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Oregon State Department of EnergyConference

Oregon State Department of EnergyConference. Daniel Duncan, EPA Region 10 PCB Program Manager November 5, 2003. Regulatory Review. PCB Disposal Amendments June 29, 1998 Effective August 28, 1998 PCB Fluorescent Light Ballast Regulated Bulk Product Waste 40 CFR 761.62.

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Oregon State Department of EnergyConference

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  1. Oregon State Department of EnergyConference Daniel Duncan, EPA Region 10 PCB Program Manager November 5, 2003

  2. Regulatory Review • PCB Disposal Amendments June 29, 1998 • Effective August 28, 1998 • PCB Fluorescent Light Ballast Regulated • Bulk Product Waste 40 CFR 761.62

  3. Agenda for Today • Toxic Substances Control Act (TSCA) • PCB Regulations • Criteria for Your Decision • PCB Compliance & Enforcement • Self-Disclosure Policy • Solution Overview • PCB Light Ballasts • PCB Regulatory Compliance • Summary

  4. PCB Regulations • Why are PCB Fluorescent Light Ballasts Regulated under TSCA ? • Probable Carcinogen • Persistent, Bioaccumulative, Toxic (PBT) • Dose Reassessment • http://www.epa.gov/pcb/effects.html

  5. Criteria for Your Decision • PCB Fluorescent Light Ballasts are regulated based on PCB in potting mtl • PCB Fluorescent Light Ballasts that are leaking constitute improper disposal • PCB non-leaking ballasts must be disposed of under 40 CFR 761.50(b)(2)(ii) and 40 CFR 761.62(a)-(c) • PCB leaking ballasts must be disposed of under 40 CFR 761.60(a) and 40 CFR 761.61

  6. Criteria for Your Decision • TSCA Regulations stipulate a penalty of up to $ 27, 500 per day per violation • EPA Response may consist of a Letter of Case Closure, Letter of Advisement • EPA Enforcement actions may include a Notice of Noncompliance, and/or a TSCA Complaint • School Districts may self-disclose under the Self-Disclosure Policy

  7. Criteria for Your Decision • Self-Disclosure Policy: 65 FR No. 70 April 11, 2000 (http://www.epa.gov/ fedrgstr /2000-apr.htm) 19617-19627 • Specifies Incentives for Self-Policing; Discovery; Disclosure, Correction and Prevention of Violations • Specifies Nine Conditions • Region 10 Contact: Submit Self-Disclosures :Mr. Jackson Fox Office of Regional Counsel

  8. PCB Light Ballasts • PCB leaking Fluorescent Light Ballasts must be disposed of as PCB Liquid or PCB Remediation Waste • PCB non-leaking Fluorescent Light Ballasts is a PCB Article, Containers must be labeled for transport and disposal as bulk product waste • PCB Fluorescent Light Ballasts must be manifested

  9. PCB Regulatory Compliance • PCB Compliance will result in significant reduction in TSCA liability • PCB Compliance will also enable you to properly maintain, store and dispose of Flourescent Light Ballasts • PCB Compliance requires the submittal of a PCB Remediation Plan under 40 CFR 761.61(a) • Self-Disclosure of PCB Disposal Violations

  10. Solution Overview • PCB Fluorescent Light Ballasts must be properly inspected, maintained, and disposed of iaw 40 CFR 761.50(b)(4) • PCB non-leaking Fluorescent Light Ballasts may be disposed of in a TSCA Incinerator, TSCA Landfill, Alternate Destruction • PCB leaking Fluorescent Light Ballasts may be disposed of in a TSCA Incinerator, Alternate Destruction Method, or Decontaminated

  11. PCB Program Contacts • EPA Office of Pollution Prevention & Toxics (OPPT) • National Program Chemicals Division: David Hannemann (202) 565-0585 Dr. John Smith (202) 565-0512 • EPA PCB Program Homepage: http://www.epa.gov/pcb • Region 10 PCB Program: • Daniel Duncan (206) 553-6693 • Ray Nye (206) 553-4226 • Bernie Pribish (206) 553-5293

  12. PCB Program Contacts • Region 10 PCB Contacts • Regional Expert /Toxicologist: Dr. Michael Watson (206) 553- 1072 • QA/QC: Sampling Dr. Bruce Woods (206) 553-1193 • Agency for Toxic Substances and Disease Registery (ATSDR) 1-800-447-1544 (National #) Dr. Karen Larson (206) 553-6978

  13. Summary • Develop & Institute PCB Compliance Program in District Schools • Ensure Monthly Inspections of PCB Fluorescent Light Ballasts • Ensure Maintenance Records are Maintained • Submit PCB Remediation Plan under 40 CFR 761.61(a) for REgio 10 Review & Approval • Self-Disclose Violations under EPA Self-Disclosure Policy

  14. Summary (Cont'd) • PCB Disposal Amendments regulate Fluorescent Light Ballasts as PCB bulk remediation waste • PCB Fluorescent Light Ballasts that contain > 50 ppm PCB in potting compound are regulated under TSCA • PCB Fluorescent Light Ballasts need to be inspected, maintained, stored and properly disposed of under the PCB Regulations • PCB Compliance limits liability Next

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