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1999 Chlorine Institute Annual Report
Second Annual Report to EPA
May 14, 1999
This is the second annual report by the Chlorine Institute to the United States Environmental Protection Agency detailing the progress made by the Institute’s member chlor-alkali mercury cell plants towards meeting the commitment industry made to the US EPA. The Chlorine Institute, on behalf of its members, has 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 to 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.
Mercury use declined during the reporting year, 1998. The attached Table 1 provides the quantitative results. Although it was stated at the initiation of this effort that the use reduction would not be linear and that there could be variation up or down year to year, there has been an annual decline reported for each year of the program. Mercury purchases are somewhat higher than use. However, these purchases can be accounted for by identifiable and measurable increases in virgin or process mercury inventories. Through 1998, mercury use reduction has yielded a drop of 35% from the baseline. There have been numerous reasons for this, individual company efforts, as well as impact from task group activities.
The group efforts resulted in 34 meetings involving 45 people, amounting to more than 1,000 work hours in meetings alone. Outlined below are reports on task group activities, Chlorine Institute facilitated events, and some specific member projects shared with all producers.
Background information on the various committees, subcommittees and task groups, and two work products are included in the appendices.
Miscellaneous Activities
The Institute and its members were involved in several meetings in 1998 with EPA and other groups that are not included in the 34 meetings indicated above discussing the mercury reduction commitment, the Binational Strategy as it relates to mercury, proposed NESHAP revisions, possible changes to the RCRA regulations as they pertain to mercury containing wastes, and international initiatives related to the transport of atmospheric mercury. These meetings included the following:
- United Nations Economic Commission for Europe Meetings (Geneva, Switzerland) pertaining to the Heavy Metals protocol
- EPA Region 1 and New England governors meetings pertaining to mercury concerns in the northeast (Boston, MA)
- Meetings with EPA’s Office of Air Quality Planning and Standards in discussing possible changes to the mercury NESHAP (Durham, NC)
- Commission for Environmental Cooperation meeting on mercury issues in North America (Mexico City, Mexico)
- Meetings with the Office of Solid Wastes discussing possible changes to RCRA regulations pertaining to mercury containing wastes (Washington, DC area)
- Meetings on the Binational Strategy (BNS) (Fredericton, NB and Chicago, IL
- Meeting with EPA to update progress made in 1998 (Chicago, IL)
Additionally, the Institute facilitated visits by EPA personnel to five mercury cell producer sites in 1998 pertaining to the proposed NESHAP and RCRA changes. The Institute assisted EPA in facilitating the collection of data pertaining to the NESHAP revisions from all fourteen mercury cell producers.
A mercury issues workshop addressing the mercury reduction commitment and related activities was held and attended by nearly 100 people in 1998. A workshop addressing mercury emission control (operating) techniques was planned in 1998 and held in February of this year. Thirty four people, primarily involved with operations and maintenance within cell houses, shared information on ways to reduce mercury releases to the environment.
Individual efforts by several companies were shared with all mercury cell chlor-alkali producers. A cell database to track maintenance issues, mercury collection, and materials life and a mercury guidance document to enhance handling techniques were developed. These were provided to all Chlorine Institute mercury cell producers and made available to other members. The guidance document was provided to EPA in our October meeting. The Chlorine Institute members will be modifying this document to provide a more generic document suitable for any mercury cell chlor-alkali facility. Another member provided a technical report on how it measured mercury emissions from the cell house. That member provided the report to its state agency and EPA’s Office of Air Quality Planning and Standards. The report was shared with the Institute’s members. It is being reviewed by the Mercury Emissions Control and Measurement Task Group as that group continues to evaluate options for quantitative measurement of mercury emissions from cell houses.
The Institute and the mercury cell chlor-alkali producers are encouraged by the progress made to date in achieving the mercury use reductions. We have committed significant resources in this effort and will continue to do so. However, we believe future reductions will be more difficult to achieve and not come so quickly. We continue to be fully committed to achieve the 50% reduction.
APPENDICES
Appendix A - Mission Statements of Various Groups
Board Committee on Mercury Issues (BCMI)
The Institute’s Board of Directors established an ad hoc Board Committee on Mercury Issues (BCMI) to insure that appropriate oversight is given to monitoring progress being made to achieve the commitment. Reporting to the BCMI is a technical subcommittee, the Mercury Issues Management subcommittee (MIMSC).
Mercury Issues Management Subcommittee (MIMSC)
The mission of the Mercury Issues Management Subcommittee (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. These include the following:
The Mercury Emissions Control and Measurement (MECM) Task Group
The mission of the Mercury Emissions Control and Measurement (MECM) Task Group is to identify control techniques that can be used by member companies to further reduce mercury emissions from the cell rooms and to identify a protocol that is technically feasible to measure mercury emissions from cell room operations.
The Mercury Balance Task Group
The mission of the Mercury Balance task Group 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
The mission of the Mercury Health Issues Task Group is to address issues of concern pertaining to the health effects to employees potentially exposed to mercury.
The Mercury Containing Wastes Task Group
The mission of the Mercury Containing Wastes Task Group 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
The mission of the Mercury Cell Rubber Lining Task Group 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
The mission of the Mercury in Sodium Hydroxide – Current Technology Task Group 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
The mission of the Mercury in Sodium Hydroxide – New Technology Task Group is to identify and evaluate new technologies for further reducing the mercury content of sodium hydroxide to the lowest practical level economically achievable.
APPENDIX B - Task Group Progress Reports
The Mercury Emissions Control and Measurement (MECM) Task Group
The MECM Task Group continued working with EPA in the development of the new mercury NESHAPS for mercury cell chlor-alkali facilities and the implementation of the Binational Strategy agreement for mercury.
The task group conducted the following activities concerning the development of the new mercury NESHAP:
- Met with EPA and its contractor in Research Triangle Park, NC to discuss EPA’s intent for the new mercury NESHAP regulation (April, 1998).
- Worked with EPA and its contractor in scheduling visitations to five mercury cell facilities (May-June 1998).
- Assisted EPA in gathering mercury survey questionnaire data from all fourteen mercury cell chlor-alkali facilities in the U.S.
- Participated in an EPA two-day workshop in Boston (March, 1998) on mercury cell technology.
- Participated in meetings with EPA’s Office of Air Quality Planning and Standards and Great Lakes National Program Office (Region V) in Chicago (October and November, 1998).
- Developed plans for and conducted one-day industry workshop at member company to identify best control techniques for reducing mercury emissions from cell rooms (February, 1999).
- Researched technologies to determine feasible means to measure quantitatively mercury emissions from cell houses.
- Conducted one-day technical workshop for EPA’s contractor, industry’s contractor, EPA personnel, industry personnel and Chlorine Institute personnel at member company facility to address mercury emissions from cell rooms (February, 1999).
- The issuance of a guidance document identifying the best control techniques that can be used by member companies toward further reductions of mercury emissions from cell rooms.
- The identification of a protocol (If technically feasible) that can be used by member companies to measure mercury emissions from cell room operations.
The task group will also continue to participate in the development of the new mercury NESHAP by continuing to interface with EPA and their contractor.
The Mercury Balance Task Group
The guidance document has been developed and a copy is attached. This task group has now sunset. Its monitoring function will be assumed by the Mercury Issues Management Subcommittee.
The Mercury Health Issues Task Group
The task group completed and issued an Institute publication, Guidelines to Physicians in Conducting Mercury Medical Surveillance Programs. This publication complements another publication, Guidelines: Medical Surveillance and Hygiene Monitoring Practices for Control of Worker Exposure to Mercury in the Chlor-Alkali Industry. This group also monitored the activities of the interagency meeting in Research Triangle Park, NC in November concerning the assessment of health effects from exposure to mercury.
The Mercury Containing Wastes Task Group
The Mercury Wastes Task Group continued with its mission of addressing regulatory issues of concern pertaining to mercury-containing wastes and interacting with EPA concerning regulatory proposals. The following solid waste issues were addressed:
- Phase IV Land Ban Regulations
- Re-invention of Land Ban Regulations (June, 1998 EPA Round table)
The Mercury Cell Rubber Lining Task Group
This task group completed its objective with the issuance of the Chlorine Institute Pamphlet 154, Guidelines for the Handling of Rubber-Lined Cell Parts Potentially Contaminated with Mercury (pdf file), issued in January, 1998. With its objective accomplished, this task group has sunset.
The Mercury in Sodium Hydroxide Task Group – Current Technology
Information has been developed by the task group and provided to the membership. The information developed will be consolidated into a guidance document being prepared by the following task group.
The Mercury in Sodium Hydroxide – New Technology Task Group
This task group conducted extensive research on removing mercury from sodium hydroxide. The information developed will be compiled in an Institute guidance document providing information on techniques that have been successful in bench scale tests to lower the mercury content of 50% sodium hydroxide below 5 - 10 ppb. As stated above, a consolidated internal guidance document describing both optimization of existing filtration technology and newly developed laboratory techniques will be prepared.
Note: The Second Annual Report of the Chlorine Institute includes "APPENDIX C - Guidelines for Conducting a Mercury Balance" (pdf file) and "APPENDIX D - Guidelines to Physicians in Conducting Mercury Medical Surveillance Programs" (pdf file).
The Mercury Issues Management Subcommittee has also been very active managing the efforts of the various task groups and in planning the annual Mercury Workshop as part of the annual meeting of The Chlorine Institute.