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Q&A: Disposal of Used X-Ray Lamps

Q&A: Disposal of Used X-Ray Lamps

This question was posted on a Yahoo Group, of which I am a member, back on January 22, 2016:

A very happy Friday to all.

Here is an interesting one.

I have five used X-ray Lamps to dispose of.

Ohio makes this difficult.

The Ohio Department of Health claims that Ohio EPA has declared the lamps a Hazardous Waste.

They actually state that the lamps con only be disposed of by “approved Vendors”.

They have a web page with a list of these Vendors.

These vendors are running a scam by way overpricing the disposal citing ODH, Ohio EPA rules and requirements.

I have seen prices from $125.00-$425.00/lamp.

This is complete Client Abuse.

Ohio EPA has no idea what ODH is doing about this.

The lamps are not a Hazardous Waste. (Ohio EPA confirms this)

The lamps are X-ray emitters only if energized.

There is no lead.

We might have silver since the electrical contact need to be of a higher temperature material than lead.

We might have a beryllium ring as part of the structure.  This is not a hazardous waste nor is it dangerous unless we have the dust form.

The lamps have one of the noble gasses inside and they are under pressure.

Dropping or banging one can cause the lamp to shatter and explode.

I am looking for a vendor that can dispose of the used X-ray lamps in a safe and economical manor.

Any ideas would be useful.

I had five lamps, this is down to four lamps and a bunch of pieces.

These puppies are heavy and slippery.

I can legally destroy these items myself.  I would rather not do that.  But I can be persuaded.

HELP!!!

Normally many others reply to these questions before I get a chance but this time I was right there with an answer:

The lamps you describe may be a hazardous waste due to the presences of silver.  The presence of a concentration of silver in the leachate (aka: extract) created by the waste equal to or greater than 5 mg/L (same as parts per million) would require the D011 hazardous waste code for the characteristic of toxicity per 40 CFR 261.24.  40 CFR is the federal regulation and not the state of Ohio but Ohio EPA has incorporated this federal regulation into its own.

The presence of D011 and other toxins can be determined by analysis with the Toxicity Characteristic Leachate Procedure (TCLP).  Or, as the generator of the waste you may assume that it contains silver at toxic levels.
However, federal and state regulations allow you to manage a lamp or bulb that is a hazardous waste as a universal waste.  This article of mine summarizes the universal waste regulations of Ohio and Kentucky.
I am not certain but I don’t think the Ohio Department of Health regulates the management or disposal of hazardous waste or universal waste.  That is the responsibility of the USEPA & the Ohio EPA.
I see three options:
  1. Determine conclusively that it is not a hazardous waste.  Best outcome but may be difficult to prove.
  2. Manage as a hazardous waste.  Easiest to do but highest cost and regulatory burden.
  3. Manage as a universal waste.  Easy to do and may be an inexpensive disposal if you can find a universal waste recycler willing to take them.
I hope this helps.  Please don’t hesitate to contact me with any questions.
Daniel Stoehr
Daniels Training Services