Polychlorinated Biphenyls (PCBs)

Issue Summary
U.S. EPA
Toxic Substances Control Act (TSCA)
PCB Remediation Waste
PCB Spill Cleanup
Disposal and Storage
Tribes
Resources
U.S. EPA
Other Agencies
Resources for Indian Tribes
States

Issue Summary

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. 

U.S. EPA

Toxic Substances Control Act (TSCA)

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.

PCB Remediation Waste

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.



PCB Spill Cleanup

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. 

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.


Disposal and Storage

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.

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Tribes

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. 

Resources

U.S. EPA

Other Agencies

  • 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.

Resources for Indian Tribes

States

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