Waste Management Procedures
Fluorescent Light Bulbs
Before you begin
Description
Burned-out / spent fluorescent light bulbs
Scrap Fluorescent Light Bulbs (Unless broken):
 Universal Waste Electric Lamp (Unless broken)
 Non-hazardous, Not regulated by DOT
 Non-exempt recyclable material
Category
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) the container
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
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Waste Management Procedures
Fluorescent Light Bulbs
Before you begin,
Disposal
Recordkeeping
(continued)
Send to a facility that will separate the mercury and beneficially reuse or
recycle both the metal and the glass.
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 the
Fieldwood 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.
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Waste Management Procedures
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:
a. Place in the 39 bulb box provided by Safety-Kleen.
3.
Mark Package:
a. No DOT marking is required.
b. Stencil Container-“Fieldwood Energy” and the generator’s location (i.e. Eugene Island
158).
4.
Label Package:
a. No DOT Label is required.
b. Use label provided by Safety Kleen.
5.
Prepare shipping papers:
a. Complete entry in General Cargo Section [Section II] of the Fieldwood Energy
Shipping Manifest (See example).
b. 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.
8.
No MSDS required.
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Waste Management Procedures
Fieldwood Energy LLC
2014 W. Pinhook Road, Suite 800
Lafayette, LA 70510
(337) 232-8282
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Waste Management Procedures
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:
a.
“Waste Mercury Contained in manufactured articles , 8, UN 2808, PG III”
b.
Stencil Container -“Fieldwood Energy” and the generator’s location (i.e. EI 215-B)
4.
Label Package:
a.
DOT "Class 8” label.(See example)
b.
EPA “Hazardous Waste” label.(See example)
5.
Prepare shipping papers:
a.
Complete entry in Hazardous Materials Section [Section I] of the Fieldwood Energy
Shipping 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.
b.
Complete all of Uniform Hazardous Waste Manifest, EPA 8700-22b for hazardous
waste. (See example)
c.
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
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Waste Management Procedures
Shipping Instructions: BROKEN FLUORESCENT LIGHT BULBS,
(continued)
7.
Load cargo in accordance with the following shipping limitations:
AIR
RESTRICTIONS (49 CFR 172.101)
Passenger Aircraft
No Limit
Cargo Aircraft
No Limit
WATER
8.
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”.
Include MSDS with shipment.
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Waste Management Procedures
Reuse / Recycle
To be issued by state of shore base
Fieldwood Energy LLC
[Address of field location]
Phone of field location
McCall Boat Rental, Inc.
(337)
LAD981594054
775-5485
Safety Kleen
MERCURY TECHNOLOGIES
INT
Safety
Kleen Systems,
Cor
4317-L FORTUNE PL
WEST MELBOURNE, FL
32904
LAD985171024
(800/808-4684
504) 466-5718
FLD98426272
Waste Mercury 8 UN2809 PG III, Contained in manufactured
articles (D009), Emergency Response Guide No. 172
1
DM
55
P
D009
R
a. Reuse / Recycle (Contains <2500
MG/KG) (FL001965)
(A) M141
If not accepted at disposer's address, return to
Fieldwood Energy. In case of emergency contact: (1) Fieldwood Energy at (337) 232-8282
and (2) Louisiana Transportation & Environmental Safety Section (TESS) at (504) 925-6595
Emergency Response Guide Number 172. MFST R/T# 00000000 0-000-00
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Waste Management Procedures
Waste Mercury Contained in
manufactured articles
UN 2808
Fieldwood Energy LLC (EI 158)
[Address of field location]
D009
July 1, 2011
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