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REQUIREMENTS AND POLICIES MANUAL

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    Title:

    PCB Management

    Publication date:

    9/14/2021

    Effective date:

    4/29/2013

    BRIEF

    Policy Summary

    The Lawrence Berkeley National Laboratory (Berkeley Lab) polychlorinated biphenyl (PCB) policy requires personnel to identify, label, and properly dispose of electrical equipment that contains or could contain PCBs.

    Who Should Read This Policy

    Berkeley Lab employees, visitors, affiliates, and subcontractors who work with or operate electrical equipment that contains or could contain PCBs

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    To Read the ES&H Program Details, Go To:

    ES&H Manual Chapter 63

    Contact Information

    Polychlorinated Biphenyls Subject Matter Expert
    Environmental Services Group
    EHS Division

    Waste Management (Hazardous) Subject Matter Expert
    Waste Management Group
    EHS Division

    Title:

    PCB Management

    Publication date:

    9/14/2021

    Effective date:

    4/29/2013

    POLICY

    A. Purpose

    The Lawrence Berkeley National Laboratory (Berkeley Lab) polychlorinated biphenyl (PCB) policy requires personnel to identify, label, and properly dispose of electrical equipment that contains or could contain PCBs.

    B. Persons Affected

    Berkeley Lab employees, visitors, affiliates, and subcontractors who work with or operate electrical equipment

    C. Exceptions

    None

    D. Policy Statement

    1. Berkeley Lab will treat all liquid-filled electrical equipment with unknown content as containing PCBs. 
    2. Berkeley Lab Waste Management will handle transportation and disposal of all disconnected and unused electrical equipment.
    3. Berkeley Lab employees are encouraged to purchase dry electrical equipment or otherwise label equipment known to be free of PCBs as such to minimize future hazardous waste (Work Process A).

    E. 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 that 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 East Bay Municipal Utility District (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.

    F. Definitions/Acronyms

    Term

    Definition

    Department of Toxic Substances Control (DTSC)

    The department within the California Environmental Protection Agency that regulates hazardous waste management, including PCB waste, 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

    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 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 environmental laws. In California, some of this responsibility is typically delegated to state and local regulatory agencies.

    Waste minimization

    Per the U.S. EPA, measures that reduce the volume and toxicity of hazardous waste disposed to landfills. California defines "waste minimization" as measures that reduce, eliminate, or recycle hazardous waste at the point in a process where such waste may be generated.

    G. Recordkeeping Requirements

    Waste manifests are maintained by the Waste Management Group.

    H. Implementing Documents

    Document number

    Title

    Type

    07.09.013.001

    Polychlorinated Biphenyl (PCB) Management

    Program

    07.09.013.002

    Work Process A, General Requirements

    Process

    07.10.002.001

    Waste Management

    Program

    07.09.012.001

    Contaminated Soil and Groundwater

    Program

    07.09.007.001

    Stormwater Discharge

    Program

    I. Contact Information

    Polychlorinated Biphenyls Subject Matter Expert
    Environmental Services Group
    EHS Division

    Waste Management (Hazardous) Subject Matter Expert
    Waste Management Group
    EHS Division

    J. Revision History

    Date

    Revision

    By Whom

    Revision Description

    Section(s) Affected

    Change Type

    11/27/2012

    0

    R. Pauer

    Rewrite for wiki (brief)

    All

    Minor

    5/14/2013

    1

    R. Fox

    Rewrite for wiki (policy)

    All

    Minor

    9/1/2021

    1.1

    J. Buehler

    Periodic review

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    PCB Management

    Document number

    07.09.013.000

    Revision number

    1.1

    Publication date:

    9/14/2021

    Effective date:

    4/29/2013

    Next review date:

    9/14/2026

    Policy Area:

    Environmental Protection Program

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    None

    Functional Division

    EHS

    Prior reference information (optional)

    ES&H Manual Section 11.3.10 moved to Chapter 63

    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

    Implementing Documents

    Document number

    Title

    Type

    07.09.013.001

    Polychlorinated Biphenyl (PCB) Management

    Program

    07.09.013.002

    Work Process A, General Requirements

    Process

    07.10.002.001

    Waste Management

    Program

    07.09.012.001

    Contaminated Soil and Groundwater

    Program

    07.09.007.001

    Stormwater Discharge

    Program

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