WASHINGTON, D.C. 20460
                                                                          OFFICE OF
                                                                       AIR AND RADIATION
                                           March 29, 1993
Dear Green Lights Participant:

      The  Green  Lights  program  printed  "EPA  Answers Your Questions  About
Fluorescent Lamp Disposal" in the December "Green Lights Update". Attached for your
information is a reprint of the article. It is important that Green Lights participants are
aware of Federal requirements for the disposal of mercury-containing lamps and handle
them accordingly.   Remember that  these requirements apply to all users of mercury
containing lamps, not only Green Lights participants.

      If you  have any questions or comments, please contact the numbers listed on the
attached document, or contact the Green Lights Program at:

                        Green Lights Program
                        U.S. Environmental Protection Agency
                        401 M Street, S.W.
                        Mail Code 6202J
                        Washington, D.C.  20460
      Thank You!
                                        ^/Jackie Krieger, Chief
                                          Implementation Section
                                          Green Lights Branch
                                                                      Printed on Recycled Paper

                        United States
                        Environmental Protection
                        Air and Radiation
            EPA 430-F-93-002
            January 1993
Fluorescent  Lamp       ^
Disposal                              \tos
EPA Answers Your
Questions About
Fluorescent Lamp
EPA has been receiving an
increasing number of questions
as to whether used fluorescent
lamps are a hazardous or non-
hazardous waste, as well as
requests for guidance on the
best waste-handling methods.
EPA is happy to take this
opportunity to answer these
questions and to provide clearer
guidance on the status of
current federal regulations on
fluorescent lamp disposal.
      uestion: Why is proper
      disposal of fluorescent
      lamps important?
Fluorescent lamps contain small
quantities of mercury that may
be harmful to the environment
and to human health. To prevent
these materials from polluting
the environment, used lamps
must be handled in an
environmentally safe manner.
      uestion: Are fluorescent
      lamps considered a
      hazardous waste?
According to current federal law,
fluorescent lamps may be a
hazardous waste. Under the
       Resource Conservation and
       Recovery Act (RCRA), used
       fluorescent lamps, like most
       other wastes, are subject to
       evaluation against the RCRA
       hazardous waste characteristics,
       including the toxiciry
       characteristic. The generator of
       the waste is responsible for
       making this determination.
         Wastes found to exhibit
       toxicity characteristics are
       defined as hazardous wastes and
       must be managed according to
       hazardous waste storage,
       treatment, and disposal
       regulations, unless otherwise
       excluded. The mercury content
       of fluorescent lamps can cause
       them to be classified as
       hazardous under this regulation,
       requiring their management as a
       hazardous waste.
            uestion: What is EPA's
            thinking on lamp
       EPA's Office of Solid Waste is
       responsible for implementing
       RCRA. It is currently assessing
       the hazards of mercury-
       containing wastes via land
       disposal. A full range of options
       is being considered, including
       changing the regulatory levels
       for mercury and developing
       specific rules for fluorescent
       lamps. Although the end result
of this evaluation could be
deregulation, EPA encourages all
Green Lights participants, as well
as other fluorescent lamp users,
to handle fluorescent lamps in
compliance with current
hazardous waste regulations.
      uestion: Should IstM
[ & \Join the Green Lights
L   1 Program? Will Uzbtins
upgrades expose me to haz-
ardous waste regulation?
All lamp disposers, regardless of
whether or not they participate
in Green Lights, are subject to
hazardous waste regulations.
However, a comprehensive
energy-efficient lighting program
(such as Green Lights) can
reduce the cost of complying
with these regulations. First, a
good energy-efficient lighting
upgrade typically includes some
type of control strategy (e.g.,
occupancy sensors, energy
management systems), which
will reduce lamp burning hours.
This means that the lamps will
not have to be replaced as
frequently, reducing total
disposal  costs. Second, a good
energy-efficient lighting program
typically includes a lighting
management plan whereby an
independent contractor replaces
all of the lamps on a pre-deter-
mined schedule. These service
                                                                                1/93 7009

contracts can include removal
and disposal of the spent lamps
(if desirable to both parties),
thereby reducing the burden of
complying with the regulations.
      I uestion: What is the
       Green lights Program
       doing to help partic-
ipants address this issue?
The disposal of used fluorescent
lamps has been an important
consideration in Green Lights
since the program's inception in
1991. Green Lights has educated
participants on'the proper
disposal of both fluorescent
lamps and PCB-containing
ballasts by issuing fact sheets
and by devoting a chapter of the
Green Lights Lighting Upgrade
Manual to the topic.
      I uestion: What are the
I A \ftnancial implications
      of disposal?
The costs of complying with
these regulations are not trivial,
but they are not extraordinary.
In California, where earlier state
regulation has lead to significant
experience with regulated lamp
disposal, a 4-foot fluorescent
lamp typically costs 50 cents to
remove, transport, and dispose,
in compliance with regulations.
   This cost can be put into
perspective in two ways.  First,
the cost of operating a lamp
(including ballast losses) for its
20,000-hour life is $64 at the
national average electric rate of 7
cents per kilowatt-hour. The 50-
cent disposal cost of the lamp is
quite modest in comparison.
   Second, replacing an old
fixture with a new one usually
costs about $100-$150, including
installation. Disposing of an old
fixture's lamps will cost approx-
imately $2, depending on market
conditions and disposal services
purchased. If the new fixture uses
half the electricity of the  old fix-
ture (as is typical with Green
Lights upgrades), then the electric
bill savings will pay for the cost
of disposing of the old lamps
after 310 hours of operation—
about 1 month for most busi-
nesses. Essentially, lamp disposal
will extend the payback of a pro-
ject by approximately 1 month.
       uestion: What role do
       states play in fluor-
       escent lamp disposal?
States may classify mercury-
containing lamps as hazardous
waste and may regulate their
disposal independent of EPA's
regulations. Check with your
Regional EPA office or the solid
and hazardous waste department
of your state environmental
protection agency for require-
ments concerning disposal of
mercury-containing lamps in
your area.
      I uestion: Witt there be
       more mercury in the
       environment if I convert
to energy-efficient lighting?
No, there will be less. Power
plants burning fossil fuels to
 generate electricity for lighting
 systems also generate air
 pollutants such as carbon
 dioxide, sulfur dioxide, and
 nitrogen oxides, as well as toxic
 trace metals, including mercury.
 More mercury is emitted from
 power plants supplying electri-
 city to lamps than is found in the
 lamps themselves. Upgrading to
 energy-efficient lighting therefore
 keeps more mercury out of the
 environment than would leaving
 inefficient lighting in place.
 Mercury emissions are reduced
 by 60 percent through reduced
 power plant emissions when
 inefficient lighting is replaced
 with efficient lighting.
       uestion: Can lamps be
       made with less
 Yes. American manufacturers are
 working to adopt new processes,
 which can significantly reduce
 the amount of mercury needed to
 operate a lamp.
       uestion: Who should I
       contact if I have
         rther questions
about the disposal of
fluorescent lamps?

If you have questions about
handling fluorescent lamps as a
hazardous waste, please call the
RCRA Hotline at 1-800-424-9346
(703 920-9810 in the Washington,
DC area). Questions about the
Green Lights Program should be
directed to the Green Lights
Hotline at 202 775-6650.