Time-critical Superfund Action to Clean Up Millions of Waste Lamps

Posted on 3/5/2018 by Roger Marks

EPA will begin a “Superfund time-critical removal action” to remove fluorescent lamps, lighting ballasts, and electronic equipment from a Cleveland, OH waste transporter’s warehouse. After a fire broke out in the warehouse earlier this year, EPA and the Cleveland Fire Department tested for and found mercury vapors and PCBs in the air. 
In total, EPA will remove two to three million lamps, 250 drums of lighting ballasts containing PCBs, and some electronic equipment from the facility.  (At right: Photo courtesy of US EPA)
There is no mention in EPA’s announcement of a financial settlement, but EPA has authority to pursue liable parties for costs incurred from cleanup activities under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). 
EPA may also issue civil penalties under RCRA, if management standards for storing lamps on site were not followed, and under the Clean Air Act, for release of hazardous air pollutants during the fire (depending on how much was released).  

Are Fluorescent Bulbs Hazardous Waste?

Fluorescent_Lamps_Universal_Waste_Closing_Box_2.jpgCompact fluorescent lamps are regulated as universal waste due to levels of mercury sufficient to trigger the D009 toxicity characteristic for mercury (in most traditional CFLs). Along with lamps, EPA regulates batteries, certain pesticides, and mercury-containing equipment as universal wastes under standards at 40 CFR Part 273.
States may add additional wastes to the list of universal waste. Texas, for instance, allows generators to manage paint-related wastes as universal waste. In California, cell phones, computers, cathode-ray tubes, and certain non-empty aerosol cans are regulated as universal waste (see 22 CCR Div. 4.5, Ch. 11, Section 66261.9). 
Under Federal universal waste requirements, universal waste lamps must be stored in closed, sturdy containers, be properly labeled, and be removed from the property within one year. 
Facilities that handle more than 5,000 kilograms of universal waste at any time must keep detailed records of universal waste shipments and training for personnel who handle universal waste. Training personnel and keeping those records is a best management practices for all generators and universal waste handlers, no matter the size. 
States may impose additional restrictions on the ID, management, handling, storage, or disposal of universal wastes.
Read more: 4 Common Universal Waste Mistakes And How To Avoid Them
Read more: State Differences for Universal Waste 
See best practices for cleaning up broken CFLs, for businesses or households, here. 

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Tags: CERCLA, hazardous waste, RCRA, Universal wastes, Waste lamps

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