fluorescent lamps are hazardous waste (D009) due to a small amount of Hg contained in the article. Intact lamps are allowed to be managed under the rule exemption - universal waste.
A broken lamp, although the Hg has escaped, must be managed as hazardous waste.
Crushing lamps can be considered treatment of hazardous waste, I'd be very careful if you have an EPA ID generator # but do not have a permit to treat hazardous waste unless you state has a specific rule.
Further, who will perform this work and will you monitor for Hg emissions? You dont want to expose anyone or generate a fugitive emission. How will you capture, contain, and manage the Hg separated from the lamps during crushing?
The juice is not worth the squeeze, it is less inexpensive to accumulate and send to a TSDF in the long term.
Does anyone have any experience dealing with a Bulb Eater 3L from Air Cycle Corporation? I have attached a link below. It crushes linear fluorescent lamps into a sealed drum that is picked up by the company for recycling. Curious on your thoughts?
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