Jennifer Downey, Enforcement OfficerUS 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 samplingCaulk – difficult to tell without samplingBallast – newer ballast will clearly state that

it has no PCBs.Wiring – difficult to tell without samplingGaskets – difficult to tell without sampling

Electrical Equipment

Ballast

Transformer Capacitor

Key regulationsLegal 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 InspectionsInspect facilities that store, treat, or dispose

PCBs (“PCB approved facilities”)Follow-up on complaintsSources of complaints

Exception reports from PCB approved facilitiesPublic and NGOsState or other parts of EPA

Areas of PCB Enforcement FocusPCB approved facilitiesShipsFollow-up on complaintsIdentifying 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

LocationLevels (Sampling is key)Type of material (soil, equipment, paint, oil)Does it appear to be a legacy issue or an

ongoing issueDo you know who is responsible for the source

of PCBs

Hypothetical #1Leaking Transformer and sampling of oil

finds level at 400 ppm.Identify owner land and transformerInformation 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 # 2Building paint is sampled and found to have

600 ppmIdentify ownerWhat is color of the paint? Are there a

variety of colors on the building?Photograph buildingInterview employees and owner as to

knowledgeCall or refer to EPA.

Hypothetical # 3Soil 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?QuestionsHopefully answers!

How to Contact US EPAPCB Tips go to: Christopher Rollins, RCRA

Enforcement Office, US EPA Region IXAddress: 75 Hawthorne Street, San Francisco,

CA 94105Phone: (415) 947-4166Email: rollins.christopher@epa.gov

Technical Issues on Sampling or Corrective action – santos.carmen@epa.gov or rollins.christopher@epa.gov