PA
               United States
               Environmental Protection
               Agency
            OHice of
            Solid Waste ana
            Emergency Response
 DIRECTIVE NUMBER: 
-------
                UnitM Suits
                Environment*! Protection
     3EPA
              Offic* of
              Solid W««te end
              £m«rgtncy fl»§oon»«
DIRECTIVE NUMBER: <7'M43.
TITLE:   Determination of "Regulatory Status-Light Bulbs,

APPROVAL DATE.   4/30/86
EFFECTIVE DATE:   4/30/86
ORIGINATING OFFICE: OSW/SMP
E FINAL
D DRAFT
  STATUS:

REFERENCE (other documents):
 O.9I/I/P/?
J|E    DIRECTIVE    DIRECTIVE    D

-------
 &EPA
                                                      .. .„     -
                                        Wasnmgton. DC 20460
                        OSWER Directive initiation Request
                                                  9443.00-2A  ,
                                            Originator Informat'On
Name of Contact Person
   David Friedman
                                  Mail Code  —    Branch
                                   WH-562B      SMB
                                  Teleonone*Numoer
                                     382-4770
 ead Office
   D OERR
   0 OSW
                 Q OUST
                 Q OWP6
                 Q A
                           Approved for Review
Signature of Office 0. rector
                           Date
Tiile
   Determination of  Regulatory Status.
   Products,  Inc.
                                             Light Bulbs Letter to Ritchey  Vaughn/Quicksilver
Summary of Directive
   Opinion on  whether  flourescent  and mercury vapor light bulbs  are or are not hazardous
   waste  when  discarded.
Key Words:
   Mercury, Light Bulbs, Hazardous  Waste
Type of Directive {Manual. Policy Directive. Announcement, etc./
   Letter of  clarification
                                  Status
                                  |   D Draft
                                  !   BU Final
                                                                                         tU New
                                                                                         LJ Revision
Does- this Directive Supersede Previous Oirectivels;'   [ |  Yes
If "Yes" to Either Question, What Directive (number, title)
                                                   N°   Does It Supplement Previous Directive*!)'
                                                         Yes   LJ No
Review Plan
   D AA-OSWER   D OUST
   D OERR       O OWPE
   Gl OSW       U Regions
                                  D OECM
                                  D OGC
                                  O OPPE
                 D
Other [Specify!
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Officer
                                                                                  I Date
                                                                                  '5
Signature of OSWER Directives Officer
                                                                                  Date

-------
                                                    DFMA:02:30
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                       WASHINGTON, D.C. 20460
                            APR 30 1986
                                                        OFPiCE OF
                                               SOLID WVST6 AND EMERGENCY RESHCMitr
Mr. Ritchey Vaughn
Quicksilver Products, Inc.
200 Valley Drive, Suite 1
Brisbane, California  94005

Dear Mr. Vaughn:

     I am writing in response to your request for a definitive
opinion on whether discarded fluorescent and mercury vapor lamps
would be classified as a hazardous waste under Section 261.24 of
the Resource Conservation and Recovery Act  (RCRA) regulations.

     With only the data you submitted, it is not possible for me
to give you a definitive answer to your question.. For example,
using the data presented on the GE MVR1000/VBU lamp as a worst
case, the amount of mercury that is potentially available is
223 mg/kg of waste.  If all the mercury was extracted into the
Extraction Procedure (EP) extract during the test, this would
yield an extract concentration of 11.3 mg/1.  However, mercury
is a relatively inert metal, with respect to reactivity toward
nonoxidizing acids such as the acetic acid used as the extraction
medium in the EP.  In addition, while mercury has a relatively
high solubility in water (as compared to most metals), it solubility
is only .02 mg/1 which is substantially below the regulatory
threshold of 0.2 mg/1.

     While I do not believe that either fluorescent or mercury
vapor lamps would be hazardous waste under the RCRA regulations,
actual EP testing would have to be conducted before any definite
conclusion could be drawn.  You should keep in mind, however, that
RCRA is a State administered program in those States that have
applied for and received authorization.  In such States it is the
State program which must be adhered to.  Some States have more
stringent regulations than those of the Federal program.  Thus,
it is possible that a State may elect to regulate a waste as a
hazardous waste based on its total mercury content and not on
leachable mercury.  California may be one such State.  I recommend
you contact the California Department of Health Services for
State-specified regulations.

-------
                               -2-
               e any further questions, please feel  free to call

ToJ^ i™2!-^?2'4770 °r y°U may cal1 the RCRA/Superfund Hotline at
^ ouO / 4^4—«7w4v«


                                       Sincerely yours, ;.
                                       David Friedman
                                           Manager
                                       Methods Program

-------