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(c).  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