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Crushing Mercury Lamps: When Is It Acceptable?

Posted on 6/24/2014 by James Griffin

The fluorescent lamps in offices and facilities across the US use mercury vapor for illumination. Under the US EPA’s RCRA regulations, wastes that contain elevated levels of leachable mercury compounds are hazardous waste. [40 CFR 261.24] When you discard the bulb from a tube or compact fluorescent lamp, you are discarding hazardous waste. Because nearly every office and business in the country generates this kind of waste (i.e., the wastes are generated universally), the Federal and every State EPA allow generators to manage these lamps under the universal waste rules. [40 CFR 273.5]
 
Most of the volume of a fluorescent lamp is empty space, filled with a thin mercury vapor. Crushing the lamps during storage saves space and is the first step of recycling. As long as the glass is contained and the vapors are recovered, crushing the lamps protects the environment.
 
The universal waste regulations allow generators to manage broken lamps along with whole ones. However, the EPA considers purposefully crushing lamps to be treatment of hazardous waste. [40 CFR 260.10] Generally, treating hazardous waste (even by simply physically reducing volume) requires a RCRA permit from the US or State EPA. [40 CFR 270.1] While the US EPA has permitted-by-rule some common activities (diverting to wastewater treatment unit, elementary neutralization, adding absorbents, disassembling mercury thermostats, etc.), it has not done so for crushing lamps. 
 
While the US EPA does not permit universal waste handlers to crush lamps, the Agency has authorized several State programs that do permit this form of treatment when those State RCRA programs include methods to contain mercury vapors. 
 
Which States Permit Lamp Crushing?
 
The following states permit universal waste handlers who meet certain conditions to crush universal waste lamps: 
 
  • Colorado [6 CCR 1007-3, Section 273.13(e), 6 CCR 1007-3 Section 273.33(e)]
  • Florida [FAC 62-737.400(6)(b)]
  • Illinois [35 IAC 733.113(d)(3) or 35 IAC 733.133(d)(3)]
  • Massachusetts [310 CMR 30.1034(5) and 310 CMR 30.1044(5)]
  • Maryland [COMAR 26.13.10.15(B)(3) and 26.13.10.20(D)]
  • Montana [ARM 17.53.1303]
  • New Mexico [NMAC 20.4.1.1001(C)]
  • Tennessee [Rule 0400-12-01-.12(2)(d)(4), 0400-12-01-.12(3)(d)(4), and 0400-12-01-.12(8)]
  • Texas [30 TAC 335.261(e)]
  • Virginia [9 VAC 20-60-273(B)(3)(b)]
Crushing mercury lamps under RCRA
 
How Does Crushing Work?
 
While there is variation between different states’ RCRA rules, the following conditions usually apply when a universal waste handler crushes lamps/bulbs: 
 
  • The handler must use a specially designed mechanical device to crush the lamps, accumulate the glass, and contain the mercury vapor.
  • The handler must crush the lamps in a final accumulation container.
  • The handler must crush the lamps in a controlled manner that prevents the release of mercury vapor or other contaminants to the environment.
  • The handler may need to recycle the captured mercury vapor and crushed glass or else manage the separated components as hazardous waste, if applicable
  • The handler must have and follow a written plan for operating and maintaining the crushing device. 
  • The handler must ensure that all employees operating the crushing device are trained on the operating and maintenance plan.
  • In some cases, the State EPA requires handlers to notify or register with the agency before they begin crushing lamps. Massachusetts requires lamp crushers to obtain a Class A recycling permit, which, while more burdensome than a permit-by-rule used in other states, is less burdensome than a RCRA treatment permit.
Be advised: Even when the state allows crushing, not every recycler is set up to receive pre-crushed glass and mercury vapors. And because only some states allow bulb-crushing, interstate shipments for recycling can be complicated.
 
Nationwide Annual RCRA Training for Managers and Personnel 
 
Be confident your site is in compliance with the latest RCRA hazardous waste rules! For annual training on the EPA’s core requirements for managing and storing hazardous waste on site, Lion presents the Hazardous/Toxic Waste Management Workshop in cities nationwide. 
 
Seeking new management strategies or recycling options to minimize waste and cut costs? The Advanced Hazardous Waste Management Workshop also covers the RCRA rules that generators must know, with an emphasis on strategies to streamline your operations, keep waste “out of the system” of RCRA, and treat waste on site without a RCRA permit. 
 

Tags: hazardous, RCRA, state rules, treatment, universal waste, waste

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