MEC&F Expert Engineers : PCB-Containing Fluorescent Light Ballasts (FLBs) in School Buildings

Wednesday, October 14, 2015

PCB-Containing Fluorescent Light Ballasts (FLBs) in School Buildings




PCB-Containing Fluorescent Light Ballasts (FLBs) in School Buildings

A Guide for School Administrators and Maintenance Personnel

NOTE: This guide may also be used by other building owners or operators to manage their PCB-containing FLBs
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TSCA Information Hotline
For additional information call:
202-554-1404
Highlights
Get more information on TSCA disposal requirements for FLBs (PDF) (1pg, 8K)
Page Contents:
Introduction

An intact FLB from a typical pre-1979 FLB.
The purpose of this website is to provide information to school administrators and maintenance personnel on the hazards posed by polychlorinated biphenyls (PCBs) in PCB-containing FLBs, how to properly handle and dispose of these items, and how to properly retrofit the lighting fixtures in your school to remove potential PCB hazards.
It should be noted that procedures outlined on this website (with the exception of disposal requirements) are a guide to assist building owners and operators. States may have mandatory and more stringent requirements than EPA.
PCB-containing FLBs that are currently in use have exceeded their designed life span. Sudden rupture of PCB-containing FLBs may pose health hazards to the occupants and is difficult and costly to clean up. EPA recommends removing PCB-containing FLBs from buildings as soon as possible to prevent potential inhalation or dermal exposure. Even intact PCB-containing FLBs may emit small amounts of PCBs into the air during normal use. Removal of PCB-containing FLBs, as part of lighting upgrades or a stand-alone project, is an investment that may pay off with long-term benefits to students, school staff, the community, and the environment.
Congress banned the manufacture of PCBs in the United States in 1976 because of their toxic effects. In July of 1979, EPA phased out the processing or use of PCBs, except in totally enclosed equipment. However, a large number of FLBs that were installed prior to the ban, or that were stored and later used after the 1979 phase-out, may contain PCBs and may still be in use in U.S. schools. While the use of small capacitors in FLBs was authorized by EPA in 1982, if these capacitors are found to be leaking, then the spill area must be cleaned up as quickly as possible or within 24 hours (40 CFR section 761.125(c)(1)) and the leaking FLBs must be properly disposed of pursuant to 40 CFR section 761.62. EPA regulations also require that all FLBs built between July 1, 1978 and July 1, 1998 that do not contain PCBs must be labeled "No PCBs."

PCB-Containing FLBs in School Buildings

This FLB sparked a fire at a southern California school in 1999.
Schools in the United States built before 1979 may have PCB-containing FLBs. The PCBs are contained within the T12 FLBs' capacitors and in the FLBs' interior potting material. Only the T12 magnetic FLBs (not T8 or T5 FLBs) may contain PCBs. The "T" designates the lamp that goes with the FLB as "tubular" shape. The number after the "T" represents the lamp diameter in eighths of an inch.
As they age, the FLBs degrade and EPA’s Office of Research and Development (ORD) has determined that even apparently intact and non-leaking FLBs can release PCBs into the air. Depending on the number of operating hours, operating temperature, and on/off cycles, the typical life expectancy of a magnetic FLB is between 10 and 15 years. The total failure rate over the useful life of small capacitors in FLBs is about 10 percent (47 FR 37342, August 25, 1982). After this typical life expectancy, FLB failure rates increase significantly. All of the pre-1979 FLBs in lighting fixtures that are still in use are now far beyond their typical life expectancy, increasing the risk of leaks, smoking conditions, or even fires, which would pose health and environmental hazards.
The oldest PCB-containing FLBs may also be lacking in thermal overload protection. Thermally protected FLBs are marked with a "P" as required by the National Electrical Code. FLBs without a "P" marking do not contain a mechanism to prevent overheating and are at a higher risk of failure and creating smoke conditions. The potential spread of PCBs can be worsened by mishandling by personnel who are unaware of the presence of PCBs in FLBs. A FLB that has been damaged or mishandled in such an incident can increase exposure of students and school personnel to PCBs.
Recent reports from schools in New York and New Jersey show that FLB failures are not uncommon. From September 2012 to August 2013, 130 schools in New York and New Jersey reported FLB failures that may have released PCBs. And, 111 of the reports involved smoking or odor conditions from FLBs. FLBs may not always be located in fluorescent lighting fixtures. New York City public schools found remote FLB cabinets in the hallways of 16 of their school buildings. These cabinets are essentially large high voltage electrical panels that house up to twenty FLBs. EPA has also received reports of leaking PCBs in FLBs in schools in Oregon, North Dakota, and Massachusetts. Incidents where FLBs leak require cleanup and disposal actions according to federal law. These actions are discussed later in this guide.
The New York City Department of Education has instructed its staff to conduct regular visual inspections in their buildings of all lighting fixtures containing T12 lighting fixtures with FLBs that may contain PCBs. Other building managers may also wish to adopt this type of approach.

Exposure to PCBs from FLBs in Schools
The most likely way that people are exposed to PCBs from FLBs is through breathing PCB-contaminated air or touching PCB-contaminated materials after a FLB leaks or catches fire. Where they remain in place, leaking FLBs could continue to release PCBs over several years and generate elevated levels of PCBs in air that students and teachers breathe. PCBs are persistent, bioaccumulative toxicants. This means that they are most harmful when exposure accumulates over a prolonged period of time.
Since the likelihood of harm increases with increased exposure, the best protection is to remove leaking FLBs. Even intact FLB capacitors can lead to the presence of PCBs in school environments. PCB residues from previously failed FLB capacitors may remain in fixtures even if the FLB is replaced. Leaking or bursting capacitors are likely to substantially elevate PCB levels in indoor environments.
Steps should be taken so children and teachers do not continually spend time in an area with elevated PCB levels in their air. While students and teachers do not need to be evacuated from the building, the affected area, classroom, hallway, cafeteria, or auditorium should be off-limits during cleanup and decontamination. EPA developed Public Health Levels to help in determining if you have an inhalation exposure concern. Exceeding these levels does not mean that adverse effects will occur. However, as exposure levels increase, EPA has less confidence that the exposures will not result in adverse effects. Until the area meets EPA’s recommended Public Health Levels, the school should consider using appropriate temporary accommodations in the building for students and staff.
Read more information on the health effects of PCBs.


Image comparison of PCB-containing and Non-PCB containing FLBs.
+ Enlarged view
Identifying FLBs that May Contain PCBs
The following criteria are provided to help identify FLBs that may contain PCBs:
  • FLBs manufactured before July 1, 1979 may contain PCBs.
  • FLBs manufactured between July 1, 1978 and July 1, 1998 that do not contain PCBs must be labeled "No PCBs".
  • If an FLB is not labeled "No PCBs", it is best to assume it contains PCBs unless it is known to be manufactured after 1979.
  • FLBs manufactured after 1998 are not required to be labeled.
If the FLB does contain PCBs, they are located inside the small capacitor located within the FLB or in the potting material (a black, tar-like substance that encapsulates the internal electrical components). There would be approximately 1 to 1.5 ounces of PCBs in the capacitor itself and lower amounts in the potting material. If a FLB fails or overheats, the capacitor may break open and both its oil and the potting material may be released from the FLB. PCBs may be present as a yellow, oily liquid or in the tar-like potting material that leaks from the FLB. The capacitor does not always leak when the FLB fails, nor does a leaking capacitor always cause the FLB to fail. Leaking or ruptured FLBs may increase the level of PCBs in the air. Measures should be taken to limit or avoid personal exposure in all cases.
Determining Whether PCB-Containing FLBs are Present in Your School Building
If any of the statements below apply to your school, its FLBs probably contain PCBs and have exceeded their useful lifetime:
  • Your school was built before 1979; and
  • Your school has not had a complete lighting retrofit since 1979; or
  • Your school still has T12 magnetic FLBs.
Any building built before 1979 is likely to have PCB-containing FLBs if it has not undergone a complete lighting retrofit (all light fixtures in the school were upgraded). In some cases, PCB-containing FLBs that were manufactured before the 1979 ban were stored and later used in some fluorescent light fixtures installed or repaired after 1979. Thus, some schools built after 1979 that have not undergone a complete lighting retrofit could have PCB-containing FLBs. To determine whether your school has PCB-containing FLBs, conducting a visual inspection of the FLBs in a representative number of light fixtures (not just the bulbs) is recommended. For an example of how to determine what the representative number is, see Chapter 7 of the HUD Guidelines for the Evaluation and Control of Lead Based Paint Hazards in Housing (PDF) (74pp, 7.01Mb)

Figure 1. Flowchart on how to identify PCB-containing FLBs.
+ Enlarged view
Figure 1 can help you determine whether there may be PCB-containing FLBs in your school. The FLBs are contained within light fixtures. Because you may need to open the fixtures to view the FLBs, select a representative number of each type of fixture in use throughout the school to inspect first. Inspection may be accomplished by removing a portion of the fixture, such as the metal panel covering the FLB. Expand your inspection if you find PCB-containing FLBs.
To prevent exposure if leaking FLBs are discovered, EPA recommends:
  • Wearing protective clothing, including chemically resistant gloves selected for PCB resistance, disposable shoe covers, and disposable overalls as prescribed by OSHA.
  • Removing furniture and other classroom objects from underneath the fixtures.
  • Covering the floor with plastic sheeting to capture any material that might leak from the FLB or fixture.
  • Ventilating the room or use supplemental ventilation or respiratory protection to reduce the potential for breathing in fumes.
  • Keeping a record of the areas (e.g., classroom 101) and location of the fixtures inspected.
If the FLBs do not have the statement "No PCBs", you have two options:
  • Assume that the FLBs contain PCBs,

or
  • Contact the manufacturer and provide the light fixture brand, model number, and FLB serial number to determine whether the FLB contain PCBs. If the manufacturer is not sure whether the FLB contain PCBs, assume that it does.

Determining Whether You Should Replace Your PCB-Containing FLBs
A fluorescent lighting fixture retrofit might seem like a significant capital investment or low priority in schools when compared with other mandates and priorities. However, school administrators should take into account the potential effects of leaving PCB-containing FLBs in place and what they might have to address if a FLB unexpectedly fails, leaks, smokes, or catches fire.
A FLB failure, leak, smoking condition, or fire could: (1) happen at any time, without warning; (2) add to PCB levels in the air; and (3) may pose health issues for the staff or students who are exposed. When a FLB has leaked, significant costs could be incurred to cover, at a minimum:
  • Hiring experienced cleanup personnel.
  • Relocating of students and teachers from the affected area into temporary quarters during cleanup and decontamination which may disrupt school programs and functions.
  • Cleaning up and decontaminating of contaminated equipment and surfaces to required levels ( 40 CFR sections 761.61 or 761.79).
  • Complying with environmental regulations for proper storage and disposal of contaminated equipment and cleanup materials ( 40 CFR sections 761.65 and 761.60).
Postponing lighting retrofits and upgrades by leaving PCB-containing FLBs in place may result in adverse impacts for your students and staff and have additional cost impacts (e.g., lost school days, emergency spill clean-up costs, etc.).
On July 14, 2009, the Department of Energy (DOE) issued a final rule entitled Energy Conservation Standards and Test Procedures for General Service Fluorescent Lamps and Incandescent Reflector Lamps Exit EPA. The rule raises energy efficiency standards for certain fluorescent lamps for sale in the United States. After the DOE rule was promulgated the manufacture of many, but not all, T12 lamps used in fixtures that use PCB-containing FLBs were discontinued after July 14, 2012, because they did not meet the new efficiency standards. As a result, the supply of T12 lamps is expected to decrease over time and the cost of those that remain is expected to increase, adding a greater incentive to perform a retrofit of PCB-containing T12 lighting.

Cost Savings Associated with a Retrofit of Older Lighting
Replacing old lighting fixtures can not only increase energy efficiency and decreases energy costs, but may also increase property values, provides better lighting (in appearance and quality of light), and reduces the chance of emergency service situations. The retrofits can be done on an individual FLB basis (e.g., as found through visual inspection), or as part of a lighting retrofit which replaces the entire lighting fixture with newer, more energy efficient fixtures. A complete lighting retrofit eliminates the PCB hazards and increases energy efficiency by 30-50 percent (See the Energy Star website for more detailed information). Lighting retrofits to eliminate PCB-containing FLBs should be considered as a component of any remodeling effort. The T12 lamp and corresponding FLB is less energy efficient than other FLB lighting (e.g., T8 or T5 lighting). The cost of replacing these fixtures can typically be recouped in less than seven years depending upon hours of operation and local energy costs. Detailed information on the savings that may be achieved and potential funding that may be acquired through an investment in new lighting is available at the Energy Star website. The Energy Star website also provides information about funding that may be available for the replacement of old fixtures.
In most states, there are several agencies and organizations with funding available to support energy-efficiency projects or that provide ways to obtain financial assistance for making a building more energy efficient. Some of these programs cover conversion to more energy-efficient lighting. Additionally, many states, localities, and utility companies have programs for energy efficiency rebates and other benefits that may include converting to more energy efficient lighting. DOE published a guide (PDF) (46pp, 1.92Mb) in April 2013 to assist schools in funding energy efficiency upgrades. Specific programs to consider for assistance include:
  • Energy Star Program - Energy Star is a joint EPA and DOE program that supports schools, businesses, and organizations in installing energy-efficient lighting technologies. The program offers assistance through workshops 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 the Energy Star website.
  • Public Utilities and Energy Service Companies (ESCOs) - Both public utilities and ESCOs offer programs that provide technical assistance and funding assistance to support lighting upgrade projects. Contact your local energy utility company, an ESCO that services your area, or state energy commission for more information.
Recommended Procedures for Cleanup and Decontamination after a PCB-Containing FLB Leak, Smoking Condition, or Fire


An old FLB that burst unexpectedly.
An experienced contractor or experienced facilities staff person should perform the removal, cleanup and decontamination of PCB-containing FLBs that have leaked, smoked, or been on fire, including management and disposal of PCB-containing wastes generated from cleaning up such incidents.
Suggested steps to undertake include:
Preparation
  1. Isolate the affected area from central ventilation and ventilate the area separately to prevent the spread of debris and dust to other areas.
  2. Workers should wear personal protective equipment (PPE), including disposable coveralls, chemically resistant gloves, and disposable shoe covers selected for appropriate PCB penetration resistance, respirators equipped with organic vapor filters, and safety glasses, as a minimum.
  3. Move furniture and other classroom objects from underneath the fixtures and the floor should be covered with plastic sheeting to capture any material that might leak from the fixture.
  4. Turn off the light fixtures. In addition to turning off the fixtures or room switches, if present, turn off and lock out the fuses or breaker boxes that control the switches to the light fixtures or the fixtures directly.
Inspection
  1. Remove the lamp cover or grille (baffle) of the light fixture to expose the fluorescent lamp (tube).
  2. If the fluorescent tube is not contaminated with PCBs, it can be reused or recycled as Universal Waste. If the fluorescent tube is contaminated with PCBs, carefully remove it and place it in an approved Department of Transportation (DOT) container.
  3. Visually inspect the exposed section of the light fixture for potential PCB leakage or residue from a fire or smoking condition. If the light fixture shows signs of PCB leakage, then clean up according to step 12 below, then return to step 7.
Removal
  1. Remove the FLB enclosure cover (tray) within the light fixture to expose the FLBs.
  2. Remove the FLB by clipping and removing the wire at the face of the FLB and the exterior of the FLB and the interior exposed section of the light fixture including the housing (with FLB removed). Visually inspect the cover and wires.
  3. If leaking or staining is identified on the FLB or light fixture, then carefully remove them and place the items directly in an approved DOT container.

Cleanup and Disposal
  1. If no leaking or staining is identified on the light fixture, but there was asbestos-containing material (ACM) such as coated wire present, the fixture shall be disposed of as ACM waste. Otherwise, the fixture is not regulated PCB waste and can be recycled or disposed of as municipal solid waste.
  2. Clean up spills from PCB-contaminated light fixtures and leaking FLBs outside the light fixture (e.g., floors, desks, walls, etc.). ( 40 CFR section 761.61 or 761.79)
  3. Identify and properly manage PCB waste streams, including, where appropriate, the use of approved DOT containers, approved storage facilities ( 40 CFR section 761.65), manifests ( 40 CFR part 207), and records ( 40 CFR part 180), as provided below:
    • Leaking FLBs - PCB Bulk Product Waste for incineration.
    • Light fixtures contaminated with PCBs and associated clean-up waste (plastic sheeting, PPE, etc.) - PCB Remediation Waste for disposal in approved landfill.
    • Light fixtures not contaminated by PCBs with ACM wires - ACM waste for disposal in approved landfill.
    • Fluorescent lamps not contaminated by PCBs – Universal waste for recycling.
See the table (PDF) (1 p, 4 K) "TSCA Disposal Requirements for Fluorescent Light Ballasts" for additional disposal options for PCB and non-PCB-containing FLBs.
The above procedures are a guide to assist building owners and operators. Unique circumstances may be encountered in individual buildings and/or rooms. Contact your Regional EPA PCB coordinator with any questions.

Recommended Procedures for Performing a Retrofit for Non-Leaking PCB-Containing FLBs in Your School
NOTE: This section addresses non-leaking or otherwise uncontaminated FLBs. If you encounter a PCB-containing FLB that has leaked, been on fire, or smoked, refer back to the previous section Recommended Procedures for Cleanup and Decontamination after a PCB-Containing FLB Leak, Smoking Condition, or Fire for cleanup and decontamination procedures.
An experienced contractor or experienced facilities staff person should perform the lighting retrofit. Suggested steps include:

Preparation
  1. Turn off the light fixtures. In addition to turning off the fixtures or room switches, if present, turn off and lock out the fuses or breaker boxes that control the switches to the light fixtures or the fixtures directly.
Inspection
  1. Remove the lamp cover or grille (baffle) of the light fixture to expose the fluorescent lamp (tube).
  2. If the fluorescent tube is not contaminated with PCBs, it can be reused or recycled as Universal Waste. If the fluorescent tube is contaminated with PCBs, carefully remove it and place it in an approved Department of Transportation (DOT) container.
  3. Visually inspect the exposed section of the light fixture for potential PCB leakage or residue. If the light fixture shows signs of PCB leakage, then immediately refer back to the previous section Recommended Procedures for Cleanup and Decontamination after a PCB-Containing FLB Leak, Smoking Condition, or Fire for cleanup and decontamination procedures.
Removal
  1. Remove the FLB enclosure cover (tray) within the light fixture to expose the FLBs.
  2. Remove the FLB by clipping and removing the wire at the face of the FLB and the exterior of the FLB and the interior exposed section of the light fixture including the housing (with FLB removed). Visually inspect the cover and wires.
  3. Place the FLB directly in an approved DOT container.
Disposal
  1. If no leaking or staining is identified on the light fixture, but there was asbestos-containing material (ACM) such as coated wire present, the fixture shall be disposed of as ACM waste. Otherwise, the fixture is not regulated PCB waste and can be recycled or disposed of as municipal solid waste.
  2. Identify and properly manage PCB waste streams, including, where appropriate, the use of approved DOT containers , approved storage facilities ( 40 CFR section 761.65), manifests ( 40 CFR part 207), and records ( 40 CFR part 180), as provided below:
See the table (PDF) (1pg, 51K) "TSCA Disposal Requirements for Fluorescent Light Ballasts" for additional disposal options for PCB- and non-PCB-containing FLBs.

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