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If you are looking for information about how to manage PCBs (polychlorinated biphenyls), commonly used in electrical transformers and capacitors, the you have come to the right place. These pages are also being updated to include the latest options now available under the PCB Megarule (June 29, 1998 Federal Register). (or download the PCB megarule here) and subsequent updates Be sure to check the Mega-rule for changes, like the December 28, 1998 notification deadline! If you have any questions, or need guidance managing or disposing of PCB wastes in compliance, just just click on feedback to contact us!
This document provides guidance on:
PCB-containing materials are classified in the regulations ccording 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.
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.
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.
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.
no provision specifying a PCB concentration may be avoided as a result of any dilution, unless specifically provided (40 CFR 761.1[b]).
a device for accumulating and holding a charge of electricity and consisting of conducting surfaces separated by a dielectric.
a fluid with the electrical conductivity less than a millionth of a mho. Essentially, a dielectric fluid is a fluid which does not conduct electricity.
a device that electrically controls fluorescent light fixtures and that includes a capacitor containing 0.1 kg (0.2 lb) or less of dielectric fluid.
a capacitor containing 1.36 kg (3 lb) or more of dielectric fluid and that operates at or above 2000 V (ac or dc).
a capacitor containing 1.36 kg (3 lb) or more of dielectric fluid and that operates below 2000 V (ac or dc)
any instance in which a PCB Article, PCB Container, or PCB Equipment has any PCBs on any portion of its external surface.
abbreviation for polychlorinated biphenyl. Includes any chemical substance limited to the biphenyl molecule (see sample at right) that has been chlorinated to varying degrees, or any combination of substances that contain such a substance.
a written log of documents detailing the disposition of PCBs and PCB Items. The annual log includes a summary of the annual records and an inventory of PCB materials. The deadline for compiling the annual log is six months after the end of the calendar year (i.e., July 1). This log shall be retained for at least three years after PCBs are reduced below regulated quantities.
includes all documentation relative to the acquisition or disposal of PCBs over a 12-month period. This documentation includes purchase orders, manifests, certificates of disposal, and inadvertent generation reports. Annual records must be maintained for the same period as the annual log.
any manufactured article, other than a PCB Container, that contains PCBs and whose surfaces have been in direct contact with PCBs. It includes capacitors, transformers, electric motors, pumps, pipes, and any other manufactured item (1) that is formed to a specific shape or design during manufacture, (2) whose end-use function is dependent in whole or in part on its shape or design during end use, and (3) that has experienced either no change of chemical composition during its end use or only those changes of composition that have no commercial purpose separate from that of the PCB Article.
any package, can, bottle, bag, barrel, drum, tank, or other device used to contain PCB Articles or PCB Equipment and whose surfaces have not been in direct contact with PCBs.
any package, can, bottle, bag, barrel, drum, tank, or other device that contains PCBs or PCB Articles and whose surfaces have been in direct contact with PCBs.
any substance or material containing between 5 and 500 ppm PCB. Toxic Substances Control Act regulations for PCB-contaminated materials apply to materials containing between 50 and 500 ppm PCBs. For waste disposal, the state of California hazardous waste regulations apply to all materials containing more than 5 ppm PCBs.
any electrical equipment that contains PCBs, including, but not limited to, transformers, capacitors, circuit breakers, reclosers, voltage regulators, switches, electromagnets, and cable.
any manufactured item, other than a PCB Container or a PCB-Article Container, that contains a PCB Article or other PCB Equipment.
any PCB Article, PCB-Article Container, PCB Container, or PCB Equipment that deliberately or unintentionally contains or has as part of it any PCB or PCBs.
any transformer that contains 500 ppm PCBs or more.
For purposes of this guidance, any PCB or PCB Item that is no longer in use or stored for use or reuse.
parts per million by weight. Unit of concentration of PCBs expressed as milligrams per kilogram (mg/kg).
a capacitor containing less than 1.36 kg (3 lb) of dielectric fluid. When the amount of dielectric fluid is not known, the following capacitors can be assumed to be small: (1) capacitors whose total volume is less than 1639 cubic centimeters and (2) capacitors with a total volume between 1639 and 3278 cubic centimeters and a total weight of less than 4.08 kg (9 lb).
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).
|A unique identification number (serial number) for each PCB Article, PCB Container and PCB-Article Container|
|PCB weight (kg)|
|Date removed from service|
|Date placed in transport|
|Date of disposal, if known
Report of PCB Manufacturing Process
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.
PCB Waste Manifest Exception Reports
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:
|Date(s) when the PCBs or PCB Items were removed from service|
|Date(s) when the PCBs or PCB Items were received by the submitter, if applicable|
|Date(s) when the PCBs or PCB Items were transferred to a designated disposal facility|
|Identity of the transporters, storage facilities, and disposal facilities known to be involved with the transaction|
|Reason, if known, for the delay in bringing about the disposal of the PCBs within one year from the date of removal from service.
Notification of PCB Waste Activity
Your company should file a Form 7710-53 with the EPA prior to using, storing, etc. PCBs..
PCB Spill Cleanup Records
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:
Equipment Inspection Logs
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.