NCD980602163_19840625_Warren County PCB Landfill_SERB C_Draft PCB Control, Handling and Disposal Guidelines-OCR

NORTH CAROLINA
DRAFT
PCB CONTROL, HANDLING AND DISPOSAL GUIDELINES
DATE: May 10, 1984
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PCB CONTROL, HANDLING AND DISPOSAL GUIDELINES
TABLE OF CONTENTS
INTRODUCTION
Purpose
Scope .
Applicability
Definitions ••
SECTION -PROCEDURES
1. IDENTIFICATION OF PCB ITEMS .....
2. DETERMINATION OF APPROPRIATE TRANSFORMER CATEGORIES
3. MARKING REQUIREMENTS
4. TRANSFORMER SERVICING
5. HANDLING OF PCB ITEMS FOR DISPOSAL.
6. RECORDKEEPING ..
7. SPILL REPORTING
8. SPILL CLEAN-UP
9. PERSONAL PROTECTION.
10. ANALYTICAL TESTING
lJ. EPA-REQUIRED EQUIPMENT PHASE-OUT
APPENDIXES
A. Trade names used for PCB fluids and various manufacturers
B. PCB Label
C. Recordkeeping Forms and Instructions
D. PCB Disposal Transport Record and Instructions
E. Oil Sampling for Laboratory Analysis
F. PCB Spill Diagram
G. 40 CFR 761 PCB Regulations
H. PCB Risk Assessment-Inventory Guidance
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6
8
13
16
25
28
33
39
44
45
PCB CONTROL, HANDLING AND DISPOSAL GUIDELINES
Purpose
The purpose of this Plan is to provide guidance to State personnel
involved with the handling and disposal of polychlorinated biphenyls (PCBs).
This plan addresses new or revised regulations promulgated by the U.S.
Environmental Protection Agency (EPA) through July 13, 1983.
Scope
The EPA rulemarking applies to any substance, mixture or item with a 50
ppm (parts per million) or greater concentration of PCBs.
The PCB regulations greatly affect the management of electrical
eauipment of which contain PCB fluids as an insulator with varying
concentrations of PCBs.
This eauipment occasionally fails, and a PCB spill may result. The
failed item, spilled fluid or any contaminated materials (soil, rags,
solvents, debris, etc.) must be disposed of in accordance with EPA's rules and
regulations.
Applicability
These procedures are applicable to all Departments who are involved with
the use, storage, handling, marking or disposal of PCB Items or Articles,
Containers, Eauipment or other substances which contain or have been
contaminated by PCBs. Immediately following the section entitled Definitions
are procedures that have been prepared to implement this Plan.
Definitions
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The definitions issued by EPA for PCB terminology are most important in
determining the proper handling, marking, servicing, and disposal reauirements
of PCB Items.
(a)
( h)
(c)
(d)
"PCB" or "PCBs" means any chemical substance or combination of
substances that is limited to the biphenyl molecule that has been
chlorinated to varying degrees. (EPA has chosen a concentration
level of 50 parts per million (ppm) or greater to implement their
regulations.)
"PCB Item" is defined as any PCB Article, PCB Article Container, PCB
Container or PCB Eauipment, that deliberately or unintentionally
contains or has as a part of it any PCB or PCBs at a concentration
of 50 ppm or greater.
"PCB Article" means any manufactured article, other than a PCB
Container, that contains PCBs and whose surface(s) has been in
direct contact with PCBs. "PCB Article" includes capacitors,
transformers, electric motors, pumps, pipes, etc.
"PCB Container" means any package, can, bottle, bag, barrel, drum,
tank or other device that contains PCBs or PCB Articles and whose
surface(s) has been in direct contact with PCBs.
(e)
(f)
(g)
(h)
(i)
(j)
"PCB Article Container" means any package, can,
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drum, tank or other device used to contain PCB Articles or PCB
Equipment and whose surface(s) has not been in direct contact with
PCBs.
"PCB Transformer" means any transformer whose dielectric fluid
contains a concentration of 500 ppm or greater PCBs.
"PCB-Contaminated Electrical Eauipment" means any electrical
equipment including (but not limited to) transformers, circuit
breakers, reclosers, voltage regulators, switches (including
sectionalizers and motor starters), electromagnets, and cable, that
contain 50 ppm or greater PCB, but less than 500 ppm PCB. Oil
filled electrical eauipment other than circuit breakers, reclosers,
and cable whose PCB concentration is unknown must be assumed to be
PCB-Contaminated Electrical Eauipment (50-499 ppm PCB).
"Non-PCB Transformer" is referred to in the rules and regulations,
but is not officially defined. In general, a "Non-PCB Transformer"
is any transformer whose dielectric fluid contains less than 50 ppm
PCBs. A "Non-PCB Transformer" has to be demonstrated as such rather
than assumed (i.e., testing).
"Small Capacitor" means a capacitor which contains less than three
pounds (about 1 auart) of dielectric fluid such as capacitors found
in streetlights, fluorescent light ballasts and small applicances.
"Large High Voltage Capacitor" means a capacitor which contains
three pounds (about 1 auart) or more of dielectric fluid and
operates at 2000 volts a.c. or above such as primary voltage
substation and distribution capacitors.
(k)
( 1)
(m)
(n)
"Large Low Voltage Capacitors" means a capacitor
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which conta1 sl...V_J•.1 jJ
three pounds (about 1 ouart) or more of dielectric fluid and
operates below 2000 volts a.c. such as low voltage secondary
capacitors.
"PCB Eouipment" means any manufactured item, other than PCB
Container or PCB Article Container, which contains a PCB Article or
other PCB Eouipment, and includes such things as electronic
equipment and fluorescent light ballasts and fixtures.
"Posing an Exposure Risk to Food or Feed" means electrical eouipment
in any location (except private homes) where human food or animal
feed products (those food or feed products regulated by the U.S.
Department of Agriculture or the Food and Drug Administration),
including additives, could be exposed to PCBs released from a PCB
Item. A PCB Item poses an exposure risk to a food or feed process
if PCBs released in any manner from the PCB Item have a potential
pathway to human food or animal feed.
"Disposal" means to intenU onal ly or accidental] y discard, throw
away or othewise complete or terminate the useful life of PCBs
and/or PCB Items. Disposal includes spills, leaks, and other
uncontrolled discharges of PCBs.
SECTION 1
Identification of PCB Items
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The regulations apply to any substance, mixture or item containing or
contaminated with a 50 ppm or greater concentration of PCBs.
1.1 All capacitors purchased for use before 1978 shall be assumed to be
PCB-filled. Non-PCB-filled capacitors will usually be identified by
the manufacturer on the nameplate as containing one of their series
of non-PCB fluids, and some manufacturers' capacitors will bear
separate labels denoting that the capacitors are "Non-PCB."
Examples of some common trade names include: Selectrol I (Sangamo);
Dielectrol II (G.E.); Wemcol (Westinghouse); Edisol (McGraw Edison).
1.2 Transformers fall into one of three basic classifications:
(a) PCB Transformer -The transformer dielectric fluid
contains 500 ppm or greater PCBs.
(b) PCB-Contaminated Electrical Eouipment -This new definition
includes the former "PCB-Contaminated Transformer" category
and means that the transformer dielectric fluid contains at
least 50 ppm but less than 500 ppm PCB.
(c) Non-PCB Transformer -The transformer dielectric fluid
contains less than 50 ppm PCBs.
Section 2 of this Plan explains how to determine appropriate
transformer classification. Section 4 of this Plan discusses in
more detail the transformer servicing restrictions.
-3-
1.3 Some electric motor cooling systems, heat exchange systems, and
older hydraulic systems may contain PCBs.
1.4 Indoor switchgear may contain PCBs.
1.5 When in doubt whether eouipment contains PCBs, refer to nameplate
data or consult eouipment manufacturers for verification. Appendix
A lists the names used to denote PCB fluids by various manufacturers.
1.6 Dielectric fluids in mineral oil-filled transformers, voltage
regulators, switches (including sectionaJizers and motor starters)
and electromagnets must be assumed to contain at least 50 ppm, but
less than 500 ppm PCBs. (Formerly, this reouirement applied only to
mineral oil-filled transformers).
1.7 Dielectric fluids in circuit breakers, reclosers and oil-filled
cable may be assumed to contain less than 50 ppm PCBs even when the
PCB concentration is unknown.
1.8 Oil Sampling Procedures for Laboratory Analysis of Transformer Oil
are in Appendix F.
-4-
SECTION 2 @~~::,-~
Determination of Appropriate Transformer Categories .!.J
2.1 PCB Transformers are transformers whose dielectric fluid contains
PCBs at a concentration of 500 ppm or greater. This category
includes transformers that were designed to use highly concentrated
PCBs as a dielectric fluid as well as those designed to use mineral
oil, but contain 500 ppm or greater PCBs as a result of
manufacturing or servicing operations.
A transformer must be considered to be a PCB Transformer if one of
the following conditions exist: (1) the nameplate indicates that
the transformer contains PCB dielectric fluid (greater than 500
ppm); or (2) the dielectric fluid has been tested and found to
contain 500 ppm or greater PCBs.
2.2 Mineral oil-filled transformers, formerly called PCB-Contaminated
Transformers and now classified as PCB-Contaminated Electrical
Eauipment, are transformers whose dielectric fluid contains between
50 and 499 ppm PCBs. This includes transformers that were designed
to use PCB-free mineral oil dielectric fluids but not contain 50 to
499 ppm PCBs because of manufacturing or servicing operations. ALL
MINERAL OIL-FILLED TRANSFORMERS MUST BE ASSUMED TO BE
PCB-CONTAMINATED ELECTRICAL EQUIPMENT unless tested and found to
contain 500 ppm or greater PCBs, or less than 50 ppm PCBs.
-5-
2.3 Non-PCB Transformers are transformers whose dielectric fluid
contains less than 50 ppm PCBs. No transformer may ever be assumed
a Non-PCB Transformer unless its dielectric fluid has been tested
and found to contain less than 50 ppm PCBs.
-6-
SECTION 3
Marking Reouirements
3.0 Introduction
Marking reouirements are outlined in the PCB Disposal Plan
3.1 All of the following shall be labeled:
a. All PCB Transformers (500 ppm or greater PCBs) whether or not in
service.
b. All capacitors not in service that contain PCBs.
c. All in-service Large High Voltage Capacitors containing PCBs.
d. All PCB Containers -i.e., a package, can, bottle, bag, barrel,
drum, tank, etc., which contains 50 ppm or greater PCBs.
e. All PCB Eouipment, whether or not in service, which contains a PCB
Large High Voltage Capacitor.
f. Hydraulic machinery using PCB hydraulic fluid.
g. Heat transfer systems (other than transformers) using PCBs.
h. All PCB Large Low Voltage Capacitors when removed from service (if
not already marked).
i. All PCB Items when they are removed from service, if not already
marked.
j. Each transport vehicle loaded with PCB Containers that contain more
than 99.4 pounds (roughly 10 gallons) of liouid phase PCBs in
concentrations of 50 ppm or greater or if loaded with one or more
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3.2 NOTE:
PCB Transformers (500 ppm or greater).
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A vehicle requiring~·ma-Pki~ .
should be marked in the following manner: PCB labels should be
placed on both sides and the rear of the vehicle. Marking the front
end of a vehi cle is not required.
a. All required markings must be placed in a position on the exterior
of PCB Items or transport vehicles so that the marks can be easily
seen.
b. MARKING OF "PCB-CONTAMINATED ELECTRICAL EQUIPMENT" (50 TO 449 PPM
PCBs) IS NOT REQUIRED AND THAT EQUIPMENT SHOULD NOT BE MARKED.
3.3 Approved labels for marking are available from Label Master See
Appendix B for label format and address.
3.4 Labeling shall be as follows:
3.4.1 Capacitors at Protected Locations
If one or more PCB Large High Voltage capacitors are installed
in a protected location such as on a power pole or other
structure, or behind a fence or other enclosure, the pole,
structure, fence or other enclosure may be marked instead of
marking each individual capacitor unit. If such method of
marking is used, all individual capacitor units must be marked
with the approved label when removed from service.
-8-
3.4.2 Other Capacitors
Each individual capacitor unit requiring marking in accordance
with Section 3.1 of this Plan shall be marked with the
approved label.
3.4.3 All Other PCB Items Noted in Section 3.1
All other items shall be individually marked with the approved
label applied to an area where the label will be readily
visible.
-9-
SECTION 4
Transformer Servicing
4.1 Routine Transformer Servicing
Routine servicing of transformers (i.e., testing the dielectric fluid,
filtering the fluid, replacing some fluid, or replacing gaskets, bushings
or valves) in any of the transformer categories is permitted.
4.1.1 ROUTINE TOPPING-OFF OF TRANSFORMERS SHALL BE PERFORMED WITH
NON-PCB FLUID (tested at less than 50 ppm PCBs) OR WITH CERTIFIED
I
PCB-FREE FLUID. This will eliminate the need for marking service
transport vehicles when carrying drums of fluid into the field for
servicing and topping-off transformers. In addition, it will
eliminate the reouirement for marking and keeping records of drums
of PCB-Contaminated mineral oil in storage, and will assure that
no highly contaminated dielectric fluids are inadvertently used to
service or top-off transformers.
4.1.2 Filter paper, rags or other by-products contaminated during
routine field servicing of electrical eouipment containing PCBs
shall be disposed of in accordance with Section 5.3.1 of this Plan
after the items are no longer in use.
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4.2 Fluids Removed from Transformers @r&;fJJ;~r
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4.2.1 Fluids removed during servicing of PCB Transformers or
PCB-Contaminated Electrical Eauipment must be captured and re-used
as dielectric fluid or disposed of in accordance with Section
5.3.2 of this Plan.
4.3 Batching of Fluids Removed from Electrical Eauipment
4.3.1 If dielectric fluid drained from more than one piece of mineral
oil-filled eauipment is batched together in a collection tank, the
following should be observed:
(a) Care should be taken to avoid adding fluid drained from a PCB
Transformer (500 ppm or greater) or any other fluids with 500
ppm or greater PCBs to the collection tank. Should this
knowingly happen, the entire tank contents must be considered
to be greater than 500 ppm PCBs, and the mixture could not be
re-used as a dielectric fluid. Proper disposal would be
reauired in accordance with Section 5 of this Plan.
(b) PCB-free or low concentration (less than 50 ppm) dielectric
fluids cannot be added to highly-contaminated mineral oil in
order to dilute the oil to avoid more stringent disposal
requirement.
-11-
4.4 Servicing Prohibitions
4.4.1 Any servicing (rebuilding) of PCB Transformers (500 ppm or
greater) that involves removing the coils from the casing or
reauires detanking is prohibited. Minor repair work such as
replacing a valve or gasket, etc. is permitted.
4.5 Re-Classifying a Transformer
4.5.1 A PCB Transformer may be converted to the status of
"PCB-Contaminated Electrical Eauipment" by draining of the
dielectric fluid and refilling with a non-PCB dielectric fluid.
If, after a minimum of three months of in-service use, an
analytical PCB test shows that the fluid in the transformer
contains less than 500 ppm PCBs, the transformer is re-categorized
to "PCB-Contaminated Electrical Eauipment" and can be rebuilt
(including removal of the coil).
-12-
SECTION 5
HANDLING OF PCB Items for Disposal
5.1 Transformers
5.1.1 Non-Leaking Transformers
a. Non-Leaking PCB Transformers -Arrangements for handling
non-leaking PCB Transformers which are no longer of use and
may reauire disposal should be made by contacting your
designated department PCB Manager. Under no circumstances
shall the transformer be moved or otherwise handled without
contacting the department PCB Manager.
b. Non-Leaking PCB-Contaminated Electrical Eauipment -There are
no special regulatory reauirements necessary for handling
PCB-Contaminated Electrical Eauipment or transporting for
inspection, testing and/or repair. However, precautions shall
be taken to protect the eauipment from damage to the tank,
bushing, etc. that could cause leaks during temporary storage
or during transit.
5.1.2 Leaking Eauipment
In each instance, regardless of the type or category of the
transformer, take immediate action to prevent the loss of fluid
-1 3-
~-0
and to limit the area of contamination. ~1..,-;;, Do NOT DRAIN a
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dielectric fluid which may remain in the transformer unless \,.,~
necessary to prevent possible loss of fluid during storage or
'
transporting. Refer to Sections 7 and 8 of this Plan for proper
spill reporting and clean-up procedures, respectively, then:
a. For PCB Transformers, if possible, patch or plug the leak, and
take any other special precautions necessary to prevent
further fluid loss and water entry. This may include covering
or wrapping with plastic as described in Section 5,1.3 or
other suitable protective method. Contact the department PCB
Manager for special instructions prior to moving or otherwise
handling the PCB Transformer.
b. For PCB-Contaminated Electrical Equipment (including mineral
oil filled transformers, regulators and switches), if
possible, patch or plug the leak and take any other special
precautions necessary to prevent further fluid loss or water
entry. This may include covering or wrapping the equipment
with plastic or other similar material described in Section
5.1.3. Unless absolutely necessary, do not remove fluid from
the eauipment. This can cause damage to the core and coils.
Use special handling and securing procedures when transporting
the equipment to a temporary storage site where it will await
shipment for inspection, testing, and/or repair. If the
eauipment is still leaking, regardless of whether it is
-14-
5 .1.3
covered or wrapped in plastic, it should be temporarily stored
in an area protected from rain or runoff. It is important to
give careful attention and use good judgement when securing
the equipment for transport.
0) !fl;~ r;
If the PCB-Contaminated Electrical Equipment has leaked ~
ruptured and no longer has fluid in it (except residual
amounts), there are no special handling or transporting
requirements.
Plastic Bags and Cushioning Material
The department PCB Manager stocks three sizes of plastic bags for
use with distribution transformers as an additional preventive
measure in avoiding fluid loss in temporary storage and
transporation. Bag sizes are:
1. 40" x 65" X .008" thick
2. SO" x 80" x • 008" thick
3. 60" x 90" x . 008" thick
Also stocked are pieces of wax coated cardboard 42" x 42" x 3/16"
thick for use as cushioning between the bags and pallets. The bags
should be used with transformers that show evidence of leaking or
appear not to be properly sealed.
-15-
Effective use of the bags reouires:
1. Removing dirt and other abrasive material from the bottom
of the transformer.
2. Using care to avoid damage to the bag in placing the
transformer in it, loading on the pallet, etc.
3. Placing the cardboard cushioning material between the bag
and pallet.
5.2 PCB Capacitors
5.2.1 Non-Leaking PCB Capacitors
Non-Leaking capacitors DESIGNATED FOR DISPOSAL may be temporarily
stored at local sites on your facility for thirty days from the
time they are removed from service. A non-leaking capacitor
designated for disposal shall be moved within the thirty-day
period to a PCB storage site designated by the department PCB
Manager. Non-leaking capacitors shall not be placed in PCB
Containers. Precautions shall be taken in handling and moving
non-leaking capacitors so that bushings will not be broken or the
can punctured.
-16-
5.2.2 Leaking PCB Capacitors
All leaking capacitors (except those which are too large and must
be put in a capacitor box) shall be stored in properly marked
open-head type drums. The drum must be sealed by firmly clamping
the cover. The drum can be stored in a temporary location for up
to thirty days after removal from service and then must be moved
to a designated PCB storage site. Handle with care in loading and
transporting to prevent further damage to the capacitor or damage
to the drum. Do not drop or roll drum from one elevation to
another. If contaminated, clean the outside of the drum and/or
boxes and dispose of cleaning materials properly. Do not put any
other materials -soil, gravel, rags, etc. -in the same container
with capacitors.
5.2.3 Small PCB Capacitors
Small PCB capacitors, such as those found in small appliances,
streetlights, and fluorescent light ballasts, may be disposed of
as municipal solid waste if approved by the DHR. This reauires
written request and approval from both the Solid and Hazardous
Waste Management Branch and the controlling authority of the
landfill.
-17-
5.3 Other PCB Items for Disposal
5.3.l Contaminated Solids
Unless decontaminated (see Section 8,5), all soil, rags, paper,
gravel, vegetation, cans, bags or any other material contaminated
with PCBs and DESIGNATED FOR DISPOSAL shall be stored in a
properly marked open-head type drum which may be obtained from the
department PCB Manager. The drum must be sealed by firmly
clamping the cover. Clean the outside of the drum, if
contaminated, and dispose of cleaning materials properly. Do not
put capacitors in drums with other solids. Handle the drum with
care. Within thirty days the sealed drums shall be moved to PCB
storage location at a designated storage area.
5.3.2 Contaminated Fluids
PCB fluids, including transformer dielectric fluids DESIGNATED FOR
DISPOSAL, shall be stored in a properly marked drum of the
tight-head type (having threaded plug closures) which meets DOT
Specification 17E. These are available from the department PCB
Manager. The drum must be sealed by firmly tightening the
threaded plugs. DO NOT put grease, rags or any other impurities
into the fluid designated for disposal. Within thirty days the
sealed drums shall be moved to the PCB storage location designated
by the department PCB Manager.
-18-
5.4 Drums
In filling drums, leave at least 1 3/4 inches
expansion. Clean outside of drums thoroughly, if contaminated,
and dispose of cleaning materials properly. Handle with care. Do
not drop or roll drums from one elevation to another or damage in
any manner. Do not use removable head for fluids.
Disposal costs for PCB fluids vary greatly for different classes
of contamination level, and testing is costly. If the fluid has
been tested, show the PCB content on the Form attached to the
drum, i.e., 87 ppm. If the PCB content is not known, but drum
contents are from a common batch -storage tank, large
transformer, etc. -indicate the number of drums of the common
fluid on each Form involved i.e., Drum No. 1 of 16, etc.
There are two types of drums which are approved for storage and transport
of PCB Items:
1. Open Head type having a gasketed cover and clamping ring to be used
for either leaking PCB capacitors (with no other mixtures placed in
the drum with the capacitors), or other PCB Items.
2. Tight head type drums having threaded plug closures to be used for
fluids contaminated with PCBs.
-19-
These approved drums must be used for PCB Items, and
for any other purpose. No exceptions are permitted.
Drums, whether empty or not, must be considered contaminated on the
inside, and shall be sealed except when being filled. If outside of drum
is contaminated, clean it thoroughly and dispose of all cleaning
materials properly.
Handle with care; do not drop or roll drums from one elevation to another
or damage in any manner.
All drums containing PCB items shall have attached a PCB Disposal Record
Card as discussed in Section 5.5 of this Plan.
5.5 PCB Disposal Transport Record Cards
Form No. (shown in Appendix E), PCB Disposal Transport Record cards shall
be prepared by persons removing a PCB Item from service or storage FOR
DISPOSAL. The card is available from the department PCB Manager. Upon
completion of the information called for on the card, the card is to be
placed in a clear, waterproof envelope and attached to the PCB drums or
other PCB Items DESIGNATED FOR DISPOSAL. All state personnel and
approved contractor personnel are authorized to transport PCB Items only
if this Form is attached with all necessary information provided on the
card. The use of the Form applies only to DISPOSAL of PCB Items, and
functional eouipment transported between storerooms should be handled
according to routine procedures. Instructions for filling out the Form
are given on the reverse side of the card as shown in Appendix E.
-20-
SECTION 6
Recordkeeping
6.0 Introduction
To verify and assure compliance with EPA regulations, adeouate records
must be maintained which show a balance of the following PCB equations
for each facility:
Items in service Items removed Items added Items in service
or stock for disposal or service to or stock ending
beginning -during + stock during = December 31 each
January 1 calendar calendar year
each year year year
To establish the balance of these equations, each responsible operating
department shall maintain records on each facility that has in service or
storage the following items: PCB Transformers, PCB Large High or Low
Voltage Capacitors, or 99.4 pounds of PCBs contained in a PCB Container
(this would mean roughly 10 gallons of fluid, leaking PCB Capacitors, or
99.4 pounds of contaminated debris such as soil from clean-up, etc.). A
facility is defined as any location such as warehouse, storeroom, etc.
-21-
6.1 Records Format
Each institution or department shall maintain records which show the
following information:
a. Location of PCB Items in service or storage (records should identify
the physical location of the PCB Items such as a name of
institution, pole, building, etc.).
b. Amount of PCB Items at each facility according to the following
units:
(1) Capacitors -each.
(2) PCB Transformers -each.
NOTE: There are no recordkeeping reauirements for mineral
oil-filled "PCB-Contaminated Electrical Eauipment."
(3) Liauids and contaminated debris stored for use or disposal in
PCB Containers -kilograms (pounds divided by 2.2).
c. Dates that items were removed from service or storage and put in
transport for disposal.
-22-
6.2 Records Retention
Records shall be retained for at least five (5) years after a facility
ceases using or storing PCBs. Records shall be maintained at the
institution owing the PCB Item.
6.3 Annual Report
An Annual PCB Summary Report shall be prepared for each facility (as
described above) for the previous calendar year and forwarded to the
department PCB Manager by April 30 of the following year. The department
PCB Manager will, early in the calendar year, specify the format and give
examples of information to be submitted for the annual report. The
Annual Report will then be prepared and filed for future inspection by
EPA officials by July 1 of each year. An illustration of the type of
information which will be required in the Annual Report is shown in
Appendix C of this Plan.
6.4 PCB items reauiring more freauent inspection shall be inspected using the
Form in Appendix C.
-23-
SECTION 7
Spill Reporting
7.0 Introduction
At the present time, Federal and State laws and regulations governing
spill reporting requirements are inconsistent.
Federal reporting requirements are mainly geared toward those spills
which enter surface waters of the United States, drainage systems, or
those that threaten waterways, etc., although reporting of the spills
which occur on land may be necessary if the incident poses a "substantial
risk" to human heal th or the environment.
North Carolina has spill reporting requirements somewhat broader and more
stringent than federal requirements. In general, the state requires
reporting of spills or <lischarges "into the environment."
In accordance with State and Federal statutes and regulations concerning
spill reporting, the department PCB Manager will give timely notification
of all reportable spills to the regulatory agencies. The statutes and
regulations also prescribe severe fines and possible criminal penalties
for failing to notify the regulatory agencies of spill incidents. THE
POLICY FOR REPORTING SPILLS ~S OUTLINED IN THIS SECTION MUST BE STRICTLY
ADHERED TO.
-24-
7.1 Applicability
FOR THE PURPOSES OF THIS PLAN, THE REPORTING REQUIRMENTS IN THIS SECTION
WILL APPLY TO SPILLS FROM THE FOLLOWING:
a. All transformers, regulators, and oil switches, unless a test
identifies the fluid contained within as a non-PCB or PCB-free fluid.
b. All capacitors, unless a manufacturers label indicates that the
capacitor contains a PCB-free fluid.
c. Servicing or transfer operations when using contaminated mineral oil.
d. All oil storage tanks, drums, or any container from which a
reportable fluid is spilled.
7.2 What Spills to Report
SPILLS MUST BE REPORTED whenever the incident poses a "substantial risk"
to human health or the environment which, according to EPA, includes a
spill whereby people come into direct or uncontrolled contact with PCBs
or when the extent of the spill is large enough to expose significant
numbers of animals.
-25-
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Al 1 spi 11 s into water, shorelines, or those that threaten wa tercou:
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shall always be reported. Spills shall also be reported when the volume
or the extent of the spill is unknown such as spills into storm sewers or
other drainage systems.
Spills from mineral oil-filled equipment shall be reported unless only
minor leaks, such as bushing leaks, are involved and no waterway is
threatened.
EXCLUSIVE OF ANY PARTICULAR QUANTITY OF FLUIDS SPILLED, ALL SPILLS,
REGARDLESS OF THE AMOUNT, SHOULD BE REPORTED IF THE SPILL OCCURS IN A
LOCATION READILY ACCESSIBLE TO THE PUBLIC.
7.3 Guidelines for PCB Spills
1. Introduction
Priority shall be given to clean-up of any PCB spill. Response must
be prompt, especially if weather conditions are likely to cause the
spill to be dispersed. If a small spill such as liauid from a
single capacitor is discovered at night, to avoid disturbing the
neighborhood and to reduce the hazards of vehicles parked on the
streets, the clean-up may be delayed until daylight hours. Quick
response to a spill minimizes the impact of the spill on the
environment.
The guidelines are to be followed for spills involving any
dielectric liquid with a PCB content equal to, or greater than 50
ppm.
-26-
2. Spills -General
A. Spills from Capacitors
Spillage of dielectric liauid from capacitor units shall be
assumed to be a spillage of PCB material unless the liauid can
positively be identified by a manufacturer's label or another
label as non-PCB. The tanks of all failed capacitor units
should be carefully inspected for leaks. Failed capacitors
often have bulged tanks, but do not always leak. Leaking
units shall be immediately removed for disposal and the leaks
contained. A "leak" means any instance in which a PCB
capacitor has PCB substance on any portion of its external
surface.
B. Spills from Other Electric Eauipment
Spillage of dielectric liauid from PCB electrical eauipment
shall be treated as a spillage of PCB material. Spillage of
dielectric liauid from mineral oil filled transformers,
regulators and switches will be treated as a mineral oil
spill. An oil sample will be taken for each mineral oil spill
to confirm the non-PCB nature of the oil. Any analysis that
shows a PCB content eaual to or greater than 50 ppm will
require clean-up as though the liauid was a PCB material.
-27-
Spill reporting, clean-up, storage and
[!}) !JJfa Ii ·.
disposal of oon-~c~"'j]
insulating and lubricating oils are regulated by various
federal and state programs. Regulations may require special
handling of non-PCB oil spills in some instances.
3. Administration
The facility administrator or his designee will have direct
responsibility for the clean-up operation.
4. Reporting
Spills from PCB eouipment, or mineral oil spills that reach a
waterway shall be reported immediately by the administrator to the
following:
1) EPA Region IV
Atlanta, Georgia
24 hour Emergency Response Number -[phone]
2) N.C Highway Patrol Communications Center
Raleigh, North Carolina
N.C. Warning Point Numbers -[phone]
-[phone] (Raleigh Area)
3) Division of State Construction -[phone]
-28-
Information provided when reporting spills shall include the
following:
Time/date of discharge.
Name, address and phone number of person responsible for
clean-up.
List of names, addresses, and phone numbers of persons,
employees, and others having knowledge of the facts
surrounding the spill.
Material discharged: Trade and chemical names.
Quantity discharged: Gallons, pounds, etc.
Description of vessel or facility from which discharge
occurred (i.e. tank, capacitor, transformer).
Exact location of the discharge including building
name/number, road name/number, city.
Steps taken since discharge to minimize environmental damage.
Did discharge reach waterway? If so, estimate of ouantity.
-29-
4.
By reporting this information, all appropriate federal and state
agencies charged with responding to a PCB spill will have been
notified. Further instructions concerning sampling and clean-up
procedures should follow through these appropriate federal and state
agencies.
Clean-up -General
Actual clean-up of spilled PCB and contaminated materials may be
contracted out to a private firm experienced in clean-up, handling,
and transportation of PCB materials. The Division of State
Construction shall be contacted for assistance. A list of firms
with these capabilities can be secured from the Solid and Hazardous
Waste Management Branch, Division of Health Services, (919)
733-2178. Site should always be protected from weather to prevent
spreading of spill problem (i.e. polyethelene sheet).
5. PCB Contaminated Items
Any vehicle, capacitor, bank rack, transformer, pole or other
eouipment should be identified and isolated or tagged for clean-up.
-30-
6. PCB Contaminated Metal or Pavement
The area should be roped off and, as needed, dikes built to prevent
further contamination. Sufficient Oil Dri to absorb all liouid
shall be applied as soon as possible to the area where dielectric
liouid is spilled. Site should always be protected from weather to
prevent spreading of spill problem (i.e. polyethene sheet).
7. PCB Contaminated Gravel, Soil, etc.
8.
The area should be roped off and, as necessary, dikes built to
prevent further contamination. As soon as possible after a spill,
Oil Dri should be applied in sufficient ouantity to absorb all
liouid that can be reached out of the gravel or soil. Site should
always be protected from weather to prevent spreading of spill
problem (i.e. polyethelene sheet).
PCB Spillage into Water
Immediate reporting is essential particularly if spilled PCB enters
a waterway.
If PCB liouid is spilled into a small stream, the stream should be
dammed up with an earthen dike downstream from any visible sheen. A
submerged outlet (pipe of sufficient size to handle stream flow)
should be installed in the dam to make a water pool if possible, so
that the floating portion of the PCB liauid will surface, making
recovery easier.
-31-
9. Personnel Protection Precautions
In some cases, it may be necessary that facility
engineering/maintenance staff enter an area contaminated by a PCB
spill. If so, precautions should be taken as follows:
If contact with PCBs is unavoidable, PCB-resistant gloves, boots,
and other protective clothing shall be used. Porous gloves and
other material which might absorb and retain PCBs shall not be
used in direct contact with the skin. PCB PROTECTIVE CLOTHING
SHOULD NOT BE WORN OVER NORMAL PROTECTIVE EQUIPMENT, SUCH AS
RUBBER GLOVES AND SLEEVES.
If contact with PCBs is unavoidable, chemical-type eye protection
shall be worn. If eyes come into contact with PCBs, they shall be
irrigated immediately with large auantities of waste for 15
minutes. They shall then be examined by a physician.
Whenever possible, skin which has come into contact with PCBs,
should first be washed with waterless soap and wiped with
disposable towels. Cleaning materials shall be properly disposed
of with other contaminated wastes. This should be followed by
washing with warm water and soap, especially before eating,
drinking, smoking or using toilet facilities.
-32-
In case of spillage on clothing, the
@T0,a1~
clothing shoul~~Wa id,
soon as practicable, the skin washed, and the clothing properly
disposed of in properly marked sealed drums. Employee should
immediately wash as outlined above.
In no instance should facility personnel enter an unventilated
underground vault or other unventilated area. Entry into these
areas can be extremely hazardous to life, and should be done
following strict precautions. Emergency response agencies (i.e.
fire/rescuse department with ventilation equipment and emergency
breathing equipment (self-contained breathing apparatus) should be
called for assistance.
In the event a building ventilation system needs to be shut down
to prevent further possible building contamination, under no
circumstances should an unprotected individual enter into a
contaminated area for this purpose. Emergency personnel dressed
in proper protective gear shall perform the shut-down task.
-33-
SECTION 8
Spill Clean-up and Decontaminat;@)~~ ~~
8.0 Introduction
All spills of PCBs of 50 ppm or greater concentration must be cleaned
up. Clean-up of spills from PCB Transformers (500 ppm and above) and PCB
Capacitors is straightforward--those spills along with contaminated soil,
gravel, rags, etc., must be cleaned up and processed for disposal in
accordance with Section 5 of the Plan.
PCB-Contaminated Electrical Equipment (mineral oil-filled) poses a
different problem because they must be assumed to contain 50 to 499 ppm
PCBs and, as such, spills from the equipment become a candidate for
clean-up.
A. For spills from PCB-Contaminated Electrical Eauipment estimated at
35 gallons of fluid or less, the clean-up and disposal procedures
outlined in Sections 8.1-8.4 of this Plan should be followed. If,
in the judgement of the person handling the spill, extraordinary
measures beyond the clean-up procedures outlined in Sections 8.1-8.4
are necessary, the department PCB Manager should be contacted.
-34-
B.
involve greater than 35 gallons of fluid, the department PCB Manage .
should be contacted for instructions. In certain situations it may
be desirable to perform analytical testing of the dielectric fluid
remaining in the transformer and/or the contaminated soil prior to
beginning major clean-up. This will be decided at the time the call
is made.
8.1 Spills Which Enter or Threaten to Enter Surface Waters or Drainage Systems
If dielectric fluid is dis~overed to be free-flowing at a spill site,
every effort should be made to prevent the fluid from reaching surface
waters, storm sewers, drains, etc. Ditches and/or retention pits can be
dug to retain or divert fluid from entering watercourses.
If dielectric fluids have already reached surface waters directly or by
way of storm sewers or drainageways, every effort should be made to
contain as much of the spill as possible in the watercourse. For
example, a small earthen dike constructed downstream from the point of
spill entry into a small creek or stream can be effective in retarding
the flow in the watercourse. Hay or straw bales placed in the
watercourse between the point of spill entry and the earthen dike would
be effective as a fluid absorbent. The auantities of straw needed would
vary as to the extent of the spill. Saturated straw shall be removed and
placed in a drum for disposal. This procedure should be repeated until
as much of the fluid as possible is removed from the watercourse. Straw
is also an effective absorbent when used to remove fluids from ponds,
lakes, or other still bodies of water.
-35 -
8.2 ~ Clean-up of Hard Surfaces (metal, cement, concrete, etc.)1--0~
Sufficient absorbent material (Oil-Dri, sawdust, soil, etc.) s:~
applied as soon as possible to an area where dielectric fluid is spilled
to absorh all free-standing fluid . The absorbent material shall be
removed and stored in properly marked sealed drums as it becomes
saturated or after 30 minutes of contact time.
Following removal of excess fluid, the surface should be cleaned with
rags soaked in an approved solvent (kerosene, varsol). All contaminated
items must then be deposited in a drum or other approved PCB Container
for proper disposal.
8.3 Clean-up of Spillage to Gravel, Soil, etc.
Contaminated gravel, soil, vegetation, etc., shall be removed and stor~~
in properly marked , approved sealed drums for disposal. Absorbent
material should be applied to a spill area ONLY when there is
free-standing fluid which has not soaked into the soil, etc. Apply only
enough absorbent material to absorb the free-standing puddles of fluid.
After the absorbent material becomes saturated, it should be removed and
placed in a drum along with the contaminated soil, gravel, etc. While
there are no specific rules for determining the depth of soil to be
removed following PCB contact, good judgement should be used to determine
the depth of penetration of the chemical during the time period since
initial contamination. Clean replacement soil and/or gravel should be
returned to the area clean-up if it is necessary to restore the area
where the spill occurred.
-36 -
8.4 Spillage onto Vegetation
Contact with lawns would necessitate removal of grasses along with at
least two inches of underlying soil (using practical judgement to
determine depth of penetration).
All bushes and non-grassy plant contaminated with PCBs should be either
removed or trimmed and disposed of properly. Large trees (i.e.,
contaminated as a result of a ruptured pole-mounted capacitor) should be
trimmed of branches and leaves which are visibly contaminated.
8.5 Decontamination
Any container, hose, tank, or pump which has been used to handle PCBs
shall either be disposed or decontaminated. Decontamination requires
flushing the internal surfaces three times with a solvent (kerosene,
varsol, etc.). Each flushing should be with any commonly used, approved
solvent which has not been previously used for any PCB clean-up or
decontamination purpose. Each rinse shall use a volume of solvent eoual
to at least ten percent of the internal volume of the eouipment to be
decontaminated. The solvent rinse shall be retained for disposal as a
PCB liouid waste according to Section 5.3.2. The decontaminated
container, hose, tank or pump may then be considered non-PCB contaminated
and used accordingly.
-37-
~ ✓pi
Vehicles, walls, structures, eouipment exteriors, etc., upon whic~ P6iff/~
liauid has spilled, leaked or spattered shall be decontaminated hy r'\J 7~
swabbing affected surfaces with an approved solvent. Any resulting
contaminated solvent and rags shall be disposed of as PCB waste according
to Section 5.3.1 of this Plan.
8.6 Handling Eauipment
Crews dispatched to clean-up dielectric fluids contaminated with PCBs
spilled from a power capacitor(s) or PCB-Contaminated Electrical
Eauipment failure should have the following eauipment available to them:
1. Gloves of PCB resistant material
2. Shovels
3. Cotton or wool rags
4. Approved cleaning solvent (kerosene, varso1, etc.)
5. Face shield or safety glasses with side shields
6. Waterless soap and disposable towels
7. 55-gallon drums with sealable top
8, Absorbent material
9. PCB resistant clothing
-38-
SECTION 9
Personal Protection
9.0 Introduction
Recent studies on the toxicity of PCBs have shown that there is very
little evidence of significant or irreversible health effects resulting
from PCB exposure at levels encountered in occupational environments.
One health effect is the development of an acne-like rash due to skin
contact with liouid PCBs . However, this effect appears to be reversible
when the skin contact exposure ceases.
Direct skin contact with PCB's should be minimized to reduce the chance
of the rash and to prevent the long term build-up of the chemical in the
body that could result from repeated skin contact and absorption of the
chemical into the body.
PCB's evaporate very slowly. Vapors from PCB liouids are released in
significant amounts only when the liouid is heated. The odor that is
sometimes associated with PCB fluids is probably due to the carrier
solvent used to dilute the PCB liouid. The most common solvent used for
this purpose is trichlorobenzene. Inhalation of this solvent, as well as
skin contact, should be avoided.
-39-
9.1 Personal Protection
For the purpose of this Plan, the department PCB Manager is responsible
for providing these personal protection procedures:
A. The personal protection eauipment noted in Section 9.2 of this Plan
shall be used as needed to minimi ze direct skin contact with PCBs
when handling dielectric fluids and other items which contain 500
ppm or greater PCBs as follows:
1 . Dielectric fluid from PCB Transformers: These transformers
can be identified by the affixed PCB warning label (shown as
Appendix B).
2 . Dielectric fluids from PCB Capacitors: Al l primary and
secondary capacitors shall be considered PCB capacitors unless
they have a Non-PCB label or manufacturers' label indicating
that the capacitor contains a PCB-free fluid.
3. Other Items: This includes unenclosed eauipment, fluids or
other materials which are suspected to contain or to be
contaminated with greater than 500 ppm PCBs.
B. The personal protection equipment listed in Section 9.2 may also be
used to minimize direct skin contact with PCBs when handling
dielectric fluids and other items which contain less than 500 ppm
PCBs.
-40-
c. The personal protection equipment listed in Section
when needed, to minimize PCB contact with clothing.
D. A complete set of personal protection equipment (trousers, jacket,
gloves, shoe covering, etc.) may not be needed in all cases of
potential exposure to PCBs. The equipment selected for use shall
match the degree of potential skin contact caused by a specific
operation.
E. No personal protection eauipment is necessary when handling
non-leaking transformers, non-leaking capacitors, sealed drums, and
other equipment in which the fluids are totally enclosed.
F. The personal protection equipment is intended for one time use.
When the equipment is soiled it may be disposed according to Section
5 of this Plan.
G. If hands or other skin areas come into direct skin contact with
PCB-containing materials, those parts of the body shall be cleaned
using waterless soap and disposable towels.
H. Smoking, eating, and drinking is prohibited during PCB handling and
until personal clean-up, if needed, is completed.
I. Chemical goggles shall be used, when needed, to prevent liquid PCB
splashes from damaging the eyes.
-41-
9.2 Personal Protection Equipment
A. Personal protection equipment for use in minimizing skin contact
will be stocked in an area designated by the department PCB manager.
1. Chemical gloves, size 8
2. Chemical gloves, size 9
3. Chemical gloves, size 10
4. PCB resistant jacket, large size
s. PCB resistant jacket, extra large size
6. PCB resistant trousers
7. PCB resistant apron
8. PCB resistant boots
B. Respiratory protection equipment for use in preventing the
inhalation of carrier solvents used in PCB equipment will be stocked
in an area designated by the department PCB Manager.
1. Organic vapor respirator with dust and mist prefilter, large
size
2. Replacement cartridges for organic vapor respirator
-42-
9.3
J',
First Aid
l/J",,~
---~· I I l~!) --'<{~¼[~
A. Skin contact -Direct skin contact with PCBs can cause sk: ZI
irritation in some people. If skin irritation results from PCB
contact, the affected skin areas should be immediately cleansed with
waterless soap and then with soap and water. Cold creams can
decrease skin irritation but should not be used until the skin is
thoroughly cleaned.
B. Eye contact -If PCB liauids enter the eye, the eye should be
immediately flushed with running clean water or an approved eye wash
solution.
-43-
SECTION 10
ANALYTICAL TESTING
10.1 All request for analytical testing should be submitted to the
department PCB Manager.
10.2 Food and Feed Facility Testing Program
Special regulatory reauirements exist for transformers located at
food and feed related locations. These transformers shall be
identified as soon as possible for analytical testing.
10.3 Documentation of PCB Analytical Testing
A copy of all results from PCB testing shall be maintained at the
facility that requested the test for 5 years.
10.4 Oil Sampling Procedure for Laboratory Analysis of Transformer Oil
Oil sampling procedure for laboratory analysis of transformer oil
in Appendix F.
-44-
SECTION 11
EPA-Required Eauipment Phase -Out
In its most recent rulemaking, EPA has reauired a phase-out of the
following electrical eauipment1:
NOTE:
1. The use and storage for re-use of PCB Transformers posing a risk of
contamination (exposure risk) to food or feed processes is
prohibited after October 1, 1985.
2. The use of Large PCB Capacitors after October 1, 1988 unless the
capacitor(s) is used within a restricted-access electrical
substation or in a contained and restricted-access indoor
installation (see NOTE below).
EPA defines a "restricted-access electrical substation" as an
outdoor, fenced or walled-in facility that restricts public access,
and a ''restricted-access indoor installation" as a facility which
does not have public access and does have adeauate roof, walls, and
floor to contain any release of PCBs. These definitions exempt our
fenced substations from the phase-out.
The regulations reauiring eauipment phase-outs have been challenged by
four (4) legal suits in Federal Appellate Court.
-45-
3. The use of Large PCB Capacitors which pose a risk of contamination
to food or feed (whether or not in a restricted-access) area
facilities is prohibited after October 1, 1988.
-46-
APPENDIX A
The following list contains the trade names used for PCB
various manufacturers of capacitors and transformers:
NAME
Aroclor
Aroclor B
As bestol
Askarel
Askarel
Askarel
Chlorexto1
Clorinol
Clorphen
Diaclor
Dykanol
Elemex
Eucarel
Hyvol
Inerteen
No-Flamol
Pyranol
Pyroclor
Saf-T-Kuhl
Santo therm FR
Santovac 1 and 2
MANUFACTURER
Monsanto
P. R. Mallory
American Corporation
Hevi-Duty Corporation
Ferranti-Packard Ltd.
Universal Mfg. Company
Allis-Chalmers
Sprague Electric
JARD Company, Inc.
Sangamo Electric
Cornell Dubilier
McGraw-Edison
Electric Utilities Corp.
Aerovox
Westinghouse Electric
Wagner Electric
General Electric
Monsanto
Kuhlman Electric
Monsanto
Monsanto
APPENDIX C
INSTRUCTIONS FOR PREPARING DATA
FOR THE ANNUAL PCB SUMMARY REPORT
Section 6 of the PCB Control, Handling and Disposal Plan -reauires
operating departments to prepare and forward a summary report of PCB
activities for each department for the previous calendar year. PCB Form 1 and
PCB Form 2 are to be used for reporting data for the Annual PCB Summary Report.
PLEASE BE EXPLICIT. FEEL FREE TO MAKE NOTES ON THE PCB FORMS WHICH WOULD BE
HELPFUL IN EXPLAINING UNIQUE SITUATIONS.
PCB Form 1 (Capacitors1 and Mixtures) -Instructions
This form is used to show a balance of PCB capacitor inventories in
service or storage for each location. It is used to report PCB Capacitors and
the Mixtures that result from PCB capacitor ruptures, spillage, and clean-up.
Mixtures resulting from other than PCB capacitor spillage are to be reported
on PCB Form 2. Mixtures include soil, debris, rags, protective clothing, or
other items contaminated by PCBs. "Type" is defined as a description of the
contaminated item (see Appendix C of the PCB Plan for an example), and weights
must be given in kilograms (pounds divided by 2.2). When a capacitor is
placed in the PCB drum, the mixture weight shall include the capacitor weight
plus all other drum contents . "Location or Facility" must provide enough
information to enable the capacitors to be physically located such as a
description of the pole number and name of institution.
PCB Form 2 (Miscellaneous PCB Items) -Instructions
1ln-~-f))~ ..,_ ·~ . .-.,,,,•r,J
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~. I : r, 7(\1
.,, I
··•·.i
This form is used to report PCB inventories of items other than PCB
capicators and the mixtures that result from failed PCB capacitors.
Transformers, hydraulic equipment, motors, and heat exchanges are examples of
PCB Items that should be reported on this form. Mixture resulting from
miscellaneous spills and clean-up should also be reported. For each type
item, record total weight and fluid weight. Weights shall be given in
kilograms (pounds divided by 2 .2). "Location or Facility" must provide enough
information to enable the PCB Item to be physically located such as a
description of the pole number and name of institution.
l Secondary capacitors are not to be reported.
I.
II.
PCB TRANSFORMER INSPECTION AND MAINTENANCE PROGRAM PROCEDURES
INSPECTIONS
1. Identify the locations of PCB Transformers under your
jurisdiction and arrange to inspect for leaks on a quarterly
basis.
2. Fill out the part of Form A, Record of Quarterly PCB
Transformer Inspections, under the heading "Inspection
Results." The types of leaks are defined by EPA as follows:
"minor leak" -
"moderate leak" -
MAINTENANCE/SERVICING
any instance in which a transformer has
any dielectric fluid on any portion of
its external surface.
any leak which results in any quantity
of dielectric fluid running off or
about or run off the external surface
of the transformer.
1. Maintenance of PCB Transformers is reouired only in instances
where a "moderate leak", as defined above and on Form A, is
discovered during an inspection. To eliminate the source of
the leak, the PCB transformer must be repaired and cleaned, or
it must be replaced. This servicing is required by the EPA
rulemaking to commence within two (2) business days from the
date the moderate leak is observed.
III.
2. After mairt~nance/servicing is completed, fill out the
"Servicing Results" portion of Form A.
RECORDKEEPING
1. It is suggested that one Form A sheet be used for each
individual PCB Transformer. By doing this, a running account
of each PCB Transformer can be kept as future inspections are
made.
2. Retain the original of completed Form A for your continued
future use. However, after each quarterly inspection (and
servicing, if needed) has been accomplished, make a copy of
Form A and send to the department PCB Manager. A central file
will be kept in Raleigh in case of an EPA inspection.
3. Form A will serve as the permanent record of PCB Transformer
inspection and maintenance. The records, as reouired by EPA,
must be kept for at least three (3) years. Should your
working copies of Form A be lost or damaged, we will furnish
you a copy of your most recent update as sent to us.
PURPOSE
APPENDIX F.
OIL SAMPLING PROCEDURE FOR
LABORATORY ANALYSIS OF
TRANSFORMER OIL
This document is to be used as a procedure for gathering and handling oil
samples to be analyzed in the lab. The department PCB Manager will be
responsible for locating a state or private laboratory for PCB analyses.
GENERAL NOTES
Incorrect data may result in the lab unless care is taken to avoid
contamination of samples from outside sources. Keep dirt and grease out of
the sample vial. Use only clean vials to eliminate cross contamination from
one sample to another. Inspect screw caps to be certain they have a foil or
Teflon liner and are not cracked or broken.
Accurate recordkeeping is as important as avoiding contamination. A sample
information and check sheet should be filled out for each sample and sent
along with the sample to the test facility. A blank form is included with
this procedure.
Personal protective eouipment is available and shall be used as necessary,
Any excess oil obtained in the sampling process, including rags or protective
clothing that comes in contact with the oil, should be disposed of in a proper
manner.
SAMPLE KIT
A complete kit consists of either two or six clean sample vials (3.7 ml) with
a number on the outside of each vial, screw caps with foil or Teflon liners
for each, and a carrying/shipping case. A sample form should be filled out by
the person gathering the sample. Any vials without a vial number should not
be used.
PROCEDURE
1. Place container under valve to catch overflow.
2. Obtain at least 2 ml. of clean oil in vial. (If necessary, an adapter
can be attached to control the oil flow.)
3. Cap securely and wipe any oil from outer surface of the vial.
4. Fill out a sample form for each individual sample obtained.
In some cases, a sample must be obtained from the top of a transformer instead
of through a drain valve. In this case, use a length of mechanics wire (18
gauge) to lower the vial through the opening in the top of the transformer
until the vial fills with oil. Then withdraw the sample, dispose of the wire
properly, and begin with step 3 above.
If tubing is used to obtain a transformer oil sample, teflon tubing should be
used, not plastic.
Anyone with auestions concerning testing or scheduling tests should contact
the department PCB Manager.