Mercury Lamp and E-Waste Recovery in Northern Virginia
While individual fluorescent tubes may contain very small amounts of mercury, collectively they become a hazardous waste issue when they no longer work. One region of the US has taken action.
Mercury is an essential ingredient in energy-efficient lighting and long-lasting light bulbs. Lamp manufacturers have reduced the use of mercury over the years. One hundred fluorescent lamps contain approximately 4 grams of mercury (AERC Web site: www.aercrecycling.com/pps/index1.html ). If improperly handled or disposed of, mercury lamps contribute to mercury emissions.
Each year, there are millions of fluorescent lamps and spent electronic products that are improperly discarded in northern Virginia. Computer monitors and lamps, when thrown away, can discharge mercury and other toxins into the environment. People in the northern Virginia region are becoming increasingly aware that recovering such things as mercury lamps and old computers prevents this toxic pollution. Fluorescent and high-intensity discharge (HID) lamps contain mercury, which is a potent nerve toxin. Mercury damages the brain, liver, and kidneys and causes developmental disorders in children.
Outreach
The Northern Virginia Waste Management Board and Northern Virginia Regional Commission (http://www.knowtoxics.com) are developing an outreach program to promote the safe disposal of this e-waste by larger generators under the universal waste rule. The first step is with mercury lamps. Similar efforts have been made in many regions and states throughout the US (background information can be found at http://www.almr.org/).
The northern Virginia region is launching an outreach program to address this concern by creating greater community awareness of the benefits of mercury lamp and e-waste recovery.
A combination of methods has been developed for lamp collection, including drum-top crushers, “recycling-by-mail,” and lamp and electronic waste pick-ups.
Drum-Top Crushing
As with any hazardous waste recovery process, there are risks involved with lamp recovery. One hotly debated technology is drum-top crushers. A 2005 EPA study on the subject (“Drum-Top Crushing of Mercury Lamps,” by Gregory Helms, USEPA Office of Solid Waste Conference on Achieving Mercury reduction in Products and Waste, Northeast Organization of Solid Waste Management Officials, May 24, 2005) explores the concerns of lamp crushers. Most mercury is contained by the drum-top crushing, but there are concerns that very small amounts of mercury may be inevitably released. Some states (California, Minnesota, Pennsylvania) and much of the Northeast require a permit to operate lamp-crushing systems. When broken in a drum-top lamp crusher, mercury is retained, but some small fraction can be released.
Drum change-outs can cause short term releases of mercury and therefore should be done quickly.
Because of the lack of detailed guidance in the Universal Waste Rule preamble, and the prompting of one state, EPA Region 3 is drafting guidance to state programs interested in allowing crushing. In the EPA Drum Crusher Study, mercury was tested using Hopcalite sample media (for the operator samples), and a Jerome Mercury Vapor Analyzer for the ambient air levels. Data were collected through July 2003, and four rounds of testing were carried out with three drum top crushers in three locations. Tested crushers from three manufacturers (Dextrite, Air Cycle, and RTI) were conducted in Virginia, Arizona and Florida. A fourth crusher dropped out due to poor performance. Approximately 5,500 lamps were crushed and these tests were done at permitted commercial lamp recyclers (AERC and EPSI).
This study observed that it is critical that drum-top crushers are properly assembled and operated. Also, they require operation training and the inspection of seals before each use. Since higher levels of mercury release at drum changes are inevitable, these can be reduced through practicing the drum change procedure and using a two-person team.
A Balancing Act
With the great interest in lamp crushing to reduce volume and save on transportation costs, environmental exposure issues also must be balanced. Another area of question is that of the need for crushing-room ventilation. While drum-top crushers are supposed to achieve a particle retention rate of 99.97% in the filter, several environmental officials cite this as a concern. Key pollution controls for lamp crushers and best management practices are essential to ensure public health and control environmental releases. Unfortunately no cost-benefit quantitative analysis exists to evaluate the effectiveness of lamp recovery using these drum top units in lessening overall mercury emission.
Good Business Sense
In the Washington DC area, major property management firms are realizing that it is good business sense for safe asset management, since this provides security that ensures all information is protected on computers and other electronics are safely destroyed. (The Federal Trade Commission has issued mandatory document destruction rules from the Fair and Accurate Credit Transactions Act of 2003. Penalties can be as high as $2,500 per incident, and violators may be exposed to class-action lawsuits. For example, any organization that possesses personal data within the workplace must make every effort to shred papers containing personal data and to destroy or erase electronic files or media. More information can be found at http://www.ftc.gov/bcp/online/pubs/alerts/disposalalrt.htm.)
Also by managing this waste through approved, licensed, and permitted facilities and by documenting compliance, they ultimately profit.
Trammell Crow is the top property manager of commercial office space in the northern Virginia-DC-Maryland metropolitan area, managing 270 properties and over 22 million square feet.
In 2005 the company collected more then 10,000 lbs of old lamps. Nationwide, Trammell Crow has extended this program to the nearly 400 million square feet it manages. In the DC area alone, that means over 2 million lamps in use. Trammell Crow facilities have been recruited as members of Businesses for the Bay, the regional pollution prevention effort in support of Chesapeake Bay restoration.
The recovery of spent lamps requires a target outreach campaign aimed at property management companies and building managers.
Those who handle mercury lamps have the legal responsibility for proper disposal of mercury-containing lamps.
Universal Waste Rule
EPA added mercury-containing materials and equipment to the Universal Waste Rule including: lamps, batteries and mercury containing thermostats. EPA estimates there are 1877 generators handling 550 tons of mercury-containing equipment affected by this rule. (www.epa.gov/epaoswer/hazwaste/recycle/electron/crt.htm)
Other types of public/private partnerships and incentives can be explored to ensure that mercury lamp handling is properly addressed. It is time for us to shed new light on reducing mercury pollution. According to the Association of Lighting and Mercury Recyclers (ALMR) and the National Electrical Manufacturers Association (NEMA), there are an estimated 670 million fluorescent lamps discarded in the United States each year, of which only about 24% are recycled.
The lamps that are thrown away may break because of their fragile nature. However, this causes only a small amount of mercury to be released into the atmosphere, since most of the mercury is not in a vapor state. Mercury also is a part of e-waste: The average life span of a computer is 2 years, and Americans are junking some 3,000 tons of related equipment each day.
Water Quality
Another impact of mercury pollution is to our water. Whether the lamps are considered hazardous or not, when lamps are broken in solid waste containers where rainfall can enter and leak out, the water table is affected. No one knows how many containers there are, how many will have tops open when it is raining or exactly how many lamps will break in any container.
Eventually these lamps break and most of the breakage occurs in the container, not at the landfill, since compacting occurs typically in containers. When these containers are also exposed to moisture from rain or other sources and they leak, or when they are washed out, mercury enters the environment.
Other studies indicate that when fluorescent lamps break in containers the mercury can remain for days and migrate downwind and back onto the land. (Lindberg, S. et al. 1999. “Pathways of Mercury in Solid Waste Disposal, Preliminary Data Report.”) Today’s fluorescent lamps can contain anywhere from 3 mg to 15 mg of mercury per lamp depending on whether or not it is TCLP-compliant. There is enough mercury in one fluorescent lamp to contaminate 7,000 gallons of drinking water if improperly disposed. The Association of Lighting and Mercury Recyclers has called for a study to determine the impacts of broken mercury lamps on water quality.
The Role of RCRA
Until recently, all hazardous wastes were regulated uniformly under the Resource Conservation and Recovery Act (RCRA). The RCRA defines which materials are considered solid wastes and then identifies which are hazardous and subject to hazardous waste requirements. In 1995 the USEPA finalized streamlined requirements for collecting certain widely dispersed hazardous wastes under the Universal Waste Rule because their diffuse nature made them difficult to monitor, particularly if the rules were lengthy or complex.
USEPA concluded there was enough evidence that spent mercury-containing lamps were a high source of mercury in the municipal solid waste stream. These findings, along with heightened concerns about mercury in the environment, have resulted to the inclusion of waste lamps in the Universal Waste Rule.
Under the Universal Waste Rule the users of fluorescent lamps must characterize spent lamps using the TCLP test to determine hazardous waste classification for appropriate disposal. Users also must recycle the lamps by a reclaimer or dispose of spent lamps in a hazardous waste landfill.
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Under the RCRA, those who generate less than 100 kg/mo (220 pounds) or less than 1000 kg of hazardous waste are exempted from RCRA hazardous waste requirements.
Management of mercury-containing lamps under these regulations is based on a “recycling presumption,” that is, in order to qualify for reduced management requirements the lamps must be collected or managed for recycling/reclamation. Lamps that are to be “disposed of” rather than legitimately recycled/reclaimed are subject to full regulation as hazardous wastes if they exhibit a hazardous waste characteristic.
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Elements 2007
Mercury Lamp and E-Waste Recovery in Northern Virginia
While individual fluorescent tubes may contain very small amounts of mercury, collectively they become a hazardous waste issue when they no longer work. One region of the US has taken action.
Mercury is an essential ingredient in energy-efficient lighting and long-lasting light bulbs. Lamp manufacturers have reduced the use of mercury over the years. One hundred fluorescent lamps contain approximately 4 grams of mercury (AERC Web site: www.aercrecycling.com/pps/index1.html ). If improperly handled or disposed of, mercury lamps contribute to mercury emissions.Each year, there are millions of fluorescent lamps and spent electronic products that are improperly discarded in northern Virginia. Computer monitors and lamps, when thrown away, can discharge mercury and other toxins into the environment. People in the northern Virginia region are becoming increasingly aware that recovering such things as mercury lamps and old computers prevents this toxic pollution. Fluorescent and high-intensity discharge (HID) lamps contain mercury, which is a potent nerve toxin. Mercury damages the brain, liver, and kidneys and causes developmental disorders in children.
Outreach
The Northern Virginia Waste Management Board and Northern Virginia Regional Commission (http://www.knowtoxics.com) are developing an outreach program to promote the safe disposal of this e-waste by larger generators under the universal waste rule. The first step is with mercury lamps. Similar efforts have been made in many regions and states throughout the US (background information can be found at http://www.almr.org/).
The northern Virginia region is launching an outreach program to address this concern by creating greater community awareness of the benefits of mercury lamp and e-waste recovery.
A combination of methods has been developed for lamp collection, including drum-top crushers, “recycling-by-mail,” and lamp and electronic waste pick-ups.
Drum-Top Crushing
As with any hazardous waste recovery process, there are risks involved with lamp recovery. One hotly debated technology is drum-top crushers. A 2005 EPA study on the subject (“Drum-Top Crushing of Mercury Lamps,” by Gregory Helms, USEPA Office of Solid Waste Conference on Achieving Mercury reduction in Products and Waste, Northeast Organization of Solid Waste Management Officials, May 24, 2005) explores the concerns of lamp crushers. Most mercury is contained by the drum-top crushing, but there are concerns that very small amounts of mercury may be inevitably released. Some states (California, Minnesota, Pennsylvania) and much of the Northeast require a permit to operate lamp-crushing systems. When broken in a drum-top lamp crusher, mercury is retained, but some small fraction can be released.
Drum change-outs can cause short term releases of mercury and therefore should be done quickly.
Because of the lack of detailed guidance in the Universal Waste Rule preamble, and the prompting of one state, EPA Region 3 is drafting guidance to state programs interested in allowing crushing. In the EPA Drum Crusher Study, mercury was tested using Hopcalite sample media (for the operator samples), and a Jerome Mercury Vapor Analyzer for the ambient air levels. Data were collected through July 2003, and four rounds of testing were carried out with three drum top crushers in three locations. Tested crushers from three manufacturers (Dextrite, Air Cycle, and RTI) were conducted in Virginia, Arizona and Florida. A fourth crusher dropped out due to poor performance. Approximately 5,500 lamps were crushed and these tests were done at permitted commercial lamp recyclers (AERC and EPSI).
This study observed that it is critical that drum-top crushers are properly assembled and operated. Also, they require operation training and the inspection of seals before each use. Since higher levels of mercury release at drum changes are inevitable, these can be reduced through practicing the drum change procedure and using a two-person team.
A Balancing Act
With the great interest in lamp crushing to reduce volume and save on transportation costs, environmental exposure issues also must be balanced. Another area of question is that of the need for crushing-room ventilation. While drum-top crushers are supposed to achieve a particle retention rate of 99.97% in the filter, several environmental officials cite this as a concern. Key pollution controls for lamp crushers and best management practices are essential to ensure public health and control environmental releases. Unfortunately no cost-benefit quantitative analysis exists to evaluate the effectiveness of lamp recovery using these drum top units in lessening overall mercury emission.
Good Business Sense
In the Washington DC area, major property management firms are realizing that it is good business sense for safe asset management, since this provides security that ensures all information is protected on computers and other electronics are safely destroyed. (The Federal Trade Commission has issued mandatory document destruction rules from the Fair and Accurate Credit Transactions Act of 2003. Penalties can be as high as $2,500 per incident, and violators may be exposed to class-action lawsuits. For example, any organization that possesses personal data within the workplace must make every effort to shred papers containing personal data and to destroy or erase electronic files or media. More information can be found at http://www.ftc.gov/bcp/online/pubs/alerts/disposalalrt.htm.)
Also by managing this waste through approved, licensed, and permitted facilities and by documenting compliance, they ultimately profit.
Trammell Crow is the top property manager of commercial office space in the northern Virginia-DC-Maryland metropolitan area, managing 270 properties and over 22 million square feet.
In 2005 the company collected more then 10,000 lbs of old lamps. Nationwide, Trammell Crow has extended this program to the nearly 400 million square feet it manages. In the DC area alone, that means over 2 million lamps in use. Trammell Crow facilities have been recruited as members of Businesses for the Bay, the regional pollution prevention effort in support of Chesapeake Bay restoration.
The recovery of spent lamps requires a target outreach campaign aimed at property management companies and building managers.
Those who handle mercury lamps have the legal responsibility for proper disposal of mercury-containing lamps.
Universal Waste Rule
EPA added mercury-containing materials and equipment to the Universal Waste Rule including: lamps, batteries and mercury containing thermostats. EPA estimates there are 1877 generators handling 550 tons of mercury-containing equipment affected by this rule. (www.epa.gov/epaoswer/hazwaste/recycle/electron/crt.htm)
Other types of public/private partnerships and incentives can be explored to ensure that mercury lamp handling is properly addressed. It is time for us to shed new light on reducing mercury pollution. According to the Association of Lighting and Mercury Recyclers (ALMR) and the National Electrical Manufacturers Association (NEMA), there are an estimated 670 million fluorescent lamps discarded in the United States each year, of which only about 24% are recycled.
The lamps that are thrown away may break because of their fragile nature. However, this causes only a small amount of mercury to be released into the atmosphere, since most of the mercury is not in a vapor state. Mercury also is a part of e-waste: The average life span of a computer is 2 years, and Americans are junking some 3,000 tons of related equipment each day.
Water Quality
Another impact of mercury pollution is to our water. Whether the lamps are considered hazardous or not, when lamps are broken in solid waste containers where rainfall can enter and leak out, the water table is affected. No one knows how many containers there are, how many will have tops open when it is raining or exactly how many lamps will break in any container.
Eventually these lamps break and most of the breakage occurs in the container, not at the landfill, since compacting occurs typically in containers. When these containers are also exposed to moisture from rain or other sources and they leak, or when they are washed out, mercury enters the environment.
Other studies indicate that when fluorescent lamps break in containers the mercury can remain for days and migrate downwind and back onto the land. (Lindberg, S. et al. 1999. “Pathways of Mercury in Solid Waste Disposal, Preliminary Data Report.”) Today’s fluorescent lamps can contain anywhere from 3 mg to 15 mg of mercury per lamp depending on whether or not it is TCLP-compliant. There is enough mercury in one fluorescent lamp to contaminate 7,000 gallons of drinking water if improperly disposed. The Association of Lighting and Mercury Recyclers has called for a study to determine the impacts of broken mercury lamps on water quality.
The Role of RCRA
Until recently, all hazardous wastes were regulated uniformly under the Resource Conservation and Recovery Act (RCRA). The RCRA defines which materials are considered solid wastes and then identifies which are hazardous and subject to hazardous waste requirements. In 1995 the USEPA finalized streamlined requirements for collecting certain widely dispersed hazardous wastes under the Universal Waste Rule because their diffuse nature made them difficult to monitor, particularly if the rules were lengthy or complex.
USEPA concluded there was enough evidence that spent mercury-containing lamps were a high source of mercury in the municipal solid waste stream. These findings, along with heightened concerns about mercury in the environment, have resulted to the inclusion of waste lamps in the Universal Waste Rule.
Under the Universal Waste Rule the users of fluorescent lamps must characterize spent lamps using the TCLP test to determine hazardous waste classification for appropriate disposal. Users also must recycle the lamps by a reclaimer or dispose of spent lamps in a hazardous waste landfill.
Under the RCRA, those who generate less than 100 kg/mo (220 pounds) or less than 1000 kg of hazardous waste are exempted from RCRA hazardous waste requirements.
Management of mercury-containing lamps under these regulations is based on a “recycling presumption,” that is, in order to qualify for reduced management requirements the lamps must be collected or managed for recycling/reclamation. Lamps that are to be “disposed of” rather than legitimately recycled/reclaimed are subject to full regulation as hazardous wastes if they exhibit a hazardous waste characteristic.
States ultimately decide how to regulate lamp disposal and recycling. A number of states now ban the disposal of mercury-containing lamps or else have limited the amount of these entering disposal facilities. These states also require commercial facilities to recycle these lamps. In New York, households and very small generators of lamp waste are exempt from the new rule.
Shedding Light on Mercury
The development of numerous collection avenues for mercury lamp and e-waste recovery must be stimulated. Other types of public/private partnerships and incentives can be explored to ensure that mercury lamp handling is properly addressed.
There is a new alliance to promote recycling. “Most people simply are not aware that fluorescent lamps contain mercury to help save energy, and that they can easily be recycled” says Paul Abernathy of the Association of Lighting and Mercury Recyclers.
“We need to get the right information to the people who make disposal decisions to avoid adding to the mercury in our environment.” This project is being funded by the US EPA. ALMR has partnered with the Solid Waste Association of North America and the National Electrical Manufacturers Association in an outreach program for businesses, which use 85% of the fluorescent lighting in the US.
The outreach, which will include meetings and workshops around the country, features a CD-ROM—available at no charge—that gives businesses the resources and information they need to set up recycling programs.