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MERCURY SOURCES AND REGULATIONS
Background Information for the virtual
Elimination Pilot Project
Prepared for
U.S. EPA
Great Lakes National Program Office
Contract #68-C8-O066
Prepared by
ROSS & ASSOCIATES
ENVIRONMENTAL CONSULTING. LTD.
Under Contract to
Science Applications International Corporation
September 12,1994
1218 Third Av«nue Sole 1207	(206) 447-1B05
Sea«e Weshngton 98101	Printed on Recycled Piper	Fn (206) U7-0956

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ACKNOWLEDGEMENTS
Ross & Associates would like to thank the many reviewers and other participants who contributed
information and insights to this background material. Discussions with EPA staff, including
GLNPO, Region 5, and headquarters, as well as representatives from each of the Great Lakes
states helped shape many of the ideas included here.
Special thanks are due to the following individuals who reviewed earlier drafts of this material.
Raymond Balfour, Vice President, Rayovac Corporation
(for the Dry Battery Section of the National Electrical Manufacturers Association)
Angela Bandemehr, U.S. EPA Region 5 (Air)
Pat Carey, Minnesota Pollution Control Agency
Lloyd Eagan, Air Management Supervisor, Wisconsin Department of Natural Resources
Tim Eder, National Wildlife Federation
Gary Gulezian, Chief Air Toxics and Radiation Branch, U.S. EPA Region 5
Steve Jasinski, Mercury Commodity Specialist, U.S. Dept. of Interior Bureau of Mines
Martha Keating, U.S. EPA Office of Air Quality Planning and Standards
Carrie Lohse-Hanson, Minnesota Pollution Control Agency
Barbara McLeod, U.S. EPA Region 5 (Water)
Edward Swain, Minnesota Pollution Control Agency
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TABLE OF CONTENTS
I.	Introduction		1
II.	What are the sources of mercury?		4
A.	Intentional Use			8
1)	Producing or Supplying Mercury 		8
2)	Using Mercury as an Input 		11
3)	Waste Disposal		17
B.	Incidental Release		20
1)	Manufacturing Processes		20
2)	Energy Production 			20
C.	Data Sources for the Great Lakes States 		21
III.	How is Mercury Regulated? 		26
A)	Types of Mercury Regulations		27
B)	Mercury Use Regulations 		30
1)	Mercury in Commerce		30
2)	Mercury in Products		33
3)	Reporting Requirements		37
C)	Mercury Release Regulations		37
1)	Mercury Air Emissions		38
2)	Mercury Discharges to Water 			41
3)	Mercury Waste Disposal 		43
4)	Mercury Reporting Requirements 		46
Appendix A: Mercury Use Tree
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
Appendix C: Products that Contain Mercury
Appendix D: Summary of Mercury-Specific Statutes in the Great Lakes States
Appendix E: Battery Statutes
Appendix F: Data on Mercury Releases
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LIST OF TABLES
Table
1:
Overview
Table
2a:
Categories of Mercury Sources
Table
2b:
Sources of Mercury
Table
3:
United States Mercury Statistics (Includes graph)
Table
4:
U.S. Industrial Consumption of Refined Mercury Metal, By Use (Includes graph)
Table
5:
Products That May Contain Mercury
Table
6:
Discards of Mercury in Products in the Municipal Solid Waste Stream
Table
7a:
TRI - Mercury Releases and Transfers, the Eight Great Lakes States
Table
7b:
TRI - Mercury Releases and Transfers, the Eight Great Lakes States, 1992
Table
8:
Mercury: Regulatory Overview
Table
9:
Environmental Standards for Mercury
Table
10:
Common Mercury Product Regulations in the Great Lakes States
Table
11:
Summary of Mercury Product Regulations
Table
12:
Potential Changes in Mercury Regulations
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Virtual Elimination Pilot Project
Mercury Sources and Regulations
Background Information on
Mercury Sources and Regulations
I. Introduction
Mercury enters our lives more frequently than we may imagine. It may be in the fluorescent
lights in our office, in old cans of latex paint, in our batteries, in our dental fillings, and
numerous other sources. Within the United States alone, manufacturers use 500 - 600 metric tons
of mercury annually as part of their manufacturing processes or to create products that rely on
mercury's diverse properties.
A naturally-occurring, inorganic element, mercury's value in numerous industrial processes was
discovered centuries ago, In very small quantities, it conducts electricity, measures temperature
and pressure, acts as a biocide, and functions a catalyst. Over time, however, we have discovered
that mercury is a potent neurotoxin, capable of impairing neurological development in fetuses and
young children and damaging the central nervous system of adults. Mercury does not degrade
and is not destroyed by combustion. When released to the environment, even in small quantities,
it bioaccumulates, reaching dangerous levels in fish at the top of the aquatic food chain. Fish
consumption advisories throughout Great Lakes waterbodies are testament to the health risks
caused by mercury present in the Great Lakes ecosystem. Thirty-seven states have issued fish
consumption advisories due to mercury contamination.
Scientists believe that atmospheric deposition contributes a large portion of the mercury found
in the lakes and soil. Mercury emitted into the air by combustion, incineration, or manufacturing
processes may later be deposited in lakes. Mercury emissions also come from natural sources
including marine and aquatic environments, as well as volcanic and geothermal activity.
However, recent studies suggest that anthropogenic sources contribute the majority of mercury
releases.
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At both federal and state levels, numerous efforts are underway to curtail mercury releases into
the environment. To understand what options are available to reduce mercury use and release
we must first answer four basic questions:
(1)	What are the sources of the mercury (supplying mercury and releasing mercury)
into the environment?
(2)	What products contain mercury?
(3)	What regulations and non-regulatory measures currently influence mercury use
and release?
The objective of this background information is to provide a context for understanding the full
range of mercury sources and existing regulations that affect mercury use and release. From
this information, we will be able to understand the extent to which existing regulations
encourage a reduction in mercury use and release, and identify other opportunities—including
regulatory and non-regulatory programs--that might hasten the pace of reductions.
Table 1 provides an overview of the material covered in this background section.
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Mtmnf Snurcw and Regulations
TABLE 1: Overview
What are the
Sources or
Mercury?
Describes five categories of anthropogenic mercury sources and the individual sources covered in this analysis.
Intentional Use
Incidental Release
Producing Mercury

Use as Input in

Waste Disposal

Manufacturing
(mercury supply)

Manufacturing


Processes





1


1
1
Chemical and Allied

Electric and

liMtramenlj and

Other
Pmducti

Electronic Unci

Rtlttel Products

Energy Production
How is Mercury Characterizes the different types of mercury regulations.
Regulated?	Describes how mercury use and release is regulated by the relevant statutes in each category:
Environmental
Management
Standards
Links regulations to specific mercury sources.
Identifies mercury products regelated at a federal and state level.
ffo.11 it AiitKlattt Environmental Coiuulllng, Ltd.
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Mercury Sources and Regulations
II. What are the sources of mercury?
Mercury is released into the environment from natural and anthropogenic sources. This report
focuses on anthropogenic sources of mercury. Because mercury use is widespread throughout
multiple industries as a process or product ingredient, its releases cannot be traced to one
industrial sector. As a naturally occurring metallic element, mercury is also present as a trace
contaminant in ores and fuels. It may be released into the environment when raw materials
containing mercury are heated, even though the mercury itself plays no role in these processes.
Thus, mercury releases occur as a result of decisions to intentionally use mercury in consumer
products or manufacturing processes, and as a result of incidental release^.
Through a separate analysis, EPA is estimating the relative air emissions of different mercury
sources. In the "Mercury Study," mandated by the Clean Air Act amendments of 1990
(§112(n)(l)(B); see discussion in Section III of this report), anthropogenic mercury sources are
divided into the following broad groups, based on their emission properties: (1) combustion
point sources; (2) manufacturing point sources; (3) miscellaneous point sources; and (4) area
sources. Note that the individual source categories in the mercury study are similar to the ones
used in this report.
Using emissions factors to estimate mercury releases, preliminary analysis indicates that, in the
United States, anthropogenic sources emit 263 tons of mercury annually to the atmosphere.
Of this total, combustion point sources, which include utility, commercial, industrial and other
boilers, as well as municipal waste combustors and other incinerators, account for 85% of
anthropogenic mercury emissions. Four specific combustion source categories account for the
majority of anthropogenic emissions: municipal and medical waste incineration (25% each);
utility boilers (21%); and commercial/industrial boilers (12%). In addition, manufacturing
sources, which include chlor-alkali production, smelting, secondary mercury production,
equipment manufacture, and other processes, account for 12% of total anthropogenic mercury
emissions.
For the Virtual Elimination project, we have divided mercury sources into two broad groups,
based on these two different roles of mercury: is mercury intentionally used or is it
incidentally released? Table 2A shows the categories of mercury sources used in this report.
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Virtual Elimination Pilot Project
Mercury Sources and Regulations
	TABLE 2A: Categories of Mer cury Sources
Mercury releases occur as a result of intentional use or incidental release. This table shows the categories of
anthropogenic mercury sources discussed in this report. For each category, the issues involving the origin and release of
mercury are different. Therefore, the options for obtaining additional mercury reductions differ. Table 2B lists the specific
mercury sources for each category shown in this table.
Intentional Use	Mercury is used as a product or process ingredient. Mercury release is a result of intentional mercury use.
Producing or
Supplying Mercury
Use in
Manufacturing
(products contain mercury or
processes rely on mercury)
Waste
Disposal
(mercury-containing products
or waste streams)
I ncidental Release	Mercury is released incidentally as a result of using raw materials that contain traces of mercury. Mercury
is not used intentionally in these sources.
Manufacturing
Processes
(raw materials
contain mercury)
Energy
Production
(fuel sources
contain mercury)
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Mercury Sources and Regulations
Intentional Use: When mercury is used intentionally as an input in production processes
or consumer products, three distinct but inter-related types of sources contribute to mercury
releases. Sources in this category include:
(1)	Produce or supply mercury;
(2)	Use mercury as an input to manufacture products containing mercury or as part of
a manufacturing process; and
(3)	Receive mercury-containing wastes for disposal.
All of these sources supply, use, or release intentionally used mercury into the environment.
Because the quantity of mercury used in the manufacturing sector directly influences a
significant amount of the mercury ultimately released into the environment, several leverage
points are potentially available to reduce mercury releases. The price and supply of mercury,
the feasibility of recycling, the availability of alternative inputs or processes, and the structure
of existing regulations all contribute to a company's decision to use mercury in their production
processes or products.
Incidental Release: Incidentally released mercury comes from two categories of sources:
(1)	Manufacturing processes where the raw materials contain trace amounts of
mercury; and
(2)	Energy Production where the fuel source (primarily coal) contains mercury.
These sources, particularly coal combustion, and copper, lead and zinc smelting, may contribute
a large portion of overall mercury air emissions. However, because their processes or products
do not rely on mercury, their mercury emissions are not influenced by the costs associated with
using mercury. They are affected only by regulatory costs associated with releasing mercury.
Therefore, the menu of opportunities for reducing mercury releases from these sources will
differ from sources that rely on mercury for some aspect of their business.
The source categories used throughout this report are, for the most part, consistent with sources
identified in recently released reports that track mercury use and emissions, specifically the
Bureau of Mines Mineral Industry Surveys, and the EPA Mercury Study Report to Congress
mandated under the Clean Air Act Amendments of 1990 (§112(n)(l)(B)) (in preparation). By
using similar source categories, we can combine information on mercury use and emissions
trends at a national level with an overview of existing regulations. Table 2B lists the specific
source categories of mercury that are covered in this analysis.
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Mercury Sources nnd Regulations
TABLE 2B: Sources of Mercury
Intentional Use
Producing
or Supplying
Mercury
Use in
Manufacturing*
(producls contain mercury or
processes use mercury)
Primary Mercury Production
(by-product or gold mining)
Secondary Hg production
(mercury recovery)
Mercury Compound
Production
Government Slocks
* National Defense Stockpile
(primary mercury)
• Dept. of Energy slocks
(secondary mercury)
Imports
Waste
Disposal
(mercury-containing
products or wastcstrcams)
Chemical and Allied Products
Chlorine/Caustic Soda
Lab Uses
Paint
Other Chemical and
Allied Products
Catalysis
Pesticides
Pharmaceuticals
Electrical and Electronic Uses
Electric Lighting
Wiring Devices & Switches
Battery Manufacturing
Instruments and Related Products
Measuring & Control Instruments
Dental Equipment & Supplies
Hospitals, Dentists
1 See Table 5 for a list of the main mercury-containing products
Municipal Waste Incinerators
Commercial/Industrial
Waste Incinerators
Sewage Sludge Driers
& Incinerators
Wastewater Treatment (POTWs)
Hazardous Waste Incinerators
Medical Waste Incinerators
Landfills
Ash disposal facilities
Auto salvage/scrapyards
Crematories
Incidental Release
Manufacturing
Processes
(raw materials
contain mercury)
Carbon Black Production
Coke Production
Petroleum Refining
Lime Manufacturing
Portland Cement Manufacturing
Phosphate-based fertilizer production
Copper Smelting & Refining
Non-ferrous Metals Smelting
(except copper and aluminum)
Energy
Production
(fuel source
conlains mercury)
Utility Boilers
Commercial & Industrial
Boilers
Residential Boilers
and wood stoves
Ron <6 A'tcclattt EmlfoitmiMat Coittultftig. Ltd.
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Mercury Sources and Regulations
For this analysis, we have focused only on the largest uses and releases of mercury. Part D
of this section discusses the reporting data available to track mercury sources. Data on
mercury releases available through different reporting programs illustrates the industrial sectors
where mercury release occurs most frequently , in the Great Lakes states (based on the reporting
requirements of each program). Because mercury has thousands of applications, these data
may cover a much broader list of sources than the categories covered in this report. Appendix
A includes a detailed "use tree" of mercury sources.
A. Intentional Use
This section provides a brief overview of the three source categories that contribute to mercury
releases as a result of intentional mercury use: 1) production; 2) use; and 3) disposal.
1) Producing or Supplying Mercury
The mercury available for use in the United States comes from five main sources: (1) Primary
mercury production; (2) Secondary mercury production (mercury recovery); (3) Mercury
compound production; (4) Government stocks; and (5) Imports. Table 3 (and the
accompanying figure) illustrates the relative contributions of these sources to the United States
mercury supply.
(1) Primary Mercury Production. Virgin mercury is mined from mercury ore or
produced as a by-product of gold mining. In the United States, mercury is produced
only as a by-product of gold mining. The last mercury ore mine, the McDermitt Mine
in Nevada, closed in 1990. No by-product mercury mines are located in the Great
Lakes States.
Byproduct Mercury-Producing Mines in the United States (19921*
Mine
Alligator Ridge
Carlin Mines Complex
Hog Ranch
Enfield Bell
Getchell
McClaughlin
Mercur
Paradise Peak
Pinson
Location
White Pine, NV
Eureka, NV
Washoe, NV
Elko, NV
Humboldt, NV
Napa, CA
Tooele, UT
Nye, NV
Humboldt, NV
Operator
USMX Inc
Newmont Gold Co.
Western Hog Ranch Co.
Independence Mining Co.. Inc.
FMC Gold Co.
Homestake Mining Co.
Barrick Mercur Gold Mines Inc.
FMC Gold Co
Pinson Mining Co
U.S. Department of the Interior Bureau of Mines,
Mineral Industry Surveys, July 1994.
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Mercury Sources and Regulations
(2) Secondary Mercury Production. Mercury is also recovered from discarded products
and wastes such as chlor-alkali wastes, dental amalgams, fluorescent light tubes, electronic
devices, and others. The mercury is vaporized in a retort and collected by condensation.
Condensed mercury is then distilled to remove impurities. Triple-distilling yields the highest
purity mercury. Secondary production almost doubled in 1993, expanding to 63% of U.S. total
mercury consumption from 30% in 1991. The table below shows the trends in U.S. mercury
consumption and secondary mercury production.
Secondary Mercurv Production in the U.S.*

1950
1960
1970
1980
1990
1991
1993
Industrial demand (consumption)
1697
1764
2120
2033
720
554
558
Secondary production (industrial)
69
184
253
234
108
165
350
Secondary production as a percent of
consumption
4%
10%
12%
12%
15%
30%
63%
October 1993, and Mineral Industry Surveys: Mercury in 1993, July 1994.
Three facilities, all located in Great Lakes states, produce the bulk of secondary
mercury in the United States. D.F. Goldsmith Chemical and Metal in (Evanston, IL)
specializes in distilling 99% or greater flowable mercury, and Bethlehem Apparatus
(Hellertown, PA) and Mercury Refining Company (Albany, NY) retort and distill a
wide variety of mercury wastes and scrap material. However, they do not accept
certain types of RCRA wastes. At the end of 1993, eleven plants in the U.S. recycled
mercury from fluorescent lights, using physical separation to recover mercury. Six of
these facilities opened in 1993.
(3) Mercury Compound Production. Mercury compounds are used in a wide
variety of pharmaceutical and other uses. Commonly used mercury compounds include
mercuric oxide (cathode material in batteries), mercuric chloride (pharmaceuticals),
phenylmercuric acetate (used in paints and pharmaceuticals), mercuric sulfide (used in
red pigment and other pharmaceuticals), and thimerosal (contact lens solution). Several
mercury compound manufacturers are located in Great Lakes states:
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Mercury Sources and Regulations
Mercurv Compound Producers in Great Lakes Slates*
Company
Location
Compound(s)
AAKASH Chemicals & Dye Stuffs,
Inc.
Addison, 1L
Hg acetate, HgBr2, HgI2, Hg(N03)2,
HgO (red & yellow), HgS04, Mercurous
Nitrate, Hg(ammoniated), Hg salts
Atomergic Chemetals Corp.
Farmingdale, NY
Hg cyanide, HgO (black), Mercurous
Iodide, Mercurous Sulfate, Thimerosal
GFS Chemicals, Inc.
Powell, OH
Hg acetate, HgI2,Hg(N03)2, HgS04
R.S.A. Corp.
Ardsley, NY
Hg(SCN)2 - thiocyanate
Chemical Buyers Directory, 81 si Annual Edition, 1994.
(4) Government Stocks. The United States government maintains a supply of
mercury as part of the National Defense Stockpile, established at the end of World War
I to maintain adequate supplies of materials deemed critical to national defense. The
Defense Logistics Agency (DLA), a unit of the Department of Defense, manages the
stockpile. DLA periodically evaluates the quantity Of mercury and other materials
needed in the stockpile, and may sell any "excess" material on the open market.
Mercury is stored and sold in flasks, which contain 34.5 kg of mercury. Regulations
governing the sale of excess mercury are described in Section III ("Regulations").
At the end of April 1994, DLA held 127,000 flasks (4,381 metric tons) of mercury in
the stockpile. With a current stockpile goal of zero for mercury, all of this material is
considered excess. DLA suspended stockpile mercury sales in January after selling its
entire 1994 mercury allocation (10,000 flasks). However, DLA received Congressional
approval to increase the total amount of mercury available for sale in fiscal year 1994
to 50,000 flasks (1,725 metric tons), leaving 40,000 flasks (1,380 metric tons) available
to sell by September 30, the end of the fiscal year. For comparison, DLA sold only
8,250 of the 10,000 (345 metric tons) flasks authorized for sale during fiscal year 1993.
In July 1994, however, DLA suspended future mercury sales until the environmental
implications of these sales are addressed.
In past years, DLA also sold mercury for the Department of Energy (DOE), at monthly
auctions. DOE holds' secondary mercury (scrap mercury) at its facility in Oak Ridge,
TN, leftover from mercury accumulated by the Atomic Energy Commission (DOE's
predecessor) for use in nuclear reactors. All of this mercury is also considered excess
to government needs. DLA suspended these mercury sales in July 1993, and plans to
continue the suspension through 1994 in order to concentrate on selling its own
material.
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Mercury Sources and Regulations
(5) Imports. The United States imported 92 metric tons of mercury in 1992, the most
recent year for which data are available. Of this total, 70% (64 metric tons) came from
Canada and 29% came from Germany. The remainder (one percent) came from Spain
and the United Kingdom. Mercury compounds are also imported. Section III
("Regulations") discusses mercury imports and relevant tariffs in more detail.
2) Using Mercury as an Input
Mercury is used throughout the worldwide industrial base as a result of its diverse properties.
In very small quantities, it conducts electricity, measures temperature and pressure, and forms
alloys with almost all other metals. With these and other unique properties, mercury plays an
important role as a process or product ingredient in several industrial sectors.
a) Industrial Categories
For this report we have used the industrial categories reflected in the Bureau of Mines Minerals
Commodities Summaries to illustrate the quantities of mercury used in different industrial
sectors. Table 4 shows the trends in domestic mercury use since 1988, and the relative
amounts of mercury used in the following industrial categories:
~	Chemical and Allied Products;
~	Electrical and Electronic Uses; and
~	Instruments and Related Products.
Mercury use in the United States has declined 63% since 1988, to 558 metric tons per year in
1993 from 1,503 metric tons in 1988. In many cases, manufacturers appear to be moving away
from mercury except those uses for which mercury is currently considered essential. However,
the rate of decline has slowed since 1990.
Public pressure has also driven manufacturers to seek alternatives to non-essential mercury in
their products. For instance, recent public outcry against mercury switches contained in
children's light-up sneakers caused the manufacturer to change to a non-mercury switch that
accomplishes the same purpose. The manufacturer now provides a toll-free number for
customers to request a postage-paid mailer and return the shoes for proper mercury disposal.
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Mercury Sources ami Regulations
TABLE 3: UNITED STATES MERCURY SUPPLY AND DEMAND
(Metric tons)
1988 1989 1990 1991 1992 1993
Mine production(l)-metric tons	J79 414 448	0	0	0
By-product production(2)	W	W 114 58	64	W
Secondary production:
Industrial
278
137
108
165
176
350
Govcmmcnt(3)
214
180
193
215
103
0
Industry stocks, year-end(4)
338
217
197
313
436
400
Shipments from the National Defense






Stockpiled)
52
170
52
103
267
543
Imports for consumption
329
131
15
56
92
40
Exports
NA
221
311
786
977
389
Industrial demand (consumption)
1503
1212
720
554
621
558«
(1)	Comprises only the mercury produced at the McDermitt Mine, as reported in Placer Dome Inc. annual and 10-K reports. The mine was closed in November 1990.
(2)	Mercury by-product from nine gold mining operations.
(3)	Secondary mercury shipped from U.S. Department of Energy stocks.
(4)	Slocks at consumers nnd dealers only. Mine stocks withheld to avoid disclosing company proprietary data.
(5)	Primary mercury. This quantity represents shipments during the 1993 calendar year. Congressional authorization for stockpile sales is based
on a fiscal year (October-September) which bridges 2 calendar years.
w = withheld to avoid disclosing proprietary information
~ Note: See Table 4 for a breakdown of mercury consumption by industrial category.
Source: United States Bureau of Mines, Mineral Industry Surveys, July 22, 1994.
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Chemical and Allied Products: Chemical and allied products are responsible for the
largest quantity of mercury used in the United States. This is due to the fact that a single
industrial process—chlorine and caustic soda manufacture-alone uses more mercury than any
of the other industrial sectors that use mercury. One chlor-alkali process, known as the
mercury-cell process, relies on a mercury cathode to produce hydrogen gas and caustic soda.
Caustic soda produced from this process may contain mercury, which in turn may contaminate
other products.
At a national level, the chlor-alkali industry is regulated more directly for mercury than any
other industry, with national air emissions limits, water discharge limits, and waste disposal
restrictions. Although most mercury-cell chlor-alkali plants in the United States have closed,
two still exist in the Great Lakes. Fourteen facilities remain in the United States. The chlor-
alkali facility in Wisconsin is the second largest source of mercury emissions in that state.
Until the early 1990s, paint manufacturing used large quantities of mercury. The mercury
compound phenylmercuric acetate was used as a biocide to control mildew in latex paints.
However, EPA curtailed this use, eliminating mercury in interior latex paints in 1990 and
exterior paints in 1991. Mercury emissions from volatized paint and demolition waste may
continue from paints manufactured before the ban.
Electric and Electronic Uses: In the electrical industry, mercury is used in electric
lighting devices such as fluorescent lamps, wiring devices and switches, and several different
kinds of batteries. In 1992, electrical manufacturing accounted for approximately 25% of the
mercury used in the United States. As recently as 1988, battery manufacturing alone consumed
almost 25% of the total mercury use in the United States. As manufacturers have found
alternatives to mercury in alkaline batteries, and states began limiting mercury content in
batteries, the volume of mercury used in batteries declined by over 95%. Mercury substitutes
are not as readily available in fluorescent and other lamps. Mercury use in lamps appears to
be rising especially as fluorescent lamps are promoted for energy conservation. Some
manufacturers are developing fluorescent lamps that rely on smaller quantities of mercury.
Instruments and Related Products: Mercury is also used in navigational devices,
instruments that measure temperature and pressure, and other related uses. It is also used
frequently in dental amalgam tooth fillings, although substitutes are available. Mercury use
in this area has declined.
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U.S. Consumption of Refined Mercury Metal, by Use
1600
19X7	1988	1989	1990	1991	1992	1993
Source: Bureau of Mines, Mineral Industry Surveys, July, 1994.
	category	
[HI] Other uses
CD Dental equipment and supplies
H Measuring and control instruments
inil Datteries
H Wiring devices and switches
H Electric lighting
H Other chemical
CH Paint
Si Laboratory uses
H Chlorine and ciiuslic soda manufacture
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Mercury Sources and Regulations
b) Specific Uses of Mercury
In each of the industrial categories listed above, mercury plays a unique role in a
manufacturing process or in a product. Table 5 lists the primary products that contain mercury
in each of the source categories discussed in this section. These products, which may not pose
mercury-related health risks during regular use, contribute mercury to the environment upon
disposal. In addition, Appendix A includes a detailed mercury use tree.
Several states regulate mercury-containing products directly by limiting or prohibiting mercury
content in certain products, and restricting disposal options. These regulations, which have had
a direct impact on the quantity of mercury consumed in industrial activities, are discussed in
more detail in Section III ("Regulations"). Many mercury products are used as components
in widely used products. Mercury may be released when products are discarded. For example,
Honeywell, Inc. a thermostat manufacturer, has developed a thermostat collection program in
Minnesota to recycle the mercury switches.
Mercury is also used in numerous industrial processes for amalgamation, wood processing, as
a solvent for reactive and precious metals, in nuclear reactors, and as a catalyst. Any facility
that uses mercury in its process is a potential source of mercury emissions. Available reporting
data may help locate and identify these sources. However, many sources that use or release
mercury may fall below existing reporting thresholds.
3) Waste Disposal
Mercury-containing waste streams and products sent offsite for disposal contribute mercury to
waste disposal facilities, which then release mercury into the environment. Industrial facilities,
hospitals, and dental offices that divert their wastewater to Publicly Owned Treatment Works
(POTWs) contribute to mercury in POTW effluent. Batteries, electric lamps, old paint, and
other mercury-containing products contribute to the mercury emissions at municipal, hazardous
waste, and medical waste incinerators, and may leach or vent mercury from landfills. As long
as mercury is used in industrial processes, facilities will generate wastes that contain mercury,
and consumer products will contribute mercury upon disposal. Table 6 shows the trends in
mercury products contained in municipal solid waste.
Table 2B lists the different types of waste disposal sources. Appendix B provides details on
the mercury-specific regulations for waste disposal sources. Note that cement kilns are not
listed as a waste disposal source. However, cement kilns, used frequently as a waste disposal
option, may burn hazardous wastes as a fuel source. Mercury may accumulate in the cement
kiln dust. Metals emissions from cement kilns, which are regulated under EPA's interim
standards for boilers and industrial furnaces (BIFs), are currently under review.
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Mercury Sources and Rcgnlatloni
TABLE 5: P r o d u c t s That May Contain Mercury
This table lists the primary products that may contain mercury. It is not an exhaustive list of all mercury products. Rather, it
illustrates the types of products where mercury may be used. In several cases, manufacturers are moving away from mercury use.
See Table 4 for the relative amounts of mercury used in each industrial category. See Appendix A for a detailed mercury use tree.
Chemical and Allied
Products
Electrical and
Electronic Uses
Instruments and
Related Products
Paint (existing stocks only)
latex paint
maritime paint
Other
•	agricultural products
•	catalysts
•	cosmetics
•	explosives
•	fireworks
•	livestock and poultry remedies
•	packaging
•	pharmaceuticals
•	pigments/dyes
•	poisons
•	preservatives
•	special paper coatings
•	turf products (existing stocks only)
Electric Lighting
fluorescent lights
high intensity lamps
incandescent lamp filaments
mercury vapor lamps
metal halidc lighting
UV disinfectant lamps
Wiring Devices and Switches
electric wall switches
shoes
thermostats
toys
white goods (appliances)
Batteries
•	alkaline batteries (no longer used)
•	carbon zinc batteries (no longer used)
•	mercuric oxide batteries
•	zinc air
Measure and
Control Instruments
barometers
medical and scientific instruments
thermometers
Dental Equipment and Supplies
dental amalgam
Other Uses
Electrical Components
•	high purity copper foil
•	mercury arc rectifiers
•	relays
•	tilt switches
Ro.1.1 
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Virtual Elimination Pilot Project
Mercury Sources and Regulations
TABLE 6 Discards* of Mercury in Products in the Municipal
Solid Waste Stream, 1970 to 2000 (in short tons**)
Products
1970
1975
1980
1985
1989
1995
2000
Household Batteries







Alkaline
4.1
38.4
158.2
352.3
419.4
41.6
0.0
Mercury-Zinc
301.9
287.8
266.8
235.2
196.6
131.5
98.5
Others
4.8
4.7
4.5
4.5
5.2
3.5
0.0
Subtotal Batteries
310.8
330.9
429.5
592.0
6212
176.6 •••
98.5
Electric Lighting







Flore scent Lamps
18.9
21.5
23.2
27.9
26.0
32.6
39.7
High Intensity Lamps
0.2
0.3
1.1
0.7
0.8
1.0
1.2
Subtotal Lighting
19.1
21.8
24.3
28.6
26.8
33.6
40.9
Paint Residues
30.2
37.3
26.7
31.4
18.2
2.3
0.5
Fever Thermometers
12.2
23.2
25.7
32.5
16.3
16.9
16.8
Thermostats
5.3
6.8
7.0
9.5
11.2
8.1
10.3
Pigment]
32.3
27.5
23.0
25.2
10.0
3.0
1.5
Dental Uses
9.3
9.7
7.1
6.2
4.0
2.9
2.3
Special Paper Coating
0.1
0.6
12 .
1.8
1.0
0.0
0.0
Mercury light Switches
0.4
0.4
0.4
0.4
0.4
1.9
1.9
Film Pack Batteries
2.1
2.3
2.6
2.8
0.0
0.0
0.0
TOTAL DISCARDS
421.8
460.5
547.5
730.4
709.1
245.3
172.7
¦ Discards before recovery.
" * Weights in this report are converted to short tons of2000 pounds, and refer to the weight of mercurv in the products,
not the weight of the entire product.
Source: EPA, Characterization of Products Containing Mercury in Municipal Solid Waste in the United Slates.
1970 to 2000, April 1992
""" NOTE: These numbers may not reflect recent state, federal, and battery manufacturer efforts to reduce mercury content
in batteries. Since this report was released, several states have restricted mercury content in alkaline batteries, and/or
banned the sate of mercuric oxide batteries Federal legislation to restrict mercury use in batteries is pending. The battery
industry has eliminated mercury as an intentional additive in alkaline batteries, except button cells and reusable alkaline
batteries.
Rou 4 Auociolri Enviiviim*nsal Consulting. Lid.
MER9407B XLS-discards

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Mercury Sources and Regulations
B. Incidental Release
1)	Manufacturing Processes
As a natural element, mercury is found in many raw materials that form the backbone of the
industrial base. Mercury is emitted from numerous manufacturing processes that use raw
materials containing mercury as a trace element. A list of these sources is included in Table
2B, and Appendices A and B describe these sources in greater detail.
Smelting processes, such as copper, lead, and zinc smelting, may contribute a large percentage
of overall mercury releases. For example, the Copper Range Smelter in White Pine, Michigan,
releases over 1000 pounds of mercury annually. In 1992, Zinc Corporation of America
contributed 90% of total mercury releases reported in Toxic Chemical Release Inventory (TRI)
for the Great Lakes states. This high level of mercury release, which was sent off site for
recycling, reflected periodic cleaning of the sulfuric acid plants, not ongoing releases. Mercury
is also present in zinc concentrates and is removed as an impurity during sulfuric acid
production.
Because these sources are not dependent on mercury as a component of their business, they
are not influenced by the costs associated with using mercury. In some cases, they may be
more amenable to control technology or to incentives that are not tied directly to mercury.
2)	Energy Production
Utility boilers, particularly coal-fired utilities, may contribute a large portion of the overall
atmospheric mercury emissions due to the presence of mercury in fuel sources. Although
currently unregulated for mercury emissions, they are the subject of intensive study under a
separate Utility Study mandated by the 1990 Clean Air Act amendments (§112(n)(l)(A)). The
report, scheduled for completion in 1995, is evaluating the extent to which coal combustion
contributes to overall mercury releases, as well as the need for specific mercury emissions
regulations for the utility industry. Given this in-depth report on the full range of utility
emissions, we will not focus on utility mercury emissions in this report, beyond identifying any
relevant existing regulations.
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Mercury Sources and Regulations
C. Data Sources for the Great Lakes States
Mercury releases are reported under several different federal and state programs, each with a
different set of regulatory requirements, and each covering a different subset of the regulated
community. Mercury information is available from three federal reporting programs: (1) the
Toxic Chemical Release Inventory (TRI), (2) RCRA Biennial Report System (BRS) data, and
(3) the Permit Compliance System (PCS) data for water releases. In addition to these federal
reporting programs, some Great Lakes states maintain other reporting systems that provide
additional information on mercury releases. Data is included for Wisconsin air point sources,
Michigan's Critical Materials Wastewater Report, and Indiana's Aerometric Information
Retrieval System (AIRS).
Information from each of these sources is summarized below, and included in detail in
Appendix F. With the exception of TRI data, all information is shown by SIC code to
illustrate the distribution of mercury releases across different industrial sectors. Appendix F1
provides a summary of the number of facilities that report mercury releases under each of these
programs, and shows how the number of facilities varies by reporting program as a result of
differing reporting requirements. For instance, 572 facilities in the Great Lakes states report
mercury-bearing wastestreams under RCRA biennial reporting requirements, while only 14
facilities report mercury releases under TRI.
Toxic Chemical Release Inventory (TRI). Appendix F2 shows TRI mercury releases for the
Great Lakes states. The Toxic Chemical Release Inventory contains chemical release and
transfer information from manufacturing facilities (SIC codes 20 - 39) that meet reporting
thresholds (manufacture or process 25,000 pounds of a listed chemical or otherwise use 10,000
pounds of a listed chemical. Appendix F2a includes 1992 data for the eight Great Lakes
states, including any source reduction activities implemented by each facility. Appendix F2b
contains similar data for the 1991 reporting year.
In 1992, 14 facilities in the Great Lakes Stales reported mercury releases, down from 20
facilities that reported in 1991. Tables 7A shows the trends in mercury releases from 1987 -
1992, and Table 7B shows the industrial sectors that reported mercury releases in 1992. The
majority of mercury releases reported in 1992 came from Zinc Corporation of America.
Because zinc concentrates contain mercury that is released during the sulfuric acid production
process, mercury builds up in the sulfuric acid plants. Periodically, these plants must be
cleaned, which generates a higher then normal volume of waste for that year.
Appendices F2c and F2d show nationwide mercury releases reported in TRI for 1992 and
1991, respectively. Great Lakes states reported 60.65% of the mercury releases and transfers
reported nationwide in TRI for 1992. This number was skewed by the large volume of waste
generated by Zinc Corporation of America, as described above. In 3991, Great Lakes states
reported 18.13% of total mercury releases and transfers nationwide.
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TABLE7A
KG/YR
200,000
150,000
100,000
50,000
¦fi.
Mercury Releases and Transfers,
The Eight Great Lakes States
J#
i*.
Total Number of Industries
Reporting per Year
-liiV;'
I
? '•,! » '
I >2
X 'iii
; f
;-r


Industries
n
25
20
15
10
YEAR
YEAR
1967
1968
1969
1990
1991
1992
Oflsfte	H
POTW ¦
38.826
82.263
34.337
66.473
29.484
163.366
S36
285
1.019
35
47
20
Land [~1
262
519
256
14
2.750
5
Underground CI]
0
0
0
0
0
0
Water B
889
374
16
10
14
	5	
1,435
AJrNonpt E]
Air Potnt ¦
	976	
" 3.650
1.682
3.482
3,216
2.422
4.013
4.217
3.168
1.078
1.215
TOTAL
45,139
89,136
43.329
72,916
35.795
166.046
Source: Tp*>t Chemtcnl Release Inventory
D-*' * ¦'mfvnloodad June 21, 1994

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TABLE 7B	Mercury Releases and Transfers,
The Eight Great Lakes States, 1992
SOURCES	DESTINATION
Petroleum & Coal
Instruments
Chemical Products
Rubber & Plastics
Electronics
Fabricated Metals
SIC Coda
Quantity
kg/yr
%ot
Total
Total Number
of Facilities
n
28 Chemical and Allied Products
2819 Industrial Inorganic Chemicals Not Elsewhere
Classified (mercury, redistilled)
2821 Plastics Material, Synthetic Resins
1,553
0
.83
0
2
1
29 Petroleum Refining and Related Industries
2911 Petroleum Refining
128
07
1
30 Rubber and Miscellaneous Plastics Products
3067 Custom Compounding of Purchased Plastic Resins
1261
.68
1
33 Primary Metal Industries
3339 Primary Smelting and Refining Nonferrous Me tab
3341 Secondary Smelting and Refining of Nonferrous
Metals ,
168,294
270
90.48
.14
1
1
34 Fabricated Metal Products
3471 Electroplating, Rating, Polishing, Anodizing, and
Coloring
20
.01
1
34 Electronic and Other Electrical Equipment
3641 Electric Lamp Bulbs and Tubes
3679 Electrical Components Not Elsewhere Classified
3692 Primary Batteries, Dry and Wet
3,514
5,356
0
1.89
2.88
0
1
1
38 Measuring, Analyzing, and Controlling Instrument*
3843 Dental Equipment and Supplies
5,650
3.04
1
TOTAL
106,048
100
14
Primary Metals
Destination
Quantity
kg/yr
%of
Total
Facilities
Reporting
Releases
(Out of 14)
Air Point
1,215
.65
a
Air Non point
1,435
.77
7
Oflsite
183,366
96.56
10
Water
Land
POTW
5
5
20

1
1
4
Underground
0
0
0
TOTAL
188,040
100
N/A

Source: Toxic Chemical Release Inventory
Data downloaded June 21, 1994

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Virtual Elimination Pilot Project
Mercury Sources and Regulations
RCRA Biennial Report data. Ap;.- : dix F3 includes 1991 data from the RCRA Biennial
Report System (BRS). BRS da;; tracks information on hazardous waste generated and
managed by large quantity generators and permitted Treatment, Storage, and Disposal (TSD)
facilities. RCRA wastes are identified by waste code, several of which indicate the presence
of mercury in a wastestream or discarded product (see RCRA discussion in section III).
Appendix F3a shows the number c.f facilities, by SIC code, that report mercury-bearing
wastestreams. The data reflects only recurrent waste generation, and does not include one-time
waste or remediation wastes. A total of 572 facilities reported mercury-bearing wastestreams.
Mercury-bearing wastestreams showed up most frequently in the following industrial sectors:
colleges and universities :! 5 facilities), pharmaceutical preparations (28 facilities), electric
services (22 facilities), plastics materials and resins (21 facilities), and industrial organic
chemicals (20 facilities). Because most of the mercury-bearing wastes are characteristic for
mercury (i.e., they exceed the regulatory concentration limit for mercury), and include other
substances, it is difficult to gauge the quantity of mercury in the wastestreams.
Biennial report data also indicates the source processes that generated a given waste stream.
Appendix F3b lists the sources processes in each SIC code that generated mercury-bearing
waste streams. A summary table at the end of the appendix shows the frequency with which
each process occurred. A total of 39 different sources processes contributed to mercury-
bearing wastestreams. Laboratory wastes was reported most frequently (168 facilities),
followed by discarded out of data products or chemicals (76 facilities).
PCS data. Appendix F4 contains data from EPA's Permit Compliance System (PCS) for water
discharges. PCS data approximates point source loads from municipal and industrial
dischargers. The information is based on monitoring data supplied by regulated facilities. EPA
uses PCS data as the basis for its enforcement program. In 1993, the top 10 mercury
dischargers in Region 5 were:
Detroit WWTP
Lake County - Mentor
City of Fostoria
Gary Wastewater Treatment Plant
Hammond Municipal STP
Milwaukee MSO - South Shore
Fort Wayne Municipal STP
Watertown(C) WPCP
Ashta Chemicals
Milwaukee MSD - Jones Island
108kg
54kg
27kg
17kg
16kg
13kg
12kg
11kg
10kg
8kg
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Mercury Sources and Regulations
Wisconsin Air Point Source Emissions Data. Appendix F5 contains air emissions data for
Wisconsin facilities (J992 data). As part of its Clean Air Act Title V Operating Permit
Program, Wisconsin collected emissions data from facilities that reported releases greater than
one pound of hazardous air pollutants, including mercury. Sixty one facilities reported mercury
emissions under this program. This total includes 13 utilities and nine paper mills. A utility
reported the largest emissions (1272 pounds), followed by a chlor-alkali facility (1071 pounds).
Michigan Critical Materials Registry. Appendix F6 includes data from Michigan's Critical
Materials Wastewater Report (1991 data). As part of its water quality program, Michigan
collects information on chemical use and release from facilities that use any substance,
including mercury, on the "Critical Materials Registry." It is the only program that requires
facilities to report information about chemical use. Under this program, "use" means the
presence of the chemical on site. A total of 270 facilities reported mercury use, including 19
hospitals, 18 motor vehicle parts facilities, 16 plastics products facilities, and 16 utilities. The
total mercury use was between 288,174 - 308,510 pounds. Of this total, 121 facilities reported
discharges ranging in total between 271 and 1740 pounds. 160 facilities reported residuals
ranging in total between 2720 and 10,420 pounds.
Indiana Aerometric Information Retrieval System (AIRS): Appendix F7 includes data from
Indiana's 1991 AIRS database. Mercury emissions quantities in this database are estimates
derived by the Indiana Department of Environmental Management, based on data reported for
criteria pollutant emissions. As such, the quantities do not represent measured data, nor data
supplied directly by individual facilities.
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Mercury Sources and Regulations
III. How is Mercury Regulated?
Mercury regulations span multiple federal and state statutes, as well as multiple agency
jurisdictions. For example, the Environmental Protection Agency (EPA) regulates mercury in
pesticides, and mercury releases into the environment through air, water, and land disposal
limits. The Food and Drug Administration (FDA) regulates mercury in cosmetics, food, and
dental products. The Occupational Safety and Health Administration (OSHA) regulates
mercury air exposures in the workplace.
Unlike the separate regulatory structure created for PCBs under the Toxic Substances Control
Act (TSCA), no statute, at a federal level, has strategically identified mercury as a sole source
of concern. Instead, mercury is one of several substances covered under the overarching
structure of numerous statutes. In some cases, mercury receives more attention than other
substances covered in the same statute. Mercury regulations do hot apply uniformly to all
source categories. Thus, the nature and completeness of mercury regulation varies by statute.
Furthermore, aspects of mercury regulation extend beyond the traditional realm of
environmental statutes. Federal and state agencies are exploring efforts to curtail the use of
mercury, not just its release, in order to focus on prevention opportunities.
Individually, no single regulation appears to motivate substantial change in mercury use and
release. Collectively, however, the existing set of regulations has caused a dramatic decline
in mercury use. Whether or not these regulations have caused a similar drop in mercury
releases is not readily known. However, mercury is beginning to command more widespread
public recognition, and public concern is becoming a powerful leveraging tool to change
manufacturing practices. It is important to recognize that the face of mercury regulations is
changing rapidly.
This section describes the regulations that affect mercury use and release. We have provided
tables that describe how existing mercury regulations apply to mercury-containing products and
sources that use and/or release mercury. From this information, we can identify the extent to
which individual mercury sources are covered—or not covered—by existing regulations, and the
opportunities that might exist to encourage additional reductions mercury use and release.
Table 8 illustrates the different categories of mercury regulations used in this report, and the
applicable statutes or regulations for each category. Table 9 shows the federal environmental
management standards for mercury. Tables 10 and 11 summarize mercury product regulations.
Table 12 summarizes the potential changes in mercury regulation. At the end of the report,
Appendix B provides a detailed description of mercury sources and specific release
regulations; Appendix C describes the regulations affecting mercury products; and Appendix
D describes the main provisions of Great Lakes states' mercury-specific statutes.
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Mercury Sources and Regulations
A) Types of Mercury Regulations
To understand how existing mercury regulations influence the full spectrum of economic
activities that involve mercury, it is helpful to first distinguish between regulations that have
a direct effect on sources from those that have an indirect effect on sources.
Use- or release-related regulations have a direct effect on sources that use mercury or release
mercury into the environment. These regulations specify, for individual mercury sources, the
costs and/or conditions associated with using and releasing mercury during production or
disposal. This project is concerned primarily with the structure of use- and release-related
regulations and the extent to which existing regulations encourage pollution prevention.
Environmental management standards, on the other hand, have an indirect effect on individual
sources. Environmental standards are numeric criteria that specify a maximum acceptable
mercury concentration for different media, based on scientific or risk-based criteria. For
instance, mercury standards exist for water, sludge, fish tissue, drinking water, and several
other media. These standards provide a yardstick against which to measure the effectiveness
of mercury release regulations.
In contrast to use- and release-related regulations which apply directly to individual sources,
environmental standards remain independent of specific sources. However, environmental
standards exert an important effect on sources that release mercury to any media. For instance,
sewage treatment plants must ensure that the mercury content of their sludge remains below
the mercury concentration specified for land application. Even absent a specific mercury
effluent limit, the POTW must still work with its dischargers to minimize mercury content in
their discharges to the treatment plant.
Ross & Associates Environmental Consulting. Ud. 9/12/94
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Mercury Source* and Regulation!
Mercur
a
e
•fs
I
4»
06
w
o
©
V
CI
u
Direct Effect


Procuring/Using Mercury
Commerce
1)	Obtaining mercury
•	Excise tax
¦ Import tax
- Government
stockpile sales
2)	Transporting
mercury
•	Transportation
Products
¦	F1FRA
• FDA regulations
¦	State laws
Reporting
Requirements
•SARA §312 Threshold
Planning Quantities
¦ MI Critical Materials
Registry
KEY: ¦
FIFRA=Federal Insecticide, Fungicide, and
Rodenticide Act
FDA=Food and Drug Administration
OSHA=Occupational Safety and Health Act
RCRA=Resoarce Conservation and Recovery Act
SARA=Superfund Amendments and
Reauthorization Act of 1986
(Title III)= Emergency Planning and Community
Right to Know Act
Ross & Associates Environmental Consulting, Ltd.
TABLE 8:
: Regulatory Overview
Air
¦	Clean Air Act
¦	OSHA workplace standards
¦	State laws
Water
¦	Clean Water Act
¦	MI Critical Materials Registry
Waste
- RCRA (listed and
characteristic waste codes)
¦ State-laws
Reporting Requirements
¦	SARA §313 Toxics Release
Inventory
¦	SARA §312 Reportable
Quantities (spills)
Fish
Groundwater
Bottled Water
Water (level of detect)
Hazardous Waste
Water
Drinking Water
OSHA standards
Sludge
Compost
Tahie Explanation
Mercury regulations include (1) use-and release-related
regulations that specify the requirement;; associated with
using or releasing mercury, and (2) environmental
standards, which specify a maximum acceptable mercury
concentration in different media, and thus may indirectly
influence mercury release levels. .
Specific statutes regulate mercury in each of these differei
categories.
The charts above illustrate the different types of use and
release regulations, and the different media that have
mercury limits.
MERC9407XLS--R

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Virtual Elimination Pilot Project
Mfrcury Sources and Regulation!
Table 9: Environ mental Standards for Mercury
Media
Mercury Standard
Explanation
Ambient Water
•	0.144 u/1 Tor ingestion of both water and aqunlic organisms;
•	0.146 u/1 for ingestion of only aquatic organism.
•	2.4 u/1 for freshwater acute exposure;
•	0.012 u/1 for freshwater chronic exposure;
¦ 2.1 u/1 for marine acute exposure;
•	0.025 u/1 for marine chronic exposure.
(50 FR 30791)
•	Established under Clean Water Act 5304(a)
•	Ambient water criteria varies by state (may
change with GL1)
Drinking Water
¦ Maximum contaminant level = .002 mg/1 (40 CFR 141.62)
• Maximum contaminant level for mercury
established under the Safe Drinking Water Act.
Air
• No ambient standard.

Sludge
Limits;
•	17 mg/kg (dry wt) and 17 kg/hectare cumulative loading for sludge
applied on agricultural, forest and publicly accessible lands.
•	17 mg/kg (dry wt) and .85 kg/hcctare annual loading rate for sludge sold
or distributed for application to a lawn or home garden.
•	57 mg/kg (dry wt) for sludge sold or distributed for other types of land
disposal
•	100 g/kg (dry wt) for sludge disposed in lined or unlincd facilities
(40 CFR 503).

Compost
• No federal standards.
• Minnesota sets mercury concentration limits in
compost.
Fish
• 1 ug/g (I mg/kg or 1 ppm)
• FDA action level for methyl mercury, ug/g (1
mg/kg or 1 ppm)
Groundwater
• 2 ug/I

Bottled Water
• .002 mg/1 (21 CFR 103.35)

Water-level or
detect
• .2 ug/I (200 mg/1) = recommended method
• EPA-approved method to detect Hg in water.
Lower detection methods are available, but not yet
approved by EPA.
Hazardous
Waste
• TCLP = .2 mg/1 or .2 ppm (40 CFR 261.24, 264)
• Land disposal (Subtitle D, nonhazardous landfills)
prohibited unless Icachatc contains less than .2
mg/1.
Rots& Associates Environmental CortwMng, Ltd.
ENVSTAND.XLS 09/11/94

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Virtual Elimination Pilot Project
Mercury Sources and Regulations
B) Mercury Use Regulations
Regulations associated with mercury use in commerce impose costs, conditions, and/or
restrictions associated with obtaining, selling, using, or transporting mercury. We have used
the following categories to describe mercury use regulations: (11 commerce-related regulations
such as taxes and transportation requirements; (2) product-related restrictions; and (3) reporting
requirements.
Mercury use regulations affect only those facilities that use mercury as an input. They do not
affect those sources that release mercury incidentally as a by-product. For each statute, we
describe the mercury-specific information, the type of regulatory mechanism used, and any
potential changes to the current regulatory status.
1) Mercury in Commerce
Provisions of several statutes regulate different aspects of mercury in commerce. Excise taxes
and import taxes directly affect the cost of using mercury as an input in manufacturing
processes; regulations governing mercury sales from the National Defense Stockpile influence
the amount of mercury available for purchase; and transportation requirements impose
restrictions on mercury transport.
a) Obtaining Mercury
Excise Tax: Internal Revenue Code of 1986 (26 USCA §4661)
Mercury Information: The Internal Revenue Code imposes taxes on 40 chemicals,
including mercury, that are sold by the manufacturer, producer, or importer . The tax
rate for mercury is $4.45/ton, the second highest tax rate listed (10 substances have the
highest tax rate of $4.87/ton).
Regulatory Mechanism: Input/sales tax
Potential changes: None identified
IMPORT Tax: Harmonized Tariff Schedule of the United States
Mercury Information: Mercury and several mercury compounds are subject to import
taxes under the Harmonized Tariff Schedule of the United States, which identifies
import taxes on all goods imported into the United States from most-favored-nation
(MFN) countries, as well as from special treaty nations and non-most-favored-nation
(non-MFN) countries.
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For 1994, the tax rate for mercury imports from MFN countries is 16.5 £/kg, compared
to a 55.1 0/kg tax on imports from non-MFN countries (item 2805.40). Due to special
treaty agreements, no duty is imposed on mercury imports from Canada, Israel, Bolivia,
Colombia, Ecuador, and Caribbean Basin countries.
Regulatory Mechanism: tax
Potential Changes: Under GATT, mercuric oxide, a mercury compound used
frequently in medical and military batteries, will be exempt from all U.S. import duties,
effective July 1, 1995. Until the end of 1992, facilities that imported mercuric oxide
enjoyed duty-free imports, as a result of a special line-item tariff exemption heading
(9902.28.25). This duty-waiver lapsed at the end of December 1992. In January 1993,
Iowa representatives introduced bills into both houses of Congress designed to extend
the waiver for several more years (S.397 (Grassley), HB2522 (Grandy)). Neither bill
emerged from committee, and, thus, the import duty on mercuric oxide has remained
in effect since January 1993. The GATT duty-waiver will replace the need to amend
the Harmonized Tariff Schedule with specific legislation.
Mercury recycling equipment is also subject to import taxes. A bill introduced by
Minnesota Senator Durenberger (S.1308) would suspend the duty on equipment used
to recycle mercury and other parts of fluorescent light bulbs (adding sections
9902.87.17 and .18 to amend sections 8419.40.00 and 8479.82.00). A Swedish
company manufactures the only equipment capable of separating each part of a
fluorescent bulb and distilling mercury pure enough for industrial reuse. A duty-waiver
would lower the cost of recycling mercury from fluorescent lamps.
Government mercury STOCKPILE SALES: Strategic and Critical Materials Stockpile Act
(50 USCA §98)
Mercury Information: The Strategic and Critical Materials Stockpile Act regulates
mercury that the Defense Logistics Agency (DLA) sells from the National Defense
Stockpile. The amount of mercury sold from the stockpile has the potential to affect
the mercury market, although DLA considers its impact on the market when requesting
Congressional authorization for sales. DLA accepts daily bids for mercury. Over the
last year, the price of DLA mercury has ranged from $57 - 82 per flask.
DLA must submit an Annual Materials Plan to Congress that includes its requests for
selling materials deemed excess to stockpile needs for each fiscal year, including
projections for the following four years. For fiscal year 1994, DLA initially received
authorization to sell 10,000 flasks of mercury, but reached that limit by early 1994. In
April, DLA received Congressional authorization to increase fiscal year 1994 mercury
sales to 50,000 flasks, a five-fold increase that is more than three times the estimated
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total US consumption of mercury for 1993. By comparison, DLA had authority to sell
10,000 flasks of mercury (345 metric tons) in fiscal year 1993, but by year's end, sold
only 8,250 flasks (284.6 metric tons).
Until fiscal year 1994, funds received from stockpile sales were used only for stockpile-
related activities. However, the Defense Appropriation Act for fiscal year 1994 (PL
103-160, §305) changed the allowable uses of stockpile revenues, specifying that up to
$500 million be transferred to Department of Defense operations and maintenance
accounts. This change, combined with favorable market conditions and increasing
interest in stockpile materials, motivated DLA to seek approval to sell additional
quantities of several stockpile materials, including mercury.
Potential changes: In July, 1994, DLA suspended future mercury sales until a number
of potential environmental implications can be addressed. EPA will be represented on
the market impact committee that reviews stockpile sales. DLA has submitted its 1995
Annual Materials Plan to Congress, requesting authorization to sell 20,000. flasks of
mercury for fiscal year 1995. The House Armed Services subcommittee, chaired by
Rep. Earl Hutto (D-FL), handles strategic material issues. DLA is also considering
offering long-term contracts for mercury purchases.
b)	Transporting Mercury
Transportation: The Hazardous Materials Transportation Act
Mercury Information: The Department of Transportation regulates hazardous
materials transport under the Hazardous Materials Transportation Act (HMTA).
Mercury and mercury compounds are hazardous substances subject to packaging,
shipping and transportation rules for hazardous materials. RCRA regulations for
hazardous waste transporters incorporate HMTA rules.
Regulatory mechanism: operating requirements, labeling
Potential changes: None identified
c)	Using Mercury
Mercury Information: Currently, only Minnesota has a use-restriction law providing
that mercury sold in the state will be used only for medical, dental, instructional,
research, or manufacturing purposes. Sellers must provide buyers with a material safety
data sheet and have the buyer sign a statement of proper use and disposal.
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2) Mercury in Products
Mercury-containing products are regulated in several different ways. At a federal level,
mercury product regulation has generally centered around health-based reasons to eliminate
mercury from products, using the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
and the Federal Food, Drug, and Cosmetic Act (FFDCA) regulations.
In recent years, many states have taken a different approach. Restrictions on mercury-
containing products, once used sparingly by the federal government, are increasing rapidly at
the state level. States are beginning to move beyond strictly health-based concerns associated
with particular products, and are looking instead to the waste disposal problems associated with
mercury containing products. Many Great Lakes states, most notably Minnesota, are beginning
to ban the sale of certain products that contain mercury (e.g., toys and shoes), limit the content
of mercury in other products (e.g., batteries and packaging), and impose recycling requirements
and disposal restrictions on mercury-containing products.
At present, mercury product laws represent a patchwork of regulations that vary by state. Table
10 compares characteristics of the most common mercury product regulations in each of the
Great Lakes states. Table II summarizes the regulations that affect mercury-containing
products at a national level and in each of the Great Lakes states. Appendices C and D
describe each of these regulations in more detail. Appendix E shows the different types of
mercury battery legislation in place nationwide.
At a federal level, two statutes have been used to limit mercury content or curtail mercury use
in specific products.
Statute: Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
Mercury Information: FIFRA covers the sale and use of pesticides, including
registration of chemicals that meet health and safety tests. Until recently, several
mercury compounds were registered as pesticides, bactericides, and fungicides. By
1991, however, all registrations for mercury compounds in paints had been canceled by
EPA or voluntarily withdrawn by the manufacturer. Registrations for calo-chlor and
calo-gran, the last mercury-based pesticides registered for use in the United States (to
control pink and grey snow mold) were voluntarily canceled by the manufacturer in
November 1993. Existing stocks may be sold until depleted.
Regulatory Mechanism: ban, cancellation
Potential changes: None identified
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Statute: Federal Food, Drug, and Cosmetic Act (FFDCA)
Mercury Information: The Food and Drug Administration is responsible for mercury
in food, drugs, and cosmetics. Mercury use as a preservative or antimicrobial is limited
to eye-area cosmetics or ointments in concentrations below 60ppm. Yellow mercuric
oxide is not recognized as a safe and effective ophthalmic anti-infective ingredient.
The FDA also regulates dental amalgam under FFDCA. Dental mercury is classified
as a Class I medical device, with extensive safety regulations on its use. Dental
amalgam alloy is classified as a Class II device, subject to additional special controls.
Regulatory Mechanism: content restriction, use conditions, labeling
Potential Changes: None identified. However, California may require warnings on
dental amalgam above and beyond FFDCA rules, under its Safe Drinking Water and
Toxic Enforcement Act (Proposition 65), which requires businesses to warn employees
and the public if business activities result in emissions of listed chemicals.
Federal regulations may soon take a different approach to mercury product regulation. Two
bills introduced recently into Congress would impose restrictions on the mercury content in
packaging and batteries ("Mercury-Containing and Rechargeable Battery Management Act,"
SI949 (passed the Senate in May 1994); and HB4528 (same language). Similar language ins
included in the "Lead Exposure Reduction Act," which will be considered by Congressman
John Dingell's Energy and Commerce Committee). A bill to limit mercury content in
packaging materials was introduced in 1993. If passed, these bills would establish national
standards for allowable mercury content in batteries and packaging. Currently, over a dozen
states independently limit mercury content in batteries and packaging.
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Table 10: Common Mercury Product Regulations in the Great Lakes States

ILLINOIS
INDIANA
MICHIGAN
MINNESOTA
NEW YORK
OHIO
PENN.
WISCONSIN
Batteries"
TF

SC,R,DR,D
CR,SB,SC,D,R,
L
CR,SBA,SC,P


CR.SB^.DASC*
Packaging**
CR,SB


CR.SB
CR,SB,L

P
CR.SB
Toys, Clothes,
Footwear


P
SB, SC



SB
Electric Lamps***



D, SC, L
CR*



Thermostats



D, R, SC*, L




White Goods
D,SC,R


D, R, L, SC




Thermometers



L,R




Dental Supplies



D,R,L




FEDERAL REGULATIONS:
* Batteries: Bills introduced recently to the U.S. House and Senate are
designed to phase out mercury in batteries by imposing limitations on the
sale of (1) alkaline- manganese and zinc caTbon batteries containing mercury;
and (2) mercury button cell and other mcrairic-oxide batteries. (S. 1949,
Lautenberg (D-NJ), "Mercuiy-Conlaining and
Rechargeable Battery Management Act", passed the Senate on 5/25/94; HB
4528, Richardson (D-NM) contains same language.) Mercury battery provisions
of HB4528 were added to HB4882 (Lead Exposure Reduction Act of 1994;
Swift, 8/11/94) and will be considered by Congressman Dingcll's (Ml) Energy
and Commerce Committee after Labor Day.
** Packaging: A bill introduced into the U.S. Senate would prohibit
intentionally introduced mercury in packaging. (S.966, Lautenberg (D-NJ)
introduced May 13, 1993. "Reduction of Metals in Packaging Act")
**~ Electric lamps: EPA is considering two options to modify RCRA disposal
restrictions for mercury-containing lamps: (1) inclusion in universal waste
rule; and (2) conditional exemption.
Key
CR = content restriction - *design restriction
D = disposal restrictions
DR = deposit refund
L = labeling
P = pending legislation (see table 9 for details)
R ® Hg recycled before product disposal
SB = sale banned-*dislribution restricted
A= sales banned unless content restriction met
SC = special collection program -^public education
TF = task force
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1 1 • O U 111 in a I j \j a A • A C A w m * J
Key:. OH-Ohio
IL-nitnots _ .
PA - Pennsylvania
IN - Indiana ....
w] - Wisconsin
MI - Michigan - . r . ,
. fed - federal regs
MN - Minnesota .
NY -New York '-P«*»S
Content
Restriction
Sale Banned
Use Cancelled
or Restricted
Disposal
Restrictions
tig Recycled
Before Disposal
Labeling
Special
Collection Pgm.
Deposit Refund
m"
1 i
i 1
£ °"
£ sc
Chemical and Allied Products
Paint








Latex paint
fed
fed






Maritime paint
fed
fed






Other








Agricultural products

fed






Cosmetics
fed







Explosives


MN.WI





Fireworks

MI






Livestock and poultry remedies




MI



Packaging
IL, MN, NY,
PA*,WI
IL, MN, PA*,NY,
WI


NY



Pharmaceuticals
fed



IL, IN,
NY, OH,



Pigment, dyes
MN
fed






Poisons
PA
OH






Special paper coatings








Turf products

fed, MN






Electrical and Electronic Uses
Electric Lighting








Fluorescent lights


MN
MN
MN
MN

MN, fed
High intensity lamps


MN

MN
MN

MN, fed
Incandescent lamp filaments








Mercury vapor lamp
NY
MN
MN




MN, fed
Metal halide lighting








Wiring Devices and Switches








Electric wall switches


MN
MN
MN
MN


Electrical components
PA

MN
MN
MN
MN


Thermostats


MN
MN
MN
MN


Tilt switches, relays, rectifiers

MN
MN
MN
MN
MN


Toys

MN, WI, MI*






White goods


MN, IL
MN, IL
MN
IL, MN


Batteries








Alkaline batteries
MN, NY, WI
MN,NY,WI,fed*






Caibon zinc
NY, W1
NY, WI, fed*






Mercuric oxide batteries

MN, WI, fed*
MI,
MN.WI
MI,
MN.WI
MN, fed*
MN,W1
MI
MN
Zinc air
MN







Instruments and Relatec
Products
Measure and Control Instruments








Barometers





MN


Medical, scientific instruments


MN
MN
MN
MN


Thermometers

MN
MN
MN
MN
MN


Dental Equipment and Supplies


MN
MN
MN
MN


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3) Reporting Requirements
Mercury use reporting is seldom required under the existing regulatory framework. Most
reporting requirements track mercury releases, and are discussed separately in the "Mercury
Release" section that follows.
At a federal level, only facilities that exceed threshold planning quantities for mercury under
SARA Title III regulations must report that quantity to their local emergency planning
commission. This program is included under "Releases," because it is geared toward spill
prevention, rather than use. EPA is currently considering a chemical use inventory, which
would track the quantities of chemicals used at individual facilities.
Currently, only Michigan has regulations that specifically require facilities to report the
quantities of chemicals used. Under the Part 9 rules of Act 245, Michigan's water pollution
control act, businesses that use any substance listed on the "Critical Materials Registry" must
report the quantities of each substance used and released. Mercury is included the Critical
Materials Registry. The state uses this information to assist in permit development and
compliance in its water program.
C) Mercury Release Regulations
This section describes regulations that affect mercury release into air and water, as well as
waste disposal, and requirements for public disclosure of releases (e.g., TRI reporting).
Specific statutes—at a federal and/or state level—regulate mercury in each of these different
categories. Appendix B shows the specific mercury release regulations that apply to each
mercury source.
The Clean Air Act, Clean Water Act, and the Resource Recovery and Conservation Act
(RCRA) all operate differently, and impose different thresholds that influence the extent to
which mercury releases are covered. In addition, states have the flexibility to impose site-
specific mercury regulations on individual sources. With the exception of the Toxic Chemical
Release Inventory (TRI), which specifically requires facilities to report chemical releases into
all media, programs that require mercury release reporting are incorporated into broader
regulatory programs.
The following information is provided for each statute discussed: the principal provisions that
affect mercury releases; the specific sources regulated; the threshold that triggers coverage; the
regulatory mechanism(s) used; environmental standards included in the statute; potential
changes to existing regulations; and other relevant statutes that may provide similar
information.
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1) Mercury Air Emissions
Statute: Clean Air Act
Principal Provisions that affect mercury releases:
Mercury and mercury compounds are considered Hazardous Air Pollutants (HAPs)
under the Clean Air Act. To date, EPA has established National Emission Standards
for Hazardous Air Pollutants (NESHAPs) for mercury emissions from three source
categories: ore processing facilities, mercury cell chlor-alkali plants, and sewage sludge
driers.
EPA will also be promulgating a new category of regulation, known as maximum
achievable control technology (MACT standards) for "major source" in any listed
source category. Major sources are defined as those sources that release 10 tons per
year of any HAP, or 25 tons per year in total HAP emissions. Mercury releases alone
are unlikely to trigger the major source definition. For instance, Wisconsin's air point
source inventory showed the highest mercury release at 1000 pounds, well below a 10
ton (20,000 pound) threshold for major sources.
It is too early to tell the extent to which MACT standards will influence mercury
release levels. MACT standards will be defined based on an analysis of existing control
technology for a given source category. Thus, if mercury controls are not currently in
use, they may not be part of a defined MACT standard. EPA may set lesser quantity
cutoffs, which would redefine the level at which a facility would be defined as a major
source.
Under the Title V Operating Permits program, states may impose emissions fees up to
$25/ton of emissions for all chemicals. Facilities releasing mercury are subject to this
fee for their mercury emissions. Without a differential fee structure, the fee alone is
not likely to be high enough to spur reductions in mercury emissions. For instance,
Wisconsin's largest source of mercury air emissions, an electric utility, would only pay
$15.90 for its mercury releases (.63 ton @ $25/ton).
Specific Sources covered: Only three source categories have NESHAPs for mercury
emissions: (1) mercury cell chlor alkali plants (2) sewage sludge incinerators and driers
(3) mercury ore processing facilities.
Individual states may impose specific mercury emissions limits on individual facilities.
For instance, many states impose mercury emissions limits on municipal and hazardous
waste incinerators.
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Threshold that triggers coverage: Listed source category for NESHAPs (no numeric
thresholds); MACT threshold not yet defined, but will probably be specific to source
categories.
Regulatory mechanism(s): emissions limits, emissions fees, permits, monitoring,
operating requirements (which may include pollution prevention), reporting.
Environmental Standards'. No federal ambient air mercury standards
Potential Changes: The 1990 Clean Air Act amendments single out mercury for
additional study—and potential future regulations—more than any other substance. The
following studies may potentially alter significantly the manner in which mercury air
emissions are regulated:
Mercury Studv ($112(W1VB^: The 1990 Clean Air Act amendments mandated a
special study of mercury emissions to the environment. The study, which will be
finalized in early 1995, is estimating the relative contribution of mercury emissions
from source categories, the public health and environmental effect of such emissions
and evaluating available control technologies and their costs.
EPA must also list (by 1995) the source categories that account for at least 90% of
aggregate emissions for seven pollutants, including mercury (§112(c)(6)). Information
developed for the mercury study will contribute to this evaluation. Sources identified
in the § 112(c)(6) strategy will be subject to MACT standards within ten years.
Utility Studv ("ST 12(n)(n(AY>: Closely tied to the mercury study is the Utility
Emissions Study, mandated by Section 112(n)(l)(A) of the 1990 Clean Air Act
amendments. This study, scheduled for completion in November 1995, will describe
in detail the contribution of utilities to mercury emissions and other HAPs. The CAA
exempted utilities from the categories of sources potentially subject to MACT standards
until the study is completed. The study may recommend specific controls, including
controls for utility boilers, which are currently unregulated for mercury emissions.
Municipal Waste Incinerator Limits f$129): EPA has begun a rulemaking for mercury
emissions from municipal and medical waste incinerators.
Great Waters Program: Section 112(m) required EPA to study atmospheric deposition
of mercury and other substances into several large water bodies, including the Great
Lakes. The program is geared toward building an improved atmospheric monitoring
network that will enable EPA and other agencies to study the relative contributions of
different HAPs and the extent to which atmospheric deposition causes human health or
environmental problems. If necessary, EPA may require additional controls on certain
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sources as a result of this study. Under §112(m)(5), EPA is required to assess the
contribution of atmospheric deposition to pollutant loadings, the environmental and
public health effects of atmospheric deposition and the extent to which atmospheric
deposition contributes to water quality standard exceedances. The Great Waters report
recommends that EPA promulgate Lesser-Quantity Emissions Rates for mercury.
Other relevant statutes: Mercury air releases are listed in a facility's TRI report,
provided the facility meets the TRI threshold reporting requirements. RCRA
regulations cover emissions from hazardous waste combustion, and boilers and
industrial furnaces. Existing regulations do not include specific mercury standards.
Statute: OCCUPATIONAL Safety AND HEALTH ACT
Mercury Information: The Occupational Safety and Health Administration has
responsibility for maintaining safe workplace conditions. OSHA sets permissible
exposure levels for mercury in workplace settings. Mercury is listed as a neurotoxin
capable of causing behavioral changes, decreased motor function and other effects on
the nervous system (29CFR1926.59). OSHA mercury standards also recommend that
skin contact should be avoided.
Workplace standards may influence the types of processes used at a facility. For
instance, OSHA standards for cadmium were tightened recently. Stricter OSHA limits
for cadmium will force many cadmium users to modify their processes or eliminate
cadmium entirely in order to meet these new standards.
Regulatory Mechanism(s): operating requirements, inspections
Environmental Standards: workplace air concentration levels
Specific Sources covered: Facilities that use mercury are subject to mercury standard
Potential Changes: None identified. However, the Agency for Toxic Substances and
Disease Registry (ATSDR), which evaluates exposure levels for hazardous substances
at superfund sites under CERCLA, recently revised its toxicological profile for mercury.
Although these levels have no direct regulatory effect, they may cause other agencies
that evaluate mercury exposure levels to re-evaluate existing standards.
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2) Mercury Discharges to Water
Statute: Clean Water Act
Principal Provisions that affect mercury releases:
Mercury is listed as a toxic pollutant under §307(a) of the Clean Water Act. For
mercury discharge, Clean Water Act regulations specify technology-based effluent limits
for classes and categories of industries, and describes the circumstances in which states
may require effluent limits or monitoring requirements more stringent than technology-
based standards. States may also set water quality standards for pollutants including
mercury. The Clean Water Act relies on a permit system, known as the National
Pollutant Discharge Elimination System (NPDES) to regulate water discharges.
Facilities may be assigned a specific mercury discharge limit, or may only be required
to monitor their discharge for mercury. Facilities report actual discharge levels in
Discharge Monitoring Reports (DMRs), which serve as the basis for determining
compliance.
Pretreatment standards regulate industries that discharge into a publicly owned treatment
plant (POTW) instead of discharging directly into a receiving water body. Regulations
list industrial categories subject to national categorical pretreatment standards for new
and existing facilities that discharge into treatment plants. POTWs with approved
pretreatment programs may set permit limits and conduct inspections of industrial users.
Facilities that do not have specific pretreatment standards for mercury (or other
hazardous substances), are supposed to notify the POTW of any hazardous waste
discharge that exceeds 100kg per month. Wastestreams from certain manufacturing
processes that may involve mercury, such as fluorescent lamps and switchgear, are
excluded from categorical pretreatment standards because they are considered dilute.
Mercury is included in the list of chemicals eligible for removal credits at a
POTW. That is, a POTW may allow a facility to discharge a higher quantity
of mercury provided that the POTW meets the applicable mercury standard in
its sludge without additional costs.
EPA Region 5 Water Division recently revised its enforcement program for certain
chemicals to trigger enforcement investigations earlier than the previous program.
Under the Great Lakes Enforcement Strategy, EPA will target violations of daily
maximum permit limits. This screening criteria is more stringent than the national
definition of significant noncompliance, which targets violations of monthly average
limits.
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Specific Sources covered: The Clean Water Act lists technology-based standards for
the following industry source categories: Inorganic Chemicals Manufacturing, chlor-
alkali subcategory (mercury cell process)(40CFR415.60); Nonferrous Metals category
including, primary antimony subcategory (40CFR421.140), secondary mercury
subcategory (40CFR421.200), primary precious metals and mercury subcategory
(40CFR250); Steam electric power generation (40CFR423—mercury is an Appendix A
priority pollutant); Ore Mining and Dressing Category including, mercury ore
subcategory (40CFR440.40), copper, lead, zinc subcategory (40CFR440.100), platinum
ores subcategory; Pesticide Manufacturing category, metallo organic pesticide chemicals
subcategory (40CFR455); Battery Manufacturing category, LeClanche and zinc
subcategories (40CFR461.40).
However, this list does not limit the types of dischargers that may have mercury
effluent limits or monitoring requirements in their NPDES permits. Individual states
may impose specific mercury discharge limits and/or monitoring requirements on
individual facilities that discharge into water quality-limited waterbodies. The current
EPA-approved level of detect for mercury is 200 ng/L, which may be higher than water
quality based effluent limits, and higher than some states' water quality standards for
mercury.
Threshold that triggers coverage: No volume or quantity threshold
Regulatory Mechanism(s): effluent limits, effluent fees (WI), permits, operating
requirements, control requirements, monitoring/reporting
Environmental Standards: surface water, sludge
Potential Changes:
Great Lakes Water Quality Initiative fGLP: In recognition of the vulnerability of the
Great Lakes to bioaccumulative pollutants, including mercury, EPA proposed water
quality criteria designed to protect aquatic life, wildlife, and human health on a long
term basis. The GLI is designed to remedy the differences in water quality standards
of the Great Lakes states and protect lakes from chemicals that bioaccumulate in the
food chain. Released in draft form, the GLI proposes several major changes to water
quality programs in the Great Lakes states, including water quality standards for
mercury designed to protect wildlife.
Clean Water Act Reauthorization: Several bills introduced into Congress as part of the
Clean Water Act reauthorization process may change the current regulations governing
mercury water discharges. Proposed changes include a ban and/or discharge tax on all
mercury discharges.
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Other relevant statutes: Mercury water releases are listed in a facilities Toxic Release
Inventory, provided the facility meets the TRI threshold reporting requirements (see
discussion under Mercury Reporting Requirement). Michigan also collects information
on use and release in its Critical Materials Registry.
3) Mercury Waste Disposal
Statute: Resource Conservation and Recovery Act (RCRA) (see also 40 CFR 261)
Principal Provisions that affect mercury disposal:
RCRA regulations outline specific classification and disposal requirements for products
and wastes that contain mercury. In general, RCRA regulations are waste-specific, not
source-specific, and thus may apply to any facility that generates mercury-containing
wastes.
Waste code identification: RCRA regulations assign specific waste codes to five types
of wastes that are either "characteristic" wastes or "listed" wastes. Mercury is both a
characteristic and a listed waste under RCRA.
Wastes are considered "characteristic" hazardous wastes if they exhibit any of four
specified characteristics: ignitability, corrosivity, reactivity, or toxicity. Ignitability,
corrosivity, and reactivity describe, general properties of the waste, whereas the toxicity
characteristic identifies wastes likely to leach specific toxic constituents into
groundwater if managed improperly. Wastes that exhibit concentrations above a
specific regulatory level for any of 40 substances, including mercury, are considered
hazardous.
A specific "D" waste code identifies the contaminant(s) for which a waste exhibits the
toxicity characteristic. The regulatory level for mercury is 0.2 mg/1 (or 0.2ppm), and
the waste code D009, identifies wastes that exceed the toxicity characteristic for
mercury (40CFR261.24). Regulations outline the required toxicity characteristic
leaching procedure (TCLP) test necessary to determine the concentration of each
substance (40CFR261 AppII).
"Listed" wastes are specifically identified wastestreams or products that appear on one
of three hazardous waste lists in RCRA. Each listed waste is assigned a different waste
code. Wastes from non-specific sources such as spent solvents, are assigned an "F"
code. Wastes from specific sources are assigned a "K" code. Each of these wastes are
listed for a specific substance (40CFR 261.30). Appendix VII of the regulations lists
the constituents that caused specific wastestreams to be listed.
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Commercial chemical products such as manufacturing chemical intermediates, off-
specification species, container residues, and spill residues may also be considered
hazardous wastes when discarded. Two sublists identify waste codes for commercial
chemical products. Chemicals assigned a "P" code are considered acute hazardous
wastes when discarded (40CFR261.33 (e)); chemicals assigned a "U" code are toxic
chemicals considered hazardous when discarded and are regulated like other listed
hazardous wastes (40CFR261.33(f)). The P and U lists are triggered only when the P
or U chemical is the sole active ingredient, a commercial product is discarded, or a
listed chemical is spilled. These lists do not apply to manufacturing process
wastestreams that contain listed chemicals.
In addition to the D009 waste code, the following waste codes identify mercury-
containing wastes or discarded chemical products:
F039: Leachate (liquids that have percolated through land disposed wastes) resulting
from the disposal of more than one restricted waste classified as hazardous. F039 is
listed for multiple substances and may not be a reliable indicator of mercury in the
wastestream.
K071: Brine purification muds from the mercury cell process in chlorine production,
where separately prepurified brine is not used. K071 is listed only for mercury.
K106: wastewater treatment sludge from the mercury cell process in chlorine
production. K106 is listed only for mercury.
P065 identifies mercury fulminate (mercury compound used in explosives) as an acute
hazardous waste;
P092 identifies phenylmercuric acetate (mercury compound used in paints) as an acute
hazardous waste; and
U151 identifies mercury as a toxic waste.
Disposal Requirements, including prohibitions on land disposal: RCRA regulations
describe specific disposal requirements for individual waste codes. All mercury-bearing
wastes (wastewaters and nonwastewaters) are subject to land disposal restrictions. That
is, the mercury concentration in these wastes must be below the regulatory
concentration level before the wastes may be land-disposed. For some types of waste,
the regulations require a specific treatment, such as incineration or thermal treatment.
In other cases, only a maximum mercury concentration is required, and any treatment
method may be used. As a result of recently imposed land disposal restrictions on chlor
Page 44
Ross & Associates Environmental Consulting, Ltd. 9/12/94

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Virtual Eliminaiion Pilot Project
Mercury Sources and Regulations
alkali wastes (K071 and K.106), some facilities are building their own mercury recovery
facilities, whereas others are shipping their wastes to Canada or elsewhere for disposal.
RCRA regulations also influence product disposal and recycling options for mercury
containing products. Discarded products considered hazardous wastes are subject to
storage, transportation, and permitting requirements under RCRA subtitle C (hazardous
wastes). Currently, batteries are included in a "universal waste rule" that eases RCRA
restrictions on hazardous waste management and enables states to set up special
collection programs. Fluorescent lamps, however, are considered hazardous waste
because levels of mercury exceed the toxicity characteristic for mercury. EPA is
considering two options to ease disposal restrictions: (1) including mercury-lamps in the
universal waste rule to facilitate recycling, or (2) a conditional exemption which would
allow disposal in solid waste landfills.
Requirements for owners and operator* of ha7prdon;! waste land treatment facilities:
Landfill owners must determine the mercury concentrations in any wastes if food chain
crops are grown at the facility. Food chain crops cannot be grown on the treated area
of a hazardous waste land treatment facility unless the owner or operator can
demonstrate, based on field testing that any mercury and other specified constituent will
not impair the quality of the food grown there (40CFR 265.273 and .276).
Ha7flrrinns waste combustion: RCRA regulates air emissions from hazardous waste
combustion and boiler and industrial furnaces (BIFs). Cement kilns, regulated under
interim BIF standards, frequently burn hazardous waste as a fuel source. Federal
regulations for hazardous waste incinerators do not currently set metals limits. A
potential for regulatory overlap exists between RCRA hazardous waste combustion rules
and Clean Air Act municipal waste combustion rules.
Specific Sources covered: Any facility that uses mercury may generate waste that
exceeds the toxicity characteristic for mercury. Facility operators use best professional
judgment to determine whether or not to test their waste specifically for mercury.
Mercury-cell chlor-alkali facilities are the only mercury sources that have specifically
listed wastestreams (K071, K106).
Threshold that triggers coverage: Facilities must meet RCRA hazardous waste
quantity thresholds before they are required to report information on their hazardous
waste generation and management. Thresholds are based on the total amount of
hazardous waste generated at a facility, not on the amount of any one kind of waste
(e.g., facilities that generate more than 2,200 pounds per month of hazardous waste are
considered large quantity generators; facilities that generates 220 - 2,200 pounds of
hazardous waste per month are considered small quantity generators). Therefore, levels
Ross & Associates Environmental Consulting. Ltd. 9/12/94
Page 45

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Virtual Elimination Pilot Project
Mercury Sources and Regulations
of mercury waste alone are not likely to determine whether or not an individual facility
it subject to RCRA requirements.
Regulatory Mechanisms: disposal restrictions, labeling, control requirements,
inspections, planning requirements, operating requirements, permits, reporting
Environmental Standards: hazardous waste concentration, groundwater standards
Potential Changes: EPA is revising the hazardous waste combustion rules, the interim
standards that regulate boilers and industrial furnaces, and fluorescent lamp disposal
requirements. The "universal waste rule" for batteries, and possibly thermostats, is
scheduled to be finalized in the fall of 1994.
4) Mercury Reporting Requirements
Several sections of the Superfimd Amendments and Reauthorization Act of 1986 (SARA),
which amended CERCLA to address ongoing activities that result in releases of hazardous
substances, impose reporting requirements on mercury use, release, and spills. Title III, known
as the "Emergency Planning and Community Right-to-Know Act" establishes emergency
release, inventory, and release reporting requirements. The most well known requirement is
the Toxics Release Inventory (TRI), which requires facilities in the manufacturing sector (SIC
codes 20-39) to report releases to air, water, and land for all listed chemicals, including
mercury. Other sections require facilities to report spills of listed substances above a threshold
reporting quantity (reportable quantities), and the quantities of chemicals stored above a
specified threshold planning quantity. Each of these sections is discussed separately below.
Statute: (SARA Title III, §313) Toxic Chemical Release Inventory (TRI)
Principal Provisions that affect mercury reporting: All facilities in the
manufacturing sector (SIC codes 20 - 39) that meet the threshold reporting requirements
must report their releases of mercury to all media. TRI thresholds are based on the
quantity of each substance used, processed, manufactured, or imported at any of these
facilities.
Mercury is one of 17 priority chemicals target by EPA's 33/50 program, a voluntary
pollution prevention initiative that established an interim goal of achieving a 33%
reduction in releases of targeted chemicals by 1992 and a 50% reduction by 1995, using
1988 TRI reporting data as a baseline. The 33/50 program is one of EPA's primary
voluntary reduction programs designed to augment traditional command and control
regulations. Releases and transfers of the 33/50 chemicals declined four times faster
than non-33/50 chemicals between 1991 and 1992.
Page 46
Ross & Associates Environmental Consulting, Ltd. 9/12/94

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Virtual Elimination Pilot Project
Mercury Sources and Regulations
Specific Sources covered: Any manufacturing facility that uses quantities of mercury
above the reporting threshold.
Threshold that triggers coverage: Facilities that manufacture, process, or import
25,000 pounds of mercury and/or otherwise use 10,000 pounds of mercury must report
releases to all media. These thresholds are generally too high to capture the vast
majority of sources that use mercury.
Regulatory Mechanism: public disclosure, reporting
Potential Changes: EPA is considering two proposals that would affect the number
and types of facilities required to report under TRI. One proposal would lower the TRJ
reporting threshold, and perhaps include multiple thresholds. Given the low number of
sources captured under the current reporting threshold, it is conceivable that, depending
on the level of a new threshold, many new facilities would be captured under TRI.
Another proposal would expand the reporting universe beyond the manufacturing sector.
At present, mining operations, waste disposal sources, and other facilities not included
in SIC codes 20 - 39, are not required to report releases under TRI. Again, depending
on how this expansion is structured, different types of facilities would likely be captured
under TRI.
Other relevant statutes: Clean Air Act, Clean Water Act, RCRA. Courts are
currently reviewing whether or not a facility that reports mercury releases to water in
its TRI report but does not have a Clean Water Act NPDES permit for those discharges
is in violation of its NPDES permit.
Statute: SARA Title III §302, §304, §311 and §312 (threshold planning quantities and
reportable quantities)
Principal Provisions that affect mercury reporting: SARA reportable quantities are
linked closely to CERCLA §102 reporting requirements. Under SARA §302, any
facility that produces, uses, or stores "extremely hazardous" substances must notify the
State Emergency Response Commission. Mercuric acetate, mercuric chloride, and
mercuric oxide (mercury compounds) are considered extremely hazardous substances
(40CFR355). Under §304, a facility must notify the state emergency response
commission and a local emergency planning committee of releases that exceed
reportable quantities for hazardous substances. Facilities must also notify the National
Response Center (1-800-424-8802). The reportable quantity for mercury spills is one
pound (40CFR302).
Ross & Associates Environmental Consulting, Ltd 9/12/94
Page 47

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Mercury Sources and Regulations
Under §311 and §312, facilities that keep hazardous substances on-site in quantities
greater than threshold levels must submit a chemical inventory to the state emergency
response commission, the local emergency planning commission, and the local fire
department (40CFR370). The threshold for mercury (a hazardous substance) is 10,000
pounds, and the threshold for listed mercury compounds is 500 pounds (extremely
hazardous substances).
Specific Sources covered: Any facility that uses mercury may be potentially subject
to these regulations.
Threshold thai triggers coverage: Hazardous substances in quantities greater than
10,000 pounds, and extremely hazardous substances in quantities greater than 500
pounds must be reported. The reporting threshold for mercury spills is one pound
(40CFR355.40).
Regulatory Mechanism(s): reporting, public disclosure
Environmental Standards: n/a
Potential Changes: None identified.
Other relevant statutes: Clean Air Act, Clean Water Act, CERCLA. Ohio imposes
an annual chemical inventory filing fee of $100.00 base fee, plus $10 for each
additional hazardous substance over 5 substances and $50 per extremely hazardous
substance reported. The facility filing fee cap is $2,500.
Page 48
Ross & Associates Environmental Consulting, Ltd. 9/12/94

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Virtual F.liminnlion Pilot Project
Mrmiry Snortti and RrgiilaHnns
TABLE 12: POTENTIAL CHANGES IN MERCURY REGULATIONS
Using Mercury
Regulation Category
Commerce:
Import tax
Government Stockpile sales
Fed/State
Fed
Fed
Potential Change
•	Mercuric oxide, a mercury compound used in military and medical batteries, will
be exempt from all import duties under GATT effective July 1, 1995.
•	Bills introduced into the House and Senate would extend the duty waiver on
mercuric oxide that expired at the end of 1992.
•	A bill introduced into the Senate would suspend the duty on equipment used to
recycle mercury and other parts of fluorescent bulbs.
•	1995 Annual Materials Plan requests authorization to sell 20,000 flasks of mercury
•	DLA may offer long term sales contracts for mercury fiscal year 1994 mercury
sales.
Products
Fed
Bills introduced into Congress would limit the mercury content and impose sales
restrictions on batteries containing mercury, and limit the mercury content in packaging
'Releasing Mercury
Regulation Category
Air emissions
Fed/State	Potential Change
Fed (CAA)	• Mercury study: identifying sources of mercury, public health, and environmental effects,
and available control technologies
•	Utility study: evaluating utility HAP emissions and public health effects; may recommend
emissions limits
•	Municipal waste incinerator rules (CAA § 129): may result in mercury emissions limits for
municipal and medical waste incinerators
•	Great waters study:
•	MACT standards
Water discharge
Waste disposal
Fed (RCRA)	• Hazardous waste combustion rules, BIF rules
Fed (CWA)	• GLI: uniform water quality standards for mercury
• CWA reauthorization: proposed changes include discharge taxes and bans
Fed (RCRA)
MN
Hazardous waste combustion rules, BIF rules, lamp disposal rules
Solid waste incinerator standards
Reporting requirements	Fed (TRI)
Ross A Associates Environmental Consulting. Ltd.
Lower thresholds, expanded reporting community
CHANOESJCLS

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Virtual Elimination Pilot Project
Mercury Sources and Regulations
Appendices
Appendix
A:
Mercury Use Tree
Appendix
B:
Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
Appendix
C:
Products that Contain Mercury
Appendix
D:
Summary of Mercury-Specific Statutes in the Great Lakes States
Appendix
E:
Battery Statutes
Appendix
F:
Data on Mercury Releases
Ross & Associates Environmental Consulting. Ltd 9/12/94

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Appendix A: Mercury Use Tree
(prepared by the Lake Superior Work Croup)
>
a.
z>
u
a.
UJ
en
UJ
a
a
3
O
to
£
D
O
I—
a>
E
o

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* = discontinued
The mercury use tree was developed by Carri Lohse-Hanson of the Minnesota Pollution Control Agency on behalf
of the Lake Superior Workgroup. The use tree is part of the Binational Program to restore and protect the Lake
Superior basin.

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Viiltin| EfiminMion Pilot Project
Mrrtury Smtrres imd Itegutiitlons
Appendix B: Industrial Sources of Mercury am' Applicable Mercury-Specific Regulntions

U FAC.
ORIGIN/USES

WATER
WASTE

SOURCE
IN CL*
OF MERCURY
AIR RELEASES *¦
DISCHARGES ***
MANAGEMENT*'**
COMMENTS
MERCURY PRODUCTION
Primary llg
Production

1 Ig no longer produced
fniin 1 Ig ore; primary 1 Ig
recovered us by-product
from gold ores
NliSI lAl'S: 1 Ig air
emissions shall not exceed
2300 grums llg/24hrs Tor
mercury ore processing
facilities (40CFR6I.52)
llg diluent limits lor
primary precious inetats
und llg subcategory
(40CFR42I.250) nnd
mercury ore subcategory
(40CFR440.40)
Solid wastes from
extraction,
beniliciation, und
processing of ores
exempt from RCRA
hazardous waste
regulations under
llcvill amendment.
Mining facilities do not
report chemical releases
under TRJ.
Secondnry Hg
Production
l'A--2
II.--1
NY—1
Recycling/recovery of 1 Ig
conluining products (e.g.
dental uinulgams,
batteries); industrial
waste and scrap (e.g.
instrument and electrical
manufacturing, waste,
sludges froin research
labs)
Designated mujor source
category of IIAP
emissions (CAA5112(c))
llg ellliient limits I'ur
secondary 1 Ig
subcategory
(4UCIrR42I.200)--NSPS,
I'SNS bused on amount
of 1 Ig produced nr
processed

In-liuuse 1 Ig reclamation also
occurs at industrial plants.
A bill introduced into the IJS
Senate would eliminate
the tariff on machines
used to recycle 1 Ig from
fluorescent btilbs.
Key: I Ig - Mercury, CAA - Clean Air Act, NLSIIAPS -
National Emissions Standards for Hazardous Air
Pollutants, 11IF - boilers nnd industrial furnaces, TRI •
Toxic Release Inventory, MSW - municipal solid waste,
HAP - hazardous nir pollutant, MACT - maximum
achievable control technology
MN: drilling management
standards for facilities
recycling hazardous wastes
llg refining plants in NY, PA, 1L
MN ulso litis three liiinp
recycling facilities.
Note: This tulile slums the significant sources "Til" relciisci by source category, nnd Inn* those releases tire
currently regulated. Appendix A Includes live catenaries nT mercury sources: (I) Mercury Production, (2) Use
ns a Manufacturing Input, (3) Waste Disposal, (>
/\(ERC9407JCLS. In J sourer

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Virtual Kliininutioii Pilot Project
Mercury Source* nnd R((iiliillnns
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
SOURCE
n FAC.
IN CL'
ORIGIN/USES
OF MERCURY
AIR RELEASES"
WATER
DISCHARGES ***
WASTE
MANAGEMENT****
COMMENTS
MERCURY PRODUCTION CONT.
llg compound
production
NY--3
OII--I
I'A— 1
llg compounds include
mercuric oxide, mercuric
chloride, mercuric &
mercurous sulfate,
incrcurous nilmle,
orgiinic llg stilt,
thimersol



M;uiy mercury compounds
lire imported. Duly lor
mercuric oxide will be
suspended under GATT
NOTE: Other inurccs of Hr, including (he Nntlonnl Defense Stockpile, Department of Energy stocks, nnd imports are disunited in the
overview of mercury regulation.
Htt.u .li.iociut€M Envkonmtntal Consulting, l.tct.

MEHC9407.XIX. hut source

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Virttinl |'!)iiniimtion Pilol Project
Mfimcy Suiirtrs unit
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
« FAC. ORIGIN/USES
SOURCE IN CL* OF MERCURY AIR RELEASES "
WATER
DISCHARGES
WASTE
MANAGEMENT""
COMMENTS
| MERCURY USE IN MATf 1JFAOTUIt 1NG* -j^ ,v¦"^- ^
Chemic.il And Allied Products
Chlorine/Caustic
WI--I Used us u calulyst in
1 Ig emissions ciinnot
Existing Sources: DAT,
Industry Specific:
Lurgest single use nl'llg in IIS
Soil it
Ol I--I mercury cell process u(
exceed 2300g /24hrs;
IHTIIg ellluent limits
K07I und KI06 are

Manufacture
chlor-ulkuli plants, which
prescribed stack dimpling
New Sources: NSl'S,
chlor-olkali wustes
linpuct of land disposal

munulucture chlorine
methods required, and
PSNS
listed specifically for
restrictions: some facilities
(mercury cell
tind sodium hydroxide.
approved practices to

1 Ig. Land disposal
are building mercury recovery
chlor-ulkuli
1 Ig cell process
meet specified ventilation
No presentment
restrictions for
plants; others are shipping
process)
uccountcd lor 14% of
emissions. (CAA
standards lor existing
clilor-ulkali process
wustes to Cnnadu

1992 US chlorine
(40CFR6l,Nr:SllAPS))
sources using mercury
wustes effective May


production.

cell process
1993
Many llg cell plants have



(40CFR415.60)

changed to diuphrugin cell





process
Laboratory Uses
Used in instruments as

No restriction --I'OTWs

Use declined from 32 metric

reagent, ciilnlyst.

may develop public

tons in 1990 to 10 metric tons

indiculor, und lor

education campaigns Ibr

in 1991.

calibration, sealing, and

Inbs



radioactive diagnosis




Paint
Mercury compounds


11)92 - I'hcnylmercuric
'All registrations lor mercury

used to control


acetute (llg
biocides used in paint banned

microbial growth in latex


compound used in
or voluntarily cancelled by

paint cans; prevent


paints) is un acute
registrant

mildew growth on


RCRA waste
• 1 Ig in paints expected to

pninlcd surfaces;



continue declining as existing

unli-fouling agent in



supplies depleted. I'aitil on

muritime painl



buildings is demolition wuste





(not RCRA)
Other Chemical and (see Tublc 5 and Appendix 13 for mercury- containing
Allied Products		 products.)
Ro.u & Aisociatei Environmental Comultlnx. l.td.
Pagt S of IS
MERC9407JiLS. in,I w.i/rer

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Virion) Hltminnlion Pilot Project
Mercury 5 -«ircei uiul Regiiliitlom
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
»FAC. ORIGIN/USES

WATER
WASTE

SOURCE IN CL* OF MERCURY
AIR RELEASES ••
DISCIIARCES •••
MANAGEMENT*
COMMENTS
Chcmicnl And Allied Products
Pesticides Mercury compounds
used ;is pesticides,
biocides, fungicides

Process wuslewiiter
from mimuriicliire of
inctulln-orgiinic
pesticides w/uclive
ingredient containing llg
prohibited, subject to
vurinnces upproved by
EPA (40CFR455.30)

Voluntiiry cancellation of last
two mcruiry-conWiiiiing
fungicides unnouneed in
November 1 lJ93
Ron A As.toclattM Envtronnirntal Consulting, Ltd.
Pot* 4 of ti
AtEH('9407JCLS. hitl source

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Vriltiol Kliiuiniilion Pilot IVojccI
Mrmiry Sources nnd Itrent.ilioiii
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
SOURCE
# FAC.
IN CL*
ORIGIN/USES
OF MERCURY
AIR RELEASES
WATER
DISCHARGES
WASTE
MANAGEMENT"
COMMENTS
Electrical And Electronic Uses
Electric Lamps
Use: elcclriciil
conductor Ilg emitted
wlten lumps brcnk
Pniilucli: llii;h
intensity lumps: mercury
vnpor lamps (used in
motion picture
product ion,
photography, licut
therapy); mctol linlidc
lumps; high pressure
sodium lumps;
incandescent lump
lilumenls, fluorescent lights
Waste streams from
fluorescent bulb
muiuifucturing exempted
from pretreiitmcnt
regulations (lor till
chemiculs)
llg levels in smne
products meet RC'RA
or stute huzunUms
wuste dellnition nnd
require special
management nnd
disposal
Second largest source of
mercury in MSW
Fluorescent bulbs are
promoted for energy
conscrvution, but considered
hazardous wuste due to llg
levels; lil'A is considering two
options to avoid lull Subtitle C
regulation: (I)conditionul
exemption; (2) inclusion in
universal waste nile.
MN Ims three lump recycling
facilities
Wiring Devkei &
1 Ig eiiciiseii in metal is
No pretreiitmcnt limits
Components found in a wide
Switches
used us conductor to
for swilchgcur
variety of equipment with

close electrical circuit
wustestreams (for imy
ctcclricul parts (e.g. while

Proilucls: Ihcrmostnls,
chemiculs)
goods)

llg cells in smoke



detectors, mercury arc



rectifiers, silent switches.



tilt switches, relays,



cathode tubes used lor



radios, rndur, ft



telecommunications



equipment, electric toys


Hcmj it AiJtn Uitfi tifivil onmtnlai Cott-ivltlng, Ltd.

hKRC9407JCLS. hut source

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Viilu;il Klitninalion I'ilol Project
Merrill^ Sourer* timl
Appendix B: Industrial Sources of Mercury nnd Applicable Mercury-Specific Regulations

U FAC.
ORIGIN/USES

WATER
WASTE
SOURCE
IN CL"
OF MERCURY
AIR RELEASES *•
DISCHARGES "¦
MANAGEMENT"** COMMENTS
Electrical And Electronic Uses, Cont.
Buttery

(1) 1 )sed ns anode or

llg effluent limitations lor
t'-iUcry muniifacturers have
Manufacturing

electrolyte to prevent

I.eClanchc subcategory
eliminated


corrosion and hydrogen

(zinc anode batteries
1 Ig levels in alkaline buttcric-


release; extends

w/acid electrolyte)
to .025% (zero added


shell-life; improves

(40CFR461.40); NSPS,
mercury); llg cannot he


performance in extreme

l'SNS, PSl-S based on
eliminated from mercuric


temperatures.

ing/kg cell produced for
oxide butteries where mercur


Products: ulkaline

specified operations
oxide is used as an electrode


butteries

only; no discharge
material.




allowed Iroin
1 latteries are largest source


(2) used us cathode in

nonspecified operations
of llg in MSW incinerators.


I Ig oxide butteries.





Products: mercuric

llg diluent limits for zinc
Military and medical batteric


oxide (1 Ig zinc) button

subcategory
use mercuric oxide to meet


balteric.1, silver oxide.

(40CFR46I.70) - HIT,
performance specifications;


zinc-air, carbon zinc

DAT, NSPS, I'SfiS,
the import duly for mercuric


butteries, mercuric oxide

PSNS specified lor
oxide will be suspended undi'


cunnister butteries. 1 Ig

various processes
GAIT


leaches from corrosion





in landfill; volatilizes


MN, WI.NY: restrict the 11;


during combustion


content in alkaline batteries





MN bans sale of mercuric
oxide batteries;
pending federal legislation
iniiy bun mercuric oxide
batteries
Hum A Ax-WciaHi Environmental Consulting, Lift
Paf 6of 1S
MFJIC9M7JCLS. hut wiii

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Viiluul Rliinin;ili
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Virtual Fliminntion Pilnl Project
Mtrcui; -tirces mill Rrj»ul;itli>iis
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
n FAC. ORIGIN/USES

WATER
WASTE

SOURCE IN CL" OF MERCURY
AIR RELEASES'"
DISCHARGES ***
MANAGEMENT*"*
COMMENTS
| PRQD|ICT DISPOSAL - INCINEI^TIQN AND LAND IMS: :
Municipal Wuste
llg is present in solid
No existing federal llg limit;
N/A
MSW ash is
Municipal solid waste indudi
Incineration
wuste (butteries, electric
l:PA must establish

considered hazardous
waste generated Iroin

lighting,etc.) - llg
numericul limits Tor llg

waste if it exceeds
residential, commercial, und
(under CAA, luol
emitted when wuste is
emissions (§ 129(a)(4)); not

RCKA toxicity levels.
institutional sources;
feed strcum must
burned tit high
included in list of 1 LAI'

Supreme Court
equipment installed to trap 11%
be >30% munieipul
temperatures
source categories.

decision (Chicago v.
ash and ucid ruin gases do not
wuste)

MN - proposed wuste
combustion rules including
emissions limits; new
incinerator permits with 1 Ig
limits will require air
monitoring systems and
periodic stack testing.

EDF, K Inixrli 1994)
control llg emissions
MN: llg must be removed
from products before
disposal. Oil: Considering
installing 1 Ig emission control
equipment and separating llg
conjaining products; II.:
Incinerator technology based
on consideration of specific
pollutants.
No existing federal I Ig limit;	N/A
I*l*A must establish
numerical limits Tor llg
emissions (§ 129(a)(4)); not
included in list or MAP
source categories.
Commercial/Industrial	I Ig present in wastes:
Wuste Incincrnlurs	butteries, lighting, etc.
{(nvktmmrniul Citnwltlrt)', l.hl.
1'itg* 8 vf /.1
A th'Jd 'VJtl7.XLS. httl toutr«

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Virtual nitininohVu* Pilul Project
Mercury .Sources mid Rrgiilitllona
Appendix 13: Industrial Sources of Mercury and Applicable Mercury-Spccific Regulations
SOURCE
# FAC.
INCL'
ORICIN/USES
OF MERCURY
AIR RELEASES 1
WATER
DISCHARGES
WASTE
MANAGEMENT-
COMMENTS
J'ROP (JCT DJSPOSA L - INC INERATIO N AND LAND DISPOSAL, CONT.
Sewage Sludge
Driers <&
Incinerators
NY--33 t Ig in sludge from
I'A—21 wastewater treatment
Ml--19 plunls.
CAA -1Ig emissions limit
= 32t)()g/2'1lirs; :wmi;il
monitoring unci reporting if
Jig emission* exceed t-600
g/24lirs; prescribed
emissions testing
procedure or procedures
for sludge to demonstrate
compliance (40CFR61.52,
NHSIIAI'S); Listed us
source cutcgory Tor I LAP
emissions limits (CAA
2(c)(1))
(see wastewater treatment)
Waitcwater
1 Ig present in wastewater
No existing standards;
Mercury is eligible for
Sludges for land
EPA will conduct studies to
Trentmcnt
entering facility
listed us category of 1IAI'
removal credits - I'O'lWs
application or surface
characterize 1 IAI'emissions


sources — MACT
iniiy rei|iiest removal
disposal inusl meet
from industries discharging to


slumlords due 1 'J'J5
credits iig;iinst facility
specific concentration
l'OTWs


(CAAjl 12(e)(5) -standards
pretrealinenl limits, us
requirements fur
Hazardous waste incinerators


muy include prctrentmcnl
long lis I'O'IW meets
tigriculhinil hind, forest
may test Ilg content in sludge


control measures Bnd
sludge concentration
limd, public contact
in lieu of emissions testing


process or product
limits
sites, home garden
requirements.


substitutions ur 1 imitntions

application or landfills
Western Luke Superior


(f!12(n))

Ilg cuneentrutiun
limits in sludge: 57
ing/kg limit Tor iund
nppliciition of sludge
{40CTO503)
Sanitary District (WI.SSI)) in
Diifulh, MN lias nctive
pollution prevention program
MI - POTWs must liuve waste
minimization plans
Hnznrduui Wmtc
Inctnerntnrs
IL--I
No uniform emissions
standards; Ilg limits
depend on individnul
Residues must meet
1.1)11 specified! ions
Not j.-peci fiddly listed us
CAA§I 12 (e) source ciilcgory
lor IIA1' emissions limits or
Hun.t A AuocUtltt Enviroimrnlat Conwtlln)*, Lid.
rep fefl J
KtEliCOJO 7-XLS. imlauunr

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Vii1u.nl Mliminnllon Pilot Project
Mercury Sources mid Regulations
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
M FAC. ORIGIN/USES
SOURCE IN GL* OF MERCURY
WATER
AIR RELEASES " DISCHARGES *"
WASTE
MANAGEMENT"**
COMMENTS
j PRODUCT: DISI'OSAL - INCINERATION: ANp LAND DISPOSAL* CONT;
Mnziirdouj Wiute
Indncrntors (cunt.)
pennits; facilities shielded
Irom rcguliilory chiinges
until permit expires (CI;R
264.344)
Waste analysis required to
determine 1 Ig
concentmtions unless
incinenitor luis
documentation of no Kg
presence (4DCFR2fi5.341)

§129 (solid waste incineration)
CI'A is revising dr:ilt
hazardous w;iste combustion
rules - considering
technology-based vs
risk-based standards
Cement kilns ulso bum
hazardous wnste
Mcilicnl Wnslc llg in wnstesi gcncnitcd
Inrlncrntori from hospitals, clinics,
lill)S, etc.
No existing llg limits; lil'A
must establish nuinericul
limits lor 1 Ig emissions
(§I29(uX4)); not included in
list ofHAP source
categories.
VVI - incinerators willi
ciipiicity >5 tons/day must
be tested for 1 Ig during llrst
90 duy period und following
ycur


Landfills
Monitor for llg in
groundwater, Icuclmte
testing requirements
Subtitle D
(non-liiiziirdous)
liuidfills: lencliute
cannot exceed 0.2mg/l
He;
MN - studying llg content of
liiiulfill gus und Icuclmte.
II. - llg components must be
removed from discarded white
goods (e.g. appliances) before
disposal
| PRODUCT DISPOSAL -INCINERATION AND LAND DISPOSAU CONT.
Ho\.i 
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Virtual Diminution Pilot Project
Mm tiry Sources mill ltrgiihifloiii
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
# FAC. ORIGIN/USES WATER	WASTE
SOURCE	IN CL* OF MERCURY	AIR RELEASES ••	DISCHARGES	MANAGEMENT*"**	COMMENTS
Landfills (cont.)
Subtitle C (hazardous


wusle) landfills:
MN: I Ig must be removed

disposal prohibited
from products before

unless waste
disposal.

undergoes prescribed


treatment to reduce


1 Ig to regulated levels


Determine Hg


concentrations if


food chain crops are


grown -1 lg cannot be


transferred to food


chain portion of crop

Ash disposal	Mercury in incinerator permit specific
facilities	ash
Auto snlvnge/	Automobile
scrnp ynrds	components have Ug,
some automobiles used
lor illegal disposal; I Ig
released from crushing
	switches		
Crcmotorles	I Ig in dental fillings
vulutili/.cs during
cremation
Hospitals,	Mercury in waste streams	No pretreatment regs	II.: I" IHireau gives guidance
Dentists	(wnter and solid wuste)	on I Ig disposal
MN: WIJ5SI) has a brochure
for dentists
Oil: Community volunteer
efforts address I Ig in waste
/faint Jxinclatf* EnvtrtmnirnlalConsulting. l.tj.	ragr It of 13	httf .unirre
MN monitors mercury
levels
MN: developing best
manugemcnt practices Tor
yurd operators

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Virtual Rliminalinn Pilot Project



Mtmiry Sources nnil RccithiHoiia




Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations

ft FAC.
ORICIN/USES

WATER WASTE
SOURCE
IN CL*
OF MERCURY
AIR RELEASES••
DISCHARGES MANAGEMENT*"* COMMENTS
Carbon Dlnik
MI—I
llg present in oil feedstock

No 1 Ig limits; but discbarge of
Production
OII--I


process waste water prohibited




except to POTWs. 40CFIW5K
Coke Production
IL--3
I Ig is By-product present



IN--3
in coul used us



MI—I
feedstock for coke oven



NY--1
. butteries (primary



Oil—3,
feedstock for iron und



PA—3
conl industry)


Petroleum

llg present in petroleum cmde
No specific llg limits.
Refining




Lime
II.—1
llg present iim impurity in


Manufacturing
Oil—1
processed stone und



PA—1
from fuel used to heut




kiln*


Portland Cement

llg present in ore und
No specific llg limits; KCItA
Cement kiln dust exempt from
Manufacturing

mineruls used as ruw
I)ll: rule sets emissions limits
11CIIA hazardous waste


materials; llg in fossil
und operating standards lor
definition.


fuels used in cement
kilns und oilier facilities Hint



kilns
burn wastes; nil MPs openile
Cement industry is increasing



under interim status
its use of municipal, industrial.




und hazardous wastes for kiln



Feed rule screening limits for
firing to replace fossil fuel use



mercury specified under
(lor energy conservation);



interim standards lor burners
KPA is revising draft



or industrial furnaces
hazardous waste combustion



(40CF1W6.I03 and 266.106)
rules
Phnsphatc-bnscd I Ig is trace element in rock
fertilizer factories	phosphate	
Uttu *it Axsttclaltx lOivironmenta! (Utruulllnx. Ltd.
I'mIJ of IS
MFMC9-/07.XLS, hit/wttrce

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Virtual Mliminulion Pilol I'rojccl
Merrill? Sources iittd llcgiilulloiis
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
SOURCE
n FAC.
IN CL*
ORIGIN/USES
OF MERCURY
AIR RELEASES
WATER
DISCHARGES
WASTE
MANAGEMENT*
COMMENTS
MERCURY AS A BY-PRODUCT OF MANliFACTURING PROCESSES, CONT.
Primary Smelting
& Refining of
Copper	
Ml—I Copper recovered from
sulfide ore that contains
lie	
I Ig diluent limits lor copper,
lead, zinc, gold, silver ores
subcutegory (40 CFR 440.100)
Residues exempted from
RCKA under llcvill exclusion
Primary Smelting
& Refining of
Nonferrou*
Metals, Except
Copper &
aluminum
llg present in almost all No existing regulations
minerals; lend recovered
from sulfide ore that
contains llg; zinc
smelting process
generates I Ig
emissions
for mercury
Many mining Facilities
lire listed as source
categories for IIAPS
llg diluent limitations
for: primary antimony
subcategory (nonferrous
metals category).
(40CTU42I.I40); copper,
lead, zinc, gold, silver,
and inolymbdnemun ores
(40CFR44O.IOO), und
platinum ores
subcategory (440.110)
Residues exempted from
RCRA under Uevill exclusion
ftni.1 
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Viiliinl F.limiiulion Pilot Project
Mrrrury Smtrrrs mnl
Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations
SOURCE
n FAC.
IN GL*
ORIGIN/USES
OF MERCURY
AIR RELEASES
WATER
DISCHARGES
WASTE
MANAGEMENT"
COMMENTS
MERCURY RELEASED AS A BY-PRODUCT IN POWER GENERATION AND HEATING
Electric Power
Genenitinn
(Utility Boilers)
llg present in coal, oil,
niiliirnl gas, or wood
used in electric utility
slesini generating units -
emitted us truce
contaminant when
volatilized at high
temperatures.
No current I Ig emissions
limits under CAA. CAA
112(n)(l)(A) Utility Study
Report to Congress due
11/94 will unalyze (lie public
health hazards Prom
utilities; HPA muy
promulgate regulations
based on study results;
utilities exempted from list
or sources accounting Tor
90% of I Ig emissions that
will require MACT
standards (§112(c)(6)
No detectable I Ig
ill lowed in discharge
Residues exempt from
RCRA under llovill
exclusion
Con! has highest I Ig content
of fossil fuels. 80% of energy
consumption in utility boilers
is from coal combustion; 95%
ol'conl is bituminous and
subhituminous coal.
Commercial &
Industrial Boilers
I Ig present in fuels
Residential Boilers
nnd Wood Slovc*
1 Ig present in fuels
/fan A Associates Emironmsntnl Coniultbig. Ltd.
Pag* " M
S4FJIC9-W7.X1X but wit ret

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Virtual	Pilot Project
Mercury Sources ntitl Urgnlufimis
Appendix B: Industrial Sources of Mercury and Applicable Mcrcury-Specific Regulations
0 FAC.	ORIGIN/USES	WATER	WASTE
SOURCE	IN CL*	OF MERCURY	AIR RELEASES "	DISCHARGES •** MANAGEMENT""	COMMENTS
Notes:
Source categories used to identify manufacturing uses of mercury follow Bureau of Mines categories, which truck U.S. industrial consumption of
refined 1 Ig mclut.
Mercury releases to uir, wuter and land arc reported by manufacturing firms that meet TRI threshold requirements. Manufacturing facilities (SIC codes
20-39) that have 10 or more full time employees and manufacture/process 25,000 pounds of a listed chemical or otherwise use 10,000 pounds ol a listed
chemical must report chemical release information in 11(1.
*	"U FAC. IN GL" = number of facilities in Great Lakes States.
Source: National Emissions Inventory of Mercury and Mercury Compounds: Interim Final Report, USI-PA, 12/93.
"	Air emission*: EPA must list source categories that account lor 90% of aggregate Ilg emissions by l')95, excluding
electric utilities. Sources will be subject to MACT standards within 10 years (§1 I2(cX<>))- I'-I'A has also published a list of major categories and
subcategories of sources that emit hazardous uir pollutants (including mercury and compounds). Any stationary source emitting more than 10 tons per
year of a listed .substance or 25 tons per year of any combination of substances will be subject to MACT standards. Major air toxics.emitters will
require permits.
**•	Wntcr discharge: UAT=bcst available control technology, l)l'T=best practicable control technology, NSl*S=new source performance standards,
PSNS=prctreatment standards for new sources, PSES=pretreatmcnt standards for existing sources. States inuy impose more stringent permit limits
to meet water quality standards for mercury (standards vary by state). Facilities must notify I'OTW of hazardous substances discharged which are not
covered by prelrealment standards.
Wnstc mnnnRcment: Mercury is a listed und characteristic waste under RCRA. Any source listed here may be generating D009, the RCRA
hazardous waste code that identifies wastes characteristic for mercury. Other RCRA waste codes that identify mercury include UI51 (mercury), K07I
and K106 (listed for mercury), F039 (listed for multiple sources), 1HJ65 and l'092 (mercury compounds). All incrcury-conlaining wastes have land
disposal restrictions. Specified treatment for mercury-containing wastes is incineration or thermal processing (40C1:R 26H.42).
ffc/xi if Associate Envtronmtntut Conxulthx. Ud.
Pa f# 1J /J
AIERC9J07J\'LS. but source

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Virtual I'fiminalion Pilol Project
Mrrrury Suitrrra mi
-------
Viriuul HliminnlSon Pilol Project
Mercury Sources tand K«ctil«tliina
Appendix C: Regulations on Products that Contain Mercury
Note: 7 hit table hlghliyhLi regulation* that affect the mo.it common mercury-containing jtroducti. It it not a com/trehemlve Iht of all (troclucti that may cotrtaln mercury. The
*X?omment*"section htcttxle* general information tftat r.tfutfklt on tfv regulatory hrformation.
Pruduct/Usc
Role of Mcrcitry
RegubJlons/l'roKriinij on Mercury Products
Fcil/Sfute '
Ri'jjuliilinn
Comments
Pharmaceuticals
Used in antiseptics, ointments,
diuretics
Misbrandcd drug luws - list quantity of mercury in
product
Yellow mercuric oxide is not gcnernlly recognized as safe
and effective, or is misbrandcd for over the counter use
IL, IN, NY,
OH. PA
Federal

Poison*

Restrictions on sale of mercury nnd mercury compounds
poisons
Oil
PA

Catalysts
Hg used as catalysts for production
of vinyl chloride monomers und
iirclluiiie fiuimx. as well ii.i other
product*



Packaging

Kcstrictions on mercury content in packaging nnd
packaging components; no products may lie sold in
packaging that contains intentionally introduced llg
IL, MN, NY,
Wl
Implementation dulcs vary by state, und include
general exceptions if no feasible alternatives exist;
Pennsylvania is considering bill to regulate toxic
mutcriuls in puckuging
Special Paper
Dialings
Mercury bromide nnd mercury acetic
ocid used in specialized paper and
lilm with cathode rny tubes


Manufacturers plan to phase out use of mercury ill
coating
Explosives
Mercury fulminate is detonator
Kxplosives containing mercury are Class A, maximum
hazards
MN. Wl
In the Inst 20 yeurs, only the military has used
mercury explosives
Fireworks
Catalyst/explosive
Permits required lor fireworks with mercury
Ml

Livestock and Poultry
Remedies

List percentage uf mercury on remedy
Ml

A Associate* Etrvlrunrnettlnl ('utnulling, Ltil.
rage 2 of 7
Afl,'JlC9'4O7.XLS-/ir0tt re#*

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Virtual l'!liininalion I'ilol I'inject
Kuurret und Rt^ubllitni
Appendix C: Regulations on Products that Contain Mercury
Mj/c: 7 hi t tah/e highlights regulation* tfutt affect tlur ««»/ common mercury-containing /rot/itfu, // it not a contfirrhttnire litf of aft product* ifuit may contain niemrry. The
tTommrHlt" xtc tion iitchttlts genemi ittfonnniion tfutt r.Tj»ro)rfa on the regulatory information
Pruriuct/Usc
Role of Mercury
: Rc|»iil;itioiis/Programjt on Mcrcwry Vrotlucts :
' Pcil/Stiltc
Rcgiiiniion
Comments
Electrical nnd Electronic Uses
Electric Lighting



Electric lighting products are second largest
component of municipul solid waste (after batteries)
Fluorescent Lamps
(low pressure)
Mercury vapor fluoresces al UV
wavelength
Encouraged as rcplucemcnt for incandescent bulbs for
energy conservation (see 10CFR450.3I - energy
conservation measures)
Lamps in slutc-owned buildings must be recycled
Federal
MN
Fluorescent lights arc lurgest component of electric
lighting discurds in municipal solid wusle; used
bulbs considered hazardous waste bccuusc high
levels of mercury exceed RCRA toxicity
characteristic limit (.2 mg/1 in Icuclintc)


Viewed ns by-produet that cun be reeyclcd, und exempt
from RCRA
Lamps sold to managers of industrial, commerciul, office,
or multiunit buildings must be labeled; building
contractors must specify mercury munugemcnt pluns
for removed lumps
Oil
MN
EPA considering two options to ease KCRA
disposal restrictions: (1) inclusion in universal waste
rule to facilitate recycling; (2) conditional exemption,
which would bIIow disposal in solid waste landfills
Mercury Vapor
Lump*
Facilitates light production by
electric nrc
Encouraged for energy conservation (see I0CFR450.31
- energy conservation measures)
Lamps must be self-extinguishing or huvc protective
shield; efficiency standard* in public areas (theaters, gyms)
Mercury must be removed before disposul; lump sellers
nnd contractors responsible for public education about
mercury management requirements; limits on
production und distribution of lamps
Federal
NY
MN

High Intensity
Lamps

Lamps sold to mnnugers of industrial, commercial.
olYiccs, or multiunit buildings must be labeled; building
contractors must specify mercury management plans
for removed lumps
MN
Used for outdoor lighting; mercury lamps are more
efficient and brighter than other outdoor lights
Kau A A lloc lairs Etirironmertlnl Cnnvilling. Ltd.
I'ngt J nfl



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Virtual Kliiiiinntioit iVojcul
Mtixtii7 Sources hii<1 Kcciilullniit
Appendix C: Regulations on Products (hat Contain Mercury
Sole: Thlt table highlight* regulation* thai affect the mo.M common mercury-containing ffrodiiclt, ft h not a comftreltennl¥t Iht of nil /»w/iict! that may contain mercury. The
'Vonimenti" section Includes general htformathn that expand* on the regulatory biformtttfon
; Product/Use'
I Role of Mercury
Regulations/Programs on Mercury Products
Fcij/Stiilc
Regulation
Comments /"
Metal llallde
l.ainpi


Federal
Encouraged lor energy conservation (sec IOCFIl<
- energy conservation measures)
Incandescent
Lamp Filaments
llg used as continuous electrical
contact in tungsten bar sintering



Wiring Devices and Switches
Thermostats
Temperature measurement
Mercury must be removed for recycling or recovery
before disposal; manufacturers must provide
information and incentives tu ensure recycling or
proper manngement; hcuting, venliloting and
oir-condilioning (IIVAC) dealers required to properly
ninnuge or recycle used mercury thermostats (MN St
II5A.93, 11SA.95AI. 115.932)
Products c(iiil:iining 1 Ig must be lubclcd, including
disposul restrictions
MN
MN
Digilul thermostats are replacing mercury
tlicnnostiits; long lug time before old 1 Ig
thermostats discarded
MN just began pilot program for 1IVAC dealers !¦
recycle mercury contuining tlicrmostuts by return!
them to IIVAC wholesaler who. in turn, returns
tlicin In Honeywell lor recycling/reclaiming
White Gmidj
Mercury components (e.g.,
switches) may be included in Inrge
appliances (e.g., refrigerutors, air
conditioners, etc.)
Mercury components must be removed prior to
disposul
l lg in repuired or replaced items must be reused or
recycled
MN. IL
MN

Toys

Ran on toys with llg; fines imposed Tor retail stiles
MN. Wl

Electric
Wall Switches

Products containing 1 Ig must be lubclcd, including
disposal restrictions
MN

Rott <( A.imclaie.i fanrtronmental Conuilting. Ltd.
Page 4 of 7
MKKC940 7.A7-y-/«nx/ ergf

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Virliinl Kliininntion Pilot Project
MriTiirj Smiirta unit Urgiilnlliuis
Appendix C: Regulations on Products that Contain Mercury
Note: This table highJight.t regutafbru that affect the mo.if common ntercury-cotttahun\* //rwfnctr. U f.r not a cvin/rrhewivr Hit of at! ftroduc It that may contain mercury. The
"Cummetiti" section /ttcJitrffi genernt information tfotf e.ytands on t/te regulatory Information.
: Pnujuct/Usc
Role of Mercury
^cgtilatfons/Prtignims on Mercury Products =
Fcit/Sfntc
- Regulation
Comments
Klrctiical
Components
Mny lie included in tiny electricnl
machinery (e.g.. mining, automotive,
und induslrinl equipment, smoke
detectors, etc.)
Limits on mercury use in mining equipment
Products ciintuiuing mercury must be labelled, including
disposul restrictions
PA
MN

Batteries
Central Mercury
Containing Batteries

Butteries included in universal waste rule lo cose UCRA
restriction* on hazardous wuste management and divert
wuste from MSW landfills; vtules may set up spcciul
collection progruins not .subject lu storage,
transportation, and permitting requirements ofllCRA
Deposit/refund system will begin in 1998: purchasers
return used mercury batteries to retailer or approved
collection facility
Tusk lurcu on storage, transport, disposal, recycling
Ml
II,
Galleries were Inrgest source of llg in municipal solid
waste. Many stules have banned mercury in
butteries', momifuclwcrs have reduced mercury use
by nvcr 90V. since I98R.
EPA is requesting comments on lubcling butteries lo
nid ill collection, sorting, and recycling; denied a
petition filed under §TSCA to require deposit on
mercuiy-conloining batteries.
Industry groups have developed uniform voluntary
industry lubcling stundards for lead and cadmium
batteries
Alkaline llnttciies
Prevents corrosion mid hydrogen
release, extends shelf life; improves
performance over temperature range
(batteries used in flashlights, radios,
and other electronics)
1 Ig concentrations <.025°/. by weight
1 Ig banned in ulkuline batteries in 1996
MN. NY
MN.WI
MN
Duller)' inmiiifuctiircrv Ikivc eliminated mercury in
ulkuline batteries, except button cells and reusable
butteries.
Hott A Axxociate* Etrrirvttmentctl (.'rmrultin^, Ltd
Page S of 7
AOCf1CV4Q7,XLS*it*wt

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Viilmil Flimifwttiim Pilot Projccl
MfiTur^ Som-cri und Krguluiioni
Appendix C: Regulations on Products that Contain Mercury
Mifr: Thii table highlight* regulatiom that affect the nui.xt common mercitry-corrlainlrrg jwtxJucLi. It it ml a comjwrhemirr li.ti of (ill frotlucli that may contain mercury, llie
^Comment*" xecfhn Include* general Information that e.xpanlt on the regulatory Information
| Product/Usc :;
i
Role of Mercury
RcguljiJions/Progriims on Mercury Products
Fctl/Sfiilc
ftiguliition :
Comments
Mercuric Oxide
Batteries (alio
liiillon cell,
merctiry-iinc
button cell)
Mercury used as cathode motcriul
and is integral component (button
cell batteries contain -40% mercury)
Sale of dry cell bnllerics with mercuric oxide, electrode
batteries prohibited without exemption; button cell
nonrcchurgcahlc butteries restricted to <25mg 1 Ig;
labeling requirements; disposal prohibited;
manufacturer* responsible lor collection system
1 Ig content of alkaline button cell batteries must be <25
mg by weight
MN
NY
Primarily used in hearing aids; also used in
calculators, watches, cameras, photographic
equipment, electronic gnmcs, hcaltli/liospitiil
equipment, uirplane underwater locator beacons
NY is exploring recycling options for these b:itteri
Sonic mercuric oxide cells used in military and
medical operations (e.g., night vision devices, l:K'
machines, etc.) are disposed of as hazardous wasli
Proposed federal legislulion may ban mercuric ox!
batteries.
Carbon Zinc
(1/cClanchc)
Contain -l*/» llg; llg controls
chemical reactions between zinc and
other buttery components
Sale prohibited if llg concentration >lppm
Sale of batteries with 1 Ig banned after 1994
NY
Wl
Curbon zinc cells have shorter life tliun alkaline
batteries. Mercury is no longer used in certain ziii
buttery products.
Zinc Air
llg content - 1%
Million colls restricted In * 25 mg mercury, labelling
MN
Used in pagers, hearing aids
Instruments nnd Related Products
Mi'iixure timf Control lnxlrumenf.%
Thermometers
Elemental mercury indicates
temperature
Limits on distribution of 1 Ig thermometers; mercury
must be removed before disposal; no routine distribution
of 1 Ig thermometers by medical facilities
MN
Digital thermometers are replacing mercury
thermometers
Barometers
Indicates pressure



Medical, Scientific
Instruments
Temperature and pressure measuring
devices
Products w/1 Ig must be labeled, including disposal
restrictions
MN

/fo.u AtsoclaltJ Etirirvnmttitrtl Contulllng, Ltd.
Page 6 of 1

MERC9-I0 7..XLS-prod rrgi

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Virlunl I'tiiniiiolion Pilol Project
Mfixiity Simirrt mihI ItrgnlutliMi*
Appendix C: Regulations oil Products that Contain Mercury
Note: Thh table highlights regulation* that affect the nunt common mercury-containing prtxlucts. It it not a comftrehemiee list of all products that may contain mercury. The
"Comments"section inchttlex central information tluit exfHtmh on tlte regulatory information
¦ Product/Use
Role or Mercury
UcBul.'itions/l'rournms on Mercury Products
Fcd/Sfutc
:: Kt'gilliitinn
Comments
Dental Equipment and Supplies
Drntul
Equipment/Supplies
Forms alloys; chemically binds
compounds to form restorutivc
material
FDA regulates dental mercury and amalgam alloys
separately as class 1 and class II devices under Fcderul
Food, Drug, and Cosmetic Act
Disposal banned unless mercury reused, recycled or
managed to ensure compliuncc
Federal
MN
One of nation's largest manufacturers of mercury
amalgam dentul lillings will place warnings on
nmulgam containers shipped to California und
provide wurning signs lor dental patient wailing
rooms under California's Proposition 65 (Safe
Drinking Wuler und Toxic F-nlbrccmenl Act).


Purchaser must sign agreement or use Tor medical or
dental uses
MN
The Act requires businesses lliat use or distribute
toxics to lubel or otherwise notify the public ubout
possible exposure to chemicals.
Discontinued Uses
embalming lluid	Preservative
film puck batteries	Use discontinued as of 1988
maritime paints	Antifouling agent	Registrations suspended in 1972	Fedcrul
photographic development
soap
wood preservatives
Rna it Auocinter Enrlronmrnlat Conmlilrtg, Ltd.
Pngt 7 of 7
MF.RC9107XLS-pnxl rrgJ

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Virtual I'liminnlion Pilot Project
Mrrcury Soiirrra mill Krciilufltxi*
Appendix D: Summary of Mcrcury-Specific Statutes in Great Lakes States
State
I tern (s)
NOTE: This table summarizes provisions of statutes that specifically regulate mercury in the Great Lakes States. At
this time, not all states have specific mercury statutes. This table tines nat include state regulations for
implementing federal environmental programs.
Provisions
Batteries
Packaging
White Goods
Task force studied storage, transport, disposal, and recycling
After 7/1/94, no package or packaging component may be sold if it contains mercury above
600ppm; levels decrease to 250ppm (7/1/95), lOOppm (7/1/96)
Mercury must be removed before disposal (landfill operators may have permits to remove Hg
components at landfill)

Bnttcrics


usiat;
Fireworks
Use/release
Pending: Toys,
Shoes, Clothes
MM
Batteries
Lamps
After 1/1/98, deposit refund system to facilitate return of used mercury batteries to distributor or
recycling/disposal contractor
Permits required for Fireworks containing mercury
Water Pollution Control Act- businesses must report use and discharge information for chemicals
on "critical materials registry", which includes mercury
No sale of toys w/Hg
No batteries >.025% Hg by weight may be sold or distributed; after 1/1/96, alkaline manganese
batteries must have no added Hg
Button cell nonrechargeable batteries must have <25mg Hg and must be labeled
Exemption required to sell batteries containing mercuric oxide electrodes
Mercury must be removed before disposal; lamp sellers and contractors responsible for informing
buyer/generator of mercury management requirements
Ross it Associate* Eiivlnitimrnial Consulting, Lid
Page t ol3
STATRSJCLS.OWIl/94

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Vltlinil Kliniiniition Pilot Project
Mr rcnry Sotiirrs unit Itrciilulinui
Appendix D: Summary of Mcrcury-Specific Statutes in Great Lakes States


NOTE: This table summarizes provisions of statutes that specifically regulate mercury in the Great Lakes States. At
this time, not all states have specific mercury statutes. This table does not include state regulations for
implementing federal environmental programs.
State
Itcm(s)
Provisions
MN cont'd
Product Disposal
Disposal banned unless mercury removed (reused or recycled) from items such as thermometers,
thermostats, etc.

Product Servicing
Repair person must ensure proper Hg management when Hg items removed from service

Product Labeling
Thermostats, thermometers, switches, appliances, and medical and scientific instruments must be
labeled to inform purchaser/consumer that mercury must be removed before disposal

Inks, Dyes Paints,
Fungicides
No mercury after 7/1/94

Packaging
No mercury in packaging after 8/1/93 (threshold 600ppm); allowable concentration decreases to
lOOppm in 8/1/95

Toys, Shoes,
Clothes
No sale of toys, clothes, or shoes w/l-Ig

Thermometers
No routine distribution of Hg thermometers in medical facilities

Thermostats
Manufacturers must provide incentives for proper management (Honeywell, a thermostat
manufacturer, implemented a thermostat take-back and recycling program)
NY
Batteries
After 1/1/92, alkaline manganese, batteries must have <0.25mg Hg by weight; alkaline button
batteries must have <25mg Hg; zinc carbon batteries 
-------
Virtual F.timinnlion Pilot Project
Mercury Sources mitl Uceiiliilliiii.t
Appendix D: Summary of Mercury-Spccific Statutes in Great Lakes States
State
Item(s)
NOTE: litis tabic summarizes provisions of statutes that specifically regulate mercury in the Great Lakes States. At
this lime, not all states have specific mercury statutes. This table does not include state regulations for
implementing federal environmental programs.
Provisions
Packaging:	No intentionally introduced mercury in packaging
(pending)

PA

WI
Batteries
Packaging
After 1/1/96, alkaline manganese batteries cannot contain intentionally introduced mercury;
button-shaped alkaline manganese batteries <25mg Hg; after 1/1/94 zinc carbon batteries
cannot contain Hg
No mercury in packaging after 6/1/92 (threshold 600ppm), allowable concentration decreases to
lOOppm 6/1/94
Medical Waste Incinerators with >5 tons/day capacity must be tested once for mercury
Incinerators
Toys
No sale of toys containing Hg
Ron it- Associates Environmental Consulting. Ltd
Page 3 of3
STATESJCLS. 09/11/94

-------
MERCURY BATTERIES
APPENDIX E	(except Button Cells)
Information as of July 31,1994
JURISDICTION
STATUS OF
LEGISLATION
EFFECTIVE
DATE
NOTES
(see separate page
for explanation)
FEDERAL
Pending
1-1-97
1(a)
ARKANSAS
Passed
1-1-94
2(a), 4(a)
CONNECTICUT
Passed
1-1-92
3(a), 4(a), 6(a,b)
FLORIDA
Passed
1-1-94
1(c), 2(b[ii]),
3(a,b,g), 4(a)
IOWA
Passed
7-1-96
1(c), 3(b,c(e),
6(a,b)
MAINE
Passed
1-1-94
2(a,b[i)),
3(b,c,d,e,f), 4(a)
MARYLAND
Passed
7-1-94
l(b,c), 2(b[i]),
3(b,c,d,e,f), 4(a),
6(afb)
MASSACHUSETTS
Pending
??
1(c), 3(b,c),
4(a,b)
MICHIGAN
Passed
Pending
1-1-98
7-1-95
5, 6(a)
3(b,c,h), 4(a,b)
MINNESOTA
Passed
2-1-92
1(b), 3(b,c,d),
4(a), 6(a)
NEW HAMPSHIRE
Passed
1-1-93
(Dept.. has
not yet
issued
rules)
2(a)
NEW JERSEY
Passed
1-20-93
1(c), 2(b[i]),
3(b,c,d,e,f,h),
4 (a)
RHODE ISLAND
Passed
1-1-94
2(a), 3(a,b,c,e),
4(a)
VERMONT
Passed
1-1-93
3(a,b,c,e), 4(a)
WISCONSIN
Passed
7-1-94
1(c), 2(b[ii]),
3(b,cfg), 4(a)
Information in Appendix £ provided by Raymond Balfour, Rayovac Corporation

-------
i: BAN ON SALE OF PRODUCT
(a)	Absolute ban (no exemptions possible).
(b)	Banned generally, but state agency authorized to grant
exemptions (conditioned on: showing of need; collection
requirements; manufacturers responsibilities; etc.)
(c)	Banned only if manufacturer fails to meet collection and
other responsibilities.
2: STATE REGULATORY AGENCIES
(a)	State agency authorized or required to issued regulations
defining collection procedures, responsibilities, etc.
(b)	State statute generally defines collection procedures,
responsibilities, etc.
[i]	Manufacturers must get approval of collection plans
from state agency prior to implementation.
[ii]	Prior approval of implementation plans not required,
but manufacturer must notify state agency of plans.
3S MANUFACTURER RESPONSIBILITIES
(a)	Accept used batteries.
(b)	Identify collection site having necessary treatment and
disposal permits.
(c)	Inform purchasers about:
[i]	Prohibition against disposal in solid, medical
waste.
[ii]	Collection site available to user.
[iii]	Telephone number user can call for more information.
(d)	Pay for consumer (user) education efforts.
(e)	Pay for transportation and disposal of used batteries.
(f)	Get approval of collection plans, etc. from state agency
prior to implementation.
(g)	Notify state agency of collection plans, etc. (approval
not required).
(h)	Manufacturer must submit periodic reports to state agency.
4: USER RESPONSIBILITIES
(a)	Don't dispose of batteries in solid or medical waste.
(b)	Pay for proper disposal.
5: DEPOSITS
(a) $2/battery required at time of sale, unless trade-ins of
used batteries made at that time.
61 OTHER
(a)	Legislation does not distinguish between button cells and
larger sizes of mercury batteries.
(b)	"Retailer," "wholesaler," "supplier," "all participants in
the stream of commerceetc. mentioned in legislation,
may have responsibilities.

-------
APPENDIX E	ALKALINE BATTERIES
STATE
EFFECTIVE.DATE,
250 PPM (0.025%)
MERCURY
EFFECTIVE DATE,
NO-MERCURY
FORMULA
Federal (pending)
	
1-1-96 (mfg. date)
Arkansas
	
1-1-96 (mfg. date)
California
1-1-94 (mfg. date)
1-1-96 (mfg. date)
Connecticut
1-1-92 (mfg. date)
—
Florida
7-1-93 (sale date)
1-1-96 (sale date, rtl.)
Iowa
7-1-93 (sale date)
1-1-96 (sale date, rtl.)
Maine
1-1-94 (sale date)
1-1-96 (mfg. date)
Massachusetts (pending)
	
1-1-95 (sale date, rtl.)
Michigan (pending)
	'
7-1-95 (sale date, mfg.)
Minnesota
2-1-92 (sale date, mfg.)
1-1-96 (sale date, mfg.)
New Hampshire
1-1-93 (mfg. date)
1-1-96 (sale date, mfg.)
New Jersey
1-1-92 (mfg. date)
1-1-96 (mfg. date)
New York
1-1-92 (mfg. date)
—
Oregon
1-1-92 (mfg. date)
—
Rhode Island
1-1-92 (mfg. date)
—
Vermont
2-1-92 (mfg. date)
1-1-96 (sale date, rtl.)
Wisconsin
	
1-1-96 (mfg. date)
NOTES:
1.	Information as of August 18, 1994.
2.	State laws banning the sale of alkaline batteries containing more
than allowable mercury content may be either of two types:
Effective date refers to manufacture. Batteries made prior to
the effective date may be sold after the effective date, even if
they exceed allowable mercury content. ("Mfg. date")
Effective date refers to sale. Batteries containing more than
allowable mercury content may not be sold, regardless of when
manufactured. But the legislation may refer either to the date
of sale by the battery manufacturer ("sale date, mfg.") or by the
retailer ("sale date, rtl.").
3. Mercury limitations do not apply to alkaline button cells.

-------
APPENDIX E
ZINC CARBON BATTERIES
ir'?-* STATE "
EFFECTIVE DATE,
; NO-MERCURY FORMULA
Federal (pending)
1-1-95 (mfg. date)
Arkansas
1-1-94 (mfg. date)
California
1-1-94 (mfg. date)
Connecticut
1-1-93 (mfg. date)
Florida
1-1-96 (sale date)
Maine
1-1-93 (sale date)
Michigan (pending)
1-1-95 (mfg. date)
New Hampshire
1-1-93 (mfg. date)
New Jersey
1-1-92 (mfg. date)
New York
1-1-93 (mfg. date)
Wisconsin
7-1-94 (mfg. date)
NOTES:
1.	Information as of August 18, 1994.
2.	State laws banning the sale of zinc carbon batteries
containing more than allowable mercury content may be
either of two types:
Effective date refers to manufacture. Batteries made
prior to the effective date may be sold after the
effective date, even if they exceed allowable mercury
content. ("Mfg. date")
Effective date refers to retail sales. Batteries
containing more than allowable mercury content may not
be sold at retail, regardless of when manufactured.
("Sale date")

-------
APPENDIX E CONSUMER MERCURY BUTTON CELL BATTERIES
Information as of July 31, 1994


EFFECTIVE DATE

JURISDICTION
STATUS OF
LEGISLATION
BAN
COLLECTION
NOTE(S)
FEDERAL
Pending
1-1-95
—
—
ARKANSAS
Passed
1-1-94
—
—
CALIFORNIA
Passed
1-1-94
—
—
CONNECTICUT
Passed
—
1-1-92
2(a), (b)
FLORIDA
Passed
10-1-93
—
—
IOWA
Passed
—
7-1-96
1, 2(a)
MAINE
Passed
1-1-93
—
—
MARYLAND
Passed
—
7-1-94
1
MASSACHUSETTS
Pending

—
—
MICHIGAN
Passed
—
1-1-98
3

Pending
7-1-95
—
—
MINNESOTA
Passed
2-1-92
—
—
NEW HAMPSHIRE
Passed
—
1-1-93
2(b)
NEW JERSEY
Passed
1-1-94
—
—
RHODE ISLAND
Passed
1-1-93
—
—
VERMONT
Passed
1-1-93
—
—
Note 1: Battery manufacturers financially responsible for collection,
transportation, disposal, consumer education, etc. Failure to meet these
requirements results in a sales ban for the manufacturer's mercury button
cells.
Note 2: Battery manufacturer not expressly responsible, but:
(a)	Retailer required to collect;
(b)	State regulatory agency to issue regulations.
Note 3: $2/battery'required at time of sale, unless trade-ins of used
batteries made at that time.

-------
Virtual Elimination Pilot Project
Mercury Sources and Regulations
Appendix F: Data on Mercury Releases
Appendix F contains information on mercury releases available from several federal and state
reporting systems. Federal and state agencies collect information on mercury releases as part
of broader programs designed to meet reporting requirements for multiple substances. It is
important to keep in mind that each data set must be interpreted separately due to differences
in reporting requirements and the types of information collected.
All data is organized by Standard Industrial Classification codes (SIC codes). This structure
offers a uniform method to identify industrial sectors. The first two digits of an SIC code
identify major, industrial sectors. The full four digit code allows more specific identification
of industry type. Even with this detailed breakdown, variation exists within a given SIC code.
For a complete list and description of SIC codes, as well as the specific industrial processes
covered by each code, refer to the Standard Industrial Classification Manual.
By using SIC codes, it is possible, on a broad scale, to identify the types of industrial sectors
where mercury releases occur most frequently. However, particularly for air emissions data,
the link to SIC code may be misleading. For example, any facility that maintains a coal-fired
boiler on site may generate mercury releases that are independent of a specific industrial
process that uses mercury.
Appendix F includes mercury release information from six specific data sources. The list
below indicates the specific components of Appendix F. The first page of each set of data
includes an explanation of the reporting program and the data reviewed.
App. F1 Summary of Reporting Information: The table shows, by SIC code, the
frequency with which mercury releases appear in each data set reviewed for this
analysis. It is organized by SIC code and by state.
App. F2 Toxic Chemical Release Inventory (TRI) data: TRJ data for 1992 and 1991.
F2a = 1992 data for Great Lakes states only
F2b = 1991 data for Great Lakes states only
F2c = 1992 national mercury data
F2d = 1991 national mercury data
Ross <4 Associates Environmental Consulting. Ltd. 9/12/94

-------
Virtual Elimination Pilot Project
Mercury Sources and Regulations
App. F3 RCRA Biennial Report System (BRS) data: 1991 BRS data for mercury-
bearing waste codes.
F3a = Summary of facilities reporting mercury-bearing wastes in each
SIC code
F3b = Summary of source processes that generate mercury-bearing
wastes
App. F4 Permit Compliance System (PCS) data: PCS data for the Great Lakes basin
(facilities located in the Great Lakes basin only; not necessarily statewide)
F4a = July 1992 - June 1993 data
F4b = July 1991 - June 1992 data
App. F5 Wisconsin Air Point Source data: Mercury air emissions data collected for
Wisconsin's Clean Air Act Title V Operating Permit Program (reported data).
App. F6 Michigan Critical Materials Registry: 1991 data collected under Michigan's
wastewater reporting program. Data indicates the number of facilities reporting
mercury use.
App. F7 Indiana AIRs data: Air emissions derived from data reported on criteria
pollutants. This is not measured data. Instead, it represents estimated mercury
releases based on emissions factor calculations.
Ross & Associates Environmental Consulting. Ltd. 9/12/94

-------
Appendix Fl: Summary of Mercury Reporting Data
H of Fatilillw Reporting Mercury Releases
SIC SIC
Category Code

Tola


IL
IN
Ml
MN
NY
OH
PA
Wl
S
00
g
PCS
VI
CC
CO
TRI
PCS
BRS
s
2
3
£
m
B
PCS
5
a
to
M
e
PCS
1
&
u
CL
22
CO
P
PCS
BRS
E
PCS
i
s
r-»
PCS
*
7 Agricultural SmicM
723 Crop Pn.'pawiion Services
1


















1









10 Melai Mining
tOll IronOies
5













5














1021 Copper Ores


\









I
1















1031 Metal Mining Services













1















M Nonroelj!IirMii)(rilj( fxcept fuels
1422 Ciusheti And Broken limestone
1








1
1


















15 General Building Contractors
1542 Noniesitlcnlial Construction See
1









1


















17 Special Irade contractors, NEC
1799 Special TradeContractors, Nec
1


















1









NOTE; Tliis lablc compares Ihe number nf facilities in each SfC code lh;it report mercury releases under the did'crenl federal reporting programs discussed in this report.
In addition. Ilirce Crcal I .ulrcs Mules collect state-specilic information on mercury refuses, wliicli is ul?o cflptured in lliis table. live Jala is the most current available for cadi program.
Tliis tahk illustrates how the nmnhrr of facilities reporting mercury releases varies based on the reporting requirements and thresholds oreach repotting program.
More detailed data sets Per each program oreprovided following Ihis summary'ab]e.
* BUS data for New York and Wisconsin are not included in this total due to technical difficulties in obtaining the data. Additional information may be provided at the September meeting.
Ohio data did not include waste origin codes, and therefore may include remediation wastes as well as ongoing process wastes.
KEV: TRJ = Toxic Chemical Release Inventory, 1992 data
BRS = RCRA Diennial Report System, 1991 data
PCS =¦ Fermit Compliance System, July 1992 - June 19M dala
IV =¦ A.'RS Inventory, 19'JC data
MT = Mlchigun Ciilical Materials Wastewater Report, 1991 Jatu
Wl - Wisconsin Title V Operating Permits Program, 19?I data
SUMMEDCXLS1 nl II
OW11194

-------
Appendix F1: Summary of Mercury Reporting Data
# or Facilities Reporting Mercury Releases

Total
IL
IN
Ml
MN
NY
OH
PA
WI
SIC SIC
Category Code
3
m
M
e
PCS
2
CO
TRJ
PCS
2
m
S
PCS
5
BRS
i
PCS
s
g
m
i
PCS
£
c/i
a
2
CD
s
to
kl
2
m
8
PCS
BRS
E
PCS
20 Food and Kindred Products
2011 Meal Parking Plants









I



2














2013 Sausages and Other Prepared Meat




























Products




























2020 Dairy Products













3














2022 Cheese, Natural And Processed
1


1
























2023 Dry, Condensed, Evaporated Products
1









1

















2033 Canned Fruits and Vegetables









l


















2037 Frozen Fruits, Fruit Juices, and Vegetabl




























2035 Pickles, Sauces, And Salad Dressings
1


1
























2043 Cereal Breakfast Foods













2














2046 Wet Corn Milling









i


















2048 Prepared Feeds, NEC









i


















2063 Beet Sugar


1









1
4














2075 Soybean Oil Mills









l


















2077 Animal and marine fats and oils









i



1














2082 M.ill Beverages









i


















2085 Distilled and Blended Liquors









i


















2087 Flavoring Extracts And Syrups, Nirc
1


















1








2092 Fre>h Or Fro/en Prepared fish
1





















1





2099 Food Preparations, Nec
1


1





l


















22 Textile Mill Products
2295 Coated Fabrics
1


















1








2299 Textile Goods, Nec
1





















1





24 Lumber and Wood Products
2431 Millwork
2













2













2434 Wood Kitchen Cabinets









3


















2435 Hardwood Veneer and Plywood









2


















2491 Wood Preserving
1


















1








2493 Not Listed




























SUMMCRC XLS 3 of 13
09/11/94

-------
Appendix Fl: Summary of Mercury Reporting Data
' H of Futilities Reporting Mercury Releases
SIC SIC
Citegory Code
Total
IL
IN
Ml
MN
NY
OH
PA
W|
BRS"
g
PCS

-------
Appendix F1: Summary of Mercury Reporting Data
0 of Fucilidci Reporting Mercury Releases

Total
IL
IN
Ml
MN
NY
OH
PA
WI
SIC SIC
Category Code
3
03
TRI
PCS
BRS
TRI
PCS
E2
CO
TRI
PCS
5
BRS
nu
PCS
£
a
CO
TRI
PCS
TRI
PCS
2
to
TRI
PCS
3
CO
TRI |
PCS
BRS
TRI
PCS |
- 2820 Plastics Materials and Synthetics













2














2821 Plastics Materials And Resins
21
1
2
4
1

1



3


1




1
7

1
6





2822 Synthetic Rulilier
1

1





1










1








2830 Drugs













It)














2833 Mudii in.its And Bol.inic.iU
(,





4


i












2





2834 Pharmaceutical Preparations
28


5


7


3
2


1





2


12





2835 Diagnostic Substances
2





2





















2841 Soap And Other Detergents
3


1















2








2842 Polishes And Sanitation Goods
2


















1


1





2843 Surface Active Agents
2


2
























2844 Toilet Pre|>aralions
1













1













2850 Paints and Allied Products













5














2851 Paints And Allied Products
15





1



3


1





8


3





2860 Industrial Organic Chemicals













2














2865 Cyclic Crudes And Intermediates
1


















1








2868 Not Listed
1


















1








2869 Industrial Organic Chemicals, Nee
20

3
4


1


1
3



1



3
7


4





2875 Fertilizers, Mixing Only
1


















1








2879 Agricultural Chemicals, Nec
1


















1








2890 Miscellaneous Chemical Products













1














2891 Adhcsives And Sejlants
4












1





4








2899 Chemical Prejwrations, Nec
11









3


1





6


2





29 Petroleum and Coal Products
2900 PHiolrum jml C«'.il Products













1














2911 Petioleum Refining
5
1




1






1
1
1






3





2951 Asphalt Paving Mixtures and Blocks




























2992 Lubricating Oils And Creases
3


1















2








2999 Petroleum And Coal Products, Nec
1


















1








30 Rubber and Miscellaneous Plastic Products
3011 Tires And Inner Tubes
3


1















2








3069 Fabricated Rubber Products, Nec
3









1


3





1


1





3079













2








i




SIIMMERCXIJJnfll
09/11/94

-------
Appendix F!: Summary of Mercury Reporting Data
1 of Facilities Reporting Mercury Release!
SIC SIC
C«(ec«iy Cflde
Total
IL | IN | Ml
MN
NY | OH
PA
Wl
B
m
B
VI
&
2
00
TRI
PCS 1
£
CO
t
vt
u
a.
s
2
to
g
vs
k
¦e.
2
00
I
VI
£
B
£
£
GO
g
2
2
DO
B
a
2
ta
i
2
%
3080 Miscellaneous Plastics ProducH, NEC












16















3081 Unsupported Plaslics, Film And Sheet
1








i












1






3086 Plastics, Foam Products
J





















t





3087 Custom Compound Purchased Resins

I


















1








3089 -PLisiirs Products, Ncr
3


I









1





2









31 Leather and leather Products
3111 Leather Tanning and Finishing













1















32 Slone, Car, and Glass Products
32H Flal Glass
t


















1








3220 Glass and Glassware, Pressed or Blown













1















3229 Pressed And Blown Glass, Nec
1





















1






323' Products Of Purchased Glass
1









1


















3241 Cement, Hydraulic
2








2
1








1









3251 Brick and Structural Clay Tile









1



















325S Cl.iy Ri'ImUijim".
1


















1









326'9 Pottery Pnxkicts, N£C








1



















32^2 Corcrete Products, NEC









1



















H274 Lire
r








1 |


















4
J29I Alnjcs
2





1















1






3317 Steel Pipe And Tulics
3


















2


1






¦ 3320 Iron and Steel Foundries













1















3321 Gray And Ductile Won foundries
4


1






1


2





1


1






3322 Mallealil^ Irnn Foundries
1









1


1















3330 Primary NonteimusMetals













1















3331 Primary Coppe'
1






,

'



















-------
Appendix Fl: Summary of Mercury Reporting Data
# of Facilities Reporting Mercury Releases

Total
IL
IN
Ml
MN
NY
OH
PA
WI
SIC SIC
Category Code
¦
ITRI
PCS
BRS
TRI
PCS
BRS
B
PCS .
5
BRS
P
PCS
2
BRS
B
PCS
B
PCS
BRS
B
PCS
BRS
B
V)
u
g
TRI
I
.3334 Primary Aluminum
1

1















1



1





3339 Noi Listed

1





















1




3340 Secondary Nonferrous Metals













i














3341 Secondary Nonlrrrous Met.ils

1







I







1










3353 Aluminum Sheet, Plate, AniJ Foil
3


1















1


1





3354 Aluminum Extruded Products
1





1





















3356 Nonferrous Rolling And Drawing, Nec
4









1








2


1





3360 Nonferrous Foundries (Casings)













i














3361 Not Listed
1













1













3365 Aluminum Foundries













i














3366 Copper Foundries













i














34 Fabricated Metal Products
3400 Fabricated Metal Products













2














3411 Metal Cans
1


1
























3412 Metal Barrels, Drums, And Pails
1


















1








3429 Hardware, Nec
2





1















1





3441 Fabricated Structural Metal
1












1





1








3443 Fabricated Plate Work (Boiler Shops)
1








l












1





3446 Ar< liiln lut.il Mcl.il Work
1





















1





3449 Miscellaneous Metjl Work
1












1








1





3452 Bolts, Nuts, Rivets, And Washers
1





















1





3456 Not Listed
1









1

















3462 Iron and Steel Forgings













1














3465 Automotive Stampings
7









2


5





4


1





3470 Metal Services, NEC













1














3471 Plating And Polishing
5
1
2
1





I

1
1
5





3


1





3479 Metal Coaling And Allied Services
1





1






4














3482 Small Arms Ammunition
4


3










1













3483 Ammunition, Except For Small Arms, N
2


















2








3489 Ordnance And Accessories, Nec
2


1










1













3490 Misc. Fabricated Metal Products













4














3494 Valves And Pipe Fillings, Nec
1





















1





3496 Miscellaneous Fabricated Wire Product
1





















1






-------
Appendix FI: Summary of Mercury Reporting Data
ft nf Facilities Reporting Mercury Releases

Total
IL
IN
Ml
MN
NY
OH
PA
W|
SIC SIC
Category Cnde
g
m
2
to
u
Q.

U
IL
S
2
CO
g
l/l
(J
QL
3

OS
ca
E
V)
(J
0*
i
1/5
U
a.
2
DO
s
H
V)
a.
2
CQ
s
H
(/)
U
a.
2
CO
6
U3
U
a
5
3499 Fabricated Metal Products, Nee
8


1






1


i
1




4


1






35 Industrial Machinery and Equipment
3510 Engines ami Turbines













4















3519 Internal Combustion Engines, Ncc
1








i
1

















i
3523 Farm Mdf.hinery Antt Equipment
1


1
























i
3531 Construction Machinery
2


2
























i
3535 Conveyors And Conveying Equipment
1





















1






3540 Metalworking Machinery













1















3541 Machine Tonls, Mi_'ta1 Cutting Tyfces









i



















3545 Machine Tool Accessories
1





















1






3548 Welding Apparatus
1


















1









3560 General Industrial Machinery













2















3562 Ball and Roller Bearings





























3563 Air And Cas Compressors
1


















1









3569 General Industrial Machinery, NEC









i



















3571 Electronic Cnmpulers
2













1







1






3585 Refrigi-ratiiin And Hejling Equipment
3


















3








2
3S99 Industrial Machinery, Nee
1









I


















36 Electronic and Other Electronic Equipment
3612 Transformers, Except Electronic
2





1


i












1






3613 Switchgear And Switchboard Apparatus
1





















1






3621 Motors Arid Generators
3





1












1


1






3624 Carbon And Graphite Products
1


















1









3630 Household Appliances













1















3632 Household Refrigerators And Free/ers
7





2


l



















3633 Household Laundry Equipment
1


















I









3641 Electric Lamps
3


















3









3645 Residential Lighting Fixtures
]





















1






3647 Vehicular Lighting Equipment
1
I







i









1
1








3663 Radio And Tv Communication Equipm
3





2







1














3665 Not listofl
2


















2









3669 Commiinirations Equipment, Nor.
2


'


















1






SUMMER*: XLS 1 i*f 12
09.11/94

-------
Appendix Fl: Summary of Mercury Reporting Data
0 of Facilities Reporting Mercury Releases

Total
IL
IN
Ml
MN
NY
OH
PA
WI
SIC SIC
Category Code
g
CO
TRI
PCS
BRS
TRI
PCS
S
OQ
S
PCS
5
BRS
£
m*
PCS
5
2
09
2
PCS
2
PCS
BRS
B
PCS
BRS
B
PCS
BRS
B
IPCS 1
3670 Not Lined














i
1













3671 Electron Tubes























1





3672 Printed Circuit Boards















1













3674 Semiconductors And Related Devices
6





















6





3678 Electronic Connectors
1





















1





3679 Electronic Components
6
3

2
1

2
2














2





3691 Storage Batteries









l



i














3692 Primary Batteries, Dry And Wet
5
1




2












3






1

3694 Engine Electrical Equipment








i


















3695 Magnetic And Optical Recording Medij
2













1




1








3699 Electrical Equipment And Supplies, Ner
1


















1








37 Transportation Equipment
3700 Transportation Equipment













i














3710 Motor Vehicles and Equipment













4














3711 Motor Vehicles And Car Bodies
10

1
1


1



4


X





4

1






3713 Truck And Bus Bodies
1


















1








3714 Motor Vehicle Parts And Accessories
17

1



1


7
10

1
18





4


2





3720 Aircraft and Parts













2














3721 Aircraft
1


1
























3724 Aircraft Engines And Engine Parts
3








1









3








3728 Aircraft Parts And Equipment, Nec
2













1




1








3731 Ship Building And Repairing
1





















1





3743 Railroad Equipment
3


1


















2





3769 Space Vehicle Equipment, Nec
1





















1





3790 Miscellaneous Transportation Equipme













1














38 Instruments and Related Products
3812 Search And Navigation Equipment
2


1


1






1













3820 Measuring and Controlling Devices













2














3821 Laboratory Apparatus and Furniture













1














3822 Environmental Controls
3





1







1




1








3823 Process Control Instruments
2





















2





3824 Fluid Meiers And Counting Devices
1





















1





SUMMER*' XLS 8oH2
09/(1/94

-------
Appendix Fl: Summary of Mercury Reporting Data
# of Facilities Reporting Mercury Releases
SIC SIC
Cntejjnry Code

Tota


IL

IN
Ml
MN
NY
OH
PA
WI
S
09
g
(/)
u
a,
2
CO
TRI
PCS
£
co
S
i/i
(J
a.
s
2
CO
PS
(A
O
a.
§
2
m
s
H
1/1
u
a.
B
U
a.
2
CO
S
i/i
u
a.
t/J
06
ffl
i
1/1
k!
BRS
g
V)
U

3826 Analytical Instruments
1









1


















3829 Measuring And Controlling Devices, N
2


















1


1






3840 Medical Instruments and Supplies













i















3841 Surgical And Medicjl Instruments
1





1






















3842 Surgical Appliances And Supplies
2





1















1






3843 Dental Equipment and Supplies

1









1

i















3845 Electromedical Equipment
1













1














Photographic Eqtiip A Supplios-
3861 Instruments & Related Products
1





















1






39 Miscellaneous Manufacturing Industries
3953 Marking Devices
1


1

























3996 Hard Surface Floor Coverings, Nec
2





















2






3999 Manufacturing Industries, Nec
2

1







1



1



1









i
40 Railroad Transportation
4011 Railroads, Line-Haul Operating
3


















1


2






41 local and Interurban Passenger Transit
4111 local And Suburban Transit
1





















1






4173 Bus Terminal And Service Facilities
1


















1









42 T rucking and Warehousing
4200 Trucking and Warehousing













i















4213 Trucking, Except Local
1


















1









4225 General Warehousing And Storage
3





1















2






4226 Spocial Warehousing And Slnr.igo, Ner
2


2

























45 Transportation by Air
4511 Nol Listed
1













1














4512 Air Transpurtation, Scheduled
2













2














4581 Airports, Flying Fields, And Services
1


1

























46 Pipelines, Except Natural Gas
4613 Refined Petroleum Pipelines
2













1




1









3UMMERC XLS 9 of 12
09/11/94

-------
Appendix FI: Summary of Mercury Reporting Data
0 of Futilities Reporting Mercury Releases

Total
IL
IN
Ml
MN
NY
OH
PA
W1
SIC SIC
Category Code
2
to
t

-------
Appendix F1: Summary of Mercury Reporting Data
tt uf Facilities Reporting Mercury Releases
SIC SIC
Category Code

ratal


IL
IN
Ml
MN
NY
OH
PA
WI
BRS*
e
i/)
u
Q*
BRS
TRI
PCS
2
ta
e
t/>
u
a.
5
2
CO
g
t/>
U
a.
s

06
CO
s
(/)
o
e
o
2
GO
E
Ui
U
Cu
2
m

V)
U
Q»
2
CO
B
«/»
u
0.

7389 Business Services, Nec
2


















2









7391 Noticed
1












3





1









75 Automotive Repair, Services, and Parking
7538 General Automotive Repair Shops
2


1


1






















76 Miscellaneous Repair Services
7699 Repjir Services, Nec
3


1









1
1







1






80 Health Services
8011 Offices And Clinics Of Medical Doctors
1


1

























8021 Offices And Clinics Of Dentists





























8050 Nursing and Personal Care Facilities













1















8060 Hospitals













19















8061 Hospitals









4



















8062 General Medical And Surgical Hospital
16


5


1



2








3


5






8063 Psychiatric Hospitals









5



















8070 Medical and Denial Laboratories













4















8071 Medical Laboratories
1


















1









8093 Specially Outpatient Clinics, NEC













8















82 Educational Services
8211 Elementary And Secondary Schools
5


1















4









8221 Colleges And Universities
35


5


5


9
4



2




13


6





3
8249 Vocational Schools, NEC









1



















83 Social Services
8361 Residential Care









2



















84 Museums, Art Galleries, & Botanical & Zoos
8422 Botanical And Zoological Gardens
1


1

























87 Engineering and Management Services
8711 Engineering Services
1


1

























8730 Research and Testing Services













12















8731 Commercial Physical Research
15


3


1



2


1
1




4


4






8732 Commerc ial Nonphysiral Research
1





















1






SUMMERCXLS II of 12
09/11/94

-------
Appendix Fl: Summary of Mercury Reporting Data
H of Facilities Re-purling Mercury Rclcaici
SIC SIC
Cttejjnry Code
Total
IL
IN
Ml
MN
NY
OH
PA
Wl
2
eo
g
PCS
2
00
TRI
PCS
BRS
S
PCS
5
BRS
S
PCS
£
BRS
S
PCS
B
PCS
BRS
B
PCS
i2
n
i
PCS
a
ca
S
[PCS |
0733 Noncommercial Research Organization
3


1









i
1







1





8734 Testing Laboratories
12


5


1






2
1




1


4





8741 Management Services













1














8744 Facilities Sii|>|>orl Services













1














91 Executive, legislative, and General
9199 General Government, Nee
3


1















1


1





92 lustice. Public Order, and Safely
9223 Correctional Institutions









2


















94 Administration of Human Resource Programs
9451 Administration Of Veterans' Affairs
1


1
























95 Environmental Quality, and Housing
9511 Air, Wjter, And Solid Waste Managerm
5

1















1
3


2





96 Administration of Economic Programs
9661 Space Rosiurch And Technology
2


















2








97 National Security and International Affairs
9711 National Security
9

1
2


2


2








1
4


1





99 Nondassifiablc Establishments
9999 Nonclassifialile Establishment
8


3


1



1








1


2





Grand Total
572
14
1-10
94
2
1
50
2
to
120
65
2
40
273
38
1
1
1
27
181
2
49
144
3


1
1
St/MMERC XI.3 IJ of IJ
IIWII/V4

-------
Appendix F2a tri mercury data, the eight cheat lakes states
(ka/yr)
REPORTING TEARI 1992
CREAT
LAKES


ROLE OF
SOURCE REOUCTION
NONPT
POINT





TOTAL
BASIN
STATE
siccooe
FACILITY NAHE
MERCURY
ACTIVITIES t ID METHODS
AtR
, AIR
250
WATER
UNDRGRND
LAW)
ptrrw
OFFS1TE
RELEASES
T
PA
2619
MAILINCKROOT SPECIALTY
1A1C102A
NA
250
0
0
0
s
1020
1525
n
PA
2619 3S59
BETHLEHEM APPARATUS CO. INC.
1A1B1C1D2D
U52T04 U58T04
20
0
0
0
0
s
3
28
*
IL
2621
GE CHEMICALS INC.
2B
U42T02111NA NA
0
0
0
0
0
0
0
0
N
NN
2911
KOCH REFINING CO.
1A1E1F3C
V52T01104T05
S
100
0
0
0
0
23
128
T
OH
3087
PMS CONSOLIDATED
2B

180
2
0
0
0
0
1079
1261
N
PA
3339 3341
ZINC CORP. OF AMERICA
1A1F
NA
0
14
0
0
0
0
168280
168294
N
NY
3341
MERCURY REFINING CO. INC.
1A1C1D2D
NA
250
5
5
0
5
0
5
270
T
Ml
3471
ELM METAL FINISHING USA
2C
NA
5
0
0
0
0
5
10
20
T
OH
3641
CE CO.
2C3C
NA
500
1060
0
0
0
0
1954
3514
N
IL
3679
HOMEYUELL INC.
2C
NA
0
4
0
0
0
0
S342
5346
T
IN
3679
HERMASEAL CO.
2C
NA
0
0
0
0
0
0
0
0
r
IN
3679
DURAKOQL INC.
2C
NA
5
0
0
0
0
5
0
10
N
Ul
3692
RAYOVAC CORP.
2B

0
0
0
0
0
0
b
0
r
HI
3643
KERR MFG. CO.
20
NA
0
0
0
0
0
0
5650
5650
ROLE OF MERCURY AHO ITS USES AT THE FACILITY
SOURCE REDUCTION ACTIVITIES
HETHOOS USED TO ID SOURCE REOUCTION ACTIVITIES
1	¦ Manufacture the toxic chemical
A ¦ Produce
8 ¦ [sport
C ¦ For on-site use/processing
2	¦ Process the toxic chenlcal
A ¦ As a reactant
B ¦ At I formulation component
3	¦ Otherwise use the toxic cheeilcal
A ¦ As a chemical processing aid
¦ ¦ As a manufacturing aid
C • Ancillary or other use
D ¦ For sale/distribution
E ¦ At ¦ byproduct
F ¦ As an I «pur'ty
C • Aa an article component
D ¦ Repackaging
Ut3 ¦ Inproved maintenance scheduling,
recordkeeping, or procedures
U19 • Other changes In operating practices
W36 ¦ Inplemnted inspection or nonftorIng
program of potential spill or leak sources
W42 ¦ Substituted rati Materials
U52 ¦ Modified equipment, layout or piping
1/58 ¦ Other process modification*
U82 ¦ Modified design or conpoiltlon of product
T01 » Internal Pollution Prey. Opportunity Audi
T02 ¦ External Pollution Prev. Opportunity Audi
103 ¦ Materials Balance Audits
TO* ¦ Participative Team Manage—nt
TOS ¦ Esployee Recoonendatlon (Independent of I
foraal coapany prograa)
T10 ¦ Vendor Assistance
Til • Other
Source: Toxic Chenlcal Release Inventory, data downloaded June 21, 1996

-------
Appendix F2b TRI HERCURr DATA. THE EIGHT CHEAT LAKES STATES

-------
Appendix F2c
1992 NATIONWIDE TRI MERCURY DATA (KG/TR)
ROLE OF
fAC1LI1Y NAME
STATE
SIC CODE
MERCURY
NONPT AIR
POINT AIR
MATER
UNDGRND
IANP
0
POTU
0
OFFSITE
TOTAL
12110
GEOSCIA-PACIFIC CORP.
UA
2611 2621
3A
1000
2S0
2S0
0
10610
OCCIDENTAL CHEMICAL CORP.
AL
2812
3A
176
1
33
0
0
0
2286
2496
OCCIDENTAL CHEMICAL CORP.
DE
2812 NA
3A
430
40
15
0
0
0
4916
5421
LCP CHEMICALS
GA
2812
3A
1000
380
38
0
0
0
81
1499
OLIN CORP.
GA
2812 2819
3A
1046
271
12
0
0
0
5933
7262
IF GOOORICH
KY
2812 2821
3A
0
391
35
0
0
0
12902
13328
POINEER CHLOR ALKALI CO. INC.
LA
2812 NA
3A
0
1286
18
0
0
0
15229
16533
PPG 1ND. INC.
LA
2812 2816
3A
1100
160
24
0
0
0
327
1611
DOW CHEMICAL CO.
LA
2812 2821
2A3C
0
130
0
0
0
0
0
130
LCP CHEMICALS
ME
28t2 2819
3A
743
13
4
0
1
0
1358
2118
LCP CHEMICALS
NC
2812 2819
3A
1046
49
4
0
0
0
326
1425
OLIN CORP.
TN
2812 NA
3A
104$
180
17
0
3111
0
743
1985
OCCIDENTAL CHEMICAL CORP.
TX
2812 2869
3A
1000
40
4
0
0
0
6130
7174
NANLIN CHEMICALS
UV
2812 2819
20
0
0
28
0
0
0
69
97
PPC INO. INC.
WV
2812 2819
3A
1045
85
33
0
0
0
250
1413
BORDEN CHEMICALS I PLASTICS
LA
2813 2821
1B1C3A
0
0
14
9
0
0
1450
1473
BETHLEHEM APPARATUS CO. INC.
PA
2819 3559
1A1B1C1D20
20
0
0
0
0
5
3
28
MALL1NCKR0DT SPECIALTY
PA
2819 NA
1A1C1D2A
250
250
0
0
0
3
1020
1525
CE CHEMICALS INC.
IL
2821 NA
2B
0
0
0
0
0
0
0
0
CE CHEMICALS INC.
UV
2821 NA
2B
0
1
29
0
17
0
2400
2430
COSAN CHEMICAL CORP.
NJ
2869 28r?
2A
(6
1
0
0
0
1
738
786
TEXACO REFINING t MARKETING
CA
2911 NA
1A1F
0
96
0
0
0
0
0
96
KOCH REFINING CO.
MN
2911
1A1E1F3C
5
100
0
0
0
0
23
128
COOPER TIRE 1 RUBBER CO.
AR
3069 3061
2A2C
S
5
0
0
0
0
4000
4010
PMS CONSOLIDATED
OH
3087 NA
2B
180
2
0
0
0
0
1079
1261
ZINC CORP. OF AMERICA
PA
3339 3341
1A1F
0
14
0
0
0
0
168280
168294
ROLE OF MERCURY AND ITS USES AT THE FACILITY
1	¦ Manufacture the toxic chemical
A ¦ Produce
B ¦ laport
C ¦ For on-alte use/processing
2	¦ Process the toxic chemical
A ¦ Aa a reactant
B « As a formulation conponent
D ¦ For aale/dlstrlbutlon
E ¦ Aa a byproduct
F ¦ Aa en lapurlty
C ¦ Aa an article component
D ¦ Repackaging
3 ¦ Otherwlae use the toxic chemical
A • Aa a chemical proceeding aid
B ¦ As a itanufacturlng aid
C ¦ Ancillary or other use
Source: toxic Chemical Release Inventory, data downloaded March 28, 1994
Page 1 of 2

-------
1992 NATIONUIDE TRI MERCURY DMA (KC/TR)
ROLE OF
FACILITY NAME
STATE
SIC CODE
MERCURY
NOMPT AIR
POINT AIR
water
s
UNDGRND
lANQ
POTU
OFFSITE
TOTAL
265
MERCURY REFINING CO. INC.
NY
3341

1A1C1D2D
250
5
0
5
0
5
ELM METAL FINISHING USA
Ml
3471
NA
2C
3
0
0
0
0
5
10
20
(X CO.
OH
3641
NA
2C3C
500
1060
0
0
0
0
1954
3514
HONEYUELL INC.
IL
3679
NA
2C
0
4
0
0
0
0
5342
5346
DURAKOOL INC.
IN
3679
NA
2C
5
0
0
0
0
5
0
10
HERMASEAL CO.
IN
3679

2C
0
0
0
0
0
0
0
0
ALEXANDER MFG. CO.
IA
3692
NA
1B1C2B
1
1
0
0
0
1
250
253
EVEREADY BATTERY CO. INC.
VT
3692
NA
2C
1
1
0
0
0
0
37056
37058
RAYOVAC CORP.
Ul
3692

2B
0
0
0
0
0
0
0
0
KERR MFG. CO.
Ml
3843

20
0
0
0
0
0
0
5650
5650
NASA
MS
9661
NA
1B1C2C3C
5
0
0
0
0
0
0
5
Total Nuifcer of Facilities: 37
TOTALS
10904
4816
563
3134
22
290440 306754
60.65 X (186,046) of Total Release* and Transfers of Mercury cane from Creat Lakes State*
ROLE OF MERCURY AND ITS USES AT THE FACILITY
1	¦ Manufacture the toxic cheatcal
A * Produce
B • l«*»rt
C ¦ For on-site use/processing
2	¦ Process the toxic chemical
A ¦ As a reactant
B ¦ As a formulation cwponent
D • For sole/distribution
E ¦ As a byproduct
F ¦ As an Inpurlty
C ¦ As an article confionent
D ¦ Repackaging
3 ¦ Otherwise use the toxic chemical
A ¦ As a chemical processing aid
1 ¦ As * nnufacturlng aid
C ¦ Ancillary or other use
Source: Toxic Chemical Release Inventory, data downloaded March 28, 1994
Page 2 of

-------
Appendix F2d
1791 NATIONUIDE TRI MERCURY DATA 
-------
1991 NATIOMJIDE TRI MERCURY DATA (KG/YR)



ROLE OF








FACILITY NAME
STATE
SIC COOE
MERCURY
AIR NONPT
AIR POINT
WATER
25
UNDGRND
LAND
pom
OFFSITE
TOTAL
2428
CE CHEMICALS INC.
W
2821 NA
2B
1
0
0
2
0
2400
AMERICAN CYANAMIO CO.
N J
2833 2869
3A
0
0
0
0
0
6
16287
16293
KELLY-MOORE PAINT CO. INC.
CA
2851 NA
2B
0
0
0
0
0
0
5
5
TROY CHEMICAL CORP.
NJ
2851 NA
1B10
0
0
0
0
0
0
0
0
COSAN CHEMICAL CORP.
NJ
2869 2879
2A
46
1
0
0
0
1
260
308
HULS AMERICA INC.
NJ
2869 2851
IBID
0
0
0
0
0
0
3241
3241
TEXACO REFINING 1 MARKETING
CA
2911
1A1F
0
96
0
0
0
0
0
96
KOCH REFINING CO.
MN
2911 NA
1A1F
3
120
0
0
0
0
1
124
VALERO REFINING CO.
TX
2911 NA
1B1F3A
0
0
1
0
0
0
3
4
PPG INDUSTRIES INC.
UV
2912 2819
3A
1000
85
60
0
0
0
1800
2945
CROSSVILIE RUBBER PRODUCTS
TN
3069
2B
0
499
0
0
0
10
0
509
PMS CONSOLIDATED
OH
3087 NA
2B
49
1
0
0
0
0
296
346
CHATAS GLASS CO.
NJ
3231
38
0
0
0
0
0
0
0
0
ZINC CORP. OF AMERICA
PA
3333 3341
1A1F
0
250
0
0
0
0
0
250
MERCURY REFINING CO. INC.
NY
3341
1A1C1D2D
5
5
5
0
0
0
5.
20
MERCURY REFINING CO. INC.
NY
3341
1A1C1020
250
5
5
0
0
0
5
265
ELM PLATING CO.
Ml
3471 NA
2C
5
0
0
0
0
5
5
15
GE CO.
OH
3641 NA
2C3C
500
1780
0
0
2750
0
13450
18480
HONEYUELL INC.
IL
3679
2C
0
4
0
0
0
0
7234
7238
DURAKOOL INC.
IN
3679
2C2D
5
0
0
0
0
5
0
10
HERMASEAL CO.
IN
3679
20
5
0
0
0
0
0
0
5
ALEXANDER MFG. CO.
IA
3692
1B1C2B
0
0
0
0
0
0
250
250
DURACELL USA
SC
3692 NA
2B
0
15
0
0
0
0
372
387
EVEREADY BATTERY CO. INC.
VT
3692 NA
2C
1
1
0
0
0
0
11
13
ROLE OF MERCURY ANO ITS USES AT THE FACILITY
1	¦ Manufacture the toxic chemical
A ¦ Produce
I ¦ liport
C ¦ For on-site use/processing
2	¦ Process the toxic chemical
A * As a reactant
B ¦ As a formulation conponent
D ¦ For sale/dlstrlbutlon
E ¦ As a byproduct
F ¦ As an Ispurlty
C ¦ As an article component
D "Repackaging
3 ¦ Otherwise use the toxic chemical
A ¦ As a chemical processing aid
B ¦ As a Manufacturing aid
C ¦ Ancillary or other use
Source: Toxic Chemical Release Inventory, data downloaded April 21, 1993
Page 2 of 3

-------
1991 NATIONWIDE TRI MERCURY DATA (KG/YR)



ROLE OF








FACILITY NAME
STATE
tic COOE
MERCURY
AIR NONPT
AIR POINT
WATER
UNDGRND
LAND
POTV
OFFSITE
TOTAL
RAYOVAC CORP. .
Ul
3692
2B
0
0
0
0
26
0
26
52
KERR MANUFACTURING CO.
Ml
3843
20
0
0
0
0
0
0
2000
2000
NASA
MS
9661 NA
3C
5
0
0
0
0
0
0
5
NASA
MS
9661 NA
3C
250
0
0
0
5
0
250
505
Total Nwfcer of Facilities:
52*

TOTALS
12162
7B30
671
9
5320
64
171392
1970S





llltllll

iisanai
¦IMIISI


¦
s
¦
¦
¦
¦
18.13 X (35,795 kg/yr) of Total Release* and Transfers of Mercury came frcai Great Lakes State*
•TRI Information My be edited after It Is originally reported. The 1991 reporting year data shown In this table reflect a TRI download perfornd nearly concurrently
with the TRI Information published In April 1993, with one exception. One Great lakes facility that had reported Mercury releases In this version of TRI was no longer
included In a later version of TRI. To maintain consistency with 1991 TRI Mercury data pulled specifically for the Great Lakes atatea (downloaded 6/21/94), that facility
was removed (rem this table.
ROLE OF MERCURY AND ITS USES AT THE FACILITY
1	¦ Manufacture the toxic chemical
A ¦ Produce
B ¦ Inport
C ¦ For on-site use/processing
2	¦ Process the toxic chemical
A ¦ As a reactent
B ¦ As a fomilatlon component
D ¦ For sale/distribution
E ¦ As a byproduct
F ¦ As an Inpurlty
C ¦ As an article conponent
D ° Repackaging
3 ¦ Otherwise use the toxic chemical
A ¦ As a chemical processing aid
B ¦ As a manufacturing aid
C • Ancillary or other use
Source: Toxic Chemical Release Inventory, data downloaded April 21, 1993
Page 3 of 3

-------
Appendix F3a: Facilities Reporting Mercury-Bearing Wastes in RCRA Biennial
Report System
SIC
SIC

# of Facilities Reporting


Category
Code
IL
IN
MI
MN
OH
PA
Total
7
Agricultural Services








723 Crop Preparation Services For Market
0
0
0
0
1
0
1
10
Metal Mining








1011 Iron Ores
0
0
0
5
0
0
5
14
Nonmetallic Minerals, Except Fuels








1422 Crushed And Broken Limestone
0
0
1
0
0
0
1
15
General Building Contractors








1542 Nonresidential Construction. Nec
0
0
1
0
0
0
1
17
Special trade contractors, NEC








1799 Special Trade Contractors. Nec
0
0
0
0
1
0
1
20
Food and kindred Products








2022 Cheese. Natural And Processed
1
0
0
0
0
0
1

2023 Dry. Condensed. Exaporatcd Products
0
0
1
0
0
0
1

2035 Pickles, Sauces. And Salad Dressings
1
0
0
0
0
0
1

2087 Flavoring Extracts And Syrups, Nec
0
0
0
0
1
0
1

2092 Fresh Or Frozen Prepared Fish
0
0
0
0
0
1
1

2099 Food Preparations. Nec
1
0
0
0
0
0
1
22
Textile Mill Products








2295 Coated Fabrics
0
0
0
0
1
0
1

2299 Textile Goods. Nec
0
0
0
0
0
1
1
24
Lumber and Wood Products








2431 Milwork
0
0
0
2
0
0
2

2491 Wood Preserving
0
0
0
0
1
0
1
25
Furniture and Fixtures








2522 Office Furniture. Except Wood
0
0
1
0
0
0
1
NOTE: This table shows, by the SIC code of the generating facility, the number of generators that reported
hazardous mercury-bearing waste streams for the 1991 reporting year, the most recent year for which data is widely
available. Large Quantity Generators (LQGs) and permitted Treatment. Storage, and Disposal facilities (TSDs) are
required to report on waste generation and management activities biannually. although some states require more
frequent reporting or have lower generation thresholds that trigger reporting requirements. Most states manage this
data through the Biennial Reporting System (BRS) or Biennial-Report compatible data systems. Mercurv-bcaring
wastes include the following waste codes: D009 (characteristic for mercury ). UI51 (discarded product). K071
(chlor alkali process waste). K106 (chlor-alkali process waste), P092 (phenybucrcuric acetate), and P065 (mercury
fulminate). This table includes only data for waste of recurrent origin: that is. waste generated as a result of
ongoing production or services processes. Data for waste streams of other waste origins (remediation-derived waste
hazardous residuals resulting from the treatment of other waste streams, and waste not generated originally at the
reporting facility) are not included. Ohio does not col lea waste origin information, and as a result, any hazardous
mercury-bearing remediation waste, treatment residuals, or wastes passing through Transfer/Storage facilities may
be included in Ohio data. Wisconsin and New York data are not included due to technical delays in obtaining the
data.
Ross & Associates Em'ironmentaJ Co/iiuliing. Lid
TOTALS? .M. J-
Oft'l I >94

-------
nepon system
SIC
SIC


U of Facilities Reporting


Category
Code

IL
IN
MI
MN
OH
PA
Total
26
Paper and Allied Products








2621
Paper Mills
0
0
1
0
1
1
3

264]
Not Listed
0
0
0
1
0
0
1

2657
Folding Papcrboard Boxes
0
0
0
0
1
0
1

2679
Convened Paper Products. Nec
0
0
0
0
1
0
1
27
Printing and Publishing








2731
Book Publishing
0
0
0
1
0
0
1

2754
Commercial Printing. Gravure
0
0
0
0
1
1
2

2759
Commercial Printing. Nec
1
0
0
0
0
1
2
28
Chemicals and Allied Products








2812
Alkalies And Chlorine
0
0
0
0
1
0
1

2816
Inorganic Pigments
1
0
0
0
1
0
2

2819
Industrial Inorganic Chemicals. Nec
2
0
1
0
4
5
12

2821
Plastics Materials And Resins
4
1
3
0
7
6
21

2822
Synthetic Rubber
0
0
0
0
1
0
1

2833
Medicinals And Botanicals
0
4
0
0
0
2


2834
Pharmaceutical Preparations
5
7
2
0
2
12
28

2835
Diagnostic Substances
0
2
0
0
0
0
2

2841
Soap And Other Detergents
1
0
0
0
2
0


2842
Polishes And Sasnitation Goods
0
0
0
0
1
1


2843
Surface Active Agents
2
0
0
0
0
0
2

2844
Toilet Preparations
0
0
0
1
0
0
1

2851
Paints And Allied Products
0
1
3
0
8
3
15

2865
Cyclic Crudes And Intermediates
0
0
0
0
1
0
1

2868
Not Listed
0
0
0
0
1
0
1

2869
Industrial Organic Chemicals. Nec
4
1
3
1
7
4
20

2875
Fertilizers. Mixing Only
0
0
0
0
1
0
1

2879
Agricultural Chemicals. Nec
0
0
0
0
1
0
1

2891
Adhcsives And Sealants
0
0
0
0
4
0
4

2899
Chemical Preparations. Nec
0
0
3
0
6
2
11
29
Petroleum and Coal Products








2911
Petroleum Refining
0
1
0
1
0
3
5

2992
Lubricating Oils And Greases
1
0
0
0
2
0
3

2999
Petroleum And Coal Products. Nec
0
0
0
0
1
0
1
30
Rubber and Miscellaneous Plastic Products








3011
Tires And Inner Tubes -
1
0
0
0
2
0
3

3069
Fabricated Rubber Products, Nec
0
0
1
0
1
1
3

3081
Unsupported Plastics. Film And Sheet
0
0
0
0
0
1
1

3086
Plastics. Foam Products
0
0
0
0
0
1
1

3089
Plastics Products. Nec
1
0
0
0
2
0
3
32
Stone, Clay, and Glass Producls








3211
Flat Glass
0
0
p
0
1
0
1

3229
Pressed And Blown Glass. Nec
0
0
0
0
0
1
1

3231
Products Of Purchased Glass
0
0
1
0
0
0
1

3241
Cement. Hydraulic
0
0
1
0
1
0
2
Ross & Associates Emironn*tilaI Conluhing. Ltd.
TOTALS.VXIS
09/11/54

-------
Appendix F3a: Facilities Reporting Mercury-Bearing Wastes in RCRA Biennial
Report System
SIC SIC	# of Facilities Reporting
Categor>'
Code

IL
IN
Ml
MN
OH
PA
Total

3255
Clay Reiractories
0
0
0
0
1
u
1

3291
Abrasive Products
l
0
0
2
1
0
4

3296
Mineral Wool
0
0
0
0
1
0
1
33
Primary Metal Industries








3312
Blast Furnaces And Steel Mills
0
0
1
0
3
2
6

3316
Cold Finishing Of Steel Shapes
0
1
0
0
0
1
2

3317
Steel Pipe And Tubes
0
0
0
0
2
1
3

3321
Gray And Ductile Iron Foundries
1
0
1
0
1
1
4

3322
Malleable Iron Foundries
0
0
1
0
0
0
1

3331
Primary Copper
0
0
1
0
0
0
1

3334
Priman Aluminum
0
0
0
0
0
1
1

3353
Aluminum Sheet. Plate. And Foil
1
0
0
0
1
1
3

3354
Aluminum Extruded Products
0
1
0
0
0
0
1

3356
NonfcrTous Rolling And Drawing. Nec
0
0
1
0
2
1
4

3361
Not Listed
0
0
0
1
0
0
1
34
Fabricated Metal Products








3411
Metal Cans
1
0
0
0
0
0
1

3412
Metal Barrels. Drums. And Pails
0
0
0
0
1
0
1

3429
Hardware. Nec
0
1
0
0
0
1
2

3441
Fabricated Structural Metal
0
0
0
0
1
0
1

3443
Fabricated Plate Work (Boiler Shops)
0
0
0
0
0
1
1

3446
Architectural Metal Work
0
0
0
0
0
1
1

3449
Miscellaneous Metal Work
0
0
0
0
0
1
1

3452
Bolts. Nuts, Rivets, And Washers
0
0
0
0
0
1
1

3456
Not Listed
0
0
1
0
0
0
1

3465
Automotive Stampings
0
0
2
0
4
1
7

3471
Plating And Polishing
1
0
0
0
3
1
5

3479
Metal Coating And Allied Services
0
1
0
0
0
0
1

3482
Small Arms Ammunition
3
0
0
1
0
0
4

3483
Ammunition. Except For Small Arms.
0
0
0
0 '
2
0
2

3489
Ordnance And Accessories. Nec
1
0
0
1
0
0
2

3494
Valves And Pipe Fittings. Nec
0
0
0
0
0
1
1

3496
Miscellaneous Fabricated Wire Product
0
0
0
0
c
1
1

3499
Fabricated Mcial Products. Nec
1
0
1
1.
4
1
8
35
Industrial Machinery and Equipment








3519
Internal Combustion Engines. Nec
0
0
1
0
0
0
1

3523
Farm Machinery And Equipment
1
0
0
0
0
0
1

3531
Construction Macliinerv
2
0
0
0
0
0
2

3535
Conveyors And Conveying Equipment
0
0
0
0
0
1
1

3545
Machine Tool Accessories
0
0
0
0
0
1
1

3548
Welding Apparatus
0
0
0
0
1
0
1

3563
Air And Gas Compressors
0
0
0
0
1
0
1

3571
Electronic Computers
0
0
0
1
0
1
2

3585
Refrigeration And Heating Equipment
0
0
0
0
3
0
3

3599
Industrial Machinerv. Nec
0
0
1
0
0
0
1
Ross & Associates Ettviromnttuol Cotnul*iit$. Lid.
TOTAL53 XLS
09/U/94

-------
Report System
SIC SIC


# of Facilities Reporting

Category Code

IL
IN
MI
MN
OH
PA Total
36 Electronic and Other Electronic Equipment






3612
Transformers. Except Electronic
0
1
0
0
0
1 2
3613
Switchgcar And Switchboard Apparatu
0
0
0
0
0
1 1
3621
Motors And Generators
0
1
0
0
1
1 3
3624
Carbon And Graphite Products
0
0
0
0
1
0 1
3632
Household Refrigerators And Freezers
0
2
0
0
0
0 2
3633
Household Laundry Equipment
0
0
0
0
1
0 1
3641
Electric Lamps
0
0
0
0
3
0 3
3645
Residential Lighting Fixtures
0
0
0
0
0
1 1
3647
Vehicular Lighting Equipment
0
0
0
0
1
0 1
3663
Radio And Tv Communication Equipm
0
2
0
1
0
0 3
3665
Not Listed
0
0
0
0
2
0 2
3669
Communications Equipment. Nec
1
0
0
0
0
1 2
3670
Not Listed
0
0
0
1
0
0 1
3671
Electron Tubes
0
0
0
0
0
1 1
3672
Printed Circuit Boards
0
0
0
1
0
0 1
3674
Semiconductors And Related Devices
0
0
0
0
0
6 6
3678
Electronic Connectors
0
0
0
0
0
] 1
3670
Electronic Components
2
2
0
0
0
2 6
3692
Primary Batteries. Dry And Wet
0
2
0
0
3
0 5
3695
Magnetic And Optical Recording Medi
0
0
0
1
1
0 2
3699
Electrical Equipment And Supplies. Ne
0
0
0
0
1
0 1
37 Transportation Equipment






3711
Motor Vehicles And Car Bodies
1
1
4
0
4
0 10
3713
Truck And Bus Bodies
0
0
0
0
1
0 1
3714
Motor Vehicle Pans And Accessories
0
1
10
0
4
2 17
3721
Aircraft
1
0
0
0
0
0 1
3724
Aircraft Engines And Engine Parts
0
0
0
0
3
0 3
3728
Aicraft Parts And Equipment. Nec
0
0
0
1
1
0 2
3731
Ship Building And Repairing
0
0
0
0
0
1 1
3743
Railroad Equipment >
1
0
0
0
0
2 3 -
3769
Space Vehicle Equipment. Nec
0
0
0
0
0
1 1
38 Instruments and Related Products






3812
Search And Navigation Equipment
1
1
0
0
0
0 2
3822
Environmental Controls
0
1
0
1
1
0 3
3823
Process Control Instruments
0
0
0
0
0
2 2
3824
Fluid Meters And Counting Devices
0
0
0
0
0
1 1
3826
Analytical Instruments
0
0
1
0
0
0 1
3829
Measuring And Controlling Devices, N
0
0
0
0
1
1 2
3841
Surgical And Medical Instruments
0
1
0
0
0
0 1
3842
Surgical Appliances And Supplies
0
1
0
0
0
1 2
3845
Electromedical Equipment
0
0
0
1
0
0 1
3861
Photographic Equip.& Supplies-lnstru
0
0
0
0
0
1 1
Ross 4 Associates Environmental Coutuhtng. Lid.
TOTALS? .XLS
W/Jl/CJ

-------
Appendix F3a: Facilities Reporting Mercury-Bearing Wastes in RCRA Biennial
Report System
SIC
SIC

# of Facilities Reporting


Category
Code
IL
IN
MI
MN
OH
PA
Total
39
Miscellaneous Manufacturing Industries








3953 Marking Devices
1
0
0
0
0
0
1

3996 Hard Surface Floor Coverings, Nec
0
0
0
0
0
2
2

3999 Manufacturing Industries. Nec
0
0
1
1
0
0
2
40
Railroad Transportation








4011 Railroads. Line-Haul Operating
0
0
0
0
1
2
3
41
Local and Interurban Passenger Transit








4111 Local And Suburban Transit
0
0
0
0
0
1
1

4173 Bus Terminal And Serv ice Facilities
0
0
0
0
1
0
1
42
Trucking and Warehousing








4213 Trucking. Except Local
0
0
0
0
1
0
1

4225 General Warehousing And Storage
0
1
0
0
0
2
3

4226 Special Warehousing And Storage. Nec
2
0
0
0
0
0
1
45
Transportation by Air








4511 Not Lisied
0
0
0
1
0
0
1

4512 Air Transportation. Scheduled
0
0
0
2
0
0
2

4581 Airpons. Flying Fields. And Sen-ices
1
0
0
0
0
0
1
46
Pipelines, Except Nalural Gas








4613 Refined Petroleum Pipelines
0
0
0
1
1
0
1
47
Transportation Services








4789 Transportation Services. Nec
0
0
0
0
0
1
1
48
Communications








4813 Telephone Communications. Except Ra
(1
0
0
0
0
2
2
49
Electric, Gas, and Sanitary Services








4911 Electric Services
5
0
6
0
2
9
22

4952 Sewerage Systems
0
0
0
0
1
0
1

4953 Refuse Svsiems
3
0
0
1
4
0


4959 Sanitarv Scrvics. Nec
0
0
0
0
1
0
1
51
Wholesale Trade - Non-Durable Goods








5122 Drugs. Proprietaries. And Sundries
1
0
0
0
0
0
1

5169 Chemicals And Atlied Products. Nec
2
0
0
0
1
0
3

5171 Petroleum Bulk Stations And Terminal
1
0
0
0
0
0
1

5191 Farm Supplies
0
0
0
0
0
1
1
73
Business Services








7331 Direct Mail Advertising Services
0
0
0
0
0
1
1

7389 Business Services. Nec
0
0
0
0
2
0


7391 Not Listed
0
0
0
0
1
0
1
75
Automotive Repair, Services, and Parking








7538 General Automotive Repair Shops
i
1
0
0
0
0
2
76
Miscellaneous Repair Services








7699 Repair Serv ices, Nec
1
0
0
]
0
1
3
Rou £ Associates Etnironmenlnl Cofitulrirqt, Ltd.
TOTALS* XLS
09/J1/94

-------
Appendix F3a: Facilities Reporting Mercury-Bearing Wastes in RCRA Biennial
Report System
SIC
Category
80
82
84
87
91
94
93
96
97
99
SIC

# of Facilities Reporting


Code
IL
IN
MI
MN
OH
PA
Tota
Health Services







8011 Offices And Clinics Of Medical Doctor
1
0
0
0
0
0
1
8021 Offices And Clinics Of Dentists
0
0
0
0
0
0
0
8062 General Medical And Surgical Hospital
5
1
2
0
3
5
16
8071 Medical Laboratories
0
0
0
0
1
0
1
Educational Services







8211 Elementary And Secondary Schools
1
0
0
0
4
0
5
8221 Colleges And Universities
5
5
4
2
13
6
35
Museums, Art Galleries, & Botanical & Zoological
Gardens





8422 Botanical And Zoological Gardens
1
0
0
0
0
0
1
Engineering and Management Services







8711 Engineering Services
1
0
0
0
0
0
1
8731 Commercial Physical Research
3
1
2
1
4
4
15
8732 Commercial Nonphysical Research
0
0
0
0
0
l
1
8733 Noncommercial Research Organization
1
0
0
1
0
l
3
8734 Testing Laboratories
5
1
0
1
1
4
12
Executive, Legislative, and General







9199 Genral Government, Nec
1
0
0
0
1
l
3
Administration of Human Resource Programs







9451 Administration Of Veterans' Affairs
1
0
0
0
0
0
1
Environmental Quality, and Housing







9511 Air. Water. And Solid Waste Manasem
0
0
0
0
3
2
5
Administration of Economic Programs







9661 Space Research And Technology
0
0
0
0
2
0
2
National Security and International Affairs







9711 National Security
2
2
0
0
4
l
9
Nonclassifiable Establishments







9999 Nonclassifiable Establishment
3
1
1
0
1
2
8
Grand Total
94
50
65
38
181
144
572
Ross A Associates Em-iromncrul Coniulsmg. Lid.
TOTALS*XLS
09/11*4

-------

Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
SIC SIC
Category Code Sic Description
Source
Code
Source Code Description
U of Facilities
Reporting
Source Code
10
Melal Mining
Hill Iron Ores
> >
94
Discard out-of-dlc prods/cheins - 1-Timc & Intermit Processes
Laboratory wastes - Oilier Processes
1
4
14
Mining and Quarrying of Nonmellalic Minerals, Except Fuels
1422 Crushed And Broken Limestone A94 Laboratory wastes - Other Processes
1
15
Building Construction • General Contractors and Operative Builders
1542 Nonresidential Construction. Nee A99 Other - Other Processes
1
20
Food and Kindred Products
2<>22 Cheese. Natural And Processed
A94
Laboratory wastes - Other Processes
1

2(12.1 Dry, Condensed. Exaporatcd Products
A.5 9
A94
Other - l-Tinic& Intermit Processes
Laboratory wastes - Other Processes
1
1

2D35 Pickles. Sauces, And Salad Dressings
A94
Laboratory wastes - Other Processes
1

21)92 Fresh Or Frozen Prepared Fish
A58
Discard ont-of-dtc prods/clicms - l-Timc A Intermit Processes
1

2099 Food Preparations, Ncc
A56
Discontinue use process equip - 1-Time & Intermit Processes
1
22
Textile Mill Products
2299 Textile Goods, Ncc
A59
Oilier - t-Time& Intermit Processes
1
24
Lumber and Wood Products, Except Furniture
24.11 Milwork
A49
A55
Odicr - Processes Not Surface Prep
Filter/Battery replacement - l-Time & Intermit Processes
1
I
25
Furniture and Fixtures
2522 Office Furniture, Except Wood
A58
Discard out-of-dte prods/chctns - I-Time & Intermit Processes
1
NOTE: This table. organized by fncllity SIC Code, shows the specific processes responsible for gcnemling mercury-bearing waste streams, as reported in
1991 BRS data. Facilities supply a source code, describing lite specific process or activity that created the waste, Tor each waste stream genented.
Ohio data did not include source code information, and therefore, Ohio facilities are not included in the totals. Wisconsin and New York data are not
included al present due to technical delays in obtaining the data. Facilities are counted once for each source code they report in connection with mercury-
bearing waste streams, regardless of the number or mcrcury-bcaring waste streams associated with the source process.
A summary page of source codes and total number of facilities reporting each source code is included at the end of this section.
ttoi.t /fMor/nfrt r.iiviroiitnfnta! Conxulfing. [,t
-------

Appendix l
-------
Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
SIC SIC
Category Code
Sic Description
Source
Code
Source Code Description
M of Facilities
Reporting
Source Code


A54
Oil changes - l-Tinic & Intermit Processes
1


A55
Filter/Battery replacement - l-Time& Intermit Processes
1


A5f>
Discontinue use process equip - 1-Tiine & Intermit Processes
2


A57
Discarding olT-spcc material - l-Timc & Intermit Processes
2


A58
Discard oul-of-dlc prods/clicins - l-Timc & Intermit Processes
4


A59
Other - l-Timc & Intermit Processes
1


AC.9
Other - Remediation Derived Waste
1


A89
Other - Pollution Ctrl/Wst Trtnint Processes
1


A 94
Laboratory wastes - Oilier Processes
18


A 99
Other - Other Processes

2 S.I 5
Diagnostic Substances
A37
Spent process liquids removal - Processes Not Surface Prep
1


A58
Discard out-of-dlc prods/clicins - l-Timc & Intermit Processes
1
2841
Soap And Oilier Detergents
A94
Laboratory wastes - Oilier Processes
1
2X42
Polishes And Sasnilalion Goods
A 58
Discard out-of-dlc prods/clicins - l-Timc A Intermit Processes
1
2843
Surface Active Agents
A94
Laboratory wastes - Oilier Processes

2844
Toilet Preparations
A58
Discard out-of-dlc prods/chcms - l-Timc& Intermit Processes
1
2851
Paints And Allied Products
AU9
Clean out process equipment - Cleaning & Dcgrcasing
1


A57
Discarding ofT-spcc material - l-Timc & Intermit Processes
1


A5R
Discard out-of-dlc prods/cltcms - I-Time & Intermit Processes
1


A59
Other - l-Timc & Intermit Processes
1


A94
Laboratory wastes - Oilier Processes

2869
Industrial Organic Chemicals. Ncc
A57
Discarding off-spec material - l-Timc & Intermit Processes
1


A5R
Discard out-of-dtc prods/clicins - l-Time & Intermit Processes
1


A59
Other - l-Timc & Intermit Processes
1


A94
Laboratory wastes - Oilier Processes
10


A99
Other - Oilier Processes
1
2899
Chemical Preparations. Nec
A24
Phospliating - Surface Prep & Finishing
1


A32
Product filtering - Processes Not Surface Prep
1


A57
Discarding off-spcc material - l-Timc & Intermit Processes
1


A94
Laboratory wastes - Other Processes
2
29 Petroleum and Coal Products
2911 Pclrolcimi Refining
AOS Pliysic.il scraping & rciuov.nl - Cleaning & Decreasing	I
A58 Discard out-of-dlc prods/clicins - 1 -Time A Intermit Processes 2
ftin.t if* /4sio
-------
Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)





# of Facilities
SIC
SIC

Source

Reporting
Category Code
Sic Description
Code
Source Code Description
Source Code



A 94
Laboratory wastes - Other Processes
2

2992
Lubricating Oils And Greases
A58
Discard oul-of-dtc prods/chcnis - 1-Tinic & Intermit Processes
1
30
Rubber and Miscellaneous Plastic Products




3011
Tires And Inner Tubes
A58
Discard oiit-oT-dtc prods/chcms - 1-Tiinc & Intermit Processes


3H69
Fabricated Rubber Products. Nee
A53
Cleanup of spill residues - l-Timc & Intermit Processes


3081
Unsupported Plastics. Film And Sheet
A94
Laboratory wastes - Oilier Processes
1

3086
Plastics. Foam Products
A19
Other - Cleaning & Decreasing
1

30X9
Plastics Products. Ncc
A94
Laboratory wastes - Other Processes
1
32
Stone, Clay, and Glass Products




3229
Pressed And Blown Glass. Ncc
A09
A78
Clean out process equipment - Cleaning & Dcgrc.ising
Air pollution Ctrl dev - Pollution Ctrl/NVst Trtmnt Processes
1
1

323 1
Products Of Purchased Glass
A94
Laboratory wastes - Other Processes
1

3241
Cement, Hydraulic
A 56
Discontinue use process equip - l-Timc & Inlcnnit Processes
1

3291
Abrasive Products
A3 7
A94
A99
Spent process liquids removal • Processes Not Surface Prep
Laboratory wastes - Other Processes
Other - Other Processes
1
1
33
Primary Metal Industries




3312
Blast Furnaces And Steel Mills
A58
A59
A69
Discard oul-of-dtc prods/chcms - I-Time & Intermit Processes
Other - 1-Time & Intermit Processes
Other - Remediation Derived Waste
1
1

3316
Cold Finishing Of Steel Shapes
A58
A94
Discard oul-of-dtc prods/chcms - l-Time & Intermit Processes
Laboratory wastes - Other Processes
1
1

3317
Steel Pipe And Tubes
A94
Laboratory wastes - Other Processes
1

3321
Gray And Ductile Iron Foundries
A2I
A57
A58
Painting - Surface Prep & Finishing
Discarding off-spec material - 1-Time & Intermit Processes
Discard out-of-dte prods/chcms - 1-Time & Intermit Processes
1
1
I

3322
Malleable Iron Foundries
A69
Other - Remediation Derived Waste
1

3331
Primary Copper
A94
Laboratory wastes - Oilier Processes
1

3334
Primary Aluminum
A94
Laboratory wastes - Other Processes
1

3353
Aluminum Sheet, Plate. And Foil
A94
Laboratory wastes - Other Processes


3354
Aluminum Extruded Products
A94
A99
Laboratory w.tstcs - Oilier Processes
Other - Other Processes
1
1
Roxs iC Anocinlf* Enritvimn'iitnl ('unutllitij*. f.td
TCJTAISJ v
no/j i

-------
Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
H of Facilities
SIC SIC Source Reporting
Category Code	 Sic Description	Code	Source Code Description	Source Code
3.156
Nonfcrrous Rolling And Drawing. Nec
> >
'-/> —
Other - Cleaning & Dcgrcasing 1
Oilier - 1 -Time & Intermit Processes 1
.1361
Not Listed
AOI
Stripping - Cleaning & Dcgrcasing 1
34 Fabricated Metal Products


3-111
Metal Cans
A5I
Leak collection - 1 -Time & Intcnnil Processes 1
3-129
Hardware. Ncc
A2I
A99
Painting - Surface Prep & Finishing I
Other - Other Processes 1
3443
Fabricated Plate Work (Boiler Shops)
A54
Oil changes - 1 -Time & Intermit Processes 1
3446
Architectural Mclal Work
A(IV
Clean out process equipment - Cleaning & Dcgrcasing 1
3449
Miscellaneous Mclnl Work
A 53
A57
A 59
A91
Cleanup of spill residues - l-Timc A Intcnnil Processes 1
Discarding ofT-spcc material - l-Timc & Intcnnil Processes 1
Oilier - l-Timc& Intermit Processes 1
Clothing & personal protective equipment - Other Processes 1
3452
Bolls. Nuts. Rivets. And Washers
A19
Other • Cleaning A Dcgrcasing 1
3456
Not Listed
A2I
Painting - Surface Prep & Finishing 1
3465
Automotive Stampings
A56
A58
A59
Discontinue use process equip - 1 -Time & Intermit Processes 1
Discard out-of-dtc prods/clicms • l-Timc & Intermit Processes 1
Other - l-Timc & Intcnnil Processes 1
3471
Plnting And Polishing
A22
A94
Electroplating - Surface Prep & Finishing 1
Laboratory wastes - Other Processes 1
3479
Mclnl Coating And Allied Sen ices
AIM
A3 2
Stripping - Cleaning & Dcgrcasing 1
Product filtering - Processes Not Surface Prep 1
.14H2
Small Anns Ammunition
A2I
A53
A58
A79
A92
Painting - Surface Prep & Finishing 1
Cleanup of spill residues - 1 -Time &. Intermit Processes 1
Discard out-of-dtc prods/clicms - l-Timc & Intermit Processes 1
Lcacliatc collection - Pollution Ctrl/Wst Trtmnt Processes 1
Routine clcan-up wastes - Other Processes 1
3489
Ordnance And Accessories. Ncc
A56
A58
Discontinue use process equip - l-Timc & Intermit Processes 1
Discard out-of-dtc prods/clicms - l-Timc & Intcnnil Processes 1
34 94
Valves And Pipe Fillings, Ncc
A58
Discard out-of-dtc prods/clicms - l-Timc & Intcnnil Processes 1
3496
Miscellaneous Fabricated Wire Products
A94
Laboratory wastes - Other Processes 1
3499
Fabricated Metal Products. Ncc
AO 9
A3 5
Clean out process equipment - Cleaning & Dcgrcasing 1
By-product processing - Processes Not Surface Prep 1
flo.it Aunci/itc 1 i'nvironiumtnl (an%n!(iti£, Lid
TOTALS3 *13
00/11/94

-------
Appendix F3I>: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
ft of Facilities
SIC SIC Source Reporting
Category Code	Sic Description	Code	Source Code Description	Source Code
AIM)	Sludge removal - t-Time & Intermit Processes	I
A59	Other-I-Time & Intermit Processes	I
35	Industrial Machinery and Equipment
1519 liitcmnl Combustion Engines. Ncc	A27	Etching - Surface Prep &. Finishing	I
A94	Laboratory wastes - Oilier Processes	I
3523 Farm Machinery And Equipment	A55	Filter/Battery replacement - I -Time A Intermit Processes	1
A94	Laboratory wastes - Other Processes	1
3531 Construction Machinery	A56	Discontinue use process equip - 1 -Time & Intermit Processes	I
		A58	Discard oul-or-dtc prods/chcnis - 1 -Time & Intermit Processes	I
3535 Conveyors And Conveying Equipment	A53	Cleanup or spill residues -1 -Time & Intermit Processes	I
3545 Machine Tool Accessories	A29	Oilier - Surface Prep A Finishing	I
3571 Electronic Computers	A53	Cleanup of spill residues - I -Time & Intermit Processes	I
AfiV	Other - Remediation Derived Waste	I
	359V Industrial Machinery. Ncc	A53	Cleanup of spill residues - I -Time & Intermit Processes	I
36	Electronic and Other Electronic Equipment
3612	Transformers. Except Electronic	A94	Laboratory wastes - Other Processes	2
3613	Swilchgcar And Switchboard Apparatus A40	Metal forming - Processes Not Surface Prep	1
3621 Motors And Generators A58	Discard out-of-dtc prods/chcnis - 1-Time & Intermit Processes	2
3632 Household Refrigerators And Freezers A94	Laboratory wastes - Other Processes	I
A99	Other - Other Processes	I
3645 Residential Lighting Fixtures	A22	Electroplating - Surface Prep & Finishing	1
3663 Radio And Tv Communication Equipment A55	Filter/Battery replacement - l-Time & Intermit Processes	I
A58	Discard out-of-dtc prods/clicms - I-Time & Intermit Processes	2
3669	Communications Equipment. Ncc	A37	Spent process liquids removal - Processes Not Surface Prep	I
A5I	Leak collection - l-Tiine A Intermit Processes	I
A58	Discard out-of-dtc prods/chcnis - 1-Time & Intermit Processes	1
3670	Not Listed	A49	Oilier - Processes Not Surface Prep	I	
3671	Electron Tubes	ASH	Discard out-of-dtc prods/chcnis - l-Titnc & Intermit Processes	I
3672	Printed Circuit Boards A27	Etching - Surface Prep & Finishing	i
3674 Semiconductors And Related Devices AO I	Stripping - Cleaning & Dcgrcasing	1
A56	Discontinue use process equip - 1-Time & Intermit Processes	I
A57	Discarding ofT-spcc material - 1-Time & Intermit Processes	2
A59	Other - 1-Time & Intermit Processes	2
Rntt rC Attocintc* Enviromnrutnt Conxuhinx. Ltd
TOTAI-MXIX
09/1 i/q.t

-------
Appendix F3b: Source Processes that Generate Mercury-Bcnring Wastes (1991 BRS data)
SIC SIC
Category Code
Sic Description
Source
Code
Source Code Description
ft or Facilities
Reporting
Source Code
A94 Laboratory wastes - Oilier Processes
3678 Electronic Connectors
A5X Discard out-of-dlc prods/chcms • I-Time & Intermit Processes
3679 Electronic Components
A09	Clean out process equipment - Cleaning & Degreasiiig
A27	Etching - Surface Prep A Finishing
A54	Oil changes - I-Time & Inlcrmil Processes
A56	Discontinue use process equip - I-Time A Intermit Processes
A57	Discarding off-spcc material - l-Tinic A Intermit Processes
A58	Discard out-or-dte prods/chcms - 1 -Time & Intermit Processes
A92	Routine clean-up wastes - Other Processes
A99	Other - Other Processes
3692 Primary Batteries. Drv And Wet
A55 Filler/Battery replacement - I-Time & Intermit Processes
A94 Laboratory wastes - Oilier Processes
3695 Magnetic And Optical Recording Media
A55 Filter/Battery replacement - I-Time A Intermit Processes
37 Transportation Equipment
3711 Motor Vehicles And Car Bodies
A04	Flush rinsing - Cleaning A Dcgrcasing
AOS	Dip rinsing - Cleaning A Dcgrcasing
A09	Clean out process equipment • Cleaning A Dcgrcasing
A21	Painting - Surface Prep & Finishing
A29	Other - Surface Prep & Finishing
A37	Spent process liquids removal - Processes Not Surface Prep
A51 • Leak collection - l-Timc A Intermit Processes
A54	Oil changes - l-Timc A Intermit Processes
AS6	Discontinue use process equip • l-Timc & Intermit Processes
A57	Discarding olT-spec material - l-Time& Intermit Processes
A58	Discard out-of-dle prods/chems - 1-Tinie A Intermit Processes
AS9	Other - I-Time A Intermit Processes
A72	Metals recovery - Pollution Ctrl/Wst Trtnuit Processes
A94	Laboratory wastes - Oilier Processes
2
3
2
1
2
3714 Motor Vehicle Parts And Accessories
A21	Painting - Surface Prep & Finishing	I
A53	Cleanup of spill residues - l-Timc & Intermit Processes	I
A56	Discontinue use process equip - I-Time A Inlcrmil Processes	2
A57	Discarding off-spec material - I -Time & Intermit Processes	I
A58	Discard out-of-dtc prods/chcms - l-Timc A Intermit Processes	2
/[(».»»rf ,tt\neialrt F.iirimiiiiicnlnl Cmiwlling. I.til
TdrAI-iJ XI
ng/||*<

-------
ik|i|iLiiuiA i ^u. juuai » muijcs tii.i! ocuciaie i\iei cury-Uearing Wastes (lyyi BRS data)
tf of Facilities
SIC SIC Source Reporting
Category Code	Sic Description	Code	Source Code Description	Source Code


A59
Other - 1-Timc & Inlcnuit Processes 1


A 94
Laboratory' wastes - Other Processes 6


A99
Other - Other Processes 1
3721
Aircraft
A65
Underground storage tank cleanup - Remediation Derived Was 1
.1728
AicraH Paris And Equipment. Ncc
AO 1
AI9
Stripping - Cleaning Dcgrcasing 1
Olhcr - Cleaning & Dcgrcasing 1
3731
Ship Building And Repairing
A26
A58
A59
Pickling - Surface Prep & Finishing I
Discard out-or-dtc prods/chcms - l-Timc & Intermit Processes 1
Other - 1-Timc & Intermit Processes I
3743
Rnilrond Equipment
AI9
A2I
A 39
Other - Cleaning & Dcgrcasing 1
Painting - Surface Prep & Finishing 1
Other - 1-Timc & Intermit Processes 1
3769
Spncc Vehicle Equipment. Ncc
A94
Laboratory wastes - Olhcr Processes 1
38 Instruments and Related Products


3812
Search And Nnvigntiou Equipiuent
A55
A57
Filter/Battery replacement - l-Titnc & Intermit Processes 1
Discarding olT-spcc material - 1-Timc & Intermit Processes 1
3X22
Environmental Controls
A53
A58
Cleanup of spill residues - 1-Timc & Inlcnuit Processes 1
Discard oul-of-dtc prods/chcms - 1-Timc & Intermit Processes 1
3824
Fluid Meters And Counting Devices
A56
A59
Discontinue use process equip - 1-Timc & Intermit Processes 1
Oilier - 1-Time & Intermit Processes 1
3823
Process Control Instruments
Al>2
A57
A58
Acid cleaning - Cleaning & Dcgrcasing 1
Discarding off-spec material - 1 -Time & Intermit Processes 1
Discard ont-of-dtc prods/chcms - I-Time & Intermit Processes 1
3826
Analytical liistniments
A94
Laboratory wastes - Olhcr Processes 1
3829
Measuring And Controlling Devices, Nec
A94
Laboratory wastes - Oilier Processes 1
3H4I
Surgical And Medical Instruments
A57
A58
A94
Discarding off-spec material - l-Time & Intermit Processes 1
Discard out-of-dlc prods/chcms - 1-Timc & Intermit Processes 1
Laboratory wastes - Olhcr Processes 1
3842
Surgical Appliances And Supplies
A04
A05
A57
A94
Flush rinsing - Cleaning & Dcgrcasing 1
Dip rinsing - Cleaning & Dcgrcasing 1
Discarding ofT-spcc material - 1-Time & Intermit Processes I
Laboratory wastes - Other Processes 1
Hi mi if- /h.n»cinff t hmirontneiitnl CoHwItinji. I.hi
TntAi^! XI.
iw/11'*

-------
Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
H of Facilities
SIC SIC Source Reporting
Category Code	Sic Description	Code	Source Code Description	Source Code

3845 Electromedical Equipment
A94
Laboratory wastes - Other Processes 1

3861 Photographic Equip.& Supplies-Instrument
A94
Laboratory wastes - Oilier Processes 1
39
Miscellaneous Manufacturing Industries



3953 Marking Devices
A94
Laboratory wastes - Other Processes 1

39% Hnrd Surface Floor Coverings. Ncc
A19
A56
A58
A94
Oilier - Cleaning & Decreasing 1
Discontinue use process equip - 1 -Time & Intermit Processes 1
Discard out-of-dte prods/chems - 1-Tintc & Intermit Processes 1
Laboratory wastes - Other Processes 1

3999 Manufacturing Industries, Ncc
A19
A49
A59
A99
Other - Cleaning & Degrcasing 1
Other - Processes Not Surface Prep 1
Other - 1-Timc &. Intermit Processes 1
Other - Other Processes 1
40
Railroad Transportation



4011 Railroads.'Line-Haul Operating
A2I
A99
Painting - Surface Prep & Finishing 1
Other - Other Processes 1
41
Local & Suburban Transit & Interurban Highway Passenger Transportation

4111 Local And Suburban Transit
AO.l
Caustic (Alkali) cleaning • Cleaning & Degrcasing 1
42
Trucking and Warehousing



4225 General Warehousing And Storage
A57
A58
Discarding olT-spcc material - 1-Timc & Intermit Processes 1
Discard out-of-dte prods/chems - 1 -Time & Intermit Processes 3

4226 Special Warehousing And Storage. Ncc
AII9
A55
A58
A59
Clean out process equipment - Cleaning & Decreasing 1
Filler/Batter)' replacement - 1-Timc & Intermit Processes 1
Discard out-of-dte prods/chems - 1-Timc & Intermit Processes 1
Other - 1-Tinie & Intermit Processes 1
45
Transportation by Air



4511 Not Listed
A55
Filter/Batter)' replacement - l-Time & Intermit Processes 1

4512 Air Transportation. Scheduled
A19
A55
A57
Other - Cleaning & Degrcasing 2
Filter/Batten' replacement - l-Time & Intermit Processes 1
Discarding off-spec material - l-Time & Intermit Processes 1

4581 Airports, Flying Fields. And Sen ices
A55
Filter/Battery replacement - l-Time & Intermit Processes 1
i$ J.nociatc* Fwirnnmentnl CoHuilting. I.ul
TOTALS? XL*
WII/Q1

-------
Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
# of Facilities
SIC SIC Source Reporting
Category Code	Sic Description	Code	Source Code Description	Source Code
46	Pipelines, Except Natural Gas
	4613 Refined Pelrolcum Pipelines	A59	Other - 1-Time A Intermit Processes	1	
47	Transportation Services
4789 Transportation Services. Nee	A58	Discard out-of-dle prods/chems - 1-Time A Intermit Processes	1
48	Communications
4RI3 Telephone Communications. Except Radio A58	Discard out-of-dle prods/chems - 1-Time & Intermit Processes I
	A99	Other - Other Processes	I	
49	Electric, Gas, and Sanitary Services
4911 Electric Services	A02	Acid cleaning - Cleaning A Dcgreasing	1
A55	Fillcr/Baltery replacement - I -Time A Intermit Processes	2
A56	Discontinue use process equip - 1-Time A Intermit Processes	4
A57	Discarding olT-spcc material - I-Time A lntcnnil Processes	.1
A58	Discard out-of-dte prods/chems - 1-Time A Intermit Processes (I
A59	Other -1 -Time A Intermit Processes	I
A94	Laboratory wastes - Other Processes	4
A99	Other - Oilier Processes	1
4953 Refuse Systems	A79	Lcncliatc collection - Pollution Clrl/Wst Trtmnt Processes	i
A94	Laboratory wastes - Oilier Processes 3
	A99	Other - Other Processes	1	
51 Wholesale Trade - Non-Durable Goods
5122 Drugs, Proprietaries. And Sundries	A58	Discard out-of-dle prods/chems - 1-Time A Intermit Processes	I
5169 Chemicals And Allied Products. Nee	A57	Discarding off-spec material - I-Time A lntcnnil Processes	I
A58	Discard out-of-dte prods/chems - I-Time A Intermit Processes 1
5171 Petroleum Bulk Stations And Terminals A92	Routine clean-up wastes - Other Processes I
5191 Farm Supplies A58	Discard out-oT-dte prods/chcms - I-Time A lntcnnil Processes I
	A94	Laboratory wastes - Other Processes 	I	
73 Business Services
	7331 Direct-Mail Advertising Sen ices	A04	Flush rinsing - Cleaning A Degreasing	1	
75 Automotive Repair, Services, and Parking
7538 General Automotive Repair Shops	A55	Filter/Battery replacement - I-Time A Intermit Processes	2
/ton A Anocintei Environmental Consulting, l td.
TOT ALU
09/1

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Appendix F3b: Source Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
# of Facilities
SIC SIC	Source	Reporting
Category Code	Sic Description	Code	Source Code Description	Source Code
76 Miscellaneous Repair Services
7699 Repair Services, Ncc	A04	Flush rinsing - Cleaning & Dcgreasing	I
A22	Elcclroplnting - Surface Prep & Finishing	1
	A56	Disconlinue use process equip - 1-Timc & Intermit Processes	1
80 Health Services
8tMI Offices And Clinics Or Medical Doctors A5R	Discard oiil-of-dlc prods/clicms - I -Time & fntcrniit Processes	1
8021 Offices And Clinics Or Dentists	A')')	Oilier - Other Processes	i
8062 Genernl Medical And Surgical Hospitals A55	Filter/Batter)- replacement - I -Time & Intermit Processes	I
A59	Other-I-Time A. Intermit Processes	2
A75	Wastewater treatment - Pollution Clrl/Wsl Trimiil Processes	I
	A94	Laboratory wastes - Other Processes	 H)
82 Educational Services
8211 Elementary And Secondary Schools	A94	Laboratory wastes - Other Processes	I
8221 Colleges And Universities	A02	Acid cleaning - Cleaning & Decreasing	I
AU3	Caustic (Alkali) cleaning - Cleaning & Dcgrcasing	I
A53	Cleanup of spill residues - I -Time & Intermit Processes	2
A55	Filter/Battery replacement - I-Time & Intermit Processes	3
A57	Discarding ofT-spcc material - I-Time & Intermit Processes	1
A58	Discard out-of-dtc prods/clicms - I-Time & Intermit Processes 3
AGO	Sludge removal - 1-Timc A Intermit Processes	I
A59	Other - 1-Timc & Intermit Processes	2
	A94	Laboratory wastes - Other Processes	16	
84 Museums, Art Galleries, & Botanical & Zoological Gardens
	8422 Botanical And Zoological Gardens	A94	Laboratory wastes - Other Processes	 1	
87 Engineering and Management Services
8711 Engineering Services	A94	Laboratory wastes - Other Processes	I	
8731	Commercial Physical Research	A5I	Leak collection - 1-Timc & Intermit Processes	I
A59	Other - I -Time A Intermit Processes I
	A94	Laboratory wastes - Other Processes	11	
8732	Commercial Nonphysical Research	A94	Laboratory wastes - Oilier Processes	1
8733	Noncommercial Research Organizations A57	Discarding olT-spec material - I-Time & Intermit Processes	I
Ro.li A .l.iwciafei [jn-i/rwrne/i/n! ('ottiulling l.ul
KvrM.sj XLS
tlQ/) 1/01

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Appendix FJb: bource Processes that Generate Mercury-Bearing Wastes (1991 BRS data)
SIC SIC
Category Code Sic Description
Source
Code
Source Code Description
# of Facilities
Reporting
Source Code


A94
Laboratory wastes - Other Processes
2

8734 Testing Laboratories
A94
Laboratory wastes - Other Processes
11
91
Executive, Legislative, and General
9199 Gcnral Govcmmcnl. Ncc
A94
Laboratory wastes - Other Processes
2
94
Administration of Human Resource Programs
9451 Administration Of Veterans' Affairs
A58
Discard out-of-dte prods/chems - l-Time & Intermit Processes
1
95
Administration of Environmental Quality & Housing Programs
9511 Air. Water. And Solid Waste Management A94 Laboratory wastes - Oilier Processes
A99 Other - Other Processes
1
1
97
National Security and International Affairs
9711 National Security
A53
A55
A57
A58
A99
Cleanup of spill residues - l-Time & intermit Processes
Filter/Battery replacement - l-Time & Intermit Processes
Discarding ofT-spec material - I-Time & Intermit Processes
Discard out-of-dtc prods/chems - 1-Timc& Intermit Processes
Other - Other Processes
1
3
1
1
1
99
Nondassifiable Establishments
9999 Nondassifiable Establishment
A37
A55
A5>8
A94
Spent process liquids removal - Processes Not Surface Prep
Filter/Battery replacement - l-Time & Intermit Processes
Discard out-or-dte prods/chems - 1-Timc & Intermit Processes
Laboratory wastes - Other Processes
1
2
1
3
Grand total	485
ffoti A*tocialc\ F.iivirowntntal Contuhin^, Ijd.
TOTALS? XI
og/||/

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Appendix F3b: Summary Data of Source Processes that Generate Mercury-Bearing Wastes
Source Soiii cc Code Description	Sum of # of Facilities
Cmlc					Reporting Source Code
AO I	Stripping - Cleaning ft Decreasing	4
A02	Acid cleaning - Cleaning ft Degreasing	3
A03	Caustic (Alkali) cleaning - Cleaning ft Degreasing	2
A04	Flush rinsing - Cleaning ft Degreasing	4
A05	Dip rinsing - Cleaning & Degreasing	2
A08	Physical scraping ft removal • Cleaning & Degreasing	3
A09	Clcan out process equipment - Cleaning ft Degreasing	7
AI9	Other - Cleaning ft Degreasing	10
A22	Electroplating - Surface Prep ft Finishing	3
A2I	Painting - Surface Prep ft Finishing	9
A24	Phosphating - Surface Prep ft Finishing	I
A26	Pickling - Surface Prep ft Finishing	|
A27	Inching - Surface Prop ft Finishing	3
A29	Other - Surface Prep ft Finishing	2
A32	Product tillering - Processes Not Surface Prep	3
A35	lly-product processing - Processes Not Surface Prep	2
A37	Spent process liquids removal - Processes Not Surface Prep	6
A40	Metal forming - Processes Not Surface Prep	1
A49	Other - Processes Not Surface Prep	5
A51	Leak collection - I-Time ft Intermit Processes	4
A53	Cleanup of spill residues - I -Time ft Intermit Processes	16
A54	Oil changes - I-Tune ft Intermit Processes	5
AS5	l-'ilter/llattery replacement - I-Time ft Intermit Processes	25
AS6	Discontinue use process equip - I -Time ft Intermit Processes	20
A57	Discarding olT-spcc material - I -Time ft Intermit Processes	29
A58	Discard mit-of-dte prods/cliems - I-Time ft Intcnnit Processes	76
A5')	Other - I-lime ft Intermit Processes	30
A6U	Sludge removal - l-Timeft Intcnnit Processes	2
Afi5	t Inderground storage tank cleanup - Remediation Derived Waste	I
A69	Other - Remediation Derived Waste	4
A72	Metals recovery - Pollution CtrlAVst Trtmnt Processes	I
A75	Wastewater treatment - Pollution CtrlAVst Trtmnt Processes	1
A78	Air pollution Ctrl dev - Pollution CtrlAVst Trtmnt Processes	3
A91	Clothing ft personal protective equipment - Other Processes	1
A89	Other-Pollution CtrlAVst Trtinnt Processes	1
A79	l.eachatc collection - Pollution CtrlAVst Trtinnt Processes	2
A92	Routine clean-up wastes - Other Processes	4
A9'l	I .ahoratory wastes - Other Processes	I6X
A99	Other - Other Processes	21
39	«Tolals ft of Source Processes Reported
Root «C Atxociatei F. itvirott mental ('on\ulthi$. I id.
*KCI xu
0*11 * *

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APPENDIX F4a: MERCURY DISCHARGES IN TIIE GREAT LAKES BASIN (PCS DATA)
JULY 1992-JUNE 1993
SIC CODE/SIC NAME
NUMBER of
FACILITIES
TOTAL IIG
DISCHARGES
(kg/yr)
RANGE of
RELEASES
(kg/yr)
10 Metal Mining
1021 Copper ores
20 Food and Kindred Products
2063 Beet Sugar
26 Paper & Allied Products
26 \1 Pulp mills
2621 Paper mills, except building paper
2679 Converted paper and paperboard products, not elsewhere classified
28 Chemicals and Allied Products
2812 Alkalies and chlorine
2819 Industrial inorganic chemicals, not elsewhere classified
2821	Plastics materials and synthetics
2822	Synthetic rubber
2869 Industrial organic chemicals, not elsewhere classified
33 Primary Metal Industries
3312	Blast furnaces and steel mills
3313	Electromelallurgical products
331S Steel wire and related products
3334 Primary aluminum
1
2
I
3
1
2
1
3
2
1
2
i
1.08
0
0
0.08
10.25
0
0.11
0.37
1.49
0
0
0
0
1.08
0
0
0.08
0.01 - 10.17
0
0 - 0.11
0.37
0.03 - 1.46
0
0
0
0
Note: This table shows the numbet of facilities in the Great Lakes basin, by
SIC code, that reported mercury discharges under the Permit Compliance
System (PCS). PCS data approximates point source loads from municipal and
industrial discharges. Information is based on monitoring data supplied by
regulated facilities.
Key:
Number of Facilities — if of facilities reporting
Total Mercury Discharges = total mercury discharges
from all facilities reporting in each SIC code.
Range = range of reported releases from all sources
reporting in each SIC code.
Source: Pcrmil Compliance System

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APPENDIX F4a: MERCURY DISCHARGES IN THE GREAT LAKES BASIN (PCS DATA)
JULY 1992 - JUNE 1993
SIC CODE/SIC NAME	
34 Fabricated Metal Products
3471 Pl.iiing and polishing
37 Transportation Equipment
3711 Motor vehicles and car bodies
3714 Motor vehicle parts and accessories
39 Miscellaneous Manufacturing Industries
3999 Manufacturing industries, not elsewhere classified
49 Electric, Gas and Sanitary Services
4931 Electric and other services combined
4952	Sewerage systems
4953	Refuse systems
Public Administration
9511 Air, water resource and solid waste management
9711 National Security
TOTAL HG	RANGE of
NUMBER or	DISCHARGES	RELEASES
FACILITIES	(kg/yr)	(kg/yr)
2	0.01	0-0.01
1	0	0
1	0	0
1	5.17	5.17
1	0	0
109	451.85	0- 162.21
1	0	0
1	0	0
	1	0	0
TOTALS: 140	470.41	0- 162.21
Source: Permit Compliance Sysiem

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APPENDIX F4b:
MERCURY DISCHARGES IN THE GREAT LAKES BASIN (PCS DATA)
JUNE 1991 - JULY 1992
SIC CODE/SIC NAME
NUMBER of
FACILITIES
TOTAL IIG
DISCHARGES
(kg/yr)
RANGE of
RELEASES
(kg/yr)
10 Metal Mining
1021 Copper ores
24 Lumber & Wood Products
2493 Reconstituted Wood Products
26 Paper & Allied Products
2611 Pulp mills
2621 Paper mills, except building paper
2679 Converted paper and paperboard products, not elsewhere
classified
28 Chemicals and Allied Products
2812 Alkalies and chlorine
2819 Industrial inorganic chemicals, not elsewhere classified
2821	Plastics materials and synthetics
2822	Synthetic rubber
2869 Industrial organic chemicals, not elsewhere classified
2879 Agricultural chemicals, not elsewhere classified
33 Primary Metal Industries
3312	Blast furnaces and steel mills
3313	Eleclrometallurgical products
33IS Steel wire and related products
3334 Primary aluminum
2
2
I
3
1
2
I
3
1
1
1
2
1
0.68
0.04
0.45
0.03
12.75
0.15
1.60
3.96
32.69
0
0
0.02
0
0.02
0.68
0-0.04
0.17 -0.28
0.03
0.03 - 12.63
0.15
0.21 - 1.39
3.96
0.09 - 23.82
0
0
0.02
0
0.02
Note: This table shows the number of facilities in the Great Lakes basin,
by SIC code, that reported mercury discharges under the Permit
Compliance System (PCS). PCS data approximates point source loads
from municipal and industrial discharges. Information is based on
monitoring data supplied by regulated facilities.
Key:
Number of Facilities - It of facilities reporting .
Total Mercury Discharges = total mercury discharges
from all facilities reporting in each SIC code.
Range = range of reported releases from all sources
reporting in each SIC code.
Source: Permit Compliance Sysicm

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Al'l'blNLUA t"4b: IVILKCUK V LMSCIIAKI.LS IN HIE GKEA I LAKES BASIN (PCS DATA)
JUNE 1991 - JULY 1992
TOTAL HG RANGE of
NUMBER or DISCHARGES RELEASES
SIC CODE/SIC NAME	FACILITIES	(kg/yr)	(kg/yr)
34	Fabricated Metal Products
3471 Plating and polishing	2	0.07	0- 0.07
35	Machinery, Except Electrical
3562 Ball and roller bearings	I	0	0
37 Transportation Equipment
3711 Motor vehicles and car bodies	1	0.07	0.07
3714 Motor vehicle parts and accessories	1	0	0
39 Miscellaneous Manufacturing Industries
3999 Manufacturing industries, not elsewhere classified	I	9.80	9.80
49 Electric, Gas and Sanitary Services
4952 Sewerage systems	105	424.52	0 - 97.35
4953 RtTu.se systems	I	0.24	0.24
Administration
9511 Air, water resource and solid waste management	1	0.01	0.01
9711 National Security	1	0	0
TOTALS:	137	487.10	0 -97.35
Source: Permit Compliance System

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Appendix io: \visv_uiNv>iin iviilk^ukv uiviidMUiNd (/\ir point sources, vjvl uawj


TOTAL IIC
RANGE or

NtllMMER nf
EMISSIONS
RELEASES
SIC CODE/SIC NAME
FACILITIES
(pounds/yr)
(pounds/yr)
20 Food and Kindred Products



2013 Sausages and Other Prepared
1
15
15
Meat Products



2020 Dairy Producls
1
2
2
20.17 Frozen Fniits. Fruit Juices, and Vegclablcs
1
1
1
26 Paper and Allied Products



2611 Pulp Mills
2
.13
1-32
2621 Paper Mills
9
302
7-59
26.11 Papcrboard Mills
2
33
12-21
28 Chemicals and Allied Pruducls



2812 Alkalies and Chlorine
1
1071
1071
2821 Plastics Materials, Synthetic Resins, and Non-vulcanizable Elastomers
1
1
1
29 Petroleum Refining and Related Industries



2911 Petroleum Refining
1
7
7
2951 Asphalt Paving Mixtures and Blocks
1
75
75
30 Rubber and Miscellaneous Plastics Products



3011 Tires and Inner Tubes
I
1
1
32 Stone, Clay, Glass, and Concrete Producls



3274 Lime
4
17
1 -6
33 Primary Metal Industries



3.141 Secondary Smelting and Refining of Nonfcrrous Metals
1
1
1
Note: This table shows Ihc facililics (by SIC code) that reported mercury emissions under
Wisconsin's Clenn Air Act Title V Operating Permits Program. Under the Title V Program,
states may impose Tecs up to S25/lon or emissions or nil eligible substances. In Wisconsin,
facilities report emissions that exceed 1 pound.
In some cases, mercury emissions may be linked to processes such as fuel combusion that are
independent of SIC codes.
Kev
Number of Facilities = # of facilities reporting emissions.equal or
greater than I lb.
Total Emissions= total Hg emissions from all sources reporting ii
each SIC Code.
Range = range of reported releases from all sources reporting in
each SIC Code.
Continued
WISC2 XL* I 7
09/11*1

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Appendix F5: WISCONSIN MERCURY EMISSIONS (Air point sources, 1992 Data)
TOTAL IIG	RANGE of
NUMBER or EMISSIONS	P'LEASES
SIC CODE/SIC NAME			FACILITIES (pounds/yr)	(pounds/yr)
35
Industrial and Commercial Machinery and Computer Equipment




3519 Internal Combustion Engines. Not Elsewhere Classified
1
4
4

.1523 Farm Machinery and Equipment
1
21
21

3531 Construction Machinery and Equipment
1
1
1

35X5 Air-Conditioning and Warm Air Heating Equipment and Commercial and
2
2
1

Industrial Refrigeration Equipment



36
Electronic and other Electrical Equipment and Components, Except Computer Equipment




3692 Primary Batteries, Dry and Wet
2
4
1-3
37
Transportation Equipment




3713 Truck and Bus Bodies
I
It
11
39
Miscellaneous Manufacturing Industries




3999 Manufacturing Industries. Not elsewhere classified
1
3
3
49
Electric, Gas, and Sanitary Services




4911 Electric Services
13
5220
10- 1272

4931 Electric and Other Services Combined
3
79
12-44

4953 Refuse Systems
3
355
4-223

4961 Steam and Air-Conditioning Supply
5
7
1-2
82
Educational Services




X22I Colleges. Universities, and Professional Schools
3
5fi
3-42
TOTALS:	61	7307	1 - 1272
Note: This tabic shows llic facilities (by SIC code) that reported mercury emissions under
Wisconsin's Clean Air Act Title V Operating Permits Program. Under lite Tille V Program,
slates may impose Tees up to $25/ton or emissions of all eligible substances. In Wisconsin,
facilities report emissions that exceed I pound.
In soinc cases, mercury emissions may be linked to processes sucli as fuel combiision that are
independent of SIC codes.
Kcv
Number of Facilities = # or facilities reporting emissions.equal or
greater than I lb.
Total Emissions= total Hg emissions from all sources reporting ii
each SIC Code.
Range = range of reported releases from all sources reporting in
each SIC Code.
WISCJ M-l J "f J
rwil/94

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Appendix F6: Michigan Critical Materials Wastewater Report - 1991 Data
(Mercury)
SIC	Number of
Code	SIC Name	Facilities
10
Metal Mining


1021
Copper Ores
1

1081
Meta! Minine Services
2
20
Food and Kindred Products


2011
Meat Packing Plants
2

2020
Dain- Products
3

2043
Cereal Breakfast Foods
2

2063
Beet Sugar
4

2077
Animal And Marine Fats And Oils
1
25
Furniture and Fixtures


2500
Furniture And Fixtures
4
26
Paper and Allied Products


2600
Paper and Allied Products
2

2621
Paper Mills
4

2631
Paperboard Mills
3

2650
Paperboard Containers and Boxes
3

2670
Misc. Convened Paper Products
1
27
Printing
and Publishing


2700
Printing and Publishing
1

2710
Newspapers
2

2750
Commercial Printino
5
28
Chemicals and Allied Products


2800
Chemicals and Allied Products
2

2810
Industrial Inorganic Chemicals
1

2819
Industrial Inorganic Chemicals, Nec
2

2820
Plastics Materials and Synthetics
2

2821
Plastics Materials And Resins
1

2830
Drugs
10

2834
Pharmaceutical Preparations
1

2850
Paints and Allied Products
5

2851
Paints And Allied Products
1

2860
Industrial Organic Chemicals
2

2890
Miscellaneous Chemical Products
1

2891
Adhesives And Sealants
1

2899
Chemical Preparations. Nec
1
29 Petroleum and Coal Products
2900 Petroleum and Coal Products	1
2911 Petroleum Refining	1
Hom £• Associates Environmental Consulting. Ltd
Sic J .XLs
»/>T9i

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(Mercury)



Sir Namp

30
Rubber and Misc. Plastic Products


3069
Fabricated Rubber Products. Nec
3

3079

2

3080
Miscellaneous Plastics Products. NEC
16

3089
Plastics Products. Nec
1
31
Leather and Leather Products


3111
Leather Tannine And Finishing
1
32
Stone, Clay and Class Products


3220
Glass and Glassware. Pressed or Blown
1

3297
Nonclav Refractories
1
33
Primary Metal Industries


3312
Blast Furnaces And Steel Mills
3

3320
Iron and Steel Foundries
1

3321
Gray And Ductile Iron Foundries
2

3322
Malleable Iron Foundries
1

3330
Primary Nonferrous Metals
1

3340
Secondary Nonferrous Metals
1

3360
Nonferrous Foundries (Castings)
1

3365
Aluminum Foundries
1

3366
Copper Foundries
1
34
Fabricated Metal Products


3400
Fabricated Metal Products
2

3441
Fabricated Structural Metal
1

3449
Miscellaneous Metal Work
1

3462
Iron And Steel Forgings
1

3465
Automotive Stampings
5

3470
Metal Services, NEC
1

3471
Plating And Polishing
5

3479
Metal Coating And Allied Serv ices
4

3490
Misc. Fabricated Melal Products
4

3499
Fabricated Metal Products. Nec
1
35
Industrial Machinery and Equipment


3510
Engines and Turbines
4

3540
Metalworking Machinery
1

3560
General Industrial Machinery
2
36
Electronic & Other Electric Equipment


3630
Household Appliances
1

3670
Electronic Components and Accessories
1

3691
Storace Batteries
1
37
Transportation Equipment


3700
Transportation Equipment
1

3710
Motor Vehicles and Equipment
4

3711
Motor Vehicles And Car Bodies
8

3714
Motor Vehicle Pans And Accessories
18

3720
Aircraft and Pans
2

3790
Miscellaneous Transponation Equipment
1
S1CIJCLS
Ross <£ Associates Etrvirctnntntal Consulting, Ltd.	09/11/94

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Appendix F6: Michigan Critical Materials Wastewater Report - 1991 Data
(Mercury)
Code	SIC Name	Facilities	
38 Instruments and Related Products
3812 Search And Navigation Equipment	1
3820	Measuring and Controlling Devices	2
3821	Laboratory Apparatus And Furniture	1
3840 Medical Instruments and Supplies	1
3843	Dental Equipment And Supplies	1
42 Trucking and Warehousing
4200 Trucking and Warehousing 1
47 Transportation Services
	4785 Inspection And Fixed Facilities	1
49	Electric, Cas, and Sanitary Services
4911 Electric Services	16
4925 Gas Production And/Or Distribution	2
4950 Sanitary Services	I
4953 Refuse Systems	1
50	Wholesale Trade - Durable Goods
5013 Motor Vehicle Supplies And New Parts-Wholesale Trade 2
	5085 Industrial Supplies-Wholesale Trade	1	
51	Wholesale Trade - Nondurable Goods
5169 Chemicals And Allied Products. Nec	1	
65 Real Estate
	6512 Nonresidential Building Operaion	3_	
72	Personal Services
	7210 Laundry. Cleaning. & Garment Services	6
73	Business Services
	7391	3	
76 Miscellaneous Repair Services
	7699 Repair Services. Nec	1
80 Health Services
8050	Nursing and Personal Care Facilities	1
8060	Hospitals	19
8070	Medical and Dental Laboratories	4
	8093	Specialty Ourpntient Clinics. Nec	8
87 Engineering & Management Services
8730	Research ahd Testing Services	12
8731	Commercial Physical Research	I
8733	Noncommercial Research Organizations	1
8734	Testing Laboratories	2
S741	Management Services	1
8744	Facilities Support Services	1
Total:	273
Ron & Associatts Enviroiuutuial Consulting. Lid
SIC7JOS
W/II/SU

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Appendix F7: Indiana Mercury Emissions (Air Point Sources, 1990 Data)
sic sic
Code Category
# OF FACILITIES
14 Nonmetallic Minerals, Except Fuels
	1422 Crushed and Broken Limestone
20 Food and Kindred Products
2011	Meat Packing Plants
2033	Canned Fruits and Vegetables
2046	Wet Com Milling
2048 . Prepared Feeds, NEC
2075	Soybean Oil Mills
2077	Animal and marine fats and oils
2082	Malt Beverages
2085	Distilled and Blended Liquors
2099	Food Preparations, nec	
24 Lumber and Wood Products
2434	Wood Kitchen Cabinets
2435	Hardwood Veneer and PI wood
25 Furniture and Fixtures
2511	Wood Household Furniture
2512	Upholstered household furniture
2521 Wood Office F umiture
2531 Public Buildine and Related Furniture
26 Paper and Allied Products
2631 Paperboard Mills
2645
	2679 Convened Paper Products, nec
28 Chemicals and Allied Products
2819 Industrial Inorganic Chemicals, nec
2833	Medicinals And Botanicals
2834	Pharmaceutical Preparations
2869 Industrial Oreanic Chemicals. Nec
30 Rubber and Misc. Plastic Products
3081 Unsupported Plastics, Film And Sheet
NOTE: This table shows the facilities (by SIC code) that may generate mercury
emissions in Indiana. Hie information is included in Indiana's Aerometric Information
Retrieval System (AIRS) 1990 emissions inventory, which contains data on criteria
pollutant emissions. Mercury emissions quantities are estimates derived by the Indiana
Department of Environmental Management, based on reported data. As such, the
quantities do not represent measured data, nor data supplied directly by individual
facilities. The quality of this data may be suspect based on uncertainty of specific
emissions factors used and its completeness.
In some cases, mercury emissions mnv be linked to processes such as coal-buming
boilers that are independent of SIC codes and specific industrial processes.
Ross & Associates Environmental Consulting. Ltd
NDYABL5QJ
Oft/1 |/W

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SIC
SIC

Code
Category
# OF FACILITIES
32
Stone, Clay, and Class Products


3241 Cement, Hydraulic
2

3251 Brick and Structural Clav Tile
1

3269 Pottery Products, nec
1

3272 Concrete Products, nec
1

3274 Lime
1
33
Primary Metal Industries


3312 Blast Furnaces And Steel Mills
2

3341 Secondary Non-ferrous Metals
1
34
Fabricated Metal Products


3443 Fabricated Plate Work (Boiler Shops)
1

3471 Plating And Polishine
1
35
Industrial Machinery and Equipment


3319 Internal Combustion Engines, nec
1

3541 Machine Tools. Metal Cutting Types
1

3569 General Industrial Machinery nec
1
36
Electronic & other Electric Equipment


3612 Transformers. Except Electronic
1

3632 Household Refrigerators and Freezers
1

3647 Vehicular Lighting Equipment
1

3691 Storage Batteries
1

3694 Eneine Electrical Equipment
1
37
Transportation Equipment


3714 Motor Vehicle Parts And Accessories
7

3724 Aircraft Eneines and Eneine Parts
1
47
Transportation Services


4789 Transportation Sen-ices. Nec
1
49
Electric, Cas, and Sanitary Services


4911 Electric Services
30

4953 Refuse Systems
1
80
Health Services


8061 Hospitals
4

8063 Psychiatric Hospitals
5
82
Educational Services


8221 Colleges And Universities
9

8249 Vocational Schools, nec
1
83
Social Services


8361 Residential Care
2
92
Justice, Public Order, and Safety


9223 Correctional Institutions
2
97
National Security and Int'l Affairs


9711 National Security
2
Totals:	120
DTOYAXXU
floss & Associates Emnrotrmental Consulting. Ltd.	An*ol PrntftCtlOH nQBOCy


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