T S H. Guidance for Used Fluorescent Lamp Management. Problems of Fluorescent Lamp Disposal

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1 Guidance for Used Fuorescent Lamp Management Probems of Fuorescent Lamp Disposa F AC T S H EE T Approximatey 15 miion used fuorescent amps are generated in North Caroina each year. Fuorescent amps and High Intensity Discharge (HID) amps contain mercury as an essentia component for operation. Studies have shown that used 4-foot fuorescent amps contain approximatey 30 to 40 miigrams (mg) of mercury. When a amp is broken, disposed in a andfi, or incinerated, the mercury can contaminate air, surface water, or groundwater. Contamination is a concern because mercury is a highy toxic meta that bioaccumuates through the food chain and affects a variety of body systems incuding the nervous system and kidneys. Mercury emissions have contributed to surface water contamination, which has caused eevated concentrations in fish. As of November 1994, thirty-four states have issued fish consumption advisories to warn of eevated eves of mercury in fish. Eight such advisories have been issued in North Caroina. The U.S. Environmenta Protection Agency (EPA) has estimated that amps containing mercury contribute 3.8 percent of a mercury entering municipa soid waste (MSW) andfis. (The argest source of mercury, approximatey 88 percent, in the MSW stream comes from househod batteries (e.g., akaine batteries); the next argest contributors are mercurycontaining thermostats, thermometers, and fuorescent amps.) Athough the direct reationship between mercury in andfis and its eachabiity into groundwater is under some dispute, 23 unined andfis in North Caroina have exhibited mercury eves in ground water above the maximum contaminant eve for drinking water. Data for mercury eves in newer, ined h&fis are currenty unavaiabe. Tests conducted by the Nationa Eectrica Manufacturing Association (NEMA) and by EPA have shown that a significant percentage of fuorescent amps can be characterized as a hazardous waste under the Resource Conservation and Recovery Act (RCRA) because they surpass the 0.2 mg/l mercury imit by the toxicity characteristic eaching procedure (TCLP). The TCLP is a toxicity test that measures the potentia of a waste to each in a andfi. Energy-Efficient Lighting is Sti the Environmentay and Economicay Sound Choice NC Office of Waste Reduction and NC Division of Soid Waste Management Despite the chaenges associated with recycing or disposa of fuorescent amps and HDs, use of these highy efficient ighting systems wi resut in a net decrease in mercury reeases to the environment - even when mercury in the amps is counted - because ess energy is used to operate these systems. As fossi-fue-burning power pants are the argest emitters of mercury emissions, reduced energy usage through use of energy-efficient ighting means ess reiance on non-renewabe resources as we as substantia reductions in carbon dioxide, sufur dioxide, and nitrogen dioxide air emissions. Thus, instaation of energy-efficient ighting is sti one of the best choices a business or industry can make to protect the environment and to save money.

2 High-efficiency fuorescent amps and HIDs are two types of energy-efficient ighting systems that EPA promotes through its Green Lights Program. The Green Lights Program can be reached at (202) Trends in Fuorescent Lamp Manufacturing Fuorescent amp manufacturers have significanty reduced the amount of mercury in amps as we as increased their energy efficiency. Average mercury content in a 4-foot amp dropped 14 percent between 1985 and 1990, and industry predicts an additiona 35-percent reduction by Even with these reductions, fuorescent amps are sti ikey to be considered a hazardous waste under the current TCLP testing requirement. Waste Management Options for Mercury-Containing Lamps Current Reguatory Status for Disposa of Fuorescent Lamps Current State and Federa aws may characterize mercury-containing amps as a hazardous waste. Under RCRA used fuorescent amps (as with most other wastes) are subject to evauation for a hazardous waste characteristic, incuding the toxicity characteristic. The generator of the waste is responsibe for making this determination. A waste found to exhibit the toxicity characteristic is defined as hazardous and must be managed according to hazardous waste storage, treatment, and disposa reguations, uness otherwise excuded. As mentioned, EPA and NEMA test resuts have shown a sign&ant percentage of mercury-containing amps to be characterized as hazardous waste by the TCLP test. North Caroina Soid Waste Management Rue 15A NCAC 13B prohibits the disposa of hazardous waste in a MSW andfi. Conditionay exempt sma quantity generators (CESQGs) are aso incuded in this prohibition. Thus, no hazardous fuorescent amps from a commercia source may go to a MSW andfi. Househod fuorescent amps are, however, exempt from these reguations. Currenty, if a business or industry disposes of more than approximatey 300 to foot T-12 fuorescent amps or 400 to foot T-S amps in any month, it can no onger caim the status of an exempt sma quantity generator, uness it can prove that the amps are non-hazardous. Some oca governments may pace additiona disposa restrictions on mercury-containing amps. The oca soid waste agency shoud be contacted for information about oca disposa restrictions and preferred management options. For oca agency contacts, consut the oca teephone directory or the NC Office of Waste Reduction at (919) ). Recycing Lamps and Hazardous Waste Exemptions Intact amps sent to a recycer wi not be reguated as a hazardous waste in North Caroina. Generators who recyce intact amps are permitted time to accumuate a sufficient quantity to make recycing more economicay feasibe. The quantity of amps wi not be used in determining the hazardous waste generator status. Any amp may be recyced at a permitted or icensed recycing faciity whether or not it tests hazardous. need for waste manifesting wi vary with the requirements of the recycer, the transporter, and the states crossed enroute to the recycer. The Recycing faciities separate the toxic substances (such as mercury) from the gass, auminum end caps, and other components. Auminum end-caps are recyced as scrap meta, and gass is typicay used as a fier materia in such products as fibergass. Mercury is usuay recaimed through a retorting (distiation-ike) -2-

3 process. The sma end vaue of the recaimed materias infuences the amount charged for processing. Generators shoud ask their prospective service providers about the fina use for a recyced components of the amps. Handing Fuorescent Lamps for Recycing Most recycing faciities prefer to receive amps intact, athough some faciitates wi accept crushed tubes in ined drums. Intact bubs shoud be packed either in their origina carton, for which paper dividers are not necessary, or specia containers. Many recycing services can provide containers, and some have speciay designed containers that can be used for storage of spent amps unti they are shipped. S o m e recycers may require that 4-foot amps be repackaged in their origina cartons, paetized, and shrinkwrapped. The company generay wi specify the packaging it prefers for the amps. Costs of Recycing The specific cost of recycing bubs wi depend on the voume, distance, and specific services chosen by the cient. Recycing costs on the average are 10 cents per foot of amp, not incuding shipping and handing fees. The cost for recycing HID amps ranges from $1.25 to $4.50 per amp. The cost of recycing a amp is quite modest in terms of its HID ife-cyce cost. At $64 ($0.07 per kwh) to operate a amp for a 20,000-hour ife, a 50-cent recycing cost woud be ess than 1 percent of the cost of operation Recycing Services Avaiabe Lamp recycers offer services ranging from no transportation with fat rates at the recycer s dock to fu service operations that incude transportation, packaging, oading, and paperwork. Most fu service operations wi work with the customer to determine the optimum package for the customer s needs. A ist of fuorescent amp handers providing service to businesses in North Caroina is provided with this Fact Sheet. Hazardous Waste Disposa of Lamps - Costs and Liabiities Many hazardous waste handers offer waste disposa services for fuorescent amps. The generator must meet a RCRA management, storage, and shipping requirements. EPA has estimated that the cost to dispose of amps in hazardous waste andfis ranges between 25 to 50 cents per 4-foot amp, not incuding packaging transportation, or profie fees. It is important that generators understand the iabiity issues associated with the disposa of hazardous waste. Generators may be egitimatey concerned about potentia future Superfund iabiity in connection with any disposa method. A generators of mercury-containing amps waste, regardess of amount, coud be hed iabe in any subsequent Superfund ceanup at hazardous waste andfis or at MSW andfis. Current EPA Proposas for the Management of Fuorescent Lamps In the June 27,1994, Federa Register, EPA proposed two modifications to the Hazardous Waste Program for the management of mercury-containing amps. First, EPA has asked if an excusion for mercurycontaining amps from reguation as hazardous waste woud be appropriate, provided amps are disposed in municipa Subtite D ined andfis. The second approach is to incude mercury-containing amps under the newy approved Federa Universa Waste Rue. The Universa Waste approach is a streamined, reduced reguatory structure designed to address proper management of certain widey generated wastes that fa under the RCRA Subtite C reguations. The NC Division of Soid Waste Management supports

4 the incusion of mercury-containing amps under the Universa Waste Rue. However, even if the amp excusion is adopted at the Federa eve, the Division coud not support or adopt a rue to excude mercury waste from hazardous waste reguation because of the current State aw prohibiting the disposa of hazardous waste in Subtite D andfis. Incineration of Lamps is Highy Discouraged EPA advises that mercury-containing amps shoud never be incinerated because most soid waste combustors ack the necessary emission contro devices to effectivey remove mercury from the fue gases. EPA estimates that the eimination of mercury-containing amps from MSW incinerators woud resut in a 3-percent decrease in mercury-bearing waste in a MSW that is incinerated Crushing Lamps for Voume Reduction Most recycers prefer to receive mercury-containing amps intact. Athough amp crushing by generators is generay discouraged, it can be performed with the proper equipment and provisions to meet a RCRA and Occupationa Safety and Heath Administration (OSHA) reguatory requirements. The act of amp crushing is considered treatment of a hazardous waste if a generator assumes or has determined amps to be hazardous. According to 40 CFR 268.7(a)(4), treatment in an accumuation container is aowed if a waste anaysis pan is in pace. A treatment pan as part of the waste anaysis pan, woud have to incude the capture of a gases in the amps. The pan shoud incude prevention measures such as detection methods for mercury vapors as we as emergency shutdown measures. Without these pans, the crushing of amps woud not be considered egitimate treatment or voume reduction. A recent study on fuorescent amp crushing found that crushing units that do not operate under negative pressure and do not contain emission contro equipment (such as carbon canisters) can exceed the OSHA worker exposure imits of 0.05 mg/m 3 for mercury during norma operations. Currenty, exposure data are not avaiabe for incidenta breakage of amps. Suggestions For Working With Reamping Contractors - Generator s Responsibiities Any ighting upgrade projects or reamping maintenance operations shoud incude specifications for proper handing and safe recycing or disposa of amps, baasts, or other hazardous materias. Beow are some genera suggestions for working with reamping contractors: Ask the ighting or eectrica contractor to provide recycing or disposa services either directy or through a subcontractor as part of the contract, aong with shipping and disposition documentation Do not expect your reamping contractor to be we versed in a disposa requirements and options. Remember, the generator is utimatey responsibe for the management of the waste. Ask for certifications, icenses, and references from a subcontractors who provide recycing or disposa services. Househod Hazardous Waste Coection and Conditionay Exempt Generators The North Caroina Office of Waste Reduction and the Division of Soid Waste Management encourage the support of business and industry in oca Househod Hazardous Waste (HHW) coection programs. Loca governments that conduct HHW coection programs can choose to aow CESQGs to participate in the program. Such programs have typicay required CESQGs to pay a fee for waste disposed but can offer an -4-

5 opportunity for CESQGs to recyce or dispose of amps and other hazardous waste at reduced costs. CESQGs are encouraged to support such coection programs. For Additiona Information: For more information on reguatory issues, ca the NC Division of Soid Waste Management, Hazardous Waste Section, at (9 19) For more information on the EPA Green Lights Program, amp recycers, or amp source reduction activities, ca the NC Office of Waste Reduction at (919) Bibiography Truesdae, Robert, S., et. a. Management of Used Fuorescent Lamps: Preiminary Risk Assessment. Research Triange Institute, Research Triange Park, NC. Revised May What to do With Used Fuorescent and High-intensity Discharge Lamps. Minnesota Office of Waste Management Fact Sheet. August Lighting Waste Disposa. EPA Green Lights Program. January, Michae T. Nobe, Fuorescent Light Tube Crushing: Lamp Component Separation and Recycing of Mercury Phosphors. Certified Environmenta Consuting, Inc., Benicica, CA. Mercury-Containing Lamps Proposed Rue. Federa Register Vo. 59, No.143. Juy 27, Battye, Wiiam, et. a. Evauation of Mercury Emissions From Fuorescent Lamp Crushing. EPA-453/D February OWR copies of this document were printed on recyced paper at a cost of $13.65 or $0.09 per copy.

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7 Fuorescent Light Servctra and Rtcycers Page-7-

8 FLUORESCENT LIGHTS Most fuorescent amps, by the TCLP, test 0.2 ppm or greater for mercury and thus are hazardous wastes (DOO9) when disposed. Intact fuorescent amps sent to a recycer wi not be reguated as such. However, these intact amps or broken ones woud have to be handed as any other hazardous waste if disposed of rather than recyced propery. If these are caimed to be non-hazardous, a aboratory anaysis woud have to substantiate this caim. Recycing - Intact Lamps Since intact amps to be recyced wi not be reguated as a RCRA hazardous waste, the generator of the intact tubes wi have time to accumuate enough to make it economicay feasibe to recyce them. Aso, the quantity wi not be counted in determining the hazardous waste generator status. One recycer said that the recycabe parts may be separated more easiy with the intact tubes and that a smaer voume is retorted to recover the mercury; a of the crushed materia has to be retorted at a net higher cost per tube. Recycing - Crushed/Broken Lamps Drums are avaiabe in which fuorescent ights are crushed and the vapor coected. This process is considered treatment of a hazardous waste but is aowed in accumuation containers with certain precautions. The bubs themseves are containers hoding the gaseous mercury. Any treatment process woud have to incude the capture of mercury gases contained in the fuorescent tube. Otherwise this crushing woud not be caed egitimate treatment or voume reduction. Changing the gaseous mercury fiter before a spiover must be done. Testing for eaking mercury gas is advised. Recycing of the mercury and other materia in the drum is highy recommended. Disposa Hazardous waste is forbidden in North Caroina s Sanitary Landfis. Conditionay Exempt Sma Generators are incuded in this prohibition of sending any hazardous waste to a Soid Waste Landfi. No fuorescent amps from a commercia source may go to a soid waste andfi. Househod amps are, however; exempt from these reguations. Repacing ighting systems with energy efficient ones can cut energy costs. EPA s Green Lights Program offers free workshops for those companies who wish to accompish this goa. The contact is Dean Brockob [(202) ]. Lighting consutants aso provide this service. Attached are copies of reevant pages from the Green Lights Program Lighting Upgrade Manua and of Fuorescent Lighting vendors. For further questions, pease ca Margaret S. Babb, CHMM, Environmenta Chemist, Hazardous Waste Section at (919) [Foight.MSB (Revised 12/94)]

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