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NORA Considering Five Proposals for PCB/TSCA Reform Effort
Here are the five proposals NORA is considering and why NORA members should support our TSCA amendment effort. 

Note: These proposals are based on the precondition that NORA members will follow best management practices for collecting, testing, and managing used oil.
  • NORA is proposing that the relevant concentration for deciding how to manage PCBs is the level when they are discovered by the collector/recycler – not the original level at the generator.  This would make it much easier for NORA members to know what rules apply when they have an incident.  Existing regulations say that the original PCB concentration (before any mixing/dilution) determines how the material is regulated, but this is often difficult or impossible to determine.

  • NORA is proposing that used oil which is discovered by the collector/recycler at a concentration of 50 ppm of PCBs or less can be managed like normal used oil.

  • NORA is proposing that used oil with more than 50 ppm of PCBs will be easier and cheaper to manage, because we are suggesting that EPA give permission for other outlets including high efficiency boilers and hydrotreating re-refiners.

  • NORA is proposing that the unintentional dilution of PCBs by a collector/recycler is not a violation or a crime, and EPA would not be able to assess penalties or fines against the collector or recycler for this.

  • NORA is proposing to exempt oil recyclers who follow best management practices from EPA fines or other penalties that are often imposed when the generator has certified that the used oil does not have any PCBs.  Such fines have been imposed simply because the PCB-contaminated used oil is being transported from the generator's facility to the processing facility -- even though the oil will be tested for PCBs before being processed. NORA's amendment would abolish these punitive and draconian "enforcement" actions and penalties.
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11/11/2020 » 11/14/2020
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