E PA/910-S-95-001 Alaska
United States Region 10 Idaho
Environmental Protection 12(50 Sixth Avenue Oregon
Agency Seattle WA 98101 Washington
Air & Toxics Division Pesticides & Toxic Substances Branch August 1995
SEFft Summary of
General PCB Regulations
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SUMMARY OF GENERAL
PCB REGULATIONS*
EPA REGION 10
TOXIC SUBSTANCES SECTION
(206) 553-1270
AUGUST 1995
~NOTE: This is intended to be only a general guidance to the PCB Regulations and is not an
official or legal substitute for the PCB Regulations. If questions arise about specific issues, the
requirement should be verified by reference to 40 C.F.R. Part 761.
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CONTENTS
SECTION TITLE PAGE
NUMBER
1. Assumption Requirements 5
2. Marking 8
3. Quarterly Inspections 10
4. Annual Document Logs, Documents, and Records 11
5. Disposal 14
6. Uncontrolled Rule: Burning/Use of Used Oil 16
Containing 2 to less than 50 ppm PCB
7. Storage for Disposal 21
8. Spill Prevention 23
9. PCB Spill Cleanup Policy 25
10. Food and Feed Restrictions 30
11. PCB Transformer Fire Regulations 32
12. Substitute Dielectric Fluid 39
13. Container Specifications 40
14. Notification and Manifesting Rule 42
15. Physical Separation 49
16. Reclassification of Transformers 50
17. PCB Fluorescent Light Ballast Disposal 51
18. PCBs in Laboratories 53
19. General PCB Information 56
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1. ASSUMPTION REQUIREMENTS
ASSUMPTION REQUIREMENTS FOR LIQUID-FILLED ELECTRICAL EQUIPMENT
(IN LIEU OF CHEMICAL ANALYSIS)
EPA REGION 10
SEATTLE, WASHINGTON
TRANSFORMERS
1. If a transformer does not have a nameplate or if there is no information available
to indicate the type of dielectric fluid in it, the transformer must be assumed to
be a PCB Transformer (i.e., containing 500 ppm PCB or greater) unless it is
tested and found to contain less than 500 ppm PCB.
All assumed-to-be PCB Transformers must meet all of the regulatory
requirements for PCB Transformers, including, but not limited to, inclusion on
Annual Reports, Quarterly Inspections, disposal, marking, and response to spills
and leaks.
[Reference: Federal Register, Vol. 44, No. 106, May 31, 1979, page 31517, column
one].
2. All untested (by chemical analysis) mineral oil dielectric fluid transformers must
be assumed to be PCB-contaminated transformers, unless reasons exist to believe
that a transformer was filled with greater than 500 ppm PCB fluid (in which case
the assumption is that the transformer is a PCB Transformer).
All assumed-to-be PCB-contaminated transformers must meet all of the
regulatory requirements for PCB-contaminated transformers, including, but not
limited to, inclusion on Annual Reports (for PCB Items removed from
service/placed into storage for disposal/placed into transport for disposal/
disposed of), disposal, and response to spills and leaks.
[Reference: Federal Register, Vol. 44, No. 106, May 31, 1979, page 31517, column
3. Also refer to 40 C.F.R. § 761.3, definition of "PCB-Contaminated Electrical
Equipment"]
PAGE 5 - SUMMARY OF PCB REGULATIONS
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CAPACITORS
The disposal of any capacitor shall comply with all requirements of
40 C.F.R. § 761.60 unless it is known from label or nameplate information,
manufacturer's literature (including documented communications with the
manufacturer), or chemical analysis that the capacitor does not contain PCBs.
[Reference: 40 C.F.R. § 761.60(b)(2).]
Generally, any capacitor that cannot be shown to be PCB-free by examining label or
nameplate information must be assumed to be a PCB Capacitor and must be marked
with the PCB mark (i.e., the required label). The exception to this is for those
relatively few oil-filled capacitors: these are assumed to be PCB-contaminated
electrical equipment absent chemical analysis and need not be labeled.
[Reference: Federal Register, Vol. 44, No. 106, May 31, 1979, page 31522, column one.]
OTHER ELECTRICAL EQUIPMENT
If the actual PCB concentration of any oil-filled transformer, voltage regulator, switch,
or electromagnet is unknown, the equipment must be assumed to contain more than
50 ppm PCBs and may be assumed to contain less than 500 ppm PCBs for purposes of
servicing and disposing of this equipment.
EPA allows that oil-filled circuit breakers, reclosers, and cable need not be classified as
PCB-contaminated electrical equipment and may be assumed to contain less than
50 ppm PCB if the PCB concentration is unknown.
[References: Federal Register, Vol. 47, No. 165, August 25, 1982, page 37353; 40
C.F.R. § 761.3, definition of "PCB-contaminated electrical equipment"].
I SEP OIL
Used oil to be burned for energy recovery is presumed to contain quantifiable levels
(2 ppm or greater) of PCB unless the marketer obtains analysis (testing) or other
information that the used oil fuel does not contain quantifiable levels of PCBs.
[Reference: 40 C.F.R. § 761.20(e)(2)].
PAGE 6 - SUMMARY OF PCB REGULATIONS
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I SE OF TEST KITS FOR CHLORINE CONTENT
EPA presently finds gas chromatography to be the minimum standard for determining
the concentration and nature of PCBs in most samples. There is no prohibition against the use
of test kits utilizing total chlorine analysis as rough field screening devices to determine if
further testing is required. However, analytical errors resulting from such testing could expose
a company to liability should the Agency obtain evidence of a violation of the PCB rule.
Testing, to determine disposal requirements, including response to leaks, spills, and other
uncontrolled discharges of PCBs, should be by gas chromatography.
In a PCB spill situation, EPA Region 10 is willing to allow the initial cleanup approach
to be based on a field test kit result (or preferably two tests for better reliability) if:
1) the date and result of testing is documented in the owner's spill records,
2) a gas chromatography follow-up analysis is obtained by the owner in the shortest
reasonable time, and
3) the owner promptly performs any additional cleanup required by the EPA PCB
Spill Cleanup Policy if the gas chromatography result indicates a more serious
spill category than did the test kit.
(However, enforcement action could result if, in EPA's judgment, the owner failed to
adequately satisfy any of these three conditions.)
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2. MARKING
The regulatory designation for the standard PCB label or mark is "\1L."
Must be 6" X 6" unless PCB Article or PCB Equipment too small to
accommodate - then may be reduced proportionately down to 2" X 2".
Where mark ML is specified by the regulations, but the PCB Article or PCB
Equipment is too small to accommodate the smallest permissible size of mark \l
mark Ms may be used instead of mark ML. Ms is 1" X 2". If the PCB Article or
PCB Equipment is too small to accommodate this size, the mark may be reduced
in size proportionately down to a minimum of 1 by 2 cm (0.4" X 0.8"). See
regulations at 40 C.F.R. § 761.45 for pictures of PCB labels.
The following must be marked with ML:
PCB Containers
PCB Article Containers containing items required to be marked with the
PCB label.
PCB Transformers (including assumed-to-be PCB Transformers)
PCB Storage for Disposal Areas
PCB Large High Voltage Capacitors [If 1 or more Large High Voltage
Capacitors are installed in a protected location - power pole, fence, or
structure - the pole/fence/structure can be marked in lieu of marking the
equipment - HOWEVER, a record of individual PCB Capacitors must be
kept.]
PCB Large Low Voltage Capacitors (at time of removal from use)
Transport Vehicles (all 4 sides) IF loaded with:
PCB Containers containing greater than 45 kg PCBs (liquid)
One or More PCB Transformers
PCB Transformer access areas (see PCB Transformer Fire Regulations
section)
PAGE 8 - SUMMARY OF PCB REGULATIONS
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Equipment containing a PCB Transformer or PCB Large High Voltage
Capacitor
PCB Equipment containing a PCB Small Capacitor.
NOTE: Oil-filled PCB Capacitors containing less than 500 parts per million
PCB are not required to be marked.
PAGE 9 - SUMMARY OF PCB REGULATIONS
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3. QUARTERLY INSPECTIONS
Required for ai[ PCB Transformers in use or stored for reuse. Both complete
visual inspections and maintenance of records of the inspections are required
Not required for PCB-contaminated transformers or PCB Capacitors.
Records required to be maintained:
Location of PCB Transformer
Date of Each V isual Inspection
Person Inspecting
Date Any Leak* Discovered
Location of Leak
Estimate of Amount Leaked
Date of Cleanup, Containment, Repair, or Replacement**
Description of Cleanup, Containment, or Repair Performed
* 40 C.F.R. § 761.3 (Definitions) defines a "leak" or "leaking" as any
instance in which a PCB Article, PCB Container, or PCB Equipment
has any PCBs on any portion of its external surface.
** If a leaking transformer cannot be permanently repaired, PCB
Transformer must be replaced, (refer 40 C.F.R.
§ 761.30(a)(l)(ix), (xii), (xiii), and (xiv).
Reduced Inspection Frequency (once a
containment exists (with at least 100%
Reduced Inspection Frequency (once a
than 60,000 parts per million PCB.
year) if undrained, secondary, impervious.
dielectric fluid capacity).
year) if PCB Transformer contains less
PAGE 10 - SUMMARY OF PCB REGULATIONS
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4. ANNUAL DOCUMENT LOGS,
ANNUAL DOCUMENTS, AND
ANNUAL RECORDS
RECORDKEEPING
Beginning February 5, 1990, each owner or operator of a facility, other than a commercial
storer or a disposer of PCB waste, using or storing at any one time:
1. At least 45 kilograms (99.4 pounds) of PCBs contained in PCB Container(s), or
2. One or more PCB Transformers, or
3. 50 or more PCB Large High or Low Voltage Capacitors,
shall develop and maintain at the facility, or a central facility provided they are maintained at
that facility, all annual records and the written annual document log"' of the disposition of
PCBs and PCB Items.
Annual Records shall include:
1. All signed manifests generated by the facility during the calendar year;
2. All Certificates of Disposal that have been received by the facility during
the calendar year.
The written annual document log shall include the following:
i. The name, address, and EPA identification number of the facility
covered by the annual document log and the calendar year covered by
the annual document log.
ii. The unique manifest number of every manifest generated by the
facility during the calendar year, and from each manifest and for
unmanjfested waste that may be stored at the facility, the following
information:
(A) For bulk PCB waste (e.g., in a tanker or truck), its weight in
kilograms, the first date it was removed from service for
disposal, the date it was placed into transport for off-site storage
or disposal, and the date of disposal, if known.
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v'i- F°r any PCBs or PCB Item received from or shipped to another
facility owned or operated by the same generator, the information
required under paragraph § 761.180(a)(2)(ii)(A) through (a)(2)(ii)(D).
viii. A record of each telephone call, or other means of verification agreed
upon by both parties, made to each designated commercial storer or
designated disposer to confirm receipt of PCB waste transported bv
an independent transporter, as required by § 761.208.
NOTE: Commercial storage and disposal facilities are required to prepare and maintain PCB
Annual Reports and PCB Annual Document Logs. They are required to submit PCB
Annual Reports for each calendar year by July 15 for the previous calendar year. The
requirements for the PCB Annual Reports and PCB Annual Documents for commercial
storage and disposal facilities are outlined at 40 C.F.R. § 761.180(b).
* Prior to 1990, the PCB Annual Document Log was called the PCB Annual Document in
40 C.F.R. § 761.180(a). The format is somewhat different than that required for the
PCB Annual Document Logs for 1990 and subsequent years because the regulations
changed. Sample formats for the PCB Annual Document Log (for 1990 and
subsequent years) and for the PCB Annual Document (for 1989 and prior years) are
available from EPA Region 10 at (206) 553-1270, These sample formats are also
available on disk in Wordperfect 5.1.
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5. DISPOSAL
NOTE: A current list of EPA-permitted disposal facilities is available from EPA
Region 10 Toxic Substances Section, phone (206) 553-1270.
Mineral Oil Dielectric Fluid (50-499 ppm PCB)
incinerator, or
chemical waste landfill, or
high efficiency boiler (stringent conditions listed in regulations - prior
notification to EPA required)
approved alternate method
Liquids (Non-Mineral Oil) (50-499 ppm PCB)
incinerator, or
chemical waste landfill, or
high efficiency boiler (permit required)
approved alternate method
Non-Liquid PCBs (Contaminated Soil, Rags, Other Debris)
incinerator, or
chemical waste landfill
approved alternate method
(NOTE: LIQUIDS CANNOT BE SOLIDIFIED TO CIRCUMVENT
DISPOSAL REQUIREMENTS].
PCB TRANSFORMERS (Transformers containing PCB concentrations of 500
ppm or greater) are required to be disposed of in one of three ways:
1) The transformer and the dielectric fluid can be burned together in a
high temperature incinerator approved by EPA, or
2) the liquid can be thoroughly drained out of the transformer and be
disposed of by incineration, while the transformer may be disposed of
in an EPA-approved chemical waste landfill provided that the
transformer is first flushed with solvent for 18 hours and then is
reseated prior to disposal.
3) approved alternate method
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PCB-CONTAMINATED ELECTRICAL EQUIPMENT
drain free-flowing liquid:
liquid to incinerator or chemical waste landfill;
drained PCB-contaminated electrical equipment disposal not
regulated [MUST BE DRAINED - SEE DEFINITION OF
UNCONTROLLED DISCHARGES, LEAKS, AND SPILLS
UNDER 40 C.F.R. 761.60(d)]. Also, drained PCB-contaminated
electrical equipment cannot be exported)
PCB ELECTROMAGNETS (Electromagnets containing PCB concentrations in
excess of 500 ppm) are required to be disposed of in one of two ways:
1) The electromagnet and fluid can be burned together in a high
temperature incinerator approved by EPA, or
2) the liquid can be thoroughly drained from the electromagnet and
disposed of in an incinerator and the drained electromagnet can be
disposed of in an EPA-approved chemical waste landfill.
PCB LARGE CAPACITORS are required to be disposed of by high temperature
incineration (unless specific alternate methods are approved by EPA). Some
oil-filled capacitors are classified as PCB-contaminated electrical equipment
However, they are not allowed to be drained and disposed of in a chemical waste
landfill: they must be incinerated.
DILUTION/SOLIDIFICATION
1. No provision specifying a PCB concentration may be avoided as a result of dilution,
unless otherwise provided. Refer 40 C.F.R. § 761.1(b).
2. Except as provided by 40 C.F.R. § 761.75(b)(8)(H) (chemical waste landfills), liquid
PCBs shall not be processed into non-liquid forms to circumvent the high temperature
incineration requirements of 40 C.F.R. § 761.60(a). Refer 40 C.F.R. § 761.60(a)(4).
PAGE 15 - SUMMARY OF PCB REGULATIONS
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6. UNCONTROLLED RULE
Bl'RNING OF USED OIL CONTAINING 2 TO LESS THAN 50 PPM PCB
RESTRICTIONS ON USE
The use of waste oil that contains any detectable concentration of PCB as a sealant, coating, or
dust control agent is prohibited. Prohibited uses include, but are not limited to, road oiling,
general dust control, use as a pesticide or herbicide carrier, and use as a rust preventative on
pipes. Refer 40 C.F.R. § 761.20(d).
RESTRICTIONS ON BURNING
1. Used oil containing any quantifiable levels of PCB may be burned for
energy recovery only in the following combustion facilities:
a. Qualified burners as defined in 40 C.F.R.
§ 761.3.
b. Burners identified in 40 C.F.R. § 266.41(b).
NOTE: These facilities must be operating at normal operating
temperatures (this prohibits feeding these fuels during either start-up or
shutdown operations). Owners and operators of such facilities are
"burners" of used oil fuels.
Before a burner accepts from a marketer the first shipment of used oil fuel
containing detectable levels of PCB (2 ppm), the burner must provide the
marketer a one-time written and signed notice certifying that:
a. The burner has complied with any notification requirements
applicable to "qualified incinerators" (§ 761.3) or to "burners"
regulated under 40 C.F.R. Part 266, Subpart E.
b. The burner will burn the used oil only in a combustion facility
identified in 1(a) and (b) above and identify the class of burner
that qualifies.
PAGE 16 - SUMMARY OF PCB REGULATIONS
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Recordkeeping requirements: The following recordkeeping requirements
are in addition to the recordkeeping requirements for marketers found in
40 C.F.R. §266.43(b)(6)(i) and (ii), and for burners found in 40 C.F.R.
§ 266.44(e).
a. Marketers who first claim that the used oil fuel contains no
detectable PCBs must include among the records required by
40 C.F.R. § 266.43(b)(6)(i), copies of the analysis or other
information documenting his claim, and he must include among
the records required by 40 C.F.R. § 263.43(b)(6)(ii), a copy of
each certification notice received or prepared relating to
transactions involving PCB-containing used oil.
b. Burners must include among the records required by
40 C.F.R. § 266.44(e), a copy of each certification notice
required by § (e)(3)(iii) (Number 2 above) that he sends to a
marketer.
RESTRICTIONS ON MARKETERS AND BURNERS OF USED OIL CONTAINING
QUANTIFIABLE LEVEL OF PCBS LESS THAN 50 PPM PCB
MARKETING RESTRICTIONS
Used oil containing any quantifiable level* of PCBs (2 ppm) may be marketed only to:
1. Qualified incinerators as defined in 40 C.F.R. § 761.3:
a. An incinerator approved under the provisions of
40 C.F.R. § 761.70. Oil at any level of PCB concentration
may be destroyed in an incinerator approved under
§ 761.70.
b. A high efficiency boiler which complies with the criteria of
40 C.F.R. § 761.60(a)(2)(iii)(A), and for which the operator
has given written notice to the appropriate EPA Regional
Administrator in accordance with the notification
requirements for the burning of mineral oil dielectric fluid
under 40 C.F.R. § 761.60(a)(2)(iii)(B).
c. An incinerator approved under section 3005(c) of the
Resource Conservation and Recovery Act (42 U.S.C.
§ 6925(c)) [RCRA].
PAGE 17 - SUMMARY OF PCB REGULATIONS
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d. Industrial furnaces and boilers which are identified in
40 C.F.R. § 260.10 and 40 C.F.R. § 266.41(b) when
operating at their normal operating temperatures (this
prohibits feeding fluids, above the level of detection, during
either start-up or shutdown operations).
2. Other marketers identified in 40 C.F.R. § 260.41(aM 1). [Burners or
other marketers who have notified EPA of their used oil management
activities stating the location and general description of such activities,
and who have an EPA identification number.]
3. Burners identified in 40 C.F.R. § 266.41(b):
a. Industrial furnaces identified in § 260.10.
"Industrial furnace" means any of the following enclosed
devices that are integral components of manufacturing
processes and that use controlled flame devices to
accomplish recovery of materials or energy:
(1) Cement kilns.
(2) Lime kilns.
(3) Aggregate kilns.
(4) Phosphate kilns.
(5) Coke ovens.
(6) Blast furnaces.
(7) Smelting, melting, and refining furnaces
(including pyrometallurgical devices such as
cupolas, reverberator furnaces, sintering
machines, roasters, and foundry furnaces).
(8) Titanium dioxide chloride process oxidation
reactors.
(9) Methane reforming furnaces.
(10) Pulping liquor recovery furnaces.
(11) Combustion devices used in the recovery of
sulfur values from spent sulfuric acid.
(12) Such other devices as the EPA Administrator
may, after notice and comment, add to this
list.
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b. Boilers, as defined in § 260.10, thai are identified as
follows:
i. Industrial boilers located on the site of a
facility engaged in a manufacturing process
where substances are transformed into new
products, including the component parts of
products, by mechanical or chemical
processes.
ii. Utility boilers used to produce electric power,
steam, or heated or cooled air or other gases
or fluids for sale.
iii. Used oil-fired space heaters provided that:
A. The heater burns only used oil that the
owner or operator generates or used oil
received from do-it-yourself oil changers
who generate used oil as household
waste.
B. The heater is designed to have a
maximum capacity of not more than
0.5 million Btu per hour; and
C. The combustion gases from the heater
are vented to the ambient air.
* "Quantifiable Level/Level of Detection" means 2 micrograms per gram from any
resolvable gas chromatographic peak, i.e., 2 ppm.
NOTE: Only burners in the automotive industry may burn used oil generated from
automotive sources in used oil-fired space heaters provided the provisions of 40 C.F.R.
§ 266.41(b)(2)(iii)(A), (B) and (C) are met. The Regional Administrator may grant a
variance for a boiler that does not meet the 40 C.F.R. § 266.41(b) criteria.
TESTING OF USED OIL FUEL/ASSUMPTION REQUIREMENT
Used oil to be burned for energy recovery is presumed to contain quantifiable levels
(2 ppm) of PCB unless the marketer obtains analyses (testing) or other information
that the used oil fuel does not contain quantifiable levels of PCBs.
1. The person who first claims that a used oil fuel does not contain
quantifiable level (2 ppm) PCB must obtain analyses or other information to
support that claim.
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2. Testing to determine the PCB concentration in used oil may be conducted
on individual samples, or in accordance with the testing procedures
described in § 761.60(g)(2) (batch testing). However, if any PCBs at a
concentration of 50 ppm or greater have been added to the container or
equipment, then the total container contents must be considered as having a
PCB concentration of 50 ppm or greater for purposes of complying with the
disposal requirements.
3. Other information documenting that the used oil fuel does not contain
quantifiable levels (2 ppm) of PCBs may consist of either personal, special
knowledge of the source and composition of the used oil, or a certification
from the person generating the used oil claiming that the oil contains no
detectable PCBs.
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7. STORAGE FOR DISPOSAL
STORAGE FOR DISPOSAL ISFD)
PCB Articles/Containers are required to be disposed of within One Year of date
placed into storage for disposal (SFD).
SFD FACILITY REQUIREMENTS*
Adequate roof/walls to prevent rainwater from reaching stored
PCBs/PCB Items.
Adequate floor, continuous curbing minimum 6" HIGH
Containment must be greater of:
2 times internal volume of largest PCB
Article/Container
25% total internal volume of all PCB
Articles/Containers.
Mo drain valves, floor drains, expansion joints, sewer lines, other
openings that would permit liquids to flow from area.
Floors/Curbing constructed of smooth and impervious materials.
Not located below the 100-year flood water elevation.
* Generators must notify EPA on Form 7710-53 if they store PCBs in
an area subject to the 40 C.F.R. § 761.65(b) and (c)(7) SFD
requirements. See Notification, Chapter IS.
TEMPORARY STORAGE FOR DISPOSAL
Permitted only if PCBs/PCB Items marked with date removed from service.
Permitted only for 30 days from date removed from service by generator.
ALLOWABLE
Non-leaking PCB Articles/Equipment
Leaking PCB Articles/Equipment IF placed in non-leaking PCB Container
containing sorbent material
PCB Containers containing non-liquid PCBs such as contaminated soil,
rags, and debris
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PCB Containers containing liquid PCBs (50 to less than 500 ppm) -
must prepare SPCC Plan
container must bear notation that liquids do not exceed 500 ppm
PCB.
[Liquids cannot be diluted to circumvent disposal requirements.]
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8. SPILL PREVENTION
REPORTING OF SPILLS
There are several Federal laws which have PCB spill reporting requirements. The most
stringent of these is section 103(a) of CERCLA (Comprehensive Environmental Response.
Compensation, and Liability Act - commonly known as SUPERFUND). CERCLA requires that
any person in charge of any vessel or any facility, as soon as he has knowledge of the release of
a reportable quantity of any hazardous substance to the environment (over a 24 hour period),
must immediately notify the NRC at 1-800-424-8802. The Reportable Quantity (RQ) for PCBs
is presently set at 1 pound of PCBs (not just PCB-containing material) by statute under
CERCLA for releases into all environmental media (land, air, water). The Department of
Transportation (DOT) and the Clean Water Act (CWA) also have release reporting
requirements for PCBs.
Additional reporting requirements for spills are outlined in section 9 of this summary, PCB
Spill Cleanup Policy.
SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) PLANS WHEN
REQUIRED FOR LARGE CONTAINERS UNDER TOXIC SUBSTANCES CONTROL ACT
PCB REGULATIONS 40 C.F.R PART 761
REGULATION: 40 C.F.R. § 761.65(c)(7)(H) states that the owners or operators of any facility
using containers described in 40 C.F.R. § 761.65(c)(7)(i) -- larger than the
Department of Transportation specifications listed in 40 C.F.R.
§ 761.65(c)(6) - shall prepare and implement a Spill Prevention Control
and Countermeasure (SPCC) Plan as described in 40 C.F.R. Part 112. In
complying with 40 C.F.R. Part 112, the owner or operator shall read
"oil(s)" as "PCB(s)" whenever it appears. The exemptions for storage
capacity,
40 C.F.R. § 112.1(d)(2), and the amendment of SPCC Plans by the Regional
Administrator, 40 C.F.R. § 112.4, shall not apply unless some fraction of the
liquids stored in the container are oils as defined by Section 311 of the
Clean Water Act.
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W ATER POLLl TION CONTROL ACT (CLEAN WATER ACT) - Section 311:
For the purpose of this section, the term "oil" means oil of any kind or in anv
form, including, but not limited to, petroleum, fuel oil, sludge, oil, refuse, and oil
mixed with wastes other than dredged spoils.
If any fraction of the stored liquids are oils as defined above, the SPCC Plan is required only
if:
1. The underground buried storage capacity of the facility is greater than 42,000
gallons of oil; or
2. i. The storage capacity, unburied, of such stored liquids is greater than 1.320
gallons of oil; or
ii. Any single container has a capacity greater than 660 gallons.
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9. PCB SPILL CLEANUP POLICY
SUMMARY OF PCB SPILL CLEANUP POLICY
The following table summarizes EPA's PCB (polychlorinated biphenyl) Spill Cleanup
Policy as published in the Federal Register on April 2, 1987. It is meant only as a quick
reference, not as a replacement to the policy itself. In all cases, the policy is the formal
authority to be followed.
NOTE: Although old spills are excluded from the automatic use of levels set by the PCB
Spill Cleanup Policy, they are not excluded from the requirement to clean up a
spill under PCB Spill Cleanup Policy. The Policy directs EPA to determine
site-specific cleanup requirements based on the individual characteristics of the
site.
Item/Tvpe of
Requirement
I. SCOPE OF POLICY a.
b.
c.
II. IN GENERAL
A. SPILL
PAGE 25 - SUMMARY OF PCB REGULATIONS
Applies only to spills which occur on or after
May 4, 1987. (For spills which occurred prior
to this date, the EPA Regional Office should be
consulted for advice.)
Excludes: spills into water, sewers, grazing
lands, and vegetable gardens. (EPA Regional
Office will provide site-specific evaluation on
these spills).
Retains EPA flexibility to apply other
standards based upon presence of factors that
significantly alter riskycost balance (specifies
certain scenarios).
Applies to all spills involving 50 ppm PCB or greater.
a. If inadequate visible traces, owner must use statistically
valid sampling to determine boundary of spill
b. owner responsible for area of actual contamination
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B IMMEDIATE Report to EPA Regional Office [EMERGENCY RESPONSE:
1-206-553-11961 within 24 hours after responsible party was
notified or became aware of spill if:
a. spilled material greater than 10 pounds of PCB by weight,
[This is in addition to requirement to report to NRC at
1-800-424-8802.1. or
b. spill directly contaminated surface water, sewers, or
drinking water supplies, or
c. spill directly contaminated grazing lands or vegetable
gardens.
C. DEFINITIONS
a. "High-concentration PCBs' means PCBs that contain 500
ppm or greater PCBs, or those materials which EPA
requires to be assumed to contain 500 ppm or greater
PCBs in the absence of testing.
b. "Low-concentration PCBs" means PCBs that are tested
and found to contain less than 500 ppm PCBs, or those
materials for which EPA requires an assumption of
concentrations between 50 and 500 ppm PCB (i.e., untested
mineral oil dielectric fluid).
D. CLEANUP OF LOW-CONCENTRATION SPILLS: (less than 1 pound of
PCBS by weight - less than 270 gallons of untested mineral oil)
a. solid surfaces double washed/rinsed (as defined in policy ,
except indoor, residential surfaces other than vaults =
10 micrograms per 100 cm2.
b. [Spill area = visible traces plus 1 foot buffer] Soil within
spill area excavated - ground restored to its original
configuration with fill soil containing less than 1 ppm PCB.
c. (a) and (b) above completed within 48 hours after
responsible party was notified or became aware of spill.
d. records kept for five years (see policy for details).
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e. responsible party or designated agent certifies that cleanup
requirements have been met and information in record is
correct. The certification should be kept for five years.
E. CLEANUP OF HIGH-CONCENTRATION SPILLS AND
LOW-CONCENTRATION SPILLS INVOLVING 1 POUND OR MORE OF
PCBS BY WEIGHT (270 gallons or more of untested mineral oil).
Actions to be taken within 24 hours after responsible party was notified or became
aware of spill (except 48 hours for PCB Transformers):
a. Notify EPA Regional Office and/or National Response
Center, as required.
b. Cordon off/restrict area = visible traces + 3 foot buffer
beyond visible traces - place clearly visible signs advising
to avoid area.
c. record/document area of visible contamination - record if
no visible contamination.
d. initiate cleanup of visible fluid on hard surfaces • initiate
removal of visible contamination on soil/other media.
in. STANDARDS [NOTE:
All numerical standards are maximum
threshold values for judging whether cleanup
was adequate, and comparison to these
standards is valid only after completion of all
cleanup procedures specified by the policy.]
A. OUTDOOR ELECTRICAL SUBSTATIONS
a. Verify by post-cleanup sampling.
b. If substation ever converted to other use, spill site cleaned
up to non-restricted access standard.
c. Contaminated solid surface (impervious, nonimpervious):
100 micrograms/100 cm2
d. Soil contaminated by spill:
25 ppm by weight;.or
50 ppm PCB by weight and label or notice visibly
placed.
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B.
OTHER RESTRICTED ACCESS ARF.A
a. Verify by post-cleanup sampling.
b. High-contact solid surfaces = 10 micrograms/100 cm2.
c. Low-contact, indoor, impervious solid surface =
10 micrograms/100 cm2.
d. Low-contact, indoor, nonimpervious
surfaces =
10 micrograms/100 cm2 or
100 micrograms/100 cm2 and encapsulated.
e. Low-contact, outdoor surfaces
(impervious/nonimpervious) =
100 micrograms/100 cm2.
f. Contaminated soil = 25 ppm.
C. NON-RESTRICTED ACCESS AREAS
a. Verify by post-cleanup sampling.
b. Furnishings, toys, other easily replaceable household
items - dispose of per 40 C.F.R. § 761.60 - responsible
party replaces.
c. indoor, solid surfaces/high-contact outdoor solid
surfaces =
10 micrograms/100 cm2.
d. indoor vault areas/low-contact outdoor, impervious
solid surfaces =
10 micrograms/100 cm2.
e. low-contact, outdoor, nonimpervious solid surfaces =
10 micrograms/100 cm2 or
100 micrograms/100 cm2 and encapsulated.
(Encapsulation would not be allowed if special
concerns arise - see policy for details.)
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f. Contaminated soil = 10 ppm, provided soil is
excavated to minimum 10
inches - excavated soil
replaced with clean soil
(less than 1 ppm PCB), spill site
restored (replacement of turf).
g. Keep appropriate records for 5 years.
D. POST-CLEANUP SAMPLING
a. Sampling area greater of:
i. area equal to area cleaned plus additional
1-foot boundary; or
ii. area 20 percent larger than original area of
contamination.
b. Number of samples sufficient to ensure area of
contamination of radius of 2' or more will be detected.
Minimum number of samples = 3;
Maximum number of samples = 40.
c. Sampling scheme methodology is such as to ensure 95%
confidence level against false positives. Includes
calculation for expected variability due to analytical error.
NOTE: EPA Region 10 has the following two documents available to assist in developing post-
cleanup sampling plans:
1. Verification of PCB Spill Cleanup by Sampling and Analysis
2. Field Manual for Grid Sampling of PCB Spill Sites to Verify
Cleanup
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10. FOOD AND FEED RESTRICTIONS
FOOD AND FEED RESTRICTIONS
DEADLINES
OCTOBER 1. 1985 - Prohibition on use and storage for reuse of electrical
transformers and electromagnets with PCB concentrations of 500 ppm or more
which pose the risk of contaminating food or feed.
OCTOBER 1, 1988 - Prohibition on use and storage for reuse of large PCB
Capacitors which pose an exposure risk to food and feed. Prohibition on use of
all large PCB Capacitors unless they are suitably isolated.
NOTE: There is no prohibition of use of PCB Capacitors or PCB Transformers in
food or feed facilities if the PCB Capacitors or PCB Transformers do not
pose an exposure risk to food or feed.
DEFINITIONS (TO CLARIFY WHERE THESE REGULATIONS APPLY)
POSING AN EXPOSURE RISK TO FOOD OR FEED means being in any
location where human food or animal feed products could be exposed to PCBs
released from a PCB Item. A PCB Item poses an exposure risk to food or feed if
PCBs which might be released in any way from the PCB Item have a potential
pathway to human food or animal feed.
HUMAN FOOD AND ANIMAL FEED include items regulated by the U.S.
Department of Agriculture and the Food and Drug Administration as food or
feed, including intentional food additives. This definition covers food and feed
held in a variety of facilities including grocery stores, restaurants, warehouses,
barns, bins, sheds, silos, and other structures, and in feedlots, open fields, and
animal grazing areas. Commercial or recreational fishing areas are excluded
from these regulatory requirements. Products used or stored in private
residences by the public are also excluded from this definition.
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REGULATORY COMPLIANCE
There are several ways to comply with the EPA requirement. The equipment can
be replaced or serviced to reduce the PCB concentration to less than 500 ppm.
Lsers may also relocate the equipment or build protective containment around it
to eliminate the exposure risk.
Fines of up to $25,000 per day of violation can be assessed against those who fail
to comply with these regulations.
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11. PCB TRANSFORMER FIRE REGULATIONS
PCB TRANSFORMER FIRES REGULATIONS (IN BUILDINGS AND ELSEWHERE) - A
SUMMARY
DATE
REQUIREMENT
August 16. 1985
October 1. 1985
All PCB Transformer fire-related incidents must be
immediately reported to the National Response Center
(1-800-424-8802). and measures must be taken as soon as
practically and safely possible to contain potential releases of
PCBs and incomplete combustion products to waterways.
PCB Transformers can no longer be installed in commercial
buildings after October 1, 1985.
October 1. 1985
Except as otherwise provided, the installation of PCB
Transformers, which have been placed into storage for reuse
or which have been removed from another location, in or
near commercial buildings, is prohibited.
October 1, 1985
The installation of PCB Transformers on or after
October 1, 1985, and their use thereafter, is permitted either
in an emergency situation, as defined in 40 C.F.R. § 761.3, or
in situations where the transformer has been retrofilled and
is being placed into service in order to qualify for
reclassification under 40 C.F.R. § 761.30(a)(2)(v).
"•Emergency Situation: Emergency situation for continuing
use of a PCB Transformer exists when:
(1) Neither a non-PCB Transformer nor a
PCB-contaminated transformer is currently in
storage for reuse or readily available (i.e.,
available within 24 hours) for installation.
(2) Immediate replacement is necessary to continue
service to power users.
See restrictions on installation at 40 C.F.R. § 761.30(a)(iii)(B).
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Emergency installation permitted until October 1, 1990, and
the use of any PCB Transformer installed on an emergency
basis is permitted for 1 year from the date of installation or
until October 1, 1990, whichever is earlier.
December 1, 1985
December 1. 1985
All PCB Transformers, regardless of location, must be
registered in writing by the owner with appropriate fire
response personnel by December 1, 1985, and those PCB
Transformers in or near commercial buildings must also be
registered with the building owners by December 1, 1985.
All PCB Transformer locations must be cleared within a
5 meter radius of stored combustible materials by
December 1, 1985.
October 1, 1990
High secondary voltage PCB Transformers (480 volts and
above, including 480/227 volts) configured in a network
fashion and used in or near commercial buildings must be
removed from use, placed into storage for disposal, disposed
of, or reclassified to PCB-contaminated or non-PCB status by
October 1, 1990.
October 1, 1990 No emergency installation permitted after this date.
PCB Transformers installed for emergency purposes may be
reclassified rather than removed; however, if this is done,
reclassification to non-PCB or PCB-contaminated status must
be completed within 1 year of installation or by October 1,
1990, whichever is earlier.
The use of a retrofilled PCB Transformer installed for
reclassification purposes is limited to 18 months after
installation or until October 1, 1990, whichever is earlier.
October 1, 1990 Retrofilled PCB Transformer installed for reclassification
purposes must be tested 3 months after installation to
ascertain the PCB concentration. If PCB concentration is
still greater than 500 ppm, the retrofill process must be
repeated at three month intervals until transformer can be
reclassified as non-PCB or PCB-contaminated.
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Owners who installed PCB Transformers in emergency
situations or for reclassification purposes between
October 1, 1985, and September 1, 1988, must have notified
the Regional Administrator in writing by October 3, 1988, of
such installation. See 40 C.F.R. § 761.30(a)* l)(iii)(D) for
required information.
October 1, 1990 All radial PCB Transformers, in use in or near commercial
buildings, and lower secondary voltage network PCB
Transformers not located in sidewalk vaults in or near
commercial buildings (network transformers with secondary
voltages below 480 volts) that have not been removed from
service as provided in 40 C.F.R. § 761.30(a)(l)(v), must be
equipped with electrical protection to avoid transformer
ruptures caused by high current faults.
Current-limiting fuses or other equivalent technology must
be used to detect sustained high current faults and provide
for complete deenergization of the transformer (within
several hundredths of a second in the case of radial PCB
Transformers and within tenths of a second in the case of
lower secondary voltage network PCB Transformers), before
transformer rupture occurs. The installation, setting, and
maintenance of current-limiting fuses or other equivalent
technology to avoid PCB Transformer ruptures from
sustained high current faults must be completed in
accordance with good engineering practices.
October 1, 1990 As of October 1, 1990, owners of lower secondary voltage
network PCB Transformers, in use in or near commercial
buildings, which have not been protected as specified in
40 C.F.R. § 761.30(a)(l)(iv)(A), and which are not located in
sidewalk vaults, must register those transformers in writing
with the EPA Regional Administrator in the appropriate
region. The information required to be provided to the
Regional Administrator includes:
1. The specific location of the PCB
Transformer(s).
2. The address(es) of the building(s) and the
physical location of the PCB Transformeds) on
the building site(s).
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3.
The identification number(s) of the PCB
Transformer(s)
October 1. 1990 As of October 1, 1990. ail radial PCB Transformers with
higher secondary voltages (480 volts and above, including
480/277 volt systems) in use in or near commercial buildings
must, in addition to the requirements of 40 C.F.R.
§ 761.30(a)(l)(iv)(A), be equipped with protection to avoid
transformer ruptures caused by sustained low current faults.
October 1, 1993 All lower secondary voltage network PCB Transformers not
located in sidewalk vaults (network transformers with
secondary voltages below 480 volts), in use in or near
commercial buildings, which have not been protected as
specified in 40 C.F.R. § 761.30(a)(l)(iv)(A) by
October 1, 1990, must be removed from service by
October 1, 1993.
October 1, 1993 As of October 1, 1993, all lower secondary voltage network
PCB Transformers located in sidewalk vaults (network
transformers with secondary voltages below 480 volts) in use
near commercial buildings must be removed from service.
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MINERAL OIL TRANSFORMERS DISCOVERED TO BE PCB TRANSFORMERS
IMMEDIATELY AFTER
DISCOVERY
Report fire-related incidents.
WITHIN 7 DAYS AFTER
DISCOVERY
Mark the PCB Transformer with the ML.
WITHIN 7 DAYS AFTER
DISCOVERY
WITHIN 30 DAYS AFTER
DISCOVERY
WITHIN 18 MONTHS OF
DISCOVERY OR BY
OCTOBER 1, 1990
(the later of)
WITHIN 18 MONTHS OF
DISCOVERY OR BY
OCTOBER 1, 1990
(later of)
WITHIN 18 MONTHS OR
BY OCTOBER 1, 1990
(later of)
Mark the vault door, machinery room door,
fence, hallway or other means of access to the PCB
Transformer.
Register the PCB Transformer in writing
with fire response personnel with primary jurisdiction and
with the building owner.
Install electrical protective equipment on
a radial PCB Transformer and a non-
sidewalk vault, lower secondary voltage
network PCB Transformer in or near a
commercial building within 18 months of
discovery or by October 1, 1990, whichever
is later.
Retrofill and reclassify a radial PCB
Transformer or a lower or higher secondary
voltage network PCB Transformer, located
in other than a sidewalk vault in or near
a commercial building. (This is an option in lieu of installing
electrical protective equipment on a radial or lower
secondary voltage network PCB Transformer located in
other than a sidewalk vault or of removing a higher
secondary voltage network PCB Transformer or a lower
secondary voltage network PCB Transformer, located in a
sidewalk vault, from service).
Retrofill and reclassify a higher
secondary voltage network PCB Transformer,
located in a sidewalk vault, in or near a
commercial building. (This is an option in lieu of other
requirements).
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WITHIN IS MONTHS OF
DISCOVERY OR BY
OCTOBER 1, 1993
(later of)
Remove a non-sidewalk vault, lower
secondary voltage network PCB Transformer
in or near a commercial building, if
electrical protective equipment is not
installed.
WITHIN 18 MONTHS OF
DISCOVERY OR BY
OCTOBER 1. 1993
(later of)
Remove a lower secondary voltage network
PCB Transformer located in a sidewalk
vault in or near a commercial building.
WITHIN 18 MONTHS OR
BY OCTOBER 1, 1993
(later of)
Retrofit! and reclassify a lower secondary
voltage network PCB Transformer, located
in a sidewalk vault, in or near a
commercial building. (This is an option in lieu of installing
electrical protective equipment or removing the transformer
from service).
MARKING - FIRE REGULATIONS
PCB TRANSFORMER LOCATIONS TO BE MARKED:
1. (EXCEPT AS PROVIDED IN (2) BELOW) As of December 1, 1985, the vault
door, machinery room door, fence, hallway, or means of access, other than grates
and manhole covers, to a PCB Transformer must be marked with the mark ML.
A mark other than the ML mark may be used provided all of the following
conditions are met:
i. The program using such an alternative mark was initiated prior to
August 15, 1985, and can be substantiated with documentation.
ii. Prior to August 15, 1985, coordination between the transformer owner
and the primary fire department occurred, and the primary fire
department knows, accepts, and recognizes what the alternative mark
means, and that this can be substantiated with documentation.
iii. The EPA Regional Administrator in the appropriate region is
informed in writing of the use of the alternative mark by
October 3, 1988, and is provided with documentation that the
program began before August 15, 1985, and documentation that
demonstrates that prior to that date the primary fire department
knew, accepted and recognized the meaning of the mark, and included
this information in firefighting training.
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iv. The Regional Administrator will either approve or disapprove in
writing the use of an alternative mark within 30 days of receipt of the
documentation of a program.
3. Any mark placed in accordance with the requirements of this section must be
placed in the locations described in (1) above and in a manner that can be easily
read by emergency response personnel fighting a fire involving this equipment.
COMMERCIAL Bl ILDINGS:
EPA defines commercial buildings to include all types of buildings other than industrial
facilities. This would include locations such as office buildings, shopping centers,
hospitals, and colleges (places that generally have both public and employee access). A
PCB Transformer located in or near a commercial building is located on the roof of,
attached to the exterior wall of, in the parking area of, or within 30 meters of a
commercial building.
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12. SUBSTITUTE DIELECTRIC FLUID
SI BSTITl'TE DIELECTRIC FLUID
While EPA has concluded that there are available substitutes for the use of PCBs in
electrical transformers, including silicone oil filled transformers and dry transformers,
preliminary data from EPA studies indicate that chlorinated benzenes and
perchloroethylene (both of which have been proposed as substitutes for PCBs) may in
combustion situations also lead to the formation of PCDFs (polychlorinated
dibenzofurans) and PCDDs (polychlorinated dibenzodioxins). The replacement of PCB
dielectric fluid with materials which in fire situations may also lead to the formation of
PCDFs and PCDDs should be carefully considered in the light of the Agency's decision
in this rule to place conditions and restrictions on the use of PCB Transformers. EPA
is studying the issue of substitute dielectric fluids and will make a future determination
of whether there is a need for additional regulation to address this area.
Further information on PCB substitutes and enhanced electrical protection procedures may be
obtained from the Toxic Substances Control Act (TSCA) Assistance Office in Washington,
D C.: (202) 554-1404.
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13. CONTAINER SPECIFICATIONS
CONTAINER SPECIFICATIONS
STORAGE OF LIQUID AND NON-LIQUID PCBs
STORAGE CONTAINERS (LIQUID PCBs) LARGER THAN DOT-SPECIFICATIONS
Except as provided in 40 C.F.R. § 761.65(c)(7) [see below], any container used for the storage
of liquid PCBs shall comply with the Shipping Container Specifications of the Department of
Transportation (DOT):
49 C.F.R. § 178.80 - Specification 5 container without removable head
49 C.F.R. § 178.82 - Specification 5B container without removable head
49 C.F.R. § 178.102 - Specification 6D overpack with Specification 2S [40
C.F.R. § 178.35] or Specification 2SL
[40 C.F.R. § 178.35a] polyethylene containers
49 C.F.R. § 178.116 - Specification 17E container
Any container used for the storage of non-liquid PCBs shall comply with:
49 C.F.R. § 178.80 - Specification 5 container
49 C.F.R. § 178.82 - Specification 5B container
49 C.F.R. § 178.115 - Specification 17C container
As an alternate, containers larger than those specified in DOT Specifications 5, 5B, or 17C may
be used for non-liquid PCBs if the containers are designed and constructed in a manner that
will provide as much protection against leaking and exposure to the environment as the DOT
Specification containers, and are of the same relative strength and durability as the DOT
Specification containers.
40 C.F.R. § 761.65(c)(7) states that storage containers for liquid PCBs can be larger than the
containers specified in 40 C.F.R. § 761.65(c)(6) provided that:
The containers are designed, constructed, and operated in compliance with
Occupational Safety and Health Standards, 29 C.F.R. § 1910.106, [FLAMMABLE
AND COMBUSTIBLE LIQUIDS]. Before using these containers for storing
PCBs, the design of the containers must be reviewed to determine the effect on
the structural safety of the containers that will result from placing liquids with
PAGE 40 - SUMMARY OF PCB REGULATIONS
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the specific gravity of PCBs into the containers [Refer 29 C.F.R.
§ 1910.106(b)(i)(fM
ii. The owners or operators of any facility using containers described above shall
prepare and implement a Spill Prevention Control and Countermeasure (SPCC)
Plan as described in 40 C.F.R. Part 112. In complying with 40 C.F.R. Part 112,
the owner or operator shall read "oil(s)" as "PCB(s)" whenever it appears. The
exemptions for storage capacity, 40 C.F.R. § 112.1(d)(2), and the amendment of
SPCC plans by the Regional Administrator, 40 C.F.R. § 112.4, shall not apply
unless oils (as defined by Section 311 of the Clean Water Act) constitute some
fraction of the liquids stored in the container.
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14. NOTIFICATION AND MANIFESTING RULE
PCB NOTIFICATION AND MANIFESTING RULE: SUMMARY
Federal Register Publication Date: December 21, 1989
Promulgation Date: January 4, 1990
Regulation Amendment Effective Date: February 5, 1990
Deadline for Notification by generators,
commercial storers, transporters,
and disposers (engaged in PCB waste
activities prior to February 5, 1990) April 4, 1990
Deadline for Submittal of Complete
Application for Commercial Storage
Facility Approval August 2, 1990
GENERAL SUMMARY
1. This rule adds to the PCB disposal requirements a tracking system for PCB waste akin
to the "cradle-to-grave" tracking system for hazardous wastes which EPA promulgated
under RCRA (Resource Conservation and Recovery Act) Subtitle C.
2. This rule includes a requirement that certain entities among those who handle
(generate, transport, store and/or broker, or dispose of) regulated PCB waste must
notify EPA of their PCB waste activities, so that the Agency may obtain basic
information about the nature, location, and extent of these activities.
Note: The rule: a) limits the generator notification requirements to
generators who are required to operate their own 40 CFR § 761.65(b)
or (c)(7) PCB storage for disposal areas, and b) uses a relinquishment
of control criterion to define when a generator most manifest waste.
3. The rule requires that each such entity notifying EPA obtain from the Agency a unique
identification number which will identify that entity in the shipping documents
(manifests) and other records and reports that constitute the PCB waste tracking
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system. Entities which already have RCRA identification numbers may use those
numbers and will receive confirmation from EPA Headquarters of those numbers after
notifying under TSCA.
4. The rule describes the manifest system that will be implemented to track the movement
of PCB waste from the point of generation to the point of disposal, and it describes the
recordkeeping and reporting requirements that complete the tracking system.
5. The rule adds to the storage regulations an approval mechanism for commercial storers
of PCB waste. The rule requires, among other things, that all commercial storers of
PCB waste prepare closure plans for their facilities, and demonstrate their financial
responsibility for the closure of their PCB storage areas. The rule also requires an
environmental history of each facility's principals and key employees. STORERS OF
PCB WASTE WHO CANNOT DEMONSTRATE COMPLIANCE WITH THE
RULE'S FINANCIAL ASSURANCE OR CLOSURE REQUIREMENTS WILL BE
REQUIRED TO CEASE OPERATIONS AND CLOSE THEIR FACILITIES.
DEFINITION: GENERATOR OF PCB WASTE
"Generator of PCB waste" means any person whose act or process produces PCBs that
are regulated for disposal under Subpart D of 40 C.F.R. (Code of Federal Regulations)
Part 761, or whose act first causes PCBs or PCB Items to become subject to the
disposal requirements of Subpart D of this part, or who has physical control over the
PCBs when a decision is made that the use of the PCBs has been terminated and
therefore is subject to the disposal requirements of Subpart D of this part. Unless
another provision of this part specifically requires a site-specific meaning, "generator of
PCB waste" includes all of the sites of PCB waste generation owned or operated by the
person who generates PCB waste.
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DEFINITION:
COMMERCIAL STORER OF PCB WASTF
"(Ommercial storer of PCB waste" means the owner or operator of each facility which
is subject to the PCB storage facility standards of 40 C.F.R. § 761.65, and who engages
in storage activities involving PCB waste generated by others, or PCB waste that was
removed while servicing the equipment owned by others and brokered for disposal.
The receipt of a fee or any other form of compensation for storage services is not
necessary to qualify as a commercial storer of PCB waste. It is sufficient under this
definition that the facility stores PCB waste generated by others or the facility removed
the PCB waste while servicing equipment owned by others. A generator who stores
only the generator's own waste is subject to the storage requirements of § 761.65, but is
not required to seek approval as a commercial storer. If a facility's storage of PCB
waste at no time exceeds 500 gallons of liquid PCBs, the owner or operator is not
required to seek approval as a commercial storer of PCB waste.
NOTE: The 500 gallon exemption applies to facilities storing only liquids. For
example, a facility storing a single 300-gallon PCB Transformer or PCB-
contaminated transformer is a commercial storer. Storage of any PCB
Article makes a facility a commercial storer.
DEFINITION: TRANSFER FACILITY
"Transfer facility" means any transportation-related facility including loading docks,
parking areas, and other similar areas where shipments of PCB waste are held during
the normal course of transportation. Transport vehicles are not transfer facilities
under this definition, unless they are used for the storage of PCB waste, as Opposed to
exclusive use for actual transport activities. Storage areas for PCB waste at transfer
facilities are subject to the storage facility standards of § 761.65, but such storage areas
are exempt from the approval requirements of § 761.65(d) and the recordkeeping
requirements of § 761.180, unless the same PCB waste is stored there for a period of
more than 10 consecutive days between destinations.
RESTRICTIONS ON GENERATORS. STORERS. TRANSPORTERS, AND DISPOSERS
After June 4, 1990, generators of PCB waste may turn over their PCB waste only to
commercial storers, transporters, and disposers of PCB waste who have notified EPA of
their PCB waste activities and received EPA identification numbers and any required
approvals. The use of the generic identification number, 40 CFR Part 761, is
acceptable as long as the facilities have notified EPA within the timeframes required by
the regulations and have not yet received either the new identification number or the
verification of the old number.
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Likewise, commercial storers, transporters, and disposers of PCB waste may accept
PC B waste only from generators, other commercial storers, transporters, and disposers
who have notified EPA of their PCB waste activities and received identification
numbers.
NOTIFICATION - IDENTIFICATION NUMBERS
This rule adopts the same numbering system as RCRA.
1. Generators of PCB waste who are exempted from notification requirements under
§ 761.205(c)(1) will be deemed as having received by rule the identification
number 40 CFR Part 761. However, facilities exempted from the notification
requirements are not exempted from the manifesting requirements.
2. For generators with multiple storage areas subject to the requirements of
§ 761.65. a notification form for each of the storage areas must be submitted.
3. Required notifications must be made by April 4, 1990. Persons who have notified
EPA by April 4, 1990, may use the generic identification number until assignment
of a new number by EPA. Persons who already have RCRA identification
numbers may use those numbers and will receive confirmation from EPA
Headquarters for those numbers after they have notified under TSCA.
4. Any non-exempt generator, commercial storer, transporter, or disposer of PCB
waste who begins PCB waste activities after the effective date of the final rule is
required, prior to handling any PCB waste, to notify EPA and receive an EPA
identification number in accordance with this rule. Operation is not allowed until
this number is received.
5. Facilities legally storing PCBs for disposal in areas not complying with 40 C.F.R.
§ 761.65(b) or (c)(7) for up to 30 days after removal from service are not
required to notify as long as all PCBs are removed from the facility prior to the
expiration of 30 days.
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MANIFESTING
1. The final rule adopts the use of the UNIFORM HAZARDOUS YVASTF
MANIFEST. " ~~
The final rule requires all generators of PCB waste at concentrations of 50 ppm
or greater to manifest their waste.
3.
4.
There is no small quantity generator exclusion.
Any PCB or PCB Item that is not subject to disposal requirements is not subject
to manifesting.
EXAMPLES:
1. Drained PCB-contaminated carcasses for salvage.
2. Decontaminated PCB Containers.
3. Drained PCB-contaminated containers.
4. Small capacitors (intact and non-leaking).
5. Drained PCB Containers which will continue to be used as
PCB Containers or PCB Containers which have been
decontaminated pursuant to 40 C.F.R. § 761.79.
5. The manifest must be prepared by the generator at the time the PCB waste is
first introduced into commerce in a manner that will cause the waste to leave the
generator's control (even if the generator is using its own transportation).
6. Generators using independent transporters must verify receipt of the PCB waste
by the designated disposal or commercial storage facility by telephone call, or
other mutually agreed method, after the generator has received the signed copy of
the manifest from the disposal or commercial storage facility acknowledging
acceptance of the shipment
7. Reporting of unmanifested waste, of discrepancies, and of one year exceptions is
required of all generators who must manifest their PCB waste.
Examples: 1. Disposer must report when he receives PCBs more than nine
months after the PCBs were removed from service and cannot
dispose of the PCBs within one year of the date the generator
removed them from service.
2. The storer or disposer must report if there is a discrepancy in
quantity or type of waste on the manifest when it arrives at the
commercial storage or commercial disposal facility.
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3. The commercial storer or disposer must report if he receives
unmanifested PCBs (unless manifesting is not required bv the
regulations).
4. The generator must report if he does not get a certificate of
disposal within 13 months of removal from service, and the
PCBs were sent for disposal within nine months of removal from
service.
8. Certificates of disposal from disposal facilities are required to be provided to
generators.
RECORDKEEPING
1. Both an annual report and an annual document log (separate and distinct
documents) must be prepared by commercial disposers or storers. Generators
need to prepare and maintain the annual document log. Generators, storers, and
disposers must also maintain specific annual records.
NOTE: Annual Records = manifests and disposal certifications
(definition in Section 40 C.F.R. § 761.3)
2. Commercial storers and disposers must submit annual reports to EPA by July 15
for the preceding calendar year. The first report required for submittal is the
one due July 15, 1991.
NOTE: 1989 PCB Annual Reports will include the period from January 1, 1989,
through February 4, 1990. The 1990 PCB Annual Document Logs and the
1990 PCB Annual Reports that are required to be submitted to EPA will
include the period from February 5, 1990, through the end of the calendar
year.
COMMERCIAL STORAGE PERMITS
1. Applicant must supply information on environmental violations by the facility, the
facility's principals, and key employees, that occurred within 5 years of the day
application was submitted.
2. Applicant must submit relevant information bearing upon the qualifications of
the facility's principals and key employees to engage in the business of
commercial storage of PCB waste.
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3. PCB storage areas at a RCRA-permitted facility mav be exempt from obtaining a
separate TSCA storage approval upon a showing to the EPA Regional
Administrator's satisfaction that existing RCRA closure plan and financial
assurance demonstration account for PCB inventories and that environmental
history does not indicate an inability of the facility to operate such a commercial
storage facility.
4. PCB storage areas ancillary to a TSCA-permitted disposal facility mav be exempt
from the requirement to obtain a separate TSCA storage approval if the existing
closure plan and financial assurance demonstration account for the facility's PCB
storage activities and if the environmental history does not indicate an inability to
properly operate such a commercial storage facility.
5. Applicant must supply a written estimate of the cost, in current dollars, of closing
the PCB storage areas of the facility in accordance with the closure plan.
6. Federal and State governments are exempt from closure cost estimates and
financial assurance requirements (but not from the requirement to obtain
approval). Local governments are not exempt
7. Commercial storers of PCB waste have interim approval to operate commercial
facilities for the storage of PCB waste until August 2, 1990.
8. A commercial storer of PCB waste is prohibited from storing any PCB waste at
its facility after August 2, 1990, unless it has submitted a complete application for
a final storage approval. Such submittal continues interim approval until EPA
makes a final decision on the storage application.
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15. PHYSICAL SEPARATION
PHYSICAL SEPARATION OF PCBS - EPA POLICY
(See TSCA Compliance Program Policy No. 6-PCB-2)
ISSUE:
Does the physical separation of PCBs from liquids and solids require EPA approval?
POLICY
The physical separation of PCBs from liquids and solids requires an approval if the use or
disposal of these liquids and solids avoids, or is alternative to, the disposal requirements that
would have applied to the original material before separation. An approval is required for
physical separation activities that can be part of, or an initiation of, a disposal activity.
However, an approval is not required for physical separation activities which process PCBs
during authorized activities and reuse the processed materials in equipment authorized for
continued use by the PCB rules. An approval is also not required for treatment of PCB
contaminated water where the treatment medium is properly disposed of and the water is
discharged in accordance with an NPDES permit
DISCUSSION
A permit is not required to physically separate an organic phase from an aqueous phase of
collected water (e.g., leachate, lagoon water, storm water). The organic phase must be disposed
of according to the regulations for its concentration of PCBs. The aqueous phase may be
disposed of by means of filtration to remove any residual PCBs (e.g., activated carbon),
provided the filter medium is disposed of in accordance with the regulations for solids
containing that concentration of PCBs, and the water, if discharged to navigable waters, is
discharged in accordance with a National Pollutant Discharge Elimination System (NPDES)
permit granted under the Clean Water Act Water cannot legally be discharged from a point
source without meeting the permit conditions. Through this permitting process, EPA limits the
amount of PCBs released in the water prior to discharge. Since EPA controls the amount of
PCBs released with the water, and also controls the disposal of any PCBs physically separated
from the water (40 C.F.R. § 761.60), no additional approval under TSCA is necessary or
w arranted. This form of physical separation may be compared to the policy of not requiring
approvals for physical separation methods which result in all materials going to controlled
equipment or proper disposal under the PCB Regulations.
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16. RECLASSIFICATION OF TRANSFORMERS
KFCLASSIFICATION OF TRANSFORMERS
Reference: 40 C.F.R. § 761.30(a)(2l(v)
A PCB Transformer may be converted to either:
1. a PCB-Contaminated Electrical Equipment or
2. a non-PCB Transformer
And a transformer that is classified as PCB-Contaminated Electrical Equipment may be
reclassified to a non-PCB Transformer by:
1. Draining,
2. Refilling, and/or
3. Otherwise servicing the transformer.
In order to reclassify, the transformer's dielectric fluid must contain:
a. less than 5(H) ppm PCB (for conversion to PCB-Contaminated Electrical
Equipment) or
b. less than 50 ppm PCB (for conversion to a non-PCB Transformer)
AFTER: A minimum of three months of in-service use subsequent to the last
servicing conducted for the purpose of reducing the PCB
concentration in the transformer.
In-service means that the transformer is used electrically under loaded conditions
that raise the temperature of the dielectric fluid to at least 50° Centigrade (see
below).
EXCEPTIONS
The Director, Toxics and Pesticides Enforcement Division, may grant approval, without further
rulemaking, for the use of alternative methods that simulate the loaded conditions of in-service
use. All PCBs removed from transformers for purposes of reducing PCB concentrations are
subject to the disposal requirements of § 761.60.
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17. PCB FLUORESCENT LIGHT BALLAST DISPOSAL
PCB FLUORESCENT LIGHT BALLAST DISPOSAL
40 C.F.R. § 761.60(b)(2)(h) states that a person may dispose of PCB Small Capacitors as
municipal solid waste, unless that person is subject to the requirements of 40 C.F.R.
§ 761.60(b)(2)(iv). NOTE: READ ON - THIS IS NOT AS SIMPLE AS IT SOUNDS!
EPA requires that any leaking PCB small capacitor be properly disposed of in:
1. an EPA-approved chemical waste landfill, or
2. a high temperature incinerator
The PCB regulations do not require the removal of ballasts which contain non-leaking PCB
small capacitors. Unfortunately, it is virtually impossible to determine whether a small
capacitor inside a light ballast is leaking since you can not see the capacitor. NOTE: The issue
is whether the capacitor is leaking, not whether the ballast is leaking. However, if the ballast
itself is leaking, the black potting compound may be PCB-contaminated, which in and of itself
makes the ballast fully regulated for disposal (i.e., cannot be disposed of as municipal solid
waste).
Therefore, EPA recommends that ballasts in older light fixtures be removed and disposed of as
part of a regular maintenance program. This approach should reduce or eliminate exposure
from leaking units and also the potentially costly cleanup and disposal that can result when a
PCB light ballast fails. If a PCB leak has occurred, the PCB regulations require prompt and
thorough cleanup. Specific numerical cleanup standards -• which apply to any PCB spill or
leak -¦ are contained in the PCB regulations at 40 C.F.R., Part 761, Subpart G.
When ballast removal occurs as part of a relamping or removal project, even non-leaking and
intact PCB light ballasts should be disposed of at least in a chemical waste landfill because of
the large quantities which may be involved in such a program and because it is difficult to
determine whether the capacitor is leaking. The provision in the PCB Regulations to allow
non-leaking PCB small capacitors to go to municipal solid waste landfills was based on the
premise that persons other than capacitor manufacturers would dispose of only one or a few
PCB small capacitors at a time and was intended primarily to recognize that most homeowners
would not be able to afford to send one or two light ballasts containing PCB small capacitors to
an EPA-approved disposal facility. The intent of the PCB regulations to permanently
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remove PCBs from the environment is not achieved when significant quantities of PCB small
capacitors go to municipal landfills since such landfills are not designed to handle toxic
materials.
PCB large capacitors (i.e., those that contain more than 3 pounds of PCB dielectric fluid) are
required to be incinerated at EPA-approved PCB incinerators onlv, and, from a practical and
environmental standpoint, there is no difference in the potential hazard from one large
capacitor or a number of small capacitors which have the same total volume.
Effective February 5, 1990, leaking PCB small Capacitors must be manifested for disposal, and
any transporter used to transport such leaking equipment from the generator to either a PCB
storage or disposal facility must have formally notified EPA of its PCB transportation activity
and received an EPA identification number pursuant to the Toxic Substances Control Act
(TSCA). It would be prudent to confirm that such notification has been made by any such
firms offering such disposal, storage, or transportation services. EPA can verify whether such
notification has been made.
HOMEOWNERS
EPA clearly has not intended for homeowners with a few PCB light ballasts to comply with the
more stringent disposal requirements. Many homeowners have access to local household
hazardous waste collection centers. Homeowners should check with their city, county, or local
health department to determine if such collection centers exist and can accept PCB light
ballasts. Most collection centers will not accept such waste from commercial enterprises. In
addition, many fire departments put on yearly household hazardous waste collection events.
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18. PCBS IN LABORATORIES
PCBS IN LABORATORIES
41) C.F.R. $ 761.30( i) states that PCBs may be used in small quantities for research and
development as defined in 40 C.F.R. § 761.3 (see below), in a manner other than a totally
enclosed manner, indefinitely. Manufacturing, processing, and distribution in commerce of
PCBs in small quantities for research and development is permitted only for persons who have
been granted an exemption under TSCA Section 6(e)(3)(B).
Small Quantities for Research and Development is defined as any quantity of PCBs:
1. that is originally packaged in one or more hermetically sealed containers to a
volume of no more than five (5.0) milliliters, and
2. that is used only for purposes of scientific experimentation or analysis, or
chemical research on, or analysis of, PCBs, but not for research or analysis for
the development of a PCB product.
Process is defined as the preparation of a chemical substance or mixture, after its manufacture,
for distribution in commerce:
1. In the same form or physical state as, or in a different form or physical state
from, that in which it was received by the person so preparing such a mixture, or
2. As part of an article containing the chemical substance or mixture.
MARKING: All PCB Containers (including sample vials) must be labeled with a PCB label
identified at 40 C.F.R. § 761.45.
COMMON REGULATORY ISSUES FOR A LABORATORY TO CONSIDER IF IT
CONDUCTS PCB CHEMICAL ANALYSIS
1. Analysis of PCBs is considered an authorized use of PCBs. So long as the PCBs are in
use. as is, there are few requirements.
In use includes:
a. Samples stored prior to chemical analysis
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b. Samples undergoing the analytical process
c. I sed samples being stored for enforcement or compliance purposes
PC B Samples in uses other than the three situations listed above, and anything that
contacted regulated PCBs, are regulated for disposal.
-¦ Laboratory Standards must be purchased from a company which has the appropriate
EPA TSCA exemption.
NOTE: Laboratories may not distribute "home" analytical standards to another
laboratory, including samples prepared for conducting multi-lab or round-
robin laboratory samples.
3. Laboratory waste and any PCBs diluted during analysis are regulated for disposal
according to the original PCB concentration of PCBs contacted and diluted.
4. Laboratories may not recycle solvents without a PCB disposal approval, but may
decontaminate glassware (rinse solvents are regulated for disposal).
5. Laboratories are generators of PCB waste (glassware, extraction solvents, spent
florisil/alumina, gloves, disposable pipettes, etc.) and as such are required to:
a. Obtain an EPA ID Number under TSCA (RCRA notification does not
satisfy the TSCA notification requirement). Exception: This notification
requirement is only for those facilities maintaining storage for disposal
facilities subject to the requirements of 40 C.F.R. § 761.65(b). If a
laboratory never stores PCB waste for longer than 30 days from removal
from service (i.e., when the sample is no longer required for analytical or
evidentiary purposes), such notification is not required.
b. Manifest samples not in use to a disposal or commercial storage facility or
back to the sample collector.
c. Prepare and maintain a PCB Annual Document Log if more than 45
kilograms of PCB waste is handled during the year.
d. Keep copies of manifests and track the waste designated for disposal.
6. Certain laboratories conditionally do not need a PCB Commercial Storage Approval.
a. If they are not associated with a disposal facility.
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b. If no more than 500 gallons or 70 cubic feet of PCB materials are on hand
at any one time.
7. Laboratories which temporarily store PCB waste for disposal:
a. Are required to follow storage regulations (40 C.F.R. § 761.65)
b. Must dispose of generated waste and used samples within one year of the
date that the use has ended.
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APPENDIX
19. GENERAL PCB INFORMATION
POLV( HLORINATED BIPHENYLS
Polvchlorinated biphenyls, commonly known as PCBs, belong to a family of organic compounds
known as chlorinated hydrocarbons. PCBs were produced in the United States between 1929
and 1977, when the primary U.S. manufacturer voluntarily stopped making them because of
mounting public concern over their harmful environmental effects. Most PCBs were sold for
use as dielectric fluids (insulating liquids) in electrical transformers and capacitors. Although
PCBs are no longer being commercially made in this country, many electrical transformers and
capacitors once filled with PCBs are still in service. The Toxic Substances Control Act (TSCA).
which became law in 1976, prohibits the manufacture of PCBs, controls the phase-out of their
existing uses, and sees to their safe disposal.
Almost all PCBs in existence today were intentionally manufactured. Some inadvertent
production of PCBs occurs in certain manufacturing processes of organic chemicals. Such
inadvertent production must be specifically authorized by federal PCB regulations. PCBs may
be formed when chlorine, carbon, and elevated temperatures or catalysts are present together
in a process stream.
General Characteristics
Clear to yellow oily liquids or waxy solids
High boiling point
High degree of chemical stability
Low fiammability
Low electrical conductivity
Weight: about 10-12 pounds per gallon
Flash Point: 383° F
Water solubility: only very slightly soluble
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Other I ,'ses
Heat transfer fluid
Hydraulic fluid
Dye carriers in carbonless copy paper
Plasticizers in paints, adhesives, and caulking compounds
Fillers in investment casting wax (for precision casting)
Whv are PCBs harmful to Human Health and the Environment?
Once released into the environment, PCBs tend not to break down into other less toxic
substances, but persist and take several decades to slowly decompose.
Bv remaining in the environment, PCBs can be taken up and stored in the fatty tissues
of all organisms from which they are slowly released into the bloodstream. Therefore,
due to storage in fat, the concentration of PCBs in the body tissues can increase with
time, even though PCB exposure levels at any one time may be very low. This is called
bioaccumulation.
As PCBs accumulate in the tissues of simple organisms, and as they are consumed by
progressively higher organisms, the concentration increases. This is called
biomagnification.
Through bioaccumulation and biomagnification, the cumulative quantity of PCBs
consumed by humans, who are at the top of the food chain, can be quite significant.
Bioaccumulation in organisms and biomagnification in the food chain are especially
significant because PCBs are harmful to health at low levels.
Chronic (Long-Term) Effects (based on well-documented tests on laboratory animals
and some human exposure cases) include:
Reproductive system effects
Gastric disorders
Skin lesions; can cause a severe acne-like rash (chloracne) which may persist for
years
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They are presumed carcinogens in humans based on studies which have shown
them to cause cancerous tumors in animals
Possible teratogenic (fetal development) effects (have been shown to be teratogens
in animals)
Possible liver damage (have been shown to cause liver cancer in animals/
Possible nervous system damage, causing numbness, weakness and tingling in the
arms and legs (from high exposure)
Acute (Short-Term) Effects:
Exposure to the vapor can irritate the eyes, nose, and throat
High exposures can damage the liver
Effects on Fish
PCBs may, even at low concentrations in water, reduce the supply of commercial
fish, either through direct adverse effects on their development and juvenile
growth or through reduction in populations of aquatic animals and plants which
are the food sources for the fish.
Exposure Routes
Lungs (breathing)
Gastrointestinal tract (eating PCB-containing food or eating with hands that have
been in contact with PCBs)
Skin (direct contact)
After absorption, PCBs are circulated in the blood throughout the body and are stored
in fatty tissues and a variety of organs, including the liver, kidneys, lungs, adrenal
glands, brain, heart, and skin.
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Where Are PCBs Found?
Everywhere - they pervade the environment. Measurable amounts have been
found in:
Soils
Water
Fish
Milk
Human tissues
Polar ice caps
PCBs have been found in fish from the Hudson River and the Great Lakes, in
fish meal used as feed (as a resuit of a leaking heat exchanger), and in animal
feed (as a result of a leaking transformer).
How Are PCBs Regulated?
PCBs are regulated under the federal Toxic Substances Control Act (TSCA). Congress passed
this statute in 1976. Section 6(e) of TSCA specifically directs EPA to regulate PCBs. PCBs are
the only chemical class specifically named in TSCA because Congress believed that the
chemical and toxicological properties of PCBs posed a significant risk to public health and the
environment. Implementing regulations that EPA promulgated pursuant to TSCA are
published at 40 C.F.R. Part 761. A copy of these regulations is available from your EPA
regional office.
Work Practices • Recommendations
Do not eat, smoke, or drink where PCBs are handled, processed, or stored, since the
chemicals can be swallowed, inhaled, or absorbed via skin. Wash hands carefully
before eating or smoking.
Avoid skin contact with PCBs. Wear protective gloves and clothing. Safety equipment
suppliers/manufacturers can provide recommendations on the most protective
glove/clothing material.
If there is the possibility of skin exposure, emergency shower facilities should be
provided.
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I pon skin contact with PCBs. immediately wash or shower with soap to remove the
chemical. At the end of a workshift, wash anv areas of the body that may have
contacted PCBs. even though no known skin contact has occurred. However, don't rub
the skin too much to avoid damaging the epidermis.
Workers whose clothing has been contaminated by PCBs should change into clean
clothing promptly after cleaning contaminated areas of skin (see below).
Do not take contaminated work clothes home. Family members could be contaminated.
Contaminated work clothes shouJd be disposed of as regulated PCB waste if they came
into contact with PCBs at a concentration of 50 parts per million or greater.
All protective clothing (suits, gloves, footwear, headgear) should be clean, available
each day. and put on before work.
If vacuuming up PCB-containing solid materials, a high efficiency particulate absolute
(HEPA) filter should be used, not a standard shop vacuum.
In any situation where there is a possibility of exposure to PCBs through inhalation,
use a MSHA^/NIOSH** approved supplied-air respirator with a full facepiece operated
in the positive pressure mode or with a full facepiece, hood, or helmet in the continuous
flow mode, or use a MSHA/NIOSH approved self-contained breathing apparatus with a
full facepiece operated in pressure-demand or other positive pressure mode. In the
event that using such a respirator is not possible or practicable, such as when changing
out failed PCB light ballasts, other reasonable steps should be taken to minimize any
possible exposure from inhalation such as using goggles or a face shield.
* \1SHA: Mine Safety and Health Administration
Seattle telephone (206) 553-7037
** NIOSH: National Institute for Occupational Safety and Health (Department of
Health and Human Services)
NIOSH has no office within EPA Region 10 - the Department of
Health and Human Services can be reached at (206) 615-2010
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PCB MANUFACTURERS AND TRADE NAMES
PCBs have been marketed and used by manufacturers in their products under various trade
names. This list is not complete or comprehensive since many companies have gone out of
business and information is no longer available. Therefore, it should only be used as an initial
reference to infer whether a piece of equipment may contain PCBs. If a dielectric trade name
on a piece of equipment does not appear on this list, it does not mean it does not contain PCBs.
This list does not provide an alternative to testing or use of the assumption requirements.
MANUFACTURER
COUNTRY
TRADE NAME
Aerovox
Allis-Chalmers
American Corp.
Axel Electronics
Bayer
Caffaro
Caffaro
Caffaro
Capacitor Specialists
Chemko
Cornell Dubilier
Dings Co.
Electrical Utilities Corp.
Electro Engineering Works
Electromagnetic Filter Co.
Envirotech Buell
Eriez Magnets
ESCO Mfg. Co.
Ferranti-Packard Ltd.
General Electric
Geneva Industries
H.K. Porter
Helena Corp.
Hevi-Duty Electric
ltaliano
ITE Circuit Breaker
Jard Corp.
Kanegafuchi
US
US
US
•>
Germany
Italy
Italy
Italy
US
Czechoslovakia
US
US
US
US
US
US
US
US
US
US
US
US
US
US
Italy
US
US
Japan
Hyvol
Chlorextol
Asbestol
•>
Clophen
Dk
Fenclor
Inclor
Dykanol
Eucarel
•>
Pyranol
Askarel*
Askarel*
Pyranol, Magvar, Abestol
<>
Askarel*
Inflamol
Non-Flammable Liquid
Clorphen
Kennechlor
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kuhlman Electric
Mc(irav\ Edison
Malonev Electric
Mitsubishi
Monsanto
Monsanto
Monsanto
Monsanto
Monsanto
Monsanto
Monsanto
Monsanto
Niagara Transformer Corp.
Niagara Transformer Corp.
Niagara Transformer Corp.
P R Mallory & Co.
Power Zone Transformer
Prodelec
Prodelec
Queensboro Transformer and
Machinery
R.C. Uptegraff
R.F. Interonics
Reliance Electric Co.
Research-Cottrell
Sangamo Electric
Sovol
Sprague Electric Co.
Standard Transformer Corp.
Stens .Magnetics
Tobe Deutschmann Labs.
Toshiba
Universal Mfg. Corp.
Van Tran Electric
Wagner Electric
W estinghouse Electric
IS
IS
US
Japan
UK and US
UK and Japan
UK and Europe
US
US
US
US
US
US
US
US
US
US
France
France
US
US
US
•>
US
US
USSR
US
us
us
us
Japan
US
US
US
US
Saf-T-Kuhl
Elemex
•)
Kanechlor, Santotherm
Aroclor
Santotherm FR
Pvroclor
Therminol**
Pydraul***
Santovac 1 and 2
MCS 1489
Capacitor 21
Askarel*
EEC-18
N-3
Aroclor B
EEC-18
Phenoclor
Phyralene
ASK
ALC
•>
•>
Askarel*
Diaclor
7
Chlorinol
Shibanol
Askarel*
No-Flamol
Inerteen
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>rk Electronics
US
US
USSR
Nepolin
Apirolio
Kaneclor
Solvol
Turbinol
Dicanol
Santorac
Askarel is the generic name for nonflammable insulating liquid in transformers and
capacitors.
Various products used as heat transfer fluids, such as Therminol FR-O, were
manufactured under this name.
Various products used as hydraulic fluid, such as Pydraul A-200, were manufactured
under this name.
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