Management System: Environmental Management System
Subject Area: PCB Management VIEW/PRINT ALL (No Exhibits and Forms)
Effective Date: Jan 6, 2006 (Rev 2.5) Periodic Review Due: Jan 6, 2011	Subject Matter Expert: Mark Davis	Management System Steward: Carol Parnell

Polychlorinated biphenyls (PCBs) belong to a broad family of organic chemicals known as chlorinated hydrocarbons. The use, storage, and disposal of PCBs is regulated under the federal Toxic Substance Control Act (TSCA) of 1976. TSCA also has specific requirements for performing research on PCBs as well as specific requirements for cleanup of spills involving PCBs.

The U. S. Environmental Protection Agency (EPA) banned the manufacture of PCBs in 1979. Prior to 1979, PCBs were widely used in electrical equipment such as capacitors, transformers, switches, voltage regulators, and klystrons. They were also used in heat transfer and hydraulic systems. Monsanto, the principal domestic producer of PCBs, sold PCBs under the trade name "Aroclor." Other common trade names for PCBs include askarel, chlorinol, diaclor, inerteen, pyranol, and pyroclor.

The current BNL PCB Inventory does not contain PCB transformers that are defined as >=500 ppm PCBs. Therefore, the specific regulatory requirements regarding these PCB transformers have not been included in this subject area. If a PCB Transformer is identified, the PCB SME must be notified as soon as possible.

 

Section	Overview of Content (see section for full process)
1. PCB Equipment Inventory Reporting Requirements	Maintain an inventory of department PCB and PCB-contaminated equipment. Notify ECR and/or SME of planned changes. Submit annual inventory reports.
2. PCB Equipment Labeling Requirements	Obtain PCB labels from BNL stock supply. Affix largest PCB label that will fit on equipment. Label equipment exteriors that contain large PCB capacitors, doors to rooms, and storage areas used to store PCB items for disposal. Record the "Removed-From-Service" date on the PCB item or PCB-contaminated item removed from service.
3. PCB Article Storage For Reuse Requirements	Ensure PCB items are stored for reuse in a facility that meets requirements.
4. Requirements for Research Using PCBs	Determine if work involving PCBs requires EPA approval. Submit information to DOE for transmittal to EPA. Conduct research as prescribed by the EPA. Maintain required records.
5. PCB Spill/Fire Response, Reporting and Cleanup	Respond to PCB spill by calling 911 or extension 2222 and following the Spill Response Subject Area. Notify agencies identified in EWMSD SOP for Oil/Chemical Spill Emergency Response at BNL if spill exceeds 1 lb of PCBs by weight. Initiate additional mitigation efforts listed. Complete the Record of PCB Spill and Certification of Cleanup Initiation Form. Forward form to SME, retain copy in files.
6. Disposing of PCB Waste	Notify ECR or SME of intent to dispose of PCB item to ensure inventory control. Determine PCB concentration, volume, and weight of waste material and record on Nonradioactive Waste Control Form. Contact EWMSD and the SME for additional guidance on treatment/disposal requirements for dielectric fluid. Record the "Removed-From-Service" date on the PCB item or PCB-contaminated item and the Nonradioactive Waste Control Form. Go to the section PCB Waste Management in the Hazardous Waste Management Subject Area.
7. Combining PCB Fluids	It is not permissible to combine PCB fluids having different PCB concentrations in order to: Circumvent regulatory requirements, or Meet specifications for burning used oil. Process the mixture based on the source having the highest PCB concentration. Contact SME for details on establishing programs for repeat batch samples.

Definitions

Exhibits

Forms

Training Requirements and Reporting Obligations

• If a spill exceeds 1 pound of PCBs by weight, responsible staff (e.g., EWMSD Spill Responder) notify the agencies identified in the EWMSD RC-SOP-202 for Oil/Chemical Spill Emergency Response at BNL.

External/Internal Requirements

References