Document 0JBvQeNONEKNEN8B23QoxEmBm

Prefabricated transformer vault solves problem of Providing Temporary Storage for PCB Transformer Fluid By JOHN H. MOORE, Etectro-Test Inc . Sen Ramon, CA The Toxic SubM.tnccs Control Act (TSCA) enacted by Con has been manufactured under a va riety of brand names, but has come gress in 1976 imposes rigid restric to be referred to gcncrically as tions on the handling, packaging, askarcl transportation, use, storage, and TSCA regulations classify trans disposal of any material containing, formers containing KB into two or having come in contact with, categories; compliance require polychlorinated biphenyl (PCB); ments and the owner's potential lia KB has been determined to be bility vary with the particular cate highly toxic to humans and other gory: forms of animal life. The initial PCB transformer--any trans TSCA regulations regarding KB former that contains KB in a con appeared in the Federal Register centration of S00 ppm or more I cbruary 17. 1978. and were re PCB-contaminatcd transform vised in 1979; this revision notably er--any transformer that contains supplemented the original regula SO ppm or more, but less than 500 tions with more stringent require ppm, of KB. Transformers con ments.* taining KB in concentrations be A major use of PCB has been as low SO ppm are considered to be a coolant and dielectric insulating non-PCB items exempt from TSCA medium for liquid-cooled trans regulations. formers installed indoors and in TSCA regulations prohibit re other locations where only a high- building a KB transformer; KB fire-point coolant can be used in transformers in need of rebuild conformity with the National Elec must be scrapped. If the transform trical Code. KB transformer fluid er has been retrofilled with a non- KB fluid, and documented to be a *Sc "Ik)** ISCA CluiMn Affect ike Owners of I H|w4-C'nutcd r.htcffical T;Horffnem." PU I/S/7S, p 19. Ilk #0510. KB-contaminated transformer at least 90 days following retrofill. then rebuilding is permitted, l iquid removed from KB irunsformcrt must be taken immediately to an Environmental Protection Agency (EPA)-approved incineration dis posal facility for ultimate deposi tion; storage and reuse of the K B is not permitted. TSCA regulations notwithstand ing, there are no EPA-approved liq uid KB disposal facilities in exis tence, although three facilities have been constructed and are awaiting EPA approval and licensing I vert as these disposal facilities arc grad ually brought on stream, they will not be able to immediately di>pe of all of the KB that is now jw.ui ing final disposition. Temporary storage while awaiting dispovil ts therefore permitted, provided th.ii such storage is in an FPA-approved storage facility. To qualify a> .in EPA-approved storage facility, the facility must meet the requirement given in the section. **EPA K H Storage Requirements." Electro-Test Inc. is an indepen dent company offering engineering. EPA PCB STORAGE REOUREMENTS Storage facIHtleo she* conform to the foAowtng: 17E for liquid PCB, and DOT 17C tor PCB nonaqurts Tha storage aim must bt above the Novation ol the 100 year flood lavaI. Th storage fadfity must heve weMa and roof capable of keeping out rain. Tha floor must be strong enough to hoid the toed without cracking. Tha containment area must be provided with a continu ous curb at teas! 6 in. high. Tha Boor and containment curb aha* be continuoue. heve no laws or cracks, and ba otherwiao impervious to Hquid penetration. e Volume of the containment aree shall ba at least twice the volume of the largest containsr stored therein, or 25 percent of the aggregate volume of the stored containers, whichever is greeter. Containers shad conform to tha foowing: PCB containers stored within the fadfity must comply with Deparlmsnt of Transportation (OOT) specification Containers must be labsled in accordance with Title 40 761.44 Annex VI (Fader* flsgwrer. February 17. 1978 Part V) and identified as to the date thsy wars placed m storage. The following record-keeping requirements must be obeerved: e necords are required for any fadfity that contains 45 kilograms (99.4 lb) or mora of PCBchamical substances These records must be kept for 5 years after fie facility has esassd to contain 45 kg of PCB matsrialt Records must be updated ennuefiy and be current at calendar-year and. giving dales whan PCBa were removed from service and weight (in Mograme) of such PC8s. name of owner or operator of faeffty from which the PCB was removed, end total quantity of PCB remaining m gee Other: PCB material stored for disposal before January i 1963, must ba removed from storage and disposed of by January 1. 1964. HONS 015007 rut *oe to FEBRUARY 19. 1981 PIAN1 . Ptecast transform* vaults can be obtained in a variety of sizes on short notice They are offered with or without cover and can be e* tended with optional extension rings if adtilionel height is needed. They can be easily relocated with the proper handling equipment and have resate value when there is no longer a need (or temporary PC8 storage. Unit shown was purchased for $500. including delivery and unloading DOT/ EPA-approved drums containing PCB art loaded four to a pallet and stacked two pallets high: sixteen 55 gel drums can be accommodated easily. Because me vault is located indoors, it could legally accommodate far more stacks of drums, if the vault is interpreted to be a 5 It high indoor concrete dike, and stilt meet EPA. requirements lor minimum permissible containment volume. Loaded pallets are lowered into me vault by a fork lift truck equipped with eppropriete attachments. COMPANION Of PROPOSED STORAGE FACILITY ALTERNATIVES Preceet Vault Block Masanry er Canarcla Dlku Com lnataBation Craft Requirement $500 Non. $1500-52500 Mason or form carpenter and trowel trade Portability Ym No--requires demolition nwjMCaeabWy Ym None SaJveQa Value *500 None--must be demolished et addition al expense laboratory, and field services on major electrical equipment to in dustrial. utility, and commercial clients in the western United States. At the time the TSCA regulations went into effect, F.kctro-Tesl had on hand at its San Francisco facility several hundred gallons of PCB. The PCB had been accumulated from residual left over from sam ples sent in for laboratory analysis and from transformers that had been retrofitted with rton-PCB flu id. There was an immediate need for a storage facility that would meet EPA requirements quickly and at reasonable cost. Because indoor floor space was available, a decision was made to locate the storage facility inside, thereby simplifying construction and reducing the cost. This decision also minimized installation time and potential liability under the TSCA regulations. Three approaches were consid ered. One proposal involved con structing a concrete-wall dike on the existing concrete floor. This ap proach would involve saw-cutnotching the existing slab, roughing and sealing the wall-floor interface, constructing a form, placing rein forcing steel, pouring the concrete, and stripping form'. alter curing. Following stripping of the forms, a sealant would haw- to be applied to the inner surfaces An alternative approach involved erecting a concrete block dike; this method would also require notching and roughening the existing slab. Steel reinforcing dowels would have to be placed in the block cells, the cells would have to be filled with mortar, and a sealant would have to be applied to the inner walls of the dike. The third option, the solution that was applied, was to use a pre cast concrete transformer vault. Such vaults come in a variety of sizes, are portable and readily relo catable with the proper material handling equipment, arc relatively inexpensive, and can be obtained on short notice. They are offered with or without cover, making them suit able for outdoor use if desired Extension rings that permit the height to be extended in 12 or 1A in increments are offered for the vault that was chosen In addition to providing the quickest solution and thereby minimizing the company's potential liability in the event of a leaking container--the transformer vault proved to be the most economical solution. A comparison of costs and benefits for the three options arc given in the section. "CompuT^n of Proposed Storage Facility \lternatives." Because the vault w,is to be located indoors, and the baMc ami was sufficient for the comp.uiv\ needs, it was purchased wuh.<ot cover or extension rings. The vault weighs 12,000 tb. With sixteen <5 gallon drums of askarc). weight ,u the loaded vault is about 2H.0tX) lb It was determined that the plant's t in. thick concrete floor could c.imK withstand the loading. Cost of the vault, including delivery .md un loading at the site, was $500 The askarel liquid to be placed m storage is packaged in IXrpiirtmem of Transportation/EPA-approved 55 gal DOT 55E drums PCB con taminated solid materials I w iping cloths, adsorbents, etc ) are pack aged in open-top 30 gal DOT 30C drums. All storage containers and the exterior of the storage facility are labeled as required by TSC \ regulations, and records are kept in accordance with TSCA EPA approval of the storage fa cility was quick in coming; in fact, the vault was installed and approv.il was obtained in less lime than it would have taken to install either form of dike and Have it ready for inspection by TSCA authorities The EPA compliance officers who inspected the facility satisfied themselves that no PC B could enter the environment and that records were in order. They also took photo graphs of the storage facility for documentation. A letter of compli ance was received from l.PA 2 weeks after the inspection For eowplkaestary eapy el IMo article chela 259 an peat ear* 11# m FtAMT ENGMCEMN9 m FEBMUAffY 19, 1961 HONS 01500a os>o