COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108 617-292-5500
BUREAU OF WASTE PREVENTION
POLICY FOR DISPOSAL OF LIGHTING BALLASTS FROM FLUORESCENT
LIGHTS CONTAINING PCB-IMPREGNATED CAPACITORS
The utility companies and U.S. Environmental Protection Agency (EPA) have initiated a program to replace existing lighting ballasts which historically have contained capacitors impregnated with polychlorinated biphenyls ("PCBs") with ballasts which are more energy efficient. Lighting ballasts generally consist of a housing unit which contains a capacitor, wire and asphalt material. Under this program, contractors remove and collect the old lighting ballasts. The Department of Environmental Protection ("Department") acknowledges that the replacement ballasts generally do not contain PCBs. The Department has developed this policy in an effort to encourage recycling and waste minimization practices prior to disposal of the replaced lighting ballasts. The Department's policy for the proper handling, storage, transport and disposal of lighting ballasts is described in the following paragraphs.
The Department has information that leads it to assume that capacitors found in existing lighting ballasts contain PCBs greater than 50 ppm, and therefore such capacitors, when separated from the lighting ballasts, are identified as hazardous waste pursuant to 310 CMR 30.131, and must be managed as a hazardous waste in accordance with 310 CMR 30.000. A hazardous waste transporter must be used to transport the PCB capacitors or ballasts that contain PCB capacitors if such items are intended for disposal. In addition, such items must be disposed of at a licensed hazardous waste treatment, storage or disposal facility if they are being disposed of in Massachusetts. Out of state disposal must be in compliance with the laws of the state where disposal occurs.
Under this policy, the Department will consider a contractor's central receiving location the site of hazardous waste generation. Accordingly, the Department will not require the use of a hazardous waste transporter and manifest for transport of intact non-leaking lighting ballasts to the contractor's central location for subsequent processing (removal of capacitors) or accumulation provided that all such ballasts and/or components are subsequently properly transported off-site in accordance with 310 CMR 30.000, either as a hazardous waste for disposal, or as a regulated recyclable material for recycling. If any of the ballasts and/or capacitors are leaking, they must be managed as a hazardous waste. A hazardous waste manifest shall not be used for transport of non- leaking lighting ballasts to the contractor's central location unless such location is a treatment, storage or disposal facility. A licensed hazardous waste transporter and manifest MUST be used and the waste disposed of as a hazardous waste if the ballasts and/or capacitors are leaking. If the capacitors are being disposed of in another state, the generator must comply with that state's requirements for disposal of PCB capacitors.
This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD# 1-866-539-7622 or 1-617-574-6868.
MassDEP on the World Wide Web: http://www.mass.gov/dep
Printed on Recycled Paper
Under this policy, the contractor becomes the generator of record if the intact, non-leaking lighting ballasts are transported to the contractor's central location, and as such the contractor must obtain a site specific Environmental Protection Agency (EPA) Identification Number for that central location. If the PCB capacitors are separated from the ballasts at that central location, the contractor must register for the hazardous waste generator status which appropriately reflects the quantity of PCB capacitors which the contractor typically generates each month. If the contractor simply stores the ballasts and does not separate the PCB capacitors prior to disposing of the ballasts as a hazardous waste, the contractor must estimate his generation rate based on the weight of the entire ballast and then register for the appropriate hazardous waste generator status. The contractor must base the accumulation start date for the intact ballasts or separated capacitors on the date the ballasts are received at the contractor's central location.
All generators are responsible for determining if the waste they generate is hazardous waste. To determine if the asphalt contained in the ballast meets the Toxicity Characteristic of hazardous waste, an analysis consisting of a composite sample of the asphalt material from several ballasts may be tested according to the Toxicity Characteristic Leaching Procedure (TCLP) described in 310 CMR 30.125. If the asphalt waste stream is consistent, the Department believes a one-time analysis is sufficient to determine the Toxicity Characteristic. If the asphalt material fails the Toxicity Characteristic, then it must be disposed of as a hazardous waste. The generator may also apply for a recycling permit for the asphalt material. Applicability of such permits will be decided on a case-by-case basis by the Department. Otherwise, the ballasts, without the PCB capacitors, may be disposed of as a solid waste if the asphalt tests non-hazardous.
The Department reserves the right to modify or withdraw this policy at any time should additional information require such action.
Questions should be addressed to James Paterson at (617) 556-1096.
Effective Date: January 16, 1992
Steven A. DeGabriele
Division of Hazardous Waste