2
Introduction
Stepl: Identifying PCB
Ballasts
4
Step 2: Act Immediately
if Ballasts are Leaking
or if there is a Fire
Accidental Exposure and
What to Do
5
Health Effects of PCBs
7
Step 3: Avoid Problems
- Make a Lighting
Retrofit Part of Your
Modernization Plan
10
Resources for School
Retrofits
Conclusion
               United States
               Environmental Protection
               Agency
                    Region 9
                    Pollution Prevention Program
                    San Francisco, CA 94105
EPA 909B-00-002
May 2001
www.epa.gov/region09
A Guide for School Maintenance Personnel
Removing  PCBs  from
Light Fixtures:
Protecting  Students from Hidden  Dangers
                     The U.S. Environmental Protection Agency (EPA)
                     recommends removal of all pre-1979 fluorescent light
                     ballasts in schools to prevent accidental exposure of
              students, teachers, and other school personnel to highly toxic
              polychlorinated biphenyls (PCBs) through fires or leaks.  This
              guide  provides step-by-step instructions for identifying,
              properly managing, and ultimately replacing PCB-containing
              light ballasts in your school.

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                    Introduction
                           Until the late 1970s, PCBs were
                           commonly used in small
                           capacitors and in the potting
                    material used as insulation in fluorescent
                    light ballasts because of their low electrical
                    conductivity. The Toxic Substances
                    Control Act (TSCA), enacted in 1976,
                    banned the production of PCBs in the U.S.
                           in 1978.

                           However, the continued use of
                           PCB-containing items, such as
                           fluorescent light ballasts, manu-
                           factured before the ban was not
                           prohibited. That is why PCBs in
                           light ballasts manufactured before
                           1978 are a potential problem for
                           many schools in the U.S. today.
                           As the ballasts age, they can
                           break down and pose a potential
                           health and environmental hazard
                           due to increasing risk of leaks or
                           even fires. To remove this poten-
                           tial hazard and increase energy
                    efficiency, the U.S. Environmental Protec-
                    tion Agency (EPA), recommends a com-
                    plete lighting retrofit — removal and
                    replacement of all potentially PCB-con-
                    taining fluorescent light fixtures — for all
                    affected schools. A complete lighting
                    retrofit is the best option because:
                                        • It removes the hazard posed by PCBs in
                                          small capacitors and potting material in
                                          the fluorescent light fixture;

                                        • The older fluorescent tubes used with
                                          PCB-containing (magnetic) capacitors
                                          typically do not work with the new
                                          electronic capacitors;

                                        • The newer fluorescent tubes contain less
                                          mercury, also a toxic substance,
                                          than the older tubes;

                                        • The newer fluorescent tubes and
                                          capacitors increase energy efficiency and
                                          lead to long-term savings; and

                                        • The new fluorescent tubes produce
                                          better quality light and contribute to a
                                          better and safer learning environment
                                          for students and teachers.

                                        Lighting retrofits should be conducted as
                                        part of overall school modernization
                                        efforts to ensure safety and cost-effective-
                                        ness.

                                        This guide provides step-by-step instruc-
                                        tions for identifying, properly managing,
                                        and ultimately replacing PCB-containing
                                        light ballasts in your school.
                    Step  1:  Identifying  PCB  Ballasts
An intact ballast.
      Figure 1 (right) can help you
      determine whether there may be
      PCBs in your school.  If you deter-
mine that your lights might have PCBs,
you should conduct a visual inspection.
                     The ballasts are
                     contained within
                     the light fixture.
                     Because you may
                     need to remove
                     the fixtures to
                     view the ballasts,
                     select a represen-
                     tative number of
ballasts throughout the school to inspect
first. Inspection may also be accomplished
by removing a portion of the fixture, such
as the metal panel covering the ballast.
Expand your inspection if you find PCB
ballasts. To prevent possible exposure if
leaking ballasts are discovered, wear
protective clothing, including chemically
resistant gloves, boots, and disposable
overalls.  Make sure the survey is per-
formed in a well-ventilated area to reduce
the potential for breathing in fumes. Be
sure to keep a record of the areas (e.g.,
classroom 101) and location of the lights
surveyed.

PCBs are found only in magnetic ballasts.
If your ballasts are electronic, they are

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PCB-free. Electronic ballasts should be clearly marked as electronic. After July 1,1979,
magnetic ballasts manufactured without PCBs in their capacitors or potting material
required the state-
ment "No PCBs."
Even if the ballasts
in your sample are
magnetic ballasts
labeled "No PCBs," a
lighting retrofit is
recommended                 /            \  YES   ^ff  ffB  ^^. YES
Figure 1: How to Identify PCB-containing Ballasts
because of the
educational and
energy saving
benefits.

If the magnetic
ballasts do not have
the statement "No
PCBs," you have two
options:

1.   Assume that
    the ballasts
    contain PCBs
    and consider
    performing a
    lighting retrofit,
    OR

2.   Contact the
    manufacturer
    to determine
    whether the
    ballasts contain
    PCBs.

If the manufacturer
is not sure whether
the ballasts contain
PCBs, assume that
they do and consider
retrofitting. If the
manufacturer does
know whether the
ballasts contain
PCBs, document the
conversation with
the manufacturer.
Then, if the ballasts
contain PCBs, EPA
recommends a
complete lighting
retrofit.
                                   Has a
                                 complete
               NO
                               been performed,
NO
                  Ballasts
                probably do
                not contain
                   PCBs
          Perform visual survey of a representative
          sample of ballasts throughout the school
                                                                                   • Recommended
                                                                                   • Precautionary
                                                                                   • Measure
       Option 1
                         Are
                        ballasts  •
                      electronic or
                   include statement
                      "No PCBs?" .  "
                            NO
  YES
                                                                                Ballasts
                                                                                 do not
                                                                                contain
                                                                                 PCBs
  Option 2
          Call
      manufacturer to
       determine if
      ballasts contain
         PCBs
                                        I
 Assume
 ballasts
 contain
  PCBs
                                                                                Perform a
                                                                                complete
                                                                                 lighting
                                                                                 retrofit
        Document
       conversation
         and label
          ballast

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                   Step  2: Act Immediately if  Ballasts  are
                   Leaking  or  if  there  is a Fire
                   Leaking Ballasts -What to Do:
                   I^Tf Evacuate the area (e.g., classroom, hall
                   way) immediately to prevent any acciden-
                   tal exposure through touching or breath-
                   ing in fumes from the leak. Do not close
                   off the area of the leak by shutting doors
                   and windows as this may create a hazard-
                   ous situation for personnel responding to
                   the leak. It is important to keep students
                                   and staff as far away
                                   from the leak as practi-
                                   cable (approximately
                                   100 feet minimum) to
                                   minimize potential
                                   exposure.
This ballast sparked a fire at a school in Southern
California in 1999.
                    Call 911 and
                inform them that the
leaking ballast may contain PCBs.   911
personnel will send the appropriate local
emergency response  team to respond to
the leak.
                                           Notify the appropriate local and
                                           state authorities.
    Engage a contractor to manage the
decontamination and prevent further
leaking. If a school has PCB-containing
ballasts and is not planining a lighting
retrofit, school administration should
consider setting up a contract now to
facilitate the decontamination process
should it become necessary. Otherwise,
the area of the leak could be off-limits
for several months instead of just
several weeks because of paperwork re-
quirements.

Leaks typically take two forms: a clear to
yellow, oily liquid, the PCB oil itself, or a
tar-like substance, the liquefied potting
material.  Of the two, the oil contains
much higher levels of PCBs, sometimes
100%, and is therefore more dangerous
than the potting material.
       Accidental  Exposure and What to Do
       To prevent accidental exposure of workers cleaning up the leak, be sure to observe the following safety
       precautions: wear protective clothing, including chemically resistant gloves and boots, and disposable
       overalls; ensure that the area of the leak is well ventilated to minimize the potential for breathing in
       fumes; use a respirator if proper ventilation of the area is not possible or not advised due to potential
       exposure.

       Some of the warning signs of exposure include irritation of the eyes, nose, and throat, and an acne-like
       skin rash, called chloracne. Below are some tips to follow if accidental exposure occurs:
       Eye Contact - immediately flush with large amounts of water for at least 15 minutes, occasionally
       lifting upper and lower lids.
       Skin Contact - remove contaminated clothing and immediately wash contaminated skin with large
       amounts of soap and water.  Contaminated clothing must be disposed as PCB-contaminated waste.
       Breathing - remove the person from the area and take to the emergency room. Begin rescue breathing
       if breathing has stopped and CPR if heart action has stopped.
       Please note that any skin contact may constitute overexposure.  For your safety, consult a doctor as
       soon as possible after skin contact.

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Ballast Fires -What to Do
H  Immediately call the Fire Depart-
ment, and indicate potentially hazardous
materials are present. Evacuate the area.

     Turn off electricity to the affected
     area.

     Notify the appropriate local and
     state authorities.
     Engage a contractor to manage the
     dec ontamination.
PCB-containing ballast fires are especially
dangerous because burning PCBs produce
other highly toxic substances such as
dioxins and furans. It is best to allow the
trained professionals in the Fire Depart-
ment to respond to the fire.  Any person-
nel expected to respond to fires must be
trained and equipped in accordance with
federal regulation 29 CFR 1910 156.

General Cleanup and Decontamination
Procedures After a Leak or Fire
The cleanup and decontamination proce-
dures for a leak are outlined below.  Due
to the hazards associated with PCBs, an
experienced contractor should be retained.
Suggested responsibilities include:

• Cleaning up the leak and decontaminat-
 ing the area, including testing and re-
 testing as necessary.

• Providing appropriate storage and
 shipping containers for waste materials.

• Marking, labeling, and preparing the
 drums containing the waste material
 from the cleanup for storage, removal,
 transportation, and disposal.

• Preparing manifests and other related
 documentation for the removal, trans-
 portation, storage, and disposal of PCB
 wastes and ensuring submittal to appro-
 priate  authorities.

• Notifying the appropriate federal, state,
 and local authorities.

• Handling any federal,  state, and local
 reporting and record keeping
 requirements.

• Transporting the drum containing the
 leaking ballasts to a high-temperature
 incinerator, the only approved disposal
 Health  Effects  of  PCBs

 The EPA has classified  all PCBs as probable human carcinogens (cancer-causing
 substances). Evidence suggests a possible association between PCB exposure and liver
 cancer. PCBs also have significant ecological and human health effects other than cancer.

 The most likely way that staff may become exposed to PCBs from light ballasts is through
 breathing contaminated air or touching PCB oil or PCB-contaminated materials after a
 ballast leak or fire. No information is available on the short-term  effects of PCBs in
 humans. However, long-term effects can occur at any time after exposure and may last
 for months or years. They include: effects to the nervous and  reproductive system,
 immune system suppression; hormone disruption; respiratory tract symptoms;
 gastrointestinal effects; mild liver  effects;  and effects on the skin  and eyes such as
 chloracne, skin rashes, and eye irritation.   Infants  of mothers exposed to PCBs can
 experience developmental effects impairing movement, visual recognition memory, and
 short term memory.  PCBs may also be passed onto infants through their pregnant or
 nursing mothers.

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                     method for leaking ballasts, and decon-
                     taminating the associated cleanup
                     wastes prior to transportation to a PCB
                     disposal facility or a RCRA Subtitle C
                     (hazardous waste) landfill permitted to
                     accept PCB waste.

                    • Ensuring disposal of the wastes in
                     accordance with federal and state regula-
                     tions.

                    The procedures for cleaning up and
                    decontaminating a fire are essentially the
                                           same as a leak.
                                           However, after a
                                           fire, the area
                                           must be tested
                                           not only for
                                           PCBs, but for
                                           furans as well.
Table 1: Packing and Disposal of Leaking, PCB-Containing
Ballasts and PCB-Containing Wastes1
Disposal
Method
Packing and
Labeling
Manifests and
Reporting
Storage
Transportation
USEPA-approved high-temperature incinerator
• Place ballasts in containers that comply with EPA and
Dept. of Transportation regulations. Call the TSCA
hotline at 202-554-1404 for information.
• All containers must have label indicating PCB
waste.
• Label the containers as hazardous waste according to
Department of Transportation regulations.
Uniform Hazardous Waste Manifest required
Permit required if storing over 270 days
Registered hauler required
Management and Disposal of Wastes
from Ballast Leaks or Fires
Federal law requires that leaking PCB-
containing ballasts and any PCB-contami-
nated materials must be incinerated at an
EPA-approved high-temperature incinera-
tor. For a list of approved facilities, please
call the TSCA information hotline at
(202) 554-1404, or refer to the PCB web site
at www.epa.gov/pcb.  Schools should be
aware that, as a generator of PCB-contain-
ing ballast wastes, they could be liable in
any subsequent Superfund cleanup for any
improper disposal or release to the
environment.

Table 1, to the left, outlines the packing,
labeling, storing, transportation, reporting,
and disposal requirements for disposing of
the waste streams resulting from cleanup of
PCB-containing ballast leaks or fires.

As a generator of PCB (or hazardous)
waste, you need to prepare a Uniform
Hazardous Waste Manifest, available from
the incinerator that will be receiving the
waste.  Please note that if the EPA previ-
ously has not issued a hazardous waste
generator identification number to the
school, the school must obtain one by filling
out and submitting EPA form 8700-12
before disposing of any PCB-containing
waste.
                                                             Toxic Substances Control Act
                                                                           Hotline
                                                                       202-554-1404
Disposal of PCB-containing ballasts and PCB-containing wastes are
regulated federally under the Toxic Substances Control Act (TSCA).

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Step 3: Avoid  Problems -  Make a Lighting
Retrofit Part  of Your Modernization  Plan
Planning for a Retrofit
Lighting retrofits can improve classroom
quality, save money and energy, and
reduce worry and liability. Replacing the
older ballasts with newer lighting ballasts,
reflectors, an d tubes improves lighting
quality, distributing the light more uni-
formly and thus providing a more com-
fortable and productive learning environ-
ment. The newer lighting technology also
increases energy efficiency which means
savings for the school in the long term.
Replacing PCB-containing ballasts now
will prevent a potentially costly cleanup
later.

A lighting retrofit ideally should be
performed as part of overall moderniza-
tion efforts such as roofing or seismic
bracing.  It is critical to examine the
modernization plan to determine where a
lighting retrofit would best fit into the
overall plan to ensure safe, cost-effective
school upgrades. To ensure that all legal
requirements are met, engage a contractor
to review the relationship of PCB work to
the design of all building systems and the
removal and replacement of PCB-contami-
nated equipment. The architect should
consult with electrical and demolition
engineers to be certain that their work is
coordinated and all building codes are
followed.

An experienced contractor should perform
the lighting retrofit. Suggested responsi-
bilities include:
         Disconnecting and removing all
ballasts, incidental PCB-contaminated items,
and    fluorescent tubes from the lighting
fixture housings and compartments.
    Disconnecting all power to and
de-energizing all electrical equipment to
be retrofitted under the supervision of a
licensed electrician.
    Inspecting all fluorescent light fixtures
to determine if each individual ballast
should be assumed to contain PCBs or is
potentially leaking.
    Providing the appropriate containers and
packing materials for packaging and storing the
four possible types of waste streams:

    1.  Intact, non-leaking, PCB-contain-
    ing ballasts;

    2.  Leaking PCB-
     containing
     ballasts and
    cleanup wastes
    generated by
    handling and
    dec ontaminating
     areas where
    leaking ballasts
    were discovered;

    3.  Ballasts that
     contain no PCBs; and

    4.  Fluorescent tubes.

    Maintaining a record for each area (e.g.,
classroom, hallway) where lighting fixtures are
removed including how many leaking vs.
nonleaking PCB-containing ballasts were re-
moved from each area.

|77f  Maintaining a record for each drum used to
store PCB-containing ballasts including:

    1.  The number of ballasts in the drum;

    2.  The condition of the ballasts -
       leaking or non-leaking;

    3.  The date the first ballasts were
       placed in the drum;

    4.  The destination of the ballasts;

    5.  The name of the contractor
       packing the drum; and

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6.   The name and address of the
    waste generator (e.g., the school's
    name).

1771  Packaging and labeling the drums
according to federal, state, and local regu-
lations.
    Storing the drums according to fed-
eral, state, and local regulations until a
transporter currently licensed for transpor-
tation of extremely hazardous waste
removes them to the appropriate disposal
facility for each type of waste stream.

ITTf Preparing manifests and other related
documentation for the removal, transpor-
tation, storage, and disposal of PCB
wastes and ensuring submittal to appro-
priate authorities.
                  Notifying the appro-
               priate federal, state, and
               local authorities.

               |77f  Handling any federal,
               state, and local record-
               keeping or reporting
               requirements.
Management and Disposal of Four
Types of Retrofit Wastes
The sections below outline the notification,
packing, reporting, storage, transportation
and disposal requirements for the four
types of wastes resulting from a lighting
retrofit.

It is critical to check with state solid and
hazardous waste agencies to ensure that
wastes are handled properly.

Some states have adopted stricter
requirements than Federal regulations.
Contact your state hazardous waste
program for information on the rules
that apply in your area.
Schools also should be aware that, as a
generator of PCB-containing ballast
wastes, they could be liable under federal
law in any subsequent federal cleanup at a
hazardous or chemical land disposal site,
incinerator, or recycling facility for im-
proper disposal or release to the environ-
ment.

Waste 1: Intact, Non-leaking
PCB-containing Ballasts
Under federal law,  the EPA recommends
non-leaking ballasts should be handled,
transported, and disposed of as hazardous
wastes. They can be sent to a chemical
waste landfill, an EPA-approved high-
temperature incinerator, or to an EPA-
approved ballast recycler. If the EPA has
not previously issued a hazardous waste
generator identification number to the
school, the school must obtain one by
filling out and submitting EPA Form 8700-
12 before disposing of any PCB-containing
waste. The storage, labeling, notification,
and transportation  requirements vary
depending on the volume of waste.  Please
contact the TSCA information hotline, at
(202) 554-1404, for the full requirements
for managing hazardous wastes.

Under TSCA, ballasts with PCB-contain-
ing small capacitors that are intact are
regulated as non-hazardous waste.  How-
ever, if the ballasts  contain PCBs in the
potting material, the ballasts are regulated
as PCB bulk product waste and must be
sent to an EPA-approved high tempera-
ture incinerator or disposed through other
approved methods as listed in 40 CFR
761.62.

Waste 2: Leaking PCB-containing Bal-
lasts and Cleanup Wastes
Leaking ballasts that contain PCBs must
be managed as PCB waste and sent  to an
EPA-approved high-temperature incinera-
tor. Any material that is contaminated by
leaking PCBs should also be considered
PCB waste. For proper packing, storage,

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transportation, and disposal information
for leaking ballasts and clean-up wastes,
refer to Table 1 on page 6, call the TSCA
hotline, or check the EPA website at
www.epa.gov/pcb.

Waste 3: Non-PCB-containing Ballasts
Non PCB-containing ballasts manufac-
tured after 1979 may contain di-2-
ethylhexylphthalate (DEHP) which has
been classified as a probable human
carcinogen. DEHP was used as a PCB
replacement in fluorescent light ballasts
until 1991. However, most manufacturers
stopped using it in 4-foot fixtures in 1985.
Though not required under federal law,
the EPA recommends you treat DEHP
ballasts as hazardous waste to avoid
potential releases to the environment.
However, if you are disposing of more
that 100 Ibs. of DEHP (the equivalent of
approximately 1,600 ballasts) in a 24 hour
period, you must notify the National
Response Center at 1-800-424-8802.

Waste 4: Mercury-containing
Fluorescent Tubes
Disposal of mercury-containing fluores-
cent lamps is federally regulated under
the Resource Conservation and Recovery
Act (RCRA). Because of  the high cost of
testing a fluorescent lamp for mercury
(approximately  $140 per  lamp) and the
likelihood that the lamp will fail the test,
USEPA recommends assuming that all
fluorescent lamps  contain mercury and
handling them as hazardous waste. Some
states have added mercury-containing
fluorescent lamps  to their universal waste
rule, which allows streamlined storage,
handling, and transportation require-
ments for specific types of waste.
Table 2, below, summarizes the general
notification, packing, labeling,
transporting, storage, reporting, and
disposal requirements.
Table 2: Packaging and Disposal of Mercury-Containing
Fluorescent Tubes2
Disposal
Method
Notification
Packing and
Labeling
Manifests and
Reporting
Storage
Transportation
Hazardous Waste Landfill
Recycling
Notify the National Response Center at 1-800-424-8802
• Pack lamps in cushioning material to prevent breakage
• Place lamps in containers that comply with federal law.
Call the RCRA Hotline at 1-800-424-9346
• Label the containers as hazardous waste according to
Department of Transportation regulations
Uniform Hazardous Waste
Manifest required
Record waste on
bill of lading
Permit required if storing over 90 days
Registered hauler required
No requirements
2Disposal of mercury-containing fluorescent tubes is regulated feder-
ally under the Resource Conservation and Recovery Act (RCRA).

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Resource  for School  Retrofits
Energy Star Program
The U.S. Environmental Protection
Agency's Energy Star Program supports
corporations and organizations in install-
              ing energy-efficient
              lighting technologies.
              The program offers
              assistance through work-
              shops and information
              services that can be
              accessed from the
              Internet.  These
              include: Lighting
              Upgrade Technologies;
              Financing Your Upgrades;
New Building Design    Guidance; and
Service and Product
Providers. These materials are available at
www.energystar.gov. EPA's Office of
Pollution Prevention and Toxics also
offers lists of approved storage and
disposal facilities through its web page at
www.epa.gov/opptintr/pcl).

State Programs
Many states provide additional incentives
for lighting retrofits.  Check with your
state energy commission or with your
local utility for more information.

Energy Providers
Both public utilities and private energy
companies may offer programs to support
energy efficiency improvements such as
lighting upgrades. Programs may include
technical assistance, rebates, or other
funding assistance to support lighting
upgrade projects. Contact your local
energy provider for more
information.
Conclusion

To eliminate the potential hazard posed by
PCB-containing light ballasts, USEPA
recommends removing PCB-containing
ballasts as part of a complete lighting
retrofit.  A complete lighting retrofit
includes removing old fluorescent tubes as
well as ballasts and replacing the entire
lighting fixture with newer, more energy efficient fixtures. A complete lighting retrofit
not only eliminates the hazard, but also improves the school's learning environment,
and increases energy efficiency.  It's an investment that pays off with long-lasting
returns to your students, your community, and the environment.

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