LAMP

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LAMP BALLAST
RECYCLING
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Sponsored by a partnership of the
National Electrical Manufacturers Association
Association of Lighting and Mercury Recyclers
(ALMR)
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Recycling- Who Needs to Know ?

• Government
• Government buildings
• Local enforcement agencies
• Public Works agencies and associations
• Solid waste agencies
• School districts

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Recycling- Who Needs to Know ?

• Business
• Institutions, universities, hospitals
• Building commercial property owners
• Contractors lighting, maintenance, energy
  efficiency, demolition, etc.
• Estimated 10 million individual businesses in
  U.S.
• Public (exempt from regulations)
• Households may choose to recycle

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What You Need to Know

• Mercury and Hazardous Waste
• What lamps contain mercury?
• How does mercury get into the environment?
• Who regulates disposal?
• Who is responsible for mercury-waste management?
• How can you dispose of mercury-containing lamps
  properly?

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Which Lamps Contain Mercury?
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Mercury-Containing Lamps
Fluorescent HID Lamps
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Which Lamps Contain Mercury?

• Fluorescents
• High Intensity Discharge
• Mercury Vapor
• Metal halide
• High Pressure Sodium
• Neon
• Some specialty lamps

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Fluorescent Lamp Operation
A small amount of mercury in the lamp enables the
phosphors to fluoresce, producing visible light
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HID Lamp Operation
Mercury Vapor
Mercury is used to produce visible light, or to
start and regulate the lamps
Metal Halide
HighPressureSodium
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Mercury-Containing Lamps Energy Efficient

• Energy efficiency is the key
• Mercury-containing lamps
• Save energy
• Reduce air pollution and greenhouse gases
• Lower energy production needs
• Trade off
• The mercury from spent lighting can be a problem
  if released in the environment
• Proper management of spent lamps makes for a
  win-win solution

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Many People Handle Lamps

• Janitors
• Maintenance workers
• Truck drivers
• Trash handlers, etc.

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How Does Mercury Get into the Environment?
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The Mercury Cycle
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The Mercury Cycle
Industrial, Mining Agricultural
Precipitation
Urban RuralRunoff
Fisherman
Waste Water Treatment
THEFOODCHAIN
Fish
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Who Regulates Disposal?
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(No Transcript)
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Historical Lamp Disposal Problem
80
70
60
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Recycling
40
30
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EPA Goal 80 Recycling
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Universal Waste Rule

• Universal Waste Rule (UWR) 40 CFR Part 273

See Federal Register July 6, 1999, Volume 64
Number 128, pp 36465-36490
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Universal Waste Lamp

• Any lamp having a hazardous characteristic,
  not limited to mercury, and including lead or
  other metals, can be managed as a Universal Waste
  

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Universal Waste Lamp

• Mercury is the major concern. The EPA
  encourages all handlers of spent lamps, whether
  hazardous or not, to manage them under the
  Universal Waste provisions of 40 CFR part 273

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Features of the Federal Policy (UWR)

• Encourages recycling
• Paperwork is easier
• Transportation costs are less
• Expensive analytical testing is not required
• Anyone can become a handler

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Features of the Federal Policy

• Individuals very small businesses may be
  exempt- check with state
• Optional for Households and CESQGs
• (hazardous waste, including lamps)
• Not optional in many states states control
• No exemption from pollution liability

Conditionally Exempt Small Quantity Generator
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Features of the Federal Policy

• Whole lamps are exempt from the H W manifesting
• Shippers/generators may use a Bill of Lading
  (BOL) for recycling
• EPA tries to remove the stigma of managing a
  hazardous waste by allowing Universal Wastes to
  be handled like other commodities

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Features of the Federal Policy

• Broken lamps require a closed container that is
  structurally sound to prevent leakage or release
  of mercury
• Many states dont allow intentional crushing of
  lamps to reduce volume. Crushers must comply
  with OSHA and RCRA requirements

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Features of the Federal Policy

• Normally, costly analytical testing is required
  to make the hazardous waste determination
• With Universal Waste recycling, no testing is
  required

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Features of the Federal Policy

• May use any common carrier instead of a certified
  hazardous waste hauler for shipment to a
  recycling facility
• May also use common package carriers
• May self-transport

this lowers shipping costs
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Features of the Federal Policy

• Allows anyone to collect lamps provided they are
  taken to a Destination Facility
• Allows anyone to be a handler, and to store
  lamps up to one year
• Imposes minimal training and labeling
  requirements on generators and handlers

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Who is Responsible for Mercury Waste Management?
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Generator

• Anyone who creates waste mercury lamps (a
  RCRA characteristic waste 0.2mg/l TCLP)

TCLP Toxic Characteristic Leaching Procedure
Test for potential for migration of mercury
from a landfill
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Categories of Generators

• Household
• Individual

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Categories of Generators

• CESQGConditionally Exempt Small Quantity
  Generator
• Less than 100 kg total HW per month

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Categories of Generators

• SQGSmall Quantity Generator
• Greater than 100kg and less than 1000 kg total
  per month

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Categories of Generators

• LQG
• Large Quantity Generator
• Greater than 1000 kg per month

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Categories of Handlers

• SQHUW
• Small Quantity Handler Universal Waste
• LQHUW
• Large Quantity Handler Universal Waste

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SQHUW

• A generator or third party who accumulates less
  than 5,000 kg at a time, up to one year.
• Requirements (40 CFR 273.10)
• No EPA registration
• Training and information on handling mercury
  lamps and emergency procedures
• Proper marking and labeling  

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LQHUW

• A generator or third party who accumulates
  greater than 5,000 kg at a time, up to one year
• Requirements (40 CFR 273.30)
• EPA or state registration and ID.
• Training and information on handling mercury
  lamps and emergency procedures
• Proper marking and labeling

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UW Transfer Facility

• A non-permitted temporary storage location
  for

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Transporter

• One who transports UW lamps for
• Requirements (40 CFR 273.50)
• No EPA registration
• Proper marking and labeling

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Destination Facility

• These are typically the recycling facilities
  that must comply with stringent requirements

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Household Hazardous Waste

• Local government may sponsor programs allow
  citizens very small businesses to drop off
  materials at no cost
• Not allowed for larger businesses
• Contact your local government agency

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The Bottom Line

• Non-exempt generators, handlers and
  transporters are not allowed to dispose of
  hazardous lamps into municipal landfills, and
  must either
• Manage them as hazardous waste, or
• Recycle them

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Guidelines

• States still have the final word
• Many states are more stringent than EPA- some
  have completely banned mercury products from
  landfilling
• How will you know what to do in your state?
• www.lamprecycle.org
• www.almr.org

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What About Ballasts?
Magnetic Ballasts with PCBs
Ballasts Labeled No PCBs
1970
1980
1990
2000
1978
PCBsBanned

• Ballasts produced since 1978 do not contain
  capacitors with PCBs hence, only a limited
  number of known PCB ballasts still exists

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Ballast Operation

• A ballast provides operating power to a
  fluorescent or HID lamp

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US EPA PCB Mega Rule (8/28/98)

• More strict than previous policy due to evidence
  and concerns about 50 ppm PCB in the potting
  compound
• Final Rule (63 FR 35383-35474) and 40 CFR Part
  761
• Need to go the TSCA approved facilities, such as
  recycling or incineration

Toxic Substances Control Act Law that
regulates hazardous substances
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• How Can You Dispose of Mercury-Containing Lamps
  Properly?

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Legal Options for Lamps

• Recycling
• A safe compliant choice in any state
• Landfilling in special hazardous waste landfills
  (specifically permitted to contain mercury)
• Less preferred more costly in some states
• Mixing with trash
• Not allowed!

For non-exempt lamps
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What Lamp Recycling Does

• Removes hazardous characteristic of mercury from
  lamps
• Separates makes all materials reusable
• Recycles mercury into lamps and other products

150,000 tons of waste can be diverted from
landfills  
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Proper Management

• Its easier to properly manage spent lamps than
  before
• Nationally, movement is growing to require
  recycling for all mercury lamps

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Economics of Recycling

• Cost of recycling represents approximately 1 of
  the total ownership cost of lamps

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Proper Disposal of Ballasts with PCBs

• Hazardous waste landfill
• PCB Incinerator
• Recycle

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What Ballast Recycling Does

• Capacitors and potting compound are isolated for
  incineration
• Core, windings, casing for metals go to
  reclamation

Another 60,000 tons of waste can be diverted
from landfills  
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Shared Responsibility Public Sector

• EPA
• States
• Local Governments
• Local Agencies
• School Districts
• Government Buildings

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Shared Responsibility Private Sector

• Building Owners, Corporations
• Commercial Property
• Solid Waste Industry Manufacturers
• Recycling Industry

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How Can You Do the Right Thing?

• Large firms-
• Contact any commercial recycler or HW contractor
• (see websites for links and references)
• Small firms- Use mail-in box programs available
  from many electrical distributors, or ship
  directly to recyclers, use milk run pick-ups
• Homeowners- Take to HHW facilities or contact
  local agencies for resources (usually free for
  individuals)

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Business Opportunities

• Lighting maintenance companies
• Relamping firms
• Energy service companies
• Building maintenance
• Demolition contractors
• Anyone who removes lamps
  from their fixtures

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• Please do your part to keep mercury lamps
  PCB ballasts out of the environment 

Please recycle!
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For More Information

•  
• NEMA at www.nema.org
• ALMR at www.almr.org
• Rebuild America at www.rebuild.org

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Sponsors
National Electrical Manufacturers Association
Association of Lighting and Mercury Recyclers
(ALMR)
Educational program developed by