PCB HANDBOOK

Prepared by GLENN L. KUNTZ PLEXUS ENGINEERING GROUP LTD. 4900 SEMINARY ROAD ALEXANDRIA, VIRGINIA 22311 for RURAL ELECTRIC RESEARCH NATIONAL RURAL ELECTRIC COOPERATIVE ASSOCIATION 4301 WILSON BOULEVARD ALEXANDRIA, VIRGINIA 22203-1860

This publication is designed to provide accurate and authoritative information regarding its subject matter. It is intended to be used as a guide and not as a substitute for the regulations. Every reasonable effort has been made to provide reliable information but the author and the publisher cannot assume responsibility for the validity of all materials or for the consequences of their use.

PCB Handbook Table of Contents

TABLE OF CONTENTS Executive Summary: PCBs and the Electric Cooperative 1 Introduction 1.1 Background 1.2 Why Are PCBs Controlled? 1.2.1 Environmental Consequences 1.2.2 Human Health Effects 1.3 Regulatory Background 2 PCB Equipment Requirements 2.1 PCB Transformers 2.1.1 Use 2.1.2 In or Near Commercial Buildings 2.1.3 Enhanced Electrical Protection 2.1.4 Servicing 2.1.5 Marking 2.1.6 Inspection 2.1.7 Storage for Disposal 2.1.8 Disposal 2.1.9 Newly Discovered PCB Transformers 2.2 PCB-Contaminated Electrical Equipment 2.2.1 Use 2.2.2 Servicing 2.2.3 Marking 2.2.4 Inspection 2.2.5 Storage for Disposal 2.2.6 Disposal

2.3 Non-PCB Transformers 2.3.1 Use 2.3.2 Servicing 2.3.3 Inspection 2.3.4 Marking 2.3.5 Storage 2.3.6 Disposal 2.4 Non-PCB Items 2.5 Voltage Regulators: New Rules 2.6 Voltage Regulators, Switches, and Sectionalizers 2.6.1 Use 2.6.2 Servicing 2.6.3 Inspection 2.6.4 Marking 2.6.5 Records 2.6.6 Storage for Disposal 2.6.7 Disposal 2.7 Circuit Breakers, Reclosers, and Cable 2.7.1 Use 2.7.2 Servicing 2.7.3 Inspection 2.7.4 Marking 2.7.5 Records 2.7.6 Storage for Disposal 2.7.7 Disposal 2.8 PCB Capacitors 2.8.1 PCB Large Capacitors 2.9 Heat Transfer Systems 2.9.1 Use

Page 2 of 14

PCB Handbook Table of Contents

2.9.2 Servicing 2.9.3 Inspection 2.9.4 Marking 2.9.5 Records 2.9.6 Storage for Disposal 2.9.7 Disposal 2.10 Hydraulic Systems 2.10.1 Use 2.10.2 Servicing 2.10.3 Inspection 2.10.4 Marking 2.10.5 Records 2.10.6 Storage for Disposal 2.10.7 Disposal 2.11 PCB Testing 2.12 Equipment Modification and Reclassification 2.12.1 Modification 2.12.2 Reclassification 3 Records 3.1 Why and How a Cooperative Should Keep Records 3.2 Annual Records 3.3 Annual Document Log 3.3.1 Stored or Transported PCBs 3.3.2 PCB Equipment in Use 3.3.3 Record Keeping Mechanics 3.4 Potential EPA Record Keeping Penalties 3.5 Records of PCB Articles in Storage for Reuse 3.6 PCB Transformer Inspections and Maintenance

3.7 Commercial Storers of PCB Waste 4 Notification and Manifesting 4.1 Waste Generator Identification 4.2 Manifests 4.3 Manifest Discrepancy Report 4.4 Exception Report 5 Labeling, Marking, and Placarding 6 Transportation Requirements 6.1 Multiagency Regulation 6.2 Hazardous Material Transport Marking 6.3 DOT PCB Regulations 6.3.1 Classification 6.3.2 Packaging 6.4 Shipping Papers 6.5 Packaging Requirements 6.5.1 Marking Nonbulk Packages 6.5.2 Marking Bulk Packages 6.6 Employee Training 6.6.1 Hazmat Employee Training 6.6.2 Driver Training 6.6.3 Training Records 6.7 Emergency Response 6.8 Dot Registration and Fees 7 PCB Storage 7.1 Storing for Reuse

Page 3 of 14

PCB Handbook Table of Contents

7.2 Temporary Storage for Disposal 7.3 Long-Term PCB Storage 7.4 General Requirements for PCB Storage Facilities 7.4.1 Spills and Cleanups in Storage 7.5 Storage Area Operational Requirements 8 Spill Prevention, Control, and Countermeasures (SPCC) Plan 8.1 Objective 8.2 SPCC Plan Requirements 8.3 SPCC Plan Content 8.3.1 Secondary Containment 8.3.2 Cleanup Equipment 8.3.3 Security 8.3.4 Training 8.3.5 Drills 9 PCB Disposal Methods 9.1 General Disposal Rules 9.2 Chemical-Waste Landfills 9.3 High-Temperature Incineration 9.4 High-Efficiency Boilers 9.5 Alternative Methods of Disposal 9.6 Used Oil (Less Than 50 ppm PCB) 10 CERCLA Liabilities 10.1 Who Is Liable? 10.2 Corrective Action 10.3 Possible Defenses

11 PCB Spill Cleanup 11.1 Fire-Related Incidents 11.2 Transformer or Capacitor PCB Spills 11.3 PCB Spill Cleanup Equipment and Materials 11.4 Reporting of Incidents 11.5 Old Spills and Releases 12 Decontamination 12.1 New in 98 12.2 Performance-Based Standards 12.2.1 Standards for Liquids 12.2.2 Standards for Nonporous Surfaces 12.2.3 Standards for Concrete 12.2.4 Confirmation 12.3 Self-Implementing Decontamination Procedure 12.4 Decontamination Exclusions 13 PCB Bulk Product Waste 13.1 What Is Bulk Product Waste? 13.2 Performance-Based Disposal 13.3 Disposal in Solid-Waste Landfills 13.4 Notification and Record Keeping Requirements 13.5 Risk-Based Disposal 13.6 Daily Landfill Cover or Roadbed Disposal 14 PCB Remediation Waste 14.1 New in 98 14.2 Self-Implementing On-Site Cleanup and Disposal

Page 4 of 14

PCB Handbook Table of Contents

14.3 Notification and Certification for Self-Implementing Cleanup 14.4 Cleanup Levels 14.4.1 Bulk PCB Remediation Waste 14.4.2 Nonporous Surfaces 14.4.3 Porous Surfaces 14.4.4 Liquids 14.5 Performance-Based Disposal 14.6 Risk-Based Disposal Approval 15 Contractor Selection Process 15.1 Need for Care and Caution in the Selection Process 15.2 Transporters 15.3 Decommissioning and Disposal Facilities

Glossary Field Manual for PCB Spill Cleanup Bibliography

ACKNOWLEDGMENT The author gratefully acknowledges the technical assistance provided by Richard W. Sternberg, senior environmental manager at NRECA, and Douglas H. Green of the law firm of Piper and Marbury, Washington, DC.

Page 5 of 14

PCB Handbook Executive Summary

EXECUTIVE SUMMARY: PCBs AND THE ELECTRIC COOPERATIVE

The United States Environmental Protection Agency (EPA) in 1978 first promulgated regulations for control of polychlorinated biphenyls (PCBs), then clarified, strengthened, and extended the regulations in 1998 (in addition to issuing several other revisions, most recently in 1999). The regulations directly affect electric cooperatives, which are likely to still be operating PCB-containing equipment, even though PCBs have not been produced since the early 1970s. The EPA regulations spell out: The conditions under which PCB-containing equipment can continue to be used How to handle PCB spills and leaks How to dispose of PCBs

15250-7954; phone (202) 512-1800; fax (202) 512-2250; www.access.gpo.gov/. EPAs Web site, www.epa.gov/, also provides helpful information. This executive summary can only give a brief overview of the regulations and their implications for electric cooperatives. Readers are urged to consult the sections of the handbook that follow and the rules themselves.

ABOUT PCBs
Polychlorinated biphenyls are a group of chemical compounds that have been used in various concentrations as hydraulic fluid, heat transfer fluid, and insulating fluid in electrical equipment such as capacitors and transformers. At their introduction in 1929, they were widely accepted for their chemical stability, heat resistance, low flammability, and low electrical conductivity. But because they are so stable, they have become almost ubiquitous. As a result of leaks, spills, and careless disposal, they have become distributed in air, water, sediments, and soil around the globeand in the food chain as well. In the 1960s, PCBs were identified as a potential risk to health and the environment. Their presence and concentration in the food chain caused great alarm at the time, and suppliers of PCBs in North America, Europe, and Asia ceased production in the 1970s. Current evidence suggests that PCBs are not as dangerous as many other hazardous substances. Some workers who came in

The regulations are strict, and the penalties for violating themeven accidentally or through ignoranceare severe. Electric cooperatives are no different from manufacturers or large electric utilities in this respect; they are held to the same standards and incur the same penalties. The latest version of the EPAs PCB rules, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions (40 CFR Chapter 1, Part 761) is available from the U.S. Government Printing Office; address Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA

Page 6 of 14

PCB Handbook Executive Summary

direct contact with PCBs developed skin rashes, but no link between PCBs and cancer has been found. Normal precautions are adequate for people who handle PCBs; they should wear disposable coveralls, gloves, and glasses. EPAs strict regulations on PCBs stem not so much from fear of toxicity of PCBs themselves, but of the contaminants that often accompany themhighly toxic compounds such as furans. In two separate incidents, about 3000 people in Japan and Taiwan who ingested rice oil accidentally contaminated with PCBs containing a small amount of furans developed symptoms ranging from general weakness to liver dysfunction.

ABOUT THE HANDBOOK

The PCB Handbook is designed to give the staff members of electric cooperatives the information they need to deal with the complex federal rules for dealing with PCBs, whether in equipment, in waste, or in bulkstate and local agencies PCB rules are not covered. Electric cooperatives obviously dont have the abundant resources of industrial companies or big electric utilities; they often cant afford the specialized staff that many large organizations devote to environmental concerns such as PCBs. Co-op staffers often have to do double or triple duty, dealing with PCB rules as a crucial adjunct to their regular responsibilities. Although the PCB rules are complex, electric cooperative staffers can avoid violating them by observing a few simple guidelines:

Keep meticulous records on your PCBs: when and where you found them; where they are now, whether in use, in storage somewhere, or disposed of; what you did if any leaked or spilled. EPA hands out most of its citations for record keeping violations. Notify your EPA regional office if you discover any PCBcontaining equipment or any leaks. If you are uncertain about what to do, call your EPA regional office for advice. If you are still uncertain after that, call the National Rural Electric Cooperative Association (NRECA) at (703) 907-5500. NRECA may be able to answer you questions; if not, NRECA can refer you to a consultant who specializes in PCB problems and should be able to advise youfor a fee. Keep in mind that your facilities are likely to be inspected by EPA, since PCBs are so common in the electric power industry. Be prepared with adequate records, conveniently available, and with properly labeled equipment and storage areas.

Even those who feel familiar with PCB rules should keep in mind that they are continually changing. EPA promulgated sweeping modifications in 1998, for example. The handbook highlights new and modified rules, and devotes three chapters to new aspects of the 1998 modifications. The chapters in the handbook should provide you with virtually all the information and guidance you need to adhere to the federal rules and avoid costly violations and liabilities. The end of the handbook contains much information of a practical nature: The Glossary will help readers cope with the subtleties of EPA nomenclature. A Field Guide gives a detailed checklist that will help ensure that all necessary steps are taken in the event of a PCB spill.

Page 7 of 14

PCB Handbook Executive Summary

And the Bibliography lists many rules that were referenced in preparing the handbook. A brief disclaimer is in order: It is impossible to cover every aspect of these complex and comprehensive regulations in a handy reference; nevertheless the handbook should be adequate for most situations that an electric cooperative is likely to encounter. The first chapter recounts the history that led to the present PCB rules. The subsequent chapters are organized so that they cover the range of PCB-related activities from identifying PCBs to choosing contractors for transporting and disposing of them. Here is a brief summary of the chapters content. 1 Introduction PCBs, originally highly prized for their stability and low flammability in electrical equipment, have been found to contaminate much of the earth and the inhabitants of the earth. Accordingly, EPA has issued regulations governing their use, storage, and disposal to prevent further contamination. It issued major rules in 1978, 1979, 1982, 1985, 1987, 1988, 1989, and 1998. Other federal statutes and agencies also directly affect electric utilities and their use of PCBs, including the Clean Water Act; the Resource Conservation and Recovery Act (RECRA); the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund; the Occupational Safety and Health Administration (OSHA); and the Department of Transportation (DOT).

2 PCB Equipment Requirements EPA allows the following electrical equipment to continue in use, even though it contains PCBs: Transformers Heat transfer systems Hydraulic systems Electromagnets Switches Voltage regulators Capacitors Circuit breakers Reclosers Cable

EPA attaches certain conditions to continued use, however, depending on the equipments proximity to food or feed and to public spaces and on the concentration of its PCB content. For example, EPA defines a PCB Transformer (the initial capital letter T is in accordance with EPA usage) as one that contains 500 parts per million (ppm) PCB or more. Such transformers may continue in service provided that they are registered with EPA, are marked with PCB labels, and are inspected at regular intervals. They must be removed if they are near food or

Page 8 of 14

PCB Handbook Executive Summary

feed. If they are in or near an EPA-defined commercial building, they either must be removed or must be equipped with electrical protection, depending on the transformer type. EPA designates electrical equipmentincluding transformersas PCB Contaminated if it contains less than 500 ppm but at least 50 ppm PCB. Equipment in this category may be used without restriction, but must be registered with EPA. Finally, EPA designates as non-PCB items any equipment containing less that 50 ppm PCB. Such equipment may be used without restriction. Although EPA singles out transformers for special attention because of the large volume of fluid they contain, other equipment such as capacitors and circuit breakers is specifically regulated, albeit less stringently than transformers. The 1998 modifications to the EPA rules give special attention to voltage regulators, which are now treated more like transformers than they were before. 3 Records Inaccurate or missing records are the number one source of PCB violations. A cooperative would be well-advised to take record keeping seriously; it is not difficult to do, and it can avoid much difficulty. If you have, either in use or in storage, more than a minimal amount of PCB materials, transformers, or capacitors, EPA wants you to maintain an annual document log of information about your cooperative, its in-service PCB Transformers and Capacitors, and its PCB storage, shipment, and disposal activities. The log should also include information about any PCB-Contaminated Electrical

Equipment (>50 but <500 ppm PCB content) that has been taken out of service. EPA requires visual inspection of PCB Transformers (>500 ppm PCB content) periodically, and you must keep records of these inspections. If you find any leaking equipment, you must take corrective action immediately and record information about the action. 4 Notification and Manifesting Electric cooperatives are considered generators of PCB waste if they store, transport, or dispose of PCB materials. They must notify EPA of their activities and obtain a generator identification number from EPA, to be used in all PCB manifests. If, however, a cooperative generates so little PCB waste that is does not need a long-term storage facility, it does not need a generator identification number; instead, it may use the identification 40 CFR PART 761 in its PCB manifests. All generators of PCB waste (PCB spill cleanup material, for example) containing 50 ppm PCB or more must use a manifest system to track and ensure proper handling of the material when it is transported. A cooperative originates a manifest that tracks each shipment all the way to the disposer. The copy signed by the generator, transporter, and disposer becomes part of the cooperatives annual document log. When a shipment is finally disposed of, the cooperative receives a certificate of disposal from the disposer. This too goes into the annual document log. A manifest discrepancy occurs when there is a difference between the quantity or type of PCB designated on the manifest and

Page 9 of 14

PCB Handbook Executive Summary

that actually received by a commercial storer or disposer. If the discrepancy cannot be resolved with the cooperative within 15 days, the storer or disposer must nofify EPA. The cooperative must submit an exception report to EPA if there is any slip-up in the manifest system. For example, if a cooperative does not receive a signed copy of the manifest from the transporter within a specified time period, it must file an exception report. 5 Labeling, Marking, and Placarding Most PCB Articles (>50 ppm PCB), containers, storage areas, and enclosures must be marked with yellow PCB labels. Trucks when hauling PCBs may require labels and placards. The object of labeling is to identify the items clearly to workers who might otherwise accidentally come in contact with them and to fire fighters so they can take precautions appropriate for a hazardous material. EPAs requirements for labeling are clear and easy to follow. With a little attention, a cooperative should be able to avoid penalties for nonobservance. 6 Transportation Transportation of PCBs and PCB Itemswhich cooperatives must utilize whenever they move materials or equipment off site for storage or disposalis regulated under the federal EPA PCB rules, the federal Department of Transportation (DOT) regulations, and various state regulatory agencies. Transportation is also one of the highest risk activities in handling PCBs.

For example, a PCB shipment is governed by DOT regulations if it contains at least 1 lb of PCBs in a concentration of more than 20 ppm. If the shipment contains less than 1 lb PCB, DOT regulations do not apply, even though the concentration may be very high; for such shipments, EPA rules govern if the PCB concentration is 50 ppm or more. Differences exist between DOT and EPA rules for labeling, manifesting, and packaging. The mode of transportation also makes a difference. DOT regulates PCBs more stringently if they are shipped by air or water than if by highway or rail. Transportation by truck over highways is by far the most common mode. DOT considers those who prepare PCBs for transportation and who drive PCB vehicles as hazmat (hazardous material) employees, and requires special training for them. Drivers, for example, must be instructed in such things as the effects of braking, curves, and speed on vehicle stability, the dangers of driving under adverse weather and road conditions, and the procedures to follow in case of a collision, especially one causing a PCB spill. In general, both the cooperative and the transporter are responsible for compliance with the various transportation rules. Fortunately, reputable transporters are familiar with the complexities of PCB transportationhence the importance of choosing the right transportation contractor. 7 PCB Storage EPA regulates both temporary and long-term storage of PCBs and PCB Items. Certain items may be placed in temporary storage areas for up to 30 days. They include nonleaking PCB Equipment; leaking

Page 10 of 14

PCB Handbook Executive Summary

PCB Equipment in nonleaking containers; contaminated soil, rags, and debris in containers; and liquid PCBs at concentrations of 50 ppm to less than 500 ppm in containers. The requirements for temporary storage areas are minimal: the areas and the stored items must be labeled as PCB materials and, for liquid PCBs in containers, a Spill Prevention, Control, and Countermeasures (SPCC) plan must be prepared. After 30 days, such items must be moved to long-term storage facilities, and other PCB Items must be placed in long-term storage facilities at the outset. Long-term facilities must meet certain EPA specifications: they must have roof and walls to protect the stored contents from rain, an impervious floor with a curb and no drains or openings, and other provisions aimed at preventing PCBs from entering the environment. The long-term storage area and its contents must bear conspicuous PCB labels. PCBs and PCB Items may be stored no longer than 1 year in a long-term storage facility. After that, they must be removed to a disposal facility for disposal according to EPA rules. In addition to EPA, many state and local agencies impose regulations on PCB storage. They may be stricter and allow shorter storage time than the EPA rules, and would thus take precedence. A cooperative should check with its state environmental agency to be sure it is in compliance with all rules. If a cooperative has functional, nonleaking PCB Items and doesnt want to dispose of them but rather to store them for reuse, that is permissible. In such cases, EPAs rules for PCB Items still in use apply: avoid storage where there is risk to food or feed, inspect periodically for leaks, keep records, and so forth. They do not need a

special storage area unless they are stored for reuse more than 5 years. 8 Spill Prevention, Control, and Countermeasures (SPCC) Plan

Temporary storage facilities need an SPCC plan. A plan is not needed for long-term stroage because of the provisions for containment that already exist in such facilities. An SPCC plan is intended to minimize the effects of discharge of PCBs on the environment and exposure of personnel. A plan should list a cooperatives sites where a PCB discharge is possible and spell out the cooperatives strategy to contain and remedy a discharge if one should occur. It should contain all the information that might be needed in a hurry in an emergency: the names and contact information for the members of the cooperatives emergency response team and of local emergency response contractors; the chemical composition of any hazardous materials stored, not just PCBs; the provisions for secondary containment of spilled PCBs; the equipment and procedures for cleaning up; and more. 9 PCB Disposal Methods The most common methods for disposing of PCBs are burial in hazardous-waste landfills, high-temperature incineration, and chemical destruction by dechlorination. All methods are closely controlled by EPA. For PCB-Contaminated solids, large quantities of soil and debris from spill cleanup, and decontaminated containers and

Page 11 of 14

PCB Handbook Executive Summary

transformers, landfill is the primary option. Landfill is forbidden, however, as a disposal method for PCB liquids and sludges and for PCB Articles containing 500 ppm PCB or more until they are drained and flushed. All PCB materials may be disposed of by high-temperature incineration. For PCB liquids containing 500 ppm or more, incineration is the only allowed method. Incineration must be done at a high temperature (greater than 1600C) to ensure that not only PCBs, but also any accompanying toxic materials or toxic byproducts, are decomposed into harmless materials. Industrial furnaces, boilers, and incinerators provide the requisite high temperature. What EPA terms high-efficiency boilers are considered adequate for incinerating PCB-Contaminated liquids (50 to <500 ppm); most utility boilers and many industrial boilers fall into the highefficiency category. Chemical destruction disposal methods transform the polychlorinated biphenyl molecules into nontoxic polyphenyls and other end products. A variety of EPA-approved methods are available for chemical destruction. 10 CERCLA Liabilities

generators (including cooperatives) that supplied the waste. EPA may perform the cleanup and bill the parties for the costs. If one of the parties, such as the site owner/operator, goes bankrupt, the remaining parties take up that share of the costs. The moral for cooperatives is: Check potential transporters and disposers with extreme care; make sure they are responsible in their practices and solvent in their finances. 11 PCB Spill Cleanup

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund, authorizes EPA to order a cleanup of sites that can adversely affect the environment and the public. Sites such as a chemical-waste landfills and disposal facilities canand havefallen into this category. Cooperatives can be involved, because EPA holds all parties liable: the owner/operator of the site, transporters that brought waste to the site, and

EPA views spillage or leakage of PCBs and PCB materials as illegal disposal and spells out clearly the actions that a cooperative (or any other responsible party) must take in such an event. Most important, any spill must be thoroughly and rapidly cleaned up. EPA specifies a lengthy series of steps that must be taken to deal with transformer or capacitor spills. It also specifies the equipment and materials that should be on hand to handle spills. PCB Equipment involved in a fire warrants special attention because of the added potential for water used in fire fighting to carry PCBs into the environment. EPA also specifies a procedure for reporting spills. The National Response Center must usually be notified and informed of the nature of the spill and the action taken (or to be taken). 12 Decontamination For some PCB materials, decontamination is an alternative to disposal that the 1998 PCB rule amendments explain and clarify. A cooperative may reuse or sell decontaminated materials; the

Page 12 of 14

PCB Handbook Executive Summary

cooperative may also dispose of materials according to less strict rules if they have been decontaminated. EPA allows either performance-based or selfimplementing decontamination. Performance-based decontamination must meet certain standards for postdecontamination PCB content. It can be used for liquids, nonporous surfaces, and concrete. The material must be sampled after decontamination and records must be kept of the sampling tests. EPA allows such methods as chopping, distilling, filtering, and oil/water separation, scraping, and solvent extraction for performance-based decontamination. Self-implementing decontamination does not require sampling, but it must be done according to EPA-approved procedures, and records of compliance with the procedures must be kept. Self-implementing decontamination can be used for nonporous surfaces in contact with flowing dielectric fluid, containers, movable equipment, tools, and sampling equipment. 13 PCB Bulk Product Waste The 1998 PCB rule amendments introduced a new category of PCB waste: bulk product waste, such as nonliquid bulk waste from demolition of buildings; PCB-containing waste from shredding of automobiles, appliances, or machines; and fluorescent light ballasts contain PCB-Contaminated potting material. Bulk product waste may be disposed of according to performance-based standards (described in Chapter 13) by such methods as incineration, landfilling, and decontamination. Risk-based disposal is sometimes allowed, but getting permission is difficult.

Bulk product waste does not include PCB remediation waste (that is, from cleanups) and most liquids such as heat transfer fluids and waste oil. 14 PCB Remediation Waste Another new category of waste introduced in the 1998 rule amendments is PCB remediation waste: waste containing PCBs as a result of a spill, release, or other unauthorized disposal. The new category includes floors and walls contaminated by PCBs and soil, rags, and other debris generated in a PCB cleanup. To clean up remediation waste, a cooperative may choose between traditional methods and new self-implementing on-site methods. For disposal of remediation waste, several alternative methods are available as well, including self-implementing disposal, performance-based disposal, and risk-based disposal. The level to which remediation waste must be cleaned depends on the nature of the PCB remediation wastewhether it is bulk solid waste, porous, nonporous, or liquid. The great advantage of self-implementing cleanup and disposal is that it does not require EPA approval. The cooperative simply notifies EPA (and state and local agencies, if appropriate) before cleanup begins, describing the nature of the contamination, the sampling procedures and results, and the cleanup plan, and providing a site map. If the EPA does not respond within 30 days, the cooperative can assume that the plan is acceptable and proceed with the cleanup.

Page 13 of 14

PCB Handbook Executive Summary

Liquid wastes in general are not eligible for selfimplementing disposal. For such wastes, the only choice is performance-based disposal according to approved processes such as incineration. Risk-based disposal, in which the required post-cleanup contamination level depends on the occupancy level of the area, requires EPA approval. The applicant must demonstrate to EPAs satisfaction that the method will not present a risk to health or the environment.

Before awarding any contracts, a cooperative should investigate the companies being considered by reviewing references and asking for pertinent information from regulatory agencies and other cooperatives. The cooperative should interview the owners and managers to assess their knowledge and understanding of environmental regulations and liability. Their insurance coverage should be checked. Site visits are appropriate, before and periodically after award of the contract, so that deficiencies in practices and any obvious contamination can be detected. CONCLUSION

15 Contractor Selection Process Selecting contractors is an extremely important step for cooperatives, particularly contractors for transportation and disposal of PCB Articles and materials. This is because a cooperatives liability doesnt end when PCBs go out the door. EPA can hold PCB generators such as cooperatives partially responsible for violations committed by transporters and disposersand if a transporter or disposer goes out of business, the generators must take up that partners share of responsibility. Environmental regulations on PCB use and disposal are complex and sometimes confusing, but for electric cooperatives that use or store PCB Equipment, they must be accommodated. Fortunately, by following simple and straightforward practices, cooperatives are likely to stay out of trouble: keep meticulous records; notify EPA if you find any PCB leaks; if youre in doubt, get expert advice; be prepared for inspections. Keep in mind that expenditures made in following these practices are wise investments if they protect a cooperative from violating the rules, incurring citations and the extra work that inevitably accompanies them, and, most important, paying expensive fines.

Page 14 of 14