FY2002 OSWER Innovation Pilot Results Fact Sheet oEPA Developins an Innovative Policy to Facilitate the Use of Drum-Top Crushing Devices for Mercury Containing Lamps The Environmental Protection Agency's Office of Solid Waste and Emergency Response initiated a series of innovative pilot projects to test ideas and strategies for improved environmental and public health results. This series of fact sheets highlights the innovative approaches, results, and environmental and economic benefits from the pilot projects that may be replicated across various sectors, industries, communities, and regions. PROJECT DESCRIPTION/INNOVATION EPA's Office of Solid Waste and Emergency Response awarded an Innovation grant to EPA Region 3 to conduct an empirical study evaluating the release of mercury emissions from drum- top crushing (DTC) devices when processing fluorescent bulbs, DTC devices are designed to fit on the top of a 55 gallon drum in order to prevent the release of mercury vapors while crushing the fluorescent lamps into the drum below. In partnership with the states in Region 3, DTC device manufacturers, and the Association of Lighting and Mercury Recyclers, EPA collected data that helped frame policy discussions and develop awareness and educational tools on the safe use of DTC devices for recycling mercury-containing lamps, This project showcased an innovative approach of addressing the challenge of promoting mercury lamp recycling through its unique collaboration with federal, state and industry partners, BACKGROUND The increasingly widespread use of energy-efficient, fluorescent lamps has had tremendous environmental benefits. However, mercury, a toxic chemical, is an essential component of fluorescent lamps. When lamps are broken, whether during storage, transport, disposal or crushing, a substantial portion of the mercury in the lamp is released as mercury vapor. If the mercury vapor is not controlled or contained, it could be easily inhaled, which is a health hazard for exposed individuals. Additionally, mercury released from broken lamps is persistent in the environment, where it can be chemically transformed to methyl mercury, which is more toxic than elemental mercury. When lamps are disposed in a landfill, rather than recycled, a substantial percentage of the lamps are broken and virtually all of the mercury contained in the lamps is released into the environment. This is a similar issue when lamps are broken during collection, shipping or handling. Lamps can be recycled either by sending whole, boxed lamps to a recycier or by using a DTC device, These devices are used to The DTC devices all released some mercury emissions when used. Use of a poorly designed device could result in mercury exposures above regulatory standards. The study results helped frame policy discussions and develop awareness and educational tools on the safe use of DTC devices for recycling mercury- containing lamps. reduce the volume of waste lamps so as to improve storage and handling, and reduce shipping costs associated with fluorescent lamp recycling, Each method of recycling has potential benefits and draw-backs. Recycling fluorescent lamps with DTC devices has been inconsistently regulated due to the lack of a clear national strategy for controlling the mercury emissions from these devices. This project would generate the additional data needed to help EPA develop an effective national policy and an educational strategy on the safe use of DTC devices for recycling mercury- containing lamps. PROJECT SUMMARY In 2002, EPA Region 3 partnered with the States of Delaware, Maryland, Pennsylvania, Virginia, and West Virginia; DTC device manufacturers; and the Association of Lighting and Mercury Recyclers, to design and conduct the Mercury Lamp Drum-Top Crusher Study, The objective was to evaluate the ability of DTC devices to contain mercury released when lamps are crushed and to prevent worker exposure to adverse levels of airborne mercury. The study examined the performance of three DTC devices at separate commercial lamp recycling facilities over a five ------- month period. Over the course of the study, the three devices each crushed approximately 5,500 lamps inside constructed enclosures under a variety of environmental and operational conditions. RESULTS More than 200 air samples were collected and indicated a release of mercury vapor from all DTC devices during crushing operations. Operator exposure only remained below the regulatory exposure limits when the DTC devices were operated optimally. The study also demonstrated an increased risk of mercury exposure when full drums were replaced with empty ones, an operation inherent in the use of a DTC device. Additionally, minor mistakes in DTC device assembly can significantly affect its ability to capture mercury. For example, a leak on one device notably raised mercury levels in the operator's breathing zone and caused mercury concentrations to exceed the regulatory exposure limits for the area sample collected near the leak. It was also determined that mercury vapor can exceed established levels even if the lamps being crushed in the DTC device (i.e., low-mercury lamps) are not identified as hazardous wastes. The pilot study illustrated that the mercury released during DTC device use would inevitably create some new mercury exposure situations, primarily for DTC device operators and anyone else handling lamps or working directly with the DTC device. Appropriate administrative and engineering controls are warranted to help control exposure to mercury during DTC operation. If engineering controls are not feasible or inadequate to control mercury exposures, the use of personal protective equipment such as respiratory protection may be necessary. Study results also demonstrated the importance of using a two- person team to perform the drum changes in order to minimize potential mercury releases and exposure potential. The findings of the pilot study were later incorporated into the Mercury Lamp Drum-Top Crusher Study published by EPA in 2006. This report provides information on mercury emission control effectiveness, compliance assurance for DTCs, safety practices for crusher use, and the potential for mercury releases from DTCs in use and during non-operational periods. Lead and Sponsor: U.S. EPA Region 3 Other Partners: Association of Lighting and Mercury Recyclers Drum-top crushing (DTC) device manufacturers State of Delaware State of Maryland State of Pennsylvania State of Virginia State of West Virginia OSWER Innovation Projects: www.epa.gov/oswer/iwg/pilots Mercury Lamp Drum-Top Crusher Study: www.epa.gov/osw/hazard/wastetypes/universal/drumtop/ Information on Spent Mercury-Containing Lamp Recycling: www.epa.gov/bulbrecycling 2010 UPDATE The pilot project and subsequent Mercury Lamp Drum-Top Crusher Study helped EPA develop awareness and educational tools on the safe use of DTC devices for recycling mercury- containing lamps like the Fluorescent Lamp Recycling Report published in February 2009. This report provides information to businesses interested in recycling their spent mercury-containing lamps including best management practices (BMPs) for the storage of spent fluorescent lamps and the use of DTCs for compacting waste lamps. These BMPs are based on the results of EPA's study of these devices and are intended to promote the safest possible use of DTCs for those who choose to use them. A PQA United States Environmental Protection ' m Agency OSWER Innovation Pilot Results Fact Sheet January 2011 Developing an Innovative Policy to Facilitate the Use of Drum-Top Crushing Devices for Mercury Containing Lamps ------- |