PCBs (Polychlorinated Biphenyls)

Federal Regulation 40 CFR Part 761
State Regulation 10 CSR 25-13

EXCECUTIVE SUMMARY
The Environmental Protection Agency (EPA) is authorized to regulate the use, storage, and disposal of items with PCB concentrations ≥50 ppm under the Toxic Substances Control Act (TSCA). In addition, the Missouri Department of Natural Resources (DNR) regulates the disposal of low concentration PCBs (≥2 ppm, but ≤49 ppm). For facilities that meet the record keeping criteria, all annual records and the written annual document log of the disposition of the PCBs and PCB Items must be prepared for each facility by July 1 covering the previous calendar year. PCB wastes stored inside an approved PCB storage facility must be disposed of within nine (9) months from the date it was determined to be a PCB waste. PCB Items in temporary storage (i.e., outside of a PCB storage facility) must be disposed of within 30 days from the date it was removed from service. PCB storage facilities must be inspected monthly, while temporary storage facilities must be inspected at least weekly. Testing, marking, and labeling requirements are described below.

PCB Q&A Manual
Sample PCB Handling Flowchart

DEFINITIONS
Decommissioned: an item that is not currently in use and is being evaluated for future use.

Leak or leaking: any instance in which a PCB Article, PCB Container, or PCB Equipment has any PCBs on any portion of its external surface.

Low-concentration PCB: containing PCBs at concentrations ≥ 2ppm, but ≤49 ppm.

PCB Article: any manufactured article, other than a PCB Container, that contains PCBs and whose surfaces(s) has been in direct contact with PCBs. “PCB Article” includes, but is not limited to, capacitors, transformers, electric motors, pumps, and pipes.

PCB Container: any package, can, bottle, bag, barrel, drum, tank, or other device that contains PCBs or PCB Articles and whose surface(s) has been in direct contact with PCBs.

PCB-Contaminated: a non-liquid material containing PCBs at concentrations ≥50 ppm but < 500 ppm; a liquid material containing PCBs at concentrations ≥50 ppm but < 500 ppm or where insufficient liquid material is available for analysis, a non-porous surfacing having a surface concentration >10 µg/100 cm2 but < 100 µg/100 cm2, measured by a standard wipe test as defined in §761.123.

PCB Equipment: any item (e.g., capacitors, transformers, regulators, bushings) that contains ≥500 ppm PCB.

Removed from Service: an item that is currently not in use, is being evaluated for future use, has had a PCB test sample taken, and is awaiting results.

Returned to Stock: an item that is currently not in use that will be stored for reuse.

Spill: both intentional and unintentional spills, leaks, and other uncontrolled discharges where the release results in any quantity of PCBs (≥50 ppm) running off or about to run off the external surface of the equipment or other PCB source, as well as the contamination resulting from those releases.

Stored for Disposal: a PCB-contaminated item or PCB item that has been evaluated and determined will be disposed of by a permitted Treatment, Storage, and Disposal Facility (TSDF).

PCB STORAGE FACILITY CRITERIA
Any facility used for the storage of PCBs and PCB Items designated for disposal shall comply with the following storage unit requirements:

  • Adequate roof and walls to prevent rain water from reaching stored PCBs and PCB Items;
  • Adequate floor that has continuous curbing with a minimum of 6 inch high curb;
  • Floor and curbing must provide a containment volume equal to at least two times the internal volume of the largest PCB Article or PCB Container or 25 percent of the total internal volume of all PCB Articles or PCB Containers stored there, whichever is greater.
  • No drain valves, floor drains, expansion joints, sewer lines, or other opening that would permit liquids to flow from the curbed area;
  • Floors and curbing must be constructed of Portland cement, concrete, or a continuous, smooth, non-porous surface;
  • Not located at a site that is below the 100-year flood water elevation;
  • Has an assigned EPA Identification number.

STORAGE FOR REUSE
A PCB Article may be stored indefinitely for reuse if the Article is stored inside an approved PCB storage facility. A PCB Article may be stored for reuse outside of an approved PCB storage facility for no more than five (5) years after the date the Article was originally removed from use (e.g., disconnected electrical equipment). PCB Articles stored for reuse must be labeled with the date that the Article was removed from service and the words “Stored for Stock” or “Stored for Reuse”.

STORAGE FOR DISPOSAL 
This section applies to the storage for disposal of PCBs and PCB Items at concentrations of 50 ppm or greater. Any PCB waste must be stored inside an approved PCB storage facility and disposed of within nine (9) months from the date it was determined to be a PCB waste and the decision was made to dispose of it. A PCB Item may be stored temporarily outside of a PCB storage facility for up to 30 days from the date it was removed from service. PCB Items must be labeled with the date that it was removed from service and the words “Stored for Disposal”.

MARKING & LABELING REQUIREMNETS
PCB Articles, PCB Equipment, PCB Containers, and PCB storage areas must be marked following the format further described in 40 CFR 761.45. The large PCB mark must be durable, sized at least 6 inches x 6 inches, and have letters and striping on a white or yellow background.  Marks must be placed in a position on the exterior of the PCB Items or storage units so that the marks can be easily read by any person inspecting or servicing the marked PCB Items or storage units. In addition, all means of access, other than grates and manhole covers, to PCB storage areas and PCB Equipment must be marked (e.g., doorways, substation fences, hallways).  

PCB Containers must be labeled with a unique container identification number, the accumulation start date (i.e., the date when the first PCB Item was placed in the container), and a description of container contents.

PCB Articles stored for reuse must be labeled with the date that the Article was removed from service and the words “Stored for Stock” or “Stored for Reuse”.

PCB Items stored for disposal must be labeled with the date that it was removed from service and the words “Stored for Disposal”. It is recommended that words such as, “bad’ or “junk” are not written on any equipment or tags at any time for any reason.

It is recommended that any decommissioned item that is be evaluated for reuse or disposal be labeled with the words: “Removed from Service” and the corresponding date; “Tested by” and the corresponding name; and “From” and the corresponding name of the facility/substation where the item originated.

TESTING 
It is recommended that a PCB test sample is taken at the time an item is removed from service or decommissioned. If test results indicate that an item contains PCBs at a concentration ≥50 ppm, it is recommended that that item be stored for disposal. 

To comply with applicable U.S. Department of Transportation (DOT) requirements, PCB samples being sent to a laboratory for analysis must have the following accompanying information: sample collector’s name, mailing address, and telephone number; laboratory’s name, mailing address, and telephone number; quantity of the sample; date of shipment; and description of sample. In addition, the sample should be packaged so that it does not leak, spill, or vaporize from its packaging.

EQUIPMENT INSPECTIONS 
All PCB Items stored for disposal inside an approved PCB storage facility must be inspected for leaks once every 30 days. All PCB Items temporarily stored for disposal outside of a PCB storage facility must be inspected for leaks at least once per week. Leaking PCB Items and their contents must be immediately placed in a non-leaking properly marked PCB Container (i.e., must be placed inside double containment) that has sufficient sorbent materials.

SPILLS AND LEAKS 
The EPA has established criteria to use to determine the adequacy of the cleanup of spills resulting from the release of materials containing ≥50 ppm PCBs. Due to state regulations, it is recommended that low concentration PCB spills be cleaned up and disposed of in the same manner as ≥50 ppm PCB materials. If a spill of untested oil occurs, the oil is presumed to contain >50 ppm, but <500 ppm PCBs.

Cleanup methods must be applied to the entire spill area. The spill area includes any surface or object (e.g., soil or concrete pad) on which visible traces of the spill can be observed plus a buffer zone of one (1) foot beyond the visible traces. The minimum requirement to cleanse solid surfaces (both impervious and non-impervious) is to perform a double wash/rinse with an appropriate solvent or other material in which PCBs are at least five (5) percent soluble (by weight). Equipment (e.g., shovels) used in the cleanup process should also be cleansed using the double wash/rinse method.  

EPA has developed a number of guidance documents to assist with managing, cleaning up, and disposing of PCB wastes and PCB-contaminated materials. These documents can be found at the following links:

DISPOSAL OF PCB-CONTAMINATED WASTES
At the time of disposal you must know the equipment’s PCB concentration and must be able to produce a PCB test record. Wastes with PCB concentrations ≥50 ppm cannot be disposed of in any sanitary, demolition, utility waste, or special waste landfill in Missouri. These wastes should be manifested using EPA’s Uniform Hazardous Waste Manifest and sent to a PCB-permitted facility for disposal.

Low concentration PCB used oil should be recycled or sent to a PCB-permitted facility for disposal using Missouri waste code D096 on the shipping paper or manifest. Low concentration PCB equipment should also be sent to a PCB-permitted facility for disposal.   

RECORDKEEPING  
A facility that uses or stores at any one time at least 45 kilograms (99.4 pounds) of PCBs contained in PCB Container(s), or one or more PCB Transformers (i.e., transformers ≥500 ppm PCBs), or 50 or more PCB Large High or Low Voltage Capacitors must develop and maintain all annual records and the written annual document log of the disposition of the PCBs and PCB Items. The written annual document log must be prepared for each facility by July 1 covering the previous calendar year. The annual document log is a document that details an inventory of PCB Items in use, stored for stock, stored for disposal, and items disposed of during each calendar year. If a facility uses or stores PCBs below the above listed threshold, it is recommended that the facility annually document that this record keeping requirement is not required.

The annual records must include the following:

  • All signed shipping manifests generated by the facility during the calendar year.
  • All Certificates of Disposal that have been received by the facility during the calendar year.
  • Records of all inspections and cleanups performed.

The written annual document log must include the following:

  • The name, address, and EPA identification number of the facility covered by the annual document log.
  • The calendar year covered by the annual document log.
  • For each PCB Item, include the following information: the serial number or unique container identification number; the weight in kilograms of the PCB waste; the date it was removed from service for disposal; the date it was placed in transport for off-site storage or disposal; and the date of disposal, if known.
  • The total number and total weight in kilograms of any PCBs, PCB Items, PCB Transformers, Large High or Low Voltage PCB Capacitors remaining in service at the end of the calendar year.
  • Summary page with total numbers and weights of specific PCB Items.  

Additional records that should be maintained for each facility include PCB test results and retrofill and reclassification records. Records should be maintained indefinitely.

 

Rob LeForce, AECI, revised 8/12/2015