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