Available Now: 2023 Schedule of Hazmat & RCRA Training
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

Lion is my preferred trainer for hazmat and DOT.

Jim Jani

Environmental Coordinator

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

Download Our Latest Whitepaper

This report answers two common questions concerning the hazardous waste manifest: "Is training required for person who sign the manifest?" and "If so, what training is required?"

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.