DYNEX Industries - PCB Requirements

PCB REQUIREMENTS
PCB Megarule

The EPA has published amendments to the Toxic Substances Control Act (TSCA) polychlorinated biphenyl (PCB) disposal regulations in the June 29, 1998 Federal Register. These regulations in the "PCB Megarule" address many issues covering the use, cleanup, storage, and hazardous waste disposal of PCBs. There are some significant departures from the way EPA has regulated PCBs in the past. The Megarule appears in Title 40, Code of Federal Regulations (CFR) Part 761, published in the July 1, 1998 edition of the CFR. The effective date of the regulations is August 28, 1998. On the Internet, EPA's PCB Home Page is: www.epa.gov/pcb/ .

Here are some hypothetical questions and answers regarding PCBs that may be of interest to you:

If I have PCB or PCB contaminated electrical equipment, what are my requirements to notify EPA?

As per 40 CFR Part 761.30 (a)(1)(vi); as of December 28, 1998 all owners of PCB Transformers, including those in storage for re-use, must have registered their PCB transformers with EPA in Washington DC on EPA Form # 7720-12. There are no fees due with registration. This form is available on EPA's PCB web site. EPA registration of PCB contaminated electrical equipment is not required.

If I have retrofilled my askarel in-service transformer and the replacement fluid is 500 ppm PCB or higher, and the transformer is now leaking, what do I do?

You need to have a qualified PCB service handler stop the leak and clean up the spill. The transformer must be repaired or replaced to eliminate the source of the leak. Cleanup of the released PCBs must be initiated as soon as possible, but in no case later than 48 hours of its discovery. A spill is defined by EPA as a leak or other uncontrolled discharge 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. The EPA’s PCB Spill Cleanup Policy is stated in 40 CFR subpart G, part 761.120 to 761.135.

If I have retrofilled my askarel in-service transformer and the replacement fluid is 50 ppm PCB or higher but less than 500 ppm, and the transformer is now leaking, what do I do?

Essentially the same answer as the over 500 ppm case.

What are my decontamination requirements in the above two examples?

As outlined in 40 CFR Part 761.30 (a)(2)(v) in either case the in-service transformer can be re-retrofilled and converted to a lower PCB concentration status.

If I have PCB or PCB contaminated transformer in storage for re-use, what are my options?

A PCB transformer has to be registered with EPA. Either a PCB mineral oil filled or PCB contaminated transformer can be re-retrofilled and converted to a lower PCB concentration status. Storage for re-use is outlined in 40 CFR Part 761.35. All electrical equipment that is known or assumed to 50 ppm PCB or greater may not be stored for re-use for longer than 5 years from the date the unit was removed from service (or 5 years after August 28, 1998, whichever is later), with certain limited exceptions. Owners of such equipment in storage for re-use must fill out and maintain records on each unit that includes the following information: (a) the date that the unit was removed from service (start of the 5 year clock), and (b) the projected location where the unit will be used; and (c) if applicable, the date that the unit is scheduled for repair or servicing.

If I retrofill a greater than 50 ppm PCB mineral oil transformer that is in storage for re-use, can I re-classify it without putting it into electrical service?

No, if the pre-retrofill PCB concentration is 1000 ppm or greater. Yes, if the pre-retrofill PCB concentration is less than 1000 ppm.

If I have a PCB or PCB contaminated transformer in storage for disposal, what are my options?

Storage for disposal is outlined in 40 CFR Part 761.65. Generally speaking, any PCB waste 50 ppm or greater must be disposed of within 1 year from the date it was determined to be PCB waste and the decision was made to dispose of it. As a generator of PCB waste, if your state classifies PCBs as a hazardous waste, you may be more limited on the length of time you can store your own PCB or PCB contaminated waste – a typical case is 90 days.

What is the regulation on PCB remediation waste?

This is a category introduced in the PCB Megarule and is written in 40 CFR Part 761.61. PCB remediation waste is generally defined as: waste (such as soil, rags, and other debris) containing PCBs as a result of a spill, release, or other unauthorized disposal, at PCB concentrations greater than or equal to 50 ppm or 500 ppm, depending on the date of the incident. Sewage sludge containing less than 50 ppm PCBs and not in use according to Part 761.20(a)(4) is considered PCB remediation waste. EPA has designed a self-implementing procedure for a general, moderately sized spill site where there should be low residual environmental impact from remedial activities. Remember that in some cases certain state, county or local regulations may be more stringent than EPA regulations; if that is the case in your situation, the more stringent regulations apply. Should you have additional questions regarding the PCB Megarule, please feel free to call Brian Sjoberg at (763) 717-3131.