From: "Battles, Paul" <pmb024**At_Symbol_Here**SHSU.EDU>
Subject: Re: [DCHAS-L] Bulb Eater
Date: Mon, 6 Nov 2017 22:31:35 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: addb6d4f7cf544148c8fe9c6378b2de7**At_Symbol_Here**WinEx15Mbx05.SHSU.EDU

Thanks for all the responses! There is a department on campus looking into purchasing one of these things and I was skeptical of it from the beginning, it didn't seem to make much since to me to turn UW into HW. There are just way to many issues that arise for this to be a reasonable option. Just needed to make sure I had plenty of background information before making a recommendation. Thanks again!




From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Jeffrey Lewin
Sent: Monday, November 6, 2017 2:30 PM
Subject: Re: [DCHAS-L] Bulb Eater


I'll second Paul's caution to review your state rules.  In Michigan you need an air permit, follow additional documentation rules, and treat the crushed bulbs as Hazardous Waste rather than Universal Wastes.


It looks like Texas has restrictive rules as well:



Crushing UW Lamps Crushing lamps is permissible only under the controlled conditions described in 30 TAC Subsection 335.261(e). The crushing system must have the approval of the TCEQ, and the selected crushing method must be carefully evaluated. To get approval for crushing UW lamps, contact: IHW Permits Section, MC 130 Waste Permits Division TCEQ PO Box 13087 Austin TX 78711-3087 Phone: 512-239-6412 Fax: 512-239-2007 The lamps must be crushed entirely inside a drum or storage unit so that the mercury is captured and recycled. Ventilation must be adequate in the space where the crushing occurs. Intentional crushing of characteristically hazardous lamps—whether it is to physically separate, reduce in volume, or facilitate for transportation, storage, or recovery—is considered "treatment" unless the crushing device is capable of completing the recycling process and recovering the mercury as a product. Note: Filters from a lamp crusher when disposed of are subject to hazardous-waste determination and cannot be managed as UW. It is the generator's responsibility to determine whether used filters are hazardous waste and manage them according to federal and state regulations. Whenever possible, used filter material should be sent to a recycler so that the mercury can be reclaimed.  





On Mon, Nov 6, 2017 at 2:44 PM James Saccardo <James.Saccardo**At_Symbol_Here**> wrote:


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.

Be well,


James Saccardo, MPH, CHMM?


From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Battles, Paul <pmb024**At_Symbol_Here**SHSU.EDU>
Sent: Monday, November 6, 2017 1:56 PM
Subject: [DCHAS-L] Bulb Eater


Hello All,


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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Jeff Lewin

Chemical Safety Officer

Compliance, Integrity, and Safety

Environmental Health and Safety

Michigan Technological University

Houghton, MI 49931


O 906-487.3153

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