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 The interpretation presented in a given letter may have been partially superceded by subsequent rulemakings. However, letters that have been entirely superceded are not listed.
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Response to Westcott about PCBs in X-Ray Equipment (PDF)(2 pp, 466 K,
11/08/1984)
Overview of PCB regulations for electrical equipment, particularly X-Ray machines.
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Response to East Kentucky Power Company about Classification as a Marketer or Incinerator of Used Oil (PDF)(2 pp, 94 K,
03/04/1998)
Proper Classification for Utilities that Incinerate Oil which Contains Less than 50 ppm PCBs
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Response to Howrey about In-Transit Shipment of PCBs from Mexico to France (PDF)(5 pp, 285 K,
03/04/1998)
Status of PCB Waste Shipments which Transit Through United States Territory
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Response to ISK Biosciences Corp about Interpretation of PCB Regulations for Excluded Manufacturing Processes (PDF)(7 pp, 156 K,
03/05/1998)
Management of Wastes and Products Derived from an "Excluded Manufacturing Process"
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Response to Public Service Company of Oklahoma about Clarification of Recordkeeping Requirements for Annual Document Logs (PDF)(7 pp, 130 K,
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
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Response to ADI Technology Corp about Application of Cutting Torch to PCBs Regulated for Disposal (PDF)(3 pp, 131 K,
08/12/1998)
Use of a cutting torch on surfaces containing regulated PCBs constitutes thermal destruction and must be approved.
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Response to EPS about Individual PCB Testing of All Mineral Oil Filled Distribution Transformers and Manifesting Under the New PCB Disposal Amendments (PDF)(12 pp, 538 K,
09/18/1998)
Applying the PCB concentration assumption to mineral oil filled distribution transformers for disposal purposes under the new PCB disposal amendments
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Response to Stinson, Mag & Fizzel about Drained PCB-Contaminated Electrical Equipment and Threshold Counting (PDF)(3 pp, 76 K,
09/29/1998)
Clarification of the volume limit for commercial storers with drained PCB-Contaminated Electrical Equipment
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Response to Reynolds Metal Company about Technical Corrections on Contaminated Porous Surfaces and Dermal Protection; Clarification on Decontamination and Definition of Disposer (PDF)(6 pp, 187 K,
10/30/1998)
Clarification of the applicability of 761.30(p) for authorized use of contaminated porous surfaces and dermal protection; Clarification whether decontaming PCB waste makes one a disposer
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Response to Transformer Disposal Specialists about Regulation of Drained PCB-Contaminated Transformers (PDF)(3 pp, 111 K,
10/30/1998)
Clarification of how drained PCB-contaminated transformers are regulated and sampling requirements for scrap metal recovery ovens
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Response to SD Myers about Scrap Metal Recovery Oven and Room Temperature Requirement (PDF)(2 pp, 85 K,
11/12/1998)
Response to SD Myers about scrap metal recovery oven and room temperature requirement
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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)(5 pp, 161 K,
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.
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Response to EPS about Utility Companies Disposing of PCB Contaminated Electrical Equipment and Non-PCB Electrical Equipment (PDF)(7 pp, 243 K,
12/21/1998)
Response to questions about utility companies disposing of PCB cotaminated electrical equipment and non-PCB electrical equipment.
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Response to Full Circle Inc about Recycling Fluorescent Light Ballasts Containing PCBs (PDF)(3 pp, 135 K,
01/04/1999)
Response to questions about testing and storage of fluorescent light ballasts containing PCBs
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Response to Hale and Dorr about Use Authorization and Abandonment and Disposal Provisions for Natural Gas Pipeline Systems (PDF)(20 pp, 718 K,
02/01/1999)
Reponse to the American Gas Association regarding the use authorization, characterizaiton, abandonment, and disposal provisions for natural gas pipeline systems
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Response to Blank, Rome, Comsky & McCauley about Clarification of Porous Concrete Surfaces and PCB Remediation Waste, and PCB Liquids (PDF)(3 pp, 127 K,
03/24/1999)
Clarification technical correction for use of porous surfaces and use of absorbents for PCB liquids
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Response to Institute for Scrap Recycling Industry about PCB Bulk Product Waste from the Shredding of Automobiles or Household Appliances (PDF)(3 pp, 102 K,
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)
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Response to EPS about Use of Mineral Oil Dielectric Fluid as a Performance-Based Organic Decontamination Fluid (PODF) (PDF)(3 pp, 78 K,
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.
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Response to Linda Wilson about Sampling and Characterization of PCB Remediation Waste in Self-Implementing Cleanups (PDF)(5 pp, 155 K,
04/12/1999)
Clarification of the sampling and characterization requirements for PCB remediation waste in self-implementing cleanups
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Response to Dow Chemical Company about Epoxy Coated Concrete as a Non-Porous Surface (PDF)(14 pp, 788 K,
07/14/1999)
Response to Dow Chemical to help determine whether a painted surface meets the definition of nonporous surface.
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Response to Argonne National Laboratory about PCB Bulk Product Waste, Approval for Re-Use in Commerce, and R&D Use for PCBs (PDF)(13 pp, 629 K,
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.
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Response to Institute for Scrap Recycling Industry about Decontamination of Shredder Residue and Beneficial Reuse (PDF)(3 pp, 95 K,
07/28/1999)
Response to ISRI regarding the decontamination of automotive shredder residue and beneficial reuse
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Response to McClintock, Weston, Benshoof, Rochefort, Rubalcava & Maccuish about "As-Found" Concentrations and the Anti-Dilution Rule (PDF)(9 pp, 324 K,
08/13/1999)
Clarification on "as-found" concentrations, dilution of PCB remediation waste, and use of the Spill Cleanup Policy
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Response to University of Detroit Mercy about Recycling of Auto Shredder Residue Contaminated with PCBs (PDF)(2 pp, 117 K,
09/29/1999)
This letter responds to questions about how auto shredder residue can be managed under the PCB regulations.
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Response to Bond, Schnoeneck & King about Application of the PCB Disposal Amendments when the As-Found Concentration is Less Than 50 ppm (PDF)(2 pp, 52 K,
11/17/1999)
Description of anticipated technical correction to clarify that less than 50 ppm PCB remediation wastes can be regulated for disposal.
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Response to Idaho Power Company Clarifying the PCB Questions and Answers Manual for PCB Electrical Equipment (PDF)(3 pp, 109 K,
02/16/2000)
Response to Idaho Power Company regarding the use, storage, and disposal of PCB Electrical Equipment.
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Response to Institute for Scrap Recycling Industry about Recycling of Auto Shredder Residue Contaminated with PCBs (PDF)(3 pp, 366 K,
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.