October 29, 1999

To: County and District Superintendents

From: Duwayne Brooks, Director, School Facilities Planning Division

Subject: Polychlorinated Biphenyl (PCB) Fluorescent Lighting Ballasts in Schools

The purpose of this memo is to alert you to a possible health hazard that can be mitigated when you do a modernization project. School districts currently planning modernization projects should include PCB fluorescent light ballast removal where pre-1979 lighting systems are still in use. While continued use of PCB ballasts is not prohibited, school districts need to be aware that as PCB ballasts age, they degrade structurally and can become a health hazard.

The California Department of Education (CDE) and Department of Toxic Substances Control (DTSC) recommend removal of pre-1979 PCB ballasts from schools as soon as practicable. A good time to remove PCB ballasts is during a modernization project. PCBs are carcinogenic and were banned by federal regulations for use in products manufactured after 1979. However, continued use of older PCB containing fluorescent light ballasts is not prohibited, and many are still in use in California schools.

The possibility of students being exposed to PCBs came to the attention of California's DTSC recently when a PCB ballast in a school in Southern California caught fire. Although ballast fires are rare, the chance of fires and/or leaks increases with the age of the ballast.

The ballast will often continue to function despite leaks. Because lighting ballasts are physically contained within a fluorescent light fixture, maintenance personnel walking through a classroom and looking at fluorescent light fixtures are not able to determine visually if a ballast is leaking. Sometimes the first indication of failure is the ballast's liquefied insulation material dripping down on a desk or the floor.

The legislature is currently discussing requirements for the removal of PCB ballasts. If there is evidence of leakage, school districts should remove them as soon as possible. If pre 1979 systems are still in use, school districts should inspect them for PCB type ballasts and remove such ballasts and replace them with electronic devises.

• If faced with a PCB ballast leak or fire, assistance concerning what analytical tests to perform and cleanup levels can be obtained by calling DTSC's Ms. Debbie Oudiz at 916-327-2495.

• For assistance concerning state and federal regulations regarding the handling, transportation, storage, and disposal of PCB ballasts, contact DTSC's Mr. Mardis Coers at 916-322-0712.

• For assistance concerning architectural specifications and contract requirements for PCB ballast removal, contact Department of General Services (DGS), Real Estate Services Division's Mr. Paul Hypnarowskiat 916-445-2415.

If you are not contemplating general modernization of your facility at this time, but need to have PCB ballasts removed and electronic ballasts installed, you may request labor assistance from the California Conservation Corps (CCC) a state agency.

The California Conservation Corps (CCC) has a 10-year history of ballast and lighting retrofit projects at a reduced cost. The CCC has worked with a number of schools in replacing ballasts, upgrading lighting systems and installing controls and new fixtures. In so doing, the CCC provides valuable employment skills and "on the job training" for young adults under the supervision of skilled and experienced staff. If you wish more information regarding cost or availability of CCC crews, please contact the CCC office closest to your location:

Southern California Area
Scot Schmier
562-651-5502

San Francisco Bay Area
Virginia Clark
707-562-3520

Central Northern Area
Claudia Orlando
530-823-4900

Funding Assistance

Loan programs are available through State agencies to assist in the replacement of the older style ballasts. Both the State of California's Energy Commission 916-654-4008 and General Services 916-323-8777 currently have loans and technical assistance programs available for K-12 schools for replacing and upgrading their lighting systems. With funding assistance from the Energy Commission's Bright Schools Program or General Services' Energy Assessment Program, it is possible to address two issues at once: 1) replacement of remaining PCB ballasts and 2) upgrading other components (fluorescent light tubes, lighting fixtures, etc.) of existing lighting systems with more energy efficient lighting devices. In addition to eliminating the possibility of exposure to PCBs from older ballasts, energy lighting costs can be reduced at the same time. Money loaned from these sources may be used as part of the district's local match in State School Facilities Program Modernization projects.

So that all legal requirements are met, engage an architect to supervise the relationship of PCB work to design of all building systems, and removal and replacement of PCB contaminated equipment. The architect should consult with electrical and demolition engineers to be certain their work is coordinated and all building codes are followed. It is especially important that the work be sequenced and phased with other potential remodeling projects such as roofing, new lighting, seismic bracing, electrical switches, and indoor air quality remediation, among others. The work must be performed in accordance with applicable federal, state and local laws and regulations.

CDE will forward additional information as it becomes available. The following web-sites may provide more information in the interim:

California Department of Education, School Facilities Planning Division
California Energy Commission (Outside Source)
California Department of General Services (Outside Source)

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The information in this memo is not binding on local educational agencies or other entities. Except for the statutes, regulations, or court decisions that are referenced herein, the memo is exemplary and compliance with it is not mandatory (See Education Code Section 33308.5).
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cc:

Debbie Oudiz, Department of Toxic Substance Control
Mardis Coers, Department of Toxic Substance Control
Patrick Couch, California Conservation Corps
Bright Schools Program, Energy Commission
Energy Assessment Program, Department of General Services