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Presentations May 23 – 25, 2005 Portland, Maine For related information visit:

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1 Presentations May 23 – 25, 2005 Portland, Maine For related information visit:

2 Ray Graczyk’s Presentation Is Separate From The Three Of These.

3 NEWMOA Lamp Recycling Outreach Project Achieving Mercury Reduction in Products & Waste: Coordinating National & Local Government Initiatives Portland, Maine May 24, 2005

4 EPA Lamp Recycling Outreach NEWMOA one of 10 grantees EPA Office of Solid Waste Goal to increase national recycling rate to 40% by 2005, to 80% by 2009

5 NEWMOA Outreach Program Lamp Recycling Workgroup Estimate baseline recycling rate Electrical distributor outreach: Make recycling more convenient Property Manager outreach: Motivate to increase recycling

6 Why Distributors? Important link Convenient, one-stop shopping arrangement for lamp purchasing and spent lamp management Potential business opportunity

7 Distributor Comments on Lamp Recycling The profit is better on recycling lamps than on the sale of new lamps, Jim Baines, Wesco “The real benefit of our recycling program is receiving orders for lamps that we wouldn’t have if we didn’t recycle,” Greg Smith, Granite City Electric “Offering a recycling option to customers can be a good ‘value-add’ service for distributors,” TED Magazine

8 Lamp Take Back Programs Customer Drop-off (Electrical Wholesalers) Distributor Picks Up Lamps (J.G. Temple) Distributor Acts as a Broker (Ralph Pill) Box Programs (Grainger, Graybar) Universal Waste Consolidation Facility (Wesco)

9 Electrical Distributor Outreach Led 3 sub-regional meetings Goals to educate distributors on state management requirements; encourage lamp take back; business to business dialogue with recyclers

10 Distributor Meeting Results 30 distributors representing 14 different companies attended the meetings Attendees ranged from individual branch managers, to company-wide representatives to northeast district managers NEWMOA educated many more distributors who did not attend

11 Distributor Meeting Results Reverse distribution set up at 29 branches of 7 different companies Grainger and Graybar reported expansion of their recycling services

12 Distributor Take Back Important Factors State Requires Recycling Across the Board Few Options for Recycling in Distributor’s Area Strong Outreach Program Competition Customer Demand

13 Property Manager Outreach Anecdotal evidence of minimal compliance Potential to reach many lamp users Social Marketing Approach: Identify barriers and potential incentives

14 Lamp Workgroup’s Assessment of Barriers to Recycling Perceived lack of convenience Cost Lack of enforcement Poor awareness

15 Social Marketing Research Focused on Understanding: How/where property managers get information How lamp management decisions are made Communications with tenants Budget process

16 Benefits of the Research Helped workgroup: Better understand roles of different players in property management sector Identify key professional organizations Identify important publications Confirm anecdotal information about budget process, barriers Hone its messages

17 For more information Meg Wilcox X305

18 Presentations May 23 – 25, 2005 Portland, Maine

19 Influences for Change Promoting Lamp Recycling Among Commercial Property Managers Portland, Maine May 24, 2005 Promoting Lamp Recycling Among Commercial Property Managers Portland, Maine May 24, 2005

20 Interviews  Minute Phone Interviews  11 Property Managers at 9 Different Massachusetts Firms  Very Small (38, ,000 sq. ft.)  Medium (8 - 9 million sq. ft.)  Very Large ( million sq. ft.)  Office, Mixed Office/Retail, Upscale Shopping Mall  Minute Phone Interviews  11 Property Managers at 9 Different Massachusetts Firms  Very Small (38, ,000 sq. ft.)  Medium (8 - 9 million sq. ft.)  Very Large ( million sq. ft.)  Office, Mixed Office/Retail, Upscale Shopping Mall

21 Lamp Replacement  Very Small:  Building Superintendents  Maintenance or Cleaning Staff (In-House or Contractual)  Larger:  Janitorial Staff or Contractors  Construction/Maintenance Staff or Contractors  Electrical/Maintenance Contractors or ESCOs for Major Relamping  Very Small:  Building Superintendents  Maintenance or Cleaning Staff (In-House or Contractual)  Larger:  Janitorial Staff or Contractors  Construction/Maintenance Staff or Contractors  Electrical/Maintenance Contractors or ESCOs for Major Relamping

22 Lamp Replacement  Retail:  Generally Responsible for In-Store Lamp Replacement, but Some Hire Property Management Firm to Carry Out this Task  Retail:  Generally Responsible for In-Store Lamp Replacement, but Some Hire Property Management Firm to Carry Out this Task

23 Lamp Management Decision Makers  Very Small: Property Management Company Owner  Larger: General Manager/Property Manager  Budget Cycle: Calendar Year  Preparation begins in mid to late summer for large firms; late summer to fall for small firms  Very Small: Property Management Company Owner  Larger: General Manager/Property Manager  Budget Cycle: Calendar Year  Preparation begins in mid to late summer for large firms; late summer to fall for small firms

24 Information Sources  Very Small:  Community Associations Institute  Letters from State and Local Government  Very Small:  Community Associations Institute  Letters from State and Local Government

25 Information Sources  Larger:  BOMA, NAIOP  Internal Training (v. large firms)  Waste Removal Vendors  State and Local Government  Consultants  Daily Updates  Boston Business Journal  BOMA newsletters  Larger:  BOMA, NAIOP  Internal Training (v. large firms)  Waste Removal Vendors  State and Local Government  Consultants  Daily Updates  Boston Business Journal  BOMA newsletters

26 Information Sources  Large Retail:  International Council of Shopping Centers  International Retail Federation  “Shopping Centers Today” (ICSC)  “Chain Store Age”  Large Retail:  International Council of Shopping Centers  International Retail Federation  “Shopping Centers Today” (ICSC)  “Chain Store Age”

27 Influences for Change  Cost Considerations (Potential Expenditures and Savings)  Laws, Code Compliance Requirements, Corporate Policy  Tenant Satisfaction  Environmental Concern  Turn-Key Program Provided by Waste Removal Vendor  Cost Considerations (Potential Expenditures and Savings)  Laws, Code Compliance Requirements, Corporate Policy  Tenant Satisfaction  Environmental Concern  Turn-Key Program Provided by Waste Removal Vendor

28 Presentations May 23 – 25, 2005 Portland, Maine

29 Drum-Top Crushing of Mercury Lamps by Gregory Helms US EPA Office of Solid Waste Presented to: Conference on Achieving Mercury Reduction in Products and Waste May 24, 2005

30 What is Drum-Top Crushing? Drum-Top Crushers are devices designed to volume-reduce waste fluorescent lamps by crushing them in a contained environment. Crushers fit on the top of a 55 gallon drum. When mercury lamps are broken or crushed, the mercury is released.

31 What is Drum Top Crushing? Crushers are designed to contain the mercury released from lamps when they are broken. –Crushers are sealed and operate at negative pressure (generated by a vacuum pump). –Air is exhausted through particle and Granular Activated Carbon (GAC) filters. Most mercury is contained by the Drum Top Crusher, but some is inevitably released.

32 What is Drum top Crushing? The key questions in operating Drum Top Crushers are: –How much mercury is released? –Who is exposed? –What are exposure levels?

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36 Why do Drum Top Crushing? Many waste mercury lamps are hazardous waste. –They are therefore required to be handled according to hazardous waste regulations for transport, storage, treatment and disposal. –Alternately, hazardous waste lamps may be handled as Universal Wastes (UW). The UW rule reduces RCRA requirements to facilitate entry of lamps into the waste management system and recycling.

37 Why Do Lamp Crushing? Spent lamps are a high-volume, low-mass waste. –Available storage may be limited. –Lamps are fragile, and breakage may occur. –Shipping crushed lamps is much cheaper than shipping whole lamps (on a per-lamp basis). Approximately lamps will fit in a 55 gallon drum when crushed.

38 Who Might Do Drum-Top Crushing? Lamp Generators: Any facility that generates a significant number of waste lamps. –Industrial/manufacturing plants –Office buildings –Other commercial buildings Other Universal Waste Handlers: Crusher-equipped truck could visit office buildings.

39 How is Drum-Top Crushing Regulated? Lamp crushing is considered waste treatment because it: –changes the physical form of the waste; –reduces volume to make storage and transport safer and easier; –See 40 CFR and 64 FR , 7/6/99.

40 How is Drum-Top Crushing Regulated? Hazardous Waste treatment usually requires a RCRA waste treatment permit. –Exception: Waste generators may treat wastes without a RCRA treatment permit, under 40 CFR accumulation regulations (51 FR 10168, 3/24/86; 57 FR 37194, 8/18/92). –However, lamps crushed under this provision cannot subsequently be handled as UW.

41 How is Drum-Top Crushing Regulated? In the UW rule preamble, EPA recognized that some states allowed lamp crushing without a RCRA treatment permit (while others have prohibited crushing). The rule preamble said states could allow crushing by UW handlers if the state program includes a demonstration of equivalency to the federal ban on treatment without a RCRA permit, including: –Effective mercury emissions controls –Compliance assurance

42 How is Drum-Top Crushing Regulated? Lamps crushed under a state permit issued as part of an approved state UW program remain Universal Waste for subsequent management (as allowed by the state program).

43 What Are Lamp Crushing Environmental Concerns? All fluorescent lamps contain some mercury, which is necessary for their operation. When a lamp is broken, the mercury is released. –See: Aucott et.al, J. Air & Waste Mgt. Assoc., 53: , When broken in a drum-top lamp crusher, most mercury is retained, but some is released: –seals are imperfect and subject to wear; –GAC removes most, but not all mercury from exhaust air; –drum changes cause short-term, higher level release.

44 What Are Lamp Crushing Environmental Concerns? Potentially exposed individuals include: –The crusher operator –Other people in the same work area –Other people working in spaces sharing the HVAC system Release to the environment

45 EPA Drum-Top Crushing Study The lack of detailed guidance in the UW rule preamble, and the prompting of one state, led Region 3 to draft guidance to state programs interested in allowing crushing. Discussion of the draft guidance led to interest in a better understanding of Drum- Top Crusher performance. Region 3 took the lead in conducting a study of crushers.

46 EPA Drum-Top Crushing Study Four rounds of testing were done with three drum top crushers in three locations –Tested crushers from Dextrite, Air Cycle, and RTI –A fourth crusher dropped out due to poor performance –Tests conducted in Virginia (twice), Arizona and Florida –Approximately 5500 lamps crushed Testing was done at permitted commercial lamp recyclers: Thank you AERC and EPSI.

47 EPA Drum-Top Crushing Study Testing was conducted within a 12’x12’x10’ polyethylene containment to: –reduce the effects of variations in air circulation on mercury levels; and –isolate the test from background Hg. Mercury levels were tested in: –operator breathing zones; –crusher exhaust ports and other locations near the crusher, during drum changes; and –in the ambient air within and outside the containment during operation and overnight.

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49 EPA Drum-Top Crushing 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 The draft report is currently being peer reviewed, and will be released after EPA addresses peer review comments.

50 Observations from Study Proper DTC assembly and operation are critical and require: –Operator training –Inspection of seals before each use Higher level Hg release at drum changes are inevitable. Release can be reduced through: –Practicing the drum change procedure –Use of a 2-person team

51 Guidance to State Programs on Drum-Top Crushing Once the study report is completed we expect to return to the development of guidance to states on drum-top crushing programs.

52 Minnesota Dept. Health/ATSDR A limited study of drum top lamp crusher emissions, conducted by the Minnesota Dept. of Health, was released December 1, Minnesota Health Dept. and Pollution Control Agency staff attended a demonstration of an Air Cycle “Bulb Eater”. The demonstration ran for about 8 minutes. A Lumex analyzer was used to measure mercury vapor in the crusher exhaust air and at estimated breathing height in the room.

53 Minnesota Dept. Health/ATSDR Mercury levels at the exhaust port; –Range: mg/M 3 (N=5). Mercury at breathing height range: – mg/M 3 (N=4; door closed), and – mg/M 3 (N=3; door open). The OSHA PEL is 0.1 mg/M 3 (ceiling) The ACGIH TLV is mg/M 3 The EPA RfC is mg/M 3 (chronic exp.)

54 Implementation Issues If DTC devices are going to be used, several issues must be addressed: –Monitoring: One device failed to contain Hg, but we knew this during operation only because of the Jerome analyzer alarm. However, Hg vapor analyzers are expensive. –Ventilation: Crushing room ventilation should not be part of general building HVAC.

55 Free Advice for DTC Design Pressure check devices: Inadequate pressure inside DTC could indicate air leaks. Brominated GAC: Most DTCs use regular GAC. Recent EPA/ORD research on power plant emissions shows higher Hg adsorption with brominated GAC. Sulfur injection: Develop sulfiding agent injector to convert Hg in drum to HgS.

56 Conclusions Strong interest in lamp crushing to reduce volume and save transportation cost. Lamp crushing can create new exposures: –Crusher operator –Co-worker exposures –Exposures to the general public –Release to the environment Goal of study and guidance: ensure public health and control environmental release


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