If a facility is in the process of removing old light ballasts containing PCBs and/or mercury, would CERCLA reporting be required any time one pound of PCB has been moved in a 24-hour period?

As defined in CERCLA section 101(22), the term "release" encompasses (among other things) "...the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance..." Because light bulbs and light ballasts may contain mercury, PCBs, or other CERCLA hazardous substances, the abandonment or discarding of such closed containers could constitute a release under CERCLA, depending upon what happened to the containers after they were moved. The moving of one pound or more of PCBs (the RQ for PCBs is one pound) contained in light ballasts could, if the ballasts were then abandoned or discarded, constitute a release that must be reported to the National Response Center. If hazardous substance-containing ballasts, lamps, or both are moved without being abandoned or discarded, no release has occurred. The determination of whether "abandonment or discarding" has occurred should be made by the facility or other persons handling the ballasts or bulbs on a case-by-case basis, considering the circumstances of activity. A common sense approach should be used in making this determination. For example, if PCB-containing ballasts are moved from one place to another place in the environment prior to being transported off-site for disposal, this generally would not constitute a release because the ballasts were not abandoned or discarded.