PCB - What You Need to Know Presented by:

1
PCB - What You Need to KnowPresented by

• Darren Lee
• Environmental Control Corp., Project Mgr.,
• Industrial Hygienist
• Previous West Linn-Wilsonville Environmental
  Safety Health Mgr.

• Cec Amuchastegui
• Director of Secondary Education Klamath Falls
  City Schools
• School Improvement District Communications

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Who Is At Risk If We Dont Learn This?
A Safe Learning and Working Environment Is
Everyones Responsibility
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SB 1149 Education Plan

• HOW TO IDENTIFY PCB
• CONTAINING LIGHT BALLASTS

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Classifications of Electrical Light Ballast
Containing PCBs

• PCB Containing
• Electrical ballast that contain dielectric fluid
  with a PCB concentration of 500 ppm or greater
• PCB Contaminated
• Electrical ballast that contains dielectric fluid
  with a PCB concentration of 50 ppm but lt500 ppm
• Non PCB
• Electrical ballast that contains dielectric fluid
  with a PCB concentration less than 50 ppm.

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Classification Of PCB Liquids

• PCB Liquid that contains 50 ppm or greater is
  considered to be PCB
• Non PCB Liquid that contains less than 50 ppm
  is considered non-PCB
• Non-Detectable Liquid with a concentration of
  less than 2 PPM of PCB in non-detectable
• Note If non PCB liquid is spilled, it is still
  subject to EPA, Toxic Substances Control ACT
  (TSCA), spill requirements.

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Classification of PCB Spill

• School Districts are required to notify the EPA
  when a spill from an electrical light ballast
  contains gt than 50 ppm PCBs

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How Do We Know If a Fluorescent Light Ballast
Contains PCBs?

• Manufacturer
• Product Manufacturers Label
• Date Manufactured
• Testing (the only sure method)
• And when in doubt implement the
• Assumption Rule

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SB 1149

• BASIC INSPECTION NOTIFICATION
• HANDLING
• CLEANING
• AND
• DISPOAL PROCEDUURES

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Initial Building Assessment (Investigation) for
PCB Containing Light Ballast

• Initial (high-level) research of lighting systems
  and building records
• Age of building
• Date fixtures were installed
• Building records
• Style of fixtures (new vs. old, large lamps vs.
  small)
• Record keeping system for keeping track of
  inspection findings.

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Primary or Detailed Assessment of Suspect Light
Fixtures

• Worker Training
• Personal Protective Equipment
• What to look for when inspecting each suspect
  light fixture
• Visible leaking or contamination evident on the
  outside of the fixture
• PCB or non PCB containing ballast
• PCB contaminated ballast
• Associated spills and/or leaks beyond the fixture
  (potential contamination to surrounding
  environment)
• Mercury vapor light tubes

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Handing and Cleaning Procedures

• Worker Protection (OR-OSHA)
• Proper training
• Training documentation
• Personal Protective Equipment (PPE)
• Electrical Safety
• Cleaning Kits

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Regulatory Notification Responsibility Concerning
PCB Spills and PCB Activities

• School Districts EPA Notification Process
  Requirements
• Self disclosure submittal to EPA concerning any
  leaking Ballasts identified
• Submission of PCB spill remediation Plan
• Submission of EPA form 7710-53 concerning PCB
  activities
• Receipt of EPA hazardous waste generator ID number

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PCB Containing Ballast Removal and Fixture
Decontamination Methods

• Issues to address when preparing for the removal
  of PCB containing ballasts from light fixtures
• Has the District fulfilled the EPA Notification
  requirements?
• Electrical Hazard Identification?
• Worker Training?
• Personal Protective Equipment (PPC)
• Bagging or containerizing ballasts?

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PCB Containing Ballast Removal and Fixture
Decontamination Methods cont.

• Issues to address when preparing for the removal
  of PCB containing ballasts from light fixtures
  cont.
• Leaking vs. non-leaking ballasts (separation of
  waste streams)
• Cleaning contaminated fixtures
• Addressing larger PCB spills
• Mercury vapor fluorescent light tubes
• Proper Record keeping

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Improper Storage of Removed Ballast
Ballasts were removed from light fixtures and
stored in open bins
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Not on your playground!
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Verification Testing, Post Spill Clean Up or
Fixture Decontamination Process

• Verification testing
• Training for persons conducting PCB
  Decontamination verification testing
• Accredited analytical laboratories
• Interpretation of analytical results

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SB 1149

• WASTE GENERATION, CONSOLIDATION, TRANSPORTATION,
• AND
• DISPOSAL

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Waste Generation

• Generation and Consolidation of PCB Containing or
  PCB Contaminated Waste Streams
• Generation and Consolidation Factors
• Proper handling of PCB containing Waste
• Separation of waste Streams
• PCB vs. Non-PCB
• Leaking vs. non-leaking
• PCB contaminated cleaning equipment and PPE

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Waste Generation

• Proper PCB waste storage and shipping containers
• Proper storage of
• PCB containing waste prior to transportation
• Hazardous materials placarding/labeling

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Transportation and Disposal of PCB Containing
Wastes

• As a Generator your District is responsible for
  the hazardous waste you generate from
• CRADLE TO GRAVE

KLAMATH CITY SD PCB 1902-2003
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Transportation and Disposal of PCB Containing
Wastes cont.

• Regulatory Requirements pertaining to
• Transportation Disposal
• Waste Manifest
• EPA Generator ID Number
• Proper Waste Containers and Placarding
• Licensed Waste Transporters
• Approved Hazardous Waste Landfills or
  Incineration facilities

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Transportation and Disposal of PCB Containing
Wastes cont.

• Disposal of PBC Containing Waste
• gt50 ppm

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Transportation and Disposal of PCB Containing
Wastes cont.

• Recycling, treatment and disposal methods
• Licensed-Permitted Hazardous Waste Landfills
• Licensed Incinerators Reclamation Facilities

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Transportation and Disposal of PCB Containing
Wastes cont.

• DISTRICT LIABLITY

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Transportation and Disposal of PCB Containing
Wastes cont.

• Disposal Options For PCB Containing Ballasts
• Permitted Hazardous Waste Landfills
• Land disposal restrictions
• Incineration Facility
• Thermal Destruction
• Reclamation Facility
• Recycling Reclamation Resource Recovery

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Transportation and Disposal of PCB Containing
Wastes cont.

• Certificates of Disposal Destruction of Waste
• Additional Disposal Requirements for Mercury
  Vapor Light Tubes

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MANAGEMENT CONSIDERATION!

• PROACTIVE PLANNING
• PROPER TRAINING
• CONSCIENTIOUS MANAGEMENT
• THOROUGH DOCUMENTATION
• and
• DETAILED RECORD KEEPING

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MONEY MATTERS

• PCB HANDLING DISPOSAL COSTS
• General costs for safety equipment (PPE)
• Training
• PPE
• Containers
• Cleaning materials

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MONEY MATTERS cont.

• PCB HANDLING DISPOSAL COSTS cont.
• General Costs for Testing and Laboratory
  Analytical Work
• General Costs for Transportation and Disposal or
  Destruction of Ballasts
• Transportation fees
• Disposal Fees
• Landfills
• Incineration
• Reclamation
• Mercury vapor fluorescent light tubes

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SB1149 - PCB Disposal Costs

• Eligible
• Tracking
• Storage
• Transportation
• Disposal
• Cleaning
• Verification sampling
• Ineligible
• Fines

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BETC - PCB Disposal Costs

• Eligible
• Removal
• Storage
• Transportation
• Tracking
• Disposal
• Ineligible
• Cleaning
• Verification sampling
• Fines

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Costs for Previous Retrofits

• Eligible for SB1149 and/or BETC
• None

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OTHER POSSIBLE ENVIRONMENTAL CONCERNS

• Asbestos
• Lead Paint
• Mold
• Indoor Air Quality

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