&EPA
USEPAOItoolRB[!rchani!D.vt!ep=to!
        United States
        Environmental Protection
        Agency
           Office of Research and
           Development
           Washington DC 20460
EPA/625/R-00/014
June 2001
Proceedings and Summary
Report

Workshop on Mercury in
Products, Processes,
Waste and the Environment:
Eliminating, Reducing and
Managing Risks from
Non-Combustion Sources

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                                         EPA/625/R-00/014
                                            June 2001
    Proceedings and Summary Report

     Workshop on Mercury in Products,
Processes, Waste and the Environment:
 Eliminating, Reducing and Managing Risks
       from Non-Combustion Sources
                   March 22-23, 2000
                    Baltimore, MD
           National Risk Management Research Laboratory
              Office of Research and Development
              U.S. Environmental Protection Agency
                  Cincinnati, Ohio 45268
                                     Recycled/Recyclable
                                     Printed with vegetable-based ink on
                                     paper that contains a minimum of
                                     50% post-consumer fiber content
                                     processed chlorine free.

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                                       Notice

The United States Environmental Protection Agency (EPA), through its Office of Research and
Development, funded and managed the research described here under Contract 68-C7-0011 to
Science Applications International Corporation (SAIC). It has been subjected to the Agency's peer
administrative review and has been approved for publication as an EPA document. Statements
captured  in the panel discussion summary in Appendix  C are those of  the participants, not
necessarily reflective of the EPA. Mention of trade  names or commercial products does not
constitute endorsement or recommendation for use.
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                                      Foreword
       The U.S. Environmental Protection Agency is charged by Congress with protecting the
Nation's land, air, and water resources.  Under a mandate of national environmental laws, the
Agency strives to formulate and implement actions leading to a compatible balance between human
activities and the ability of natural systems to support and nurture life. To meet this mandate, EPA's
research program is providing data and technical support for solving environmental problems today
and building a science knowledge base necessary to manage our ecological resources wisely,
understand how pollutants affect our health, and prevent or reduce environmental risks in the future.

       The National Risk Management Research Laboratory (NRMRL) is the Agency's center for
investigation of technological and management approaches for preventing and reducing risks from
pollution that threaten human health and the environment. The focus of the Laboratory's research
program is on methods and their cost-effectiveness for prevention and control of pollution to air,
land,  water, and  subsurface resources;  protection of water  quality in public  water systems;
remediation of contaminated sites, sediments and ground water; prevention and control of indoor air
pollution; and restoration of ecosystems. NRMRL collaborates  with both public and private sector
partners to foster technologies that reduce the cost of compliance and to anticipate emerging
problems. NRMRL's research provides solutions to environmental problems by: developing and
promoting technologies that protect and improve the  environment; advancing scientific and
engineering information to support regulatory and policy decisions; and providing the technical
support and information transfer  to ensure implementation of environmental regulations and
strategies at the national, state, and community levels.

       This publication has been produced as part of the Laboratory's strategic long-term research
plan.  It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
                                        E. Timothy Oppelt, Director
                                        National Risk Management Research Laboratory
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                                       Abstract

Mercury contamination, both nationally and internationally, has long been recognized as a growing
problem for humans and ecosystems, since mercury does not degrade to simpler compounds. Once
it is released to the environment, it will always be present in one form or another.  Mercury is
released to the environment from a variety of human (anthropogenic) sources including plant effluent
discharge, fossil-fuel combustors, incinerators, chlor-alkali plants, mining and landfills.  Other
sources of anthropogenic mercury release include industrial processes and the disposal of products
containing mercury. Anthropogenic sources of mercury emissions to the atmosphere include fossil
fuel combustion (containing trace amounts of mercury), municipal incineration, medical waste
incineration,  chlor-alkali plants, and landfills.  These emission sources represent a  significant
contribution to the total mercury released (including natural and re-emitted) in the United States.
A workshop titled, Mercury in Products, Processes, Waste and the Environment: Eliminating,
Reducing and Managing Risks from Non-combustion Sources, was held on March 22-23, 2000,
in Baltimore, Maryland. To facilitate discussions of these issues, the workshop combined a series
of presentations at plenary sessions, moderated technical sessions and panel discussions. The topics
of these presentations focused on treatment and disposal technologies, stockpile management, and
prevention,  collection  and elimination programs.  Presenters were from U.S.  Environmental
Protection Agency (USEPA), Department of Energy (DOE),  state agencies, industry, academia,
technology developers, equipment manufacturers, consulting firms, international representatives.
The presentations were followed by two panel discussions: the first addressed treatment and disposal
of mercury-contaminated wastes and the second addressed prevention, collection, and elimination
issues. This report provides a discussion of the overarching issues in mercury treatment, disposal,
prevention, collection, and elimination, and a summary of the panel discussions that took place at
the close of the workshop.
                                           IV

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                                      Contents
Foreword 	iii

Abstract  	iv

List of Acronyms	  vii

Acknowledgments	viii

Executive Summary

Section 1     Introduction	1
       1.1    Workshop Structure, Purpose, and Intended Audience  	1
       1.2    Background  	1
       1.3    Need for Eliminating, Reducing and Managing Risks from
             Non-Combustion Sources	2

Section 2     Treatment and Disposal Options	3
      2.1    Regulations Guiding Treatment and Disposal of Mercury Waste	3
      2.2    State of the Science in Treatment Options for Mercury Waste	4
      2.3    State of the Science in Disposal Options for Mercury Waste 	5
      2.4    Additional Topics of Concern from Treatment and Disposal
             Panel Discussion	7

Section 3     Prevention, Collection, and Elimination  	11
      3.1    Current Status of Mercury Prevention, Collection, and Elimination	11
      3.2    Issues in Mercury Prevention, Collection, and Elimination  	11
      3.3    Additional Topics of Concern from Prevention, Collection, and
             Elimination Panel Discussion 	12

Section 4     Summary and Conclusions	17

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Appendices
A     Workshop Agenda
B     Workshop Abstracts ................................................      21

C     Panel Discussion Summary - Treatment and Disposal  .......................... 71

D     Panel Discussion Summary - Prevention, Collection, and Elimination .............. 81

E     List of Attendees ...............................................          95
                                         VI

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                              List of Acronyms

ANPRM      Advance Notice of Potential Rulemaking
BDAT       Best Demonstrated Available Technology
DLA         Defense Logistics Agency
DOD         Department of Defense
DOE         Department of Energy
EPA         Environmental Protection Agency
FR          Federal Register
GAC         Granular Activated Carbon
Hg          Mercury
HW         Hazardous Waste
LDR         Land Disposal Restrictions
MSW        Municipal Solid Waste
NESHAP     National Emissions Standards for Hazardous Air Pollutants
NGO         Non Government Organization
NRC         Nuclear Regulatory Commission
NRMRL      National Risk Management Research Laboratory
P2           Pollution Prevention
PBT         Persistent, Bioaccumulative, and Toxic
RCRA       Resource Conservation and Recovery Act
SAMMS      Self-Assembled Mercaptans on Mesoporous Silica
TCLP        Toxicity Characteristic Leaching Procedure
                                       VII

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                              Acknowledgments
Many people contributed their expertise to the preparation and review of this publication. Overall
technical guidance was provided by Douglas Grosse of the U.S. EPA's National Risk Management
Research Laboratory. The document was prepared by Lisa Kulujian and Lisa Enderle of Science
Applications International Corporation. The following people provided guidance and review:
      Jonathan Herrmann

      Benjamin Blaney

      Paul Randall

      Josh Lewis

      Edward Weiler


      Jeri Weiss
USEPA, National Risk Management Research Laboratory

USEPA, National Risk Management Research Laboratory

USEPA, National Risk Management Research Laboratory

USEPA, Office of Solid Waste

USEPA, Office of Prevention, Pesticides and Toxic
Substances

USEPA, Region I
                                        VIII

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                               Executive Summary

                                      Section 1
                                    Introduction
1.1     Workshop Structure, Purpose, and Intended Audience

A workshop titled "Mercury in Products, Processes, Waste and the Environment: Eliminating,
Reducing and Managing Risks from Non-Combustion Sources," was held on March 22 - 23,2000,
in Baltimore, Maryland.

The purpose of the workshop was to achieve three goals:
1.  Convey public, non-profit, and private sector perspectives on the management of mercury in
   , products, processes, and wastes;
2.  Present ongoing efforts that address mercury prevention, elimination, non-combustion treatment
    and disposal; and
3.  Identify data gaps and information needs to improve mercury risk management in products,
    processes, waste  and the environment.

To facilitate discussions of these issues, the workshop featured a series of presentations at a plenary
session, moderated technical sessions and panel discussions.  The topics of these presentations
focused on treatment and disposal technologies, stockpile management, and prevention, collection
and elimination programs.  Presenters were from U.S. Environmental Protection Agency (USEPA),
Department of Energy (DOE), state agencies, industry, academia, technology developers, equipment
manufacturers, and consulting firms, which included international participants.  The technical
presentations were followed by two panel discussions: the first addressed treatment and disposal of
mercury-contaminated wastes and  the second addressed prevention, collection, and elimination
issues. Statements captured in Appendix C, Panel Discussion Summary - Treatment and Disposal,
are those of the participants, not necessarily the EPA.

This report provides  a summary of the key issues pertaining to mercury treatment, disposal,
prevention, collection, and elimination, followed by speaker abstracts and a transcript of the panel
discussions that took place at the close of the workshop.

1.2 Background

Mercury contamination, both nationally and internationally, has long been recognized as a growing
problem for both humans and ecosystems, since mercury does not degrade to simpler compounds.
Once released to the environment,  it will always be present in one form or another.  Mercury is

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released to the environment from a variety of human (anthropogenic) sources including plant effluent
discharge, fossil-fuel combustors,  incinerators, chlor-alkali plants, mining, and landfills.  Other
sources of anthropogenic mercury release include industrial processes and the disposal of products
containing mercury.

Anthropogenic sources of mercury emissions  to the atmosphere include fossil fuel combustion
(containing trace amounts of mercury), municipal incineration, medical waste incineration, chlor-
alkali plants, and landfills. These emission sources represent a significant contribution to the total
mercury released (including natural and re-emitted) in the United States. The 1997 Mercury Study
Report to Congress indicated that the deposition of atmospheric mercury has increased by a factor
of two to five over pre-industrial  levels. Reference: (EPA Document Nos. EPA-452/R-97-003
through 010, http://epa.gov/oar/mercury.html).  Furthermore,  most atmospherically deposited
mercury is in the form of gaseous or particulate-phase inorganic mercury.  Unfortunately, the
inorganic mercury released into the environment can be converted, by naturally occurring biological
processes, into the highly toxic methyl mercury species.

1.3 Need for Eliminating, Reducing and Managing Risks from Non-Combustion
    Sources

Mercury has been identified as a persistent, bioaccumulative, and toxic (PBT) chemical, (Office of
Pollution Prevention and Toxic Substances) making it a chemical of concern. PBT chemicals are
of great concern because they persist in the environment, bioaccumulate in the food chain, and are
toxic, posing a significant threat to humans,  and ecosystems. Many of these chemicals, including
mercury, are of concern because they easily transfer from one media to another in the environment.
EPA is in the process of developing a research strategy which aims to address the mercury problem
through multimedia initiatives.

Controlling the environmental risks associated with mercury is complicated by several  issues:
mobility, exposure, and PBT characteristics.  Elemental mercury, frequently found in products and
processes, volatilizes readily at ambient and combustion temperatures, leading to air emissions from
almost every process or product using mercury. Elemental mercury can remain in the atmosphere
for long periods of time; thereby being dispersed over a large geographical area.  Further, multiple
exposure pathways exist for the various mercury species. The most critical concern is the formation
of highly toxic and  bioaccumulative methyl mercury in water bodies.  Thirdly,  the  PBT
characteristics of mercury ensure that it will pose a threat to human health and ecosystems for a long
time to come.  For these reasons, safe treatment and disposal, and prevention, collection, and
elimination of mercury are at the forefront of environmental risk management.

This workshop was divided into two major concurrent session which dealt with (1) treatment and
disposal options and (2) prevention, collection and elimination initiatives.  Sections 2 and 3  present
summaries of presentations made in each of the two respective sessions.  Section 4 provides a
summary and conclusions from the overall workshop. Material and discussions presented at this
workshop reflect the opinions and ideas of the presenters and participants  and not the participating
organizations.

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                                      Section 2
                        Treatment and Disposal Options

2.1  Regulations Guiding Treatment and Disposal of Mercury Waste

The EPA defines waste with mercury concentrations above a certain threshold (40 CFR §261.24)
as characteristically hazardous. These wastes are defined as any waste that is characteristically
hazardous based on the concentration of mercury in its leachate, as determined by the Toxicity
Characteristic Leaching Procedure (TCLP). EPA was required by the Hazardous and Solid Waste
Amendments (HS WA) to the Resource Conservation and Recovery Act (RCRA) in 1984 to establish
treatment standards for all listed and characteristic hazardous waste destined for land disposal.  The
First Final Rule (53 FR 31166, August 17,1988) established standards for brine purification muds,
and the Third Final Rule (55 FR 22569, June 1,1990) established treatment standards for five more
wastewater and nonwastewater codes which contain mercury as the primary hazardous constituent.
Some of these standards were revised under the Universal Treatment Standards in the Phase II Land
Disposal Restrictions (LDR) Rule (59 FR 47980, September 19, 1994) and further revisions were
made in the Phase IV Final  Rule (63  FR 28556, May 26,  1998).   Mixed wastes, which are
radioactive RCRA hazardous wastes, are currently regulated under both RCRA and the Atomic
Energy Act of 1954.

There are two recent proposed updates to the rules governing the disposal of mercury-bearing wastes:

Storage, Treatment, Transportation, andDisposalofMixedWaste,publishedonNovemberl9,1999
(64 FR 63464). This proposed rule would provide flexibility to generators of mixed waste in the
form of a conditional exemption from the definition of hazardous waste for some types of wastes and
activities.  The goal of this proposal is to reduce dual regulation for generators, transporters, and
disposers in  the management of these wastes.  Wastes that fall under the  specific areas in the
proposed rule  will be regulated  and managed  as  hazardous  waste in accordance with NRC
regulations, and will be exempted from RCRA Subtitle C regulations. EPA is currently developing
the final rule.

Potential Revisions to the Land Disposal Restrictions Mercury Treatment Standards, published on
May 28, 1999 (64 Federal Register 28949). This  Advance Notice of Proposed Rulemaking
(ANPRM) seeks to begin  a comprehensive review of the standards for treating mercury-bearing
hazardous waste. The specific goals are to review  and update EPA's waste generation and treatment
data for mercury-bearing hazardous wastes, present technical and policy issues for public discussion,
and determine an avenue  by  which  current mercury treatment standards may be  revised.  The
anticipated proposed rule is scheduled, for late 2001.

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 2.2 State of the Science in Treatment Options for Mercury Waste

 The  most  common  techniques  currently  used  for  treating  mercury-bearing  waste  are
 roasting/retorting and incineration. These thermal techniques separate the mercury from the rest of
 the waste stream and condense it for recovery or removal.  The treatment technology used depends
 on the type of waste being treated. In many cases, a "treatment train" of technologies is used, where
 one technology is used to pre-treat the waste to remove characteristics that inhibit the effectiveness
 of another treatment technology.

 The need for further research evaluating "treatment trains" was discussed during the workshop.
 Participants felt that a combination of the technologies listed below and new technologies discussed
 during the sessions, will be the best possible way to treat mercury-bearing wastes.

 Roasting and Retorting Mercury Wastes (RMERQ

 During retorting, mercury-bearing waste is sealed in a batch vessel, heated, with the volatile gases
 released. Mercury vapor is condensed and collected. Roasting mercury-bearing wastes involves
 introducing air to the hot waste which oxidizes mercury compounds and helps transport them to a
 condenser.  In either process, collected mercury  may be purified for resale or reuse through
 successive distillation.  The remaining waste residues derived from the RMERC process must be
 retested to ensure sufficient mercury removal.  If the mercury content of the waste remains above
 the allowable level (260 mg/kg total mercury) the waste must be roasted or retorted again. Wastes
 below this mercury content must meet a TCLP mercury  standard of 0.20 mg/L  prior to land
 disposal.

 Incinerating Mercury Wastes

 During incineration, mercury is volatilized from mercury-bearing wastes and converted to elemental
 mercury in the high temperature regions of the furnace. As the flue gas cools, the elemental mercury
 is oxidized to ionic forms. Elemental mercury, mercuric chloride, and mercuric oxide, each present
 in the vapor phase of flue gas, must be captured by various methods, such as adsorption onto porous
 solids such as fly ash, or removed using a wet scrubber. The efficiency of these mercury-removal
 methods varies by incinerator and method.

 Alternative Treatment Technologies

 In recent years, several alternative treatment technologies  have been developed to treat mercury-
 bearing wastes. The need for developing alternative treatment methods arises from complex waste
 characteristics greaterremoval efficiency, and/or cost reduction. Some of these alternative processes
 include:

Removal and recovery technologies. This category includes: (1) acid/chemical leaching, where the
 mercury is converted to a more  soluble form for removal from the waste matrix;  (2) carbon
 adsorption, where mercury is removed from stack gas or effluents and concentrated; and (3) ion

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 exchange, where ions in the exchange resins are substituted for mercury ions, facilitating mercury
 removal.

 Immobilization Technologies.  This category includes solidification and stabilization processes,
 where the mercury is immobilized in a matrix such as cement or flyash for long-term storage and
 amalgamation, where elemental mercury is mixed with a powdered granular metal to form a semi-
 solid matrix for long-term storage. Stabilization techniques, such as the combination of elemental
 mercury with a sulfur mixture to create insoluble HgS can produce a residual which will pass the
 TCLP. Use of these technologies is dependent on the characteristics of the waste treated.

 Thermal/Chemical Oxidation. Thermal and chemical oxidation, is a destruction technology that is
 frequently used in conjunction with other processes, as part of a treatment train. Oxidation may
 prepare the waste for retorting or immobilization for disposal.

' Developing Technologies. Some developing technologies include nonthermal methods, direct
 chemical oxidation, acid digestion, and thermal processes such as steam reforming. These methods
 may be used separately or in conjunction with other treatment processes, such as stabilization.

 Additional Treatment Technologies Discussed at the Conference:

 Adsorbents/Calgon™ F400 GAC. This granulated activated carbon- (GAC-) based adsorbent was
 used in a pilot-scale study of removal of mercury from pharmaceutical wastewater generated by the
 production of thimerosal, a mercury-containing preservative.  Treatment with the GAC system
 reduced the mercury content of the  wastewater by a factor of 400, enabling wastewater that was
 previously disposed of as hazardous waste to pass the TCLP and be considered non-hazardous.

 Adsorbents/SAMMS.™  This  adsorbent,  called  SAMMS  (Self-Assembled  Monolayers  on
 Mesoporous Materials), is a versatile mercury-philic material that can be used to extract mercury
 from contaminated oil and other waste streams.  Studies have shown up to 90% mercury removal
 using this material, which provides a cost-effective and versatile treatment option. This material was
 recently developed, and has not been widely available for use.
 2.3 State of the Science in Disposal Options for Mercury Waste

 There are two possible destinations for mercury separated from mercury-bearing waste: reuse and
 disposal. Many of the treatment options described in Section 2.2 of this report extract mercury from
 waste. The extracted mercury is purified for reuse and either returned to the industrial process or
 resold through the secondary mercury market. The mercury that remains in the waste after treatment
 is disposed.  The regulations described in Section 2.1 of this report govern the mercury content of
 disposed wastes.

 Mercury-bearing waste treatment options are geared towards the type of waste and the disposal
 method to be used.  Some treatment options aim to lower the mercury content to an acceptable level

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 for land disposal. However, others such as amalgamation, solidification, and stabilization, seek to
 lock the mercury inside a matrix to enable land disposal of higher quantities of mercury. While the
 long-term performance of some of these methods may be in question, there are a number of options
 for mercury-bearing waste disposal.

 Landfill Disposal Wastes that pass the TCLP may be land disposed. The TCLP test is designed to
 ensure that mercury will not leach out of the waste matrix under landfill conditions. However,
 concerns about the suitability of the TCLP cast some doubt on this  practice, as there is debate
 whether the TCLP accurately predicts real world landfill conditions. Landfills may be responsible
 for air emissions due to the low volatilization temperature of mercury, although these emissions may
 be minimal due to the lack of a carrier gas such as methane. There is also the potential for long-term
 hazards, such as landfill cracking, with land disposal of mercury. In spite of these issues, landfill
 disposal after treatment has long been the preferred method of mercury waste disposal.

' Subseabed Emplacement. This method of disposal seals solidified waste inside a cannister, which
 is then placed in deep-sea sediments. The waste form, cannister, sediment, and ocean water should
 inhibit the migration of hazardous quantities of waste.  This method was developed with the intent
 of isolating radioactive materials for long periods of time to allow the radionuclides to decay to
 harmless forms. Because mercury is nonradioactive, it presents a permanent environmental threat,
 and the long-term stability of this disposal method has not been fully studied.

 Stabilization. The stabilization of mercury-bearing waste to provide a durable long-term waste form
 is the objective of many treatment  and disposal options. Mercury sulfide, chemically bonded
 phosphate ceramics are all waste forms which have been used; each having advantages over the
 other. For example, mercuric chloride is quite soluble; hence, mobile.  This type of treatment often
 reduces the mercury vapor pressure and leachability sufficiently to enable the waste to be disposed
 of as non-hazardous. However, these are relatively new technologies and there is concern that we
 many not know the true long-term durability of these waste forms. It has been shown that laboratory
 experiments often do not  properly predict the long-term conditions found in landfills.   Since
 mercury is not radioactive, it does not degrade; thereby,  posing a continuous threat to the
 environment. Many conference participants felt that further research is needed to ensure long-term
 protection of human health and the environment from these technologies.

 Surface, Shallow, and Deep Storage. As mercury stockpiles grow from increased recycling and
 collection efforts, long-term mercury storage is an option that circumvents some of the uncertainties
 associated with disposal practices. Doubts about the performance of land-disposed and subseabed
 disposed wastes under real-world conditions, makes long-term storage options appealing. State-of-
 the-art surface, shallow, and deep storage have been examined for this  purpose.

 Deep geological repositories, such as mines, are currently being used in Europe for the long-term
 disposal of mercury wastes. These repositories have the advantage of reducing the potential for
 exposure that confronts surface repositories.  However, there are  concerns that  deep-disposed
 mercury may find a pathway back to the surface in oil and natural gas. Surface storage, has the
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advantage of easier monitoring for the purpose of intervention in the event that it is needed. While
it is possible to monitor deep-disposed wastes, it is difficult to correct a problem should one arise.

2.4 Additional Topics of Concern from Treatment and Disposal Panel Discussion

The purpose of the panel discussion on treatment and disposal was to discuss a) the state-of-the-art
of mercury treatment and disposal techniques for mercury wastes and stockpiles, and b) to identify
maj or research needs/directions needed to meet the goal of bringing the state of technologies (or any
other options) closer to environmentally safe (including in the long term), cost-effective treatment
and disposal processes.  The proceedings of this panel discussion are provided as Appendix C in this
report.  This section highlights the recurring themes that drove the discussion of the panel members
and attendees.

The panelists were asked to respond to two sets of questions.

 Question A: State of the Art and Significant Advances.

•   What are two or three accomplishments described in the treatment and disposal session that may
    support significant advances in the state of the art in non-combustion options for mercury
    waste/stockpile treatment and disposal techniques?

•   Based on your  general knowledge, how would you  characterize the state of the art of non-
    combustion techniques for mercury treatment and disposal with respect to where we currently
    stand in meeting the goal stated above?

Question B: Research Needs.

•   What are three  priority research areas you feel are most important to address so that we can
    make significant steps toward reaching the goal stated above?

Accomplishments Supporting Advances

The panelists listed recent accomplishments they felt were specifically supporting of advances in the
state-of-the-art in treatment and disposal. Each of these topics has been discussed in the preceding
section. Selections included both technical accomplishments, such as new treatment processes or
materials, and  regulatory accomplishments, such as the  formation  of partnerships  and the
classification of wastes.

•   Mercury sulfide.  The mercury sulfide method of stabilization and disposal is significant
    because it essentially puts mercury back where it came from.
•   Waste type.  Recent technologies make a distinction between Resource Conservation and
    Recovery Act (RCRA) wastes and mixed waste mercury.
•   Thermal desorption. Thermal desorption may be the most sensible technology for mercury-
    contaminated soils because it can also deal with organics and other species.

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•    Formation of partnerships. The next step in advancing treatment and disposal will come from
     the formation of partnerships among waste generators, treaters, and regulators, and getting the
     available technologies out to the field.
•    Electrochemical processes.  Progress in developing electrochemical processes, which could
     have many future applications, would be welcome. This technology could be improved or
     modified for use.
•    SAMMS material. The newly engineered S AMMS material, which may be useable as a drop-in
     replacement for ion-exchange, appears to have potential.

State of the Art

Many of the panelists agreed that the state of the art in mercury treatment and disposal is good.
Effective technologies exist for treating mercury waste containing  less than and greater than 260
ppm mercury. These technologies are either commercially available or soon to be available, with
the best treatment determined by the specific market and waste. The available technologies are more
similar than dissimilar in that they focus on  keeping mercury immobile or  insoluble. There is no
"silver bullet" technology available, or likely to be identified; rather, it is likely that only incremental
changes in technologies will occur in the future.

While the panelists agreed on the state of technological availability, several panelists noted that there
are problems that need to be solved.  One of those that was frequently discussed is the performance
and propriety of measurement standards such as the TCLP. Both the technical utility of the test and
the propriety of landfilling wastes with low levels of mercury was  questioned.  Panelists also noted
that there are technical issues with many of the currently used treatment and disposal options that
require further research, such as the long-term stability of amalgams and macroencapsulation under
real-world conditions.

Research Needs

Panelists and the audience were asked to identify priority research  needs for mercury treatment and
disposal. They responded with the following needs:

•    Alternatives to the TCLP. There is a  need to identify alternatives to compensate for the
     inadequacies of the TCLP, which a) only concentrates on one pH range, and is therefore not
     representative of long-term landfill conditions; b) only provides a static snapshot (18 hours);
     c) provides no mechanism information; and d) has artificial particle size requirements.
    Furthermore, there is a need for standardization in testing procedures, with the regulatory and
     scientific  communities in agreement.   Standardization  will increase confidence  in the
    measurement results.
•   Long-term Performance of Disposal Options Under Real-World Conditions. There is a need
     for further research into the  long-term performance  of stabilization,  amalgamation and
    macroencapsulation due to the effects  of pH on storage and disposal of mercury wastes.
    Previous testing has assumed a constant  pH, which may not be accurate under real storage and
    disposal conditions, such as a landfill. It must be determined whether fluctuations in pH will
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    reduce the suitability of some storage and disposal technologies.
    Mercury Emissions from Landfills.  There is ,'a need for additional research into mercury
    emissions from landfills  to determine the potential for environmental impact from mercury
    waste following disposal.                           .
    Durable Short-term Storage.  There is a need for further research into durable short-term
    stockpile storage options for elemental mercury.
    International Technology Transfer. There is a need for technology transfer to other countries
    to communicate the status of the U.S. program on mercury.  An international policy forum to
    discuss reduction  of mercury use and consumption was suggested with the provision of
    international incentives to reduce mercury use and pollution.
    Non-Intrusive Mercury Measurement. There is a need to develop a non-intrusive method for
    measuring or identifying mercury in waste. Non-intrusive identification of mercury will allow
    easier identification and disposal of non-mercury wastes.
    Transmutation of Radionuclides. There is a need for further research into the transmutation of
    radionuclides to discover how can we better identify and treat mercury and mercury wastes.
    Characterization  of Hazardous Waste  Stream.   There  is  a need  for  economic  and
    characterization information on the hazardous waste stream.  While municipal solid waste
    (MSW) is well characterized, hazardous waste identification codes (such as D009) yield little
    information about the waste. More information regarding the waste will enable more efficient
    recycling, treatment, and disposal.
    Treatment of Commingled Waste.  There is a need for further research on the treatment of
    commingled organics and mercury. Can there be an effective treatment train identified and
    designated as the Best Demonstrated Achievable Technology (BDAT)?
Other Issues of Interest

Propriety of the TCLP.  Attendees expressed concerns about the TCLP on several levels, including
the representativeness of the test, the testing procedure, and the interpretation of the results.

The TCLP may not be the most appropriate tool to determine the utility of treatment technologies.
The test is also limited by one pH range, which is not necessarily representative of real-world landfill
conditions. The test uses a duration of 18 hours, which may not be sufficient to determine the long-
term stability of a waste form. Other limitations include: (1) the procedure provides no mechanism
information, therefore does not yield sufficient information about the process taking place; and (2)
has artificial size requirements that are not representative of real-world landfill conditions. While
the TCLP can be an effective  leach method for assessing treatment and disposal efficiency, under
certain conditions these technical shortcomings may undermine the effort to identify the most
appropriate technologies.

Another issue hampering the utility of the TCLP is the lack of standardization in testing procedures.
Variations  in test conditions may significantly  skew the test results further hampering the
identification of appropriate technologies. A standardization of the procedure, with the regulatory
and scientific communities in agreement, will increase confidence in the measurement results.

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The final issue raised with the TCLP, as well as other leach testing, is the assumption that if a waste
passes the test, it is safe to put in the ground. Aside from the aforementioned concerns that the test
accurately predicts long-term landfill conditions, there is still the question that the big picture is
being overlooked. Wastes that pass the TCLP still contain mercury, and each disposal adds more
mercury mass to the global pool. This maybe a perception issue, rather than a specific shortcoming
of the TCLP.

Stockpile Elimination/Mercury Supply and Demand. The elimination of mercury stockpiles is both
a business and environmental issue. Stockpiles were developed for national security purposes and
for now can be used to ensure a proper balance between supply and demand. There is movement
to eliminate the stockpiles since they pose a potential environmental hazard.

Research and Development.  While there have been numerous technologies developed in recent
years to facilitate the treatment and disposal  of mercury wastes, there is still a need for further
research and development to improve current technologies and identify new ones.  Regulatory
pressure limiting the uses of mercury and enforcement of mercury cleanup regulations would create
a market demand for new and improved technologies. This market demand would in turn stimulate
research and development, which will lead to additional cleanup, treatment, and disposal.

Treatment Train. The next advances in treatment and disposal technology may be in the form of
further development of treatment trains for specific waste types. Waste are commonly treated with
more than one technology; however more research is needed to optimize treatment trains.
                                          10

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             Section 3  Prevention, Collection, and Elimination

3.1 Current Status of Mercury Prevention, Collection, and Elimination
Mercury prevention, collection, and elimination can reduce the need for treatment and disposal over
the long run. These practices intend to on prevent pollution from currently used mercury products,
collecting discarded mercuryproducts and mercury waste removal from commerce and the reduction
or elimination of mercury use.  There are many programs underway in EPA, state and local
organizations to facilitate all three of these practices.

3.2 Issues in Mercury Prevention, Collection, and Elimination
Mercury Waste and  Product Collection.   Municipalities  and international communities have
undertaken mercury-containing product take-back and collection programs designed to remove all
unnecessary mercury from use.  These include the voluntary thermometer  trade-in programs
operating in many municipalities that offer free or discounted digital thermometers in exchange for
mercury  thermometers, as well as large-scale programs such as Sweden's virtual  elimination
program which uses inspectors and mercury-sniffing dogs to identify and label mercury-bearing
products. While these programs often remove large amounts of mercury from use, two potential
limitations to these programs have been identified.  One drawback is the potential for inefficient
collection practices to result in release of mercury to the atmosphere. This occurs because mercury
volatilizes at ambient temperatures; consequently, great care must be taken to ensure that collected
products do not break. The second drawback is the increasing saturation of the secondary mercury
market. While collection of mercury does remove a potential hazard from the consumer, it may
leave agencies with ever-increasing  stockpiles of mercury due to the over-saturated secondary
market.

Mercury Source Reduction.  A long-term method for reducing the need for mercury treatment and
disposal along with the hazards from mercury use is source reduction, the preferred method for
pollution prevention.  Source reduction is the reduction or elimination of the use of mercury in
products and processes; thereby, reducing the demand for mercury entering the marketplace. Source
reduction efforts may include the utilization of mercury substitutes, such  as NewMerc™; the
reduction of mercury use in products, such as the low-mercury fluorescent lamps; and the use of
alternative technologies, such as digital thermometers versus conventional mercury thermometers.
These substitutes may not befeasible for all applications, because they do not reproduce the same
characteristics of mercury. However, there are many applications where these substitute chemicals
and technologies will be sufficient.

Identification of Pollution Prevention Opportunities. Since pollution prevention (P2) can be applied
to a wide range of industries, EPA has taken the lead in identifying P2 opportunities  for mercury
source reduction.  EPA  has initiated a P2 Prioritization Assessment which will guide the
development of P2 opportunities.
                                          11

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 Mercury Dogs. Swedish agencies use mercury-sniffing dogs to identify mercury in products and
 wastes.

 Middle-level Handling of Mercury. Currently, industries that collect mercury-containing instruments
 such as thermostats and thermometers are not regulated. The government is promoting incentives
 to encourage collection efforts that are economically viable without releasing mercury into the
 environment. Regulation of this collection program is typically done at the state and local level. For
 example, Minnesota regulates collectors under the universal hazardous waste rule and have obtained
 good oversight of their activities.

 EPA received a petition from the Edison Electric Institute to add all mercury-containing devices to
 the Universal Waste Rule to help  better  manage these devices.  Utilities also use mercury
 instruments such as temperature and pressure sensors within their processes. EPA has not yet acted
 on this petition.
 3.3 Additional Topics of Concern from Prevention, Collection, and Elimination Panel
     Discussion

 The panel discussion on prevention, collection, and elimination focused on the need to reduce the
 amount of mercury entering the waste stream through improved pollution prevention techniques,
 waste collection methods, and source reduction.   The proceedings of this panel discussion are
 included as Appendix B to this report. This section highlights the recurring themes that drove the
 discussion of the panel members and attendees.

 The panelists were asked to respond to four questions:

 1.   What are the two or three most important insights you want to convey to the audience regarding
     the management of mercury from non-combustion sources?

2.  What are the two or three most critical/essential efforts that need to be undertaken to prevent,
    eliminate, treat, or dispose of mercury from non-combustion sources?

2.  Name  two or three  data gaps or information needs for mercury risk management from non-
    combustion sources.

4.  Prioritize the two or three most important research needs  for managing risks from non-
    combustion sources of mercury.
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Conclusions:

Cooperation.  Cooperation is essential both within industries and between industry and regulators.
The chlor-alkali industry realized that some plants can manage at mercury control better than others,
and they can all learn from each other without engaging in uncompetitive practices. The industry as
a whole has realized that working with regulators toward a common goal can allow both parties to
maximize their limited resources.

Set Achievable Goals. It is important to set achievable goals in eliminating mercury use and reducing
mercury waste. Total elimination is not practical since mecury is  mobile and is persistent in the
environment (i.e., multimedia).  A risk-based approach to determining an acceptable and achievable
level of mercury in products processes and waste is more practical. The chlor-alkali industry has
publically committed to a goal of a 50% reduction in mercury use (using a 1990-95 baseline) by 2005.
A few companies, including Vulcan Chemicals, have set a goal of a 50% mercury consumption
' reduction based on a 1999 baseline. The industry intends to achieve these goals through cooperation
with the regulatory community. Most plants are on track to achieving their goals.

Although the U.S. chlor-alkali industry have not planned a phase-out of mercury in the U.S. any
phase-out needs to be well-planned as a cooperative venture between the government and industry.
An immediate phase-out could have unintended consequences. For example, any disruption in alkali
production could force alkali prices to rise and spur increases in production elsewhere in the world,
such as Mexico, where chlor-alkali facilities are subject to less stringent environmental regulations.
     Members of the chlor-alkali industry have worked together to address the following issues:

     •   Mercury in Sodium Hydroxide.  The chlor-alkali industry's mercury in sodium hydroxide
         task group is about to release a draft publication that details the best strategy available on
         minimizing mercury in sodium hydroxide.
     •   Mercury Health Issues. The chlor-alkali industry has also convened a mercury health issues
         task group that has looked into ensuring that the  best science is used to provide worker
         safety at chlor-alkali facilities.
     •   Mercury Balance.  George Gissel stated that Vulcan Chemicals has assessed its mercury
         balance since 1973. Other chlor-alkali companies have looked toward this example to assist
         them in establishing a mercury balance. Vulcan Chemicals  has given several seminars to
         the chlor-alkali industry about mercury balance. Through a multi-year evaluation of mercury
         consumption and purchasing, a facility can gain a better understanding of  minimizing
         mercury consumption and  losses.
     •   Cross-plant/Cross-industry Sharing for Continuous Improvement. The chlor-alkali industry
         formed the mercury control task group to identify the best management practices. This task
         group has produced two in-plant technology exchange workshops in 1999, with a third
         planned  for 2000.  These workshops provide detailed descriptions on using specific
         technologies.
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     The chlor-alkali industry has worked with the EPA to address the following issues:

     •   Measuring Cell Room Fugitive Emissions.  The chlor-alkali industry formed a mercury
         emissions measurement task group to work with the EPA toward  a common goal of
         measuring cell room fugitive emissions.  The EPA at Research Triangle Park (RTP)
         developed the protocol. Testing began at the Olin Corporation's Augusta, Georgia, facility.
         The Chlorine Institute covered the out-of-pocket costs of Olin Corporation and the EPA is
         underwriting the cost of the equipment and measurements.
     •   Revising National Emissions Standards for  Hazardous  Air Pollutants  (NESHAP)
         regulations.  The EPA worked with the chlor-alkali  industry revising the NESHAP
         regulations.  They are conducting audits at five facilities.

 Pursue Voluntary Efforts.  Although voluntary efforts are not always effective, there are more
 successes than failures.  Experience with the chlor-alkali  industry shows that voluntary efforts can
'yield positive results.

 Encourage Office of Solid Waste (OSW) Efforts. The EPA should support OSW in researching
 alternative disposal technologies.

 Enhance Technology Development and Verification Programs. To enhance technology development
 and verification of alternative mercury technologies, the EPA should look at complementarity
 between ORD's Small Business Innovative Research (SBIR) program and Environmental Technology
 Verification (ETV) program.

 Support Environmentally Preferable  Purchasing.    Use  federal  procurement  to achieve
 environmentally preferable purchasing by reducing mercury in commerce.

 International Mercury Flows.  The EPA needs to support efforts to measure international flows of
 mercury. Characterizing the international flows are critical to assessing and addressing background
 mercury levels.  Like many other countries, there is currently neither mercury monitoring nor a
 mercury inventory in Mexico. At present, Mexico is building its  first large scale coal-fired utility
 plant. Mexican environmental officials have identified that they have three mercury cell chlor-alkali
 facilities. The Chlorine Institute and Eurochlor are working with their Mexican counterparts to raise
 their level of concern toward mercury issues as well as raise plant performance efficiencies. An
unintended consequence of a rapid closure of mercury cell chlor-alkali plants in the U.S., could be
a demand for more chlor-alkali plants in foreign countries  with fewer environmental controls.

 Virtual Elimination of Mercury Requires Private Sector Cooperation. Previous  discussions during
the workshop concluded that new regulations restricting mercury  use are not likely. Therefore, if
mercury is to be removed from the marketplace, government must work closely with the private
sector. The challenge is to create positive incentive programs that can encourage the private sector
to make business from phasing out mercury use; both in terms of developing alternative disposal
technologies and developing chemical substitutes (such as NewMerc).
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 Mercury as a Consumer Products Safety Issue.  Mercury can be thought of as a consumer products
 safety issue where it exists in small amounts, such as in thermometers and electronic displays. The
 most common calls to poison hotlines deal with broken mercury fever thermometers. Although,
 thermometers and electronic displays represent a small percentage of mercury emissions (especially
 when compared with utility coal emissions), they still present a risk. It is recommended that  the
 Consumer Products Safety Commission could be used to address the mercury safety issue.

 Educating the Public about Mercury Exposures. Although most of this workshop has focused on
 emissions rather than on exposures, educating the public on exposures is critical.  Over 90% of the
 calls to a poison control center in a certain state was attributed to broken fever thermometers.Yet,
 while most people may know that there is mercury in their thermometers, they may not be aware of
 the  mercury in  their thermostats or  cars. The public needs  to better understand through
 communication the risks of mercury in their everyday life.

' Categorization. A standard categorization scheme for mercury disposition and contamination starting
 with products and ending with  releases can help communicate risks and corrective  action.  The
 Northeast Model Legislation proposes the following categorization scheme:
     •   Product with elemental mercury
     •   Product with compounds and chemicals
     9   Processes
     •   Waste streams of the three above areas of deliberate use
     •   Non-combustion incidental releases, including refining, mining, and cement and limestone
         production

 Mercury-free Procurement/Buildings by Government. It is important for the government to become
 a model for a  mercury-free environment by setting an example for the public and industry.

 Mercury in Consumer Products.  The intentional use of mercury in consumer products should
 eventually be phased out, including mercury in lamps. A gatekeeper, such as EPA's hazardous waste
 listing determination, would provide some consistency in how regulations treat industry as well as
 the consumer. For example, there is no gatekeeper controlling the mercury found in Drano.
 Some states have regulations in place, but there is nothing enforced at the national level. Minnesota
 has a provision in its regulations that prohibit mercury disposal in its solid wastes and wastewaters,
 where solid wastes include construction and demolition non-hazardous industrial, etc.

 Data Gaps and Research Needs

 Division of Mercury Sources by Deliberate Use and Trace Contamination  of Raw Materials.
 Categorizing mercury sources by emissions resulting from mercury use and emissions resulting from
 contamination of raw materials may be more relevant than  categorizing by combustion and non-
 combustion for the following reasons:
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     •    Avoids the disparity of equating combustion emissions with  coal-fired utility emissions.
         As  currently defined by EPA, combustion sources include incinerators.  Incinerators,
         however, do not make mercury, but receive mercury from mercury-containing wastes as a
         result of mercury use in products;.
     •    Normalizes the division of mercury sources.  If emissions are categorized on a deliberate use
         basis, use-related emissions are about 50% of total emissions;, combustion basis, where
         combustion-related emissions constitute about 90% of total emissions.
     •    Better consideration of life cycle emissions. Since incinerator emissions represent the end
         of a product's life cycle, this type of assessment makes it easier to look at different points
         along a product's life'cycle to assess opportunities to control mercury emissions.

Life Cycle Emissions by Product Type.  There is an inadequate understanding of life cycle emissions
by product type. Further research may help prioritize mercury collection efforts and target programs
to critical sectors. There are some data on mercury emissions from mercury-containing products,
'however these estimates do not seem to be based on actual measurements. There are better data from
incinerators,  but these data could also be improved.  However, there is a paucity of data regarding
emissions estimates from other phases of the mercury product life cycle, in particular:

     •    Accidental emissions that occur during product use;
     •    Emissions associated with collecting, processing, storage, and transport of wastes prior to
         incineration;
     •    Emissions that occur from landfills, particularly the working faces of landfills;
     •    Mercury emissions from the use  of metal scrap.  For example, emissions from mercury
         switches placed in automobiles are currently not accounted for in EPA emissions estimates,
         though these emissions could be  significant.

Increase Focus on Prevention Opportunities.  Currently cost effectiveness data are based on cost
effectiveness per mass of mercury collected rather than on the prevention of mercury releases. More
emphasis should be place on the following areas for prevention efforts:

     •    Auto industry.  There should be  more research on this sector since most of the mercury
         associated with automobiles is ultimately released into the environment.
     •
     •    Electrical Switches. Alexis Cain cited data presented by Bruce Lawrence (Bethlehem
         Apparatus Company) in the plenary session indicating that electrical products, particularly
         mercury relays in capital equipment, are now the largest user of mercury in the U.S. (even
         more than the chlor-alkali industry); now estimated at 110 tons per year. Moreover, mercury
         use in electrical switches has not decreased over the past 20 years.

Mercury Retirement. As the secondary market grows and mercury use shrinks, an "end-game" for
mercury must be devised for retiring mercury. The EPA should work with the Department of Energy
(DOE) andDepartment of Defense (DOD) to develop mercury stabilization technologies. Ultimately,
all  of the mercury in commerce needs to be  treated, contained and/or sequestered in a final
disposition.
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                                     Section 4
                           Summary and Conclusions
The panel discussions provided a valuable forum for experts to summarize what they saw as the
important findings and future steps to reduce risks from mercury over the next several years.  As
discussed, the state of the science for treatment and disposal of mercury wastes has advanced
substantially. Research is now needed to refine the existing technologies and establish cost-effective
treatment strategies using the best available knowledge.  Efforts  to identify mercury pollution
prevention, collection, and elimination options will promote environmentally sound risk management
practices.
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                                   Appendix A
                              Workshop Agenda
Conference Agenda
DAY 1 - Wednesday, March 22,2000
Welcome and Opening Remarks - Douglas Grosse, US EPA/NRMRL
Plenary Session
Moderator: Jon Herrmann/Ben Blaney, US EPA/NRMRL
    ORD Research Strategy
    The Mercury Marketplace: Sources, Demand, Price and the Impacts of Environmental
Regulations - Bruce Lawrence, Bethlehem Apparatus, Inc.
    Waste Minimization and Elimination - Harold Charles, US EPA OSW
    EPA's Mercury Action Plan - Greg Susanke, US EPA OPPTS
    Disposal of Mercury Waste and Stockpiles - Josh Lewis, US EPA OSW
    Mixed Waste Issues - Greg Hulet, US DOE/BBWXT Co. and Grace Ordaz, US EPA
    International Perspective - John Diamante, OIA
    Mercury Information Management Issues - Jim Ekmann, DOE
    National Implementation of the Universal Waste Rule for Mercury Lamps (Industry
Perspective) - Paul Abernathy, Association of Lighting and Mercury Recyclers
    Regional Perspective - Jeri Weiss, US EPA Region 1
    State Perspective - John Gilkeson, Minnesota OEA
    Model State Legislation - Richard Phillips, Vermont DEC
    NGO Perspective - Jane Williams, California Communities Against Toxics
Concurrent Technical Sessions

Session A - Treatment and Disposal Technologies
Moderator - Josh Lewis, US EPA OSW
    Mercury Stock Management - Folke Dorgelo, Netherlands Ministry for Housing, Spatial
Planning and the Environment
    Subseabed Emplacement: Long-Term Ultimate Disposition of Mercury Wastes - Leo Gomez,
Sandia National Laboratories
    Case Study of a Polit Scale System for Removal of Organic Mercury from Pharmaceutical
Wastewater - Patrick Cyr, Advanced GeoServices Corp.
    SAMMS Technology - Nick Lombardo and Shas V. Mattigod, Pacific NW National
Laboratory
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Session B - Overall Reduction of Mercury: Phase out and Mercury Management of
Stockpiles
Moderator: Anita Cummings, US EPA
    Stockpile (DLA) - Giles LePage and Dale Wilhelm, DOD, DLA
    Mercury Collection Programs in Sweden - Kristina von Rein, Swedish Environmental
Protection Agency
    Mercury Stockpile Management - Luke Trip, Environment Canada, Implementation Task
Force
    Phase-out of Mercury Containing Products - Folke Dorgelo, Netherlands Ministry for
Housing, Spatial Planning and the Environment

DAY 2 - Thursday, March 23,2000
Session A - Treatment and Disposal Technologies: Treatment Technologies
Moderator: Mary Cunningham
    DOE Mercury Waste Treatment Demonstrations - Greg Hulet, US DOE/BBWXT Co.
    Return and Recycling of Used High Intensity Bulbs for Recycling and Closed-Loop Mercury
Control - Lester Gress and Jeff Lord, Cleveland Fluid Systems Co.
    Mercury Amalgamation Demos with the DOE - Clifton Brown, ADA Technologies, Inc.
    Deployment of the Sulfur Polymerization and Stabilization Process as Applied to Mercury
Contamination in Soils - Paul Kalb,  Brookhaven Natl. Laboratory and Trevor Jackson,
EnviroCare

Session B - Prevention, Collection  and Elimination: The Business Side of the Mercury
Problem
Moderator: Ed Weiler, US EPA
    Speed Bumps on the Road to Commercialization of New Environmental Technologies -
David Case, Environmental Technology Council  ,
    Commercializing a Safer Substitute for Mercury - James D. Rancourt, NewMerc Ltd.
    The Business of Mercury Pollution Prevention: Identifying Source Reduction Opportunities
and Engineering Trade-Offs - Kenneth Stone, US EPA/NRMRL
    A PBT Technology Information Clearinghouse (with special emphasis on information
relating to environmental technology development and commercialization) - Frederic H. K. Booth
and Kay can der Horts, Waste Policy Institute

Session A - Treatment and Disposal Technologies: Disposal Technologies
Moderator: Paul Randall, US EPA
    Mercury Stabilization in Chemically-Bonded Phosphate Ceramics - Dr. Arun Wagh, Argonne
National Laboratory
    Characterization and Leachability of Stabilized Mercury-Containing Wastes - Linda Reiser,
University of Cincinnati
    Treatment of Wastes Contaminated with Mercury - Paul Lear, IT Corp
    Treatment of Mercury Bearing Wastes with Thermal Desorption Technology - Dave
Mulkmus, Sepra Dyne Corporation
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 Session B - Impacts of Mercury Collection and Elimination Programs
 Moderator: Jeri Weiss, US EPA Region 1
     Mercury Sniffing Dogs: The Swedish Experience - Kjell Avergren, Sweden Dog Training
 Centre
     Mercury Source Reduction and Recycling in Electrical Products - Ric Erdheim, NEMA
     DSCP Buying Green - Anthony Armentani, Defense Supply Center Philadelphia
     EPA/AHA Agreement: Reduction of Mercury Waste from Hospitals/Health Care Facilities
 Chen Wen, EPA and Video Presentation, AHA

 Session A - Treatment and Disposal Technologies: Stabilization
 Moderator: Paul Randall, US EPA
     Permanent Mercury Disposal in Sweden - Kristina von Rein, Swedish Environmental
 Protection Agency
     Subseabed Emplacement: Long-Term Ultimate Disposal of Mercury Wastes in Geologic
'Formations on Land - Rip Anderson, Sandia National Laboratories

 Session B - Impacts of Mercury Collection and Elimination Programs (Continued)
 Moderator - Jeri Weiss, US EPA Region 1
     New Strategies for Reducing Mercury Discharges from Boston Area Medical Facilities -
 Kevin McManus, Massachusetts Water Resources Authority
     Eliminating Non-Essential Mercury Uses - Michael Bender, Mercury Policy Project

 Panel Discussion A - Treatment and Disposal
 Facilitator:    Ben Blaney, US EPA/NRMRL
 Panelists:      Paul Kalb, Brookhaven National Laboratory
        Paul Lear, IT Corp.
        Ed Swain, Minnesota OEA
        Greg Hulet, US DOE/BBWXT Co.
        Fred Charania, US EPA OSW

 Panel Discussion B - Prevention, Collection, and Elimination
 Facilitators:    Doug Grosse, US EPA, Office of Research and Development (ORD)
        Jon Herrmann, US EPA, ORD
 Panelists:      Alexis Cain, US EPA, Region V
        John Gilkeson, Minnesota OEA
        George Gissel, Vulcan Chemicals
        Edward Weiler, US EPA OPPT
        Jane Williams, California Communities Against Toxics
 Combined Workshop Session - Presentation of Concurrent Panel Findings
 Closing Remarks
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                       Appendix B Workshop Abstracts

Table of Contents

Abstracts

    The Mercury Marketplace: Sources, Demand, Price and the Impacts
        of Environmental Regulations 	 23
    Waste Minimization and Elimination 	 24
    EPA's Mercury Action Plan	 25
    Disposal of Mercury Waste and Stockpiles	 26
    Mixed Waste Issues  	 27
    International Perspective  	 28
    Mercury Information Management Issues  	 30
    National Implementation of the Universal Waste Rule for Mercury Lamps
        (Industry Perspective)	 31
    State Perspective	 33
    Model State Legislation	 34
    NGO Perspective 	 35
    Mercury Stock Management  	 37
    Sub-Seabed Emplacement: Long-Term Ultimate Disposition of Mercury Wastes	 38
    Case Study of a Pilot Scale System for Removal of Organic Mercury
        from Pharmaceutical Wastewater	 39
    SAMMS Technology	 40
    Mercury Collection Programs in Sweden	 41
    Phase-out of Mercury-Containing Products	 43
    Demonstration of Mercury Treatment Technologies to Meet DOE Customer Needs	 44
    Return and Recycling of Used High Intensity Bulbs for Recycling and
        Closed-loop Mercury Control	 46
    Mercury Amalgamation Demos with the DOE 	 47
    Deployment of the Sulfur Polymerization and Stabilization Process as Applied to
        Mercury Contamination in Soils	 48
    Commercializing a Safer Substitute for Mercury	 49
    The Business of Mercury Pollution Prevention: Identifying Source Reduction Opportunities
        and Engineering Trade-Offs	 50
    A PBT Technology Information Clearinghouse	 52
    Mercury Stabilization in Chemically Bonded Phosphate Ceramics	 55
    Characterization and Leachability of Stabilized Mercury-Containing Wastes  	 57
    Treatment of Wastes Contaminated with Mercury	:	 58

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Treatment of Mercury-Bearing Wastes with Thermal Desorption Technology	  59
Permanent Mercury Disposal in Sweden	  60
Sub-Seabed Emplacement: Long-Term Ultimate Disposal of Mercury Wastes in
    Geologic Formations on Land	  62
Mercury-Sniffing Dogs: The Swedish Experience	  63
Mercury Source Reduction and Recycling in Electrical Products	  64
DSCP Buying Green	  66
EPA/AHA Agreement: Reduction of Mercury Wastes from Hospitals/Health Care
    Facilities	  67
Mercury Content of Products Commonly Used by Boston Area Hospitals	  68
Eliminating Non-Essential Mercury Uses 	  69
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            The Mercury Marketplace: Sources, Demand, Price
               and the Impacts of Environmental Regulations

Bruce Lawrence
President
Bethlehem Apparatus Company, Inc., 890 Front Street
Hellertown, PA 18055
Phone: (610) 838-7034, Fax: (610) 838-6333
brucelawr@ aol. com

                                   Bruce Lawrence
Mr. Lawrence is the President of Bethlehem Apparatus Company, Inc., since 1980, and the principal
stock holder since 1992. Bethlehem Apparatus Company is the leading company supplying mercury
to the U.S. domestic market, as well as the leading mercury retort recycling operation. Mr. Lawrence
has been published in the Engineering and Mining Journal for several years in the annual mineral
section on the Mercury Market. He has also presented work to EPA on the retort distillation of
mercury, 1992.
                     The Mercury Marketplace: Sources, Demand,
                  Price and the Impacts of Environmental Regulations

Presentation will provide answers to the following questions. Where does the present market for
mercury get its supplies? How does recycling of mercury waste materials effect the market? What is
byproduct mercury and how does it interact with the more traditional supplies of mercury? Mercury
Mining; Who does it and is it still necessary for the supply to the mercury marketplace? Who still uses
mercury in products and services? How is mercury used in consumer products? How is mercury used
in non-consumer products? How much mercury is in use today? How much mercury is available for
the mercury marketplace? Who owns this mercury? Why are there stockpiles of mercury? What
changes have taken place in the past few years since efforts have been made to limit mercury use?
How much does mercury cost? Has this changed since the onset of environmental regulation? How
does price affect the supply and demand of mercury? Are there other effects of mercury pricing?
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                      Waste Minimization and Elimination

                                     Harold Charles
                           Waste Minimization and Elimination
                U.S. Environmental Protection Agency, Office of Solid Waste
                                    401 M Street, SW
                                 Washington, D.C. 20460
                         Phone: (703)308-8918, Fax: (703)308-8433
                                 charles. harold© epa. gov
                                     Harold Charles
 B.S. in Civil Engineering, University of DC, 1986
 M.S. in Waste and Environmental Management, University of MD, 1994
'Professional Engineering License with DC and MD, 1997

 1987 to 1994, Civil Engineer and Environmental Coordinator, DC Air National Guard at Andrews
 Air Force Base, 113th Civil Engineering Squadronl994 to 1995, Environmental Protection Specialist,
 Headquarters U.S. Army at the Pentagon, Environmental Programs Directorate, Pollution Prevention
 Division

 1995 to 1998, Civil Engineer and Environmental Officer,  Headquarters Federal Emergency
 Management Agency, Response and Recovery Directorate, Infrastructure Division, Engineering
 Branch

 1998 to Present, Environmental Engineer, Headquarters Environmental Protection Agency, Office
 of Solid Waste, Hazardous Waste Management and Minimization Division, Waste Minimization
 Branch
 Mercury is one of the PBT (persistent, bioaccumulative and toxic) chemicals that EPA has focused
 on over the years.

 An overview will be given of how mercury in products and production process is found in waste
 streams.  Subsequently national data of mercury bearing wastes and how they are managed (i.e.
 treated, recycled, and disposed of) will be highlighted.

 Current EPA initiatives  focusing on mercury in wastes will be discussed, including pollution
 prevention initiatives.

 EPA/OS W supports waste minimization to reduce mercury in wastes and when not feasible, effective
 treatment or more Land Disposal Restriction (LDR).
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                            EPA's Mercury Action Plan

                                      Greg Susanke
        U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics
                                    401 M Street, SW
                                  Washington, DC 20460
                                   Phone: (202)260-3547
                                  susanke. sree @eva. sov
                                      Greg Susanke
 Greg Susanke is a biologist, and the manager of EPA's Office of Pollution Prevention and Toxics'
 Mercury Program. He is currently leading a multi-Office workgroup effort in developing a Mercury
 Action Plan for the Agency. Greg is also serving as a U.S. representative on the Commission for
'Environmental Cooperation's Mercury Task Force where he has helped implement Phase I of the
 North American Regional Action Plan on  Mercury, and has assisted in the drafting of its second
 phase.
                        EPA's Mercury Action Plan: An Overview

 Among the many pollutants that  EPA addresses, persistent, bioaccumaltive and toxic (PBT)
 substances are pollutants of primary concern. It has traditionally addressed these and other pollutants
 among its single-media offices. However, many pollutants, especially PBTs, can not be  fully
 addressed in this manner because of their cross-media nature. Accordingly, the EPA is committing,
 through the development of a PBT Strategy, to create an enduring cross-office system that will
 address the cross-media issues associated with priority PBT pollutants. The PBT Strategy, which is
 currently being drafted, will integrate the work being done across media offices and between national
 and regional programs more  thoroughly. It will align domestic and international activities more
 effectively, involve stakeholders, and use measurable objectives and assess performance. This strategy
 is intended to make the whole of the Agency's efforts on PBT pollutants more than a sum of its parts.

 A central element to EPA's PBT Strategy is the development and implementation of national action^
 plans for priority PBT pollutants. Mercury has been selected as one of the first PBT substances to be
 addressed under this strategy. The Agency is currently in the process of drafting a Mercury Action
 Plan. Although the PBT Strategy will not be discussed in the presentation, an understanding of its
 principles, as previously mentioned, frame the context of the action plans.

 The presentation will briefly discuss use, release, and risk reduction goals for mercury, as well as the
 tools to be used to measure progress in achieving these goals. A  listing of the numerous source
 categories/sectors to be addressed will be presented, but the focus of the presentation will be on
 describing the priority areas of future action. Mention of these priorities at the time of writing this
 abstract is not possible, as they are currently being developed.
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                  Disposal of Mercury Waste and Stockpiles

                                       Josh Lewis
                       United States Environmental Protection Agency
                              Office of Solid Waste (5302 W)
                                    401 M Street, SW
                                 Washington, D.C. 20460
                        Phone: (703) 308-7877, Fax: (703) 308-8433
                                lewis, josh @ evamail. eva.gov
                                       Josh Lewis
 Josh Lewis in an Environmental Engineer in the Waste Treatment Branch of EPA's Office of Solid
 Waste. He graduated from Cornell University with a B.S. in Environmental Engineering. Josh has
' worked at EPA for two years, during which time one of his main projects has been the reevaluation
 of the Land Disposal Restriction treatment standards for mercury-bearing wastes.

                   Treatment and Disposal of Mercury Hazardous Waste

 The original Land Disposal Restriction (LDR) treatment standards for mercury-bearing wastes were
 promulgated in 1990. These standards, which are still in place, require high mercury subcategory
 wastes (i.e., wastes that contain greater than or equal to 260 ppm total mercury) to be roasted or
 retorted to recover the mercury or, if organics are present, the wastes can also be incinerated. Low-
 mercury subcategory wastes (i.e., wastes that contain less than 260 ppm total mercury) have to meet
 a numerical treatment standard based on the toxicity characteristic leaching procedure (TCLP). Since
 1990, many issues have arisen with the mercury treatment standards, including whether the original
 premise of incineration as a pretreatment step to mercury recovery is still  true; whether there are
 options for treating high-mercury wastes that are not amenable to retorting;  and, since mercury use
 in industry is on the decline, whether we should still require mercury recovery for high subcategory
 wastes, or instead allow treaters the option of stabilizing these wastes. Because of these and other
 issues, EPA has begun a reevaluation of the LDR mercury treatment standards. The first step in this
 reevaluation was the publication of an Advance Notice of Proposed Rulemaking (ANPRM) on May
 28, 1999, which described the issues we have with the current mercury treatment standards and
 discussed some potential options for amending the standards. We are now evaluating the comments
 that we received on this ANPRM. In addition, we are involved in two treatability studies that are
 researching the efficacy of emerging mercury treatment technologies. The end result of our current
 mercury work will be the publication of a proposed rule on changes to the LDR mercury treatment
 standards in late 2000.
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                                Mixed Waste Issues
                Grace Ordaz
             Chemical Engineer
     U.S. Environmental Protection Agency
            Office of Solid Waste
       401 M Street, SW (MC 5304W)
           Washington, DC 20460
  Phone: (703) 308-1130, Fax: (703) 605-0744
           Ordaz. Grace @eva. eov
               Greg Hulet
         Mixed Waste Focus Area
           Bechtel BWXT, LLC
Idaho National Engineering and Environmental
               Laboratory
         P.O. Box 1625 MS 3875
        Idaho Falls, ID 83415-3875
Phone: (208) 526-0283, Fax:  (208)526-1061
             Hae@inel.sov
                                     Grace Ordaz
 Ms. Ordaz has been working on EPA mixed waste proposal for the past two years. Ms. Ordaz has
 also worked at US DOE Office of Environmental Management, Office of Research and
 Development on mixed waste technology development, and at the MD Department of
 Environment administering the State Biomonitoring Program under CWA's municipal NPDES
 permit program. Ms. Ordaz also has experience with the AA county pretreatment program under
 the CWA, and process design of petroleum plants.

                                      Greg Hulet
 Mr. Hulet is the work package manager for the Unique Waste Work Package, which includes DOE's
 mercury mixed wastes. As such, he coordinates research, development, and technology deployment
 activities to ensure that all the wastes in the Unique category have a path for treatment and disposal.
 He has a Masters Degree in Chemical Engineering and ten years experience in waste management and
 pollution prevention. He also has considerable experience with Naval Nuclear Propulsion Plants. He
 has been a scoutmaster for 15 years, which, after watching scouts cook for that long, has made him
 an expert in unique hazardous wastes.
 EPA Proposed Rule for Storage, Treatment, Transportation, and Disposal of Mixed Waste

Conservation and Recovery Act  (RCRA) to provide  a conditional  exemption from certain
requirements for eligible mixed waste. EPA is requesting public comments on this proposed action.

Mixed waste is a radioactive RCRA hazardous waste. It is regulated under two authorities: 1) the
Resource Conservation and Recovery Act (RCRA), as implemented by EPA or authorized states for
the hazardous waste component; and 2) the Atomic Energy Act of 1954, as amended (AEA), for the
radiological component as implemented by either the Department of Energy (DOE), or the Nuclear
Regulatory Commission (NRC) or its Agreement States.
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The focus of this proposal is to provide flexibility under RCRA Subtitle C to generators of eligible
mixed waste. We are proposing a conditional exemption from the definition of hazardous waste
applicable to: low-level mixed waste (LLMW) for storage; and LLMW or Naturally Occurring and/or
Accelerator-produced Radioactive Material (NARM) for transportation and disposal. The proposal
is expected to reduce dual regulation for generators in the management and disposal of their wastes.
This flexibility will enable generators of LLMW who  are licensed by  the Nuclear Regulatory
Commission (NRC) to claim an exemption for storing and treating these wastes in tanks or containers
(using solidification, neutralization, or other stabilization processes) without a RCRA permit. This
proposal will also provide flexibility for the manifesting, transportation and disposal of eligible mixed
waste. Waste meeting the proposed conditions will be exempted from certain RCRA Subtitle C
hazardous waste requirements and managed as radioactive waste in accordance with NRC regulations.
                             International Perspective
              John Diamante
  U.S. EPA, Office of International Activities
             401 M Street, SW
           Washington, DC 20460
  Phone: (202)564-6608, Fax: (315)475-9351
           vdemarchi @ secor.com
            Marilyn E. Engle
U.S. EPA, Office of International Activities
            401 M Street, SW
         Washington, DC 20460
Phone: (202)564-6472, Fax: (202)565-2409
         engle.marilvn@epa.gov
                                    John M. Diamante
John M. Diamante is the Senior Science Advisor for the EPA Office of International Activities,
reporting to the Assistant Administrator and Deputy. His responsibilities are to provide advice,
review and oversight on technical and scientific matters and related policy issues concerning the
programs and activities of the  Office.  He is actively engaged in interagency and international
cooperative projects concerned with radioactive waste management problems in Northwest Russia.
He received his doctorate from New York University based on research in planetary atmospheres
conducted at the NASA Goddard Institute for Space Studies in New  York.  Subsequently, he was
employed at several aerospace companies, including TRW Systems and EGandG, and then went on
to federal employment with the National Oceanic and Atmospheric Administration (NOAA). At
NOAA, he served as a scientific and technical advisor in the National Ocean Service, Oceanic and
Atmospheric Research Office and Climate Change Program Office.

                                     Marilyn E. Engle
Marilyn E. Engle is an International Affairs Specialist in the EPA Office of International Activities.
She presently is the Agency lead on international transboundary transport aspects of mercury, and has
served as lead on international marine and coastal issues, where she  initiated Agency activities to
shape a Land-Based Sources of Pollution (LBS) Protocol for the Wider Caribbean. She received her
BA in Zoology and  Anthropology from Duke University and her Master's Degree from George
Washington  University. Her experiences include being a Senior Research Technician at Duke

                                            28

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University Medical Center working conducting research on non-ionizing radiation sublethal effects.
After joining EPA, she was an Environmental Scientist for the Office of Radiation Programs and
supported the regulatory program on ocean disposal of low-level radioactive waste before taking her
present position in the Office of International Activities. She also co-managed the Arctic Nuclear
Waste Assessment Program (ANWAP) while on a recent detail from EPA to the Department of
Defense Office of Naval Research, where she focused on preparing a human and ecological risk
assessment of the potential for transport from Russia to the U.S. State of Alaska of Russian nuclear
wastes dumped into or entering the Arctic Ocean.
    Long-Range Transboundary Transport of Mercury: International Dimensions of the
              Mercury Problem and Opportunities for Cooperative Solutions

       We are becoming increasingly  aware that we must  address mercury, a persistent and
bioaccumulative toxic, at local, regional and global scales. In addition to the problem of long-range
transport from combustion sources of mercury, such as coal burning, the EPA Office of International
Activities (OLA) also sees a need to focus on the long-range transport from non-combustion sources,
such as the chlor-alkali industry and mercury in waste streams.

       There is growing evidence that the U.S. is being impacted by many atmospherically borne,
globally circulating persistent toxics, such as persistent  organic pollutants (POPs), and other
atmospheric contaminants, including ozone and particulates. There is reason to believe that mercury
is  similarly being transported to the U.S. from abroad, and that U.S. sources are contributing to the
global pool of mercury that is being circulated worldwide. EPA estimates that about one-third of U.S.
anthropogenic mercury emissions are deposited in the contiguous U.S.,  while the remaining two-
thirds is transported outside the U.S. and enters the global pool. Correspondingly, estimates suggest
that about 35  tons, or 40% of the mercury that is deposited in the U.S. per year, may originate from
sources external to the U.S. With the rapid industrialization and increasing use of coal in Asia, and
re-industrialization in Russia, this trend is expected to increase.  Rapid industrialization will also
increase the burden arising from the non-combustion sources.

       The mission of OLA regarding mercury is multifold: 1) to improve  understanding of
international sources of mercury, and the regional and global-scale transport processes; 2) to influence
international awareness and actions through international fora; 3) to provide international training and
technology transfer in selected countries to bring about reductions in mercury use and emissions; and
4) to facilitate data and information management. Our emphasis to date has been on improving
scientific understanding of long-range transport, and on partnering with other countries in cooperative
solutions, and through regional fora to collectively influence actions in other countries. Currently,
OLA,  in cooperation with other EPA Offices, other  federal agencies and other governments, is
supporting activities such as speciated mercury monitoring and modeling efforts in Barrow, Alaska
and in the Ohio River Valley and the Florida Everglades to evaluate international contributions of
mercury to U.S. deposition. EPA is also actively engaged in mercury issues and regional action plans
under numerous regional agreements, including the U.S.-Canada Binational Toxics Strategy, the
North American Commission on Environmental Cooperation (CEC) involving the U.S., Canada and
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Mexico, the UNECE Convention on Long-Range Transboundary Air Pollution (LRTAP) Heavy
Metals Protocol, and the activities of the Arctic Council, which includes the Arctic Monitoring and
Assessment Program (AMAP).

       In addition to improving scientific knowledge of transport and fate of mercury sources, we
are working through international fora to find opportunities for international cooperative approaches
to further: 1) source identification and characterization, particularly with the chlor-alkali sector; 2)
pollution prevention,  such as taking mercury out of products; 3) environmental capacity building;
4) environmentally sound trade and free market decisions regarding mercury, and 5) informed
international policy making concerning mercury.
                  Mercury Information  Management Issues

                                     James Ekmann
                      Office of Systems and Environmental Analysis,
                         National Energy Technology Laboratory,
                               U.S. Department of Energy
                                 Phone: (412)386-5716
                                 ekmann@netl.doe.gov
                                     James Ekmann
Mr. Ekmann serves as the Deputy Associate Director in the Office of Systems and Environmental
Analysis. This office is part of the National Energy Technology Laboratory of the U.S. Department
of Energy. OSEA assesses the technical, environmental, and cost performance  of technologies
developed at or under funding from NETL. Staff in the office conduct environmental assessments,
detailed engineering reviews in support of RDandD projects. The office also provides a focal point
for the laboratory's external communication including technology transfer, and preparation of
materials summarizing technical successes.
                 Information Tools for Mitigation Strategy Development

The need to link technology costs and a comprehensive risk assessment methodology in the context
of addressing major environmental contaminants, e.g., mercury and other persistent bioaccumulative
toxics (PBTs) has been discussed by a number of authors. Assessments of policy  options rely
increasingly on multiple tiers of modeling studies informed by large volumes of data. This tendency
raises the need to manage the use of models and the data needed to ensure analytical results that are
consistent and of sufficient quality. The NETL has been examining the connection between data, and
concepts such as information, knowledge, and wisdom as these relate to the role of advanced fossil
fuel technologies in a carbon managed future. We plan to develop a decision support model that

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would be an information portal to both process-level data and information and to system-level
analyses.  We believe that this linkage will lead to knowledgeable choices  about  mitigation
technologies and has the potential to clearly communicate results facilitating formulation of wise
policy options. We believe that this endeavor offers useful insights to similar information needs and
structures for other issues such as mercury/PBTs. This paper discusses both the approach being used
to design the decision support system and the linkages between scientific and technical data and
information on societal values that are essential to making such a concept useful.
    National Implementation of the Universal Waste Rule for Mercury
                          Lamps (Industry Perspective)

                                   Paul W. Abernathy
                                   Executive Director
                       Association of Lighting and Mercury Recyclers
                               2436 Foothill Blvd. Suite K
                                  Calistoga, CA 94515
                        Phone: (707) 942-2197, Fax: (707) 942-2198
                                  abernath @ napanet.net
                                   Paul W. Abernathy
Paul W. Abernathy is the Executive Director of the Association of Lighting and Mercury Recyclers,
a national non-profit organization representing members of the mercury recycling industry. Mr.
Abernathy has worked for over 25 years in the environmental services industry throughout North
America, representing public and private companies and clients. His background includes extensive
participation in public policy development and implementation for water quality, air and hazardous
substances management. Mr. Abernathy has had experience working with NATO on international
exchange of environmental management programs and technologies; was appointed by a California
governor to serve on the multi-disciplined State Hazardous Waste Facility "Siting" committee; and
presently serves as technical advisor to regional governments in Northern California on hazardous
waste management  planning,  siting and development issues, water and energy  conservation,
regulatory and environmental compliance, pollution prevention and resource recovery. Paul serves
as member of Northern California Green Business Advisory Board.

Mr. Abernathy earned a M.B. A. from Pepperdine University and a B.S. in Biology/Chemistry from
the University of Arizona.
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         National Implementation of the Universal Waste Rule for Mercury Lamps

 This presentation includes a brief history of mercury lamp recycling and disposal in the U.S., the
 public policies that have influenced lamp disposal, highlights of states' programs regulating lamps,
 and it discusses the latest changes to the Universal Waste Rule effective 1/6/00. EPA's goal is to
 divert mercury lamps from municipal wastes, and the Association of Lighting and Mercury Recyclers
 is part of a public-private partnership that is forming to work with business and all state and local
 governments in the U.S. for implementation of the new rule. This presentation discusses local
 government roles  and options, business and generator options and the educational and resource
 information being developed.

 Spent mercury lamps are considered hazardous waste, but for the most part they have not been
 managed this way. EPA believes the major reason for the wholesale non-compliance is the lack of
 awareness and access to information on the  part of lamp owners and local governments, which
' includes nearly everyone. The national recycling rate has been about 12%, which means there are still
 500,000,000 mercury lamps disposed in the garbage, potentially exposing people and the environment
 to mercury. RCRA has always required the proper  management of mercury lamps as hazardous
 wastes, but with few exceptions (MN, FL) there has been little or no enforcement by regulatory
 agencies. EPA adopted the UWR to include lamps on 7/6/99. (PR July 6,1999, Volume 64 Number
 128, pp. 36465-36490, and 40 CFR 273), effective  1/6/00. The goal of the rule is to increase the
 recycling rate to 80% and remove regulatory and cost burdens for those who recycle. States may take
 several possible actions to achieve consistency with RCRA. States may have more stringent policies,
 but  the minimum regulatory criteria must  not allow the land disposal of mercury-lamps. Local
 governments have a responsibility too, through their franchises for solid wastes, HHW programs,
 SQG programs, pollution prevention programs, landfill operations.

 Our recycling association has formed a partnership with Earth's 911,  and along with EPA and
 corporate partners is helping provide information and resources to the states, and working with local
 governments to  adopt and implement programs that encourage recycling and set up a sufficient
 infrastructure to divert mercury lamps from municipal wastes altogether by making recycling easy,
 inexpensive and available to business and the public.

 The new UWR makes it easier than before and less costly to manage lamps properly. Where RCRA
 has not been enforced and the compliance rates are low, non-compliant disposal has cost  little to
 generators. Proper lamp management under the UWR represents a small percentage of total lighting
 costs, and it keeps mercury from being released into the environment. To achieve compliance it is
 incumbent on states and local government agencies,  working with both public and private entities,
 to ease the burden on generators by making collection and recycling programs for mercury lamps
 readily  available.  By sharing information,  conducting  public-private seminars and workshops
 throughout the country, offering Earth's 911  resource guide, website and toll-free number we are
 helping educate people about their responsibility. The national goal is to recycle as many mercury
 lamps as possible.
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                                  State Perspective

                                       John Gilkeson
                                     Principal Planner
                        Minnesota Office of Environmental Assistance
                                    520 Lafayette Rd. N.
                                 St. Paul, MN 55155-4100
                         Phone: (651) 215-0199, Fax: (651) 215-0246
                              John, gilkeson @ moea. state, mn. us
                                       John Gilkeson
 John Gilkeson has worked for the state of Minnesota for 10 years and is currently a principal planner
 with the Office of Environmental Assistance. During that time John has worked on "problem and
' special wastes," including medical and infectious waste, household hazardous waste, batteries, lead,
 electronics, and mercury wastes. John's  focus for the past four years has been on  the use and
 management of mercury in products. John has worked on the Minnesota universal waste rule, the
 federal mercury lamp rule, the federal mercury stockpile issue, and represents  Minnesota on the
 Binational Toxics Reduction Strategy Mercury Work Group. John has also worked with several
 industries  and sectors that use, manage, or release mercury, including oil refineries, thermostat
 manufacturers, relay manufacturers, automobile  manufacturers, the state  dental  association,
 demolition contractors, and several mercury recyclers.
                               Minnesota State Perspective

 Minnesota and other states are taking a variety of approaches to understanding, reducing, and
 managing mercury that is released from a variety of human activities.  Though states have differing
 needs and resources, and must take different approaches, they also have much in common and would
 benefit from more coordination in laws, rules, programs, and research. Similarly, on a national and
 international basis, our common interests would benefit from a more coordinated approach to
 research, programs, and policy. Other public and private sector interests are key players in these
 processes and have a strong interest in consistent  and equitable measures to address mercury
 nationally and internationally.

 In this presentation, Minnesota state agency staff will present their perspective on impediments to and
 opportunities for advancing local to international mercury reduction efforts in the areas of:
    Environmental research and monitoring;
    Laws and regulations;
    Policies and programs;
    Education;
    Incentives and other measures for voluntary action, including national early reduction credit;
    Coordination among governments, businesses, and NGOs;
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   Research and measures for reducing and managing mercury in purposeful use (and waste
   management);
   Research and measures for reducing emissions from energy and resource sectors;
   Research and measures for reducing emissions from other unintentional use or material reuse;
   Management and disposition of stockpiles and reserves;
   Retirement of mercury removed from commerce; and
   Developing and promoting non-mercury products and processes.

The presentation will include an overview of recommendations from the Minnesota Comprehensive
Mercury Reduction Initiative (March 1999) and International Policy Recommendations developed
by attendees of the 5th International Mercury Conference in Rio de Janeiro (May 1999).
                             Model State Legislation

                                    Richard Phillips
                    Virginia Department of Environmental Conservation
                                  103 South Main Street
                                  Waterbury,VT 05671
                        Phone: (802)241-3470, Fax: (802)241-3273
                                 rich @ dec, anr. state, vt. us
                                    Richard Phillips
Richard Phillips spent two years designing and overseeing construction of water systems on the
Navajo reservation. For the last 30 years he has supervised and managed programs for the Vermont
Department of Environmental Conservation. Mr. Phillips managed the construction grant program,
the wastewater operation oversight program, the enforcement program and the P2/Assistance
programs. He has been responsible for the implementation of Vermont's mercury products labeling
and disposal ban law passed in 1998. He  has been involved with the development of the regional
model mercury products legislation.

Mr. Phillips has a Bachelor and Master's degree from Northeastern University.
                    Model State Legislation (Northeast States Model)

This presentation is based on efforts of the Northeast States to develop model state legislation.
This presentation will describe:

1.     The basis for creating model mercury product legislation as recommended in the Regional
       Mercury Action Plan.
2.     The process used to develop the model legislation.
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       The high points of the current draft model legislation which includes the following
       sections:
       Legislative Findings
       Definitions
       Interstate Cleaning house
       Notifications
       Phase-out and Exceptions
       Labeling
       Disposal Ban and Scrap Facilities
       Collection
       Sales Restrictions
       Disclosure
       Limitations on Use
Public Outreach and Education
Universal Waste
       State Procurement
Enforcement
       State Review
       Severability Clause
       Effective Date
Administrative Fees
       Appropriation
Public Notification and Review
Prohibition
4.     The remaining steps to adoption as a regional model.

5.     The status of state-by-state legislative initiatives.
                                  NGO Perspective

                                      Jane Williams
                                   Executive Director
                          California Communities Against Toxics
                                      P.O. Box 845
                                  Rosamond, CA 93560
                       Phone: (661) 273-3098, FAX: (661) 947-9793
                                   Danloan @ aol.com
                                      Jane Williams
Ms. Jane Williams serves as the executive director of California Communities Against Toxics, a
coalition of 80 community based environmental groups in California. She has a degree in economics
from  the University of California, Los Angeles and has eight  years  experience  working on
environmental issues with a focus on persistent, bioaccumulative toxins, Superfund sites, incineration,
and nuclear issues.

She has worked extensively with community-based environmental/public health advocacy groups and
Native American tribes on numerous pollution-related issues. Ms. Williams has also worked in
Mexico on environmental issues with the Secretaria de Relaciones Exterior, the Institute Nacional
de Ecologia, Commision Nacional del Agua, and with non-governmental organizations in Mexico.
She has presented papers at three different conferences in Mexico dealing with pollution and water
policy issues.
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 She is also the Chair of the Waste Committee for the National Sierra Club. This committee has
 responsibility over many of the Club's pollution related issues including Toxic and Nuclear Waste,
 Superfund, Brownfields, Nuclear and Chemical Weapons,  Solid and Medical  Waste,  Federal
 Facilities, and Environmental Justice issues related to waste.

 Ms. Williams serves on the board of the California Environmental Research Group, the Clean Air
 Network, Greenaction, the California Stop  Dioxin Exposure Campaign, the Del  Amo Action
 Committee, and the Nonstockpile Chemical Weapons Forum.  She is a past member of the Federal
 Advisory Committee on the Industrial Combustion Coordinated Rulemaking and a former member
 of the Regulatory Structure Update Technical Advisory Committee on Superfund for the State of
 California Department of Toxic Substance Control.
                                    NGO Perspective

The United States and Canada agreed to the virtual elimination of persistent toxic substances into the
Great Lakes under Article E of the Great Lakes Water Quality Agreement signed November 18,1987.
The current Mercury Action Plan does not serve as an integrated blueprint for actions that will
achieve the elimination of mercury emissions into the environment. Forty states now have fish
consumption advisories for mercury in fresh water fish due to the continued release of mercury into
the air and water.  Non-governmental organizations have become concerned about the lack of
"linkage" between current EPA policy on mercury and the virtual elimination goal. They have set
forth a series  of recommendations which they believe would lead to the attainment of this goal,
including steps that the EPA should take both in the short term and the long term. This paper will
present these recommendations along with the rationale for their adoption.
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                           Mercury Stock Management

                                      Folke Dorgelo
                                  Internal postal code 655
                      Directorate-General for Environmental Protection
                  Ministry of Housing, Spatial Planning and the Environment
                                     P.O. Box 30 945
                                  2500 GX THE HAGUE
                                     The Netherlands,
                      Phone: + 31 70 339 4908, Fax: + 31 70 339 1297
                          Folke.Dorselo@DSVS.DGM.minvrom.nl
                                      Folke Dorgelo
'Mr. Dorgelo's role at the Ministry of Housing, Spatial Planning, and the Environment encompasses
heavy metals policy, negotiations with the metal industry in The Netherlands — especially concerning
the reduction of corrosion and run-off of copper, zinc and lead used for construction and building;
recycling  of plastics and packaging  (waste) containing heavy metals;  risk evaluation and risk
management of metals (lead, mercury, cadmium, copper, zinc, chromium, nickel, bismuth, tin) and
PNAs; and chemicals risk reduction programme of the OECD, Environmental Health and Safety Divisi-
on (lead, mercury and cadmium). Mr. Dorgelo also participates in the European Commission DG
Enterprise working group (chemicals, plastics and rubber) on the 'limitations on marketing and use of
dangerous substances and preparations' (Directive 76/769/EEC).

Mr. Dorgelo earned his M.S. in Biochemistry (1974) from the State University of Leiden, has a
Teaching  Degree in Chemistry and is a registered toxicologist (Dutch Society for Toxicology).
PARCOM Decision 90/3 (1990) aims at the phase-out of the mercury cell process in the chlor-alkali
industry in Europe by 2010. About 12,000 tons of mercury in Europe are now in use in this process.
It is expected that these mercury stocks from the chlor-alkali industry, when becoming available due
to phase-out of the mercury cell process, will end up in worldwide uncontrollable applications with
diffuse emissions to air, water and soil. This concern for global transportation, application and
emission of mercury is the main reason for the Netherlands to start a project to achieve commitments
with industry for an environmentally proper and sustainable handling, transportation and disposal of
the mercury stocks.
                               Mercury Stock Management

Mercury mining in Spain produces about 1,000 tons of mercury per year, mainly for export. No
European policy dealing with the primary and secondary flows of mercury exists up to now.

The presentation will focus on the flow of mercury in the Netherlands, including recycling of
mercury-containing waste to technical grade mercury. Experiences with two chlor-alkali production
plants in the Netherlands phasing out their mercury cell process will be presented.

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The actual situation of the mercury stocks in Europe will be presented with some preliminary policy
options.
      Sub-Seabed Emplacement: Long-Term Ultimate Disposition of
                                  Mercury Wastes

                                  Leo S. Gomez, Ph.D.
                               Sandia National Laboratories
                                P.O. Box 5800, MS-0779
                                Albuquerque, NM 87185
                        Phone: (505)284-3959, Fax: (505)844-2348
                                   lssomez@sandia.sov
                                  Leo S. Gomez, Ph.D.
Dr. Gomez has worked in nuclear waste management at Sandia National Laboratories in Albuquerque,
New Mexico since 1977. He has been the biological research project manager for four ocean disposal
projects and works in the Performance Assessment Department for the Waste Isolation Pilot Plant, a
transuranic waste repository in southeastern New Mexico. Before going to Sandia, Dr. Gomez worked on
a cancer therapy project at Los Alamos National Laboratory in New Mexico, and worked on a project to
detect low levels of transuranic elements in workers at Oak Ridge National Laboratory in Tennessee.

Dr. Gomez has served as a U.S. representative on three international ocean pollution commissions. He is
also  an editor of the multinational journal, Radioactive  Waste  Management and Environmental
Restoration. In addition to his work in nuclear waste management, Dr. Gomez has worked with the
Institute of Public Policy at the University of New Mexico investigating the public's perceptions of risk
of nuclear technologies. He has also been involved with Sandia's educational outreach activities from
kindergarten through the college level.

Leo Gomez earned a Ph.D. in Radiation Biology at Colorado State University in 1973.
          Emplacement of Mercury Wastes in the Sediments of the Deep-Ocean?

The primary goal of the U.S. Subseabed Disposal Project (SDP) was to assess the technical and
environmental feasibility of disposing of high-level nuclear wastes in deep-sea sediments. Subseabed
disposal, like other geological disposal options, was a multibarrier concept that studied the feasibility
of burial of solidified and packaged high-level nuclear waste or spent nuclear fuel in high-integrity
canisters, tens of meters within the stable geologic formations of the deep-ocean floor. These deep-
ocean floor geologic formations are some of the most  stable  and predictable on earth.  In the
subseabed concept the multiple barriers of the waste form, the canister, the clay sediments, and the
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ocean waters were predicted to delay migration of radionuclides until they decayed to innocuous
levels.

The SDP was comprised of the following task groups: Site Assessment, Engineering Studies, Near
Field, Sediment Barrier, Physical Oceanography, Biological Oceanography, Radiological Assessment,
and Legal and Institutional. The SDP research team developed biosphere transport models to predict
the oceanic transport of radionuclides.  Researchers also developed the capability to determine and
evaluate the risks associated both with normal disposal operations and with potential accidents. Safety
assessments contributed to evaluation of the feasibility of the subseabed concept and helped focus
required work to answer the feasibility questions. Even though the SDP models were developed to
predict the transport of radionuclides, they can be used to predict the biosphere transport of non-
radioactive environmental pollutants, such as mercury products and other toxic metals. Many of these
pollutants cannot be destroyed or broken down through treatment or environmental degradation, and
through physical, chemical, or biological processes will ultimately be deposited in the oceans.
  Case Study of a Pilot Scale System for Removal of Organic Mercury
                       from  Pharmaceutical Wastewater

                                     Patrick J. Cyr
                              Advanced Geoservices Corp.
                              Chadds Ford Business Campus
                       Routes 202 and 1, Bradywine One, Suite 202
                                 Chadds Ford, PA 19317
                        Phone: (888)824-3992, Fax: (610)558-2620

                                      Funded by:
                          Wyeth Ayerst Pharmaceutical Company and the
               Institute for Environmental Engineering Research, Villanova University
                                        Patrick J. Cyr
       Mr. Cyr has worked in the environmental industry since 1995, practicing environmental, civil,
and geotechnical engineering. He has served as project/resident engineer for landfill construction
projects and remediation of wetlands. His experience in the environmental field includes removal of
contaminants from wastewater, compiling and evaluating data from contaminated sites, civil design,
and management of a water quality database. He has conducted lab testing of samples in an
environmental and geotechnical laboratory. He also has experience in design, construction, and testing
of pilot plants.

       Mr. Cyr  earned his  Masters  degree in Civil/Environmental  Engineering (1999) from
Villanova University, and his B achelor of Science degree in Civil Engineering (1996) from Worcester
Polytechnic Institute.
                                          39

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                Case Study of a Pilot Scale System for Removal of Organic Mercury
                                from Pharmaceutical Wastewater

 Mercury discharged to the environment puts the public health and the environment at risk for toxic
 effects. Organic mercury as thimerosal (a benzene mercury sodium salt: C9H9HgO2SNa) is used as
 an antiseptic and preservative in topical medicines, cosmetics, and vaccines. Hospitals use thimerosal
 for standard lab tests, such as albumin, herpes, hepatitis, and HTV, etc. Thimerosal and trace amounts
 of Kg2* are present in wastewater from the manufacture of certain pharmaceutical drugs and quality
 analysis/control procedures. The scope of this study was to examine the technical feasibility of using
 adsorption technology for removing thimerosal and inorganic mercury from a pharmaceutical
 wastewater. Several adsorbents were selected based on their physical and chemical properties and
 their adsorption affinity for mercury. Batch isotherm and column studies were conducted to determine
 the most suitable adsorbent for removal of mercury. Results showed that F-400 GAG provided the
 best results for the removal of thimerosal and Hg2+. A pilot plant was designed, constructed, and
' tested successfully for treatment of wastewater from a pharmaceutical manufacturing facility.
                                SAM MS Technology
       Nick Lombardo
       Pacific NW National Laboratory
       PO Box 999
       Richland, WA 99352
       Phone: (509)375-3644
       ni. lombardo @ pnl. sov
Shas V. Mattigod
Pacific Northwest National Laboratory
PO Box 999
Richland, WA 99352
Phone: (509)376-4311, Fax:  (509)376-5368
shas. mattisold@vnl. sov
             Self-Assembled Monolayers on Mesoporous Materials (SAMMS):
              A Novel Adsorbent for Mercury Removal from Waste Streams

A new class of hybrid mesoporous materials has been developed at the Pacific Northwest National
Laboratory for removing toxic heavy metals such as mercury from aqueous and nonaqueous waste
streams. The basis of these novel adsorbent  materials are organized monolayers of functional
molecules covalently bound to a siliceous mesoporous support.  The mesoporous supports are
synthesized using surfactant liquid crystalline templates. The resulting mesoporous materials have
high surface areas and ordered porosity in the nanometer size range. Functional molecules capable
of selectively binding of mercury (thiol groups) are covalently attached to the mesoporous substrates
as densely populated monolayers. Mercury adsorption data obtained over an eight order range
equilibrium concentrations indicated that thiol-SAMMS can achieve Hg loading as high as -635
mg/g. The high affinity for Hg adsorption by this material was reflected by Kd values as high as IxlO8
ml/g. The data also showed that mercury adsorption by thiol-SAMMS was not affected by the initial
                                           40

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form of Hg (nitrate, chloride, and methylated) in solution. A study of mercury adsorption kinetics
indicated that thiol-SAMMS bound Hg rapidly (about 99.9% adsorption occurring within first five
minutes). Tests showed that neither the pH (2 to 10) or the ionic strength (0.01 to 4M) of simulated
waste solutions did not significantly affect the mercury adsorption capacity of thiol-SAMMS. Waste
streams containing Hg also typically contain many other cations (Ca, Cd, Cu(n), Fe(II), Ni, Pb, and
Zn) and complexing anions (Cl, CN, CO3, SO4, and  PO4). Tests were conducted to examine the
competitive adsorption effects of these  cations, and the complexation effects of anions  on Hg
adsorption.  The results indicated that the mercury adsorption capacity of thiol-SAMMS was not
impaired by the presence of these cations and anions that would be present in different types of waste
solutions. The reason for this rioncompetitiveness of other cations appears to be due to preferential
binding of a softer cation (Hg) by thiol functional groups. These adsorption characteristics show that
thiol-SAMMS is a versatile and cost-effective material for removing, recovering, and recycling Hg
from various types of waste streams.
                   Mercury Collection Programs in Sweden

                                    Kristina von Rein
                                Principal Technical Officer
                               Section for Chemicals Control
                         Swedish Environmental Protection Agency
                               S-106 48 Stockholm, Sweden
                        Tel:+46(0)8-6981127, Fax:+46(0)8-6981222
                               Kristina. von-rein @ environ, se

                                    Kristina von Rein
Ms. von Rein has been with the Swedish Environmental Protection Agency since 1990, and is the
project leader for the Govermental Assignment that includes both an Action Programme for more
efficient collection of used goods and products containing mercury and preparation of a proposal for
final disposal in Sweden of mercury-containing waste.

Ms. von Rein has a M.S. degree in chemical engineering.
                        Mercury Collection Programs in Sweden
Phase-out of mercury
Several years ago Sweden decided that the use of mercury should eventually cease altogether, the
target year being 2000. A mercury phase-out means that it is firstly the input of new mercury to
society that is reduced. Still, large quantities of mercury are present in goods and products still in use.
It has been estimated that in Sweden alone (8 million people) there are hundreds of tonnes of mercury
in circulation in products.
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Action Programme for the collection of mercury
The Swedish EPA was engaged in an  Action Programme (1994 - 1999) as instructed by the
government in order to improve the efficiency of mercury collection. The Swedish state had allocated
about 20 million SEK for this purpose. The SEPA has given aid to 49 projects as well as carried out
several projects of their own.

The SEPA programme has focussed on increasing the collection of hidden mercury in the form of:
•         clinical thermometers containing mercury,
•         mercury in technical goods and products,
•         metallic mercury ori shelves and in storage rooms, and
•         "historic" mercury (in sinks, floor drains, tubes, etc.).

Many efforts undertaken in the action programme have been aimed at mercury inventory, on one hand
identification and labelling of mercury in use and on the other hand collection of worn out mercury
'and discarded goods and products containing mercury.
A total of 10 -11 tonnes of mercury has been identified, 6 - 7 of which have been collected and 3,5
- 4 tonnes have been labelled.

New ways of finding and collecting mercury
In different regions in Sweden, specially trained electricians, so-called mercury detectives, were
visiting companies, local businesses, municipal sewerages to identify and collect or label mercury-
containing products. Also, some projects involved tracing mercury with the world's first mercury
dogs, Froy and Ville. The dogs have been searching for mercury in schools and at universities, finding
mercury while saving both time and money. Several tonnes of mecury  have been found this way.
Swedish municipalities and county administrative boards have participated in all projects.
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               Phase-Out of Mercury-Containing Products

                                   Folke Dorgelo
                               Internal postal code 655
                    Directorate-General for Environmental Protection
               Ministry of Housing, Spatial Planning and the Environment
                                   P.O. Box 30 945
                               2500 GX THE HAGUE
                                   The Netherlands
                    Phone: + 31 70 339 4908, Fax: + 31 70 339 1297
                        Folke.Dorselo@DSVS.DGM.minvrom.nl               ,

                                   Folke Dorgelo
 Mr. Dorgelo's role at the Ministry of Housing, Spatial Planning, and the Environment encompasses
' heavy metals policy, negotiations with the metal industry in The Netherlands - especially concerning
 the reduction of corrosion and run-off of copper, zinc and lead used for construction and building;
 recycling of plastics and packaging (waste) containing heavy metals; risk evaluation and risk
 management of metals (lead, mercury, cadmium, copper, zinc, chromium, nickel, bismuth, tin) and
 PNAs; and chemicals risk reduction programme of the OECD, Environmental Health and Safety
 Division (lead, mercury and cadmium). Mr. Dorgelo also participates in the European Commission
 DG Enterprise working group (chemicals, plastics and rubber) on the 'limitations on marketing and
 use of dangerous substances and preparations' (Directive 76/769/EEC).

 Mr. Dorgelo earned his M.S. in Biochemistry (1974) from the State University of Leiden, has a
 Teaching Degree in Chemistry and is a registered toxicologist (Dutch Society for Toxicology).
              Phase Out of Mercury-Containing Products in the Netherlands

The pollution by mercury in the Netherlands is largely caused by mercury-containing products. Closer
examination of the Dutch flow of mercury into soil shows that in 1990 over 40% of the flow
originated from mercury-containing products. For surface water, a similar percentage comes from
mercury-containing products and for sewage sludge over 80% originated from mercury-containing
products. This shows that taking product-oriented measures makes a relevant contribution to the
reduction in mercury emissions and in addition to the quality of sewage sludge. To determine which
products contain mercury and which alternatives are available, an inventory research was carried out.

The data from this research partly forms the basis for the Dutch 'Decree on products containing
mercury 1998'. The use  of mercury in the Netherlands was estimated at 12.5 tonnes in 1994.
Approximately 45% of this can be accounted for by the use of amalgam in dental surgeries. Since
1991, emissions into the  environment have been greatly reduced by the use of special amalgam
separators. Approximately 40% is used in various measuring instruments, electro-technical products
and in lighting. The remaining 15% is used in batteries, chemicals, pharmaceutical preparations and
in the chlor-alkali industry (mercury cell process).
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The Decree is intended to achieve the mercury emission reduction objective. Through a ban on the
manufacture of and trade in products containing mercury where alternatives are available, the supply
of mercury within the economic circuit will be reduced by approximately 35%, or 4.3 tonnes per year.
This relates to products such as measuring instruments and electro-technical products. As a result of
the Decree, mercury emissions will gradually decrease, because it will take a few years before all the
products containing mercury which are in use are replaced by mercury-free alternatives. Starting from
the Dutch emission levels in 1990, the emission into sewage sludge, soil and water will decrease by
30%,  20% and 15% respectively. Existing facilities are used for the safe  disposal of mercury-
containing products.
                Demonstration of Mercury Treatment Technologies
                            to Meet DOE Customer Needs
                                          Greg Hulet
                                   Mixed Waste Focus Area
                                     Bechtel BWXT, LLC
                     Idaho National Engineering and Environmental Laboratory
                                   P.O. Box 1625 MS 3875
                                  Idaho Falls, ID 83415-3875
                           Phone: (208) 526-0283, Fax: (208) 526-1061
                                        Hag@inel.gov

                                          Greg Hulet
Mr. Hulet is the work package manager for the Unique Waste Work Package, which includes DOE's
mercury mixed wastes. As such, he coordinates research, development, and technology deployment
activities to ensure that all the wastes in the Unique category have a path for treatment and disposal.
He has a Masters Degree in Chemical Engineering and ten years experience in waste management and
pollution prevention. He also has considerable experience with Naval Nuclear Propulsion Plants. He
has been  a scoutmaster for 15 years, which, after watching scouts cook for that long, has made him
an expert in unique hazardous wastes.
                        DOE Mercury Waste Treatment Demonstrations

Mercury has been used in Department of Energy (DOE) operations in a variety of applications. It has
been used as a catalyst in nuclear fuel reprocessing, as  shielding, and as a component of isotope
separation processes. It is  still being used in a number of facilities. Because of its widespread use,
mercury contamination can be found at most DOE facilities. Efforts to clean up, treat and dispose the
associated wastes are underway. However, for some DOE mercury wastes, until recently, no treatment
processes were available  that had been demonstrated  to be safe  and effective in a  radioactive
environment. The DOE  Mixed  Waste Focus  Area (MWFA) has  been  supporting research,
development, demonstrations, and technology deployments to ensure that all mercury-contaminated
waste can be safely treated and disposed. These activities have been divided into three main areas:
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 amalgamation, stabilization, and separation. Subcategories of separation include removal of mercury
 from water, extraction from solid matrices, and gaseous emission control.

 DOE supported the demonstration of two commercial mercury amalgamation processes. Both
 successfully amalgamated radioactive waste elemental mercury from DOE sites. The final waste
 forms met the Land Disposal Restriction for mercury, O.2  ppm by Toxic Leach Characteristic
 Procedure (TCLP). Vapor pressure data for the waste forms are available.

 The MWFA coordinated several commercial demonstrations for stabilization of mercury mixed waste
 with  <260 ppm mercury. Allied Technology Group (ATG), Nuclear Fuel Services (NFS), and
 International Technologies  (IT) performed bench-scale studies using surrogate waste with several
 species of mercury. ATG, NFS, and GTS Duratek demonstrated their respective processes on actual
 waste. In all cases the stabilized mercury met LDR limits. Reports covering each of these studies are
 available from the MWFA. Demonstrations are presently underway to treat >260 ppm mercury waste
' from Brookhaven National Laboratory (BNL). Sepradyne/Raduce is using their vacuum thermal
 desorption unit to extract mercury from the waste, while ATG, NFS, and BNL are using stabilization
 processes to treat the material. DOE is working closely with EPA on this project to acquire data that
 may support a change in the regulations for treatment of >260 ppm mercury-contaminated soils and
 sludges. BNL is the only group to have completed testing.

 The DOE program for development of a process to extract mercury  from solid matrices by non-
 thermal means is currently  on hold because of funding cutbacks. The Polymer Filtration process
 dissolves  mercury in  shredded matrices  and  separates it from the solution using a complexing
 polymer. The process is ready for pilot-scale demonstration.

 Oak Ridge conducted comparison tests of mercury sorbents on mercury-contaminated stream water
 from their East Fork Poplar Creek. ADA Technologies also tested their mercury sorbent process on
 the creek water with good results. Reports are  available that summarize these two projects.

 The MWFA is investigating continuous emission monitors for mercury but units are not available yet
 for commercial deployment. ADA has made  progress in this  area and in the area of sorption of
 mercury from gas streams.

 Budget reductions have impacted work on the DOE mercury problems. Hopefully, funding will be
 available in fiscal year 2001 to bring the work to fruition.
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 Return and Recycling of Used High Intensity Bulbs for Recycling and
                         Closed-loop Mercury Control

                               Lester Gress and Jeff Lord
                              Cleveland Fluid Systems Co.
                                     PO Box 41070
                                  Cleveland, OH 4414
                        Phone: (440)526-7070, Fax: (440)526-0770
                                    lsress@aol.com
          Return and Recycling of Used High Intensity Bulbs for Recycling and
                             Closed-loop Mercury Control

Mercury is recognized as a highly toxic material and is stringently regulated in waste discharges. The
majority of these discharges contain mercury in low concentrations limiting the control and recovery
options.  Wastes from a variety of  industries generate wastewater containing residual mercury,
including: lighting, medical, photographic, chloralkali, electronics and power generation.

The lighting industry has begun to address control and the reuse of mercury while they are trying to
find substitute materials that adjust the electrical characteristics for the discharge lamp. One company
has instituted a return of used high intensity lamps and the recovery of mercury from them. This
program, helps prevent mercury from entering into the eco-system. Some of the used and crushed
glass is washed to insure the complete removal of mercury.

Typical treatment of wastewater requires multi-step processing ending in polishing steps that
scavenge or trap residual mercury. These processing schemes result in added treatment costs and
generate hazardous waste. A closed-loop mercury control/recovery system can reduce these treatment
and disposal costs. The technology under development provides a means of accumulating sufficient
mercury that recovery is possible and, at the same time,  allows the minimization of the process
wastewater by operating in a recirculating loop.  Mercury is converted to its ionic  form in-situ by
chemical oxidation to improve solubility and is recovered electrolytically. The recovered mercury
is relatively pure depending on the other contaminants present and potentially requires little additional
processing before reuse.
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                 Mercury Amalgamation Demos With the DOE

                                     Clifton Brown
                                 ADA Technologies, Inc.
                             8100 Shaffer Parkway, Suite 130
                                Littleton, CO 80127-4107
                        Phone: (303)792-5615, Fax: (303)792-5633
                                cliff, b rown @ adatech. com
                                     Clifton Brown
 Mr, Brown is currently the Vice President of Operations for ADA Technologies, Inc. — a Denver-
 based technology R&D firm. Mr. Brown has 23 years of experience at Oak Ridge National Laboratory
. managing and performing R&D related to reactor fuel processing, coal conversion, and environmental
 processes.

 Mr. Brown has B.S. and M.S. degrees in Chemical Engineering. Mr. Brown is also a Professional
 Engineer.
                  Recent Advances in Mercury Stabilization Technology

 Since the early 1950s, mercury has been widely used throughout the DOE weapons complex. The
 legacy is contaminated solid waste, soils, and water. The main holders of mercury-contaminated waste
 are the Oak Ridge Reservation, the Idaho National Engineering and Environmental Laboratory, and
 the Savannah River Site.

 Nationally, the largest categories of mercury-bearing wastes are sludges,  soil, and debris. The
 Environmental Protection Agency subdivided  mercury-contaminated  solid wastes into three
 subcategories.

 •      Radioactively contaminated elemental mercury - treatment is amalgamation
 •      Low-mercury subcategory - treatment is stabilization
 •      High-mercury subcategory - treatment is thermal retort, followed by amalgamation if the
       recovered mercury is radioactively contaminated

 ADA Technologies, Inc., has demonstrated and filed a patent for a process to handle radioactive
 elemental mercury. In recent studies this initial work has been extended to soil matrices that are
 contaminated with greater than 260 pprn mercury. Results derived from both of these studies will be
 presented and discussed.
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  Deployment of the Sulfur Polymerization and Stabilization Process as
                  Applied to Mercury Contamination in Soils
                  Paul Kalb
        Brookhaven National Laboratory
  Environmental and Waste Management Group
    34 Railroad St., Bldg. 830, P.O. Box 5000
            Upton, NY 11973-5000
            -Phone:(631)344-7644
                kalb@bnl.sov
           Trevor Jackson
        EnviroCare Utah, Inc.
    46 West Broadway, Suite 116
       Salt Lake City, UT 8410
Phone: (801) 532-1330, Fax: (801) 532-
               7512
    tiackson @ envirocareutah. com
                                       Paul Kalb
•Paul Kalb is a Senior Research Engineer at Brookhaven National Laboratory. He has a bachelor's
 degree in mechanical engineering from the State University of NY at Binghamton and a master's
 degree in nuclear engineering from Polytechnic Institute of NY. Paul has been employed at BNL for
 20 years and has concentrated his efforts in the areas of hazardous/radioactive waste management,
 environmental restoration, and health and safety aspects of emerging energy technologies. Current
 responsibilities include Principal Investigator for programs on D&D and waste form development for
 DOE and industry. He has served as a member of several national technical support groups on Final
 Waste Forms for DOE and EPA, recently currently chaired a team that wrote a WASTECH volume
 on Stabilization/Solidification, is a member of the Program Advisory Committee for  Waste
 Management Symposia, Inc.,  and has numerous patents and publications in the area of waste
 treatment and encapsulation.

                                     Trevor Jackson
 Dr. Jackson received his Ph.D. in Mechanical Engineering from Oklahoma State University in 1983.
 He spent two years as an Assistant Professor at the University of Maryland then progressed into
 industry. He was the site engineer at the solar energy plants located in the Mojave desert of Southern
 California, responsible for upgrades of existing plants.  In 1988  he joined Science Applications
 International Corporation (SAIC) in San Diego providing assistance to the EPA in evaluating
 innovative technologies for the treatment of hazardous waste in the Superfund Innovative Technology
 Evaluation Program  (SITE).  He was Project Manager for the evaluation  of many  different
 technologies ranging from novel incinerators to bioremediation.  In  1998 Dr. Jackson joined
 Envirocare of Utah, Inc., as Technology Development Manager. In this role he is responsible for
 reviewing and implementing treatment technologies for mixed low level waste at the Envirocare TSD
 facility in Utah. Dr. Jackson also upgrades performance of the existing stabilization, micro-, and
 macroencapsulation technologies.
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Treatment of Elemental Mercury and Mercury Contaminated Soil and Debris by the Sulfur
                       Polymer Stabilization/Solidification Process

Elemental mercury contaminated with radionuclides (mixed waste mercury) and mixed waste
mercury-contaminated soil and debris, is a problem throughout the Department of Energy (DOE)
complex.  This presentation describes an innovative process developed at Brookhaven National
Laboratory (BNL) and currently being commercialized at Envirocare of Utah, Inc., to immobilize
mixed waste elemental mercury and mercury-contaminated soils and debris.  The product is a
monolithic solid waste form that is non-dispersible, will meet current and newly adopted EPA
leaching   criteria,  and  has low  mercury  vapor  pressure.   The BNL  Sulfur  Polymer
Stabilization/Solidification (SPSS) process (patent pending) is a two-stage process that chemically
reacts with mercury to form a product of low solubility and vapor pressure and then solidifies the
product in a solid matrix to further reduce leachability and dispersion of contaminants. Waste forms
containing as much as 33 wt% elemental mercury and as much as 60 wt% mercury-contaminated soil
were formulated which successfully passed current  Environmental Protection Agency Toxicity
Characteristic Leaching Procedure (TCLP) criteria as well as the more stringent Universal Treatment
Standard criteria that has been approved. In addition, the final waste form products exhibit extremely
low leachability when subjected to long-term leaching, and significantly reduced  vapor pressure
compared with untreated mercury. Bench and pilot-scale development at BNL is complete and plans
for commercial deployment at Envirocare's Clive UT mixed waste treatment facility are underway.
The process may also be applied for direct and simple treatment of hazardous mercury streams
as-generated or produced as secondary wastes from mercury separation technologies.
              Commercializing a Safer Substitute for Mercury

                                James D. Rancourt, Ph.D.
                                     NewMerc, Ltd
                               1872 Pratt Drive (MS 1260)
                                 Blacksburg, VA 24060
                       Phone: (540) 951-2500, Fax: (540) 961-5778
                                   info @ newmerc. com
                                httv://www. newmerc. com
                                 James Rancourt, Ph.D.
Dr. James Rancourt obtained an undergraduate degree in Chemistry at the University of Lowell in
Massachusetts. He earned a doctorate in chemistry, with an emphasis on analysis and preparation of
electrically conductive plastics,  from Virginia Tech. In 1987, Dr.  Rancourt founded Polymer
Solutions Incorporated, a company that provides innovative technical solutions to polymer and
materials programs.

Dr. Rancourt led a research team to develop alternative materials for the mercury metal that is used
in electrical switch applications, in 1992, at the request of the Virginia State Government. Dr.

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 Rancourt's team now has four international patents and commercial products. He is the President of
 NewMerc, Ltd., a company devoted to producing reliable alternative materials to mercury metal for
 industrial and government applications.

                     Commercializing a Safer Substitute for Mercury

 Mercury metal is a fundamental chemical element that has unusual properties: volatile, electrically
 conductive, reflective and liquid to low temperatures. Unfortunately, mercury metal, when handled
 or disposed of improperly, poses environmental and health  risks. It is becoming increasingly
 important that mercury be replace in industrial applications with a less toxic and reliable material.
 NewMerc, Ltd., has an  exclusive, all-fields worldwide license to technology that offers a safe
 replacement for mercury in many applications.

 This presentation  will provide a brief description of the impetus  for the nonmercury alloy
' development project, the research approach that was taken and the rationale for the technical solution
 that has been developed. The presentation  will provide information about the composition of the
 alloy, its method of preparation and application areas. In addition, the properties of the NewMerc
 alloy, its MSDS sheet and questions remaining for the full-scale implementation of the patented
 material will be provided. A brief overview of the company structure will also be provided.
    The Business of Mercury Pollution Prevention: Identifying Source
           Reduction Opportunities and Engineering Trade-Offs

                                    Kenneth R. Stone
                      National Risk Management Research Laboratory
                          U.S. Environmental Protection Agency
                             26 W. Martin Luther King Drive
                                 Cincinnati, Ohio 45268
                        Phone: (513) 569-7474, Fax: (513) 569-7111
                                 stone, kenneth @ et>a. sov
                                    Kenneth R. Stone
 Kenneth Stone is the Engineering Trade-Offs Team Leader for EPA's National Risk Management
 Research Laboratory, based in Cincinnati, Ohio. Ken has been with the EPA for 18 years and has
 worked primarily in pollution prevention research with an emphasis on federal facilities and
 operations. Ken founded and managed the Life Cycle Engineering and Design Program, a cooperative
 venture with DoD to apply Life Cycle Engineering and pollution prevention methodology to industrial
 systems. Ken's team is conducted research to advance the state of the practice of LCE and has
 completed several LCE case histories on both public and private products and operations.
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             The Business of Mercury Pollution Prevention: Identifying Source
                  Reduction Opportunities and Engineering Trade-Offs

The demand for mercury in the United States is still growing or declining only slightly in a number
of industrial sectors. These include electric lighting, electronic equipment, wiring devices  and
switches, measurement and control instruments, dental equipment and supplies, laboratory uses, and
medical uses. About 190 tons of mercury were used by these sectors in 1997. While EPA is pursuing
a number of voluntary initiatives within these industries, information on consumption, use, release
and environmental impact is poor. Therefore, an assessment is underway to collect the data needed
to identify the potential for source reduction across industry sectors. This assessment will determine
in which areas emissions are large and difficult  to measure. This assessment will incorporate
collaborative activities with industry, including providing systems analysis tools such as Life Cycle
Engineering (LCE) and Engineering Trade-Offs (ETO) to help industry determine the economic,
energy, and environmental costs and benefits of management options.

The National Risk Management Research Laboratory (NRMRL) has initiated a Pollution Prevention
Prioritization Assessment (P2PA),  based on evaluation of the potential for source  reduction of
mercury use in the consumer sector, to identify major needs and opportunities for reduced use  and
releases. The P2PA will guide the development of at least two evaluations of pollution prevention
approaches for mercury using life  cycle  analysis,  and determine  the reduction in  adverse
environmental impacts. The P2PA will also guide the selection of sector activities for evaluation of
engineering trade-offs and input/output modeling.

ORD will use research innovative and emerging technologies for reducing reliance on mercury  and
mercury-containing products in these industries. This investigation will focus on source reduction
opportunities. A compendium of technologies and technical solutions will be developed in order to
inform the next step of the plan,  prioritization.
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                A PBT Technology Information Clearinghouse
            Frederic H. K. Booth
           Waste Policy Institute
      12850 Middlebrook Rd., Suite 250
       Germantown, MD 20874-5244
 Phone: (301) 528-1909, Fax: (301) 528-1970
          fred booth@st.wpi.ors
             Kay Van der Horst
Associate Director, Environmental Security Programs
           Waste Policy Institute
      12850 Middlebrook Road, Ste. 250
       Germantown, MD 20874-5244
Phone: (301) 528 - 1923, Fax: (301) 528 - 1971
 Kvanderh @ dark, net or Kay vdh @ st. wpi. ore
                                  Frederic H. K. Booth
Mr. Fred Booth is the senior economist at WPI and has more than 25 years experience in leading
economic, energy and environmental analysis programs.  His experience includes analyses and
'optimization of energy, economic, and environmental system interactions; development of global
climate change decision support tools and programs; development of environmental information systems
architectures; systems analysis of local, regional, and national energy policy/regulatory issues; alternative
fuels and electric utility demand forecasting; and technology diffusion analyses of advanced energy
technologies. He has experience in evaluating the economic implications of proposed amendments to
both RCRA and CERCLA. Additionally, his experience includes environmental  technology cost
analysis model  development, econometric analyses, comparative and parametric life cycle cost
modeling,  innovative environmental technology cost-benefit analyses, and evaluation/demand
forecasting for emerging technologies, particularly in energy and environmental markets.

                                   Kay Van der Horst
Mr. Van der Horst is the Associate Director for Environmental Security Programs for WPI, a
Virginia Tech owned not-for-profit organization. He is a specialist on domestic and international
environmental security concerns with a particular emphasis on stakeholder involvement and risk
communication. Currently, he is co-leading for WPI the development of EPA's new "PBT
Information, Communication and Decision Support Clearinghouse". His responsibilities also
include the development and implementation of Stakeholder Communication, Risk
Communication, Training and Community Outreach Programs. Other programmatic areas focus
on the development on risk management response and systems engineering. Prior to WPI Mr. van
der Horst has worked in various capacities on environmental security issues for the University of
Alaska-Fairbanks, Texas A&M University and various international institutions such as the
United Nations and the European Parliament.

             The EPA PBT Information and Communications Clearinghouse

Many EPA Offices  individually address Persistent Bioaccumulative Toxics (PBTs) in varying
contexts. The basic goal of the PBT Initiative is to identify and reduce risks to human health and the
environment from current and future exposures to priority PBT pollutants and address them in an
integrated manner. Implicit in achieving EPA's objectives in the PBT initiative is effective, efficient,
and focused information management in the context of PBT technical data, scientific data, and
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communications/outreach efforts. This presentation addresses the key aspects of developing and
implementing an EPA/OPPT PBT Information and Communications Clearinghouse. This concept
evolved from discussions with representatives of the various EPA Offices and programs represented
on the Mercury Task Force.

The structural approach contemplated in the  Clearinghouse is straightforward: Develop generic
information management structures and strategies that are sufficiently flexible such that they can be
adapted to accommodate potentially unique informational dimensions of any PBT, yet are consistent,
comparable, and robust.  Key features of this approach include: creating processes that support
information flows into and from the Clearinghouse,  and providing on-going opportunities for
stakeholder information inputs in a dynamic information management environment. This approach
directly contributes to ensuring cost effectiveness via economies of scale in managing multiple PBT
data sets, and enhances the ability of the Clearinghouse to transparently provide user interfaces to
similar information management activities at other federal agencies, universities, and research
'organizations.

The activities conducted in assessing the aspects of developing and implementing an EPA/OPPT PBT
Information and Communications Clearinghouse will include:

•       Defining the specific mission, objectives, and goal(s) of the PBT Clearinghouse;

•       Defining/characterizing alternative PBT Information Clearinghouse structural approaches and
        the relative strengths and limitations of each structural alternative;

•       Identifying preliminary opportunities for programmatic leverage;

•       Identifying/characterizing the benefits of the PBT Clearinghouse;

•       Identifying/characterizing existing information management activities  that could either
        contribute to, or be considered competitive with, the OPPT PBT Clearinghouse;

•       Identifying/characterizing the specific PBT Clearinghouse pre-implementation activities that
        will contribute to a successful, cost-effective, highly functional PBT Clearinghouse;
•       Defining/characterizing stakeholder audiences (and their needs) for the mercury module of
        the PBT Clearinghouse;

•       Identifying critical  PBT  Clearinghouse Quality Assurance issues, including  information
        consistency, comparability, data validation and verification, and systems configuration;

•       Identify international mercury information activities, including DOE/FETC, UAF, UNEP,
        AMAP, and the European Union; and

 •       Consideration of risks (technical, information management, performance, schedule) inherent
        in developing and implementing an activity such as the PBT Clearinghouse.
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 The EPA PBT Industry Technology Market Forum

 Implicit in achieving the objectives of the EPA PBT initiative's guiding principles is the effective,
 efficient, and focused management of PBT information, scientific data, and communications/outreach
 efforts. These guiding principles include:

 • Addressing problems on multimedia bases through integrated use of all EPA tools;
 • Coordinating with and building on relevant international efforts;
 • Coordinating with and building on relevant federal programs and agencies;
 • Stressing cost-effectiveness (amount of PBT removed per dollar spent);
 • Involving stakeholders;
 • Emphasizing innovative technologies and pollution prevention;
 • Protecting vulnerable sub-populations;
 • Basing decisions on sound science; and
• • Using measurable objectives and assess performance.

 The subject of this presentation is assessing the key aspects of developing and implementing an
 EPA/OPPT PBT dynamic, stakeholder driven EPA/Industry Technology Market forum that is an
 integral element of an OPPT/PBT  Information and Communications  Clearinghouse which will
 directly contribute to implementing  the guiding principles of the PBT Initiative. The EPA/Industry
 Technology Market Forum:

 •   Provides  Regulatory  Compliance  Incentives for Industry by  Providing Cost  Savings
    Opportunities;
 •   Eases Regulatory Compliance Support by Providing Industry With Higher Production Efficiency
    Opportunities;
 •   Creates a Marketplace for Ihtercomparable/Verifiable Innovative Technologies;
 •   Fosters Development of Innovative Technology Developments by Expanding Hidden Technology
    Visibility; and
 •   Fosters Global Environmental Technology Improvement and Exchange.

The initial focus of the EPA Environmental Technology Market Forum will be mercury-related
information, communications products and services. Though initially driven by a mercury focus, the
EPA Environmental Technology Market Forum will be designed to  accommodate a larger
environmental technology market that addresses technology needs of all other PBTs.

WPI currently also supports the Department of Energy-National  Energy Technology Laboratory
(DOE-NETL) in the design, development and implementation of its Decision  Support Center. The
first information module in the Center focuses on DOE's coal combustion-based mercury data
collection and analysis program. The NETL effort is also  significantly driven by providing
comparable technology solutions and information. This project represents both a unique opportunity
for OPPT and the Mercury Task Force to apply real-time lessons learned from the NETL program,
and  additionally,  leverage EPA  and DOE mercury  program funds to improve the  overall
programmatic return on investment. Most significantly, the successful creation and implementation
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of the Environmental Technology Market Forum, in conjunction with the PBT Clearinghouse
concept, represents the first of an on-going series of opportunities to leverage limited EPA resources.
    Mercury Stabilization in Chemically Bonded Phosphate Ceramics

                                  Arun S. Wagh, Ph.D.
                          Ceramist, Energy Technology Division
                              Argonne National Laboratory
                                  9700 S. Cass Avenue.
                                   Argonne, IL 60439
                      Phone: (630)252 4295/5741, Fax: (630)252 3604
                                    wash@anl.eov
                                     Arun S. Wagh
Dr. Wagh is working as a materials research engineer at Argonne National Laboratory and has a Ph.D.
in physics. His expertise includes radioactive waste management, mineral waste management, and
structural ceramics.

With his colleagues who are co-authors  of this presentation, he developed chemically bonded
phosphate ceramic program for radioactive and hazardous waste stabilization at Argonne National
Laboratory, pioneered research on bauxite tailings (high volume residue from alumina refineries),
directed projects related to utilization of greenhouse CO2, and hot gas ceramic cross-flow filters at
Argonne National Laboratory, and worked as consultant to alumina industries, that include, ALCOA,
ALCAN, and Virgin Island Alumina Co.

Dr. Wagh was a recipient of the R&D-100 Award given by R&D Magazine in 1996 for 'Ceramicrete
Binder', and the Pace Setter award by Argonne National Laboratory in 1997.
            Mercury Stabilization in Chemically Bonded Phosphate Ceramics *

Mercury stabilization and solidification is one of the challenges for the conventional stabilization
technologies. This is because of the stringent limits on leaching of its stabilized products that need
to be enforced. In a conventional cement stabilization process, Hg is converted to its hydroxide at
high pH which is not a very insoluble compound and hence sulfidation of Hg is considered to be a
preferred route which converts it into an insoluble cinnabar (HgS). Unfortunately, efficient formation
of this compound is pH dependent. At a high pH, one obtains more soluble sulf ate of Hg, in a low pH
range insufficient immobilization results due to escape of hydrogen sulfide, while efficient formation
of HgS occurs only in a moderately acidic region. This is the region (pH = 4-8) in which stabilization
using Chemically Bonded Phosphate Ceramics is carried out.
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This presentation will discuss this kinetics followed by our experience on bench stabilization of
various U.S. Department of Energy (DOE) waste streams containing Hg in the Chemically Bonded
Phosphate Ceramic (CBPC) process. This process was developed to treat DOE's mixed waste
streams. It is a room-temperature-setting process based on an acid-base reaction between magnesium
oxide and monopotassium phosphate solution that forms a dense ceramic within hours. For Hg
stabilization, addition of a small amount (<1 wt.%) of Na2S or K2S is sufficient in the binder
composition.

Here we discuss the Toxicity Characteristic Leaching Procedure (TCLP) results on CBPC waste
forms of secondary waste streams generated from Hg-containing wastes such as combustion residues
and Delphi "DETOXSM" residues. The results show that though the current limit on leaching of Hg
is 0.2 mg/1, the results on the CBPC waste forms are at least an order lower than this stringent limit.
This  low leaching level provides robustness to  the process and allows sufficient margin for the
variability of Hg content in the waste. The efficient stabilization is attributed to chemical
immobilization of Hg as cinnabar followed by its physical encapsulation in a dense matrix of the
ceramic.

Using this process, Argonne-West has eliminated Hg-contaminated light bulbs from its inventory.
These bulbs were slightly contaminated radioactively and hence this Was a typical mixed waste
stream. This presentation will provide a brief review on this work as an example of disposal of Hg-
contaminated actual waste.

* Work supported by U.S. Department of Energy, Office of Technology Development, as a part of
the Mixed Waste Focus Area, under Contract W-31-109-Eng-38, and Delphi Research, Inc., of
Albuquerque, NM.
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              Characterization and  Leachability of  Stabilized
                          Mercury-Containing Wastes

                                      Linda Rieser
                                   Academic Director
           Accelerated Life Testing and Environmental Research (ALTER) Facility
                                 University of Cincinnati
                                     Cincinnati, OH
                       Phone: (513) 556-2060, Fax: (513) 556-3148
                                  Irieser© ucens. uc. edu
                                      Linda Rieser
Linda Rieser joined the University of Cincinnati in 1981. She served as Senior Research Associate
from 1981 to 1991 and as Academic Director of UC's Accelerated Life Testing and Environmental
Research (ALTER) Facility for the last 9 years. Her expertise includes the application of experimental
methods to problems involving the solubility and mobility of hazardous and radioactive elements,
the origin and remediation waters and soil, and the treatment of hazardous and radioactive wastes.
       Characterization and Leachability of Stabilized Mercury-Containing Wastes

EPA's National  Risk Management Research Laboratory (NRMRL)  in collaboration with the
University of Cincinnati established a research program supporting Agency actions on mercury; in
particular, the potential revisions to the Land Disposal Restrictions for mercury-bearing wastes. Over
the past year, research has been conducted on the characterization and leachability of several mercury
waste forms. Wastes studied include mercuric sulfide sludges from several chemical plants, mercuric
chloride catalyst used in the manufacture of vinyl chloride, surrogate mercuric chloride and elemental
mercury wastes This presentation describes characterization of the stabilized waste samples and
analysis of leaching stability. The testing includes TCLP analysis and constant pH leaching tests to
determine the potential mobility and stability of the mercury under simulated landfill conditions.

The work to be presented was performed by Paul Randall (EPA) and Paul Bishop, Haishan Piao,
Renee Rauche, Linda Rieser, Makram Suidan, and Jian Zhang (UC).
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               Treatment of Wastes Contaminated with Mercury

                                     Paul R. Lear, Ph.D.
                                      ET Corporation
                                     304 Directors Drive
                                    Knoxville, TN 37923
                         Phone: (865) 694.7316, FAX: (865) 694.9573
                                   plear@ theitsrouv. com
                                    Paul R. Lear, Ph.D.
 Dr. Lear has over 12 years experience in the treatment of hazardous waste with dewatering, soil
 washing and stabilization treatment technologies. He has experience in selecting and evaluating
 treatment alternatives and providing data for preliminary design activities and project equipment
'specifications. He has conducted research in the area of innovative stabilization systems, including
 systems for the stabilization of organic contaminants in hazardous wastestreams. Dr. Lear has also
 conducted research into the stabilization of metals, concentrating on arsenic,  mercury, thallium,
 vanadium, antimony, and beryllium. He has extensive experience in the stabilization of hard-to-treat
 wastestreams, such as hazardous waste incinerator residues. Dr. Lear has hands-on experience with
 full-scale remediation activities and specializes in process troubleshooting. He has provided technical
 operational support to bioremediation, dewatering soil washing, stabilization, thermal, and wastewater
 treatment activities at remedial sites. He has also managed several pilot- and field-scale technology
 demonstrations.

                     Treatment of Wastes Contaminated with Mercury

 This presentation will focus on the treatment of wastes contaminated with mercury. Four technologies
 (heavy  metals bioremediation, surface decontamination, stabilization, and  thermal  desorption)
 applicable for the treatment of mercury wastes will be discussed, along with data from selected case
 studies.

 Heavy metals bioremediation involves the stimulation of naturally occurring or augmented sulfur-
 reducing bacteria. These bacteria produce sulfuric acid and reduce the pH of the waste to below 2.
 Leaching of water through the waste removes the solubilized metals. The metals are then precipitated
 from the leach solution and sent for metals recovery or disposal.

 Surface decontamination combines physical and chemical removal of contamination on the surface
 of debris such as concrete, block, and scrap metal.  Extraction  solutions containing chelants or acids
 are applied to the surfaces, allowed to react, and collected. Vacuum techniques are often applied to
remove the extraction solution from semi-porous surfaces such as concrete. Multiple extractions are
often required, especially on semi-porous surfaces.

Stabilization of mercury involves re-speciation of the mercury contamination to mercury sulfides. The
chemistry required for re-speciation depends on the form of mercury in the waste. The solubility of
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mercury sulfides is on the order of 10 mg/L. The mercury sulfides are then encapsulated in a cement
matrix.

Thermal desorption involves the direct or indirect heating of the waste to volatilize the mercury. The
temperature required for the volatilization depends on the form of mercury in  the waste. The
volatilized mercury is then condensed in the air pollution control system for recovery or disposal.

Case histories involve the application of thermal desorption and stabilization treatment technologies
to mercury-contaminated wastes.
                    Treatment of Mercury-Bearing Wastes
                    with Thermal Desorption Technology

                                  David B. Malkmus
                             Applied Technologies Manager
                                SepraDyne Corporation
                                    72011-35 North
                                  Denton, TX 76207
                       Phone: (940)243-8203, Fax: (940) 243-9089
                             Dmalkmus. sevradvne @ iolt. com
                                   David B. Malkmus
Mr. Malkmus received his degree (BS 1979) in Chemical Engineering from Clemson University with
specialization toward Environmental Engineering. He has over 20 years experience in the design,
startup operation and project management of waste processing systems used in the commercial and
energy industries including the Department of Energy and commercial nuclear power plants. Mr.
Malkmus has designed large scale, proprietary waste treatment systems incorporating advanced water
processing and state of the art waste minimization technologies. He has published several technical
papers regarding technology advances through EPRI, US DOE  and the  International  Water
Conference.

     High Vacuum Rotary Retort for the Recovery of Products and the Minimization of
                                    Wastestreams

At a Westinghouse subsidiary, Scientific Ecology Group, Mr. Malkmus served as a fellow engineer
responsible for the evaluation, development, and deployment of new technologies for waste treatment
applications in addition to serving as a project manager in the Operations Department. Prior to that,
he held engineering and operation management positions with VECTRA Technologies, the SCANA
Corporation: VC Summer Nuclear Power Plant and the NUS Corporation.
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 The SepraDyne Corporation has commercialized an extremely cost-effective process for removing
 and recovering constituents having boiling points below 800°C. The process further provides a highly
 efficient reduction in the volume of any remaining non-volatilized media. The process material is
 indirectly heated within a rotating vessel under a high vacuum inert environment. The constituents
 of concern are volatilized and diffused from the feed material through the off-gas treatment train.
 Volatile constituents are condensed to liquid through an advanced impinger, chill water system. By
 operating under high vacuum, the material boiling points are significantly reduced thus enabling the
 ease of product recovery at lower operating temperatures. There is little decomposition of products
 due to thermal energy. Since the desorption and product recovery process is performed in an oxygen-
 free inert environment, there is no generation of furans and dioxins as well as any products of
 incomplete combustion. All retort off-gases are condensed to liquid eliminating the potential release
 of toxic substances to  the atmosphere and thus permitting the recovery of the constituents for
 beneficial use. In addition, secondary waste streams are not produced because a steam or gas stripping
 media is not required to remove and transport chemicals from the processed material.

 This paper will provide an overview of SepraDyne vacuum desorption system(s) and outline the
 technological advances of the indirectly heated high vacuum retort.  Also included are the results of
 several commercial and DOE applications for the separation of mercury from previously classified
 waste stream sources the minimization of waste sources and the near complete destruction of furans
 and dioxins.
                   Permanent Mercury Disposal in Sweden

                                    Kristina von Rein
                                Principal Technical Officer
                               Section for Chemicals Control
                         Swedish Environmental Protection Agency
                               S-106 48 Stockholm, Sweden
                      Phone: +46(0)8-6981127, Fax: +46(0)8-6981222
                               Kristina. von-rein @ environ, se
                                    Kristina von Rein
Ms. von Rein has been with the Swedish Environmental Protection Agency since 1990, and is the
project leader for the Govermental Assignment that includes both an Action Programme for more
efficient collection of used goods and products containing mercury and preparation of a proposal for
final disposal in Sweden of mercury-containing waste.

Ms. von Rein has a M.S. degree in chemical engineering.
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                         Permanent Mercury Disposal in Sweden

Phase-out of mercury
Mercury is currently being phased out by means of various bans on the use of goods and products
containing this metal, the target year being 2000. Also, the export of mercury as a residual product
has been prohibited since July 1,1997. Exports of mercury waste for reprocessing and reuse abroad
is not a feasible alternative, at the same time as use of mercury in Sweden is being phased out. The
Agency believes that capacity for disposal  of mercury-containing waste should exist within the
country.

Mercury is one of the most toxic of all pollutants. The burden of mercury on our environment must
be reduced since every addition is undesirable. The Swedish EPA believes that it is our generation
that must reverse the trend in order to create a healthy living environment for future generations. The
question of how to store waste containing mercury ultimately concerns finding a way of detoxifiyng
our society.

Disposal of mercury-containing waste
Large quantities of discarded goods are currently in storage pending a solution. Large amounts of
waste are also  stored in industry, either temporarely or at sites which do not meet long-term
environmental safety requirements. The Swedish EPA considers this situation to be untenable. It is
therefore essential to find a method for the terminal storage of mercury.

In December 1997, the Swedish EPA presented a report, concluding several years of investigations,
to the Swedish government with the conclusion that disposal of waste containing mercury demands
a tailor-made solution. The  Swedish Environmental Protection Agency believes that mercury-
containing  waste should be disposed of in such a manner that the mercury leaks  to the external
environment as little as possible, viewed in a long-time perspective.

Deep storage rock - the best alternative
Alternative solutions have been compared, with a view to finding the form of terminal storage which
best fulfils stringent environmental requirements. The alternatives compared are high-quality surface
storage, shallow storage in rock and deep storage in rock. These options differ in philosophy and the
way in which the surrounding environment must be protected against emissions.

The EPA considers that deep storage in rock is the safest method of storage in the long term,  since
it is the solution most in harmony with the environment; i.e., nature is used as a barrier and a buffer.
The surrounding bedrock will protect the functionality of the storage facility for thousands of years
or even longer. This solution can and should also be accompanied by technical measures to further
reduce the risk of future emissions and to compensate for our lack of knowledge about the long-term
processes governing the dispersal of mercury.
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  Sub-Seabed Emplacement:  Long-Term Ultimate Disposal of Mercury
                   Wastes in Geologic Formations on Land

                              D. R. (Rip) Anderson, Ph.D.
                              Sandia National Laboratories
                                P.O. Box 5800, MS-0779
                                Albuquerque, NM 87185
                                Phone: (505) 284-4600
                                 drander@ sandia. sov
                               D.R. (Rip) Anderson, Ph.D.
Dr. Anderson has 39 years of experience at Sandia National Laboratories and currently is the Project
Manager for Sandia activities supporting  the Waste Isolation Pilot Plant.  Dr.  Anderson's
responsibilities include: technical analysis, code development, quality assurance, testing, field and
laboratory data analysis, geotechnical and geochemical analysis, and incorporating the above into
performance assessment calculations for the Waste Isolation Pilot Plant.

Dr. Anderson is an internationally recognized expert in risk and performance assessment. As manager
of the WDPP Performance Assessment Department, Dr. Anderson led the construction and preparation
of performance assessment analysis for a compliance certification application to EPA which has led
to the opening of the first deep geological repository for radioactive wastes in the U.S. Dr. Anderson
also has led numerous waste disposal and management efforts, including, but not limited to, the Sub-
SeabedHigh Level Waste Project, the FUSRAP Disposal Program, and the Decommissioned Nuclear
Submarine Program.

Dr. Anderson has authored and co-authored more than 50 publications and reports dealing with waste
disposal, performance assessment and risk assessment. Dr.  Anderson is also the editor of the
Radioactive Waste Management Journal.

Dr. Anderson earned a B.S. in Chemistry (1957) from Idaho State University, and a Ph.D. in
Theoretical Organic Chemistry and Chemical Oceanography (1961) from Oregon State University.
                 Land-Based Geologic Emplacement of Mercury Wastes

In 1979, Congress authorized the U.S. Department of Energy to build a research and development
facility - the Waste Isolation Pilot Plant (WTPP) - to demonstrate the safe disposal of defense nuclear
wastes containing transuranic radionuclides. The WIPP, located near Carlsbad, NM, was opened as
the world's first nuclear waste repository and received its first shipments of transuranic wastes in
March 1999.

The overall process of assessing whether or not a waste disposal system meets a set of performance
criteria is known as a Performance Assessment (PA). The WEPP PA, conducted by Sandia National
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Laboratories, provided important input to decisions on the safety of a plan of action using a detailed
procedure and scientific knowledge. For radioactive wastes, a computationally demanding set of risk-
based performance criteria was specified by the U.S. Environmental Protection Agency (EPA). These
were quantitative criteria that specified probabilistic limits that had to be met for the first 10,000 years
of operation of a nuclear waste facility. The WIPP PA group developed a suite of models to predict
future-behavior of the facility. The physical, chemical, and geological processes that determined the
behavior and evolution of the WIPP site were complex and highly nonlinear. The PA models that
describe  the processes are  complex and technically sophisticated, and can be used to study the
feasibility of the disposal of non-radioactive environmental contaminants with infinite half-lives, such
as mercury product wastes,  in a land-based repository.
              Mercury-Sniffing Dogs: The Swedish Experience

                                     Kjell Avergren
                              Environmental Dogs' Manager
                       The Dog Training Centre in Solleftea, Sweden
                                     +46 302 326 79
                                kiell. aversren @ swipnet. se
                               http://www. humanitydog. com
                                     Kjell Avergren
Mr. Kjell Avergren has worked with environmental issues on both a governmental and a
consultant level (local, regional and national) since 1980. He has lead the four Mercury Tracing
Dogs projects within the Swedish EPA's mercury collecting program.

           The Dog Training Centre in Solleftea and Mercury Decontamination.

                          Mercury - An environmental problem
Mercury is one of the world's most serious pollutants. One way to protect the environment is to
remove the mercury and deposit it in  safe storage. The Swedish Parliament has concluded that
mercury plays no part in the natural world and the use of mercury should be phased out by the year
2000. In several mercury-collecting projects with the Swedish EPA, the Dog Training Centre in
Solleftea showed that it is possible to obtain low-cost, successful, and rapid results using mercury
tracing dogs. The strategy was to work together with many different actors, rather than using new or
more regulations. The outcome was remarkable..
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                       Mercury Dogs - The Cost-Effective Solution
 In laboratories and chemical store cupboards, in hospitals, doctors' surgeries and dentists' consulting
 rooms and throughout industry, mercury can be found in sinks, drains and sewage systems. The Dog
 Training Centre now offers a mercury tracing service using sniffer dogs (The German Shepherd mr
 Froy and the labrador mr Ville Sigmund) and dog handlers. The service enables the cost-effective
 recovery of the mercury and prevents it from being dispersed in the environment through refuse or
 in the sewage system. Using sniffer dogs benefits the environment and the customer's bank balance.
 Tests have shown that using the dogs protects the environment, saves time and money, and generates
 goodwill.

 More than 3,000 kg of mercury were collected from more than 1,200 schools, 20 universities and
 many hospitals taking part in different Swedish EPA projects. A number of doctors' surgeries, den-
 tists' rooms, laboratories and business premises also participated in the projects. The dogs traced
 hidden mercury in sinks and floors in many thousands of buildings. German Shepherd mr Froy and
 labrador mr Ville Sigmund from the Dog Training Centre in Solleftea, Ltd., saved at the same time
 up to 3-3.5 million U.S. dollars in reduced decontamination costs. On average 5.300-8.800 U.S.
 dollars in clean-up costs were saved each working day, resulting in a short pay-off time.

 The dogs' achievement has attracted positive publicity from television, radio, newspapers, magazines
 and on the Internet in both Sweden and abroad. They have been the subject of more than 2,000 items,
 including 90 television programmes.

 The Dog Training Centre is part of the Iris Group, owned by the Foundation of the Visually Impaired,
 and the company's profit benefits the visually impaired. Humanity Dog trains guide dogs for the blind
 and breeds dogs to detect drugs, mould, PCB, oil, fire and mines. As part of its constant effort to
 improve the environment, the Centre has joined the "Green Trade network", established by the
 Swedish Trade Council.
     Mercury Source Reduction and Recycling in Electrical Products

                                   Eric (Ric) Erdheim
      Senior Manager/Government Affairs, National Electrical Manufacturers Association
                   Executive Director, Thermostat Recycling Corporation
                   National Electrical Manufacturers Association (NEMA)
                            1300 North 17th Street, Suite 1847
                                Rosslyn, Virginia 22209
                       Phone: (703) 841-3249, Fax: (703) 841-3349
                                 ric erdheim@nema.ors
                                   Eric (Ric) Erdheim
Ric Erdheim is Senior Manager for Government Affairs at the National Electrical Manufacturers
Association. He represents electrical manufacturers on environmental, occupational health, consumer
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product safety, and fire safety issues. He also serves as the Executive Director of the Thermostat
Recycling Corporation, an organization formed by the major thermostat manufacturers to operate a
wholesaler take-back program for mercury switch thermostats.

Mr. Erdheim spent ten years as a Congressional aide, most of that time as Environmental Legislative
Assistant to  Senator Frank R. Lautenberg of New Jersey. Mr. Erdheim played a significant role in
enactment of the ozone transport and air toxics provisions of the Clear Air Act Amendments of 1990,
the Pollution Prevention Act,  the Ocean Dumping Ban Act,  and the Mercury Containing and
Rechargeable Battery Management Act.

Mr. Erdheim graduated from the University of Pennsylvania with a B A in Economics and the George
Washington University Law School.
             Mercury Source Reduction and Recycling in Electrical Products

Manufacturers have used mercury in batteries, lamps and thermostats. Each has industry has adopted
different approaches to reducing environmental exposure to mercury that reflect the unique
characteristics of the product.

In the 1980s, battery manufacturers used over 1,000 tons of mercury a year, mostly to make alkaline
batteries. In response to environmental concerns, the industry developed alternatives to mercury in
virtually all batteries. As a result, the only consumer batteries manufactured today that contain any
mercury are button cell batteries. With the phase-out of mercury use by 1993, mercury from alkaline
batteries in the waste stream has dropped from 10,000 PPM to less than 300 PM. This level will
decline  by 50% every two years. This significant decline has been partially responsible for the
declines in mercury levels from incinerators.

Lamp manufacturers have reduced the average mercury level in four foot lamps from 48 mg in 1985
to 11.6  mg in 1999. As a result,  mercury contained in  lamps has  dropped significantly. More
importantly, use of mercury-containing lamps results in a net decrease in mercury because of the
energy efficient nature of the lamps as contrasted with no mercury but energy inefficient incandescent
bulbs.

Manufacturers cannot reduce the amount of mercury used in mercury switch thermostats. The average
mercury level in these thermostats is 3-4 grams. To address the problem of disposing of a product
with such relatively high levels of mercury as compared to lamps, manufacturers have established the
Thermostat Recycling Corporation to recapture mercury-switch thermostats. In the first eighteen
months  of operations in nine states, the TRC has recovered 270 pounds of mercury. This program
works because of the unique characteristics of thermostats and is not necessarily a model for other
products.

These examples indicate that manufacturers use mercury in a wide range of products for different
purposes. The products differ in: units sold, mercury levels, size and product composition, users
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(businesses/specialized installers/homeowners) and other factors. Because of these differences, issues
involved in waste management vary for each product necessitating different approaches.
                                DSCP Buying Green

                                   Anthony Armentani
                           Program Manager, Lighting Products
                           Defense Supply Center Philadelphia
                                   700 Robbins Ave
                               Philadelphia Pa. 19111-5096
                        Phone: (215) 737-8047, Fax: (215) 697-9093
                                aarmentani @ dscv. dla. mil
                                   Anthony Armentani
Anthony Armentani is currently the Program Manager for Lighting Products at the Defense Supply
Center Philadelphia. In this position Mr. Armentani is responsible for leading a team of associates
in the acquisition, inventory management, technical and quality support initiatives in the management
of over 60,000 commercial, non-commercial and military unique lighting items.

Mr. Armentani has over twenty years of federal service, all with the Defense Logistic Agency. He
started his career at the Defense Industrial Supply Center (DISC) in Philadelphia as an Equipment
Specialist and quickly moved up to Team leader, Supervisor and Branch Chief of the Miscellaneous
Hardware and Physical Security Equipment unit in the Technical  Operations Directorate. Mr.
Armentani spent four years, as the Technical Data Manager at DISC where he was responsible for the
acquisition,  management and distribution of all the technical data required for competitive
procurements at the center. Mr. Armentani spent two years on the  Commanders staff at DISC,
reengineering the work processes and participated in the development of DSCP's Innovative Logistic
Support units that have allowed for a strong customer focus.

Mr. Armentani is a graduate of Rowan University in Glassboro, NJ.

                                     Buying Green

The DSCP presentation will cover the methods and guidelines utilized by the DSCP Lighting Team
in the acquisition and support of energy-efficient low-mercury lighting products. The presenter will
discuss the DSCP/DLA customer commitment, The advantages and related savings in the use of low-
mercury energy-efficient lamps and the projects and partnerships that we nurture  and develop to
ensure widespread energy-efficient lighting use throughout the federal sector.  The briefing will
identify Energy and environmental guidelines used in the acquisition of energy-efficient products,
various types of low-mercury lamps available through DSCP and what new technologies are on the
horizon for federal energy users. The presenters will also discuss the different ways to research, select
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and order these energy-efficient low-mercury products from DSCP. Primary presenter for DSCP will
be Tony Armentani Program Manager-Lighting.


        EPA/AHA Agreement: Reduction of Mercury Wastes from
                        Hospitals/Health Care Facilities

                                      Chen Wen
                                   Program Analyst
           Pollution Prevention Division, Office of Pollution Prevention and Toxics
                         U.S. Environmental Protection Agency
                             401 M Street, SW (MC-7409)
                                Washington, DC 20460
                       Phone: (202) 260-4109, Fax: (202) 260-0178
                                  wen.chen@eva.sov
                                      Chen Wen
Chen is currently serving as a team member of the EPA Hospitals for a Healthy Environment
(H2E) project, and staffs a number of different workgroups associated with H2E.  Prior to
working on H2E, Chen served in a number of diverse posts throughout the EPA, including:

       Program manager of the Environmental Justice Through Pollution Prevention Grant
       Program;
•      Program manager of the Pollution Prevention and Insurance Project;
       Vice President Gore's Task Force for Government Reinvention;
•      Agency Task Force for Contracts Management Reform.

Prior to joining the EPA, Chen obtained his Bachelor of Arts degree in Political Science from the
University of Washington, and his Master of Arts degree in Public Policy Studies from the
University of Chicago.
                EPA/AHA Agreement: Reduction of Mercury Wastes from
                            Hospitals/Health Care Facilities

EPA's Voluntary Agreement with the American Hospital Association and Its Implications on the
Need for Agency Standard for the Disposal of Mercury According to EPA's Mercury Report to
Congress, the healthcare industry is the 4th largest source of mercury release.  The mercury
release eventually find its way into the food chain, and back to humans.

The voluntary agreement between the American Hospital Association - which represent some 85
percent of all healthcare facilities in the United States - and the EPA outlines a number of goals.
One of the stand-outs is to "virtually eliminate" mercury-containing waste by 2005.
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              Mercury Content of Products Commonly Used by
                              Boston Area Hospitals

                                    Kevin McManus
                     Toxic Reduction and Control Department (TRAC)
                         Massachusetts Water Resources Authority
                                    5313 38 St., NW
                                 Washington, DC 20001
                        Phone: (202)362-6034, Fax: (202)362-6632
                                    Kevin McManus
 Mr. Kevin McManus is the Director of the Toxic Reduction and Control Department (TRAC) of the
 Massachusetts Water Resources Authority.

 Mr. McManus is responsible for implementation of the MWRA's Industrial Pretreatment Program.
 MWRA currently regulates approximately 1,100 industrial and commercial dischargers in order to
 control the loadings of heavy metals and organic pollutants to MWRA's new treatment plant on Deer
 Island. TRAC also works with trade organizations, municipalities and other agencies to reduce toxics
 from a wide array of non-industrial sources such as hospitals, laboratories, photoprocessors, dental
 facilities and automotive facilities.

 Prior to coming to the MWRA in 1993, Mr. McManus worked for seven years with Metcalf and
 Eddy, Inc., managing the environmental compliance programs  for numerous private and public
 construction projects. He also  worked as General Manager for  Offshore Devices, Inc., a marine
 engineering firm specializing in the manufacture and use of offshore oil spill cleanup equipment.

 Mr. McManus has an undergraduate degree in Marine Policy from the University of Rhode Island,
 a Masters degree in Marine Resource Management from the University of Washington, and a Master
 of Business Administration degree from Boston University.


       New Strategies for Reducing Mercury Discharges from Health Care Facilities

The five-year MWRA/Hospital  Mercury Workgroup  is  a cooperative  effort  between  the
Massachusetts Water Resources Authority (MWRA) and Boston-area hospitals and medical facilities
to reduce the discharge of mercury-containing products from hospitals to the sewer system. This
workgroup identified mercury in many products that have commonly been used in hospitals and other
medical facilities, such as blood test reagents and cleaning products. The workgroup has actively
researched mercury-free alternatives to many of these products, and developed a mercury products
database which is available to area hospitals and other interested parties.
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The workgroup also:
•  Developed standards for replacing piping where mercury can accumulate over time;
•  Prepared guidance documents for industries detailing mercury compliance problems;
•  Assessed loadings of mercury from industrial dischargers in the MWR A sewer service area; and
•  Conducted pilot-scale testing of promising mercury pretreatment systems.

A key factor in gaining the cooperation of facilities in the workgroup was MWRA's Mercury Safe
Harbor Program. Under this program, MWRA will not escalate enforcement (beyond enforcement
orders) against companies that have non-compliant mercury discharges, provided  they actively
participate in the program and demonstrate progress in reducing their mercury discharges. Under this
program, the MWRA has divided its non-compliant mercury dischargers into two groups. Group 1
consists of sewer users whose discharge contains 0.004 mg/1 or less of mercury; Group 2 consists of
sewer users whose discharge contains more than 0.004 mg/1 of mercury. Facilities that operate outside
the safe harbor will be subject to escalating enforcement including monetary penalties.

To date, this cooperative effort has resulted in a significant decrease in mercury concentrations from
the facilities permitted by the MWRA in the metropolitan Boston region. The 29 major hospitals and
medical centers (representing 55 individual sampling locations) were a maj or source of mercury from
MWRA's permitted users. Since 1995,77% of these sampling locations have achieved compliance
(1 part per billion or less), and only 9% remain above 4 parts per billion on a consistent basis.
Average mercury discharge concentrations from these hospitals dropped from 22 ppb in 1994 to 2 ppb
in 1999.
                   Eliminating Non-Essential Mercury Uses

                                   Michael T. Bender
                                  Mercury Policy Project
                                     1420 North St.
                                  Montpelier, VT 05602
                        Phone: (802) 223-9000, Fax: (802) 223-7914
                                 MTBenderVT@aol.com
                              httt>://www.mercurvr>olicy. ors
                                   Michael T. Bender
Michael Bender is a consultant to the Mercury Policy Project, a small, nonprofit enterprise
dedicated to reducing human exposures to mercury and the virtual elimination of anthropogenic
mercury releases. The Project identifies strategic opportunities and works collaboratively with
business, government and nongovernment officials toward attaining its goals.
Michael has over 10 years experience in municipal hazardous waste management and has focused
on mercury for the past several. From 1995 to 1997, Michael worked to secure the release of the
Mercury Report to Congress and since then has provided input on the Universal Waste Rule and
the Mercury-Containing Lamps Rule, the New England Governors/Eastern Canadian Premiers

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Mercury Action Plan, the North American Regional Action Plan on Mercury and the Agency for
Toxics Substances and Disease Registry's mercury reference level.

Michael has a Bachelor of Arts in General Studies and a Masters of Science in Resource
Management and Administration from Antioch New England.
    Phasing Out Thermometers and Other Non-Essential Mercury-Containing Products

The top priority of federal, tribal and state waste hierarchies is source reduction, with special
attention paid to eliminating substances in products, like mercury, when they are found to present
some of the most profound risks to human health, wildlife and the environment. For mercury-
containing products, then, whenever viable, environmentally sound and cost-effective alternatives
are identified that contain no mercury, they should become the preference of government
procurement programs and strongly supported as the preferred societal choice.  For this to occur
effectively, non-essential mercury-containing products must be "virtually eliminated" over time
by phasing out their manufacture, import and sale. As an interim step, existing products should be
collected and properly managed to prevent the haphazard release of mercury indoors or into the
environment. There are currently a number of initiatives where both voluntary and mandatory
phase-outs of mercury-containing products are being carefully considered, developed or
implemented. This paper will present several case study examples.
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                                    Appendix C
           Panel Discussion Summary - Treatment and Disposal

  C.1   Introduction
  Two panel discussions were held during the workshop; the first addressed treatment and
  disposal of mercury-contaminated wastes and the second addressed prevention, collection, and
  elimination issues. Each panel discussion opened with an overview emphasizing key findings
  and issues presented during the workshop.  After each source panelist briefly discussed what he
  or she thought were the most critical and controversial issues, an open discussion period was
  initiated.  It was assumed that the issues discussed by the panelists and audience would be
  based on the list of questions and topics provided to workshop attendees prior to the workshop.
  The goal of the panel discussions was to work toward consensus on these critical issues.

  Panel A contained one facilitator and five panelists. There was a note-taker present to ensure
  the that the product of the discussions was captured. The focus of the panel and any questions
  provided to workshop attendees or panelists are included in the written summary generated for
  each panel session.

  C.2   Focus/Emphasis of Panel Discussion on Treatment and Disposal
  The purpose of the Panel Discussion on Treatment and Disposal was (a) to discuss the state of
  the art of mercury non-combustion treatment and disposal techniques for mercury wastes and
  stockpiles, and (b) to identify major research needs/directions required to meet the goal of
  bringing the state of technologies, or any other options, closer to environmentally safe
  (including in the long term), cost-effective treatment and disposal processes.

  C.3   Treatment and Disposal Panel Members
  Ben Blaney of U.S. EPA NRMRL was the panel moderator and Paul Kalb of Brookhaven
  National Laboratory,  Paul Lear of IT Corp., Ed Swain of Minnesota OEA, Greg Hulet of U.S.
  DOE/BBWXT Co., and Fred Charania of U.S. EPA OSW served as panelists.

  C.4   Questions/Topics for Treatment and Disposal Panel Discussion
  The panelists were asked to respond to two sets of questions in turn.

  Question A: State of the Art and Significant Advances.
  •      What are two or three accomplishments described in Session  A that may support
        significant advances in the state of the art in non-combustion  options for mercury
        waste/stockpile treatment and disposal techniques?
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.


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  •      Based on your general knowledge, how would you characterize the state of the art of
         non-combustion techniques for mercury treatment and disposal with respect to where
         we currently stand in meeting the goal stated above?

  Question B: Research Needs.
  •      What are three priority research areas you feel are most important to address so that we
         can make significant steps toward reaching the goal stated above?
  C.5    Summary of the Treatment and Disposal Panel
  C.5.1  Chair Comments
  Ben Blaney, U.S. EPA NRMRL

  C.5.2  Panel Member Comments
  Paul Kalb, Brookhaven National Laboratory
  Paul Kalb presented the following comments in response to Questions A and B.

         Regarding the State of the Art:

         Effective technologies exist. The state of the art is good from the perspective of where
         we are now. Effective technologies exist for treating mercury waste containing both
         less than and greater than 260 ppm mercury. These technologies are either currently
         commercially available or soon to be available. The available technologies are more
         similar than dissimilar in that they focus_on keeping mercury immobile or insoluble.

         Regarding Accomplishments Supporting Advances:

         •      Mercury sulfide. The mercury sulfide method of stabilization and disposal is
               significant because it essentially puts mercury back where it came from.
         •      Waste type. Recent technologies make a distinction between Resource
               Conservation and Recovery Act (RCRA) wastes and mixed waste mercury.
         •      Thermal desorption. Thermal desorption may be the  most sensible technology
               for mercury-contaminated soils because it can also deal with organics and other
               species.

  Paul Kalb described the following research needs for performance testing and measurement:

         Alternatives to the TCLP

         There is a need to identify alternatives to compensate for the  failings of the TCLP,
         which (a) only concentrates on one pH range, and is therefore not representative of
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.
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        long-term landfill conditions; (b) only provides a small duration snapshot (18 hours);
        (c) provides no mechanism information; and (d) has artificial particle size requirements.

        Durability of Solid Matrices

        There is a need for more data on the durability of solid matrices used to immobilize
        mercury in waste. We need to understand how the forms will hold up over time.

  Paul Lear, IT Corp.
  Paul Lear presented the following comments in response to Question B.

        Regarding the State of the Art:

        •      As good as it will get. There are many treatment and disposal options -
                amalgamation, stabilization, thermal treatments - that are almost commercially
                available. There is no "silver bullet" technology available, or likely to be
                identified; only incremental changes in technologies will occur from now on.
        •       Treatment determined by market and waste. The available technologies are
                similar, and for any given case, the best treatment and disposal option will be
                determined by the market and waste type.

        Regarding Accomplishments Supporting Advances:

        Formation of partnerships. The next step in advancing treatment and disposal will
        come from the formation of partnerships between waste generators, treaters, and
        regulators, and getting the available technologies out to the field.

  Paul Lear described the following research needs:

        Mercury Emissions from Landfills

        There is a need for additional research into mercury emissions from landfills to
        determine the potential for environmental impact from mercury waste after disposal.

        Shortcomings of TCLP

        There is a need for standardization, with the regulatory and scientific communities in
        agreement.  Standardization will increase confidence in the measurement results.

  Ed Swain, Minnesota OEA
  Ed Swain presented the following comments in response to Questions A and B.
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.

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         Regarding the State of the Art:

         Are the performance standards appropriate?  There is a tendency to draw lines, such as
         "insoluble" and "no offgassing" when referring to the treatment and disposal of
         mercury-contaminated wastes, but all of these terms are measures of degree.  Just
         because a waste can pass the Toxicity Characteristic Leaching Procedure (TCLP) does
         not mean it's environmentally benign, so we need to think of the bigger picture, the
         total mercury mass in the atmosphere. If all waste is treated, how much mercury will
         join the global or regional pool?

  Ed Swain described the following research needs:

         Durable long-term storage

         There is a need for further research into durable long-term storage forms for sulfides
         and matrices.

         Durable short-term storage

         There is a need for further research into durable short-term stockpile storage options for
         elemental mercury.

         International Technology Transfer

         There is a need for technology transfer to other countries to prevent them from making
         the same mistakes as the U.S.. Ed Swain suggested an international policy forum to
         discuss reduction of mercury use and consumption, and the provision of international
         incentives to reduce mercury use and pollution.

  Greg Hulet, U.S. DOE/BBWXT Co.
  Greg Hulet presented the following comments in response to Questions A and B.

         Regarding the State of the Art:

         There are problems that must be addressed. There are some problems in the current
         state of the art. Metal amalgams have a vapor pressure similar to elemental mercury, so
         there are questions about the long-term stability and potential for vapor release of this
         disposal solution.  There are questions about the long-term performance of
         macroencapsulation methods and materials. While stabilization appears to meet the
         disposal standards, it is unknown what happens under real landfill conditions with
         changing pH.
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.

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         Regarding Accomplishments Supporting Advances:

         •      Electrochemical processes. Progress in developing electrochemical processes,
               which could have many future applications, would be welcome. This
               technology could be improved or modified for DOE use.
         •      SAMMS material. The newly engineered S AMMS material, which may be
               useable as a drop-in replacement for ion-exchange, appears to have potential.
  Greg Hulet described the following research needs:

         Non-Intrusive Mercury Measurement

         There is a need to develop a non-intrusive method for measuring or identifying mercury
         in waste or matrix.  Non-intrusive identification of mercury will allow easier
         identification and disposal of non-mercury wastes.

         Transmutation of Radionuclides

         There is a need for further research into the transmutation of radionuclides to discover
         how we can better identify and treat mercury and mercury wastes.

         Long-term Performance of Disposal Options

         There is a need for further research into the long-term performance of amalgamation
         and macroencapsulation.
  Fred Charania, U.S. EPA OSW
  Fred Charania presented the following comments in response to Question B.

        Regarding the State of the Art:

        The paradigm is changing.  The legal standard is 'minimize threat to human health and
        the environment', and recent technological advances allow us to address this more
        effectively than in the past.
        •      Minimizing the threat means considering multimedia issues, such as offgassing
               and leaching. We must think of the long-term issues, because a waste passing
               TCLP to go to a landfill is not sufficiently protective. The effects of pH in
               landfills have not been fully examined to determine the true safety of disposal.
        •      We need to address mixtures of organics and mercury together.- Is there a
               treatment train that should be designated as the Best Demonstrated Available
               Technology (BOAT)?
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.

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         •      Little data were received when the Advanced Notice of Proposed Rulemaking
               (ANPRM) was issued, but data are expected within the next 6 months. Research
               is a occurring, and data on treatment processes are needed and wanted. The data
               should be incorporated in the rulemaking docket so the designation of a BDAT
               can be examined.Fred Charania described the following research needs:

         Characterization of Hazardous Waste Stream

         There is a need for economic and characterization information on the hazardous waste
         stream. While Municipal Solid Waste (MSW) is well characterized, hazardous waste
         codes such as D009 yield little information about the waste. More information
         regarding the waste will enable more efficient recycling, treatment, and disposal.

         Treatment of Commingled Waste

         There is a need for further research on the treatment of commingled organics and
         mercury. Can there be an effective treatment train identified and designated as the
         BDAT?

         Effects of pH on Storage and Disposal

         There is a need for further research on the effects of pH on storage and disposal of
         mercury wastes. Previous testing has assumed a constant pH, which may not be
         accurate under real storage and disposal conditions, such as a landfill. It must be
         determined whether fluctuations in pH will reduce the suitability of some storage and
         disposal technologies.

  C.5.3  Open Discussion
         Deep Geological Repository for Mercury Wastes

         Should we be considering utilizing deep  disposal for mercury wastes? Is this a better
         option than surface disposal?
         •      Deep geological repositories are currently being used in Europe. Mercury
               wastes are sent down old mines.
         •      There may be a need to segregate wastes before disposal.  A dedicated
               repository (mercury wastes segregated from other waste streams) would prevent
               co-disposal problems.
         •      If the current problems with surface disposal can be solved, surface disposal
               may be preferable to deep disposal because landfills can be monitored. Deep
               disposed wastes  are difficult to monitor and cannot be moved if they begin to
               present environmental problems.
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.

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         •      Deep disposal may be preferable to surface disposal, because of the greater
                potential for exposure from surface disposal. Long-term geological issues such
                as landfill cracking may also make deep disposal more desirable.
         •      Mercury from deep geological repositories may find a way back to the surface in
                natural gas and oil. There is a paper in Environmental Progress on this issue by
                Dr. Wilhelm.

         Mercury in Landfills

         Are landfills a feasible long-term option for mercury wastes? If not, what should be
         done about mercury wastes previously disposed of in landfills?
         •      Mercury-related environmental issues from landfills may be air emissions,
                rather than leachate.
         •      Mercury air emissions from landfills are a only minor problem. Without a
                carrier gas, such as methane, slow diffusion of mercury would occur rather than
                air emissions.
         •      There are bacteria in municipal solid waste (MSW) which may create methyl
                mercury, introducing a major pathway for human exposure as it bioaccumulates
                in fish.
         •      There are long-term geological issues with landfill disposal of hazardous wastes,
                such as landfill cracking.
         •      If deep disposal becomes the favored option, should previously surface-disposed
                mercury wastes be mined from landfills? There is little data regarding mercury
                in leachate from landfills, so it is not known if previously landfilled wastes will
                be a problem in the future.
         •      Because of the chlor-alkali facilities closing and the Department of Defense
                (DOD) eliminating stockpile, handling of existing mercury and mercury waste
                will take precedence over landfill mining for the foreseeable future, unless
                landfill leachate begins to pose an environmental hazard.

         Stockpile Elimination Effect on Mercury Supply and Demand

         The long-term effects of stockpile reduction, recycling, and mercury mining should be
         analyzed to ensure a proper balance between mercury supply and demand. If the
         stockpile is eliminated, will we need to mine more mercury to meet demand?
         •      Secondary and byproduct mercury production meets the current demand. As
                long as we mine materials that coexist with mercury and have mercury
                recycling, there will always be a plentiful supply of mercury for domestic needs.
                The secondary production in the U.S. almost meets the current demand.
         •      Some of the stockpile should be reserved as a cushion for the market and future
                needs, but the majority should be eliminated.
Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.

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                      •      Mercury retorters say there is a market for their recycled mercury.  If there is a
                             market and use for the product, why remove the product using questionable
                             treatment and disposal techniques?
                      •      The public wants mercury to be retired rather than recycled for future use. We
                             need to convey that recycling mercury reduces the amount mined.
                      •      As mercury use by the chlor-alkali industry is being reduced (it agreed to reduce
                             mercury use by 80%), decommissioned mercury will add greatly to the market
                             supply.
                      •      Mercury recovery doesn't necessarily mean recycling.  Recovered mercury
                             could be stored rather than put into use.
                      •      The government  used to subsidize mercury mining. Perhaps the government
                             should buy back the mercury to stockpile and dispose.
                      •      Congress should  limit the uses of mercury by law to encourage alternatives.
                             There is currently no economic incentive to use mercury alternatives.

                      Mercury in Wastewater and Direct Discharge

                      What is the best technology to identify and reduce mercury in wastewater and direct
                      discharge?
                      •      In the Great Lakes, mercury in water can be quantified at 1.0 ng/ml.
                      •      There is no treatment option to the direct discharge level.
                      •      The treatment technologies presented have not been geared toward wastewater
                             treatment, but there are other technologies available.
                      •      Getting mercury down to ppt levels is difficult, and treatment to that level is
                             unreliable.  The form of the mercury makes a difference in its treatability.
                      •      Rather than concentrating on treatment of wastewater, we should focus on
                             source reduction, which has greater potential for reducing mercury to acceptable
                             levels in the long-term.

                      Temporary-/Short-Term  Storage for Mercury Wastes and Stockpiles

                      Has short-term storage been considered for the decommissioned mercury stockpile?
                      •      The stockpile is still in the hands of DOD. Additional short-term storage has
                             not been considered because existing short-term mercury storage is not suitable.
                      •      Short-term storage of mercury could be used as a method to regulate the market.
                             To assess the usefulness of short-term storage as a market regulator, we need
                             more information on the economics, future use projects, and supply of mercury.
                      •      The 90-day rule is limited to generator waste and RCRA sites. Elemental
                             mercury that can  be used as  a product may not be classifiable as a waste.
             Note:  Statements captured in the panel discussion are those of participants, not necessarily EPA.

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  Formerly Contaminated Sites

         Mercury production or use sites exist around the world. What should be done with
         formerly contaminated production sites?
         •      No participants were aware of any of international reclamation efforts.
         •      Mercury cell plants abroad are often converted for alternative uses rather than
               cleaned.

         Improve Material Collection

         Collection of mercury waste materials could be improved to reduce emissions and
         facilitate recycling.

         Research and Development

         Research and development will not take place in a vacuum; we must create a demand
         for it.  Enforcement of mercury cleanup regulations would create a market for the new
         technologies that research and development would bring. Enforcement will lead to
         market demand, which leads to research and development, which leads to better
         cleanup, treatment, and disposal.

         Lessons Learned

         All of the problems being addressed at this conference are identical or similar to those
         addressed in the past for nuclear waste. We should take care to follow the lessons
         learned from those efforts to avoid making the same mistakes.

         Applicability of Treatment Technologies

         There is currently no one technology which can address all matrix types with significant
         volumes of waste. We need to focus on getting technologies to work together in a
         treatment train.  The available technologies will always need tweaking based on the
         type of waste needing treatment. There will never be one technology or approach for all
         waste streams.  Know what you're treating and verify the performance of your treatment
         technology.

  Additional Research Needs. Members of the audience contributed suggestions.

         •      Characterization of mercury in sediments and research into ecological impacts.
         •      Methods for faster, cheaper, and better characterization and cleanup, especially
               non-intrusive characterization.
         •      Mercury in the presence of radionuclides.

Note: Statements captured in the panel discussion are those of participants, not necessarily EPA.

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                Separation of mercury from matrices without the use of thermal processes.
                Chemical-based separation would allow wastes to be incinerated.
                Long-term durability of waste forms in surface storage. Disposal conditions
                must be reducing, not oxidizing.
Note:  Statements captured in the panel discussion are those of participants, not necessarily EPA.

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                                  Appendix D
Panel Discussion Summary - Prevention, Collection, and Elimination

D.1    Introduction
Two panel discussions were held during the workshop; the first addressed treatment and
disposal of mercury-contaminated wastes and the second addressed prevention, collection, and
elimination issues. Each panel discussion opened with an overview emphasizing key findings
and issues presented during the workshop. After each source panelist briefly discussed what he
or she thought were the most critical and controversial issues, an open discussion period was
initiated. It was assumed that the issues discussed by the panelists and audience would be
based on the list of questions and topics provided to workshop attendees prior to the workshop.
The goal of the panel discussions was to work toward consensus  on these critical issues.

Panel B contained two facilitators and five panelists. There was  a note-taker present to ensure
the that the product of the discussions was captured. The focus of the panel and any questions
provided to workshop attendees or panelists are included in the written summary generated for
each panel session.

D.2    Focus/Emphasis of the Panel Discussion on Prevention, Collection, and
       Elimination
The Panel Discussion on Prevention, Collection, and Elimination focused on the need to reduce
the amount of mercury entering the waste stream through improved pollution prevention
techniques, waste collection methods, and source reduction.

D.3    Prevention, Collection, and Elimination Panel Members
Doug Grosse and Jon Herrmann of U.S. EPA ORD were the panel moderators, and Alexis Cain
of U.S. EPA Region V, John Gilkeson of Minnesota OEA, George Gissel of Vulcan
Chemicals, Edward Weiler of U.S. EPA OPPT, and Jane Williams of California Communities
Against Toxics served as panelists.

D.4    Question/Topics for the Panel Discussion on Prevention, Collection, and
       Elimination
1.     What are the two or three most important insights you want to convey to the audience
       regarding the management of mercury from non-combustion issues?

2.     What are the two or three most critical/essential efforts that need to be undertaken to
       prevent, eliminate, treat, or dispose of mercury from non-combustion sources?

3.     Name two or three data gaps or information needs for mercury risk management from
       non-combustion sources.
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 4.
Prioritize the two or three most important research needs for managing risks from non-
combustion sources of mercury.
 D.5    Summary of the Panel Discussion on Prevention, Collection, and
        Elimination
 D.5.1  Chair Comments
 Doug Grosse introduced the facilitated panel discussion on prevention, collection, and
 elimination issues (Panel B). He emphasized that ORD is interested in the thoughts, ideas, and
 suggestions of the workshop, participants.

 D.5.2  Panel Member Comments
 Alexis Cain, USEPA Region V
 Alexis Cain described the following research needs:

       Division of Mercury Sources by Deliberate Use and Trace Contamination of Raw
       Materials

       Alexis Cain felt that although the Workshop's division of mercury sources by
       combustion and noncombustion sources is useful, categorizing mercury sources by
       emissions related to the deliberate use mercury and the emissions that are related to the
       contamination of raw materials  with trace amounts of mercury is also informative
       because it:

       •      Avoids the confusion of equating combustion emissions with only coal-fired
              utility emissions. As currently defined by EPA, combustion sources include
              incinerators. Incinerators, however, do not make mercury, but receive mercury
              from mercury-containing wastes as a result of mercury use in products.
       •      Evens the division of mercury sources.  If emissions are categorized on a
              deliberate use basis, use-related emissions are about 50% of total emissions;
              when categorized on a combustion basis, combustion-related emissions
              constitute about 90% of  total emissions.
       •      Improves consideration of life cycle emissions. Since incinerator emissions
              represent the end of a product's life cycle, this method of division makes it
              easier to look at different points along a product's life cycle to assess
              opportunities to control mercury emissions.

       Life Cycle Emissions by Product Type

       Alexis Cain contended that there is an inadequate understanding of life cycle emissions
by product type.  He explained that this  research can help prioritize mercury collection efforts.

       There are some data on mercury emissions from mercury-containing products, although
       these estimates do not seem to be based on actual measurements. There are better data
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        from incinerators, but these data could also be improved. However, he contends that
        there is a paucity of data regarding emissions estimates from some of the other phases
>        of the mercury product life cycle, in particular:

        •      Accidental emissions that occur during product use.
        •      Emissions associated with collecting, processing, storage, and transport of
              wastes prior to incineration.
        •      Emissions that occur from landfills, particularly the working faces of landfills.
        6      Mercury emissions from the use of metal scrap, For example, emissions from
              mercury switches placed in automobiles are currently not accounted for in EPA
              emissions estimates, though  these emissions could be  significant.

        Increase Focus on Prevention Opportunities

        Currently cost effectiveness data are based on cost effectiveness per mass of mercury
        collected rather than on the prevention of mercury releases. Alexis Cain would like to
        see more emphasis on the following areas for prevention efforts:

        •      Auto industry.  There should be more research on this sector because most of
              the mercury associated with automobiles is ultimately released into the
              environment.
        •      Electrical Switches. Alexis Cain cites data presented by Bruce Lawrence
              (Bethlehem Apparatus Company) in the plenary session that electrical products,
              particularly mercury relays in capital equipment, are now the largest user of
              mercury in the U.S. (even more than the chlor-alkali industry) - now estimated
              at 110 tons per year. Moreover, mercury use in electrical switches has not
              decreased over the past 20 years.

        Pursue Voluntary Efforts

        Although voluntary efforts are not always effective, Alexis Cain states that it does not
        hurt to try, and his experience with the chlor-alkali industry shows that voluntary efforts
        can yield positive results.

 George Gissel, Vulcan Chemicals
 George Gissel looks to the first two questions (questions  a and b) as supporting a practical
 approach to mercury management and control and the second two questions (questions c and d)
 as addressing the longer range issues.
                                          83

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Questions (a) and (b)

George Gissel stressed that the guides to answering the first two questions are
cooperation and achievable goals.

•      Cooperation. Cooperation is key on two fronts:
       Cooperation within the chlor-alkali industry. The chlor-alkali industry realized
       that some plants are better at mercury control than others, and they can all learn
       from each other without engaging in uncompetitive practices.
       Cooperation with their respective state agencies and the EPA. By working with
       regulators toward a common goal of regulations that reduce mercury, both
       parties can maximize their limited  resources.
•      Achievable Goals.  The chlor-alkali industry has publically committed to a goal
       of a 50% reduction in mercury use (using a 1990-95 baseline) by 2005. A few
       companies, including Vulcan Chemicals, have set a goal of a 50% mercury
       consumption reduction based on a  1999 baseline. The industry intends to
       achieve these goals through cooperation. All plants are on track to achieving
       their goals.

Members of the chlor-alkali industry have worked together to address the following
issues:

•      Mercury in sodium hydroxide. The chlor-alkali industry's mercury in sodium
       hydroxide task group is about to release a draft publication that details the best
       thinking available on minimizing mercury in sodium hydroxide.
•      Mercury health issues.  The chlor-alkali industry has also convened a mercury
       health issues task group that has looked into guaranteeing that the best science is
       used to ensure worker safety at chlor-alkali facilities.
•      Mercury balance. George Gissel stated that his company has assessed its
       mercury balance  since 1973. Other chlor-alkali companies have looked toward
       Vulcan Chemicals to assist them in establishing a mercury balance. Vulcan
       Chemicals has given seminars to the chlor-alkali industry about mercury
       balance, as well as a seminar to the EPA in Boston.  Through a multi-year
       examination of mercury consumption and purchasing, a facility can gain a better
       understanding of minimizing mercury consumption and losses.
•      Cross-plant/cross-industry sharing for continuous improvement. The chlor-
       alkali industry formed the Mercury Control Task Group to identify the best
       industry practices.  This task group has produced two in-plant technology
       exchange workshops in 1999; it has a third workshop planned for 2000.  These
       workshops provide detailed descriptions on using specific technologies.
                                  84

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      The chlor-alkali industry has worked with the EPA to address the following issues:

      •      Measuring cell room fugitive emissions. The chlor-alkali industry formed a
             mercury emissions measurement task group to work with the EPA toward a
             common goal of measuring cell room fugitive emissions. The EPA at Research
             Triangle Park (RTF) developed the protocol. Testing is now underway at the
             Olin Corporation's Augusta, Georgia, facility.  The Chlorine Institute covered
             the out-of-pocket costs of Olin Corporation and the EPA is underwriting the
             cost of the equipment and measurements.
      •      Revising National Emissions Standards for Hazardous Air Pollutants
             (NESHAP) regulations.  The EPA worked with the chlor-alkali industry revising
             the NESHAP regulations.  They are conducting multi-day observations at five
             facilities owned by four companies.

      Questions (c) and (d)

      George Gissel emphasized that the key to addressing the final two questions is
      continued consistency from the regulatory community so it can prepare for the future.
      In particular, he would like to strive toward:

      •      Achievable levels of mercury in products.  Total elimination is not practical
             because it is now possible to measure mercury to the parts per trillion level. A
             risk-based approach to determining an acceptable and achievable level of
             mercury is more practical.
      •      EPA and  industry consensus on regulations. In the early 1990s, the EPA
             required the chlor-alkali industry to install thermal recovery units. After the
             chlor-alkali industry has spent in excess of $15 million, the EPA is rethinking
             that policy.
Edward Weiler discussed following issues:
       Final Disposition of Collected Mercury

       Edward Weiler contended that there is a lack of understanding of the final disposition
       of mercury. As more mercury-containing products are recovered through take-back
       programs, there will be an increasing need to dispose of that mercury.

       •      Emissions from mercury collection. There are likely to be significant emissions
              from collection efforts, such as those resulting from accidents, and EPA should
              potentially rethink Best Demonstrated Available Technology (BDAT)
              regulations.

       •      Alternative disposal technologies. EPA must encourage the development of
              alternative mercury disposal technologies. EPA should work with industry to
              verify alternative technologies.

                                         85

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 •      Business side of mercury problem. Currently it is difficult to raise the
       investment capital necessary to establish companies that develop alternative
       disposal technologies.

 Virtual Elimination of Mercury Requires Private Sector Cooperation

 Edward Weiler noted that previous discussions during the Workshop concluded that
 new regulations restricting mercury use are not likely. Therefore, if mercury is to be
 removed from the marketplace, government must work closely with the private sector.
 The challenge is to create positive incentive structures that can encourage the private
 sector to make a business of phasing out mercury use, both in terms of developing
 alternative disposal technologies and developing chemical substitutes (such as
 NewMerc).  It is difficult to make inroads with a new technology or alternative
 chemical substitute in the absence of a regulatory hammer.

 Mercury as a Consumer Products Safety Issue

 Mercury can be thought of as a consumer products safety issue where it exists in small
 amounts, such as in thermometers  and electronic displays. Edward Weiler cited an
 earlier Workshop discussion that the most common call to poison hotlines dealt with
 broken mercury fever thermometers. Although thermometers and electronic displays
 represent a small percentage of mercury emissions (especially when compared with
 utility coal emissions), nonetheless they represent a risk. Perhaps an entity like-the
 Consumer Products Safety Commission could be used to address the mercury safety
 issue.
Critical Efforts

Edward Weiler concluded with the following critical efforts:

       Encourage Office of Solid Waste (OSW) efforts. The EPA should support OSW
       in researching alternative disposal technologies.
•      Enhance technology development and verification programs. To enhance
       technology development and verification of alternative mercury technologies,
       the EPA should look at complementarity between ORD's Small Business
       Innovative Research (SBIR) program and Environmental Technology
       Verification (ETV) program.
•      Support Environmentally preferable purchasing. Use the power of the federal
       procurement dollar toward environmentally preferable purchasing.

•      International mercury flows. The EPA should support efforts to measure
       international flows of mercury. Edward Weiler was particularly struck by the
       magnitude of the international flows.  Characterizing the international flows are
                                  86

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              critical to describing background mercury levels.

John Gilkeson, Minnesota OEA
       John Gilkeson stated that as a state representative,, he feels that it is important to collect
       the mercury-containing products before they are found in wastes and wastewaters.
       Once mercury is in solid wastes and wastewaters, it is difficult to control and is often
       released in the environment, especially since Minnesota incinerates most of its wastes.

       John Gilkeson discussed the following issues:

       Categorization. The Northeast Model legislation proposes the following categorization
       scheme:
             Product with elemental mercury
             Product with compounds and chemicals
             Processes
             Waste streams of the three above areas of deliberate use
             Non-combustion incidental releases, including refining, mining, and cement and
             limestone production
      Hierarchy of Actions for Mercury Control.

      •      Identification of existing uses, sales, and product lines
      •      Separation from uses and separation from wastes
      0      Collection and retirement of mercury wastes
      •      Substitution and elimination of mercury in the future

      Model Program for Product Lines and Activities To Be Implemented at the State or
      Local Level

      A model program provides consistency in implementing mercury control efforts.

      Prioritization of Mercury Issues

      MN OEA prioritizes its mercury issues on the following basis:

      •      Feasibility
      •      Effectiveness
      8      Quantity
      •      Available information
      •      Existing working relationship with protected parties and sectors
      •      Opportunities that might arise

      Categories of Mercury Issues.
                                        87

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                            "Big easy"
                            "Little easy"
                            "Big difficult"
                            "Little difficult"
                     •       Unknown

                     "Difficult" is based on cost, practicality, infrastructure, or level of information.
                     Information Gaps

                     John Gilkeson identified the following information gaps:

                     •      Control measures for "big difficult" issues such as coal
                     •      The search for a non-mercury dental restorative for dental amalgams
                     •      Cleanup of wastewater treatment plant infrastructure. Mercury is found in
                           hundreds of miles of pipes within buildings and underground
                     •      Mercury found in refineries
                     •      Mercury found in land application of biosolids
                     •      Mercury presence in drugs

              Jane Williams, California Communities Against Toxics
              Jane Williams reiterated that mercury is a serious threat to the environment. She asked the
              Workshop to visualize a "mercury-free future."

                     Key Points

                     Jane Williams began her discussion by describing the need for a new paradigm for
                     dealing with mercury:

                     •      National and international implications. The international implications of the
                           mercury issues such as mercury deposition  over the Pacific Ocean should spur
                           us to look at mercury problems in a more holistic way. The U.S. should adopt a
                           "clean hands" policy (developed by the New England Governor's Mercury
                           Action Plan) because even if all mercury emissions ended in the U.S., we would
                           still have a significant mercury problem.
                     •      Mercury in consumer products should be phased out. The intentional use of
                           mercury in consumer products should eventually be phased out, including
                           mercury in lamps.

                     •      No new mercury should be introduced in commerce. An important step in this
                           direction was the cessation of sales of the national mercury stockpile in the early
                           1990s. Mercury trade should not be shifted to other countries, particularly
                           Mexico.
                                                       88
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 •      Mercury education and awareness is key. It would be difficult to develop the
       political consensus necessary to deal with mercury issues until government,
       industry, and the public acknowledge that mercury is a serious problem. Public
       education is key to raising this consensus.

 Interesting Effort

 Jane Williams discussed the following interesting effort:

 Mercury-free procurement/buildings by government.  It is important for the
 government to become a models of mercury-free thinking to set an example for the
 public and industry.

 Important Scientific Questions

 Jane Williams identified the following critical scientific questions:

 •      Extent of mercury contamination in ocean fish. The Food and Drug
       Administration (FDA) has ceased testing the most common ocean fish; as a
       result mercury exposures and risks to the public are uncertain.

 •      Educating the public about mercury exposures. Although most of this
       Workshop has focused on emissions rather than on exposures, educating the
       public on exposures is critical.  Jane Williams also referred to the fact that over
       90% of the calls to a poison control center of a certain state was for broken fever
       thermometers, and while most people may know that there is mercury in their
       thermometers, they may not be aware of the mercury in their thermostats or cars.
       Once the public understands the ubiquity and risks of mercury in the   ,
       environment, ultimately the mercury problem may be handled like the tobacco
       problem.

•      Mercury retirement.  It is increasingly apparent that an "end-game" for mercury
       must be devised for retiring mercury. The EPA should work with the
       Department of Energy (DOE) and Department of Defense (DOD) to devise
       mercury stabilization technologies. Eventually, all of the mercury in circulation
       needs to be pulled out and sequestered from the biosphere — and like the nuclear
       waste debate, this could become a politically painful experience,
                                  89

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D.5.3  Open Discussion
       Phase-out of Chlor-alkali Mercury Cell Process

       Luke Trip (Environment Canada) asked George Gissel whether the chlor-alkali industry
       in the U.S. planned to phase out the mercury cell process.

       George Gissel responded that various countries have phased out or are planning to
       phase out the mercury cell process. Japan phased out the mercury dell process in 1985,
       and Europe is discussing a 2005 or 2010 phase-out.

       Although the U.S. chlor-alkali industry has not been informed of a phase-out in the
       U.S., he said that it would work with the EPA if asked to do so.  However, George
       Gissel stated that any phase-out needs to be well-planned and a cooperative venture
       between the government and industry. An abrupt phase-out could have unintended
       consequences.  For example, any disruption in alkali production could force alkali
       prices to rise and spur increases in production elsewhere in the world, such as Mexico,
       where chlor-alkali facilities are subject to less stringent environmental regulations.

       Chlor-alkali Mass Balance

       Peter Berglund (Metropolitan Environmental Services, MN) asked George Gissel how
       the chlor-alkali industry measures its mercury mass balance.

       George Gissel responded that a mercury mass balance at a chlor-alkali facility is not a
       simple case of input minus output equals losses because there are internal inventory
       points that change on a continuous basis.

       Mercury Concentration in Caustic Soda

       Peter Berglund noted that an appropriate goal to achieve for mercury concentrations in
       caustic would be the caustic from a non-mercury cell chlor-alkali facility.

       Gatekeeper for Consumer Products

       Lester Gress (CFS Environmental) asked that if EPA's hazardous  waste listing
       determination is the gatekeeper for industrial hazardous waste, where is the gatekeeper
       for consumer hazardous material?  If a gatekeeper were in place, there would some
       consistency in how regulations treat industry as well as the consumer. For example,
       there is no gatekeeper controlling the mercury found in Drano.

       John Gilkeson stated that Minnesota has a gatekeeper in its regulations that prohibit
       mercury disposal in its solid wastes and wastewaters, where solid  wastes include
       construction and demolition (C and D) wastes, non-hazardous industrial wastes, etc.
                                         90

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He added that they are enforcing these regulations on contractors who do not remove
mercury from buildings prior to demolition.

Ed Weiler responded that the logical gatekeeper would be TSCA, but notes that nobody
would be willing to go down that road.

With regard to mercury use in consumer products, Anita Cummings (OSW) cited
research on recent patent records that finds that there are patented products that still use
mercury.  EPA is not certain whether these products are being manufactured, but she
feels that these products should be tracked. John Gilkeson added that his office had
done a patent search of the 1970s and 1980s and uncovered thousands of patents that
used mercury.

Local Actions Are Important

John Ackerman (U.S. EPA Region IV) stated that although mercury is a global concern,
local releases matter, and local efforts do pay off. There is increasing evidence that
local waste incineration and releases are all part of the problem.

Mercury Speciation Is Key

John Ackerman also pointed out that the mercury species is critical to understanding
mercury risks. The water soluble Hg (2+) ionic form of mercury is particularly
dangerous because it quickly becomes biomagnified. Elemental mercury is also
dangerous, but in the near term it  does not bioaccumulate. There is a need for speciated
data on mercury releases, and therefore there is also a need for better tools  to measure
mercury. More research needs to be done to make the standard methods and equivalent
methods viable tools.

Middle-level Handling of Mercury

John Ackerman raised the issue of regulating middle level handling of mercury.
Currently, industries that collect mercury-containing items such as thermostats and
thermometers are not regulated. The government needs to ensure that this  industry is
economically viable and not releasing mercury into the environment. Permitting and
regulating for this industry should be done at the local level. These industries typically
do not fit in the standard categories.

John Gilkeson stated that Minnesota does regulate collectors under the universal
hazardous waste rule and feels they have good oversight of their activities.

Edward Weiler thought that most states probably do  not have an answer like
Minnesota's, and he feels that there is not much on the federal level either.
                                  91

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       Alexis Cain added that EPA received a petition from the Edison Electric Institute to add
all mercury-containing devices to the Universal Waste Rule to help it better manage its
mercury-containing devices. Utilities also use mercury instruments such as temperature and
pressure sensors within their processes. EPA has not yet acted on this petition.

       Fate of Amalgam in Sludges

       Peter Berglund stated that the fate of amalgams in sludges is a data gap. Sludge is
       either incinerated and the mercury released to the atmosphere or applied to land. This
       may be an appropriate research area for the Water Environment Research Foundation
       (WERF).

       Alexis Cain added that University of Illinois research indicates that there is a
       considerable amount of mercury that is not in the amalgam form, but as soluble mercury
       in the amalgam wastewater.

       Mercury Levels in Common Consumer Products

       An audience member from the Northeast Region cited a study completed by the
       Hampton Roads Sanitation District that found mercury in common household consumer
       products. For example:
             Toothpaste
             Deodorant
             Soap
             Laundry detergent
             Kool Aid
             Mountain Dew
3.8 parts per billion (ppb)
1.35 ppb
25 ppb
2.4 ppb
6 ppb
158 parts per trillion (ppt)
       He added that domestic sewage now contains 100 ppt background levels of mercury.
       He contends that the EPA or FDA needs to begin a regular program of testing these
       products for mercury.

       Jane Williams responded by stating that she has worked on similar issues with leaded
       wick candles. She stated that the FDA seems not to be concerned with consumer
       ingestion of mercury based on its track record on fish testing. She suggests raising this
       issue with the Consumer Products Safety Commission, reiterating her call for public
       education and awareness.

       An audience member (Judy Schoefen) said that she would be happy to work with Jane
       Williams to help raise this subject at the next New England Governor's Mercury Task
       Force Meeting.
                                        92

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 Dental Amalgam Health Concerns

 Freya Koss (DAMS, Dental Amalgam Mercury Syndrome) asked why the EPA was
 funding a National Academy of Sciences (NAS) study to determine a safe level of
 mercury when there is no safe level of mercury exposure.

 Freya Koss also added that there is not enough awareness about the hazard of mercury
 exposure from dental amalgams.  For example, she cited an ongoing National mstitute
 of Health (NIH) study that is putting amalgams into children and testing for
 neurological damage - a clear violation of the Nuremberg Convention.  She calls for a
 meeting with the EPA and FDA to discuss the hazards of dental amalgams.

 Jane Williams stated that the NAS study was mandated by Congress to review the
 methyl-mercury reference dose. She also added that EPA does not regulate consumer
 products such as dental amalgams. Jane Williams said that she also shares many of the
 questioner's concerns with dental amalgams. Although she noted that a scientific
 consensus on dental amalgams has not yet been reached, there clearly is a sub-
 population that is more sensitive to mercury exposure. She added that Canadian efforts
 to restrict dental amalgam use is a step in the right direction.

 Alexis Cain said that establishing a reference dose for methyl-mercury is not an
 irrelevant question because mercury exists naturally, and we would have background
 levels of mercury even if there were no anthropogenic sources of mercury.

 John Gilkeson noted that the NJH study is being conducted at the University of
 Rochester. He also stated that the Agency for Toxic Substances and Disease Registry's
 (ATSDR's) toxic profile on mercury estimates of the average exposure to dental
 amalgams overlaps the range of concern for adults.

 Ann Ferreira (DAMS) asked, as a person with high sensitivity to mercury, if the EPA
 had a website listing products that contained high mercury concentrations.

 Jane Williams told her that a list is available at www.mercurypolicy.org.

 Folke Dorgelo (Netherlands Ministry for Housing, Spatial Planning and Environment)
 asked if there is a possibility that the NAS study could show that there is no safe level
 of mercury, meaning that even background levels of mercury levels are not safe.

 Conference Proceedings

J^ester Gress asked if there will be conference proceedings or a press release to the
public.

Doug Grosse responded that there will be proceedings.
                                  93

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Viewing Mercury as a North American Problem

Luke Trip, as a the Chair of the Mercury Task Force for the North American Regional
Action Committee, expressed concern over mercury control efforts in Mexico.  There is
currently neither mercury monitoring nor a mercury inventory in Mexico. Now Mexico
is building its first large coal-fired utility plant. Mexican environmental officials have
just become aware that they have three mercury cell chlor-alkali facilities. Luke Trip
urges "clean hands" across North America.

John Gilkeson commented that if Mexico is to address its mercury issues, the U.S. and
Canada will have to directly fund staff time to make that happen.  Mexico faces
incredible barriers.

George Gissel noted that the Chlorine Institute and Eurochlor are working with their
Mexican counterparts to raise their level of concern toward mercury issues as well as
raise plant performance efficiencies. He also reiterated that an unintended consequence
of a rapid shutdown of mercury cell plants in the U.S. could be a demand for caustic
from mercury cell plants in foreign countries with few environmental controls.  It takes
5 years  to bring up capacity from a plant closure.
                                  94

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  Appendix E
List of Attendees
      95

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           Workshop on Mercury Products, Processes,  Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                         LIST OF
 Paul W. Abernathy
           OFFICE:  707-942-2197
             FAX:  707-942-2198
_ abemath@napanet.net
Association of Lighting and Mercury Recyclers
   2436 Foothill Boulevard
   Calistoga, CA 94515   USA
 John Ackermann
           OFFICE: 404-562-9063
             FAX:  404-562-9019
US EPA Region 4
   61 Forsyth Street, SW
   Atlanta, GA 30303-8960
      USA
 Anthony Armentani
           OFFICE:  215-697-5028
             FAX:  215-697-9093
	aarmentani@dscp. dla.mil
Defense Supply Center Philadelphia
   700 Robbins Avenue
   ATTN: DSCP-IFB, Building #3C
   Philadelphia, PA 19111-5096   USA
 Marc Audet
           OFFICE:  506-684-6171
              FAX:  506-684-5979
            maaudet@piona. com
PCI Chemicals Canada Inc.
   . 600 Quenn Street
    Dalhousie
    New Brunswick, ESN 3S9
      CANADA
 Dominique B. Auigur
            OFFICE:  410-436-7958
              FAX:  410-436-5237
USACHPPM (Ctr. for Health Promotion & Preventive Medicine)
   1677BlackhawkRd.
   Aberdeen Proving Ground, MD 21010  USA
            dominlque.aulgur@apg.amedd.army.mil
 Kjell Avergren
           OFFICE: 46-302-32-679
              FAX:  46-70-203-4579
	kjell.avergren@swipnet.se
The Dog Training
   Madenvagen 7
   FLODA,  s-44891
SWEDEN
 Mike Bahorsky
           OFFICE: 540-562-6749
              FAX:  540-562-6725
	msbahorsky@deq.state. va. us
VA. Dept. of Environmental Quality
    3019 Peters Creek Rd.
    Roanoke, VA  24019    USA
 Michael Bender
           OFFICE: 802-223-9000
              FAX:  802-223-7914
            mtbendervt@aol. com
Mercury Policy Project
    1420 North Street
    Montpelier, VT 05602  USA
 Peter Berglund
           OFFICE: 651-602-4708
              FAX:  651-602-4730
            peter.berglund@metc.state.mn.us
Met. Council Enviro Services
    230 East 5th Street
    St. Paul, MN 55101    USA
 Susan Berneski
            OFFICE: 215-697-5028
              FAX:  215-697-9093
            aarmentani@dscp.dla.mil
Defense Supply Center Philadelphia
   700 Robbins Avenue
   ATTN: DSCP-IFB, Building #3C
   Philadelphia, PA  19111-5096  USA
 Ben Blaney
            OFFICE: 513-569-7852
              FAX:  513-569-7680
            blaney.ben@epa.gov
US EPA, NRMRL
   26 W. Martin Luther King Drive, MC 235
   Cincinnati, OH 45268  USA
FINAL
                                                  96
                           As of:  Monday, April 10, 2000

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            Workshop on Mercury Products, Processes, Waste, & the Environment:
          Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                                Baltimore, Maryland, March 22-23, 2000
                                          LIST OF ATTENDEES
  Frederic H. K. Booth
      J      OFFICE: 301-528-1909
               FAX:  301-528-1970
 	fred_booth@wpi.org
                              Waste Policy Institute
                                 12850 Middlebrook Road, Suite 250
                                 Germantown, MD  20874-5244 USA
  Robert Booze
            OFFICE:  410-436-8554
               FAX:  410-436-5237
             robert. booze@apg. amedd. army, mil
                              USACHPPM
                                 5158 Blackhawk Road - E 1677
                                 APG-Edgewood Area, MD 21010
                                   USA
  Michael Borsykowsky, P.E.
            OFFICE:  718-595-6072
              FAX:  718-595-6027
 	cwbiga@aol.com
                             NYC DEP
                                 96 - 05 Horace Harding Expwy.
                                 Corona, NY 11368-5107      USA
  Bruce Bowman

              FAX:
410-396-9695
410-396-9838
Baltimore City
   8201 Eastern Boulevard
   Baltimore, MD 21224  USA
  Leonard Breitstein
            OFFICE: 301-652-2215
              FAX:  301-656-8059
 	  waslb@dames.com
                             Dames & Moore, Inc.
                                7101 Wisconsin Ave., Suite 700
                                Bethesda, MD 20814  USA
  Clifton H. Brown
            OFFICE: 303-792-5615
              FAX:  303-792-5633
 	cliff. brown@adatech. com
                             ADA Technologies, Inc.
                                8100 Shaffer Parkway, Suite 130
                                Littleton, CO 80127    USA
  Karen Busshart
                   802-241-3455
              FAX:  802-241-3273
             karenbu@dec.anr.st. vt. us
                             Vermont Agency
                                103 South Main
                                Waterbury, VT 05671
                      USA
 Alexis Cain
              FICE: 312-886-7018
              FAX:  312-886-0617
             cain.alexis@epa.gov
                             US EPA Region 5
                                77 W, Jackson Blvd.
                                Chicago, IL 60604
                      USA
 Charles (Randy) Case
            OFFICE: 608-267-7639
              FAX:  608-267-0496
     '	casec@dnr.state. wi.us
                             Wisconsin Department of Natural Resources
                                101 S.Webster St.
                                P.O. Box 7921
                                Madison, Wl  53707    USA
 David Case
            OFFICE:  202-783-0870x12
             EM:  202-737-2038
            dcase@etc. org	
                             Environmental Technology Council
                                734 15th Street, Suite 720
                                Washington, DC 20005 USA
 Fred Chanania
           OFFICE:  703-308-8420
             FAX:  703-308-8433
	  x   chanania.fred@epa.gov
                            US EPA, OSW
                               Mail Code 5302W
                               1200 Pennsylvania Ave. NW
                               Washington, DC 20460 USA
FINAL
                              97
                                                                           As of: Monday, April 10, 2000

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          Workshop on Mercury Products, Processes, Waste, & the Environment:
        Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                             Baltimore, Maryland, March 22-23, 2000
                                       LIST OF ATTENDEES              	
Harold Charles
          OFFICE:  703-308-8918
            FAX:  703-308-8433
           charles.harold@epa.gov
US EPA/OSW/
   401 M Street, SW (5302W)
   Washington, DC 20460 USA
Chad Cliburn
          OFFICE:  312-353-5617
             FAX:  312-353-4788
           dibum. chad@epa.gov
US EPA Region 5
   77 W. Jackson Boulevard
   Chicago, IL 60604    USA
David Colbert
          OFFICE: 315-435-2260
             FAX:  315-435-5023
           dsdcolb@lake. onondaga.ny. us
Onondaga County Department of Drainage and Sanitation
   650 Hiawatha Blvd. W
   Syracuse, NY 13204   USA
Thomas Corbett
          OFFICE:  716-851-7255
             FAX:  716-851-7226
            Tacorbet@GW.Decistate.NY. US
NYSDEC
   270 Michigan Ave.
   Buffalo, NY 19203-2999
USA
Matthew Cox
           OFFICE: 757-460-7048
             FAX:  757-464-3985
            mcox@hrsd.dst. va. us
Hampton Roads
    1436 Air Rail Ave.
    Virginia Beach, VA 23455
USA
Gerard Cox, P.E.
           OFFICE: 718-595-6072
             FAX:  718-595-6027
            cwbiga@aol.com	
NYC DEP
    96 - 05 Horace Harding Expwy.
    Corona, NY  11368-5107      USA
Anita Cummings
           OFFICE: 703-308-8303
             FAX:  703-308-8433
            cummings. anita@epa.gov
US EPA HQ
   401 M Street, SW (5302W)
   Washington, DC 20460 USA
 Mary Cunningham
           OFFICE: 703-308-8453
             FAX:
 US EPA
   401 M Street, SW (MC 5302W)
   Washington, DC 20460 USA
 Patrick Cyr
           OFFICE: 888-824-3992
             FAX:  610-558-2620
            pcyr@agcinfo.com
Advanced GeoServices Corp.
    Chadds Ford Business Campus
    Routes 202 & 1, Bradywine One, Suite 202
    Chadds Ford, PA 19317-9676  USA
 Stephanie D'Agostino
           OFFICE: 603-271-6398
             FAX:  603-271-2867
      	sdagostino@des.state.nh.us
 NH Department of Environmental Services
    6 Hazen Drive
    Concord, NH 03301    USA
 Swati Damle
           OFFICE: 301-496-7990
             FAX: 301-480-8056
            sdamle@helix.nih.gov
 NIH
    9000 Rockville Pike, Bldg. 1312W64
    Bethesda, MD 20892   USA
FINAL
                                                 98
                           As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
         	___                LIST OF ATTENDEES
  Curtis De Tore
            OFFICE: 410-631-3440
              FAX: 410-631-S472&
 	•':,.     cdetore@mde.md. us
                              Maryland Department of the Environment
                                 2500 Broening Highway
                                 Baltimore, MD 21224  USA
  Vita DeMarchi
            OFFICE: 315-475-9204
              FAX:  315-475-9351
 	vdemarchi@secor. com
                              SECOR International Inc.
                                 120 East Washington Street, Suite 421
                                 Syracuse, NY 13202  USA
  John Diamante
            OFFICE: 202-564-6608
              FAX:  202-565-2407
 	diamante.john@epa.gov
                              Office of International Activities
                                 401 M Street, SW
                                 Washington, DC 20460 USA
 John DiMarzio
            OFFICE: 301-353-8342
              FAX:  301-428-3482
 	john.a.dimarzio@saic.com
                              SAIC
                                 20201 Century Boulevard
                                 Germantown, MD 20874
                             USA
 Dr. Folke Dorgelo
            OFFICE: +31 70 339 4908
              FAX:  +31 703391297
 	Folke.Dorgelo@DSVS.DGM.minvrom.nl
                              Netherlands Ministry for Housing, Spatial Planning & Environ.
                                 directoraat-generaal Milieubeheer Ministrie VROM
                                 Interne Postcode 655, Rijnstraat 8, Postbus 30 945
                                 2500 GX DEN HAAG,  NETHERLANDS
 David Eaton
            OFFICE: 208-526-7002
              FAX:  208-526-1061
 	dle@inel.gov	
                              BBWI
                                 Box 1625
                                 Idaho Falls, ID 83402
                      USA
 John Eichner
            OFFICE: 301-353-1871
              FAX:
 	eichnerj@saic. com
                              SAIC
 David Eick
              FAX:
410-396-9695
410-396-9838
Baltimore City
   8201 Eastern Boulevard
   Baltimore, MD 21224  USA
 Jim Ekmann
           OFFICE: 412-386-5716
             FAX:
	.,.-.   ekmann@netl.doe.gov
                             US DOE, NETL
                                Office of Systems and Environmental Analysis
                                       USA
 Steve Elie-Pierre, P.E.
           OFFICE:  718-595-6072
              FAX:  718-595-6027
	cwbiga@aoi. com
                             NYC DEP
                                 96 - 05 Horace Harding Expwy.
                                 Corona, NY 11368-5107      USA
 Holly Elwood
           OFFICE:  202-260-4362
              FAX:  202-260-0178
	elwood.holly@epa.gov
                             USEPA - Office of Pollution Prevention and Toxics
                                401 M Street SW
                                Washington, DC 20460 USA
FINAL
                               99
                                                                         As of: Monday, April 10, 2000

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          Wortehop on Mercury Products, Processes, Waste, & the Environment:
        Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                         LIST OF ATTENDEES
 Lisa Enderle
           OFFICE: 703-676-7857
             FAX: 703-676-7945
            lisa, e. enderle@cptnx.saic. com
SAIC
   1710 Goodridge Drive, T3-3-1
   McLean, VA 22102   USA
 Marilyn Engle
           OFFICE: 202-564-6472
             FAX: 202-565-2409/2411
            engle.marilyn@epa.gov
US EPA
   Office of International Activities
   401 M Street, SW (2660R)
   Washington, DC 20460 USA
 Ric Erdheim
           OFFICE:  703-841-3249
             FAX:  703-841-3349
            ric_erdheim@nema.org
NEMA
   1300 North 17 Street, Suite 1847
   Rosslyn, VA 22209    USA
 Holly Evans
Electronic Industries Alliance
           3FFICE:  703-907-7576
             FAX:  703-907-7501
            hevans@eia.org	
 Ann Ferreira
           OFFICE: 757-851-4805
             FAX:
	virginia@portone. com
DAMS, Dental Amalgam Mercury Syndrome
   Anne, 22 Neff Drive
   Hampton, VA 23669   USA
 Chris Ferrigan
           OFFICE: 561-338-7333
              FAX:  561-338-7345
            cfem'gan@ci. boca-raton. fl. us
City of Boca Raton
    1501 Glades Road
    Boca Raton, FL 33431  USA
 Julie A. Fitzsimmons
           OFFICE: 215-648-4028
              FAX:  215-641-0656
            jfitzsimmons@matheson-trigas.com
Matheson Tri-Gas
    166 Keystone Drive
    Montgomeryville, PA 18936
USA
 Errol Fletcher
           OFFICE: 513-541-1823
              FAX:  513-782-8950
	errolfletcher@spn'ntmail. com
Environmental Enterprises, Inc.
    10163 Cincinnati - Dayton Rd.
    Cincinnati, OH 45241   USA
 Quentin Forrest
            OFFICE: 410-631-3633
              FAX:  410-631-3889
            gforrest@mde.state.md.us
Maryland Dept. of the Environment
    2500 Broenning Hwy.
    Baltimore, MD 21224   USA
 Bill Fortune
            3FFICE: 202-586-7302
              FAX:  202-586-3915
             wiltiam.fortune@eh.doe.gov
US DOE
   Office of Environmental Policy and Guidance
   1000 Independence Avenue, SW (EH-41)
   Washington, DC  20585-0119   USA
 Jane J. Frank
            OFFICE: 302-739-3689
              FAX:  302-739-5060
            jfrank@dnrec.state.de.us
State of Delaware DNREC
    Solid & Hazardous Waste Management Branch
    89 Kings Highway
    Dover, DE 19901     USA
FINAL
                                                   100
                           As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                         LIST OF ATTENDEES
  Jim Frankos
             FFICE: 410-396-9695
              FAX:  410-396-9838
 Baltimore City
    8201 Eastern Boulevard
    Baltimore, MD 21224  USA
  Twila Frieders
            OFFICE: 703-767-7624
              FAX:  703-767-7716
 	twila_frieders@hq.dla.mil
 Defense National
    8725 John J. Kingman Road, Suite 4616
    Fort Belvoir, VA 22060 USA
  James R. Gagnon
            OFFICE: 603-623-3600
              FAX:  603-624-9463
 	jgagnon@gza. com
 GZA GeoEnvironmental, Inc.
    380 Harvey Road
    Manchester, NH 03103 USA
  Herman Gibb
            OFFICE: 202-562-3334
              FAX:  202-565-0059
 	g.bb.herman@epa.gov
 National Center For Environmental Assessment
    US EPA
    Ariel Rios Bldg., 1200 Pennsylvania Ave. NW
    Washington, DC 20460 USA
 John Gilkeson
            OFFICE: 651-215-0199
              FAX:  651-215-0246
 	john.gilkeson@moea.state.mn. us
MN Office of Envrionmental Assistance
    Problem Materials Program
    520 Lafayette Road North, 2nd Floor
    , MN 55155   USA
 Tristan Gillespie
            OFFICE: 212-637-3753
              FAX:  212-637-3771
 	gillespie.tristan@epa.gov
EPA Region 2
    325 Court St.
    Hoboken, NJ 07030
USA
 J. Wade Gilley
            OFFICE: 865-405-4892
              FAX:
SAIC
   2469 Pine Grove Church Road
   Knoxville, TN  37921   USA
 George Gissel
           OFFICE: 715-887-4507
              FAX:  715-887-4513
      ..;    george_gissel@vul.com
Vulcan Chemicals
   State Highway 73 South
   Port Edwards, Wl 54469
       USA
 Leo S. Gomez
           OFFICE:  505-284-3959
              FAX:  505-844-2348
	lsgomez@sandia.gov
Sandia National Laboratories
   P.O. Box 5800, MS-0779
   Albuquerque, NM 87185
       USA
 Michael Greene
           OFFICE:  631-344-5217
             FAX:
	mgreene@bnl.gov
Brookhaven National Laboratory
 Peter Greer
           OFFICE:  734-324-6168.
             FAX:  734-324-6121
	greerp@basf. com
BASF Corp.
   1609 Biddle Avenue
   Wyandotte, Ml 48192
USA
FINAL
  101
                                                                           As of: Monday, April 10, 2000

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          Workshop on Mercury Products, Processes, Waste, & the Environment:
        Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                              Baltimore, Maryland, March 22-23,  2000
                                        LIST OF ATTENDEES
 Lester Gress
           OFFICE: 440-526-7070
             FAX:  440-526-0770
    	Igr8ss@aol.com	
Cleveland Fluid Systems Co.
   P.O. Box 41070
   Cleveland, OH 44141  USA
 Doug Grosse
           OFFICE: 513-569-7844
             FAX: 513-569-7585
	grosse.douglas@epa.gov
US EPA
   26 W. Martin Luther King Drive, MC G75
   Cincinnati, OH 45268  USA
 Leah Hagreen
           OFFICE: 416-922-9038x25
             FAX: 416-922-1028
            lhagreen@lourielove. com
Lourie & Love Environmental Management Consulting Inc.
   1216 Yonge Street, Suite 201
   Toronto, ON  M4T 1W1 CANADA
 Harry J. Hansen
           OFFICE: 410-554-5554
             FAX:  410-554-5502
	hhansen@mgs.md.gov
Maryland Geological Survey
   2300 St. Paul Street
   Balitmore, MD 21218  USA
 James Harvie
           OFFICE: 218-525-7806
             FAX:
            harvie@isfusa.org
HealthCove Without Harm
   c/olSF 5232TiogaSt.
   Duluth, MN 55804    USA
 Patricia Heck
           OFFICE: 410-354-7985
             FAX: 410-354-7962
            theck@mic-usa. com
Millenium Inorganic Chemicals
   3901 Ft. Armistead Rd.
   Baltimore, MD 21226  USA
 Jon Herrmann
           OFFICE: 513-569-7839
             FAX: 513-569-7680
  	herrmann.jonathan@epa.gov
US EPA
   26 W. Martin Luther King Drive
   Cincinnati, OH 45268   USA
 Randy Hiebert
           OFFICE: 406-494-7233
             FAX: 406-494-7230
            hiebert@mse-ta. com
MSE, Inc.
   200 Technology Way
   Butte, MT 59701
USA
 Gregory Hulet
           OFFICE:  208-526-0283
              FAX:  208-526-1061
            eag@inel.gov	
Idaho National Engineering & Env. Laboratory
    P.O. Box 1625 MS 3875
    Idaho Falls, ID 83415-3875    USA
 Tom Hyatt
           OFFICE:  717-787-7382
              FAX:  717-787-1904
            hyatt. thomas@dep.state.pa. us
Dep - Land Recycling & Waste Management
    400 Market Street
    Harrisburg, PA 17105  USA
 Trevor Jackson
           OFFICE:  801-532-1330
              FAX:  801-532-7512
            tjackson@envirocareutah.com
Envirocare of Utah, Inc.
    46 West Broadway, Suite 116
    Salt Lake City, UT 84101
      USA
FINAL
                                                  102
                           As of:  Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
         	                         LIST OF ATTENDEES
  John James
            OFFICE: 207-287-7866
              FAX:  207-287-7826
 	john.james@state.me. us
 Maine Department of Environmental Protection
    17SHS
    Augusta, ME 04330   USA
  Daniels Jarad
            OFFICE: 202-586-7355
              FAX:  202-586-1492
 	jarad. daniels@em. doe.gov
 U.S. Dept. of Energy
    1000 Independence Avenue SW
    Washington, DC 20585 USA
 Jennifer Johnson
            OFFICE: 734-462-0207
              FAX:  734-462-0508
 	ijohnson@gza. com
 GZA Geo Environmental
    38019 Schoolcraft
    Livonia, MI 48150     USA
  Paul Kalb
                   516-344-7644
              -AX:  516-344-4486
             kalb@bnl.gov
 Brookhaven National Laboratory
    Sr. Research, Environ. & Waste Mgmt. Group
    34 N. Railroad Street, Building 830
    Upton, NY 11973      USA
 Ron Karaway
            OFFICE: 847-688-5647
              FAX:  847-688-4279
 	drglrsk@drg10.med.navy.mil
Naval Dental Research Institute
    310-AB Street, Building 1H
    Great Lakes, IL 60088-5259   USA
 Nicholas Kauffman
            OFFICE: 202-535-2305
              FAX:  202-535-1338
 	NVJ@epaibm.rtpnc.epa.gov
District of Columbia EPA Program
   51 N Street NE, Room 6001
   Washinton, DC 20002  USA
 Kirk Kessler
            OFFICE: 410-381-4333
             FAX:  410-381-4499
 	kirkk@geosyntec. com
GeoSyntec Consultants
   10015 Old Columbia Road, Suite A-200
   Columbia, MD 21046  USA
 Peggy Knecht
           OFFICE: 208-526-8094
              FAX:  208-526-1061
 	mak@inel.gov	
MWFA, BBWI, INEEL
   P.O. Box 1625
   Idaho Falls, ID 83415
USA
 Freya B. Koss
           OFFICE:  610-649-2606
              FAX:  610-649-1938
	frekoss@aol. com
DAMS, Dental Amalgam Mercury Syndrome
   519 Sussex Road
   Wynnewood, PA 19096 USA
 Steve Kratzer
           OFFICE:  517-373-0939
              FAX:  517-335-4729
	kratzers@state. mi. us
Michigan Dept. of Environmental Quality
   333 South Capitol Ave.
   Lansing, Ml 489      USA
 Robert Krauel
           OFFICE:  416-739-5861
             FAX:  416-739-4405
     "•	robert.krauel@ec.gc. ca
Environment Canada
   4905 Dufferin Street
   Downsview, Ontario M3H 5T4  CANADA
FINAL
  103
                                                                           As of: Monday, April 10, 2000

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r

                 Workshop on Mercury Products, Processes, Waste, & the Environment:
               Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                                     Baltimore, Maryland, March 22-23, 2000
                                               LIST OF ATTENDEES
       Arnold M. Kuzmack
                  OFFICE: 202-260-5821
                    FAX:  202-260-5394
                   kuzmack. amold@epa.gov
EPA, Office of Water
    MC 4301
    Washington, DC 20460 USA
       Mitch Lasat
                  OFFICE: 202-564-6826
                    FAX:  202-564-2446
       	lasat.mitch@epa.gov
EPA/ORD/NCERQA
   401 M Street, SW
   Washington, DC 20460 USA
       Bruce Lawrence
                  OFFICE: 610-838-7034
                    FAX:  610-838-6333
                  brucelawr@aol. com
Bethlehem Apparatus Company, Inc.
   890 Front Street, P.O. Box Y
   Hellertown, PA 18055  USA
       Ron Le Tourneau
                  OFFICE: 248-351-2644
                    FAX:  248-351-2645
R.G. Enterprises, Inc.
    2000 Town Center, Suite 1900
    Southfield, Ml 48075-1152
                                                                                  USA
       Dr. Paul Lear
                 OFFICE: 865-694-7316
                    FAX:  865-694-9573
      	plear@theitgroup. com
IT Corporation
   304 Directors Drive
   Knoxville.TN 37923
USA
       Gale LeBlanc
                 OFFICE: 225-751-4200
                    FAX:  225-752-4208
      	cale@walshcomp. com
Walsh Environmental, Inc.
   727 Highlandia Dr.
   Baton Rouge, LA  70810
      USA
       C.C. Lee
                 OFFICE:  513-569-7520
                    FAX:  513-569-7471
                  lee.chun@pamail.epa.gov
US EPA
   26 West Martin Luther King Dr.
   Cincinnati, OH  45268  USA
       Patty R. Lee
                 OFFICE:  757-460-4213
                    FAX:  757-460-6586
      	plee@hrsd. dst. va. us
Hampton Roads Sanitation District
   1432 Air Rail Avenue
   Virginia Beach, VA 23455      USA
       Giles LePage
                 OFFICE:  703-767-7642
                   FAX:  703-767-7716
      	gilesjepage@hq.dla.mil
Defense National
   8725 John J. Klingman Road, Suite 4616
   Fort Belvoir, VA 22060 USA
       Josh Lewis
                 OFFICE:  703-308-7877
                   FAX:  703-308-8433
      	lewis.josh@epamail. epa.gov
US EPA HQ
   401 M Street, SW (MC 5302W)
   Washington, DC 20460 USA
       George Loeb
                 OFFICE: 202-260-0670
                    FAX: 202-260-9960
      	loeb.george@epa.gov
EPA OCPD
   Mail Code 4504-F
   1200 Pennsylvania Ave.
   Washington, DC 20460 USA
      FINAL
  104
                           As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                        LIST OF ATTENDEES
 Jeff Lord
                   440-526-7070
                   440-526-0770
                             Cleveland Fluid Systems Co.
                                P.O. Box 41070
                                Cleveland, OH  44141  USA
 Dennis Lynch
           OFFICE:  703-767-7609
              FAX:  703-767-7608
____"••	dennisjynch@hq.dla.mil
                             Defense National
                                8725 John J. Kingman Rd., Suite 4616
                                Fort Belvoir, VA 22060 USA
 Joseph Malki
           OFFICE:  212-637-4101
              FAX:  212-637-4437
	malki.joseph@epa.gov
                             US EPA Region 2
                                290 Broadway
                                New York, NY 10007
                      USA
 Dave Malkmus
           OFFICE:  940-243-8203
             FAX:  940-243-9089
	dmalkmus.sepradyne@iolt. com
                             Sepra Dyne Corporation
                                7201 I-35 North
                                Denton, TX 76207    USA
 Allen Q. Maples
           OFFICE:  703-605-0794
             FAX:  703-308-0522
	maples.allen@epa.gov
                             US EPA, OSW
                                401 M Street, SW (5304W)
                                Washington, DC 20460 USA
 Ralph Marchitelli
           OFFICE: 718-595-6072
             FAX: 718-595-6027
            cwbiga@aol. com
                             NYC DEP
                                96 - 05 Horace Harding Expwy.
                                Corona, NY 11368-5107
                            USA
 Frank Marella
             FAX:
201-529-9408
201-512-3472
Sharp Electronics Corp.
   Sharp Plaza
   Mahwah, NJ  07430
                                                                      USA
 Alina Martin
             FAX:
                             SAIC
                                11251 Roger Bacon Drive
                                Reston.VA 20190    USA
 Haren M. Master
           OFFICE: 484-530-0800
             FAX: 484-530-9140
            hmmaster@mactec.com
 Paul Matthai
           OFFICE: 202-260-3385
             FAX: 202-260-1580
	matihai.paul@epa.gov
                             MACTEC ETG
                                5205 Militia Hill Road
                                Plymouth Meeting, PA 19462
                            USA
                             US EPA
                                1200 Pennsylvania Avenue, NW
                                Ariel Rios Building
                                Washington, DC 20460 USA
 Shas V. Mattigod
           OFFICE: 509-376-4311
             FAX: 509-376-5368
	shas.mattigod@pnl.gov
                             Pacific Northwest National Laboratory
                                Richland, WA 99352   USA
FINAL
                                                 105
                                                        As of:  Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                        LIST OF ATTENDEES
 Donna Maxey
            OFFICE: 916-557-7437
              FAX:  916-557-5307
 	dmaxey@spk. usace. army, mil
Army Corps of Engineers
   1325 J Street / CESPK-ED-EH
   Sacramento, CA 95814-2922
USA
 Alec McBride
           OFFICE:  703-308-0466
              FAX:  703-308-0511
	mcbride.alexander@epa.gov
US EPA, OSW
   1200 Pennsylvania Avenue, NW
   Washington, DC 20460 USA
 Daniel McCabe
           OFFICE:  513-541-1823
              FAX:  513-782-8950
	errolfletcher@sprintmail. com
Environmental Enterprises, Inc.
   10163 Cincinnati-Dayton Rd.
   Cincinnati, OH 45241  USA
 Bryan McDowell
           OFFICE:  972-404-2416
              FAX:  972-404-3285
	bryan_l._mcdowell@oxy. com
Occidental Chemical Corporation
   5005 LBJ Freeway - 14th Floor
   Dallas, TX 75244-6119 USA
 Michael McKenna, P.E.
           OFFICE:  718-595-6072
              FAX:  718-595-6027
	cwbiga@aol.com
NYC DEP
   96 - 05 Horace Harding Expwy.
   Corona, NY 11368-5107      USA
 Kevin McManus
           OFFICE:  617-788-2306
              FAX:  617-788-2301
	         kmcmanus@mwra.state.ma.us
Massachusetts Water Resources Authority
   Toxics Reduction and Control Program
   100 First Avenue
   Boston, MA 02129    USA
 Greg Merrill
            OFFICE:  703-741-5417
             FAX:  703-741-6084
            greg_menill@cmahq.com
Chlorine Chemistry Council
   1300 Wilson Boulevard
   Arlington, VA 22209   USA
 Tom Metzner
           OFFICE:  860-424-3242
              FAX:  860-424-4081
	tom.metzner@pa.state.ct.us
Conn. Dept. of Environmental Protection
   79 Elm Street
   Hartford, CT 06106-5127     USA
 Melinda Miller
           OFFICE: 410-631-3618
             FAX:
MDE (Health Risk Asessment Program)
   2500 Broening Hwy.
   Baltimore, MD  USA
 Amanda Monchamp
           OFFICE:  703-907-7582
             FAX:  703-907-7501
	amonchamp@eia.org
Electronic Industries Alliance
 George Moreau
           OFFICE: 315-451-9560
             FAX: 315-451-9570
	george.h.moreau@parsons. com
Parsons Engineering Science, Inc.
   290 Elwood Davis Road, Suite 312
   Liverpool, NY 13088   USA
FINAL
 106
                          As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment-
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                         LIST OF ATTENDEES
 Mitchell L. Moss
            OFFICE: 484-530-0800
            •  FAX:  484-530-9140
 	mlmoss@mactec. com
 MACTEC ETC
    5205 Militia Hill Road
    Plymouth Meeting, PA 19462
USA
 Jon Nelson
            3FFICE: 248-351-2646
              FAX:  248-351-2645
             rgenterprises@msn.com
R.G. Enterprises, Inc.
    200 Town Center, Suite 1900
    Southfield, Ml 48075-1152
USA
 Diarmuid E. Nicholson
            OFFICE: 202-782-3472
              FAX:  202-782-9059
 	     diarmuid.nicholson@na.amedd.army.mil
Dept. Clinical Investigation, Walter Reed AMC
    6825 16th Street, NW
    Washington, DC  20307-5001  USA
 Susan Nogas
            OFFICE: 703-308-7251
              FAX:  703-308-8686
 	nogas.sue@epa.gov
USEPA
   Ariel Rios Building; 1200 Pennsylvania Ave., N.W.
   MC: 5306W
   Washington, DC 20460 USA
 Tom Nowicki
            OFFICE: 414-225-2275
              FAX:  414-272-0270
	tnowicki@mmsd. com
Milwaukee Metropolitan Sewerage District
    P.O. Box 3049
    Milwaukee, Wl 53201  USA
 Barbara Nuffer
            OFFICE: 518-485-8427
              FAX:
	bjnuffer@gw. dec.state. ny. us
New York State Dept. of Env. Conservation
   50 Wolf Rd.
   Albany, NY 12233-3254USA
 Jim Ogorek
                   215-697-5028
              FAX:  215-697-9093
            aarmentani@dscp.dla.mil
Defense Supply Center Philadelphia
   700 Robbins Avenue
   ATTN: DSCP-IFB, Building #3C
   Philadelphia, PA 19111-5096  USA
 Dana Oliver
           OFFICE: 225-642-1863
              FAX:  225-642-1882
	dsoliver@piona.com
Pioneer Americas, Inc.
   P.O. Box 23
   St. Gabriel, LA 70776  USA
 Linda B. Oxendrine
           OFFICE:  865-632-3440
              FAX:  865-632-6855
	lboxencline@tva.gov
Tennessee Valley Authorithy
   400 West Summit Hill Drive, WT 8C
   Knoxville, TN  37902   USA
 Jayakumar Pallegar
           OFFICE:  313-297-5882
              FAX:  313-297-5805
	pallegar@dwsd. org
Detroit Water & Sewerage Dept.
   303 S. Livernois Ave.
   Detroit, Ml 48209     USA
 Patricia Papa
           OFFICE:  301-353-8218
              FAX:  301-428-3482
	patricia. e.papa@saic. com
SAIC
   20201 Century Boulevard
   Germantown, MD 20874
USA
FINAL
                                                  107
                          As of: Monday, April 10, 2000

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          Workshop on Mercury Products, Processes, Waste, & the Environment:
        Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                              Baltimore, Maryland, March 22-23, 2000
                                        LIST OF ATTENDEES
AnaMarie Paredes
           OFFICE: 703-676-7873
             FAX:  703-676-7945
            ana.marie.paredes@saic.com
SA1C
   1710 Goodridge Drive, T3-3-1
   McLean, VA 22102    USA
 Vibhakar Patel
           OFFICE: 410-396-9695
             FAX:  410-396-9838
Baltimore City Pollution Control
   8201 Eastern Boulevard
   Baltimore, MD 21224  USA
 Mehran Pazzrandeh
           OFFICE: 202-404-6073
             FAX: 202-767-9594
	mpp@cbmse.ni1.navy.mil
Naval Research Laboratory
   4555 Overlook Avenue, SW
   Washington, DC 20375 USA
 Ernest D. Pederson
           OFFICE: 847-688-5647x147
             FAX: 847-688-4279
	drg1edp@drg10.med.navy.mil
Naval Dental Research Institute
   310-A B Street, Building 1-H
   Great Lakes, IL 60088-5259   USA
 Peter M. Pettit
           OFFICE: 518-457-7337
             FAX: 518-457-1283
	pmpettit@gw.dec.state.ny.us
New York State Department of Environmental Conservation
    50 Wolf Road
    Albany, NY 12233-7253USA
 Richard Phillips
           OFFICE: 802-241-3455
             FAX: 802-241-3273
  	richph@dec.anr.st.vt.us
Vermont Agency of Natural Resources
    103 South Main
    Waterbury, VT 05671   USA
 M. Saleem Qureshi
           OFFICE:  313-297-5862
             FAX:  313-297-9429
   	qureshi@dwsd.org
Industrial Waste Control Div. DWS Detroit
    303 S. Livernois
    Detroit, Ml 48209      USA
 James C. Ragain Jr.
           OFFICE: 847-688-5647x104
             FAX: 847-688-4279
            james.ragain@ndri.med.navy.mil
Naval Dental Research Institute
    310 A, B Street, Bldg 1-H
    Great Lakes, IL 60088-5259   USA
 Norman Rainer, Ph.D.
           OFFICE:  804-288-7109
              FAX:  804-282-1325
	lcpatent@aol. com
Dynaphore, Inc.
    2709 Willard Rd.
    Richmond, VA 23294  USA
 Caleb Rancourt
           OFFICE: 540-951-2500
              FAX:  540-961-3602
            info@newmerc. com
 NewMerc, Ltd.
    1872 Pratt Drive, MS 1260
    Blacksburg, VA 24060  USA
 James D. Rancourt
            OFFICE: 540-951-2500
              FAX:  540-961-3602
            info@newmerc. com
 NewMerc, Ltd.
    1872 Pratt Drive, MS 1260
    Blacksburg, VA 24060  USA
FINAL
                                                 108
                             As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                                Baltimore, Maryland, March 22-23, 2000
  Paul Randall
            OFFICE:  513-569-7673
              FAX:  513-569-7620
 _     randalt.paul@epa.gov
 US EPA
    26 W. Martin Luther King Drive, MC 443
    Cincinnati, OH 45268  USA
  Kevin Reilly
            OFFICE:  703-767-6522
              FAX:  703-767-7716
 	kevin_reilly@hq.dla.mil
 Defense National
    8725 John J. Kingman Rd., Suite 4616
    Fort Belvoir, VA  22060 USA
 John Reinders
            OFFICE: 703-767-4430
              FAX: 703-767-6187
 	John_Reinders@hq.dla.mil
 Defense Logistic Agency
    8725 John J. Kingman Road, Suite 2638
    Ft. Beltvoir, VA 22060 USA
  Linda Rieser
            OFFICE: 513-556-2060
              FAX:  513-556-3148
 	lrieser@ uceng. uc. edu
University of Cincinnati
    Civil and Environmental Engineering
    Cincinnati, OH 45221-0071     USA
 Terry W. Rogers
            OFFICE: 505-292-9315
              FAX: 505-292-9316
 	trogers@delphi-res. com
Delphi Research, Inc.
    11930 Menaul Blvd. NE, Suite 105
    Albuquerque, NM 87112      USA
 James Roof
            OFFICE: 717-787-6239
              FAX:  717-787-0884
 	roof.james@dep.state.pa.us
PA Dept of Env. Protection
   P.O. Box 8471
   Harrisburg, PA 17110  USA
 David E. Rugg
            OFFICE: 313-556-5258
              FAX:  313-556-7629
 	   david.rugg@gm. com
General Motors
   485 W. Milwaukee
   Detroit, Ml 48202
USA
 Arthur L. Russell
            OFFICE: 318-741-8379
              FAX:  318-741-8369
	russella@bossiercity.org
Bossier City Utilities
   8000 Shed Road
   Bossier City, LA 71111 USA
 Jeanette M. Samaritan
            OFFICE: 404-562-9339
              FAX:  404-562-9224
	samaritan.jeanette@epa.gov
US EPA, WMD
   61 Forsyth Street, 15th Floor
   Atlanta, GA 30303     USA
 Bill Schildt
            OFFICE: 410-354-7737
              FAX:  410-354-7962
             wschildt@mic-usa. com
Millennium Inorganic Chemicals
   3901 Fort Armistead Road
   Baltimore, MD 21226   USA
 W.G. Schuetzenduebel
           OFFICE: 334-271-9343
              FAX:  334-271-9365
	wolframgs@aol. com
Montenay International Corp.
   801 Timberlane Road
   Pike Road, AL  36064   USA
FINAL
 109
                                                                           As of: Monday, April 10, 2000

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r
                  Workshop on Mercury Products, Processes, Waste, & the Environment-
                Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                                      Baltimore, Maryland, March 22-23, 2000
                                               LIST OF ATTENDEES               	
        Mark J. Sharp
                  OFFICE:  202-223-2575x116
                     FAX:  202-223-2614
       	sharpm@panasonic.com
                             Panasonic
                                1620 L Street NW, Suite 1150
                                Washington, DC 20036 USA
        David W. Sheaves
                  OFFICE: 734-324-6836
                     FAX:  734-324-6775
                   sheaves@basf. corp
                             BASF Corporation
                                1609 Biddle
                                Wyandotte, Ml 48192
                      USA
        Swati Sheladia
                   OFFICE: 202-564-6477
                     FAX:  202-565-2409/2411
                   ssheladi@naco.org	
                             National Association of Counties
                                440 N. First Street
                                Washington, DC 20460 USA
        Judu Shope
                     FAX:
617-292-5597
617-292-5778
Mass Dept. Env. Protection
   1 Winter Street, 9th Floor
   Boston, MA 02108    USA
        Surendra S. Shukla
                   OFFICE: 313-297-5823
                     FAX:  313-297-5860
                    surendrashukla@hotmail. com
                             City of Detroit - Water & Sewerage Department
                                303 S. Livernois
                                Detroit, Ml 48209     USA
        Steve Skavroneck
                   OFFICE: 414-486-1613
                     FAX:
                    cranehousesp@msn. c
                                346 E. Wilson Street
                                Milwaukee, Wl 53207
                      USA
        Jeff Sloan
                   OFFICE: 703-741-5183
                     FAX:  703-741-6183
                   J8ffrey_sioan@cmahq. com
                             Chlorine Chemistry Council
                                 1300 Wilson Boulevard
                                 Arlington, VA 22209    USA
        Paul D. Smith, P.E.
                   OFFICE: 718-595-6072
                     FAX:  718-595-6027
                    cwbiga@aol. com
                             NYC DEP
                                 96 - 05 Horace Harding Expwy.
                                 Corona, NY 11368-5107      USA
        Christopher Smoiar
                   OFFICE: 610-861-2150
                     FAX:  610-861-2072
        	smolar.christopher@dep.state.pa
                              PA Dept. of Environmental Protection
                                4530 Bath Pike
                                Bethlehem, PA 18017 USA
         Robert Snowden
                   OFFICE: 225-339-2848
                     FAX:  225-339-2369
                              BASF
                                 P.O. Box 457
                                 8404 River Road
                                 Geismar, LA 70734-0457
                                                                                    USA
         Carl L. Spadaro
                   OFFICE: 412-442-4157
                     FAX:  412-442-4194
        	spadaro.carl@dep.state.pa.us
                              PA Dept. of Environ. Protection
                                 400 Waterfront Drive
                                 Pittsburgh, PA 15222  USA
        FINAL
                                                         110
                                                        As of: Monday, April 10, 2000.

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           Workshop on Mercury Products, Processes,  Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                         LIST OF ATTENDEES
 Karyn E. Sper
           OFFICE:  703-318-4733
              FAX:  703-736-0826
            karyn. e.sper@saic. com
SAIC
   11251 Roger Bacon Drive
   P.O. Box 4875
   Reston, VA 20190    USA
 Jeff Stamps
           OFFICE:  501-624-8593
             FAX:  501-624-8588
	jeff.stamps@weyerhaeuser.com
Weyerhaeuser Company
   810 Whittington Avenue
   Hot Springs, AR 71901 USA
 Douglas Steele
           OFFICE:  202-564-6759
             FAX:  202-565-2917
    •    •    Steele.doug@epa.gov
ORD/OSP
   1200 Pennsylvania Avenue, NW
   Washington, DC 20460 USA
 William G. Stelz
           OFFICE:  202-564-6834
             FAX:  202-565-2447
            stelz. william@epa.gov
US EPA, ORD, NCER
   1200 Pennsylvania Avenue, NW
   Ariel Rios Building
   Washington, DC 20460 USA
 Kenneth R. Stone
           OFFICE: 513-569-7474
             FAX: 513-569-7111
	stone.kenneth@epa.gov
US EPA/NRMRL
   26 W. Martin Luther King Drive, MS 466
   Cincinnati, OH 45268  USA
 Mark E. Stone
           OFFICE:  847-688-5647x122
             FAX:  847-688-4279
	mark.stone@ndri. med. navy, mil
Naval Dental Research Institute
   310-A B Street, Building 1-H
   Great Lakes, IL 60088-5259    USA
 Vicki Strause
           OFFICE: 410-436-3651
             FAX: 410-436-5237
            vIcki. strause@apg. amedd. army, mil
US Army Center for Health Promotion & Preventive Medicine
   5158 BlackhawkRd.
   Attn: MCHB-TS-EHM
   Aberdeen Proving Ground, MD 21010-5403    USA
 Greg Susan ke
           OFFICE: 202-260-3547
             FAX:
	susanke.greg@epa.gov
US EPA, OPPTS
   401 M Street, SW (Mail Code 7404)
   Washington, DC 20460 USA
 David B. Sussman
           OFFICE: 202-554-6020
             FAX: 202-863-1897
   •    	poubelle@erols. com
Poubelle Associates
   704 6th St., SW
   Washington, DC 20024 USA
 Edward Swain
           OFFICE: 651-296-7800
             FAX: 651-297-7709
	edward.swain@pca.state.mn
Minnesota Pollution
   520 Lafayette Road
   St. Paul, MN 5515
USA
 Jeff Talburt
            )FFICE:  940-243-8203
             FAX:  940-243-9089
Sepra Dyne Corporation
   721 I 35 North
   Denon, TX 76201
USA
FINAL
                                                 111
                          As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23,  2000
                                         LIST OF ATTENDEES
 Joy K. Taylor
           OFFICE: 517-335-6974
              FAX:  517-241-7499
	taylorjk@state.mi. us
Ml Department of Environmental Quality
   106W. Allegan
   Lansing, Ml  48933   USA
 Delores Thompson
           OFFICE: 703-767-6523
              FAX:  703-767-4074
	dthompson@ogc.dla.mil
Defense National
   8725 John J. Kingman Rd., Suite 4616
   Fort Belvoir, VA 22060 USA
 Jamie M. Tosches
           OFFICE: 401-222-3434x4406
              FAX:  401-831-5508
	jtosches@dem.state	
Rl Department of Environmental Management
   235 Promenade St., Suite 330
   Providence, Rl  02908 USA
 Eric Trinkle
           OFFICE: 302-739-3689
              FAX:  302-739-5060
	etrinkle@dnrec.state. de. us
DE Dept. of Natural Resources &
   89 Kings Hwy
   Dover, DE 19903     USA
 Luke Trip
           OFFICE: 819-997-1967
              FAX:  819-994-3479
            luke. frvp@ec.gc. ca
Environmental Canada
   351 St. Joseph Blvd.
   Hull-QUE,  KIAOH3
CANADA
 Tim Tuominen
           OFFICE: 218-722-3336x324
              FAX:  218-727-7471
	tim.tuominen@wlssd.duluth.mn.us
Western Lake Superior
   2626 Courtland Street
   Duluth, MN 55806    USA
 Kay Michael van der Horst
           OFFICE:  301-528-1923 or 703-536-4906
              FAX:  301-528-1971
	kvanderh@clark.net	
Waste Policy Institute
   12850 Middlebrook Road, Suite 250
   Germantown, MD 20874-5244  USA
 Carmen Varela
           OFFICE: 703-676-7878
              FAX:  703-676-7945
	carmen, v. varela@cpmx.saic. com
SAIC
   1710 Goodridge Drive, T3-3-1
   McLean, VA 22102    USA
 John Vierow
           OFFICE:  703-318-4551
              FAX:  703-736-0815
            john.b.vierow@saic.com
SAIC
   11251 Roger Bacon Drive
   P.O. BOX 4875
   Reston, VA 20190    USA
 Kristina von Rein
           OFFICE: 4608-698-1127
              FAX:  4608-698-1222
            kristina.von-rein@environ.se
Swedish Environmental Protection Agency
   S-106 48 Stockholm
   Stockholm,    SWEDEN
 John N. Wachtler
           OFFICE: 651-297-8333
              FAX:
	john.wachtler@pca.state.mn.us
Minnesota Pollution Control Agency
   520 Lafayette Rd.
   St. Paul, MN 55155   USA
FINAL
                                                 112
                           As of: Monday, April 10, 2000

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           Workshop on Mercury Products, Processes, Waste, & the Environment:
         Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                               Baltimore, Maryland, March 22-23, 2000
                                        LIST OF ATTENDEES
 Arun Wagh
            OFFICE: 630-252-4295
              FAX:  630-252-3604
   	wagh@et. anl.gov
                             Argonne National Laboratory
                                 Energy Technology Division
                                 9700 S. Cass Avenue
                                 Argonne, IL 60439    USA
 Edward Weiler
            OFFICE: 202-260-2996
              FAX:  202-260-0178
 	weiler.edward@epamail.epa.gov
                             US EPA HQ
                                401 M Street, SW (MC 7409)
                                Washington, DC 20460 USA
 Jeri Weiss
              FAX:
617-918-1568
617-918-1505
USEPA New England
    1 Congress St., Suite 1100 -CME
    Boston, MA 02114    USA
            weiss.jeri@epa.gov
 Laura Weiss
              FAX:
503-222-1963x111
503-222-1405
Oregon Environmental Counsil
   520 SW 6th Avenue, Suite 940
   Portland, OR 97204   USA
            laura@orcouncil. org
 Chen H. Wen
           OFFICE:  202-260-4109
              FAX:  202-260-0178
 	wen.chen@epa.gov
                             USEPA HQ
                                401 M Street, S.W. (MC - 7409)
                                Washington, DC 20460 USA
 Timothy R. Westman
            OFFICE:  231-724-3440
              FAX:  231-724-3588
	westmanti@co. muskegon.mi. us
                             Muskegon County Wastewater Management System
                                8301 White Road
                                Muskegon, Ml 49442  USA
 Pat Wherley
           OFFICE:  301-353-8346
             FAX:  301-601-5678
            wherleyp@saic. com
                             SAIC
                                20201 Century Boulevard
                                Germantown, MD 20874
                            USA
 David Whipple
           OFFICE: 562-699-7411x2909
             FAX: 562-692-5103
   	dwhipple@lacsd.org	
                             Los Angeles County Sanitation Districts
                                P.O. Box 4998
                                Whittier, CA 90607-4998     USA
 J. Kenneth Whittle
           OFFICE: 610-687-9070
             FAX: 610-964-8570
	kwittle@aol.com	
                             EPI
                                996 Old Eagle School Rd.
                                Wayne, PA 19087    USA
 Dale Wilhelm
           OFFICE: 410-436-7440
             FAX: 410-436-7442
    '	dwilhelm@c-pmcd.apgea.army.mil
                             Defense National
                                8725 John J. Kingman Rd., Suite 4616
                                Fort Belvoir, VA 22060 USA
 Jane Williams

             FAX:
661-256-0968
661-256-0674
California Communities Against Toxics
   P.O. Box 845
   3813 30th St. West
   Rosamono, CA 93560 USA
FINAL
                                                 113
                                                As of: Monday, April 10, 2000

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r
                 Workshop on Mercury Products, Processes, Waste, & the Environment:
               Eliminating, Reducing, & Managing Risks from Non-Combustion Sources
                                    Baltimore, Maryland, March 22-23, 2000
                                              LIST OF ATTENDEES                    	
        Winston A. Williams
                  OFFICE: 202-782-0315
                    FAX:  202-782-8383
                   winston.williams@na.amedd.army.mil
Walter Reed Army Medical Center
   6825 16th Street, NW
   Washington, DC 20307-5000  USA
        Elaine Wilson
                  OFFICE: 703-218-6283
                    FAX:  703-591-1305
                   elaine.wilson@parsons.com
Parsons Engineering Science
   10521 Rosehaven Street
   Fairfax, VA 22030     USA
        Arvin Wu
                  DFFICE: 703-318-4754
                    FAX:  703-736-0826
                   an/in. wu@saic. com
SAIC
   11251 Roger Bacon Drive
   P.O. Box 4875
   Reston, VA 20190    USA
        Glen M. Wyatt
                  OFFICE: 253-924-6103
                    FAX:  253-924-6182
         	glen. wyatt@weyerhaeuser. com
Weyerhaeuser Company
   WTC-2G2, P.O. Box 2999
   Tacoma, WA 98477-2999
USA
       FINAL
                                                       114
                            As of: Monday, April 10, 2000

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United States
Environmental Protection Agency/ORD
National Risk Management
   Research Laboratory
Cincinnati, OH 45268
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detach or copy, and return to the address in the upper
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