Hazardous and Solid Waste

Keeping the Right Records for PCBs

Yesterday we told you about a Connecticut company that paid almost $40,000 to settle claims with EPA that it violated federal polychlorinated biphenyl (PCB) recordkeeping requirements. Specifically, the company allegedly failed to create and maintain annual document logs for several years. Here’s what they should have done to be compliant.

Proper Recordkeeping for the Annual Log

Each owner or operator of a facility (including high-efficiency boiler operations) used for commercial storage or disposal of PCBs and PCB items must maintain annual records and a written annual document log. These recordkeeping requirements cover all PCB handling at each facility and must be prepared for each facility by July 1 covering the previous calendar year.

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These records must be retained at each facility for at least 3 years after the facility ceases using or storing PCBs and PCB items, except that in the case of chemical waste landfills, the records must be maintained for 20 years after the site is no longer used to dispose of PCB wastes.

If the facility ceases commercial PCB storage or disposal operations, the owner or operator must notify the regional EPA administrator 60 days before the facility intends to begin closure.

Annual records (commercial and noncommercial) must include all manifests and Certificates of Disposal from the previous calendar year.

Note: The above recordkeeping requirements do not apply to commercial storers or disposers of PCB waste. The commercial records are basically the same, but the retention periods and information required are different.

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___ Annual records kept 3 years after the facility ceases to use PCB equipment.
___ Copies of all signed manifests.
___ Certificates of Disposal.
___ Annual document logs must be kept if you have:

___ 50 or more capacitors (in use or storage)
___ One or more PCB transformers
___ 45 kg (99.4 lb) or more PCBs in PCB containers (40 CFR 761.180)
___ Annual document logs must be completed by July 1 of each year for the previous year to account for all PCBs on-site from year to year. The log must be kept 3 years after equipment is disposed of and must include:

___ Information on the facility
___ Total number of PCB transformers and capacitors in use and in storage
___ Dates the items were placed in storage or removed from the site
___ A unique ID number (such as serial number) for each item
___ Unique manifest numbers for each shipment of PCBs
___ Records of each phone call made to confirm delivery of PCB shipments
____ Date and keep a copy of this completed checklist/inventory as part of your records.

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