United States Pesticides and Environmental Protection Toxic Substances Agency Enforcement Division &EPA Toxic Substances Control Act PCB Manua Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- 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 Training Module ------- . 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 Training Module ------- 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 Training Module ------- _^____ 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 Training Module ------- 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 Training Module ------- ^___ . 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 ------- 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 ------- 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 ------- 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 ------- - 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 ------- 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 ------- |