FulCircle's Practical Guide

to PCB Ballast Disposal

bY Mitchell Dong

and Brin McCagg

Headquarters 509 Manida Street Bronx, NY 10474 Fax: (7 18) 328-4462 Tel: (718) 328-4667

FulCircle Ballast Recyclers

January, 1995 Fifth Edition

Regional Offices Atlanta Baltimore Boston Chicago Detroit Houston Philadelphia San Francisco Los Angeles 800-775-15 16

OCopyright 1995 FulCircle Recyclers, Inc.

PROLOGUE

Lightingretrofits and electric utility rebates present unique opportunities to rid your building of PCB ballasts and dispose of them properly. Without group ballast replacement you only have small quantities of PCB ballasts to dispose of. This can be expensive if you choose to have the ballasts handled as hazardous waste. Worse yet, they can create legal liability if you decide to simply put them in the dumpster where they can contaminate the local landfill. However, with group replacement, proper disposal becomes much more economical.

Recycling large quantities of PCB ballasts not only reduces liability, but it is inexpensive enough to allow the healthy financial returns you expect fiom upgrading your lighting. The Environmental Protection Agency encourages recycling of spent ballasts and fluorescent lamps and emphasizes that recycling normally costs less than 2% of the life cycle cost of a typical lighting system. Thls is bue because approximately 90% of all costs associated with lighting are attributable to energy use.

In other words, what may seem like an impediment to upgrading your lighting system is actually an opportunity to decontaminate,your buildings of PCBs and dispose of them in an environmentally sound, low cost manner.

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I. INTRODUCTION

The subject of PCB ballast disposal is complex and can be expensive if not handled properly. The purpose of h s Guide is to assist building owners, facility managers, contractors, engineers and electric utilities in decidmg on the best means of disposal for light ballasts. The mformation provided is based on the experience of FulCircle Ballast Recyclers, a company specializing in PCB ballast disposal.

II. WHY SHOULD WE WORRY ABOUT PCBs?

According to the U.S. EPA, polychlorinated biphenyls (PCBs) are toxic chemicals suspected of causing cancer in humans. The Centers for Disease Control report that workers exposed to PCBs have developed:

chloracne (a s h disorder)

liver injury

irritation of the skin and mucous membranes

adverse reproductive effects

Animals exposed to controlled levels of PCBs have developed liver injury. For h s reason, PCBs are classlfied as a probable human carcinogen by the EPA. Given the substantial evidence developed by the Centers for Disease Control and other health organizations, it is prudent to handle PCBs with extreme care.

III. THE LARGE QUANTITY OF PCBs

Because lighting ballasts contain nearly pure PCBs (900,000 ppm or greater), there is a surprisingly large amount of harmful material in each ballast. For example, there are more PCBs in a single ballast than are in 125 gallons of 50 parts per million "PCB oil."

In addition there is a large number of PCB ballasts currently installed in the United States. As a result, the total amount of PCBs in existing ballasts is very large. Please consider the following facts:

Installed base of ballasts in the U.S. is approximately one billion ballasts

About half were manufactured prior to 1979 and contain PCBs

1

One ounce of virtually pure PCBs per ballast

Total quantity of PCBs in buildings in the US: 25 million pounds PCBs

This quantity is staggering. The problem is exacerbated because of the confusing disposal regulations under Federal law.

n7. FEDERAL REGULATIONS CONCERNING THE DISPOSAL OF PCB BALLASTS

There are two primary Federal laws which affect the disposal of PCB ballasts:

Toxic Substances Control Act (TSCA)

Superfund Law (Comprehensive Environmental Response, Compensation and Liability Act or "CERCLA")

Udortunately, these two laws are conflicting and confusing. Portions of TSCA states that it is permissible to dispose of non-leakmg PCB ballasts in a municipal solid waste landfill, whle Superfund prohibits the dlsposal of more than one pound of PCBs (25 or more ballasts) in a municipal solid waste landfill. Prudent corporate policy would follow the more stringent of the two regulations.

Beware that these laws and regulations are llkely to change over the next year or two. The Superfund law is up for reauthorization by Congress and the current Administration has declared it a priority to streamline the Superfund clean up process. In addition, EPA issued in December, 1994, its proposed PCB Amendments to completely revamp the TSCA regulations. Ths includes a proposal to require the disposal of more than 25 ballasts in regulated TSCA disposal facilities, and for more stringent disposal requirements for ballasts because of PCB contaminated asphalt potting material. Keep a watchful eye out for these changing regulations over the next year or two.

Each of these laws is discussed in more detail below. The other Federal regulations which refer to PCBs are discussed toward the end of t h ~ s section.

A. Toxic Substances Control Act

Under the Small Capacitor Exemption TSCA has allowed the disposal of non- leaking, intact "Small Capacitors", defined as containing less than 3 pounds of PCB dielectric fluid in a municipal solid waste landfill, ( a regular non-

2

I

' hazardous dump.) Lighting ballasts contain a Small PCB Capacitor and as a result have been virtually unregulated for disposal.

The exceptions to this rule are as follows:

if the Small Capacitor or ballast is leaking PCBs;

if the ballast is owned by a company wluch, at any time in the past, manufactured equipment wluch contained PCBs;

ifthe potting material in the ballast contains greater than 50 ppm PCBs.

If a ballast meets any of these criteria, then it must be disposed of by incineration in a TSCA-approved facility.

Even though it is legal to dispose of ballasts in a municipal solid waste landfill, the EPA encourages disposers of large quantities of PCB ballasts to treat them as ifthey were a regulated waste. The preamble to the May 3 1, 1979 PCB Final Rule in the Code of Federal Regulations (40 CFR Part 76 1). makes it clear that the intent of the Small Capacitor disposal rule was intended for "random disposal" in landfills by "householders and other infrequent disposers". When commercial and industrial entities dispose of large quantities of small PCB capacitors, it "poses a somewhat larger environmental risk, and the EPA strongly encourages the voluntary collection and disposal of small PCB capacitors in chemical waste landfills or hgh-temperature incinerators.

The draft PCB Amendments propose that any person disposing of more than 25 ballasts per year be required to dispose of the ballast is a TSCA approved, PCB disposal facility.

Recent laboratory tests by SD Myers of Tallmadge, OH, Rollins Environmental Services of Wilmington, DE and General Services Canada of Otawa have indicated that the majority of asphalt potting material inside ballasts are contaminated with PCBs at levels over 50 ppm. If these results are representative of all ballasts, then ballasts may be fully regulated under TSCA as a PCB Article. Ifthls is the case, then the Small Capacitor Exemption would be irrelevant and PCB ballasts must be disposed of only in TSCA approved, toxic waste facilities. EPA has acknowledged these studies and has asked for comments from the public on this subject in its proposed PCB Amendments.

3

B. Superfund Laws

Under the Superfund laws, PCBs are specifically listed as a hazardous substance. The "release" or "threat of release" of more than one pound of PCBs into the environment triggers a Superfund notlfication and cleanup requirement.

Since 25 ballasts collectively contain roughly one pound of PCBs, the disposal of 25 or more PCB ballasts in a landfill triggers a Superfimd action. Any municipal solid waste or chemical waste landfill could become a Superfund site.

EPA's office of Toxic Substances issued a memo on April 16, 1992 to Hank Habicht, then General Counsel of the EPA, which states that the disposal of PCB ballasts from relamping projects could create liability under CERCLA (Superfund). The release of 1 pound of PCBs would require the individual involved to not@ the Emergency Response Center. "Ths notlfication would firmly establish their liability and lead to possible future involvement in any remediation at municipal solid waste landfills receiving such waste. The defhtion of release under CERCLA includes virtually all ways that hazardous substances may enter the environment, including the removal and disposal of PCB containing fluorescent light ballasts" (see Appendix C for a copy of this memo). In EPA's proposed PCB Amendments, this linkage between TSCA and CERCLA is acknowledged.

# d e landfilling has the lowest initial cost, it places those responsible at great risk by creating a large potential cleanup liability. Landfilling in either municipal solid waste or chemical waste facilities has the potential of creating large Superfund-type cleanup costs in the future.

C. Other Federal Laws Affecting Ballast Disposal

The other relevant Federal regulations include the following:

1. Department of Transportation (DOT) regulations - CERCLA requires that DOT list and regulate the transportation of all hazardous materials, including PCBs. Hazardous Materials Regulations (HM) 181 is particularly relevant.

2. Occupational Safety and Health Administration (OSHA) - regulates worker safety and exposure to a variety of chemicals including PCBs.

3. Resource Conservation and Recovery Act (RCFU) - regulates hazardous wastes (whch fail the Toxic Characteristic Leaching Procedure (TCLP) test) and which contain more than 50 ppm PCBs. Wastes are not

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regulated under RCRA if they contain PCBs and are not otherwise hazardous.

Information on the above is provided in Sections VIII, IX and X.

V. STATE REGULATIONS CONCERNING BALLAST DISPOSAL

In addition to the Federal laws, there are state laws which regulate PCBs. The following states class@ PCB ballasts as hazardous, special, regulated or i n d h a l waste, and ban large quantities of PCB ballasts from municipal solid waste or municipal landfills. The following chart is based on: a 1991 survey conducted by the EPA Office of Toxic Substances on state regulations of PCBs, a 1993 state survey of ballast regulations conducted by the EPA Green Lights Program and a 1994 state survey of ballast regulations done by FulCircle Ballast Recyclers. It includes whch states have policies or requirements which may be more stringent than the Federal laws and may prohbit the disposal of ballasts as non-hazardous waste.

STATE REGULATIONS REGARDING BALLAST DISPOSAL

State

AL

AR

Az

CA

co

CT

Comments

In-State landfill requires prior approval.

Regulates transportation of PCBs > 50 ppm.

Can be sent to municipal landfill if packed in approved drums.

PCBs > 50 ppm are hazardous waste and must either be placed in lab packs and disposed of in hazardous waste landfill or incinerated. New ballast regulations were issued April 23, 1993, which eliminated the Extremely Hazardous Waste Permit and exempted up to 2 drums ffom being transported by a hazardous waste transporter. (Title 22 66699, Title 22 66723.)

Follows policy of Region VIII, which recommends that 10 or more ballast be disposed of in a TSCA approved facility.

PCB ballasts must be incinerated or sent to a chemical waste landfill. Connecticut defines PCB wastes, including PCB ballasts, as Connecticut Regulated Wastes. (CT General Hazardous Waste Statute 22A 454, 446.)

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II State I Comments

- KS

KY

LA

Interim guidelines state that PCB ballasts may not be disposed of at any solid waste facility in Florida. PCB ballasts must be sent to a processing facility which will send the capacitors to an approved disposal facility.

Must check with local landf3l and see if it will accept the waste.

Substances regulated include substances which contain PCBs in concentrations of 50 ppm or more. (Kansas Public Health Chapter 65 Article 55.)

Solid waste PCB greater the or equal to 1 ppm cannot be placed on the land; waste containing PCB less than 50 ppm can be placed in a contained lanfiill. Residual lanfiills may dispose of PCBs according to their permit. As a common practice, most landfills in state do not accept PCB ballasts. Kentucky Statute 224.877.)

PCBs >50 ppm considered hazardous waste. LA Administrative Code Title 33, Vol. 13, Chapt. 49.)

IA

MA

MD

ME

ID

Ballasts are regulated as hazardous waste; special exemptions for transportation and madesting exist if ballasts are recycled. (Hazardous Waste Regulations of 1973.)

PCBs are a waste at 50 ppm or more. A quantity of 1 Kg of ballast, the equivalent of 1 ballast or more, are regulated as hazardous waste. Based on entire weight of ballast. (State RCRA program.)

All PCBs >50 ppm regulated as hazardous waste. (ME State Hazardous Waste Statutes.)

IN

Used fluorescent ballasts containing PCBs can not be disposed of in a sanitary landfill and must be handled as hazardous waste. The ballast must be taken by a permitted ballast recycler or hazardous waste disposal or incineration facility. The small quantity generator exemption does not apply to ballasts containing PCBs.

Idaho DOT may have special transportation requirements.

Wastes with concentrations of PCBs to levels greater than 50 ppm are defined as toxic wastes. Need approval to dispose of > 25 small capacitors of ballastdday. (Indmna State PCB Rule.)

11 State I Comments

MI Wastes with more than 100 ppm PCBs are considered to be hazardous. PCB disposal prohbited in Michigan landfills with no small quantity exemptions. (State Act 60 - PCB Act.)

MN

MS

All PCBs > 50 ppm regulated as hazardous waste. (State RCRA)

PCBs are managed when they “impose adverse impacts on the environment andor human health.” PCBs > 25 ppm must be dis- posed of in hazardous waste landfill. (DEQ Environmental regs.)

PCBs > 50 ppm is hazardous waste, unless meets certain conditions. >Ion leaking, intact small capacitors in ballast are exempt under certain conditions, e.g. if recycled or landfilled in a hazardous waste landfll. (NJAC annotated Code 7-26.)

Follow EPA Region 6 policy.

NC

NE

~~ ~~ ~~

Follows EPA Region IV policy whch distributes a list of ballast recyclers.

Follows EPA Region VI1 policy whch recommends disposal of 8 or more ballasts subject to Superfund reporting.

NV

NY

OH

7

State waste codes (BOO 1 -BO 1 1) class@ PCB wastes in NV. PCB Ballasts regulated as hazardous waste. (State Waste code listings.)

Small capacitors in ballasts are exempt fiom hazardous waste regs, although most other PCBs > 50 ppm are regulated. NYS DEC has special requirements for transporting solid wastes, including ballasts. (NY Statute Article 27, Title 9.)

Recommends recycling & disposing as a TSCA waste. More than 1 lb. 01 10 ballasts must be reported to OH Div. of Energy & Remeha1 Response.

OR

PA

Follow EPA Region 10 policy (> 5 ballastslyear should be incinerated or sent to chemical waste landfill.)

If PCBs > 50 ppm, then waste is regulated by DER. (PA Solid Waste Management Act.)

State I Comments

RI

SC

PCBs > 50 ppm regulated as hazardous waste includmg ballasts. However, a state hazardous waste mamfest is not required but a bill of lading or a special log is. @I Hazardous Waste Management Act.)

In-State disposal requires prior approval.

TN

TX

In-State disposal requires prior approval.

PCBs in concentrations less than 1 ppm are regulated by the state as Class 2 wastes; Wastes with PCB concentrations between 1 ppm and 50 ppm are regulated as nonhazardous wastes. PCBs in concentrations greater than 50 ppm defer to TSCA. (Solid Waste Disposal Act Section 25, Article 4477-7.)

UT

VT

WA

Follows EPA Region VI11 policy which recommends that 10 or more ballasts be disposed of in a TSCA facility

All PCBs > 50 ppm regulated as hazardous waste. (VT 0 1 .)

Regulates PCB ballasts as Dangerous Waste. A licensed hazardous waste hauler must be used by "regulated generators". Also follow EPA Region 10 policy (> 5 ballasteear must be incinerated or sent to chemical waste landfN)

8

WI

WV

~~

All PCBs > 50 ppm regulated as PCB waste. (WI Administrative Code, Chapter NR 157 and 180.)

Follow EPA Region 3 policy. ~~

WY Wash. D.C.

~~ ~~ ~

Follows policy of Region VIII, whch recommends that 10 or more ballast be hsposed of in a TSCA facility.

Recommends incineration or chemical waste landiill.

States which ban P CB ballasts from sanitary landfills

States which ban PCB ballasts from sanitary llndfilk m States which may have special policies or requirements regarding disposal of PCB ballasts

Source: FulCircie's.survey of state environmental agencies. 1994; EPA GreenUghb, , March. 1994; and EPA a c e of Toxic S u b s t a n v n a n l p e m . n t , February, I99 I.

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VI. HOW TO IDENTIFY PCB BALLASTS

Nearly all ballasts manufactured prior to 1979 contain PCBs. All ballasts manufactured after July 1, 1978 that do not contain PCBs are required to be clearly marked "No PCBs".

Since most ballasts also contain a date stamp in the metal base plate, we recommend looking for the "No PCB" label and checlung the date stamp to ensure that it was made after 1979 before classifying the ballast as a non-PCB ballast. Umarked ballasts or ballasts without a date code should be classified as PCB ballasts.

Please refer to Appendm A for information on individual ballast manufacturers and when they ceased mandacturing PCB ballasts.

VII. HOW TO IDENTIFY LEAKERS

"Leakers" (leakmg ballasts or capacitors) are items in which PCBs have escaped from the interior onto the exterior surface.

PCBs are a clear or yellow oil, and most PCB leaks are visible. If you see oil on the surface of a ballast, you have a leaker.

FulCircle has observed a leak rate of PCBs out of the capacitor of approximately one per thousand. The next section includes mformation on handling ballasts, including leakers.

VIII. TIPS ON BALLAST REMOVAL

Electrical contractors are generally very experienced with ballast replacement, so we will only highlight a few safety and efficiency tips as they specifically pertain to PCB ballasts.

Workers handling ballasts should be properly trained.

Wear chemically resistant (e.g., rubber) gloves when handling the ballast, as the exterior surface may contain PCBs.

When handling leakers, a chemically resistant suit (e.g., Tyvek@) and a face mask is also recommended to reduce exposure to PCBs. Dispose of protective equipment as contaminated PCB waste along with the PCB ballasts.

10

Ifthere has been a fire in or around the light fixture, assume it is a leaking ballast and handle it with care.

All leakmg ballasts should be placed in a single plastic bag. The bag should be immediately placed in steel dsums with the other ballasts.

If PCBs have leaked onto a light fixture, the entire fixture should be disposed of as toxic waste.

If PCBs have leaked onto the floors, walls or ceiling, consult with your local EPA and state agencies. The clean-up should be done in accordance with EPA's PCB Spill Clean Up Policy (40 CFR 761 Subpart G).

Don't throw the used ballasts around because this could cause leaks and greatly increase your disposal cost. Treat them with care as if they were new ballasts.

Clip off the connecdng Wires on the ballast as close as possible to the PCB ballast. Remember -- ballast disposal services frequently charged by the pound.

Do not bend back the ends of the ballasts.

Ifthe ballast has been burning or smoking, cut the power off at the panel and immediately ventilate and vacate the room. Allow the ballast to cool for 20-30 minutes before replacing.

IX. TIPS ON PACKING

After the ballasts have been removed, they should be taken to the shippingheceiving area, packed in steel drums and labelled. Most companies use 55-gallon steel drums for packing ballasts.

Moving Ballasts to ShivvindReceiving Area

When moving ballasts within the building, cardboard boxes can be used. Use the same large boxes in whch the new ballasts were packaged.

Ballasts are heavy, so don't try to load too many into a box e.g. 12 F40 ballasts weigh 40-50 pounds.

Separate leakers as they are removed, place them in plastic bags and then into a drum with the other non-leaking ballasts.

11

As soon as possible, pack the ballasts into steel drums. Don't let them sit in cardboard boxes for too long in case there is an unnoticed leaker whch could leak PCBs onto your floor.

Sources of Steel Drums

Steel drums can be obtained fkom local suppliers. Look in your local Yellow Pages under "Barrels" or "Drums".

When purchasing drums, spec& 17C or 17H 55-gallon, open head, steel drums with lids for transporting hazardous materials. New DOT regulations also refer to these drums as "UN 1A2" packages.

New drums need not be purchased. Used or reconditioned drums are suitable if they have been properly cleaned, tested and labelled pursuant to DOT regulations. The cost is $20-$40 per barrel in metropolitan areas, plus delivery charges of $50-$200 per load.

Paclung Ballasts into Drums

Don't crush the ballasts because this could cause leaks.

A typical drum will hold 150-250 F40 ballasts fkom 4-foot light fixtures or 60-100 F% ballasts ftom 8-foot light fixtures. We have seen as many as 300 F40 ballasts fit into a drum, but we don't recommend putting more than 200 ballasts into a drum for safety purposes.

A drum filled with ballasts wdl weigh 650 pounds average. Drum weight should not exceed 750 pounds for safety purposes and for ease of handling.

Some companies only fill half the drum because full drums are too heavy to move manually and require special equipment, such as a hand truck, fork lfi, or l f i gate trucks.

Only if you plan to landfill the non-lealung ballasts should you put 6- 12 inches of absorbent material (lutty litter or sawdust) in the bottom of the drum and in the interstitial areas between ballasts. This is required by Federal law (TSCA).

12

If you are sending the ballasts for recvclinp. do not use absorbent material.

Do not use plastic liners inside the drums.

Do not put the drum inside an "Overpack drum.

Drums of Used Ballasts

CAT. NO. S-275-S-TP FOR TWO 75W 96" T12,84" T12,

S7W 72"T12, SOW 64"T12, or 48W 60"T12 SLIMLINE LAMPS

High Power Foctor Sound Rated B

Min. Starting Temp: FOR USE IN FIXED EQUIPMENT ONLY

Note "No PCB's '' Marking on Sample Manufacturer's Label

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X. LABELLING, MANIFESTING AND TRANSPORTING BALLASTS

Ths subject is very complex, open to interpretation and state-specific. We strongly recommend that you check with your local environmental agency to determine your state's requirements.

Under Federal law (TSCA), all regulated "PCB Waste" must be labelled, mamfested, transported and disposed of according to the Federal regulations (40 CFR 761 and 49 CFR Parts 100 to 177 ). PCB Waste includes:

leaking ballasts or lealung capacitors

ballasts owned by a manufacturer of equipment which used PCBs at any time in the past

ballasts containing asphalt potting material with greater than 50 ppm PCBs

ballasts which fail EPA's TCLP test pursuant to RCRA (40 CFR 261)

In &tion to Federal law, the states whch classlfy PCB ballasts as hazardous, regulated, special or industrial waste, usually include speclfic requirements for labelling, madesting, transportation and dsposal. Please check with your individual state.

Labelling

All barrels of ballasts f?om generators or states whch classlfy ballasts as hazardous waste should bear the yellow "Caution Contains PCBs" label (see example). This label is available fi-om most ballast disposal companies or fi-om label printing companies.

All barrels of non- lebg and lealung ballasts should contain a label with the following mformation:

the name and address of the generator, and the date the ballasts were first removed

a description ofthe material (e.g., discarded lighting ballasts with small PCB capacitors)

EPA regulatory status: disposal requirements pursuant to 40 CFR 761.60 (b)(2)(11)

14

A Class 9 label (see example) is required as per DOT HM 181 regulations

Madesting

We recommend using a specially designed madest for ballasts or the Federal Uniform Hazardous Waste Manifest, except in those states which require the state Hazardous Waste Manifest.

States whch class@ PCB ballasts as hazardous, usually require the state's hazardous waste madest form. There are some exceptions such as California, Massachusetts, Connecticut and Rhode Island. California issued new ballast disposal regulations in May, 1993 which exempt generators from the Extremely Hazardous Waste Permit requirements and exempt generators with two drums of ballasts or less from using a hazardous waste transporter.

Storage

Storage of non-leaking ballasts is not regulated, but it is recommended that they be moved off site as soon as feasible due to the danger of a leak or fire.

Ifballasts have potting material greater than 50 ppm, then the storage of the ballasts is regulated. The storage area must meet TSCA standards or items can not be stored for more than 1 year.

Since PCB incinerators and chemical waste landfills must destroy or dispose of regulated waste, such as leakers, within 1 year of the date the equipment was removed from service, customers who store leaking PCB ballasts for over 6 months may pay a significant premium to dispose of these items.

Under TSCA, generators are allowed to store lealung ballasts up to 30 days unless they meet the PCB storage requirements outlined in the regulations. A Notice of PCB Activity @PA Form 77 10-53) must then be filed for the EPA.

15

This PCB label should be used ij'you classij'y

PCB ballasts as regulated waste

CAUTION

(Polychlorinated Biphenyls) A toxic environmental contaminant requiring

special handling and disposal in accordance with U. 5. Environmental Protection Agency Regulations

40 CFR 761-For Disposal Information contact the nearest US. E.P.A. Office.

In case of accident or spill, call roll free the US. Coast Guard National Response Center:

800:424-8802

Also Contact - FulCircle Ballast Recyclers - Tel. No. Brom, YI 10474 - 509 "ids Stree t

~0 m w - . Tel . lo. (n8) 328-4667

m USEPA ID NO. ~ ~ i m i l i l t l i m

16

Chi

cago

, IL

6064

6 (S

OO) 6

21-5

806

HM

SLS

l

UNIFORM HAZARDOUS WASTE MANIFEST

W A I Desianated Facilitv Name and Site Address

Manifest DOCUmenl N~ 2 Page 1 Information in the shaded areas

I 0 0 0 0 1

1 Generators US EPA ID No

4 0 CFR PART 76 1 of 1 snot required by Federal law

L , , , , , , , , . , . IF. Transportel 10 US EPA ID Number i G State Facili

ABC Facility Owner I Generatoh Name and Mailing Address

123 Energy Street, Anytown, USA 44999

INS ID

A State Manifest Document Number

B State Generatots ID

FulCircle Ballast Recyclers I 509 Manida Street

NY in474 I NYD 986 980 233 . H Facility% Phone

718-328-4667

1.

>.

RQ, Polychlorinated Biphenyls, Mixture, 9 UN2315 - PG I11 __

12 Containers

No IType I 1 US DOT Description (Includmg Proper Shrpprng Name Hazard Class and ID Number) m

13 14 f Total Unit WasteNo

Quantity Wgol

Used fluorescent light ballasts containing small capacitors. Ballasts are being shipped for reuse, reconditioning and recycling.

In Case of an Emergency, call FulCircle Ballast Recyclers at: IS. Special Handling Instructions and Additional lnformalion

1-718-328-4667 16. GENERATOR’S CERTIFIWTlON I hereby declare that the conleas of this consignment are fully and a~~urs le iy described above by

pope! Shlppng name and are ClaSJled. packed. marked. and labeled. and are 8n all respecls m proper mnditlon lor lransporl by hlghway

I1 I am a large quanllty generalw. I certly lhal I have a pmgram In place 10 reduce the volume and loxiclly 01 waste generated lo the deg:ee I have determined Io Dt B C m i C a l l y practrable and 1 b 1 I have relected Ihe practicable metMd of Ireatmen!. slorage or d#sposal cuirenlly available Io me which mlnlmlzes the present M Mum lhreal 10 human health a M the mvlrMmel. OR. 11 I am a small quanllly generator. I have made a good ldilh enol! 10 minlmlze my waste generatan and odec the tesl wale management mmhcd lhal D available 10 me and lhal I can anod

accadjng IO appica~le mternaiwi ana “mi government reguiai~onr

Month Day Yes Printed/Typed Name [ Signature

1. Additional Descriptions for Materials Listed Above K. Handling Codes for Wastes List& Above

Printed/Tywd Name

18

Signature Month Day Yes

Printed/Typed Name Signature Month Day Yes

Printed/Typed Name Signature Month Day Yez

1 If a generator stores fewer than 10 drums of lealung ballasts, then no EPA approval is required except the filing of a Notice of PCB Activity. The generator must meet the storage requirements of the TSCA regulations (40 CFR 76 1.65). If a generator stores more than 10 drums of lealung ballasts or of any PCB waste, then EPA approval as a Commercial Storer is required.

Spills of more than 1 pound of PCBs must be reported to the National Response Center (1 -800-424-8802) and cleaned up immediately.

Transporting Ballasts (Each state has its own requirements.)

The shpment of hazardous materials is regulated by the US Department of Transportation (49 CFR Parts 100- 199). These regulations provide detailed instructions on how Hazardous Materials have to be identified, packaged, marked, labeled, documented and placarded. The performance- oriented packaging standards (HM-18 1) were issued on December 2 1, 1990 with an effective date of October 1,199 1. Specific requirements are being phased-in from 199 1 to 200 1.

The regulations require that PCB ballasts be shpped in packages whch meet Certain perfomance standards, e.g. 17H and 17C drums. The new DOT regulations also refer to these drums as UN 1A2 packages. The Containers must be marked with a Class 9 label and the contents identfied by the proper slupping name:

RQ, Polychlorinated Biphenyls mare, 9, UN 23 15, PG 111.

Ballasts may generally be transported using a common carrier because of an exemption for placarding and registering vehicles canylng Class 9 materials.

However, some states which class@ PCB ballasts as hazardous waste also require a hazardous waste transporter. There are some exceptions. Check with your state for all necessary requirements.

Lists of hazardous waste transporters are available from your state environmental agency.

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A hazardous waste traqnnter must be licensed withm the states in whch it picks up and disposes of hazardous or regulated waste. Each state has many requirements for the types of trucks, maintenance, placarding, training of hvers , safety and contingency plans, financial assurances, insurance, etc.

Under Federal law (TSCA), a transporter whch hauls PCB waste must file a Notification of PCB Activity with EPA.

XI. DISPOSAL OPTIONS

There are at least 7 disposal options.

A. Leaving the disconnected PCB ballast in the ceiling (not recommended)

B. Municipal solid waste landfill (not recommended)

C. Municipal incinerator or resource recovery facility (not recommended)

D. Chemical waste landfill (acceptable, but future liability remains)

E. Whole ballast incineration in PCB incinerator (recommended but expensive and wasteful of natural resources)

F. Chopping open the ballast (not recommended)

*G. Capacitor removallincineration and recycling (hlghly recommended)

* Only option G can be fully recommended.

A. Leaving the PCB Ballast in the Ceiling - Not Recommhded

This practice may be inexpensive in the short term, but it is really only deferring the cost of removal and disposal. It is dangerous because in the event of a building fire, the PCBs in the ballast may volatilize and contaminate large portions of the building. This may result in a challenge by the insurance carrier to paying the hgh cost of a TSCA clean up.

Ifthe building is ever sold or mortgaged, environmental auditors often require the removal of PCB ballasts along with other hazardous materials, e.g., asbestos or lead paint. Hiring a contractor to remove ballasts alone will be much more expensive than removing them during a lighting upgrade.

2 0

Utilities offering rebates do not favor this option since it is too easy to re- connect the old, inefficient ballast when the new ballast fails. Ths would defeat the purpose of their original rebate.

If the ballast contains potting material over 50 ppm, leaving the disconnected ballast is the ceiling may be considered improper storage of PCB Articles and a violation under TSCA.

B. Municipal Solid Waste Landfills - Not Recommended

Even though landfilling is low in short-term costs, it is not recommended for environmental reasons and has potentially large contingent liabilities.

It is illegal to dispose of PCB ballasts in a municipal solid waste lan&ill if the asphalt potting material has in excess of 50 ppm PCBs.

Municipal solid waste landiills are not designed to handle the liquid PCBs found in the pre 1979 ballast capacitors, which are essentially steel or aluminum cans that will eventually corrode or rupture and cause PCB leaks. This could lead to hture Superfimd liability for you or your company.

As discussed in Appendix C, one pound of PCBs, whch is contained in 25 or more PCB ballasts may be a Reportable Quantity under the Superfund laws.

Disposal of large quantities of PCB ballasts in municipal solid waste landfills is not permitted in the states whch class@ PCB ballasts as hazardous waste, and may not be allowed in the other states which may have special requirements for PCB ballasts.

Disposal of leaking ballasts is not allowed in municipal solid waste lan&ills under Federal law (TSCA).

The proposed PCB Amendments require that any person disposing of 25 or morePCB ballasts dispose of them in a TSCA approved, PCB disposal facility and not in a municipal solid waste landfill.

C. Municipal Incinerator or Resource Recovv Facilities - Not Recommended

These facilities are not designed to handle PCB ballasts, whch are over 80% metal. Because of the solid metal mass and the fact that the PCBs are contained inside steel cans, a municipal incinerator cannot destroy all of the PCBs. It is likely that the ash will contain PCBs and unburned metal parts. In addition,

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many incinerators burn at lower temperatures or do not have the specialized control and monitoring systems required of PCB incinerators.

In a PCB incinerator, the ballast or capacitor is shredded prior to incineration. During incineration, combustion conditions are carefully monitored to ensure a 99.9999% (six nines criteria) destruction of the PCBs, and the ash is carefully tested. A municipal incinerator or modem resource recovery facility is not speclfically designed to destroy PCBs or handle large metal objects.

D. Chemical Waste LandfUs - Acceptable but Not Recommended

Some PCB ballasts are disposed of in th~s manner because of its relatively low cost ($1 -$2 per F40 ballast fkom a 4-foot fixture). However, secure chemical waste landfills are not designed to handle PCB liquids and materials with over 500 ppm PCBs. A PCB ballast has both. PCB ballasts contain PCB liquids of virtually pure PCBs (e.g., 700,000 to 1,000,000 ppm PCBs) and pose risks to chemical landfills.

The Superfund laws still apply although this option is permissible under TSCA.

Lealang ballasts and capacitors are regulated PCB Articles containing over 500 ppm of PCBs and therefore cannot be disposed of in a chemical waste landtll. They must be incinerated.

Many chemical waste lan&ill operators require that PCB liquids be drained prior to landf3hng. Draining the ballasts or capacitors is not practical and some chemical waste lan&ills will not accept ballasts.

If you do decide to landfill, put absorbent material at the bottom of the drum and in the interstitial areas between the ballasts. (Do not do this ifvou are recvcling your ballasts).

The EPA has a list of chemically secure landfills whch can be obtained by calling the TSCA Hotline (1-202-554-1404).

E. Whole Ballast Incineration at a PCB Incinerator - Recommended but exDensive and wasteful of natural resources

This option involves sendmg the entire ballast to a permitted, PCB solids incinerator. The only five facilities which can accept PCB ballasts for incineration are:

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Rollins Environmental Service Deer Park, Texas Coffeyville, Kansas

Aptus Environmental Services

(7 13) 930-2334 1-800-292-2558 and

Chemical Waste Management Aragonite, Utah Port Arthur, Texas 1-800-53 1-4200 (409) 736-2821

Clive Incineration Facility - USPCI Lakepoint, Utah (801) 595-4400

The advantage of this option is the permanent destruction of PCBs by incineration. The risk of hture Superfund liabilities is minimal.

The disadvantage is the high expense, e.g., $4-6 per F40 ballast eom a 4-foot fixture and wasteful of natural resources. Incineration also generates a great deal of residual metals because the ballast is 80% metal, does not burn and has to be 1anXilled afterwards. It is also wasteful of valuable metals whch can be recycled.

F. Cutting Open the Ballast - Not Recommended

Some companies saw the ballast open and dispose of the portion containing the capacitor as hazardous waste (incineration or chemical waste landfill). The other section is sent to a municipal solid waste lanXill.

Chopping open a ballast with a saw or guillotine without proper safety devices is a dangemus practice and can result in a PCB spill. A rupture of the capacitor could expose workers to PCBs and result in a release of PCBs into the air or onto the ground. In addition, sawing the ballast releases PCB-contaminated asphalt dust into the air which spreads contaminants and is very dangerous to the workers.

Also, this practice does not deal with the problem of PCB-contaminated asphalt. Ifthe asphalt contains over 50 ppm, as is usually the case, it must be treated as hazardous waste.

G. PCB Removal, Incineration and Recvcling - Highlv Recommended

In our opinion the best option is the removal of the 4-ounce capacitor and asphalt potting material from the 3.5-pound ballast, incinerating only the PCB- contaminated material (e.g. Capacitor, contaminated potting material and

2 3

leaking ballasts), and recycling the remaining uncontaminated metals (copper, steel and aluminum). Over 80% of the ballast by weight is recoverable.

This option ensures permanent destruction of the PCBs by incineration and is 30-50Y0 lower in cost than whole ballast incineration. It also generates less ak pollution and ash, uses less fuel, and reclaims valuable c o m d t i e s .

H. Economics

The economics of the 7 disposal options are evaluated on the following table.

Cost of Ballast Disposal

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ECONOMIC EVALUATION OF DISPOSAL OPTIONS

Option

A. Leavingin ceiling

B. Municipal solid waste landl3l

C. Municipal solid waste incineration

D. Chemical waste landfill

E. Whole ballast incineration

F. Chopshop ballast

G. PCB removal incineration and recycling

Disposal cost

deferred

10-206 per ballast

10-206 per ballast

$1-2 per ballast

$4-6 per ballast

$3-5 per

$2-4 per ballast

Environment a1 Cost

high

medium

low

very low

Overall

not recommended

not recommended

not recommended

acceptable, but future liability remains

recommended, but expensive and wasteful

not recommended; dangerous

strongly recommended; best option

Note: These dsposal costs are for F40 ballasts from a 4-foot fixtures in quantities of loo0 or more ballasts in major metropolitan areas. Disposal costs for F96 ballasts from %foot fixtures are typically 2-3 times greater because of the greater weight. High Output (HO) and Very figh Output (VHO) ballasts are even heavier and cost more.

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XII. WHYRECYCLE?

We believe that capacitor removallincineration and recycling of the non- contaminated components is the best disposal option of the 7 discussed in the previous section because:

Incineration of the PCB components results in the permanent destruction of PCBs.

It is lower in cost (30-50% lower) than whole ballast incineration, and does not create a potential future cleanup cost as is the case with landfilling or leaving the ballasts in the ceiling.

It conserves valuable resources. Reclaiming copper, steel and aluminum displaces the use of virgin materials, saving energy and natural resources.

It saves landiill space. Whether you were planning to landfill the ballast or incinerate it whole, decidmg to recycle instead keeps re-usable metals out of the landfill.

Compared to whole ballast incineration, recycling generates less air pollution and ash. In additio~ it uses much less fuel to burn !4 pound of PCB material than a 3.5-pound ballast, whch is 80% metal.

Recycling is the right thmg to do. Many govemmental entities have recycling mandates as goals. Recycling ballasts helps meet these goals.

XIII. NON-PCB BALLASTS

When PCBs were banned in 1979, one of the most commonly used chemicals to replace them in ballast capacitors was di (2-ethylhexyl) phthalate or DEHP. DEHP is found in F40 ballasts manufactured between 1979 and 1985, and in F96 ballasts manufactured between 1979 and 1991. Although probably less toxic to humans and the environment than PCBs, DEHP is a probable human carcinogen. As a result, it is regulated by a variety of environmental laws.

Under the Superfimd laws (CERCLA), DEHP is a listed hazardous substance. If a person disposes of DEW ballasts in a landfill and this causes DEHP contamination, then the person involved may be liable for the clean up of DEHP in the future.

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DEHP ballasts are not regulated under RCRA, the main hazardous waste law in the U.S. However, DEW in its pure chemical form is a listed hazardous waste (Waste Code U028) prior to its being "used". DEHP is also regulated by 10 states and 2 cities.

Recycling costs for DEHP ballasts are the same as for PCB ballasts. We recommend DEW ballasts be handled in the same manner as PCB ballasts to avoid potential Superfhd liability.

XIV. HOW TO SELECT A DISPOSAURECYCLING VENDOR

The short answer is: Very Carehlly! Remember - if the vendor contaminates the environment, you may be responsible for cleaning up their mess!

Please consider the following checklist when selecting a company which removes the PCB capacitor from a ballast and recycles the remaining material. Ths checklist is not intended for selecting a PCB incinerator or a landfill.

Permits and Regulations

1. Is the facility an approved Commercial Storer Over 500 gallons of PCB Waste under EPA's TSCA regulations? Does it have the necessary state and local permits?

2. Does the facility have an Alternative Disposal Method approval for ballast recycling from the EPA?

3. Check with local, state and Federal environmental agencies for infixmation on past violations. Is the company viewed favorably by its regulators?

Safetv Precautions

1. Is the facility a chop shop? How does it remove the capacitor? Does it use a saw or guillotine without proper safety precautions?

2. How does the facility remove the asphalt potting material? Are they aware that it is often contaminated with PCBs? How do they ensure that the metals are clean of contaminated asphalt? What are its standards for metals

3. How does the company test for PCB contamination? Does the company have an in-house lab or contract with a State Certified outside lab?

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4. Does the facility have the following environmental planning documents?

- Closure Plan, funded with a bond, trust fund or escrow account

- Hazard Communication Plan

- Spill Prevention and Countermeasure (Contingency) Plan

- Quality Assurance/Quality Control (QNQC) Program

- Worker Safety Training Program (40 hour OSHA training and HAZWOPER training)

- Sampling protocol for metals cleanliness approved by the EPA

5. Is proper protective equipment available and used by the employees?

Financial

1. Do the company's fmancial statements show stability and e€ consistent profitability for at least 3 years?

2. Does the company have a favorable Dun & Bradstreet rating and a positive net worth?

3. Does the facility have $5 million of pollution liability insurance?

4. What financial assurances has the company provided to the EPA to fund its closure requirements? Have these assurances been approved in writing by the EPA?

DisposaVRecvcling Outlets

1. What is the recycler's reputation with its PCB incineration company? How much material has been shpped there?

2. Does the facility have contracts with foundnes or mills for copper, steel and aluminum? Has the company completed an environmental audlt of these facilities?

3. How does the facility dispose of its asphalt potting material?

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4. How is the metal cleaned before it is reclaimed? What levels of cleanliness are acheved?

5 . What is the sampling protocol for the metals prior to slupment?

Facility Cleanup

1. What type of monitoring is conducted to prevent and detect PCB contamination?

2. Does the facility conduct PCB air monitoring?

3. How often are wipe tests performed on facility floors?

4. How often are the floors cleaned? How are tools cleaned? What is done with the sweepings or wash water?

Experience

1.

2.

How many Fortune 500 companies are on the recycler's customer list?

What volume of ballasts has the recycler processed?

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XV. ABOUT FULCIRCLE

FulCircle is a fuuy licensed contractor permitted to dispose of and recycle PCB and non-PCB ballasts. The company has a 1 3,500-foot2 facility in the Hunts Point area of the Bronx in New York City.

FulCircle is one of two ballast recyclers in the United Sates to receive fiom the EPA an Alternative Disposal Method approval for ballast recycling and a related Commercial Storer approval.

In FulCircle's process, the ballast is disassembled carefully. The capacitor is removed, packaged in steel drums and shipped off-site for destruction by incineration. Contaminated asphalt is incinerated, the metals are cleaned and then tested before being recycled. The clean metals are sent directly for smelting and reuse in new metal products.

For nationwide service or a quotation on handling your ballasts, FulCircle can be reached at:

For Sales 1-800-775-15 16

Atlanta Baltimore Boston Chcago Detroit Houston New York Philadelpha San Francisco Los Angeles

For Customer Service 1-800-581 -0857

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I

APPENDIX C: Memo from EPA on Superfund Liability

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

APR 1 6 1992

OFFICE OF PEST~tDES-AHDTOXK;

SUBSTANCES

NOTE TO: Hank Habicht

RE : Disposal of PCB-containing Fluorescent Light Ballasts

As a result of inquiries from Region X I you asked us to resolve with the Office of Air and Radiation (OAR) the question of disposal of PCB-containing fluorescent light ballasts in relation to the Green Lights Initiative. Working with OAR we reassessed the disposal requirements under TSCA and assisted in developing the attached materials distributed by EPA for the Green Lights Program.

light ballasts (relamping) for energy conservation under the Green Lights Initiative. These relamping projects could result in large numbers of PCB-containing fluorescent light ballasts being disposed of in municipal solid waste landfills.

Currently, EPA is advocating the replacement of fluorescent

The PCB regulations promulgated under the Toxic Substances Control Act (TSCA) allow the disposal of intact, non-leaking small capacitors containing PCBs in municipal solid waste landfills. Most fluorescent light ballasts manufactured prior to 1978 contain approximately 0.5 ounces of PCBs in a small capacitor. In 1978, EPA estimated that there were approximately 850,000,000 PCB-containing fluorescent light ballasts in use in the United States. However, due to the difficulty and associated cost in removing small capacitors from their associated electrical equipment, EPA determined that random disposal in municipal landfills of these small capacitors containing PCBs would not present an unreasonable risk to health or the environment. The information developed for the original rules regarding enforcement difficulties, collection and concentration problems, and cost associated with removal of PCB-containing small capacitors is still valid.

In 1982, EPA again reviewed the issue of small capacitors, this time in regard to their potential phaseout. EPA stated that these PCB-containing small capacitors are: encapsulated, often surrounded by significant amounts of absorbent material such as paper (100 to 1000 times the weight of the PCBs in the case of light ballasts), and rarely release PCBs to the environment ( 4 7

33 @ Prinfedon Recycled Paper

2

FR 37349). However, EPA Cannot be positive that small amounts of PCBs could not, over time, leak out of landfills and contaminate the environment. EPA continues to encourage disposal of large quantities of PCB-containing small capacitors in a chemical waste landfill or a high temperature incinerator by commercial and industrial firms, such as those involved in relamping projects.

These relamping projects have also raised questions about

These individuals may also be required to

the liability for the release of a hazardous substance (e.g., PCBs) under section 107 of CERCLA for individuals involved in relamping projects. notify the Emergency Response Center of each release of a reportable quantity (1 pound) of PCBs under section 102 of CERCLA (40 CFR 302.4). liability and lead to possible future involvement in any remediation at municipal solid waste landfills receiving such waste. The definition of release under CERCLA includes virtually all ways that hazardous substances may enter the environment, including the removal and disposal of PCB-containing fluorescent light ballasts.

EPA is aware that relamping projects such as the Green Lights Initiative have the potential to concentrate the disposal of PCB-containing fluorescent light ballasts in a limited number of landfills, thereby removing the random distribution in municipal solid waste landfills originally contemplated in the 1978 and 1979 PCB regulations. EPA's current policy is not to further regulate the disposal of fluorescent light ballasts under TSCA while notification under CERCLA for disposal of PCB- containing fluorescent light ballasts is a requirement. The CERCLA notification requirement and liability provisions should be considered before undertaking a green lights program. The existing PCB rules under TSCA allow the disposal of intact and non-leaking PCB-containing fluorescent light ballasts in municipal solid waste landfills. At the same time, CERCLA requires those who release 1 pound or more of PCBs to notify the Emergency Response Center, thereby identifying them for possible future liabilities for disposal. This paradox in disposal verses liability requirements under Federal laws finds a parallel in RCRA's small quantity generator requirements which would allow similar disposal of thousands of one ounce capacitors every month in municipal solid waste landfills but not protect small quantity generators from liability for this practice under CERCLA.

to relampers, OPFT staff has worked closely with the Green Lights staff to ensure that materials they develop are accurate and reflect our position on the handling and disposal requirements for PCB-containing fluorescent light ballasts. The EPA Green Lights Program has developed the attached "Light Brief" outlining the regulatory requirements under both TSCA and CERCLA. They have also developed the attached chapter entitled "Waste

This notification would firmly establish their

Therefore, in an effort to provide information and guidance

34

3

Disposal" for the "Lighting Upgrade Manual (Kl), EPA Green Lights Program" which provides more detailed information than the "Light Brief." The Waste Disposal chapter includes a variety of information sources such as EPA Regional Offices, State Solid and Hazardous Waste Agencies, EPA Approved Oisposal Locations, and Recycling Resources.

ballasts is the most environmentally correct thing to do. Recycling capacity may be increasing, but at this time it is very limited. Forcing everyone into expensive incineration or chemical waste land disposal of the entire ballast would increase the costs of relamping projects and further reduce limited disposal capacity. However, forcing everyone to recycle could slow or halt many relamping projects with little prospects for significant environmental benefit. With a normal failure rate for ballasts of 10-15% per year and the large increases in disposal rates since the Green Lights program went into effect, the numbers of PCB containing ballasts remaining in service is believed to be relatively small.

'

We believe removal and recycling of PCB-contaminated light

The ballast disposal guidance developed in conjunction with Green Lights provides a balance between the benefits of the Green Lights program and the risks posed by the remaining PCB- containing ballasts, a disposer's liability under CERCLA, and any environmental gain that could be realized through new regulations.

If you would like to discuss this matter further, please contact me (260-2902) or Mark Greenwood (260-3810).

Enclosures

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APPENDIX A: Identifying Fluorescent Light Ballasts Which Contain PCBs

Advance Transformer

Stopped using PCBS in 1978-1979.

Ballasts stamped with a date earlier than 1978 should be assumed to contain PCBs.

Ballasts which do not contain PCBs will state on the label "No PCB".

General Electric (which sold its ballast business to Valmont Electric in the early 1980's)

Used in all high power factor (HDF) ballasts ma& between 1953-1979.

Date of manufacture is stamped on ballast using a letter date code (see next page).

Changed &om PCB to non-PCB during 1977-1978.

HDF ballasts made during 1977-1978 which do not contain PCBs will have a "W" added after the catalog number.

All ballasts ma& after 1979 will state "No PCB" on label.

Jefferson Electric (now owned by MagneTek, Inc.)

Stopped using PCBs during 1977-1979.

Non-PCB ballasts made during 1977-1979 will be marked with a green dot and possibly marked "No PCB" on label.

Ballasts stamped with a date prior to 1977 contain PCBs.

Ballasts made after 1979 will be marked "No PCB" on label.

Universal (now owned by MagneTek, Inc.)

Ballasts made prior to January, 1979 contain PCBs.

Ballasts made starting January, 1979 will state "No PCB" on label.

Source: Wisoonsin Department of Natural Resources, Advance Transformer, General Electric and MagneTek.

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APPENDIX B: SPECIFICATIONS FOR PCB AND DEHP BALLAST DISPOSAL BY INCINERATION AND RECYCLING

What is "proper disposal"? Federal and State regulations are both lax and confusing and can E t be relied upon to answer this question. For example, these regulations allow PCB and DEW ballasts to be landfilled.

Building owners, architects and engmeers should be concerned about proper disposal because of future Superfund clean-up liability. Ths specification is designed to protect customers from improper disposal.

This specification is also designed to create a level playing field among electrical contractors bidding on lighting retrofit projects.

The following is a short form, standard clause for inclusion in contracts between building owners and electrical contractors involved with a lighting retrofit project. It can also be used by utilities offering rebates for lighting improvements.

All ballast components which contain polychlorinated biphenyls (PCBs) shall be incinerated pursuant to the U.S. Environmental Protection Agency Final Rules 40 CFR 761.70. All ballast components which contain diethylhexyl phthalate @ E D ) shall be incinerated pursuant to 40 CFR 761.70 or 40 CFR 264 Subpart 0. All uncontaminated (less than 100 ug/100cm2 PCBs) metal components of the ballast shall be recycled, recovered or reclaimed as per FulCircle Ballast Recyclers or equivalent. Disposal Contractor shall pmvide a manifest and certificate of destruction pursuant to 40 CFR 761 Subpart K. Disposal Contractor shall have at least $5 million of pollution liability insurance. Disposal contractor shall have an Alternative Disposal Method approval for ballast recycling pursuant to 40 CFR 761.60(e) and a Commercial Storer approval for over 500 gallons of PCB waste pursuant to 40 CFR 761.65(d).

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