AirCycler 333-200-120, User Manual

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What’s hazardous?
Persons who generate wastes are responsible for determining whether their wastes are hazardous. One
common method for determining whether a waste is hazardous is the Toxicity Characteristic Leaching
Procedure (TCLP) test. The TCLP test is a laboratory test that simulates the potential leaching of hazardous
wastes under conditions typically found in municipal solid waste landfills. If the concentration of mercury in
water that is passed through a sample of crushed fluorescent lamp fragments exceeds 0.2 mg/liter, the
crushed lamp frag
ments are classified as a hazardous waste. (See test method 1311 in “Test Methods for
Evaluating Solid Waste, Physical/ Chemical Methods,” EPA Publication SW846 for more information about the
TCLP procedures.)
In most cases, standard fluorescent lamps and lamp fragments fail the TCLP test and are considered
hazardous wastes. Facilities should treat the spent lamps and lamp fragments as hazardous wastes unless
they test the spent lamps and fragments and determine that the wastes are non-hazardous. Facilities should
manage the spent lamps as hazardous waste according to applicable federal, state, and local requirements.
New low-mercury lamps have been introduced into the market. While these lamps may pass the TCLP test and
be considered non-hazardous, some states - like Minnesota and Vermont - still prohibit persons from disposing
of even these non-hazardous lamps in a solid waste landfill. You may want to talk with a State EPA
representative to find out how you may handle spent lamps in your state.
Please note that regardless of whether the State in which you are located allows you to dispose of lamps in
your dumpster with other non-hazardous trash, the lamps do contain mercury and mercury vapors are released
into our environment when you throw lamps in the trash. Typically, the lamps break in the dumpsters, during
transportation or in the landfill and release mercury into the air or groundwater. These hazardous releases are
a risk to surrounding communities.
Facilities that throw their spent lamps in the trash thinking they are saving money may be mistaken. Throwing
spent lamps in the trash may result in the person being held responsible for the cleanup of a remote and costly
Superfund site. Because of the potential liability under Superfund, Air Cycle Corporation believes facilities that
decide to recycle their spent lamps are making a smart decision that benefits not only the environment but also
the bottom line.
What are universal wastes?
Universal wastes are specific hazardous waste streams that facilities can choose to manage in an alternative
manner in place of the more complex hazardous waste requirements. These wastes are typically generated by
many facilities and are often not properly managed under hazardous waste regulations.
Universal Wastes include:
Lamps
– Including fluorescent, high intensity discharge (HID), sodium vapor, mercury vapor, neon, and
incandescent lamps Batteries
– Including spent dry cell and lead-acid batteries Pesticides – Including certain
suspended, canceled, or unused pesticides Devices containing elemental mercury
– Including thermostats,
switches, thermometers, manometers, barometers, and various medical devices.
Does quantity matter?
Yes. RCRA (hazardous waste) requirements differ according to the amounts of hazardous waste generated
per month by the facility. There are three main categories of hazardous waste generators:
Conditionally Exempt Small Quantity Generators (CESQG’s) are persons who generate 220 lbs. per month or
less of all hazardous wastes combined (not just lamps!). These generators are exempt from most of the
hazardous waste regulations, which include transportation, treatment, and disposal requirements. They must
not, however, store more than 2200 lbs. of hazardous waste on site at any time and must dispose of their
hazardous waste in facilities that are permitted or authorized to accept hazardous or non-hazardous wastes.
Many states acknowledge CESQG exemptions for paperwork, but not for disposal. Many states do not allow
CESQG to dispose of hazardous waste in a solid waste landfill.