PCB Management -- 4. PCB Spill/Fire Response, Reporting and Cleanup

Management System: Environmental Management System
Subject Area: PCB Management
4. PCB Spill/Fire Response, Reporting and Cleanup
Effective Date: Feb 9, 2011	Subject Matter Expert: Peter Pohlot	Management System Executive: Robert Lee

Applicability

This information applies to all Departments/Divisions.

Required Procedure

All Departments/Divisions are required to respond to all PCB spills in accordance with emergency response protocols (see the Spill Response Subject Area). For PCB spills, follow the steps below.

Step 1	Respond to all PCB spills by calling 911 or ext. 2222 from any internal Laboratory telephone and following emergency response protocols (see the Spill Response Subject Area). For PCB spills, the following additional steps must be taken.
Step 2	If a spill exceeds 1 lb of PCBs by weight, responsible staff (e.g., EPD Spill Responder) notify the agencies identified in the EPD RC-SOP-202 for Oil/Chemical Spill Emergency Response at BNL.
Step 3	If a spill occurs that contains concentrations >50 ppm PCBs or unknown PCB concentrations, the Department/Division designee immediately initiates the following actions: Cordons off the area, restricting access to area evidencing any visible traces of PCBs plus a 3-ft buffer. Posts visible signs advising personnel to avoid the area. Documents the area of visible contamination, noting the center and extent of visible contamination. Initiates cleanup immediately through designated PCB response cleanup personnel (call F&O's Facility Operations Center at ext. 2468). Contacts the Environmental Compliance Representative (ECR) and the respective Industrial Hygiene Representative for instructions and guidance on sampling, cleanup, and verification requirements, and implementing these instructions. Initiates the documentation of the spill on a Record of PCB Spill and Certification of Cleanup Initiation Form and delivers a copy to the ECR. Note: All costs associated with PCB cleanups and hazardous waste disposal are the responsibility of the Department/Division.
Step 4	The ECR reviews the form and submits it to the PCB Management Subject Matter Expert (SME)
Step 5	Upon completion of cleanup, the Department/Division designee completes the Record of PCB Spill and Certification of Cleanup Completion Form and submits a copy to the ECR.
Step 6	The ECR reviews the form and submits it to the PCB Management SME.
Step 7	The PCB Management SME and Department/Division designee retain a complete file with all associated records and forms for a period of at least five years.