Polychlorinated biphenyls (PCBs) range in consistency from heavy oily liquids to waxy solids. Prior to 1979, PCBs were widely used in electrical equipment such as transformers, capacitors, switches, fluorescent lamp ballasts, electromagnets and voltage regulators. Their popularity derived from the fact that they do not readily burn or conduct, but rather only boil at high temperatures. They also do not readily react with other chemicals.
The EPA regulates PCBs through the federal Toxic Substance Control Act (TSCA), which categorizes the management and disposal of PCB-containing fluids into three groups:
- Greater than 500 parts per million (ppm) PCBs (PCB-containing)
- Between 50 and 500 ppm (PCB-contaminated)
- Less than 50 ppm (non-TSCA regulated)
PCB waste that is generated by residents on the premises of a temporary or permanent residence for individuals (including multi-unit construction), and that is composed primarily of materials found in wastes generated by consumers in their homes is considered PCB household waste. PCB household waste managed in a permitted solid waste facility or PCB bulk waste approved facility is not subject to any other TSCA provisions.
Among the aspects of PCB-containing materials governed by TSCA are:
- Spill-related incident reporting
- Fire-related incident reporting
- Cleanup requirements
- Recordkeeping and reporting
- Proper disposal
In the residential life facilities of your college or university, small capacitors in fluorescent light ballasts are a leading source of PCBs. Light ballasts are the primary electrical components of fluorescent light fixtures, and they are generally located within the fixture under a metal cover plate. The ballast units are generally composed of a transformer to reduce the incoming voltage, a small capacitor (which may also contain PCBs) and a small thermal cut-off switch and/or safety fuse. These components are surrounded by a tar-like substance, which is designed to muffle the noise that is inherent in the operation of the ballast. When a ballast unit fails, excessive heat can be generated, which may melt or burn the tar material, creating a characteristic foul odor.
Labels are required not only on in-use or stored PCB-containing equipment (except for small capacitors), but also at the storage areas used for PCB wastes and in access areas to any PCB transformers. Any large low-voltage capacitor, small capacitor used in alternating-current circuits or fluorescent light fixture ballast manufactured between July 1, 1978, and July 1, 1998, that does not contain PCBs must be marked by the manufacturer with the words, "No PCBs," in accordance with 40 CFR Part 761.40(g). Other than on transformers, manufacturers' markings should enable the consumer to differentiate between items that contain PCBs and those that do not.
The regulations stipulate that the storage area for PCB items must meet specific design criteria and that these items must be removed from storage for disposal within nine months and must be destroyed within one year. An area used to store items containing PCBs of 50 ppm or greater prior to disposal must meet the criteria specified in 40 CFR Part 761.65(b). This regulation addresses the requirements for adequate roofing and walls, impervious floors with curbing, restrictions on openings, adequate containment and a location above the 100-year flood plain. However, certain PCB items may be stored temporarily in areas meeting the requirements under 40 CFR 761.65(c).
TSCA recordkeeping provisions require that owners maintain information about the weight of the PCBs; the identification of PCB-containing items; the dates of storage, transfer and disposal; and the names of shippers and receivers. The generator (owner) is responsible for manifesting all PCB containers shipped off-site for disposal, for verifying that PCB containers have been disposed of properly and for maintaining a signed copy of the manifest. Certificates of disposal alone are not sufficient. If the generator stores at least 45 kgs of PCBs in a PCB container or, one or more PCB transformers, or 50 or more large high- or low-voltage PCB capacitors, then an annual document log of required records (e.g., manifests, certificates of disposal, inspection and cleanup records) must be maintained. (40 CFR 761.180)
Spill Cleanup and Reporting Requirements
The TSCA PCB cleanup and spill reporting requirements are complicated and difficult to summarize because they may vary according to the source, volume and location of a spill. It is recommended that facilities refer to the TSCA PCB regulations before taking any spill cleanup and reporting actions.
According to TSCA's reporting requirements for PCB spills at concentrations of 50 ppm or greater, cleanup must be documented with sampling records and certification, and the documentation must be maintained for five years (40 CFR Part 761.125). Depending on the location and/or volume of spilled material, certain spills must have cleanup initiated and be reported to EPA as soon as possible and within either 24 or 48 hours. For example, for PCB Transformer leaks, cleanup must be initiated as soon as possible and within 48 hours of discovery. Any TSCA PCB reporting requirements are in addition to reports required under other applicable environmental laws, such as the Clean Water Act and the Comprehensive Environmental Response, Compensation, and Liability Act.
For the complete text of regulations (40 CFR 761), click here:
40 CFR 761