Environmental Health & Safety

Polychlorinated Biphenyls Management Policy


January 2010

Scope:

In accordance with the requirements of the Toxic Substances Control Act (TSCA), 15 USC 2605 and the Federal Environmental Protection Agency 40 CFR 716, Amherst College under the direction of the Environmental Health & Safety Committees has drafted, implemented and will maintain this PCB (Polychlorinated Biphenyls) Management Policy for the health and safety of the faculty, staff, students, visitors, outside contractors and the emergency response agencies that may respond to an incident involving our PCB transformers.

Purpose:

Amherst College has written and implemented this policy in order to lessen potential health and safety risk to the faculty, staff, students, the community and the local emergency response agencies for Amherst College. In addition, the College will aggressively work to reduce the negative environmental impact by inspecting the PCB transformers on a monthly basis and by eventually eliminating the PCB transformers in there entirety. Monitoring and future disposal of the PCB transformers shall be properly managed in accordance with the regulatory requirements of the local, state and federal governments and the standard operating guidelines of the Environmental Health and Safety Committee.

Applicability:

The PCB Management Policy is most often associated with the Electrical and Engineering Departments within the Physical Plant at Amherst College. The Management Policy is the responsibility of these two above referenced departments and the Office of Environmental Health & Safety.

In cases of emergency response, such as a PCB spill or fire the applicability of this policy may become the responsibility of the local fire department, board of health and the Massachusetts Department of Environmental Protection.

Definitions

PCB (Polychlorinated Biphenyl): A halogenated organic chemical substance normally found in a liquid state that is limited to the biphenyl molecule that has been chlorinated to various degrees, or any combination of substances containing such a substance
  • The EPA has classified PCB's as "suspect carcinogens"
PCB Transformers: Electrical pieces of equipment used in the process of making electrical energy. The fluid used to keep the transformers cool is an oil that is contaminated with the Polychlorinated Biphenyls (PCB's)

PCB Identification

PCB fluid or oil is identified as being a free flowing, yellow, viscous or waxy coated liquid. The liquid or solid is considered to be very stable, even at extremely high temperatures. They are chemically resistant with low volatility, flammability and conductivity.

PCB's are often referred to by other names, such as;

  1. Askarel:
    PCB liquid in transformers and capacitors
  2. Therminol:
    PCB liquid in heat transfer systems
  3. Pydraul:
    PCB liquid in hydraulic systems
Trade names that are used to identify PCB containing oil or fluid are;
  1. Arochlor
  2. Chlorinol
  3. Inerteen

PCB Equipment

Those pieces of equipment that have been found to contain PCB contaminated oil include;
  1. light and other ballast's
  2. capacitors and transformers
  3. electric motors
  4. circuit breakers
  5. door closures
  6. voltage regulators
  7. switches and motor starters
  8. electromagnets
  9. cables
  10. hydraulic machines
  11. pumps, and
  12. pipes

Regulatory Requirements

In 1990, the Federal Environmental Protection Agency mandated that tracking systems be established for the control of PCB wastes. The rule required disposers and commercial storers of PCB's to…
  1. obtain an EPA identification number, and improve documentation, and
  2. improve record keeping requirements

Health Hazards

PCB's have been determined to be "suspect carcinogens", materials that are believed to be cancer causing. Chronic exposure to PCB's may cause reproductive failure, gastric disorders, skin lesions and tumors. PCB's store themselves in tissues of living organisms, the liver and fatty deposits within the body Furthermore, PCB's when permitted to burn (in smoke) will migrate very easily into the environment and will pose an immediate threat to those in close proximity. In a small space, exposure to PCB smoke could cause adverse health effects.

Labels and Markings for PCB's

The EPA has outlined two (2) marking formats that must be used to identify PCB's
  1. Large Marks
    Large Mark -must be at least 6" on each side, or reduced to 2" if the item is too small for a full sized label
  2. Small Marks
    Small Mark is a rectangle 1" x 2", or it can be reduced to not less than 0.4" x 0.8" in size
The marks must be placed so that they can be easily read by inspectors or personnel servicing the equipment containing PCB's

Also, labels are required to:

  1. be black letters on a white or yellow background
  2. be durable enough to last the life of the PCB storage container

PCB Determination

Amherst College is in possession of three (3) PCB contaminated electrical transformers in Barrett Hall, Northeast corner of the basement. The required PCB labels have been located on the outside of the door to the above referenced electrical vault for purposes of identification. Except for the High Voltage Station that belongs to the Western Massachusetts Electric company, across from 2 East Drive at Amherst College, we are not aware of any other remaining PCB sources. If old, outdated, unwanted oil is discovered on campus, EH&S can test same utilizing a Chlor-N-50 test kit and then dispose of in accordance with DEP/EPA.

Manifest Requirements

When PCBs are removed from Amherst College, the College becomes the generator of PCB waste and are now required to complete a waste manifest for the "cradle to grave" tracking of that material if it contains more than 50 ppm. The PCB manifest system is similar to the RCRA required manifests. The PCB tracking system requires use of a RCRA manifest forms, that the forms be completed in there entirety and that all of the records are maintained in accordance with the requirements of the Amherst College Manifest Policy.

Disposal Certificate

A. Certificate of Disposal
The Waste Disposal Contractor for Amherst College, in accordance with the requirements of 40 CFR 761.218 is required to prepare a Certificate of Disposal for the PCBs and the containers in which the oil was placed. The Waste Disposal Contractor must…
  1. keep a copy of the certificate
  2. send a copy to Amherst College, and
  3. a copy to any commercial storer
The copies must be kept for a minimum of 3 years.
B. Return Receipt Request
In accordance with 40 CFR 761.215, if Amherst College does not receive a copy of the waste manifest (Return Receipt Requested) with the handwritten signature of the owner or operator of the designated PCB commercial storage or disposal facility within 35 days of the date that the waste was accepted by the initial transporter, the College must immediately contact the transporter and/or the owner or operator of the designated facility to determine status of the PCB waste.
C. Exception Report
Amherst College must submit an Exception Report to the EPA Region 1 Administrator if the College does not receive a copy of the manifest with a handwritten signature of the owner or operator of the designated facility within 45 days of the date that the waste was officially accepted by the initial transporter.

Storage for Disposal

A. Disposal
If stored PCB fluid, oil, other equipment or items are to be disposed of, they shall be properly discarded in accordance with the requirements of the Federal EPA within one (1) year, provided the storage area meets the criteria stipulated below. If the facility does not meet the criteria for storage, the College shall properly dispose of the material within 30 days.
B. Storage Facility Criteria
  1. Roof and walls must be adequate to prevent rainwater from reaching the PCB's or the containers they are placed in.
  2. The floor must have continuous curbing with a minimum 6" high curb.
  3. The floor and curbing must be able to contain two (2) times the volume of the largest PCB container, or 25% of the total internal volume of the stored items, whichever is greater.
  4. Drains valves, floor drains, expansion joints, sewer lines or other openings that would permit liquids to flow from the curbed area are not permitted
  5. Floor and curbing must be constructed of continuous smooth and impervious materials, such as Portland cement, concrete, or steel to prevent or minimize the penetration of PCB's
  6. The storage site must be above the 100 year floodwater elevation.
Each PCB piece of equipment or item located in temporary storage must have a date attached that indicates the day it was removed from service.

Leak Detection

A. Inspections
Amherst College shall check PCB articles, containers, equipment and other items every 30 days. The inspection reminder will be made available to the Physical Plant Electric Shop each month, through our TMA Work Order System. The results will then be recorded in the TMA program.
B. Leakage and Spillage
Any leaking PCB article or container must be immediately disconnected from service by a qualified electrician and then transferred to a non-leaking container.

Any spilled material shall be immediately cleaned up using the appropriate absorbent material or other means of containment and then properly disposed of in accordance with the requirements of the Massachusetts DEP and the Federal EPA.

Any oil spilled in quantities > 10 gallons must be reported to the Massachusetts DEP.

Fire

In the event of a fire involving PCBs, the first priority shall be…
  1. Evacuation of the Building and the immediate area around Barrett Hall.
  2. Smoke from a fire involving the basement transformers could pose a significant health hazard to those persons in close proximity.
  3. Notification of the Fire Department should take place as soon as evacuation has been initiated.
  4. The Fire Department must be told that the fire may involve the PCB transformers located in the Northeast corner of the Barrett Hall Basement.
  5. After the Fire has been extinguished, personnel should not be allowed to enter the building, until the building has been inspected for potential contamination and has been properly cleaned and all hazardous conditions removed (if found to be a health hazard)
All three (3) PCB Transformers are located in…
Barrett Hall
  • Northeast Corner of the Basement

Each transformer contains

> 50 ppm, but < 500 ppm

The test results are located in the office of the Physical Plant Engineer