BASICS OF HAZARDOUS WASTE DISPOSAL

BASICS OF HAZARDOUS WASTE DISPOSAL

Created by the U.S. Department of Energy Rebuild America Business

Partners and Earth Protection Services, Inc.

Created by the U.S. Department of Energy Rebuild America Business

Partners and Earth Protection Services, Inc.

Proper Disposal of MercuryProper Disposal of Mercury

Some Facts About Mercury

Mercury is classified as one of several "heavy" metals which are regulated under the Resource Conservation and Recovery

Act (RCRA) waste disposal guidelines. When mercury is tested using the Toxicity Characteristic Leaching Procedure (TCLP) and the mercury within the waste leaches out at a rate which meets or exceeds 0.2 mg/l, then that waste is

classified as a "D009" RCRA regulated waste.

Mercury can also be classified as a RCRA listed waste, U151, when the metal is in its "unused" chemical grade form. Whether classified as a U151, or as a D009, mercury is subject to the

Land Disposal Restrictions (LDR) for hazardous wastes as provided in 40 CFR Part 268.

Hazardous wastes which contain mercury can be treated either by retort, incineration, or stabilization. "Retorting" or roasting is the preferred process environmentally in which a thermal processing unit is used to vaporize mercury and subsequently condense the volatilized mercury for recovery.

Local and state environmental regulations combine with the strict EPA enforcement of the Resource Conservation and

Recovery Act (RCRA) and the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) to

regulate the generation, treatment, storage, handling, clean-up, transportation and disposal of hazardous wastes, including

products which contain Mercury.

What Are the Human Health Hazards Caused By Mercury?

Although mercury can be taken in through the lungs, mouth or skin, the most likely exposure is by eating

mercury-contaminated fish. It is the most toxic form -methylmercury - that collects in the flesh of fish.

Mercury affects the human brain, spinal cord, kidneys and liver. It affects the ability to feel, see, taste and move. There can be tingling sensations in the fingers and toes, a numb sensation around

the mouth, and tunnel vision. Long-term exposure to mercury can result in symptoms that get progressively worse and lead to personality

changes, stupor and coma.

Women who expect to become pregnant or are pregnant should not eat mercury-contaminated

fish. Mercury affects fetal development, preventing the brain and nervous system from developing normally. Affected children show

lowered intelligence, impaired hearing and poor coordination. Their verbal and motor skills may be

delayed.

Eagles, osprey, loons,turtles, mink, otters, and other fish eating creatures are at risk from eating mercury-contaminated fish. Mercury in their diets can cause early death, weight loss, and problems with their ability to reproduce.

Why is Mercury used in Lamps?

Fundamental to efficient operation of fluorescent lamps

Efficiently generates ultra-violet radiation that is converted to visible light by the phosphor

Too little mercury for lamp operation under all conditionsmay result in: • short lamp life • low output • pink color

A “no-mercury” fluorescent lamp loses ~70% efficiency No prospect for elimination of mercury

Metal Halide and most HPS use mercury as starting aid and voltage control

Some prospects for elimination (eg Hg-free HPS)

Lamp Disposal

Efficient light sources contain:Mercury (fluorescent & most HID)Lead Solder (many lamps)Lead Glass (most lamps)

Annual Lamp Disposal Quantities: 650M (mercury containing)2,500M (other types)

Proper Disposal of Fluorescent and HID Lamps is Mandated by Federal Law!

Proper Disposal of Fluorescent and HID Lamps is Mandated by Federal Law!

Fluorescent and HID lamps are often found to be hazardous because of excessive mercury content.

Mercury is a chemical regulated under the Resource Conservation and Recovery Act (RCRA).

Lamps must be tested by an independent laboratory using EPA’s TCLP test which is designed to replicate what happens to discarded and broken lamps in a landfill. It specifically determines whether the mercury in the lamp will run off (leach) into the ground and contaminate ground water.

Lamps are considered hazardous if they fail the TCLP test.

Do All Lamps Fail The TCLP Test?

TCLP test results of individual lamps may vary. However, more often than not the results are negative.

If your lamps fail the TCLP test your business is a generator of waste containing a toxic chemical which is therefore hazardous and is subject to regulation under the Federal RCRA law.

All fluorescent lamps on the market today contain mercury. If disposed of in sufficient quantities, even low-mercury lamps pose environmental dangers.

What Alternatives do Generators of Hazardous Waste Have?

Dispose of Lamps as a Hazardous Waste.

Seek a special waste exclusion from the state to allow lamps to be placed in the trash.

Do nothing and continue to send out with regular trash thereby risking environmental liability.

Manage Lamps as a Universal Waste and recycle with properly licensed and permitted companies.

Universal Waste Basic Principals Eases handling and disposal regulations and reduces cost

to properly manage and recycle due to the fact that shipments can be made via bill of lading. A uniform hazardous waste manifest is no longer required. Requires full regulatory compliance for hazardous waste if recycling is not chosen.

Does not require the analytical testing or reporting of whole lamps destined for recycling.

Generators of universal waste lamps are prohibited from crushing lamps. EPA feels that uncontrolled crushing of lamps in containers meeting general performance standards would not sufficiently protect human health.

Contractors who remove universal waste lamps from serviceare considered handlers and co-generators of the waste.

Universal Waste Rule - General CaseThree categories for disposers of Universal Waste Exempt

Households Conditionally Exempt Small Quantity

Generator Lamps which pass TCLP

Small Quantity Universal Waste Handler Accumulates <5000 Kg of all universal

wastes Large Quantity Universal Waste Handler

Accumulates >5000 Kg of all universal wastes

http://www.epa.gov/buildings/esbhome/newsroom/Bulletin200002.pdf

IncreasingRegulatoryBurden

What Risks Are Taken If Lighting Materials Are Thrown Away?

Violating hazardous waste regulations can trigger state and federal enforcement actions and result in significant monetary fines:

Reynolds School District, Troutdale, Oregon - $400,000West Linn-Wilsonville, Oregon - $328,300University of New Hampshire - $229,000

“Responsible businesses learned long ago that good environmental performance is a sound business practice. It’s a sound practice for a university as well.”

– John P. DeVillars, EPAs New England Administrator

How Can EPSI Help Minimize Environmental Liability?

• Lamp Recycling - Toxic substances from glass, aluminum and other lamp components are removed and on-site retorted using advanced mechanical and thermal technologies to recover mercury which is purified. All materials are TCLP tested – no hazardous material is generated.

• Ballast Recycling - PCB capacitors and potting compound are removed and sent to a EPA/TSCA high temperature incinerator. Copper, steel and aluminum are reclaimed for reuse in manufacturing.

Upon Completion of Proper DisposalCertificates of Recycling & Destruction are Issued

Fluorescent Lamps for Proper Disposal

Custom Designed Lamp De-Manufacturing Machinery& Component Separator

Hg / Powder Aluminum Glass

Basic Lamp Recycling Process

Hg (99.999% Pure)Calcium Phosphate

THERMALRETORT

RETURNED TO INDUSTRY

HID Bulb Recycling Process

Lamp Separation

Hg Ampule GlassMetal

THERMALRETORT

TRIPLEDISTILLEDMERCURY

99.999%PURE

PRODUCT

RECYCLED

GlassAluminumEndcaps

PhosphorPowder

Mercury

Uses of Recovered Lamp Components

ManufacturingPaving Material

Sent toSmelter

Used ForChemical Value

Triple Distilled & Returned to Commerce

All MaterialsPass TCLP

No HazardousMaterial Generated

Other Lamp Typesfor Recycling

IncandescentHalogenLow / High Pressure Sodium

These lamps do not contain mercury,but fail TCLP for other metals such as lead.

Proper Disposal of PCB’sProper Disposal of PCB’s

Lamp ballasts contain an oil-filled capacitor which may contain polychlorinated biphenyls (PCB) or di (2-ethyl hexyl) phthalate (DEHP). PCBs and DEHP are regulated under the U.S. EPA Comprehensive Environmental Response Compensation and Liability Act ("Superfund") as a hazardous substance. In addition, several states regulate PCBs as a hazardous waste (e.g. Massachusetts, Maine, Rhode Island, California, etc.).

Proper Disposal of Ballasts is Mandated by Federal Law!

Generators can choose from three (3) different methods of recycling or

disposal options including:

•Whole Ballast Incineration

•Recycle and Incineration

•Recycle and Landfill

Lamp ballasts that are recycled and incinerated are handled such that the PCB containing component (capacitor and potting compound) are manifested and sent to properly

licensed incinerators. Ballasts designated for chemical secured landfill are sent to a Subtitle C Secure Landfill. All recovered

metals are tested and sold to an approved smelter for reclamation.

PCB Mega Rule –Management of Fluorescent Light Ballast

According to data submitted in the Toxic Substances Control Act Section 21 Petition, ballasts manufactured prior to July 1978 have a better than 50% chance of containing PCBs at 50 ppm or greater in their potting material.

The US EPA is asking that anyone who seeks to dispose of these ballasts in a municipal landfill to dispose of them as PCB waste.

The recommended disposal method is high temperature incineration. If equipment is labeled "Non-PCB", then it has no PCB's. If the equipment is either unmarked or poorly marked, the generator should assume PCB content >500 ppm and dispose of in accordance with TSCA guidelines.

The Center For Disease Control reports that workers exposed to DEHP

and PCBs have developed:

Cancer of the liver

Skin disorders

Irritation of skin and membranes

Adverse reproductive effects

The primary concern regarding the disposal of ballasts is the health risk associated with polychlorinated biphenyls (PCBs) and Di(2-ethylhexyl) phthalate (DEHP).

Steps to Certification

Spend ballasts collected and shipped to licensed Recycler Load info registered

Ballast dismantledBallast metal tested according to EPA Standards

Metals shipped to smelter

Incinerable components sent to disposal facility

Certificate of Destruction

Monitors, keyboards, printers and batteries contain chemicals such as lead, mercury, cadmium, lithium and beryllium which pose an environmental threat when disposed of in landfills.

Some states, such as Massachusetts, have banned the disposal of computer monitors in municipal landfills.

State regulators are enforcing regulatory standards in order to reduce land-filling of outdated electronic equipment.

CRT's (monitors) may contain leaded glass which also has demonstrated the inability to pass the TCLP test due to high levels of leachable heavy metals.

State and Federal regulatory agencies have begun enforcing the “Land Ban” on CRTs. Regulatory trends are leaning toward proper management of all electronic scrap.

Approximately 20% of disgarded electronic equipment can be reused and 80% can be properly recycled.

As a generator of computer waste, the most common options considered for computer disposal are: Determine that your computer waste is hazardous/non-hazardous by conducting a TCLP test on every model and design.

Assume that your computer waste is hazardous and dispose of in accordance with RCRA, State, and Local regulations.

Printed circuit boards may contain heavy metals in concentrations that exceed the Toxicity Characteristic Leaching Procedure (TCLP) and are regulated under the Resource Conservation and Recovery Act (RCRA) waste disposal guidelines.

                  

               

                  

               

Battery Recycling Protects Our Environment From Heavy Metal Contamination.

Once batteries are removed from service, most meet the definition of a hazardous waste as they exhibit a hazardous characteristic- corrosive, reactive, or toxic. As such, their disposal is regulated under the Resource Conservation Act (RCRA) guidelines, 40 CFR 261 through 268.

Types of batteries which can be recycled include:

Alkaline, Silver, Zinc, Gel cel, Gates Sealed Lead Acid, NiCad, NiFe, Magnesium, Mercury, Lithium & Carbonaire with/Hg