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You are most likely to encounter polychlorinated biphenyls (PCBs) during remodeling or renovation. PCBs were widely used before 1979 as dielectric fluid to insulate electrical equipment such as capacitors, transformers, switches, and voltage regulators, and for fluorescent lamp ballasts. PCBs are considered hazardous because studies have shown them to cause cancer as well as reproductive and developmental defects in laboratory animals. Handling and disposal of materials containing PCBs is regulated by federal and state law.
PCB Management
Before disposing of fluorescent ballasts, you should determine if they contain PCBs. Look to see if the ballast carries a "No PCBs" label. If it does, then your ballast does not contain PCBs and you don't have to worry about most of the other information in this section. See the content in this section under Disposal of PCB Ballasts and Recycling Ballasts for disposal and recycling options.
General EPA Information About PCB's
In the fall of 1993, the EPA received data from several sources indicating that PCBs were found in the insulating (potting) compounds of fluorescent light ballasts generally manufactured prior to 1978 (all ballasts manufactured through approximately 1978 contain PCBs and some manufactured after 1978 contain PCBs as well). Ballasts that contain potting compounds that have 50 ppm or more PCBs (which includes any PCB-containing ballast you will encounter) are termed PCB Articles. PCB Articles must be stored, transported, and disposed of in accordance with Toxic Substances Control Act (TSCA) regulations. Contact an EPA Regional or State Operations Office.
To avoid incurring liability from improperly managed ballasts that have PCB-contaminated potting compounds, the EPA recommends that untested ballasts or ballasts that do not carry a "No PCBs" label should be managed as PCB waste.
CERCLA Reporting Requirements
PCB is defined as a hazardous substance under CERCLA (Superfund). CERCLA lists one pound as the reportable quantity for PCBs when they are disposed of in a landfill. Each small capacitor in a fluorescent light ballast contains at least 0.1 pounds of pure PCB. So if you are disposing of 10 or more light ballasts, you are subject to CERCLA reporting requirements. Reporting places you on a list of potential Primary Responsible Parties in any subsequent Superfund cleanup of the landfill. For this reason, you can avoid liability by managing ballasts in an alternative manner such as recycling.
Capacitor Terms
Two terms you may often come upon when dealing with PCBs:
- Small capacitor - the capacitor contained in the ballast has less than three pounds of dielectric fluid
- Large capacitor - the capacitor contained in the ballast has more than three pounds of dielectric fluid
You can also look for PCB testing labs in the Yellow Pages under "Laboratories-Analytical."
Disposal of PCB Ballasts
EPA has established a policy that recommends against disposing of individual small PCB capacitors, small PCB capacitors contained in fluorescent light ballasts, or untested fluorescent light ballast potting compounds as municipal solid waste. Instead, the EPA encourages you to dispose of non-leaking fluorescent light ballasts and small PCB capacitors at a TSCA-approved facility. These facilities include recyclers, landfills, and incinerators that have EPA approvals to dispose of PCBs.
Disposal procedures for PCB ballasts depends on your particular situation:
- The following types of ballasts may be disposed of at a TSCA-approved recycler, landfill, or incinerator (they may also be disposed of at a licensed Class II municipal landfill that agrees to accept them, although EPA does not recommend this disposal method):
- All ballasts without PCBs
- Ballasts that contain PCBs, but are not leaking and have less than three pounds of dielectric fluid (which should always be the case)
- If the capacitors in your ballasts are leaking, you must send them to an EPA-approved PCB incinerator. Recycling is not an option.
- Whether your ballasts are leaking or not, you can transport them yourself or you can hire a certified hauler. If you transport the ballasts yourself, contact the disposal facility first to make sure your ballasts will be accepted.
Ballasts in a lighting system can be punctured or damaged, exposing an oily, tar-like substance (the potting compound). If the leaking ballast is identified as containing PCBs, the ballast and all materials that come in contact with it are fully regulated and are subject to federal PCB requirements.
Should you encounter a leaking ballast containing PCBs, follow these procedures:
- Immediately (within 24 hours) follow detailed spill procedures outlined in 40 CFR, Part 761, Subpart G.
- Leaking ballasts must be disposed of in an EPA-approved PCB incinerator.
- You can transport the leaking ballasts yourself or you can hire a certified hauler. If you transport the ballasts yourself, contact the incinerator first to make sure your ballasts will be accepted. If you hire a certified hauler, the leaking ballasts must be manifested for shipment. Some haulers are authorized as PCB commercial storers and may be used to arrange for the disposal of ballasts containing PCBs.
Used, non-leaking ballasts may be recycled even if they contain PCBs. Recycling reclaims valuable metals, reduces the volume of solid waste sent to landfills, and prevents toxic substances from being burned in an incinerator or buried in a landfill.
Regulations
- Toxic Substances Control Act (TSCA)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
- 40 CFR Part 761 Federal regulations governing disposal and liability from improper disposal of PCB-containing materials.
- Investigate and follow state and local requirements for handling and disposing of ballasts containing PCBs.
- Recycle PCB-containing ballasts through a licensed and permitted recycling facility.
- If you don't recycle your PCB-containing ballasts, follow hazardous waste
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