PCB Spill Cleanup: Your Policy And Epa-Regulated Cleanup Requirements
September 5, 2014
Lately we’ve been spending some time talking about products and equipment containing Polychlorinated Biphenyls or PCBs. We’ve discussed the history of PCBs, as well as handling, storage, inspections, and drum management. That’s only part of the story when it comes to dealing with PCBs, though.
Nobody likes to think about a spill, whether it’s PCB materials or anything else. Spills are always bad news, but they won’t just go away if we ignore them, and having a clearly spelled-out spill cleanup policy is a vital part of any PCB management plan. As part of the Toxic Substance Control Act (TSCA) of 1979, the Environmental Protection Agency (EPA) placed guidelines on the storage and disposal of PCBs, as well as cleanup of any PCB spills. A good cleanup policy can ensure that you’re compliant with the laws, as outlined in 40 CFR 761.
First, though, there are a couple of types of spills that are excluded from the EPA policy. Spills of non-PCB oil, which is defined as oil that is less than 50 ppm PCB, and old spills that occurred before May 4, 1987 are both excluded from the guidelines. In the case of non-PCB spills, it’s important to be certain that the oil is non-PCB. Equipment that was manufactured after 1979 should have a nameplate certifying that it is non-PCB, but you should always confirm with a GC analytical test for PCB content. If the equipment was manufactured before 1979 or if it isn’t certified, you must do a test to ensure that the oil is non-PCB before disposal. For older spills, see the EPA regulations in 40 CFR 761.120 Subpart G for guidelines.
When it comes time to implement your cleanup policy, remember that EPA regulations break spills down into 3 different Cleanup Requirements, depending on the size and concentration of the spill. Each set of Requirements has the same 3 components:
- Cleanup Requirements
- Recordkeeping Requirements
- Post-Cleanup Sampling
Spills that meet certain qualifications-such as larger spills or spills with particularly high concentration levels-may also have immediate requirements that must be initiated within 24 hours of discovery, or notification requirements.
Cleanup Requirement #1
This applies to a small, low concentration spill of less than 1lb PCBs by weight or less than 270 gallons untested with a concentration known or assumed to be between 50 and 499 ppm PCB. Cleanup must be completed within 48 hours of discovery. Double-wash/rinse all contaminated surfaces, including wood poles, as well as indoor or residential surfaces. You can find instructions for double wash/rinse procedure in the regulations, or you can ask your Solomon Corporation sales representative. Indoor, residential surfaces must be cleaned to 10 micrograms per 100 square centimeters. Excavate all soil within the spill area, including all visible traces of the spill plus a 1 foot buffer area, then backfill the excavated area with clean soil and restore the spill site to its original configuration.
For recordkeeping, you’ll need a spill report which must include the source of the spill, the date and time the spill occurred, the date and time the cleanup was completed, a brief description of the spill location, sampling data, and the approximate depth and amount of soil excavated, along with other information. There are no special post-cleanup sampling requirements required under Cleanup Requirement #1, but each spill should be reviewed to determine if post-cleanup sampling would be prudent.
Cleanup Requirement #2
Applies to larger spills of more than 1lb PCBs by weight or more than 270 gallons untested, but still of a low concentration (50 to 499 ppm PCBs). If more than 1lb PCBs are spilled, you must notify the National Response Center.
Cleanup must be initiated within 24 hours of discovery, including cordoning off the spill location, placing clearly visible signs advising persons to avoid the spill site, and recording a diagram of the spill area. (If there are no visible areas to determine spill boundaries, contact the EPA for guidance.) Once the spill area has been secured, cleanup efforts can begin, very similar to those outlined in Cleanup Requirement #1. See 40 CFR 761 for further guidance.
Cleanup Requirement #3
The requirements for Cleanup Requirement #3 are the same as for Cleanup Requirement #2, except that they apply to spills of any detectable quantity that have a concentration higher than 500 ppm known or assumed. For any spill of more than 10lb PCBs you must notify the National Response Center and your regional EPA office as soon as possible, but no later than 24 hours after discovery.
Remember that if PCB material of any quantity or concentration spills into surface water, drinking water, sewers, grazing lands, or vegetable gardens, notify the EPA office ASAP, within 24 hours.
A PCB spill isn’t something that anybody likes to think about, but with the right cleanup policy, you can be prepared for any eventuality, and keep it from turning into a tragedy. Click here to read Part II of this article.