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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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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

PCB - What You Need to KnowPresented by:
who is at risk if we don t learn this
Who Is At Risk If We Don’t Learn This?

A Safe Learning and Working Environment Is

Everyone’s Responsibility

sb 1149 education plan
SB 1149 Education Plan

HOW TO IDENTIFY PCB

CONTAINING LIGHT BALLASTS

classifications of electrical light ballast containing pcb s
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
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
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
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
SB 1149

BASIC INSPECTION NOTIFICATION

HANDLING

CLEANING

AND

DISPOAL PROCEDUURES

initial building assessment investigation for pcb containing light ballast
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
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
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
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
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
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
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, 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 11491
SB 1149
  • WASTE GENERATION, CONSOLIDATION, TRANSPORTATION,

AND

DISPOSAL

waste generation
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 generation1
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
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
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 cont1
Transportation and Disposal of PCB Containing Wastes cont.
  • Disposal of PBC Containing Waste
    • >50 ppm
transportation and disposal of pcb containing wastes cont2
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 cont4
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 cont5
Transportation and Disposal of PCB Containing Wastes cont.
  • Certificates of Disposal – Destruction of Waste
  • Additional Disposal Requirements for Mercury Vapor Light Tubes
management consideration
MANAGEMENT CONSIDERATION!

PROACTIVE PLANNING

PROPER TRAINING

CONSCIENTIOUS MANAGEMENT

THOROUGH DOCUMENTATION

and

DETAILED RECORD KEEPING

money matters
MONEY MATTERS
  • PCB HANDLING & DISPOSAL COSTS
    • General costs for safety equipment (PPE)
      • Training
      • PPE
      • Containers
      • Cleaning materials
money matters cont
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
SB1149 - PCB Disposal Costs
  • Eligible
    • Tracking
    • Storage
    • Transportation
    • Disposal
    • Cleaning
    • Verification sampling
  • Ineligible
    • Fines
betc pcb disposal costs
BETC - PCB Disposal Costs
  • Eligible
    • Removal
    • Storage
    • Transportation
    • Tracking
    • Disposal
  • Ineligible
    • Cleaning
    • Verification sampling
    • Fines
costs for previous retrofits
Costs for Previous Retrofits
  • Eligible for SB1149 and/or BETC
    • None
other possible environmental concerns
OTHER POSSIBLE ENVIRONMENTAL CONCERNS
  • Asbestos
  • Lead Paint
  • Mold
  • Indoor Air Quality

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