EPA/560/R-80/001
"^                           EPA's Final  PCB  Ban  Rule:
                                    Over  100

                               Questions  & Answers
                                To Help You Meet
                               These  Requirements

 o
  J
 \j     .                           Prepared by:
 ^_                       Industry Assistance Office and
 AC                          Chemical Control Division
 ^                         Office of Toxic Substances
 7-                   U.S.  Environmental Protection Agencv
 .9
 /3                               Revised Edition
                                     June 1980

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                       INTRODUCTION



On May»t3.1tv ¥979 in the Federal Register (44 FR 31514)  the'
U.S*;i Environmental Protection Agency published the Final
RuJLe for^-'Kn^ychlorinated Biphenyls (PCBs)  Manufacturing,
Proces,s#^g,  Distribution in Commerce,  and Use Prohibitions.
This'Bdra#let* in a non-technical manner,  deals with the
Rule's coverage and requirements.   Its question-and-answer
format is categorized into the following  18 areas.


        Q&A Category                            Questions

        Introductory Information 	"...  1-8

        General Rule Provisions 	 9-21

        Import/Export 	  22-23

        Transformers 	  24-40

        Railroad Transformers 	  41-49

        Capacitors 	  50-54

        Mining Equipment 	  55-60

        Hydraulic Systems 	  61-65

        Heat Transfer Systems 	  66-67

        Other PCB Uses 	  68-74

        Labeling 	  75-82

        Testing 	  83-85

        Storage 	  86-94

        Spills	  95-98

        Recordkeeping 	  99-103
    *
        Disposal 	  104-118

        PCBs in the Workplace	  119-124

        Contacts for Information  	  125-126
*This Booklet has been prepared by the Industry Assistance
Office and the Chemical Control Division within EPA's Office
of Toxic Substances.  It is an informal document, and
persons are directed to the PCB Final Rule for specific
legal requirements,

                            (1)

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                      INTRODUCTORY INFORMATION
(1)   WHAT ARE PCBs?

     The term PCBs is short for polychlorinated biphenyls.
PCBs belong to a broad family of organic chemicals known as
chlorinated hydrocarbons.  PCBs are produced by attaching
one or more chlorine atoms to a biphenyl molecule.  Virtually
all PCBs in existence today have been synthetically manufactured,
(2)  WHO MANUFACTURED PCBs?

     Monsanto Corporation was the principal manufacturer of
PCBs in the United States.  They began production of PCBs in
1929; in 1977 they voluntarily terminated production because
of the wide-spread environmental concerns about PCBs.
(3)  WHAT TRADE NAMES WERE PCBs SOLD UNDER?

     The trademark Monsanto Corporation sold PCBs under was
"Aroclor".  However, companies who used PCBs in the manufacture
of transformers and capacitors/ and for other uses, often
used other tradenames.  The following list is representative
of PCB Tradenames:  Aroclor, Askarel, Pydraul, Therminol, Pyroclor,
Santotherm Pyralene, Pyranol, Inerteen, Asbestol, Chlorextol,
Diachlor, Dykanol, Elemex, Hyvol, No-Flamol, Saf-T-Kuhl,
Aroclor B, Clorinol, Clorphen, Eucarel.  Askarel is the generic
name used for nonflammable insulating liquid in transformers and
capacitors.
(4)  WHAT ARE THE PHYSICAL AND CHEMICAL PROPERTIES OF PCBs?

     PCBs have a heavy liquid, oil-like consistency, and
weigh 10-12 pounds per gallon.  The properties which made
them commercially attractive include:  a high degree of
chemical stability, low solubility in water, low vapor
pressure, low flammability, high heat capacity, low electrical
conductivity, and a favorable dielectric constant.
(5)  HOW ARE PCBs USED?

     The primary use of PCBs has been in "closed" or "semi-
closed" systems in electrical transformers, capacitors, heat
transfer systems, and hydraulic systems.  PCBs have also
been used in paints, adhesives, caulking compounds, plasticizers,
                                (2)

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         inks,  lubricants,  carbonless  copy paper, and sealants,
         coatings,  and  dust control  agents.

             Most  of the PCBs marketed  in the United States  are  still
         in  service, primarily in  electrical equipment.
j         (6)   WHY ARE  PCBs HARMFUL TO HUMAN HEALTH AND  THE  ENVIRONMENT?

I              PCBs are harmful  because once released  into the  environment
|      •   they do not break apart into new chemical arrangements,  instead
r         they bioaccumulate  in  organisms  throughout the environment.
!         In addition,  PCBs biomagnify in  the  food chain —  that is,
         they accumulate  in  the tissues of living organisms and as
         they move up  the food  chain towards  man their  concentration
         increases.  These facts are significant because PCBs  have
         been shown to cause chronic (long-term) toxic  effects in
         many species  even when they are  exposed to very low concentrations,
         (7)   WHAT ARE THE KNOWN HEALTH EFFECTS  OF  PCBs?

              There are well documented tests which show PCBs cause,
         among other things,  reproductive failures,  gastric disorders,
         skin lesions,  and tumors in laboratory  animals.

              Studies of workers exposed to PCBs have shown a number
         of symptoms and adverse effects including,  but not limited to,
         chloracne and other epidermal disorders, digestive disturbances
         jaundice,  impotence,  throat and respiratory irritations, and
         severe headaches.
         (8)   WHAT ACTiON HAS EPA TAKEN AGAINST PCBs?
                 !                '
              In  1976,  Congress enacted the Toxic Substances Control
         Act (TSCA).   Section 6(e)  of this law requires EPA to establish
         rules to:   (1)  govern the disposal and marking of PCBs; and
         (2)  prohibit,  with certain exceptions, the manufacture,
         processing,  distribution in commerce, and non-totally enclosed
         use of PCBs.

              Final Marking and Disposal Rules appeared in the Federal
         Register on February 17, 1978 (clarifying amendments to this
         Rule appeared in the August 2, 1978 Federal Register).

              On  June 7, 1978, the Proposed PCB Ban Rule was published
         in the Federal Register.  The Final PCB Ban Rule appeared in
         the Federal Register on May 31, 1979; this Rule supersedes the
         February 17,  1978 PCB regulation and takes effect on July 2, 1979.

              May 9,  1980 EPA proposed to amend the Final PCB Regulation to
         prohibit the use of PCB Items in facilities manufacturing, processors,
         or storing fertilizers or agricultural pesticides.  FDA and USDA
         published similar proposals to cover the entire food and feed chain.

                                         (3)

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                      GENERAL RULE PROVISIONS


(9)   WHAT DOES THE MAY 31, 1979 PCB BAN RULE DO?

     Specifically, the rule:

     (1)   prohibits the manufacturing, processing, distribution
          in commerce, and the use of PCBs except in a totally
          enclosed manner after July 2, 1979;

     (2)   provides authorizations for certain PCB processing,
          distribution in commerce, and use activities in a non-
          totally enclosed manner.

     (3)   prohibits,  unless exempted by EPA, all manufacturing
          of PCBs after July 2, 1979;

     (4)   prohibits,  unless exempted by EPA, all processing
          and distribution in commerce of PCBs after July 1,
          1979.

     Also, the February 17, 1978 PCB Disposal and Marking
Rule requirements are integrated into this PCB Ban Rule.
Therefore, with the total scope of the PCB regulation — from
labeling to production ban to disposal — now appearing in
the May 31, 1979 Federal Register, this publication supersedes
all earlier PCB regulations upon its July 2, 1979 effective
date.
                                         *
     EPA has published in the May 31, 1979 Federal Register
a notice which explains how to file for an exemption from
the July 1, 1979 bans on processing and distribution in
commerce of PCBs.  Petitions for exemptions must be filed by
July 2, 1979."  EPA earlier published procedures for filing
petitions for exemption from the January 1, 1979 prohibition
on manufacturing of PCBs.  These procedures can be found in
the November 1, 1978 Federal Register  (43 FR 50905) .

     Since publication of the final ban rule, Federal Register
notices dealing with PCBs have been published.  They are
listed on pages 40-41.
(10) DOES THIS RULE APPLY TO ALL PCBs OR IS THERE A CUT-OFF
     POINT BASED ON THE CONCENTRATION OF PCBs?

     In order to practically implement this rule (i.e.,
exemptions, disposal and marking requirements), EPA had to
adopt a PCB concentration cut-off point for regulation. Therefore,
the final rule applies to any substance, mixture, or item
with 50 ppm or greater PCB; wherever the term "PCB" or "PCBs"
is used in the rule, it means PCBs at a concentration of 50
ppm or greater, unless otherwise specified.


                                (4)

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     This 50 ppm is a change from the February 17,  1978 Disposal
and Marking Rule which set a 500 ppm cut-off.  By lowerina
the PCB cut-off point from 500 ppm to 50 ppm, it will substantially
increase health and environmental protection 	approximately,
one million pounds of existing PCBs will be controlled, as
well as 100,000 to 500,000 pounds per year of new PCBs.
(11)  IS THERE ANYTHING WHICH CONTAINS LESS THAN 50 PPM PCBs
      WHICH IS BANNED FROM BEING USED UNDER THIS RULE?

     Yes, waste oil containing any detectable concentration
of PCBs is forbidden from being used as a sealant, coating,
or dust control agent (including floor sweeps).  To permit
the use of waste oil with any PCB-contaminatiori to be used
in road oiling, pipe coating, or vegetation spraying would
cause PCBs to directly enter the air and waterways, which
could introduce them into the food chain.
(12)  WHAT IS THE DIFFERENCE BETWEEN "MANUFACTURING OF PCBs"
      AND "PROCESSING OF PCBs"?

     The actual creation of the chemical substance PCB, -or a
substance contaminated with PCBs  (e.g., PCBs as an impurity),
is the "manufacturing of PCBs."

     The production of PCB Articles and PCB Equipment is
considered "processing of PCBs," and involves the use of
existing PCBs.  Processing PCBs includes such activities as
placing manufactured PCBs into capacitors or transformers.
(13)  WHAT IS CONSIDERED A PCB ARTICLE?  PCB EQUIPMENT? PCB
      ITEM?

     Any manufactured article whose surface is directly
contacted by PCBs is considered a "PCB Article."  Examples
include capacitors, transformers, electric motors, pumps, and
pipes.

     "PCB Item" is a collective term used throughout  the
Rule to refer to PCB Equipment/Articles/Containers/Article
Containers that has as a part of it any PCB or PCBs at a  con-
centration of 50 ppm or greater.
 (14) WHAT EFFECT DOES THE PCB BAN RULE HAVE ON  PCB  ARTICLES?
     PCB EQUIPMENT?
                                 (5)

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     PCB Articles and PCB Equipment can no longer be produced,
however, if EPA grants an exemption to a petitioner,- ihat
petitioner may continue production.


(15)  THE FINAL RULE SAYS THAT EPA CAN GRANT EXEMPTIONS FROM
      THE PCB MANUFACTURING/IMPORTATION BAN EFFECTIVE JULY  2,
      1979 — OR FROM THE PCB PROCESSING/DISTRIBUTION IN
      COMMERCE PROHIBITION EFFECTIVE JULY 1, 1979.  HOW CAN
      I GET AN EXEMPTION?  HAS EPA ALREADY GRANTED SOME?

     Anyone wanting an exemption must petition EPA for it.
An exemption, valid for a maximum of one year, must be
granted annually through a formal rulemaking.  In some
instances, individuals may not have to seek separate exemptions
when the Agency grants "class" exemptions for some bans on
processing and distribution in commerce.

     In the November 1, 1978 Federal Register, EPA published
interim rules for submitting exemption petitions from the
July 2, 1979 PCB manufacturing/importation prohibition; over
70 petitions have been received.  EPA announced, in the
January 2, 1978 Federal Register, that it would not enforce
the ban against those who had submitted petitions until
action had been taken on them.  Subsequently, in the May 31,
1979 Federal Register notice, EPA published a Notice of
Proposed Rulemaking which identifies each exemption petition
received, and the action p;?A proposed to take on most of
them.

     Also, in the May 31, 1979 Federal Register, EPA has
published procedure rules for submitting exemption petitions
from the July 1, 1979 processing/distribution in commerce
prohibitions.  These procedures include the categories
eligible for class exemptions.

     On March 5, 1980 EPA announced that it will decide on  a
case-by-case basis whether or not to accept for consideration all
manufacturing, processing, and distribution in commerce exemption
petitions submitted after the filing deadline.
 (16)  WHERE CAN I DETERMINE WHAT CATEGORIES ARE ELIGIBLE FOR
      CLASS EXEMPTIONS?

     You should make a careful review of Section 750.31(a)
of the Interim Procedural Rules for the processing and
distribution in commerce exemptions.  These rules are published
in the May 31, 1979 Federal Register.  Section 750.31(a),
lists and describes the categories that may file class
exemption petitions.  If your activity is not listed in
Section 750.31(a), you must file a petition on an individual
basis.
                                 (6)

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(17)  THE BAN RULE PROHIBITS THE USE OF PCBs EXCEPT IN A
      "TOTALLY ENCLOSED MANNER".  WHAT IS MEANT BY "TOTALLY
      ENCLOSED MANNER?"

     "Totally enclosed manner" is a term which Congress
wrote into TSCA1s Section 6(e) and refers to PCBs contained
in a way that does not permit any detectable exposure to
PCBs.

     Examples of totally enclosed PCB uses, allowed to
continue after July 2, 1979, are found in television sets,
airconditioners, and microwave ovens.  These items contain
PCB components  (such as PCB capacitors) but their normal
continued use will not result in any exposure to human
beings or their surroundings.
          •
     In the May 31, 1979 regulation EPA states that it
considers the distribution in commerce and use of most
intact, non-leaking; PCB Transformers, PCB-Contaminated Trans-
formers, PCB electromagnets and PCB capacitors as well as
the processing, distribution in commerce and use of PCB
Equipment containing an intact, non-leaking PCB Capacitor
totally enclosed activities.
(18)  THE BAN RULE SAYS THAT EPA CAN GRANT EXCEPTIONS, KNOWN
      AS AUTHORIZATIONS, TO ENABLE THE CONTINUED MANUFACTURING,
      PROCESSING, DISTRIBUTION IN COMMERCE, OR USE OF PCBs
      IN A NON-TOTALLY ENCLOSED MANNER AFTER JULY 2, 1979.
      HOW CAN I GET AN AUTHORIZATION?  HAS EPA ALREADY
      GRANTED SOME?

     EPA may propose and grant an authorization without  a
specific request from those who will benefit from the authori-
zation.  Also, the authorization can be valid for any time
period that EPA finds appropriate.

     The following non-totally enclosed PCB activities have
already been authorized with restrictions by EPA  (beside
each is the Rule section to refer to for details):

     0  servicing PCB Transformers and PCB-Contaminated
        Transformers (Sec. 761.31(a));

     0  use in and servicing of Railroad Transformers  (Sec.
        761.31(b));

     0  use in and servicing of Mining Equipment  (Sec.
        761.31(0));

     0  use in Heat Transfer Systems  (Sec.  761.31(d));

     0  use in Hydraulic Systems (Sec. 761.31(e));

     0  use in Carbonless Copy Paper (Sec. 761.31(f));
                                 (7)

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     0  use in Pigments (Sec. 761.31(g)};

     0  servicing Electromagnets  (Sec.  761.31(h));

     0  use in Small Quantities for Research & Development
        (Sec. 761.3KJ));

     0  use in Microscopy Mounting Medium  (Sec. 761.31(k)).

     EPA authorized the above PCB activities in a non-
totally enclosed manner after evaluating:  the likelihood,
magnitude, and nature of exposure to human beings or the
environment; the availability and characteristics of substitutes;
and the economic significance of the activity, including its
importance to the national economy, small business, technological
innovation, the environment and public  health.
(19)  WHAT IS THE DIFFERENCE BETWEEN A PCB AUTHORIZATION AND
      A PCB EXEMPTION?

     Authorizations are for certain uses of PCBs to extend
beyond July 2, 1979.  However, exemptions for manufacturing ,
are needed in order to manufacture PCB-ccntaminated substances
after January 1, 1979.  Also, exemptions for processing and
distribution in commerce of PCBs are needed in order to
continue these activities after July 1, 1979.

     Exemptions are valid for a maximum of one year, while
authorizations may be granted for longer periods of time.
Other differences between authorizations and exemptions are
described in detail in the Preamble to the Final Rule.

     Since EPA must make more stringent findings under
Section 6(e)(3)  of TSCA than under S 6(e)(2), there is no
reason to require petitioners to have an authorization if
they have been granted an exemption for the same activity.
Therefore, a PCB processing or distribution in commerce
activity cannot be authorized after July 1, 1979.  After
this date, persons who process or distribute PCBs must
petition for and be granted an exemption by EPA in order to
continue these activities.
(20)  WHAT DOES THE RULE PROVIDE FOR LEASED PCB EQUIPMENT?

     PCB Equipment can be leased for any period of time as
long as the lease begins before July 1, 1979; if you want to
lease equipment after this date you have to first get an
exemption from EPA.  To import or export leased PCB equipment
after July 1, 1979 will also require an exemption from EPA.
                                (8)

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(21)   IS THERE AN ECONOMIC IMPACT STATEMENT AVAILABLE?

     Yes, there is an economic impact statement available on
the PCB Ban Rule.  It is called "PCB Manufacturing,  Processing,
Distribution in Commerce and Use Ban Regulation:  Economic Impact
Analysis, " also commonly referred to as the "Versar Report" and
found in the support document to the ban rule dated April 1979.
For a copy of this document call the Industry Assistance
Office (see the "Contacts for Information" section of this
Booklet).
                           IMPORT/EXPORT
(22)  CAN PCBs BE EXPORTED OR IMPORTED?  WHAT ABOUT PCB
      EQUIPMENT?  WHAT ABOUT IMPORTING OR EXPORTING PCBs FOR
      DISPOSAL?

     Because TSCA considers the term "import" to be synonomous
with "manufacture,"  no PCBs or PCB Equipment can be imported
or exported after July 2, 1979, unless an exemption is
obtained from EPA.  Persons wishing to export for use must
also file a TSCA Section 12 export notice.

     The Open Border Policy for PCB disposal expired May 1,
1980; therefore no PCBs may be exported or imported for
disposal until new rules are in effect.  In the summer of
1980 EPA will publish a proposed rule governing the export
and import of PCBs for disposal and use.
                                 (9)

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                        TRANSFORMERS
(24)  UNDER THE FINAL BAN RULE, THE USE OF PCBs  IN  TRANSFORMERS
      IS CONSIDERED USE IN A TOTALLY ENCLOSED MANNER.   DOES  THIS
      MEAN I CAN CONTINUE TO USE MY TRANSFORMERS CONTAINING  PCBs?
      IF SO, FOR HOW LONG?

     Transformers containing PCBs can be used as long  as  they
perform their intended function and do not leak  any PCBs  into the
environment.  Once a transformer leaks it is no  longer totally
enclosed and its use is therefore not authorized.   One exception
to the authorization are EPA, FDA, and USDA's proposed rules to
prohibit the use of PCB Items in food and feed facilities in-
cluding agricultural chemical facilities.


(25).  IN ORDER TO GET THE FULL USEFUL LIFE OUT OF LIQUID  FILLED
      TRANSFORMERS, THEY MUST BE SERVICED OR REPAIRED  PERIOD-
     ICALLY, ARE THERE ANY RESTRICTIONS?
     Servicing of these transformers  is  authorized  until  July  1,
1984 (any activity involving removing the  coil  is not'considered
servicing).  EPA will consider the necessity  of extending the
authorization period prior to the 1984 termination  date.   Special
restrictions are dependent upon the concentration of PCBs in the
transformer and whether PCBs are sold during  the servicing activities,

     There are four categories of transformers  considered in this
regulation and the restrictions and special conditions are easier
to understand in the context of these categories.


(26)  WHAT ARE THE 4 TRANSFORMER CATEGORIES?  WHAT  IS  THE
      SIGNIFICANCE OF EACH?

     The  four categories of transformers established by the PCB
Rule are:

     (1)  PCB Transformers contain PCBs  at a  concentration of
          500 ppm or greater;

     (2)  PCB-Contaminated Transformers  contain between 50 ppm
          and 500 ppm' PCB  (usually they  were  originally mineral
          oil transformers) ;

     (3)  Non-PCB Transformers contain less than 50 PCB;

     (4)  Railroad Transformers used  in  electric railroad
          locomotives and  self-powered cars that contain  PCB
          fluid.
                                 (10)

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     The transformer categories are significant,  because under
the Rule each is subject to different disposal,  servicing
(including rebuilding),  and storage requirements.   (Note:  The
Rule, as do these Q & A's,  addresses Railroad Transformer re-
quirements separately;  the other 3 categories are discussed
simultaneously.)
(27)  HOW DO I DETERMINE WHICH OF THE FOUR TRANSFORMER CATEGORIES
      I HAVE?

     A transformer must be assumed to be a PCB Transformer if:
(1) the nameplate indicates that the transformer contains PCB
dielectric fluid;  (2")  the owner or operator has any reason to
believe that the transformer contains PCB dielectric fluid; or
(3) the transformer's dielectric fluid has been tested and found
to contain 500 ppm or greater PCB.  If a transformer does not
have a nameplate or there isn't any information to indicate the
type of dielectric fluid in it, the transformer should be assumed
to be a PCB Transformer.  Unless there is reason to believe a
mineral oil transformer contains greater than 500 ppm it may be
assumed to be PCB-Contaminated.

     A transformer can be reclassified as a Non-PCB Transformer
if its dielectric fluid has been tested or otherwise verified to
contain less than 50 ppm PCB.  Testing Transformers in order to
classify them as Non-PCB Transformers does not significantly
change the actions required by the Rule.  If your transformers
are proven Non-PCB Transformers you should take precautions to
see that they aren't later contaminated during servicing with PCB
fluid over 50 ppm.
(28)  WHY-SHOULD I ASSUME THAT MY MINERAL OIL TRANFORMER IS A
      PCB CONTAMINATED TRANSFORMER?  IF I GO TO THE EXTRA TROUBLE
      AND EXPENSE TO TEST MY TRANFORMER IN ORDER TO CLASSIFY IT
      AS A NON-PCB TRANSFORMER, WHY WON'T MY REQUIREMENTS UNDER
     1 THE RULE BECOME SIGNIFICANTLY SIMPLER?

     Current data shows that 25-40% of the existing mineral oil
transformers are contaminated with 50 ppm or more of PCBs.

     No clear pattern exists to explain why one transformer is
contaminated and another one is significantly less contami-
nated.  This means that testing all transformers would  be
necessary in order to be certain about the appropriate  cate-
gory.  This would be extremely expensive.  Therefore, the
requirements in the Rule for servicing, disposal, labeling,
and use have been designed to make this testing step largely
unnecessary.
                                 (11)

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     The only servicing restriction on PCB-Contaminated Trans-
formers is that companies servicing transformers owned by others
and who sell PCB-contaminated mineral oil to their customers must
receive an exemption from EPA.  If they sold only uncontaminated
mineral oil (less than 50 ppm PCBs), then no exemption would be
needed.

     The disposal requirements for PCB-contaminated fluids  are
specific (high efficiency boilers, incineration or chemical waste
landfills).  However, the disposal options for fluids from  Non-
PCB Transformers are not much greater, because of the broad pro-
hibition on using waste containing PCBs for dust control, seal-
ant or coating purposes.

     There are no labeling requirements for either transformer
categories (PCB-Contaminated or Non-PCB Transformers), and  no use
restriction differences.
 (29)  HOW WOULD TRANSFORMERS WHICH USE PCB-FREE MINERAL OIL
      DIELECTRIC FLUID BE CATEGORIZED?

     Because of the widespread contamination of mineral oil  -
dielectric fluid tranformers, they must be assumed to be PCB-
Contaminated Transformers.  Even if PCB-free dielectric fluid
was added to an existing transformer, you couldn't be certain
that PCB contamination in the transformer would not contaminate
the new fluid to a level above 50 ppm PCB.

     You, of course, have the option of testing the new aggregate
dielectric fluid in the transformer to determine if the PCB  con-
centration is below 50 ppm, in which case it could be consid-
ered a Non-PCB Transformer.
 (30)  CAN I RECLASSIFY MY PCB TRANSFORMER IF I REDUCE ITS PCB
      CONCENTRATION?

     PCB Transformers can be reclassified to PCB-Contaminated
Transformers by draining and refilling them with non-PCB di-
electric fluid.  Before they can be "reclassified the trans-
formers must be tested and found to contain less than 500 ppm
PCB after at least 3' months of in-service use.
 (31)  WHAT TYPE OF SERVICING CAN I DO ON MY TRANSFORMER?

     Routine servicing of transformers  (i.e., testing the di-
electric fluid, filtering the  fluid, removal of some fluid and
then returning or replacing it, replacing gaskets) in any of the
categories will result in minimal exposures to PCBs and allow the
                                 (12)

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use of most existing transformers throughout their lifetime.  EPA
has decided that this activity doesn't present an unreasonable
risk to human health and the environment.

     However, any servicing (including rebuilding) of PCS Trans-
formers that involves removing the coils from the casing is
prohibited by the Ban Rule.  Removing the coils substantially
increases PCB exposure/ therefore, EPA concludes that this type of
servicing presents an unreasonable risk.  EPA believes the cost of
this prohibition (about $12 million the first year and steadily
less each year after) is justified by the increased risks which
would otherwise occur to human health and the environment.
(32)  CAN I REBUILD MY TRANSFORMERS?

     Rebuilding a transformer could involve one or more of the
following:  draining the transformer, removing and disassembling
the core, reworking the coil or rewinding a new coil, reassem-
bling the core, and refilling the transformer with new fluid.

     EPA permits the rebuilding only of PCB-Contaminated Trans-
formers  (containing between 50 ppm and 500 ppm PCB), and, of
course, Ncn-PCB Transformers.  If your transformer is classified
as a PCB Transformer (containing 500 ppm or greater PCB), it
cannot be rebuilt unless it is first reclassified to a PCB-
Contaminated Transformer.

     EPA decided to permit rebuilding of PCB-Contaminated Trans-
formers, because the exposure to PCBs is relatively  low and  the
economic impact of not permitting this activity would be very
high.
 (33)  CAN I SERVICE MY OWN TRANSFORMERS?
                        t

     EPA authorizes the routine servicing of PCB Transformers  and
 the routine servicing and rebuilding of PCB-Contaminated  Trans-
 formers subject to certain conditions until July 1,  1984.
 (34)  CAN I HAVE A  SERVICE  SHOP WORK ON MY  TRANSFORMER?

     Yes, you can have work done  on your  tranformer  without
 receiving an exemption from EPA provided  the  shop  does not add
 any PCB fluid.  If  PCB fluid  (50  ppm PCB  or greater)  needs to be
 added, the shop can add  your  fluid without  obtaining an  exemp-
 tion.  However, if  the service shop adds  their  PCB fluid to
 your transformer, they must get an exemption  to do so.
                            (13)

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(35)  CAN I REUSE MY DIELECTRIC FLUID?

     Dielectric fluid can be reused as long as it  is  used  in
either the transformer that it came from or in a transformer
which had a higher concentration of PCBs than the  replacement
fluid.
(36)  WHAT FLUIDS CAN I USE WHEN I RETROFILL MY TRANSFORMER?

     Dielectric fluids containing less than 500 ppm PCBs  can be
used to refill transformers.  However, dielectric  fluids
containing less than 500 ppm  PCB under no circumstances  can be
mixed with fluids containing  500 ppm or greater PCBs.   In other
words, the deliberate dilution of PCB Transformers is         .
prohibited.  A PCB Transformer must be drained, refilled,  and
tested after it was retrofilled before it can be reclassified as
a PCB-Contaminated Transformer.  It should be noted that  PCB
Transformers are usually retrofilled with fluids that have fire
resistant properties similar  to PCBs.
 (37)  ARE THERE ANY RESTRICTIONS ON WHO CAN SELL ME  DIELECTRIC
      FLUID?

     After July 1, 1979, only those persons who have obtained
exemptions from EPA can distribute  (and sell) PCB dielectric
fluid.
 (38)  CAN I SELL MY DIELECTRIC FLUID TO A WASTE OIL DEALER?

     Dielectric fluid  containing .greater than  50 ppm PCB  cannot
be  sold to a waste oil dealer unless the dealer is to dispose of
it  in accordance with  the  regulation.  Dielectric fluid with
concentrations of less than  50 ppm can be sold to a waste oil
dealer as long as it will  not be used as a sealant, coating, or
dust control agent.
 (39)  CAN I SCRAP MY  TRANSFORMER OR SELL IT TO SOMEONE TO SCRAP?

     If your transformer  is  a PCB Transformer, you cannot scrap or
 sell your transformer to  someone else to scrap.  You must dis-
 pose of your drained  PCB  Transformer in an approved chemical waste
 landfill.  On the other hand, if the transformer is a PCB-
 Contaminated or Non-PCB Transformer, once the fluid is drained,
 the transformer can be scrapped or sold for scrap.
                                 (14)

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(40)  CAN USABLE TRANSFORMERS BE SOLD BY PRESENT OWNERS?

     Yes, provided the transformer was sold for use before July 1,
1979.  No exemption from EPA is required for such sales.
                       RAILROAD TRANSFORMERS
(41)  HOW DO I KNOW IF MY RAILROAD TRANSFORMERS ARE COVERED BY
      THE REGULATION?

     Unless a nameplate (or a test) indicates that the trans-
former on an electric locomotive contains dielectric fluid having
either no PCBs or a concentration of less than 50 ppm PCBs, your
railroad transformer is covered by the PCB regulation.


(42)  WHY ARE RAILROAD TRANSFORMERS DIFFERENT FROM OTHER
      TRANSFORMERS?  ARE THEY SUBJECT TO DIFFERENT REQUIREMENTS
      UNDER THE REGULATION?

     Railroad transformers are the transformers used on electric
locomotives and some commuter cars.  These transformers are
subject to occasional leakage due to damage caused by objects
thrown up from the tracks and by damage caused from overloads
to which these heavy service units are subjected.  Because of the
greater environmental and health risks from these transformers,
the PCB Ban rule requires that the PCBs be removed from these
transformers on a phased reduction schedule.
(43)  WHAT IS THE SCHEDULE FOR REDUCTION OF PCBs IN RAILROAD
      TRANSFORMERS?
             \
     By January 1, 1982 all Railroad Transformers must  contain
PCB concentrations of 60,000 ppm  (6%) or less.  The next  dead-
line is January 1, 1984, at which time all Railroad Transformers
must have a PCB concentration of no more than  1,000 ppm.
(44)  HOW LONG CAN I USE MY PCB RAILROAD TRANSFORMERS?

     You can use your Railroad Transformer until  January 1,  1982
if the PCB concentrations exceed  60,000 ppm,  after  that date it
is possible to use the Transformer  until January  1,  1984 if  the
PCB concentration does not exceed 60,000 ppm.   You  will not  be
                                  (15)

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able to use a Railroad Transformer containing greater than  1,000
ppm PCB after July 1, 1984.
(45)   DO I HAVE TO TEST MY RAILROAD TRANSFORMER?

     You will have to test your Railroad Transformers  immediately
after any PCB concentration reduction related servicing,  and
again between 12 and 24 months after such servicing.
(46)  HOW OFTEN DO I HAVE TO TEST MY RAILROAD TRANSFORMER?

     It is necessary to test your Railroad Transformer  immed-
iately after it has been serviced to reduce the PCB concentra-
tions in  order to verify the PCB concentration.  In addition,
between. 12 and 24 months after such servicing the transformer is
to be tested again to gauge the PCB concentration level.
(47)  ARE THERE RESTRICTIONS ON WHAT I PUT IN MY RAILROAD  ,
      TRANSFORMER?

     Yes, there are restrictions.  If you rebuild  (remove  the
coil) the Transformer after January 1, 1982 it cannot be refilled
with dielectric fluid containing a PCB concentration greater than
50 ppm.  After January  1,  1982, Railroad Transformers may  only be
serviced with dielectric  fluid containing less than 60,000 ppm
PCB.  Finally, after January 1, 1984, Railroad Transformers may
only be serviced with dielectric fluid containing  less  than 1000
ppm.
 (48)  WHAT KIND OF SERVICING CAN BE DONE ON RAILROAD
      TRANSFORMERS?

     Any kind of servicing  can be done on Railroad Transformers
until January 1, 1982.  After that time, the transformer can be
rebuilt only if it is  to be refilled with dielectric  fluid
containing less than 50 ppm PCB.  Starting on January 1, 1982
transformers may on-ly  be serviced with dielectric fluid contain-
ing less than 60,000 ppm PCB  (except when it has been rebuilt).
After January 1, 1984, Railroad Transformers may only be serviced
with dielectric fluid  containing less than 1000 ppm PCB  (except
when it has been rebuilt).

     After July 1, 1979, processing and distribution  in commerce
of PCBs in order to service Railroad Transformers can be con-
ducted only by those persons granted an exemption.
                                 (16)

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(49)  CAN I REBUILD MY RAILROAD TRANSFORMER?

     Before January 1, 1982 you can rebuild your Railroad
Transformer with PCS dielectric fluid.   After January 1, 1982,
any rebuilt Railroad Transformers must not contain dielectric
fluid with a PCB concentration greater than 50 ppm.
                            CAPACITORS
(50)  HOW DO THESE RULES AFFECT CAPACITORS?  CAN I CONTINUE TO
      USE MY PCB CAPACITORS?

     Yes, you can continue to use your PCB capacitors for their
useful life.  The primary effect of the new prohibition rules is
to terminate the manufacture of any new PCB capacitors.


(51)  WHAT ABOUT THE DISPOSAL OF PCB CAPACITORS?

     These rules continue the provisions of the PCB Disposal and
Marking Rule published in the February 17, 1978 Federal Register.
Large PCB capacitors must be disposed of in an EPA approved chem-
ical waste landfill or incinerator.  After March 1, 1981 all PCB
large capacitors will have to be incinerated in an EPA approved
incinerator.  EPA requires that all PCB capacitors be packed in
Department of Transportation (DOT) drums with absorbent material
prior to their disposal in chemical waste landfills.

     Special disposal is not required for. small capacitors	
except those waste capacitors owned by PCB capacitor or PCB
equipment producers.  Disposal of small PCB capacitors owned by
manufacturers parallels the disposal of large PCB capacitors.
(52)  WHAT IS THE DIFFERENCE BETWEEN LARGE AND SMALL CAPACITORS?

     Small capacitors have less-than 3 pounds of dielectric fluid;
large capacitors have 3 pounds or more of dielectric fluid.


(53)  I HAVE PCB CAPACITORS THAT ARE TEMPORARILY OUT OF  SERVICE;
      CAN THEY BE PUT BACK INTO SERVICE?

     Yes, but they will be subject to disposal requirements at a
later date.
                                 (17)

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(54)   I NEED SPECIAL PCB CAPACITORS TO SERVICE MY PCB
      EQUIPMENT.  WILL I BE ABLE TO BUY REPLACEMENT PCB
      CAPACITORS?

     If suppliers receive an exemption from EPA, they can  sell
existing stocks of PCB capacitors to service existing .PCB
equipment.
                         MINING EQUIPMENT
(55)   WHAT TYPE OF MINING MACHINES ARE LIKELY TO HAVE PCBs?

     PCBs are found in the electric motors of continuous miners
and loader-type equipment that were manufactured up through  the
early 1970's.
(56)  CAN I CONTINUE TO USE THESE MACHINES?
                                    •
     In general, these machines can be used until January  1, >1982.
The new rules set up a schedule whereby the motors  in the
equipment can be converted to non-PCB types.  It appears that  the
continuous miner motors cannot be converted, which  means the
older models with PCB motors will probably have to  be scrapped.
 (57)  CAN I REPAIR THESE MACHINES?

     Servicing or repair of PCB mining equipment  is permitted
only for persons who are granted an exemption by  EPA.  Repair
restrictions apply only to the PCB motors, not  the rest of  the
machine.  While the machines are in use in mines  or mining  areas,
PCBs can be added to these motors until January 1, 1982.

     When PCB motors in loader-type equipment are returned  to a
service shop for servicing they must be rebuilt as air cooled or
other non-PCB containing motors or be replaced  with non-PCB motors.
Because PCB motors in continuous miner equipment  cannot be  success-
fully converted to non-PCB motors, these motors are allowed to be
rebuilt as PCB motors until January 1, 1980 in  order to ease the
impacts of phasing out this equipment.  Any servicing or repair
that involves the sale of PCBs can be performed only by persons
who are granted.an exemption by EPA.
 (59)  CAN I SCRAP THESE MACHINES?

     Yes, but first  the PCB motors must be removed  and properly
disposed.  PCB motors  can either be incinerated  or, after drain-
ing the PCBs, placed in a chemical waste  landfill.


                                 (18)

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(60)   HOW LONG CAN I USE THESE MACHINES?

     PCBs cannot be used in mining equipment after January 1, -1982.



                         HYDRAULIC SYSTEMS
(61)  DO ALL HYDRAULIC SYSTEMS HAVE PCBs IN THEM?

     Probably not.  PCB hydraulic fluid was developed for use in
machines that were subject to high temperatures, such as aluminum
die casting machines and hydraulic machines in steel mills.  Be-
cause of their low flammability, PCBs provide an extra measure of
fire protection.  The use of these high concentration fluids was
discontinued several years ago by most users,-because of serious
water pollution problems.  However, residues of the original
fluid remain in sufficient quantities to be of continuing envi-
ronmental concern.

     In addition, it is possible that hydraulic systems on other
machines that did not pose any special fire risk also had these
PCB fluids added to them.  These may be sufficiently contaminated
to require action under these regulations.


(62)  CAN"THESE PCB CONTAMINATED HYDRAULIC SYSTEMS CONTINUE TO BE
      USED?  IS ANY CORRECTIVE ACTION NECESSARY?

     These PCB contaminated systems can be used until July 1, 1984,
provided that a corrective program of testing, draining, refilling,
and/or topping-off is undertaken.


(63)  HOW OFTEN MUST I TEST MY HYDRAULIC SYSTEM?

     Any hydraulic system that ever contained PCB hydraulic fluid
must be tested by November 1, 1979, and, at  least annually there-
after, until the system reaches 50 ppm PCB.  However, on November  1,
1979 EPA proposed to require testing only of  hydraulic  systems engagec
in the production or forming of metal by November 1,  1979  and at
least annually thereafter.


(J64)  DO I HAVE TO DRAIN AND THEN  REPLACE ALL OF THE  HYDRAULIC
      FLUID IN MY MACHINES WHENEVER THEY EXCEED  50  PPM  PCBs?

     The regulations provide a  flexible approach for  reducing PCB
concentrations.  Highly contaminated systems  will have  to  be
drained and probably flushed and wiped clean  in  order to effec-
tively reduce the PCB levels.   Other systems  may be effectively
decontaminated by draining and  filtering or  distilling  to  reduce
the PCB concentration below  50  ppm.  Systems  with  low level  con-
tamination or borderline levels may be effectively  controlled by
simply topping-off with non-PCB fluid.
                                 (19)

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(65)  ARE THERE ANY RESTRICTIONS ON THE FLUIDS  THAT CAN  BE ADDED
      TO THESE SYSTEMS?

     Yes, there are restrictions.  No  fluids  containing  more than
50 ppm PCBs can be added.  This moans  that  fluids  collected from
leaking seals, fittings, etc.  cannot  be  returned  to the systems
if the fluid exceeds 50 ppm PCBs.
                       HEAT TRANSFER SYSTEMS
(66)  DO HEAT TRANSFER SYSTEMS CONTAIN PCBs?   WHAT ARE THE
      REQUIREMENTS FOR USE/OR REMOVAL?

     PCBs have been used in heat transfer  systems  because of
their high heat retention capacity.   These  systems do leak at
times, and, therefore, are controlled by this  rule.  The re-
quirements for testing, refilling,  and topping-off are very
similar to hydraulic  systems.
(67)  ARE THERE DIFFERENT REQUIREMENTS FOR  HEAT TRANSFER SYSTEMS
    -  USED IN THE MANUFACTURE OF FOODS,  DRUGS,  AND COSMETICS?

     Yes, after November 1,  1979 all heat transfer systems  must
contain fluid below  50 ppm  if they  are to be  used in the manufacture
or production of foods, drugs, and  cosmetics.   EPA proposed on
May 9, 1980 to prohibit their use in facilities manufacturing,
processing, or storing fertilizer or agricultural pesticides
with a few exceptions.
                          OTHER PCB USES
(68)  CAN PCBs BE USED AS A MOUNTING MEDIUM FOR MICROSCOPIC
      SLIDES?

     Yes, until July  1,  1984.  EPA will decide  later whether to
extend the authorized time for this PCB use.
(69)  CAN PCBs CONTINUE  TO BE USED IN SMALL QUANTITIES FOR
      RESEARCH AND DEVELOPMENT?

     Yes, until July  1,  1984.  As with microscopic  slides, EPA
will decide later whether to extend the authorized  time  for use,
                                 (20)

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(70)   IN THE -\?-- --'Vs CARBONLESS  COPY PAPER f'AS MADE WITH  INK
               TF^.   WHAT PROVISIONS DOES THE PCB BAN RULE
      MAKE FOR THIS ?---?ER?

     Although carbonless copy paper is no longer made with .PCBs,
supplies of this raperstock still exist; most are  in files.
Because the amount of PCB on each sheet is extremely small  and no
inexpensive method of separating PCB from ncn-PCB  carbonless
paper has been developed, EPA has _ authorized the use of  existing
PCB carbonless copy paper indefinitely.



(71)  SOME 'PIGMENTS CONTAIN PCBS, CAN THEY CONTINUE TO BE USED?

     EPA1 s PCB Ba^ Sale  authorizes the  use of  diarylide and
pthalocyanine pig=ents,  containing PCBs  as an  impurity " con-
centrations ranging from several thousand parts per ^-lljon to
50 ppm, until January  1,  1982.  However,  after July 2, 1979,
these pigments, containing greater than 50 ppm PCB  canno t be
manufactured, and they cannot be processed or  distributed in
commerce after July 1,  1979, unless  EPA grants exemptions for
these activities.


(72)  OTHER CHEMICALS  ALSO CONTAIN PCBs IN LOW CONCENTRATIONS,
      CAN THEY CONTINUE TO BE USED?

     At  this time  EPA' s Ban Rule does not authorize  the use  of
anv other chemicals containing  PCBs.  Several manufacturers
have request exemptions to' manufacture chemicals with  low concen-
trations of PCBs, and, if these exemptions are granted,  EPA will
consider appropriate authorizations to permit  the use of the
chemicals.



(73)  IF SOMEONE MANUFACTURES PCB CONTAMINATED CHEMICALS BUT DID
      NOT APPLY TO EPA FOR AN EXEMPTION CAN THEY  STILL REQUEST
      ONE?

     Anyone  in that situation should  apply  to EPA for an
exemption using the procedures EPA  published  ir the Federal
Register on November  1,  1978.   (See the ''Contacts for Infor
mation"  Section of this Booklet  to find  out  how to obtain a copy
of  this  Federal Register Notice.)

     EPA will  decide  on a case  by case bas is .whett"°f "<*]£„
accept  for  consideration all exemption petitions submitted after
their respective  filing deadline.   See the  March 5,  1980 Federal
Register Notice  for more details.
                                 (21)

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(7'4)  CAN ELECTROMAGNETS CONTAINING PCBs STILL B2 USED?

     EPA considers the use of electromagnets (similar to trans-
formers in construction) containing PCBs to be used in a totally
enclosed manner, therefore, these PCB electromagnets may continue
to be used and serviced.

     Persons may service their own PCB electromagnets until July 1,
1984.  However, if someone else adds PCBs, not owned by the
electromagnet owner, during the servicing, they must obtain an
exemption from EPA after July 1, 1979.
                             LABELING
(75)-  WHAT NEEDS A LABEL?

     Most PCB Items (including PCB Containers, PCB Article
Containers, PCB Articles, PCB Equipment, and PCB Transport
Vehicles) that contain 50 ppm or greater PCBs must be labeled.
This labeling requirement is a modification from the February 17,
1978 Disposal and Marking Regulation which applied to PCB Items
that contain 500 ppm or greater PCBs.
(76)  DO ALL TRANSFORMERS CONTAINING PCBs HAVE TO BE LABELED?

     PCB Transformers, containg 500 ppm or greater PCB, are
required to be labeled.  PCB-Contaminated Transformers, con-
taining between 50 and 500 ppm PCB, are not required to be
labeled.  The cost of marking a very large number of PCB-
Contaminated Transformers while they are in service would be
extremely high (approximately $10 for each of the 35 million
transformers).

     An unmarked mineral oil transformer is automatically assumed
to be a PCB-Contaminated Transformer.  However, if a transformer
has no nameplate information but there is a reasonable suspicion
that PCBs may be present above 500 ppm 	 the transformer should be
labeled as a PCB Transformer until the PCB content can be
verified.
 (78)  WHERE DO I HAVE TO PUT THE LABELS?

     All labels  (or marks) are to be put on the exterior of PCB
 Items and transport vehicles in a place that they can be easily
 seen and read by anyone inspecting or servicing them.
                                (22)

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(78)   THERE ARE A LOT OF PCB CAPACITORS AND EQUIPMENT CONTAINING
      THESE CAPACITORS IN USE.   DO THEY ALL. HAVE TO BE LABELED?

     The requirements for labeling capacitors are primarily
related to disposal;  the labels serve as a positive reminder
regarding disposal.   All large, high voltage PCB capacitors have
to be labeled, including those in service.  Large, low voltage
capacitors have to be labeled when they are taken out of service
for disposal.

     Small capacitors do not have to be labeled.  Equipment con-
taining PCB capacitors does not have to be labeled unless the
capacitor is a large, high voltage type or if the equipment was
produced after January 1, 1979 and contains a small PCB capacitor
Then the equipment should be marked at the time of manufacture,
"This equipment contains PCB Capacitors".
(79)  DO I HAVE TO LABEL A PCB CAPACITOR THAT IS ON A POLE OR IN
      A SIMILAR INACCESSIBLE LOCATION?

     If a PCB capacitor is installed in a "protected" area  (e.g.,
on a power pole, or structure, or behind a fence) the pole,
structure, or fence is to be labeled in a place easily seen by
interested persons", such as servicemen.
(80)  I SUBMITTED A PETITION TO EPA TO BE GRANTED AN EXEMPTION
      FROM THE JULY 2, 1979 MANUFACTURING BAN.  IF I AM GRANTED
      AN EXEMPTION, WHAT WILL THE LABELING REQUIREMENTS BE FOR
   '  THE PCBS I MANUFACTURE?

     Any labeling requirements for chemical  substances or mix-
tures containing 50 to 500 ppiu PCBs manufactured after July  2,
1979, including PCBs that are byproducts or  impurities, will be
included in the exemption response EPA might grant to permit such
manufacture.

     If you have already submitted a petition to EPA for a
manufacturing exemption and your chemical contains less than 500
ppm PCBs, you do not have to apply a label until EPA acts on your
petition.  However, any container or any products  that contain
500 ppm or greater PCB must be labeled — even before EPA acts on
the petition for your chemical.

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(81)  IF RENTED OR'LEASED EQUIPMENT CONTAINS PCBs, WHO IS
      RESPONSIBLE FOR LABELING?

     Both the owner and the operator could be held responsible
for the labeling of rented PCB equipment.
(82)  DOES EPA SUPPLY LABELS FOR PCB CONTAINERS OR PCB ARTICLES
      AND EQUIPMENT?  DOES EPA PROVIDE NAMES OF SOURCES FOR SUCH
      PCB LABELS?

     EPA does not supply any PCB labels.  However, the Agency
knows of two sources from which you can obtain the required
labels:  LABELMASTER, 7525 North Wolcott Ave., Chicago, Illinois
60626, phone:  312-973-5100 — to place only orders call toll
free 800-621-5808 (except in Illinois); W.H. BRADY CO., Faci-
ilities, Identification, Products Division, 727 W. Glendale Ave.,
Milwaukee, Wisconsin, phone:  414-332-8100  (x624).

     Printing shops who produce labels would also be potential
sources for these labels.  The label format and sizes are
included in the regulation.
                              TESTING
(83)  IS THERE AN EPA APPROVED TESTING AND SAMPLING PROCEDURE FOR
      PCB DETECTION?

     A variety of procedures exist for determining PCB con-
centrations in various media such as water, air, soil, mineral
oil, pigments, etc.  EPA has already made available through its
Regional Offices copies of test procedures for PCBs in air, soil,
water, and sediments.  EPA is also preparing additional infor-
mation on test procedures for PCBs in oils; this information will
also be available from EPA Regional Offices.  In addition, copies
of  these procedures can be obtained from EPA's Office of Industry
Assistance.   (See the "Contacts for Information" Section of this
Booklet on how to obtain this information.)
 (84)  WHAT EQUIPMENT IS AVAILABLE TO DETECT PCBs?

     There is no simple field test for detecting PCBs.  It is
usually done using gas chromatography/electron capture.  The best
solution would be to contact an experienced chemical laboratory
in your area that could perform such tests.
                                 (24)

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 (85)  ARE THERE EPA APPROVED LABS TO ANALYZE SAMPLES OF PCBs?

     No,  EPA does not have a program for recommending or
approving analytical laboratories.
                              STORAGE
(86)   WHAT KINDS OF CONTAINERS ARE APPROPRIATE FOR STORAGE?

     The May 31, 1979 Final Rule permits 5 container types  (5,
SB, 6D,  17C and 17E) which comply with Department of Trans-
portatioii (DOT) specifications set out in 49 CFR 173.346, to be
used to store liquid PCBs.  Most of industry already is using
these containers for PCB storage and handling.
(87)   CAN LARGE CONTAINERS, SUCH-AS STORAGE TANKS, BE USED FOR
      THE STORAGE OF PCB LIQUIDS?

     EPA decided in the Final Rule to permit large containers,
such as storage tanks, to be used to store bulk PCB liquids.
This is to -allow safe transfer and storage of large PCB liquid
quantities; in addition, to reduce storage costs.  In other words,
the transfer of stored bulk PCBs from tanks to other tanks or
tank trucks will lessen the•spill risks as opposed to having to
transfer these large quantities from a number of smaller storage
drums into transfer tanks.

     These storage tanks must meet design and construction
standards adopted by OSHA  (29 CFR 1910.106).  Also the storage
facilities must have a spill prevention control and counter
measure plan similar to the plans required for oil spill
prevention.          .   l

     Owners and operators of bulk storage facilities will have  to
keep records of the amounts added to and removed from bulk
containers.  These records will be important in tracing waste
shipments and enforcing the disposal and storage requirements.
(88)  CAN PCB CONTAINERS OF CONTAMINATED SOIL BE TEMPORARILY
      STORED?

     Yes, non-liquid PCB wastes,  such as contaminated  soil, can
be temporarily stored for up  to  30 days.
                                 (25)

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(89)   CAN PCB LIQUIDS OF LOW CONCENTRATION BE TEMPORARILY
      STORED?  OF HIGH CONCENTRATION?

     Low concentration PCB liquids  (50 to 500 ppm) can be
temporarily stored for up to 30 days.  All temporary  storage
areas must have a spill prevention control and counter measure
plan.  However, the final rule does not allow temporary  storage
for high concentration PCB liquids  (above 500 ppm) because  of the
potential harm from a spill.
(90)   I HAVE A SMALL QUANTITY OF PCBs  (I.E., A FEW SOAKED  RAGS
      AND 1 GALLON OF PCBs IN AN APPROVED CONTAINER), AND  I  DON'T
      WANT TO SEND THEM A LONG DISTANCE FOR DISPOSAL.  CAN I
      STORE THEM UNTIL A PCB DISPOSAL  SITE CLOSE TO ME IS
      APPROVED?

     The mentioned items may be stored until the last day  of
1983.
(91)  ONCE PCB ARTICLES ARE TAKEN OUT OF SERVICE,"HOW LONG CAN
      THEY BE KEPT BEFORE BEING PLACED IN AN APPROPRIATE  STORAGE
      AREA?  WHAT ABOUT PCB EQUIPMENT CONTAINING  LEAKING  PCB  .
      ARTICLES?

     Non-leaking PCB articles and PCB containers  containing
leaking articles can be temporarily stored for up to 30 days.
 (92) ' WHEN PCB CAPACITORS OR CONTAINERS ARE STORED  IN AN
    -  APPROPRIATE STORAGE AREA, WHAT HAPPENS WHEN ONE OF  THESE
      ITEMS START TO LEAK?

     A leaking PCB capacitor should be immediately  placed in  a
non-leaking Department  of Transportation approved drum  and any
spillage cleaned up using sorbent or suitable  solvents.   It is  a
good practice to add sorbent material, such as  saw  dust,  to the
container to soak up any liquid that continues  to leak  out of the
capacitor.

     When a container develops a leak, the contents -should
immediately be transferred  to another, non-leaking  container  or
to  special "overpack" containers, such as those used in the
chemical industry for leaking containers.
                                 (26)

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(93)   MUST THE EPA INSPECT A PCB STORAGE AREA ONCE IT IS BUILT
      BEFORE IT CAN BE USED?

     No, it is the responsibility of the organization storing the
PCBs to insure that the storage area meets the specifications.
(94)  DO PCB STORAGE AREAS HAVE TO BE PERIODICALLY CHECKED FOR
      LEAKS OR OTHER PROBLEMS?  WHAT ABOUT PCB ARTICLES/ SUCH AS
      TRANSFORMERS, THAT ARE IN SERVICE?

     PCB storage areas must be checked by the owner or operators
at least every 30 days.  Articles in service are not required to
be checked by the regulations, but periodic checks would be a
wise practice.
                           SPILLS
(95)  DO PCB SPILLS HAVE TO BE REPORTED?

     Under the authority of TSCA, PCB spills have to be reported
whenever the incident poses a substantial risk to human health or
the environment.  Since "substantial risk" cannot be precisely
defined, any spill should be reported when people come
into direct and uncontrolled contact with PCBs, or the extent of
the spill is large enough to expose significant numbers of  ani-
mals.

     In addition, a spill should also be reported when the  volume
or the extent of the spill is unknown — such as' spills that
enter drainage systems.  PCB spills into water, onto shorelines,
or those that threaten water-courses should always be immediately
reported.      '
                         \
     EPA is currently 'completing regulations under the Clean Air
Act that will require reporting for water-related hazardous
chemical spills  (including PCBs).  These regulations will have
criminal penalties for failing to report such spills.

     As a general rule, spills involving a single capacitor do
not have to be reported unless PCBs threaten or enter a water-
course.  Because of the greater threat  to health and the envi-
ronment, transformer spills should be reported — unless only
minor leaks, such as bushing leaks, are involved.  Any  spilling
or  leaking should be stopped and repaired as soon as possible.
                                 (27)

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(96)   HOW DO I REPORT PCB SPILLS?

     PCB spills can be reported to the National Response Center
operated by the U.S. Coast Guard at 800-424-8802  (in  the District
of Columbia, call 426-2675)  and to the nearest EPA Regional Office.
(97)   WHAT HAPPENS WHEN I REPORT A PCB SPILL? CAN I GET
  . -   INFORMATION OR ADVICE ON WHAT TO DO ABOUT THE SPILL?

     The National Response Center will direct the report to the
appropriate EPA environmental emergency office, based on the
location of the spill.  Experts from these offices  (or related
state and local experts) will contact persons responsible for the
spills, in order to evaluate the potential environmental threat
and to determine the appropriate spill control and cleanup
measures.
(98)  IF I HAVE A SPILL, WHAT SHOULD I DO TO CONTROL OP CLEAN UP
      THE SPILL?
                                                   \        ^
     The first priority is to control the spread of the spill by
damming or diking the leak.  Also, any threats t6 water should be
given top priority.

     Once a spill is contained clean up measures can begin.
Clean up can be simply the removal of contaminated soil or
debris.  In some cases, more complex techniques may be required,
such as special PCB sorbents or special filtration/carbon
absorption removal of PCBs from water.

     Water and complicated spills should be cleaned up by trained
and experienced personnel.  Organizations, who frequently handle
PCBs, should develop contingency plans and conduct training for
dealing with spills.  Commercial firms are also available on a
contract basis to clean up spills.  Government spill experts can
provide information on such firms.
                    RECORDKEEPING
 (99)  MUST COMPANIES KEEP  RECORDS OF THE DISPOSITION OF PCBs IN
      SERVICE?  IN STORAGE?   IF SO, FOR HOW LONG?

     If you own or operate a  facility which uses PCBs or PCB
Items, or have either  stored, you are to keep records of their
                                 (28)

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disposition.  Specifially, this applies to facilities using or
storing at least 99.4 pounds (45 kilograms)  of PCBs in PCB
Container(s);  one or more PCB Transformers;  or 50 or more PCB
High or Low Voltage Large Capacitors.

     These records shall be maintained for at least 5 years after
the facility ceases using or storing PCBs or PCB Items in
prescribed quantities.
(100) DO PCB INCINERATOR FACILITIES HAVE TO KEEP RECORDS?
      CHEMICAL WASTE LANDFILL FACILITIES?  HIGH EFFICIENCY BOILER
      FACILITIES?  IF SO, FOR HOW LONG?

      Owners or operators of all three types of PCB Disposal
Facilities have to keep records.  Incinerator and high efficiency
boiler facilities must keep their records for 5 years; chemical
waste landfill facilities .must keep their records for at least 20
years after PCBs have stopped being disposed there.
(101) WHEN MUST I BEGIN KEEPING RECORDS OF MY PCB FACILITIES?

     PCB recordkeeping, if applicable, was to have begun on July
2, 1978.  These records form the basis of an annual document
prepared for each facility by July 1; the first annual  reports
should be compiled by July 2, 1979, for the period January 1, 1978
through December 31, 1978.
 (102)  MUST COMPANIES SEND THEIR ANNUAL REPORTS CONCERNING PCBs  TO
       EPA OR KEEP THEM FOR THEIR OWN RECORDS?

     Companies should keep their PCB records  and  annual reports
 at their facility for.inspection by EPA peronnel.   Do not send
 the  records or reports to EPA unless it is  specifically requested
 by the Agency.
 (103) I HAVE PCB  FACILITIES  IN  SEVERAL  LOCATIONS.   DO RECORDS
      HAVE TO BE  KEPT AT EACH SITE?

     Owners or  operators of  more than one  facility having PCBs
may  choose to keep  all of the records at a single  facility,  but
the  identity of that single  facility must  be available at each
location.  The  record location  must  be  manned at least 8 hours a
day, for  a normal forty hour work week.
                                 (29)

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                          DISPOSAL
(104) HOW DO I DISPOSE OF TRANSFORMERS CONTAINING PCBs? -

     There are two ways to dispose of a PCB Transformer, which
contains PCB concentrations in excess of 500 ppm.  The trans-
former and the dielectric fluid can be burned together in a high
temperature -incinerator • approved by EPA, or the liquid can be
drained out of the transformer first.  If the liquid is drained,
the transformer must be flushed with solvent for 18 hours; the
solvent and the dielectric fluid must then be disposed of in an
EPA approved high temperature incinerator.  The drained trans-
former after it is resealed must be disposed of in a chemical
landfill which has been approved by EPA.

     If the transformer is a PCB-Contaminated Transformer,
containing more than 50 ppm PCB and less than 500 ppm PCB, the
transformer and the liquid can also be incinerated or the di-
electric liquid can first be drained.  If the liquid is drained
it can be disposed of in a high temperature incinerator, a chem-
ical landfill- which has been approved by EPA, or in a high effi-
ciency boiler.  The drained transformer can be disposed of as
scrap or in a disposal facility equivalent to good municipal
solid waste disposal practices.
(105)  HOW DO I DISPOSE OF LARGE PCB CAPACITORS?

     Until March 1, 1981 large PCB capacitors as well as small
PCB capacitors owned by manufacturers of PCB capacitors can be
disposed of in approved chemical waste landfills or high temper-
ature incinerators.  EPA requires all PCB capacitors be con-
tainerized and packed with absorbent material prior to their
disposal in chemical waste landfills.  After March 1, 1981
they must be disposed of in EPA approved incinerators.  It is
expected that hammermill type crushers will be used at the
incinerators to improve the destruction efficiency.  These large
capacitors account for approximately one-third of the PCBs
currently in service.
(106) WHERE CAN PCB.ARTICLES  (OTHER THAN PCB TRANSFORMERS AND
      CAPACITORS) BE DISPOSED?

     PCB articles can be disposed of in a chemcial waste land-
fill, as well as, in high temperature incinerators, provided they
are EPA approved.  Examples of these articles, which account for
less than 1% of the PCBs currently in use in the U.S., are pipes,
hoses, parts of heat transfer systems, electromagnets, and
electric motors.
                                (30)

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     When these articles are disposed of in chemical waste
landfills, they must be drained of free flowing liquid, and
therefore, will contain only small amounts of PCBs.


(107) ARE THERE SPECIAL DISPOSAL REQUIREMENTS FOR SMALL PCB
      CAPACITORS CONTAINED PRIMARILY IN SMALL APPLIANCES AND
      FLUORESCENT LIGHT BALLASTS?

     No, small capacitors can be disposed of as municipal
waste.  EPA has determined that the random disposal of small
capacitors in municipal solid waste sites by householders and
other infrequent disposers does not present an environmental
hazard.

     However, the disposal of large quantities of small PCB
capacitors by commercial and industrial activities poses a larger
environmental risk.  Therefore, EPA encourages these persons to
establish voluntarily a collection and disposal program that
wo-uld result in the waste capacitors going to chemical waste
landfills or high temperature incinerators.
 (108)  HOW ARE HYDRAULIC MACHINES CONTAMINATED WITH PCBs TO BE
       DISPOSED?

     In general, only a relatively small portion of these ma-
chines are contaminated with PCBs, in particular those used in
die-casting and forging operations.  Therefore, instead of re-
quiring disposal in  a chemical waste landfill, the final rule
permits disposal of  hydraulic systems as municipal solid waste
and  salvaging of these machines  after draining.  First, the ma-
chines must be drained of  all free-flowing  liquid.  If the fluid
contains more than 1000 ppm PCBs, the machine must be flushed
with'a solvent and thoroughly drained before disposal.  The
liquid must be-disposed of by high temperature incinerators or,
if the PCB concentration is 50 to 500 ppm,  by high efficiency
boilers or in chemical waste landfills.
 (109)  HOW CAN I  DISPOSE OF THE DIELECTRIC  FLUID IN MY
       TRANSFORMER?

     Fluids from  PCB Transformers  (concentration of 500 ppm
 or greater)  must  be  disposed of only by high temperature incin-
 eration.   Fluids  from PCB-Contaminated Transformers (with 50 ppm
 to 500 ppm PCBs)  must be disposed  of in high efficiency boilers,
 in approved chemical waste landfills,  or in high temperature
 incinerators.   Fluids from Non-PCB Transformers (with less than
 50 ppm PCBs)  have one disposal restriction:  they cannot be used
 as a sealant,  coating, or dust control agent if they contain any
 detectable PCB.
                                  (31)

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(110)   WHERE CAN OTHER LIQUID WASTES WITH OVER 500 PPM PC3s BE
       DISPOSED?  BETWEEN 50 AND 500 PPM PCBs?  LESS THAN 50 PPM
       PCBs?

     The same disposal options apply as for transformer
dielectric fluid.  (refer to Question #109).
(Ill)   WHERE CAN NON-LIQUID PCBs BE DISPOSED?

     Non-liquid PCBs at any concentration  (e.g., contaminated
rags and absorbent materials, and contaminated soils and other
solids recovered from spills or removed from old disposal  sites)
can be disposed in Annex II chemical waste landfills.
(112)  CAN DECONTAMINATED PCB CONTAINERS BE DISPOSED OF IN AN
       ORDINARY LANDFILL SITE?

     Yes, decontaminated PCB containers may be disposed of in
ordinary landfill sites, rather than in EPA approved chemical
waste landfills.                                    •*
 (113)  CAN DECONTAMINATED PCB CONTAINERS BE REUSED?

     Containers decontaminated in accordance with Annex IV can
be reused for general use.


 (114}-- HOW CAN PCB CONTAINERS USED ONLY TO HOLD LOW PCB' CON-
       CENTRATIONS BE DISPOSED?

     PCB Containers used only to contain materials or fluids with
PCB concentrations between 50 and 500 ppm can be disposed of as
municipal waste.
 (115)  WHAT ARE THE REQUIRMENTS FOR DISPOSAL SITES?

     Incinerators used to dispose PCBs must be approved by
 the  appropriate EPA -Regional Administrator.  The approved incin-
 erators must meet the requirements set out in Annex I of the May
 31,  1979 Rule.

     Likewise, the chemical waste landfills used for the disposal
 of PCBs and PCB Items must be  approved by the appropriate EPA
 Regional Administrator, which  meet the requirements established in
 Annex  II of the Final Rule.


                                (32)

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     High efficiency boilers used for the disposal of PCB-
contaminated non-mineral oil fluids must also be approved by
the appropriate EPA Regional Administrator using the procedures
established in Section 761.10 (a) (3) (iii) (B)  of the Final
Rule.  High efficiency boilers used for the disposal of PCB-
contaminated mineral oil fluids do not need to be approved, how-
ever, persons are required to notify the appropriate Regional
Administrator using the procedures established in Section 761.10
(a) (2) (iii) (B) before commencing such burning."
(116)  HAVE ANY DISPOSAL SITES BEEN APPROVED FOR PCBs?  WHERE ARE
       THEY?

     Yes, eight chemical waste landfills sites have been approved.
No incinerator sites have yet been approved, but three sites are
currently being considered.


The landfill locations are as follows:

1.  Facility:  CECOS International Waste Systems, Inc. Facility Address;
4528 Royal Avenue, Niagara Falls, New York  14303.  Facility Telephone
Number:  (716) 731-3281.  Type of Facility Approved:  Chemical
Waste Landfill. " Type of PCB Waste Handled:  Capacitors (small and
large); Properly drained "transformers:  Contaminated soil, dirt,
rags, and other debris; Dredge spoils; Municipal sludges; and
Properly drained containers  (drums).  Expiration Date of Approval:
August 18, 1981.  EPA Regional Office Contact:  Wayne Pierre.
EPA Telephone Number:   (212)  264-0505.


2.  Facility;  SCA Chemical Services, Inc.  Facility Address:
1550 Balmer Rd., Model City, New York  14107.  Facility Telephone
Number:  (716) 754-8231.  Type of Facility Approved:  Chemical
Waste Landfill.  Type of PCB Waste Handled:  Capacitors  (small
and large); Properly drained transformers:  Contaminated soil,
dirt, rags, and other debris; Dredge spoils; Municipal sludges;
and Properly drained containers  (drums).  Expiration Date of
Approval:  October 2, 1981.  EPA Regional Office Contact:  Wayne
Pierre.  EPA Telephone  Number:   (212) 264-0505.


3.  Facility;  Waste Management of Alabama, Inc.  Facility Address:
P.O. Box 1200 Livingston, Alabama  35470.   Facility Telephone
Number:  (205) 652-9531.  Type of Facility  Approved:  Chemical
Waste Landfill.  Type of PCB Waste Handled:  Capacitors  (small  and
large):  Properly drained transformers; Contaminated  soils,
dirt, rags, and other debris; Dredge spoils; Municipal sludges;
and Properly drained containers  (drums) ; Liquid PCBs  at  a con.-
centration of between  50  to 500  ppm.  Expiration Date of
Approval:  Open-ended.  EPA Regional Office Contact:  Mr. James
Scarbrough.  EPA Telephone  Number:   (404)  881-3016.
                               (33)

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4.  Facility;  CECOS International Chemical Waste Systems of
    Ohio, Inc.  Facility Address:  5092 Aber Rd., Williamsburg,
    Ohio  45176.  Facility Telephone Number:   (513) 724-6114.
    Type of Facility Approved:  Chemical Waste Landfill,  "type
    of Waste Handled:  Capacitors (small and large); Properly
    drained; Dredge spoils; Municipal sludges; Properly drained
    containers  (drums);  Liquid PCBs at a concentration of between
    50 to 500 ppm.  Expiration Date:  Open-ended.  EPA Regional
    Office.Contact:  Mr. Jay Goldstein.  EPA Telephone Number:
    (312) 353-2197.

5.  Facility;  Casamalia Disposal. Facility Address:  539 Ysidro
    Rd., P.O. Box 5275,  Santa Barbara, California  93108 - main
    office  (site located near Casamalia in Santa Barbara County).
    Facility Telephone Number:   (805) 969-5897.  Type of Facility
    Approved:  Chemical Waste Landfill.  Type of PCB Waste
    Handledt:  Capacitors (small and large) ; Properly drained
    transformers; Contaminated soil, dirt, rags and other debris;
    Dredge spoils; Municipal sludges; and Properly drained
    containers  (drums).   Expiration Date of Approval:  Open-
    ended.  EPA Regional 'Office Contact:  Raymond Seid.  EPA
    Telephone Number:   (414) 556-3450.

6.  Facility;  Nuclear Engineering Co., Inc.  FacilityvAddress-:
    9200 Shelbyville Rd., Suite 526, P.O. Box 7246, Louisville,
    Kentucky  40207, main office  (site located near Beatty, Nevada
    in Nye County).  Facility Telephone Number:  (502) 426-7160.
    Type of Facility Approved:  Chemical Waste Landfill.  Type of
    PCB Waste Handled:   Capacitors  (small and large); Properly
    drained transformers; Contaminated soil, dirt, rags and other
    debris; Dredge spoils;  Municipal sludges; and Properly drained
    containers  (drums) .   Expiration Date of Approval:  Open-ended-.
    EPA Regional Office Contact:  Raymond Seid.  EPA Telephone Number:
    (415) 556-3450.


7.  Facility:  Chem-Nuclear Systems Inc.  Facility Address:  P.O.
    Box 1269, Portland,  Oregon  97205, main office (site located in
    Arlington, Oregon).   Facility Telephone Number:   (503) 223-1912.
    Type of Facility Approved:  Chemical Waste Landfill.  Type of
    of PCB Waste Handled:  Capacitors  (small and large); Properly
    •drained transformers; Contaminated soil, dirt, rags, asphalt,
    and other debris; Properly drained containers  (drums).  Liquid
    PCBs at a concentration of between 50 to 500 ppm.  Expiration
    Date of Approval: ' January 1, 1982.  EPA Regional Office Contact:
    Mr. Roger Fuentes.   EPA Telephone Number:   (206) 442-2850.

8.  Facility:  Wes-Con., Inc. Facility Address:  P.O. Box 564,
    Twin Falls, Idaho83301, main office  (site located in
    Grand View, Idaho).   Facility Telephone Number:   (208)
    834-2275.  Type of Facility Approved:  Disposal in Missile
    Silos.  Type of PCB Waste Handled:  Capacitors (small and
    large); Properly drained transformers; Contaminated soil,
    dirt, rags, asphalt, and other debris; and Properly drained
    containers  (drums) .


                                  (34)

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 Liquid PCBs at a concentration of between 50 to 500 ppm.
 Expiration Date of Approval:  January 1, 1982.  EPA Regional
 Office Contact:  Mr. Roger Fuentes.  EPA Telephone Numb.er:
 (206) 442-2850
 (117)  CAN A COMMON CARRIER (E.G., TRUCK LINE) TRANSPORT PCBs
       FOR A COMPANY TO,A DISPOSAL FACILITY IF THE TRANSPORT
       IS NOT WITHIN.THE INDUSTRY?

     If the common carrier complies with the Hazardous Materials
requirements set by the Department of Transportation, and the
vehicle is properly and visibly labeled on its exterior with a
PCS label it can be used to transport PCBs to a disposal site.
 (118)  CAN PCBs OR PCB ITEMS BE EXPORTED FOR DISPOSAL?  BE
       IMPORTED FOR DISPOSAL?

     No, refer to Question #22 in the "Import/Export" section of
 this Booklet.
                       PCBs IN THE WORKPLACE


 (119)  ARE THERE ANY OSHA RULES GOVERNING PCBs IN THE WORKPLACE?

     Yes, there are OSHA regulation governing PCBs in the workplace;
In addition, in 1977 the National Institute of Occupational Safety
and Health (NIOSH) — the HEW organization responsible for research-
ing workplace safety — published "Criteria for  a Recommended
Standard ... Occupational Exposure to Polychlorinated Biphenyls  (PCBs)."
OSHA, 'associated with the Department of Labor, will use  this document
to develop mandatory standards regarding PCBs.   However, the
Occupational Safety and Health Act (Section 5(a)(1)) requires  employers
to provide employees with a place of employment  that is  free from
recognized hazards.
(120)  WHAT IS A RECOMMENDED STANDARD FOR OCCUPATIONAL EXPOSURE?
       WHAT IS: THE STANDARD RECOMMENDED BY NIOSH FOR OCCUPATIONAL
       EXPOSURE TO PCBs?

     A recommended standard is a determination of the level of
exposure that will substantially reduce any risks of reproductive
or tumorigenic effects of PCBs and prevent other adverse effects
of exposure in the workplace.  It is based on a 10-hour workday,
40-hour workweek, over a normal working lifetime.
                                  (35)

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     NIQSH has recommended in their Criteria Document  for PCBs
that occupational exposure to PCBs be controlled so that no
worker is exposed at a concentration greater than 1.0  micrgram
total PCBs per cubic meter of air  (1.0 Mg/cu m) , determination  as
time-weighted average  (TWA) concentration, for  up to a 10-hour
workday, 40 hour workweek.  This is only a recommended standard
and it has not been adopted to date, by either  OSHA or EPA.  At
the present time, however, OSHA is reviewing this recommended
standard.
 (121)  DID NIOSH RECOMMEND ANYTHING ELSE TO REDUCE EXPOSURE  TO
       PCBs IN THE WORKPLACE?

     Yes, NIOSH made recommendations about work practices, per-
 sonal protective equipment and clothing, medical  surveillance,
 personal clean up and sanitation practices, and employee
 information programs.


 (122)  HOW DO OSHA STANDARDS AND NIOSH RECOMMENDATIONS  RELATE TO
       EPA1s PCB REGULATION?

     EPA1 s PCB Rules do not directly regulate workers,  but the
 Rules do restrict or prohibit certain PCB activities  which reduce
 the  number of workers exposed.  The EPA Rules prohibit  PCB trans-
 former 'and capacitor manufacture,  as well as PCB  transformer re-
 building  (except for railroad transformers); these  activities were
 the  major  long-term occupational exposures  to high  concentration
 PCBs.  The rebuilding of  PCB railroad transformers  and  mining
 machine PCB motors will result  in  long-term worker  exposure  that
 will warrant  special worker protection, but these activities will
 be phased  out over the next several years.

     Worker exposure can  -also occur as a result of  PCB  spills and
 authorized servicing operations for PCB transformers.
 (123)   WHAT KIND OF PROTECTIVE CLOTHING SHOULD BE WORN WHEN
        WORKING WITH PCBs?

      The type of protective clothing which should be worn when
 working with PCBs is dependent on the individual circumstances.
 Worker protective clothing and equipment is intended to prevent
 skin and eye contact, and control respiratory exposure.

      In any operation where ^workers may come into contact with
 PCBs, protective clothing impervious to PCBs shall be worn.
 Gloves, boots, overshoes, and bib-type aprons that cover boot
 tops should be provided when necessary.
                                   (36)

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     Skin protection can usually be achieved by wearing non-
porous gloves and boots and heavy overalls.  For major spill
clean up activities, a full suit of non-porous clothing may be
appropriate.  Also, non-porous aprons can be effective in
reducing contamination of worker clothing.

     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, "the eyes.-shall be irrigated immediately
with large quantities of water and then examined by a physician
or other responsible medical personnel.

     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 pose respiratory problems because of
solvents, such as trichlorobenzene, that are mixed with the
PCBs.  Small spills, such as capacitor failures, seldom pose
respiratory problems,  but protection should be provided for
incidents in confined areas.
                     RESPIRATOR SELECTION GUIDE
   Concentration
     of PCBs
Respirator Type Approved under
Provisions of 30 CFR 11 (OSHA)
Greater than 1.0 ug/cu m
or Emergency
(1)  Self-contained breathing
     apparatus with full face
     piece operated in pressure-
     demand or other positive
     pressure mode.

(2)  Combination Type C supplied-
     air respirator with full face
     piece operated in pressure-
     demand or other positive
     pressure mode and an
     auxiliary self-contained
     breathing apparatus operated
     in pressure demand or other
     possitive mode.
                                 (37)

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(124)   IF I GET PCB LIQUID ON MY SKIN, HOW CAN  I  REMOVE  IT?

     If liquid or solid PCBs are splashed or  spilled  on  an
employee, contaminated clothing should be removed promptly and
the skin washed thoroughly with soap and water  for at least  15
minutes.

     Eyes should be irrigated for at least 15 minutes if liquid
or solid PCBs get into them.  A drop of vegetable oil may be put
into the eye to relieve the irritating effect of  PCBs.


                     CONTACTS FOR INFORMATION
 (125)  IF I HAVE OTHER QUESTIONS ABOUT  THE  PCB BAN RULE'S
       PROVISIONS,  IS THERE SOMEONE  I CAN CONTACT?

     If you have more questions call the Industry Assistance
Office on their nationwide toll free number:   800-424-9065;
persons in the Washington, B.C. area can reach this office by
calling 554-1404.

                                                    i       %
 (126)  HOW DO I GET A COPY OF  THE  RULE? SUPORT DOCUMENT/
       VOLUNTARY ENVIRONMENTAL IMPACT STATEMENT (REFERRED  TO  IN
       THE RULES AS THE VERSAR REPORT)?

     Copies of both can be obtained  by  calling the phone numbers
mentioned in the answer to Question  125, or by writing to:

                    John  B. Ritch, Jr., Director
                    Industry Assistance Office
                    Office of  Toxic  Substances (TS-799)
                    U.S.  Environmental  Protection Agency
                    401 "M" Street,  S.W.
                    Washington, B.C.  20460
                                    (38)

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               Current PCB Regulations Published By

                The Office of Toxic Substances and

                     The Office of Enforcement
Date

December 2, 1977



January 2, 1979
Federal Register Notice

Final Rules.   Procedures for
Rulemaking Under Section 6 of
the Toxic Substances Control Act

Policy for Implementation and
Enforcement.   44- FR 108
May 31, 1979
July 9, 1979
July 20, 1979
September 19, 1979
October 2, 1979
November 21, 1979
November 21, 1979
November 29, 1979
Final Rule Interim Procedures
for Exemptions from PCB Processing
& Distribution in Commerce.
44 FR 31558

Denial of Citizens Petition.
Disposal of PCB Contaminated
Soil & Debris - North Carolina.
44 FR 13575

Notice of Receipt of Additional
Manufacturing Petitions and
Extension of Reply Comment Period.

Final Rule.  PCB Disposal Requirements
Sedgwick County, Kansas.  44 FR 54296

Exporting PCBs Proposed Rule
and Interim Guidance  44 FR 5635

Proposed Amendment to the
Disposal Requirement for Large
PCB Capacitors in Chemical Waste
Landfills.  44 FR 66851

Polychlorinated Biphenyls Approved
PCBs Disposal Facilities.

PCB, Manufacturing, Processing,
Distribution in Commerce and Use
Prohibitions; Clarification and
Proposed Amendment on Hydraulic
Machines.  44 FR 68489
                                (39)

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•March 5,  1980
 March 28,  1980
 May 1,  1980


 May 9,  1980
Request for Information on the PCB
Transformer referred to in the
Electrical Utility Industry as
"Weeping" or "Sweating". -45 FR 14232
(April 16, 1980 extended comment
period to May 5, 1980.)  45 FR 25828

Final Amendment to the Disposal
Requirements for PCB Capacitors
in Chemical Waste Landfills.  Final
Rule.  45 FR 20473

Expiration of the Open Border
Policy for PCB Disposal.  45 FR 29115

Proposed Rule prohibiting PCB Items in
Facilities Manufacturing, Processing,
or Storing Fertilizers or Agricultural
Pesticides.  45 FR 30989
                                  (40)

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