Chapter 63 – Polychlorinated Biphenyl (PCB) Management

Contents

Approved by Jim Buehler
Revised 9/21

63.1 Policy
63.2 Scope
63.3 Applicability
63.4 Exceptions
63.5 Roles and Responsibilities
63.6 Definitions
63.7 Required Work Processes

• Work Process A. General Requirements

63.8 Source Requirements
63.9 Reference Documents

Note:
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63.1 Policy

The Berkeley Lab Polychlorinated Biphenyl (PCB) Management policy requires personnel to identify, label, and properly dispose of electrical equipment that contains or could contain PCBs.

63.2 Scope

Oil-filled electrical equipment that may contain PCBs, including (but not limited to) transformers, capacitors, circuit breakers, reclosures, voltage regulators, switches, motor starters, and electromagnets.  If the oil in the oil-filled electrical equipment is unknown, it should be assumed to contain PCBs.

63.3 Applicability

Berkeley Lab employees, visitors, affiliates, and subcontractors who work with or operate oil-filled electrical equipment.

63.4 Exceptions

 None

63.5 Roles and Responsibilities

Role	Responsibilities
Principal investigators and supervisors	Ensure that environmental laws, regulations, and policies are followed Request assistance from the Environmental Services Group within the EHS Division for technical advice on what environmental requirements apply to their operations and what would be an appropriate compliance strategy Provide training for employees in operational requirements pertaining to environmental protection, and maintain records of such training (e.g., generator training) Ensure that activities are performed within acceptable operating standards and that any required records (e.g., training records) are current Notify the EHS Division immediately of any unplanned or accidental releases Contact the Waste Management Group within the EHS Division in the early planning stages before PCB-contaminated oil-filled electrical equipment is disconnected for disposal
Employees	Follow applicable environmental laws, regulations, and policies Must be fully aware of the environmental impact of their activities, and comply with all requirements that govern those activities Perform activities within acceptable operating standards, and maintain current records whenever required   Take immediate action to stop unplanned releases to the environment, and report all instances of unplanned environmental releases to the EHS Division Complete all required training (e.g., generator training) provided by supervisors and the EHS Division
Environmental Services Group	Develops Laboratory policies and procedures to ensure operations are conducted in an environmentally safe manner and in full compliance with all applicable environmental laws and regulations and DOE orders Assesses current and planned Berkeley Lab programs, and assists in defining environmental protection compliance upgrades and corrective actions Participates in discussions regarding PCB management matters with Berkeley Lab employees and regulatory agencies Curtails or suspends any operations that pose an immediate danger to members of the public or the environment Monitors laboratory discharges to the sanitary sewer to verify compliance with applicable regulations and EBMUD permits Investigates reports of unplanned environmental releases, and notifies federal, state, and local authorities in a timely manner, as required
Waste Management Group	Picks up and disposes of PCB waste from Laboratory generators Establishes, as needed, a Satellite Accumulation Area or Waste Accumulation Area for PCB-contaminated oil-filled electrical equipment destined for disposal

63.6 Definitions

Term	Definition
Department of Toxic Substances Control (DTSC)	The department within the California Environmental Protection Agency that regulates hazardous waste management and remedial actions
East Bay Municipal Utility District (EBMUD)	The local municipal wastewater treatment facility that accepts and regulates sanitary-sewer discharges from Berkeley Lab
Effluent	Any treated or untreated liquid discharge from Berkeley Lab or from a Berkeley Lab facility
Environmental monitoring	The collection and analysis of sanitary sewer samples for the analysis of PCB congeners for determining compliance with EBMUD permits
Environmental occurrence	Any sudden or sustained deviation from a regulated or planned performance at an operation with environmental protection and compliance significance
Environmentally preferable products and services	Goods and services that have a lesser or reduced effect on human health and the environment when compared with other goods and services that serve the same purpose
Hazardous wastes	Wastes exhibiting any of the following characteristics:  ignitability, corrosivity, reactivity, and toxicity. In addition, EPA has listed specific wastes as hazardous that do not necessarily exhibit these characteristics.
Large capacitor	A capacitor that contains more than 3 pounds or 30 liquid ounces of dielectric fluid
Pollution prevention	Reducing or eliminating waste at the source by modifying production processes, promoting the use of nontoxic or less-toxic substances, implementing conservation techniques, and reusing materials rather than putting them into the waste stream
Public Owned Treatment Works (POTW)	A general term used for sewage-treatment plants. The East Bay Municipal Utility District (EBMUD) plant is the POTW that accepts sewage from Berkeley Lab. The EBMUD permit sets a discharge limit for PCB congeners.
San Francisco Regional Water Quality Control Board	The agency responsible for regulating the water quality in the San Francisco basin and setting discharge limits for POTWs, including the limit for PCB congeners.
U.S. Environmental Protection Agency (EPA)	A federal agency responsible for enforcing PCB regulations.  PCB spills are reported to the U.S. EPA.

63.7 Required Work Processes

Work Process A. General Requirements

1. Oil-filled Electrical Equipment
   1. In general, oil-filled electrical equipment of unknown content should be assumed to contain polychlorinated biphenyls (PCBs).
   2. Oil-filled electrical equipment that may contain PCBs includes (but is not limited to) transformers, capacitors, circuit breakers, reclosures, voltage regulators, switches, motor starters, and electromagnets.
   3. If a piece of oil-containing equipment is to be disconnected and not reused, please contact Waste Management early in the planning stages so Waste Management can set up the waste accumulation area (WAA) and arrange shipment to meet regulatory requirements.
   4. If the waste is known to have PCBs at a concentration of 50 parts per million (ppm) or greater, or contains waste from a PCB spill cleanup, the accumulation time in the generator satellite accumulation area (SAA) or WAA is 30 days.
   5. Report any oil-filled electrical equipment with greater than 50 ppm PCBs to the Environmental Services Group.
2. Purchasing Oil-filled Electrical Equipment
   1. When new large capacitors are purchased, it is recommended that the owner place a “non-PCB” label on the capacitor. A “large capacitor” is a capacitor that contains more than 3 pounds or 30 liquid ounces of dielectric fluid.
   2. When a new transformer is purchased, it is recommended that a “dry type” transformer be specified over an oil-filled transformer whenever possible.
   3. If an oil-filled transformer is purchased, it is recommended that the owner place a “non-PCB” label on the transformer.
   4. If a used transformer is obtained from another facility, the transformer must not contain PCBs greater than 5 ppm, and the transformer must have supporting documentation proving that the transformer does not have any PCBs above this threshold.

63.8 Source Requirements

• 40 CFR 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions
• CCR, Title 22, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, Sections 66001–67800.5
• City of Berkeley Storm Water Pollution Reduction Ordinance No. 6216
• City of Berkeley Toxics Management Program

63.9 Reference Documents

Title	Type
Chapter 20 Waste Management	Program
Chapter 61 and Groundwater Management	Program
Chapter 63 Polychlorinated Biphenyl (PCB) Management	Program

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