PCB - What You Need to KnowPCB - What You Need to KnowPresented by:Presented by:

Darren LeeDarren Lee Environmental Control Environmental Control

Corp., Project Mgr., Corp., Project Mgr., Industrial HygienistIndustrial Hygienist Previous West Linn-Previous West Linn-

Wilsonville Wilsonville Environmental Safety Environmental Safety & Health Mgr.& Health Mgr.

Cec Cec AmuchasteguiAmuchastegui

Director of Secondary Education Director of Secondary Education Klamath Falls City SchoolsKlamath Falls City Schools

School Improvement & District School Improvement & District CommunicationsCommunications

Who Is At Risk If We Don’t Learn This?

A Safe Learning and Working Environment Is

Everyone’s Responsibility

SB 1149 Education PlanSB 1149 Education Plan

HOW TO IDENTIFY PCB HOW TO IDENTIFY PCB

CONTAINING LIGHT CONTAINING LIGHT BALLASTSBALLASTS

Classifications of Electrical Light Ballast Containing PCB’s

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 <500 ppm

Non PCB – Electrical ballast that contains dielectric fluid with a

PCB concentration less than 50 ppm.

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.

Classification of PCB Spill

School Districts are required to notify the EPA when a spill from an electrical light ballast contains > than 50 ppm PCB’s

How Do We Know If a Fluorescent Light Ballast Contains PCB’s?

Manufacturer Product Manufacturer’s Label Date Manufactured Testing (the only sure method)

And when in doubt implement the Assumption Rule

SB 1149SB 1149

BASIC INSPECTION BASIC INSPECTION NOTIFICATIONNOTIFICATIONHANDLINGHANDLINGCLEANING CLEANING

ANDANDDISPOAL PROCEDUURESDISPOAL PROCEDUURES

Initial Building Assessment (Investigation) for PCB Containing Light Ballast

Initial (high-level) research of lighting systems and building records

1. Age of building2. Date fixtures were installed3. Building records4. Style of fixtures (new vs. old, large lamps vs.

small) Record keeping system for keeping track of

inspection findings.

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

Handing and Cleaning Procedures

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

Regulatory Notification Responsibility Concerning PCB Spills and PCB Activities

School District’s EPA Notification Process Requirements– Self disclosure submittal to EPA concerning any

leaking Ballast’s identified– Submission of PCB spill remediation Plan– Submission of EPA form 7710-53 concerning

PCB activities– Receipt of EPA hazardous waste generator ID

number

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?

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

Improper Storage of Removed Ballast

Ballasts were removed from light fixtures and stored in open bins

Not on your playground!

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

SB 1149SB 1149

WASTE GENERATION, WASTE GENERATION, CONSOLIDATION, CONSOLIDATION, TRANSPORTATION,TRANSPORTATION,

AND AND

DISPOSALDISPOSAL

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

Waste Generation

Proper PCB waste storage and shipping containers

Proper storage of

PCB containing waste prior to transportation

Hazardous materials placarding/labeling

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

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

Transportation and Disposal of PCB Containing Wastes cont.

Disposal of PBC Containing Waste

– >50 ppm

Transportation and Disposal of PCB Containing Wastes cont.

Recycling, treatment and disposal methods

Licensed-Permitted Hazardous Waste Landfills

Licensed Incinerators – Reclamation Facilities

Transportation and Disposal of PCB Containing Wastes cont.

DISTRICT LIABLITY

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

Transportation and Disposal of PCB Containing Wastes cont.

Certificates of Disposal – Destruction of Waste

Additional Disposal Requirements for Mercury Vapor Light Tubes

MANAGEMENT CONSIDERATION!

PROACTIVE PLANNING

PROPER TRAINING

CONSCIENTIOUS MANAGEMENT

THOROUGH DOCUMENTATION

and

DETAILED RECORD KEEPING

MONEY MATTERS

PCB HANDLING & DISPOSAL COSTS– General costs for safety equipment (PPE)

Training PPE Containers Cleaning materials

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

SB1149 - PCB Disposal Costs

Eligible– Tracking – Storage– Transportation– Disposal– Cleaning – Verification sampling

Ineligible– Fines

BETC - PCB Disposal Costs

Eligible– Removal– Storage – Transportation– Tracking– Disposal

Ineligible– Cleaning – Verification sampling– Fines

Costs for Previous Retrofits

Eligible for SB1149 and/or BETC– None

OTHER POSSIBLE OTHER POSSIBLE ENVIRONMENTAL CONCERNSENVIRONMENTAL CONCERNS

AsbestosAsbestos Lead PaintLead Paint MoldMold Indoor Air QualityIndoor Air Quality

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