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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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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 PCB - What You Need to KnowPresented by:
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 HANDLING CLEANING AND DISPOAL PROCEDUURES
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.
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
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 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 SDPCB 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 ENVIRONMENTAL CONCERNS • Asbestos • Lead Paint • Mold • Indoor Air Quality Next