of cleanup of a large, low-
               concentration or high-concentration spill, the
               responsible party or appropriate agent must
               document the cleanup with records of
               decontamination.  These records must be maintained
               for a period of 5 years.  The records must include
               the following:

               (1)  The source of the spill (e.g., type of
                    equipment).
               (2)  The date and time the spill occurred  (actual
                    or estimated).
               (3)  The date and time cleanup was completed or
                    terminated.
               (4)  The nature and duration of any delayed
                    cleanup.
               (5)  A brief description of the spill location.
               (6)  Precleanup sampling data used to determine
                    spill boundaries if there were insufficient
                    visible traces.
               (7)  A brief description of any solid surfaces
                    cleaned.
               (8)  The approximate depth of soil excavation and
                    the amount of soil removed.
               (9)  Postcleanup verification sampling data (test
                    results).

          •    SAMPLING/TESTING REQUIREMENTS:

               Under the PCB spill  policy requirements for large,
               low-concentration and high-concentration spills,
               responsible parties  are required to conduct post-
               cleanup sampling to  verify the level of cleanup.
               The responsible party,  or designated agent, may

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          use any statistically valid, reproducible,
          sampling scheme  (either random samples or grid
          samples),  provided the following requirements are
          satisfied:

          (1)  The sampling area is the greater of:  (a) an
               area equal to the area cleaned plus an
               additional 1-foot boundary, or (b)  an area 20
               percent larger than the original area of
               contamination.
          (2)  The sampling scheme must ensure 95 percent
               confidence against false positives.
          (3)  The number of samples must be sufficient to
               ensure that areas of contamination of a
               radius of 2 feet or more within the sampling
               area will be detected, except that the
               minimum number of samples is 3 and the
               maximum number of samples is 40.
          (4)  The sampling scheme must include calculation
               for expected variability due to analytical
               error.
EXCLUDED SPILLS

As discussed earlier, certain PCB spills which occur in
areas of higher potential risk and exposure to humans are
specifically excluded from the spill policy.  For each of
the following spill situations, the responsible party must
contact the appropriate Regional EPA Office of Pesticides
and Toxic Substances (see page xiv of this document) within
24 hours of discovery of the spill.  The EPA Regional Office
will establish cleanup standards and requirements for the
"excluded" spills on a case-by-case basis.  The following
six spill situations are "excluded spills" and are not
included in the cleanup, recordkeeping, and sampling
requirements of the PCB Spill Cleanup Policy.  They are
subject, however, to all the measures in the policy that
minimize further environmental contamination.

     •    Spills that result in the direct contamination of
          surface waters.

     •    Spills that result in the direct contamination of
          sewers or sewage treatment plants.

     •    Spills that result in the direct contamination of
          any private or public drinking water sources or
          distribution systems.
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          •    Spills which migrate to and contaminate surface
               waters, sewers, or drinking water supplies before
               cleanup has been completed in accordance with the
               policy.

          •    Spills that contaminate animal grazing lands.

          •    Spills that contaminate vegetable gardens.

Q16: Are commercial farming crop lands included in the definition
     of "vegetable gardens"?  Also, are residential gardens
     included in the definition?

A16: Generally yes.  EPA performed some preliminary analysis of
     the risks posed by the consumption of vegetables grown on a
     spill area cleaned to 25 ppm PCBs in the case of farmland
     and 10 ppm in the case of residential gardens.  Assuming
     that vegetables grown on a residential garden or farm are
     the entire vegetable diet of the site residents, cleaning
     soil to the levels in the policy may not be adequate.  Also,
     EPA has concluded that vegetables are more likely to become
     contaminated through contact with contaminated dirt rather
     than plant uptake, especially root crops such as carrots and
     potatoes.
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                            CHAPTER XV

                          RECORDKEEPING
                          AND REPORTING
40 CFR 761.180(a): PCBs and PCB Items In-Service or Projected  for
Disposal  (page XV-2)

40 CFR 761.180(b): Disposers and Commercial Storers of PCB Waste
(page XV-6)

Incineration Facilities (page XV-9)

Chemical Waste Landfill Facilities  (page XV-10)

High Efficiency Boiler Facilities  (page XV-10)

Special Recordkeeping Requirements  (page XV-11)

-------
             - RECORDKEEPING AND REPORTING -
EPA finalized specific recordkeeping and reporting
regulations with the promulgation of the "PCB Ban Rule" in
1979.  These regulations outlined the various records and
reports which owners, storers, and disposers of PCBs and PCB
Items were required to develop and maintain.  The
Notification and Manifesting Rule, published on December 21,
1989  (54 FR 52716) changed the format of the recordkeeping
requirements for PCBs that were in place since 1979.  Year
after year, "improper recordkeeping" continues to be the
single most frequent area of noncompliance in each of the
ten EPA regions across the country.  The following is a
brief overview of the recordkeeping and reporting
requirements for PCBs and PCB Items.  One should pay
particular attention to the changes as a result of the
Notification and Manifesting Rule.  Responsible parties are
encouraged to refer to 40 CFR 761.180 and the Notification
and Manifesting Rule  for a detailed outline of the "Records
and Reports" regulations.

The Notification and Manifesting Rule adopts additional
recordkeeping and reporting requirements to complete the
tracking system for PCB wastes.  The rule requires that the
manifests themselves be retained as records by waste
handlers, and it requires reporting to EPA in the event of
irregularities in the transport of regulated wastes.  These
reports depend largely on information derived from
particular manifests.

Three of the waste tracking reports are modeled after their
RCRA counterparts.  The rule requires "Exception Reports" to
be filed with EPA whenever a generator has not received
verification of delivery within 45 days.  Also,  a
"Discrepancy Report" is  required of storage or disposal
facilities in those cases where the waste actually delivered
to them does not correspond exactly with the types and
quantities described on the manifest.  Third,  an
"Unmanifested Waste Report" is required of disposers or
storers in those instances in which waste arrives at a
facility unaccompanied by a required manifest.

The rule adds one additional reporting requirement for which
there is no counterpart under RCRA.  This requirement is the
"One-year Exception Report," intended to bolster EPA's
ability to enforce the requirement under TSCA regulations
that limits storage of PCBs prior to disposal to no more
than one year.   Information on when items of PCB waste were
removed from use is included with the manifests  that
accompany the waste from generation to disposal.   Disposers
are required to certify to the date of disposal  of PCB waste

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manifested to them, and in the event more than one year has
elapsed since the PCBs were removed from use, a report must
be filed with EPA.

Finally, the rule adds several amendments to the existing
PCB recordkeeping provisions that concern the Annual
Document requirements for the users, storers, and disposers
of PCBs.  The most significant of these amendments is the
requirement that each disposer and commercial storer of PCB
waste submit on July 15 of each year an "Annual Report,"
which is a summary of the previous calendar year's PCB
activity at the facility.  The report will be submitted to
the appropriate EPA Regional Administrator.

40 CFR 761.180(a)t  PCBs and PCB Items In-Service or
Projected for Disposal

Beginning February 5, 1990, each owner or operator of a
facility, other than a commercial storer or disposer of PCB
waste, using or storing at one time any of the following
quantities of PCBs and/or PCB Items is required to develop
and maintain Annual Records and by July 1 prepare an Annual
Document Log on the disposition PCBs and PCB Items.  The
quantity limits are:

     •    45 kilograms (99.4 pounds) or more of PCBs (50 ppm
          or greater) contained in PCB Containers, or

     •    one or more PCB Transformers (500 ppm or greater),
          or

     •    50 or more PCB large, high- or low-voltage
          capacitors.

If any of these three quantity limits is met or exceeded,
the owner or operator of the facility must maintain "Annual
Records" for the PCBs and PCB Items, as well as develop and
prepare an "Annual Document Log" each calendar year until
the facility ceases using, storing, or disposing of PCBs and
PCB Items.  "Annual Records" and "Annual Document Logs" must
be maintained for at least 3 years after that time.

The Annual Records include the following:

     •    All signed manifests generated by the facility
          during the calendar year.

     •    All Certificates of Disposal received at the
          facility during the calendar year.
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An Annual Document Log is the summary of the detailed
information maintained at the facility on its waste handling
activities, including:

     •    The identity of the facility and the year covered
          by the Annual Document Log.

     •    The unique manifest number of every manifest
          generated by the facility during the calendar year
          and from each manifest and for unmanifested waste
          that may be stored at the facility, the following
          information:

          •    Weight in kilograms for bulk PCB waste (e.g.,
               in a tanker or truck), the first date it was
               removed from service for disposal, date it
               was placed into transport for off-site
               storage or disposal, and the date of disposal
               if known.

          •    The serial number or other means of
               identifying each PCB Article, the weight in
               kilograms of the PCB waste in each PCB
               Article, the date removed from service for
               disposal, the date placed in transport for
               off-site storage or disposal, and the date of
               disposal if known.

          •    The unique number identifying each PCB
               Container, a description and total weight in
               kilograms of the contents of the container,
               the first date material was placed into the
               container for disposal, the date each
               container was placed in transport for storage
               or disposal, and the date of disposal if
               known.

          •    The unique number identifying each PCB
               Article Container, a description and total
               weight in kilograms of the contents of the
               PCB Article Container, the first date a PCB
               Article was placed into the container for
               disposal, the date the PCB Article container
               was placed in transport for off-site storage
               or disposal, and the date of disposal if
               known.

     •    The total number by specific type of PCB Articles
          and the total weight in kilograms of PCBs in PCB
          Articles, the total number of PCB Article
          Containers and total weight in kilograms of the
          contents of the PCB Article Containers, the total

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               number of PCB Containers and the total weight in
               kilograms of the contents of the PCB Containers,
               and the total weight in kilograms of bulk PCB

               waste that was placed into storage for disposal or
               disposed during the calendar year.

          •    The total number of PCB Transformers and total
               weight in kilograms of the PCBs contained in the
               transformer remaining in-service at the end of the
               calendar year.

          •    The total number of Large, High- or Low-Voltage
               PCB Capacitors remaining in-service at the end of
               the calendar year.

          •    The total weight in kilograms of any PCBs and PCB
               Items in PCB Containers, including the
               identification of container contents, remaining
               in-service at the facility at the end of the
               calendar year.

          •    Weights in kilograms, number and description of
               any PCBs or PCB Item shipped from or shipped to
               another facility owned or operated by the same
               generator.

          •    A record of each telephone call or other means of
               verification agreed upon by both parties to each
               designated commercial storer or designated
               disposer to confirm receipt of PCB waste
               transported by an independent transporter, as
               required by § 761.208.

          NOTE:  Readers are requested to closely review
                 761.180(a)(2) for the detailed information
                 required in this Annual Document Log.

Ql:  Are the Annual Records and Annual Document Logs as specified
     at § 761.180(a)(1) and  (2), required to be sent in to EPA?

Al:  No.  Unless specifically requested, a facility's PCB records
     should be maintained in-house and made available for
     inspection by authorized EPA personnel.   [The Annual Report
     as specified at § 761.180(b)  (which is discussed in the next
     section) is the only recordkeeping document that need be
     sent to EPA.]

Q2:  Is a facility required to obtain a  "Certificate of Disposal"
     for each shipment of PCBs for disposal?
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A2:  "Certificates of Disposal" are industry-developed documents
     normally used by PCB brokers and disposal companies to
     assure their customers that final disposal has, in fact,
     taken place.  Under §761.218 owners and operators of
     disposal facilities are now required to prepare a
     Certificate of Disposal for PCB waste.  The generator of the
     waste  (i.e., either the original generator or the
     owner/operator of a storage facility that has co-mingled PCB
     wastes) would be required to maintain signed Certificates of
     Disposal.

Q3:  Is an Annual Document Log and Annual Record supposed to
     report activity from July 1 of the preceding year to June 30
     of the year the records are developed?

A3:  No.  An Annual Document Log and Annual Record should cover
     activity which took place the previous calendar year
     (January 1 - December 31).  The regulations allow a 6-month
     period to July 1 to develop and complete the Annual Document
     Log and Annual Record.  NOTE:  For 1989 the documents shall
     cover the period from January 1, 1989 to February 5, 1990
     (the effective date of the Notification and Manifesting
     Rule).   For 1990 the documents shall cover the period from
     February 6, 1990 to December 31, 1990.

Q4:  Our facility is past due on several years of Annual
     Documents  [NOTE:  "Annual Documents" is the term used to
     describe the records and reports that were to be developed
     and kept at the facility before the Records and Monitoring
     section (761.180)  of the regulations was amended in the
     Notification and Manifesting rule.]   Is it illegal to go
     back now and develop these required reports?

A4:  If a facility has accurate past records and information, it
     is advisable to prepare all required Annual Documents, even
     those that are currently delinquent.  A facility compiling
     such reports may receive an EPA penalty for completing
     Annual Documents after the allowed 6-month period.
     Penalties will be assessed for those who do not file these
     reports.

Q5:  What exactly does the term "removed from service" mean?

A5:  "Removed from service," when used in the context of the PCB
     regulations, specifically refers to the designation of a PCB
     Item for the end of its useful life or,  in other words,
     "date of removal from service for disposal."  Unfortunately,
     the term "removed from service," as used in the regulations,
     has often been misinterpreted by those in the regulated
     community.  This is particularly so in the case of electric
     utilities where the term has been used for years in
     conjunction with a transformer or other piece of electrical

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     equipment being "changed out" and/or "brought in from the
     field."  Many times these types of "change outs" involve
     electrical equipment that is in sound functional condition
     (intact and nonleaking) and is simply placed back into
     "stock" (storage for reuse)  to be reused on an as-needed
     basis.  In other instances,  equipment is "changed-out" when
     it is in need of and will receive repair work before going
     back into "stock" for future use.  In either case,  this is
     not what EPA means when by "removed from service."   On the
     other hand,  electrical equipment which is legally stored for
     reuse, or stored for repair by authorized servicing, is just
     as much "remaining jji service" as a unit in the field
     operating under loaded conditions.  In fact, once a PCB Item
     (50 ppm or greater)  has been "removed from service for
     disposal," EPA does not allow that unit to be placed back
     into service, repaired, rebuilt, or sold for reuse.  In
     addition,  the one year storage for disposal requirement
     begins on the date of removal from service for disposal.

Q7:  If I drain a PCB-Contaminated Transformer (50 - 499 ppm
     PCBs) prior to shipment for disposal,  must I prepare an
     annual document?
                                      \
A7:  If the total weight of the liquid drained into the
     container(s) is 45 kgs. (99.4 Ibs.)  or more you must prepare
     an annual document for the PCB Container(s).  If you are
     shipping only the drained transformer carcass you need not
     prepare an annual document.

     40 CFR 761.180(b);  Disposers and Commercial Storers of PCB
     Waste

     Beginning February 5,  1990,  each owner or operator of a
     facility  (including high efficiency boiler operations)  used
     for the commercial storage or disposal of PCBs and PCB Items
     is required to prepare and maintain an Annual Record on the
     disposition of all PCBs and PCB Items at the facility and
     prepare and maintain a written Annual Document Log for PCBs
     and PCB Items by July 1 that were handled as PCB waste at
     the facility during the previous calendar year.  In
     addition,  by July 15,  the owner or operator of the facility
     must submit  to the appropriate EPA Regional Administrator an
     "Annual Report" which is a brief summary of the information
     included in the Annual Document Log.   (See § 761.180(b)(3)
     for further detail.)   NOTE:   For 1989 the documents shall
     cover the period from January 1, 1989 to February 5, 1990
     (the effective date of the Notification and Manifesting
     Rule). For 1990 the documents shall cover the period from
     February 6,  1990 to December 31, 1990.
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The Annual Records include the following:

     •    All signed manifests generated or received at the
          facility during the calendar year.

     •    All Certificates of Disposal that have been
          generated or received by the facility during the
          calendar year.

The written Annual Document Log includes the following:
[Readers are requested to closely review § 761.180(b) (2) for
the detailed information required in this Annual Document
Log.]

     •    The name, address, and EPA identification number
          of the storage or disposal facility covered by the
          annual document log and the calendar year covered
          by the annual document log.

     •    For each manifest generated or received by the
          facility during the calendar year, the unique
          manifest number and the name and address of the
          facility that generated the  manifest the
          following information:

          •    The date when any PCBs and PCB Items were
               disposed of at the facility or transferred to
               another disposal or storage facility,
               including the identification of the specific
               types of PCBs and PCB Items that were stored
               or disposed of.

          •    A summary of the total weight in kilograms of
               PCBs and PCB Articles in containers and the
               total weight of PCBs contained in PCB
               Transformers that have been handled at the
               facility during the previous calendar year.
               This summary shall provide totals of the
               above PCBs and PCB Items which have been:
               (1) received during the year; (2) transferred
               to other facilities during the year;  and (3)
               retained at the facility at the end of the
               year.

          •    The contents of PCB Containers shall be
               identified.  When PCB Containers and PCBs
               contained in a transformer are transferred to
               other storage or disposal facilities, the
               identification of the facility to which such
               PCBs and PCB Items were transferred shall be
               included in the document.
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               •    The total number of any PCB Articles or PCB
                    Equipment not in PCB Containers received
                    during the calendar year, transferred to
                    other storage or disposal facilities during
                    the calendar year, or remaining on the
                    facility site at the end of the calendar year
                    shall be included.

               •    The identification of the specific types of
                    PCB Articles and PCB Equipment received,
                    transferred, or remaining on the facility
                    site shall be indicated.

               •    When PCB Articles and PCB Equipment are
                    transferred to other storage or disposal
                    facilities, the identification of the
                    facility to which the PCB Articles and PCB
                    Equipment were transferred must be included.

Q7:  Do the above requirements for a PCB storage facility apply
     to an electric utility which has set up a PCB storage
     facility for their own PCBs and PCB Items?

A7:  No.  An electric utility which has set up a PCB storage
     facility for their own PCBs and PCB Items is only required
     to prepare a document under the criteria outlined for owners
     and users of PCBs at 761.180(a).  The recordkeeping
     requirements for disposal and storage facilities outlined
     under 761.180(b) do not apply to electric utilities or
     others who are simply storing their own PCBs.  They are not
     commercial storers of PCB waste.

     The above documents must be completed for each calendar year
     until the facility is no longer used for the storage or
     disposal of PCBs and PCB Items.  All documents that are
     required to be maintained at the facility must be maintained
     for at least 3 years after that time; except in the case of
     chemical waste landfills.  These documents must be
     maintained at least 20 years after the chemical waste
     landfill is no longer used for the disposal of PCBs and PCB
     Items.

     Other PCB Records:  In addition to "Annual Records" and
     "Annual Documents," owners or operators of facilities using
     or storing PCBs and PCB Items are required to maintain the
     following records and reports when applicable:

          •    PCB Transformer Inspections  (Quarterly and/or
               Yearly)

          •    PCB Transformer Registrations  (Fire Departments
               and Building Owners)

                               XV-8

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          PCB Container/Drum/Bulk Tank Identification Logs

          PCB Spill Reports  (See "PCB Spill Cleanup Policy")

          Spill Prevention Control and Countermeasure  (SPCC)
          Plans for Storage of Large Tanks

          PCB Test/Sampling Data (See "PCB Spill Cleanup
          Policy")

          Data on PCB Transformers installed for either
          emergency or reclassification purposes
INCINERATION FACILITIES

In addition to the required documents which must be prepared
by all PCB disposal facilities, each owner or operator of a
PCB incinerator facility shall also collect and maintain the
following information:

     •    When PCBs are being incinerated, the following
          continuous and short-interval data:

          (1)  the rate and quantity of PCBs fed to the
               combustion system as required in
               761.70(a)(3);

          (2)  the temperature of the combustion process as
               required in 761.70(a)(4); and

          (3)  the stack emission product to include O2,  CO,
               and C02 as  required  in  761.70(a)(7).

     •    When PCBs are being incinerated, data and records
          on the monitoring of stack emissions as required
          in 761.70 (a) (7) .

     •    The total weight in kilograms of any solid
          residues generated by the incineration of PCBs and
          PCB Items during the calendar year.

     •    The total weight in kilograms of any solid
          residues disposed of by the facility in chemical
          waste landfills during the calendar year.

     •    The total weight in kilograms of any solid
          residues remaining on the facility site.

     •    When PCBs and PCB Items are being incinerated,
          additional periodic data shall be collected and
                         XV-9

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          maintained as specified by the Regional
          Administrator pursuant to 761.70(d)(4).

     •    Upon any suspension of the operation of any
          incinerator pursuant to 761.70(a)(8), the owner or
          operator of such an incinerator shall prepare a
          document.  This document shall,  at a minimum,
          include the date and time of the suspension and an
          explanation of the circumstances causing the
          suspension of operation.  The document shall be
          sent to the appropriate Regional Administrator
          within 30 days of any such suspension.

PCB incinerator facilities must collect and maintain the
above information for a period of at least 3 years from the
date the information was collected.
CHEMICAL WASTE LANDFILL FACILITIES

In addition to the required documents which must be prepared
by all PCB disposal facilities, each owner or operator of a
chemical waste landfill facility shall also collect and
maintain the following information:

     •    Any water analysis obtained in compliance with
          761.75(b) (6) (iii); and

     •    Any operations records including burial
          coordinates of wastes obtained in compliance with
          761.75(b) (8) (ii) .

Chemical waste landfill facilities must collect and maintain
the above information until at least 20 years after the
chemical waste landfill is no longer used for the disposal
of PCBs and PCB Items.
HIGH EFFICIENCY BOILER FACILITIES

In addition to the required documents which must be prepared
by all PCB disposal facilities, each owner or operator of a
high efficiency boiler used for the disposal of liquids
containing between 50 and 500 ppm PCBs shall also collect
and maintain the following information:

     •    For each month PCBs are burned in the boiler, the
          carbon monoxide and excess oxygen data required in
          761. 60 (a) (2) (iii) (A) (8) and
          761.60 (a) (3) (iii) (A) (8) .
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     •    The quantity of PCBs burned each month as required
          in 761.60(a)(2)(iii)(A) (7) and
          761.60(a) (3) (iii) (A) (7).

     •    For each month PCBs  (other than mineral oil
          dielectric fluid) are burned, the chemical
          analysis data of the waste as required in
          761.60(a) (3) (iii) (B) (6).

High efficiency boiler facilities used for the disposal of
liquids containing between 50 and 500 ppm PCBs must collect
and maintain the above information for a period of at least
3 years from the date the information was collected.
SPECIAL RECORDKEEPING REQUIREMENTS

In addition to the documents and other records outlined in
Units II through V above, each owner or operator of a PCB
storage or disposal facility (including high efficiency
boiler operations) shall collect and maintain the following
information:

     •    All documents, correspondence, and data that have
          been provided to the owner or operator of the
          facility by any state or local government agency
          and that pertain to the storage or disposal of
          PCBs and PCB Items at the facility.

     •    All documents, correspondence, and data that have
          been provided by the owner or operator of the
          facility to any state or local government agency
          and that pertain to the storage or disposal of
          PCBs and PCB Items at the facility.

     •    Any applications and related correspondence sent
          by the owner or operator of the facility to any
          local, state, or Federal authorities in regard to
          waste water discharge permits, solid waste
          permits, or other permits or authorizations such
          as those required by 761.70(d) and 761.75(c).

Each owner or operator of a PCB storage or disposal facility
must collect and maintain these special records for a period
of at least 3 years after the facility is no longer used for
the storage or disposal of PCBs and PCB Items except that in
the case of chemical waste landfills, the special records
must be maintained at least 20 years after the landfill is
no longer used for the disposal of PCBs and PCB Items.
                         XV-11

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                           CHAPTER XVI



                      PCS TESTING PROCEDURES





Oil-Filled Electrical Equipment  (page XVI-l)



Waste Oil (page XVI-2)



PCB Spills (page XVI-3)

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               -  PCB TESTING PROCEDURES  -
OIL-FILLED ELECTRICAL EQUIPMENT

The PCB regulations under TSCA do not require electrical
equipment containing mineral oil dielectric fluid to be
tested for PCB contamination.  Instead,  EPA allows the
continued use and storage for reuse of untested mineral oil
electrical equipment provided the equipment is intact and
nonleaking, and provided the equipment is used in compliance
with all applicable "assumption" requirements.  However,
owners or operators of mineral oil dielectric fluid
electrical equipment may use the following procedures to
determine the concentration of PCBs in the dielectric fluid:

     •    Mineral oil dielectric fluid removed from
          electrical equipment may be collected in a common
          container, provided that no other chemical
          substances or mixtures are added to the container.
          This common container option does not permit
          dilution of the collected oil.  Mineral oil that
          is assumed or known to contain 50-ppm PCBs or
          greater must not be mixed with mineral oil that is
          known or assumed to contain less than 50-ppm PCBs
          to reduce the concentration of PCBs in the common
          container.  If dielectric fluid from untested oil-
          filled circuit breakers, reclosers, or cable is
          collected in a common container with dielectric
          fluid from other oil-filled electrical equipment,
          the entire contents of the container must be
          treated as PCBs at a concentration of at least 50
          ppm.

     •    For purposes of complying with the marking and
          disposal requirements, representative samples may
          be taken from either the common containers or the
          individual electrical equipment to determine PCB
          concentration.  Except, that if any PCBs at a
          concentration of 500 ppm or greater have been
          added to the container or equipment, then the
          total contents must be considered as having a PCB
          concentration of 500 ppm or greater for purposes
          of complying with the disposal requirements at
          761.60.  Representative samples are either samples
          taken in accordance with the American Society of
          Testing and Materials  (ASTM) method D-923, or
          samples taken from a container that has been
          thoroughly mixed in a manner such that any PCBs in
          the container are uniformly distributed throughout
          the liquid in the container.
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Ql:  Can a facility utilize "screen tests" to prove that mineral
     oil dielectric fluid electrical equipment is not
     contaminated with PCBs?

Al:  EPA currently finds gas chromatography (GC)  to be the
     minimally acceptable method for determining the
     concentration and nature of PCBs in oils and uses GC for
     verification purposes.  EPA neither requires nor prohibits
     use of any particular test method to determine PCB
     concentration or total chloride ion detection methods.
     Total organic chlorine or chloride analysis is not as
     specific as gas chromatography for determination of PCB
     content (i.e., it cannot distinguish between PCBs and other
     chlorine containing compounds).   Since PCB-Containing
     Materials frequently contain organic chlorine from sources
     other than PCBs (e.g., trichlorobenzenes),  test data
     obtained by total chlorine or chloride analysis are not as
     reliable for PCB quantitation as gas chromatography.
     Therefore, EPA will not accept total chlorine analysis data
     as proof that a company has satisfied any of the testing
     requirements, or achieved any of the concentration levels
     found in the PCB regulations.  There is no prohibition on
     the use of total organic chlorine or chloride analysis as a
     rough field screening device to determine whether further
     testing is needed.  However, the Agency finds gas
     chromatography to be the minimally acceptable method for
     ascertaining the level of PCBs in oils.
     WASTE OIL

     Owners or users of waste oil may use the following
     procedures to determine the PCB concentration of waste oil:

          •    Waste oil from more than one source may be
               collected in a common container,  provided that no
               other chemical substances or mixtures, such as
               non-waste oils, are added to the container.

          •    For purposes of complying with the marking and
               disposal requirements, representative samples may
               be taken from either the common container or
               individual containers to determine the PCB
               concentration.  Except, if any PCBs at a
               concentration of 500 ppm or greater have been
               added to the container, then the total container
               contents must be considered as having a PCB
               concentration of 500 ppm or greater for purposes
               of complying with the disposal requirements at
               761.60.  Representative samples are either samples
               taken in accordance with the American Society of
               Testing and Materials  (ASTM) method D-923, or

                              XVI-2

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          samples taken from a container that has been
          thoroughly mixed in a manner such that any PCBs in
          the container are uniformly distributed throughout
          the liquid in the container.
PCS SPILLS

See the chapter XIV on "PCB Spill Cleanup -Policy" for a
detailed discussion of proper sampling/testing methods for
PCB spills.
                         XVI-3

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                           CHAPTER XVII




                        IMPORT AND EXPORT
Closed Border Policy  (page XVII-1)



Exemptions to Closed Border Policy  (page XVII-1)

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                 - IMPORT AND EXPORT -
CLOSED BORDER POLICY

EPA has generally established a "closed border" policy which
went into effect May 1, 1980, pertaining to the importing
and exporting of PCBs and PCB Items.  In the Federal
Register of May 31, 1979, EPA recognized that PCB contamina-
tion is a global problem, and that PCBs used outside the
United States can cause PCB contamination of this country
due to the extreme persistence of the substance and the ease
with which it is transported in the environment.  Conse-
quently, the Agency concluded in 1979 that the distribution
in commerce of PCBs for export constitutes an unreasonable
risk to health and the environment in the United States.
However, certain activities involving the import and export
of PCBs have been specifically exempted from the regulatory
prohibitions on distribution in commerce (import and export)
of PCBs.

EXEMPTIONS TO CLOSED BORDER POLICY

These exemptions are:

     •    Persons who import or export products containing
          PCBs generated as unintentional impurities in
          "excluded manufacturing processes" as defined in
          76"!.3, are exempt from the distribution in
          commerce prohibitions provided that such persons
          comply with the records and certification
          requirements at 761.185,  761.187,  and 761.193.

     •    Persons who import or export products containing
          "recycled PCBs" as defined in 761.3,  are exempt
          from the distribution in commerce  prohibitions
          provided that such persons comply  with the records
          and certification requirements at  761.185,
          761.187,  and 761.193.

     •    Persons who import or export products containing
          "Excluded PCB Products" as defined in 761.3 are
          exempt from the distribution in commerce
          prohibitions.

     •    Persons who import or export products that were
          contaminated with PCBs because of  a spill from,  or
          proximity to, a PCB Item 50 ppm or greater,  and
          which have been decontaminated in  accordance with
          applicable EPA spill cleanup policies, are exempt
          from the  distribution in commerce  prohibitions.
                        XVII-1

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          •    PCBs at concentrations less than 50 ppm may be
               imported or exported for purposes of disposal
               (761.20(b)(2)).

          •    PCBs at any concentration may be exported for
               reuse provided they were sold for purposes other
               than resale prior to July 1, 1979 and are in a
               totally enclosed manner.

Ql:  Can PCB samples be imported for purposes of analysis?

Al:  No, not without an exemption.  Since TSCA defines import as
     manufacture  (TSCA section 3), and the manufacture of PCBs is
     banned unless exempted by rule (TSCA section 6(e)), a person
     may not import PCBs other than at less than 50 ppm for
     purposes of disposal.
                              XVII-2

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                          CHAPTER XVIII

            PCS TRANSFORMER FIRE-RELATED REQUIREMENTS


Installation of PCB Transformers  (page XVIII-2)

Enhanced Electrical Protection  (page XVIII-3)

Phaseout of Lower Secondary Voltage Network PCB
Transformers in Sidewalk Vaults (page XVIII-3)

Discovery of a PCB Transformer  (page XVIII-3)

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     - PCB TRANSFORMER FIRE-RELATED REQUIREMENTS -
In the August 25, 1982 "Electrical Equipment Use Rule," EPA
authorized the continued use of all nonrailroad transformers
containing or contaminated with PCBs for the remainder of
their useful lives.  The only exceptions were PCB
Transformers (500 ppm or greater) whose use was prohibited
after October 1, 1985 if they posed an exposure risk to food
or feed.  In making its August 1982 decision, EPA determined
that authorizing the use of transformers containing PCBs for
the remainder of their useful lives did not present an
unreasonable risk to public health or the environment.   In
evaluating the risks posed by the continued use of
transformers containing PCBs, EPA considered the principal
route of release and exposure to PCBs to result from leaks
and spills from this equipment.  However, since that time,
EPA has learned that fires involving transformers can also
be significantly responsible for the release of PCBs, and
that PCBs released from transformers in a fire situation can
be volatilized and converted into dioxins and dibenzofurans
which are many times more toxic than PCBs.

Originally, EPA believed that PCB Transformer fires were
very rare and isolated events.  Thus, EPA did not directly
consider the public health and environmental risk posed by
fire-related events until after the 1982 "Electrical
Equipment Use Rule" when additional information came to
EPA's attention indicating that PCB Transformer fires may
occur more frequently than previously expected, and that
transformer fire-related hazards are not restricted solely
to transformers located inside buildings.

In an attempt to reduce fire-related risks posed by the use
of PCB Transformers,  EPA issued a final rule published in
the Federal Register of July 17,  1985 (50 PR 29170)  which is
referred to as the "PCB Transformer Fires Rule."  In
addition to the existing use and servicing regulations  for
PCB Transformers, this 1985 rule further regulated the  use
of PCB Transformers.   Among other provisions, the rule
specifically:

     •    prohibited the use of higher secondary voltage
          (secondary voltages equal to or greater than  480
          volts including 480/277 volt systems) network PCB
          Transformers,  located in or near a commercial
          building,  after October 1,  1990;

     •    prohibited the further installation of PCB
          Transformers in or near a commercial building;
                        XVIII-1

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     •    required, as of October 1, 1990,  the enhanced
          electrical protection of all radial and lower
          secondary voltage (secondary voltages below 480
          volts) network PCB Transformers,  located in or
          near a commercial building;

     •    required the registration of all PCB Transformers
          with the Fire Department having primary
          jurisdiction by December 1, 1985;

     •    required the registration of any PCB Transformers
          located within 30 meters  (roughly 100 feet) of a
          commercial building to be registered with the
          building owner;

     •    required the marking of the means of access (vault
          door, fence, hallway, etc.) to a PCB Transformer
          with the mark ML (PCB label);

     •    required the removal of all combustible materials
          stored within 5 meters  (roughly 15 feet) of a PCB
          Transformer; and

     •    required immediate notification of the National
          Response Center  (NRC) in the event of a PCB
          Transformer fire-related incident.

Shortly after the promulgation of the 1985 "PCB Transformer
Fires Rule," Mississippi Power Company filed a petition for
review of the rule.  After reviewing new information
submitted by Mississippi Power and others,  and considering
their requests for clarification and amendments to the "PCB
Transformer Fires Rule," EPA determined that the issues
raised warranted further Agency consideration and
subsequently, in the Federal Register of December 31, 1986
(51 FR 47241), published a document responding to issues
that needed clarification and in the Federal Register of
July 19, 1988, EPA promulgated final amendments to the
original 1985 "PCB Transformer Fires Rule."  These
amendments included:

     •    INSTALLATION OF PCB TRANSFORMERS:

          The "PCB Transformer Fires Rule" banned the
          installation of PCB Transformers in or near
          commercial buildings after October 1, 1985.  EPA
          has amended the 1985 rule to allow the
          installation of a PCB Transformer under "emergency
          situations" as described in 761.30(a)(1)(iii)(B);
          and, installation for purposes of reclassification
          as described in 761.30(a) (1) (iii) (C) .

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ENHANCED ELECTRICAL PROTECTION:

The "PCB Transformer Fires Rule" required the
installation of enhanced electrical protection on
all radial and lower secondary voltage network PCB
Transformers, located in or near a commercial
building, by October 1, 1990.  On July 19, 1988
(53 FR 27322) EPA amended the 1985 rule by
allowing the use of nonsidewalk vault, lower
secondary voltage network PCB Transformers in or
near commercial buildings without enhanced
electrical protection until October 1, 1993,
provided EPA is notified as of October 1, 1990.
These PCB Transformers must then be removed by
October 1, 1993.

On November 26, 1990 (55 FR 49043) EPA further
amended the PCB Transformer Fires rule by allowing
for partial deenergization, i.e., deenergizing
only the faulted phase(s), of certain low voltage
radial transformers.  In some circumstances this
may be equivalent to total deenergization of such
transformers in the event of a high current fault.
See "History of the PCB Regulations" earlier in
this manual for greater discussion on this issue.

PHASEOUT OF LOWER SECONDARY VOLTAGE NETWORK PCB
TRANSFORMERS IN SIDEWALK VAULTS:

The 1985 fires rule prohibited the use of all
network PCB Transformers with higher secondary
voltages, in or near a commercial building, after
October 1, 1990.  EPA added to this original
phaseout requirement in the 1988 final amendments
by also requiring that all lower secondary voltage
network PCB Transformers,  located in sidewalk
vaults, be removed from service by October 1,
1993.

DISCOVERY OF A PCB TRANSFORMER:

In the event a mineral oil transformer, assumed to
contain less than 500-ppm PCBs as provided in
761.3, is tested and found to be contaminated at
500 ppm or greater,  it will be subject to all of
the requirements for "PCB Transformers."  In
addition, efforts must be initiated immediately to
bring the transformer into compliance.  The
following is a partial listing of compliance
requirements for newly discovered PCB
Transformers:

              XVIII-3

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               (1)  Mark/label the PCB Transformer within 7 days
                    after discovery.
               (2)  Mark/label the means of access to the PCB
                    Transformer within 7 days after discovery.
               (3)  Register the PCB Transformer with fire
                    response personnel and with the commercial
                    building owner  (if within 30 meters), within
                    30 days of discovery.

               NOTE:  Responsible parties should refer to 40 CFR
                      761.30 for detailed requirements.


Ql:  Are single family residential homes considered "commercial
     buildings"?

Al:  Commercial buildings are described in the regulations as
     including residential properties.  However, in promulgating
     the 1985 fires rule, EPA was concerned with residential
     properties where groups of people live and reside  (e.g.,
     apartments,  hotels, dormitories).  Consequently, EPA is
     clarifying that the term "residential properties" as used in
     the definition of "commercial building" does not include
     single family residential homes.

Q2:  Is it allowable to send PCB Transformer registration letters
     to building managers instead of the owners if there are
     multiple owners?

A2:  Yes.  Registration of PCB Transformers with the property
     manager is acceptable when there are multiple owners  (e.g.,
     condominiums).

Q3:  Could you please clarify the term "combustible materials"
     and their prohibited storage within "5 meters" of a PCB
     Transformer as referenced in the PCB Transformer Fires Rule?

A3:  Although EPA did not specifically define "combustible
     materials," examples were set forth in the regulation to
     help in understanding what EPA meant by "combustible
     material."   (See 50 FR 29200.)  These combustible materials
     include, but are not limited to, paints, solvents, plastics,
     paper, and sawn wood.  EPA's intent in promulgating this
     rule was to prevent the storage of materials near a PCB
     Transformer that would start or feed a fire.

     The regulation, at 50 FR 29200, specifically requires that
     combustible material not be stored within a PCB Transformer
     enclosure, or within 5 meters of a transformer enclosure, or
     if unenclosed  (unpartitioned), within 5 meters of a PCB
     Transformer.  Wood walls, platforms, and other integral

                             XVIII-4

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building structures, even if considered combustible, do not
constitute "stored" materials.  Any item "in use" cannot be
considered a stored item within the purview of the rule.
EPA's intent in promulgating this requirement was to reduce
the risk of fire by mandating that combustible materials
stored near transformers be moved to other locations.  Wood
walls, platforms, and other integral building structures, if
they are not "stored" items, do not fall within the purview
of the stored combustible rule.

The 5-meter distance requirement does not apply where
combustible materials are in a storage room adjacent to a
PCB Transformer vault if the common wall between the storage
room and vault is constructed in a manner which would
effectively reduce the risk of the stored combustible
starting or feeding a fire.  The purpose of the "5-meter
requirement" is to provide an adequate distance between a
PCB Transformer and stored combustible materials, thus
reducing the potential for these materials to ignite in the
event of an electrical fault or transformer fire, or prevent
a fire external to the transformer from involving the
transformer.  EPA recognizes that equivalent levels of
protection can be provided by other means including
separating a PCB Transformer from stored combustibles by a
barrier or enclosure that would contain a fire until it
could be extinguished or until the transformer could be
deenergized.  Six-inch-thick reinforced concrete is a
typical 3-hour fire-resistant construction, as specified in
ASTM Standard E119-75; Fire Tests of Building Construction
and Materials,  NFPA 251-1972; and Methods of Fire Tests of
Building Construction and Materials, ANSI A2.1-1972.  For
PCB Transformer fires, EPA believes that a 2- to 3-hour
fire-rated wall or enclosure constructed of noncombustible
materials, such as concrete, separating a PCB Transformer
from stored combustibles would present an adequate barrier
to fire.  If the wall can accomplish this purpose, the 5-
meter rule does not apply.

The 5-meter distance requirement, although not specified in
the regulation, applies not only to horizontal distances,
but to vertical distances as well, unless the vertical
distance is separated by a continuous, permanent ceiling or
floor.  EPA did not intend that a 5-meter distance be
measured through separate and distinct rooms located above
or below the transformer.
                        XVIII-5

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                       CHAPTER XIX
          PCS NOTIFICATION AND MANIFESTING RULE





Background  (page XIX-1)



Tracking System for PCB Waste  (page XIX-2)



Notification Requirement  (page XIX-2)



Manifesting of PCB Waste  (page XIX-4)



Records and Report  (page XIX-7)



Commercial Storage Approvals (page XIX-8)

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         -PCS NOTIFICATION AND MANIFESTING RULE-
The general provisions of the PCB Notification and
Manifesting Rule are outlined in this chapter as well as a
number of common questions and answers that have been raised
since the effective date of the rule  (February 5, 1990).
Readers should refer to the Federal Register of December 21,
1989  (54 FR 52716) for the specific provisions of the final
rule.  In addition, readers should be aware that there  are
many State programs which impose overlapping transportation,
storage, or disposal requirements on the Federally regulated
PCB disposal community.  Compliance with Federal rules  does
not provide relief from compliance with State requirements.
Conversely, compliance with State requirements does not
provide relief from compliance with Federal rules

First, the rule adds to the TSCA disposal regulations a PCB
waste tracking system modeled after the "cradle-to-grave"
tracking system for hazardous wastes under RCRA.  At the
heart of the tracking system are the requirements that  PCB
waste handlers notify EPA of their PCB waste activities, and
use the RCRA Uniform Manifest (Form 8700-22) in connection
with their shipments of regulated PCB waste.

Second, the Rule requires all persons who commercially  store
PCB wastes to obtain an approval from their EPA Regional
Administrators, or from the Director, Chemical Management
Division (CMD)/Office of Pollution Prevention and Toxics
(OPPT) (when they seek approval for commercial storage  areas
ancillary to disposal facilities that were approved by
Headquarters).  The approval process will enable EPA to
evaluate the qualifications of applicants to engage in  the
business of PCB waste storage, and more particularly, to
impose standards relating to closure plans, financial
responsibility, and maximum storage capacity.
BACKGROUND

Congressional oversight committees have probed into several
incidents which the committees believed demonstrated a need
for additional controls to ensure that PCB waste is in fact
properly disposed of at permitted facilities.  In
particular, the House Subcommittee on Environment, Energy,
and Natural Resources (Rep. Synar, Chairman) held hearings
in August 1986, and again in April 1987,  on PCB disposal
incidents.  The testimony elicited at these hearings
highlighted the fact that the national PCB disposal program
lacked a means of tracking PCB waste from the point of
generation to the point of disposal at approved facilities.
These proceedings also highlighted another shortcoming which

                         XIX-1

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the Subcommittee found to be especially troubling--the lack
of any Agency oversight of the qualifications and activities
of certain PCB waste brokers and others who act as
intermediate storers of PCB waste generated by others.  The
Agency was criticized for not having a means of identifying
definitively the intermediate handlers of PCB wastes, and
for not having a means of evaluating the qualifications and
financial responsibility of those who engage in these
commercial activities.
             TOPICS ADDRESSED BY THIS RULE
TRACKING SYSTEM FOR PCB WASTE

The rule adopts a tracking system for PCB waste modeled
after the "cradle-to-grave" tracking system for RCRA
hazardous wastes.  Specifically, the tracking system
consists of the following components:

     •    A requirement that certain PCB waste handlers
          notify EPA of their PCB waste activities, and
          receive from the Agency unique identification
          numbers;

     •    A requirement that generators of regulated PCB
          wastes initiate shipping documents  (manifests),
          which  physically track the waste from the point
          of generation to the site of storage and/or
          disposal; and

     •    Recordkeeping and reporting requirements that
          complete  the tracking system and facilitate
          enforcement of the PCB disposal regulations.
NOTIFICATION REQUIREMENT; (40 CFR 761.202 and 205)

The notification requirement imposed on PCB waste handlers
is similar to that which EPA requires under the Resource
Conservation and Recovery Act (RCRA) section 3010 for
notification of hazardous waste activities.  It is illegal
to engage in PCB waste handling activities unless one has
notified EPA in advance, and received a unique
identification number.  The persons who are required to
notify EPA consist of generators, transporters, commercial
storers, and disposers of PCB wastes.  To maintain, as far
as possible, consistency with existing RCRA requirements,
the "Notification of PCB Activity" form is similar to the
RCRA notification form.  Importantly, PCB waste handlers who
have previously notified and received identification numbers

                         XIX-2

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     under RCRA do not need to obtain a new identification number
     from EPA under this rule, but they still must notify EPA in
     order to confirm the existing identification number.
     Identification numbers issued under this rule will be based
     upon the same 12-digit numbering system (DUNS) which RCRA
     uses to designate hazardous waste entities.

     The rule differs slightly from RCRA in that it requires only
     a limited class of PCB waste generators to notify EPA and
     obtain unique identification numbers.  The generator
     notifications are limited to the generator-owned or operated
     storage facilities that are subject to the TSCA storage
     facility standards (761.65(b) and/or (c)(7))  for PCB waste.
     The purpose in designating this class of facilities is to
     focus on those larger volume users, owners, and processors
     who store PCB waste which they generate and may be expected
     to utilize PCB disposal services on a fairly regular and/or
     large scale basis.  For the generators exempted from
     notification, this rule specifies a generic identification
     number  (40 CFR PART 761) for use on their manifests.

     This rule treats notification by transporters and commercial
     storers and disposers of PCB waste like they would be
     treated under RCRA.  All such facilities are required to
     notify and receive from EPA unique identification numbers as
     a condition of doing business.

Ql:  Are transfer facilities required to notify EPA of their PCB
     waste handling activities?

Al:  Transfer facilities may hold PCB waste for up to 10
     consecutive days to provide trains, trucks and other
     transport vehicles the opportunity to unload or transfer the
     PCB waste to the next connecting transport vehicle.  If the
     waste is held for more than 10 consecutive days, then the
     facility becomes a commercial storer subject to the
     notification requirements (§761.205), the storage area
     requirements (§761.65(b)), and the requirements associated
     with obtaining commercial storage approval (§761.65(d)-(h)).

Q2:  Does the EPA have to be notified when fluorescent light
     ballasts are removed from a building?

A2:  No.  If the business does not conduct any other PCB handling
     activities, they need not notify EPA under the PCB
     regulations, but you must notify the NRC pursuant to CERCLA
     if more than 1 Ib. of PCBs is involved.

Q3:  If we have an existing RCRA EPA identification number, do we
     need a different TSCA identification number?
                              XIX-3

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A3:  No.  You may use your RCRA number but still must notify EPA
     under TSCA in order to confirm that number.  EPA must
     confirm that number before you may commence any PCB waste
     handling activity.


     MANIFESTING OF PCB WASTE; (40 CFR 761.207-211. 215 and 218)

     The centerpiece of the tracking system for PCB waste is the
     requirement that all who handle regulated PCB wastes use
     shipping documents known as manifests to track the movement
     of PCB waste from the point of generation to the point of
     delivery to off-site storage or disposal facilities.  The
     generator bears the primary burden of preparing the
     manifest, which at all times physically accompanies the
     waste to its destination.

     Most importantly, the manifest establishes a paper trail of
     accountability that documents each waste handler's
     completion of his responsibilities with regard to the waste.
     Each person (generator, transporter,  etc.) who handles the
     waste must obtain the signature of the next person in the
     chain of distribution, and he must keep a copy signed by the
     "next-in-line" handler in his files as a record of his
     involvement with the waste shipment.   Finally, an additional
     copy signed by the storage or disposal facility designated
     on the manifest is returned to the generator who initiated
     the shipment,  signifying the successful completion of the
     waste delivery transaction.   In effect, the manifest serves
     notice of the types and quantities of waste being shipped;
     it creates a paper trail documenting that the waste was
     properly delivered; and it is a source of information for
     other records and reports that summarize a facility's
     overall waste activities.

     EPA is requiring that the same manifest document used in
     connection with RCRA hazardous waste--the Uniform
     Manifest--be the shipping document for tracking PCB waste.
     The existing Uniform Manifest is designed to elicit basic
     information identifying the persons handling the waste, as
     well as the nature and quantity of the waste.  This format
     lends itself well to the tracking of PCB waste.

     The rule requires that manifests be used in connection with
     the off-site transport of PCB wastes at the 50 ppm or
     greater level (see 761.207 (j) for a discussion of
     manifesting and anti-dilution).  The 50 ppm threshold for
     manifesting matches the existing cut-off for the disposal of
     PCBs under the TSCA PCB regulations.   The 50 ppm threshold
     also corresponds to the level at which a number of States
     require manifests under their hazardous waste programs, and
     it corresponds to the level at which disposers are currently

                              XIX-4

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     requiring manifests as a means of limiting their
     liabilities.

Q4:  When states require the use of a manifest for shipping PCB
     waste, which form should I use?

A4:  If both the consignment state and the generator state
     require the use of a specific manifest for use in their
     state, the PCB rules require that the consignment state's
     manifest must be used.  EPA suggests that both manifests be
     prepared, but only the consignment state's manifest be
     retained in the TSCA annual PCB records, when any state is
     unwilling to use a form of manifest used in another state.

Q5:  Do I need to manifest drained PCB-Contaminated Transformers?

A5:  No.  Since drained PCB-Contaminated Transformers are not
     subject to the disposal requirements of Subpart D, 40 CFR
     Part 761, they are not subject to the manifesting
     requirements.

Q6:  If a generator owns two storage facilities which have
     different EPA identification numbers and ships PCB waste
     from one facility to another for purposes of consolidation,
     must the waste be manifested?

A6:  No.  The PCB waste has not left the generator's control and,
     therefore, need not be manifested at this time.

Q7:  I own a transformer service shop.  Am I considered the
     generator of the residual oils that are collected during
     repair and servicing operations?

A7:  Yes.  You are the generator of this waste because you have
     physical control of the equipment when the oil was removed.
     If the residuals were generated on-site at the owner's
     facility, the owner would be the generator of this waste.

Q8:  A transformer is shipped off-site for purposes of inspection
     and repair.  It is determined by the repair shop that the
     cost of repair would exceed the cost of replacing the unit.
     The repair shop contacts the owner of the unit for
     instructions on how to proceed and is instructed by the
     owner to dispose of the unit.   Who is the generator?  If it
     is the repair shop,  how would the transformer show up on the
     annual records of the original owner and how would the
     original owner ensure receipt of a Certificate of Disposal
     (CD) ?

A8:  The repair shop is the generator of the waste (i.e.,
     transformer) because it "has physical control over the PCBs
     when a decision is made that the use of the PCBs has been

                              XIX-5

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     terminated and is subject to the disposal requirements," (40
     CFR 761.3 -- definition of "Generator of PCB Waste").   The
     day that the original owner made the decision to dispose of
     rather than repair the unit is the day the unit is
     considered to be "removed from service for disposal."   This
     information is required to be recorded in the repair shop's
     annual document log as per 40 CFR 761.180(a)(2)(ii)(B).  The
     original owner would not receive a CD because he was not the
     generator of the waste, but he could make arrangements with
     the repair shop to receive a copy of the CD when the repair
     shop gets its copy from the disposer.  Likewise,  the repair
     shop could not "return" the waste oil to the original  owner
     unless that owner was a commercial storer or disposer who
     had notified the Agency of such activities.

Q9:  In which of the following situations is a generator required
     to make a confirmation telephone call to the designated
     facility to confirm receipt of PCB waste?

     a.   The designated facility provides transportation
          services with vehicles owned and operated by them.

     b.   The designated facility provides transportation through
          a wholly-owned subsidiary.

     c.   Through a contract with the generator, the designated
          facility is responsible for the transportation and
          chooses an independent company.

A9:  The only time a confirmation telephone call need be made is
     when an "independent transporter" is used.   Section
     761.208(a)(4).  Therefore, in situations "a" and "b" a
     confirmation call would not be needed and in situation "c"
     one would.

Q10: When completing the manifest form, can the weight in
     kilograms be entered in the space provided in item 14?

A10: Yes.  The instructions for filling out the Uniform Hazardous
     Waste Manifest allow for the use of various units of
     measure; kilograms is one of those units.  DOT currently has
     no rule that limits the unit of measure to only gallons or
     pounds.

Qll: Is it mandatory to use the waste codes "PCB 1" and "PCB 2"
     on the manifest?

All: No.  The use of these waste codes is intended to facilitate
     data exchange among cooperating states and is, therefore,
     optional.
                              XIX-6

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Q12: (a) Can estimates for weight be used when facilities do not
     have scales to weigh drums?  (b) If so, is the difference of
     more than 10 percent in weight still significant if the
     generator and the disposal firm have reached an agreement
     that the disposal firm's weighing will be the accepted
     figure?

A12: (a) Estimates may be used.  The PCB regulations take into
     account that it is not always feasible to weigh the
     material.  When it is not possible to weigh the material, it
     is acceptable either to weigh a 1 gallon sample or estimate
     the weight using 12 pounds per gallon of askarel and 8
     pounds per gallon for contaminated mineral oil.  You must
     indicate on the manifest whether the weight is actual or
     estimated.  (b) There would be no need to submit a
     discrepancy report if a weight difference of greater than 10
     percent can be reconciled, i.e., it is mutually agreed to
     use the disposal firm's scales.

Q13: Who is the generator in the following cases of shipped
     laboratory samples?

     a.   The laboratory ships the unused portion back to the
          person from whom it was originally received.

     b.   The person submitting the sample for analysis
          subsequently ships that sample for commercial storage
          or disposal.

     c.   The sample is manifested by the lab to a disposal
          facility.

A13: Laboratory samples are implicitly authorized for use, as
     opposed to being under the disposal regulations, and are
     considered to remain in use until their use for analysis or
     for an enforcement case has ended.  Therefore, in case "a"
     no one is the generator since no waste is being generated.
     In case "b" the sample is now subject to the disposal
     regulations since it is being shipped to a commercial storer
     or disposer.  In this case then, the person shipping the
     sample for storage or disposal is the generator.  In case
     "c" the sample is obviously no longer in use since the lab
     is manifesting it to the disposal facility; the lab is the
     generator.

     RECORDS AND REPORTS; (40 CFR 761.180. 209. 210. 211. 215.
     and 218)

     The rule adopts additional recordkeeping and reporting
     requirements to complete the tracking system for PCB wastes.
     The rule requires that the manifests themselves be retained
     as records by waste handlers (761.209), and it requires

                              XIX-7

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     reporting to EPA in the event of irregularities in the
     transport of regulated wastes (761.210).   In addition, there
     are reporting requirements for:  unmanifested waste
     (761.211), exception reporting -- when the one-year storage
     for disposal requirement is breached (761.215),  or a
     Certificate of Disposal is not received in a timely manner
     by the generator (761.218).  These reports depend largely on
     information derived from particular manifests.

     The rule adds several amendments to the existing PCB
     recordkeeping provisions that concern the annual document
     requirements for the users, storers, and disposers of PCBs.
     The most significant of these amendments is the requirement
     that each disposer and commercial storer of PCB waste submit
     by July 15 of each year an Annual Report, which is a summary
     of the previous calendar year's PCB activity at the
     facility.  Section 761.180(b)(3).  The report must be
     submitted to the appropriate EPA Regional Administrator.
     Chapter XV discusses the new recordkeeping provisions of the
     Notification and Manifesting Rule in greater detail.

Q14: As the ultimate disposer of manifested PCB waste,  do I send
     the Certificate of Disposal to the generator or to the
     commercial storer from which I received the waste directly?

A14: The Certificate of Disposal must be sent to the generator
     indicated on the manifest.  In the event the storer
     generates a new manifest because he consolidates a number of
     PCB waste shipments prior to sending the waste to the
     disposal facility,  the original generator may make
     arrangements with the commercial storer to receive a copy of
     the Certificate of Disposal.


     COMMERCIAL STORAGE APPROVALS; (40 CFR 761.65(d)-M))

     The rule adopts an approval process for commercial PCB waste
     storers.  The term "commercial storer"  is defined broadly to
     mean any facility that stores PCB wastes generated by
     others, or that brokers waste generated during electrical
     equipment servicing.

     The rule allowed existing commercial storers a 180-day
     period from the effective date (February 5,  1990), within
     which they must have applied for approvals from their EPA
     Regional Administrators (or from the Director,  CMD/OPPT for
     approval of commercial storage areas at disposal facilities
     approved by Headquarters).  If a facility submitted a
     complete application (including but not limited to: identity
     of principals and key employees,  a list of State and/or
     Federal environmental violations occurring over the past 5
     years, description of the design and capacity of the

                              XIX-8

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     facility, a closure plan, a demonstration of financial
     assurance, and a closure cost estimate) by August 4, 1990,
     the applicant was granted interim approval to operate until
     the facility's application was either approved or denied at
     which time interim authorization was terminated.

     The issuance of a final storage approval is contingent upon
     the company satisfying the seven criteria in 40 CFR
     761.65(d)(2).  Among other things, the Regional
     Administrator must be satisfied that the applicant is
     qualified to engage in the commercial storage business.
     Also, applicants are required to submit acceptable closure
     plans and demonstrate their financial responsibility for
     closure.  The requirement to demonstrate one's financial
     responsibility can be satisfied by using one or more of the
     financial assurance mechanisms described in current RCRA
     regulations for permitted hazardous waste facilities (40 CFR
     264, Subpart H).  Applicants will also be required to
     certify their compliance with the TSCA storage facility
     standards, and to estimate the maximum quantities of PCB
     waste that will be handled at the facility.

     The final rule contains a small quantity exemption from the
     definition of "commercial storer" for facilities that store
     less than 500 gallons of PCBs at any time.  Such facilities
     need not seek approvals to operate under 761.65(b).  At the
     time of this printing, the Agency is considering proposing a
     similar small quantity exemption for solid PCB waste.

Q15: Does the small quantity exemption for applying for a
     commercial storage approval apply only to less than 500
     gallons of liquid PCB waste?

A15: In the Federal Register of June 27,  1990,  EPA clarified this
     exemption by stating that one need not apply for a
     commercial storage approval if the facility's storage of PCB
     waste at no time exceeds 500 liquid gallons of PCBs.
     Pending publication of a final amendment in the Federal
     Register. EPA will not bring enforcement actions against
     facilities storing less than 70 cubic feet of solid PCB
     waste,  provided such facilities notify EPA of their waste
     activities and comply with all other TSCA and PCB
     regulations.

Q16: I operate the central PCB storage facility which is owned by
     and accepts waste from members of our public power
     association.   Am I considered a commercial storer and
     therefore required to submit a commercial  storage
     application?
                              XIX-9

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A16: No.  Storage of one company's PCB waste by a "related
     company" is not commercial storage.  Therefore, storage
     between "related companies" is exempt from commercial storer
     status.  Storage of any waste generated by a non-affiliated
     organization would change this status to that of a
     commercial storer.  "Related companies" include a parent
     company and its subsidiaries, sibling companies owned by the
     same parent company, companies owned by a common holding
     company and members of an electric cooperative.  The test is
     whether the "related" companies have a financial or
     managerial relationship that would provide for a mutual role
     in the financial assurance for the storage area.  By this
     definition, companies are not related if they merely belong
     to the same trade association.

Q17: Would all Department of Defense (DOD) facilities be
     considered "related" under this rule?

A17: Yes.  DOD facilities are considered related so there will be
     no commercial storage involved when one DOD facility stores
     PCB waste that is generated by another DOD facility.
     However, storage of PCBs at a DOD facility generated by
     another Federal, State, or local government
     departments/agencies, or other (i.e., private)  facilities
     will constitute commercial storage.

Q18: Are independent laboratories required to get commercial
     storage approval?

A18: No.  As long as they are independent (i.e., separate from
     any firm whose activities involve PCB waste handling) and
     store their waste in an area that complies with 40 CFR
     761.65(b)(i)-(iv), such facilities are not required to get
     commercial storage approvals.

Q19: A power marketing agency has contracts with its customers to
     operate and maintain equipment that the customer owns.   The
     agency may operate a customer's equipment located either on
     the customer's property or the agency's property.  Is the
     power marketing agency a commercial storer if it stores PCB
     waste owned by its customers?

A19: Yes.  The power marketing agency is providing a service for
     a fee.  That is not the same interwoven managerial or
     financial interest that exists between electrical
     cooperatives, sibling corporations, or other relationships
     where there would be a mutual role in financial assurance
     for the storage area.
                              XIX-10

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         APPENDIX I
CODE OF FEDERAL REGULATIONS
      40 CFR PART 761
(Revised as of  July 1,  1993)

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-------
     APPENDIX II
PCB DISPOSAL COMPANIES
COMMERCIALLY PERMITTED

-------
                           PCB DISPOSAL COMPANIES
                           COMMERCIALLY PERMITTED
                                                            MAR -41994
*Permitted to operate in all ten EPA Regions
COMPANY

INCINERATORS

Aptus,  Inc.
Chemical Waste
 Management

Rollins
WESTON
      ADDRESS
P.O. Box 1328
Coffeyville, KS  67337

P.O. 27448
Salt Lake City, UT

1160 N. Aptus Road
Aragonite, UT

P.O. Box 2563
Port Arthur, TX 77643

P.O. Box 609
Deer Park, TX  77536

One Weston Way
West Chester, PA  19380
  PHONE NO.



312-251 6380


801-521-9009
409-736-2821


713-930-2300


215-692-3030 *
ALTERNATE THERMAL TECHNOLOGIES

General Electric
100 Woodlawn Avenue
Pittsfield, MA  01201
413-494-2700
CHEMICAL DECHLORINATION

Chemical Waste
 Management

Exceltech, Inc.
 (ENSCO Subsidiary)

Aptus,  Inc.

PPM, Inc.
 (USPCI Subsidiary)

ENSR Operations
 (formerly Sunohio)
1550 Balmer Road
Model City, NY  14107

41638 Christy Street
Fremont, CA  94538

P.O. Box 1328

1875 Forge Street
Tucker,  GA  30084

1700 Gateway Blvd. S.E.
Canton,  OH  44707
Coffeyville, KS  67337
716-754-8231


415-659-0404


316-251-6380

404-934-0902 *


216-452-0837 *

-------
                                    -2-

COMPANY                            ADDRESS

CHEMICAL DECHLORINATION  (Continued)
Transformer
 Consultants, Div. of
 S.D.  Myers,  Inc.

Trinity Chemical Co.
 Inc.
180 South Avenue
Tallmadge, OH  44278
6405 Metcalf, Cloverleaf 3
Suite 313
Shawnee Mission, KS  66202
                                PHONE NO.
800-444-9580 *
913-831-2290
PHYSICAL SEPARATION

CECOS International
 Process Center

Aptus, Inc.
Unison Transformer
 Services, Inc.

Quadrex Environmental
 Company

General Electric
S. D. Myers, Inc.
PIPELINE REMOVAL

Alguonguin Gas
 Transmission Company

CNG Transmission
 Corporation

Columbia Gas
 Transmission Corp.

Columbia Gulf
 Transmission Co.

Natural Gas Pipeline
 Company of America

Northern Natural Gas
 Company
4879 Spring Grove Ave.
Cincinnati, OH  45232

P.O. Box 1328
Coffeyville, KS  67337

5801 Riverport Road
Henderson, KY  43420

1940 N.W. 67th Place
Gainesville, PL  32606

One River Road
Schenectady, NY  12345

180 South Avenue
Tallmadge, Ohio  44278
1284 Soldiers Field Rd.
Boston, MA  02135

445 West Main Street
Clarksburg, WV 26302

P.O. Box 1273
Charleston, WV  25325-1273

P.O. Box 1273
Charleston, WV  25325-1273

701 East 22nd Street
Lombard, Illinois 60148

P.O. Box 2511
Omaha, NB 68103-
513-681-5738


316-251-6380


502-827-0541


904-373-6066 *


518-385-2426 *


800-444-9580
617-254-4050 *


304 623-8446


304-359-2727 *


304-359-2727 *


708 691-3808


515-226-2011 *

-------
 OMPANY

PIPELINE REMOVAL (Continued)
Tennessee Gas Pipeline
 Company  (Tenneco)

Texas Eastern Gas
 Pipeline Company

Texas Gas Transmission
 Corporation

Transwestern Pipeline
 Corporation
                                     -3-

                                   ADDRESS
                              P.O. Box 2511
                              Houston,TX  77252-2511

                              P.O. Box 2521
                              Houston, TX  77252-2521

                              3800 Frederica Street
                              Owensboro, KY 42302

                              3800 Frederica Street
                              Owensboro, KY 42302
  PHONE NO.




713-757-5687 *



713-759-5472 *



502-926-8686 *


713-853-7237 *
PIPELINE AND COMPRESSOR
  SYSTEMS DECONTAMINATION

Burlington Environmental
 Inc.
LQuadrex Environmental
 Company

Vector Group, Inc.
                              2203 Airport Way South
                              Suite 400
                              Seattle, WA  98134

                              1940 N.W. 67th Place
                              Gainesville, FL  32606

                              1118 Ferris Road
                              Cincinnati, OH  45102
206-223-0500 *




904-373-6066 *


513-752-8988 *
PCB TRANSFORMER DECOMMISSIONING
  (Disassembly/Smelting)
Aptus, Inc.
Transformer Consultants
 Div of S.D. Myers, Inc

Unison
                              P.O. Box 1328
                              Coffeyville, KS  67337

                              180 South Avenue
                              Tallmadge, OH  44278

                              1302 West 38th Street
                              Ashtabula, OH  44004

                              3126 Brinkerhoff Road
                              Kansas City, KS  66115
316-251-6380


800-444-9580


216-992-8665


913-321-3155

-------
COMPANY

CHEMICAL WASTE LANDFILLS

Chemical Waste
 Management
Chem-Security Systems
 Incorporated

Envirosafe Services
 Inc. of Idaho

CWM Chemical Services
 Control, Inc.

U.S. Ecology, Inc.
U.S. Pollution
 Control, Inc.
BIOLOGICAL

Detox Industries,  Inc,
      -4-

     ADDRESS
Alabama Inc. Box 55
Emelle, AL  35459

Box 471
Kettleman City, CA  93239

Star Route, Box 9
Arlington, OR  98712

P.O. Box 16217
Boise, ID  83715-6217

1550 Balmer Road
Model City, NY  14107

Box 578
Beatty, NV  89003

Grayback Mountain
8960N Hwy 40
Lake Point, UT  84074
12919 Dairy Ashford
Sugar Land, TX  77478
  PHONE NO.



205-652-9721


209-386-9711


503-454-2643


800-274-1516


716-754-8231


702-553-2203


801-595-3900
713-240-0892

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