Background
Polychlorinated biphenyls (PCBs) were the only class of chemicals specifically named in the Toxic Substances Control Act of 1976 (TSCA). TSCA prohibited the manufacture of PCBs, phased out existing uses, and required that disposal of PCBs follow specific procedures.
Environmental Protection Agency (EPA) regulations that implement the requirements of TSCA for PCBs are in 40 CFR Part 761. The first PCB regulations date to 1978, but there have been frequent revisions. In June 1998, the EPA published a major change to the PCB regulations, specifying requirements for PCB disposal.
In summary, TSCA details requirements for
- identification and classification of PCBs and PCB items;
- continued use of PCBs and PCB items, including requirements for labeling, inspection, and spill prevention;
- use of PCBs use near food or animal feed;
- use and burning of used oil containing PCBs;
- levels of equipment servicing that mandate disposal of PCBs and PCB items;
- PCB spill clean-up policy, including targets for contamination removal;
- management of PCB oils, items in storage, and the design specifications for storage areas;
- manifesting of PCB wastes;
- regulations concerning worker protection;
- options for decontamination and reuse options for some PCB items;
- waste disposal; and
- record keeping and reporting.
Key Concepts
Polychlorinated Biphenyls (PCBs)
PCBs are a family of over 200 organic compounds. They vary from mobile, oily liquids to white solids, or resins. PCBs demonstrate a high degree of chemical stability, high boiling points, low flammability, and low electrical conductivity. These properties made PCBs attractive for many high-temperature and electrical insulating applications. However, these same properties cause PCBs to remain in the environment for a long time. PCBs accumulate throughout the food chain, and EPA considers them carcinogens.
PCB Classifications
Regulation of PCBs and PCB-containing materials derives from the concentration of PCBs in a material. Below 50 parts per million PCBs, the material is “non-PCB.” Between 50 and 500 parts per million PCBs, the material is “PCB-contaminated.” Above 500 parts per million PCBs, the material is a PCB.
PCBs and PCB Items
The EPA has different regulations for pure PCBs and objects that contain PCBs.
Hazardous Waste
PCBs are not hazardous waste under federal regulations, although many of the management requirements are similar to those for hazardous wastes. Some states, however, choose to include PCBs in their Resource Conservation and Recovery Act (RCRA) hazardous waste programs. Therefore, management and disposal of PCBs in these states are subject to requirements of both TSCA and RCRA.
PCBs and PCB-Containing Equipment Use and Disposal
Before federal limitations were put on PCB production and use, PCBs were widely used in various types of equipment. Managing and disposing of this equipment may be subject to a portion of the numerous TSCA requirements.
PCB Spill Clean-Up Policy
In 1985, EPA prepared comprehensive instructions for remediation of PCB spills. EPA expects that facility owners will respond to all releases of PCBs using these instructions.
PCB Caulk
Some types of high-performance caulk contained PCBs. Some EPA regions consider that some circumstances where PCBs have migrated from caulk to concrete meet the definition of a spill and require compliance with the PCB spill clean-up policy.
Does this apply to my campus?
Yes. With very few exceptions, campuses are subject to some of the TSCA PCB requirements.
What do I have to do?
Inventories of PCB transformers and large capacitors (with oils containing PCBs in concentrations exceeding 500 parts per million) were due to the EPA and local fire departments in 1985. You must verify this inventory annually and maintain it onsite.
TSCA management requirements for PCBS vary with type, use, and location of equipment, as well as concentration of PCBs and proximity to food or animal feedstocks. Campuses should become familiar with the management requirements for their particular uses of PCBs. EPA has requirements for
- PCB item labeling,
- disposal schedule,
- spill prevention,
- inspection of PCB items, and
- storage areas.
Both past and recent spills of PCBs are subject to the PCB clean-up policy. Get specific guidance for addressing PCB releases or spills. Note that EPA regions are turning more attention to PCB caulk and PCB migration to adjoining building materials.
Also, TSCA has specific requirements for the disposal of PCBs and PCB items (see the nearby tables for more detailed guidance).
Campuses conducting research on PCBs must ensure that both the procurement of the PCBs and the actual research take place according to specific requirements for spill control, storage, and disposal. These requirements apply to use of PCBs as a reference sample or PCB-contaminated soils or sludge.
Identifying all PCBs and PCB items on campus is an essential step toward reducing the risks associated with PCBs. Most, if not all, of the above requirements require knowledge of what campus equipment contains PCBs. Oil testing, verification of equipment components with manufacturers, investigating historical spills, and wipe testing are part of this identification process.
Fluorescent light ballasts are one of the largest sources of PCB wastes from a campus. Although the PCB regulations allow for disposal of ballasts and some small capacitors in local landfills, EPA recommends recycling as a preferential disposal protocol. Note that using a local landfill for disposal may involve reporting requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA; see CERCLA — Spills).