&EPA
United States
Environmental Protection
Agency
Office of
Toxic Substances TS-799
Washington DC 20460
June ^979
Toxic Substances
EPA's Final PCB Ban Rule:
Over 100
Questions & Answers
To Help You Meet
These Requirements
-------
EPA's Final PCB Ban Rule:
Over 100
Questions & Answers
To Help You Meet
These Requirements
Prepared by:
Industry Assistance Office
Office of Toxic Substances
U.S. Environmental Protection Agency
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INTRODUCTION
On May 31, 1979 in the Federal Register (44 FR 31514) the U.S.
Environmental Protection Agency published the Final Rule for
Polychlorinated Biphenyls (PCBs) Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions. This Booklet*
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 68-75
Labeling 76-83
Testing 84-86
Storage 87-95
Spills 96-99
Recordkeeping 100-104
Disposal 105-119
PCBs in the Workplace 120-125
Contacts for Information 126-127
*This Booklet has been prepared by the Industry Assistance
Office 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.
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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
chlorine molecules to a biphenyl molecule. Although PCBs may
be produced naturally in the environment, almost 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 tradename Monsanto Corporation sold PCBs under was
"Askarel". 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, Pydraul, Therminol, Pyroclor, Santotherm,
Pyralene, Pyranol, Inerteen, Asbestol, Chlorextol, Diachlor,
Dykanol, Elemex, Hyvol, No-Flamol, Saf-T-Kuhl, Aroclor B,
Clorinol, Clorphen, Eucarel.
(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 com-
mercially 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,
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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.
(6) WHY ARE PCBs HARMFUL TO HUMAN HEALTH AND THE ENVIRONMENT?
PCBs are harmful because once released into the environment
they do not break apart into new chemical arrangements, instead
they bioaccumulate in organisms throughout the environment. In
addition, PCBs biomagnify in the food chain — that is, they ac-
cumulate 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 the
exposured 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) pro-
hibit, 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.
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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 processing, dis-
tribution in commerce, and use of PCBs 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 also 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 1, 1979.
EPA earlier published procedures for filing petitions for exemp-
tion 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).
(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., excep-
tions, 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.
This 50 ppm is a change from the February 17, 1978 Disposal
and Marking Rule which set a 500 ppm cut-off. By lowering the
PCB cut-off point from 500 ppm to 50 ppm, it will substantially
increase health and environmental protection approximately,
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one million additional pounds of existing PCBs will be con-
trolled, 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. To permit the use of waste oil with any PCB-
contamination to be used in road oiling, pipe coating, or vege-
tation 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 con-
sidered "processing of PCBs", and involves the use of existing
PCBs. Processing PCBs includes such activities as placing man-
ufactured PCBs into capacitors or transformers.
(13) WHAT IS CONSIDERED A PCB ARTICLE? PCB EQUIPMENT? PCB
ITEM?
An article whose surface is directly contacted by PCBs is
considered a "PCB Article". Examples include capacitors, trans-
formers, electric motors, pumps, and pipes.
Equipment whose surface is not directly contacted by PCBs,
but contains a PCB article, is considered "PCB Equipment". Ex-
amples include televisions, air conditioners, microwave ovens,
electronic equipment, and fluorescent light ballasts and fix-
tures.
"PCB Item" is a collective term used throughout the Rule to
refer to PCB Equipment/Articles/Containers/Article Containers.
(14) WHAT EFFECT DOES THE PCB BAN RULE HAVE ON PCB ARTICLES?
PCB EQUIPMENT?
After July 2, 1979, PCB Articles can no longer be produced
because the production is not totally enclosed. However, since
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the production of PCB Equipment is considered totally enclosed
processing, this can continue until July 1, 1979 under the Rule;
in order to continue PCB Equipment production after that date, an
exemption must be chained from EPA.
(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 PRO-
HIBITION EFFECTIVE JULY lr 1979. HOW CAN I GET AN EXEMP-
TION? HAS EPA ALREADY GRANTED SOME?
In general, anyone wanting an exemption must petition EPA
for it. An exemption, valid for only one year, must be granted
annually through a formal rulemaking. In some instances, indi-
viduals may not have to seek separate exemptions when the Agency
grants "class" exemptions for some processing and distribution in
commerce bans.
In the November 1, 1978 Federal Register, EPA published in-
terim 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. Sub-
sequently, in the May 31, 1979 Federal Register notice, EPA
published a Notice of Proposed Rulemaking which identifies each
exemption petition received, and the action EPA proposed to take
on most of them.
Also, in the May 31, 1979 Federal Register, EPA has pub-
lished procedure rules for submitting exemption petitions from
the July 1, 1979 processing/distribution in commerce prohib-
itions. These procedures include the categories eligible for
class exemptions.
(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 ac-
tivity is not listed in Section 750.31(a), you must file a peti-
tion on an individual basis.
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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 TSCA's 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, air condi-
tioners, 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.
(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 spe-
cific 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 al-
ready been authorized by EPA (beside each is the Rule section to
refer to for details):
o servicing PCB Transformers and PCB-Contaminated
Transformers (Sec. 761.3l(a));
o use in and servicing of Railroad Transformers (Sec.
761.31(b));
o use in and servicing of Mining Equipment (Sec.
761.31(c));
o use in Heat Transfer Systems (Sec. 761.31(d));
o use in Hydraulic Systems (Sec. 761.31(e));
o use in Carbonless Copy Paper (Sec. 761.31(f));
o Pigments (Sec. 761.31(g));
o servicing Electromagnets (Sec. 761.31(h));
o use in Natural Gas Pipeline Compressors (Sec.
761.31(1));
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o Small Quantities for Research & Development
Sec. 761.3K j) );
o 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 avail-
ability and characteristics of substitutes; and the economic sig-
nificance of the activity, including its importance to the nation-
al economy, small business, technological innovation, the envi-
ronment, 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-contaminated 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 only 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.
(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 will 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.
(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, Dis-
tribution in Commerce and Use Ban Regulation: Economic Impact
Analysis", also commonly referred to as the "Versar Report". For
a copy of this document call the Industry Assistance Office (see
the "Contacts for Information" section of this Booklet).
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IMPORT/EXPORT
(22) CAN PCBs (THE CHEMICAL ITSELF) BE IMPORTED OR EXPORTED
AFTER THE BAN RULE'S JULY 2, 1979 EFFECTIVE DATE? WHAT
ABOUT PCB EQUIPMENT (TELEVISION SETS, MICROWAVE OVENS,
ETC.) WHICH CAN CONTINUE TO BE DOMESTICALLY PRODUCED UNTIL
JULY 1, 1979, HOW LONG CAN THEY CONTINUE TO BE IMPORTED AND
EXPORTED?
Because TSCA considers the term "import" to be synonomous
with "manufacture", no PCBs (except waste) can be imported or
exported after July 2, 1979, unless an exemption is obtained from
EPA.
Furthermore, it was the intent of Congress to have this Rule
treat domestic and foreign PCB production equally. Therefore,
PCB Equipment can be imported and exported until July 1, 1979.
After July 1, 1979, an exemption must be obtained from EPA in
order to continue this activity.
(23) EPA HAS DECIDED TO ADOPT AN OPEN BORDER POLICY WITH RESPECT
TO THE DISPOSAL OF PCBs. WHAT DOES THAT MEAN?
The PCB Ban Rule allows for PCB wastes to be either imported
or exported for disposal for one year — until May 1, 1980. All
imported PCB wastes must be disposed of in accordance with Sub-
part B of the Final Rule. Persons exporting PCB wastes for dis-
posal are to notify EPA at least 30 days before the first export
shipment; quarterly reports of actual shipments are also required.
EPA believes that the adoption of this open border policy
for PCB waste disposal will be advantageous to both the U.S. and
foreign countries, especially Canada. Generators of PCB wastes
will be able to select the PCB disposal site that offers the most
reasonable transportation and disposal costs. The open border
policy will be in effect for almost one year, at which time EPA
will examine the progress made by other nations in establishing
and operating safe PCB disposal sites. The Agency will also at
this time determine if extension of the open border policy is
appropriate.
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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 PCBs into the
environment.
(25) IN ORDER TO GET THE FULL USEFUL LIFE OUT OF LIQUID FILLED
TRANSFORMERS, THEY MUST BE SERVICED OR REPAIRED PERIOD-
ICALLY. ARE THESE ACTIVITIES PERMITTED UNDER THE RULE?
ARE THERE ANY RESTRICTIONS?
Servicing of these transformers is authorized until July 1,
1984. EPA will consider the necessity of extending the author-
ized period prior to the 1984 termination date. Special re-
strictions are related to the extent of the repairs or servic-
ing activities, 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 containing PCBs at a concentration of
500 ppm or greater;
(2) PCB-Contaminated Transformers containing between 50 ppm
and 500 ppm PCB;
(3) Non-PCB Transformers containing less than 50 ppm PCB;
(4) Railroad Transformers used in electric railroad
locomotives and self-powered cars that contain PCB
fluid.
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, address Railroad Transformer
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requirements 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 must be assumed
to be a PCB Transformer.
If a transformer is tested and found to contain less than
500 ppm PCB, it will then fall into one of the other appropriate
categories.
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 TRANSFORMER IS A
PCB-CONTAMINATED TRANSFORMER? IF I GO TO THE EXTRA TROUBLE
AND EXPENSE TO TEST MY TRANSFORMER IN ORDER TO CLASSIFY IT
AS A NON-PCB TRANSFORMER, WHY WON'T MY REQUIREMENTS UNDER
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 unnec-
essary.
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
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receive an exemption from EPA. If they sold only uncontaminated
mineral oil (less than 50 ppm PCBs), then an 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 transformers, 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.
If the PCB concentration was successfully reduced below 50
ppm, then the transformer can be reclassified to a Non-PCB
Transformer.
(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
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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 PCB 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 this servicing
to be an unreasonable risk. EPA believes the cost of this pro-
hibition (about $14 million the first year and steadily less each
year after) is justified by the increased risks which would other-
wise occur to human health and the environment.
(32) CAN I REBUILD MY TRANSFORMERS?
Rebuilding a transformer would 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, Non-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 PCB is relatively low and the
economic impact of not permitting this activity would be very
high.
(33) CAN I SERVICE MY OWN TRANSFORMERS?
EPA has decided to authorize this activity, which is con-
sidered use, for persons who service their own transformers until
July 1, 1984.
(34) CAN I HAVE A SERVICE SHOP WORK ON MY TRANSFORMER?
Yes, you can have work done on your transformer 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 after July
1, 1979.
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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
dispose of it 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.
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(40) CAN USABLE TRANSFORMERS BE SOLD BY PRESENT OWNERS?
Yes, provided the seller had originally obtained the
transformer for use and not resale and the buyer does not
purchase the usable PCB transformers for resale, but rather uses
them himself.
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
these heavy service units are subjected to. 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 exceeds 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
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able to use a Railroad Transformer containing greater than 1,000
ppm PCB after July lf 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.
(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 new 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 only 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.
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(49) CAN I REBUILD MY RAILROAD TRANSFORMER?
Before January 1, 1982 you can rebuild your Railroad
Transformer with PCB dielectric fluid. After January 1, 1982,
any rebuilt Railroad Transformers must not contain dielectric
fluid with a PCB concentration greater than 50 ppm.
(50)
CAPACITORS
HOW DO THESE RULES AFFECT CAPACITORS?
USE MY PCB CAPACITORS?
CAN I CONTINUE TO
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 January 1, 1980 all
large PCB capacitors will have to be incinerated in special EPA
approved incinerators.
Special disposal is not required for small capacitors
except those waste capacitors owned by PCB capacitor or PCB
equipment producers.
(52) WHAT IS THE DIFFERENCE BETWEEN LARGE AND SMALL CAPACITORS?
Small capacitors have less than 3 pounds of contained
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.
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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 EPAf 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 in 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 lr
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. PCB motors
in continuous miner-type equipment may be rebuilt until December
31, 1979. PCB motors in loader-type equipment must be rebuilt as
air-cooled or other non-PCB containing motors whenever they are
returned to a service shop for servicing. After January 1, 1982
PCBs may not be added to mining equipment.
(58) CAN I REBUILD THESE MACHINES?
Yes you can. In fact, when you have the loader serviced the
motor must be rebuilt as a non-PCB motor. Rebuilding of the PCB
motors in continuous miners is permitted only until December 31,
1979.
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(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.
(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.
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(64) 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 a drain and refill approach. Systems with low
level contamination or borderline levels may be effectively con-
trolled by simply topping-off with non-PCB fluid.
(65) ARE THERE ANY RESTRICTIONS ON THE FLUIDS THAT CAN BE ADDED
TO THESE SYSTEMS?
No fluids containing more than 50 ppm PCBs can be added.
This means 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 with 50 ppm PCB or less if they are to be used in
the manufacture or production of foods, drugs, and cosmetics.
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.
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(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,
(70) IN THE EARLY 1970's CARBONLESS COPY PAPER WAS MADE WITH INK
CONTAINING PCBs. WHAT PROVISIONS DOES THE PCB BAN RULE
MAKE FOR THIS PAPER?
Although carbonless copy paper is no longer made with PCBs,
supplies of this paperstock still exists; most are in files.
Because the amount- of PCB on each sheet is extremely small and no
inexpensive method of separating PCB from non-PCB carbonless pa-
per 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?
EPA's PCB Ban Rule authorizes the use of diarylide and
pthalocyanine pigments, containing PCBs as an impurity in con-
centrations ranging from several thousand parts per million to
50 ppm, until January 1, 1982. However, after July 2, 1979,
these pigments, containing greater than 50 ppm PCB, cannot 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
any other chemicals containing PCBs. Several manufacturers have
requested 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 MANUFACTURERS 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 in the Federal
Register on November 1, 1978. (See the "Contacts for Infor-
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mation" Section of this Booklet to find out how to obtain a copy
of this Federal Register Notice.)
(74) CAN ELECTROMAGNETS CONTAINING PCBs STILL BE 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 elecromagnets may continue
to be used and serviced.
Persons may service their own PCB electromagnets. 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.
(75) CAN PCBs CONTINUE TO BE USED IN NATURAL GAS PIPELINE
COMPRESSORS?
Yes, until May 1, 1980. In general, these systems were
drained of high concentration PCB fluid several years ago, thus
removing most of the PCBs. EPA has authorized these compressors
to be used until May 1, 1980 — so that they can be drained and
refilled with non-PCB fluid to further reduce the PCB
concentration until it is below 50 ppm.
LABELING
(76) 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. To provide sufficient time
to identify and mark these additional items containing between 50
and 500 ppm PCB, the final May 1979 Rule allows until October 1,
1979 for labeling requirements to be met.
(77) DO ALL TRANSFORMERS CONTAINING PCBs HAVE TO BE LABELED?
PCB Transformers, containing 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
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extremely high (approximately $10 for each of the 35 million
transformers).
An unmarked 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.
(79) 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.
(80) 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.
(81) 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 ppm PCBs manufactured after July 2,
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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.
(82) 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.
(83) 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-
lities, Identification, Products Division, 727 W. Glendale Ave.f
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
(84) 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.)
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(85) 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.
(86) ARE THERE EPA APPROVED LABS TO ANALYZED SAMPLES OF PCBs?
No, EPA does not have a program for recommending or
approving analytical laboratories.
STORAGE
(87) WHAT KINDS OF CONTAINERS ARE APPROPRIATE FOR STORAGE?
The May 31, 1979 Final Rule permits 5 container types (5,
5B, 6D, 17C and 17E) which comply with Department of Trans-
portation (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.
(88) 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, 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.
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.
Material belongs to:
Office of Toxic Substances Library ""•
U.S. EnvTonrr.r'ntal Protection Agency
401MStfi?.t,S.W.TS-793
-25- Wasbinccn, D.C. 20460
(202) 382-3944
-------
(89) 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.
(90) 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.
(91) 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.
(92) 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.
(93) WHEN PCB CAPACITORS OR CONTAINERS ARE STORED IN AN
APPROPRIATE STORAGE AREA, WHAT HAPPENS WHEN ONE OF THESE
ITEMS STARTS 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. :f:>i";i »;:hj{;;?4
f\ :... \»
.**! ..... . (M.-I.JW
f^c-^€(i:v>^ -26-
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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.
(94) 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.
(95) 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
(96) 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, however, 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
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minor leaks, such as bushing leaks, are involved. Any spilling
or leaking should be stopped and repaired as soon as possible.
(97) 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).
(98) 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.
(99) IF I HAVE A SPILL, WHAT SHOULD I DO TO CONTROL OR CLEAN UP
THE SPILL?
The first priority is to control the spread of the spill by
damming or diking the leak. Also, any threats to 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.
Large 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. Commerical firms are also available on a
contract basis to clean up spills. Government spill experts can
provide information on such firms.
RECORDKEEPING
(100) MUST COMPANIES KEEP RECORDS OF THE DISPOSITON 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
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disposition. Specifically, 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.
(101) DO PCB INCINERATOR FACILTIES 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.
(102) 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.
(103) 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 personnel. Do not send
the records or reports to EPA unless it is specifically requested
by the Agency.
(104) 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 identify of that single facility must be available at each
location. The record location must be manned at least 8 hours a
day.
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DISPOSAL
(105) 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 EPAf 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.
(106) HOW DO I DISPOSE OF LARGE PCB CAPACITORS?
Until January 1, 1980, large PCB capacitors can be disposed
of in EPA approved chemical waste landfills or high temperature
incinerators. After January 1, 1980, they must be disposed of by
high temperature incinerators. It is expected that hammermill-
type crushers will be used at the incinerators to improve the de-
struction efficiency. These large capacitors account for approx-
imately one-third of the PCBs currently in service.
(107) WHERE CAN PCB ARTICLES (OTHER THAN PCB TRANSFORMERS AND
CAPACITORS) BE DISPOSED?
PCB articles can be disposed of in a chemical 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.
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.
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(108) 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
would result in the waste capacitors going to chemical waste
landfills or high temperature incinerators.
(109) 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.
(110) HOW CAN I DISPOSE OF THE DIELECTRIC FLUID IN MY
TRANSFORMER?
Fluids from PCB Transformers (concentrations of 500 ppm
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.
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(Ill) WHERE CAN OTHER LIQUID WASTES WITH OVER 500 PPM PCB 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 #110).
(112) 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.
(113) 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.
(114) CAN DECONTAMINATED PCB CONTAINERS BE REUSED?
Containers decontaminated in accordance with Annex IV can be
reused for general use.
(115) HOW CAN PCB CONTAINERS USED ONLY TO HOLD LOW PCB CONCEN-
TRATIONS 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.
(116) WHAT ARE THE REQUIREMENTS 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 Re-
gional Administrator, which must meet the requirements estabished
in Annex II of the Final Rule.
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(117) HAVE ANY DISPOSAL SITES BEEN APPROVED FOR PCBs? WHERE ARE
THEY?
Yes, eight chemical waste landfill sites have been ap-
proved. No incinerator sites have yet been approved, but three
sites are currently being considered.
The landfill locations are as follows:
1. Facility; General Electric Co., Silicone Products
Division.Facility Address:260 Hudson River Rd.f Waterford,
New York 12189. Facility Telephone Number (518) 237-3330. Type
of Facility Approved: Incinerator. Type of PCB Waste Handled:
Approval allows G.E. to incinerate only those PCB wastes which
are generated on site, i.e., G. E. can not accept PCBs for
incineration from any other company or any other G.E. facility.
Expiration Date of Approval: September 1, 1981. EPA Regional
Office Contact: Wayne Pierre. EPA Telephone Number: (212) 264-
0505.
2. Facility; Newco Chemical Waste Systems, Inc. Facility
Address: 4526 Royal Avenue, Niagara Falls, New York 14330.
Facility Telephone Number: (716) 285-6944. 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).
Expirationd Date of Approval: August 18, 1981. EPA Regional
Office Contact: Wayne Pierre. EPA Telephone Number: (212) 264-
0505.
3. 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.
4. Facility; Waste Management of Alabama, Inc. Facility
Address: P.O. Box 1200 Livingston, Alabama 35470. Facility
Telephone Number: (205) 652-9529. 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). Expiration
Date of Approval: Open-ended. EPA Regional Office Contact:
Mr. James Scarbrough. EPA Telephone Number (404) 881-3016.
5. Facility; Casmalia Disposal. Facility Address: 539 Ysidro
Rd., P.O. Box 5275, Santa Barbara, California 93108-main office
(site located near Casmalia in Santa Barbara County). Facility
Telephone Number: (805) 969-4703. Type of Facility Approved:
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Chemical Waste Landfill. Type of PCB Waste Handled: Capacitors
(small and large): Properly drained transformers; Contaminated
soil, dirt, rags and other debris; Dredge spoils; Muncipal
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. Facility
Address: 9200 Shelbyville Rd., Suite 526f P.O. Box 7246, Louis-
ville, Kentucky 40207, main office (site located near Beatty,
Nev. 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 PCB Waste Handled: Capacitors (small and large): Properly
drained transformers; Contaminated soil, dirt, rags, asphalt, and
other debris; and Properly drained containers (drums). Expira-
ation Date of Approval: January 1, 1980. EPA Regional Office
Contact: Mr. Roger Fuentes. EPA Telephone Number: (206) 442-
1260.
8. Facility; Wes-Con., Inc. Facility Address: P. O. Box
564. Twin Falls, Idaho 83301. main office (Site located in
Grand View, Idaho). Facility Telephone Number: (208) 734-
7711. 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). Expiration Date of Approval: January 1, 1980. EPA
Regional Office Contact: Mr. Rogers Fuentes. EPA Telephone
Number: (206) 442-1260.
(118) 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
PCB label it can be used to transport PCBs to a disposal site.
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(119) CAN PCBs OR PCB ITEMS BE EXPORTED FOR DISPOSAL? BE
IMPORTED FOR DISPOSAL?
Yes, refer to Question #23 in the "Import/Export" section of
this Booklet.
PCBs IN THE WORKPLACE
(120) ARE THERE ANY OSHA RULES GOVERNING PCBs IN THE WORKPLACE?
Nof not at the present time; however, in 1977 the National
Institute of Occupational Safety and Health (NIOSH) — the HEW
organization responsible for researching 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.
(121) 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.
NIOSH 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 microgram
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.
(122) 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.
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(123) HOW DO OSHA STANDARDS AND NIOSH RECOMMENDATIONS RELATE TO
EPA's PCB REGULATION?
EPA'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 ma-
chine 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.
(124) 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.
Respiratory exposure control (whether individual protection
or workplace control) is most relevant for long-term production
operations or major spills. PCB Transformer spills pose respir-
atory 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.
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 re-
ducing contamination of worker clothing. Non-porous protective
gear can usually be decontaminated with solvents. Work clothing
can usually be laundered and reused, unless the garment is heavily
contaminated. It is wise to launder work clothes separately from
other garments.
Eye protection should be worn when it is possible for PCBs
to be splashed in the eyes. Removing contaminated soil does not
usually pose such a threat.
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(125) 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
(126) 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, D.C. area can reach this Office by
calling 554-1404.
(127) HOW DO I GET A COPY OF THE RULE? SUPPORT 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 126, 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, D.C. 20460
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