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1998 Chlorine Institute Annual Report
First Annual Report to EPA
May 8, 1998
This is the first annual report of the Chlorine Institute to the United States Environmental Protection Agency detailing the Institute's member chlor-alkali mercury cell plants' progress towards meeting the commitment made to US EPA on July 10, 1997. During that meeting, the Chlorine Institute, on behalf of its members, committed to reduce mercury use in the chlor-alkali industry by 50%. The average annual mercury usage for the 1990 - 1995 period was 160 tons. This is the basis for the reduction. The goal is to reduce mercury usage by 80 tons per year by the year 2005. In addition, it was agreed to submit to EPA, on an annual basis, a report describing the progress made by the various task groups in their technical activities.
The chlor-alkali mercury cell producers and the Chlorine Institute are dedicated to continuous improvements in the protection of human health and the environment connected with the production of chlorine by mercury cell technology. The Institute believes that the industry is in compliance with existing regulations governing releases of mercury to the environment, and that no significant harm to human health and the environment exists as a result of mercury releases from the chlor-alkali industry. Driven by the industry's commitment to Responsible Care®, the Institute will strive for further improvements, always guided by sound science, risk management principles, and cost/benefit analysis.
To insure that appropriate oversight is given to the monitoring of progress being made to achieve the commitment, the Institute's Board of Directors established an ad hoc Board Committee on Mercury Issues (BCMI). Reporting to the BCMI is a technical subcommittee, the Mercury Issues Management subcommittee (MIMSC). All chlor-alkali producers using mercury cell technology are represented on both these committees.
The mission of MIMSC is to address proactively safety, health, and environmental issues that will impact the manufacture and use of chlor-alkali products produced by the mercury cell process. The subcommittee will develop and promote practices that will assist the users of this technology in the achievement of the goal to reduce mercury usage by 50% and in the continued protection of human health and the environment.
MIMSC established seven (7) technical task groups to carry out its mission:
- The Mercury Emissions Control and Measurement Task Group's mission is to identify control techniques that can be used by member companies to further reduce mercury emissions fromthe cell rooms and to identify a protocol that is technically feasible to measure mercury emissions from cell room operations.
- The Mercury Balance Task Group's mission is to develop a guidance document for the conducting of accurate mercury balances, to monitor information received from members pertaining to such accounting, and to recommend appropriate future Chlorine Institute administration.
- The Mercury Health Issues Task Group's mission is to address issues of current concern pertaining to the health effects to employees potentially exposed to mercury.
- The Mercury Containing Wastes Task Group's mission is to address regulatory issues of concern pertaining to mercury-containing wastes and to interact with EPA concerning regulatory proposals.
- The Mercury Cell Rubber Lining Task Group's mission is to develop a pamphlet to assist members in evaluating rubber lining services pertaining to potential mercury contamination.
- The Mercury in Sodium Hydroxide - Current Technology Task Group's mission is to develop an Institute guidance document providing recommendations for mercury cell producers to consider to reduce mercury in caustic soda to a level of 0.020 ppm.
- The Mercury in Sodium Hydroxide - New Technology Task Group's mission is to identify and evaluate new technologies for further reducing the mercury content of sodium hydroxide to the lowest practical level economically achievable.
The attached Table 1 is an updated mercury use report covering both 1996 and 1997 as discussed in the July 10, 1997 meeting. We are pleased by the reduced usage for two consecutive years, but the significance of these reductions should not be overstated. Mercury usage can be highly variable in any given time period because of 'in process' accumulations that can understate or overstate mercury usage during the time frame of concern. Such accumulations require plant shutdowns or maintenance outages to recover and properly account for the mercury. Activities being undertaken by the Mercury Balance Task Group should help to reduce such effects in future years.
While the mercury cell chlor-alkali producers are fully committed to achieving the mercury usage reduction goal, the extensive resource commitment made in 1997 has given us additional confirmation that achievement will not come quickly or easily. Below is a summary of the various task groups' technical activities in 1997.
- The Mercury Emissions Control and Measurement Task Group (MECM) has been very active since holding its first meeting on May 20, 1997. The MECM and the Mercury Balance Task Group jointly held a 2-day workshop to further develop a protocol to identify cell room mercury emissions control and measurement techniques. A work plan has been developed and action items assigned to Task Group members. A mercury emissions survey for member companies has been prepared and will be sent out in 1998.
- The Mercury Balance Task Group has also been very active with preparation of survey requests for baseline data from member companies and compilation of survey results, as well as holding a workshop - jointly with MECM - to share/discuss/develop information on accountability techniques. Initial work was begun on a "Good Practices Document" for mercury balance.
- The Mercury Health Issues Task Group has made substantial progress toward the publication of Chlorine Institute Pamphlet 156 - Guidelines to Physicians in Conducting Medical Surveillance Programs, a companion to the existing Chlorine Institute Pamphlet 125 - Guidelines: Medical Surveillance and Hygiene Monitoring Practices for Control of Worker Exposure to Mercury in the Chlor-Alkali Industry. Pamphlet 156 is expected to be published in 1998.
- The Mercury Containing Wastes Task Group continues with its objective of reviewing and commenting on newly-proposed rules affecting mercury-containing wastes as they are proposed by EPA.
- The Mercury Cell Rubber Lining Task Group achieved its objective by publishing Chlorine Institute Pamphlet 154 - Guidelines for the Handling of Rubber-Lined Cell Parts Potentially Contaminated with Mercury (pdf file). A copy can be ordered from the Chlorine Institute.
- The Mercury in Sodium Hydroxide Task Group - Current Technology has conducted a member companies' survey concerning technologies currently available to reduce mercury levels in sodium hydroxide. The data collected are being used to develop a guidance document for members. This document is expected to be finalized 1998.
- The Mercury in Sodium Hydroxide - New Technology Task Group has developed a survey to be sent to member companies for any information, data, etc., they may have regarding the objective of identifying and evaluating technologies that have the potential to reduce mercury content in sodium hydroxide beyond the limits of current technologies. Additionally the task group has conducted a preliminary review of the literature and is planning a report on the results of the technologies' efforts.
