1. LAMP & BALLAST RECYCLING

2. Sponsored by a partnership of the: For the U.S. Department of Energys Rebuild America Program National Electrical Manufacturers Association Association of Lighting and Mercury Recyclers (ALMR)

3. 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

4. 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

5. 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?

6. Which Lamps Contain Mercury?

7. Mercury-Containing Lamps Fluorescent & HID Lamps

8. 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

9. Visible Light Fluorescent Lamp Operation Phosphor Hot Cathode Electron Mercury Atom UV Radiation A small amount of mercury in the lamp enables the phosphors to fluoresce, producing visible light

10. HID Lamp Operation Metal Halide Mercury Vapor High Pressure Sodium Mercury is used to produce visible light, or to start and regulate the lamps

11. 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

12. Many People Handle Lamps Janitors Maintenance workers Truck drivers Trash handlers, etc. Janitors Maintenance workers Truck drivers Trash handlers, etc.

13. How Does Mercury Get into the Environment?

14. Waste Water Treatment Urban & Rural Runoff Industrial, Mining & Agricultural Precipitation Fish The Mercury Cycle

15. Waste Water Treatment Urban & Rural Runoff Industrial, Mining & Agricultural Precipitation Fish Fisherman The Mercury Cycle THE FOOD CHAIN

16. Who Regulates Disposal?

18. Historical Lamp Disposal Problem 0 10 20 30 40 50 60 70 80 1990-1999 1999-Pres. Future EPA Goal = 80% Recycling % Recycling

19. Universal Waste Rule Universal Waste Rule (UWR) 40 CFR Part 273 See Federal Register July 6, 1999, Volume 64 Number 128, pp 36465-36490

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

21. 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

22. 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

23. Features 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

24. 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 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

25. 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 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

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

27. 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 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

28. 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 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

29. Who is Responsible for Mercury Waste Management?

30. 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

31. Categories of Generators Household: Individual Household: Individual

32. Categories 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

33. Categories 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

34. Categories of Generators LQG: Large Quantity Generator – Greater than 1000 kg per month LQG: Large Quantity Generator – Greater than 1000 kg per month

35. Categories 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

36. 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 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

37. 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 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

38. UW Transfer Facility A non-permitted temporary storage location for <10 days

39. 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

40. Destination Facility These are typically the recycling facilities that must comply with stringent requirements

41. 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 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

42. 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

43. 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…

44. What About Ballasts? 1970 1980 1990 2000 1978 Magnetic Ballasts with PCBs PCBs Banned 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

45. Ballast Operation A ballast provides operating power to a fluorescent or HID lamp

46. 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

47. How Can You Dispose of Mercury-Containing Lamps Properly?

48. 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 * For non-exempt lamps

49. What 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

50. Proper Management Its easier to properly manage spent lamps than before… Nationally, movement is growing to require recycling for all mercury lamps Its easier to properly manage spent lamps than before… Nationally, movement is growing to require recycling for all mercury lamps

51. Economics of Recycling Cost of recycling represents approximately 1% of the total ownership cost of lamps

52. Proper Disposal of Ballasts with PCBs Hazardous waste landfill PCB Incinerator Recycle Hazardous waste landfill PCB Incinerator Recycle

53. What 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

54. Shared Responsibility: Public Sector EPA States Local Governments Local Agencies School Districts Government Buildings EPA States Local Governments Local Agencies School Districts Government Buildings

55. Shared 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

56. 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)

57. $ 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

58. Please recycle! Please do your part to keep mercury lamps & PCB ballasts out of the environment

59. For More Information NEMA at www.nema.orgwww.nema.org ALMR at www.almr.orgwww.almr.org Rebuild America at www.rebuild.orgwww.rebuild.org NEMA at www.nema.orgwww.nema.org ALMR at www.almr.orgwww.almr.org Rebuild America at www.rebuild.orgwww.rebuild.org

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