June 11, 2013

CRT Glass as a Fluxing Agent

Although fewer and fewer cathode ray tubes (CRTs) are being produced, CRT recycling is still a major trend in the United States because a large number of CRTs are still being retired. EPA recognized this when they promulgated the CRT rule on July 28, 2006. [71 FR 42928] The goal of the rule was to promote the collection and recycling of CRTs by easing RCRA regulatory requirements. One of the exclusions that EPA created in the rule is that processed CRT glass sent for recycling at lead smelters is not a solid waste unless speculatively accumulated. [§261.39(c)]

To understand this exclusion better, let’s take a closer look at CRT recycling. When CRTs are recycled, they contain two types of glass. The first type, panel glass, is basically the screen at which we are used to looking. The second type, funnel glass, is the back side of the CRT which is usually underneath a plastic housing (i.e., the back of the unit). In addition, processed glass (i.e., glass chunks) is generally called “cullet.” Thus, the terms “panel cullet” and “funnel cullet” are commonly used in CRT recycling to refer to processed panel glass and processed funnel glass.

Because funnel cullet generally contains a lot more lead than panel cullet, it is more difficult to recycle. However, it makes a good substitute for virgin silica that is used as a fluxing agent in lead smelters. This use is precisely why EPA created the §261.39(c) exclusion.

Recently, the agency was asked whether the §261.39(c) exclusion would cover use of funnel cullet as a fluxing agent for copper smelting, since this is basically the same process as using CRT glass at lead smelters. EPA said “No,” noting that it had addressed this issue in the preamble to the final CRT rule:

“The Agency agrees with those commenters who pointed out that the degree of processing that is required for use in a copper smelter appears to be the same as that required for use in a lead smelter. The economics also may be similar for fluxes used in both kinds of smelters. Processed glass is composed mainly of silica, which is useful as a flux, although lead is not recovered when CRT glass is used as a flux at a copper smelter. Nevertheless, the Agency has been unable to confirm that CRT glass is accepted at actual copper smelters.” [71 FR 42937]

For this reason, EPA did not include copper smelters in the §261.39(c) exclusion. However, the agency has noted in recent guidance [RO 14835] that processed CRT glass used, without reclamation, as an effective substitute for virgin fluxing agent at copper smelters would be excluded from RCRA regulation as an effective substitute for a commercial product under §261.2(e)(ii). Furthermore, EPA noted that this interpretation is in line with a similar finding for foundry sands used as a fluxing agent at copper smelters. [RO 11900] Keep in mind that regulations in authorized states may be more stringent.

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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.