© Circadian EnviroCon 2006

What are PCB's

PCB's are a class of chemicals known as polychlorinated biphenyls, they are entirely man-made. US manufacturer Monsanto began producing PCB's in the late 1920's.


Where were PCB's used

They were used in many products including hydraulic fluid, casting wax, pigments, carbonless copy paper, plasticizer, vacuum pumps, compressors, and many others. The primary use of PCB's was as a dielectric fluid in electrical equipment, due to the stability and resistance to thermal breakdown and insulating properties.  PCB's were extensively used in capacitors and transformers.

The most common capacitors for general use were attached to fluorescent lights. These capacitors are generally called ballasts.

       Identifying PCB Ballasts:

  • All ballasts manufactured through 1979 contain PCBs.
  • Ballasts manufactured after 1979 that do not contain PCBs are labeled "No PCBs."
  • If a ballast is not labeled "No PCBs," assume it contains PCBs.


When are PCB's a concern

When PCB containing ballasts are leaking they must be handled differently than non leaking PCB containing ballasts.  You should not remove leaking PCB ballasts yourself, contact a qualified hazardous materials contractor to remove it from the fixture, and dispose of it properly.


How Circadian can help

 

Health Effects

PCB's can enter the body in three ways:

  1. Ingesting PCB contaminated food or drink.
  2. Absorption through the skin.
  3. Inhaling the vapour. However, vapour concentrations at room temperature are not significant.

Once PCB's are in the body they accumulate in fat cells and stay there for a considerable time. The stability which makes them such useful materials prevents the body from eliminating them quickly.
PCB's are a suspected carcinogen, creating skin problems called chloracne, reproductive disorders, liver disease and  neurological problems in children.

PCB Regulations

Congress enacted the Toxic Substances Control Act (TSCA) of 1976, and placed a ban on PCB manufacturing. Later the EPA regulated the use and disposal of PCB's already in service.

Federal Requirements

Non-Leaking PCB Ballast Disposal
TSCA regulates ballasts that contain PCBs under 40 CFR 761.60(b)(2)(ii). Intact fluorescent and high-intensity discharge (HID) ballasts that are not leaking PCB's may be disposed in a municipal solid waste landfill.  The EPA recommends packing and sealing the intact ballasts in 55 gallon drums with an absorbant material like cat litter.

The Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) regulates the disposal of non-leaking PCB-containing ballasts. CERCLA requires building owners and waste generators to notify the National Response Center at (800) 424-8802, when disposing of 1 pound or more of PCB's (about 12-16 fluorescent ballasts) in a 24-hour period.

As a generator of PCB-containing ballast wastes, you could be liable in any subsequent Superfund cleanup at a municipal, hazardous, or chemical land disposal site, incinerator, or recycling facility.
EPA encouraged proper disposal of PCB-containing ballasts in the preamble to the 1979 PCB Ban Rule (44 FR 31514) and in the preamble to the final rule on August 25, 1982 (47 FR 37342).
"The EPA encourages commercial and industrial firms that use and dispose of large quantities of small PCB capacitors to establish a voluntarily collection and disposal program that would result in the waste capacitors going to chemical or hazardous waste landfills or high-temperature incinerators."

Leaking PCB Ballast Disposal
A puncture or other damage to ballasts in a lighting system exposes an oily tar-like substance. If this substance contains PCB's, the ballast and all materials it contacts are considered PCB waste, and are subject to TSCA requirements. Leaking PCB-containing ballasts must be incinerated at an EPA-approved high-temperature incinerator.

It is very important that you remove, handle, and dispose PCB-containing ballasts properly. Take precautions to prevent exposure of the leaking ballast, since all materials that contact the ballast or the leaking substance are also PCB waste. Use trained personnel or contractors to handle and dispose leaking PCB-containing ballasts.



State Requirements

Non-Leaking PCB Ballast Disposal
Many states have developed regulations governing the disposal of non-leaking PCB-containing ballasts that are more stringent than Federal regulations. In addition, some EPA Regional offices published policies specifying ballast disposal methods adopted by individual states.

State standards can take several forms (e.g., written regulations, regional policies, written and verbal recommendations, transportation documentation). Some states do not regulate PCB-containing ballasts as toxic waste, but prohibit their disposal in municipal solid waste landfills. All generators of PCB-containing ballasts should thoroughly investigate their state's regulations and follow local requirements.

Green Lights recommends three methods for disposing of non-leaking PCB-containing ballasts:

  • High-temperature incineration
  • Recycling
  • Chemical or hazardous waste landfill

High-Temperature Incineration
High-temperature incineration is the method preferred by many companies because it destroys PCBs, removing them from the waste stream permanently and removing the potential for future CERCLA liability. Incinerating a PCB-containing ballast costs more than sending it to a hazardous waste landfill, but this additional cost is one many organizations are willing to absorb.

Recycling Ballasts
Recyclers remove the PCB-containing materials (i.e., the capacitor and possibly the asphalt potting material surrounding the capacitor) for incineration or land disposal. Metals, such as copper and steel, can be reclaimed from the ballasts for use in manufacturing other products. You may recycle used non-leaking ballasts despite PCBs. The last section of this document contains a list of companies that recycle ballasts.

Chemical or Hazardous Waste Landfill
PCB-containing ballasts may also be disposed in a chemical or hazardous waste landfill. Landfill disposal is less expensive than high-temperature incineration or recycling, but does not eliminate PCBs from the waste stream permanently. While chemical or hazardous waste landfill disposal is an acceptable, regulated disposal method, your organization may be legitimately concerned about potential future CERCLA liability using this method.

Packing PCB Ballasts for Disposal
Despite the disposal method selected, ballasts are packed ( according to PCB regulations ( in 55-gallon drums for transportation.

  • One drum holds 150 to 300 ballasts depending on how tightly the ballasts are packed.
  • Fill void space with an absorbent packing material for safety reasons.
  • Label drums according to Department of Transportation regulations.
  • Note that tightly packed drums may weigh more than 1,000 pounds, which may present a safety risk, particularly when moving the drum for loading or unloading.

Record Keeping
To track transported TSCA or hazardous waste, EPA requires generators to prepare a Uniform Hazardous Waste Manifest. The hazardous waste landfill, incinerator, or recycler that you use can provide this one-page form. The manifest identifies the type and quantity of waste, the generator, the transporter, and its ultimate destination.

General Contractors
and
Polychlorinated Biphenyl's