From: Essential Information <ei@igc.apc.org>
Newsgroups: sci.energy
Date: 31 Dec 92 13:55 PST
Subject: Re: Energy Ideas - HVAC-2
Nf-ID: #R:cdp:1466300134:cdp:1466300144:000:6835
Nf-From: cdp.UUCP!ei    Dec 31 13:55:00 1992



LIGHTING TECHNOLOGY UPDATE: DISPOSAL OF FLUORESCENT BULBS

While compact fluorescent (CFL) and long-tube fluorescent bulbs
save energy, they present disposal problems because they contain
mercury vapor. Fluorescent bulbs have always been discarded in
municipal landfills, but the question of what environmental
hazard is posed by the mercury contained within them has never
been addressed. With lighting retrofits in commercial buildings,
massive quantities of T-12 fluorescent bulbs are discarded.
Eventually, CFLs and other energy-efficient bulbs will burn out
and require disposal. These frequently contain a sufficient
amount of mercury to be classified as hazardous waste.

Toxicity of Mercury

Mercury is a heavy metal with a high toxicity and a strong
tendency to accumulate in the food chain. Worldwide, the major
source of mercury in humans is consumption of
mercury-contaminated food, especially fish. Long-term exposure,
or exposure during developmental stages, to either organic or
inorganic mercury can permanently damage the brain and kidneys.
Short-term exposure to high levels of inorganic or organic
mercury can cause similar health effects, which may be
reversible. Pregnant women, children and fetuses appear to be at
highest risk.

Mercury poisoning also damages the ecosystem. Mercury is unique
among the metals in that it consistently accumulates, rather than
diminishes, within the aquatic food chain. Organisms eating
mercury-contaminated fish, such as birds, wild mink and otter,
have been found to have mercury poisoning. In addition, several
countries have reported poisoning of birds through ingestion of
seeds treated with mercury compounds, and of predatory animals
through ingestion of contaminated birds.

Mercury in Landfills on the Rise

The use of fluorescent lights has increased the amount of mercury
in the municipal solid waste stream (MSWS). According to the U.S.
Environmental Protection Agency (EPA), the amount of mercury in
the MSWS from electric lighting is expected to rise dramatically
in the next decade. In 1970, well after the entry of the
fluorescent bulb into the market, 19.1 short tons of mercury
entered the MSWS; in 1980, 24.3 short tons; in 1989, 26.7 short
tons; and in 2000, an estimated 40.9 short tons of mercury is
expected. This increase is not likely to cause a switch to
another metal vapor, since no other metal performs as well as
mercury.

Energy-Efficiency May Offset Increase

Energy-efficient lighting will, however, reduce the amount of
mercury released into the air. According to a series of
independent studies, coal-fired power plants emit 80 to 90 tons
of mercury into the air every year in the United States. The EPA,
the Electric Power Research Institute and the Department of
Energy are currently conducting studies to measure more
accurately the amount of mercury emitted by coal plants, but
these results are not expected until after 1994.

The Question of Liability

As of yet, the EPA has not ruled on whether a facility that
discards fluorescent bulbs is liable for future cleanup costs. As
reported in the October, 1992 Energy User News ( "EPA: Spent
Fluorescent, HID Lamps May Be Hazardous Waste," p. 1), "end users
who discard spent fluorescent or high intensity discharge lamps
in municipal landfills may be violating federal hazardous waste
regulations and could be liable for fines or clean-up costs
[emphasis added]." 

Therefore, end users now must determine whether the lamps contain
a hazardous amount of mercury. According to David Layland of the
EPA~s Office of Solid Waste in Washington, DC, fluorescent bulbs
must undergo a "toxicity characteristic" test (TCLP) to classify
them as hazardous waste. This test mimics the conditions of a
landfill disposal and determines the mercury concentration of the
water which will leach from the landfill. If the mercury
concentration exceeds 0.2 milligrams per liter, the lamp fails
the toxicity test and must be disposed in a licensed hazardous
waste facility. 

States Enact Their Own Policies

The only federal legislation regulating the disposal of mercury
is the Resource Conservation and Recovery Act (RCRA). RCRA does
not require generators of small quantities of mercury (less than
100 kilograms per month) to dispose their waste in a licensed
hazardous waste landfill. This translates to roughly 350-400
bulbs per month. However, poor record keeping in a municipal
landfill may not identify who disposed of the bulbs in the
landfill, and any facility disposing of a large number of the
bulbs may be held liable for Superfund Cleanup. The EPA will not
clarify the fluorescent bulb question until 1993.

As a result, states have begun to address this issue. In
California, for example, the state EPA established a policy in
1988 under which end users may not dispose more than 25
fluorescent lamps per day in dumpsters bound for municipal
landfills. In Minnesota, the Minnesota Pollution Control Agency
(MPCA) strongly recommends that the lamps be recycled rather than
landfilled or incinerated. The October, 1992 Energy User News
reported that, in Minnesota, "a business or institution that
replaces the equivalent of more than 1,000 four-foot fluorescent
lamps per year must have a hazardous waste license and report to
the MPCA or appropriate metro-area county on what it does with
the used lamps. Smaller quantities need not be reported but must
still be managed properly as described in [an MPCA] fact sheet."

Recycling Processes Have Been Developed

Private firms have developed an enclosed recycling process which
crushes the fluorescent lamps in a vacuum and removes the mercury
vapor. A separating unit divides the remaining phosphor powder,
glass and metal. Mercury residuals, according to test data, are
well below legal limits. The glass and metal are recycled. The
phosphor powder is heated to volatilize and remove the mercury. 
The powder can be reused in another form, although these
additional uses require further investigation. According to one
of the firms, the mercury which is collected in this process
achieves 99.5 percent purity and can be reused in industry. 

Although recycling is currently the most expensive method of
disposal, it is the safest. The least expensive method,
incineration, will result in the emission of mercury into the
air. The second method of disposal, landfill in a licensed
hazardous waste facility, releases the end user of liability, but
nonetheless poses an environmental threat. The actual cost of
recycling, which may be 12 cents per bulb, does not prove to be
expensive relative to the total cost of a lighting retrofit.
According to a recycling firm, when including all of the costs
from using fluorescent lights for five years, recycling the
lights at the end of their useful life only accounts for 2
percent of the total cost. 


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