A Project for Recovering Mercury from Fluorescent Tubes from Schools in the Grand Erie District School Board Prepared by: The Recycling Council of Ontario (RCO) October 2005 with funding support from: The Mercury Recovery Board This report was prepared by the Recycling Council of Ontario (RCO) RCO 51 Wolseley St, 2nd Floor Toronto, Ontario M5W 1B2 (416) 657-2797 www.rco.on.ca Project Acknowledgements This pilot project was funded by the Mercury Recovery Board and managed by the Recycling Council of Ontario (RCO). Project implementation was a result of the partnership between the RCO, the Grand Erie District School Division (GEDSB) and Florescent Lamp Recyclers (FLR). Contributers to the project Jo-Anne St. Godard, Executive Director, Recycling Council of Ontario Sarah Mills & Tammy Chung, Project Coordinators, Recycling Council of Ontario Joe Saldarelli, Manager of Facility Services, Grand Erie District School Board Tom Oldham & Randy Smith, Custodial Team Leaders, Grand Erie District School Board Tom Maxwell & Dan Power, Florescent Lamp Recyclers 2 Project Background & Objectives Targeting Mercury Mercury is a persistent, toxic substance widely recognized as a threat to the environment and human health. Once airborne, mercury compounds can be carried hundreds of kilometers. Inhaling mercury vapours or ingesting mercury can cause serious injury or death. High levels of exposure may cause birth defects, permanent brain or kidney damage and death. 1 Despite mercury's toxicity and the availability of alternatives for almost all uses, 100 tonnes of mercury is used deliberately each year in Canada, in thousands of products such as fluorescent lamps, thermostats, fever thermometers and button batteries, as well as a variety of industrial applications. In November 2004, the Recycling Council of Ontario (RCO) submitted a project proposal to the Mercury Recovery Fund, targeting the recovery of mercury from fluorescent lighting tubes. The project, which targeted schools, within the Grand Erie District School Board (GEDSB), was approved and an official Terms of Reference was drafted (see Appendix A). The primary objective of the project was to pilot a program, over a period of 3 months, that would track, collect and recycle sufficient number of fluorescent tubes to successfully divert 2200 mgs of mercury that may otherwise be destined for landfill. The overall objective of the pilot FAST FACTS! project was to establish, through experience, an operating system to collect and recycle fluorescent tube The big three fluorescent lamp manufacturers in Canada are lighting and develop recycling guidelines for the GESDB Phillips, GE and Osram that would be transferable to other school districts. Sylvania. 8-foot lamps contain Why Fluorescent Lamp Recycling approximately 15-25 mg. of It is estimated that between 60-70 million spent mercury. fluorescent lamps are generated in Canada each year Mercury vapor and High and less than 10% of them are recycled2 . The most Intensity Discharge lamps have commonly used lamp (4 foot standard lamp) contains on approx. 200 mg. of mercury average, 11.6 mg of mercury3. Ensuring that these Compact fluorescents contain products are properly stored and recycled presents an on average 4mgs of mercury. important opportunity to capture the mercury they 20 pre-1986 4-foot fluorescent contain and divert their component materials from lamps represent 1kg of mercury. landfill. RCO managed and implemented the pilot in partnership with the GEDSB. The schools in the GEDSB provided a controlled setting, with large facilities that were in close proximity to the only fluorescent tube recycler in Ontario, Florescent Lamp Recyclers (FLR). Working with the GEDSB also presented 1 Mercury in the Environment, A Primer, Pollution Probe, June 2003 Power, Dan, Fluorescent Lamp Recyclers, Personal Interview. January 2005. 3 National Electrical Manufactures Association. “Environmental Impact Analysis: Spent Mercury-Containing Lamps.” January, 2000 (Fourth Edition). 2 3 an opportunity to develop guidelines for recycling FLR tubes and an educational resource for school boards and their operational/custodial departments. Project Partners The Recycling Council of Ontario – Project Proponent Established in 1978, RCO is an environmental, non-governmental organization and registered charity that promotes waste reduction and recycling programs in Ontario. RCO’s mandate is to minimize society’s impact on the environment by eliminating waste. Its mission is to inform and educate all members of society about the generation of waste, the avoidance of waste, the more efficient use of resources, and the benefits and/or consequences of these activities. Over the years, its mandate has evolved to include research, policy development, advocacy, public education and demonstration projects. Mercury Recovery Fund – Project Funder The Mercury Recovery Fund was set up to create and sustain mercury-product collection, as a means of reducing toxic mercury emissions. Through a combination of research, financing and direct project management, the organization promotes and supports mercury-product recovery efforts. The Grand Erie District School Board – Pilot Participant Partner The Grand Erie District School Board (GEDSB) is a medium sized school board in the Province of Ontario. It encompasses an area of 4,067 sq. km. in south-central Ontario and includes the City of Brantford and the Counties of Brant, and Halidmand-Norfolk. Major cities and towns are: Brantford, Caledonia, Cayuga, Delhi, Dunnville, Hagersville, Paris, Port Dover, Simcoe and Waterford. The area’s population is approximately 223,000. GEDSB is comprised of 94 schools, 69 elementary, 15 secondary and 10 closed schools servicing approximately 30,000 students. In addition, the GEDSB maintains five administration buildings. Total square footage managed by the GEDSB facility department is 3.8 million. Fluorescent Lamp Recyclers – Recycling Partner Fluorescent Lamp Recyclers (FLR) managed all of the recycling of fluorescents lamps received from the GEDSB during this project. The company has been recycling fluorescent lamps since 1995. Notable clients include the Toronto District School Board, EcoSuperior – an environmental non-government organization based in the Lake Superior watershed areas, and various other Ontario school boards. At the completion of this project, there are four other Canadian companies in the fluorescent lamp recycling business, Environmental Lamp Disposal Ltd4. and Proeco 4 Environmental Lamp Disposal Ltd. Retrieved from the World Wide Web 3 June 2005. www.environmentallamp.com 4 Corporation5 both located in Edmonton, Alberta. Nu Life Industries Inc.6, located in British Columbia, and RLF7, located in Coteau Du Lac in Quebec. FLR is the largest fluorescent lamp recycler, processing 40-50% of all lamps recycled in Canada8. In addition, FLR is conveniently located for this project FLR Recycling Process FLR has its own fleet of transport vehicles to pick-up fluorescent lamps stored in cardboard boxes or specialized collection containers which are delivered to FLR’s recycling facility in Ayr, Ontario. Once at the recycling plant, fluorescent lamps go through the following processes. Lamps move on conveyor to a negative pressure containment area. Lamps are then broken in the negative pressure machine to allow the capture of glass, aluminum, brass, and phosphor-mercury powder. The broken glass is transported to Nexcycle Industries in Guelph, and then forwarded to Owens Corning where it is turned into fiberglass products. The metals are sent to Woznuk Brothers Metal Recycling in Cambridge for further processing and then forwarded to a smelter. The phosphor-mercury powder is put into a retort treatment unit where it is heated to separate the mercury from the phosphor powder. The mercury is collected and allowed to cool to liquid form and then sent to Bethlehem Apparatus in Hellertown, Pennsylvania, in one tonne containers where it is triple distilled and then sold as a product. The phosphor powder that is comprised mainly of calcium phosphate is sent to various outlets, depending on market conditions. At the writing of this report the phosphor powder generated during the fluorescent lamp recycling process was sent to Bethlehem Apparatus, through Raw Materials Corporation (RMC), a transfer station in Port Colbourne, Ontario. During the recycling process, each lamp is separated into its individual elements (glass, aluminum, phosphor powder and mercury) and recycled. Over 98% of each lamp is recycled and diverted from landfill.”9 FLR specializes in treating all mercury containing lamp waste including fluorescent tubes, mercury vapour, metal halide, high-pressure sodium, high intensity discharge and compact fluorescents. A visual representation of the fluorescent lamp recycling process is available in Appendix B. FLR also treats PCBs, and acts as a hazardous waste transfer facility under eight Certificates of Approval (C of A’s), four of which are specific for their fluorescent lamp recycling processes. All relevant C of A’s are still valid and active as of April 2005. For more information on FLR’s individual C of A’s see Appendix C. 5 Proeco Corporation. Retrieved from the World Wide Web 3 June 2005. www.proeco.com. Nu-Life Industries Inc. Retrieved from the World Wide Web 3 June 2005. www.nulife-ind.com. 7 Menard, Chantal, RLF. Personal Interview. 3 June 3, 2005. 8 Power, Dan, Fluorescent Lamp Recyclers. Personal Interview. January 2005. 9 Fluorescent Lamp Recyclers (FLR) Technologies Inc. “We Take Recycling Further.” Ayr, Ontario. 2005. 6 5 Regulations affecting the handling and disposal of Florescent Lamps in Ontario While there is currently no legislation in Ontario that specifically refers to fluorescent lamp disposal or recycling specifically, fluorescent lamps are considered a leachate toxic hazardous waste, under Environmental Protection Act, Regulation 34710. Generators that produce or handle more than 5kg (approximately 20 standard 4 foot fluorescent lamps) per month for disposal are subject to this regulation. These generators must register with the Ontario Ministry of Environment on an annual basis as Hazardous Waste Generators11. Generators who are producing or handling less than 5kg of mercury per month are considered “small quantity generators” and are not subject to regulation. Current Disposal Practices at GEDSB All custodial products, including fluorescent tubes are supplied on a five-year contract by Dominion Supplies, a single source supplier for custodial products. The school board spends approximately $25,000.00 annually on fluorescent lamp purchases, and disposes of about 10,000 fluorescent tubes each year12. New tubes are delivered one to three times per year to each school on an as needed basis. Each tube has a life of about 5 years. Currently, GEDSB uses a Random Replacement Method (RRM) for replacing and disposing of spent fluorescent tubes. A case (or cases) of lamps are delivered to each school, usually ordered by the school’s custodian when needed. Custodial staff regularly surveys facilities for spent fluorescent lamps and replaces them as they expire. Spent lamps are stored in an empty fluorescent lamp box, when full; the boxes are disposed though the regular disposal methods, that is, tubes are placed in a dumpster along with the regular garbage. In the case of GEDSB, dumpsters are emptied by either Abco/Kingswood, which services the schools in the County of Brant, or Norfolk Disposal, servicing the schools in the Counties of Haldimand and Norfolk. Waste picked up by Abco/Kingswood goes to the City of Brantford municipal landfill, while Norfolk Disposal takes the waste collected from GEDSB to the Ridge Landfill Site in Blenham, Ontario in south-central Chatham-Kent. This type of disposal method is permissible as each school disposes of fewer than 20 fluorescent lamps (or 5 kgs of mercury per month). Under the current regulation, GEDSB is defined as a small generator and is exempt from Regulation 347, meaning they are not required to manifest or register the waste with the provincial government. The Pilot Study The pilot study to collect and recycle fluorescent lamps from the GEDSB, was designed 10 Okuhara, Dick. Ontario Ministry of Environment. Personal Interview. 3 June 2005. Ontario Ministry of Environment. Environmental Protection Act - R.R.O. 1990, Reg. 347. 3 June 2005. 12 Saleralli, Joe, Grand Erie District School Board. Personal Interview. 8 February 2005. 11 6 to quantify the amounts of mercury containing fluorescent lamps available for proper recycling and to facilitate diversion of these materials by coordinating efforts at each of the schools within the division and FLR. Objectives The primary objective of this project were to; Identify through a controlled environment, opportunities to collect fluorescent lamps form the GEDSB otherwise destined for landfills in Brantford and Chatham-Kent, Recover a minimum of 2200mg of the available mercury and ensure proper recycling of all lamp components. Quantify the of the amount of mercury, which could be captured through the recycling of end-of-life lamps Create a guidance document, focused at school board trustees, operational and custodial staff, which provided information about the harmful affects of mercury, identifies the mercury containing products in schools and the proper storage and recycling options currently available. This document was to be designed to ensure transference to other schools and ICI establishments. GEDSB’s Responsibilities The GEDSB was responsible for collection and storage of the spent fluorescent lamps at each participating school site until the scheduled collection date. GEDSB was to communicate diversion activities to the RCO. GEDSB contributed the following information to the RCO List of all schools in the GEDSB and their associated custodian(s) Contact information for equipment supplier(s). Number of florescent tubes being diverted per school to the pilot project Estimate of the number of spent lamps generated each year by the GEDSB FLR’s Responsibilities As an experienced fluorescent lamp recycler, FLR was responsible for Providing advice and information on fluorescent lamp usage, Providing insight into the design of the collection program Providing costing information, prior to the start of the fluorescent lamp collection process. Coordinating the actual collection of spent fluorescent lamps from each school Ensuring each lamp was recycled in an environmentally sound manner. RCO’s Responsibilities As the lead proponent of the study, RCO was responsible for the following tasks: Ensuring project “buy-in” and participation from all project partners Facilitating communications between project partners Ensure lamps were stored and properly recycled 7 Track and record all data Writing the final pilot project report Developing guidelines for proper diversion of fluorescent lamps from schools and other ICI facilities Researching, designing and developing an educational resource directed toward school boards, operational and custodial staff which provides details on mercury, the importance of its diversion from landfill, and guidelines on implementing a diversion program. 8 Estimated Mercury Capture Rate for 3 Month Study Period In order to quantify generation and diversion numbers, the proponent utilized the following equation provided by FLR. Calculating the number of fluorescent tubes in use at GEDSB 3.8 million sq ft / (1 light fixture for every 50 sq ft) = 76,000 light fixtures. Classrooms typically have fixtures with two lamps13; therefore the total number of lamps at in use at GEDSB is 152,000. The industry standard for the replacement of fluorescent lamps is three years14. However, the GEDSB typically has received, on average, 5 years of life from their lamps, therefore generating about 10,000 spent lamps per year (approximately 80% fewer spent fluorescent lamps than the industry standard). It is understood that the number of spent lamps replaced per year may fluctuate pending on whether GEDSB undergoes re-lamping projects15 in addition to their regular maintenance. Based on a 1999 survey by the National Electrical Manufacturers Association (NEMA), “The average four-foot fluorescent lamp contains about 11.6 milligrams (mg) of mercury This number has been steadily declining as lamp manufacturer’s work to reduce mercury content to the minimum amount technically feasible without reducing lamp life. The average four-foot lamp today contains over 75% less mercury than the same lamp would have contained in 1985,16 when lamps contained about 48.2 mg of mercury. Table 1 shows the number of fluorescent lamps likely in use at GEDSB facilities, and the estimated quantity of mercury generated in one year and in 10 years in comparison with the replacement rate of lamps in the average office building. Note this information does not include re-lamping retrofit projects that may occur during that 10-year period.. Table 1: Fluorescent Lamps in use at GEDSB Facility Industry Standard GEDSB Facility Sqft 3.8 million Light Fixtures 76,000 # of lamps in use 152,000 Lamp life (yrs) 2-3 # of spent lamps/yr 50,000 3.8 million 76,000 152,000 5 9200 Quantity of Hg/yr 58,000g100,000g 10,672g18,400g Quantity of Hg in 10yrs 580,000g1,000,000g 106,720g184,000g 13 Maxwell, Tom, Joe Saldarelli. Personal Interview. 31 January 2005. Maxwell, Tom. Personal Interview. 31 January 2005. 15 A re-lamping project refers to a lighting retrofit project where all the fluorescents lamps (spent or unspent) are removed and disposed of to allow for the installation of new lighting fixtures and new fluorescent lamps. 16 National Electrical Manufacturers Association. “Fluorescent Lamps and the Environment: Mercury Use, Environmental Benefits, Disposal Requirements.” Rosslyn, Virgina. January 2001. 14 9 For the last several years, and up until November 2004, the GEDSB purchased primarily Phillips brand fluorescent lighting of the following types for their facilities: Compact Fluorescent Lamps 3’ Fluorescent Lamps 4’ Fluorescent Lamps At present it is not possible to generate an exact quantity of mercury contained in each of the above listed lamps. Mercury levels vary pending on the following; the manufacturer producing the lamp, the location or facility it was manufacturer and the age of the lamp or timeframe it was manufactured (older lamps tend to contain more mercury than those manufactured more recently). Table 2 provides details on how many lamps were purchased at the GEDSB in 2004 and extrapolates what that means in terms of mercury usage. Table 2: 2004 Fluorescent Lamp Purchased at GEDSB Lighting Type Hg/lamp (mg) Lamps/yr Compact Fluorescent 417 1285 18 3’ & 4' Fluorescent Lamps 11.6 7848 TOTAL 9133 Total Hg 5140 91,036 96,176 Assuming that the GEDSB purchased lamps to replace spent lamps, we can use the information in Table 2 to estimate how much mercury was landfilled from the school board last year and therefore determine how many fluorescents lamps can be diverted for this pilot project. In addition, the GEDSB has been working with Ameresco (formerly Duke Solutions) since November 2004, to retrofit the fluorescent lamping of 15% of their schools. Once the re-lamping is complete, most lamps in the retrofitted schools will not need to be replaced for about 5 years (the standard life of a fluorescent tube at the GEDSB). Ten schools remain to be retrofitted between March and May 2005. In a three month period, using the “random replacement method” coupled with the scheduled retrofits, it was expected this pilot project could divert as much as 70,000 mg of mercury from spent fluorescents from landfill disposal. Table 3 below details that estimate. Table 3: Quantity of Mercury to be Diverted During Pilot Project Spent Lamp Generation Lamps Hg 3 Month Random Replacement 2283 26,482 mg Re-Lamping Retrofit 3823 44,347mg Estimated Total Mercury 70,829 mg 17 National Electrical Manufactures Association, www.lamprecycle.org. “Fact Sheet: Mercury in Compact Fluorescent Lamps (CFL).” 2000-2003 18 National Electrical Manufactures Association. “Environmental Impact Analysis: Spent Mercury-Containing Lamps.” January, 2000 (Fourth Edition). 10 Transportation and Recycling Costs FLR provided RCO with their estimated transportation and recycling costs based on the projected recovery numbers. These costs were expected to vary pending on the number of tubes collected and the distance of each school. Cost estimates for transportation and recycling were as such: Recycling 94 participating schools recycling 30 four-foot tubes each at a cost of 12 cents per foot = $1353.60 Transportation $85.00 per school x 94 schools = $7990.00 Total costs for recycling and collection is estimated at $9343.60 Retrofitting While participating in the florescent lamp diversion pilot with RCO, GEDSB was also collaborating with Ameresco, to retrofit selected schools. The timing of this retrofit was expected to have a positive impact on the pilot program, in that more tubes were made available for overall recovery. Ameresco is a ‘first tier’ contractor that is coordinating all tasks related to the re-lamping retrofit including creating the retrofit plan, to hiring sub-contractors to dispose of the redundant materials. The company has worked on the retrofit of many schools including Thames Valley District School Board, Upper Grand District School Board, Kawartha Pine Reidge District School Board, Greater Essex County District School Board and Hamilton Wentworth District School Board. Ameresco has also designed an energy conservation program called EarthCARE, an environmental education partnership that is intended to involve all key stakeholders in the customization, implementation and celebration of energy savings and environmental stewardship at school and in the community. Ameresco also has an ongoing partnership with Fluorescent Lamp Recyclers (FLR). Fluorescent Lamp Collection Process Preparation In February 2005, RCO’s Project Coordinator met with Joe Saldarelli, the Manager of Facility Services at GEDSB, and Randy Smith and Tom Oldham, Custodial Team Leaders for the GEDSB, to learn more about the custodial operations of the GEDSB. The objective of the meeting was to estimate the quantity of spent fluorescent lamps available for study and to gain an understanding of the logistics required to ensure effective recovery. RCO gathered all information provided by the GEDSB staff and created a spreadsheet which detailed the names of the schools participating, custodial leaders at each of the 11 schools and details of the scheduled retrofits. The table was then forwarded to Tom Maxwell of FLR for input on the logistics and timing of the collection and recycling portion of the program. The completed spreadsheet is available in Appendix E. The table shows: Which schools in the GEDSB would be included in this project; The estimated number of lamps to be collected from each school; The estimated amount of mercury that can be diverted through this project; The transportation costs for picking up the lamps at the participating schools; The recycling costs for recycling the lamps from each of the participating schools; Each schools street address; Custodial contact for each school; and, Tentative fluorescent lamp collection dates. List List of schools with the GEDSB List of fluorescent lamp purchases for 2004 List of GEDSB custodians and the schools they support The 2004-2005 GEDSB contact directory GEDSB Light Replacement Plan list Provider Tom Oldham, GEDSB Shannon Buzek, Domclean/Dominion Equipment Sharon Stamper, GEDSB Sharon Stamper, GEDSB Wayne Heeg, Ameresco Collection Schedule Based on the information received from the various sources (GEDSB, Ameresco, Dominion Equipment and FLR), a logistics outline for collection of fluorescent lamps from GEDSB was prepared (shown in Appendix F). It was determined that the collection of fluorescent lamps from the GEDSB should occur in three phases. The first two phases, planned for March and April, would be based on the lighting retrofit currently in progress. Phase 3 would focus on those schools not planned for the relamp retrofit. Collection Results Despite attempts at including all spent lamps resulting from the retrofitting activities into the lamp recovery pilot program in Phase 1, only two of the four schools actually diverted their spent lamps for proper recycling through FLR. In the original information from Ameresco estimated the retrofits in the first 4 schools, would yield 1800 fluorescent lamps for recycling, resulting in 20,880 mg of mercury diverted. Unfortunately, the actual amount collected was significantly less, at 390 lamps or 4524 mg of mercury. 12 The final collection phases (2 and 3) were completed in June 2005 and August 2005 respectively. Spent lamps were collected through random replacements in 21 schools in the City of Brantford area results in the recovery of 568 lamps and the capture of 11,360 mg of mercury. The total number of lamps diverted to proper recycling at the end of the 3 month pilot project was 958, for a total diversion quantity of 15,884 mg of mercury. Recovery following the 3 month pilot time frame In October of 2005, GEDSB contacted RCO and FLR reporting another 5000 lamps in storage that had resulted from the scheduled retrofits during the project pilot. RCO has added these tubes to the project diversion rate, increasing the total number of lamps recovered 5 times to 5958 and 69,112.80 mg of mercury. Table 4 details the total amounts of lamps and mercury recovered and diverted during each phase of the pilot project. Table 4: Fluorescent Lamp Recycling & Mercury Capture Collection Phase Lamps Mercury Phase 1 390 4524 mg Phase 2 & 3 568 11,360 mg Late pickup (Oct. 05) 5000 58,000 mg Total 5958 69,112 mg Collection Date March 31, 2005 August, 2005 October 2005 13 Summary of the Project The florescent lamp recovery pilot project at the Grand Erie District School Board provided valuable information and insight into current trends, challenges and opportunities to divert spent fluorescent lamps and the mercury they contain, from landfill. Effective diversion was dependent on the project partner’s ability to continually communicate and adhere to project objectives. Core to the success of the recovery of the materials was clear direction and follow-through with the custodial staff of each the schools. Clear and consistent instructions, regarding proper sorting, storage and final destination of the lamps was key to maximizing recovery rates. The addition of a retrofit within the school division during the pilot, had both negative and positive affects on recovery. The exercise of retrofitting the lamping systems of entire buildings, provided increased opportunity to capture more materials. However, since Ameresco’s objectives were different from that of RCO’s, much of the waste materials created through the retrofits was not recovered for proper disposal. It is anticipated that in order to maximize the collection and recycling resulting through scheduled retrofits, a partnership with the company managing the retrofit must be established early in the developments of any recovery program. The projects’ ability to recover the total targeted amount of mercury within the very first phase of the pilot, is a clear indication of the opportunity that exists in schools, and other IC&I facilities. Unfortunately, as the existing regulation does not compel facility managers to divert fluorescent lamp wastes, participation will be based on a voluntary basis. Key to diverting florescent lamp wastes is the willingness and ability for on-site managers and facility staff, to coordinate the storage of lamps until quantities are sufficient to justify the costs of transportation and recycling. This pilot has proven that with very little effort, significant amounts of fluorescent lamps can be diverted, preventing mercury from entering landfill. The results and the resources developed within the purview of this pilot project will be shared with other school divisions to support the growth and expansion of florescent lamp recovery program in schools throughout the province. A template will be used to roll-out similar programs to other members within the IC&I sector. 14 APPENDIX A TERMS OF REFERENCE A PROJECT FOR RECOVERING MERCURY FROM FLUORESCENT TUBES FROM SCHOOLS IN THE GRAND ERIE DISTRICT SCHOOL BOARD Recycling Council of Ontario 51 Wolseley Street, 2nd floor Toronto, ON M5T 1A4 416-657-2797 15 PROJECT DELIVERABLES The project outlined in this proposal will aim to deliver the following: 1. Recovery of 2200 mgs of mercury from fluorescent tube lighting, from 94 sites over a 3month implementation period, equivalent to 206.8 grams (nearly 1 lb). 2. The development of operating systems and guidelines to enable a widespread, selfsufficient implementation of the project in the long-term. These systems would be implemented at either the Grand Erie District School Board or at the individual school level and allow all Ontario schools to recover mercury through proper disposal of fluorescent tube lighting. 3. The research, design and development of an educational resource directed toward school students, teachers and school boards, providing information on mercury and the importance of its recovery. BACKGROUND The Grand Erie District School Board is a medium sized school board in the province of Ontario. It encompasses an area of 4,067 sq. km. in south--central Ontario and encompasses the City of Brantford and the Counties of Brant, Haldimand and Norfolk. Major cities and towns are: Brantford, Caledonia, Cayuga, Delhi, Dunnville, Hagersville, Paris, Port Dover, Simcoe and Waterford. The area's population is approximately 223,000. Each school within this GEDSB has classrooms, offices, storerooms, cafeterias and common areas that utilize fluorescent tube lighting. The nature of fluorescent lighting means it contains mercury. Each tube contains between 3 - 6 mgs of the element. With an average of between 300 and 700 fluorescent tubes in use at each school every day, there is the potential to recover approximately (on average) 2200 mgs of mercury at each site. Fluorescent tube lighting is slightly more expensive to purchase than regular incandescent lighting but saves money in the long term through energy efficiency and length of life. Fluorescents use 60 to 80 per cent less energy than regular incandescent lights and last 10 to 15 times longer. They are though, the only consumer product sold in Canada containing mercury for which there are no costeffective alternatives. The hazards on human health and the environment are minimal when the lamps are in use, but at the point of disposal through landfilling, incineration and sewage, this toxic element can enter the environment negatively affecting the natural world and human health. Recycling fluorescent tubes offers an environmentally friendly and safe option for their disposal. Tubes are separated into individual components making them eligible for recycling. The toxic elements, such as mercury, are recovered and recycled, eliminating any liability of contamination. 16 ABOUT THE RECYCLING COUNCIL OF ONTARIO The Recycling Council of Ontario (RCO) is a multi-stakeholder with established links to the community. A membership based not-for-profit organization, its aim is to engage local communities and affect change. Since its inception in 1978, RCO has actively assisted municipalities, corporations, other organizations and individuals in reducing their waste. In 2001, RCO took a provincial program to the national level and launched Waste Reduction Week in Canada. This is one of the organization’s high profile outreach events and attracts attention from government, industry and the public throughout the year. RCO Mission Statement The Recycling Council of Ontario believes that society must minimize its impact on the environment by eliminating waste. We will carry this out by informing and educating all members of society about the generation of waste, the avoidance of waste, the more efficient use of resources and the benefits and/or consequences of these activities. The Recycling Council of Ontario’s guiding principles are: Full Cost Accounting – Goods and services should be priced to include their true environmental costs from all phases of production, transportation, distribution, use, reuse, recycling, composting and disposal. Shared Responsibility – The responsibility for minimizing environmental and economic impacts must be shared by all parties that benefit from and/or impact on the production, distribution, use, and/or disposal of products and packaging or delivery of services. Regulatory and Legislative Initiatives – Governments should intervene using regulatory and/or legislative mechanisms where voluntary initiatives are not in place or fail to adequately protect the environment. Non-Regulatory Initiatives – Non-regulatory environmental protection and remediation initiatives implemented on a voluntary basis should have mechanisms to monitor performance and there should be consequences for non-participants and/or failure to meet standards. Level Playing Field – Government(s) should support environmental initiatives that ensure equitable participation using incentives, disincentives or, if necessary, regulations. Economic Instruments – Financial incentives/economic instruments should be used to encourage the development and implementation of environmentally sound initiatives. Harmonization – Federal/provincial/municipal environmental policies and programs should be harmonized where possible and practical and should meet or exceed the highest environmental protection standards currently in use. Accountability – Participants in both voluntary and regulatory environmental programs and practices should be monitored and held accountable for meeting goals, targets or standards. Monitoring data and analyses should be publicly available. Communication and Education – Stakeholders should be adequately informed and educated as to their respective roles and responsibilities in environmental programs and the results of their participation in these programs. Public Participation – All stakeholders should have the opportunity to participate in the development of environmental policies and in the monitoring of environmental programs. Adequate resources should be made available to ensure such participation. Operational Efficiency – Environmental initiatives should promote the highest levels of efficiency and effectiveness through using ‘Best Available Technology’ and benchmarking. 17 PROJECT OBJECTIVES The primary objective of this project is to identify through a controlled environment, opportunities to collect fluorescent tubes otherwise destined for landfill, recover the available mercury and ensure proper recycling of all components. This will involve a detailed analysis of the amount of mercury, which is captured through the recycling of end-of-life tubes, allowing an assessment of the environmental benefits and successes of the project. A secondary objective of the project will be to provide the 32,000 students of the GEDSB with an educational resource providing information on mercury and the importance of its proper recovery, as well as the importance of proper storage, transportation and recycling of fluorescent tubes, and other mercury containing products. This resource could take the form of a poster or a simple activity sheet, which could be utilized by teachers and taken into the homes of each student. The students could be involved in the research and the design of the resource, through a poster competition and providing their insight into the positive aspects of recovering mercury from their lighting. PROJECT SCOPE The Recycling Council of Ontario (RCO) proposes to work with administrators and management of the GEDSB and Fluorescent Lamp Recyclers Inc (FLR) assuming the following tasks: 1. A pilot project will be undertaken documenting the present purchasing agreements, current uses, infrastructure and disposal rates for fluorescent tubes within all GEDSB buildings and amenities to include: Interviews with GEDSB purchasing staff Interviews with GEDSB building maintenance / janitorial management Interviews with existing waste contractors and or municipal service providers 2. A review of other programs will identify efforts to recover mercury from fluorescent tubes. This will include: Consultation with FLR Interviews with EcoSuperior Programs in Thunder Bay Internet search and literature review 3. An estimation of the amount of mercury released into the environment by improper disposal of fluorescent tubes from GEDSB buildings and amenities will be carried out: Determine an average number of tubes which are used per year through consultation with GEDSB management and document current disposal practices Quantify amounts of available mercury available for recovery Interview experts as to the amount of mercury, which may be released through improper disposal as well as the potential pathways for this release Data will be projected over a 10 year period to illustrate environmental and health hazards should a recovery and recycling system not be implemented 4. An outline of the physical system requirements and procedures for storing and transporting used tubes for recycling will be developed: 18 Technical information will be provided by FLR as to the storage and transportation of the fluorescent tubes; this will provide the basis of a simple assessment questionnaire for each school Data from this questionnaire will determine the feasibility of source separation storage and transport of the fluorescents as well as identify time and any physical constraints involved in the process in different sized schools A selection of these schools will then become part of a short-term implementation program, designed and monitored to establish guidelines for recycling of fluorescent tubes in all schools 5. Estimation of the monetary costs and environmental implications of proper storage, transportation and recycling of the tubes will be compared to that of improper disposal by landfilling or incineration: Identify financial costs of storage, transportation and recycling vs. disposal in consultation with GEDSB and FLR Consult with experts and government officials as to the environmental costs associated with improper disposal and any legislative requirements placed on mercury recovery and landfilling/incineration processes as these may result in monetary fines 6. Project is implemented across GEDSB schools for a 3-month monitoring period and results will be extrapolated. 7. An educational resource will be developed for the students and staff under trustee of the GEDSB: This resource will provide the school population with an insight into common consumer products which contain mercury and the effects their contents may have on their environment and their health This information will also be applicable to student’s residences thereby increasing the outreach of the resources to the entire school community 8. A summary of the findings, requirements, procedures and the amount of mercury recovered and recycled through the project will be developed to provide a template for other District School Boards to undertake a similar project. 9. The project findings and educational resources to be officially launched during Waste Reduction Week in Canada, October 17th – 23rd, 2005. This is an established national event spearheaded by RCO, which receives recognition from all levels of government, industry and the community in general. 19 SCHEDULE As per the project scope, the following timeline details tasks to be completed: Tasks Jan 2005 Feb Mar Apr May Jun July Oct 2005 1 – GEDSB study 2 – Program review 3 – Mercury quantification 4 – Logistics outline 5 – Cost comparison 6 – Project implementation 7 – Resource development 8 – Summary report 9 – Launch of report The Partners Contact Bob Kazopas Organization Ontario Power Generation Rob Maxwell Florescent Light Recycling Joe Saldavelli Grand Erie District School Board Jo-Anne St. Recycling Godard Council of Ontario Title Telephone 416.592.6438 Email bob.kozopas@opg.com President 1.800.324.9018 x38 519.756.6306 x161 519.750.4366 cell 416.657.2797 x 1 rob@flr.ca Manager of Facilities Executive Director joesaldavelli@fe.gedsb.net Joanne@rco.on.ca 20 APPENDIX B USED FLUORESCENT LAMPS CRUSHER SEPARATOR PHOSPHOR POWDER & METALLIC SEPARATION BY RETORT PHOSPHOR POWDER REUS META GLAS RECYCLE RECYCLE CLEAN MERCURY RECOVERE MERCURY TRIPLE DISTILLATIO REUS 21 USED MERCURY VAPOUR LAMPS CRUSHER SEPARATOR MERCURY AMPOULES SEPARATION BY RETORT GLAS RECYCLE METAL GLAS RECYCLE RECYCLE RECOVERED MERCURY TRIPLE DISTILLATIO CLEAN REUSE 22 Appendix C Certificates of Approval for Fluorescent Lamp Recyclers Inc. Certificate Description Number Status Fluorescent Lamp Operations 1638-4YGL5B 1156-52WR9P Processing of mercury waste, cleaning ballasts, and metal w/ PCBs for recycling – will receive liquid, industrial haz waste, solid haz waste, solid non-haz waste storing in bulk for final disposal – 4 mobile trailer units for PCB processing Installation of a industrial oil water storm ceptor 6602-5KNTXB Dust collectors and fume hood A821193 Waste management system cofa for hauling of waste Still valid & active Still valid & active Ongoing amend to define waste classes of what can and cannot be hauled and still valid & active PCB Containment Operations A821199 Waste management system cofa for hauling of waste) – waste classes to be defined 821206 Waste management system for mobile unit to drain pcb contaminated oil from transformers Amended, waste site mobile processing facility Waste management system mobile unit, waste disposal site(mobile unit now stationary) A181011 A821112 A181000 (mobile unit) 8-2258-93-957 4 mobile trailer units Ongoing amendments, still valid & active Revoked 2003 and combined with 1638 Revocation in process Revoked and combined with 1638 23 APPENDIX D Fluorescent Lamp Recycling Literature Review INTRODUCTION The primary focus of the literature review was to identify existing programs targeting fluorescent lamp recycling (FLR). These programs would be used to provide a template to design FLR programs in Canadian schools. The secondary focus of the literature review was to provide a general background of the legislation and governmental initiatives of Canada, US, and European Standards. Currently, there are few fluorescent lamp recycling programs in Canada that could provide guidance for the development and implementation of a school level program. The findings are summarized in this literature review. The following sections represent the summarized findings of national standards and local programs operating in Canada (Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland & Labrador, Northwest Territories, Nova Scotia, Nunavut, Ontario, Prince Edward Island, Saskatchewan, Yukon). A general review is also included for programs in the United States (New Jersey, Massachusetts, Oregon, Minnesota) and in Europe (London and Sweden). 1.0 CANADIAN INITIATIVES ON MERCURY REDUCTION 1.1 NATIONAL STANDARDS & REGULATIONS Canada-Wide Standard for Mercury-containing Lamps (CWS) Canadian Council of Ministers of the Environment (CCME) First developed in 2001, Canada-Wide Standard for Mercury-containing Lamps was adopted by the Canadian Council of Ministers of the Environment through the framework of a Harmonization Accord19. The CCME consists of federal, provincial (with the exemption of Quebec) and territorial environment ministers. The CWS calls for a reduction in mercury content of lamps sold in Canada. The target reduction is 70% by 2005, from a 1990 baseline, for a total reduction of 80% by 2010. 19 The Harmonization Accord refers to the “Canada-Wide Accord on Environmental Harmonization.” The purpose of the Accord is to provide a framework and mechanisms to achieve the vision of governments working in partnership to achieve the highest level of environmental quality for all Canadians and to guide the development of sub-agreements pursuant to the Accord. Canadian Council of Ministers on the Environment. Retrieved, March 2005 from the World Wide Web “A Canada-Wide Accord on Environmental Harmonization” webpage www.ccme.ca/assets/pdf/cws_accord_env_harmonization.pdf 24 To reach this goal, participating jurisdictions were asked to commit to the assessment of the feasibility of recycling/recovery of lamps and implement initiatives to encourage these types of activities.20 Initial action plans were developed as the first steps towards the achievement of the mercury CWS. In May 2001, the CWS was signed by participating jurisdictions with the intent of developing implementation plans for their respective action plans. Each of the following jurisdictions has submitted an implementation plan: Federal Government Alberta Manitoba New Brunswick Newfoundland and Labrador Ontario Saskatchewan Other jurisdictions participating in the CWS initial action plans include: British Columbia Northwest Territories Nova Scotia Yukon 1.2 FEDERAL INITIATIVES Following the signing of the mercury CWS, the federal government put forth in December 2002 the following commitments to manage the mercury emissions from fluorescent lamps. First, the federal government would monitor industry compliance with the mercury reduction goal outlined in the CWS. Second, the federal government will work with industries and fluorescent lamp manufacturer jurisdictions to reduce mercury emissions on an operational level. These emissions will be reported under the National Pollutant Release Inventory. Third, Environment Canada will encourage purchases for lighting of federal buildings that prove to have mercury reduced and energy saving components. High mercury content lamps are to be replaced with low mercury energy efficient lamps using 20 Environment Canada. Retrieved, March 2005 from the World Wide Web “Mercury and the Environment – Mercury Management – Canada-Wide Standards” webpage www.ec.gc.ca/MERCURY/MM/EN/mmcws.cfm?SELECT=MM#mcl 25 programs such as the Federal Buildings Initiative, a program of Natural Resources Canada21. 2.0 PROVINCIAL PROGRAMS & CWS IMPLEMENTATION PLANS 2.1 ALBERTA CWS Commitment As part of Alberta’s implementation plan of the CWS for Mercury-containing lamps, a “Partner’s in Recycling Program” was established on January 16, 2001. This voluntary program is a joint initiative between Alberta Environment, Alberta Plastics Recycling Association, the City of Calgary, Northern CARE (Coordinated Action for Recycling) and Recycling Council of Alberta. With this action, Alberta became the first province to introduce an initiative to recycle fluorescent bulbs and obsolete computers.22 Partners in Recycling Program Governmental, Industrial, & NGO joint initiative The program aimed to increase the recycling rates of obsolete computers and spent fluorescent lamps. According to Alberta Environment, these materials contribute approximately 1,600 tonnes of mercury and lead to Alberta landfills each year23. Participating organizations were considered a “Partner in Recycling” and agreed to: Ensure that waste fluorescent tubes and end-of-life computers are safely recycled Implement the necessary recycling policies and procedures in their organizations, and specify recycling practices with staff and external contractors. Help spread the word about the importance of recycling these materials, and encourage their peers to join the "Partners in Recycling" program. The "Partners in Recycling" program was launched in two phases. 21 Natural Resources Canada's Office of Energy Efficiency offers the Federal Buildings Initiative (FBI) to help federal departments and agencies reduce energy and water consumption and greenhouse gas emissions. Through the FBI, thousands of federal buildings have already been upgraded. Natural Resources Canada’s Office of Energy Efficiency. Retrieved April 2005 from the World Wide Web. “Federal Buildings Initiative” webpage http://oee.nrcan.gc.ca/fbi/home_page.cfm?PrintView=N&Text=N. 22 Tara Matsuzaki. Retrieved, April 2005 from the World Wide Web.“Techno-Trash – Social and Environmental Costs of Creating and ” webpage www.slais.ubc.ca/courses/libr500/02-03-wt2/www/T_Matsuzaki/tt_cdn.htm. Destroying Technology 23 Alberta Environment. Retrieved, March 2005 from the World Wide Web: “Fluorescent Bulb and Computer Recycling” webpage www3.gov.ab.ca/env/waste/aow/flcr/ 26 The first phase was initiated on February 2001 and targeted organizations from the MUSH (Municipalities, Universities, Schools and Hospitals) sector. The goal of phase one was to achieve a 75 per cent recycling rate by the end of 2002. Currently, the MUSH sector produces 35% of Alberta’s discarded fluorescent tubes. 24 Phase One received significant results, however the ultimate goal was not achieved. In 2002, more than 500,000 kilograms of computer equipment from municipalities, universities, schools and hospitals were reused or recycled translating into an approximate recycling rate of 25 per cent. The recycling rate for fluorescent bulbs in 2002 was 23 percent, translating in to more than 350,000 feet (107,000 meters) of fluorescent tubes recycled. The second phase, launched in June 2002, concentrated on the IC&I (Industrial, Commercial and Institutional) sector. The goal for this sector is to have a 75 percent recycling rate by 2005. The industrial, commercial and institutional (IC&I) sector currently has 40 partners signed up for the program. Results from this program are not yet available25. Since the start of the program, 130 organizations have signed on as Partners in Recycling including at least 13 schools, 8 school boards and 6 post-secondary education facilities. For information on the CWS in Alberta contact: Christine DellaCosta, Waste Reduction Specialist Alberta Environment 9820 - 106 Street Edmonton, Alberta T5K 2J6 Phone: (780) 427-8242 Fax: (780) 422-5120 E-mail: christine.dellacosta@gov.ab.ca 2.2 BRITISH COLUMBIA CWS Commitment British Columbia put forth initial action plans that included an investigation of options to promote partnerships to develop fluorescent tube recycling opportunities within the province. Implementation plans are not yet available to the public on the CCME website. Currently, there are established voluntary local fluorescent recycling programs in the educational and private sectors. 24 Saskatchewan Waste Reduction Council. Retrieved from the World Wide Web. “Fluorescent Bulb Recycling,” WasteWatch, September 2000, webpage www.saskwastereduction.ca/hazardous/fluorescent.html. 7 Alberta Environment. Retrieved, March 2005 from World Wide Web: “Canada-Wide Standard for Mercury – Alberta Implementation Plan: Mercury Containing Lamps” webpage www3.gov.ab.ca/env/protenf/standards/cws_participation/publications/Mercury-MercuryContainingLamps.pdf 27 Campus Sustainability Office University of British Columbia The Campus Sustainability Office (CSO) at UBC implemented a sustainability policy; in 199826 The policy targeted resource consumption and the generation of wastes on campus. The CSO spearheaded the project by increasing awareness of conservation alternatives to students, staff and faculty. In a joint effort with the CSO, UBC’s Waste Management Department is currently recycling various recyclable materials, including fluorescent lamps.26 CSO Sustainability Coordinators are continually promoting, coordinating and implementing sustainability practices. For further information, please contact Ruth Abramson at (604) 822-0473 or email: abramson@ubc.ca. Power Smart at Home Program (CFL Recycling Program) BC Hydro Since January 2005, BC Hydro has been conducting a Compact Fluorescent Lamp (CFL) Recycling Pilot Project available to customers in the Lower Mainland and Vancouver Island. The program runs until July 2005 in partnership with 11 retailers. BC Hydro customers were encouraged to bring old CFLs to specified retailers for recycling. Results from this pilot program will not be available until after July; however BC Hydro’s intention with this project is to determine whether there is value to retailers participating in a program such as this one 2.3 MANITOBA CWS Commitment Manitoba’s commitment to the CWS for Mercury-Containing Lamps involved a review of barriers to recovery and recycling programs of lamps that contain mercury levels subject to hazardous waste regulatory requirements. This review would be followed by an assessment and promotion of these programs in government buildings. The use of lamps with low mercury content as part of the government’s procurement policy would also be promoted. 27 To that end in the summer of 2001, Manitoba released a discussion paper and proposed regulation which would place product stewardship requirements on sellers and manufacturers of mercury-containing lamps among a variety of product categories. 26 Smart Steps: Business Tools for Sustainability. Retrieved from the World Wide Web May 2005. “Case Study University of British Columbia” webpage http://www.gvrd.bc.ca/smartsteps/pdfs/CaseStudy-Schools.pdf 28 Though the program primarily focuses on household hazardous waste, plans must also address service in industrial, commercial and institutional settings.27 2.4 NEW BRUNSWICK CWS Commitment To address its responsibilities under the CWS, New Brunswick continues to maintain contact with lamp manufacturers to ensure that progress is made to meet the CWS. The province will also continue to use low mercury/energy efficient fluorescent lights in government buildings, wherever possible, and will encourage large property owners to do the same. In addition, New Brunswick is exploring the feasibility of a recycling program for fluorescent lights with its Solid Waste Commissions28. New Brunswick Mercury Action Plan – Progress Report NB Environment and Local Government Department (ELG) In September 2004, New Brunswick Environment and Local Government Department created the NB Mercury Action Plan - Progress Report. There is a stated objective to identify and implement mercury source reduction programs. By 2003, the overall amount of mercury-containing waste should be reduced where feasible from household, commercial and industrial sources, through source reduction, segregation, and safe waste management, including recycling. The plan also includes exploring the potential for the recycling of fluorescent lamps. One of the targeted audiences for this initiative is schools. As a result, the Department of Education has reported that liquid mercury is no longer used in school science labs, and that fluorescent lights are being replaced with low mercury/energy-efficient models. The ELG continues to check on this progress29. 2.5 NEWFOUNDLAND & LABRADOR CWS Commitment According to their implementation plan, prepared in 2002, the government of Newfoundland and Labrador intended to examine the recycling of fluorescent lamps to determine whether recycling of mercury-containing fluorescent tubes is not cost prohibitive, in which case the Government will encourage recycling as a means of implementing the Canada-Wide Standards. However, if costs are prohibitive the 27 Manitoba Conservation. Retrieved from the World Wide Web April 2005. “Implementation of the CSW for Mercury-Containing Lamps – Manitoba Implementation Plan” webpage http://www.gov.mb.ca/conservation/cwsmb/pdf/hg-lamps.pdf. 28 Government of New Brunswick. Retrieved from the World Wide Web April 2005. “Canada-Wide Standards (CWS) for Mercury –Implementation Plans for New Brunswick, Mercury Containing Fluorescent Lamps” webpage http://www.gnb.ca/0009/0369/0008/MercuryContainingFluorescentLamps.pdf 29 New Brunswick Environment and Local Government Department. Retrieved from the World Wide Web April 2005. “NB Mercury Action Plan - Progress Report Under the NEG/ECP” webpage http://www.gnb.ca/0009/0355/0009/0004-e.pdf 29 implementation of the CWS will likely be through voluntary efforts to encourage building owners to use low mercury content fluorescent tubes30. Fluorescent Lighting Tube Crushers Department of Environment & Conservation Multi Material Stewardship Board (MMSB) The Department of Environment and Conservation, with funding from the Multi Material Stewardship Board have supplied two fluorescent lighting tube crushers to the Department of Transportation and Works. The bulb crusher removes the mercury and mercury-impregnated phosphorous in these tubes through a filtering process and allows them to be destroyed in a way that does not pose any health and safety risk to employees handling them. This initiative is expected to divert approximately 200 grams of mercury per year from entering the environment.31 2.5 NORTHWEST TERRITORIES CWS Commitment According to their initial action plans, requirements would ensure proper lamp disposal by institutional users and follow the existing Disposal Guideline for Fluorescent Lamps and new Guideline for the Management of Waste Institutional, Commercial and Industrial Chemicals. The government would also work with municipalities towards the expansion of lamp collection programs for non-institutional users. Currently there are no public or private sector programs in place.32 30 Newfoundland & Labrador Department of Environment & Conservation. Retrieved from the World Wide Web April 2005. “Implementation Plan for Mercury in Fluorescent Lamps – Newfoundland and Labrador” webpage www.env.gov.nl.ca/env/Env/PollPrev/impl_merc_flou_Lamp.asp 31 Department of Environment and Conservation. Retrieved from the World Wide Web April 2005. “Green Communities Initiatives” webpage www.env.gov.nl.ca/env/Env/green%20committee/initiatives.htm. 32 Canadian Council of Ministers of the Environment (CCME). Retrieved from the World Wide Web April 2005. “Initial set of actions for the Canada-wide Standard for Mercury-Containing Lamps” webpage http://www.ccme.ca/assets/pdf/merc_lampinitacts_e.pdf 30 1.6 NOVA SCOTIA CWS Commitment The Government of Nova Scotia also participated in the creation of the “Initial set of actions for the Canada-wide Standard for Mercury-Containing Lamps” but did not become a signatory of the Canada-Wide Standards for mercury. The government of Nova Scotia has completed an inventory estimating of the number of tubes available for recycling on an annual basis, has provided a mechanism to divert lamps from Nova Scotia's only municipal incinerator and according to the Initial Set of Actions, intends to continue developing an option for recovery and proper disposal of fluorescent lamps.33 1.7 NUNAVUT CWS Commitment The province’s initial action plans intended to develop guidelines for the disposal of fluorescent lamps. These guidelines would require proper lamp disposal from institutional users. The province would also work with municipalities in the expansion of lamps from non-institutional users. The status of the three actions listed below is unknown.34 2.8 ONTARIO CWS Commitment Achievement of the Canada-Wide Standard for fluorescents is primarily the result of actions by the federal government through an agreement with lamp manufacturers to further reduce the mercury content of lamps. The federal government is responsible for collecting information on the progress of fluorescent lamp manufacturers towards reducing the mercury content of lamps and any progress reports from the federal government on this issue is made available on the MOE Web site. In addition, any actions by Waste Diversion Ontario with respect to lamp recycling will be reported35. For information on the CWS in Ontario, contact: Shelly Bonte-Gelok, Canada-wide Standards Advisor Technology Standards Section, Standards Development Branch 33 ibid. ibid. 35 Ontario Ministry of Environment. Retrieved from the World Wide Web April 2005. “Canada-Wide Standards in Ontario” webpage www.ene.gov.on.ca/envision/cws/index.htm#lamps. 34 31 Ontario Ministry of the Environment 40 St. Clair Ave. West, 7th Floor Toronto, Ontario M4V 1M2 Tel: (416) 212-4295 Email address: shelly.bontegelok@ene.gov.on.ca Ecosuperior Fluorescent Lamp Recycling Programs – OVERVIEW Ecosuperior is a Thunder Bay based not-for-profit whose goal is to provide residents of the Lake Superior basin with information and motivation for building healthy, sustainable communities. The group pursues projects that help promote water and energy conservation, waste reduction, pollution prevention and urban green spaces. Ecosuperior first began to target mercury-containing products with the introduction of their Merc-Divert Superior program. The first program was button battery recycling program that was started in 1996. This was followed by a thermostat recycling program in 2000, and then finally the fluorescent lamp recycling program of which they have two, one targeting the industrial, commercial and institutional (IC&I) sectors and another targeting homeowners called which was also started in 2000. Fluorescent Lamp Recycling Program for Large Volume Generator’s Participating organizations arrange to get their spent fluorescent lamps to the Central Consolidation Point. When a there are enough lamps to fill a transport truck the spent lamps are trucked 1300 km to Fluorescent Lamp Recycler’s Inc. (FLR) in Ayr, Ontario for recycling. Participating companies pay for storage, recycling and transportation of the lamps to FLR. Participants in this program include Lakehead University, Bombardier Transportation, Bowater, Smurfit-Stone Packaging, Abitibi-Consolidated, Norampac Packaging, Kimberly-Clark and Marathon Pulp. The health and safety benefits of such a program were a strong motivating factor for many companies to participate. The Zero Waste Action Team that is comprised of industries, institutions and organizations from Thunder Bay and Lake Superior North Shore communities, has also been active in fluorescent lamp recycling program. Ontario Power Generation (OPG) sponsors the homeowners program. Homeowners can drop of fluorescent lamps that are 4ft or less free of charge at the “Homeowner Central Consolidation Point” which is located at Ecosuperior. Ecosuperior makes all the arrangements to get the spent lamps from this program transported with the spent fluorescent lamps generated from the IC&I program to FLR for recycling. For more information: Jim Bailey Ecosuperior 212 E. Miles St. Thunder Bay, Ontario P7C 1J6 32 Ph: 807-624-2140 Fx: 807-622-0005 Em: mercdivertsuperior@yahoo.com Web: www.ecosuperior.com 2.9 PRINCE EDWARD ISLAND CWS Commitment As part of their commitment to the CWS for Mercury-containing Lamps, the Province of Prince Edward Island actively promotes fluorescent lamp recycling programs. They will be responsible for continuing their work with the Island Waste Management Corporation (IWMC). Within the Waste Watch System, the IWMC plans to incorporate the recovery of residential mercury containing lamps and other mercury containing waste. The program currently focuses on source separation and recycling of wastes, reducing the amount of mercury fed to the municipal solid waste incinerator.36 In order to service the industrial and institutional sectors, the province supports the development of a privately operated collector/disposal system. For more information contact: Island Waste Management Corporation 110 Watts Ave. Charlottetown, PE C1E 2C1 Tel: 902-894-0330 Fax: 902-894-0331 Email: info@iwmc.pe.ca 2.10 QUEBEC CWS Commitment Quebec was not a signatory on the Canada-wide Accord on Environmental Harmonization or the Canada-wide Standards, and therefore is not required develop an implementation plan under the CWS.37 Since the spring of 2003, the Ministère du développement durable, de l'environnement et des parcs (MDDEP) has been developing a provincial Mercury Action Plan with a Québec representative on the NEG/ECP Mercury Task Force. 36 Canadian Council of Ministers of the Environment (CCME). Retrieved from the World Wide Web May 2005. “Initial set of actions for the Canada-wide Standard for Mercury-Containing Lamps” webpage http://www.ccme.ca/assets/pdf/merc_lampinitacts_e.pdf. 37 Canadian Council of Ministers of the Environment. Retrieved from the World Wide Web June 2005. “http://www.ccme.ca/assets/pdf/hg_implplans_lamps_e.pdf. 33 The Action Plan will address mercury sources, monitoring, and remedial plans. Over the past two years, the working agenda towards the Action plan has included three main categories38 : The establishment of an overall portrait of the mercury situation in Québec, including a series of investigations on mercury uses and management within the education and health systems, and in end-of-life vehicles and their final disposal and recycling processes , and identifying the main sources within the province ; The identification of a series of measure to counter mercury release and production, including for example changes to air quality related regulations, Extended Producer Responsibility, Procurement and equipment replacement programs, etc. ; Monitoring of mercury emissions and contamination in various streams; Quebec is currently working on Extended Producer Responsibility regulations to incorporate into their waste management strategy. 2.11 SASKATCHEWAN CWS Commitment As a partner in the development of the CWS for mercury, the government of Saskatchewan did prepare a “Mercury Implementation Plan for Saskatchewan” in 2001 that does promote fluorescent lamp recycling and discusses partner with SaskPower to develop collection and recycling initiatives.39 However, the province has had difficulty moving beyond promotion of fluorescent lamp recycling because the infrastructure does not exist in the province to recycle the lamps in a cost effective way. As a result, there are currently no programs in place, legislated or voluntary, for the recycling of lamps in Saskatchewan.40 38 Gaetan Roy. Government of Quebec, Service des matières résiduelles. Personal Communication. Governement of Quebec. Personal Interview. June 15, 2005. 39 Saskatchewan Environment & Resource Management (SERM). Retrieved from the World Wide Web April 2005. “Canada-Wide Standards (CWS) for Mercury Implementation Plan for Saskatchewan – Mercury Containing Lamps” webpage www.se.gov.sk.ca/environment/protection/general/CWS%20mercury%20containing%20lamp.pdf 40 Dave Ballagh, Saskatchewan Environment, Environmental Protection Branch. Personal Interview. April 29, 2005. 34 2.12 YUKON CWS Commitment The Yukon Territory will assist the CCME and Environment Canada in their development of a Canada-wide Environmental Standard for mercury-containing lamps. The Yukon’s primary roles are to develop government purchasing policy for low-mercury fluorescent lamps, develop policy for the recycling of fluorescent lamps in government buildings, and to investigate partnerships for territory-wide collection of mercurycontaining lamps.36 AMERICAN MERCURY REDUCTION INITIATIVES 3.0 NATIONAL STANDARDS & REGULATIONS 3.1 United States Environmental Protection Agency (US EPA) On June 12, 2002, the US EPA added Mercury-containing lamps to the federal list of universal wastes that falls under Universal Waste Regulations41. The tough standards and high costs associated with hazardous wastes will no longer limit the recycling potential of these lamps. This new designation will ultimately affect implications regarding the collection and management of these materials, with the intent to be recycled or treated appropriately.42 Other such wastes similarly classified include batteries, thermostats, or obsolete pesticides. States such as Minnesota, California, Wisconsin and Florida, have gone as far as to develop their own legislation that bans mercury-containing lamps from accumulating in their landfills. 43 3.2 NATIONAL PROGRAMS Lamp Recycle Outreach Program United States Environmental Protection Agency (US EPA) Association of Lighting and Mercury Recyclers (ALMR) In 2002, the Lamp Recycle Outreach Program, funded by the US Environmental Protection Agency (EPA) and sponsored by the Association of Lighting and Mercury Recyclers (ALMR), Solid Waste Association of North America (SWANA) and the 41 Hilkene International Policy, Pollution Probe. (March 31st, 2005). "Background Study on Increasing Recycling of Obsolete Mercury Containing Lamps from Residential and Commercial Sources in Canada – Draft Final report”. 42 US Environmental Protection Agency. Retrieved from the World Wide Web May 2005. “Mercury Regulations and Standards – Universal Waste Regulations” webpage. http://www.epa.gov/epaoswer/hazwaste/mercury/reg_stand.htm#universal 43 Prince Edward Island – Official Website. Retrieved from the World Wide Web May 2005. “Crack Down in Mercury in Fluorescent Bulbs” webpage http://www.gov.pe.ca/fae/env/epa.php3 35 National Electrical Manufacturers Association (NEMA), released a CD-ROM to promote the recycling of mercury-containing lamps. 44 The goal of the project was to increase awareness regarding the toxic nature of fluorescent lamps, educate the public about proper disposal methods that comply with federal and state universal waste laws, and essentially to try and reduce the amount of mercury entering the environment through an increased recycling effort.44 For more information regarding specific contents of the CD-ROM, please visit www.almr.org or www.lamprecycle.org. United States Naval Academy (USNA) Fluorescent Tube Recycling Initiative USNA Environmental Division During the first year of the USNA’s fluorescent tube recycling initiative, more than 15,000 pounds of hazardous waste was diverted from landfills with a cost-savings of $6000 from previous hazardous waste disposal methods.45 A crush-and-sieve method was applied to effectively separate the lamp components, allowing for the total recycling of mercury and all other lamp parts. 45 For more information, contact George McNelly or Dave Higgens at 293-1024. ________________________________________________________________________________________________________________________________________________________________________ 4.0 STATE PROGRAMS 4.1 NEW JERSEY School Recycling Program Harmony Township School The head of maintenance at the Harmony Township School in rural New Jersey, in cooperation with school staff and students, has developed a comprehensive recycling program that includes paper, cardboard, newspaper, aluminum and steel cans, glass, plastic, batteries, fluorescent tubes, telephone books, textbooks and computers.46 The program is designed to have the students and teachers search classrooms and offices every Friday for recyclable items, and collect material in shopping carts.46 Monthly trips 44 Association of Lighting and Mercury Recyclers (ALMR). Retrieved from the World Wide Web May 2005. “Recycling Mercury-Containing Lamps: Alliance Formed to Promote Recycling” webpage http://www.almr.org/cdrelease.html 45 United States Naval Academy Environment Division. Retrieved from the World Wide Web May 2005. “Recycling Fluorescent Light Tubes and High Intensity Discharge Lamps” webpage http://p2library.nfesc.navy.mil/P2_Opportunity_Handbook/2_II_6.html. 46 New Jersey Department of Environmental Protection. Retrieved from the World Wide Web May 2005. “2004 Recycling Awards Recipients and Program Descriptions” webpage http://www.state.nj.us/dep/newsrel/2004/04_0123awards.htm 36 are then made to the Warren County Recycling Center. The school also acts as a dropoff depot for various recyclables. The main objective of this program was to educate members of the local community, by increasing awareness of the value of recycling programs, and actively seek their participation in such activities. 4.2 MASSACHUSETTS Getting Mercury Out of Schools and Communities Northeast Waste Management Officials Association (NEWMOA) The Northeast Waste Management Officials’ Association (NEWMOA) started a program in January 2001 called “Getting Mercury out of Schools and Communities” with funding support from the Massachusetts Department of Environmental Protection and the Massachusetts Executive Office of Environmental Affairs. The focus of this program is to identify and remove elemental mercury and products containing mercury from schools and homes. To that end, NEWMOA developed the following materials: A series of individual fact sheets for specific school staff members (e.g., facilities manager, science chairperson, medical personnel) called “Getting Mercury Out of Schools: Why it’s a problem. Where it is. What to do.” An “Identification of Mercury Devices in Schools” table to help school staff identify mercury-containing materials commonly found in schools and suggest non-mercury alternatives. Specific tables were also created for science rooms, medical offices, and school facilities. A “Case Study on Mercury Elimination from Bay Path Vocational Technical High School, Charlton, Massachusetts.” The school eliminated mercury and mercury containing products from their facilities and passed a “mercury-free” resolution. A list of “Eight Good Ideas for Reducing Mercury Exposure and Pollution in your Community” was developed to assist municipal officials. A document about conducting and publicizing a thermometer exchange called “Nearly Everything You Need to Know About Mercury Fever Thermometer Exchanges” was created. In the four years this program has been operating a total of 103 Massachusetts schools (53 high schools, 24 middle schools and 26 elementary schools) have participated. NEWMOA has removed approximately 936 pounds of mercury. The average amount of mercury removed per high school is approximately 9-14 pounds. The program has also resulted in the education of hundreds of teachers, schools administrators, nurses and students about the health and environmental hazards of mercury and the importance of preventing future use of mercury in schools. 37 For more information: Meg Wilcox Northeast Waste Management Officials' Association (NEWMOA) 129 Portland St., Suite 602 Boston, Massachusetts 02114 Ph: 617-367-8558 ext. 305 Em: mwilcox@newmoa.org Web: www.newmoa.org/prevention/mercury/schools/ 4.3 OREGON Fluorescent Tube Recycling in Healthcare Facilities Oregon Department of Environmental Quality City of Milwaukee The Oregon Department of Environmental Quality (DEQ) is supporting the City of Milwaukee, Oregon, to develop a fluorescent lamp recycling program for state-wide hospitals.47 The program will aim to recognize the limiting factors of implementing these recycling programs in Oregon hospitals.48 Urban and rural hospitals will be given economic incentives as encouragement for participation. Current participants are the Legacy Health System in Portland, Asante Health System in Medford, and the Good Sheppard Health System in Hermiston47. The program aims to divert 50,000 fluorescent tubes from 10-15 hospitals within the first year of its inception. 4.4 MINNESOTA Low-Mercury Lamps University of Minnesota The University of Minnesota has recently made attempted to switch to a less toxic alternative to fluorescent lamps. Older bulbs are collected and recycled for mercury from all campuses. The university lends its services to other institutions throughout the state with its Chemical Safety Day program. The program was capable of recycling 95,000 fluorescent tubes in the year 2000, which amounted to nearly eight pounds of mercury that would have otherwise ended up in landfills. 49 The following year, the university purchased more than 50,000 fluorescent lamps with 60 percent less mercury content. 49 47 Recycling Advocates. Retrieved from the World Wide Web May 2005. “DEQ Awards Grants for Portland AreaBased Recycling Projects” webpage http://www.recyclingadvocates.org/newsletter/feb2003.htm 48 Recycling Today. Retrieved from the World Wide Web May 2005. “Recycling Program Established for Fluorescent Tubes” webpage http://www.recyclingtoday.com/news/news.asp?ID=3511&AdKeyword=fluorescent+tubes 49 Sustainability AND U: University of Minnesota. Retrieved from the World Wide Web May 2005. “Low-Mercury Lamps” webpage http://www.uservices.umn.edu/sustainableU/materials.html#6. 38 Further information regarding less toxic fluorescent lamps can be found at INFORM’s Purchasing for Pollution Prevention webpage at http://www.informinc.org/p3_00.php. 5.0 EUROPEAN MERCURY REDUCTION INITIATIVES 5.1 EUROPEAN UNION STANDARDS & REGULATIONS Waste Electrical and Electronic Equipment (WEEE) Directives On January 27,2003, the European Parliament and the Council of the European Union passed legislation on the restriction of the use of certain hazardous substances in electrical and electronic equipment and on prevention of waste electrical and electronic equipment (WEEE). Directive 2002/95/EC prevents any new electrical and electronic equipment put on the market, from 1 July 2006, from containing lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). 50 Directive 2002/96/EC addresses the operator responsibility in the life cycle of electrical and electronic equipment. In order to prevent and reduce the creation/disposal of WEEE, producers and distributors are responsible for providing mechanisms for taking back and recycling electrical and electronic equipment. These take-back programs are provided to consumers free of charge. 51 6.0 EUROPEAN PROGRAMS 6.1 LONDON 50 Environmental-Directorate of the European Commission. Retrieved from the World Wide Web July 2005. “Waste Electrical and Electronic Equipment”webpage http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=3200 2L0095&model=guichett 51 Environmental-Directorate of the European Commission. Retrieved from the World Wide Web May 2005. “Waste Electrical and Electronic Equipment” webpage. http://europa.eu.int/comm/environment/waste/weee_index.htm 39 Green Light Project Ealin Community Transport Waste Resource Action Programme (WRAP) This pilot project was put in place in London for redistributing useable fluorescent lamps to schools in exchange for their spent fluorescent lamps. Ealing Community Transport developed the pilot with funding from the Waste and Resource Action Programme (WRAP).52 Old fluorescent lamps are collected from businesses and those that are still useful are given to schools for their use; spent lamps are collected for recycling purposes. The pilot is more of a donation program rather than a recycling program and does not seem to have an educational component involved. For more information on UK initiatives, visit www.wasteonline.org.uk 6.2 SWEDEN Mercury Removal Projects Swedish Environmental Protection Agency The Swedish government is involved in three projects surrounding the removal of mercury from the environment be it natural or manmade. Two of the projects consist of removing mercury from schools, universities and colleges. Mercury is found with the use of mercury sniffing dogs; Froy, Ville and Troy. Within this project it is mentioned that waste disposal collection systems for fluorescent lamps exist, but does not go into detail with the collection scheme. The program focuses on the removal of mercury caused by instrumentation used which contains the substance (mostly for scientific means, for example; clinical thermometers and antique barometers).53 52 Remade Scotland. Retrieved from the World Wide Web May 2005. “Fluorescent Tube Recycling” webpage http://www.remade.org.uk/Glass/fluorescent_tube_recycling.htm 53 Swedish Environmental Protection Agency (SEPA). Action Programme for the Collection of Mercury. SEPA; Stockholm. 1999. 40 41 Appendix E List of Schools in the GEDSB that participated in the Pilot Program Type School Burford E.S. Est. Lamps 736 Est. Hg(mg) 8537.6 Elementary 5254.8 Elementary Elementary Secondary Princess Elizabeth PS River Heights Pauline Johnson C.V.S. (SE) Paris DHS 453 834 9674.4 20880 1800 3823 44346.8 TBD #VALUE! #VALUE! Prince Charles PS Rainham PS TBD TBD #VALUE! Simcoe Composite SS TBD #VALUE! Tollgate Technological Skills Ctr.(SE) Valley Heights SS TBD TBD #VALUE! 0 0 Elementary Secondary Secondary 290 Agnes G. Hodge PS 25 365.4 Elementary Banbury Heights S K-6 K - 8, SE K-8 9 - 12, S Address 35 Alexander St, PO Box 130 Town/City Burford Phase 60 Tecumseh St. 37 Forfar St. East Brantford Caledonia 1 627 Colborne St. Brantford 1 231 Grand River St., North Paris 2 40 Morton Ave. 572 Concession 5, R.R. #1 40 Wilson Ave. Brantford Fisherville 2 2 Simcoe 2 112 Tollgate Rd. 2561 Hwy. 59, Box 159 Brantford Langton 2 2 52 Clench Ave. Brantford 3 141 Banbury Rd. 238 Brantwood Park Rd. 10 Blackfriar Lane Brantford 3 Brantford Brantford 3 3 60 Ashgrove Ave. Brantford 3 1 1 #VALUE! Secondary Elementary K-8 K - 6, SE K-8 9-12, S Elementary Elementary Grades 32 232 Elementary Elementary Branlyn Community S Brier Park PS 20 7 Elementary Cedarland PS 7 81.2 81.2 9-12, S 9 - 12, S K - 6, SE K - 8, SE K - 8, SE K-8 K - 8, SE 42 Elementary Elementary Elementary Elementary Centennial-Grand Woodlands S Central PS, Brantford 81.2 7 8 Elementary Elementary Echo Place S F. C. Bodley PS Fairview S (French Immersion) Graham Bell-Victoria PS 21 8 Elementary Grandview PS 28 87 72.5 6 0 246.5 87 319 348 Elementary Elementary James Hillier PS Joseph Brant PS 30 13 Elementary King George S 46 145 536.5 0 Elementary Major Ballachey PS K - 8, SE K-6 41 Ellenson Drive 135 George St. 723 Colborne St., East 365 Rawdon St. Brantford Brantford 3 3 Brantford Brantford 3 3 34 Norman St. 56 Grand St. Brantford Brantford 3 3 68 North Park St. Brantford 3 62 Queensway Dr. 347 Erie Ave. Brantford Brantford 3 3 265 Rawdon St. Brantford 3 105 Rawdon St. 21 Brant School Rd., R.R. #1 10 Wade St. Brantford 3 Brantford Brantford 3 3 43 Cambridge Dr. 61 Sherwood Dr. Brantford Brantford 3 3 9-12, S 9-12, ILC 120 Brant Avenue Brantford 3 40 Richmond St. Brantford 3 9-12 280 North Park St. Brantford 3 K-8 K-6 K-8 K-6 K - 8, SE K - 8, SE 7-8 K - 8, SE K - 8, SE 246.5 Elementary Elementary Onondaga-Brant PS Riverview PS 21 13 Elementary Elementary Russell Reid PS Ryerson PS Brantford Collegiate Inst. & V.S. (SE) Grand Erie Learning Alternatives ** North Park Collegiate-V.S. (SE) SUBTOTAL 30 35 Secondary Secondary Secondary TOTAL 145 348 406 1856 160 812 70 K-8 K-4 K - 3, SE 5-8 2871 248 833 9657 4656 54003.8 43 Logistics Outline for Collection of Fluorescent Lamps from GEDSB The collection of fluorescent lamps from the Grand Erie District School Board will be limited to schools in the City of Brantford and the 10 schools that will be going through a lighting retrofit between March and May 2005. The collection of the lamps will occur in three phases: Phase 1 – Schools scheduled to be retrofitted in March Phase 2 – Schools scheduled to be retrofitted in April Phase 3 – Collection of all spent lamps from City of Brantfort schools Phase 1 – Schools Scheduled to be Retrofitted in March The following schools are scheduled to be retrofitted in March 2005, in an effort being coordinated by Ameresco. All the lamps from this process will be stored on site until the scheduled collection date in late March or early April (exact dates to be determined). Table 1: Schools to be Re-lamped in April School Lamps Contact Phone Address City P. Code Pauline Johnson Burford E.S. River Heights Princess Elizabeth 627 Colborne St. 35 Alexander St. 37 Forfar St. East 60 Tecumseh St. Brantford Burford Caledonia Brantford N3S 3M8 N0E 1A0 N3W 1L6 N3S 2B5 1800 736 834 435 Sharon Marr 519 750-5293 519 750-5536 905 974-7057 519 770-2026 3805 Phase 2 – Schools Scheduled to be Retrofitted in April The following schools are scheduled to be retrofitted in April 2005, in an effort being coordinated by Ameresco. All the lamps from this process will be stored on site until the scheduled collection date in late April or early May (exact dates, and lamp quantities to be determined). Table 2: Schools to be Re-Lamped in May School Lamps Contact Phone Paris DHS TBD Prince Charles PS TBD Judy Wilson 519 750-5168 519 750-8538 Address City P. Code 231 Grand River St., North 40 Morton Ave. Paris N3L 2N6 Brantford N3R 2N5 44 Rainham PS TBD 905 972-5151 Simcoe Composite SS Tollgate TSC Valley Heights SS TBD Vern Morrow 519 750-5657 TBD TBD Daryl Sinden 519 750-5142 572 Concession 5, R.R. #1 40 Wilson Ave. 112 Tollgate Rd. 2561 Hwy. 59, Box 159 Fisherville N0A 1G0 Simcoe N3Y 2E5 Brantford Langton N3R 4Z6 N0E 1G0 Phase 3 – Collection of all spent lamps from City of Brantford schools Phase 3 of the collection process will be limited to schools in the City of Brantford to maximize project efficiencies and minimize collection costs. There are 33 schools in the City of Brantford (see attached list), however only 23 of them will be included in the Phase 3 fluorescent lamp collection process as they recently underwent the lamping retrofit process and will therefore have very limited quantities of fluorescent lamps available for collection, or are scheduled to be retrofitted in and so are already included in Phase 1 or Phase 2 of the collection process. Table 3: City of Brantford Schools Retrofit Plan School Dufferin Greenbrier Woodman Drive Bellview Coronation Lansdowne Pauline Johnson C.V.S. (SE) Princess Elizabeth PS Prince Charles PS Tollgate Technological Skills Ctr.(SE) Retrofit Date Jan 05 Nov 04 Nov 04 Dec 04 Dec 04 Dec 04 Mar 05 Mar 05 Apr 05 Apr 05 Collection Phase Lamps N/A N/A N/A N/A N/A N/A Phase 1 Phase 1 Phase 2 Phase 2 N/A N/A N/A N/A N/A N/A 1800 435 TBD TBD 45