PCB Chemical Action Plan 

February 2015

Publication no. 15-07-002
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Publication and Contact Information

This report is available on the Department of Ecology’s website at 

https://fortress.wa.gov/ecy/publications/SummaryPages/1507002.html

For more information contact:

Waste 2 Resources

P.O. Box 47600 

Olympia, WA 98504-7600 

Phone: 360-407-6900

Washington State Department of Ecology - www.ecy.wa.gov

o Headquarters, Olympia 360-407-6000

o Northwest Regional Office, Bellevue 425-649-7000

o Southwest Regional Office, Olympia 360-407-6300

o Central Regional Office, Yakima 509-575-2490

o Eastern Regional Office, Spokane 509-329-3400

If you need this document in a format for the visually impaired, call the Waste 2 Resources 

Program at 360-407-6900. Persons with hearing loss can call 711 for Washington Relay Service.

Persons with a speech disability can call 877-833-6341.
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PCB Chemical Action Plan

by

Washington State Department of Ecology

Olympia, Washington

Holly Davies, Ph.D. Waste 2 Resources Program

Alex Stone, Sc.D. Hazardous Waste and Toxics Reduction Program

Art Johnson Environmental Assessment Program

Dale Norton Environmental Assessment Program

Kasia Patora Rules Unit

Kim Morley Rules Unit

Adriane Borgias Water Quality Program

Cheryl Niemi Water Quality Program

Joshua Grice Waste 2 Resources Program

Gary Palcisko Air Quality Program

Jim White, Ph.D. Toxics Cleanup Program

Damon Delistraty, Ph.D. Hazardous Waste and Toxics Reduction Program

Washington State Department of Health

Olympia, Washington

Barbara Morrissey

David McBride
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Table of Contents

Page

Figures............................................................................................................................................. 6

Tables.............................................................................................................................................. 7

Acknowledgements......................................................................................................................... 9

Summary of Findings.................................................................................................................... 10

PBT Rule and Chemical Action Plans ...................................................................................... 10

PCBs.......................................................................................................................................... 10

Major sources............................................................................................................................ 11

Pathways.................................................................................................................................... 11

Exposure.................................................................................................................................... 12

Toxic effects.............................................................................................................................. 12

Priorities for new actions........................................................................................................... 12

Recommendations for New Actions............................................................................................. 15

Summary of Recommendations................................................................................................ 22

Implementation Steps.................................................................................................................... 23

General Chemical Information ..................................................................................................... 25

Summary ................................................................................................................................... 25

Physical and Chemical Properties of PCBs............................................................................... 26

Historic Manufacturing ............................................................................................................. 32

Analytical Methods................................................................................................................... 34

PCB Uses and Sources.............................................................................................................. 40

Methods of Manufacturing........................................................................................................ 44

Environmental Transformation and Degradation...................................................................... 45

Production, Uses, and Releases .................................................................................................... 48

Closed Legacy Uses.................................................................................................................. 50

Open Uses ................................................................................................................................. 56

Inadvertent generation in new products .................................................................................... 59

Commercial and industrial releases........................................................................................... 64

Summary ................................................................................................................................... 66

Pathways and Environmental Fate................................................................................................ 67

Pathways.................................................................................................................................... 67

Environmental Partitioning ....................................................................................................... 70

Wildlife Health.............................................................................................................................. 73

Introduction ............................................................................................................................... 73

Health effects in wildlife ........................................................................................................... 74

PCBs in Washington’s Environment......................................................................................... 79

Local Hazard Assessments...................................................................................................... 101
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Human Health Effects of PCBs .................................................................................................. 103

Introduction ............................................................................................................................. 103

Historical Episodes of PCB Poisoning.................................................................................... 104

Endpoints of Human Health Concern ..................................................................................... 106

Established Health Guidelines for PCB Mixtures................................................................... 110

PCB Exposures in People........................................................................................................ 114

Sources and Pathways of Human Exposure............................................................................ 117

Existing Washington State Health Advice .............................................................................. 134

Current Regulatory Approaches for PCBs.................................................................................. 138

Federal Laws & Regulations................................................................................................... 138

Washington State Laws and Regulations................................................................................ 148

Select Regulations in Other US Jurisdictions ......................................................................... 153

Select International Regulations.............................................................................................. 153

Economic analysis ...................................................................................................................... 155

Cost Estimates of Various PCB Reduction Methods.............................................................. 155

Economic References.............................................................................................................. 170

References................................................................................................................................... 172

Appendices.................................................................................................................................. 205

Appendix A. List of 209 PCB Congeners (EPA, 2003).......................................................... 205

Appendix B. PCB Mixtures and Trade Names (EPA 2013d)................................................. 211

Appendix C. Distribution of Aroclor mixtures (EPA, 2013d)................................................ 212

Appendix D. Chemical Processes that have the Potential to Generate PCBs......................... 215

Appendix E. Reported Products with Inadvertently Generated PCBs.................................... 217

Appendix F. Washington PCB transformers in EPA database ............................................... 220

Appendix G. Response to Comments
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Figures

Page

Figure 1. PCB Structure................................................................................................................ 25

Figure 2. Chemical abbreviation for benzene ............................................................................... 29

Figure 3. PCB Structure................................................................................................................ 30

Figure 4. Alternate PCB-11 Structure........................................................................................... 30

Figure 5. Location of meta, ortho, and para positions.................................................................. 31

Figure 6. Monsanto Domestic sales of PCBs in the US by use (EPA 1987)................................ 32

Figure 7. PCB Distribution in Aroclor1260 (EPA 2013e)............................................................ 33

Figure 8. Diarylide yellow and PCB-11 (Rodenburg, 2012)........................................................ 43

Figure 9. Hydroxyl photo-degradation pathways for PCBs in air (ATSDR 2000) ...................... 45

Figure 10. Photolysis of PCB-11 .................................................................................................. 46

Figure 11. Pathways for Aerobic Degradation of PCBs (ATSDR 2000) ..................................... 47

Figure 12. Total estimated PCB loading to Puget Sound by pathway (kg/yr).............................. 68

Figure 13: Relative contributions of different land use covers to PCBs in surface runoff in Puget 

Sound (Ecology 2011g) ................................................................................................................ 68

Figure 14. Relative importance of pathways assessed in freshwater systems.............................. 69

Figure 15. Total PCBs in Age-Dated Sediment Cores from Puget Sound, Lake Washington, and 

Lake Spokane................................................................................................................................ 81

Figure 16. Total PCB Concentrations in Marine Mussels from Columbia River to Puget Sound: 

1986 – 2010................................................................................................................................... 82

Figure 17. Historical Decline in PCB Levels among South Puget Sound Harbor Seals: Blubber 

Samples 1972-1991 (Calambokidis, 1999)................................................................................... 83

Figure 18. 20-year Time Series for PCBs in English Sole from Selected Urban and Non-urban 

Locations in Puget Sound ............................................................................................................. 84

Figure 19. a. Category 4 and 5 303 (d) listings (blue dots). b. Waterbody-specific fish 

consumption advisories (blue lines, see section on Human Health). c. Overlap of water quality 

listings and fish consumption advisories. ..................................................................................... 87

Figure 20. Distribution of PCBs in Marine Sediments from Puget Sound to Strait of Georgia... 89

Figure 21. PCBs in Edible Tissues of Four Species of Puget Sound Fish ................................... 90

Figure 22. PCB Spatial Patterns in Herring: British Columbia, Washington, and California...... 91

Figure 23. PCB Spatial Patterns in English Sole Muscle: Puget Sound and Vicinity.................. 92

Figure 24. Average PCB Concentrations in Fish Muscle Samples from Washington Rivers and 

Lakes............................................................................................................................................. 93

Figure 25. PCBs in Blubber of Puget Sound Seal Pups, 2009 (from Ecology 2011i; mean and 

standard error)............................................................................................................................... 95

Figure 26. Figure of 483 PCB cleanup sites in Washington in 2010............................................ 96

Figure 27. Washington Statewide PCB Distribution in Freshwater Fish Fillets 2001-2012. .... 118
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Figure 28. Mean PCB concentrations (total Aroclors) in fish collected from markets and grocery 

stores in Washington State and from Puget Sound. Data Source: McBride et al. 2005. ............ 119

Figure 29. PCB Concentrations (ppb) in Sportcaught Fish Collected in Washington, Commercial 

Fish Purchased in Washington, & Common Foods.................................................................... 127

Tables

Table 1. Summary of sources, reservoirs, releases, exposures and priorities............................... 14

Table 2. Summary of Typical PCB (Aroclor) Physical Characteristics (from ATSDR 2000)..... 27

Table 3. EPA PBT Profiler Estimates of Persistence and Bioaccumulation for Select PCB 

congeners ...................................................................................................................................... 28

Table 4. PCB Homolog Chemical properties (IPCS, 1995) ......................................................... 28

Table 5. Table of location of chlorine atoms................................................................................ 31

Table 6. Table of Aroclors (EPA 2013a)...................................................................................... 33

Table 7. Methods developed to test for PCBs in a wide range of media (NEMI, 2013).............. 35

Table 8. PCBs reported by Method 8082A (EPA 2012a)............................................................. 37

Table 9. Historical Aroclor Uses (from ATSDR 2000)................................................................ 40

Table 10. PCBs congeners found in specific pigments (EPA 1982) ............................................ 41

Table 11. PCB-11 worldwide concentrations from printed materials .......................................... 42

Table 12. Industrial Uses of PCBs (1929-1975) from EPA 1997................................................. 48

Table 13. Examples of legacy uses of PCBs................................................................................. 49

Table 14. PCB transformers in use in Washington....................................................................... 51

Table 15. Release estimate for transformers and capacitors......................................................... 54

Table 16. Lamp ballasts and other small capacitors..................................................................... 55

Table 17. Estimates from caulk .................................................................................................... 58

Table 18. Reports to EPA on inadvertent generation 1994-present.............................................. 61

Table 19. Table of TRI reports from 2007-2011 .......................................................................... 64

Table 20. Summary of Uses and Releases for Washington State ................................................. 66

Table 21. Estimates for the status of PCBs (in metric tons)......................................................... 71

Table 22. Global PCBs from Tanabe 1988 for PCBs on land, rivers and coastal waters............. 71

Table 23. PCB Hazards in Wildlife with references noted in original (ATSDR 2000 Table 3-6)75

Table 24. WHO TEFs for fish and birds (Van den Berg et al. 1998)........................................... 78

Table 25. Water Quality Assessment for PCBs............................................................................ 87

Table 26. PCB clean up sites........................................................................................................ 96

Table 27. PCB-contaminated waste reported under WPCB......................................................... 98

Table 28. PCB-ballasts collected as MRW (2010-2012).............................................................. 98

Table 29. Toxicity Equivalence Factors for PCB Congeners..................................................... 111

Table 30. Established health regulations/guidance for PCBs..................................................... 113
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Table 31. Sum of 35 PCB congeners in 2003-04 NHANES survey (Patterson et al. 2009)...... 115

Table 32. Measured PCB Levels as Reported by U.S.FDA ....................................................... 121

Table 33. Level of PCBs in U.S. Foods (1994 – 2009).............................................................. 124

Table 34. Estimates of Background Dietary Exposure to Dioxins and Coplanar PCBs on a Toxic 

Equivalents (TEQs) Basis........................................................................................................... 125

Table 35. Washington State PCB Fish Advisories ..................................................................... 135

Table 36. Subparts of TSCA....................................................................................................... 139

Table 37. Summary of the costs associated with Recommendation 6........................................ 166

Table 38. Estimated costs to Ecology to implement recommendations ..................................... 168
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Acknowledgements

The authors of this report would like to thank the PCB CAP Advisory Committee for their 

contribution to this study:

• Dianne Barton, Columbia River Inter-Tribal Fish Commission

• Kevin Booth/Bryce Robbert, Avista Utilities

• Patricia Cirone, UW School of Public Health, Dept of Environmental and Occupational Health 

• Jenee Colton, King County DNRP

• Karen Dinehart, Seattle City Light

• Rick Eichstaedt, Center for Justice

• Brandon Houskeeper, Association of Washington Business (AWB)

• Nancy Johns, Office of the Superintendent of Public Instruction

• Ken Johnson, Weyerhaeuser/AWB

• Doug Krapas, Inland Empire Paper Company

• Michelle Mullin, EPA Region 10

• Sandy Phillips, Spokane Regional Health District

• Rosalind Schoof, Environcorp

• Beth Schmoyer, City of Seattle

• Heather Trim, Futurewise

• Laurie Valeriano, Washington Toxics Coalition

• Dirk Wassink, Second Use

• Jim West/Sandie O'Neill, Washington Department of Fish and Wildlife
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Summary of Findings

PBT Rule and Chemical Action Plans

A Chemical Action Plan (CAP) identifies, characterizes, and evaluates uses and releases of 

specific persistent, bioaccumulative and toxic chemicals (PBT) or a group of chemicals and 

recommends actions to protect human health and the environment (173-333 WAC). PBTs are 

considered the “worst of the worst” chemical contaminants because they remain in the 

environment for a long time, and build up within organisms and/or the food chain.

This Polychlorinated Biphenyls (PCBs) CAP estimates releases of PCBs from various sources to 

air, land, and water. It also describes the physical and chemical properties of PCBs and why they 

are considered toxic to humans and other organisms. The recommendations are a set of actions to 

reduce and phase out uses, releases, and exposures in Washington in consideration of current 

management approaches. An economic analysis on the cost of recommendations and the most 

promising options is also included. 

PCBs

From 1929 to 1979 about 600,000 metric tons of PCBs were commercially manufactured in the 

US. The 1976 Toxics Substances Control Act (TSCA) prohibited manufacture, processing, and 

distribution of PCBs. While TSCA is often referred to as a “ban” on PCBs, the law allowed some 

historical uses to continue, and set allowable levels of inadvertent production of PCBs in other 

products. PCBs are also regulated under additional state and federal laws, and they are not 

always consistent. For example, the level of PCBs that is allowed in products under TSCA is 

millions of times higher than what is allowed in water under the Clean Water Act. This leads to 

water permit holders being held responsible at the end of their pipe for PCBs that came from 

other products. Back in the late 70’s the total amount seemed small and the amount allowed in 

each product seemed low, but now we know that it’s high compared to levels that impact human 

health.. 

PCBs are synthetic compounds that consist of 209 possible arrangements (called congeners) of 

chlorines around a biphenyl molecule. PCBs were sold commercially as various mixtures of 

these different arrangements. They are also found in the environment as various mixtures, 

bioaccumulate as complex mixtures, and have been assessed for toxicity largely as mixtures. 

They are largely regulated as total PCBs. As a result, Ecology chose to evaluate available 

information on all PCB compounds. 
11

Major sources 

For the purposes of this CAP, sources are considered to be the original material, such as PCBs in 

transformers. PCBs move through pathways such as stormwater and expose people and wildlife. 

Current PCB levels in Washington State represent both historical uses and ongoing 

manufacturing processes that create PCBs. A large reservoir of past uses of PCBs includes

electrical equipment such as transformers and capacitors, and building materials such as caulk 

and paint. About 75 percent of PCBs produced before 1979 were used in transformers and 

capacitors, including small capacitors in lamp ballasts and appliances. The second largest pre1979 use, about 10 percent, was as plasticizers, including in caulk. 

PCBs are still unintentionally generated by combustion and by different manufacturing 

processes, such as for some pigments and dyes. While there is a lot of recent research on the 

generation of PCBs during production of pigments and dyes, little work has been done to shed 

light on other processes that are likely to generate and release new PCBs. Non-point releases, 

such as from consumer products, are becoming increasingly important to control and reduce 

overall PCB delivery to humans and the environment.

Pathways 

Lower chlorinated congeners are more readily emitted to the air from sources such as old caulk 

and intact lamp ballasts. When lamp ballasts fail or caulk is disturbed, a greater amount of all of 

the congeners are released. Lower chlorinated congeners travel further in air compared to the 

higher chlorinated congeners, and eventually all the congeners are deposited onto surfaces. PCBs 

do not readily dissolve in water and they bind to particles. Particle-bound PCBs can be 

transported through stormwater and end up in sediment. The relative abundance of PCBs in

sediment is seen in Puget Sound where 97 percent of the PCBs are bound to sediment (1440 kg), 

less than three percent are in organisms (40kg), and less than one percent (10 kg) are dissolved in 

water. Under certain conditions, such as in the Spokane River, PCBs are found in the water 

column rather than in sediments. 

Stormwater is the largest delivery pathway to surface waters for PCBs statewide. Loadings from 

water treatment plants and atmospheric deposition are each less than 10 percent of the total, 

although atmospheric deposition is less well studied. There are smaller pathways, such as from 

salmon that accumulate PCBs while in the Pacific Ocean and then return to Washington to 

spawn. While the long-term goal is to prevent PCBs from entering stormwater, it is important to 

continue work on stormwater management, including piloting new technologies. 
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Exposure

Levels of PCBs in the environment are mostly declining, but PCBs are still widespread. Wildlife 

are exposed to PCBs in their diet, along with PCBs in water, soil, and sediments. PCBs 

accumulate in fatty tissues, including in animals eaten for food. PCBs in food are the most 

significant source of exposure for most people, and we are particularly concerned with levels of 

PCBs in fish we eat. People are also exposed to PCBs in air, water, soil, and house dust. Levels 

of PCBs in people have declined since the 1980s, but everyone in the US has detectable levels of 

PCBs in their bodies. PCBs remain in people and animals for different numbers of years, varying 

by type of organism and type of PCB congener. Because PCBs are more readily absorbed than 

excreted, they accumulate in the body over time. 

Toxic effects

PCBs are persistent in the environment, build up in the food chain, and can cause adverse health 

effects in humans and wildlife including cancer and harm to immune, nervous, and reproductive 

systems. PCBs disrupt thyroid hormone levels in animals and humans, hindering growth and 

development.

Priorities for new actions

As shown in Table 1 below, there are a variety of PCB sources with different concerns (each 

estimate is presented in the order it is discussed in the section on Sources, Uses and Releases and 

how each is derived is explained in that section). The table divides sources into those that are a 

legacy of the historic uses before 1979 and those that are currently ongoing. 

We are especially concerned about exposure to children in school buildings with old lamp 

ballasts and other PCB-containing building materials. It is uncertain how many pre-1979 lamp 

ballasts are still in use, but they should be removed both for their potential to expose people to 

PCBs when they fail and because newer lights are more energy efficient. A large reservoir of 

PCBs in old caulk and other building materials is slowly being released into the environment. 

Releases from building materials can be greatly accelerated during remodeling and demolition. 

There is an opportunity, through use of best management practices, to prevent releases of PCBs 

during remodeling and demolition. 

Inadvertent generation of PCBs is a potentially large and important source of uncontained PCBs, 

but little is known about the processes that inadvertently generate PCBs and what products 

contain them. We do know PCBs are created as a byproduct of pigments and dyes, and this

creates a regulatory burden for paper recycling, municipal treatment works, and other dischargers

in Washington. Finding alternative pigments and dyes will reduce PCB releases to the 

environment and alleviate water treatment burdens on business and municipalities. 
13

While about 75 percent of the PCBs produced prior to 1979 were used in electrical equipment, 

most of the transformers and large capacitors that contain PCBs have been identified and 

replaced. The remaining equipment is largely monitored for spills that are cleaned up, further 

reducing the impact to people and the environment. 
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Table 1. Summary of sources, reservoirs, releases, exposures and priorities. 

Source

Legacy 

reservoir

of PCBs

Annual 

releases

of PCBs

(kg/yr)

Potential exposure pathways and 

concerns

Is the 

release 

contained? Priorities

Historic uses

transformers 100-200 kg < 2 Accidental spills, which are identified and 

cleaned up. Yes

large capacitors 20 metric 

tons 10 to 80 Accidental spills, which are identified and cleaned up. Yes

lamp ballasts 100-350 

metric tons

400 to 

1,500

Continual release of lower concentrations, 

with high concentrations released when the 

ballast fails. 

Yes

In school buildings as part 

of energy efficiency 

improvements. 

small capacitors 1-35 metric 

tons 3 to150 Disposal in landfills from a variety of old appliances. 

Yes

other closed uses unknown Yes

caulk 87 metric 

tons 160

Continual release of lower concentrations 

into the air, with high concentrations 

released when materials are disturbed. 

No

Remodeling and 

demolition, especially in 

schools. 

other open uses unknown No

Current generation 

pigments and dyes N/A 0.02 to 31a

Continual release of lower concentrations, 

with higher concentrations released during 

recycling.

No

Identify and promote safer 

alternatives.

other inadvertent 

generation N/A 900 Concerns about both continual releases and potential large releases. No

Identify processes and 

products first and then 

identify and promote safer 

alternatives.

residential waste 

burning N/A 199 Released to air and already addressed by current regulations. No

commercial marine 

vehicles N/A 0.4 Released to air and already addressed by current regulations. No

a. This estimate is for PCB-11, although additional congeners are present. 
15

Recommendations for New Actions

The goal of a CAP is to recommend actions to protect human health and the environment. 

Averting toxic exposures and avoiding future costs is the smartest, cheapest, and healthiest 

approach. The priority recommendations address the largest sources, largest reservoirs, 

uncontrolled sources, protect the most people, or protect especially vulnerable children, in the 

context of existing programs, costs, and available technology. Ongoing permitting, cleanup, and 

other actions are crucial to any efforts on PCBs. The following recommendations are for new 

actions in addition to our existing efforts to reduce PCBs.

The recommendations are based on an evaluation of the following factors associated with 

implementing the action: 1) environmental and human health benefits, 2) economic and social 

impacts, 3) feasibility, 4) availability and effectiveness of safer substitutes, and 5) consistency 

with existing federal and state regulatory requirements.

Historic PCB-Containing Building Materials

1. Identify PCB-containing lamp ballasts in schools and other public buildings. Encourage 

replacement with more energy efficient PCB-free fixtures. 

Goal: Remove remaining PCBs lamp ballasts from schools and other publically owned 

buildings. 

Before 1979 PCBs were widely used in fluorescent lamp ballasts. PCB-containing lamp ballasts 

still in use should be identified and replaced with more energy efficient lighting. These ballasts 

have outlived their useful lives and are at high risk for failing (dripping, smoking, and catching 

fire). Ballast failures can expose children to concentrated PCB oils and elevated PCBs in air. 

Low concentrations of lower chlorinated PCB congeners are continually released from lamp 

ballasts. When ballasts fail, high concentrations of a broader spectrum of congeners are released, 

so it is important to find and remove the lamp ballasts before they fail. 

There is no easily accessible source of information on how many of our approximately 9,000 

school buildings are of the age and construction type likely to have PCB-containing lamp 

ballasts. The first step is to conduct a survey on schools (and other public buildings as time and 

resources allow) to identify buildings most likely to contain PCBs based on age, type of 

construction and scope of any past remodeling. This data will be used to identify those buildings 

where PCB-containing light ballasts are likely still in use. Lamp ballasts with PCBs can then be 

identified through visual inspection. 

Public money should be used to remove PCB-containing lamp ballasts from schools and other 

public buildings. Since 2009, the legislature has provided money to the Office of the 

Superintendent of Public Instruction (OSPI) and the Department of Commerce to support energy 
16

efficiency measures in schools and other public buildings. It makes sense to combine PCB 

removal with increasing energy efficiency rather than create a new program just for removal of 

PCB-containing ballasts. If the grant programs are not funded, the legislature should establish a 

fund to help offset the costs of replacing PCB-containing lamp ballasts. Schools with PCBcontaining lamp ballasts will be provided with information about the importance of removing 

these ballasts and referred to OSPI (or Washington State Department of Health and other 

available resources) to replace these fixtures with more energy-efficient lighting. Environmental 

justice will also be considered in setting priorities for removing PCB-containing lamp ballasts. 

2. Develop and promote Best Management Practices (BMPs) to contain of PCBs in building

materials currently in use and those slated for remodel or demolition. 

Goal: Reduce exposure to people from PCBs in historic building materials and prevent 

PCBs in building materials from getting into stormwater. 

Ecology should work to prevent PCBs currently in building materials from being released into 

the environment.Historically, PCBs were used at high levels in some caulks and paints. Studies 

in other areas have shown the widespread occurrence of PCB-containing caulk in buildings from 

about 1950-1980, especially masonry buildings, and smaller sampling efforts in Washington 

support this conclusion. There is some information about PCB-containing building materials in 

the Duwamish basin and other information from source tracing, such as PCBs in sidewalk and 

building caulk in Tacoma. 

Based on available data in Washington, other government programs, and the scientific literature, 

Ecology would develop BMPs for containing PCBs to prevent exposure during the life of the 

building and during remodeling or demolition. Lower concentrations of lower chlorinated 

congeners are continually released from caulk and paint, with higher concentrations of a broader 

spectrum of congeners released when the materials are disturbed. Ecology should also provide 

education and outreach on BMPs to local governments and those in the building trades. 

While Ecology is working on BMPs, it should also support assembling existing information into 

a PCB Source Control Guidance Manual that can aid Local Source Control work to identify and 

control sources of PCBs. PCB source identification work has been performed by a number of 

urban waters programs around the Northwest. To date, the lessons learned from each of these 

programs has not been synthesized and summarized for the benefit of future pollution prevention 

efforts at the state and local level
17

3. Assess schools and other public buildings for the presence of PCB-containing building 

materials. 

Goal: Reduce children’s exposure to PCB-containing building materials in schools.

Goal: Prevent PCBs in building materials from getting into stormwater.

Many historical building materials, such as caulk and paint, have been found to contain high 

levels of PCBs. These materials are more common in industrial buildings, including schools, 

compared to residential buildings. It makes sense to focus on schools for testing and remediating 

these materials, as children are more sensitive to PCBs and the buildings are usually publically 

owned. Washington has not tested schools for PCBs, but other states have found high levels of 

PCB contamination in schools. 

The first step in Recommendation #1 is to get information on how many of our approximately 

9,000 school buildings are of the age and construction type likely to have PCB-containing 

materials. The information would be used to prioritize schools for testing, pending the 

availability of funding to either contain or remediate PCBs that pose a risk for children and 

teachers. A similar approach should be used to assess other public buildings once the assessment 

and remediation of schools is complete. 

Ecology would initially focus on determining how many schools are likely to contain PCBs in 

historic building materials, narrow that list with visual inspections and then physical testing to 

determine the scope of the problem in Washington. This will determine how much time and 

money will be required for remediation and allow for long term planning, including funding. As 

Ecology learns more about PCB-containing building materials in Washington schools and other 

buildings, that information will be used to improve efforts to locate and remediate buildings. 

Environmental justice will also be considered in setting priorities for removing PCB-containing 

building materials.

Current Manufacturing Processes

4. Learn more about what products contain PCBs and promote the use of processes that 

don’t inadvertently generate PCBs. 

Goal: Reduce newly generated PCBs in manufacturing processes. 

In 1982, the Environmental Protection Agency (EPA) identified 70 manufacturing processes 

likely to inadvertently generate PCBs. Little is known about most of this potentially large source 

of uncontained PCBs, including which congeners are produced. More information is known 

about PCBs in pigments and dyes, which are known to be released into the environment in 

stormwater, effluents from municipal treatment works, and effluents from pulp mills re-pulping 

post-consumer paper. Unpermitted non-point releases, such as from consumer products, are 

becoming increasingly important to control to reduce overall PCB delivery. Ecology should 
18

work with EPA, manufacturers, the Northwest Green Chemistry Center, and other partners to 

identify products likely to contain PCBs, including a workshop focused on bringing together the 

supply chain to look for solutions to the current PCBs in products issue.

Ecology should test identified products and give that information to the Department of Enterprise 

Services (DES) to assist them in implementing new purchasing policies (RCW 39.26.280) that 

provide a preference for products that do not contain PCBs. Government purchasing of nonPCB-containing products is an effective way to both identify products that don’t contain PCBs 

and encourage suppliers to remove PCBs from their products. Once products are identified that

contain fewer PCBs, the information will be available shared with other purchasers, such as by 

schools, cities and residents. Ecology should support other government and business entities that 

adopt similar purchasing policies to drive the market-demand for PCB-free products. 

Ecology, the Washington State Department of Health (DOH), and DES should work together to 

educate purchasers and vendors in the state supply chain by developing a focus sheet that 

concisely outlines the problem and its potential impacts on compliance with water quality 

standards, as well as impacts on people and the ecosystem. 

Ecology should begin with directing an alternatives assessment for pigments and dyes, based on 

the Interstate Chemicals Clearinghouse (IC2) Alternatives Assessment Guide. Businesses and 

other concerned stakeholders would be asked to participate in the alternatives assessment 

process. If there are currently no alternatives that do not generate PCBs, Northwest Green 

Chemistry should work to develop alternative processes. 

In addition to investigating which products contain inadvertently generated PCBs and finding 

safer alternatives, Ecology and DOH should petition the federal government to reform current 

regulations under the Toxics Substances Control Act (TSCA). TSCA generally allow a maximum 

of 50 ppm of inadvertently generated PCBs in most products, while Washington standards under 

the Clean Water Act (CWA) to protect human health that allow only 0.00000017 ppm (170 ppq 

or parts per quadrillion) PCBs in water bodies. The TSCA allowance is over 294 million times 

greater than the CWA criteria for human health and it is suspected that the TSCA allowance is 

likely a pathway for new PCBs to enter the environment, resulting in a paradox between these 

regulatory structures that must be resolved. The lower CWA standards are based on protecting 

human health and what we know about the health effects of PCBs. The higher allowable level of 

PCBs in products leads to higher levels of PCBs in water, and the responsibility of PCB levels in 

water are borne by downstream permittees that are not generating PCBs. Allowable levels of 

newly generated PCBs in products must be lowered by the federal government in order to meet 

water quality standards to protect human health and the environment. 
19

Historic Electrical Equipment

5. Survey owners of historic electrical equipment, including transformers and large 

capacitors.

Goal: Confirm estimates of EPA-regulated electrical equipment with more than 500 parts 

per million (ppm) PCBs, learn what is known about electrical equipment with PCBs 

greater than 2ppm, and find out when such electrical equipment is estimated to be 

replaced. 

Before 1979, the majority of PCBs were produced for use in electrical equipment. Major 

industries and electrical utilities indicate that they have either already removed these potential 

sources or have plans to do so. Ecology should survey the state’s 61 utilities and other owners of 

electrical equipment to confirm that this is the case and provide technical assistance for proper 

replacement and disposal. 

Federal regulations focused on transformers with more than 500 ppm PCBs. According to 

industry, many of these transformers and other electrical equipment have already been disposed 

of, but we do not have updated inventories of this equipment to reflect this progress and target 

technical assistance to remaining equipment. To avoid spills or other unexpected releases, the 

users should know which pieces of equipment have PCBs and have a plan to remove all such 

pre-1979 equipment from service or an estimate on when they will be replaced during regular 

maintenance. This inventory would not include small capacitors. This survey would not require 

additional testing or disposal of equipment by a certain date. Owners would be asked what they 

know about detectable levels of PCBs in their equipment, using the industry standard detection 

level (currently 2 ppm) and when they expect all the equipment to be replaced based on their 

current maintenance practices. A statewide inventory will allow the state to confirm current 

inventories and target efforts to prevent releases of PCBs from this equipment. Ecology should 

also work with EPA to update EPA’s 1998 inventory and more accurately reflect the PCB 

transformers that are no longer in use. 

PCB concentrations in many pieces of electrical equipment are high compared to other sources, 

so relatively rare leaks and spills can release a significant amount of PCBs into the environment. 

While PCB spills from electrical equipment are cleaned up, there are some spills where PCBs 

enter the waterways before being cleaned up, such as from transformers that are located close to 

storm drains or water bodies.

Ecology should also investigate the possibility of providing state financial assistance to 

businesses, state agencies, cities, municipalities, and schools to accelerate this process of 

collecting and properly disposing of equipment with concentrated PCBs. 
20

Multi-Source

6. Expand environmental monitoring to identify any new areas requiring cleanup and 

investigate air deposition. 

Goal: Find areas with highly concentrated PCBs and clean them up to prevent the wider 

release of PCBs. 

Goal: Find about more about distribution of PCBs in the state to prioritize future actions. 

Ecology should expand environmental monitoring of water, fish tissue, and sediment to identify 

PCB hot spots. For example levels of PCBs in fish were high enough to prompt Oregon and 

Washington to issue a joint consumption advisory for select species from Bonneville Dam 

upstream to McNary Dam. This led to the discovery of an historical landfill of electrical 

equipment on Bradford Island near Bonneville Dam on the Columbia River. This site is currently 

a federal Superfund site. A number of fish sampling efforts in the Columbia basin (CRITFC, 

Hanford Corridor Study and Ecology’s Freshwater Fish Contaminant Monitoring Program) 

found other areas (mid-Columbia and Snake River) with elevated levels of PCBs and a number 

of hydroelectric facilities. To our knowledge, no work has been done to identify sources of 

contaminants in these areas. The proposed monitoring would conduct sampling to determine if 

contaminant sources exist in areas with a focus on hydroelectric facilities. Mapping and 

prioritization of historical information on the location of potential sites, such as landfills, 

industrial sites, railroad switching yards, etc., should also be used to find potential sites. Newly 

identified sites would be prioritized for cleanup using existing procedures. 

In addition to identifying new hot spots, Ecology should continue its trend monitoring to show 

changes in PCBs in the environment and organisms over time. 

Air deposition is a potentially significant pathway for PCBs to move into the environment. 

Ecology should investigate monitoring air deposition to assess the relative importance of this 

pathway. 

7. Conduct a public educational campaign. 

Goal: Provide information to residents about ways they can minimize exposure. 

Goal: Raise awareness of the problems associated with current and past production of 

PCBs.

Goal: Educate residents to identify and addresses possible household sources of PCBs. 

Ecology and DOH should work together with local entities to help residents, people who fish, 

schools, local governments, and businesses understand the risks associated with PCB exposure 

and ways to reduce risks, including the availability of safer alternatives. 

The public educational campaign will include perspectives on public health risks and information 

on where exposures to PCB are most likely. It will also include advice on how individuals can 
21

minimize their own exposures to PCBs. The campaign will include where to look for potential 

sources of PCBs in households, such as in old appliances, electrical equipment, and building 

materials. It will also teach the public how to safely remove and dispose of these materials to 

prevent PCB releases. 

8. Conduct a study on which PCB congeners are present in Washington residents. 

Goal: Learn more about PCB congeners to which Washington residents are exposed. 

Goal: Find out more about the distribution of PCBs in Washington to prioritize future 

actions. 

Within available resources, DOH should conduct biomonitoring of Washington residents for 

PCBs including PCB-11 and other inadvertently produced PCBs associated with dyes, pigments, 

and printing inks. This would be in tandem with learning more about what other processes 

produce certain PCB congeners. Use the data to better understand 1) the extent of total human 

exposure from multiple potential pathways and 2) the relative contribution of these congeners to 

human body burden of PCBs. In addition, use the data to estimate the statewide distribution of 

PCBs in Washington residents. This will provide a better baseline than national data, given the 

elevated levels of PCBs in local fish populations and relatively high fish consumption in a 

number of Washington communities and regions.
22

Summary of Recommendations 

1. Identify PCB-containing lamp ballasts in schools and other public buildings. Encourage 

replacement with more energy efficient PCB-free fixtures.

2. Develop and promote Best Management Practices (BMPs) to contain PCBs in building

materials currently in use and those slated for remodel or demolition.

3. Assess schools and other public buildings for the presence of PCB-containing building 

materials.

4. Learn more about what products contain PCBs and promote the use of processes that don’t 

inadvertently generate PCBs. 

5. Survey owners of historic electrical equipment, including transformers and large capacitors.

6. Expand environmental monitoring to identify any new areas requiring cleanup and 

investigate air deposition. 

7. Conduct a public educational campaign.

8. Conduct a study on which PCB congeners are present in Washington residents. 
23

Implementation Steps

The recommendations outline a set of first steps in a long-term plan to reduce PCB releases and 

exposures. Due to the magnitude and diversity PCB sources, many of the approaches will take 

significant commitments of time and money to implement effectively. In addition, Ecology and 

DOH can support other agencies, but it is up to the other agencies to carry out some of the 

recommendations. 

Ecology focuses on prevention, which is the smartest, cheapest, and healthiest approach to 

reducing PBTs. Our priority is actions that result in the biggest reduction in exposure to the most 

sensitive receptors. However, sometimes other opportunities to reduce PCBs may arise and it 

makes sense to reduce all sources of PCBs where possible. 

Ecology will continue our existing programs on PCBs to the environment, such as cleanup, 

stormwater management, and permits. DOH will also continue their existing programs, including 

fish advisories and working with residents to reduce their exposures. Expanding or increasing 

programs will require additional funds. Ecology and DOH will work on acquiring additional 

funds, but cannot predict when we will be able to obtain them. 

Ecology and DOH will seek resources to implement the following recommendations in:

FY16-17

Recommendation 1. Survey and assess PCB-containing lamp ballasts in schools and other 

public buildings. Encourage replacement with more energy efficient PCB-free fixtures.

Recommendation 2. Develop and promote Best Management Practices (BMPs) for containment 

of PCB-containing materials in buildings currently in use and those slated for demolition.

Recommendation 4. Learn more about what products contain PCBs and promote the use of 

processes that don’t inadvertently generate PCBs. This will begin with an alternatives assessment 

on PCBs in pigments. Use this information to continue to request reforms of PCB regulations 

under TSCA.

Recommendation 5. Survey owners of historic electrical equipment.

Recommendation 6. Expand environmental monitoring to identify any new areas requiring 

cleanup. 

Recommendation 7. Collaborate with DOH to conduct an educational campaign. 
24

FY18 -21

Recommendation 3. Assess schools and other public buildings for the presence of PCBcontaining building materials. This work will start once school buildings have been surveyed 

(Recommendation 1) and the BMPs have been developed (Recommendation 2).

Recommendation 4. Learn more about what products contain PCBs and promote the use of 

processes that don’t inadvertently generate PCBs. Ongoing work will focus on determining other 

processes that inadvertently generate PCBs and alternatives that do not generate PCBs. Ongoing 

work to support reforms of PCB regulations under TSCA.

Recommendation 6. Expand environmental monitoring to identify any new areas requiring 

cleanup. This project is expected to be finished in FY18. 

Recommendation 7. Conduct an educational campaign. This education and outreach will be 

ongoing past FY17. 

Recommendation 8: DOH will seek resources to design and conduct biomonitoring. 
25

General Chemical Information

Summary

3 2

4

5 6

2'

6' 5'

4'

3'

1 1'

Figure 1. PCB Structure

Polychlorinated biphenyls (PCB) are a family of man-made chemicals consisting of two benzene 

rings joined together and containing one to 10 chlorine atoms attached to the benzene rings.

There are 209 possible combinations of chlorine positions, called congeners. Depending upon the 

amount of chlorine present, PCBs appear as oily liquids to white crystalline solids and hard noncrystalline resins (HSDB, 2013). PCBs are hydrophobic and bind to particles. Due to their nonflammability, chemical stability, high boiling point and electrical insulating properties, PCBs 

were used in hundreds of industrial and commercial applications including electrical, heat 

transfer and hydraulic equipment; as plasticizers in paints, plastics, and rubber products; in 

pigments, dyes, and carbonless copy paper; and many other industrial applications (EPA 2013a). 

From 1929 to 1979, 700,000 tons (or 1.4 billion lbs or 600,000 metric tons) of PCBs were 

commercially manufactured in the US (EPA 1997a). Most of the PCBs in the US were 

manufactured by Monsanto, which continued manufacture in the US until 1979 when US 

production stopped. PCBs were not typically manufactured as individual congeners but as 

mixtures called Aroclors. Individual Aroclor mixtures were manufactured using specific 

chemical processes imparting varying chemical characteristics such as vapor pressure, solubility, 

viscosity, amount of chlorination, etc. that produced a unique distribution of congeners in the

different Aroclor mixtures. (HSDB, 2013) Much of the research and discussion on PCBs is 

centered upon the specific Aroclor mixtures. The 1976 Toxic Substances Control Act (TSCA) 

prohibited manufacture, processing, and distribution of PCBs. Some legacy uses of PCBs were 

allowed to continue. 

PCBs are identified as persistent, bioaccumulative and toxic (PBT). Because of their persistence, 

PCBs continue to be found in the environment and contamination from legacy sources remains a 

problem. In addition, PCBs are not prohibited in some products at concentrations below 50 ppm.

PCB concentrations of less than 50 ppm are considered to be “PCB-free.” Recent evidence has 

also indicated that PCBs may be found as contaminants in a wide range of consumer products 

because of the presence in several pigments and dyes (Hu et al. 2010, Rodenburg et al. 2010)
26

Physical and Chemical Properties of PCBs

A summary of typical characteristics for PCBs can be found in Table 2 (ATSDR 2000).

In general, PCB compounds range from heavy oily liquids to sticky resins, or melting crystalline 

solids depending upon the amount of chlorine present. These man-made compounds are odorless, 

colorless to light yellow or amber, and very stable and have relatively low volatility at ambient 

temperatures. PCBs were attractive in many applications because they resist breakdown at high 

temperatures or from aging, or oxidation. They persist in the environment since they do not 

easily biodegrade. PCBs are hydrophobic and thus do not dissolve well in water. As hydrophobic 

and very stable compounds, PCBs may volatilize from water despite their low vapor pressure. 

PCBs also easily adsorb onto organic particles in soils, sediments, biological systems, or water. 

(Panero et al. 2005) These organic particles can be transported long distances and has been 

shown as one of the reasons PCBs are distributed throughout the planet including remote areas.

Washington State’s PBT Rule (WAC 173-333) defines persistence, bioaccumulation, and 

toxicity:

• The criterion for persistence is the half-life (the time it takes for half of the chemical to 

breakdown) of the chemical in water, soil, or sediment is greater than or equal to 60 days. 

• The criterion for bioaccumulation is either:

o The bioconcentration factor (BCF) or bioaccumulation factor (BAF) in aquatic species 

for the chemical is greater than 1,000.

o In the absence of such data, the log-octanol water partition coefficient (log Kow) is greater 

than five. 

• In order for a chemical to be considered toxic, it must meet at least one of the following 

criteria: 

o Be a carcinogen, a developmental or reproductive toxicant, or a neurotoxicant.

o Have a reference dose or equivalent toxicity measure less than 0.003 mg/kg/day.

o Have a chronic no-observed-effect concentration (NOEC) or equivalent toxicity measure 

less than 0.1 mg/L or an acute NOEC or equivalent toxicity measure less than 1.0 mg/L. 

Many but not all PCB congeners are persistent and bioaccumulative as defined in Washington’s 

PBT Rule. Table 2 demonstrates persistence and bioaccumulation for a series of PCBs, one from 

each of the ten homolog groups as predicted by EPA’s PBT Profiler (EPA 2012b). PCBs are 

often grouped by the total number of chlorine atoms and a group with the same number of 

chlorines is called a homolog. Washington’s PBT characteristics are included in the bottom of 

the table (WAC 173-333). Table 4 (IPCS 1995) provides ranges of characteristics for congener 

groups and also includes Washington’s PBT characteristics on the bottom of the table.
27

Although the information in Table 2 is modeled data, which should not be confused with 

analytical results, the PBT Profiler results do demonstrate some trends. In general, persistence as

indicated by the half-lives increases as the number of chlorine atoms increase. The tendency to 

bioaccumulate increases until the molecular structure of the PCB becomes large enough that the 

amount of bioaccumulation plateaus and begins to decrease. This plateauing is a direct result of 

the size of the PCB molecule, which can restrict transport through cell walls. Although all PCBs 

shown meet Ecology’s persistence criterion, some of the mono-substituted may have sufficiently 

low bioaccumulation factors (BCF) that they may not meet Ecology’s PBT criteria. 

Table 2. Summary of Typical PCB (Aroclor) Physical Characteristics (from ATSDR 2000)

Property Aroclor 1254 Aroclor 1260 Aroclor 1262 Aroclor 1268

Molecular weight 328 357.7 389 453

Color Light yellow Light yellow No data Clear

Physical state Viscous liquid Sticky resin No data Viscous liquid

Melting point, oC No data No data No data No data

Boiling point, oC 365 - 390 385 - 420 390 - 425 435 - 450

Density, g/cm3, 25 oC 1.54 1.62 1.64 1.81

Odor Mild hydrocarbon No data No data No data

Solubility:

Water, mg/L 0.012, 0.57

(24oC)

0.0027, 0.08 

(24oC) 0.052 (24o

C) 0.300 (24oC)

Organic solvent(s) Very soluble Very soluble No data Soluble

Partition coefficients:

Log Kow 6.5 6.8 No data No data

Vapor pressure, mm 

Hg at 25 oC 7.71x10-5 4.05x10-5 No data No data

Henry's law constant, 

atm-m3/mol at 25 oC 2.0x10-3 4.6x10-3 No data No data

Flashpoint, oC

(Cleveland open cup) No data No data 195 o

C 195 oC

Flammability limits, oC None to boiling pt None to boiling pt None to boiling pt None to boiling pt

Conversion factors

Air (25 oC) 1 mg/m3

= 0.075 

ppm

1 mg/m3= 0.065 

ppm

1 mg/m3= 0.061 

ppm

1 mg/m3=0.052 

ppm
28

Table 3. EPA PBT Profiler Estimates of Persistence and Bioaccumulation for Select PCB 

congeners

PCB Congener 

number CAS

Half-Life (days) BCF1

Water Soil Sed. Air

4-Chlorobiphenyl PCB-3 2051-62-9 38 75 340 4.2 510

3,3’-Dichlorobiphenyl PCB-11 2050-67-1 38 75 340 3.9 5,400

2,3,4’-Trichlorobiphenyl PCB-22 38444-85-8 60 120 540 15 6,700

2,3’,5,5’-Tetrachlorobiphenyl PCB-72 41464-42-0 180 360 1,600 13 27,000

2,2’,4,4’5-Pentachlorobiphenyl PCB-99 38380-01-7 180 360 1,600 13 40,000

2,3,3’,4,4’,5-Hexachlorobiphenyl PCB-156 38380-08-4 180 360 1,600 75 26,000

2,3,3’,4,4’,5,6’-Heptachlorobiphenyl PCB-190 41411-64-7 180 360 1,600 130 12,000

2,2’,3,3’,4’,5,5’,6’-Octachlorobiphenyl PCB-199 52663-75-9 180 360 1,600 290 5,900

2,2’,3,3’,4,4’,5,6,6’-Nonachlorobiphenyl PCB-207 52663-79-3 180 360 1600 370 2,900

Decachlorobiphenyl PCB-209 2051-24-3 180 360 1,600 880 12,000

WA PBT Characteristics > 60 > 60 > 60 >1,000

BCF = Bioconcentration Factor; half-life = the amount of time it takes for the 

concentration of a chemical to diminish to half its original value; N/A = Not Applicable

Table 4. PCB Homolog Chemical properties (IPCS, 1995)

Congener Group CASRN Molecular weight 

(g/molecular)

Vapour 

Pressure (Pa)

Water Solubility 

(g/m3) log KOW

Monochlorobiphenyl 27323-18-8 188.7 0.9-2.5 1.21-5.5 4.3-4.6

Dichlorobiphenyl 25512-42-9 223.1 0.008-0.60 0.06-2.0 4.9-5.3

Trichlorobiphenyl 25323-68-6 257.5 0.003-0.22 0.015-0.4 5.5-5.9

Tetrachlorobiphenyl 26914-33-0 292.0 0.002 0.0043-0.010 5.6-6.5

Pentachlorobiphenyl 25429-29-2 326.4 0.0023-0.051 0.004-0.02 6.2-6.5

Hexacholorbiphenyl 26601-64-9 360.9 0.0007-0.012 0.0004-0.0007 6.7-7.3

Heptachlorobiphenyl 28655-71-2 395.3 0.00025 0.000045-0.000 6.7-7

Octachlorobiphenyl 55722-26-4 429.8 0.0006 0.0002-0.0003 7.1

Nonachlorobiphenyl 53742-07-7 464.2 - 0.00018-0.0012 7.2-8.16

Decachlorobiphenyl 2051-24-3 498.7 0.00003 0.000001-0.000 8.26

WA PBT Criterion >5

log Kow = natural log of the octanol/water coefficient

 1 EPA’s PBT Profiler defines the bioconcentration factor (BCF) as ‘... a measure of the ability for a water-borne 

chemical substance to concentrate in fatty tissue of fish and aquatic organisms relative to its surroundings. EPA 

defines bioconcentration as the net accumulation of a substance by an aquatic organism as a result of uptake 

directly from the ambient water through gill membranes or other external body surfaces (60 FR 15366).’
29

Stability of Ring Structure and Carbon to Halogen Bond

The chemistry and related stability of ring compounds was discussed extensively in the 

Polycyclic Aromatic Hydrocarbon (PAH) Chemical Action Plan (CAP) (Ecology, 2012a).

Benzene (cyclohexa-1,3,5-triene) 2 is cyclohexane with three double bonds equally spaced 

throughout the molecule. Unlike compounds where the electrons forming the double bonds are 

localized around specific carbon atoms, the electrons in benzene’s double bonds are equally 

shared among all six-carbon atoms. This is a defining characteristic of aromatic compounds. 

Benzene is typically represented by chemists as a six-carbon ring with a circle inside to represent 

the sharing of all electrons equally among the carbon atoms (Figure 2):

Figure 2. Chemical abbreviation for benzene

The most common theory currently accepted by chemists is that this sharing of electrons 

accounts for the thermodynamic stability of benzene and other aromatic compounds. Other 

theories have been promulgated (Cooper et al., 1986) but are not currently widely accepted.

Regardless, the increased stability of benzene and benzene-based compounds like PCBs can be 

attributed to the unique ringed structure and sharing of electrons throughout the molecule.

PCBs have another feature that contributes greatly to their stability. Carbon and chlorine form a 

very strong bond and the amount of energy needed to break apart the bond is higher than most 

other covalent bonds. The strength of this bond greatly increases the ability of PCBs to persist in 

the environment. Persistence is also related to the number of chlorine atoms with increasing 

degree of persistence with increasing chlorine mass. Comparatively, the mono- and dichlorobiphenyls are less persistent than the larger congeners; however, all PCBs meet the 

definition of persistence (see Table 3 for examples).

Naming of PCB congeners

PCBs have a variable structure with two benzene rings joined together. Each benzene ring can 

have one to five chlorine atoms attached. The number and location of the chlorine atoms attached 

to the biphenyl ring determine the physical properties and characteristics of the PCB congener.

 2 The formal name for benzene describes a cyclical compound (cyclo) with six carbons (hexa) and three (tri) double 

bonds (ene). The ‘1,3,5’ indicates which carbon atoms contain the double bond. Given the structure, the double 

bonds are represented as between the carbons 1 & 2, 3 & 4 and 5 & 6, although in reality the electrons are equally 

shared with all of the carbons on the ring.
30

The position of the chlorine atoms are differentiated by using 2 through 6 for one benzene atom 

and 2’ (two prime) through 6’ (six prime) for chlorine atoms on the second benzene ring. The 

naming convention assumes that the two benzene molecules are joined together at the 1 and 1’ 

position. See Figure 3 for the carbon numbering. 

3 2

4

5 6

2'

6' 5'

4'

3'

1 1'

Figure 3. PCB Structure

This naming convention allows chemists to identify the structure of specific PCB congeners. For 

example, PCB-11 (3,3’-dichloro-1,1’-biphenyl or 3,3’-dichlorobiphenyl) contains two chlorine 

atoms in the 3 and 3’ position. Unless indicated otherwise, a hydrogen atom is located on the 

benzene ring in all the unmarked locations.

Because it is possible for the PCB-11 molecule to rotate around the 1-1’ carbon bond, there is no 

chemical difference between the above structure and 3,5’-dichlorobiphenyl (Figure 4).

Figure 4. Alternate PCB-11 Structure

Several additional names potentially exist for PCB-11 including 5,3’-dichlorobiphenyl and 5,5’-

dichlorobiphenyl. To prevent confusion, the naming convention uses the lowest numbers for 

these equivalent structures leading to PCB-11 being identified as 3,3’-dichlorobiphenyl. The 

naming convention can lead to confusion if an incorrect name is used.

3

5'

Cl

Cl
31

Planar and non-planar PCBs

The issue of rotation can also have an impact on the relative toxicity of the PCB congeners. PCB 

congeners can either exist as planar where the two benzene rings are in the same plane or nonplanar where the benzene rings are at 90 degree angle from each other.(ATSDR 2000). Planar 

and non-planar PCBs can have very different toxicity and this issue will be an important 

consideration in the relative toxicity of the PCB congeners discussed in subsequent sections.

A further naming convention using the terms ortho, meta and para are also used to identify the 

position of the chlorine atoms in a PCB molecule. If a chlorine atom is attached to the carbons 

adjacent to the 1 to 1’ bond between the two benzene molecules (positions 2, 2’, 6 or 6’), the 

chlorine atoms are said to be in the meta position. If the chlorine atom is attached to positions 3, 

3’, 5 or 5’, they are in the ortho position. If they are attached to the 4 or 4’ position, they are in 

the para position. Table 5 and Figure 5 indicate the position of the chlorine atoms in a PCB 

congener using the three naming conventions:

Table 5. Table of location of chlorine atoms

Name Carbon atom location

Meta 3,3’,5,5’

Ortho 2,2,6,6’

Para 4,4’

Figure 5. Location of meta, ortho, and para positions

The location of chlorine atoms plays an important role in the decomposition and toxicity of 

specific PCB congeners. Degradation reactions, for example, may selectively remove chlorine 

atoms from specific locations while PCB molecules with specific arrangements of chlorine atoms 

may have greater toxicity than related congeners.

Using the base structure (Figure 3), 209 different and unique PCBs (also known as congeners) 

can exist depending upon the number and position of chlorines involved. A list of these 209 

congeners (EPA 2003) can be found in Appendix A. In addition to specific congeners, PCBs are 

also often grouped by the total number of chlorine atoms also called homologs (Table 4).
32

Historic Manufacturing 

Historically, PCBs were not manufactured as specific congeners or homologs but as mixtures.

Globally there was a wide range of product names for PCB mixtures (Appendix B). There were 

nine major mixtures in the US called Aroclors (Table 6). Prior to 1971, the Monsanto Chemical 

Company produced Aroclors 1016, 1221, 1232, 1242, 1248, 1254, 1260, 1262, and 1268. 

(ATSDR 2000). Figure 6 shows the amounts and uses of PCBs produced in the US between 

1957 and 1971. (EPA 1987). Most Aroclor mixtures are named utilizing a code. Most begin with 

a 12 and the last two digits indicate the percentage amount of chlorine in the mixture. Therefore 

Aroclor 1254 contained 54% chlorine by weight, Aroclor 1216 contained 16% chlorine, etc. The 

only major Aroclor mixture that deviates from this system is 1016.

In 1971, Monsanto voluntarily restricted the uses of PCBs and subsequently produced only 

Aroclor 1016, 1242, 1254, and small quantities of Aroclor 1221. In 1974, the Monsanto 

Chemical Company produced slightly more than 40 million pounds (18 million kg) of Aroclor 

mixtures. Of the total volume of Aroclors sold in the United States for that year, the percentages 

of the market for each of the Aroclors were: Aroclor 1016, 64%; Aroclor 1242, 17.9%; Aroclor 

1254, 17.9%; and Aroclor 1221, 0.1%. The estimated, cumulative production and consumption 

volumes (in millions of pounds) of PCBs in the United States from 1930 to 1975 were: total 

production, 1,400 (635 million kg); imports, 3 (1.4 million kg); domestic sales, 1,253 (568 

million kg); and exports, 150 (68 million kg) (ATSDR 2000).

Figure 6. Monsanto Domestic sales of PCBs in the US by use (EPA 1987)
33

Table 6. Table of Aroclors (EPA 2013a)

CASRN IUPAC Name

12674-11-2 Aroclor 1016

147601-87-4 Aroclor 1210

151820-27-8 Aroclor 1216

11104-28-2 Aroclor 1221

37234-40-5 Aroclor 1231

11141-16-5 Aroclor 1232

71328-89-7 Aroclor 1240

53469-21-9 Aroclor 1242

12672-29-6 Aroclor 1248

165245-51-2 Aroclor 1250

89577-78-6 Aroclor 1252

11097-69-1 Aroclor 1254

11096-82-5 Aroclor 1260

37324-23-5 Aroclor 1262

11100-14-4 Aroclor 1268

12767-79-2 Aroclor (unspecified)

These Aroclor mixtures can be fingerprinted depending upon the distribution of specific PCB 

congeners as indicated below (Figure 7) for the Aroclor 1260 mixture.

Figure 7. PCB Distribution in Aroclor1260 (EPA 2013e)
34

Additional fingerprints of common Aroclor mixtures can be found in Appendix C. Fingerprinting 

is an analytical technique that shows a distinct distribution of chemicals. Each Aroclor mixture 

has an identifiable distribution of PCB congeners. Aroclor fingerprinting is important as it can 

point toward potential PCB sources when contamination has been found in the environment.

However, due to differential uptake by organisms, differential volatilization, and differential 

degradation, the congeners present in weathered mixtures in the environment will be different 

than the original congeners present in the Aroclors.

Analytical Methods

Because of their impact upon human health and the environment, considerable data exists on the 

presence of PCBs in a wide range of media. Historically, analytical methods were developed 

based upon the Aroclor fingerprints or values for total PCB concentrations. Recently, more 

sensitive and detailed congener-specific analyses have been developed to enable more detailed 

study of PCBs in the environment. PCBs are regulated under the Toxics Substances Control Act 

(TSCA), other Federal regulations (EPA 2013f) and state regulations such as Washington State’s 

Dangerous Waste Regulations (WAC 173-303). Special analytical methods have been developed 

to meet these regulatory requirements. Methods range from traditional gas chromatography 

(GC), more recent high resolution GC mass spectroscopy, to new immunoassay techniques.

Numerous methods (Table 7 from National Environmental Methods Index) have been developed 

to analyze PCBs in a wide range of media using techniques with variable costs and detection 

levels. Although the list is not complete, it is indicative of the variety and type of methods 

currently available to test samples for PCBs. In Table 7 “Source” refers to the organization that 

developed the method, although it may now be required by different regulations.

For the purposes of this CAP, the three most commonly used analytical methods will be 

discussed in more detail:

• Aroclor methods

• Congener specific methods

• Screening methods
35

Table 7. Methods developed to test for PCBs in a wide range of media (NEMI, 2013)

Method Number Source Method Descriptive Name Detection 

Level Instrumentation Relative Cost

530021 Abraxis PCBs by Immunoassay, Lower Chlorinated, Magnetic Particle 5 ppb IA $

530011 Abraxis Coplanar PCBs by Immunoassay, Microtiter Plate 14 ng/L IA $

530001 Abraxis PCBs by Immunoassay, Higher Chlorinated, Magnetic Particle 0.1 ppb IA $

505 EPA-NERL Pesticides and PCBs in Water GC-ECD N/A GC-ECD $$$

525.3 EPA-NERL Organics in Water Using GCMS N/A GC-MS $$$

508A EPA-NERL PCBs by GC-ECD N/A GC-ECD $$$

508.1 EPA-OGWDW/TSC Chlorinated Pesticides, Herbicides, and Organohalides in Water by GC-ECD N/A GC-ECD $$$

8082A EPA-RCRA Polychlorinated Biphenyls (PCBs) by GC N/A GC-ECD/ELCD $$

508 EPA-TSC/NERL Chlorinated Pesticides in Water Using GC-ECD N/A GC-ECD $$$

ET013 Envirologix PCB (polychlorinated biphenyl) immunoassay .3 μg/g IA $

A00134 MWI PCB (polychlorinated biphenyl) in water by immunoassay .2 μg/L IA $

A00134/A00137 MWI PCB (polychlorinated biphenyl) in soils/sediment by immunoassay .5 μg/g IA $

130.10 NOAA NST Organic contaminants in marine sediments by GC-ECD .05 ng/g GC-ECD $$$

130.11 NOAA NST Organic contaminants in marine animal tissues by GC-ECD .05 ng/g GC-ECD $$$

SPMDs USGS Passive sampling of organic compounds in water, air, and soils/sediments by SPMDs N/A SPMD $$$$

O-1104 USGS-NWQL Organochlorine and organophosphorous compounds, dissolved .01 μg/L GC-ECD $$$

O-3104 USGS-NWQL Organochlorine and organophosphorous compounds, total recoverable .01 μg/L GC-ECD $$$

O-5129-95 USGS-NWQL Organochlorine Pesticides and Gross PCBs in Bottom Sediment by GC 50 μg/kg GC-ECD $$$$

525.2 EPA-NERL Organics in Water Using GCMS .11 μg/L GC-MS $$$

1668a (Tissue) EPA-OGWDW/TSC Chlorinated Biphenyls in Tissue by HRGC/HRMS .011 ng/g GC-MS $$$$

1668a (Water) EPA-OGWDW/TSC Chlorinated Biphenyls in Aqueous Samples by HRGC/HRMS 112 pg/L GC-MS $$$$

1668a (Soil/Sediment) EPA-OGWDW/TSC Chlorinated Biphenyls in Soil, Sediment, and Mixed Samples by HRGC/HRMS .011 ng/g GC-MS $$$$

ECD = Electron capture detector MS = Mass Spectroscopy

MWI = Modern Water Inc. OGWDW = Office of Ground Water and Drinking Water

ELCD = Electrolytic conductivity detector NERL = New England Regional Laboratory RCRA = Resource Conservation and Recovery Act

GC = Gas Chromatography NOAA = National Oceanographic and Atmospheric Association SPMD = Semi-permeable membrane device

HRGC = High Resolution Gas Chromatography NST = National Standards and Trends TSC = Technical Support Center

HRMC = High Resolution Mass Spectroscopy NWQL = National Water Quality Laboratory USGS = United States Geological Survey
36

Aroclor detection 

EPA developed specific methods to comply with TSCA and other applicable legislation. In order 

to meet the requirements of the Resource Conservation and Recovery Act or RCRA, EPA 

developed Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, more 

commonly known as SW-846 (EPA 2012a). Included in SW-846 are two specific methods for 

analyzing PCBs in a wide range of media:

• Method 8082A: Polychlorinated Biphenyls (PCBs) by Gas Chromatography

• Method 8275A: Semi-volatile Organic Compounds (PAHs and PCBs) in Soils/Sludges and 

Solid Wastes Using Thermal Extraction/Gas Chromatography/Mass Spectrometry 

(TE/GC/MS)

Method 8082A is the more traditionally used as one of the earliest methods developed to meet 

regulatory requirements and is responsible for much of the legacy data reported as Aroclor 

mixtures or specific PCB congeners identified in the method. Method 8082A is ‘... used to 

determine the concentrations of polychlorinated biphenyls (PCBs) as Aroclors or as individual 

PCB congeners in extracts from solid, tissue, and aqueous matrices, using open-tubular, 

capillary columns with electron capture detectors (ECD) or electrolytic conductivity detectors 

(ELCD).’ (EPA 2012a) The specific chemicals reported by this method (Table 8) are detected in 

the parts per billion (ppb) to parts per million (ppm) levels depending upon complexity of sample 

and matrix involved.

Congener detection

As technology improved and the need for congener specific analysis was identified, Method 

1668C (USGS 2010) was developed. Method 1668 was created to analyze PCBs in water, soil, 

sediment, biosolids and tissue. It provides analytical results for ‘... the 12 polychlorinated 

biphenyls (PCBs) designated as toxic by the World Health Organization (WHO): congeners 77, 

81, 105, 114, 118, 123, 126, 156, 157, 167, 169, and 189 [and] the remaining 197 CBs 

[chlorinated biphenyls], approximately 125 of which are resolved adequately on an SPB-octyl 

gas chromatographic column to be determined as individual congeners. The remaining 

approximately 70 congeners are determined as mixtures of isomers (co-elutions).’ (EPA 2010) 

Method 1668 requires the use of a high-resolution mass spectrometer for detection and,

therefore, is considerably more expensive than Method 8082. Method 1668, however, is 

becoming more common as concerns have been raised about PCBs from non-legacy sources and 

potential degradation products from legacy Aroclor mixtures. Detection limits for Method 1668

can be in the low part per quadrillion (PPQ) levels in clean water to ppb levels or higher 

depending upon complexity of sample and matrix involved.

It is important to note that PCB detection methods have improved over time. Current methods 

provide detailed data on specific congeners while earlier methods provided data on specific PCB 

mixtures and homologs. This improvement of analytical methods can prove challenging as it is 
37

often difficult to compare data over time as the methods do not provide comparable information 

at similar detection levels.

Table 8. PCBs reported by Method 8082A (EPA 2012a)

Compound CAS No. IUPAC #

Aroclor 1016 12674-11-2 -

Aroclor 1221 11104-28-2 -

Aroclor 1232 11141-16-5 -

Aroclor 1242 53469-21-9 -

Aroclor 1248 12672-29-6 -

Aroclor 1254 11097-69-1 -

Aroclor 1260 11096-82-5

2-Chlorobiphenyl 2051-60-7 1

2,3-Dichlorobiphenyl 16605-91-7 5

2,2',5-Trichlorobiphenyl 37680-65-2 18

2,4',5-Trichlorobiphenyl 16606-02-3 31

2,2',3,5'-Tetrachlorobiphenyl 41464-39-5 44

2,2',5,5'-Tetrachlorobiphenyl 35693-99-3 52

2,3',4,4'-Tetrachlorobiphenyl 32598-10-0 66

2,2',3,4,5'-Pentachlorobiphenyl 38380-02-8 87

2,2',4,5,5'-Pentachlorobiphenyl 37680-73-2 101

2,3,3',4',6-Pentachlorobiphenyl 38380-03-9 110

2,2',3,4,4',5'-Hexachlorobiphenyl 35065-28-2 138

2,2',3,4,5,5'-Hexachlorobiphenyl 52712-04-6 141

2,2',3,5,5',6-Hexachlorobiphenyl 52663-63-5 151

2,2',4,4',5,5'-Hexachlorobiphenyl 35065-27-1 153

2,2',3,3',4,4',5-Heptachlorobiphenyl 35065-30-6 170

2,2',3,4,4',5,5'-Heptachlorobiphenyl 35065-29-3 180

2,2',3,4,4',5',6-Heptachlorobiphenyl 52663-69-1 183

2,2',3,4',5,5',6-Heptachlorobiphenyl 52663-68-0 187

2,2',3,3',4,4',5,5',6-Nonachlorobiphenyl 40186-72-9 206
38

Screening methods

In response to a need by industry to test wastes quickly and cheaply, manufacturers developed 

screening methods to test specific waste types. These methods were reviewed and adopted by 

EPA into SW-846. Specifically, PCB applicable screening methods listed in SW-846 include:

• Method 9077: Test Methods for Total Chlorine in New and Used Petroleum Products (Field 

Test Kit Methods)

• Method 9078: Screening Test Method for Polychlorinated Biphenyls in Soil

• Method 9079: Screening Test Method for Polychlorinated Biphenyls in Transformer Oil

• Method 4020: Screening for Polychlorinated Biphenyls by Immunoassay

Method 9077 is ‘... used to determine if a new or used petroleum product meets or exceeds 

requirements for total halogen measured as chloride. An analysis of the chlorine content of 

petroleum products is often required prior to their use as a fuel. The method is specifically 

designed for used oils, permitting onsite testing at remote locations by nontechnical personnel to 

avoid the delays for laboratory testing’ (EPA 2012a). It provides results ranging from 300 to 

4,000 parts per million (ppm).

Method 9077, however, tests for total chlorine and cannot differentiate PCBs from other 

chlorinated species such as chlorinated solvents commonly used in industry. Methods 9078 and 

9079 test specifically for PCBs. Method 9078 is ‘...used to determine the amount of PCB 

(polychlorinated biphenyl) contamination in soils such as sand, gravel, loam, sediment, and clay, 

assuming that PCBs are the sole source of organic halogens in the sample.’ Detection levels 

range from 2 to 2,000 ppm PCBs. The method provides inaccurate results if other chlorinated 

species are present and should be used with caution. However, in those instances where PCB 

contamination is known, it provides a quick and easy method to determine the extent of 

contamination and is often used as a screening tool to limit the number of samples sent to a 

laboratory for more detailed analyses.

Method 9079 is ‘... used to screen hydrocarbon based electrical insulating fluids for 

polychlorinated biphenyls (PCBs) at preset levels of 20, 50, 100, or 500 μg/g [ppm].’ The 

method is calibrated using Aroclor 1242 as a standard and results for other Aroclor mixtures may 

vary slightly. Method 4020 is ‘... a procedure for screening soils and non-aqueous waste liquids 

to determine when total polychlorinated biphenyls (PCBs) are present at concentrations above 5, 

10 or 50 mg/kg.’ Method 4020 only works on soils containing more than 0.625 ppm PCBs.

Used correctly, Methods 9078, 9079 and 4020 are specifically designed to help meet regulatory 

requirements. Simple PCB kits meeting the requirements of these methods include but are not 

limited to:
39

• Dexsil® Clor-N-Oil Field Test Kit3

• Dexsil® Clor-N-Soil Field Test Kit4

• Dexsil® Clor-d-tect Field Test Kit5

• EnSys Field Test6

• RaPID Assasy Field Test7

In addition to these wet chemical methods, several simple instrumentation and detection kits are 

also available to test for PCBs including, but are not limited to:

• Dexsil® L2000DX PCB/Chloride Analyzer System (LP-2000)8

• Hach® PCB in Soil Pocket Colorimeter II Test Kit9

• Hach® DR 2700TM Portable Spectrophotometer10

These field test kits are useful as they allow detection for PCBs in the field by individuals with 

limited technical knowledge and expertise.

 3 More information available at: http://www.dexsil.com/products/detail.php?product_id=2, accessed 7/2013. 4 More information available at: http://www.dexsil.com/products/detail.php?product_id=4, accessed 7/2013. 5 More information available at: http://www.dexsil.com/products/detail.php?product_id=29, accessed 7/2013. 6 More information available at: http://www.tttenviro.com/store/ensys, accessed 7/2013. 7 More information available at: http://www.tttenviro.com/store/rapid-assay, accessed 7/2013. 8 More information available at: http://www.dexsil.com/products/detail.php?product_id=13, accessed 7/2013. 9 More information available at: http://www.hach.com/pcb-in-soil-pocket-colorimeter-ii-test-kit/product-parameterreagent?id=7640220978, accessed 7/2013. 10 More information available at: http://www.hach.com/dr-2700-portablespectrophotometer/product?id=7640439006&callback=bp, accessed 7/2013.
40

PCB Uses and Sources

Legacy 

Historically, PCBs were used in closed systems such as electrical transformers and capacitors, 

partially closed uses such as heat transfer and hydraulic systems, and open systems such as 

surface coatings, adhesives, plasticizers, inks, insulating materials, and pesticides (UNEP 1999).

PCBs were valued for their stability, inability to conduct electricity and anti-microbial effects. 

60% of worldwide and 77% of US production was used in the production of transformers and 

capacitors and total worldwide production from 1929 to 1989 is estimated at 1.2 million tons 

(Tanabe 1988).

PCBs were intentionally added to some products in open applications where the PCBs are in 

direct contact with the environment and may be transferred from the product into the 

environment. Plasticizers were the most common use of PCBs in products such as PVC 

(polyvinyl chloride), neoprene and other chlorinated rubbers. PCBs have also been used in paints 

and surface coatings as flame retardants and adhesives as plasticizers (UNEP 1999). PCBs were 

often added to caulk and paint in the field at varying amounts. 

Current levels in the environment are due to cycling of PCBs from these historical uses with 

additional releases of PCBs from legacy uses and new inadvertently produced by-products of 

chemical manufacture. Specific Aroclor mixtures were often used in specific applications (Table 

9). Companies have found alternatives for most PCB uses. 

Table 9. Historical Aroclor Uses (from ATSDR 2000)

End Use Aroclor

1016 1221 1232 1242 1248 1254 1260 1262 1268

Capacitors   

Transformers   

Heat transfer 

Hydraulics/lubricants

Hydraulic fluids     

Vacuum pumps  

Gas-transmission turbines  

Plasticizers

Rubbers      

Synthetic resins     

Carbonless paper 

Miscellaneous
41

End Use Aroclor

1016 1221 1232 1242 1248 1254 1260 1262 1268

Adhesives     

Wax extenders   

De-dusting agents  

Inks 

Cutting oils 

Pesticide extenders 

Sealants/caulks 

Inadvertent Generation in New Products

PCBs may be found as contaminants in a wide range of chemical processes involving chlorine 

and can be found in recycled materials contaminated with PCBs. As part of 1984 TSCA 

rulemaking on PCBs the EPA identified about 200 chemical processes that may inadvertently 

create PCBs and narrowed the list to 70 chemical processes that are likely to contain PCBs as 

contaminants from manufacturing processes (Panero et al. 2005, see Appendix D for list). Most 

of these chemical processes have not been evaluated to determine if PCBs are actually a reaction 

byproduct and present in the final product. In addition there are other processes that may 

inadvertently generate PCBs that are not on this list. Nor have these processes been analyzed to 

determine how inadvertently generated PCBs enters the consumer supply chain.

Recent studies on PCBs from pigment manufacturing have shown that PCBs can still be found in 

products. Many of these products contain PCBs as an impurity created during the production 

process. Inadvertent sources include contaminants or byproducts from manufacturing processes 

using chlorinated compounds either as a reaction component or solvent. As shown in Table 10,

PCBs have been found in various pigments at substantial levels (EPA 1982b).

Table 10. PCBs congeners found in specific pigments (EPA 1982)

PCB Congeners Pigment Levels found

(μg/g or ppm)

PCB-11 Diarylide yellow 70

PCB-209 Phthalocyanine green 40

Mix of penta- and hexa- Phthalocyane blue 90*

*Total of PCB congeners

According to one of the rules created by EPA to implement TSCA (49 FR 28172) products may 

contain low levels of PCBs if the certain conditions are met (see section on Regulations). 
42

Over the last few years, researchers have begun to test consumer products for the potential 

presence of PCBs. Numerous organic pigments and dyes exist that may contain PCBs as an 

unintentional byproduct including diarylides (yellow and orange), naphtharylamides (oranges 

and reds), phthalocyanines (blue), and basic dye complex pigments (reds, violets, blues and 

greens) (Christie 2013). In general pigments are insoluble in their application medium and dyes 

are soluble, with inks mostly being used for textile coloration and pigments having broader uses 

(Christie 2013, Guo et al. 2014). Many of these pigments fall into the broad category of azo 

compounds. An azo compound contains one or more double-bonded nitrogen atoms (R-N=N-R′) 

where R and R′ are organic additions with varying degrees of complexity. Azo compounds are 

very efficient at absorbing light and emitting the radiation in specific wavelengths, thereby 

providing specific colors. Chlorinated compounds are often used in azo pigments as they can 

greatly increase the lifetime of the resultant product.

Hu and Hornbuckle (2010) conducted sampling of consumer paints containing specific azo 

(yellow) and phthalocyanine (blue and green) organic pigments and found PCB levels ranging 

from 2 to 200 ppb in 15 of 33 consumer paints tested. PCB-11 is also found in printed materials 

(Table 11) from various locations around the world (Guo et al. 2014).

Table 11. PCB-11 worldwide concentrations from printed materials

Printed Material (Country) PCB 11 concentration 

(ng/g or ppb)

Black and white printed newspaper (Georgia) 1.6

Black and white printed newspaper (Moldova) 9.7

Black and white printed newspaper (China) 15

Color newspaper (Georgia) 6.5

Color newspaper (Moldova) 16

Food packaging box (Czech Republic) 6.8

Food packaging box (Ukraine) 5.0

As an example of dyes contaminated with PCBs, diarylide yellow comprises approximately 25% 

of the 250 million tons of organic pigments produced yearly worldwide (Rodenberg 2012) and 

testing has shown PCBs and especially PCB-11 are produced during pigment manufacture. PCB11 is part of the structure of diarylide yellow (Figure 8) as indicated in the red box. PCB-11 can 

be produced either as a byproduct during the manufacturing process or from degradation of the 

pigment.
43

Figure 8. Diarylide yellow and PCB-11 (Rodenburg, 2012)

In addition to PCB-11, purification of the inorganic pigment titanium dioxide (TiO2) produces 

larger molecular weight PCBs as a byproduct (Rodenburg 2012). Chlorine is reacted at high 

temperatures with titanium dioxide (TiO2) ores containing other metal oxides such as rutile 

(TiO2) or ilmenite (FeTiO3) to form titanium tetrachloride (TiCl4) which as a liquid is easily 

collected. TiCl4 is then reacted with oxygen to make pure TiO2 (UNEP 2007). During this 

product process, the larger molecular weight PCBs are created as a reaction byproduct.

Titanium dioxide can also be produced by a sulphate process that does not generate PCB 

contamination. The sulfate process uses 2.4-3.5 tons of concentrated sulfuric acid (H2SO4) per 

ton of titanium dioxide and the process creates large amounts of acid waste that must be further 

treated. The chloride process does not generate spent acids and, therefore, creates less waste to 

be dealt with. (UNEP 2007) 

Research is continuing on alternatives to the organic azo pigments. The main challenges faced 

with replacements (Christie 2013) are:

• Required color performance

• Required degree of transparency or opacity

• Level of fastness or permanence to light, solvents, heat, chemicals, etc. demanded by 

specific applications

• Cost effectiveness

• Acceptable toxicological and environmental profile.

Research is continuing and alternatives have been identified which appear to address many of 

these concerns (Christie 2013).
44

Combustion 

Lastly, PCBs are formed through incomplete combustion of products containing carbon and a 

chlorine source (ATSDR 2000). Given the widespread use of chlorinated compounds such as 

polyvinylchloride for packaging, tubing, and other applications, incomplete combustion forms a 

wide range of halogenated compounds such as chlorinated dioxins and furans and PCBs. Most 

municipal incinerators are not effective in destroying PCBs and it is recommended that PCBcontaminated waste be burned at temperatures above 1,100 degrees Celsius and that care is taken 

with the temperature, residence time and turbulence of the waste in order to guarantee complete 

combustion (UNEP 1999). There is only one municipal solid waste incinerator in Washington. 

Methods of Manufacturing

PCBs were first mentioned in a publication in Germany in the 1880s. The Swann Chemical 

Company in Anniston, Alabama was the first US company to manufacture PCBs commercially 

by bubbling benzene through molten lead to create biphenyl with subsequent chlorination of the 

biphenyl. Monsanto purchased the Swann Chemical Company in 1935 (Erickson and Kaley 

2011).

Much has been written about the methods in which PCBs were manufactured (Panero et al.

2005, ATSDR 2000, Pomerantz 1978). Similar methods were used to manufacture PCBs with 

the main variable being the starting materials of biphenyl and naphthalene. The manufacturing 

process for Aroclors involved the ‘... chlorination of biphenyl with anhydrous chlorine in the 

presence of a catalyst, such as iron filings or ferric chloride. The degree of chlorination, which 

determines the nature of the Aroclor, was controlled by the chlorine-contact time (range, 12–36 

hours) in the reactor.’ (ATSDR 2000)

Once the manufacturing process was complete, ‘The crude product [was] blown with air, and a 

small amount of lime ... added to remove hydrogen chloride and ferric chloride. The resulting 

chlorinated mixtures [were] batch-distilled to remove color and traces of hydrogen chloride and 

ferric chloride’ (HSDB 2013).

PCBs were also created using naphthalene which was ‘... reacted to varying degrees with 

chlorine to produce a number of compounds designated by various trade names such as Aroclor’

(HSDB 2013).
45

Environmental Transformation and Degradation

Although very stable in the environment, the major pathways for degradation (ATSDR 2000) 

are:

• Vapor phase degradation with hydroxyl radicals

• Photolysis in water

• Aerobic biodegradation (preferentially less chlorinated congeners)

• Anaerobic microbial degradation (more highly chlorinated congeners favored)

PCBs in the atmosphere undergo complicated reactions (Figure 9) primarily with hydroxyl 

radicals created when water absorbs sunlight and separates into hydroxyl (OH) and hydrogen 

(H) radicals. Reactions with hydroxyl radicals are most prevalent. A radical is an atom or 

chemical that has a net charge of zero (neither negative nor positive) but has less than the 

preferred number of electrons in its outer shell. This instability causes a radical to be very 

reactive (ATSDR 2000). 

Figure 9. Hydroxyl photo-degradation pathways for PCBs in air (ATSDR 2000)
46

In water, photolysis is the primary pathway for degradation as other more common reaction 

mechanisms such as hydrolysis and oxidation do not appear to contribute substantially. In these 

reactions, a carbon to chlorine bond absorbs energy from sunlight and separates into PCB and 

chlorine radicals. The PCB radical reacts with water forming a stable PCB compound but with 

one less chlorine (Figure 10). This reaction is particularly important for the larger PCBs as the 

more chlorines present, the easier it is to cleave a carbon to chlorine bond. In large PCB 

molecules, cleavage occurs preferentially on the ring with the most carbons. (ATSDR 2000)

3 3'

Cl Cl

3 3'

Cl

.

+ H2O

3, 3'dichloro-1,1'-biphenyl Energy from sunlight 3-chloro-1,1'-biphenyl radical*

3

Cl

3-chloro-1,1'-biphenyl

*Note: Although the radical is shown on the 3' position, the electron is actually dispersed throughout the benzene ring.

Figure 10. Photolysis of PCB-11

In sediment and soil, no abiotic process is known that significantly degrades PCBs. PCBs, 

however, have been found to degrade readily in both aerobic and anaerobic conditions. Both 

bacterial and fungal species have been shown to biodegrade PCBs using aerobic processes.

Because of size restrictions, PCBs with 1 to 4 chlorine atoms are most likely to be degraded 

under aerobic conditions via a two step process (Figure 11). First, one of the two benzene rings is 

oxygenated and separated from the other ring. The remaining benzene ring is left as a 

chlorobenzoic acid. This combined process is called cometabolism.

After cometabolism has occurred, the remaining chlorobenzoic acid is further broken down into 

water and carbon dioxide (mineralization) in a series of reactions that continually add oxygen to 

the compound. Aerobic biodegradation of PCBs also occurs primarily in soil and surface 

sediments. Interestingly, PCBs with fewer chlorine atoms (1-3) degrade faster than those with 

more chlorine atoms. This causes a fractionating effect where less chlorinated species biodegrade 

first while those with higher levels of chlorine atoms are left behind for long-term build up in the 

environment. (ATSDR 2000)
47

Anaerobic degradation of PCBs is a much slower process compared with aerobic degradation 

and occurs primarily by reductive dechlorination where chlorine atoms are removed one after the 

other from a PCB molecule. At least eight distinct and complicated anaerobic pathways have 

been identified which may occur alone or in combination. Different pathways may favor chlorine 

in specific positions on the PCB molecule. (ATSDR 2000)

Figure 11. Pathways for Aerobic Degradation of PCBs (ATSDR 2000)
48

Production, Uses, and Releases

According to the PBT Rule (WAC 173-333) chemical action plans (CAPs) must include a 

section on “production, uses and releases” that contains information on the production of the 

chemical and estimates on the amount of the PBT used and released from all sources or activities 

in Washington. 

From 1929 to 1979 the production of PCBs in the US was approximately 1.4 billion lbs (600,000 

metric tons), with the largest use for electrical equipment (EPA 1997a). Monsanto, the primary 

manufacturer of PCBs in North America, voluntarily limited production to certain Aroclors in 

1971 (ATSDR 2000) and commercial production was stopped by 1979 under TSCA. 

Washington’s portion was estimated based on population size to give an estimate of the expected 

uses in Washington State. 

Table 12. Industrial Uses of PCBs (1929-1975) from EPA 1997

PCB Use Pounds 

(millions)

Percentage of 

Total

Washington’s 

portion 

(millions of 

pounds)

Washington’s 

portion 

(metric tons)

Capacitors 630 50.3% 13 5,700

Transformers 335 26.7% 7 3,040

Plasticizer uses 115 9.2% 2 1,040

Hydraulics and lubricants 80 6.4% 2 730

Carbonless copy paper 45 3.6% 1 410

 Heat transfer fluids 20 1.6% 0.4 180

 Petroleum additives 1 0.1% .02 9

Miscellaneous industrial 

uses 

27 2.2% .5 250

TOTALS 1,253 100.0% 25 11,400

EPA defines transformers and capacitors as closed uses. There are partially closed uses, such as 

hydraulic fluids, heat exchange fluids, and gas pipelines. There is a much larger variety of open 

uses as detailed in Table 13. In closed sources PCBs are contained, barring accidental spill or 

leakage. In partially contained sources PCBs are partially contained and there is some exposure 

to the environment. In open sources PCBs are exposed to environment with no containment.
49

Table 13. Examples of legacy uses of PCBs

Class US 

consumption Examples

Closed 75%

Industrial scale transformers, capacitors, voltage regulators

Fluorescent light ballasts

Consumer electrical items (fridges, televisions, washing machines)

Manufacturing machinery (capacitors, transformers, associated 

switchgear)

Partially 

closed 10%

Hydraulic fluids

Heat exchange fluids

Gas pipelines

Open 15%

Plasticizer in paints, resins, synthetic rubber, surface coatings, wax

Sealants, waterproofing compound, glues and adhesives

Caulking compounds

Pesticide extenders

Pigments and dyes

Carbonless copy paper

Microscope immersion oil

Sound proofing materials

Window glazing

We do not have enough information to estimate the historic use of PCBs in all of these 

applications or how much is still in use in Washington. 

We cannot estimate the amount of PCBs currently in Washington State from partially closed 

applications, i.e. hydraulic fluids, heat exchange fluids, and gas pipelines. Hydraulic fluids 

containing PCBs were used in industrial applications that required heat and/or fire resistance. 

From 1929 to 1975 about 6% of PCBs produced were used for hydraulic fluids and lubricants 

(EPA 1997a). About 2% of PCBs produced were used heat transfer fluids (EPA 1997a) during 

the same time period. PCB-based oils were also used in gas transmission compressors. The 

compressors were used to move natural gas through thousands of miles of pipelines across the 

U.S. PCBs were also used as a fine mist into underground metal gas pipes to slow corrosion and 

lubricate the pipelines. PCBs remain in the pipelines until remediated, contributing to 

environmental releases through leaks and spills. 
50

Closed Legacy Uses

Transformers and Large Capacitors

PCBs have not been manufactured in the US for use in 

transformers and capacitors since 1979. Although 

many PCB-containing transformers have been retired, 

some remain in use. The estimated lifetime of 

transformers may be as long as 85 years and 20 years 

for capacitors (Ecology 2011b). While transformers 

and capacitors are considered “totally enclosed” under 

TSCA, there are leaks and spills from such equipment 

until it is retired and replaced. 

Transformers are used to transform electricity from one voltage to another through 

electromagnetic induction. For example, they are used to convert a power generator’s lowvoltage electricity to higher voltage levels for transmission or to convert high voltages to lower 

voltages at the end user. Examples include pole-mounted, pad-mounted, and underground 

distribution transformers and larger transformers at substations. Utilities operated about 80% of 

mineral oil transformers (Panero et al. 2005). Transformers are also found in institutional, 

commercial, or other private facilities, including schools, mines, and railways. 

Capacitors are passive electronic components used to store energy. They have many uses and 

come in many different sizes. This section includes large capacitors and small capacitors are 

discussed in the following section. 

The size of transformers and capacitors vary and the amount of PCBs per unit also varies (see 

side bar for regulatory classification and the regulations section for more information). Mixtures 

of PCBs were marketed under different names in different areas. Askarel was the trade name 

used in the US for the blend of PCB and trichlorobenzene used for transformers. Askarel 

transformer fluid was typically 60-70% PCB by weight. Other transformers used mineral oil as 

the dielectric fluid. Transformers that were manufactured after 1979 are certified to be PCB-free 

by the manufacturer. Prior to that date some mineral oil transformers were contaminated with 

PCBs, often during manufacture when the same equipment was used for both Askarel and 

mineral oil fluids. 

Capacitors were typically filled with nearly pure PCB oil and the largest capacitors contained as 

much as 35 kg PCB (Ecology 2011b). The typical large capacitor contained 31 lbs (14 kg) of 

PCBs (Federal Register Vol 47, No. 78). 

A 1987 EPA report on sources of PCBs includes accidental release estimates from a 1982 study 

by the Edison Electric Institute and the Utility Solid Wastes Activity Group (USWAG/EEI) in 

response to an order issued by the US Court of Appeals for the District of Columbia Circuit. The 

Federal regulations classify 

transformers into three groups: 

1. PCB transformers with > 500 

ppm PCBs. 

2. Contaminated transformers

with 50-500 ppm PCBs.

3. Non-PCB transformers have 

less than 50 ppm PCBs. 
51

EEI/USWAG study gathered survey data from 98 of the 100 largest utilities on leaks and spills. 

It also estimated the number of pieces of equipment and concentrations of PCBs in the 

equipment based on data from utilities (USWAG/EEI 1982). This is the only study on leaks that 

was identified. 

Estimate in Washington 

An earlier report by Ecology overestimated PCBs in transformers and large capacitors in the 

Puget Sound basin (Ecology 2011b) in several ways. The earlier estimate relied on an EPA 

database of registered PCB transformers that was not up to date, estimates of unregistered PCB 

transformers, an assumption that the PCB transformers in Washington are Askarel transformers 

with 60% PCBs, and the leakage rates did not take into account the lower concentrations of 

PCBs in transformers currently in use. Conversations with public and private utilities in 

Washington, non-utility users of PCB transformers, and other experts led to much lower 

estimates here.

It is not appropriate to use national estimates or estimates from other regions for Washington 

State. Compared to other regions of the country, public utilities in Washington State have been 

the most progressive in testing equipment for PCBs and disposing of equipment with PCBs 

(Mark Pennell, personal communication). 

Transformers

There are 252 registered transformers in the EPA PCB Transformer Registration Database with 

121,053 kg of PCB oil in Washington (Appendix F). These are PCB transformers (>500 ppm) 

that were required to be registered with the EPA in 1998. The regulations do not require EPA to 

update the database when PCB transformers are taken out of use. We were able to contact most 

of the parties who registered transformers and found that most of the transformers had been 

disposed of (Table 14).

Table 14. PCB transformers in use in Washington

Still in use 14

Disposed of 228

Unknown 10

Total 252

The PCB transformer registry does not reflect the actual number of PCB transformers still in 

service and no current inventory of PCB equipment exists in the US (EPA/EC 2009). The EPA 

states that the database is “not particularly useful for determining the amount of PCB equipment 

that is remaining in service” (EPA/EC 2009). Various attempts have been made to estimate the 

number of units remaining in use. The Great Lakes Binational Toxics Strategy 2009 Biennial 

Report (EPA/EC 2009) estimates that 64,312 PCB transformers remained in use throughout the 

US while there are about 14,150 registered transformers in the EPA database. Scaled down from 
52

the national to the state based on 2010 population, an estimated 1,401 transformers remained in 

use in Washington in 2007. This estimate assumes that about 80% of the PCB transformers still 

in use were not registered with EPA. Based on conversations with public and private utilities in 

Washington, there is not that much unknown equipment in use. A more reasonable estimate 

would be about 20% of transformers are unknown and never registered. Some utilities know the 

PCB concentration of all their transformers.

Using the 14 known PCB transformers still in use from the EPA database, adding an additional

20% results in an additional three PCB transformers still in use in Washington. If the other 10

registered PCB transformers whose status is unknown are all still in use, the total number of PCB 

transformers (> 500 ppm PCB) in Washington could be as high as 27, including the additional 

20% of unknown and never registered PCB transformers. Based on the sizes and PCB 

concentrations of some of the known PCB transformers still in use, we have estimated they each 

contain about 665 gallons of fluid that is 1500 ppm PCB. Askarel transformers were less than 

0.2% of utility transformers nationwide (USWAG/EEI 1982) and were used even less frequently 

in Washington State. Askarel transformers contain 60-70% PCBs and the more common mineral 

oil transformers have a much lower concentration of PCBs. When national data was compiled for 

the USWAG/EEI study (1982) 90% of the mineral oil transformers had <50 ppm PCBs. As 

utilities have identified and removed PCB contaminated transformers, the average concentration 

of PCBs has become even lower. 

There do not seem to be known Askarel transformers in Washington, but each leak/spill from an

Askarel transformer has the potential to release a significant amount of PCBs. The USWAG/EEI 

study estimated that each leak/spill would release 0.56 - 64.5 lbs (0.25 – 29 kg) of PCBs. 

There are still some transformers with lower levels of PCBs, mostly < 50 ppm, that are 

considered PCB contaminated (50-500 ppm) or non-PCB (1-50 ppm) in the regulations. These 

have never been required to be tracked or reported. Utilities in Washington have been testing 

transformers and many have been disposing of transformers with any detectable level of PCBs 

(>1-2 ppm). Based on the number of these transformers that are known to be still in use by 

utilities, the amount of older equipment that is untested and has unknown levels of PCBs, there 

are about 40,000 PCB contaminated (50-500 ppm) and non-PCB (1-50 ppm) transformers in the 

state that have a concentration of about 25 ppm PCBs. The transformers used in distribution lines 

on top of poles have about 20 gallons of fluid. 

Large Capacitors

Less is known about the number of large PCB capacitors in Washington compared to the number 

of PCB transformers. Capacitors were never required to be tested or registered. The Puget Sound 

study (Ecology 2011b) used the national estimate of 1,293,000 large capacitors still in use from 

The Great Lakes Binational Toxics Strategy 2009 Biennial Report (EPA/EC 2009). Scaled down 

from the national to the state level based on 2010 population size, an estimated 28,162 large PCB 
53

capacitors could remain in use in Washington. However, based on conversations with some of 

the 61 public and private utilities, there are very few large PCB capacitors remaining in 

Washington State. PCB capacitors were never required to be inventoried and not all equipment is 

known, but utilities we asked were confident that all the large PCB capacitors had been removed 

from 10 to more than 20 years ago. About 15% of large PCB capacitors were owned by nonutilities (EPA 1987) and we have not tried to identify where those were used or if they are still in 

use. If we estimate 95% of the PCB capacitors have been disposed of, then there would be about 

1,400 remaining still in use. We do not have any evidence for which non-utilities in Washington 

had PCB capacitors or how many of those capacitors are still in use. The estimate that 5% remain 

in use is based on the hypothesis that non-utilities have also removed capacitors over time, but 

have not removed all of them. 

Other equipment not estimated

Utilities have other equipment that historically contained PCBs, such as reclosers, switches, 

circuit breakers, bushings, etc. This equipment contained much less PCBs compared with the 

transformers and capacitors (USWAG/EEI 1982). We have not attempted to estimate how much 

of the old PCB-containing equipment still remains in use. Some utilities have been testing and 

removing this equipment. 

Leakage and Spillage Rates

In the Puget Sound study (Ecology 2011b) the leakage rates were based on PCBs/unit for 

Askarel transformers, which does not take into account the lower concentrations of PCBs in 

transformers currently in Washington. 

The USWAG/EEI study (1982) found about 2% of all transformers and 0.77% large capacitors 

had moderate leaks or spills each year. The study includes lower rates for equipment that had > 

50 ppm PCBs. They did not include equipment with < 50 ppm PCBs that is considered non-PCB 

in federal regulations, but we are including that equipment here. The average amount of PCBs 

leaked/spilled per event was 0.00004 – 0.005 lbs (18 mg – 2.27 g) for mineral oil transformers 

and 2 – 17.1 lbs (0.9 – 7.76 kg) for PCB capacitors. As mentioned earlier, the average amount of 

PCBs per leak/spill for Askarel transformers was 0.56 - 64.5 lbs (0.25 – 29 kg) of PCBs.

Leaks from transformers and large capacitors were estimated in San Francisco Bay (McKee et al.

2006) and NY Harbor (Panero et al. 2005). Both of these studies relied on the EPA transformer 

database that is not accurate for Washington. 

This results in a total annual release estimate of < 2 kg for transformers and 10-80 kg for 

capacitors in Washington State (Table 15).
54

Table 15. Release estimate for transformers and capacitors

Equipment 

Type

PCB 

concentration

Number 

of units Reservoir

PCB 

spill/leak 

rate 

(annual)

PCBs 

released 

per 

spill/leak 

(kg)

Annual PCB 

release 

Transformers

>500 ppm 14 - 27

100-200 kg

2% 0.000018-

0.00227

5 mg – 1.2 g

1-500 ppm 40,000 2% 14 g- 2 kg

Large Capacitors 100 % 1,400 20 metric tons 0.77% 0.9- 7.76 10-80 kg

There is uncertainty in the number of electrical units still in use and the older data on leakage 

rates may not reflect current operating conditions. The estimates do not account for spill 

response, thus actual amounts of PCBs released to the environment may vary. Indoor spills in 

particular are likely to be contained and cleaned up. Additional emissions from direct 

volatilization from equipment are likely, but not estimated due to lack of information. 

Opportunities for Reduction 

• Status quo

o 1998 EPA registry for known transformers > 500 ppm

o Voluntary removal 

• Develop a state inventory of equipment that includes the number of units and the amount of 

PCBs. 

• Require utilities and other owners of transformers, capacitors, and other electrical equipment 

to develop and implement a plan for removal. 

• Require complete change out to remove old units (with proper disposal) by a certain date. 

Based on conversations with public and private utilities in Washington, they have been actively 

testing and removing equipment with PCBs beyond what is required by federal law. Several 

utilities in Washington (personal communication) and other states (Panero et al. 2005) use serial 

numbers of transformers to identify additional transformers that are likely to have PCBs, once 

one transformer in a batch has been identified as having PCBs. Many utilities are disposing of 

equipment with any detectable level of PCBs (> 1 ppm). 

Small Capacitors

Capacitors containing less than three pounds of PCB oil are considered small capacitors. Small 

capacitors containing PCBs have been used in a number of items including motors, appliances, 

and light ballasts. Small capacitors generally contain 45-270g of PCBs in oil and lamp ballast 

capacitors contain 45-70 g PCBs (EPA 1982 proposed rule in the Federal Register).

Wisconsin found submersible well pumps that contain PCB filled capacitors and in 1992 

estimated that 10,000 -15,000 of their 800,000 wells contained capacitors with PCBs (Wisconsin 

DNR 2001). This only applies to equipment that was manufactured before 1979. Wisconsin has 
55

recommendations for owners to identify such pumps and prevent exposure. It is unknown how 

common this is in Washington. There is a report of one contaminated well from a pump in 

Whatcom County in 1990 (Seattle Times January 8, 1990). 

Estimate in Washington 

Several studies estimate the number of small PCB containing capacitors remaining in use that are 

not light ballasts. In 1992 the University of Illinois estimated that 10-25% of US household 

appliances contained capacitors with PCBs (Panero et al. 2005). EPA (1982b) estimated that 

historically there were 870 million small capacitors in use throughout the US in 1977 in 

industrial machines and small appliances. EPA (1987) also estimated a 10% annual disposal rate 

in 1982. Scaling the national estimate to Washington based on population and applying annual 

disposal rates of 20% and 10% yields an estimate of 12,000 to 586,000 small capacitors still in 

use in 2010. 

Globally, one third of all PCB production may have gone into lighting ballasts (Ecology 2011b).

National estimates of lamp ballasts currently in use include 300 million (US Army 2001) and 

500 million (Missoula County 2010). In 1998 EPA, citing an unnamed industry source, estimated 

that 1 billion small lamp PCB ballasts remained in use in the US (EPA 1998). Scaling this 

estimate to Washington based on population and applying annual disposal rates of 20% and 10% 

yields an estimate of 1.7 million to 6.2 million such ballasts still in use in 2010 in Washington. 

While we have some information on the number of PCB containing capacitors collected in 

Washington as hazardous waste or moderate risk waste, the information is not complete enough 

to use for estimating the number of units still in use. 

A range of 12,000 to 6.2 million non-lamp ballast small capacitors and lamp ballasts remains in 

use in Washington State. While small capacitors may contain 45-270 g PCB per unit, most of the 

remaining units are likely to be lamp ballasts, which typically contain 45-70 g PCB per unit. For 

the estimate we used 57.5g PCB/unit as an average. The assumed leakage rate is 4.2 kg/metric 

tons of PCBs, from the 1982 study on large capacitors (EPA 1982b). This results in an estimate 

of 400- 1,500 kg for lamp ballasts and 3-150 kg annually for other small capacitors (Table 16).

Table 16. Lamp ballasts and other small capacitors

Equipment 

Type

Basis for 

estimate

Number 

of units PCBs (kg)

PCB 

spill/leak rate 

(annual)

Annual PCB 

release 

kg/yr)

Other small 

capacitors

Scaled from 

national estimate

12,000-

586,000 690-33,695

4.2%

3-150 

Lamp ballasts Scaled from 

national estimate

1.7-6.2 

million 

97,750-

356,500 400-1,500

There is uncertainty around both the estimate of how many small PCB capacitors remain in use 

and how much leaks each year. Additional emissions from direct volatilization from equipment 

are likely, but not estimated.
56

Opportunities for Reduction 

• Status quo

o Continued use of old capacitors, with expected 10-20% annual disposal/replacement rates

• Educate consumers on which lamps and small appliances are likely to contain PCBs, 

including appropriate disposal options

• Statewide program to remove small capacitors. 

• Remove PCB-containing lamp ballasts in schools. 

• Investigate the status of PCB containing materials in schools. 

Removal of old light ballasts could be linked to changes for energy efficiency. EPA has national 

guidance for schools to replace PCB ballasts. NY settled a lawsuit in 2013 after widespread PCB 

contamination was found in schools and some fires (http://www.epa.gov/region2/pcbs/). 

Open Uses

Caulk

PCBs were used in caulk and joint sealants to improve the flexibility, increase the resistance to 

erosion, and improve adherence to other building materials from the 1950s to the 1970s (Robson 

et al. 2010). Monsanto voluntarily stopped producing PCBs for open uses, such as caulk, in 1971 

(ATSDR 2000). While the use of PCBs in open products above 50 ppm was banned in the US 

effective in 1979 under TSCA, materials that contain PCBs were not required to be removed. 

The use of PCB-containing caulk was a common practice in the 1970s and caulk formulations 

changed during the late 1970s (Herrick et al. 2004). The studies on PCBs in caulk have focused 

on buildings built from about 1950 to 1980 to include using up the existing stocks of PCBcontaining caulk. 

Sealants with high levels of PCBs have been found at varying levels in buildings in several 

studies. All of the studies found congener profiles consistent with Aroclors 1248, 1254, and 

1260. In general, PCBs were used at 5-30% in caulk (Priha et al. 2005). PCBs can be lost from 

caulk through volatilization, as well as wash-off and erosion. PCBs in caulk are associated with 

higher levels of PCBs in indoor air and dust, and the external soil (Priha et al. 2005, Herrick et 

al. 2007, SAIC 2011). Larger amounts of PCBs may be lost during renovations or destruction. 

Certain removal practices can reduce the amount of PCBs released both to workers and the 

environment (Sundahl et al. 1999). 

Herrick et al. (2004) found PCBs in schools and other buildings in the Boston area. In 13 of the 

24 buildings sampled, PCBs were found at concentrations of 2 to 36,000 ppm. PCB levels in the 

air ranged from 111 to 393 ng/m3 and in dust samples up to 81 ppm. 

There was a nationwide comprehensive survey in Switzerland (Kohler et al. 2005). In this study, 

1348 caulk samples from concrete buildings built between 1950 and 1980 were analyzed for 
57

PCBs. Forty-eight percent of the caulk samples contained PCBs, from < 50 ppm up to 550,000 

ppm (55%). 

The amount of PCBs in caulk was estimated in Toronto, Canada (Robson et al. 2010, Diamond 

et al. 2010). This study was based on a smaller sample size and found PCB-containing caulk in 

14% of 95 buildings at concentrations of 0.57 ppm to 82 ppm. In Toronto, institutional and 

commercial buildings and infrastructure (e.g., bridges and parking lots) made of concrete were 

most likely to have PCB-containing caulk. They detected PCB in caulk in one single family 

detached home. As expected, they did not detect PCBs in caulk in buildings built before 1945 or 

after 1980. Based on the number of concrete institutional and commercial buildings built 

between 1945 and 1980, the size of the buildings, the amount of caulk in a typical building, the 

percentage estimated to have caulk, and the average concentration of PCBs in caulk, the authors 

estimated 13 metric tons of PCBs are in caulk in Toronto. The authors further estimated that up 

to 9% of the PCBs in caulk had been lost via volatilization. The observed congener pattern is 

consistent with volatilization of lower chlorinated congeners and comparative enrichment of 

higher chlorinated congeners (Robson et al. 2010). 

There was also a study of PCB in caulk in the San Francisco Bay area as part of implementing 

the TMDL (Klosterhaus et al. 2011, 2014). This report estimates PCBs in buildings and how 

much is released to runoff during renovation and demolition. PCBs were detected in 88% of the 

25 samples from 10 buildings. The concentrations ranged up to 220,000 ppm (22%) with 40% of 

the samples exceeding 50 ppm. The median and range were similar to the studies in Boston and 

Switzerland. The mid-range estimate was 10,500 kg of PCBs in caulk in existing buildings, using 

a similar method as was used in the Puget Sound Study (Ecology 2011b, Klosterhaus et al. 2011, 

2014). Information on the number of renovations and demolitions in the San Francisco Bay area 

each year was used to estimate that 0.04 kg PCB is released each year to stormwater from 

renovation and demolition. Washington does not have information on the number of commercial 

buildings of that age and construction type that are renovated or demolished each year. 

As part of the Lower Duwamish Waterway (LDW) cleanup in Seattle, Science Applications 

International Corporation (SAIC) investigated PCBs in old caulk and paint in the LDW (SAIC 

2011). This was part of an effort to find additional sources of PCBs in the cleanup area, 

especially since high levels of PCBs in paint, caulk, and other building materials had been found 

at the former Rainier Brewery and North Boeing Field. They detected Aroclors in 8 of 17 

composite caulk samples from representative buildings with detected concentrations from 3 to 

920 mg/kg. The focus was on industrial buildings from 1950-1977. As expected, they did not 

find PCBs in a sample from buildings built in the 1940s. Surprisingly, they reported another 

building in the Seattle area that was built in 1989 and contained PCBs in caulk up to 1000 

mg/kg. The use of PCBs in caulk in North America has not been reported this late. The number 

of samples with detectable PCBs (47%) is in agreement with the larger comprehensive study in 

Switzerland (Kohler et al. 2005). 
58

Estimate in Washington 

The report on sources of toxic chemicals released in the Puget Sound Basin (Ecology 2011b) 

estimated 59 metric tons of PCBs are in building sealants in that area with about 110 kg released 

annually. This estimate was based on the number of existing masonry commercial buildings that 

were built between 1945 and 1980, the average size of those buildings and the distribution of 

PCB concentrations in caulk found in the more comprehensive survey by Kohler et al. (2005). 

This is likely to underestimate the amount of PCBs in sealants because it does not consider all 

uses in buildings, such as around windows, uses in residential buildings, or in other structures, 

such as bridges and sidewalks. The annual release estimate was based on a release rate 

coefficient of 0.0018/yr from long term loss rates in Robson et al. 2010.

The estimate for the Puget Sound Basin was based on detailed information about buildings in 

Pierce and Snohomish Counties and then scaled up to the rest of the study area by population. 

The estimated volume of masonry buildings built from 1945 to 1980 in Pierce and Snohomish 

Counties was 21,941,562 m3. To estimate PCBs in caulk for the state we scaled up the volume of 

masonry commercial buildings that were built between 1945 and 1980 by population, leading to 

an estimate of 97,702,645 m3 with 5,373,645 kg of caulk for the state. 

The large study in Switzerland (Kohler et al. 2005) found 48% of the targeted buildings had 

PCB- containing sealants. Applying this to the state estimate on sealants leads to 2,573,976 kg of 

PCB-containing sealants. The PCB concentration ranges from Kohler et al. (2005) were applied 

to the estimated mass of PCB-containing sealants in Washington, yielding an estimate of 87 

metric tons of PCBs in sealants in Washington with 157 kg released annually (Table 17). 

Table 17. Estimates from caulk

sealant 

quantity 

(kg)

sealants 

with PCBs 

(kg)

PCB conc 

bin (mg/kg)

bin mid 

point

% for 

each 

bin

PCB quantity 

(kg)

Annual 

releases 

(kg)

5,373,645 2,573,976 20-50 35 0.121 11

50-100 75 0.0772 15

100-1,000 550 0.1899 269

1,000-10,000 5,500 0.1815 2,569

10,000-

100,000 55,000 0.2316 32,787

>100,000 100,000 0.2003 51,557

Total 1.0 87,208 157

In addition, PCBs are released into the environment during renovation and demolition of 

buildings that contain PCBs in caulk and other building materials. In order to estimate this we 

need to know how many buildings of that age and construction type are demolished or renovated 

in the state, which we do not know. 
59

Opportunities for Reduction 

• Status quo

o PCBs may be found and remediated during source identification efforts. 

• Require removal or remediation of all PCB containing caulks, statewide.

• Develop best practices for demolition and renovation.

• Investigate the status of PCB containing materials in schools.

• Remove or remediate PCB-containing caulk in schools.

• Partner with EPA and federal facilities to identify and remove caulk and other PCBcontaining materials. 

Many schools in Washington were built when PCBs were used in caulk, lighting ballasts, paint, 

and other building materials. EPA has information on PCBs in caulk and other building materials 

that includes how to test for PCBs and how to safely remove PCB-containing materials 

(http://epa.gov/pcbsincaulk/index.htm). Their outreach has been focused on schools, due to the 

sensitivity of developing children. There are reports of methods for removing PCBs where more 

than 99% of the PCBs in caulk were captured following the use of BMPs specifically aimed at 

preventing PCB releases (e.g., Sundahl et al. 1999). 

Caulk, other building materials, and other historic uses of PCBs are found on Navy vessels and 

other military equipment (EPA 2006). This is an opportunity for Ecology to partner with EPA 

and federal facilities to expand PCB source identification and removal activities.

Inadvertent generation in new products

PCBs are no longer intentionally manufactured in the U.S. and the manufacture, processing, and 

distribution in commerce of PCBs at concentrations of 50 ppm or greater is not allowed. EPA 

promulgated a rule under TSCA in 1984 for inadvertent generation of PCBs that are not in closed 

or controlled manufacturing processes (49 FR 28172). The concentration of inadvertently 

generated PCBs in products must have an annual average of < 25 ppm, with a maximum of 50 

ppm. In addition, EPA required manufacturers with processes inadvertently generating PCBs and 

importers of products containing inadvertently generated PCBs to report to EPA any process or 

import for which the PCB concentration is greater than 2 mg/kg for any resolvable PCB gas 

chromatographic peak. More details on TSCA are in the section on Regulations. 

As part of this rulemaking on inadvertently generated PCBs, EPA generated a list of 200 

chemical processes with a potential for generating PCBs (Appendix D) and narrowed it to 70 

with a high potential to inadvertently generate PCBs. The list does not include every process that 

inadvertently generates PCBs and not everything on the list inadvertently generates PCBs. In 

general, PCBs can be produced when chlorine and carbon are present with elevated temperatures 

or catalysts. 
60

The final rule also includes an estimated annual production of inadvertently generated PCBs of 

100,000 lbs (45,400 kg). Scaled to population, Washington’s share of that would be about 900 kg 

a year. Only 11% of the PCBs were estimated to enter products, or 100 kg annually in 

Washington. As the economy has grown over the last 30 years, the amount of inadvertently 

generated PCBs may also have grown. The 100,000 lbs was an estimate from a consensus 

proposal from the Environmental Defense Fund, Natural Resources Defense Council, and 

Chemical Manufacturers Association (now known as the American Chemistry Council) that 

included all inadvertent generation of PCBs, without being broken down into how much came 

from each process. Products that are mentioned include paints, printing inks, agricultural 

chemicals, plastic materials, and detergent bars. The 1982 economic analysis for this rule 

mentions 135 manufacturing processes that generate PCBs at less than 50 ppm from a Chemical 

Manufacturers Association survey. The economic analysis also includes a list from EPA of about 

20 “end-products of manufacturing processes in which PCBs are incidentally generated.”

In their rule on inadvertent production, EPA specifically mentions surfactants as the component 

of detergent bars that is likely to contain PCBs. EPA also mentioned PCBs are likely to be in 

surfactants in skin lotions and creams that are regulated by the FDA. We have no estimate for 

how many PCBs are inadvertently produced in surfactant. 

Reports to EPA on inadvertent generation

As mentioned above, the 1984 rule under TSCA (49 FR 28172) requires manufacturers to report 

inadvertent generation of PCBs. There are 77 reports for inadvertently generated PCBs from 

1994 to present (Table 18). Some information on each report is in Appendix E. There are 

additional reports included in the docket for related topics, such as requests to produce small 

amounts of PCBs for research purposes. A lot of the information in the reports has been redacted 

to remove confidential business information (CBI). In general the reports repeated the federal 

requirements while stating the company is in compliance and without giving specific information 

about the concentration of PCBs in the products or the total amount of the products. None of the 

reports were for facilities in Washington State. 

Many reports include a statement that the materials may contain PCBs > 2 ppm, but likely do not 

and the reporter was being very conservative in reporting anything that might contain PCBs > 2 

ppm. The reports assert that no products contained more than 50 ppm or more than 25 ppm for 

an annual average (which are the limits in rule). 
61

Table 18. Reports to EPA on inadvertent generation 1994-present

Chemical or process Number of reports

Pigments and dyes 53

GE silicones 8

Vinyl chloride production 3

Unique 6

Unknown 7

Total 77

Some of the reports in Table 18 in the category of pigments and dyes list individual pigments 

(yellow, red, green, blue violet and orange with Color Index (CI) numbers), some include a 

general description such as “imported dyes,” while others do not include any specific 

information, but come from a division of the company such as the “Pigments Division.” 

Eight reports are from GE Silicones. There is no additional information on the products. 

There are three reports from three different companies regarding vinyl chloride production, one 

of which was a unique incident involving diesel contamination. Geon stated they are reporting on 

740 lbs of PCBs in 62,676,000 lbs of chemical feedstocks used in a vinyl chloride monomer 

manufacturing facility in Texas. The third report is for incidental PCBs generated in the 

chlorination step of a process stream to remove an impurity. 

There are six reports from six different companies on unique compounds or processes. These 

reports are for trichlorobenzene manufacture, 2,4,6-Trichlorophenylhydrazine (2,4,6-TCPH), 

2,6-Dichloro-4-Nitro Aniline, a pesticide intermediate, chlorothalonil production process, and 

one report for electrical capacitors. The one report for electrical capacitors also included the 

information that PCBs were at 3.9 ppm in 134 liters. The report on 2,4,6-

Trichlorophenylhydrazine stated the concentration was usually 9-12 ppm. 

Seven reports were for unknown compounds or processes. Four of these were completely 

redacted with a place holder stating there was a report. Two reports redacted the name of the 

company in addition to the compounds. One report was for two containers of a non-PCB product 

with 4 and 5 ppm PCBs. 

Pigments and dyes

More details on generation of PCBs during manufacturing are provided in the earlier section on 

Chemistry. PCBs are known to be inadvertently generated in certain pigments and dyes, 

including diarylides (yellow and orange), naphtharylamides (oranges and reds), phthalocyanines 

(blue), and basic dye complex pigments (reds, violets, blues and greens) (Christie 2013). PCB-11 

is thought to be primarily from pigment production and not from legacy uses of Aroclors (Hu 

and Hornbuckle 2010, Guo et al. 2014), and so is useful as an indication of inadvertent 
62

generation of PCBs, especially from pigments. Specifically, the ratio of PCB 11 to a 

characteristic dechlorination end product, PCB-4, indicates that dechlorination is not a 

significant source of PCB 11 where it has been examined (Rodenburg et al. 2010). PCB-11 has 

been seen to be strongly correlated with PCBs 35 and 77 (Rodenburg 2014). PCB-77 is one of 

the dioxin-like congeners.

Hu and Hornbuckle (2010) found PCBs in azo and phthalocyanine pigments, including PCB-11 

and higher chlorinated PCBs 206-209. Previously PCB-209 was only thought to be found in 

ferric oxide as a by-product of titanium dioxide production (Panero et al. 2005). PCB-11 and 

PCB-209 have been found in Washington’s environment and animals (Ecology EIM database). 

Higher chlorinated PCBs are inadvertently generated during the production of the inorganic 

pigment titanium dioxide using the chlorine process (UNEP 2007). We were unable to locate 

estimates on the amount of PCB inadvertently generated in this process. 

PCBs have been detected in general consumer products purchased in Washington. Individual 

congeners were detected between 1 and 45 ppb. Four congeners known to be associated with 

pigments (PCB 11,206,208, and 209) were selected for the initial study and were tested for in 74 

samples from 68 products (Ecology 2014). The products included packaging, paper products, 

paint and colorants, and caulk. Ecology is in the process of reporting on the results of all the 

congeners for the same samples. As in previously published work (Hu and Hornbuckle 2010), we 

also see a wide selection of congeners in the consumer products. 

Estimate in Washington 

While different researchers have detected PCBs in pigments and consumer products, we don’t 

have a good estimate for how much is released in Washington each year. Panero et al. (2005) 

estimated PCB-11 represents 5-20% of the PCBs entering NY harbor. Guo et al. (2014) 

estimated that between 5 and 7800 kg11 of PCB-11 are produced worldwide each year from 

diarylide yellow in 2006. The US market consumes approximately 20% of global organic 

pigments (Guo et al. 2014). Washington is approximately 2% of the US population, which leads 

to an estimate for Washington’s share of PCB-11 from yellow pigment of 0.02 and 31 kg per 

year. This is the amount of PCB-11 in products, with an unknown amount entering the 

environment. 

The Color Pigments Manufacturers Association (CPMA) estimated that the total annual amount 

of these pigments (phthalocyanine and diarylide) imported or manufactured in the US is about 90 

million lbs (41,000 metric tons). They further estimated inadvertently generated PCBs in these 

pigments with an upper bound of 1.1 tons per year and a more reasonable estimate of 1000 lbs 

 11 Jia Guo is an author on an earlier paper (Rodenburg et al. 2010) that estimated worldwide production of PCB 11 

from diarylide yellow pigment production at 1.5 t in 2006. This estimate was revised in Guo 2013 and Guo et al. 

2014. 
63

per year (CPMA 2010). Using the lower annual estimate of 1000 lbs (450 kb), leads to an 

estimate of 9 kg per year in Washington, that is within the range of the estimate above. 

There are permitted releases in Washington State that are pathways for PCBs to get from sources 

such as pigments in paper and other consumer goods into waterways. Looking at the PCBs in 

these permitted pathways illustrates that some PCBs from pigments are released in Washington, 

even thought the permittees are not the source of the PCBs. Paper mills that recycle paper and 

municipal wastewater treatment plants discharge small amounts of PCBs into Washington 

waterways. In 2012 the average PCB concentrations in the discharge of two paper recycling 

mills were 2,520 and 1079 pg/L, respectively. Based on flow rate, the estimated PCB loading for 

these two facilities is 28 g per year, with 3.8 g being PCB-11. It is suspected that dyes from 

clothing and other consumer products such as soaps, lotions, and creams are also contributing 

PCBs to municipal wastewater treatment plants. For example, the Spokane River Source 

Assessment (Ecology 2011c) estimated that the Spokane waste water treatment plant was 

discharging 194 mg of PCBs/day.

Opportunities for Reduction 

Inadvertent generation 

• Status quo

o Continue to permit products containing less than 50 ppm (with discount factor for monoand bi-chlorinated biphenyls- see Regulations section) to be sold in Washington. 

o Implement RCW 39.26.280- Preference for PCB free products by state agencies.

• Assess alternatives for pigments and dyes to identify the availability of safer materials. 

• Encourage businesses to use alternate processes/materials that do not generate PCBs. 

• Conduct research using green chemistry to develop new processes that do not inadvertently 

generate PCBs. 

• Test products to determine the extent of PCBs in products likely to contain PCBs.

• Require labeling to educate consumers on what products contain PCBs and which ones do 

not. 

• Petition EPA to revise the federal regulatory limit on PCBs in products to align with the 

federal Clean Water Act.

There are many processes that might inadvertently generate PCBs, but not much is known about 

most of them. If the state doesn’t make progress in reducing inadvertent generation of PCBs, 

permitted facilities might be forced to close or eliminate environmentally beneficial processes 

(such as recycling), which are undesired outcomes.
64

Commercial and industrial releases

Toxics Release Inventory (TRI)

The federal Toxics Release Inventory (TRI) includes permitted estimated releases from facilities 

that discharge from certain industries. The TRI database is authorized under the federal 

Emergency Planning and Community Right to Know Act to aid in community planning in case 

of an emergency and to generally inform the public about releases of toxic chemicals. 

PCBs are subject to reporting and listed with the general CAS number 1336-36-3 for all PCBs. 

Because PCBs are PBTs, there is a lower level for reporting and the reporting threshold is 10 lbs. 

There are only two reporters of PCBs in Washington on the TRI. Burlington Environmental in 

King County and Perma-Fix Northwest in Benton County are both hazardous waste treatment 

and disposal companies. From 2007-2011 they reported an average off-site waste disposal of 

25,000 pounds (Table 19). 

Table 19. Table of TRI reports from 2007-2011

Year Reporter Offsite waste 

reported (pounds)

2007 BURLINGTON ENVIRONMENTAL 

INC 485

2007 PERMA-FIX NORTHWEST 

RICHLAND INC. 14,163

2008 BURLINGTON ENVIRONMENTAL 

INC 389

2008 PERMA-FIX NORTHWEST 

RICHLAND INC 710

2009 BURLINGTON ENVIRONMENTAL 

INC 565

2009 PERMA-FIX NORTHWEST 

RICHLAND INC 11,869

2010 BURLINGTON ENVIRONMENTAL 

INC 1,081

2010 PERMA-FIX NORTHWEST 

RICHLAND INC 61,554

2011 BURLINGTON ENVIRONMENTAL 

LLC 1,000

2011 PERMA-FIX NORTHWEST 

RICHLAND INC 31,543
65

National Emissions Inventory (NEI)

The National Emissions Inventory (NEI) is a comprehensive and detailed estimate of air 

pollutants from all air emissions sources. The NEI is prepared every three years by the EPA 

based primarily upon emission estimates and emission model inputs provided by State, Local, 

and Tribal air agencies for sources in their jurisdictions, and supplemented by data developed by 

the EPA. According to the most recent NEI for 2008, there were 439 lbs (199 kg) of PCBs 

released to the air in Washington State from residential waste burning and 0.8 lbs (0.4 kg)

released from commercial marine vessels. In addition to these sources, the Spokane Regional 

Clean Air Agency reported about 1 lb of PCB emitted from the Waste to Energy facility in 2011.

To obtain emission estimates for residential waste burning, EPA applies emission factors to an 

assumed mass of residential waste burned at the county level across the country. Some of the key 

assumptions are that residential waste burning only occurs in rural counties, and roughly 28% of 

the waste generated in these counties is burned in backyard burn barrels. This estimate is very 

uncertain, but can only be improved with location specific information regarding local 

compliance with residential waste burning rules. 
66

Summary 

Table 20 below summarizes the estimates for uses and sources in Washington State found in this 

section. 

Table 20. Summary of Uses and Releases for Washington State 

Source Historic

reservoir 

Annual releases 

(kg/yr)

Closed

transformers 100-200 kg < 2

large capacitors 20 metric tons 10-80

lamp ballasts 100-350 metric 

tons 400-1,500

small capacitors 1-34 metric 

tons 3-150

other closed uses unknown

Partially closed unknown

Open 

caulk 87 metric tons 160

other open uses unknown

pigments and dyes (PCB-11) 0.02-31

other inadvertent 

generation 900

residential waste burning 199

commercial marine 

vehicles 0.4
67

Pathways and Environmental Fate

Current PCB levels represent both historical and ongoing loadings and cycling among 

environmental compartments. We consider sources to be the original use of the material, such as 

PCBs in transformers. PCBs move through pathways such as stormwater and expose people and 

wildlife. 

Unfortunately, we don’t know where much of the PCBs that were produced prior to 1979 are 

currently located. For example, small capacitors used large amounts of PCBs, but since they 

were used in unregulated appliances, we don’t know how many are still in appliances in people’s 

homes, how many were disposed of in municipal waste landfills (and how much PCBs have 

since leaked out of those landfills or volatilized), and how many were disposed of outside of 

landfills. 

Pathways 

Assessments of both Puget Sound (Ecology 2011a) and freshwater systems (Ecology 2011c, 

King Co 2013b) have found the largest pathway for PCBs to reach the aquatic environment

statewide is stormwater. Figure 12 shows the estimated loadings to Puget Sound by pathway 

(Ecology 2011a) and Figure 13 shows the relative stormwater loadings by type of land cover. In 

the Puget Sound study, we looked at the concentration of PCBs and other chemicals in surface 

runoff from four land-cover types: commercial/industrial, residential, agricultural, and forest, 

field, and other undeveloped lands. The concentration of PCBs in surface runoff was higher from 

commercial/industrial areas, especially during storm events, but the total loading was lower since 

industrial/commercial lands occupy less area than other land covers. Overall loads from forests 

accounted for 83% of the load (Ecology 2011g). 
68

Figure 12. Total estimated PCB loading to Puget Sound by pathway (kg/yr)

Figure 13: Relative contributions of different land use covers to PCBs in surface runoff in Puget 

Sound (Ecology 2011g)

0

5

10

15

20

25

25th %ile Median 75th %ile

Total PCBs (kg/yr)

POTWs

Surface 

Runoff

Air 

Deposition

Forest/Field/Other

83%

Agricultural

4%

Residential

7%

Commercial/Industrial

6%
69

Figure 14 shows the relative importance of different pathways in three freshwater systems in 

Washington. Publically owned treatment works (POTWs) are a smaller pathway in all the 

systems, with less than 10% of total loading. Direct air deposition was estimated to be the second 

largest pathway in the Puget Sound and Lake Washington study (Ecology 2010d, King County 

2013b).There is a large and variable amount of PCB loading from unknown pathways. 

Figure 14. Relative importance of pathways assessed in freshwater systems 

Salmon 

Pacific salmon returning to spawn are another pathway for PCBs to enter Washington. Salmon 

have complex life histories and long-range migrations for feeding. The accumulation of PCBs in 

fish depends on many things including contaminated habitats, which food they eat and the levels 

of PCBs in food, lipid level, and age. Chinook salmon are 3-5 times more contaminated than 

coastal Chinook (West 2011). Most (99%) of the final weight of adult Chinook is achieved in 

salt water, both ocean and Puget Sound, and >96% of the PCBs in adult Chinook accumulated 
70

during their marine life history phase (O’Neill and West 2009). O’Neill estimated that 0.265 

kg/yr PCBs enters Washington through this pathway (Ecology 2011a). This estimate comes from 

whole body PCB concentrations for five species of Pacific salmon and their estimated biomass. 

Motor oil

The City of Spokane reported measurements of PCBs in motor oil in their 2013 Adaptive 

Management Plan for Reducing PCBs in Stormwater Discharges from the Wastewater 

Management Department. The concentration of total PCBs in four samples of motor oil ranged 

from 14 to 116 ppb with an average of 54 ppb. In the PAH CAP (Ecology 2012a), Ecology 

estimated that 9,737,812 kg of motor oil is released annually in Washington from drips and leaks 

and another 1,555,179 kg of used motor oil is released to the environment through improper 

disposal. Using the average concentration of PCBs in motor oil from sampling in Spokane (54 

ug/kg) and the statewide estimate of drips and leaks from motor vehicles and improper disposal 

of used motor oil in Washington (11,292,991 kg), gives an estimate of 0.6 kg of PCBs per year 

from motor oil.

PCBs are not created in motor oil, so motor oil is not considered a source here. The PCBs in 

motor oil are likely contamination from an unknown source. The homologue pattern is different 

from the PCBs found in sediments from stormwater catch basins in Spokane, with a much larger 

percentage of mono and dichlorobiphenyls and smaller percentage of higher chlorinated 

congeners. Of course, the congeners in sediment have been weathered and would no longer 

match the profile of the original source. 

Environmental Partitioning

The estimates we do have for the fate of all the PCBs produced are not current. Newer 

publications cite estimates in earlier publications. These estimates vary, but they agree that much 

of the PCBs that were produced up to 1979 are still in use. This is a large reservoir of PCBs that 

are slowly leaking out into the environment. For transformers in particular, we know that much 

of the PCBs in transformers have been removed since these estimates were made. Transformers 

and capacitors were the largest use of PCBs and have been targeted for PCB removal. 

In 1997 EPA estimated the inventory of PCBs as of 1977 as “Of the 700,000 [short] tons of 

PCBs produced, 150,000 tons had been landfilled; 75,000 tons had entered the air, water, and 

soil; 25,000 tons had been incinerated; and 375,000 tons remained in electrical equipment. The 

remainder, approximately 75,000 tons, had been exported.” 

Converting this 1997 EPA estimate of short tons into metric tons leads to:

• 636,000 Produced (1927-1976)

• 568,000 Used (68,000 exported)
71

• 340,000 Remaining in use (60%)

• 228,000 Disposal/environment

• 132,000 Landfill (23%)

• 68,000 Environmental media (12%)

• 28,000 Incinerated (5%)

Table 21 shows estimates for the status of PCBs. The estimates in Keeler (1993) for the status of 

PCBs in the US as of 1982 are similar to those of the EPA above. The Canadian government 

estimated PCBs in Canada as of 1992 (CCME 1995) and Tanabe (1988) estimated similar 

percentages worldwide in 1985 (Table 21). All of these estimates include a large percentage of 

PCBs still in use and a small percentage destroyed by incineration. Unfortunately, we do not 

have more current estimates of PCB stocks and many of the PCBs that were in use at the time of 

these estimates have been taken out of use for disposal. 

Table 21. Estimates for the status of PCBs (in metric tons)

Status US 1977

(EPA 1997)

US 1982

(Keeler et al 1993)

Canada 1992

(CCME 1995)

Global 1985

(Tanabe 1988)

Produced 636,000 640,000 1,200,000

Used 538,000 582,000 (91%) 40,000 1,200,000

Remaining in Use 340,000 (40%) 346,000 (54%) 15,000 (38%)

780,000 (65%)

Landfill/Storage 132,000 (23%) 134,000 (21%) 6000 (15%)

Environment 68,000 (12%) 70,000 (11%) 12,400 (31%) 370,000 (31%)

Incinerated 28,000 (5%) 19,000 (3%) 6,200 (16%) 50,000 (4%)

Tanabe (1988) also broke down the global PCBs in the environment into different media (Table 

22). Not shown in Table 22 is that the largest global reservoir of PCBs is ocean water (while 

PCBs are not very soluble in water, the vast quantities of oceans worldwide hold more than half 

of the PCBs in the environment). Table 22 only includes estimates from the terrestrial and 

coastal waters and not ocean water. 

Table 22. Global PCBs from Tanabe 1988 for PCBs on land, rivers and coastal waters

PCB loads

(metric tons) percent

air 500 0.35

river and lakewater 3,500 2.45

seawater 2,400 1.68

soil 2,400 1.68

sediment 130,000 90.85

biota 4,300 3.00

Total 143,100 100
72

The estimates from Tanabe 1988 in Table 22 agree well with the model for Puget Sound 

(Ecology 2009b) and Lake Washington (King County 2013). For Puget Sound it was estimated 

approximately 97% (1440 kg) of the total mass of PCBs currently in the aquatic ecosystem of 

Puget Sound is contained in the active sediment layer (top 10 cm), <1% (10kg) is stored in the 

water column, and <3% (40 kg) is stored in the biota. O’Neill and West (2007) estimated PCBs 

in biota using PCB concentrations and biomass. Their total estimate is less than 40 kg of PCBs in 

Puget Sound biota.
73

Wildlife Health 

Introduction 

PCBs have similar effects in wildlife, people, and model organisms used to study people in 

laboratory experiments. Thus, this section and the section on Human Health have many 

similarities, although the health effects that are measured often differ between people and 

wildlife. Negative effects of PCBs in wildlife are of concern because of the effects on animal 

populations, because animal populations may be sentinels for human health, and because we are 

also part of the food chain and are exposed to PCBs through our diet. 

PCBs can be acutely toxic to wildlife, but most of the impacts occur due to chronic exposure. 

Data are most prevalent on mortality, reproduction, development, and endocrine effects. In 

addition to toxicity endpoints, the induction of enzymes and genes are also used to assay PCB 

effects. Other endpoints include cancer, immunological, neurological/behavioral, and hepatic 

effects. Experimental studies are often performed for certain endpoints because of correlations 

seen in the field with PCB levels and specific endpoints. 

Wildlife is exposed to varied mixtures of PCBs in the environment. Different PCB congeners 

behave differently in the environment; they preferentially partition into different media and they 

are preferentially degraded and bioaccumulated. In addition, there are multiple sources of PCBs 

that contain different mixtures of congeners that release PCBs into the environment. Therefore, 

the actual environmental conditions are different than many of the laboratory studies on specific 

Aroclor mixtures or specific congeners. 

Sensitivity to PCBs varies among species and within species. For example, fish are most 

susceptible in early life stages. Inter-species variation is also due to different lipid levels, because 

PCBs are lipophilic and sequestered in lipid-rich tissues. PCBs are biomagnified up the food 

chain, so organisms on higher trophic levels have higher concentrations of PCBs. There are other 

differences among species that affect PCB metabolism. For example, invertebrates lack the 

enzyme systems that react with dioxin-like PCBs.

Although environmental levels of PCBs have declined substantially since they first came under 

regulation in the 1970s, the rate of decline has slowed in recent years and significant 

contamination continues to be widespread in Washington State..

Puget Sound is a regional hot spot for PCBs compared to the Pacific coast and British Columbia. 

Within Puget Sound, the most contaminated areas are in the main basin, especially Seattle’s 

Elliott Bay and Tacoma’s Commencement Bay, and, to a lesser extent, Everett Harbor and the 

Bainbridge Basin. Puget Sound’s food web, from plankton on up to harbor seals and killer 

whales, has significant PCB contamination. Herring and Chinook salmon are notably affected. 
74

Hot spots for PCBs are also present in Washington rivers and lakes. Based on PCB levels in 

resident fish species, major waterbodies of most concern are the Wenatchee River, Lake 

Washington, the Columbia River, and the Spokane River.

Health effects in wildlife

Table 23 (from ATSDR 2000) summarizes PCB effects seen in laboratory experiments and field 

studies with wildlife species. Most species have mortality at high doses. 

Adverse effects in birds include: 

• Reduced egg hatchability and live births

• Reduced avoidance response

• Altered mating, reproductive, parenting, and nesting behavior

• Suppression of immune response 

Adverse effects in fish include:

• Reduced hatchability in eggs

• Altered muscle coordination

• Depressed immune system with increased susceptibility to infections

• Loss of fins and tails in flatfish

Adverse effects in mammals include: 

• Loss of embryos and fetuses and reduced live births

• Alteration in the immune system in mink, sea lions, and seals

• Tumors and deformities of skeleton and skin in seals
75

Table 23. PCB Hazards in Wildlife with references noted in original (ATSDR 2000 Table 3-6)

Adverse effect Wild mammals Birds Reptiles Amphibians Fish

Primate Mustelid Cetacean, 

pinniped Other Piscivore Galliform Other Turtle Frog Toad Freshwater Marine

Mortality OE1 OE1 OE3 OE3 OE1 OE3 OE1 OE1 OE1 OE3

OE3 OE3 OE3 OE3 OE2

OE4 OE3

Systemic effects

Respiratory OE4 OE3 OE3

Cardiovascular

OE3 OC4 OE3

OE4

Gastrointestinal

OE1 OE1 OC4 OE3

OE3

Hematological OE4 OE3

Musculoskeletal OE3 OE3

Hepatic

OE3 OE1 OE3 OE1 OE1 OE3 OE3

OE3 OE2 OE3

OE4 OE3

OE5 OE5

Renal OE4 OC4 OE3 OE3

Endocrine

OE3 OE3 OE3 OE3 OE3 OE1 OE3 OE3

OE4 OE4 OC4 OE3

OE5 OC4

Dermal/ocular

OE1 OE3 OC4 OE3

OE3

Body weight

OE1 OE1 OE2 OE1 OE3 OE3

OE3 OE3

Metabolic OE5 OE1 OE2 OE3
76

Adverse effect Wild mammals Birds Reptiles Amphibians Fish

Primate Mustelid Cetacean, 

pinniped Other Piscivore Galliform Other Turtle Frog Toad Freshwater Marine

Enzyme induction

OE1 OE1 OE1 OE1 OC4

OE3 OE2 OE2 OE3

OE4 OE3 OE3

OE5

 Blood chemistry OE1 OE5 OE3 OE1 OE3

Immunological/ 

lymphorecticular

OE1 OE4 OE4 OC4 OE1 OE1 OE3 OE3

OE3 OC4 OE3 OE3

Neurological/ 

behavioral

OE2 OE2 OE3 OE3 OE3 OE2 OE3

OE3 OE4 OE3

Reproductive

OE3 OE1 OC4 OE3 OC4 OE3 OE1 OC4 OE3 OE3

OE3 OE4 OE3 OC4 OC4

OE4

OE5

OC4

Developmental

OE3 OE3 OE3 OE1 OE1 OE4 OE1 OE1 OE3

OE4 OC1 OE3 OE3 OE3 OC4

OC4

Egg shell

OC4 OE3 OE3

OC4

Genotoxic OE3

O= observed effect E= experimental observation C= correlational field observation 

1 = dioxin-like PCB congener (AhR binder; planar; chlorine para-substituted and non- or mono-ortho-substituted)

2 = non-dioxin-like PCB congener (poorly binds to AhR; non-planar; chlorine di-, tri-, or quatro-ortho-substituted)

3 = commercial PCB mixture (e.g., Aroclor 1016)

4 = “weathered” (i.e., environmentally degraded and/or metabolized) PCB mixture, usually in combination with other chemicals (e.g., PCBs in wildcaught fish)

5 = unspecified PCB
77

Examples of major endpoints 

Reproduction and development 

PCBs affect reproduction and development in different species. Mink are particularly sensitive to 

the reproductive effects of PCBs (Eisler 1986). Farm-raised mink fed a diet of PCBcontaminated fish from the upper Hudson River at the same levels wild mink are exposed to 

PCBs in food, showed effects on reproduction and offspring growth and mortality (Bursian et al. 

2013). Females with higher levels of PCBs had fewer live kits per litter. Kit mortality increased 

over time, with no kits surviving in the animals fed higher levels of PCBs. The surviving kits 

also had lower body masses after 6 weeks. The effects on reproductive performance were similar 

to those seen in earlier studies on mink fed contaminated fish from Saginaw Bay (Heaton et al. 

1995a). 

Immune System

PCBs are linked to increased disease susceptibility in several species. Captive harbor seals 

exhibit negative effects on their immune system after being fed PCB-contaminated herring, as 

assayed by immune cell function and response (Ross et al. 1996). This research was undertaken 

to understand factors contributing to virus-caused mass mortalities of marine mammals, 

especially when attributed to a virus that does not always cause mass mortalities. The results 

suggest higher levels of PCBs contribute to higher virus-caused mortality. 

Cancer

PCBs have been shown to cause cancer in laboratory animals (ATSDR 2000) and are considered 

to be probable human carcinogens by EPA. PCBs are thought to cause cancer indirectly, rather 

than by direct alterations to DNA. 

Cancer is less well studied in wild populations compared to laboratory species, partly due to 

lower incidence. However, beluga whales in the St. Lawrence estuary and Hudson Bay have 

been found to have a high incidence of cancers and high levels of PCBs (Mikaelian et al. 2003). 

There is also evidence linking cancer in St. Lawrence estuary belugas to PAHs from nearby point 

sources (Martineau et al. 2002), illustrating the difficulties in pointing to a specific group of 

chemicals in these marine mammals with many different industrial contaminants. PCB levels in 

California sea lions have also been found to be significantly associated with death from cancer 

(Ylitalo et al. 2005). 

Mechanisms of action

Endocrine 

PCBs interfere with estrogen and thyroid hormone levels. Studies on PCB endocrine disruption 

have been done in the laboratory with model animals and cell cultures (see section on Human 

Health). The endocrine system regulates all biological processes, although endocrine disruption 
78

is often used just to refer to the disruption of thyroid hormones and the sex hormones estrogen 

and androgen. These hormones are important for growth and development, especially of the 

brain and nervous system and reproductive systems. While hormones are important throughout 

the life cycle, they are particularly important during fetal development. Hormones are signaling 

molecules that function at low levels, and compounds that either mimic or block natural 

hormones may have effects at low levels. 

Ah-receptor dependent

Similar to dioxins, non-ortho (co-planar) and mono-ortho PCBs can bind to the aryl hydrocarbon 

(Ah) receptor. Subsequent to binding of the Ah receptor, there are changes in gene expression 

(e.g., induction of cytochrome p450 CYP1A1/1A2) leading to toxic responses. Induction varies 

by degree and pattern of chlorines and is the basis for the World Health Organization (WHO) 

toxic equivalency factors (TEFs) for dioxins and dioxin-like PCB congeners. These have been 

reviewed and modified several times. In 2005 WHO updated the TEFs for humans and mammals 

to replace the 1998 values (Van den Berg et al. 2006, see Table 29 in the Human Health 

Section). The adverse effects for these compounds are mediated through the Ah receptor and the 

relative potencies are compared to 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). Consensus 

TEFs for wildlife were developed in 1998 (Van den Berg et al. 1998). The WHO working group 

harmonized the TEFs across different taxa as much as they could, but there are large differences 

in responses among different taxa. 

Table 24. WHO TEFs for fish and birds (Van den Berg et al. 1998)

Type Congener

TEFs

Fish Birds

Co-planar PCBs 

3,3',4,4'-TCB (77) 0.0001 0.05

3,4,4',5-TCB (81) 0.0005 0.1

3,3',4,4'-5-PeCB (126) 0.005 0.1

3,3',4,4',5,5'-HxCB (169) 0.00005 0.001

Mono-ortho PCBs

2,3,3',4,4'-PeCB (105) <0.000005 0.0001

2,3,4,4',5-PeCB (114) <0.000005 0.0001

2,3',4,4',5-PeCB (118) <0.000005 0.00001

2',3,4,4',5-PeCB (123) <0.000005 0.00001

2,3,3',4,4',5-HxCB (156) <0.000005 0.001

2,3,3',4,4',5'- HxCB (157) <0.000005 0.0001

2,3',4,4',5,5'- HxCB (167) <0.000005 0.00001

2,3, 3',4,4',5,5'- HpCB (189) <0.000005 0.00001
79

PCBs in Washington’s Environment 

Air and Soil

Due to long-range regional and global atmospheric transport, PCBs are present in all parts of the 

environment. Most of the PCBs in air come from volatilization of PCB-contaminated soil and 

surface water. In the atmosphere, PCBs are primarily associated with the gaseous phase; 

approximately 10% is adsorbed to particulates, especially the higher chlorinated forms. Less 

chlorinated compounds travel farther than highly chlorinated compounds, which tend to stay 

closer to the source of contamination. Atmospheric deposition is, in turn, the dominant source of 

PCBs to most soil and water surfaces. The cycle of persistent compounds like PCBs depositing 

onto soil and then revolatilizing back into air is often referred to as the grasshopper effect. 

PCB levels in the atmosphere have been decreasing slowly since the late 1970s when EPA began 

restricting their use (EPA Integrated Atmospheric Deposition Network 

http://www.epa.gov/glnpo/glindicators/air/airb.html, Venier and Hites 2010, ASTDR 2000). Due 

to residual sources in the U.S. and long-range transport from other countries, PCB levels in air 

may be leveling off after a period of decreasing. 

Air in rural and remote locations has lower PCB levels than urban air, which is a source to 

nearby environments. Nationally, average total PCB concentrations at background locations (not 

near known sources of PCBs) are in the approximate range of one to several hundred pg/m3

(Hornbuckle and Robertson, 2010). In contrast, concentrations near Lake Superior in the 1970s 

were well over 1,000 pg/m3 due to influences from upstate New York and the East Coast (EPA 

Integrated Atmospheric Deposition Network)

The limited data available for PCBs in Washington’s air has been from measurements of wet 

(rainfall) and dry (particulate) deposition rates to water and land surfaces (ng/m2/day) rather than 

mass per unit volume. In 2008, Brandenberger et al. (Ecology 2010d) recorded PCB fluxes to the 

Puget Sound basin at seven stations from Nisqually River to Padilla Bay. The median flux across 

all stations and rain events was 0.51 ng/m2

/day. Similar results were obtained for most areas, 

except Tacoma’s Commencement Bay had a median of 1.8 ng/m2/day. Brandenberger et al. 

concluded that PCB deposition rates to the Puget Sound basin were similar to background sites 

in New Jersey (0.82 ng/m2/day; 1999-2000), but lower than Chesapeake Bay (9.0 ng/m2/day; 

1990-1991) and Jersey City, NJ (11 ng/m2

/day; 1999). King County recently completed an air 

deposition study at six stations in the Lower Duwamish/Green River watershed (King County 

2013a). Station locations included three in the Lower Duwamish River area, two in downtown 

Kent and one in Enumclaw. Median fluxes of total PCBs ranged from 1.1 ng/m2/day in 

Enumclaw to 16.9 ng/m2/day in the South Park neighborhood of the Lower Duwamish River. 

King County has also measured air deposition to Lake Washington at one station near Sand 

Point; a median flux of 1.39 ng/m2/day was estimated from these measurements (King County 

2013b).
80

The Western Airborne Contaminants Assessment Project for national parks in the western U.S. 

included Mount Rainier, Olympic, and North Cascades parks (Landers et al. 2008). The results, 

however, are of limited use for present purposes in that only eight PCB compounds were 

analyzed and detection frequency was low.

Meijer et al. (2003) estimated that the contemporary PCB burden in background soils is about 

2% of the known production volume. PCB levels in U.S. background soils generally average 

from several hundred to several thousand ppt dry weight (Hornbuckle and Robertson, 2010). An 

EPA nation-wide survey of soil at 27 remote or rural sites in 2003 put the average total PCB 

concentration at 3,089 ppt (EPA 2007). The single Washington site sampled during the study –

Lake Ozette on the northwest coast – had 2,419 ppt.

With the exception of site-specific determinations for contaminated sites, the PCB background in 

Washington soils has not been well characterized. Relatively more is known about PCBs in 

Washington’s marine and freshwater environment, as discussed below.

Marine and Fresh Waters

Historical vs. Recent Trends

PCB levels in Washington’s marine and fresh waters have decreased substantially since peaking 

in the 1970s. This has been attributed to EPA’s restrictions and bans on PCBs in the late 1970s 

and early 1980s, similar actions in Canada and other countries, contaminated site cleanups, 

improved wastewater treatment, losses through volatilization and metabolism of lighter 

compounds, and deep burial in aquatic sediments.

Although historical declines have been documented, there are components of Washington’s 

marine and freshwater ecosystems where a decreasing trend is no longer evident. In most cases, 

the time-trend for PCBs can be characterized by an initial rapid decline after the ban, followed 

by a slowing and, ultimately, low to negligible rate of decrease over recent years, waterbodies 

benefitting from cleanups being a notable exception. Current PCB levels continue to be a 

concern for the health of fish, wildlife, and humans in Washington.

The effect of the 1970s and 1980s regulations can be clearly seen in age-dated sediment cores 

from Puget Sound and Lake Washington (Figure 15). A rapid increase in concentrations occurred 

in both Puget Sound and Lake Washington into the mid-1970s, reaching 35 ppb and 250 ppb, 

respectively, in sediments at these two locations. Concentrations in the recent past declined to 

around 10 to 20 ppb. (Detections shown prior to the mid-1930s when PCBs were first introduced 

are analytical noise.) A sediment core from Lake Spokane (lower Spokane River) in eastern 

Washington showed a similar steep decline in the 1960s and 1970s, followed by a gradual 

reduction over a 20-year period from approximately 1980 to 2000 similar to what was observed 

in Lake Washington (Ecology 2011c). 
81

Figure 15. Total PCBs in Age-Dated Sediment Cores from Puget Sound, Lake Washington, and 

Lake Spokane

NOAA’s Mussel Watch has monitored PCBs in marine mussels from the mouth of the Columbia 

River to Puget Sound since 1986. Results show that PCBs have been declining slowly, although 

somewhat erratically, in Washington’s marine waters (Figure 16). After a steep decline in the 

mid-1980s, there have been two spikes of unknown origin, most obvious at the regional hot spot: 

Four-mile Rock in Elliott Bay. PCB levels in Puget Sound mussels remain well above national 

median concentrations (Mearns 2013, O’Connor and Lauenstein 2006).

1900

1910

1920

1930

1940

1950

1960

1970

1980

1990

2000

2010

0 10 20 30 40

ppb,dry weight

Puget Sound, Central

1900

1910

1920

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1940

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1960

1970

1980

1990

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0 100 200 300

ppb, dry weight

Lake Washington, South End

1900

1913

1927

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1982

1995

2009

0 500 1000 1500

Lower Lake Spokane
82

Figure 16. Total PCB Concentrations in Marine Mussels from Columbia River to Puget Sound: 

1986 – 2010

(Data from NOAA National Mussel Watch Program, prepared by Alan J. Mearns, NOAA, Seattle)

Compared to historical levels, PCBs have declined in Puget Sound harbor seals (1972 to 1997) 

and killer whales (1993-1995 vs. 2004-2006) that inhabit or transit Puget Sound (Calamabokidis 

et al. 1999, Krahn et al. 2007, Hickie et al. 2007). Despite these declines, levels of PCB

sassociated with health impacts are observed in seals from this region (Strait of Georgia) and 

most Southern Resident killer whales exceed health effects thresholds for PCB residues (Cullon 

et al. 2009, Hickie et al. 2007, Krahn et al. 2009). The PCB decline in these animals has been 

slowed by continued atmospheric delivery of PCBs from other parts of the world and internal 

cycling (Johannessen et al. 2008). Figure 17 shows the PCB changes observed in the blubber of 

South Puget Sound harbor seals up until 1997.
83

Figure 17. Historical Decline in PCB Levels among South Puget Sound Harbor Seals: Blubber 

Samples 1972-1991 (Calambokidis, 1999)

Monitoring by the Washington Department of Fish and Wildlife (WDFW) for the Puget Sound 

Estuary Monitoring Program (PSEMP) gives a mixed picture of PCB time-trends in edible 

tissues of marine fish (West 2011, West et al. 2011). Levels have declined in coho salmon from 

central Puget Sound, but only until the 1990s. Trend data do not exist for Chinook salmon. There 

is no evidence of a PCB decline in four stocks of Puget Sound herring. English sole from all 

urban and non-urban monitoring locations except Sinclair Inlet show no significant change in 

PCB concentrations over the past 20 years (Figure 18). There is some evidence of improvement 

in Sinclair Inlet in recent years, which has been attributed to reduced stormwater loading, and 

dredging and capping of contaminated sediments in 2000-2001 (O’Neill et al. 2011). Sole are a 

bottom-living species that demonstrate the link between PCBs in sediment and biota.
84

Figure 18. 20-year Time Series for PCBs in English Sole from Selected Urban and Non-urban 

Locations in Puget Sound 

(prepared by James West, WDFW; parts per billion; symbol shift indicates change in analytical 

method)

Long-term trend data are limited for Washington freshwater fish. PCB levels have declined in 

Spokane River fish since the early 1990s due to cleanup of hazardous waste sites, excavation and 

capping of contaminated river sediments, and reduced discharge from industrial and municipal 

treatment plants (Ecology 2011a, EPA 2009).

The U.S. Geological Survey (USGS) analyzed changes in PCB residues in whole fish samples 

collected from 16 stations in the Columbia River Basin between 1970 – 1986, and in 1997 

(Hinck et al. 2004). Not surprisingly, a number of sites had lower levels in 1997 than in the 70s 

or 80s. USGS observed, however, that criteria for the health of fish or wildlife were still 

exceeded and concluded that PCBs remain a cause for concern. Historical declines have also 

been documented for PCBs in Columbia River otter, mink, eagle, and osprey (EPA 2009), all of 

which prey largely on fish. Here again, the comparison is primarily with samples collected in the 

70s and 80s.
85

Current Levels and Spatial Patterns

Water

Due to the extremely low solubility of PCBs and the high cost of analysis, there have been few 

attempts to measure concentrations in the water column. As part of the Puget Sound Toxics 

Loading Analysis (PSTLA), Ecology analyzed PCBs at four sites in Puget Sound, three sites at 

the eastern end of the Strait of Juan de Fuca, and five major Puget Sound rivers in 2009-2010 

(Ecology 2011d). Average concentrations in the Strait of Juan de Fuca (20 ppq) and Puget Sound 

(31 ppq) were similar to that previously reported for the Strait of Georgia (42 ppq) by Canadian 

researchers (Dangerfield et al. 2007). The mean total PCB concentration in the five Puget Sound 

rivers was 16 ppq. The Puyallup and Stillaguamish Rivers tended to have higher concentrations 

(up to approximately 40 and 60 ppq, respectively) than the Skagit, Snohomish, or Nooksack (less 

than 20 ppq). King County (2013b) measured PCB concentrations in Lake Washington, the Ship 

Canal, Sammamish and Cedar rivers, and three major tributaries to the Lake. The total PCB 

concentrations in Lake Washington ranged from an average of 54 ppq during mixed conditions 

to 62 ppq in the hypolimnion and 229 ppq in the epilimnion during stratified periods. 

Concentrations in the two rivers were similar and together averaged 90 ppq. Ship Canal 

concentrations averaged 108 to 295 ppq. Concentrations in tributaries were higher than the Ship 

Canal, ranging from a mean of 451 ppq during baseflow conditions to 2,985 ppq during storm 

events. Williston (2009) and Gries and Sloan (Ecology 2009a) report concentrations in the 

Green/Duwamish River, up to 2,360 and 1,600 ppq total PCBs, respectively.

A surface water study conducted for Puget Sound Toxics Loading Analysis (PSTLA) in 16 

Puyallup and Snohomish county streams found higher PCB levels during storm-events than for 

baseflow conditions (Ecology 2011g). The median total PCB concentration was 348 ppq for 

storm-event samples compared to 227 ppq for baseflow samples. Washington’s human health 

water quality criterion for PCBs is 170 ppq . Of the 70 samples analyzed, approximately 1/3 

exceeded the criterion, primarily storm event samples. Except for a single sample, Washington’s 

aquatic life criteria (ranging from 0.014 to 10.0 ppb) for PCBs were not exceeded

PSTLA estimated the total PCB load to Puget Sound and the U.S. portions of the Straits of 

Georgia and Juan de Fuca was 3-20 kg per year (Ecology 2011a). Surface water was identified as 

the major PCB pathway, accounting for 74-76% of the total load (2.55–15.77 kg/yr). The 

concentration of PCBs in surface runoff was higher from commercial/industrial areas, especially 

during storm events, but the total loading was lower since industrial/commercial lands occupy 

less area than other land covers. Overall loads from forests accounted for 83% of the stormwater

load (Ecology 2011g). Atmospheric deposition and publicly owned treatment works (POTWs) 

accounted for 18-20% (0.68-3.76 kg/yr) and 4-8% (0.126-1.75 kg/yr), respectively, of the 

loading (Ecology 2011a). PSTLA concluded there was insufficient data to estimate PCB loading 

from groundwater (Ecology 2011f).
86

Ecology and USGS have used passive sampling techniques (e.g., semi-permeable membrane 

devices (SPMDs)) to concentrate and estimate PCB concentrations in other freshwater areas 

(McCarthy and Gale 1999, Ecology 2012b, Ecology 2011a, Ecology 2005, Ecology 2004, 

Ecology 2010b, Ecology 2011m). Rivers, their tributaries, and lakes that have exceeded the 

human health criterion to the greatest extent are: 

• Columbia River: Wenatchee River, Willamette River (Oregon), Lake River

• Spokane River: (major pathway is stormwater)

• Yakima River: Granger Drain and Sulphur Creek Wasteway (stormwater also a major 

pathway)

• Walla Walla River: Garrison Creek

• Lake Washington

Water Quality Assessment list

There are 158 303(d) listings for PCBs in Washington’s 2012 Water Quality Assessment. The 

federal Clean Water Act, adopted in 1972, requires that all states restore their waters to be

“fishable and swimmable.” Washington's Water Quality Assessment lists the water quality status 

for water bodies in the state. The assessed waters are grouped into categories that describe the 

status of water quality. The 303(d) list comprises those waters that are in the polluted water 

category, for which beneficial uses– such as drinking, recreation, aquatic habitat, and industrial 

use – are impaired by pollution.

For the water body segments found to be impaired (category 5) Ecology conducts a total 

maximum daily load (TMDL) analysis and develops a cleanup plan for meeting water quality 

standards. Table 25 shows the PCB listings. There are 158 listings for PCBs in category 5. There 

are ten listings for PCBs in category 4a, which means a TMDL is completed and a plan is in 

place to meet water quality standards. Sinclair Inlet is in category 4b, which is similar to 

category 4a, but there is a pollution control plan instead of a TMDL. Fifty-six waterbody 

segments across the state are in category 2, meaning there is some evidence for elevated levels of 

PCBs, but there is not sufficient evidence to list it as impaired.

Figure 19 is a state map of the category 5 and 4 listings along with the Washington DOH fish 

consumption advisories. DOH guidance to develop fish consumption advisories differs from 

Ecology’s procedures to identify impaired waters. See the section on Human Health for a more 

detailed explanation. While the details of how a water body segment is considered impaired 

differs from how a fish consumption advisory is developed, there is a lot of overlap as seen in 

Figure 19. 
87

Table 25. Water Quality Assessment for PCBs

Number of Waterbody 

Segments Category Description

158 5 Polluted waters that require a TMDL

11 4a and 4b Polluted water that have a plan in place

56 2 Waters of concern 

Figure 19. a. Category 4 and 5 303 (d) listings (blue dots). b. Waterbody-specific fish consumption 

advisories (blue lines, see section on Human Health). c. Overlap of water quality listings and fish 

consumption advisories.

Marine Sediments

PCBs have been extensively monitored in the marine sediments of Washington. Ecology has 

PCB data for 630 random sediment monitoring sites in Puget Sound and vicinity up through 

2011, collected for PSEMP (e.g., Ecology 2013a).The highest levels are found in urban bays -

Elliott Bay, Commencement Bay, Everett Harbor, and the Bainbridge Basin - with 

concentrations generally diminishing with distance from the shoreline (Figure 20). Particularly
88

high PCB concentrations occur in the Duwamish and Hylebos Waterways in Seattle and Tacoma.

Much lower levels are typically encountered in other marine areas.

Total PCBs in Washington marine sediments range from approximately 5 to 2,000 ppb (dry 

weight), with an overall median of approximately 15 ppb for the greater Puget Sound area. 

Ninety percent of PSEMP stations have a total PCB concentration below 40 ppb. Less than one 

percent exceed Washington State sediment quality standards (12 ppm, organic carbon 

normalized). For perspective, the mean concentration reported for total PCBs in bottom 

sediments from the Duwamish Waterway Cleanup site is 1,100 ppb, with maximum 

concentrations as high as 220,000 ppb, dry weight (EPA 2013g).

Freshwater Sediments

The PCB data on freshwater sediments are limited to studies focused on specific waterbodies or 

cleanup sites rather than large-scale monitoring programs as in Puget Sound. Spatial patterns for 

PCBs in Washington rivers and lakes are best illustrated with the more comprehensive fish tissue 

data, discussed below.

A regional freshwater sediment study by Ecology assessed the background for PCBs in northeast 

Washington (Ecology 2011h). Sediment samples were collected from fifteen lakes and one river 

thought to be minimally impacted by local human activity. Median and 90th percentile total PCB 

concentrations were 2.5 and 6.3 ppb, respectively. Atmospheric deposition is assumed to be the 

predominant PCB source to these waterbodies. By way of comparison, PCB levels in surface 

sediments of urban/industrial waterbodies such as Lake Washington and Lake Spokane approach

50 - 60 ppb (Ecology 2010a, Ecology 2011c).
89

Figure 20. Distribution of PCBs in Marine Sediments from Puget Sound to Strait of Georgia

(prepared by Sandra Weakland, Ecology Environmental Assessment Program; parts per billion, 

normalized to total organic carbon).
90

Fish

WDFW has monitored PCB levels in Puget Sound marine fish since 1992. Figure 21 summarizes 

the total PCB concentrations measured in edible tissues of four important marine and 

anadromous species. The highest concentrations have been observed in herring (whole fish), 

followed by Chinook salmon, English sole, and coho salmon, in that order. Median and 90th

percentile concentrations for these species are 159/234 ppb (herring), 44/95 ppb (Chinook), 

23/135 ppb (sole), and 10/26 ppb (coho). The fish tissue equivalent of Washington’s human 

health water quality criterion for PCBs is 5.3 ppb. For more information on exposure to people 

from fish and fish advisories, see the section on Human Health. All samples of herring and 

Chinook, and most (70 – 80%) of the English sole and coho have exceeded the criterion. 

Figure 21. PCBs in Edible Tissues of Four Species of Puget Sound Fish (1992-2010 data provided 

by James West, WDFW; N =60 – 210)

Puget Sound herring are 3 to 9 times more contaminated with PCBs compared to Strait of 

Georgia herring (West et al. 2008). The high concentrations in this pelagic species suggest 

continued input of PCBs to the water column, rather than direct uptake from contaminated 

sediments (O’Neill et al. 2011). WDFW’s herring studies show Puget Sound is a regional hot 

spot for PCBs in the food web on the Pacific coast (Figure 22). Within Puget Sound there is a 

gradient of decreasing PCB levels in plankton and several pelagic fish species moving away 

from urban areas (West et al. 2011). 

0.1

1

10

100

1000

0.0 0.2 0.4 0.6 0.8 1.0

Total PCBs (ppb)

Fraction of Samples

Herring

Chinook

Eng. Sole

Coho

Fish tissue concentration of 5.3 

ppb, calculated from the Human 

Health Criterion in water.
91

0

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0

50

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100

150

200

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0

50

 

Figure 22. PCB Spatial Patterns in Herring: British Columbia, Washington, and California

(prepared by James West, WDFW, and Sandie O’Neill, NOAA-NWFSC)

A high percentage of Chinook are resident in Puget Sound, with 29% of sub-yearlings and 45% 

of yearling out-migrants displaying resident behavior (O’Neill and West, 2009). Puget Sound 

Chinook are 3 to 5 times more contaminated than coastal Chinook (West 2011). According to 

O’Neill et al. (2011), 23-100% of juvenile Chinook from Puget Sound urban bays and 19% of 

returning adult Chinook have PCB levels above effects thresholds. The lower levels in coho are 

more reflective of combined oceanic and Puget Sound conditions.

English sole show a strong north-south gradient in PCB concentrations, increasing from the 

Strait of Georgia into Puget Sound (Figure 23). Sole from urban bays, especially the Duwamish 

River estuary, have much higher PCB levels than fish from non-urban locations. The degree of 

contamination in Puget Sound sole is positively correlated with PCB levels in the sediments 

(West 2011). Adverse effects on reproduction, growth, and immune response in English sole and 

other fish species have been attributed to the elevated levels of PCBs and other legacy 

contaminants in Puget Sound embayments (Collier 2009).
92

Figure 23. PCB Spatial Patterns in English Sole Muscle: Puget Sound and Vicinity

(prepared by James West, WDFW; parts per billion).

A Pacific coast survey by the National Marine Fisheries Service showed outmigrating juvenile 

Chinook salmon typically have 2 to 5 times higher concentrations of PCBs and other 

contaminants compared to outmigrating coho (Ecology 2007). Of the 12 estuaries sampled, 

PCBs were highest in Chinook from the Duwamish River and Columbia River. The average PCB 

content in juvenile Chinook from these areas was near or above effects thresholds for growth and 

survival. For the Columbia River, the tidal freshwater portion of the estuary between Portland 

and Longview appears to be an important source of contamination. PCB levels were higher in 

fish that feed and rear in the lower river as opposed to those that migrate more rapidly through 

the estuary (Arkoosh et al. 2011, Johnson et al. 2013). 

Figure 24 summarizes data obtained since 1997 on total PCBs in muscle tissue of resident 

freshwater fish collected throughout Washington, drawn from studies by EPA, Ecology, and 

others (CH2MHill 2007, Delistraty 2013, EPA 2002, Ecology 2004, Johnson et al. 2007,

Ecology Washington State Toxics Monitoring Program, e.g., Seiders et al. 2012). The statewide 

natural background for PCBs in edible fish tissue has been estimated at 6.5 ppb (90th percentile; 
93

Johnson et al. 2010). Large areas of the state have relatively low PCB levels (<20 ppb) not 

greatly above background. However, elevated to high concentrations are also commonly 

encountered, especially in the Columbia River, some of its major tributaries, and the Seattle 

urban area. In approximate decreasing order, the following ten rivers and lakes are reported to 

have the highest total PCB concentrations in fish muscle samples (1,100 to 60 ppb, site average):

• Wenatchee River

• Lake Washington

• Middle Columbia River 

• Green Lake (Seattle)

• Spokane River

• South Fork Palouse River

• Upper Columbia River

• Walla Walla River

• Lower Columbia River

• Snake River

Figure 24. Average PCB Concentrations in Fish Muscle Samples from Washington Rivers and

Lakes

(prepared by Keith Seiders, Ecology Environmental Assessment Program; 1997-2010 data, N = 

587).

Figure 27 in the section on Human Health shows statewide data on PCB levels in fish tissues

(fillet). There is a line at 5.3 ppb, which is equivalent to the human health water quality criterion, 

and a line at 23 ppm, which DOH uses as a screening level for advisories. About 60% of samples 

exceed the 5.3 ppb level calculated from the water quality criterion. The median concentration 
94

statewide for total PCBs in freshwater fish is approximately 10 ppb. Ninety percent of samples 

are less than 85 ppb.

High mountain lakes experience enhanced atmospheric deposition of PCBs due to colder 

temperatures and greater amounts of precipitation (Blais et al. 1998, Gillian and Wania 2005).

USGS analyzed PCBs in fish from 14 pristine Washington lakes over 3,000 ft. elevation (Moran 

et al. 2007). Although a relatively insensitive analytical method was used, total PCB 

concentrations of 17 – 20 ppb were found in approximately 20% of the tissue samples.

Mammals and Birds

Southern Resident killer whales are among the world’s most PCB-contaminated marine 

mammals, which has been implicated in a range of negative health effects (Alva et al. 2012). It is 

estimated that Southern Residents have 4 to 7 times the daily PCB intake compared to Northern 

Residents (Cullon et al. 2009). Salmon, especially Chinook, comprise most of their diet and are 

thus the major source of contamination (Cullon et al. 2009). Transient killer whales have higher 

levels of PCBs compared to either resident population (Ross 2006) and are in a higher trophic 

level, eating marine mammals (Ross et al 2000). PCBs have been seen to cause reproductive 

impairment, immunotoxicity, skeletal abnormalities, endocrine disruption, and negative effects 

on population growth rate in marine mammals (Alva et al. 2012). While there are no established 

health effects thresholds for PCBs in killer whales, the levels in Puget Sound killer whales is 

above the health effects threshold for harbor seals that is based on immune system and 

endrocrine endpoints and predicted to remain high for decades, mostly driven by the long half 

lives of PCBs (Hickey et al. 2007).

Total PCBs in blubber biopsy samples collected in 1993-1997 averaged 146 ppm (lipid weight) 

in Southern Resident males vs. 37 ppm in Northern Resident males and 251 ppm in Transient 

males (Ross et al. 2000). Southern resident males sampled in 2004/2006 averaged 62 ppm 

(Krahn et al. 2007). Females off-load PCBs during calving and lactation, resulting in lower 

concentrations than males, by about a factor of three in the 1993-1997 study. PCB levels rise 

quickly in nursing calves, then the levels fall as the PCBs are diluted with growth, with levels in 

males increasing with age and females increasing until the onset of reproduction (Hickey et al.

2007).

A north-south gradient in increasing PCB levels has also been observed in harbor seals, which 

are non-migratory. Ross et al. (2004) reported average total PCB concentrations in adult seal 

blubber of 1.1 ppm in Queen Charlotte Strait, 2.5 ppm in the Strait of Georgia, and 18 ppm in 

Puget Sound. More recently, WDFW analyzed the blubber of 24 seal pups at four locations in 

Puget Sound (Ecology 2011i). Total PCBs ranged from 1.0 to 9.4 ppm. Concentrations increased 

following the order Hood Canal < Whidbey Basin < South Sound < Main Basin (Figure 25). As

with killer whales, indicators of adverse health impacts have been observed in harbor seals and 
95

linked to PCBs or other persistent organic pollutants (Cullon et al. 2012, Ecology 2011i, Mos et 

al. 2010).

Figure 25. PCBs in Blubber of Puget Sound Seal Pups, 2009 (from Ecology 2011i; mean and 

standard error)

USGS and USFWS have analyzed PCBs in lower Columbia River wildlife. Their most recent 

data (1990-2004) show average wet weight concentrations of 0.2 ppm in mink livers, 0.5 ppm in 

otter livers, 0.8 ppm in osprey eggs, and 5.4 ppm in eagle eggs (Henny et al. 1996, Grove et al. 

2007, Henny et al. 2007, Buck et al. 2005).

Another USGS study reported mean total PCB concentrations of 0.8 ppm in osprey eggs 

collected from the lower Duwamish River in 2006-07, but noted these birds had been feeding 

largely on hatchery raised salmon smolts (Johnson et al. 2009). The significance of 

hematological and biochemical differences observed between eggs from the Lower Duwamish 

and a reference site (upper Willamette River) was unclear. The same study reported 2.6 ppm, 1.9 

ppm, and 0.7 ppm total PCBs, respectively, in osprey eggs collected from Lake Washington, the 

Lower Duwamish River, and Snohomish River estuary in 2002-2003. 

0.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

9.0

Hood Canal 

(n=8)

Whidbey Basin 

(n=6)

Main Basin 

(n=3)

South Sound 

(n=7)

Total PCBs (ppm lipid)
96

Cleanup Sites

There are 336 hazardous waste sites listed in Ecology’s Integrated Site Information System 

(ISIS) as having confirmed or suspected PCBs. Many sites had multiple media with confirmed or 

suspected PCB contamination. Of the sites with confirmed or suspected PCBs in sediments, all 

but 15 also had soil with confirmed or suspected PCB contamination.

Table 26. PCB clean up sites

Medium # of Sites Confirmed Suspected Remediated Below CUL

Soil 295 165 99 11 20

Groundwater 173 60 109 2 2

Sediment 62 47 11 1 3

Surface Water 89 19 64 6 0

Air 18 3 14 0 1

Figure 26. Figure of 483 PCB cleanup sites in Washington in 2010
97

Waste 

Landfills

All Shred Residue

The material that remains after other parts are removed from automobiles at end of life for reuse 

or proper disposal is sometimes shredded and nearly all is used as landfill cover. PCBs may be 

present in automobiles in hydraulic fluids, plastics, voltage regulators, electric motors, switches, 

small capacitors, and light ballasts, leading to PCBs in the shredder waste. The all shred residue

(ASR) is not just from end of life vehicles, but also includes consumer goods and commercial 

scrap. Feedstock sources may come from in or out of state. This material is difficult to sample, 

due to its heterogeneity in waste streams, metal extraction processes, and changes in 

manufacturing materials. 

PCB concentrations in untreated shredder waste have been measured between 0.59 – 129 mg/kg 

and treated shredder waste contains 2.6 - 45.1 mg/kg (McKee et al.2006). McKee et al. further 

estimated that there is 270,000 tons of shredder waste from automobiles and appliances in 

California, leading to an estimate of 30-6,970 kg of PCBs (Average = 3,500 kg) in untreated 

shredded waste and 140-2,440 kg of PCBs (Average = 1,300 kg) of treated shredder waste in the 

Bay Area. 

We have some information on PCBs in shredder residue in Washington in a 2013 report prepared 

for EPA Region 10 (Toeroek 2013). In this study Ecology and EPA sampled four facilities for 

PCBs (using Method 8082) and other analytes. There were different sampling protocols to look 

at variation, and all included a 9.5 mm sieve. Based on observations during the sampling, end of 

life vehicles were only shredded during two of the four days sampling occurred and all samples 

included consumer goods and commercial scrap. PCB concentrations ranged from 0.4 - 59 ppm 

(mg/kg) for the Aroclors tested, with a mean of 19 ppm, which is similar to the other results 

mentioned above. 

Across Washington, shredders generate over 500 tons of ASR daily (Full Circle Environmental 

and Ecology 2011) and landfills reported disposing of 230,157 short tons (208,983 metric tons) 

of ASR in 2012. Using the range of concentrations found of 0.4 - 59 and the average 

concentration found of 19 ppm, results in an estimated 80 to 12,000 kg (12 metric tons) with an 

average of 4,000 kg (4 metric tons) of PCBs in 208,983 metric tons of ASR disposed of in 

Washington landfills each year. 

Electrical equipment

Under federal TSCA, non-leaking small capacitors are allowed to be disposed of as solid waste. 

However, Washington State applies its own regulations to PCB electrical equipment containing 2 

ppm PCBs or more and to materials contaminated to 2 ppm PCBs or more by electrical 
98

equipment. Unless the waste meets specific exclusions under the Washington State PCB rule 

(WPCB), these items must be properly disposed of and reported to Ecology as WPCB waste by 

the generator in annual data source reports. The waste code is for proper disposal and does not 

include more information on concentrations. 

From 2009 – 2012, 10,577 MT of PCB-contaminated waste were reported under WPCB (Table 

27). 

Table 27. PCB-contaminated waste reported under WPCB

Year WPCB (MT)

2009 2,322

2010 2,616

2011 1,310

2012 4,310

PCB-ballasts are considered moderate risk waste (MRW) when they are disposed of by 

households (household hazardous waste) and small businesses (small quantity generator waste).

The weights reported in Table 28 include ballasts and shipping containers and we have not 

corrected for that due to the unknown weights of the shipping containers. Estimating that each 

ballast weighs 1.6 kg, and contains 44g of PCBs the estimated amount of PCBs ranges from 340 

to 560 kg each year. Most of these PCB-ballasts go to a hazardous waste landfill outside of 

Washington State. 

Table 28. PCB-ballasts collected as MRW (2010-2012)

Year PCB-ballasts MRW (lbs) PCBs (kg)

2010 32,871 410

2011 44,996 560

2012 26,885 340

Biosolids

Biosolids fall under the Clean Water Act (CWA) and the 503 rule (40 CFR 503). There are no 

requirements to monitor PCBs in biosolids, nor a regulated level of PCBs in biosolids. 

EPA(1995) made a “policy decision to delete all organic pollutants from land application and 

surface disposal sections of the final Part 503 rule because these pollutants met one of the 

following criteria: (1) the pollutant has been banned or restricted for use in the United States or it 

is no longer manufactured for use in the United States; (2) the pollutant is not present in 

biosolids at significant frequencies of detection based on data gathered in the NSSS [the National 

Sewage Sludge Survey], or (3) the limit for a pollutant from the biosolids exposure assessment is 

not expected to be exceeded in biosolids that are used or disposed based on data from the NSSS.” 
99

EPA continues to investigate pollutants in sewage sludge and uses risk analysis to ascertain 

which pollutants require monitoring and regulatory levels. 

While neither federal nor state regulations require testing of biosolids for PCBs, some 

jurisdictions such as King County, have tested for PCBs in biosolids (King County 2007). In 

2006 Aroclor 1248, 1254, and 1260 were detected and other Aroclors were not detected at the 

West Point Treatment Plant. Only Aroclor 1254 was detected at the South Treatment Plant. 

Historically PCB Aroclors have been detected in King County biosolids at the ppb level. We do 

not have enough information to estimate the amount of PCBs in biosolids in Washington.

PCBs have also been measured in a few samples of Canada Goose guano in the Lower 

Duwamish area. In four composite samples the total Aroclor PCBs ranged from 28-103 ppb with 

an average concentration of 58 ppb. This is generally indicative of the ubiquitous nature of PCBs 

in Washington. This is not enough information to estimate the amount of PCBs in goose guano 

in Washington. 

Environmentally Significant PCBs

As a result of partitioning, transformation, and bioaccumulation, PCB mixtures in the 

environment do not resemble the commercial products. About half of the 209 possible congeners 

account for most of the environmental contamination. Based on toxicity, prevalence, and relative 

abundance, less than 40 congeners are most commonly found in the environment.. Twenty-five 

of these account for 50-75% of the total PCBs in biological tissues (McFarland et al. 1989). 

In Washington and elsewhere, PCBs with three to six chlorines (tri- through 

hexachlorobiphenyls) are the dominant compounds found in environmental samples. Less 

chlorinated compounds are more volatile and more readily metabolized and eliminated from 

organisms. Highly chlorinated compounds are relatively less abundant, more tightly bound to 

sediment particles, and taken up poorly by fish and other aquatic animals. 

Twelve PCBs have a co-planar configuration that imparts dioxin-like toxicity (Tables 20 and 25). 

These compounds are frequently detected in Washington’s environment. PCB-118 is the coplanar most often encountered in the highest concentrations (Cleverly et al. 1996, Ecology 2011i

most toxic co-planar, PCB-126, is typically present at the lowest concentrations. 

Although their toxicity is low relative to dioxin - a tenth or less – these PCBs can impart a 

significant fraction of the total dioxin toxicity equivalents (TEQ), particularly in higher animals.

Co-planar PCBs accounted for up to 89% of the total TEQ in harbor seal pups collected from 

Puget Sound in 2009 (Ecology 2011i). PCB-118, -105, and -156, in that order, were the major 

contributors to the TEQ. Cullon et al. (2009) reports that PCBs explained the majority of the 

TEQ in adult salmon from British Columbia and Puget Sound waters. In contrast, the PCB TEQ 

in Washington freshwater fish is typically much lower than the dioxin TEQ, by an order of 

magnitude or more in most cases (CH2MHill 2007, USDOE 2010, Ecology 2010c). 
100

PCB-11, a non-legacy PCB, has been identified in Columbia River water and clams (Ecology 

2005, McCarthy 2007). In some samples, PCB-11 was either the most or second-most abundant 

congener detected. PCB-11 is neither associated with historical commercial PCB products nor a 

breakdown product of the commercial mixtures. The source has been traced to pigments 

currently used in paint (Hu and Hornbuckle, 2010). Reports of PCB-11 in environmental samples 

have become widespread in North America (Litton 2006, Grossman 2013). PCB-11 is considered 

a significant source of contamination to air, soil, and water (Hornbuckle and Robertson 2010). 

Model Predictions 

Ecology modeled the long-term fate and bioaccumulation of PCBs in Puget Sound (Ecology 

2009b). Pertinent findings from Ecology’s box model include the following: 

• Approximately 97% of the total mass of PCBs in the aquatic ecosystem of Puget Sound is in 

the active sediment layer (top 10 cm), <1% is in the water column, and <3% is in the biota. 

• Decreases in PCBs in sediment and biota are possible by the year 2020 in the urban bays due 

to burial and transport of sediments.

• Increases in PCBs in sediment and biota are possible by the year 2020 in the larger basins.

• Considering the wide range of uncertainty in loading from outside of the Puget Sound basin, 

it is possible the mass of PCBs in the aquatic ecosystem of Puget Sound may either increase 

or decrease over time at the current loading levels.

Ecology is currently re-evaluating this model using more recent data. 

A delayed response to environmental declines in PCB levels is predicted for long-lived species 

like killer whales (~50-year lifespan). According to an individual-based model, Southern 

Resident killer whales may not fall below PCB effects thresholds for several more generations 

(Mongillo et al. 2012, Hickie et al. 2007). 

Food web models for Lake Washington and the Spokane River conclude that PCB residues in 

fish are driven mainly by levels in the sediments in Lake Washington and are an important factor 

in the Spokane River (Ecology. 2010a and 2011c). Thus, recovery in these water bodies may 

respond slowly to reductions in external PCB loading.

Results of a mass balance model for the Willamette River basin in Oregon demonstrated that the 

PCB levels observed in fish could be due entirely to atmospheric deposition from global legacy 

sources (Hope 2008). In this analysis, PCB sources within the Willamette basin were assumed to 

be insignificant. Portland was discounted because it occupies a short segment of the lower river 

isolated by Willamette Falls. 
101

Local Hazard Assessments

Spokane River

The Spokane River has elevated levels of PCBs in Washington. Ecology calculated hazard 

quotients (HQs) for different endpoints and receptors in six different parts of the river for aquatic 

life and fish-eating wildlife (Ecology 2001). HQs are ratios of the level of PCBs in the 

environment and the level at which no adverse effects are expected. If the HQ is greater than 1, 

then adverse health effects are possible, but do not necessarily occur. 

The primary ecological hazards identified were: 

1. Possible adverse effects on the sustainability of salmonid populations and fish-eating 

mammals, primarily in the reach between Trentwood and Nine-Mile Dam. 

PCB levels in salmonid fish tissue were high compared to the National Marine Fisheries Service 

(NMFS) effects threshold for sublethal effects (HQs of 2.2-4.1). 

The levels of PCBs in water were high compared to the Great Lakes criterion for reproductive 

effects on fish-eating mammals (HQs of 4.5-17). Also the PCB levels in fish tissue were high 

when compared to the British Columbia guideline for reproduction in fish eating wildlife (HQs 

of 2-6) and compared to the lowest observable effects levels (LOEL) for mink and otter 

reproduction (HQs of 1.5-2.4). 

2. Possible adverse effects on benthic invertebrates in the Trentwood to Monroe Street Dam 

reach in areas where PCBs have been concentrated in fine-grained sediments, such as behind 

Upriver Dam. The levels of PCBs in sediment were high compared to the threshold effect for 

abundance and diversity of benthic invertebrates (HQs of 2.5-9.8)

Puget Sound

As part of the larger, multi-year, multi-agency, project to study toxic chemicals in Puget Sound, 

the Assessment of Selected Toxic Chemicals in the Puget Sound Basin, 2007-2011 (Ecology 

2011a) included a hazard evaluation to estimate the relative hazard posed by the 17 chemicals of 

concern assessed in the Puget Sound studies. This was not a risk assessment, but part of the 

effort to prioritize efforts on pollutants in Puget Sound. The hazard evaluation was for the entire 

Sound, not for hot spots where there are higher levels of contamination, such as in cleanup sites. 

PCBs were ranked as having the highest level of concern for a range of media and receptors in 

both the freshwater and marine aquatic environments. 

PCBs were found to be at the highest level of concern (Priority 1) for the five categories 

assessed. The category and the reason PCBs were placed in Priority one is given below for each. 
102

• Aquatic life through surface water exposure. The 90th percentile of observed concentrations 

of Aroclors was above the chronic Water Quality Standard (WQS) for aquatic species in 

freshwater. 

• Benthic organisms through sediment exposure. The 90th percentile of the observed 

concentrations exceeds the Sediment Quality Standard for Aroclors for freshwater (FP-SQS) 

and offshore marine sediment (SQS). 

• Tissue Residue Effects. The 90th percentile of observed concentrations was above the 10th

percentile of the effects concentration for non-decapod invertebrates for both Aroclors and 

total congeners. 

• Wildlife through seafood consumption. Using Great Blue Heron, Osprey, River Otter, and 

Harbor Seal as representative species, the daily dose was more than the lowest effect dose 

divided by10.

• Human health through seafood consumption. The 90th percentile of observed tissue 

concentrations was above National Toxics Rule (NTR) water quality criteria for freshwater, 

nearshore marine, and offshore marine for both Aroclors and congeners for bivalves, fish and 

invertebrates. Tissue criteria were back calculated from the NTR based water quality criteria.

Environmental data from January 2000 to July 2010 were collected from a variety of sources, 

and the largest source of data was Ecology’s Environmental Information Management (EIM) 

system. Information on effects levels were found in the scientific literature and regulatory 

benchmarks. Comparisons to effects levels, criteria, and guidelines were done separately for both 

PCB Aroclor and congener data. Box Plots showing these comparisons can be found in the 

Assessment report Appendices D3-D7 

(https://fortress.wa.gov/ecy/publications/summarypages/1103055.html).
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Human Health Effects of PCBs

Introduction

There is a very large body of toxicological and epidemiological research on the health effects of 

PCBs. Research conducted in experimental animals has shown that PCBs can cause a wide 

variety of adverse health effects including, immune suppression, adverse reproductive effects, 

abnormal motor and cognitive development, injury to the liver and other internal organs, changes 

in the endocrine system, and cancer. Epidemiological studies have found evidence of similar 

adverse effects on human development and behavior, reproduction, immune function, and cancer 

(ATSDR 2000). The International Agency for Research on Cancer (IARC) recently changed 

their classification of PCBs and dioxin-like PCBs from “probable human carcinogens” to 

“human carcinogens” to recognize that there is now sufficient evidence in humans and animals. 

(Lauby-Secretan et al. 2013).

The primary historic uses of PCBs were banned in 1979 but existing electrical equipment and 

other closed systems containing PCBs were permitted to remain in use (40 CFR part 761). Caulk, 

joint sealant, paint, and other building materials sold before 1979 may have contained PCBs and 

could still be in place. PCBs have continued to slowly escape from these historic sources with 

rapid releases during leaks, fires, and building demolition.

Historically, PCB oils and equipment containing those oils have been disposed in ways that 

allowed PCB release into the environment. A number of waste sites in Washington have been 

identified as contaminated with PCBs. Many have been cleaned up but additional clean-up 

remains. Because many PCBs are persistent and bioaccumulative, these legacy sources of PCBs 

continue to cycle through air, water, soil, sediments, and biota. Although general environmental 

levels have dropped dramatically since 1979, human exposure to legacy PCBs in fish, other 

foods, and air will continue into the future.

In addition, PCBs are inadvertently formed during current production of certain pigments and ink 

(Hu and Hornbuckle 2010). These PCBs have been detected in colored papers, cardboard, 

plastics, and textiles and may be released to the environment during manufacturing, use, 

disposal, or recycling of consumer products (Litten et al. 2002, Rodenburg et al. 2010). PCB 11 

has emerged as a useful indicator of these new sources of exposure since commercial PCBs 

mixtures did not contain more than trace amounts of PCB 11 (Grossman 2013).

There are 209 possible configurations of chlorine substitutions of the biphenyl molecule. Each 

possible configuration (called a congener) is assigned a number and most can now be quantified 

analytically. Because congeners vary in their toxicity and their resistance to metabolism, risk 

assessment of PCB mixtures is complex. One of the earliest discoveries in the search for 

common mechanisms of toxicity was that certain congeners have dioxin-like ability to bind to 
104

the aryl hydrocarbon (Ah) receptor. Dioxin-like PCBs are planar or nearly planar in structure 

(Van den Berg et al. 1998). Their interaction with the Ah receptor is dose-dependent, saturable,

and induces hepatic enzymes, including aryl hydrogen hydroxylase (also called cytochrome p450 

CYP1A1) and 7-ethoxyresorfin O-deethylase (CYP4501A2) (Seegal 1996). These enzymes 

metabolize (or breakdown) a number of environmental chemicals but also act on important 

endogenous chemicals such as hormones, retinoids, and neurotransmitters (ATSDR 2000).

Several toxic responses have been well correlated with the Ah-receptor binding affinity, 

including body weight reduction, hepatotoxicity, and thymic atropy (Seegal 1996). Laboratory 

animals exposed solely to coplanar PCBs have shown reproductive problems, increases in brain 

levels of biogenic amines including dopamine, alterations in fetal and neonatal plasma thyroid 

hormone levels, and neurobehavioral effects (Brouwer et al. 1995). Available evidence in lab 

animals suggests that the maturation of the immune system is especially vulnerable to adverse 

effects of dioxin-like compounds (Holladay and Smialowicz 2000). Toxic equivalency factors 

(TEF) for 12 PCB congeners have been developed to facilitate human health risk assessment of 

mixtures of dioxin-like chemicals (Van den Berg et al. 1998, 2005, see Table 24 and Table 29).

EPA and ATSDR have established health recommendations concerning oral intake and 

inhalation of PCBs. These screening levels help public health agencies and communities identify 

exposures of concern. The three primary pathways of current PCB exposure for the U.S. general 

public are diet, indoor air, and ambient air. In addition, ingestion of PCB residues in house dust 

could be a significant contributor to exposures in toddlers (ATSDR 2000, Harrad et al. 2009). 

Although background exposures in the U.S. population appear to have dropped below levels of 

concern, special populations at higher risk for exposure exist and require attention. These include 

people who work around PCB contaminated equipment or materials, who consume fish and 

seafood from contaminated waters, or who live or work in a building with PCBs in building 

materials or fluorescent light ballasts.

Historical Episodes of PCB Poisoning

Acute poisoning to PCBs has been documented in people following accidental food 

contamination and workplace accidents. These incidents underscore why people must be

protected from direct contact with concentrated PCB liquids or materials during source removal, 

transport, and disposal. There have been two episodes of mass human poisoning by inadvertent 

community-wide consumption of PCB contaminated rice oil. One occurred in Japan in 1968 and 

the other in Taiwan in 1978-79. Affected people in Japan were diagnosed with “Yusho” which 

means “the oil disease” and in Taiwan with “Yu-Cheng,” the term for “oil disease” in 

Taiwanese. About 1700 adults were acutely affected in the Japanese incident. Exposure of adults 

resulted in increased skin pigmentation, severe acneform eruptions, swelling of the meibomian 

gland with eye discharge, thickening of the nail bed, numbness in extremities, and respiratory 

disease (Urabe and Asahi 1985, Ikeda 1996, Nakanishi et al.1985). Affected women who were 
105

pregnant at the time gave birth to children with physical abnormalities (dental disorders, 

hyperpigmentation of skin) and severe neurodevelopmental problems (Seegal 1996). Exposure 

monitoring for PCBs in blood of Yusho patients did not begin until five years after the onset of 

disease.

About 2000 persons were initially affected with illness in the Taiwan incident. Symptoms 

included hyperpigmentation, acneform eruptions, swelling of eyelids and increased discharge 

from the eyes, as well as systemic complaints (Lu and Wu 1985). Women who were pregnant at 

the time of exposure gave birth to children who showed hyperpigmentation, nail deformities, 

conjunctival discharge and swelling. Eight of the 39 infants born with hyperpigmentation during 

the four years following the incident died (Hsu et al. 1985). A cohort of most of the Taiwanese 

children (n =118) born to affected mothers up to six years past the incident has been followed 

and tested annually for cognitive deficits. A comparison population with the same number of 

children was matched on maternal age, child’s birthdate, gender, and neighborhood of residence. 

Blood PCB levels of Yu Cheng patients were measured early in the disease outbreak and were

high (44.4% of 613 patients sampled had blood levels of PCBs between 51-100 ppb). The 

highest value reported was 1156 ppb (Hsu et al. 1985). Yu-Cheng offspring have been shown to 

have persistent cognitive deficits, lower IQ, and higher rates of problem behaviors compared to 

neighborhood controls (Lai et al. 2002).

Immune effects were also reported in both groups of poisoned people including an increase in 

respiratory and skin infections and changes in immune parameters such as immunoglobulins and 

T cells (Lu and Wu, 1985). Studies also detected depressed responses to tuberculin tests (Lu and 

Wa 1985, Nakanishi et al. 1985). Infants born to mothers who had Yu-Cheng disease had more 

episodes of bronchitis or pneumonia during their first six months of life and had higher 

frequencies of ear infection and respiratory tract infection in a six-year follow-up (Yu et al. 

1998).

There is debate about the degree to which these two mass poisonings are relevant to current 

assessments of PCB exposure (Schantz 1996, Seegal 1996). The levels of PCB intake were very 

high compared to environmental sources. PCBs in both incidents had been repeatedly heated to 

high temperatures in a heat exchanger before contamination of rice oil occurred. The high 

temperatures changed the chemical composition of the oil creating high concentrations of 

polychlorinated dibenzofurans (PCDF) and other toxic compounds. Many of the developmental 

and physical effects seen in these populations, however, are also observed in monkeys dosed 

with pure PCB mixtures.

Developmental abnormalities have also been observed in occupationally exposed populations. A 

seven-year follow-up study of capacitor manufacturing workers in Japan and their children 

evaluated effects on children born to mothers who had PCB blood and breast-milk levels that 

were 10-100 times the normal background and markedly higher than the blood of Yusho 
106

patients. Forty children were examined once a year for five years and none were diagnosed with 

PCB poisoning. Some of the children were found to have decay of nails, gingival pigmentation, 

mottled enamel, and dental caries that were typical symptoms in Yusho but were less serious in 

this study population (Hara 1985).

Endpoints of Human Health Concern

Cancer

There is clear evidence that commercial PCB mixtures cause cancer in animals in a dosedependent manner (EPA 1996b, ATSDR 2000). Cancers observed primarily involve thyroid and 

liver tissue. Studies of workers exposed to commercial PCB mixtures found increases in liver 

and bile-duct cancers and malignant melanoma across multiple human studies (NTP 2011, 

Lauby-Secretan et al. 2013).

EPA and NTP consider PCBs to be probable human carcinogens and recently International 

Agency for Research on Cancer (IARC) strengthened its classification of PCBs to “human 

carcinogens” based on new evidence of melanoma in epidemiological studies (Lauby-Secretan et 

al. 2013). EPA concluded that the types of PCBs likely to be bioaccumulated in fish and bound 

to sediments are likely to be the most carcinogenic PCB mixtures (EPA 1996b).

PCB mixtures and individual congeners can act as tumor promoters (ATSDR 2000, WHO 2003, 

EPA 1996b). Tumor promotional activity has been observed by congeners that are aryl 

hydrocarbon agonists (dioxin-like congeners), that induce cytochrome P450 1A and 2B 

isozymes, and induce P450 CYP2 and CYP3 families of enzymes and have a phenobarbital 

pattern of enzyme induction (ortho-substituted congeners). Oxidative stress and disruption of 

intercellular communication have also been proposed as mechanisms for cancer promotion (EPA 

1996b, WHO 2003).

Certain PCB congeners have been shown to be direct tumor inducers as well. In a series of recent 

investigations, the National Toxicology Program (NTP) demonstrated that dioxin-like congeners, 

PCB 118 and PCB 126, were able to induce lung, liver, bile duct, oral, and uterine cancers in 

rodents (NTP 2006). Certain non-dioxin-like congers that are likely to be in air, such as PCB 3, 

also appear to undergo metabolic activation in rodents to reactive species that are genotoxic and 

can initiate DNA and chromosomal damage (Xie et al. 2010; Ludewig and Robertson, 2013).

Few studies of genotoxicty in humans have been conducted but these have been negative for 

environmental PCB exposures (Ludewig and Robertson, 2013).

Immune Effects

Numerous immune effects have been measured in laboratory animals exposed to PCBs (ATSDR 

2000). Changes in the immune system were selected by both ATSDR and EPA as the most 

sensitive non-cancer endpoint for chronic exposure to PCBs. In the critical study chosen by these 
107

agencies (Tryphonas et al. 1989, 1991a, 1991b), PCB-treated rhesus monkeys had a dose-related 

reduction in antibody response to an injected antigen (sheep red blood cells). The diminished 

production of immunoglobulins IgM and IgG, in response to antigen was statistically-significant 

at two time points during the study (27 months and 55 months) at the lowest dose of Aroclor 

1254 tested (5 μg/kg/d). No differences in baseline serum concentrations of IgG, IgM, or IgA 

were evident. Both EPA’s Reference dose for chronic exposure and ATSDR’s minimal risk level 

were derived from findings of this study at the 5 ug/kg/d dose level (EPA 1994, ATSDR 2000). 

Body burdens after 25 months of dosing at 5 μg/kg/d were reported to be 10.3 ppb in blood (8.4 

ppm in blood when expressed on a lipid basis) and 2.2 ppm in adipose tissue (7.5 ppm in adipose 

when expressed on a lipid basis) (Arnold et al. 1993a, 1993b).

The experiment above continued into a breeding phase to measure reproductive and 

developmental outcomes in the rhesus monkeys. Female monkeys treated for 37 months with 

Aroclor 1254 were bred to unexposed males. Among other things, offspring were tested for 

immunological function. A reduction in IgM titres to sheep red blood cells were statistically 

significant for the 5 μg/kg/d dose level at multiple post-natal time points (Arnold et al. 1999).

Statistically significant but clinically mild developmental abnormalities were observed in 

offspring at the 5 μg/kg/d dose level including nail and nail bed changes, and inflammation 

and/or enlargement of the tarsal glands. There were also adverse reproductive effects that were 

elevated but did not reach statistical significance at the 5 μg dose (Arnold et al. 1999).

A number of epidemiological studies have reported immune effects associated with human 

environmental exposures to PCBs. Inuit children with high exposure to PCBs and other 

organochlorines, were reported to have higher incidence of ear infection and lower (but not 

upper) respiratory tract infection during the first five years of life (Dallaire et al. 2006). Early life 

exposures to PCBs have also been associated with reduced response to childhood vaccinations in 

European children (Weisglas-Kuperus et al. 2000, Heilman et al. 2006) and reduced size of the 

thymus (Park et al. 2008).

Neurological and Neurodevelopmental Effects

Extensive animal research on neurologic impacts of PCB shows adverse effects in adults and the 

young with fetal and early postnatal periods being the most sensitive in producing adverse effects 

in rodents and monkeys (Brouwer et al. 1995). Hyperactivity and learning and memory 

impairments are very sensitive to developmental PCB exposure in non-human primates 

(Bowman et al. 1978, Schantz et al. 1991). ATSDR based their health advice for oral PCB 

exposure over intermediate durations on learning and memory impairments observed after 

postnatal exposure to a PCB in male rhesus monkeys (ATSDR 2000). In this study, Rice et al. 

created a congener mixture that represented 80% of the congeners present in breast milk in 

Canadian women and administered it for 20 weeks post-natally at a dose estimated to be 

equivalent to nursing from a mother with 50 ppb PCB in breast milk (7.5 μg/kg/d). Behavioral 
108

tests were conducted 3-5 years later. Treated monkeys were slower to learn new responses, adapt 

to new response patterns, and inhibit a response that was previously rewarded (Rice 1999). This 

study also measured effects at the lowest and only dose tested.

A number of studies have reported developmental effects in children although PCB levels in cord 

blood at birth or in the mothers were significantly higher than current body burdens in most 

populations (Jurewicz et al. 2013). Some studies, such as the Michigan Maternal/Infant Cohort 

and the Oswego Newborn and Infant Development Project, compared pregnant women who 

consumed Great Lakes fish to mothers who did not. Other studies, such as the North Carolina 

Breast Milk and Formula Project and the Dutch PCB/Dioxin Study, focused on mothers in the 

general population. These studies reported a range of subtle neurobehavioral effects such as 

abnormal newborn reflexes, cognitive and memory deficits including decreased IQ and changes 

in physical activity that were associated primarily with in utero not lactational PCB exposure 

(Jacobson and Jacobson 1996, Stewart et al. 2008, Brouwer et al. 1995). Although some studies 

have measured effects of lactational exposure to PCBs via breast milk, breast feeding appears to 

have a net positive effect on children with regard to mental and physical development (Anderson 

et al. 1999, Boersma and Lanting 2000, Pan et al. 2009). Fish consumers had higher proportions 

of PCB congeners with 7-9 chlorines and, in one analysis, these congeners were shown to be 

more closely associated with the neurobehavioral effects observed (Stewart et al. 1999). In 

another study, maternal body burden of dioxin-like mono-ortho substituted congeners (PCBS 

118 and 156) were most strongly associated with neurobehavioral outcomes in children (Park et 

al. 2010).

Several researchers have proposed potency schemes for neurotoxicity of PCB mixtures that 

include both dioxin-like and non-dioxin-like PCB congeners. One neurotoxicity equivalency 

scheme is based on congener potency in interfering with intracellular signaling pathways and 

calcium ion modulation in the nervous system (Simon et al. 2007). Another is based on congener 

potency in altering brain dopamine and blood thyroid hormone levels (Yang et al. 2009). 

Although these schemes are not sufficiently developed for risk assessment, they point to the need 

to expand beyond TEQ of dioxin-like congeners when assessing potential neurotoxicity of PCB 

mixtures.

Reproductive Effects, including Birth Defects

Reproductive effects of PCBs have been demonstrated in a variety of animal species including 

non-human primates (ATSDR 2000). Oral PCB exposures reduced birth weight, conception rates 

and live birth rates of monkeys exposed during preconception and gestation (Arnold et al. 1995). 

Similar results have been observed in rodents. Developmental exposures in rodents resulted in

lasting changes in reproductive tissue that were measurable at puberty and into adulthood (WHO 

2003).
109

Investigations of reproductive effects have also been carried out in human populations exposed 

to PCBs. Longer time-to-pregnancy for couples trying to get pregnant has been reported to 

correlate with higher levels of certain PCB congeners (Axmon et al. 2005, Buck Louis et al. 

2013). Obvious growth retardation was observed in offspring following the Yusho and YuCheng incidents. Children born to women who worked with PCBs in factories showed decreased 

birth weight and a significant decrease in gestational age with increasing exposures to PCBs 

(Taylor et al. 1989, Hara 1985). Studies in fishing populations believed to have high exposures 

to PCBs also suggest similar decreases in either birth weight or gestational age or both (Fein et 

al. 1984, Rylander et al. 1995). Govarts et al. 2012 reported that birth weight decreased with 

increasing cord serum concentration of PCB-153 after adjustment for potential confounders in 12 

of 15 study populations in Europe. Several studies have observed persistent deficits in physical 

growth into childhood following prenatal exposure to PCBs, particularly in girls (Jacobson and 

Jacobson 1997, Lamb et al. 2006, Blanck et al. 2002). Other investigations did not detect lower 

weight or shorter gestation times in other populations, including fish consumers (Rogan et al. 

1986, Patandin 1999, Dar et al. 1992, Buck et al. 2013, Cupul-Uicab et al. 2013).

Endocrine Effects

There has been significant discussion and research on the effects of PCBs on the endocrine (or 

hormone) system. A number of PCB congeners and their metabolites display weak estrogenic, 

antiestrogenic effects, or antiandrogenic effects (Goncharov et al. 2009, Hamers et al. 2011, 

Brouwer et al. 1999, Birnbaum 1994). Certain PCBs and their metabolites appear able to directly 

interfere with estrogen or androgen receptors and bind directly to the estrogen receptor while 

others may act indirectly by inducing enzymes that then change estrogen metabolism (Brouwer 

et al. 1999, Kester et al. 2000, Hamers 2011).

The strongest evidence is for disruption of thyroid hormone levels. Hydroxylated PCB 

metabolites are structurally similar to the thyroid hormone thyroxine (T4) and may interfere with 

hormone receptor binding directly. They have been shown to competitively displace binding of 

thyroid hormone (T4) to transthyretin in rodents and to disrupt the normal delivery of thyroid 

hormone from maternal plasma to the rodent fetus in vivo (Porterfield 2000, Brouwer et al. 

1999). In addition, PCBs and their metabolites may act indirectly by interfering with thyroid 

hormone metabolism. For example, activation of the Ah receptor by dioxin-like PCBs, induces 

production of the enzyme uridine diphosphoglucuronyl transferase that metabolizes T4 and may 

accelerate T4 clearance from the liver (Porterfield 2000, Koopman-Esseboom et al.1994). 

Thyroid hormones are essential for regulating metabolism and normal growth and brain 

development. They also promote normal cardiovascular, reproductive and nervous system 

functioning.

Dioxin-like PCBs have been associated with changes in thyroid hormone levels in infants 

(Koopman-Esseboom et al. 1994, Nagayama et al. 1998, Pluim et al. 1992). A more recent study 
110

by Wilhelm et al. 2008 looked for but did not find any decrease in thyroid hormones related to 

dioxin-like PCBs or total TEQ at current exposure levels in Germany. Chevrier et al. 2008

reported that blood concentration of thyroid stimulating hormone in newborns was associated 

with non-dioxin like PCB congeners (PCBs 99, 138, 153, 180, 187, 194, and 199). Similar 

results, higher TSH and lower free T4 levels with increasing PCB levels, were reported in 

adolescents, although only in the group that had not been breast-fed (Schell et al. 2008).

Established Health Guidelines for PCB Mixtures

EPA’s approach to cancer risk assessment of PCB mixtures

EPA uses a tiered approach to cancer risk assessment for PCB exposure. EPA recognized that 

selective bioaccumulation in the environment creates dietary PCB mixtures that differ markedly 

from Aroclor mixtures produced commercially. The tiers attempt to address the likely 

differences in toxicity and persistence of PCB mixtures. The tiers also reflect that PCB mixtures 

comprised mostly of congeners with more than four chlorines are more persistent and more 

carcinogenic than more lightly-chlorinated, less persistent congeners.

EPA recommends that risk assessors use a cancer slope factor of 2.0 per mg/kg/d for PCB 

mixtures present in the food chain. This most potent assumption should also be applied to protect 

all early life exposures. A less potent assumption of 0.4 per mg/kg-d can be used in assessments 

of ingestion of water soluble congeners and inhalation of evaporated congeners. A third tier 

(cancer slope equal to 0.07 per mg/kg-day) is provided for assessment of exposure to PCB 

mixtures with less than one half percent congeners of four or more chlorines. (Cogliano 1998)

Dioxin-like congeners and Toxic Equivalency (TEQ) approach.

Mixtures of PCBs congeners that have dioxin-like toxic effects can be evaluated by their toxicity 

relative to the most toxic dioxin, 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). Dioxins and 

dioxin-like compounds have a common mechanism of action mediated by the aryl hydrocarbon 

receptor (AhR) but differ in their potency. Their potency relative to TCDD is reflected in their 

Toxic Equivalent Factor (TEF) developed by the World Health Organization for 7 dioxins, 10 

dibenzofurans, and 12 PCB congeners. TEFs for PCBS are shown in Table 29 (Van den Berg et 

al. 2006). The most potent PCB congener has a TEF =0.1 which means that it is 1/10 as toxic as 

TCDD. The TCDD Toxicity Equivalent (TEQ) of a mixture can be calculated by summing the 

individual congener concentration and their TEFs as shown in the equation below.

TEQ = Σ (TEFi ∙ Ci)
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Where:

TEQ = TCDD toxicity equivalance

TEFi = Toxicity equivalency factor for an individual congener

Ci = Concentration of individual congener

Table 29. Toxicity Equivalence Factors for PCB Congeners

Class Congener

Mammal Toxicity 

Equivalence Factor 

(TEF)

Co-planar PCBs 3,3',4,4'-TCB (77) 0.0001

3,4,4',5-TCB (81) 0.0003

3,3',4,4'-5-PeCB (126) 0.1

3,3',4,4',5,5'-HxCB (169) 0.03

Mono-ortho PCBs 2,3,3',4,4'-PeCB (105) 0.00003

2,3,4,4',5-PeCB (114) 0.00003

2,3',4,4',5-PeCB (118) 0.00003

2',3,4,4',5-PeCB (123) 0.00003

2,3,3',4,4',5-HxCB (156) 0.00003

2,3,3',4,4',5'-HxCB (157) 0.00003

2,3',4,4',5,5'-HxCB (167) 0.00003

2,3,3',4,4',5,5'-HpCB (189) 0.00003

Source: TEFs recommended by World Health Organization (Van den Berg et al. 2006).

The EPA recently set the daily level of exposure considered safe for humans over a lifetime (also 

known as the Reference Dose or the RfD) at 0.7 picograms per kilogram of body weight of 

TCDD or toxicity equivalent as calculated by the equation above (EPA 2012d). This number is 

believed to protect against the most sensitive non-cancer endpoints observed. It is based on 

observations of health effects at 20 pg/kg/d in two studies conducted after an industrial accident 

in Seveso, Italy. The follow-up studies detected reduced sperm counts in men exposed in 

childhood and increased thyroid hormones in infants of mothers exposed during pregnancy 

(Mocarelli et al. 2008, Baccarelli et al. 2008). An earlier health guideline for acceptable daily 

intake of dioxin-like compounds, set by the World Health Organization/United Nations in 2001, 

was based on older data. The newer EPA RfD is three times lower (see Table 30). EPA is 

currently developing its health guidance for dioxin cancer assessment.
112

Other Health Guidance

There are a number of health standards that address exposures to PCBs in people. For assessment 

of dietary intake, the Washington State Department of Health (Health) uses the EPA RfD and

TEFs as described in WHO 2005 for non-cancer endpoints and an upper bound cancer slope 

factor of 2.0 per mg/kg/d for cancer.

The EPA standard for PCBs in drinking water is 0.5 μg/L and the FDA adopted the same 

standard for bottled water (see Table 30). The FDA has also set residue limits for PCBs in 

various foods to protect against harmful health effects including a maximum of 0.2 mg/kg in 

infant and junior foods, 0.3 mg/kg in eggs, 1.5 mg/kg in milk and other dairy products (fat basis), 

2 mg/kg in fish and shellfish (edible portions), and 3 mg/kg in poultry and red meat (fat basis).

The FDA regulatory action level for PCBs in fish is much higher than human health risk levels 

established under the National Toxics Rule or used by Health to assess fish. The FDA action 

level reflects FDA’s higher tolerance for PCBs in food and the agency’s emphasis on the net 

benefit to consumers of eating fish, despite contamination.

The National Toxics Rule sets water quality criteria for PCBs to protect human health over a 

lifetime of drinking water and eating fish from surface water. The NTR includes an equivalent

fish tissue criteria (5.3 ppb) for PCBs. This serves as an “equivalent” measure of water quality in 

that fish living in water at the surface water criteria (0.00017 μg/L) should not exceed 5.3 ppb 

PCB in tissue. While Health supports Ecology’s use of the NTR criteria for identifying problems 

and controlling water pollutant sources, Health does not use the NTR criteria to establish fish 

consumption advisories.

Health establishes fish advisory screening levels for mercury, PCBs, and other contaminants by 

using an approach similar to that outlined in EPA’s Guidance for Assessing Chemical 

Contaminant Data for use in Fish Advisories Vol. 1-4 (EPA 2000b). This guidance provides a 

framework for state development of fish consumption advisories, based on best available 

science, and established procedures in risk assessment, risk management, and risk 

communication. Health’s current screening level for PCBs also incorporates recommendations 

from the American Heart Association that people should consume two meals of fish per week to 

gain the known health benefits associated with fish consumption. The Health screening value of 

23 ppb is derived from assumptions of two meals/week consumption rate, average body weight 

of a person, and EPA’s RfD for protection of human health effects. Health uses this value to 

identify populations of local fish that may need a fish advisory. This is a starting point for state 

advisories which need to balance the many health benefits of fish with the possible risks of PCB 

ingestion. More on information about how Health develops PCB fish advisories is at: 

http://www.doh.wa.gov/AboutUs/ProgramsandServices/EnvironmentalPublicHealth/Environmen

talHealthSafetyandToxicology/FishAdvisories.
113

For inhaled PCBs, EPA calculated indoor air guidance for schools ranging from 0.07-0.60 μg/m3

depending on the age of the children (see Table 30). These EPA calculations account for

additional average exposures through diet, water, air and other sources and would maintain 

children’s exposure levels below the RfD of 0.02 μg/kg/d (EPA 2012c). Residential indoor air 

levels would need to be lower to reflect the longer hours spent at home.

Public health guidance for PCBs in ambient air are lower still and assume exposure 24 hours a 

day and seven days a week. For inhalation of evaporated congeners, EPA IRIS assessment 

considers a concentration of 0.01μg/m3 to be conservative protection against cancer risk (EPA 

1997b). A variety of higher occupational inhalation exposure limits were established more than 

10 years ago, assume exposures to adults only, and assume exposure during a standard work 

week (see Table 30).

Table 30. Established health regulations/guidance for PCBs

Exposure Limits Agency Reference

Total oral daily 

intake-chronic

Oral Reference dose 

(RfDs

0.07 μg/kg/day 

(Aroclor 1016)

0.02 μg/kg/day 

(Aroclor 1254)

EPA, 2000

EPA, IRIS

http://www.epa.gov/iris/subst/0462.htm

http://www.epa.gov/iris/subst/0389.htm

Total daily 

intake of dioxinlike chemicals 

(TEQ)

0.7 pg/kg/day EPA, 2012 EPA, Dioxin Assessment

http://www.epa.gov/iris/subst/1024.htm

Total daily 

intake of dioxinlike chemicals 

(TEQ)

2.3 pg/kg/day WHO 2001 World Health Organization, Joint Expert Committee on Food 

Additives

Minimal Risk 

Level for 

chronic oral 

intake

MRL is 0.02 μg/kg/d

(based on Aroclor 

1254)

ATSDR, 2000 Toxicological Profile for PCB

http://www.atsdr.cdc.gov/toxprofiles/tp17.pdf

PCBs in specific 

foods

0.2-3.0 ppm in 

various categories of 

food.

FDA 1996 21 CFR 109

PCBs in edible 

fish entering 

interstate 

commerce

2.0 ppm FDA, 2011 http://www.fda.gov/downloads/Food/GuidanceRegulation/U

CM251970.pdf

PCBs in fish

Screening level of 

23 ppb in fish tissue 

(fillet)

DOH

See DOH website

http://www.doh.wa.gov/CommunityandEnvironment/Contam

inants/PCBs

PCBs in fish 5.3 ppb Fish tissue 

equivalent for NTR, 1999 National Toxics Rule 64 FR 61182

http://www.gpo.gov/fdsys/granule/FR-1999-11-09/99-25559
114

surface water quality 

criteria

Drinking water

MCL is 0.5 μg/L (or 

500 ppt). The MCL 

Goal is set at zero.

EPA1992 

(reviewed 

2010)

http://water.epa.gov/drink/contaminants/basicinformation/pol

ychlorinated-biphenyls.cfm

Bottled water 0.5 μg/L FDA, 1999 21 CFR 165.110

Ambient Air

0.01 μg/m3 based on 

cancer risk of 1 in 

1,000,000

EPA, 2000 EPA IRIS

http://www.epa.gov/iris/subst/0294.htm

Indoor air –

schools*

0.07-0.60 μg/m3

depending on age of 

children present.

EPA http://www.epa.gov/pcbsincaulk/maxconcentrations.htm

Occupational air 1.0 μg/m3 NIOSH, 2000 Http://www.cdc.gov/niosh/npg

Occupational air

1,000 μg/m3

(Aroclor 1254); 500 

μg/m3 (Aroclor 

1242)

OSHA 1998-29 CFR 1910.10003

PCB Exposures in People

PCBs are absorbed primarily from the diet and air, accumulate in fatty tissues, and are excreted, 

often very slowly, from the human body. PCBs are readily absorbed from the gastrointestinal 

tract. Absorption efficiency across the gut is higher with more chlorinated congeners. Once in the 

blood stream, PCBs are rapidly cleared and initially accumulate in liver and muscle tissue. In 

general, PCBs then redistribute to adipose tissue and skin but this varies depending on the 

congener (ATSDR 2000). For instance, PCB 126 is a coplanar PCB and binds very tightly to 

CYP1A2 and subsequently concentrates in the liver of rodent. Other highly persistent PCBs 

(e.g., PCB 153) are stored primarily in the adipose tissue and skin. There are also gender 

differences in storage of PCBs (Feeley and Jordan 1998). Metabolism of PCBs involves 

metabolic enzymes called cytochrome P450 enzymes (CYP). Specific subtypes involved in PCB 

metabolism are CYP1A1 and 1A2, CYP2B1 and 2B2, and CYP3A. Metabolism can lead to 

biologically active arene oxides and hydroxylated and methysulfonyl metabolites. Elimination of 

PCBs from the body is largely dependent on biotransformation of congeners to more polar 

metabolites. Half-lives for PCBs congeners in humans are estimated at 1.4-4.9 years for lightly 

chlorinated PCB 28 and 10-15 years for the more chlorinated congeners such as PCB 153, 170, 

and 180 (Ritter et al. 2011). Longer half-life estimates have also been reported (ATSDR 2000, 

Milbrath et al. 2009). Because PCBs are more readily absorbed than excreted, they accumulate 

in the body over time.

PCB Body Burden in the General U.S. Population

PCBs are widely detected in adipose tissue and blood of people (Lordo et al. 1996, CDC 2009). 

PCB in serum is a common indicator of body burden since there is a dynamic equilibrium 
115

between PCBs stored in fat and PCBs circulating in blood. Most studies of PCBs in serum report 

lipid-adjusted measurements to correct for short-term fluctuation in circulating lipids.

Since the 1980s, body burdens of PCBs in the U.S. have declined by more than 80% and 

continue to decrease (CDC 2009, Longnecker et al. 2003, Woodruff et al. 2011, Xue et al.

2014). Recent estimates of body burden of PCBs in the U.S. general population are available 

from the National Health and Nutritional Examination Study or NHANES (CDC 2009). This 

survey sampled serum for 34 PCB congeners in 2001-2002 and added four dioxin-like PCB

congeners in 2003-2004 for a total of 38 congeners. In the 2003-2004 survey, 100% of the 1866 

participants sampled had detectable levels of PCBs in their serum (Patterson et al. 2009). The 

primary congeners detected were PCB 153, 180, and 138/158. PCB 28, 74, 118, 170, and 187 

were also frequently detected (Table 31 lists NHANES results). The sum of 35 PCB congeners in 

participants had a mean of 134.4 ng/g blood lipid (0.820 ng/g whole weight blood). Five percent 

of the participants sampled had a sum of PCB in blood higher than 530.7 ng/g lipid weight 

(3.531 ng/g whole weight) (Patterson et al. 2009). The TEQ of total dioxins, furans and dioxinlike PCB in the NHANES 2001-2002 survey was calculated to be 30.4 pg/g lipid for the general 

population. The nine PCB congeners with dioxin-like properties contributed 38-41% of the TEQ 

depending on the age of the participant (Ferriby et al. 2007). Both studies showed that increasing 

PCB body burden is strongly associated with increasing age.

Table 31. Sum of 35 PCB congeners in 2003-04 NHANES survey (Patterson et al. 2009)

Age of participant 50th percentile for 

population (CI)

95th Percentile for 

population (CI)

Population 

sample size

12-29 years 51.2 (48.2-56.1) 139.0 (110.8-164.3) 585

20-39 years 75.4 (71.2–81.7) 226.5 (170.6-300.5) 452

40-59 years 174.4 (159.9-201.9) 470.7 (373.5-650.9) 383

60+ years 334.5 (308.7-351.8) 929.4 (752.2-1167.9) 446

Total (all ages) 131.8 (121.8-145.5) 530.7 (498.4-570.2) 1866

Serum levels in ng/g blood lipid

CI is the 95% confidence interval for the estimate of percentile in the study population.

Greater body burdens of PCB congeners that readily bioconcentrate have been observed in avid 

consumers of seafood or land and marine mammals that eat a diet rich in fish. (Dewailly et al. 

1993; Ayotte et al. 1997, Muckle et al. 1998, Fängström et al. 2002, Grandjean et al. 2001).

Lightly chlorinated PCB congeners (congeners 1-52) may be elevated in people exposed to PCBs 

in ambient or indoor air. Disposal and recycling workers may have elevated exposures to the full 

spectrum of PCB congeners in the initial Aroclor mixtures.
116

PCB Exposures to Developing Children

Fetal and early life are considered the most sensitive life stage for PCB toxicity so it is important 

to understand early life exposure to PCBs. PCBs cross the placenta of experimental animals and 

humans. When PCB level is adjusted for percent lipid in the blood, there is no difference 

between PCB blood levels in maternal serum and cord blood at the time of birth (Jacobson et al. 

1984).

PCBs stored in fat and fatty tissues are mobilized as serum lipids increase during the normal 

course of pregnancy. Median concentration of total serum lipids increased 43% and median 

serum levels of PCBs increased 34% between the first and third trimesters in a study of 67 

women. The increase was completely explained by the increase in lipids; when results were lipid 

normalized there was no difference in μg PCB/g serum lipid (Longnecker et al. 1999).

The body burden of PCBs accumulated over a lifetime is thought to be the primary determinant 

of circulating levels of PCB during pregnancy; however, a study reported by Humphrey in 1989 

demonstrated that a single meal could conceivably expose a fetus to a transient peak of PCBs. In 

his measurements following a meal of Great Lakes fish (fish contained 4-10 ppm PCB) he 

observed a short-term spike of 250-500% above serum baseline in healthy volunteers. Most fish 

consumed in the U.S. today are about 1000 times less contaminated than the fish used in 

Humphrey’s experiment.

Breast milk has healthy fat to support the rapid growth of babies. PCBs can accumulate in fat and 

be transferred to babies during nursing. The PCB body burden of children at four years old is 

strongly related to the level of contamination in milk and duration of lactation (Swain 1991,

Patandin et al. 1999, Walkowiak et al. 2001). Blood levels of PCBs in Japanese children of 

occupationally-exposed parents also showed a strong correlation with length of lactation (Hara

1985). By some estimates, human infants can receive up to 10-12% of their lifetime dose from 

nursing (Birnbaum and Slezak, 1999).Breast milk samples from 40 first-time mothers from the 

Pacific Northwest of the U.S. and Canada were analyzed for PBDEs and PCBs (She et al. 2007). 

Total PCBs were calculated by summing values of 82 separate PCB congeners and ranged from 

0.049 to 0.415 mg/kg lipid. This is 10-100 times lower than the levels documented in breast milk 

in the 1980s in a North Carolina study and further evidence that PCBs in U.S. breast milk have 

declined since PCB production ceased (Pan et al. 2009, Zietz et al. 2008). PCB in breast milk 

should not deter women from nursing because studies have shown that even breast milk with 

PCBs has a net benefit on cognitive and motor development of children compared to formula-fed 

children (see DOH Recommendation for Breast Feeding).
117

Sources and Pathways of Human Exposure

PCBs in Food

PCBs in food are the most significant source of exposure for most people. Recent studies on fish 

indicate concentrations of PCBs can be in the 10 to 100 parts per million in fish (especially 

freshwater fish). High levels are typically found in top predator fish, in bottom-feeding fish such 

as carp and large scale suckers, and in fish living near known sources of PCB contamination.

Meat and dairy products are generally much lower in PCBs with concentrations in the low parts 

per billion (see Table 34). A recent analysis of 2001-2004 NHANES data looked at food 

consumption patterns in a general U.S. population relative to 30 PCB congeners measured in 

their serum (Xue et al. 2014). The study found a strong correlation between serum PCB and 

reported fish consumption but no measurable correlation with consumption of meat or milk.

PCBs in Freshwater Fish Species from Washington State

PCBs can be highly concentrated in the fish of waters contaminated with even low levels of 

PCBs. The Washington State Department of Ecology routinely conducts fish tissue monitoring 

as part of its Washington State Toxics Monitoring Program (WSTMP). Between these two 

programs, thousands of fish have been sampled from hundreds of sites across Washington State. 

Figure 27 displays the distribution of total PCB tissue concentrations from fish collected across 

Washington State from several sources.
118

Figure 27. Washington Statewide PCB Distribution in Freshwater Fish Fillets 2001-2012. Data 

sources: 2001-2010 total PCB fish tissue concentrations extracted from Ecology’s EIM database 

(Seiders 2012), EPA’s Upper Columbia River site investigation as reported by Health (WDOH 

2012), U.S Department of Energy’s 2012 assessment of contaminant data in the Mid-Columbia 

River, and fish tissue data provided to Health by the U.S. Army Corps of Engineers near Bradford 

Island and the Bonneville Dam on the Columbia River (unpublished data). NTR and Health 

screening levels for PCB concentration in fish tissue are displayed for reference.

The data set displayed in Figure 27 includes 353 total PCB values that range from non-detects to 

greater than 26,000 ppb, with a median of 8.7 ppb. The maximum detection is from a single bass 

collected near the Bonneville Dam in the Columbia River.

PCBs in Commercially Available Fish in Washington State

Limited data on PCBs in commercially available fish are also available for Washington State. 

The primary source of this data is a Washington Department of Health 2005 study of 

contaminants in canned tuna and other frequently consumed store bought fish purchased in 

0.1

1.0

10.0

100.0

1000.0

10000.0

0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0%

Total PCB Concentration (ppb wet weigtht)

Percentile (n=353)

Washington Statewide PCB Distribution in 

Freshwater Fish 2001-2012

National Toxics Rule (NTR) calculated level 5.3 ppb

DOH Fish Advisory Screening Level 23 ppb
119

Washington State grocery stores (McBride et al. 2005). In this study, PCBs (based on Aroclors 

concentrations) were detected in store-bought halibut, red snapper, and salmon in at least 10% of 

the samples collected. Salmon had the highest average PCB concentrations (31.5 ppb PCBs, total 

Aroclors). Additional data from the Washington State Department of Fish and Wildlife on PCB 

levels in Puget Sound Chinook and coho salmon were also included for this assessment (WDOH 

2006). A comparison of PCB concentrations in store bought and Puget Sound commercially 

available fish can be seen in Figure 28. Of all fish species, PCB concentrations were highest in 

Chinook salmon collected in Puget Sound. PCB levels in Chinook salmon returning to Puget 

Sound waters typically have higher concentrations than coastal salmon or Alaskan Chinook. The 

higher concentration in Puget Sound Chinook and resident Blackmouth is believed to be due to 

residence time in areas such as Puget Sound that have greater PCB loads. DOH recommends that 

women of childbearing age and young children should eat no more than one meal per week of 

Puget Sound Chinook salmon. Most fish species collected from grocery stores were below 

Health’s general screening level of 23 ppb.

Figure 28. Mean PCB concentrations (total Aroclors) in fish collected from markets and grocery 

stores in Washington State and from Puget Sound. Data Source: McBride et al. 2005.

0 20 40 60

Flounder/Sole

Cod (Pacific)

Pollock/Fishsticks

Tuna (canned, white albacore)

Halibut (Pacific)(Atlantic)

Rockfish/Red Snapper

Catfish

Farmed Salmon (Atlantic)

Salmon (Coastal/Alaska)

Coho Salmon (Puget Sound)

Chinook salmon (Puget Sound)

PCB Concentrations in Commercial Fish 

Purchased in WA Stores 

PCB concentration in fish tissue (ppb) 
120

Other Dietary Sources of PCBs

Humans may be exposed to small but detectable quantities of PCBs in meat, dairy products, and 

other foods. PCB concentrations in fish, meat, and dairy products vary widely depending on 

where they are grown and how they are processed or cooked. Sampling for PCB concentrations 

in FDA’s Market Basket studies between 1991 and 2003 showed PCB levels are far below FDA

limits in a variety of prepared dishes. This section summarizes the limited data available from 

various U.S. and international sources.

The Total Diet Study (TDS), sometimes called the market basket study, is an ongoing FDA 

program that determines levels of various contaminants and nutrients in foods. 

http://www.fda.gov/downloads/Food/FoodScienceResearch/TotalDietStudy/UCM184304.pdf. A 

unique aspect of the TDS is that foods are prepared as they would be consumed (table-ready) 

prior to analysis, so the analytical results provide the basis for realistic estimates of the dietary 

intake of these analytes. TDS Market Basket surveys are generally conducted four times each 

year, once in each of four geographic regions of the countries. Food samples are purchased from

supermarkets, grocery stores, and fast food restaurants in three cities in the region and are shipped

to a central laboratory. The foods are then prepared table-ready and the three samples are

combined to form a single analytical composite for each food. For each survey, samples of food 

are collected over a 5-week period. Table 32 presents data collected from 1991 through 2004 for

PCBs in 26 separate food items. Total PCB concentrations are expressed as Aroclor equivalents,

rather than as the sum of congener-specific measurements. Mean PCB concentrations ranged 

from 0.09 ppb for chicken potpie to 24.4 ppb for salmon.

PCB concentrations in foods from the market basket survey are much lower than previously 

reported by the Puget Sound Action Team in 2007 and cited by Ecology’s Toxics Cleanup 

Program (Ecology 2012d). PCB levels in foods reported by the Puget Sound Action Team were 

based on very small sample sizes of one or two. FDA data presented in Table 32 are based on 

average samples sizes of 40 resulting in more robust, representative PCB levels. The state of 

origin of the food sampled is not available.
121

Table 32. Measured PCB Levels as Reported by U.S.FDA

Food Description Sample 

Size

Results

Concentration (ppb) Detection 

Mean Maximum Frequency %

Chicken potpie, frozen, heated 44 0.09 4 2.3

Candy, caramels 40 0.15 6 2.5

Beef roast, chuck, oven-roasted 44 0.23 10 2.3

Pork roast, loin, oven-roasted 44 0.23 10 2.3

Lamb chop, pan-cooked w/ oil 44 0.23 10 2.3

Chicken, drumsticks and breasts, breaded and 

fried, homemade 40 0.23 9 2.5

Corn/hominy grits, enriched, cooked 44 0.23 10 2.3

Cornbread, homemade 44 0.23 10 2.3

Biscuits, refrigerated-type, baked 44 0.23 10 2.3

Raisins 44 0.23 10 2.3

English muffin, plain, toasted 44 0.23 10 2.3

Veal cutlet, pan-cooked 40 0.25 10 2.5

Crackers, butter-type 44 0.25 11 2.3

Pork chop, pan-cooked w/ oil 44 0.45 20 2.3

Meatloaf, beef, homemade 44 0.45 20 2.3

Beef (loin/sirloin) steak, pan cooked with 

added fat 40 0.5 20 2.5

Pancakes made from mix with addition of egg, 

milk, and oil 40 0.5 20 2.5

Baby food, vegetables and chicken 44 0.68 30 2.3

Brown gravy, homemade 40 0.75 30 2.5

Tuna, canned in oil, drained 40 1.0 40 2.5

Eggs, fried with added fat 40 1.23 39 5.0

Chicken breast, oven-roasted (skin removed) 44 1.36 30 4.5

Popcorn, popped in oil 40 1.7 30 10.0

Butter, regular (salted) 44 3.18 120 4.5

Catfish, pan-cooked w/ oil 4 4.25 17 25.0

Salmon, steaks/fillets, baked 24 24.38 55 91.7

Table 32 summarizes PCB analytical results of food from the Food and Drug Administration’s Total Diet 

Study program. The information pertains to Total Diet Study market baskets 1991-93 through 2003-04. 

Statistics were calculated using value of zero for results below the detection limit. This document is 

available on the internet at: http://www.cfsan.fda.gov/~comm/tds-res.html.
122

In addition to the U.S.FDA information, Arnold Schecter and colleagues at the University of 

Texas in Dallas have analyzed PCB concentrations in foods in the U.S. over the past 15 

years. These studies have focused on common foods in the American diet that were 

collected throughout the country. The following summarizes those individual studies and a 

compilation of the data is presented in Table 33.

• Schecter et al. (1997) pooled food samples collected from grocery stores across the

U.S. and measured 15 different PCB congeners, including eight coplanar PCBs, three

mono-ortho PCBs, and four di-ortho PCBs. A total of 90 individual food specimens

were pooled into 12different food types (e.g., cheese, beef) and analyzed for dioxins,

dibenzofurans, and PCBs. Based on a conversion of the measured congeners, the

authors conclude that PCBs contribute significantly to total TEQ values in eight out 

of 12 sample types.

• Schecter and Li (1997) measured dioxin-like PCBs in U.S. fast food purchased at 

five cities across the US. Samples were pooled by type and tested for seven monoand di-ortho PCBs. Total PCB levels ranged from 0.957 ppb (McDonald’s Big Mac) 

up to 1.180 ppb (Pizza Hut Personal Pan Supreme with anchovies). The authors 

estimate that fast food accounts for roughly 16.7-52.7% of the total daily TEQ of 

dioxin-like compounds.

• Schecter et al. (1998) analyzed both cooked and uncooked samples of beef, bacon, 

and catfish from a supermarket in Binghamton, New York. A total of five cooked, 

and four uncooked samples of each type of meat were analyzed for dioxins, 

dibenzofurans, and three dioxin-like PCBs (77, 126, 169). Total PCB concentration 

for each food type ranged from 1.028 ppb (wet weight) (uncooked hamburger) to 

5.370 ppb (cooked bacon). Broiling each type of sample resulted in a 50% decrease 

on average in total PCDD, PCDF, and coplanar PCB TEQ. However, broiling of 

hamburger resulted in an increase of total coplanar PCB concentration of 10.4%; 

broiling bacon resulted in an increase of 75.7% of total coplanar PCB concentration. 

The authors conclude that final concentrations (pg TEQ/kg) of PCDDs, PCDFs, and 

coplanar PCBs in broiled foods cannot be accurately predicted from raw samples due 

to variances in cooking method.

• Schecter et al. (2002) analyzed a total of 72 meat baby food samples purchased from

grocery stores across the U.S. (Illinois, Nebraska, California, Georgia, New York,

Pennsylvania, and Maryland). Three to six samples (200 g each) were purchased from

each state, and analyzed for dioxins and three coplanar PCB congeners (77, 126, and 

159). Total PCBs for each food sample type range from 0.579 ppb (wet weight) (lamb)

to 2.280 ppb (chicken). Converted TEQ concentration for total PCBs for each food

type ranged from 17.6 (lamb) to 95.9 (beef). The authors note that for the turkey, beef,

lamb, and ham samples, total PCBs contributed more to total TEQ values than did the 

PCDD/PCDF values.
123

• Schecter et al. (2010) study expanded their previous studies of persistent organic 

pollutants contamination, including PCBs in composite U.S. food samples collected in 

Dallas, Texas. The study showed that PCBs were not detected by congener analysis in 

any meats except hamburger, in any fish except salmon and canned sardines, or in any 

dairy products or eggs.

Overall, Schecter and colleagues have shown that the PCB levels in foods common in the U.S. 

are typically low relative to freshwater fish species collected in Washington State. PCB levels in 

foods other than fish are generally in the low single digit parts per billion range whereas 

freshwater and marine fish species are generally one, two, and sometimes three orders of 

magnitude higher. Even when beef, chicken, and pork consumption rates are greater than fish 

consumption rates, dietary exposure to PCBs is dominated by the consumption of fish.
124

Table 33. Level of PCBs in U.S. Foods (1994 – 2009)

Location (date) Type of Sample PCB congeners Food (sample size) Total PCB concentration ppb (wet weight) Reference

Total coplanar 0.0428 ng/g; Schecter et al. 1997

mono-ortho 0.344 ng/g; di-ortho

0.593 ng/g

Total 0.980 ppb

Total coplanar 0.132 ng/g; mono- ortho 0.403 

ng/g; di-ortho 0.505 ng/g

Total 1.04 ppb

Total coplanar 0.182 ng/g; monoortho 0.375 ng/g; di-ortho 0.322 ng/g

Total 0.879 ppb

Total coplanar 0.156 ng/g; monoortho 1.500 ng/g; di-ortho 1.871 ng/g

Total 3.027 ppb

Total coplanar 0.0006 ng/g; monoortho 0.064 ng/g; di-ortho 0.147 ng/g

Total 0.212 ppb

Total coplanar 0.0017 ng/g; monoortho 0.240 ng/g; di-ortho 0.342 ng/g

Total 0.584 ppb

Total coplanar 0.004 ng/g; monoortho 1.150 ng/g; di-ortho 2.080 ng/g

Total 3.23 ppb

Total coplanar 0.0001 ng/g; mono- ortho and diortho ND

Total 0.0001 ppb

Total coplanar 0.0004 ng/g; mono

and di-ortho ND

Total 0.0004 ppb

Total coplanar 0.0002 ng/g; monoortho 0.015 ng/g; di-ortho 0.144 ng/g

Total 0.159 ppb

Hamburger, McDonalds Big Mac (5) mono & di-ortho total 0.957 ppb Schecter and Li 1997

Pizza, Pizza Hut Supreme (5) mono & di-ortho total 1.180 ppb

Chicken, KFC Original Recipe (5) mono & di-ortho total 1.170 ppb

Hamburger, cooked (5) Mean 1.401; range 1.204-1.601 ppb Schecter et al. 1998

Hamburger, uncooked (4) Mean 1.270; range 1.028-1.736 ppb

Bacon, cooked (5) Mean 2.734; range 1.722-5.370 ppb

Bacon, uncooked (4) Mean 1.556; range 1.205-1.971 ppb

Catfish, cooked (4) Mean 3.188; range 1.945- 3.963 ppb

Catfish, uncooked (4) Mean 4.691; range 2.200-6.387 ppb

Chicken Range 0.883-0.228 ppb Schecter et al. 2002

Turkey Range 0.144-0.160 ppb

Beef Range 0.150-0.225 ppb

Lamb Range 0.579-0.844 ppb

Ham 0.771 ppb

Hambuger PCB-153 1.2 ppb; PCB-180 0.21 ppb Schecter et al. 2010

Salmon

PCB-52 0.28 ppb; PCB-101 0.51 ppb; PCB-118 

0.43 ppb; PCB-138 0.93 ppb; PCB-153 1.21 ppb; 

PCB-180 0.44 ppb 

Canned Sardines

PCB-52 0.28 ppb; PCB-101 0.67 ppb; PCB-118 

0.80 ppb; PCB-138 1.80 ppb; PCB-153 1.83 ppb; 

PCB-180 0.49 ppb 

Bacon Non-detected

Turkey Non-detected

Sausages Non-detected

Ham Non-detected

Chicken breast Non-detected

Roast beef Non-detected

Canned chili Non-detected

Catfish fillet Non-detected

Tilapia Non-detected

Cod Non-detected

Frozen fish sticks Non-detected

Butter Non-detected

American cheese Non-detected

Other cheese Non-detected

Whole milk Non-detected

Yogurt Non-detected

Cream cheese Non-detected

Eggs Non-detected

PCBs, 52, 101, 118, 

138, 153, 180 Dallas, TX (2009) Supermarkets

Beef (5 pooled)

Chicken (4 pooled)

Pork (5 pooled)

Hot dog/bologna (2 pooled)

Eggs (3 pooled)

Cheese (5 pooled)

Butter (2 pooled)

Ice cream (5 pooled)

Milk (5 pooled)

Across U.S. (IL, NE, 

CA, GA, NY, PA, MD) 

(1998)

Baby Food 

Grocery Stores PCBs 77, 126, 159

Vegan diet (1 pooled)

Fast Food 

Restaurants

Grocery Stores

PCBs 105, 

118,156,128,138,153,

180

Coplanar PCBs 

77,126, 169

Binghamton, NY 

(1996)

Across U.S. (1995)

15 total, including 8 

coplanar, 3 monoortho, and 4 di-ortho 

PCB congeners

Across U.S. (1995) Grocery Stores
125

PCB Contribution to Dioxin TEQ in Food

Coplanar PCB congeners act toxicologically like dioxins and contribute to the total dioxin TEQ 

in foods. The National Academies of Science provided a comprehensive compilation of data on 

dietary exposure to dioxin and dioxin-like compounds including PCBs (NAS 2003). Estimates of 

exposure are based on concentrations of dioxins and dioxins-like compounds measured in foods 

and dietary consumption habits of those foods. The dioxin and PCB food concentration data 

were based on the U.S. Food and Drug Administration’s Total Diet Study (FDA 2006). The NAS 

report identifies that dietary sources of animal fat are by far the largest source of dioxin exposure 

to the general population, with 90% of total exposure being due to consumption of food –

namely animal products and their associated animal fats (beef, pork chicken, fish, fats (butter), 

and dairy products. The NAS reported that estimates of the contribution of PCBs to dietary 

dioxin TEQ range from 37-57% and concluded that 50% was a reasonable estimate (NAS 2003).

EPA’s 2000 Draft Dioxin Reassessment (EPA 2000a) summarized the available data on 

background concentrations in foods for the United States. Using that data and standard 

assumptions for intake, they developed an estimate of general background exposure to coplanar 

PCBs. The estimates assume concentrations in food reported as nondetected are present at 1⁄2 the 

detection limit. EPA estimated background exposure to adults in the general population to be 

0.64 pg/kg/day for dioxins and furans and 0.34 pg/kg/day for dioxin-like PCBs. Based on EPA’s 

analysis, coplanar PCBs account for approximately one-third of total dioxin-TEQs (Smith and 

Frohmberg, 2008). See Table 34.

Table 34. Estimates of Background Dietary Exposure to Dioxins and Coplanar PCBs on a Toxic 

Equivalents (TEQs) Basis.

Chemical

Estimated Exposure 

Assuming NDs = 0 

(pg/kg/day)

Estimated Exposure

Assuming NDs = 1/2 

DL (pg/kg/day)

Dioxins/Furans TEQs 0.38 0.64

Coplanar PCB TEQs 0.34 0.34

Total TEQ 0.72 0.98

% Contribution of 

Coplanar PCBs to Total 

TEQs

47% 35%

EPA RfD for dioxin (noncancer endpoints) 0.7 pg/kg/d 0.7 pg/kg/d

(Source: Smith and Frohmberg, 2008)

ND = non-detected, DL= Laboratory detection limit

In summary, food and especially fish appear to be major contributors to PCB exposure in the 

U.S. population. With few exceptions, freshwater fish species have the highest PCB levels. Mean 

PCB concentration of all Washington state freshwater fish for which Health has issued fish 

consumption advisories is over 150 times higher than the mean PCB concentration reported in 

other common food items. Freshwater fish species in Washington are over ten times higher than 
126

PCB concentrations measured in commercially available fish in Washington State stores. 

Commercially purchased fish PCB levels are also greater than mean PCB concentrations of other 

non-fish foods tested by a factor of ten (Figure 29). Such comparisons illustrate the relative 

contribution of freshwater fish species to an individual’s dietary PCB exposure, particularly for 

high fish consumers. Those individuals or groups that rely on freshwater fish species as an 

important component of their diet are potentially at greater exposure to PCBs and 

correspondingly at greater health risk.

Dioxin-like PCBs are significant contributors to dietary dioxin burden in the U.S. and the total 

dioxin burden appears to be at the EPA reference dose for dioxin TEQ.

The PCBs in fish are relatively well studied and this source of exposure has a robust health 

literature pointing to adverse health impacts. The most vulnerable lifestage to PCB exposure 

appears to be fetal development. Although U.S. exposures have dropped dramatically since the 

1980s, Avid consumers of Puget Sound salmon, freshwater sports fish like bass, and other fish 

from contaminated waters are still at risk for elevated exposure. Reducing PCB exposure in 

people will require efforts to reduce PCB levels in freshwater and some marine fish and to 

mitigate the sources of PCB loading to the waters where they live.
127

Figure 29. PCB Concentrations (ppb) in Sportcaught Fish Collected in Washington, Commercial Fish Purchased in Washington, & Common Foods

Data sources: WA freshwater fish data 2001-12 in Ecology EIM database, U.S. Dept. of Energy, WA Dept of Health commercial fish study (McBride et 

al.,2005), FDA Total Diet Study 1991-2006. Only a subset of the state’s freshwater fish PCB data are shown to represent those species associated with 

Health fish advisories based on PCB levels.

0 200 400 600 800 1000 1200 1400 1600 1800 2000

Chicken potpie, frozen, heated

Candy, caramels

Beef roast, chuck, oven-roasted

Pork roast, loin, oven-roasted

Lamb chop, pan-cooked w/ oil

Chicken, drumsticks and breasts, breaded and fried, homemade

Corn/hominy grits, enriched, cooked

Cornbread, homemade

Biscuits, refrigerated-type, baked

Raisins

English muffin, plain, toasted

Veal cutlet, pan-cooked

Crackers, butter-type

Pork chop, pan-cooked w/ oil

Meatloaf, beef, homemade

Beef (loin/sirloin) steak, pan cooked with added fat

Pancakes made from mix with addition of egg, milk, and oil

Baby food, vegetables and chicken

Brown gravy, homemade

Tuna, canned in oil, drained

Eggs, fried with added fat

Chicken breast, oven-roasted (skin removed)

Popcorn, popped in oil

Butter, regular (salted)

Catfish, pan-cooked w/ oil

Flounder/Sole

Cod (Pacific)

Pollock/Fishsticks

Tuna (canned, white albacore)

Halibut (Pacific)(Atlantic)

Rockfish/Red Snapper

Catfish

Farmed (Atlantic)

Salmon, steaks/fillets, baked

Salmon (Coastal/Alaska)

Coho (Puget Sound)

Coho

Smallmouth Bass

Chinook salmon (Puget Sound)

Bridgelip Sucker

Channel Catfish

Largescale Sucker

English Sole

Chinook

Smallmouth Bass

Common Carp

Rainbow trout

Common Carp

Mt Whitefish

Quillback Rockfish

Brown Trout

Northern Pikeminnow

Largescale Sucker

Smallmouth Bass

Sturgeon

Brown Rockfish

Common Carp

Common Carp

Cutthroat Trout

Northern Pikeminnow

Common Carp

Walleye

Largescale Sucker

Common Carp

Lake Whitefish

Mountain Whitefish

Smallmouth Bass*

Smallmouth Bass **

* > 25,000 ppb

** > 180,000 ppb

Common foods

Marine fish 

Washington freshwater fish

/ //

Dashed line indicates level of concern,

above which an advisory may be warranted

PCB concentration (ppb) -->
128

PCBs in Ambient Air

PCBs with fewer chlorines can volatilize from water, soil, or contaminated materials and effect 

local air concentrations (ATSDR 2000, Carlson and Hites 2005, Du et al. 2009).They can also be 

transported long distances by global air currents and have been detected polar research stations 

where no local sources exist (Choi et al. 2008). Heavier PCBs are not volatile but can 

contaminate air when adhered to demolition dust, wind-blown dust, and airborne particulate. 

Inhalation was thought to be the primary pathway of occupational exposure to PCBs historically 

but was largely ignored for general population exposures until recently. PCB air monitoring 

started in Chicago in 1995 and found surprising PCB concentrations in urban air. Hu et al. 2008 

analyzed for 209 PCB congeners in Chicago area air and reported an annual average of 0.000835 

μg/m3 (range 0.000075 to 0.0055 μg/m3). Similar air concentrations results have been reported 

from the Philadelphia, PA (Du et al. 2009) and Cleveland, OH (Basu et al. 2009). Air levels at 

least an order of magnitude lower have been detected in polar regions (Choi et al. 2008) and in 

various remote locations around the Great lakes region (Basu et al. 2009).

Only limited air sampling for PCBs has been conducted in Washington State. Bulk air deposition 

samplers have been used to estimate the load to Puget Sound soils and water surfaces (Ecology 

2010d). These results are not adequate for estimating inhalation exposure for health risk 

assessment because the lighter gas phase PCBs would be largely missed by these samplers.

One EPA pilot study analyzed air samples collected in year 2000 from rural areas of the U.S. for 

six PCBs that are considered dioxin-like. This study included one site on the Olympic Peninsula 

in Washington. PCB 118 was the most common dioxin-like PCB detected (0.337 pg/m3). PCB 

105 was detected at 0.115 pg/m3, PCB 156/7 were detected at 19.7 fg/m3, 77 was detected at 16 

fg/m3

, and PCB 126 and 169 were detected at 1 fg/m3 or less (EPA 2007).

The reported levels of PCBs in ambient air are generally well below EPA level of human health 

concern. The maximum PCB levels reported on hot summer days in Chicago was 0.0055 μg/m3

which is still below the EPA “de minimus” cancer risk estimate for chronic inhalation of 

evaporated PCB congeners (0.01 μg/m3).

Congener profiles of PCBs in ambient air differ both from profiles of commercial Aroclors and 

from congeners that partition to fish. Although the full spectrum of congeners has been detected 

in ambient air, lightly chlorinated congeners predominate (PCBs 1-52). Lighter congeners are 

more quickly eliminated from the body and their toxicological properties are less studied. This 

introduces uncertainty in the exposure and toxicity assessment of the mixture. Norström et al.

2010 conducted modelling to predict the contribution to PCB body burden from breathing urban 

air contaminated with a profile of PCBs similar to those detected in Chicago air. Their model 

suggests that urban air would not significantly impact the body burden of congeners associated 

with dietary uptake such as PCB 153, 180, and 183 but could contribute to human body burden 

of PCB 28, 33, and 52 by as much as 30% depending on the congener (Norström et al. 2010). 
129

The toxicological relevance of inhaling congeners in urban air was investigated by Hu et al.

2012. They conducted a subchronic rodent inhalation assay with a cocktail of PCBs representing 

urban air and observed for immune responses, microsomal enzyme induction, cellular toxicity 

and histopathologic abnormalities. The minimal effects detected are suggestive of mild oxidative 

stress during the course of treatment.

The toxicological relevance of lighter chlorinated congeners must also consider the impact of 

metabolites produced once these lighter PCBs are absorbed into the body. For example, some 

PCB 3 metabolites are genotoxic and have been shown to cause point mutations in rodents (Xie 

et al. 2010, Robertson and Ludewig 2011). There is also limited evidence of tumor initiating 

activity of PCB 3, 15, 52 and 77 in a rodent model (Espandiari et al. 2004). Congeners like PCB 

11 may be transformed into metabolizes that contribute to oxidative stress and cellular damage 

(Zhu et al. 2013). This is an active area of research and more study is needed to understand the 

potential toxicity of lower chlorinated PCBs and their metabolites.

PCBs in Indoor Air (Caulk, Joint Sealants, Lamp Ballasts)

PCBs were used as plasticizers and flame retardants in building materials such as some elastic 

caulks, joint sealing compounds for brick and masonry buildings, exterior paints, window 

glazing, ceiling tile coatings, and some floor finishes sold in the 1950-1970s. PCBs were also 

widely used in fluorescent lighting ballasts installed during this same period. In different 

investigations since 1980, these materials have been identified as sources of elevated PCB levels 

in air in schools, office buildings, large apartment complexes, and other buildings. A few 

examples are listed below.

EPA investigated PCB levels at six unoccupied schools in New York that were scheduled for 

major renovation or demolition and were suspected of containing PCB sources (EPA 2012c). 

EPA measured PCBs in air and surface wipes in the buildings and estimated student exposures 

before and after PCB remediation. EPA estimated doses for an average student were 0.022 

μg/kg/day before remediation and 0.007 μg/kg/d after. Estimates of higher student exposure 

scenarios were 0.041 μg/kg/day before remediation and 0.012 μg/kg/day after. PCB light ballasts 

and caulk were considered the primary PCB sources in the schools and inhalation the primary 

exposure route. Remediation reduced estimated exposure by approximately two thirds. EPA 

conducted congener specific PCB analysis in one of the six schools. Average indoor air 

concentration of total PCBs in air was 0.50 μg/m3, the average TEQ of dioxin-like congeners in 

air was 0.788 pg/m3. (EPA 2012c). EPA research associated with this project confirmed that 

caulk with high levels of PCBs caused elevated PCB in the surrounding air, that light ballasts 

emit PCBs at normal operating temperatures even when there was no visible liquid leaking, that 

caulk with low levels of PCBs can be encapsulated to reduce emissions, and that a special 

treatment system can be effective in removing PCBs from thin surfaces such as wall paint (EPA 

2013h). In December 2010, EPA released national guidance recommending that schools remove 
130

all PCB-containing lighting ballasts. 

http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/ballasts.htm

Elastic joint sealants containing PCBs were found to be the source of elevated PCBs in indoor air 

at 29 sampling sites in various public buildings in Switzerland (Kohler et al. 2002). In most cases 

the indoor air levels of PCBs were below 1.50 μg/m3 but levels up to 4.20 μg/m3were detected. 

As a comparison, this study reported air levels of 13.0 μg/m3 PCB at an industrial building that 

formerly produced transformers. PCB congeners 28 and 52, used as indicators for the more 

volatile PCBs, predominated in all air samples. Dioxin-like PCBs were also measured (primarily 

PCB 118 and 105) and the TEQ was calculated using WHO 1998 TEFs. Emissions from joint 

sealants had a consistent ratio of dioxin-like PCBs to total PCBs. Air levels of 1.0 μg/m3 total 

PCBs corresponded to a 1.2 pg/m3 of dioxin-like PCBs. (Kohler et al. 2002).

Joint sealants were also the source of PCB contamination in a public building in Germany 

(Schettgen et al. 2012). Investigations included air measurements and biomonitoring of people 

who worked in the building. Workers from an uncontaminated building served as controls. 

Median air levels for total PCBs were reported as 1.74 μg/m3 with a maximum of 4.28 μg/m3

. 

Exposed workers had significantly higher blood levels of the more volatile PCBs (28, 52, 101 

and the dioxin-like congeners 105 and 118) but not heavier PCBs which constitute the bulk of

human body burden and are taken up primarily in the diet (PCB 138, 153, or 180). The 

calculated TEQ for dioxin-like congeners did not differ statistically between the groups. Followup monitoring of three people who were removed from the building demonstrated that levels of 

PCB 28, 52, and 101 declined steadily after removal and that the biological half-lives were 4.5 ± 

0.9 years for PCB 28, 1.3 ± 0.1 years for PCB 52, and 2.8 ± 0.7 years for PCB 101 (Schettgen et 

al. 2012). Longer retention of PCB 28 in the body may explain why PCB 52 predominated in air 

samples but PCB 28 predominated in serum samples.

Liebel et al. 2004 reported significantly higher median serum concentrations for PCBs 28, 52, 

and 101 in 377 children from the contaminated school in Germany compared to 218 students 

attending an uncontaminated school. There was a significant positive association between years 

spent at the contaminated school and serum levels of the combined lower chlorinated congeners. 

Air levels measured in multiple locations over two years in the school building ranged 0.004-

0.600 μg/m3 for PCB 28, 0.038-2.300 μg m3 for PCB 52, and 0.003-1.100 μg/m3 for PCB 101. 

Very little PCB 138, 153 or 180 were detected in air sampling. The authors estimated total PCB 

in air over the two-year period to be 0.690- 20.80 μg/m3 (mean 2.044 μg/m3

) based on 

measurement of six indicator congeners. When PCB congeners associated with dietary intake 

were considered, there was no statistically significant difference between overall PCB body 

burden in students from the two schools. Nor was there a detectable difference in a survey of 

children’s subjective symptoms.
131

Frederiksen et al. 2012 reported that mean PCB air levels in Danish multiunit housing was 

1.03 μg/m3 (range 0.168-3.843 μg/m3) in apartments that contained PCB in elastic sealants 

verses a mean of 0.006 μg/m3 in apartments sealed with PCB-free sealants. PCB sealants 

contained up 20% (221,680 ppm) PCB and were the primary determinant of indoor PCB levels. 

A survey of residents about their adherence to advice about minimizing their exposure showed 

that frequent ventilation, vacuuming, dusting, and floor washing were associated with lower 

indoor air levels.

In 2009, PCBs were discovered in chipping exterior paint on the former Rainier Brewery in 

Seattle at concentrations over 10,000 ppm PCB. This 4.5 acre site now houses mixed residential, 

restaurant, and business spaces. Paint chips were suspected to be the source of elevated PCBs in 

a nearby stormwater collection area. In 2010, sampling by EPA detected PCBs in indoor air in 

some office areas (0.010-0.028 μg/m3) and in an outside stairwell that had been enclosed with 

the exterior paint intact (0.052 μg/m3

). Sampling also detected PCBs in vacuum dust at 

concentrations between 1.4-15.6 ppm in residential and office spaces, 3.4-36 ppm in storage and 

warehouse areas, and 470 ppm in stairwell dust. DOH concluded that there was a very low to 

insignificant increase in cancer risk associated with the levels detected. Recommendations for 

mitigation included removing all paint with more than 50 ppm PCB (as required by law), 

warning occupants to avoid regular use of the external stairwell until remediation could take 

place, and adopting cleaning techniques that would reduce potential for human exposure 

(WDOH 2013b).

PCBs can bind to indoor dust and present an inhalation or ingestion pathway for people. Dust 

intake is associated with higher molecular weight PCBs than air exposures. A 2006 survey of 

PCBs in residential settings reported median dust concentrations to be 0.200 μg/kg dust (ppb) in 

20 Texas homes and 0.260 μg/kg in ten Toronto homes (Harrad et al. 2009). Maximum detected 

was 0.820 μg/kg PCBs in dust. While ingestion of house dust was a minor contributor to adult 

exposures, it contributed 1-20% of total PCB exposure to toddlers in exposure modelling (Harrad 

et al. 2009). Homes built before 1980 had higher PCB loading in house dust than more recently 

constructed homes in a large sampling of 415 homes in California (Whitehead et al. 2013). A 

recent study in China reported that house dust levels of PCBs were associated with subtle 

neurodevelopmental effects in pre-school aged children (Wang et al. 2015).

It appears that PCBs in older building materials can elevate PCBs in indoor air and dust and 

cause higher body burden of certain PCB congeners in the bodies of people living or working in 

these buildings. In some cases the detected air concentrations were high enough to exceed 

residential or occupational health guidelines. In the EPA investigation into older schools in New 

York, indoor air levels frequently exceeded EPA health guidance for schools of 0.70-0.60 μg/m3

depending on the age of the children present. EPA requires caulk with more than 50 ppm of 

PCBs to be removed. PCB containing fluorescent light ballasts that remain in service are 
132

generally more than 30 years and have exceeded their expected life-span. They are at high risk 

for over-heating and failing and should be removed and properly disposed.

PCBs in Pigments and Dyes

Residual PCBs in dyes and pigments have been detected in ambient air, food, water, and 

consumer products. Air monitoring studies of urban air and remote polar air detect PCB 11,

occasionally as a major component (Hu et al. 2008, Du et al. 2009, Basu et al. 2009, Choi et al.

2008). Consumer product testing has measured residual amounts of PCB 11 and other congener 

in a variety of colored paper, cardboard, and plastic packaging. (Hu and Hornbuckle 2010, 

Rodenberg et al. 2010). In Washington, PCBs associated with pigments and dyes have been 

identified in Columbia River water and clams and in a majority of fish sampled in a recent study 

in the Mid-Columbia. River (McCarthy 2007, Ecology 2005, U.S. Department of Energy 2010)

There is only limited investigation of absorption of PCB 11 into people. In rats, PCB 11 was 

rapidly absorbed via inhalation, distributed to tissue, and eliminated with half-lives in lung, liver 

and serum of approximately two hours. A hydroxylated metabolite of PCB 11 was also detected 

in the rodent liver (Hu et al 2013). Biomonitoring for PCB congeners unique to dyes and 

pigments (PCB 11) has detected PCB 11 in people. In a recent study, 65% of 85 women in a 

mid-West had traces of PCB 11 in their blood (Marek et al 2013). Three potentially toxic 

metabolites of PCB 11 have also been detected in human serum (Zhu et al. 2013).

There is only limited toxicity information specific to PCB 11. Zhu et al 2013, tested PCB 11 and 

the 4-hydroxymetabolite detected in human serum for toxicity in vitro. In this study, the PCB 11 

metabolite suppressed cell growth, created oxidative stress, and resulted in cytotoxicity. Coadministration of antioxidants partially protected against the observed effects. PCB 11 had no 

effect in the test (Zhu et al 2013). Further study is needed to understand the magnitude of human 

exposure to PCB 11 and its metabolites as well as their toxicity.

Other Environmental Exposures

Small amounts of PCBs can be found in almost all soil surfaces and sediments. Most soil levels 

of PCBs are less than 0.010-0.040 μg/kg (ppb) but soil at hazardous waste sites may be much 

higher. In water, a small amount of PCB may remain dissolved but most tends to stick to organic 

particles and sediments or evaporate from the water surface (ATSDR 2000).

Direct contact with PCB in old paint, caulk or fluids leaking from capacitors can lead to skin 

absorption or ingestion of PCBs. It is important to wear protective clothing gloves and 

respiratory protection if repairing or handling equipment like light ballasts that may have PCBs 

in them.
133

Occupational Exposures

Current occupational exposures can come from exposure to leaking electrical equipment made 

before 1979, from PCB abatement programs, or during demolition or recycling of PCBcontaminated structures and equipment.

Herrick et al. (2007), conducted biomonitoring for 54 PCB congeners in a small group of 

construction workers with a history of removing PCB caulk from buildings in the greater Boston 

area. The workers had higher proportions of lighter PCB congeners (PCBs 6-74) in their serum 

than a reference population of men who sought health care in the Boston area. The construction 

workers as a group had more than five times more PCB 6, 16, 26, 33, 37, 41, 70, 97, and 136

than the referent population. One worker, who was actively involved with removal of PCB 

products at the time of blood collection, had 25% of his body burden comprised of the lighter 

PCBs compared to 7% of the PCB serum levels in the referent population.

Wingfors et al. 2006 collected blood samples from 36 workers directly involved in abating PCB 

sealants in Sweden. These were compared in a biomonitoring study to 33 age- and sex-matched 

construction workers who did not work in the abatement program. The exposed workers had 

PCB serum levels (sum of 19 congeners) that were twice as high as the controls (mean of 

exposed workers were 575 ng/g lipid compared to 267 ng/g for the controls). The PCB congener 

patterns also differed between the workers and the controls, with much higher levels of many 

less chlorinated PCBs in the exposed workers, compared to the controls. The authors concluded 

that PCBs 56/60 and 66, were good markers of general occupational exposure; PCB 44, 70, and 

110 were good markers for recent occupational exposures; and PCB 153 and 180 reflected 

background (dietary) exposure. Follow-up samples taken 10 months later showed that serum 

concentrations of rapidly excreted congeners (PCB 52, 44, 70, and 110) declined after workers 

were given information about protecting themselves from exposure.

Adequate safeguards are also important during recycling and disposal of PCB containing 

materials. Electronic waste recycling and disposal practices in China have resulted in elevated 

exposures in workers, PCB release into nearby soils and rivers, and subsequent contamination of 

staple foods grown in surrounding areas. (Yang et al. 2013, Tue et al. 2013, Labunska et al.

2015).
134

Existing Washington State Health Advice

Fish consumption is the primary exposure pathway that most Washingtonians have to many 

Persistent, Bioaccumulative Toxics (PBTs). Many PBTs such as PCBs, DDT, and mercury are 

linked to a variety of adverse health effects (e.g. neurological, developmental, immunological, 

and cancer). The paradox of consuming fish is that it also known to be one of the healthiest 

forms of protein due in part to the high levels of omega-3 fatty acids that have been associated 

with a variety of positive health outcomes (e.g. prevention of heart disease, inflammation, 

arteriosclerosis, and cognitive development). Results from the most recent Behavioral Risk 

Factor Surveillance System (BRFSS) conducted by DOH indicate that nearly three quarters of 

the adult general population in Washington State consume fish. Washington State is also the 

home of numerous federally recognized tribes whose fish consumption rates are often well above 

that of the general population (Ecology 2013b). Additionally, there are other high fish 

consuming populations within the state including Asian and Pacific Islanders and sports fishers.

Because of potential exposure to PBTs to fish consuming populations, DOH collaborates with 

numerous state and federal agencies on the collection and analysis of contaminants in fish. 

DOH’s role is to evaluate fish contaminant levels in fish tissue for potential public health 

impacts and to convey information on risks and benefits to fish consumers by way of fish 

advisories. Currently, Washington State has thirteen waterbody specific fish advisories based on 

PCB levels in tissue. PCBs account for the greatest number of waterbody specific advisories in 

Washington State and across the country (WDOH 2013a, EPA 1999b).

Table 35 lists those waterbodies and fish species that currently have a fish advisory due to 

elevated PCB levels.
135

Table 35. Washington State PCB Fish Advisories

Water Body/Location Fish Species Advisory

Green Lake Common Carp 1 meal per month

Lake Roosevelt Largescale Suckers 2 meals per month

Lake Washington

Common Carp Do not eat

Northern Pikeminnow Do not eat

Cutthroat Trout 1 meal per month

Yellow Perch 1 meal per week

Lower Duwamish River

Resident fish Do not eat

Shellfish Do not eat

Crab Do not eat

Lower Columbia – (Bonneville Dam) Resident fish Do not eat

Bonneville Dam to McNary Dam Resident fish 1 meal per week

Okanogan River Common Carp 1 meal per month

Puget Sound

Chinook 1 meal per week

Chinook (Blackmouth) 2 meal per month

English Sole/Flatfish Varies by location

Rockfish Varies by location

Spokane River

Idaho Border to Upriver Dam All species Do not eat

UpRiver Dam to Nine Mile Dam All species* 1 meal per month

* Exception: Largescale Suckers Do not eat

Long Lake (Lake Spokane) Largescale Suckers, Brown Trout 1 meal per week

Mountain Whitefish 1 meal per month

Walla Walla River – Lower Carp 1 meal per month

Walla Walla River – Lower & Upper Northern Pikeminnow Do not eat

Wenatchee River Mountain Whitefish Do not eat

Yakima River Common Carp 1 meal per week

Pending Advisories*

Mid-Columbia

Lake Whitefish 1 meal per month

Largescale Suckers 2 meals per month

Sturgeon 2 meals per month

Common Carp 1 meal per month

Walleye 2 meals per month

Bass 2 meals per month

Snake River

Channel Catfish 2 meals per month

Common Carp 2 meals per month

* preliminary assessment, meal recommendations may change

Fish advisories apply to all individuals. Women of childbearing age and young 

children should pay particular attention.
136

Food Preparation and Cooking Advice to Reduce Exposure

Chemical contaminants are not distributed uniformly in fish. Fatty tissues typically concentrate 

organic chemicals such as PCBs and dioxins more readily than lean muscle tissue (ATSDR 

2004). To reduce the level of PCBs in fish, remove the fish skin and visible fat before cooking. 

Do not use the fat for gravy or sauces. For further information on reducing contaminants such as 

PCBs in fish, visit 

http://www.doh.wa.gov/CommunityandEnvironment/Food/Fish/ReduceContaminantExposure.

Benefits of Fish Consumption

The primary health benefits of eating fish are well documented for children and adults. Dietary 

fish is associated with reduction of cardiovascular disease (Yuan et al. 2001, Rodriguez et al. 

1996, Hu et al. 2002, Marckmann and Gronbaek 1999, Mozaffarian et al. 2003, Simon et al. 

1995, Burr et al. 1989, 1994, Singh et al.1997, and Harrison and Abhyankar 2005) and positive 

pregnancy outcome (Jorgensen et al. 2001, Olsen et al. 1992, Olsen et al. 1995, Olsen and 

Secher 2002, Carlson et al. 1993, 1996, Fadella et al. 1996, San Giovanni et al. 2000, and 

Helland et al. 2003). Limited data also show a link between fish consumption and a decrease in 

development of some cancers (SACN 2004, IOM 2007). Additionally, eating fish has been 

associated with impacts on brain function, including protection against cognitive decline (SACN 

2004, IOM 2007).

At present, we know that fish is an excellent protein source that is low in saturated fats, rich in 

vitamin D, omega-3 fatty acids, and other vitamins and minerals. The health benefits of eating 

fish are associated with low levels of saturated versus unsaturated fats. Saturated fats are linked 

with increased cholesterol levels and risk of heart disease while unsaturated fats (e.g., omega-3 

polyunsaturated fatty acid) are an essential nutrient. Replacing fish in the diet with other sources 

of protein may reduce exposure to contaminants but could also result in increased risk for certain 

diseases (Pan et al. 2012). For example, replacing fish with red meat could increase the risk of 

cardiovascular disease due to the fact that red meat has higher levels of saturated fat and 

cholesterol (Law, 2000).

DOH fish advisories work to be protective of human health while acknowledging the benefits of 

eating fish. This is done by recommending decreased consumption of fish known to have high 

concentrations of contaminants in favor of fish that are lower in contaminants. DOH supports the 

American Heart Association and the U.S. Food and Drug Administration recommendation of 

consuming at least two servings (12 oz.) of fish per week as part of a healthy diet.

Health benefits of eating fish deserve particular consideration when dealing with groups that 

consume fish for subsistence. Removal of fish from the diet of subsistence consumers may have 

serious health, social, cultural, and economic consequences. In order to decrease the potential 

risks of fish consumption, these populations are encouraged to consume a variety of fish species, 
137

to fish from locations with low contamination, and to follow recommended preparation and 

cooking methods.

Recommendation for Breast-feeding

DOH recommends that babies be breast fed because breast feeding has many demonstrated 

health benefits for the developing child and the mother. (Washington State Department of Health 

website http://www.doh.wa.gov/YouandYourFamily/WIC/BreastfeedingSupport.aspx)

Many investigations have looked for adverse effects associated with PCBs in breast milk and 

duration of breast feeding. Most studies have shown that prenatal, not postnatal PCB exposure 

correlates with neurobehavioral effects (Michigan, NC, Patandin et al. 1999, Darvill et al. 2000). 

Breast feeding appears to have a net positive effect on neurobevavioral test performance 

regardless of PCB concentration of the milk (Jacobson et al. 1990b).

A Dutch study on PCB and dioxin exposures to children recently found that PCB body burden at 

42 months is associated with possible immune deficits. However, when the researchers 

controlled for length of breast feeding, they found that the negative effect of higher postnatal 

PCB exposure was counteracted by the positive effect of longer duration of nursing in infancy 

(Weisglas-Kuperus et al. 2000). Using this same cohort, other researchers conducted

neurological and cognitive assessments at 42 months and found that breast-fed children 

performed better than their formula fed counterparts despite higher prenatal and postnatal 

exposure to PCBs (Lanting et al. 1998, Patandin et al. 1997 and 1999). Follow-up with these 

children at 6.5 years showed that effects of prenatal exposure to PCBs on cognitive and motor 

abilities were still measureable in the formula fed group and not measurable in the breast-fed 

group (Vreugdenhil et al. 2002). Analysis of parental and home characteristics suggested that an 

advantaged home environment contributed significantly to the resilience of the breast-fed group 

(Vreugdenhil et al. 2002).
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Current Regulatory Approaches for PCBs

This chapter describes the existing regulations relevant to PCBs and the activities that generate 

them at the federal, state, and international levels. It includes a brief summary of many laws and 

regulations directly related to management of processes that produce PCBs, the production, use, 

and disposal of products that contain PCBs, and exposure limits and cleanup levels for PCBs 

themselves. This chapter is not an exhaustive review of all of the regulations pertinent to PCBs. 

In many instances, federal laws and regulations delegate the authority for implementing these 

laws and regulations to state or Tribal governments. In some cases, states adopt laws and 

promulgate regulations that are more stringent than their federal partners.

Federal Laws & Regulations

Toxic Substances Control Act

15 USC 2601 et seq., Toxic Substances Control Act

The Toxic Substances Control Act (TSCA) of 1976 (15 USC 2601 et seq.) gives EPA the 

authority to regulate new and existing substances. TSCA gives EPA the authority to require 

reporting, record-keeping and testing requirements, and restrictions relating to chemical 

substances and/or mixtures. Certain substances are generally excluded from TSCA, including, 

among others, food, drugs, cosmetics, and pesticides.

TSCA is the primary federal law pertinent to PCBs in the United States. PCBs are regulated by 

Title I Section 6 of the Act and by EPA implementing regulations, Title 40, Part 761 of the Code 

of Federal Regulations (CFR). Section 6(e)(2)(A) of TSCA states that “...effective one year after 

January 1, 1977, no person may manufacture, process, or distribute in commerce or use any 

polychlorinated biphenyl in any manner other than in a totally enclosed manner.” Section 6 of 

TSCA further prohibited the manufacture of all PCBs by 1979, but allowed the EPA 

administrator to authorize certain processing, distribution in commerce, and use of PCBs 

manufactured before 1979 if the Administrator determined that such activity did not present an 

unreasonable risk of injury to health or the environment. Table 37 summarizes several subparts 

of TSCA and their contents
139

Table 36. Subparts of TSCA

Subpart A General regulations governing PCBs including definitions

Subpart B

Manufacturing, processing, distribution in commerce and use of PCBs and PCB items

Prohibitions and exceptions

Authorizations including:

• Totally enclosed uses (e.g. transformers, capacitors)

• Non-totally enclosed uses (including requirements for servicing PCB-containing 

equipment)

• Other uses (carbonless copy paper, research and development, scientific 

instruments, continued use of porous surfaces contaminated with PCBs)

Subpart C Marking of PCBs and PCB items

Subpart D

Storage and disposal, including:

• PCB disposal requirements

• Remediation waste disposal and cleanup levels

• Bulk product waste

• PCB household waste storage and disposal

• PCB decontamination standards and procedures

• Storage for disposal

Subpart E

Manufacturing, processing, and distribution in commerce exemptions, including:

• Research and development for disposal technologies

• Analytical reference samples

• 5 ml or less PCB fluids from electrical equipment for analysis

•

Subpart F Transboundary shipments of PCBs for disposal

Subpart G PCB spill cleanup policy

Subpart J General records and reports

Subpart K PCB waste disposal records and reports

Subparts M-R Sampling requirements for various media and disposal authorizations

Subpart S Double wash/rinse method for decontaminating non-porous surfaces

Subpart T Comparison study for validating a new performance-based decontamination solvent
140

Continued use and disposal of existing PCBs is governed by a framework of controls driven by 

the form the PCBs take (liquid form, non-liquid form, or multi-phasic, meaning a combination of 

liquid and non-liquid forms), the amount of PCBs in each form, and the original source of PCBs 

for media contaminated by a release.

While not a complete summary of all sections in TSCA that pertain to PCBs: below are some 

important requirements:

• Prohibits of manufacture, sale, and distribution, with exceptions. 

• Mandates proper disposal for any PCBs unauthorized for use.

• Does not require testing to find PCB sources, but does require proper use and disposal of 

identified PCB contaminated items.

o Many unauthorized uses are therefore not found until a release to the environment has 

occurred.

• Limits use of PCBs to certain “totally enclosed” uses, such as transformers and capacitors,

or concentrations below 50 ppm in bulk product. Various other levels exist for remediation 

waste and other limited uses, typically with EPA approval.

• Requires that by December 1998, all known transformers containing PCBs >500 ppm be 

registered with EPA. 

o There is no requirement to determine if transformers contain >500 ppm PCBs, only to 

register it if it is known to be a PCB Transformer (>500 ppm PCBs).

• Allows many forms of PCB waste to be disposed of as municipal solid waste, which does not 

require PCBs to be listed on a manifest. Examples include:

o Small non-leaking PCB capacitors. 

o 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).

 Any of these may also be disposed as landfill daily cover or as roadbed under asphalt. 

o Other PCB bulk product waste that leaches PCBs at <10 μg/L of water measured using a 

procedure used to simulate leachate generation.

o PCB bulk product waste other than those materials listed above if:

 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.

• Requires labels identifying electrical equipment containing over 500 ppm PCBs. 

• Requires quarterly inspections of PCB transformers containing more than 60,000 ppm PCBs.

Transformers with less than 60,000 ppm PCBs and those with appropriate secondary 

containment must be inspected for leaks at least annually. 
141

• Requires removal or reclassification of high-voltage network PCB-containing transformers to 

prevent fires. Requires enhanced electrical protection be added on many types of PCB 

transformers in, or within 30 meters of, commercial buildings.12

• Requires EPA authorization for commercial storage of PCBs. Non-Commercial storage does 

not always require EPA oversight.

TSCA Rules

Under TSCA EPA has promulgated 29 rules for the regulation of PCBs. A list of rules, with the 

associated notices, drafts, etc. can be found on the EPA website at 

http://www.epa.gov/wastes/hazard/tsd/pcbs/pubs/laws.htm. The current regulations can all be 

found in the Federal Code of Regulations (CFR) part 761. In general, each rule addresses a 

specific portion of managing PCBs, such as labeling and spills. Below is some information on 

three specific regulations. 

1. 44 FR 31514 PCBs; Manufacturing, Processing, Distribution in Commerce and Use Bans. 

This 1979 rule implemented the ban on PCBs and established 50 ppm PCBs as the general 

regulatory limit. 

2. 49 FR 28172 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in 

Commerce, and Use Prohibitions; Exclusions, Exemptions, and Use Authorizations

EPA promulgated a rule in 1984 for inadvertent generation of PCBs that are not in closed or 

controlled manufacturing processes (49 FR 28172). EPA found the societal benefit of these 

products and the cost of not producing PCBs outweighed the risks to human health and the 

environment from these sources of PCBs. The rule was based on a consensus proposal from the 

Environmental Defense Fund, Natural Resources Defense Council, and Chemical Manufacturers 

Association (now known as the American Chemistry Council). It requires that the concentration 

of inadvertently generated PCBs in products, including recycled paper, must have an annual 

average of < 25 ppm, with a maximum of 50 ppm. Detergent bars are treated differently as they 

are consumer products with a high potential for exposure, and are limited to 5ppm (soap and 

deodorant are regulated by the FDA). 

There were several additional criteria in the rule:

• Releases to ambient air must be less than 10ppm.

• Discharges to water must be less than 0.1ppm, except from recyclable paper the limit is 3 ppb 

total Aroclors. 

 12 Panero, M., Boheme, S., and Muñoz, G. Pollution Prevention and Management Strategies for Polychlorinated 

Biphenyls in the New York/New Jersey Harbor. February 2005. New York Academy of Sciences, New York, NY. 

Available at: http://www.nyas.org/WhatWeDo/Harbor.aspx
142

• All wastes must be disposed of properly. Process wastes with PCB levels > 50 ppm must be 

disposed of in accordance with TSCA.

• The concentration of monochlorinated biphenyls is discounted by a factor of 50 and 

dichlorinated biphenyls are discounted by a factor of 5. 

• Certification, reporting, and records maintenance. 

The numerical limits in the law were set at the Limits of Quantification (LOQs) at the time. 

The rule clarifies some overlap between TSCA with the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA) and Federal Food Drug and Cosmetic Act (FFDCA). If a chemical is 

solely manufactured for a use that is regulated by FIFRA or FFDCA, then that substance is not 

regulated under TSCA. If only some uses are regulated under FIFRA, then the chemical is 

regulated under TSCA until it becomes part of an identified pesticide product. However, 

chemicals used in FDA-regulated products under FFDCA (like a food, food additive, drug, 

cosmetic, or medical device) are excluded from TSCA jurisdiction. 

In 2013 EPA clarified the definition of “excluded PCB Products” to generally allow for the 

recycling of plastic separated from shredder residue containing < 50 ppm PCBs under specific 

conditions. The voluntary procedures to prevent the introduction of PCBs in shredder residue are 

(1) documented source control programs and (2) documented output control. The review was 

done at the request of the Institute of Scrap and Recycling Industries to clarify whether the 

plastic material should be managed as an Excluded PCB Product or as a PCB Remediation 

Waste. This interpretation reiterates EPA’s “generic exclusion for processing, distribution in 

commerce, and use, based on the Agency’s determination that the use, processing, and 

distribution in commerce of products with less than 50 ppm concentration will not generally 

present an unreasonable risk of injury to health or the environment” (FR Vol. 78, No. 66, April 5, 

2013). 

3. Several rules on transformers and other electrical equipment have been promulgated. The 

current regulations are in CFR part 761. 

The regulations include several important definitions: 

• PCB Transformer (≥500 ppm) PCB Transformer means any transformer that contains ≥500 

ppm PCBs.

• PCB contaminated (50-500 ppm) PCB-Contaminated refers to liquid and non-liquid material 

containing PCBs at concentrations ≥50 ppm but <500 ppm, and non-porous surface having a 

surface concentration >10 μg/100 cm2 but <100 μg/100 cm2.

The definitions specifically mention electrical equipment with a very similar definition. PCBContaminated Electrical Equipment means any electrical equipment including, but not 

limited to, transformers (including those used in railway locomotives and self-propelled 

cars), capacitors, circuit breakers, reclosers, voltage regulators, switches (including 
143

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

concentrations of ≥50 ppm and <500 ppm in the contaminated 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.

• Non-PCB Transformer (<50 ppm) Non-PCB Transformer means any transformer that 

contains less than 50 ppm PCB.

Owners of PCB transformers (≥500 ppm) were required to register their transformers with the 

EPA by Dec. 28, 1998. Some important points about this requirement:

• There is no requirement to test a transformer to determine if it is a PCB Transformer.

• There is no requirement to register a transformer if the owner takes ownership after 1998.

• There is no requirement to register a PCB-contaminated transformer (50-500ppm PCBs)

• There is no requirement to request a registered transformer be removed from the database if 

it is physically removed from service.

• Other equipment, such as bushings with ≥ 500 ppm PCBs, are not required to be registered. 

While testing for PCBs is not required, the regulations do include PCB concentration 

assumptions that are based on the age and size of the equipment. The assumptions include: 

• Transformers with <3 pounds (1.36 kilograms (kgs)) of fluid, circuit breakers, reclosers, oilfilled cable, and rectifiers whose PCB concentration is not established contain PCBs at <50 

ppm.

• Mineral oil-filled electrical equipment that was manufactured before July 2, 1979, and whose 

PCB concentration is not established is PCB-Contaminated Electrical Equipment (i.e., 

contains ≥50 ppm PCB, but <500 ppm PCB). All pole-top and pad-mounted distribution 

transformers manufactured before July 2, 1979, must be assumed to be mineral-oil filled. 

• Electrical equipment manufactured after July 2, 1979, is non-PCB (<50 ppm PCBs). 

• If the date of manufacture of mineral oil-filled electrical equipment is unknown, any person 

must assume it to be PCB-Contaminated.

• A transformer manufactured prior to July 2, 1979, that contains 1.36 kg (3 pounds) or more 

of fluid other than mineral oil and whose PCB concentration is not established, is a PCB 

Transformer (i.e., ≥500 ppm). If the date of manufacture and the type of dielectric fluid are 

unknown, any person must assume the transformer to be a PCB Transformer.

• A capacitor manufactured prior to July 2, 1979, whose PCB concentration is not established 

contains ≥500 ppm PCBs. 

• A capacitor manufactured after July 2, 1979, is non-PCB (i.e., <50 ppm PCBs). 

• If the date of manufacture is unknown, any person must assume the capacitor contains ≥500 

ppm PCBs. 
144

Water Regulations

33 USC 1251 et seq., The Clean Water Act (CWA)

EPA has established water quality criteria for certain compounds that define levels to protect 

human health and aquatic life. The Clean Water Act and its amendments prohibit discharging 

pollutants from a point source without a National Pollutant Discharge Elimination System 

(NPDES) permit. These permits include conditions to protect water quality. EPA authorizes

states to issue and monitor compliance with these permits. The Clean Water Act also directs EPA 

to establish technology-based standards, known as Best Available Technology (BAT) 

requirements to prevent discharges of harmful amounts of pollutants. 

Stormwater from certain industries and municipalities is also considered a point source of 

pollution that requires NPDES permitting13. PCBs from various sources that are deposited on 

land and washed into storm drains would be regulated under these stormwater permits. EPA’s 

stormwater regulations establish two phases for the stormwater permit program:

• Phase I stormwater permits cover discharges from certain industries, construction sites 

involving five or more acres, and municipalities with a population of more than 100,000.

• Phase II stormwater permits cover all municipalities located in urbanized areas and 

construction sites between one and five acres. The EPA rule also requires an evaluation of 

cities outside of urbanized areas that have a population over 10,000, to determine if a permit 

is necessary for some or all of these cities.

National Recommended Water Quality Criteria14

PCBs are a Priority Pollutant under the CWA. EPA has national recommended water quality 

criteria for the protection of aquatic life and human health in surface water for about 150 

pollutants. These criteria are published pursuant to Section 304(a) of the Clean Water Act and 

provide guidance to states. For aquatic health the chronic freshwater criterion is 0.014 ug/L and 

0.03 ug/L for saltwater. For human health the criteria are 0.000064 ug/L both for the 

consumption of water and organism and for the consumption of organism only. 

National Toxics Rule (40 CFR 131.36).15

The National Toxics Rule promulgated chemical-specific numerical criteria for priority toxic 

pollutants for 14 states to bring them into compliance with requirements of section 303(c)(2)(B) 

 13 Department of Ecology. How is Stormwater Regulated? Available at: 

http://www.ecy.wa.gov/programs/wq/stormwater/municipal/howregulated.html

14 US EPA. National Recommended Water Quality Criteria. Available at: 

http://water.epa.gov/scitech/swguidance/standards/current/index.cfm (accessed 9 June 2011). 15US EPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants; States' 

Compliances. 57 FR 60848. Available at: http://water.epa.gov/lawsregs/rulesregs/ntr/index.cfm (accessed 21 Oct 

2013).
145

of the CWA. This rule became effective in 1993. The criterion for PCBs for both freshwater and 

marine water is 0.00017 ug/L, which has a fish tissue equivalent of 5.304 ug/kg. 

42 USC 300f et seq., Safe Drinking Water Act (SDWA)

The Safe Drinking Water Act specifies water quality standards for drinking water. The National 

Primary Drinking Water regulations under the SDWA apply to public water systems with at least 

15 service connections or more than 25 individuals for more than 60 days per year.

The SDWA sets two drinking water standards. The Maximum Contaminant Level Goal (MCLG) 

is a non-enforceable health goal. The Maximum Contaminant Level (MCL) is the legally 

enforceable standard. Water systems must reduce levels of the contaminant as close to the 

MCLG as feasible, considering technology, treatment techniques, and costs. For PCBs the 

MCLG is zero and the MCL is 0.0005 mg/L (ppm)16

Air Regulations

42 USC 7401, Clean Air Act and Amendments

PCBs are regulated under Section 112 of the Clean Air Act as Hazardous Air Pollutants (HAPs).

Regulation under Section 112 of the Clean Air Act requires major sources of HAPs to meet 

standards based on Maximum Achievable Control Technology (MACT). These standards must 

require the maximum degree of emission reduction that the EPA determines to be achievable by 

each particular source category. Different criteria for MACT apply for new and existing sources.

For existing major sources, MACT is defined as the technology used to control emissions at the 

top 12% of facilities within the same source category. Eight to nine years after MACT is 

implemented, EPA is required to conduct a residual risk analysis. If the "residual risk" for a 

source category does not protect public health with "an ample margin of safety," the EPA must 

promulgate health-based standards for that source category to further reduce HAP emissions.

PCBs are one of several substances listed in Section 112(c)(6) of the Clean Air Act, which 

requires EPA to “list categories and subcategories of sources assuring that sources accounting for 

not less than 90 per centum of the aggregate emissions of each such pollutant are subject to 

standards.” EPA published this listing in a Federal Register notice in June 1997.17 Various forms 

of waste incineration were identified as the primary industrial source categories emitting PCBs.

 16 US EPA. List of Contaminants & their MCLs. Available at: 

http://water.epa.gov/drink/contaminants/index.cfm#List (accessed 9 June 2011). 17 Notice of draft source category listing for section 112(d)(2) rulemaking pursuant section 112(c)(6) requirements.

62 FR 119 (20 June 1997). p. 33625 - 33638. 
146

Waste, Hazardous Substance & Cleanup Regulations

42 USC 6901 et seq., Resource Conservation and Recovery Act (RCRA)

Under the authority of the Resource Conservation and Recovery Act of 1976, EPA implements 

regulations pertaining to solid waste, hazardous waste and underground storage tanks (40 CFR 

parts 239-299).

Hazardous wastes are managed under RCRA from their point of generation to their proper

disposal or treatment. There are three means under RCRA of identifying if a waste is hazardous: 

(1) if the waste is specifically listed as hazardous, (2) if it exhibits hazardous characteristics, as 

determined by a Toxicity Characteristic Leaching Procedure (TCLP) test or 3) exhibits the 

characteristics of ignitability, corrosivity or reactivity. 

Wastes are given waste codes based on their sources or specific properties. D codes are for 

characteristic wastes. P and U waste codes are assigned to discarded chemical products. F codes 

are for non-specific and K codes are for specific industrial sources. 

Standards for the Management of Used Oil (40 CFR Part 279)

18 include management standards 

for generators, transporters, processors, burners, and marketers of used oil containing PCBs at 

less than 50 ppm. Used oil containing more than 50 ppm is regulated under TSCA (40 CFR part 

761). 

RCRA allows EPA to permit facilities to Treat, Store and Dispose of hazardous waste. 

Additionally, RCRA grants EPA the authority to require cleanup of any releases of hazardous 

waste to the environment from a permitted or interim status facility through the RCRA 

Corrective Action Program. RCRA cleanup sites regularly also have PCB contamination. 

Generally these sites come under both programs for approval of the waste cleanup. 

42 USC Part 103, Comprehensive Environmental Response, Compensation and Liability

Act (CERCLA)

CERCLA, passed in 1980, is the primary federal authority used to regulate and cleanup historic 

hazardous waste sites. The statute and implementing regulations establish procedures for the 

long-term remediation of such sites, but also provides authority to clean up hazardous waste sites 

in need of immediate action. The law has subsequently been amended, by the Superfund 

Amendments and Reauthorization Act of 1986 (SARA), and the Small Business Liability Relief 

and Brownfields Revitalization Act of 2002.

Under CERCLA Section 103, releases of hazardous substances are required to be reported to the 

National Response Center if they exceed the Reportable Quantity (RQ) for that substance, which 

 18 US EPA. Standards for the Management of Used Oil. 40 CFR Part 279. Available at: 

http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfr279_07.html (accessed 10 June 2011).
147

is 1 pound for PCBs.19 CERCLA implements TSCA as an Applicable or Relevant and 

Appropriate Requirements (ARAR), without need for separate approval under TSCA for PCB 

waste disposal.

42 USC Part 116, Emergency Planning and Community Right-to-Know Act (EPCRA)

EPCRA, or SARA Title III, is intended to protect public health and the environment from 

hazards posed by toxic chemicals by providing information about the presence of toxic 

chemicals in communities. The Act, passed in 1986, creates the annual hazardous chemical 

inventory as well as the toxics release inventory (TRI). 

Under Section 302 of EPCRA, facilities that manufacture, process or use chemicals on the list of 

Extremely Hazardous Substances (EHSs) must report the presence of those chemicals above a 

certain quantity, known as the Threshold Planning Quantity (TPQ).

Section 313 of EPCRA establishes the Toxics Release Inventory (TRI). Under the TRI, the 

release or waste management of toxic chemicals by certain industries must be reported if the 

quantity of a chemical that is manufactured, processed, or otherwise used during the calendar 

year exceeds the reporting threshold. For most TRI chemicals, the thresholds are 25,000 pounds 

manufactured or 10,000 pounds otherwise used.20 The reporting threshold for PBTs is lower and 

is 10 lbs for PCBs.

Worker & Product Safety Regulations

84 USC 1590 et seq., Occupational Safety and Health Act (OSHA)

The Occupational Safety and Health Act allows the Occupational Safety and Health 

Administration (OSHA) to set protective regulatory limits on the amount or concentration of a 

substance in the air in workplaces. These limits, called Permissible Exposure Limits (PELs) are 

based on an average exposure over an 8 hour workday, or a Time-Weighted Average (TWA).21

OSHAs PEL is 1,000 μg/m3 for PCBs containing 42% chlorine (CAS 53469-21-9) and 500 

μg/m3 for compounds containing 54% chlorine (CAS 11097-69-1). The PELs include “skin” to 

refer to the contribution to overall exposure through skin. These are based on the prevention of 

liver injury in exposed workers. 

The National Institute for Occupational Safety and Health (NIOSH) recommends a 10-hour 

TWA of 1 μg/m3 based on the minimum reliable detectable concentration and the potential 

 19 US EPA. List of Lists: Consolidated List of Chemicals Subject to the Emergency Planning and Community RightTo-Know Act (EPCRA) and Section 112(r) of the Clean Air Act. EPA 550-B-01-003. October 2012. Available at: 

http://www.epa.gov/emergencies/tools.htm#lol (accessed 21 October 2013). 20 US EPA. List of Lists: Consolidated List of Chemicals Subject to the Emergency Planning and Community RightTo-Know Act (EPCRA) and Section 112(r) of the Clean Air Act. EPA 550-B-01-003. October 2012. Available at: 

http://www.epa.gov/emergencies/tools.htm#lol (accessed 21 October 2013). 21 Occupational Safety and Health Administration. Permissible Exposure Limits (PELs). Available at: 

https://www.osha.gov/dsg/topics/pel/ (accessed 21 October 2013).
148

carcinogenicity of PCBs.22 The NIOSH Recommended Exposure Limit (REL) was based on 

reproductive effects in animal models, carcinogenic effects, and prevention of liver injury. 

NIOSH also recommends that all workplace exposures be reduced to the lowest feasible level.

Washington State Laws and Regulations

Water Regulations

Chapter 90.48 RCW Water Pollution Control

Chapter 173-200 WAC Water quality standards for groundwaters of the state of Washington.

This regulation is intended to protect current and future beneficial uses of groundwater from 

deleterious effects, prevent degradation of waters of outstanding value, and actively maintain the 

higher quality of waters that exceed water quality criteria. 

Chapter 173-201A WAC Water quality standards for surface waters of the state of Washington.

This regulation institutes narrative and numeric criteria for surface water quality, an antidegradation policy, and use-based protection measures. 

Chapter 70.142 RCW Chemical Contaminants and Water Quality

This law allows the State Board of Health to establish standards for allowable concentrations of 

chemical contaminants in public water supplies.

Chapter 246-290 WAC Water quality standards for groundwaters of the state of Washington

This regulation establishes regulatory requirements applicable to public drinking water supplies. 

Multiple Statutes – Chapters 90.48, 70.105D, 90.70, 90.52, 90.54 and 43.21 RCW

Chapter 173-204 WAC, Sediment Management Standards

Enacted in 1991, this chapter establishes marine, low salinity and freshwater surface sediment 

management standards. The purpose of this chapter is to reduce health threats to humans and 

biological resources resulting from surface sediment contamination.23

Air Regulations

Chapter 70.94 RCW Washington Clean Air Act

The Washington Clean Air Act authorizes the Department of Ecology to develop and implement 

regulations that are needed to control air pollution.

 22 Polychlorinated Biphenyls (PCBs). Current Intelligence Bulletin 45 (1986) http://www.cdc.gov/niosh/docs/86-

111/ (accessed 21 October 2013) 23 WAC 173-204-320. Table 1, Marine Sediment Quality Standards. Available at: 

http://apps.leg.wa.gov/wac/default.aspx?cite=173-204-320 (accessed 10 June 2011).
149

Chapter 173-460 WAC Controls for new sources of toxic air pollutants

Under this chapter, Ecology reviews new sources of toxic air pollutants and establishes emission 

control requirements that are needed to prevent air pollution that may impact human health and 

safety. This chapter, enacted in 1991, requires new sources to implement Best Available Control 

Technology for toxics (BACT). The owner or operator of a new toxic air pollutant source must 

also conduct an Acceptable Source Impact Level (ASIL) analysis for toxic air pollutants. When 

performing these assessments, the owner/operator must quantify the amount of toxic air pollutant 

likely to be emitted from the new source and estimate ambient air concentrations that might 

result from those emissions. Ambient air concentrations are estimated using air quality models. 

The model air concentrations are then compared to regulatory screening values (ASIL). If the 

modeled concentration exceeds the ASIL screening levels, the owner/operator must perform a 

comprehensive review using a more sophisticated model and, if necessary, apply additional 

emission controls. Violators may be subject to enforcement actions, civil penalties and/or 

criminal charges such as gross misdemeanor. Twelve PCB congeners and general PCBs (CAS 

1336-36-3) are regulated as Toxic Air Pollutants (TAPs).24

Waste, Hazardous Substance & Cleanup Regulations

Multiple Statutes - Chapter 70.105 RCW and parts of chapters 70.105A, 70.105D and 15.54 

RCW

Chapter 173-303 WAC, Dangerous Waste Regulations

These regulations meet the requirements of the Federal Resource Conservation and Recovery 

Act (RCRA) and the Department of Ecology is authorized by the US EPA to implement RCRA 

within the state. Therefore, all the requirements identified under RCRA are also part of the 

state’s dangerous waste regulations. In addition, this chapter also contains specific state-only 

dangerous waste requirements for any waste generated or disposed of within the state. The 

dangerous waste regulations require a generator of dangerous waste to designate that waste 

according to the regulations and follow the associated requirements for waste of that designation.

Washington State has specific requirements that pertain to toxicity and persistent criteria. 

Halogenated organic compounds like PCBs are considered persistent in the dangerous waste 

regulations. 

WAC 173-303-100(5) requires waste to be evaluated for mammalian and aquatic toxicity and 

WAC 173-303-100(5)(b)(i) provides a process to designate a specific waste stream based upon 

the toxicity of the individual components. In this evaluation, toxicity must be considered with 

other waste constituents to determine if the waste stream designates as a state-only toxic waste 

 24 WAC 173-460-450. Table of ASIL, SQER and de minimis emission values. Available at: 

http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150 (accessed 10 June 2011).
150

and assigned the waste codes of WT02 as dangerous waste or WT01 as EHW (extremely 

hazardous waste).

In Washington State, PCB waste may be regulated as a state criteria dangerous waste or as a state 

listed dangerous waste. The Washington dangerous waste regulations separate wastes into four 

categories:

• Characteristic wastes.

• Criteria wastes.

• Discarded chemical products.

• Non-specific and specific industrial sources.

Wastes are given waste codes based on their sources or specific properties as discussed in the 

Federal Regulations section on RCRA. W codes are for state-only wastes.

PCBs as a state criteria dangerous waste

Since PCBs meet the definition of Halogenated Organic Compound (WAC 173-303-040), wastes 

containing PCBs (other than state listed PCB wastes discussed below) must be evaluated for state 

persistence. This requirement has been in place since early adoption of the State’s Dangerous 

Waste Regulations in 1982. At 100ppm PCB, a waste would be considered a persistent 

dangerous waste (waste code WP02). A few examples of PCB persistent waste include: caulking, 

tar and rubber stripping at airport runways. If the PCB concentration exceeds 10,000 ppm (waste 

code WP01), the waste is recognized as an extremely hazardous waste pulling on additional 

requirements and/or prohibitions on the management of that waste.

PCBs as a state listed dangerous wastes

To address the management of the most problematic PCB wastes- liquid PCBs in transformers, 

bushings and capacitors- RCW 70.105.105 gives the authority to Ecology to regulate PCBs as a 

dangerous waste. In 1985, Ecology amended its Dangerous Waste Regulations to include certain 

PCB wastes (waste code WPCB). This is a source specific group of waste products that only 

applies to discarded transformers, capacitors or bushings containing 2 ppm PCB or greater 

(except when drained of all free flowing liquid) and to the following wastes generated from the 

salvaging, rebuilding, or discarding of transformers, capacitors or bushing at 2 ppm PCB or 

greater: cooling and insulation fluids, cores, and core papers.

Exclusions

1) -071(3)(k). PCB exclusion. One may manage a state only PCB waste under specific 

TSCA regulations instead of the state Dangerous Waste regulations. The waste would 

become excluded from the state Dangerous Waste regulations. Often, listed-WPCB 

dangerous wastes are managed under this exclusion.
151

2) -073 “Special waste exclusion”. If the waste meets the definition of special waste (WAC 

173-303-040), then some listed WPCB wastes and some state only persistent criteria 

waste (due to PCB) can be managed this way.

Chapter 70.95I RCW Used oil recycling

Used oil is conditionally regulated under the dangerous waste regulations as long as 1) it is not 

contaminated with chlorinated solvents or PCBs and 2) it is managed appropriately. If used oil is 

not contaminated, it may be recycled or burned for energy recovery. Used oil with 2 ppm or 

greater PCBs is prohibited from being managed as used oil under the Dangerous Wastes used oil 

regulations when burned for energy recovery. WAC 173-303-515 contains management 

standards for used oil. 

This statute requires local governments to include an element in their hazardous waste plans 

enumerating how they will collect used oil. It also requires used oil recycling containers and 

educational information about used oil to be provided at any business that sells above 1,000 

gallons of lubricating oil to consumers (500 gallons in a city with an approved used oil recycling 

element in their hazardous waste plan).

Chapter 70.105D RCW Hazardous Waste Cleanup – Model Toxics Control Act

Chapter 173-340 WAC, Model Toxics Control Act – Cleanup

Chapter 70.105D RCW establishes the framework and authority for the development of a 

program dealing with the cleanup of sites contaminated with toxic chemicals. The MTCA 

Cleanup Regulation, issued in 1991, establishes procedures and standards for the identification, 

investigation and cleanup of facilities contaminated with hazardous wastes.

MTCA provides several methods for setting cleanup standards. Under MTCA Method A, precalculated protective cleanup levels are available in tables within the regulation for use at 

relatively simple sites.

Method B is the universal method for determining cleanup levels for all media at all sites. A

target cancer risk level of one in one million (10-6

) is used when calculating cleanup levels under 

Method B. Toxicity equivalency factor (TEF) methodology (Van Den Berg et al. 2006) may also 

be used to evaluate the toxicity of PCBs, where the mixture is considered a single hazardous 

substance.25

Method C cleanup levels are established when cleanup levels established under Method A or B 

may be impossible to achieve or may cause greater environmental harm.

 25 Department of Ecology. Evaluating the Toxicity and Assessing the Carcinogenic Risk of Environmental Mixtures 

Using Toxicity Equivalency Factors. Available at: https://fortress.wa.gov/ecy/clarc/FocusSheets/tef.pdf (accessed 16 

June 2011).
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Chapter 173-360 WAC, Underground Storage Tank Regulations

The Department of Ecology implements Chapter 90.76 RCW, Underground Storage Tanks, in 

order to protect human health and the environment from leaking underground storage tanks 

containing petroleum and other regulated substances. No underground storage tank systems, 

within the parameters of this chapter’s scope, may operate without a valid permit. This chapter 

sets forth performance standards for underground storage tanks. Tanks must be monitored and 

owners and operators are required to comply fully with testing and inspection. Releases into the 

surrounding environment must be immediately reported to Ecology and appropriate cleanup and 

containment measures must be taken. Under most circumstances, MTCA cleanup standards 

apply to the remediation of releases from leaking underground storage tanks. This chapter was 

adopted in 1990 and violators face fines of up to $5,000 dollars per day per violation.

Worker & Product Safety Regulations

Chapter 49.17 RCW Washington Industrial Safety and Health Act

Chapter 296-841 WAC Airborne Contaminants

This chapter specifies Permissible Exposure Limits (PELs) of 1,000 μg/m3 for PCBs containing 

42% chlorine (CAS 53469-21-9) and 500 μg/m3 for compounds containing 54% chlorine (CAS 

11097-69-1) that mirror the federal OSHA requirements (see Federal Regulations). 

They also specify Short-Term Exposure Limits (STEL) of 3,000 μg/m3 for PCBs containing 42% 

chlorine (CAS 53469-21-9) and 1,500 μg/m3 for compounds containing 54% chlorine (CAS 

11097-69-1). STELs refer to 15 minute exposure periods. 

Taxes

Chapter 82.21 RCW Hazardous substance tax – model toxics control act

Chapter 458-20-252 WAC Hazardous substance tax and petroleum product tax

PCBs are taxed under the Hazardous Substance Tax. 

This law places a tax on the first possession of hazardous substances in Washington. The 

Department of Ecology determines which substances are subject to the tax. The tax applies to 

petroleum products, pesticides, and certain chemicals. There are currently over 8,000 different 

hazardous substances identified as being subject to the tax. The tax rate is .007 of the wholesale 

value of the product. Funds are distributed to the Department of Ecology to help clean up,

manage and prevent solid and hazardous waste in the state of Washington.26 The tax does not 

apply to components or contaminants, such as inadvertently generated PCBs in other products. 

 26 Washington State Department of Revenue. Hazardous substance tax. Available at: 

http://dor.wa.gov/content/findtaxesandrates/othertaxes/tax_hazard.aspx
153

The tax applies to 

• Petroleum products.

• Substances designated as hazardous under the federal Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA – see Federal Regulations).

• Any pesticide product required to be registered under the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA – see Federal Regulations).

• Other substances or categories of substances designated by Ecology.

Select Regulations in Other US Jurisdictions

Maine

http://www.mainelegislature.org/legis/statutes/38/title38sec419-B.html

This law requires public utilities to remove transformers with more than 50 ppm PCBs. There are 

earlier deadlines for transformers within 100 feet surface water, elementary school or secondary 

school. 

Select International Regulations

Most countries have prohibited the commercial manufacturing of PCBs. 

Stockholm Convention27

The Stockholm Convention on Persistent Organic Pollutants is a global treaty that aims to protect 

human health and the environment from the effects of persistent organic pollutants. The 

Convention has a range of control measures to reduce and, where feasible, eliminate the release 

of POPs. The Convention also aims to ensure the sound management of stockpiles and wastes 

that contain POPs. 

The Convention was signed in 2001 and entered into force in 2004. The US is a signatory, but 

has not ratified the Convention, so is not a Party to it. 

PCBs are one of the 12 initial POPs under the Stockholm Convention. The parties to the 

Convention are required to eliminate the use of PCBs in existing equipment by 2025 and ensure 

environmentally sound waste management of them by 2028. Each country is expected to develop 

inventories and identify contaminated sites. To help stakeholders achieve the goals in the 

Stockholm Convention they created the PCB Elimination Network (PEN) as a voluntary 

 27http://chm.pops.int/Home/tabid/2121/mctl/ViewDetails/EventModID/871/EventID/407/xmid/6921/Default.aspx
154

collaborative arrangement to promote and facilitate information exchange to support the 

obligations of Stockholm Convention on environmentally sound management of PCBs. Canada

Sweden

In addition to banning the use of PCBs, Sweden has required inventorying buildings with PCBcontaminated materials, such as caulk, and removing them28. The initial program in 1980 was 

voluntary, with information to homeowners and voluntary work by the Ecocycle Council to 

inventory and remediate buildings. In 2007 an ordinance passed to make owners required to 

inventory and remediate structures built or renovated between 1956 and 1973 (when PCBs in 

open applications were banned in Sweden). Working at the local city level, the inventories have 

mostly been completed and the remediation is expected to be finished by 2016. 

Canada 

PCBs were never manufactured in Canada and most PCBs used in Canada were imported from 

the US. Like the US, Canada banned the import, manufacture, and sale of PCBs in 1977 and 

allowed PCB equipment to be used until the end of its service life in the original regulation. The 

release of PCBs to the environment was made illegal in 1985. 

One significant difference between US and Canada regulations is that Canada does not regulate 

mono- and di-chlorinated biphenyls29. PCBs with more than 2 chlorines are on Schedule 1 of the 

Toxics Substances list in Canada. 

The Canadian Environmental Protection Act (CEPA) covers PCB Regulations.30 Many of the 

regulations are similar to TSCA, such as a general limit of 50 ppm. One major difference is the 

Canadian regulations set deadlines for the phase-out of PCBs in use: 

• Dec. 31, 2009 for equipment containing more than 500 ppm PCBs 

• Dec. 31, 2009 for equipment containing 50-500 ppm PCBs within 100 meters of a drinking

water plant, food or feed processing plant, school, hospital, or care center

• Dec. 31, 2025 for other equipment containing 50-500 ppm PCB

• Dec. 31, 2025 for light ballasts and pole-top electrical transformers

 28 Johansson, Niklas. PCBs in Schools: International Experience: Inventory, Remediation, and Outcomes. EPA 

webinar series PCBs in Schools Session II. April 28, 2014. 

29 http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=0DA2924D-1&wsdoc=4ABEFFC8-5BEC-B57A-F4BF11069545E434 (accessed 13 July 2014). 30 SOR/2008-273 available at http://www.ec.gc.ca/bpc-pcb/default.asp?lang=En&n=663E7488-1 (accessed 21 

October 2013). 
155

Economic analysis 

Cost Estimates of Various PCB Reduction Methods

Chapter 173-333 WAC, the Persistent Bioaccumulative Toxic Chemical rule, requires Ecology 

to follow a specific process while developing Chemical Action Plans (CAPs). Specifically, 

Chapter 173-333-420(1) (f) (iii) (B) requires Ecology to consider the potential economic and 

social impacts of implementing the recommendations within the CAPs. In this section, we 

present estimates for the likely costs associated with the recommendations within the 

polychlorinated biphenyls (PCBs) CAP. The majority of the initial costs would accrue to 

Ecology because of the amount of scoping and research necessary to grasp the extent of PCB 

contamination in the state of Washington. 

Economic analysis, like all analytical exercises, depends on the quantity and quality of data. As 

described throughout the document, PCBs are ubiquitous in the environment, which dictates that 

the scope of activities taken to reduce PCBs involve the combined efforts of public and private 

actors across numerous sectors of the economy throughout Washington. To the greatest extent 

possible given data limitations, we estimated costs to Ecology and the entities directly impacted 

by the recommended actions. 

As expected, we lack data on various processes involved in remediating PCB-contaminated 

buildings, equipment, and habitats. In some cases, representative data is not available. In other 

cases, we determined that systemic attributes of entities affected by the recommendations, 

especially public and quasi-public entities, hindered our ability to reasonably assume that past 

costs serve as a basis for future costs. We determined that a scarcity of data in some areas 

required us to consider certain figures as anecdotal that fail to describe what an average entity in 

Washington affected by the recommendations might face. When we faced questions concerning 

the availability or reliability of data, we proceeded with a qualitative analysis. That is, we 

focused more on identifying the variables that drive the costs to those affected by 

recommendations. 

As evident from the recommendations below, we anticipate building databases concerning PCBs 

based upon data submitted from entities and collected by Ecology. This new data would enable 

us to revisit the qualitative cost estimates presented in this section. Accordingly, it is important to 

remember that qualitative analysis is suggestive as opposed to representative. 

The economic analysis section proceeds with a statement of each recommendation, specific 

goals, related background, and analysis of likely costs. 
156

Historic PCB-Containing Building Materials

1. Identify PCB-containing lamp ballasts in schools and other public buildings. Encourage 

replacement with more energy efficient PCB-free fixtures. 

Goal: Remove remaining PCB lamp ballasts from schools and other publicly owned buildings.

Prior to 1979, PCBs were widely used in fluorescent lamp ballasts, including those in use at 

schools and other public buildings. The pre-1979 ballasts have likely outlived their useful lives

and are at high risk for failing (dripping, smoking, and catching fire). Ballast failures can expose 

children and others that frequently use public school buildings to concentrated PCB oils and 

elevated PCBs in the air. 

There is no easily accessible source of information on how many buildings are of the age and 

construction type likely to have PCB-containing light ballasts. Because children are more 

sensitive to PCBs and school buildings are typically publicly owned, Ecology recommends 

prioritizing public schools. The first step towards implementing this recommendation is to 

conduct a survey of the 295 school districts in Washington to identify how many of the 

approximately 9,000 school buildings are likely to have PCB-containing light ballasts. Other 

public buildings will be surveyed as time and resources allow. Ecology would use the survey 

results to construct a database with information on construction and renovation dates and 

activities of schools (and other public buildings if possible). Ecology would first use the database 

to identify schools where PCB-containing light ballasts are likely still in use. Lamp ballasts with 

PCBs can then be identified through visual inspection.

Ecology anticipates that this recommendation would require an additional FTE at Environmental 

Specialist 3 (ES3) level. One FTE at ES3 level would cost $90,931 annually. We employed 

Washington State employee pay grades at step H (DOP, 2014) and standard overhead cost 

assumptions used for legislative fiscal notes and related estimation (Ecology, 2013). Wages 

include the following adjustments for overhead expenses (per FTE):

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)

Ecology envisions this person would split time between working towards this recommendation 

(0.75 FTE) and working towards Recommendation 5 (0.25 FTE). Because the staff person would 
157

work on two goals, we estimate the cost based on the time spent (.75 FTE) on this 

recommendation as $68,198 annually. Ecology anticipates that work on this recommendation 

could span two years (FY2016- FY2017) for a total estimated cost of $136,396.

We do not have confident cost estimates for replacing light ballasts in schools or other public 

buildings. Estimating the cost of replacing the light ballasts to school districts is not possible 

without knowing how many schools might contain PCB-containing light ballasts, the condition 

of the light ballasts, and the extent of the problem within each building. However, replacing old, 

potentially dangerous light ballasts not only reduces the risk of exposure for children and others 

that use the school buildings frequently, it also reduces energy costs. Accordingly, it makes sense 

to combine PCB removal with initiatives to increase energy efficiency rather than create a new 

program just for removal of PCB-containing ballasts.31

Public money should be used to remove PCB-containing lamp ballasts from schools and other 

public buildings. Schools with PCB-containing lamp ballasts will be provided with information 

about the importance of removing these ballasts and referred to the Office of the Superintendent 

of Public Instruction (OSPI) (or Washington State Department of Health and other available 

resources) to replace these fixtures with more energy-efficient lighting. Ecology has requested 

$200,000 in public money to assist with some of this work. 

2. Develop and promote best management practices to contain PCBs in building materials 

currently in use and those slated for remodel or demolition. 

Goal: Reduce exposure to people from PCBs in historic building materials and prevent PCBs in 

building materials from getting into stormwater.

Historically, PCBs were used at high levels in some caulks and paints. Studies in other areas 

have shown the widespread occurrence of PCB-containing caulk in buildings from about 1950-

1980, especially masonry buildings. Smaller sampling efforts in Washington support this 

conclusion.32 Accordingly, developing best management practices and other materials to provide 

guidance for renovation and demolition of buildings that contain PCB materials would help to 

prevent the release of PCBs into the environment. 

 31 Since 2009, the Legislature has provided money to the Office of the Superintendent of Public Instruction (OSPI) 

and the Department of Commerce to support energy efficiency measures in schools and other public buildings. If the 

grant programs are not funded, the legislature could establish a fund to help offset the costs of replacing PCBcontaining lamp ballasts. 

32 For example, studies suggest that buildings with PCB-containing materials exist in the Duwamish basin. In 

addition, source tracing from cleanup efforts in Tacoma revealed PCBs in sidewalk and building caulk. 
158

The first step toward preventing PCBs in building materials from getting into the environment is 

to compile, compose, and distribute information concerning best management practices for 

containment of PCB-containing materials. Based on available data in Washington, other 

government programs, and scientific literature, Ecology would develop BMPs for containing 

PCBs to prevent exposure during the life of the building and during remodeling or demolition. 

Ecology should also provide education and outreach on BMPs to local governments and those in 

the building trades. 

Ecology estimates that developing BMPs would require an additional FTE of an Environmental 

Specialist 3 (ES3) for a three-year period. We employed Washington State employee pay grades 

at step H (DOP, 2014) and standard overhead cost assumptions used for legislative fiscal notes 

and related estimation (Ecology, 2013). One FTE at ES3 would cost $90,931 annually. Wages 

include the following adjustments for overhead expenses (per FTE):

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)

While working on the BMPs, Ecology would also work to compile existing information into a 

PCB Source Control Guidance Manual to aid Local Source Control work. A number of urban 

waters programs around the northwest have performed PCB source identification work. 

However, to date, the lessons learned from each of these programs have not been synthesized 

and summarized for the benefit of future pollution prevention efforts at the state and local levels.

Ecology estimates that work on the best management practices and source control manual would 

last approximately three years (FY2016-FY2018) and result in total staff costs of $272,793.

3. Assess schools and other public buildings for the presence of PCB-containing building 

materials. 

Goal: Reduce children’s exposure to PCB-containing building materials.

Goal: Prevent PCBs in building materials from getting into stormwater.

Many buildings constructed prior to the ban of PCBs include materials, such as caulk, paint, and 

light ballasts that often contain high levels of PCBs. Industrial buildings, including schools, are 

more likely to contain PCB-contaminated materials than residential buildings. Other states have 

found high levels of PCB contamination in schools. Because children are more sensitive to PCBs 
159

and school buildings are typically publicly owned, Ecology recommends assessing public 

schools for possible PCB contamination first and expanding the effort to include other buildings, 

as appropriate. 

To our knowledge, school districts in Washington have not systematically tested schools for 

PCBs. Schools built prior to 1980 are more likely to contain material with PCBs. The first step in 

assessing public school buildings that contain PCB material is to construct a centralized database 

based on information provided by school districts. The database would contain information on 

the date of construction and dates of renovation for each school building in Washington. The 

database would serve as a mechanism to identify schools, based on construction date, that require 

testing for PCBs. Initial testing would include visual inspections and then physical testing where 

appropriate. Ecology would use the database and test results to determine the scope of the 

problem in Washington and plan accordingly. A similar approach would be used to assess other 

public buildings once the assessment of schools is complete, and as resources allow.

Ecology estimates that the person retained to compile information on PCB light ballasts in 

schools would compile the database for building materials, as well. Ecology anticipates that two 

Environmental Specialist 3 (ES3) positions in other recommendations will merge tasks in 

FY2018:

• The 0.75 FTE at Environmental Specialist 3 (ES3) level at $68,198 annually would spend 

two years (FY2016-FY2017) focusing on light ballasts (Recommendation 1).

• The 0.25 FTE at the ES3 level at $22,733 annually would spend two years (FY2016-2017) 

focusing on electrical equipment (Recommendation 5).

• These positions would shift their database efforts to include other building materials at 

schools.

Ecology anticipates that work on this recommendation could span four years (FY2018- FY2021) 

for a total estimated cost of $363,724.

We employed Washington State employee pay grades at step H (DOP, 2014) and standard 

overhead cost assumptions used for legislative fiscal notes and related estimation (Ecology, 

2013). Wages include the following adjustments for overhead expenses (per FTE):

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)
160

Ecology understands the time and budget constraints facing school districts across the state. 

However, this recommendation would not require school districts to generate new reports or 

information. We assume that school districts have information concerning construction and 

renovation of school buildings from routine recordkeeping, operations, and maintenance 

documents. Therefore, we do not expect a cost to school districts to submit documents to 

Ecology for the database beyond minimal expenditures of time and resources to submit records 

to Ecology.

After compiling the database and conducting initial testing, Ecology would work with school 

districts to plan and coordinate remediation efforts at schools that have PCB-contaminated 

materials. There is no one size fits all approach to remediation projects for buildings containing 

PCBs (Environmental Health & Engineering, 2012). Depending on the extent of contamination, 

schools decide whether to pursue abatement (reducing the amount of PCBs in building materials 

permanently) or mitigation (controlling exposure) procedures. Regardless of the remediation 

technique, schools would need to work with local health agencies, Ecology, and EPA to meet 

removal criteria and follow hazardous waste regulations. 

Estimating the cost of remediating school buildings in Washington is not possible without 

knowing the scope (number of schools and extent of remediation needed) of the problem. The 

number of school buildings and extent of work necessary to bring a building in compliance 

would determine bids from contractors and others involved in remediation activities. In addition, 

remediation activities generally involve mandated testing procedures, extensive planning, 

feasibility studies, and permitting requests. School districts might also have to explore 

temporarily relocating students during the initial testing/cleanup stage (depending on age of 

building and likelihood of PCB contamination). Because of the extensive nature of remediation 

projects, we feel that a database is appropriate to enable Ecology and school districts to narrow 

the scope, identify economies of scale, and prioritize remediation projects. 

As mentioned above, systemic attributes of public entities make some estimates less reliable. We 

consider the process school districts use to price construction projects such a structural 

constraint. Generally, available data suggests that the cost of remediating PCB-contaminated 

school buildings depends on the extent of contamination and approach used by schools 

(abatement or mitigation) to address the problem. To our knowledge, no state has addressed PCB 

contamination in schools in a comprehensive manner. It appears that most schools learn of PCB 

contamination by miscellaneous tests conducted prior to unrelated renovation work, and must 

react quickly to bring exposure levels below EPA guidelines. This creates immediate financial 

stress on local/state agencies responsible for public health, school facilities, etc. Further, school 

districts face unique budget constraints and absorb costs differently than owners of private 

buildings. 
161

Schools generally face administrative procedures (feasibility studies, budget requests, and 

limited window for large remediation projects) that increase the overall cost of projects. 

However, it is difficult to compare how school districts determine costs for certain projects, 

especially when comparing school districts in different regions or states. School districts in 

Washington form cost estimates based on the needs of schools here in Washington. In sum,

existing estimates of remediation projects based solely on PCB contamination are too limited to 

provide a meaningful basis for comparison, at this point. 

Acknowledging the above limitations, though, illustrates the need for Ecology to identify the 

scope of the problem here in Washington. We found estimates for remediation work at five 

schools in New York and two schools in Massachusetts. Estimates from remediation projects at 

the five public schools in New York City ranged from $3.2 million to $3.6 million (2014$) per 

school depending on the techniques (abatement or mitigation) used to address the PCBcontaminated areas (TRC, 2011). In 2010, an elementary school in Lexington, MA found PCBcontaminated material. The school had to close for a week while workers performed testing 

required by the EPA and performed preliminary cleanup work. Feasibility studies suggested that 

officials faced temporary solutions ranging from $3.0 million to $4.6 million (2014$) to relocate 

students while remediating the school (Goddard, 2010). Ultimately, officials decided to replace 

the school with a new $40 million building (Parker, 2014). A different school in Westport, MA 

also found PCB material and encountered initial costs in excess of $3 million (Wagner, 2014). 

Currently, the school faces additional costs ranging from $1.8 million to $7.75 million (2014$) 

(CGKV Architects, 2013) to remediate the PCB-contaminated material. Again, we consider the 

estimates from New York and Massachusetts more suggestive than representative. That said, the 

expenses incurred by the school districts in New York City and Massachusetts, along with the 

extent of activity required to remediate the structures, indicate a need to determine the scope of 

the problem by compiling construction dates and preliminary testing of high risk schools here in 

Washington. 

Current Manufacturing Processes

4. Learn more about what products contain PCBs and promote the use of processes that 

don’t inadvertently generate PCBs. 

Goal: Reduce newly generated PCBs in manufacturing processes.

Unpermitted non-point releases, such as from consumer products, are becoming increasingly 

important to control in order to reduce total PCB delivery. In 1982, EPA identified 70 

manufacturing processes that are likely to inadvertently generate PCBs, but little else is known 

about this potentially large source of uncontrolled PCBs. More information is known about PCBs 

in pigments and dyes, which are a known source of PCBs in the environment and a problem for 
162

paper recyclers in Washington. Ecology recommends adding additional staff and funding to 

determine the extent of inadvertently generated PCBs in consumer products. 

To accomplish the goal of reducing newly generated PCBs in manufacturing processes, Ecology 

would work with EPA, manufacturers, and other partners to identify products that inadvertently 

contain PCBs and explore available alternatives. Ecology would test identified products, and 

provide relevant results to the Department of Enterprise Services (DES) to assist with 

implementing new purchasing policies that provide a preference for products that do not contain 

PCBs. Ecology would also work with the Department of Health and DES to develop a focus 

sheet to educate purchasers and vendors in the state supply chain about the prevalence and 

incidence of products that inadvertently contain PCBs and concisely outlines the problem and its 

potential impacts. 

Learning more about processes that inadvertently generate PCBs would require 1 FTE of a 

Natural Resource Scientist 3 (NRS3) at $116,641. We employed Washington State employee pay 

grades at step H (DOP, 2014) and standard overhead cost assumptions used for legislative fiscal 

notes and related estimation (Ecology, 2013). Wages include the following adjustments for 

overhead expenses (per FTE): 

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)

Ecology anticipates that the NRS3 would test approximately 100 products a year. Ecology 

anticipates that the employee retained to perform the product testing would continue to work on 

this issue on an ongoing basis, with costs from FY2016 through FY2021 totaling $699,846. 

Additionally, at $1,000 per test, Ecology estimates annual testing costs of $100,000.

In addition to testing for PCBs, we also estimated the cost of investigating alternate processes in 

chemical manufacturing, to prospectively replace processes that produce PCBs as a byproduct. 

Specifically, we estimated the cost of initiating an alternatives assessment process for pigments 

and dyes, based on the Interstate Chemicals Clearinghouse (IC2) Alternatives Assessment Guide. 

Ecology anticipates that producing such an “Alternatives Assessment” would cost $470,000 in 

FY2016, which includes hiring a consultant. Ecology plans to engage business and other 

concerned stakeholders to participate in the alternatives assessment process. If there are currently 
163

no alternatives that do not generate PCBs, Ecology would engage Green Chemistry Northwest or 

a similar institution to develop alternative processes. 

Historic Electrical Equipment

5. Survey owners of historic electrical equipment, including transformers and large 

capacitors.

Goal: Confirm estimates of EPA-regulated electrical equipment with more than 500 parts per 

million (ppm) PCBs, learn what is known about electrical equipment with the PCBs greater than 

2 ppm, and find out when such electrical equipment is estimated for replacement. 

Electrical equipment, such as transformers and capacitors, used by utility and large non-utility 

industrial sites are the primary historical use of PCBs. Concentrations of PCBs in many pieces of 

electrical equipment are high compared to other sources, so relatively rare leaks and spills can 

release a significant amount of PCBs into the environment. Ecology recommends a survey of the 

61 utilities and other sites that provide electricity to construct a recent and relevant database of 

electrical equipment that contains PCBs in Washington. 

We anticipate that this recommendation would most likely affect utilities and large non-utility 

entities that provide electrical transmission (operate transformers or large capacitors) on site. The 

nature of electricity and the regulatory status of utilities presents unique challenges regarding this 

recommendation. Electricity is difficult to store, impossible to substitute, and a necessity to most 

consumers and businesses. Accordingly, each utility in the state enjoys a natural monopoly in the 

transmission of electricity to end users within a defined area. In exchange for monopoly status, 

various regulatory agencies set prices administratively based on costs incurred by utilities. The 

process of setting prices administratively makes it difficult, if not impossible, for us to determine 

the cost of individual projects and to determine how the utilities absorb costs. Regulations also 

require utilities to provide electricity on demand that makes a recommendation to test all existing 

equipment difficult to undertake without potentially disrupting service. In sum, from a practical 

perspective, a recommendation for further testing could prove cost prohibitive to utilities and 

consumers. 

Prior to the ban on PCBs, manufacturers of transformers, capacitors, and other electrical 

equipment used oil-containing PCBs as a coolant within the housing of utility equipment. Since 

the ban on PCBs took effect in the United States, utilities and owners of electrical equipment 

have worked to identify and replace equipment that contains PCBs. According to a report 

submitted by the Utility Solid Waste Activities Group (USWAG, 2010) to the EPA, utilities 

across the country have reduced the use of equipment containing PCBs through normal 

maintenance and replacement procedures. A similar statement by the Northwest Public Power 
164

Association (2010), extensive discussions with representatives from various utilities, and local 

news reports (Kramer, 2014), suggest that utilities across Washington have also replaced many 

units that contain PCBs. Currently, however, no reporting requirement exists to verify the claims 

of utility and a non-utility users of electrical equipment concerning retirement of equipment that 

contains PCBs.

Ecology believes that surveying the state’s utilities and compiling a centralized database based 

on past, present, and future efforts by owners of electrical equipment is within reason and at 

minimal cost to the owners of electrical equipment. Because electrical equipment that might 

contain PCBs are part of a complex transmission system that requires significant time and 

resources to maintain, Ecology assumes that owners of electrical equipment maintain records 

that form the basis of routine maintenance schedules. Over the past 15 years, increased demand 

for energy and the interconnectedness of the electrical grid has changed the regulatory 

environment in such a way that providers of electricity at all levels of the transmission process 

must maintain certain levels of service at all times. In addition, utilities upgrade old and 

inefficient transmission equipment (often the equipment that might also contain PCBs) to 

increase efficiency and output. The need to maintain a consistent supply of energy and increase 

profitability, where possible, necessitates that utilities maintain extensive records. Therefore, we 

assume that utilities and other large non-utility owners know which pieces of equipment have 

PCBs or may have PCBs based on the age of the equipment.

Because the utilities have taken action to address the use of equipment that contains PCBs, 

Ecology believes establishing a database of current equipment containing PCBs would require 

minimal effort and cost to Ecology and users and electrical equipment. The survey of electrical 

equipment would not include small capacitors. The survey would not require additional testing or 

disposal of equipment by a certain date. The survey would ask owners to report what they know 

about detectable levels of PCBs in their equipment, using the industry standard detection level 

that is currently 2 parts per million (ppm), and detail when they expect all the equipment to be 

replaced based on their current maintenance practices. A statewide inventory will allow the state 

to confirm current inventories and target efforts to prevent releases of PCBs from this equipment.

Ecology anticipates that the FTE assigned to collect data on PCBs in public schools 

(Recommendation 1) would also assemble and enter data on electrical equipment. Ecology 

envisions this person would split time between working towards this recommendation (.25 FTE 

on this goal) and working towards Recommendation 1. 

One FTE at Environmental Specialist 3 (ES3) level would cost $90,931 annually. We employed 

Washington State employee pay grades at step H (DOP, 2014) and standard overhead cost 

assumptions used for legislative fiscal notes and related estimation (Ecology, 2013). Wages 

include the following adjustments for overhead expenses (per FTE):
165

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)

Because the staff person would work on two goals, we estimate the cost based on the time spent 

(.25 FTE) on this recommendation as $22,733 annually. Ecology anticipates that work on this 

recommendation could span two years (FY2016-FY2017) for a total estimated cost of $45,466.

Multi-Source

6. Expand environmental monitoring to identify any new areas requiring cleanup. 

Goal: Find areas with highly concentrated PCBs and clean them up to prevent the wider release 

of PCBs. 

Goal: Find out more about the distribution of PCBs in Washington to prioritize future actions. 

Ecology should expand environmental monitoring of water, fish tissue, and sediment to identify 

PCB hot spots, such as the recently found historical landfill of electrical equipment on Bradford 

Island in the Columbia River. Historical disposal practices at Bradford Island near Bonneville 

Dam on the Columbia River contaminated resident fish with high levels of PCBs. Levels were 

high enough to prompt Oregon and Washington to issue a joint fish consumption advisory for 

select species from Bonneville Dam upstream to McNary Dam. A number of fish sampling 

efforts in the Columbia basin (CRITFC, Hanford Corridor Study and Ecology’s Freshwater Fish 

Contaminant Monitoring Program) found other areas (mid-Columbia and Snake River) with 

elevated levels of PCBs and a number of hydroelectric facilities. 

To our knowledge no work has been done to identify sources of contaminants in these areas. The 

proposed monitoring would conduct sampling to determine if contaminant sources exist in areas 

with a focus on hydroelectric facilities. Ecology may also use mapping and historical information 

on the location of potential sites, such as landfills, industrial sites, railroad switching yards, etc., 

to find potential sites. Newly identified sites would receive priority for clean up using existing 

procedures. In addition to identifying new hot spots, Ecology would continue its trend 

monitoring to show changes in PCBs in the environment and biota over time. 

Air deposition is a potentially significant pathway for PCBs to move into the environment. 

Ecology proposes to investigate monitoring air deposition to assess the relative importance of 

this pathway.
166

Ecology estimates that the workload generated by Recommendation 6 would require the addition 

of three FTE. Ecology estimates that it would take 1 FTE Natural Resource Scientist 3 (NRS3) 

to identify new hot spots and implement necessary testing procedures. In addition, Ecology 

estimates that effectively monitoring hot spots would require an Environmental Specialist 2 

(ES2) FTE to provide support for testing. The addition of one FTE at NRS3 level would cost 

$116,641 annually, and one FTE at the ES2 level would cost $79,513 annually. To monitor air 

deposition, Ecology would require an additional FTE at the Environmental Specialist 3 (ES3) 

level to conduct the air monitoring tests. The ES3 would cost $90,931 annually. 

We employed Washington State employee pay grades at step H (DOP, 2014) and standard 

overhead cost assumptions used for legislative fiscal notes and related estimation (Ecology,

2013). Wages include the following adjustments for overhead expenses (per FTE):

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)

Ecology anticipates that the work of the NRS3 toward this recommendation would take 3 years, 

with assistance from the ES2 for 2 years. Ecology anticipates that testing to identify potential hot 

spots would result in lab costs of $87,192 annually for two years. Ecology anticipates that the 

work of the ES3 to monitor air disposition would take two years, and anticipates testing costs of 

$37,967 annually for two years to monitor air deposition.

Table 37 summarizes the costs associated with this recommendation.

Table 37. Summary of the costs associated with Recommendation 6.

FY 2016 FY 2017 FY 2018

Hot spot monitoring

1 FTE NRS3 $116,641 $116,641 $116,641

1 FTE ES2 $79,513 $79,513

Hot spot testing $87,192 $87,192

Air monitoring

1 FTE ES3 $90,931 $90,931

Air testing $37,967 $37,967
167

7. Conduct a public educational campaign. 

Goal: Provide information to residents about ways they can minimize exposure. 

Goal: Raise awareness of the problems associated with current and past production of PCBs.

Goal: Educate residents to identify and address possible household sources of PCBs.

To reach the goal of raising public awareness for PCBs, Ecology and the Department of Health 

would work together to help residents, people who fish, schools, local governments and 

businesses understand the risks associated with PCB exposure and ways to reduce risks, 

including the availability of safer alternatives. 

The public educational campaign will include perspectives on public health risks and information 

on where exposures to PCB are most likely. It will also include advice on how individuals can 

minimize their own exposures to PCBs. The campaign will include where to look for potential 

sources of PCBs in households, such as in old appliances, electrical equipment, and building 

materials. It will also teach the public how to safely remove and dispose of these materials to 

prevent PCB releases. 

Ecology anticipates that this recommendation would require the addition of 1 FTE 

Communication Consultant 3 (CC3) to develop and disseminate information to businesses, 

purchasing agents, vendors, residents, fishers, schools, and local governments describing the 

hazards associated with exposure to PCBs and resources available to address the problem. This 

FTE would cost $92,957 each year. This work includes promotion of BMPs for containment and 

demolition of buildings containing PCB laden materials.

We employed Washington State employee pay grades at step H (DOP, 2014) and standard 

overhead cost assumptions used for legislative fiscal notes and related estimation (Ecology,

2013). Wages include the following adjustments for overhead expenses (per FTE): 

• Benefits of 33.0 percent of salary

• Goods and services of $5,709 annually, or $2.74 per hour

• Travel costs of $1,394 annually, or $0.67 per hour

• Equipment costs of $1,131 annually, or $0.54 per hour

• Agency administrative overhead of 32.25 percent of salaries and benefits (Agency 

administrative overhead FTEs are included at 0.15 FTE per direct FTE, and are identified as 

Fiscal Analyst 2 and IT Specialist 2.)

Ecology anticipates that the community awareness work would continue on an ongoing basis. 

Estimated costs for this recommendation from FY2016 through FY2021 are $557,742.
168

8. Conduct a study on which PCB congeners are present in Washington residents

Goal: Learn more about PCB congeners to which Washington residents are exposed

Goal: Find out more about the distribution of PCBs in Washington to prioritize future actions

Within available resources, the Department of Health should conduct bio-monitoring of 

Washington residents for PCBs including PCB 11 and other inadvertently produced PCBs 

associated with dyes, pigments, and printing inks. Researchers would use the data to better 

understand 1) the extent of total human exposure from multiple potential pathways and 2) the 

relative contribution of these congeners to human body burden of PCBs. In addition, the data 

would enable researchers to estimate the statewide distribution of PCBs in Washington residents, 

which would provide a better baseline than national data given the elevated levels of PCBs in 

local fish populations and relatively high fish consumption in a number of Washington 

communities and regions.

Ecology believes that this sort of bio-monitoring falls within criteria already established under 

existing DOH programs. Accordingly, we do not anticipate new costs with this recommendation. 

Summary of Economic Impacts

Table 38 presents estimated costs to Ecology to implement the recommendations above. 

Table 38. Estimated costs to Ecology to implement recommendations

Recommendation FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

1

0.75 FTE 

(ES3) to 

survey and 

assess lamp 

ballasts in 

schools. 

$68,198 $68,198

2

1 FTE (ES3) to 

develop and 

promote 

BMPs.

$90,931 $90,931 $90,931

3

1 FTE (ES3) to 

assess 

schools for 

PCBcontaining 

building 

materials. 

$90,931 $90,931 $90,931 $90,931

4

Conduct an 

alternatives 

assessment 

for pigments 

and dyes.

$470,000

1 FTE (NRS3) $116,641 $116,641 $116,641 $116,641 $116,641 $116,641
169

to look for 

sources of 

PCBs in 

products.

Lab costs for 

product 

testing.

$100,000 $100,000 $100,000 $100,000 $100,000 $100,000

5

0.25 FTE 

(ES3) to 

survey owners 

of electrical 

equipment.

$22,733 $22,733

6

1 FTE (NRS3) 

to identify 

environmental 

hot spots.

$116,641 $116,641 $116,641

1 FTE (ES2) to 

assist with 

monitoring.

$79,513 $79,513

Environmental 

monitoring/ lab 

analysis.

$87,192 $87,192

1 FTE (ES3) 

for air 

monitoring

$90,931 $90,931

Sampling/lab 

analysis for air 

monitoring 

stations.

$37,967 $37,967

7

1 FTE (CC3) 

to conduct an 

education 

campaign.

$92,957 $92,957 $92,957 $92,957 $92,957 $92,957

Total $1,373,704 $903,704 $608,101 $400,529 $400,529 $400,529

All estimates in (2014 $)

ES2 = Environmental Specialist 2

ES3 = Environmental Specialist 3

NRS3 = Natural Resource Scientist 3

CC3 = Communications Consultant 3

Ecology does not anticipate that these initial recommendations would increase compliance costs 

for affected firms or public entities. 
170

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Appendices

Appendix A. List of 209 PCB Congeners (EPA, 2003)

CASRN Congener 

Number IUPAC Name

1336-36-3 Polychlorinated biphenyl (PCB)

2051-60-7 1 2-Chlorobiphenyl

2051-61-8 2 3-Chlorobiphenyl

2051-62-9 3 4-Chlorobiphenyl

13029-08-8 4 2,2'-Dichlorobiphenyl

16605-91-7 5 2,3-Dichlorobiphenyl

25569-80-6 6 2,3'-Dichlorobiphenyl

33284-50-3 7 2,4-Dichlorobiphenyl

34883-43-7 8 2,4'-Dichlorobiphenyl

34883-39-1 9 2,5-Dichlorobiphenyl

33146-45-1 10 2,6-Dichlorobiphenyl

2050-67-1 11 3,3'-Dichlorobiphenyl

2974-92-7 12 3,4-Dichlorobiphenyl

2974-90-5 13 3,4'-Dichlorobiphenyl

34883-41-5 14 3,5-Dichlorobiphenyl

2050-68-2 15 4,4'-Dichlorobiphenyl

38444-78-9 16 2,2',3-Trichlorobiphenyl

37680-66-3 17 2,2',4-Trichlorobiphenyl

37680-65-2 18 2,2',5-Trichlorobiphenyl

38444-73-4 19 2,2',6-Trichlorobiphenyl

38444-84-7 20 2,3,3'-Trichlorobiphenyl

55702-46-0 21 2,3,4-Trichlorobiphenyl

38444-85-8 22 2,3,4'-Trichlorobiphenyl

55720-44-0 23 2,3,5-Trichlorobiphenyl

55702-45-9 24 2,3,6-Trichlorobiphenyl

55712-37-3 25 2,3',4-Trichlorobiphenyl

38444-81-4 26 2,3',5-Trichlorobiphenyl

38444-76-7 27 2,3',6-Trichlorobiphenyl

7012-37-5 28 2,4,4'-Trichlorobiphenyl

15862-07-4 29 2,4,5-Trichlorobiphenyl

35693-92-6 30 2,4,6-Trichlorobiphenyl

16606-02-3 31 2,4',5-Trichlorobiphenyl
206

38444-77-8 32 2,4',6-Trichlorobiphenyl

38444-86-9 33 2,3',4'-Trichlorobiphenyl

37680-68-5 34 2,3',5'-Trichlorobiphenyl

37680-69-6 35 3,3',4-Trichlorobiphenyl

38444-87-0 36 3,3',5-Trichlorobiphenyl

38444-90-5 37 3,4,4'-Trichlorobiphenyl

53555-66-1 38 3,4,5-Trichlorobiphenyl

38444-88-1 39 3,4',5-Trichlorobiphenyl

38444-93-8 40 2,2',3,3'-Tetrachlorobiphenyl

52663-59-9 41 2,2',3,4-Tetrachlorobiphenyl

36559-22-5 42 2,2',3,4'-Tetrachlorobiphenyl

70362-46-8 43 2,2',3,5-Tetrachlorobiphenyl

41464-39-5 44 2,2',3,5'-Tetrachlorobiphenyl

70362-45-7 45 2,2',3,6-Tetrachlorobiphenyl

41464-47-5 46 2,2',3,6'-Tetrachlorobiphenyl

2437-79-8 47 2,2',4,4'-Tetrachlorobiphenyl

70362-47-9 48 2,2',4,5-Tetrachlorobiphenyl

41464-40-8 49 2,2',4,5'-Tetrachlorobiphenyl

62796-65-0 50 2,2',4,6-Tetrachlorobiphenyl

68194-04-7 51 2,2',4,6'-Tetrachlorobiphenyl

35693-99-3 52 2,2',5,5'-Tetrachlorobiphenyl

41464-41-9 53 2,2',5,6'-Tetrachlorobiphenyl

15968-05-5 54 2,2',6,6'-Tetrachlorobiphenyl

74338-24-2 55 2,3,3',4-Tetrachlorobiphenyl

41464-43-1 56 2,3,3',4'-Tetrachlorobiphenyl

70424-67-8 57 2,3,3',5-Tetrachlorobiphenyl

41464-49-7 58 2,3,3',5'-Tetrachlorobiphenyl

74472-33-6 59 2,3,3',6-Tetrachlorobiphenyl

33025-41-1 60 2,3,4,4'-Tetrachlorobiphenyl

33284-53-6 61 2,3,4,5-Tetrachlorobiphenyl

54230-22-7 62 2,3,4,6-Tetrachlorobiphenyl

74472-34-7 63 2,3,4',5-Tetrachlorobiphenyl

52663-58-8 64 2,3,4',6-Tetrachlorobiphenyl

32284-54-7 65 2,3,5,6-Tetrachlorobiphenyl

32598-10-0 66 2,3',4,4'-Tetrachlorobiphenyl

73575-53-8 67 2,3',4,5-Tetrachlorobiphenyl

73575-52-7 68 2,3',4,5'-Tetrachlorobiphenyl
207

60233-24-1 69 2,3',4,6-Tetrachlorobiphenyl

32598-11-1 70 2,3',4',5-Tetrachlorobiphenyl

41464-46-4 71 2,3',4',6-Tetrachlorobiphenyl

41464-42-0 72 2,3',5,5'-Tetrachlorobiphenyl

74338-23-1 73 2,3',5',6-Tetrachlorobiphenyl

32690-93-0 74 2,4,4',5-Tetrachlorobiphenyl

32598-12-2 75 2,4,4',6-Tetrachlorobiphenyl

70362-48-0 76 2,3',4',5'-Tetrachlorobiphenyl

32598-13-3 77 3,3',4,4'-Tetrachlorobiphenyl

70362-49-1 78 3,3',4,5-Tetrachlorobiphenyl

41464-48-6 79 3,3',4,5'-Tetrachlorobiphenyl

33284-52-5 80 3,3',5,5'-Tetrachlorobiphenyl

70362-50-4 81 3,4,4',5-Tetrachlorobiphenyl

52663-62-4 82 2,2',3,3',4-Pentachlorobiphenyl

60145-20-2 83 2,2',3,3',5-Pentachlorobiphenyl

52663-60-2 84 2,2',3,3',6-Pentachlorobiphenyl

65510-45-4 85 2,2',3,4,4'-Pentachlorobiphenyl

55312-69-1 86 2,2',3,4,5-Pentachlorobiphenyl

38380-02-8 87 2,2',3,4,5'-Pentachlorobiphenyl

55215-17-3 88 2,2',3,4,6-Pentachlorobiphenyl

73575-57-2 89 2,2',3,4,6'-Pentachlorobiphenyl

68194-07-0 90 2,2',3,4',5-Pentachlorobiphenyl

68194-05-8 91 2,2',3,4',6-Pentachlorobiphenyl

52663-61-3 92 2,2',3,5,5'-Pentachlorobiphenyl

73575-56-1 93 2,2',3,5,6-Pentachlorobiphenyl

73575-55-0 94 2,2',3,5,6'-Pentachlorobiphenyl

38379-99-6 95 2,2',3,5',6-Pentachlorobiphenyl

73575-54-9 96 2,2',3,6,6'-Pentachlorobiphenyl

41464-51-1 97 2,2',3,4',5'-Pentachlorobiphenyl

60233-25-2 98 2,2',3,4',6'-Pentachlorobiphenyl

38380-01-7 99 2,2',4,4',5-Pentachlorobiphenyl

39485-83-1 100 2,2',4,4',6-Pentachlorobiphenyl

37680-73-2 101 2,2',4,5,5'-Pentachlorobiphenyl

68194-06-9 102 2,2',4,5,6'-Pentachlorobiphenyl

60145-21-3 103 2,2',4,5',6-Pentachlorobiphenyl

56558-16-8 104 2,2',4,6,6'-Pentachlorobiphenyl

32598-14-4 105 2,3,3',4,4'-Pentachlorobiphenyl
208

70424-69-0 106 2,3,3',4,5-Pentachlorobiphenyl

70424-68-9 107 2,3,3',4',5-Pentachlorobiphenyl

70362-41-3 108 2,3,3',4,5'-Pentachlorobiphenyl

74472-35-8 109 2,3,3',4,6-Pentachlorobiphenyl

38380-03-9 110 2,3,3',4',6-Pentachlorobiphenyl

39635-32-0 111 2,3,3',5,5'-Pentachlorobiphenyl

74472-36-9 112 2,3,3',5,6-Pentachlorobiphenyl

68194-10-5 113 2,3,3',5',6-Pentachlorobiphenyl

74472-37-0 114 2,3,4,4',5-Pentachlorobiphenyl

74472-38-1 115 2,3,4,4',6-Pentachlorobiphenyl

18259-05-7 116 2,3,4,5,6-Pentachlorobiphenyl

68194-11-6 117 2,3,4',5,6-Pentachlorobiphenyl

31508-00-6 118 2,3',4,4',5-Pentachlorobiphenyl

56558-17-9 119 2,3',4,4',6-Pentachlorobiphenyl

68194-12-7 120 2,3',4,5,5'-Pentachlorobiphenyl

56558-18-0 121 2,3',4,5',6-Pentachlorobiphenyl

76842-07-4 122 2,3,3',4',5'-Pentachlorobiphenyl

65510-44-3 123 2,3',4,4',5'-Pentachlorobiphenyl

70424-70-3 124 2,3',4',5,5'-Pentachlorobiphenyl

74472-39-2 125 2,3',4',5',6-Pentachlorobiphenyl

57465-28-8 126 3,3',4,4',5-Pentachlorobiphenyl

39635-33-1 127 3,3',4,5,5'-Pentachlorobiphenyl

38380-07-3 128 2,2',3,3',4,4'-Hexachlorobiphenyl

55215-18-4 129 2,2',3,3',4,5-Hexachlorobiphenyl

52663-66-8 130 2,2',3,3',4,5'-Hexachlorobiphenyl

61798-70-7 131 2,2',3,3',4,6-Hexachlorobiphenyl

38380-05-1 132 2,2',3,3',4,6'-Hexachlorobiphenyl

35694-04-3 133 2,2',3,3',5,5'-Hexachlorobiphenyl

52704-70-8 134 2,2',3,3',5,6-Hexachlorobiphenyl

52744-13-5 135 2,2',3,3',5,6'-Hexachlorobiphenyl

38411-22-2 136 2,2',3,3',6,6'-Hexachlorobiphenyl

35694-06-5 137 2,2',3,4,4',5-Hexachlorobiphenyl

35065-28-2 138 2,2',3,4,4',5'-Hexachlorobiphenyl

56030-56-9 139 2,2',3,4,4',6-Hexachlorobiphenyl

59291-64-4 140 2,2',3,4,4',6'-Hexachlorobiphenyl

52712-04-6 141 2,2',3,4,5,5'-Hexachlorobiphenyl

41411-61-4 142 2,2',3,4,5,6-Hexachlorobiphenyl
209

68194-15-0 143 2,2',3,4,5,6'-Hexachlorobiphenyl

68194-14-9 144 2,2',3,4,5',6-Hexachlorobiphenyl

74472-40-5 145 2,2',3,4,6,6'-Hexachlorobiphenyl

51908-16-8 146 2,2',3,4',5,5'-Hexachlorobiphenyl

68194-13-8 147 2,2',3,4',5,6-Hexachlorobiphenyl

74472-41-6 148 2,2',3,4',5,6'-Hexachlorobiphenyl

38380-04-0 149 2,2',3,4',5',6-Hexachlorobiphenyl

68194-08-1 150 2,2',3,4',6,6'-Hexachlorobiphenyl

52663-63-5 151 2,2',3,5,5',6-Hexachlorobiphenyl

68194-09-2 152 2,2',3,5,6,6'-Hexachlorobiphenyl

35065-27-1 153 2,2',4,4',5,5'-Hexachlorobiphenyl

60145-22-4 154 2,2',4,4',5,6'-Hexachlorobiphenyl

33979-03-2 155 2,2',4,4',6,6'-Hexachlorobiphenyl

38380-08-4 156 2,3,3',4,4',5-Hexachlorobiphenyl

69782-90-7 157 2,3,3',4,4',5'-Hexachlorobiphenyl

74472-42-7 158 2,3,3',4,4',6-Hexachlorobiphenyl

39635-35-3 159 2,3,3',4,5,5'-Hexachlorobiphenyl

41411-62-5 160 2,3,3',4,5,6-Hexachlorobiphenyl

74472-43-8 161 2,3,3',4,5',6-Hexachlorobiphenyl

39635-34-2 162 2,3,3',4',5,5'-Hexachlorobiphenyl

74472-44-9 163 2,3,3',4',5,6-Hexachlorobiphenyl

74472-45-0 164 2,3,3',4',5',6-Hexachlorobiphenyl

74472-46-1 165 2,3,3',5,5',6-Hexachlorobiphenyl

41411-63-6 166 2,3,4,4',5,6-Hexachlorobiphenyl

52663-72-6 167 2,3',4,4',5,5'-Hexachlorobiphenyl

59291-65-5 168 2,3',4,4',5',6-Hexachlorobiphenyl

32774-16-6 169 3,3',4,4',5,5'-Hexachlorobiphenyl

35065-30-6 170 2,2',3,3',4,4',5-Heptachlorobiphenyl

52663-71-5 171 2,2',3,3',4,4',6-Heptachlorobiphenyl

52663-74-8 172 2,2',3,3',4,5,5'-Heptachlorobiphenyl

68194-16-1 173 2,2',3,3',4,5,6-Heptachlorobiphenyl

38411-25-5 174 2,2',3,3',4,5,6'-Heptachlorobiphenyl

40186-70-7 175 2,2',3,3',4,5',6-Heptachlorobiphenyl

52663-65-7 176 2,2',3,3',4,6,6'-Heptachlorobiphenyl

52663-70-4 177 2,2',3,3',4,5',6'-Heptachlorobiphenyl

52663-67-9 178 2,2',3,3',5,5',6-Heptachlorobiphenyl

52663-64-6 179 2,2',3,3',5,6,6'-Heptachlorobiphenyl
210

35065-29-3 180 2,2',3,4,4',5,5'-Heptachlorobiphenyl

74472-47-2 181 2,2',3,4,4',5,6-Heptachlorobiphenyl

60145-23-5 182 2,2',3,4,4',5,6'-Heptachlorobiphenyl

52663-69-1 183 2,2',3,4,4',5',6-Heptachlorobiphenyl

74472-48-3 184 2,2',3,4,4',6,6'-Heptachlorobiphenyl

52712-05-7 185 2,2',3,4,5,5',6-Heptachlorobiphenyl

74472-49-4 186 2,2',3,4,5,6,6'-Heptachlorobiphenyl

52663-68-0 187 2,2',3,4',5,5',6-Heptachlorobiphenyl

74487-85-7 188 2,2',3,4',5,6,6'-Heptachlorobiphenyl

39635-31-9 189 2,3,3',4,4',5,5'-Heptachlorobiphenyl

41411-64-7 190 2,3,3',4,4',5,6-Heptachlorobiphenyl

74472-50-7 191 2,3,3',4,4',5',6-Heptachlorobiphenyl

74472-51-8 192 2,3,3',4,5,5',6-Heptachlorobiphenyl

69782-91-8 193 2,3,3',4',5,5',6-Heptachlorobiphenyl

35694-08-7 194 2,2',3,3',4,4',5,5'-Octachlorobiphenyl

52663-78-2 195 2,2',3,3',4,4',5,6-Octachlorobiphenyl

42740-50-1 196 2,2',3,3',4,4',5,6'-Octachlorobiphenyl

33091-17-7 197 2,2',3,3',4,4',6,6'-Octachlorobiphenyl

68194-17-2 198 2,2',3,3',4,5,5',6-Octachlorobiphenyl

52663-75-9 199 2,2',3,3',4,5,5',6'-Octachlorobiphenyl

52663-73-7 200 2,2',3,3',4,5,6,6'-Octachlorobiphenyl

40186-71-8 201 2,2',3,3',4,5',6,6'-Octachlorobiphenyl

2136-99-4 202 2,2',3,3',5,5',6,6'-Octachlorobiphenyl

52663-76-0 203 2,2',3,4,4',5,5',6-Octachlorobiphenyl

74472-52-9 204 2,2',3,4,4',5,6,6'-Octachlorobiphenyl

74472-53-0 205 2,3,3',4,4',5,5',6-Octachlorobiphenyl

40186-72-9 206 2,2',3,3',4,4',5,5',6-Nonachlorobiphenyl

52663-79-3 207 2,2',3,3',4,4',5,6,6'-Nonachlorobiphenyl

52663-77-1 208 2,2',3,3',4,5,5',6,6'-Nonachlorobiphenyl

2051-24-3 209 Decachlorobiphenyl
211

Appendix B. PCB Mixtures and Trade Names (EPA 

2013d)

Acector Dicolor PCB

Adkarel Diconal PCB's

ALC Diphenyl, chlorinated PCBs

Apirolio DK Pheaoclor

Apirorlio Duconal Phenochlor

Arochlor Dykanol Phenoclor

Arochlors Educarel Plastivar

Aroclor EEC-18 Polychlorinated biphenyl

Aroclors Elaol Polychlorinated biphenyls

Arubren Electrophenyl Polychlorinated diphenyl

Asbestol Elemex Polychlorinated diphenyls

ASK Elinol Polychlorobiphenyl

Askael Eucarel Polychlorodiphenyl

Askarel Fenchlor Prodelec

Auxol Fenclor Pydraul

Bakola Fenocloro Pyraclor

Biphenyl, chlorinated Gilotherm Pyralene

Chlophen Hydol Pyranol

Chloretol Hyrol Pyroclor

Chlorextol Hyvol Pyronol

Chlorinated biphenyl Inclor Saf-T-Kuhl

Chlorinated diphenyl Inerteen Saf-T-Kohl

Chlorinol Inertenn Santosol

Chlorobiphenyl Kanechlor Santotherm

Chlorodiphenyl Kaneclor Santothern

Chlorphen Kennechlor Santovac

Chorextol Kenneclor Solvol

Chorinol Leromoll Sorol

Clophen Magvar Soval

Clophenharz MCS 1489 Sovol

Cloresil Montar Soltol

Clorinal Nepolin Terphenychlore

Clorphen No-Flamol Therminal

Decachlorodiphenyl NoFlamol Therminol

Delor Non-Flamol Turbinol

Delorene Olex-sf-d

Diaclor Orophene
212

Appendix C. Distribution of Aroclor mixtures (EPA, 

2013d)
213
214
215

Appendix D. Chemical Processes that have the 

Potential to Generate PCBs 

The following was transcribed from EPA rulemaking records from “Polychlorinated Biphenyls 

(PCBs); Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions: 

Exclusions, Exemptions and Use Authorizations” Doc No. OPTS-62032. This was transcribed 

for Panero et al. (2005). 

Chlorinated Compounds 

Produced Using Direct 

Chlorination

Chlorinated Compounds 

Produced Using Chlorinated 

Feedstocks

Non-chlorinated Compounds 

Produced Using Chlorinated 

Feedstocks

IPPPE

U No.

Petroleum Feedstock: BENZENE

Chlorinated benzenes Chloronitrobenzenes Phenol 8

Chlorinated phenols Dichloronitrobenzenes Aniline 9

Hexachlorocyclohexane Dichloroanilines o-Phenylenediamine 28

Chloranilines Chlorinated methyl phenols o-,p-Nitroanilines 29

Trichloroanilines Chlorophenyl phenylethers Diphenylamine 34

Chlorinated benzidines Acetanilide 17

Petroleum Feedstock: ETHYLENE

Mono, di-chloroacetic acid Ethyl chloroacetate Glycine 108

Sodium chloroacetate Vinyl chloride Cyanoacetic acid 111

Chlorinated ethanes Vinylidene chloride Sodium, carboxymethyl cellulose 112

Chlorinated ethylenes Bis (2-chloroethyl) ether Ethyl cellulose 118

Ethylene chlorohydrin Chlorinated acetophenones Ethylene diamine 134

Chlorinated, fluorinated 

ethanes Choline chloride Aminoethylethanolamine 135

Chlorinated, brominated 

ethylenes Hexachlorobutadiene Mono-, di-, and triethylene glycol ethers 150

Chlorinated, fluorinated 

ethylenes Tetramethylethylene diamine (3341)

Chlorinated acetaldehyde

Chlorinated acetyl chloride

Hexachlorobenzene

Petroleum Feedstock: METHANE

Chlorinated methanes Chlorinated, fluorinated 

methanes Carbon tetrabromide 162

Phosgene Chlorinated, brominated 

methanes Carbon tetrafluoride (812)

Tetrachloroethane Bis (chloromethyl) ether

Chlorodifluoroethane (?) Cyanuric chloride

Perchloromethyl mercaptan (?) Trichloroethylene

Cyanogen chloride
216

Chlorinated Compounds Produced 

Using Direct Chlorination

Chlorinated Compounds 

Produced Using 

Chlorinated Feedstocks

Non-chlorinated Compounds 

Produced Using Chlorinated 

Feedstocks

IPPPE

U No.

Petroleum Feedstock: NAPHTHALENE

Chloronaphthalenes

Tetrachlorophthalic anhydride

Petroleum Feedstock: PARAFFINS

n-Propyl chloride n-Propylamine 231

Carbon tetrachloride Butyronitrile 232

Perchloroethylene Amyl amines 243

Hexachloroethane Amyl alcohols 244

Amyl chlorides Amyl Mercaptans 245

Chloroprene Benzophenone 249

Hexachlorocyclopentadiene Linear alkylbenzenes (2417)

Methallyl Chloride

Petroleum Feedstock: PROPYLENE

Dichlorohydrin Epichlorohydrin Isopropylphenols 272

Chloranil Bis (2-chloroisopropyl) 

ether Propylene oxide 280

Propylene chlorohydrin Anisols 302

Chlorinated propanes Allyl alcohol 317

Chlorinated propylenes Glycerol 318/31

9

Propyl amines (1446)

Petroleum Feedstock: TOLUENE

Benzyl chloride Benzoyl chloride Benzyl alcohol 334

Benzyl dichloride Benzyl amine 335

Benzyl trichloride Benzamide 337

Chlorotoluenes Toluenesulfonamide 358

Chlorobenzaldehyde Benzoyl peroxide (495)

Chlorobenzoic acids & esters

Chlorobenzoyl chlorides

Toluenesulfonyl chloride

Chlorobenzotrichlorides

*The IPPEU No. refers to the process description in the 1977 EPA summary (EPA, 1977). Those numbers bracketed 

by parentheses refer to the OCPDB numbers in the 1980 EPA summary (EPA, 1980)
217

Appendix E. Reported Products with Inadvertently 

Generated PCBs

Manufacturers are required to report inadvertent generation of PCBs to EPA. Below is a 

summary table of the 77 reports received from 1994 to present. See the Regulations section for 

explanation of the requirement and “discounted.”

Date Reporter Product Concentration or 

amount Category

4/13/1995 Sun Chem. Corp

2-Naphthalenecarboxylic 

acid, 4-[(2,5-

dichlorophenyl) azo]-3-

hydroxy, a dye precursor

pigments and dyes

2/11/2004 Clariant imported dyes pigments and dyes

6/13/2005 Clariant imported dyes pigments and dyes

5/19/2011 Clariant imported dyes pigments and dyes

7/29/1994 Ciba-Geigy 

Pigments Division CBI pigments and dyes

12/28/1994 Ciba-Geigy 

Pigments Division CBI pigments and dyes

12/29/1994 DIC Trading 3 pigments pigments and dyes

6/22/1995 Ciba-Geigy 

Pigments Division CBI pigments and dyes

7/25/1995 Cappelle 4 pigments pigments and dyes

7/2/1996 Uhlich Color Co CI Pigment Orange 24 pigments and dyes

7/15/1996 Ciba-Geigy 

Pigments Division CBI pigments and dyes

8/16/1996 Engelhard CI Pigment Violet 23 19.6 ppm pigments and dyes

8/23/1996 Cappelle CI Pigment Yellow 170 pigments and dyes

9/27/1996

UMC (United 

Mineral and 

Chem) 

CI Pigment Green 7 pigments and dyes

1/13/1997 Zeneca 7 pigments pigments and dyes

7/29/1996 CDR Pigments 

and Dispersions 6 pigments pigments and dyes

6/18/1997 Fabricolor 12 pigments pigments and dyes

7/1/1997 BASF 13 pigments pigments and dyes

8/18/1997 Ciba Pigments 

Division CBI for several pages pigments and dyes

10/21/1997 Mil International 5 pigments pigments and dyes

1/6/1998 Sun Chem. Corp 4 pigments pigments and dyes

10/26/1997 Mil International 4 pigments pigments and dyes

5/15/1998 Mil International 5 pigments pigments and dyes

7/20/1998 Ciba Pigments 

Division CBI pigments and dyes

10/23/1998 Ciba Pigments 

Division CBI pigments and dyes

2/2/1999 Lansco Colors 7 pigments pigments and dyes

7/15/1999 Ciba Colors CBI pigments and dyes
218

Division 

7/31/1999 Sun Chem. Corp CBI pigments and dyes

2/2/2000 Ciba Colors 

Division CBI pigments and dyes

5/23/2000 Ciba Colors 

Division CBI pigments and dyes

8/31/2000 Ciba Colors 

Divison CBI pigments and dyes

9/8/2000 Avecia 7 pigments pigments and dyes

11/22/2000 Mil International 7 pigments pigments and dyes

12/13/2000 Ciba Colors 

Division CBI pigments and dyes

3/30/2001 Ciba Colors 

Division CBI pigments and dyes

5/4/2001 Magruder Color 

Co 3 pigments pigments and dyes

6/1/2001 Sun Chem. Corp 9 pigments pigments and dyes

7/18/2001 Ciba Colors 

Division CBI pigments and dyes

4/8/1994 PCL Group Copper Phthalocyanine 

Blue pigments and dyes

10/17/2001 Ciba Colors 

Division CBI pigments and dyes

1/25/2002 Ciba Colors 

Division CBI pigments and dyes

3/27/2002 Mil International 8 pigments pigments and dyes

4/29/2002 Ciba Coating 

Effects CBI pigments and dyes

8/6/2002 Ciba Coating 

Effects CBI pigments and dyes

8/28/2002 Sun Chem. Corp CBI pigments and dyes

11/5/2002 Ciba Coating 

Effects CBI pigments and dyes

6/13/2003 Ciba Coating 

Effects CBI pigments and dyes

10/16/2003 Ciba Coating 

Effects CBI pigments and dyes

4/2/2004 Ciba Coating 

Effects CBI pigments and dyes

7/6/2004 Ciba Coating 

Effects CBI pigments and dyes

7/6/2004 Ciba Coating 

Effects CBI pigments and dyes

8/8/2005 Sun Chemical CBI pigments and dyes

5/25/2006 Cappelle CI Pigment Yellow 17 pigments and dyes

1/30/1995 GE Silicones CBI

<2.5 ppm 

discounted, total 

discounted quantity 

<1.1 lbs

silicones

1/30/1996 GE Silicones CBI

<1.1 ppm 

discounted, total 

discounted quantity 

<0.9 lbs

silicones
219

1/24/1997 GE Silicones CBI

<1.5 ppm 

discounted, total 

discounted quantity 

<0.6 lbs

silicones

1/24/1997 GE Silicones CBI

<1.3 ppm 

discounted, total 

discounted quantity 

<0.53 lbs

silicones

2/25/1999 GE Silicones CBI

<1.5 ppm 

discounted, total 

discounted quantity 

<0.8 lbs

silicones

2/7/2000 GE Silicones CBI

<1.7 ppm 

discounted, total 

discounted quantity 

<0.5 lbs

silicones

3/13/2001 GE CBI

<1.9 ppm 

discounted, total 

discounted quantity 

<0.7 lbs

silicones

5/28/2002 GE

CBI, adding hydrolyzed 

phenylchlorosilanes and 

phenylchlorosilanes

total discounted 

quantity < 0.83 lbs silicones

4/30/1997 ABB electrical capacitors 3.9 ppm, 134 liters Unique

6/24/1994 Nagase America 2,4,6-TCPH (2,4,6-

Trichlorophenylhydrazine) 9-12 ppm Unique

11/30/1995 PHT International 2,6-Dichloro-4-Nitro Aniline Unique

3/17/1998 ISK Biosciences CBI, Chlorothalonil 

production Unique

5/15/2001 PPG Industries trichlorobenzene (TCB) Unique

8/17/2012 Future Fuel pesticide intermediate Unique

4/7/1997 Elf Atochem 4 and 5 ppm Unknown

2/18/2000 CBI CBI Unknown

6/13/2001 CBI CBI Unknown

2/4/2003 CBI CBI Unknown

CBI CBI CBI Unknown

5/31/2011 CBI CBI Unknown

9/11/2012 CBI CBI, 220 kg shipment Unknown

8/23/2004 Formosa Plastics up to 215-255 ppm, 

143 lbs vinyl chloride

6/24/1996 Geon

740 lbs PCB/ 

62,676,000 lbs 

chemical 

feedstocks

vinyl chloride

11/13/1997 Dow vinyl chloride
220

Appendix F. Washington PCB transformers in EPA database

We attempted to contact the registrants to find out about the current whereabouts of the registered transformers. While owners of PCB 

transformers (> 500 ppm PCBs) were required to register with the EPA, the EPA is not required to update the database. 

Company City Contact Transformer street address Trans. City 

Trans. 

Zip 

code

No. of 

Trans.

Weight 

(kg)

Current 

whereabouts

Puget Sound Energy Bellevue John Rork Talcott Avenue & Columbia 

Street Olympia 98501 3 7 In use

Puget Sound Energy Bellevue John Rork 14401 278th Avenue NE Duval 98019 2 5 In use

Puget Sound Energy Bellevue Lea Boyle 14401 188th Avenue NE Redmond 98052 2 4.52 In use

Puget Sound Energy Bellevue John Rork S 173rd & 43rd Avenue S Renton 98055 0 0

Puget Sound Energy Bellevue John Rork 2211 Nevada Street Bellingham 98225 0 0

Puget Sound Energy Bellevue John Rork 24810 156th Avenue SE Kent 98025 0 0

Puget Sound Energy Bellevue John Rork Hodgedon & Garfield Streets Tenino 98589 0 0

Puget Sound Energy Bellevue John Rork 70th Street E & Myers Road Bonney Lk 98390 0 0

Puget Sound Energy Bellevue John Rork Dolarway Road Ellensburg 98922 0 0

Puget Sound Energy Bellevue John Rork Jackson & Main Streets Cle Elum 98922 0 0

Puget Sound Energy Bellevue John Rork 19319 Electron Road Orting 98360 0 0

Puget Sound Energy Bellevue John Rork W. side of Stottlemeyer Road Poulsbo 98370 0 0

Puget Sound Energy Bellevue John Rork 40801 268th Avenue SE Enumclaw 98022 0 0

Puget Sound Energy Bellevue John Rork N. Tapps Highway & 

Vandermark Road Auburn 98002 0 0

Puget Sound Energy Bellevue John Rork SE 80th Street & 246 Avenue 

SE Issaquah 98027 0 0

Puget Sound Energy Bellevue John Rork 13635 SE 26th Bellevue 98004 0 0

Puget Sound Energy Bellevue John Rork 3975 E. Highway 525 Langley 98260 0 0

Puget Sound Energy Bellevue John Rork 1274 Thompson Road Anacortes 98221 0 0

Puget Sound Energy Bellevue John Rork 2857 S. 221st Des Moines 98148 0 0

Puget Sound Energy Bellevue John Rork 12251 Mt Baker Highway Glacier 98244 0 0
221

Puget Sound Energy Bellevue John Rork 7537 Portal Way Ferndale 98248 0 0

Puget Sound Energy Bellevue John Rork 13635 NE 80th Redmond 98052 0 0

Puget Sound Energy Bellevue John Rork 9512 Pacific Highway SE Lacey 98503 0 0

Puget Sound Energy Bellevue John Rork 9221 Wilows Road NE Redmond 98502 0 0

Puget Sound Energy Bellevue John Rork 34717 21st Avenue SW Federal Way 98003 0 0

Puget Sound Energy Bellevue John Rork 1035 Stevenson Avenue Enumclaw 98022 0 0

Puget Sound Energy Bellevue John Rork Hanford Road & Centralia 

Steam Plt Centralia 98531 0 0

Puget Sound Energy Bellevue John Rork South of I-90 between Exits 

37 & 38 Snoqualmie 98065 0 0

Puget Sound Energy Bellevue John Rork Corner of Central Valley Road 

& Bucklin Bremerton 98310 0 0

Puget Sound Energy Bellevue John Rork 20th Street E & 169th Avenue 

E (2111) Sumner 98340 0 0

Western Washington 

University Bellingham Gayle Shipley Commissary 781 25th St. Bellingham 98225 0 0

SDS Lumber Co Bingen Ronald Schultz South Side BNSF RR Bingen 98605 2 2138 Unknown

Kimberly-Clark Worldwide Everett Jim Ketchum 2600 Federal Ave. Everett 98201 0 0

Grays Harbor Paper L.P. Hoquiam Richard Johnston 801 23rd St. Hoquiam 98550 5 50932 In use

Reynolds Metals Company Longview H.S. Hays 4029 Industrial Way Longview 98632 0 0

Washington Veneer Omak Joe Atwood 1100 Eighth Ave.E. Omak 98841 7 12412 Unknown

PUD. No. 1 of Clallam Co Port Angeles Quimby Moon 1936 West 18th Street Port Angeles 98362 4 505 Disposed of

City of Port Angeles Port Angeles Mark Shamp 321 E. Fifth Street Port Angeles 98362 1 Disposed of

PUD. No. 1 of Clallam Co Port Angeles Quimby Moon 1936 West 18th Street Port Angeles 98363 1 100 Disposed of

PUD No. 1 of Clallam Co Port Angeles Quimby Moon 1936 West 18th Street Port Angeles 98363 1 68 Disposed of

Port Townsend Paper 

Corporation Port Townsend John M. Recht 100 Mill Hill Rd Port Townsend 98368 0 0

City of Richland Richland Wayne Collop 806 Thayer Drive Richland 99352 2 45 Disposed of

US Dept of Energy 

Richland Oper. Office Richland B.J. Dixon 200 East Area Richland 99352 1 137 Unknown

Energy Northwest Richland J.P. Chasse

HPCS Diesel Generator Rm, 

Nuclear Plant #2, N. Power 

Plant Loop

Blank Blank 0 0

Entercom Communications Seattle Martin Hadfield 910 Lone Oak Road Longview Blank 0 0
222

Corp

Total Reclaim, Inc Seattle Craig Lorch 2200 Sixth Avenue South Seattle 98134 1 215 Disposed of

Seattle City Light Seatle Karen Dinehart Laurelhurst Lane and 51st Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 4502 NE 41st Street Seattle 98124 3 182 Disposed of

Seattle City Light Seattle Karen Dinehart Bellevue Ave E & E. John Seattle 98124 3 160 Disposed of

Seattle City Light Seattle Karen Dinehart 2826 NW Market Street Seattle 98124 2 114 Disposed of

Seattle City Light Seattle Karen Dinehart 7710 35th Avenue, SW Seattle 98124 1 68 Disposed of

Seattle City Light Seattle Karen Dinehart 6730 24th Avenue, NW Seattle 98124 0 0

Seattle City Light Seattle Karen. Dinehart 1414 NW Leary Way Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 7750 28th Ave NW Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 1405 NW 65th Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 8032 15th Avenue NW Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 3209 NW 65th Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 2333 W Boston Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 2100 SW Andover Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 35th Ave SE & SW Genessee Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 5601 23rd Avenue SW Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 1605 SW Holden Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 3405 SW Graham Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 4118 SW Morgan Street Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 9370 52nd Avenue S Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 1stE/Of Earl Ave NW, S/SI 

NW 90th Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 1stN/Of S Holden,E/SI 

Rainier AveS Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 1stS/Of W Bertona,E/SI 21st 

Ave W Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 48th NE & 47th NE Seattle 98124 0 0

Seattle City Light Seattle Karen Dinehart 51st Ave NE & NE 41st Street Seattle 98124 0 0

Inland Power and Light Spokane Todd Hoffman 10110 W. Hallett Road Spokane 99014 1,249.0

0

Avista Utilities Spokane Clarice various locations Blank Blank 157 16,434. Disposed of
223

Robertson 00

Avista Corporation Spokane Clarice 

Robertson Onion Creek Road Colville Blank 0 0

Avista Corporation Spokane Clarice 

Robertson

SE corner of Rockwell and 

Monroe Streets Spokane Blank 0 0

Tacoma Power Tacoma Russell Post 418 Gershick Rd Silver Creek 98585 10 830 Disposed of

Tacoma School District #10 Tacoma Margaret Ohlson 111 North E Street Tacoma 98403 1 358 In use

Tacoma School District #10 Tacoma Margaret Ohlson 2502 North Orchard Tacoma 98406 1 358 In use

Pioneer Americas, 

Inc./Chlor Alkali Co. Inc. Tacoma Karl Iams 605 Alexander Ave. Tacoma 98421 0 0

TransAlta of Calgary Alberta Roger Carter 913 Big Hanaford Rd Centralia 98531 42 34731 Disposed of