PCB STORAGE
With the exception of utilities, very few PCB owners are choosing to store their PCB wastes on site. The practice of on-site PCB storage was commonplace before Swan Hills opened up in 1996 but now over the past several years, the number of PCB storage sites has been significantly reduced.
Depending on the amount and type of PCB waste requiring storage, there are several different PCB containment units available. The following are some examples of containers that PCB Disposal has provided to customers over the years. Any of them are still available for order.
Types of Portable PCB Storage Containers
1) 2-drum unit (4’ x 2’ x 4’) 2) 4-drum unit (4’ x 4’ x 4’)
3) 8-drum unit (8’ x 4’ x 4’) 4) 16-drum unit (8’ x 8’ x 10’)
5) 54-drum unit (8’ x 8’ x 20’) 6) 108-drum unit (8’ x 8’ x 40’)
7) 20-ft unit with removable roof 8) 20-ft unit with extended removable roof
9) 20-ft unit with two side doors 10) 40-ft unit with removable roof
11) 40-ft unit, three side doors, separate compartments 12) 20-ft unit with bulk storage tank
Required Features
(a) secondary spill containment trays (b) bilingual PCB stickers on drums and Txs
(c) lockable doors (d) spill cleanup paraphernalia nearby
(e) Restricted access (lockable fence) (f) Log book for inventory record keeping
(a) lifting lugs (b) fork truck slots
Other Features
(a) alarm (b) fire suppression cylinders
(c) grounding (d) explosion-proof heaters
(e) smoke detector (f) external siren
(g) steel grating (h) spark-resistant, non-corrosive grating
Other Requirements
(c) leakers are placed in over-pack drums (d) spills and leaks must be cleaned up ASAP
(e) container labelling identifying “PCB” contents (f) containers for disposal must be wipe-tested
Improper Storage
MOE officials often inspect storage sites to investigate compliance with PCB storage regulations. Drums and other PCB wastes must be stored to prevent release of PCBs into the storage area and prevent contamination of pallets, floors, walls and the environment.
Dumping of PCB-contaminated drums and electrical equipment not only harms the environment but it is illegal and the penalties, if caught, can be severe under the EPA.
It is not surprising that there is more PCB waste in landfills than there is in approved PCB storage sites. It is unfortunate that government policies, past and present, regarding small waste exemption and disposal of obsolete transformer carcasses has lead to widespread contamination of the environment.
PCB Site Number
Where PCB owners set up PCB storage sites, the MOE assigns a number to the site that identifies the owner, address, contact name, inventory, etc. The MOE requires that companies that decide to store PCBs for extended periods submit a letter explaining why no effort is being made to take advantage of existing PCB destruction technology. The new federal PCB regulations published in the Canada Gazette September 17, 2008 stipulate deadlines for disposal of PCB wastes in Canada.
Soil Storage
PCB-contaminated soil is stored in a number of different containers depending on how much is removed for disposal. Small quantities are stored in 18-gauge drums and larger quantities are stored in luggers
Sometimes, reinforced 20-ft containers can be sued for storing larger quantities of soil. Alternatively, soil is excavated directly into trucks for immediately transportation to the receiving/destruction facility.
Spill Containment
In addition to spill trays in storage containers, berms around transformers and drip trays for moving electrical equipment are essential for ensuring PCB-contaminated fluids do not escape into the environment.
Unsafe Storage
PCBs should not be stored in a way that could create a workplace hazard. Below is a photo showing 30,000 ballasts in a 40-ft container stacked like bricks. If they ever fell over onto someone, it could cause severe injury or even death. Remember, 1375 nine-inch ballasts weigh one tonne (2200 pounds).
Underground Storage Tanks were not typically used for storing PCB contaminated oils, fuels or solvents but many became contaminated accidentally and had to be decontaminated and/or disposed of.
Obviously this should be avoided since overfilling and leakage inevitably leads to expensive cleanup costs, particularly if groundwater is impacted.
Important Regulatory Notes
1) Non-PCB wastes cannot be store with PCB wastes. They must be stored in separate containers or storage rooms.
2) PCBs cannot be stored in plastic drums
4) Leaking capacitors, transformers, drums, etc. cannot be left to contaminate other wastes in the storage container.
In addition to the MOE having an inventory of the PCB wastes stored at each site, the local fire department should receive as copy of the inventory and each person responsible for the storage site should be trained in the use of PPE, spill response and emergency procedures.
A copy of the “Contingency Plan” should be made available to all employees and should cover what to do in the case of spills, fires, floods and vandalism.
The new Federal PCB Regulations passed on September 5, 2008 and published in the Canada Gazette on September 17, 2008, have new requirements for storage of PCBs and it is important for all PCB owners to familiar themselves with their new obligations under these regulations.
