PCB Cleanup and Disposal Guidance in Interpretive Letters Issued by EPA

This page contains copies of interpretive letters issued by EPA that contain guidance. While these letters were each directed to a particular party in response to a specific request for interpretation, the responses are broadly applicable to the regulated public. The interpretation presented in a given letter may have been partially superceded by subsequent rulemakings. However, letters that have been entirely superceded are not listed.

• Response to Westcott about PCBs in X-Ray Equipment (pdf) (455.34 KB, 11/08/1984)
  Overview of PCB regulations for electrical equipment, particularly X-Ray machines.
• Response to East Kentucky Power Company about Classification as a Marketer or Incinerator of Used Oil (pdf) (92.19 KB, 03/04/1998)
  Proper Classification for Utilities that Incinerate Oil which Contains Less than 50 ppm PCBs
• Response to Howrey about In-Transit Shipment of PCBs from Mexico to France (pdf) (278.8 KB, 03/04/1998)
  Status of PCB Waste Shipments which Transit Through United States Territory
• Response to ISK Biosciences Corp about Interpretation of PCB Regulations for Excluded Manufacturing Processes (pdf) (152.76 KB, 03/05/1998)
  Management of Wastes and Products Derived from an "Excluded Manufacturing Process"
• Response to Public Service Company of Oklahoma about Clarification of Recordkeeping Requirements for Annual Document Logs (pdf) (126.5 KB, 03/24/1998)
  Clarification of Requirement to Keep a Distinct Annual Document Log (ADL) for Each Electrical Substation that May Contain In-Service PCB Transformers
• Response to ADI Technology Corp about Application of Cutting Torch to PCBs Regulated for Disposal (pdf) (128.09 KB, 08/12/1998)
  Use of a cutting torch on surfaces containing regulated PCBs constitutes thermal destruction and must be approved.
• Response to EPS about Individual PCB Testing of All Mineral Oil Filled Distribution Transformers and Manifesting Under the New PCB Disposal Amendments (pdf) (525.77 KB, 09/18/1998)
  Applying the PCB concentration assumption to mineral oil filled distribution transformers for disposal purposes under the new PCB disposal amendments
• Response to Stinson, Mag & Fizzel about Drained PCB-Contaminated Electrical Equipment and Threshold Counting (pdf) (74.07 KB, 09/29/1998)
  Clarification of the volume limit for commercial storers with drained PCB-Contaminated Electrical Equipment
• Response to Reynolds Metal Company about Technical Corrections on Contaminated Porous Surfaces and Dermal Protection; Clarification on Decontamination and Definition of Disposer (pdf) (182.65 KB, 10/30/1998)
  Clarification of the applicability of 761.30(p) for authorized use of contaminated porous surfaces and dermal protection; Clarification whether decontaminating PCB waste makes one a disposer
• Response to Transformer Disposal Specialists about Regulation of Drained PCB-Contaminated Transformers (pdf) (108.37 KB, 10/30/1998)
  Clarification of how drained PCB-contaminated transformers are regulated and sampling requirements for scrap metal recovery ovens
• Response to SD Myers about Scrap Metal Recovery Oven and Room Temperature Requirement (pdf) (82.7 KB, 11/12/1998)
  Response to SD Myers about scrap metal recovery oven and room temperature requirement
• Response to Safety-Kleen about Relationship Between a Generator and Commercial Storage Facility of PCB Waste and the One Year Storage for Disposal Requirement (pdf) (157.25 KB, 12/03/1998)
  Description of the enforcement policy to split liability for failure to dispose of PCB waste in 1 year time frame between the generator and the commercial storage or disposal facility.
• Response to EPS about Utility Companies Disposing of PCB Contaminated Electrical Equipment and Non-PCB Electrical Equipment (pdf) (237.66 KB, 12/21/1998)
  Response to questions about utility companies disposing of PCB contaminated electrical equipment and non-PCB electrical equipment.
• Response to Full Circle Inc about Recycling Fluorescent Light Ballasts Containing PCBs (pdf) (131.63 KB, 01/04/1999)
  Response to questions about testing and storage of fluorescent light ballasts containing PCBs
• Response to Hale and Dorr about Use Authorization and Abandonment and Disposal Provisions for Natural Gas Pipeline Systems (pdf) (701.6 KB, 02/01/1999)
  Response to the American Gas Association regarding the use authorization, characterization, abandonment, and disposal provisions for natural gas pipeline systems
• Response to Blank, Rome, Comsky & McCauley about Clarification of Porous Concrete Surfaces and PCB Remediation Waste, and PCB Liquids (pdf) (123.7 KB, 03/24/1999)
  Clarification technical correction for use of porous surfaces and use of absorbents for PCB liquids
• Response to Institute for Scrap Recycling Industry about PCB Bulk Product Waste from the Shredding of Automobiles or Household Appliances (pdf) (99.23 KB, 03/24/1999)
  Response to ISRI regarding the options for disposal of PCB Bulk Product Waste from the shredding of automobiles or household appliances (shredder fluff)
• Response to EPS about Use of Mineral Oil Dielectric Fluid as a Performance-Based Organic Decontamination Fluid (PODF) (pdf) (76.39 KB, 04/12/1999)
  EPA approves of the use of mineral oil dielectric fluid as a performance-based organic decontamination fluid (PODF) due to its similarity to diesel fuel.
• Response to Linda Wilson about Sampling and Characterization of PCB Remediation Waste in Self-Implementing Cleanups (pdf) (150.97 KB, 04/12/1999)
  Clarification of the sampling and characterization requirements for PCB remediation waste in self-implementing cleanups
• Response to Dow Chemical Company about Epoxy Coated Concrete as a Non-Porous Surface (pdf) (769.42 KB, 07/14/1999)
  Response to Dow Chemical to help determine whether a painted surface meets the definition of nonporous surface.
• Response to Argonne National Laboratory about PCB Bulk Product Waste, Approval for Re-Use in Commerce, and R&D Use for PCBs (pdf) (614.28 KB, 07/28/1999)
  Reponse to Argonne National Laboratory about PCB Bulk Product Waste, Approval for Re-Use in Commerce, and R&D Use for PCBs when managing shredder residue.
• Response to Institute for Scrap Recycling Industry about Decontamination of Shredder Residue and Beneficial Reuse (pdf) (92.53 KB, 07/28/1999)
  Response to ISRI regarding the decontamination of automotive shredder residue and beneficial reuse
• Response to McClintock, Weston, Benshoof, Rochefort, Rubalcava & Maccuish about "As-Found" Concentrations and the Anti-Dilution Rule (pdf) (316.88 KB, 08/13/1999)
  Clarification on "as-found" concentrations, dilution of PCB remediation waste, and use of the Spill Cleanup Policy
• Response to University of Detroit Mercy about Recycling of Auto Shredder Residue Contaminated with PCBs (pdf) (114.3 KB, 09/29/1999)
  This letter responds to questions about how auto shredder residue can be managed under the PCB regulations.
• Response to Bond, Schnoeneck & King about Application of the PCB Disposal Amendments when the As-Found Concentration is Less Than 50 ppm (pdf) (50.95 KB, 11/17/1999)
  Description of anticipated technical correction to clarify that less than 50 ppm PCB remediation wastes can be regulated for disposal.
• Response to Idaho Power Company Clarifying the PCB Questions and Answers Manual for PCB Electrical Equipment (pdf) (106.65 KB, 02/16/2000)
  Response to Idaho Power Company regarding the use, storage, and disposal of PCB Electrical Equipment.
• Response to Institute for Scrap Recycling Industry about Recycling of Auto Shredder Residue Contaminated with PCBs (pdf) (357.51 KB, 04/04/2011)
  This letter describes how the PCB regulations apply to the use of auto shredder residue contaminated with PCBs in recycling for consumer products.