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REQUIREMENTS AND POLICIES MANUAL

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PCB Management

    Title: PCB Management
    Publication date: 5/14/2013
    Effective date: 4/29/2013

    BRIEF

    Policy Summary

    The 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:

    http://www.lbl.gov/ehs/pub3000/CH63.html

    Contact Information

    Polychlorinated Biphenyls Subject Matter Expert
    Environmental Services Group
    EHSS Division

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

    Title: PCB Management
    Publication date: 5/14/2013
    Effective date: 4/29/2013

    POLICY

    A. Purpose

    The 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 EHSS 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 EHSS Division immediately of any unplanned or accidental releases
    • Contact the Waste Management Group within the EHSS 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 EHSS Division
    • Complete all required training (e.g., generator training) provided by supervisors and the EHSS 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 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 The U.S. EPA as 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
    EHSS Division

    Waste Management (Hazardous) Subject Matter Expert
    Waste Management Group
    EHSS 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

    DOCUMENT INFORMATION

    Title: PCB Management
    Document number 07.09.013.000
    Revision number 1
    Publication date: 5/14/2013
    Effective date: 4/29/2013
    Next review date: 5/14/2016
    Policy Area: Environmental Protection Program
    RPM Section (home) ESH
    RPM Section (cross-reference) None
    Functional Division EHSS
    Prior reference information (optional) PUB-3000 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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