My School District Does Not Have PCB Fluorescent Light Ballasts

1. My School District Does Not Have PCB Fluorescent Light Ballasts ThingsYou Should Know Questions to Ask Yourself

2. What Does That Mean? • Terms • Toxic Substance Control Act TSCA We say Toss-ka • Resource Conversation and Recovery Act RCRA We say Rick-rah

3. 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

4. Disposal Records • If You removed leaking PCB ballasts you must have - • A TSCA Identification Number TSCA 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)

5. 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 Number TSCA 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)

6. 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

7. Prohibitions Now that you removed your PCB ballasts, what is EPA looking for – 1) PCB spills inside light fixtures These are high risk spills to students in your schools 2) A plan to clean up these spills Remove the risk to students

8. 40 CFR §  761.20Prohibitions and Exceptions • No persons may use any PCB, or any PCB Item regardlessofconcentration, in any manner other than in a totallyenclosedmanner within the United States unless authorized by regulation or EPA approval.

9. §  761.20Prohibitions 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

10. OOPS!

11. 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

12. 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

13. PCBs were 125,000 ppm

14. PCBs were 70,000 ppm

15. PCBS were 270,000 ppm

16. OUCH!

17. 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

18. 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

19. Reminder • Your “Self-implementing” remediation plan must address – continued • How will the clean-up material be disposed • When will the project be completed

20. 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

21. 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: tsca-hotline@epamail.epa.gov • Region 10 • 1-800-424-4EPA

22. 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