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2000 Chlorine Institute Annual Report
Third Annual Report to EPA
May 3, 2000
The Chlor-Alkali industry committed to reduce mercury use from the 1990 - 95 average of 160 tons/year by 50% to 80 tons per year by 2005. Included in this commitment was an annual report detailing the progress made to date. This is the third annual report submitted on our progress.
Mercury use is detailed in Table 1. The reduction to date is 45%. After adjusting for two facilities that shutdown in 1999, the reduction in mercury use by the chlor-alkali industry from the base period is 42%. This progress to date keeps us well on target to our goal of 50% reduction. All our members are committed to this goal and are working diligently towards that end.
The group effort involved meetings, plant visits by the agency, workshops hosted by various producers, technology transfers, and individual company progress shared between producers. The true measure of any program is not in the hours committed or even resources committed, but by the actual results. Our results demonstrate our success to date. This effort will continue as we move to fully accomplish our goal.
Industry determined that the objectives of the task group "Mercury Emissions Control and Measurement" was significant enough to warrant two task group efforts. This task group was broken into "Mercury Emissions Measurement Task Group", and "Mercury Control Techniques Task Group". Both groups are functioning and have separate mission statements, detailed in Appendix A.
The Mercury in Sodium Hydroxide - Current Technology Task Group, completed its mission, and turned over the data to The Mercury in Sodium Hydroxide - New Technology Task Group. This task group was very active and has developed new technologies that are capable of substantially reducing mercury levels in sodium hydroxide to the lowest practical level economically achievable. With the completion of a guidance document, Guidelines for Technologies to Reduce Mercury in Sodium Hydroxide (PDF), this task group has completed its work.
Industry worked pro-actively with EPA to detail emissions from a cell house. Industry proposed a novel method to determine emissions, working with the University of Tennessee, on Computational Fluid Dynamics. Also an alternate method was developed by a member company to do an indirect energy balance measurement of air flows out of a cell house. EPA also developed a procedure to accomplish air flow measurement. The end result was a field test completed in early 2000 at a producer's site, comparing two EPA methods and the indirect energy balance method. This effort consumed significant member resources in 1999.
A summary of the various task groups and their activities for 1999 are discussed in appendices A and B.
Miscellaneous Activities
Meetings with EPA continued throughout 1999, similar to previous years, and are anticipated to continue into the future.
Efforts at various state levels continue. Member companies pro-actively work with the state agencies on various issues, one of which is to measure mercury in ambient air down wind ofa chlor-alkali plant. These data have been provided to EPA.
Two mercury cell chlor-alkali facilities, one in Washington
state, and one in North Carolina,
ceased operation in 1999.
A summary of the meetings held with various groups is listed below:
- February 1999 - EPA, Oak Ridge National Laboratory, various states, and University of Michigan researchers - Augusta, GA - Discussion of techniques to measure mercury emissions from cell rooms and other areas of chlor-alkali facilities
- April 1999 - Binational Strategy Group - Toronto, ON - Semi- annual progress meeting
- June 1999 - Environment Canada - Hull, PQ - Discussion of draft CEC revised document Mercury Action Plan
- June 1999 - New England governors - Portland, ME - Discussion of progress made on mercury action plan
- July 1999 - EPA - Research Triangle Park, NC - Discussion of R&D programs to measure mercury emissions from cell rooms
- July 1999 - EPA - Durham, NC - Discussion of mercury MACT standards for chlor-alkali facilities
- August 1999 - EPA - Research Triangle Park, NC - Discussion of R&D programs to measure mercury emissions from cell rooms
- November 1999 - Binational Strategy Group - Chicago, IL - Semi- annual progress meeting
- November 1999 - EPA - Durham, NC - Discussion of mercury MACT standards for chlor-alkali facilities
- December, 1999 - Northeast Waste Management Officials' Association - Bedford, NH - Discussion of Draft Model Act to Reduce Mercury Containing Wastes
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 has established numerous technical task groups to carry out its mission.
In 1999 one task group, the Mercury Emissions Control and Measurement (MECM) was separated into two (2) separate task groups: Mercury Emissions Measurement (MEM) and Mercury Control Techniques (MCT). In addition, two (2) task groups, Mercury in Sodium Hydroxide - Current Technology and Mercury in Sodium Hydroxide - New Technology were combined.
The five currently active technical task groups include the following:
The Mercury Emissions Measurement (MEM) Task Group
The mission of the Mercury Emissions Measurement (MEM) Task Group is to identify methods that are technically feasible to measure mercury emissions from cell room operations.
The Mercury Control Techniques (MCT) Task Group
The mission of the Mercury Control Techniques (MCT) Task Group is to identify and communicate control techniques and technologies that can be used by member companies to further reduce mercury emissions from the cell rooms.
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 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 for 1999 Activities
The Mercury Emissions Measurement (MEM) Task Group
The MEM 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 in 1999:
- Assisted EPA in gathering and reviewing mercury survey questionnaire data from all mercury cell chlor-alkali facilities in the U. S. (1998/1999)
- Held joint meeting with EPA and EPA's contractor ECR personnel to discuss EPA's first draft proposal on the mercury NESHAP MACT standard (July,1999). Provided feedback on draft proposal
- Held joint meeting with EPA and EPA's contractor to discuss revised EPA draft proposal on point sources and housekeeping standards for the mercury NESHAP MACT standard (November, 1999)
- Evaluated EPA's data summary for MACT development, submitted data on Hydrogen and endbox systems to EPA (December, 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 measuring mercury emissions from cell rooms (February, 1999)
- Held joint meeting with EPA's Binational Strategy, Office of Research and Development (RTP & Cincinnati), Oak Ridge National Laboratory, University of Michigan, Region IV and Region V personnel in Research Triangle Park to discuss potential ways of measuring mercury emissions from a mercury chlor-alkali cell room (July, 1999)
- Held joint meeting with EPA's Binational Strategy, Office of Research and Development (RTP & Cincinnati), Oak Ridge National Laboratory, University of Michigan, Region IV, Region V and University of Tennessee Knoxville personnel in Research Triangle Park to discuss EPA's proposal and industry's proposals to measure mercury emissions from a mercury cell room (August, 1999)
- Agreed to proceed with implementation of EPA's three (3) phased proposal to quantify mercury emissions from a mercury cell room at a member company facility and member company implemented agreement with EPA (October, 1999). Agreed to testing of an alternate indirect measurement method "Heat Balance Method" after EPA recommendation.
The Mercury Control Techniques (MCT) Task Group
The Mercury Control Techniques Task Group held two workshops that were attended by plant operating personnel from mercury cell chlor-alkali facilities and prepared a draft guidance document that will be used by member companies to reduce mercury use/emissions.
The first workshop was held at the Pioneer, St. Gabriel, Louisiana facility in February. During this workshop, the group of approximately 30 attendees brainstormed ideas to reduce mercury use/ emissions. This brainstorming list, along with a document provided by a member company, was used to prepare a draft guidance document.
The second workshop was held at the Vulcan, Port Edwards, Wisconsin facility in November. This workshop focused on reducing mercury emissions related to maintenance of cells and decomposers. The intended participants were those that work closely to cell maintenance and operation. Approximately 25 attendees exchanged ideas during the 1½ day workshop.
Plans for year 2000 include conducting a workshop at the OxyChem, Muscle Shoals, Alabama facility, and completion of the internal guidance document. The 1 ½ day workshop is planned for June and will focus on housekeeping issues (prevention of leaks, detection of leaks, and spill cleanup). This workshop will be similar in format to the November 1999 workshop, providing a forum for participants that work directly in the cell rooms to exchange ideas related to mercury housekeeping.
The Mercury Health Issues Task Group
No new issues were identified in 1999.
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. Comments were submitted to EPA in July regarding the Advanced Notice of Proposed Rulemaking pertaining to possible changes in treatment standards for mercury containing wastes.
The Mercury in Sodium Hydroxide - New Technology Task Group
With the issuance of guidance document referenced above, this task group is being sunset.
The following task groups completed their mission and were sunset in 1999 or earlier years.
- The Mercury Balance Task Group (1999)
- The Mercury in Sodium Hydroxide - Current Technology Task Group (1999)
- The Mercury Cell Rubber Lining Task Group (1998)
Electronically-available appendices to the Guidelines (pdf files):
- Analytical Considerations (PDF)
- SUrvey of Mechanical Filtration from 50% Sodium Hydroxide Solutions (PDF)
- Optimization of RP Adams Filter (PDF)
- Selective Absorption Technologies (PDF)
he 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.