PCB Record Keeping, Spills and Reporting

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Appendix B
PCB Recordkeeping and Reporting

The polychlorinated biphenyl (PCB) recordkeeping and reporting specifics are presented here as guidance to the Environmental Protection Department (EPD) and the Programs.

Federal regulations require that copies of all PCB records be kept in a central location.

Annual Records

Annual records are required for any facility that uses or stores at least 45 kg (99.4 lb) of PCBs, or one PCB Transformer, or 50 PCB Capacitors. These records include:

bulletAll signed manifests for PCBs generated by the facility during the calendar year (manifests should be legible)
bulletAll exception reports and one-year exception reports
bulletAll Certificates of Disposal received by the facility during the calendar year.

The annual records must be retained for at least three years after the facility drops below the required reporting quantities.

Annual Document Log

An annual document log is required for any facility that uses or stores at least 45 kg (99.4 lb) of PCBs, or one PCB Transformer, or 50 PCB Capacitors. The document log includes:

bulletThe calendar year covered by the log; and the name, address, and the U. S. Environmental Protection Agency (EPA) identification number of the facilitybulletThe unique number of every manifest for PCBs generated by the facility during the calendar yearbulletFor all manifested PCB waste, unmanifested PCB storage, and any PCBs or PCB Item received from or shipped to other facilities managed by the U. S. Department of Energy (DOE) or the University of California (UC): bulletA unique identification number (serial number) for each PCB Article, PCB Container and PCB-Article ContainerbulletPCB weight (kg)bulletDate removed from servicebulletDate placed in transportbulletDate of disposal, if knownbulletThe total number of PCB Articles, PCB-Article Containers, and PCB Containers disposed of or stored for disposal by specific type. The total weight (kg) of PCBs in PCB Articles, PCB-Article Containers, and bulk PCB wastebulletThe total number of PCB Transformers and the total weight (kg) of PCBs contained in transformers that remain in service at the end of the calendar yearbulletThe total number of PCB Capacitors remaining in service at the end of the calendar yearbulletThe total weight (kg) of any PCBs and PCB Items in PCB Containers remaining in service at the end of the calendar year, including the identification of the container contentsbulletRecords of phone calls and other documentation verifying receipt by the designated storage or disposal facility of PCB waste transported by an independent transporter.

Report of PCB Manufacturing Process

The manufacture of PCBs is prohibited in the United States except for PCBs inadvertently generated under certain conditions. The inadvertent generation of PCBs in a concentration greater than 2 ppm must be reported to the EPA. Additional data must be provided to the EPA whenever:

bulletThe total quantity of PCBs in products leaving the manufacturing site in any calendar year exceeds 0.0025 percent of the site's rated capacitybulletThe total quantity of PCBs released to the air from the manufacturing process exceeds 4.54 kg (10 lb) in any calendar yearbulletThe total quantity of PCBs released to the water from the manufacturing process exceeds 4.54 kg (10 lb) in any calendar year.

The data submitted shall include all analytical data and corresponding throughput data for PCBs.

PCB Waste Manifest Exception Reports

A generator of PCB waste who does not receive a copy of the manifest with a handwritten signature from the designated PCB storage or disposal facility within 35 days of the initial shipment date must immediately contact the transporter and/or designated facility to determine the status of the PCB waste. Such contacts must be documented. Copies of the manifests must be included in the PCB annual log.

A generator of PCB waste who does not receive a copy of the manifest with a handwritten signature from the designated PCB storage or disposal facility within 45 days of the initial shipment date must submit an Exception Report to the EPA Regional Administrator, Region IX. The Exception Report must include:

bulletA legible copy of the manifestbulletA cover letter explaining the efforts taken to locate the PCB wastes and the results of those efforts. The cover letter must be signed by the generator or by the generator's authorized representative.

A One-Year Exception Report must be filed by a generator of PCB waste who (1) does not receive a copy of the Certificate of Disposal within 13 months from the date of removal from service, (2) receives a Certificate of Disposal confirming disposal on a date more than one year after the date of removal from service, or (3) stores PCB waste for greater than one year prior to disposal. The only exception to this requirement is if the generator does not transfer the PCB waste to the disposer within nine months from the date of removal from service, as required. The One-Year Exception Report must include:

bulletA legible copy of the manifest, plus other documentation relevant to the transfer and disposal of the PCB wastebulletA cover letter, signed by the submitter (generator) or authorized representative, explaining: bulletDate(s) when the PCBs or PCB Items were removed from servicebulletDate(s) when the PCBs or PCB Items were received by the submitter, if applicablebulletDate(s) when the PCBs or PCB Items were transferred to a designated disposal facilitybulletIdentity of the transporters, storage facilities, and disposal facilities known to be involved with the transactionbulletReason, if known, for the delay in bringing about the disposal of the PCBs within one year from the date of removal from service.

Notification of PCB Waste Activity

Your company should file a Form 7710-53 with the EPA prior to using, storing, etc. PCBs..

PCB Spill Cleanup Records

Records documenting the cleanup of spills with high concentrations (500 ppm or greater PCBs) or more than 454 g (1 lb) of PCBs shall be maintained for five years. The records and certification shall consist of the following:

bulletIdentification of the source (e.g., type of equipment) of the spillbulletEstimated or actual date and time that the spill occurredbulletDate and time that cleanup was completed or terminated (or the nature and duration of the delay if cleanup was delayed by an emergency or adverse weather)bulletA brief description of the spill location and the nature of the material contaminated, including whether the spill occurred in an outdoor electrical substation, other restricted access location, or non-restricted access areabulletPre-cleanup sampling data used to establish the spill boundaries, if required because of insufficient visible traces, and a brief description of the sampling methodology used to establish thembulletA brief description of the solid surfaces cleanedbulletThe approximate depth of soil excavation and the amount of soil removedbulletPost-cleanup verification sampling data, a brief description of the sampling methodology, and the analytical technique usedbulletThe estimated cost of cleanup (not required).

Equipment Inspection Logs

Records of the legally required inspections and maintenance history of PCB Equipment, including the name of the person responsible for the inspections and the dates of inspection, must be maintained for at least three years after disposal.

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Appendix C
PCB Spill Cleanup and Reporting Requirements
(40 CFR 761.120-135)

Polychlorinated biphenyls (PCB) spill cleanup and reporting requirements are presented here as guidance. Spills of PCB materials can only be remediated by personnel trained to handle PCB cleanups. Report all spills of PCBs to your Health and Safety / Environmental Staff.

When spills with low concentrations (less than 500 ppm PCBs) and less than 454 g (1 lb) of PCBs occur, all soil within the spill area (visible boundary plus a 1-lateral-ft buffer zone) must be excavated and backfilled with clean soil. Solid surfaces must be double washed/rinsed. (Double wash/rinse means a minimum requirement to cleanse solid surfaces two times with an appropriate cleaning agent. PCBs must be at least 5-percent soluble by weight in the cleaning agent. A volume of PCB-free fluid sufficient to cover the contaminated surface completely must be used in each wash/rinse.The wash/rinse requirement does not mean the mere spreading of the cleaning agent over the surface, nor does the requirement mean a once-over wipe with a soaked cloth.) This action must be completed within 48 hours after the responsible party was notified or became aware of the spill.

When spills with high concentrations (500 ppm or more PCBs) or more than 454 g (1 lb) of PCBs occur, the National Response Center must be notified immediately. The spill area must be cordoned off with at least a 3-ft buffer zone. Warning signs must be clearly visible. The responsible party must document and record the area of visible contamination, noting the extent and center of the visible trace areas. The cleanup of fluid from hard surfaces and the removal of contaminated soil must be initiated (not necessarily completed) within 24 hours after the responsible party was notified or became aware of the spill. If the spill will result in PCB exposure outside the facility, other spill reporting procedures may be required.

The U. S. Environmental Protection Agency (EPA), Region IX, regards soil, asphalt, wood, cement, and concrete as porous materials that absorb PCBs. Where practicable, these materials must be removed when they are within the spill area. The spill boundary must be verified by sampling and analysis. Solid, impenetrable surfaces (e.g., metals and impervious liners) may be decontaminated by a double wash/rinse. All decontamination must be verified by sampling and analysis, using bulk samples for porous materials and wipe samples for impenetrable surfaces.

All concentrated soils, solvents, rags, and other materials resulting from the cleanup of PCBs must be properly stored, labeled, and disposed of as PCB or PCB-contaminated materials. The containers of PCB wastes generated must be free of PCB contamination on all outside surfaces.

The PCB Spill Cleanup Policy for the EPA, Region IX, requires soils to be remediated to background levels (i.e., detection limits), where practicably attainable, of any PCB spill from a source greater than 50 ppm PCBs. In certain cases, the EPA, Region IX, will consider alternative cleanup levels. Cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 allows deviation from the Regional Policy when the reason for deviation is included in the Record of Decision (ROD). The ROD should have the concurrences of the EPA Pesticides and Toxics Branch Chief and the Toxics and Waste Management Division Director.

Spill reports (both verbal and written) must be completed only by the EPD personnel and are required to contain the following information:

bulletNature of waste or pollutant (i.e., PCB)bulletQuantity of waste or pollutant involvedbulletTime and duration of the incidentbulletCause of the spillbulletEstimated size and location of the affected areabulletNature of effects (e.g., fish kill, toxic cloud, discoloration of receiving water)bulletCorrective measures taken or planned, and a schedule of these activitiesbulletSpill Prevention Control and Countermeasures (SPCC), and/or contingency plans, in effectbulletPersons notified (include name, organization, date, and times).

AŹnumber of agencies are potentially interested in spills of PCBs depending on the spill concentration, quantity, and location. Spill reports must be reported a soon as possible and within the 24-hour legal requirement. Table C-1 (below) summarizes the reporting requirements and notes where written reports are also required.

PCB Spills Table C-1, III.GIF (8292 bytes)

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This page was updated on 10-Jul-2013

 

 

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Contact information:
Environmental Health & Safety Online
EHSO, Inc., 8400 Roswell Rd., Atlanta, GA 30350

Table of Contents for Environmental Health & Safety Online for EHS Professionals http://www.ehso.com/contents.php
Environmental and safety services for business - training, consulting, assessments, ISO14000, report and permit preparations and expert testimony. http://www.ehso.com/EHSservices/enviserv.htm
EHSO is looking for environmental and safety service providers, such as trainers, consultants, CIH's, etc., anywhere in the United States to provide their services to our site visitors.  Write us for more information. Email: or click on feedback

How to get help on your questions
Copyright © 2013 Benivia, LLC (dba EHSO) All rights reserved.