1. Overview of Universal Waste (UW) Lamp Crushing in Virginia
May 16, 2017
VRA Conference
Virginia Beach

2. Purpose Provide a brief background on UW lamp crushing in Virginia
Provide an overview of the regulatory amendment and the associated requirements for lamp crushing focusing on the requirements for on-site lamp crushing by generators
Provide information and resources to assist facilities in complying with the new requirements

3. Background on the UW Rules
EPA issued the UW rule in 1995
UW include items that are commonly thrown into the trash by households and small businesses
Goal is to streamline environmental regulations for these types of wastes that are typically generated by a large number of businesses but in relatively small quantities

4. Specific Goals
Reduce the amount of hazardous waste items in the municipal solid waste stream
Encourage the recycling and proper disposal of some common hazardous wastes
Reduce the regulatory burden on businesses that generate these wastes

5. Crushing Under the Federal Regs
On July 6, 1999 EPA added “lamps” to the universal waste rule (64 FR 36466)
EPA stated that UW handlers should not be allowed to treat UW
Crushing = Treatment and is inconsistent with UW designation for lamps and prohibited
EPA provided a mechanism for states that already allowed crushing to demonstrate equivalency

6. Items for Equivalency Demonstration
The effectiveness of the technical requirements in controlling emissions of hazardous constituents;
The level of interaction of regulated entities with the regulatory agency to ensure compliance with the control requirements; and
Other factors that demonstrate state regulatory program equivalency to the Federal treatment prohibitions.

7. Summary of Virginia Regulatory Actions
DEQ adopted the UW lamp rules and included the provisions allowing crushing to the regulations effective March 13, 2002
DEQ subsequently applied for authorization and EPA published in the Federal Register an immediate final rule on March 13, 2003.
EPA reviewed Virginia's UW lamp regulations and determined that the requirements are at least as protective as, and therefore equivalent to, the Federal prohibition on the treatment of UW lamps
EPA had to withdraw this final rule on May 2, 2003 due to the adverse comments that were received

8. Current Regulatory Dilemma
To date DEQ has not received authorization for its UW lamp crushing rules
As such the state rules do not operate in lieu of the Federal regulations
This puts Virginia’s UW generators and handlers in an awkward regulatory position.
They are in compliance with Virginia’s requirements but not EPA’s
EPA could enforce the Federal
requirements

9. Recent Regulatory Activity
Worked with EPA to modify the regulations to support an equivalency demonstration
Initiated regulatory action in 2012 to amend the lamp crushing provisions
Held several stakeholder meetings to receive input
Amended regulations became effective January 1, 2017

10. Compliance Dates
Existing crusher operations (as of 1/1/17) were required to:
Notify by January 31, 2017, and
Achieve compliance with applicable regulatory requirements by April 1, 2017
New crushing operations must:
Notify 30 days prior to beginning operations
Comply with applicable regulatory requirements upon start-up

11. Summary of Changes
Written notification initially & when there are any changes
Crush on the site of generation or “under the control of the generator” only
Crushed lamps must be sent off-site for recycling.
No mobile crushing units
Written procedure
Unit must be hermetically sealed except for air intakes and operate under negative pressure
Air intake points closed except when not operating
Crush indoors only

12. Summary of Changes (con’t)
Ambient air isolated other work areas and discharges only after filtration
Air monitoring and compliance with risk-based protectiveness standards
“Beefed up” operation and maintenance and training requirements
Closure plan & financial assurance for large quantity handlers (based on lamps only)
All records (O&M, training, notices, testing, etc.) maintained & available

13. Notification Requirements
Written notification to DEQ must include:
The name of the company or individual
EPA ID Number, if one has been issued
Physical location of the crushing operation
Name, address, and phone number of operators and principal contact
A change in any of the information supplied with the initial notification must be submitted to DEQ within 15 days of occurring

14. Under the Control of the Generator
Lamps may be generated and crushed at different facilities if:
Crushing facility is controlled by the generator or if both generating and crushing facility are controlled by the same person as defined in the regulations
“Control” means power to direct the policies of the facility by ownership of stocks, voting rights, or otherwise
Must provide certification along with notification

15. Written Procedures Must be developed, implemented and documented
How to safely crush, handle & store lamps & minimize releases
Must include:
Type of equipment to be used
Instructions for proper O&M and schedule
Proper waste management practices
Use of personal protective equipment

16. Secondary Filtration
Secondary HVAC, with filtration before discharge to ambient air, is required for area where lamp crushing occurs
Minimum recommended equipment standards for the filtration system include a HEPA filter, sorption column of sulfur impregnated activated carbon and negative pressure
Alternate designs which discharge to primary HVAC may be approved if:
Filtration system is capable of capturing both particulate and mercury vapor emissions
The filtration system is maintained according to manufacturer recommendations
Maintenance records for the filtration system are maintained at the facility

17. Sampling and Monitoring Requirements
Generators who crush more than 2 hours or more than 100 kg per month are required to monitor for mercury emissions
Sample within 30 days of initial crushing operating, after any modification to crusher, and annually thereafter
Exhaust air from the crushing unit to be sampled whenever modification or replacement occurs within 2 inches of testing ports
Ambient air to be sampled no more than 5 feet from crushing unit

18. Testing Requirements & Limits
Sampling to be performed using OSHA or DEQ approved vapor analyzer
Exposure limits for sampling are based duration:
Facilities may demonstrate compliance with acute exposure limit by comparing 95% upper confidence limit of the mean to the standard
Units which fail testing must be removed from service immediately
*Monthly crushing duration is determined based on the maximum number of hours that bulb crushing occurred in any one month over the last 12 month period.
Monthly Bulb Crushing Duration (Hours/Month)*
Chronic Exposure Air Emission Limit mg/m3)
Acute Exposure Air Emission Limit (mg/m3)
X > 32
1.314skin µg/m3
300 µg/m3
8 < X < 32
6.317 skin µg/m3
300 µg /m3
X < 8
skin µg/m3

19. Exemption from Monitoring
Looked at the equivalent number of bulbs that would equate to 220 lbs. or the monthly generation cut-off amount for a CESQG
For perspective, the following amount of lamps weigh approx. 220 lbs or 100 kg according to industry sources:
• 360 4’ T12 lamps
• 540 4’ T8 lamps
• 910 4’ T5 lamps
Anyone crushing (on the site of generation only) less than 2 hours per month and less than 100kg/220 lbs a month would be exempt from the requirement to conduct air monitoring
Still subject to all other applicable requirements (i.e., notification, equipment O&M, training, recordkeeping, etc.)

20. Training
Initial and subsequent annual training are required to be developed and implemented
Training shall include proper crushing procedures, waste handling, use of PPE and emergency response protocols
Specific training for cleaning up broken bulbs to be included in the training plans

21. Closure & Recordkeeping Requirements
Financial assurance and closure plans required for Large Quantity Handlers (5000 kg or more handled at any time of lamps only)
Maintain records of the following:
Monitoring
Maintenance
Amount of time spent crushing lamps
Training
Procedures
Notifications and certifications
Maintain all records on-site for 3 years

22. Summary of Destination Facility Requirements
Additional requirements for destination facilities that recycle:
Established markets
Process only lamps the device has been designed to process
Testing & analysis of processed materials; comply with mercury limits
Operating requirements
Air monitoring & compliance with risk-based protectiveness standards
Closure plan and financial assurance
Recordkeeping
May require TSDF permit

23. Information Resources
DEQ UW Web Page
DEQ UW Lamp Crushing Guidance – includes checklist
DEQ UW Lamp Crushing FAQ
DEQ UW Regulations

24. Contacts for Further Questions
Ashby Scott –
Lisa Ellis –
Leslie Romanchik -
DEQ Regional Offices – Waste Permitting and Compliance/Solid and Hazardous Waste -

25. Questions