Polychlorinated Biphenyls (PCBs)

Polychlorinated Biphenyls (PCBs) are a class of organic chemicals that were widely used in industrial applications. Historically PCBs were used in electrical equipment such as utility transformers and capacitors, as well as in other applications. In additional to having good dielectric properties, PCBs are chemically inert and fire-retardant. Although the stability of PCBs was advantageous for fire safety and equipment durability, it created an unanticipated problem - when released into the environment, PCBs accumulate in soils, pass up the food chain, and become more concentrated in humans and other species. The manufacture of PCBs was banned in 1976. However, older electrical equipment may contain PCBs.

This page covers Toxic Substances Control Act (TSCA) regulations applicable to PCB-containing electrical equipment.

• Who is covered by the regulations?
• What is the purpose of the regulations?
• Regulations
• Best Practices
• More Resources

Who is covered by the regulations?

Transportation facilities owning and/or operating electrical equipment containing threshold concentrations (see below) of polychlorinated biphenyls must comply with the TSCA PCB rules.

What is the Purpose of the Regulations

PCBs can be released into the environment from leaks or releases from electrical equipment. Once in the environment, PCBs do not readily break down. The material can still be found, many decades after being released, cycling between air, water, and soil. Some of this material enters the food chain, where it increases in concentration as it moves up the chain. In humans, it is typically found concentrated in fatty tissue. PCBs have been demonstrated to cause cancer, as well as a variety of other adverse health effects on the immune system, reproductive system, nervous system, and endocrine system.

Regulations

The Toxic Substances Control Act (TSCA) banned the manufacture of PCBs after 1978. The first PCB regulations were promulgated later that same year and are codified at 40 CFR Part 761. These regulations cover proper use, inspection, labeling and marking, recordkeeping, storage, reporting, transportation, management, and disposal of electrical equipment containing PCBs.

For spills of PCBs containing 50 ppm or more, several release reporting and spill clean-up requirements, other than those under TSCA, must be satisfied under several statutes. These statutes include the Clean Water Act, and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.

Three categories of PCB-containing equipment are defined under TSCA: Non-PCB equipment (e.g., transformers, capacitors) contains PCBs in concentrations of less than 50 parts per million (ppm). These units are not regulated and have no restrictions on use, disposal, and servicing. They can be sold at the end of their useful service lives.

• PCB-contaminated equipment contains PCBs in concentrations of between 50 and 499 ppm. Although these units have no restrictions on in-service use, disposal of the coolant is regulated.
• PCB equipment contains PCB concentrations of 500 ppm or greater. They are closely regulated and some are banned outright. Exterior labeling and periodic inspections and reporting are required for the units not banned.

PCB or PCB-contaminated equipment cannot be sold. Known in-use PCB equipment must be inspected quarterly for leaks. Records must be kept of these inspections. If PCB waste or PCB equipment is disposed of, PCB levels must be ascertained via laboratory analysis.

PCB equipment designated for disposal must be stored in a designated PCB storage area in the following manner:

• PCB equipment must not be stored for more than 30 days.
• No leaking PCB equipment should be stored without being placed in a suitable non-leaking container or over pack-drum with enough sorbent material to soak up all fluid released.
• Place 6 inch x inch labels, "CAUTION contains PCBs" on all items and doorways.
• Make sure that the roof and walls of your storage facility prevent rain from reaching PCB items.
• Use a relatively impervious floor with a 6 inch high curb and no drains or other openings. Contained volume must equal at least twice the volume of the largest item stored or 1/4 the volume of all equipment.
• The storage area floor must be above the 100-year floodplain.
• If PCB equipment is to be shipped, it must transported under a hazardous waste manifest and hazardous material waybill.
  

Any spill of one gallon or more of insulating fluid should be assumed to be a PCB spill, unless tests or records indicate otherwise. Regulated spills should be reported to the U.S. EPA, the National Response Center, and state and local authorities (more information). All electrical equipment involved in spills or emergencies should similarly be assumed to be PCB equipment, unless tests or records indicate otherwise. If regulated and involved in a spill, the following actions must be taken:

• Cleanup of PCB spills must be initiated within 24 hours and completed within 48 hours regardless of holidays or weekends.
• Cleanup of all PCB spills must be conducted by personnel trained in PCB spill remediation.
• There are short- and long- range recordkeeping requirements that result from a spill of PCB-containing, or PCB-suspect, insulating fluids. A clear-cut narrative must be developed describing: detection of the spill (e.g., time, location, date, description of site); steps taken to mitigate environmental impact of spill; steps taken to clean up the spill; notification activities; and, verification of the effectiveness of the cleanup.
  

If PCB-containing transformers are involved in a fire, a report should be made to the National Response Center on-line or call 1-800-424-8802. It is important to notify firefighting authorities when PCB materials are involved in a fire. PCB materials can form dioxins, another suspect carcinogen, during a fire; smoke from burning PCB items may be toxic.

Best Practices

All electrical equipment manufactured before 1978 containing insulating fluids should be assumed to contain PCBs unless tests or records indicate otherwise.

Appropriate personal protective clothing should always be worn when working with substances that contain or come into contact with PCBs. Any protective or work clothing (including boots, gloves, etc.) which comes into contact with PCB fluid must be disposed of as PCB debris. In the case of inadvertent skin contact with PCBs, the contact area should be washed with soap and water. PCBs are not toxic in short term exposures.

More Resources

Managing Polychlorinated Biphenyls (PCBs) From Electrical Equipment (2007). PCB pollutant minimization plan workshop. Useful resource for helping identify PCB-containing equipment.