PCB Inspection 

Manual 

Disclaimer 

The purpose of this manual is to provide inspectors with an indepth knowledge of the Toxic Substances Control Act (TSCA) 

Polychlorinated Biphenyl (PCB) inspection process. The mention 

of trade names, commercial products, or organizations does not 

imply endorsement by the U.S. Government. 

Table of Contents 

Table of Contents

Page 

Glossary of Terms ............................................................. v

Foreword ................................................................... ix

Chapter One PCBs: Facts 

1.0 PCBs: Facts ........................................................ 1-1

1.1 Background ......................................................... 1-1

1.2 Overview of TSCA Section 6 ............................................ 1-3

1.3 Overview of TSCA Confidential Business Information ......................... 1-7

Chapter Two Pre-Inspection Activities 

2.0 Pre-Inspection Activities ................................................. 2-1

2.1 Inspection Authority .................................................... 2-1

2.2 Preparation ........................................................... 2-1

2.3 Confidential Business Information Clearance ................................ 2-3

2.4 Equipment Preparation ................................................. 2-5

Chapter Three Inspection Procedures 

3.0 Inspection Procedures .................................................. 3-1

3.1 Entry ................................................................ 3-1

3.2 Opening Conference ................................................... 3-4

3.3 Records Assessment .................................................. 3-6

3.4 Records Verification .................................................... 3-8

3.5 Inspecting for Compliance with Disposal Requirements ....................... 3-10

3.6 Marking Assessment .................................................. 3-14

3.7 Storage Assessment .................................................. 3-15

3.8 Closing Conference ................................................... 3-18

3.9 Compliance Assistance ................................................ 3-19

Chapter Four Equipment-Specific Information 

4.0 Equipment-Specific Information ........................................... 4-1

4.1 Transformers ......................................................... 4-1

4.2 Capacitors ........................................................... 4-9

4.3 Other Electrical Equipment ............................................. 4-12

4.4 Hydraulic Systems .................................................... 4-12

4.5 Other PCB Equipment ................................................. 4-13

PCB Inspection Manual i August 2004 
Table of Contents 

Table of Contents (continued) 

Chapter Five Regulatory Requirements and Inspection Procedures 

5.0 Regulatory Requirements and Inspection Procedures ......................... 5-1

5.1 Authorizations ......................................................... 5-1

5.2 Storage for Reuse .................................................... 5-30

5.3 Marking of PCBs and PCB Items ......................................... 5-32

5.4 Storage and Disposal .................................................. 5-36

5.5 Transboundary Shipments of PCBs for Disposal ............................ 5-82

5.6 PCB Spill Cleanup Policy ............................................... 5-83

5.7 General Records and Reports ........................................... 5-90

5.8 PCB Waste Disposal Records and Reports ............................... 5-102

Chapter Six Sampling 

6.0 Sampling ........................................................... 6-1

6.1 Sampling Guidelines .................................................. 6-1

6.2 Priorities for Sampling ................................................. 6-2

6.3 Sample Collection .................................................... 6-5

6.4 General Considerations for Sampling ..................................... 6-8

6.5 Sample Documentation ............................................... 6-11

6.6 Sampling Strategies .................................................. 6-15

6.7 Sampling Hazardous Materials .......................................... 6-29

Chapter Seven Post-Inspection Activities 

7.0 Post-Inspection Activities ............................................... 7-1

7.1 Introduction .......................................................... 7-1

7.2 Inspection Follow-up .................................................. 7-1

7.3 The Inspection Report ................................................. 7-2

7.4 What To Do With the Completed Inspection Report .......................... 7-6

7.5 Data Entry ........................................................... 7-6

7.6 Appearing as a Witness ................................................. 7-7

August 2004 ii PCB Inspection Manual 
Table of Contents 

Appendices 

Appendix A Inspection Forms 

Appendix B National Policy: The Role of the EPA Inspector in Providing Compliance 

Assistance During Inspections 

Appendix C Large PCB Mark (ML) 

Appendix D Inspection Conclusion Data Sheet (ICDS) 

Appendix E PCB Manufacturers and Trade Names 

Appendix F PCBs in Underground Mines 

Appendix G PCBs in Natural Gas Pipelines 

Appendix H Submersible Pump Units that Contain PCBs 

Appendix I Incinerators 

Appendix J Chemical Waste Landfills 

Appendix K High-Efficiency Boilers 

Appendix L Alternative Disposal Methods 

Appendix M Scrap Metal Recovery Ovens and Smelters 

Appendix N Reclassification of Retrofilled Transformers 

Appendix O Sample Seal and Chain-of-Custody Form 

Appendix P Department of Transportation Hazardous Materials Training 

Appendix Q Appearing as a Witness 

PCB Inspection Manual iii August 2004 
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August 2004 iv PCB Inspection Manual 
Glossary of Terms 

Glossary of Terms

Bushing: a rigid conductor that is placed between the transformer-winding leads and the 

external conductor. Usually consists of a solid copper rod surrounded by porcelain. 

Destructive sample: a discrete sample such as a piece of wood, paving, or brick (EPA Field 

Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup.) 

Destructive sampling: using chisels, drills, and/or hole saws, to remove sufficient sample for 

analysis. 

High-concentration PCBs (as defined in §761.123): PCBs that contain 500 ppm or greater 

PCBs, or those materials which EPA requires to be assumed to contain 500 ppm or greater 

PCBs in the absence of testing. 

Investment Casting Wax: wax used to either cast small models of precious metals (mostly 

jewelry) or larger parts of steel, titanium, or alloys (precision casting). 

Liquid PCBs (as defined in §761.3): a homogenous flowable material containing PCBs and no 

more than 0.5 percent by weight non-dissolved material. 

Low-concentration PCBs (as defined in §761.123): PCBs that are tested and found to contain 

less than 500 ppm PCBs, or those PCB-containing materials which EPA requires to be 

assumed to be at concentrations below 500 ppm (i.e., untested mineral oil dielectric fluid). 

NPCD: National Program Chemicals Division. 

Network Transformer: transformers hooked up in parallel systems so that if one transformer 

fails another one will pick up the load. 

Non-liquid PCBs (as defined in §761.3): materials containing PCBs that by visual inspection 

do not flow at room temperature (25 °C or 77 °F) or from which no liquid passes when a 100 g 

or 100 ml representative sample is placed in a mesh number 60 ±5 percent paint filter and 

allowed to drain at room temperature for 5 minutes. 

PCB and PCBs (as defined in §761.3): any chemical substance that is limited to the biphenyl 

molecule that has been chlorinated to varying degrees or any combination of substances which 

contains such substance. Refer to §761.1(b) for applicable concentrations of PCBs. PCB and 

PCBs as contained in PCB items are defined in §761.3. For any purposes under this part, 

inadvertently generated non-Aroclor PCBs are defined as the total PCBs calculated following 

division of the quantity of monochlorinated biphenyls by 50 and dichlorinated biphenyls by 5. 

PCB Article (as defined in §761.3): any manufactured article, other than a PCB Container, that 

contains PCBs and whose surface(s) has been in direct contact with PCBs. ‘‘PCB Article’’ 

includes capacitors, transformers, electric motors, pumps, pipes and any other manufactured 

item (1) which is formed to a specific shape or design during manufacture, (2) which has end 

use function(s) dependent in whole or in part upon its shape or design during end use, and (3) 

which has either no change of chemical composition during its end use or only those changes of 

composition which have no commercial purpose separate from that of the PCB Article. 

PCB Inspection Manual v August 2004 
Glossary of Terms 

PCB Article Container (as defined in §761.3): any package, can, bottle, bag, barrel, drum, 

tank, or other device used to contain PCB Articles or PCB Equipment, and whose surface(s) 

has not been in direct contact with PCBs. 

PCB bulk product waste (as defined in §761.3): waste derived from manufactured products 

containing PCBs in a non-liquid state, at any concentration where the concentration at the time 

of designation for disposal was >50 ppm PCBs. PCB bulk product waste does not include PCBs 

or PCB Items regulated for disposal under §761.60(a) through (c), §761.61, §761.63, or §761.64. 

PCB bulk product waste includes, but is not limited to: 

(1) Non-liquid bulk wastes or debris from the demolition of buildings and other man-made 

structures manufactured, coated, or serviced with PCBs. PCB bulk product waste does 

not include debris from the demolition of buildings or other man-made structures that is 

contaminated by spills from regulated PCBs which have not been disposed of, 

decontaminated, or otherwise cleaned up in accordance with subpart D of this part. 

(2) PCB-containing wastes from the shredding of automobiles, household appliances, or 

industrial appliances.items are defined in §761.3. For any purposes under this part, 

inadvertently generated non-Aroclor PCBs are defined as the total PCBs calculated 

following division of the quantity of monochlorinated biphenyls by 50 and dichlorinated 

biphenyls by 5. 

(3) Plastics (such as plastic insulation from wire or cable; radio, television and computer 

casings; vehicle parts; or furniture laminates); preformed or molded rubber parts and 

components; applied dried paints, varnishes, waxes or other similar coatings or sealants; 

caulking; adhesives; paper; Galbestos; sound deadening or other types of insulation; and 

felt or fabric products such as gaskets. 

(4) Fluorescent light ballasts containing PCBs in the potting material. 

PCB Capacitor (as defined in §761.3): any capacitor that contains >500 ppm PCB. 

Concentration assumptions applicable to capacitors appear under §761.2. 

PCB Container (as defined in §761.3): any package, can, bottle, bag, barrel, drum, tank, or 

other device that contains PCBs or PCB Articles and whose surface(s) has been in direct 

contact with PCBs. 

PCB-Contaminated Electrical Equipment (as defined in §761.3): any electrical equipment 

including, but not limited to, transformers (including those used in railway locomotives and selfpropelled cars), capacitors, circuit breakers, reclosers, voltage regulators, switches (including 

sectionalizers and motor starters), electromagnets, and cable, that contains PCBs at 

concentrations of > 50 ppm and < 500 ppm in the contaminating fluid. In the absence of liquids, 

electrical equipment is PCB-Contaminated if it has PCBs at > 10 μg/100 cm2

 and < 100 μg/100 

cm2

 as measured by a standard wipe test (as defined in § 761.123) of a non-porous surface. 

PCB Equipment (as defined in §761.3): any manufactured item, other than a PCB Container 

or a PCB Article Container, which contains a PCB Article or other PCB Equipment, and includes 

microwave ovens, electronic equipment, and fluorescent light ballasts and fixtures. 

PCB Household Waste (as defined in §761.3): PCB waste that is generated by residents on 

the premises of a temporary or permanent residence for individuals (including individually owned 

or rented units of a multi-unit construction), and that is composed primarily of materials found in 

wastes generated by consumers in their homes. PCB household waste includes unwanted or 

discarded non-commercial vehicles (prior to shredding), household items, and appliances or 

appliance parts and wastes generated on the premises of a residence for individuals as a result 

August 2004 vi PCB Inspection Manual 
Glossary of Terms 

of routine household maintenance by or on behalf of the resident. Bulk or commingled liquid 

PCB wastes at concentrations of >50 ppm, demolition and renovation wastes, and industrial or 

heavy duty equipment with PCBs are not household wastes. 

PCB Item (as defined in §761.3): any PCB Article, PCB Article Container, PCB Container, PCB 

Equipment, or anything that deliberately or unintentionally contains or has as a part of it any PCB 

or PCBs. 

PCB Transformer (as defined in §761.3): any transformer that contains >500 ppm PCBs. For 

PCB concentration assumptions applicable to transformers containing 1.36 kilograms (3 lbs.) or 

more of fluid other than mineral oil, see §761.2. For provisions permitting reclassification of 

electrical equipment, including PCB Transformers, containing >500 ppm PCBs to PCBContaminated Electrical Equipment, see § 761.30(a) and (h). 

PCB Waste(s) (as defined in §761.3): those PCBs and PCB Items that are subject to the 

disposal requirements of subpart D of this part. 

Posing an Exposure Risk to Food/Feed (as defined in §761.3): being in any location where 

human food or animal feed products could be exposed to PCBs released from a PCB Item. A 

PCB Item poses an exposure risk to food or feed if PCBs released in any way from the PCB 

Item have a potential pathway to human food or animal feed. EPA considers human food or 

animal feed to include items regulated by the U.S. Department of Agriculture or the Food and 

Drug Administration as human food or animal feed; this includes direct additives. Food or feed 

is excluded from this definition if it is used or stored in private homes. 

Radial Transformer: transformers hooked up in a single line method, and if the transformer 

fails, the load is not picked up by another transformer. 

Recloser: circuit breakers with an automatic close feature, which are used to minimize outage 

time when temporary problems occur. 

Retrofill (as defined in §761.3): to remove PCB or PCB-contaminated dielectric fluid and to 

replace it with either PCB, PCB-contaminated, or non-PCB dielectric fluid. 

Self-implementing Clean-up: applicable for sites one acre or smaller (definition of moderately 

sized site). This method includes: site characterizations, notification to Regional Administrator 

or Director of State and/or local government environmental agency, and clean up levels have to 

be followed according to 40 CFR 761.61(a)(4). 

PCB Inspection Manual vii August 2004 
Glossary of Terms 

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August 2004 viii PCB Inspection Manual 
Foreword 

Foreword

EPA developed this inspection manual to guide inspectors in conducting inspections to ensure 

compliance with regulations promulgated under section 6(e) of the Toxic Substances Control 

Act (TSCA) pertaining to polychlorinated biphenyls (PCBs). The pertinent regulations are found 

at Part 761 of Title 40 of the Code of Federal Regulations (CFR). This manual contains frequent 

citations to the regulations; all citations, unless otherwise noted, are to Title 40 of the CFR. 

The manual gives inspectors an overview of the regulations they will use in determining 

compliance. EPA case development/enforcement personnel make the ultimate determination of 

where a violation has occurred. 

Inspectors need to refer to the regulations as well as the manual. Appendices supplement 

information in the manual. The chapters and appendices of the manual are summarized below: 

Chapter One - PCBs: Facts contains an introduction, including a brief discussion of PCBs and 

an overview of the PCB regulations. 

Chapter Two - Pre-Inspection Activities contains general pre-inspection preparation 

procedures. 

Chapter Three - Inspection Procedures contains general inspection procedures, entry and 

opening conference procedures, records assessment and verification, disposal provisions, 

storage assessment, and closing conference procedures. Inspectors should use this chapter in 

conjunction with Chapter Five, which covers specific regulatory requirements. 

Chapter Four - Equipment-Specific Information presents an overview of PCB-containing 

equipment that an inspector is likely to encounter during a PCB inspection. This chapter 

includes general background information on the equipment, the locations of such items in the 

economic sector, and a partial list of manufacturers and trade names. Regulations applicable to 

such equipment are contained in Chapter Five. 

Chapter Five - Regulatory Requirements and Inspection Procedures details the key 

general regulatory provisions that apply to PCBs, PCB Items, and facilities. Such provisions 

pertain to authorized activities (e.g., use and servicing), marking, decontamination, and general 

recordkeeping and reporting. In addition, this chapter contains inspection procedures for 

documenting compliance/noncompliance with such provisions. For provisions applicable to the 

commercial disposal and storage facilities (e.g., incinerators and chemical waste landfills), see 

the appendices. 

PCB Inspection Manual ix August 2004 
Foreword 

Chapter Six - Sampling is necessary to supplement documented evidence of potential 

violations of the PCB regulations by determining the presence and concentration of PCBs. This 

chapter includes guidelines for sampling, priorities for sampling, and procedures for sample 

collection and documentation. 

Chapter Seven - Post-Inspection Activities discusses the Inspection Report and provides 

guidance and tips for writing the report. 

Appendices. There are 17 appendices. Appendix A contains blank forms for Notice of 

Inspection, TSCA Inspection Confidentiality Notice, and Declaration of Confidential Business 

Information. Appendix B is the “Role of the EPA Inspector in Providing Compliance Assistance 

During Inspections.” Appendix C is a large PCB mark at the actual size of six inches by six 

inches. Appendix D contains the Fiscal Year 2004 Inspection Conclusion Data Sheet Reporting 

Forms and an accompanying memorandum. Appendix E contains a comprehensive listing of 

PCB manufacturers and the trade names for PCB materials. Appendix F addresses the use 

and distribution of PCBs in underground mines and mine-specific training and safety 

considerations for inspectors. Appendix G discusses requirements pertaining to PCBs in 

natural gas pipelines. The inspector should refer to the appendix appropriate for the specific 

type of facility. Appendix H contains the manufacturer’s models and serial numbers of 

submersible pump units that contain PCBs. The next five appendices address specific disposal 

methods and storage facilities subject to the regulations: 

! Appendix I: Incinerators, 

! Appendix J: Chemical Waste Landfills, 

! Appendix K: High-Efficiency Boilers, 

! Appendix L: Alternative Disposal Methods (as authorized by EPA), and 

! Appendix M: Scrap Metal Recovery Ovens and Smelters 

Appendix N contains a table from Part 761 that outlines the procedures for reclassifying 

retrofilled PCB Transformers. 

Appendix O includes blank sample seals and a blank chain-of-custody form.

Appendix P is Department of Transportation Hazardous Materials Training, which is applicable to

the handling, packaging, and shipping of hazardous material samples.

Appendix Q provides guidance for inspectors in appearing as a witness in court.

August 2004 x PCB Inspection Manual 
Chapter One PCBs: Facts

Chapter One

PCBs: Facts

Page 

1.0 PCBs: Facts ........................................................ 1-1

1.1 Background .......................................................... 1-1

1.2 Overview of TSCA Section 6 ............................................. 1-3

1.3 Overview of TSCA Confidential Business Information ......................... 1-7

PCB Inspection Manual 1-i August 2004 
PCBs: Facts Chapter One 

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August 2004 1-ii PCB Inspection Manual 
Chapter One PCBs: Facts 

1.0 PCBs: Facts 

1.1 Background 

Polychlorinated biphenyls (PCBs) are synthetic organic chemical compounds (aromatic 

hydrocarbons) produced by substituting chlorine atoms for the hydrogen atoms on a biphenyl 

molecule. PCBs have ideal properties for industrial applications. They are one of the most 

stable synthetic compounds known, are inflammable, are resistant to breakdown, and exhibit low 

electrical conductivity. PCBs can also extend the temperature range of operating fluid and can 

provide long-lasting heat at a consistent temperature. Accordingly, the majority of PCBs 

manufactured in the U.S. were used in electrical equipment because their properties made them 

ideal dielectric and heat transfer fluids. PCBs were used widely in transformers, transformer 

bushings, capacitors, voltage regulators, hydraulic systems, small capacitors in fluorescent light 

ballasts, and heat transfer systems. In addition, PCBs were sometimes used in electrical cable, 

switches, breakers, vacuum pumps, gas turbines, natural gas pipelines, carbonless copy paper, 

paints, adhesives, caulking compounds, and investment casting wax. 

Extensive research has shown a link between PCBs and various human health effects (acute 

and chronic), including the formation of malignant and benign tumors, fetal deaths, reproductive 

abnormalities, mutations, liver damage, and skin irritation (chloracne). In addition, experiments 

have shown that PCBs attack the immunological system and affect the production of enzymes. 

PCBs are pervasive throughout the environment. Measurable amounts of PCBs have been 

found in soils, water, fish, milk of nursing mothers, and human tissue. In addition to being a 

known hazard to humans, PCBs also present a serious threat to the environment. PCBs have 

an affinity to be adsorbed onto organic matter and sediments and have been found in significant 

concentrations in waterways and sediments throughout the world. They are widely spread 

contaminants of fish and wildlife resources because of their pronounced tendency to 

bioconcentrate in the tissues or lipids of living organisms. PCBs are highly toxic to aquatic 

organisms in relatively low concentrations. The following is a list of potential PCB contamination 

scenarios. 

! Spills 

- Maintenance operations 

- Decontamination operations 

- Transport operations 

- Draining, refilling operations 

- Contamination of waste oil 

- Drainage systems, storm water systems, discharge points, sumps, and areas 

adjacent to surface waters

- Disconnection/disassembly of railroad transformers

- Lack of spill containment provisions in work pits/servicing areas

PCB Inspection Manual 1-1 August 2004 
PCBs: Facts Chapter One 

- Poor housekeeping practices. 

- Improper storage. 

! Leaks 

- Normal wear of equipment in service (e.g., valves, gaskets, and fittings) 

- Malfunctioning equipment 

- Dismantling/reassembly of equipment 

- Damaged equipment 

- Cracked or damaged transformer bushings 

- Containers used for storage and transport 

- Equipment stored for disposal or reuse. 

! Improper storage of PCB-containing and/or PCB-contaminated equipment. 

! Illegal importation of PCBs. 

! Inadvertent manufacture of PCBs during chemical processing. 

! Low Level of Worker Knowledge of Hazards 

- Spread of contamination through insufficient protective clothing and equipment 

- Improper handling techniques 

- Improper disposal of defective PCB-containing and/or PCB-contaminated equipment. 

! Other 

- Contaminated waste liquids 

- Contaminated rags, filter media, and debris gathered during cleanup operations 

- Contaminated parts 

- Contaminated soil 

- PCBs discarded prior to TSCA regulations 

- Fires. 

The number and location of the chlorine atoms attached to the biphenyl ring determine the 

physical properties and characteristics of the PCB congener. Generally, commercial PCBs tend 

to be viscous and heavy (11 to 13 pounds per gallon), but also may be solid and waxy. In the 

United States, the only large producer of PCBs was Monsanto Chemical Company, which 

manufactured them from 1929 to 1975 under the name AroclorTM. Monsanto Chemical 

Company assigned a four-digit number to each Aroclor PCB product. The last two numbers 

indicate the approximate percentage by weight of chlorine (for example, Aroclor 1260 is 

approximately 60 percent chlorine by weight). 

August 2004 1-2 PCB Inspection Manual 
Chapter One PCBs: Facts 

1.2 Overview of TSCA Section 6 

In recognition of the risks associated with PCBs and their spread throughout the environment, 

under section 6(e) of the Toxic Substances Control Act (TSCA) of 1976, it is the intent of 

Congress that EPA regulate the manufacturing, processing, distribution in commerce, use, and 

disposal of PCBs.1 

Section 6 states that “no person may manufacture, process, or distribute in commerce or use 

any [PCB] in any manner other than in a totally enclosed manner” as of one year after the 

effective date of TSCA (i.e., as of January 1, 1978). However, the EPA Administrator “may by 

rule authorize the manufacture, processing, distribution in commerce or use (or any combination 

of such activities) of any [PCB] in a manner other than in a totally enclosed manner if the 

Administrator finds that such [activities] will not present an unreasonable risk of injury to health 

or the environment.” Under section 6, a "totally enclosed manner” means any manner that "will 

ensure that any exposure of human beings or the environment to a [PCB] will be insignificant as 

determined by the Administrator." 

Section 6 sets additional deadlines after which no person may manufacture, process or 

distribute in commerce PCBs, regardless of whether in a totally enclosed manner or not. 

Section 6 states that “no person may manufacture any polychlorinated biphenyl after two years 

after the effective date” of TSCA (i.e., after January 1, 1979), and that “no person may process 

or distribute in commerce any polychlorinated biphenyl after two and one-half years” after the 

effective date of TSCA (i.e., after July 1, 1979). However, “any person may petition the 

Administrator for an exemption from [the prohibitions above], and the Administrator may grant by 

rule such an exemption” if the Administrator finds that such an activity will not result in an 

unreasonable risk to human health or the environment and that good faith efforts have been 

made to develop a substitute chemical substance that does not pose an unreasonable risk to 

health and the environment. Section 6 states that such exemptions shall be in effect for a 

specified period not more than one year. 

Under section 6, Congress required EPA to promulgate regulations prescribing methods for the 

disposal of PCBs. Congress also mandated that EPA require clear and adequate markings, 

warnings, and instructions with respect to the processing, distribution in commerce, use, and 

disposal of PCBs. 

Polychlorinated terphenyls (PCTs) were also manufactured and are similar in properties to PCBs. Although 

PCTs are not covered by the regulations, most were contaminated with up to 10,000 ppm PCBs and, 

therefore, are regulated. 

PCB Inspection Manual 1-3 August 2004 

1 
PCBs: Facts Chapter One 

Regulations promulgated pursuant to section 6 of TSCA are summarized below. Guidance on 

conducting PCB inspections to ensure compliance with key provisions of the regulations is 

provided throughout the manual. 

EPA regulations implementing section 6 of TSCA are found at 40 CFR Part 761. All citations to 

the regulations are to Title 40 unless otherwise noted. The following is a summary of regulatory 

actions concerning PCBs and a brief overview of major components of the regulations. For 

more detail on regulatory provisions, see Chapter Five. 

Regulations concerning PCBs have evolved over a number of years. EPA promulgated its initial 

PCB rule under section 6(e) on February 17, 1978 (43 Federal Register 7150). This rule 

prohibited the manufacture, processing, distribution in commerce, or use of any substance 

containing intentionally manufactured PCBs with concentrations of 50 parts per million (ppm) or 

more, except in a manner that is "totally enclosed" or unless other uses are specifically 

authorized by the Administrator. 

EPA has amended the PCB regulations several times, including: 

! Ban Rule: On May 31, 1979, EPA promulgated Interim Procedural Rules for Exemptions 

from the PCB Processing and Distribution in Commerce Bans. 

! Electronic Equipment Rule: On August 25, 1982, EPA promulgated this rule, 

addressing totally enclosed PCB use. 

! Fires Rule: On July 19, 1988, EPA promulgated the PCBs in Electrical Transformers 

Rule. 

! Notification and Manifesting Rule: On December 21, 1989, EPA promulgated this 

rule, requiring notification of PCB activity, manifesting, and other recordkeeping 

requirements. 

! Approval Criteria for Commercial Storage of PCBs for Disposal: On November 9, 

1993, EPA promulgated Criteria for Granting Approval for Commercial Storage of PCBs 

for Disposal. 

! Import Rule (overturned): On March 18, 1996, EPA promulgated regulations allowing 

the importation of PCBs for disposal at 50 ppm or greater under certain circumstances. 

These regulations were superceded by the June 29, 1998 amendments, which removed 

the language allowing such imports. 

August 2004 1-4 PCB Inspection Manual 
Chapter One PCBs: Facts 

! Disposal of Polychlorinated Biphenyls (PCBs) or “Mega Rule”: On June 29, 1998, 

EPA promulgated a major revision to the PCB regulations, often referred to as the Mega 

Rule. The revisions covered many aspects of PCB use and disposal, including revisions 

of: 

- PCB Registration to EPA Headquarters 

- Prohibitions and exemptions

- Marking requirements

- Storage for disposal requirements

- Disposal requirements

- Transboundary (international) shipment of PCBs for disposal

- Records and monitoring requirements

- Certificate of Disposal deadlines

- 30-day storage inspection. 

The revisions included new requirements to address: 

- The assumed concentration of PCBs where actual data are unavailable 

- Storage for reuse 

- Waste handling 

- PCB spill cleanup requirements 

- Sampling procedures for several types of projects 

- Decontamination procedures. 

! Reclassification of PCB and PCB-Contaminated Electrical Equipment: On April 2, 

2001, EPA promulgated a rule regarding the reclassification of PCB and PCBContaminated electrical equipment. 

! Polychlorinated Biphenyls; Manufacturing (Import) Exemptions: On January 31, 

2003, EPA promulgated manufacturing (import) exemptions. 

! Polychlorinated Biphenyls (PCBs); Use of Porous Surfaces, Amendment in 

Response to Court Decision: On June 20, 2003, EPA amended the regulations 

regarding the use of porous surfaces in response to a court decision that stated that the 

regulatory language was unclear. 

In general, TSCA and the PCB regulations are designed to ban the manufacture of PCBs and 

ensure the proper disposal of PCBs and PCB Items, while minimizing the risk posed by the 

storage, use, and handling of the substance. The PCB regulations apply to any substance, 

mixture, or item with a concentration of 50 ppm PCBs or greater or with a concentration below 

50 ppm that resulted from dilution. There are certain exceptions; for example, the regulations 

restrict the marketing and burning of used oil containing any quantifiable PCB level (2 ppm) and 

prohibit the use of waste oil that contains any detectible concentration of PCBs as a sealant, 

coating, or dust control agent. Some of the major provisions of the PCB regulations include: 

! General (Subpart A). In addition to identifying who is regulated, establishing definitions, 

and listing reference documents, this subpart prescribes the assumed PCB 

PCB Inspection Manual 1-5 August 2004 
PCBs: Facts Chapter One 

concentrations, for regulatory purposes, of various articles (such as oil filled capacitors) 

for which the actual PCB concentration is unknown. 

! Prohibitions/Authorizations (Subpart B). There are numerous prohibitions on the use of 

PCBs or PCB Items in a manner other than in a totally enclosed manner; on the 

manufacture of PCBs for use within the United States or for export; and on the 

processing and distribution of PCBs and PCB Items for use within the United States or 

for export. However, the regulations also establish numerous exceptions and authorized 

activities (e.g., where "non-totally enclosed" activities may be conducted). Such 

authorizations pertain to the use of PCBs and servicing of PCBs in various PCB 

Equipment, such as transformers, capacitors, natural gas pipelines, and hydraulic 

systems; the manufacturing of certain products with inadvertent, low-concentration 

production of PCBs; and the use of sewage sludge with PCBs where such sludge use is 

regulated by other parts of 40 CFR. Owners of PCB Transformers must register the 

transformers with EPA. Owners of PCB Articles may store them for reuse subject to 

storage area specifications, maximum storage periods, and/or recordkeeping 

requirements. 

! Marking (Subpart C). Specified items including PCB Equipment (e.g., heat transfer 

systems using PCBs, PCB large low voltage capacitors, and storage areas used to 

store PCBs/PCB Items) must bear markings warning of PCBs in accordance with 

prescribed formats. The regulation does not require PCB-contaminated electrical 

equipment to be marked. 

! Storage and Disposal (Subpart D). Regulations govern storage (for reuse or disposal) 

and disposal of PCBs, PCB waste, and PCB Items, including PCB Articles (e.g., 

transformers, capacitors, and hydraulic machines) and PCB Containers. The subpart 

includes separate sections that set out disposal requirements and allowed disposal 

methods for PCB remediation waste, PCB bulk product waste, and PCB waste from 

research and development activities. The regulations exempt PCB household waste 

from regulatory requirements. The regulations also set out requirements applicable to 

PCB waste and PCB Items in storage for disposal and decontamination of various 

surfaces. Further regulatory sections specify requirements for each disposal method, 

including incineration, high-efficiency boilers, scrap metal recovery ovens and smelters, 

and chemical waste landfills. PCB disposal and PCB commercial storage facilities must 

obtain written final approval to operate facilities. 

! Exemptions (Subpart E). This subpart grants exemptions to specific companies or 

groups of companies for the manufacture, processing, and distribution in commerce of 

PCBs for specified purposes, including microscopy, research and development, and 

laboratory sampling and analysis. 

! Transboundary Shipments of PCBs for Disposal (Subpart F). EPA prohibits the 

importation of PCBs for disposal without an exemption issued under the authority of 

TSCA section 6(e)(3). EPA prohibits the exportation of PCBs for disposal at 

concentrations greater than or equal to 50 ppm. Shipments that leave the United States 

only as part of their transit from one part of the United States to another are not 

considered exports or imports. Shipments passing through from Canada to Mexico or 

vice versa are not considered exports or imports. 

August 2004 1-6 PCB Inspection Manual 
Chapter One PCBs: Facts 

! Recordkeeping/Reporting (Subpart J). Owners and operators of facilities with PCBs and 

PCB Items in service or projected for disposal, commercial storage facilities of PCB 

waste, incineration facilities, chemical waste landfill facilities, high efficiency boiler 

facilities, importers, facilities generating PCBs in excluded manufacturing processes, 

and facilities that manufacture, import, process, distribute in commerce, or use 

chemicals containing inadvertently generated PCBs must comply with recordkeeping 

and reporting requirements. Some types of data for which records may be required to be 

kept include PCB weights; the identification and numbers of items; storage, transfer, and 

disposal dates; and the identification of shippers and receivers. 

! PCB Waste Disposal Records and Reports (Subpart K). Some generators and all 

transporters, storers, and disposers of PCB wastes must notify EPA that they are 

engaging in such activity, and obtain an identification number from EPA. When a PCB 

waste generator sends such wastes offsite, the generator, transporter, and disposer 

must prepare and maintain manifests identifying the waste and tracking the dates and 

parties involved in the disposal process. The disposer must prepare a Certificate of 

Disposal and send it to the generator identified on the manifest. The subpart also 

includes recordkeeping requirements and procedures for cases in which manifests or 

Certificate of Disposal are not prepared by one of the parties in a transaction. 

! Sampling and Decontamination Procedures for Wastes and Surfaces (Subparts M 

through T). These subparts set out recommended procedures for sampling PCBs in 

various wastes and surfaces, including sample site and size selection, sample 

collection, analytical requirements, and interpretation of results. The regulations also set 

out a method for decontaminating non-porous surfaces and requirements for studies of 

new decontamination solvents. 

1.3 Overview of TSCA Confidential Business Information 

During the course of TSCA PCB inspections, inspectors may encounter information which may 

be entitled to confidential treatment under TSCA Section 14 and EPA regulations (40 CFR Part 

2). This section of the Statute and the regulations are designed to protect confidential business 

information (CBI) from unauthorized disclosure. CBI includes information considered to be trade 

secrets (including chemical identity, process, formulation, or production data) that could damage 

a company's competitive position if it became public. Inspectors must be cleared to handled 

CBI, however inspectors who have not been cleared to handle CBI can still inspect a facility. 

Many PCB facilities do not have any CBI information. 

PCB Inspection Manual 1-7 August 2004 
PCBs: Facts Chapter One 

Blank Page 

August 2004 1-8 PCB Inspection Manual 
Chapter Two Pre-Inspection Activities 

Chapter Two 

Pre-Inspection Activities 

Page 

2.0 Pre-Inspection Activities ................................................. 2-1

2.1 Inspection Authority .................................................... 2-1

2.2 Preparation ........................................................... 2-1

2.2.1 Document Preparation .................................................. 2-3

2.3 Confidential Business Information Clearance ................................ 2-3

2.3.1 CBI and Inspectors ..................................................... 2-4

2.4 Equipment Preparation ................................................. 2-5

Tables 

Table 2-1. Types of Equipment Useful for an Inspection .............................. 2-6

PCB Inspection Manual 2-i August 2004 
Pre-Inspection Activities Chapter Two 

Blank Page 

August 2004 2-ii PCB Inspection Manual 
Chapter Two Pre-Inspection Activities 

2.0 Pre-Inspection Activities

The chapter includes general pre-inspection preparation procedures. 

2.1 Inspection Authority 

Section 11(a) of TSCA sets forth the authority for an inspector to enter and inspect a facility 

handling PCBs or PCB Items. Under section 11(a), "the Administrator and any duly designated 

representative of the Administrator" may inspect "any establishment, facility, or other premises 

in which chemical substances or mixtures are manufactured, processed, stored, or held before 

or after their distribution in commerce." The inspector also may inspect "any conveyance being 

used to transport chemical substances, mixtures, or such articles in connection with distribution 

in commerce." The Agency may designate EPA employees, state/tribe personnel, or 

contractors to conduct inspections. 

Section 11(b) of TSCA addresses the scope of the inspection. It prohibits the inspection of the 

following unless described with reasonable specificity in the required written Notice of 

Inspection (see Section 2.4.2 and Appendix A): 

! Financial data 

! Sales data (other than shipment data) 

! Pricing data 

! Personnel data 

! Research data (other than data required under TSCA or a rule promulgated under 

TSCA). 

2.2 Preparation 

To prepare, an inspector collects and analyzes background information such as address, parent 

company, and compliance history on the facility to be inspected. This background information 

enables the inspector to become familiar with facility operations and any previous legal issues 

before entry. This preparation phase enables the inspector to note areas that may need 

investigation during the inspection. 

The inspector can obtain and review the following information for the facility, which may be on 

file in previous inspection reports/files with Regions and EPA Headquarters. Some of this 

information may also be available in the PCB Activity Database (PADS), which has information 

on facilities that generate, store, transport, or dispose of PCBs. Inspectors can access this 

database at http://www.epa.gov/pcb/data.html. 

PCB Inspection Manual 2-1 August 2004 
Pre-Inspection Activities Chapter Two 

! General facility information, including the official name of the facility, exact physical 

location of the facility, facility type and size, industrial processes employed, and EPA 

identification number. EPA records or files on the particular facility (where a previous 

inspection was conducted) may contain such data as well as the company web site (if 

available). Inspectors may find enforcement and inspection data in the FIFRA/TSCA 

Tracking System (FTTS). 

! Facility offices or contacts, including names, titles, and telephone numbers. 

! Previous inspection records and reports. Note previous violations cited; target these 

areas to ensure or verify compliance. Identify any changes in facility conditions since 

previous inspection. 

! Compliance status, including past, current, and pending litigation, deficiency notices 

issued to the facility, the status of administrative orders or consent decrees, penalties 

imposed against the facility, and citizen suits or complaints. Some of this information is 

found in EPA databases such as Enforcement and Compliance History Online (ECHO), 

Online Targeting Information System (OTIS), and FIFRA/TSCA Tracking System (FTTS). 

! Permits, types of permits, and permit approvals (EPA and/or state). The main types of 

permitted facilities or activities that include permits are commercial storers, disposal 

facilities, and remediation/decontamination activities. 

! TSCA, PCB Exemptions granted by EPA. Note specific exemption eligibility 

requirements listed (if any). 

! Reports of spills or other environmental incidents. 

! Transformers. Review the PCB Transformer Registration Database to find the number 

of PCB Transformers the facility registered. 

! Annual PCB Records, Annual PCB Document Log, and Annual Reports for 

commercial storers and disposers. Note omissions/deficiencies for clarification during 

the inspection. Remember that the requirement to submit annual reports to EPA applies 

only to commercial storers and disposers. If EPA possesses annual PCB records for an 

owner/operator from a previous inspection, the inspector should review those records as 

well. 

! Facility location, 100-year floodplain evaluation to verify that storage is not in a 100­

year floodplain or determine whether a landfill is subject to flood protection provisions of 

the regulations. Consult U.S. Geological Survey topographic maps or Federal Flood 

Insurance maps at http://www.usgs.gov/. 

! PCB manifests, exception reports, and unmanifested waste reports. 

! Correspondence between the facility and EPA. 

August 2004 2-2 PCB Inspection Manual 
Chapter Two Pre-Inspection Activities 

! PCB Transformer Registration Database at http://www.epa.gov/pcb/data.html for any 

information which might be useful for PCB inspections. 

! EPA’s National Policy: The Role of the EPA Inspector in Providing Compliance

Assistance During Inspections (see Appendix B) and the Compliance Assistance

Resources Guide. Inspectors should familiarize themselves with this policy.

2.2.1 Document Preparation 

Before conducting an inspection, the inspector should obtain an adequate number of the 

following forms and documents to properly document all events that may take place during the 

inspection. 

! Notice of Inspection

! TSCA Inspection Confidentiality Notice

! Receipt for Samples and Documents*

! Declaration of Confidential Business Information*

! PCB Inventory (part of the PCB Field Report: see Chapter Seven)

! Custody Seals*

! Chain of Custody Record*

! Sample Collection Report*

! A copy of TSCA and a copy of PCB Regulations

! Related Information/Educational/Outreach Material to provide to the facility

! A copy of the Inspection Conclusion Data Sheet (ICDS) forms or if entering information

directly into ICIS review the information that needs to be entered. Refer to Appendix D or 

to the EPA Inspector website at http://intranet.epa.gov.oeca.oc.campd.inspector for 

copies of the most recent ICDS forms. 

* These documents are required when documentary or sample evidence will be collected. For 

sample collection, the inspector should follow the regulations and the sampling quality assurance 

plan approved by the appropriate Region prior to the inspection. 

2.3 Confidential Business Information (CBI) Clearance 

U.S. EPA PCB inspectors must be cleared for TSCA CBI clearance before handling any

information that is claimed as CBI by a facility. The CBI clearance process includes viewing a 

video, completing a TSCA CBI form, and gaining approval from the Regional Document Control 

Officer (DCO). Inspectors are required to view a video which covers the following topics: 

! working with TSCA CBI on computers

! handling TSCA CBI

! storing CBI documents.

After viewing the video, inspectors need to fill out EPA Form 7740- 6: “TSCA CBI Access 

Request, Agreement and Approval”, which they can obtain from their Regional DCO. The form 

PCB Inspection Manual 2-3 August 2004 
Pre-Inspection Activities Chapter Two 

needs to be signed by the inspector’s supervisor and submitted to the Regional DCO. The 

Regional DCO sends the completed Form 7740-6 to the Headquarters/ OPPT DCO for 

processing and approval. Once the form is submitted to the Headquarter’s DCO, inspectors 

usually get CBI clearance within 24 hours. 

Only EPA inspectors and government contractors working for EPA can obtain TSCA CBI 

clearance. EPA-cleared government contractors go through a different process to get CBI 

clearance including a published Federal Register Notice. It takes approximately 30 to 60 days 

for contractors to obtain TSCA CBI clearance. State inspectors, grantees (including Senior 

Environmental Employment (SEE) Program employees), and state inspectors working under a 

grant cannot get TSCA CBI clearance. For more detailed information on TSCA CBI, please refer 

to the TSCA CBI Security Manual that can be found at: 

http://intranet.epa.gov/rmpolicy/ads/manuals/7700.pdf. 

2.3.1 CBI and Inspectors 

The PCB inspector must present the facility official with the TSCA Inspection Confidentiality 

Notice (Appendix A) at the start of the opening conference. This notice informs the facility 

representative of the right to claim any information (e.g., documents, records, physical samples, 

or other material) collected from the facility during the inspection as confidential. The facility 

may make CBI claims by completing the Declaration of Confidential Business Information form 

(Appendix A). The inspector should also have available, if possible, certification that he or she is 

authorized to have access to CBI. 

The inspector should inform the facility official that an authorized facility official may declassify 

information claimed as CBI in the original submission of the Declaration of Confidential Business 

Information. However, the inspector must inform the facility official that the facility cannot make 

such a declassification verbally, but rather must make it through a letter waiving confidentiality 

sent to the EPA DCO for EPA's OPPT. The facility must send a separate letter for each item for 

which confidentiality is waived. 

The inspector must determine whether the facility official to whom the Confidentiality Notice was 

given is authorized by the facility to make claims of confidentiality. The inspector should obtain 

the official's signature on the notice certifying that the person does or does not have such 

authority. The facility owner is assumed to have such authority. In most cases, it is expected 

that the agent designated by the owner will also have such authority. It is possible that the facility 

officials will want to consult with their attorneys concerning this issue. 

August 2004 2-4 PCB Inspection Manual 
Chapter Two Pre-Inspection Activities 

If no one at the site has the authority to make business confidentiality claims, the notice and 

other inspection materials should be sent to the CEO of the company within two days of the 

inspection. The CEO will then have seven calendar days in which to make confidentiality 

claims. During this seven-day period, the inspector should follow routine security measures in 

the event that records taken during the inspection are subsequently claimed as CBI. For 

example, the inspector should file the records in a secured area instead of leaving them on 

his/her desk. 

2.4 Equipment Preparation 

The inspector should assemble the equipment needed for the inspection. Table 2-1 lists the 

general equipment and documents the inspector will most likely need. Note that the specific 

equipment needed for an inspection varies, and the inspector should consider the equipment list 

on a case-by-case basis, taking into account important factors such as the physical conditions 

at the facility or whether sampling is likely. 

PCB Inspection Manual 2-5 August 2004 
Pre-Inspection Activities Chapter Two 

Table 2-1. Types of Equipment Useful for an Inspection 

General Safety Emergency Sampling 

• Credentials 

• Camera 

• Film/memory card and 

flash equipment 

• Pocket calculator 

• Tape measure 

• Clipboard 

• Waterproof pens, 

pencils, and markers 

• Pre-addressed 

envelopes (e.g., to 

Document Control 

Officer) 

• Plastic covers 

• Plain envelopes 

• Polyethylene bags 

• Disposable towels or 

rags 

• Laptop computer or 

personal digital assistant 

(PDA) 

• Global Positioning 

System (GPS) equipment 

• Portable copying 

machine 

• Flashlight and batteries 

• Pocket knife 

• Locking briefcase 

(especially for CBI) 

• Binoculars 

• Safety glasses or 

goggles 

• Face shield 

• Ear plugs 

• Rubber-soled, metal-toed, 

non-skid shoes 

• PCB-resistant gloves 

(disposable, if possible) 

• Coveralls, long-sleeved 

(disposable, if possible) 

• Long rubber apron 

• Hard hat 

• Disposable footwear 

covers 

• Respirators and 

cartridges 

• Self-contained breathing 

apparatus (may be 

required occasionally 

under certain 

circumstances) 

• Nitrile/butyl rubber gloves 

• Coated Tyvek 

• First-aid kit 

• Emergency telephone 

numbers 

• First-aid kit with 

eyewash 

• Fire extinguisher 

• Soap and towels 

• Supply of clean water for 

washing 

• Do not use waterless 

hand cleaner 

• Crescent wrench, bung 

opener 

• Siphoning equipment 

• Weighted bottle sampler 

• Bottom sediment sampler 

• Liquid waste samplers 

(e.g., glass samplers) 

• Auger, trowel, or core 

sampler 

• Scoop sampler 

• Sample 

bottles/containers 

(certified clean bottles 

with teflon-lined lids) 

• Labeling tags, tape, 

chain-of-custody forms, 

waterproof permanent 

pen 

• Ice chest, ice (if required 

by the lab) 

• Container for 

contaminated material 

• Hazard labels for 

shipping samples 

• Ambient air monitor 

• Field document records 

• Department of 

Transportation (DOT) 

approved shipping 

containers 

• Thermometer 

• Colorimetric gas 

detection tubes 

• PCB labels 

• Custody seals 

• Wipe sample template 

• Gauze pads 

Safety Note: Some enclosed storage areas or transformer vaults may be in confined spaces that present health 

hazards because of dangerous levels of explosives or insufficient oxygen. The inspector should not enter a 

confined space unless properly trained and equipped. 

August 2004 2-6 PCB Inspection Manual 
Chapter Three Inspection Procedures 

Chapter Three 

Inspection Procedures 

Page 

3.0 Inspection Procedures .................................................. 3-1

3.1 Entry ................................................................ 3-1

3.1.1 Credentials ..................................................... 3-1

3.1.2 Notice of Inspection .............................................. 3-2

3.1.3 Withdrawal of Consent and Denial of Access .......................... 3-2

3.1.4 TSCA Inspection Confidentiality Notice ............................... 3-2

3.1.5 Problems with Entry or Initial Consent ................................ 3-3

3.1.6 Warrants and Warrant Procedures .................................. 3-3

3.2 Opening Conference ................................................... 3-4

3.3 Records Assessment .................................................. 3-6

3.3.1 Inventory ....................................................... 3-7

3.3.2 Compliance Assessment .......................................... 3-7

3.4 Records Verification .................................................... 3-8

3.4.1 Selection of PCB Items for Verification ............................... 3-8

3.4.2 Verification .................................................... 3-10

3.5 Inspecting for Compliance with Disposal Requirements ....................... 3-10

3.5.1 Indicators of Disposal Violations ................................... 3-10

3.5.2 Sources of Potential Violations .................................... 3-11

3.6 Marking Assessment .................................................. 3-14

PCB Inspection Manual 3-i August 2004 
Inspection Procedures Chapter Three 

3.7 Storage Assessment .................................................. 3-15

3.7.1 Storage Facility ................................................. 3-16

3.7.2 Storage Containers ............................................. 3-16

3.7.3 Storage Facility Operation ........................................ 3-17

3.7.4 Outside Storage ................................................ 3-17

3.7.5 Temporary Storage ............................................. 3-17

3.8 Closing Conference ................................................... 3-18

3.8.1 Discussions ................................................... 3-18

3.8.2 Required Receipts .............................................. 3-19

3.9 Compliance Assistance ................................................ 3-19

3.9.1 General Outreach Activities ....................................... 3-19

3.9.2 Information Sources ............................................. 3-20

August 2004 3-ii PCB Inspection Manual 
Chapter Three Inspection Procedures 

3.0 Inspection Procedures 

This chapter includes general inspection procedures, entry and denial of entry, opening 

conference, compliance assessments, and closing conference. 

3.1 Entry 

Consent to inspect the premises must be given by the owner or operator at the time of the 

inspection. As long as the inspector is allowed to enter, entry is considered voluntary and 

consensual, unless the inspector is expressly told to leave the premises. Expressed consent is 

not necessary; absence of an expressed denial constitutes consent. See Sections 3.1.3-3.1.6 

below for details on denials of entry and warrant and subpoena procedures to be followed when 

entry or access to records is denied. 

Under section 11(a), the inspection team must start and complete the inspection with 

reasonable promptness and conduct it at reasonable times, within reasonable limits, and in a 

reasonable manner. When an inspection is likely to continue beyond the facility's customary 

close-of-business, EPA recommends that the inspection continue on the following business day. 

If facility officials do not object to the inspector working past regular working hours, the inspection 

can conclude the same day. In general, the inspector should arrive at the facility during regular 

working hours unless the inspection’s purpose is to investigate special circumstances, such as 

suspected illegal activity at night. 

Upon arrival at the facility, the inspector should locate the facility official or agent-in-charge (i.e., 

president, owner, or plant manager) and present his/her credentials, a written Notice of 

Inspection, and a TSCA Inspection Confidentiality Notice. 

3.1.1 Credentials 

The inspector must present appropriate credentials whether identification is requested or not. 

Credentials are identifying documents that identify that the holder of the papers (i.e., the 

inspector) is a duly designated representative of the Administrator. A letter of authorization and 

photo identification or EPA-issued credentials may be used. The inspector should make a note 

in his/her field logbook of the fact that credentials and a Notice of Inspection were presented, the 

date and time of presentation, and the name and title of the facility official to whom they were 

presented. Credentials should never leave the possession of the inspector, nor should they be 

photocopied. Inspectors should safeguard where they store their credentials and should 

immediately report lost or stolen EPA credentials to their immediate supervisor. For more 

information on credentials, refer to the Final Fact Sheet: The United States Environmental 

PCB Inspection Manual 3-1 August 2004 
Inspection Procedures Chapter Three 

Protection Agency Credentials Fact Sheet, June 1, 2000. This document can be found in the 

inspector website at: http:intranet.epa.gov/oeca/oc/campd/inspector. 

3.1.2 Notice of Inspection 

Section 11(a) of TSCA requires that the inspector present a written Notice of Inspection to the 

owner, operator, or agent-in-charge. The notice, EPA Form 7740-3, should include the date and 

time of inspection. A blank Notice of Inspection is presented in Appendix A. 

3.1.3 Withdrawal of Consent and Denial of Access 

If the facility representative asks the inspector to leave the premises after the inspection has 

begun, the inspector should leave as quickly as possible following the procedures discussed 

previously for denial of entry. All activities and evidence obtained before the withdrawal of 

consent are valid. The inspector should ensure that all personal and government equipment is 

removed from the facility. 

If, during the course of the inspection, access to some parts of the facility is denied, the 

inspector should make a notation of the circumstances surrounding the denial of access and of 

the portion of the inspection that could not be completed. He or she then should proceed with 

the rest of the inspection. After leaving the facility, the inspector should contact his or her 

supervisor or staff attorney at the Regional Office to determine whether a warrant should be 

obtained to complete the inspection. 

3.1.4 TSCA Inspection Confidentiality Notice 

The EPA inspector may present the facility official with the TSCA Inspection Confidentiality 

Notice (Appendix A) at the start of the opening conference or during the closing conference and 

have the authorized facility official complete and sign the appropriate sections. This notice 

informs the facility representative of the right to claim any information (e.g., documents, records, 

physical samples, or other material) collected from the facility during the inspection as 

confidential. The facility makes confidential business information (CBI) claims by completing the 

Declaration of Confidential Business Information form (Appendix A). The notice informs the 

official of his/her right to claim as CBI any information (e.g., documents, photographs, physical 

samples) collected during the inspection. 

The inspector should inform the facility official that an authorized facility official may declassify 

information claimed as CBI in the original submission of the Declaration of Confidential Business 

August 2004 3-2 PCB Inspection Manual 
Chapter Three Inspection Procedures 

Information. The facility must send a separate letter to the EPA Document Control Officer 

(DCO) for each item for which confidentiality is waived. 

3.1.5 Problems with Entry or Initial Consent 

Because a facility may consider an inspection to be an adversarial proceeding, the legal 

authority, techniques, and competency of inspectors may be challenged. If explanations are not 

satisfactory or disagreements cannot be resolved, the inspectors should leave and obtain further 

direction from his EPA supervisor or legal staff. Professionalism and politeness must prevail at 

all times. 

If entry is not granted, the inspector should ask why to see if obstacles (such as 

misunderstandings) can be removed. If resolution is beyond the authority of the inspector, he or 

she may suggest that the officials seek advice from their attorneys to clarify EPA's inspection 

authority under TSCA. If entry is still denied, the inspector should withdraw from the premises 

and contact his or her supervisor or Regional Counsel. Generally, the supervisor will confer with 

attorneys to discuss the desirability of obtaining an administrative warrant. 

All observations pertaining to the denial are to be carefully noted in the field notebook and 

inspection report. The inspector should include such information as the facility name and exact 

address, name and title of person(s) approached, name and title of the person(s) who refused 

entry, date and time of denial, detailed reasons for denial, facility appearance, and any 

reasonable suspicions of regulatory violations. All such information will be important should a 

warrant be sought. 

Under no circumstances should the inspector discuss potential penalties or do anything that 

may be construed as coercive or threatening. 

Inspectors should use discretion and avoid potentially threatening or inflammatory situations. If a 

threatening confrontation occurs, the inspector should document it and then report it immediately 

to the supervisor or staff attorney. If feasible, statements from witnesses should be obtained 

and included in the documentation. 

3.1.6 Warrants and Warrant Procedures 

A warrant is a judicial authorization for an appropriate official (e.g., EPA inspector, U.S. Marshal) 

to enter a specifically described location and perform specifically described functions. A 

magistrate at EPA issues an administrative warrant to enter and inspect a facility subject to 

PCB Inspection Manual 3-3 August 2004 
Inspection Procedures Chapter Three 

TSCA and the PCB regulations. EPA's authority to conduct inspections under section 11 of 

TSCA serves as the basis for requesting the issuance of an administrative warrant. 

Once the inspector has contacted his/her supervisor about the circumstances surrounding the 

refusal of entry, the supervisor will contact the Regional Counsel (for the Region in which the 

facility is located), to decide whether to obtain a warrant. 

In addition to the observations pertaining to the denial of consent, if applicable, the inspector 

should supply the supervisor/Regional Counsel with the following: 

! Information specifically describing the premises to be searched 

! Information specifically describing the items to be seized 

! Identification of the particular regulatory provisions suspected of being violated (if any) or, 

in the alternative, the particular predetermined inspection schedule (i.e., the neutral 

scheme) upon which the inspection was to be based. 

If the decision is to seek a warrant, the Regional Counsel will contact the U.S. Attorney's office 

for the district in which the facility to be inspected is located. The Regional Counsel will brief the 

U.S. Attorney (or Assistant U.S. Attorney) on the particular inspection, entry refusal, and

apparent need for a warrant. Finally, the Regional Counsel should arrange for the U.S. Attorney 

(or Assistant U.S. Attorney) to meet with the inspector as soon as possible. 

3.2 Opening Conference 

Once the PCB inspector has presented, upon entry, his/her credentials and the required Notice 

of Inspection (see Section 3.1.2 above), it is time for the opening conference. The inspector 

should request the use of a conference room or office to conduct the opening conference with a 

facility representative and review facility records with a facility representative. 

The opening conference provides an opportunity for the inspector to strengthen EPA-industry 

relations. The inspector's role, in addition to that of determining compliance problems at subject 

facilities, can be that of an educator and EPA public relations representative. The inspector can 

serve in this role throughout the inspection, but especially during the opening and closing 

conferences (see Section 3.9). 

It is important that the inspector have a thorough understanding of PCB regulations. This is 

because facility officials may have questions and will probably be familiar with the provisions of 

the regulations. The inspector should be at least as well informed as the regulated community 

August 2004 3-4 PCB Inspection Manual 
Chapter Three Inspection Procedures 

concerning TSCA's PCB provisions and the applicable regulations. For this reason, inspectors 

should have a copy of the regulation on hand. 

The inspector should keep in mind the following objectives during the opening conference: 

! Inform facility officials of the purpose and scope of the inspection. 

! Conduct the meeting on a positive and professional note. 

! Collect and document general facility information. 

! Establish a rapport with facility officials. 

The inspector should describe the planned inspection. By providing a general description of how 

the inspection will proceed, the inspector can foster an atmosphere of trust and cooperation 

between EPA and the facility. The following are topics that the inspector should address during 

the opening conference pertaining to the inspection: 

! General Information 

- Information regarding facility official (e.g., position, length of time in position, 

familiarity with facility operations)

- General operations conducted at the facility

- General history of the company

- History of the site

- Ownership of the business

- Ownership of the property

- Corporate structure

- Whether the company is a subsidiary.

! PCB Activities at the Facility. Discuss how and where the facility stores and uses 

PCBs. If the facility official is not familiar with PCBs or PCB regulations, questions about 

electrical equipment may provide enough information to locate PCBs in use or storage at 

the facility. Other questions may include the following: 

- Is the facility using or storing any of the liquid-filled equipment identified below? 

-- Transformers 

-- Railroad transformers 

-- Capacitors 

-- Containers of PCBs or PCB Items 

-- Hydraulic equipment 

-- Heat transfer systems 

-- Mining equipment 

PCB Inspection Manual 3-5 August 2004 
Inspection Procedures Chapter Three 

-- Electromagnets 

-- Other electrical equipment (regulators, switches). 

- Are transformers serviced on the facility premises? If so, by whom? 

- Is the facility aware of any PCB spills on the premises? 

- Has the facility ever manufactured PCBs or PCB Items? 

- Does the site have a PCB storage area? 

- Does the facility produce PCBs as a by-product of any of its manufacturing 

processes? 

! Inspection Objectives. After going over the inspection objectives, discuss the order in 

which the inspector will inspect activities at the facility. 

! Meeting Schedules. If meetings with facility personnel are necessary, schedule them 

during this conference. 

! Access/Accompaniment. Request access to all areas of the facility potentially involving 

PCB activities. Request that a facility official accompany you throughout the inspection. 

! Safety Requirements. Determine what safety precautions (e.g., the use of protective 

clothing or hard hats) should be observed during the inspection. Some industries and 

facilities may have specific safety issues and requirements. 

! Photographs. The inspector should advise facility officials that the inspector may use 

cameras or electronic recording devices to gather evidence of compliance/noncompliance. However, the inspector should also advise facility officials that the facility 

may claim as CBI photographs and other data gathered through such means. If a facility 

official forbids the inspector to take photographs, the inspector should continue to 

conduct the inspection without taking photographs, make sketches, if relevant, and, after 

leaving the premises, contact his/her supervisor to report the incident and determine next 

steps. Note: Inspectors should keep a log of the photographs taken with name of facility, 

date, time, and name of inspector taking the photographs. 

! Samples. Inform facility officials that the inspection may require samples. 

! Records. Identify records needed to review. 

3.3 Records Assessment 

The purpose of a records assessment is to develop an inventory of PCBs and PCB Items at the 

facility. The assessment also will help determine compliance with the recordkeeping provisions. 

The inspector should maintain a record of all discrepancies, such as missing or incomplete 

records, in the field notebook. The inspector should obtain copies of any records necessary. 

August 2004 3-6 PCB Inspection Manual 
Chapter Three Inspection Procedures 

3.3.1 Inventory 

The inspector should develop a PCB Inventory, which will become part of the PCB Inspection 

Report (see Chapter Seven), that identifies the type, quantity, and status of PCBs and PCB 

Items at the facility from the facility's records. The inventory information will be the same type of 

information found in the annual document log required for certain facilities under §761.180. The 

inspector can use the facility’s annual document log as a framework to develop the PCB 

Inventory. 

3.3.2 Compliance Assessment 

Based on the type of facility being inspected, the inspector should evaluate the records required 

by the regulations to determine compliance. (See Chapter Five for specific recordkeeping 

requirements.) In conducting this evaluation, the inspector should address the following 

considerations: 

! Is the facility meeting all of the annual document requirements? 

- Does the facility meet the minimal threshold (a PCB Transformer, 50 PCB 

Capacitors, or 45 kilograms of PCB in a container) to be required to keep an annual 

document log? (see §761.180(a) for more detailed information). 

- Is the necessary information provided in the annual document log? 

- Are annual document logs available for the past three years? 

- Are copies of signed manifests maintained; do they match the annual document log? 

- Is the three-year retention requirement for manifests being met? 

- Are Certificates of Disposal maintained? 

! Is the facility keeping PCB Transformer inspection records? 

! Is the facility keeping transformer registration records? 

! Have there been any spills? Are there any spill reports? 

! If the facility conducted decontamination, are records of confirmatory sampling after 

decontamination available for the last three years? 

! Are there any unmanifested waste reports that indicate that the disposer rejected waste 

sent offsite for disposal due to PCBs? 

! Do the records (and/or correspondence file) indicate areas needing further investigation? 

! Is the facility operating under a distribution-in-commerce authorization? 

- If so, is the facility meeting the specific requirements listed in the authorization? 

- If not, do the shipping records indicate transfer of PCBs to other than storage or 

disposal facilities? 

PCB Inspection Manual 3-7 August 2004 
Inspection Procedures Chapter Three 

- Is the facility using PCBs/PCB Items under use authorizations and if so, is it using 

them correctly? 

3.4 Records Verification 

The objective of records verification is to assess the accuracy of records by physically 

inspecting selected items listed in the records inventory. Although the facility records document 

the number of PCB items, the facility records may be incomplete, and the inspector should 

check for PCB Items that are not documented. The inspector should document in the field 

notebook any inaccuracies in the records. The inspector may need to take samples to establish 

PCB concentrations of any suspect substance or material. If the facility conducted laboratory 

testing of PCB concentrations, the inspector should obtain copies of the results. The inspector 

should also take photographs at appropriate locations to document observations. 

3.4.1 Selection of PCB Items for Verification 

From the PCB Inventory developed in the records assessment, the inspector should select a 

group of items (e.g., PCB Transformers, PCB containers, PCB large capacitors) to examine. 

(This will depend on the type of facility being inspected.) Chapter Four provides equipmentspecific information, including background information, common locations, and maintenance and 

repair activities relating to the specific equipment types. 

! If the items are grouped in the facility records by location, select one or more groups for 

examination. 

! If records list only totals of each item, select a percentage of each total. Ascertain from 

facility officials the location(s) of the items. 

! Consider the following in making the selection: 

- Practicality of inspection 

- Discrepancies indicated in the records assessment 

- Suspicions raised during the records assessment 

- Facility violation history, if any. 

Presented below is a sample equipment inspection list. The inspector should refer to the 

following list to target specific areas of potential non-compliance with PCB regulations. The 

inspector should not rely on this list to determine compliance with all PCB regulatory provisions 

(see Chapter Five). Inspectors should check for: 

! Condition of PCB-containing or PCB-contaminated equipment. 

August 2004 3-8 PCB Inspection Manual 
Chapter Three Inspection Procedures 

! Leaks and spills 

- Storage areas (particularly incoming storage site) 

- Maintenance operations sites 

- Floor drains that empty into a sewer or outfall to ditches or streams. 

- Facility drainage systems, storm water systems, discharge points, sumps, and 

areas adjacent to surface waters, which should be inspected and, if suspect, 

sampled for PCB contamination.

- Transport vehicles

- Nearby operating equipment.

If the inspector encounters a leak or spill, he/she should note the actual amounts of 

PCBs present in the ground. If the actual amounts are unknown, the inspector should 

provide a range (e.g., 25 to 125 kg). The inspector should also provide the approximate 

area of contamination. 

! Compliance with marking requirements (§761.40). 

! Enhanced electrical protection at the facility. 

! Compliance with recordkeeping requirements (§761.180 - §761.218). Facilities must 

maintain the following records for at least three years (Note: Disposal facilities must keep 

records for at least three years after ceasing the use/storage of PCBs): 

- Annual Document Logs 

- Manifests 

- Maintenance records

- Inspection records and frequency of inspections

- Record of registration.

! Maintenance and repair operations of PCB-containing equipment. 

! Compliance with storage regulations at sites storing PCB-containing equipment 

- Storage for reuse (§761.35)

- Storage for disposal (bulk, long-term, temporary) (§761.65).

! Improper disposal of PCBs including:

- Scrap areas and dumps

- Abandoned buildings

- Leachate from landfills

- Maintenance areas.

! Compliance with PCB transport requirements (Department of Transportation

requirements 49 CFR 171 through 180).

! Compliance with retrofilling requirements (i.e., fluid less than 50 ppm PCB). 

PCB Inspection Manual 3-9 August 2004 
Inspection Procedures Chapter Three 

3.4.2 Verification 

The inspector should locate the group(s) of items selected for verification and compare 

information in the records with actual conditions, noting the following: 

! Are items accurately described in the records? 

- Type (transformer, capacitor, etc.) 

- Status (in use, removed from service, stored for disposal) 

- PCB ppm content 

- PCB weight (if applicable). 

! Is the number of items correct? 

Safety Note. Inspectors should use extreme caution when in the vicinity of live electrical 

equipment. They should NOT sample live equipment. 

3.5 Inspecting for Compliance with Disposal Requirements 

The inspector should check for and evaluate the extent of improper disposal while conducting 

the physical assessment of the facility. The inspector should document in the field notebook all 

evidence of improper disposal and sample when necessary to establish PCB concentrations 

(see Chapter Six for guidance). Inspectors should note if the facility has or has had any PCB 

spills, since these constitute improper disposal. The inspector should photograph all sample 

locations and all suspected violations and obtain statements when possible to document where 

the disposal violation occurred. Drawings, sketches, diagrams, or maps can be helpful. The 

inspector should discuss prior spills and cleanup with the facility representatives and ask to 

examine spill cleanup reports. 

3.5.1 Indicators of Disposal Violations 

A number of signs, including the following, may indicate disposal violations: 

! Abandoned or discarded potential PCB-contaminated equipment, parts, or containers. 

- Transformers 

- Capacitors 

- Fluorescent light ballasts 

- Drums 

! Obvious spills or leaks 

- Discoloration of the soil near PCB Items, in drainage systems, or on the banks of 

streams 

- Oil films on the surface of streams or standing water 

August 2004 3-10 PCB Inspection Manual 
Chapter Three Inspection Procedures 

- Highly saturated soils 

- Oily rags, debris, or other material 

- Puddles or drips on or near equipment, containers, drip pans, or floors 

- Dead grass or other dead vegetation 

- Odor of chlorinated solvents - especially of trichlorobenzene, the principal solvent for 

PCBs (the presence of detectible odor may indicate concentrations of PCBs over 

5000 ppm) 

- Stains on equipment near spigots, cooling tubes, ganges, or insulators. Older stains 

may have dust accumulations on them. 

3.5.2 Sources of Potential Violations 

Housekeeping Practices 

Attitudes toward housekeeping may reflect attitudes toward compliance in general and may 

provide an indication of potential disposal violations. The questions listed below will be helpful in 

gauging these attitudes: 

! Are PCB handling areas orderly and in good repair? 

! How long has PCB waste (if any) been in storage? (A facility can store waste for no 

longer than one year unless EPA issues an extension.) 

! Are cleanup materials disposed of properly? 

! Are oily rags, debris, or other material stored near PCB Items? 

Worker Knowledge 

A low level of worker knowledge of the hazards of PCBs may result in poor PCB handling 

practices. The inspector may uncover actual or potential disposal violations by asking 

managers and workers questions about PCBs. Questions to ask the managers include: 

! Who deals with leaks and spills? Is training available to those employees? 

! Who is responsible for conducting and recording required inspections of transformers 

and storage areas? 

Questions to ask the workers include: 

! Are you trained to deal with leaks and spills? 

! If you are not trained, who is trained to deal with leaks and spills? 

PCB Inspection Manual 3-11 August 2004 
Inspection Procedures Chapter Three 

Maintenance and Repair Operations 

Maintenance and repair operations may take place at various locations throughout the facility and 

will generate significant amounts of PCB waste. The inspector should consider the following in 

assessing their effectiveness: 

! Does the facility have written maintenance and repair procedures? 

! Are maintenance sites located, constructed, and maintained to minimize the risk of 

contamination of surrounding areas? 

! Are there indications of leaks or spills at these sites? 

! Are there provisions for spill containment (such as a copy of 40 CFR 761, Subpart G 

[PCB Spill Cleanup Policy] or any other written policies/materials governing spill cleanup 

and containment) at the facility? Do the procedures note the requirement to report spills 

of one pound or more of PCBs to the National Response Center? Has the facility in fact 

reported such spills? (Ask for records or interview responsible personnel.) 

! Are draining/filling operations conducted in a manner to prevent spills? 

! Are containers used in the maintenance process of adequate size and in good condition? 

! Is maintenance equipment in good condition? 

! Are waste PCBs, testing samples, filter media, and contaminated parts, among other 

substances, handled, stored, and disposed of properly? 

! Are oily rags, debris, or other contaminated material handled, stored, and disposed of 

properly? 

Decontamination Operations 

Decontamination operations will often take place in conjunction with equipment maintenance and 

repair and involve extensive handling of PCBs. The following issues should be addressed during 

the inspection by referring to §761.79 (pertaining to decontamination generally): 

! Does the facility have written decontamination procedures? (If so, the inspector should 

obtain a copy.) Do the procedures meet the requirements of §761.79? 

! Are the solvents used among those listed in §761.79 or have they undergone the

validation study set out in Subpart T of Part 761?

! Does the facility drain or clean PCB equipment prior to disposal? 

August 2004 3-12 PCB Inspection Manual 
Chapter Three Inspection Procedures 

! Is the site adequate to protect surrounding areas from leaks and spills? 

! Does the facility properly store and dispose of drained substances and solvents? 

! Does the facility properly decontaminate movable equipment? 

! Does the facility properly decontaminate drums and pallets prior to reuse? 

Reclassification Operations 

PCB authorization regulations (§761.30) allow for reclassification of specific types of PCB 

equipment (e.g., transformers with a PCB concentration of greater than 500 ppm may be 

reclassified to a PCB-Contaminated Electrical Equipment or to a non-PCB Transformer). For 

reclassification in general, the inspector should ascertain compliance with regulations by 

ensuring that the facility: 

! Follows applicable regulatory procedures governing reclassification 

! Documents that adequate loading conditions occurred or that they used an EPAapproved alternative method to simulate loading

! Meets disposal requirements. 

Drainage Systems 

Contaminated drainage systems, which may include storm water systems, discharge points, 

sumps, and areas adjacent to surface waters, are a source of direct discharge of PCBs into the 

environment. Therefore, it is important to consider these issues: 

! Is there evidence of leaks or spills near the systems? 

! Are small spills washed into drainage systems by rain or by workers unaware of the 

contamination risks? 

! Is any oil mixed with motor fuels, waste solvents, other waste oils, etc.? 

! Are PCB Items located in or near drainage systems? 

PCB Inspection Manual 3-13 August 2004 
(Polychlorinated Biphenyls)

Inspection Procedures Chapter Three 

Waste Oil Use 

The regulations specifically prohibit the use of waste oil containing any amount of PCBs for road 

oiling, dust control, pesticide carriers, sealant, or rust prevention. However, waste oil may be 

burned for energy recovery in accordance with §761.20(e). In general, when ensuring 

compliance with waste oil provisions, the inspector should ascertain the following: 

! Does the facility use waste oil for any of these purposes? 

! What is the source of the waste oil? 

! Does the facility burn waste oil for energy recovery (e.g., space heaters, boilers,

furnaces)? If so and the facility has a history of PCB spills and/or leaks, consider

sampling the waste oil.

Sites 

The inspector may find evidence of leaks, spills, and illegally discarded PCB Items at various 

sites throughout the facility: 

! Scrap areas and/or dumps

! Abandoned buildings and vehicles

! Outbuildings

! Construction sites

! Warehouses

! Loading docks

! Basement sumps/underground tanks.

3.6 Marking Assessment (§§ 761.40 and 761.45) 

The objective of the marking assessment is to determine that 

all items are marked in accordance with the regulations so 

that PCBs and PCB Items are clearly identified. The 

inspector should document in the field notebook all evidence 

of non-compliance and sample when necessary to establish 

the PCB level. The inspector should identify the exact 

location of each item in violation. The inspector should 

photograph the item and its nameplate and all sample Figure 3-1. Small PCB Mark, 

locations and photograph suspected areas of non- also referred to as MS. See 

CAUTION CONTAINS PCBs 

(Polychlorinated Biphenyls) 

FOR PROPER DISPOSAL INFORMATION 

CONTACT U S ENVIRONMENTAL 

PROTECTION AGENCY 

Appendix C for a Large PCB Mark compliance and document these areas in the field notebook. (ML) that is six inches by six (See Chapter Five for regulatory requirements and inspection inches, the size required by the procedures pertaining to marking.) regulations at §761.45(a). 

August 2004 3-14 PCB Inspection Manual 
Chapter Three Inspection Procedures 

Throughout the physical assessment, the 

inspector should check compliance with the 

marking requirements, giving particular 

attention to: 

! How all required items, including the 

transformer, transformer accesses, 

capacitors, and PCB Containers are 

marked 

! How transport vehicles are marked 

! How storage areas, including 

temporary storage areas, are 

marked. 

Figure 3-2. PCB Transformer nameplate. 

3.7 Storage Assessment (§ 761.65) 

The objective of the storage assessment is to determine whether the facility properly stores all 

PCBs and PCB Items. The inspector should check to see whether storage operations comply 

with the regulations, document all discrepancies in the field notebook, and sample when 

necessary to establish the PCB level. The inspector should identify the location of items 

suspected to be in violation and take photographs of these items when appropriate. In addition, 

the inspector should inspect the storage site(s) on the facility premises. If the site is not within 

the facility boundaries, the inspector should note the address and operator of the site. (See 

Chapter Five for specific requirements pertaining to storage.) 

Safety Note. The inspector should exercise caution prior to entering a closed storage area or 

vault. The storage area should be ventilated sufficiently before entering because hazardous 

conditions may exist (e.g., low oxygen content, explosive vapors). 

PCB Inspection Manual 3-15 August 2004 
Inspection Procedures Chapter Three 

3.7.1 Storage Facility 

In evaluating the storage facility, the inspector should consider: 

! How is the facility marked for PCB? 

! Does the facility have adequate roof and

walls to prevent rain water from reaching

the stored PCBs or PCB Items?

! Is the containment volume sufficient for

quantity of PCBs stored?

! Is the containment area free of drains,

valves, joints, or other openings?

! Are flooring and curbing requirements 

met? Figure 3-3. PCB Transformers in storage. 

! Is the site above the 100-year flood

elevation?

3.7.2 Storage Containers 

The inspector should determine the following when checking containers: 

! Do containers meet DOT specifications 49 CFR Subchapter I? 

For liquid PCBs: Specification 5 container without removable head, Specification 5B 

container without removable head, Specification 6D over pack with specification 2S or 

2SL polyethylene containers or specification 17E container. 

For non-liquid PCBs: Specification 5 container, Specification 5B container or 

Specification 17C container. 

! Are storage containers dated and marked? 

! Are other containers used? 

- If yes, have design review requirements been met? Has a Spill Prevention Control 

and Countermeasure (SPCC) Plan been prepared? Are required records being 

kept? Has a registered professional engineer certified the SPCC Plan? 

August 2004 3-16 PCB Inspection Manual 
Chapter Three Inspection Procedures 

3.7.3 Storage Facility Operation 

A number of issues pertain to this area of the assessment: 

! Does the facility have written storage procedures?

! Are articles and containers checked for leaks every 30 days?

! Are leaking articles and containers transferred to nonleaking containers?

! Is spilled or leaked material cleaned up immediately?

! Is movable equipment properly decontaminated prior to being removed from the facility?

! Are containers and articles handled in a manner that protects them from accidental

damage or breakage?

! Are the containers/articles dated with the out-of-service date?

! Are the containers/articles carrying PCBs properly marked?

! Is the storage-for-disposal area properly marked?

3.7.4 Outside Storage 

Outside storage is overflow from a permanent storage location. The inspector should make 

sure that outside storage areas meet all applicable regulations: 

! Are large high voltage PCB Capacitors and PCB-Contaminated Electrical Equipment that 

have not been drained of free flowing dielectric fluid the only items stored outside the 

prescribed storage area? 

- Are they on pallets? 

- Are they structurally undamaged and free of leaks? 

- Are they checked weekly for leaks? 

! Is the outside area adjacent to the prescribed storage area? 

! Does the facility maintain immediately available space in the prescribed storage area to 

accommodate 10 percent of the volume of capacitors and transformers stored outside? 

3.7.5 Temporary Storage 

Temporary storage is any storage location used for less than 30 days. The use of temporary 

storage also raises a number of issues: 

PCB Inspection Manual 3-17 August 2004 
Inspection Procedures Chapter Three 

! Is the temporary storage area properly marked? 

! Are only nonleaking articles and containers in temporary storage? 

- Have articles and containers been in the storage area less than 30 days? 

- Do they have attached notations indicating the date they were removed from service? 

- Are PCB liquids below 500 ppm being stored using a SPCC Plan? The inspector 

should keep in mind that liquid PCBs containing more than 500 ppm PCBs may not 

be temporarily stored. 

- Do containers of PCB-contaminated liquid bear notations of PCB content? 

3.8 Closing Conference 

The inspector should hold a closing conference with the facility officials. The inspector should 

limit the discussion to specific findings of the inspection. The inspector should note to the facility 

officials that the Regional Office, not the inspector, determines overall compliance upon final 

review of the report and other pertinent information. Therefore, the inspector should not discuss 

compliance status, legal effects, or enforcement consequences of non-compliance, unless this 

authority has been delegated to the inspector. Generally only the Division Director or whoever 

has been delegated authority may make compliance determinations after reviewing all of the 

evidence. The inspector may refer facility officials to approved compliance assistance sources 

and documents. At this meeting, an inspector may request additional data, ask questions, and 

secure necessary receipts (see Section 3.8.2). 

3.8.1 Discussions 

The inspector should discuss and clarify any questions or problems relating to the inspection. 

The inspector should: 

! Without using the term violation, inform facility officials of any leaks, spills, or other 

problems that may need immediate attention and relay information to the facility official 

concerning any conditions which may require corrective action. 

! Respond to questions regarding TSCA and the PCB regulations and refer any questions 

that exceed his/her knowledge or authority to other EPA personnel. 

! Ensure the EPA sample chain-of-custody form is completed and maintain sample 

integrity until the sample is delivered or shipped to laboratory. 

! Do not advise that no violations were found (even if he/she believes this is the case) 

unless this authority has been delegated to him/her. The inspector should explain to 

facility official(s) that EPA makes compliance determinations after reviewing all of the 

evidence. 

August 2004 3-18 PCB Inspection Manual 
Chapter Three Inspection Procedures 

3.8.2 Required Receipts 

Under TSCA, inspectors must give written receipts for samples and documents taken from the 

facility. These include the following: 

! Receipts for Samples and Documents. Inspectors should list and describe all 

samples taken and all documents taken or copied during the inspection, sign the receipt, 

obtain facility official signatures, and distribute the appropriate copies to facility officials. 

! Declaration of Confidential Business Information. Inspectors should list and 

describe all information the facility declares as confidential, sign the receipt, obtain facility 

official signatures, and distribute the appropriate copies to facility officials. 

Note: Inspectors may not send any CBI documents via U.S. mail. Documents must be hand 

delivered to the DCO. 

3.9 Compliance Assistance 

Since inspectors are often the only contact between EPA and the regulated industries, they 

should be aware of opportunities to promote compliance with EPA regulations. After an 

inspection, the inspector will have first-hand knowledge of the inspection site, as well as 

knowledge of any specific questions or problems the site officials may have. The inspector can 

use this time to answer those questions and/or convey information that will move the site toward 

improving compliance and acting in an environmentally responsible manner. Please refer to the 

National Policy: The Role of the EPA Inspector in Providing Compliance Assistance During 

Inspections (Appendix B) for more information. 

3.9.1 General Outreach Activities 

Since the purpose of the inspection process is to promote future compliance as well as to 

identify past and current violations, it is important for the inspector to help raise the level of a 

facility's awareness of both PCB regulations and other EPA regulations. The inspector may 

leave EPA listings of the names and telephone numbers of other media programs (i.e., air, 

water) to help promote compliance with other EPA programs. 

Depending on the particular situation, specific EPA or State initiatives may be applicable to the 

facility. Examples of such initiatives include pollution prevention or EPA’s Green Lights program. 

The inspector can give the facility contact names, brochures, publications, or other materials 

that address topics of concern to the site. 

PCB Inspection Manual 3-19 August 2004 
Inspection Procedures Chapter Three 

3.9.2 Information Sources 

The inspector has a broad selection of information sources from which to obtain outreach/ 

educational materials. These sources include: 

! EPA OECA Website. www.epa.gov/oeca/monitoring/index.html. 

! EPA’s PCB Home Page. EPA’s internet site at http://www.epa.gov/pcb/ includes links to 

statutory and regulatory language, question and answer documents, spill cleanup policy 

guidance, regional contact lists, and other information sources. Versions of the PCB 

Transformer Registration Database and the PCB Activity Database are available for 

download. The site also includes listings of approved commercial storers and disposers. 

! Pollution Prevention Information Clearinghouse (PPIC). On EPA’s internet site at 

http://www.epa.gov/opptintr/library/ppicindex.htm. PPIC is a free, nonregulatory 

clearinghouse focusing on source reduction and recycling of industrial wastes. It 

contains technical, policy, programmatic, legislative, and financial information. 

! Inspectors Compliance Assistance Resources Guide. Located on EPA Inspector 

Website at http://intranet.epa.gov/oeca/oc/campd/inspector. 

August 2004 3-20 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

Chapter Four 

Equipment-Specific Information 

Page 

4.0 Equipment-Specific Information ........................................... 4-1

4.1 Transformers ......................................................... 4-1

4.1.1 Background .......................................................... 4-1

4.1.2 Transformer Locations .................................................. 4-2

4.1.3 Maintenance and Repair of PCB Transformers .............................. 4-5

4.1.4 Manufacturers and Trade Names ......................................... 4-7

4.2 Capacitors ........................................................... 4-9

4.2.1 Background .......................................................... 4-9

4.2.2 Locations ........................................................... 4-10

4.2.3 Maintenance and Repair ............................................... 4-10

4.2.4 Manufacturers and Trade Names ........................................ 4-10

4.3 Other Electrical Equipment ............................................. 4-12

4.4 Hydraulic Systems .................................................... 4-12

4.4.1 Background ......................................................... 4-12

4.4.2 Manufacturers and Trade Names ........................................ 4-13

4.5 Other PCB Equipment ................................................. 4-13

4.5.1 Fluorescent Light Ballasts .............................................. 4-13

4.5.2 Heat Transfer Systems ................................................ 4-14

4.5.3 Natural Gas Pipelines .................................................. 4-15

4.5.4 Electric Motors ....................................................... 4-16

4.5.5 Electromagnets ...................................................... 4-16

4.5.6 Products Containing PCBs ............................................. 4-16

PCB Inspection Manual 4-i August 2004 
Equipment-Specific Information Chapter Four 

Tables 

Table 4-1. Estimate of the Number of Registered Transformers by Industry Sector ..... 4-4

Table 4-2. Transformer Manufacturers and PCB Fluid Trade Names ................ 4-8

Table 4-3. Capacitor Manufacturers and PCB Fluid Trade Names ................. 4-11

Table 4-4. Hydraulic Fluid Manufacturers and Trade Names ...................... 4-13

Table 4-5. TSCA Disposal Requirements for Fluorescent Light Ballasts ............ 4-14

Table 4-6. Heat Transfer Fluid Manufacturers and Trade Names .................. 4-15

August 2004 4-ii PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

4.0 Equipment-Specific Information 

An inspector may encounter several types of PCB-containing equipment during a PCB 

inspection. This equipment consists chiefly of five major categories: transformers, capacitors, 

other electrical equipment, hydraulic systems, miscellaneous (e.g., fluorescent light ballasts, 

heat transfer systems), and other equipment. This chapter provides the inspector with general 

information on these major categories of regulated PCB equipment for which EPA authorizes 

certain activities (e.g., servicing and/or use), in accordance with Section 6(e) of TSCA. 

For each type of PCB equipment discussed, this chapter provides information on the typical 

economic sectors using the equipment and a list of manufacturers and trade names. This 

chapter also includes information on inspections relating to specific equipment and the risk of 

contamination from exposure to such equipment. 

The sections below summarize those regulations pertaining only to activities authorized for the 

specific equipment. Section 761.30, "Authorizations" describes these authorization provisions. 

General regulatory requirements (e.g., provisions concerning disposal and storage, marking, and 

recordkeeping) also apply to authorized uses of such equipment. Inspectors should refer to 

Chapters Three and Four as well as the regulations when preparing to conduct inspections. 

Each section in this chapter contains a list of manufacturers and trade names used for PCBs or 

materials containing PCBs. Appendix E contains a comprehensive listing of PCB 

manufacturers and the trade names they used for PCB materials. 

4.1 Transformers [§761.30(a) and (b)] 

4.1.1 Background 

Transformers increase or decrease the voltage 

level of an electric current. Electrical 

transformers are often filled with a dielectric liquid 

that increases the resistance of the unit to arcing 

and acts as a heat transfer medium, helping to 

cool the coils. Today, most transformers are 

filled with mineral oil or silicone. 

PCBs are chlorinated fire-resistant fluids that 

meet the definition established in the National 

Electrical Code (NEC) for askarel, the generic 

name for non-flammable synthetic chlorinated 

hydro-carbons used for insulating media. Figure 4-1. Two PCB Transformers. 

PCB Inspection Manual 4-1 August 2004 
Equipment-Specific Information Chapter Four 

Askarel transformers, containing 40 to 60 percent PCBs, with the remainder of the fluid being 

chlorobenzenes, were manufactured in the United States from 1929 to 1978. Askarel 

transformers were made in a variety of sizes, containing from three to 3,000 gallons (average 

235 gallons) of liquid. They were generally used in locations where flammability was a concern. 

Many mineral oil transformers may have been contaminated with PCBs through servicing or at 

the time of manufacturing. Figure 4-2 shows an oil filled transformer and a non-oil filled 

transformer. 

The regulations define PCB and PCBs as any chemical substance that is limited to the biphenyl 

molecule that has been chlorinated to varying degrees or any combination of substances which 

contains such substances. The regulations define a PCB Transformer as any transformer 

containing 500 ppm PCBs or greater. PCB-Contaminated Transformers contain PCBs at 

concentrations greater than or equal to 50 ppm and less than 500 ppm. The inspector should be 

aware that the PCB concentration of transformer bushings may differ from the transformer. 

The inspector should note that regulations pertaining to railroad transformers are separate from 

those relating to other transformers. Therefore, the information pertaining to railroad transformer 

regulations, as well as to maintenance, repair, and inspection of railroad transformers, is 

presented separately, later in this chapter. 

4.1.2 Transformer Locations 

As of August 28, 1998, owners/operators of PCB Transformers in use, or in storage for reuse, 

must register those transformers with EPA. Owners/operators of a transformer who failed to 

register in 1998 are still required to register. This registration is a one-time requirement. When 

an owner/operator of a company removes PCB Transformers from service and disposes of 

them, it need not update its original registration. EPA has developed a database of the 

registered PCB Transformers (the PCB Transformer Registration Database) which can be 

accessed at www.epa.gov/pcb/data.html. Based on a simple analysis of the company names in 

the October 2001 version of this database, the industries listed in the table below registered the 

most transformers. The inspector should use the information below only as a general guide to 

which industries commonly have PCB Transformers, as opposed to an exact count of the 

transformers in use. Some owners of PCB Transformers may not have registered, while others 

incorrectly registered. 

August 2004 4-2 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

Non-Oil Filled 

Transformer 

Oil Filled 

Transformer 

Surge 

Arrestor Surge 

Arrestor 

Surge 

Arrestor 

Figure 4-2. Oil filled and non-oil filled transformers. 

PCB Inspection Manual 4-3 August 2004 
Equipment-Specific Information Chapter Four 

Table 4-1. Estimate of the Number of Registered 

Transformers by Industry Sector 

Industry Sector Number of Registered 

Transformers 

Utilities 10,644 

Steel 1,968 

Federal 1,805 

Metal 1,292 

Automotive 1,063 

Paper and Paper Products 391 

Tire and Rubber 344 

Mining 340 

Education 308 

Transportation 287 

Textiles 221 

Durable Goods 215 

Chemicals and Polymers 208 

Cement and Concrete 179 

Non-Federal Government 164 

Fertilizer and Allied Products 150 

Glass 135 

Pharmaceutical 113 

Oil/Gas/Refinery 111 

Building Materials 102 

Other 1,814 

Grand Total 21,854 

PCB Transformers are in use in a wide variety of locations, often including: 

Utilities 

! PCB Transformers can be found in: 

- Distribution substations 

- Generating facilities (including coal, gas, and nuclear facilities). 

August 2004 4-4 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

Mines 

! Transformers are usually located within the power substation that supplies electricity to 

the entire mine. (See Appendix F for more information regarding the use and distribution 

of PCBs in underground mines and training and safety issues for inspectors visiting 

mines.) 

Industrial and Other Sectors 

! Industries with high-power requirements or equipment are likely to have PCB 

Transformers. Likely locations of PCB Transformers include: 

- In electrical substations 

- Inside, around, or on top of buildings 

- In powerhouses that generate and distribute electrical power throughout the facility 

- In underground vaults. 

! Transformers can also be found in the broadcasting industry. 

Commercial Buildings 

! PCB Transformers often are used inside commercial buildings to meet fire code 

restrictions or to reduce fire insurance premiums. Most commercial building owners 

contract the servicing of their transformers to transformer maintenance and repair 

companies. However, commercial building owners may not own PCB Transformers. 

The electric utility providing service to the building often owns such units. The inspector 

should determine who owns and is responsible for the unit. 

! Neon signs may also contain PCB Transformers and may be found on old or abandoned 

commercial buildings or in scrap yards. 

Railroads and Subways 

! Railroad companies used PCBs in on-board transformers in electric locomotives and 

self-propelled cars in service in the Northeast Corridor (Washington to Boston). The 

transformers reduce the high voltage current from overhead lines. Subway systems 

used PCB Transformers to distribute power to subway cars. Transformers are generally 

underground. 

4.1.3 Maintenance and Repair of PCB Transformers 

PCB Transformers (both railroad and others) require periodic maintenance and repair, which 

may be handled by facility staff or by independent contractors. 

! Independent firms may contract to maintain and repair transformers for all types and 

sizes of industries, including small firms (e.g., commercial buildings). 

PCB Inspection Manual 4-5 August 2004 
Equipment-Specific Information Chapter Four 

! Maintenance divisions of larger industries may operate facilities to maintain and repair 

transformers. These divisions occasionally service transformers for other firms. 

Maintenance operations take place both onsite (at the operating location of the equipment) and 

offsite (at a special shop or facility operated by the firm or by the contractor). 

! Onsite maintenance and repair may involve considerable handling of PCBs, including: 

- Transport of items such as waste liquids and contaminated rags to storage or 

disposal. 

! Offsite maintenance may occur in specific facilities used only for transformer 

maintenance or in shops that handle other maintenance as well. The handling includes: 

- Removal of the transformer from the operating site 

- Transport of damaged or leaking equipment 

- Transport of waste to storage or disposal site 

- Reinstallation of repaired equipment. 

PCB Transformer Maintenance 

PCB Transformers (excluding railroad transformers, which are discussed below) require 

service periodically and repair when out-of-order. Maintenance includes: 

! Sampling fluid to test dielectric strength 

! Topping off fluid (historically a source of PCB contamination) 

! Replacing gaskets, bushings, insulators, etc., which may involve partial draining of the 

unit 

! Removing and filtering the dielectric liquid and refilling the unit 

! Removing PCB liquid and refilling with replacement dielectric fluid 

! Generating waste liquid, contaminated rags, equipment, etc., which must be disposed of 

in accordance with the regulations. 

Railroad Transformer Maintenance 

Railroad transformers require additional and more frequent maintenance because of their unique 

installation and operating circumstances: 

! On-board transformers are subject to severe conditions (high loads, cramped space) 

and require a high level of maintenance. 

! Pumps circulate oil containing PCBs through the transformers, where the oil absorbs 

heat, to a series of finned radiators which dissipate the heat. 

August 2004 4-6 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

! Transformers and the cooling apparatus located in the undercarriage are subject to 

damage from objects dislodged from the roadbed. Inspectors should be aware that 

leaks can cause exterior surfaces to become contaminated. 

Maintenance frequently takes place in repair pits, which can become severely contaminated with 

PCBs. Operations are similar to those listed for other PCB Transformers, but include additional 

activities, such as: 

! Repairing/replacing circulating pumps and damaged, leaking cooling systems and 

radiators 

! Dismantling/disconnecting cooling systems filled with PCB fluids 

! Decontaminating the system and equipment surfaces. 

4.1.4 Manufacturers and Trade Names 

Many manufacturers of PCB askarel liquid identified the substance by a trade name. PCBs 

have been used since 1929, and many of the early manufacturers have gone out-of-business. 

PCB Inspection Manual 4-7 August 2004 
--------------------------

Equipment-Specific Information Chapter Four 

Table 4-2. Transformer Manufacturers and 

PCB Fluid Trade Names 

Transformer Manufacturer PCB Fluid Trade Name 

Allis-Chalmers Chlorextol 

American Corporation Asbestol 

Cornell Dubilier Dykanol 

Electro Engineering Works 

Envirotech Buell 

ESCO Manufacturing Company Askarel* 

Ferranti-Packard Limited Askarel* 

General Electric Pyranol 

H.K. Porter 

Helena Corporation 

Hevi-Duty Electric Askarel* 

ITE Circuit Breaker Company Non-flammable Liquid 

Kuhlman Electric Saf-T-Khul 

Maloney Electric 

Mitsubishi Kennechlor, Santotherm 

Monsanto (fluid only) Aroclor 

Niagara Transformer Corporation Askarel*, EEC-18 

Power Zone Transformer EEC-18 

Research-Cottrell Askarel* 

Standard Transformer Corporation 

Uptegraff Manufacturing Company 

Van Tran Electric 

Wagner Electric No-Flamol 

Westinghouse Inerteen 

Nepolin 

* Generic name for non-flammable insulating liquids.

Note: There may be other manufacturers and PCB fluid trade names that are not listed.

August 2004 4-8 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

4.2 Capacitors [§761.30(l)] 

4.2.1 Background 

Capacitors regulate the flow of electric current. PCBs were the dielectric fluid used in 

approximately 95 percent of U.S.-produced, liquid-impregnated capacitors manufactured prior to 

1978. The regulations require that all capacitors be disposed of as a PCB Capacitor except 

when a specific capacitor is known not to contain PCBs based on a label or nameplate, 

manufacturers' literature, or chemical analysis. To assist in this determination, EPA regulations 

required all non-PCB, large low voltage capacitors, small capacitors, and fluorescent light 

ballasts manufactured between July 1, 1978, and July 1, 1998, must bear a "No PCBs" label 

[§761.40(g)]. 

There are two general types of capacitors containing PCBs: (1) capacitors built into electrical 

equipment, such as fluorescent lights, televisions, and small motors, which are smaller in size; 

and (2) capacitors used as separate units in electrical power distribution systems, which are 

larger in size (see Figure 4-3). 

The PCB regulatory program under TSCA defines three types of PCB Capacitors in 40 CFR 

761.3: 

! A small capacitor contains less than 1.36

kg (3 pounds) of dielectric fluid.

! A large high voltage capacitor contains 1.36

kg (3 pounds) or more of dielectric fluid and

operates at 2,000 volts (AC or DC) or

above.

! A large low voltage capacitor contains 1.36

kg (3 pounds) or more of dielectric fluid and

operates below 2,000 volts AC or DC.

Figure 4-3. Six large high voltage capacitors. 

PCB Inspection Manual 4-9 August 2004 
Equipment-Specific Information Chapter Four 

4.2.2 Locations 

The following is a list of likely locations, by economic sector, of capacitors. Within these 

sectors, the capacitors may be located almost anywhere. 

Electric Utilities 

! Capacitors are usually located in distribution substations. 

Manufacturing 

! Capacitors are: 

- Located in banks or individually. 

- Located in underground pump stations. 

- Used for power factor correction on motor control circuits and as part of the circuitry 

of electric induction furnaces. 

- Used for power correction or startups of large motors as used commonly with water 

pumps for large air conditioning systems or lift stations. 

- Used for startup of any large motor associated with manufacturing (e.g., drills, saws). 

Subway Systems 

! Large capacitors are used:

- In conjunction with underground transformers.

- On subway cars.

Mines 

! Capacitors are: 

- Usually located within the power substation that supplies electricity to the entire mine 

- Located underground in skid-mounted or wheel-mounted power centers or 

individually

- Often installed in control boxes for large electrical motors.

4.2.3 Maintenance and Repair 

Facilities replace rather than repair non-functioning capacitors. Short-circuiting units can rupture 

and leak. 

4.2.4 Manufacturers and Trade Names 

Several companies manufactured PCB Capacitors in the United States from 1929 until 1978. 

Many of the manufacturers identified the PCB dielectric liquid by trade name. The following list 

of manufacturers and trade names is not necessarily complete and, therefore, should be used 

only as a guide. 

August 2004 4-10 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

Table 4-3. Capacitor Manufacturers and PCB Fluid Trade Names 

Capacitor Manufacturer PCB Fluid Trade Name 

Aerovox Hyvol 

Axel Electronics 

Capacitor Specialists 

Cornell Dubilier Dykanol 

Electrical Utilities Corporation Eucarel 

Electromagnetic Filter Company 

Federal Pacific Non-flammable liquid 

General Electric Pyranol 

Jard Corporation Clorphen 

McGraw Edison Elemex 

Monsanto (fluid only) Aroclor, Capacitor 21, MCS 1489 

P.R. Mallory & Company Arclor B 

R.F. Interonics 

Sangamo Electric Company Diaclor 

Sprague Electric Company Clorinol 

Tobe Deutschmann Labs 

Universal Manufacturing Corporation Askarel* 

Westinghouse Inerteen 

York Electronics 

* Generic name for non-flammable insulating liquids. 

PCB Inspection Manual 4-11 August 2004 
Equipment-Specific Information Chapter Four 

4.3 Other Electrical Equipment [§761.30(h) and (m)] 

Other PCB-Contaminated Electrical 

Equipment includes circuit breakers, 

reclosers, voltage regulators, switches 

(including sectionalizers and motor 

starters), and electromagnets. The 

inspection guidelines are similar to those 

for capacitors. Figure 4-4 shows a circuit 

breaker system and location where PCBcontaminated oil may be found. 

4.4 Hydraulic Systems [§761.30(e)] 

4.4.1 Background 

Hydraulic systems are machines that 

operate by the force exerted by pressurized 

and confined liquid. Many steel 

manufacturing and die casting plants used 

PCBs in hydraulic systems to reduce fire 

hazards on machines that handled hot 

metals. These systems included hydraulic 

systems for metal dye casting equipment, 

trim presses, induction hardening 

machines, heat treating furnaces, forge 

furnaces, and forge presses. The PCB 

regulations authorize the use of hydraulic 

systems containing PCBs below 50 ppm. Figure 4-4. Hydraulic system for closing circuit breaker. 

Owners drained and flushed hydraulic 

systems in an attempt to reduce PCB contamination. However, systems may still be 

contaminated with residual PCBs that remained after refilling with non-PCB fluid. Hydraulic 

systems normally leak several times their capacity each year because the fluid is often 

pressurized to several thousand pounds per square inch causing the system to leak at 

connection joints and piston rings.

 Operating Linkage

 Going to Contacts 

Hydraulic Oil 

Container 

August 2004 4-12 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

4.4.2 Manufacturers and Trade Names 

The following list of hydraulic fluid trade names may not contain all trade names. PCBs have 

been used since 1929, and many of the early manufacturers have gone out-of-business. 

Table 4-4. Hydraulic Fluid Manufacturers 

and Trade Names 

Manufacturer Hydraulic Fluid Trade Names 

Monsanto Pydraul A-200 Pydraul 230 

Pydraul A-200-B Pydraul 230-A 

Pydraul AC* Pydraul 280 

Pydraul AC-A* Pydraul 312 

Pydraul AC-28 Pydraul 312-A 

Pydraul F-9 Pydraul 540 

Pydraul F-9-A Pydraul 540-A 

Pydraul 135 Pydraul 540-B 

Pydraul 135-A Pydraul 625 

Pydraul 150 Pydraul 625-A 

Pydraul 150-A Turbinol 153 

Santovac 1 Santovac 2 

* These were reportedly used as lubricating fluids in some natural gas pipelines as well. 

4.5 Other PCB Equipment 

4.5.1 Fluorescent Light Ballasts 

Light ballasts are the primary electric components of fluorescent light fixtures and are generally 

located within the fixture under a metal cover plate. The PCBs are located in the light ballasts’ 

small capacitor or in the potting material, the insulating material inside the ballast. Since 1978, 

EPA has required manufacturers of fluorescent light ballasts to mark ballasts that do not contain 

PCBs with the statement “No PCBs.” Inspectors should assume that light ballasts contain PCB 

small capacitors if they were manufactured before 1978 or do not have a “No PCBs” statement. 

Table 4-5 indicates the disposal requirements for fluorescent light ballasts. Please note that 

after July 1, 1998, fluorescent light ballast manufacturers are no longer required to mark 

fluorescent light ballasts with the statement “No PCBs.” 

PCB Inspection Manual 4-13 August 2004 
Equipment-Specific Information Chapter Four 

Table 4-5. TSCA Disposal Requirements for Fluorescent Light Ballasts 

PCB Capacitor 

PCB 

Potting 

Material 

Labeling, 

Transportation, and 

Manifesting for 

Disposal 

Disposal 

Reference 

in §761 

Disposal Options 

“No PCBs” label Not regulated under 

TSCA. 

N/A Not regulated under 

TSCA. 

None* < 50 ppm Not regulated under 

TSCA. 

N/A Not regulated under 

TSCA. 

Intact and nonleaking or none* 

> 50 ppm 

-Is a PCB bulk product 

waste. 

-No labeling is required. 

-Manifesting is required for 

disposal in accordance 

with §761.62(a); is not 

required under §761.62(b); 

may be required under 

§761.62(c). 

.50(b)(2)(ii) 

.62(a)-(c) 

-TSCA incinerator** 

-TSCA/RCRA landfill 

Alternate Destruction 

Method. 

-Decontamination 

(§761.65(d) storage may be 

required). 

-Coordinated approval. 

-State-approved landfill 

(leach test required). 

-Risk-based approval. 

Intact and nonleaking < 50 ppm No labeling or manifesting 

required. 

.50(b)(2)(i) 

.60(b)(2)(ii) 

Dispose as municipal solid 

waste (§761 Subpart D 

options). 

Leaking 

< 50 ppm

 or 

> 50 ppm 

-Disposal as PCB bulk 

product waste. 

-No labeling is required. 

-Manifesting is required for 

disposal in accordance 

with §761.62(a); may be 

required under §761.62(c). 

.62(a) or (c) 

-TSCA incinerator* 

-TSCA/RCRA landfill 

Alternate Destruction 

Method-

-Decontamination 

(§761.65(d) storage may be 

required). 

-Coordinated approval. 

-Risk-based approval. 

* "None" means that the capacitor contains no PCB's or was manufactured after 1978. 

** A TSCA incinerator is one approved by the Regional Administrator or by the Director of NPCD to handle TSCA waste. 

Source: www.epa.gov/pub/guidance.html (EPA PCB Website) 

4.5.2 Heat Transfer Systems [§761.30(d)] 

Heat transfer systems use fluids of high heat capacity to remove unwanted heat or to transfer 

heat from one place to another within a system. They are commonly used to provide heat in 

chemical manufacturing where temperatures greater than that provided by steam are needed. 

August 2004 4-14 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

Heat transfer systems in certain applications used PCBs as a heat transfer fluid. Heat transfer 

systems that contained PCB fluid were refilled with non-PCB fluid approximately 90 percent of 

the time. Despite this refilling, most systems contained residual PCBs. Leaks usually occur 

through pump motor seals. 

Inspectors of facilities using PCB heat transfer fluid should ensure that all systems are below the 

50 ppm limit by checking records or sampling (if it is safe to sample). Inspectors should also 

review disposal records such as manifests for PCB-contaminated fluid drained from the 

systems to determine if the facility properly stored the fluids for disposal or disposed of the fluids 

by incineration and visually check for PCB contamination and current releases of PCBs on site 

due to prior spills or disposal of the PCB fluids. 

The following is a list of heat transfer fluid manufacturers although it may not contain all trade 

names. PCBs have been used since 1929, and many of the early manufacturers have gone 

out-of-business. 

Table 4-6. Heat Transfer Fluid Manufacturers 

and Trade Names 

Manufacturer Heat Transfer Fluid Trade Names 

Geneva Industries Monsanto FR-1 

Therminol FR-0 Therminol FR-2 

Monsanto Therminol FR-LO Therminol FR-3 

Therminol FR-1 

4.5.3 Natural Gas Pipelines [§761.30(i)] 

A number of gas pipeline companies used PCBs as a working fluid in their compressors 

between 1950 and the early 1970's. There are several sources of PCBs associated with natural 

gas transmission pipelines. The use of PCBs in turbine compressors leaked PCBs (Arolcors 

1221, 1242 and 1248) into the transmission pipelines and contaminated the existing natural gas 

pipeline liquids (water and condensate). The condensate fraction consists of heavier 

hydrocarbons that may be ignitable, BTEX (benzene, toluene, ethyl benzene and xylenes) and 

naphthalenes. The PCB contamination spread to other interconnected pipeline systems. The 

improper disposal of PCB contaminated condensate into open pits, via spills and venting caused 

significant contamination at natural gas companies such as Texas Eastern and Transwestern 

compressor stations. The historical use of waste oils, contaminated with PCBs, to "fog" or 

lubricate the old pipelines and use (probably minor) of a Rockwell plug valve sealant/grease 

containing PCBs (Aroclor 1268) also contaminated existing natural gas pipeline condensate. 

The use of PCBs (Aroclors 1221, 1242, 1248 and 1254) in reciprocating air compressors and 

associated blowdowns resulted in onsite surface soil and wastewater drainage system PCB 

PCB Inspection Manual 4-15 August 2004 
Equipment-Specific Information Chapter Four 

contamination. This use did not result in transmission pipeline PCB contamination. This 

occurred at Texas Eastern, Tenneco, Columbia Gas, Texas Gas and other companies. 

Current regulations (761.30(i)) authorize the use of PCBs in natural gas pipelines at 

concentrations of less than and greater than 50 ppm PCBs under certain conditions. These 

(761.30(i)) are the rules that now govern the PCBs that still remain in the various natural gas 

transmission pipelines. The old PCB/Compliance Monitoring Program (CMP) was terminated 

when this rule was promulgated in 1998. Additional NGP information and details of the 1981 

and 1996 PCB CMP are found in Appendix G of this manual. 

4.5.4 Electric Motors 

In the late 1960s and early 1970s, Reliance Electric for Joy Manufacturing Company 

manufactured electric motors that contained PCBs. Liquid-filled motors were used because 

they were smaller and lighter than air-cooled motors. Manufacturers chose a PCB mixture for 

the liquid because it was non-flammable, provided adequate lubrication, and possessed the best 

overall combination of electrical properties, chemical stability, and cost. 

Mining machine electric motors used on certain underground continuous loaders built by Joy 

contain PCBs as a coolant fluid in the large cutting head motors and traction motors. Previous 

versions of the regulations established a deadline of January 1, 1982, for phasing-out the use of 

these motors. The current regulations [§761.30(c)] allow the use of PCB-containing mining 

equipment only under 50 ppm. 

Submersible well pump motors manufactured before 1979 may contain up to five ounces of 

PCB dielectric fluid in their capacitors. PCBs may leak out of these submersible well pump 

motors during normal wear-and-tear or when the pump suddenly fails due to lightening strikes or 

electrical failures or shorts. Appendix H contains the manufacturer’s models and serial numbers 

of some of the submersible pump units that contain PCBs. 

4.5.5 Electromagnets [§761.30(h)] 

Regulations prohibit servicing, including rebuilding, of PCB electromagnets with a PCB 

concentration of 500 ppm or greater that requires the removal of internal components. 

4.5.6 Products Containing PCBs 

Other products that may contain PCBs include: 

! Investment casting wax 

! Carbonless copy paper 

! Resins 

! General sealants and coatings, including windshield sealant and silo sealant 

August 2004 4-16 PCB Inspection Manual 
Chapter Four Equipment-Specific Information 

! Lubricants, including bridge bearings and additives to transmission fluids 

! Paint, including marine paint 

! Electrical cable insulation 

! Gaskets 

! Roofing materials. 

PCB Inspection Manual 4-17 August 2004 
Equipment-Specific Information Chapter Four 

Blank Page 

August 2004 4-18 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Chapter Five 

Regulatory Requirements 

and Inspection Procedures 

Page 

5.0 Regulatory Requirements and Inspection Procedures ......................... 5-1

5.1 Authorizations ......................................................... 5-1

5.1.1 Transformer Use Conditions ............................................. 5-1

5.1.2 Transformer Servicing Conditions ........................................ 5-12

5.1.3 Railroad Transformers ................................................. 5-14

5.1.4 Mining Equipment ..................................................... 5-15

5.1.5 Heat Transfer Systems ................................................ 5-15

5.1.6 Hydraulic Systems .................................................... 5-15

5.1.7 Carbonless Copy Paper ................................................ 5-15

5.1.8 Electromagnets, Switches, and Voltage Regulators .......................... 5-16

5.1.9 Natural Gas Pipeline Systems ........................................... 5-19

5.1.10 Research and Development ............................................ 5-23

5.1.11 Scientific Instruments .................................................. 5-24

5.1.12 Capacitors .......................................................... 5-25

5.1.13 Circuit Breakers, Reclosers, and Cable ................................... 5-25

5.1.14 Porous Surfaces Contaminated with PCBs ................................ 5-26

5.1.15 Rectifiers ........................................................... 5-27

5.1.16 Air Compressor Systems .............................................. 5-27

5.1.17 Other Gas or Liquid Transmission Systems ................................ 5-28

5.1.18 Decontaminated Materials .............................................. 5-29

5.2 Storage for Reuse .................................................... 5-30

5.3 Marking of PCBs and PCB Items ......................................... 5-32

5.4 Storage and Disposal .................................................. 5-36

5.4.1 Applicability .......................................................... 5-36

5.4.2 Disposal Requirements ................................................ 5-42

5.4.3 PCB Remediation Waste ............................................... 5-49

5.4.4 Disposal of PCB Bulk Product Waste ..................................... 5-55

5.4.5 Storage for Disposal .................................................. 5-58

5.4.6 Approval of Commercial Storers ......................................... 5-67

5.4.7 Coordinated Approval .................................................. 5-74

5.4.8 Decontamination Standards and Procedures ............................... 5-75

5.5 Transboundary Shipments of PCBs for Disposal ............................ 5-82

PCB Inspection Manual 5-i August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.6 PCB Spill Cleanup Policy ............................................... 5-83

5.7 General Records and Reports ........................................... 5-90

5.7.1 PCBs and PCB Items in Service or Projected for Disposal .................... 5-90

5.7.2 Disposers and Commercial Storers of PCB Waste .......................... 5-93

5.7.3 Retention of Special Records by Storage and Disposal Facilities ............... 5-97

5.7.4 Certification Program and Retention of Records by Importers and Persons

Generating PCBs in Excluded Manufacturing Processes ...................... 5-98

5.7.5 Reporting Importers and by Persons Generating PCBs in Excluded

Manufacturing Processes ............................................. 5-100

5.7.6 Maintenance of Monitoring Records by Persons Who Import, Manufacture,

Process, Distribute in Commerce, or Use Chemicals Containing Inadvertently

Generated PCBs .................................................... 5-101

5.8 PCB Waste Disposal Records and Reports ............................... 5-102

5.8.1 EPA Identification Numbers ............................................ 5-102

5.8.2 Notification of PCB Waste Activity ....................................... 5-103

5.8.3 The Manifest - General Requirements .................................... 5-106

5.8.4 Manifest Procedures ................................................. 5-108

5.8.5 Exception Reporting .................................................. 5-115

5.8.6 Certificates of Disposal ............................................... 5-117

August 2004 5-ii PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.0 Regulatory Requirements and Inspection Procedures 

This chapter presents the key regulatory provisions applicable to PCBs and inspection 

procedures for the major regulatory provisions. The summary addresses authorized activities 

pertaining to PCBs and PCB Items: marking; disposal; storage for disposal; and recordkeeping 

and reporting. Appendices I through M contain operating and reporting requirements applicable 

to the following specific facilities: incinerators, chemical waste landfills, high efficiency boilers, 

alternative disposal facilities, and scrap metal recovery ovens and smelters. Inspectors should 

follow the procedures listed below when conducting an inspection. 

5.1 Authorizations 

5.1.1 Transformer Use Conditions 

Regulation Reference: §761.30 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

Transformers, except railroad transformers, may 

contain PCBs at any concentration for the 

remainder of their useful lives (including servicing 

and rebuilding) subject to the following use 

conditions: 

§761.30(a) 

• As of 10/1/85, a person may not use or store 

for use PCB Transformers in such a manner 

that they pose an exposure risk to food or 

feed. §761.30(a)(1)(i) 

• As of 10/1/90, a person may not use network 

PCB Transformers with higher secondary 

voltages (i.e., voltage > 480 volts, including 

480/277 volt systems) in or near commercial 

buildings. §761.30(a)(1)(ii) 

Determine whether facility location of 

transformers is near food or feed posing 

an “exposure risk to food or feed." 

Remind operator/owner of the definition 

of "exposure." 

Determine whether transformer is a 

"network" or “radial” transformer by 

asking responsible facility official. Then 

review transformer repair, maintenance, 

and rebuilding procedures at the facility: 

• Ask company. 

• Ask utility. 

• Review/obtain electrical schematic. 

PCB Inspection Manual 5-1 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• A person who removes from service a 

network PCB Transformer with higher 

secondary voltages in accordance with this 

requirement must either reclassify the 

transformer to PCB-contaminated or nonPCB status, place it into storage for disposal, 

or dispose of it. §761.30(a)(1)(ii) 

• As of 10/1/85, no person may install PCB 

Transformers which have been placed into 

storage for reuse or which have been 

removed from another location in or near a 

commercial building. §761.30(a)(1)(iii) 

- EPA indefinitely permits the installation of 

a retrofilled mineral oil PCB Transformer 

for reclassification purposes. 

§761.30(a)(1)(iii)(A) 

Check PCB nameplates of 

transformers installed in or near 

commercial buildings. If any are PCB 

Transformers, check to see whether 

service records show that (1) such 

units have been placed into storage or 

(2) relocated from another location. 

August 2004 5-2 PCB Inspection Manual 
--

Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

A person installing a retrofilled 

transformer for reclassification 

purposes must test the PCB 

concentration 3 months after 

installation. Classification from the 

testing results is as follows: 

§761.30(a)(1)(iii)(B) 

* <50 ppm PCB= non-PCB 

transformer 

* 50-500 ppm PCB= PCBContaminated Transformer, and 

* >500ppm= repeat the 

reclassification process until the 

transformer can be classified as to 

non-PCB or a PCB-contaminated 

status; or remove the transformer 

from service. 

• In order to avoid transformer ruptures from 

high current faults, all radial PCB 

Transformers and lower secondary voltage 

network PCB Transformers not located in 

sidewalk vaults (i.e., network transformers 

with secondary voltages <480 volts) must 

have electrical protection if they are located in 

or near commercial buildings. 

§761.30(a)(1)(iv) 

Request and review reclassification 

PCB testing data. Ensure 

reclassification procedures and testing 

data are in compliance with regulations. 

Proper procedures include: 

• owner/operator assumption that 

transformer contains >1000 ppm of 

PCBs. 

• owner/operator retrofills transformer 

with fluid containing <50 ppm of 

PCBs and assumes transformer is 

a PCB-Contaminated Transformer 

(50 ppm - 500 ppm). 

• or use appropriate testing methods 

such as those listed under 40 CFR 

760(g)(1)(iii): Gas Chromatography 

methods: 

- EPA Method 608 

“organochlorine Pesticide and 

PCBs found at 40 CFR part 136, 

Appendix A 

- EPA Method 8082 - PCB by 

Capillary Column Gas 

Chromatography, SW-846, 

available from NTIS 

Obtain copies of documentation for 

reclassification procedures. 

Conduct visual inspection and check 

facility records for existence of such 

units at the facility and determine 

whether electrical protection has been 

installed and the date of installation. 

PCB Inspection Manual 5-3 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• As of 10/1/90, PCB Transformers must have 

protective equipment, such as current-limiting 

fuses or other equally effective methods, to 

detect sustained high current faults and deenergize the transformer before transformer 

rupture occurs. The owner of the transformer 

must install, set, and maintain the protective 

equipment in accordance with good 

engineering practices. §761.30(a)(1)(iv)(A) 

• As of 10/1/93, lower secondary voltage 

network PCB Transformers located in or near 

commercial buildings (not located in sidewalk 

vaults) must have protective equipment. 

§761.30(a)(1)(iv)(B) 

• The owner must register the PCB 

Transformer with the EPA Regional 

Administrator (RA) by 10/1/90. The 

registration must include §761.30(a)(1)(iv)(C): 

- Location of the PCB Transformer 

- Building address/building location of the 

transformer 

- Transformer identification number. 

• As of 10/1/93, no lower secondary voltage 

network PCB Transformers located in 

sidewalk vaults in use near commercial 

buildings may be in service. 

§761.30(a)(1)(iv)(D) 

• As of 10/1/93, in order to avoid transformer 

ruptures from low current faults, all radial 

PCB Transformers with higher secondary 

voltages (i.e., > 480 volts, including 480/277 

volt systems) must have electrical protection 

if they are located in or near commercial 

buildings. §761.30(a)(1)(v) 

• Facilities must have detection equipment 

such as pressure and temperature sensors 

or other equivalent technology to detect 

sustained low current faults. 

§761.30(a)(1)(v)(A) 

Document types of protective 

equipment via statements from 

responsible officials, photos, electrical 

drawings, and service records. Ask 

responsible official(s) to clarify any 

uncertainties. 

Determine from registration records 

whether any lower secondary voltage 

network transformers are PCB 

Transformers. If any are PCB 

Transformers, inspect for required 

protective equipment. 

Verify that the owner registered each 

PCB Transformer with EPA or Regional 

offices by comparing the PCB 

Transformer Registration Database 

(www.epa.gov/pcb/data.html) with the 

identification number of each 

transformer in the facility. 

Explain to responsible official what a 

secondary voltage network transformer 

is and ask if there are any. Check 

facility records for dates removed from 

service, if such units exist at facility. 

Conduct visual inspections for operation 

of such units at facility and determine 

whether electrical protection has been 

installed and date of installation. 

If any, check facility records for use of 

such equipment. Ask facility official(s) 

for clarification if necessary and for 

locations of equipment. Ensure that 

applicable criteria are met. 

August 2004 5-4 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• Disconnect equipment must be provided to 

ensure complete de-energization of 

transformer in the event of abnormal 

conditions in accordance with 

§761.30(a)(1)(v)(B). Equipment must: 

- Operate automatically within 30 seconds 

to 1 minute of signaling a sustained low 

current fault (circuit breakers must also 

have the capacity to be opened manually 

if necessary); or 

- Allow for manual de-energization from a 

manned onsite control center after 

audio/visual signaling of a sustained low 

current fault. Such manual deenergization must occur within 1 minute 

of the audio/visual signal. 

• The facility must properly install, maintain, 

and set sensitively enough electrical 

protection system to detect sustained low 

current faults such that de-energization 

occurs prior to transformer rupture and PCB 

release. §761.30(a)(1)(v)(C) 

Review settings and maintenance 

records to verify that the electrical 

protection system works properly and 

detects sustained low current faults. 

Review facility procedures with facility 

officials and document the procedures 

to be implemented in case of sustained 

low current fault detection (i.e., who is 

responsible for de-energizing the PCB 

Transformer). 

PCB Inspection Manual 5-5 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• Owners of PCB Transformers (including PCB 

Transformers in storage for reuse) were 

required to register those transformers with 

EPA by 12/28/98. Persons taking possession 

of a registered PCB Transformer after 

12/28/98 do not need to register. An owner, 

who discovers after 12/28/98 an unregistered 

PCB Transformer, must register within 30 

days, unless the owner has already 

registered other PCB Transformers at the 

same location. The registration must include 

the following information §761.30(a)(1)(vi): 

- Company name and address 

- Contact name and telephone number 

- Actual address of PCB Transformers 

- Number of PCB Transformers 

- Total kilograms of PCBs in transformers 

- Signature of authorized representative 

The registration may optionally include 

information on whether any transformers have 

flammable dielectric fluid. 

The owner must keep records of the transformer 

registration with the transformer inspection and 

maintenance records for at least 3 years after 

disposal of the transformer. 

• As of 12/1/85, owners of PCB Transformers 

must register them with the building owner of 

record if they are located in commercial 

buildings and with all owners of buildings 

within 30 meters of the transformer if the PCB 

Transformer is located near commercial 

buildings. The registrations must include the 

following information §761.30(a)(1)(vii): 

- The specific location of the PCB 

Transformer 

- The principal constituent of the 

transformer's dielectric fluid 

- The type of transformer installation 

Check the PCB Transformer 

Registration Database 

(www.epa.gov/pcb/data.html) prior to 

the inspection to find registrations from 

the facility. During the inspection, 

review the inspection and maintenance 

records for PCB Transformers to locate 

registration records. 

Verify that the registration contains the 

required information (refer to left 

column). 

Ensure registration has all of the 

required information (refer to left 

column). Verify with commercial 

building owners if transformers are 

registered with them and surrounding 

commercial buildings. 

August 2004 5-6 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• Effective 12/1/85, no person may store 

combustibles within a PCB Transformer 

enclosure, within 5 meters of a PCB 

Transformer enclosure, or, if unenclosed, 

within 5 meters of an PCB Transformer. 

§761.30(a)(1)(viii) 

• Once every 3 months with at least 30 days 

between inspections, owners must visually 

inspect PCB Transformers in use or stored 

for reuse. Owners must inspect PCB 

Transformers for leaks of dielectric fluid on or 

around the transformer. The inspections 

should not require electrical shutdowns. 

§761.30(a)(1)(ix) 

• Owners must eliminate the source of any 

external PCB leaks from a PCB Transformer 

and follow proper cleanup and disposal 

requirements (§761.60) for PCBs resulting 

from a leak. Owners must initiate cleanup as 

soon as possible, but no longer than 48 hours 

after discovery of PCB releases. In addition, 

owners must contain PCBs from an active 

leak and inspect the containment daily to 

ensure that human or environmental 

exposures are prevented. §761.30(a)(1)(x) 

Inspect several transformer enclosures 

to ensure that no combustibles are 

stored inappropriately. 

Explain requirement, ask for policy and 

procedures, review records, and obtain 

documentation. 

Explain requirement to facility officials. 

Ascertain what policy and practice the 

facility uses concerning leaks of PCBs 

and obtain documentation, if available. 

Review records to determine whether 

there has been a leak (or leaks) and 

how it was handled. Inspect units that 

leaked and containment area(s). 

PCB Inspection Manual 5-7 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• The owner of a PCB Transformer must report 

any fire-related incidents involving such 

equipment to the National Response Center 

(NRC) (toll free 1-800-424-8802; in 

Washington, DC 202-426-2675). The owner 

must supply the following information to the 

NRC: §761.30(a)(1)(xi) 

- The type of PCB Transformer installation 

involved. 

- The cause of the fire-related incident. 

In addition, the owner of the PCB Transformer 

must seek to contain and control any potential 

releases of PCBs and incomplete 

combustion products as soon as is 

feasible/safely possible. The owner should: 

- Block all floor drains in the transformer's 

vicinity 

- Contain water runoff 

- Control/treat water used in cleanup 

processes prior to release. 

Explain requirements to facility officials. 

Ascertain what policy and practice is at 

facility concerning fire-related incidents, 

and obtain documentation of such 

policy/practice. Obtain documentation 

of incident. Check both National 

Response Center and facility records. 

Through interviews with responsible 

facility officials, records review, and site 

observations, determine whether all 

requirements have been met. Inspect 

transformer/location involved in incident. 

Inspect the facility for proper 

containment and control for potential 

PCB releases. Ensure the areas 

comply with requirements (refer to left 

column). 

August 2004 5-8 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• Owners of PCB Transformers must keep 

inspection and maintenance records. They 

must maintain the records until at least 3 

years after disposal of the PCB Transformer 

and make these records available for EPA 

inspection. The records must include the 

following §761.30(a)(1)(xii): 

- The location of the PCB Transformer 

- Visual inspection dates and dates on 

which any leaks were discovered 

- Name of inspectors 

- Location of any leaks 

- Estimates of amounts of dielectric fluid 

released from leaks 

- Dates and descriptions of any cleanup, 

containment, repair, or replacement 

- Description of results of containment and 

daily inspection records for any 

uncorrected active leaks 

- Transformer registration records 

- Records of transfer of ownership [see 

§761.180(a)(2)(ix)] 

• EPA requires visual inspections only once 

every 12 months if the PCB Transformer 

§761.30(a)(1)(xiii): 

- (A) Has an impervious, undrained, 

secondary containment capacity of at 

least 100 percent of the total dielectric 

fluid volume, or 

- (B) Has a tested concentration of <60,000 

ppm PCBs (after 3 months use if the 

transformer was serviced to reduce the 

PCB concentration). 

A minimum period of 180 days must occur 

between the annual inspections. 

Review records and document missing 

information. If incomplete, request 

responsible official to provide missing 

information and/or clarify. Note what 

type and amount of incomplete 

information or missing records. 

Ask how inspections are conducted, 

who conducts them, and how often they 

are conducted. Review inspection 

records and document facility 

inspection practices. 

PCB Inspection Manual 5-9 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

• If a PCB Transformer in use or stored for 

reuse constitutes an exposure risk to food or 

feed, it is subject to an increased visual 

inspection schedule of at least one inspection 

per week. The user of the PCB Transformer 

is responsible for inspection, recordkeeping, 

and maintenance until the user notifies the 

owner of the potential exposure risk. Once 

notified, the owner is responsible for 

determining the actual extent of the exposure 

risk. §761.30(a)(1)(xiv) 

• Mineral oil transformers tested and found to 

contain >500 ppm PCBs are subject to all of 

the requirements of §761. The owner must 

implement the following steps immediately to 

bring the transformer into compliance 

§761.30(a)(1)(xv): 

- Report fire-related incidents. 

- Mark the transformer within 7 days of 

discovery. 

- Mark the vault door, machinery room, 

fence, hallway, or other access ways 

within 7 days of discovery. 

- Register the transformer with the building 

owner within 30 days of discovery. 

- Install electrical protective equipment if a 

radial transformer/non-sidewalk vault 

lower secondary voltage network 

transformer is located in or near 

commercial buildings within 18 months of 

discovery or by 10/1/90 (whichever is 

later). 

Check facility inspection records of 

PCB Transformers in use or in storage 

for reuse. 

Inquire whether facility has PCB testing 

programs. Check records and obtain 

documentation. Determine compliance 

with conditions. 

Inspect the PCB Transformer for proper 

marking. If missing, photograph all 

sides of the PCB Transformer. 

Inspect vault doors, etc., for proper 

marking. 

Check and review facility owner’s 

records for compliance with registration 

provisions. 

Review documentation as to whether 

the time frames are being met. Obtain 

photos, electrical schematics, policy 

statements. Obtain clarification from 

responsible officials if necessary. 

August 2004 5-10 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Transformer Use Conditions 

- Remove the transformer from service if 

electrical protective equipment is not 

installed on a non-sidewalk vault, or a 

lower secondary voltage network 

transformer within 18 months of discovery 

or by 10/1/93. 

- Remove lower secondary voltage network 

transformers from service if they are 

located in sidewalk vaults within 18 

months of discovery or by 10/1/93. 

- Retrofill and reclassify radial PCB 

Transformers and lower/higher secondary 

voltage network PCB Transformers within 

18 months or by 10/1/90 (whichever is 

later). 

- Retrofill and reclassify higher and lower 

secondary voltage network PCB 

Transformers which are located in 

sidewalk vaults within 18 months or by 

10/1/90 (whichever is later). 

Visually inspect the areas described in 

the left column. 

PCB Inspection Manual 5-11 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.1.2 Transformer Servicing Conditions 

Regulatory Requirements Inspection Procedures 

Transformer Servicing Conditions 

• Owners of PCB-Contaminated Transformers 

(i.e., transformers that have less than 500 

ppm PCBs) must service or rebuild them with 

dielectric fluids containing less than 500 ppm 

PCBs. §761.30(a)(2)(i) 

• No person may service a PCB Transformer 

by removing the transformer coil from the 

casing. §761.30(a)(2)(ii) 

• PCB Transformer owners/operators may 

service the transformers with dielectric fluid at 

any PCB concentration. §761.30(a)(2)(ii) 

• People servicing PCB Transformers must 

capture and reuse the PCBs as dielectric fluid 

or dispose of the PCBs in accordance with 

the disposal regulations. §761.30(a)(2)(iii) 

• Persons servicing PCB Transformers must 

not mix PCBs from PCB Transformers with 

dielectric fluid from PCB-Contaminated 

Transformers. §761.30(a)(2)(iii) 

• Electrical equipment may not contain 

dielectric fluid of less than 500 ppm PCBs 

that has been mixed with fluids of 500 ppm or 

greater. The entire mixture must be 

considered to be greater than 500 ppm PCB 

and must be disposed of in an incinerator that 

meets the requirements in §761.70. 

§761.30(a)(2)(iv) 

Ask facility owner/operator to see 

service records to assess if any 

transformers have been serviced or 

rebuilt in the facility. 

Ensure proper servicing procedures 

were followed, such as: 

• Using dielectric fluids containing 

<500 ppm. 

• Not removing the transformer coil 

from the casing. 

• Not mixing PCBs from PCB 

Transformers with dielectric fluid 

from PCB-Contaminated 

Transformers. 

• Refer to retrofilling chart in 40 CFR 

761.30(a)(2) located in Appendix N 

of this manual. 

August 2004 5-12 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Transformer Servicing Conditions 

• A person may reclassify a PCB Transformer 

as a PCB-Contaminated Transformer or nonPCB Transformer by draining, refilling, and 

servicing the transformer with non-PCB 

dielectric fluid. After 3 months, the dielectric 

fluid must contain 50 to 500 ppm PCBs (for 

PCB-contaminated reclassification) or less 

than 50 ppm (for non-PCB reclassification). 

§761.30(a)(2)(v) 

- If an owner discovers after reclassification 

that the PCB concentration in the 

transformer has changed, the owner must 

follow the regulations based on its actual 

PCB content. 

- Owners must keep reclassification 

records in accordance with §761.180(g). 

• Persons using dielectric fluid containing 50 

ppm or greater PCB to service transformers 

must store the PCBs in accordance with the 

storage for disposal requirements of §761.65. 

§761.30(a)(2)(vi) 

• Only persons granted an exemption under 

TSCA may process or distribute PCBs for the 

purposes of servicing transformers. 

§761.30(a)(2)(vii) 

Determine number of PCB 

Transformers reclassified as PCBcontaminated or non-PCB from 

records. Sample reclassified deenergized transformers if noncompliance is suspected. Check 

testing records. 

Obtain records of facility policy 

concerning storage and servicing. 

Inspect storage area for: 

• proper marking requirements, 

• reports of fire-related incidents, if 

any, 

• inspection requirements, and 

• recordkeeping requirements for 

storage areas. 

If there is evidence that the facility 

processed or distributed PCBs, 

determine whether the facility has an 

exemption. 

PCB Inspection Manual 5-13 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.1.3 Railroad Transformers 

Regulatory Requirements Inspection Procedures 

Railroad Transformers 

• After 7/1/86, the regulations prohibit the use of 

railroad transformers that contain dielectric 

fluids with a PCB concentration greater than 

1,000 ppm. §761.30(b)(1) 

• If the coil is removed from the casing of a 

railroad transformer after 1/1/82, the person 

servicing the transformer may not refill the 

transformer with dielectric fluid containing a 

PCB concentration greater than 50 ppm 

PCBs. §761.30(b)(2)(i) 

• After 1/1/84, persons may only service 

railroad transformers with dielectric fluid 

containing less than 1,000 ppm. 

§761.30(b)(2)(ii) 

• Dielectric fluid may be filtered through 

activated carbon or otherwise industrially 

processed to reduce the PCB concentration. 

§761.30(b)(2)(iii) 

• Persons servicing PCB railroad transformers 

must store PCB dielectric fluid in accordance 

with the storage for disposal requirements of 

§761.65. §761.30(b)(2)(iv) 

• Only those granted an exemption under 

TSCA may process and distribute PCBs for 

purposes of servicing railroad transformers. 

§761.30(b)(2)(v) 

• A person may reclassify a PCB Transformer 

as a PCB-Contaminated Transformer or nonPCB Transformer by draining, refilling, and 

servicing the transformer with non-PCB 

dielectric fluid so that after 3 months, the 

dielectric fluid contains 50 to 500 ppm PCBs 

(for PCB-contaminated reclassification) or 

less than 50 ppm (for non-PCB 

reclassification). §761.30(b)(2)(vi) 

Conduct visual inspections and review 

records. 

Review rebuilding, repair, and 

maintenance records. Determine from 

written work procedures or interviews of 

workers/operators what these 

procedures are. Determine level of 

compliance with servicing restrictions. 

Obtain records of facility policy 

concerning storage and inspect storage 

areas. 

If there is evidence that the facility 

processed or distributed PCBs, 

determine whether the facility has an 

exemption 

Determine number of PCB 

Transformers reclassified as PCBcontaminated or non-PCB from 

records. Sample reclassified deenergized transformers if noncompliance is indicated. Check testing 

records. 

August 2004 5-14 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.1.4 Mining Equipment 

Regulatory Requirements Inspection Procedures 

Mining Equipment 

Mining equipment may only contain PCBs at 

concentrations less than 50 ppm. §761.30(c) 

Check to determine whether PCBs are 

still in use. Sample fluid from 

suspected PCB motors when noncompliance is suspected. 

5.1.5 Heat Transfer Systems 

Regulatory Requirements Inspection Procedures 

Heat Transfer Systems 

Heat transfer systems may only contain PCBs at 

concentrations less than 50 ppm. Persons may 

service heat transfer systems in operation after 

7/1/84 to maintain a PCB concentration less than 

50 ppm. Persons may only service heat transfer 

systems with fluids containing less than 50 ppm 

PCBs. §761.30(d) 

Check records for compliance. Take 

samples as necessary. Question 

facility officials regarding procedures for 

reducing PCB concentrations. 

5.1.6 Hydraulic Systems 

Regulatory Requirements Inspection Procedures 

Hydraulic Systems 

Hydraulic systems may only contain 

concentrations of less than 50 ppm. Persons 

may service hydraulic systems in operation after 

7/1/84 to maintain a PCB concentration less than 

50 ppm. Persons may only service hydraulic 

systems with fluids containing less than 50 ppm 

PCBs. §761.30(e) 

Check records for compliance. Take 

samples as necessary. Question 

facility officials regarding procedures for 

reducing PCB concentrations. 

5.1.7 Carbonless Copy Paper 

Regulatory Requirements Inspection Procedures 

Carbonless Copy Paper 

Any person may use carbonless copy paper in a 

non-totally enclosed manner indefinitely. 

§761.30(f) 

PCB Inspection Manual 5-15 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.1.8 Electromagnets, Switches, and Voltage Regulators 

Regulatory Requirements Inspection Procedures 

Electromagnets, Switches, and Voltage Regulators 

Persons may use PCBs to service or rebuild 

electromagnets, switches (sectionalizers and 

motor starters), and voltage regulators for the 

remainder of their useful lives subject to the 

following conditions: §761.30(h) 

• No one may use or store for service any 

electromagnet that poses an exposure risk to 

food or feed if it contains greater than 500 

ppm PCBs. §761.30(h)(1)(i) 

• Voltage regulators with 1.36 kg (3 lbs.) or 

more of dielectric fluid with a PCB 

concentration of $500 ppm are subject to the 

following regulations: §761.30(h)(1)(ii) 

- The owner must mark the voltage 

regulator in accordance with §761.40. 

- The owner must immediately report any 

fire-related incident to the NRC. 

- The owner must inspect the voltage 

regulator according to the requirements of 

§761.30(a)(1)(ix), (xiii), and (xiv). 

- The owner must comply with the 

recordkeeping and reporting requirements 

at §761.180. 

• If an owner discovers that a voltage regulator 

assumed to have <500 ppm PCBs in fact has 

a concentration $500 ppm, the owner must 

comply with marking requirements within 7 

days, and with fire incident reporting, 

inspection, and recordkeeping/reporting 

requirements immediately. §761.30(h)(1)(iii) 

• No person may service or rebuild 

electromagnets, switches, or voltage 

regulators if the servicing requires the 

removal and rework of internal components 

and the use of PCBs with a concentration of 

> 500 ppm. §761.30(h)(2)(i) 

Interview facility officials and review 

records to see whether such PCB use 

is taking place and to ensure that 

required conditions are being met. 

Review testing records. Locate 

electromagnet at the facility. 

Inspect the voltage regulator for proper 

marking. If missing, photograph all 

sides of the voltage regulator to 

document. 

Check that all requirements are being 

met by verifying that the owner/facility 

designated official complies with: 

• proper marking requirements, 

• reports of fire-related incidents, if 

any, 

• inspection requirements, and 

• recordkeeping requirements for 

storage areas. 

August 2004 5-16 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Electromagnets, Switches, and Voltage Regulators 

• Persons servicing or rebuilding 

electromagnets, switches, or voltage 

regulators that are classified as PCBContaminated Electrical Equipment may only 

use PCBs of less than 500 ppm. 

§761.30(h)(2)(ii) 

• Persons servicing or rebuilding 

electromagnets, switches, or voltage 

regulators must be capture and either reuse 

as dielectric fluid or dispose of in accordance 

with §761.60 all PCBs removed during 

servicing. §761.30(h)(2)(iii) 

• No person may mix PCBs from 

electromagnets, switches, or voltage 

regulators with a concentration 

> 500 ppm with the dielectric fluid from PCBContaminated Electrical Equipment. 

§761.30(h)(2)(iii) 

• No person may use dielectric fluid in electrical 

equipment that is a combination of fluid with 

a concentration of < 500 ppm PCBs and > 

500 ppm PCBs. The regulations require that 

the mixture be disposed of in an approved 

incinerator. §761.30(h)(2)(iv) 

Interview service technicians and 

review servicing protocols to verify 

compliance with PCB concentration 

limits. 

Interview service technicians and 

review servicing protocols to verify 

compliance with dielectric fluid handling 

requirements. 

PCB Inspection Manual 5-17 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Electromagnets, Switches, and Voltage Regulators 

• PCB electromagnets, switches, and voltage 

regulators may be reclassified to PCBContaminated Electrical Equipment or to a 

non-PCB classification. PCB-Contaminated 

Electrical Equipment may be reclassified to 

non-PCB by draining, refilling, and/or 

otherwise servicing the equipment. 

§761.30(h)(2)(v) 

- A person may reclassify electromagnets, 

switches, and voltage regulators as PCBContaminated Electrical Equipment or 

Non-PCB Electrical Equipment by 

servicing the equipment with non-PCB 

dielectric fluid so that after 3 months of inservice use, the dielectric fluid contains 

50 to >500 ppm PCBs (for PCBcontaminated reclassification) or less 

than 50 ppm (for non-PCB 

reclassification). 

- In-service uses means the equipment is 

used electrically under loaded conditions. 

The Assistant Administrator may approve 

an alternative method that simulates 

loaded conditions without further 

rulemaking. 

- If an owner discovers after reclassification 

that the PCB concentration in the 

electromagnet, switch, or voltage 

regulator has changed, the owner must 

follow the regulations based on its actual 

PCB content. 

- Owners must keep reclassification 

records in accordance with §761.180(g). 

• Persons must store PCBs of a concentration 

> 50 ppm used for servicing electromagnets, 

switches, and voltage regulators in 

accordance with disposal requirements 

§761.65. §761.30(h)(2)(vi) 

• Only those granted an exemption under 

TSCA may process and distribute PCBs for 

purposes of servicing electromagnets, 

switches, and voltage regulators 

§761.30(h)(2)(vii). Note: Exemptions may not 

be granted for more than one year (TSCA 

6(e)(3)(B). 

Check facility records, including the 

facility’s required reclassification 

records, for data on reclassified 

electromagnets. 

If facility claims exemption, check facility 

paperwork on exemption granted by the 

Administrator and check if it is current. 

August 2004 5-18 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.1.9 Natural Gas Pipeline Systems 

Regulatory Requirements Inspection Procedures 

Natural Gas Pipeline Systems 

• Natural gas pipeline systems may contain 

PCBs in concentrations of less than 50 ppm. 

§761.30(i)(1)(i) 

• An owner of a natural gas pipeline system 

who is not a seller or distributor of natural gas 

may use PCBs at or over 50 ppm in that 

system. §761.30(i)(1)(ii) 

• An owner of a natural gas pipeline system 

who is a seller or distributor of natural gas 

may use PCBs at or over 50 ppm in that 

system if §761.30(i)(1)(iii)(A): 

- The owner submits to EPA upon request 

a written description of the nature and 

location of PCBs at or over 50 ppm within 

the pipeline system (this may include 

historical information) 

- The owner characterizes the extent of 

PCB contamination by sampling and 

analysis to determine the beginning and 

end points of the segment contaminated 

at 50 ppm or greater. The 

characterization must be complete by 

12/28/98 or 120 days after discovering 

contamination of 50 ppm or greater, 

whichever date is later. This 

characterization may include historical 

information. 

Gather company information to 

determine ownership and business 

lines. 

Review the sampling and 

characterization report to verify that it 

was completed by 12/28/98 or 120 

days after discovering the 

contamination. 

PCB Inspection Manual 5-19 August 2004 
--

--

--

Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Natural Gas Pipeline Systems 

- The owner samples and analyzes for 

PCB concentration all potential sources of 

introduction of PCBs to the pipeline 

system, including compressors, 

scrubbers, filters, and interconnects. The 

sampling and analysis must be complete 

by 12/28/98 or 120 days after the 

characterization of the extent of PCB 

contamination, whichever date is later. 

These analyses may include historical 

data. 

- Within one year of characterization of the 

extent of PCB contamination, the owner: 

reduces all demonstrated sources of 

PCBs $50 ppm to <50 ppm, or 

removes the contaminating sources 

from the pipeline system, or 

implements other engineering 

measures or methods to reduce 

levels to under 50 ppm and prevent 

further introduction of PCBs over 50 

ppm (e.g., pigging, decontamination, 

or in-line filtration). 

Note: The owner may use documented historical 

actions to reduce PCB concentrations to meet 

this requirement. 

- The owner must repeat sampling and 

analysis for PCBs at least annually until 

the pipeline segment or component is 

under 50 ppm PCBs in two successive 

samples with a minimum interval between 

samples of 180 days. 

- The owner must mark aboveground 

sources of PCB liquids $50 ppm with the 

ML mark in accordance with §761.45(a). 

Review the sampling and 

characterization report to verify that all 

potential sources of introduction of 

PCBs to the pipeline system were 

sampled and analyzed. 

Interview facility personnel and review 

records to verify that the owner 

completed one of the three possible 

actions. 

Review sampling records to verify. 

Inspect aboveground sources for the ML 

mark. If missing, document through 

photography and field notes. 

August 2004 5-20 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Natural Gas Pipeline Systems 

• Owners or operators of systems without 

potential sources of PCB contamination need 

not complete characterization, sampling and 

analysis for potential sources, reduction of 

PCB concentration, or marking. They must 

comply with other parts of the regulations 

such as sampling and recordkeeping. 

§761.30(i)(1)(iii)(B) 

• The owner of a natural gas pipeline system 

must document in writing all data and actions 

(taken or not taken) pursuant to the 

requirements of §761.30(i)(1)(iii)(A). The 

owner must keep the records for at least 3 

years after the pipeline segment’s PCB 

concentration falls below 50 ppm. 

§761.30(i)(1)(iii)(C) 

• EPA may modify the requirements of 

§761.30(i)(1)(iii)(A). §761.30(i)(1)(iii)(D) 

• Any person may reuse PCB-contaminated 

natural gas pipe and appurtenances in a 

natural gas pipeline system, provided all freeflowing liquids have been removed. 

§761.30(i)(2) 

• Any person may use PCB-contaminated 

natural gas pipe, drained of all free-flowing 

liquids, in the transport of liquids (e.g., bulk 

hydrocarbons, chemicals, petroleum 

products, or coal slurry), as casing to provide 

secondary containment or protection (e.g., 

protection for electrical cable), as industrial 

structural material (e.g., fence posts, sign 

posts, or bridge supports), as temporary 

flume at construction sites, as equipment 

skids, as culverts under transportation 

systems in intermittent flow situations, for 

sewage service with written consent of the 

Publicly Owned Treatment Works (POTW), 

for steam service, as irrigation systems (<20 

inch diameter) of less than 200 miles in 

length, and in a totally enclosed compressed 

air system. §761.30(i)(3) 

Inspect the area to verify that there are 

no potential sources of PCB 

contamination. 

Review records, if any, and ensure 

compliance with recordkeeping 

requirements. 

Ask if using PCB-contaminated natural 

gas pipeline drained of free-flowing 

liquids in the manner described on the 

left column. If so, verify facility 

owner/operator has written consent of 

the POTW. 

PCB Inspection Manual 5-21 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Natural Gas Pipeline Systems 

• Any person characterizing PCB 

contamination in natural gas pipe or natural 

gas pipeline systems must do so by 

analyzing organic liquids collected at existing 

condensate collection points in the pipe or 

pipeline system. The level of PCB 

contamination found at a collection point is 

assumed to extend to the next collection point 

downstream. Any person characterizing 

multi-phasic liquids must do so in accordance 

with §761.1(b)(4); if no liquids are present, 

they must use standard wipe samples in 

accordance with subpart M of this part. 

§761.30(i)(4) 

• Any person disposing of liquids containing 

PCBs $50 ppm removed, spilled, or 

otherwise released from a natural gas 

pipeline system must do so in accordance 

with §761.61(a)(5)(iv) based on the PCB 

concentration at the time of removal from the 

system. Any person disposing of materials 

contaminated by spills or other releases of 

PCBs $50 ppm from a natural gas pipeline 

systems, must do so in accordance with 

§§761.61 or 761.79, as applicable. 

§761.30(i)(5)(i) 

• Any person who markets or burns for energy 

recovery liquids containing PCBs at 

concentrations <50 ppm PCBs at the time of 

removal from a natural gas pipeline system 

must do so in accordance with the provisions 

pertaining to used oil at § 761.20(e). No 

person may use liquid containing PCBs at 

concentrations above the quantifiable 

level/level of detection removed from a natural 

gas pipeline system in any other way. 

§761.30(i)(5)(ii) 

Review sampling and disposal records 

to verify compliance with 

concentrations stated in 

§761.61(a)(5)(iv), 761.61, or 761.79 as 

applicable. 

August 2004 5-22 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.1.10 Research and Development 

Regulatory Requirements Inspection Procedures 

Research and Development 

A person may use PCBs in a non-totally enclosed 

manner for research and development, subject to 

the following conditions: §761.30(j) 

• User obtains PCBs from sources authorized 

under §761.80 and the PCBs are packaged in 

compliance with the Hazardous Materials 

Regulations at 49 CFR Parts 171 through 

180. 

• User stores all PCB wastes resulting from 

R&D activities (e.g., spent laboratory 

samples, residuals, contaminated media 

such as clothing, etc.) in compliance with 

§761.65(b) and disposes of all PCB wastes in 

compliance with §761.64. 

• A person granted an exemption under 

§6(e)(3)(B) of TSCA may process and 

distribute PCBs for research and 

development. §761.30(j)(4) 

Determine whether PCBs are still in 

use at the facility by reviewing records 

and interviewing facility personnel. 

Inspect area where PCB wastes are 

stored to verify compliance with 

§761.65(b). Review storage and 

disposal procedures and records. 

Verify that the facility has an exemption 

and check with Regional Office and 

National Program Chemicals Division. 

PCB Inspection Manual 5-23 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.1.11 Scientific Instruments 

Regulatory Requirements Inspection Procedures 

Scientific Instruments 

• A person may use PCBs in a non-totally 

enclosed manner indefinitely in scientific 

instruments, e.g., in oscillatory flow 

birefringence and viscoelasticity instruments 

for the study of the physical properties of 

polymers, as microscopy mounting fluids, as 

microscopy immersion oil, and as optical 

liquids. §761.30(k) 

• Only persons granted an exemption under 

TSCA section 6(e)(3)(B) may manufacture, 

process, or distribute in commerce PCBs for 

use in scientific instruments. §761.30(k) 

If PCBs are in use, determine if use is 

allowed. 

If the facility manufactures, processes, 

or distributes PCBs, determine if used 

in scientific instruments by checking to 

whom they ship. 

Check if facility has exemption from 

Administrator and check that it is 

current. Exemptions are only good for 

up to one year. 

August 2004 5-24 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.1.12 Capacitors 

Regulatory Requirements Inspection Procedures 

Capacitors 

Capacitors may contain PCBs at any 

concentration subject to the following conditions: 

§761.30(l) 

• No person may use or store for reuse any 

large PCB High- and Low-Voltage Capacitors 

that pose an exposure risk to food or feed. 

§761.30(l)(1)(i) 

• No person may use large PCB High- and 

Low- Voltage Capacitors unless capacitors 

are within a restricted-access electrical 

substation or in a contained and restrictedaccess indoor installation. §761.30(l)(1)(ii) 

• A restricted-access electrical substation is an 

outdoor fenced or walled-in facility that 

restricts public access and is used for the 

transmission or distribution of electrical 

power. A contained and restricted-access 

indoor installation does not have public 

access and has a roof, wall, and floor that are 

adequate to contain the release of any PCBs. 

§761.30(l)(1)(ii) 

Inspect area to determine whether 

capacitor is near food or feed and 

conditions that allow exposure can 

pose a threat. 

Inspect substation or installation to 

determine that it is 

• an outdoor fenced or walled-in 

facility that restricts public access, 

or 

• an indoor installation that has a roof, 

wall, and floor that are adequate to 

contain the release of PCBs and 

restricts public access. 

5.1.13 Circuit Breakers, Reclosers, and Cable 

Regulatory Requirements Inspection Procedures 

Circuit Breakers, Reclosers, and Cable 

A person servicing circuit breakers, reclosers, 

and cable may use PCBs of any concentration in 

and for the servicing subject to the following 

conditions: §761.30(m) 

• A person may service or rebuild with PCBs of 

less than 50 ppm. §761.30(m)(1)(i) 

• A person must service in accordance with 

§761.30(h)(2) "Use in and servicing of 

electromagnets..." where the PCBs are found 

to be at least 50 ppm. §761.30(m)(1)(ii) 

Review facility records to determine 

compliance with servicing restrictions. 

PCB Inspection Manual 5-25 August 2004 
--

--

Regulatory Requirements and Inspection Procedures Chapter Five 

5.1.14 Porous Surfaces Contaminated with PCBs 

Regulatory Requirements Inspection Procedures 

Porous Surfaces Contaminated with PCBs 

Any person may use porous surfaces contaminated 

by spills of liquid PCBs at concentrations >10 

μg/100 cm2

 for the remainder of the useful life of the 

surface and subsurface material if the following 

conditions are met: §761.30(p) 

• The source of PCB contamination is removed 

or contained to prevent further release to porous 

surfaces. 

• If the porous surface is accessible to superficial 

surface cleaning: 

- The double wash rinse procedure in subpart 

S of this part is conducted on the surface to 

remove surface PCBs. 

- The treated surface is allowed to dry for 24 

hours. 

• After accessible surfaces have been cleaned 

according to paragraph (p)(1)(ii) of this section 

and for all surfaces inaccessible to cleanup: 

- The surface is completely covered to 

prevent release of PCBs with: 

Two solvent resistant and water 

repellent coatings of contrasting colors 

to allow for a visual indication of wear 

through or loss of outer coating integrity; 

or 

A solid barrier fastened to the surface 

and covering the contaminated area or 

all accessible parts of the contaminated 

area. Examples of inaccessible areas 

are underneath a floor mounted 

electrical transformer and in an 

impassible space between an electrical 

transformer and a vault wall. 

Interview facility personnel and 

review records to verify that the 

conditions for using porous surfaces 

contaminated by spills of liquid PCBs 

were met. 

Note: Review 2003 Final Rulemaking 

“Polychlorinated Biphenyls (PCBs) -

Use of Porous Surfaces, 

Amendment in Response to Court 

Decision.” 

Visually inspect the accessible area. 

Note and photograph wear of paint 

coatings, if applicable. 

August 2004 5-26 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Porous Surfaces Contaminated with PCBs 

- The surface is marked with the ML Mark in a 

location easily visible to individuals present 

in the area; the ML Mark shall be placed over 

the encapsulated area or the barrier to the 

encapsulated area. ML Marks shall be 

replaced when worn or illegible. 

A person may remove a porous surface 

contaminated with PCBs from its location or current 

use only for disposal in accordance with §761.61 or 

761.79 for surfaces contaminated by spills, or 

§761.62 for manufactured porous surfaces. 

Inspect the surface for proper 

marking. If missing, worn, illegible, or 

not easily visible, photograph to 

document. 

Verify compliance by reviewing 

records, if available. 

5.1.15 Rectifiers 

Regulatory Requirements Inspection Procedures 

Rectifiers 

Any person may use PCBs at any concentration Review servicing records and 

in rectifiers for the remainder of the PCBs’ useful protocols to verify that only PCBs 

life and may use PCBs <50 ppm in servicing <50 ppm are used to service 

(including rebuilding) rectifiers. §761.30(r) rectifiers. 

5.1.16 Air Compressor Systems 

Regulatory Requirements Inspection Procedures 

Air Compressor Systems 

Any person may use PCBs in air compressor 

systems at concentrations <50 ppm. §761.30(s)(1) 

Any person may use PCBs in air compressor 

systems (or components thereof) at concentrations 

$50 ppm provided that: §761.30(s)(2) 

Verify that the PCB concentration in 

the air compressor system is <50 

ppm. 

Review operating records, if 

available, operating conditions, and 

other relevant information to verify 

compliance. 

PCB Inspection Manual 5-27 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Air Compressor Systems 

• All free-flowing liquids containing PCBs $50 ppm 

are removed from the air compressor crankcase 

and the crankcase is refilled with non-PCB 

liquid. 

• Other air compressor system components 

contaminated with PCBs $50 ppm, are 

decontaminated in accordance with §761.79 or 

disposed of in accordance with subpart D of this 

part. 

• Air compressor piping with a nominal inside 

diameter of less than 2 inches is 

decontaminated by continuous flushing for 4 

hours, at no less than 300 gallons per hour 

(§761.79 contains solvent requirements). 

• These requirements must be completed by 

August 30, 1999 or within 1 yr of the date of 

discovery of PCBs at $50 ppm in the air 

compressor system, whichever is later. The 

EPA may extend this deadline. 

5.1.17 Other Gas or Liquid Transmission Systems 

Regulatory Requirements Inspection Procedures 

Other Gas or Liquid Transmission Systems 

• Intact and non-leaking gas or liquid transmission 

systems may contain PCBs at concentrations 

<50 ppm. §761.30(t)(1) 

• Intact and non-leaking gas or liquid transmission 

systems not owned or operated by a seller or 

distributor of the gas or liquid transmitted in the 

system may contain PCBs at concentrations $50 

ppm. §761.30(t)(2) 

• Any person may use PCBs at concentrations $50 

ppm in intact and nonleaking gas or liquid 

transmission systems, with the written approval 

of EPA, subject to the requirements applicable to 

natural gas pipeline systems at paragraphs 

(i)(1)(iii)(A), (i)(1)(iii)(C) through (i)(1)(iii)(E), and 

(i)(2) through (i)(5) of this section. §761.30(t)(3) 

Interview facility personnel and 

review records, such as operating 

records, written approval for 

operating system, if applicable, or 

any records indicating the system 

PCB concentration, to determine 

who owns or operates the system. 

If the owner or operator is a seller or 

distributer of the gas or liquid 

transmitted in the system, verify that 

the system does not contain PCBs 

at concentrations $50 ppm unless 

the owner/operator has written EPA 

approval from the Director of EPA’s 

National Program Chemicals 

Division. 

August 2004 5-28 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.1.18 Decontaminated Materials 

Regulatory Requirements Inspection Procedures 

Decontaminated Materials 

• Any person may use equipment, structures, other 

non-liquid or liquid materials that were 

contaminated with PCBs during manufacture, 

use, servicing, or because of spills from, or 

proximity to, PCBs $50 ppm, including those not 

otherwise authorized for use under this part, 

provided that the materials were decontaminated 

in accordance with: 

A. A TSCA PCB disposal approval issued under 

subpart D of this part; 

B. Section 761.79; or 

C. Applicable EPA PCB spill cleanup policies 

(e.g., TSCA, RCRA, CERCLA, EPA regional) 

in effect at the time of the decontamination. 

• If not previously decontaminated, the materials 

now meet an applicable decontamination 

standard in §761.79(b). §761.30(u)(1) 

• No person shall use or reuse such 

decontaminated materials in direct contact with 

food, feed, or drinking water unless otherwise 

allowed under this section or this part. 

§761.30(u)(2) 

• Any person may use water containing PCBs at 

concentrations #0.5μg/ L PCBs without 

restriction. §761.30(u)(3) 

• Any person may use water containing PCBs at 

concentrations <200 μg/ L (i.e., < 200 ppb PCBs) 

for non-contact use in a closed system where 

there are no releases (e.g., as a non-contact 

cooling water). §761.30(u)(4) 

Verify that proper decontamination 

procedures were followed by 

reviewing records and procedures. 

Verify that decontaminated materials 

are not in direct contact with food, 

feed, or drinking water. 

PCB Inspection Manual 5-29 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.2 Storage for Reuse 

Regulation Reference: §761.35 

Regulatory Requirements Inspection Procedures 

Storage for Reuse 

The owner or operator of a PCB Article may store it 

for reuse in an area which is not designed, 

constructed, and operated in compliance with 

§761.65(b), for no more than 5 years after the date 

the Article was originally removed from use (e.g., 

disconnected electrical equipment) or 5 years after 

August 28, 1998, whichever is later, if the owner or 

operator complies with the following conditions 

§761.35(a): 

• Follows all use requirements at §761.30 and 

marking requirements at subpart C of this part 

that are applicable to the PCB Article. 

• Maintains records starting at the time the PCB 

Article is removed from use or August 28, 1998. 

The records must indicate: 

- The date the PCB Article was removed from 

use or August 28, 1998, if the removal date is 

not known. 

- The projected location and the future use of 

the PCB Article. 

- If applicable, the date the PCB Article is 

scheduled for repair or servicing. 

Some facilities applied for and 

received EPA approvals for their 

storage for reuse areas. The 

inspector should check for such 

EPA approvals prior to the 

inspection and should consult with 

the permit writer or the person 

responsible for the permit to 

determine if any critical areas of the 

facility need to be inspected or do 

not need to be inspected. Visually 

inspect and verify compliance with 

storage time limit by reviewing 

records and procedures. 

Review records to verify that they 

contain the required information. 

August 2004 5-30 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Storage for Reuse 

The owner or operator of a PCB Article may store it 

for reuse in an area that does not comply with 

§761.65(b) for a period longer than 5 years, provided 

that the owner or operator has received written 

approval from the EPA RA for the Region in which 

the PCB Article is stored. An owner or operator of a 

PCB Article seeking approval to extend the 5-year 

period must submit a request for extension to the 

EPA RA at least 6 months before the 5-year storage 

for reuse period expires and must include an 

item-by-item justification for the desired extension. 

The owner or operator of the PCB Article being 

stored for reuse must comply with the other 

applicable provisions of this part, including the record 

retention requirements at §761.180(a). §761.35(b) 

Any person may store a PCB Article for reuse 

indefinitely in: §761.35(c) 

• A unit in compliance with §761.65(b). 

• A unit permitted under section 3004 of RCRA to 

manage hazardous wastes in containers. 

• A unit permitted by a State authorized under 

section 3006 of RCRA to manage hazardous 

waste. 

Review records to determine if the 

5-year limit has expired. If so, check 

company records for EPA approval. 

If no records found, note what 

required records are missing. Note 

records may be checked at EPA 

prior to the inspection. 

PCB Inspection Manual 5-31 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.3 Marking of PCBs and PCB Items 

Regulation Reference: §§761.40 & 761.45 

CAUTION 

CONTAINS 

PCBs 

(Polychlorinated Biphenyls) 

A toxic environmental contaminant requiring 

special handling and disposal in accordance with 

U.S. Environmental Protection Agency Regulations 

40 CFR 761 - For Disposal Information contact the 

nearest U.S. E.P.A. Office 

In case of accident or spill, call toll free the U.S. 

Coast Guard National Response Center: 

800-424-8802 

Also contact 

Tel. No. 

Figure 5-1. Large PCB Mark, also referred to as ML. 

See Appendix C for a Large PCB mark (ML) that is six 

inches by six inches, the size required by the 

regulations at §761.45(a). 

CAUTION CONTAINS PCBs 

(Polychlorinated Biphenyls) 

FOR PROPER DISPOSAL INFORMATION 

CONTACT US ENVIRONMENTAL 

PROTECTION AGENCY 

Figure 5-2. Small PCB Mark, also 

referred to as MS. The size required 

by the regulations at §761.45(b) is 1 

inch by 2 inches. 

Regulatory Requirements Inspection Procedures 

Marking Requirements 

Each of the following PCB Items in existence on or 

after July 1, 1978, shall be marked with the mark 

ML: (1) PCB containers; (2) PCB Transformers; (3) 

Large High-Voltage Capacitors; (4) Large LowVoltage Capacitors; (5) PCB Large Low Voltage 

Capacitors at the time of removal from use; (6) 

Electric motors using PCB coolants; (7) Hydraulic 

systems; (8) Heat transfer systems; (9) PCB 

Article Containers containing articles or equipment; 

(10) Each storage area used to store PCBs and 

PCB Items for disposal. §761.40(a) 

Check for unmarked or improperly 

marked items. Note location and, if 

available, the serial or identification 

numbers of the equipment. 

Photograph items to document 

unmarked or improperly marked 

items. 

August 2004 5-32 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Marking Requirements 

The owner or operator of each transport vehicle 

loaded with PCB containers that contain more than 

45 kg of liquid PCBs at concentrations of $50 ppm 

or loaded with one or more PCB Transformer shall 

mark the vehicle on each end and each side with 

the ML mark. §761.40(b) 

If one or more PCB Large High Voltage Capacitors 

are installed in a protected location, such as on a 

power pole or behind a fence, the owner or 

operator of the location must mark the structure 

with the ML mark. The owner or operator of the 

protected location must maintain a record or 

procedure identifying the capacitors. 

§761.40(c)(2)(ii) 

After January 1, 1979, manufacturers of equipment 

containing a PCB Small Capacitor must mark the 

equipment with the statement, "This equipment 

contains PCB Capacitor(s)." This mark must be 

the same size as mark ML. §761.40(d) 

As of October 1, 1979, owners or operators of PCB 

containers, electric motors using PCB coolants, 

hydraulic systems, and heat transfer systems 

containing PCBs in concentrations of 50 to 500 

ppm shall mark the items with the ML mark. 

§761.40(e) 

The manufacturer of large low voltage capacitors, 

small capacitors normally used in alternating 

current circuits, and fluorescent light ballasts 

between July 1, 1978, and July 1, 1998, must mark 

the items "No PCBs" if they contain none. Note: 

Requirement has expired. §761.40(g) 

Owners or operators must place all marks required 

in §761.40 in a position on the exterior of the PCB 

items, storage units, or transport vehicles so that 

persons inspecting or servicing the PCB items, 

storage units, or transport vehicles can easily read 

the mark. §761.40(h) 

Inspect transport vehicles (including 

forklifts) for proper marking. 

Photograph unmarked or improperly 

marked PCB transport vehicles. Note 

the type of PCB material carried and 

the vehicle identification number. 

Sample PCB material to determine 

concentration if necessary. 

Inspect the structure for proper 

marking. Photograph unmarked or 

improperly marked structures. Ask to 

review the records or procedures that 

the owner or operator is required to 

maintain identifying the capacitors. 

Inspect the equipment for proper 

marking. Photograph unmarked or 

improperly marked equipment. 

Inspect the equipment for proper 

marking. Photograph unmarked or 

improperly marked equipment. 

Inspect all marks to verify that they 

can be easily read. Photograph 

marks that are faded, damaged, or 

inverted. 

PCB Inspection Manual 5-33 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Marking Requirements 

Containers of PCBs manufactured under an 

exemption granted by EPA are not subject to the 

requirements in §761.40 unless so specified in the 

exemption (PCB Articles and equipment containing 

these PCBs are subject to marking requirements). 

§761.40(i) 

The owner or operator of all PCB Transformer 

locations must mark the vault and machinery room 

doors, fences, hallways, or means of access with 

the ML mark unless the conditions of §761.40(j)(2) 

are met. The owner or operator must place the 

mark in a manner that emergency personnel can 

read easily. §761.40(j) 

As of 4/26/99, the owner or operator of all PCB 

Large Low Voltage Capacitors not marked under 

§761.40(a), shall mark the capacitor individually, or 

shall mark the protected location where the 

capacitor is installed (e.g., power pole, structure, 

or fence). The owner or operator shall maintain a 

record or procedure identifying the PCB Capacitors 

at the protected location. The owner or operator 

does not need to mark each PCB Large Low 

Voltage Capacitors in inaccessible locations inside 

equipment, provided the owner or operator marks 

the equipment in accordance with §761.40(k)(2) 

and marks the individual capacitors at the time of 

removal from use in accordance with §761.40(a). 

§761.40(k)(1) 

As of 4/26/99, the owners or operators of all 

equipment not already required to be marked under 

§761.40(a) containing a PCB Transformer or a 

PCB Large High or Low Voltage Capacitor shall 

mark the equipment. §761.40(k)(2) 

Owners or operators must mark each voltage 

regulator that contains 1.36 kilograms (3 lbs.) or 

more of dielectric fluid with a PCB concentration of 

$500 ppm. §761.40(l)(1) 

Inspect all PCB Transformer locations 

for proper marking. Photograph 

unmarked or improperly marked 

locations. 

Ask to review the records or 

procedures that the owner or operator 

is required to maintain identifying the 

capacitors at protected locations. 

Inspect the capacitors or their 

protective location for proper marking. 

Photograph unmarked or improperly 

marked capacitors or locations. 

Inspect all equipment containing a 

PCB Transformer or large capacitor 

for proper marking. Photograph 

unmarked or improperly marked 

equipment. 

Inspect voltage regulators for proper 

marking. Verify that unmarked voltage 

regulators contain less than 3 lbs. of 

dielectric fluid with a PCB 

concentration of $500 ppm. 

Photograph unmarked or improperly 

marked voltage regulators. 

August 2004 5-34 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Marking Requirements 

Owners or operators of locations of voltage 

regulators that contain 1.36 kilograms (3 lbs.) or 

more of dielectric fluid with a PCB concentration of 

$500 ppm shall mark the vault door, machinery 

room door, fence, hallway, or means of access, 

other than grates or manhole covers with the ML 

mark. §761.40(l)(2) 

Mark ML must be at least 15.25 cm (6 inches) on 

each side. If the PCB Article or PCB Equipment is 

too small to accommodate this size, the mark may 

be reduced in size proportionately down to a 

minimum of 5 cm (2 inches) on each side. 

§761.45(a) 

Mark MS must appear as a rectangle of 2.5 x 5 cm 

(1 inch x 2 inches). The mark may be reduced to a 

minimum of 1 x 2 cm (0.4 x 0.8 inches) if the PCB 

Article or PCB Equipment is too small to 

accommodate this size. §761.45(b) 

All PCB marks must have letters and striping on a 

yellow or white background and must be sufficiently 

durable to equal or exceed the life of the items they 

label. They must be placed on the exterior of items 

so they can be easily read. §761.45 (a) and (b) 

Inspect locations of voltage regulators 

for proper marking. Verify that 

unmarked locations have voltage 

regulators that contain less than 3 lbs. 

of dielectric fluid with a PCB 

concentration of $500 ppm. 

Photograph unmarked or improperly 

marked voltage regulator locations. 

Photograph all sides of items 

potentially not in compliance. Note 

circumstances. Sample unmarked 

suspect items to determine 

presence/concentration of PCBs. 

The marking requirements are not 

applicable to PCB-Contaminated 

Electrical Equipment. 

PCB Inspection Manual 5-35 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.4 Storage and Disposal 

5.4.1 Applicability 

Regulation Reference: §761.50 

Regulatory Requirements Inspection Procedures 

Applicability 

Any person storing or disposing of PCB waste Inspect the facility, interview facility 

must follow subpart D of this part. The following personnel, and review required 

prohibitions and conditions apply to all PCB waste records as specified in Section 4.8 to 

storage and disposal: §761.50(a) determine compliance with the PCB 

waste storage and disposal 

• No person may openly burn PCBs. prohibitions. 

Combustion of PCBs approved under §761.60 

(a) or (e), or otherwise allowed under part 761, 

is not open burning. 

• No person may process liquid PCBs into 

non-liquid forms to circumvent the high 

temperature incineration requirements of 

§761.60(a). 

• No person may discharge water containing 

PCBs to a treatment works (as defined Sec. 

503.9(aa) of this chapter) or to navigable waters 

unless the PCB concentration is <3 Fg/L 

(approximately 3 ppb), or unless the discharge 

is in accordance with a PCB discharge limit 

included in a permit issued under section 

307(b) or 402 of the Clean Water Act. 

• Spills and other uncontrolled discharges of 

PCBs at concentrations of $50 ppm constitute 

the disposal of PCBs. 

• Any person land disposing of non-liquid PCBs 

may avoid otherwise-applicable sampling 

requirements by presuming that the PCBs 

disposed of are $500 ppm (or $100 Fg/100 cm2 

if no free-flowing liquids are present). 

• Any person storing or disposing of PCBs is also 

responsible for determining and complying with 

all other applicable Federal, State, and local 

laws and regulations. 

Any person removing PCB liquids from use (i.e., not 

PCB remediation waste) must dispose of them in 

accordance with §761.60(a), or decontaminate them 

in accordance with §761.79. §761.50(b)(1) 

August 2004 5-36 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Applicability 

Any person removing from use a PCB Item Visually inspect and check what PCB 

containing an intact and non-leaking PCB Article Articles facility has, if any. 

must dispose of it in accordance with §761.60(b), 

or decontaminate it in accordance with §761.79. Check PCB Articles are disposed 

PCB Items where the PCB Articles are no longer properly. For example, transformers 

intact and non-leaking are regulated for disposal as must be disposed of in a TSCA 

PCB bulk product waste under §761.62(a) or (c). incinerator or approved chemical 

§761.50(b)(2) waste landfill. See Section 5.4.2 for 

the disposal requirements for other 

PCB Articles. 

Fluorescent light ballasts containing PCBs only in For the disposal requirements 

an intact and non-leaking PCB Small Capacitor are applicable to flourescent light ballasts 

regulated for disposal under §761.60(b)(2)(ii). refer to Table 3-5. 

Fluorescent light ballasts containing PCBs in the 

potting material are regulated for disposal as PCB 

bulk product waste under §761.62. 

§761.50(b)(2) (i) and (ii) 

PCB remediation waste, including PCB sewage Ask owner/operator if any spills or 

sludge, is regulated for cleanup and disposal in releases of PCBs have occurred and 

accordance with §761.61. §761.50(b)(3) if so, when did they occur, have they 

been remediated, when and how. In 

addition to spills or other releases 

from electrical equipment, inspectors 

should check hydraulic systems. 

Previous use of PCBs in hydraulic 

systems and subsequent spills from 

that system are the main source of 

contamination at facilities currently 

undergoing remediation. Spills from 

the use of PCB-contaminated 

hydraulic oil contaminate surrounding 

floors, drainage systems, outfalls, and 

streams. Inspectors may also collect 

samples from outfalls and oil/water 

separators to check for PCBs. 

PCB Inspection Manual 5-37 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Applicability 

• Any person responsible for PCB waste at 

as-found concentrations $50 ppm that was 

either placed in a land disposal facility, spilled, 

or otherwise released into the environment prior 

to April 18, 1978, regardless of the 

concentration of the spill or release; or placed in 

a land disposal facility, spilled, or otherwise 

released into the environment on or after April 

18, 1978, but prior to July 2, 1979, where the 

concentration of the spill or release was $50 

ppm but < 500 ppm, must dispose of the 

waste as follows: §761.50(b)(3)(i) 

- Sites containing these wastes are 

presumed not to present an unreasonable 

risk of injury to health or the environment 

from exposure to PCBs at the site. 

However, the EPA RA may make a finding 

that an unreasonable risk of injury exists, 

and then direct the owner or operator of the 

site to dispose of the PCB remediation 

waste in accordance with §761.61 such that 

an unreasonable risk of injury no longer 

exists. 

August 2004 5-38 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Applicability 

- Unless directed by the EPA RA to dispose 

of PCB waste in accordance with 

paragraph (b)(3)(i)(A) of this section, any 

person responsible for PCB waste at asfound concentrations >50 ppm that was 

either placed in a land disposal facility, 

spilled, or otherwise released into the 

environment prior to April 18, 1978, 

regardless of the concentration of the spill 

or release; or placed in a land disposal 

facility, spilled, or otherwise released into 

the environment on or after April 18, 1978, 

but prior to July 2, 1979, where the 

concentration of the spill or release was 

greater than 50 ppm but less than 500 ppm, 

who unilaterally decides to dispose of that 

waste (for example, to obtain insurance or 

to sell the property), is not required to 

cleanup in accordance with §761.61. 

Disposal of the PCB remediation waste 

must comply with §761.61. However, 

cleanup of those wastes that is not in 

complete compliance with §761.61 will not 

afford the responsible party with relief from 

the applicable PCB regulations for that 

waste. 

• Any person responsible for PCB waste at 

as-found concentrations $50 ppm that was 

either placed in a land disposal facility, spilled, 

or otherwise released into the environment on 

or after April 18, 1978, but prior to July 2, 1979, 

where the concentration of the spill or release 

was $500 ppm; or placed in a land disposal 

facility, spilled, or otherwise released into the 

environment on or after July 2, 1979, where the 

concentration of the spill or release was $50 

ppm, must dispose of it in accordance with 

either of the following: §761.50(b)(3)(ii) 

- In accordance with the PCB Spill Cleanup 

Policy (Policy) at subpart G of this part, for 

those PCB remediation wastes that meet 

the criteria of the Policy. 

PCB Inspection Manual 5-39 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Applicability 

The owner or operator of a site containing PCB Inspector should ask owner/operator if 

remediation waste has the burden of proving the any PCB remediation waste is at the 

date that the waste was placed in a land disposal site or removed from the site. If so, 

facility, spilled, or otherwise released into the ask for records that show the date 

environment, and the concentration of the original waste was removed and that show it 

spill. §761.50(b)(3)(iii) was disposed of. 

Any person disposing of PCB bulk product waste 

must do so in accordance with §761.62. PCB bulk 

product waste is waste that was $50 ppm when 

originally removed from service, even if its current 

PCB concentration is <50 ppm. PCB bulk product 

waste is regulated for disposal based on the risk 

from the waste once disposed. Land disposed 

waste is regulated based on how readily the waste 

is released from disposal to the environment, in 

particular by leaching out from the land disposal 

unit. §761.50(b)(4)(i) 

Any person disposing of metal surfaces in contact 

with PCBs (e.g., painted metal) may use thermal 

decontamination procedures in accordance with 

§761.79(c)(6) [see §761.62(a)(6)]. 

§761.50(b)(4)(ii) 

Any person storing or disposing of PCB Household 

Waste must do so in accordance with §761.63. 

§761.50(b)(5) 

Any person disposing of PCB wastes generated 

during and as a result of research and development 

for use under §761.30(j), or for disposal under 

§761.60(j), must do so in accordance with 

§761.64. §761.50(b)(6) 

Any person storing or disposing PCB/radioactive 

waste $50 ppm PCBs must do so taking into 

account both its PCB concentration and its 

radioactive properties, except as provided in 

§761.65(a)(1), (b)(1)(ii), and (c)(6)(i). §761.50(b)(7) 

August 2004 5-40 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Applicability 

In most cases a person must dispose of porous 

surfaces as materials where PCBs have 

penetrated far beneath the surface, rather than a 

simple surface contamination. §761.50(b)(8) 

• Any person disposing of porous surfaces on 

which PCBs have been spilled and meeting the 

definition of PCB remediation waste at §761.3 

must do so in accordance with §761.61. 

• Any person disposing of porous surfaces 

which are part of manufactured non-liquid 

products containing PCBs and meeting the 

definition of PCB bulk product waste at §761.3 

must do so in accordance with §761.62. 

• Any person may decontaminate concrete 

surfaces upon which PCBs have been spilled in 

accordance with §761.79(b)(4), if the 

decontamination procedure is commenced 

within 72 hours of the initial spill of PCBs to the 

concrete or portion thereof being 

decontaminated. 

• Any person may decontaminate porous 

non-liquid PCBs in contact with non-porous 

surfaces, such as underground metal fuel tanks 

coated with fire retardant resin or pitch, for 

purposes of unrestricted use or disposal in a 

smelter in accordance with §761.79(b)(3). 

Any person who holds PCB waste must store it in 

accordance with §761.65. §761.50(c) 

Performance specifications for disposal Verify that the disposal facilities meet 

technologies: the necessary criteria by reviewing 

• Any person using an incinerator to dispose of records that the incinerator meets 

PCBs must use an incinerator that meets the criteria specified in the regulations as 

criteria in §761.70. §761.50(d)(1) stated in Appendix I of this manual. 

• Any person using a high efficiency boiler to 

dispose of PCBs must use a boiler that meets 

the criteria in §761.71. §761.50(d)(2) 

• Any person using scrap metal recovery ovens 

and smelters to dispose of PCBs must use a 

device that meets the criteria in §761.72. Verify facility has appropriate TSCA 

§761.50(d)(3) Coordinated Approval documentation, 

• Any person using a chemical waste landfill to if applicable. Documentation may 

dispose of PCBs must use a chemical waste include the application, any notice of 

landfill that meets the criteria in §761.73. deficiencies, and final approval by 

§761.50(d)(4) EPA. 

PCB Inspection Manual 5-41 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.4.2 Disposal Requirements 

Regulation Reference: §761.60 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

Persons must dispose of PCB liquids at 

concentrations $50 ppm in an incinerator that 

complies with §761.70. §761.60(a) 

• Persons may dispose of mineral oil dielectric 

fluid with a PCB concentration of $50 ppm and 

<500 ppm in a high efficiency boiler according 

to §761.71(a) 

NOTE: Owners or users of mineral oil dielectric 

fluid electrical equipment may use the procedures 

in §761.60(g) to determine the concentration of 

PCBs in the dielectric fluid. 

• Persons may dispose of liquids, other than 

mineral oil dielectric fluid, containing a PCB 

concentration of $50 ppm and <500 ppm in a 

high efficiency boiler according to §761.71(b). 

• Persons may dispose of liquids from incidental 

sources, such as precipitation, condensation, 

leachate or load separation and are associated 

with PCB Articles or non-liquid PCB wastes in a 

chemical waste landfill that complies with 

§761.75 if information is provided to the owner 

or operator of the landfill that shows that the 

liquids are <500 ppm and are not an ignitable 

waste per §761.75(b)(8)(iii). 

Persons may dispose of PCB Transformers in 

accordance with either of the following: 

§761.60(b)(1) 

• An incinerator that complies with §761.70 

• A chemical waste landfill that complies with 

§761.75, provided that the requirements of 

§761.60(b)(1)(i)(B) are met. 

Review records to ensure compliance 

with all applicable requirements (e.g., 

concentration of mineral oil dielectric 

fluid is between $50 & <500 ppm at 

the time of disposal). 

Review records and verify that liquids 

containing a PCB concentration of 

$50 ppm and <500 ppm, other than 

mineral oil dielectric fluid, are 

disposed in compliance with all 

applicable requirements. 

Review records and verify that PCB 

Transformers are disposed in 

compliance with all applicable 

requirements. 

August 2004 5-42 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

Any person may dispose of PCB Small Capacitors 

as municipal solid waste, unless that person is or 

was a PCB Capacitor manufacturer. The owner or 

any PCB Large High- or Low- Voltage Capacitor 

that contains $500 ppm PCBs must dispose of the 

capacitor in an incinerator that complies with 

§761.70. Any person who manufactures or at any 

time manufactured PCB Capacitors or PCB 

Equipment and acquired the PCB Capacitors in the 

course of such manufacturing must place PCB 

small capacitors in a container meeting DOT 

requirements and dispose of them in an incinerator 

that complies with §761.70. EPA may by notice 

allow disposal of the above items in a chemical 

waste landfill compliant with §761.75. 

§761.60(b)(2) 

Any person disposing of PCB hydraulic machines 

that contain concentrations of $50 ppm PCBs 

(such as die casting machines) must drain the 

machines of all free-flowing liquid and disposed of 

the liquid in an incinerator that complies with 

§761.70. If the PCB liquid contains $1000 ppm 

PCBs, the person must decontaminate the 

machine in accordance with §761.79 or flush the 

machine prior to disposal with a solvent containing 

<50 ppm PCB and disposed of in accordance with 

§761.60(a) or §761.79. §761.60(b)(3) 

The drained PCB hydraulic machines may be 

disposed of: 

• at a properly approved solid waste facility 

• in accordance with the decontamination 

procedures at §761.79 

• in a scrap metal recovery oven or smelter 

operating in compliance with §761.72 

• in an approved disposal facility. 

Verify that all PCB Capacitors are 

disposed of in compliance with all 

applicable requirements by reviewing 

records. Conduct a physical 

inspection of what is stored for 

disposal or its records. Small 

capacitors contain less than 1.36 kg 

(3 lbs.) of dielectric fluid. If the actual 

weight is unknown, the inspector can 

assume that a capacitor whose total 

volume is less than 1,639 cm3

 (100 

in3

) meets the definition of a small 

capacitor. If the capacitor weighs less 

than 4.08 kg (9 lbs.), the inspector can 

assume that a capacitor whose total 

volume is between 1,639 and 3,278 

cm3

 meets the definition of a small 

capacitor. 

Verify that PCB hydraulic machines 

are disposed of in compliance with all 

applicable requirements by reviewing 

records. 

PCB Inspection Manual 5-43 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

Any person disposing of PCB-Contaminated 

Electrical Equipment (except capacitors) must 

drain all free-flowing liquid from the electrical 

equipment and dispose of the liquid in an 

incinerator or high efficiency boiler. Persons must 

dispose of the drained equipment and keep records 

for four years: 

• at a properly approved solid waste facility 

• in accordance with the decontamination 

procedures at §761.79 

• in a scrap metal recovery oven or smelter 

operating in compliance with §761.72. 

• in an approved disposal facility. 

Any person disposing of large capacitors with $50 

and <500 ppm PCBs must do so in an approved 

disposal facility and keep records for four years. 

§761.60(b)(4) 

The owner or operator of natural gas pipeline 

systems containing $50 ppm PCBs, when no 

longer in use, shall dispose of the system either by 

abandonment in place of the pipe under paragraph 

§761.60(b)(5)(i) or removal under paragraph 

§761.60(b)(5)(ii). Any person determining the PCB 

concentrations in natural gas pipeline systems 

shall do so in accordance with paragraph 

§761.60(b)(5)(iii). §761.60(b)(5) 

• Any person disposing of liquids containing 

PCBs $50 ppm removed, spilled, or otherwise 

released from a natural gas pipeline system 

must do so in accordance with 

§761.61(a)(5)(iv) based on the PCB 

concentration at the time of removal from the 

system. 

• Any person disposing of material contaminated 

by spills or other releases of PCBs $50 ppm 

from a natural gas pipeline system, must do so 

in accordance with §761.61 or §761.79, as 

applicable. 

Verify that PCB-Contaminated 

Electrical Equipment is disposed of in 

compliance with all applicable 

requirements by reviewing records. 

August 2004 5-44 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

• Any person who burns for energy recovery 

liquid containing PCBs at concentrations <50 

ppm PCBs at the time of removal from a 

natural gas pipeline system must do so in 

accordance with the provisions pertaining to 

used oil at §761.20(e). 

• No other use of liquid containing PCBs at 

concentrations above the quantifiable level of 

detection removed from a natural gas pipeline 

system is authorized. 

Any person must dispose of PCB Articles with 

concentrations at $500 ppm PCBs in an incinerator 

that complies with §761.70 or a chemical waste 

landfill that complies with §761.75, provided that all 

free-flowing liquid PCBs have been thoroughly 

drained from any articles before the articles are 

placed in the landfill and the drained liquids are 

disposed of in an incinerator that complies with 

§761.70. §761.60(b)(6)(i) 

Any person disposing of a PCB-contaminated 

article must remove all free-flowing liquid from the 

article and dispose of the liquid in accordance with 

§761.60(a). The drained article must be disposed 

of: §761.60(b)(6)(ii) 

• at a properly approved solid waste facility 

• in accordance with the decontamination 

procedures at §761.79 

• in a scrap metal recovery oven or smelter 

operating in compliance with §761.72. 

• in an approved disposal facility. 

Persons disposing of fluorescent light ballasts 

containing PCBs in their potting material must 

dispose of them in a TSCA-approved disposal 

facility, as bulk product waste under §761.62, as 

household waste under §761.63 (where 

applicable), or in accordance with the 

decontamination provisions of §761.79. 

§761.60(b)(6)(iii) 

Check facility records, including old 

records, new relevant records, and 

test results, to determine compliance. 

Verify that PCB Articles, such as 

capacitors, transformers, electric 

motors, pumps, and others, are 

disposed of in compliance with all 

applicable requirements by reviewing 

the facility’s records and procedures 

and the disposal facility’s records and 

procedures. 

Review disposal records such as 

manifests to verify that fluorescent 

light ballasts containing PCBs are 

disposed of in a TSCA-approved 

disposal facility, as bulk product waste 

under §761.62, as household waste 

under §761.63 (where applicable), or 

in accordance with the 

decontamination provisions of 

§761.79. NOTE: Procedures for 

inspecting ballast disposers and 

recyclers are discussed in Appendix 

L. 

PCB Inspection Manual 5-45 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

Persons disposing of PCB Articles must wear or 

use protective clothing or equipment to protect 

against dermal contact with or inhalation of PCBs 

or materials containing PCBs. §761.60(b)(8) 

Any person disposing of PCB Containers with a 

concentration of $500 ppm PCBs, unless 

decontaminated in accordance with §761.60(c)(2) 

or §761.79, must dispose of them in an incinerator 

that complies with §761.70, or a chemical waste 

landfill that complies with §761.75, provided that the 

PCB Container is first drained and the PCB liquid 

disposed of in accordance with §761.60(a). Any 

container used to contain only PCBs at a 

concentration of <500 ppm can be disposed of as 

municipal solid waste, provided that the PCB 

Container is first drained and the PCB liquid 

disposed of in accordance with §761.60(a). 

§761.60(c) 

Any person who is required to incinerate any PCBs 

and PCB Items may apply to EPA for a waiver if 

that person can demonstrate that an alternative 

method of destroying PCBs and PCB Items exists. 

The person must not use the alternative method 

until obtaining approval of the waiver. §761.60(e) 

Persons must dispose of PCBs resulting from 

spills and other uncontrolled discharges at 

concentrations of 50 ppm or greater in accordance 

with §761.60(a). 

Inspect the protective clothing or 

equipment to verify that the facility has 

appropriate protective gear. Observe 

if disposal is occurring. 

Verify that PCB containers are 

disposed of in compliance with all 

applicable requirements by reviewing 

records. Interview facility officials and 

see what their disposal procedures 

are. 

Verify that any alternative methods in 

use were approved by EPA by 

reviewing the required paperwork. 

Verify that PCBs resulting from spills 

and other uncontrolled discharges in 

concentrations of 50 ppm or greater 

are disposed of in accordance with 

§761.60(a) by reviewing disposal 

records. 

August 2004 5-46 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

Any person may conduct research and 

development for PCB disposal without prior written 

approval from EPA if they: §761.60(j)(1) 

• file a notification and obtain an EPA 

identification number. §761.60(j)(1)(i) 

• notify the EPA RA, the state environmental 

protection agency, and local environmental 

protection agency, having jurisdiction where the 

R&D for PCB disposal activity will occur in 

writing at least 30 days prior to the 

commencement of any R&D for PCB disposal 

activity. §761.60(j)(1)(ii) 

• do not treat more than 500 gal or 70 ft3

 of liquid 

or non-liquid PCBs or maximum concentration 

of 10,000 ppm PCBs annually. §761.60(j)(1)(iii) 

• dispose of no more than 1 kg total of pure 

PCBs per year in all R&D for PCB disposal 

activities at the facility. §761.60(j)(1)(iv) 

• conduct each R&D for PCB disposal activity for 

no more than 1 calendar year. §761.60(j)(1)(v) 

• store all PCB wastes (treated and untreated 

PCB materials, testing samples, spent 

laboratory samples, residuals, untreated 

samples, contaminated media or 

instrumentation, clothing, etc.) in compliance 

with §761.65(b) and disposes of them 

according to the undiluted PCB concentration 

prior to treatment. §761.60(j)(1)(vi) 

• use manifests for all R&D PCB wastes being 

transported from the R&D facility to an 

approved PCB storage or disposal facility. 

However, §761.207 through §761.218 do not 

apply if the residuals or treated samples are 

returned either to the physical location where 

the samples were collected or a location where 

other regulated PCBs from the physical location 

where the samples were collected are being 

stored for disposal. §761.60(j)(1)(vii) 

• package and ship all PCB wastes according to 

DOT requirements under 49 CFR 171 through 

180. §761.60(j)(1)(viii) 

• comply with the recordkeeping requirements of 

§761.180. §761.60(j)(1)(ix) 

Verify that the conditions are met if 

conducting R&D for PCB disposal 

without prior written approval from 

EPA. 

Verify that each written notification 

includes the EPA identification 

number, the quantity of PCBs to be 

treated, the type of R&D technology to 

be used, the general physical and 

chemical properties of material being 

treated, and an estimate of the 

duration of the PCB activity. Note 

records may be checked at EPA prior 

to the inspection. 

Verify that material limitations (500 

gallons/70ft3

 of liquid or non-liquid 

PCB or maximum concentration of 

10,000 ppm PCB) and time limitations 

(one year) are not exceeded without 

prior written approval from EPA. 

PCB Inspection Manual 5-47 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Disposal Requirements 

Portions of samples of a size designated in a 

chemical extraction and analysis method for PCBs 

and extracted for purposes of determining the 

presence of PCBs or concentration of PCBs are 

unregulated for PCB disposal. §761.64(a) 

All other wastes generated during these activities 

are regulated for disposal based on their 

concentration at the time of disposal as follows: 

§761.64(b) 

• Liquid wastes, including rinse solvents, must be 

disposed of according to §761.61(a)(5)(iv). 

• Non-liquid wastes must be disposed of in the 

same manner as non-liquid cleaning materials 

and personal protective equipment waste 

according to §761.61(a)(5)(v)(A). 

August 2004 5-48 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.4.3 PCB Remediation Waste 

Regulation Reference: §761.61 

(NOTE: The PCB Spill Cleanup Policy found at Regulation Reference §761.125 (page 4-83) is intended 

for spills less than 72 hours old. Any spills older than 72 hours must be cleaned up as PCB remediation 

waste. There are three options for disposal/cleanup of PCB remediation waste: self implementing, 

performance-based standards, and risk-based cleanup.) 

Regulatory Requirements Inspection Procedures 

PCB Remediation Waste 

Self Implementing Cleanup Policy 

Persons should use self-implementing onsite 

cleanup and disposal of PCB remediation waste 

only for a general, moderately-sized site where 

there should be low residual environmental impact 

from remedial activities. Persons may not use the 

self-implementing procedures to cleanup the 

following: §761.61(a)(1) 

• surface or ground waters 

• sediments in marine and freshwater ecosystems 

• sewers or sewage treatment systems 

• any private or public drinking water sources or 

distribution systems 

• grazing lands 

• vegetable gardens. 

The self-implementing cleanup notice includes: 

§761.61(a)(3)(i) 

• the nature of the contamination, including kinds 

of materials contaminated 

• a summary of the procedures used to sample 

contaminated and adjacent areas and a table or 

cleanup site map showing PCB concentrations 

measured in all pre-cleanup characterization 

samples 

• the location and extent of the identified 

contaminated area, including topographic maps 

with sample collection sites cross referenced to 

the sample identification numbers in the data 

summary 

• a cleanup plan for the site, including schedule, 

disposal technology, and approach 

Verify that the site is adequately 

characterized to be able to provide the 

required notification information. 

Verify that at least 30 days prior to the 

date that the self-implementing 

cleanup of a site begins, the person in 

charge of the cleanup or the owner of 

the property where the PCB 

remediation waste is located notifies, 

in writing, the EPA Regional 

Administrator, the director of the state 

or tribal environmental protection 

agency, and the director of the county 

or local government where the 

cleanup will be conducted. 

PCB Inspection Manual 5-49 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCB Remediation Waste 

• a written certification, signed by the owner of 

the property where the cleanup site is located 

and the party conducting the cleanup, that all 

sampling plans, sample collection procedures, 

sample preparation procedures, extraction 

procedures, and instrumental/chemical 

analysis procedures used to assess or 

characterize the PCB contamination at the 

cleanup site, are on file at the location 

designated in the certificate, and are available 

for EPA inspection 

• when applicable, a statement that alternate 

methods for chemical extraction and chemical 

analysis for site characterization will be used 

and that a comparison study which meets or 

exceeds the requirements of Subpart Q of 

§761, and for which records are on file, has 

been completed prior to verification sampling. 

The EPA RA will respond in writing approving the 

self-implementing cleanup, disapproving the selfimplementing cleanup, or requiring additional 

information. If the EPA RA does not respond within 

30 days of receiving the notice, the person 

submitting the notice may assume that it is 

acceptable and proceed with the cleanup according 

to the information provided to EPA. 

§761.61(a)(3)(ii) 

Any person conducting a cleanup activity may 

obtain a waiver of the 30-day notification 

requirement, if they receive a separate waiver, in 

writing, from each of the agencies they are required 

to notify. The person must retain the original 

written waiver. §761.61(a)(3)(iii) 

Verify that once the self-implementing 

cleanup is underway, the person 

conducting the cleanup provides any 

proposed changes from the 

notification to the EPA RA in writing no 

less than 14 calendar days prior to the 

implementation of the change. 

Review records to verify that the 

cleanup was done in accordance with 

the notice provided to EPA. If any 

changes were made, verify that the 

EPA Regional Administrator was 

notified no less than 14 days prior to 

the implementation of the proposed 

change. 

Review the original written waiver, if 

applicable. 

August 2004 5-50 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCB Remediation Waste 

Responsible party must collect and analyze 

samples to verify the cleanup and onsite disposal 

of PCB waste according to specific parameters. 

§761.61(a)(6)(i) 

Where sample analysis results in a measurement 

of PCBs less than or equal to the levels specified in 

§761.61(a)(4), self-implementing cleanup is 

complete. Otherwise, the owner or operator of the 

site must either dispose of the sampled PCB 

remediation waste, or reclean the waste 

represented by the sample and reinitiate sampling 

and analysis. §761.61(a)(6)(ii) 

Verify that any person collecting and 

analyzing samples to verify the 

cleanup and onsite disposal of bulk 

PCB remediation wastes and porous 

surfaces do so in accordance with 

Subpart O of §761. Sampling by the 

responsibly party according to 

Subpart O must precede the 

beginning of cleanup for selfimplementing cleanup to be a viable 

option. 

Verify that any person collecting and 

analyzing samples from non-porous 

surfaces does so in accordance with 

§761, Subpart P. 

Verify that any person collecting and 

analyzing samples from liquids does 

so in accordance with §761.269. 

PCB Inspection Manual 5-51 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCB Remediation Waste 

Caps for PCB cleanup sites must meet specific 

requirements. When referring to onsite cleanup 

and disposal of PCB remediation waste, a cap 

means a uniform placement of concrete, asphalt, 

or similar material of minimum thickness spread 

over the area where remediation waste was 

removed or left in place in order to prevent or 

minimize human exposure, infiltration of water, and 

erosion. §761.61(a)(7) 

Verify that any cap is designed and 

constructed in accordance with 

§264.310(a), and complies with the 

permeability, sieve, liquid limit, and 

plasticity index parameters in 

§761.75(b)(1)(ii) through (b)(1)(v). 

Verify that there is a cap of 

compacted soil with a minimum 

thickness of 25 cm (10 in). 

Verify that a concrete or asphalt cap 

has a minimum thickness of 15 cm (6 

in). 

Verify that the cap integrity is sufficient 

to maintain its effectiveness during the 

use of the cap surface which is 

exposed to the environment. 

Verify that a cap is not contaminated 

at a level $1 ppm PCB per Aroclor (or 

equivalent) or per congener before 

use by sampling or reviewing testing 

data. 

Visually inspect for breaches and 

determine if repair began within 72 

hours of discovery. 

Verify that, when there is a fence or 

cap, the fence or cap is maintained. 

August 2004 5-52 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCB Remediation Waste 

When a cleanup activity conducted under this 

section includes the use of a fence or a cap, the 

owner of the site must maintain the fence or cap, in 

perpetuity. In addition, whenever a cap, or the 

procedures and requirements for a low occupancy 

area, is used, the owner of the site must record a 

notice on the deed. 

The owner of the site may remove a fence or cap 

after conducting additional cleanup activities and 

achieving cleanup levels (§761.125) that do not 

require a cap or fence. The owner may remove the 

notice on the deed no earlier than 30 days after 

achieving the cleanup levels that do not require a 

fence or cap. § 761.61(a)(8) 

Performance Based Standards 

Any person disposing of liquid PCB remediation 

waste shall do so according to §761.60(a) or (e), or 

decontaminate it in accordance with §761.79. 

§761.61(b)(1) 

Any person disposing of non-liquid PCB 

remediation waste shall do so by one of the 

following methods: 

• Dispose of it in a high temperature incinerator 

approved under §761.70(b), an alternate 

disposal method approved under §761.60(e), a 

chemical waste landfill approved under 

§761.75, or in a facility with a coordinated 

approval issued under §761.77. 

• Decontaminate it in accordance with §761.79. 

§761.61(b)(2) 

Verify that the owner 1) recorded a 

notation on the deed to the property, 

or on some other document which is 

normally examined during a title 

search, and 2) submitted a signed 

certification that they recorded the 

notation to the EPA RA within 60 days 

of completion of a cleanup activity. 

The notation will in perpetuity notify 

any potential purchaser of the 

property: 

- That the land has been used 

for PCB remediation waste 

disposal and is restricted to 

use as a low occupancy area 

as defined in §761.3. 

- Of the existence of the fence 

or cap and the requirement to 

maintain the fence or cap. 

- The applicable PCB levels left 

at the site, inside the fence, 

and/or under the cap. 

Verify that the fence or cap is 

maintained. 

PCB Inspection Manual 5-53 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCB Remediation Waste 

Any person may manage or dispose of material 

containing < 50 ppm PCBs that has been dredged 

or excavated from waters of the United States: 

§761.61(b)(3) 

• in accordance with a permit that has been 

issued under Section 404 of the Clean Water 

Act, or the equivalent of such a permit as 

provided for in regulations of the U.S. Army 

Corps of Engineers at 33 CFR 320 

• in accordance with a permit issued by the U.S. 

Army Corps of Engineers under section 103 of 

the Marine Protection, Research, and 

Sanctuaries Act, or the equivalent of such a 

permit as provided for in regulations of the U.S. 

Army Corps of Engineers at 33 CFR 320. 

Risk-Based Cleanup Provisions 

Any person wishing to sample, cleanup, or dispose 

of PCB remediation waste in a manner other than 

prescribed in the self implementing cleanup policy 

or performance based standards, or store PCB 

remediation waste in a manner other than 

prescribed in §761.65, must apply in writing to the 

appropriate EPA RA or to the Director of the 

National Program Chemicals Division. Each 

application must contain information described in 

the notification required by §761.61(a)(3). No 

person may conduct cleanup activities under 

this paragraph prior to obtaining written approval by 

EPA. §761.61(c)(1) 

Identify whether facility has 

appropriate permits and is operating in 

accordance with the permit. 

Some facilities applied for and 

received EPA approvals for the 

remediation of PCBs. The inspector 

should check for such EPA approvals 

prior to the inspection and should 

consult with the permit writer or the 

person responsible for the permit to 

determine if any critical areas of the 

facility need to be inspected or do not 

need to be inspected. 

August 2004 5-54 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.4.4 Disposal of PCB Bulk Product Waste 

Regulation Reference: §761.62 

Regulatory Requirements Inspection Procedures 

Disposal of PCB Bulk Product Waste 

Performance-based disposal of PCB bulk product 

waste must be in accordance with specific 

parameters. §§761.50(b)(4), 761.62(a) and 

761.62(c) 

Persons may dispose of PCB bulk product waste: 

§761.62(a) 

• in an incinerator approved under §761.70 

• in a chemical waste landfill approved under 

§761.75 

• in a permitted hazardous waste landfill 

• under an alternate disposal method approved 

under §761.60(e) 

• in accordance with the decontamination 

provisions of §761.79 

• for metal surfaces in contact with PCBs, in 

accordance with the thermal decontamination 

provisions of §761.79(c)(6) 

• in accordance with a TSCA PCB Coordinated 

Approval issued under §761.77 

• as daily landfill cover as long as the daily cover 

remains in the landfill and is not released or 

dispersed by wind or other action or under 

asphalt as part of a road bed. 

Disposal of PCB bulk product waste in solid waste 

landfills must be in accordance with specific 

parameters (§761.62(b) through 761.62(d)). 

Check disposal records to determine 

where and how materials were 

disposed. 

When PCB bulk product waste is 

disposed of in a solid waste landfill, 

verify that the landfill is permitted, 

licensed, or registered by a state as a 

municipal or non-municipal nonhazardous waste landfill. 

For any disposal of PCB bulk product 

waste, verify that a written record is 

maintained of all sampling and 

analysis of PCBs or notifications 

made for 3 years from the date of the 

waste’s generation. 

PCB Inspection Manual 5-55 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Disposal of PCB Bulk Product Waste 

Any person may dispose of the following PCB bulk 

product waste in a facility permitted, licensed, or 

registered by a state as a municipal or nonmunicipal non-hazardous waste landfill: §761.62(b) 

• plastics (such as plastic insulation from wire or 

cable; radio, television, and computer casings; 

vehicle parts; or furniture laminates); preformed or molded rubber parts and 

components; applied dried paints, varnishes, 

waxes or other similar coatings or sealants; 

caulking; Galbestos; non-liquid building 

demolition debris; or non-liquid PCB bulk 

product waste from the shredding of 

automobiles or household appliances from 

which PCB small capacitors have been 

removed (shredder fluff) 

• other sampled PCB bulk product waste that 

leaches PCBs at <10 μg/L of water measured 

using a procedure used to simulate leachate 

generation. 

Any release of PCBs (including but not limited to 

leachate) from the landfill unit must be cleaned up 

in accordance with §761.61. §761.62(c) 

Bulk product waste as described in the above 

NOTE statement may be disposed of as daily 

landfill cover as long as the daily cover remains in 

the landfill and is not released or dispersed by wind 

or other action or under asphalt as part of a road 

bed.) 

Any person disposing off-site of PCB bulk product 

waste regulated under §761.62(b)(1) or (2) at a 

waste management facility not having a 

commercial PCB storage or disposal approval 

must provide written notice to the facility a 

minimum of 15 days in advance of the first 

shipment from the same disposal waste stream 

and, for disposal in solid waste landfills, with each 

shipment thereafter. §761.62(b)(4) 

Verify that, if materials other than 

those listed under regulatory 

requirements are disposed of in a 

facility that is permitted, licensed, or 

registered by a state to manage 

municipal solid waste or nonmunicipal 

nonhazardous waste, the following 

are met: 

• the PCB bulk product waste is 

segregated from organic liquids 

disposed of in the landfill unit 

• leachate is collected from the 

landfill unit and monitored for 

PCBs. 

If PCB release is suspected, sample. 

Verify that the written notice states 

that the PCB bulk product waste may 

include components containing PCBs 

at $ 50 ppm based on analysis of the 

waste in the shipment or application of 

a general knowledge of the waste 

stream (or similar material) which is 

known to contain PCBs at those 

levels, and that the PCB bulk product 

waste is known or presumed to leach 

$ 10 μg/L PCBs. 

August 2004 5-56 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Disposal of PCB Bulk Product Waste 

Any person sampling or disposing of PCB bulk 

product waste in a manner other than prescribed in 

§761.62(a) or (b), or storing PCB bulk product 

waste in a manner other than prescribed in 

§761.65, must apply in writing to the EPA and 

receive written approval. §761.62(c) 

Any person may dispose of bulk product waste 

described in §761.62(b)(1) provided EPA RA 

approves: 

• as daily landfill cover as long as the cover 

remains in the landfill and is not released or 

dispersed by wind or other actions 

• under asphalt as part of a road bed. 

Verify that, if bulk product waste is 

disposed of in a manner other than 

prescribed in §761.62(a) or 761.62(b), 

the EPA RA (if the disposal site is 

located in a single EPA Region) or the 

Director of the National Program 

Chemicals Division (if disposal is 

occurring in more than one EPA 

Region) received and approved the 

application. Inspector can check PCB 

website for a list of approved facilities: 

www.epa.gov/pcb/stordisp.html 

PCB Inspection Manual 5-57 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.4.5 Storage for Disposal 

Regulation Reference: §761.65 

(NOTE: This section applies to the storage for disposal of PCBs at concentrations $50 ppm and PCB 

Items with concentrations of $50 ppm.) 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

No one may store PCB waste for more than one 

year from the date they determined it to be waste 

and decided to dispose of it. §761.65(a)(1) 

To obtain an automatic one-year extension, the 

person storing PCB waste for disposal may notify 

the EPA Region that efforts to secure disposal 

were unsuccessful. §761.65(a)(2) 

EPA may grant additional extensions beyond the 

one-year extension. EPA may also grant extended 

storage time as part of a PCB storage or disposal 

approval. §§761.65(a)(3) and (4) 

Storage areas where PCBs and PCB Items are 

stored for disposal must be marked with mark ML. 

§761.65(c)(1) 

Roofs and walls of storage facilities must be 

adequate to prevent rain water from reaching PCBs 

and PCB Items. §761.65(b)(1)(i) 

Check storage records to verify that 

no containers stored for disposal have 

been in storage for more than nine 

months (The one-year disposal time 

includes 90 days for the disposal 

facility to conduct the disposal, so the 

generator’s effective storage time is 

nine months.) NOTE: This is a policy 

requirement. 

If PCB wastes have been stored for 

more than one year, verify with 

National Program Chemical Division 

that the facility sent a complete notice 

for the one-year automatic extension 

or received another extension from 

EPA. NOTE: The one year starts 

when PCB waste is first placed into 

the container or when PCB Items 

were removed from service for 

disposal. 

Before entering a storage area, allow 

the storage area to ventilate 

sufficiently. Inspect storage area for 

proper markings. Photograph and 

note location of unmarked or 

improperly marked storage areas. 

Inspect roof and walls for evidence of 

leakage. Provide exact location of 

leaks by measurement from floor, 

wall, or ceiling. Photograph when 

possible, and draw a scale floor plan 

noting objects water might contact. 

Note drainage path of water (run-on 

and runoff) around the storage 

building. 

August 2004 5-58 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

Floors must have at least a 6" continuous curb 

creating a containment area (PCB radioactive 

wastes are exempt). The containment area must 

not have any drains, valves, expansion joints, 

sewer lines, or other openings that would permit 

liquids to flow from the curbed area. The floor and 

curbing must provide a containment volume equal 

to the greatest of: §§761.65(b)(1)(ii) and (iii) 

• at least twice the internal volume of the largest 

PCB Article or Container stored 

• or 25 percent of the total internal volume of all 

PCB Articles or Containers stored. 

Floors and curbing must be constructed of Portland 

cement, concrete, or continuous, smooth, and nonporous materials, to prevent or minimize 

penetration of PCBs. §761.65(b)(1)(iv) 

The facility’s PCB storage area must be located 

above the 100- year flood elevation. 

§761.65(b)(1)(v) 

Visually inspect floor for openings that 

would permit liquids to flow from the 

curbed area. Estimate volume of all 

stored articles or containers through 

records or by actual measurement. 

Take special note of largest container 

or article and take photographs. 

Measure surface dimensions and 

curbing height to determine volume of 

containment area. Compare the 

above to determine adequacy of 

containment area. Check to ensure 

that all items are stored far enough 

away from dike to prevent potential 

leaks from escaping over the dike. If a 

discrepancy is found, verify all 

measurements, and record in field 

notebook. Photocopy records 

describing volume of containers or 

articles if available. NOTE: When 

estimating the volume of storage 

remember to account for the footprint 

of drums, tanks, pallets, etc. which 

reduce the volume. 

Inspect containment area for any 

openings, including cracks, floor 

drains, and pipe conduits. Review 

construction records including piping 

and sewer blueprints. If openings are 

found, verify exact location and 

determine drainage path and ultimate 

disposal. Note exact location of any 

openings relative to a stationary 

object. Photograph or provide scale 

floor plan. Review blueprints showing 

openings. 

Prior to the inspection, determine the 

100-year flood elevation from U.S. 

Geological Survey or U.S. Army Corps 

of Engineers records. During the 

inspection, determine the elevation of 

facility from facility records. 

PCB Inspection Manual 5-59 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

PCBs and PCB Items designated for disposal 

must be stored in a storage unit approved by EPA 

pursuant to §761.65(d) or meeting the design 

requirements of §761.65(b), unless the unit meets 

one of the following conditions: §761.65(b)(2) 

• The unit is permitted by EPA under section 

3004 of RCRA to manage hazardous waste in 

containers, and PCB spills are cleaned up in 

accordance with §761 subpart G. 

• The unit qualifies for interim status under 

section 3005 of RCRA to manage hazardous 

waste in containers, meets the requirements 

for containment at Sec. 264.175 of this chapter, 

and PCB spills are cleaned up in accordance 

with §761 subpart G. 

• The unit holds a permit from a State authorized 

under section 3006 of RCRA to manage 

hazardous waste in containers, and PCB spills 

are cleaned up in accordance with §761 

subpart G. 

• The unit is approved or otherwise regulated 

pursuant to a State PCB waste management 

program no less stringent in protection of health 

or the environment than the applicable TSCA 

requirements found in this part. 

• The unit is subject to a TSCA Coordinated 

Approval, which includes provisions for storage 

of PCBs, issued pursuant to §761.77. 

• The unit has a TSCA PCB waste management 

approval, which includes provisions for storage, 

issued pursuant to §761.61(c) or §761.62(c). 

Check with the National Chemical 

Program Division if unit is approved. If 

the storage unit has not been 

approved or does not meet the above 

design requirements, determine if it 

meets one of the conditions for 

exemption by reviewing records. 

Review the TSCA Coordinated 

Approval for storage conditions. 

Facilities must keep a copy of the 

approval, so inspectors can review 

the facility copy. 

August 2004 5-60 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

Persons may store the following PCB Items in an 

area that does not comply with §761.65(b) for up to 

30 days from the date the item was removed from 

service, provided that they attach a notation to the 

PCB Item indicating the date the item was removed 

from service: §761.61(c)(1) 

• Non-leaking PCB Articles and PCB Equipment 

• Leaking PCB Articles and PCB Equipment if the 

PCB Items are placed in a non-leaking PCB 

Container that contains sufficient sorbent 

material to absorb any liquid PCBs remaining in 

the PCB Items. 

• PCB Containers containing non-liquid PCBs 

(e.g., contaminated soil, rags, and debris) 

• PCB Containers containing liquid PCBs at 

concentrations > 50 ppm, provided a Spill 

Prevention Control and Countermeasure 

(SPCC) Plan has been prepared for the 

temporary storage area and the liquid PCB 

waste is in packaging authorized in the 

Department of Transportation (DOT) 

Hazardous Materials Regulations (HMR) at 49 

CFR Parts 171 through 180 or stationary bulk 

storage tanks. 

Persons may store non-leaking, undrained, 

structurally undamaged PCB Large High Voltage 

Capacitors and PCB-Contaminated Electrical 

Equipment outside on pallets next to a storage 

facility meeting the general requirements described 

above. §761.65(c)(2) 

Verify that only items meeting the 

appropriate requirements are in 

temporary storage. Inspect all 

equipment or articles for leaks. 

Photograph and establish location of 

discrepant items. Describe leaks, 

number of containers, condition of 

equipment, drainage path, and 

ultimate disposition. Collect sample 

of leaked material. 

Check notation on each item in 

temporary storage to determine date 

item was removed from service. 

Compare with copies of records 

indicating date of removal from 

service. Note discrepancies. 

Verify that an SPCC Plan has been 

prepared for the temporary storage 

area in accordance with 40 CFR 112; 

obtain a copy of the plan, and review 

for compliance with 40 CFR 112. 

Check transformers and capacitors 

for structural integrity and evidence of 

leakage. Observe general condition of 

outside storage area. Sample, 

photograph suspected leaks. Verify 

that the owner or operator checks the 

capacitors and equipment for leaks 

weekly. 

PCB Inspection Manual 5-61 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

Persons may store capacitors and equipment 

outside only when there is immediately available 

space within the prescribed facility equal to 10% of 

the volume of all capacitors and equipment stored 

outside the facility. §761.65(c)(2) 

Persons temporarily storing capacitors and 

equipment outside must check them for leaks 

weekly. 

No one may remove moveable equipment that is 

used for handling PCBs and PCB Items in the 

storage units and comes in direct contact with 

PCBs unless it has been decontaminated as 

specified in §761.79. §761.65(c)(4) 

Owners/operators must check for leaks at least 

once every 30 days on all PCB Articles and PCB 

Containers in storage §761.65(c)(5) 

Owners/operators must transfer immediately to 

properly marked non-leaking containers any leaking 

PCB Articles and PCB Containers and their 

contents. Owners/operator must immediately 

cleanup and properly dispose of any spilled or 

leaked PCB-contaminated materials and residues. 

§761.65(c)(5) 

Determine the volume of PCB 

Capacitors and transformers stored 

outside. Calculate volume of unfilled 

stored space inside facility. Enter 

measurements and calculations in 

field notebook. Verify figures if 

discrepancy appears. NOTE: This 

requirement provides for immediate 

inside storage of leaking capacitors or 

equipment. When estimating volume 

of storage, remember to account for 

the footprint of drums, tanks, pallets, 

etc. which reduce the volume. 

Verify that personnel are conducting 

weekly inspections. Obtain records 

and/or statements. Note 

discrepancies. 

Visually inspect moveable equipment 

used within the storage facility area for 

proper decontamination; check 

decontamination procedures and 

verify use of these procedures. 

Obtain wipe samples from suspect 

equipment. 

Verify that regular inspection is carried 

out. Check for facility records of the 

inspections. 

Inspect articles, containers, and the 

general storage area for evidence of 

leakage. Determine whether leaking 

articles and containers have been 

placed in properly marked non-leaking 

containers. Note, describe, and 

establish location and photograph 

leaking articles and containers. 

Collect samples of suspected PCB 

spills. 

August 2004 5-62 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

PCB Containers must meet the shipping container 

specifications of the Hazardous Materials 

Regulations (HMR) at 49 CFR Parts 171 through 

180. §761.65(c)(6) 

Persons must package PCB waste not subject to 

HMR (under 20 ppm or less than 1 pound of waste) 

in accordance with Packaging Group III, unless 

other hazards require Groups I or II. §761.65(c)(6) 

Containers for PCB/radioactive waste need not 

meet HMR standards, but: 

• must not be leaking, 

• for non-liquid wastes, must be designed to 

prevent the buildup of liquids if in an area 

meeting §761.65(b)(1)(ii), 

• must meet all requirements for nuclear 

criticality safety. §761.65(c)(6)(i) 

A person may use the following containers for liquid 

PCBs for storage and transportation activities not 

subject to DOT regulation: §761.65(c)(6)(ii) 

• Specification 5 containers, without removal 

heads 

• Specification 5B containers, without removal 

heads 

• Specification 6D overpack with specifications 

2S or 2SL polyethylene containers 

• Specification 17E containers 

A person may use the following containers for nonliquid PCBs for storage and transportation activities 

not subject to DOT regulation: §761.65(c)(6)(ii) 

• Specification 5 containers, without removal 

heads 

• Specification 5B containers, without removal 

heads 

• Specification 17C containers 

The specifications include exemptions 

to the packaging requirements (49 

CFR 173.155); packaging 

requirements for non-bulk shipments 

(49 CFR 173.202); and packaging 

requirements for bulk shipments of 

liquid PCBs (49 CFR 173.241) and 

solid PCBs (49 CFR 173.240). 

Check specification numbers where 

available. When specification 

numbers are not present, compare to 

DOT specifications. (Use a caliper 

gauge to measure container 

thickness). Note and describe noncompliance with DOT regulations and 

notify DOT. 

Verify that containers used to hold 

nonliquid PCBs meet all applicable 

DOT specifications, or in the case of 

larger non-DOT specification 

containers, that containers provide 

adequate protection against leaking. 

PCB Inspection Manual 5-63 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

Larger liquid PCB Containers other than those 

specified above must be designed, constructed, 

and operated in compliance with Occupational 

Safety and Health Administration standards in 29 

CFR 1910.106. Prior to use, the above design 

must be reviewed to determine the structural safety 

for containing PCBs. §761.65(c)(7) 

Containers larger than those specified in DOT 

specifications 5, 5B, or 17C may be used for nonliquid PCBs 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 DOT specification containers, 

and are of the same relative strength and durability 

as specification DOT containers. 

Owners/operators of facilities using these 

containers must keep records indicating the 

quantity of PCBs and the date PCBs were added to 

or removed from these containers. Disposition of 

any PCBs removed must also be included. 

Persons storing PCB Articles and Containers must 

place the date of storage on the PCB Items when 

they are placed in storage and manage the storage 

area so that articles and containers can be located 

by the date they entered storage. §761.65(c)(8) 

Persons may store bulk PCB remediation waste or 

PCB bulk product waste at the clean-up site or site 

of generation for 180 days subject to the following 

conditions: §761.65(c)(9) 

• The waste pile is designed and operated to 

control wind dispersal, where necessary, by 

means other than wetting. 

Check specification numbers and 

compare to OSHA regulations. Note 

and describe non-compliance. Verify 

by records or by statements that 

safety of design was reviewed by 

owner/operator. Note names, dates, 

and findings. Use of such containers 

must coincide with the preparation 

and implementation of an SPCC Plan. 

Inspectors may notify OSHA if 

noncompliance is suspected. 

Inspect these records for compliance. 

Note missing or erroneous records. 

Non-liquid PCB Containers must meet 

the shipping container specifications 

of the Department of Transportation 

per §761.65(c)(6). 

Verify that dates appear on all articles 

and containers. Note locations and 

contents of undated articles and 

containers. Compare storage date 

records with stored articles and 

containers to see that they can be 

located by date of storage. If 

discrepancy appears, obtain copy of 

records, and establish location of 

relevant items. 

Verify that the storage site meets the 

conditions through visual examination 

and records review. 

August 2004 5-64 PCB Inspection Manual 
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Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

• The waste does not generate leachate through 

decomposition or other reactions. 

• The storage site has: 

- A liner designed, constructed, and installed to 

prevent any migration of wastes off or through 

the liner into the adjacent subsurface soil, 

ground water or surface water at any time 

during the active life (including the closure 

period) of the storage site. The liner may allow 

waste to migrate into the liner. 

The liner must be: 

Constructed of materials that have 

appropriate chemical properties and 

sufficient strength and thickness to prevent 

failure due to pressure gradients (including 

static head and external hydrogeologic 

forces), physical contact with the waste or 

leachate to which they are exposed, 

climatic conditions, the stress of installation, 

and the stress of daily operation. 

Placed upon a foundation or base capable 

of providing support to the liner and 

resistance to pressure gradients above and 

below the liner to prevent failure of the liner 

due to settlement, compression, or uplift. 

Installed to cover all surrounding earth likely 

to be in contact with the waste. 

- A cover that meets the requirements 

§761.65(c)(9)(iii)(A), is installed to cover all of 

the stored waste likely to be contacted with 

precipitation and is secured so as not to be 

functionally disabled by winds expected under 

normal seasonal meteorological conditions at 

the storage site. 

Conduct visual inspections of the 

area. 

PCB Inspection Manual 5-65 August 2004 
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Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Storage for Disposal 

- A run-on control system designed, constructed, 

operated, and maintained such that it 

Prevents flow onto the stored waste during 

peak discharge from at least a 25-year 

storm. 

Collects and controls at least the water 

volume resulting from a 24-hour, 25-year 

storm. Collection and holding facilities (e.g., 

tanks or basins) must be emptied or 

otherwise managed expeditiously after 

storms to maintain design capacity of the 

system. 

August 2004 5-66 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.4.6 Approval of Commercial Storers 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

Commercial storers must submit an application to 

EPA for storage approval. The storer must not 

store PCB waste at its facility prior to written 

approval from EPA. §761.65(d) 

EPA’s approval includes a maximum PCB storage 

capacity that the commercial storer must not 

exceed. The approval may include other 

conditions as EPA deems necessary. 

.• Storage areas at transfer facilities are exempt 

from the requirement to obtain approval as a 

commercial storer of PCB waste under this 

paragraph, unless the same PCB waste is 

stored at these facilities for a period of time 

greater than 10 consecutive days between 

destinations. §761.65(d)(5) 

• Storage areas at RCRA-permitted facilities 

may be exempt from the separate TSCA 

storage approval requirements if they meet the 

criteria at §761.65(d)(6). 

• Storage areas ancillary to TSCA-approved 

disposal facilities may be exempt from a 

separate facility approval provided they meet 

the criteria at §761.65(d)(7). 

Review facilities’ EPA approval 

document and facility records to verify 

that the storer did not store PCB 

waste prior to receipt of written 

approval from EPA. Also review the 

regional files. 

NOTE: Commercial storers were 

required to submit “complete” 

applications by August 1990, and 

some facilities may still be operating 

without written approval. 

Obtain and bring a copy of the EPA 

approval to check for conditions. 

Obtain information on the amount of 

PCBs currently in storage. Collect 

copies of at least the last 12 months 

of manifests and bills of lading to 

determine if the facility at anytime 

exceeded their approved storage 

capacity or store waste for 10 days or 

more. 

PCB Inspection Manual 5-67 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

Commercial storers of PCB waste must have a 

closure plan that has been accepted and approved 

by EPA. The plan must include: §§761.65(e)(1) 

and (2) 

• a description of how the PCB storage areas of 

the facility will be closed in a manner that 

eliminates the potential for post-closure 

releases of PCBs into the environment 

• an identification of the maximum extent of 

storage operations that will be open during the 

active life of the facility, including an 

identification of the extent of PCB storage 

operations at the facility relative to other 

wastes that will be handled at the facility 

• an estimate of the maximum inventory of PCB 

wastes that could be handled at one time at the 

facility over its active life and a detailed 

description of the methods or arrangements to 

be used during closure for removing, 

transporting, storing, or disposing of the 

facility's inventory of PCB waste, including an 

identification of any offsite facilities that will be 

used 

• a detailed description of the steps needed to 

remove or decontaminate PCB waste residues 

and contaminated containment system 

components, equipment, structures, and soils 

during closure, including a description of the 

methods for sampling and testing of 

surrounding soils, and the criteria for 

determining the extent of removal or 

decontamination 

• a detailed description of other activities 

necessary during the closure period to ensure 

that any post-closure releases of PCBs will not 

present unreasonable risks to human health or 

the environment (e.g., ground-water 

monitoring, runon and runoff control, and 

facility security). 

Verify that the commercial storer of 

PCB waste has a written closure plan 

that EPA has determined to be 

acceptable. Check list of EPA’s 

approved commercial storers: 

www.epa.gov/pcb. 

August 2004 5-68 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

• a schedule for closure of each area of the 

facility where PCB waste is stored or handled, 

including the total time required to close each 

area of PCB waste storage or handling, and 

the time required for any intervening closure 

activities 

• an estimate of the expected year of closure of 

the PCB waste storage areas, if a trust fund is 

opted for as the financial mechanism. 

Commercial storers do not need to submit a 

separate and new closure plan in cases where a 

facility is currently covered by a TSCA approval or 

a RCRA permit, upon a showing to the satisfaction 

EPA that the existing closure plan is substantially 

equivalent to current requirements for closure 

plans and that the plan adequately accounts for 

PCB waste inventories. §761.65(e)(3) 

The commercial storer must submit a written 

request to EPA for modification of its closure plan 

if: §761.65(e)(4) 

• changes in ownership, operating plans, or 

facility design affect the existing closure plan 

• there is a change in the expected date of 

closure, if applicable 

• in conducting closure activities, unexpected 

events require a modification of the approved 

closure plan. 

Verify that the commercial storer of 

PCB waste submitted a written 

request to EPA for a modification to its 

storage approval to amend its closure 

plan if the storer meets the criteria 

and that EPA has approved it. Facility 

may be operating without written 

approval. 

PCB Inspection Manual 5-69 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

Commercial storers of PCB waste must follow a 

specific closure schedule. They must: 

§761.65(e)(6) 

• notify EPA RA or Director of National Program 

Chemicals Division at least 60 days prior to the 

date on which final closure of its PCB storage 

facility is expected to begin. 

• “expect to begin closure” no later than 30 days 

after the date on which the facility received its 

final quantities of PCB waste. 

• remove all PCB waste in storage from the 

facility within 90 days after receiving the final 

quantity of PCB waste for storage. 

• complete closure activities within 180 days 

after receiving the final quantity of PCB waste 

for storage at the facility. 

When PCB waste is removed from the storage 

facility during closure, the owner or operator 

becomes a generator of PCB waste subject to the 

generator requirements of §761.180 through 

761.193. 

During the closure period, the commercial storer 

must dispose of all contaminated system 

component equipment, structures, and soils in 

accordance with the disposal requirements, or, if 

applicable, decontaminated in accordance with the 

levels specified in the PCB Spills Cleanup Policy. 

§761.65(e)(7) 

Within 60 days of completion of closure of each 

facility for the storage of PCB waste, the 

commercial storer of PCB waste must submit to 

the EPA RA (or Director, NPCD if he approved the 

closure plan), by registered mail, a certification that 

the PCB storage facility has been closed in 

accordance with the approved closure plan. 

§761.65(e)(8) 

Verify that the commercial storer 

complies with the schedule. Note that 

for good cause shown, EPA may 

approve a reasonable extension to the 

required deadlines regarding closure 

activities. Approved commercial 

storers may be found at the PCB 

website 

(www.epa.gov/pcb/waste.html). 

Verify that the commercial storer 

properly disposed of or 

decontaminated the required items. 

Obtain a copy of the certification from 

the facility representative and verify 

that the owner or operator and an 

independent registered professional 

engineer signed the certification. 

August 2004 5-70 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

Commercial storers of PCB waste must have a 

detailed written estimate from the commercial 

storer, in current dollars, of the cost of closing the 

facility in accordance with its approved closure 

plan. §761.65(f)(1) 

The person who prepared the cost estimate must 

certify it. The estimate must: 

• equal the cost of final closure at the point in the 

PCB storage facility's active life when the 

extent and manner of PCB storage operations 

would make closure the most expensive, as 

indicated by the facility's closure plan 

• be based on the costs to the owner or operator 

of hiring a third party to close the facility, and 

the third party is not be either a corporate 

parent or subsidiary of the owner or operator, 

or member in joint ownership of the facility 

• include the current market costs for offsite 

commercial disposal of the facility's maximum 

estimated inventory of PCB wastes, except 

that onsite disposal costs may be used if 

onsite disposal capacity will exist at the facility 

at all times over the life of the facility 

• not incorporate any salvage value that may be 

realized with the sale of wastes, facility 

structures or equipment, land, or other assets 

associated with the facility at the time of 

closure. 

During the active life of the PCB storage facility, 

the commercial storer of PCB waste must adjust 

the cost estimate annually for inflation within 60 

days prior to the anniversary date of the 

establishment of the financial instruments used to 

demonstrate financial responsibility for closure, 

except that owners or operators who use the 

financial test or corporate guarantee must adjust 

their closure cost estimates for inflation within 30 

days after the close of the storer's fiscal year. 

§761.65(f)(2) 

Request the most recent cost 

estimate to verify that it is kept at the 

facility. Review the cost estimate to 

verify that it was certified by the 

person who prepared the cost 

estimate and meets the necessary 

criteria listed in the regulatory 

requirements and has properly been 

adjusted for inflation each year. 

PCB Inspection Manual 5-71 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

When the EPA approves a modification to the 

facility's closure plan, and that modification 

increases the cost of closure, the owner or 

operator must revise the closure cost estimate no 

later than 30 days after the modification is 

approved. §761.65(f)(3) 

A commercial storer must establish financial 

assurance for closure of each PCB storage facility 

that they own or operate. §761.65(g) 

Laboratories are exempt from the reporting and 

documentation requirements for commercial 

storers if they meet stipulated conditions. 

§761.65(i)(1) 

Laboratory samples are exempt from the 

manifesting requirements of §761.208 if the 

sample is being: §761.65(i)(2) 

• transported to a laboratory for the purpose of 

testing 

• transported back to the sample collector after 

testing 

• stored by the sample collector before transport 

to a laboratory for testing 

• stored in a laboratory before testing 

• stored in a laboratory after testing but before it 

is returned to the sample collector 

• stored temporarily in the laboratory after testing 

for a specific purpose (e.g., until conclusion of 

a court case enforcement action where further 

testing of the sample may be necessary). 

Verify that the laboratory is storing 

samples held for disposal in a facility 

that complies with the standards in 

§761.65(b)(1)(i) through (b)(1)(iv). 

August 2004 5-72 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Approval of Commercial Storers 

To qualify for the exemptions in §761.65(i)(2), the 

sample collector or laboratory shipping the sample 

must: §761.65(i)(3) 

• comply with applicable DOT or U.S. Postal 

Service (USPS) shipping requirements, found 

respectively in 49 CFR 173.345 and U.S. 

Postal Regulations 652.2 and 652.3 

• assure that the following information 

accompanies the sample: 

- the sample collector's name, mailing 

address, and telephone number 

- the laboratory's name, mailing address, 

and telephone number. 

- the quantity of the sample 

- the date of shipment 

- a description of the sample. 

• package the sample so that it does not leak, 

spill, or vaporize from its packaging. 

After the laboratory determines the concentration 

of the PCB sample and terminates its use, the 

laboratory must either manifest the PCB waste to 

a disposer or commercial storer, retain a copy of 

each manifest, and follow up on exception 

reporting, or return the sample to the sample 

collector who must then properly dispose of the 

sample. §761.65(i)(4) 

Review records and facility 

procedures to verify that the facility 

personnel are properly shipping 

samples. 

If inspecting a laboratory that 

conducts PCB analysis, review facility 

records to verify that the samples are 

properly manifested to a disposer or 

returned to the sample collector. 

PCB Inspection Manual 5-73 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.4.7 Coordinated Approval 

Regulation Reference §761.77 

Regulatory Requirements Inspection Procedures 

Coordinated Approval 

Any owner or operator of a facility that he or she 

intends to use to: landfill PCB wastes; incinerate 

PCB wastes; dispose of PCB wastes using an 

alternative disposal method that is equivalent to 

disposal in an incinerator approved under 

§761.70 or a high efficiency boiler operating in 

compliance with §761.71; or store PCB wastes; 

or conduct research and development (R&D) into 

PCB disposal methods (regardless of PCB 

concentration), or conduct PCB remediation 

activities may apply to EPA for a TSCA PCB 

Coordinated Approval. Generally, EPA must find 

that such a person holds a permit or other 

document which properly regulates PCB wastes. 

All requirements, conditions, and limitations of 

any such other permit or waste management 

document, cited or described in paragraph (b) 

and (c) of this section, as the technical or legal 

basis on which the TSCA PCB Coordinated 

Approval is issued, are conditions of the TSCA 

PCB Coordinated Approval. §761.77 

Verify compliance with the permit or 

other document on which the 

Coordinated Approval is based. 

August 2004 5-74 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.4.8 Decontamination Standards and Procedures 

Regulation Reference §761.79 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

Decontamination in accordance with the 

standards in §761.79(b) does not require a 

disposal approval under §761, Subpart D. 

Materials from which PCBs have been removed 

by decontamination may be distributed in 

commerce, used or reused, and are unregulated 

for disposal. §761.79(a) 

Any person decontaminating porous surfaces 

other than concrete and non-porous surfaces 

covered with a porous surface, such as paint or 

coating on metal, must obtain an alternative 

decontamination approval. §761.79(a)(5) 

Persons using chopping (including wire 

chopping), distilling, filtering, oil/water separation, 

spraying, soaking, wiping, stripping of insulation, 

scraping, scarification, or abrasives or solvents 

to remove or separate PCBs from liquids, 

concrete, or non-porous surfaces must adhere to 

standards. §761.79(b) 

• Standards for water containing PCBs: 

- < 200 μg/L (i.e., 200 ppb PCBs) for noncontact use in a closed system where 

there are no releases 

- for water discharged to a treatment works 

or to navigable waters, <3 μg/L 

(approximately <3 ppb) or a PCB 

discharge limit included in a permit issued 

under section 307(b) or 402 of the Clean 

Water Act 

- #0.5 μg/L (i.e., approximately # 0.5 ppb 

PCBs) for unrestricted use 

• Standards for organic liquids and nonaqueous inorganic liquids containing PCBs: 

- <2 mg/kg (i.e., <2 ppm PCBs) 

If the facility has conducted 

decontamination, review records to 

verify that it had a disposal approval or 

that it conducted decontamination in 

accordance with the standards in 

§761.79(b). 

Request the facility’s alternative 

decontamination approval if the facility 

decontaminated porous surfaces other 

than concrete or non-porous surfaces 

covered with a porous surface. 

Verify that they are adhering to the 

applicable decontamination standards. 

PCB Inspection Manual 5-75 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

• Standards for non-porous surfaces previously 

in contact with liquid PCBs at any 

concentration, where no free-flowing liquids 

are currently present, for unrestricted use: 

- # 10 μg/100 cm2

 as measured by a 

standard wipe test at selected locations 

• Standards for non-porous surfaces in contact 

with non-liquid PCBs (including non-porous 

surfaces covered with a porous surface, 

such as paint or coating on metal) 

- cleaning to Visual Standard No. 2, NearWhite Blast Cleaned Surface Finish, of 

the National Association of Corrosion 

Engineers (NACE) as verified by visually 

inspecting all cleaned areas. 

• Standards for non-porous surfaces previously 

in contact with liquid PCBs at any 

concentration, where no free-flowing liquids 

are currently present for disposal in a smelter 

meeting specified standards under §761.72: 

- < 100 μg/100 cm2

 as measured by a 

standard wipe test at selected locations 

• Standards for non-porous surfaces in contact 

with non-liquid PCBs (including non-porous 

surfaces covered with a porous surface, 

such as paint or coating on metal) for 

disposal in a smelter meeting specified 

standards under §761.72: 

- cleaning to Visual Standard No. 3, 

Commercial Blast Cleaned Surface 

Finish, of NACE as verified by visually 

inspecting all cleaned areas. 

• Standard for concrete 

- #10 μg/100 cm2

 as measured by a 

standard wipe test if the decontamination 

procedure is started within 72 hours of the 

initial spill of PCBs to the concrete or 

portion thereof being decontaminated. 

August 2004 5-76 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

Any person performing self-implementing 

decontamination procedures must comply with 

one of the following procedures: §761.79(c) 

• For PCB Containers, flush the internal 

surfaces of the container 3 times with a 

solvent containing <50 ppm PCBs. The 

volume of each rinse must equal 

approximately 10% of the PCB Container 

capacity. §761.79(c)(1) 

• For PCB-contaminated movable equipment, 

tools, or sampling equipment, swab surfaces 

with a solvent, perform a double wash/rinse in 

accordance with §761.360 through 761.378, 

or perform another applicable 

decontamination procedure. §761.79(c)(2) 

• For non-porous surface in contact with freeflowing mineral oil dielectric fluid (MODEF) at 

levels <10,000 ppm, drain all free-flowing 

MODEF and allow the surfaces to drain for an 

additional 15 h, dispose of drained MODEF 

according to §761.75(g), soak the surfaces in 

a sufficient amount of clean (containing <2 

ppm PCBs) performance-based organic 

decontamination fluid (PODF) such that there 

is a minimum of 800 mL of PODF for each 

100 cm2

 of contaminated or potentially 

contaminated surface for at least 15 h at $ 

20°C, drain the PODF from the surfaces, and 

dispose of the drained PODF in accordance 

with §761.79(g). Approved PODFs include 

kerosene, diesel fuel, terpene hydrocarbons, 

and mixtures of terpene hydrocarbons and 

terpene alcohols. §761.79(c)(3) 

Verify that persons performing selfimplementing decontamination complied 

with one of the procedures in §761.79(c) 

by reviewing records. 

PCB Inspection Manual 5-77 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

• For a non-porous surface in contact with freeflowing MODEF containing >10,000 ppm 

PCB in MODEF or askarel PCB (up to 70 

percent PCB in a mixture of 

trichlorobenzenes and tetrachlorobenzenes), 

drain the free-flowing MODEF or askarel and 

allow the residual surfaces to drain for an 

additional 15 h, dispose of drained MODEF or 

askarel in accordance with §761.79(g), soak 

the surfaces to be decontaminated in a 

sufficient amount of clean PODF (containing 

< 2 ppm PCBs) such that there is a minimum 

of 800 mL of PODF for each 100 cm2

 of 

contaminated or potentially contaminated 

surface for at least 15 h at > 20°C, drain the 

PODF from the surfaces, dispose of the 

drained PODF in accordance with 

§761.79(g), resoak the surfaces to be 

decontaminated in a sufficient amount of 

clean PODF (containing < 2 ppm PCBs) 

such that there is a minimum of 800 mL of 

PODF for each 100 cm2

 of surface for at 

least 15 h at > 20°C, drain the PODF from 

the surfaces, dispose of the drained PODF in 

accordance with §761.79(g). §761.79(c)(4) 

August 2004 5-78 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

• Any person decontaminating piping and air 

lines in an air compressor system must: 

§761.79(c)(5) 

- before decontamination proceeds, 

disconnect or bypass the air 

compressors and air dryers from the 

piping and air lines and decontaminate the 

air compressors and air dryers separately 

- dispose of filter media and desiccant in 

the air dyers based on their existing PCB 

concentration 

- test the connecting line and 

appurtenances of the system to assure 

that there is no leakage by introducing air 

into the closed system at from 90 to 100 

psi. Only if there is a pressure drop of < 5 

psi in 30 minutes may decontamination 

take place. 

- when there is no leakage, fill the piping 

and air lines with clean (containing < 2 

ppm PCBs) solvent. Solvents include 

PODF, aqueous potassium hydroxide at a 

pH between 9 and 12, or water containing 

5 percent sodium hydroxide by weight 

- circulate the solvent to achieve turbulent 

flow through the piping and air lines in the 

air compressor system until the total 

volume of solvent circulated equals 10 

times the total volume of the particular 

article being decontaminated, then drain 

the solvent 

- calculate the total volume of solvent 

circulated by multiplying the pump rate by 

the time of pumping 

- refill the system with clean solvent and 

repeat the circulation and drain process. 

• For metal surfaces in contact with liquid and 

non-liquid PCBs at concentrations < 500 

ppm, use a scrap metal recovery oven or 

smelter. 

• For metal surfaces in contact with liquid or 

non-liquid PCBs at concentrations > 500 

ppm, decontaminate to a surface 

concentration of 100 μg/100 cm2

 then use a 

scrap metal recovery oven or smelter. 

Interview facility workers on 

decontamination procedures. Check 

disposal records to ensure facility 

complied with disposal requirements. 

PCB Inspection Manual 5-79 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

Decontamination solvents: §761.79(d) 

• must be 5 percent or more by weight (unless 

otherwise provided) 

• must have a PCB concentration of <50 ppm 

• may be tested and validated for performancebased decontamination of non-porous 

surfaces contaminated with MODEF or other 

PCB liquids, in accordance with the selfimplementing procedures. Specific conditions 

for the performance-based testing from this 

validation are determined in the validation 

study. 

Any person conducting decontamination activities 

shall limit their exposure and take necessary 

measures to protect against direct release of 

PCBs to the environment from the 

decontamination area. §761.79(e) 

Persons conducting self-implementing 

decontamination must retain a written record 

documenting compliance with required 

compliance sampling or self-implementing 

decontamination procedures for 3 years after 

completion of the decontamination. §761.79(f) 

Verify that individuals participating in 

decontamination activities wear or use 

protective clothing or equipment to 

protect against dermal contact or 

inhalation of PCBs or materials 

containing PCBs. 

Verify that the persons conducting selfimplementing decontamination have 

retained the required written record for 3 

years after completion of the 

decontamination. 

August 2004 5-80 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Decontamination Standards and Procedures 

Persons must dispose of decontamination waste 

and residues at their existing PCB concentration 

unless otherwise specified. §761.79(g) 

Any person wishing to decontaminate material or 

perform sampling using an alternate method 

must apply in writing to the EPA RA and receive 

approval. §761.79(h) 

Verify that 

• distillation bottoms or residues and 

filter media are disposed of as PCB 

remediation waste. 

• PCB wastes physically separated 

from regulated waste are disposed 

of at their original concentration 

• hydrocarbon solvent that contains 

<50 ppm PCB is burned and 

marketed in accordance with 

§761.20(e), disposed of in 

accordance with §761.60(a) or 

761.60(e), or decontaminated. 

• chlorinated solvent with any PCB 

concentration are disposed of in an 

incinerator in accordance with 

§761.70 or decontaminated 

• solvents > 50 ppm other than those 

described above are disposed of in 

accordance with §761.60(a) or 

decontaminated 

• non-liquid cleaning materials and 

personal protective equipment waste 

at any concentration, including nonporous surfaces and other non-liquid 

materials such as rags, gloves, 

booties, other disposable personal 

protective equipment, and similar 

materials resulting from 

decontamination are disposed of in 

accordance with §761.61(a)(5)(v). 

Verify that the facility does not conduct 

decontamination or sampling using an 

alternate methodology prior to obtaining 

written approval from EPA. 

PCB Inspection Manual 5-81 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.5 Transboundary Shipments of PCBs for Disposal 

Regulation Reference §761.91 through §761.99 

Regulatory Requirements Inspection Procedures 

Import for Disposal 

No person may import PCBs or PCB Items for 

disposal without an exemption issued under the 

authority of TSCA section 6(e)(3). §761.93(a) 

From EPA databases, review facility 

historical enforcement data and obtain 

information on whether the facility 

imported PCBs or PCB Items. If so, 

verify that the facility had received an 

exemption at the time of import. 

Export for Disposal 

No person may export PCBs or PCB Items for 

disposal without an exemption, except that PCBs 

and PCB Items at concentrations <50 ppm (or <10 

μg PCB/100 cm2

 if no free-flowing liquids are 

present) may be exported for disposal. 

§761.97(a)(1) 

Persons shall treat PCBs and PCB Items of 

unknown concentrations as if they contain >50 

ppm. §761.97(a)(2) 

Obtain information on whether the 

facility exported PCBs or PCB Items. 

If so, verify that the facility received an 

exemption prior to export, or that the 

PCBs were below the specified 

concentrations. 

Other Transboundary Shipments 

The following transboundary shipments are not 

considered exports or imports: 

• PCB waste generated in the U.S., transported 

outside the Customs Territory of the U.S. 

(including any residuals resulting from cleanup 

of spills of such wastes in transit) through 

another country or its territorial waters, or 

through international waters, and returned to 

the U.S. for disposal. §761.99(a) 

• PCB waste in transit, including any residuals 

resulting from cleanup of spills during transit, 

through the U.S. (e.g., from Mexico to Canada, 

from Canada to Mexico). §761.99(b) 

• PCB waste transported from any State to any 

other State for disposal, regardless of whether 

the waste enters or leaves the customs 

territory of the U.S., provided that the PCB 

waste or the PCBs from which the waste was 

derived were present in the U.S. on January 1, 

1979, and have remained within the U.S. since 

that date. §761.99(c) 

August 2004 5-82 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.6 PCB Spill Cleanup Policy 

Regulation Reference §761.125 

(NOTE: The PCB Spill Cleanup Policy is intended for spills less than 72 hours old. Any spills older than 

72 hours must be cleaned up as PCB Remediation Waste found at Regulation Reference §761.61 (page 

4-49). This is a policy, not a regulation.) 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

Unless expressly limited, the reporting, disposal, and 

precleanup sampling requirements below apply to all 

spills of PCBs at concentrations of > 50 ppm which 

are subject to decontamination requirements under 

TSCA including those spills listed under §761.120(b) 

which are excluded from the cleanup standards of 

§§761.125(b) and (c). §761.125(a) 

Where a spill directly contaminates surface water, 

sewers, or drinking water supplies, the responsible 

party must notify the appropriate EPA regional 

office or National Chemical Program Division and 

obtain guidance for appropriate cleanup measures 

within 24 hours of discovery or sooner if possible. 

§761.125(a)(1)(i) 

Where a spill directly contaminates grazing lands 

or vegetable gardens, the responsible party must 

notify the appropriate EPA regional office and 

proceed with immediate requirements specified 

under §§761.125(b) or (c) within 24 hours of 

discovery or sooner if possible. §761.125(a)(1)(ii) 

Where a spill exceeds 10 pounds of PCBs by 

weight and is not addressed in §§761.125(a)(1)(i) 

or (ii), the responsible party must notify the 

appropriate EPA regional office and proceed to 

decontaminate the spill area in accordance with 

this Policy within 24 hours of discovery or sooner if 

possible. §761.125(a)(1)(iii) 

Where a spill is 10 pounds or less and is not 

addressed in §§761.125(a)(1)(i) or (ii), the 

responsible party must decontaminate the spill 

area in accordance with this Policy but does not 

need to notify EPA. §761.125(a)(1)(iv) 

Determine who is the responsible 

party based on interviews and 

information gathered from the citizen 

complaint. Verify that the responsible 

party notified the EPA within 24 hours 

of discovery. 

Verify that the responsible party 

notified the EPA within 24 hours of 

discovery and immediately began 

cleanup. 

Verify that the responsible party 

notified the EPA within 24 hours of 

discovery and immediately began 

cleanup. 

PCB Inspection Manual 5-83 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

The responsible party must properly store, label, 

and dispose of all concentrated soils, solvents, 

rags, and other materials resulting from the 

cleanup in accordance with Subpart D. 

§761.125(a)(2) 

The responsible party must use a statistically 

based sampling scheme to determine the 

boundaries of the spill where there are insufficient 

visible traces yet there is evidence of a leak or spill. 

§761.125(a)(3) 

Low-concentration spills which involve less 

than 1 pound of PCBs by weight (less than 270 

gallons of untested mineral oil) §761.125(b) 

Within 48 hours after they were notified or became 

aware of the spill, the responsible party must: 

§761.125(b)(1) 

• Double wash/rinse (as defined under §761.123) 

all solid surfaces 

• Clean all indoor, residential surfaces other than 

vault areas to 10 μg/100 cm2

 by standard 

commercial wipe tests. 

• Excavate all soil within the spill area (i.e., visible 

traces of soil and a buffer of 1 lateral foot 

around the visible traces) and restore the 

ground to its original configuration by back-filling 

with clean soil (< 1 ppm PCBs). 

The responsible party may delay completion of 

cleanup beyond 48 hours in case of circumstances 

including but not limited to, civil emergency, 

adverse weather conditions, lack of access to the 

site, and emergency operating conditions. The 

occurrence of a spill on a weekend or overtime 

costs are not acceptable reasons to delay 

response. The delay may only last for the duration 

of the adverse conditions. If the adverse weather 

conditions, or time lapse due to other emergency, 

has left insufficient visible traces, the responsible 

party must use a statistically based sampling 

scheme to determine the spill boundaries. 

§761.125(b)(2) 

Verify decontamination procedures. 

If cleanup completion was delayed 

beyond 48 hours, document the 

reason for the delay. 

August 2004 5-84 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

At the completion of cleanup, the responsible party 

shall document the cleanup with records and certify 

decontamination. They must maintain the records 

and certification for 5 years. The records and 

certification shall consist of the following: 

§761.125(b)(3) 

• Identification of the source of the spill. 

• Estimated or actual date and time of the spill 

occurrence. 

• Date and time cleanup was completed or 

terminated (the nature and duration of the delay, 

if applicable). 

• Description of the spill location. 

• Precleanup sampling data used to establish the 

spill boundaries, if required, and a brief 

description of the sampling methodology used 

to establish the spill boundaries. 

• Description of the solid surfaces cleaned and of 

the double wash/rinse method used. 

• Approximate depth of soil excavation and the 

amount of soil removed. 

• A certification statement signed by the 

responsible party stating that the cleanup 

requirements have been met and that the 

information contained in the record is true to the 

best of their knowledge. 

High-concentration spills and lowconcentration spills involving 1 pound or more 

PCBs by weight (270 gallons or more of 

untested mineral oil). §761.125(c) 

As quickly as possible and within no more than 24 

hours (48 hours for PCB Transformers) after the 

responsible party was notified or became aware of 

the spill, they must: §761.125(c)(1) 

• Notify the EPA regional office and the National 

Response Center (NRC) as required by 

§761.125(a)(1) or by other applicable statutes. 

• Cordon off or otherwise delineate and restrict 

an area encompassing any visible traces plus a 

3-foot buffer and place clearly visible signs 

advising persons to avoid the area to minimize 

the spread of contamination and the potential 

for human exposure. 

Check the company records and copy 

of certification of decontamination for 

the required information if applicable. 

Verify that the responsible party 

completed the required notification, 

restriction, and documentation. 

PCB Inspection Manual 5-85 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

• Record and document the area of visible 

contamination, noting the extent of the visible 

trace areas and the center of the visible trace 

area. If there are no visible traces, the 

responsible party shall record this fact and 

contact the regional office of the EPA for 

guidance in completing statistical sampling of 

the spill area to establish spill boundaries. 

• Initiate cleanup of all visible traces of the fluid on 

hard surfaces and initiate removal of all visible 

traces of the spill on soil and other media, such 

as gravel, sand, oyster shells, etc. 

• Estimate (based on the amount of material 

missing from the equipment or container) the 

area of the spill and immediately cordon off the 

area of suspect contamination if there has been 

a delay in reaching the site and there are 

insufficient visible traces of PCBs remaining at 

the spill site and utilize a statistically based 

sampling scheme to identify the boundaries of 

the spill area as soon as practicable. 

• Achieve prompt decontamination (EPA will 

consider promptness of completion in 

determining whether the responsible party 

made good faith efforts to cleanup in 

accordance with this policy.) 

Note: The responsible party may delay the actions 

above beyond 24 hours for the duration 

of the adverse conditions (e.g., civil emergency, 

hurricane, tornado, or other similar adverse 

weather conditions, lack of access due to physical 

impossibility, or emergency operating conditions). 

The occurrence of a spill on a weekend or overtime 

costs are not acceptable reasons to delay 

response. Owners of spilled PCBs who have 

delayed cleanup because of these types of 

circumstances must keep records documenting 

the fact that circumstances precluded rapid 

response. 

Take photographs of the spill. 

If any of the actions above were 

delayed beyond 24 hours, verify that 

adverse circumstances cause the 

delay. 

August 2004 5-86 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

The party responsible for a spill in outdoor electrical 

substations must: §761.125(c)(2) 

• Clean contaminated solid surfaces (both 

impervious and non-impervious) to a PCB 

concentration of 100 μg/100 cm2 (as measured 

by standard wipe tests). 

• At the option of the responsible party, clean soil 

contaminated by the spill to 25 ppm PCBs by 

weight, or to 50 ppm PCBs by weight provided 

that a label or notice is visibly placed in the 

area. If the responsible party demonstrates that 

cleanup to 25 ppm or 50 ppm will jeopardize the 

integrity of the electrical equipment at the 

substation, the EPA regional office may 

establish an alternative cleanup method or level 

and place the responsible party on a reasonably 

timely schedule for completion of cleanup. 

• Verify conformance to the cleanup standards by 

post-cleanup sampling as specified under 

§761.130. 

The party responsible for a spill in other restricted 

access areas must: §761.125(c)(3) 

• Clean high-contact solid surfaces to 10 μg/100 

cm2

 (as measured by standard wipe tests). A 

high-contact surface is a surface that is 

repeatedly touched, often for long periods of 

time. Examples of high-contact industrial 

surfaces are manned machinery or control 

panels. Examples of high-contact 

residential/commercial surfaces are doors, 

walls below 6 feet, uncovered flooring, 

windowsills, bannisters, fencing, stairs, 

automobiles, and children’s play areas. 

• Decontaminate low-contact, indoor, impervious 

solid surfaces to 10μg/100 cm2 

. 

Verify that the responsible party 

cleaned the spill to the prescribed 

concentrations. 

If improper cleanup procedures are 

suspected or no records are available, 

the inspector may sample. 

Verify company’s sampling records to 

ensure that the responsible party 

cleaned the spill to the prescribed 

concentrations. 

PCB Inspection Manual 5-87 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

• At the option of the responsible party, clean lowcontact, indoor, nonimpervious surfaces to 10 

μg/100 cm2

 or clean to 100 μg/100 cm2 and 

encapsulate. The EPA RA may disallow the 

encapsulation option for a particular spill 

situation upon finding that the uncertainties 

associated with that option pose special 

concerns at that site. 

• Clean low-contact, outdoor surfaces (both 

impervious and nonimpervious) to 100 μg/100 

cm2 

. 

• Clean soil contaminated by the spill to 25 ppm 

PCBs by weight. 

• Verify conformance to the cleanup standards by 

postcleanup sampling as specified under 

§761.130. 

Note: Persons responsible for spills to outdoor 

electrical substations or other restricted access 

areas that have been converted to another use 

must clean the spill to the nonrestricted access 

requirements at §761.125(c)(4). 

The party responsible for a spill in nonrestricted 

access areas must: §761.125(c)(4) 

• Dispose of furnishings, toys, and other easily 

replaceable household items in accordance 

with the provisions of subpart D of this part and 

replace them. 

• Clean indoor solid surfaces and high contact 

outdoor solid surfaces, defined as high contact 

residential/commercial surfaces under 

§761.123, to 10 μg/100 cm2

 (as measured by 

standard wipe tests). 

• Decontaminate indoor vault areas and lowcontact, outdoor, impervious solid surfaces to 

10 μg/100 cm2 

. 

Visually inspect and review company 

sampling records to ensure that the 

responsible party cleaned the spill to 

the prescribed concentrations. 

If improper sampling is suspected, 

inspector may sample area affected 

by the spill. 

August 2004 5-88 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCB Spill Cleanup Policy 

• At the option of the responsible party, clean lowcontact, outdoor, nonimpervious solid surfaces 

to 10 μg/100 cm2

 or clean to 100 μg/100 cm2 

and encapsulate. The EPA RA may disallow 

the encapsulation option for a particular spill 

situation upon finding that the uncertainties 

associated with that option pose special 

concerns at that site. 

• Decontaminate soil contaminated by the spill to 

10 ppm PCBs by weight, excavate the soil to a 

minimum depth of 10 inches, replace the 

excavated soil with clean soil (<1 ppm PCBs), 

and restore the spill site. 

• Verify conformance to the cleanup standards by 

postcleanup sampling as specified under 

§761.130. 

The responsible party must document the cleanup 

with records of decontamination and maintain the 

records for 5 years. The records and certification 

shall consist of the following: §761.125(c)(5) 

• Identification of the source of the spill 

• Estimated or actual date and time of the spill 

occurrence 

• Date and time cleanup was completed or 

terminated (the nature and duration of the delay, 

if applicable). 

• Description of the spill location (outdoor 

electrical substation, other restricted access 

location, or in a nonrestricted access area) and 

the nature of the materials contaminated. 

• Precleanup sampling data used to establish the 

spill boundaries, if required, and a brief 

description of the sampling methodology used 

to establish the spill boundaries. 

• Description of the solid surfaces cleaned. 

• Approximate depth of soil excavation and the 

amount of soil removed. 

• Postcleanup verification sampling data and, if 

not otherwise apparent, a brief description of 

the sampling methodology and analytical 

technique used. 

Check the records and certification of 

decontamination for the required 

information. 

PCB Inspection Manual 5-89 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.7 General Records and Reports 

5.7.1 PCBs and PCB Items in Service or Projected for Disposal 

Regulation Reference §761.180(a) 

Regulatory Requirements Inspection Procedures 

PCBs and PCB Items in Service or Projected for Disposal 

Beginning 2/5/90, owners and operators of a facility 

other than a commercial storer or disposer of PCB 

waste, using or storing at any time at least 45 

kilograms (99.4 pounds) of containerized PCBs, 

one or more PCB Transformers, or 50 or more 

PCB Large High-or Low-Voltage Capacitors must 

develop and maintain all annual records and a 

written annual document log of the disposition of 

PCBs and PCB Items. The owners and operators 

must prepare a written annual document log for 

each facility by July 1st covering the previous 

calendar year (January - December) and maintain 

the annual document log for at least 3 years after 

the facility ceases using or storing PCBs. 

§761.180(a) 

The annual records must include: 

§761.180(a)(1) 

• All signed manifests generated by the facility 

during the calendar year 

• All certificates of disposal (CODs) that have 

been received by the facility during the calendar 

year 

• Records of inspections and cleanups 

performed in accordance with §761.65(c)(5). 

The annual document log must include: 

§761.180(a)(2) 

• Name, address, and EPA ID number of the 

facility covered by the annual document log and 

the calendar year covered by the annual 

document log §761.180(a)(2)(i) 

Check the amount of PCBs or PCB 

Items to determine whether facility is 

subject to general recordkeeping 

requirements. If PCBs or PCB Items 

are present in prescribed amounts, 

verify that the facility is preparing and 

maintaining the proper records. 

Inspect annual records for required 

information. 

Inspect annual document log for 

required information. 

August 2004 5-90 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCBs and PCB Items in Service or Projected for Disposal 

• The manifest number of every manifest 

generated during the calendar year, and from 

each manifest and for unmanifested waste 

stored at the facility, the following information: 

§761.180(a)(2)(ii) 

All PCB Items — First date it was removed from 

service for disposal, date it was placed into 

transport for storage or disposal, and date of 

disposal. 

Bulk PCB waste — Weight in kg, total bulk weight 

in kg of bulk PCB waste that was placed into 

storage for disposal or disposed of during the 

calendar year. 

PCB Transformers — The serial number or other 

means of identifying each PCB Transformer, 

weight in kg of the PCB waste in the transformer or 

capacitor, and the total number of PCB 

Transformers and total weight in kg of PCBs 

contained in the transformers. 

PCB Containers — A unique number identifying 

each PCB Container, a description of the contents 

of each PCB Container (liquid, soil, cleanup debris, 

etc.), total weight in kg of PCB Container(s), and 

total weight in kg of the contents of PCB 

Containers. 

PCB Articles — a unique number identifying each 

PCB Article Container, a description of the contents 

of each PCB Article Container (pipes, capacitors, 

motor pumps, etc.), total weight of material in PCB 

Container(s), the total number by specific type of 

PCB Articles, total weight in kg of PCBs and PCB 

Articles, and total number of PCB Article 

Containers. 

Interview owner/operator and verify 

what materials the facility handles and 

inspect annual document log for 

required information applicable to 

specific materials. 

Take photographs of facility’s PCB 

items, waste, transformers, 

containers, and articles. 

Ensure all of the above comply with 

the appropriate requirements. 

PCB Inspection Manual 5-91 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

PCBs and PCB Items in Service or Projected for Disposal 

• The total number by specific type of PCB 

Articles and the total weight in kg of PCBs in 

PCB Articles, the total number of PCB Article 

Containers and total weight in kg of the 

contents of PCB Article Containers, the total 

number of PCB Containers and the total weight 

in kg of the contents of PCB Containers, and 

the total weight in kg of bulk PCB waste that 

was placed into storage for disposal or 

disposed during the calendar year. 

§761.180(a)(2)(iii) 

• The total number of PCB Transformers and 

total weight in kg of PCBs contained in the 

transformers remaining in service at the end of 

the calendar year. §761.180(a)(2)(iv) 

• The total number of Large High or Low Voltage 

PCB Capacitors remaining in service at the end 

of the calendar year. §761.180(a)(2)(v) 

• The total weight in kg of any PCBs and PCB 

Items in PCB Containers, including the 

identification of container contents, remaining in 

service at the facility at the end of the calendar 

year. §761.180(a)(2)(vi) 

• For any PCBs or PCB Item received from or 

shipped to another facility owned or operated by 

the same generator, the information required 

under §761.180(a)(2)(ii). §761.180(a)(2)(vii) 

• A record of each telephone call, or other means 

of verification agreed upon by both parties, 

made to each designated commercial storer or 

designated disposer to confirm receipt of PCB 

waste transported by an independent 

transporter (as required by §761.208). 

§761.180(a)(2)(viii) 

Verify whether any PCBs or PCB 

Items were received from or shipped 

to another facility owned or operated 

by the same generator; if so, check 

annual report log for required 

information. 

Verify whether any PCBs or PCB 

Items were shipped for storage or 

disposal via transportation by an 

independent transporter; if so, check 

annual report log for records of 

required verification. 

August 2004 5-92 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

PCBs and PCB Items in Service or Projected for Disposal 

• Whenever a PCB Item, excluding small 

capacitors, with a concentration of $50 ppm is 

distributed in commerce for reuse pursuant to 

§761.20(c)(1), the name, address, and 

telephone number of the person to whom the 

item was transferred, date of transfer, and the 

permanently marked serial number or internal 

identification number of the item. 

§761.180(a)(2)(ix) 

For purposes of the annual document log, PCB 

Voltage Regulators must be recorded as PCB 

Transformers. §761.180(a)(4) 

Verify whether any PCB Item was 

transferred, sold, or otherwise 

distributed in commerce. 

5.7.2 Disposers and Commercial Storers of PCB Waste 

Regulation Reference: §761.180(b) 

Regulatory Requirements Inspection Procedures 

Disposers and Commercial Storers of PCB Waste 

Beginning 2/5/90, each owner and operator of a 

facility (including high-efficiency boiler operations 

used for the commercial storage or disposal of 

PCBs and PCB Items) must maintain annual 

records on the disposition of all PCBs and PCB 

Items at the facility and prepare and maintain a 

written annual document log for PCBs and PCB 

Items that were handled as PCB waste at the 

facility. §761.180(b) 

The owner and operator must prepare the written 

annual document log by July 1 for the previous 

calendar year (January - December) and maintain 

the log at each facility for at least 3 years after 

each facility is no longer used for the storage or 

disposal of PCBs and PCB Items, except that 

owners/operators of chemical waste landfills must 

maintain the annual document log for at least 20 

years after the landfill is no longer used for PCB 

disposal. The maintenance requirements for 

annual records are the same as those for the 

annual document log. §761.180(b) 

Verify that annual records and written 

annual document log are being 

maintained and are correct. 

Verify that annual records and annual 

document log are maintained 

according to specified time table. 

PCB Inspection Manual 5-93 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Disposers and Commercial Storers of PCB Waste 

The annual records must include: §761.180(b)(1) 

• All signed manifests generated by the facility 

during the calendar year 

• All certificates of disposal (CODs) that have 

been received by the facility during the 

calendar year 

• Records of inspections and cleanups 

performed in accordance with §761.65(c)(5). 

The annual document log must contain the 

following information: §761.180(b)(2) 

• Name, address, and EPA ID number of the 

facility covered by the annual document log 

and the calendar year covered by the annual 

document log §761.180(b)(2)(i) 

• The manifest number of every manifest 

generated by the facility during the calendar 

year and from each manifest and for 

unmanifested waste stored at the facility, the 

following information: §761.180(b)(2)(ii) 

All PCB Items — First date it was removed from 

service for disposal, date it was received at the 

facility, date it was placed into transport offsite 

disposal (if applicable), date of disposal (if known), 

and confirmed date of disposal. 

Bulk PCB waste — Weight in kg. 

PCB Articles not in a PCB Container — A 

unique number identifying each PCB Article and 

weight in kg of the PCB waste in the article. 

PCB Containers — The unique number assigned 

by the generator identifying each PCB Container 

and a description of the contents of each PCB 

Container (liquid, soil, cleanup debris, etc.), and 

total weight in kg of the PCB waste in the PCB 

Container(s). 

Inspect annual document log for all 

required information. 

Verify what materials are handled at 

facility and inspect annual document 

log for required information applicable 

to specific materials. 

The inspector should also obtain 

copies of at least one years worth of 

shipping documents (manifests and 

bills of lading). By comparing the 

dates of incoming and outgoing 

weights, the inspector can determine if 

the facility at any time exceeded their 

allowed storage capacity. 

August 2004 5-94 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Disposers and Commercial Storers of PCB Waste 

PCB Article Containers — The unique number 

assigned by the generator identifying each PCB 

Article Container and a description of the contents 

of each PCB Article Container (e.g., pipes, 

capacitors, electric motors, pumps, etc.), and total 

weight in kg of the PCB waste in the PCB Article 

Container. 

For any PCBs or PCB Items received from or 

shipped to another facility owned or operated by 

the same generator, the information listed in 

§761.180(b)(2)(ii). §761.180(b)(2)(iii) 

The owner or operator of a PCB disposal or 

commercial storage facility must submit an annual 

report (that briefly summarizes the records and 

annual document log required to be maintained 

and prepared as indicated above) to the RA of the 

EPA Region where the facility is located by July 15 

of each year. §761.180(b)(3) 

Verify what materials are handled at 

facility and inspect annual document 

log for required information applicable 

to specific materials. 

Verify whether any PCBs or PCB 

Items were received from or shipped to 

another facility owned or operated by 

the same generator; if so, check 

annual report log for required 

information. 

During the inspection, verify that 

annual report has been submitted to 

the EPA Regional Administrator 

according to required timetable. 

PCB Inspection Manual 5-95 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Disposers and Commercial Storers of PCB Waste 

The annual report must contain: 

• Name, address, and EPA identification number 

of the facility covered by the annual report for 

the calendar year §761.180(b)(3)(i) 

• A list of the numbers of all signed manifests of 

PCB waste initiated or received by the facility 

during that year §761.180(b)(3)(ii) 

• The total weight in kg of bulk PCB waste, PCB 

waste in PCB Transformers, PCB waste in 

PCB Large High- or Low- Voltage Capacitors, 

and PCB waste in PCB Containers in storage 

at the facility at the beginning of the calendar 

year, received or generated at the facility, or 

disposed of at the facility during the calendar 

year and remaining in storage for disposal at 

the facility at the end of the calendar year. 

(The information must be provided for each of 

these categories as appropriate.) 

§§761.180(b)(3)(iii and v) 

• The total number of PCB Transformers, the 

total number of PCB Large High- or LowVoltage Capacitors, the total number of PCB 

Article containers, and the total number of PCB 

Containers in storage at the facility at the 

beginning of the calendar year, received or 

generated at the facility, or disposed of at the 

facility during the calendar year, and remaining 

in storage for disposal at the facility at the end 

of the calendar year. (The information must be 

provided for each of these categories as 

appropriate.) §§761.180(b)(3)(iv and vi) 

The requirement to submit annual reports to the 

EPA RA continues until the submission of the 

annual report for the calendar year during which 

the facility ceases PCB storage or disposal 

operations. §761.180(b)(3)(vii) 

Whenever a commercial storer of PCB waste 

accepts PCBs or PCB Items at his or her storage 

facility and transfers the PCB waste offsite to 

another facility for storage or disposal, the 

commercial storer of PCB waste must initiate a 

manifest for the transfer of PCBs or PCB Items to 

the next storage or disposal facility. 

§761.180(b)(4) 

Inspect annual report for all required 

information. (See left column.) 

If facility has ceased operations, verify 

that an annual report was submitted to 

the EPA RA for the calendar year in 

which the facility ceased operations. 

Verify whether facility has accepted 

PCBs or PCB Items and transferred 

the PCBs or PCB Items to an offsite 

facility for storage or disposal; if so, 

inspect manifests executed pursuant 

to this requirement. 

August 2004 5-96 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Disposers and Commercial Storers of PCB Waste 

For purposes of these requirements, PCB Voltage 

Regulators must be recorded as PCB 

Transformers. §761.180(b)(5) 

5.7.3 Retention of Special Records by Storage and Disposal Facilities 

Regulation Reference: §761.180(f) 

Regulatory Requirements Inspection Procedures 

Retention of Special Records by Storage and Disposal Facilities 

In addition to the information required to be 

collected and maintained under §761.180(b),(c),(d) 

and (e), each owner or operator of a PCB storage 

or disposal facility (including high-efficiency boiler 

facilities) must collect and maintain for three years 

the following data for the time period specified in 

§761.180(b): §761.180(f): 

• All documents, correspondence, and data that 

have been provided to the owner or operator of 

the facility by any State or local government 

agency and that pertain to the storage or 

disposal of PCBs and PCB Items at the facility 

• All documents, correspondence, and data that 

have been provided by the owner or operator of 

the facility to any State or local government 

agency and that pertain to the storage or 

disposal of PCBs and PCB Items at the facility 

• Any applications and related correspondence 

sent by the owner or operator of the facility to 

any local, State, or Federal authorities in regard 

to wastewater discharge permits, solid waste 

permits, building permits, or other permits or 

authorizations such as those required by 

§§761.70(d) and 761.75(c). 

Inspect facility records for all required 

information. 

PCB Inspection Manual 5-97 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.7.4 Certification Program and Retention of Records by Importers and Persons 

Generating PCBs in Excluded Manufacturing Processes 

Regulation Reference: §761.185 

Regulatory Requirements Inspection Procedures 

Certification Program and Retention of Records by Importers and Persons 

Generating PCBs in Excluded Manufacturing Processes 

Manufacturers with processes inadvertently 

generating PCBs and importers of products 

containing inadvertently generated PCBs must 

report to EPA any excluded manufacturing 

processes or imports for which the concentration 

of PCBs in products leaving the manufacturing site 

or imported is greater than 2 μg/g (approximately 2 

ppm) for any resolvable gas chromatographic 

peak. The manufacturers and importers must file 

such reports within 90 days of having processes 

or imports for which such reports are required. 

The reports must contain the following: 

§761.185(a) 

• For manufacturers—the number, type, and 

location of excluded manufacturing processes 

in which PCBs are generated when the PCB 

level in products leaving any manufacturing site 

is greater than 2 Fg/g for any resolvable gas 

chromatograph peak. 

• For importers—the concentration of PCBs in 

imported products when the PCB 

concentration of products being imported is 

greater than 2 Fg/g for any resolvable gas 

chromatograph peak. 

Persons required under this section to report to 

EPA must also certify the following: §761.185(b) 

• Their compliance with all applicable 

requirements of §761.1(f), including any 

applicable requirements for air and water 

releases and process waste disposal. 

Verify whether the manufacturing 

facility or importer has manufactured 

or imported products with PCBs and 

determine the concentration; if greater 

than 2 μg/g, inspect report for all 

required information and verify that it 

was sent to the EPA National 

Chemical Program Division within 90 

days of the commencing of the 

process or importation for which the 

report was required. 

Verify whether the report has been 

properly certified by a companyauthorized person and submitted to 

EPA National Chemical Program 

Division. 

Review the report to verify that the 

following items were certified: 

• Compliance with all applicable 

requirements of §761.1(f) 

(recordkeeping and reporting 

requirements of Subpart J), 

• Whether determinations of 

compliance are based on actual 

monitoring of PCB levels or on 

theoretical assessments, and 

• That such determinations of 

compliance are being maintained. 

August 2004 5-98 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Certification Program and Retention of Records by Importers and Persons 

Generating PCBs in Excluded Manufacturing Processes 

• Whether determinations of compliance are 

based on actual monitoring of PCB levels or on 

theoretical assessments (if the determination 

of compliance is based on a theoretical 

assessment, the letter must also notify EPA of 

the estimated PCB concentration levels 

generated and released). 

• That such determinations of compliance are 

being maintained. 

Any person who reports pursuant to this section: 

§761.185(c) 

• Must have performed either a theoretical 

analysis or actual monitoring of PCB 

concentrations; and 

• Must maintain for a period of 3 years after 

ceasing process operations or importation, or 

for 7 years, whichever is shorter, records 

containing the following information: 

Theoretical analysis—Manufacturers records 

must include the reaction or reactions believed 

to be generating PCBs; the levels of PCBs 

generated; and levels of PCBs released. 

Importers records must include the reaction or 

reactions believed to be generating PCBs and 

the levels of PCBs generated; the basis for all 

estimations of PCB concentrations; and the 

name and qualifications of the person or 

persons performing the theoretical analysis; 

-orActual monitoring—The method of analysis, 

the results of the analysis including data from 

the Quality Assurance Plan, description of the 

sample matrix, name of the analyst(s), date 

and time of the analysis, and numbers for lots 

from which the samples are taken. 

A responsible corporate official must sign the 

certification required by section §761.185(b) in 

accordance with §761.185(d) and (e). 

Verify whether theoretical or actual 

analysis was utilized in determining 

PCB levels in manufactured or 

imported products and that the records 

containing the analysis are being 

maintained for 3 years after ceasing 

process operations or importation, or 

for 7 years., whichever is shorter. 

Verify a responsible corporate official 

properly signed the report. 

PCB Inspection Manual 5-99 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Certification Program and Retention of Records by Importers and Persons 

Generating PCBs in Excluded Manufacturing Processes 

The manufacturer or importer must repeat the 

certification process whenever process conditions 

are significantly modified to make the previous 

certification invalid. §761.185(g) 

Verify the facility records and ensure 

that the certification process is 

repeated whenever process conditions 

are significantly modified to make the 

previous certification no longer valid. 

Obtain information on modifications of 

process conditions. 

5.7.5 Reporting Importers and by Persons Generating PCBs in Excluded Manufacturing 

Processes 

Regulation Reference: §761.187 

Regulatory Requirements Inspection Procedures 

Reporting Importers and by Persons Generating PCBs 

in Excluded Manufacturing Processes 

PCB-generating manufacturing processes or 

importers of PCB-containing products are “excluded 

manufacturing processes” only when the following 

conditions are met: 

• The owner/operator or importer reports to the 

EPA data concerning the total quantity of PCBs 

in product from excluded manufacturing 

processes leaving any manufacturing site in any 

calendar year when such quantity exceeds 

0.0025% of that site's rated capacity for such 

manufacturing processes as of October 1, 

1984; or the total quantity of PCBs imported in 

any calendar year when such quantity exceeds 

0.0025% of the average total quantity of such 

product containing PCBs imported by such 

importer during the years 1978, 1979, 1980, 

1981 and 1982. §761.187(a) 

Compare internal facility reports to 

those submitted to EPA, which can be 

found in the National Chemical 

Program Division database at 

http://www.epa.gov/pcb/data.html, to 

verify that the data reported to EPA are 

correct. 

August 2004 5-100 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Reporting Importers and by Persons Generating PCBs 

in Excluded Manufacturing Processes 

• The owner/operator or importer reports to the 

EPA data concerning the total quantity of 

inadvertently generated PCBs released to the air 

or water from excluded manufacturing 

processes at any manufacturing site in any 

calendar year when such quantity exceeds 10 

pounds. §§761.187(b) and (c) 

5.7.6 Maintenance of Monitoring Records by Persons Who Import, Manufacture, Process, 

Distribute in Commerce, or Use Chemicals Containing Inadvertently Generated 

PCBs 

Regulation Reference: §761.193 

Regulatory Requirements Inspection Procedures 

Maintenance of Monitoring Records by Persons Who Import, Manufacture, Process, 

Distribute in Commerce, or Use Chemicals Containing Inadvertently Generated PCBs 

Persons who import, manufacture, process, 

distribute in commerce, or use chemicals 

containing PCBs present as a result of inadvertent 

generation or recycling or who perform any actual 

monitoring of PCB concentrations must maintain 

records of any such monitoring for a period of 3 

years after a process operation or importation 

ceases, or for 7 years, whichever is shorter. 

§761.193(a) 

Monitoring records must contain the method of 

analysis, results of the analysis, including data from 

the Quality Assurance Plan, description of the 

sample matrix, name of the analyst(s), date and 

time of the analysis, and numbers for the lots from 

which the samples are taken. §761.193(b) 

Verify if monitoring of PCB 

concentrations has taken place; if so, 

inspect monitoring records of all 

required information and retention for 

prescribed time period. 

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Regulatory Requirements and Inspection Procedures Chapter Five 

5.8 PCB Waste Disposal Records and Reports 

5.8.1 EPA Identification Numbers 

Regulation Reference: §761.202 

Regulatory Requirements Inspection Procedures 

EPA Identification Numbers 

A generator of PCB waste shall not: 

• Process, store, dispose of, transport, or offer 

for transportation PCB waste without having 

received an EPA identification number. A 

generator of PCB waste who is exempted from 

notification under §761.205(c)(1) or who 

notifies EPA in a timely manner under 

§761.205(c)(2)(i), but has not yet received a 

unique identification number, shall be regarded 

as having received from EPA the 

identification number “40 CFR PART 761.” 

§761.202(b)(1)(i) 

• Offer the PCB waste to transporters, 

disposers, or commercial storers of PCB 

waste who have not received an EPA 

identification number. §761.202(b)(1)(ii) 

A transporter of PCB waste shall not: 

• Transport PCB waste without having received 

an EPA identification number. 

§761.202(b)(2)(i) 

• Deliver PCB waste to transporters, disposers, 

or commercial storers of PCB waste that have 

not received an EPA identification number. 

§761.202(b)(2)(ii) 

A commercial storer of PCB waste shall not 

accept any PCB waste for storage without having 

received an EPA identification number. 

§761.202(b)(3) 

A disposer of PCB waste shall not accept any 

PCB waste for disposal without having received an 

EPA identification number. A disposer of PCB 

waste who owns more than one disposal facility or 

mobile treatment unit shall not accept waste 

unless the disposer has received an EPA 

identification number for each facility or mobile 

unit. §761.202(b)(4) 

Check National Chemical Program 

Division database records to ensure 

that the generator of PCB waste has 

an EPA identification number. 

Check records to ensure that the 

transporter of PCB waste transported 

waste only after receiving an EPA 

identification number and only 

delivered waste to facilities that had 

EPA identification numbers. 

Check records to ensure that the 

commercial storer of PCB waste has 

an EPA identification number. 

Check records to ensure that the 

disposer of PCB waste has an EPA 

identification number. 

August 2004 5-102 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

EPA Identification Numbers 

Generators (other than generators exempt from 

notification under §761.205(c)(1)), commercial 

storers, transporters, and disposers of PCB waste 

who are required to have EPA identification 

numbers, and who engaged in PCB waste 

handling prior to 2/5/90, are not subject to the 

prohibitions of §761.202(b) if they have applied for 

an EPA identification number. Such persons must 

use "40 CFR Part 761" or a number assigned by 

EPA or a State under RCRA, until EPA or a State 

issues a specific identification number under 

§761.205(a), (b) or (c). §761.202(c) 

If the generator, commercial storer, 

transporter or disposer is handling 

PCBs without an EPA identification 

number, verify that (1) facility was 

handling PCBs prior to 2/5/90, and (2) 

that facility has applied for an EPA 

identification number in accordance 

with §761.205. 

5.8.2 Notification of PCB Waste Activity 

Regulation Reference: §761.205 

Regulatory Requirements Inspection Procedures 

Notification of PCB Waste Activity 

All commercial storers, transporters, and 

disposers of PCB waste who were engaged in 

PCB waste handling activities on or prior to 2/5/90 

shall notify EPA of their PCB waste activities by 

filing EPA Form 7710-53 with EPA by no later than 

4/4/90. §761.205(a)(1) 

All generators (other than generators exempt from 

notification under paragraph (c)(1) of this section), 

commercial storers, transporters, and disposers 

of PCB waste who first engage in PCB waste 

handling activities after 2/5/90, shall notify EPA of 

their PCB waste activities by filing EPA Form 

7710-53 with EPA prior to engaging in PCB waste 

handling activities. §761.205(a)(2) 

Upon receiving the notification form, EPA will 

assign an EPA identification number to each entity 

that notifies. 

Prior to inspection, check National 

Chemical Program Division database 

to verify that the facility filed EPA Form 

7710-53 before 4/4/90. Can also 

check PCB website 

(www.epa.gov/pcb/waste.html) for 

approved facilities. 

Verify that the facility filed EPA Form 

7710-53 before engaging in PCB 

waste handling activities by reviewing 

records. Note: Not all generators 

have to notify; most can use the 

generic identification number for 

manifesting. 

PCB Inspection Manual 5-103 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Notification of PCB Waste Activity 

All of the following information shall be provided to 

EPA on Form 7710-53: §761.205(a)(4) 

• The name of the facility, and the name of the 

owner or operator of the facility 

• EPA identification number, if any, previously 

issued to the facility 

• The facility's mailing address 

• The location of the facility 

• The facility's installation contact and telephone 

number 

• The type of PCB waste activity engaged in at 

the facility 

• Signature of the signer of the certification 

statement, typed or printed name and official 

title of signer, and date signed. 

Generators (other than those generators exempt 

from notification under §761.205(c)(1)), 

commercial storers, transporters, and disposers 

of PCB waste who have previously notified EPA or 

a State of hazardous waste activities under RCRA 

shall notify EPA of their PCB waste activities under 

this part by filing EPA Form 7710-53 with the 

Director of National Chemical Program Division or 

Regional Administrator by no later than 4/4/90. 

The notification shall include the EPA identification 

number previously issued by EPA or the State and 

upon receipt of the notification, EPA shall verify 

and authorize the use of the previously issued 

identification number for PCB waste activities. 

§761.205(b) 

Generators of PCB waste need not notify EPA and 

receive unique EPA identification numbers unless 

their PCB waste activities meet the following 

requirements of §761.205(c)(2). Generators 

exempted from notifying PEA shall use the generic 

identification “40 CFR PART 761." §761.205(c)(1). 

Review Form 7710-53 to verify that all 

of the information was provided and is 

accurate. 

Note that most generators do not have 

to notify and can use the generic 

identification number for manifesting. 

August 2004 5-104 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Notification of PCB Waste Activity 

• Generators of PCB waste who use, own, 

service, or process PCBs or PCB Items shall 

notify EPA of their PCB waste activities only if 

they own or operate PCB storage facilities 

subject to the storage requirements of 

§761.65(b) or (c)(7). Such generators shall 

notify EPA in the following manner: 

§761.205(c)(2) 

- Generators storing PCB waste subject to 

the storage requirements of §761.65(b) or 

(c)(7) shall notify EPA by filing EPA Form 

7710-53 with EPA by no later than 4/4/90. 

- Generators who desire to commence 

storage of PCB waste after 2/5/90 shall 

notify EPA and receive an EPA 

identification number before they may 

commence storage of PCBs at their 

facilities established under §761.65(b) or 

(c)(7). 

- Generators of PCB waste shall submit a 

separate notification to EPA for each PCB 

storage facility they own or operate. Upon 

receiving these notifications, EPA will 

assign generators unique EPA 

identification numbers for each storage 

facility. 

When a facility has previously notified EPA 

(National Chemical Program Division Director or 

RA) of its PCB waste handling activities using EPA 

Form 7710-53 and those activities change, the 

facility must resubmit EPA Form 7710-53 to reflect 

those changes no later than 30 days from when a 

change is made. Examples of when a PCB waste 

handler must renotify EPA include, but are not 

limited to the following: the company changes 

location of the facility; or the company had notified 

solely as engaging in a certain type of PCB waste 

handling activity and now wishes to engage in 

another PCB waste activity (e.g., previously only 

commercially stored PCB waste and now wishes 

to transport PCB waste). §761.205(f) 

Identify whether the facility has 

changed its PCB waste handling 

activities by reviewing Form 7710-53, 

their current manifests, waste storage 

areas, and disposal records. Check 

National Chemical Program Division 

database and PCB website 

(www.epa.gov/pcb/waste.html) to see 

if all are approved in their current 

form. If they have, verify that the 

facility resubmitted Form 7710-53. 

PCB Inspection Manual 5-105 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.8.3 The Manifest - General Requirements 

Regulation Reference: §761.207 

Regulatory Requirements Inspection Procedures 

The Manifest - General Requirements 

A generator who ships by transporting, or offering 

for transport by his or her own vehicle or by a 

vehicle owned by another person, PCB wastes for 

commercial offsite storage or offsite disposal must 

prepare a manifest on EPA Form 8700-22, with a 

continuation sheet if necessary. On the manifest, 

the generator must specify: §761.207(a) 

• For each bulk load of PCBs, identification of 

the PCB waste, the date of removal from 

service for storage and/or disposal, and the 

weight in kg of the PCB waste; 

• For each PCB Article Container or PCB 

Container, the unique identifying number, type 

of PCB waste (e.g., soil, debris, small 

capacitors), date of removal from service for 

storage and/or disposal, and weight in kg of the 

PCB waste; 

• For each PCB Article not in a PCB Container, 

the serial number (if available) or other 

identification number if there is no serial 

number, the date of removal from service for 

storage and/or disposal, and weight in kg of the 

PCB waste in each PCB Article. 

The generator must designate on the manifest one 

offsite commercial storage or disposal facility 

approved for the commercial storage and/or 

disposal of PCBs and PCB Items described on the 

manifest. §761.207(g) 

The manifest that accompanies the PCB waste 

must consist of at least the minimum number of 

copies required to provide the generator, the initial 

transporter, each subsequent transporter, and the 

owner or operator of the designated commercial 

storage or disposal facility with one legible copy for 

each of their records, and one additional copy 

signed by the commercial storage or disposal 

facility and returned to the generator. §761.207(i) 

Inspect manifests for all required 

information, signatures (manifests 

must be maintained as part of the 

facility annual record). Verify that the 

facility has manifests terminated 

(signed) by the storage or disposal 

facility for all shipments of PCB 

waste. 

An inventory sheet should accompany 

the manifest with the appropriate 

number of waste and the out-ofservice date of each piece of 

equipment. 

Verify that the designated storage 

and/or disposal facility listed on the 

manifest is approved under the Part 

761 for the storage and/or disposal of 

the PCBs or PCB Items listed on the 

manifest. 

Verify that the facility is manifesting 

waste using an adequate number of 

manifest copies. 

August 2004 5-106 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

The Manifest - General Requirements 

The requirements of this section apply only to PCB 

wastes as defined in §761.3. This includes PCB 

wastes with PCB concentrations below 50 ppm 

where the PCB concentration below 50 ppm was 

the result of dilution; these PCB wastes are 

required under §761.1(b) to be managed as if they 

contained PCB concentrations of 50 ppm and 

above. An example of such a PCB waste is spill 

cleanup material containing <50 ppm PCBs when 

the spill involved material containing PCBs at a 

concentration of $50 ppm. However, there is no 

manifest requirement for material currently below 

50 ppm which derives from pre-April 18, 1978, 

spills of any concentration, pre-July 2, 1979, spills 

of <500 ppm PCBs, or materials decontaminated 

in accordance with §761.79. §761.207(j) 

PCB Inspection Manual 5-107 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

5.8.4 Manifest Procedures 

Regulation Reference: §761.208 through §761.211 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

Generators of PCB waste—for shipments of PCB 

waste for which a manifest must be executed, the 

generator must: 

• Sign the manifest certification by hand 

• Obtain the handwritten signature of the initial 

transporter and date of acceptance on the 

manifest 

• Retain one copy among its records for at least 

3 years in accordance with §761.209(a) 

• Give to the transporter the remaining copies of 

the manifest that will accompany the shipment 

of PCB waste. §761.208(a)(1) 

For bulk shipments of PCB waste within the U.S. 

transported solely by water, the generator must 

send three copies of the manifest dated and 

signed in accordance with this section directly to 

the owner or operator of the designated 

commercial storage or disposal facility. Copies of 

the manifest are not required for each transporter. 

§761.208(a)(2) 

For rail shipments of PCB waste within the U.S. 

which originate at the site of generation, the 

generator must send at least three copies of the 

manifest dated and signed in accordance with this 

section to the next nonrail transporter, if any, and 

the designated commercial storage or disposal 

facility if transported solely by rail. §761.208(a)(3) 

When a generator has employed an independent 

transporter to transport the PCB waste to a 

commercial storer or disposer, the generator must 

confirm by telephone, or by other means of 

confirmation agreed to by both parties, that the 

commercial storer or disposer actually received 

the manifested wastes. The generator must 

confirm receipt of the waste by the close of 

business the day after they receive the manifest 

copy hand-signed by the commercial storer or 

disposer. §761.208(a)(4) 

Verify that generator of PCB waste is 

in compliance with required 

manifesting procedures. 

If the generator is shipping bulk 

shipments of PCBs via water, verify 

that special requirements for such 

shipments are being met, such as 

sending 3 copies of manifests to the 

owner/operator of the designated 

commercial storage or disposal 

facility. 

If the generator is shipping bulk 

shipments of PCBs via rail, verify that 

special requirements for such 

shipments are being met, such as 

sending 3 copies of the manifest to 

the non-rail transporter, if any, and to 

the storage or disposal facility. 

Verify that the generator has in place 

the required procedures for confirming 

receipt of PCB waste shipments. 

August 2004 5-108 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

If a generator does not receive the copy of the 

manifest hand-signed by the commercial storage 

or disposal facility within 35 days after the 

transporter accepted the PCB waste, the 

generator must telephone, or communicate by 

some other agreed upon means, the disposer or 

commercial storer to determine whether the PCB 

waste has actually been received. If the PCB 

waste has not been received, the generator must 

contact the transporter to determine the disposition 

of the PCB waste. If the generator has not 

received a hand-signed manifest from an EPAapproved facility within 10 days from the date of 

the telephone call or other means of agreed upon 

communication, to the transporter, the generator 

must submit an exception report to the EPA RA for 

the Region in which the generator is located 

pursuant to the requirements of §761.215. The 

generator must retain a written record of all 

telephone or other confirmations to be included in 

the annual document log in accordance with 

§761.180. §761.208(a)(4) 

A generator of PCB waste must keep a copy of 

each manifest signed in accordance with 

§761.208(a)(1) until they receive a signed copy 

from the designated commercial storage or 

disposal facility that received the PCB waste. The 

generator must retain the signed copy of the 

manifest for at least 3 years from the date the PCB 

waste was accepted by the initial transporter. 

Note: A generator subject to annual document 

requirements under §761.180 must retain manifest 

copies for the period of time specified in 

§761.180(a). §761.209(a) 

Transporters of PCB wastes—for shipments of 

PCB waste for which a manifest must be 

executed: 

• A transporter may not accept PCB waste from 

a generator unless it is accompanied by a 

manifest signed by the generator as required 

by §761.208(a)(1). §761.208(b)(1) 

Verify that the generator has in place 

the required procedures for PCB 

waste for which a hand-signed 

terminated manifest is not returned to 

the generator within the specified 

period of time. 

Verify that if such procedures have 

been invoked by the generator, then all 

required records are included in the 

annual document log. 

Verify that the generator has on hand 

all required copies of manifests for 

shipments of PCB waste for storage 

or disposal. For recent shipments 

where the copy from the storage or 

disposal facility has not yet been 

received by the generator, verify that 

the generator has a copy of manifest 

with the generator and transporter 

hand-signed signatures. 

Verify that the PCB waste transporter 

is in compliance with required 

manifesting procedures. 

PCB Inspection Manual 5-109 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

A manifest is not required if any of the following 

conditions exists: 

• The shipment of PCB waste consists solely of 

PCB wastes with PCB concentrations <50 

ppm, unless the PCB concentration <50 ppm 

was the result of dilution, in which case 

§761.1(b) requires that the waste be managed 

as if it contained PCBs at the concentration 

prior to dilution. 

• The PCB waste is accepted by the transporter 

for transport only to a storage or disposal 

facility owned or operated by the generator of 

the PCB waste. 

Before transporting the PCB waste, the transporter 

must sign and date the manifest acknowledging 

acceptance of the PCB waste from the generator. 

The transporter must return a signed copy to the 

generator before leaving the generator's facility. 

§761.208(b)(2) 

The transporter must ensure that the manifest 

accompanies the PCB waste. §761.208(b)(3) * 

A transporter who delivers PCB waste to another 

transporter, or to the designated commercial 

storer or disposer, must: §761.208(b)(4) * 

• Obtain the date of delivery and the handwritten 

signature of the subsequent transporter, or of 

the owner or operator of the designated 

commercial storage or disposal facility 

designated on the manifest. 

• Retain one copy of the manifest in accordance 

with §761.209(b)(1). 

• Give the remaining copies of the manifest to 

the accepting transporter of PCB waste, or to 

the designated commercial storage or disposal 

facility. §761.208(b)(4) 

If the transporter has transported PCB 

waste without an accompanying 

manifest, verify that one or both of 

these conditions existed for the 

shipment shipped without a manifest. 

Review the generator’s manifests to 

verify that the transporter 

acknowledged acceptance of the PCB 

waste and returned the signed copy. 

Review the transporter’s manifests to 

verify that they are properly dated and 

signed. 

August 2004 5-110 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

* Note: These requirements do not apply to 

transporters of bulk shipments by water or rail 

shipment if all of the following applicable conditions 

are met: 

For transporters of bulk shipments by water 

§761.208(b)(5) 

• The PCB waste is delivered by water to the 

designated commercial storage or disposal 

facility. 

• A shipping paper containing all the information 

required on the manifest (excluding EPA 

identification number, generator certification, 

and signatures) accompanies the waste. 

• The person delivering the PCB waste to the 

initial water transporter obtains the date of 

delivery and signature of the water transporter 

on the manifest and forwards it to the 

designated facility. 

• Each water transporter retains a copy of the 

shipping paper or manifest in accordance with 

§761.209(b). 

For shipments involving rail transportation— 

§761.208(b)(6) 

• These requirements do not apply; instead, the 

requirements described at 40 CFR §263.20(f) 

[Rail Transportation of Hazardous Waste] 

apply to rail shipments of PCB waste. 

The transporter must deliver the entire quantity of 

PCB waste accepted from a generator or 

transporter to either the designated commercial 

storage or disposal facility listed on the manifest or 

the next designated transporter of PCB waste. 

§761.208(b)(7) 

If PCB waste cannot be delivered in accordance 

with §761.208(b)(7), the transporter must contact 

the generator for further directions and shall revise 

the manifest and/or return the PCB waste 

according to the generator's instructions. 

§761.208(b)(8) 

Verify that the transporter has in place 

and observes the required procedures 

to comply with the requirements for 

undeliverable shipments of PCBs. 

PCB Inspection Manual 5-111 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

A transporter of PCB waste must keep a copy of 

the manifest signed by the generator, transporter, 

and the next designated transporter, if applicable, 

or the owner or operator of the designated 

commercial storage facility. This copy must be 

retained for at least 3 years from the date the PCB 

waste was accepted by the initial transporter. 

§761.209(b)(1) 

A water (bulk shipment) transporter must retain a 

copy of the shipping paper described in 

§761.208(b)(5)(ii) for a period of at least 3 years 

from the date the PCB waste was accepted by the 

initial transporter. §761.209(b)(2) 

The initial rail transporter shall keep a copy of the 

manifest and the shipping paper required to 

accompany the PCB waste for a period of at least 

3 years from the date the PCB waste was 

accepted by the initial transporter. 

§761.209(b)(3)(i) 

The final rail transporter shall keep a copy of the 

signed manifest, or the required shipping paper if 

signed by the designated facility in lieu of the 

manifest, for a period of at least 3 years from the 

date the PCB waste was accepted by the initial 

transporter. §761.209(b)(3)(ii) 

Commercial storage or disposal facilities receiving 

offsite shipment of PCB wastes for which a 

manifest was executed must: 

• Sign and date each copy of the manifest to 

certify that the PCB waste covered by the 

manifest was received. 

• Note any significant discrepancies in the 

manifest (as defined in §761.210(a)(1)) on 

each copy of the manifest. 

• Give the transporter at least one copy of the 

signed manifest immediately. 

• Send a hand-signed copy of the manifest to the 

generator within 30 days after the delivery. 

• Retain a copy of each manifest among the 

facilities records in accordance with 

§761.209(d). §761.208(c)(1) 

Verify that the transporter is in 

compliance with manifest retention 

requirements. 

Verify that the water (bulk shipment) 

transporter is in compliance with 

manifest retention requirements. 

Verify that the rail transporter is in 

compliance with manifest retention 

requirements. 

Verify that the commercial storage or 

disposal facility is in compliance with 

required manifesting procedures. 

August 2004 5-112 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

If a commercial storage or disposal facility 

receives PCB waste from a rail or water (bulk 

shipment) transporter accompanied by a shipping 

paper containing all of the information required on 

the manifest except the EPA identification 

numbers, generator's certification, and signatures, 

the owner or operator, or her/his agent, must: 

• Sign and date each copy of the manifest or 

shipping paper to certify that the PCB waste 

covered by the manifest or shipping paper was 

received. 

• Note any significant discrepancies in the 

manifest or shipping paper on each copy of the 

manifest or shipping paper. 

• Give the rail or water transporter at least one 

copy of the manifest or shipping paper 

immediately. 

• Send a copy of the hand-signed and dated 

manifest to the generator; however, if the 

manifest has not been received within 30 days 

after delivery, the owner or operator must send 

a copy of the shipping paper signed and dated 

to the generator within 30 days after the 

delivery. 

• Retain at the commercial storage or disposal 

facility a copy of the manifest and shipping 

paper, if signed in lieu of the manifest, in 

accordance with §761.209(d). §761.208(c)(2) 

If the commercial storage or disposal facility 

initiates any offsite shipments of PCB waste, the 

owner or operator of the commercial storage or 

disposal facility must comply with all manifest 

requirements applicable to generators of PCB 

waste. §761.208(c)(3) 

The owner or operator of a PCB commercial 

storage or disposal facility that receives offsite 

shipments of PCB waste shall retain a copy of 

each manifest or shipping paper that the owner or 

operator signs in accordance with §761.208(c)(1) 

or (c)(3). §761.209(c) 

If commercial storage or disposal 

facility accepts PCB waste shipments 

by water (bulk shipment) or rail 

transport, verify that manifesting 

procedures are in place and the 

facility is complying with those 

procedures. 

If the commercial storage or disposal 

facility ships PCB waste offsite, then 

the facility becomes a generator of 

PCB waste for that shipment; verify 

that the facility complies with all 

requirements applicable to 

generators. 

PCB Inspection Manual 5-113 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Manifest Procedures 

Upon discovering a significant manifest 

discrepancy as defined in §761.210(a)(1), the 

owner or operator of the designated commercial 

storage or disposal facility must attempt to 

reconcile the discrepancy with the waste generator 

or transporter. If the discrepancy is not resolved 

within 15 days after receiving the PCB waste, the 

owner or operator must immediately submit to the 

EPA RA for the Region in which the designated 

facility is located a letter describing the 

discrepancy and attempts to reconcile it, and a 

copy of the manifest or shipping paper at issue. 

§761.210(b) 

If, after 4/4/90, a PCB commercial storage or 

disposal facility receives any shipment of PCB 

waste from an offsite source without an 

accompanying manifest or shipping paper (where 

required in place of a manifest), and any part of the 

shipment consists of any PCB waste regulated for 

disposal, then the owner or operator of the 

commercial storage or disposal facility must 

attempt to contact the generator. If the owner or 

operator cannot contact the generator of the PCB 

wastes, he shall notify the RA of the EPA Region in 

which the facility is located. Within 15 days after 

receiving the unmanifested PCB waste, the owner 

or operator must prepare and submit to the EPA 

RA an unmanifested waste report prepared in 

accordance with the requirements of §761.211(c). 

§761.211(a) 

Note: The periods of record retention required by 

§761.209 will be automatically extended during the 

course of any outstanding enforcement action 

regarding the regulated activity. 

Verify that the commercial storage or 

disposal facility has in place and 

complies with the required manifest 

discrepancy procedures. If the 

discrepancy is not resolved within 15 

days, verify that facility submitted a 

letter describing the discrepancy to 

the EPA RA. 

If the facility has ever accepted 

unmanifested waste after 4/4/90, 

verify that an unmanifested waste 

report was prepared and submitted to 

the EPA RA in accordance with 

§761.211. Check Regional records. 

August 2004 5-114 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

5.8.5 Exception Reporting 

Regulation Reference: §761.215 

Regulatory Requirements Inspection Procedures 

Exception Reporting 

A generator must file an exception report with the 

EPA RA if the generator has not received a copy of 

the manifest with the hand-written signature of the 

owner or operator of the designated facility within 

45 days of the date the waste was accepted by the 

initial transporter. The exception report shall be 

submitted to EPA no later than 45 days from the 

date on which the generator should have received 

the manifest. The exception report shall include 

the following: §§761.215(a) and (b) 

• A legible copy of the manifest for which the 

generator does not have confirmation of 

delivery 

• A cover letter signed by the generator or his 

authorized representative explaining the efforts 

taken to locate the PCB waste and the results 

of those efforts. 

A disposer of PCB waste shall submit a One-year 

Exception Report to the EPA RA for the Region in 

which the disposal facility is located no later than 

45 days from the end of the 1-year storage for 

disposal date when the following occurs: 

§761.215(c) 

• The disposal facility receives PCBs or PCB 

Items on a date more than 9 months from the 

date the PCBs or PCB Items were removed 

from service for disposal, as indicated on the 

manifest or continuation sheet. 

• Because of contractual commitments or other 

factors affecting the facility's disposal capacity, 

the disposer of PCB waste could not dispose 

of the affected PCBs or PCB Items within 1 

year of the date of removal from service for 

disposal. 

When inspecting facility records, if it is 

determined that the generator had not 

received a copy of the manifest with 

the hand-written signature of the 

owner or operator of the designated 

facility within 45 days of the date the 

waste was accepted by the initial 

transporter for any waste shipments, 

verify that the generator initiated an 

exception report in conformance with 

all exception report requirements. 

If the disposer of PCB waste was 

required to submit a One-year 

Exception Report to the EPA RA, 

verify that the report was submitted in 

conformance with all exception report 

requirements by reviewing the 

facility’s regional files and facility 

records. 

PCB Inspection Manual 5-115 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Exception Reporting 

A generator or commercial storer of PCB waste 

who manifests PCBs or PCB Items to a disposer 

of PCB waste shall submit a One-year Exception 

Report to the EPA RA for the Region in which the 

generator or commercial storer is located no later 

than 45 days from the date the following occurs: 

§761.215(d) 

• The generator or commercial storer 

transferred the PCBs or PCB Items to the 

disposer of PCB waste on a date within 9 

months from the date of removal from service 

for disposal of the affected PCBs or PCB 

Items, as indicated on the manifest or 

continuation sheet. 

• The generator or commercial storer either has 

not received within 13 months from the date of 

removal from service for disposal a Certificate 

of Disposal confirming disposal of the affected 

PCBs or PCB Items on a date more than one 

year after the date of removal from service. 

The one-year exception report must include: 

§761.215(e) 

• A legible copy of any manifest or other written 

communication relevant to the transfer and 

disposal of the affected PCBs or PCB Items 

• A cover letter signed by the submitter or an 

authorized representative explaining: 

(1) the date(s) when the PCBs or PCB Items 

were removed from service for disposal; 

(2) the date(s) when the PCBs or PCB Items 

were received by the submitter of the report, if 

applicable; 

(3) the date(s) when the affected PCBs or PCB 

Items were transferred to a designated 

disposal facility; 

(4) the identity of the transporters, commercial 

storers, or disposers known to be involved with 

the transaction; and 

(5) the reason, if known, for the delay in 

bringing about the disposal of the affected 

PCBs or PCB Items within 1 year from the 

date of removal from service for disposal. 

If a generator or commercial storer of 

PCB waste who manifests PCBs or 

PCB Items to a disposer of PCB 

waste was required to submit a oneyear exception report to the EPA RA, 

verify that one-year exception report 

was submitted in conformance with all 

one-year exception report 

requirements by reviewing Regional 

records and facility records. 

August 2004 5-116 PCB Inspection Manual 
Chapter Five Regulatory Requirements and Inspection Procedures 

Regulatory Requirements Inspection Procedures 

Exception Reporting 

PCB/radioactive waste that is exempt from the 

one-year storage for disposal time limit pursuant to 

§761.65(a)(1) is also exempt from the exception 

reporting requirements of §761.215 (c), (d), and 

(e). §761.215(f) 

5.8.6 Certificates of Disposal 

Regulation Reference: §761.218 

Regulatory Requirements Inspection Procedures 

Certificates of Disposal 

For each shipment of manifested PCB waste that 

the owner or operator of a disposal facility accepts 

by signing the manifest, the owner or operator of 

the disposal facility must prepare a Certificate of 

Disposal for the PCBs and PCB Items disposed of 

at the facility. The Certificate of Disposal must 

include: §761.218(a) 

• The identity of the disposal facility, by name, 

address and EPA identification number 

• The identity of the PCB waste affected by the 

Certificate of Disposal including reference to 

the manifest number for the shipment 

• A statement certifying the fact of disposal of the 

identified PCB waste, including the date(s) of 

disposal, and identifying the disposal process 

used 

• A certification pursuant to §761.3. 

The owner or operator of the disposal facility must 

send the Certificate of Disposal to the generator 

identified on the manifest which accompanied the 

shipment of PCB waste within 30 days of the date 

that disposal of the PCB waste identified on the 

manifest was completed unless the generator and 

the disposer contractually agree to another time 

frame. §761.218(b) 

The disposal facility must keep a copy of each 

Certificate of Disposal among the records that it is 

required to retain under §761.180(b). §761.218(c) 

Verify that the disposal facility is in 

compliance with all Certificate of 

Disposal requirements. 

Check disposal facility records for 

dates the facility sent manifests to 

generators. Compare these to the 

dates of disposal on the Certificates of 

Disposal. If over 30 days, ask facility 

whether it had an agreement to use 

another time frame. Obtain a copy of 

the agreement if possible. 

Verify that the disposal facility has 

retained copies of all Certificates of 

Disposal as required. 

PCB Inspection Manual 5-117 August 2004 
Regulatory Requirements and Inspection Procedures Chapter Five 

Regulatory Requirements Inspection Procedures 

Certificates of Disposal 

Generators of PCB waste must keep a copy of 

each Certificate of Disposal that they receive from 

disposers of PCB waste among the records they 

retain under §761.180(a). §761.218(d)(1) 

Commercial storers of PCB waste must keep a 

copy of each Certificate of Disposal that they 

receive from disposers of PCB waste among the 

records they are required to retain under 

§761.180(b). §761.218(b)(2) 

Verify that the generator facility has 

retained copies of all Certificates of 

Disposal as required. 

Verify that the commercial storage 

facility has retained copies of all 

Certificates of Disposal as required. 

August 2004 5-118 PCB Inspection Manual 
Chapter Six Sampling 

Chapter Six 

Sampling 

Page 

6.0 Sampling ............................................................ 6-1

6.1 Sampling Guidelines ................................................... 6-1

6.2 Priorities for Sampling .................................................. 6-2

6.3 Sample Collection ..................................................... 6-5

6.3.1 Sampling Collection Indicators ............................................ 6-5

6.3.2 Sampling Plan ........................................................ 6-5

6.3.3 Standard Operating Procedures .......................................... 6-6

6.3.4 Personal Protective Equipment ........................................... 6-6

6.3.5 Suggested Sampling Equipment .......................................... 6-7

6.4 General Considerations for Sampling ...................................... 6-8

6.4.1 Samples: Number and Volume ........................................... 6-9

6.4.2 Sample Preservation .................................................. 6-10

6.4.3 Safety Procedures .................................................... 6-10

6.5 Sample Documentation ................................................ 6-11

6.5.1 Documentation of Precision and Accuracy ................................. 6-12

6.5.2 Chain-of-Custody ..................................................... 6-12

6.5.3 Sample Identification .................................................. 6-14

6.5.4 Sample Seal ......................................................... 6-14

6.6 Sampling Strategies ................................................... 6-15

6.7 Sampling Hazardous Materials .......................................... 6-29

Tables 

Table 6-1. Sampling Priority Table ............................................. 6-3

Table 6-2. Suggested Sample Volumes from Inspectors and Program Office

based on Sample Type ............................................. 6-9

Table 6-3. Guidance for Sampling Transformers, Heat Transfer Systems, and

Hydraulic Systems ............................................... 6-16

Table 6-4. Guidance for Sampling Barrels and Drums ............................ 6-17

Table 6-5. Guidance for Sampling Drip Pans and Puddles ......................... 6-18

Table 6-6. Guidance for Surfaces Sampling .................................... 6-19

Table 6-7. Guidance for Destructive Sampling (defined in glossary) ................. 6-20

PCB Inspection Manual 6-i August 2004 
Sampling Chapter Six 

Table 6-8. Guidance for Sampling Surface Soil and Gravel ........................ 6-21

Table 6-9. Guidance for Taking Soil Core Samples ............................... 6-22

Table 6-10. Guidance for Sampling Water ....................................... 6-23

Table 6-11. Guidance for Sampling Vegetation ................................... 6-26

Table 6-12. Composite Sampling .............................................. 6-27

Table 6-13. Other Types of Sampling .......................................... 6-28

Table 6-14. Sample Site Selection ............................................. 6-29

August 2004 6-ii PCB Inspection Manual 
Chapter Six Sampling 

6.0 Sampling 

6.1 Sampling Guidelines 

Inspectors should consider sampling for analysis an integral part of any PCB-related inspection. 

The purpose of sampling is to verify the presence and concentration of PCBs. Since it is 

impractical to sample everything that might contain PCBs, EPA has established sampling 

guidelines intended to assist the inspector in making sampling determinations. These guidelines 

set out general principles for sampling and prioritize the types of situations in which inspectors 

should undertake sampling. The wide variety of field situations an inspector can encounter 

make it impractical to specify in advance exactly when the inspector should or should not take 

samples. In addition, sampling policies may vary among the Regions. Considering the 

guidelines below and Region-specific policies, the inspector must make this determination. 

1. Take a sample whenever one is needed to prove a potential violation. 

This means obtaining a sample of any material that the inspector needs to verify as 

containing PCBs. Sample results eliminate any uncertainty concerning whether or not 

the material at issue is a PCB. 

2. Sample only when there is reason to suspect PCB presence. 

Unless there is some reason to believe that PCBs are present, there is little likelihood of 

finding them through indiscriminate sampling. These general rules ensure the best case 

preparation in all instances, but they are sometimes impractical to observe: 

! On many inspections, an inspector would need to take a very large number of samples, 

resulting in an unduly long inspection and an unreasonable backlog of sample analyses. 

! In some instances, it is not possible or advisable for an inspector to take a sample. For 

example, inspectors usually cannot sample transformers on poles, and should never 

sample energized transformers. 

3. Verify the presence of PCBs by sampling and other means. 

The most common sources of such verification are the company's records, nameplate 

or label information, and statements by company representatives. Such sources may be 

contested, but experience to date indicates that they usually are not. Therefore, 

sampling becomes less important when there is other evidence of the presence of 

PCBs. 

PCB Inspection Manual 6-1 August 2004 
Sampling Chapter Six 

4. Always be sure that a laboratory is available and capable of providing reliable and 

defensible analyses within the necessary time frame . 

Verify with the laboratory prior to taking unusual samples or when anticipating the collection 

of an unusually large number (>10) of samples as part of an inspection or investigation. The 

laboratory should use an appropriate standard operating procedure (SOP) in conducting the 

analysis. 

6.2 Priorities for Sampling 

The following table lists the order of priority for taking samples. These priorities are based on 

the following: 

! Potential exposure presented by the suspected violation 

! Extent of the potential violation 

! Need for independent proof of the presence of PCBs. 

August 2004 6-2 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-1. Sampling Priority Table 

(Level 1 is the highest priority, Level 7 is the lowest) 

DISPOSAL VIOLATIONS 

Level 1: Improper disposal (including leaks and spills) 

MAJOR USE, STORAGE, MARKING, OR RECORDKEEPING VIOLATIONS 

Level 2: Items bearing no indication of PCB content that are suspected to contain PCBs 

! Transformers 

! Large containers 

! More than ten 55-gallon drums 

Level 3: Items claimed to be decontaminated that are suspected to contain PCBs 

! Transformers 

! Large tanks 

Level 4: Other items claimed to be decontaminated that are suspected to contain PCBs 

Level 5: Other unmarked or unidentified items that are suspected to contain PCBs 

MAJOR STORAGE OR RECORDKEEPING VIOLATIONS 

Level 6: Items bearing a mark or indication of PCB content when the concentration is 

unknown. 

! Transformers 

! Large tanks 

! More than ten 55-gallon drums 

Level 7: Other items bearing a mark or indication of PCB content 

The highest sampling priority is to prove disposal violations because they result in direct 

environmental contamination and present the highest risk of human exposure. 

! Level 1 includes sampling in all instances of improper disposal, including leaks and 

spills, with priority for potential exposure to the public or potential to contaminate water, 

food, or feed. 

The next four levels involve major use, storage, marking, or recordkeeping violations. These 

violations are grouped together because they often occur together. 

! Level 2 calls for sampling in situations involving large amounts of material for which 

there is no independent proof of the presence of PCBs. These situations involve a risk of 

extensive environmental harm and require solid evidence. 

! Level 3 calls for sampling in situations where large numbers of items are claimed to be 

decontaminated. Although these situations pose a lower risk of environmental harm, 

PCB Inspection Manual 6-3 August 2004 
Sampling Chapter Six 

there is a need for solid evidence because companies are likely to dispute claims of PCB 

presence. 

! Level 4 involves sampling other items claimed to be decontaminated. The need for 

evidence is high, but the risk of environmental harm is less than in Level 3, since the 

amount of material involved will be smaller. 

! Level 5 calls for the sampling of unmarked items suspected of containing PCBs. 

Although there is a strong need for evidence in such cases, the risk of harm is lower 

because smaller amounts of PCB materials will usually be involved. 

The last group of priorities concerns situations where major storage or recordkeeping violations 

are suspected involving items that bear some indication of PCB content (such as a label). 

Sampling establishes concentration levels for determining compliance/noncompliance and the 

extent of the violation for penalty purposes. 

! Level 6 calls for sampling in situations where the risk of potential harm is high due to the 

large amount of PCB material. 

! Level 7 includes sampling in situations involving smaller amounts of PCB material. 

Sampling is usually necessary where there is reason to determine compliance/noncompliance 

with the ban on unauthorized manufacture, process, distribution in commerce, or use of PCBs. 

Experience to date indicates that these violations are not usually encountered in routine 

inspections. Therefore, these violations are not included in the priority list. Because of the 

seriousness of such violations, the inspector should design in advance, in consultation with the 

appropriate EPA personnel to include EPA Headquarters, a sampling plan to document 

compliance/noncompliance. 

Sampling is not required, in general, for situations involving only minor storage, marking, or 

recordkeeping violations. In these instances, independent evidence of PCB presence, either 

through records or marking, will usually exist. Moreover, the risk posed by these situations will 

usually be relatively small. Unusual circumstances sometimes will necessitate sampling in 

such cases. For example, the suspected violator may: 

! Refuse access to records that would indicate PCB presence. 

! Refuse to answer questions that would indicate PCB presence. 

! Indicate, through past behavior or statements made to the inspector, reluctance to come 

into compliance. 

Such actions indicate a need for more comprehensive evidence. The decision whether or not to 

sample in such situations rests with the inspector. 

August 2004 6-4 PCB Inspection Manual 
Chapter Six Sampling 

6.3 Sample Collection 

The first step in any sample collection program is to determine the purpose of obtaining a 

sample for laboratory analysis. Samples collected for determining the PCB level of possible 

contaminated solvents or for establishing whether a transformer with unidentified dielectric fluid 

contains PCBs will require different sampling considerations than samples collected to confirm 

spills of PCBs or to identify the extent of PCB contamination of soil, surface water, or 

groundwater resulting from spills or improper disposal. 

6.3.1 Sampling Collection Indicators 

Inspectors should generally obtain samples when direct physical evidence indicates that 

contamination has taken place. Sample collection is in order when: 

! Leaking PCB articles or equipment are present. 

! Discoloration of soil adjacent to in-service or stored PCB articles, equipment, or 

containers is present. 

! Oil films, sheens, or sheets in standing water or on banks of nearby streams is present. 

! Soils are highly saturated and groundwater contamination from PCB leakage is 

suspected. 

! The facility improperly stores PCB materials, such as rags and other debris. 

! There is reason to believe PCBs are present in unmarked or improperly stored articles. 

! Dead or stressed grass or other vegetation is present. 

When sampling spills and/or leaks near equipment, the inspector should sample both the spill 

area and the equipment to verify the source of the PCB contamination unless a PCB mark or 

nameplate identifies the equipment as containing PCBs. 

6.3.2 Sampling Plan 

An effective sample collection program includes the development of a sample plan that is 

consistent with the requirements of the Region’s quality assurance plan and contains at least the 

following items: 

! An overall evaluation of the facility based on records of previous inspections and onsite 

observations 

! An evaluation of the risk to sampling personnel 

! Identification of proper equipment and procedures for safe, effective sampling 

! Laboratory availability, capacity, capability, and reliability 

PCB Inspection Manual 6-5 August 2004 
Sampling Chapter Six 

! Identification of representative sampling sites (properly identified photographs are helpful) 

! Procedures to collect sufficient volumes of the PCB mixtures, water, soil, or sludge to 

carry out the required analyses 

! Procedures to preserve samples to maintain sample integrity (refer to sampling guidance 

tables at the end of this chapter) 

! Proper labeling of the sample containers (including the exact location where the sample 

was taken) 

! Procedures for identifying and handling potentially hazardous samples (PCBs in other 

hazardous substances) 

! Procedures for maintaining and documenting chain-of-custody. 

Inspectors should record the time, date, location, type of sample, sampling method, and reasons 

for obtaining the sample in their field logbook at the time of sample collection and, if possible, 

photograph the sampled area. If it is impossible to take photographs, the inspector should draw 

or sketch the contaminated area including a reference point. The drawing should indicate where 

the inspector takes any samples. Specific procedures for collecting PCB samples are detailed 

below. 

6.3.3 Standard Operating Procedures 

Specific regional procedures may exist on the collection of routine samples to ensure 

consistency and reconstructability, as well as serving as a training guide for new inspectors. 

Generally, these procedures take the form of SOPs. The inspector should review pertinent 

SOPs prior to the inspection. 

6.3.4 Personal Protective Equipment 

The inspector may take the following personal protective equipment to an inspection and 

sampling site depending on the situation. Please note that all equipment may not be available or 

necessary depending on the inspection type. 

! Full face, air purifying, negative pressure respirator with organics cartridge(s) 

! Disposable PCB-resistant gloves 

! Disposable footwear covers 

! Safety glasses with side shields or goggles 

! Disposable full-body coveralls impervious to PCBs 

August 2004 6-6 PCB Inspection Manual 
Chapter Six Sampling 

! Hard hat 

! Safety shoes/boots 

! First-aid kit 

! Other safety equipment specified by EPA and facility safety officers. 

6.3.5 Suggested Sampling Equipment 

The validity of PCB samples depends upon the integrity of sampling equipment. The following 

guidelines should be observed: 

! Use appropriate containers. 

- Inspectors should use glass vials, bottles, or jars with Teflon-lined lids as 

sample containers. If cap is not Teflon-lined, cover vial, bottle, or jar with 

solvent-rinsed aluminum foil and cap. Do not use plastic as a primary 

container for PCB samples. PCBs will absorb in most plastics and can 

contaminate samples with plasticizers; however Teflon/Tedlar plastic 

bags can be used in place of poly or vinyl plastic. 

- An inspector may use new containers without additional treatment for 

samples where only PCB concentrations at or above 1 ppm are of 

concern. Keep the lids in place during storage and travel to the field. Do 

not reuse sample containers. 

- If the data objective is PCB concentration of less than 1 ppm, then clean the primary 

sample container with three rinses of acetone followed by three rinses of hexane. It 

is preferable that the laboratory that will conduct the analysis performs this rinsing. 

! Prepare a field blank, which is an empty capped (and officially sealed) container of each 

type used in a sampling exercise, and submit it to the laboratory as a quality control 

check. Take this empty container to the sampling site, but do not uncap it. For surface 

samples, submit as a control a piece of the swabbing material, treated with the solvent 

used, in a vial or bottle. 

! Choose from the following list of equipment customarily used to sample for PCBs: 

- Glass tubing or coliwassa samplers (solvent rinsed)

- Glass pipettes, with squeeze bulbs

- Disposable 10 ml pipettes and bulbs

- Extra clean sample jars for scooping 

- Eye droppers

- Aluminum foil

- Container of solvent (hexane is recommended)

- Pharmaceutical grade gauze pads (3" x 3")

PCB Inspection Manual 6-7 August 2004 
Sampling Chapter Six 

- Stainless steel forceps (several) 

- Stainless steel or disposable cardboard templates (10 cm x 10 cm) 

- Stainless steel trowels, or Teflon scoops 

- Laboratory spatulas (precleaned) 

- Soil coring devices (such as King-tube samplers, piston corers, or bulb planters) 

- Flashlight 

- Hammer and chisel 

- Hole saw and drill 

- Pruning shears 

- Precleaned stainless steel buckets 

- Disposable wiping cloths 

- Plastic disposal bags 

- Plastic secondary container bags and official seals 

- Survey stakes 

- 100 ft tape measure 

- Ice chests containing ice or ice packs and secured with padlocks (if required by the 

laboratory) 

- Compass and maps 

- Duct tape 

- Subsurface water sampling equipment (such as pumps, siphons, and glass 

sampling jars with attachments)

- Container of distilled water

- Stainless steel mixing bowls and spoons

- Peterson dredge, Ekman dredge, weighted bottom dredge

- 1/4" sieves

- Adjustable wrench or channel lock pliers

- Chain-of-custody forms

- Sample labels

- Evidence tape

- Indelible markers.

! Take an adequate number of sampling tools (whether disposable or not) to each

inspection site to avoid having to decontaminate such implements in the field.

! Notify the laboratory receiving the samples prior to the inspection to ensure availability of 

necessary analytical support. 

6.4 General Considerations for Sampling 

To minimize the likelihood of PCB spills and health hazards during sampling, the inspector 

should: 

! Avoid contamination of the outside of the sample container. 

! Ensure that the cap is tightly affixed. 

! Wipe stop cocks, hard surfaces, etc., when sampling is complete. 

August 2004 6-8 PCB Inspection Manual 
Chapter Six Sampling 

! Dispose of all contaminated sampling equipment or store the equipment for

decontamination.

The inspector should try to minimize the risk of cross-contamination at all times to protect 

sample containers. If glass tubing or dipping vessels are used to collect a sample, the inspector 

should use a separate clean unit for each sample and should not co-store samples suspected 

of containing greater than 50 ppm with environmental samples where less than 1 ppm is of 

interest. 

Inspectors should not use tools (e.g., adjustable wrenches or channel lock pliers) on any of the 

facility’s equipment. If necessary, the inspector should request that the facility representative 

use the facility’s tools (e.g., to open a transformer drain cock). 

6.4.1 Samples: Number and Volume 

The inspector should prepare a field blank for each type of container used to collect samples 

and submit it to the laboratory as a quality control check. The inspector should also collect one 

duplicate sample for every ten samples collected. 

Collect a sufficient volume of each sample obtained to perform all the required PCB analyses 

and to provide for any quality control needs, split samples, or repeat testing. The size of the 

sample depends on the type of material and the analyses to be performed. Suggested amounts 

required for each sample type are listed below. 

Table 6-2. Suggested Sample Volumes from Inspectors and 

Program Office based on Sample Type 

Sample Type Required 

Volume 

Transformer oil and other 100 ml 

homogeneous PCB mixtures (i.e., 

hydraulic oil or heat transfer oil) 

Nonhomogeneous PCB mixtures, 3 x 25 ml - 35 ml 

including waste oil 

Soil, sludge, sediment Approximately 250 g (1⁄2 lb) 

Water 4 L 

Water-oil mixtures 3 x 100 ml 

Solid PCB mixtures 3 x 50 g 

(nonhomogeneous, e.g., pigments) 

Surfaces 3 cm x 10 cm x 10 cm areas 

PCB Inspection Manual 6-9 August 2004 
Sampling Chapter Six 

The inspector may collect the lower sample volume for uses where the target level is in the 50 

ppm or greater range. Collect larger volumes where samples will be analyzed to identify 

environmental levels (1 ppm). The inspector should consult the laboratory in such cases. 

The inspector may encounter some situations (e.g., condensate in natural gas lines or residual 

oil from drained drums) where the recommended sample size is not available; in these cases, 

the inspector should sample as feasible. 

6.4.2 Sample Preservation 

PCBs are normally stable in oil, soil, and surface samples, but the laboratory may require some 

or all of the following sample preservation procedures. To minimize the effects of temperature, 

pH, and bacterial action, protect all samples from high temperatures and sunlight. Keep water 

and other environmental samples (target levels < 1 ppm) below 4EC. Arrange for freezing of all 

soil, surface, and vegetation if lengthy storage periods are necessary before transfer to the 

laboratory. According to 40 CFR 136.3, the maximum holding time for samples to be analyzed 

for PCBs is seven days until extraction and 40 days after extraction. 

6.4.3 Safety Procedures 

The inspector should observe all facility safety requirements. In addition, the inspector should 

take special precautions, including the following, to avoid contact with PCBs or exposure to the 

fumes from hot PCBs: 

! Wear clean or new disposable PCB-resistant gloves, coveralls, and safety goggles while 

taking samples suspected to contain PCBs. 

! Wear disposable shoe covers when entering areas known or suspected to be 

contaminated with PCBs. 

! Dispose of gloves, shoe coverings, and other disposable protective garments in a plastic 

bag after use. Final disposition of these items should be the same as for PCBs. 

! Do not enter an area where there is an odor of fumes, solvents, or PCBs, unless wearing 

a full-face canister-type respirator. 

! Ask facility personnel to obtain a sample, if required, from transformers. Observe and 

fully document the entire sample collection procedure. Photograph activities if possible. 

! Do not attempt to obtain samples from transformers that are in operation or service. 

August 2004 6-10 PCB Inspection Manual 
Chapter Six Sampling 

! Ask facility personnel to obtain a sample, if required, from operating heat transfer 

systems. Have the liquid drained directly into the sample bottle, and leave the bottle open 

until cool enough to handle. 

! Do not insist on samples of transformer or heat transfer system liquids if the facility is 

uncooperative, or if the sampling expertise is not available, but note in the report the 

problem and the reason for requesting a sample. 

! Observe the safety regulations of the facility. 

! Note that PCBs may pose a greater risk to pregnant women and nursing mothers. 

! Leave power substations immediately when raining/lightning. 

Treatment for PCB Contact with Skin 

PCBs on the skin are likely not particularly hazardous if washed off within one-half hour. 

! Do not touch and contaminate food or drink. 

! Clean PCBs off skin and dispose of the wiping material as PCBs. 

! Wash with soap and water. 

! If PCBs get into the eyes, flush with water for several minutes and get immediate 

medical attention. 

! If skin is blistering or symptoms of chloracne occur, see a physician immediately. 

Polychlorinated dibenzofurans are possible components of some PCB mixtures 

and may cause these symptoms. 

6.5 Sample Documentation 

Sample documentation procedures include the means of establishing both chain-of-custody and 

the precision, accuracy, and representativeness of the samples. The procedures discussed 

below cover the basic elements that should be a part of all sample documentation procedures 

for PCB inspections. Inspectors should also become familiar with any additional or different 

documentation procedures required by their Regional office. These procedures are designed to 

assure that an inspector will be able to testify that a particular sample was drawn from a 

particular location at a particular time, describe the procedures that were used to obtain the 

sample, and explain how the integrity of the sample was secured. 

PCB Inspection Manual 6-11 August 2004 
Sampling Chapter Six 

6.5.1 Documentation of Precision and Accuracy 

Field Measurement and Sampling Process. The inspector should follow the Region’s quality 

assurance project plan (QAPP) for collecting and handling samples and performing field 

measurements in the sampling process. The inspector uses the field logbook to record the 

procedures undertaken during sampling. The documentation should identify: 

! Type of sample matrix 

! Exact location where each sample was collected 

! Types of sample containers used for each parameter or group of parameters 

! Sample container preparation process 

! Sample collection process 

! Sample preservation and handling 

! Type and frequency of calibration and maintenance of field analytical procedures 

! Calibration and maintenance of field instruments 

! Identification and documentation of samples 

! Custody of samples collected 

! Decontamination of sampling equipment 

! Date and time when each sample was collected. 

6.5.2 Chain-of-Custody 

The purpose of chain-of-custody procedures is to be able to trace possession of a sample from 

the time it was collected until the time it is introduced as evidence in a legal proceeding. Case 

development personnel should be able to demonstrate that none of the samples involved have 

been tampered with or contaminated during collection, transit, storage, or analysis. The various 

handlers should maintain an accurate written record to trace the possession of each sample 

from the moment of collection through its introduction as evidence. The concept of custody 

requires the maintenance of several procedures to ensure the authentication of the sample. 

These procedures begin with the identification of the sample and continue through the laboratory 

analysis process. 

! Establishing Custody. Sample custody is initiated at the time of collection by sealing the 

sample with an official seal. The inspector should place evidence tape onto the sample 

and initial and date the tape in ink/waterproof pen. 

! Preparing Sample Documentation. The inspector and lab personnel must prepare the 

documentation. Properly maintained, this documentation will serve as a clear and 

complete account indicating that the sample offered into evidence was the same one that 

was collected. 

August 2004 6-12 PCB Inspection Manual 
Chapter Six Sampling 

The documentation includes the entries in the inspector's field logbook, the Official 

Sample Seal, and the Chain-of-Custody Record (see Appendix O for blank sample seals 

and a Chain-of-Custody Record). The inspector needs to assure that the relationship 

between the physical sample and the related documentation is clear, complete, and 

accurate. The sample number, date, and inspector's initials should appear on all 

documents, and the inspector should fully and accurately complete all forms. 

! Ensuring custody during transit. Shipment of samples to the laboratory should involve 

the following procedures: 

- Samples must be accompanied by the Chain-of-Custody Record. The originator 

retains copies of documents. 

- If sent by common carrier, the inspector must obtain and keep a bill of lading. 

- The inspector must keep all receipts and shipping documents and include them in 

the Chain-of-Custody documentation. 

! Initiating Chain-of-Custody Record. Inspectors initiate the process that controls and 

records access to the sample once it has left their possession by filling out the Chain-ofCustody Record. The sample number relates the sample to the Chain-of-Custody 

Record which accompanies the sample through all the processing stages. 

! Field Logbook Entry. The inspector's entry in the field logbook is the principal reference 

for the sample. Note this record may be maintained electronically such as in a PC tablet. 

The following information should be included about each sample collected: 

- Sample identification number 

- Any other unique identifying marks on the container 

- Date and time of collection 

- Type of matrix (e.g., oil, sludge, sediment, etc.) 

- Description of specific location of collection 

- Collection method (should include collection equipment; field analytical equipment; 

and all calculations, results, and calibration data for field sampling analytical and 

physical measurement equipment. All sampling and field analyses must be traceable 

to the type of equipment used and the inspector who did the work.) 

- Rationale for selecting the sample and representativeness considerations 

- Description of any deviations from standard protocols 

- A note regarding provision to the facility of duplicate or split samples, if appropriate. 

PCB Inspection Manual 6-13 August 2004 
Sampling Chapter Six 

6.5.3 Sample Identification 

Tag each sample container immediately upon collection with a standard EPA sample tag. In 

some cases, particularly with biological samples such as vegetation, the tag may have to be 

included with or wrapped around the sample. Fill out appropriate sample tag and/or field data 

sheet. 

The following basic considerations govern identification of samples: 

! Use one sample number for each sample. Assign only one number to one sample 

consisting of several subsamples or units. 

! Inspectors may seal subsamples in a single bag if they are part of one sample and if 

adequate packaging protection is provided. 

! The inspector must include sample numbers on all documentation relating to a sample: 

official seals, Chain-of-Custody Records, drawings, or photographs. 

6.5.4 Sample Seal 

Once the inspector collects and tags the sample, the inspector should place its container inside 

a plastic bag. The inspector should first write her/his name or initials and the date on the bag 

and then turn the bag inside out to prevent any means of tampering with its contents. Place the 

sample inside the inverted bag, then tape it closed in a secure manner with the Official Sample 

Seal (EPA Form 7500-2). Blank sample seals are provided in Appendix O. Seal the sample 

container or wrapper so that it may not be opened at any point without breaking the seal and/or 

the original unit package. Do not seal more than one sample under one seal. The inspector 

may choose to use evidence tape as well. If it becomes necessary to break a seal, mount the 

seal on a piece of paper, properly initial and date it, and submit it with sample records to provide 

a continuous history. Reseal the sample with a new seal. 

If the company declares a physical sample as confidential business information (CBI), the 

inspector should mark the seal "Confidential Business Information". Transfers of TSCA CBI 

must be conducted through the facility’s DCO, in accordance with the following procedures: 

! Inspectors may not deliver samples to a laboratory. Samples can only be mailed by: 1) 

inspectors cleared by the TSCA CBI DCO (this is on a case-by-case basis) to deliver 

samples/documents, or 2) by inspectors who are TSCA CBI DCO’s. 

! Inspectors must take the samples to their regional TSCA CBI DCO, who can deliver the 

samples to a CBI cleared laboratory for analysis. 

For more details on how to transfer CBI materials, please refer to the TSCA Confidential 

Information Security Manual. 

August 2004 6-14 PCB Inspection Manual 
Chapter Six Sampling 

6.6 Sampling Strategies 

EPA has developed guidance related to sampling strategies for 761 Subparts M, O, P, and R. 

This guidance provides an excellent source for inspectors developing a sampling strategy. The 

guidance is titled Sampling Guidance for 40 CFR 761 Subparts M, O, P and R and is available 

at http://www.epa.gov/pcb/guidance.html. The following tables provide additional information on 

sampling strategies. 

PCB Inspection Manual 6-15 August 2004 
Sampling Chapter Six 

Table 6-3. Guidance for Sampling Transformers, 

Heat Transfer Systems, and Hydraulic Systems 

CAUTION: Do not sample electrically live transformers or systems by yourself. If samples 

are required, experienced facility personnel should take them in the presence of the inspector 

and should use the facility’s, not the inspector’s, tools. The inspector should fully witness and 

document the procedures followed in obtaining these samples. 

Equipment ! PPE - Disposable coveralls, footwear covers, safety goggles and 

disposable PCB-resistant gloves (one pair per sample) 

! 40 ml volatile organic analysis (VOA) vials with Teflon (TFE)-lined 1 ml 

caps 

! Secondary sample container bags, custody seals, and custody forms 

! Disposable wiping clothes 

! Plastic disposal bags 

! Container labels and indelible pens 

! Flashlight 

! Disposable 10 ml pipettes and bulbs 

! Extra clean sample jars for scooping. 

Site Selection ! A sample from a transformer or system drain cock is assumed to be 

representative of the entire system. 

Sampling ! Transformer drain cock * 

Points ! System drain cock * 

! Expansion tank drain cock * 

! Reservoir tank (hydraulic system) 

Note: (1) Hydraulic fluid may also be sampled from barrels in storage 

or from drip pans and puddles. 

(2) De-energized transformers may be sampled by unlocking 

the top cover or opening the refilling port. 

Volume ! 25 - 35 ml 

Procedures ! Use the PPE listed above. 

! Have the facility personnel open the drain cock because it may be 

difficult to reclose. 

! Drain 25 - 35 ml into the container. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.** 

! Wipe spills from the sampling point. 

! Place contaminated equipment in a plastic bag for disposal or 

decontamination. 

*

 Beware drain cocks may be difficult to reclose. 

** Placing samples in an ice chest is recommended when dealing with PCBs. 

August 2004 6-16 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-4. Guidance for Sampling Barrels and Drums 

Since pure PCBs and chlorinated solvents used to dilute PCBs in electrical fluids are heavier 

than water, these materials will sink in water. However, PCBs in petroleum solvents as 

waste oils or rinsing solutions will be lighter than water and will float. For this reason, to the 

degree possible, drums of liquids suspected of containing PCBs should be representatively 

sampled from the top to the bottom. 

Equipment ! PPE - Disposable coveralls, disposable PCB-resistant gloves (one pair 

per sample), footwear covers, and respiratory protection 

! New glass tubing or coliwassa sampler 

! Suitable size glass bottles with TFE-lined caps (new containers may 

be used as received) 

! Secondary sample container bags, official seals, and custody forms 

! Sample labels and indelible pens. 

Volume ! As appropriate to the volume of the sample. Collect three samples 

from the drum, if nonuniformity is evident. 

Procedures ! Use the PPE listed above. 

! Open the sample container. 

! Insert the glass sampler into a drum to just above the bottom of the 

drum or until solids are contacted. Allow the sampler to fill as the tub is 

lowered. Cap the sampler. 

! Remove the sampling device. 

! Place the bottom end of the sampler into the sample container and let 

the sample slowly drain by removing the cap. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.* 

! Decontaminate sampling equipment and dispose of the waste. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

PCB Inspection Manual 6-17 August 2004 
Sampling Chapter Six 

Table 6-5. Guidance for Sampling Drip Pans and Puddles 

Drip pans and puddles may be present under equipment drains, barrel stop cocks, etc. 

Equipment ! PPE - Disposable PCB-resistant gloves (one pair per sample), 

disposable coveralls, footwear covers, and safety goggles 

! 40 ml VOA vials with TFE-lined 1 ml caps (new containers may be 

used as received) 

! 25 ml clean glass sample containers (new containers may be used as 

received) 

! Glass pipette and squeeze bulb 

! Eye dropper 

! Clean sampling spatula 

! Secondary sample container bags, custody seal, and custody forms 

! Disposable wiping cloths 

! Plastic disposal bags 

! Sample labels and indelible pens. 

Site Selection ! Obtain a sample from the center of the pan or puddle. 

Volume ! 25 ml (or whatever available, if less). Collect three samples, if the 

liquid is nonhomogenous. 

Procedures ! Use the PPE listed above. 

! Using a pipette, draw approximately 25 ml by means of a squeeze 

bulb. NEVER PIPETTE BY MOUTH. Use a separate pipette for each 

sample. 

! Deposit the sample in a 40 ml VOA vial. Cap the container. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.* 

! Wipe any spills from the sampling point. 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

August 2004 6-18 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-6. Guidance for Surfaces Sampling 

Take wipe samples of any smooth surface that is considered relatively nonporous (e.g., 

metal, glass, or enameled wood). Take destructive samples of hard porous surfaces (e.g., 

cement, brick, asphalt, or bare wood). See also the definition of standard wipe test under 

§761.123. 

Equipment ! PPE - Disposable PCB-resistant gloves (one pair per sample), 

disposable coveralls, footwear covers, and safety goggles 

! Gauze pads (3" x 3" pharmaceutical grade) 

! 40 ml VOA vials with TFE-lined caps (new containers may be used as 

received) 

! Stainless steel forceps 

! Container of hexane (e.g., eyedropper bottle) 

! Steel template or disposable cardboard template (10 cm x 10 cm) 

! Plastic disposal bags 

! Secondary sample container bags, official seals, and custody forms 

! Sample labels and indelible pens 

Site Selection ! If the area of suspected contamination is small, take three co-located 

samples from the center of area, if possible. If large (e.g., a spill site), 

see Sample Site Selection. 

Procedures ! Use the PPE listed above. 

! Identify in the field logbook the size and location of the areas to be 

sampled. Photograph the area, if possible. 

! Dip gauze pad into hexane or wet thoroughly with eyedropper. 

! Using stainless steel forceps or a disposable rubber glove to hold the 

wool or pad, thoroughly swab a 100 cm2 sample area as identified with 

the template. Swab in horizontal direction with one side of the 

swabbing material and repeat in the vertical direction with the other 

side. 

! Place the pad in a clean sample container. Cap the container. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

! At the end of the sampling prepare a control blank by going through the 

entire procedure without swabbing the surface. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

PCB Inspection Manual 6-19 August 2004 
Sampling Chapter Six 

Table 6-7. Guidance for Destructive Sampling (defined in glossary) 

Equipment ! 

! 

! 

! 

! 

! 

! 

! 

! 

Site Selection ! 

Procedures ! 

! 

! 

! 

! 

PPE - Disposable PCB-resistant gloves (one pair per sample),

disposable coveralls, footwear covers, and safety goggles

Full face piece, supplied air (as specified by OSHA regulation 29 CFR

Part 1915)

8 oz glass jars with TFE-lined caps

Hammer, chisel, drill, or hole saws

Clean glass sample bottle

Aluminum foil

Plastic disposal bags

Secondary sample container bags, official seals, and custody forms

Sample containers labels and indelible pens.

If the area of suspected contamination is small, take three samples

from the center. If the area is large (e.g., a spill site), follow the

procedures outlined in Sample Site Selection in this chapter.

Use the PPE listed above.

Remove a sufficient sample for analysis (consult with the laboratory).

Place samples of less than 1 cm in glass sample jars (8 oz) and cap

or solvent-rinsed aluminum foil. Aluminum foil packets should be

identified and placed in a secondary plastic bag.

Identify, officially seal, and log samples. Place samples in an ice

chest.*

Place contaminated equipment into a plastic bag for disposal or

decontamination.

* Placing samples in an ice chest is recommended when dealing with PCBs. 

August 2004 6-20 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-8. Guidance for Sampling Surface Soil and Gravel 

Equipment ! PPE - Disposable PCB-resistant gloves (one pair per sample), 

disposable coveralls, footwear covers, and safety goggles 

! Disposable or cleaned aluminum or Teflon scoop (washed with soap 

and water, rinsed with distilled water, acetone and hexane, and 

wrapped in aluminum foil) 

! 8 oz glass sample containers, with TFE-lined caps (New container 

may be used as received if PCB levels of concern > 1 ppm.) 

! Secondary sample bags, custody seals, and custody forms 

! Plastic disposal bags 

! Stainless steel templates or disposable cardboard template (10 cm x 

10 cm) 

! Sample container labels and indelible pens 

Site Selection ! If the area of suspected contamination is small (less than 10 sq ft), 

collect three samples from near the center of the area. In larger areas 

(e.g., a spill site), follow the procedures outlined in Sample Site 

Selection in this chapter. 

Volume ! 250 grams (approximately 1⁄2 lb) 

Procedures ! Use the PPE listed in Section 6.3.4 of this chapter. 

! Remove foil from the sampler. Scoop to a depth of approximately 1 

cm. 

! Collect three 250 gram samples. Deposit them in a sample container. 

Cap the container. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

PCB Inspection Manual 6-21 August 2004 
Sampling Chapter Six 

Table 6-9. Guidance for Taking Soil Core Samples 

Equipment ! PPE - Disposable PCB-resistant gloves (one pair per sample), 

disposable coveralls, footwear covers, and safety goggles 

! Piston core, bulb planter, hand auger, or King-tube sampler 

! New or clean sample containers of sufficient size to contain a cored 

sample of 5 cm (8 oz glass jar with TFE-lined cap or prepare an 

aluminum field packet) 

! Aluminum foil (solvent-rinsed if environmental levels (< 1 ppm) are of 

concern) 

! Secondary sample bags, custody seals, and custody forms 

! Full face, negative pressure respirator, if necessary, for highly 

contaminated or enclosed area 

! Plastic disposal bags 

! Sample containers labels and indelible pens 

Site Selection ! If the area is small, core samples should be taken at the center and 

edge of the area. In larger areas (e.g., a spill site), follow the 

procedures outlined in Sample Site Selection in this chapter. 

Volume ! Cores of 5 cm should be taken initially. If there is visible contamination 

at the 5 cm level, deeper samples should be taken. Analytical results 

may also indicate the need for deeper samples to be taken later. 

Procedures ! Use the PPE listed in Section 6.3.4 of this chapter. 

! Take at least three surface samples as previously described.* 

! Use the corer to obtain a 5 cm sample. Displace compacted surface 

soil with a trowel or laboratory spatula if necessary. 

! Extrude the sample into hexane-rinsed foil and wrap. 

! Label the top and bottom of the sample. 

! Place the sample in a container. Cap the sample container. 

! Identify, officially seal, and log samples. Store the samples in an ice 

chest.** 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Very high surface concentrations of PCBs may easily contribute to crosscontamination at lower depths during sampling, thus the results of surface sampling 

will indicate this possibility and the need to resample using a more sophisticated or 

careful technique. 

** Placing samples in an ice chest is recommended when dealing with PCBs. 

August 2004 6-22 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-10. Guidance for Sampling Water 

Water sampling requires special attention. Because of the chemical properties of PCBs and 

because other substances may be in the water, PCBs may be present as a surface film 

(particularly when PCBs are dissolved in hydrocarbon oils) or sink to the bottom (particularly 

when PCBs are in askarel or other heavier-than-water materials). When a surface film is 

suspected (or visible), sample the water surface. Otherwise, take the water sample near the 

bottom. 

Equipment ! PPE - Disposable PCB-resistant gloves (one pair per sample), 

disposable coveralls, footwear covers, and safety goggles 

! Cleaned, capped sample containers (4 L bottles or jars with TFE-lined 

caps) 

! Peterson dredge 

! Ekman dredge 

! Weighted bottom dredge 

! 3-gallon hexane-rinsed steel bucket 

! Plastic disposal bags 

! Disposable wiping cloths. 

Volume ! 4 Liters. 

Surface Water Samples 

Site Selection ! Stagnant, standing water (puddles, ponds, impoundments, etc.) 

Procedures ! Use the PPE listed in Section 6.3.4 of this chapter. 

! Slowly lower a tilted wide-mouth sample jar or bottle into the water until 

the water begins to run into it. 

! Slowly turn the bottle upright keeping the lip just under the surface of 

the water so that the whole sample is surface water. 

! Carefully lift the bottle out of the water and cap. Wipe the outside of the 

bottle with disposable wiping cloths. 

! Identify, officially seal, and log the sample. Store samples in an ice 

chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

PCB Inspection Manual 6-23 August 2004 
Sampling Chapter Six 

Table 6-10. Guidance for Sampling Water (continued) 

Subsurface Samples 

Site Selection ! In moving water, choose the most turbulent area where the greatest 

amount of mixing is taking place. Avoid quiescent areas. In still water, 

choose areas that appear to have an oil film on the surface. 

Procedures ! Use the PPE listed in Section 6.3.4 of this chapter. 

! Immerse a sealed wide-mouth sample jar (1 L jar is recommended) to 

the required depth. 

! Remove the bottle top to let the air escape and the bottle fill. 

! Transfer the sample into a precleaned sample container (4 L jar or 

bottle). Repeat as necessary to fill sample container. Wipe the 

container with disposable wiping cloths. 

! Use a separate dipping vessel for each sample to prevent crosscontamination. 

! Identify, officially seal, and log samples. Store samples in an ice 

chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

Groundwater 

Note: Take these samples only in consultation with a groundwater hydrological 

laboratory. 

Site Selection ! Collect samples from a water well located downgradient from the area 

of suspected contamination. 

Procedures ! Use the PPE listed in Section 6.3.4 of this chapter. 

! Open the tap on the supply line from the well (or hand pump the well). 

! Let water run about 2-3 minutes at full flow. 

! Fill and cap the sample container. 

! Seal, identify, and log samples. Store samples in an ice chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

August 2004 6-24 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-10. Guidance for Sampling Water (continued) 

Sediment (Bottom Samples) 

Site Selection ! Take samples from the same area that surface samples were taken. 

Procedures ! Use the PPE listed in Section 6.3.4 of this chapter. 

! For lakes and slow-moving streams, use a weighted bottom dredge. 

! For hard bottoms of sand, gravel, etc., use a Peterson dredge; for soft 

bottoms, use an Ekman dredge. 

! Collect the sample. 

! Empty the contents into a hexane-rinsed 3-gallon steel bucket. Stir to 

mix thoroughly. Pass the slurry through a 1/4 inch mesh sieve if 

necessary to remove sticks, leaves, etc. 

! Allow the sediment to settle. 

! Slowly pour off water. 

! Transfer 1 liter of the sediment to a clean, wide-mouth sample jar. Cap 

the jar. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Placing samples in an ice chest is recommended when dealing with PCBs. 

PCB Inspection Manual 6-25 August 2004 
Sampling Chapter Six 

Table 6-11. Guidance for Sampling Vegetation 

The sample design or visual observation may indicate that samples of vegetation (e.g., tree 

leaves, bushes, and flowers) are required. 

Equipment ! PPE - Disposable PCB-resistant gloves (one pair per sample), 

disposable coveralls, footwear covers, and safety goggles 

! Pruning shears, heavy duty scissors, or other suitable tools 

! Cleaned glass sample containers (8 or 16 oz jars with TFE-lined caps) 

! Plastic disposal bags 

! Sample containers labels and indelible pens 

! Secondary sample bags, custody seals, and custody forms. 

Procedures ! Use PPE listed above. 

! Place sufficient material (usually about 250 grams or 1⁄2 pound) into a 

clean glass sample jar. Cap. 

! Identify, officially seal, and log samples. Place samples in an ice 

chest.* 

! Place contaminated equipment into a plastic bag for disposal or 

decontamination. 

* Placing samples in an ice chest is recommended when dealing with only PCBs. 

August 2004 6-26 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-12. Composite Sampling 

Compositing is the pooling of several discrete samples from different areas to form one 

sample for chemical analysis; usually, only soils lend themselves to this approach. In many 

circumstances, it may be desirable to composite samples to reduce the number of (often 

costly) analyses. 

The following PCB regulation subparts specify compositing procedures for the analyses 

regulated by those subparts.

 §761 Subpart Compositing Procedures 

Subpart O--Sampling to Verify Completion of 

Self-Implementing Cleanup and On-Site Disposal of Bulk 

PCB Remediation Waste and Porous Surfaces in 

Accordance with §761.61(a)(6)

Subpart P--Sampling Non-Porous Surfaces for 

Measurement-Based Use, Reuse, and On-Site or Off-Site 

Disposal Under §761.61(a)(6) and Determination Under 

§761.79(b)(3)

Subpart R--Sampling Non-Liquid, Non-Metal PCB Bulk 

Product Waste for Purposes of Characterization for PCB 

Disposal in Accordance With §761.62, and Sampling PCB 

Remediation Waste Destined for Off-Site Disposal, in 

Accordance With §761.61

 §761.289 

§761.310 

§761.350 

PCB Inspection Manual 6-27 August 2004 
Sampling Chapter Six 

Table 6-13. Other Types of Sampling 

For other types of sampling, such as that conducted under §761.130, the following 

compositing procedures may be used. These suggested strategies for compositing 

samples are taken from PCB spill sites sampled using the grid sampling methods described 

in the Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup (May 1986), 

available on the EPA webpage http://www.epa.gov/pcb/guidance.html. Consult with the 

laboratory prior to compositing to ensure regulatory levels can be validly achieved. 

! Composite only samples of the same type (i.e., all soil or all water). Since the 

composite must be thoroughly mixed to ensure homogeneity, do not composite certain 

types of samples, such as asphalt, wipe samples, and other hard-to-mix matrices. 

! Do not form a composite with more than 10 samples, since in some situations 

compositing a greater number of samples may lead to such low PCB levels in the 

composite that the recommended analytical method approaches its limit of detection 

and becomes less reliable. 

! Keep in mind that the PCB concentration of interest (e.g., regulatory or clean-up level) 

for the composite will be equal to: 

Regulatory or clean-up concentration level

 Number of samples in composite 

It must be assumed that one sample at the target regulatory or clean-up level could be 

diluted by the remainder of the samples, which may be nondetectible or at very low 

levels with respect to the PCB concentrations. 

! For each type of sample, determine the number of composites to be formed using the 

table below.

 Number of Samples Number of Composites

 2-10 1

11-20 2

21-30 3

31-37 4

As much as possible, try to form composites of equal size. For example, if 37 soil 

samples are taken, then 4 composites could be formed using 9, 9, 9, and 10 samples 

apiece. 

! To the extent possible, composite adjacent samples. If residual contamination is 

present, it is likely that high PCB levels will be found in some samples taken close 

together. 

August 2004 6-28 PCB Inspection Manual 
Chapter Six Sampling 

Table 6-14. Sample Site Selection 

Regulated facilities conducting sampling must follow the procedures set out in §761 Subparts 

M through R where the sampling activities are within the scope and applicability of those 

subparts. For example, a facility conducting abandonment-in-place or removal and disposal 

off-site of a natural gas pipeline in accordance with §761.60(b)(5) must use the procedures in 

Subpart M to select surface sampling sites for determining the pipe’s PCB surface 

concentration. For further guidance on sample site selection, see: 

! Sampling Guidance for 40 CFR 761 Subparts M, O, P and R; 

! Verification of PCB Spill Cleanup by Sampling and Analysis; and 

! Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup. 

All are available at the EPA webpage http://www.epa.gov/pcb/guidance.html. 

6.7 Sampling Hazardous Materials 

During sampling, inspectors handle hazardous materials and are subject to Department of 

Transportation (DOT) requirements applicable to handling, packaging, and shipping hazardous 

material samples. Information regarding these requirements and where training for these 

procedures is available can be found in EPA’s Fact Sheet titled the Department of 

Transportation Hazardous Materials Training (see Appendix P). 

PCB Inspection Manual 6-29 August 2004 
Sampling Chapter Six 

Blank Page 

August 2004 6-30 PCB Inspection Manual 
Chapter Seven Post-Inspection Activities 

Chapter Seven 

Post-Inspection Activities 

Page 

7.0 Post-Inspection Activities ................................................ 7-1

7.1 Introduction ........................................................... 7-1

7.2 Inspection Follow-up ................................................... 7-1

7.3 The Inspection Report .................................................. 7-2

7.3.1 Objectives ........................................................... 7-2

7.3.2 Time Frame for Preparing the Inspection Report ............................. 7-3

7.3.3 Confidential Business Information Considerations ............................ 7-3

7.3.4 Elements of the Inspection Report ......................................... 7-3

7.3.5 Practical Tips for Report Preparation and Writing ............................. 7-5

7.4 What To Do With the Completed Inspection Report ........................... 7-6

7.5 Data Entry ........................................................... 7-6

7.6 Appearing as a Witness ................................................. 7-7

PCB Inspection Manual 7-i August 2004 
Post-Inspection Activities Chapter Seven 

Blank Page 

August 2004 7-ii PCB Inspection Manual 
Chapter Seven Post-Inspection Activities 

7.0 Post-Inspection Activities 

7.1 Introduction 

The effectiveness of a PCB compliance inspection is dependent on many factors, including the 

thoroughness of the inspection, the evidence collected by the inspector, and the cooperation of 

the facility being inspected. Critical to the success of the inspection process are two steps that 

follow the inspection itself: 

! Conducting necessary follow-up activities at the conclusion of the inspection 

! Preparing the inspection report 

! Ensuring data is entered into the appropriate databases. 

This chapter addresses inspection follow-up activities (Section 7.2), the preparation of the 

inspection report (Section 7.3), and what to do with the completed inspection report ( Section 

7.4). It also includes tips for developing narrative language for the inspection report. 

Some of the actions described above may change as new technologies (e.g., handhelds, 

notebook computers) are implemented. These technologies may enable inspectors to complete 

their inspection reports in the field; however, the information regarding the elements that should 

be included in the report and the practical tips for report writing and preparation will continue to 

be applicable. 

7.2 Inspection Follow-up 

Prior to preparing the inspection report, the inspector should gather all data collected during the 

inspection, including records and reports and other supporting evidence (e.g., photographs, 

samples, affidavits, laboratory analyses reports, and the field logbook and/or other inspection 

notes). The inspector should review the information, noting any gaps or discrepancies, and 

refresh her/his memory of the entire inspection process. The inspector may need to fill in gaps 

by a phone call to the facility or, if necessary, by a follow-up visit. The inspector may also use 

written requests to collect additional information. Requests for supplemental data should specify 

a time frame for a response. 

The inspector should conduct any necessary follow-up activities to answer outstanding 

questions and obtain relevant documents. The inspector should also collect information that 

clarifies the data already in the inspector's possession and include the additional and/or clarifying 

information in the inspection report (see Section 7.3.4). Other follow-up can be through EPA 

Headquarters (late reports, etc.), other contacts suggested onsite, or other program offices, if 

warranted. 

PCB Inspection Manual 7-1 August 2004 
Post-Inspection Activities Chapter Seven 

In some instances, the inspector may have identified potential violations of other statutes. In this 

case, the inspector should refer this information to the applicable EPA or State program office or 

other Federal or State agency. 

7.3 The Inspection Report 

The primary function of the inspection report is to serve as the main document upon which the 

Division Director or other delegated authority will base enforcement decisions concerning the 

facility. The inspector's role in the preparation of the report is to be as accurate and inclusive as 

possible in recording the events that occurred and the observations that were made during the 

inspection. The following guidance on preparing the PCB inspection report includes objectives 

of the report (Section 7.3.1), the time frame for preparing the report (Section 7.3.2), CBI 

considerations (Section 7.3.3), and report elements (Section 7.3.4). 

The inspection report should present a complete and factual record of the inspection process 

from opening conference, through the inspection itself, to closing conference. The inspector 

should keep in mind that the report should contain enough information about the facility and the 

inspection (as well as observations made during the inspection) to enable the Division Director 

or other delegated authority to make enforcement decisions pertaining to the subject facility and 

to develop a case, as necessary. 

7.3.1 Objectives 

As the inspector prepares the report, she/he should have the following objectives in mind: 

! To include in the report all of its basic elements (see Section 7.3.4), ensuring that 

the report contains copies of relevant forms and documents as appendices, and 

the narrative component of the report references those forms and documents 

! To substantiate with as much evidence as possible each potential violation of 

PCB regulations cited in the report (including location, type and size of PCB 

equipment in violation, size and description of spills, and nature of the suspected 

violation) 

! To ensure that any documents and/or photographs are appended to the report 

and referenced in the narrative component of the report. (This is necessary so 

that the Division Director or other delegated authority know how the data relates 

to the inspection.) 

! To write the report in clear and concise language 

! To present factual and accurate information pertaining to all steps in the 

inspection process from opening to closing conference and follow-up 

August 2004 7-2 PCB Inspection Manual 
Chapter Seven Post-Inspection Activities 

! To make only those observations that are based on firsthand knowledge of the 

facility since enforcement personnel must be able to depend on the accuracy of 

all information 

! To include only information that is relevant to the facility and its compliance with 

PCB regulations. (Irrelevant facts can interfere with enforcement decisionmaking.) 

7.3.2 Time Frame for Preparing the Inspection Report 

The inspector should prepare the inspection report as soon as possible following the inspection. 

EPA recommends that the report be completed within 45 days of the inspection. However, the 

actual amount of time will depend on the ability to obtain any additional required information in a 

timely fashion. This time frame should be sufficient to conduct necessary follow-up and to 

prepare the report. 

7.3.3 Confidential Business Information Considerations 

While preparing the inspection report, the inspector should keep in mind that some or all of the 

data gathered during the inspection may be CBI, if claimed as such by the facility. Under normal 

circumstances, a report may be released to the public in response to a Freedom of Information 

Act (FOIA) Request, unless the report falls under a FOIA exemption, such as law enforcement. 

On the other hand, if the inspection report contains CBI, those portions of the inspection report 

must be treated in accordance with CBI procedures and not released under FOIA. In preparing 

the inspection report, it is recommended that the inspector reference CBI in a non-confidential 

manner (i.e., by Document Control Number and a general description of the information 

contained in the document). Note, inspection reports may be released after the case file is 

closed. 

7.3.4 Elements of the Inspection Report 

Although inspection reports may vary in general content and format, there are certain elements 

that should be contained in each inspection report to ensure that necessary information is not 

inadvertently overlooked. The basic components of the inspection report are discussed below. 

The inspection report should be a concise account of observations made and activities 

undertaken during the inspection, from opening conference to closing conference and follow-up. 

The inspector should use the field logbook and an inspection checklist (if one was used) to 

develop the narrative. These tools can help the inspector recall and include in the narrative 

important details concerning the inspection. Inspectors should include and note in the report any 

information submitted by the company as a result of the inspection. 

PCB Inspection Manual 7-3 August 2004 
Post-Inspection Activities Chapter Seven 

The following is suggested information that may be included in the inspection report. The 

inspector is encouraged to include additional information in the inspection report as may be 

necessary. 

! Title Page 

! Index 

! Facility Information 

- Company name, address, and telephone number 

- EPA Federal Registry System (FRS) ID Number 

- Primary NAICS/SIC code 

- DUNS number 

- Number of employees 

- Type of facility 

- Parent company name and address 

- Primary areas of business 

! Inspection Conduct Information 

- Type of inspection conducted 

- Date and time of inspection 

- Responsible official's name, title, and telephone number 

- Name of EPA inspector(s) (Identify lead inspector if there is more than 

one inspector.) 

- Other facility participants 

- Person to whom the inspector presented his credentials 

- Person to whom the inspector provided the Notice of Inspection 

- Narrative of the inspector’s observations regarding 

compliance/noncompliance with the regulations. 

! Administrative Exhibits 

- The inspector should attach, as exhibits to the inspection report, all 

documentary evidence that supports the observations made during the 

inspection (and which should be described in the report narrative, as 

appropriate). The inspector should be sure that any data attached to the 

report as an exhibit is labeled as such and is mentioned within the 

narrative. Also, the inspector should prepare an index of exhibits (or 

attachments) listing the name and the location of each exhibit. This index 

should precede the exhibits and serve as a reference for enforcement 

personnel. Exhibits the inspector should include are: Notice of Inspection, 

Inspection Confidentiality Notice, Declaration of Confidential Business 

Information, Laboratory Analyses, Receipt for Samples and Documents, 

and other evidence. 

! The inspector’s signature with date. 

The inspection report should not include any statements concluding that violations of PCB 

regulations exist. 

August 2004 7-4 PCB Inspection Manual 
Chapter Seven Post-Inspection Activities 

7.3.5 Practical Tips for Report Preparation and Writing 

The style of the inspection report should be clear, concise, accurate, factual, fair, complete, and 

logical. The inspector should write the report in such a way as to eliminate the possibility of 

erroneous conclusions, inferences, or interpretations. The report will become part of the 

permanent records for the facility, along with the samples, formal statements, photographs, and 

other pieces of evidence. A well-written report will serve as a summary of these other records. 

In general, three rules apply to the preparation of good inspection reports: 

! Write to express, not to impress. The inspector should include only facts and 

evidence that are relevant to the compliance situation. 

! Keep the report simple. The inspector should discuss complicated matters in 

organized, simple, direct terms. 

! Keep the reader in mind. The inspector should use writing, language, and terms 

familiar to the reader. 

Keeping these rules in mind, the inspector should follow these basic steps when preparing to 

write the inspection report: 

! Review the information. As the first step, the inspector should collect and review 

all information gathered during the inspection, including inspection report forms 

and checklists. The inspector should then review the information for relevance 

and completeness. If the inspector identifies gaps, he or she can make follow-up 

telephone calls or, if necessary, conduct a follow-up inspection. 

! Organize the material. There are several different methods available for 

organizing the inspection data. Whatever the method, the inspector should 

present the material in a logical, comprehensive manner and organize it so it is 

easily understood. 

! Reference accompanying material. The inspector should clearly reference all 

pieces of evidence (e.g., copies of records, analytical results, and photographs) 

that accompany the report so that the reader can locate them easily. The 

inspector should check supporting documents for clarity prior to writing. 

When developing the narrative language portion of an inspection report, the inspector should: 

! Ensure that the reader is able to readily ascertain the following information from 

the narrative: 

- The persons who participated in the inspection (i.e., identity of each facility 

representative and inspector) 

- A brief description of the facility being inspected (i.e., what it manufactures 

and/or imports, physical size of plant, number of buildings, etc.) 

- Verification that all required notices and receipts were completed and 

issued as required and are attached to the report 

PCB Inspection Manual 7-5 August 2004 
Post-Inspection Activities Chapter Seven 

- The actions taken and observations made during the inspection which 

establish compliance status 

- The evidence (e.g., documents, photographs) that was collected during 

the inspection. 

! Include the facility information, inspection conduct information, and inspection 

results within the narrative. 

! Consider the types of information necessary to prove the circumstance and 

extent of noncompliance as shown in the PCB Penalty Policy, which can be 

found on the following website: 

http://www.epa.gov/Compliance/resources/policies/civil/tsca/. 

In writing the report, the inspector should record in a factual manner the procedures used in, and 

the findings resulting from, the evidence-gathering process. The report should refer to routine 

procedures and practices used and describe in detail the facts relating to potential 

noncompliance and discrepancies, but should not suggest or conclude that there may be or are 

potential violations. 

7.4 What To Do With the Completed Inspection Report 

After the inspector files the inspection report, the supervisor or designated senior inspector 

reviews it and sends it to the case development officer (CDO). If a case is issued and does not 

settle out-of-court, the inspector may need to appear as a witness in court. 

7.5 Data Entry 

In addition to writing the inspection report, the inspector should submit required information for 

EPA’s data tracking system. PCB inspectors must enter or provide appropriate information to 

data entry staff. 

Inspectors must complete the Inspection Conclusion Data Sheets (ICDS) forms immediately 

after completing the inspection. If inspectors enter the ICDS information directly into ICIS they 

may include the ICDS information in their inspection notes without filling the actual form. Refer 

to Appendix D for information on Inspection Conclusion Data Sheets (ICDS). Current 

information on ICDS is found in the EPA inspector website at 

http://intranet.epa.gov/OECA/OC/CAMPD/inspector. 

Finally, it is important that inspection data is submitted to the FIFRA/TSCA Tracking System 

(FTTS). FTTS is a regional system used to track compliance activities such as inspections, 

case review, enforcement actions taken, and samples collected. Compliance monitoring and 

enforcement activities are tracked from the time an inspector conducts an inspection until the 

time the case is closed. 

August 2004 7-6 PCB Inspection Manual 
Chapter Seven Post-Inspection Activities 

7.6 Appearing as a Witness 

The majority of cases that the EPA files result in out-of-court settlements that will not usually 

require the inspector’s testimony. However, in cases that do not settle, the inspector may be 

called upon to be a “fact witness,” or one who describes personal knowledge obtained through 

one of the five senses. Throughout the enforcement process, everything an inspector hears, 

sees, samples, or records may become evidence about which he or she may be questioned. 

Many cases are tried years after the field and laboratory activities have been conducted. Thus, 

the inspection report and field notebook should be sufficiently detailed and legible to allow the 

inspector to reconstruct the inspection “on the record.” See Appendix Q for detailed information 

regarding preparing to testify; legal etiquette, appearance, and demeanor; and testifying during 

deposition, direct examination, and cross-examination. 

PCB Inspection Manual 7-7 August 2004 
Post-Inspection Activities Chapter Seven 

Blank Page 

August 2004 7-8 PCB Inspection Manual 
Appendices
Blank Page 
Appendix A Inspection Forms 

Appendix A 

Inspection Forms 

The following pages contain blank Notice of Inspection, TSCA Inspection Confidentiality Notice, 

and Declaration of Confidential Business Information forms. See Chapter 2 for more detailed 

information regarding these forms. These forms may be obtained by calling the EPA 

Headquarters warehouse in Cincinnati, Ohio at (513) 489-8190. 

PCB Inspection Manual A-1 August 2004 
Inspection Forms Appendix A 

EPA 

US ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, DC 20460 

TOXIC SUBSTANCES CONTROL ACT 

NOTICE OF INSPECTION 

1. INVESTIGATION IDENTIFICATION 3. FACILITY NAME 

DATE INSPECTOR’S NO. DAILY SEQ. NO. 

2. INSPECTOR’S ADDRESS 4. FACILITY ADDRESS 

For Internal EPA Use. Copies may be provided to recipient as acknowledgment of this notice. 

REASON FOR INSPECTION

 Under the authority of Section 11 of the Toxic Substances Control Act: 

Q For the purpose of inspecting (including taking samples, photographs, statements, and other inspection activities) an establishment, facility, or other premises in which chemical substances or mixtures, articles containing same are manufactured, processed, stored or held before or after their distribution in commerce (including records, files, papers, processes, controls, and 

facilities) and any conveyances being used to transport chemical substances, mixtures, or articles containing same in connection

 with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on whether the 

requirements of the Act are applicable to the chemical substances, mixtures, or articles within, or associated with, such premise or 

conveyance have been complied with. 

Q In addition, this inspection extends to (check appropriate blocks): 

Q A. Financial data Q D. Personnel data 

Q B. Sales data Q E. Research data 

Q C. Pricing data

 The nature and extent of inspection of such data specified in A through E above is as follows: 

INSPECTOR’S SIGNATURE RECIPIENT’S SIGNATURE 

NAME NAME 

TITLE DATE SIGNED TITLE DATE SIGNED

 EPA FORM 7740-3 (REVISED JULY 1997) CORE TSCA — PREVIOUS VERSIONS ARE OBSOLETE Recipient’s COPY 

August 2004 A-2 PCB Inspection Manual 
Appendix A Inspection Forms 

EPA 

US ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, DC 20460 

TOXIC SUBSTANCES CONTROL ACT 

TSCA INSPECTION CONFIDENTIALITY NOTICE 

1. INVESTIGATION IDENTIFICATION 4. FACILITY NAME 

DATE INSPECTION NO. DAILY SEQ. NO. 

2. INSPECTOR’S NAME 5. ADDRESS 

3. INSPECTOR’S ADDRESS 6. NAME OF CHIEF EXECUTIVE OFFICER 

7. TITLE 

For internal EPA use. Copies may be provided to recipient as acknowledgment of this notice. 

TO ASSERT A TSCA CONFIDENTIAL BUSINESS INFORMATION CLAIM 

It is possible that EPA will receive public requests for release of the information 

obtained during the inspection of the facility cited above. Such requests will be 

handled by EPA in accordance with provisions of the Freedom of Information 

Act (FOIA), 5 USC 552; EPA regulations issued thereunder, 40 CFR, Part 2; 

and the Toxic Substances Control Act (TSCA), Section 14. EPA is required to 

make inspection data available in response to FOIA requests unless the EPA 

Administrator determines that the data is entitled to confidential treatment, or 

may be withheld from release under other exceptions of FOIA. 

Any or all information collected by EPA during the inspection may be claimed 

as confidential if it relates to trade secrets, commercial, or financial matters 

that you consider to be confidential business information (CBI). If you assert a 

CBI claim, EPA will disclose the information only to the extent, and by means 

of the procedures set forth in the regulations (cited above) governing EPA’s 

treatment of CBI. Among other things, the regulations require that EPA notify 

you in advance of publicly disclosing any information claimed as CBI. 

A CBI claim may be asserted at any time prior to, during, or after the 

information is collected. This notice was developed by EPA to assist you in 

asserting a CBI claim. If it is more convenient for you to assert a CBI claim 

on your own stationary or by making the individual documents or samples 

“TSCA confidential business information,” it is not necessary for you to use 

this notice. The inspector will be glad to answer any questions you may have 

regarding EPA’s CBI procedures. 

While you may claim any collected information or sample as CBI, such claims 

are not likely to be upheld if they are challenged unless the information meets 

the following criteria: 

1. Your company has taken measures to protect the confidentiality of the 

information and it intends to continue to take such measures. 

2. The information is not, and has not been, reasonably obtainable without 

your company’s consent by other persons (other than governmental 

bodies), or by use of legitimate means (other than discovery based on 

showing of special need in a judicial or quasi-judicial proceeding). 

3. The information is not publicly available elsewhere. 

4. Disclosure of the information would cause substantial harm to your 

company’s competitive position. 

At the completion of the inspection, you will be given a receipt for all documents, 

samples, and other materials collected. At that time, you may make claims that 

some or all of the information is CBI. 

If you are not authorized by your company to assert a CBI claim, this notice will 

be sent by certified mail, along with the receipt for documents, samples, and other 

materials to the Chief Executive Officer of your company within 2 days of this 

date. The Chief Executive Officer must return a statement specifying any 

information which should receive CBI treatment. 

The statement from the Chief Executive Officer should be addressed to: 

and mailed by registered, return-receipt requested mail within 7 calendar days of 

receipt of this notice. Claims may be made at any time after the inspection, but 

the inspection data will not be entered into the TSCA/CBI security system until an 

official confidentiality claim is made. The data will be handled under EPA’s routine 

security system unless and until a claim is made. 

TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE 

I acknowledge receipt of this notice: 

If there is no one on the premise who is authorized to make CBI claims for this 

facility, a copy of this notice and other inspection materials will be sent to the 

company’s Chief Executive Officer. If there is another official who should also 

receive this information, please designate below. 

SIGNATURE NAME 

NAME TITLE 

TITLE DATE SIGNED ADDRESS

 EPA FORM 7740-4 (Revised July 1997) PREVIOUS VERSIONS ARE OBSOLETE INSPECTOR’S COPY 

PCB Inspection Manual A-3 August 2004 
Inspection Forms Appendix A 

EPA 

US ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, DC 20460 

TOXIC SUBSTANCES CONTROL ACT 

DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION 

1. INVESTIGATION IDENTIFICATION 2. COMPANY NAME 

DATE INSPECTION NO. DAILY SEQ. NO. 

3. INSPECTOR ADDRESS 4. COMPANY ADDRESS 

For internal EPA use. Copies of this form may be provided to recipient as acknowledgment of TSCA Confidential documents described below collected in connection 

with the administration and enforcement of the Toxic Substances Control Act. 

INFORMATION DESIGNATED AS CONFIDENTIAL BUSINESS INFORMATION 

NO. DESCRIPTION 

INSPECTOR SIGNATURE CLAIMANT SIGNATURE 

NAME NAME 

TITLE DATE SIGNED TITLE DATE SIGNED

 EPA FORM 7740-2 (REVISED JULY 1996) PREVIOUS VERSIONS ARE OBSOLETE INSPECTOR’S COPY 

August 2004 A-4 PCB Inspection Manual 

For your information, here is a summary of the Policy’s major points: 

• EPA compliance inspectors are encouraged to provide appropriate general, and limited 

site-specific, compliance assistance, consistent with the primary purpose of compliance 

determination. The Policy provides examples of general and site-specific compliance 

assistance. 

• The Policy is not intended to address every inspection scenario or situation. The Policy 

does not supplant the need for prudent judgement by EPA inspectors, based on their 

knowledge, experience, and expertise. 

• EPA inspectors should not provide site-specific interpretive technical assistance during 

compliance inspections. 

• EPA inspectors should not provide site-specific interpretive legal assistance during 

compliance inspections. 

• EPA inspectors should not make applicability determinations in the field. 

• Specific activities occurring during the inspection should be documented and reported 

after the inspection, including potential violations, actions taken to address potential 

violations, and compliance assistance provided. 

• Facilities receiving compliance assistance are not shielded from possible enforcement 

actions for violations identified during the compliance inspection. 

Please distribute this policy widely throughout the organization to all EPA employees, 

EPA contractors, and EPA grantees that conduct inspections. If you have questions, please call 

the Compliance Assessment and Media Programs Division (CAMPD) at 202-564-2300. 

Attachments: National Policy: A) Background and Sources of Information; and B) U.S. EPA 

Compliance Assistance Resources 

Addressees: Regional Enforcement Division Directors, Regions 1, 2, 4, 6, and 8 

Regional Science and Technology Division Directors, Regions 1-10 

Regional Media Division Directors, Regions 1-10 

Regional Enforcement Coordinators, Regions 1-10 

Regional Compliance Assistance Coordinators, Regions 1-10 

David S. Evans, Director, Oil Program Center 

Steve Page, Director, Office of Air Quality Planning and Standards 

Brian McLean, Director, Office of Atmospheric Programs 

James Jones, Director, Office of Pesticide Programs 

Charles Auer, Director, Office of Pollution Prevention and Toxics 

Debbie Dietrich, Director, Chemical Emergency Preparedness and Prevention 

Office 
Robert Springer, Director, Office of Solid Waste 

Cliff Rothstein, Director, Office of Underground Storage Tanks 

Cynthia Dougherty, Director, Office of Ground Water and Drinking Water 

James A. Hanlon, Director, Office of Wastewater Management 

Diane Regas, Director, Office of Wetlands, Oceans and Watersheds 

cc: Phyllis Harris, Principal Deputy Assistant Administrator, OECA 

Steve Shimberg, Associate Assistant Administrator, OECA 

Michael Stahl, Director, OC 

Lisa Lund, Deputy Director, OC 

OC Division Directors and Branch Chiefs 

Walker B. Smith, Director, ORE 

David Nielsen, Deputy Director, ORE 

ORE Division Directors 

Leo D’Amico, Director, OCEFT 

OCEFT Division Directors 

Gerald A. Bryan, Director, NETI 

Mary-Kay Lynch, Director, OPPAC 

David Kling, Director, FFEO 

Diana Love, Director, NEIC 

Anne N. Miller, Director, OFA 

Susan E. Bromm, Director, OSRE 
NATIONAL POLICY 

The Role of the EPA Inspector in Providing Compliance Assistance During Inspections 

Summary of 

Policy The main purpose of EPA conducting compliance inspections is to determine 

compliance with environmental regulations and enforcement agreements. 

This policy clarifies, but does not change, the existing practice of providing 

appropriate compliance assistance during inspections (recent results from the 

Inspection Conclusion Data Sheet project indicate that inspectors currently 

provide assistance during 75% of compliance inspections). This policy applies 

during the course of the on-site compliance inspection and only to EPA inspectors 

as defined under the Inspection Process section. Here is a summary of the main 

points: 

• EPA compliance inspectors are encouraged to provide appropriate general, 

and limited site-specific, compliance assistance, consistent with the 

primary purpose of compliance determination, as time allows. Examples 

of general and site-specific compliance assistance are provided in the 

Policy. 

• The Policy is not intended to address every inspection scenario or 

situation. The Policy does not supplant the need for prudent judgement by 

EPA inspectors, based on their knowledge, experience, and expertise. 

• EPA inspectors should not provide site-specific interpretive technical 

assistance during compliance inspections. 

• EPA inspectors should not provide site-specific interpretive legal 

assistance during compliance inspections. 

• EPA inspectors should not make applicability determinations in the field. 

• EPA inspectors should only provide assistance on state requirements that 

are identical to federal environmental regulations. 

• Specific activities occurring during the inspection should be documented 

and reported after the inspection, including potential violations, actions 

taken to address potential violations, and compliance assistance provided. 

• Facilities receiving compliance assistance are not shielded from possible 

enforcement actions for violations identified during the compliance 

inspection. 

• Facilities are subject to potential enforcement action, even if they correct 

potential violations observed during the compliance inspection. 
This policy was developed based on information sources (Attachment A), tips 

from a Region III inspector, comments from the Regions/HQ offices, and the 

Region VII Documentation Guidelines for Compliance Related Field Activities. 

Index This Policy includes the following: 

• Introduction 

• Inspection process 

• Definition for this policy 

• Appropriate general assistance 

• Inappropriate assistance 

• Site-specific examples 

• Documentation 

• Reporting 

Introduction In 1997, a workgroup of Headquarters and regional compliance inspectors and 

managers was formed to discuss and report on the proper role of the EPA 

inspector in providing compliance assistance. The workgroup developed a report 

that was circulated to the Regions. However, the 1997 report was never 

communicated as a national policy that EPA inspectors should follow. It was 

issued only as a guide. This national policy document supercedes the 1997 

report. 

This national policy describes the appropriate role of the EPA inspector when 

providing compliance assistance. The Regions and HQ offices played a significant 

role in formulating this revised policy. Their comments are incorporated in this 

final Policy. 

Inspection 

Process During every compliance inspection, EPA inspectors (i.e., EPA employees, 

contractors, and SEE enrollees, as well as state and tribal inspectors using federal 

credentials to conduct inspections) are tasked primarily with determining 

compliance and, secondarily, with determining the appropriate level of 

compliance assistance to provide to the facility being inspected. Generally, an 

EPA inspector conducts the following activities during an inspection: 

• presents credentials and gains access to the facility; 

• identifies a facility representative with knowledge and authority to answer 

questions, and conducts interviews with various facility personnel; 

• announces the purpose of the inspection and, in some cases, presents a 

notification of inspection; 

• takes environmental samples when appropriate; 

• reviews a variety of records, reports, and other written documentation; 

• conducts an on-site review of the physical buildings, processes, pollution 
control equipment, and monitoring practices; 

• makes notes of observations and interviews and takes photographs; and 

• conducts a closing or exit conference. 

At any time during these activities, the EPA inspector could be asked general 

and/or site-specific compliance-related questions. This policy provides guidance 

to EPA inspectors on how to respond to these questions and what types of 

assistance should, and should not be, provided. 

Caution: If the facility fixes or corrects potential violation(s) observed during the 

inspection, the EPA inspector should make note of it in the inspection report. 

However, the facility is still subject to an enforcement action if the potential 

violation is deemed appropriate, and there is ample evidence documenting it. 

Under no circumstances should the EPA inspector tell the facility that it is 

exempt from enforcement actions if the facility corrects or fixes potential 

violations observed during the inspection. 

Definition for 

this Policy While EPA has a broader definition of Compliance Assistance for other 

purposes, this policy defines compliance assistance as: 

• Providing tools or regulatory assistance to the facility during an on-site 

compliance inspection to help the facility understand and comply with 

federal environmental regulations/requirements. 

Compliance assistance for this policy does not include the following two 

situations: 

• EPA inspectors may observe situations where there are significant 

problems that rise to the level of an imminent and substantial 

endangerment to human health or the environment. If the inspector 

believes such a situation exists, he/she must notify the facility during the 

inspection and refer the facts to the appropriate office for subsequent 

action. This is an obligation EPA inspectors assume as part of their 

normal duties. 

• EPA inspectors may share information about, or provide a review of the 

compliance status of the facility including a preliminary evaluation of 

some, but possibly not all, of the potential violations observed during the 

closing conference. These preliminary findings could change at a later 

date subject to research, management or legal review, or new information 

received by the Agency. This information is part of the routine 

compliance and enforcement process and is not considered compliance 

assistance. 
Regional and HQ inspection programs vary on whether EPA inspectors 

share initial inspection results, and even final inspection reports, with 

facility owners/operators. This national policy does not alter these existing 

regional or HQ inspection program practices or policies. 

Appropriate 

General 

Assistance EPA compliance inspectors are encouraged to provide general compliance 

assistance during the compliance inspection. The following examples illustrate 

appropriate general compliance assistance during inspections: 

• Providing physical copies of environmental statutes or regulations, 

conveying a general explanation of where to obtain the regulatory 

requirements, and providing information on where to find regulatory 

interpretations (e.g., CAA Applicability Determination Index); 

• Providing information including prepared guidance, manuals, and 

technology transfer documents; 

• Providing information on what assistance can be obtained from EPA, 

State, local assistance programs, trade associations, and other 

organizations; 

• Informing facilities regarding the physical equipment or processes and 

reports and/or records they need to maintain, as well as a general idea of 

what these documents should contain to ensure compliance; 

• Distributing the small business information sheet with information on web 

sites, hotlines, and other materials; 

• Providing prepared literature on pollution prevention techniques and 

opportunities, environmental management practices, and innovative 

technologies; 

• Providing information on visible compliance problems (e.g., labeling, aisle 

space), which do not pose any issues of first impression requiring legal or 

technical interpretation by the inspector, potentially enabling the facility to 

undertake quick action to remedy the non-compliance problem; 

• Providing facilities with the website for the EPA Audit Policy and Small 

Business Policy to encourage self-auditing; 

• Providing suggestions from published material developed and recognized 

by EPA on simple techniques and concepts to reduce or eliminate 

pollution (e.g., housekeeping tips); 
• Sharing information from published material developed and recognized by 

EPA on control practices and equipment used within a specific sector to 

comply with environmental regulations and potentially reduce their 

regulatory burden; 

• Providing information published material developed and recognized by 

EPA on recognized industry or sector-based practices and concepts to 

reduce or eliminate pollution (e.g., chemical substitution, equipment 

changes); 

• Explaining regulations or guidance that describe how to collect a sample, 

but not providing advice on the number or location of samples necessary 

to meet “representative” criteria; and 

• Mentioning to regulated facilities that state requirements, which may apply 

to them, may be different than federal requirements. 

Inappropriate 

Assistance EPA inspectors should not provide site-specific interpretive technical assistance, 

nor should they provide site-specific interpretive legal assistance during 

compliance inspections. Legal assistance involves providing advice to the facility 

on how to deal with EPA or the state on a potential violation or enforcement 

action, or stating that no action will be taken if potential violations are corrected 

by the facility. 

Examples of inappropriate site-specific technical and legal assistance that should 

NOT be provided during EPA compliance inspections include: 

• Providing information on specific commercial consultant services, or 

recommending a specific product or consultant providing a service; 

• Providing interpretive site-specific legal or technical advice on how a site 

or facility can achieve compliance with environmental regulations; 

• Providing interpretations that do not already exist in writing or are not 

written agency policy; 

• Providing determinations of whether a facility, unit, waste, or piece of 

equipment is subject to federal environmental requirements, providing 

regulatory interpretations, or approving alternative monitoring approaches. 

These are typically known as applicability determinations; 

• Providing specific design information on a facility's particular problem, 

engineering design, or materials management process; 
• Divulging information that could be classified as confidential business 

information; 

• Advising on technical solutions, such as process changes that should be 

made or types of equipment that should be purchased; and 

• Offering opinions on recommendations made by others, particularly state, 

tribal, or local inspectors. EPA inspectors should only provide assistance 

on state requirements that are identical to federal environmental 

regulations. 

The above examples are not appropriate for the following reasons: 

Complexity – Due to the scope of regulatory requirements, routine changes to 

manufacturing processes, technological advances, and limited time for reviewing 

and observing on-site procedures and practices, EPA inspectors may not always 

have the information and time needed to provide appropriate compliance 

assistance. Also, the facility owner or operator may provide EPA inspectors with 

incorrect or misleading information. This lack of, or incorrect, information may 

lead the EPA inspector to make statements that do nothing to improve the 

facility’s operations or its ability to achieve compliance with environmental 

requirements. 

Potential legal implications – It may affect the Agency’s ability to develop and 

prosecute civil and criminal enforcement actions. For example, if a facility relied 

upon assistance that the EPA inspector provided to initiate action to achieve 

compliance and a subsequent enforcement action was taken for non-compliance or 

imminent and substantial endangerment resulting from that assistance, it could 

cause problems in successfully prosecuting the case and achieving environmental 

compliance. The Office of Regional Counsel or Office of Regulatory 

Enforcement should be consulted if this issue arises during, or after, a compliance 

inspection. 

Potential to develop new policy in the field – Policy decisions at one facility can 

have a precedential effect on all other facilities. It is important that EPA 

inspectors follow established procedures for developing national compliance and 

enforcement policies. EPA inspectors may not have all of the facts or the 

authority necessary to make policy decisions in the field. They may need to 

consult existing guidance and obtain technical advice to ensure consistency on 

how to address the issue, which may not be available during the inspection. 

Site-Specific 

Examples The following examples are provided to assist the EPA inspector in identifying 

appropriate and inappropriate site-specific assistance during a compliance 

inspection. These examples are illustrative only and do not represent the entire 
spectrum of all possible site-specific compliance assistance situations. 

Example 1 - Missing Labels: An inspector on a tour of a facility observes a 

number of electric transformers on-site. The transformers have no labels posted 

on them. The inspector inquires as to the type of transformers. The plant operator 

states that the transformers contain polychlorinated biphenyls (PCBs). 

Appropriate assistance 

The inspector tells the facility, “the regulations require that you will need to put 

labels on transformers containing PCB’s. The labels must say ‘Caution Contains 

PCBs and other specific language.’” The inspector directs the facility to the 

specific regulatory citation for the exact wording for the labels. 

Inappropriate assistance 

The inspector either places the labels on the transformers for the facility or 

recommends a specific company or brand of label by saying, “here is X company 

who sells and can provide you with the correct labels.” 

Example 2 - Open Containers – In the aerosol fill area of a facility, the 

inspector observes a 55-gallon satellite accumulation container that is open. The 

inspector verifies that the container is full. A plant operator informs the inspector 

that the container is used to collect spent line flushing solvent (lacquer thinner) 

used to wash paint out of the fill equipment. The inspector asks the plant operator 

if the spent solvent is classified a hazardous waste by the company. The plant 

operator affirms it is classified a hazardous waste. 

Appropriate assistance 

The inspector tells the facility, “the regulations specify that you need to make sure 

containers holding hazardous waste that are full are closed except when it is 

necessary to add or remove waste.” The inspector directs the facility to the 

specific regulatory citation requiring the containers to be closed. The inspector 

also discusses standard industry practices from published material developed and 

recognized by EPA to ensure proper handling of hazardous waste. 

Inappropriate assistance 

The inspector tells the facility that if it fails to keep containers holding hazardous 

waste closed, it will have to change its process to avoid generating the waste. 

Alternatively, the inspector suggests a different process design for the facility that 

will allow waste to be generated but will keep the containers closed. The 

inspector advises the facility on how to avoid penalties for drums remaining open. 

Example 3 - Sludge Deposits – The state waste water permit for a facility 

requires that “[w]aters shall be free from substances in sufficient amounts to cause 

formation of putrescent, unsightly, or harmful bottom deposits.” At the facility’s 

outfall, the inspector observes the receiving stream to have 4-5 inches of sludge 

deposit at the bottom, as well as significant bloodworm populations. After 
discussion with the facility, the facility operator signs a statement that the facility 

has been losing solids to the stream for four months due to an increased organic 

load from a meat packing company. 

Appropriate assistance 

The inspector inquires whether there are other discharges from the facility, what 

treatment processes and controls are in place to prevent solids from reaching the 

outfalls, and what problems have occurred. The inspector asks the facility about 

its understanding of permit conditions regarding sludge deposits in the receiving 

stream, and whether the facility is meeting its permit conditions. The inspector 

tells the facility that it should limit solids reaching the outfall to meet its state 

permit requirements. The inspector directs the facility to the specific permit 

language regarding protection of the receiving stream and to agency guidance 

discussing wastewater requirements and various treatment methods for solids. 

Inappropriate assistance 

The inspector tells the facility it will have to stop accepting waste from the meat 

packing plant to meet the permit limits. Alternatively, the inspector suggests a 

different process design for the facility that will prevent solids from reaching the 

outfall. The inspector advises the facility on how it can renegotiate its permit with 

the state. 

Example 4 - Chromate Coating Process – A steel plant facility states it is 

“galvanizing” steel with a 55% aluminum and 45% zinc coating followed by a 

chromate dip. The inspector consults the EPA development document and 

concludes that the chromate coating process is actually “electroplating” and that 

residues from treating the spent chromate solution would be a listed hazardous 

waste. If the process is defined as “electroplating”, the facility could have 

significant noncompliance with hazardous waste requirements. 

Appropriate assistance 

The inspector asks the facility what processes and controls it has in place for 

handling the spent chromate solution. The inspector inquires whether the facility 

has looked into whether the spent chromate solution requires special handling as 

hazardous waste, what it found, and the rationale for operating the controls that 

are currently being implemented. The inspector asks the facility to explain why it 

determined that the process is “galvanizing” rather than “electroplating”. 

The inspector tells the facility that there are some questions about the process, 

specifically its definition of the process as “galvanizing” rather than 

“electroplating”. The inspector states that an applicability determination will have 

to be made, after a review and research, as part of evaluating the facility’s 

compliance status and consultation with EPA management and legal counsel. The 

Agency may also request additional information about the process. 

The inspector directs the facility to available agency, state, or local materials and 
websites dealing with galvanizing, electroplating, and chromate coating processes, 

such as the Metal Finishing Compliance Assistance Center (1-800-AT-NMFRC or 

http://www.nmfrc.org), the Self-Audit and Inspection Guide for Facilities 

Conducting Cleaning, Preparation, and Organic Coating of Metal Parts (EPA 305-

B-95-002, August 1998), and/or the CAA Applicability Determination Index at 

http://www.epa.gov/Compliance/planning/data/air/adi.html. 

Inappropriate assistance 

The inspector tells the facility it needs to stop operating the galvanizing process 

until the Agency determines whether the operation generates a hazardous waste. 

Alternatively, the inspector advises the facility to modify its process to allow it to 

be defined as a “galvanizing” process. 

Example 5 - Record keeping – An inspector observes that a facility did not 

maintain good air emission monitoring records over a two-year period. The 

managers at the facility had a system to record readings from their continuous 

monitoring system, but no one at the facility had direct responsibility to ensure the 

readings were properly recorded every day. A review of the records revealed that 

a daily report was being used for several days of readings. The standards 

specifies separate records for each 24-hour period. 

Appropriate assistance 

The inspector tells the facility: “the underlying standards clearly specify that 

separate records must be maintained for each 24-hour period.” The inspector 

directs the facility to the standards requiring the record keeping requirements. 

Inappropriate assistance 

The inspector tells the facility that to ensure the records are maintained it should 

include the responsibility in the plant engineer’s job description. 

Documentation EPA inspectors should document in their field notes, and subsequent inspection 

reports, the following information: 

• any and all actions actually observed that were taken by the facility to 

come into compliance; and 

• any assistance provided (both written and oral) to the facility. 

In FY 2003, some EPA inspection programs (CAA-Stationary Source, CWANPDES, TSCA lead-based paint, Good Laboratory Practices, and CAA-Mobile 

Source) are required to complete an Inspection Conclusion Data Sheet (ICDS). 

The ICDS form is designed to capture information on deficiencies observed and 

communicated, actions taken to address deficiencies, and compliance assistance 

provided during inspections. 
Reporting EPA currently has two existing databases that capture instances where EPA 

inspectors provide compliance assistance during inspections. 

1. The Integrated Compliance Information System has a data field for 

capturing compliance assistance during inspections. In a December 4, 

2002 memo to the Regions, Headquarters described the process for 

reporting the ICDS information. 

• In FY 2003, for the five regional and HQ inspection programs 

targeted to complete the ICDS, the regions had the option of using 

either entering the data into ICIS or completing and sending a 

manual form as part of the mid-year and end-of-year RECAP 

request. 

• In FY 2004 and later years, additional media-specific inspection 

programs (e.g., RCRA Hazardous Waste and TSCA) will be added 

to the ICDS reporting. 

• The Regional Compliance Assistance Tracking System (RCATS) tracks 

only the number and type of tools distributed during on-site activities, 

including inspections. RCATS does not capture the other ICDS 

information (deficiencies observed and communicated, specific actions 

taken to address deficiencies, and site-specific compliance assistance). 

The preferred approach is the Regions and HQ offices conducting compliance 

inspections to use ICIS to report general and site-specific compliance assistance 

provided during inspections. 

Attachment A: Background Sources of Information and SBREFA Information Sheet 

Attachment B: SBREFA Information Sheet (revised) 
ATTACHMENT A 

Role of the EPA Inspector in Providing Compliance Assistance During Inspections 

Background and Sources of Information 

Sources This policy was developed based on the following sources of information: 

• Role of the EPA Inspector in Providing Compliance Assistance Final 

Report, July, 1997. 

• Regional Inspector Dialogues, February-May, 1998. 

• National EPA Inspector Workshop, November 28-30, 2000. 

• National EPA Inspector Workshop, December 11-13, 2001. 

• Informal discussions between OECA managers, staff and the Regions. 

• SBREFA law and handout. 

• Draft Region III Compliance/Corrective Assistance Tips for Inspectors, 

Summer, 2002. 

• Documentation Guidelines for Compliance Related Field Activities, 

October 17, 2002, Region VII Enforcement Coordination Office. 

Background In March, 1995 the Office of Compliance initiated a headquarters and regional 

work group co-chaired by Region III to review the traditional roles and assess 

innovative roles for EPA compliance monitoring inspectors with regard to 

providing compliance assistance and technical assistance to regulated facilities 

and to facilitate multi-media and sector-based activities. 

The reader is encouraged to obtain a copy of the 1997 report titled the “Role of the 

EPA Inspector in Providing Compliance Assistance” and read it as a main 

companion piece to this policy. The report is available on the OC Inspector 

Website, under Reference Materials. The URL for the website is: 

http://intranet.epa.gov/oeca/inspector. 

The workgroup produced a report that discussed options for providing on-site 

compliance assistance during inspections, implementation issues, conclusions and 

recommendations. The workgroup conclusions were: 

• On-site compliance assistance during inspections can be viewed as a 

continuum from the simple to more complex. The most technically 

complex and site-specific level of assistance, Tier III, is not an appropriate 

EPA inspection activity, but the use of any compliance assistance depends 

on the training and expertise of the particular inspector in techniques and 

substance. 

• To be most effective, EPA decisions about when and how to use 

compliance assistance to address an environmental problem or noncompliance situation should be made during up-front planning and 

targeting processes, particularly in the development of sector-based 

strategies. 
Since October 1, 2001, the Regions have been completing ICDS forms for the 

CAA-Stationary, CWA-NPDES, Lead-based paint, and Good Laboratory 

Practices (GLP) inspections. The Office of Compliance recently sent a memo to 

the Regions summarizing the results of the mid-year data. The results showed 

that EPA inspectors provided compliance assistance on 77% of a total of 1269 

inspections for the first half of FY 2002 in the above programs. 

Inspector’s 

Guide OC expects to finalize the Inspector’s Compliance Assistance Resource Guide in 

the late 2002 or early 2003. This guide will provide information to EPA 

inspectors on how to use the compliance assistance resources that OECA has 

developed. These resources range from hard copy documents to interactive online tools. The Guide’s main purpose is to enable EPA inspectors to know what 

is available to provide to inspected facilities. The Guide includes information on: 

• Sector Notebooks 

• Compliance Assistance Centers 

• Compliance Assistance Clearinghouse 

• Audit Protocols 

• Sector-specific tools 

The draft guide can found at http://www.ergweb.com/projects2/inspectorguide/. 

SBREFA The Small Business Regulatory Enforcement Fairness Act (SBREFA) was signed 

into law on March 29, 1996. The Act required agencies conducting enforcement 

at facilities “subject to an audit, on-site inspection, compliance assistance effort, 

or other enforcement related communication or contact by agency personnel” have 

a means to comment on such enforcement actions. 

To implement this provision, OECA has developed a revised SBREFA 

Information Sheet (following attachment). SBREFA information should be 

provided when EPA has its initial enforcement contact with a small business, 

which may or may not be at the time of the inspection. A small business is 

defined by the Small Business Administration and is based on the SIC/NAICS 

code, number of employees, and annual receipts. The inspector should distribute 

the SBREFA sheet if he/she is uncertain whether the business meets the definition 

of a “small business”. 
ATTACHMENT B

 U.S. EPA Compliance Assistance Resources

If you own a small business, the United States Environmental Protection Agency (EPA) offers a variety of 

compliance assistance resources and tools to assist you in complying with federal and State environmental laws. 

These resources can help you understand your environmental obligations, improve compliance and find costeffective ways to comply through the use of pollution prevention and other innovative technologies. 

Hotlines, Helplines, and Clearinghouses 

EPA sponsors approximately 89 free hotlines and 

clearinghouses that provide convenient assistance 

regarding environmental requirements. 

The National Environmental Compliance 

Assistance Clearinghouse provides quick access to 

compliance assistance tools, contacts, and planned 

activities from the U.S. EPA, states and other 

compliance assistance providers: 

http://www.epa.gov.clearinghouse 

Pollution Prevention Clearinghouse 

http://www.epa.gov/opptintr/library/ppicindex.htm 

EPA’s Small Business Ombudsman Hotline Can 

provide a list of all the hot lines and assist in 

determining the hotline best meeting your needs. (800) 

368-5888 

Emergency Planning and Community Right-toKnow Act (800) 424-9346 

National Response Center (to report oil and 

hazardous substance spills) (800) 424-8802 

Toxics Substances and Asbestos Information 

(202) 554-1404 

Safe Drinking Water 

(800) 426-4791 

Stratospheric Ozone and Refrigerants 

(800) 296-1996 

Clean Air Technology Center 

(919) 541-0800 

Wetlands Hotline 

(800) 832-7828 

EPA Websites 

EPA has several Internet sites that provide useful 

compliance assistance information and materials for 

small businesses. If you don’t have access to the 

Internet at your business, many public libraries provide 

access to the Internet at minimal or no cost. 

EPA’s Home Page 

http://www.epa.gov 

Small Business Assistance Program 

http://www.epa.gov/ttn/sbap 

Office of Enforcement and Compliance Assurance 

http://www.epa.gov/compliance 

Compliance Assistance Home Page 

http://www.epa.gov/compliance/assistance 

Office of Regulatory Enforcement 

http://www.epa.gov/compliance/civil/index/htm 

Office of Site Remediation Enforcement 

http://www.epa.gov/compliance/cleanup 

Innovative Programs for Environmental 

Performance 

http://www.epa.gov/partners 

Small Business Ombudsman 

www.sba.gov/ombudsman 

Compliance Assistance Centers 

In partnership with industry, universities, and other 

federal and state agencies EPA has established national 

Compliance Assistance Centers that provide Internet 

and “faxback” assistance services for several industries 

with many small businesses. The following 

Compliance Assistance Centers can be accessed 

through the Center’s gateway at 

http://www.assistancecenters.net or by calling the 

phone numbers below and at their respective websites. 

Metal Finishing

 (1-800-AT-NMFRC or http://www.nmfrc.org) 

Printing 

(1-888-USPNEAC or http://www.pneac.org) 

Automotive Service and Repair 

(1-888-GRN-LINK or http://www.ccar-greenlink.org) 
Agriculture 

(1-888-633-2155 or http://www.epa.gov/oeca/ag) 

Printed Wiring Board Manufacturing 

(1-734-995-4911 or http://www.pwbrc.org) 

The Chemical Industry 

(1-800-672-6048 or http://www.chemalliance.org) 

The Transportation Industry 

(1-888-4509-0656 or http://www.transource.org) 

The Paints and Coatings Center 

(1-800-286-6372 or http://www.paintcenter.org) 

Three new centers are under development for the auto 

salvage sector, the construction industry, and the U.S. 

Mexican border waste issues. 

State Agencies 

Many state agencies have established compliance 

assistance programs that provide on-site and other 

types of assistance. Contact your local state 

environmental agency for more information. For 

assistance in reaching state agencies, call EPA’s Small 

Business Ombudsman at (800)-368-5888 or visit the 

Small Business Environmental homepage at 

http://www.smallbiz-enviroweb.org/state.html. 

Compliance Incentives 

EPA provides incentives for environmental compliance. 

By participating in compliance assistance programs or 

voluntarily disclosing and promptly correcting 

violations, businesses may be eligible for penalty 

waivers or reductions. EPA has two policies that 

potentially apply to small businesses: the Audit Policy 

http://www.epa.gov/oeca/auditpol.html) and the Small 

Business Policy 

(http://www.epa.gov/oeca/smbusi.html). These do not 

apply if an enforcement action has already been 

initiated. 

Commenting on Federal Enforcement Actions and 

Compliance Activities 

The Small Business Regulatory Enforcement Fairness 

Act (SBREFA) established an ombudsman (“SBREFA 

Ombudsman”) and 10 Regional Fairness Boards to 

receive comments from small businesses about federal 

agency enforcement actions. The SBREFA 

Ombudsman will annually rate each Agency’s 

responsiveness to small businesses. If you believe that 

you fall within the Small Business Administration’s 

definition of a small business (based on your North 

American Industry Classification System (NAICS) 

designation, number of employees or annual receipts, 

defined at 13 CFR 121.201; in most cases, this means a 

business with 500 or fewer employees), and wish to 

comment on federal enforcement and compliance 

activities, call the SBREFA Ombudsman’s toll free 

number at 1-888-REG-FAIR (1-888-734-3247). 

Every small business that is the subject of an 

enforcement action is entitled to comment on the 

Agency’s actions without fear of retaliation. EPA 

employees are prohibited from using enforcement or 

any other means of retaliation against any member of 

the regulated community because the regulated 

community previously commented on its activities. 

Your Duty to Comply 

If you receive compliance assistance or submit 

comments to the SBREFA Ombudsman or Regional 

Fairness Boards, you still have the duty to comply with 

the law, including providing timely responses to EPA 

information requests, administrative or civil complaints, 

other enforcement actions or communications. The 

assistance information and comment processes do not 

give you any new rights or defenses in any enforcement 

action. These processes do no affect EPA’s obligation 

to protect human health or the environment under any 

of the environmental statutes it enforces, including the 

right to take emergency actions when appropriate. 

Those decisions will be based on the facts in each 

situation. The SBREFA Ombudsman and Fairness 

Boards do not participate in the resolution of EPA’s 

enforcement actions. Also remember that to preserve 

your rights, you need to comply with all rules 

governing the enforcement process. 

EPA is disseminating this information to you 

without making a determination that your 

business or organization is a small business as 

defined by Section 222 of the Small Business 

Regulatory Enforcement and Fairness Act 

(SBREFA) or related provisions. 
Appendix C Large PCB Mark (ML) 

Appendix C 

Large PCB Mark (ML) 

CAUTION 

CONTAINS 

PCBs 

(Polychlorinated Biphenyls) 

A toxic environmental contaminant requiring 

special handling and disposal in accordance with 

U.S. Environmental Protection Agency Regulations 

40 CFR 761 - For Disposal Information contact 

the nearest U.S. E.P.A. Office 

In case of accident or spill, call toll free the U.S. 

Coast Guard National Response Center: 

800-424-8802 

Also contact 

Tel. No. 

PCB Inspection Manual C-1 August 2004 
Large PCB Mark (ML) Appendix C 

Blank Page 

August 2004 C-2 PCB Inspection Manual 
s 

J~jED STS 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

'° WASHINGTON, D .C. 20460 

~ 4( PR0001 

NOV 2 5 2003 

OFFICE OF 

ENFORCEMENT AND 

COMPLIANCE ASSURANCE 

MEMORANDUM 

SUBJECT: Fiscal Year 2004 Inspection Conclusion Data Sheet Reporting Forms 

FROM: Michael M . Stahl 

Director 

Office of Co 

TO: Regional Enforcement Division Directors, Regions 1, 2, 4, 6 and 8 

Regional Media Division Directors, Regions 1-10 

Regional Science and Technology Division Directors, Regions 1-10 

Purpose The purpose of this memorandum is to provide the forms for fiscal year 2004 

Inspection Conclusion Data Sheet (ICDS) data collection/reporting . ICDS 

reporting will continue to be required for the following inspection/evaluation 

programs in 2004: 

• Clean Air Act (CAA) Stationary Source 

• Clean Water Act NPDES, excluding pretreatment inspections 

• Good Laboratory Practices (GLP) 

• Toxic Substances Control Act (TSCA) lead-based paint 

• Clean Air Act Mobile Source 

and for the following new programs (number of 2003 inspections in parentheses) : 

• Resource Conservation and Recovery Act Subtitle C (1643) 

• Underground Storage Tanks (1327) 

• TSCA core, PCBs and asbestos (1090) 

• CAA 112 (r) (632) 

Reporting The regions and headquarters programs have two options for reporting the FY 

2004 ICDS information: 

• Manual reporting : Submit summary ICDS information at mid-year 

(April, 2004) and end-of-year (October, 2004) using the form in 

Attachment A . First-line supervisors need to review the ICDS forms prior 

Internet Address (URL) • http ://www.epa .gov 

Recycled/Recyclable • Printed with Vegetable 00 Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
to compiling the ICDS data for mid-year and end-of-year reporting to verify 

its completeness and accuracy. 

C Integrated Compliance Information System (ICIS): Use ICIS to enter 

the ICDS data. HQ will then pull the ICDS information from ICIS for midyear and end-of-year reporting. 

Goal 5 One reason to continue to expand ICDS to new media programs is the new 

structure of the EPA Strategic Plan. Under Goal 5, Compliance and Environmental 

Stewardship, the sub-objective for Monitoring and Enforcement includes a strategic 

target for the outcomes from compliance inspections. The strategic target is listed 

as “the percentage of regulated entities taking complying actions as a result of 

compliance monitoring.” The measure for this strategic target is dependent upon 

data collected from the ICDS. 

ICDS Forms Attachment A includes: 

C Changes to the ICDS manual form;

C Procedures for reporting ICDS information manually; and the

C FY 2004 Inspection Conclusion Data Sheet Manual Reporting Form

Attachment B includes:

C FY 2004 Process for Entering ICDS Information into ICIS;

C Step-by-Step Process for Entering ICDS Information Into ICIS; and the 

C FY 2004 Inspection Conclusion Data Sheet Form for ICIS Reporting

Data Quality We continue to emphasize it is critically important for regional and HQ first-line 

supervisors (or designated alternates) to review either the manual ICDS forms prior 

to compiling the ICDS data, or the ICDS information entered into ICIS to verify its 

completeness and accuracy. 

If you have questions about this memorandum or the Attachments, please call Ken 

Gigliello at 202-564-7047. We thank you for your attention to this memorandum. 

Attachment A: FY 2004 Inspection Conclusion Data Sheet (ICDS) Manual Reporting Form 

Attachment B: FY 2004 Process for Entering ICDS Information into ICIS 

cc: OC and ORE Division Directors 

Enforcement Coordinators, Regions 1-10 

MOA Coordinators, Regions 1-10 

Field Operations Group, Regions 1-10 

2 
ATTACHMENT A 

FY 2004 Inspection Conclusion Data Sheet Manual Reporting Form 

Changes to the Form in FY 2004: 

The ICDS form has been changed to include the new programs added in FY 2004. 

Additional changes should make it easier for the regions or HQ program to compile the data for 

mid-year and end-of-year reporting and minimize reporting errors. EPA inspectors and first-line 

supervisors (or designated alternates) should find it easier to completely and accurately record the 

ICDS information. The changes include: 

C Added RCRA Subtitle C, UST, TSCA core, PCBs and asbestos, and CAA112 (r) to 

form; 

C Modified the question dealing with observing and communicating deficiencies into 

two (2) separate questions; 

C Modified the two questions on compliance assistance to reflect the national policy 

of the Role of the EPA Inspector in Providing Compliance Assistance During 

Inspections; and 

C Revised the ICDS instructions. 

FY 2004 Reporting Process: 

• After completing the revised attached form, EPA inspectors should forward the 

form to their first-line supervisor or designated alternate. The first-line supervisor 

or designated alternate should review the forms for accuracy and completeness. 

• The first-line supervisor or designated alternate should compile the results from the 

individual ICDS forms completed by the inspectors and fill in the numbers on the 

“ICDS DATA REPORTING FORM FOR FY 2004 MID-YEAR and EOY” 

• The completed “ICDS DATA REPORTING FORM FOR FY 2004 MID-YEAR 

and EOY” should be forwarded to OECA at mid-year (April, 2004) and end-ofyear (October, 2004). 

A-1 
_____________________________________________________________________________________________ 

_____________________________________________________________________________________________ 

FY 2004 EPA MANUAL INSPECTION CONCLUSION DATA SHEET (ICDS) FORM 

Instructions and Definitions for Completing the Information Follow 

1. Region: ______ Facility Name/Location: _____________________________________________ 

2. General Facility Permit ID or Media-Specific Permit ID number (e.g. NPDES permit #):

 ____________________________________________________ 

3. SIC (4-digit) 9 9 9 9 OR NAICS Code (5-digit): 9 9 9 9 9

4. Date of Inspection: __________________________ (mm/dd/yyyy) 

5. Media Type (check one only) 

CAA-Stationary 9 CWA-NPDES 9 GLP 9 TSCA Lead Paint 9 CAA 112r 9 

CAA-Mobile Sources 9 RCRA 9 UST 9 TSCA core, PCBs, asbestos 9 

6. Deficiencies: Did you observe deficiencies during inspection? ”Yes ”No [N/A is not allowed] 

a. If YES, go to #7 

b. If NO, go to #9 

7. If YES: Did you communicate the deficiencies to the facility during the inspection? ”Yes ”No 

8. Actions Taken: Did you observe or see the facility take any actions during the inspection to address the 

deficiencies communicated? ” Yes ” No [N/A is not allowed] 

a. If NO, go to #9 

b. If YES, check the action(s) taken, or describe any other actions taken. (Check all that apply) 

Action(s) taken 

____ Verified compliance with previously issued enforcement action -part or all conditions 

____ Corrected recordkeeping deficiencies 

____ Corrected monitoring deficiencies 

____ Completed a notification or a report 

____ Requested a permit application 

____ Implemented new or improved management practices or procedures 

____ Improved pollutant identification (e.g., labeling, manifesting, storage, etc.) 

____ Reduced pollution (e.g., use reduction, industrial process change, emissions or discharge change, 

etc.). Specify the pollutant(s) reduced only if this action is checked.. 

Water: Ammonia 9 BOD 9 COD 9 TSS 9 O/G 9 TC 9 DO 9 Metals 9 CN 9

Air: NOx 9 SO2 9 PM 9 VOC 9 Metals 9 HAPs 9 CO 9

List other actions observed or other pollutants reduced: ________________________________________ 

9. Assistance: Did you provide general assistance based on national policy? Yes ” No ”

 Did you provide site-specific assistance based on national policy? ” Yes ” No 

Note: EPA inspectors are not required to provide compliance assistance. 

Optional Information: Describe actions taken or assistance provided to assist the facility. 

A-2 
NOTE TO EPA INSPECTORS: 

The main purpose of EPA inspections/evaluations is to determine compliance with environmental regulations and 

enforcement agreements. Secondary purposes include providing a field presence to create a credible deterrent and 

providing assistance, when appropriate, to help facilities achieve compliance. 

• The ICDS is used to identify observable corrections to deficiencies and compliance assistance activities. 

ICDS is NOT designed to capture all of the observations, findings, and other data contained in the final 

inspection report. Deficiencies identified as potential violations, and actions to address deficiencies noted on 

the ICDS must be included in the final EPA inspection report. 

• ICDS information will be used to collect accomplishments of EPA’s national inspection efforts, develop 

inspection outcomes for GPRA, and manage national compliance monitoring resources. 

• The information will NOT be used to track individual EPA inspectors’ performance. 

• The ICDS should only be used for EPA-led inspections, not for state oversight inspections. 

Instructions for each question: 

1. Region, Facility Name/Location: Enter the Region, and facility name/location (for unpermitted facilities). 

2. Permit ID#: Enter either the Facility Registration System (FRS) permit ID or media-specific ID # (e.g., 

NPDES, CAA, or RCRA permit number). 

3. SIC/NAICS Codes: Identify the SIC or NAICS code at (http://www.commerce.gov), 

(http://www.osha.gov/oshstats/sicser.html), (http://www.census.gov/epcd/www/naics.html), by CD-rom 

(PB98-502024- NTIS (800-553-6847), or OC Inspector Website (http://intranet.epa.gov/oeca/inspector) 

4. Date of Inspection: Enter the beginning date of the inspection (e.g., 04/10/2004) 

5. Media Type: Check the environmental media program inspection being conducted. 

6. Deficiencies: Check YES or NO. EPA inspectors should follow the regional policy on when and how to 

inform facilities of deficiencies. Deficiencies are defined as potential violations. Deficiencies are NOT 

compliance determinations (further review is needed to determine violations). A list of potential deficiencies 

is on the ICIS compliance monitoring screen. (https://caribou.rtpnc.epa.gov/ICIS/) 

7. Communication: Check YES or NO. N/A is not allowed. 

8. Actions Taken: Check YES or NO. If Yes, check only action(s) actually observed/seen, or write in a short 

description of the action in the “Other” section. These are not compliance determinations. Check the box to 

specify the pollutant: Ammonia – NH3-N, ammonia nitrogen, ammonia as N, BOD-Biochemical Oxygen 

Demand, COD- Chemical Oxygen Demand, TC-Total Coliform, TSS- Total Suspended Solids, SS, Settleable 

solids, O/G- Oil and Grease, DO- Dissolved Oxygen, NOx- Nitrogen Oxides, SO2- Sulphur Dioxide, PMParticulate Matter, VOC- Volatile Organic Compound, CN- Cyanide, HAPs – Hazardous Air Pollutants, COCarbon Monoxide, Metals- Hexavalent Chromium, Lead, Mercury, etc. Write in other pollutants if not listed. 

The Case Conclusion Data Sheet Training Booklet [November, 2000] provides additional information on 

actions taken. The Training Booklet can be obtained by calling the Office of Compliance(202-564-6004). 

9. Compliance Assistance: Inspectors are not required to provide compliance assistance during inspections. 

Check YES or NO to the two questions. General compliance assistance involves distributing prepared 

information on regulatory compliance, P2 or other written materials/websites. Refer to National Policy: Role 

of the EPA Inspector in Providing Compliance Assistance During Inspections, June, 2003 for more 

information for examples of site-specific assistance. The policy is available on the EPA website 

(www.epa.gov), the Inspector Website (http://intranet.epa.gov/oeca/inspector), or calling (202-564-2300). 

Data Collection Process: 

o Inspectors must complete the ICDS immediately after the inspection is conducted. 

o Inspector should forward completed forms to first-line supervisor/designated alternate within five (5) days after 

returning from either a single inspection, or a series of inspections. 

o The first-line supervisor/designated alternate must review the ICDS for completeness and accuracy and compile 

the ICDS information by media program to report ICDS results using the consolidated manual reporting form. The 

consolidated manual reporting form will be sent to HQ for mid-year 2004 & end-of-year 2004 reporting. 

A-3 
_________ 

________ 

________ 

ICDS DATA MANUAL REPORTING FORM FOR FY 2004 MID-YEAR AND EOY 

REPORT BY MEDIA PROGRAM 

IMPORTANT NOTE: 

This is the only form the region must submit if they are using manual reporting instead of ICIS reporting. 

DO NOT SEND INDIVIDUAL ICDS FORMS TO OECA. 

• Total number of on-site inspections/evaluations conducted ___________ 

• Number of on-site inspections/evaluations where deficiencies were observed ___________ 

• Number of inspections/evaluations where deficiencies were communicated to the facility 

• Number of on-site inspections/evaluations where the facility took action to address deficiencies 

noted during the inspection or evaluation ___________ 

• Total number of inspections/evaluations where general compliance assistance was provided 

• Total number of inspections/evaluations where site-specific compliance assistance was provided 

• Total number of SIC/NAICS codes inspections/evaluations ___________ 

# List the SIC/NAICS codes and (# of inspections for each SIC/NAICS code): 

SIC example: 4513 (10), 3922 (2), 3713 (4), 1209 (6), 4522 (12) 

NAICS example: 45123 (18), 21456 (6), 32785 (3), 20575 (7) 

A-4
ATTACHMENT B 

FY 2004 Process for Entering ICDS Information into ICIS 

If the regions and the HQ inspection/evaluation programs decide to use ICIS to report the 

ICDS information, they will also need to determine who will be responsible for entering the data 

into ICIS. There are two options: 

1. Require EPA inspectors to enter the data directly into ICIS 

2. Require central data processing personnel to enter the data into ICIS 

While each approach has advantages and disadvantages, HQ strongly supports data 

entry by EPA inspectors. By enabling and requiring EPA inspectors to be responsible for ICIS 

data entry, it: 

• eliminates the need for completing the ICDS form (inspectors may still want to 

complete the form) 

• makes EPA inspectors more accountable for data quality of inspections, and 

• encourages EPA inspectors to utilize the ICIS data system more fully 

If EPA inspectors will be responsible for ICIS data entry: 

The EPA inspectors will need to be provided access to ICIS and will need some training 

from the regional/HQ ICIS coordinator. EPA inspectors will not be required to complete 

the ICDS form since all of the ICDS information should be included in the inspector’s 

notes to complete the ICIS data entry process. EPA inspectors can choose to complete the 

form in the field directly after the inspections to facilitate ICIS data entry at a later date. 

If non-EPA inspectors (regional data entry personnel) will be responsible for ICIS 

data entry: 

EPA inspectors will have to complete the longer ICDS form to enable the data entry 

personnel to efficiently enter the ICDS data into ICIS. After completing the longer form, 

EPA inspectors should forward it to their first-line supervisor or designated alternate. The 

first-line supervisor or designated alternate should review the forms for accuracy and 

completeness, and then forward the forms to the central data entry personnel. Inspectors 

can photocopy the ICDS form for their inspections. 

Page 1 
Step-by-Step Process for Entering ICDS Information Into ICIS 

The data fields below are required for ICDS. Not all ICIS data fields are required to be entered 

for ICIS. Regions may decide to enter additional data fields for their own purposes. 

• Acquire access to the ICIS data system through the regional or HQ ICIS contact 

• Log onto the ICIS system: https://caribou.rtpnc.epa.gov/ICIS/ with a user ID & password 

• Click on "Data Entry" 

• Click on "Add Compliance Monitoring" 

• Complete the data fields on the ICIS screens. The majority of the data fields have pull 

down menus to assist in making data entry simple and straightforward. 

The data fields that need to be completed for ICDS information are: 

1. Compliance Activity Type (Select Compliance Inspection only) 

2. Compliance Monitoring Activity Name (Type in the name of facility, site, etc.) 

3. Compliance Monitoring Type (There is a long list segregated by statute. Click on only one 

compliance monitoring type - e.g., Clean Air Act Full Compliance Evaluation FCE, RCRA 

Compliance Evaluation Inspection CEI, etc.) 

4. Region (Select the appropriate region) 

5. Facilities (enter the facility name) 

6. Federal Statutes (Select either the CAA, CWA, RCRA, or TSCA) 

7. Sections (Select the appropriate statutory section that was inspected) 

8. SIC and NAICS code (Select the appropriate SIC or NAICS code inspected) 

9. Compliance Monitoring Action Reason (Select on either Agency priority, Citizen 

compliant, Core program, selected monitoring action, or random evaluation/inspection) 

10. Compliance Monitoring Action Type (Select EPA only) 

11. Select Yes, if you observed deficiencies during the inspection/evaluation. 

12. Select Yes, if you communicated the deficiencies to facility during inspection 

13. If Yes to question #12, click on Edit Deficiencies and select the deficiencies observed 

during the inspection/evaluation listed from the pull down menu. 

14. Click Yes or No on whether actions were taken by the facility to address deficiencies 

observed? You must select NO if the answer to question #12 was NO. 

15. If Yes to question #14, click on Edit Corrective Actions and select the appropriate actions 

listed on the pull down menu 

16. If one of the actions taken was "Reduced Pollution", click on Edit Water Pollutants or Edit 

Air Pollutants and select the pollutants reduced. 

17. Click Yes or No on whether general compliance assistance was provided during the 

inspection or evaluation 

18. Click Yes or No on whether site-specific compliance assistance was provided during the 

inspection or evaluation 

19. The inspector can add comments about the inspection or evaluation in the optional 

"Summary of Comments". 

20. Hit "Save" and the ICDS information entered is saved in the ICIS system 

Page 2 
C

FY 2004 Inspection Conclusion Data Sheet (ICDS) Form for ICIS Reporting 

* Data elements required to be completed for the ICIS system 

** Data elements required for Inspection Conclusion Data Sheet reporting 

Data elements that do not have asterisks are optional 

For Data Entry Staff Use Only 

Date Information is Entered into ICIS (mm/dd/year): ____________________ 

EPA Inspector Name: ______________________________________

EPA Inspector Phone # (include entire phone # 404-566-9000): ____________________

THIS FORM MIRRORS THE FORMAT OF THE ICIS DATA ELEMENTS

1. *Compliance Activity Type: (enter Compliance Inspection only) _________________________ 

2. *Compliance Monitoring Activity Name: ____________________________________________ 

3. *Compliance Monitoring Type: Circle ONLY ONE of the following choices: 

CLEAN AIR ACT (CAA) 

CAA Asbestos Demolition and Renovation 

CAA Case Development Inspection 

CAA Full Compliance Evaluation (FCE ) 

CAA Partial Compliance Evaluation (PCE) 

CAA Stack Test 

CAA 112 (r)(7) Desk Audit 

CAA 112 (r) (7) Inspection (i.e., site visit) 

CAA 112 General Duty Clause inspection 

CAA CFR Section 68.220 Desk Audit 

CAA CFR Section 68.220 Site Visit 

CAA CFR Section 608 Stratospheric Ozone inspection 

CAA CFR Section 609 Stratospheric Ozone inspection 

CAA Motor vehicle fuels (Section 211) 

CAA Motor vehicle/engine (Section 203) 

CAA Wood Heater Evaluation 

CLEAN WATER ACT (CWA) 

CWA Compliance Evaluation Inspection (CEI )

CWA Compliance Biomonitoring Inspection (CBI)

CWA Compliance Schedule Evaluation (CSE)

CWA Compliance Sampling Inspection (CSI)

CWA Case Development Inspection (CDI)

CWA Combined Sewer Overflow (CSO) inspection

CWA Concentrated Animal Feeding Operation inspection

CWA Diagnostic Inspection (DI)

CWA Performance Audit Inspection (PAI)

CWA Pretreatment Audit

CWA Preatreatment Compliance Inspection (PCI)

CWA Pretreatment Industrial User Non-sampling Insp. 

CWA Pretreatment Industrial User Sampling Inspection 

CWA Reconnaissance Inspection (RI) 

CWA Sanitary Sewer Overflow (SSO) inspection 

CWA Section 311 SPCC Inspection 

CWA Section 311 SPCC Plan Review 

CWA Stormwater inspection 

CWA Toxics Sampling inspection 

CWA Section 404 Wetlands 

CWA Sewage Sludge Inspection 

EPCRA 

EPCRA 313 Data Quality Inspection 

EPCRA 313 Non/Late reporter Inspection 

EPCRA 304/CERCLA 103 Inspection 

EPCRA 311/312 inspection 

FIFRA 

FIFRA Good Laboratory Practices 

FIFRA Agricultural Use inspection 

FIFRA Agriculture Use follow-up inspection 

FIFRA Non-Agriculture Use inspection 

FIFRA Non-Agriculture Use follow-up inspection 

FIFRA Experimental Use inspection 

FIFRA Producing Establishment inspection 

FIFRA Marketplace inspection 

FIFRA Import inspection 

FIFRA Export inspection 

FIFRA Certified applicator inspection 

FIFRA Use Restricted Pesticide Dealer inspection 

FIFRA Worker Protection Standards inspection 

Page 3 
RCRA Hazardous or UST 

RCRA or UST Compliance Evaluation Inspection (CEI )

RCRA or UST Compliance Schedule Evaluation (CSE)

RCRA or UST Compliance Sampling Inspection (CSI)

RCRA Comp. Groundwater Monitoring Evaluation(CME)

RCRA Corrective Action Oversight (CAO)

RCRA Laboratory Audit Inspection

RCRA Non-Financial Record Review

RCRA Operation and Maintenance Inspection (OAM)

RCRA or UST Case Development Inspection (CDI)

RCRA or UST Follow-up inspection

RCRA Illegal operators inspection

RCRA or UST Focused Compliance Inspection (FCI)

RCRA or UST Citizen complaint inspection

SDWA (Public Water Supply & UIC) 

SDWA Sanitary survey 

SDWA UIC inspection 

TSCA 

TSCA AHERA, federally conducted 

4. *Region: ___ 

TSCA AHERA, SEE conducted 

TSCA Section 6 Asbestos Ban, Federal conducted 

TSCA Section 6 Asbestos Ban, SEE conducted 

TSCA Asbestos MAP, federally conducted 

TSCA Asbestos MAP, SEE conducted 

TSCA Section 6 Asbestos Worker Protection, federally 

conducted 

TSCA Section 6 Asbestos Worker Protection, SEE 

conducted 

TSCA Good Laboratory Practices 

TSCA Core (Sections 5 and/or 8) 

TSCA Polychlorinated Biphenyls (PCBs) 

TSCA Section 1018 Lead Paint 

TSCA Section 12/13 Imports/Exports 

TSCA Section 402/404 inspections 

TSCA Section 406 inspections 

OTHER 

Other Oversight Inspection 

Statistically valid non-compliance rate inspection 

5. *Facilities Name and Location: ___________________________________________ 

6. Planned Start: _____________ (mm/dd/yyyy) 

7. Planned End: _____________ (mm/dd/yyyy) 

8. **Actual Start: _____________ (mm/dd/yyyy) 

9. **Actual End: _____________ (mm/dd/yyyy) 

10. *Federal Statutes: Check only ONE of the following: 

CAA ____ CWA ____ CERCLA____ EPCRA____ FIFRA____ MCBRMA____ 

RCRA ____ SDWA ____ TSCA ____ 

11. *Sections: Circle or check the statutory section that applies to the inspection or the evaluation 

Statute Statutory Section 

Clean Air Act (CAA): 

CAA 110 

CAA 111 

CAA 112 

CAA 112(r)(1) 

CAA 112(r)(7) 

CAA 118 

CAA 129 

CAA 183(e)(A) 

CAA 183(e)(B) 

State Implementation Plans (SIPs)- National Primary & Secondary Ambient Air Quality Standards 

Standards of Performance for New Stationary Sources (NSPS) 

National Emission Standards for Hazardous Air Pollutants (NESHAPS/MACTs 

Prevention of Accidental Release/General Duty Clause 

Prevention of Accidental Release/Risk Management Plans 

Control of Pollution from Federal Facilities Control of Pollution from Federal Facilities 

Solid Waste Fuel Combustion 

Federal Ozone Measures - Best Available Controls 

Federal Ozone Measures – Consumer or Commercial Products 

Page 4 
CAA 183(f) Federal Ozone Measures – Tank Vessel Standards 

CAA 202 Emission Standards for New Motor Vehicles or New Motor Vehicle Engines 

CAA 203 Prohibited Acts – Motor Vehicle & Motor Vehicle Engines 

CAA 207 Compliance by Vehicles and Engines in Actual Use 

CAA 208 Information Collection from Motor Vehicle Manufacturers 

CAA 211 Regulation of Fuels for Motor Vehicle and Engines 

CAA 213 Emission Standards for Nonroad Engines and Vehicles 

CAA 219 Urban Bus Standards and Retrofit Requirements 

CAA 608 Stratospheric Ozone– National Recycling & Emission Reduction Program 

CAA 609 Stratospheric Ozone – Servicing of Motor Vehicle Air Conditioners 

CAA 610 Stratospheric Ozone– Nonessential Products Containing Chlorofluorocarbons 

CAA 611 Stratospheric Ozone – Labeling 

CAA Part C Prevention of Significant Deterioration (PSD) of Air Quality 

CAA Part D Requirements for Non Attainment Areas/SIP Provisions 

CAA Title IV Acid Rain 

CAA Title V Operating Permits 

Clean Water Act (CWA) 

CWA 301/307 Effluent Limitations – NPDES Toxic and Pretreatment Effluent Standards 

CWA 301/311 Effluent Limitations – Oil and Hazardous Substance Liability Effluent Limitations 

CWA 301/404 Effluent Limitations –Permits for Dredged or Fill Material 

CWA 308(a)(B) Records and Reports; Inspections – Sanitary Sewer Overflows 

CWA 308(a)(B) Records and Reports; Inspections – Combined Sewer Overflows 

CWA 308(a)(B) Records and Reports; Inspections – Stormwater 

CWA 308(a)(B) Records and Reports; Inspections – Concentrated Animal Feeding Operations 

CWA 308(a)(B) Records and Reports; Inspections – Biosolids/Sewage Sludge 

CWA 308(a)(B) Records and Reports; Inspections – Aquaculture 

CWA 308(a)(B) Records and Reports; Inspections – Other Permit Violations, Base Program Limits, Reporting, 

Schedule 

CWA 308(a)(B) Records and Reports; Inspections – Information Requests 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 

CERCLA 103(a) Notification requirements respecting released substances 

CERCLA 104(e) Information gathering and access 

CERCLA 106 Abatement actions – Response Actions by Potentially Responsible Parties 

CERCLA 107(a) Liability – Cost Recovery 

Emergency Planning and Community Right to Know Act (EPCRA) 

EPCRA 302 Substances and Facilities Covered and Notification 

EPCRA 303 Comprehensive Emergency Response Plans 

EPCRA 304 Emergency Notification Section 313 program 

EPCRA 311 Material Safety Data Sheets 

EPCRA 312 Emergency and Hazardous Chemical Inventory Forms 

EPCRA 313 Toxic Chemical Release Forms (TRI) 

EPCRA 325 Enforcement: Civil & Administrative Penalties, & Procedures for Administrative Penalties including 

subpoenas 

Mercury Containing Battery Recycling Management Act (MCBRMA) 

MCBRMA 103A Rechargeable Batteries, Rechargeable Consumer Products, Easy Removability and Labeling 

MCBRMA 6 Records, Reports, Access – Battery Recycling 

Page 5 
Resource Conservation and Recovery Act (RCRA) & Underground Storage Tanks (UST) 

RCRA 3002 Standards Applicable to Generators of Hazardous Waste 

RCRA 3003 Standards Applicable to Transporter of Hazardous Waste 

RCRA 3004 Standards Applicable to Owners/Operators of Hazardous Waste Treatment, Storage & Disposal 

Facilities 

RCRA 3005 Permits for Treatment, Storage or Disposal of Hazardous Waste 

RCRA 3010 Notification of Hazardous Waste Activity 

RCRA 3013 Monitoring, Analysis, Testing 

RCRA 3014 Restrictions on Recycled Oil 

RCRA 3017 Export of Hazardous Wastes 

RCRA 3020 Interim Control of Hazardous Waste Injection 

RCRA 7003 Interim Control of Hazardous Waste Injection 

RCRA 9002 Notification of Underground Storage Tanks 

RCRA 9003 Release, Detection, Prevention, and Correction Regulations 

RCRA 9005 Inspections, Monitoring, Testing and Corrective Action 

RCRA 9006 Federal Enforcement: Compliance Orders, Procedure, Contents, Civil Penalties 

Toxic Substances Control Act (TSCA) 

TSCA 4 Testing of Chemical Substances and Mixtures 

TSCA 5 Manufacturing and Processing Notices 

TSCA 6 Regulation of Hazardous Chemical Substances and Mixtures (includes PCBs and asbestos) 

TSCA 7 Imminent Hazards 

TSCA 8 Reporting and Retention of Information 

TSCA 11 Inspections and Subpoenas 

TSCA 12 Exports 

TSCA 13 Entry into Customs Territory of the U.S. 

TSCA 14 Disclosure of Data 

TSCA 15 Prohibited Acts 

TSCA 203 EPA Regulations -- Asbestos in Schools 

TSCA 206 Contractor and Laboratory Accreditation 

TSCA 208 Emergency Authority 

12. **Citations: Enter the regulatory citation(s) that apply to the inspection conducted

 _____________ __________ __________ __________ 

13. * Programs: No entry needed. This data element is automatically populated by the ICIS data system based on 

the information provided in items #10 and #11. 

14. **SIC (4-digit) or NAICS Code (5-digit): 

15. Media Monitored: Check only ONE of the following: 

Air ____

Animals (only applies to FIFRA) ____

Humans (only applies to FIFRA) _____

Land (includes RCRA waste, FIFRA Pesticides, TSCA Asbestos and PCBs) ____

Plants (only applies to FIFRA) ____

Schools/Housing/Buildings (includes TSCA lead paint and asbestos) ____

Soil (CERCLA and RCRA Corrective Action, TSCA PCBs, UST soil, UIC remedial activities) ____

Water (biosolids and other sludges) ____ Water (drinking) ____ Water (ground) ____

Water (navigable) ____ Water (sediment) ____ Water (stormwater)____

Water (wastewater to or from POTW) _____ Water (wetlands) _____

Page 6 
16. *Compliance Monitoring Action Reason: (Check only one of the following) 

Agency Priority ____ Citizen Complaint/Tip ____ Core Program _____

Selected Monitoring Action _____ Random Evaluation or Inspection _____

17. *Compliance Monitoring Agency Type: _____________ (EPA is only choice) 

18. If State, local or tribal lead, did EPA assist: Does not apply to ICDS activities. Leave the box blank. 

19. Number of days physically conducting the activity: _____________ 

20. Number of hours spent physically conducting the activity: _________ 

21. Compliance Monitoring Action Outcome: Check one (if known at the time of the activity): 

Administrative ____ Immediately corrected ____ Judicial ____ No violation ____ 

No compliance monitoring (access denied ) ____ No compliance monitoring (facility shutdown) ____ 

Not immediately corrected ____ Notice of Determination ____ Under review ____ 

Withdrawn ____ 

22. MOA Priorities: (Circle only one that apply from the following) 

CAA Air Toxics and NSR/PSD - Coal-Fired Power Plant(SIC 4911)

CAA Air Toxics and NSR/PSD - NSR

CAA Air Toxics and NSR/PSD - PSD

Petroleum Refining - Benzene Waste (BENZW)

Petroleum Refining - LDAR (LDAR)

Petroleum Refining - Refinery Fuel Gas (REFFG)

RCRA - Misidentified Wastes (RMISWT)

RCRA - Permit Evaders (RCRPE)

SDWA Microbial - SWTR Violations (SWTR)

SDWA Microbial - TCR Violations (PWTCR)

Wet Weather - CAFO (AFLOT)

Wet Weather - Combined Sewer Overflow (CSO)

Wet Weather - Sanitary Sewer Overflow (SSO)

Wet Weather - Stormwater (STORM)

23. Regional Priorities: (Check only one that apply from the following) 

Agriculture FIFRA Distributor Registrants Comp.with FIFRA Section 3 

Consumer Confidence Rule (CCR) under Safe Drinking Water Act Endangered Ecosystems 

EPCRA and CAA Section 112(r) Accident History by Facility Lead-Based Paint 

EPCRA and CAA Section 112(r) Accident History by Sector RCRA Permit Evaders 

EPCRA and CAA Section 112(r) St. Louis Project Sensitive Populations 

24. **Did you observe deficiencies (potential violations) during the on-site inspection? ” Yes ” No 

**If you observed deficiencies, did you communicate them to facility during the inspection? 

” Yes ” No 

**If deficiencies were observed select one or more of the following: 

Potential violation of a compliance schedule in an enforceable order____

Potential failure to maintain a record or failure to disclose a document____

Potential failure to maintain/inspect/ repair equipment including meters, sensors, and recording equipment 

Potential failure to complete or submit a notification, report, certification, or manifest____

Potential failure to obtain a permit, product approval, or certification____

Potential failure to follow a required sampling or monitoring procedure or laboratory procedure____

Potential failure to follow or develop a required management practice or procedure____

Potential failure to identify and manage a regulated waste or pollutant in any media____

Potential failure to report regulated events such as spills, accidents, etc.____

Potential incorrect use of a material (e.g., pesticide, waste, product)or use of improper/unapproved material_

Potential failure to follow a permit condition(s) ____

Potential excess emission in violation of a regulation _____

Page 7 
_______________________________________________________________________________________________ 

_______________________________________________________________________________________________ 

_______________________________________________________________________________________________ 

___________________________________________________________________________________________ 

27. **Did you observe or see the facility take any actions during the inspection to address the deficiencies 

communicated to the facility? ” Yes ” No 

If YES, check only the action(s) actually observed/seen and/or write a short description of the action in the “optional” 

section. (Check all of the actions that apply) 

Action(s) taken 

Complete(d) a Notification or Report 

Correct(ed) Monitoring Deficiencies 

Correct(ed) Record Keeping Deficiencies 

Implemented New or Improved Management Practices or Procedures 

Improved Pollutant Identification (e.g., Labeling, Manifesting, Storage, etc.) 

Reduced Pollution (e.g., Use Reduction, Industrial Process Change, Emissions or Discharge Change, etc.) 

Request(ed) a Permit Application or Applied for a Permit 

Verify (ied) Compliance with Previously Issued Enforcement Action - Part or All Conditions 

The following common air or water pollutant(s) should only be checked if the “Reduced Pollution” action 

was checked. 

Water: Ammonia 9 BOD 9 COD 9 TSS 9 O/G 9 Total Coliform 9 D.O. 9 Metals 9 Cyanide 9

Other___________________________________ 

Air: NOx 9 SO2 9 PM 9 VOC 9 Metals 9 HAPs 9 CO 9

Other_______________________________________________

28. Did you provide general compliance assistance in accordance with the policy on the Role of the EPA 

Inspector in Providing Compliance Assistance During Inspections? ” Yes ” No 

29. Did you provide site-specific compliance assistance in accordance with the policy on the Role of the EPA 

Inspector in Providing Compliance Assistance During Inspections? ” Yes ” No 

Note: This form does not require EPA inspectors to provide compliance assistance. 

Optional Information: Describe actions taken by the facility or assistance provided to the facility: __________ 

EPA Form 3540-39 

Page 8 
NOTE TO EPA INSPECTORS 

The main purpose of EPA inspections/evaluations is to determine compliance with environmental regulations and 

enforcement agreements. Secondary purposes include providing a field presence to create a credible deterrent and 

providing assistance, when appropriate, to help facilities achieve compliance. 

• The ICDS is designed to identify readily observable corrections to deficiencies and compliance assistance 

activities. ICDS is NOT designed to capture ALL of the observations, findings, and other data contained in the 

final inspection report. Deficiencies identified as potential violations, and actions to address deficiencies noted on 

the ICDS must be included in the final inspection/evaluation report. 

• ICDS information will be used to collect accomplishments of EPA’s national inspection/evaluation efforts, 

develop outcomes for GPRA, and manage national compliance monitoring resources. 

• The information will NOT be used to track individual EPA inspector’s performance. 

• The ICDS should only be used for EPA-led inspections or evaluations, not for oversight inspections of the states. 

Instructions for Each Question: 

1. Compliance Activity Type: EPA inspectors should only enter compliance inspection. This choice includes Clean 

Air Act Full Compliance Evaluations (FCEs) and Partial Compliance Evaluations (PCEs) 

2. Compliance Monitoring Activity Name: Enter the actual name of the facility inspected/evaluated 

3. Compliance Monitoring Type: There are a number of choices listed in alphabetical order by statute. Circle the 

appropriate choice pertaining to the type of inspection or evaluation conducted. Circle only one choice. 

4. Region: Enter the EPA region or HQ associated with the inspection/evaluation. 

5. Facilities: Enter the facility name. If the facility is in FRS, it will automatically populate when you enter 

sufficient information. If the facility is not in FRS, the data entry person will have to create a new facility to link 

to FRS. 

6. Planned Start Date of Inspection: Enter the planned start of the inspection/evaluation 

7. Planned End Date of Inspection: Enter the planned end date of the inspection/evaluation 

8. Actual Start Date of Inspection: Enter the actual start date of the inspection/evaluation 

9. Actual End Date of Inspection: Enter the actual end date of the inspection/evaluation 

10. Federal Statutes: Check only one of the statutes listed that applies to the inspection/evaluation being conducted. 

11. Sections: Enter the section(s) of law(s) that authorize the compliance inspection/evaluation. Examples: Solid 

Waste Disposal Act Section 3002 for RCRA generator inspections, Clean Air Act Section 112 for MACT partial 

compliance evaluations, and CWA Section 308 for NPDES inspections. NOTE: When selecting a statute from 

the previous data element, ICIS provides a pull down list of the statutory sections available for that statute. 

12. Citations: Enter the regulatory citations that were inspected or evaluated during the on-site activity. 

Examples: RCRA:40 CFR 262.11 and 40 CFR 265.31,

CAA: 40 CFR 63.1254 and 40 CFR 60.703

CWA:40 CFR 129.8 and 40 CFR 122.41

13. Programs: This data element is automatically generated by ICIS when completing items #10 and #11. 

14. SIC/NAICS Codes: Identify the code corresponding to the facility. Guidance on how to identify SIC or NAICS 

codes can be downloaded at (http://www.doc.gov), CD-rom (PB98-502024) by calling NTIS (800-553-6847), or 

Inspector Website (http://intranet.epa.gov.oeca/oc/metd/inspector). 

15. Media Monitored: Check one or more of the fifteen (15) choices listed. 

16. Compliance Monitoring Action Reason: Check only one of the five (5) reasons for performing the 

inspection/evaluation. 

Page 9 
17. Compliance Monitoring Agency Type: Write in EPA. This is the only choice that should be entered 

18. If State, local or tribal lead, did EPA assist: Does not apply to ICDS activities. Leave the box blank. 

19. Number of days physically conducting the activity Enter the number of days to conduct the 

inspection/evaluation 

20. Number of hours spent physically conducting the activity: Enter the number of hours it took to conduct the 

inspection/evaluation 

21. Compliance Monitoring Action Outcome: Check one of the outcomes associated with the inspection/evaluation 

(if known at the time of the inspection or evaluation) 

22. MOA Priorities: These are the national priorities. Choose only one that applies to the inspection/evaluation 

23. Regional Priorities: These are the regional priorities. Choose only one that applies to the inspection or 

evaluation. 

24. Did you Observe Deficiencies: Check YES or NO. 

25. Communicating Deficiencies: If Yes to question #24, did you communicate the deficiencies to the facility? 

Check YES or NO. EPA inspectors should follow the Regional policy on when and how to inform facilities of 

deficiencies. Deficiencies are defined as readily observable violations of statues, permits, or regulations. 

Deficiencies are NOT compliance determinations (further review by a compliance officer or attorney is needed to 

determine actual violations). 

26. Deficiencies Observed: Check one or more of the eleven (11) choices. 

27. Actions Taken: Check YES if you observed the facility taking actions. Check only the action(s) actually 

observed/seen, or write a short description of the action in the “Optional” section. These are not compliance 

determinations. If the Reduced Pollution Box is checked, specify the pollutant(s): Other -- any pollutant 

besides listed below. Ammonia – NH3-N, ammonia nitrogen, ammonia as N, BOD-Biochemical Oxygen 

Demand, COD- Chemical Oxygen Demand, TC-Total Coliform, TSS- Total Suspended Solids, SS, Settleable 

solids, O/G- Oil and Grease, DO- Dissolved Oxygen, NOx- Nitrogen Oxides, SO2- Sulphur Dioxide, PMParticulate Matter, VOC- Volatile Organic Compound, CN- Cyanide, HAPs – Hazardous Air Pollutants, COCarbon Monoxide, Metals- Hexavalent Chromium, Lead, Mercury, etc. You can write in other pollutants if not 

listed. The Case Conclusion Data Sheet Training Booklet [November, 2000] provides additional information on 

actions taken. The Training Booklet can be obtained by calling the Office of Compliance at 202-564-6004. 

28. General Compliance Assistance: Check YES if the EPA inspector provided general compliance assistance 

during the inspection or evaluation. Inspectors are not required to provide compliance assistance during 

inspections. General compliance assistance includes distributing or sharing information on industry regulatory 

compliance, pollution prevention, or technical written assistance materials or websites and EPA, state and local 

assistance programs. 

29. Site-Specific Compliance Assistance: Check YES if the EPA inspector provided site-specific compliance 

assistance during the inspection or evaluation. Inspectors are not required to provide compliance assistance 

during inspections. Site-specific compliance assistance is defined in the National Policy on the Role of the EPA 

Inspector in Providing Compliance Assistance During Inspections, dated June 25, 2003. 

Data Collection Process: 

o Inspectors should complete the ICDS form immediately after the inspection or evaluation is completed.

o Completed forms should be forwarded to the first-line supervisor or designated alternate within five (5) days after

returning from either a single inspection/evaluation or a series of inspections/evaluations.

o The first-line supervisor or designated alternate should review the ICDS for completeness and accuracy.

o The first-line supervisor or designated alternate should then forward the form to the central data entry personnel for

entry of the data into ICIS.

Page 10 
Appendix E PCB Manufacturers and Trade Names 

Appendix E 

PCB Manufacturers and Trade Names 

Manufacturer PCB Fluid Trade Name 

Aerovox Hyvol 

Allis-Chalmers Chlorextol 

American Corporation Asbestol 

Axel Electronics -

Bayer (Germany) Clophen 

Caffaro (Italy) DK, Fenclor, Inclor 

Capacitor Specialists -

Chernko (Czechoslovakia) -

Cornell Dubilier Dykanol 

Dings Company -

Electrical Utilities Corporation Eucarel 

Electro Engineering Works -

Electromagnetic Filter Company -

Envirotech Buell -

Eriez Magnets Pyranol 

ESCO Manufacturing Company Askarel* 

Ferranti-Packard Limited Askarel* 

General Electric Pyranol 

Geneva Industries -

H.K. Porter -

Helena Corporation -

Hevi-Duty Electric Askarel* 

ITE Circuit Breaker Non-Flammable Liquid 

PCB Inspection Manual E-1 August 2004 
PCB Manufacturers and Trade Names Appendix E 

Manufacturer PCB Fluid Trade Name 

Jard Corporation Clorphen 

Kanegafuchi (Japan) Kennechlor 

Kuhlman Electric Saf-T-Khul 

Maloney Electric -

McGraw Edison Elemex 

Mitsubishi (Japan) Kennechlor, Santotherm 

Monsanto (US and UK) Aroclor 

Monsanto (US) Therminol, Pydraul, Santovac 1 and 2 

Monsanto (UK and Japan) Santotherm FR 

Monsanto (UK and Europe) Pyroclor 

Niagara Transformer Corporation Askarel*, EEC-18 

P.R. Mallory & Company Aroclor B 

Power Zone Transformer EEC-18 

Prodelec (France) Phenoclor, Pyralene 

R.C. Upteraff -

R.F. Interonics -

Reliance Electric Company -

Research-Cottrell Askarel* 

Sangamo Electric Diaclor 

Sovol (USSR) -

Sprague Electric Company Chlorinol 

Standard Transformer Corporation -

Stens Magnetics -

Tobe Deutschmann Labs. -

Universal Manufacturing Corporation Askarel* 

Uptegraff Manufacturing Company -

Van Tran Electric -

Wagner Electric No-Flamol 

Westinghouse Inerteen 

York Electonics -

- Nepolin, Apirolio, Kaneclor 

* Generic name for non-flammable insulating liquids.

Note: This list is a compilation of information from several data sources.

August 2004 E-2 PCB Inspection Manual 
Appendix F PCBs in Underground Mines 

Appendix F 

PCBs in Underground Mines 

Underground mines present potential hazards unique to the mining environment and 

specialized training is needed before an inspector goes underground. However, an 

understanding of mines is necessary before training is considered. Therefore, this appendix is 

divided into two major sections, "Use and Distribution of PCBs in Underground Mines," followed 

by "Training and Safety." 

Use and Distribution of PCBs in Underground Mines 

As of January 1, 1982, PCBs used in mining equipment must be at a concentration under 50 

ppm [§761.30(c)]. The discussion that follows explains how mines use PCBs. PCB electrical 

equipment may be found in mines because electrical systems in mines follow the same general 

pattern as any other industry. 

General Description of Mines 

All underground mines are categorized as either coal mines or metal/nonmetal mines. Each is 

different in their operation and in their use of electrical equipment. Underground coal is most 

frequently accessed via a ground-level entry leading to the coal seam. The entry, or "adit," may 

include an electric trolley for personnel, equipment, or coal transportation, or the transportation 

may be provided by rubber-tired vehicles. Often, coal is hauled out of the mine separately by a 

conveyor belt. Either way, all personnel and equipment access is via the adit, which may be 

level or inclined. 

In "room-and-pillar" mining, the working area of the mine is divided into numerous sections by 

"pillars," or columns of coal, that are left intact during mining for roof support. These columns 

are left standing until the section is mined out, after which they too may be removed and the 

roof allowed to collapse. Another type of coal mining is called "longwall" mining, in which 

several hundred feet of a coal face is mined at once. As the machinery advances into the 

seam, the roof is allowed to collapse behind it. The transformers that power the underground 

equipment are located away from active working areas of the mine. 

Coal mining also is done by hand, or with the use of hand-held equipment, when the seam is 

not thick enough for the use of mining equipment. Such "low-seam coal" will not be of concern 

to the PCB inspector since PCB electrical equipment will not be found underground in such 

mines. 

PCB Inspection Manual F-1 August 2004 
PCBs in Underground Mines Appendix F 

Metal/nonmetal mines, which produce metal ores containing gold, silver, or lead, or nonmetal 

resources such as salt and other minerals, often gain access to the ore via adits. More often 

the access is gained via a vertical shaft. An elevator, which is used to transport both personnel 

and ore, is operated from a surface-level shaft house that contains electric motors, controls, and 

a hoist. The shaft may lead to a number of mining levels, much like an elevator in a building. 

Working levels can be 10,000 or more feet below the surface and constitute miles of drifts. 

Working levels are typically separated by 100 or more feet of rock. Transportation of material 

and people in the mine can be by diesel or electric vehicle, train or other means. Mines vary 

considerably in size, manpower, production capacity, and in the use of electrical equipment 

underground. Ore may undergo primary crushing and milling underground or on the surface. 

Whichever applies, ore or concentrates can be hoisted or pumped to the surface or can be 

transported horizontally, by train, truck or pipeline to the surface. 

All mines have fresh air ventilation systems and personnel escape routes that are incorporated 

into the mining plan. Health and safety compliance is enforced by the Mine Safety and Health 

Administration (MSHA), which conducts unannounced quarterly inspections of each mine. 

Federal law provides for mandatory personal safety equipment and training, as discussed later 

in this appendix. 

PCBs in Underground Equipment 

Underground mines can have a high demand for electric power, both on the surface and 

underground. Both coal and metal/nonmetal mines may use high-voltage/high-amperage 

equipment on the surface for ventilation, shaft equipment, coal or rock loading facilities, and 

associated ore mills. PCB Transformers can be found at the mine's primary electrical 

substation (located on the surface), at areas of power use such as an associated mill, shaft 

house, or ore loading facility, or in the mine's equipment storage area. PCB Capacitors may be 

found in motor control boxes, transformer locations, loading facilities, or in storage areas. 

Underground equipment can also have high-current requirements. Coal mining makes 

substantial use of electrical coal-cutting machines (such as "continuous miners"), conveyors, 

mobile loading machines, drilling machines shuttle cars, and water pumps. Metal/nonmetal 

mines may have a number of electrical applications underground, including vehicles, crushers, 

pumps, etc. These applications are significantly different from coal and thus these mines are 

discussed separately below. 

PCBs in Coal Mines. In coal mines, high voltage (1,000 to 13,000 volts AC) from a mine's 

primary substation is typically cabled underground to smaller distribution substations to provide 

lower voltage for trolleys, continuous miners, conveyor belts, groundwater pumps, and other 

equipment. High-voltage cables are normally suspended from the roof, or "top," along primary 

access routes. Many coal mines have replaced transformers with "mobile power centers." 

These power centers are rectangular steel enclosures measuring approximately 22 feet long, 6 

August 2004 F-2 PCB Inspection Manual 
Appendix F PCBs in Underground Mines 

feet wide, and 3 feet tall. They are mounted on skids and contain a dry-type transformer. Coal 

mine operators prefer these units because they are designed for rugged use. According to 

industry sources, about 10 percent of them contain capacitors. Units that were manufactured 

up until the late 1970's may contain PCB Capacitors. One model that contains PCB capacitors 

is a 4,160 volt, 500 kV unit manufactured by Hubbel Ensign Company. Other models may have 

also been manufactured with PCB Capacitors, and there may be no indication on the enclosure 

that PCBs are located inside. Other manufacturers of mobile power centers include, but are not 

limited to, Line Power Manufacturing, Pemco, Service Machine Company, MCI Corporation, and 

Sasser. 

Inspecting mobile power centers requires some planning because the units must be deenergized in order to look inside. If the mine is in production, it may not be possible to inspect 

the units that are in service until there is a change in work shift. Mines that operate around the 

clock normally have three shifts in each 24-hour period, with approximately one-half hour of 

nonproduction activity per shift. If the mine is on standby, meaning that it is not producing but 

the mine is being maintained by a small crew, then it should be possible to shut off power to all 

units for the purpose of inspection. It is reasonable for the inspector to request that the mine 

operator shut power to the units s/he intends to inspect, and that mine personnel remove the 

steel cover plates to enable you to look inside, when the unit is not in active service. Shutting 

power and removing the covers are routine operations. In some models, removal involves 

unbolting the top panels and sliding them to the side. Access to the inside may vary with the 

model. 

The manufacturer's nameplate should provide information about the type of dielectric fluid in the 

capacitor. If they are PCB Capacitors, examine the casing and the area below the capacitor. 

Leaks may be common in these units because of their age and rugged use environment. As 

usual, follow standard precautions when inspecting electrical equipment. The capacitors will 

retain a charge after the power has been shut off. Do not place any part of your body within the 

mobile power center's enclosure. 

PCBs were also used as a coolant in the electric motors of continuous coal miners and loaders 

manufactured by Joy from 1961 to 1973; some 652 of the units were still in service in 1973, 

requiring some 23,000 kilograms of PCBs per year for "topping off." Electric motors in mine 

equipment are usually rebuilt every 5 years or less. A mine that has been in uninterrupted 

operation since 1973 would not be expected to have PCB-filled electric motors today. However, 

there may be motors in storage. Also, a mine may have closed in the early 1980s and 

reopened recently, and may therefore contain such motors; or there may be older, disabled 

equipment abandoned in the mine. There is also evidence that PCB hydraulic fluid was used in 

mining equipment, although the amount and specific applications are not well documented. 

Be aware that EPA has little information concerning the disposition of the PCB Transformers 

that were used in coal mines prior to the advent of dry-type mobile power centers. However, 

PCB Inspection Manual F-3 August 2004 
PCBs in Underground Mines Appendix F 

there is reason to believe that some mine operators may have abandoned their PCB 

Transformers in the mine. Economics may have played a role in such abandonment due to the 

cost of mine labor. Like other equipment, the salvage value of PCB Transformers may have 

been less than the cost of removal. Also, after the enactment of TSCA and the PCB rules, PCB 

Transformers became increasingly less attractive on the transformer resale market. It is useful 

to inquire whether there are any liquid-filled transformers in the mine, even if the mine uses only 

the mobile power centers. It is possible that there are transformers stored or abandoned in 

nonproducing sections of the mine. 

PCBs in Metal/Nonmetal Mines. Unlike coal mines, metal/nonmetal mines did not replace 

their PCB Transformers with mobile power centers. In 1981, the U.S. Bureau of Mines 

estimated that 1,300 PCB Transformers were in use in underground metal/nonmetal mines. 

This estimate was an extrapolation based on limited data. More recent data from the Centers 

for Disease Control (CDC), and from EPA's enforcement experience, suggests that this figure 

may have been low. 

Metal/nonmetal mines will most likely have one or more shaft houses leading to different 

sections of the mine. If there is a shaft house or mine section that is not in operation, inquire 

about the location of electrical equipment there. Although it may not be possible to inspect the 

equipment, such information may be useful should an enforcement action be taken. 

Ask the mine representative to show you the location of all liquid-filled capacitors and 

transformers. It is useful to examine the mine map before going underground, since the 

transformer locations may be indicated there. Transformers are typically located near the shaft 

entry at each level, or in a larger mine may be distributed throughout the mine section. 

Additional indication of transformer location can be determined by the size of the conductors. If 

you see large-gauge conductors leading somewhere, inquire about the equipment they serve 

and whether there are additional transformers there. 

Additional Inspection Tips 

It may be worthwhile to contact MSHA prior to inspection for information and planning purposes 

(you may also need to contact MSHA for specific certification and training, as described in the 

next section). For example, MSHA personnel can tell you how much time it may take to inspect 

a particular mine, what the shift schedules are, the general compliance policy of the 

owner/operator, and who you should expect at the entry conference. MSHA can also tell you 

whether the mine is in active operation or on standby and can supplement information provided 

in the PCB Checklist for many mines. 

Most mines should have a mine map indicating the locations of electrical substations. It is 

helpful to review this map during the entry conference when planning your inspection 

underground. 

August 2004 F-4 PCB Inspection Manual 
Appendix F PCBs in Underground Mines 

Frequently, mines will keep scrap equipment in outdoor storage yards for spare parts. These 

areas may contain PCB Transformers, older mobile power centers with PCB Capacitors, electric 

motors, containers of PCB hydraulic fluid, and other equipment with PCBs. Inspecting this area 

before entering the mine can give you a sense of the equipment being used underground. 

Inspectors should also inquire about underground storage areas, particularly in large or old 

mines. 

Training and Safety 

Inspections at mines are essentially the same as inspections at any facility that uses or stores 

PCB electrical equipment. The main difference is the equipment and training needed to enter a 

mine. This section describes the equipment and training requirements. 

General 

MSHA accident data indicates that mining is one of the most hazardous industrial occupations 

in the United States. While mine safety is strictly regulated under Federal and State law, there 

are hazardous conditions in an operating mine that are not encountered in other facilities. 

Specialized training is needed for EPA inspectors. This section will identify the regulatory 

training requirements for mine entry, and where the inspector can obtain training. 

Equipment 

30 CFR Parts 48, 57, and 75 set forth a number of health and safety requirements for both coal 

and metal/nonmetal mines. This section describes the general requirements that apply to 

persons who enter a mine. 

! Breathing Devices 

- Self-Contained Self-Rescuers (Coal) 

Under 30 CFR 75.1714, all persons who enter an underground coal mine 

must carry or have within easy reach a self-contained self-rescuer 

(SCSR). These units are carried on the belt and provide oxygen in the 

event of fire. The units produce oxygen via a chemical reaction; some 

units may have oxygen tanks. Oxygen production continues for at least 

one hour, providing the user more time to reach the surface through the 

designated escape passageways. Training in the use of this equipment 

can be provided by the mine operator, or by the local MSHA office. 

PCB Inspection Manual F-5 August 2004 
PCBs in Underground Mines Appendix F 

! Self-Rescuers (Metal/Nonmetal) 

Under 30 CFR 57.15030, all persons who enter an underground metal/nonmetal 

mine must carry a self-rescuer (SR). Unlike SCSR's, these units merely convert 

carbon monoxide to carbon dioxide. They are smaller and easier to operate than 

SCSR's. However, they cannot be used in coal mines. The mine operator or the 

local MSHA office can provide training in the use of this equipment. 

! Steel-Reinforced Footwear 

Persons entering a mine must, at a minimum, wear boots with steel-reinforced 

toes. In some States the law requires full reinforcement from the toe to the top of 

the instep. 

EPA inspectors normally carry steel-toe boots. The inspector may want to 

consider obtaining fully-reinforced boots, and if the mine is wet, to use boots 

made of a waterproof material. 

! Lamps 

Miners carry battery-powered cap lamps that attach to the hardhat. Hardhats 

intended for mining use have a clip to which the lamp is attached. The battery is 

carried on a belt. 

! Tags 

All persons entering an underground mine must leave their identification tag at 

the mine's main office. The tag is usually made of brass and is stamped with the 

person's name and social security number. Alternatively, the inspector can leave 

a slip of paper at the mine office with the same information. This records the 

inspector's entry into the mine in the event of a mine emergency. 

! Hardhats 

Hardhats are required when on mine property. Hardhats intended for mining 

have a clip to which the cap light is attached. In some mines, a distinctivelycolored hardhat is required for all visitors, as they are for all new miners, which 

the mine's management may want to provide for inspectors. 

August 2004 F-6 PCB Inspection Manual 
Appendix F PCBs in Underground Mines 

! Eye Protection 

All persons are required to wear safety glasses, goggles or face shields or other 

suitable protective devices when in or around are area of a mine where a hazard 

exists which could cause injury to unprotected eyes. 

Training and Supplies 

Under 30 CFR 48.31, mine operators must provide training for new miners in the following 

areas: 

! Hazard recognition and avoidance 

! Emergency and evacuation procedures 

! Safe working procedures 

! Self-rescuer and respiratory devices 

! Such other instruction as determined by the MSHA District Manager. 

This training is focused on personnel who will be working in the mine and thus exposed to 

hazards associated with mine production activities. Other than training in the use of SCSRs 

or SRs, there are no similar training requirements for EPA inspectors or other temporary 

visitors in the mine. An inspector can obtain this training at the mine just prior to an 

inspection. Mine opertors can often supply all necessary equipment except for boots. The 

principal safety precaution for all mine visitors is to accompany a mine representative at all 

times, however, the inspector may still be asked to sign a release absolving the company of any 

liability should the inspector be injured. In general, EPA’s policy is that inspectors should not 

sign such releases. In addition, before an EPA inspector enters a mine, s/he should become 

familiar with mine operations and general safety procedures. The following sections describe 

the training resources available to the EPA inspector. 

Mine Safety and Health Administration. MSHA District, Subdistrict, and Field Offices can be 

consulted for training prior to conducting an inspection.1 MSHA can provide training in the use 

of SCSRs (coal) and SRs (metal/nonmetal), and the equipment should be available on loan.2 

1

The EPA Regional Office should have a copy of the MSHA Directory; alternatively, the MSHA 

Headquarters Office can provide the inspector with the local MSHA contact for training purposes. 

The inspector may contact the Coal Mine Safety and Health Division at 

(703)235-9423 and the Metal/Nonmetal Mine Safety and Health Division at (703)235-1565. 

2 A training video entitled "An Efficient Method for Donning the SR-100," a type of SCSR, has been 

distributed to the Regional Pesticides and Toxics Branches. 

PCB Inspection Manual F-7 August 2004 
PCBs in Underground Mines Appendix F 

The inspector may also borrow hard hats, cap lamps, and utility belts, and obtain information on 

vendors that supply name tags. In addition, the MSHA local office may be able to provide minespecific training in hazard recognition and avoidance, and the mine's emergency evacuation 

procedures. 

MSHA also operates the National Mine Health and Safety Training Academy, which is an 

excellent training facility in Beckley, West Virginia. The facility offers a wide range of training 

courses. These courses are offered free or at low cost to government inspectors and the facility 

provides room and board. EPA inspectors should take "Introduction to Mining" offered by the 

Academy to become familiar with the various mining operations and general safety procedures. 

The Academy continually develops and modifies is safety training programs, and may suggest 

additional training courses depending on the timing and availability of the courses offered. The 

address and telephone number are as follows: 

U.S. Department of Labor

Mine Safety and Health Administration 

National Mine Health and Safety Academy 

1301 Airport Road 

Beaver, West Virginia 25813-9426 

(304) 256-3257 

U.S. Environmental Protection Agency. There are several EPA inspectors who have 

experience in underground mine inspection. In addition to the training available through MSHA, 

it may be possible for the experienced inspectors to train new inspectors in the field. Contact 

the Office of Enforcement and Compliance Assurance/Office of Compliance/Compliance 

Assessment and Media Programs Division/Compliance Monitoring and Water Programs Branch, 

for further information. 

August 2004 F-8 PCB Inspection Manual 
Appendix G PCBs in Natural Gas Pipelines 

Appendix G 

PCBs in Natural Gas Pipelines 

Background 

Major interstate natural gas pipelines (NGPs) transport natural gas from production areas on the 

Gulf Coast and western US to local distribution companies (LDCs) that distribute the natural gas 

to industrial and urban customers. PCBs were used in turbine and air compressors as a 

hydraulic/lubricant and a plug valve sealant by some large interstate natural gas transmission 

pipeline companies and by some smaller LDCs. Some pipeline companies may have had PCB 

Transformers and/or PCB Capacitors at large compressor stations and/or maintenance facilities. 

Between 1950 and the early 1970's, Monsanto manufactured and sold several brands of 

hydraulic/lubricant oils containing PCBs. These included Turbinol 153 that contained 6.4% 

Aroclor 1221 and 81.5% Aroclor 1242, Santovac 1 and 2 containing 100% 1248 and 1254, 

respectively. In addition, several Pydraul-brand oils containing both PCBs and PCTs (polychlorinated terphenyls) containing Aroclors 1221, 1242, 1248, and 1254 with PCB content 

ranging between 20% and 70%. Note that the early PCT oils were found to be contaminated 

with PCBs between 2 and 10% and therefore should be assumed to contain PCBs. 

At some compressor stations, the PCBs above were used in large turbine compressors. As part 

of the normal operation, PCB compressor lubricants could leak or blow by pressure seals and 

enter the transmission pipeline. These PCBs would generally mix with the “pipeline liquids” 

already in the transmission lines. The main components of pipeline liquids are water and 

heavier hydrocarbons that condense-out (“condensate”) of the natural gas as pressure drops 

along the pipeline. Pipeline liquids may also contain metal-based corrosion inhibitors and other 

liquids (methanol) that were added to the pipeline when cleaning (“pigging”) the lines. These 

liquids traveled through the pipeline and entered other companies' pipelines via numerous 

interconnections. The liquids/condensate are removed downstream at compressor stations and 

other condensate collection ("drip") points along the pipeline. PCBs pipeline liquids were 

illegally disposed of in unlined earthen pits, vented to the atmosphere and surface soils at 

various equipment blowdowns, used as herbicides on station fence-lines, and used for dust 

control on roads. Examples of past cases/settlements involving the use of PCBs in turbine 

compressors include the Texas Eastern Gas Pipeline Company and Transwestern Gas Pipeline 

Company. 

PCB Inspection Manual G-1 August 2004 
PCBs in Natural Gas Pipelines Appendix G 

At some compressor stations, Monsanto-brand Pydrauls were used in reciprocating air 

compressors to start the main natural gas compressors or turbines and to power hand tools. 

These air compressors were not directly connected to the pipeline. PCBs used as air 

compressor-lubricants did not normally enter into the gas pipeline and were used in much 

smaller quantities than PCBs used in the large natural gas turbine units. Air compressor “water 

& condensate” containing PCBs was routinely formed in air receiver tanks or bottles. This 

“water & condensate” mixture was vented to the atmosphere and surface soils from receiver 

tank or bottle blowdown valves. PCBs may have also been captured by the wastewater 

drainage control or treatment systems at some compressor stations, thereby contaminating the 

systems. Some examples of past cases or settlements involving the use of PCBs in 

reciprocating air compressors include the Tennessee Gas Pipeline Company, Columbia Gas 

Pipeline Corporation, and Transcontinental Gas Pipeline Company. Note that these air 

compressor and air compressor systems were required to be decontaminated via alternate 

disposal permit and/or air compressor system decontamination guidance. 

Rockwell made a plug valve sealant (No 860 and 991) that contained PCB Aroclor 1268 

sometime prior to the mid-1970s. The PCB sealant or grease was apparently dissolved by 

transmission pipeline condensate and spread to other downstream locations. 

PCBs are also present in natural gas pipelines as a result of the historical practice of oil fogging. 

Oil fogging was a gas conditioning technique used in natural gas pipelines in the late 1940s 

through the late 1960s. This technique minimized dust entrainment in the gas stream and 

reduced leaks in cast iron pipe joints by keeping the packing material moist. Reclaimed 

transformer and waste oils, probably containing PCBs, were used in the oil fogging process at 

some pipelines. By the late 1960s the practice of oil fogging had largely disappeared. Welded 

steel pipe now replaces cast iron pipe in most pipelines, and the remaining cast iron joints may 

be sealed with bell joint clamps. Dry filters now in use remove dirt and rust entrained in the gas 

stream. Nevertheless, the residues from prior oil fogging may still remain in parts of natural gas 

pipelines. 

In 1981, EPA discovered PCBs in pipeline liquids in Long Island, NY. Consequently, EPA, the 

states and industry formed a cooperative task force to address this problem. Extensive 

sampling of pipeline transmission liquids revealed that 13 major natural gas interstate 

transmission companies and a number of regional LDCs had PCB contamination greater than 

50 ppm in their transmission lines. EPA Headquarters retained the responsibility for 

implementing remedial programs with the interstate gas transmission companies. EPA regional 

offices worked with states, public service commissions, and the local utilities to determine the 

extent of PCB contamination and established remedial monitoring programs with the LDCs. 

In late 1981, EPA Headquarters instituted a Compliance Monitoring Program (CMP) for the 13 

interstate companies with PCBs greater than 50 ppm in their pipelines. The CMP had four basic 

objectives: (1) contain the contamination to limited areas; (2) eliminate any further entry of 

August 2004 G-2 PCB Inspection Manual 
Appendix G PCBs in Natural Gas Pipelines 

PCBs into the pipeline system; (3) remove known contamination from the system and ensure its 

proper handing and disposal; and (4) perform periodic monitoring of each companies pipeline 

system. 

In 1981, the use of PCBs at greater than 50 ppm in a non-totally enclosed manner was 

prohibited by 40 CFR §761.20(a). EPA decided that it would not bring enforcement actions 

against the 13 companies for the improper use of PCBs as long as they participated in EPA’s 

CMP and undertook measures to reduce PCBs in their pipeline systems. The 13 CMP 

companies were required to comply with all other aspects of the PCB rule and other applicable 

laws and regulations. Thus, the 1981 CMP allowed the use of PCBs in natural gas 

transmission lines subject to certain conditions, including the proper disposal of PCB wastes 

and compliance with applicable federal and state laws. The 1981 CMP did not grant immunity 

to any of the participating companies from enforcement if violations were discovered. The 1981 

CMP has not prevented EPA from taking judicial or administrative enforcement actions against 

participating companies such as Texas Eastern Gas Pipeline Company, Transwestern Gas 

Pipeline Company, Tennessee Gas Pipeline Company, Columbia Gas Pipeline Corporation and 

Transcontinental Gas Pipeline Company. Several states have also taken enforcement actions 

against companies participating in the CMP. 

The CMP was revised in 1996 for ten remaining companies still participating in the program. A 

detailed description of the 1981 and 1996 revised CMP was sent to the Regions on December 

24, 1996. Under the revised CMP, each participating company was required to submit their 

Annual “PCB Condensate” Compliance Monitoring Report to EPA by June 15th of each year. 

Promulgation of 1998 PCB disposal amendments terminated the 1996 PCB CMP. The 1998 

rule revised the use authorization for natural gas pipelines at 40 CFR Part 761.30(i) to permit 

the use of PCBs in natural gas pipelines at greater than 50 ppm under certain conditions. 

Regulatory Requirements 

The regulations governing the use of PCBs in natural gas pipeline systems are found at Section 

761.30(i)(1). See also Section 4.1.9 Natural Gas Pipeline Systems Chapter Four. 

Inspection Focus 

The general inspection procedures detailed in this manual should be followed when conducting 

PCB inspections of natural gas pipeline sites. The inspector should evaluate the following likely 

PCB locations (sources of PCB contamination) for evidence of potential violations of PCB 

regulations: 

! PCB Sources 

- Natural Gas Turbine Compressors 

- Air Compressors 

- Condensate Drip Points 

PCB Inspection Manual G-3 August 2004 
PCBs in Natural Gas Pipelines Appendix G 

- Condensate Scrubbers (oil scrubbers may have PCBs) 

- Pig Launchers and Receivers. 

- Wastewater/Oils Treatment System 

! PCB Storage 

- Condensate Storage Tanks 

- Condensate and Oil Scrubber Storage Tanks 

- Waste Oil Storage Tanks 

- Wastewater Storage Tanks 

! PCB Disposal 

- Blowdown Vents (all types of compressors and equipment) 

- Burn Pits 

- Burn Barrels 

- Surface Disposal (Soil, Drains, Floor) 

- Condensate Disposal 

- Condensate Scrubber Disposal 

- Dehydration Material Disposal 

- Wastewater and Storm Water Discharge Points. 

August 2004 G-4 PCB Inspection Manual 
Appendix H Submersible Pump Units that Contain PCBs 

Appendix H 

Submersible Pump Units that Contain 

PCBs* 

The following pump units, which are identified by manufacturer’s model and serial number, are 

potential sources of PCB contamination in well water. 

Dempster Industries: Prior to 1964, Dempster may have distributed pump units manufactured 

by REDA and Sta-Rite that may have contained PCBs. Use the REDA and Sta-Rite 

identification data for those pump units. 

F.E. Myers: Models SF and SF-2, two wire units manufactured from 1964 through 1970 in 1/3 to 

1 horsepower and models SG and S2G, two wire units manufactured from 1970 through 1976 in 

1/3 to 1 horsepower with date codes prior to 1976 are included. Some S2X models 

manufactured before 1979 utilized capacitors that contained less than 50 parts per million of 

PCBs. The date code is located on the motor casing and on a nameplate or tag in the format 

MMYY, e.g., 1177 signifies November 1977. 

Fairbanks Morse: Two wire units manufactured from 1964 through January, 1979 have a coded 

alpha numeric date code on the nameplate. These include the Colonial series and the Chateau 

series units with date codes of J_, K_, L_, M_, N_, P_, R_, S_, T_, V_, W_, X_, A_, B_, C_, and 

DA. The blanks are filled with additional characters. 

* Modified from Appendix I: Submersible Pump Units that are Known to Contain PCBs of “The Potential 

for Drinking Water from Submersible Well Pumps,” Wisconsin Department of Natural Resources, 

Bureau of Water Supply, PUBL-WS-025-92. 

PCB Inspection Manual H-1 August 2004 
Submersible Pump Units that Contain PCBs Appendix H 

SERIES MODEL NUMBERS 

Colonial A2-2507 C2-3306 E2-7509 G2-1009

A2-3309 C2-7511 E2-10011

A2-5012

Chateau A2S-3309 C2S-3306 E2S-7509 G2S-1009 273

A2S-5012 C2S-5008 E2S-10011 G2S-15012 275

A2S-7517 C2S-7511 E2S-15015 277

A2S-10021 C2S-10014

Johnston Water Systems: Peabody Barnes manufactured these pumps. Models include: 

V507-31 V513-52 V909-51 VSP913-75 V317-150 

V507-32 V523-100 V909-52 VSP909-52 V1306-51 

V509-31 V531-100 V913-75 VSP909-51 V1307-52 

V509-32 V906-31 V917-100 V1309-75 V1809-100 

V513-51 V906-32 V923-150 V313-100 V1813-150 

Montgomery Ward: Peabody Barnes manufactured these pumps. Models include: 

3677A 3679A 3681C 3682E 3684D 24623 

3677B 3679B 3681D 3683C 3675A 24625 

3678A 3680C 3682C 3683D 3675B 

3678B 3680D 3682D 3684C 3675C 

Peabody Barnes: Two wire units are identified with the letter “W” as part of the model number, 

e.g., 409W52. In 1977, an “N” was added to the model number, e.g., 409W52 became 

409WN52. The date codes are the last 3 or 4 digits of the coding, showing month, then year of 

manufacture, e.g., 409WN52-67753-1279 signifies a two wire unit manufactured in December 

1979. Codes are on a stainless steel band located around the discharge neck of the pump. 

August 2004 H-2 PCB Inspection Manual 
Appendix H Submersible Pump Units that Contain PCBs 

REDA: Two wire units have a date code on the nameplate with the format MMYY, e.g., 0877 

signifies August 1977. All models listed below with a year code of 79 or less are included. All 

motors had the serial number stamped on the head of the motor preceded by the four digit date 

code. 

41100 42121 43091 7D9P030 4D35P101 14D18P151 312X7P050 

41101 42131 43171 7D9P031 6D35P151 17D5P071 314X4P050 

41120 42171 43181 9D5P031 7D18P071 17D9P101 320X4P050 

42070 42181 43121 9D6P030 10D18P101 23D5P101 32D5P151 

42090 42251 43131 9D9P050 12D5P050 23D9P151 

42091 44091 9D9P051 12D5P051 

44251 12D9P071 

Red Jacket: The capacitor is encapsulated in a plastic housing and the unit is fastened to the 

bottom of the motor. Although these units are less likely to leak PCBs, there are confirmed 

cases of PCB contamination from Red Jacket pump motors. Motor Models include two wire 

units with the designations “BV”, “BVC”, “C”, “W”, and “RW”, 1/3 through 1-1/2 horsepower. The 

model designation appears as the first part of the identification number, e.g., BV 300-2 or 

50W0-9BC. 

The date of manufacturer is on the motor housing and on the pump. Codes include: 

1968 MC_ and NC_ 1973 AH_ through NH_ _ _ _78 

1969 AD_ through ND_ 1974 AK_ through NK_ e.g. 20378 signifies the 2nd week of 

March 1978 1970 AE_ through NE_ 1975 AL_ through NL_ 

1971 AF_ through NF_ 1976 AM_ through NM_ 

1972 AG_ through NG_ 1977 AN_ through NN_ 

e.g. 3FHR signifies the 3rd week of June, 1973 

STA-RITE: Two wire units have a date code on the nameplate with the format MYY. The month 

is coded as a letter from “A” to “M” and the year as a number, e.g., B77 signifies February 1977. 

Units dated 1979 or earlier are included. 

NOTE: Some three wire motors with Sta-Rite labels have been verified containing PCB. 

PCB Inspection Manual H-3 August 2004 
Submersible Pump Units that Contain PCBs Appendix H 

Blank Page 

August 2004 H-4 PCB Inspection Manual 
Appendix I Incinerators 

Appendix I 

Incinerators 

Except as specifically provided by regulation (see §761.60[a]), PCBs at concentrations of 50 

ppm or greater must be disposed of in a high temperature incinerator. 40 CFR 761.70 requires 

high temperature incineration facilities to meet certain technical (e.g., operating and monitoring) 

requirements. (Technical criteria are discussed in the operating requirements section of the 

regulatory review, below.) Persons may dispose of any PCBs or PCB Items (e.g., liquid and 

nonliquid PCBs, PCB articles) by incineration; persons must dispose of some items (e.g., liquid 

PCBs 500 ppm and above) by incineration. The regulations authorize disposal methods other 

than incineration (e.g., chemical waste landfills) for disposal of PCBs and PCB Items under 

certain circumstances. 

The owner or operator of a PCB incinerator may not dispose of PCBs unless they receive 

written approval of the appropriate Regional Administrator or, under certain circumstances, the 

Director of the National Programs Chemical Division (NPCD) (at Headquarters). The owner or 

operator must include the following in the application for approval: location of the incinerator, 

engineering reports on facility performance, and available sampling and monitoring equipment. 

The inspector must obtain the facility’s approval document and refer to it during the inspection. 

The inspector should verify compliance with the approval document as well as the regulations. 

The Regional Administrator or the Director, NPCD may require the facility to conduct a trial burn. 

If so, the Regional Administrator or the Director, NPCD must notify the owner or operator of this 

requirement. Prior to disposal, the owner or operator must submit a detailed plan for conducting 

and monitoring the trial burn and receive approval of the plan from the Regional Administrator or 

the Director, NPCD. 

Once the Regional Administrator (or the Director, NPCD) determines that the incinerator meets 

all regulatory requirements, he will issue a written, signed approval stating all requirements 

applicable to the facility. The final approval may contain the following items: 

• Technical requirements 

• Person(s) authorized to operate the incinerator 

• Owner(s) of the facility 

PCB Inspection Manual I-1 August 2004 
Incinerators Appendix I 

• Additional requirements (if any) necessary to ensure that the operation of the 

facility does not present unreasonable risk to health or the environment 

• Period of time for which the approval is valid (if limited) 

• Waivers (if any) from one or more of the technical requirements if there is a 

finding, based upon evidence submitted by the owner or operator, that the 

incinerator will not present an unreasonable risk if one or more of the 

requirements are not met. 

Acceptable for Disposal 

• Liquid PCBs 500 ppm and above must be disposed of by incineration; other liquid 

PCBs (with PCB concentrations between 50 and 500 ppm) may be disposed of 

by incineration or by other methods as allowed by the following regulations: 

§761.60(a) 

• §761.60(a)(1) - Mineral oil dielectric fluid may be disposed of in a high 

efficiency boiler according to § 761.71(a). 

• §761.60(a)(2) - Liquids other than mineral oil dielectric fluid may be 

disposed of in a high efficiency boiler according to § 761.71(b). 

• §761.60(a)(3) - Liquids from incidental sources, such as precipitation, 

condensation, leachate or load separation and are associated with PCB 

Articles or non-liquid PCB wastes may be disposed of in a chemical 

waste landfill which complies with § 761.75 if information is provided to or 

obtained by the owner or operator of the chemical waste landfill that 

shows that the liquids do not exceed 500 ppm PCB and are not an 

ignitable waste as described in § 761.75(b)(8)(iii). 

• All other PCBs and PCB Items are acceptable at an approved incinerator. These 

PCBs and PCB Items include, but are not limited to, non-liquid PCBs with at least 

50 ppm in the form of rags, soil, or other debris; dredged materials and sludges; 

articles; and PCB containers. §761.60(b) and §761.60(c) 

The following tables provide an overview of the regulatory requirements and inspection 

procedures related to incinerators used to dispose of PCBs. 

Inspectors must be familiar with §§761.60 and 761.70 and conditions of the PCB approval for the 

incinerator before conducting the inspection. Note that incinerators for PCB liquids must meet 

all of the requirements specified in §761.70(a)(1)-(a)(9). The inspector should check for any 

waivers as provided for under §761.70(d)(5). 

August 2004 I-2 PCB Inspection Manual 
Appendix I Incinerators 

Regulatory Requirements Inspection Procedures 

Notice Requirements (§761.60) 

Owners/operators must notify the State and 

local governments, within whose jurisdiction 

the incinerator is located, at least 30 days 

before the facility is first used for disposal of 

PCBs. §761.60(f)(1)(i) 

At the request of any State or local 

government, owners/operators must provide 

an annual notice to the government of the 

quantities and general description of PCBs 

disposed of during the year no more than 30 

days after the end of the year covered. 

§761.60(f)(1)(ii) 

Check PCB databases at 

http://www.epa.gov/pcb/data.html 

to check if facility submitted required notices 

and check facility files to ensure their 

records are properly kept. 

PCB Inspection Manual I-3 August 2004 
Incinerators Appendix I 

Regulatory Requirements Inspection Procedures 

Recordkeeping Requirements (§761.180) 

Owners/operators must measure and record 

the rate and quantities of PCBs fed into the 

incinerator at least every 15 minutes 

§761.180(c)(1)(i) 

Owners/operators must continuously 

measure and record the temperatures of the 

incineration process by either: 

• Direct temperature readings 

(pyrometer) 

• Indirect temperature readings 

(wall thermocouple-pyrometer 

correlations). 

§761.180(c)(1)(ii) 

Owners/operators must monitor and record 

combustion products and incineration 

operations for the following parameters 

whenever the incinerator is incinerating 

PCBs: 

• O2 and CO Continuous monitoring and 

recordkeeping 

• CO2 Periodic monitoring and 

recordkeeping specified by the 

Regional Administrator. 

§761.70(a)(7) and 

§761.180(c)(1)(iii) 

Verify and review monitoring records 

indicating: 

• Rate and quantities of PCBs fed into 

incinerator 

• Determine if the temperature of 

incineration is maintained at 1200°C 

(+ 100°C) for 2-second dwell times 

or 1600°C (+ 100°C) for 1.5-second 

dwell times. 

Check facility operations records or facility 

monitoring logbook for compliance with 

required monitoring frequency. Use these 

records to verify that 2% (1.5-second dwell 

time at 1600°C) or 3% (2-second dwell time 

at 1200°C) oxygen is maintained in the stack 

gas and to verify that combustion efficiency 

(CE) is at least 99.9% using the following 

equation. 

CE = [CO 2] X 100%

 ([CO 2] + [CO]) 

August 2004 I-4 PCB Inspection Manual 
Appendix I Incinerators 

Regulatory Requirements Inspection Procedures 

Owners/operators must monitor and record Check facility operations records or facility 

stack emissions when: monitoring logbook for compliance. 

• The incinerator is first used for PCB 

disposal 

• The incinerator is first used after it has 

been modified in a way that may affect 

stack emissions. §761.180(c)(2) 

Owners/operators must monitor and record 

the following stack emissions when 

monitoring is required: 

• O2 • HCl 

• CO • RCl 

• CO2 • PCBs 

• NOx • Total Particulate Matter 

§761.70(a)(6)(iii) and §761.180(c)(2) 

Owners/operators must keep records of the Check facility records for compliance. 

total weight (kg) of: 

• Solid residues generated by the 

incineration of PCBs and PCB Items 

during the calendar year 

• Any solid residues disposed of in 

chemical waste landfills 

• Any solid residues remaining on the 

facility site. §761.180(c)(3) 

The Regional Administrator may require the Check the approval document to see if 

owners/operators to collect additional additional data are required to be collected 

periodic data as specified by in the approval by the facility. Then, check facility records 

document. §761.180(c)(4) to see if such data have been collected. 

Each owner or operator of a PCB incinerator Check facility records for compliance. 

must collect and maintain the information 

required under §761.180(b) and (c) for 5 

years. §761.180(c) 

PCB Inspection Manual I-5 August 2004 
Incinerators Appendix I 

Regulatory Requirements Inspection Procedures 

Upon suspension of operations pursuant to Check EPA correspondence file for 

§761.70(a)(8), the owner/operator must compliance. 

prepare and submit to the Regional 

Administrator within 30 days of suspension a 

document including the date and time of 

suspension and an explanation of 

circumstances causing the suspension. 

§761.180(c)(5) 

Prior to transferring ownership of an If applicable, check EPA files for transfer 

incinerator, the owner/operator must notify notice and affidavit. 

EPA 30 days in advance of the transfer and 

provide a notarized affidavit signed by the 

transferee stating that the transferee agrees 

to abide by the EPA approval document. 

§761.70(d)(8) 

August 2004 I-6 PCB Inspection Manual 
Appendix I Incinerators 

Regulatory Requirements Inspection Procedures 

Operating Requirements for Liquid and Non-Liquid PCBs 

Owners/operators must maintain 

combustion efficiency at a rate of at least 

99.9%, as computed below:

 Combustion efficiency = Cco2/(Cco2 + 

Cco) x 100 

where: 

Cco2 = Concentration of carbon dioxide 

Cco = Concentration of carbon monoxide. 

§761.70(a)(2) and §761.70(b)(2) 

Owners/operators must use water scrubbers 

to control HCl and must meet any 

performance requirements specified by the 

Regional Administrator or the Director of 

NPCD. Owners/operators may use an EPAapproved alternative method of HCl control 

(e.g., cement kilns). §761.70(a)(9) and 

§761.70(b)(2) 

The flow of PCBs into the incinerator must 

stop automatically if one or more of the 

following conditions occurs: 

• Failure of monitoring operations for 

combustion products and incineration 

operation parameters 

• Failure of PCB rate and quantity 

measuring and recording equipment. 

§761.70(a)(8) and §761.70(b)(2) 

Note: Alternatively, the owner/operator can 

submit a contingency plan to the Regional 

Administrator or the Director of NPCD for 

approval indicating measures to be taken if 

these conditions occur. §761.70(a)(8) 

Owners/operators must store PCBs for 

disposal under conditions complying with 

§761.65, governing storage for disposal 

requirements. §761.60(a)(6) 

When the incinerator is in operation, check 

combustion efficiency records against the 

required level. 

Determine water scrubber compliance with 

any required performance standards. 

Check procedures and equipment used to 

ensure fail-safe operations of the facility. 

See Chapter Four regulatory provisions 

pertaining to storage for disposal §761.65. 

PCB Inspection Manual I-7 August 2004 
Incinerators Appendix I 

Regulatory Requirements Inspection Procedures 

Liquid PCB Operating Requirements 

Owners/operators must incinerate liquid 

PCBs according to either of the following 

combustion criteria: 

• Maintenance of the introduced liquids 

for a 2-second dwell time at 1,200EC 

(+100E C) and 3% excess O2 in the 

stack gas. §761.70(a)(1)(i) 

• Maintenance of the introduced liquids 

for a 1.5-second dwell time at 1,600 

degrees C (+100E C) and 2% excess 

O2 in the stack gas. §761.70(a)(1)(ii) 

For liquid PCBs, the flow into the incinerator 

must stop automatically if the following 

conditions occur: 

• The excess O2 level falls below 3%. 

(Alternatively, a contingency plan can be 

submitted to, and approved by, the 

Regional Administrator or the Director of 

NPCD.) §761.70(a)(8) 

• The combustion temperature falls below 

that specified in the chosen combustion 

criteria. §761.70(a)(5) 

Check facility operating records for 

compliance with the required combustion 

criteria. (Verifying that the combustion 

criteria are met is also outlined above in the 

review of the monitoring requirements.) 

Check facility operating records to verify that 

flow to the incinerator stops automatically 

when the required conditions occur. 

Non-Liquid PCB Operating Requirements 

The air mass emissions for the incinerator 

must be no greater than 0.001g PCB/kg 

(destruction and removal efficiency [DRE] of 

99.49%) of the PCB introduced to the 

incinerator. §761.70(b)(1) 

Check facility operating records for 

compliance with air mass emissions. 

August 2004 I-8 PCB Inspection Manual 
Appendix J Chemical Waste Landfills 

Appendix J 

Chemical Waste Landfills 

According to §761.75, the owner or operator of a chemical waste landfill used for the disposal of 

PCBs and PCB Items must obtain written approval from the EPA Regional Administrator prior to 

use of the landfill for PCB disposal. The landfill must meet technical operating requirements, 

but the Administrator, based on a finding of no unreasonable risk, may grant a waiver from one 

or more of the technical requirements. To obtain approval, the landfill owner/operator must 

submit to the Regional Administrator an initial report containing such items such as landfill 

location, description of site, an engineering report describing how the landfill complies with PCB 

regulations, and an operations plan. The inspector should obtain from the facility the approval 

document and refer to it during the inspection. The inspector should verify compliance with the 

approval document as well as the regulations. 

Landfills must meet various requirements, including provisions pertaining to synthetic 

membrane liners, flood protection, groundwater monitoring wells, and the development of an 

operations plan. A landfill approval document from EPA may include the following items: 

• Technical requirements 

• A list of persons authorized to operate the landfill 

• Any additional requirements, at the discretion of the Regional Administrator, 

where s/he finds that such requirements are necessary to protect human health 

and the environment 

• The period of time for which the approval is valid (if limited) 

• Waivers (if any). 

Acceptable for Disposal 

The following list provides selected PCB and PCB-contaminated wastes acceptable for disposal 

at chemical waste landfills: 

• Liquid PCBs (in concentrations of 50 to 500 ppm) that are from incidental 

sources, such as precipitation, condensation, leachate, or load separation, and 

are associated with PCB Articles or non-liquid PCB wastes if information is 

provided to the landfill owner/operator showing that the PCB level does not 

exceed 500 ppm and they are not ignitable wastes. §761.60(a)(3) 

PCB Inspection Manual J-1 August 2004 
Chemical Waste Landfills Appendix J 

• PCB Transformers, if drained, filled with solvent, allowed to stand for 18 hours, 

and then thoroughly drained. Solvents may include kerosene, xylene, toluene, 

and other solvents in which PCBs are readily soluble. (Precautionary measures 

should be taken to ensure that the solvent flushing procedure is conducted in 

accordance with applicable safety and health standards as required by Federal 

or State regulations.) §761.60(b)(1)(i)(B) 

• PCB articles (excluding transformers, capacitors, hydraulic machines, or PCBcontaminated electrical equipment) with PCB concentrations > 500 ppm, if freeflowing liquid is drained prior to article disposal. §761.60(b)(4)(ii) 

• PCB containers that have not been decontaminated if they have PCB 

concentrations > 500 ppm and if liquid PCBs are drained prior to container 

disposal. §761.60(c)(1)(ii) 

Not Acceptable for Disposal 

• Liquid PCBs (in concentrations > 500 ppm). §761.60(a) 

• Liquid PCBs in concentrations < 50 ppm that are the result of dilution of liquid 

PCBs > 50 ppm. §761.60(a) 

• Large PCB Capacitors with high- and low-voltage that contain 500 ppm or 

greater PCBs (after 3/1/81) unless the Administrator finds that the capability for 

incinerating PCB Capacitors is not available, or that such incineration will 

significantly interfere with incineration of liquid PCBs, or that other good cause is 

shown. §761.60(b)(2)(iii)(B), §761.60(b)(2)(v) 

• PCB small capacitors (after 3/1/81) owned by manufacturers of PCB Capacitors 

or PCB equipment and acquired in the course of such manufacturing. (Other 

small capacitors may be disposed of as municipal solid waste.) §761.60(b)(2)(iv) 

The following tables provide an overview of the regulatory requirements and inspection 

procedures related to chemical waste landfills used to dispose of PCBs. 

August 2004 J-2 PCB Inspection Manual 
Appendix J Chemical Waste Landfills 

Regulatory Requirements Inspection Procedures 

Notice Requirements (§761.60) 

When operating under a landfill waiver 

pertaining to the disposal of dredged 

materials and sludges, owners/operators must 

give State or local governments within whose 

jurisdictions the disposal will take place 

written notice at least 30 days before 

conducting disposal activities. §761.60(f)(2) 

Each operator of a landfill shall give the State 

and local government within whose 

jurisdiction the disposal facility is located at 

least 30 days notice before a facility is first 

used for disposal. §761.60(f)(1)(i) 

At the request of any State or local 

government, owners/operators must provide 

annual notice of the quantities and general 

description of PCBs disposed of during the 

year not more than 30 days after the end of 

the year covered. §761.60(f)(1)(ii) 

Check correspondence file for compliance 

with notification requirements. 

PCB Inspection Manual J-3 August 2004 
Chemical Waste Landfills Appendix J 

Regulatory Requirements Inspection Procedures 

Recordkeeping Requirements (§761.180 & 75) 

Owners/operators of chemical waste landfills 

must establish and maintain for at least 20 

years after the landfill is no longer used for 

the disposal of PCBs the following records: 

• All records and the annual document log 

required by §761.180(b) and (d) for 

disposal facilities. Required records 

include signed manifests, certificates of 

disposal, water analyses, and operations 

records with three-dimensional burial 

coordinates. §761.180(d) 

• Water analysis data for PCBs, pH, specific 

conductance, and chlorinated organics 

obtained in accordance with 

§761.75(b)(6)(iii). §761.180(d)(1) 

• PCB concentration in liquid wastes and 

three-dimensional burial coordinates. 

§761.75(b)(8)(iv). §761.180(d)(2) 

Prior to transferring ownership of a chemical 

waste landfill, the owners/operators must 

notify EPA 30 days before the transfer and 

provide a notarized affidavit stating that the 

transferee agrees to abide by the EPA 

approval document. §761.75(c)(7) 

Check facility records against regulations 

for all required records including: the 

annual document log, signed manifests, 

certificates of disposal, water analyses, 

operations records with three-dimensional 

burial coordinates, water analysis data, 

PCB concentration in liquid wastes, and 

three-dimensional burial coordinates. 

Determine adequacy of water analysis 

data. 

Check for records of PCB concentration in 

liquid wastes. These may be kept in the 

same place as records required under 

§761.180. 

Check for transfer document in EPA 

Regional files. 

August 2004 J-4 PCB Inspection Manual 
Appendix J Chemical Waste Landfills 

Regulatory Requirements Inspection Procedures 

Facility Requirements (§761.75) 

Soils. The landfill site should be located in 

thick, relatively impermeable formations, such 

as large-area clay pans. Where this is not 

possible, the soil should have a high clay and 

silt content with the following parameters: 

§761.75(b)(1) 

• In-place soil thickness of 4 ft or compacted 

soil liner thickness of 3 ft 

• Permeability (cm/sec) equal to or less than 

1 x 10-7 

• Percentage of soil passing No. 200 Sieve > 

30 

• Liquid Limit > 30 

• Plasticity index > 15. 

When the Regional Administrator requires 

synthetic membrane liners, they must provide 

permeability equivalent to the soil parameters 

in §761.75(b)(1), be compatible with PCBs, 

and be at least 30 mils thick. §761.75(b)(2) 

When a landfill has a liner, the 

owners/operators must take precautions, 

including providing adequate soil underlining 

and soil cover, to ensure that the liner does 

not rupture. §761.75(b)(2) 

The bottom of the landfill liner system or 

natural in-place soil barrier must be above the 

historical high groundwater table by at least 

50 ft, and the site must avoid floodplains, 

shorelands, and groundwater recharge areas. 

§761.75(b)(3) 

There must be no hydraulic connection 

between the site and any standing or flowing 

surface water. §761.75(b)(3) 

Review engineering plans and site tests to 

determine compliance with soil parameters 

and liner or soil barrier requirements in 

§761.75(b)(1). 

Check approval document for membrane 

liner requirement. Acquire sample of 

membrane liner if the Regional 

Administrator required synthetic membrane 

liners. 

Verify compliance of the placement of the 

bottom of the landfill liner system or natural 

in-place barrier at least 50 ft above the 

historic high groundwater table when the 

landfill is initially approved. 

Verify that there is no hydraulic connection 

when the landfill is initially approved. 

Check for hydraulic connection to surface 

water. 

PCB Inspection Manual J-5 August 2004 
Chemical Waste Landfills Appendix J 

Regulatory Requirements Inspection Procedures 

Facility Requirements (§761.75) 

The site shall have monitoring wells and 

leachate collection. §761.75(b)(3) 

If the landfill site is below the 100-year flood 

elevation, there must be surface water 

diversion dikes around the perimeter of the 

site at least 2 ft above the flood evaluation. 

§761.75(b)(4)(i) 

If the landfill site is above the 100-year flood 

elevation, the owners/operators must provide 

structures that are capable of diverting all of 

the surface water runoff from a 24-hour, 25-

year storm. §761.75(b)(4)(ii) 

The landfill site shall be located in an area of 

low to moderate relief to minimize erosion and 

to help prevent landslides or slumping. 

§761.75(b)(5) 

A 6-foot woven mesh fence, wall, or similar 

device must be located around the site to 

prevent animals or unauthorized persons from 

entering. §761.75(b)(9)(i) 

The owners/operators must maintain roads to 

and within the site that are adequate to 

support the operation and maintenance of the 

site without causing safety or nuisance 

problems or hazardous conditions. 

§761.75(b)(9)(ii) 

Determine from company records the 

presence of monitoring wells and the 

leachate collection system. 

Determine the 100-year flood evaluation 

from U.S. Geological Survey or U.S. Army 

Corps of Engineers records prior to the 

inspection. During the inspection, 

determine the elevation from facility 

records. Compare these records to 

requirement to determine compliance. 

Measure adequacy of diversion dikes 

when needed. 

Determine from records and actual 

measurement (if necessary) that the water 

diversion structures are capable of 

diverting all of the surface water runoff 

from a 24-hour, 25-year storm. 

Determine if the containment structure 

meets the height requirement and is 

located around the entire perimeter of the 

site. 

Physically inspect roadways to determine 

that they are adequate to support the 

operation and maintenance of the site 

without causing safety or nuisance 

problems or hazardous conditions. 

August 2004 J-6 PCB Inspection Manual 
Appendix J Chemical Waste Landfills 

Regulatory Requirements Inspection Procedures 

Operating Requirements (§761.60 & 75) 

The landfill must comply with all conditions and 

limitations stated in the written approval by the 

Regional Administrator for the Region in which 

the facility is located. §761.75(c) 

Liquid PCBs from incidental sources, such as 

precipitation, condensation, leachate, or load 

separation and are associated with PCB 

articles or non-liquid PCB wastes in 

concentrations of 50 to 500 ppm must be 

accompanied by information showing that the 

liquids do not exceed 500 ppm PCBs. 

§761.60(a)(3)(ii) 

Persons must pretreat and/or stabilize (e.g., 

chemically fix, evaporate, mix with dry inert 

absorbent) bulk liquid PCBs in concentrations 

not exceeding 500 ppm to a nonflowing 

consistency prior to disposal to eliminate the 

presence of free liquids. §761.75(b)(8)(ii) 

Prior to disposal, persons must drain PCB 

Transformers of free-flowing liquid, fill them 

with solvent, allow them to stand for at least 18 

hours, and then drain them thoroughly. 

§761.60(b)(1)(i)(B) 

Prior to disposal, persons must drain freeflowing liquid from other PCB articles 

(excluding transformers) with PCB 

concentrations of 500 ppm or more. 

§761.60(b)(6)(i)(B) 

Check approval document for special 

conditions and limitations. Take careful 

note of operating compliance. 

Examine labels on liquid PCB containers 

to determine PCB concentration. Sample 

if violation is suspected. 

Determine, through statement from 

operator, procedures for stabilizing bulk 

liquid PCBs. Sample if violation is 

suspected. 

Determine from operator or employees 

whether PCB Transformers are properly 

decontaminated prior to disposal. 

Determine from operator or employees 

whether PCB articles were drained prior 

to disposal. 

PCB Inspection Manual J-7 August 2004 
Chemical Waste Landfills Appendix J 

Regulatory Requirements Inspection Procedures 

Operating Requirements (§761.60 & 75) 

Prior to disposal, persons must drain the liquid 

from PCB containers that are not 

decontaminated and that contain PCB 

concentrations of 500 ppm or greater. 

§761.60(c)(1)(ii) 

-orSufficient inert sorbent material to absorb all 

liquid contents must surround all PCB 

containers not drained of liquid. 

§761.75(b)(8)(ii) 

The owners/operators must dispose of liquids 

drained from PCB Items to permit landfill 

disposal in accordance with §761.60(a) or 

§761.70 (governing incineration). §§761.60(b) 

and (c) 

Persons must place PCBs and PCB Items in 

the landfill in a manner that will prevent 

damage to containers or articles. 

§761.75(b)(8)(i) 

Wastes other than PCBs must be compatible 

with PCBs and PCB Items or must be 

segregated from the PCBs throughout the 

waste handling process. §761.75(b)(8)(i) 

No person may dispose of ignitable wastes in a 

chemical waste landfill. §761.75(b)(8)(iii) 

The owners/operators must operate and 

maintain the landfill site in a manner to prevent 

safety problems or hazardous conditions 

resulting from spilled liquids and windblown 

materials. §761.75(b)(9)(iii) 

When storage is necessary prior to disposal, 

the owners/operators must store the PCBs and 

PCB Items in accordance with §761.65. 

§761.60(a)(6) 

Review disposal procedures with a 

responsible facility employee(s). Followup indicators of improper disposal. 

Determine procedures for drainage 

and/or burial of PCB containers. 

Check procedures for handling ignitable 

wastes that may be transferred to the 

facility. 

Assess facility safety measures for spill 

prevention and for general housekeeping 

practices. 

August 2004 J-8 PCB Inspection Manual 
Appendix J Chemical Waste Landfills 

Regulatory Requirements Inspection Procedures 

Monitoring Requirements (§761.75) 

Prior to disposal operations, the 

owner/operator must sample groundwater and 

surface water from the disposal area for use 

as baseline data. §761.75(b)(6)(i)(A) 

The Regional Administrator may designate 

surface water courses that the owner/operator 

must sample at least monthly when the landfill 

is being used for disposal operations. 

§761.75(b)(6)(i)(B) 

EPA requires at least 3 groundwater monitor 

wells equally spaced on a line through the 

center of the disposal area. The line must 

extend from the highest to the lowest water 

table elevation on the property. 

§761.75(b)(6)(ii)(A) 

Groundwater monitor wells must be cased 

and the annular space between the monitor 

zone and the surface must be completely 

backfilled and plugged with cement to prevent 

percolation of surface water into the well bore. 

The well must have a removable cap to 

provide access and to prevent entrance of 

rainwater or storm water runoff. 

§761.75(b)(6)(ii)(B) 

Before obtaining a sample for analysis, the 

person sampling must pump the well to 

remove the volume of liquid initially contained 

in the well §761.75(b)(6)(ii)(B) 

Liquid pumped from groundwater monitor 

wells must be treated to meet applicable State 

or Federal discharge standards or recycled to 

the chemical waste landfill. 

§761.75(b)(6)(ii)(B) 

Check water sampling records are kept for 

the amount of time required. 

Check for monthly sampling records (if 

required by Regional Administrator). 

Check engineering plans to determine the 

locations of the groundwater monitoring 

wells. 

Determine the procedures that the facility 

uses for taking samples and for disposing 

of samples after analysis. 

PCB Inspection Manual J-9 August 2004 
Chemical Waste Landfills Appendix J 

Regulatory Requirements Inspection Procedures 

Monitoring Requirements (§761.75) 

The owner/operator must install a leachate 

collection system above the chemical waste 

landfill and monitor it monthly for the quantity 

and physicochemical characteristics of the 

leachate produced. §761.75(b)(7) 

Leachate must be treated to acceptable limits 

for discharge in accordance with State or 

Federal permits or disposed of by another 

State or federally approved method. 

§761.75(b)(7) 

After final closure of the disposal area, the 

owner/operator must sample surface water 

courses designated by the Regional 

Administrator no less than once every 6 

months. §761.75(b)(6)(i)(C) 

The laboratory must analyze all water 

samples for PCBs, pH, specific conductance, 

and chlorinated organics, and the 

owner/operator must maintain all data and 

records as required in §761.180(d)(1). 

§761.75(b)(6)(iii) 

Sampling methods and analytical procedures 

must comply with 40 CFR 136, as amended. 

§761.75(b)(6)(iii) 

Check engineering plans to verify that the 

facility installed a leachate collection 

system above the landfill and monitoring 

records to verify that the collection system 

is monitored monthly for quantity and 

characteristics of the leachate. 

Check procedures for treatment and 

disposition of leachate samples. 

Check monitoring records for water 

sampling if applicable. 

August 2004 J-10 PCB Inspection Manual 
Appendix K High Efficiency Boilers 

Appendix K 

High Efficiency Boilers 

PCB regulations allow for disposal of specified PCB fluids with concentrations of 50 to less than 

500 ppm PCBs in high-efficiency boilers. Boilers must meet certain design and operating 

criteria. These technical requirements differ depending upon the type of liquid intended for 

disposal, as discussed below. Other regulatory provisions (e.g., marking, storage) may also 

apply and, likewise, will differ based on the waste to be disposed. 

Wastes Acceptable for Disposal 

In general, two types of PCB-contaminated liquids may be disposed of in high-efficiency boilers: 

• Mineral oil dielectric fluid from PCB-contaminated electrical equipment containing 

PCBs in concentrations of 50 to less than 500 ppm. §761.60(a)(2)(iii) 

• Liquids other than mineral dielectric fluid containing PCBs in concentrations of 50 

to less than 500 ppm. 

Technical requirements applicable to wastes authorized for disposal in high-efficiency boilers 

are described below under the relevant regulatory provisions. Requirements applicable to each 

of the two waste fluid categories are discussed separately, followed by a summary of provisions 

that applies to both categories. 

PCB Inspection Manual K-1 August 2004 
High Efficiency Boilers Appendix K 

Regulatory Requirements Inspection Procedures 

Owners/operators of high efficiency Verify that high efficiency boilers burning mineral 

boilers burning mineral oil dielectric fluid oil dielectric fluid containing a PCB concentration 

containing a PCB concentration of > 50 of > 50 ppm, but <500 ppm meet the following 

ppm but < 500 ppm must operate criteria: 

according to certain parameters. -the boiler is rated at a minimum of 50 million 

§761.71(a) BTU hours (by checking the manufacturer’s 

manual or website) 

-if the boiler uses natural gas or oil as the primary 

fuel, the CO concentration 

in the stack is < 50 ppm and the excess oxygen 

is at least 3% when PCBs are being burned 

-if the boiler uses coal as the primary fuel, the 

CO concentration in the stack is < 100 ppm and 

the excess oxygen is at least 3% when PCBs are 

being burned 

-the mineral oil dielectric fluid does not comprise 

more than 10% (on a volume basis) of the total 

fuel feed rate 

-the mineral oil dielectric fluid is not fed into the 

boiler unless the boiler is operating at its normal 

operating temperature (this prohibits feeding 

these fluids during either start up or shut down 

operations) 

-the owner or operator of the boiler does one of 

the following: 

--continuously monitors and records the 

CO concentration and excess oxygen 

percentage in the stack gas while burning 

mineral oil dielectric fluid 

--if the boiler will burn <30,000 gal of 

mineral oil dielectric fluid per year, 

measures and records the CO 

concentration and excess oxygen 

percentage in the stack gas at regular 

intervals of no longer than 60 min while 

burning mineral oil dielectric fluid. 

August 2004 K-2 PCB Inspection Manual 
Appendix K High Efficiency Boilers 

Regulatory Requirements Inspection Procedures 

Owners/operators of high efficiency -the primary fuel feed rates, mineral oil dielectric 

boilers burning mineral oil dielectric fluid fluid feed rates, and total quantities of both 

containing a PCB concentration of > 50 primary fuel and mineral oil dielectric fluid fed to 

ppm but < 500 ppm must operate the boiler are measured and recorded at regular 

according to certain parameters. intervals of no longer than 15 min while burning 

§761.71(a) (Continued) mineral oil dielectric fluid 

-the CO concentration and the excess oxygen 

percentage are checked at least once every hour 

that mineral oil dielectric fluid is burned. If either 

measurement falls below the levels specified in 

this section, the flow of mineral oil dielectric fluid 

to the boiler is stopped immediately. 

Verify that 30 days before any person burns 

mineral oil dielectric fluid in the boiler, the owner 

or operator provides written notice to the EPA 

Regional Administrator for the EPA Region in 

which the boiler is located. 

Verify that the notice contains the following 

information: 

-the name and address of the owner or operator 

of the boiler and the address of the boiler 

-the boiler rating in units of BTU/hour 

-the CO concentration and the excess oxygen 

percentage in the stack of the boiler when it is 

operated in a manner similar to the manner in 

which it will be operated when mineral oil 

dielectric fluid is burned 

-the type of equipment, apparatus, and 

procedures to be used to control the feed of 

mineral oil dielectric fluid to the boiler and to 

monitor and record the CO concentration and 

excess oxygen percentage in the stack. 

PCB Inspection Manual K-3 August 2004 
High Efficiency Boilers Appendix K 

Regulatory Requirements Inspection Procedures 

Owners/operators of high efficiency 

boilers burning mineral oil dielectric fluid 

containing a PCB concentration of > 50 

ppm but < 500 ppm must operate 

according to certain parameters. 

§761.71(a) (Continued) 

Verify that, when burning mineral oil dielectric 

fluid, the boiler operates at a level of output no 

less than the output at which the required 

measurements were taken. 

Verify that any person burning mineral oil 

dielectric fluid in a boiler obtains the following 

information and retains the information for 5 yr at 

the boiler location 

-the data which is required to be collected 

-the quantity of mineral oil dielectric fluid burned 

in the boiler each month. 

Owners/operators of high efficiency 

boilers burning liquids other than mineral 

oil dielectric fluid containing a PCB 

concentration of > 50 ppm but 

< 500 ppm must operate according to 

certain parameters. §761.71(b) 

Verify that a high efficiency boiler burning liquids 

other than mineral oil dielectric fluid containing a 

PCB concentration of > 50 ppm but < 500 ppm 

meets the following criteria: 

-the boiler is rated at a minimum of 50 million 

BTU/hour 

-if the boiler uses natural gas or oil as the primary 

fuel, the carbon monoxide concentration in the 

stack is < 50 ppm and the excess oxygen is at 

least 3% when PCBs are being burned 

-if the boiler uses coal as the primary fuel, the 

carbon monoxide concentration in the stack is < 

100 ppm and the excess oxygen is at least 3% 

when PCBs are being burned 

-the waste does not comprise more than 10% 

(on a volume basis) of the total fuel feed rate 

-the waste is not fed into the boiler unless the 

boiler is operating at its normal operating 

temperature (this prohibits feeding these fluids 

during either start up or shut down operations) 

August 2004 K-4 PCB Inspection Manual 
Appendix K High Efficiency Boilers 

Regulatory Requirements Inspection Procedures 

Owners/operators of high efficiency 

boilers burning liquids other than mineral 

oil dielectric fluid containing a PCB 

concentration of > 50 ppm but 

< 500 ppm must operate according to 

certain parameters. §761.71(b) 

(Continued) 

-the owner or operator of the boiler does one of 

the following: 

-- continuously monitor and record the 

CO concentration and excess oxygen 

percentage in the stack gas while burning 

waste fluid 

-- if the boiler will burn <30,000 gal of 

waste fluid per year, measure and record 

the CO concentration and excess oxygen 

percentage in the stack gas at regular 

intervals of no longer than 60 min while 

burning waste fluid 

-the primary fuel feed rate, waste fluid feed rate, 

and total quantities of both primary fuel and 

waste fluid fed to the boiler are measured and 

recorded at regular intervals of no longer than 15 

min while burning waste fluid 

-the CO concentration and the excess oxygen 

percentage are checked at least once every hour 

that the waste is burned. If either measurement 

falls below the specified levels, the flow of waste 

to the boiler is stopped immediately. 

Verify that the owner/operator obtained approval 

from the EPA Regional Administrator prior to 

burning liquids other than mineral oil dielectric 

fluid containing a PCB concentration of > 50 ppm 

but < 500 ppm. 

Verify that the request for approval contains the 

following: 

-the name and address of the owner or operator 

of the boiler and the address of the boiler 

-the boiler rating in units of BTU/hour 

-the CO concentration and the excess oxygen 

percentage in the stack of the boiler when it is 

operated in a manner similar to the manner in 

which it will be operated when low concentration 

PCB liquid is burned 

PCB Inspection Manual K-5 August 2004 
High Efficiency Boilers Appendix K 

Regulatory Requirements Inspection Procedures 

Owners/operators of high efficiency -the type of equipment, apparatus, and 

boilers burning liquids other than mineral procedures to be used to control the feed of 

oil dielectric fluid containing a PCB mineral oil dielectric fluid to the boiler and to 

concentration of > 50 ppm but monitor and record the carbon monoxide 

< 500 ppm must operate according to concentration and excess oxygen percentage in 

certain parameters. §761.71(b) the stack 

(Continued) -the type of waste to be burned (e.g., hydraulic 

fluid, contaminated fuel oil, heat transfer fluid, 

etc.) 

-the concentration of PCBs and of any other 

chlorinated hydrocarbon in the waste and the 

results of analyses using the American Society of 

Testing and Materials (ASTM) methods 

(NOTE: On the basis of the information -the quantity of wastes estimated to be burned in 

in the request for approval, and any a 30-day period 

other available information, the U.S. -an explanation of the procedures to be followed 

EPA Regional Administrator may, at to ensure that burning the waste will not 

his/her discretion, find that the alternate adversely affect the operation of the boiler such 

disposal method will not present an that combustion efficiency will decrease. 

unreasonable risk of injury to health or 

the environment and approve the use of Verify that, when burning PCB wastes, the boiler 

the boiler.) operates at a level of output no less than the 

output when it is operated in a manner similar to 

the manner in which it will be operated when low 

concentration PCB liquid is burned. 

Verify that the following information is obtained 

and retained for 5 yr at the boiler location: 

-the data required to be collected 

-the quantity of low concentration PCB liquid 

burned in the boiler each month 

-the analysis of the waste required once a month 

for each month during which 

low concentration PCB liquid is burned in the 

boiler. 

August 2004 K-6 PCB Inspection Manual 
Appendix L Alternative Disposal Methods 

Appendix L 

Alternative Disposal Methods 

For PCBs and PCB Items 

Approval Requirements §761.60 

In accordance with Section 761.60(e), the Regional Administrator (or the Director of NPCD) may 

approve of the request for the use of an alternative method, at her/his discretion, if s/he makes 

the following findings: 

• That the alternative method will destroy PCBs as efficiently as does an approved 

incinerator (under Section 761.70) or a high efficiency boiler. §761.71 

• That the alternative method of destroying PCBs will not present an unreasonable 

risk of injury to health or the environment. §761.60(e) 

The Regional Administrator (or the Director of NPCD) must state the approval of any alternative 

method in writing. It may contain appropriate conditions and limitations as deemed appropriate 

by the approval authority. The inspector should obtain the facility’s approval document and refer 

to it during the inspection. The inspector should verify compliance with the approval as well as 

the regulations. 

Since §761.60(e) approvals have a variety of technologies, the best sources of information are 

found by reading the approval and talking to the permit writer. Please note that some of the 

§761.60(e) approvals are Regional while other approvals may be mobile, or located in more than 

one Region (i.e., a National approval). To avoid confusion, it is best to determine whether the 

approval is Regional or National. If it is a National approval, the inspector may want to contact 

other Regions for possible violations or contact EPA Headquarters Enforcement. 

The recycling of PCB fluorescent light ballasts is covered in this section. Ballast recyclers 

reclaim metals (e.g., sheet steel, high silicon steel, copper, aluminum) from ballast components. 

Facilities may not recycle leaking ballasts and must properly dispose of them. 

The recycling process typically involves freezing the ballast to enbrittle the potting compound, 

separating the metal case to allow the ballast core with capacitor to drop out, and cutting the 

leads to the capacitor, which contains PCBs and is regulated for disposal, from the transformer 

core. The frozen potting material encased transformer core is then struck on the edge of a fixed 

metal bar located over a waste collection drum or on the edge of the drum to shatter the brittle 

PCB Inspection Manual L-1 August 2004 
Alternative Disposal Methods Appendix L 

potting material allowing the brittle material to drop into the waste container. Any potting material 

still adhering to the core is crumbled off with gloved hands and/or removed with an air driven 

chisel or needle gun. The metal recovery activity scatters potting material far and wide. To 

insure that PCBs are not released from the decontamination area to the environment, the activity 

should be conducted within an enclosure equipped with walls, roof, and energy saving type strip 

doors at personnel and material ingress and egress points. Workers should also be protected 

against dermal contact and inhalation of PCB containing materials with disposable painter’s 

breathing masks, eye protection, gloves, and coveralls. 

In addition to alternative approval for disposal, ballast recyclers usually have EPA approval as a 

Commercial TSCA storer for storing the incoming ballasts and the PCB wastes generated by 

the recycling process. If the facility has EPA Commercial Storer approval, the inspector should 

collect copies of at least the last 12 months of manifests and bills of lading, which can be used 

to determine if the facility at any time exceeded their approved storage capacity. 

When inspecting a PCB fluorescent light ballast recycler, the inspector should make sure that 

PCB wastes are contained within the work area and not allowed to migrate to other areas of the 

facility or outside of the facility. 

The inspector should visually inspect or collect samples of recovered metals. Unrestricted use 

decontamination standards for non-porous surfaces previously in contact with non-liquid PCBs 

for unrestricted use are: 

• #10 ug/100 cm2 as measured by standard wipe test, or 

• Visual Standard No. 2, Near White Blast Cleaned Surface Finish of the National 

Association of Corrosion Engineers (NACE) as verified by visual inspection of all 

cleaned areas. 

The decontamination standards for disposal in a smelter meeting specified standards under 

§761.72 are: 

• #100 ug/100 cm2 as measured by standard wipe test, 

• or Visual Standard No. 3, Commercial Blast Cleaned Surface Finish of NACE as 

verified by visual inspection of all cleaned areas. 

Notice Requirements §761.60 

Owners and operators of an incinerator, a chemical waste landfill, or an approved alternative 

disposal facility must give the following written notices to the State and local governments where 

the facility is located: 

• Notice at least 30 days before a facility is first used for disposal of PCBs. 

§761.60(f)(1)(i) 

August 2004 L-2 PCB Inspection Manual 
Appendix L Alternative Disposal Methods 

• At the request of any State or local government, annual notice (given no more 

than 30 days after the end of the year covered) of the quantities and general 

description of the PCBs disposed of during the year. §761.60(f)(1)(ii) 

• To avoid confusion, inspectors should check if facility has Regional Approval 

versus Nationwide Approval. 

PCB Inspection Manual L-3 August 2004 
Alternative Disposal Methods Appendix L 

Blank Page 

August 2004 L-4 PCB Inspection Manual 
Appendix M Scrap Metal Recovery Ovens and Smelters 

Appendix M 

Scrap Metal Recovery Ovens and Smelters 

Scrap metal recovery ovens and smelters may burn PCB-contaminated articles regulated for 

disposal such as transformer cores and metal surfaces contaminated with PCBs less than 500 

ppm from which all free-flowing liquids have been removed. The scrap metal recovery ovens 

and smelters burn off the PCB contamination so the scrap metal can be recovered. 

The following tables provide an overview of the regulatory requirements and inspection 

procedures related to scrap metal recovery ovens and smelters used to remove PCB 

contamination from metals. 

Regulatory Requirements 

Scrap metal recovery ovens or smelters 

being used for the disposal of PCBs 

must meet specific requirements. 

§761.72 

(NOTE: Any person may dispose of 

residual PCBs associated with PCBContaminated articles regulated for 

disposal under §761.60(b), metal 

surfaces in PCB remediation waste 

regulated under §761.61, or metal 

surfaces in PCB bulk product waste 

regulated under §761.62(a)(6) and 

§761.79(c)(6), from which all freeflowing liquids have been removed: in a 

scrap metal recovery oven or a smelter 

meeting the requirements specified in 

this table.) 

Inspection Procedures 

Verify that the scrap metal recovery oven meets 

the following: 

-it has at least 2 enclosed (i.e., negative draft, no 

fugitive emissions) interconnected chambers 

-equipment with all free-flowing liquid removed is 

first placed in the primary chamber at room 

temperature 

-the primary chamber operates at a temperature 

between 537 0 C and 650 0 C for a minimum of 

2.5 h and reaches a minimum temperature of

650 0 C (1,202 .0 F) once during each heating 

cycle or batch treatment of unheated, 

liquid-free equipment 

-heated gases from the primary chamber feed 

directly into the secondary chamber (i.e., 

afterburner) which operates at a minimum 

temperature of 1,200 0 C (2,192 0 F) with at least 

a 3% excess oxygen and a retention time of 2.0 s 

with a minimum combustion efficiency of 99.9%. 

-heating of the primary chamber does not 

commence until the secondary chamber has 

reached a temperature of 1,200 +/- 100 0 C 

(2,192 +/- 180 0 F) 

PCB Inspection Manual M-1 August 2004 
Scrap Metal Recovery Ovens and Smelters Appendix M 

Regulatory Requirements Inspection Procedures 

Scrap metal recovery ovens or smelters Verify that the scrap metal recovery oven meets 

being used for the disposal of PCBs the following: 

must meet specific requirements. -continuous emissions monitors and recorders 

§761.72 (Continued) for CO2, CO, and excess oxygen in the 

secondary chamber and continuous temperature 

recorders in the primary and secondary 

chambers are installed and operated while the 

primary and secondary chambers are in 

operation to assure that the 2 chambers are 

within the specified operating parameters 

-emissions from the secondary chamber are 

vented through an exhaust gas stack in 

accordance with either of the following: 

--valid state and local air regulations and 

permits 

--particulates < 0.015 grains/dscf, sulfur 

dioxide < 35 ppmv, nitrogen oxide < 150 

ppmv, carbon monoxide < 35 ppmv, and 

hydrogen chloride < 35 ppmv 

-exhaust gas stack emissions are: particulates < 

0.015 grains/dscf, sulfur dioxide < 35 ppmv, 

nitrogen oxide < 150 ppmv, carbon monoxide < 

35 ppmv, and hydrogen chloride < 35 ppmv 

-a measurement of the temperature in the 

secondary chamber at the time the primary 

chamber starts heating is taken, recorded, and 

retained at the facility for 3 yr from the date each 

charge is introduced into the primary chamber. 

-the operating temperature of the hearth is at 

least 1,000 0 C at the time it is charged with any 

PCB-Contaminated non-porous surface 

-each charge containing a PCB-Contaminated 

item is added into molten metal or a hearth at > 

0 1,000 C

August 2004 M-2 PCB Inspection Manual 
Appendix M Scrap Metal Recovery Ovens and Smelters 

Regulatory Requirements Inspection Procedures 

Scrap metal recovery ovens or smelters Verify that the smelter meets the following: 

being used for the disposal of PCBs -successive charges are not introduced into the 

must meet specific requirements. hearth in less than 15-min intervals. 

§761.72 (Continued) -the smelter operates in compliance with any 

applicable emissions standards in the Clean Air 

Act standards of performance for new stationary 

sources in 40 CFR 60 

-the smelter has an operational device which 

accurately measures directly or indirectly, the 

temperature in the hearth 

-takes, records and retains at the disposal facility 

for 3 yr from the date each charge is introduced, 

a reading of the temperature in the hearth at the 

time it is charged with a non-porous surface 

item. 

Verify that scrap metal recovery ovens and 

smelters either have a final permit under RCRA 

or are operating under a valid state air emissions 

permit which includes a standard for PCBs. 

(NOTE: Scrap metal recovery ovens Verify that scrap metal recovery ovens and 

and smelters are not required to submit smelters disposing of PCBs provide notification 

annual reports.) as disposers of PCBs and otherwise comply with 

all applicable provisions of 40 CFR 761, Subparts 

J and K, as well as other applicable federal, 

state, and local laws and regulations. 

PCB Inspection Manual M-3 August 2004 
Scrap Metal Recovery Ovens and Smelters Appendix M 

Blank Page 

August 2004 M-4 PCB Inspection Manual 
Appendix N Reclassification of Retrofilled Transformers 

Appendix N 

Reclassification of Retrofilled Transformers 

If test results show 

the PCB concentration 

(ppm) in the 

transformer prior to 

retrofill is... 

and you retrofill the 

transformer with 

dielectric fluid 

containing... 

and you... and test results show 

the PCB concentration 

(ppm) after retrofill 

is... 

then the 

transformer’s 

reclassified status 

is... 

$1,000 (or untested) < 50 ppm PCBs operate the 

transformer 

electrically under 

loaded conditions for 

at least 90-continuous 

days after retrofill, 

then test the fluid for 

PCBs 

$50 but < 500 PCB-contaminated 

< 50 ppm PCBs operate the 

transformer 

electrically under 

loaded conditions for 

at least 90-continuous 

days after retrofill, 

then test the fluid for 

PCBs 

<50 non-PCB 

$500 but <1,000 <50 ppm PCBs test the fluid for PCBs 

at least 90 days after 

retrofill 

$50 but <500 PCB-contaminated 

<50 ppm PCBs test the fluid for PCBs 

at least 90 days after 

retrofill 

<50 non-PCB 

$50 but <500 $2 but <50 ppm PCBS test the fluid for PCBs 

at least 90 days after 

retrofill 

<50 non-PCB 

<2 ppm PCBs (no need to test) (not applicable) non-PCB 

Source: §761.30(a)(2) 

PCB Inspection Manual N-1 August 2004 
Reclassification of Retrofilled Transformers Appendix N 

Blank Page 

August 2004 N-2 PCB Inspection Manual 
Appendix O Sample Seal and Chain-of-Custody Form 

Appendix O 

Sample Seal and Chain-of-Custody Form 

Chain-of-Custody forms may be obtained by calling the EPA Headquarters Warehouse in 

Cincinnati, Ohio at (513) 489-8190. 

PCB Inspection Manual O-1 August 2004 
Sample Seal and Chain-of-Custody Form Appendix O 

EPA 

Chain of Custody Record 

United States 

Environmental Protection 

Agency 

Sample Number Task Number 

Inspection Number 

Inspector Name and Address Sample Name 

Date Sample Time Duplicate Requested 

( ) Yes ( ) No 

Inspector Signature Location of Sampling 

Analysis/Testing Required 

Laboratory 

Date Received 

Received By 

Sent Via 

Sample Condition 

Condition of Seals 

Units Received 

Storage Location 

Assigned By 

Assigned To 

Delivered By 

Date Delivered 

Number of Units Received 

Units Analyzed 

Date Seal Broken 

Date Resealed 

Resealed By 

Storage Location 

Date Results of Analysis Issued Date Results of Analysis 

to EPA Issued to Facility 

Remarks 

August 2004 O-2 PCB Inspection Manual 

DEPARTMENT OF TRANSPORTATION

HAZARDOUS MATERIALS TRAINING

What are DOT 

training 

requirements? 

Why does 

hazmat training 

apply to me? 

Does my EPA 

training 

substitute for 

DOT training 

requirements? 

What type of 

DOT training do 

I need? 

What are DOT’s 

training 

requirements for 

hazardous 

materials? 

DOT’s training requirements can be found at 49 CFR Part 172, Subpart H. In 

general, any employee who has a responsibility working with hazardous 

materials (hazmat) that is placed in commerce must have hazmat training. The 

employee must be familiar or aware of the requirements enabling the employee 

to recognize and identify hazardous materials, i.e., environmental samples vs. 

hazardous waste samples, consistent with the hazard communication standards. 

The training must be commensurate with functions and responsibilities of the 

employee. 

As an inspector, you are likely to be a hazmat employee because you collect 

samples during an inspection and prepare the hazmat samples for 

transportation. The EPA is a hazmat employer because the Agency causes 

hazmat to be transported or shipped in commerce through its employees. DOT 

defines "hazmat employer" to include any department, agency, or 

instrumentality of the United States, a State, a political subdivision of a State, 

or an Indian Nation. Administrative and secretarial staff are also subject to 

DOT training if their responsibilities cause hazmat materials to be placed into 

commerce, i.e., preparing shipping papers. 

EPA Health & Safety courses may substitute for some or all of DOT’s safety 

training requirements. However, the employer must make that determination. 

No EPA Health & Safety course will meet DOT’s general awareness 

/familiarization requirement. See DOT’s training requirements. 

DOT hazmat training is function-specific. For most inspectors, the general 

awareness hazardous materials training course found on the DOT’s website 

will be sufficient to meet the DOT training requirements. Alternatively, the 

employer can provide function specific training from other sources.(see 

below). 

DOT’s hazmat training, 49 CFR §172.704, focuses on three requirements 

applicable to inspectors and administrative staff: 

• General awareness/familiarization 

T Each hazmat employee shall be provided general 

awareness/familiarization training designed to provide 

familiarity with the hazmat requirements and to enable the 

employee to recognize and identify hazardous materials 

consistent with the hazard communication standards. 

EPA Inspector Training February 2002 

DOT’s General Awareness Hazardous Materials Training 
What are DOT’s 

training 

requirements for 

hazardous 

materials? cont. 

Where can I find 

training 

opportunities? 

How long does 

the certification 

last? 

Who is 

responsible for 

training? 

Who is 

responsible for 

keeping the 

training record? 

• Function-specific 

T Each hazmat employee shall be provided function-specific 

training as it applies to the employee’s job responsibilities. 

• Safety 

T Emergency response information required by part 172, 

 subpart G, i.e., information that can be used in the mitigation

 of an incident involving hazardous materials; 

T Measures to protect the employee from the hazards associated 

with hazardous materials to which they may be exposed in the 

work place, including specific measures the hazmat employer 

has implemented to protect employees from exposure; and 

T Methods and procedures for avoiding accidents, such as the 

proper procedures for handling packages containing hazardous 

materials. 

A good training resource is DOT’s hazmat page, hazmat.dot.gov/training. 

You download the instructor’s and student’s training manual for in-house use. 

The training manual does include test questions. Self-training is acceptable by 

DOT so long as §172.704 training requirements are met. The DOT’s 

Transportation Safety Institute in Oklahoma City, OK offers training on-site. 

Course dates are available from the website. 

In addition to DOT’s hazmat site, this web link, hazmat.dot.gov/thirdpty.htm 

identifies third party providers who offer a variety of hazmat training courses. 

The hazardous materials training is required to be completed within the first 90 

days of employment. The certification period is good for three years and then 

the hazardous materials training program must be retaken. If your job 

responsibilities change, your training needs may change. 

The employer is responsible. DOT’s definition of employer is not clear in 

terms of EPA’s administrative structure. “Employer” could be defined as the 

Administrator or any other manager in direct supervisory line of the employee. 

The employer is responsible for keeping the employee’s records. 

EPA Inspector Training February 2002 

DOT’s General Awareness Hazardous Materials Training 
What should be in 

the training 

record? 

Specifically, what 

documents need to 

be retained? 

Does the employee 

have to “pass” the 

test? 

Know Your 

Shipper’s 

Requirements! 

Documentation that shows the employee has completed the necessary training, 

has been tested and certified. 

A record of current training, inclusive of the preceding three years must be 

retained for as long as the employee is employed by that employer as a hazmat 

employee and for 90 days thereafter. The record shall include the following 

information:

 (1) The inspector's name;

 (2) The most recent training completion date of the inspector’s training;

 (3) A description, copy, or the location of the training materials used to meet

 the requirements;

 (4) The name and address of the person providing the training; and

 (5) Certification that the hazmat employee has been trained and 

tested.

The requirements do not state that the employee must "pass" a test; however, 

an employee may only be certified in areas in which he/she can successfully 

perform their hazmat duties. 

Before collecting samples, know which shipping company you will be using to 

ship your samples. Some require additional training and certification beyond 

the basic DOT requirements. Here are three common carriers with some of 

their requirements for shipping hazmat materials. 

Federal Express (FedEx) 

The shipping method you select determines what type of training FedEx 

expects you to have completed. If you plan to ship samples by ground, the 

DOT training requirements are sufficient. If you plan to ship the samples by 

air, then you must be trained according to International Air Transport 

Association (IATA) regulations. Successful completion of the IATA 

requirements will meet DOT’s hazard communications requirements. IATA 

training and information can be found at: www.iata.org. 

EPA Inspector Training February 2002 

DOT’s General Awareness Hazardous Materials Training 
Know Your 

Shipper’s 

Requirements! 

cont. 

United Parcel Service (UPS) 

DOT’s general awareness training is acceptable by UPS for ground shipments. 

Shipments by air require IATA training. 

United States Postal Service (USPS) 

DOT’s general awareness training and testing is acceptable by USPS for both 

shipping by ground and air. However, the Postal Service does have limits 

which are more stringent than DOT’s regulations. Check this website for 

further details - http://pe.usps.gov/text/dmm/c023.htm 

Before shipping, you should inquire with the shipping company if they have 

additional requirements for handling, packaging and shipment limitations for 

the hazmat materials. 

Here are a few issues an inspector may face with the different shippers: 

• Do you want them to meet you at the site? You may need to call ahead 

to schedule the pickup before you arrive at the site to collect samples. 

• Do you plan on dropping the shipment off? Not all offices can accept 

dangerous goods and hazmat. 

• Shipping papers may need to be typed, not handwritten. Do you bring 

a portable typewriter with you or type the shipping papers before 

leaving the office? 

EPA Inspector Training February 2002 

DOT’s General Awareness Hazardous Materials Training 
Appendix Q Appearing as a Witness 

Appendix Q 

Appearing as a Witness 

I. Introduction 

Inspectors perform a vital role throughout the regulatory enforcement process. An enforcement 

action begins with the inspector collecting and documenting on-site evidence. This chapter 

deals with the inspector’s responsibility to present evidence in formal legal proceedings. 

Due in large part to the high quality work that inspectors produce, the EPA files strong cases. 

Nearly all of the cases that the EPA files result in out of court settlements that will not usually 

require the inspector’s testimony. Of the cases that do not settle, a substantial majority of the 

legal action takes place in the EPA administrative law system rather than the federal courts. 

Major differences distinguish administrative from federal courts, such as rapid processing and 

the absence of a jury. Despite the differences between these two legal proceedings, the 

inspector’s role as a witness will remain predominantly the same. 

Under most circumstances an inspector will be called as a “fact witness.” A fact witness 

describes personal knowledge obtained through one of the five senses. Throughout the 

enforcement process, everything an inspector hears, sees, samples, or records may become 

evidence about which he or she may be questioned. Many cases are tried years after the field 

and laboratory activities have been conducted. Thus, the inspection report and field notebook 

should be sufficiently detailed and legible to allow the inspector to reconstruct the inspection “on 

the record.” 

II. Pre-Testimony Matters 

A. Preparation 

Preparation is the key to giving accurate and effective testimony. Successful preparation 

requires a substantial time commitment. Attorneys and witnesses work together in two types of 

preparation: factual and procedural. 

The inspector will complete most of the factual preparation by writing the inspection report as 

described in this manual. The witness and the attorney will meet to discuss details from this 

report. Other items should also be discussed, including the field notebook, photographs, and the 

inspector’s qualifications. Qualifications include the inspector’s educational degree, professional 

accreditations, inspector training as required by Executive Order 3500.1, and on the job 

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Appearing as a Witness Appendix Q 

experience. The inspector’s qualifications must never be exaggerated. Even a small 

exaggeration may cause the inspector’s testimony to lack credibility. 

The inspector should inform the EPA attorney of any problems, questions, or concerns in the 

case as early as possible. An example of one such concern are the confidential business 

information (CBI) procedures to which the inspectors must adhere. CBI procedures that bind 

the inspector during an inspection also have implications for the legal proceeding. 

The attorney has the primary responsibility over procedural preparation, which is assembling the 

facts for presentation in a formal legal setting. In addition to one-on-one preparation, the 

inspector and attorney may consider whether the inspector should participate in a mock trial or 

visit a hearing to observe other witnesses testifying. During one-on-one preparation, the attorney 

and the inspector should discuss: 

• Times and dates that require the inspector’s attendance. 

• Legal etiquette and procedure. 

• General legal framework of the case. 

• Significance of the inspector’s testimony in this framework. 

• Probable areas of questioning, including direct and cross-examination. 

• What documents, if any, will be used by the inspector during testimony. 

Before giving testimony, the witness should again review inspection documents, his or her 

professional qualifications, and information provided by the attorney. This review should be 

repeated until the witness has become thoroughly familiar with the details of the testimony and 

how it will be presented. 

An inspector may be subpoenaed to give testimony by the opposing attorney or even by the EPA 

attorney. A subpoena is a Court Order to appear, and it is a mandatory legal process that does 

not suggest dishonesty or bias, an inspector should not be offended if he or she receives a 

subpoena. If an inspector is subpoenaed, the appropriate EPA attorney should be contacted 

immediately. Time will be short to prepare to give testimony or to fight the subpoena. 

B. Legal Etiquette, Appearance, and Demeanor 

A witness’s conduct should reflect the solemn nature of the administrative or judicial proceeding. 

To act in accordance with required legal etiquette, a witness should: 

• Dress conservatively following the advice of the EPA attorney. 

• Arrive early and be available immediately when called to testify. 

• Address the judge as “your honor.” 

• Treat an administrative proceeding as seriously as a federal court trial. 

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A witness should not: 

• Whisper, talk, or make jokes in the hearing room. If necessary, a note may be passed. 

• Bring magazines or newspapers into the hearing room. 

• Discuss the case within the hearing of anyone but the EPA attorney. 

Posture, speech, and appearance influence a witness’s credibility. An inspector is a 

professional who collects, preserves, and presents evidence. In order to convey a professional 

demeanor, an inspector should: 

• Firmly but politely speak to the opposing attorney. 

• Appear natural and animated, but not impatient or overly anxious to testify. 

• Minimize nervous tendencies. 

• Remain calm. 

• Refrain from showing hostility toward the opposing counsel, the specific defendant, or 

the regulated community as a whole. 

III. Giving Testimony 

A. General Considerations 

A witness gives testimony to create a legal record of the facts. Before giving testimony, a 

witness will take an oath that he or she will tell the truth. Failure to tell the truth is actionable as 

perjury. A witness may give pre-trial testimony in a deposition or trial testimony under direct 

examination or cross-examination. 

To give effective testimony, a witness should 1) listen, 2) pause, and then 3) answer if possible. 

Listening carefully to the wording and implications of an attorney’s questions requires significant 

effort. If the witness does not understand the question, he or she should stop to think, have the 

question repeated, or have it explained. 

A witness should pause before answering. Pausing provides time to think, makes the response 

more considered and deliberate, and gives the attorney time to object if necessary. When 

pausing, the witness should not use words such as “um.” As the court reporter documents 

everything spoken, these words may incorrectly indicate hesitation when later read from the 

written record. 

When answering, a witness should: 

• Reply with a “Yes” or “No” when appropriate. 

• Speak in complete sentences when answering more fully. 

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• Be as descriptive as possible in referring to exhibits or photographs. For example, “In the 

upper right hand corner, we see” rather than “Here, we see.” 

• Stop immediately if the judge or either of the lawyers begins to speak. 

• Avoid memorizing answers to potential questions. 

• Never manipulate an answer to benefit one side. 

A witness’s credibility is defined as the degree of confidence that the judge or jury gives to the 

witness’s testimony. The opposing attorney will try to “impeach” a witness’s credibility by 

suggesting the following: bias, inaccuracy, inability to recollect, false testimony, or even 

corruption. To lessen the opposing attorney’s ability to discredit the witness’s testimony, the 

witness should: 

• Tell the truth. 

• Answer only the question asked, without volunteering information. 

• Explain answers fully. If the opposing attorney does not allow a full explanation, the EPA 

attorney can choose to bring this out later in the trial during a redirect examination. 

• Answer within the limits of his or her knowledge of the facts. 

• Say, “I don’t know,” or “I don’t remember,” if that is the case. 

• Correct any mistakes in his or her previous testimony as soon as a mistake is

recognized.

• Carefully identify estimates. 

• Never exaggerate. 

• Never guess. 

• Avoid absolutes, like “I always...” or “I never...”. 

B. Pre-Trial Testimony: Depositions 

In a federal court trial, an inspector may be subpoenaed to give a deposition, which is pre-trial 

questioning under oath by the opposing attorney. Depositions are not often conducted in 

administrative hearings. Participants include the attorneys for each side, a court reporter, and 

the witness. Most importantly, a judge will have no role in deposition testimony unless one side 

abuses the process and the other side seeks relief. 

The attorney may use a deposition to “discover” information or to contradict a witness’s 

testimony at trial. In most cases, deposition testimony cannot be used as a substitute for live 

testimony. To properly prepare for and give deposition testimony, an inspector should: 

• Read the notice of deposition. 

• Consult with the EPA attorney to determine what documentation will be necessary. 

• Realize that he or she is not “off the record” until completely away from the deposition 

setting. 

• Request a break whenever needed. 

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After the deposition is transcribed, the witness can read it to make any appropriate corrections. 

Small errors always exist, but some transcripts contain absolute disasters. Errors in technical 

details, such as numbers and units, can have a large impact. A witness should never waive the 

right to read and sign the finished deposition. 

C. Trial Testimony: Direct Examination 

The EPA attorney will question the inspector during direct examination in order to put the facts 

known by the inspector on the record in a well-organized and logical manner. 

A good direct examination leads the inspector through his or her entire testimony using a 

dialogue of short questions and answers. The attorney is responsible for asking appropriate 

questions in the correct order and ensuring that nothing important is omitted. The witness is 

only responsible for answering the attorney’s questions completely and truthfully. 

In order to avoid legally objectionable or tactically unwise remarks, the witness should trust the 

EPA attorney’s final decision concerning what questions to ask at the hearing. If the inspector 

has forgotten a fact, the attorney may refresh the inspector’s recollection with documents, such 

as the inspection report. The EPA attorney might also ask, “Is there anything else?” to signal to 

the inspector that something has been left out. 

Redirect examination is a round of questioning only concerning issues raised during crossexamination. Redirect will give the EPA attorney an opportunity to reduce any damage done to 

the credibility of the inspector’s testimony during cross-examination. 

D. Trial Testimony: Cross-Examination 

Cross-examination, questioning by the opposing attorney, will subject the witness to a more 

difficult interrogation than direct examination. The opposing attorney will try to cast doubt on the 

credibility of the witness’s testimony. Many witnesses fear counsel techniques such as leading 

questioning and twisting interpretation. The EPA attorney will try to protect the witness from 

abusive uses of these techniques. 

The witness can also protect the credibility of his or her testimony by 1) answering briefly, 2) 

answering accurately, and 3) remaining calm. Answering briefly consists of being responsive to 

the question, but not volunteering extra information. Avoid rambling, even if the opposing 

counsel remains silent. 

In addition to the recommendations in the section “Giving Testimony,” answering accurately 

requires listening carefully for the following types of questions: 

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Appearing as a Witness Appendix Q 

• Questions that inaccurately paraphrase the witness’s previous testimony. The error 

should be corrected or the previous answer restated in full. 

• Hypothetical questions or questions requiring a “Yes” or “No” answer. If these questions 

may compel a misleading or incomplete answer, the witness should explain the answer 

fully at that time or later during redirect if cut short by the opposing attorney. 

• Two-part questions. The inspector should ask the attorney to restate the question or 

carefully answer each part separately. 

Even when a witness’s truthfulness, occupational competence, or professional conclusions are 

challenged, he or she should remain calm. An angry, sarcastic, or argumentative answer is 

inconsistent with the inspector’s role as a neutral government witness. Remaining calm will add 

credibility to the inspector’s testimony. Becoming familiar with the process, including 

participation in a mock trial can help reduce the stress of cross-examination. 

IV. Special Considerations 

A. Technical Testimony 

An inspector frequently presents technical facts. The inspector must balance the need to be 

technically accurate with the need to reduce scientific issues to simple terms and concepts. 

The first barrier to communicating technical information is the use of jargon. The inspector 

should prepare carefully in order to simplify his or her language without over-simplifying the 

scientific concepts. The inspector should: 

• Speak as clearly as possible. The court reporter may have difficulty recognizing

numbers and unfamiliar technical terms.

• Provide a glossary of technical terms, including acronyms, to the reporter. 

• Review the meaning of frequently used acronyms, such as OECA meaning the Office of 

Enforcement and Compliance Assurance. 

Even after the witness explains the definitions of the technical language, the underlying concepts 

may still be difficult to understand. To teach the necessary technical concepts, the inspector 

and attorney should consider using: 

• Short answers in a logical progression of questions. 

• Slow enough questioning to avoid information overload. 

• Diagrams and pictures. 

• Appropriate analogies. 

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Finally, the inspector should not try to outdo the opposing attorney on technical issues. Not only 

may the inspector confuse the judge or jury in the process, but also a well-prepared attorney will 

have thoroughly studied the subject before trial and will have a large advantage in legal debate. 

To successfully answer questions regarding technical information, an inspector should: 

• Examine questions and answers for assumptions and exceptions. 

• Look for inaccurate paraphrasing of the inspector’s previous testimony. 

• Always identify estimates. 

• Use references in cases of complicated details. For example, the inspection report 

could be consulted before testifying about the characteristics of a specific sample. 

B. Expert Witness 

Expert witnesses give opinions on the record. An expert witness has technical or other 

specialized knowledge that helps the judge or jury better understand the case. In order to prove 

a witness’s expertise, his or her qualifications are introduced by one side and cross-examined 

by the other side. Only those opinions that the witness is qualified to express by virtue of special 

training or expertise will be admissible. 

An expert is not necessarily someone from outside the agency with particular academic or 

research credentials. Due to the inspector’s professional expertise, he or she might be asked 

specific questions that require an opinion or might even be called as an expert witness. The 

EPA attorney will object if the opposing counsel asks inappropriate questions and will decide 

whether to use the inspector as an expert witness. The inspector should stay carefully within his 

or her limits of expertise and knowledge whenever asked a question requiring an opinion. 

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August 2004 Q-8 PCB Inspection Manual 

U.S. EPA Office of Compliance

Compliance Assessment and Media Programs Division 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

August 2004 

EPA-305-X-04-003