Small Diameter Pipe Wipe Sampling for PCBs: Technology Review and Status of EPA Approval

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- By: ,

Courtesy of Weston Solutions, Inc

ABSTRACT

The Toxic Substances Control Act (TSCA) regulations governing management of polychlorinated biphenyls (PCBs) in the electric and gas industry include a series of options for abandoning pipe in place and managing pipe removed for disposal. The management options available to owners are different and, in some respects, more stringent for pipe that is less than or equal to 4 inches in diameter. The differentiation comes about because, in U.S. Environmental Protection Agency’s (EPA) view, it is not possible to strictly apply their wipe sampling protocol due to size constraints. Many gas companies would like to have the option of sampling small pipe in order to take advantage of the potential reduction in recordkeeping, management, and storage and disposal costs that can come with knowing the PCB concentration.

This paper reviews the current options available for small-pipe sampling and the progress that has been made in expanding the options available. Atlanta Gas Light Company (AGLC) applied for and received a limited approval from EPA in 1999 to use a modified gun-cleaning kit to wipe the inside of their pipe for purposes of characterizing the pipe for abandonment. The method was limited to qualitative (pass/fail) testing. This paper describes subsequent work, performed earlier this year between EPA, Roy F. Weston, Inc. (Weston), and a consortium of gas companies to successfully expand the AGLC permit to allow for quantitative use of the testing method. This paper also outlines the process for gaining approval of an alternate sampling procedure from your respective EPA regions and identifies other methods that could be used for this purpose.

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