Lion's office will be closed on Monday, September 1, in observance of Labor Day. For help with online training, please contact support@lion.com.
Search

Question of the Week: PCB Waste Management

Posted on 7/12/2011 by James Griffin

Q. We are doing some building maintenance and have removed or replaced a number of our fluorescent lighting fixtures. As a result, we have an assortment of lighting ballasts. I know that polychlorinated biphenyls (PCBs) are regulated under TSCA and not RCRA. Can I presume that our lighting ballasts contain less than 50 ppm PCBs? If not, how do I determine whether the ballasts contain PCBs?
 
A. As you indicated in your question, discarded electrical equipment containing PCBs are subject to the Toxic Substances Control Act (TSCA) regulations at 40 CFR Part 761. If this equipment exhibits the toxicity characteristic only, then it may be excluded from the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations [40 CFR 261.8]. It is important to note that this is a Federal exclusion. Some states have hazardous waste management regulations that are more stringent than the Federal rules and may still regulate them under their RCRA hazardous waste rules. In these cases, the waste would be subject to both TSCA and State hazardous waste management regulations.
 
Under the TSCA rule, you cannot presume that your discarded lighting ballasts have less than 50 ppm PCBs. The PCB regulations do not create any assumptions about the PCB concentrations in fluorescent light ballasts. Fluorescent light ballasts are regulated for disposal under 40 CFR 761 when they contain > 50 ppm PCBs when disposed. Disposal options depend on whether the PCBs are found in an intact and non-leaking PCB small capacitor, a non-intact or leaking PCB small capacitor, or in the potting material [40 CFR 761.50(b)(2)]. 
 
If there is no label indicating that there are no PCBs (ballasts manufactured after July 1, 1979 were required by the EPA to be labeled “No PCBs”), the EPA has recommended two options. First, you could assume that the potting material contains PCBs at 50 ppm or greater and dispose of the ballast as PCB bulk product waste in accordance with 40 CFR 761.62. Alternatively, you could conduct a survey of the manufacturer and type of ballasts in use in the building and develop a random sampling plan for each manufacturer and type of ballast found and analyze the samples for PCBs. However, regardless of the results of the survey, you are responsible for the proper disposal of each ballast. 
 

Tags: EPA, TSCA

Find a Post

Compliance Archives

Lion - Quotes

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

Hazmat Shipping Professional

I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.

John Gratacos

Logistics Manager

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.