Followup

1
PCB Workshop No. 2 Presented By

• Oregon Department of Energy
• U.S. Environmental Protection Agency
• Oregon OSHA
• Environmental Control Corporation

2
Overview PCB Workshop No. 2

• EPA answers to workshop 1, questions
• Inspection procedures for light fixtures
• Removal of PCB containing ballast
• Cleaning PCB spills
• Verification Sampling
• Storage and Transportation of PCB ballast and
  waste
• Managing contractor relations
• Oregon OSHA worker protection

3
Knowledge of EPA Rules From Workshop No.
1 Questions? Hopefully Some Answers
4
Follow-up Question 1
Can a School District transport regulated PCBs
for the purpose of consolidation as a generator
to a School District's storage for disposal
facility (SDF) and not be required to obtain a
PCB Activity ID as a transporter ? An example
would be to transport regulated PCBs two to four
blocks from one school (building) to the School
District's SDF. See the definition of transport
of PCBs under 40 CFR 761.3.
5
Follow-up Answer 1
Transporter of PCB waste means, for the
purposes of this part, any person engaged in the
transportation of regulated PCB waste by air,
rail, highway, or water for purposes other than
consolidation by a generator.
6
Follow-up Answer 1
A PCB activity number is not required for the
case that was described here. The definition of
transporter excludes this activity. Unless they
(the school district) hires an external
contractor to haul the waste offsite, then a
transporter ID is not required. However
7
Follow-up Answer 1
If you are transporting to a consolidation point,
you must.. - transport the ballast in a safe and
dedicated container - must label the container
PCB - you must have some type of tracking
record i.e. work order - at the consolidation
point must retain a batch log
8
SFD Example
This is What EPA wants to see.
9
Follow-up Question 2
Is each school within a School District required
to obtain a PCB Activity ID as a generator when
the waste is going to be consolidated at the
School District's SFD ?
10
Follow-up Answer 2
Yes. Reading the questions 1 and 2 in
succession, one is prone to confuse the issue.
However, each specific generator site needs an
ID number. If the generating faculties are in
the same contiguous area, they do not need a
separate number. Generators applicable to PCB
activity notification must generate waste and own
or operate a storage facility subject to the
storage requirements under 40 CFR 763.65(b).
11
Follow-up Question 3
Does each school in that School District need to
apply for an individual PCB Activity ID or
should the School District apply for one PCB ID
which covers all the schools in that district ?
12
Follow-up Answer 3
For the purpose of transportation for
consolidation, an ID is not required. For
generation, the same as stated above in answer
No. 2. The school, or school district needs to
apply for individual numbers for each facility if
the sites are not in the same contiguous area.
13
Show Notification Form 7710-53
Looking at box number six, right hand side at the
mid point of the form.
14
Follow-up Question 3
If a School District discovers a single leaking
ballast in a classroom can they clean this up
under the Spill Cleanup Policy ? Answer Only
if the spill is discovered within 72 hours of the
spill.
15
Follow-up Question 4
Are they required to submit a PCB Remediation
Plan for Regional review under 40 CFR 761.61(a)
for this single ballast ? Answer Yes if they
choose 761.61(a) self-implementing Procedures.
They also may choose 761.61(b) or 761.61(c).
16
Follow-up - Answer 4
761.61(a) Self-implementing clean up requires
EPA review prior to the clean up. Also qualifies
as a Self-disclosure for TSCA violations. 761.61(b
) Performance Based clean-up. Disposal to
incinerator and meet the decontamination
requirements, i.e. ,10 micrograms per 100
centimeters square for non-pours surfaces. Risk
of EPA audit and penalty if found in
violation. 761.61(c) Risk Based clean up and
requires an approval from EPA.
17
Follow-up Question 5
Do they need to know the time/date of the leaking
ballast ? Answer Only for determining whether
they can apply the spill clean-up policy.
18
Follow-up Question 6
Is this from the point of discovery i.e. the
School District has 24 hours to clean-up upon
discovery of the leaking ballast ?
Answer Within the time of the spill.
19
Follow-up Answer 6
If you discovered a leaking light ballast you are
in violation of TSCA. You must cleanup the spill
immediately and you must either notify EPA under
the self-disclosure rule, comply with the
performance based rules or the risk based clean
up rules. In any case, you must clean up the
spill, do confirmation sampling of the area of
the spill and prepare a report and retain that
report for three years.
20
Follow-up Question 7
If the School District fails to clean up within
the 24 hours are they then required to submit a
PCB Remediation Plan under 40 CFR 761.61(a)
? Answer If they choose 761.61(a). They can
also choose 761.61(b) and 761.61(c). If you dont
clean up the spill and EPA finds out, you are
subject to civil penalties
21
Follow-up Answer 7
22
Follow-up Question 8
If a School District is planning the remediation
of several classrooms are they required to submit
a PCB Remediation Plan for Region review under 40
CFR 761.61(a) ? Answer Yes
23
Follow-up Question 9
Is the School District required to submit a
Self-Disclosure under the April 11, 2000 Audit
Policy for leaking light ballasts (i.e. improper
disposal ) of PCBs? Answer OECA needs to answer
this question. A remediation plan is a
self-disclosure.
24
Follow-up Question 10
Is a Self-Disclosure required to be submitted by
a School District along with a PCB Remediation
Plan ? Answer The remediation plan could be
interpreted as self-disclosure.
25
Follow-up - Answer
26
Inspection of Light Fixtures for PCBs

• Topics Addressed
• Overview of EPAs Self Audit Policy
• What to look for during a PCB inspection
• Personal Protective Equipment
• Documentation Visual Identification System
• Notification of violations to the EPA

27
EPA, Self Audit Policy
On December 22, 1995, EPA issued its final policy
on Incentives for Self-Policing Discovery,
Disclosure, Correction and Prevention of
Violations (60 FR 66,706) (Audit Policy, or
Policy). The purpose of the Policy is to enhance
protection of human health and the environment by
encouraging regulated entities to voluntarily
discover, disclose, correct and prevent
violations of Federal environmental law. Benefits
available to entities that make disclosures under
the terms of the Policy include reductions in the
amount of civil penalties and a determination not
to recommend criminal prosecution of disclosing
entities.
28
EPA, Self Audit Policy

• Overview of Self Audit Policy Requirements
  concerning PCBs
• Self-Investigation of any potential
  violations
• Failure to notify of PCB activities
• Failure to notify of PCB clean-up
• Present spills in fixtures
• Improper storage or disposal of PCBs

29
PCB Investigation

• What to Look For during and inspection of
  Presumed PCB containing Light Fixtures
• PCB containing ballast present?
• Assumption Rule
• Leaking (non-intact Ballast)
• Contamination (spill) into the fixture?
• Spill or presumed contamination of the
  surrounding environment?

30
PCB Investigation

• When PCBs and PCB-contaminated equipment are
  inspected, inspectors should check for proper
  labeling that meets requirements.
• Inspectors should also look for indications that
  the equipment may be leaking, such as
• Oil stains near the equipment
• Weep marks on the equipment
• Smoke, dark haze, shadow, or staining
• Gross physical damage

31
(No Transcript)
32
(No Transcript)
33
PCB Investigation
Video Here - SITE SURVEY
34
PCB Investigation

• Procedures for performing an inspection of light
  fixtures
• Personnel Training
• Personal Protective Equipment
• Existing Hazards
• Electrical
• Fall protection
• PCBs
• Documentation / Visual Identification System
  of inspection findings

35
PCB Investigation

• Post PCB Investigation Requirements
• Self-disclosure of any violations
  identified
• Development of PCB spill remediation plan
• Notification of PCB Activities
• TSCA Generator ID Number
• Development of PCB Operations and
  Maintenance Plan (if district will continue to
  use PCB containing ballasts)

36
PCB Investigation

• Operations Maintenance Program Requirements
• Written Program
• Worker protection training for personnel
• Emergency response protocols
• Temporary storage requirements
• Notification to EPA of any future spills
• documentation of PCB activities

37
PCB Investigation

• Common Mistakes
• Skipping light fixtures
• Not detecting and identifying trace
  
• contamination (e.g., lite gray outline
  of ballast)
• Inadequate or under developed response
• protocols
• Lack of personal protection equipment

38
PCB Ballast Removal General
Topics Addressed

• Worker Training
• Protection of Environment
• Regulatory Mandates (EPA / OR-OSHA)
• Removal and Spill Clean-up
• Common Mistakes
• Documentation / Record Keeping

39
PCB Ballast Removal General
WORKER TRAINING
For all training requirements pertaining to PCBs
occurring in the course of construction or
maintenance work, the following regulatory
standards may apply
40
PCB Ballast Removal General
Specific OSHA requirements contained in 29
CFR 1910.120 Hazard Communications and 29
CFR 1910.132-139 Personal protective equipment
29 CFR 1910.1200 Hazardous waste operations and
emergency response
(for spill clean-up) Specific EPA regulations
contained in 40 CFR Part 761
Polychlorinated Biphenyl's Specific DEQ
regulations contained in OAR 340-110-0001
Polychlorinated Biphenyl's (PCBs) OAR
340-120-0001 Hazardous Waste Management
41
PCB Ballast Removal General
Regulatory Mandates

• PCB Remediation Plan submitted to EPA?
• Notification of PCB activities submitted to
  EPA?
• Application for TSCA PCB ID Number
  submitted?
• Proper PCB waste containers available?
• Proper PCB labels on hand?
• Generators PCB storage area in compliance?

42
PCB Ballast Removal General
Removal and Spill Clean-up
It is the Districts responsibility to see that
all use, storage, decommissioning, or disposal of
hazardous materials is performed safely and
managed in a way that conforms to all current
regulatory mandates to protect building occupants
and the environment.
43
PCB Ballast Removal General
Ballast Removal Procedures

• Protection of environment
• Personal Protective Equipment
• Proper containers for removed ballast
• Physical removal of ballast
• Electrical lock-out tag-out
• Ensure ballast is intact (non-leaking)
• Approved containers
• Documentation

44
PCB Ballast Removal General
Documentation Record Keeping
It is very important when performing the removal
of PCB ballasts or the clean-up of PCB spills
from light fixtures to provide detailed
documentation and record keeping to avoid
problems later in the process. This is
especially important when transporting PCB
ballasts to a central location for consolidation
with other ballasts and tracking the location of
the fixture where ballasts were removed.
45
PCB Ballast Removal General
Video Here - BALLAST REMOVALPROCESS
46
PCB Ballast Removal General

• Common Mistakes
• Lack of personal protection equipment
• Improper use of personal protection
  equipment
• Improper transportation of ballasts
• Improper storage of ballasts before shipping

47
Ballast RemovalCommon Mistake (PPE?)
48
Ballast Removal General Things to Avoid
49
Ballast Removal General Things to Avoid
50
Ballast Removal General Things to Avoid
51
Things to Avoid
52
Ballast Removal General Things to Avoid
53
Ballast Removal - General
Procedures for Leaking PCB Ballasts
54
Removal of Leaking PCB Ballasts
PCB Ballast Removal General

• Safety of the worker
• Safety of the Students
• Insure no further spread of contamination
• Clean up the spill
• Proper transporting to a DOT approved
  container and SDF
• Proper labeling of containers and storage

55
PCB Spill Clean-Up General
Spill Clean-Up Procedures

• Protection of environment (Critical)
• Personal Protective Equipment (Critical)
• Cleaning chemicals (acetone, TSP, solvent)
• Additional containers for cleaning waste
• Physical cleaning of fixture
• (see next slide for considerations)

56
PCB Spill Clean-Up General
Spill Clean-Up Procedures

• Important considerations to note during the
  physical cleaning of a PCB spill from light
  fixtures.
• Cleaning methods (avoid cross contamination)
• Tools and Equipment (towels, putty knives,
  etc)
• Generation of PCB contaminated waste
• Decontamination verification testing
• Documentation / Record Keeping

57
PCB Spill Clean-Up General
Video Here - PCB CLEANING ORREMEDIATION
58
PCB Spill Clean-Up General

• Common Mistakes
• Lack of personal protection equipment
• Improper use of personal protection
  equipment
• Improper wiping of item
• Failing to perform final wipe
• Improper transportation and disposal of
• cleaning equipment

59
Verification Sampling
Decontamination Verification Testing

• Worker Training
• Tools and Equipment (containers, wipes,
  chemicals)
• Sampling protocols
• Number of tests
• Documentation (Chain of custody)
• Accredited laboratory

60
Verification Sampling
Video Here - VERIFICATION SAMPLING
61
Verification Sampling

• Common Mistakes
• Lack of personal protection equipment
• Improper use of personal protection
  equipment
• Failure to collect sample from previously
• contaminated area
• Failure to send sample to lab within XXXX
  days

62
Transporting Ballasts
63
Transportation - General
What point in the Process From the classroom to
the SDF Non-Leaking Leaking Non-PCB From
the SDF to the Permitted Disposal Facility
64
Transportation GeneralCommon Mistake
65
Generator Storage Facility

• Protection of environment
• DOT approved Hazardous waste containers
• Stored on impermeable barrier
• Spill protection requirements
• Hazard Warning Labels / Placards
• Proper container labeling
• Proper demarcation of storage area
• One year temporary storage limit
• Out of service date on container

66
Storage General Things to Avoid (Improper
Storage)
67
Storage General Things to Avoid (Improper
Storage)
68
Storage General Things to Avoid (Ballast soup)
69
SFD Example
This is What EPA wants to see.
70
Managing Contractor Relations
The following are some important considerations
which should be addressed by the district when
hiring outside labor concerning the removal of
PCB ballasts or PCB spill remediation.

• Consider hiring an environmental consulting firm
• Choosing a qualified environmental contractor
• Contracts and responsibility concerning PCBs
• SD MUST monitor the electrical contractors work
• SD MUST correct problems
• SD MUST obtain receipts of required documentation

71
References
FYI. Published by California DTSC. http//www.dt
sc.ca.gov/PolicyAndProcedures/Schools/SM_POL_PCB_S
chools.pdf
To OR-OSHA Slides