Removing and Disposing of PCB-Containing Light Ballasts

Technical Procedures Disclaimer

Prior to inclusion in GSA’s library of procedures, documents are reviewed by one or more qualified preservation specialists for general consistency with the Secretary of Interior Standards for rehabilitating historic buildings as understood at the time the procedure is added to the library. All specifications require project-specific editing and professional judgement regarding the applicability of a procedure to a particular building, project or location. References to products and suppliers are to serve as a general guideline and do not constitute a federal endorsement or determination that a product or method is the best or most current alternative, remains available, or is compliant with current environmental regulations and safety standards. The library of procedures is intended to serve as a resource, not a substitute, for specification development by a qualified preservation professional.


We’ve reviewed these procedures for general consistency with federal standards for rehabilitating historic buildings and provide them only as a reference. Specifications should only be applied under the guidance of a qualified preservation professional who can assess the applicability of a procedure to a particular building, project or location. References to products and suppliers serve as general guidelines and do not constitute a federal endorsement nor a determination that a product or method is the best alternative or compliant with current environmental regulations and safety standards.



  1. This specification applies to Polychlorinated Biphenyls (PCB)-containing light ballasts to be removed, transported and disposed of in off-site treatment, storage, and disposal facilities which have been approved by the EPA for handling PCB. This Contractor shall provide all work herein.

    1. The fixtures with PCB-containing light ballasts will be taken down and stacked in construction staging area by Electrical Contractor.

    2. Removal of ballasts shall be performed in the staging area by Abatement Contractor.

    3. General Contractor shall dispose of remaining fixtures after ballasts are removed as general construction waste.

  2. The work includes the following:

  3. Partial dismantling of light fixtures and separation of ballasts to permit ballast removal and total removal of ballast from fixture.

  4. Cleaning of any PCB contamination on fixtures and surfaces.

  5. Placement of all PCB or PCB contaminated items generated as a result of work activities in approved disposal containers.

  6. Marking and labeling of all PCB Articles and Items for disposal.

  7. Transportation of all PCB articles, items and containers to EPA-approved off-site treatment, storage, and disposal facilities. Treatment facility shall be approved for disposal of PCB waster prior to transportation of PCB waste.

  8. Provide completed Uniform Hazardous Waste Manifest from the transporter and Certificate of Destruction from the treatment, storage, and disposal facility.

  9. Abatement Contractor shall pay all necessary fees and permits related to the removal, handling, transportation and disposal of PCB articles and items.


  1. Submit complete lists of all materials and equipment proposed for use in the work, e.g. protective clothing, breathing apparatus, sorbents, solvents, drums and containers. For all materials, provide the following information

    1. Name of manufacturer

    2. Brand name

    3. Catalog number

    4. Material Safety Data Sheets (MSDS) (if available for material)

    5. OSHA Form 20 (if available for material)

  2. Submit hazardous materials cleanup agencies contact information, 24-hour manned telephone numbers and phone numbers of personnel working on project, as appropriate.

  3. Submit method of removal and routes to be taken to exterior and loading area required.

  4. Submit completed PCB waste manifest.

  5. Submit a Statement of Qualifications for review and approval. The Contractor shall submit the Statement sufficiently far in advance of the performance of the work as to permit adequate time for the consultants to review and accept a firm to perform the work. The Statement shall provide sufficient data and information to prove to the satisfaction of the consultant that the firm performing the work of this section is fully experienced in the removal, handling, transportation, and storage of PCB and PCB-contaminated articles and Items.


  1. Single Party Responsibility: The firm performing the work of this section shall be responsible for, all the PCB-related activities as noted on the drawings and included herein.

  2. Supervision

    1. All PCB-related work, including separating of ballasts from light fixtures and handling or movement of PCB fluids, solids or other PCB items or material of any type, shall be conducted under the direct supervision of a qualified PCB Services Supervisor.

    2. These activities shall only be undertaken as directed by the PCB Supervisor under the authority of, or as ordered by, the GSA Contracting Officer.

    3. The Contractor shall provide the services of a qualified PCB Service Supervisor.

    4. The qualification of the PCB Supervisor shall be:

      1. Prior attendance at and satisfactory completion of an examination following a documented formalized training course on regulations and procedures for handling, marking, transportation, disposal spill prevention/clean-up, safety precautions, and testing of PCB items.

      2. Training in and awareness of obligations and responsibilities for protection of people, property and environment from hazardous waste exposure or contamination.

  3. Regulatory Requirements

    1. License Requirements: The firm performing the work of this section must be currently licensed by the applicable regulatory agency and have a current EPA authorization number for the transporting and hauling of extremely hazardous wastes including PCBs.

    2. Applicable Regulations: The applicable sections, latest editions and addenda of the following government regulations, codes, industry standards and recommended practice, form a part of these applications. Nothing in these specifications is to be construed as permitting work not conforming to these requirements.

      1. EPA -Environmental Protection Agency

      2. DOT - Department of Transportation

      3. NEC - National Electric Code

      4. NEMA - National Electrical Manufacturers Association

      5. All other applicable Federal, State, County Codes, Standards and Regulation.

    3. The Contractor is cautioned that he is responsible for ascertaining the extent to which these regulations effect the operations and to comply therewith.

  4. Safety Procedures and Worker Protection

    1. Work Area Protection and Marking: Prior to commencing any PCB-related work activities, provide barricades and warning signs to clearly identify and effectively guard against unauthorized entry into work area.

    2. Protective Clothing and Equipment: At all times when PCB materials in any volume are not sealed in drums, containers or electrical equipment, workers shall wear:

      1. Disposable, nonporous gloves.

      2. Disposable whole body clothing impermeable to PCBs.

      3. Respiratory protection (NIOSH/MSHA approved) against organic vapors and particulates (at least the level of particulate protection required at the stage of work for asbestos protection.)

      4. Eye protection.

    3. The Contractor shall provide protective clothing, eye protection and respiratory protection as required for Government Inspection Personnel monitoring work activities within the work area and for firefighters responding to incidents.

    4. Personnel Protection and Procedures:

      1. The PCB work area shall never be left unattended after procedures have begun and until ballasts and incidents have been sealed in approved containers.

      2. If immediate transportation to the PCB disposal facility is not feasible, the work area must be secured in a manner approved by the Contracting Officer.

      3. During procedures and at all times when PCB ballasts or mixtures in any volume are not sealed in drums, containers or electrical equipment, all personnel entering the work area must wear protective clothing and use equipment listed herein.

      4. Upon exiting the work area, all disposable protective clothing shall be placed in open-top drums, sealed and removed from building property when other materials in the same area are removed.


  1. Coordinate ballast removal with General Contractor.

  2. Remove ballasts from fixtures located in staging area prior to completion of renovation phase of work. Do not allow ballasts to stockpile at staging area for more than the duration of the current phase of work.



  1. Storage Containers

    1. All ballasts containing PCB material shall be stored in sealed DOT 17R closed top drums.

    2. All PCB solid wastes, and items including disposable items used in the course of the work such as rags, sorbents, protective clothing, shall be stored in sealed DOT 17C open type drums.

  2. Solvents, Sorbents and Cleaners

    1. Solvents: Diesel fuel, deodorized kerosene or other solvents recognized for a high degree of PCB solubility.

    2. Sorbents: Material recognized for a high degree of absorption.

    3. Liquid Cleaners: Concentrated liquid alkaline base cleaner.



  1. Containerization and Marking:

    1. All liquids generated as a result of work activities and cleanup operation shall be placed in closed top drums and sealed.

    2. All solids such as sorbents, rags, disposable protective clothing, and other incidentals shall be placed in open drums and sealed.

    3. All drums (and article containers where used) shall be permanently marked as to specific contents and dated. In addition, each drum (and container) shall be marked with the standard EPA type ML PCB label.

    4. All PCB articles such as ballasts and other equipment to be removed shall have a record of such action sealed in a weatherproof envelope displayed on the unit.

      1. Label record must include the type of action, date of action and the name of the technician in charge.

      2. A duplication of this label information shall be furnished to the Contracting Officer.

  2. Handling of Hazardous Waste: Prior to submitting the hazardous waste manifest for a shipment of waste to the Contracting Officer for signature, the Contractor shall make available the transport vehicle and the waste for inspection by the Contracting Officer so that the Contracting Officer can check the amount of waste (for example, number of bags or drums, or volume of waste) and its condition (for example, whether the bags or drums appear to be sealed and not leaking).

  3. Transportation to Waste Disposal Facility:

    1. All PCB articles such as ballasts, all drums containing liquids, solids and incidentals shall be transported to the off-site PCB disposal facility.

    2. The firm performing the work outlined in this section shall be licensed for the transportation and hauling of extremely hazardous wastes.

    3. The firm shall provide a routing plan which clearly identifies the routes he proposes to follow while transporting PCB items from the various work area (point of generation) to the off-site PCB disposal facility.

    4. A minimum of two operators shall be in attendance at all times when PCB items are being loaded and unloaded.

    5. Vehicles used for transporting of PCB Items must be plainly and visibly marked with a minimum of four EPA type ML PCB labels.

    6. Vehicles shall not be loaded in excess of 75% of rate load capacity.

    7. All closed and open top drums must be permanently sealed and marked prior to loading on transport vehicle. Filled drums shall be loaded on the transport vehicle by any of the following methods:

      1. By a hoist or by a lift truck using a drum lifter.

      2. By a lift truck lifting the drums from underneath by a pallet attached to the drum or by a banding arrangement.

    8. Drums shall not be lifted by:

      1. Any rope, chain or cloth slings tied about the drum,

      2. Placement of drums on bare-lift truck forks,

      3. Forcing drums between forks of a lift truck, or

      4. Any commercial drum lifters exerting force on the sides of a drum.

    9. All drums or article containers shall be secured to the transport vehicle to prevent movement in transit.

  4. Unloading and Records:

    1. Immediately following unloading of the PCB transport vehicle, the cargo area shall be inspected to check for any fluid leaks.

      1. If any fluid leaks are found, the source of the leaking drum of item shall be identified and sealed.

      2. The contaminated cargo area shall be thoroughly cleaned with sorbents, solvents and liquid cleaner.

      3. Cleaning solvents and solids shall be placed in proper drums.

    2. Upon completion of all PCB work-related activities, the firm performing the work outlined in this section shall provide a complete record of PCB-related work and storage data to the Contracting Officer. The record shall include the following data:

      1. Name of the firm performing the work outlined in this section and technician in charge.

      2. For ballasts and electrical equipment removed:

        • Manufacturer and serial number.

        • Date removed from service and location.

        • Date placed in disposal site.

        • Weight in pounds.

      3. For drums (and article containers where applicable):

        • Drum size (30 or 55 gallons).

        • Identification of contents, i.e., ballasts, cleaning solvents, etc.; for solids, rags, sorbents, etc.

        • Weight in kilograms of contents of each drum (or container).

        • Date and location of destruction of items.

        • Company that conducted destruction of items.

    3. The contract work will not be considered complete until receipt of listed record data by the Contracting Officer.

    4. Hazardous waste manifest(s) signed by the Contractor, additional transporter(s) and/or treater(s), and by the disposal facility(ies) shall be provided to the Contracting Officer within 10 days following receipt of the hazardous materials are received at the disposal facility.

    5. Completed Certificate(s) of Destruction signed by the Contractor, the disposal facility(ies), additional transporter(s) and/or treater(s), and the destruction facility(ies) shall be provided to the Contracting Officer within 10 days following receipt of the hazardous materials are received at the disposal facility.

    6. For any state requiring registration of hazardous waste-hauling vehicles and/or hazardous waste-hauling drivers, the Contractor shall provide proof that all such vehicles and/or drivers used in the contract are currently registered.


Clean-Up of Work Area, PCB Articles and Spills:

  1. Equipment and Tools: After the last ballast is removed from fixture, all tools and equipment used in the work shall be decontaminated and properly stored for reuse.

  2. Where work surfaces have contacted PCB fluids they shall be scraped clean, flushed with solvent, wiped clean and all debris placed in open type drums.

  3. All tools that may have some in contact with PCB at any concentration shall be thoroughly flushed with solvent, wiped clean and properly stored.

    1. PCB Articles (Electrical Equipment): All exterior surfaces of electrical equipment to be removed that may have come in contact with PCBs or contaminated soils or fluids, during the course of work activities or due to past leaks, shall be thoroughly cleaned with solvent and wiped clean.

    2. Slabs, Floors, and Walls: All concrete (or other surfaces) which may have come in contact with PCBs or PCB mixtures in the course of the work as a result of past leaks shall be thoroughly cleaned using a combination of sorbent, solvent and cleaners.

    3. Where feasible, the Contractor shall arrange to remove such articles directly to transport vehicles prior to general clean-up.

    4. Remainder of fixture shall be disposed of by General Contractor.

3.03 Protection

  1. Prerequisites to Submittal Completion: Prior to requesting inspection for certification of substantial completion for either entire work of portions hereof, complete the following and list known exceptions in request.

    1. Final clearance air testing

    2. Discontinuation and removal of temporary facilities and services, construction tools and facilities from project site.

  2. Prerequisites to Final Acceptance: Prior to requesting final inspection for certification of final acceptance and final payment, as required by General Provisions and Conditions, complete the following and list known exceptions (if any) in request:

    1. Submit record as built drawings and similar final record information.

    2. Submit completed asbestos waste manifest.

    3. Submit completed PCB waste manifest.

    4. Submit employee air monitoring records.

    5. Submit employee log-in/log-out form.