Proposed code of practice for management of end-of-life lamps containing mercury: chapter 8


8. Processing

Lamp processing should maximize the recovery of lamp materials while preventing releases of mercury to the environment and minimizing risks to human health. This involves crushing the lamps and separating the component parts (glass, metal, mercury phosphor powder) in sealed chambers and processing units equipped with pollution control devices (e.g., mercury vapour and dust and/or mercury-contaminated waste water capture systems) to prevent the release of mercury to the environment.

Whole lamps are transferred by a conveyor into an enclosed and sealed container or chamber for first-stage crushing. Then the material goes through a ferromagnetic separator, which separates the metals from the other materials. The metal is crushed or shredded further to prepare it for secondary (i.e., recycled or scrap) markets. The glass and mercury phosphor powder are separated by a ventilation system that consists of cyclones and filters. The glass then goes through a second-stage crusher. The glass may need further treatment to remove any traces of mercury before it can go directly to secondary markets. A thermal separation process separates the mercury and the phosphor powder by applying high levels of heat that vaporize the mercury. The mercury can then be condensed into liquid form. The separated phosphor powder is prepared for secondary markets. The mercury, however, must be purified through a distillation process before being reused or stored as elemental mercury.

The following are best practices for processing of end-of-life mercury-containing lamps.

Activity

Best Practices

Documentation and record keeping
  • The equipment and processes (e.g., air separation of mercury-phosphor powder, mechanical crushing to separate lamp components) should be defined and documented. A mass balance recording may be kept and audited. A mass balance recording indicates the amount of mercury entering the processing system versus the amount that is recovered. 
  • Documentation and record keeping to show proof of safe operations and environmentally sound practices (e.g., employee health and safety program and records, and environment and labour inspection reports) and proof that the facility and its operations meet all requirements. Record keeping should also track and reconcile units received and processed. Records should be kept for a minimum of five years, unless otherwise specified by federal, provincial, or territorial regulations or requirements. See sections 6 and section11.
  • Under provincial requirements, the processor may be required to demonstrate its recovery rate (materials recovered versus those lost to disposal) for lamps and lamp packaging material received. The processor may also be required to maintain and make available upon request all documentation, waste diversion methodology, and explanations about how the diversion rate was achieved.
Insurance
  • The processor should have insurance as required by provincial or territorial requirements, which could include comprehensive or commercial general liability covering bodily injury, property damage, environmental damage, complete operations and contractual liability appropriate to the size and type of operation. The scope of the coverage could also cover associated transportation and liability for program operators, overseers and regulators. Small operators could find that Environmental Impairment Liability insurance is appropriate for their operations. Processors could have a written statement from a licensed insurance broker or agent to confirm that the insurance policy and levels of coverage are appropriate for the size and type of operation.
Restricted access
  • Access to the processing facility should be controlled and monitored, and unauthorized access should be prohibited with appropriate security measures (e.g., restricting access to authorized personnel, locking access points, installing surveillance device(s) as appropriate).
Processing and separation
  • Materials should be separated from other products or material types for efficient processing.
  • Separation or processing activities, performed either manually or mechanically, should take place in a sectioned-off area or room with a ventilation system that is self-contained or completely separate from the general building ventilation system.
  • Lamp processing should be undertaken under a negative pressure environment to prevent mercury emissions to the environment.
Ventilation
  • The ventilation system for the processing room(s) should be monitored regularly to ensure that it is operating efficiently, and it should also be equipped with:
    • an emission control system designed to prevent environmental emissions of, and minimize worker exposure to, toxic substances and particulate matter to above applicable regulatory requirements; and 
    • a means to recover mercury as liquid, vapour, airborne particles and/or compound, from the exhaust air flow recovered from the processing rooms, so that the treated air complies with legislation and regulatory limits before being released into the environment. Contaminated air should not be diluted with fresh air as a way to lower the final concentration levels to below regulatory limits.
Air testing
  • Mercury concentrations in the air of work and non-work spaces in the facility should be regularly measured and monitored.
  • Air sampling and testing should be performed by competent and qualified personnel trained to perform air sampling tests, at a frequency and in locations as identified according to a risk assessment.Footnote14 This ensures that releases of pollutants, such as mercury, mercury vapour and phosphor powder, are kept within allowable limits as per provincial and territorial requirements. Risk assessments should be performed by qualified persons. The results of these tests should be kept in a central registry for five years, unless otherwise specified by federal, provincial, or territorial regulations or requirements.
Waste water
  • All water used for washing phosphor from processed lamps or related materials and contaminated waste water from the washing of storage and processing containers, equipment, rooms or facilities should be collected and monitored to prevent and control environmental releases of mercury and as per federal, provincial and territorial requirements.
  • Contaminated waste water may be classified, by legislation, as hazardous and/or industrial liquid waste, and may be subject to regulatory and management requirements. Contaminated waste water should be recovered and treated, as necessary, so that it complies with legislation and regulatory limits before being released into the municipal waste water or the environment. Contaminated water should not be diluted with clean water or other liquids as a way to lower the final concentration levels to below those of regulatory thresholds. Closed-loop water cleaning/filtering systems should be installed.
Equipment design and operation
  • Equipment and machinery used for lamp crushing or processing should:
    • be equipped with a system to collect mercury vapour or airborne mercury-containing particles;
    • be designed so that under normal conditions of operation, mercury in vapour or liquid form, phosphor powder, or other materials of concern cannot escape from the equipment and be released into the surroundings or the environment;
    • be designed so that all mercury, phosphor powder or other material of concern accumulated in the equipment can be removed and recovered safely; and
    • include a means to recover mercury vapour and mercury phosphor powder from the exhaust air flow and waste water collection equipment or system. Contaminated air or water should not be diluted with clean air or water as a way to lower the final concentration level to below that of regulatory limits.
  • Equipment and machinery used for lamp processing should be operated and maintained according to specifications and applicable regulations at all times.
  • Equipment and machinery used for lamp processing should be operated and maintained by trained operators and technicians.
Maintenance and inspection
  • Maintenance and cleaning should be:
    • performed by trained personnel;
    • performed according to the equipment manufacturer’s instructions and recommendations; and
    • recorded in a maintenance registry.
  • The maintenance registry should include:
    • description of the maintenance work that has been performed;
    • location where the maintenance was performed;
    • date of the maintenance work;
    • name of the person who performed the maintenance; and
    • records for the five years prior to the date of the last record, unless otherwise specified by the jurisdiction in which the facility operates.
  • Inspection protocols should be implemented on a regular basis to ensure compliance with provincial and territorial requirements.
Consumables
  • Consumables or disposable parts, such as filters for equipment, machinery or the ventilation system, that are contaminated with mercury should be managed in compliance with applicable federal, provincial and territorial regulations and requirements. Contaminated consumables may be considered hazardous waste, depending on the level of contamination.
Facility closure or decommissioning plan
  • Processors should have a facility closure or decommissioning plan, which should contain details on how the processing of mercury-containing lamps will be discontinued, and/or how the facility will be decommissioned. The plan should describe how it will be funded to ensure that the tasks and risks (e.g., major pollutant releases) are adequately financed, such as with a security or performance bond. The plan should include provisions for long-term monitoring and future use of the site in accordance with provincial and territorial requirements.
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