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Annual PCB Documentation Deadline

Posted on 6/10/2014 by Anthony R. Cardno

This week, LionNews continues to examine the ongoing cycle of Federal and State reporting requirements under major US EPA regulatory programs. In previous editions, we addressed Tier I and Tier II chemical inventory reports, annual Greenhouse Gas (GHG) reporting under the Clean Air Act, and Toxic Release Inventory (TRI) disclosures required under EPCRA.
 
At facilities that use or store items that contain polychlorinated biphenyls (PCBs), the management standards at 40 CFR 761 require employers to document their previous year’s PCB-related storage, shipping, and disposal activities each year before July 1. While employers are not required to submit this documentation to any Federal or State agency, the records must be available for inspection by authorized EPA representatives during normal business hours. [40 CFR 761, Subpart J, "General Records and Reports"]
 
Facilities With PCBs and PCB Items in Service or Projected for Disposal
 
PCB items are defined as “any PCB Article, PCB Article Container, PCB Container, PCB Equipment, or anything that deliberately or unintentionally contains or has as a part of it any PCB or PCBs.” [40 CFR 761.3]
 
Documentation is required for any facility using or storing at any one time:
 
  • At least 45 kilograms in such PCB items;
  • One or more PCB transformers; or
  • Fifty or more PCB large high- or low-voltage capacitors.
These facilities must keep two types of documentation: the Annual Records and the Written Annual Document Log.
 
Caution PCB environmental hazard labelAnnual Records
 
The Annual Record must include:
 
  • All signed manifests generated by the facility during the calendar year;
  • All Certificates of Disposal received by the facility during the calendar year; and
  • Records of inspections and cleanups performed in accordance with 40 CFR 761.65(c)(5).
Written Annual Document Log
 
The written annual document log must include:
 
  • The name, address, and EPA identification number of the facility;
  • The calendar year covered by the document log;
  • The unique manifest number of every manifest generated by the facility during the calendar year and certain details from each manifest, including data on identification, weight, and dates of removal from service, transport off site, and disposal (if known);
  • The total number by type of PCB articles/containers and total weight in kilograms of PCBs in articles/containers placed into storage for disposal or disposed of in the calendar year;
  • The total weight in kg of any PCBs and PCB items remaining in service at the end of the calendar year;
  • Total number of PCB transformers and capacitors, along with the total weight of PCBs therein, remaining in service at the end of the calendar year;
  • Record of all phone calls made to confirm receipt of PCB waste transported by independent transporter; and
  • If PCB items with concentrations of 50 ppm or greater are distributed in commerce for reuse, identification and contact information for the item and the person it was distributed to (along with date of transfer and serial numbers).
Others Who Must Document
 
In addition to the above, the following facilities that use, store, or dispose of PCBs must also complete the annual documentation requirements:
 
  • Disposers and commercial storers of PCB waste;
  • Incineration facilities;
  • Chemical waste landfill facilities; and
  • High-efficiency boiler facilities.
Lastly, PCB storage or disposal facilities must collect and maintain all documents, correspondence, and data provided by or to any State or local government agency that pertain to the storage or disposal of PCBs at the facility. This includes copies of any applications and related correspondence in regard to wastewater discharge permits, solid waste permits, building permits, or any other permits or authorizations.
 
The annual records and written document logs described above must be kept for at least three years after the facility ceases using or storing PCBs and PCB items.
 
Are you the go-to person for all things EHS at your facility? Understanding the air, water, and chemical regulations that apply to your facility will help you communicate clearly and confidently with your organization and better defend your business against costly fines, penalties, and future liability. Lion’s Complete Environmental Regulations Workshop is presented nationwide and covers the critical elements of the major EPA programs that affect industrial facilities every day.

Tags: Act, Air, Clean, EPA, EPCRA, reporting and recordkeeping

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