PCB - What You Need to Know Presented by: Darren Lee Environmental Control Corp., Project Mgr., ...
-
Upload
oliver-robertson -
Category
Documents
-
view
218 -
download
0
Transcript of PCB - What You Need to Know Presented by: Darren Lee Environmental Control Corp., Project Mgr., ...
PCB - What You Need to KnowPCB - What You Need to KnowPresented by:Presented by:
Darren LeeDarren Lee Environmental Control Environmental Control
Corp., Project Mgr., Corp., Project Mgr., Industrial HygienistIndustrial Hygienist Previous West Linn-Previous West Linn-
Wilsonville Wilsonville Environmental Safety Environmental Safety & Health Mgr.& Health Mgr.
Cec Cec AmuchasteguiAmuchastegui
Director of Secondary Education Director of Secondary Education Klamath Falls City SchoolsKlamath Falls City Schools
School Improvement & District School Improvement & District CommunicationsCommunications
Who Is At Risk If We Don’t Learn This?
A Safe Learning and Working Environment Is
Everyone’s Responsibility
SB 1149 Education PlanSB 1149 Education Plan
HOW TO IDENTIFY PCB HOW TO IDENTIFY PCB
CONTAINING LIGHT CONTAINING LIGHT BALLASTSBALLASTS
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
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
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?
Manufacturer Product Manufacturer’s Label Date Manufactured Testing (the only sure method)
And when in doubt implement the Assumption Rule
SB 1149SB 1149
BASIC INSPECTION BASIC INSPECTION NOTIFICATIONNOTIFICATIONHANDLINGHANDLINGCLEANING CLEANING
ANDANDDISPOAL PROCEDUURESDISPOAL PROCEDUURES
Initial Building Assessment (Investigation) for PCB Containing Light Ballast
Initial (high-level) research of lighting systems and building records
1. Age of building2. Date fixtures were installed3. Building records4. 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
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
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
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
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.
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
Ballasts were removed from light fixtures and stored in open bins
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 1149SB 1149
WASTE GENERATION, WASTE GENERATION, CONSOLIDATION, CONSOLIDATION, TRANSPORTATION,TRANSPORTATION,
AND AND
DISPOSALDISPOSAL
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 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
As a Generator your District is responsible
for the hazardous waste you generate
from
“CRADLE TO GRAVE”
KLAMATH
CITY SD PCB
1902-2003
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 cont.
Disposal of PBC Containing Waste
– >50 ppm
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 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 cont.
Certificates of Disposal – Destruction of Waste
Additional Disposal Requirements for Mercury Vapor Light Tubes
MANAGEMENT CONSIDERATION!
PROACTIVE PLANNING
PROPER TRAINING
CONSCIENTIOUS MANAGEMENT
THOROUGH DOCUMENTATION
and
DETAILED RECORD KEEPING
MONEY MATTERS
PCB HANDLING & DISPOSAL COSTS– General costs for safety equipment (PPE)
Training PPE Containers Cleaning materials
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
Eligible– Tracking – Storage– Transportation– Disposal– Cleaning – Verification sampling
Ineligible– Fines
BETC - PCB Disposal Costs
Eligible– Removal– Storage – Transportation– Tracking– Disposal
Ineligible– Cleaning – Verification sampling– Fines