PCB - What You Need to Know Presented 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

Who Is At Risk If We Don’t Learn This? A Safe Learning and Working Environment Is Everyone’s Responsibility

SB 1149 Education Plan HOW TO IDENTIFY PCB CONTAINING LIGHT BALLASTS

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 1149 BASIC INSPECTION NOTIFICATION HANDLINGCLEANINGAND DISPOAL PROCEDUURES

Initial Building Assessment (Investigation) for PCB Containing Light Ballast Initial (high-level) research of lighting systems and building records 1. Age of building 2. Date fixtures were installed 3. Building records 4. 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 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 1149  WASTE GENERATION, CONSOLIDATION, TRANSPORTATION, AND AND DISPOSAL DISPOSAL

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

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

SB 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 ENVIRONMENTAL CONCERNS  Asbestos  Lead Paint  Mold  Indoor Air Quality Next