PCBs in Demolition Debris Summary

The Washington State Department of Ecology's Hazardous Waste Program and the United States Environmental Protection Agency regulate PCB wastes above certain concentrations because they are toxic to people and other living things.


What are PCBs?

PCBs (polychlorinated biphenyls) are a type of organic chemical known as chlorinated hydrocarbons. PCBs are formed from a combination of one or more chlorine atoms and two benzene molecules. Two other names for PCBs are arochlors and chlorodiphenyls. In any PCB commercial mixture there may be 40 to 70 different compounds present.

PCB's appear in several forms, including oily light yellow liquids, waxy solids or resins, or white powders. All are practically odorless, flammable, sink to the bottom in bodies of water, and dissolve only slightly.

PCB compounds were used in older construction products and are still found in building waste.  Although manufacturing ended PCBs were allowed to remain in use. Many people do not realize that new PCBs are created when treated wood or plastics are burned.

Identification of PCBs in products such as paints and insulation depends upon testing at this time. In a few products a brand name can be used to identify manufactured items that contain PCBs.

See PCB Definitions  Exit Ecology and PCB ID-PCB Species Identification  Exit Ecology  from EPA Region 5

See Polychlorinated Biphenyls (PCBs) under Other Potentially Regulated Building Wastes for brand names and synonyms.

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PCB Waste in Buildings

PCBs have spread throughout the environment since the beginning of their commercial use in 1929. Over 1 billion pounds of PCBs were produced before their production was halted in 1976. Around 312 million pounds are still in use as insulation, heat-transfer, or hydraulic fluids. It is estimated that 20 to 30 years will elapse before all PCBs in use will be disposed of or destroyed.

New PCBs are un-intentionally created as a result of certain manufacturing processes and burning treated wood and plastics.

PCBs are commonly encountered at hazardous waste cleanup sites in Washington State.

Electrical Equipment

Before 1979, PCBs were widely used in for their cooling properties because they do not readily burn or conduct electricity, and they only boil at high temperature.

Most PCB contaminated electrical equipment that is in current use was manufactured to use other fluids but was contaminated with PCBs during manufacturing or servicing. Refer to the Federal Register, June 29, 1998 (Volume 63, Number 124) Disposal of Polychlorinated Biphenyls (PCBs); Final Rule, Background, pages 35385-35386.  http://www.epa.gov/fedrgstr/EPA-TOX/1998/June/Day-29/t17048.pdf Exit Ecology

Non-electrical Manufactured Items

Other Wastes:

New PCBs are created when chlorine (for example in plastics or treated wood), hydrocarbons and a catalyst or heat source (such as a fire) are brought together.

See Index to Potentially Regulated Building Wastes for links to information about paint and other products manufactured with PCBs.

See Polychlorinated Biphenyls (PCBs) under Other Potentially Regulated Building Wastes for brand names and synonyms.

Contact Ecology's Toxics Cleanup Program for information about the cleanup of PCB contaminated soil.

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Identification, Sampling and Testing

The most accurate way to determine lead, mercury, asbestos, PCBs and other environmental and health hazards at a site is to hire an independent hazard assessment expert to survey for them. An assessment contractor should be separate and financially independent from any environmental remediation companies that could be hired to remove the hazards.

EPA Requirements

Start PCB identification with the EPA's federal TSCA PCB sampling and testing requirements and procedures. The regulation,  40 CFR Part 761, was extensively revised in 1998. EPA's regulations are on their PCB Home Page at http://www.epa.gov/pcb/ Exit Ecology.

Call Dan Duncan, (206) 553-6693 at EPA Region 10, in Seattle for help. Region 10 has an excellent PCB Site  Exit Ecology. Ecology does not have authority to interpret federal PCB rules.

PCB marking is required by TSCA for items (containers, transformers, capacitors, electric motors, hydraulic systems, heat transfer systems and storage areas) that have PCBs and that were in existence after July 1, 1978. If an item that is typically known to contain PCBs does not have a "No PCB" label, presume it contains PCBs. Under TSCA, the generator of PCB waste is any person whose act or process produces PCBs that are regulated for disposal, or whose act first causes PCBs or PCB Items to become subject to the disposal requirements, or who has physical control over the PCBs when a decision is made to dispose of them.

State Requirements

The Dangerous Waste Regulations WAC (Washington Administrative Code) Chapter 173-303 Exit Ecology are concerned with PCBs in waste codes WPCB, WP01 or WP02:

WPCB - Undrained transformers, capacitors, and bushings containing PCB fluids with concentrations of 2 parts per million (ppm) or greater PCBs, and certain wastes from salvaging, rebuilding or discarding them.

Capacitors are devices for accumulating and holding a charge of electricity that contain a dielectric fluid. Capacitors are not drained or serviced and cannot be tested without destroying them.

Electrical items that were manufactured without PCBs or that were drained of federally regulated PCBs are often contaminated with lower level PCBs regulated by Ecology.

A "No PCB" label means there are less than 50 ppm PCBs but Washington starts regulation at 2 ppm. These items may be regulated by Ecology.

See "WPCB" at WAC 173-303-9904 Exit Ecology  or "WPCB" PCB Waste Code on this web site for the complete description of the waste code.

WP01 or WP02 - Wastes with 100 ppm or greater Halogenated Organic Compounds from PCBs.

EPA would most already likely regulate WP01 or WP02 PCB wastes due to the high concentration necessary for the dangerous waste designation.

See WAC 173-303-040 Exit Ecology for the definition of Halogenated Organic Compounds

See WAC 173-303-100 or Ten Designation Steps, Ten - Washington State Persistent Criteria on this web site for WP01 or WP02 designation information.

Under the Dangerous Waste Regulations the generator is any person, by site, whose act or process produces dangerous waste or whose act first causes a dangerous waste to become subject to regulation.

Sampling and Testing

Identification of PCBs in products such as paints and insulation depends upon testing at this time. In a few products a brand name can be used to identify manufactured items that contain PCBs.

Several dangerous waste tests can detect PCBs. Call the testing lab for guidance on which test to use and how to take a sample.

Refer to Chemical Test Methods for Designating Dangerous Waste, Ecology Publication #97-407 for more information. A copy is available from (360) 407-6752 or (360) 407-6038.

See Dangerous Waste Disposal Sampling Requirements and Dangerous Waste Test Methods Summary, PCBs for information about the Sampling and Testing Methods and Representative Samples cited in the Dangerous Waste Regulations, WAC 173-303-110 Exit Ecology

See Suggested Sampling Plans for Building Debris Disposal for suggestions about sampling entire buildings or parts of buildings for hazardous materials. Sampling of mixed building waste is difficult and is not currently addressed in the Dangerous Waste Regulations. 

Further Information:

See Dangerous Waste Identification / Designation for basic information or Ten Designation Steps  to identify a waste for dangerous waste disposal. 

Selected Exclusions for Building Wastes see Polychlorinated biphenyls

Refer to Generator Status and Requirements for more Dangerous Waste information.

Contact Ecology's Toxics Cleanup Program  for information about the definition of PCB contaminated soil.

Local Guidance

Guidance on PCBs Exit Ecology  King County, WA Yellow Book 

Fluorescent Light Ballasts Exit Ecology  King County, WA Yellow Book

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Notification, Labeling, Packaging and Transportation

Use test results and any resulting waste codes from designation to determine your management requirements. Both the Dangerous Waste Regulations and EPA's TSCA regulations require:

The Department of Transportation, Federal Highway Administration, Utilities and Transportation Commission, and the Washington State Patrol have transportation regulations for PCBs whether or not they are regulated as wastes.

PCB wastes that that designate as dangerous wastes and that are generated by regulated generators (rather than Small Quantity Generators or Household Hazardous Waste Generators) must be managed under the same labeling, manifesting and transportation rules as other dangerous wastes.

Region 10 EPA PCB Site Exit Ecology

National EPA PCB Site Exit Ecology

Dangerous Waste  Generator Status and Requirements

State Dangerous Waste Dangerous Waste Transportation Requirements

Washington Utilities and Transportation Commission (WUTC) Exit Ecology.

The Washington State Patrol (WSP), Commercial Vehicle Enforcement Section  http://www.wsp.wa.gov/ Exit Ecology.

The US Department of Transportation http://www.dot.gov/ Exit Ecology.

The Office of Hazardous Materials Safety  http://hazmat.dot.gov/ Exit Ecology.

The Federal Highway Administration  http://www.fhwa.dot.gov Exit Ecology

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Disposal Requirements

EPA Requirements

Disposal of federally regulated PCB wastes must follow EPA's TSCA regulations found in 40 CFR part 761:

Further Information:

Region 10 EPA PCB Site  Exit Ecology

National EPA PCB Disposal Regulations  Exit Ecology

National EPA Commercially Permitted PCB Disposal Companies  Exit Ecology

Temporary Deferral of Land Disposal Treatment for PCBs Less than 1000 ppm in Metal-Contaminated Soil. Federal Register Vol. 65, No. 248 12/26/00 TEXT  PDF  Exit Ecology

State Requirements

State regulated PCB wastes can either be disposed as state Dangerous Wastes, or they can be excluded from the state regulations if disposed through the federal PCB requirements of 40 CFR Part 761. However, exclusion from the dangerous waste regulations is not available to all dangerous wastes containing PCBs.

Some waste codes (such as D008 for lead) will require the PCB waste to be managed under both sets of regulations.

See the PCB exclusion under WAC 173-303-071 (k) Exit Ecology for the exact wording.

The WPCB waste code description states that discarded "transformers, capacitors, and bushings" are WPCB waste, "except when drained".  It is important to check the TSCA regulations before disposing of drained items since TSCA rules are different and specific to each item.  For example, TSCA requires transformer decontamination by specific rinsing, soaking, or other approved methods if the transformer is not incinerated or thermally decontaminated.

Refer to the section titled Dangerous Waste Disposal Options for more information about dangerous waste requirements.

Solid Waste
If PCB contaminated  waste doesn't designate under TSCA or the dangerous waste rules, it's solid waste and can be disposed in solid waste facilities. Some classes of TSCA waste can be disposed in municipal solid waste landfills.  For the names of construction and demolition landfill disposal sites or haulers, contact the local health department.

Ecology's Solid Waste website lists County Solid Waste Contacts and Health Departments at http://www.ecy.wa.gov/programs/swfa/contact/othercontacts.html

Recycle as Scrap Metal
PCB coated or contaminated metal is regulated under TSCA. Check those regulations before disposing or recycling it as scrap metal. Ecology allows scrap metal with dangerous waste coatings such as lead paint to be recycled per by an exclusion from the Dangerous Waste Regulations.

For the complete text of the dangeous waste Scrap Metal exclusion (WAC 173-303-071(3)(ff)) see  Selected Exclusions from Dangerous Waste Regulations for Building Wastes or the complete list of exclusions in WAC 173-303-071 Exit Ecology from the State Code Revisers Office

As Dangerous Waste
Manage regulated wastes according to the Dangerous Waste Regulations.

Small Quantity Generator or Household Hazardous Waste status reduces the regulatory requirements.

Refer to the section titled Dangerous Waste Disposal Options for more information about dangerous waste requirements.

Guidance on PCBs Exit Ecology King County, WA Yellow Book 

Fluorescent Light Ballasts Exit Ecology  King County, WA Yellow Book

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The Regulations

EPA Requirements

EPA regulates the manufacture, processing, distribution in commerce, use, cleanup, storage and disposal of most PCB wastes. The EPA regulation,  40 CFR Part 761, was extensively revised in 1998.

Some PCB containing electrical equipment manufactured before 1978 is still in use. PCBs in use that are not leaking and are not causing exposure to humans or the environment are legal.

The actual PCB concentration must be known for disposal, or if it is spilled or otherwise released.

Further Information:

National EPA PCB Site  Exit Ecology.  Federal (TSCA) PCB rules are found in the Code of Federal Regulations 40 CFR Part 761. http://www.access.gpo.gov/nara/cfr/waisidx_99/40cfr761_99.html Exit Ecology

Region 10 EPA PCB Site  Exit Ecology.  EPA Region 10's PCB rule contact is Dan Duncan (206) 553-6693

State Requirements

The Department of Ecology's Hazardous Waste and Toxics Reduction Program regulates PCB wastes at disposal.

The Dangerous Waste Regulations are WAC (Washington Administrative Code) Chapter 173-303 Exit Ecology.

Further Information:

Guidance on PCBs Exit Ecology King County, WA Yellow Book 

Fluorescent Light Ballasts Exit Ecology  King County, WA Yellow Book

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Dangers and Health Effects

PCBs have caused cancer in animals.  Humans studies support evidence of potential cancer-causing and non-cancer effects of PCBs.

Non-cancer health effects in animals include effects on the immune system, reproductive system, nervous system, and endocrine system.

The different health effects of PCBs may be interrelated, as alterations in one system may have significant implications for the other systems of the body.

Further Information:

EPA Polychlorinated Biphenyls (PCBs) Exit Ecology

The State Department of Health provides public PCB health risk information and collects information about PCB spills.

The Agency for Toxic Substances and Disease Registry (ATSDR), an agency of the US Dept of Health and Human Services:

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Contacts

Federal PCB rules:

PCB health issues:

State PCB rules:

Contact Ecology at one of the following numbers and ask to speak to a hazardous waste specialist about Ecology's Dangerous Waste / PCB rules.

Contact Ecology's Toxics Cleanup Program  for information about the cleanup of PCB contaminated soil.

Regional telecommunications devices for the deaf (TDD) numbers are:

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