Mercury in Fluorescent Lamps: Environmental Consequences and Policy Implications for NRDC

Carolyn Dunmire, Chris Calwell, Andria Jacob, My Ton, Travis Reeder, and Vicki Fulbright

FINAL REPORT This paper was prepared by Ecos Consulting for the Natural Resources Defense Council (NRDC). The opinions expressed herein are those of Ecos Consulting, and do not necessarily represent NRDC policy on the subject. May 30, 2003

Table of Contents
Table of Contents............................................................................................................ 2 Executive Summary ........................................................................................................ 3 I. Introduction................................................................................................................. 8 II. Overall U.S. Mercury Emissions and Fluorescent Lamp Contributions .................... 9 The Role of Mercury in Fluorescent Lamps ................................................................. 11 Can Mercury in Fluorescent Lamps and Other Products be Further Reduced? ........... 13 Do Fluorescent Lamps Provide a Net Emissions Benefit? ........................................... 16 The Special Case of CFLs............................................................................................. 19 III. Lamp Disposal and Mercury Emissions ............................................................... 20 Mercury Contained in Spent Lamps ............................................................................. 22 Mercury Releases from Spent Lamps in Transport (to Landfills) ................................ 23 Mercury Releases from Spent Lamps in Landfills ....................................................... 25 Mercury Releases from Incineration............................................................................. 26 Mercury Releases from Recycling Fluorescent Lamps ................................................ 26 IV. State Actions ......................................................................................................... 27 Minnesota...................................................................................................................... 27 Vermont ........................................................................................................................ 28 Pacific Northwest: Washington and Oregon................................................................. 29 V. Findings, Conclusions, and Recommendations ........................................................ 30 Findings......................................................................................................................... 30 Conclusions and Recommendations ............................................................................. 32 Appendix A Assumptions and Sources for Figure 6 ................................................. 35

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Executive Summary
This technical review was undertaken at the request of the Natural Resources Defense Council (NRDC), which is in the process of developing of a public policy position related to the recycling of mercury from compact fluorescent lamps (CFLs). The opinions expressed herein are those of Ecos Consulting. The hazards associated with mercury emissions in the environment are profound and well understood. Efforts to control mercury exposure and release into the environment have a strong public policy justification, prompting interest in how best to achieve the greatest environmental benefit with limited resources. While indisputably more energy efficient than their incandescent counterparts, fluorescent lamps contain mercury, which is essential to their operation. Though the lighting industry has achieved significant reductions in mercury content per lamp, there is no likely near-term prospect for finding mercurys substitute in fluorescent lighting. Therefore, questions have been raised about the need to carefully handle and recycle mercury from fluorescent lighting. It is clear that the mercury in linear fluorescent lights can be readily recycled. These lamps can be easily handled and transported unbroken to recycling facilities and, since a large percentage of such lamps are used by commercial facilities, their collection and recycling can be done very cost effectively. In fact, recycling companies in many states are already successfully recycling the mercury in linear fluorescent lamps, and those efforts should be encouraged and expanded. By contrast, CFLs come in many shapes and sizes and are used predominantly in residential settings. They have attached electronic ballasts and are rarely concentrated in large numbers in a single facility. All of these factors complicate the practicalities of safely collecting, transporting, and recycling their mercury. Stakeholders disagree about the science needed to inform the debate, including the fraction of mercury in a spent lamp that is available for release into the environment, the degree to which landfills can safely contain mercury waste, and the extent to which research performed on linear fluorescent lamps can usefully inform policy debates over CFL recycling. After assessing the many sides of the above controversies, these are our principal findings (citations for each are found in the full report): 1) Of the total amount of U.S. anthropogenic mercury released into the environment per year, we estimate that the share contributed by fluorescent lamps is 0.6% to 1.1%. Compact fluorescent lamps currently represent about 1% to 2% of mercury emissions from fluorescent lamps, and therefore 0.006% to 0.002% of gross total U.S. mercury emissions. Because total fluorescent lamp mercury emissions are declining and CFL sales are increasing relative to total fluorescent lamp sales, CFLs share of the total mercury found in all lamps is likely to rise over time, but only modestly so.

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2) Total fluorescent lamp mercury emissions are declining over time as a result of five factors: declining average amounts of mercury used in the manufacturing of each new lamp; growing market preference for thinner lamps with greater energy efficiency and lower average mercury content; increasing recycling rates for linear fluorescent lamps; increasing stringency of mercury control at incinerators; and new state regulations that prohibit fluorescent lamps from being discarded in landfills or incinerators (also reducing breakage during disposal). 3) The vast majority of fluorescent lighting substitutes for less energy efficient lighting alternatives, namely incandescent lamps. As a result, fluorescent lighting prevents substantial mercury emissions at coal-fired power plants, which account for about 55% of total U.S. electricity production. Figure ES-1 below illustrates the profound impact of the amount of coal-fired generation on the net mercury impact of fluorescent lamps. It dwarfs the impact of changing assumptions about the amount of mercury contained in a fluorescent lamp or the fraction of that mercury that is released upon lamp breakage (represented by the thickness of the CFL and T8 lines). Figure ES-1
How the Fraction of Electricity Generated by Coal Influences Whether Fluorescent Lamps Reduce or Increase Net Mercury Emissions
10

Sections above the horizontal line indicate a net increase in mercury emissions from the use of fluorescent lamps
(lamp disposal emissions minus prevented power plant emissions) 0

Net Milligrams of Mercury Released

-10

CFLs
-20

T8s
-30

-40

-50

-60

National Average

-70
0% 10%
Anchorage, AK=14%

20%

30%
Portland, OR=24%

40%

50%

60%

70%
Atlanta, GA=67%

80%

90%
Cleveland, OH=93%

100%

Washington, DC=47%

Fraction of Electricity Generated from Coal

Source: Ecos Consulting and www.epa.gov/cleanenergy/powerprofiler.htm

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4) Fluorescent lamps also prevent the emissions of substantial quantities of greenhouse gases and other air pollutants, reduce consumer energy bills, and last far longer than incandescent alternatives. Thus the net benefits of fluorescent lamps to society are substantial, even in parts of country with minimal reliance on coal-fired power. 5) Once purchased, fluorescent lamps face a variety of different fates, ranked below (Table ES-1) in order from highest to lowest net release of mercury to the environment: Table ES-1 Independent Impacts of Lamp Age at Failure, Handling Conditions, and Ultimate Fate of Fluorescent Lamps on Their Overall Mercury Impact1
Lamp Age at Failure Accidentally broken when new (no power plant emissions prevented, nearly all bulb mercury released) Fails before design life Achieves design life Exceeds design life Greatly exceeds design life (maximum power plant emissions prevented, most bulb mercury bound to glass or metal) Source: Ecos Consulting Handling Conditions Broken indoors (maximum health risk) Broken in open, leaky dumpster (high risk of air and water pollution) Broken in transport or on landfill surface (some pollution likely) Broken after burial in lined landfill (most mercury contained) Broken inside recycling chamber (nearly all mercury recovered) Ultimate Fate Incinerator (some mercury released to air) Unlined landfill (potential for air and water pollution) Lined, monitored landfill Hazardous waste landfill Recycling facility (nearly all mercury recovered) Environmental Impact Highest Moderately High Moderate Moderately Low Lowest

6) There are two key activities to discourage with fluorescent lamps. The first is their breakage, especially when new. Once a fluorescent lamp has operated for something close to its design life, the net mercury benefits achieved are significant, even if the lamp is discarded. Likewise, fluorescent lamp incineration should be actively discouraged whenever possible, since it puts much of the remaining mercury back into the air where it is likely to cause maximum environmental impact. RECOMMENDATIONS: On the basis of these conclusions, Ecos Consulting makes the following conclusions and policy recommendations to NRDC:

Note that each column represents an independent type of environmental impact. So, for example, incineration represents the most environmentally harmful ultimate fate of a fluorescent lamp regardless of the lamps age or how it is handled after failure. Final Draft Page 5 5/30/2003

1)

Assigning producer responsibility for mercury makes less sense for CFLs than for other products. There are generally strong economic and environmental advantages to making manufacturers responsible for recycling or safely disposing of products at end-of-life. However, CFLs represent a special case, because they not only tend to prevent more mercury emissions than they cause, but they are also more challenging and costly to recycle than other products that prevent mercury emissions like linear fluorescent lamps. Policy measures that raise CFLs cost could reduce net environmental benefits to society, even if they increase CFL recycling rates. Mercury labeling schemes for consumer products, if pursued, should be specific and quantitative. Source reduction has obvious advantages and reasons to be encouraged, and it would increase the net benefits fluorescent lamps already provide. However, mercury-labeling schemes proposed so far do little to encourage best practice, (in the form of reduced mercury content) because they do not contain adequate information. To the extent products are labeled as containing mercury, they should quantitatively state how much they contain, so products containing the lowest mercury can gain a decisive market advantage with customers seeking to minimize environmental impact. CFL recycling appears to be a very expensive way to recapture small quantities of mercury. While recycling compact fluorescent lamps reduces environmental impacts relative to discarding them, such programs should be considered in a broader context of overall environmental impact and cost effectiveness. Namely, which policies and programs can keep the most mercury out of the environment for the least money? As Figure ES-2 below indicates, some consumer products contain large amounts of elemental mercury, and represent obvious candidates for exchange and recycling programs. Linear fluorescent lamp recycling and implementing control measures at coal-fired power plants also appear to be relatively cost-effective policy options. By contrast, CFL recycling appears to be a very expensive way to recapture small quantities of mercury that may be more than offset by mercury reductions upstream at the coal-fired power plant. Reward Source Reduction. NRDC should support state and federal policies that allow lamps below a certain mercury-content threshold to continue to be discarded at properly lined municipal solid waste landfills. This is likely to encourage continued innovation by manufacturers to reduce mercury content, while improving cost effectiveness. By contrast, regulations that require recycling of all mercury-containing products, regardless of the amount they contain, do not reward further source reduction and can be very expensive per milligram of mercury recovered. Consider the merits of a tax on the production or final sale of mercury in extracted, domestically manufactured, and imported products. This would help internalize the environmental costs of mercury, both in consumer

2)

3)

4)

5)

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products and in coal. It would improve the economics of recycling consumer products that contain mercury as well, eventually making it possible for such a process to be internally financed. Finally, it would provide more honest signals to the marketplace regarding the true societal cost differences between coal-fired electricity and cleaner alternatives. While this would raise the first cost premium fluorescent lamps face relative to incandescent lamps, it would increase their lifecycle cost advantage (since increases in coal-fired power costs would increase the value of the electricity saved). In all cases, it is important to consider whether recycling regulations might deter business and household use of compact fluorescent lamps. If so, such rules could be more detrimental to the environment and public health (by discouraging energy savings) than the mercury found in the lamps themselves. The hassle or cost associated with a need to recycle CFLs because of mercury could give tentative consumers yet another reason to switch back to incandescent lamps. Using public utility funds to recycle CFLs may be especially problematic, since it would reduce the money available to fund the more societally beneficial activity of encouraging the products purchase in the first place. Figure ES-2
Range of Cost Estimates per Milligram of Mercury Reducing Measures

70

66.67

60

50 Cost (Cents/mg)

40

30

20 12.00 0.01 to 0.17 0.20 to 1.00 12.89 6.25 0.83 1.20 CFL Recycling

10

Thermometer Auto Sw itch Linear Lamp Air Pollution Recycling Exchange Recycling Control on Coal Plants Measure

Source: Ecos Consulting, see Appendix A

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I.

Introduction

The hazards associated with mercury emissions in the environment are profound and well understood. Mercury pollution contaminates lakes, river, and oceans from various sources. Naturally occurring bacteria then convert this mercury into a methylated form, which then enters the food chain, bioaccumulating in fish. People eat mercurycontaminated fish, which poses threats to the brains and developing nervous systems of children and can harm cardiovascular and immune systems in adults. Mercury contamination is ubiquitous across the United States, and the Federal Centers for Disease Control has estimated that 10% of American women have concentrations of mercury in their blood that exceeds safe levels. Thus efforts to control mercury exposure and release into the environment have a strong public policy justification, prompting interest in how best to achieve the greatest environmental benefit with limited resources. Mercury continues to be used in the manufacturing process of a wide variety of consumer products, so interest has arisen in ways to reduce that usage. Fluorescent lamps, while indisputably more energy efficient than their incandescent counterparts, contain varying amounts of mercury, so have come under increasing environmental scrutiny in recent years. Some of the publicity has been openly negative, like this recent headline in the Seattle Post-Intelligencer: Energy-saving Lights Now an Eco-hazard.2 Some advocacy groups have taken a zero tolerance approach, evidenced in their very names: Ban Mercury Working Group, Massachusetts Mercury Elimination Strategy, New England Zero Mercury Campaign, etc. Some states are moving toward more stringent regulation of mercury-containing lamps, banning landfill disposal entirely and mandating either recycling or management as regular hazardous waste. California has approved a disposal ban on all mercury containing lamps to take effect in 2006 for all generators, which has triggered six other states to follow suit.3 This technical review was undertaken at the request of the Natural Resources Defense Council (NRDC), which is in the process of developing a public policy position related to the recycling of mercury from compact fluorescent lamps (CFLs). The opinions expressed herein are those of Ecos Consulting. Our findings do not constitute NRDC policy on the topic. The stated research objectives were three-fold: To estimate the magnitude of mercury emissions resulting from spent fluorescent lamps (linear tubes as well as screw-in compact fluorescents) To determine whether the promotion of mercury-containing, energy-efficient lighting products should be conditioned upon stronger recycling/disposal policies

Candace Heckman, Energy-saving Lights Now An Eco-Hazard, Seattle Post-Intelligencer, August 27, 2002, from www.seattlepi.nwsource.com. 3 See www.dtsc.ca.gov/LawsRegulationsPolicies/Mercury/0eara_regs_mercfinaltext.pdf. Final Draft Page 8 5/30/2003

To make a particular recommendation regarding the potential environmental impact and cost effectiveness of CFL recycling.

The paper consists of five sections. Section I presents information on mercury content in fluorescent lamps and puts lamp emissions in context of overall anthropogenic mercury emissions. Section II presents results from studies that analyzed mercury emissions from fluorescent lamps during transport, disposal, and recycling. Section III describes Ecos estimates of mercury emissions from fluorescent lamps during disposal, transport, and recycling as well as the potential net emissions benefit from energy saved by lamp replacement. We also analyze and compare other mercury control options and costs. Section IV highlights a few state regulatory and recycling programs to show the status of existing fluorescent lamp disposal programs and infrastructure. Section V covers our main findings, conclusions, and recommendations. The research consisted of a thorough literature review, interviews with a range of subject matter experts, and new calculations updating earlier cost and pollution estimates.

II. Overall U.S. Mercury Emissions and Fluorescent Lamp Contributions

EPA completed a comprehensive assessment of U.S. mercury emissions in 1997.4 Of the approximately 158 tons of anthropogenic mercury emissions in the U.S., fully 86% results from various types of boilers and incinerators (Figure 1). The remaining 14% divides among a host of much smaller sources, including the manufacturing processes for cement and chlor-alkali. This report attributed about 1.5 tons or 1% of total U.S. emissions to lamp breakage (primarily fluorescent).5 A subsequent EPA report found that lamps added less than 0.8 tons of mercury into the air, primarily through breakage. The agency also accounted for two other pathways of fluorescent lamp mercury release to the environment: small but unspecified fractions of the less than 0.1 tons of landfill emissions per year and of the 29.6 tons per year from

U.S. Environmental Protection Agency, Mercury Report to Congress, 1997, Table ES-6. According to Peter Bleasby of Osram Sylvania, the principal source of mercury emissions from lamps has been found to be the breakage of large quantities on their way to disposal. Landfills in fact release very little mercury, but operationally, it is not practical to deliver bulk quantities of lamps intact to landfills, and cover them before they break.
5

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municipal waste combustors. The overall total ascribed by EPA to fluorescent lamps in the newer report is about 0.5% of all mercury emissions in the US.6 Figure 1
Sources of Mercury Emissions in the U.S.
Lamp breakage 1% Res. boilers 2% Utility boilers 33% 1.2% 1.2% 0.4% 0.7% Landfills 0.1%

Com./ind. boilers 18%

Other 14%

Portland cement 3%

0.9% 0.7% Chlor-alkali 5%

Muni. waste incinerators 19%

Haz. waste incinerators 4% Medical waste incinerators 10%

Boilers and Incinerators Account for 86% of all Mercury

Pulp & paper Other manuf. General lab use Other area sources Geothermal power Other combustion

Various state level reports, using a wide range of methodologies, found largely similar contributions by fluorescent lamps to total mercury emissions, but with greater variability, given the differences in their reliance on coal-fired power generation: 1.4% in the Great Lakes states,7 1% in Minnesota,8 and 3.6% in New Jersey.9 Figure 2 shows the share of mercury emissions by source for Minnesota. Washington estimated that fluorescent lamps were 8.7% to 13% of its mercury releases, but employed high estimates for mercury released (20 mg) per lamp and did not include consideration of coal-fired

U.S. Environmental Protection Agency, Office of Solid Waste, Economics, Methods, and Risk Analysis Division, Modification of the Hazardous Waste Program: Hazardous Waste Lamps. Final Economic Assessment, Final Document, Post-OMB Review, March 11, 1999. In the context of the rapid changes that have occurred in the US on mercury in products, and in emission control regulations, these data are presented to provide historical context, as the percentages may also be changing. 7 Great Lakes States Mercury Emissions Report. Table 3-2. 1999. 8 Minnesota Pollution Control Agency, Mercury Reduction Program: Progress Report to the Minnesota Legislature, January 2002, p. 11. 9 New Jersey Mercury Task Force Report, Sources of Mercury in New Jersey, Volume 3, Chapter 1, January 2002. Final Draft Page 10 5/30/2003

power imported from out of state.10 In addition, the discussion of mercury emissions cannot easily be limited to any single state or region, since airborne mercury is a global issue. Figure 2 Minnesotas Estimate of Sources of Mercury Emissions11

Given the scope of mercury-producing activities in the United States (with electricity generation, commercial and industrial combustion, and manufacturing being the largest sources), emissions from spent fluorescent lamps represent only a small fraction of the total mercury released into the environment. Therefore, it is essential for the environmental community to understand and work to minimize the risks posed by all anthropogenic sources of mercury, including those found in fluorescent lamps.

The Role of Mercury in Fluorescent Lamps

Mercury is essential to the operation of fluorescent lamps. When mercury vapor inside a fluorescent lamp is electrically energized, it emits ultra-violet (UV) light. Phosphor, a luminescent material that coats the inside of fluorescent lamps, absorbs this UV energy, which causes it to fluoresce, re-emitting visible light. This process yields a far longerlived, energy-efficient source of light than standard incandescent lamps. According to Osram Sylvania, the amount of mercury required in vapor form in the discharge to energize the lamp is 50 micrograms about 0.5 to 2.5% of the total placed in the lamp
Washington State Departments of Ecology and Health, Washington State Mercury Chemical Action Plan, January 2003, pp. 6, 55-56, 126. 11 Minnesota Pollution Control Agency, Mercury Reduction Program: Progress Report to the Minnesota Legislature, January 2002, p. 11. Final Draft Page 11 5/30/2003
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when manufactured.12 Therefore, there must be enough initial elemental mercury in the lamp so that at least 50 micrograms is available in vapor form even at the end of the lamps rated life (typically 5 years of use for linear tubes in commercial service, and about the same for CFLs in residential use).13 Though the lighting industry has achieved significant reductions in mercury content per lamp, reducing the average mercury dose by about two-thirds since 1985, there is unfortunately no likely near term prospect for finding a mercury substitute in fluorescent lighting.14 Osram Sylvania makes mercury-free high intensity discharge (HID) lamps using high-pressure sodium in sizes up to 150 watts, with higher wattages under development.15 However, these products have different shapes and provide light of a very different color than fluorescent, so are not readily substitutable. It remains to be seen whether these present a viable alternative, or if the technology can be translated to other lamp types. Longer term, solid state alternatives such as LEDs offer significant promise for reducing reliance on mercury-containing lamps in the next decade, particularly in applications requiring directional lighting. Mercury in fluorescent lamps has essentially two different chemical compositions: vaporphase elemental mercury and divalent mercury adsorbed on the phosphor powder, the metal lamp ends, or other components. At the end of lamp life, most of the mercury is in divalent form. Mercury from fluorescent lamps reaches the environment during the process of incineration, disposal, recycling, or accidental breakage of lamps. This will be discussed further in Sections II and III below. The total mercury content of fluorescent lamps depends upon the type of lamp, its size, manufacturer, and year of manufacture. Four-foot linear fluorescent tubes can contain 3 to 20 milligrams (mg) of mercury. A 2001 National Electrical Manufacturers Association (NEMA) survey found that the industry average for a four-foot lamp is 8.3 mg.16 In general, T12 lamps (1.5 inches in diameter) tend to contain more mercury and are less energy-efficient than T8 lamps (1 inch in diameter). Within a given manufacturers family of products, mercury content generally increases with lamp length, diameter, design life, and desired light output level. So, for example, T5 lamps contain less mercury than T8s, 4-foot lamps contain less than 8-foot lamps, and standard lamps of a given size contain slightly less mercury than very long life, high output (HO), or very high output (VHO) lamps.17 The growing market preference for thinner fluorescent

Osram Sylvania, The Use of Mercury in Efficient Electric Lamps An Update, see www.sylvania.com/press/03132001.html. 13 Note that the 50 micrograms figure is based on operational requirements for linear fluorescent tubes, but we believe the levels needed for CFLs are also in the range of micrograms i.e., a small fraction of the amount with which the lamps are manufactured. 14 National Electric Manufacturers Association, NEMA Lamp Manufacturers Reduce Use of Mercury by 67 Percent, press release, May 28, 2002. Available at www.nema.org. 15 Ibid. 16 National Electric Manufacturers Association, NEMA Lamp Manufacturers Reduce Use of Mercury by 67 Percent, press release, May 28, 2002. Available at www.nema.org. 17 Personal communication, Nick Iacobucci, General Electric Lighting, December 2002. Final Draft Page 12 5/30/2003

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lamps is thus helping to drive down average lamp mercury burdens.18 Some manufacturers including Philips, Osram Sylvania, and General Electric have developed lines of low-mercury bulbs with significantly lower mercury levels for standard lamp types. See Table 1 for mercury content for a variety of bulb types and manufacturers. CFLs operate in a similar manner to linear tubes, though they contain comparatively less mercury per lamp than most linear fluorescents. The industry average for CFLs is difficult to determine, given the flood of recent imports from new manufacturers, but likely falls in the range of 5 to 8 mg of mercury per lamp. Table 1 shows some of the recent estimates of the mercury content of a variety of fluorescent lamp types as well as the current best practice (i.e., lowest mercury content) lamps. Table 1: Mercury Content of Fluorescent Lamps -milligrams (mg) per lamp EPA Final Report EPA Final Report 2001 Current Best Lamps Manufactured Lamps Manufactured National Practice21 after 199919 1992-1999 Lamp Type Average20 4 ft T8 15 10 7-9 3.5 8 ft T8 >9 4.4 4 ft T12 30 21 9-11 4.4 8 ft T12 >11 6.8 CFLs <5-8 1.4-2.7

Can Mercury in Fluorescent Lamps and Other Products be Further Reduced?

A good deal of source reduction has already occurred in fluorescent lamp design, and far more is possible through policy measures that provide incentives or require all manufacturers to achieve best practice in lamp design. While todays average linear fluorescent lamps may contain 80% less mercury than they did in the early 1990s, current best practice reduces that by at least 50% more (Figure 3).22 However, information on these encouraging trends is available only for linear fluorescent lamps, as CFLs have yet to be tested in sufficient quantities for such information to be available. The following discussion focuses only on linear fluorescents. Philips manufactures a line of low-mercury lampsALTO lampsthat contain 3.6 mg of mercury per 4 foot T8. The amount of mercury or dose contained in an individual
18

Chris Calwell, Danielle Dowers, and Doug Johnson, How Far Have We Come? Remaining Opportunities for Upgrading Fluorescent Ballasts and Lamps, Strategic Memo SM-98-4, E Source, May 1998. 19 U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998. 20 Personal communication, Steve Goldmacher, Philips Lighting, October 14, 2002. 21 Personal communication. Steve Goldmacher. Philips Lighting. October 14, 2002. 22 Personal communication, Steve Goldmacher, Philips Lighting, October 14, 2002. Final Draft Page 13 5/30/2003

lamp can vary as well. Philips reports a dosing precision for the ALTO lamps of +/0.005 mg,23 which is important for limiting occupational exposure and bounding the risk a lamp represents at end of life.24 According to Philips, mercury levels in the ALTO lamps are low enough that these lamps can pass EPAs Toxicity Characteristic Leaching Procedure test (TCLP) and the more stringent Total Threshold Limit Concentration test (TTLC) that California has relied upon historically.25 Lamps with over 6 mg of mercury generally fail the TCLP test and lamps with over 3.8 mg of mercury usually fail the California TTLC test.26 Because the TTLC test is based on a concentration (ppm) of mercury rather than an absolute amount, the portions of a lamp with the highest mercury content (if tested by themselves) could fail the test while the overall lamp would not.27 Figure 3
Mercury Content of 4-Foot Linear Fluorescent Lamps
45

40

35 T12 Lamps (1.5" diameter) Mercury by Weight (mg) 30

25

20

15 T8 Lamps (1" diameter) 10

Best Practice T12 Best Practice T8

0 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 Year of Manufacture

Some manufacturers chemically bind the mercury content in their lamps with the addition of ascorbic acid, iron bases, silver carbonate, and other compounds so they can pass the

23 24

Personal communication, Steve Goldmacher, Philips Lighting, October 14, 2002. Another source reported to us confidentially that some of the lowest cost CFLs manufactured outside the US are dosed by hand, which would likely yield higher occupational exposure and much wider variability in the total dose. 25 Philips Pocket Guide 26 Philips Pocket Guide. Page 12. 27 Personal communication, John Chilcott, Earth Protection Services, 3/24/03. Final Draft Page 14 5/30/2003

TCLP test.28 The consequence is reduced detection of mercury in TCLP tests and a possible reduction in bioavailability of mercury when the lamps are disposed of.29 Philips has used an iron cathode shield in its lamp designs for 30 years, and has not modified that design in response to mercury regulations or testing requirements. This shield may have the effect of reducing the amount of mercury detected during a TCLP test.30 Philips states that the shield is not included for that purpose and if the shield were removed, the lamps would still pass the TCLP test because of the very low quantities of mercury used in its manufacturing process.31 Our research into the performance of the low-mercury linear Philip products yielded undocumented claims of poor lamp performance and short lamp life, and two incidences of ALTO lamps failing a TCLP test (out of nearly 1 billion units manufactured so far).32 However, we have uncovered no information that supports or refutes Philips claim of lowest mercury content in fluorescent lamp design to date.33 A recent study by the Maine Department of Environmental Protection analyzed the mercury content of lamps that pass the TCLP test. The Maine study was only able to measure about 2/3 of the mercury contained in the lamp and concluded that TCLP test was not a good measure of total mercury content of spent lamps.34 They note that the TCLP test is designed to measure leachability of toxic substances such as mercury in waste and potential water contamination caused by that waste. Since mercury vapor from lamps is released to air, the TCLP test does not fully reflect this potential impact. California recently banned all fluorescent lamps from landfills, categorizing them as hazardous wastes, based in part on the Maine findings. Even with the more stringent California TTLC test, which measure total toxicity for waste, regulators believed the TTLC test was not accurately measuring the total risk from lamps in the waste stream.35 California also disallowed Philips request for an exemption from the new requirement for its ALTO lamps, which met the old TTLC test.

See, in particular, Douglas Chandler, Philips, GE Lighting differ over mercury control in fluorescent lamps, Electrical Wholesaling, March 1, 1998 and Personal communication, Steve Goldmacher, Philips Lighting, March 19, 2003. 29 Personal communication, Nick Iacobucci, General Electric Lighting, December 2002. 30 The Truth about TCLP-Passing Fluorescent Lamps. Information obtained from Osram Sylvanias website (http://www.sylvania.com/press/01242000.html) 31 Personal communication, Steve Goldmacher, Philips Lighting, March 19, 2003. 32 Personal communication, Paul Abernathy, Association of Lighting and Mercury Recyclers, March 18, 2003. 33 Our interest in this research report is not in promoting Philips products, but in recognizing and encouraging best practice by any manufacturer whose innovations reduce environmental impact cost effectively. If anything, best practice is a moving target that can and may already be achieved by other manufacturers. 34 Maine Department of Environmental Protection. Maine Fluorescent Lamp Study. Final Report. February 2002. 35 California Department of Toxic Substances. Final Text, Mercury Classification and Management, March 2003, see www.dtsc.ca.gov/LawsRegulationsPolicies/Mercury/Oeara_regs_mercfinaltext.pdf. Final Draft Page 15 5/30/2003

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Do Fluorescent Lamps Provide a Net Emissions Benefit?

The societal benefits of fluorescent lighting are well documented: a return on financial investment (through energy bill reductions) of hundreds of percent, reduced heat output, greater control over color, better dispersion of light across large areas, and greatly increased lamp life relative to traditional incandescent sources. Indeed, even if all electricity were generated by renewable sources (and thus no pollution could be prevented by saving energy), it seems likely that mercury-containing fluorescent lighting would still yield powerful net benefits to society. The primary source of mercury from electric power production is coal-fired power plants that emit mercury vapor released from the coal during combustion. Of the approximately 158 tons of anthropogenic mercury emissions in the US, fully 65% (about 102 tons) results from various types of boilers. This mercury vapor can be dispersed over a wide area because it is emitted from tall smoke stacks. The vapor condenses and is deposited in soil and waterways, becoming available as methyl-mercury for bioaccumulation in plants, animals, and fish. The primary pathway for human exposure to mercury is through consumption of fish. Four ounces of some types of fish found in the Gulf of Mexico now contain more mercury than is safe for an adult to consume in a month.36 The electric energy saved by replacing incandescent lamps with fluorescent lamps has the potential for net mercury emissions reductions from coal-fired power plants. NEMA asserts, because of the potential for significant energy savings, using high efficiency fluorescent lamps to replace incandescent lamps or older fluorescent lamps results in a net reduction in mercury emissions.37 The United Nations Environment Program (UNEP) also recognizes the potential environmental benefit from fluorescent lamps: At the same time, it would be a mistake to assume that [mercury] substitution is always a clear winner. For example, in the case of energyefficient fluorescent lamps, as long as there are no competitive substitutes that do not contain mercury, it is generally preferable from a product-lifecycle perspective to use a mercury-containing energy-efficient lamp rather than to use a less efficient standard incandescent lamp containing no mercury, as a result of current electricity production practices.38 Consider the following examples: Example 1: One 32-watt, 4-foot T8 fluorescent lamp produces as much light as two 75-watt incandescent lamps, resulting in 118 watts of electricity savings (or 0.118 kW). If the T8 is estimated to have a 20,000-hour life, then replacing the two incandescents with the T8 will save 2,360 kWh of electricity over its lifetime.
Ben Raines, Deep Trouble, OnEarth, Spring 2003, pp. 24-27. National Electric Manufacturers Association, Fluorescent Lamps and the Environment, January 2001. Downloaded August 16, 2002. See www.lamprecycle.org. 38 United Nations Environment Programme, Chemicals, Global Mercury Assessment, December 2002. (www.chem.unep.ch).
37 36

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Example 2: One 20-watt CFL replaces a 75-watt incandescent bulb, yielding 55 watts of savings over 10,000 hours of operating life, or 550 kWh saved. EPA estimates that the average U.S. electric generation mix of coal, natural gas, oil, and other sources produces about 0.016 mg of mercury per kWh, with the majority of these emissions from the 55% of U.S. electricity that come from coal.39 In our examples, to calculate the amount of mercury avoided by using the T8 or CFL, we multiply the kWh savings by the amount of mercury per kWh, as shown in Table 2. Table 2: Average Avoided Mercury Emissions from Energy Saved by Fluorescent Lamps (lifetime savings) Lifetime energy savings (kWh) 2,360 550 Mercury emissions from power plants (mg/kWh) 0.016 0.016 Avoided Hg emissions from saved energy (mg) 37.8 8.8

Lamp type 1) Linear T8 2) CFL

EPA found that total avoided mercury emissions from energy savings for a similar case study that replaced T12 lamps with T8 lamps nationwide were on the order of 500 kg per year.40 This suggests a substantial mercury savings opportunity from measures undertaken primarily to cut energy consumption and utility bills. To estimate the net mercury avoided by fluorescent lamps, we compare the mercury content of the lamps to the avoided mercury emissions from the saved energy. Table 3 shows these results using mercury content of best practice and national average lamps. Table 3: Net Mercury for Best Practice and National Average Lamps (Lamp mercury content less avoided mercury emissions from saved energy)
Lamp type 1) Linear T8 2) CFL Mercury content of lamp Best practice National Average (mg) (mg) 3.5 8 2 5 Net Mercury (Lamp content - avoided emissions) Best Practice (mg) National Ave (mg) -34.3 -29.8 -6.8 -3.8

In reality, the environmental benefits tend to be greater than indicated above, because only 17 to 40% of the original mercury content of the lamp is readily released as a vapor when the lamp is broken (see below for an additional discussion of this topic). As a result, the net air emissions benefits from the fluorescent lamps described above are

39

U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998, pp. 2-8. 40 U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998, Table 2-6. Final Draft Page 17 5/30/2003

likely higher, a net reduction of 34.6 to 37.2 mg for the linear T8 and a net reduction of 6.8 to 8.8 mg for the CFL. But the extent to which coal contributes to a particular utilitys or states generation mix will have a far greater impact on the overall balance of net emissions. As Figure 4, illustrates, the impact of coal-fired generation is so profound that it dwarfs the impact of changing assumptions about the amount of mercury contained in a fluorescent lamp or the fraction of that mercury that is released upon lamp breakage. Note, for example, in Figure 4 that, even under pessimistic assumptions, T8s provide net benefits (negative emissions) in any region that derives more than 15% of its electricity from coal. CFLs, likewise, yield net emissions benefits under pessimistic assumptions in any region with more than 30% of its electricity coming from coal. Under more optimistic assumptions, those breakeven points are in the 1-3% coal share range for T8s and CFLs. The national average contribution of coal - 55% of the generation mix - is high enough to leave no doubt about the net mercury benefits of fluorescent lamps on a national basis. Figure 4
How the Fraction of Electricity Generated by Coal Influences Whether Fluorescent Lamps Reduce or Increase Net Mercury Emissions
10

Sections above the horizontal line indicate a net increase in mercury emissions from the use of fluorescent lamps
(lamp disposal emissions minus prevented power plant emissions) 0

Net Milligrams of Mercury Released

-10

CFLs
-20

T8s
-30

-40

-50

-60

National Average

-70
0% 10%
Anchorage, AK=14%

20%

30%
Portland, OR=24%

40%

50%

60%

70%
Atlanta, GA=67%

80%

90%
Cleveland, OH=93%

100%

Washington, DC=47%

Fraction of Electricity Generated from Coal

Source: Ecos Consulting and www.epa.gov/cleanenergy/powerprofiler.htm

Oregon provides an interesting worst-case example, having within its borders only one coal-fired power plant, which uses a type of coal with lower than average mercury content and sophisticated pollution prevention technology that recovers about 25% of the
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mercury emissions. In total, about 7% of the states electricity comes from coal, ignoring the impact of imports, which constitute a few additional percent.41 At the same time, Oregon has been a leader in efforts to promote energy efficient lighting, particularly CFLs. Estimates put statewide CFL sales at about 2 to 4 million lamps in 2001. A study of anthropogenic mercury emissions in Oregon found that spent fluorescent lamps in the waste stream may be responsible for more mercury emissions in Oregon than coal-fired electricity generation within the states borders.42 However, the majority of these emissions would still be coming from linear rather than compact fluorescent lamps. Likewise, including consideration of imported coal-fired power and regional power pools could tip the balance between positive and negative emissions.

The Special Case of CFLs

CFLs have yet to penetrate the market in a way that linear fluorescent lamps have. National sales of screw-based CFLs for all markets (residential, commercial and industrial) are roughly 30 to 40 million units per year. Pin-based lamp sales (primarily for two piece CFLs and dedicated fixtures with hard-wired ballasts) appear to be somewhat larger and heavily concentrated in commercial and industrial applications, totaling about 50 million units per year.43 Combined, total national CFL sales are about 85 million units per year far less than the more than 500 million linear fluorescent lamps sold per year. In addition, the volume of linear lamps being removed from buildings annually is probably larger than annual sales (because of de-lamping programs), while CFL removal rates are almost certainly lower than annual sales at present (due to large increases in sales in 2000 and 2001 relative to previous years).44 In general, CFLs contain less mercury than linear lamps, which are much larger in physical size and tend to provide higher levels of illumination as well. As Table 4 below indicates, average mercury dosage in removed CFLs likely ranges between 3 and 8 mg, while average dosages in the linear lamps being removed now may vary between 5 and 12 mg (older lamps were higher, but those populations are declining). Even with recent rises in national CFL sales, the total mercury burden that linear lamps represent will continue to dwarf the CFL contribution. About 40 times as many linear
See www.epa.gov/air/clearskies/state/or.html. Laura Weiss, MPH and Sandy Wright, MercuryOn the Road to Zero: Recommended Strategies to Eliminate Mercury Releases from Human Activities in Oregon by 2020. Oregon Environmental Council and the Mercury Solutions Team. December 2001. Note that the lions share of mercury emissions in Oregon stems from abandoned mercury mines, dwarfing any other anthropogenic source. 43 Chris Calwell, Chris Granda, Lois Gordon, and My Ton, Lighting the Way to Energy Savings: How Can We Transform Residential Lighting Markets? Volume 2: Background and Reference, prepared by Ecos Consulting for Noah Horowitz, NRDC, December 1999, p. 10. 44 See Chris Calwell and John Zugel (Ecos Consulting), Peter Banwell and Wendy Reed (U.S. Environmental Protection Agency), 2001: A CFL Odyssey, presented at the 2002 ACEEE Summer Study, Asilomar, CA, 2002; and Chris Calwell, Danielle Dowers, and Doug Johnson, How Far Have We Come? Remaining Opportunities for Upgrading Fluorescent Ballasts and Lamps, Strategic Memo SM-98-4, E Source, May 1998.
42 41

Final Draft

Page 19

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lamps are being removed from use each year, and each one typically contains at least 50% more mercury. A number of other vital distinctions between the lamp types affect their relative viability for recycling. CFLs are sold in a tremendous array of sizes and shapes, often with an integral ballast (electronic circuit board), so are more likely to break in transport and somewhat more challenging to deal with in the recycling process. More importantly for recycling purposes, however, the vast majority of linear fluorescent lamps are sold in standard lengths of 4 and 8 feet and standard diameters of 1 and 1.5 inches. This makes them much easier than CFLs to handle safely in standardized shipping containers, transport without breakage, and recycle with automated equipment. They are retrievable in large numbers from commercial and industrial buildings as well, highlighting an important cost-effectiveness distinction from the CFLs typically found in small numbers in individual homes. While linear lamps can typically be recycled at a cost of perhaps $0.20 to $0.60 per lamp, including transportation costs, CFLs typically cost $0.40 to $0.80 per lamp for just the recycling and transportation costs alone. Programs that have undertaken broad-based CFL recycling, such as Xcel Energys program in Minnesota, have spent $300,000 per year to recycle about 150,000 CFLs, or $2 per bulb. Much of the extra cost resulted from funds spent to advertise the program, encourage participation by consumers, and provide the means for collecting the lamps in stores. Pilot efforts under consideration in the Pacific Northwest would be run at a far smaller scale, but would still require significant advertising and infrastructure startup costs, leading to even higher total program costs per bulb. In summary, CFL recycling costs significantly more per bulb to recapture significantly less mercury per bulb than linear lamp recycling, and is applicable to only a few percent of all the fluorescent lamps currently being removed each year. Although residential CFL sales increases have created a strong level of media and political interest in recycling them, that interest appears to exceed the relative mercury risk they represent.

III.

Lamp Disposal and Mercury Emissions

At the end of their average 5-year life, spent lamps typically are sent either to municipal landfills, incinerated, handled by a hazardous waste facility, or recycled. NEMA estimates that in 1999, 620 million lamps were disposed in the U.S.45 According to NEMA, the fate of these lamps was as follows: 71% were landfilled 15% were recycled 14% were incinerated.
NEMA, Environmental Impact Analysis: Spent Mercury-Containing Lamps, Fourth Edition, January 2000. Final Draft Page 20 5/30/2003
45

The mercury in spent lamps is found in vapor form, in the phosphor powder, and bound to the lamp glass and end caps. The amount of mercury in each of the locations depends on the age of the lamp, the type of lamp, method of lamp operation, and temperature of lamp contents.46 For a burned-out lamp, only a small fraction of the mercury is still in vapor form at room temperature. In fact, one cause of failure in fluorescent lamps can be the impinging of much of the mercury vapor onto the glass, the phosphor, or the metal lamp ends. That mercury can no longer contribute to the illumination process or be readily released as a gas or liquid when the lamp breaks, unless the lamp is heated. Once the lamps are spent, what can be done to minimize environmental impacts? Keeping fluorescent lamps out of incinerators appears to be the most important factor in keeping the most mercury out of the environment in the disposal process. The secondmost important issue turns out to be the process by which the lamps are handled en route to their ultimate fate. If the lamps are broken during transport or disposal, the mercury in the lamp can be released to the environment. If left intact, mercury emissions are likely to be very low.47 In an effort to improve handling of lamps, EPA classified fluorescent lamps under the Universal Waste Rule (UWR) in 1999. The Universal Waste Rule is a subset of the federal Resource Conservation and Recovery Act (RCRA) that regulates hazardous waste. The Universal Waste Rule covers ubiquitous wastes that contain toxics such as lamps, rechargeable nickel-cadmium batteries and thermostats. The UWR was designed to ease the burden of disposal for businesses. Prior to the UWR designation, spent lamps were subject to costly and stringent hazardous waste storage, collection, transportation, and record-keeping requirements. Lamps that fail the TCLP test are still subject to the full battery of RCRA hazardous waste regulations. Some low-mercury containing lamps can avoid these regulations and can be sent directly to landfills in most states (except for states that have bans in place). Currently, EPAs rule exempts almost all but the largest generators from handling spent lamps as universal waste. The UWR only applies to generators that produce 220 pounds or more of universal waste each month. This corresponds to disposing 300 to 350 4-foot T12 lamps or 400 to 450 T8 lamps per month. Small quantity generators, like households and businesses that generate less than these amounts, are exempt. Universal waste management requirements stipulate that handlers of waste lamps managed under the universal waste rule must:
46

Manage lamps in a way that prevents releases of the waste to the environment Contain lamps in containers such as cardboard boxes or fiber drums, which are adequate to prevent breakage Keep containers closed Minimize lamp breakage and immediately clean up any broken or damaged lamps Store broken lamps in a closed, structurally sound container

New Jersey Mercury Task Force, Sources of Mercury in New Jersey, Volume 3, Chapter 3, p. 83, January 2002. 47 Ryan Marquardt, Zero Waste Alliance, p. 11. Final Draft Page 21 5/30/2003

Mercury Contained in Spent Lamps

There is a wide range of estimates (and more are being reported regularly) on the mercury emitted from spent lamps. The discrepancy is related to the amount of initial mercury dose in the lamp as well as the portion of this mercury that is in vapor phase at end of lamp life and the amount that is bound to the phosphor powder or adhered to the glass or end caps. To start, we estimate a range of values for the total mercury content of lamps disposed in 1999. This estimate shows the total amount of mercury that could be emitted by spent lamps. Using low, medium, and high assumptions for the number of linear lamps and CFLs disposed in that year and the total mercury content of these lamps, we estimate that in 1999 a low of 3.3 and a high of 10.5 short tons of mercury was disposed of in spent lamps in the US (see Table 4). The medium estimate was 5.5 tons. Table 4: Estimated Total Mercury Contained in Spent Lamps (1999) Removed Mercury Removed Content Linear Lamps CFLs Million mg/linear Million 600 10 5 620 15 8 780 20 12 Mercury Content mg/CFL 3 5 8 Total Mercury Content in Spent Lamps (tons) 3.33 5.54 10.47

Case Low Medium High

Note the distinction between this estimate of total mercury contained in the lamps and other estimates of mercury releases to the environment from fluorescent lamps (which is discussed further in the next section). Three factors account for the major difference between those two estimates: the majority of mercury remains relatively immobile in discarded fluorescent lamps fluorescent lamps are actively diverted from incinerators when possible, though an unknown fraction still get incinerated fluorescent lamp recycling is on the rise, particularly for linear lamps that account for the majority of the mercury burden

While these values are significant, other consumer products such as batteries, thermometers, auto switches, CRTs, and thermostats can contribute more mercury to the solid waste stream (Figure 5). In comparison to an average fluorescent lamp with 8 mg of mercury, a mercury thermometer contains about 500 mg of mercury and an older thermostat 3000 mg of mercury.48 Disposal of these products can also contribute significant amount of mercury to the waste stream. Furthermore, the liquid mercury in thermometers, auto switches, and thermostats is far more mobile in the waste stream than
48

U.S. EPA. Fact Sheet: Mercury in Compact Fluorescent Lamps (CFLs), 2002. Page 22 5/30/2003

Final Draft

the mercury bound to the glass and end caps in spent fluorescent lamps, though both forms pose a significant risk in incinerators. Adding to this the previously discussed benefit of power plant emissions reductions further clarifies the distinction between fluorescent lamps and other mercury-containing products. Using the net mercury emissions calculated in Tables 2 and 3, and the medium case for number of lamps disposed, the net mercury in fluorescent lamps (accounting for avoided power plant emissions) amounts to over 20 tons per year for linear tubes and about 200 lbs for CFLs. The fact that these values are negative demonstrates that fluorescent lamps can offer a net benefit with regard to mercury emissions. Figure 5
Sources of Mercury in Oregon's Solid Waste Stream
Blood Pressure Cuffs 2.0% Manometers 0.5%

Fluorescent Lamps 11%

Thermostats 11%

Batteries 30%

Auto Switches 13%

Thermometers 18% Computers 14%

Mercury Releases from Spent Lamps in Transport (to Landfills)

As the spent lamps enter the solid waste stream, they can potentially emit mercury during transport if the lamp is broken. If the lamp is recycled, mercury can be emitted during the recovery process. The data for mercury emissions from spent lamps is not very extensive, though new studies are being released regularly. Findings from the most recent studies are summarized below:
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EPA assumes that all lamps transported to landfills (or incinerators) are broken in transport and that all the vapor phase mercury will be emitted at that time.49 EPA estimates that only 0.2% of the total mercury in the lamp is still in vapor form at end of life with the remainder in powder form or sufficiently bound to the glass and end caps that it will not be released to the air without heat.50 A recent study completed in New Jersey estimates that between 17% to 40% of initial mercury in spent low-mercury linear lamps volatilizes during the first two weeks after breakage.51 The study also found that the higher volatilization rate coincides with higher temperatures, though they have fewer data for higher temperature ranges. The study finds that the amount of mercury released by a lamp is related to the initial amount of mercury in the bulb and the temperatures experienced after breakage. The study concludes that waste management systems that minimize breakage before final disposal, which is assumed to minimize subsequent release of mercury, could reduce this total [emission] (as could the reduction of mercury content of the bulbs). NEMA estimates that that in 1990, 98% of all lamps that were not recycled were broken in transport but that fraction will drop to 75% by 2004.52 NEMA estimates that lamp releases from breakage average 0.04 mg per lamp.53 Preliminary data from a Florida landfill study indicate that mercury from broken fluorescent lamps persists for at least a week and may represent 20% to 80% of the mercury in the lamps.54 A general assumption used by Philips is that approximately 1/3 of mercury originally placed in a fluorescent lamp remains in vapor phase at end of life.55 We estimate the total amount of mercury released by fluorescent lamps in the solid waste steam in Table 5 using the central estimate of total mercury disposed in 1999 of 5.5 tons. (See Table 4). We use low, medium, and high estimates for the recycling rate (or lamps that are diverted out of the waste stream and remain unbroken) and the percentage of total mercury released by the lamps for the first two weeks after breakage. With these assumptions, we estimate that in 1999, a low of 0.3 tons and a high of 2 tons of mercury
U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998. 50 U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998, Section 2.3.1.1, p. 2.4 51 Journal of Air and Waste Management Association. 53:143-151. Release of Mercury from Broken Fluorescent Bulbs. Michael Aucott. Michael McLinden, Michael Winka. New Jersey Department of Environmental Protection. February, 2003. 52 National Electrical Manufacturers Association, Environmental Impact Analysis: Spent MercuryContaining Lamps, Fourth Edition, January 2000. 53 Ibid. 54 Ibid. 55 Personal communication, Steve Goldmacher, Philips Lighting, March 19, 2003. Final Draft Page 24 5/30/2003
49

were released by lamps. Table 5 shows the results with the medium estimate at 0.8 tons very similar to EPAs estimate. This estimate represents the potential amount of mercury released from the point the lamp is broken (during transport) and the first two-weeks the lamp is lying in a staging area or uncovered in the landfill. Table 5: Estimated Tons of Mercury Released by Lamps in Transport and Uncovered Landfills Case Low Medium High Recycle Rate 20% 15% 10% % Mercury Released by Lamp 6% 17% 40% Landfill Mercury (Tons) 0.27 0.80 1.99

Mercury Releases from Spent Lamps in Landfills

It is generally agreed that all lamps are broken during transport to the landfill or while they are being staged for transfer into the landfill. Emissions during this stage are included in Table 5. There are few studies on the emissions from broken lamps after they are covered by soil or other substances at the landfill, but findings to date can be summarized as follows: According to EPA, RTI reviewed the available data on mercury releases from landfills, and concluded that the release rates for mercury in landfill gas leachates are very low. RTI calculated mercury emissions from landfill leachate of 0.8 kg per year nationwide.56 A study by Tetra Tech measured mercury emissions from broken bulbs under soil cover depths of 0.5 feet and 1.0 feet. Results indicate that releases from the 0.5 foot soil cover averaged 0.8% of the total mercury content of the bulb over a 20day period and averaged 0.2% for the 1.0 foot soil cover. These rates are approximately three orders of magnitude higher than the RTI estimate.57 The Zero Waste Alliance report notes that about 0.01 mg of the original 5 mg in a CFL might be released to the environment in a standard or hazardous waste landfill.58 EPA assumes that lamps for Subtitle C landfills (hazardous waste facilities) have no mercury releases to the air or water.59

56

U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, Section 2.3.1.5, March 31, 1998. 57 ibid. 58 Ryan Marquardt, Zero Waste Alliance, p. 11. 59 U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, Section 2.3.1.5, March 31, 1998. Final Draft Page 25 5/30/2003

If the lamps are disposed into a well-designed, licensed, and monitored landfill, most water-borne mercury should be contained by the liner or otherwise be detected and mitigated. The other pathway for fluorescent lamps to release mercury in the environment is through water. Rainwater in open dumpsters could liberate mercury bound to lamp parts or in phosphor powder. Estimating the magnitude of that impact would be difficult, but we believe it to be minor.

Mercury Releases from Incineration

Municipal Waste Combustors (MWC) include incinerators that burn waste and waste-toenergy plants that generate energy from garbage. According to the EPA, incinerating fluorescent lamps without mercury emission controls may result in the release of up to 90% of the mercury in a lamp directly into the air.60 MWC with EPA-mandated mercury controls significantly limit the amount of mercury emissions released into the air, with estimates ranging between 8% and 30%. NEMA recommends diverting spent lamps from incineration, regardless of the mercury emission controls in place.61 Recognizing that it would be very difficult for an incinerator to prevent broken fragments of fluorescent lamps from being combusted with other waste and that no emission controls will be 100% effective, source reduction and minimizing the practice of incineration have obvious appeal.

Mercury Releases from Recycling Fluorescent Lamps

The average national recycling rate of spent tubes is currently about 20-25%, though these numbers are most robust in states with full disposal bans.62 Lamp recyclers report that CFLs account for a much smaller part of their business than linear lamps. CFLs cost more to recycle than linear lamps because the mercury recovery process is more laborintensive. Generally, lamps transported for recycling arrive to the facility intact. Lamp breakage rates in Florida average 0.2%. One facility in Maryland reported breakage rates significantly lower than 1% for properly packaged lamps and as high as 25% for improperly packaged lamps (in this case the entire box would be broken). Minnesota requires recyclers to reject shipments with 5% breakage or higher.63

U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998. Section 2.3.1.4. 61 NEMA, Fluorescent Lamps and the Environment: Mercury Use, Environmental Benefits, Disposal Requirements, January 2001, p. 8. 62 Chris Calwell, Danielle Dowers, and Doug Johnson, How Far Have We Come? Remaining Opportunities for Upgrading Fluorescent Ballasts and Lamps, ESOURCE Strategic Memo SM-98-4, May 1998, p. 11. 63 All breakage statistics from U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998. Section 2.3.1.1. Final Draft Page 26 5/30/2003

60

During recycling, the mercury in vapor phase can be directly recovered, and extracted from the phosphor powder, the glass, and the end caps. The recycling process involves crushing unbroken lamps in a closed system, followed by a heating (retort) process to drive off residual mercury from the crushed lamp components.64 Mercury released as a vapor is collected in a distillation unit for sale or reuse. Emissions from recycling can be minimal, with well-managed facilities recovering over 99% of the mercury.65 EPA estimated mercury control efficiency of 90% for primary recycling and 98.9% for secondary recycling (lamp glass retort only).66 Recycling costs about $0.05 to $1.00 per linear lamp, with CFL recycling cost estimated to be five to 10 times as much. These costs vastly exceed the economic value of the materials recovered.67 Osram Sylvania estimates that the cost to recover mercury through recycling is approximately $4,000 per pound. They also estimate that the value of this recycled mercury (based on the market price of purchasing new mercury) when manufacturing new lamps is only $2 to $3 per pound.68 If the contents were more valuable, lamp recycling would not require payments by the disposer or a government agency. Because lamp recycling is done on a relatively small scale in most states, the cost to collect, contain, and transport the lamps for recycling can be 10 times the cost of recycling alone. Therefore the total cost or retail cost for recycling lamps can range from under $1 per lamp to over $10 per lamp depending on the status of recycling infrastructure.

IV.

State Actions

State regulation of mercury-containing products continues to rapidly gain momentum. At least 28 states have or are considering enacting legislation for various household products that contain mercury.69 Currently, 10 states have introduced bills to regulate the labeling and/or disposal of fluorescent lamps. Below is a review of a few key states driving mercury legislation. (Few, if any, distinguish between linear lamps and CFLs.)

Minnesota

New Jersey Mercury Task Force, Sources of Mercury in New Jersey, January 2002, Volume 3, Chapter 3, p. 86. All of the mercury can theoretically be recovered, regardless of its chemical form. 65 Personal communication, Paul Abernathy, Association of Lighting and Mercury Recyclers, March 18, 2003. 66 U.S. Environmental Protection Agency, Office of Solid Waste, Mercury Emissions from the Disposal of Fluorescent Lamps, Revised Model, Final Report Post-OMB Review, March 31, 1998. Section 2.3.1.3. 67 Linear lamp recycling costs range from 5 to 50 cents per lamp with an additional 5 to 10 cents for collection, handling, and transport. CFL recycling costs currently range from $0.35 to $1.00 with an additional $0.15 to $1.00 for collection and transport depending on the status of recycling and collection infrastructure. 68 New Jersey Mercury Task Force, Sources of Mercury in New Jersey, January 2002, Volume 3, Chapter 3, p. 86. 69 See www.dtsc.ca.gov/HazardousWaste/HWMP_REP_DraftMercury2.pdf and www.mercurypolicy.org/new/documents/StatusofStateandFedProductLeg03.pdf. Final Draft Page 27 5/30/2003

64

Minnesota passed a solid waste ban for both residential and non-residential fluorescent lamps even before the EPA had promulgated its Universal Waste Rule. When the law was passed, stakeholders determined that programs would need flexibility; therefore, there is no centralized state program and activities occur at the local level. Minnesota requires that every county have a hazardous household waste (HHW) collection program. Additionally, utilities are required to support it (funds used also count toward conservation improvement program spending requirements). Residents are provided with contacts for options in their area through the local utility and on state and county government web sites.70 Local programs can use independent retail hardware stores, recycling centers and periodic HHW events as collection points for tubes and CFLs from the residential and small business sectors. From the retail collection sites, lamps are transported to recycling facilities. Utilities can support lamp recycling a number of ways. Xcel Energy, which serves at least 50% of the states energy needs, subsidizes part of the CFL recycling fees by presenting coupons to households to redeem at participating hardware stores. The $0.50 coupons cover half of the fee consumers must pay to recycle a CFL. Customers can also receive $0.50 off the purchase of another bulb when they bring one in for recycling. Otter Tail Power, on the other hand, subsidizes lamp recycling directly with the recycling facilities.

Vermont
Vermont enacted a mercury-added consumer products law that went into effect on March 1, 2000. The law requires products containing mercury to carry consumer labels and requires manufacturers to report on mercury-containing consumer products they sell in Vermont. The labeling must inform the user that the product contains mercury and that it is illegal to dispose of it in trash. Towns and solid waste districts collect mercury-added consumer products and are responsible for informing the public about them. The state Environmental Conservation Department plans to start an education campaign to bolster recycling rates. Proper disposal consists of: recycling through a municipal or solid waste district household hazardous waste collection program direct shipment to a lamp recycler shipment through a Universal Waste Handler.

See www.pca.state.mn.us/waste/hhw.html and personal communication with John Gilkeson, Minnesota Office of Environmental Assistance, March 20, 2003. Final Draft Page 28 5/30/2003

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Some districts offer year-round disposal; others conduct one-day collections twice a year. In 2001, 280,000 linear feet of tubes were collected.71 Labeling is a contentious part of Vermonts law. NEMA challenged it in court, going all the way to the US Supreme Court, which declined to hear the case in June 2002. The industry claimed that lamp labeling would impose significant legal, marketing, and manufacturing complications on manufacturers, wholesalers, and retailers. It is too soon to see if the markets experience bears this out, but NEMA issued a statement in January 2003 that members of its Lamp Section will initiate a nationwide program this year to label fluorescent and high-intensity discharge (HID) lamps that contain mercury, as well as their packaging.72 This will not be quantitative labeling, indicating the amount of mercury content, but qualitative labeling acknowledging that the products contain mercury. To provide users with current information about disposal laws, NEMA developed a website, www.lamprecycle.org, with links to disposal regulations in all states and a list of lamp recycling companies. The internationally recognized symbol for mercury, Hg, will be labeled on each lamp to indicate that it contains mercury. The package label will state: Hg - LAMP CONTAINS MERCURY MANAGE IN ACCORD WITH DISPOSAL LAWS See www.lamprecycle.org or 1-800-XXX-XXXX

Pacific Northwest: Washington and Oregon

Soaring sales of CFLs in the Pacific Northwest have prompted municipalities and states in the region to consider developing recycling programs aimed at households. Thus far, household hazardous waste programs run by cities and counties handle most CFL recycling, and the number of CFLs being recycled remains minimal. Most are being sent to landfills. Surveys of recyclers in the Northwest confirmed that only about 15,000 of the more than one million CFLs that reached end-of-life in the region in 2001 were recycled.73 Washington recently produced the Mercury Chemical Action Plan to identify sources of anthropogenic mercury in the state and possible strategies for further mercury reduction, and to make recommendations for action to be taken by the state Department of Ecology and state Department of Health.74 Shortly after the report was released, the Washington House unanimously passed HB1002, which will require a label to indicate that a product, including fluorescents lamps, contains mercury. The Governor recently signed this
71

Personal communication Tom Benoit, Hazardous Materials Specialist, Vermont Department of Environmental Conservation, September 4, 2002. 72 See NEMA online press room, www.nema.org/DocUploads/7F72D825-D4B4-48229BA6678E1F1F017E//Lamp_Label_PR.doc. 73 Ryan Marquardt, Zero Waste Alliance, p. 17. 74 Washington Mercury Chemical Action Plan, January 2003, http://www.ecy.wa.gov/pubs/0303001.pdf Final Draft Page 29 5/30/2003

Mercury Education and Reduction Act into law, with labeling scheduled to go into effect January 2004. However there may not sufficient money to fully fund the programs implementation. The Oregon Senate is also considering a bill, SB 818, requiring labeling of products containing mercury and their manufacturers to develop a plan for recycling and collection. Under the proposed legislation, CFLs and linear fluorescent lamps will be required to include labeling and notification. Lamps will not fall under the extended producer responsibility component, so no mandatory recycling requirements are pending for them at this time. The Senate Committee heard testimony in March 2003, but no additional hearings have been set.75 Additionally, a stakeholder group that includes representatives from the Northwest Energy Efficiency Alliance, local utilities, Ecos Consulting, lamp manufacturers, and recyclers has been convened to study whether and how a CFL recycling program might be pilot-tested. Options under consideration included a curbside program, retail collection sites (like Minnesotas), mail-back collection, and expanding household hazardous waste capacity. A report with recommendations for a retail-based pilot is due in the spring of 2003 from the Zero Waste Alliance.

V.

Findings, Conclusions, and Recommendations

This is a topic marked by significant complexity, uncertainty, and controversy. Stakeholders disagree in significant ways about much of the key science needed to inform the debate, including the fraction of mercury in a spent lamp that is available for release into the environment, the degree to which landfills can contain mercury waste, and the extent to which research performed on linear fluorescent lamps can usefully inform policy debates over compact fluorescent lamps. After assessing the many sides of the above controversies and others, Ecos has reached the following principal findings:

Findings
1) Of the total amount of U.S. anthropogenic mercury released into the environment per year, we estimate that the share contributed by fluorescent lamps is 0.6% to 1.1%, affirming EPAs main findings. Compact fluorescent lamps currently represent about 1% to 2% of mercury emissions from lamps, and 0.006% to 0.002% of gross total U.S. mercury emissions. CFLs share of the fluorescent total is likely rising over time, but only modestly so. 2) Total fluorescent lamp emissions are declining over time as a result of at least five factors: a. Declining average amounts of mercury used in the manufacturing of each new lamp.
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b. Growing market preference for thinner lamps with greater energy efficiency and lower average mercury content. c. Increasing recycling rates for linear fluorescent lamps. d. Increasing stringency of mercury control at incinerators. e. New state regulations that prohibit fluorescent lamps from being discarded in landfills or incinerators, which likely reduces breakage during disposal. 3) The vast majority of fluorescent lighting substitutes for less energy efficient lighting alternatives, such as incandescent lamps. As a result, fluorescent lighting prevents substantial mercury emissions at coal-fired power plants, which account for about 55% of total U.S. electricity production. We estimate that a linear fluorescent lamp prevents about 5 to 10 times as much mercury emissions from power plants as it contains, and at least 12 to 60 times as much as it releases to the air if broken at end of life. We estimate that a CFL prevents about 1 to 4 times as much mercury emissions from power plants as it contains, and at least 2.5 to 24 times as much as it releases to the air if broken at end of life. 4) Fluorescent lamps also prevent the emissions of large amounts of greenhouse gases and other pollutants, reduce consumer energy bills, and last far longer than incandescent alternatives. Thus the net benefits of fluorescent lamps to society are substantial, even in parts of country with minimal reliance on coal plants. 5) Once purchased, fluorescent lamps face many different fates, ranked in Table 6 in order from highest to lowest net release of mercury to the environment: Table 6 Independent Impacts of Lamp Age at Failure, Handling Conditions, and Ultimate Fate of Fluorescent Lamps on Their Overall Mercury Impact76
Lamp Age at Failure Accidentally broken when new (no power plant emissions prevented, nearly all bulb mercury released) Fails before design life Achieves design life Exceeds design life Greatly exceeds design life (maximum power plant emissions prevented, most bulb mercury bound to glass or metal)
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Handling Conditions Broken indoors (maximum health risk) Broken in open, leaky dumpster (high risk of air and water pollution) Broken in transport or on landfill surface (some pollution likely) Broken after burial in lined landfill (most mercury contained) Broken inside recycling chamber (nearly all mercury recovered)

Ultimate Fate Incinerator (some mercury released to air) Unlined landfill (potential for air and water pollution) Lined, monitored landfill Hazardous waste landfill Recycling facility (nearly all mercury recovered)

Environmental Impact Highest Moderately High Moderate Moderately Low Lowest

Note that each column represents an independent type of environmental impact. So, for example, incineration represents the most environmentally harmful ultimate fate of a fluorescent lamp regardless of the lamps age or how it is handled after failure. Page 31 5/30/2003

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Source: Ecos Consulting

6) The key activity to discourage with lamps is their breakage, especially when new. Once a fluorescent lamp has operated for something close to its design life, the net mercury benefits achieved are significant, even if the lamp is discarded.

Conclusions and Recommendations

It is good policy to want to impose responsibility for cleanup of mercury emissions on the manufacturers of mercury-containing products, and in general this is an efficient way to accomplish this. However, Ecos believes that CFLs represent a special case, because they not only prevent more mercury emissions than they cause, but they are more challenging and costly to recycle than other products that prevent mercury emissions, like linear fluorescent lamps. They are also much less established in the US market than linear tubes. Mercury product labeling schemes proposed so far would do little to encourage best practice (i.e., lowest mercury content and/or improved lamp light output or lifetime performance) as long as some mercury is needed to illuminate a fluorescent lamp. To the extent products are labeled as containing mercury at all, they should quantitatively state how much they contain, so products containing the lowest mercury can gain a decisive market advantage with customers seeking to minimize environmental impact. While recycling fluorescent lamps reduces environmental impacts relative to discarding them, such programs should be considered in a broader context of overall environmental impact and cost effectiveness. Namely, which policies and programs can keep the most mercury out of the environment for the least money? As Figure 6 indicates, below, some consumer products like thermometers and mercury switches contain large amounts of elemental mercury, and represent obvious candidates for exchange and recycling programs. Note that such products contain amounts of mercury measured in grams, vs. milligrams in fluorescent lamps, so recycling one thermometer can recapture as much mercury as recycling hundreds of fluorescent lamps regardless of type. Linear fluorescent lamp recycling and implementing control measures at coal-fired power plants also appear to be relatively cost effective policy options. By contrast, CFL recycling appears to be a very expensive way to recapture not very much mercury. NRDC should support state and federal policies that allow lamps below a certain mercury-content threshold to continue to be discarded at properly lined municipal solid waste landfills. This is likely to encourage continued innovation by manufacturers to reduce mercury content, while improving cost effectiveness. By contrast, regulations that require recycling of all mercury-containing products, regardless of the amount they contain, do not reward further source reduction and can be very expensive per milligram of mercury recovered. Without proactive support for source reduction, we as a society cause unnecessary environmental harm by putting too much mercury in each new lamp to begin with. We then
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spend too much money trying to transport each lamp carefully to a facility and recycle it, all in an attempt to prevent a problem best prevented through better design at the factory. One way to increase producer responsibility for mercury and foster greater innovation by manufacturers toward best practice would be to impose a substantial tax on the production or final sale of mercury. It could likewise be assessed on imported mercury-containing products as well. This would not only discourage the release of mercury into the environment, but it would greatly improve the economics of recycling, making it possible for such a process to eventually be internally financed. While this would raise the first cost premium fluorescent lamps face relative to incandescent lamps, it would increase their lifecycle cost advantage (since coal-fired power would become more expensive). The energy efficiency community should support linear fluorescent lamp recycling regulation, but approach CFL recycling with caution. The volume of T8 and T12 lamp populations and their average mercury content are significant enough to warrant recycling, but CFLs will continue to be challenging, given their relative position in the US market and the cost effectiveness issues noted above. In all cases, it is important to remember that regulations that deter business and household use of fluorescent lamps could be more detrimental to the environment and public health (by discouraging energy savings) than the mercury found in the lamps themselves. The hassle or cost associated with a need to recycle CFLs because of mercury could give tentative consumers yet another reason to switch back to incandescent lamps. Using public utility funds to recycle CFLs may be especially problematic, since it reduces the money available to fund the more societally beneficial activity of encouraging the products purchase in the first place.

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Figure 6
Range of Cost Estimates per Milligram of Mercury Reducing Measures

70 66.67 60

50

Cost (Cents/mg)

40

30

20 12.89 6.25 0 0.01 to 0.17 0.20 to 1.00 0.83 1.20

10

12.00

Thermometer Recycling

Auto Switch Exchange

Linear Lamp Recycling

Air Pollution Control on Coal Plants

CFL Recycling

Measure

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Appendix A Assumptions and Sources for Figure 6

LOW mg 500 1000 5 3 LOW LOW $ $/mg $0.17 $0.0000833 $2.00 $0.0020000 $0.10 $0.0083333 $0.0076389 $0.50 $0.0625000 HIGH mg 2000 1000 12 8 HIGH HIGH $ $/mg $0.83 $0.001667 $10.00 $0.010000 $0.60 $0.120000 $0.160417 $2.00 $0.666667

Measure Thermometer Recycling Auto Switch Exchange Linear Lamp Recycling Air Pollution Control on Coal Plants CFL Recycling

Thermometer Recycling: Jim Mansfield, Clark County Dept. of Public Works. Washington. Clark County Thermometer Exchange with Hi School Pharmacy. Paid for disposal costs 6,000 thermometers with an average of 2 gm of Hg per thermometer $979 to recycle (also included other Hg containing products). Low mg 500 mg per thermometer EPA Factsheet High mg Clark County Program Low cost - $1000/6000 High cost - $5000/6000 Auto Switch Exchange Source: Rich McConaghy, City of Vancouver, WA Fall 2001 Clean Car Campaign Auto switch program for the City fleet. Approximately 500 vehicle switches exchanged. Average of 1 gm of Hg per switch. Cost $1 for new switch. 3 to 6 minutes time to change out switches. Low mg 1000 from program High mg 1000 from program Low cost = $1 +3 minutes *$20/hour mechanic rate = $2 High cost = $4 + 6 minutes * $60/hour mechanic rate = $10 Linear Lamp Recycle Low mg = 5 mg best practice Table 1 High mg = 12 mg national average Table 1 Low cost = $0.05 recycle cost from Bethlehem (NJ) + $0.5 for transport, handling High cost = $0.50 recycle cost + $0.10 for transport, handling

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Air Pollution Control on Coal Plants From: pg. 2-8 U.S. Environmental Protection Agency. Office of Solid Waste. Mercury Emissions from the Disposal of Fluorescent Lamps. Revised Model. Final Report Post-OMB Review. March 31, 1998. Installation of high efficiency lighting will reduce mercury emissions from coal-fired power plants. In this section the Agency provides an estimate of the mercury emissions avoided as a result. (Please note that neither oil-fired nor natural gas-fired plants emit significant amounts of mercury.) Therefore, EPAs focus is on coal-fired units. Electrical Generation in the United States totaled 2,825,023,000,000 kilowatt hours (kwh) in 1991.11 The draft Mercury Report To Congress estimated mercury emissions from coalfired utility boilers as 46.3 megagrams per year (Mg/yr) from 1990 through 1995.12 We developed an emissions factor in milligrams per kwh by dividing the 46.3 Mg/yr of emissions by the electric generation of 2,825,023,000,000 kwh, which resulted in an emissions rate of 0.016 mg/kwh. Mg low and high Emission rate = 0.3 mg/kWh based on average coal emissions rate of 0.0448 lbs/MWh from EPA's Emissions & Generation Resource Integrated Database E-GRID 2000 (version 2.0). Emission rate = 0.3 mg/kWh = 0.016/55% - total amount of coal generation Removal rate 80% from New Jersey Mercury Task Force Report. Sources of Mercury in New Jersey. Volume 3. Chapter 3. Page 185. January, 2002. 0.3*80% = 0.24 mg/kWh removed. Low cost = 0.2 mils/kwh Average of low end of Hg control costs in Table B-1 from in Massachusetts Bureau of Waste Prevention. Evaluation of the Technological and Economic Feasibility of Controlling and Eliminating Mercury Emissions from the Combustion of Solid Fossil Fuel. December 2002. Appendix B. High cost = 2 mils/kWh Average of high end of Hg Control costs in Table B-1 from in Massachusetts Bureau of Waste Prevention. Evaluation of the Technological and Economic Feasibility of Controlling and Eliminating Mercury Emissions from the Combustion of Solid Fossil Fuel. December 2002. Appendix B. CFL Recycling Costs Low mg = 3 best practice from Table 1 High mg = 8 high end of national average from Table 1 Low cost = $0.50 is based on $0.05 to $0.35 cost for recycle (from Zero Waste Alliance) + $0.15 collection, transport cost. High costs = $2.00 is based on $1.00 recycle cost (from Zero Waste Alliance) + $1 collection and transport cost. Also estimate for recycling program in Minnesota Zero Waste Alliance.

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