Remediation plan for fluorescent light fixtures containing polychlorinated biphenyls (PCBs)

This report describes the remedial action to achieve compliance with 29 CFR 1910 Occupational Safety and Health Administration (OSHA) requirements of fluorescent light fixtures containing PCBs at K-25 site. This remedial action is called the Remediation Plan for Fluorescent Light Fixtures Containing PCBs at the K-25 Site (The Plan). The Plan specifically discusses (1) conditions of non-compliance, (2) alternative solutions, (3) recommended solution, (4) remediation plan costs, (5) corrective action, (6) disposal of PCB waste, (7) training, and (8) plan conclusions. The results from inspections by Energy Systems personnel in 2 buildings at K-25 site and statistical extension of this data to 91 selected buildings at the K-25 site indicates that there are approximately 28,000 fluorescent light fixtures containing 47,036 ballasts. Approximately 38,531 contain PCBs and 2,799 of the 38,531 ballasts are leaking PCBs. Review of reportable occurrences at K-25 for the 12 month period of September 1990 through August 1991 shows that Energy Systems personnel reported 69 ballasts leaking PCBs. Each leaking ballast is in non-compliance with 29 CFR 1910 - Table Z-1-A. The age of the K-25 facilities indicate a continued and potential increase in ballasts leaking PCBs. This report considers 4 alternative solutions for dealing with the ballasts leaking PCBs. The advantages and disadvantages of each alternative solution are discussed and ranked using cost of remediation, reduction of health risks, and compliance with OSHA as criteria