United States
Environmental Protection
Agency
Air and Radiation
6202J
LIGHTING WASTE
DISPOSAL
EPA 430-B-95-004
September 1998
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WfGreen
35 Lights
an ENIKCY STAR imgnm
Upgrading a lighting system will likely involve the removal
and disposal of lamps and ballasts. Some of this waste
may be hazardous, and you must manage it accordingly.
This document provides an overview of issues relating to
the disposal of lamps and ballasts. For project-specific
assistance, please refer to the information resources
provided at the end of this document
Note: The information in this document is believed to be
correct as of September 1998. EPA does not provide legal
advice, nor does this document. Generators of lighting
wastes should check with local, state and regional
authorities tor the most up-to-date information.
DISPOSAL OF PCB-
CONTAINING BALLASTS
ACTION CHECKLIST
/ Investigate and follow state and local requirements
for handling and disposing of ballasts.
/ Identify ballasts that contain PCBs and ballasts
that are leaking PCBs.
/ Remove, handle, and dispose of leaking PCB-
containing ballasts by high-temperature
incineration.
/ The Green Lights and ENERGY STAR Buildings
Partnership recommends disposing of non-leaking
PCB-containing ballasts in an environmentally
responsible manner, such as by
high-temperature incineration, recycling, or
chemical or hazardous waste landfill.
/ Maintain permanent records of PCB-containing
ballast disposal.
CONTENTS
ACTION CHECKLISTS
PCB-CONTAINING BALLASTS....
DEHP-CONTAINING BALLASTS.,
1
..2
7
MERCURY-CONTAINING LAMPS 7
EVALUATING DISPOSAL OPTIONS 12
WORKING WITH CONTRACTORS 13
DEFINITIONS 13
INFORMATION RESOURCES 14
DISPOSAL OF MERCURY-
CONTAINING LAMPS
CTION CHECKLIST
/ Investigate and follow state and local requirements
for handling and disposing of lamps.
/ If you have not tested, or have state-accepted proof,
to show that your mercury-containing lamps are not
hazardous, then assume they are hazardous and
dispose of them as hazardous waste.
/ Mercury-containing lamps that test hazardous must
be handled in compliance with hazardous waste
regulations.
/ Maintain permanent records of mercury-containing
lamps that are disposed as hazardous waste
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights" Program September 1998
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PCB-CONTAINING
BALLASTS
The primary concern regarding the disposal of used
fluorescent ballasts is the health risk associated with
polychlorinated biphenyls (PCBs). Human exposure to
these possible carcinogens can cause skin, liver,
and reproductive disorders. Fluorescent and high-
intensity discharge (HID) ballasts contain a small
capacitor that may contain high concentrations of PCBs
(greater than 90% pure PCBs or 900,000 ppm). These
chemical compounds were widely used as insulators in
electrical equipment such as capacitors, switches, and
voltage regulators through the late 1970s.
The Toxic Substances Control Act (TSCA) was enacted
in 1976, and subsequently banned the production of
PCBs in the United States. The specific regulations
governing the use and disposal of PCBs are found in
Volume 40 Code of Federal Regulations (CFR) Part 761.
The proper method for disposing used ballasts
depends on several factors, such as the type and
condition of the ballasts and the regulations or
recommendations in effect in the state(s) where you
remove or discard them. TSCA specifies the disposal
method for ballasts that are leaking PCBs. In addition,
generators of PCB-containing ballast wastes may be
subject to notification and liability provisions under the
Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA)
also known as "Superfund." To select the appropriate
disposal method for PCB-containing ballasts, refer to
the decision flow chart on the following page.
Because disposal requirements vary from state to
state, check with regional, state, or local authorities for
all applicable regulations in your area. For your
convenience, information resources are listed at the
end of this document.
Identifying PCB Ballasts
Use the following guidelines to identify ballasts that
contain PCBs.
All ballasts manufactured through 1979 contain PCBs.
Ballasts manufactured after 1979 that do not
contain PCBs are labeled "No PCBs."
If a ballast is not labeled "No PCBs," assume it
contains PCBs.
Contains
PCBs
Manufactured
through 1979
Probably does not
contain PCBs
Manufactured
after 1979
It is extremely important to find out if a ballast
containing PCBs is leaking before you remove it from
the fixture, so that you can handle it properly.
Federal Requirements
Non-Leaking PCB Ballast Disposal
TSCA regulates ballasts that contain PCBs (40 CFR
761.60(b)(2)(ii)). Under TSCA, intact fluorescent and
HID ballasts that are not leaking PCBs may be
disposed in a municipal solid waste landfill. EPA
recommends packing and sealing the intact ballasts in
55 gallon drums. Green Lights also encourages its
participants to dispose of PCB-containing ballast
wastes responsibly, and recommends high-temperature
incineration, recycling, or a chemical or hazardous
waste landfill.
In addition, CERCLA regulates the disposal of non-
leaking PCB-containing ballasts. CERCLA requires
building owners and waste generators to notify the
National Response Center at (800) 424-8802. They
must notify when disposing a pound or more of PCBs
(roughly equivalent to 12-16 fluorescent ballasts) in a
24-hour period.
As a generator of PCB-containing ballast wastes, you
could be liable in any subsequent Superfund cleanup
at a municipal, hazardous, or chemical land disposal
site, incinerator, or recycling facility.
EPA encouraged proper disposal of PCB-containing
ballasts in the preamble to the 1979 PCB Ban Rule
(44 FR 31514) and in the preamble to the final rule on
August 25,1982 (47 FR 37342).
"EPA encourages commercial and industrial firms
that use and dispose of large quantities of
small PCB capacitors to establish voluntarily a
collection and disposal program that would result
in the waste capacitors going to chemical or
hazardous waste landfills or high-temperature
incinerators."
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lightsฎ Program September 1998
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Does ballast
contain PCBs?
NO
YES
YES
i
Send ballast to high-
temperature incinerator
(Federal Law)
Is the
ballast leaking?
Do state/
local disposal regulation
exist?
No special
disposal procedures
required
NO
'AdopT
voluntary safe,
responsible disposal
practices?
YES
Dispose of ballast according
to state/local regulations or
policies
Send ballast to high
temperature incinerator,
chemical or hazardous waste
landfill, or ballast recycler
-------
Leaking PCB Ballast Disposal
A puncture or other damage to ballasts in a lighting
system exposes an oily tar-like substance. If this
substance contains PCBs, the ballast and all materials
it contacts are considered PCB waste, and are subject
to TSCA requirements. Leaking PCB-containing
ballasts must be incinerated at an EPA-approved
high-temperature Incinerator. (See last section for a
list of incinerators).
It is very important that you remove, handle, and dispose
PCB-containing ballasts properly. Take precautions to
prevent exposure of the leaking ballast, since all materials
that contact the ballast or the leaking substance are
also PCB waste. Use trained personnel or contractors to
handle and dispose leaking PCB-containing ballasts.
For proper packing, storage, transportation, and
disposal information call the TSCA assistance
information hotline at (202) 554-1404.
State Requirements
Non-Leaking PCB Ballast Disposal
Many states have developed regulations governing the
disposal of non-leaking PCB-containing ballasts that are
more stringent than Federal regulations. In addition,
some EPA Regional offices published policies specifying
ballast disposal methods adopted by individual states.
State standards can take several forms (e.g., written
regulations, regional policies, written and verbal
recommendations, transportation documentation).
Some states do not regulate PCB-containing ballasts as
toxic waste, but prohibit their disposal in municipal solid
waste landfills. The table on the next page provides a
listing of state regulations and recommendations. The
last section of this document lists solid and hazardous
waste agencies for states and EPA Regions.
All generators of PCB-containing ballasts should
thoroughly investigate their state's regulations and
follow local requirements.
Green Lights recommends three methods for disposing of
non-leaking PCB-containing ballasts: high-temperature
incineration, recycling, and chemical or hazardous waste
landfill.
When upgrading lighting, make sure your contractor
removes all disconnected PCB-containing ballasts from
the lighting fixtures. Non-leaking PCB-containing
ballasts may still be hazardous if left in upgraded
fixtures, especially in case of fire.
H^h-TemperaturB/ndneraOon
High-temperature incineration is the method preferred by
many companies because it destroys PCBs, removing
them from the waste stream permanently and removing
the potential for future CERCLA liability. Incinerating a
PCB-containing ballast costs more than sending it to a
hazardous waste landfill, but this additional cost is one
many organizations are willing to absorb.
Recycling Ballasts
Recyclers remove the PCB-containing materials (i e., the
capacitor and possibly the asphalt potting material
surrounding the capacitor) for incineration or land
disposal. Metals, such as copper and steel, can be
reclaimed from the ballasts for use in manufacturing
other products. You may recycle used non-leaking
ballasts despite PCBs. The last section of this document
contains a list of companies that recycle ballasts.
Chemical or Hazardous Waste Landfill
PCB-containing ballasts may also be disposed in a
chemical or hazardous waste landfill. Landfill disposal
is less expensive than high-temperature incineration or
recycling, but does not eliminate PCBs from the waste
stream permanently. While chemical or hazardous
waste landfill disposal is an acceptable, regulated
disposal method, your organization may be legitimately
concerned about potential future CERCLA liability using
this method.
Packing PCB Ballasts for Disposal
Despite the disposal method selected, ballasts are
packed according to PCB regulations in 55-gallon
drums for transportation.
"& One drum holds 150 to 300 ballasts depending on
how tightly the ballasts are packed.
Gf Fill void space with an absorbent packing material
for safety reasons.
us- Label drums according to Department of
Transportation regulations.
us- Note that tightly packed drums may weigh more
than 1,000 pounds, which may present a safety
risk, particularly when moving the drum for loading
or unloading.
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights* Program September 1998
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STATE REGULATIONS REGARDING BALLAST DISPOSAL
AL
In-State landfill requires prior approval. Recommend incineration or chemical waste landfill.
AR
PCB-containing ballasts tranported as hazardous waste
CA
PCB-contaming ballasts should be handled, transported, and disposed of as hazardous waste
CO
Non-leaking PCB ballasts require prior approval from solid waste landfill operator Leaking PCB ballasts must be
sent to high-temperature incinerator in accord to TSCA regulations Non-PCB ballasts require approval from solid
waste landfill operator.
CT
PCB ballasts must be incinerated or sent to a chemical waste landfill
DE
Ballast disposal is regulated under the Delaware Regulations Governing Solid Waste
FL
Follow EPA Region 4 Policy. Per Florida regulations, PCB capacitors or other contaminated ballast material
cannot be disposed in any solid waste management facility in Florida Recycling of non-PCB ballast components
is highly recommended.
GA
Follow EPA Region 4 Policy
ID
PCB-contaming ballasts are governed according to EPA Region 10 policy (leaking ballasts or generation of more
than 5 ballasts/year must be handled as PCB waste)
IL
Leaking PCB-containinq ballasts meet definition of special waste (35 IAC)
IN
Disposing > 25 non-leaking ballasts (or small capacitors) requires written approval prior to disposal at a municipal
solid waste landfill Recycling requires approval pursuant to 329 IAC 4-1-5(7) as incorporated from 40 CFR
761 .BOe,
KY
Recommend recycling, chemical landfill, or incineration
LA
Ballasts may be recycled as regulated by the recycling regulations. If disposed, it is a solid waste and it must be
determined if it is a hazard as specified by the Louisiana Environmental Regulatory Code
MA
Considered hazardous waste at point of consolidation or dismantling See PEP Policy HW 92-01
MD
PCBs > 500 ppm regulated as acute hazardous waste. 1kg (based on entire weight of the ballasts) subject to full
regulation as hazardous waste Average limit is 1-2 ballasts.
ME
Ml
PCBs > 50 pom regulated as hazardous waste
Follow EPA Region 5 policy.
MN
Ballasts that are NOT marked "Does not nontam PCBs" must be managed 1) as hazardous waste, or 2) according
to MPCA special waste guidelines.
MO
PCB ballasts must be disposed in a chemical waste landfill or incinerated .
NC
PCB >50 opm not allowed in municipal solid waste landfills.
ND
Encourage recycling PCB ballasts are allowed to be disposed in permitted municipal landfills
NJ
PCBs > 50 opm considered hazardous waste.
NM
Follow EPA Region 6 policy
NY
Ballast disposal must comply with 6NYCRR Part 364 (permitting of waste haulers) and 6NYCRR Part 360 (solid
waste disposal)
OR
Follow EPA Region 10 policy (>5 ballasts/year must be incinerated or sent to chemical waste landfill)
PA
PCB ballasts must go to an approved PCB disposal facility
Rl
PCBs > 50 ppm regulated as hazardous waste. No exemptions for small quantity generators of hazardous waste
SC
PCB waste may NOT be disposed of in a municipal landfill.
SO
PCB ballasts are allowed to be disposed of at municipal landfills as long as the generator is not in the business of
manufactunng these items.
TX
PCBs > 50 ppm may be disposed of at hazardous waste landfills which are also authorized for PCB disposal or at
authorized hazardous waste disposal facilities.
VA
PCB-contaming materials regulated as Special Solid Waste. PCBs > 50 ppm may NOT be disposed or stored
without EPA approval. PCBs between 1 and 50 ppm restricted to disposal in sanitary landfills or industrial waste
landfills
VT
Intact and non-leaking PCB-contaming ballasts may be managed as Universal Waste Follow Vermont Hazardous
Waste Management Regulations -1998 Revision. Subchapter 9. Universal Waste Management Standards
Follow EPA Region 10 policy (>5 ballasts/yr must be incinerated or sent to chemical waste landfill.)
WA
Wl
Regulates all PCB-containing ballasts as hazardous waste. Recommend recycling of PCB ballasts
WV
Follow EPA Region 3 policy PCBs below Federal regulatory level are considered a special waste by WV Solid
Waste Permit Section
WY
Recommend recycling of all ballasts. Follow EPA Region 8 policy.
States not listed follow Federal Regulations
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights* Program September 1998
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PCB Ballast Disposal Costs
High-temperature incineration and chemical or
hazardous waste landfill costs can vary considerably.
Disposal prices vary according to the following.
S quantity of waste generated
S location of removal site
S proximity to an EPA-approved high-temperature
incinerator or chemical or hazardous waste landfill
S state and local taxes
When shopping for ballast disposal services, request cost
estimates in terms of both pounds and number of ballasts.
Typical F40 (fluorescent) ballasts weigh about 3.5 Ibs.,
and F96 (fluorescent) ballasts weigh about 8 Ibs.
Negotiate with hazardous waste brokers, transporters,
waste management companies, and disposal sites to
obtain the lowest fees.
High-Temperature Incineration Costs
Incineration costs are calculated by weight.
Costs range from $0.55/lb. to $2.10/lb.
ป Average cost is $1.50/lb., which equals
approximately $5.25 perF40 ballast.
Note: Estimated costs do not include packaging,
transportation, or profile fees.
Recycling Costs
When recyclers remove the PCB-containing capacitor,
the volume and weight of the ballast are reduced. This
change results in lower packing, transportation, and
incineration or disposal costs.
Recycling costs are calculated by weight.
Costs range from $0.75/lb. to $1.75/lb.
Average cost is $ 1.00/lb., which equals
approximately $3.50 per F40 ballast.
Note: Recycling cost can range from $1.25 per F40
ballast (if the PCB wastes are sent to a chemical or
hazardous waste landfill) to approximately S3.50 per
F40 ballast (if the PCB wastes are high-temperature
incinerated). Estimated costs do not include
packaging, transportation, or profile fees.
Waste
Chemical or Hi
Landfill Costs
Chemical or hazardous waste landfill costs are
calculated per 55-gallon drum.
Costs range from $65/drum to $ 165/drum
Average cost is $100/drum, which equals
approximately $0.50/F40 ballast.
Note: Estimated costs do not include packaging,
transportation, or profile fees.
Transportation Costs
Transportation fees are calculated as cents per pound per
mile. They vary according to (1) the number of drums
removed from the site, and (2) the distance from your
location to the location of the high-temperature incinerator,
chemical or hazardous waste landfill, or recycler.
Transporters may need to be registered or licensed to
move hazardous wastes in certain states.
Documentation of the movement of hazardous waste
may be required even if a state does not regulate
disposal or require the use of a licensed transporter.
Profile Fees
Operators of the high-temperature incinerator or
chemical or hazardous waste landfill may charge a
profile fee to document incoming hazardous waste.
Profile fees vary depending on the volume of waste
materials generated.
Profile fees range from $0 to $300 per delivery.
Fees may be waived if a certain volume or
frequency of deliveries is assured or a working
relationship has been established with a waste
management broker, lighting management
company, or other contractor.
Record Keeping
To track transported TSCA or hazardous waste, EPA
requires generators to prepare a Uniform Hazardous
Waste Manifest. The hazardous waste landfill,
incinerator, or recycler that you use can provide this
one-page form. The manifest identifies the type and
quantity of waste, the generator, the transporter, and its
ultimate destination.
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights" Program September 1998
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The manifest must
accompany the waste
wherever it travels. Each
handler of the waste must
sign the manifest and
keep one copy. When the
waste reaches its
destination, the owner of
that facility returns a copy of the manifest to the generator
to confirm that the waste arrived. If the waste does not
arrive as scheduled, generators must immediately notify
EPA or the authorized state environmental agency (see
the last section), so that they can investigate and act
appropriately.
In addition, require your contractor to provide you with
documents verifying the disposal method, whether the
PCBs are incinerated at high-temperatures or disposed
in a chemical or hazardous waste landfill.
DEHP-CONTAINING BALLASTS
Di (2-ethylhexyl) phathatlate (DEHP) is a substance
that was used to replace PCBs in certain ballast
capacitors beginning in 1979. DEHP in its pure form is
listed as a hazardous waste under the Resource
Conservation and Recovery Act (RCRA). However,
once it has been used in a lighting ballast, it is no
longer hazardous as defined by RCRA. (See 40 CFR
261.33, Part 261 Appendix VII, Section 268.34, and
Section 268.43.)
DEHP is regulated under CERCLAthe Superfund law.
The "Reportable Quantity" (RQ) of DEHP under
CERCLA is 100 pounds. (See 40 CFR, Section 302.4.)
This means that if you are disposing of 100 pounds or
more of the material in a 24 hour period (approximately
1,600 fluorescent lighting ballasts), you are required to
notify the National Resource Center at (800) 424-8802.
It also means that parties involved with the disposal of
DEHP ballasts may be held liable under Superfund if
clean up of the DEHP is required.
DEHP has been found in ballasts designed for the
following lighting fixtures: four-foot fluorescent fixtures
manufactured between 1979 and 1985; eight-foot
fluorescent fixtures manufactured between 1979 and
1991; and high-intensity discharge (HID) fixtures manu-
factured between 1979 and 1991. Some ballasts manu-
factured during these periods may contain dry capacitors
or substances other than DEHP. To make sure your
ballasts do not contain DEHP, contact the manufacturer
or send the capacitor to a laboratory for testing.
MERCURY-CONTAINING
LAMPS
Fluorescent and high-intensity discharge (HID) lamps
contain a small quantity of mercury that can be harmful
to the environment and to human health when
improperly managed. Mercury is regulated under
RCRA, which is administered by the US Environmental
Protection Agency. Under current Federal law,
mercury-containing lamps such as fluorescent and
HID lamps may be hazardous waste. In addition,
incandescent and HID lamps may contain small
quantities of lead that can also be potentially harmful to
human health and the environment. To prevent these
toxic materials from contaminating the environment,
dispose of used lamps responsibly.
Federal Regulations
Resource Conservation and
Recovery Act (RCRA)
RCRA requires generators of solid wastes containing
toxic constituents (such as mercury) to determine
whether or not the waste is hazardous by using
generator knowledge or testing representative samples
of that waste. According to RCRA, generators of used
fluorescent and HID lamps are responsible for
determining whether their lamp wastes are hazardous.
If you do not test used fluorescent and HID lamps and
prove them non-hazardous, assume they are
hazardous waste and dispose them accordingly.
Generator Knowledge
To use generator knowledge in making a hazardous
waste determination, the generator must have
information on possible hazardous constituents and their
quantities in the waste. Sometimes manufacturers
generate solid waste as part of their manufacturing
process, and can use process knowledge to determine
whether the waste exhibits a characteristic of hazardous
waste. However, with expired lamp wastes, the
generator has little process knowledge on which to make
a hazardous waste determination (since the generator is
not the manufacturer). The generator could base a
determination on data obtained from the manufacturer.
Alternately, refer to EPA's study entitled "Analytical
Results of Mercury in Fluorescent Lamps" (dated 5/15/
92, available in EPA's RCRA docket).
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lightsฎ Program September 1998
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"testing Lamps Tb Determine
If They Are Hazardous Waste
The Toxicity Characteristic Leaching Procedure (TCLP)
identifies whether a waste is toxic and must be
managed as hazardous waste. The test attempts to
replicate the conditions in a municipal landfill to detect
the mercury concentration of water that would leach
from the landfill. If the mercury concentration exceeds
0.2 milligrams per liter, the lamp fails the toxicity test
and is managed as hazardous waste.
When mercury-containing lamps are tested using the
TCLP, the test results can vary considerably, depending
on the lamp manufacturer, the age of the lamp, and the
laboratory procedures used. These lamps often fail the
TCLP. If you do not use the TCLP to verify that your
lamps are non-hazardous, you should (1) assume that
they are hazardous waste, and (2) manage them as
hazardous waste. Contact your state hazardous waste
agency for information on laboratories in your state that
conduct the TCLP test. The cost to test one lamp is
approximately $140. However, due to variability in
TCLP testing for lamps, EPA recommends that a large
representative sample be tested.
For more information on RCRA regulations and waste
identification, storage, transportation, and disposal,
contact the RCRA hotline at 1-800-424-9346 (in the
District of Columbia call 703-412-9810).
ComprehenshieElwiK
ttitia
illy Exempt Small
QuantityGenetators
A conditionally exempt small quantity generator, as defined
under RCRA, is a generator who disposes 100 kg or less of
hazardous waste per month. Generators must add the
weight of all the hazardous waste (lamps plus other
hazardous wastes) that their business generates during a
month. For lamp disposal, this quantity of waste includes
the mercury in the lamp along with the glass, phosphors,
and other materials (the weight of the entire lamp).
Conditionally exempt small quantity generators are
excused from RCRA identification, storage, treatment
and disposal regulations. To qualify as a conditionally
exempt small quantity generator (if the only hazardous
waste is mercury-containing lamps), a generator must
dispose of fewer than 300-350 four-foot T12 fluores-
cent lamps or 400-450 four-foot T8 fluorescent lamps
per month, depending upon the approximate weight of
each lamp. EPA encourages all users of fluorescent
and HID lamps to dispose of mercury-containing lamps
responsibly to limit the release of mercury into the
environment.
tental/tesponse,
Compensation, and Liability Act (CERCLA)
CERCLA also regulates the disposal of mercury-containing
lamps. The law requires building owners and waste
generators to notify the National Response Center at (800)
424-8802 under certain conditions. For example, they must
notify if they dispose of a pound or more of mercury (roughly
equivalent to 11,000 four-foot T12 fluorescent lamps) in a 24-
hour period. All generators of mercury-containing lamp
waste (large, small, and conditionally exempt small
generators) could be held liable in any subsequent
Superfund cleanup at a land disposal site, incinerator,
storage site, or recycling or other treatment facility.
State Regulations
Some states have adopted lamp disposal regulations that
are more stringent than current Federal requirements, while
other states have added mercury-containing lamps to their
universal waste rule (see below). Check the table on the
following page fora listing of state regulations, and contact
your regional EPA office or state agency to confirm the
most current rules and information on fluorescent and HID
lamp waste management in your state.
Under the universal waste rule, storage, handling, and
transportation practices are streamlined. Although lamps
may be identified as a universal waste under state law, they
are still considered hazardous waste and must be recycled
or properly disposed in a chemical or hazardous waste
landfill. Please note that although a state may have
previously adopted the universal waste rule for batteries,
pesticides and thermostats, this rule does not automatically
apply to mercury-containing lamps. Mercury-containing
lamps may be added to the state's list of universal wastes
only after the state has adopted a special petitioning
process, has obtained authorization to implement the
RCRA toxicity characteristic rule, and petitions have been
granted by the state (40 CFR 273). In states that do not
adopt the universal waste rule for mercury-containing
lamps, the disposal of such lamps would remain subject to
current RCRA hazardous waste regulations.
Low-Mercury Lamps
Recently, low-mercury fluorescent and HID lamps have
been introduced. Although these lamps contain much
less mercury than conventional lamps, they may still be
hazardous waste. To determine if they are hazardous
waste, the lamps must be tested using the TCLP, or the
generator can apply "knowledge of the hazard
characteristic of the waste in light of the materials or
the process used" (40 CFR 262.11(c)(2)). However,
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights8 Program September 1998
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STATE REGULATIONS REGARDING MERCURY-CONTAINING LAMP DISPOSAL
AL
Lamps failing TCLP test are handled as hazardous waste
AZ
All spent lamps should be managed in accordance with EPA Universal Waste Rule (40 CFR 2731
CA
Over 25 lamps per 24-hour period must be disposed of as hazardous waste
CO
Lamps exhibiting a characteristic of a hazardous waste would be expected to be managed in accordance with the Colorado
Hazardous Waste Act and implementing regulations Non-hazardous lamps can be disposed in a solid waste landfill with prior
approval from the solid waste landfill operator
CT
Mercury-containing lamps are subject to Federal (RCRA) regulations through TCLP testing, and if they fail the TCLP test, must
be treated as a hazardous waste
DE
FL
Lamps exceeding TCLP regulatory limits are fully regulated as hazardous waste pursuant to the Delaware Regulations
Governing Hazardous Waste Transportation must be conducted by a Delaware permitted hazardous waste transporter
Lamps may not be disposed in any municipal waste combustor Generators of > 10 lamps/month must arrange for disposal in
permitted lined landfills or recycling at mercury reclamation facilities Lamps that are recycled are subject to streamlined,
universal-waste regulations (Chapter 62-737. FAC)
HI
Follow Federal (RCRA) regulations Recommend recycling
IA
Lamps failing TCLP test are considered hazardous waste Recycling recommended EPA RCRA transportation requirements apply
Follow Federal (RCRA) regulations Conditionally-exempt generators may dispose of mercury-containing lamps in a municipal
landfill with prior approval from the landfill operator
ID
Lamps exhibiting the toxicity characteristic are subject to hazardous waste management Mercury-containing lamps have been
added to the list of Universal Wastes.
IN
Subject to RCRA through TCLP testing and may be regulated as hazardous waste under 329 IAC 3 1 Mercury-containing
lamps have been added to the list of Universal Wastes in Indiana
KS
Follow State guidance policy
KY
Spent lamps are regulated as a Universal Waste under 401 KAR Chapter 43
LA
Fluorescent lamps containing mercury can be recycled as a Universal Waste under LAC 33V Chapter 38 If disposed, it is a
solid wasted and it must be determined if it is hazardous as specified by LAC 33 V1103
MA
Regulated under the Universal Waste Rule
MO
Lamps exhibiting the toxicity characteristic subject to hazardous waste regulations Persons who generate 100 kg or more of
hazardous waste or who accumulate 100 kg or more of hazardous waste at any time (all hazardous waste, not just lamps) are
fully regulated hazardous waste generators
ME
Lamps that are unbroken, managed according to Maine's current policy, and recycled do not need to be handled as hazardous
waste If the lamps are broken or not managed according to Maine's policy they must be handled as hazardous waste
Lamps may be managed as Universal Waste
Ml
MN
Mercury containing lamps must be stored according to Minnesota Pollution Control Agency (MPCA) guidelines and shipped to
an existing recycling facility in accordance with MPCA requirements Illegal to place lamps into a solid waste landfill
MO
All spent lamps should be managed as Universal Waste
NC
Lamps that are intact and destined for recycling can be managed as Universal Waste If < 220 Its per month of lamps is
generated, a facility can send their lamps to a landfill in NC without lab data upon the landfill's approval If > 220 Ibs per
month, lab data must be submitted to a lined landfill indicating that they are non-hazardous prior to them accepting the lamps
ND
Follow Federal (RCRA) regulations. Encourage recycling
NE
Mercury-containing lamps can be recycled or disposed of as Universal Waste (NDEQ Title 128, Chapter 25) Mercury-containing
lamps not managed as Universal Waste that fail a TCLP for mercury must be managed as hazardous waste CESQG lamps
can go to a regulated landfill in 43 Ib per day quantities
NH
Hazardous fluorescent lamps that are NOT designated for recycling or which are broken are subject to NH hazardous waste rules
Follow Federal (RCRA) regulations Recommend Recycling
NM
NY
Mercury-containing lamps must comply with the hazardous waste management regulations (6NYCRR Parts 370-374 and 376)
if they fail TCLP test for any hazardous constituent
OH
Lamps designated for recycling are NOT considered hazardous waste, and are not subject to Ohio hazardous waste regulations
Lamps may be managed as Universal Waste
OR
PA
Handling, storage and shipment requirements are relaxed when lamps are sent to approved recycling facilities.
Rl
Handle and ship lamps that are determined to be hazardous in accordance with all applicable hazardous waste requirements
Disposal is regulated by SCHWMR-R 61-79 and SCHWMR-R 61-107 Intact fluorescent lamps destined for recycling that are
properly packaged and are not speculatively accumulated can be handled as non-hazardous
SC
SD
Follow Federal (RCRA) regulations Recommend Recycling
TN
Lamps designated for recycling are not considered hazardous waste and are not subject to Tennessee hazardous waste
regulations Tube crushers must meet state regulations. State approval is required for disposal of non-hazardous lamps and
hazardous waste from small-quantity generators In solid waste (Subtitle D) landfills
UT
Lamps may be managed as Universal Waste Follow Utah Administrative Code R315-16, Standards for Universal Waste Management
Intact lamps may be managed as Universal Waste Follow Vermont Hazardous Waste Management Regulations -1998
Revision. Subchapter 9. Universal Waste Management Standards
VT
WA
Recommends recycling Follow Chapter 173-351 WAC for disposal in a municipal solid waste landfill Fluorescent lamps may
not be sent to a municipal waste incinerator or industrial landfill
Wl
Hazardous waste lamps and bulbs (including bulbs with high lead concentrations) may not be placed in a solid waste landfill
Lamps and bulbs that are recycled are subiect to reduced hazardous waste management requirements as Special Wastes
WV
Follow EPA Region 3 recommendations Adopted the Universal Waste Rule
waste if determined to be below TCLP level
Can only be managed as a non-hazardous
WY
Recommend recycling and compliance with State Universal Waste Rule. Chapter 14 Wyoming Slate Hazardous Waste Rules and Regulations
Fluorescent lamps that are not designated for recycling or that are broken are subject to District of Columbia Hazardous
Waste Management Regulations (20DCMR, Chapters 40-54)
Wash DC
States not listed follow Federal (RCRA) Regulations
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most states require the lamps to be tested (using
TCLP) by the generator to determine if the lamps are
non-hazardous. Check with your regional EPA office or
state agency to confirm the most current rules and
information on the disposal requirements of these new
low-mercury lamps.
Disposal of Used Fluorescent
and HID Lamps
The following sections outline the storage, packing,
transportation and disposal options for used mercury-
containing lamps discarded as hazardous waste.
Used lamps that test hazardous or are determined
hazardous by the generator must be disposed of at a
hazardous waste landfill or sent to a lamp recycling
facility. Mercury-containing lamps should never be
incinerated. Most municipal incinerators and solid
waste combustors lack the necessary control
technologies to effectively remove mercury from the
flue gas before it is released into the atmosphere.
Hazardous Waste Landfill
A hazardous waste landfillalso known as a RCRA
Subtitle C facilityis a landfill that is permitted under
Subtitle C of RCRA and is engineered to contain hazardous
waste. Incoming wastes are manifested by the facility and
some incoming wastes are subject to treatment standards.
GLASS May be remanufactured for non-food
containers or reused as filler in cement asphalt
r END CAPS May be sent to an aluminum
I recyderforremanufactunng
Recycling Flu
nt and HID Lamps
My lamp may be recycled at permitted or licensed
recycling facilities, regardless of whether the lamp tests
hazardous. However, for lamps that are hazardous
waste, generators must follow generation, transport,
and storage requirements under RCRA Subtitle C.
Recycling separates the toxic substances (such as
mercury) from the glass, aluminum, and other lamp
components, and all materials may be re-used in
manufacturing other products. Some lamp recycling
companies recycle HID lamps as well as fluorescent
lamps. A list of companies that provide lamp recycling
services is included in the last section.
Lamp Disposal Costs
The costs for lamp disposal by recycling or hazardous
waste landfill can vary considerably. Prices vary
according to the following.
MERCURY May be sent to a mercury
distiller where it can be reused for
thermometers and other products
quantity of waste generated
location of disposal site
ซ proximity to a permitted hazardous waste landfill or
recycling facility
ซ state and local taxes
Negotiate with hazardous waste brokers, transporters,
waste management companies, and disposal sites to
obtain lowest fees.
Recycling Costs
Recycling costs for fluorescent lamps are typically
calculated by linear foot. HID lamp recycling costs are
typically quoted on a per-lamp basis.
fluorescent recycling costs range from $0 06/ft to
$0.1 sm
average cost is $0.10/ft
approximately $0.40 per F40 lamp
HID recycling costs range from $1 25/lamp to
$4.50/lamp
average cost is $2.50/lamp
Note: Estimated costs do not include packaging,
transportation, or profile fees.
Chemical or Hazardous Waste
LandfillCosts
Disposal costs for fluorescent lamps at a hazardous
waste landfill range from 25-50 cents per 4-foot tube,
not including costs for packaging, transportation, or
profile fees.
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Packing Lamps for Disposal
Transportation
To prevent used fluorescent and HID lamps from
breaking, lamps should be properly packed for storage
and transportation. When lamps are removed and
replaced with new lamps (e.g., during group relamping),
the used lamps should be packed in the cardboard
boxes that contained the replacement lamps. The
boxes containing the hazardous waste must be
properly labeled. Pre-printed labels or rubber stamps
that meet Department of Transportation regulations are
recommended for high-volume disposal.
Storing Lamps for Disposal
RCRA sets storage requirements for generators
depending on how much hazardous waste they dispose
each month.
Small quantity generators dispose 100 to 1,000 kg
of hazardous waste per month (which roughly
corresponds to 350 to 3,600 four foot lamps), and
can store hazardous waste up to 180 days.
ป Large quantity generators dispose over 1,000 kg of
hazardous waste per month (more than 3,600 four
foot lamps), and can store hazardous waste up to
90 days.
ป Conditionally exempt small quantity generators
dispose 100 kg or less of hazardous waste per month
and are exempt from RCRA storage requirements.
In addition to proper packing, care should be taken when
stacking the boxes of used lamps for storage to avoid
crushing the bottom boxes under the weight of the boxes
on top. If you work with a contractor to maintain your
lighting system, you may want to specify a safe storage
arrangement in your contract. This approach ensures
that your used lamps are not accidentally broken or
crushed before they are sent to a disposal facility.
Some organizations crush their used lamps before
disposal. This option should be pursued with care. The
crushing equipment should have the approval of state
and local authorities, and crushing methods should be
evaluated carefully. The lamp should be crushed entirely
inside the drum or storage unit so that no mercury vapor
enters the atmosphere. There should also be adequate
ventilation in the space where the crushing occurs.
Under current EPA hazardous waste regulations,
crushing lamps before sending them to a hazardous
waste landfill may be considered treatment. Therefore,
a RCRA treatment permit may be required.
Registered haulers and other transporters of hazardous
waste calculate transportation fees as cents per pound
per mile. The costs will vary according to the number of
lamps, drums, or other containers to be removed from the
site and the distance from your location to the location of
the hazardous waste landfill or recycling facility.
Profile Fees
Operators of chemical or hazardous waste landfills may
charge a profile fee to document incoming waste.
Profile fees vary depending on the volume of waste
materials generated and may be waived if a certain
volume or frequency of deliveries is assured.
Establishing a working relationship with a lighting
management company or lighting maintenance
contractor who assists with the maintenance of your
lighting system can reduce your disposal costs.
Record Keeping
To track transported waste, EPA requires generators to
prepare a Uniform Hazardous Waste Manifest. This
one-page form can be provided by the recycler or
hazardous waste landfill where you dispose of your
used fluorescent or HID lamps. The manifest identifies
the type and quantity of waste, the generator, the
transporter, and the facility to which the waste is being
shipped. The manifest must accompany the waste
wherever it travels. Each handler of the waste must
sign the manifest and keep one copy. When the waste
reaches its destination, the owner of that facility returns
a copy of the manifest to the generator to confirm that
the waste arrived. If the waste does not arrive as
scheduled, generators must immediately notify EPA or
the authorized state environmental agency (see the last
section), so that they can investigate and take
appropriate action.
In addition, require your contractor to provide you with
documentation verifying that the lamps were properly
recycled or disposed in a hazardous waste landfill.
Municipal Solid Waste Landfill
Lamp wastes generated in small quantities (see
"Conditionally Exempt Small Quantity Generators" in the
previous section) and used fluorescent and HID lamps
that do not test hazardous under RCRA may be disposed
in a properly managed municipal solid waste landfill
(RCRA Subtitle D facility). The municipal landfill may
impose restrictions or regulate incoming wastes in
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights" Program September 1998
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accordance with local rules or company guidelines.
Disposal costs for lamps at a Subtitle D municipal solid
waste landfill are approximately 2-3 cents per 4-foot lamp.
Generators may be legitimately concerned about
potential future Superfund liability in connection with
this disposal method. All generators of mercury-
containing lamp waste, regardless of size, could be
held liable in any subsequent Superfund cleanup at a
municipal solid waste landfill.
EVALUATING DISPOSAL
OPTIONS
Liability Issues
Under CERCLA, owners and operators of facilities and
persons disposing hazardous substances may be held
liable for response costs, if there is a release or threat of a
release of a hazardous substance into the environment.
Liability under CERCLA is broad and potentially costly,
and can apply retroactively. All generators may incur
Superfund liability for disposing mercury-containing lamps
or PCB-containing ballasts in a dumpster, local landfill, or
recycling, storage, or treatment facility. Disposal of
mercury wastes or PCBs in an environmentally sound
manner, however, will help to minimize the potential for
environmental contamination and thus also minimize the
potential for liability.
Impact of Lamp Disposal Cost
on Profitability
The overall impact of lamp disposal on the profitability
of typical Green Lights lighting upgrade projects is
minimal. The example below shows the impact of
various lamp recycling costs on the internal rate of
return (IRR) and the net present value (NPV) of a
typical lighting upgrade project. The assumed project
consists of upgrading a 4-lamp standard fluorescent
system that uses magnetic ballasts and 40-watt lamps
with a 4-lamp T8/electronic system and occupancy
sensors. Without considering the cost of lamp
disposal, the IRR and NPV were calculated at 47.1%
and $52,242, respectively. Note that even when
assuming lamp disposal costs of $1.50 per lamp
three times the average recycling cost the IRR and
NPV values decreased only slightly to 44.8% and
$51,642, respectively. These results were obtained
using the Green Lights analysis tool ProjectKalc.
Disposal Costs
(per lamp)
Lamp
Disposal
Cost
No fee
$0.50
$1.00
$1.50
$2.00
$2.50
$3.00
$3.50
IRR
47.1%
46.3%
45.5%
44.8%
44.1%
43.4%
42.7%
42.1%
NPV
$52,242
$52,042
$51,842
$51,642
$51,442
$51,242
$51,042
$50,842
ProjectKalc Assumptions
63% energy savings
Before: 2x4 4-lamp fixture, 40W T12 lamps, standard ballasts
After: 2x4 4-lamp fixture, 32W T8 lamps, electronic ballasts,
occupancy sensors, 25% operating hour reduction
Recycling 1%
i Material 6%
Labor 3%
Energy (X)%
FLUORESCENT LAMP LIFE-CYCLE COST
he total cost of disposing of a lamp as a hazardous waste
either by recycling or using a hazardous waste landfill can
be put into perspective in three additional 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 is quite modest in comparison.
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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
approximately $2, depending on market conditions and
disposal services purchased. If the new fixture uses
half the electricity of the old fixture (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 one month for most
businesses. Essentially, lamp disposal will extend the
payback of a project by approximately one month.
Third, as shown in the pie chart, the cost of disposing
of a lamp as hazardous waste either by recycling or
using a hazardous waste landfill represents only a
small fraction of the total life-cycle operating costs of a
lighting system. If operating a 2-lamp 18/electronic
system, disposal as a hazardous waste represents only
about 1 percent of total life-cycle operating costs.
T8 lamps contain about 15 mg of mercury
compared to 20-30 mg for T12 lamps
(low-mercury T8 lamps contain <10mg)
- so less mercury is disposed of during
relamping
T8 lamps are more energy efficient than
T12 lamps
- so less mercury is emitted from fossil-
fueled generating plants*
'(average emission is 0.04 mg/kWh)
Mercury Emissions and
the Environment
The largest man-made sources of mercury in the
atmosphere are fossil fuel combustion (58% of total) and
municipal solid waste incineration (37% of total). When
the mercury in a fossil fuel is heated in a combustor, it
turns into a vapor. In vapor form, mercury is difficult to
remove from the flue gas and easily escapes into the
atmosphere. When moisture vapor in the atmosphere
turns to rain, mercury returns to the earth and is
deposited in streams, lakes, and other waterways.
The mercury that is released into the atmosphere by
burning fossil fuels can be substantially minimized
using efficient lighting technologies.
On average, fossil-fueled power plants emit 0.04
milligrams of mercury per kilowatt-hour sold. By
maximizing the efficiency of your lighting system, you
can minimize mercury emissions from the power plants
that provide your electricity.
The amount of mercury emitted into the atmosphere
through solid waste incineration and resource recovery
facilities (which bum solid waste to produce energy)
can be minimized if you adopt a sound lamp disposal
practice.
WORKING WITH
CONTRACTORS
Your lighting upgrade project specification should
include provisions for proper handling and safe
disposal of lamps, ballasts, and other hazardous
materials that may be associated with the project
Here are some general guidelines.
" Investigate your disposal options thoroughly.
*" Do not expect your contractor to be well-versed in
all disposal requirements and options.
ซ Ask your lighting or electrical contractor to provide
disposal services (either directly or through a sub-
contractor) as part of their contract.
f Be specific in your disposal requests (e.g , request
high-temperature incineration of PCB-contammg
ballasts at an EPA-approved incinerator).
ซ Ask for certifications, licenses, and references from
all subcontractors providing waste disposal services.
DEFINITIONS
CERCLA
The Comprehensive Emergency Response.
Compensation and Liability Act of 1980. CERCLA
referred to also as "Superfund" established cleanup
and emergency response guidelines for releases of
hazardous substances into the environment. A release
of a hazardous substance in an amount equal to or
greater than its "reportable quantity" (one pound for
mercury and PCBs) in a 24-hour period triggers
CERCLA notification requirements CERCLA applies
to any size generator.
Chemical Waste Landfill
A TSCA permitted landfill that accepts hazardous
substances and extremely hazardous waste. These
facilities must meet different engineering requirements
than RCRA Subtitle C (hazardous waste) landfills.
Conditionally Exempt Small Quantity Generator
(CESQG)
A generator who generates 100 kilograms or less a
month of a hazardous waste. Under RCRA, small
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quantity generators are exempt from RCRA regulations
for the transportation, storage, treatment, and disposal
of that hazardous waste.
Hazardous Waste Landfill
See Subtitle C landfill.
RCRA
The Resource Conservation and Recovery Act which
regulates the management of solid (hazardous and
non-hazardous) wastes. Under RCRA, generators of
solid wastes are responsible for determining whether
the solid wastes are hazardous and following RCRA
transportation, storage, treatment, and disposal
requirements for those wastes.
RCRA Subtitle C Landfill
A landfill containing hazardous wastes that is permitted
under Subtitle C of RCRA. Land disposal of hazardous
wastes is restricted to permitted RCRA Subtitle C
disposal facilities.
RCRA Subtitle D Landfill
A municipal solid waste landfill containing non-
hazardous wastes permitted under Subtitle D of RCRA.
TSCA
The Toxic Substances Control Act of 1976 which
regulates the handling, storage, transportation and
disposal of polychlorinated biphenyls (PCBs)
INFORMATION RESOURCES
EPA Regional Offices
REGION I fME. VT. NH. MA. CT. Rh
Environmental Protection Agency
1 Congress St.
10th Floor
Boston, MA 02203
(617)565-3420
REGION II (NY. NJ. PUERTO RICO. VIRGIN ISLANDS!
Environmental Protection Agency
290 Broadway
New York, NY 10007-1866
(212)637-3000
REGION III (PA. WV. VA. MD. DE. WASHINGTON DC)
Environmental Protection Agency
841 Chestnut Building
Philadelphia. PA 19107
(215)566-5000
REGION IV (TN. KY. NC. SC. GA. AL. MS. FU
Environmental Protection Agency
61 Forsyth St.. SW
Atlanta, GA 30303
(404) 562-9900
REGION V (IL. Wl. IN. Ml. MN. OH)
Environmental Protection Agency
77 West Jackson Boulevard
Chicago, IL 60604-3507
(312)353-2000
REGION VI (NM. TX. OK. AR. LA)
Environmental Protection Agency
"Fountain Place"
12th Floor/Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
(214)665-6444
REGION VII (NE. KS. MO. IA1
Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7000
REGION VIII (MT. WY. ND. SD. UT. CO)
Environmental Protection Agency
Suite 500
999 18th Street
Denver, CO 80202
(303)236-3636
REGION IX (CA. NV. AZ. HI. AMERICAN SAMOA. GUAM)
Environmental Protection Agency
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1305
REGION X (WA. OR. ID. AK)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4973
State Solid and Hazardous
Waste Agencies
ALABAMA
CleteStallworth
Department of Environmental Management
Land Division Solid/Hazardous Waste
1751 Federal Drive
Montgomery, AL 36130
(334)271-7761/7735
(334)279-3053
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ALASKA
Steve Willingham
Manager, Solid Waste Program
State of Alaska
Department of Environmental Conservation
410 Willoughby Avenue
Juneau, Alaska 99801-1795
(907)465-5158
ARIZONA
Anthony Leverock
Arizona Department of Environmental Quality
Hazardous Waste Permits Unit
3033 North Central Avenue
Phoenix, AZ 85012
(602)207-4160
ARKANSAS
Bob Finn
Department of Pollution Control and Ecology
Hazardous Waste Division
PO Box 8913
Little Rock, AR 72219-8913
(501)758-0745
CALIFORNIA
Mardis Coers
Department of Toxic Substances Control
PO Box 806
Sacramento, CA 95812-0806
(916)322-0712
COLORADO
Scott Klarich
Environmental Compliance Officer
Monitoring and Enforcement Section
Hazardous Materials and Waste Management Division
Colorado Department of Health and Environment
Mail Code: HMWMD-HWC-B2
4300 Cherry Creek Drive South
Denver, CO 80222-1530
(303) 692-3369
CONNECTICUT
Mark Parker
Department of Environmental Protection
Waste Management Bureau
79 Elm Street
Hartford, CT 06106
(860)424-3372
DELAWARE
Karen J'Anthony
Department of Natural Resources and Environmental
Control
Division of Environmental Control
Solid Waste/Hazardous Waste Section
Edward Tatnall Building
PO Box 1401
Dover, DE 19901
(302) 739-4403
(302) 739-3689
DISTRICT OF COLUMBIA
Department of Consumer and Regulatory Affairs
Environmental Regulation Administration
Pesticides, Hazardous Waste and Underground
Storage Tank Division
Hazardous Waste Management Branch
(Hazardous Waste Disposal)
2100 Martin Luther King, Jr. Ave. SE,
Suite 203
Washington. DC 20020
(202)404-1167
Department of Public Works
Public Space Maintenance Administration
Bureau of Sanitation Services
(Solid Waste Disposal/Recycling)
2750 South Capitol St.. SE
(202)767-8512
FLORIDA
John Price
Bureau of Solid and Hazardous Waste
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, Florida 32399-2400
(850)488-0300
GEORGIA
Vern George
Environmental Protection Agency
Toxics Branch
345 Courtland St., NW
Atlanta, GA 30334
(404) 562-9900
John Williams
Department of Natural Resources
Environmental Protection Division
Land Protection Branch
205 Butler Street. SE
Suite 1154
Atlanta, GA 30334
(404) 656-2833
HAWAII
Paul Kalai Waa
State of Hawaii
Department of Health
Environmental Management Division
Clean Air Branch
Asbestos Abatement Office
PO Box 3378
Honolulu, HI 96801-3378
(808)586-8144
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IDAHO
Mike Gregory
Division of Environmental Quality
Division of Environment
Bureau of Hazardous Materials
450 W. State Street
Boise. ID 83720
(208)373-0494
ILLINOIS
Edwin Bakowski
State of Illinois
Environmental Protection Agency
2200 Churchill Road
Springfield, IL 62794-9276
(217)524-3300
INDIANA
Robert Snodgrass
Solid Waste Permit Section
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)635-2491
IOWA
Lavoy Haage
Department of Natural Resources
Solid Waste Section
Land Quality Bureau
Wallace State Office Building
900 East Grand Avenue
DesMoines, IA50319
(515)281-4968
KANSAS
Ron Smith
Department of Health and Environment
Solid Waste Management Division
Forbes AFBBIdg. No. 740
Topeka.KS 66620
(913)296-1500
KENTUCKY
Abbie Myer
Department for Environmental Protection
Division of Waste Management
Ft. Boone Plaza
14ReillyRoad
Frankfort, KY 40601
(502)564-6716 x242
LOUISIANA
Rosselle Foote
Department of Environmental Quality
Office of Solid and Hazardous Waste
Solid Waste Division
PO Box 44307
Baton Rouge, LA 70804
(504) 765-0355
(504) 765-0246
MAINE
Cherrie Plummer
Department of Environmental Protection
Bureau of Oil & Hazardous Materials Control
State House Station 17
August, ME 04333
(207) 287-2651
MARYLAND
Ed Hammerburg
Department of Environment
Toxic Operations Program
2500 Boenmg Highway
Baltimore, MD 21224
(410)631-3345
MASSACHUSETTS
Dikran Kaligian
Office of Hazardous Waste
Enforcement Division
1 Winter Street
Boston, MA 02108
(617)556-1022
MICHIGAN
Tish May
Department of Natural Resources
Hazardous Waste Division
PO Box 30241
Lansing, Ml 48909
(517)373-2730
(517)373-4630
MINNESOTA
Nancy Ellefson or Bob Cross
Minnesota Pollution Control Agency
Solid or Hazardous Waste Division
520 Lafayette Road North
St. Paul. MN 55155
1-800-657-3864
(651)297-7560
(612)296-6300
MISSISSIPPI
David Lee
Department of Environmental Quality
Office of Pollution Control
PO Box 10358
Jackson, MS 39209
(601)961-5171
MISSOURI
Cathy Flippin
Department of Natural Resources
Division of Environmental Quality
Waste Management Program
Jefferson State Office Building
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205 Jefferson Street
PO Box 176
Missouri Boulevard
Jefferson City, MO 65102
(573)751-3176
MONTANA
Don Vidrine
Department of Health and Environmental Sciences
Environmental Sciences Division
Solid and Hazardous Waste Bureau
PO Box 200901
Helena, MT 59620-0901
(406)444-1430
NEBRASKA
Jim Harford
Department of Environmental Control
PO Box 94877
State Office Building
Lincoln, NE 68509
(402)471-8308
(402)471-2186
NEVADA
Colleen Crips
Bureau of Hazardous Waste
333 West Nye Lane
Carson City. NV 89710
(702)687-5872
NEW HAMPSHIRE
Robert C. White, Chief
PCB Section
Department of Environmental Services
Air Resources Division/Toxics Management Bureau
64 N. Main St., Caller Box 2033
Concord, NH 03302-2033
(603)271-1370
Department of Environmental Services
Waste Management Division/Compliance Bureau
6 Hazen Drive
Concord, NH 03301
(603)271-2942
NEW JERSEY
John Shevlin
NJ Department of Environmental
Protection and Energy
Hazardous Waste Regulation Program
401 East State Street
CN421
Trenton, NJ 08625
(609)984-6650
NJ Department of Environmental Protection and Energy
Solid Waste Management Division
840 Bear Tavern Road
CN44
Trenton, NJ 08625
(609)984-6650
NEW MEXICO
John Gimkowych
New Mexico Environmental Department
Harold Runnels Building
PO Box 26110
Santa Fe, New Mexico 87502
Hazardous and Radioactive Materials Bureau
(505)827-1508
Solid Waste Bureau
(505)827-2775
NEW YORK
John Miccoli
Environmental Specialist
Division of Solid & Hazardous Materials
Bureau of Hazardous Waste Management
Technical Determination Section
New York State Department of
Environmental Conservation
Room 452
50 Wolf Road
Albany, NY 12233-7251
(518)485-8988
NORTH CAROLINA
Doug Roberts
Department of Environment, Health, and Natural
Resources
Solid Waste Management/Hazardous Waste Division
PO Box 27687
Raleigh, NC 27611
(919)733-2178 x233
NORTH DAKOTA
Conrad Carlson
Division of Waste Management
1200 Missouri Avenue
PO Box 5520
Bismarck, ND 58502-5520
(701)328-5166
OHIO
JeffMayhugh
Environmental Protection Agency
Office of Solid and Hazardous Waste
PO Box 1049
1800 Watermark Drive
Columbus. OH 43266-0149
(614)644-2917 x2934
OKLAHOMA
Jerry Sanger
Oklahoma Department of Environmental Quality
Public Information and Education
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1000 Northeast 10th Street
Oklahoma City. OK 73117-1212
(405)271-7353
OREGON
RickVopel
Department of Environmental Qualify
Waste Management Clean-up Division
811S.W. 6th Avenue
Portland, OR 97204
(503)229-5630
PENNSYLVANIA
Jim Roof
Department of Environmental Protection
Bureau of Waste Management
PO Box 8471
Harrisburg, PA 17105-8471
(717)787-6239
PUERTO RICO
Environmental Quality Board
Solid and Hazardous Waste Bureau
PO Box 11488
Santurce, PR 00910
RHODE ISLAND
Robert Nero
Department of Environmental Management
Air and Hazardous Materials
291 Promenade Street
Providence, Rl 02908
(401)222-1360 x7516
SOUTH CAROLINA
Howard Moseley
Board of Health and Environmental Control
Bureau of Solid and Hazardous Waste
2600 Bull Street
Columbia, SC 29201
(803)896-4126
(803)896-4174
SOUTH DAKOTA
Carrie Jacobson
Department of Water and Natural Resources
Environmental Health Division
Joe Foss Building
Pierre. SD 57501
(605)773-3153
TENNESSEE
Elizabeth Jayne, Technical Coordinator
Department of Environment and Conservation
Division of Solid Waste Management
5th Floor, L&C Tower
401 Church Street
Nashville, TN 37243-1535
(615)532-0834
(615)532-0780
TEXAS
Sonia Rails
Texas Water Commission
PO Box 13087
1700 North Congress Avenue
Austin. TX 78711-3087
(512) 463-7830 (Fax)
(512)463-8176
UTAH
Dennis Downs
Department of Environmental Quality
Division of Solid and Hazardous Waste
POBox 1448BO
Salt Lake City, Utah 84114-4880
VERMONT
Lynn Metcalf,
Department of Environmental Conservation
Hazardous Materials Management Division
103 South Main Street
Waterbury, Vermont 05671-0404
(802)241-3888
VIRGINIA
Robert Lincoln, Waste Division
Virginia Department of Environmental Quality
Special Solid Waste Program
P.O. Box 10009
Richmond, VA 22240
(804)698-4000
WASHINGTON
Stacie Singleton
Department of Ecology
Solid and Hazardous Waste Program
PO Box 47600
Olympia. WA 98504-7600
1-800-633-7585
WEST VIRGINIA
Tom Fisher
WV Division of Environmental Protection
Office of Waste Management
1356 Hansford Street
Charleston, WV 25301
(304)558-5989
(304)558-5929
WISCONSIN
Tim Mulholland
Department of Natural Resources
Bureau of Solid Waste Management
101 South Webster Street
Madison, Wl 53707
(608)266-2111
(608)266-1327
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights* Program September 1998
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WYOMING
Tim Link
Department of Environmental Quality
Solid and Hazardous Waste Division
122 West 25th Street
Cheyenne, WY 82002
(307)777-7752
TSCA, RCRA, and CERCLA
Information Phone Lines
Toxic Substances Control Act (TSCA)
Assistance Information Hotline
(202) 554-1404
RCRA/CERCLA Hotline
(800)424-9346
in the Washington. DC Metro Area
(703)412-9810
CERCLA National Response Center
(NRC) Hotline
(800)424-8802
EPA-Approved Disposal Locations
Commefcia//ypenn/ttet/
Aptus, Inc.
PO Box 1328
Coffeyville.KS 67337
(316)251-6380
Aptus, Inc.
P.O. Box 27448
Salt Lake City, UT 84127
11600 N. Aptus Road
Argonite.UT 84029
(801)531-4200
Chemical Waste Management
PO Box 2563
Port Arthur, TX 77643
(409) 736-2821
Rollins
PO Box 609
Deer Park, TX 77536
(713)930-2300
Weston
One Weston Way
West Chester, PA 19380
(215)692-3030
Coituitctciti/lyfjottiuiuju
HAZARDOUS WASTE LANDFILLS
Chemical Waste Management
Call 1-800-843-3604 for
information on CWM disposal
facilities nation-wide.
Envirosafe Services Inc. of Idaho
PO Box 16217
Boise, ID 83715-6217
(800)274-1516
US Ecology, Inc.
Box 578
Beatty.NV 89003
(702) 553-2203
US Pollution Control, Inc.
Grayback Mountain
8960NHwy40
Lake Point, UT 84074
(801)595-3900
Waste Control Specialists
P.O. Box 1937
Pasadena, TX 77501
(713)944-5900
THIS IS NOT A COMPLETE LIST OF COMPANIES
WHO PROVIDE DISPOSAL SERVICES THROUGH-
OUT THE UNITED STATES. COMPANIES LISTED IN
THIS SECTION ARE NOT ENDORSED BY THE EPA
OR THE ENERGY STAR BUILDINGS AND GREEN
LIGHTS PARTNERSHIP.
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights" Program September 1998
19
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GREEN LIGHTSฎ
A Bright Investment in the Environment
Green Lights, one of several ENERGY STAR programs, is
sponsored by the US Environmental Protection Agency
(EPA) and encourages major US corporations and
other organizations to install energy-efficient lighting
technologies.
Organizations that make the commitment to Green
Lights will profit by lowering their electricity bills,
improving lighting quality, and increasing worker
productivity. They will also reduce the air pollution
caused by electricity generation.
For more information, contact the Green Lights
program office.
Green Lights Program
US EPA
401 M Street. SW (6202J)
Washington, DC 20460
ENERGY STAR Hotline
& 1-888-STAR-YES (1-888-782-7937)
Fax: (202)775-6680
Green Lights Homepage
www.epa.gov/greenlights/
ENERGY STAR Homepage
www.epa.gov/energystar/
Lighting Waste Disposal is one of a series of
documents known collectively as the Lighting Upgrade
Manual. Other documents in the Manual are Listed
below.
LIGHTING UPGRADE MANUAL
Planning
Green Lights Program
Implementation Planning Guidebook
Financial Considerations
Lighting Waste Disposal
Progress Reporting
Communicating Green Lights Success
Technical
Lighting Fundamentals
Lighting Upgrade Technologies
Lighting Maintenance
Lighting Evaluations
The Lighting Survey
Appendices
Upgrading Tenant Spaces
Green Lights for Federal Participants
Requesting Proposals
To order other documents or
appendices in this series, contact
the ENERGY STAR Hotline at 1-888-
STAR-YES. Look in the E NERGY
STAR Update newsletter for
announcements of new
publications.
:een
Lights
an ENERGY STAR program
Lighting Waste Disposal Lighting Upgrade Manual EPA's Green Lights* Program September 1998
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