my school district does not have pcb fluorescent light ballasts things you should know questions to...
TRANSCRIPT
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My School District Does Not Have PCB Fluorescent Light
Ballasts
Things You Should Know
Questions to Ask Yourself
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What Does That Mean?
• Terms
– Toxic Substance Control Act
TSCA We say Toss-ka
– Resource Conversation and Recovery Act
RCRA We say Rick-rah
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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
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Disposal Records• If You removed leaking PCB ballasts you must have
-
– A TSCA Identification NumberTSCA Form 7710-53 – Not RCRA Form 8700-12
– 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)
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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 NumberTSCA Form 7710-53 – Not RCRA Form 8700-
12– 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)
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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
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Prohibitions
Now that you removed your PCB ballasts, what is EPA looking for –
1) PCB spills inside light fixturesThese are high risk spills to students in your
schools
2) A plan to clean up these spillsRemove the risk to students
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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.
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§ 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
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OOPS!
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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
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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
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PCBs were 125,000 ppm
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PCBs were 70,000 ppm
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PCBS were 270,000 ppm
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OUCH!
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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
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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
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Reminder
• Your “Self-implementing” remediation plan must address – continued
– How will the clean-up material be disposed– When will the project be completed
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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
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Questions
• Contact EPA Region 10 – EPA Web page of forms
• http://www.epa.gov/pcb/data.html
– TSCA Hotline • 202-554-1404 or
E-mail at: [email protected]
– Region 10 • 1-800-424-4EPA
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Questions
• Alaska, Idaho, Oregon, Washington
– Dan Duncan - Regional PCB Coordinator - phone - (206) 553-6693
– Bernie Pribish - phone - (206) 553-5293– Ray Nye - phone - (206) 553-4266– Bruce Long – phone – (503) 326-3686