United States       Office of Air Quality        EPA-453/R-94-018
Environmental Protection  Planning and Standards       February 1994
Agency          Research Triangle Park NC 27711

Air
EVALUATION OF MERCURY

EMISSIONS  FROM FLUORESCENT

LAMP CRUSHING
control
technology center

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                                   EPA-453/R-94-018
      EVALUATION  OF MERCURY
  EMISSIONS  FROM FLUORESCENT
           LAMP  CRUSHING
   CONTROL  TECHNOLOGY CENTER
              Sponsored by

        Emission  Standards  Division
Office of Air Quality Planning and Standards
    U.S. Environmental Protection Agency
     Research Triangle Park, NC  27711
   Air and Energy Engineering Laboratory
    Office of Research and Development
   U.S. Environmental Protection Agency
     Research Triangle Park, NC  27711
              February 1994
                      U.S. i-      ' . ,-'• ;••>-,u-, Agency
                      Regi:o ,       -,•-)

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                              EPA-453/R-94-018

                              February  1994
    EVALUATION OF MERCURY
EMISSIONS  FROM  FLUORESCENT
          LAMP  CRUSHING
              Prepared by

            William Battye
             Una McGeough
            Calvin Overcash
           EC/R Incorporated
       3101 Petty Road, Suite 404
           Durham, NC   27707
      EPA Contract No.  68-D1-0119
       Work Assignment  No. 1/026
           Project Manager

          Robert J. Blaszczak
      Emission Standards Division
  U.S. Environmental Protection Agency
   Research Triangle Park, NC  27711
            Prepared for

       Control Technology Center
  U.S. Environmental Protection Agency
   Research Triangle Park, NC  27711

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                            DISCLAIMER
     This report has been reviewed by the Control Technology
Center (CTC) established by the Office of Research and
Development (ORD) and the Office of Air Quality Planning and
Standards (OAQPS) of the U.S. Environmental Protection Agency
(EPA) ,  and has been approved for publication.  Approval does riot
signify that the comments necessarily reflect the views and
policies of the EPA, nor does mention of trade names,
organization names,  or commercial products constitute endorsement
or recommendation for use.
                               11

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                              PREFACE
      This project was  funded  by  EPA's  Control  Technology Center
 (CTC)  and prepared by  EC/R  Incorporated.   The  CTC  was  established
 by  EPA's Office of Research and  Development  (ORD)  and  Office  of
 Air Quality Planning and Standards  (OAQPS) to  provide  technical
 assistance to State and local air pollution  control  agencies.
 Several levels of assistance  are provided  by the CTC.   First,  a
 CTC HOTLINE is available to provide telephone  assistance on
 matters relating to air pollution control  technologies.   Second,
 more  in-depth engineering assistance is provided when
 appropriate.  Third, the CTC  can provide technical guidance by
 designing technical guidance documents, developing personal
 computer software, and presenting workshops  on technology
 matters.  The CTC also serves as the focal point for the Federal
 Small  Business Assistance Program, maintains the Reasonably
 Available Control Technology/Best Available  Control
 Technology/Lowest Achievable Emission Rate (RACT/BACT/LAER)
 Clearinghouse, and provides access to the Global Greenhouse Gases
 Technology Transfer Center.  Information concerning all  CTC
 products and services can be accessed through  the CTC  Bulletin
 Board  System (BBS) which is part of the OAQPS  Technology Transfer
 Network (TTN).
     This report is the result of a request  for technical
 assistance from the Florida Department of Environmental
 Protection.   Florida was concerned about potential mercury
 emissions and control options for a proposed facility  that would
 crush fluorescent lamps for recycling.   This report presents an
 evaluation of mercury emissions  from the crushing of fluorescent
 light bulbs.   Background information on mercury-containing
 fluorescent lamps and their disposal is also presented.  _These
 light bulbs are crushed as the first step in recovery  of mercury,
or disposal of the bulbs in a landfill  or incinerator.    Three
                               iii

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different crushing systems are described in detail, and
variations on these systems are also discussed.   The report
describes the air pollution controls on each system, and
emissions of mercury from the crushing process are estimated.
This information provides the basis for evaluating the potential
for mercury emissions from the crushing of fluorescent light
bulbs,  and the efficacy of available air pollution controls in
limiting these emissions.
                               IV

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                         TABLE  OF  CONTENTS

Section                                                       Page

PREFACE	iii

1.0  INTRODUCTION  	    1
     1. 1  PROJECT  GOAL	    1
     1.2  OVERVIEW OF DOCUMENT 	    1

2.0  BACKGROUND INFORMATION ON FLUORESCENT LAMPS   	    2
     2. 1  LAMP USAGE	    2
     2.2  DESCRIPTION OF FLUORESCENT LAMPS   	    2
     2.3  DISPOSAL OF LAMPS	    4
     2.4  MERCURY_EMISSIONS 	    7

3.0  LAMP CRUSHING PROCESSES   	    8
     3.1  BASIC CRUSHING SYSTEM 	    9
          3.1.1     Crusher Design  	    9
          3.1.2     Air Pollution Controls   	    9
          3.1.3     Emission Points and Estimates  	  10
     3.2  MRS CRUSHING SYSTEM	12
          3.2.1     Crusher Design	12
          3.2.2     Air Pollution Controls	13
          3.2.3     Emission Points and Estimates  	  15
     3.3  MERCURY TECHNOLOGIES CRUSHING SYSTEM  	  16
          3.3.1     Crusher Design	16
          3.3.2     Air Pollution Controls	17
          3.3.3     Emission Points and Estimates  	  17
     3.4  OTHER VARIATIONS  	  18
          3.4.1     Transfer Operations 	  19
          3.4.2     Removal of Endcaps	19
          3.4.3     MRT AB Mercury Recovery Systems	20

4.0  MERCURY RECOVERY 	  20

5.0  DISCUSSION AND CONCLUSIONS 	  21

6.0  REFERENCES	24

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                          LIST OF TABLES

Table                                                        Page

1.   Elemental Analysis of Used Fluorescent Lamp Powder. ...  3

2.   Mercury Content of Used Fluorescent Lamps 	  5

3.   Mercury Content of New Fluorescent Lamps	6

4.   Airborne Mercury Levels Associated with Fluorescent
     Lamp Compaction Unit	11

5.   Comparison of Calculated and  Measured Emissions from
     Different Crushing Systems	23
                               VI

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 1.0   INTRODUCTION

 1.1   PROJECT GOAL

      This  project is  sponsored  by  the  Control  Technology  Center
 (CTC)  of the U.S.  Environmental Protection Agency  (EPA),  Research
 Triangle Park,  North  Carolina.   The purpose  of this  project  is to
 evaluate the processing  of  spent fluorescent lamps,  and
 technology for  the control  of mercury  emissions from this
 process.   The procedure  involves crushing fluorescent light
 lamps, which results  in  mercury emissions, either  in liquid  or
 vapor  form.   The  lamps are  crushed as  the first step in
 reprocessing.   Subsequent to crushing, the broken  lamps are
 either landfilled,  incinerated,  or recovered.   This  study
 addresses  emissions from the crushing  of fluorescent lamps and
 the initial  handling  of  the resulting  crushed  material.   The
 study does not  cover  subsequent mercury recovery and refining
 operations.

 1.2  OVERVIEW OF  DOCUMENT

     This  document provides brief  background information  on the
 use and disposal  of fluorescent  lamp tubes.  The major emphasis
 of the document is on the lamp  crushing process  and  associated
 mercury emission  control devices.  Three different crushing
 processes  are discussed, as well as the air pollution controls in
 practice,  and the resulting air  emissions.  This provides the
 basis for  an  evaluation  of  the  effectiveness of  various crushing
methods and the efficacy of different air pollution  controls.
 Some relevant variations on these crushing processes are  also
described,  along with their potential for emissions.  This
document does not address the retorting of mercury-containing
material for the recovery and recycling of elemental mercury, or
the disposal of mercury-containing wastes, resulting from
crushing operations, in  landfills.   However,  these operations are

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mentioned  incidentally throughout the document, as they  are
closely associated with crushing operations.

2.0  BACKGROUND INFORMATION ON FLUORESCENT LAMPS

2.1  LAMP  USAGE

     Fluorescent lamps are widely used in businesses, as they
provide an energy-efficient source of lighting.  The commercial
and industrial sectors dominate usage of fluorescent lamps,
accounting for over 90 percent of total usage.1  Approximately
five hundred million lamps were manufactured in 1991.:   It is
possible that this number will increase substantially, as the EPA
promotes the use of fluorescent lighting as part of its Green
Lights program, which is designed to reduce energy consumption.
Each lamp  has a lifetime of three to four years under normal use.
Fluorescent lights are designed so that approximately half of
them will  operate after 20,000 hours of operation.1   Where these
lamps are  being used on a small scale, they are generally
replaced as they burn out, one at a time.  However,  in large
companies  and industries,  this method is not practicable, and,
therefore,  group relamping is done on a regular basis.
Typically,  group relamping is performed at 15,000 hours, or 75
percent of the lamp's rated life.1   This  translates to
replacement every two years for continuous operations,  and every
three to five years for noncontinuous operations, which are much
more common.   Approximately 20 percent of all lamps are currently
replaced annually.1  Group relamping operations generate large
quantities of lamps to be disposed of at a single time.

2.2   DESCRIPTION OF FLUORESCENT LAMPS

     A typical fluorescent lamp is composed of a sealed glass
tube filled with argon gas at a low pressure (2.5 Torr), as well
as a low partial pressure of mercury vapor,  thus the tube is a

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partial vacuum.1'2  The inside of the tube is coated with a powder
composed of various phosphor compounds.  The composition of this
powder is shown in Table I.1  Tungsten coils,  coated with an
electron emitting substance, form electrodes at either end of the
tube.  When a voltage is applied, electrons pass from one
electrode to the other.  These electrons pass through the tube,
striking argon atoms, which in turn emit more electrons.  The
electrons strike mercury vapor atoms and energize the mercury

  Table l:  Elemental Analysis of Used Fluorescent Lamp Powder1
Element
Aluminum
Antimony
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Zinc
Concentration
(mg element/kg phosphor
powder)
3,000
2,300
610
1,000
170,000
9
2
70
1,900
75
1,000
4,400
4,700
130
140
1,700
48

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vapor,  causing  it  to  emit ultraviolet radiation.  As  this
ultraviolet  light  strikes the phosphor coating  on the tube,  it
causes  the phosphor to  fluoresce, thereby producing visible
light.  Thus, the  mercury in these lamps is critical  to  the
production of light.  The life of the lamp is determined by  the
life of the  electron  producing coating on the cathode, which
diminishes as the  lamp  is operated.2   The most commonly used
fluorescent  lamp is the 40 watt, 4 foot long tube, although
smaller, larger and differently shaped lamps are also used.1
     The amount of mercury in fluorescent lamps varies
considerably with  manufacturer, and even possibly within
manufacturers.2   Tables 2  and 3  show  the  mercury content of used
and new fluorescent lamps made by various manufacturers.  These
results are  from a study conducted by Science Applications
International Corporation for the EPA.2   The  National  Electric
Manufacturers Association (NEMA) estimates that in 1990, the
average fluorescent lamp contained 41 mg of mercury per  lamp.
NEMA predicts that this will decrease to 27 rag by 1995.1

2.3  DISPOSAL OF LAMPS

     In a study report prepared for EPA Office of Solid Waste  by
Research Triangle  Institute (RTI)  entitled "Management of Used
Fluorescent Lamps:  Preliminary Risk Assessment," it is estimated
that approximately 600 million lamps  are disposed each year.
Currently,  the largest fraction of lamps are disposed  in the
waste stream; 82 percent of lamps are landfilled,  16 percent are
incinerated,  and only 2 percent are recycled.1   RTI  estimates,
based upon Department of Commerce data and industry information,
that the total amount of mercury entering the U.S.  municipal
solid waste system annually (1989)  is 643 Mg.1   The  contribution
from fluorescent lamps is  approximately 24.4  Mg, or 3.8 percent.1
     The amount.of mercury emitted from a spent lamp depends on

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       Table 2:  Mercury Content of Used Fluorescent Lamps2
            Manufacturer
Mercury Concentration
 (mg  of  mercury/lamp)
   Westinghouse
   Westinghouse
   Westinghouse
   Westinghouse
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   Dayton
   Phillips
   General Telephone & Electric
   Minimum
   Maximum
   Average
   Standard Deviation
         21.0
         16.6
         17.2
         61.5
         24.4
         23.1
         0.72
         36. 1
        115.0
         27.2
         22.5
         17.5
         48.0
         0.72
        115.0
        33 . 14
        28.91
the way the lamp is handled after it is changed.  Discarded lamps
may be transported in two ways: in garbage trucks as household or
commercial trash, or in closed vans or trailers as part of a bulk
relamping program.  In the former case, used lamps are simply
disposed in a dumpster, which is then transported to the landfill
by a garbage truck.  It is assumed that all of the lamps in
garbage trucks are broken and that vaporized mercury in these
trucks finds its way to the atmosphere.1   In  the case  of  bulk
relamping programs, the discarded lamps are packed in corrugated
containers from which the new lamps were taken and are then

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        Table 3:   Mercury  Content  of  New  Fluorescent  Lamps'
           Manufacturer
  Mercury Content
(mg of mercury/lamp)
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   General Electric
   Minimum
   Maximum
   Average
   Standard Deviation
        35.8
        40.2
        29.3
        33.0
        18.8
        15.1
        14.3
        15.7
        19.1
        20.5
        44.8
        15.7
        14.3
        44 .8
       25. 19
       10.87
loaded into enclosed vans or trailers for removal to a landfill.
In this case, it is assumed that few lamps are broken and
practically all of the mercury is retained in the landfill.1
     In any case, recovery of the mercury in lamps appears to be
desirable, in that the net amount of mercury ultimately released
to the environment is reduced.  The recovery process begins with .
the crushing of lamps to extract the white phosphor powder, which
contains the bulk of the mercury.  This powder is then put into a
mercury retort to recover elemental mercury.
     There are presently few mercury recycling facilities in the
country.  Most facilities are located in California or Minnesota.
The State of Minnesota is now enforcing a requirement passed, by

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 the  Minnesota Pollution Control Agency (MPCA)  on May 8,  1992 that
 declares  used fluorescent and high intensity discharge lamps with
 specified levels of mercury are hazardous waste,  and as  such must
 not  be  landfilled if a recycling option is available.3  The  State
 of Minnesota  is  also requiring that businesses store their spent
 lamps until such a facility is available to them.3  This has
 provided  a substantial impetus to development of recycling and
 recovery  operations in Minnesota.3

 2.4  MERCURY  EMISSIONS

     The  disposal of mercury-containing fluorescent  lamps  and the
 potential for emissions therefrom is  of concern because mercury
 is a highly toxic heavy metal,  which  bioaccumulates  through  the
 food chain.1  Mercury also has a vapor pressure of 2X1CT3 mm
 (25°C)  and is volatile at room temperature.  Emissions of mercury
 in liquid or  vapor form,  therefore, need to be considered.   The
 volatilization pathway is especially  significant  with respect to
 human health  concerns,  as it  results  in ambient concentrations of
 mercury that  can be absorbed  through  various pathways.1  These
 include direct inhalation,  or ingestion through the  consumption
 of contaminated  food products,  particularly fish. Estimates  on
 global and national mercury emission  vary widely.
     EPA's estimates of  U.S.  anthropogenic  mercury emissions  are
 somewhat  incomplete,  but indicate  levels  around 309 Mg/yr.4
 Coal-fired power plants,  municipal  solid  waste  combustors  and
 industrial sources  account  for  110  Mg,  58 Mg,  and 32  Mg per year,
 respectively  (note  that  this  is a worst-case estimate for  coal-
 fired power plants;  i.e., all mercury in  the coal is  emitted).4
 Based upon air emission  and mass balance  information  received
 from the MRT AB  mercury  recovery system,  RTI estimates that only
 0.005 Mg of mercury  are  emitted each year from  all recycling
 plants combined.1  This number may have increased somewhat,
 because there are more recycling plants operating now than there
were at the time  of  the  study.

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 3.0   LAMP  CRUSHING  PROCESSES

      The crushing of  fluorescent lamps to  separate the  glass  from
 the phosphor powder in the  lamp is commonly the  first step  in
 recycling  of mercury; although some companies use other methods,
 such  as removal of  the phosphor powder by  air vortex or by
 flushing with hydrochloric  acid.1   Although separation of the
 phosphor powder and, hence, the mercury, from the glass and metal
 endcaps is necessary for recycling and recovery  of mercury, it  is
 not done only to facilitate this process.  Crushing of  mercury-
 containing fluorescent lamps is also done  in order to reduce  the
 volume of the lamps being disposed in landfills.
      In this section, several different systems  used for the
 crushing of fluorescent lamps are described.  Information was
 gathered from RTI's "Management of Used Fluorescent Lamps:  A
 Preliminary Risk Assessment,"1  and  through conversations with
 different individuals involved in the processing of fluorescent
 lamps.  These individuals were from both recycling companies''6'7'8
 and State agencies.3'9
     Three different crushing systems are described in  detail in
 the following sections.   These are: (i)  the basic crushing
 system; (ii)  the MRS crushing system; and  (iii)  the Mercury
 Technologies crushing system.   The basic system used to  crush the
 fluorescent lamps is quite similar in many cases, and is a
 relatively simple process.   Most of the differences between
 crushing systems reside in the air pollution controls they have
 in place to control mercury emissions from the crushing process.
Thus,  in the discussion of each system,  particular attention  will
be paid to the controls in place,  and,  where data are available,  •
the efficacy of those controls in  reducing or eliminating mercury
emissions into the environment.

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 3.1  BASIC CRUSHING SYSTEM

 3.1.1     Crusher Design

      The simplest of crushers  is  essentially a single unit,  with
 a  crusher mounted on top of  a  barrel,  usually a 55-gallon drum.
 This  system is  used in  many  industrial facilities to crush their
 fluorescent lamps as a  means to reduce the solid waste volume
 before  disposing  the material  in  a  landfill.10  In this version,
 light lamps are hand-fed to  a  feeder chute of variable length and
 diameter.   This chute is not necessarily  longer than the lamps
 being fed into  it.   The lamps  pass  to  the crushing unit,
 typically consisting of motor-driven blades,  which implode and
 crush the lamps.   From  here, the  crushed  powder drops into the
 barrel  below the  crusher.

 3.1.2      Air Pollution Controls

      In the simplest of these  systems,  there  are no air pollution
 controls  on the device.10  The  crushed  lamps are collected in
 drums until they  are full, and then the full  drums  are
 transported to  one  of several  facilities.   The  crushed material
 may then  be separated into glass, metal,  and  powder components.
 Typically,  the  untreated powder is then deposited in a landfill.
 This  is currently the most common method  of disposing these
 lamps.1   Alternatively,  the barrels  may be transported to a
 mercury recovery facility, which will  separate  the  mercury-
 containing  phosphor  powder from the crushed glass and aluminum
 endcaps, and recycle all the materials.
     A more  sophisticated version of this barrel-mounted  crusher
utilizes a  negative  air exhaust system  to draw  the  crushed debris
 and prevent  it  from  reemerging through  the  feeder tube.11   The
drawn air is then passed through a High Efficiency  Particulate
Air (HEPA)  filter to remove particulate matter  from  the exhausted

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 air  flow.  The  crushed material  is then disposed  in one  of  the
 manners discussed  above.

 3.1.3     Emission Points and Estimates

     In the simplified crushing  systems discussed above, there
 are  several emission points.10  The feeder tube  itself  is a
 potential emission point.  The length of this tube, as well as
 the  length of the  lamps being crushed, affects the magnitude of
 emissions from  the feeder tube.  Additionally, the juncture
 between the crushing unit and the receiving barrel below is a
 possible emission  point, depending on how well the connection is
 sealed.  Finally,  an emission point of concern is the collection
 barrel itself.  Whenever this barrel is removed from the crushing
 unit for disposal  at another facility, the open area of  the
 barrel constitutes a potential emission point.  All these points
 are relevant when  there are no air pollution controls in place.
 In the modified case, where negative air is employed,  emissions
 through the feeder tube may be reduced or eliminated entirely,
 depending upon the strength of the air flow.
     In many cases, actual emission estimates have not been
 determined;  rather, occupational exposure estimates have been
 derived from ambient air measurements taken in the workplace.10
 For the case of the simplified system discussed above,  Kirschner,
 et. al.,  conducted a workplace study of mercury emissions from a
 similar fluorescent lamp compaction unit.   In this case,  the
compaction was performed to reduce volume prior to landfilling.
This unit consisted of a crusher mounted on top of a 30  gallon
drum, with a feeder tube of an unspecified length.  When the
study was undertaken, no air pollution controls were in place on
this device.   The scientists observed significant dust emissions
from the  mouth of the feeder tube,  and the juncture between the
crusher and  the collection drum.   Indoor ambient air monitoring
revealed  ambient mercury levels  that  varied widely with different
lamp inputs  (possibly due to manufacturer variability).
                               10

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Nonetheless, the measurements  indicated  levels  of mercury near
to, as well as above the Occupational  Safety  and Health
Administration (OSHA)  limits of  0.05 mg/m3.10'12  Results of this
study are shown in Table 4.  During the  test, 300 lamps were
crushed in a 20 minute period, yielding  an  average operational
crushing rate of 15 lamps per minute.10  The researchers
concluded that such uncontrolled fluorescent  lamp crushers should
be considered emitters of mercury.10
     Several controls  were put in place  in  the  crusher  to
determine if mercury emissions could be  reduced: 1) gasketing  was
applied to seal the area around  the connection  between  crusher
and drum; 2) the crushing unit was housed entirely within a shed
which allows fluorescent lamps to be fed in from outside; and
3) a 55 gallon disposable barrel was substituted for the
collection barrel.   In the third control, the disposable  barrel
        Table 4:  Airborne Mercury Levels Associated with
            Fluorescent Lamp Compaction Unit  (mg/m3)10

Sample
Distance (ft.)
Background
Trial 1
Trial 1, Time
Area Samples
ABC
5 20 50
0.0002 0.0010 0.0006
0.31 	 	
	 	 	
Personnel
Samples
D E
15 20
	 	
0.54 0.65
0.02 0.03

OSHA
Limit

0.05
0.05
0.05
  Weighted
  Average
  Trial 2
  Trial 2, Time
  Weighted
  Average
3.00     0.09     0.10     2.23    1.82    0.05

	     	     	     0.12    0.10    0.05
                               11

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 became  the  final waste  receptacle.  When filled  it was  disposed
 directly  to the company's  sanitary  landfill, rather  than  being
 emptied into a dumpster, thus eliminating one step in the
 transfer  process,  and reducing employee exposure to  mercury
 emissions.
     Preliminary tests  indicated that all these  measures  were
 useful  in reducing emissions.10  Nonetheless, the authors
 concluded that fluorescent lamp crushing units should be
 considered  emitters of  mercury unless ventilation and adsorbent
 capabilities, such as carbon filters, are added.10
     A  further example  of the problems with uncontrolled  crushing
 devices is  illustrated  in the case  of Quicksilver Products.1
 This company, located in California, briefly entered the  business
 of fluorescent lamp crushing.  Their lamps were  crushed outside
 in a unit mounted  on top of a 55 gallon drum.  An air separation
 system was  used to remove the phosphor powder and mercury from
 the glass.  This facility was closed down for violations  of s;afe
 operating practices.  Extensive contamination was found around
 the facility; high concentrations of mercury were measured in the
 soil, rinse water, and  on a nearby  roof.

 3.2  MRS  CRUSHING  SYSTEM

 3.2.1     Crusher Design

     Mercury Recovery Services (MRS) is a mercury recycling plant
 located in California.   The information about their  crushing
process presented below was provided by the company.7 The
fluorescent lamp crushing apparatus operated by MRS  is more
sophisticated than the basic system described above,  particularly
in terms  of the air pollution controls.   The process currently  in
operation is described in detail here.   However,  the company is
in the process of developing a new design which will be patented,
thus, specific information on the new design is proprietary and
is not included in this report.   MRS did indicate that the new
                               12

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 system will include a self-loading apparatus where lamps will be
 deposited for delivery to the crusher,  and a totally enclosed
 operation to separate the glass,  endcaps,  and phosphor powder
 within the system.
      The current crusher operated by MRS  is a hand fed apparatus
 with two feeder chutes.   One chute is 5 feet long,  to accommodate
 4  foot lamps,  and the other tube  is 9 feet,  in order to
 accommodate 6  to 8  foot lamps.  Each chute is placed at an angle,
 and  has a 9 inch by 12 inch opening,  which can accommodate
 several lamps  at a  time.   The lamps are delivered  down this
 angled tube onto a  motor driven blade made of heavy gauge
 hardened steel rotating at 2700 rotations  per minute.   The
 rotating blades implode and crush the lamps  as they arrive.   The
 crushing unit  has an operating capacity of 62.5 lamps per minute.
      A vacuum  system collects air from  beneath the  crusher,
 preventing mercury  laden air from exiting  through the feed tube.
 Material collected  in the vacuum  system first passes through  a
 cyclone separator.   This  removes  glass  particles, which drop  into
 the  drum.   Air from the  cyclone separator  contains  phosphor
 powder and some mercury  vapor.  These are  removed by further
 controls,  as discussed below.
      At the end of  the process, the glass  and aluminum are sent
 to recyclers.   The  phosphor  powder  is sent to a mercury recovery
 company for retorting and recovery  of the mercury.

 3.2.2      Air  Pollution Controls

     After  passing  through the cyclone, the air is  pulled  through
to a baghouse, where  9 fabric filters trap particulate  matter in
the air  stream.   Every 45 seconds, these fabric filters  are
cleaned with a  reverse pulse  of air.  The air  leaving the
baghouse  is typically composed only of air and mercury  vapor.
This air  and mercury vapor mixture continues  through several more
particulate matter  filters and HEPA filters,  to ensure  that all
particulates have been removed.  From here, the exhaust  is
                               13

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 delivered  to two  250-pound activated carbon beds, which trap  the
 mercury vapor.  These  carbon beds are replaced at saturation,
 typically  after two years.  The airflow is then directed through
 yet more particulate matter filters to trap any carbon that may
 have been  carried along from the activated carbon beds.
     At this point in  the air pollution filter chain, a five  to
 ten horsepower pump exhausts the air flow into a mediator
 (essentially an area where air from the different sources  is
 mixed prior to discharge into the warehouse area).  Air is also
 being pumped from the  containment room through the mediator on a
 continuous basis," and  subsequently to another series of
 particulate filters and more activated carbon.  Therefore, air
 from the crushing unit and the containment room is mixed, after
 filtration, and discharged into the warehouse area.  Thus, in
 addition to cleaning the exhaust air from the crushing unit, the
 system cleans the air  in the containment room six times per hour.
 Air flow through  the filter chain is 25 cubic meters per minute
 (900 cubic feet per minute),  on average.  The entire crushing
 system and filter chain is enclosed within a containment room,
 which is itself within a warehouse.   After all air has passed
 through the entire filter system and been cleaned,  it is pumped
 into the containment room and to the warehouse,  essentially a
 closed loop system.  The only exchange of air with outside
 ambient air would occur incidentally in the warehouse, such as
when doors are open and closed, or at points in the warehouse
that are not airtight.
     The entire process is vacuum sealed and monitored
continuously for  leaks and to ensure that air in the containment
 area is in compliance with OSHA regulations.   In the case of a
 leak,  work ceases until the leak is repaired,  and then resumes.
Effectively,  the only time where levels of mercury in the
workplace may approach the OSHA limit of 0.05 mg/m3,  is when
 lamps have been dropped and broken.7  No efficiencies  of  control
devices are cited; rather,  MRS monitors constantly and bases
                                14

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 their determination of adequacy on measured mercury levels in the
 workplace.

 3.2.3     Emission Points and Estimates

      This  crusher is designed to ensure that there  is  no leakage
 of  air from the system.1  The opening through which the  lamps are
 fed is a potential emission point,  but  strong negative air flow
 pulling on  the  crushing apparatus prevents  emissions from
 resulting.   Additionally,  the negative  air  flow  ensures that  the
 entire filter process is vacuum sealed.  The entire system is
 continuously monitored for leaks.
      No emission estimates are  available for this particular
 process, because the company monitors constantly for compliance
 with  OSHA as its standard and bases their determination of
 control device  adequacy on measured ambient  mercury levels in the
 workplace.   As  noted above,  the MRS crusher  is controlled by  a
 combination  of  fabric filtration and carbon  adsorption.
      To provide a  basis for estimation  of control device
 effectiveness in the fluorescent lamp crushing process,  EC/R
 investigated other industries where carbon adsorbers are used to
 control mercury emissions.   In  the chlor-alkali  industry,  carbon
 adsorbers applied  to mercury vapor streams attain outlet
 concentrations  under 50  parts per billion (ppb), and sometimes  as
 low as  1 ppb.13   Although outlet concentrations have not been
measured for a  lamp  crushing operation,   it is reasonable to
assume that  comparable  concentrations could be attained  if the
carbon adsorption  system  is  well designed and operated.
Therefore,  using outlet concentrations from the chlor-alkali
plants and the  reported airflow  for the MRS unit, mercury
emissions would range from  0.2 to 10 mg per minute.   [According
to Bob Roberts,  president of MRS, monitoring indicates ambient
mercury levels-well  below the OSHA limit of 0.05 mg/m3. ]
                                15

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 3.3  MERCURY TECHNOLOGIES CRUSHING SYSTEM

 3.3.1     Crusher Design

     Mercury Technologies of Minnesota is one of only three
 companies in the United States using this particular technology.6
 The original developer of this technology was Mercury
 Technologies Corporation, a company that operates a mercury
 recycling and recovery facility in Hayward, California.  The
 system is a completely enclosed design that feeds fluorescent.
 lamps in one end" to a crusher, passes the exhaust through an
 extensive filtering system, and delivers the powder to a thermal
 reduction unit  (TRU), which recovers the mercury from the
 phosphor powder.6   Thus,  this  system carries out the entire
 mercury recycling process, from the crushing of fluorescent light
 lamps to the retorting and reclamation of mercury from phosphor
 powder.
     Lamps are hand-fed into feeder tubes of different lengths,
 depending upon the size of the lamps being processed.  If 4-foot
 lamps are being processed, they are fed into a tube that is 5
 feet long, and if 8-foot lamps are being processed,  they are fed
 into a 9 foot feeder tube.  The lamps are fed to the crusher,
which implodes and crushes the lamps into small fragments.  The
 operating capacity of the unit is 60 lamps crushed per minute.
     As with the MRS operation,  the entire process is conducted
under negative airflow.   The crushed debris is exhausted first to
a cyclone, where the larger particles,  such as crushed glass and
aluminum endcaps are separated out.   At this point,  much of the
phosphor powder drops out into a cyclone hopper.  From this
collection hopper,  the phosphor powder,  containing mercury, is
transferred to the TRU via an enclosed auger conveyer,  as
described in the following section.
                                16

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 3.3.2      Air Pollution Controls

     After the cyclone,  the airflow proceeds to a baghouse,  where
 fabric filters continue to remove particulate matter from the
 airstream.   The fabric filters  are cleaned with a reverse pulse
 mechanism,  and the  powder  that  drops out here is also routed to
 the  cyclone hopper.   The air stream leaving the baghouse proceeds
 to a HEPA filter, and then to a potassium iodide-impregnated
 carbon filter.   This  removes the mercury vapor,  by precipitating
 it in  the form of mercuric iodide (no removal efficiencies were
 cited).   The air in the  building that houses the self-contained
 unit is  also under  continual negative air pressure.   Thus, all
 this air is drawn through  the entire filter system as well.
 There  is no exhaust to the outdoors.   Rather,  all air is
 recirculated back into the workplace.  Air flow through  the
 system is approximately  18 cubic meters  per minute (650  cubic
 feet per minute).
     From the cyclone  hopper, the powder,  which consists mainly
 of 6 to  12  /xm particles, is  auger-conveyed to the TRU.   An auger
 conveyor is a tube with  a  6-inch diameter,  and a screw or helix-
 like component  that pushes the  powder  up through the  tube to  the
 TRU.   Here,  the powder is  retorted to  recover separate fractions
 of elemental  mercury and phosphor powder.

 3.3.3     Emission Points  and Estimates

     Because  of  the design of this mercury  recycling  and recovery
 system,  there  is virtually no leakage  of  air  from  the  lamp charge
 chute.    As with  the MRS system  described  above,  the entire
process  is carried out under negative  air pressure, which
prevents emissions from the mouth  of the  feeder  tube.
Furthermore, because recovery of the mercury  is  carried  out in
the  same self-contained unit as  lamp-crushing, there  is  no point
where the transfer of phosphor powder  to  a  subsequent  processing
device  can result in emissions.
                                17

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     Mercury Technologies of Minnesota monitors their  indoor  air
regularly, and the company consistently operates with  indoor
levels of mercury of approximately 0.005 mg/m3,  which is an order
of magnitude lower than the OSHA limit.6  The plant is shut down
if levels reach 0.01 mg/m3.
     No information is available regarding the particular
effectiveness of different control devices; instead, the facility
relies upon its workplace monitoring to ensure that emissions  are
restricted or eliminated.  As previously stated, carbon adsorbers
applied to mercury vapor streams in other industries typically
achieve outlet mercury concentrations under 50 ppb, and sometimes
as low as 1 ppb.13  If it is assumed that these  levels  are
attained by the Mercury Technologies system, then using these
outlet concentrations and the reported air exhaust rate for the
crusher, mercury emissions would range from 0.14 to 7 mg per
minute.

3.4  OTHER VARIATIONS

     The crushing systems discussed above demonstrate the range
of available technology, and are generally representative of the
fluorescent lamp reduction and recycling industry.  After the
most simple crushing units have been expanded upon, most of the
differences between crusher systems result from differences in
pollution control devices.   Several industry representatives
contacted during this study articulated the feeling that the
basic crushers mounted on top of barrels are inadequate methods
and pollute excessively.6'7'8   This is due to the fact that,
although most of the mercury is contained in the phosphor powder,
a considerable percentage of the mercury is in vapor form, and
therefore will not be removed by particulate capture methods.
This leads to an environmental problem in the form of mercury
emissions.
                                18

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 3.4.1      Transfer  Operations

     Removal  of  the collection  barrel  (55-gallon  drums)  from the
 collection device  (e.g.,  cyclone  separator,  baghouse)  and placing
 the  seal  and  lid on it  constitutes  a potential  emission  point.
 The  55-gallon drums are Department  of  Transportation-approved
 vessels,  and  are sealed as  soon as  they  are  removed  from the
 crushing  device.  USALights of  Minnesota said that this  procedure
 is carried out very rapidly to  minimize  emissions.8  The workers
 involved  in this operation  all  wear respirators and  protective
 clothing  during  the operation to  minimize their exposure to
 mercury.   USALights replaces its  barrels about  once  every two
 weeks.
     Typically,  when facilities do  not recover  mercury on-site,
 they must ship it elsewhere for further  processing.  In
 Minnesota,  this  is  done under a hazardous waste manifest,  and all
 mercury is  shipped  with a licensed  hazardous waste transporter.8

 3.4.2      Removal of Endcaps

     An operation which is  not  discussed in detail here,  because
 it does not involve  crushing of the light lamps,  is  carried  out
 by a company  called  Lighting Resources.1   Lighting Resources
 received  a variance  for treatment of used fluorescent lamps  in
 California  in  January 1991.  The variance allows  operation of
 equipment as  a prototype unit to determine optimal treatment
 conditions.
     Instead  of crushing the lamps, this  company's process cuts
 off the endcaps,  thereby releasing the vacuum in  the lamp, and
 then removes the phosphor powder with an  air vortex.  The
 phosphor powder is then collected in a cyclone  separator.  The
process is operated  at a low temperature  (actual  temperature
value was not reported)  in the process room to  reduce
volatilization of mercury.1
                                19

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 3.4.3     MRT AB  Mercury Recovery Systems

     MRT AB, a  company based  in Sweden with worldwide  operations,
 has one of the  more refined mercury reclamation operations  in  the
 world.1  The operation is a full scale system for the recovery of
 mercury from fluorescent lamps, batteries and other mercury-
 containing waste.  They use a batch distillation retort to
 reclaim the mercury, and have developed a modular design that
 allows their plants to handle widely varying numbers of inputs
 (lamps).  The smallest of their units is a single lamp crusher
 with a distilling unit that can handle up to 200,000 lamps  per
 year.
     The entire system is enclosed and operated under negative
 pressure to minimize fugitive emissions.  The system vents  to
 carbon filtration units for mercury emission control.  MRT  AB
 closely monitors emissions from all their systems.  Based on
 measurements downstream of all their charcoal filters, MRT  states
 that air emissions from their crush/sieve unit has an average
 mercury concentration of 0.5 /ig/m3,  resulting in  annual emissions
 of 1 g/year.1   Emissions  from  the  crush/sieve ventilation  room
 are also 0.5 /xg/m3,  yielding 5.25  g/year in  annual  emissions.1
 The differences are due to differences in operating hours.  No
 inlet concentrations or control device efficiencies were
 reported.   The MRT system is used successfully by RecycLights  of
Minnesota.5

 4.0  MERCURY RECOVERY

     After crushing of fluorescent light lamps,  mercury recovery
 is  often the next step taken in the recycling process.  Most
commonly,  crushed lamps that are not. landfilled undergo retorting
or  roasting.1  These processes recover mercury by distillation
 (i.e.,  heating the material to vaporize the  mercury and
subsequently collecting it by  cooling the offgas  stream to
condense liquid elemental mercury).   Different versions exist,
                               20

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 but in each,  the material is heated to vaporize the mercury and
 recover it as a liquid.   This can be accomplished in closed
 vessels (retorts)  or in  open-hearth furnaces,  ovens,  or rotary
 kilns  (roasting).1  Recovery  of the vaporized mercury can be done
 with condensers and separators or with a  venturi scrubber  and
 decanter,  followed by an air pollution control system.1
     Retorting generally gives higher recovery rates than  does
 roasting,  and is also well-suited to wastes  containing  volatile
 forms  of mercury (e.g.,  elemental,  oxidized  species).   Thus
 retorting  is  generally the recovery method of  choice for
 fluorescent lamps T1
     Generally,  the mercury-containing wastes  are placed in a
 retort,  and heated for four to twenty hours  to  a temperature
 above  the  boiling  point  of mercury  (357°C) but  below 550"C.1
 Vaporized  material from  this  process  is condensed in the scrubber
 or  condenser,  and  then it is  collected in a  collector or
 decanter.   This  collected mercury may require additional
 treatment,  such  as nitric acid bubbling, to  remove  impurities.1
     The potential emission points  from a retort process include
 the  condenser  or scrubber vent and  the handling  areas for waste
 feed and recovered mercury.1  Fugitive emissions from these
 points may be  controlled by enclosing the entire system  and
 operating  it under negative pressure,  similar to the system at
 MRS  AB,  as  previously  described.  There may  also be mercury
 emissions  from scrubber  wastewater.   Final treatment of  these
 wastes has  been shown  to be achieved  with activated carbon, with
 the  used carbon being  disposed at a hazardous waste  landfill.1

 5.0  DISCUSSION AND CONCLUSIONS

     A typical four-foot  fluorescent  lamp contains about 41 mg of.
mercury, although this value  is expected to decrease to  27  mg by
 1995.  The maximum measured concentration is found in the white
phosphor powder on the inside surface of the glass.  The vapor in
                                21

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 the  lamp  would  contain about  0.04 rng of mercury at room
 temperature  (assuming the vapor  is saturated with mercury).
     The  amount of mercury emitted from a  spent lamp depends  on
 the  way the  lamp  is handled after it is changed.  In one  extreme,
 used lamps are  simply broken  into a dumpster and transported  to
 the  landfill  in a garbage truck.  It is assumed that all  of the
 lamps  in  garbage trucks are broken and that vaporized mercury in
 these  trucks  finds its way to the atmosphere.1   In the other
 extreme,  the  discarded lamps are packed in corrugated containers
 from which the  new lamps were taken and are then loaded into
 enclosed  vans or_trailers for removal to a landfill.  In  this
 case,  it  is assumed that few lamps are broken and practically all
 of the mercury  is retained in the landfill.1
     In any case,  recovery of the mercury in lamps appears to be
 desirable, in that the net amount of mercury ultimately released
 to the environment is reduced.  The recovery process begins with
 the  crushing of lamps to extract the white phosphor powder, which
 contains  the bulk of the mercury.  This powder is then put into a
 mercury retort to recover elemental mercury.
     Lamps can be crushed either by a mobile crushing unit at  the
 point of  collection,  or by a centralized stationary crushing
 unit.  Both of these operations generally use small lar.p  crushing
 units which fit on the top of a 55 gallon collection drum.
 Industrial hygiene measurements around these drum-mounted
 crushers have shown that,  even in a well-covered crusher,  some
mercury escapes from the lamp feed tube,  causing concentrations
 of about  0.3 mg/m3.  This  is well in excess of  the OSHA  limit  of
 0.05 mg/m3.
     Two well-controlled crusher systems were identified.   Both
 of these use a vacuum collection system to prevent release of
mercury from the lamp feed system.   In both cases,  the air is
passed through a cyclone,  a HEPA filter,  and a  carbon adsorber
before being exhausted.   The cyclone removes  glass particles;  the
HEPA filter removes the phosphor powder,  which  contains most of
the mercury;  and the  carbon adsorber captures mercury vapor.
                               22

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Typically, depending upon the specific operation and the  degree

of mercury contamination, the glass particles, HEPA filters,  and
carbon adsorbers are either processed to recover the mercury  or
disposed of in a hazardous waste landfill.

     These controls reduce mercury levels near the crusher to

well below the 0.05 mg/m3 OSHA limit.   This implies an emission

reduction of at least 90 percent.  Table 5 compares calculated

and measured mercury emissions and concentrations from different

crushing systems.
    Table 5:  Comparison of Calculated and Measured Emissions
                 from Different Crushing Systems
                         Resulting
                          Mercury
                       Concentration
                           (mg/m3)
              Estimated Emissions
             (mg/min)
            (mg/lamp)
  Amount of mercury
  in the vapor in a
  lamp  (4 foot)
  prior to breakage
  (for comparison)

  Simple covered
  system with no
  add-on control

  MRS

  Mercury
  Technologies
                           0.04'
 0.3D



<0.05C

<0.05C
0.2-10°

0.14-7C
0.003-0.16d

0.002-0.117d
 aMercury in the vapor phase,  calculated based on the vapor
  pressure of elemental mercury.
 bMeasured five feet from crusher.
 °Rough estimate using the reported air flow rate and typical
  exhaust characteristics from a  carbon adsorber controlling
  mercury vapor emissions.
 Calculated using the reported rate of lamp-crushing.
                               23

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6.0  REFERENCES

1.   Truesdale, R.S., S.M. Beaulieu, T.K. Pierson.  Management of
     Used Fluorescent Lamps:  Preliminary Risk Assessment.
     Prepared by Research Triangle Institute, Research Triangle
     Park, North Carolina, for the Office of Solid Waste, U.S.
     Environmental Protection Agency.  Revised May 1993.

2.   Science Applications International Corporation.  Analytical
     Results of Mercury in Fluorescent Lamps.  Prepared by
     Science Applications International Corporation, Falls
     Church, Virginia, under Contract No. 68-WO-0027 for the
     Office of Solid Waste, U.S. Environmental Protection Agency,
     Washington, D.C.  May 1992.

3.   Brist, Jim.  Minnesota Pollution Control Agency,
     Minneapolis,  Minnesota.  Personal communication.  August
     1993.

4.   National Emissions Inventory of Mercury and Mercury
     Compounds: Interim Final Report.  EPA-453/R-93-048.
     December 1993.

5.   Boerjan, Dale.  Recycling Coordinator,  RecycLights,
     Minneapolis,  Minnesota.  Personal communication.  August
     1993.

6.   Kite, Ray.  Mercury Technologies of Minnesota,  Pine City,
     Minnesota.  Personal communication.  August 1993.

7.   Roberts, Bob.   President, Mercury Recovery Services,
     Monrovia,  California.   Personal communication.   August L993.

8.   USALights, Roseville,  Minnesota.  Personal communication.
     August 1993.
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9.   Nickel, Eric.  California Department of Health Services,
     Toxic Substances Control Program, Alternative Technology
     Division, Sacramento, California.  Personal communication.
     August 1993.

10.  Kirschner, D.S., R.L. Billau, and T.J. MacDonald.
     Fluorescent Light Tube Compaction:  Evaluation of Employee
     Exposure to Airborne Mercury.  Applied Industrial Hygiene
     Vol. 3, No. 4: pp. 129-131.  April 1988.

11.  Flynn,  Mike.  Vice President, Intersol, in letter to Florida
     Department of Environmental Regulation.  1992.

12.  American Conference of Governmental Industrial Hygienists.
     Threshold Limit Values and Biological Exposure Indices for
     1987-88.   Pg.  25.   1987.

13.  Anastas,  M.Y.   Molecular Sieve Mercury Control Process in
     Chlor-Alkali Plants.   EPA-600/2-76-014, U.S.  Environmental
     Protection Agency,  Research Triangle Park,  North Carolina.
     January 1976.
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