Are there any other locations that
require marking?
There are two other locations, not mentioned in
40 CFR Part 761 Subpart C, that require marking.
First, is the marking of, or over, an encapsulated
area or at a barrier to a porous surface that was contaminated
with 50 ppm of liquid PCBs and cleaned
up in accordance with 40 CFR Part 761.30(p). Second,
is the marking of fenced PCB remediation
waste sites cleaned up to > 25 ppm and 50 ppm of
PCBs in accordance with 40 CFR Part
761.61(a)(4)(I)(B).
What are the marking requirements for
vehicles transporting PCBs?
Vehicles transporting either (1) > 45 kg (99.4 lbs) of
liquid PCBs with a concentration 50 ppm of PCBs
or (2) one or more PCB Transformers must be
marked on each end and each side of the vehicle.
What is the significance of EPA adding
40 CFR Part 761.40(k)(2) about marking
PCB Transformers and PCB Large (Low
or High Voltage) Capacitors?
40 CFR Part 761.40(k)(2) requires marking of all
equipment containing a PCB Transformer or PCB
Large (Low or High Voltage) Capacitor that was not
marked at the time of manufacture, distribution in
commerce, or removal from use. This means that if
the mark falls off or otherwise disappears from a
PCB Transformer or PCB Large (Low or High Voltage)
Capacitor while in use, the owner/operator is
responsible for making sure the equipment is remarked.
Prior to this amendment, the responsibility
for marking had been put solely on the manufacturer
or retailer, and no responsibility for maintaining the
mark had been placed on the owner/operator of the
equipment.
Are there any other labeling requirements?
Yes. In addition to applying the PCB mark to the required
PCB and PCB Items, PCB wastes being
stored prior to disposal must also be labeled with a
notation indicating the date that the item was removed
from service for disposal. If the wastes in
storage include drums of PCB-contaminated soil
from a remediation activity, the “date removed from
service for disposal” would be the date on which the
soil was excavated and placed into drums. If the
wastes are liquid wastes (e.g., solvents used for
flushing or decontaminating PCB Items), the “date
removed from service for disposal” is defined as the
date that the first batch went into the drum. If PCBs
in containers or PCB Items are contaminated with
hazardous wastes regulated under the authority of
the Resource Conservation and Recovery Act
(RCRA), they must be marked in accordance with
the applicable RCRA hazardous waste marking requirements,
as defined in 40 CFR Part 262, as well
as with the applicable TSCA marking requirements. |
