The PCBs (polychlorinated biphenyls) and PCTs (polychlorinated terphenyls) are organic polychlorinated compounds that are characterised by high resistance to fire, low electrical conductivity, low volatility and an extreme physicochemical stability. In 1929, PCBs and PCTs were first produced on an industrial scale and applied everywhere, and especially from the 50s and up to the end of the 70s they were used as a refrigerant in electrical equipment such as transformers, condensers, resistances, cutters, equipment with thermoconductor fluids, etc.

From the regulatory point of view, PCBs/PCTs are considered to be the polychlorinated biphenyls, polychlorinated terphenyls, monomethyltetrachlorodiphenylmethane, monomethyldichlorodiphenylmethane, monomethyldibromoodiphenylmethane, as well as mixes that present a concentration of the above substances that together are more than 50 ppm by weight.

The technological advantages of PCBs and PCTs become harmful when considered from the environmental and health point of view. Their high chemical stability means that they are not easily biodegradable. Once released into the environment, they persist for many years and accumulate in living organisms. At the same time they also penetrate into the animal and human body through the skin, the lungs and the intestinal tract; in the last case mainly because of the ingestion of animal and vegetable tissues, especially fats, that have accumulated these compounds.

As a consequence of shortcomings in waste management in the past, nowadays PCBs are found in all environments and are magnified in food chains because of their low biodegradability and the tendency to accumulate in fatty tissues.

What is more, they can travel long distances through the air to accumulate in cold regions where they have never even been used. Particularly high concentrations of PCBs are found in the fatty tissues of seals and polar bears.

Because of their persistence in the environment, their bioaccumulation, their potential for travelling long distances and migration and their harmful effects for the environment and health, PCBs are considered Persistent Organic Pollutants (POPs). For this reason, since May 2001 they have been an object of the Stockholm Convention on Persistent Organic Pollutants.

Studies of two incidents of poisoning caused by the consumption of food contaminated with PCBs provided fundamental results on the long-term effects of PCBs in organisms (“Yusho”, Japan, 1968 and “Yu Cheng”, Taiwan, 1979).

Apart from the chronic toxic effects such as severe urticaria (chloracne), hair loss and hyperpigmentation, PCBs are now considered to be responsible for foetal malformations, as well as feminisation of male animals, which leads to a decrease in fertility and the subsequent decrease in the affected populations. Some PCBs are suspected of causing cancer.

Decontamination is the set of operations that make possible the reuse or management of items or products that contain PCBs/PCTs in secure conditions. These operations include the replacement of PCBs/PCTs by fluids that do not contain them, with the intention that the items should not present the danger inherent in the presence of PCBs/PCTs and are not subject to the relevant regulations.

The conditions to be met for the decontamination of items are the following:

• The results of the decontamination must be the reduction of the PCB/PCT content to 50 ppm.
• The decontamination must be accredited by means of a double analysis: one analysis of PCB content immediately after the treatment and another one year after this operation. Both analyses must be carried out in accordance with the regulations (see specific conditions of analysisi)and their results must be below 50 ppm..
• The replacement fluid must not contain PCBs/PCTs or represent a danger for the environment, or, in any case, it will be less than that of PCBs/PCTs.
• • The replacement must be done in such a way that it does not represent an obstacle for the later disposal of PCBs/PCTs.
• • The labelling of transformers subjected to inventory must be changed after the decontamination, in accordance with the provisions set out below (see obligations of the owner)

The regulation of the disposal of PCBs originates mainly from the community field, with the publication of Council Directive 96/59/EC of 16 September on the disposal of polychlorinated biphenyls and the polychlorinated terphenyls (PCBs/PCTs).

This regulation establishes, principally, the obligation for items with PCBs to be decontaminated or disposed of in general before 1 January 2011, with the exception of weakly contaminated transformers, and for items subjected to inventory and the premises where they are located to be labelled. It also provides for inventories to be carried out of items that are modernised periodically.

The Directive also establishes that the member states are to draw up a plan for the decontamination and disposal of items subjected to inventory and of the PCBs that they contain.This plan was published by Spain in 2001 by means of resolution..

Directive 96/59/EC was applied to Spain by means of Royal Decree 1378/1999, of 27 August, establishing measures for the disposal and management of the polychlorobiphenyls, polychloroterphenyls and items that contain them, amended by Royal Decree 228/2006, of 24 February

These regulations specify the requirements of the European legislation, set out the obligations of everyone involved in management and regulate the conditions for maintaining the inventory of items with PCBs.

The regulation affects items that contain or have contained PCBs, such as electrical transformers, resistances, inductors, electrical condensers, cutters, equipment with thermoconductor fluids, underground equipment in mines with hydraulic fluids and containers with residual quantities, provided that they have not been decontaminated below 50 ppm. An item is considered to contain PCBs if it has been manufactured with it or if its use or maintenance could have contaminated it, unless it is possible to prove the opposite.

The basic typologies of items are:

• Items manufactured with PCB fluids: items that have been manufactured with fluids consisting of PCBs.
• Items contaminated with PCBs: items that, though not manufactured with PCBs, have been contaminated with it later.
• Items that might contain PCBs: items that are suspected to contain PCBs, unless their history or an analysis of the fluid proves that they are not contaminated.

If there is no information about an item of those defined in the first paragraph, this item must be included in the third of these categories.

Compliance with the regulations leads to the following obligations for owners of items:

• To eliminate or decontaminate transformers with a PCB content of more than 500 ppm and other items with PCB content of equal to or greater than 50 ppm that have a volume of fluid greater than 1 dm3, in accordance with the specific restrictions for disposal or decontamination.
• To analyse the PCB content of items that might contain PCBs, in accordance with the specific conditions for analysis.
• To make an annual declaration of the entirety of items subject to inventory, including those that have been decontaminated and/or disposed of in previous years, which must include the complementary documentation relating to the taking of samples, visual inspection, disposal and decontamination of the items.
• Labelling all the items subject to inventory and, if they have a volume of fluid greater than 5 dm3, signing the premises where they are located (see model of label for items subject to inventory).
• Labelling the decontaminated items in accordance with preset minimum contents (see model of label for decontaminated items).

Under the regulations, the items must be decontaminated or disposed of at the end of their useful life. However, there is a general deadline for the disposal or decontamination of the following items set at 1 January 2011. The items to be disposed of or decontaminated before that date are:

• All items and their contents, except for transformers, that have a volume of PCBs greater than 1 dm3 and a concentration greater than or equal to 50 ppm by weight.
• All transformers and their contents that have a volume of PCBs greater than 1 dm3 and a concentration greater than 500 ppm by weight.

Additionally, the decontamination or disposal must be carried out under a schedule or in determined percentages, with the aim of avoiding collapse of the treatment installations for these items. The restrictions in this regard are:

• Items manufactured with PCB fluids. Their owners must eliminate them in accordance with the following schedule:
  
  

  Date of manufacture of the item	Unknown or before 1965	Between 1965 and 1969	Between 1970 and 1974	Between 1975 and 1980	later than 1980
  Date disposal/decontamination	Before 1/1/2007	Before 1/1/2008	Before 1/1/2009	Before 1/1/2010	Before 1/1/2011

  
  
• Items contaminated with PCBs. Their owners must eliminate or decontaminate them in the following percentages (referring to the total weight of contaminated items that they own at the beginning of each year) and dates:
  
  

  Year disposal/decontamination	2006	2007	2008	2009	2010
  Percentage to eliminate	20%	25%	33%	50%	100%

  
  
Owners who have fewer than 6 items can decontaminate or eliminate one item per year provided that the last is disposed of before 2011.

On the other hand owners of items with PCBs or that might contain PCBs, must give priority in the order of decontamination or disposal to those items that are especially dangerous, either because of their high PCB content in or their location, or any other circumstance that implies an increased risk for persons or the environment. Items with fluid leaks must be disposed of or decontaminated as soon as possible, from the time when the leaks are detected.

Owners of PCBs, used PCBs and items with PCB must deliver them to an authorised waste manager for their decontamination or disposal.

Of all items with PCBs, it is the items that might contain PCBs that present uncertainty about their composition, as they are the ones about which there is a reasonable suspicion that they might contain it, unless their history or their analysis proves the opposite.

The owners of those items must analyse their PCB content by the following dates and percentages (referring to the total weight of such items that they own at the beginning of each year):

Owners who have fewer than 4 items can analyse one item per year provided that the last is disposed of before 2009.

The taking of samples for PCB analysis must be done by bodies that work with the public authorities in environmental matters. These are the Environmental Control Bodies accredited for energy, industrial and waste management. In the case of power stations, substations and transformation centres, this sample can be taken by the official electrical regulation bodies.

Once taken the samples must be analysed by laboratories accredited by the National Accreditation Board (ENAC) for the analysis of PCBs, and these analyses must be performed in accordance with the method described by regulation UNE-IN 61619. For guidance purposes, a list of laboratories accredited by the ’Agència de Residus de Catalunya, as all of them have accreditation for PCB analysis.

The items that have to be included in the inventory are summarised in the following table:

These conditions mean that some of the items that have undergone maintenance operations could be contaminated, even in cases where these operations have been done in items that did not originally contain PCBs/PCTs. The owners of the items are not always aware of this fact, so that it is necessary to inventory items that have been handled up to the time when it can be shown that no contamination has been produced. The most effective way of proving whether the item is free of PCBs/PCTs is by doing an analysis.

It is not necessary to declare items that do not have PCBs/PCTs.

However, items that might contain PCBs/PCTs must be declared. That means items where there is a reasonable suspicion that their PCB content is greater than 50 ppm. The safest way to check this is to analyse the PCB content in the insulator.

It must be emphasised that in no case do items that are not subject to inventory have to be declared in accordance with the regulation (see question 10). Some particular cases in which items do not have to be declared are:

• Items that do not have insulating fluid (dry type or similar).
• Items that have insulators that are not compatible with the presence of PCBs/PCTs.
• Items that have an analysis of the PCB/PCT content of the insulator in which the result is below 50 ppm.

Reial Royal Decree 228/2006, of 24 February establishes the obligation for owners to make a declaration of all the items subject to inventory.

The declaration is ANNUAL and includes the information set out in the annex to Royal Decree 228/2006. Additionally, the declaration must have attached to it the documents that justify events during the year of the declaration, and in particular:

• Follow-up documentation of the disposed of items
• Certificates of disposal or destruction of the disposed of items
• Certificates of decontamination of the decontaminated items
• Certificates of reduction of PCBs for the items that have undergone this process
• Minutes or certificates of sampling and the reports of analytical results
• Minutes or certificates of visual inspection

The declaration for one year must be presented during the first two months of the following year. Therefore, the first one must be presented between 1 January and 28 February 2007.

The declaration must be made officially in a public register, with the original signature of the declarer.

Not confirming the presence of PCBs/PCTs in items could mean:

• Ignorance of the presence of a significant pollutant, especially with regard to the employment and accident risks that it could involve
• Not declaring items that appear not to contain PCBs/PCTs but could really contain them, for example by external contamination.
• The possible missing of the legal deadlines for the destruction of items, which would represent an offence.

• The impossibility of proving compliance with the regulations at an inspection by the relevant safety and other bodies. (Catalan Police, the Guardia Civil or environmental inspectors).
• A possible infringement in a certification process of an environmental management system.

The regulation sets out a series of restrictions and conditions for the maintenance and handling of items with PCBs/PCTs. The following should be mentioned:

• Maintenance can only be carried out so that the fluid maintains its properties or its technical specifications, and provided that the items are not leaking and are in good condition.
• Refilling of items to restore insulating fluid levels must not be done with PCBs/PCTs.
• PCBs/PCTs must not be handled or stored together with explosives, flammable substances, oxidising or corrosive agents or food products.
• In all cases, the handling areas must be isolated from the ground and must have systems for clean up of leaks.