The management of hazardous materials used, waste streams generated, and the handling of PCBs in electrical repair/installation activities for the maintenance of the facility and facility components. Electrical shops service an extensive range of products including computers, fax machines, televisions, and transformers.
Summary of Federal Requirements
Common wastes generated in an Electrical Shop are electronic components such as semiconductors, printed wiring boards, and Cathode Ray Tubes (CRT). Each waste stream must be evaluated to determine if it is hazardous waste.
A variety of batteries are used and disposed of through electrical shops. Some of the common types are: alkaline batteries, mercury batteries, carbon-zinc batteries, lead-acid batteries, lithium batteries, magnesium batteries, nickel-cadmium batteries, silver batteries, and thermal batteries. Before the advent of Universal Waste regulations, many of these batteries were disposed of as hazardous waste. Now, all batteries can be handled as universal waste except spent lead acid batteries that are reclaimed/recycled and batteries that are not hazardous waste.
- The CRT contains lead and improper disposal of CRTs can place lead in the waste stream which represents not only a health hazard, but also the loss of a recyclable natural resource.
- Depending on its constituents waste solder, including the left-over stubs, may be a hazardous waste.
- Depending on the solvents used to clean electrical components, toxic air emissions may be being emitted . This is particularly true if using one of the EPA 17 chemicals.
- Rags and wipes used to clean electronics may have to be disposed of as hazardous waste.
Federal facilities may have PCB-contaminated electrical equipment, including transformers, capacitors, ballasts, circuit breakers, reclosers, voltage regulators, or switches. Determination f PCB contamination can be done through analysis of the oil or a swipe test. Additionally, the regulations provide for certain assumptions that can be made about equipment instead of having to perform testing. Once identified, PCB contaminated electrical equipment must be labeled, inspected, managed to prevent leakage. When maintenance is done, all efforts are to be made to replace the contaminated equipment with PCB-free equipment.
- PCB-Contaminated - a non-liquid material containing PCBs at concentrations >/= 50 ppm but <500 ppm; a liquid material containing PCBs at concentrations >/= 50 ppm but <500 ppm or where insufficient liquid material is available for analysis, a non-porous surface having a surface concentration >10 mg/100 cm2 but <100 mg/100 cm2, measured by a standard wipe test as defined in 40 CFR 761.123 (40 CFR 761.3).
- PCB Concentration Assumptions - the following assumption may be made in relation to PCB concentrations (40 CFR 761.1(b)(2), 761.1(b)(3), and 761.2(a)):
- transformers with < 3 lb (1.36 kg) of fluid, circuit breakers, reclosers, oil-filled cable, and rectifiers whose PCB concentration is not established contain PCBs at <50 ppm
- mineral oil-filled electrical equipment that was manufactured before 2 July 1979, and whose PCB concentration is not established, is PCB-Contaminated Electrical Equipment (i.e., contains >/= 50 PCB, but <500 ppm PCB)
- all pole-top and pad-mounted distribution transformers manufactured before 2 July 1979 are assumed to be mineral-oil filled
- electrical equipment manufactured after 2 July 1979 is non-PCB (i.e., < 50 ppm PCBs). If the date of manufacture of mineral oil-filled electrical equipment is unknown, assume it to be PCB-Contaminated.
- transformers manufactured prior to 2 July 1979, that contain 1.36 kg (3 lb) or more of fluid other than mineral oil, and whose PCB concentration is not established, are PCB Transformers (i.e., >/= 500 ppm). If the date of manufacture and the type of dielectric fluid are unknown, assume the transformer to be a PCB Transformer.
- a capacitor manufactured prior to 2 July 1979, whose PCB concentration is not established contains >/= 500 ppm PCBs
- a capacitor manufactured after 2 July 1979 is non-PCB (i.e., <50 ppm PCBs). If the date of manufacture is unknown, assume the capacitor contains >/= 500 ppm PCBs
- a capacitor marked at the time of manufacture with the statement "No PCBs" in accordance with 40 CFR 761.40(g) is non-PCB
- provisions that apply to PCBs at concentrations of < 50 ppm apply also to contaminated surfaces at PCB concentrations of = 10 micrograms/100 cm210
- provisions that apply to PCBs at concentrations of >/= 50 to <500 ppm apply also to contaminated surfaces at PCB concentrations of >10 micrograms/100 cm2 to <100 micrograms/100 cm211
- provisions that apply to PCBs at concentrations of >/= 500 ppm apply also to contaminated surfaces at PCB concentrations of >/= 100 micrograms/100 cm2.
Unless otherwise noted, PCB concentrations shall be determined on a weight-per-weight basis, or for liquids on a weight-per-volume basis if the density of the liquid is also reported. Unless otherwise provided, PCBs are quantified based on the formulation of PCBs present in the material analyzed.
Owners of transformers containing 500 ppm or greater of PCBs must register their transformer(s) with EPA using Form 7720-12. This form cannot be filled out or submitted online.
Any company or person storing, transporting or disposing of PCBs or conducting PCB research and development must notify the EPA and receive an identification number using Form 7710-53. EPA routinely updates and posts the list of companies or persons storing, transporting, or disposing of PCBs or conducting PCB research.
Summary of State Requirements
States may require additional certification or licensing of removal personnel or firms. State may require additional labeling or additional measures to minimize the release of asbestos fibers.
Laws and Statutes
Clean Air Act
Toxic Substances Control Act
The Resources Conservation and Recovery Act, Subtitles C and D