Technical briefs

Lamp and ballast disposal

Technical Brief #97-004

Lamps and ballasts removed as part of a lighting system upgrade or as part of normal maintenance may be a hazardous material. Government regulations, health and safety issues, and environmental concerns dictate that lamps and ballasts be disposed of properly. This Technical Brief provides guidance on the benefits and costs of proper lamp and ballast disposal, hazardous waste regulations, handling guidelines, disposal options, and economics.

Why is proper disposal important?

Old ballasts manufactured through 1979 and those without a "No PCBs" label should be assumed to contain polychlorinated biphenyls (PCBs). The capacitor in a ballast may contain two to three ounces of PCBs. Potting compound (used to dissipate heat from electrical components in the ballast) may be made of waste oil contaminated by PCBs. Workers exposed to PCBs may develop skin disorders, nausea, dizziness, bronchitis, liver damage, or adverse reproductive effects. Longer exposures can cause cancer. One of the replacements for PCBs used between 1979 and 1984 is DEHP. DEHP is classified by EPA as a probable human carcinogen. Lamps may contain small quantities of mercury, lead, cadmium, sodium, and radioactive materials. When lamps and ballasts are improperly disposed of, these chemicals can leak into the environment and contaminate water supplies and eventually work their way up the food chain, affecting people. The owner of old lamps and ballasts is responsible for their proper handling and disposal. Given the liability this responsibility brings, it is important for the owner to be well informed.

What do regulations require?

The Toxic Substances Control Act of 1976 (TSCA) bans the manufacture and distribution of PCBs and regulates disposal and storage. TSCA requires that leaking PCB ballasts not be stored on site over 30 days or in more than 10 drums at a time and that they be disposed of in a hazardous waste incinerator only. "Large quantities" of ballasts should be disposed of at hazardous waste incinerators or chemical waste landfills. The regional EPA office serving the Pacific Northwest defines a large quantity as five or more ballasts per year. Check with your regional EPA office to determine their definition of a "large quantity."

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund Law) provides for extensive liability for improper hazardous waste disposal practices. Liability can extend to individuals within an organization that knowingly direct the improper disposal of hazardous waste. Anyone disposing of more than one pound of PCBs or mercury in any landfill is a Potentially Responsible Party in any subsequent Superfund cleanup of the landfill. DEHP is reportable at quantities of 100 pounds. Proper disposal is the best protection against future liability.

Resource Conservation and Recovery Act (RCRA) regulates many hazardous wastes, including lead, sodium, and mercury, but not PCBs. To be fully regulated by RCRA, more than 100 kilograms (about 220 pounds, including entire lamps and any other hazardous materials) of hazardous material must be generated in a month. In addition, one of the regulated substances must be present above a specified concentration in leachate produced by the Toxic Characteristic Leachate Procedure. This test can cost several hundred dollars. If less than 100 kilograms per month of hazardous waste is generated, the waste generator is classified as a conditionally exempt small quantity generator, and minimal RCRA regulations apply. EPA is planning some deregulation options that ease some of the lamp disposal requirements.

Some jurisdictions have more stringent lamp and ballasts disposal regulations than the Federal requirements. It is important to check with local authorities to be sure of the requirements in your area.

What guidelines should be observed?

Ballasts

When removing ballasts, wear protective gear and dispose of it along with the ballasts. Be careful not to drop any ballasts, possibly causing them to leak. Ballast disposal workers must be provided with special education about hazardous waste handling, and a materials data safety sheet must be available at the site. When moving non-leaking ballasts within a building, a cardboard box can be used. Do not overload the boxes and risk dropping the ballasts and causing a potential PCB leak. If more than one pound of PCBs (the amount contained in 12-16 ballasts) is spilled, it must be reported to the EPA National Response Center and cleaned up according to EPA procedures. A typical 55-gallon drum will hold 150-300 ballasts from four foot fixtures or 60-100 ballasts from eight foot fixtures and will weigh 600-1000 pounds. For exact packing instructions, contact the disposal facility that you plan to ship the ballasts to. Non-leaking ballasts must be disposed of within one year of being removed from the fixture.

Any leaking ballasts, along with any other materials that come in contact with the PCB oil, should be put into a double plastic bag and packed in a separate steel drum. Drums of leaking ballasts should bear a yellow "Caution: Contains PCBs" label. All drums should be clearly labeled. For leaking PCB ballasts, you must use a Federal Uniform Hazardous Waste Manifest or an equivalent state manifest. Less then 12-16 ballasts is not a reportable quantity, so a manifest may not be required. It is best to leave the handling of leaking ballasts to a hazardous waste contractor or lighting maintenance firm that is specially trained to do so. Contact your state environmental agency for assistance.

Lamps

Lamp recyclers generally require that lamps arrive unbroken. This can usually be accomplished by inserting old lamps into the boxes that the new lamp came in. If a lamp breaks, ventilate the area well and clean up with minimal dust generation. Use safety glasses, goggles, or face shields as well as a respirator. Lamp disposal workers must be provided with special education about hazardous waste handling, and a materials data safety sheet must be available at the site.

What disposal options are available?

Select disposal and recycling vendors carefully, remembering that the waste generator is always liable regardless of who else is involved. In selecting a service, make sure they know all the regulations, have the necessary state and local permits and licenses, and have no past violations on file with EPA.

Municipal waste landfills and waste incinerators are popular because of their low cost (10-20 cents per ballast and 2-3 cents per lamp) These facilities are not designed to handle hazardous waste and are not recommended. Leaking ballasts are prohibited from disposal in such a facility. Disposal of non-leaking ballasts in such a land fill must be reported to the National Response Center and may violate local interpretations of Federal regulations. Some liability may exist if the landfill becomes a Superfund site.

Hazardous waste landfills are acceptable for non-leaking ballasts and are relatively inexpensive; roughly 50 cents per ballast and 25 to 50 cents per lamp plus packing, transportation and profile fee. Leaking ballasts cannot be brought here. Some liability may exist if the landfill becomes a Superfund site. EPA recommends that the slightly more specialized chemical waste landfill be used.

Hazardous waste incinerators destroy PCBs permanently and have strict monitoring requirements. This minimizes any Superfund liability. However, this approach is expensive (about five dollars per ballast plus shipping and handling) and generates air pollution and is energy intensive because ballasts do not burn easily.

Ballast recycling facilities remove and properly dispose of the PCB-contaminated parts of the ballast and recycle the remaining materials. Over 80 percent of the ballast is recyclable by weight. The cost is about $3.50 per ballast plus shipping and handling. This is the most environmentally friendly approach.

Lamp recycling facilities charge six to twelve cents per foot, depending on transportation and quantity. High intensity discharge lamps cost about one to two dollars to recycle. Almost 100 percent of the materials in lamps can be recycled.

Processing hazardous waste on site is not recommended. Besides the serious health and environmental hazards, permits may be required and in some states this may be prohibited. Community hazardous waste drop-off sites may be a convenient option for small quantities of hazardous waste. Treatment, storage and disposal facilities can provide complete waste disposal services for a fee and may be worth it for small waste generators. Leaving old ballasts in place or storing them on site is not recommended because they may leak at any time, requiring a costly cleanup.

What are the economics of proper disposal?

Some proponents of energy conservation are concerned that the costs of ballast and lamp disposal may discourage the replacement of old lighting systems with newer energy efficient equipment. However the total cost of disposing or recycling lamps as hazardous waste is roughly two percent of its life cycle cost. Disposal costs generally do not extend the payback of a project more than three to four months. Furthermore, the environmental risks of disposing of the old ballasts are trivial compared to the risks of leaving them in the building and the environmental impacts associated with generating the additional electricity to operate old, inefficient lighting systems.

Western Energy Services

Western’s Energy Services Program offers customers information, resources and solutions to improve their energy efficiency, use of renewable energy, and competitive positions. For additional information about lamp and ballast disposal or any other commercial, industrial, agricultural or residential technologies, programs or products, just:

• call The Power Line Hotline at (800) 769-3756
• link to the Energy Services Web site or the Energy Ideas Clearinghouse Web site
• E-Mail your question to Power Line, or
• fax to (360) 586-8303

Acknowledgment: This technical brief was produced by the Washington State University Cooperative Extension Energy Program. It was adapted from the Technology Update "Lamp and Ballast Disposal" (CH-51) funded by the Bonneville Power Administration.