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. Hopefully Some Answers
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

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. This is What EPA wants to see.
SFD Example

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 (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 (a) for this single ballast ?
Answer:
Yes if they choose (a) – self-implementing Procedures.
They also may choose (b) or (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 (a) ?
Answer:
If they choose (a). They can also choose (b) and (c).
If you don’t 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 (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 PCB’s
Topics Addressed:
Overview of EPA’s 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 PCB’s:
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 PCB’s

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. Any item containing regulated levels of PCBs (50 ppm or greater)_ must be disposed of in accordance with the regulations to minimize exposure to humans and the environment. The regulations governing disposal of PCBs include RCRA as well as TSCA. TSCA Disposal requirements vary depending on the type of item, and the concentrations of PCBs in the dielectric fluid in the item, or of the liquid in a container.

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
PCB’s
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 Hazard Communications and
29 CFR Personal protective equipment
29 CFR 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 Polychlorinated Biphenyl's (PCBs)
OAR 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?
Generator’s PCB storage area in compliance?

42. PCB Ballast Removal – General
Removal and Spill Clean-up:
It is the District’s 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 REMOVAL PROCESS

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 Removal Common 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
Removal of Leaking PCB Ballasts
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 OR REMEDIATION

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 – General Common 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. This is What EPA wants to see.
SFD Example

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 PCB’s
SD MUST monitor the electrical contractor’s work
SD MUST correct problems
SD MUST obtain receipts of required documentation

71. References FYI. Published by California DTSC.
To OR-OSHA Slides