Polychlorinated Biphenyls (PCBs) are a group of highly toxic artificial chemicals that persist in the environment for long periods of time. PCBs have both serious carcinogenic and noncarcinogenic health effects, including on the immune, reproductive and endocrine systems.
PCBs were manufactured in the U.S. between 1929 and 1979, until Congress banned domestic production under the Toxic Substances Control Act (TSCA), barring some exceptions for inadvertent generation of PCBs in excluded manufacturing process. However, PCBs persist in materials produced earlier, including transformers and capacitors, electrical equipment, oil products, light ballasts, cable insulation, thermal insulation material, adhesives, caulking, plastics, carbonless copy paper and floor finish.
Local and Tribal governments may incur obligations to monitor and even remediate PCBs in the following categories:
- Municipally owned or leased buildings constructed prior to 1979, such as schools, day cares, recreation centers, public housing and office buildings where city employees work.
- Contaminated water bodies impacting drinking water supplies.
- PCB-containing materials damaged during natural disasters, causing spills and leaks.
PCBs are primarily regulated under TSCA, which sets forth a number of monitoring and clean-up obligations applicable to local governments (they are not regulated under the Resource Conservation and Recovery Act (RCRA), as they are not considered hazardous wastes).
Sampling requirements are triggered when a PCB remediation is performed or the presence of PCBs is suspected, such as when carrying out renovation or repair activities in buildings constructed prior to 1979. Sampling is also required to verify completion of a cleanup or disposal. Different methods of sampling will be required based on the characteristics of the cleanup site. EPA guidelines set forth sampling procedures, based on the material to be sampled and the intended goal. EPA also provides sampling guidance on building characterization and sampling plans and sample collection and documentation procedures. A PCB remediation contractor should be contacted to perform the sampling procedures.
Recordkeeping requirements span keeping records of samples taken before and after clean-up activities, any required EPA approval and copies of each Certificate of Disposal when disposing of PCB waste at an approved facility. Sampling for concentrations of bulk PCB remediation waste and porous surfaces should be carried out on a dry weight basis as parts per million (ppm) by weight and kept on file for three years.
There are three approved strategies for remediating PCB waste, or waste containing PCBs released into the environment from a spill, release or other unauthorized disposal of PCBs. Local and Tribal governments should first consult their EPA regional PCB program coordinator to determine the best method and gain advice on how to proceed based on the circumstances. The PCB Facility Approval Streamlining Toolbox (FAST) is a helpful resource in this process.
- Self-implementing cleanups, generally used for moderately sized sites where there will be low residual environmental impact from remedial activities, require notifying the EPA Regional Administrator, the Director of the State or Tribal environmental protection agency and the Director of the county or local environmental protection agency. Submitting a copy of the notification to the EPA Regional PCB Coordinator will expedite the process. Notification must occur at least 30 days prior to date of cleanup and include information on the nature of the contamination, sampling procedures and cleanup plan, as well as certification from the owner of the property. EPA is currently updating this option in a rulemaking.
- Performance-based disposal, recommended for disposing of solid PCB remediation waste via a landfill, incinerator (required for PCB liquids at 50 ppm concentrations or higher) or other TSCA-approved disposal method. No EPA notification or approval is required at this time. EPA is currently updating this option in a rulemaking.
- Risk-based cleanup and disposal covers all other forms of disposal and requires EPA approval from the EPA via an application (found on page 39 of the PCB FAST).
EPA's PCB spill cleanup policy applies to spills less than 72 hours old with PCB source concentrations greater than or equal to 50 ppm concentration. The Regional Administrator may require additional cleanup activities or allow for less stringent or alternative decontamination procedures based on the individual situation. The policy excludes certain types of spills (e.g., spills directly into surface waters, drinking waters, sewers, grazing lands and vegetable gardens); however, these types of spills remain subject to site-specific requirements established by the EPA regional office.
Less stringent requirements for low concentration spills (less than 500 ppm) that involve under 1 pound of PCBs by weight or under 270 gallons of untested mineral oil.
- Double wash and clean all indoor surfaces (using standard commercial wipe tests).
- Excavate soil in the spill area and restore the ground to its original configuration.
- Document and certify the cleanup, maintain these records for at least 5 years.
More stringent requirements for high concentration spills (greater than 500 ppm) or spills more than one pound or more PCBs by weight.
- Begin cleanup within 24 hours.
- Contact the EPA regional office and the National Response Center (1-800-424-8802).
- Cordon off the contaminated area and put-up signs making clear there is PCB contamination.
- Document the area of contamination (contacting the EPA regional office for guidance in sampling the area if there are no visible traces).
- Document and certify the cleanup, maintaining these records for at least 5 years.
PCB-containing solids and liquids removed from use must be disposed of or decontaminated. This also applies to PCB remediation waste between 50ppm and less than 500ppm.
PCB liquids of concentrations of at least 50ppm must be disposed of in an approved incinerator. Proper method of disposal also depends on the exact type of item that is being disposed of (set out in regulations). Certain PCB articles may be stored prior to disposal, but only at an approved facility; some facilities received approval only for specific decontamination processes.Back to Top
PCBs may be present in Tribal schools, office buildings, waters and homes constructed prior to 1979. Tribal citizens often have a higher fish consumption rate (FCR) than the general U.S. population and, as the highest human exposures to PCBs are through consumption of contaminated fish. Tribes should be aware of when there are fish advisories due to PCBs.
Though TSCA is silent on the role of Tribes, EPA has interpreted TSCA to authorize Tribal participation. EPA allows Tribes to administer and enforce certain TSCA programs and apply for TSCA grants. The National Tribal Toxics Council (NTTC) is an EPA Tribal Partnership Group that provides Tribes with an opportunity for greater input on issues related to toxic chemicals and pollution prevention. NTTC comments on EPA rules and works with EPA administrators to ensure Tribal input, including on issues related to PCBs.
- Regional PCB Coordinator Contact Information. List of states per Regional Office and their contact information, including the regional hotline and EPA regional 24-hour spill hotline.
- PCB Question and Answer Manual. Frequently asked questions about TSCA and EPA's rules regarding PCB regulations.
- List of Approved PCB Commercial Storage and Disposal Facilities. Comprehensive list of facilities approved by EPA for storage or disposal of commercial PCB waste.
- PCB Facility Approval Streaming Toolbox. Framework for streamlining PCB Site Cleanup Approvals, including helpful guidance, flow charts and checklists.
- PCBs in Building Material. Information about PCBs in building materials targeted to school administrators, building owners and managers, and contractors. Includes testing methods and EPA research on PCBs in buildings.
- PCBs in Building Materials—Questions and Answers. Frequently asked questions on addressing PCBs in building materials.
- Guide for Determining PCBs in Building Materials. Information on determining the presence of manufactured PCB products in buildings. Includes recommendations on sampling, testing and evaluating building records for key dates on construction and renovation.
- How to Manage PCB Containing Materials in School Buildings. Flowchart setting out a series of containment strategies.
- Practical Actions for Reducing Exposure to PCBs in Schools and Other Buildings. Factsheet on reducing PCB exposure and best management practices for affected building. Includes instructions on actions such as removing PCB-containing caulk and paint.
- Instructions on Removing PCB Containing Fluorescent Light Ballasts. Information on how to check if PCB-containing fluorescent light ballasts need to be replaced and proper methods.
- Testing Methods for Indoor Air. EPA's two approved methods for determining the presence of PCBs in indoor air.
- Exposure Levels for Evaluating PCBs in Indoor School Air. EPA calculations on the exposure levels for PCBs where harmful effects may start to occur.
- Sampling Guidance. Directions for sampling for PCBs, based on the type of material.
- Guidance for Safe Renovation and Repair Activities. Instructions on how: a renovation or repair project can be safely carried out, including creating a secure work area, communicating with building occupants and third parties, and properly following OSHA regulations.
- Planning for PCB Containing Disaster Debris. Guidance on how to plan for PCB assessment, cleanup, and disposal during and after a natural disaster.
- Agency for Toxic Substances and Disease Registry. Information on PCB exposure, including standards and regulations. Includes a training course for professionals to understand the standards and regulations that exist for PCB exposure in drinking water, food and workplaces.
- National Tribal Toxics Council. Information about PCBs customized for Tribes.
- National Tribal Water Council. Represents Tribes in matters relating to water.
- National Tribal Air Council. Represents Tribes in matters relating to air.
- Tribal Waste and Response Steering Committee. Represents Tribes regarding waste and contaminated sites.
- California PCB Evaluation Quick Reference Guide. Information on PCBs and coordinating between local and federal agencies.
- Massachusetts PCB in Building Materials. FAQ for local and State agencies for addressing PCB contamination of building materials.