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

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

3. 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

4. Disposal Records If You removed leaking PCB ballasts you must have -
A TSCA Identification Number
TSCA Form – Not RCRA Form
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)

5. 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 – Not RCRA Form
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)

6. 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

7. 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

8. 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.

9. § 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

10. OOPS!

11. 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

12. 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

13. PCBs were 125,000 ppm

14. PCBs were 70,000 ppm

15. PCBS were 270,000 ppm

16. OUCH!

17. 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

18. 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

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

20. 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

21. Questions Contact EPA Region 10 EPA Web page of forms TSCA Hotline
TSCA Hotline
or at:
Region 10
EPA

22. Questions Alaska, Idaho, Oregon, Washington
Dan Duncan - Regional PCB Coordinator phone - (206)
Bernie Pribish - phone - (206)
Ray Nye - phone - (206)
Bruce Long – phone – (503)