United States Pesticides and
Environmental Protection Toxic Substances
Agency Enforcement Division
&EPA Toxic Substances
Control Act
PCB Manua
Training Module
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Table of Contents
Participant Guide
Introduction
PCS Use and Controls
Uses of PCBs 1-1
PCB Terms 1-3
Prohibited and Authorized Ar'ivities 1-4
Evaluation 1-5
Recordkeeping
Recordkeeping Requirements 2-1
Inspecting for Compliance 2-3
Evaluation 2-4
Marking
Marking Regulations 3-1
Inspecting for Compliance 3-3
Evaluation 3-4
Storage
Storage Requirements 4-1
Inspecting for Compliance 4-3
Decontamination 4-4
Evaluation 4-5
Disposal
Disposal Regulations 5-1
Inspecting for Compliance 5-3
Disposal Options 5-5
Evaluation 5-6
Sampling
Sampling Guidelines 6-1
PCB Inspection Manual March 1981
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Participant Guide
The PCB Inspection Manual Training Module is a detailed program of
instruction designed to provide the specific information you will need to
develop the skills necessary to conduct successful PCB inspections.
The scope of the program includes a study of the PCB Regulations (40 CFR Part
761) and of the basic policies, procedures, and techniques involved in PCB
inspections.
The Module is designed for independent study. With the PCB Inspection Manual
as a text, the Module will guide you through a series of exercises which
introduce, clarify, and reinforce the major concepts related -to inspections.
To facilitate the program and to provide necessary guidance, you should be
assigned to work with an experienced inspector. This "sponsor" will clarify
problems or questions you may have throughout the program, supervise your
field experience, and monitor your progress.
The material presented in this Module is organized into 6 units of study.
Each unit contains a number of exercises designed to help you relate basic
information to practical application in PCB inspections. At the close of the
Module, you will have experienced the major aspects of an inspection and will
have a sound base on which to develop practical inspection skills.
The level of achievement to be attained will depend largely on the care with
which you complete each exercise. Instructions for the exercises are
specific and clear and, if followed carefully, will guide you to mastery of
the material.
Study Checklists
Each unit contains at least one study checklist that states precisely what
you should be able to do at the close of the unit. Read through the list and
respond orally to as many items as you can. This preliminary check will help
you focus your attention on the unit material and will help identify areas
that will need detailed study. After completing the reading assignment,
return to the study checklist and carefully respond in writing to each
item. Work through the list, correcting any errors you may have made the
first time. If questions persist, discuss them with your sponsor. Do not
proceed to the next exercise until you can complete each item of the list.
Reinforcement Exercises
Most units contain several exercises that will ask you to use the basic unit
information to solve problems that inspectors often face in the field.
Responses to many of these exercises will not simply be right or wrong, but
will be open to interpretation and discussion. You should check your
responses with your sponsor.
PCB Inspection Manual ' 1 March 1981
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Participant Guide
Evaluation Exercises
Most units conclude with a unit evaluation that wraps up the unit material.
These evaluations should be completed without the use of notes, books, or
other references. Evaluations are not designed to be graded, but minimum
performance standards list a level of performance that should be achieved.
("7 of 9 items" indicates that a minimum of 7 items should be completed
correctly without use of references.) If you score below the minimum level,
review the unit carefully and confer with your sponsor to ensure a thorough
understanding of the material. Your sponsor has answer keys to the
evaluation exercises.
General Guidelines for Completing the Module
Complete all reading assignments carefully.
Complete each exercise in the order in which it is presented in the
unit.
Follow exercise instructions carefully.
Discuss with your sponsor any problems or questions you cannot resolve
yourself.
PCB Inspection Manual ' ii March 1981
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Introduction
Polychlorlnated Biphenyls, or PCBs, are synthetic organic chemicals with
unique properties that are useful in a variety of products from hydraulic
fluids to carbonless copy paper. They are very stable, inert, noncorrodlng,
and highly heat resistant.
Developed over 45 years ago, PCBs were generally thought of as a "wonder"
chemical. Unlike other organic compounds, PCBs do not easily break down.
This durability, combined with their excellent insulating qualities, made
them ideal for many Industrial applications.
As the use of PCBs continued, increasing amounts of the substance began to
enter and accumulate in the environment. Simultaneously, research and
experiments were showing alarming effects of PCBs on both health and the
environment. The accumulation of PCBs began to affect the food chain, and
consequently, poisonous levels of PCBs were actually present in food. PCBs
have even been found in the milk of nursing mothers and are linked to the
formation of malignant and benign tumors, fetal deaths, reproductive
abnormalities, and mutations. Experiments showed that PCBs attacked the
immunological system and affected the production of enzymes.
In recognition of the risks associated with PCBs and their spread throughout
the environment, Congress mandated in the Toxic Substances Control Act that
PCBs and PCB items be regulated.
The PCB rule, which applies to any substance, mixture, or item with a
concentration of 50 ppm PCBs or greater, lists prohibitions on use,
distribution in commerce, processing, and manufacture without specific
exemption or authorization from EPA.
Specific requirements of the rule designed to ensure the proper disposal of
PCBs and PCB items while minimizing risk to health or to the environment
during use, handling, and storage include:
Recordkeeping. Certain records must be kept by facilities
using, storing, and disposing of PCBs. Of particular interest
are PCB weights; identification and number of items; storage,
transfer, and disposal dates; and identification of shippers and
receivers.
Marking. Items must be clearly identified if they contain
PCBs. (Marking of PCB-contaminated transformers' is not
required.)
PCB Inspection Manual ' ill March 1981
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Introduction
Storage. PCBs and PCB items not in use must be stored in
accordance with requirements designed to ensure safe storage
prior to disposal.
Disposal. Except as provided, PCBs and PCB items must be
disposed of by high-temperature incineration. In some cases,
alternatives to incineration may be acceptable, including
chemical waste landfills, high-efficiency boilers, and other
methods approved by EPA.
EPA has established guidelines and procedures for sampling PCBs in
circumstances where a violation of the regulations is suspected.
This training module will cover in depth the regulations and their
significance in PCB inspections.
PCB Inspection Manual ' iv March 1981
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Unit 1
PCB Uses and Controls
The superior insulating and fire retardant qualities of PCBs have
resulted in the widespread use of this substance in many industrial and
commercial applications. To ensure that human and environmental exposure to
PCBs is insignificant, the PCB rule contains specific prohibitions and
authorizations on the manufacture, use, processing, and distribution in
commerce of PCBs and PCB items.
Essential to PCB facility inspections is an understanding of the controls
Imposed on PCBs and the specific details relating to authorized activities.
Inspectors should be thoroughly familiar with this information and with
specific PCB items, their uses, characteristics, and locations.
Topics covered in this Unit include:
Uses of PCBs and PCB Items
Risks of Contamination
Common Terms Relating to PCBs
Authorizations and Prohibitions
Exercise 1-1 Uses of PCBs 1 Hour
PCBs have been most commonly used in the dielectric fluid of
electrical transformers and capacitors. However, PCBs can be used in
a number of other ways. Together, all uses of PCBs
represent, if uncontrolled, a serious threat to health and the
environment. The risk of contamination from PCBs and PCB items and
the focus of PCB inspections to minimize the risk are covered in
this exercise.
1. Read through the study checklist. Test your background knowledge
by responding to as many items as possible.
2. Read pages 3-1 through 3-17 of the Manual and pages 1-5
through 1-10 of the Glossary,
4. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify
with your sponsor any questions or problems.
5. Proceed to Exercise 1-2 only when the material In this exercise
has been mastered.
Study Checklist. At the close of this exercise, you should be able to:
! Explain what risks of contamination are associated with the
use of PCBs in:
Transformers
PCB Inspection Manual 1-1 . March 1981
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PCB Uses and Controls
Capacitors
Hydraulic Systems
Heat Transfer Systems
Electromagnets
List the factors of primary interest during an inspection of:
Transformers
Capacitors
Define accurately in your own words, the following terms:
Large High-Voltage Capacitor
PCB Article
PCB Article Container
PCB Container
PCB Equipment
PCB Item
PCB Transformer
PCB-Contaminated Transformer
PCB Inspection Manual ' 1-2 March 1981
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PCB Uses and Controls
Exercise 1-2 PCB Terms 10 Minutes
A working knowledge of the PCB regulations is a basic requirement
for inspectors. Before studying the regulations, however, the uses
of PCBs and terms associated with PCBs should be clearly understood.
This exercise will reinforce your understanding of this
informat ion.
1. Read each of the following items. Some are correct, some are
incorrect. If an item is correct, write "Correct." If it is
incorrect, explain why.
2. Do not exceed the time limit listed above.
3. Do not proceed to Exercise 1-3 before this exercise has been
mastered.
4. Clarify with your sponsor any problems or questions.
1. All PCB articles are PCB items.
2. A PCB transformer is a PCB article.
3. A PCB container is a PCB article.
4. The term PCB equipment includes PCB transformers.
5. A PCB large high-voltage capacitor is a PCB item.
6. A transformer containing PCBs with a concentration of less than 50
ppm is a PCB item.
7. A PCB article container containing a PCB transformer is
a PCB item.
8. A PCB-contaminated transformer is a PCB article.
9. A transformer is not classified as a PCB transformer unless it
contains 500 ppm PCBs or greater.
PCB Inspection Manual ' 1-3 March 1981
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PCB Uses and Controls
Exercise 1-3 Prohibited and Authorized Activities 1 Hour
PCB activities that are prohibited and allowed under the PCB rule
are covered in this exercise.
1. Read through the study checklist. Test your background knowledge
by responding to as many items as possible.
2. Read the prohibited and authorized activities (§761.30 and §761.31)
and appropriate cross references.
3. Read pages 2-47 through 2-56 of the Manual.
4. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify
with your sponsor any questions or problems.
5. Proceed to Exercise 1-4 only when the material in this exercise
has been mastered.
Study Checklist. At the close of this exercise, you should be able to:
! State under what conditions PCBs may be
Manufactured
Processed
Distributed in commerce
2. Explain the meaning of "totally enclosed manner."
3< List 4 prohibited uses of waste oil containing PCBs.
Explain the rule regulating a PCB transformer coil.
PCB Inspection Manual 1-4 March 1981
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FOB Uses and Controls
6. Explain the rule regulating the mixing of transformer
dielectric fluids.
7. Explain the process for converting a PCB transformer to a
PCB-contaminated transformer.
Exercise 1-4 Unit 1 Evaluation 15 Minutes
1. Complete this exercise without referring to any text material.
2. Do not exceed the time limit listed above.
3. Clarify questions or problems with your sponsor.
4. Minimum performance standard: 12 of 14 items.
1. List 5 activities in transformer maintenance and repair that could
result in PCB spills.
a.
b.
c.
d.
e.
2. Define "totally enclosed manner."
3. State the primary risks of contamination associated with capacitors.
4. Define the two types of transformers cited in the regulations.
a.
b.
PCB Inspection Manual 1-5 March 1981
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PCB Uses and Controls
5. Describe the waste oil ban.
6. Describe the rule regulating the removal of a coil from a PCB
transformer.
Exercise 1-5 Transformers and Capacitors
After completing this unit, discuss with your sponsor the possibility
of scheduling a visit to a site containing PCB transformers and
capacitors in service or in storage. Before going, review Exercise
1-2, keeping in mind the uses, risks of contamination, and inspection
focus associated with transformers and capacitors. Use the site visit
to clarify questions you may have regarding these items.
PCB Inspection Manual ' 1-6 March 1981
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Unit 2
Records Inspection
The recordkeeping regulations require that facilities using, storing, or
disposing of PCBs and PCB items must maintain comprehensive records of the
types and amounts of PCBs handled at the facility over the previous
calendar year. This information will form the basis of an annual document
that summarizes the total number and quantities of PCBs in service, in
storage for use, in storage for disposal, and disposed of by a facility.
This inventory of information will track PCBs as they move from use through
disposal.
Although the regulations stipulate what information must be recorded, no
particular format is outlined. The records will appear in many different
formats, so particular care must be taken to ensure that the required
information is present in the records. These records must be kept at the
facility for inspection and need only be sent to EPA if requested.
Topics covered in this unit include:
Facilities Required To Keep Records
Types of Records Required
Record Retention Requirements
Exercise 2-1 Recordkeeping Requirements 1 Hour
Inspection of records is a major part of a PCB Inspection.
Careful examination and comparison of the data will indicate
recordkeeping violations, and possibly uncover storage and disposal
violations.
1. Read through the study checklist. Test your background
knowledge by responding to as many items as possible.
2. Read the recordkeeping requirements (§761.45) and appropriate
cross references.
3. Read pages 2-21 through 2-29 of the Manual.
4. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify
with your sponsor any questions or problems.
5. Proceed to Exercise 2-2 only when the material in this exercise
has been mastered.
Study Checklist. At the close of this exercise, you should be able to:
1. List facilities that are required to keep records.
PCB Inspection Manual ' 2-1 March 1981
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Records
2- List retention requirements for these records.
Note the date by which the annual document must be prepared.
For facilities using or storing PCBs. list what records are
required for:
PCB transformers.
PCB large capacitors.
PCBs in containers.
PCB items in containers.
5. For storage and disposal facilities, list what records are
required for:
PCB transformers.
PCB large capacitors.
PCBs in containers.
PCB items in containers.
Correspondence files.
PCB Inspection Manual 2-2 March 1981
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Records
Exercise 2-2 Inspecting for Compliance 15 Minutes
1. Read pages 2-21 through 2-27 and 4-3 through 4-10 of the Manual.
2. Read pages 2-7 and 2-9 of the Manual.
3. Read the items listed below. If noncompliance is indicated,
specify what procedures should be followed to document each
violation. Clarify with your sponsor any questions or problems.
4. Proceed to Exercise 2-3 only when the material in this exercise
has been mastered.
Situations.
1. A facility has not prepared an annual document.
2. A facility has maintained the required records but has not
summarized them.
3. A facility has not identified contents of containers.
4. A facility has not maintained a correspondence file.
PCB Inspection Manual ' 2-3 March 1981
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Records
Exercise 2-3 Unit 2 Evaluation 15 Minutes
1. Complete this exercise without referring to any text material.
2. Do not exceed the time limit listed above.
3. Clarify questions or problems with your sponsor.
4. Minimum performance standard: 8 of 10 items.
1> and facilities are required to keep a
correspondence file.
2. A facility storing : must maintain records in
accordance with §761.45.
3. Records and documents must be kept for years after a facility
ceases PCB activities.
4. Properly maintained records will allow EPA to trace PCBs and PCB
items from initial use through .
5. EPA must be notified within days when a storage or disposal
facility ceases operation.
6. A commonly found PCB item for which records are not required is
7. An annual document covering the previous calendar year must be
prepared no later than
i i- «
8. Six types of information are required for PCB transformers that have
been removed from service at a facility that commonly uses these
items. One type is provided below. What are the other five?
a. Date removed from service.
b.
c.
d.
e.
f.
9. Weight of PCBs must be calculated in
10. The only information required for PCB large capacitors in service is
PCB Inspection Manual P4 " March 1981
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Units
Marking Inspection
The marking regulations require that all PCB items containing 50 ppm PCBs or
greater must be marked to identify PCBs as a regulated hazardous substance
and to ensure their proper handling and disposal.
Topics covered in this unit include:
Applicable Items
Description of Marks ML, MS
Exercise 3-1 Marking Regulations 30 Minutes
A thorough understanding of the1 marking regulations is required for
assessing marking compliance during a facility inspection.
1. Read through the study checklist. Test your background
knowledge by responding to as many items as possible.
2. Read the Marking Regulations (§761.20 and §761.44)
3. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify
with your sponsor any questions or problems.
4. Proceed to Exercise 3-2 only when the material in this exercise
has been mastered.
Study Checklist. At the close of this exercise, you should be able to
relate:
1. To what PCBs and PCB items the marking requirements are
applicable. (§761.20 et seq.) (§761.44 et seq.)
2. To what PCB items the requirements are not applicable.
(§761.20(a)(2))
PCB Inspection Manual 3-1 March 1981
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Marking
The description and uses of the marks ML and MS.
Marking requirements for PCB large high-voltage capacitors in
a protected location such as on a power pole or behind a
fence. (§761.20(c)(2))
Marking requirements for PCB small capacitors. (§761.20(d),
(g))
Marking requirements for PCB large low-voltage capacitors.
(§761.20(a)(5), (g))
7. Marking requirements for storage areas and transport
vehicles. (§761.20(a)(10), (b))
PCB Inspection Manual ' 3-2 March 1981
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Harking
Exercise 3-2 Inspecting for Compliance 30 Minutes
1. Read pages 2-29 through 2-31 of the Manual, taking special note
of the inspection procedures.
2. Read the Marking Assessment Inspection Guide on page 2-15.
3. For each of the following situations, indicate the proper
procedures to ensure compliance with the marking requirements.
If noncompliance is Indicted, specify procedures for documenting
violation. Clarify with your sponsor any questions or problems.
4. Proceed to Exercise 3-3 only when the material in this exercise
has been mastered.
Situations.
1. An unmarked transformer.
2. An unmarked transport vehicle carrying four 55-gallon containers of
liquid PCBs.
3. An unmarked container in a marked storage area.
4. An unmarked low-voltage capacitor in use at a manufacturing plant,
PCB Inspection Manual ' 3-3 March 1981
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Marking
Exercise 3-3 Unit 3 Evaluation 10 Minutes
1. Complete this exercise without referring to any text material.
2. Do not exceed the time limit listed above.
3. Clarify questions or problems with your sponsor.
4. Minimum performance standard: 7 of 9 items.
1. Circle the letter preceding those items to which the marking
regulations are not applicable.
a. Containers of PCBs of 50 ppm or greater.
b. PCB transformers in a marked storage area.
c. PCB-contaminated transformers in service.
d. PCB large high-voltage capacitors inside a marked protective
enclosure
e. Containers of PCB articles.
f. Transport vehicle carrying marked PCB large high-voltage
capacitors.
g. Storage area, if all items inside are properly marked.
2. When is the mark MS used?
3. Where on an article or container must PCB marks be placed?
PCB Inspection Manual ' 3-4 March 1981
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Unit 4
Storage Inspection
The storage regulations require that PCBs and PCB items not in service be
properly stored and managed to ensure minimal migration of PCBs into the
environment*
PCBs not in active service are considered stored; either for future use,
such as fluid for servicing a PCB item, or for disposal at an approved site.
In any case, all facilities that hold stored PCBs must meet the storage
requirements of the rule. Stored PCBs may be found in operating facilities,
storage facilities, and disposal facilities.
Topics covered in this unit include:
Applicable Items
Facility Requirements
Types of Storage
Decontamination
Exercise 4-1 Storage Requirements 1 Hour
A storage inspection is made in conjunction with other parts of a PCB
inspection and requires a thorough understanding of the storage
requirements of the rule and of inspection procedures for determining
compliance.
1. Read through the study checklist. Test your background knowledge
by responding to as many items as possible.
2. Read the Storage Regulations (§761.42).
3. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify with
your sponsor any questions or problems.
4. Proceed to Exercise 4-2 only when the material in this exercise has
been mastered.
Study Checklist. At the close of this exercise,'you should be able to
relate:
1. To what PCBs and PCB items the storage requirements are
applicable. (761.10(a),(b),(c); §761.31(a),(b),(c),(h))
2. To what PCB item the requirements are not applicable.
(761.42(c)(2))
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Sto.
3* The length of time PCB articles and containers stored for
disposal may remain in storage. (§761.42(a),(c))
* The five construction requirements for a storage facility.
(§761.42(b))
5< What items may be placed in a temporary storage area that
does not meet storage requirements. (§761.42(c)(i))
What items may be stored outside a prescribed storage
facility. Where they may be stored. Under what conditions.
Checked how often. (§761.42(c)(2))
The regulation governing the removal of movable equipment
from a storage facility. (§761.42(c)(4))
How often PCB articles and containers in storage must be
checked for leaks. (761.42(c)(5), (c)(2))
9' The proper handling of leaking PCB articles and containers,
(§761.42(c)(5))
PCB Inspection Manual 4-2 March 1981
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Storage
10' The proper handling of spilled or leaked materials.
(§761.42(c)(5))
11 what determines the acceptability of PCB containers for
storing PCBs. (§761.42(c)(6))
12 When a "Spill Prevention Control and Countermeasure Plan" is
required. (§761.42(c)(7)(ii))
Exercise 4-2 Inspecting for Compliance 30 minutes
1. Read pages 2-33 through 2-40 of the Manual, taking special note of
the inspection procedures.
2. Read the Storage Assessment Inspection Guide on pages 2-17 and
218.
3. Respond to each question in the Guide, indicating:
Proper procedures for determining compliance
Means of documenting noncompliance
When sampling would be appropriate
4. Clarify with your sponsor any questions or problems.
5. Proceed to Exercise 4-3 only when the material in this exercise
has been-mastered.
P.CB Inspection Manual : 4^3 March 1981
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Storage
Exercise 4-3 Decontamination 20 Minutes
To guard against risk to health and to the environment, the regulations
require that PCB containers intended for reuse in a non-PCB capacity be
rinsed with a solvent to dilute residual PCBs. Movable equipment whose
surfaces have been in direct contact with PCBs must be cleansed with a
PCB solvent prior to removal from a storage facility area.
1. Read through the study checklist. Test your background knowledge
by responding to as many items as possible.
2. Read the Decontamination Regulations (§761.43) and pages 2-12
and 2-41 of the Manual.
3. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify with
your sponsor any questions or problems.
4. Proceed to Exercise 4-4 only when the material in this exercise has
been mastered.
Study Checklist. At the close of this exercise, you should be able to
relate:
1. Types of items that are likely to require decontamination.
In what area(s) of a facility decontamination operations are
likely to take place.
Proper methods of decontaminating containers and movable
equipment. (§761.43(a), (b))
4. PPM and solubility limitations for solvents.
PCB Inspection Manual ' 4-4 March 1981
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Storage
Exercise 4-4 Unit 4 Evaluation 15 minutes
1. Complete this exercise without referring Co any text material.
2. Do not exceed the time limit listed above.
3. Clarify questions or problems before proceeding to Unit 5.
4. Minimum performance standard: 16 of 18 items.
True False
Check True or False according to the validity of the
following statements .
1. Storage requirements are applicable to drained
PCB-contaminated transformers.
2. Nonleaking PCB articles and containers may be stored
outside the storage facility.
3. Liquid PCBs stored for servicing equipment In use are
subject to the storage regulations.
4. Liquid PCB containers must meet the DOT shipping
container specifications.
5. PCB-contaminated rags, debris, and clean-up materials
are not covered by the regulations.
6. Temporary storage applies only to transformers and
capacitors.
7. Records of quantity and dates must be kept of PCBs
removed from or added to PCB liquid containers in
storage.
8. The storage regulations specify that PCB articles and
containers must be handled in a manner that protects
them from accidental damage or breakage.
9. PCB items stored outside must be stored on pallets.
10. The storage area must be managed such that articles
and containers can be located by date.
Correctly complete the following statements
by filling in the blanks.
11. The major 40 CFR reference for storage requirements is
12. A storage facility floor must have a -inch continuous curb
creating an adequate containment area.
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. Storage
13. PCB articles and containers in temporary storage must be checked at
least once every for leaks.
14. A storage facility must not be located below the
elevation.
15. A storage facility 20 ft. x 20 ft. with minimum curbing would have
a containment area of cubic feet.
16. All PCB articles and containers must be checked for leaks once
every while in a storage facility.
17. Outside storage is permitted only when the facility has immediately
available space equal to 10% of .
18. Some of the means of documenting a suspected violation of the
storage requirements include: ,
19. Solvent may be reused until it contains ppm PCBs.
20. Each PCB container to be used must be flushed times with an
amount of diluent equal to of the PCB container.
21. The method of decontaminating movable equipment is
22. The solubility of PCBs in the solvent must be at least % by
weight.
PCB Inspection Manual 4-6 March 1981
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Unit5
Disposal Inspection
The ultimate goal of the FOB rule Is the safe elimination of PCBs from the
environment. The disposal regulations require that PCBs and PCB items be
disposed of only by approved processes in EPA-approved disposal facilities.
Topics covered in this unit include:
Approved Disposal Methods
Disposal Options
Improper Disposal
Exercise 5-1 Disposal Regulations 1 Hour
PCB Inspectors must have a knowledge of the disposal regulations and
an ability to detect indications of improper disposal.
1. Read through the study checklist. Test your background knowledge
by responding to as many items as possible.
2. Read the disposal regulations (§761.10).
3. Study the disposal chart on page 2-45 of the Manual.
4. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify
with your sponsor any questions or problems.
5. Proceed to Exercise 5-2 only when the material in this exercise
has been mastered.
Study Checklist. At the close of this exercise, you should be able to
relate:
1. The approved methods of disposal of PCBs and PCB items.
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_^____ Disposal
2. To what PCBs and PCB items the disposal regulations apply.
3. The ppm levels covered by the waste oil ban.
4. Which methods of disposal are acceptable for:
a. Liquid PCBs (500 ppm or greater)
b. Liquid PCBs (50 to 500 ppm)
c. Nonliquid PCBs
d. Contaminated municipal sewage treatment sludge and
dredged materials
e. PCB transformers
f. PCB-contamlnated transformers
g. Large high or low-voltage capacitors
h. Small capacitors
PCB Inspection Manual ' 5-2 March 1981
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Disposal
i. Other PCB articles
j. PCB containers.
Exercise 5-2 Inspecting for Compliance 15 Minutes
Spills and leaks, as well as inadvertent or deliberate discharge or
discard of PCBs and PCB items, constitute Improper disposal. A major
part of PCB inspections involves checking for indications of
Improper disposal.
1. Read pages 2-43 and 2-44 of the Manual.
2. Read pages 2-11 through 2-13, Inspecting for Improper Disposal.
3. Use this information in responding to the following questions.
Clarify with your sponsor any questions or problems.
4. Proceed to Exercise 5-3 only when the material in this exercise
has been mastered.
Throughout an inspection, care should be taken to check for
indications of improper disposal. What indications might be
discovered in the following areas?
a. Drainage system discharge points.
b. Repair and maintenance operation sites.
c. Dumps and scrap areas.
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^___ . Disposal
d. Abandoned buildings.
e. Decontamination operation sites.
f. Construction sites.
a
g. Nearby receiving waters.
2. Give one example of how improper disposal might be uncovered during
a records inspection.
3. How might a violation of the waste oil ban be discovered? How would
it be documented?
4. How would a spill be documented?
5. Should general housekeeping at the facility warrant the attention of
the inspector? Why?
PCB Inspection Manual ' 5-4 March 1981
Training Module
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Disposal
Exercise 5-3 Disposal Options 10 Minutes
1. For each of the following PCB items, list all approved options
available for disposal. (Item 1 has been completed as an example.)
2. Refer to information in Exercises 5-1 and 5-2, to the Manual,
and to the regulations as needed. Clarify with your sponsor any
questions or problems.
3. Proceed to Exercise 5-4 only when the material in this exercise'
has been mastered.
1. A PCB transformer.
a. Incineration. . ^
b. Chemical waste landfill, if drained, filled with solvent,
allowed to stand for 18 hours, and then drained thoroughly.
2. A drained PCB-contamlnated transformer.
3. 45 gallons of liquid identified at 1,100 ppm PCBs.
4. An empty container that had contained fluid for servicing PCB
transformers.
5. A 55-gallon drum of soil removed from a spill site.
6. A drum containing a damaged, leaking large high-voltage capacitor.
7. 200 gallons of mineral oil dielectric fluid from PCB-contaminated
transformers.
PCB Inspection Manual ' 5-5 March 1981
Training Module
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Disposal
Exercise 5-4 Unit 5 Evaluation 15 Minutes
1. Complete this exercise without referring to any text material.
2. Do not exceed the time limit listed above.
3. Clarify questions or problems with your sponsor.
4. Minimum performance standard: 5 of 7 items.
1. The only approved method of disposal for liquids above 500 ppm PCBs
is
2. Can waste oil containing 30 ppm PCBs be used for road oiling?
3. List 5 signs that might indicate disposal violations.
a.
b.
c.
d.
4. List 3 areas of a facility that should be routinely checked for
signs of improper disposal.
a.
b.
c.
5. Can PCB transformers be disposed of in a chemical waste landfill?
6. Is there an alternative to Incineration for disposal of PCB large
high-voltage capacitors?
7. Can liquid PCBs from PCB transformers be disposed of in high-
efficiency boilers?
PCB Inspection Manual 5-6 March 1981
Training Module
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Unit 6
Sampling
The integrity and documentation of samples are crucial to the validity of
PCB samples presented as evidence in'EPA case'proceedings. Inspectors must
know when, where, and how to sample to verify the presence and concentration
of PCBs.
Topics covered in this unit include:
' Sampling Guidelines
Sampling Priorities
Exercise 6-1 Sampling Guidelines 1 Hour
In order to make sound judgments in sampling decisions, an inspector
must have a thorough understanding of sampling guidelines and
priorities
1. Read through the study checklist. Test your background knowledge
by responding to as many items as possible.
2. Read pages 2-57 through 2-61 of the Manual.
3. Respond to each item on the study checklist. Correct any errors
and expand any incomplete responses made in Step 1. Clarify with
your sponsor any questions or problems.
4. Proceed to Exercise 6-2 only when the material in this exercise
has been mastered.
Study Checklist. At the close of this exercise, you should be able to:
1 ______ State the purpose of sampling
2. State the 3 general sampling guidelines.
PCB Inspection Manual 6-1 March 1981
Training Module
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- Sampling
Name the final declsionmaker as to whether to sample during a
PCB inspection.
Identify the highest sampling priority.
State the reason for high sampling priority in situations
where items are claimed to be decontaminated.
Cite 2 Instances where sampling may be in order for minor
violations.
List one example of each of the following:
Major storage violation
Major recordkeeping violation
Major marking violation
Minor storage violation
Minor recordkeeping violation
Minor marking violation
PCB Inspection Manual 6-2 March 1981
Training Module
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Sampling
Exercise 6-2 Sampling Priorities 15 Minutes
1.
2.
On Che basis of the three general sampling guidelines,
you would or would not take a sample in the following
situations.
Clarify with your sponsor any questions or problems.
state why
Situations;
1. You discover a large leaking container marked "askarel."
2. You discover discolored soil under a pallet in an outside storage
area.
3. You discover several unmarked containers in a PCB storage area that
are not accounted for in the facility annual document.
4. The facility has in storage several large transformers that the
owner claims have been decontaminated.
5. You discover 1 unmarked container stored along with 26 containers
bearing the mark ML and labeled "over 500 ppm PCBs."
PCB Inspection Manual 6-3 March 1981
Training Module
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