Robert A. Penney, P.E.
Clearinghouse Lead Engineer at the Washington State Energy Office
925 Plum Street, Box 43171
Olympia, WA 98504-3171
Across the country, thousands of lighting systems are being upgraded for a variety of reasons--energy savings, improved lighting quality, and the lure of utility rebates. There is a growing interest in proper disposal of lighting equipment. This is primarily a result of the fear of liability for noncompliance with new environmental regulations and a trend in public opinion to become "greener." The good news is that although proper disposal does take some education and cost, lighting retrofit projects can still have very attractive paybacks. Furthermore, the reduced pollution from electricity generation due to the increased energy efficiency of most new lighting equipment will more than offset any environmental impact of lighting equipment disposal.
Deterrents to proper disposal include cost and inconvenience as well as lack of infrastructure and clear, consistent information. With the alternative being a local dumpster, the idea of paying 40 cents each to ship spent fluorescent lamps across the country when they may have only cost a dollar new can be a hard sell. Some building owners and contractors may, therefore, be tempted to risk taking the road currently more traveled. The media has not been highlighting anyone going to jail or paying huge fines for throwing lighting equipment in a dumpster. The media has, however, covered stories of major corporations suddenly finding their public image plummeting due to the discovery of some impropriety--and it only takes one. Some building owners choose to be more environmentally responsible and proactively "do the right thing", regardless of legal liability, rather focusing on hunting for every possible loophole in the regulations. Each party involved in lighting retrofits needs to develop their own policy on this issue, weighing cost and liability. A lack of policy does not ensure lack of liability, as some may believe.
The first step in this process is to become well informed; a daunting task for those without advanced degrees in environmental science and law. Consulting firms can provide assistance for a fee. Environmental regulations related to lighting tend to be difficult to understand and not widely enforced. The safest approach is to check federal, regional, state, and local regulations and comply with the strictest measures for lighting equipment removal, storage, transport, and disposal. The following guidelines are intended to help the reader make more informed decisions, but it is still necessary to consult the proper authorities about more detailed and updated regulations. A list of information resources and disposal services is provided at the end of this article.
With some lighting equipment disposal methods, polychlorinated biphenyls (PCBs) or DEHP contained in older ballasts as well as mercury, lead, cadmium, sodium, and radioactive materials which may be found in lamps can find their way into the environment. They may leak through landfills, and end up in ground water. They can also get into the atmosphere from the surface of landfills or from municipal incinerators, and then rain down into surface water. Small amounts of PCBs or mercury can contaminate a sizable water supply. They are both chemically stable, so do not readily break down over time. Once introduced into the environment, they can work their way up the food chain, eventually affecting people. In 1992, there were 1550 fish consumption bans or advisories due to mercury in the U.S.
While almost 600 million lamps are discarded each year in the U.S., lamps contribute only 3-5 percent of the mercury in landfills, batteries taking credit for almost 90 percent. Manufacturers of both lamps and batteries are steadily reducing the mercury content of their products. Mercury is found is fluorescent, high-pressure sodium, metal halide, and mercury vapor lamps, not incandescent, halogen, or low-pressure sodium lamps. Some manufacturers have reduced mercury content of many lamps by more than 50 percent within the past decade without sacrificing lamp life or light output. Thinner lamps (T-8 rather than T-12) and compact fluorescent lamps contain less mercury. Exposure to very high concentrations of mercury vapors for brief periods can cause symptoms such as respiratory difficulties, chest pains, and mouth inflammation. Chronic exposure to low levels may cause tremors and neurological problems as well as skin and eye irritation. These dangers generally only concern workers regularly exposed to mercury.
It should be noted that mercury is emitted from soil and rocks naturally, and that the largest man-made sources of mercury in the atmosphere are fossil fuel combustion and solid waste incineration, together totalling 95% by EPA estimates. More mercury is introduced into the environment from the average power plant (typically .04 milligrams of mercury per kilowatt-hour) generating the additional power needed for less efficient incandescent lamps than is contained in lamps that may contain mercury.
Ballasts manufactured through 1979 and those without a "No PCBs" label on them should be assumed to contain PCBs. Ballasts can operate for 20 years or more, resulting in approximately 25 million pounds of PCBs in the one billion ballasts currently installed in U.S. buildings. The capacitor in a four-pound ballast may contain 2-3 ounces of PCBs. The capacitor may leak, allowing the PCB oil (clear or yellow in color, over 90 percent pure) to leak out of the fixture. If this happens, contact EPA for detailed cleanup procedures.
Potting compound (an asphalt compound used in ballasts to dissipate heat from electrical components) may be made of waste oil contaminated by PCBs and could be contaminated by a leaking capacitor. Therefore, leaking potting compound could also be a problem. Workers exposed to PCBs may develop skin disorders, nausea, dizziness, bronchitis, liver damage, or adverse reproductive effects. Longer exposures can cause cancer in some animals. The possibly hazardous character of alternatives to PCBs may be of concern. One of the replacements for PCBs used between 1979 and 1984 is DEHP, which has been found at almost half of the National Priorities List Superfund cleanup sites. DEHP is classified by EPA as a probable human carcinogen, and has been shown to cause liver tumors, testicular damage, cancer, and kidney damage in rodents.
Compact fluorescent lamps with magnetic ballasts may contain trace quantities of a radioisotope. However, the use of the incandescent lamps they replace results in the production of many times more radioactive waste and emissions than by using and disposing of compact fluorescent lamps. Cadmium is found in older (pre-1988) fluorescent lamps which have almost all been replaced by now. Sodium can react somewhat explosively with water, especially when found in higher concentrations such as in low-pressure sodium lamps.
The Toxic Substances Control Act of 1976 (TSCA) bans the manufacture and distribution of PCBs and regulates its disposal and storage. TSCA requires that leaking PCB ballasts not be stored on site over 30 days or in more than 10 drums at a time and that they be disposed of in a hazardous waste incinerator only. EPA strongly encourages the disposal of large quantities of ballasts to hazardous waste incinerators and chemical waste landfills. It is important to check with the regional EPA office for each retrofit site to discover their definition of "large quantities."
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund Law) provides for extensive liability for improper hazardous waste disposal practices rather than regulating disposal practices directly. Anyone disposing of more than one pound of PCBs or mercury in any landfill is a Potentially Responsible Party (PRP) in any subsequent Superfund cleanup of the landfill. If a municipal landfill is used, it must be reported to the National Response Hotline. DEHP is listed as a hazardous substance under CERCLA, and its reportable quantity is 100 pounds. Liability can extend to individuals within a corporation that knowingly directs the improper disposal of hazardous waste. It should be noted that compliance with federal and state law does not preclude later Superfund liability. Disposing of old ballasts at a hazardous waste incinerator, either directly or through a recycler, is the best protection against future liability.
Resource Conservation and Recovery Act (RCRA) regulates many hazardous wastes, including lead, sodium, and mercury, but not PCBs. To be fully regulated by RCRA, more than 100 kilograms (about 220 pounds, including the entire lamps) of hazardous waste must be generated in a month. In addition, one of these substances must be present above a specified concentration in leachate produced by the Toxic Characteristic Leachate Procedure (TCLP) or exhibit certain characteristics, such as the reactivity of sodium. Anyone wishing to dispose of lamps containing mercury must have TCLP run on a sampling of their lamps by a testing laboratory (costing several hundred dollars), obtain manufacturer's information about the lamp's toxicity (not generally available), or assume the lamps are hazardous. If less than 100 kilograms per month of hazardous waste is generated, the waste generator is classified as a conditionally exempt small quantity generator (SQG), and minimal RCRA regulations apply. The material can then be brought to any state-approved landfill (municipal or industrial) in addition to a recycler or hazardous waste disposal facility.
EPA believes that fluorescent lamps will generally fail TCLP for mercury. Test reports from the General Electric Company indicate that all high intensity discharge (HID) lamps (metal halide, high-and low-pressure sodium, and mercury vapor) fail TCLP for lead due to lead in solder, however, some manufacturers are now coming out with HID lamps containing less lead. Low pressure sodium lamps are usually classified as hazardous due the reactivity of the sodium they contain.
Some trade associations question the reliability of TCLP, and EPA admits that results can vary considerably with lamp manufacturer, lamp age, and the exact laboratory procedures used. However, TCLP is still the definitive determinant of lamp toxicity at this time.
EPA is planning to submit a proposal with two deregulating options.
When removing ballasts, wear protective gear and dispose of it along with the ballasts. Be careful not to drop non-leaking ballasts, possibly causing them to leak. If more than one pound of PCBs (the amount contained in 12-16 ballasts) is spilled, it must be reported to the EPA National Response Center and cleaned up according to EPA procedures. Note that all materials that come in contact with PCBs must also be disposed of as hazardous waste. Ballast disposal workers must be provided with special education about hazardous waste handling, and a materials data safety sheet (MSDS) must be available at the site.
Put all leaking ballasts, along with any other materials that came in contact with PCB oil, into a double plastic bag inside a separate steel drum. When moving non-leaking ballasts within a building, cardboard boxes can be used, but don't load too many in a box; twelve ballasts from four-foot fixtures weigh 40-50 pounds. Clip off wires to reduce ballast weight.
A typical 55-gallon drum will hold 150-300 ballasts from 4-foot fixtures or 60-100 ballasts from 8-foot fixtures, depending on how tightly they are packed, and will weigh 600-1000 pounds. If you plan to send the ballasts to a landfill, put non-biodegradable absorbent material (such as kitty litter) under and between the ballasts. Do not seal the drums until the transporter has had an opportunity to inspect the contents. Pack leaking ballasts separately from non-leaking ballasts. For more exact packing instructions, contact the disposal facility that you plan to ship the ballasts to.
Drums of leaking ballasts should bear a yellow "Caution: Contains PCBs" label. All drums should be clearly labeled with the name and address of the generator, weight, the date the ballasts were first removed, a description of the material (discarded fluorescent lighting ballasts), a DOT shipping description (i.e., RQ Polychlorinated Biphenyls, 9, UN2315, PGII), and a tracking number unique from any other hazardous waste container ever shipped from the same building. Don't store leaking ballasts on site for over 30 days. Non-leaking ballast must be disposed of within one year of being removed light fixtures.
For leaking PCB ballasts, you must use a Federal Uniform Hazardous Waste Manifest or an equivalent state manifest. The manifest is a form that would be signed by the building owner and transporter, describing the waste and where it's going. Less than 12-16 ballasts is not a reportable quantity, so a manifest may not be required. Non-leaking PCB ballasts are not subject to federal TSCA regulations, but may be by interpretations of TSCA by regional EPA offices. Lists of hazardous waste transporters may be available from state environmental agencies or EPA regional offices. The cost of transportation is calculated in terms of cents per pound per mile, and varies according to the number of drums to be shipped.
For more information about ballast handling, storage, and transportation, call the TSCA Hotline (see information resource list). It may be best to have the handling of leaking ballasts performed by a hazardous waste contractor or lighting maintenance firm that is specially trained to do so. You contact your state environmental agency for assistance. Just remember that building owners are the waste generators and are liable, so use caution in contracting for services and require documentation of disposal.
Lamp recyclers generally require that the lamps arrive unbroken. This can usually be accomplished by inserting old lamps into the boxes that the new lamp came in. If a lamp breaks, ventilate the area well and clean up with minimal dust generation. Use safety glasses, goggles, or face shields as well as a respirator. Lamp disposal workers must be provided with special education about hazardous waste handling, and a materials data safety sheet (MSDS) must be available at the site.
Select disposal and recycling vendors very carefully, remembering that the waste generator is always liable regardless of who else is involved. In selecting a service, make sure that they know all the regulations, have the necessary state and local permits, and have no past violations on file with EPA. Make sure that they have a good procedure for dealing with contaminated potting compound and are capable of testing for PCB contamination. They should have sufficient pollution liability insurance or environmental impairment liability coverage, and should demonstrate good worker training and quality assurance. Recycling firms should also have signed contracts with a PCB incinerator as well as with foundries or mills for scrap metal.
Facilities accepting hazardous waste generally require a profile form submitted and approved ahead of time describing just what sort of waste and how much waste will be shipped. The fee for this generally ranges from $0-$300. This fee may be waived if a certain volume or frequency of deliveries is assured. The disposal facility will provide any specific requirements they may have regarding packing, transportation, and labeling of containers as well as pricing. It is wise to have a signed document mailed to you by the disposal facility after your ballasts has actually been disposed of, closing the loop of liability.
Municipal waste landfills, also known as sanitary or RCRA Subtitle D landfills, are popular because of their low cost (10-20 cents per ballast and 2-3 cents per lamp). However, they are not designed to handle hazardous waste and may become Superfund sites. Disposal of non-leaking ballasts in such a landfill must be reported to the National Response Center and may violate the interpretation of federal regulations by some EPA Regional offices. Disposal of leaking PCB ballasts in a municipal landfill is against TSCA regulations. This would even apply to industrial landfills, which have a liner, but are still not set up to handle hazardous waste.
Hazardous waste landfills, also known as RCRA Subtitle C landfills, are acceptable for non-leaking ballasts, and are relatively inexpensive; roughly $.50 per ballast and $.25-$.50 per lamp plus packing, transportation, and profile fee. Leaking ballasts cannot be brought here. Even though hazardous waste landfills listed are approved by EPA to accept non-leaking PCB ballasts, this does not preclude the landfill from becoming a Superfund site in the future, so there is still some liability. Chemical waste landfills are slightly more specialized to handle extremely hazardous waste, and this is the type of landfill which EPA recommends most.
Municipal waste incinerators charge about the same as municipal waste landfills and are similarly becoming more restrictive as to what they will accept. These are not recommended because they lack the combustion conditions and monitoring equipment to thoroughly destroy all the PCBs or contain the mercury in lighting equipment. There may be some questions about how much hazardous waste will leach from a landfill, but a municipal incinerator will ensure the waste gets into the environment, so this option should be avoided for hazardous waste whenever possible. Leaking ballasts are prohibited from disposed in such a facility.
Hazardous waste incinerators, also called high temperature, PCB, or TSCA incinerator, destroy the PCBs completely, permanently removing them from the waste stream, so Superfund liability is minimal. In a hazardous waste incinerator, the ash and air emissions are carefully tested to insure 99.9999% destruction of the PCBs. The primary drawback of using this method for whole ballasts is cost; about $5.00 per ballast plus packing, transportation, and profile fee. This method also generates ash and air pollution and uses a great deal of energy because the ballast is 80% metal and is difficult to burn. It also wastes valuable metals that can be recycled.
Ballast recycling facilities remove and properly dispose of the PCB-contaminated parts of a ballast, including the asphalt potting materials, and recycle the remaining metals. Over 80 percent of the ballast by weight is recoverable. Recycling is lower in cost than whole ballast incineration (about $3.50 per ballast plus packing, transportation, and profile fee) and generates less air pollution and ash, uses less energy, and reclaims valuable materials, resulting in additional energy savings. If PCB components are sent to a hazardous waste landfill rather than incinerator, the price drops by over 50 percent. Non-PCB ballasts can also be recyled at a lower cost.
Lamp recycling facilities charge 6 to 12 cents per foot, depending on transportation and quantity. High intensity discharge lamps cost about $1-2 to recycle. Almost 100 percent of the materials in lamps can be recycled. Modular compact fluorescent lamps are easier to recycle than integral. The recycling industry is new, so technological advances are being made rapidly. Some European countries are far ahead of the U.S. in providing a wide-spread infrastructure to recover a large percentage of lamps; Germany's 220 collection sites and 20 processing facilities recover about 75% of spent lamps. The interNational Association of Lighting Management Companies (NALMCO) strongly encourages lamp recycling efforts and would support clearer directions and education programs for those in the lighting retrofit industry.
Processing hazardous waste on site is not recommended. Disassembling ballasts on site is a dangerous practice because of possible spills and does not deal with the problem of PCB-contaminated asphalt. Fluorescent tube compactors sit on top of a drum and crush fluorescent tubes as they are fed in. These are not generally recommended due to the risk of mercury emissions. More expensive models have highly efficient filters and mercury monitoring equipment. One drawback to this method is that it creates waste that must go to a mercury recycler--an expensive process. A RCRA treatment permit may be required for lamp crushing. Processing hazardous waste should generally be left to proper licensed facilities, and in some states it is specifically prohibited.
Community drop-off sites are provided in some areas for small quantities of household hazardous waste. Some communities have semi-annual hazardous waste collections which may be useful to small quantity generators.
Treatment, storage, and disposal facilities (TSDF) include hazardous waste landfills and incinerators as well as hazardous waste management companies and some brokers. Some such firms can often perform the whole process of packing, manifesting, transporting. Not surprisingly, they charge a fee for this, but for small waste generators this may be well worth it.
Leaving old ballasts in place may be a tempting option for delamping retrofits, but this is not recommended. Storing old ballasts on site to be used in the future is also not recommended. Ballasts may leak at any time and contaminate other building materials, requiring a costly cleanup. If there is a building fire, the temperature will be enough to vaporize but not destroy the PCBs, resulting in wide-spread contamination of building, including the floors, ceilings, fixtures, and furniture. The cost of proper ballast disposal is minor compared with packing building materials into 55-gallon drums. If the buildings were mortgaged or sold, realtors or financiers may require the PCB ballasts to be removed, and that would be more difficult than removing them as part of a planned lighting upgrade.
Some proponents of energy conservation are concerned that the costs associated with new regulations can discourage large-scale relamping may jeopardize the success of their programs. Looking at the effect quantitatively, if a recycler charges ten cents per foot of lamps, and a utility charges ten cents per kWh, recycling a four-foot, T-12 lamp would extend the payback of an investment to replace that lamp with a 32-watt, T-8 lamp by 500 operating hours (about 2 1/2 months), or about 2 percent of its rated life. The total cost of disposing or recycling lamps as hazardous waste is roughly one percent of its life cycle cost. For a typical lighting upgrade from T-12 lamps with magnetic ballasts to T-8 lamps with electronic ballasts and the addition of occupancy sensors, a disposal cost of 50 cents per lamp would only reduce the project's internal rate of return from 47.1 percent to 46.3 percent. Looking at the effect qualitatively, attractive paybacks are still available from lighting retrofit projects using proper disposal methods. The cost of proper disposal or recycling should be incorporated into price quotes and contracts.
Some utilities such as Arizona Public Service and San Diego Gas and Electric Company have modified their rebate programs to include an allowance for the proper disposal of lamps. This is a trend that is expected to continue due to utility's fear of implication into improper disposal of hazardous waste.
Although proper disposal of lamps and ballasts will increase the cost of a lighting retrofit, this will not significantly alter the project economics, and it allows building owners to avoid the substantial liability that could result from a having disposed of hazardous materials incorrectly. Retrofitting lighting systems with more efficient equipment will likely have less environmental impact due to reduced electricity generation than any disposal of the old lighting equipment, and will also provide energy cost savings. Equipment with longer life further reduces the environmental impact. Federal, regional, state, and local regulations must all be checked periodically and complied with. Permanent records should be kept of all lamps and ballasts removed. Remember that if old lighting equipment is disposed of incorrectly for any reason, a number of parties can be found liable. Aside from regulations, remember that lighting retrofit projects can have very attractive paybacks without damaging the environment.
Last Updated: December 18, 1995