RCRA Closure of Lamp Crushing Operations

In 2009, the national headquarters of an insurance company purchased a commercial lamp crusher as part of a company-wide “Green” initiative. Lamps that were generated from routine replacement of light fixtures throughout the office building complex were crushed onsite prior to periodic disposal as hazardous waste (D009). Following a State compliance evaluation inspection, the company was cited for violation of hazardous waste rules, including operation of an unpermitted treatment, storage and disposal facility (due to storage at large quantity generator volumes for greater than 90 days). To abate the violations, the State agency required RCRA closure of lamp crushing operations through Director’s Final Findings and Orders.

Cox-Colvin assisted with negotiation of the Orders and prepared a closure plan for final closure of the unit. The State agency and the company feared that mercury from crushing activities had been released and spread throughout the building. Following approval of the closure plan, unrestricted clean closure was achieved through removal and disposal of remaining crushed lamps and the lamp crusher, followed by confirmation sampling. One of 14 wipe samples from three different indoor surfaces contained mercury above background concentrations. A performance-based decontamination of the indoor surface was conducted by Cox-Colvin using a water-soluble powder which reacts with mercury to form a non-hazardous non-vaporizing sulfide. Following certification by Cox-Colvin, a return-to-compliance letter was issued by the State agency. The company now manages lamps under the States universal waste program.

Outcome and Benefits

  • Rapidly obtained unrestricted clean closure by removal and a return to compliance determination
  • Use of a performance-based decontamination approach eliminated the need for additional confirmation sampling following decontamination
  • No additional post-closure requirements.