AMES Environmental Work Instructions EWI 5-5 Polychlorinated Biphenyl Management

Responsible Office: Code JQ Environmental Management Division Ext. 4-5602, Mail Stop 237-14 Approval Signatures Name of Approver (original signature on file)

Title of Approver Date Approved

Dr. Ann Clarke

Chief, Environmental Management Division

5/18/2011

Document History Log Status (Baseline/Revision/Cancelled)

Document Revision

Effective Date Description

Baseline

April-2011 Replaces APR8800.3 Chapter 9

TABLE OF CONTENTS

Preface: P.1 Purpose P.2 Applicability P.3 Authority P.4 Applicable Documents P.5 Measurement/Verification P.6 Cancellation Chapter 1: Responsibility 1.1 Environmental Management Division 1.2 Users of PCB-Containing or PCB-Contaminated Equipment 1.3 Facilities Engineering Branch 1.4 Facilities Maintenance Branch 1.5 Line Management and Contracting Officers Technical Representatives Chapter 2: Requirements 2.1 General 2.2 Specific Chapter 3: Records Appendix A: Definitions Appendix B: Acronyms Appendix C: Reports Appendix D: Example Labels

 

Preface: P.1 PURPOSE a. This work instruction establishes the requirements for a Polychlorinated Biphenyl (PCB) Management program at NASA Ames Research Center to protect human health, the environment, and to comply with applicable Federal, State, and local regulations. P.2 APPLICABILITY a. This instruction applies to NASA Ames Research Center and Component Facilities for NASA civil servants, onsite support service contractors and to the extent determined by their agreements with NASA regarding their tenancy to resident agency personnel and partners. b. A requirement is identified by “shall,” a good practice by “should,” permission by “may” or “can,” expected outcome or action by “will,” and descriptive material by “is” or “are” (or another verb form of “to be”). P.3 AUTHORITY The major authorities include:

a. Toxic Substances Control Act, 33 U.S.C. 2605(e), Polychlorinated Biphenyls.

b. 40 Code of Federal Regulations (CFR) § 761, Polychlorinated Biphenyls Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions.

c. 40 CFR 350, Emergency Planning and Community Right-to-Know (EPCRA) regulatory requirements relating to PCBs.

d. 40 CFR 350, Emergency planning and notification.

e. 40 CFR 370, Hazardous chemical reporting: Community right-to-know.

f. 40 CFR 372, Toxic chemical release: Community right-to-know.

g. Executive Order (E.O.) 12088, signed Oct. 13, 1978 (43 FR 47707), as amended by E.O.12580, Superfund Implementation (adding environmental contingency planning provisions), and revoked in part by E.O. 13148, Greening the Government through Environmental Leadership, signed April 21, 2000 part (revoking sec. 1-4, Pollution Control Plan).

h. 22 CCR Requirements for Management of Fluorescent Light Ballasts which Contain Polychlorinated Biphenyls (PCBs) §§ 67426.1 - 67429.1.

P.4 APPLICABLE DOCUMENTS

 

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a. NASA Policy Directive (NPD) 85001B, NASA Environmental Management. b. NASA Procedural Requirements (NPR) 8553.1B, NASA Environmental Management System. c. Ames Policy Directive (APD) 8500.1, Ames Environmental Policy. d. Ames Procedural Requirements (APR) 8553.1, Ames Environmental Management System. e. APR 8800.3, Ames Environmental Procedural Requirements. f. Revisions to the PCB Questions and Answers Manual (January 2009), US Environmental Protection Agency (EPA). g. Verification of PCB Spill Cleanup by Sampling and Analysis, U.S. Environmental Protection Agency (August 1985). h. Wipe Sampling and Double Wash/Rinse Cleanup as Recommended by the Environmental Protection Agency PCB Spill Cleanup Policy, U.S. Environmental Protection Agency (April 1991). P.5 MEASUREMENT/VERIFICATION a. PCB-containing and PCB-contaminated transformers will be inspected once per quarter. The annual PCB document will be completed by July 1 the following year. b. On a three year cycle, PCB management will be audited as follows: (1) During years one and two, the Environmental Management Division (EMD) will perform an internal audit of compliance including PCB management. (2) During year three, NASA Headquarters (HQ) will perform the audit of compliance as part of the NASA HQ Environmental Functional Review. c. Metrics will be tracked in Center Level Management Objectives. Other metrics may also be tracked as required. P.6 CANCELLATION a. Replaces APR8800.3 Chapter 9. Chapter 1: Responsibility 1.1. Environmental Management Division (EMD) Environmental Management Division (EMD) shall:

 

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1.1.1. Identify laws, regulations, and Executive Orders to which NASA Ames Research Center must adhere. 1.1.2. Develop NASA Ames Research Center policy to implement the identified laws and regulations. 1.1.3. Provide oversight and direction. 1.1.4. Provide consultation, services, and support. 1.1.5. Sign Hazardous Waste Manifests. 1.1.6. Conduct quarterly PCB transformer inspections. 1.1.7. Provide PCB Awareness training course. 1.1.8. Provide required reports to regulatory agencies. 1.1.9. Provide disposal service of PCB equipment and waste. 1.1.10. Oversee spill cleanups of PCBs. 1.1.11. Approve PCB storage facility at NASA Ames Research Center. 1.1.12. Serve as technical point of contact for regulatory agency inspections. 1.1.13. Prepare annual PCB document logs. 1.1.14. Inform potentially affected personnel and organizations of changes in Federal, State, and local regulations. 1.2. Users of PCB-Containing or PCB-Contaminated Equipment Users of PCB-Containing or PCB-Contaminated Equipment shall: 1.2.1. Attend training as required. 1.2.2. Maintain training records and provide copies of any offsite PCB training to the EMD. 1.2.3. Conduct operations in compliance with all applicable regulations and requirements. 1.2.4. Participate and provide input in order to complete plans and reports on time. 1.2.5. Provide access for inspections, assessments, and audits by the EMD and regulatory agencies.

 

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1.2.6. Implement corrective actions, if required. 1.2.7. Inform the EMD of changes in operations affecting storage and use of PCBs. 1.2.8. Promptly report spills, leaks, or other releases of PCBs to the EMD. 1.3. Facilities Engineering Branch Facilities Engineering Branch shall: 1.3.1. Provide oversight for all construction projects. 1.3.2. Provide notification to the EMD when PCB-containing or PCB-contaminated transformers, capacitors, painted or caulked surfaces or other equipment or facilities are being modified, relocated, removed from service, or disposed of. 1.4. Facilities Maintenance Branch Facilities Maintenance Branch shall: 1.4.1. Provide preventative maintenance. 1.4.2. Manage problems relating to painted surfaces and electrical equipment, including transformers, hydraulic equipment, etc. 1.4.3. Provide resources for the cleanup of non-emergency PCB leaks. 1.4.4. Inspect and document leaking PCB-containing equipment daily, until equipment is repaired or replaced. 1.4.5. Collect samples from PCB-containing or PCB-contaminated equipment 1.4.6. Provide analytical sample results to the EMD. 1.5. Line Management and Contracting Officers Technical Representatives Line Management and Contracting Officers Technical Representatives shall: 1.5.1. Ensure compliance with PCB regulations in their area of responsibility. 1.5.2. Ensure that sufficient resources are available to achieve compliance with applicable regulations. 1.5.3. Ensure that the appropriate spill response materials and personnel protective equipment are available to employees.

 

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1.5.4. Ensure that employees and contractors receive training required to handle PCBs. 1.5.5. Provide resources for response to emergency PCB spills. Chapter 2: Requirements 2.1 General PCB-containing or PCB-contaminated equipment must be managed appropriately. The following are general PCB management requirements: 2.1.1. PCB-containing and PCB-contaminated transformers must be inspected quarterly by the EMD. 2.1.2. Combustible materials must not be stored within 5 meters of a PCB-containing or PCB-contaminated transformer. 2.1.3. All PCB-containing and PCB-contaminated equipment, and enclosures which house them, must be appropriately labeled and locked. 2.1.4. Any leak in a PCB-containing or PCB-contaminated piece of equipment must be reported immediately to the EMD. 2.1.5. Releases must be cleaned up immediately by trained personnel and all releases must be documented and reported, as applicable. 2.2 Specific 2.2.1. Labeling In accordance with Federal regulations, the following must be labeled with label approved by U.S. Environmental Protection Agency: 2.2.1.1.All PCB-containing equipment. 2.2.1.2.All means of access to PCB-containing or PCB-contaminated transformers other than grates or manhole covers, and 2.2.1.3.Specific PCB-contaminated equipment: 2.2.1.3.1. PCB-contaminated transformers and containers 2.2.1.3.2. Electric motors using PCB-contaminated hydraulic fluid, and 2.2.1.3.3. Heat transfer systems (other than transformers) that use PCB-contaminated fluids.

 

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2.2.1.3.4. See Appendix D1 for examples of PCB-containing and PCB-contaminated labels, and D2 for an example of a non-PCB (<50 ppm of PCB) label. They are available from the EMD. 2.2.1.3.5. The California Department of Toxic Substances Control (DTSC) regulates fluid, articles, containers, and equipment containing PCBs at 5 ppm or more as hazardous waste. Therefore, do not assume the blue “non-PCB” label as PCB-free when disposing of the articles. See Appendix D3 for an example of a California regulated PCB (5 ppm to 49 ppm). Consult the EMD for disposal guidance. 2.2.2. Response Procedure 2.2.2.1. A spill of PCB-containing or PCB-contaminated materials shall be cleaned up only by personnel familiar with the hazards of the material and trained in chemical emergency response including proper use of personal protective equipment (PPE). 2.2.2.2. Any spill or release of PCB-contaminated or PCB-containing material shall be reported to the EMD. 2.2.2.3. All spills must be recorded on a spill log available in the Building Emergency Action Plan (BEAP). 2.2.2.4. When a spill has been cleaned up, the resulting material must be managed as a hazardous waste. Refer to your BEAP or EWI 9 Emergency Response for instructions on hazardous materials spills or other releases and procedural requirements for hazardous waste management, for instructions on hazardous waste management. 2.2.3. Inspections 2.2.3.1. All PCB-containing and PCB-contaminated transformers must be inspected quarterly by the EMD. PCB transformer inspections must be documented. 2.2.3.2. PCB transformer inspections must include, but are not limited to, the following questions: 2.2.3.2.1. Is the transformer leaking? 2.2.3.2.2. Is the transformer secondarily contained? 2.2.3.2.3. Are storm drains present near the transformer? 2.2.3.2.4. Are combustibles stored within 5 meters of the transformer? 2.2.3.2.5. Is the transformer enclosure locked? 2.2.3.2.6. What is the inspection date?

 

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2.2.3.2.7. What is the inspector's name? 2.2.3.2.8. Is there proper labeling? 2.2.4. Training Requirements 2.2.4.1. All personnel who use or store PCB-contaminated or PCB-containing materials must receive training in the safe use, handling, and proper storage methods specific to the materials and hazards associated with their normal work. Personnel must also receive training on how to read and understand MSDS and how to respond to a hazardous materials spill. 2.2.4.2. For specific training requirements and regulatory references, refer to procedural requirements for environmental training. 2.2.5. Disposal Requirements 2.2.5.1. Any material or piece of equipment, that contains PCBs in a concentration of five (5) parts per million (ppm) or greater must be disposed of as a hazardous waste. Contact the EMD for information concerning proper disposal. Also, contact the EMD if it is unclear whether the material or equipment may contain PCBs including soil or sediment. 2.2.5.2. Dilution is not a legal method to reduce the PCB concentration below the regulatory limit. No provision specifying a PCB concentration may be avoided as a result of any dilution. 2.2.5.3. Mixing a PCB waste with another waste stream is also unacceptable. Any PCB waste that is mixed with either a Resource Conservation and Recovery Act (RCRA), radioactive, or other waste must be disposed of according to all applicable regulations. Chapter 3: Records Record Name Title of

Responsible Person Retention Requirements

Location

PCB Quarterly Inspection Log

EMD PCB Program Lead

NRRS Schedule 8 23 (2)

Bier

PCB Disposal Manifests

EMD PCB Program lead

NRRS Schedule 8 23 (2)

N237/111

PCB Annual Report EMD PCB Program lead

NRRS Schedule 8 23 (2)

N237/111, T20G, EMD Server, Document Tracking System

Sample Analytical Results

EMD PCB Program lead

NRRS Schedule 8 23 (2)

T20G, EMD Server, Document Tracking System

 

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APPENDIX A. DEFINITIONS A.1 Annual PCB Document Log/Report. A detailed report prepared annually by the EMD

and maintained at Ames that tracks the PCB equipment onsite, and also covers PCB waste handling, inspections, etc. (40 CFR 761.3 and 761.180)

A.2 Combustible. A material with a flashpoint at or above 100 degrees F (Uniform Fire

Code) A.3 Large Capacitor. A capacitor that contains 1.36 kg (3 lb.) or more of dielectric fluid (40

CFR 761.3) A.4 PCB Article. Any manufactured article, other than a PCB Container, that contains PCBs

and whose surface(s) has been in direct contact with PCBs. Examples include transformers, capacitors, electric motors, pumps, and pipes. (40 CFR 761.3)

A.5 PCB Container. Any package, can, bottle, bag, barrel, drum, tank, or other device that

contains PCBs or PCB Articles and whose surface(s) has been in direct contact with PCBs. (40 CFR 761.3)

A.6 PCB-Containing Article. An article with a PCB concentration greater than or equal to

500 ppm (40 CFR 761.3) A.7 PCB-Contaminated Article. An article with a PCB concentration at greater than or

equal to 50 ppm (parts per million) but less than 500 ppm (40 CFR 761.3) A.8 PCB Inspections. Quarterly inspections by the EMD of all PCB-Containing and PCB-

Contaminated transformers per 40 CFR 761.30(a)(1)(xii).

A.9 Polychlorinated Biphenyl (PCB). A biphenyl molecule that has been chlorinated to varying degrees and that belongs to a family of organic compounds known as chlorinated hydrocarbons. PCBs have a heavy oil-like consistency, a high boiling point, a high degree of chemical stability, low flammability, and low electrical conductivity. PCBs and PCB byproducts are highly toxic and persistent. They have been found to be teratogenic and carcinogenic. PCBs are known to cause chronic reproductive effects, gastric disorders, and skin lesions, such as chloracne.

A.10 Prohibited Activities. The following is a list of prohibited activities as they apply to

PCBs. Any questions concerning this list should be directed to the EMD.

a. No persons may use any PCB, regardless of concentration, in any manner other than in a totally enclosed system. An example of a totally enclosed system is non-leaking electrical equipment.

b. No persons may manufacture PCBs for use within the United States.

 

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c. No persons may process or distribute in commerce any PCB, or any PCB item, regardless of concentration, for use within the United States or for export from the United States without a specific exemption.

A.11 Retrofill. To remove PCB or PCB-contaminated dielectric fluid and to replace it with non-PCB dielectric fluid.

A.12 Small Capacitor. A capacitor that contains less than 1.36 kg (3 lb.) of dielectric fluid.

(40 CFR 761.3) A.13 Standards. The numerical decontamination levels set forth in Subpart G of 40 CFR 761. A.14 Storage Facility. A facility designated to store PCB-Containing and PCB-Contaminated

waste, or other materials according to the standard set in 40 CFR 761.65. Any such facility must meet the following minimum standards: a. Adequate roof and walls to prevent rainwater from reaching the stored PCBs and PCB items.

b. An adequate floor that has continuous curbing with a minimum 6-inch-high curb. The floor and curbing must provide a containment volume equal to at least two times the internal volume of the largest PCB Article or PCB Container stored therein or 25 percent of the total internal volume of all PCB Articles or PCB Containers stored therein, whichever is greater.

c. No drain valves, floor drains, expansion joints, sewer lines, or other openings that would permit liquids to flow from the curbed area.

d. Floors and curbing must be constructed of continuous, smooth, and impervious materials.

e. Not be located at a site that is below the 100-year flood-water elevation.

 

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APPENDIX B. ACRONYMS

APD Ames Policy Directive APR Ames Procedural Requirement BEAP Building Emergency Action Plan CCR California Code of Regulations CFR Code of Federal Regulations CY Calendar Year DTSC Department of Toxic Substances Control EMD Environmental Management Division EO Executive Order EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right-to-Know FY Fiscal Year HQ Headquarters MSDS Material Safety Data Sheet NPD NASA Policy Directive NPR NASA Procedural Requirement PCB Polychlorinated Biphenyls PPM Parts Per Million RCRA Resource Conservation and Recovery Act TSCA Toxic Substances Control Act USEPA United States Environmental Protection Agency USC United States Code

 

 

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APPENDIX C. REPORTS

PCB Annual Report Frequency: Annual Reported To: Internal Report FY or Calendar Year (CY) Data

CY Required By: 40 CFR 761.180

Report Due: 7/1/2011 Internally Report To:

Dan Winningham

Data Source Primary Contact Contact(s) For Past Reports

Data Required Units

EMD Duc Tran, EMD Duc Tran, EMD PCB Inspection Log

N/A

EMD Duc Tran, EMD Duc Tran, EMD PCB Disposal Records

Kilograms, Pounds, Gallons

EMD Duc Tran, EMD Duc Tran, EMD PCB Sampling Analytical Results

Various

Facilities Maintenance

Carman Morey, Kent A Stednitz

Carman Morey, Kent A Stednitz

PCB Sampling Analytical Results

Various

 

 

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Appendix D. EXAMPLE LABELS D1. PCB-Containing and PCB-Contaminated Labels

 

 

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D2. Label for equipment with less than 50 ppm PCBs

 

 

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D3. Additional Label for equipment containing oil from 5 to 49 ppm PCBs.