Introduction
Prohibitions and requirements for handling polychlorinated biphenyls (PCBs) and PCB-containing items are contained in Title 40 Code of Federal Regulations (CFR) Part 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions. These federal regulations are promulgated under Sec. 6(e) of the Toxic Substances Control Act (TSCA) [15 USC 2605]. Title 40 CFR Part 761, most recently amended in June 1998, governs the manufacture, processing, distribution, use, marking, storage, disposal, cleanup, and release reporting requirements for PCBs. The amended regulations, intended by the Environmental Protection Agency (EPA) to be "deregulatory" in nature, provide individuals with more flexibility in their PCB disposal practices, while continuing to provide protection from unreasonable risk to human health and the environment. These recent amendments deleted out-of-date regulations and brought EPA's PCB policies and regulations into agreement with other federal requirements. This fact sheet focuses on key components of the PCB management provisions in Title 40 CFR Part 761 including release reporting, cleanup, marking, and disposal requirements. It also provides a summary of other federal laws and regulations governing PCB management, as well as a discussion of PCB elimination efforts within the Air Force.
Background
Polychlorinated biphenyls (PCBs) are a group of 209 fat-soluble organic compounds with a biphenyl molecule (basically two benzene molecules attached together) with chlorine atoms attached at varying locations. PCBs are also known as arochlors and chlorodiphenyls. Some references to specific PCB compounds include the percentage makeup of chlorine in the molecule; for example, Arochlor-1242 and Arochlor-1254 contain 42 and 54 percent chlorine by weight, respectively.
PCBs are stable compounds that break down very slowly in the environment. PCBs can bioaccumulate in the fatty tissue of fish, birds, and mammals after entering through the lungs, skin, or gastrointestinal tract. They are suspected human carcinogens and have been shown to be teratogenic (i.e., capable of inducing mutations in the offspring of affected organisms).
At one time PCBs were common components of hydraulic fluids, lubricants, heat transfer fluids, and insecticides. PCBs were primarily manufactured as dielectric fluid for transformers and capacitors because of their ability to absorb heat, low flammability, low electrical conductivity, and favorable dielectric constant. Currently, heat transfer fluids residing in old transformers and capacitors used in power distribution systems are the main sources of PCBs. There may also be PCB-contaminated soil in places where transformers and capacitors have been stored or serviced, transformer fires have occurred, or PCBs have been sprayed as insecticides. Non-Liquid PCBs (NLPCBs) can be found in various items such as fluorescent light ballast potting material, ceiling tile coatings, and certain painted surfaces.
Important Terms
[The following definitions are adapted from Title 40 CFR 761.3 and 761.123, are not all-inclusive, and in some instances may be paraphrased. Readers should carefully review the entire regulation for more detailed explanations of terminology.]
Double Wash/Rinse - A minimum requirement to clean solid surfaces (impervious and non-impervious) two times with an appropriate solvent (kerosene, toluene, or xylene) or other material in which PCBs are at least 5 percent soluble (by weight).
High-Concentration PCBs - PCB-containing materials containing 500 parts per million (ppm) or greater PCBs, or those materials required by EPA, in the absence of testing, to be assumed to contain 500 ppm or greater PCBs.
High-Contact Industrial Surface - A surface in an industrial setting which is repeatedly touched, often for relatively long periods of time. Manned machinery and control panels are examples of high-contact industrial surfaces. High-contact industrial surfaces are generally of impervious solid material. Examples of low-contact industrial surfaces include ceilings, walls, floors, roofs, roadways and sidewalks in the industrial area, utility poles, unmanned machinery, concrete pads beneath electrical equipment, curbing, exterior structural building components, indoor vaults, and pipes.
High-Contact Residential/Commercial Surface - A surface in a residential/commercial area that is repeatedly touched, often for relatively long periods of time. Doors, wall areas below 6 feet in height, uncovered flooring, windowsills, fencing, banisters, stairs, automobiles, and children's play areas such as outdoor patios and sidewalks are examples of high-contact residential/commercial surfaces. Examples of low-contact residential/commercial surfaces include interior ceilings, interior wall areas above 6 feet in height, roofs, asphalt roadways, concrete roadways, wooden utility poles, unmanned machinery, concrete pads beneath electrical equipment, curbing, exterior structural building components (e.g., aluminum/vinyl siding, cinder block, asphalt tiles), and pipes.
High Occupancy Area - Any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual not wearing dermal and respiratory protection for a calendar year is: 840 hours or more (an average of 16.8 hours or more per week) for non-porous surfaces and 335 hours or more (an average of 6.7 hours or more per week) for bulk PCB remediation waste.
Impervious Solid Surfaces - Solid surfaces that are nonporous and unlikely to absorb spilled PCBs. These include metals, glass, aluminum siding, and enameled or laminated surfaces.
Low-Concentration PCBs - PCB-containing materials that are tested and found to contain less than 500 ppm PCBs or those materials that EPA requires, in the absence of testing, to be assumed to be at concentrations below 500 ppm (e.g., mineral oil dielectric fluid [MODEF]).
Low Occupancy Area - Any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual not wearing dermal and respiratory protection for a calendar year is: less than 840 hours (an average of 16.8 hours per week) for non-porous surfaces and less than 335 hours (an average of 6.7 hours per week) for bulk PCB remediation waste.
Non-Impervious Solid Surfaces - Solid surfaces that are porous and are likely to absorb spilled PCBs. These include wood, concrete, asphalt, and plasterboard.
Non-Liquid PCBs - Materials containing PCBs that by visual inspection do not flow at room temperature (25 øC or 77 øF) or from which no liquid passes when a 100 gram or 100 milliliter representative sample is placed in a mesh number 60TM 5 percent paint filter and allowed to drain at room temperature for 5 minutes.
Non-PCB Transformer - Any transformer containing less than 50 ppm PCBs in its dielectric fluid.
Nonrestricted Access Areas - Any area other than restricted access, outdoor electrical substations, and other restricted access locations. In addition to residential/commercial areas, these areas include unrestricted access rural areas (areas of low-density development and population where access is uncontrolled by either man-made barriers or naturally occurring barriers, such as rough terrain, mountains, or cliffs).
Other Restricted Access (nonsubstation) Locations - Areas other than electrical substations that are at least 0.1 kilometer (km) from a residential/commercial area and access is limited by man-made barriers (e.g., fences and walls) or naturally occurring barriers such as mountains, cliffs, or rough terrain. These areas generally include industrial facilities and extremely remote rural locations. (Areas where access is restricted but are less than 0.1 km from a residential/commercial area are considered to be residential/commercial areas.)
Outdoor Electrical Substations - Outdoor, fenced-off, and restricted access areas used in the transmission and/or distribution of electrical power. Outdoor electrical substations restrict public access by being fenced or walled off. Outdoor electrical substations are defined as being located at least 0.1 km from a residential/commercial area. Outdoor fenced-off and restricted access areas used in the transmission and/or distribution of electrical power which are located less than 0.1 km from a residential/commercial area are considered to be residential/commercial areas.
PCB Article - Any manufactured article, other than a PCB Container, that contains PCBs and whose surface(s) has been in direct contact with PCBs. "PCB Article" includes capacitors, transformers, electric motors, pumps, pipes and any other manufactured item (1) which is formed to a specific shape or design during manufacture, (2) which has end use function(s) dependent in whole or in part upon its shape or design during end use, and (3) which has either no change of chemical composition during its end use or only those changes of composition which have no commercial purpose separate from that of the PCB Article.
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 Article Container - Any package, can, bottle, bag, barrel, drum, tank, or other device used to contain PCB Articles or PCB Equipment, and whose surface(s) has not been in direct contact with PCBs. Examples include shipping containers for PCB-containing capacitors and packages for PCB-containing light ballasts.
PCB Bulk Product Waste - Waste derived from manufactured products containing PCBs in a non-liquid state, at any concentration where the concentration at the time of designation for disposal was 50 ppm PCBs. PCB bulk product waste includes, but is not limited to:
- Non-liquid bulk wastes or debris from the demolition of buildings and other man-made structures manufactured, coated, or serviced with PCBs. PCB bulk product waste does not include debris from the demolition of buildings or other man-made structures that is contaminated by spills from regulated PCBs which have not been disposed of, decontaminated, or otherwise cleaned up in accordance with TSCA requirements.
- PCB-containing wastes from the shredding of automobiles, household appliances, or industrial appliances.
- Plastics (such as plastic insulation from wire or cable; radio, television and computer casings; vehicle parts; or furniture laminates); preformed or molded rubber parts and components; applied dried paints, varnishes, waxes or other similar coatings or sealants; caulking; adhesives; paper; Galbestos; sound deadening or other types of insulation; and felt or fabric products such as gaskets.
- Fluorescent light ballasts containing PCBs in the potting material.
PCB-Contaminated Electrical Equipment - Any electrical equipment including transformers, capacitors, circuit breakers, reclosers, voltage regulators, switches, etc. whose dielectric fluid contains 50 ppm, but less than 500 ppm PCBs. Levels at or above 500 ppm are not considered contaminated but PCB-containing.
PCB Equipment - Any manufactured item, other than a PCB container or PCB article container, which contains a PCB article or other PCB equipment, and includes microwave ovens, electronic equipment, and fluorescent light ballasts and fixtures.
PCB Item - Any PCB article, PCB article container, PCB container, or PCB equipment, that deliberately or unintentionally contains, or has as a part of it, any PCBs.
Liquid PCBs - a homogenous flowable material containing PCBs and no more than 0.5 percent by weight non-dissolved material.
PCB Transformer - Any transformer that contains 500 ppm or greater PCBs.
PCB Concentration Assumptions
PCB management under Title 40 CFR Part 761 is dependent upon the PCB concentration. Concentrations of PCBs in excess of 500 ppm face the most stringent regulatory requirements. Less restrictive requirements apply to concentrations of PCBs between 50 ppm and 500 ppm. Concentrations of PCBs below 50 ppm are generally not regulated. Title 40 CFR 761.2, PCB Concentration Assumptions for Use, provides guidance on when persons may assume a PCB concentration without testing. The assumptions are:
- Transformers with <3 pounds (1.36 kilograms [kg]) of fluid, circuit breakers, reclosers, oil-filled cable, and rectifiers whose PCB concentration is not established contain PCBs at <50 ppm.
- Mineral oil-filled electrical equipment that was manufactured before July 2, 1979, and whose PCB concentration is not established is PCB-Contaminated Electrical Equipment (contains 50 ppm PCB, but <500 ppm PCB). All pole-top and pad-mounted distribution transformers manufactured before July 2, 1979 must be assumed to be mineral oil filled. Any person may assume that electrical equipment manufactured after July 2, 1979, is non-PCB (<50 ppm PCBs). If the date of manufacture of mineral oil-filled electrical equipment is unknown, it must be assumed to be PCB-contaminated.
| The assumption policies outlined do not apply when electrical equipment is being disposed of. At that time, the owner or operator of PCB equipment must know its actual PCB concentration and use the proper disposal method. 63 Federal Register (FR), Number 124, Page 35389. |
- A transformer manufactured prior to July 2, 1979, that contains 3 lbs. (1.36 kgs) or more of fluid other than mineral oil and whose PCB concentration is not established, is a PCB Transformer (>500 ppm). If the date of manufacture or the type of dielectric fluid is unknown, any person must assume the transformer to be a PCB Transformer.
- A capacitor manufactured prior to July 2, 1979 whose PCB concentration is not established contains 500 ppm PCBs. Any person may assume that a capacitor manufactured after July 2, 1979, is non-PCB (<50 ppm PCBs). If the date of manufacture is unknown, any person must assume the capacitor contains 500 ppm PCBs. Any person may assume that a capacitor marked at the time of manufacture with the statement "No PCBs" in accordance with the requirements of 40 CFR Part 761 is non-PCB.
The above assumptions allow PCB program managers to implement management actions by adopting the concentration assumption and implementing the action without further, and possibly costly, analytical tests. The decision to adopt an assumed concentration should also consider the cost benefit of performing analytical testing to determine if the actual PCB concentration requires implementation of costly use and disposal procedures. In some cases, a permanent label, mark, or other documentation from the manufacturer of the equipment indicating its PCB concentration at the time of manufacture or service records or other documentation indicating the PCB concentration of all fluids used in servicing the equipment since it was first manufactured, are sufficient evidence of PCB concentration.
PCB Marking Requirements
PCB and PCB-contaminated items and articles are subject to very specific marking requirements under Title 40 CFR Part 761. These requirements generally apply to PCB containers, large high and low voltage capacitors, electric motors, hydraulic systems, transformers and PCB article containers. Additionally, there are marking requirements for transport vehicles that convey PCB containers. The marking requirements are triggered based on type of equipment and date of manufacture and are outlined in Title 40 CFR 761, Subpart C, Marking of PCB and PCB Items.
PCB Spill Reporting Requirements
Spill reporting requirements for hazardous substances are addressed under several laws and regulations. For PCBs, reporting requirements are provided in Title 40 CFR 761.125, (TSCA) Requirements for PCB Spill Cleanup, Title 40 CFR Part 355, (EPCRA) Emergency Planning and Notification, and Title 40 CFR Part 302, (CERCLA) Designation, Reportable Quantities, and Notification. "Spill" is defined in Title 40 CFR 761.123 as "both intentional and unintentional spills, leaks, and other uncontrolled discharges where the release results in any quantity of PCBs 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. This policy applies to spills of 50 ppm or greater PCBs. The concentration of PCBs spilled is determined by the PCB concentration in the material spilled as opposed to the concentration of PCBs in the material onto which the PCBs were spilled. Where a spill of untested mineral oil occurs, the oil is presumed to contain greater than 50 ppm, but less than 500 ppm PCBs and is subject to the relevant requirements of this policy." Specific reporting requirements are summarized below:
Title 40 CFR 761.125 (TSCA regulations):
Notify the National Response Center (NRC) (800-424-8802) if a spill of 1 pound or more of PCBs occurs. Notify the EPA Regional Office, Office of Prevention, Pesticides, and Toxic Substances Branch, if: 1) any amount of PCBs contaminates surface waters, sewers, drinking water supplies, grazing land, or vegetable gardens; or 2) more than 10 pounds of PCBs are spilled. Reporting requirements are fully explained in Title 40 CFR 761.125, "Requirements for PCB Spill Cleanup."
Title 40 CFR 355.40 (EPCRA regulations):
Notify the State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC) in the event of a release of an amount greater than or equal to the reportable quantity for any CERCLA hazardous substance. The reportable quantity for PCBs in this case is 1 pound.
Title 40 CFR Part 302 (CERCLA regulations):
Notify the NRC of a spill or release of 1 pound or more of PCBs in any 24-hour period.
EPA Regional Offices and State Agencies:
These offices may have additional reporting requirements for PCBs. It is recommended that installations become familiar with regional and State PCB regulations that may require additional compliance actions in the event of a spill.
PCB Cleanup
Cleanup requirements for spills of PCBs with concentrations of 50 ppm or greater (the PCB concentration of the material prior to spill) are contained in Title 40 CFR 761, Subpart G, PCB Spill Cleanup Policy. The current cleanup policy is based on the concentration of PCBs in the spilled material and the location of the spill. The PCB Spill Cleanup Policy applies to spills occurring after 4 May 1987. Spills that occurred prior to 4 May 1987 are excluded from the Subpart G requirements and are regulated by the regional EPA office. The following actions, as summarized under several different scenarios, must be accomplished within 48 hours after a PCB spill occurs:
Spills involving less than 1 pound of PCBs with a concentration between 50 and 500 ppm:
- Solid surfaces must be double washed/rinsed (all indoor residential surfaces cleaned to a surface concentration of 10 micrograms per 100 square centimeters (10 µg/100 cm2) PCBs. Solvents approved for cleaning PCB-contaminated surfaces include kerosene, toluene, and xylene; and
- All soil, plus a one lateral foot boundary, must be excavated and the ground restored to its original configuration by back-filling with clean soil containing <1 ppm PCB.
Spills of PCBs with a concentration of >500 ppm and spills involving 1 pound or more of PCBs with a concentration of 50-500 ppm:
- Notify the EPA regional office and the NRC as required within 24 hours;
- Cordon off (or otherwise delineate) and restrict an area encompassing any visible traces, plus a three foot buffer, and place signs to clearly warn individuals to avoid the area;
- Contact the EPA regional office for guidance for completing statistical sampling of the spill area and establishing spill boundaries. Assistance may also be obtained from Air Force technical experts within Headquarters Air Force Center for Environmental Excellence (HQ AFCEE) or the Institute for ESOH Risk Analysis (IERA) (See POC list on page 9);
- Initiate cleanup of all visible traces of the fluid on hard surfaces, soil, or other media;
- Decontaminate the spill area to the following levels:*
- Spills in outdoor electrical substations:
- Clean solid surfaces to 100 µg/100 cm2
- Clean soil to 25 ppm or to 50 ppm (by weight) provided the area is labeled or a notice posted
- Spills in other restricted access areas:
- Clean high contact solid surfaces to 10 µg/100 cm2
- Clean low contact indoor impervious solid surfaces to 10 µg/100 cm2
- Clean low contact indoor non-impervious surfaces to 10 µg/100 cm2 or 100 µg/100 cm2 with encapsulation
- Clean low contact outdoor surfaces (impervious and non-impervious) to 10 µg/100 cm2
- Clean soil to 25 ppm PCBs by weight
- Spills in non-restricted access areas:
- Dispose of toys, furnishings and other easily replaceable household items
- Decontaminate indoor vault areas and high contact outdoor solid surfaces (high contact residential/commercial surfaces) to 10 µg/100 cm2
- Clean low contact outdoor, non-impervious solid surfaces to 10 µg/100 cm2 or 100 µg/cm2 with encapsulation
- Decontaminate soil to 10 ppm PCB by weight (excavation of soil must be to a minimum depth of 10 inches) and replace with clean soil
- Post-cleanup sampling is required to verify the adequacy of cleanup.
*The EPA Regional Office has the option to specify alternate cleanup requirements.
Other Spills:
Spills occurring in any of the following areas are to be cleaned-up as directed by the appropriate EPA regional office:
- Spills that result in direct contamination of surface water, sewers, sewage treatment systems or any private or public drinking water sources;
- Spills that migrate to surface water, sewers, sewage treatment;
- Distribution systems or any private or public drinking water sources;
- Spills that contaminate animal grazing land; and
- Spills that contaminate vegetable gardens.
PCB Storage, Disposal, and Decontamination
Certain storage, disposal, and decontamination requirements apply in the aftermath of PCB spill cleanup actions. Title 40 CFR 761, Subpart D, Storage and Disposal, provides the regulatory requirements for storage, disposal and/or decontamination of PCB liquids, PCB items, PCB remediation wastes, PCB bulk product waste, PCB research and development waste, and PCB radioactive waste. The source of the PCBs, the concentration, and whether it is liquid or non-liquid, combine to determine the requirements under Subpart D. The main storage, disposal, or decontamination requirements follow. Readers are encouraged to carefully review the actual regulations when evaluating storage and disposal options.
Storage:
PCB waste stored for disposal must be disposed of within one year from the date it was determined to be PCB waste and the decision was made to dispose of it. Subpart D allows PCB articles to be stored for reuse for up to five years without special EPA authorization. PCB articles must be properly marked and stored in an appropriate storage area. The storage facility must also meet the following criteria:
- Adequate roof and walls to prevent rain water from reaching stored PCBs;
- An adequate floor with continuous curbing (minimum of 6" height). The 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 openings allowing liquids to flow from the curbed area;
- Floors and curbing constructed of continuous smooth and impervious materials to prevent or minimize PCB penetration; and
- Must be above the 100-year flood water elevation.
Hazardous waste storage facilities permitted under the Resource Conservation and Recovery Act (RCRA) or equivalent state regulation are authorized to store PCBs for disposal. The following PCB items may be stored in a facility not meeting the above requirements for a period of 30 days from the date of their removal from service:
- Non-leaking PCB articles and equipment;
- Leaking PCB articles and equipment providing they are placed in a non-leaking PCB container containing sufficient sorbent to absorb liquid PCBs;
- PCB containers containing non-liquid PCBs such as contaminated soil, rags, and debris; and
- PCB containers containing liquid PCBs at concentrations of >50 ppm, provided a Spill Prevention, Control and Countermeasure Plan has been prepared for the temporary storage facility in accordance with Title 40 CFR Part 112, Oil Pollution Prevention.
Disposal:
Disposal options for PCB waste significantly changed with the June 1998 amendments to Title 40 Part 761. PCB disposal requirements/options are now categorized based on the type of PCB waste. Generally, incineration is the preferred method to dispose of PCB waste. Other disposal options include placement in a municipal solid waste or chemical waste landfill, or disposal in a high efficiency boiler. The disposal categories are outlined below.
PCB Liquids - At concentrations of 50 ppm or greater, PCB liquids are generally required to be disposed of by incineration. Certain PCB liquids containing between 50 and 500 ppm PCBs may be disposed of in a chemical waste landfill or a high efficiency boiler provided the requirements outlined in Subpart D are met.
PCB Articles and Containers - PCB articles include transformers, small and large capacitors, hydraulic machines, PCB-contaminated electrical equipment and natural gas pipeline systems containing PCBs. Generally, free flowing liquid must be removed from the article, the article cleaned with an appropriate solvent, then incinerated. Several caveats to the general requirements exist and disposal must be determined based on the specific article. PCB containers can be incinerated or drained and disposed as municipal solid waste or in a chemical waste landfill, depending on PCB concentration.
PCB Remediation Waste - New disposal options for PCB remediation wastes are implemented in 40 CFR 761.61. This section includes instructions for self-implementing cleanup and disposal of PCB remediation waste for a moderately sized site where there should be low residual environmental impact from remedial activities. No prior written approval from the EPA is needed to implement these procedures. For larger sites, the self-implementing procedures may be used in consultation with the EPA. The self-implementing procedures may NOT be used for:
- Surface or ground waters.
- Sediments in marine and freshwater ecosystems.
- Sewers or sewage treatment systems.
- Any private or public drinking water sources or distribution systems.
- Grazing lands.
- Vegetable gardens.
The regulation also provides for performance-based disposal of PCB remediation waste adhering to the cleanup standards listed in the regulation. There is also authorization to design and implement a risk based disposal option after consultation with the EPA.
Disposal of PCB Bulk Product Waste - PCB bulk product wastes are generally disposed of based on analytical determination of the PCB concentration in the material at the time of its designation for disposal and its potential leachability. Bulk product wastes may be disposed of in an incinerator, chemical waste landfill, hazardous waste landfill, or may be decontaminated as discussed below. The selection of disposal method is specifically described in 40 CFR 761.62.
There is also an option to dispose of certain PCB bulk product wastes in a State-permitted municipal landfill or non-municipal non-hazardous waste landfill. These items include:
- "Plastics (such as plastic insulation from wire or cable; radio, television and computer casings; vehicle parts; or furniture laminates); preformed or molded rubber parts and components; applied dried paints, varnishes, waxes or other similar coatings or sealants; caulking; Galbestos; non-liquid building demolition debris; or non-liquid PCB bulk product waste from the shredding of automobiles or household appliances from which PCB small capacitors have been removed (shredder fluff)"; and
- Other PCB bulk product waste, sampled in accordance with the protocols set out by the EPA that leaches PCBs at 10 µg/L of water measured using a procedure used to simulate leachate generation.
In order to dispose of PCB bulk product waste in a State-permitted municipal landfill or non-municipal non-hazardous waste landfill, there may be additional sampling, recordkeeping and performance requirements that must be satisfied. Readers are encouraged to carefully review 40 CFR 761.62 if selecting this disposal option.
Additional discussion of PCB bulk product waste as it pertains to fluorescent light ballasts containing PCBs can be found in the October 1998 Lighting Waste Fact Sheet produced by PRO-ACT.
Decontamination:
Title 40 CFR Part 761, as amended in June 1998, now allows the use of decontamination as an alternative to PCB waste disposal and also permits the sale of decontaminated materials for use, reuse, or disposal. These regulations are outlined in 40 CFR 761.79 and apply to PCBs, which are regulated for disposal, from water, organic liquids, non-porous surfaces (including scrap metal from disassembled electrical equipment), concrete, and non-porous surfaces covered with a porous surface, such as paint or coating on metal.
The decontamination regulations are broken into two parts. The first part is a performance-based standard that specifies decontamination standards and requires analytical testing to demonstrate the level of decontamination has been achieved. Refer to the rule for the specific performance requirement. It allows PCBs from liquids, concrete, and non-porous surfaces to be removed using chopping, distilling, filtering, oil/water separation, stripping of insulation, spraying, soaking, wiping, scraping, and use of abrasives or solvents. Decontamination waste must be disposed as required based on the concentration of PCBs in the waste.
The second part of the regulation provides a self-implementing decontamination procedure for PCB containers, movable equipment contaminated with PCBs, non-porous surfaces in contact with free flowing mineral oil dielectric fluid (MODEF), piping and hoses in air compressor systems, and decontamination of metal surfaces using thermal processes. Confirmatory sampling is not required for self-implementing decontamination procedures; however, documentation of compliance with the procedures must be maintained for 3 years after completion of the decontamination procedures (e.g., video recordings, photographs).
PCB Household Waste Exemption
Title 40 CFR 761.63 exempts certain kinds of household wastes from PCB disposal regulations. According to the regulation, PCB household waste means "PCB waste that is generated by residents on the premises of a temporary or permanent residence for individuals (including individually owned or rented units of a multi-unit construction), and that is composed primarily of materials found in wastes generated by consumers in their homes. PCB household waste includes unwanted or discarded non-commercial vehicles (prior to shredding), household items, and appliances or appliance parts and wastes generated on the premises of a residence for individuals as a result of routine household maintenance by or on behalf of the resident. Bulk or commingled liquid PCB wastes at concentrations of >50 ppm, demolition and renovation wastes, and industrial or heavy-duty equipment with PCBs are not household wastes."
Air Force PCB Elimination Policy
It is Air Force Policy that all installations be PCB-free as of 31 December 1998. The criteria for PCB-free status are outlined in the 15 May 1996 HQ USAF/CEV policy letter, "Air Force PCB-free Status and Clarification of 'Target' PCB Equipment." Under the policy, for an installation to be considered PCB-free, PCB-containing transformers and large capacitors must be either removed from service, reclassified to non-PCB status (less than 50 ppm PCB) in accordance with the procedures in 40 CFR 761.30 Authorizations, placed into storage for disposal, or disposed. PCB items that are weapon system components or organizational equipment (e.g., fluorescent light ballasts) are excluded when determining installation PCB-free status.
It is important to note that reclassification by retrofilling is not recommended for transformers which contain high-concentration (500 ppm or greater) PCB oil. According to electrical experts at the Headquarters Air Force Civil Engineer Support Agency (HQ AFCESA), DSN 523-6317, high concentration PCB oil is absorbed on transformer components and leaches out after retrofilling. However, reclassification by retrofilling is a viable option for transformers containing PCB-contaminated mineral oil.
Summary
PCB management in the Air Force is largely centered on PCB elimination and compliance with the governing regulations established under TSCA. This fact sheet has highlighted many aspects of the governing rules. With the significant changes in the regulations promulgated in June 1998, there is now more flexibility allowed when evaluating PCB use, disposal, and decontamination options. PRO-ACT recommends careful review of the existing regulations and consultation with legal counsel prior to implementing a PCB related action.
For More Information...
If you desire more information on procedures, spill reporting, sampling, and cleanup of PCBs and PCB-containing items, you can contact PRO-ACT at DSN 240-4214 or (800) 233-4356. Our fax number is DSN 240-4254.
Technical Points of Contact
Captain Steve Novak
Headquarters Air Force Center for Environmental Excellence (HQ AFCEE/EQT)
Brooks AFB, TX
DSN 240-6375
Institute for Environment Safety and Occupational Health (ESOH) Risk Analysis (IERA)
HSW-ESOH Service Center
Brooks AFB, TX
DSN 240-5454 or (888) 232-ESOH
Mr. Ray Hansen
Headquarters Air Force Civil Engineer Support Agency (HQ AFCESA/CESE)
Tyndall AFB, FL
DSN 523-6317
Captain Greg Durand - PCB POC
Headquarters United Stated Air Force (HQ USAF/ILEVQ)
The Pentagon, D.C.
DSN 327-0132
Document References
- "Removal of Polychlorinated Biphenyl Equipment from Air Force Installations," HQ USAF/LEEV, 29 April 1986.
- "Polychlorinated Biphenyls (PCB) Spill Cleanup Policy," HQ USAF/LEE/SGP, 24 July 1987.
- "Continuation of the Air Force Polychlorinated Biphenyls (PCB) Free Policy," HQ USAF/CEV, 24 May 1993.
- "Elimination of Liquid Polychlorinated Biphenyls (PCBs)," HQ USAF/CE, 27 November 1995.
- "Polychlorinated Biphenyl (PCB) Pollution Prevention Program," HQ USAF/CEV, 27 February 1996.
- "Air Force PCB-Free Status and Clarification of "Target" PCB Equipment," HQ USAF/CEV, 15 May 1996.
- "Arochlor 1242," Material Safety Data Sheet, MDL Information Systems, Inc., 22 October 1984 (Revised June 17, 1995).
- Guidance on Remedial Actions For Superfund Sites with PCB Contamination, U.S. EPA, Office of Emergency and Remedial Response, (Washington: August 1990).
- Organic Chemistry, Carey, Francis A., New York: McGraw-Hill, Inc., 1987, pg. 967.
- PCB Q & A Manual, U.S. EPA, Office of Pollution Prevention and Toxics, Washington D.C., 1994.
- "Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibition," 40 Code of Federal Regulations, Part 761, revised 28 June 1998.
- "Handbook on the 1998 Amended PCB Management and Disposal Regulations," HQ USAF/ILEVQ, December 1998.
- "Lighting Waste Management," PRO-ACT Fact Sheet, Revised, October 1998.
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