Section 12. DISPOSAL
I.
GENERAL COMMENTS
Federal regulations do not require removal of PCBs and PCB Items from service and disposal earlier
than would normally be the case. However, when PCBs and PCB Items, including soils and debris
contaminated with PCBs, are to be removed from service or disposed of, disposal must be undertaken
in accordance with federal and state requirements.
The section which follows describes, in detail, the federal and state regulations which pertain to the
disposal of PCB contaminated soils and debris, PCB transformers and capacitors, and PCB
contaminated transformers. In addition to a description of the various regulatory approved disposal
methods, this section will address associated requirements including those pertaining to the
manifesting of these items.
It is important to recognize that disposal options may be limited by the concentration of PCBs which
are present in the items which are to be disposed of. For the purposes of disposal of items which have
been contaminated by the release of PCBs from a transformer or capacitor, the EPA regulations
provide that the concentration of PCBs in the material onto which the PCBs were spilled is determined
by the concentration of PCBs in the spilled oil and not by the concentration found in the material itself.
A new option—the self-implementing plan — is now available for clean up of old spills and disposal
of remediation waste which permits disposal based on the actual concentration in the material and not
by the concentration of PCBs in the spilled oil. The self-implementing plan rules must be carefully
followed and are quite detailed. If a large spill site is in need of a clean up, this plan may provide some
economic benefits.
Please remember that the cooperative is the generator of PCBs and PCB Items. This means that when
you use a disposal company, a rebuilder, or a transportation company, even if you do everything
according to law, if the other company does not dispose of your PCBs correctly, you may be held
liable for additional costs in the future. An example of this is Rose Chemical. Therefore, it is very
important that you use only reputable companies for disposal and transportation of your PCB waste. If
you would like names, addresses and telephone numbers of disposal companies, or legal advice
regarding disposal, please contact the Iowa Environmental Group.
II.
APPROVED METHODS OF DISPOSAL AND DECONTAMINATION OF VARIOUS
TYPES AND CONCENTRATIONS OF MATERIALS CONTAINING PCB’S
The first step in determining the proper disposal method to use is to determine the category the product
falls under. Once the classification is determined, then follow the disposal options outlined below.
A.
Mineral oil dielectric fluid (50 - 499 ppm)
Mineral oil dielectric fluid with a PCB concentration
either an approved incinerator or an approved high-efficiency boiler.
B.
Liquid PCB’s containing a PCB concentration of 500 ppm or greater must be disposed of in an
approved incinerator.
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C.
Other PCB liquids (50 - 499 ppm)
Other PCB liquids, from incidental sources such as precipitation, condensation, leachate or load
approved incinerator or in an approved chemical waste landfill.
For each of the above methods, it is important to use a disposal company which is reliable and follows
the regulations properly. You may be held liable for problems which arise from the improper disposal
of PCB or PCB-contaminated items which you generated.
D.
PCB Transformers
This provision applies to PCB transformers with a PCB concentration of 500 ppm or greater. Such
items must be disposed of using one of the following methods:
1. Incineration; or
2. Approved chemical waste landfill.
If the transformer is to be disposed of in an approved chemical waste landfill it must meet the
following requirements:
a. The transformer must be drained of all free flowing liquid. These liquids must be
disposed of by incineration only.
b. The transformer must then be filled with a solvent and allowed to stand for at least 18
hours.
Solvents may include kerosene, xylene, toluene and other solvents in which PCBs are readily
soluble.
Precautionary measures should be taken so that the solvent flushing procedure is conducted in
accordance with applicable state and federal safety regulations, such as OSHA.
c. The transformer must then be drained thoroughly.
This liquid waste, if it exceeds levels of PCBs which trigger the disposal requirements must
also be properly disposed of either as a PCB waste liquid or as a hazardous waste.
d. The PCB transformer carcass may not be sold to a scrap dealer for salvage. It must be d
disposed of by incineration or in an approved landfill.
For each of the above methods, it is important to use a disposal company which is reliable and
follows the regulations properly. There are currently no approved disposal facilities in Iowa. You may
be held liable for problems which arise from the improper disposal of PCB or PCB-contaminated items
which you generated.
There are currently no approved disposal facilities in Iowa.
See Section IIIA for information regarding the proper testing, marking, and disposal of waste
mineral oil which is collected in a common container.
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E. Capacitors
This provision applies to all capacitors unless it is known from the label or nameplate
information, manufacturer’s literature (including documented communications with the manufacture),
or chemical analysis, that the capacitor does not contain PCBs.
1. PCB Small Capacitors
"Small capacitor" means a capacitor which contains less than 1.36 kg (3 lbs.) of dielectric fluid.
When the actual weight of the dielectric fluid is unknown, the following assumptions may be used:
a. Total capacitor volume of less than 1,639 cubic centimeters (100 cubic inches) contains less
that 1.36 kg (3 lbs.) of dielectric fluid.
b. Total capacitor volume of more than 3,278 cubic centimeters (200 cubic inches) contains
more than 1.36 (3 lbs.) of dielectric fluid.
c. Total capacitor volume between 1,639 and 3,278 cubic centimeters contains less than 1.36
kg (3 lbs.) of dielectric fluid if the total weight of the capacitor is less than 4.08 kg (9 lbs.).
These capacitors may not be disposed of as municipal solid waste in Iowa.
2. PCB Large High or Low Voltage Capacitor
"Large capacitor" means a capacitor which contains 1.36 kg (3 lbs.) or more of dielectric fluid.
A "low voltage" capacitor is one which operates below 2,000 volts. A "high voltage" capacitor
is one which operates at or above 2,000 volts. For purposes of this section, however, the distinction is
not important. This section applies to both high and low voltage large capacitors.
This provision applies to large capacitors which contain a PCB concentration of 500 ppm or greater.
Such capacitors must be disposed of in an EPA-approved incinerator.
3. Capacitors with PCB Concentrations of 50 - 499 ppm. (PCB-Contaminated).
Such capacitors must be disposed of using one of the following methods:
a. Incineration; or
b. Approved chemical waste landfill.
If the capacitor is to be disposed of in an approved chemical waste landfill, it must first be
drained.
F. PCB Hydraulic Machines
1. This applies if the machines contain PCBs at concentrations of 50 ppm or greater.
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First, the following requirements must be met:
a. The machines are drained of all free-flowing liquid; and
b. The liquid is properly disposed of based on its concentration.
These machines may then be disposed of by the following methods:
a. Decontaminated (see II-L of this section);
b. State licensed municipal solid waste facility;
c. Industrial furnaces/scrap metal recovery oven operating under certain requirements; or
d. Other approved disposal facility (e.g. approved incinerator or dechlorination facility).
2. Machines which contain PCBs at concentrations of 1000 ppm or greater must be either be
decontaminated (see II-L of this section) or flushed prior to disposal with a solvent containing less than
50 ppm PCB. Solvents may include kerosene, xylene, toluene and other solvents in which PCBs are
readily soluble. The solvent must then be properly disposed of.
G.
PCB-Contaminated Electrical Equipment
(Includes Transformers)
This provision applies to any PCB-Contaminated electrical equipment, including, but not
limited to, transformers, reclosers, switches, and circuit breakers but not including capacitors, that
contain 50 ppm or greater PCB, but less than 500 ppm PCB (50-499 ppm).
4. First, the following requirements must be met:
a. All free-flowing liquid is removed (e.g. pumped) from the equipment; and
b. The liquid removed is properly disposed of, as discussed earlier, based on its concentration.
5. No longer can drained transformer carcasses or other equipment be sold for scrap or parts. This
equipment must be disposed of by the following methods:
a. State licensed municipal solid waste facility1.
b. Industrial furnaces/scrap metal recovery oven operating under certain requirements; or
c. Other approved disposal facility (e.g. approved incinerator or dechlorination facility). Once
free-flowing liquids are removed from the equipment, the storage for disposal requirements
are not applicable and the equipment can be stored indefinitely.
H. Other PCB Articles
1.
This applies if the PCB concentration is 500 ppm or greater.
Disposal may be by:
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a. Incinerator; or
b. Chemical waste landfill if the articles have been thoroughly drained and the drained liquid
is incinerated.
2. If the PCB concentration is 50 - 499 ppm, disposal is not federally regulated if the articles have
been drained of all free flowing liquid. However, the liquid must be disposed of properly.
I. PCB Containers
1. This applies if the PCB concentration is 500 ppm or greater.
Disposal may be by:
a. Incinerator; or
b. Chemical waste landfill if the containers have been thoroughly drained. The liquid must be
disposed of properly.
2. This applies if the PCB concentration is less than 500 ppm.
Disposal may be as municipal solid waste if the containers have been thoroughly drained. The
liquid must be disposed of properly.
J. Liquids and PCB Contaminated Items (< 50 ppm PCBs)
The EPA does not regulate the disposal of waste oil, waste dielectric oil, transformers, soils or
any items which exhibit a PCB concentration of less than 50 ppm. (However, for soils, the PCB
concentration is the concentration in the oil which was spilled onto the soil.) The disposal of these
contaminated items are subject to the regulations of the Iowa Department of Natural Resources which
require that disposal take place only at permitted sanitary landfills and that it be authorized. The PCB
rules prohibit you from using waste oil that contains any detectable concentration of PCBs as a sealant,
coating, or dust control agent. You may not use this oil for such things as road oiling, general dust
control, as a pesticide or herbicide carrier, or as a rust preventive on pipes.
1. Special Waste Authorization (SWA)
The DNR’s rules prohibit any person from delivering special wastes to a landfill unless a
special waste authorization (SWA) has been obtained from the department. You may request an SWA
from the DNR by submitting Form 46 (542-3216), "Request for Special Waste Authorization". (A
copy of this form is provided at the end of this chapter.) Supporting data, including analytical results,
deemed necessary by the department must also be provided. The form is to be mailed to:
Special Wastes Authorizations
Environmental Protection Division
Iowa Department of Natural Resources
Henry Wallace Building
900 East Grand Ave.
Des Moines, Iowa 50319-0034
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If you have any questions regarding the preparation of the form or the DNR’s requirements you
may call Mark Landa at (515) 244-3500, or the DNR at (515) 281-3426.
2. Liquids
The DNR will not authorize the disposal of free liquids. You are required, therefore, to treat
liquids in such a way as to render them capable of passing a paint filter test.
3. Soils
The DNR will authorize the disposal of PCB contaminated soils which exhibit a PCB
concentration of less than 50 ppm. The disposal of these soils may not be allowed, however, by the
EPA, if the contamination is the result of a spill of oil which exceeded a 50 ppm concentration.
You must contact both agencies and follow the requirements of both agencies.
K.
PCB Remediation Waste (> 50 ppm)
Remediation waste, which includes soil, gravel, sediments, sludge, man-made structures such
as concrete or wood, and other debris are those materials that are contaminated as a result of a PCB
spill of a concentration more than 50 ppm.
There are now three options available to dispose of this material: a self-implementing plan
option; a performance-based option; and a risk-based option.
1. Self-implementing plan option
Under this option, remediation waste can be disposed of based on the actual concentration of
the PCB’s on the material, as opposed to the concentration of the source of the spill. Various clean up
levels, pre-cleanup sampling and post-cleanup sampling techniques are required. This option may be
beneficial if you have a substantial amount of material to dispose of and it appears that the actual PCB
concentration may be significantly lower than the spill source. If you feel you are a possible candidate
for this option, contact Mark Landa at (515) 244-3500.
a. Bulk remediation waste (e.g. soil, gravel)
therwise. Such
PCB approved disposal facilities. Bulk remediation waste at < 50 ppm shall be disposed in a
municipal solid waste or non-municipal, non-hazardous waste landfill, RCRA C landfill, or any
approved PCB disposal facility. (PCB manifest requirements do not apply to these wastes of
concentration < 50 ppm.)
b. Non-porous surfaces (metal, glass, etc.)
Such waste can be disposed of on-site using decontamination methods (see II-L of this section)
2
2
for
2
can be disposed of off-site in a
municipal solid waste or non-municipal, non-hazardous waste landfill, certain permitted landfills or
any approved PCB disposal facility.
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c. Porous surfaces
Porous surfaces must either be decontaminated (see II-L of this section) or disposed of as bulk
remediation waste as outlined in (a) above.
d. Liquids
Liquid PCB remediation waste shall be either decontaminated (see II-L of this section), disposed of
pursuant to II-B or II-C of this chapter, or obtain risk-based disposal approval. (See II-K(3))
e. Cleaning materials (non-liquid)
Non-liquid cleaning materials, such as rags, protective equipment and gloves may be disposed
of in a municipal solid waste or non-municipal, non-hazardous waste landfill, specialized landfill, or a
PCB approved disposal facility.
2. Performance-based option
All materials upon which PCB’s have leaked may be disposed of as follows. This is the prior
disposal requirement that remains as an option. Remember, it is the PCB concentration of the source
that is the determinative factor, not the actual PCB concentration.
Such items must be disposed of using one of the following methods:
a. Liquid PCB waste according to section II A - C of this chapter.
b. Non-liquid waste in an incinerator or chemical waste landfill.
c. Decontaminated as outlined in II-L of this section.
3. Risk-based option
In order to utilized this third option, you must apply to the EPA regional administrator with an
alternate disposal plan that shows the plan will not pose an unreasonable risk of injury to healthy or the
environment and await the EPA’s written decision.
L.
DECONTAMINATION
This new section establishes decontamination standards and procedures for removing PCBs
from certain materials. Disposal approval is not required. Once an item is decontaminated, it can sold,
used or reused.
1. Applicability and methods - Decontamination methods can be applied to water, organic fluids,
non-porous surfaces, concrete and certain porous surfaces. Some examples of acceptable methods of
removing PCBs from the item include: chopping, distilling, filtering, oil/water separation, spraying,
soaking, wiping, stripping of insulation, scraping and/or scarification.
2. Standards - Decontamination can be obtained by either a measurement standard or a self11-20-2000
implementing procedure.
Under the measurement standard:
* Water must be reduced to < 200 ug/L for non-contact use in a closed system; <3 ug/L for
water discharged to a navigable system; or < 0.5 ug/L for unrestricted use. Due to various CWA
regulations, contact Mark Landa if you wish to exercise this option.
* Organic liquids must be reduced to <2mg/kg
2
* Nonfor unrestricted use and < 100
2
ug/100cm for smelter disposal.
2
*
if decontamination is started within 72 hours
of the initial spill.
Under the measurement based standard, confirmatory sampling must be performed and records kept.
Under the self-implementing decontamination standard:
* PCB containers must be triple flushed with a solvent equal to about 10% of container’s
capacity and solvent must contain < 50 ppm of PCBs.
* Moveable equipment must either: (1) swab surface with solvent, or (2) double wash/rinse.
* For non-porous surfaces in contact with free-flowing mineral oil dielectric fluid, contact the
Iowa Environmental Group for instructions.
For self-implementing decontamination, keep records of compliance with the regulations.
3. Disposal - Decontamination wastes and residues must be disposed of at their existing PCB
concentration. Solvents > 50 ppm must be incinerated or disposed of at a high-efficiency boiler.
Solvents < 50 ppm can be reused. Other cleaning materials and protective equipment must be disposed
of in a RCRA landfill or other disposal facility.
III. TESTING PROCEDURES
References to PCB concentrations relate to the level of concentration of the PCB oil, even if
tests of other material contaminated by the oil show a lower concentration. Oil may not be diluted to
avoid application of the regulations.
Chlor-N-Oil tests are not approved by EPA, and neither the EPA nor the IDNR will accept test
results from Chlor-N-Oil kits. You must bring or send oil samples to a laboratory, and the lab must
use gas chromatography in order to have the EPA and IDNR accept your test results.
A. Mineral Oil
1. Dielectric fluid removed from mineral oil dielectric fluid electrical equipment may be
collected in a common container. Other chemical substances or mixtures may not be added to the
container and the collected oil may not be diluted.
Mineral oil which is known or assumed to be 50 ppm or greater PCBs must not be mixed with
mineral oil known or assumed to be less than 50 ppm PCBs to reduce the concentration of PCBs in the
common container.
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If the PCB concentration of oil is unknown, the concentration is assumed to be at least 50 ppm.
If oil or items with an unknown PCB concentration are mixed with other oil or items, the entire
contents of the container are assumed to be at least 50 ppm. This assumption may be overcome only
by approved tests showing the PCB concentration to be less than 50 ppm. Chlor-N-Oil tests are not
approved by EPA.
If any PCBs at a concentration of 500 ppm or greater have been added to the container or
equipment, then the total container contents must be considered as having a PCB concentration of 500
ppm or greater for the purposes of disposal.
2. For purposes of complying with the marking and disposal requirements, representative
samples may be taken from either the common containers or the individual electrical equipment to
determine the PCB concentration.
B.
Waste Oil
The following procedures may be used to determine the PCB concentration of waste oil:
1. The waste oil from more than one source may be collected in a common container.
However, other chemical substances or mixtures, such as non-waste oils, may not be added to the
container.
2. For the purposes of marking and disposal, waste oil may be collected in a common
container (drum). If only oil which has a PCB concentration of less than 500 ppm is added, the oil
may be tested and disposed of in the manner required for oil of the PCB concentration determined to
exist at the time of testing. If, however, any waste oil with a PCB concentration of 500 ppm or greater
is added to the container, the entire contents of the container is to be disposed of as if it were 500 ppm
or greater, regardless of its actual concentration.
C.
Testing Laboratories
One laboratory which reportedly conducts PCB concentration tests at a reasonable price is:
National Chem Labs
P.O. Box 635
103 12th Avenue
Ephrata, Washington 98823
(509) 754-5725
The authors of this manual are not endorsing this company. However, this is one company to
call for price and service quotes.
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IV.
EPA IDENTIFICATION NUMBERS
Each rural electric cooperative which disposes of PCB waste and which has a permanent
storage for disposal area or a storage container for liquid PCBs (this will be essentially everyone who
is not PCB-free - see the Storage section of this manual) must have obtained an EPA identification
number by filing a form by April 4, 1990. The purpose of obtaining this number is to notify the EPA
of your PCB waste handling activities. If you do not yet have an EPA identification number for your
PCB waste activities, please call Mark Landa at (515) 244-3500 immediately.
All generators, (unless they fit within a very narrow exception) transporters, disposers, and
commercial storers of PCB waste must have an EPA identification number.
A.
Obtaining an EPA identification number.
You must file EPA Form 7710-53 with the EPA to get an EPA identification number. To get
EPA Form 7710-53, you may write to:
Chemical Regulation Branch (TS-798)
Office of Toxic Substances
Environmental Protection Agency
401 M Street S.W.
Washington, D.C. 20460
A copy of EPA Form 7710-53 is attached to the end of section 13.
Once you have filled out your form, you must mail it to:
Chief, Chemical Regulation Branch (TS-798)
Office of Toxic Substances
Environmental Protection Agency
Room NE-117
401 M Street S.W.
Washington, D.C. 20460
Until you get your EPA identification number, use "40 CFR Part 761" as your EPA
Identification number on all manifests and required records.
You must submit a separate notification to the EPA for each of your PCB storage facilities.
EPA will assign you unique EPA identification numbers for each of your storage facilities.
B. Generators
After June 4, 1990, generators may not process, store, dispose of, transport, or offer for
transportation PCB waste without having an EPA identification number.
NOTE: If you already have an EPA identification number for RCRA hazardous waste
activities, you must still file EPA Form 7710-53 with the EPA. Your notification must include the
EPA identification number previously issued to you under RCRA. Upon receipt of notification, the
EPA will verify and authorize you to use your RCRA identification number for PCB waste activities.
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You may not offer your PCB waste to transporters, disposers, or commercial storers who have
not received an EPA identification number.
V.
MANIFESTS
Manifesting is required when PCB or PCB-contaminated material leaves your control, as when
you give the material to a transporter for disposal. Manifesting is not required when you transport the
materials within your own operation. However, if you use your own trucks to transport the PCB waste
to a commercial storer or disposal company, you must manifest the waste.
These requirements apply to PCB wastes with PCB concentrations of 50 ppm or greater and
wastes which exhibit a concentration of less than 50 ppm because of dilution. An example of such a
waste is spill cleanup material which contains less than 50 ppm PCB’s but which results from the
spilling of PCB oil which exceeds 50 ppm.
The generator is required to prepare the manifest.
A. The Manifest (EPA Form 8700-22)
The manifest must specify:
1. The name, address, and EPA identification number for each EPA approved off-site commercial
storage facility, transporter, or disposal facility designated by the generator. The generator’s
name, address and EPA identification number.
2. For each bulk load of wastes:
a. The identity of the PCB waste,
b. The earliest date of removal from service for disposal, and
c. The weight in kilograms of the PCB waste.
3. For each PCB article container or PCB container:
a. The unique identifying number,
b. The type of PCB waste (ie, soil, debris, small capacitor),
c. The earliest date of removal from service for disposal, and
d. The weight in kilograms of the PCB waste.
4. For each PCB article not in a PCB container or PCB article container:
a. The serial number if available, or other identification if there is no serial number,
b. The date of removal from service for disposal, and
c. The weight in kilograms of the PCB waste in each PCB article.
Attached is a copy of the EPA manifest.
Some states have their own manifests which are required when PCB material is sent to, or
sometimes even through, that state (ie, Missouri). Iowa does not have its own manifest form so the
federal manifest form must be used. However, if the material will be leaving Iowa, it is necessary to
check with those states for their requirements. A copy of the Missouri manifest is also attached.
B. Which Manifest to Use
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If the state receiving the shipment requires that the receiving state’s manifest be used, then you must
use the receiving state’s manifest.
If the receiving state does not have, or does not require use of, its own state manifest, but the shipping
state does require the use of its state manifest, then you must use the shipping state’s manifest.
If both the receiving state and the state from which the shipment is sent require use of their respective
state manifests, then you must use the manifest of the receiving state.
If neither the receiving or shipping state require use of their own state manifest, then you should use
the federal manifest. The PCB regulations say in this case, you may obtain the manifest from any
source.
C. Number of Copies of the Manifest
You must supply enough copies of the manifest for each of the following parties or purposes:
1. The generator (REC),
2. The initial transporter,
3. Each subsequent transporter,
4. The owner or operator of the designated commercial storage or disposal facility, and
5. One copy to be returned to the generator by the owner or operator of the facility.
D. Use of the Manifest
As the generator of PCB waste, you must prepare the manifest and:
1. Sign the manifest certification by hand,
2. Obtain the handwritten signature of the initial transporter and the date of acceptance of the
manifest,
3. Retain one copy with your records,
4. Give the transporter the remaining copies of the manifest that will accompany the shipment of
PCB waste.
If you ship your PCB waste by water or rail, refer to 40 CFR 761.208 (2) and (3).
E. Using an Independent Transporter
If you use an independent transporter to ship your PCB waste, before leaving your cooperative,
the transporter must sign and date the manifest and must return a signed copy of the manifest to you.
If you use an independent transporter to ship the PCB waste to a commercial storer or disposal
facility, you must confirm that the commercial storer or disposer actually received the manifested
waste. This confirmation may be done by telephone, or by other means of confirmation agreed to by
both parties, but must be completed by the close of the business day after you receive the returned
manifest which has been signed by the commercial storer or disposer.
If you have not received the signed manifest within 45 days after the independent transporter
accepted the PCB waste, you must contact the commercial storer or disposer to determine whether the
PCB waste was actually received. If the disposer did not receive the PCB waste, you must contact the
independent transporter to determine what happened to the PCB waste. The follow-up may be done by
telephone, or by other means of confirmation agreed to by both parties. If you have not received the
signed manifest from the storer or disposer within 10 days of the follow-up communication with the
independent transporter you must file an exception report with the regional EPA office. (See section J
for a more detailed discussion of this report.)
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You must retain a written record of all telephone or other confirmations in your annual
document log.
If the waste cannot be delivered to the facility which you have designated, the transporter is to
contact you for further instructions and is to revise the manifest and/or return the waste to you.
F. Transporter Requirements
There are specific requirements which a transporter of PCB waste must meet concerning the
use of manifests. It is assumed that the cooperatives will generally use independent contractors. For
this reason, the transporter requirements are not discussed. Should your cooperative act as a
transporter, you will need to follow the requirements of section 761.208(b) of the PCB regulations (40
CFR 761.208(b)), and the DOT Regulations at 49 CFR part 171. You may consult the authors of this
manual at (515) 244-3500.
A "transporter of PCB waste" is any person engaged in the transportation of regulated PCB
waste by air, rail, highway, or water for purposes other than consolidation by a generator.
G. Commercial Storer Requirements
There are specific requirements which a commercial storer of PCB waste must meet concerning
the use of manifests. It is assumed that the cooperatives will generally not serve as commercial storers.
For this reason, the commercial storer requirements are not discussed. Should your cooperative act as
a commercial storer, you will need to follow the requirements of section 761.208(c) of the PCB
regulations (40 CFR 761.208(c)).
A word of caution. A "commercial storer of PCB waste" is the owner or operator of facility
who engages in storage activities involving PCB waste generated by others, or PCB waste that was
removed while servicing the equipment owned by others and brokered for disposal. The receipt of a
fee or any other form of compensation for storage services is not necessary to qualify as a commercial
storer of PCB waste. A generator who stores only the generator’s own waste is subject to storage
requirements, but is not required to seek approval as a commercial storer.
It is important to note that a commercial storer is subject to substantial additional regulations.
Therefore, it is advisable that cooperatives not get themselves into a situation which would result in the
commercial storer classification. Do not agree to store PCB waste generated by another, regardless of
the quantity.
H. Retention of Manifest Records
As a generator, you must keep the signed copy of the manifest you send with the transporter
until you receive the signed copy back from the commercial storer or disposer. The final signed copy
you receive from the commercial storer or disposer must be retained for at least 3 years from the date
the PCB waste was accepted by the initial transporter. In practice, it is advisable to keep the completed
manifest indefinitely. Superfund cleanup sites can arise years in the future. Having the manifest in
your records is proof of where the PCB waste was sent and how it was handled.
The manifest records must be included in your annual document log. For more information on
the annual document log, see the Recordkeeping section.
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I. Manifest Discrepancies
Manifest discrepancies are differences between the quantity or type of PCB waste designated
on the manifest or shipping paper and the quantity or type of PCB waste actually delivered to, and
received by, the designated facility.
1. Significant discrepancies in quantity are:
a. Variations greater than 10% in weight of PCB waste in containers.
b. Any variation in piece count, like discrepancy of one PCB transformer.
2. Significant discrepancies in type of PCB waste are:
a. Obvious differences which may be discovered by inspection or waste analysis. Examples
include substitution of solids for liquids or the substitution of high concentration PCBs
(above 500 ppm) with lower concentration materials.
The owner or operator of the commercial storage or disposal facility is required to contact the
generator of the PCB waste if a discrepancy is discovered when the shipment arrives. The two parties
and the transporter must attempt to reconcile the discrepancy. If the discrepancy is not resolved within
15 days after receiving the PCB waste, the owner or operator of the receiving facility must submit a
letter to the regional EPA office describing the discrepancy and the attempts to reconcile the matter,
and a copy of the manifest at issue.
While the responsibility to reconcile the manifest with the contents of the shipment appears to
be on the commercial storer or disposer, it is also in your best interest to reconcile any discrepancies.
EPA will probably get involved otherwise and attempt to determine where and why the discrepancy
occurred.
J. Manifest Confirmation Exception Reports
If you have not received the signed manifest within 45 days after the independent transporter
accepted the PCB waste, you must contact the commercial storer or disposer to determine whether the
PCB waste was actually received. If the disposer did not receive the PCB waste, you must contact the
independent transporter to determine what happened to the PCB waste. The follow-up may be done by
telephone, or by other means of confirmation agreed to by both parties.
If you have not received the signed manifest within 45 days of the date the waste was accepted
by the independent transporter, you must file an exception report with the regional EPA office. The
exception report must be filed no later than 45 days from the date on which the generator (REC) should
have received the manifest.
The exception report must include the following information:
1)
A legible copy of the manifest; and
2)
A cover letter signed by the generator (REC) explaining the efforts taken to locate the
PCB waste and the results of those efforts.
You must keep a written record of all telephone or other confirmations and include them in
your annual document log.
VI.
ONE-YEAR DISPOSAL EXCEPTION REPORT
You must file a One-year Exception Report within 45 days if disposal is not properly
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confirmed by the disposer, or if confirmation indicates that disposal occurred more than 1 year from
the date of removal from service for disposal.
A.
Disposal Not Confirmed Within 13 Months of Removal
You are required to transport PCB or PCB items to a disposer within 9 months of removal from
service for disposal. If you have done so, but have not received a Certificate of Disposal from the
disposer within 13 months of removal from service, you must file an Exception Report with the
Regional Administrator of EPA.
B.
Actual Disposal More Than One Year After Removal from Service for Disposal
If you receive a Certificate of Disposal from the disposer which shows that the PCB waste was
disposed of more than one year after the date of removal from service for disposal, you must file an
Exception Report.
C.
Information Required in One-year Exception Report
The following information must be included in a One-year Exception Report required under the above
sections:
1. A legible copy of the manifest or other written communication relevant to the transfer and
disposal of the affected PCBs or PCB items;
2. A cover letter signed by the REC’s authorized representative explaining:
a) The date(s) of removal from service for disposal;
b) The date(s) transported to the designated disposal facility;
c) The identity of the transporters, commercial storers, or disposers known to be involved with
the transaction; and
d) The reason, if known, for the delay in bringing about the disposal within one year from the
date of removal from service for disposal.
NOTE: The EPA has sent a letter which acknowledges that there is a shortage of disposal
capacity for PCBs. A copy of this letter is attached. If you have attempted to comply with the disposal
requirements in a timely fashion, but cannot comply through no delay of your own because of the
shortage of capacity, follow the steps outlined in the letter and note this in detail in your Exception
Report.
VII.
CERTIFICATE OF DISPOSAL
The PCB regulations provide that any PCB Article or PCB Container stored for disposal must
be transferred from the generator to the disposer within 9 months from the date of removal from
service for disposal and must be disposed of within one year from the date when it was first placed into
storage for disposal. The final document which is used to track compliance with these requirements is
the Certificate of Disposal.
Within 30 days of the date of disposal, the owner or operator of the disposal facility is required
to send the generator a Certificate of Disposal which includes the EPA ID# and identity of the disposal
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facility, the identity of the waste disposed of including the manifest number for the shipment, and a
statement certifying that the waste was disposed of, the date of disposal, and the disposal process used.
You, as the generator, are required to keep a copy of this Certificate as a part of your annual
documents. (See the Recordkeeping section for information regarding these requirements.)
If you do not receive a Certificate of Disposal within 13 months of the date of removal from
service for disposal, or if the Certificate indicates that the disposal took place on a date more than 1
year after the removal from service for disposal you must submit a One-year Exception Report to the
EPA. This process is discussed in the following subsection.
VIII. SHIPPING CONTAINERS
All shipping containers must be properly labeled.
A.
Transformers
Transformers may only be shipped in a totally enclosed manner. If the transformer is weeping
or leaking to any extent, the transformer must be enclosed in a DOT Specification 17C, 5 or 5B drum.
If the transformer is totally enclosed, it may be shipped without being placed in a drum or drained.
NOTE: 17H drums are no longer acceptable. If transformers are too large to fit in the 55gallon drums, they may be shipped in larger containers if the containers are designed and constructed
in a manner that will provide as much protection against leaking and exposure to the environment as
the 17C or 17E drums, and are of the same strength and durability as the 17C or 17E drums.
B.
Capacitors
The regulations require that capacitors be placed in drums only when leaking or bulging.
However, some disposal companies (including APTUS) prefer that capacitors be placed in drums.
They may accept non-leaking and non-bulging capacitors when banded together and banded onto a
pallet.
C.
Liquids
PCB liquids and PCB-contaminated liquids must be shipped in a DOT Specification 5 or 5B
drum without removable head, 6D with overpack with Specification 25 or 25L - polyethylene, or 17E
container the container must be properly labeled to show the contents, to warn of its hazards.
D.
Waste Rags, Debris, and Dirt
These materials must be shipped in a DOT 17C drum, or other containers specified above for
transformers.
NOTE: A copy of APTUS’ shipping guidelines is attached.
IX. SOURCES OF ASSISTANCE
Listed below are some sources of technical information concerning the disposal of PCBs. This is not a
complete list and no recommendation of their abilities is made by the authors of this manual.
However, they are provided for your consideration.
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Members of the Iowa Environmental Group may call or write to Mark Landa at 801 Grand, Suite 3500,
Des Moines, Iowa 50309 (515) 244-3500.
A. Private Consultants
Regulatory Compliance Services, Inc.
Mark and John Pennell
P.O. Box 4642
Springfield, Missouri 65508
(417) 886-4580
B. Government Assistance
Mazzie Talley
EPA - Region VII
726 Minnesota Ave.
Kansas City, KS
(913) 551-7518
Iowa Waste Reduction Center
University of Northern Iowa
75 Biology Research Complex
Cedar Falls, Iowa 50614
(319) 273-2079
C. Testing Laboratories
National Chem Labs
P.O. Box 635
103 12th Avenue
Ephrata, Washington 98823
(509) 754-5725
D. Disposal Companies
Attached is an EPA list of commercially permitted PCB Disposal companies as of August 12, 1998.
APTUS
Highway 169 North
P.O. Box 1328
Coffeyville, Kansas 67337
Gene Hamlin (Utility Rep)
Deb Tilque (Iowa Rep)
E.
(800) 292-2558
(800) 328-4061
(612) 469-8454
Written Information
PCB Equipment, Operations and Management Reference Manual prepared by SCS
Engineers, Inc. for
Energy Research and Development Division
Energy and Environmental Policy Dept.
National Rural Electric Cooperative Assoc.
1800 Massachusetts Ave., N.W.
Washington, D.C. 20036
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