U.S. EPA Staff Perspective on Polychlorinated Biphenyls (PCBs
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Transcript U.S. EPA Staff Perspective on Polychlorinated Biphenyls (PCBs
Jennifer Downey, Enforcement Officer
US EPA Region IX, RCRA Enforcement Office
How are PCBs regulated at a
federal level?
Toxic Substances Control Act (TSCA)
Section 6(e) of TSCA states that no one may manufacture,
process, distribute into commerce, or use PCBs 50 ppm in
any manner other than a totally enclosed manner unless
authorized by the EPA Administrator.
TSCA isn’t delegated to the states. EPA is responsible for all
PCB inspections and enforcement.
DTSC regulates PCBs as a hazardous waste (Greater than 2
ppm)
Sources of PCBs (pre 1978)
Historical releases.
Electrical Equipment – sometimes you can tell by the
name of the equipment, but many tags have been
removed
Paint – difficult to tell without sampling
Caulk – difficult to tell without sampling
Ballast – newer ballast will clearly state that it has no
PCBs.
Wiring – difficult to tell without sampling
Gaskets – difficult to tell without sampling
Electrical Equipment
Transformer
Capacitor
Ballast
Key regulations
Legal uses of PCBs – must be enclosed with no leaks.
PCB transformers must be labeled (over 500 ppm)
and/or registered.
When PCBs are “taken out of service”, they must be
properly disposed (or decontaminated) within a year.
Storage requirements – for over 30 days.
Equipment Labels
How to legally dispose of PCBs?
Incinerate PCBs (none in pacific southwest)
Landfill (Kettleman City, CA and Beatty, NV)
High efficiency boiler (none in pacific
southwest)
Scrap metal recovery ovens and smelters (none
in pacific southwest)
Decontamination of PCBs
EPA PCB Inspections
Inspect facilities that store, treat, or dispose PCBs
(“PCB approved facilities”)
Follow-up on complaints
Sources of complaints
Exception reports from PCB approved facilities
Public and NGOs
State or other parts of EPA
Areas of PCB Enforcement Focus
PCB approved facilities
Ships
Follow-up on complaints
Identifying potential companies with large sources of
PCBs
Recent Cases
1) Earth Protection Services, Inc. - 11/30/2001 - $2,500
2) Exxon Mobil - 08/21/2008 - $2.64 million
3) Global Shipping LLC and Global Marketing Systems,
Inc. - 01/29/2009 - $518,500
4) US Ecology (Beatty, Nevada )09/30/2010 - $497,982
(RCRA/TSCA)
5) Chemical Waste Management (Kettleman City)
11/29/2010 - $302,100
What we need from you!
Information on potential PCB sources
Location
Levels (Sampling is key)
Type of material (soil, equipment, paint, oil)
Does it appear to be a legacy issue or an ongoing issue
Do you know who is responsible for the source of PCBs
Hypothetical #1
Leaking Transformer and sampling of oil finds level at
400 ppm.
Identify owner land and transformer
Information on the transformer. Does it have a PCB
label or other labeling?
Photograph transformer and surrounding area.
Interview owner or employees to determine length of
spill.
Immediately call EPA.
Hypothetical # 2
Building paint is sampled and found to have 600 ppm
Identify owner
What is color of the paint? Are there a variety of colors
on the building?
Photograph building
Interview employees and owner as to knowledge
Call or refer to EPA.
Hypothetical # 3
Soil sampling finds PCB at 48 ppm
Is the source above 50 ppm?
Electrical equipment in use?
Historical use of land?
Can’t determine source? – If we can’t determine if source
is above 50 ppm we will refer it to DTSC.
Audience Hypothetical?
Questions
Hopefully answers!
How to Contact US EPA
PCB Tips go to: Christopher Rollins, RCRA
Enforcement Office, US EPA Region IX
Address: 75 Hawthorne Street, San Francisco, CA 94105
Phone: (415) 947-4166
Email: [email protected]
Technical Issues on Sampling or Corrective action –
[email protected] or
[email protected]