United States Office of Environmental Information EPA 260-B-01-004
Environmental Protection Washington, DC 20460 August 2001
Agency FINAL
m pp A EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
ACT-SECTION 313:
Guidance for Reporting Toxic Chemicals:
Mercury and Mercury Compounds Category
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)
requires certain facilities manufacturing, processing, or otherwise using listed toxic chemicals to report
the annual quantity of such chemicals entering each environmental medium. Such facilities must also
report pollution prevention and recycling data for such chemicals, pursuant to section 6607 of the
Pollution Prevention Act, 42 U.S.C. 13106. When enacted, EPCRA Section 313 established an initial
list of toxic chemicals that was comprised of more than 300 chemicals and 20 chemical categories.
EPCRA section 313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets
forth criteria for these actions. EPCRA Section 313 currently requires reporting on over 600 chemicals
and chemical categories.
CONTENTS
SECTION 1.0 INTRODUCTION 1
Section 1.1 Background 1
Section 1.2 Who Must Report? 2
Section 1.3 What are the Reporting Thresholds? 4
Section 1.4 What Other Changes to the EPCRA Section 313 Reporting
Requirements Apply to Mercury and the Mercury Compounds
Category? 7
1.4.1 DeMinimis Exemption 8
1.4.2 Alternate Reporting Threshold (1 Million Lbs); Form A .... 8
1.4.3 Range Reporting 9
1.4.4 Data Precision 9
SECTION 2.0 GUIDANCE ON ESTIMATING ENVIRONMENTAL RELEASES OF MERCURY AND MERCURY
COMPOUNDS 10
Section 2.1 General Guidance 10
2.1.1 Threshold Determination 10
2.1.2 Exemptions 12
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CONTENTS (Continued)
Section 2.2 Methods for Calculating Annual Releases and Other Waste
Management Quantities of Mercury and Mercury Compounds .... 14
SECTIONS.0 SOURCES OF MERCURY AND MERCURY COMPOUNDS 19
Section 3.1 Mercury in Raw Materials 19
Section 3.2 Mercury Recovery Operations 22
Section 3.3 Mercury Components 22
Section 3.4 Mercury and Mercury Compounds in the Chemical Industry 23
Section 3.5 Combustion of Fuels Containing Mercury 24
SECTION4.0 RELEASE AND OTHER WASTE MANAGEMENT CALCULATIONS 26
Section 4.1 Mercury and Mercury Compound Emissions 26
Section 4.2 Mercury in Wastewater 38
Section 4.3 Mercury Spills and Solid Waste Calculations 39
SECTION5.0 REFERENCES 42
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LIST OF TABLES
1-1 Industry and Process Sources of Mercury and Mercury Compounds 6
2-1 Potential Data Sources for Release and Other Waste Management
Calculations 18
3-1 Quantity of Raw Materials Required to Meet the Reporting Threshold 19
3-2 Quantity of Solid Fuels Required to Meet the Reporting Threshold 20
3-3 Quantity of Cement Manufacturing Streams Required to Meet the Reporting
Threshold 21
3 -4 Quantity of Common Articles Containing Mercury Required to Meet the Reporting
Threshold 23
4-1 Sources of Mercury Emissions 26
4-2 Percent Mercury Present in Coal Which is Released to Air 28
4-3 Mercury Emission Factors for Kraft Combustion Sources 32
4-4 Mercury Emission Factors from Brick Manufacturing 33
4-5 Mercury Emission Factors 35
4-6 Mercury Concentration in Combustion Residuals 40
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DISCLAIMER
This guidance document is intended to assist industry with EPCRA Section 313 reporting for mercury
and mercury compounds. In addition to providing an overview of aspects of the statutory and regulatory
requirements of the EPCRA Section 313 program, this document also provides recommendations and
emission factors to assist industry with EPCRA reporting. These recommendations do not supersede
any statutory or regulatory requirements, are subject to change, and are not independently binding on
either EPA or covered facilities. Additionally, if a conflict exists between guidance on this site and the
statutory or regulatory requirements, the conflict must be resolved in favor of the statute or regulation.
Although EPA encourages industry to consider these recommendations and emission factors, in
reviewing this document, industry should be aware that these recommendations and emission factors
were developed to address common circumstances at typical facilities. The circumstances at a specific
facility may significantly differ from those contemplated in the development of this document. Thus
individual facilities may find that the recommendations and emission factors provided in this document
are inapplicable to their processes or circumstances, and that alternative approaches or information are
more accurate and/or more appropriate for meeting the statutory and regulatory requirements of
EPCRA Section 313. To that end, industry should use facility specific information and process
knowledge, where available, to meet the requirements of EPCRA Section 313. Facilities are
encouraged to contact the Agency with any additional or clarifying questions about the recommendations
and emission factors in this document, or if the facility believes that EPA has incorrectly characterized a
particular process or recommendation. Additional guidance documents, including industry specific and
chemical specific guidance documents, are also available at the EPA TRI website:
.
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SECTION 1.0 INTRODUCTION
Section 1.1 Background
On October 29, 1999, EPA promulgated the final rule on Persistent, Bioaccumulative,
and Toxic (PBT) chemicals (64 FR 58666). This rule modified the reporting requirements for mercury
and mercury compounds under Section 313 of the Emergency Planning and Community Right-to-Know
Act (EPCRA). The reporting threshold for mercury (Chemical Abstract Service (CAS) Registry
Number 7439-97-6) and the mercury compound category was lowered to 10 pounds per year for
manufacturing, processing, or otherwise use.
The purpose of this document is to assist facilities in complying with the reporting
requirements of EPCRA Section 313 for mercury and the mercury compounds category. Facilities that
meet the EPCRA Section 313 employee threshold and SIC code requirements, and that exceed the ten
pound reporting threshold for mercury or the mercury compounds category are subject to the EPCRA
Section 313 annual reporting requirements beginning with reporting year 2000, with the first reports due
by July 1,2001.
This document explains the EPCRA Section 313 reporting requirements, and provides
guidance on how to estimate annual releases and other waste management quantities of mercury and
mercury compounds from certain industries and industrial activities. Because each facility is unique, the
recommendations presented may have to be adjusted to the specific nature of operations at your facility
or industrial activity.
A primary goal of EPCRA is to increase the public's knowledge of, and access to,
information on the presence and release and other waste management activities of EPCRA Section 313
toxic chemicals in their communities. Under EPCRA Section 313, certain facilities exceeding reporting
thresholds are required to submit annual toxic release forms. These forms must be submitted to EPA
and State or Tribal governments, on or before July 1, for activities in the previous calendar year. The
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owner/operator of the facility on July 1 of the reporting deadline is primarily responsible for the report,
even if the owner/operator did not own the facility during the reporting year. EPCRA mandates that
EPA establish and maintain a publicly available database consisting of the information reported under
Section 313. This database, known as the Toxics Release Inventory (TRI), can be accessed through
the following sources:
EPA's Internet site, www.epa.gov/tri;
TRI Explorer Internet site, www.epa.gov/triexplorer;
Envirofacts Warehouse Internet site,
www.epa.gov/enviro/html/tris/tris_overview.html; and
EPA's annual TRI data release materials (summary information).
The objectives of this guidance document are to:
Provide explanation and assistance on EPCRA Section 313 reporting requirements
for mercury and the mercury compounds category;
Promote consistency in the method of estimating annual releases and other waste
management quantities of mercury for certain industries and industrial classes; and
Reduce the level of effort expended by those facilities that prepare an EPCRA
Section 313 report for mercury and/or the mercury compounds category.
Section 1.2 Who Must Report?
To understand the following discussion you must first understand how EPCRA defines a
facility. The term "facility" is defined as, "all buildings, equipment, structures, and other stationary items
which are located on a single site or on contiguous or adjacent sites and which are owned or operated
by the same person (or by any person which controls, which is controlled by, or which is under common
control with such person)." (EPCRA Section 328(4)). A facility may contain more than one
"establishment" (40 CFR 372.3). An "establishment" is defined as, "an economic unit, generally at a
single physical location, where business is conducted or where services or industrial operations are
performed" (40 CFR 372.3).
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EPA recognizes that for business reasons it may be easier and more appropriate for
establishments at one facility to report separately. However, the combined quantities of EPCRA Section
313 chemicals and chemical categories manufactured, processed, or otherwise used in all establishments
making up that facility must be considered for threshold determinations. Also, the combined release and
other waste management activities reported singly for each establishment must total those for the facility
as a whole (40 CFR 372.30(c)).
Note that if a facility is comprised of more than one establishment, once an activity
threshold is met by the facility, provided that the facility meets the SIC Code and employee threshold
criteria, release and other waste management activities from all establishments at the facility must be
reported (40 CFR 372.30(c)).
A facility is subject to the provisions of EPCRA Section 313, if it meets all three of the
following criteria:
It is included in Standard Industrial Classification (SIC) codes 20 through 39; SIC
code 10 (except SIC codes 1011, 1081, and 1094); SIC code 12 (except SIC
code 1241); SIC code 4911 (limited to facilities that combust coal and/or oil for
the purpose of generating power for distribution in commerce), SIC code 4931
(limited to facilities that combust coal and/or oil for the purpose of generating power
for distribution in commerce), SIC code 4939 (limited to facilities that combust coal
and/or oil for the purpose of generating power for distribution in commerce); SIC
code 4953 (limited to facilities regulated under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. section 6921 etseq.); SIC code 5169; SIC
code 5171; or SIC code 7389 (limited to facilities primarily engaged in solvent
recovery services on a contract or fee basis); and
It has 10 or more full-time employees (or the equivalent of 20,000 hours per year);
and
It manufactures (includes imports), processes, or otherwise uses any of the toxic
chemicals listed on the EPCRA Section 313 list in amounts greater than the
threshold quantities established in 40 CFR 372.25, 372.28. See Section 1.3.
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These three criteria alone, not a facility's release and other waste management quantities,
determine whether a facility must prepare an EPCRA Section 313 report. A facility that meets these
three criteria is still required to prepare an EPCRA Section 313 report even if that facility has no
releases or other waste management quantities of EPCRA Section 313 chemicals or chemical
categories.
In addition, pursuant to Executive Order 13148 entitled "Greening the Government
Through Leadership in Environmental Management," federal facilities are required to comply with the
reporting requirements of EPCRA Section 313. This requirement is mandated regardless of the federal
facility's SIC code.
Section 1.3 What are the Reporting Thresholds?
Thresholds are specified amounts of listed toxic chemicals manufactured, processed, or
otherwise used during the calendar year that trigger reporting requirements. EPCRA Section 313
establishes default reporting thresholds, but authorizes EPA to establish lower thresholds for particular
chemicals, classes of chemicals, or categories of facilities, if a different threshold is warranted. EPA has
used this authority to establish lower thresholds for Persistent Bioaccumulative Toxic (PBT) chemicals.
See 40 CFR 370.28, 64 FR 58666. The thresholds are determined separately for mercury (using the
weight of the metal) and for mercury compounds (using the weight of the entire compound). Therefore,
provided that the facility meets the SIC code and employee threshold criteria, reporting for mercury is
required:
If a facility manufactures more than 10 pounds of mercury during the calendar
year.
If a facility processes more than 10 pounds of mercury during the calendar year.
If a facility otherwise uses more than 10 pounds of mercury during the calendar
year.
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Provided that the facility meets the other two reporting requirements, reporting for the mercury
compounds category is required:
If a facility manufactures more than 10 pounds of mercury compounds during the
calendar year.
If a facility processes more than 10 pounds of mercury compounds during the
calendar year.
If a facility otherwise uses more than 10 pounds of mercury compounds during the
calendar year.
If a threshold is exceeded for both mercury and the mercury compounds category, only a single Form R
needs to be prepared. The terms manufacture, process, and otherwise use are defined in 40 CFR 372.3
as:
Manufacture means to produce, prepare, import, or compound a toxic chemical.
Manufacture also applies to a toxic chemical that is produced coincidentally during the
manufacture, processing, otherwise use, or disposal of another chemical or mixture of
chemicals, including a toxic chemical that is separated from that other chemical or
mixture of chemicals as a byproduct, and a toxic chemical that remains in that other
chemical or mixture of chemicals as an impurity.
Process means the preparation of a toxic chemical, after its manufacture, for distribution
in commerce: (1) In the same form or physical state as, or in a different form or physical
state from, that in which it was received by the person so preparing such substance, or
(2) As part of an article containing the toxic chemical. Process also applies to the
processing of a toxic chemical contained in a mixture or trade name product.
Otherwise use means any use of a toxic chemical, including a toxic chemical contained
in a mixture or other trade name product or waste, that is not covered by the terms
"manufacture" or "process." Otherwise use of a toxic chemical does not include
disposal, stabilization (without subsequent distribution in commerce), or treatment for
destruction unless:
(1) The toxic chemical that was disposed, stabilized, or treated for destruction was
received from off site for the purposes of further waste management; or
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(2) The toxic chemical that was disposed, stabilized, or treated for destruction was
manufactured as a result of waste management activities on materials received from
off site for the purposes of further waste management activities. Relabeling or
redistributing of the toxic chemical in which no repackaging of the toxic chemical
occurs does not constitute otherwise use or processing of the toxic chemical.
The quantities of mercury and mercury compounds included in threshold determinations
are not limited to the amounts released to the environment. All mercury and mercury compounds
manufactured, processed, or otherwise used must be counted toward threshold determinations.
(EPCRA Section 313 (a)). This may include mercury compounds that are generated in closed systems.
To assist facilities in determining if they may need to report, Table 1-1 below lists potential industry and
process sources of mercury and mercury compounds. For more information on threshold
determinations, see Section 2.0.
Table 1-1
Industry and Process Sources of Mercury and Mercury Compounds
Industry /Process
Metal mining: trace constituent in ore
Coal mining: trace constituent in ore
Paper manufacturing: present in wood
and chemicals
Chlor-alkali production by mercury cell
process
Plastic materials and resin manufacture:
formulation component
Importing of cadmium-mercury pigments
(no domestic production)
Special paper coatings: mercury bromide
and mercury acetic acid used in paper and
film with cathode ray tubes
Chemical manufacture: mercury
compound production, reactants,
Pharmaceuticals, and catalysts
Carbon black production: trace
constituent in crude oil
EPCRA Section 313
Activity
Processed, manufactured
(by-product)
Processed
Processed
Otherwise used
Processed
Manufactured (import),
processed
Processed
Manufactured, processed,
otherwise used
Processed
Mercury or Mercury
Compounds
Mercury and mercury
compounds
Mercury compounds
Mercury
Mercury
Mercury compounds
Mercury
Mercury compounds
Mercury and mercury
compounds
Mercury compounds
Reference1
2
2
2,3
2,3
2
16
16
2,16
2,3
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Industry /Process
Petroleum refining: trace constituent in
petroleum crude
Cement and clay products: trace
constituent in raw materials
Steel industry: coke production, trace
constituent in coal
Smelting and refining: trace constituent in
sulfide ore
Fabricated metal products: article
component (e.g., high purity copper foil)
Electronic product component (e.g,
bulbs, switches, batteries)
Other product components (e.g.,
thermometers, dental amalgam fillings)
Coal, oil, wood combustion (electric
utilities, other facility electricity
generation): traces in fuels
Waste treatment and solvent recovery:
trace constituent in waste stream
Wholesale distribution of mercury
chemicals and compounds
Bulk petroleum stations: trace
constituent in petroleum products
EPCRA Section 313
Activity
Processed, manufactured
(by-product or impurity)
Processed
Processed
Processed, manufactured
(by-product)
Processed
Processed
Processed
Otherwise used,
manufactured (by-product)
Processed, otherwise used
Processed
Processed
Mercury or Mercury
Compounds
Mercury compounds
Mercury
Mercury compounds
Mercury
Mercury and mercury
compounds
Mercury
Mercury
Mercury and mercury
compounds
Mercury and mercury
compounds
Mercury and mercury
compounds
Mercury compounds
Reference1
2,3
2,3
2,3
2,3
2,16
2,3
2,3
2,3
2
2
2
'Numbers correspond to the references listed in Section 5.0.
Section 1.4 What Other Changes to the EPCRA Section 313 Reporting Requirements Apply
to Mercury and the Mercury Compounds Category?
EPA has also made modifications and/or clarifications to certain reporting exemptions
and requirements for the PBT chemicals that are subject to the lower reporting thresholds; this includes
mercury and the mercury compounds category. Each of the changes as they apply to mercury and the
mercury compounds category is discussed in the following subsections.
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1.4.1 De Minimis Exemption
The de minimis exemption allows facilities to disregard certain minimal concentrations of
toxic chemicals in mixtures or other trade name products they process or otherwise use when making
threshold determinations and release and other waste management calculations.
EPA eliminated the de minimis exemption for EPCRA Section 313 PBT chemicals,
including mercury and the mercury compounds category. This means that facilities are required to
include all amounts of mercury and mercury compounds in threshold determinations and all amounts of
mercury and the metal portion of mercury compounds in release and other waste management
calculations regardless of the concentration of mercury and mercury compounds in mixtures or trade
name products (40 CFR 372.38(a)). However, the elimination of the de minimis exemption for
reporting PBT chemicals does not affect the applicability of the de minimis exemption to the supplier
notification requirements.
1.4.2 Alternate Reporting Threshold (One Million Pounds) and Form A
The "Alternate Threshold for Facilities with Low Annual Reportable Amounts," provides
facilities otherwise meeting EPCRA Section 313 reporting thresholds the option of certifying on a Form
A (a two-page certification statement) that they do not exceed 500 pounds for the total annual
reportable amount for that chemical, and that their amounts manufactured, processed, or otherwise used
for that chemical do not exceed one million pounds.
EPA has excluded EPCRA Section 313 PBT chemicals, including mercury and the
mercury compounds category, from eligibility for the "Alternate Threshold for Facilities with Low Annual
Reportable Amounts" (40 CFR 372.27(c)). Therefore, the alternate threshold of one million pounds
and the Form A certification statement are not options for mercury and the mercury compounds
category.
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1.4.3 Range Reporting
For facilities with total annual releases or off-site transfers of an EPCRA Section 313
chemical of less than 1,000 pounds, EPA generally allows the amounts to be reported on the Form R
either as an estimate or by using ranges.
EPA has eliminated the range reporting option for releases and other waste management
activities for EPCRA Section 313 PBT chemicals, including mercury and the mercury compounds
category. This means that for those sections of the Form R for which range reporting is an option, the
option cannot be used when reporting on mercury and/or the mercury compounds category (40 CFR
372.85(b)(15)(i)). Thus, facilities are required to report an actual number rather than a selected range.
However, the elimination of range reporting for PBT chemicals for releases and transfers does not affect
the applicability of range reporting for the maximum amount on site as required by EPCRA Section
313(g).
1.4.4 Data Precision
Facilities should report for mercury and the mercury compounds category at a level of
precision supported by the data and the estimation techniques on which the estimate is based. However,
the smallest quantity that need be reported on the Form R for mercury or mercury compounds is 0.1
pounds.
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SECTION 2.0 GUIDANCE ON ESTIMATING ENVIRONMENTAL RELEASES OF
MERCURY AND MERCURY COMPOUNDS
Section 2.1 General Guidance
EPA is providing the following guidance for use by facilities in estimating and reporting
annual releases and other waste management quantities for mercury and the mercury compounds
category. It is not designed to provide exhaustive guidance for all situations involving mercury and
mercury compounds. Please consult industry specific guidance documents applicable to your facility for
more detailed guidance. Additional information and guidance is also available from the EPA's EPCRA
Hotline, 1-800-424-9346, and the Toxics Release Inventory (TRI) website at http://www.epa.gov/tri.
EPA also publishes an annual guidance document for EPCRA Section 313 reporting entitled Toxic
Chemical Release Inventory Reporting Forms and Instructions. You should consult the most current
version before preparing any report for your facility.
This document includes concentration and emission factor data which may be used as
default values in calculating activity thresholds, releases and other waste management quantities. EPA
recommends that facilities complete these calculations using best readily available information applicable
to their operations, even when it differs from the data provided herein. EPA also recommends that
facilities maintain documentation of the basis for making these estimates. Facilities are not required to
perform additional testing for EPCRA Section 313 reporting.
2.1.1 Threshold Determination
As mentioned in Section 1.3, EPA lowered the reporting threshold for mercury and the
mercury compounds category to 10 pounds per year for each of the reporting activities (manufacturing,
processing, and otherwise use). Each activity threshold is determined independently. When determining
if a threshold is exceeded for mercury, you should calculate the amount of mercury manufactured, the
amount of mercury processed, and the amount of mercury otherwise used. To determine if a threshold
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is exceeded for the mercury compounds category, use the entire weight of the mercury compounds for
each threshold determination. Quantities required to meet the threshold for fuels and other materials may
be found in tables 3-1 through 3-4. The following example illustrates key points in determining if a
threshold has been exceeded for mercury or the mercury compounds category.
Example - Threshold Determination.
Your facility processes 1,000 pounds of mercury during the calendar year, otherwise uses 8 pounds of mercury,
and manufactures 5 pounds of a mercury compound as a by-product. Your facility did not exceed the otherwise
use threshold for mercury, nor the manufacturing threshold for mercury compounds. Your facility did exceed the
processing threshold for mercury, and must prepare a Form R report for mercury. (Note: if your facility had
exceeded an activity threshold for both mercury and mercury compounds, you need only prepare one Form R.)
Since you determined that you must submit an EPCRA Section 313 Form R report for mercury, you must calculate
all releases and other waste management activity quantities of mercury from your facility, including releases and
other waste management quantities of mercury from the otherwise use activity. You are not required to submit a
Form R for mercury compounds.
If you do not know in what form mercury is present in a material, EPA recommends in
most cases assuming elemental mercury. For fuels, assume that mercury is present as mercury
compounds. In the absence of other data, EPA recommends assuming the mercury compound is Hg2O
for threshold calculations. If you burn fuels on site, elemental mercury emissions are coincidentally
manufactured. The amount of mercury emissions should be applied to the manufacturing threshold for
elemental mercury.
The concentration of mercury or mercury compounds may be known as a specific
concentration, as an average, as a range, or as an upper or lower boundary. If you know the specific
concentration of the mercury or mercury compounds in the stream, you must use that value (40 CFR
372.30 (b)(i). If only an average concentration is provided (e.g., by the supplier), use that value in the
threshold calculation. If only the upper bound concentration is known, you must use that value in the
threshold calculation (40 CFR 372.30(b)(3)(ii)). If only the lower bound concentration is known, or the
concentration is given as a range of an upper and lower boundary, EPA has developed the following
guidance on the use of this type of information in threshold determinations.
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If the concentration is given as a range or an upper and lower boundary, EPA
recommends that you use the mid-point in your calculations.
If only the lower bound concentration of mercury or mercury compounds is given
and the concentrations of the other components are given, EPA recommends that
you subtract the other component total from 100% to calculate the upper bound of
the mercury or mercury compound(s). EPA then recommends that you determine
the mid-point for use in your calculations.
If only the lower bound concentration of mercury or mercury compounds is given
and the concentration of the other components is not given, EPA recommends that
you assume the upper bound for the mercury or mercury compounds is 100% and
use the mid-point. Alternatively, product quality requirements or information
available from the most similar process stream may be used to determine the upper
bound of the range.
Example - Using a Typical Concentration to Determine Amount Processed
During Carbon Black Production
Your facility manufactures carbon black. Using inventory records, you know that 30 million pounds of crude oil
was processed through your facility. Using a mercury concentration of 1.5 ppm in the crude oil, you determine if
you have exceeded the processing threshold.
(1.5 Ib mercury / 1 x 106 Ib crude oil) x ( 30,000,000 Ib crude oil) = 45 Ib/yr
Your facility exceeded the 10 Ib/yr threshold and you must prepare a Form R for that year.
Chemical production facilities may manufacture mercury compounds for other industry
use. Production records are a great source for determining the amount manufactured. You must also
include the importing of mercury or mercury compounds in your manufacturing threshold determination.
(EPCRA Section 313(b)(l)(C)(i)). You can obtain these amounts from purchasing records.
2.1.2 Exemptions
EPA has established four classes of exemptions: de minimis, article, facility/laboratory
related, and activity related. EPCRA Section 313 chemicals or chemical categories that qualify for these
exemptions may be excluded from threshold determinations and release or other waste management
estimations.
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The PBT chemical final rule states that the de minimis exemption does not apply to PBT
chemicals or chemical categories (40 CFR 372.38(a)).
For the purpose of the article exemption, an article is defined as a manufactured item
that:
Is formed to a specific shape or design during manufacture;
Has end-use functions dependent in whole or in part upon its shape or design; and
Does not release an EPCRA Section 313 chemical or chemical category under
normal conditions of processing or otherwise use of the item at the facility (40 CFR
372.3).
If you receive a manufactured article from another facility (e.g., a thermostat containing
mercury), the mercury in that article may be exempt from threshold determinations and release and other
waste management calculations if you meet the following criteria:
You process or otherwise use it without changing the shape or design; and
Your processing or otherwise use does not result in the release of more than 0.5
pounds of mercury or any other TRI chemical in a reporting year from all like
articles.
Recycling of releases from articles allows them to remain as exempt articles.
Any mercury or mercury compounds manufactured, processed, or otherwise used in
laboratories under the supervision of a technically qualified individual may be exempt from threshold
determinations and release and other waste management calculations (40 CFR 372.38(d)). Note that
the laboratories exemption does not apply in the following cases:
1) Specialty chemical production;
2) Manufacture, processing, or use of toxic chemicals in pilot plant scale operations;
and,
3) Activities conducted outside the laboratory.
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The activity-related exemptions are available for mercury and mercury compounds (40
CFR372.38(c)).
In addition to the four exemptions discussed above, EPA has established guidance for
two special circumstances that may apply to facilities manufacturing, processing, or otherwise using
mercury and mercury compounds. This guidance applies to coal extraction and metal mining activities.
Regarding coal extraction, per 40 CFR 372.38(g), if a toxic chemical is manufactured, processed, or
otherwise used in extraction by facilities in SIC code 12, a person is not required to consider the
quantity of the toxic chemical so manufactured, processed, or otherwise used when determining whether
an applicable threshold has been met under § 372.25, § 372.27, or § 372.28, or determining the
amounts to be reported under § 372.30. For additional information regarding coal extraction, refer to
Section 313 Emergency Planning and Community Right-to-Know Act Guidance for Coal Mining
Facilities.
Regarding metal mining overburden, per 40 CFR 372.38(h), if a toxic chemical that is a
constituent of overburden is processed or otherwise used by facilities in SIC code 10, a person is not
required to consider the quantity of the toxic chemical so processed, or otherwise used when
determining whether an applicable threshold has been met under § 372.25, § 372.27, or § 372.28, or
determining the amounts to be reported under § 372.30. For additional information regarding metal
mining, refer to Section 313 Emergency Planning and Community Right-to-Know Act Guidance for
Metal Mining Facilities.
Section 2.2 Methods for Calculating Annual Releases and Other Waste Management
Quantities of Mercury and Mercury Compounds
When reporting for mercury or the mercury compound category, only the amount of
metal mercury needs to be reported on the Form R. EPA recommends that you calculate mercury
releases and other waste management activities by following these steps:
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1. Identify the processes/operations where mercury or mercury compounds may be
manufactured, processed, or otherwise used.
2. Determine potential sources of releases and other waste management activities from
these processes (e.g., process wastewater discharge, emissions from operations).
3. Identify the types of releases and other waste management activities. These types
correspond to the Form R (e.g., stack emissions, sent off site for recycling).
4. Determine the most appropriate estimation method(s) and calculate the estimates
for release and other waste management quantities.
During threshold determinations, you should have identified the processes and operations
in which mercury (and mercury compounds) are found. Potential release and other waste management
sources of mercury include the following:
Accidental spills and releases; Pumps;
Air pollution control devices Recycling and energy recovery
(e.g., baghouses, electrostatic by-products;
precipitators, and scrubbers) Storage tanks;
Clean up and housekeeping Tower stacks;
practices; Transfer operations;
Combustion by-products; Treatment sludge;
Container residues; Volatilization from processes;
Fittings; and
Process discharge stream; Waste treatment discharges.
After determining the release and other waste management activity sources of mercury
and mercury compounds, you are ready to determine the types of releases and other waste management
activities. These final destinations of mercury (not including incorporation into a final product)
correspond to elements of the Form R. The potential types of releases and other waste management
activities include:
Fugitive or nonpoint air emissions (Part n, Section 5.1 of Form R): Mercury
emissions are considered to be fugitive if not released through stacks, vents, ducts,
pipes, or any other confined air stream. You must include (1) fugitive equipment
leaks from valves, pump seals, flanges, compressors, sampling connections, open-
ended lines, etc.; (2) evaporative losses from surface impoundments and spills; (3)
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releases from building ventilation systems; and (4) any other fugitive or non-point air
emissions.
Stack or point air emissions (Part n, Section 5.2 of Form R): Mercury emissions
are considered to be stack if released through stacks, confined vents, ducts, pipes,
or other confined air streams. You must include storage tank emissions. Air
releases from air pollution control equipment would generally fall in this category.
Using the control efficiency of an air pollution control device, you can determine
how much mercury is released through the air device.
Discharges to receiving streams or water bodies (Part n, Section 5.3 of Form R):
Mercury may be released in wastewater directly from the process or from a
treatment system. Monitoring is often performed at either type of outfall. This
information can be used to determine the concentration of mercury leaving the
facility.
Underground injection on site (Part II, Section 5.4 of Form R): This waste
management type is not common for mercury and mercury compounds.
Disposal to land on site (Part n, Section 5.5 of Form R): This type of release may
occur if materials containing mercury or mercury compounds are spilled during
processing or transfer operations.
Disposal of mercury or mercury compounds in a landfill.
Discharges to Publicly Owned Treatment Works (POTW) (Part n, Section 6.1 of
Form R): As with the receiving stream discharge, monitoring may be available to
determine the mercury concentration in a waste stream from a process or from a
treatment operation.
Transfers to other off-site locations (Part n, Section 6.2 of Form R): This type
includes transferring mercury off site for recovery. Other sources include used
baghouse wastes sent to landfills, or other mercury wastes sent off site for disposal,
treatment, or recycling.
On-site waste treatment (Part II, Section 7A of Form R): You should report the
amount of mercury treated by your facility. Following treatment, mercury may be
present in sludge or the water.
On-site energy recovery (Part n, Section 7B of Form R): EPA believes that
chemicals that do not contribute significant heat energy during the combustion
process should not be considered for energy recovery. Therefore, mercury and the
16
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metal portion of mercury compounds should not be reported as combusted for
energy recovery (rather consider mercury as undergoing on-site treatment).
On-site recycling (Part n, Section 7C of Form R). If you perform mercury or
mercury compound recycling (for example at the mercury cell process), you should
report the amount recycled in Section 7C of the Form R.
After you have identified all of the potential sources for release and other waste
management activity types, you must estimate the quantities of mercury and the mercury portion of
mercury compounds released and otherwise managed as waste. EPA has identified four basic methods
that may be used to develop estimates (each method has been assigned a code that must be included
when reporting). The methods and corresponding codes are:
Monitoring Data or Direct Measurement (M);
Mass Balance (C);
Emission Factors (E); and,
Engineering Calculations (O).
Descriptions of these techniques are provided in the U.S. EPA publication, Estimating
Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory Forms (1).
Many data sources exist for these (and other) methods of developing estimates. Table 2-
1 presents potential data sources and the estimation methodology in which each estimation source is
most likely to prove useful. Based on site-specific knowledge and potential data sources available, you
should be able to determine the best method for calculating each release and other waste management
activity quantity.
17
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Table 2-1
Potential Data Sources for Release and
Other Waste Management Calculations
DATA SOURCES
Monitoring Data
Air permits
Continuous emission monitoring
Effluent limitations
Hazardous waste analysis
Industrial hygiene monitoring data
NPDES1 permits
Outfall monitoring data
POTW pretreatment standards
RCRA2 permit
Stack monitoring data
New Source Performance Standards
Title V Permit Data
MACT Standards
Emission Factors
Mass Balance
Air emissions inventory
Hazardous material inventory
Hazardous waste manifests
MSDSs4
Pollution prevention reports
Spill event records
Supply and purchasing records
AP-423 chemical specific emission factors
Facility or trade association derived chemical-
specific emission factors
Engineering Calculations
NTI6 database
Facility non-chemical specific emission factors.
Henry's Law
Raoult'sLaw
SOCMF3 or trade association non-chemical specific
emission factors
Solubilities
Volatilization rates
'National Pollutant Discharge Elimination System.
2Resource Conservation Recovery Act.
Compilation of Emission Factors, U.S. EPA.
4Material Safety Data Sheets.
'Synthetic Organic Chemicals Manufacturing Industry.
^National Toxic Inventory.
7Maximum Achievable Control Technology.
18
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SECTION 3.0 SOURCES OF MERCURY AND MERCURY COMPOUNDS
This section provides an overview of where EPA believes mercury and mercury
compounds are likely to be found at facilities and what operations may manufacture, process, or
otherwise use mercury or mercury compounds. You should determine if these sources apply to your
facility.
Section 3.1 Mercury in Raw Materials
Raw materials processed by facilities may contain metal mercury or mercury compounds
as a trace constituent in chemicals (e.g., chlorine), metal ores, petroleum products, and coal.
Mercury and mercury compounds are present in metal ores, such as copper, lead, zinc,
gold, and silver. Mercury and its compounds are also trace constituents in coal, oil, or wood that is
processed or otherwise used by a facility. Table 3-1 lists some common concentrations of mercury in
the above mentioned sources, and Table 3-2 lists average mercury concentrations from coal sampled at
electric utilities. Note that the concentrations of mercury in metal ores vary from mine to mine.
Table 3-1
Quantity of Raw Materials Required to Meet the Reporting Threshold
Raw Material
Copper ores
Gold ores
No. 2 fuel oil2
No. 6 fuel oil2
Concentration Mercury,
ppm
0.5
9
0.001
0.00067
Reference1
11
11
13
12
Quantity Needed to Meet Threshold
(pounds for ores, gallons for oil)3
2.00 xlO7
l.llxlO6
1.41 x 109
1.89 xlO9
'Numbers correspond to the references listed in Section 5.0.
Constituents are most likely metal compounds rather than elemental mercury. Mercury is listed in this table because
concentration data are for only the metal occurring in the fuel. Concentrations for metal compounds would be
somewhat higher depending on the metal compound.
3Assumes the following densities: No. 2 Fuel Oil - 7.1 Ib/gallon; No. 6 fuel Oil - 7.9 Ib/gallon.
19
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Table 3-2
Quantity of Solid Fuels Required to Meet the Reporting Threshold
Coal Type
Anthracite
Bituminous
High Sulfur Bituminous
Low Sulfur Bituminous
Lignite
Petroleum Coke
Subbituminous Coal
Tires
Waste Anthracite
Waste Bituminous Coal
Waste Subbituminous Coal
Average Mercury1
Content, ppm
0.16
0.11
0.10
0.09
0.11
0.05
0.07
0.06
0.19
0.46
0.12
Quantity Needed to Meet Threshold (pounds)
6.25 x 107
9.09 xlO7
l.OOxlO8
l.llxlO8
9.09 xlO7
2.00 xlO8
1.43xl08
1.67xl08
5.26 xlO7
2.17xl07
8.33 x 107
Source: USEPA, Electric Utility Steam Generating Units Hazardous Air Pollutant Emission Study: Data - Coal
Analysis Results (Mercury Information Collection Request (ICR), 1999). Office of Air Quality Planning and
Standards, Unified Air Toxics Website. December 2000. http://www.epa.gov/ttn/uatw/combust/utiltox/utoxpg.html
'Mercury is expected to be present in coal as metal compounds, and consequently, are expected to be at higher
concentrations than reported in the table.
The scientific literature indicates that the concentration of mercury has been measured in
many sources of crude oil. In one recent article, 76 crude samples were measured with an average
concentration of 1.5 ppm (12). The actual concentrations varied over four orders of magnitude. EPA
recognizes that this is enormous variability, and that many facilities use crude oils with a mercury
concentration well below 1.5 ppm. In the absence of site-specific information, EPA recommends that
facilities contact their trade association or other facilities to determine whether mercury concentration
data is available for the type of crude oil they use. The mean of 1.5 ppm may be used as a default value.
In the absence of data about the specific form of mercury, EPA recommends that facilities assume all
mercury is in the form of mercurous oxide, or Hg2O. As always, facilities should use the best readily
available information that is applicable to their operations.
20
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Coal and oil are common fuel sources at many facilities covered under EPCRA Section
313, and are used especially for electric power generation. Coal is processed at coal mining and coke
production facilities. Oil feedstocks (including crude oil, No. 2 fuel oil, and No. 6 fuel oil) are processed
through carbon black production facilities, petroleum refining facilities, and bulk stations and terminals.
Portland cement facilities may process mercury or mercury compounds as an impurity in
raw materials, and otherwise use mercury compounds during fuel combustion. Some typical
concentrations of mercury in cement manufacturing process streams are listed in Table 3-3.
Table 3-3
Quantity of Cement Manufacturing Streams Required to Meet the
Reporting Threshold
Process Stream
Raw mix
Waste-derived fuels
Clinker product
Cement kiln dust
Mercury Concentration
<0.01 ppm
<1.5 ppm
<0.01 ppm
< 0.5 ppm
Quantity Needed to Meet Threshold
(pounds)
1.00 xlO9
6.67 xlO6
1.00 xlO9
2.00 xlO7
Source: Radian Corporation, Trial Burn Report. 1995.
Mercury or mercury compound impurities may be present in chemicals used by your
facility. For example, chlorine used by a pulp mill may contain a mercury impurity if manufactured by the
mercury cell process.
Copper and lead smelting and refining facilities may process mercury or mercury
compounds as an impurity in the sulfide ore. At primary lead smelting operations, the amount of mercury
present in the ore is approximately 0.0004 pounds per ton of ore concentrate (5, p. 4-60).
21
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Section 3.2 Mercury Recovery Operations
The manufacture and subsequent processing of mercury may result from a facility's
mercury recovery activities. A facility may recover liquid mercury from dismantled equipment, or
recover mercury from scrap and industrial wastes using a thermal or chemical extractive process. Major
sources of recycled or recovered mercury include scrap from instrument and electrical devices (lamps
and switches), wastes and sludges from electrolytic refining plants, and mercury batteries. Secondary
smelting operations may recover mercury from scrap for reuse or sale, and gold mining facilities may
manufacture mercury as a by-product.
Section 3.3 Mercury Components
Mercury may be incorporated into final products such as lamps, switches, and batteries.
Although the use of mercury has declined, facilities may still exceed the 10-pound processing or
otherwise use threshold.
Electrical apparatus manufacturing facilities may process mercury as an article
component in products such as electrical switches, thermal-sensing devices, fluorescent lamps, and
copper foil. The electrical apparatus manufacturing industry primarily uses mercury as an electrical
contact in electric switch production. High-purity copper foil production also uses mercury as an
electrical contact. Mercury may be a component in thermal sensing devices, in which it expands upon
heating, activating the controls. Fluorescent lamp manufacturers inject mercury vapor into lamps.
In addition, mercury and mercury compounds may be processed by facilities as a
component in thermometers, dental amalgams, and batteries. Mercury is a component in mercuric
oxide, silver oxide, zinc-air, carbon-zinc, and alkaline batteries. As of 1996, mercury is legally
prohibited from being added as a corrosion inhibitor in most alkaline batteries (8). However, it is
present in alkaline battery casings still in use as a side reaction inhibitor and corrosion inhibitor. Table 3-
4 lists the concentration of mercury in common articles.
22
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Table 3-4
Quantity of Common Articles Containing Mercury Required to Meet the
Reporting Threshold
Article Type
Mercuric oxide battery
Silver oxide battery
Zinc - Air battery
Carbon - Zinc
Alkaline manganese button battery
4' Fluorescent Lamp
Ampoules1"
Thermostats15
Mercury Content (per
article)
30 - 40%
7.7xlO-6lb
1.99xlQ-5lb
0.01%
2.4xlO'5lb
2.56xKr5lb
6.2xlQ-3lb
8.8xlO'3lb
Reference
5, p. 4-20
15
15
30
15
14
17
17
Number of Articles
Required to Meet
Threshold
a
1.30 xlO6
5.03 x 105
a
4.17xl05
3.91 x 105
1.61 x 103
1.14xl03
aNo information on the weight of mercuric oxide or carbon-zinc batteries is available.
b Thermostats may contain multiple ampoules. The mercury content provided is an average value.
Although mercuric oxide batteries are the only batteries currently manufactured with
mercury and mercury compounds as main components, mercury may be recovered from the other
battery types.
Section 3.4 Mercury and Mercury Compounds in the Chemical Industry
Facilities covered by EPCRA Section 313 reporting requirements include chemical
facilities that manufacture, process, or otherwise use mercury or mercury compounds. Some industries
include chlor-alkali manufacturing, inorganic or organic mercury compound production, and custom
compound resins manufacture.
Chlor-alkali production using the mercury cell process accounts for the largest
percentage of commercial consumption of mercury. However, the amount of chlorine produced using
the mercury cell process has declined significantly over the last 20 years. The chlor-alkali industry now
23
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favors a membrane cell process that uses no mercury, is more energy-efficient, and produces mercury-
free products.
Inorganic chemical and industrial chemical production plants may manufacture mercury
compounds. The amount of mercury used as a raw material should be included in the processing
threshold determination. The amount of mercury compounds produced should be included in the
manufacturing threshold.
In addition to facilities manufacturing mercury compound products, other facilities may
import, process, or otherwise use mercury reagents or catalysts. If a reaction occurs, mercury
compounds may be manufactured. Mercury may also be present in industrial or commercial grade
sulfuric acid.
Mercury and mercury compounds may be contained in waste streams received by
facilities covered under EPCRA Section 313. A facility must consider the treatment or combustion of
these waste streams containing mercury or mercury compounds during threshold determinations. The
concentration in the waste stream will vary.
Section 3.5 Combustion of Fuels Containing Mercury
All EPCRA Section 313 chemicals contained in fuels combusted for energy production
are considered otherwise used. The amount of mercury and mercury compounds present in the fuel
(e.g., coal, fuel oil) should be included in the otherwise use threshold. If you do not know the mercury
compound present in the fuel, EPA recommends using Hg2O for threshold calculations of otherwise use.
Recall that mercury and mercury compounds are separately listed substances, and threshold calculations
should be made for them separately.
Current information indicates that elemental mercury and mercury compounds found in
coal may be either converted to other mercury compounds or to elemental mercury during the
24
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combustion process. The percent conversion is likely a function of several variables. (Study of
Hazardous Air Pollutant Emissions from Electricity Generating Units - Final Report to Congress,
February 1998). In the absence of better information, EPA recommends that facilities assume that the
form of mercury in the coal is mercurous oxide (Hg2O). The estimated quantity of mercurous oxide is
then applied towards the ten pound otherwise use threshold determination. EPA also recommends that
facilities assume that all releases and other waste management quantities of mercury from the combustion
of coal are in the form of elemental mercury. These estimates of elemental mercury are then used
toward ten pound manufacturing threshold determinations.
For fuels other than coal, EPA recommends using the same assumptions. Unless
facilities have information to indicate otherwise, EPA recommends they assume that they manufacture
elemental mercury during combustion, and that 100% of the mercury compounds in the fuel are
converted to elemental mercury. As with coal, apply the weight of the metal, rather than the metal
compound toward the manufacturing threshold for mercury.
25
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SECTION 4.0 RELEASE AND OTHER WASTE MANAGEMENT CALCULATIONS
The release and other waste management calculations provided in this section
demonstrate some available techniques you can use to calculate your facility's releases and other waste
management quantities of mercury and metal portions of mercury compounds. You should determine
the best information available for your operation and decide which calculation method works best for
you.
Section 4.1 Mercury and Mercury Compound Emissions
Fuel combustion activities and other heated processes that process or otherwise use
mercury and mercury compounds can generate mercury emissions. Following air treatment, mercury
emissions may still be released from the stack. The type of air pollution devices used at your facility may
dictate the final destination of the controlled mercury (e.g., dust in a baghouse or part of scrubber
wastewater). Table 4-1 presents some common operation sources of mercury emissions.
Table 4-1
Sources of Mercury Emissions
Facility/Process Type
Gold mining
Secondary mercury recovery: thermal treatment
Mercury compound production
Chlorine production using the mercury cell process
Mercuric oxide battery manufacturing
Electrical switch manufacturing
Tungsten bar sintering
Copper foil production
Fluorescent lamp manufacturing
Operation Sources of Mercury Emissions
Pretreatment roaster, Retort
Retort or furnace operations, Distillation, After
charcoal filters
Reactor, Drier, Filter, Grinder, Transfer operations
By-product hydrogen stream, End box and cell room
ventilation
Grinding, Mixing, Sieving, Pelleting, Consolidating
Welding, Filling, Transfer operations, Testing, Spills or
breaks
Sintering, Final density measurement
Drum room, Treating room
Mercury purification and transfer, Parts repair, Mercury
injection, Broken lamps, and Spills
26
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Table 4-1 (Continued)
Facility/Process Type
Fluorescent lamp recycling
Thermometer manufacturing
Coal and oil combustion
Waste combustion
Coke production
Primary lead smelting
Copper smelting
Petroleum refining
Pulp and paper production
Operation Sources of Mercury Emissions
Collection, Crushing
Mercury purification and transfer, Filling, Heating-out
process
Utility boiler exhaust, Bottom and fly ash handling
Exhaust stack, Bottom and fly ash handling
Coal preparation and handling, Fugitive emissions from
oven
Sintering, Blast furnace
Roasting, Smelting furnace
Distillation, Cracking, Conversion steps
Chemical recovery
Using emission factors is the most common way to determine the amount of mercury
released to air. If your facility uses an air pollution control device, you can use the capture and control
efficiency to determine the quantity of fugitive and stack emissions. Depending on the type of device, the
controlled mercury air emissions may become part of a wastewater stream or baghouse dust. Sources
of emission factors include U.S. EPA's Compilation of Emission Factors (AP-42) (9), trade association
chemical-specific factors, and other literature values.
The Unified Air Toxics Website: Electric Utility Steam Generating Units Hazardous Air
Pollutant Emission Study (http://www.epa.gov/ttn/uatw/combust/utiltox/utoxpg. html) provides speciated
mercury testing data for coal combustion collected for the 1999 Information Collection Request (ICR) .
Although the data were collected from utility boilers, it may be used for non-utility boilers. Table 4-2
provides the percent of the mercury present in the coal which is released to the air based on coal type,
boiler type, and air pollution control device. When determining mercury emissions to air, EPA
recommends using data with the same (or most similar) fuel type, boiler type, and control devices. For
more details on the data provided, refer to the website.
27
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Table 4-2
Percent Mercury Present in Coal Which is Released to Air
Coal Type
Bituminous
Bituminous and Pet Coke
Sub-bituminous
Lignite
Lignite
Bituminous
Sub-bituminous
Sub-bituminous
Bituminous
Sub-bituminous
Bituminous
Sub-bituminous
Lignite
Bituminous
Lignite
Lignite
Bituminous
Sub-bituminous
Lignite
Lignite
Sub-bituminous
Bituminous
Bituminous
Bituminous
Bituminous
Boiler Type
PC Boiler
PC Boiler
PC Boiler
PC Boiler
Cyclone Boiler
PC Boiler
PC Boiler
Cyclone Boiler
PC Boiler
PC Boiler
PC Boiler
PC Boiler
PC Boiler
Cyclone Boiler
PC Boiler
Cyclone Boiler
PC Boiler
PC Boiler
PC Boiler
Cyclone Boiler
PC Boiler
PC Boiler
PC Boiler
PC Boiler
PC Boiler
Air Pollution
Control Device
CS-ESP
CS-ESP
CS-ESP
CS-ESP
CS-ESP
HS-ESP
HS-ESP
HS-ESP
FF
CS-FF
PM Scrubber
PM Scrubber
PM Scrubber
PM Scrubber
CS-ESP and FF (COHPAC)
Mechanical Collector
SDA/FF
SDA/FF
SDA/FF
SDA/FF
CS-ESP/SDA
DSI and CS-ESP
SCR and SDA/FF
SNCR and CS-ESP
CS-ESP and Wet FGD
Scrubber
% Mercury Present in
Coal Which is
Released to Air
53.52
45.72
85.52
98.53
80.09
87.98
86.54
99.96
16.90
27.57
85.87
91.63
67.23
76.71
95.07
99.89
1.78
74.60
82.62
90.68
62.06
55.11
2.44
9.1
18.77
28
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Table 4-2 (Continued)
Coal Type
Bituminous
Bituminous
Sub-bituminous
Sub-bituminous
Lignite
Bituminous
Bituminous/Waste
Bituminous
Lignite
Lignite
Waste Anthracite
Bituminous
Bituminous
Boiler Type
Cyclone Boiler
PC Boiler
PC Boiler
PC Boiler
PC Boiler
PC Boiler
FBC
FBC
FBC
FBC
FBC
Stoker
Stoker
Air Pollution
Control Device
CS-ESPandWetFGD
Scrubber
HS-ESPandWetFGD
Scrubber
CS-ESPandWetFGD
Scrubber
HS-ESPandWetFGD
Scrubber
CS-ESPandWetFGD
Scrubber
CS-FFandWetFGD
Scrubber
CS-FF
SCR and CS-FF
CS-ESP
CS-FF
CS-FF
CS-FF/SDA
CS-ESP and Wet FGD
Scrubber
% Mercury Present in
Coal Which is
Released to Air
43.70
44.95
64.88
67.38
62.52
3.59
0.11
24.19
61.71
42.95
0.26
5.75
31.64
PC: Pulverized coal
FBC: Fluidized bed combustor
CS-ESP: Cold-side electrostatic precipitator
HS-ESP: Hot-side electrostatic precipitator
FF: Fabric filter
PM: Particulate matter
FF(COHPAC): Fabric filter pilot unit (compact hybrid particulate collector)
SDA: Spray dryer absorber (dry scrubber)
DSL Duct sorbent injection
SCR: Selective catalytic reduction
FGD: Flue gas desulfurization
SNCR: Selective non-catalytic reduction
Source: U.S. EPA. Electric Utility Steam Generating Units Hazardous Air Pollutant Emission Study (Mercury ICR).
Office of Air Quality Planning and Standards. Unified Air Toxics Website-Control Device Analysis. December 2000.
http://www.epa.gov/ttn/uatw/combust/utiltox/utoxpg.html
29
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The data provided in Table 4-2 is derived from information which may be found on the
Unified Air Toxics Website (http://www.epa.gov/ttn/uatw/combust/utiltox/utoxpg.html). This data may
be incorporated into AP-42 at some future date. As always, if a facility has other means of estimating
emissions which are more applicable to that site, they may be used.
After determining the quantity of mercury released to the air, facilities must also
determine the quantity of mercury in the bottom ash and collected by the control device. A mass
balance calculation using the total amount of mercury in coal (see Table 3-2) may be used to determine
these quantities. The release or waste management of the mercury in bottom ash or from the control
device (e.g., effluent from a wet scrubber) must be reported on the Form R.
If the data in Table 4-2 do not apply to your boiler, you may use an uncontrolled
emission factor for coal combustion of 16 lb/1012 Btu, as provided in AP-42(9).
The following example shows how you can use Table 4-2 to estimate mercury emissions
from coal combustion.
30
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Example - Mercury Emission Calculation
Your facility combusts lignite coal in a fluidized bed combustor. You feed 0.5 million tons of lignite coal into the
boiler during the reporting year. You control boiler emissions using a cold-side electrostatic precipitator (CS-ESP).
The ash is sent to an on-site landfill.
First, you complete the activity threshold determinations for otherwise use and manufacturing. Table 3-2 lists the
average mercury concentration in lignite coal as 0.11 ppm.
A) Otherwise use: According to EPA's recommendation, assume the mercury in the coal is in the form of
mercurous oxide, or Hg2O.
Amount of mercury compound otherwise used:
(0.5 x 106 tons coal) x (2,000 Ib/ton) x (0.11 Ib mercury/ 1 x 106 Ib coal) x (1.04 Ib Hg2(Mb Hg) = 114 Ib
mercurous oxide
This is the amount of mercurous oxide in the coal. Since the mass of this mercury compound is higher than 10 Ib,
your facility exceeds the reporting threshold for mercury compounds.
B) Manufacturing: In performing the manufacturing threshold calculations, assume the form of mercury
manufactured in the combustion chamber is elemental mercury.
Amount of mercury manufactured:
(0.5 x 106 tons coal) x (2,000 Ib/ton) x (0.11 Ib mercury/ 1 x 106 Ib coal) = 110 Ibs. mercury
This is the amount of mercury manufactured as a result of the combustion of coal. Since this value is greater than
10 Ib, your facility exceeds the reporting threshold for mercury.
Although your facility exceeds activity thresholds for both mercury compounds and mercury, EPA recommends
that you submit one combined Form R. When filing Section 1 of Form R, identify the chemical reported as mercury
compounds. Releases and other waste management quantities are to be calculated as elemental mercury.
To estimate mercury releases to air, you use the data provided in Table 4-2. Table 4-2 lists the percent of mercury
in coal emitted to the air from lignite coal in a fluidized bed combustor (FBC) with a cold-side electrostatic
precipitator as 61.71 percent.
Mercury air emissions:
(110 Ib mercury) x (61.71%) = 68 Ib/yr mercury
You should report this quantity in Section 5.2 of the Form R.
The remaining 42 Ib of the mercury emitted is collected from the control device and bottom ash, and is sent to an
on-site landfill. You should report this quantity in Section 5.5 of the Form R.
-------
AP-42 includes emission factors for fuel oil and wood combustion. Mercury emissions
from distillate fuel oil combustion can be calculated using an emission factor of 3.0 lb/1012 BTU
(uncontrolled). The average mercury emission factor from No. 6 fuel oil combustion is 0.000113
lb/1,000 gal (uncontrolled). Mercury emissions from wood combustion operations with particulate
matter control average 0.00000515 Ib/ton (wet, 50% moisture; >4500 Btu/lb heating value;
miscellaneous control devices). The following example shows how to calculate mercury emissions using
emission factors.
Example - Mercury Emission Calculation Using Emission Factors
Your facility uses 100 million gallons of No. 6 fuel oil to generate electricity during the reporting year. You have
determined that you exceed the 10-pound reporting threshold for mercurous oxide and must calculate all releases
and other waste management activity amounts.
After evaluating your options, you decide to use an AP-42 emission factor for your calculation.
Calculate the amount of mercury emissions using the AP-42 emission factor: 0.000113 lb/1000 gal.
Amount of mercury emissions:
(100,000,000 gal/yr) x (0.000113 lb/1000 gal) = 11 Ib/yr
If you do not have any controls on the boiler, you should report this amount plus any additional mercury fugitive
emission amounts in Section 5.1 and 8.1 of the 2000 Form R.
Pulp and paper mill mercury emissions occur primarily at chemical recovery operations.
Table 4-3 lists emission factors for the combustion sources.
Table 4-3
Mercury Emission Factors for Kraft Combustion Sources
Kraft Combustion Source
Average Mercury Emission Factor
(Ib/ton)
Recovery furnace, NDCE1
Recovery furnace, DCE1
Smelt dissolving tank1
Lime kiln, with ESP2
Lime kiln, with scrubbers2
2.2 x ID'6
ND(1.0xlQ-5)
3.3 x IQ-7
4.7 x IQ-6
ND (9.0 x ID'5)
32
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ND = non-detect
ESP = Electrostatic Precipitator
'Emission factors are per ton of black liquor solids fired in the recovery furnace.
2Emission factors are per ton of lime produced in lime kiln.
Source: Letter from R.C. Kaufmann, National Council of the Paper Industry for Air and Stream
Improvement, to Jeff Telander, U.S. EPA. Data provided to EPA's Office of Air Quality Planning and
Standards in connection with the MACT II rulemaking activity for pulp and paper combustion sources.
February 10, 1999.
Portland cement kiln emission factors listed in AP-42 (Reference 9, Table 11.6-9) are
based on the type of control. The average emission factor for mercury with an electrostatic precipitator
air pollution control device is 0.00022 Ib/ton. If a fabric filter (e.g., baghouse) is used, the average
emission factor for mercury is 0.000024 Ib/ton. Table 4-4 lists the AP-42 mercury emission factors
from brick manufacturing operations.
Table 4-4
Mercury Emission Factors from Brick Manufacturing
Source
Coal-fired kiln (SCC 3-05-003-13)
Natural gas-fired kiln (SCC 3-05-003-1 1)
Sawdust-fired kiln (SCC 3-05-003-10)
Sawdust-fired kiln and sawdust dryer (SCC 3-05-003-61)
Mercury Emission Factor, Ib/ton1
9.6 x ID'5
7.5 x 10-6
7.5 x IQ-6
1.1 x lO'5
SCC = Source Classification Code
'Per ton of fired brick produced.
Source = US EPA, Compilation of Air Pollutant Emission Factors, AP-42. Table 11.3-7, Fifth Edition, OAQPS.
Locating and Estimating Air Emissions from Sources of Mercury and Mercury
Compounds (EPA-454/R-97-012) contains additional information on emissions from manufacturing and
miscellaneous sources (3).
Treatment and disposal facilities may emit mercury when waste is incinerated. The
primary source of mercury emissions is the combustion gas exhaust stack. Small quantities of mercury
may be emitted with the fugitive particulates generated from bottom and fly ash handling procedures.
Mercury in the remainder of the ash should be reported as a release to land. At facilities processing
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metal and sulfide ores or coal, mercury particulate emissions may be gener-ated during material
processing. Table 4-5 lists additional emissions factors for certain processes.
34
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Table 4-5
Mercury Emission Factors
Process and Emission Control Type
Chlor-alkali mercury cell process - hydrogen vent
(uncontrolled)
Chlor-alkali mercury cell process - hydrogen vent (controlled)
Chlor-alkali mercury cell process - end box
Electrical switch manufacturing (uncontrolled)
Fluorescent lamp manufacturing (uncontrolled)
Fluorescent lamp recycling (fabric filter, carbon adsorber)
Instrument manufacturing (uncontrolled)
By-product Coke production (fabric filter, ESP)
Primary copper smelting, acid plant or wet scrubber controls
Petroleum refining - process heaters, uncontrolled
Petroleum refining - asphalt blowing, uncontrolled
Lime manufacture, coal-fired rotary kilns
Lime manufacture (fabric filter), natural-gas fired vertical kilns
Batch mix hot mix asphalt plants - dryer, hot screens, and
mixer (fabric filter)
Drum mix hot mix asphalt plants - natural gas or propane-fired
dryer (fabric filter)
Drum mix hot mix asphalt plants - oil-fired dryer (fabric filter)
Hot mix asphalt - rotary dryer (wet scrubber)
Hot mix asphalt - rotary dryer (multiple cyclone)
Hot mix asphalt - rotary dryer (knock out box, baghouse)
Hot mix asphalt - rotary dryer (single cyclone, wet scrubber)
Hot mix asphalt - rotary dryer (single cyclone, baghouse)
Hot mix asphalt - rotary dryer (knock out box, venturi
scrubber)
Hot mix asphalt - drum dryer (uncontrolled)
Portland cement kiln (ESP)
Portland cement kiln (fabric filter)
Carbon black manufacture (fabric filter)
Dental alloy production (uncontrolled)
Steel mill - Electric arc furnace (EAF)
Grey Iron foundries - cupola (uncontrolled)
Average Mercury
Emission Factor
3.3 x ID'3 Ib/ton Chlorine (Cl)
produced
1.2 x lO'3 Ib/ton Cl produced
1.0 x 10'2 Ib/ton Cl produced
8 Ib/ton mercury
8 Ib/ton mercury
1.9x 10-9Mamp
1 8 Ib/ton mercury
6.0 x ID'5 Ib/ton coke2
7.8 x 10'5 Ib/ton metal*
2.73 x lO'6 Ib/MMBtu
8.3 x 10-6 Ib/MMBtu
1.5x 10'5 Ib/ton lime
3.0 x ID'6 Ib/ton lime
4. 1 x 10'7 Ib/ton hot mix asphalt
(HMA) produced
2.4 x 10'7 Ib/ton HMA produced
2.6 x 10'6 Ib/ton HMA produced
3.9 x 10'6 Ib/ton HMA produced
5.7 x lO'6 Ib/ton HMA produced
4.73 xlO'7 Ib/ton HMA
produced
1. 63 xlO'6 Ib/ton HMA
produced
<4.0 x ID'8 Ib/ton HMA
produced
7.4 x lO'6 Ib/ton HMA produced
7.4 x 10'9 Ib/ton HMA produced
2.2 x 10'4 Ib/ton clinker produced
2.4 x 10"5 Ib/ton clinker produced
3.0 x 10'4 Ib/ton carbon black
40 Ib/ton mercury
7.2 x 10'5 Ib/ton scrap feed*
3.48 x 10'4 Ib/ton cast pipe
produced
Reference1
(9)
(9)
(9)
(3)
(3)
(3)
(3)
(3)
(10)
(28)
(29)
(3)
(3)
(9)
(9)
(9)
(24)
(24)
(24)
(25)
(26)
(23)
(27)
(9)
(9)
(3)
(3)
(10)
(21)
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Table 4-5 (Continued)
Process and Emission Control Type
Grey Iron foundries - cupola (baghouse)
Ferroalloy (FeSi alloy) production - open EAF (uncontrolled)
Ferroalloy (SiMn alloy) production - closed EAF
(uncontrolled)
Ferroalloy (FeMn alloy) production - closed EAF
(uncontrolled)
Ferroalloy (FeMn alloy) production - semi-covered EAF
(venturi scrubber)
Ferroalloy (FeMn alloy) production - semi-covered EAF
(uncontrolled)
Ferroalloy (other alloy) production - semi -covered EAF
(uncontrolled)
Secondary aluminum production - burning/drying (venturi
scrubber)
Secondary aluminum production - burning/drying (baghouse)
Secondary lead production - blast furnace (controlled)
Secondary lead production - kettle refining fugitive emissions
(controlled)
Glass manufacture (particulate control)
Brick manufacture
Pulp and paper - kraft combustion sources
Battery manufacturing - button cell process
Distillate fuel oil combustion (uncontrolled)
No. 6 fuel oil combustion (uncontrolled)
Electric utilities (power generation) - residual oil (controlled)
Industrial wood waste combustion (controlled)
Industrial wood waste combustion (uncontrolled)
Coal combustion (uncontrolled)3
Average Mercury
Emission Factor
1.587 x 1CT4 Ib/ton cast pipe
produced
3.8 x ICr5 Ib/ton alloy*
5.6 x 10"4 Ib/ton alloy*
1.68 x ICr6 Ib/ton alloy*
9.3 x ICr5 Ib/MWh
2.7 x ICr3 Ib/MWh
8.36 x ICr6 Ib/MWh
2.0 x 10'8 Ib/lb cans processed
2.8 x ICr9 Ib/lb cans processed
2.2 Ib/ton lead produced
4.7 x 10'6 Ib/ton lead produced
l.Ox ICr4 Ib/ton silica*
See Table 4-4
See Table 4-3
See Reference 3, page 5-10, for
individual unit operations
3.01b/1012Btu
1.13x lQ-4lb/l, 000 gallons
0.057 lb/ 1 x 106 gallons residual
oil burned*
5.15 x 10'6 Ib/ton wood waste
burned (wet, 50% moisture)
6.9 x 10"6 Ib/ton wood waste
burned (dry)
161b/1012Btu
Reference1
(21)
(10)
(10)
(10)
(20)
(20)
(20)
(22)
(22)
(23)
(23)
(10)
(9)
(4)
(3)
(9)
(9)
(10)
(9)
(19)
(9)
ESP = Electrostatic precipitator
MMBtu = Million BTUs
'Numbers correspond to the references listed in Section 5.0.
2Emission factor based on German coke ovens. If no other data available, assume coal cleaning reduces emissions by
20% (3).
facilities with industrial coal-fired boilers may refer to the Unified Air Toxics Website, http://www.epa.gov/ttn/
uatw/combust/utiltox/utoxpg.html, for concentrations of mercury in various types of coal.
*Emission factor converted from metric units.
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Mercury emissions may also be calculated using monitoring data. For instance, your
facility might continuously monitor stack emissions, or data might be available from short-term testing
performed at the facility. Engineering calculations, for example Raoult's law, may also be used for
calculations. Mass balances are not typically used to calculate emissions, but can be used if all other
quantities (e.g., leaving with the product, released with wastewater, disposed with solid waste) are
known, as demonstrated in the following example.
Example - Emission Estimate Using Mass Balance
Your facility manufactures mercury compound products. Based on purchase and import records, the amount of
mercury brought on site totals 200,000 pounds per year. The amount of mercury leaving with the product is
calculated to be 198,500 pounds per year.
Your facility wastewater from washdowns, tank cleanings, and scrubber operations is discharged to a POTW.
You monitor the wastewater to comply with the POTW pretreatment permit. The concentration of mercury in the
water is 3 ppmv. The volume of water discharged to the POTW during the reporting year is 250,000 gallons. The
specific gravity of mercury is 13.6.
Using the specific gravity, the density of mercury is calculated:
13.6 x (8.345 Ib water/ gal water) = 113.5 Ib/gal mercury
The amount of mercury discharged to the POTW is calculated below:
(250,000 gal water) x (3 gal mercury/1 x 106 gal water) x (113.5 Ib mercury/gal mercury) = 85 Ib mercury
This quantity should be reported in Part II, Section 6.1 and Section 8.1 of the 2000 Form R.
No solid waste sources of mercury were identified at your facility, therefore, you assume the remaining quantity
of mercury is released as fugitive emissions. The mercury fugitive emissions are calculated using the following
mass balance:
[200,000 Ibh = [198,500 Ib + 85 Ib + fugitive emissions lb]out
Mercury emissions = [200,000-198,500-85] Ibs = 1,415 Ib/yr
This quantity should be reported in Part II, Section 5.1 and Section 8.1 of the 2000 Form R.
Air emission monitoring for PBT chemicals may be required under industry National
Emission Standards for Hazardous Air Pollutants (NESHAPs), referred to as Maximum Achievable
Control Technology (MACT) Standards. The HAP list includes mercury compounds. Standards have
been finalized for some industry source categories and additional categories are upcoming.
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Section 4.2 Mercury in Wastewater
Wastewater sources of mercury include area washdowns and tank clean outs of
processes in which mercury or mercury compounds are manufactured, processed, or otherwise used. If
a wet air pollution control device (e.g., scrubber) is used at a process generating mercury emissions,
mercury can be transferred from the air stream to the water stream. This wastewater may be treated on
site, discharged to surface water or a POTW, or transferred off site for other activities. In addition to
the sources listed above, spills and one-time events may also generate a mercury-containing waste
stream.
If your facility discharges to surface water, you most likely have a NPDES or state
discharging permit. This permit may require you to monitor for mercury. You can use this information to
calculate the amount of mercury discharged to surface water. Discharges to POTWs may also require
mercury monitoring. The example below shows an approach to calculating mercury amounts using
monitoring information.
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Example - Mercury Discharged to a POTW - Monitoring Information Calculations
Your facility processes mercury in quantities greater than 10 pounds per year. Your facility is required to perform
monitoring for certain chemicals, including mercury, two times each year. The results of the monitoring were:
April 4: 2 ppm mercury (Jan - Jun)
October 5: 2.4 ppm mercury (Jul - Dec)
For the reporting year, the following water volumes were discharged to the POTW:
Jan through Mar: 425,000 gal
April through June: 555,000 gal
July through September: 345,000 gal
October through December: 390,000 gal
Convert the water flows to pounds, using a density of 8.345 Ib/gal:
425,000 gal x (8.345 Ib/gal) = 3,550,000 Ib
555,000 gal x (8.345 Ib/gal) = 4,630,000 Ib
345,000 gal x (8.345 Ib/gal) = 2,880,000 Ib
390,000 gal x (8.345 Ib/gal) = 3,250,000 Ib
Using the corresponding mercury concentrations, the amount of mercury discharged to the POTW is:
(2 Ib mercury / 1 x 106 Ib water) x (3,550,000 + 4,630,000 Ib) +
(2.4 Ib mercury / 1 x 106 Ib water) x (2,880,000 + 3,250,000) Ib
= 31 Ib/yr mercury
This quantity should be reported in Part II, Section 6.1 and Section 8.1 of the 2000 Form R.
Mass balances and engineering calculations can also be used to determine the amount of
mercury in the wastewater. If your facility treats wastewater on site, you may need to perform
engineering calculations to determine how much mercury becomes part of the waste sludge and how
much is discharged.
Section 4.3 Mercury Spills and Solid Waste Calculations
Mercury spills can include dust or solid raw materials being spilled during transfer or
process operations. Mercury or mercury compounds contained in solution, such as petroleum products,
may also be splashed or spilled. Other solid waste sources include sludge from on-site treatment, bags
or filters from air pollution control devices, and ash from combustion operations. Solid material spills
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and ash may also contribute to fugitive emissions. The amount of mercury in solids is commonly
calculated using mass balances from records (such as spill reports). Monitoring data on sludge may be
available, but as mentioned in the previous wastewater section, engineering calculations can be
performed to determine the mercury content in the sludge.
Facility specific information, such as waste analyses and process knowledge, can be
used to estimate amounts of mercury in combustion wastes. In the absence of data determined to be
better, facilities can use default values for concentrations of mercury in ash, presented in Table 4-6.
Table 4-6
Mercury Concentration in Combustion Residuals
Combustion Residual
Coal Fly Ash
Coal Bottom Ash
Oil Ash
Concentration (ppm)
12
4.2
1
Source: Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume I, Critical Review,
Batelle Pacific Northwest Laboratory for EPRI, EA5176, August 1987.
If your facility manufactures a mercury-containing by-product (e.g., at a gold mining
facility), you can use a mass balance to determine the quantity of mercury released or otherwise
managed as waste. Using facility concentrations, or literature concentrations if facility-specific ones are
not available, you can determine the quantity of mercury or mercury compounds processed at your
facility from the raw material. Mercury production records indicate how much mercury-containing by-
product is manufactured. From process and engineering knowledge, the destination of the mercury
releases and other waste management activity quantities can be determined.
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Example - Calculating Mercury Quantities using Mass Balances
The amount of gold ore mined by your facility is 1.5 million pounds during the year. The mercury content in your
ore is approximately 9 ppmw. The quantity of mercury processed through the facility may be calculated as
follows:
1,500,000 Ib ore x (9 Ib mercury/1 x 106 Ib ore) = 13.5 Ib mercury
Your production records show 10 pounds of mercury is sold as a by-product. The remaining 3.5 Ib/yris assumed
to be contained in discarded dusts swept up during area cleaning. The dust is then sent to an off-site landfill.
You should report the 3.5 Ib/yr in Part II, Section 6.2 and Section 8.1 of the 2000 Form R.
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SECTION 5.0 REFERENCES
1. U.S. EPA. Estimating Releases and Waste Treatment Efficiencies for the Toxic
Chemical Release Inventory Forms. 1999.
2. U. S. EPA. Economic Analysis of the Final Rule to Modify Reporting of Persistent
Bioaccumulative Toxic Chemicals Under EPCRA Section 313. Office of Pollution
Prevention and Toxics. October 1999.
3. U. S. EPA. Locating & Estimating Air Emissions from Sources of Mercury and
Mercury Compounds. EPA-454/R-97-012. Office of Air Quality Planning and
Standards (OAQPS). December 1997.
4. Letter from R.C. Kaufmann, National Council of the Paper Industry for Air and Stream
Improvement, to Jeff Telander, U.S. EPA. Data provided to EPA's Office of Air
Quality Planning and Standards in connection with the MACT U rulemaking activity for
pulp and paper combustion sources. February 10, 1999.
5. U.S. EPA. Mercury Study Report to Congress Vol. II: An Inventory of
Anthropogenic Mercury Emissions in the United States. Office of Air Quality
Planning and Standards, and Office of Research and Development. 1997.
6. U.S. EPA. Electric Utility Steam Generating Units Hazardous Air Pollutant
Emission Study (Mercury ICR). Office of Air Quality Planning and Standards, Unified
Air Toxics Website. December 2000.
http://www.epa.gov/ttn/uatw/combust/utiltox/utoxpg.html.
7. Radian Corporation. Trial Burn Report. December 1995. (Cited in U.S. EPA.
Economic Analysis of the Final Rule to Modify Reporting of Persistent
Bioaccumulative Toxic Chemicals Under EPCRA Section 313. Office of Pollution
Prevention and Toxics. October 1999. page D-17).
8. Public Law 104-142. Mercury - Containing and Rechargeable Battery
Management Act. 42 USC 14301. May 13, 1996.
9. U.S. EPA. Compilation of 'Air Pollutant Emission Factors, AP-42. Fifth Edition.
Office of Air Quality Planning and Standards.
10. Environment Canada. Supplementary Guide for Reporting to the National Pollutant
Release InventoryAlternate Thresholds-2000, Emission Factors Database.
National Pollutant Release Inventory. January 2001.
http://www.ec.gc.ca/pdb/npri/npri_gdocs_e.cfm#gdocs.
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11. Van Horn, W. Materials Balance and Technology Assessment of Mercury and Its
Compounds on National and Regional Bases (U.S. EPA contract 68-01-2931, URS
Res. Co.). EPA Rep. 560/3-75-007, Oct. 1975, 401 pp. [Cited in US Department of
the Interior: Stephen M. Jasinski. The Materials Flow of Mercury in the United
States. Bureau of Mines, Information Circular 9412. 1994. page 6,
http://greenwood.cr.usgs.gov/pub/min-info-pubs/usbm-ic/ic-9412.]
12. Wilhelm, S. Mark and Nicolas Bloom. Mercury in Petroleum. Fuel Processing
Technology 63, Elsevier Science, 2000. page 10.
13. Gilkeson, John. Mercury in Petroleum Refining; Crude Oil and Refined Products
Final Report to Legislative Commission on Minnesota Resources. Minnesota Office
of Environmental Assistance. August 20, 1999. page 5.
14. National Electrical Manufacturers Association. Environmental Impact Analysis:
Spent Mercury-Containing Lamps. January 2000. http ://www. nema. org
/government/environment/enviimpact.doc.
15. Letter from Ric Erdheim, National Electrical Manufacturers Association, to Scott
Cassel, Director of Waste Policy and Planning of Massachusetts Executive Office of
Environmental Affairs. September 24, 1996.
16. U.S. EPA and Environment Canada. Background Information on Mercury Sources
and Regulations. Table 5 and Appendix C. http://www.epa.gov/grtlakes/bnsdocs/
mercsrce/index.html
17. Ric Erdheim, National Electrical Manufacturers Association, Testimony presented to the
New Hampshire House Committee on Environment and Agriculture regarding House
Bill 675. March 14, 2001.
18. Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume I,
Critical Review, Batelle, Pacific Northwest Laboratory for EPRI, EA5176, August
1987. (Cited in U.S. EPA. EPCRA Section 313 Industry Guidance - Electricity
Generating Facilities., EPA-745-B-00-004. Office of Pollution Prevention and
Toxics. Washington, DC. February 2000. page 4-43).
19. National Council of the Paper Industry for Air and Stream Improvement, Inc. (NCASI).
Compilation of Air Toxic and Total Hydrocarbon Emissions Data for Sources at
Chemical Wood Pulp Mills. NCASI bulletin No. 701. October 1995. (Cited in U.S.
EPA. Locating & Estimating Air Emissions from Sources of Mercury and Mercury
Compounds. EPA-454/R-97-012. Office of Air Quality Planning and Standards
(OAQPS). December 1997. page 6-25)
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20. U.S. EPA. A Review of Standards of Performance for New Stationary Sources -
Ferroalloy Production Facilities. EPA-450/3-80-041. Office of Air Quality Planning
and Standards. Research Triangle Park, NC. December 1980. (Available in EPA's
Factor Information Retrieval System (FIRE) 6.22 database).
21. Compliance Testing of a Baghouse to Quantify Foundry Emissions. December
1990. (Confidential Report No. ERC-59). (Available in EPA's Factor Information
Retrieval System (FIRE) 6.22 database).
22. Source Emission Testing of an Aluminum Shredding and Delacquering System.
March 26, 1992 and April 10, 1992. (Confidential Report No. ERC-8). (Available in
EPA's Factor Information Retrieval System (FIRE) 6.22 database).
23. U.S. EPA. Assessment of the Controllability of Condensible Emissions. EPA-
600/8-90-075. Air and Energy Engineering Research Laboratory. Research Triangle
Park, NC. October 1990. (Available in EPA's Factor Information Retrieval System
(FIRE) 6.22 database).
24. Eureka Laboratories. Compilation of Air Toxics Pollutant Emission Factors,
Volume IIB: Technical Support Information, Asphalt Concrete Plants, 1991
Edition. Prepared for Central Valley Rock, Sand & Gravel Association. January
1991. (Available in EPA's Factor Information Retrieval System (FIRE) 6.22 database).
25. Source Emissions Testing of a Dryer. November 13, 1991. (Confidential Report No.
ERC-11). (Available in EPA's Factor Information Retrieval System (FIRE) 6.22
database).
26. Source Emissions Testing of a Dryer. December 1991. (Confidential Report No.
ERC-12). (Available in EPA's Factor Information Retrieval System (FIRE) 6.22
database).
27. Engineering Science, Inc. A Comprehensive Emission Inventory Report as Required
Under the Air Toxics Hot Spots Information and Assessment Act of 1987.
Prepared for Calmat Co. Fresno No. U Facility. Industrial Asphalt. September 14,
1990. (Available in EPA's Factor Information Retrieval System (FIRE) 6.22 database).
28. Composite. Radian FIRE database 1993 release. (Available in EPA's Factor
Information Retrieval System (FIRE) 6.22 database).
29. The Almega Corporation. AB-2588 Pooled Source Emission Test Program,
Volumes I andII. Report 16551-4. Project 16551. Prepared for Western States
Petroleum Association. Glendale, CA. July 1990. (Available in EPA's Factor
Information Retrieval System (FIRE) 6.22 database).
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30. National Electical Manufacturers Association. The Diclining Presence of Mercury in
Batteries and Municipal Solid Waste, page 7.
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