While crushing of mercury containing Universal Waste (UW) lamps has been allowed under the Virginia Hazardous Waste Management Regulations (VHWMR) by 9 VAC 20-60 since March, 2002. Virginia had not received authorization from the Environmental Protection Agency (EPA) for these regulations. In order to receive authorization, the DEQ must demonstrate equivalency with the federal standards which do not allow crushing. Specifically, Virginia must demonstrate that crushing can be done in a protective and safe manner and that the risk of exposure from crushing is no greater than that which would be experienced at a facility that does not crush lamps. The regulatory amendment which will support the equivalency determination that UW lamp crushing meets the federal standards is now effective and there are new compliance requirements for UW lamp generators who crush at their facility and for UW lamp recyclers in Virginia.

For generators, the amended regulations are in 9 VAC 20-60-273 and 9 VAC 20-60-1505. In general, the new requirements for generators include:

• Initial notification of intent to crush lamps and for existing crushing operations; 
• Annual training plan for operators; 
• Secondary filtration with a separate HVAC system;
• Initial and annual emissions monitoring;
• Recordkeeping; and
• Financial assurance for closure (if applicable).

This guidance was developed to assist UW lamp generators who wish to crush their UW lamps in complying with the revised regulatory requirements. Please note that the amended regulations are in addition to the regulations in 9VAC 20-60-273 for UW  handlers.