My School District Does Not Have PCB Fluorescent Light Ballasts Things You Should Know Questions to Ask Yourself

What Does That Mean? Terms Toxic Substance Control Act TSCA We say Toss-ka Resource Conversation and Recovery Act RCRA We say Rick-rah

District Building Built Before 1980 I removed our PCB Fluorescent Light Ballasts - In the early 1990s as part of an energy upgrade Removed the ballasts after West Lynn/Wilsonville School District cried out! You read EPA’s letter to the Superintendent, dated February 15, 2000, and did not want EPA to penalize your District I just woke up one day and thought it was a good idea Other reasons

Disposal Records If You removed leaking PCB ballasts you must have - A TSCA Identification Number TSCA Form 7710-53 – Not RCRA Form 8700-12 You have hazardous waste manifests for all shipments to off-site disposal facilities You have confirmation samples to show you cleaned up all spills You disposed at an approved incinerator You have a certificate of disposal You must retain records for 3 years (from July 1 of the following year)

Disposal Records If you removed intact ballasts with PCBs in the potting compound and/or PCBs in the surface paint of the ballasts- You have a TSCA Identification Number TSCA Form 7710-53 – Not RCRA Form 8700-12 You have hazardous waste manifests for all shipments to off-site disposal facilities You disposed at an approved incinerator, or You disposed at an approved TSCA landfill You have a certificate of disposal You must retain records for 3 years (from July 1 of the following year)

Disposal Records My District does not have all of those documents Your District is in violation of the TSCA Subject to penalties up to $27,500 for each violation

Prohibitions Now that you removed your PCB ballasts, what is EPA looking for – 1) PCB spills inside light fixtures These are high risk spills to students in your schools 2) A plan to clean up these spills Remove the risk to students

40 CFR § 761.20 Prohibitions and Exceptions No persons may use any PCB, or any PCB Item regardless of concentration, in any manner other than in a totally enclosed manner within the United States unless authorized by regulation or EPA approval.

§ 761.20 Prohibitions and Exceptions There is no authorization for PCBs as a coating on light fixtures, and no authorization for PCB spills EPA wants to insure that schools do not have PCBs in the light fixtures or on any surfaces in schools

OOPS!

Spill Clean Up If you do not have proof of clean up You must do a site assessment of your buildings Must notify EPA Regional Office “Self-implementing” remediation plan (Clean-up plan 30 days prior to the clean-up project) Dispose of clean-up material at an approved incinerator (use a hazardous waste manifest) Post confirmation sampling of the fixture, or spill location Submit a closure report to the EPA

Spill Clean Up Things to look for in your site assessments Tar like material inside or outside the fixtures Smokey material on the fixtures Brown molasses-like material on the fixtures

PCBs were 125,000 ppm

PCBs were 70,000 ppm

PCBS were 270,000 ppm

OUCH!

Spill Clean Up Spills from leaking fluorescent light ballasts If you discover a spill in a fixture after 12/1998 Must notify EPA Regional Office “Self-implementing” remediation plan (Clean-up plan 30 days prior to the clean-up project) Dispose of clean-up material at an approved incinerator (use a hazardous waste manifest) Post confirmation sampling of the fixture Submit a closure report to the EPA

Reminder Your “Self-implementing” remediation plan must address – When the clean-up project will start (Notify EPA 30 days before you start) What buildings are covered by the project What level of clean up you will achieve Who will be doing the clean up

Reminder Your “Self-implementing” remediation plan must address – continued How will the clean-up material be disposed When will the project be completed

Reminder After the project is completed Submit report to EPA Map of spill locations Final or confirmation sample results of clean up Shipping documents for the disposal of the clean-up debris Hazardous waste manifest Certificates of Disposal

Questions Contact EPA Region 10 EPA Web page of forms TSCA Hotline http://www.epa.gov/pcb/data.html TSCA Hotline 202-554-1404 or E-mail at: tsca-hotline@epamail.epa.gov Region 10 1-800-424-4EPA

Questions Alaska, Idaho, Oregon, Washington Dan Duncan - Regional PCB Coordinator - phone - (206) 553-6693 Bernie Pribish - phone - (206) 553-5293 Ray Nye - phone - (206) 553-4266 Bruce Long – phone – (503) 326-3686