# Federal Response to CRT 

# Recycling Concerns 2014 E - SCRAP CONFERENCE OCTOBER 22, 2014 AMANDA KOHLER, U.S. ENVIRONMENTAL PROTECTION AGENCY 1

# Agenda
 How EPA regulates CRTs  What is the issue?  EPA response to CRT recycling concerns 

###  Potential future actions

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# How EPA Regulates CRTs

• Under the Resource Conservation and Recovery Act (RCRA), used cathode ray tubes (CRTs) and CRT glass generally contain hazardous levels of lead and are therefore regulated as RCRA hazardous waste when disposed by non - household sources. • CRT glass is typically sorted into two categories – panel glass (which generally is not hazardous waste) and funnel glass (which generally is hazardous).
• In 2006, EPA excluded used CRTs and CRT glass being recycled from RCRA hazardous waste regulation, provided certain conditions are met (“CRT rule,” 40 CFR 261.4(a)(22)).

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# How EPA Regulates CRTs

4 • Conditions include storage and management requirements for used, broken CRTs and export requirements for used CRTs exported for recycling or reuse . • Additionally, used CRTs and processed CRT glass are subject to speculative accumulation limits, meaning there must be a feasible means of recycling and at least 75% of the material is recycled or transferred for recycling during the calendar year. • Currently

, CRT glass can be recycled under the CRT rule by being sent to a lead smelter (to reclaim the lead and to use the silica as a flux agent) or to a CRT glass manufacturer.
• CRT glass may also qualify for another exclusion from hazardous waste regulation, such as the “use/reuse exclusion” (40 CFR 261.2(e)), for example, when used as a fluxing agent in a copper smelter or used as an ingredient in ceramic- making.

# What is the Issue?

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### • CRTs and CRT glass were once easily recycled into new CRTs; however, the 

### demand for new CRTs has collapsed in favor of new flat panel technologies.
• Because of rising costs, negative economic incentives, and shifts in CRT 

### glass markets, some CRT processors and recyclers are choosing to store the glass indefinitely rather than send it for recycling (or disposal), which increases the risk of mismanagement and/or abandonment of the CRTs.


### • TransparentPlanet’s December 2012 report estimates that about 330,000 tons were being stockpiled. Other sources estimate 3.2 to 6.6 million tons of CRTs have yet to be collected. One electronics recycler estimates that the cost to recycle CRTs will reach over two billion dollars in the next 

### decade.

# What is the issue?
 2013 ( PA, NY) – 12,000 tons of CRT glass abandoned.  Aug 2013 (CO) –8,000 tons of CRT glass abandoned.  Aug 2013 (AZ) – 3,000 tons of CRTs and CRT glass abandoned.  Mar 2014 (OH) –1,500-3,000 tons of CRT glass abandoned. Recycler was both R2 and e-Stewards certified.  Mar 2014 (AZ) – CRT recycler was fined $120,000 for improper storage and recycling of CRTs.  Mar 2014 (UT) – Fire occurred at CRT recycler, which may have been ignited from storing CRTs outside where reflection from the sun could ignite a blaze.  Additionally, a number of attendees on EPA’s May 2013 webinar indicated they knew of stockpiles, including ones in Pennsylvania, North Carolina, and Florida.

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# EPA Response to CRT Recycling Concerns

• Over the last eighteen months, we have met with a number of stakeholders on this issue. We also hosted a public webinar in May 2013.
• We published a final rule in June 2014 that amends provisions related to exports of CRTs in order to enable better tracking and help ensure environmentally sound management abroad.
• Exporters of CRTs for reuse – now must submit notice every 12 months • Exporters of CRTs for recycling – now must submit annual reports
• We have provided regulatory support to stakeholders exploring options for recycling CRT glass, including frequently asked questions (FAQs) and three regulatory determinations that are publicly available from our website.

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## EPA Letter on Copper Smelters
• Clarifies that CRT funnel glass sent to copper smelters would be excluded from hazardous waste regulation under the “use/reuse” exclusion (rather than the CRT rule).10 

## EPA Letter on Alternative Daily 

## Cover (“ADC”)
• Explains how the hazardous waste regulations apply to CRT funnel glass sent for land disposal.
• Confirms that CRT funnel glass can be land disposed as long as the glass meets land disposal restriction requirements, which for lead is 0.75 mg/L, as determined using the TCLP.11 

## EPA Letter on CRT Glass Used as a Substitute for Lead Oxide in Manufacturing of Ceramic Tiles
• Communicates EPA’s determination that CRT glass used as a substitute for lead oxide in the manufacturing of ceramic tiles is legitimate.
• Provides EPA’s rationale for this determination based on the four factors for legitimate recycling.

# Electronics Community Call to Action
• This is a challenging problem that needs the collective power of the electronics community to address.
• On September 23, EPA held a multi -stakeholder meeting with the electronics community to identify the factors that have influenced the problem and to begin an evaluation of the existing and emerging end uses for CRT funnel glass.

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# Potential Ideas for Action Generated from

Electronics Community a) Work with R2 and e-Stewards to ensure compliance with the CRT rule, including speculative accumulation, as a means of maintaining certification . b) Improve alignment of financial incentives to facilitate actual recycling, versus collection, of CRTs . c) Consistently and effectively enforce CRT rule and other regulations . d) Provide guidance for those engaging in contracts with electronic recyclers to ensure proper downstream processing of CRT glass . e) Identify available recycling/recovery options and capacity and associated cost . f) Improve awareness of regulations (e.g., training) by states and electronics community. g) Improve tracking of CRTs to ensure proper recycling (or disposal) of glass and to reduce use of “air pounds” to claim manufacturer credits. h) Grant variances, with performance management conditions (e.g., performance management standards, financial assurance, payments to receive set aside for capital investment), for longerterm accumulation of CRT glass by CRT glass processors. i) Conduct/invest in research, development, and lifecycle analyses of technologies to recycle CRT glass. j) Need to coordinate systems-wide approach to the issue. k) Improve consistency in interpretation and application of state law. l) Ensure accountability for mismanaged CRTs. m) Provide incentives for properly managing CRTs and for recycling CRT glass. 15

# US EPA Meeting on CRTs

Thursday, 1:00 PM 

# Gatlin A

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# We need to work together to solve this problem. 

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