[Sqg-program] FW: mercury-containing UV lights from ACunits
-SQGinspector awareness
Loomis, Walter
loomisw at talgov.com
Fri Jul 13 15:11:44 EDT 2007
Glen & Jack,
I agree with Dale and fail to see where in the FAC that you cited where it says that it is allowable for commercial and public business to discharge mercury into the trash. It states entities that generate more than 10 lamps per month shall arrange for disposal. It appears to be an interpretation and not law in your (Managing Spent Fluorescent and High Intensity Discharge (HID) Lamps A Fact Sheet For Florida Businesses and Government Facilities) stating that FDEP allows people to discard them; however this policy is in conflict with sound management of solid waste landfills along with stormwater bmps, air regulations, wastewater regulation, and worker health regulations if discarding lamps into the trash since the majority of the mercury will end up in the air, stormwater, and wastewater as the trash truck compacts its loads and releases the mercury. The regulation of spent mercury containing lamps is overdue for revision since there are now abundant recycling options available.
I believe this antiquated "10-lamp free pass" concept and the verbiage stating disposal in "permitted lined landfills" should be high priority items for the state to address.
Respectfully,
Walt
******************
(2) PROHIBITION ON INCINERATION OR DISPOSAL OF MERCURY-CONTAINING DEVICES.--Mercury-containing devices may not be disposed of or incinerated in any manner prohibited by this section or by the rules of the department promulgated under this section. If the secretary of the department determines that sufficient recycling capacity exists to recycle mercury-containing devices generated in the state, the secretary may, by rule, designate regions of the state in which a person shall not place such a device that was purchased for use or used by a government agency or an industrial or commercial facility in a mixed solid waste stream. A mercury-containing device shall not knowingly be incinerated or disposed of in a landfill.
(4) WASTE MANAGEMENT REQUIREMENT FOR SPENT LAMPS.--
(a) Any person owning or operating an industrial, institutional, or commercial facility in this state or providing outdoor lighting for public places in this state, including streets and highways, that disposes of more than 10 spent lamps per month shall arrange for disposal of such lamps in permitted lined landfills or at appropriately permitted reclamation facilities.
(b) The department may, by rule, designate regions of the state wherein any person owning or operating an industrial, institutional, or commercial facility in such a designated region, or providing lighting for public places in such designated region, including streets and highways, that disposes of more than 10 spent lamps per month shall arrange for disposal of such lamps at appropriately permitted reclamation facilities; provided, however, that before such rule is adopted, the secretary of the department first determines that appropriately permitted reclamation facilities are reasonably available and afford sufficient recycling capacity.
Factsheet interpretation:
Because of this, these types of spent lamps, excluding those from households, containing any amount of mercury have
been banned from solid waste incineration since July 1, 1994, in any quantity. Since most of these types of lamps contain
hazardous levels of mercury, they should not be disposed of at solid waste landfills in Florida if more than 10 lamps per
month are generated by a business from any one location. Local solid waste departments are the final authority for landfill
disposal and may decide to refuse to accept any spent lamps from generators, regardless of the amount of mercury
contained in the lamps.
Florida businesses and governmental facilities generating spent fluorescent and HID lamps ("Generators") have two
options for managing them: either recycling or landfill disposal.
1) You are encouraged to recycle fluorescent and HID lamps, even those with lower mercury content, by following the
Chapter 62-737, Florida Administrative Code regulations outlined in this fact sheet. Hazardous waste lamps destined
for recycling and managed in accordance with these regulations are considered to be universal wastes in Florida and
do not count toward your facility's hazardous waste generator status. Check with the receiving storage or recycling
facility for its guidelines on packaging and transportation. A list of recycling facilities in Florida can be obtained by
calling 1-800-741-4337. RECYCLING IS THE RECOMMENDED MANAGEMENT OPTION FOR ALL LAMPS!
2) (a) Generators of 10 or less spent lamps per month per location may dispose of these lamps with the regular trash
going to a permitted, lined solid waste landfill. Low mercury, non-hazardous waste spent lamps may also be
disposed of at permitted, lined solid waste landfills in any quantities. However, contact your local solid waste
management department for any final guidance or restrictions on the landfill disposal of these lamps.
(b) If more than 10 spent hazardous waste lamps are generated per month, they may be disposed of at a permitted
hazardous waste landfill and would count toward your facility's hazardous waste generator status.
-----Original Message-----
From: sqg-program-bounces at lists.dep.state.fl.us [mailto:sqg-program-bounces at lists.dep.state.fl.us] On Behalf Of Perrigan, Glen
Sent: Friday, July 13, 2007 1:53 PM
To: Nottingham, Dale L.
Cc: Sqg-program at lists.dep.state.fl.us
Subject: RE: [Sqg-program] FW: mercury-containing UV lights from ACunits -SQGinspector awareness
The less than 10 lamps disposal is outlined in Florida law. See 403.7186(4), Florida Statutes (http://www.leg.state.fl.us/statutes/index.cfm?StatuteYear=2006&AppMode=Display_Results&Mode=Search%2520Statutes&Submenu=2&Tab=statutes&Search_String@3.7186
Additional information on lamps and mercury containing devices can be found
at http://www.dep.state.fl.us/waste/categories/mercury/default.htm
-----Original Message-----
From: Nottingham, Dale L. [mailto:NOTTINDL at leegov.com]
Sent: Friday, July 13, 2007 11:59 AM
To: Perrigan, Glen
Subject: RE: [Sqg-program] FW: mercury-containing UV lights from ACunits -
SQGinspector awareness
Lee County has also been inspecting the tanning salons for quite awhile. The management of these places turns over so quickly, that very few actually manage the waste properly. Apparently they don't teach management of hazardous waste in the cosmetology schools either. We teach an awareness class at our local Vo-Tech school and have had better results from the graduates once they get in the field. The key to their compliance is to start early on education and be consistent with them.
I still have not seen the 10 or less "rule" in the final version of Mercury Containing Lamp/Device regulation that I sometimes hear quoted from regulatory agencies. It may be a "policy", but not the rule. I know it was in the interim rule a long time ago, but was removed from the final rule. Some day maybe folks will realize we live in FLORIDA and that maybe tanning salons should go away!
Everyone should look at the Florida wide study performed on salt and fresh water fish to see the results of the mismanagement of mercury containing lamps/devices. It helps on inspections to tie the source, to the problem. Once you show how it does impact the environment, the target audience tends to grow and become more aware of their actions.
-----Original Message-----
From: sqg-program-bounces at lists.dep.state.fl.us
[mailto:sqg-program-bounces at lists.dep.state.fl.us] On Behalf Of
Perrigan, Glen
Sent: Friday, July 13, 2007 11:19 AM
To: Sqg-program at lists.dep.state.fl.us
Subject: FW: [Sqg-program] FW: mercury-containing UV lights from ACunits
* SQGinspector awareness
Hi All
Are you routinely inspecting tanning salons during your sqg program
verifications? Please respond to all on this post. Thanks. Glen Perrigan
-----Original Message-----
From: Jerry Palmer [mailto:jpalmer at scgov.net]
Sent: Tuesday, July 10, 2007 7:53 AM
To: Perrigan, Glen
Subject: Re: [Sqg-program] FW: mercury-containing UV lights from ACunits
-
SQG inspector awareness
Interesting info. The first I've heard of it. Glen, I'm also a little curious about other counties and their approach to tanning salons. We've inspected them for, oh....probably 7 to 8 years now. Each bed has on average 32 lamps that are changed a couple times a year. Most salons have at least 4 beds. That's pushing an average of 300 lamps per year per location, and when we started inspecting them NONE were recycling their lamps.
Do you know if other locales are routinely inspecting tanning salons?
Thanks,
JP
>>> "Perrigan, Glen" <Glen.Perrigan at dep.state.fl.us> 7/9/2007 3:59 PM
>>>
Hi All,
I want to pass this info along regarding UV lights (containing mercury) used in HVAC systems. They are used as bio filters in some HVAC systems. You might come across these in your sqg verifications (i.e. hospitals). These lamps contain mercury just light any other fluorescent lamp and should be managed as a universal waste. I found an EPA site with some studies of these lamps.
http://www.epa.gov/nhsrc/news/news062606.html
Glen Perrigan
Florida Department of Environmental Protection
Hazardous Waste Management Section
2600 Blair Stone Road MS-4555
Tallahassee, Florida 32399-2400
850-245-8749 Fax: 850-412-0528
E-mail: glen.perrigan at dep.state.fl.us
Website: www.dep.state.fl.us/waste <http://www.dep.state.fl.us/waste>
_____
From: Price, John L.
Sent: Friday, July 06, 2007 9:49 AM
To: Perrigan, Glen
Cc: Nottingham, Dale (nottindl at leegov.com); Tenace, Laurie
Subject: FW: mercury-containing UV lights from AC units - SQG
inspector
awareness
Glen: Looks like something other SQG programs ought to know about since Dale is seeing them in his county [thanks, Dale!]. Another type of mercury-containing lamp that inspectors should be aware of. Maybe a short item/case study for next year's SQG workshop?
John L. (Jack) Price
Environmental Manager
Hazardous Waste Management MS 4555
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Phone:850.245.8751
Fax: 850.245.8811
john.l.price at dep.state.fl.us
www.dep.state.fl.us/waste
Please Note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. Your e-mail is communications and may therefore be subject to public disclosure.
_____
From: Nottingham, Dale L. [mailto:NOTTINDL at leegov.com]
Sent: Monday, July 02, 2007 2:19 PM
To: Price, John L.
Cc: Cauceglia, Dorian ; Coles, Jayne M.; Girard, Edgar; Girard, Tina
M.;
Saiya, Jacqueline ; Ott, Bryan
Subject: RE: Lee County inquiry: recycling UV lights from AC units
Yes they need to be treated as a Universal Waste just like any other mercury containing lamp. They are more common for mold and mildew treatment in the Northern states, but I have seen them popping up in our County.
_____
From: Price, John L. [mailto:John.L.Price at dep.state.fl.us]
Sent: Monday, July 02, 2007 12:09 PM
To: Tscherteu, Erich P.
Cc: Tenace, Laurie; Gleason, Irene; Atkeson, Thomas; Axelrad, Don;
Clarke,
Raoul; Cifrino, Carole A; Griffith, John
Subject: Lee County inquiry: recycling UV lights from AC units
Hi, Erich: Just had a call from Bill Bosco [Haines AC, Bonita Springs 239.992.1551] about disposing of UV lights from AC systems. The UV lights contain mercury and are used somewhere in the air flow system (usually intake before the coils, sometimes downstream of the blower). Bill said that they are becoming more and more common in AC systems to control/reduce the build up of mold in the duct system or on the coils. First I have heard of UV lights in AC for disinfection purposes. I have heard of them being used to disinfect water from wells.
I told him about the incineration prohibition and that Lee County solid waste went to a combustor so he could not throw them into the trash. I advised Bill to contact you to see whether your recycling program could help him since he estimated that they would have maybe 10 of these lamps, max, in a couple of month period. I did say that if you could help him, there would probably be a pass through charge. He is primed to recycle since he is a transplant from Maine approx 10 years back and knows how serious Maine is about environmental protection.
Hope all is going well, Jack.
John L. (Jack) Price
Environmental Manager
Hazardous Waste Management MS 4555
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Phone:850.245.8751
Fax: 850.245.8811
john.l.price at dep.state.fl.us
www.dep.state.fl.us/waste
Please Note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. Your e-mail is communications and may therefore be subject to public disclosure.
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