Presentation on theme: "PCB Workshop No. 2 Presented By; Oregon Department of Energy"— Presentation transcript:
1PCB Workshop No. 2 Presented By; Oregon Department of Energy U.S. Environmental Protection AgencyOregon OSHAEnvironmental Control Corporation
2Overview PCB Workshop No. 2 EPA answers to workshop 1, questionsInspection procedures for light fixturesRemoval of PCB containing ballastCleaning PCB spillsVerification SamplingStorage and Transportation of PCB ballast and wasteManaging contractor relationsOregon OSHA & worker protection
3Hopefully Some Answers Knowledge of EPA RulesFrom Workshop No. 1Questions?Hopefully Some Answers
4Follow-up – Question 1Can 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
5Follow-up – Answer 1Transporter 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.
6Follow-up – Answer 1A 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…
7Follow-up – Answer 1If 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
9Follow-up – Question 2Is 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 ?
10Follow-up – Answer 2Yes.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).
11Follow-up – Question 3Does 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 ?
12Follow-up – Answer 3For 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.
13Show Notification Form 7710-53 Looking at box number six, right hand side at the mid point of the form.
14Follow-up – Question 3If 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.
15Follow-up – Question 4Are 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).
16Follow-up - Answer 4761.61(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.
17Follow-up – Question 5Do they need to know the time/date of the leaking ballast ?Answer:Only for determining whether they can apply the spill clean-up policy.
18Follow-up – Question 6Is 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.
19Follow-up – Answer 6If 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.
20Follow-up – Question 7If 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
22Follow-up – Question 8If 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
23Follow-up – Question 9Is 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.
24Follow-up – Question 10Is 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.
26Inspection of Light Fixtures for PCB’s Topics Addressed:Overview of EPA’s Self Audit PolicyWhat to look for during a PCB inspectionPersonal Protective EquipmentDocumentation & Visual Identification SystemNotification of violations to the EPA
27EPA, Self Audit PolicyOn 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.
28EPA, Self Audit PolicyOverview of Self Audit Policy Requirements concerning PCB’s:Self-Investigation of any potential violationsFailure to notify of PCB activitiesFailure to notify of PCB clean-upPresent spills in fixturesImproper storage or disposal of PCB’s
29PCB InvestigationWhat to Look For during and inspection of Presumed PCB containing Light Fixtures;PCB containing ballast present?Assumption RuleLeaking (non-intact Ballast)Contamination (spill) into the fixture?Spill or presumed contamination of the surrounding environment?
30PCB InvestigationWhen 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 equipmentWeep marks on the equipmentSmoke, dark haze, shadow, or stainingGross physical damage
31Any 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.
34PCB InvestigationProcedures for performing an inspection of light fixtures;Personnel TrainingPersonal Protective EquipmentExisting HazardsElectricalFall protectionPCB’sDocumentation / Visual Identification System of inspection findings
35PCB Investigation Post PCB Investigation Requirements; Self-disclosure of any violations identifiedDevelopment of PCB spill remediation planNotification of PCB ActivitiesTSCA Generator ID NumberDevelopment of PCB Operations and Maintenance Plan (if district will continue to use PCB containing ballasts)
36PCB Investigation Operations & Maintenance Program Requirements; Written ProgramWorker protection training for personnelEmergency response protocolsTemporary storage requirementsNotification to EPA of any future spillsdocumentation of PCB activities
37PCB Investigation Common Mistakes; Skipping light fixtures Not detecting and identifying tracecontamination (e.g., lite gray outline of ballast)Inadequate or under developed responseprotocolsLack of personal protection equipment
38PCB Ballast Removal – General Topics Addressed:Worker TrainingProtection of EnvironmentRegulatory Mandates (EPA / OR-OSHA)Removal and Spill Clean-upCommon MistakesDocumentation / Record Keeping
39PCB 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:
40PCB Ballast Removal – General Specific OSHA requirements contained in;29 CFR Hazard Communications and29 CFR Personal protective equipment29 CFR Hazardous waste operations and emergency response (for spill clean-up)Specific EPA regulations contained in;40 CFR Part 761 Polychlorinated Biphenyl'sSpecific DEQ regulations contained in;OAR Polychlorinated Biphenyl's (PCBs)OAR Hazardous Waste Management
41PCB 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?
42PCB 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.
43PCB Ballast Removal – General Ballast Removal Procedures:Protection of environmentPersonal Protective EquipmentProper containers for removed ballastPhysical removal of ballastElectrical lock-out tag-outEnsure ballast is intact (non-leaking)Approved containersDocumentation
44PCB 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.
45PCB Ballast Removal – General Video Here - BALLAST REMOVAL PROCESS
46PCB Ballast Removal – General Common Mistakes:Lack of personal protection equipmentImproper use of personal protection equipmentImproper transportation of ballastsImproper storage of ballasts before shipping
53Ballast Removal - General Procedures for Leaking PCB Ballasts
54Removal of Leaking PCB Ballasts PCB Ballast Removal – GeneralRemoval of Leaking PCB BallastsSafety of the workerSafety of the StudentsInsure no further spread of contaminationClean up the spillProper transporting to a DOT approved container and SDFProper labeling of containers and storage
55PCB 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 wastePhysical cleaning of fixture(see next slide for considerations)
56PCB 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 wasteDecontamination verification testingDocumentation / Record Keeping
57PCB Spill Clean-Up – General Video Here - PCB CLEANING OR REMEDIATION
58PCB Spill Clean-Up – General Common Mistakes:Lack of personal protection equipmentImproper use of personal protection equipmentImproper wiping of itemFailing to perform final wipeImproper transportation and disposal ofcleaning equipment
59Verification Sampling Decontamination Verification Testing:Worker TrainingTools and Equipment (containers, wipes, chemicals)Sampling protocolsNumber of testsDocumentation (Chain of custody)Accredited laboratory
60Verification Sampling Video Here - VERIFICATION SAMPLING
61Verification Sampling Common Mistakes:Lack of personal protection equipmentImproper use of personal protection equipmentFailure to collect sample from previouslycontaminated areaFailure to send sample to lab within XXXX days
65Generator Storage Facility Protection of environmentDOT approved Hazardous waste containersStored on impermeable barrierSpill protection requirementsHazard Warning Labels / PlacardsProper container labelingProper demarcation of storage areaOne year temporary storage limitOut of service date on container
66Storage – General Things to Avoid (Improper Storage)
67Storage – General Things to Avoid (Improper Storage)
68Storage – General Things to Avoid (Ballast soup)
70Managing 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 firmChoosing a qualified environmental contractorContracts and responsibility concerning PCB’sSD MUST monitor the electrical contractor’s workSD MUST correct problemsSD MUST obtain receipts of required documentation
71References FYI. Published by California DTSC. To OR-OSHA Slides