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PCB-containing materials are classified in the regulations according to the concentration of PCBs present. There are three classifications of PCB-containing materials:
Mixtures of PCB-containing materials are subject to all requirements of the highest PCB concentration classification within the mixture. The deliberate dilution of PCB materials to reduce the concentration of PCBs in a resultant mixture is prohibited.
CAUTION: Federal and some state regulations may differ on PCB classifications for waste. Under federal regulations, waste with a concentration below 50-ppm PCB may be defined as non-PCB waste; whereas, under state regulations waste must have a concentration below 5-ppm PCB to be defined as non-PCB waste.
There are over 200 PCB isomers and compounds, which vary from mobile, oily liquids to white, crystalline solids and hard resins.
PCBs are difficult to distinguish without using analytical methods. Field screening techniques can test for the presence of chlorine, but laboratory analysis is necessary to identify PCBs and PCB concentrations. The difficulty in identifying PCBs emphasizes the importance of properly labeling equipment and materials that contain them.
PCB materials are divided into two main groups within the regulations: PCBs and PCB Items. PCB Items are further divided into four categories: (1) PCB Articles, (2) PCB Containers, (3) PCB-Article Containers, and (4) PCB Equipment. See the PCB identification chart ( Figure 1 ) and the Glossary for definitions of these terms.
Contact your Environmental Staff about any suspected PCB material so that it can be thoroughly evaluated.
Before federal regulations limited PCB production and use, PCBs were commonly used in a variety of commercial products, including:
Many of the past uses are now unauthorized under federal and state regulations. PCB use is allowed only under specific conditions in limited scenarios.
NOTE: PCBs were widely used in equipment that is still in service today; therefore, waste oil collected from this equipment frequently contains a detectable PCB concentration.
The following items must be identified and labeled with their PCB classification:
If items were not originally labeled by their manufacturer, the owner must label items that may contain PCBs.
Standard PCB labels are square and come in 1-in. increments from 2 in. x 2 in. to 6 in. x 6 in. (see Figure 2 ).
If the standard PCB label is too large to fit on a piece of equipment, a 1-in. x 2-in. PCB label may be substituted (see Figure 3 ).
When analytical results identify an item's PCB concentration, the concentration should be written in permanent ink on the label. When the equipment is determined to have a concentration of less than 5-ppm PCBs, a "Non-PCB" label should be affixed to the equipment. Labeling is also required for materials that do not contain PCBs. Large, low-voltage capacitors; small capacitors that are normally used in alternating circuits; and fluorscent light ballasts that do not contain any concentration of PCBs should be marked "No PCBs" by the manufacturer if manufactured after July 1, 1978.
Once a PCB Item is removed from service, the PCB Article or Container should also be labeled with the date when it was removed from service. In addition, other regulatory labeling requirements apply depending upon the contents of the container. See Appendix D for details.
Standard PCB, no PCBs, and non-PCB labels are available from EHSO
CAUTION: Aged labels on electrical equipment may not accurately represent the PCB concentration of the equipment's contents. For example, sealed transformers labeled as containing non-PCB oil may become contaminated with PCBs during servicing. Other reasons for erroneous labeling include:
Hence, electrical equipment, including sealed transformers originally labeled as non-PCB and maintained in service as non-PCB, should be handled cautiously. The equipment must be evaluated for PCBs and proper PCB classification when removed from service.
The status of any unlabeled equipment suspected of containing PCBs must be determined through laboratory analysis, and the equipment subsequently labeled. Some items, such as small capacitors, electromagnets, switches, voltage regulators, circuit breakers, and PCB-contaminated Electrical Equipment, do not require identification and labeling as a condition for continued use. However, the PCB status of these items must be determined when the items are taken out of service.
The regulatory requirements for handling PCB Equipment vary according to equipment type. The regulations divide PCB Equipment into several types:
The specific equipment requirements are described in detail in Appendix A. These requirements generally specify the conditions for continued equipment use and the frequency of equipment inspections.
It is important to note that PCB and PCB-contaminated Items stored for use and reuse are regulated as if they were in use.
To comply with federal law, you must maintain and annually update an inventory of all PCB Articles located onsite. Your company's Environmental Health & Safety Department (EHSD) should maintain this annual document log. Notify your Environmental staffabout any newly discovered and unlabeled PCB Equipment for inclusion in this log. Appendix B provides more information for EPD on the required recordkeeping.
Users of PCB Equipment must take all precautions necessary to prevent radioactive contamination of PCBs. Few disposal options exist for radioactive PCBs.
Owners of specific PCB Equipment are responsible for conducting equipment inspections on a regular basis and maintaining equipment inspections logs. The recommended/required frequency of inspections for PCB and PCB-contaminated Equipment is shown in Table 1 . Required quarterly inspections may be conducted any time during the three-month period: January-March, April-June, July-September, and October-December, as long as there is a minimum of 30 days between inspections.
When PCB and PCB-contaminated equipment is inspected, proper labeling requirements should be checked. Look for indications that the equipment may be leaking, such as:
These visual inspections do not require much time or effort, but an inspection log must be maintained to document the inspections. At a minimum, the inspection log should contain the date and time of inspection, the name of the inspector, and any findings. The findings must be followed by the corrective actions taken and the date the remedial actions were completed. The inspector must initial or sign all log entries. Records of these inspections must be retained for at least three years after disposing of the PCB-containing Equipment.
Upon discovery of a small spill of PCBs in a given area, employees can usually clean up the spill safely; however, they must be trained in advance to handle these cleanups. Cleanup of the released PCBs must be initiated as soon as possible, but no later than 48 hours after its discovery. Materials for the cleanup of common chemical spills should be kept ready.
If the spill is too large to clean up safely or if employees have been injured or contaminated, immediately call the emergency number (911).
Environmental regulations and U. S. Department of Energy (DOE) Orders have notification and reporting requirements for PCB spills above certain amounts or when potential harm to individuals, property, or the environment exists. Report all spills of PCBs to the your Environmental Staff. Guidance on spill cleanup and reporting information is included in Appendix C.
A PCB or PCB-contaminated Item must be disposed of within one year from the date when the item is declared a waste or is no longer fit for use. PCB and PCB-contaminated Items stored for disposal must be stored in an HWM facility and should be shipped to an approved disposal facility within nine months of removal from service. Temporary storage of certain PCB and PCB-contaminated waste can occur in a Waste Accumulation Area (WAA) for up to 30 days. Temporary storage of PCB liquid at a concentration of 500 ppm or more is prohibited.
Notify your HWM Technician and Environmental Staff when PCB and PCB-contaminated Items require disposal. Packaging, labeling, and storage requirements for PCB wastes are provided in Appendix D as guidance. Acceptable disposal options for PCB materials are provided in Appendix E.
The research and development of PCB products are prohibited; however, other scientific experimentation or analysis using PCBs is permitted. PCBs may be purchased in hermetically-sealed containers of less than 5 mL. Manufacturing, processing, and distributing PCBs for research and development require a special exemption granted from the EPA. (Only persons granted an exemption under TSCA, Section 6(e)(3)(B) are permitted to manufacture, process, or distribute PCBs in small quantities for research and development.)
A laboratory using PCBs for research and development must provide spill containment and the appropriate labels for all PCB materials. PCB waste generated during the research and development activities must be stored and then disposed of properly. Specific recordkeeping and documentation must be maintained.
All purchases and disposal of PCB materials must be reported to your Environmental Staff.
The inadvertent generation of PCBs in a concentration greater than 2 ppm must be reported by your company to the EPA within 90 days, as detailed in 40 CFR 761.185. PCBs can be produced when chlorine, hydrocarbon, and elevated temperatures (or catalysts) are present together. Please contact your Environmental Staff in the event of the inadvertent generation of PCBs.
PCB regulations require that seven separate types of reports and records be maintained on PCB and PCB-contaminated materials. Your Envionmental Department should be responsible for producing the required reports with the exception of equipment inspection logs. PCB Equipment owners are responsible for conducting equipment inspections and maintaining equipment inspection logs. (Refer to the section, "Inspecting PCB Equipment.") Further information regarding the reports that should maintained by your environmental department is given in Appendix B.
Should there be any questions regarding regulatory handling, inspecting, and disposal of PCB and PCB-contaminated Items, please contact EHSO at 770-645-0788.
1. California Health and Safety Code, Division 20, Chapter 6.5, Hazardous Waste Control Law.
2. Toxic Substances Control Act (TSCA) of 1976 (amended by PL-97-129, December 29, 1981; PL 98-80, August 23, 1983; PL 98-620, November 8, 1984; PL 99-519, October 22, 1986; PL 100-368, July 18, 1988).
California Code of Regulations , Title 22, Part 66261, Chapter 11, "Identification and Listing of Hazardous Waste."
California Health and Safety Code, Division 20, Chapter 6.6, Safe Drinking Water and Toxics Enforcement Act.
Code of Federal Regulations , Title 29, Part 1910 , "Occupational Safety and Health Standards," (29 CFR 1910).
Code of Federal Regulations, Title 40, Part 112, "Oil Pollution Prevention," (40 CFR 112).
Code of Federal Regulations , Title 40, Part 761, "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions," (40 CFR 761).
Code of Federal Regulations, Title 49, Part 178, "Shipping Container Specifications," (49 CFR 178).
U. S. Department of Energy (1993), Environmental Guidance, Management of Polychlorinated Biphenyls , U. S. Department of Energy, Office of Environmental Guidance, RCRA/CERCLA Division, November (EH-231).
U. S. Department of Energy (1993), "Occurrence Reporting and Processing of Operations Information," U. S. Department of Energy, Washington, D.C. (DOE Order 5000.3B).
Most transformers containing polychlorinated biphenyls (PCBs) may continue to be used for their remaining useful (active) or normal lives. There are, however, a number of exceptions where PCB Transformers (containing 500 ppm or more PCBs) are prohibited:
Servicing of PCB Transformers is allowed with a dielectric fluid at any concentration. However, a PCB Transformer should not be serviced when the coil must be removed. This transformer should be disposed of properly.
PCB Transformers must be visually inspected quarterly for leaks. These visual inspections may occur any time during the periods of January to March, April to June, July to September, and October to December, as long as there are at least 30 days between inspections. More frequent inspections (monthly) are recommended. The PCB Transformer owner is responsible for maintaining records of these inspections.
No routine, visual inspections are required for PCB-contaminated Transformers, but it is recommended that these transformers be visually inspected quarterly for leaks.
All leaking transformers must be repaired immediately, or the transformer must be replaced. A leak must be cleaned up within 48 hours after its discovery. All active leaks must be contained in a drip-pan or by some other appropriate method. Daily inspections are required until the leak is repaired.
If a PCB Transformer is involved in a fire-related incident, the National Response Center must be notified through proper channels, and specific reporting and containment requirements implemented.
Large PCB Capacitors (containing 1.36 kg or more of dielectric fluid) that are located in restricted areas (either a restricted-access electrical substation or a contained and restricted- access indoor installation) may continue to be used for their remaining lives. Large PCB Capacitors that are not located in restricted areas are prohibited. All small capacitors may continue to be used for their remaining lives.
No routine inspection requirements apply to capacitors unless they are stored for disposal, but it is good practice to inspect them annually for leaks.
Most capacitors cannot be sampled for analysis of PCB concentration. In most cases, the presence of PCBs can be determined directly from information on the capacitor or from the manufacturer. (All capacitors are assumed to contain PCBs unless the label or nameplate information, manufacturer's literature, or chemical analysis states that the capacitor does not contain PCBs.) The Environmental Staff can assist in this identification.
The EPA allows continued use of non-leaking PCB and PCB-contaminated fluorescent light ballasts. When these ballasts are taken out of service, they must be disposed of properly as hazardous waste and are not to be sold to subsequent users.
Most electromagnets, switches, and voltage regulators containing PCBs may continue to be used for their remaining useful or normal lives. The use or storage of a PCB electromagnet (500 ppm or more) in a location where human food or animal feed could be exposed to PCBs released from the electromagnet is prohibited.
Weekly inspections are required for electromagnets with PCBs if they are in use or stored for reuse and contain between 50 ppm and 500 ppm and pose an exposure risk to food or feed.
No routine visual inspections are required for other PCB or PCB-contaminated (less than 500 ppm) electrical equipment in use or stored for re-use, but it is recommended that this equipment be inspected quarterly for leaks.
Strict regulations apply to the use of PCBs in equipment which may not be totally enclosed. Examples of such equipment include hydraulic systems, heat-transfer systems, and compressors. Generally, this equipment requires annual testing and fluid replacement to reduce PCB levels to less than 50 ppm. Small quantities of PCBs used in equipment during research or used in optical liquids may have less stringent requirements. Contact your Environmental Staff for information on applicable regulations.
The polychlorinated biphenyl (PCB) recordkeeping and reporting specifics are presented here as guidance to the Environmental Protection Department (EPD) and the Programs.
Federal regulations require that copies of all PCB records be kept in a central location.
Annual records are required for any facility that uses or stores at least 45 kg (99.4 lb) of PCBs, or one PCB Transformer, or 50 PCB Capacitors. These records include:
The annual records must be retained for at least three years after the facility drops below the required reporting quantities.
An annual document log is required for any facility that uses or stores at least 45 kg (99.4 lb) of PCBs, or one PCB Transformer, or 50 PCB Capacitors. The document log includes:
The manufacture of PCBs is prohibited in the United States except for PCBs inadvertently generated under certain conditions. The inadvertent generation of PCBs in a concentration greater than 2 ppm must be reported to the EPA. Additional data must be provided to the EPA whenever:
The data submitted shall include all analytical data and corresponding throughput data for PCBs.
A generator of PCB waste who does not receive a copy of the manifest with a handwritten signature from the designated PCB storage or disposal facility within 35 days of the initial shipment date must immediately contact the transporter and/or designated facility to determine the status of the PCB waste. Such contacts must be documented. Copies of the manifests must be included in the PCB annual log.
A generator of PCB waste who does not receive a copy of the manifest with a handwritten signature from the designated PCB storage or disposal facility within 45 days of the initial shipment date must submit an Exception Report to the EPA Regional Administrator, Region IX. The Exception Report must include:
A One-Year Exception Report must be filed by a generator of PCB waste who (1) does not receive a copy of the Certificate of Disposal within 13 months from the date of removal from service, (2) receives a Certificate of Disposal confirming disposal on a date more than one year after the date of removal from service, or (3) stores PCB waste for greater than one year prior to disposal. The only exception to this requirement is if the generator does not transfer the PCB waste to the disposer within nine months from the date of removal from service, as required. The One-Year Exception Report must include:
Your company should file a Form 7710-53 with the EPA prior to using, storing, etc. PCBs..
Records documenting the cleanup of spills with high concentrations (500 ppm or greater PCBs) or more than 454 g (1 lb) of PCBs shall be maintained for five years. The records and certification shall consist of the following:
Records of the legally required inspections and maintenance history of PCB Equipment, including the name of the person responsible for the inspections and the dates of inspection, must be maintained for at least three years after disposal.
Polychlorinated biphenyls (PCB) spill cleanup and reporting requirements are presented here as guidance. Spills of PCB materials can only be remediated by personnel trained to handle PCB cleanups. Report all spills of PCBs to your Health and Safety / Environmental Staff.
When spills with low concentrations (less than 500 ppm PCBs) and less than 454 g (1 lb) of PCBs occur, all soil within the spill area (visible boundary plus a 1-lateral-ft buffer zone) must be excavated and backfilled with clean soil. Solid surfaces must be double washed/rinsed. (Double wash/rinse means a minimum requirement to cleanse solid surfaces two times with an appropriate cleaning agent. PCBs must be at least 5-percent soluble by weight in the cleaning agent. A volume of PCB-free fluid sufficient to cover the contaminated surface completely must be used in each wash/rinse.The wash/rinse requirement does not mean the mere spreading of the cleaning agent over the surface, nor does the requirement mean a once-over wipe with a soaked cloth.) This action must be completed within 48 hours after the responsible party was notified or became aware of the spill.
When spills with high concentrations (500 ppm or more PCBs) or more than 454 g (1 lb) of PCBs occur, the National Response Center must be notified immediately. The spill area must be cordoned off with at least a 3-ft buffer zone. Warning signs must be clearly visible. The responsible party must document and record the area of visible contamination, noting the extent and center of the visible trace areas. The cleanup of fluid from hard surfaces and the removal of contaminated soil must be initiated (not necessarily completed) within 24 hours after the responsible party was notified or became aware of the spill. If the spill will result in PCB exposure outside the facility, other spill reporting procedures may be required.
The U. S. Environmental Protection Agency (EPA), Region IX, regards soil, asphalt, wood, cement, and concrete as porous materials that absorb PCBs. Where practicable, these materials must be removed when they are within the spill area. The spill boundary must be verified by sampling and analysis. Solid, impenetrable surfaces (e.g., metals and impervious liners) may be decontaminated by a double wash/rinse. All decontamination must be verified by sampling and analysis, using bulk samples for porous materials and wipe samples for impenetrable surfaces.
All concentrated soils, solvents, rags, and other materials resulting from the cleanup of PCBs must be properly stored, labeled, and disposed of as PCB or PCB-contaminated materials. The containers of PCB wastes generated must be free of PCB contamination on all outside surfaces.
The PCB Spill Cleanup Policy for the EPA, Region IX, requires soils to be remediated to background levels (i.e., detection limits), where practicably attainable, of any PCB spill from a source greater than 50 ppm PCBs. In certain cases, the EPA, Region IX, will consider alternative cleanup levels. Cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 allows deviation from the Regional Policy when the reason for deviation is included in the Record of Decision (ROD). The ROD should have the concurrences of the EPA Pesticides and Toxics Branch Chief and the Toxics and Waste Management Division Director.
Spill reports (both verbal and written) must be completed only by the EPD personnel and are required to contain the following information:
A number of agencies are potentially interested in spills of PCBs depending on the spill concentration, quantity, and location. Spill reports must be reported a soon as possible and within the 24-hour legal requirement. Table C-1 (below) summarizes the reporting requirements and notes where written reports are also required.
The waste polychlorinated biphenyls (PCB) packaging and storage requirements are presented here only as guidance.
Toxic Substances Control Act (TSCA) regulations defer to U. S. Department of Transportation (DOT) requirements for container specifications. Packaging PCBs vary on the type of PCB and mode of transportation. New U. S. Department of Energy (DOE) Performance Oriented Packaging (POP) will be effective after September 1996.
Until September 1996, acceptable containers for the storage and transportation of liquid PCBs include:
Until September 1996, acceptable containers for the storage and transportation of non-liquid PCBs include:
The container must be sealed, and the sides and top of the container must be free of PCB contamination. The appropriate, standard PCB label must be affixed to the out-side of the container. In addition, the container must con-form to DOT packaging requirements.
PCB Items, PCB storage areas, and PCB transport vehicles must be clearly marked with the appropriate labels indicating the presence of PCBs. The large PCB label is most often required by the regulations. A smaller label is also available for smaller items. The label must be placed in a position clearly visible by any person servicing or inspecting the item, storage area, or transport vehicle. If PCB Items are discovered that are not labeled, they must be labeled as soon as possible. Labels are available through Central Supply. In addition to PCB labels and the date of removal from service, Resource Conservation and Recovery Act (RCRA), and DOT labeling requirements may be required. Certain PCB wastes will require a manifest and a proper DOT shipping name and container. The U. S. Environmental Protection Agency (EPA), DOT, and California regulations should be consulted for proper labeling instructions.
The following items may be stored in Waste Accumulation Areas (WAAs) for up to 30 days from the date of their removal from service, provided that a notation is attached to the PCB Item or PCB Container indicating the date that the item was removed from service:
PCB Containers that have PCBs at a concentration less than 50 ppm may be stored in WAAs for up to 90 days from the date of their removal from service. A notation must be attached to the PCB Item or PCB Container indicating the date that the item was removed from service and that the liquids in the container do not exceed 50-ppm PCBs. PCB-contaminated Electrical Equipment that has been drained of free-flowing dielectric fluid may be stored in WAAs for up to 90 days from the date of their removal from service.
Storage of PCB liquid with a concentration of 500 ppm or more in a WAA is prohibited.
No item or movable equipment that is used for handling PCBs and PCB Items in the WAA and that comes into direct contact with PCBs shall be removed from the storage facility area unless it has been decontaminated by swabbing contaminated surfaces that have contacted PCBs with a cleaning agent. The cleaning agent must contain less than 50-ppm PCBs, and the solubility of PCBs in the cleaning agent must be more than 5-percent weight.
All PCB Articles and PCB Containers stored in the WAA must be visually checked for leaks at least once every 30 days.
PCB Articles and PCB Containers can be stored at a permitted storage facility for up to one year from the date they were first placed in storage before disposal but should be shipped to an approved disposal facility within nine months of removal from service. The facility must operate under either a California hazardous waste permit or interim status document. Facilities used to store PCBs must meet the following criteria:
No item or movable equipment that is used for handling PCBs and PCB Items in the storage facilities and that comes into direct contact with PCBs shall be removed from the storage facility area unless it has been decontaminated by swabbing contaminated surfaces that have contacted PCBs. The cleaning agent must contain less than 50-ppm PCBs, and the solubility of PCBs in the cleaning agent must be more than 5-percent weight.
All PCB Articles and PCB Containers in storage must be visually checked for leaks at least once every 30 days.
PCB-contaminated Electrical Equipment and large, high-voltage PCB Capacitors that are non-leaking and structurally undamaged and that have not been drained of free-flowing dielectric fluid, may be stored on pallets next to the permitted storage facility. This storage outside the facility is only allowed when the immediately available, unfilled space in the storage facility is less than 10 percent of the volume of the capacitors and equipment stored outside the facility. The capacitors and equipment temporarily stored outside the facility must be checked weekly for leaks.
Polychlorinated biphenyls (PCB) disposal requirements are presented here as guidance.
PCB or PCB-contaminated Items must be disposed of within one year from when the item is declared a waste or is no longer in service. PCB and PCB-contaminated Items stored for disposal must be stored in a Toxic Substances Control Act (TSCA)-approved storage area and should be shipped to an approved disposal facility within nine months of removal from service. The disposal options for bulk PCBs and PCB Articles are given in Table E-1 and Table E-2 .
Where PCBs or PCB Items are mixed with, contained in, or contaminated with Resource Conservation and Recovery Act (RCRA) hazardous waste, disposal may also be subject to the RCRA land disposal restrictions.
PCB or PCB Items that are contaminated with radioactive constituents are regulated by the Atomic Energy Act and applicable U. S. Department of Energy (DOE) Orders as well as TSCA; therefore, disposal may also be subject to stricter requirements.
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