When can an MRW facility crush CESQG / HHW fluorescent lamps? *Many Moderate Risk Waste (MRW) facilities collect fluorescent lamps from conditionally exempt small quantity generators (CESQGs) as well as from households. Some MRW facilities are exploring the idea of crushing lamps on-site prior to sending them off-site for final management.
CESQG and Household Hazardous Waste (HHW) are regulated differently. CESQGs have different options to manage their waste lamps. CESQGs can choose to direct their waste lamps to the following types of facilities:
General InformationUniversal waste is a category of dangerous waste.
Fluorescent lamps are a type of universal waste lamp [WAC 173-303-573(5)].
Lamps generated from households are excluded from being regulated as dangerous waste [WAC 173-303-071(3)(c)] or universal waste.
Lamp Crushing: Universal Waste LampsIf waste lamps are received by an MRW facility as UW, no crushing would be allowed. Crushing is considered treatment in relation to lamp management. For an MRW facility to accept and crush UW lamps, they would need a Treatment, Storage, Disposal (TSD) permit.
Why is a TSD permit required?
Once the generator has claimed their waste to be UW, the waste must maintain that status until it gets to a final UW destination facility (grave). An MRW facility can become a UW destination facility that crushes lamps as a form of treatment, however, they would need to keep managing UW as UW and receive a TSD final facility permit [173-303-573(35)(a)].
If an MRW facility wishes only to collect, not treat, UW, they would need to notify the Department of Ecology and obtain an EPA ID# as a large quantity handler of UW “before meeting or exceeding the 11,000 pound storage limit of all UW other than lamps and/or before meeting or exceeding the 2,200 pound storage limit for lamps” [WAC 173-303-573(19)]. This assumes the facility would exceed the storage limit to qualify as a small quantity handler.
Only permitted UW destination facilities are the permitted grave where CESQG UW handlers / generators can send their universal waste for treatment [173-303-070(8)(b)(iii)(H)]. In this circumstance the waste is not managed, counted, etc. as DW at the point of generation.
Lamp Crushing: CESQG Waste Lamps Managed as Dangerous WasteIf an MRW facility collects lamps from CESQGs as DW, the MRW facility would be allowed to crush those lamps if the crushing activity is identified in their WAC 173-350-360 solid waste permit and if the MRW facility obtains a generator ID number from the Department of Ecology.
Permitted MRW facilities are the permitted grave where CESQGs can send their dangerous waste [173-303-070(8)(b)(iii)(C)]. In this circumstance the waste is managed, counted, etc. as DW at the point of generation, which does not put the CESQG out of compliance with the DW regulations.
Lamp Crushing: Household Hazardous Waste LampsAs mentioned above, lamps generated from households are excluded from being regulated as DW. An MRW facility would be allowed to crush lamps generated from households, provided the facility was permitted under their WAC 173-350-360 solid waste permit for that activity.
As with other wastes managed at MRW facilities, waste lamps from households may be crushed and then combined with lamps crushed and managed as DW from CESQGs.
Questions?For questions about the Dangerous Waste Regulations, contact Tom Cusack at (360) 407-6755.
Need more information about requirements for Universal Waste Handlers?These publications are available from the Internet:
Universal Waste Rule for Batteries and Mercury-Containing Thermostats
Universal Waste Rule for Dangerous Waste Lamps.
Definitions:CESQG Conditionally Exempt Small Quantity Generator
DW Dangerous Waste
HHW Household Hazardous Waste
MRW Moderate Risk Waste
TSD Treatment, Storage, Disposal
UW Universal Waste
*NOTE: The answers provided to Frequently Asked Questions are guidance for implementing WAC 173-350-360. Following this guidance is not a requirement of operation or design for MRW facilities, as facilities may meet regulatory requirements through other means. Local Health Departments should be consulted to determine what will be sufficient to meet the regulatory standards.
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