A.U.C. 266 March 15, POLYCHLORINATED BIPHENYLS (PCBs) INCIDENTS * 1. INTRODUCTION

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1 A.U.C. 266 March 15, 1997 POLYCHLORINATED BIPHENYLS (PCBs) INCIDENTS * 1. INTRODUCTION Polychlorinated biphenyls, commonly called PCBs, are part of the broad family of organic chemicals known as chlorinated hydrocarbons. Manufactured in the United States since 1929, they have had many commercial uses. Further production was banned in 1977 because they are now suspected to be hazardous to health and the environment. PCBs were and continue to be used primarily as cooling liquids in electrical transformers and capacitors. The dangers of PCBs to humans and animals have been brought to our attention recently by several incidents where PCB leaks have contaminated food supplies. These contaminated food supplies were later consumed by humans and animals. Laboratory tests have documented that PCBs can cause serious health problems. Among the most stable chemicals known, they remain in the environment and are taken up and stored in the fatty tissue of all organisms. 2. ATTITUDE 2.1 In most cases, success in fighting a fire requires training, discipline and physical aggressiveness. However, fires involving PCBs require specialized knowledge, closer control by the officers at the scene, and a sense of caution must be substituted for aggression by all members involved. 2.2 All members, when operating at fires and emergencies, have a personal obligation to protect +themselves, their brother firefighters, and their families. At PCB incidents, the obligation is unique and is directly related to the fact that the hazards are unknown. An officer who treats a PCB incident as "business-as-usual" is not fulfilling his leadership responsibility to his brother firefighters, the Department or to himself and his family. The primary consideration at PCB incidents is the safety of civilians and fire personnel. * The provisions of this circular supersede those contained in WNYF 1st issue 1983 ["PCB's A Closer Look"]. 1

2 3. EPA REGULATIONS 3.1 Identification of PCBs Marking Requirements EQUIPMENT/AREA "PCB TRANSFORMER" (500 or more ppm of PCB) Vault door, machinery room door, fence, hallway, or means of access (other than grates and manhole covers) to a "PCB TRANSFORMER" MARKING REQUIRED BY EPA "PCB-CONTAMINATED TRANSFORMERS" ( ppm of PCB) "Non-PCB TRANSFORMERS" (0-49 ppm of PCB) Vehicles carrying "PCB TRANSFORMERS" No See Note No See Note Note: An unmarked transformer in automatically assumed to contain PCBs. "Until Such Time as a Laboratory Test Rules Out PCB Contamination". PCB Large, High-Voltage Capacitors (defined as a capacitor containing 3 lbs. or more of fluid having 500 PPM PCB or greater and being 2,000 volts or greater) Equipment containing a "PCB TRANSFORMER" or a PCB large High-Voltage Capacitor "PCB article containers" containing PCB articles or equipment required to be so marked Vehicles transporting PCB containers [more than 99.4 lbs of PCB (500 or > PPM PCB) or PCB-contaminated liquid ( PPM PCB)] 2

3 3.1.2 Registration Regulations All "PCB TRANSFORMERS" must be registered with the "Fire Department which would be called upon for the initial response to a fire involving this equipment." This regulation is nation wide and as such was written with this in mind. In NYC it has resulted in some confusion. Field units have received or may receive transformer registration information. The law s intent is that the central authority (headquarters) of a Fire Department receive the necessary information not a local fire house. Hence any unit receiving transformer registrations or when asked by transformer owners as to where to send registrations shall direct that they be sent to: Toxic Substance Unit, Bureau of Fire Prevention, NYC Fire Department, 9 MetroTech Center, Brooklyn, New York, Proof of registration with F.D.N.Y. for transformer owners will only come from the Toxic Substance Unit. As the information becomes available field units will receive these transformer locations via " Hazardous Substance Lists." Registration information is to include 1. Address(s) of building(s), for outdoor "PCB TRANSFORMERS", the location of the outdoor substation. 2. The physical location of the "PCB TRANSFORMER(S)" on the building site(s). 3. The principal constituent of the dielectric fluid in the transformer(s) (e.g. PCBs, mineral oil). 4. The name and telephone number of the person to contact in the event of a fire involving the equipment. 3.2 EPA Miscellaneous Information Combustible materials must not be stored within a "PCB Transformer" enclosure, within 5 meters of a "PCB Transformer" enclosure or within 5 meters of an unenclosed "PCB transformer." Note: (5 meters = 16.4 feet) Storage for disposal sites. A. Permanent Storage Site - A facility with strict requirements for the prevention of PCB release to the environment. Storage for up to a period of one (1) year is allowed for PCB items and PCB liquids. 3

4 3.3 EPA Marking Format B. Temporary Storage Site - An outdoor or indoor area with less strict requirements than a permanent storage site. Storage of "PCB" (500 or > PPM PCB) items and "PCB Contaminated" liquid ( PPM of PCB) allowed for up to a period not exceeding thirty (30) days. PCB liquids (500 or > PPM PCB) are not allowed to be stored in a Temporary Storage Site Letters and striping on a white or yellow background " x 6" square down to 2" x 2" square depending on size of equipment. CAUTION CONTAINS PCBs (Polychlorinated Biphenyls) A toxic environmental contaminant requiring special handling and disposal in accordance with U S Environment Protection Agency Regulations 40 CFR 761 For Disposal Information contact the nearest US EPA Office. In. Case of accident or spill, call toll free the U S Coast Guard National Response Center (LOCAL UTILITY COMPANY) Sufficiently durable to equal or exceed the life of the equipment being marked. 4

5 4. COMMON TRADE NAMES OF PCB DIELECTRIC FLUIDS USED IN ELECTRICAL EQUIPMENT: Askarel* (See REFERENCE # 1) Saf-T-Kul* Pyrochlor Aroclor* Asbestol* Coroclor Aroclor-B Clorextol Sanotherm* Pyranol* No Flamol Chlorinol* Inerteen* Chlorphen Dykanol Diaclor* Eucarel Hyvol Elemex Adkarel Note: *Denotes those trade names most often found in NYC 4.1 If a trade name appears on a transformer ID plate not listed in Sec. 4 and that transformer is not labeled with the PCB label it must be assumed to contain PCB. 5. FDNY HAZARDOUS SUBSTANCE LISTS. 5.1 Information pertaining to PCBs and PCB transformer/equipment locations is contained in addendum s to. Some of this information is in the form of "FDNY Hazardous Substance Lists" which will be issued, in whole or in part, to specific units. 5.2 Interpreting information in the Hazardous Substance Lists requires an understanding of the following definitions Type of fluid/coolant - indicates type of liquid in a transformer. A. If any of the names appearing in section 4 are shown, the "PCB level (PPM)" column will be blank since these dielectric fluids contains PCB in amounts in the hundreds of thousands PPM PCB. B. If a number appears in the "PCB level (PPM)" column it indicates that this particular transformer has been tested for PPM PCB. C. In some instances where a fluid/coolant shown in section 4 is listed, a number appearing in the "PPM" column is relatively low. This is accounted for by past servicing practices of that particular transformer over a period of years. D. If "oil" is shown in the type of fluid/coolant column, the PCB level (PPM) column will either be "O" indicating no PCB; a number, indicating amount in PPM; or blank. If blank, assume equipment is PCB Contaminated ( PPM PCB), see sec

6 Note: "Oil" is a mineral oil, originally, PCB free. Due to past storage and servicing practices it may have become PCB Contaminated ( PPM PCB). E. "Silicon" - A non PCB type of dielectric fluid used as a replacement for PCB fluids in a transformer. F. "Air" - A transformer cooled by air not a liquid, hence will not contain PCB. G. U.O. - Unknown oil, if no count appears in PPM column, it must be assumed to be PCB transformer. H. Dash (-) indicates that the particular information was not available. I. Carcasses - Indicates those "PCB transformers" taken out of service and awaiting disposal. They may or may not have been drained. If drained, they always will contain residual dielectric fluid and must be treated as a "PCB TRANSFORMER. 6. OPERATIONS 6.1 Until all locations containing PCBs are identified, every incident involving transformers and capacitors shall be treated as if PCBs were present. Any leaking or burning transformer oil shall be assumed to be PCB oil until proven otherwise. DESPITE EPA DEFINITIONS, THE NEW YORK CITY FIRE DEPARTMENT CONSIDERS A TRANSFORMER WITH ANY AMOUNT OF PCBs AS A PCB TRANSFORMER. 6.2 Incident Commander shall implement the procedures outlined in the Emergency Response Plan: Hazardous Materials This first arriving officer shall seek to contact a person in charge of the premises in order to determine the location and extent of fire or emergency, and the amount and type of hazardous material involved. He shall be aware that such person may be unaware of the presence of PCBs or their hazards. 6.3 The Battalion Chief first to arrive shall be advised of all actions taken and all pertinent information. He shall, as may be necessary, take appropriate action in accordance with the established procedures outlined in the Emergency Response Plan: Hazardous Materials 6

7 6.4 The Officer in Command of the operations shall be guided by the following procedures: Entrance into the contaminated or suspected area shall be kept to a minimum. Exposure shall be balanced with the benefits to be gained, i.e., life hazard, confinement of fire, protection of exposed property, etc Energized electrical transformers or capacitors must be deactivated and controls established to maintain this equipment in the "off" position. Deactivation of transformers shall be performed only by Con Edison Personnel or Engineering Personnel of the.premises familiar with procedure. No member of this department shall attempt deactivation by direction or upon instruction of engineering personnel Proper extinguishing methods must be used according to the properties of the involved materials. A. Fog or foam for flammable liquids. B. Water for structural members Wherever possible, smoke and fire gases must be channeled to minimize exposure to civilians and fire personnel Operate from upwind and uphill if possible Complete fire clothing shall be worn, i.e., helmet, boots, waterproof coat, gloves and masks. If necessary, special equipment carried by Haz Mat Unit shall be used for protection Use of self-contained masks is mandatory even in areas of light smoke condition. This applies to all personnel in the affected area Breathing apparatus shall be used at all times until the Officer in Command confirms that the area is free of toxic gases (including overhauling operations) Members exposure time shall be kept to a minimum - rotate personnel to facilitate this end No smoking, eating or drinking shall be permitted at the scene Members exposed or possibly exposed: A. Shall be confined to a designated area until decontaminated. B. Shall be decontaminated along with their equipment as outlined in HMO2. C. Shall be examined by a Medical Officer Evacuation of the fire floor and all areas exposed (even if light haze of smoke exists) shall be given prime consideration. 7

8 7. STAGING AREA 7.1 A staging area shall be established by the Officer in Command. This area shall be used for: Relief personnel Extra masks and cylinders Medical supplies Communications Extinguishing equipment (hose, foam, nozzles, etc.). 8. DECONTAMINATION 8.1 Decontamination procedures outlined in the Emergency Response Plan: Hazardous Materials shall be implemented only when members or equipment are exposed to levels of PCB's of 50 PPM or higher. Federal regulations consider transformers containing a PCB level of less than 50 PPM to be non-pcb transformers. 8.2 Notification of the OSHA Unit The OSHA Unit is available to respond to PCB emergencies, as needed, to assist the Chief in Charge in making decisions regarding decontamination and other methods of controlling the possible spread of these materials. This is expected to establish consistent criteria for the use of the Decon Unit The OSHA Unit is designated as Car The OSHA Unit can be contacted at the following telephone numbers: Headquarters Office: (718) Emergency Command Center: (718) Pager: (718) Mobile Phone: (718)

9 REFERENCE # 1 (FORMERLY SAFETY TIP # 121) This sign indicates the presence of high concentrations of PCB s. The sign will be found on the transformer vault door. These transformer vaults may be found on any floor of a building. Hazardous toxicity is possible when the transformer is involved in fire or arcing is occurring or has occurred. In addition, a spill may also pose a risk to human health and the environment. Fires in electrical transformers may be caused by events occurring at remote distances from such transformers. Transformers are equipped with overload relays and safety vents to prevent oil pressure build-up. Such vents will discharge hot oil, or if defective, a vapor-pressure buildup may develop in transformer and casing rupture may occur. Self-contained breathing apparatus and all protective clothing and equipment shall be worn at fires and spills in these locations. 9