Introduction to PCB management at UW
Polychlorinated biphenyls (PCBs) are very toxic and persistent in the environment. Before their manufacture was banned in 1979, PCBs were used widely in electrical equipment, including transformers. Many transformers still contain traces of PCB-contaminated oil even after the oil has been changed several times.
Numerous mechanical rooms and electrical vaults on campus house transformers and other PCB-containing equipment such as capacitors and switches. Most of this equipment was installed well before the PCB ban. The Washington State Department of Ecology (Ecology) and the Environmental Protection Agency (EPA) require that all these items, along with PCB-contaminated soil and surfaces, be managed carefully. The EPA regulates wastes containing 50 (parts per million) ppm PCBs and greater. Ecology regulates wastes containing from 2 to 50 ppm PCBs. Both agencies have extensive requirements for management and disposal of PCB wastes. University of Washington administrative policy further restricts the transporters and end point disposal facilities used for PCB wastes.
Facility Services manages all high voltage electrical equipment on the UW Seattle campus. EH&S oversees PCB management, coordinating sampling and disposal, conducting audits, reviewing work plans, and ensuring compliance with the regulations.
It should be assumed that any oil-filled electrical equipment (transformer or other electrical equipment) that ever contained PCBs will be regulated.
Oil-filled electrical equipment with PCB contamination must disposed of and replaced as part of all capital improvement projects that involve electrical upgrades. PCB concentrations must be determined in all oil-filled electrical equipment designated for disposal. If you have any questions, please call 206.616.5837.
The information on this page is also available in the EH&S Design Guides.
Transformer Vault Labeling
There are many mechanical rooms and electrical vaults at the University that contain older oil-filled transformers.
A significant number of these transformers have PCB-contaminated oil. There is no surface contamination, but there are still many regulatory requirements such as signage, inspections, and maintenance for these units. These locations are typically referred to as "Non-Restricted Access Areas." EH&S conducts inspections of these vaults annually to ensure compliance.
There are several mechanical rooms at the University where historical PCB floor and wall contamination has been encapsulated in place. EPA regulations require that encapsulated surfaces be marked with the yellow "Caution Contains PCBs" sticker typically used for labeling PCB Transformers (>500 ppm). There are also signs posted inside these mechanical rooms that warn against disturbing encapsulated surfaces without first contacting Environmental Health and Safety. These vaults are also inspected annually.
For any construction activity at these locations, review the existing analytical data and plan on obtaining an environmental contractor for guidance.
The following rooms at the University have PCB contamination encapsulated in place:
There is not a prohibition against drilling into encapsulated surfaces, but the work plan must show that proper precautions will prevent personnel exposure and further environmental contamination. If drilling or other activity will disturb an encapsulated surface, a work plan must be submitted for review and comment to EH&S prior to the start of work. The plan may be faxed to 206.685.2915. For further assistance, contact EH&S at 206.616.5837.
There are currently no electrical vaults with floors that have readily exposed PCB contamination. Locations previously classified as "restricted vaults" have been cleaned up.
Active inventories are kept of each transformer indicating its general specifications along with the volume of oil, PCB concentrations, and regulatory status.
"Retrofilling" is the draining of PCB-contaminated oil from transformers and the replacement with new, non-PCB containing oil. The PCB-contaminated oil is disposed of properly through EH&S. The standard practice of removing PCB contaminated oil from a unit and replacing it with non-PCB dielectric oil has greatly reduced the exposure potential of PCBs in older transformers on campus.
Retrofilling requires subsequent sampling on a semi-annual basis. This sampling confirms the level of PCB contamination and the status of each transformer. Sampling also helps prioritize replacement of older transformers. Depending on the level of contamination as well as maintenance issues, some transformers must be sampled and inspected quarterly or even weekly.
A key component of the PCB management program is to ensure that once an oil-filled transformer has reached its life expectancy that it is removed from service and replaced with non-PCB containing equipment. All PCB contamination is removed and PCB wastes are managed correctly. Higher priority is given to units with high levels of PCBs and other maintenance issues. The Capital Projects Office along with Facility Services has incorporated these priorities into the recent significant utility upgrades on the Seattle campus.
Other types of older oil-filled electrical equipment must be removed and/or replaced whenever feasible and disposed of properly through EH&S.
Remodels, laboratory moves, and standard maintenance and alterations work all require that equipment suspected or known to contain PCBs be inspected and screened for PCB contamination. Examples of items include old x-ray machines and other large older laboratory equipment that contain power sources, power generators and capacitors (pictured at right), as well as fluorescent light ballasts (see below).
Fluorescent lighting ballasts may contain PCBs and must be disposed in accordance with state and federal regulations. All ballasts manufactured through 1978 contain PCBs. Also, some ballasts manufactured after 1978 contain PCBs or the carcinogenic chemical DEHP. For these reasons, all fluorescent lighting ballasts which are not specifically labeled "No PCBs" must be suspected to contain PCBs.
Facilities Services (and the Capital Projects Office for larger projects) remove and replace all fluorescent lights and ballasts on campus. Fluorescent lighting ballasts with known or suspected PCBs or DEHP must be recycled through EH&S. They must be placed in the labeled drum outside the EH&S Environmental Safety Storage Building, which is open from 8 am to 5 pm (see picture at right.) For small amounts of light ballasts, fill out and send to us via fax or campus mail a Chemical Collection Request.
Any leaking PCB ballast is considered an occupation exposure hazard by skin contact. If you have a leaking ballast, wear gloves while handling it and other contaminated materials, and place all materials in a sturdy container that will not leak and dispose of it as hazardous waste. Or, if the contamination is extensive, call the EH&S spills advice line at 206.543.0467. Leaking ballasts must be sent to a permitted incinerator for disposal and may not be sent for recycling. EH&S will coordinate their proper management and disposal.
PCBs in Window Caulk
PCBs were added to some caulking compounds while the use of PCBs was legal. Therefore,
buildings constructed or renovated between 1950 and the 1980s may have PCBs in the caulk
around windows and in masonry expansion joints. The caulk and expansion joint material in
some schools and other public buildings around the nation have tested positive for PCBs.
The Environmental Protection Agency (EPA) is currently developing new rules that address
the issue of PCBs in caulk. Because of the potentially huge expense of removing PCB
containing caulk from buildings and the lack of understanding about the risks of exposure to
PCBs in caulk, the EPA released guidance including interim procedures for managing PCB
containing caulk in place until funds can be procured for removal and replacement. Until the
new rules are final, EH&S is using the EPA guidance to prioritize action and communicate
risks to building occupants and maintenance staff.
For more information about what EH&S is doing about this issue, see the EH&S focus sheet on PCBs in Caulk.
Records and Reports
EH&S maintains all mandatory PCB regulatory records. All routine work completed with the help of Facility Services is tracked and filed. Projects involving remediation or transformer replacements are managed by the Capital Projects office, with significant coordination from EH&S. EH&S routinely reports to the EPA the progress of the PCB program with status update letters and annual reports.
The EH&S PCB Management Coordinator can be contacted either by phone at 206.616.5837 or via email.