/

Waste Management Procedures

Fluorescent Light Bulbs

Before you begin
Description
/ Burned-out / spent fluorescent light bulbs
Category
/ Scrap Fluorescent Light Bulbs (Unless broken):
  • Universal Waste Electric Lamp (Unless broken)
  • Non-hazardous, Not regulated by DOT
  • Non-exempt recyclable material
Broken Scrap Fluorescent Light Bulbs:
  • Hazardous Waste D009-Mercury
  • Regulated by DOT as UN 2808 Waste Mercury contained in Manufactured Articles

Analysis
/ No analysis is required
Accumulation
/ Physical requirements:
If damaged, ruptured or leaking, place in closed plastic container.
If not damaged:
  • Flourescent light bulbs must be packed without other materials in the container or package.
  • Place in a contain/box provided by Safety-Kleen.
Administrative requirements:
Under federal and Louisiana regulations, fluorescent light bulbs may not be accumulated for more than one year before shipment to the recycle facility. The generator of the universal waste must be able to demonstrate the length of time that the waste bulbs have been accumulated on-site from the date they have become a waste. This is done by either:
  1. Placing each bulb in a container and marking (or labeling) thecontainer with the earliest date that a bulb (in the container) became a waste, or
  2. Mark (or label) each individual bulb with the earliest date that a bulb became a waste.
Maintain an inventory system on-site that identifies the earliest date that any bulb became a waste and the date it was shipped to the recycler.
Waste Reduction
/ Avoid breaking the bulbs. Broken bulbs are classified as hazardous waste. Unbroken bulbs are classified as universal waste [non-hazardous].

Continued on next page

Fluorescent Light Bulbs

Before you begin,(continued)
Disposal
/ Send to a facility that will separate the mercury and beneficially reuse or recycle both the metal and the glass.
Recordkeeping
/ If non-hazardous waste (Bulbs not broken):
  • List on General Cargo Manifest
  • Maintain copy of records at offshore and shorebase facilities while active.
  • Send original manifests with shipment.
  • Retain records for three years.
If hazardous waste(Broken bulbs):
  • Complete entry in Hazardous Material Section [Section I] of theFieldwood Energy Shipping Manifest prior to transportation.
  • Complete all Uniform Hazardous Waste Manifest, EPA Form 8700-22b, for hazardous waste.
  • Maintain copy of records at offshore and shorebase facilities while active.
  • Send original manifests with shipment.
  • Retain records for three years.

Shipping Instructions: FLUORESCENT LIGHT BULBS

[These instructions are for unbroken bulbs only]

1.Call or FAX Dock/Base to schedule shipment.

2.Package Scrap Fluorescent light bulbs as follows:

  1. Place in the 39 bulb box provided by Safety-Kleen.
  1. Mark Package:
  1. No DOT marking is required.
  2. Stencil Container-“Fieldwood Energy” and the generator’s location (i.e. EugeneIsland 158).

4.Label Package:

  1. No DOT Label is required.
  2. Use label provided by Safety Kleen.

5.Prepare shipping papers:

  1. Complete entry in General Cargo Section [Section II] of the Fieldwood EnergyShipping Manifest (See example).
  2. Complete bill of lading provided by Safety Kleen.
  • Sign the Non-regulated shipper’s certification, block 16b

6.Placard Vehicle/Vessel:

No DOT placard is required.

7.Load cargo:

No DOT hazardous material restrictions apply.

  1. No MSDS required.



Shipping Instructions: BROKEN FLUORESCENT LIGHT BULBS

1.Call or FAX Dock/Base to schedule shipment.

2.Package Broken Fluorescent Light Bulbs as follows:

a.Non-Bulk Packaging:

  1. Removable-head plastic drum 1H2.
  2. Removable-head steel drum 1A2 MUST HAVE A PLASTIC LINER.

3.Mark Package:

  1. “Waste Mercury Contained in manufactured articles , 8, UN 2808, PG III”
  1. Stencil Container -“Fieldwood Energy” and the generator’s location (i.e. EI 215-B)

4.Label Package:

  1. DOT "Class 8” label.(See example)
  1. EPA “Hazardous Waste” label.(See example)

5.Prepare shipping papers:

  1. Complete entry in Hazardous Materials Section [Section I] of the Fieldwood EnergyShipping Manifest (See example).
  • The material description “Waste Mercury Contained in manufactured articles, 8, UN2808, PG III” should be written in a blank line of Section 1. Enter the number 172 in the column headed “Emergency Response Guide” (See example).
  • If any single container holds more than 1 pound of Mercury, add the letters “RQ” after the words “Waste Mercury Contained in manufactured articles”. It is very unlikely that any single container will hold more than 1 pound of mercury.
  1. Complete all of Uniform Hazardous Waste Manifest, EPA 8700-22b for hazardous waste. (See example)
  2. Complete bill of lading provided by Safety Kleen.
  • Sign the US DOT REGULATED SHIPPER’S CERTIFICATION, block 16a

6.Placard Vehicle/Vessel:

a.For cargoes less than 1000 pounds and any Non-Bulk Packaging: No Placard required on transport vehicle.

b.See attached placard

Continued on next page

Shipping Instructions: BROKEN FLUORESCENT LIGHT BULBS, (continued)

  1. Load cargo in accordance with the following shipping limitations:

AIR / RESTRICTIONS (49 CFR 172.101)
Passenger Aircraft / No Limit
Cargo Aircraft / No Limit
WATER / RESTRICTIONS (49 CFR 172.101)
Cargo Vessels / Must be stowed either on deck or under deck, however under deck should be used if available.
Passenger Vessels / On deck only when a vessel under 246 feet length overall exceeds 25 passengers.
Other Requirements / Stow “Clear of Living Quarters”.
Stow “Away from azides”.

8.Include MSDS with shipment.


Version 0, October 2013Page 1 of 9