RECYCLING FLUORESCENT LIGHT TUBES AND HIGH INTENSITY DISCHARGE LAMPS

Revision Date: 5/03
Process Code: Navy/Marines: SER-004-99; Air Force: PM06; Army: ELM
Usage List: Navy: Medium; Marines: Medium; Army: Medium; Air Force: Medium
Alternative For: Disposal of used fluorescent light tubes and HID lamps
Compliance Impact: Low
Applicable EPCRA Targeted Constituents and CAS Numbers: Mercury (CAS: 7439-97-6), Lead (CAS: 7439-92-1) and Cadmium (CAS: 7440-43-9)

Overview: The recycling of fluorescent lights and high-intensity discharge (HID) lamps is a proven technology capable of reliably recovering greater than 99% of the mercury in the spent lights. Recovery begins by separating the components by a method such as the crush-and-sieve method. In this process, the spent tubes are first crushed and then sieved to separate the large particles from the mercury-containing phosphor powder. The phosphor powder is collected and processed under intense heat and pressure. The mercury is volatilized and then distilled to the required purity. The glass particles are segregated and recycled into fiberglass. Aluminum components are also segregated and recycled separately.

All of the components of the used lights are recycled into reusable/saleable raw materials [except for any polychlorinated biphenyl (PCB) contained in some ballasts, which is incinerated].

Fluorescent lights and HID lamps have traditionally had one important drawback: relatively high environmental costs associated with their use, specifically, the disposal costs. Because they contain mercury and trace amounts of lead and other metals regulated under the Resource Conservation and Recovery Act (RCRA), fluorescent light tubes and HID lamps may be considered hazardous waste. Even small quantities of these metals may be potentially harmful to human health and the environment, especially when mass quantities of used tubes are landfilled. Used fluorescent light tube disposal in municipal landfills is, in fact, considered the second largest source of mercury pollution entering the environment. These pollutants can often migrate into groundwater supplies or even become airborne (due to mercury’s relatively high volatility), at which time they pose an even greater environmental threat. To combat that threat, the U.S. EPA has established separate regulations that control the collection and management of certain widely generated hazardous wastes, including fluorescent light tubes and HID lamps, known as universal wastes. Under the universal waste rule, the specified widely generated hazardous wastes remain hazardous wastes, but are not subject to the full hazardous waste management rules. Rather, EPA determined that these identified wastes can be more effectively managed under simpler rules that subject universal waste handlers (including generators) to less stringent standards for collecting, storing, and transporting the wastes. EPA's primary objective in designating hazardous waste lamps as a universal waste is to minimize releases of mercury to the environment, ensure safe handling of the lamps, and to keep the lamps out of landfills. Other major goals of the universal waste regulations are to reduce the regulatory burden on facilities that generate those wastes and to encourage facilities to recycle their universal wastes.

Facilities that wish to crush fluorescent tubes on-site prior to recycling should consult their local regulatory agency first. Crushing may be considered treatment of a hazardous waste, thereby subjecting the facility to numerous additional requirements.

Alto lamps have recently come on the market which are produced with low levels of mercury. These lamps have passed the EPA’s Toxic Characteristic Leaching Procedure (TCLP) and are considered non-hazardous waste.


Compliance Benefit: Because generated universal waste is not counted in a facility's hazardous waste quantity if it is managed and subsequently recycled according to universal waste standards, recycling of fluorescent light tubes and HID lamps as universal wastes will result in a decrease of hazardous waste generated. This helps facilities to meet the requirements of waste reduction under RCRA, 40 CFR 262; the Pollution Prevention Act (42 USC 13101-13109); and Executive Order (EO) 13148, Greening the Government Through Leadership in Environmental Management; and may also help facilities reduce their generator status under RCRA, 40 CFR 262. While the universal waste rule reduces the regulatory burden for facilities, universal waste still must be sent to a facility that is permitted to handle hazardous wastes (40 CFR 273). Having a fluorescent light tube recycling program will help to ensure that facility personnel do not throw used tubes into the municipal solid waste that is destined for a waste facility that may not be permitted to handle these wastes. The off-site recycling of fluorescent light tubes and high intensity discharge lamps will also help facilities comply with EO 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition.

The compliance benefits listed here are only meant to be used as general guidelines and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g., the amount of workload involved.


Materials Compatibility: Storage and handling of used lights pose no compatibility problems; nevertheless, glass tubes should remain intact during storage and shipment. This prevents any mercury or mercury-containing materials from leaking and entering the environment, which could result in contamination of storage areas, packaging, soil, etc.


Safety and Health: Fluorescent light tubes must be handled with care because of the mercury, lead, and cadmium. Mercury and lead are cumulative poisons, experimental teratogens, and carcinogens. Cadmium dust (pre-1987 lamps) can be poisonous if inhaled. Proper personal protective equipment is highly recommended.

Consult your local industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology.


Benefits:
  • Saves landfill space.
  • Reduces raw materials production needs.
  • Keeps the potentially toxic material out of landfills.


Disadvantages:
  • If stored beyond one year or treated on-site, may require hazardous waste storage or treatment permits.


Economic Analysis: Actual disposal costs of used lights vary greatly, depending on the quantity, proximity, and disposal facility, and also on any state and local fees. The cost to recycle a used fluorescent light is usually calculated per linear foot, or per bulb for HID lamps. Shipping of the used lights may or may not be provided, depending on the company. Using estimated costs provided by Wright-Patterson AFB the following analysis can be calculated.

Assumptions:

  • $0.21 to recycle a 4-foot fluorescent light tube.
  • Transportation for recycling $0.06/bulb (12 loads/year at $300/load for 60,000 bulbs/year).
  • $0.25 to $0.50 per four-foot fluorescent tube for disposal in a hazardous waste landfill (average cost: $0.38).
  • Costs based on 30,000 four-foot long fluorescent light tubes.
  • Collection and storage costs are equivalent for both options.

Annual Operating Cost Comparison for Recycling and Disposal of Fluorescent Light Tubes and High Intensity Discharge Lamps

  Recycling Disposal
Operational Costs:    
Recycling Fee: $8,100 $0
Waste Disposal: $0 $11,400
Total Operational Costs: $8,100 $11,400
Total Recovered Income: $0 $0
Net Annual Cost/Benefit: -$8,100 -$11,400

Economic Analysis Summary:

  • Annual Savings for Diversion: $3,300
  • Capital Cost for Diversion Equipment/Process: $0
  • Payback Period for Investment in Equipment/Process: Immediate

Click here to View an Active Spreadsheet for this Economic Analysis and Enter Your Own Values. To return from the Active Spreadsheet, click the Back arrow in the Tool Bar.


NSN/MSDS: None identified.

 

Approving Authority: Appropriate authority for making process changes should always be sought and obtained prior to procuring or implementing any of the technology identified herein.


Points of Contact: For more information

Vendors: This is not meant to be a complete list, as there may be other suppliers of this type of equipment.

Lighting Resources, Inc.
805 E. Francis St.
Ontairo, CA   91761
Phone: (909) 923-7252 
FAX: (909) 923-7510
E-mail: Lri.recycle@aol.com

Superior Special Services, Inc.
4220 Perimeter Drive
Columbus, OH  43228
Phone: (614) 276-3094 
FAX: (614) 276-3006
Contact: Customer Service

Bethlehem Apparatus Company, Inc.
890 Front St
P.O. Box Y
Hellerton, PA   18055
Phone: (610) 838-7034 
FAX: (610) 838-6333
E-mail: bacohg@aol.com



Related Links:



Lighting Management - Air Force Center for Environmental Excellence/Environmental Quality (AFCEE/EQ)

Do You Dispose Of Fluorescent Light Tubes? - Navy Environmental Quality Initiative (EQI)


Sources: Lighting Resources, Inc., Mr. Frank Carlen, May 1996.
Mercury Recovery Services, Mr. Bill Niver, May 1996
RCRA Hotline, Fax On Demand #11906, July 1998
Recyclights, Mr. Joe Bester, August 1998.
Mr. Raymond Baker, Wright-Patterson, AFB, September 1998.
Roxanne Lastoria, Illinois ANG, September 1998.


Supplemental: Picture of Fluorescent Tube Recycler - P2 Equipment Program

Picture of Fluorescent Tube Recycler – P2 Equipment Program