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Presentations May 23 – 25, 2005 Portland, Maine PowerPoint PPT Presentation


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Presentations May 23 – 25, 2005 Portland, Maine For related information visit: http://www.newmoa.org/prevention/mercury/conferences. Ray Graczyk’s Presentation

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Presentations May 23 – 25, 2005 Portland, Maine

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Presentations

May 23 – 25, 2005

Portland, Maine

For related information visit:

http://www.newmoa.org/prevention/mercury/conferences


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Ray Graczyk’s Presentation

Is Separate From The Three Of These.


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NEWMOA Lamp Recycling Outreach Project

Achieving Mercury Reduction in Products & Waste: Coordinating National & Local Government Initiatives

Portland, Maine

May 24, 2005


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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


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NEWMOA Outreach Program

  • Lamp Recycling Workgroup

  • Estimate baseline recycling rate

  • Electrical distributor outreach: Make recycling more convenient

  • Property Manager outreach: Motivate to increase recycling


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Why Distributors?

  • Important link

  • Convenient, one-stop shopping arrangement for lamp purchasing and spent lamp management

  • Potential business opportunity


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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


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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)


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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


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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


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Distributor Meeting Results

  • Reverse distribution set up at 29 branches of 7 different companies

  • Grainger and Graybar reported expansion of their recycling services


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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


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Property Manager Outreach

  • Anecdotal evidence of minimal compliance

  • Potential to reach many lamp users

  • Social Marketing Approach: Identify barriers and potential incentives


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Lamp Workgroup’s Assessment of Barriers to Recycling

  • Perceived lack of convenience

  • Cost

  • Lack of enforcement

  • Poor awareness


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Social Marketing Research

Focused on Understanding:

  • How/where property managers get information

  • How lamp management decisions are made

  • Communications with tenants

  • Budget process


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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


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For more information

Meg Wilcox

[email protected]

617-367-8558 X305


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Presentations

May 23 – 25, 2005

Portland, Maine


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Influences for Change

Promoting Lamp Recycling Among Commercial Property Managers

Portland, Maine

May 24, 2005


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Interviews

  • 10-20 Minute Phone Interviews

  • 11 Property Managers at 9 Different Massachusetts Firms

    • Very Small (38,000 - 400,000 sq. ft.)

    • Medium (8 - 9 million sq. ft.)

    • Very Large (44 - 124 million sq. ft.)

  • Office, Mixed Office/Retail, Upscale Shopping Mall


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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


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Lamp Replacement

  • Retail:

    • Generally Responsible for In-Store Lamp Replacement, but Some Hire Property Management Firm to Carry Out this Task


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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


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Information Sources

  • Very Small:

    • Community Associations Institute

    • Letters from State and Local Government


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Information Sources

  • Larger:

    • BOMA, NAIOP

    • Internal Training (v. large firms)

    • Waste Removal Vendors

    • State and Local Government

    • Consultants

    • Daily Email Updates

    • Boston Business Journal

    • BOMA newsletters


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Information Sources

  • Large Retail:

    • International Council of Shopping Centers

    • International Retail Federation

    • “Shopping Centers Today” (ICSC)

    • “Chain Store Age”


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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


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Presentations

May 23 – 25, 2005

Portland, Maine


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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


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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.


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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.


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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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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.


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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 600-800 lamps will fit in a 55 gallon drum when crushed.


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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.


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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 260.10 and 64 FR 36477-78, 7/6/99.


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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 262.34 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.


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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


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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).


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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., 53:143-151, 2003.

  • 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.


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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


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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.


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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.


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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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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 2003.

  • The draft report is currently being peer reviewed, and will be released after EPA addresses peer review comments.


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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


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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.


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Minnesota Dept. Health/ATSDR

  • A limited study of drum top lamp crusher emissions, conducted by the Minnesota Dept. of Health, was released December 1, 2003.

  • 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.


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Minnesota Dept. Health/ATSDR

  • Mercury levels at the exhaust port;

    • Range: 0.022-0.052 mg/M3 (N=5).

  • Mercury at breathing height range:

    • 0.020-0.049 mg/M3 (N=4; door closed), and

    • 0.0026-0.020 mg/M3 (N=3; door open).

  • The OSHA PEL is 0.1 mg/M3 (ceiling)

  • The ACGIH TLV is 0.025 mg/M3

  • The EPA RfC is 0.0003 mg/M3 (chronic exp.)


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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.


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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.


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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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