University Of South Carolina
Department of Environmental Health and Safety
Polychlorinated Biphenyls (PCB) Management Program
Table of Contents:
1. PCB Management Program 3
1.1. PCB Regulation 3
1.1.1. Electrical equipment containing PCBs is classified in the following manner: 3
1.1.2. Liquids (that are not used in electrical equipment) containing PCBs are classified as follows: 3
1.1.3. Spill Material (that are not used in electrical equipment) containing PCBs are classified as follows: 3
1.2. Transformers 4
1.2.1. PCB Locations 4
1.2.2. PCB Labeling 4
1.2.3. PCB Inspections 4
1.2.4. PCB Sampling 4
1.2.5. PCB Servicing and Retrofil 5
1.2.6. PCB Leaks and Cleanup 5
1.3. PCB Ballasts 6
1.3.1. Ballast Handling 6
1.4. PCB Laboratory Waste 6
1.4.1. Waste Handling Procedures 6
1.4.2. Waste Disposal 6
1.4.3. PCB Marking 7
Appendix A 8
PCB Inspection Checklist for Transformers 9
PCB Inspection Checklist for Laboratories 9
PCB Marks 10
Appendix B 11
1. PCB Management Program
1.1. PCB Regulation
Polychlorinated Biphenyls (PCBs) are regulated by the Toxic Substances Control Act (TSCA ) of 1976 and The Code of Federal Regulations (40 CFR, part 761). PCB’s are very stable and remain in the environment for a long time. Additionally, they have been found to be extremely hazardous to human health.
Because of their stability and other chemical properties, PCBs have been widely used in electrical equipment. The following are examples of items that may contain PCBs:
1. Transformers
2. Capacitors
3. Vacuum pumps
4. Switches
5. Voltage Regulators
6. Fluorescent light ballasts
1.1.1. Electrical equipment containing PCBs is classified in the following manner:
PCB – Equipment containing fluid with a concentration of 500 ppm or greater is considered PCB equipment
PCB-Contaminated - Equipment containing fluid with a concentration of 50 ppm but less than 500 ppm is considered PCB contaminated equipment
Non-PCB - Equipment containing fluid with a concentration of less than 50 ppm non-PCB equipment
1.1.2. Liquids (that are not used in electrical equipment) containing PCBs are classified as follows:
PCB – Liquid with a concentration of 50 ppm or greater is considered PCB liquid
Non-PCB – Liquid with a concentration of less than 50 ppm is considered PCB contaminated equipment, but is still regulated by TSCA
Non-Detectable – Liquid with a concentration of less than 2 ppm is considered non-detectable
1.1.3. Spill Material (that are not used in electrical equipment) containing PCBs are classified as follows:
Liquid spills containing any amount of PCBs are regulated by TSCA and must be disposed of as PCB waste.
1.2. Transformers
1.2.1. PCB Locations
The University of South Carolina has four transformers that are contaminated with PCBs. They are located at the following areas:
1. Columbia Hall
2. West Energy
3. East Coliseum
4. West Coliseum
1.2.2. PCB Labeling
Each transformer that contains greater than 500 ppm PCBs must be labeled with a mark that identifies it as a PCB containing item. (Appendix A)
Any drum containing greater than 50 ppm PCBs must be labeled with a mark that identifies it as a PCB containing item. A sample of the PCB mark may be found in appendix A
Additionally, the entrance into any area where PCB items are contained must be labeled with a PCB mark. These markings must be easily visible when entering the area.
1.2.3. PCB Inspections
All PCB Transformers must be inspected monthly for leaks. All inspections must be documented on the PCB Inspection Form (Appendix A), and maintained on site for three (3) years.
All PCB equipment that has been taken out of service and will be reused must be inspected at the same frequency as an in-service item. All inspections must be documented on the PCB Inspection Form (Appendix A), and maintained on site for three (3) years.
All PCB items that have been taken out of service and are being stored for disposal must be inspected every 30 days. All inspections must be documented on the PCB Inspection Form (Appendix A).
1.2.4. PCB Sampling
The University will sample all PCB containing transformers annually. Initial sampling will be done on each transformer to determine the PCB levels at each sampling port. After sampling, analysis results will be analyzed to determine which sampling port yields the highest PCB concentration. The PCB management plan will be revised at that time with the relative concentration of PCBs at each sampling port. Future samples will be taken from the port with the highest PCB levels to ensure that 500 mg/kg (ppm) PCBs is not exceeded.
All samples will be analyzed by a licensed analytical laboratory. Gas chromatography is the preferred EPA method for PCB analysis.
1.2.5. PCB Servicing and Retrofill
If a transformer exceeds a concentration of 500 ppm it must be marked as a PCB transformer. The University currently has no PCB transformers. In order to prevent reclassification of any transformer as a PCB transformer, each transformer will be retrofilled as soon as the PCB level exceeds 400 ppm.
Upon completion of retrofilling, if sampling results indicate that the PCB concentration has been reduced to less than 50 ppm the transformer may be reclassified as a non-PCB item. Once this has been achieved with successive retrofilling, each transformer will be retrofilled as soon as the PCB level exceeds 40 ppm to prevent that transformer from being reclassified as a PCB contaminated item.
In order to continue to improve our environmental compliance, all servicing activities that are done to PCB items, including draining, refilling, topping off and retrofilling must be done with fluid that contains no PCBs.
1.2.6. PCB Leaks and Cleanup
Any leaking PCB or PCB-Contaminated electrical equipment must be repaired or replaced immediately. Until the repair or replacement is accomplished, any leaking fluid must be contained and daily inspections must be done to verify that full containment is being achieved. During an active leak, any drains or other areas where PCB oil may enter the environment must be completely sealed to prevent environmental impact.
The initial inspection in which the leak was detected, all measures that were taken to contain the leak, all activities that were performed to repair the leak and all follow-up inspections must be documented on the PCB Inspection Form (Appendix A).
Any liquid that spills from a PCB or PCB contaminated transformer must be cleaned up immediately using vermiculite and a shovel or scoop. All spill materials must be contained in a bucket or other leak-proof container. Each container into which spill clean-up waste is placed must be marked with the following information:
1. The words “PCB spill clean-up materials”
2. The name of the person who generated the waste
3. A contact phone number of the individual(s) who cleaned up the spill.
4. The place where the spill occurred and the waste was collected.
All materials from the clean-up must be disposed of as PCB waste. Contact Environmental Health and Safety or the hazardous waste manager for instructions regarding disposal. (Appendix B)
1.3. PCB Ballasts
Ballasts and light fixtures that are attached to ballasts may contain polychlorinated bi-phenyls (PCBs) and are regulated under the Toxic Substance Control Act. These items must be collected and recycled.
1.3.1. Ballast Handling
Ballasts must be handled in a way that prevents the release of any material into the environment. When handling ballasts take the following precautions:
1. Don Personal protective clothing (PPE), including the following:
a) Nitrile or neoprene gloves.
c) Goggles or face shield.
The following types of ballasts must be collected for recycling:
1. PCB Ballast
2. Non PCB Ballasts
3. Capacitors
4. 4ft - 2 bulb Lamp Fixtures
5. 4ft - 4 bulb Lamp Fixtures
6. 8ft - 2 bulb Lamp Fixtures
7. 8ft - 4 bulb Lamp Fixtures
8. HID Fixtures
Note: Please see the Universal Waste Management Plan, document number EHS-M-025, for further information regarding ballast collection and handling. Please contact the Hazardous Waste Manager for a copy of this plan. (Appendix B)
1.4. PCB Laboratory Waste
1.4.1. Waste Handling Procedures
Laboratory personnel may not handle or generate PCB waste at a concentration greater than 50 mg/kg.
All PCB materials must be contained in secondary containment that is adequate to hold the entire volume of the PCB container. The container that is used for this purpose must be resistant to PCBs and any other chemicals that may be applicable.
1.4.2. Waste Disposal
Prior to disposal all PCB containing waste must be analyzed to determine the concentration of PCBs in mg/kg in the waste container. This analysis may be done through knowledge of process or it may be done through a certified laboratory.
PCB concentration must be provided in writing when releasing the PCB containing waste to the waste disposal team.
Contact the Hazardous Waste Manager for disposal of all laboratory waste that contains PCBs.
1.4.3. PCB Marking
The entrance into any area where PCB items are contained must be labeled with a PCB mark. (Appendix A) These markings must be easily visible when entering the area.
Appendix A
Forms and Labels
PCB Inspection Checklist for Transformers
1. / Is the transformer free of leaks? / Yes / No / N/A
2. / Is the area around the transformer free of any uncapped drain valves, open floor drains, floor expansion joints, open sewer drains or any other openings that would allow potential leaks to escape? / Yes / No / N/A
3. / Are the drain valves, floor drains, expansion joints, sewer lines or other
openings blocked from potential leaks? / Yes / No / N/A
4. / Is the flooring free of cracks? / Yes / No / N/A
5. / Does the area have adequate roofing and walls to prevent storm water
from entering? / Yes / No / N/A
Inspector’s Printed Name Inspector’s Signature Date
PCB Transformer Inventory
Serial # and CONTAINER Identification # / PCB Cont /Non-PCB / date on label
¨ SN – 40923 / Columbia Hall Basement (196 gals) / PCB Contaminated
¨ SN – H886513 / West Energy Facility Basement (320 gals) / PCB Contaminated
¨ SN – PCR-60101 / USC Coliseum West (1,790 gals) / PCB Contaminated
¨ SN – PCR-60111 / USC Coliseum East (1,790 gals) / PCB Contaminated
¨ SN – PCV-0535-01 / School Of Nursing (226 gals) / PCB Contaminated
¨ SN – G855748 / Thomas Cooper Library (385 gals) / Non-PCB
¨ SN – PDV-1108-01 / Gambrell Hall ( 207 gals ) / PCB Contaminated
Explain any negative responses or corrective actions that were taken: ______
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PCB Inspection Checklist for Laboratories
Principle Investigator Inspector’s Printed Name
Laboratory/Room Number Inspector’s Signature
Phone Number Date
Inspection Criteria1. / Is the container closed? / Yes / No / N/A
2. / Is the container free of leaks? / Yes / No / N/A
3. / Is the container stored in secondary containment? / Yes / No / N/A
4. / Is the secondary containment vessel in good condition and free of cracks and holes? / Yes / No / N/A
5. / Is the secondary containment vessel adequate to contain 100% of the volume of the PCB container? / Yes / No / N/A
6. / Is the area around the container free of any drain valves, floor drains, expansion joints, sewer lines or other openings that would allow potential leaks to escape? / Yes / No / N/A
7. / Are the drain valves, floor drains, expansion joints, sewer lines or other openings blocked from potential leaks? / Yes / No / N/A
8. / Is the flooring free of cracks? / Yes / No / N/A
9. / Does the area have adequate roofing and walls to prevent storm water from entering? / Yes / No / N/A
10. / Are PCBs and PCB-Contaminated items disposed of within one year of the date they were placed into storage? / Yes / No / N/A
Explain any negative responses or corrective actions that were taken: ______
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PCB Signs
Large PCB Mark Small PCB Mark
Appendix B
Contact Information
Contact Information
USC Environmental Health and Safety
Environmental Compliance Officer
Roddy Whitaker
803-777-2839
803-521-5323 Cell
Hazardous Waste Manager
Wesley Seigler
803-777-1935
803-727-5706 Cell
EHS-M-026 Issued Date: 8/10/2011
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