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))
 PCB Inspection Manual                4-1                          March  1981
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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
        2—18.
    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.


PCB Inspection Manual      ''             4-5March  1981
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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.
 PCB Inspection Manual      •          5-1                        March 1981
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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.
PCB Inspection Manual                 5-3                          March 1981
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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
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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
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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
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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.
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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
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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
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