LAMP & BALLASTLAMP & BALLAST

RECYCLINGRECYCLING

Sponsored by a partnership of the:Sponsored by a partnership of the:

For the U.S. Department of Energy’s Rebuild America Program

For the U.S. Department of Energy’s Rebuild America Program

National Electrical Manufacturers AssociationNational Electrical Manufacturers Association

Association of Lighting and Mercury Recyclers (ALMR)

Association of Lighting and Mercury Recyclers (ALMR)

Recycling- Who Needs to Know ?Recycling- Who Needs to Know ?

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

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

Recycling- Who Needs to Know ?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

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

What You Need to Know 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?

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?

Which Lamps Contain Mercury?

Which Lamps Contain Mercury?

Mercury-Containing LampsMercury-Containing Lamps

Fluorescent & HID Lamps

Fluorescent & HID Lamps

Which Lamps Contain Mercury?Which Lamps Contain Mercury?

Fluorescents High Intensity Discharge

– Mercury Vapor – Metal halide– High Pressure Sodium

Neon Some specialty lamps

Fluorescents High Intensity Discharge

– Mercury Vapor – Metal halide– High Pressure Sodium

Neon Some specialty lamps

Visible Light

Fluorescent Lamp OperationFluorescent Lamp Operation

Phosphor

Hot CathodeElectron

Mercury AtomUV Radiation

A small amount of mercury in the lamp enables the phosphors to “fluoresce”, producing visible light

A small amount of mercury in the lamp enables the phosphors to “fluoresce”, producing visible light

HID Lamp OperationHID Lamp Operation

Metal HalideMetal Halide

Mercury Vapor

Mercury Vapor

HighPressureSodium

HighPressureSodium

Mercury is used to produce

visible light, or to start and regulate the

lamps

Mercury-Containing Lamps: Energy Efficient

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

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

Many People Handle LampsMany People Handle Lamps

Janitors Maintenance workers Truck drivers Trash handlers, etc.

Janitors Maintenance workers Truck drivers Trash handlers, etc.

How Does Mercury Get into the Environment?

How Does Mercury Get into the Environment?

Waste Water Treatment

Urban & RuralRunoff

Industrial, Mining & Agricultural

Precipitation

Fish

The Mercury CycleThe Mercury Cycle

Waste Water Treatment

Urban & RuralRunoff

Industrial, Mining & Agricultural

Precipitation

Fish

FishermanFisherman

The Mercury CycleThe Mercury Cycle

THEFOODCHAIN

THEFOODCHAIN

Who Regulates Disposal?

Who Regulates Disposal?

Historical Lamp Disposal ProblemHistorical Lamp Disposal Problem

0

10

20

30

40

50

60

70

80

1990-1999 1999-Pres. Future Future

EPA Goal = 80% RecyclingEPA Goal = 80% Recycling

% Recycling

Universal Waste Rule Universal Waste Rule

Universal Waste Rule (UWR)

40 CFR Part 273

Universal Waste Rule (UWR)

40 CFR Part 273

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

Universal Waste LampUniversal 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

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

Universal Waste LampUniversal 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

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

Features of the Federal Policy (UWR) 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”

Encourages recycling Paperwork is easier Transportation costs are less Expensive analytical testing is not

required Anyone can become a “handler”

Features of the Federal PolicyFeatures of the Federal Policy

Individuals & very small businesses may be exempt- check with state

Optional for Households and CESQGs * (<100kg/mo every month for 12 months, total

hazardous waste, including lamps)

Not optional in many states; states control

No exemption from pollution liability

Individuals & very small businesses may be exempt- check with state

Optional for Households and CESQGs * (<100kg/mo every month for 12 months, total

hazardous waste, including lamps)

Not optional in many states; states control

No exemption from pollution liability

* Conditionally Exempt Small Quantity Generator

Features of the Federal PolicyFeatures 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”

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”

Features of the Federal PolicyFeatures of the Federal Policy

Broken lamps require a closed container that is structurally sound to prevent leakage or release of mercury

Many states don’t allow intentional crushing of lamps to reduce volume. Crushers must comply with OSHA and RCRA requirements

Broken lamps require a closed container that is structurally sound to prevent leakage or release of mercury

Many states don’t allow intentional crushing of lamps to reduce volume. Crushers must comply with OSHA and RCRA requirements

Features of the Federal PolicyFeatures of the Federal Policy

Normally, costly analytical testing is required to make the hazardous waste determination

With Universal Waste recycling, no testing is required

Normally, costly analytical testing is required to make the hazardous waste determination

With Universal Waste recycling, no testing is required

Features of the Federal PolicyFeatures 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

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…this lowers shipping costs

Features of the Federal PolicyFeatures 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

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

Who is Responsible for Mercury Waste

Management?

Who is Responsible for Mercury Waste

Management?

GeneratorGenerator

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

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

Categories of GeneratorsCategories of Generators

Household:Individual

Household:Individual

Categories of GeneratorsCategories of Generators

CESQG:Conditionally Exempt Small Quantity Generator– Less than 100 kg total HW per month

CESQG:Conditionally Exempt Small Quantity Generator– Less than 100 kg total HW per month

Categories of GeneratorsCategories of Generators

SQG:Small Quantity Generator– Greater than 100kg and less than 1000 kg total per month

SQG:Small Quantity Generator– Greater than 100kg and less than 1000 kg total per month

Categories of GeneratorsCategories of Generators

LQG: Large Quantity Generator

– Greater than 1000 kg per month

LQG: Large Quantity Generator

– Greater than 1000 kg per month

Categories of HandlersCategories of Handlers

SQHUW – Small Quantity Handler Universal Waste

LQHUW– Large Quantity Handler Universal Waste

SQHUW – Small Quantity Handler Universal Waste

LQHUW– Large Quantity Handler Universal Waste

SQHUWSQHUW

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  

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  

LQHUWLQHUW

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

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

UW Transfer Facility UW Transfer Facility

A non-permitted temporary storage location for <10 days

A non-permitted temporary storage location for <10 days

Transporter Transporter

One who transports UW lamps for <10 days

Requirements (40 CFR 273.50)– No EPA registration– Proper marking

and labeling

One who transports UW lamps for <10 days

Requirements (40 CFR 273.50)– No EPA registration– Proper marking

and labeling

Destination FacilityDestination Facility

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

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

Household Hazardous WasteHousehold 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

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

The Bottom Line 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

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

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

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

Guidelines…Guidelines…

What About Ballasts?What About Ballasts?

19701970 19801980 19901990 20002000

19781978

Magnetic Ballasts

with PCBs

Magnetic Ballasts

with PCBs

PCBsBannedPCBs

Banned

Ballasts Labeled “No PCBs”

Ballasts Labeled “No PCBs”

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

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

Ballast OperationBallast Operation

A ballast provides operating power to a fluorescent or HID lamp

A ballast provides operating power to a fluorescent or HID lamp

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

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

How Can You Dispose of

Mercury-Containing Lamps Properly?

How Can You Dispose of

Mercury-Containing Lamps Properly?

Legal Options for Lamps*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!

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!

Lamp Recycling

Lamp Recycling

* For non-exempt lamps

What Lamp Recycling DoesWhat Lamp Recycling Does

Removes hazardous characteristic of mercury from lamps

Separates & makes all materials reusable

Recycles mercury into lamps and other products

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  

150,000 tons of waste can be diverted from

landfills  

Proper ManagementProper Management

It’s easier to properly manage spent lamps than before…

Nationally, movement is growing to require recycling for all mercury lamps

It’s easier to properly manage spent lamps than before…

Nationally, movement is growing to require recycling for all mercury lamps

Economics of RecyclingEconomics of Recycling

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

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

Proper Disposal of Ballasts with PCBsProper Disposal of Ballasts with PCBs

Hazardous waste landfill PCB Incinerator Recycle

Hazardous waste landfill PCB Incinerator Recycle

What Ballast Recycling DoesWhat Ballast Recycling Does

Capacitors and potting compound are isolated for incineration

Core, windings, casing for metals go to reclamation

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  

Another 60,000 tons of waste can be diverted from

landfills  

Shared Responsibility: Public SectorShared Responsibility: Public Sector

EPA States Local Governments Local Agencies School Districts Government Buildings

EPA States Local Governments Local Agencies School Districts Government Buildings

Shared Responsibility: Private SectorShared Responsibility: Private Sector

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

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

How Can You Do the Right Thing?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)

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)

$Business Opportunities Business Opportunities

Lighting maintenance companies Relamping firms Energy service companies Building maintenance Demolition contractors

… Anyone who removes lamps from their fixtures

Lighting maintenance companies Relamping firms Energy service companies Building maintenance Demolition contractors

… Anyone who removes lamps from their fixtures

Please recycle!Please

recycle!

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

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

For More InformationFor More Information

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

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

SponsorsSponsors

National Electrical Manufacturers AssociationNational Electrical Manufacturers Association

Association of Lighting and Mercury Recyclers (ALMR)

Association of Lighting and Mercury Recyclers (ALMR)

Educational program developed by: