Air Cycle understands that you may have questions about the regulations concerning waste disposal. We are frequently asked many questions. Listed below are some of the more common questions. Please click on the link to read the answer.

Please contact us today to learn more about the regulations and how we can help.

• Why is mercury an environmental concern?
• How do I know if my waste is hazardous?
• What’s Hazardous?
• What are Universal Wastes?
• Does Quantity Matter?
• How is controlled crushing regulated?
• How do I get more information on these regulations?

Why is mercury an environmental concern?

Mercury is a metallic element that can accumulate in living tissue. In sufficient concentrations, mercury may cause adverse health effects. Sources of mercury in the environment from human activity include coal-burning power plants, batteries, and fluorescent and HID lamps.

Small amounts of mercury are a necessary component in fluorescent and HID lamps, but when a lamp is broken, crushed, or dispensed in a landfill or incinerator, mercury may be released to the air, surface water, or groundwater. Considering this, it is a good policy to keep the mercury in fluorescent and HID lamps out of the solid waste stream by recycling.

How do I know if my waste is hazardous?

All generators of waste, except households, are responsible for determining if their waste is hazardous under current state and federal regulations. Hazardous wastes can either be included on specific lists or exhibit hazardous characteristics. This determination can be done by knowledge of the waste or by testing the waste. The Toxicity Characteristic Leaching Procedure (TCLP) is the test used to determine if a waste exhibits a toxicity characteristic. Wastes found to be hazardous are subject to the hazardous waste management regulations.

What’s Hazardous?

Persons who generate wastes are responsible for determining whether their wastes are hazardous. One common method for determining whether a waste is hazardous is the Toxicity Characteristic Leaching Procedure (TCLP) test. The TCLP test is a laboratory test that simulates the potential leaching of hazardous wastes under conditions typically found in municipal solid waste landfills. If the concentration of mercury in water that is passed through a sample of crushed fluorescent lamp fragments exceeds 0.2 mg/liter, the crushed lamp fragments are classified as a hazardous waste. (See test method 1311 in "Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods," EPA Publication SW846 for more information about the TCLP procedures.)

In most cases, standard fluorescent lamps and lamp fragments fail the TCLP test and are considered hazardous wastes. Facilities should treat the spent lamps and lamp fragments as hazardous wastes unless they test the spent lamps and fragments and determine that the wastes are non-hazardous. Facilities should manage the spent lamps as hazardous waste according to applicable federal, state, and local requirements.

New low-mercury lamps have been introduced into the market. While these lamps may pass the TCLP test and be considered non-hazardous, some states - like Minnesota and Vermont - still prohibit persons from disposing of even these non-hazardous lamps in a solid waste landfill. You may want to talk with a State EPA representative to find out how you may handle spent lamps in your state.

Please note that regardless of whether the State in which you are located allows you to dispose of lamps in your dumpster with other non-hazardous trash, the lamps do contain mercury and mercury vapors are released into our environment when you throw lamps in the trash. Typically, the lamps break in the dumpsters, during transportation or in the landfill and release mercury into the air or groundwater. These hazardous releases are a risk to surrounding communities.

Facilities that throw their spent lamps in the trash thinking they are saving money may be mistaken. Throwing spent lamps in the trash may result in the person being held responsible for the cleanup of a remote and costly Superfund site. Because of the potential liability under Superfund, Air Cycle Corporation believes facilities that decide to recycle their spent lamps are making a smart decision that benefits not only the environment but also the bottom line.

What are Universal Wastes?

Universal wastes are specific hazardous waste streams that facilities can choose to manage in an alternative manner in place of the more complex hazardous waste requirements. These wastes are typically generated by many facilites and are often not properly managed under hazardous waste regulations.

Universal Wastes include:

Lamps – Including fluorescent, high intensity discharge (HID), sodium vapor, mercury vapor, neon, and incandescent lamps Batteries – Including spent dry cell and lead-acid batteries Pesticides – Including certain suspended, canceled, or unused pesticides Devices containing elemental mercury – Including thermostats, switches, thermometers, manometers, barometers, and various medical devices

Does Quantity Matter?

Yes. RCRA (hazardous waste) requirements differ according to the amounts of hazardous waste generated per month by the facility. There are three main categories of hazardous waste generators:

Conditionally Exempt Small Quantity Generators (CESQG's) are persons who generate 220 lbs. or less of all hazardous wastes combined (not just lamps!). These generators are exempt from most of the hazardous waste regulations, which include transportation, treatment, and disposal requirements. They must not, however, store more than 2200 lbs. of hazardous waste on site at any time and must dispose of their hazardous waste in facilities that are permitted or authorized to accept hazardous or non-hazardous wastes. Many states acknowledge CESQG exemptions for paperwork, but not for disposal. Many states do not allow CESQG to dispose of hazardous waste in a solid waste landfill.

Small Quantity Generators (SQG) are persons who generate 220 to 2200 lbs. of hazardous waste per month. These generators must keep proper records of the waste, report to EPA, and follow accumulation requirements. These generators can store up to 6 months without a storage permit.

Large Quantity Generators (LQG) generate more than 2200 lbs. of hazardous waste per month. These generators are subject to the full hazardous waste management requirements. These generators cannot store hazardous wastes on site for more than 90 days (3 months) without obtaining a storage permit.

There are 2 categories of Universal Waste handlers:

1. Small Quantity Handler - Generator who accumulates less than 11,000 lbs. of universal waste (batteries, pesticides, thermostats, or lamps) at any time.
2. Large Quantity Handler - Generator who accumulates more than 11,000 lbs. of universal waste (batteries, pesticides, thermostats, or lamps) at any time.

Universal Waste Storage Limits:

Both Small and Large Quantity Generators of Universal Waste can generally store their Universal Waste for one year. (For more information please contact your state Environmental Protection Agency or Air Cycle Corporation.)

How is controlled crushing regulated?

Controlled crushing of lamps is regulated under both federal and state hazardous and universal waste regulations. The federal universal waste regulations do not authorize on-site crushing of fluorescent lamps but do allow the States to write rules that will permit crushing on-site. The States of Illinois, Florida, Virginia, Tennessee, Texas, Colorado, Maryland and Montana have all passed rules that allow persons to crush lamps on-site under the universal waste regulations. Air Cycle Corporation is working with several States and expects these States to pass rules within the next year, which allow lamp crushing under universal waste rules.

In States that allow crushing and classify crushed lamps as universal wastes, persons can generally store their waste lamps on-site for up to one year, can ship waste lamps off-site with a bill of lading rather than a hazardous waste manifest, and need not include their lamps when calculating their hazardous waste totals.

Under state and federal hazardous waste regulations, controlled crushing (which is what the Bulb Eater™ systems do) is considered treatment. The hazardous waste rules typically require a person who treats wastes to obtain a permit. Federal and most state hazardous waste rules, however, exempt from the permit requirement persons who treat their wastes "within a drum, tank, or container." (See 40 CFR 262.34).

Air Cycle Corporation believes The Bulb Eater™ systems fall squarely within this exemption and many States have acknowledged in letters to Air Cycle Corporation that the accumulation tank exemption applies to The Bulb Eater™ systems. You should be aware, however, that the States of California, Maine, Massachusetts, Connecticut, Rhode Island and Missouri have more narrow exemptions to the permitting requirements. Air Cycle Corporation suggests you contact representatives of those States before proceeding with on-site crushing.

If your State does not allow crushing under its universal waste regulations, then you typically may manage crushing under your state's hazardous waste regulations as a process exempt from the general permitting requirements. Please note that regardless of whether the lamps are managed as universal or hazardous wastes, you must properly dispose of the crushed lamps preferably by shipping the crushed lamps to a permitted recycling facility.

Air Cycle Corporation will continue to work with State lawmakers, the National Electrical Manufacturing Association and the Association of Lighting and Mercury Recyclers to promote legislation, which will authorize persons to crush lamps under universal waste regulations. Air Cycle Corporation and its customers know that persons are able to safely crush their lamps to reduce volume, minimize handling, cut costs, and create a safer work environment by managing their crushed lamps under either universal waste regulations or existing state hazardous waste regulations.

How do I get more information on these regulations?

Customers are always welcome to contact customer service at Air Cycle Corporation for further information concerning federal and state regulations. Air Cycle has a database of contact names at both federal and state environmental protection agencies, as well as guidance papers from many states that are available to our customers. We are more than willing to help you learn more about applicable regulations.