TE-HH PCB SOP.docx

DEPARTMENT OF THE ARMY

INSTALLATION MANAGEMENT COMMAND

HEADQUARTERS, UNITED STATES ARMY GARRISON, DUGWAY PROVING GROUND

DUGWAY, UTAH 84022-5000

W911S6-16-R-0002 TECHNICAL EXHIBIT HH

SUBJECT: Standing Operating Procedure (SOP) for the Management and Disposal of Polychlorinated Biphenyls (PCBs) and PCB Containing Materials

REPLY TO

ATTENTION OF:

IMDU-PW 12 April 2016

MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT: Standing Operating Procedure (SOP) for the Management and Disposal of Polychlorinated Biphenyls (PCBs) and PCB Containing Materials

1. REFERENCES.

a. 29 CFR Part 1910.1200.

b. 40 CFR Part 761.

c. DPW Regulations 200-1.

d. Hazardous Waste Turn-In SOP by the Directorate of Public Works, Environmental Compliance and Management Division.

e. Dugway Proving Ground Hazardous Waste Management Plan.

2. PURPOSE. Polychlorinated Biphenyls (PCBs) are extremely toxic chemicals that if not handled properly can have very serious human health and environmental consequences. This standing operating procedure (SOP) provides step-by-step guidance for the management, processing and disposal of PCBs and PCB containing material(s), including but not limited to light ballasts and transformers. This SOP also specifies sampling methodologies and clean-up procedures for PCB spill s.

3. OBJECTIVE. To ensure proper procedures for management, handling, turn-in, processing, disposal and clean-up of PCBs and PCB containing material(s) so human health is protected and contamination of the environment is minimized or avoided. This SOP also outlines notification and record keeping requirements for PCB management.

4. APPLICABILITY. This SOP applies to all Dugway Proving Ground personnel who are responsible for equipment containing PCBs or may encounter PCB containing material(s), including military, civilian, and contractors.

7. WORKER PROTECTION. All safety procedures will be followed when conducti ng operations on equipment potentially containing PCBs. When sampling or hand ling PCB containing material(s) or equipment, workers are required to wear proper personal protective equipment (PPE) according to the Material Safety Data Sheet (MSDS).

8. TRAINING. Employees handling PCB containing material(s) and equipment shall be thoroughly familiar with emergency and proper handling procedures. Training shall be in accordance with 29 CFR Part 1910.1200 and 40 CFR Part 761. All training shall be documented and refreshed as necessary. Workers shall not be allowed to handle PCB containing material(s) until training has taken place and is documented.

9. OPERATION. This SOP outlines the required coordination between units and/or directorates to ensure compliance with applicable laws and regulations and to avoid contract related issues. Actual turn-in of PCB containing material(s) and/or equipment shall be accomplished in accordance with DPG Regulation 200-1, the Dugway Environmental Division Hazardous Waste Tum-in SOP and this SOP.

10. ACTIVE TRANSFORME R INSPECTION.

a. The Dugway Environmental Division personnel will inspect a minimum of 10 percent of all PCB containing transformers monthly by the last working day of each month. The Dugway Environmental Division will generate a priority two service order.

b. A representative from the Installation operations and maintenance contractor will accompany the DPW Environmental Division personnel on the inspection.

c. All inspections will be documented by the Dugway Environmental Division and photographs will be taken of each PCB containing transformer inspected and included as part of the documentation.

d. The Dugway Environmental Division will notify the Directorate of Public Works (DPW) via e-mail within 24-hours after the inspection if it reveals any problems with a transformer. The Dugway Environmental Division will follow up with a full, written report to the DPW within 3 days of the inspection. The DPW shall maintain responsibility for notifying the Base Operations Support Services Contractor of any corrective action required and ensuring proper actions are taken in a timely manner.

e. The Installation operation and maintenance contractor will complete the required action to clean up any spills or leaks within 24 hours of notification and in accordance with 40 CFR 761 part IV requirements for PCB Spill Clean-up. In addition, the contractor shall provide the Dugway Environmental Division and DPW with documentation detailing the corrective measures taken.

f. Once the contractor has completed the necessary corrective actions, the DPW will contact the Dugway Environmental Division to request confirmatory sampling to document that clean-up was accomplished IAW 40 CFR Part 761.

g. If the sample results indicate that corrective measures have successfully cleaned the spill or leak, the Dugway Environmental Division will prepare a report confirming the results.

h. If the sample results indicate that corrective measures have not cleaned up the spill to regulatory guidelines, clean-up operations shall be performed again until lab analysis confirms clean up has been achieved.

i. The Dugway Environmental Division shall be responsible for maintaining all relevant records.

11. TRANSFORMER REMOVAL.

a. All transformers removed from service will be taken to the Dugway Environmental Division Hazardous Waste Storage Facility (HWSF), building 6674.

b. Once the transformer has been removed from service, it shall remain on the vehicle in secondary containment and protected from the elements. The transformer shall be taken to the HWSF within 24-hours of removal or the first working day if removed on a weekend or holiday. Personnel at the HWSF will conduct appropriate testing to determine if the transformer removed from service contains PCBs.

c. Quantitative testing of transformer fluid will be accomplished by HWSF personnel with an appropriate PCB detection kit such as the Clor-N-Oil test kits (Test 50ppm and above for PCB) to determine if the transformer contains PCBs. The results of the screening kit determine the proper disposition of the transformer, either as a solid or hazardous waste.

d. The transformers tested will be marked with a grease pencil or paint marker by Dugway Environmental Division personnel conducting the test. The markings shall indicate:

(1) The date the test was performed and the tester's initials.

(2) If the quantitative test indicates PCBs are not present a No PCB sticker will be affixed to the transformer.

e. All test information will be documented in the facility PCB Log.

f. If the HWSF test indicates the transformer contains no PCBs, the Installation operations and maintenance contractor will be notified to pick it up and dispose of it in accordance with applicable laws and regulations. The Dugway Environmental Division must approve the proposed disposal method and location in advance.

g. If the HWSF test indicates the transformer contains PCBs, the Dugway Environmental Division will collect samples and send them to an approved laboratory for analysis. The transformer will be marked with the test date, sample number, PCB level detected, and the tester’s initials.

h. The PCB containing transformer will be temporarily stored at the HWSF. The Dugway Environmental Division will process and properly dispose of it.

i. The DPW will be responsible for transportation and disposal costs for transformers containing or contaminated with PCBs.

12. LIGHT BALLAST REMOVAL.

a. All light ballasts are assumed to contain PCBs unless otherwise marked.

b. All light ballasts except those marked as "NO PCBs" shall be brought to the HWSF for disposal within 24-hours of removal.

c. Once light ballasts are received at the HWSF, they will be collected in a community drum until it is full. Each unit or directorate is required to complete a "What Are You Turning in (WAYTI) Sheet," DPG 44E Form, when turning in light ballast for disposal. Units will be billed for their portion of the disposal cost.

13. SPILLS DEFINED. "Spills" can be defined as intentional and unintentional spills, leaks, and other uncontrolled discharges of PCBs where the release results in any quantity of PCBs running off or about to run off the external surface of equipment or other sources of PCBs, as well as the contamination resulting from a spill.

14. SPILL NOTIFICATION. All PCB spills shall be immediately reported to the Dugway Proving Ground Fire Department by dialing 911. Because of the potential danger to human health and the environment, only hazardous material and waste management experts will be authorized to clean PCB spills. The Dugway Proving Ground Fire Department shall immediately notify the Dugway Environmental Division PCB Project Manager and/or Spill Response Coordinator of any reported PCB spills. Ultimately, Dugway Environmental Division shall be responsible for reporting the spill to the state Utah Department of Environmental Quality (UDEQ) Emergency Spill Reporting Line (1-801-536-0200) , Environmental Protection Agency (EPA) Region 8 Office of Prevention, Pesticides and Toxic Substances and whenever required to the National Response Center (1-800-424-8802) in conformance with 40 CFR 76 1.125 Requirements for PCB Spill Clean-up.

15. PCB SPILL CLEAN UP PROCEDURES.

a. PCB trained personnel will use safety equipment according to the MSDS and 29 CFR Part 1910.1200. Clean-up procedures will be accomplished in accordance with 40 CFR Part 761 Subpart G and DPG Regulation 200-1.

b. General spill supplies, such as socks, rags, brooms and absorbent materials can be used in the event of a spill. However, the PCB contaminated waste generated during clean-up must be disposed of IAW 40 CFR 761.61. All items used to clean-up PCB material will be immediately placed in an approved closed, leak proof container with accumulation date after use and transported to the HWSF for disposal within 24 hours or the following work day. PCB contaminated waste may include solvents, rags, gloves, booties, and other disposable "Personal Protective Equipment (PPE)."

16. SHIPPING AND DISPOSAL. Shipping and disposal of PCB containing material(s) shall be the responsibility of the DPW Environmental Division and may be accomplished through the Defense Reutilization and Marketing Office (DRMO) for hazardous waste disposal. Shipment of PCB containing material(s) requires completion of a Uniform Hazardous Waste Manifest (UHWM) and transportation by a hazardous waste transporter certified by the Department of Transportation.

17. RECORDKEEPING. All analytical results, MSDSs, UHWMs and shipment documents shall be kept in accordance with 40 CFR Part. The Dugway Environmental Division shall maintain at the HWSF, any written records of hazardous waste shipment s for at least three years from the date the waste was accepted by the initial transporter. Other documents including test results, waste analysis or other determination must also be retained by the Dugway Environmental Division. Record keeping requirements for PCB Spill Clean-up will be in accordance with 40 CFR 761 Subpart G and the records shall be maintained by Dugway Environmental Division.

DISTRIBUTION:

SJA

DPW

DES Fire Department DPW Contractors Safety Office

MEDCOM

DPTM

Deputy Garrison Manager Garrison Manager image1.wmf