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Enron Mail |
Sue - nicely done. Are we still struck with no real sampling guidance for
the turbine other than sample all surfaces for teh verification sampling??? Assume that we do not have large surfaces, only many, many small and/or irregular surfaces..??? Susan Fernandez 12/10/99 01:38 PM To: Louis Soldano/ET&S/Enron@ENRON cc: William Kendrick/OTS/Enron@ENRON Subject: PCB Decontamination of Turbine Lou - Under the PCB Mega rule, self-implementing decontamination of PCBs (i.e., cleanup without verification sampling) is only available for PCB containers; movable equipment used in storage areas, tools and sampling equipment; non porous surfaces contaminated with mineral oil dielectric fluid; and air compressor systems. 40 CFR 761.79©. EPA has yet to provide written guidance on its PCB Mega Rule decontamination regulations. Based on my reading of the regulations, a contaminated turbine must be decontaminated in accordance with the measurement-based decontamination methods. The measurement-based decontamination procedures are not prescriptive. The simply require that the non porous surface be cleaned by a method that reduces the surface concentration to less than or equal to 10 micrograms PCBs per 100 square centimeters if the equipment is decontaminated for unrestricted use or less than 100 micrograms PCBs per 100 square centimeters if the material is to be disposed of in an industrial smelter after decontamination. 40 CFR 761.79(b). I assume that the most efficient method of "cleaning" a turbine would be to drain the turbine of all free flowing liquids and then wipe or soak all surfaces that were exposed to PCBs with or in solvent. If a solvent is used to clean the surfaces, the regulations require that it have a solubility of PCBs of 5% or more by weight (other parts of the regulations recommend Kerosene, diesel fuel, terpene hydrocarbons and a mixture of terpene hydrocarbons and terpene alcohols). The solvent can continued to be used until it reaches a concentration of 50 ppm PCBs. 40 CFR 761.79(d). Once the surfaces have been wiped clean with the solvent, verification sampling can be done using the standard wipe test at locations on the turbine selected under Subpart P (which includes the sampling of small and irregular shaped surfaces). If the measurements show the surfaces have been cleaned to < 10 ug/100 cm2, the equipment is available for unrestricted use. 40 CFR 761.79(b)(3)(1)(i)(A). Persons participating in the decontamination activities must use protective clothing or equipment to protect against dermal contact of inhalation of PCBs or materials containing PCBs and take precautions not to release PCBs into the environment from the decontamination area. 40 CFR 761.79(e). Written records of the sampling procedure used to verify that the equipment has been decontaminated and sampling results must be maintained for 3 years. The regulations do not require that a written record of the procedure used to decontaminate the material be generated or maintained. 40 CFR 761.79(f). Decontamination wastes and residues that are generated by rinsing or soaking contaminated surfaces with solvent can be disposed of at their existing concentration, which means that hydrocarbon solvents used which contain <50 ppm PCBs can be marketed as used oil. 40 CFR 761.79(g). The non-liquid cleaning materials (e.g., rags) and personal protective equipment, regardless of concentration, can be disposed of at a municipal landfill, a industrial non hazardous waste facility, a RCRA subtitle C facility permitted to accept PCBs or a TSCA PCB disposal facility. 40 CFR 761.79(g)(6). Finally, notification to the EPA is not required. Verification sampling procedures and analysis must be available for EPA review when requested. 40 CFR 761.79(f). A very simple procedure would be: 1. All persons participating in the decontamination activity must wear personal protective equipment that protects from skin exposure that prevents inhalation of PCBs. 2. Drain turbine of all free flowing liquids. 3. Wipe all surfaces or parts the would or could have been in contact with liquids with rags soaked in clean, unused solvent such as Kerosene. 4. Collect all personal protective equipment and rags used during the decontamination process in drums for disposal. 5. Collect all used solvent and appropriate containers (Drums?). Collect sample of solvent and have it tested to determine disposal options. 6. Sampling cleaned equipment by collecting wipe samples at locations determined under Subpart P of the regulations. 7. If verification samples indicate equipment is contaminated at levels less than or equal to 10 ug/100 cm2 PCBs, the equipment is released for unrestricted use. If samples indicate greater levels of PCBs, cleaning as described above must be repeated with follow-up verification sampling. Call me after you have had a chance to look at this. Sue
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