PCB recordkeeping and reporting

Polychlorinated biphenyls (PCBs) are a class of organic chemicals that had become widely used in industrial applications due to their practical physical and chemical properties. Historical uses of PCBs include dielectric fluids (used in utility transformers, capacitors, etc.), hydraulic fluids, and other applications requiring stable, fire-retardant materials. Due to findings that PCBs may cause adverse health effects and due to their persistence and accumulation in the environment, the Toxic Substances Control Act (TSCA), enacted on October 11, 1976, banned the manufacture of PCBs after 1978 [Section 6(e)]. The first PCB regulations, promulgated at 40 CFR Part 761, were finalized on February 17, 1978. These PCB regulations include requirements specifying disposal methods and marking (labeling) procedures, and controlling PCB use. To assist the Department of Energy (DOE) in its efforts to comply with the TSCA statute and implementing regulations, the Office of Environmental Guidance has prepared the document ``Guidance on the Management of Polychlorinated Biphenyls (PCBs).`` That document explains the requirements specified in the statute and regulations for managing PCBs including PCB use, storage, transport, and disposal. All generators, disposers, and storers of PCB waste must comply with the recordkeeping and reporting requirements found at 40 CFR 761.180. The regulations include directions for writing and maintaining annual records and annual document logs and for preparing annual reports, exception reports, manifest discrepancy reports, and unmanifested waste reports. This Information Brief supplements the PCB guidance document by responding to common questions concerning recordkeeping and reporting requirements for PCBs. It is one of a series of Information Briefs pertinent to PCB management issues