Presentations May 23 – 25, 2005

1. Presentations May 23 – 25, 2005 Portland, Maine For related information visit: http://www.newmoa.org/prevention/mercury/conferences

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 mwilcox@newmoa.org 617-367-8558 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

20. 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

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

22. Lamp Replacement • 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

24. Information Sources • 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 Email 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”

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

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?

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 600-800 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 260.10 and 64 FR 36477-78, 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 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.

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., 53:143-151, 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.

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.

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 2003. • 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