EPA/600/R-02/104
                                                     December 2002
         Use and Release of
Mercury in the United States
                        by
                   Barry R. Leopold
         Science Applications International Corporation
                 Reston, Virginia 20190
         Contract Nos. 68-C-0027 and 68-C7-0011
                   Project Officer

                   Kenneth Stone
             Sustainable Technology Division
       National Risk Management Research Laboratory
                Cincinnati, Ohio 45268
       National Risk Management Research Laboratory
           Office of Research and Development
          U.S. Environmental Protection Agency
                Cincinnati, Ohio 45268

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                                              Notice

The information in this document has been funded by the United States Environmental Protection Agency under
Contract Nos. 68-C6-0027 and 68-C7-0011 to Science Applications International Corporation (SAIC). It has been
subj ected to the Agency' s peer and administrative review and has been approved for publication as an EPA document.
Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

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                                             Foreword

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the Nation's land, air, and
water resources. Under a mandate of national environmental laws, the Agency strives to formulate and implement
actions leading to a compatible balance between human activities and the ability of natural systems to support and
nurture life. To meet this mandate, EPA's research program is providing data and technical support for solving
environmental problems today and building a science knowledge base necessary to manage our ecological resources
wisely, understand how pollutants affect our health, and prevent or reduce environmental risks in the future.

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

This publication has been produced as part of the Laboratory's strategic long-term research plan. It is published and
made available by EPA's Office  of Research and Development to assist the user community and to link researchers
with their clients.
                                            E. Timothy Oppelt, Director
                                            National Risk Management Research Laboratory
                                                  111

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                                              Abstract

Although mercury use is decreasing in the United States, mercury continues to pose a serious risk to human health
and the environment. This report presents the results of a two-year effort sponsored by EPA's Office of Research and
Development to quantify and map the flows of mercury throughout the U.S. economy and  released into the
environment. Data contained in the report are intended to help prioritize research and development efforts.

Using a materials flow analysis (MFA), this report quantifies cradle-to-grave mercury use, reuse, release and disposal
associated with products and processes that use mercury.  Among the 100 data sources examined were industry
estimates, government statistics, literature  sources, and USEPA data such as the Toxics Release Inventory and
emission factors.  Specific industries  and sectors within the following major divisions were evaluated:  mercury
supply, mercury use in manufacturing processes, incidental mercury use associated with coal combustion, incidental
mercury use associated with non-coal  sources, and other sources of mercury resulting from previous use. For each
sector, mercury use is described, mercury-containing raw materials and products catalogued, and reported mercury
releases into media (air, water, and solid waste) quantified. For sectors in which data are available concerning mercury
speciation and geographic distributions, this information is presented.
                                                   IV

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                                       Table of Contents

Abstract  	  iv

List of Exhibits	  vi

List of Acronyms and Abbreviations	 viii

Acknowledgments 	  ix

Chapter 1 Introduction	1
       1.1 Background	1
       1.2 Purpose of Report	1
       1.3 Methodology Used in Report  	2
       1.4 Scope of Report	2
       1.5 Summary of Results  	3
       1.6 Data Limitations and Uncertainty	3

Chapter 2 Supply of Mercury  	16
       2.1 Secondary Mercury Production  	16
       2.2 Imports and Exports  	19
       2.3 U.S. Government Stockpiles	19
       2.4 Miscellaneous U.S. Government Uses 	19

Chapter 3 Manufacturing Processes Involving Mercury	20
       3.1 Chlor-Alkali Manufacturing	20
       3.2 Lamp Manufacturing, Use, and Disposal 	23
       3.3 Thermometers and Other Instruments	26
       3.4 Thermostats	29
       3.5 Switches and Relays	31
       3.6 Organic Chemical Production	34
       3.7 Dental Preparations	34
       3.8 Pharmaceutical Use	36
       3.9 Laboratory  Use  	37
       3.10 Batteries  	38
       3.11 Miscellaneous	38

Chapter 4 Incidental Mercury Use Associated With Coal Combustion or Coal Use	39
       4.1 Coal Combustion by Utilities	39
       4.2 Lime Manufacturing	43
       4.3 Residential, Commercial, and Industrial Coal Combustion  	45
       4.4 Byproduct Coke Production	47
       4.5 Portland Cement Manufacturing	48
       4.6 Coal Combustion Waste Products	50

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Chapter 5 Incidental Mercury Use Associated With Non-Coal Sources	52
       5.1 Oil Combustion	52
       5.2 Carbon Black Production 	54
       5.3 Gold Mining 	56
       5.4 Primary Lead and Zinc Mining and Smelting	57
       5.5 Primary Copper Mining and Smelting 	58
       5.6 Pulp and Paper Manufacturing 	59
       5.7 Oil Refining  	60
       5.8 Rubber and Plastic Products	60
       5.9 Geothermal Power	61
       5.10 Wood-Fired Boilers  	61
       5.11 Utility Natural Gas Combustion	62

Chapter 6 Additional Sources of Mercury Resulting from Disposal or Other Final Disposition  	63
       6.1 Hazardous Waste Combustion 	63
       6.2 Crematories	64
       6.3 Sewage Treatment and Sludge Incineration	66
       6.4 Municipal Waste Combustion	68
       6.5 Landfills  	68
       6.6 Medical Waste Incineration 	69

Chapter 7 Geographic Distribution of Mercury	70
       7.1 Purpose 	70
       7.2 Data Sources and Limitations	70
       7.3 Findings  	72
       7.4 Speciation	83

Chapter 8 Conclusions	87
       8.1 Conclusions	87

References 	94
                                                 VI

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                                         List of Exhibits

Exhibit 1-1. Summary of the U.S. Mercury Life Cycle	5
Exhibit 1-2. Summary of Mercury Mass Balance and Data Quality 	6
Exhibit 1-3. Annual Flow of Mercury in Supply and Manufacturing Sectors	8
Exhibit 1-4. Annual Flow of Mercury Associated with Incidental Mercury Use 	9
Exhibit 1-5. Summary of Data Quality for Selected Sectors	10
Exhibit 1-6. Review of Data Quality for Selected  Sectors	11
Exhibit 2-1. Mercury in Secondary Mercury Production  	17
Exhibit 3-1. Mercury in Chlor-Alkali Manufacturing	21
Exhibit 3-2. Chlor-Alkali Mercury Cell Process Mercury Used , Emitted, Recycled, and Disposed	21
Exhibit 3-3. Mercury in Electrical Lighting	24
Exhibit 3-4. Lighting Industry Mercury Consumed	24
Exhibit 3-5. Mercury in Thermometers	27
Exhibit 3-6. Mercury Used to Manufacture Thermometers in the U.S. in 1997 	27
Exhibit 3-7. Mercury Consumption by SIC Code  382 - Measuring and Control Instruments (tons)	28
Exhibit 3-8. Mercury in Thermostats	30
Exhibit 3-9. Mercury in Switches and Relays Manufacturing	32
Exhibit 3-10. Mercury Consumption by SIC Code 3643 - Wiring Device and Switches	33
Exhibit 3-11. Mercury Content of Various Mercury Switches and Relays	33
Exhibit 3-12. Mercury in Dental Preparations	35
Exhibit 3-13. Mercury in Pharmaceuticals	37
Exhibit 4-1. Mercury in Utility Coal Combustion	40
Exhibit 4-2. Efficiencies of Various Control Devices in Removing Mercury from Flue Gas	41
Exhibit 4-3. Mercury in Lime Production  	44
Exhibit 4-4. Mercury in Residential, Commercial, and Industrial Coal Combustion  	46
Exhibit 4-5. Mercury in Coke Production	48
Exhibit 4-6. Mercury in Cement Manufacturing	49
Exhibit 5-1. Mercury in Utility, Non-utility, and Residential Oil Combustion	53
Exhibit 5-2. Mercury in Carbon Black Production 	55
Exhibit 5-3. Mercury in Gold Mining  	57
Exhibit 5-4. Mercury in Primary Lead and Zinc Production	58
Exhibit 5-5. Mercury in Primary Copper Production 	59
Exhibit 5-6. Mercury Content of Crude Oil and Petroleum Products 	60
Exhibit 5-7. Mercury in Oil Refining	61
Exhibit 6-1. Mercury in Hazardous Waste Combustion 	64
Exhibit 6-2. Mercury in Crematories	65
Exhibit 6-3. Mercury Flow in Sewage Treatment	67
Exhibit 7-1. List of Data Sources for Geographic  Distribution of Mercury 	71
Exhibit 7-2. Total Mercury Releases by States (1999 TRI)	73
Exhibit 7-3. Total Mercury Air Releases by States (1999 TRI)  	73
Exhibit 7-4. Total Mercury Air Release by State (NTI 1996)	74
Exhibit 7-5. Mercury Emission Density by State (NTI 1996)	74
Exhibit 7-6. Number of Mercury Spills Reported  per State (NRC 2000)  	75
Exhibit 7-7. Mercury Fish Advisories by State  	76
Exhibit 7-8. Coal-fired Utility Boilers Release of Mercury by State (ICR 2000)	77
Exhibit 7-9. NTI County Density Map for Mercury Compounds 	79


                                                 vii

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Exhibit 7-10. 25 Counties Reporting Highest Mercury Air Emissions from NTI	80
Exhibit 7-11. 25 Counties Reporting Highest Mercury Air Emissions from Coal-fired Boilers	81
Exhibit 7-12. 25 Counties Reporting Highest Multimedia TRI Releases  	82
Exhibit 7-13. 25 Counties Reporting Highest Releases from 3 Data Sources	83
Exhibit 7-14. Speciation Emission for Coal-fired Utility Boiler by State	84
Exhibit 8-1.  Summary of Sectors with 100+Tons of Mercury in a Life Cycle Stage  	90
                                                 vin

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                            List of Acronyms and Abbreviations

Btu           British Thermal Unit
CaO          Calcium Oxide
CGLI         Council of Great Lakes Industries
CIBO         Council of Industrial Boiler Owners
USDHHS      United States Department of Health and Human Services
USDOE       United States Department of Energy
EEI           Edison Electric Institute
USEPA              United States Environmental Protection Agency
EPRI         Electric Power Research Institute
ESP          Electrostatic Precipitator
FETC         Federal Energy Technology Center
FGD          Flue Gas Desulfurization
GLNPO       Great Lakes National Program Office
GLNWF       Great Lakes National Wildlife Federation
HAP          Hazardous Air Pollutant
HC1          Hydrogen Chloride
Hg           Mercury
LCA          Life Cycle Assessment
LCI          Life Cycle Inventory
MFA         Materials Flow Analysis
MSW         Municipal Solid Waste
NaCl         Sodium Chloride
NAICS        North American Industry Classification System
NaOH         Sodium Hydroxide
NEMA        National Electrical Manufacturers Association
NPDES              National Pollutant Discharge Elimination System
PBT          Persistent, Bioaccumulative and Toxic
POTW        Publicly Owned Treatment Works
ppm          parts per million
ppmwt        parts per million (weight)
RCRA        Resource Conservation and Recovery Act
SBIR         Small Business Innovative Research Program
SIC           Standard Industrial Classification
TCLP         Toxicity Characteristic Leaching Procedure
TSCA         Toxic  Substances Control Act
UCR         University Coal Research Program
UDI          Utility Data Institute
USBM        United States Bureau of Mines
USGS         United States Geological Survey
WLSSD       Western Lake Superior Sanitary District
                                                IX

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                                       Acknowledgments

This report was prepared under the direction and coordination of Kenneth R. Stone of the U.S. Environmental
Protection Agency, Systems Analysis Branch, Sustainable Technology Division, National Risk Management Research
Laboratory, Cincinnati, Ohio.  This report was prepared by Science Applications International Corporation (SAIC)
in Reston, Virginia, under Contract nos. 68-C6-0027 and 68-C7-0011.

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                                             Chapter 1
                                           Introduction
1.1 Background
The United  States Environmental Protection Agency
(USEPA) is  charged by Congress with protecting the
Nation's land,  air, and water  resources.   Under a
mandate of national environmental laws, the Agency
strives to formulate and carry out actions leading to a
compatible balance between human activities and the
ability of natural systems to support and nurture life.
These   laws  direct  the   USEPA  to  define  our
environmental problems, measure the  impacts,  and
search for solutions. The National Risk Management
Research  Laboratory   is responsible  for  planning,
implementing, and managing research, development, and
demonstration programs. These provide an authoritative
defensible engineering basis in support of the policies,
programs, and regulations of the USEPA with respect to
drinking water, wastewater, pesticides, toxic substances,
solid  and  hazardous  wastes, and Superfund-related
activities.

USEPA has identified mercury as one of 12 persistent,
bioaccumulative, and toxic (PBT) substances (63 Federal
Register 63926, November  17,  1998).    Although
mercury use is decreasing in the United States, mercury
continues to pose a serious risk to public health and the
environment.  For several years USEPA  has  been
coordinating  efforts  with   other  North  American
countries,  as well as  its own national and regional
programs,  as part of the PBT Program.  The goal of
USEPA's PBT Program is to reduce the risk and future
exposure to PBTs using a cross-goal and cross-media
approach.

Recent USEPA activities have focused on studying and
reducing the impacts  of mercury  and  other  PBT
chemicals on the Great Lakes, and developing initiatives
to promote the recycling of mercury-containing products
to reduce the quantity of mercury in landfilled wastes.
These efforts have focused attention on  mercury use
disposal and have led to the development of some
valuable use  and release data. However, a thorough
inventory of the mercury life cycle has not yet been
developed.

Previous reports  published  by USEPA,  States, and
foreign countries  have identified sources  and uses of
mercury. These reports include USEPA's \991Mercury
Study Report to Congress, which presented nationwide
air release  estimates  for  individual  sectors  where
mercury is used  intentionally or  is  present  as  a
contaminant  in  raw  materials.    Additional data
describing  mercury use have been available from the
U.S.  Geological  Survey   (USGS)  and the  U.S.
Department of Commerce's Bureau of Census.  These
sources assist in identifying significant industrial and
consumer sectors where mercury is used, released to the
environment, or both. While the quality of the data in
the Report to Congress is necessarily variable due to the
diversity of sectors, it serves as a useful starting point for
information on most sectors where mercury  can enter the
environment.    Other  valuable  resources   include
USEPA's 1997 Locating and Estimating Air Emissions
from Sources of Mercury and Mercury Compounds and
several other sources developed through the  EPA's Great
Lakes National  Program Office (GLNPO). The 1997
Mercury Study  Report  to  Congress,  for example,
identifies over 40 types of sources releasing mercury to
air.

As part of the Agency-wide PBT Program, the Office of
Research  and  Development  (ORD)  is   identifying
economic and environmental effects of implementing
possible pollution prevention opportunities. The first
step of this  effort is to  quantify rates  of  mercury
production, use, recycling, and  environmental releases.
The data in this report will be used in future USEPA and
ORD efforts that identify industry-specific pollution
prevention opportunities and evaluate the economic and
environmental effects of their implementation.

1.2 Purpose of Report
The purpose  of this report is to quantify  the use and
release  of mercury  in the  United  States.   Using a
Materials Flow  Analysis (MFA), this report quantifies

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cradle-to-grave mercury use, reuse, release, and disposal
associated with products and processes that use mercury.
An MFA is largely based on the Life Cycle Assessment
(LCA) concept, which is  a  process  to  evaluate the
complete "life cycle" environmental impact of a product,
process, or activity.  Rather than take a broad multi-
chemical  approach,  typical of an LCA, this  report
focuses on the flow of mercury throughout each stage,
from  raw  materials  acquisition  through  ultimate
disposition.

1.3 Methodology Used in Report
This study examines mercury use in the United States
from supply through disposal.  To assess the life cycle
implications of mercury use in the United States, this
report used the USEPA's 1997Mercury Study Report to
Congress  as  a starting point  for identifying domestic
sectors where mercury is present. This report identifies
the following five categories of sectors:

•  Mercury  supply. This  accounts for facilities who
    sell  purified  (usually  elemental)  mercury  for
    industrial use.
•  Mercury use in manufacturing processes. Facilities
    may use  mercury as part of a production process
    (e.g., in chlor-alkali production, mercury is used on-
    site but is not intended to be in products) or  in a
    mercury-containing  product  (e.g.,  fluorescent
    lamps).
•  Incidental  mercury  use  associated with  coal
    combustion.  Mercury is a coal contaminant. Coal is
    used not only for large-scale power generation, but
    in other areas for combustion or as a raw material.
•  Incidental mercury use associated with non-coal
    sources.  Mercury is present as a contaminant in
    non-coal fossil fuels and in mined minerals.
•   Other sources of mercury resulting from previous
    use. In some cases, the life cycle of mercury cannot
    be easily traced.  For  example, mercury may be
    found in wastewater which is then treated as sewage.
   While the initial sources of the mercury discussed in
   this category may be covered under another sector,
    such  as the manufacture of a mercury bearing
    product, mercury from previous use is addressed in
    keeping with the life cycle approach to this report.

For each  sector, the following data elements on a
national level and annual basis are identified:

(1) A  short  description of how  mercury is used in
    processes or products.
(2) Raw materials containing mercury, and the quantity
    of mercury in these raw materials.
(3) Products containing mercury, and the quantity of
    mercury in these products.
(4) Potential release points of mercury, and quantitative
    emissions of mercury to air, water, and land.
(5) A discussion  of the quality and consistency of the
    above elements.

For each sector, these estimates are presented in a flow
diagram format.   The basis for the estimates (e.g., the
data source and/or calculation method), the quality of the
underlying data, and their uncertainty are also presented.
This format allows easy  identification of sectors in
which  information  regarding  raw materials, product
content, and mercury release is incomplete, uncertain, or
contradictory. When such instances occur, a speculation
is  made as to whether these mass  imbalances are
reflective   of unreported   emissions,  data  quality
limitations, or other reasons.   The methodology for
obtaining these estimates is presented in the individual
chapters of this report.

As a final step in the methodology, maps were created to
show which regions  of country  release the largest
amounts of mercury. The emissions from several data
sources were mapped showing the quantity and density
of mercury emissions. In addition, available speciation
data were added into the maps.

1.4 Scope of Report
Using  an  MFA,  this  study profiles mercury in  raw
materials  acquisition,  product manufacturing, use,
recycling,  and  final  disposition.   Additionally,  it
provides information from data  sources  that track
mercury  releases to  different media.    The  report
identifies uses of mercury for which data are available,
and identifies uses of certain raw materials (such as coal)
where mercury is present as a contaminant. However, all
such raw materials are not identified, and all products
containing mercury (for widespread downstream use) are
not included.

In addition, this report attempts to incorporate speciation
data into the analysis. Data sources were examined and
mapped to provide an overview of which regions of the
United States emit the  largest amounts of mercury.
Mercury speciation data were then collected and used to
quantify each species of mercury released for a particular
sector.  Speciation data were  available  only for the
combustion of utility coal and municipal waste.

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The results of this study can be used in conjunction with
other data to better identify mercury use and release
patterns. For most of the sectors identified in this report,
pollution prevention opportunities are discussed in the
report titled Identifying Research and  Development
Priorities to Reduce Mercury Use and Environmental
Releases in the United States.  This report containing
pollution  prevention opportunities and the MFA are
intended to be used as companion documents.  The
results of these two efforts could be used to help target
and reduce the mercury use in specific sectors.

1.5 Summary of Results
7.5.7 Description of Exhibits
Exhibits 1-1 through 1-4 summarize the findings of this
report for mercury use sectors and their categories.  A
"sector" is a single industry or class of similar products
or processes where mercury is present.  Subsequently,
sector is a very flexible term because it can mean, for
example, the industry of chlor-alkali manufacturing, the
production and use of mercury containing-lights, or the
process of oil combustion. As discussed above, there are
five categories of sectors presented in this report: (1)
mercury  supply;   (2)  manufacturing   and  use  of
manufactured products; (3) incidental usage of mercury
in coal; (4) incidental usage of mercury in non-coal
materials; and (5) other sources resulting from previous
use.  Each exhibit identifies these  major categories,
while Exhibits 1-2 through  1-4 identify the individual
sectors comprising the  categories.

These exhibits present the flow of mercury on a national
aggregate  annual  basis  for  mercury  sectors  and
categories of sectors. The actual flow changes from year
to year as  a result of changes in  demand, industry
initiatives  to  reduce  or   measure  mercury,  and
implementation of regulatory efforts by local, state, and
federal governments. Additionally, the same quality of
data are not available on a consistent basis from year to
year for all sectors or  even within individual sectors,
therefore  the  data presented  in  these  exhibits  are
intended to represent mercury flow in the latest year
where data are available, rather than for any specific
year.

Exhibit 1-1 provides an overview of the available data.
The data are presented according to major categories.
The purpose of Exhibit 1-1 is to identify principal flows
of mercury through the U.S. Economy. Mercury sources
are listed at the top of Exhibit  1-1.  Each of these
constitute  'inputs' to the flow of mercury in the United
States.  Mercury then flows to subsequent categories,
including manufacturing and use, or straight to final
disposition  (represented  as  wastes,  exports,  and
recycling).

Exhibit 1-2 quantifies the flow of mercury for  the
individual sectors  evaluated in this report.   The first
column accounts for mercury inputs for each sector; this
includes the use of elemental mercury and the presence
of mercury as a contaminant in raw materials.  The next
three  columns indicate  the  quantity  of releases  of
mercury into the environment for air, water, and solids.
The last column presents the quantity of mercury that
has accumulated as a result of historical use (reservoir).

Other notations are used in Exhibit 1-2 to acknowledge
that specific sectors represent a source of mercury but
that an estimate is not provided. Reasons include  an
overall lack of data or unreliable data, or that all relevant
quantities are  small relative to the  other  sources
presented in this exhibit (less than one ton).  The basis
for the estimates, or a discussion of why no estimate is
presented, is provided in the subsequent chapters of this
report.

Exhibits 1-3 and 1-4 present further sector-specific detail
for each of the sectors evaluated  in this report. Exhibit
1-3 illustrates  the quantities  of mercury  in supply,
manufacturing  processes, and   subsequent  use   of
manufactured products. These are discussed in Chapters
2 and 3 of this report.  Exhibit  1-4  illustrates  the
quantities of  mercury  in cases where  mercury  is
incidentally used and in final disposition.  These  are
discussed in Chapters 4 through  6 of this report. Data
are presented for the quantity consumed (present in raw
materials) which was previously shown  in Exhibit 1-2.
In these  exhibits,  however, the  outputs are detailed
according  to   the  quantities  in  product,  exports,
multimedia releases (sum of air, water,  and land), and
recycling.

1.6 Data Limitations and Uncertainty
The  quantitative data in  this report are based on a
combination of government data, industry  data, and
estimates.  The quality of these data often differ  by
sector due to industry-specific initiatives undertaken in
response to regulatory  or voluntary  efforts, such  as
reporting requirements.   The use and management of
mercury has been  changing in the last several years in
response to these initiatives, which makes even recent
mercury  use data  unreliable.  Where this is  the case,

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trend information has been presented, where available,
to give an indication of the changes in process. Finally,
it is unusual to obtain consistent information on raw
material use, releases, recycling, and product content.
The result is that the data presented in this report are of
varying quality and is subject to future change. It is not
possible  to  obtain data  for a single  consistent year
throughout the report. For example,   some data are
applicable for 1995, others for 1999, and other estimates
are calculated using data for a variety of years. This was
a function of two factors:

•   Use  of  data  which  was  readily  available;  for
    example, the Toxics Release Inventory (TRI) data.
    The most recent data available, from the 1999 TRI,
    were used throughout this report.
•   Data  were only available for a certain  year; for
    example,  Department  of  Commerce (Bureau  of
    Census)  data.   Until  1994, the  Department  of
    Commerce collected  data for lamp production.  In
    this report, such data were used because it was the
    most  recent.  However, based  on  later indirect
    indications as discussed in the report, such data may
    be adequate for approximating current production.

USEPA has finalized revisions to the Toxics Release
Inventory (TRI), which reduce the reporting threshold of
mercury  to  10  pounds (64 Federal  Register 58666,
October 29, 1999). These changes took effect for the
year 2000 reporting year, and the data were not available
to the public until mid-2002. These changes mean that
a facility that uses as little as 10 pounds of mercury in a
year will be required to report its release  and recycling
activities (even if its releases are zero). Under previous
reporting  years, a facility was not required to report its
releases unless it used 10,000  pounds of mercury in a
year.   The  result  of this change is that many more
facilities that use and release mercury will be reporting
this information, which  will  improve the quality  of
several of the  numerical estimates  presented in this
report.

Additional caution should be  used for Exhibits  1-2
through  1-4.  Estimates are sometimes presented  as
single numbers, and sometimes as ranges.  Ranges are
used to express the range  of uncertainty in the available
data.   However, there is uncertainty associated with
much of the data expressed as discrete values, which is
discussed in detail in the  individual chapters of this
report.
Integrating  and  interpreting  data  from  various
information sources in orderto characterize processes, in
this case the flow of mercury through key industries,
inherently results in some degree of uncertainty. In this
study, some sources of information were equivocal due
to factors such as low sample sizes, conflicting reports,
or a of lack of data.  The degree of uncertainty in data
collected for this report varies among sectors  and  by
estimate  (releases,   consumption,  and  reservoirs).
Despite  associated  uncertainties,  estimations  are
expected to  provide a relative  scale  ranging from
industries that are heavily involved with mercury to
those that are associated with the element to a much
lesser degree.

In this report, sources of uncertainty are addressed in
detail for each sector. The purpose of this section is to
provide a summary of the uncertainty associated with the
mercury usage estimates of several key sectors. Exhibit
1-5 lists the mercury quantities associated with these key
sectors  (use, release, and reservoir) and assigns each
relevant estimate a data quality score  in order to aid
interpretations of this report's findings.  Data scores use
an A, B, or C system designed to  render the sector
estimates into 3 tiers of data confidence.  Exhibit 1-6
discusses the supporting materials within each scored
industry and is intended to elucidate the basis of the data
quality scores.  Justifications of data quality scores for
remaining sectors are not explicitly identified, rather, a
discussion of data quality for each sector is provided in
their respective chapters.

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        The  U.S. Mercury  Life Cycle
Raw
Materials
Acquisition

Product
Manufacture
Domestic sources of
    mercury
Product Use
Final
Disposition
Imported sources
  of mercury
           Mercury used in
             products and
              processes
Combustion sources of
     mercury
                   Mercury found in
                   commercial and
                 professional products
           Recycled
           mercury
            wastes
          Mercury
        releases to air,
       water, and land
          Exported
          mercury
                        Exhibit 1-1. Summary of the U.S. Mercury Life Cycle

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Exhibit 1-2. Summary of Mercury Mass Balance Data
Mercury Sector
Mercury Supply (discussed in Chapter 2)
Secondary Mercury Production
Imports and Exports
U.S. Government Stockpiles
Total for Mercury Supply
Mercury Use in Manufacturing Processes (discussed in Chapter 3)
Chlor-alkali Manufacturing
Electrical Lighting: Manufacturing
Electrical Lighting: Use and Disposal
Thermometers: Manufacturing
Thermometers: Use and Disposal
Thermostats: Manufacturing
Thermostats: Use and Disposal
Switches and Relays: Manufacturing
Switches and Relays: Use and Disposal
Organic Chemical Production
Dental Preparations Manufacturing
Dental Office: Use
Mercury Compounds
Batteries
Total for mercury use in manufacturing
Mercury Used in Raw
Materials (ton/yr)

430
-83
0
347

79
16
17*
9- 17
9-17*
15-21
13-20*
36-63
36-63*
—
34-54
34 - 54 *
—
negligible
189 - 250
Waste Releases (ton/yr)
Air

0.4
0
0
0.4

6.3
0.3
3
<0.2
2-3
0
1-2
0
7-13
—
0
0.8
—
negligible
20.4 - 28.5
Water

0
0
0
0

0.1
—
0
0
0
0
0
0
0
—
0
7.4
—
negligible
7.5
Solid

0.1
0
0
0.1

21.5
0.2
11
0
7-14
0
6-8
0
29-50
—
0
0
—
negligible
74.7-104.7
Mercury Reservoir
(ton)

—
—
4,850
4,850

2,000
0
65-75
0
45-85
0
230
0
630
—
0
1,200
—
—
4,170-4,220
Incidental Mercury Use Associated with Coal Combustion (discussed in Chapter 4)
Utility Coal Combustion
Lime Manufacturing
Residential/Comm/Industrial Coal Combustion
Byproduct Coke Production
Portland Cement Manufacturing
Coal Combustion Wastes
Total for Coal Combustion
Incidental Mercury Use Associated with Non-Coal Sources (discussed
105
2.7-5.0
7.6-21.2
3.2
3.4-5.7
3
124.9-143.1
in Chapter 5)
48
0.1
21.2-23.6
0.7
4.2
0
74.2 - 76.6

1
0
0
0
0
0
7

33
0.1
0.6
1.5
0.6
3
38.8

0
0
0
0
0
—
0


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                                                                                                                 Waste Releases (ton/yr)
Mercury Sector
Oil Combustion: U.S. Utility
Oil Combustion: Other
Carbon Black Production
Gold Mining
Primary Lead and Zinc Mining and Smelting
Primary Copper Mining and Smelting
Mercury Used in Kaw
Materials (ton/yr)
0.06
0.08
0.11
1,370
0.2
6.4
Air
0.2
7.8-10.9
0.3
6.2
0.2
0.1
Water
0
0
0
0
0
0
Solid
<0.6
<0.1
0
1,342
7.6
16.4
Mercury Reservoir
(ton)
0
0
0
—
0
0
      Pulp and Paper Manufacturing                                                —
      Oil Refining                                                             2.2-11.5
      Rubber and Plastic Products                                                   —
      Geothermal Power                                                           —
      Wood-fired Boilers                                                          —
      Utility Natural Gas Combustion                                           negligible
  Total for Incidental Non-Coal Sources                                        1,379 - 1,389
  Other Sources of Mercury Resulting from Previous Use (discussed in Chapter 6)
      Hazardous Waste Combustion                                                1.0
      Crematories                                                                 1.4
      Sewage  Treatment and Sludge Incineration                                     12
      Municipal Waste Combustion                                                 —
      Landfills                                                                    —
      Medical Waste Incineration                                                   —
      Historical Mining Activities                                                   —
  Total for Previous Use Sources	14	
negligible
14.8-17.9

   7.1
   <0.1
   O.9
negligible
    0

    0
    0
   5.5
negligible
  1,365

    0
    0
   5.5
                    5.5
                   5.5
— No data available or estimate was not made.
* Not included in subtotal to avoid 'double counting.'

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                                 Exhibit 1-3. Annual Flow of Mercury in Supply and Manufacturing Sectors
Mercury Sector
Manufacturing (tons/year) Use (tons/year) Disposal (tons/year)
Consumption Product Exports Releases Recycling Domestic Imports Releases Recycling
Source
Supply of Mercury (Discussed in Chapter 2)
Recycling
Net Imports
U.S. Government Stockpiles
Subtotal
Manufacturing Processes Involving Mercury
Chor-Alkali
Electrical Lighting
Thermometers
Thermostats
Switches and Relays
Organic Chemical Production
Dental Preparations
Mercury Compounds
Batteries
Subtotal

430
-83
0
347
(Discussed in Chapter 3)
79
16
9-17
15-21
36-63
—
34-54
—
—
189-250

429 0 1.2 o — - -
-83—0 o — - -
0 ______
346 0 1.2 0 — - -

<0.5 0 27.8 13.04 — — — —
16 2 0.5 1.1 14 3 15 2
9-17 — <0.2 — 9-17 — 9-17 —
11-17 2-3 0 4.1 9-14 4-6 7-10 —
36-63 — 0 0 36-63 — 36-63 —
— — — — — — — —
34-54 0 0 2.5 34-54 — 8.2 —
— — — — — — — —
— — — — — — — —
106-167 4-5 28.26 18.24 102-162 7-9 75-113 2
Estimates are on an annual basis of mercury (short tons per year).

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                  Exhibit 1-4. Annual Flow of Mercury Associated with Incidental Mercury Use
Mercury Sector
Incidental Mercury Use Associated with Coal Combustion
Coal Combustion by Utilities
Lime Manufacturing
Residential/Commercial/Industrial Coal Combustion
Coke Production
Portland Cement Manufacturing
Coal Combustion Wastes
Subtotal
Incidental Mercury Use Associated with Non-coal Sources
Oil Combustion
Carbon Black Production
Gold Mining
Primary Lead and Zinc Mining and Smelting
Primary Copper Mining and Smelting
Pulp and Paper Manufacturing
Oil Refining
Rubber and Plastic Products
Geothermal Power
Wood-fired Boilers
Utility Natural Gas Combustion
Subtotal
Consumption
(tons/yr)
Product Releases
(tons/yr) (tons/yr)
Recycling
(tons/yr)
or Coal Use (Discussed in Chapter 4)
105
2.7-5.0
7.6-21.2
3.2
3.4-5.7
3
125-143
(Discussed in Chapter 5)
0.14
0.11
1,370
0.2
6.4
—
2.2-11.5
—
—
—
—
1,379-1,389
3 88
— 0.2
0 21.8-24.2
0 1.8
0 4.8
0 3
3 120-122

0 8.7-11.8
— 0.28
0 1,348
0 7.8
0 16.4
— —
0.93 —
— —
— —
— —
— —
0 1,380-1,383
0
0
0
0
0
0
0

0
0
21.6
0
0
—
—
—
—
—
—
22
Additional Sources of Mercury Resulting from Disposal or Final Disposition (Discussed in Chapter 6)
Hazardous Waste Combustion
Crematories
Sewage Treatment and Sludge Incineration
Municipal Waste Combustion
Landfills
Medical Waste Incineration
Historical Mining Activities
Subtotal
1
1.4
12
—
—
—
—
14
0 7.1
0 <0.1
0 12
— —
— —
— —
— —
0 19
0
0
0
—
—
—
—
0
Estimates are on an annual basis of mercury (short tons per year).

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                        Exhibit 1-5. Summary of Data Quality for Selected Sectors
Sectors Ranked by Total Releases
Sector Total
(tons/year) Data Quality
Gold Mining
Utility Coal
Combustion
Switches and Relays:
Use and Disposal
Chlor-alkali
Manufacturing
Thermometers: Use and
Disposal
Thermostats: Use and
Disposal
Dental Preparations
Secondary Mercury
Production
Oil Refining
Imports and Exports
U.S. Government
Stockpiles
1,348
88
36-63
27.8
9-17
7-10
8.2
0.5
—
—
—
B
A (air)
B (others)
B (releases)
C (recycling)
B
B (releases)
C (recycling)
B
B
C
C
—
—
Sectors Ranked by Consumption
Sector Total Data
(tons/year) Quality
Gold Mining
Secondary Mercury
Production
Utility Coal
Combustion
Imports and Exports
Chlor-alkali
Manufacturing
Switches and
Relays: Use and
Disposal
Dental Preparations
Thermostats: Use
and Disposal
Thermometers: Use
and Disposal
Oil Refining
U.S. Government
Stockpiles
1,370
430
105
-83
79
36-63
34-54
13-20
9- 17
2.2- 11.5
—
B
B
A
A
A
B
B
B
B
B
—
Sectors Ranked by Reservoir
Sector Total Data
(tons) Quality
U.S. Government
Stockpiles
Chlor-alkali
Manufacturing
Dental Preparations
Switches and Relays:
Use and Disposal
Thermostats: Use and
Disposal
Thermometers: Use and
Disposal
Secondary Mercury
Production
Utility Coal Combustion
Imports and Exports
Gold Mining
Oil Refining
4,850
2,000
1,200
630
230
45-85
—
—
—
—
—
A
B
C
B
B
B
—
—
—
—
—
Data Quality Legend:  A: Expected to be well documented, B: Data available but uncertain, C: Very little data available
                                                      10

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Exhibit 1-6. Review of Data Quality for Selected Sectors
Estimate
Data Source(s)
Review of supporting materials
Data Quality
Secondary Mercury Production
Consumption
Releases
USGS data from
1997
US EPA 1997
Mercury Report to
Congress
1999 TRI
USGS estimate of 430 tons is from latest year available. This value is uncertain and higher than a
conflicting industry estimate. Reassess estimations in 2000 TRI reports when more mercury
recyclers may report.
Air releases estimate from Mercury Report to Congress extrapolation based on 1994 TRI data.
Uncertainty results from changes in facilities and the industry since 1994. Water and solid releases
are uncertain due to low sample size (n = 2). Reassess all estimations in 2000 TRI reports when
more mercury recyclers may report.
B
C
Imports and Exports
Consumption
USGS data for
2000
Estimate from Census Bureau is expected to be accurate. Principle uncertainty is that no data are
available on trade of mercury -containing scrap or waste. Figure based on available trade data.
A
U.S. Government Stockpiles
Reservoirs
US Defense
Logistics Agency
Estimate expected to be accurate, from agency in charge of stockpile management.
A
Chlor-alkali Manufacturing
Consumption
Releases
Reservoir
Chlorine Institute
data for 2000
1999 TRI
US EPA 1997
Mercury Report To
Congress and
Chlorine Institute
(2000 data)
Data are based on a survey of all eleven industry facilities over a 4 year period. Principle
uncertainty is that usage data are variable from year to year, possibly reflecting intermittent use.
Data are based on the response of 13 mercury cell plants representing 96% of total production.
There may be some error associated with plant's ability to measure releases.
Broad estimation predicated on large storage of mercury in plants, mercury cell capacity, and
contamination in pipes, equipment, etc. based on number cells in operation (accurately known) and
quantity of mercury per cell (not accurately known or uniform).
A
B
B
                          11

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  Estimate
 Data Source(s)
                              Review of supporting materials
Data Quality
                                                Thermometers: Use (Rather than Manufacturing)
Consumption
  1997 Bureau of
   Census Data

  US EPA report
    from 1992
regarding mercury
in municipal waste
High-end estimate. The number of thermometers produced, as recorded by the Bureau of Census,
does not delineate data for liquid-in-glass thermometers sold by liquid type. Estimations of mercury
content per thermometer from a 1992 EPA report are expected to be accurate.

Key assumptions: No import or export data available. All liquid-in-glass thermometers contain
mercury.
     B
  Releases
     Same as
  Consumption
    references
Release projections are based on consumption values, which consist of some uncertainties.
Estimation of landfill waste releases (7 -14 tons) similar to prior EPA estimations (16.3 tons in
1989). No estimate for recycling.

Key assumptions'. 80% of thermometer mercury is landfilled and 20% combusted, consistent with
overall municipal solid waste management.
 C (releases)
C (recycling)
  Reservoir
  USEPA 1992b
The validity of this estimate is unclear due to lack of data (e.g. number of mercury thermometers
still in use).

Key assumptions'. Thermometer life-span of 5 years. Mercury consumption is 9 - 17 tons per year.
     B
                                                 Thermostats: Use (Rather than Manufacturing)
Consumption
  1997 Bureau of
   Census Data

  US EPA report
    from 1992
regarding mercury
in municipal waste
The ultimate calculation of this value integrates figures from 3 separate studies (average amount of
mercury per thermostat, number of thermostats produced annually, and percentage of thermostats
exported, imported, and sold domestically). Potentially, the sum of any errors from each study may
be significant, although the largest error is likely to be in the thermostat production data.

Key assumptions'. Even distribution of mercury and non-mercury devices among total thermostats
produced.
     B
  Releases
  US EPA from
   1994 report
The estimate is primarily based on the number of thermostats brought out of service in 1994.  While
this number has certainly changed 7 years later, the largest uncertainty for a present-day estimate is
the quantity recycled, which is unknown.

Key assumptions'. 80% of solid wastes are landfilled and 20% incinerated, consistent with overall
municipal solid waste management.
 C (releases)
C (recycling)
                                                                         12

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  Estimate
  Data Source(s)
                             Review of supporting materials
                                                                                           Data Quality
  Reservoir
 US EPA reports
  from 1992 and
      1994
The estimate is on the low-end since it is based on an estimation of thermostats in use among U.S.
residences only and not commercial or government sites.
                                                                                                B
                                            Switches and Relays: Use (Rather than Manufacturing)
Consumption
 USGS 1997 data

US 1997 Bureau of
    Census data
The USGS estimate of 63 tons excludes mercury reed relays, which typically have a high mercury
content but have unknown production.  The 36 tons/year estimate is based on US DOC data may be
highly variable because it includes non-mercury switches and also excludes mercury reed relays.
Switches and relays, in general, are difficult to track due to the high number of categories used to
describe them.
                                                                                                B
  Releases
     Same as
   Consumption
    references
The total releases were estimated by assuming that outflow equals inflow (disposal = consumption).
No data were available for recycling.

Key assumptions: The amount used in switch and relay manufacturing must eventually be disposed,
with 80% landfilled and 20% incinerated, consistent with overall municipal solid waste
management.
                                                                                            C (releases)
                                                                                           C (recycling)
  Reservoir
USGS 1990 -1997
      data
The estimate is but probably low. USGS estimated the consumption of mercury containing wiring
devices and switches over the period of 1990 to 1997. The 630 ton reservoir figure is the sum of
consumption over these 8 years. Switch life is typically greater than 8 years. Moreover, the data do
not include all types of mercury switches and relays or imports.
                                                                                                B
                                                            Dental Preparation
Consumption
 USGS 1997 data

US Dept. of Health
   and Human
   Services 1993
      study

   1994 literature
      paper
The range provided (34 - 54 tons/year) represents 2 different estimates. The lower estimate of 34
tons / year was provided by USGS (1997), the most recent year available. The higher estimate is
based on the number of fillings and the mercury content of fillings.

Key assumptions: Use of amalgams continued to decrease through time.
                                                                                                B
                                                                        13

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Estimate
Releases
(From Dental
Offices)


Reservoir
(Population)
Data Source(s)
US EPA 1997
Mercury Report to
Congress
1996 research by
Arenholt
1999 DAMS report
Same as
Consumption
references
Review of supporting materials
Estimated releases are probably conservative. Low-end estimates for average mercury in dental
wastewater and the number of dental offices were used. Air releases based on assumption; waste
water releases from single study and conservative estimate of the number of dental offices.
Key assumptions: Two percent of the total amount of mercury used is emitted from spills and scrap.

Very broad estimate based consumption data.
Key assumptions: Twenty to forty year life-span for fillings.
Data Quality
B (releases)
C (recycling)


C
Utility Coal Combustion
Consumption
Releases
1999 EPA ICR and
US EPA 1997
Report to Congress
US EPA Fossil
Fuel Waste
Reports To
Congress in 1998
and 1999
The estimate of mercury into utility coal combustion is based on consumption and sampling data at
over 450 coal-fired utilities during 1999.
Key assumptions: 15% of the mercury present in coal nationwide is removed prior to introduction to
the boiler. This is based on average coal cleaning efficiency from the 1997 Report to Congress.
The approximation of air releases (40 tons/year) is expected to be reliable since it was based on a
large sample of measurements during 1999. Measurements for solid waste are not as extensive
although waste generation quantities are based on relatively recent (1997) facility survey data.
Water releases (7 tons per year) may be understated since generation and / or sampling data are
unavailable for several wastewater sources including: Pile runoff, boiler blowdown, gas-side wastes,
and FGD liquor.
A
A (air)
B (others)
Gold mining
Consumption
and
Releases


1999 TRI


Total releases from gold mining is based on 1999 TRI data submitted by 8 Nevada-based facilities,
which were probably the largest sites but not all of the sites. As smaller facilities report year 2000
releases, the estimate may rise slightly. Reported air emissions are suspected to be based on
estimates and not measurements. Other media releases are of unknown quality.
Consumption estimate is largely based on same uncertainties as the releases estimate.
Key assumptions: Mercury input from trace impurities in gold ore to the gold mining process is
assumed to be equal to the amount released.
B


14

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Estimate
Data Source(s)
Review of supporting materials
Data Quality
Oil Refining
Consumption
and
Products

Releases
1999 sampling
data from
Minnesota and US
DOE Petroleum
Supply Annual for
2000
1999 TRI
The throughput data tabulated by US DOE is highly reliable. The mercury content of crude oil,
however, is variable by nature and the mercury concentration published by Minnesota is based on a
sample size of only two refineries.

Waste releases according to 1999 TRI data appeared to be minimal but were largely unavailable for
most refineries. Only six oil refineries and bulk fuel terminals reported out of approximately 150
facilities.
B

C
15

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                                             Chapter 2
                                       Supply of Mercury
Mercury in  the  United States is supplied by three
sources:  secondary  mercury  production  (recycling),
imports, and a government stockpile.  Presently, the
government stockpile does not actually supply mercury,
but rather represents a source of mercury which must be
managed at some point in the future. Mercury is also
obtained as a byproduct of gold mining, as discussed in
Section 5.3 of this report.

2.1 Secondary Mercury Production
Facilities conducting secondary mercury production may
be classified under one of several different business
classifications:

    SIC Code 2819: Industrial Inorganic Chemicals, Not
    Otherwise Specified (including redistilled mercury)
    NAICS Code 325188: All Other Basic Inorganic
    Chemical Manufacturing

    SIC Code 3341: Secondary Smelting and Refining
    of Nonferrous Metals (except copper and aluminum)
    NAICS  Code  331492:   Secondary  Smelting,
    Refining, and Alloying  of  Nonferrous  Metals
    (except copper and aluminum)

    SIC Code 4953: Refuse Systems
    NAICS Code 562211: Hazardous Waste Treatment
    and Disposal

Secondary mercury production is the production of
mercury  through  processing   scrapped  mercury-
containing materials. Mercury-containing materials that
may be recycled include dental amalgam, spent batteries,
electrical switches, control instruments, thermometers,
spent catalysts from chlorine and caustic soda production
and laboratory and electrolytic refining wastes. These
waste products are sent to mercury recycling facilities,
which then process the waste to produce mercury for
resale.

The production of secondary mercury from scrap began
rising in 1990, as industrial consumption has been
falling.   In 1997, the most recently  reported year,
secondary  mercury production was  430 tons  and
domestic consumption was 381 tons (USGS 2002a).

2.1.1 Mercury Recovery Process
Mercury may  be  recovered  using  two methods:
extractive processes to recover mercury from scrap, and
removal of liquid mercury from dismantled equipment.
The extractive processes may involve either thermal or
chemical treatment;  thermal treatment  is the most
common.   Extractive  processes are used to recover
mercury from scrapped products as well as industrial
solid and liquid waste when liquid mercury cannot be
drained.  Because these methods involve chemical and
thermal  manipulation  of  the  mercury,  extractive
processes are more likely to result in higher mercury
emissions and waste.

Thermal Extractive Process
In thermal extraction processes, mercury-bearing scrap
is heated to  about 538°C (1000°F) to vaporize the
mercury. The mercury vapors  are condensed and the
mercury  is collected under water.  Vapors  from the
condenser are combined with vapors from the mercury
collector line, then purified with an aqueous scrubber to
remove particulate matter (PM) and acid gases such as
HC1 and SO2. Organic matter is removed by passing the
vapor through  a charcoal  filter,  then the  vapor is
discharged to the atmosphere.

Chemical Extractive Process
There  are  several chemical methods  for extracting
mercury from aqueous mercury-bearing waste streams.
Metallic mercury may be precipitated by treating the
waste stream with sodium borohydride or passing the
waste stream through a zinc-dust bed. Mercuric sulfide
may be precipitated using a water-soluble sulfide. Ionic
mercury may be recovered using ion-exchange systems.
Mercuric ions  may  be trapped  with  a chemically
modified cellulose.
                                                  16

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Liquid Removal Process
Liquid mercury may be removed from waste mercury-
containing equipment by dismantling the equipment and
draining the liquid mercury. Mercury recovered through
this process  is distilled to purify the product before
resale.

The liquid removal process is easier and less expensive
than extractive processes, and may be used wherever
liquid  mercury  can  be  effectively  drained  from
equipment.   Because there is no heating or chemical
processing of the mercury under these circumstances,
very little mercury emissions or other mercury waste is
expected to be generated by liquid removal activities.
         2.1.2 Materials Flow
         Exhibit 2-1  illustrates the  consumption, release, and
         product  content of mercury  in secondary  mercury
         recovery.

         Input
         While there are no quantities available for the amount of
         mercury contained in the equipment, scrap, and waste
         sent to the recycling facilities, it was assumed that this
         amount is equal to the  mercury emissions  plus the
         mercury recovered, presented in Exhibit 2-1.
                         Consumption:
                          430tons/yr
Secondary
 Mercury
Production
 Product:
430 tons/yr
                                                         Releases: 0.5 tons/yr
                                                        ^-Air: 0.4 tons/yr
                                                         - Water: 0 tons/yr
                                                         - Disposal: 0.135 tons/yr
                         Sources/a  Mercury Release and Recycling: Air releases from EPA (1997a). Disposal releases
                                  from 1999 TRI data.
                                Mercury in Product: USGS (2002a).
                                Mercury Consumption: Assumed equal to mercury in product and mercury recycled.
                         Exhibit 2-1. Mercury in Secondary Mercury Production
Output
In 1997, an estimated 389 metric tons  (430 tons) of
secondary mercury were produced (USGS 2002a). An
industry source estimates that a much lower quantity of
mercury is produced: 75  to 150 tons (Lawrence 2000).

Another data source is TRI which requires all facilities
to estimate and report the quantity of chemicals recycled
onsite, if any.   Such data for  mercury represents the
quantities actually recovered.  Their most recent data
show that the total quantity recycled onsite is 52.5 tons
(two provided data for 1999).  However, facilities are not
required to  report TRI releases  if they  use less than
10,000 pounds per year, therefore, some releases may
not be  included in these data.
         Due to the uncertainty in the TRI data, the USGS data
         are considered more reliable and complete; these data are
         presented in Exhibit 2-1.

         Air Releases
         Two techniques used for estimating air emissions are
         presented here: the use of facility-aggregated reported
         releases and  the  use of  an  emission factor.   Each
         technique  generates different results, with advantages
         and disadvantages to each.

         The  facility-aggregated approach totals reported air
         releases from all facilities in the industry. Two mercury
         recovery facilities reported air emissions from their 1999
         TRI  data,  totaling  0.003 tons.   This  estimate is
         incomplete because many additional mercury recovery
                                                    17

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facilities did not submit TRI reports.

As a more appropriate alternative, emission factors can
be used to estimate industry-wide emissions, based on
data from a small number of facilities and extrapolated
to the industry as a whole.  This technique was used in
the Mercury Study  Report to  Congress,  where  an
estimate of 0.4 tons was  developed by extrapolating
available air emissions data (using the 1994 TRI as a
source) to the industry as a whole (USEPA 1997a). This
estimate, however, also leads to uncertainty because
some secondary mercury producers claim to not emit
mercury to the atmosphere when they recycle, and it is
difficult to account for this variability among reporters
using available information. The air release estimates
from EPA (1997a), generated using this approach, are
shown in Exhibit 2-1.

Water Releases
Wastewater is generated during the vapor-condensing
phase of thermal extraction.  These liquid wastes are
filtered to remove impurities (such as mercury).  An
industry-wide estimate for mercury releases to water is
not available. TRI data are available from 1999 for two
mercury recovery facilities. No releases were reported
for either facility.  Therefore, this release is shown as
zero in Exhibit 2-1.

Reservoir
Mercury recycling facilities are expected to have State or
federally permitted storage requirements for incoming
wastes.  No information is  available  regarding the
quantities of mercury awaiting recycling by consumers
or other users.

Solid Waste Releases
Solid waste is generated as a byproduct after mercury is
removed from scrap and equipment. Most of this solid
waste is disposed  of in landfills.  A  relatively small
amount of solid waste is sent for further treatment or
recycling to recover metals other than mercury.

Two techniques used for estimating releases to land
disposal are presented here: the use of reported facility-
aggregated releases and the use of a release factor. Each
technique   generates  different   results and   offers
advantages and disadvantages.

Release factors can be used to estimate industry-wide
releases, based  on data from one or two facilities and
applied to the  industry as a whole.    Based  on the
sampling of 'before and after' wastes from mercury
recovery operations of the late 1980s, approximately 98
percent of mercury is  recovered as product with the
remaining  present  in  the  residue  (USEPA  1998a).
Therefore, using this 2 percent loss rate applied to the
1997 production level of 430 tons results in a loss of 8.6
tons.   This estimate may  be high due to improved
process efficiencies in recent years.

Using the 1999 TRI data, two mercury recovery facilities
reported releases to land and to other sites likely to treat
waste prior to  land disposal (e.g., commercial water
treatment, waste brokers). These releases totaled 0.135
tons and are expected to  be low because the estimate
omits other recycling facilities. This quantity is used in
Exhibit 2-1, however, because of the age of the  above
recovery data.

2.1.3 Discussion
There is some uncertainty in the estimated quantity of
mercury recovered in the United States.  The quantity
presented  in  Exhibit 2-1  is based  on USGS  data.
However, one mercury recovery company has indicated
that the USGS data may be a high estimate because of
the practice of extrapolating  results for non-reporting
facilities (Lawrence 2000).

There is some uncertainty in the amount of mercury in
air and  solid waste  releases emissions generated from
secondary mercury  production.  The 0.4 tons per year
cited earlier for air releases is an extrapolated quantity
based on EPA (1997a). However, each of the different
methods of secondary mercury production (thermal
extraction,  chemical extraction, and liquid drainage)
produce widely varied amounts of air emissions.  The
quantity of mercury remaining in the waste residue is
also dependent on the form of mercury and the extent to
which it can be removed from the spent material. The
plants not  reporting emissions data  may be  using a
different combination of recovery processes than the
plants  for which data are  available.   New mercury
recovery facilities open  each year,  so  all aggregate
estimates may be low.  Without detailed knowledge of
how  much  mercury-bearing  scrap,  sludge,   and
equipment  is processed  using  each  method, a truly
representative emissions figure for this sector cannot be
developed. Belter estimates are expected when 2000
TRI data become available in summer 2002 for most
facilities in this industry.
                                                   18

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2.2 Imports and Exports
Mercury-containing  materials are  imported to and
exported from the United States. Such materials include
elemental mercury, mercury-containing scrap or waste
for disposal or  recovery,  and  mercury-containing
products such  as  fluorescent lamps.   No  data are
available for the trade of scrap or waste, while the trade
of  mercury-containing  products  is  discussed  in
subsequent chapters for each particular product.  Data
for the trade of elemental mercury are presented here.

USGS reported that 113 tons of mercury were imported
and 196 tons of elemental mercury were exported in
2000 (USGS 2002a), resulting in a net export of 83 tons.
Principal trading partners include Australia and Germany
(sources of imported  mercury)  and  India  and the
Netherlands (destinations for exported mercury) (USGS
2000a).

2.3 U.S. Government Stockpiles
The U.S. Government has previously purchased mercury
for the National Defense Stockpile to satisfy contingency
requirements for national emergencies.  A total of 4,850
tons are presently being stored in five  locations in the
eastern United States. Note that this cannot be directly
compared to the other supply  sources because this is a
'one-time'  quantity  while  the  others  are  annual
quantities.

There has been no need for  stockpiled mercury as a
national security requirement,  and sales of this material
have been suspended  since 1994. Therefore, mercury is
not presently being  added to or removed  from the
stockpile.   The Defense Logistics Agency,  which is
responsible  for maintaining the  stockpile, is in the
process  of preparing an environmental impact statement
to examine alternatives for stockpile management.  At
present, these alternatives include no  action, and the
consolidation of supply,  sales,  and  disposal  (DLA
2002).   Identification and  implementation  of  an
alternative will likely take a minimum of several years.

U.S. government stockpiled  mercury is being  stored
with  no  transport  or processing presently  being
conducted.  The only  potential releases are  from the
storage.  Such  releases are expected to be  minimal
because no handling occurs.

2.4 Miscellaneous Government Uses
Another U.S. government mercury reservoir is  in the
Spallation Neutron Source research center; this DOE
facility uses elemental mercury as the target for the
neutron (SNS 2002).  Because this is a new projected
use, reduction opportunities are not considered.  The
facility is expected to begin operating in 2006.
                                                   19

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                                             Chapter 3
                        Manufacturing Processes Involving Mercury
3.1 Chlor-Alkali Manufacturing
3.1.1 Introduction
Facilities producing chlor-alkali are classified under the
following business classifications:

       SIC Code 2812: Alkalies and Chlorine

       NAICS Code  325181: Alkalies and Chlorine
       Manufacturing

More mercury is used in chlorine and  caustic soda
manufacturing than in  any other industrial sector in the
United States. The SIC Code 2812 and NAICS Code
325181  describe  all industries primarily  engaged in
manufacturing alkalies (e.g., NaOH) and chlorine (C12).
Chlorine and alkali manufacturing are linked because of
a shared production process.  Electrolysis separates the
sodium and chlorine in salt brine (NaCl), producing 1.1
tons of caustic soda for every ton of chlorine.  Since
chlorine cannot be economically stored or moved over
long distances, chlor-alkali facilities are often located
near industries that require chlorine.  The two largest
industries for chlorine are vinyl chloride  monomer
manufacturing and pulp and paper manufacturing (Kirk-
Othmer 1991).

There are three electrolytic methods used in chlor-alkali
production: diaphragm cell, mercury cell, and membrane
cell production. Although all new chlor-alkali facilities
being built use either membrane cell or diaphragm cell
technologies - processes that do not use mercury  -
several chlor-alkali facilities still use the mercury cell
process.   In  the  United  States,  mercury cell plants
account for 10% of the chlorine production capacity;
production takes place at 11  facilities using mercury
cells (Chlorine Institute  2001 and  ChemExpo 2000).
One advantage of the mercury cell process is that it
produces a low-salt caustic soda and it is much easier to
scale production levels of chlorine and  caustic soda
based upon demand (Genna 1998).
Unlike the diaphragm cell and membrane cell processes,
which are one-step processes, the mercury cell process is
a two-step process: an electrolyzing stage produces the
chlorine gas and a decomposing  stage produces the
caustic soda (USEPA 1997a). Flowing at the bottom of
the cell, a few millimeters below the suspended metal
anode, the mercury acts as the cathode in the electrolytic
process.  Each cell may  contain three tons of mercury
(USEPA 1997a), and through most of the 1990s there
were a total of 762 mercury cells  (Chlorine  Institute
2001).  An aqueous salt brine solution (NaCl) flows
between the anode and the cathode, releasing chlorine
gas at the anode.  The remaining sodium and mercury
amalgam  flows  from  the   electrolyzer  cell  to  the
decomposing cell, which separates the mercury from the
sodium that produces sodium hydroxide  (NaOH) and
recycles the mercury back to the electrolyzer cell (Kirk-
Othmer 1991).

3.1.2 Materials Flow
Exhibit  3-1 illustrates the consumption,  release,  and
product content of mercury  in chlor-alkali production.
The environmental release estimates in Exhibit 3-1 are
based on 1999 Toxic Release Inventory (TRI) mercury
release data for 13 of the 14 plants operating in that year.
Mercury use data are based on data from the Chlorine
Institute (2001); mercury in products is  estimated as
described below.

The calculation does not match the amount consumed
with the total amount released. It is unknown why there
is a discrepancy between  consumption  and release.
Studies are being conducted by EPA to find out where
the missing mercury goes. One explanation could be that
the consumption is from the Chlorine Institute and the
release data is from TRI.
                                                  20

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Mercury Consumption
Exhibit 3-2 shows estimates of mercury consumption
for several years along with mercury release data. The
Chlorine  Institute's  (2001)  estimate  of mercury
consumption from the domestic chlor-alkali facilities
decreased from 222 tons in 1990 to 79 tons in 2000.
The Chlorine Institute also  provided  estimates  of
mercury purchases by the chlor-alkali facilities. On a
year-to-year   basis,  mercury  purchases  did  not
necessarily equal mercury use.
               However, over a multi-year period, mercury purchases
               were roughly equivalent to mercury use.  Chlor-alkali
               facilities may purchase  more  mercury than they
               anticipate using, storing the excess mercury for later
               use (Dungan 1999).  The 2000 consumption estimate
               is used in Exhibit 3-1.

               Air Releases
               Air releases of mercury from chlor-alkali production
               result from elevated process temperatures.  The heat
               generated by the electrolysis process used to
                          Consumption:
                            79tons/yr
Chlor-Alkali
Production
  Product:
 <0.5 tons/yr
(caustic soda)
                                                            Releases: 27.8 tons/yr
                                                            - Air: 6.3 tons/yr
                                                           --Water: 0.073 tons/yr
                                                            - Disposal: 21.5 tons/yr
                                                            Recycling: 13.04 tons/yr (offsite)
                         Sources:   Mercury Consumption: Chlorine Institute (2001).
                                 Mercury Release and Recycling: 1999 TRI data.
                                 Mercury in Product: Estimated from production capacity (Chlorine Institute 2001) and product
                                  concentration (WLSSD 1997).
                             Exhibit 3-1. Mercury in Chlor-Alkali Manufacturing
      Exhibit 3-2.  Chlor-Alkali Mercury Cell Process Mercury Used, Emitted, Recycled, and Disposed
Quantity (tons)
Total Mercury Used1
Total Mercury Air Emissions 2
Total Mercury Water Emissions 2
Total Onsite Mercury Recycling 2
Total Offsite Mercury Recycling 2
Total Mercury Disposal2
Total Mercury in Caustic Soda3
1990 1991 1992 1993 1994 1995 1996 1997 1998
222 175 148 104 146 165 137 118 104
7.3
0.1
469
8.2
7.2
0.6
1999
88
6.3
0.07
374
13
21.5
0.6
2000
79
-
-
-
-
-
-
1 Source: Chlorine Institute (2001 ).
2 Source: 1999 TRI data for 13 of 14 chlor-alkali facilities using the mercury cell process.  These thirteen facilities represented 96 percent of the total
production capacity, signifying that the reported releases are an excellent estimate of industry-wide releases.
3 Source: Estimated; represents high estimate of mercury likely to be in product.  See text.
This table does not summarize environmental release data from the TRI prior to 1998.
                                                         21

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separate the chlorine from the salt brine contributes to
mercury volatilization (Johnson 1999).  There are three
primary sources of mercury air emissions at a mercury
cell chlor-alkali facility: (1) byproduct hydrogen steam,
(2) end box ventilation air, and (3) cell room ventilation
air (USEPA 1997a). Ventilation systems and scrubbers
reduce the amount of mercury emitted to the atmosphere.
The mercury is transferred to water or to solid waste,
where it may be  recycled or disposed.  As shown in
Exhibit 3-1, industry-wide air releases are estimated at
6.3 tons based on  1999 TRI data.

Water Releases
Releases of mercury-containing water result from the
large quantities of water used in the electrolysis process.
Mercury is also found in the wastewater and brine of the
mercury  cell process. Some mercury is found in the
water collected from the periodic wash-down of floors
and equipment.  As shown in Exhibit 3-1, industry-wide
water releases are estimated as 0.07 tons based on 1999
TRI data.  The estimate represents the mercury  content
in waters discharged to a surface water or to a publicly
owned treatment works (POTW).

Solid Waste Releases and Recycling
Wastewater treatment sludges from chlor-alkali facilities
were routinely  landfilled until  1992,  when USEPA
banned the  landfilling of certain mercury-containing
sludges   (USEPA 1988b). Because of the restriction,
many mercury  cell  facilities  now use  retort  and
hydrometallurgical processes to remove the mercury
from their wastes prior to landfilling and  recycle the
recovered mercury back into the mercury cell process
(USEPA 1998a).   As shown in Exhibit 3-2,  a large
quantity of mercury is recycled onsite.  (However,  it is
not possible to identify how  each facility reported this
quantity, and a portion of the  quantity may represent
mercury that is continuously re-inserted back into the
process when using mercury  as a catalyst.)  This onsite
recycling is not accounted for as recycled quantities in
the summary of Exhibit 3-1 because it is internal to the
industry,  rather than being sent to  a  commercial
recycling facility such as those discussed in Section 2.
As shown in Exhibit 3-1, industry-wide land disposal
releases are estimated as 21.5 tons based on 1999 TRI.

Product
Because mercury  has a high vapor pressure at  normal
operating conditions, mercury is found in trace amounts
in the reaction products (chlorine and caustic soda). No
estimates of mercury content in chlorine gas were found.
In 1987, a Wisconsin wastewatertreatment district found
that  caustic  soda (sodium hydroxide)  can contain
mercury ranging from  10 to 300 parts per billion
(WLSSD 1997).  The Chlorine Institute  identified an
average level of 100 parts per billion, based on  1995
survey data (Chlorine Institute 2000).

Using  conservative  assumptions,  the industry-wide
mercury content of caustic soda is estimated as no more
than 0.5 tons per year. These assumptions include using
the upper end of the mercury concentration range of 300
parts  per  billion,  and  estimating  annual  sodium
hydroxide production of 1.7 million tons per year (which
is equivalent to the capacities for mercury cell facilities
reported in Chlorine Institute (2001)). This  estimate
assumes no mercury contributions from other processes.
Such contributions are  possible at facilities where the
mercury cell  process was replaced but where residual
mercury may still be present.

Reservoir
A considerable quantity of mercury is present inside a
chlor-alkali facility.  This is partly due to the function of
mercury as a catalyst; as discussed above, each cell may
contain three tons of mercury (USEPA 1997a) and there
were 762 cells operating for most of the 1990s prior to
the most recent closures (Chlorine Institute 2001). An
industry source estimates  that a  single plant  holds
between 75 and 750 tons of mercury, which would be
available to the secondary market upon dismantling of
the plant (Lawrence 2000).  Additional mercury is also
expected to be present within pipes, equipment, etc., as
an amalgam, which may not be easily  recoverable.
Based on these data, this report estimates that at least
2,000 tons of mercury is  present at operating and
recently closed chlor-alkali production facilities.

3.1.3 Discussion
There is an apparent discrepancy between the mercury
consumed by the chlor-alkali industry and the mercury
emitted. Mercury consumed by the chlor-alkali industry
is  used  to replenish production losses.   However,
mercury consumption is much larger than the reported
mercury emissions (Johnson  1999), and  the mercury
contained in  the product is not a significant fraction.
Therefore, approximately 50 tons of mercury appear to
be "missing" based on the  1999/2000 data.  There is
increasing concern among state and federal regulators
regarding this "missing mercury" (Johnson 1999). Olin
Corporation, a major chlor-alkali producer, is working
with USEPA to eliminate mercury discharges from its
                                                   22

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two mercury cell chlor-alkali facilities (Johnson 1999).
The head of Olin Corporation is urging the chlor-alkali
industry to develop better  methods to measure and
control fugitive mercury emissions (Johnson 1999).

Data for 2000 mercury consumption were provided by
the Chlorine Institute. USGS has not reported mercury
usage statistics since 1997.  Historically, USGS and
Chlorine Institute data have differed.  For example, the
quantity of mercury consumption in 1995 as provided by
the Chlorine Institute, 165 tons, is slightly lower than the
quantity of mercury consumption  in 1995 provided by
USGS, 170 tons.   This discrepancy  is  even more
apparent when comparing 1997 data (118 tons Chlorine
Institute vs. 176 tons USGS).  The  USGS data may
include  extrapolations  for non-respondents.    The
Chlorine   Institute  is   actively  tracking  mercury
consumption at the plants using the  mercury cell process.

3.2 Lamp Manufacturing, Use, and Disposal
3.2.1 Introduction
Facilities manufacturing lamps and lighting equipment
may  be   classified   under  the  following  business
classification:
       SIC Code  3641:
       Tubes
Electric Lamp Bulbs and
       NAICS Code 33511: Electric Lamp Bulb and
       Part Manufacturing

SIC Code 3641 and NAICS Code 33511 are comprised
of establishments primarily engaged in manufacturing
electric bulbs, tubes, and related light sources. Mercury
is  a  key component of fluorescent  lamps and  high
intensity  discharge (HID)  lamps (including mercury
vapor, metal halide, and high pressure sodium lamps).
Fluorescent lamps are widely used for indoor lighting in
businesses and increasingly in residences, while  HID
lamps are used for heat lamps, film projectors, dental
exams, photochemistry, water purification, and street
lighting.  When an electrical current passes through
mercury vapor, it emits ultraviolet light. In a fluorescent
lamp, this ultraviolet light is converted into visible  light
when it excites the phosphorus coating inside the tube,
causing it to fluoresce.

The mercury content in fluorescent bulbs in the  United
States has  steadily decreased during the past  two
decades.  In 1989, the average mercury content in  a
fluorescent bulb  was  48.2  mg  (USEPA  1999a),
decreasing to 11.6 mg in 1999 for a typical four-foot
lamp   (NEMA  2000).   In  1995,  Philips Lighting
introduced a low-mercury fluorescent lamp containing
only 4.4  mg of mercury (USEPA 1999a).   OSRAM
Sylvania  introduced a  mercury-free high intensity
discharge (HID) lamp in  1998 (Sylvania 1998).

3.2.2 Materials Flow
Exhibit 3-3 illustrates the consumption,  release, and
product  content  of mercury  in electrical lighting,
spanning  manufacturing,  use, and final disposal.

3.2.3 Manufacture
Mercury use in lamps depends on the quantity of lamps
manufactured and the mercury  content of  the bulbs.
Philips Lighting estimates that low-mercury lamps
constitute 85% of its current lamp production and that
they have reduced their mercury use by 13 tons per year
(USEPA  1999a).  Similar production information from
other  manufacturers  was  not  available.   OSRAM
Sylvania  estimates that introduction of their mercury-
free HID  lamp should reduce mercury consumption by
0.17 tons per year (Sylvania 1998).

Mercury  Consumption
As  shown in Exhibit  3-4, mercury  consumption by
domestic  lighting manufacturers has declined from  a
peak of 61 tons per year in 1992 to about 32 tons per
year in 1997, based on data from USGS.  While these
data are useful for identifying trends, the USGS estimate
is not reflected in Exhibit 3-3. Instead, a lower estimate
of 16 tons based on data from the Bureau of Census and
the  National  Electrical  Manufacturers  Association
(NEMA)  was used.   The NEMA estimate was used
because it is based on more recent lamp  composition
data and, due to uncertainties  with the  USGS data
identified in  Section   3.1,   the  USGS  data may
overestimate actual use.

The U.S.  Department of Commerce's Bureau of Census
(USDOC 1995) estimates that 599 million fluorescent
lamps and 28.5 million HID lamps were produced in the
United States in 1994. Assuming an average mercury
content of 11.6 mg  of mercury per  fluorescent lamp
(NEMA  2000) and  25  mg per HID lamp (USEPA
1992b), lamp  manufacturing  consumed  16 tons of
mercury in 1994.  The quantity was used as an estimate
for present day usage.

In 1994, the Census Bureau stopped collecting data on
lamp  production.   Based  on  National  Electrical
                                                 23

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Manufacturers  Association  (NEMA)  data,  lighting
system sales increased from $7.8 billion to $8.4 billion
in  1997 (NEMA  1999),  an  increase  of  8  percent.
Therefore, the 1994 Bureau of Census estimate of 599
million  fluorescent lamps manufactured in  the United
States appears to be a reasonable estimate for 1997.
                                Releases
                                Mercury can be released during transfer and parts
                                repair, mercury handling, mercury injection into the
                                lamps, accidents, and spills (USEPA 1997a). Two
                                lamp manufacturing companies submitted TRI reports
                                for 1999, reporting the release of 0.26 tons of mercury
                                to the
           Consumption:
            16tons/yr
   Lighting
Manufacturing
 Product:
16tons/yr
                                                                             Exports:
                                                                             2 tons/yr
                                                                            Domestic Use:
                                                                              14 tons/yr
                                              Releases: 0.46 tons/yr
                                              - Air: 0.26 tons/yr
                                             • - Water: Not Available
                                              - Disposal: 0.2 tons/yr
                                              Recycling: 3.7 tons/yr (off-site)
Domestic:
1 4 tons/yr
^-
^-
Imports:
3 tons/vr

Use
(66-75 tons
in use)
                                                       17 tons/yr
                                                      (4 year lag)
                                              Disposal
                                                                                         Releases: 14 tons/yr
                                                                                         - Air: 3 tons/yr
                                                                                        "- Disposal: 11 tons/yr
                                                                                         Recycling: 3 tons/yr
             Sources:n  Mercury Consumption: Extrapolated from the Bureau of Cencsus (DOC 1995), NEMA (2000), and EPA(1992b).
                     Mercury in Product: Extrapolated from lamps sold and exported (DOC 1995), lamps imported (EPA 1999b), and mercury content (NEMA 2000).
                     Mercury Release and Recycling: 1999 TRI data for manufacturing.
                     Exports and Imports: Bureau of Census (DOC 1995).
                     Emissions for Use: Recycling rate from NEMA (2000). Air and land disposal extrapolated using EPA(1997c).
                                    Exhibit 3-3.  Mercury in Electrical Lighting
                               Exhibit 3-4.  Lighting Industry Mercury Consumed
                                                    1990    1991    1992     1993    1994     1995
                                                                          1996    1997
 Total Mercury Consumed1 (tons)
                      36
     43
61
42
30
33
32
32
'Source: United States Geological Survey, Mineral Industry Surveys 1990-97
                                                           24

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air and 3.7 tons recycled. Releases from these facilities
are larger than the industry-wide estimate of 0.06 tons
in the Mercury Report to Congress (USEPA 1997a).
TRI data for these manufacturers are used in Exhibit 3-3.
This estimate may be low due to the small number of
facilities, but extrapolating to  a larger population is
difficult due to a lack of facility-specific information.

Exports
An estimated 68 million fluorescent lamps and 4 million
HID lamps were exported in 1994 (USDOC 1995). This
is approximately 1.8 tons of mercury (using the mercury
content assumptions above). This number is used in
Exhibit 3-3.

3.2.4 Use
Mercury Consumption
Of  the   nearly  600   million  fluorescent   lamps
manufactured in the United States in 1994, 517 million
lamps  were sold domestically; the remainder were
exported or stayed in inventory (USDOC 1995).  An
additional  100 million fluorescent lamps containing an
estimated 2.5 tons of mercury were imported in 1995
(USEPA 1999b). Therefore, approximately 620 million
fluorescent lights were sold  in  the  United  States
containing 16 tons of mercury.

Of the 29 million HID lamps manufactured in 1994, 25
million  were  sold domestically; the remainder were
exported or remained in inventory (USDOC 1995). An
additional   3.5  million HID  lamps  containing  an
estimated 0.1 tons of mercury were imported in 1995
(USEPA 1999b). Therefore, approximately 29 million
HID lamps (0.8 tons of mercury) were sold in the United
States in 1994. The total quantity of mercury consumed
from  lighting  (17 tons in  Exhibit 3.3) reflects  the
combination of fluorescent  lamps (16 tons)  and HID
lamps (1 ton).

Reservoir
Assuming a 20,000-hour lifespan for fluorescent lamps,
these lamps should last about four years.  Assuming the
620 million lamps sold each year are  replacing one-
fourth of the lamps in use, there were between 2.5 and 3
billion fluorescent bulbs in use in 1997, constituting 65
to 75 tons of mercury throughout  the  United  States
(assuming 11.6 mg of mercury per lamp).

Because HID lamps typically  have a usable life of
10,000 hours and most are used  24 hours per day,
USEPA (1992b) assumed that HID lamps are replaced
annually.    Therefore,  all  29  million  lamps  are
replacement lamps  and they contained 0.8 tons of
mercury (assuming 25 mg of mercury per lamp).

3.2.5 Disposal
Since fluorescent lamps have a lifespan of about four
years, the quantity of mercury used in lamps today does
not reflect the  quantity of mercury being  disposed.
Instead, there is a four year lag from initial use to
disposal. The estimated 620 million fluorescent lights
purchased in 1994 probably entered the waste stream in
1997 - 1998. The 29 million HID lamps sold that year
probably entered in 1995. Together, they equal about 17
tons of mercury removed from service in 1997.

Until 1995, most fluorescent lights were disposed of as
municipal  solid waste  (MSW).   USEPA  (1992a)
estimated in 1992 that 82 percent of mercury-containing
lamps were landfilled, 16 percent were incinerated, and
2 percent were  recycled.   The number of companies
collecting  lamps for recycling has increased since the
early 1990s to more than 60 companies.  More recent
estimates by the Association of Lighting and Mercury
Recyclers  state that the recycling rate in the late 1990s
was 15 percent  (NEMA 2000). Assuming rates of 15
percent recycled, 67 percent landfilled,  and 18 percent
incinerated (consistent with USEPA 1997c percentages
of wastes that are landfilled and incinerated), this results
in 11 tons that entered landfills, 3 tons incinerated, and
3 tons recycled.

The mercury lamp recycling rate is expected to continue
to increase due to changes in USEPA's universal waste
rule in June 1999.  In  this  rule,  USEPA  streamlined
recycling   requirements   for  mercury-containing
fluorescent, mercury  vapor, sodium halide, and metal
halide lamps that exceed mercury concentrations set by
USEPA's  Toxicity Characteristic Leaching Procedure
(TCLP) test.  A  goal  of this rule is to  encourage
recycling by making it easier for generators to collect,
store, and transport bulbs destined for recycling (USEPA
1999c).

3.2.6 Discussion
The quantity of mercury consumed for production was
assumed to equal the quantity estimated  to be present in
domestically manufactured  products (16 tons).  This
estimate was used instead of the much greater Bureau of
Mines (USGS 1997) estimate for mercury consumption
of 32 tons in 1996.  Therefore, this represents a source of
uncertainty because additional methods  to verify either
                                                  25

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of these estimates are not available.

The  quantity of mercury in lamps is  expected to
decrease, but based on current research, elimination in
fluorescent lamps is not expected. As a result, future
releases of mercury will decrease slightly.

A second  source of uncertainty is the extent to which
mercury in post-consumer lamps is currently recycled.
The  recycling  rates are expected to increase due to
regulatory changes such as the 1999 regulatory changes
by USEPA. Therefore, the quantities ultimately recycled
and disposed by commercial, industrial, and consumer
users are uncertain.

3.3 Thermometers and Other Instruments
3.3.1 Introduction
Facilities  manufacturing  thermometers  and  other
instruments  may be classified  under the following
business classifications:

        SIC Code  38295:  Commercial,  geophysical,
        meteorological,   and  general  purpose
        instruments. Applicable SIC (Product) Codes
        are as follows :

   Barometers:
        20 - Barometers
   Liquid in glass thermometers:
        22 - Scientific thermometers
        23  -   Industrial   thermometers  (food,  air
        conditioning, and refrigeration)
        24 - Household and commercial thermometer
        34 - Medical thermometer

   NAICS  Code   339112:   Surgical  and  medical
   instrument manufacture.

   NAICS  Code   334519:   Other  measuring  and
   controlling device manufacturing.

Mercury  is often  used  in   medical  and  scientific
instruments  because it  is non-reactive, metallic,  and
liquid over a relatively wide range of temperatures.  The
most common use of mercury as a medical and scientific
instrument  is   in  the  liquid-in-glass  thermometer.
Mercury is also  used in instruments such as barometers
and  other pressure-sensing devices.   Liquid-in-glass
thermometers  are  commonly used for household,
industrial, clinical,  and scientific purposes.  The U.S.
Census  Bureau  provided estimates  for each of these
classes of thermometers bought and sold in the United
States in 1997 (USDOC 1998). The Census Bureau did
not distinguish between mercury-filled thermometers and
those filled with other liquids, nor did they provide an
estimate  for  thermometer   imports  and   exports.
Therefore, estimates for mercury  use based on these
Census  quantities  are likely to  overestimate actual
quantities  of mercury consumed.   USEPA (1997a)
expects mercury use and emissions from thermometers
to remain steady, with decreases resulting from digital
thermometers to be offset by increased demand for
thermometers by a growing population.

3.3.2 Materials Flow
Exhibit  3-5  illustrates the consumption,  release, and
product content of mercury in thermometers and similar
instruments in manufacturing, use, and final disposal.

3.3.3 Manufacturing
Mercury Consumption
USEPA  (1992b)   identified  that  oral/rectal/baby
thermometers contained 0.61 grams mercury, and basal
thermometers contained 2.25 grams mercury. They also
estimated that 95 percent of clinical thermometers are
oral/rectal/baby thermometers and basal thermometers
comprised the remaining  five percent. USEPA (1992b)
did not provide an estimate of mercury  content for
scientific and industrial  thermometers; therefore, the
mercury content of these instruments were assumed to be
equal to the quantity present in basal thermometers.

The U.S. Bureau of Census estimates that approximately
8.5 million medical and household thermometers (valued
at $12.2 million,  or $1.44  each) and 0.58 million
industrial thermometers  (valued at $10.2 million, or
$17.60 each) were bought and sold in the United States
in 1997 (USDOC 1998).  The Bureau of Census did not
provide  an  estimate   for  scientific  thermometer
production, but did provide an estimated value of $5.8
million.  Assuming that each scientific thermometer
costs between $1.44 and $17.60 (derived from the other
thermometer types), an estimated 0.33 to 4.0 million
scientific thermometers were bought and sold in the
United States in 1997. The Bureau of Census also did
not  specify  whether  these  thermometers  were
manufactured  domestically  or  imported,  although
USEPA (1992b) states that thermometer imports  have
been increasing and assumes that exports are minimal.
                                                  26

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               Consumption:
               9-17 tons/yr
Thermometer
Manufacturing
  Product:
9-17 tons/yr
                                                  Releases: <0.2 tons/yr
                                                  - Air: <0.2 tons/yr
                                                 - - Water: 0 tons/yr
                                                  - Disposal: 0 tons/yr
                                                  Recycling: 0 tons/yr
                     Domestic:
                    9-17 tons/yr
                      Imports:
                   Not Estimated
                                        Use
                                    (45-85 tons
                                       in use)
                        9-17 tons/yr
                        (20 year lag)
                                                                                    Exports:
                                                                                 Not Estimated
                                                                                 Domestic Use:
                                                                                  9-17 tons/yr "
                       Disposal
                                                                                             Releases: 9-17 tons/yr
                                                                                            _-Air: 2-3 tons/yr
                                                                                             - Disposal: 7-14 tons/yr
                                                                                             Recycling: Not Available
                    Sources:n  Mercury Consumption: Calculated from USDOC (1998) and USEPA (1992b).
                            Mercury Releases: Air releases during manufacturing from USEPA (1997a). Other releases from general waste management data from
                             USEPA (1997c).
                                      Exhibit 3-5.  Mercury in Thermometers
                 Exhibit 3-6. Mercury Used to Manufacture Thermometers in the U.S. in 1997
          Thermometer Type
             Quantity Manufactured1
                       Mercury Content per    Total Mercury
                           Thermometer             (tons)
                             (grams)2
 Medical and household thermometer -
 Basal
                           425,000
                                 2.25
1.05
Medical and household thermometer -
Oral/rectal/baby
Industrial thermometers
Scientific thermometers
Total
8,100,000
583,000
330,000 to 4,000,000
8,300,000 to 11,900,000
0.61
2.25
2.25
-
5.45
1.45
0.74 to 9.0
8.7 to 17.0
1 U.S. Census (USDOC 1998), estimate for scientific thermometers is extrapolated from dollar value (see text).
2USEPA (1992b), mercury content for household thermometers is assumed to be same for oral/rectal/baby thermometers, mercury content for industrial and
basal thermometer is assumed to be same as basal thermometers.
                                                             27

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Product
For an upper-end  estimate using Bureau of Census
(USDOC  1998) data of liquid-in-glass thermometers
bought and sold in the U.S. and USEPA (1992b) data for
mercury content, Exhibit 3-6 shows that about 9 to 17
tons of  mercury  were contained in  thermometers
produced in the United States  in  1997 (assuming no
imports and that all liquid-in-glass thermometers are
mercury-filled). This quantity is high because it assumes
that all liquid-filled thermometers contain mercury.

Releases
Mercury  thermometers are produced  by creating  a
vacuum in the capillary glass tube to draw mercury into
the bulb and glass tube.  USEPA (1997a) cites a  1973
USEPA estimate of 18 pounds of mercury emitted for
every ton of mercury used in instrument manufacture.
However, USEPA  (1997a) warns that this estimate is
based on a survey of manufacturers during the 1960s and
may be an overestimate of actual emissions. Using the 9
to 17 ton consumption estimate above, approximately
160 to  300 pounds (0.08 to 0.15 tons)  of mercury are
emitted to the  air as a result of mercury thermometer
manufacturing. Thermometer manufacturers reported no
mercury releases to any media in the 1999 TRI.

3.3.4 Use
Using an estimated lifespan of 5 years (USEPA 1992b)
and an annual production rate of 9 to 17 tons per year (as
described in the manufacturing section), it is estimated
that 45 to 85 tons  of mercury are currently in use in
thermometers in the United States. Because the mercury
is completely contained in the thermometer, release and
exposure to the  mercury are unlikely  under normal
operating conditions.

3.3.5 Disposal
USEPA (1997a) reports that there is little data regarding
mercury  disposal.  Most thermometers are discarded
when they are cracked or broken and enter the waste
stream  from residential and clinical settings (USEPA
1997a). USEPA (1992b) estimates that five
            percent of the glass thermometers are broken each year.
            USEPA (1997a) cites a 1989 study that estimated that
            16.3 tons of mercury were discarded in landfills from
            thermometers.  It can be assumed that the quantity of
            mercury used in thermometer production (9 to 17 tons
            for 1997) requires  eventual recycling or  disposal.
            Assuming 80 percent is landfilled and 20 percent is
            combusted   (based   on  typical  municipal   waste
            combustion  rates), 7 to 14 tons are expected  to  be
            disposed to land and 2-3 tons are expected to be emitted
            to the air via combustion.

            Increasing awareness regarding recycling  of mercury
            thermometers has lead to programs such as Fisher
            Scientific's mercury thermometer trade-in program that
            offers to reclaim a mercury thermometer for every non-
            mercury thermometer ordered (Fisher Scientific 1999).
            Because of these recycling programs, disposal estimates
            may be high; there  is no estimate available for the
            amount of mercury recycled from thermometers.

            3.3.6 Discussion
            The quantity of mercury in thermometers was estimated
            at 9 to  17 tons for  1997,  based  on Department of
            Commerce   data  addressing   domestic  sales   of
            thermometers.  Because all of the thermometers were
            assumed to  be  mercury-filled, this  was  intended to
            represent a high estimate for mercury consumption. The
            only other estimate is USGS data. As shown in Exhibit
            3-7, 26 tons of mercury  were used  in  1997  for
            'measuring and control instruments,' which is intended
            to include both mercury thermometers and thermostats
            (Reese 1999).

            No estimates for other values could be found, so the
            remaining quantities on Exhibit 3-5 were calculated from
            this consumption quantity.   Also, mercury  recycling
            facilities are known  to  accept  thermometers  for
            recycling, but quantities are not available. Therefore, the
            quantities presented in Exhibit 3-5 as ultimately recycled
            and disposed are uncertain.
    Exhibit 3-7. Mercury Consumption by SIC Code 382 - Measuring and Control Instruments (tons)
                                        1990    1991     1992     1993     1994    1995     1996    1997
 Total Mercury Used1
119
99
72
58
47
45
26
'Source: USGS (1990-7)
                                                  28

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3.4 Thermostats
3.4.1 Introduction
Facilities manufacturing thermostats may be classified
under the following business classification:

    SIC Code 3822: Controls for Monitoring Residential
    and  Commercial  Environments  and  Appliance
    Regulating Controls.

    NAICS Code 334512:  Automatic Environmental
    Control Manufacturing for Residential, Commercial,
    and Appliance Use.

A thermostat is a type of switch that turns on or off
depending on the temperature. Thermostats are used to
control the temperature in individual rooms, building
spaces, appliances, and refrigerators.  Mercury switch
thermostats have been commonly used to control room
temperatures in commercial and residential spaces for
more than 50 years (USEPA 1994), although mercury-
free alternatives are available.  Typically, a mercury
switch is mounted on a piece of bimetal.  Bimetal is
composed of a  strip  or  coil of two  thin layers of
dissimilar metals that bend at different rates when heated
or cooled. As the bimetal bends with the temperature
change, a drop of mercury in a tube within the mercury
switch moves under force of gravity to either complete
or break an electrical circuit. Mercury thermostats have
proven to be an accurate,  reliable, and inexpensive
means to control temperature (USEPA 1994).

3.4.2 Materials Flow
Exhibit  3-8  illustrates the consumption, release, and
product content of mercury in thermostats during
manufacturing, use, and final disposal.

3.4.3 Manufacturing
Mercury Consumption
Manufacturing of mercury switch thermostats consists of
filling a short glass tube with a bead of mercury and
sealing one end with wire contacts. There is little data
available on mercury consumption in the manufacturing
of thermostats. Using U.S. Bureau of Census data and
consultations with thermostat manufacturers, USEPA
(1994) estimates that  3 to  5  million mercury switch
thermostats  were manufactured in 1994.   USEPA
(1992b) estimates that each thermostat contains about 3
grams of mercury, therefore 11 to 17 tons of mercury are
used to produce thermostats annually.

The U.S. Census Bureau (USDOC 1998) estimates that
45 million thermostats were manufactured in the United
States in 1997, but some of these units may not contain
mercury. Exhibit 3-7 shows the USGS estimates for
domestic industrial consumption of mercury for SIC
Code 382, which includes thermostat and  thermometer
manufacturing.    Export data  on  mercury  switch
thermostats were not available.

Review of the  1999 TRI data shows four facilities
involved in electronic component manufacturing (SIC
Code 3679) reporting mercury releases; it is not known
for certain whether  these  releases are  a result of
thermostat manufacturing (as opposed to switches or
other products produced by the facility). Mercury may
be emitted during the manufacturing process from spills
and breakages, product testing, and product transfer
(USEPA 1997a).  Total  emissions  from these  three
facilities show negligible releases to air (0.002 tons), no
releases to water, and 3.9 tons of mercury recycled off-
site in 1999. This recycling quantity may be the result of
off-spec product, spill collection, etc.

These  quantities may  not reflect  other companies
involved in  thermostat  production,  and may  be
overestimates  by including releases  resulting  from
unrelated facility activities. Therefore, in Exhibit 3-8, it
is assumed that the quantity  present in products (11-17
tons), plus the quantity  recycled   (4 tons) equaled
consumption (15-21 tons).

3.4.4 Use
Because mercury is contained  in  a  sealed glass tube
within the  mercury  switch thermostat,  release and
exposure to the mercury is unlikely under normal
operating conditions.  USEPA (1994) estimates that 70
million mercury  switch thermostats were used in U.S.
residences in 1994, which  is associated with 230 tons of
mercury (assuming 3 grams per thermostat as explained
above).   Since  a mercury switch thermostat is a
mechanical device with few moving parts, its lifespan is
typically between 20 and 40 years, often exceeding that
of the room  or  building within which  it is housed
(USEPA 1994).  USEPA (1997a) cites a 1995 National
Electrical  Manufacturing Association  finding  that
upgrading, remodeling, and building demolition are the
principal causes of mercury switch thermostat removal.
                                                  29

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     Consumption:
     15-21 tons/yr
 Thermostat
Manufacturing
  Product:
11—17 tons/yr
                                                                         Exports:
                                                                        2-3 tons/yr
                                                                        Domestic Use:
                                                                         9-14 tons/yr
                                        Releases: 0 tons/yr
                                        Recycling: 3.9 tons/yr (off-site)
Domestic:
9-1 4 tons/yr

Imports:
4—6 tons/vr

Use
(230 tons
in use)
                                                7-10 tons/yr
                                                (20 year lag)
                                              Disposal
                                                                                  Releases: 7—10 tons/yr
                                                                                 _-Air: 1-2 tons/yr
                                                                                 " — Disposal: 6—8 tons/yr
                                                                                  Recycling: Not Available
        Sources:^ Mercury Consumption: Sum of mercury in product and releases.
               Mercury Release and Recycling: 1999 TRI for 3 facilities
               Mercury in Product: Estimated from average mercury content (EPA 1992b) and number of thermostats produced (DOC
                                 Exhibit 3-8. Mercury in Thermostats
Imports and exports may also affect the flow of mercury
in thermostats. Bureau of Census data (USDOC 1998)
indicate that the total value of thermostats produced was
$718 million in  1997, the quantity imported was $259
million (36 percent of domestic production) and exports
were $121 million (17 percent of domestic production).
These  data include mercury and non-mercury devices.
Assuming an even distribution of mercury  and non-
mercury devices and a constant annual production rate,
this  indicates 11 to  17 tons of mercury  are present in
domestically produced devices, 4 to 6 tons of mercury
are in imported products, and 2 to 3 tons are in exported
products. The net result is that 13 to 20 tons of mercury
annually enter  the  domestic  consumer market  in
thermostats.

3.4.5 Disposal
USEPA (1994) estimates that 2 to 3 million thermostats
were brought out of service in 1994. Assuming that all
                               of the disposed thermostats contained mercury at 3
                               grams per  unit, this corresponds  to  7 to  10 tons of
                               mercury per year. In the past,  most thermostats have
                               been disposed of as municipal solid waste.  Assuming
                               that 80 percent of solid wastes are landfilled and the
                               remaining is  sent to municipal waste combustors, 80
                               percent of the mercury (6 to 8 tons) is landfilled and the
                               remainder emitted to the air.

                               Efforts to  recycle mercury switch  thermostats are
                               increasing;  however, it is unknown what proportion of
                               the thermostat wastestream is being recycled.  USEPA
                               (1999b) cites Thermostat  Recycling  Corporation as
                               recycling 120 pounds (0.06 tons) of mercury in the Great
                               Lakes region  in 1998.

                               3.4.6 Discussion
                               Since mercury switch thermostats have such long lives,
                               they are expected to enter the waste stream for at least
                                                    30

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the next 30 to 40  years.  USEPA (1992b)  projects
programmable (non-mercury) thermostats to  steadily
replace   mercury  switch  thermostats,  gaining   an
additional one percent of the market share annually.

The  quantity of mercury in thermostats  estimated to
enter the consumer market (13 to 20 tons) is greater than
the quantity of mercury estimated to be in thermostats
removed from service (7 to 10 tons). This may represent
an inaccuracy  in one  or  both  of these  estimates.
Alternatively,  and  perhaps more likely, it  may  be
indicative of the large lag time between generation and
disposal.  For example, it may be the case that a larger
number of thermostats are being sold today than 20 to 40
years ago (i.e., the thermostats just now being removed
from service), or that new construction (rather than
replacement) comprises a significant percentage of the
new thermostat market and the number of thermostats in
buildings in the United States increases every year.

The  USGS consumption  data were  not used  for
consumption estimates because  the data are combined
with other product categories (i.e., thermometers). The
estimate used here,  however,  is  consistent with  the
USGS estimate from Exhibit 3-7.

Estimates are not available  addressing the quantity of
mercury  in  used  thermostats  sent  for  recycling.
Potentially,  this  is  a  significant data gap,  because
numerous programs  are in place to recycle mercury
containing thermostats. Identifying an accurate estimate
is  difficult due to the varied methods by  which  the
thermostats may enter the recycling market, not all of
which  are  accountable.   Therefore,  the  quantities
ultimately  recycled and  disposed by  commercial,
industrial, and consumer use are uncertain.

3.5  Switches and Relays
3.5.1 Introduction
Facilities  manufacturing  switches and relays  may  be
classified under the following business classifications:

    SIC Code 36251 66: Relays and Industrial Controls,
   General Purpose and Other Relays, Reed Relays;
   Mercury Wet Reed

    SIC Code 36433 69: Wiring Devices and Supplies,
   Current Carrying Wires,  Switches for Electrical
   Circuitry,  All  Other  Switches:   Appliance and
   Fixture, Including Surface Mounted, Mercury, etc.
Mercury switches and relays are used in many household
and automotive  applications.  Mercury switches are
typically used to detect motion.   A mercury  switch
consists of  a glass  or  ceramic tube with electrical
contacts at one end. When the tube is tilted or jolted, a
bead of mercury flows over  the electrical contact and
completes the circuit. A mercury switch is often called
a "silent switch" because electrical contact is established
instantaneously  due to the surface tension  of the
mercury.  In a hard contact switch, the microscopic
"bounce" that occurs as contact is established may cause
electrical noise (USEPA 1994).

Tilt switches are mercury switches that are used to sense
tilt.  Mercury tilt switch applications include level
controls,  security  alarm systems, vending  machine
alarms, washing machine covers, and automobile trunk
light switches.  Mercury tilt  switches are also used as
motion  and  vibration  sensors  in  anti-theft devices,
"smart appliances" that turn  off when not in use, and
automobile anti-lock brakes.

A  relay  is  an electromechanical  switch  where  the
variation of current in one electrical circuit controls the
current  in another  circuit.  A  relay consists of  an
electromagnet that is connected to a moveable contact.
When the electromagnet is  energized,  the contact is
moved to either complete or break  a  circuit.   In a
mercury reed relay, the electrical contacts are  wetted
with mercury to  provide  an  instantaneous  circuit
(USEPA 1994).

3.5.2 Materials Flow
Exhibit  3-9  illustrates the consumption, release, and
product content of mercury in switches and relays, in
manufacturing, use, and final disposal.

3.5.3 Manufacturing
Mercury Consumption
USGS data in Exhibit 3-10 show that the total amount of
mercury used to produce wiring devices and switches
peaked in 1995 at 92 tons and  dropped to 63 tons in
1997.  The USGS estimate does not include mercury
reed relays because relays are classified under SIC Code
3625.  The  mercury content of various switches and
relays is shown in Exhibit 3-11.

Data from both the Department of Commerce's Bureau
of Census and USGS (1997) were used for estimating
mercury flow in this sector. The  data are expressed as a
range: 36-63 tons per year.
                                                  31

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           Consumption:
           36-63 tons/yr
Switch and Relay
 Manufacturing
  Product:
36-63 tons/yr
                                         Releases: 0 tons/yr
                                         Recycling: 0 tons/yr
Domestic:
36-63 tons/yr
^

Imports:
Not Estimated

Use
(630 tons
in use)
                                                36-63 tons/yr
                                              "(10-15 year lag)"
                                                                     Exports:
                                                                   Not Estimated
                                                                   Domestic Use:
                                                                   36-63 tons/yr'
                                         Disposal
                                                                            Releases: 36-63 tons/yr
                                                                           __- Air: 7-13 tons/yr
                                                                           "-Disposal: 29-50 tons/yr
                                                                            Recycling: Not Available
               Sources:  Mercury Consumption: Low end range from USDOC (1998) and M2P2 (1996). High end range from USGS (1997).
                     Mercury Releases: General waste management data from USEPA (1997c).
                       Exhibit 3-9. Mercury in Switches and Relays Manufacturing
The number of mercury switches manufactured in the
United States is uncertain. Mercury switches could be
included under various product codes within SIC code
36433 (Switches  for Electrical Circuitry). Mercury
switches are specified in product sub-code 69 (All other
general use switches, including mercury). However, the
quantities and  values in the  1998 Current  Industrial
Report (USDOC 1998) combines product code  69 with
other AC-DC  switches  (product code 51) to  protect
proprietary information.  Moreover, mercury switches
may  be  found within  other  product codes such as
automotive switches and other special type of switches.
Mercury reed relays are classified under SIC code 3625,
however, specific production data were withheld in the
1997  Manufacturing Profiles report (USDOC 1998).
                             Assuming that all 16.5 million general use switches (SIC
                             Code 36433-69) bought and sold in the United States
                             (USDOC 1998) are mercury switches and each contains
                             2 grams of mercury results in approximately 36 tons of
                             mercury. This estimate could be high because SIC Code
                             36433-69 includes non-mercury switches, but it could
                             also be low because it does not include mercury reed
                             relays and  may not  include  automotive  and other
                             switches. In 1996, 11.2 tons of mercury was used in
                             U.S.-made vehicles, primarily as lighting switches (GLU
                             2001).

                             Releases
                             Mercury may be released  during  the  manufacturing
                             process from spills and breakages, product testing, and
                             product transfer (USEPA 1997a). The wastes associated
                                                    32

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with  mercury  switch  manufacturing  are  uncertain.
Mercury switch manufacturing consists of filling a glass
or ceramic tube with 0.5 to 3 grams  of mercury  and
sealing the end with electrical contacts. Although four
facilities within SIC Code  3679 (Electric component
manufacturing) reported mercury waste emissions to the
Toxics Release Inventory in 1999, it is uncertain whether
those releases result  from manufacturing mercury
switches or relays.  Total emissions from these three
facilities show negligible releases to air (0.0025 tons), no
releases to water, and 3.9 tons of mercury recycled  off-
site in 1999. These estimates were previously accounted
for in thermostat manufacturing, and are not repeated
here. Applied to the industry as a whole, these quantities
are not necessarily representative  of other switch  and
relay manufacturers.

3.5.4 Use
Mercury switches are very reliable, and certain types of
mercury  switches can  last up  to  50  years (USEPA
1992b). Because the mercury is contained in a sealed
glass or ceramic tube within the mercury switch, it is
unlikely that it will be released under normal conditions.
Because  mercury  switches   are  used  in  various
applications, from lighting switches to anti-lock brakes,
the number of switches currently in use is not easy to
determine.  Using the USGS mercury consumption data
since 1990 (see Exhibit 3-10), and assuming that the
mercury contained in those switches is still in use, there
are at least 630 tons of mercury contained in switches in
the United States. This estimate is probably low because
                                     of the long life span of mercury switches; most switches
                                     manufactured in the 1970s and 1980s are probably still
                                     in use.  The amount of mercury imported into the U.S.
                                     contained  in  imported  mercury  switches  is  also
                                     unknown.

                                     3.5.5 Disposal
                                     USEPA (1992b) estimates that 1.9 tons of mercury are
                                     discarded from mercury electric light switches each year,
                                     assuming that 10 percent of the  switches are disposed
                                     after 10 years of production, 40 percent discarded after
                                     30 years of production, and the  remaining 50 percent
                                     after 50 years. However, that estimate does not include
                                     other mercury switches such as those found in household
                                     appliances, automobiles, and  mercury reed  relays.
                                     Exhibit 3-10 assumes the amount used in switch and
                                     relay manufacturing (36-63 tons/year) must eventually
                                     be disposed, with 80 percent landfilled and 20 percent
                                     incinerated.

                                     3.5.6 Discussion
                                     Because mercury switches have such long life spans,
                                     they are expected to steadily enter the waste stream for
                                     at least the next 30 to 40 years. The automobile industry
                                     is working to reduce  mercury  consumption  (CGLI
                                     1999).  Mercury reed relays are gradually being replaced
                                     by solid state relays (USEPA 1994).
          Exhibit 3-10.  Mercury Consumption by SIC Code 3643 - Wiring Device and Switches
                                         1990
                                1991
       1992
       1993
       1994
       1995
       1996
       1997
 Total Mercury Used1 (tons)
                         77
78
90
91
87
92
54
63
'Source: USGS (1990-7)
 Description
Exhibit 3-11. Mercury Content of Various Mercury Switches and Relays
                                    Mercury Content (mg)
 Automobile trunk and hood light switch
                                    500-1,000
 Freezer light
                                    2,000
 Silent Switches
                                    2,600
 Mercury Reed Relay
                                    140-3,000
Source: M2P2 1996
                                                   33

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The  wide  variety  of mercury  switches and  their
applications in consumer and industrial products makes
accounting extremely difficult. This variety results in
different classifications of switches with some portion of
each containing mercury. The most significant example
is  the classification of thermostats, which contain a
mercury switch  but is  categorized  separately  (and
discussed elsewhere in this report). Nevertheless, there
may be difficulties with data interpretation, especially in
cases where a manufacturer produces a wide variety of
mercury-containing products that contain switches, but
classifies its business activities according to  a  more
limited set of SIC codes.  Such a problem was apparent
when interpreting TRI data for manufacturers of various
electrical devices and attributing the data to different
products (such as thermostats and switches).

The quantity of mercury used for switches is uncertain.
The  quantity provided by USGS (1997) is  63  tons.
Bureau  of Census data  (36 tons) were  also  used to
account for switches that are likely to contain mercury.
Both values are included in Exhibit 3-10, as a range, to
account for this uncertainty.

3.6 Organic Chemical Production
3.6.1 Introduction
Facilities producing organic chemicals may be classified
under the following business classifications:

    SIC Code 2869: Industrial Organic Chemicals

    NAICS Code 325: Chemical Manufacturing

Mercury is used  as a catalyst in the organic chemicals
industry. One known use is in the production of vinyl
chloride monomer using acetylene as a raw material. In
this  process,  acetylene  (C2H2)  is  combined  with
hydrogen chloride (HC1)  and flows through a fixed bed
of solid mercuric chloride catalyst. The product is vinyl
chloride (C2H3C1), which is subsequently purified. This
process is used by a single facility, Borden Chemicals
and Plastics in Geismar, Louisiana. In 1996, this facility
had a capacity to produce 950 million pounds of vinyl
chloride per year, but by  1998 was expected to increase
this capacity by 250 million pounds per year (USEPA
2000a). As a result, the  quantity of mercury used and
subsequently released is expected to increase.  In  1999,
a total of three facilities  (the Geismar facility was not
one of them) reported releases of mercury; however, the
releases were negligible (0.0005 tons).
3.6.2 Materials Flow
No estimates  of  mercury  consumption  data  were
available for this industry, therefore neither consumption
nor release data can be presented due to insufficient data.

3.7 Dental Preparations
3.7.1 Introduction
Facilities manufacturing or using dental equipment may
be classified underthe following business classifications:

   SIC Code 3843: Dental Equipment and Supplies
   NAICS  Code  339114:   Dental  Equipment and
   Supplies Manufacturing

   SIC Code 8021: Offices and Clinics of Dentists
   NAICS Codes 6212 and 62121: Offices  of Dentists

This  section focuses on use of mercury by the dental
profession.   Amalgam fillings, used to fill  cavities in
teeth, contain about 50 percent mercury. Not all of the
mercury used by the dental profession ends up in the
fillings.   Some is lost  as air  emissions, some is
discharged  in  wastewater,  and some  is disposed as
hazardous waste or is recycled.

3.7.2 Material Flows
Exhibit 3-12 illustrates the flow of mercury in the dental
profession.

Mercury Consumption
Mercury consumption is assumed equal to the amount of
mercury used in amalgam fillings.

Mercury is a major component (50 percent) in amalgam
fillings. Using data from USGS (1997), USEPA (1997a)
assumed that 34 tons of mercury were used in the dental
industry during  1996, including amounts found in
equipment and supplies.  However, another approach
presented below results in a slightly higher estimate of
54 tons per year.  To account for this uncertainty both
estimates are given in Exhibit 3-12. In 1990, about 96
million of the  more than 200  million  restorative
procedures   that  were   performed  used   amalgam
(USDHHS  1993).   Amalgam use decreased by 12.5
percent among dentists from 1990 to 1995, and since the
beginning of 1993 the trend has been steady  (USDHHS
1997).   Assuming that  amalgam use continued to
steadily decline results in 81.6 million amalgam fillings
in 1996. According to a study by Yoshida (1994), an
                                                  34

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                            Consumption:
                            34-54 tons/yr
    Dental
 Preparations
Manufacturing
                                                             Releases: 0 tons/yr
                                                             - Air: 0 tons/yr
                                                            • -Water: 0tons/yr
                                                             -Disposal: 0tons/yr
                                                             Recycling: 2.5 tons/yr (off-site)
                   Use:
                34-54 tons/yr
                                            - Disposal: No estimate
                                            Recycling: No estimate
Dental
Offices

	 k.

Releases: 8.1 tons/yr
- Air: 0.7 tons/yr
Population
(1200 tons
in use)

	 k.
                                Releases: 0.1 tons/yr
                                -Air: 0.1 tons/yr
                                - Disposal: 0 tons/yr
                                Recycling: Not
                                Applicable
                Sources:  Consumption and Use: USGS (1997) for low end, and Yoshida (1994) and USDHHS(1993, 1997) for high end.
                       Manufacturing Releases: 1999 TRI.
                       Dental Office and Popluation Releases: Air releases from EPA (1997a), water and population releases from DAMS (1999).
                               Exhibit 3-12. Mercury in Dental Preparations
amalgam  filling  contains  0.6  grams  of  mercury.
Therefore, almost 49,000 kilograms (54 tons) of mercury
were used in fillings during 1996.

Air Releases
Mercury  in fillings can be released in various ways,
including emissions from spills and scrap, air discharged
by the  dental  office's vacuum pump system  (Rubin
1996),  and constant  emissions  from the fillings  in
people's mouths over time.  USEPA (1997a) assumed
that  two percent (0.7 ton  out of 34 tons)  of the total
amount of mercury used is emitted from spills and scrap,
but admits that number is likely an underestimate of the
total emissions. This estimate is reflected in Exhibit 3-
12.

Studies have been conducted to determine the amount of
mercury that is released from fillings once they are
placed in people's mouths. As presented in USDHHS
          (1993), a study by Mackert found that, on average, a
          person's  intake  of mercury  from  fillings  is  1.24
          micrograms each day; results from other studies ranged
          from 1.7 to 27.0 micrograms per day.  Using the U.S.
          Census Bureau estimate of 281 million people in the
          U.S. in 2000 (USDOC 2001) and 1.24 micrograms of
          daily release per person results in 0.35 kilograms (1
          pound) of mercury released from fillings per year.  This
          estimate is not presented in Exhibit 3-12 because it is not
          directed towards media releases to the environment but
          rather direct exposure.

          Water Releases
          Wastewater from  a  dental  office  may  contain,  on
          average,  270 milligrams per day  (range  65  to  842)
          (based on data from Arenholt [1996] in DAMS [1999]).
          Using the mean daily level of 270 milligrams per day per
          office times 250 working days per year times  100,000
          dental  offices (conservative  estimate, DAMS  1999)
                                                     35

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results in 6,750 kilograms or  7.4 tons of mercury
entering wastewater each year.

Amalgam separators can reduce the mean mercury
content in a dental office's wastewater from 270 to 35
milligrams per day (based on data from Arenholt [1996]
in DAMS [1999]).  However, few dental offices in the
United States have amalgam separators (DAMS 1999).

Solid Waste Releases
No data are available to estimate quantities of mercury
recycled or disposed.

Recycling
The quantity  of mercury recycled by  dental offices is
unknown. 1999 TRI data showed one dental equipment
manufacturing company reporting mercury emissions.
Offsite recycling was reported as 2.5 tons, while releases
to all other media were reported as zero.

Reservoir
The  total quantity of mercury  in  the  population is
estimated based on the annual use rate  of 34 to 54 tons.
No  data were available  to estimate the lifetime of a
filling. Assuming a 20 to 40 year span, this results in an
estimated quantity of 1200 tons in use.

3.7.3 Discussion
The estimate used for the amount of mercury per filling
was based upon a Japanese study. The mercury content
of fillings in  Japan may be  higher than in the United
States, which may help account for  the discrepancy
between this estimate of 54 tons of total mercury used
and USEPA's estimate of 34 tons. Additionally, this is
a single average value, where in reality the quantity used
is a function of many factors such as the patient's needs
and the technique  of the dentist. Furthermore, non-
amalgam fillings are being used for certain applications.

3.8 Pharmaceutical Use
3.8.1  Introduction
Mercury finds its way into a variety of pharmaceutical
products, including  opthalmics,  vaccines, and topical
products. Although use of mercury in these products has
been scaled back in recent years both from voluntary
actions by manufacturers due to increasing concerns over
mercury toxicity and as the result of Food and Drug
Administration (FDA) regulations, mercury is still found
in many products.

To assess the presence of mercury in food and drugs, the
FDA issued a request for data to identify food and drug
products that contain intentionally introduced mercury
compounds (63 FR 68775, December 14, 1998).  FDA's
analysis of these responses (USFDA 1999) indicate that
three mercury compounds are intentionally introduced as
apreservative into both prescription and overthe counter
(OTC) nonhomeopathic products such  as nasal spray.
These  preservatives   are   thimerosal   (TM),
phenylmercuric acetate  (PMA)  and  phenylmercuric
nitrate (PMN).  The responses also showed that more
than twenty  other mercury  compounds  are used in
homeopathic drug products,  usually  as  therapeutic
ingredients.

3.8.2  Materials Flow
Exhibit 3-13 shows the consumption  and release of
mercury pharmaceutical product manufacturing._

Mercury Consumption
USFDA (1999) calculated that approximately  75,000
grams (0.08  tons) of mercury compounds are used per
year.  The FDA calculated this amount by tallying the
responses  received  from   the  request  for  data;
categorizing   the responses by  compound used  and
product type; searching its  databases for additional
products that fall into these product type categories that
were  not reported in the  responses to  the request for
data;  applying the same  average  amounts of mercury
compounds reported for that product type and category
to the additional products found in the  databases; then
totaling the amounts of mercury compounds from each
category to reach an estimated total amount of mercury
compounds used in pharmaceutical products.

The  75,000  grams of mercury compounds estimated
comes exclusively from the three common preservatives:
TM, PMA, and PMN. While many homeopathic product
uses were reported, the FDA concluded that the dilutions
of mercury compounds in products were so low as to be
negligible in comparison  to  pharmaceutical  use.
Thimerosal in products accounts for approximately 99%
of the mercury  compounds included  in  the  FDA's
estimate.

Releases
Releases may result from the manufacture or formulation
of  the  mercury  compounds  themselves.     No
pharmaceutical manufacturers reported mercury releases
in 1999 to the TRI.
                                                  36

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                        Consumption:
                         0.08 tons/yr
Pharmaceuticals
 Product:
0.08 tons/yr
                                                       Releases: unknown
                                                       Recycling/Reuse: unknown
                       Sou/ve:   Mercury Consumption: FDA (1999).
                              Mercury Release and Product: Assumed equal to consumption.

                              Exhibit 3-13. Mercury in Pharmaceuticals
The  potential release mechanisms  for  mercury  in
pharmaceutical products include excretion, exhalation,
volatilization,  spillage during administration, and the
destruction or disposal of unused products.  Because
these products may be administered in any location,
especially in the case of OTC products, there is no way
to quantify the amounts that are spilled or discarded.
Many studies have been conducted examining the output
of mercury from the human body, but these are largely
dependent on dose, method of exposure, and the specific
mercury   compound.     Because  mercury   in
Pharmaceuticals  can  be  introduced orally,  nasally,
dermally,  ocularly, or through  injection, it is also
impossible to quantify the output of these compounds
once introduced to the human body.

3.8.3  Discussion
While mercury preservatives in pharmaceuticals were
reported to the FDA in a large array of products, their
use  is dwindling  due to  consumer and regulatory
pressure.   The few uses  remaining  are likely  to  be
discontinued due to the requirements of the New Drug
Approval process, which requires demonstration that a
product is safe and effective. The estimated total amount
of mercury  compounds  used  annually,  0.08  tons,
indicates  that pharmaceutical  use  is negligible  in
comparison to other sources and uses of mercury.

3.9 Laboratory Use
3.9.1 Introduction
This section focuses on the use of mercury and mercury
compounds  in   laboratory  chemicals.     Mercury
compounds are used  in laboratories  in two  ways:  as
chemical reagents in experiments and processes and in
            chemical products used for laboratory work. Mercury is
            also found in many laboratory  instruments,  such as
            thermometers  and manometers, as discussed  in other
            sections of this report; this section focuses specifically
            on non-equipment use.

            Histology,  the   processing  of body  tissues  for
            examination, comprises  several types of steps. These
            steps include  fixation  and  staining,  both of which
            frequently use mercury-bearing  compounds.  It is
            important to note  that these  chemicals often contain
            mercury  in concentrations less than 1 percent, so the
            mercury  compound may not  be  listed on the product
            Material  Safety Data Sheet (MSDS). A certification of
            analysis  from the  manufacturer will reveal the small
            amounts  of mercury in these products.

            3.9.2  Materials Flow
            Mercury Consumption
            Because there are a wide variety of mercury compounds
            used in laboratories, and these chemicals are made by
            many  different manufacturers, it is not possible to
            determine the quantity of mercury annually being used
            in laboratory settings. One source notes a decline from
            35 tons of mercury compounds used in 1990 to 11 tons
            of these compounds used in 1991 (NC DEHNR 1996).
            It can be assumed that  the current total usage of the
            chemicals has continued to decline in the past nine years,
            in light of the recent revisions of standard analytical
            methods   and  growing  concern over  environmental
            hazards.

            Releases
            Releases may result from the manufacture or formulation
                                                  37

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of  the  mercury  compounds   themselves.     No
manufacturers of laboratory chemicals reported mercury
releases in 1999 to the TRI.

Mercury can to be released in two additional ways: as
unused  product (e.g., expired or otherwise discarded
reagent), and as a result of use (e.g., in samples at dilute
concentrations).  In general, laboratories prepare their
own guidelines regarding handling procedures for these
waste materials.  Releases as solid waste and as water
discharges are expected to be  most prevalent.  Solid
wastes are expected to be the result of unused reagent
that  is  sent  offsite  for recycling or  disposal as  a
hazardous waste.  Water releases would result from the
disposal of analyzed  samples  which  contain  small
concentrations of the reagent, which is rinsed down the
sink. Water releases may also result from the disposal of
unused reagent down the sink. The presence or absence
of local regulations or permitting requirements regarding
sewer discharges is expected to influence the laboratory
practices used.

3.9.3   Discussion
Because data estimating the use of mercury-containing
laboratory chemicals and equipment are not avaiable, it
is impossible to determine the contribution of this sector
to domestic mercury use and release. The only available
estimate of use, 11 tons of mercury-bearing chemicals
used in  1991 (NC  DEHNR 1996), does not estimate the
amount of mercury in these chemicals; because most of
these chemicals contain only trace amounts of mercury
(less than one  percent), it can be assumed that  the
amount of mercury used and released from laboratory
chemicals is negligible in comparison to other sources
and uses of mercury.

3.10  Batteries
3.10.1 Introduction
Facilities manufacturing or storing  batteries may  be
classified under the  following business classification
code:

    SIC Code 3691: Storage battery manufacturing
    SIC Code 3692: Primary battery manufacturing
    NAICS Code  33591: Battery manufacturing

The use of mercury in electrical batteries has decreased
significantly from more than 1,000 tons annually in the
early  1980s to less than 1 ton in  1996 (USGS 2000e).
The use of mercury in battery production was sharply
reduced in the early 1990s. Mercury is presently used in
two types of batteries: button cell batteries and mercuric
oxide batteries. Button cell batteries are used in watches
and  other  consumer electronics.    Mercuric  oxide
batteries are larger cylindrical batteries used mostly for
non-consumer use items such  as medical  or military
applications (USEPA 1997a). The Mercury-Containing
and Rechargeable Battery Management Act of 1996, in
part, phased out the use of alkaline-manganese and zinc-
carbon batteries containing intentionally added mercury
and button cell mercuric-oxide batteries (USGS 2000e).

3.10.2 Materials Flow
At present, most batteries are expected to last no more
than a few years either as a  result of use or slow
discharge over time.  Therefore, little to no mercury is
expected to be  present as  part of consumer use  of
batteries from applications prior to 1992.  Furthermore,
such a quantity from past use cannot be estimated.

Releases of mercury to air from battery manufacturing
were estimated  by  USEPA (1997a).  This estimate
showed negligible mercury  emissions (<0.001 tons) in
1995. Examination of the 1999 TRI  data showed one
battery  manufacturer reporting mercury releases  of
0.0125 tons.  This facility  corresponded to the only
domestic mercuric oxide battery manufacturer (Maine
2000).

3.10.3 Discussion
In conclusion, mercury is  consumed in very  small
amounts for battery production, relative to other sources.
Quantities of mercury used  and subsequently released
are correspondingly small.  For this reason, no exhibit
illustrating  mercury flow is presented.

3.11 Miscellaneous
TRI data for 1999 identified several facilities reporting
releases of mercury that do not appear to be engaged in
the manufacturing processes described  above.   The
industries   include  electroplating  (three   facilities),
explosives   (one  facility),   food  (one  facility),
transportation (one facility), j ewelry and precious metals
(one facility). The combined releases of all the industries
is 0.21 tons of mercury.
                                                  38

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                                             Chapter 4
        Incidental Mercury Use Associated With Coal Combustion or Coal Use
4.1 Coal Combustion by Utilities
4.1.1 Introduction
This section  focuses  on utilities that  burn coal  for
electric power generation.  This sector is of concern
because electric utilities  are  the  largest  source  of
anthropogenic air emissions of mercury in the United
States (USEPA 1997a). Facilities may fall under several
SIC and NAICS Codes.

SIC codes:
    491: Electric Services
    4911: Electric Services
    493: Combination Electric and Gas, and Other
    Utility
    4931: Electric and Other Services Combined
    4939:   Combination  Utilities,  Not  Elsewhere
    Classified

NAICS codes:
    22: Utilities
    221: Utilities
    2211: Electric Power Generation, Transmission and
    Distribution
    22111: Electric Power Generation
    221112: Fossil Fuel Electric Power Generation

Utility boilers that generate electricity can be fired by
coal, oil, natural gas, or some combination of these fuels.
This section focuses on utilities that use coal.  Coal is
burned in a boiler to heat water and produce steam.  The
steam is used  to generate electricity and, in some cases,
heat.  There  are approximately 440 coal-fired utility
plants in the  United States, and they use about 1250
boilers (USEPA 1999d). Coal-fired utilities  tend to be
concentrated in the Northeast and Midwest.

In 1994, 81 percent of the energy generated from utility
boilers came from the burning of coal (USEPA 1997a).
Coal accounts for over three-quarters of  electricity
generation in some areas including the Great Lakes area
(USEPA 1988a). For example, Ohio generates roughly
90 percent of its electricity from coal (GLNWF  1997).
Coal consumption is expected to increase 26 percent
between  1997 and 2020 as utilities use more of their
generation capacity, costs of natural gas and oil rise and
nuclear plants close (USEPA 1999d).

Mercury is present in the mined coal. After mining, the
coal may be cleaned  to remove sulfur  and improve
burning characteristics. It is then transported by rail to
end users such as utilities. Coal is stored in storage piles
or silos at the plant. From storage, the coal is subjected
to mechanical sizing operations and is charged to the
boiler.  There are three basic types of boilers: pulverized,
cyclone,  or  stoker systems.  Most (92%)  coal-fired
boilers are pulverized coal systems where the coal is
pulverized before combustion. Cyclone systems, named
because of the cyclone-like vortex created by the coal
particles in the furnace during combustion, make up 8
percent of utility boilers.  A third, less common type
(<1%)  is the "stoker," which is used  for  smaller
capacities (e.g., 20-30 megawatts) and burns coal in a
variety of sizes (USEPA 1999d; USEPA 1988a).

In the  removal of sulfur during coal cleaning,  some
portion of the mercury is coincidentally removed as well.
The most widely used methods of coal cleaning use
specific gravity, relying on the principle that heavier
particles (i.e., impurities) separate from lighter ones (i.e.,
coal) when settling in liquid. A common method for
cleaning  coarse pieces is  to pulse currents of  water
through abed of coal in a jig so impurities like shale and
pyrite sink.  A mixture  of water and ground magnetite is
used to clean coarse  and  medium-sized pieces.   A
concentrating table, an inclined vibrating platform with
diagonal grooves that trap the impurities, is also used to
clean intermediate sized pieces.  Fine coal particles are
often cleaned with froth flotation.  The coal pieces are
coated  with oil and then agitated in a controlled mixture
of air, water, and reagents  until froth is formed on the
surface.  Bubbles tend to attach to the coal, keeping it
buoyant, while heavier particles remain dispersed  in the
water  (USEPA 1988a).   On average, coal cleaning
removes about 21 percent of the mercury contained in
                                                  39

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coal (USEPA 1998c).  Seventy percent of coal used by
electric utilities is cleaned to some extent (USEPA
1999d). Putting these two estimates together, 15 percent
of the  mercury present in coal nationwide  is removed
prior to introduction to the boiler.

Mercury is atrace element (i.e., contaminant) in coal and
is  a highly  volatile  metal  that vaporizes  at the
temperatures  reached  when   coal  is   burned.
Consequently,  mercury  is  emitted in the  gas stream
during combustion. The concentration of mercury in the
coal varies considerably depending on the coal type,
where  it was mined, and how it is processed before
combustion (Massachusetts 1996). There are four types
of coal: anthracite, bituminous,  subbituminous, and
lignite. Ninety-one percent of the coal burned by coal-
fired utilities  in the  United  States  in  1997 was
bituminous and subbituminous, 9 percent was lignite,
and  less  than one  percent  was  anthracite  (USEPA
1999d).   The  different types of coal  have varying
mercury content.

To estimate the quantity of mercury present in coal used
by coal-fired utility boilers, data from the EPA's 1999
Information Collection Request (ICR) were used, which
measured coal samples from every U.S. coal-fired power
plant as well as coal usage  data.  Using these data, a
consumption  89  tons  mercury was  calculated (after
processing and cleaning) from 925 million tons of coal.
In the 1999 ICR, EPA identified the mercury content of
coal at all 450 coal-fired utilities used in that year, and
also conducted air sampling at a  subset of these units.
Based  on analysis of the data, EPA estimated that 48
                       tons of mercury was released to the air (USEPA 2001).
                       (The remainder is  assumed to  be collected in air
                       pollution control residues and handled as solid waste.)

                       The combustion of coal results in the vaporization of
                       much of the contained mercury and its release to the
                       atmosphere, from which it is ultimately deposited in soil
                       or into bodies of water (USBM 1994).  The part of the
                       mercury in coal that is not emitted  to the atmosphere
                       during combustion is trapped  in wastes  such as bottom
                       ash  and recoverable  fly ash.   Landfills are often the
                       ultimate repositories for these wastes (USBM 1994).
                       The ash can also be used in products such as concrete.

                       4.1.2 Materials Flow
                       Exhibit 4-1 demonstrates the flow of mercury during the
                       coal combustion process.

                       Mercury Consumption
                       Based  on  evaluation of EPA's  1999  Information
                       Collection  Request, an estimated 89 tons of mercury
                       entered boilers in cleaned coal. As noted above, about
                       15% of mercury is removed from coal during cleaning
                       nationwide. Therefore, the quantity of mercury leaving
                       the mine is estimated as 105 tons, which is reflected in
                       Exhibit 4-1.
            Consumption
             105tons/yr
  Coal
Cleaning
Consumption
 89 tons/vr
 Utility Coal
Combustion
                                           Releases: 16 tons/yr
                                           - Air: 0 tons/yr
                                          •-Water: 0 tons/yr
                                           - Disposal: 16 tons/yr
                                           Recycling/Reuse: 0 tons/yr
                                            Releases: 72 tons/yr
                                            - Air: 48 tons/yr
                                           --Water: 7 tons/yr
                                            - Disposal: 17 tons/yr
                                            Recycling/Reuse: 0 tons/yr
            Souice:   Mercury Consumption: USEPA (2001) to estimate boiler input.
                   Mercury Release: Air releases from EPA (2001). Water releases calculated using EPA (1988a). Disposal releases from coal cleaning
                   based on cleaning efficiency from EPA(1997a). Disposal and product releases from combustion: Based on EPA(1999d) and EPA (1988a).


                            Exhibit 4-1. Mercury in Utility Coal Combustion
                                                    40

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Air Releases
In 1999, the nationwide rate of mercury emissions from
coal-fired utility boilers was estimated to be 48 tons per
year (USEPA 2001).  This  estimate is  reflected in
Exhibit 4-1.

Although small quantities of mercury may be emitted as
fugitive  particulate  matter from  coal  storage and
handling, the primary source of mercury from both coal
and combustion in utility boilers is the combustion stack.
Because  the combustion zone in boilers operates at
temperatures above  1100 °C (2000 °F), mercury in the
coal is vaporized and exhausted as a gas.  Some of the
gas may cool  and condense as  it passes through the
boiler and air pollution control
device.   Mercury is released in both elemental and
compound form (believed to be mercuric chloride), with
significant  variation  due  to  site-specific  factors.
Additional discussion regarding speciation is presented
in Section 7 of this report.

The   primary  types  of  control  devices  include
electrostatic precipitators (ESPs), wet scrubbers, fabric
filters or baghouses, and mechanical collectors.  ESPs
are the most widely used control device by the electric
utility  industry.   None  are  specifically  designed to
remove mercury, but all have some effect.  Extensive
efficiency data were collected by EPA in 1999 (USEPA
2001). These  efficiency data are presented in Exhibit 4-
2.
Exhibit 4-2. Efficiencies of Various Control Devices in Removing Mercury from Coal-fired Boiler Flue Gas
Control Device
Fabric filter
Cold-side Electrostatic precipitator (ESP)
Hot-side ESP
Fabric filter followed by wet desulfurization
(scrubber)
Cold-side ESP followed by wet desulfurization
(scrubber)
Hot-side ESP followed by wet desulfurization
(scrubber)
Median Mercury Removal Efficiency (%)
Bituminous Coals
89
29
11
97
78
39
Subbituminous Coals
73
3
0
No data
16
8
Source: USEPA 2001

Water Releases
Releases of mercury to water come from three main
sources: runoff from coal piles, wastewater from coal
cleaning, and maintenance and cleaning wastes (e.g.,
boiler   blowdown,  cooling  tower   blowdown,
demineralizer  reagents, boiler  cleaning  wastes, and
liquors from flue gas desulfurization (FGD)). Each of
these sources may contain mercury.  Waters such as
these are typically sent to  settling basins prior  to
discharge, where mercury may either be present in the
settled  solids or be  discharged with the  effluent.  As
shown below, only one source, cooling tower blowdown,
contained significant quantities of mercury or had
sufficient data to assess its contribution.

Cooling tower blowdown is waste removed periodically
from recirculating cooling tower systems to maintain
water quality.   The average production is 2.6 billion
gallons per year per plant,  and from the  limited data
available, the concentration of mercury was measured as
1.5 micrograms per liter (USEPA 1988a). This results in
7 tons of mercury contained in cooling tower blowdown
each year industry-wide (i.e., generated by 440 plants).
This estimate is reflected in  Exhibit 4-1.

Demineralizer regenerants are wastes resulting from the
periodic cleaning and regeneration of ion exchange beds
used to remove mineral salts from boiler makeup water.
The average plant production is 5 million gallons per
year, with a mercury concentration of 0.05 micrograms
per liter (USEPA 1998c).   This results in less than 1
pound of mercury contained in these wastes each year.
                                                  41

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"Water-side" boiler cleaning wastes result from the
periodic cleaning of the boiler tubes, the superheater, and
the condenser. The average plant production is 180,000
gallons per year for water-side boiler cleaning.  No
mercury  data  were available for water-side alkaline
cleaning  wastes, but  the mercury concentration for
water-side hydrochloric acid cleaning wastes ranges
from 0.0 to 0.002 milligrams per liter (USEPA  1998c).
Assuming acid is used 100 percent of the time and using
the high limit of mercury results in less than 2 pounds of
mercury in this waste each year.

Coal pile runoff is produced by precipitation falling on
coal storage areas.  A typical coal storage pile is 25-40
feet high and can cover an area up to 75 acres. Most
utilities keep a supply on hand of at least 90 days' worth
of coal, which equals about 600-1800 cubic meters per
megawatt of generating capacity (USEPA 1999d). The
mercury content in runoff ranges from 0.0002  - 0.007
mg/L, and the average runoff is 20 inches per year per
plant (USEPA 1988a).  No estimate for the quantity of
mercury from this source can be made.

Boiler blowdown is waste continuously or intermittently
removed from boilers that recirculate water to maintain
water quality.  The average plant production is  11
million gallons per year (USEPA 1998c). No mercury
concentration data were available.

"Gas-side" or "fire-side"  wastes  are produced during
maintenance of the gas-side of the boiler, which includes
the air preheater,  economizer, superheater, stack and
ancillary equipment. The residues are normally removed
with water only.    The average plant production is
700,000 gallons per year for gas-side boiler cleaning, but
no  data  on  mercury  content  in those  wastes  were
available (USEPA 1988a).

FGD sludge is the waste produced during the process of
removing sulfur oxide gases from the  flue gas and is
discussed in more detail later. Wet systems use aqueous
solutions to remove the sulfur oxides from the flue gas.
A portion of FGD waste is wet FGD sludge liquors. In
this waste stream, mercury ranges from 0.00006 to 0.1
mg/L, with  a median  concentration of 0.005 mg/L
(USEPA 1988a). No data on generation quantities were
available.

Solid Waste Releases
Wastes from the coal combustion process go primarily to
landfills and surface impoundments. There are two main
solid waste streams from coal combustion: ash and flue
gas desulfurization (FGD) sludge.

In addition, coal cleaning may generate solid and/or
aqueous wastes containing mercury. No hard data on
amounts of wastewater or solid wastes generated by coal
cleaning facilities were available, but assuming that 15
percent of mercury in coal is removed in this process
(discussed above) results in 16  tons of mercury in coal
cleaning wastes.  As identified above, mercury is likely
associated with the solids, however, an unknown portion
of the mercury may be  present in  water as suspended
solids or dissolved mercury. This estimate is reflected in
Exhibit 4-1.

Ash is  the noncombusted waste material that remains
after coal is burned. Ash may be collected from the flue
gas (fly ash and FGD sludge),  or remain in the  boiler
(bottom ash and boiler slag).

Fly ash is small, uncombusted material carried out of the
boiler with the flue gases. In mechanical hopper fly ash,
mercury content ranges  from 0.008 to 3.00 mg/kg of
coal, with a median of 0.073 mg/kg, and in fine fly ash
mercury content ranges  from 0.005 to 2.50 mg/kg with
a median concentration of 0.10 mg/kg (USEPA 1988a).
There were 60.26 million tons  of fly ash produced in
1997 (USEPA 1999d). Using the median concentration
of 0.10 mg/kg, an estimated 6.0  tons/year of mercury is
present in fly ash.

FGD sludge is the waste produced from the removal of
sulfur oxide gases from the flue gas. Wet systems use
aqueous solutions to remove the sulfur oxides  from the
flue gas. Dry FGD systems use no water for sulfur oxide
removal, although dry FGD wastes may be mixed with
water before disposal (USEPA  1988a).  Fly ash is the
primary source of most of the trace elements  found in
scrubber sludge (as shown in Exhibit 4-2, scrubbers do
not have particularly high mercury removal efficiencie s).
In wet  scrubbers that also serve as fly ash collection
devices, more than 50 percent of the sludge solids may
be ash  (USEPA 1988a). In wet FGD  sludge solids,
mercury ranges from 0.01 to 6.0 mg/kg, with a median
concentration of 0.4 mg/kg (USEPA 1988a) (dry FGD
sludge   solids  are  assumed   to   have  similar
concentrations). Utility boilers  produced 25.16 million
tons of FGD wastes in 1997 and  are expected to produce
50  million  tons of sludge in 2000 (USEPA 1999d).
Using the median concentration of 0.4 mg/kg and the
1997 waste generation  quantity,  an estimated  10.1
                                                  42

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tons/year of mercury is present in fly ash.

Bottom ash and boiler slag are uncombusted material
that does not completely melt and settles on the bottom
of the boiler. In both materials, mercury content ranges
from 0.005 to 4.2 mg/kg of coal, with a median of 0.023
mg/kg(USEPA 1988a). There were 16.9 million tons of
bottom ash and 2.7 million tons of boiler slag produced
in  1997   (USEPA  1999d).     Using  the   median
concentration  of  0.023  mg/kg,  an estimated  0.45
tons/year of mercury is present in bottom ash and boiler
slag.

A sum  of the above  sources (fly ash, FGD sludge,
bottom ash, and boiler slag) results in an estimated 16.6
tons per year of mercury.  This  estimate is shown in
Exhibit 4-1.

Product
In 1997,26.8 percent of all waste generated at coal-fired
electric  utility power plants was reused (e.g., as cement
additives, high volume  road construction material,
wallboard, flowable fill,  and blasting grit). The reused
quantity included 19.3 million tons of fly ash (31.5% of
fly ash  generated), 2.18 million tons (7.9%) of FGD
wastes,  5.10 million tons of bottom ash (27.7%), and
2.58  million tons of boiler slag  (92.9%).  Using the
mercury  concentrations discussed  previously,  an
estimated 3.0 tons/year of mercury were contained in the
reused material.  This quantity is already included in
Exhibit 4-1 as solid waste.   No quantity is  listed in
Exhibit 4-1 for recycled,  because  mercury  is  not
recovered from any coal  combustion waste.

4.1.3 Discussion
The total annual quantity  of mercury in coal processed in
utility boilers is estimated to  be 89 tons.  The  annual
quantity of mercury released or in products is estimated
to be 48 tons to air, 17 tons to  solid waste and products
and 7 tons to water; therefore, 89 tons per  year are
assumed to enter the process and 72 tons per year leaves
the process. This  discrepancy is  due to the  different
sources used  in compiling these estimates.  In these
calculations, air emissions do not assume all the mercury
present  in the fuel is emitted in stack gas.

The following list  mentions  some of the actions that
have been taken to address the problem of mercury in
coal and resulting environmental release:

•  Coal cleaning reduces the  amount of ash produced,
    thereby reducing the amount of mercury released.
    On average, coal cleaning removes about 21 percent
    of the mercury contained in coal (USEPA  1997a).
    Seventy percent of the coal used by electric utilities
    is cleaned to some extent (USEPA  1999d).

    Control devices have reduced mercury air emissions.
    The  effectiveness of  current control  devices  at
    removing mercury was  discussed earlier in this
    section.

•   Many collaborative efforts on trace element research
    focused on  mercury  have  been conducted  by
    Department Of Energy/Federal Energy Technology
    Center (USDOE/FETC) and USEPA, the U.S.
    Geological  Survey (USGS), the  Electric  Power
    Research Institute (EPRI), the utility industry, other
    governmental agencies at both the federal and state
    levels,  and   other  U.S.  and  foreign  research
    organizations.  Other  groups such as the Small
    Business  Innovative  Research Program (SBIR),
    University Coal Research Program (UCR), and the
    Jointly  Sponsored  Research  Program  at the
    University   of  North   Dakota   Energy  and
    Environmental Research Center have focus areas in
    research and development for the coal-fired utility
    industry.

    EPA's   Information   Collection  Request  data
    represent a comprehensive analysis  of mercury both
    entering and being emitted from boilers.

4.2 Lime Manufacturing
4.2.1 Introduction
Lime is produced from the  calcination of limestone.
Limestone is present  throughout the United States and
comprises  primarily  calcium  and magnesium in a
carbonate form.  The limestone is fed  to a rotary kiln
where it is heated and rotated slowly to ensure mixing.
This drives off carbon dioxide (and other volatile species
such as water).  The  product, quicklime, is discharged
from the opposite end  of the  kiln from which the
limestone is introduced. Most domestic kilns use coal as
a heat source, although the  kiln can be adapted to oil or
natural gas.  The coal is combusted separately and the
offgases travel through the kiln, to avoid mixing coal ash
with the  lime product (Kirk-Othmer 1995).  Because
both  the limestone   and  the  coal  are  heated   to
temperatures  well above  the  volatilization point  of
mercury, it is expected that any mercury initially in the
raw materials is discharged to the air.
                                                  43

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                        Consumption:
                        2.7-5.0 tons/yr
Lime Production
     Product:
Estimate not available
                                                       Releases: 0.2 tons/yr
                                                       -Air: 0.1 tons/yr
                                                      - - Water: 0 tons/yr
                                                       - Disposal: 0.1 tons/yr
                                                       Recycling: 0 tons/yr
                       Source:n  Mercury Consumption: Estimated from coal and limestone use and concentration data from Kirk-Othmer
                                (1995), USGS(2002b), USGS (1998), and CIBO (1997).
                              Mercury Release: Air releases from EPA Mercury Study Report to Congress (1997a). Disposal releases estimated
                                using utility coal combustion information.
                              Mercury in Product: Estimate not available.

                                Exhibit 4-3.  Mercury in Lime Production
4.2.2 Materials Flow
Exhibit 4-3 illustrates the consumption, release, and
product content of mercury in lime production. No lime
manufacturing facilities reported mercury releases to the
1999 TRI.

Mercury Consumption
The concentration of mercury in limestone is estimated
as 0.04 mg/kg (Council of Industrial  Boiler Owners
1997). The quantity of limestone used as raw material is
estimated to be about 2 tons per ton produced (Kirk-
Othmer 1995), and the quantity of lime produced in
2000 is 21.6 million tons  (USGS  2002b).   This
corresponds to approximately 1.7 tons of mercury in the
limestone feed.   The concentration  of mercury is
expected to  be variable, but no data demonstrating this
variability are available.

The other source of mercury in the feed results from the
coal fuel. The energy consumption of lime production
is variable depending on the efficiencies of the kiln.
Energy consumption is estimated as 5.5 to 8 million Btu
per ton lime (Kirk-Othmer 1995), or approximately 124
to  181  trillion Btu in 1999.   The  concentration  of
mercury in coal is estimated as 4.8 to 36.4 pounds  per
trillion Btus for 14 different coal types (USGS  1998).
Accounting  for the two orThe quantity is assumed to be
zero.

Solid Waste Releases
Mercury is potentially present in coal combustion wastes
generated from the burning of fossil fuels in an onsite
boiler. Estimates of coal combustion wastes generated
from lime production are not available. However, a very
              rough estimate can be obtained by using the results of
              the assessment of utility coal combustion (even though
              characteristics regarding particulate control and burner
              technology may be  different).  In Section 4.1.3,  air
              releases of 48 tons and solid waste  releases of 17 tons
              were estimated. Applying this proportion to the 0.1 tons
              of mercury released to air, no more than 0.1 ton of
              mercury is estimated to be in the waste residues.  This
              estimate is reflected in Exhibit 4-3.

              Product
              Approximately 21.6 million tons of lime were produced
              in 2000 (USGS 2002b). No data regarding the mercury
              content in lime are available.

              4.2.3 Discussion
              The quantity  of mercury entering the lime production
              process results from limestone and coal.  The total is
              estimated to be  2.8 to 5.1 tons per year. However, the
              quantity of mercury leaving the process is only estimated
              to be 0.1  ton from air and 1 ton  from solids.  This
              discrepancy can be due to the following factors:

              •   Poor estimates of mercury input.   The quantity of
                 mercury present in the feed limestone is based on a
                 single concentration value of  limestone,  from a
                 single location. The mercury content of limestone is
                 expected to vary by location throughout the United
                 States. Additionally, the energy use in  kilns  is
                 obtained from a single source (Kirk-Othmer 1995),
                 and although this is useful for a  'ballpark' estimate,
                 a second data source would be required to help
                 ensure representativeness.
                                                    44

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    Poor estimates of mercury output. The only estimate
    of mercury releases or mercury in product is an air
    estimate from theMercury Study Report to Congress
    (USEPA 1997a), and an estimate of mercury present
    in coal combustion ash. Other estimates of mercury
    in  water releases  and in  the  product are not
    available, although the quantity of mercury in water
    is  likely to  be zero.   However, even small
    concentrations  of mercury in the product would
    re suit in sizable accounting (e.g., if the concentration
    of mercury in the product equaled the concentration
    of mercury in the limestone feed, this would account
    for an  additional 0.9 tons).  In addition, quantities of
    mercury in coal combustion ash as a solid waste
    were only roughly estimated.

4.3  Residential, Commercial,  and  Industrial
Coal Combustion
4.3.1 Introduction
This section focuses on residential, commercial and
industrial boilers that burn coal to produce steam. This
sector is of concern because mercury  in the coal is
vaporized  during combustion and appears as a trace
contaminant in the gas exhaust stream.  Facilities will
fall under many SIC or NAICS Codes. There is no
category specifically for industries that use coal-fired
boilers,  and residential sources  do not fall under the
purview of SIC or NAICS.

While boilers can be fired by coal, oil, natural gas, or a
combination, this section focuses on the use of coal.
Coal is burned  in a boiler to  heat water and produce
steam.  The steam is used to generate heat or electricity
or as a production process input.

In 2000, residential, commercial, and industrial facilities
(excluding power producing utilities/non-utilities and
coke production) consumed approximately 69 million
tons of coal (USDOE 2002).

There are a wide range of boiler sizes and types used in
the commercial and industrial sector.  Larger boilers use
a suspension-fired system similar to the systems in place
at coal-fired utilities. Moderate and small  boilers use
grate-fired systems  (USEPA 1997a). Residential boilers
tend to be  small, stoker systems.

Mercury is a contaminant in coal, the raw material used
for combustion. The mercury content in coal can range
from 4.8 to 36.4 pounds per trillion Btus (USGS 1998).
In USEPA's Mercury Study Report to Congress, the
emission factor is  determined by  coal  type.   For
bituminous coal it is assumed that 16 pounds of mercury
per trillion Btus is emitted; for anthracite coal, 18 pounds
per trillion Btus (USEPA 1997a); estimates which are in
the range of the mercury content of coal from the USGS
data showing that much of the mercury was assumed to
be emitted to the air.

4.3.2 Materials Flow
Exhibit 4-4  demonstrates the flow of mercury during the
coal combustion process for industrial, commercial, and
residential boilers.

Mercury Consumption
Mercury is  a contaminant in coal, the raw material used
for combustion. As identified above, approximately 69
million tons of coal for commercial, industrial, and
residential  applications are used annually.  In Section
4.1, it was estimated that  925 million tons  of coal
contained 105 tons of mercury (about 0.11 tons mercury
per million tons coal).   Assuming  that the mercury
content of  coal burned in each industry is  similar,
approximately 7.6 tons of mercury is contained in
incoming coal for residential, commercial, and industrial
boilers.

An alternative  calculation was presented  in USEPA
(1997a).   The  same  energy  consumption  of 2.8
quadrillion  Btus was used but a  different mercury
concentration in coal was assumed: for bituminous coal
it was  assumed that 16 pounds of mercury per trillion
Btus are present, and 18 pounds per trillion Btus for
anthracite coal.  This resulted in an estimate of 21.2 tons
of mercury  per year.  Exhibit 4-4 contains both numbers
as a range.

Air Releases
In USEPA  (1997a), it  was assumed that  all mercury
present in the raw material would be released to the air.
Mercury control practices,  including the  purchase of
washed coal and the control  of emissions, were not
assumed to  occur. As a result, this source estimated that
mercury  releases  totaled  21.2  tons   annually,
corresponding   to   20.7   tons   per   year  for
commercial/industrial boilers and 0.5 tons per year for
residential boilers (USEPA 1997a; USEPA 1993a). It is
similar to an estimate of 23.6 tons in USEPA (1997b);
calculated  using the   same   emission  factors  for
bituminous and anthracite coal, but slightly different
energy  consumption  data.  The air release estimate
shown in Exhibit 4-4 presents both estimates.
                                                  45

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 Consumption:
7.6-21.2 tons/yr
                                         Residential, Commercial,
                                            and Industrial Coal
                                              Combustion
Product:
0 tons/yr
                                                              Releases: 21.8-24.2 tons/yr
                                                              -Air: 21.2-23.6 tons/yr
                                                          ->•  -Water: 0 tons/yr
                                                              -Disposal: 0.6 tons/yr
                                                              Recycling/Reuse: 0 tons/yr
                              Source:D  Mercury Consumption: Estimated using USEPA (2001) and USDOE (2002) for low
                                        end and USEPA (1997a) for high end.
                                      Mercury Release: Air releases estimated using USEPA (1997a) and USEPA
                                        (1997b). Disposal releases estimated using USEPA (1999d) and USEPA (1988a).
              Exhibit 4-4. Mercury in Residential, Commercial, and Industrial Coal
                                              Combustion
Water Releases
No water release estimate is available.

Solid Waste Releases
Mercury may be present in ash that is generated from the
combustion process and is subsequently landfilled. The
ash may also be used as a product; the estimate presented
here includes ash managed using both methods. Ash
generation for these boilers includes bottom ash and fly
ash.   The quantity and  composition of each  are a
function of the boiler technology as well as the specific
coal used (e.g.,  coal with high ash content generates
larger quantities of ash).   Furthermore, the degree to
which air pollution control devices are used is extremely
variable.

Control devices used include mechanical (e.g., cyclone),
fabric filter, and electrostatic precipitators.  Facilities
may not use  any control devices  at  all or may use
devices with low collection efficiency (USEPA 1999d).
The  type of air pollution control equipment in  place
affects whether fly ash will be generated at all, as well as
its characteristics.

Through the consideration of these factors on a plant-
specific  basis, an  annual ash generation rate  from
commercial and industrial non-utilities was presented in
USEPA  (1999d) using data from  the  1990 National
Interim Emission Inventory Database (USEPA 1990).

This estimate is 5.8 x 106 tons ash per year, for all types
                                       of ash.  As shown above, much less coal is used in
                                       residential  applications and its  contribution to  ash
                                       generation  is ignored.  Data regarding the mercury
                                       content  of ash from non-utilities are  not  available.
                                       Therefore, data from utility coal combustion wastes were
                                       used:  median concentrations of mercury in fly ash are
                                       about 0.10  mg/kg and  0.02 mg/kg in  bottom  ash
                                       (USEPA 1988a).  Using the fly ash concentration as a
                                       conservative value, about 0.6 tons of mercury are present
                                       in land disposed wastes.

                                       Product
                                       Mercury content of byproducts (e.g., recycled ash) are
                                       included in the "disposal" quantities.

                                       4.3.3 Discussion
                                       The total annual quantity of mercury in the raw material
                                       is estimated to be 9.3 tons.   The annual quantity of
                                       mercury released or in products is estimated to be 21.2
                                       tons to air, 0.6 tons to solid waste and products, and 0
                                       tons  to water.   Therefore, about 9 tons per year are
                                       assumed to enter the process and 22 tons per year are
                                       assumed to leave the process. This discrepancy is due to
                                       the different sources used in compiling these estimates.

                                       There is  a wide range in the quantity of mercury present
                                       in the raw material. USEPA (1997a) used median values
                                       in estimating this quantity,  resulting in  an estimate
                                       within  the  range  used  here.   This  estimate  was
                                       subsequently used as the basis for air emissions.  An
                                       independent source  for  air  emissions data  is  not
                                                    46

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available; therefore, it is very difficult to better identify
air releases. The above estimates show that almost all
the mercury present in the coal burned is emitted in the
stack gas.

Several other industrial sectors discussed in this report
use coal combustion as an onsite source for energy or
steam (this differs from  coke production where coal is a
raw  material).   As  discussed  in USEPA  (1999d),
industries accounting for a significant portion of coal-
fired non-utility generating capacity include  pulp and
paper,  primary metals, food  products, and  chemical
production.  Therefore, there is potential for 'double
counting' in cases where coal combustion industries are
specifically discussed in this report.

4.4 Byproduct Coke Production
4.4.1 Introduction
Facilities producing coke byproducts may be classified
under the following business classifications:

    SIC  Code 3312:   Steel  Works,  Blast  Furnaces
    (including Coke Ovens), and Rolling Mills (except
    coke ovens not integrated with steel mills).

    NAICS Code 324199: Coke oven products (e.g.,
    coke, gases, tars) made in coke oven establishments
    not integrated with steel mills.

    NAICS Code 333111: Coke oven products made in
    steel mills.

Coke has been used in iron and steel production for over
100 years.  As a byproduct of certain types of coal
combustion, coke is composed of nearly pure carbon.
Coke revolutionized  iron and steel production in the
1870s because it burned at much higher temperatures
than coal (Keller 1997).   Coke is also used in other
metallurgical  applications, for ferrous  and nonferrous
metal production, forming, and recycling activities.

Coke may be produced at large integrated steel mills that
use coke for blast  furnace operation.  It may also be
produced by independent facilities who subsequently sell
the  product in a wide  variety of markets.  Coke is
produced   by  burning  coal  in  an  oxygen-poor
environment at temperatures in excess of 2,200°F (Buss
1999), releasing the noncombustible contents within the
coal as gases (Keller 1997).  In  1991, there were 19
byproduct  coke  producers  in  the  United  States
(Huskannen 1991 cited in USEPA 1997a). Most coke in
the United States is produced in slot oven byproduct
batteries (USEPA 1997a).  The slot oven coke battery
consists of a series of narrow ovens with heating flues
between each oven pair. Pulverized coal is fed into each
oven and  combusted for 12 to 20 hours, burning off
nearly all volatile matter and forming coke. The coke is
then unloaded into a rail car where it is cooled by a water
rinse (USEPA  1997a).

4.4.2 Materials Flow
Exhibit 4-5 illustrates  the  flow  of mercury in coke
production.

Mercury Consumption
Kirk-Othmer (1993) estimates that 27 million tons of
coke were produced in the United States for the steel
industry in 1990.  The quantity  of coal used as raw
material for 2000 is estimated  as 29  million tons
(USDOE 2002). In Section 4.3.2,  the mercury content
of coal was estimated as about 0.11 tons of mercury per
million tons of coal  (using USEPA 2001).   This
nationwide weighted average is most appropriate for fuel
coal and may not be applicable to coal used for coke
production. Nevertheless, using these data results in an
estimate of 3.2 tons mercury in the incoming coal per
year, which is reflected in Exhibit 4-5.

Product
There were no data regarding the mercury content in
product coke.   Additionally, there  were  no  data
regarding  mercury  emissions  in  the  iron  and steel
manufacturing process where coke is used. It is assumed
that nearly all of the mercury is volatilized from the coke
during  the coke production process.

Air Release
There are no reported mercury emissions from byproduct
coke plants in the Toxics Release Inventory.  However,
mercury is probably present in the volatilized  gases
released during the coking operation (USEPA 1997a).
Mercury may also be emitted through door leaks and
from the stacks. Sang and Lourie (1995) report that 306
kg (0.7 tons) of mercury are released from coke-making
operations in the Great Lakes Basin.  Using emissions
factors from European coke plants, USEPA (1997a) also
estimates that potential emissions  from domestic coke
plants are  about 0.7 tons per year.  This estimate is used
in Exhibit 4-5.
                                                  47

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                    Consumption:
                     3.2 tons/yr
Coke Production
     Product:
Estimate not available
                                                       Releases: 2.2 tons/yr
                                                       - Air: 0.7 tons/yr
                                                      • - Water: 0 tons/yr
                                                       - Disposal: 1.53 tons/yr
                                                       Recycling/Reuse: 0 tons/yr
                    Source:   Mercury Consumption: Estimated from coal use (USDOE 2002) and concentration data (USEPA 2001).
                           Mercury Release and Recycling: Air releases estimated using EPA Mercury Study Report to Congress (1997a).
                           Disposal releases from 1999 TRI.
                           Mercury in Product: Estimate not available.
                                Exhibit 4-5.  Mercury in Coke Production
Water Release
Mercury may be found in the rinse water.  However no
estimate of this quantity is available.

Solid Waste
Evaluation  of 1999 TRI  data  showed  three  steel
production companies  reporting mercury emissions.
These releases were assumed to be the result of coke
production.   A total of 1.53 tons were disposed in
landfills; zero releases were reported to other media.
This estimate is shown in Exhibit 4-5.

4.4.3 Discussion
Due to the severity of the process conditions, the coking
process should volatilize nearly all of the mercury within
the  coal.   There  is,  however,  a large  apparent
discrepancy between the estimate of mercury within the
coal entering  the  coking facility  (4.9 tons),  and the
estimate of mercury leaving the facility as emissions (1.8
tons). This discrepancy may be the result of differences
in the data sources used.

4.5  Portland Cement Manufacturing
4.5.1 Introduction
Facilities manufacturing portland  cement  may  be
classified under the following business classifications:

    SIC Code  3241:  Hydraulic Cement Manufacture

    NAICS Code 32731: Cement Manufacturing
               USEPA's Report to Congress  on Cement Kiln Dust
               (1993b) states that United States clinker production in
               1990 was 65.1 million tons from 115 plants, representing
               a production capacity of 76 million tons per year. This
               is  somewhat lower than the data presented  in  the
               Mercury Study Report to Congress (81 million tons of
               capacity at 212 plants for 1990).

               Mercury emissions are a byproduct of Portland cement
               manufacturing because  the  raw materials and  fuel
               contain small amounts of mercury. Portland cement is
               manufactured using a mixture of gypsum, limestone, and
               silica.  After the rock is quarried, a series of crushers
               reduce it to an appropriate size to be used as cement kiln
               feed.  The final rock size is approximately three inches
               or smaller. The raw material is then processed through
               either the "wet" or the "dry" process, depending on the
               cement manufacturing facility. In the "wet" process, the
               raw material is mixed with water during the grinding
               step to form a slurry, and is  then fed to  the kiln as a
               liquid. In the "dry" process, rather than mixing the raw
               materials with water, the raw  materials are dried to
               reduce the moisture content, then fed to the kiln.  The
               remainder of the cement production process is essentially
               the same.

               The wet or dry material is pyroprocessed at abouthi,700"
               F in a rotary kiln fed with powdered coal, oil or gas.
               Some gases are released during this process, and the raw
               material is transformed into clinker, hard gray nodules
               about the size and shape of marbles. The clinker is then
                                                    48

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cooled, and the heated air from the coolers is returned to
kilns  to  save fuels and  increase burning efficiency
(Portland Cement Association 1999).

4.5.2 Materials Flow
Exhibit 4-6 presents the flow of mercury through the
cement manufacturing process.

Mercury Consumption
Approximately 74.6 million tons of limestone  were
consumed  in cement production in  1990  (USEPA
1993b).   This  represents the  most significant raw
material  by weight, accounting  for 85 percent of kiln
inputs (coal  or other fuels were not included).  The
mercury  content of limestone is between 0.02 - 2.3 ppm
(USBM  1994),  with a second  source (CIBO  1997)
estimating a value of 0.04 ppm.  Using the CIBO value
           gives an estimated mercury input of 3 tons of mercury
           nationwide. The use of the USBM data would result in
           an extremely wide range of mercury.

           Additional mercury is present in fuels combusted onsite
           for heating the kilns.  These  fuels include coal, oil,
           natural  gas,  and  hazardous  wastes  (e.g., organic
           solvents). However, in 1990 coal was the dominant fuel
           used, accounting for 71 percent of the total heating value
           (147xl012 Btu) (USEPA 1993b).  The mercury content
           in coal ranges from 4.8 to 36.4  pounds per 1012 Btu
           (USGS 1998), accounting for about 0.35 to 2.7 tons of
           mercury per year for this process.

           Adding the contributions from  coal and  limestone, the
           two most significant  contributors,  gives an  estimated
           mercury loading of 3.4 to 5.7 tons per year.
                        Consumption:
                        3.4-5.7tons/yr
 Portland
 Cement
Production
    Product:
Estimate not available
                                                      Releases: 4.8 tons/yr
                                                      -Air: 4.2 tons/yr
                                                     - - Water: 0 tons/yr
                                                      - Disposal: 0.6 tons/yr
                                                      Recycling: 0 tons/yr
                             Mercury Consumption: Estimated from coal use and concentration data (USGS 1998; USEPA 1993b).
                             Mercury Release and Recycling: Air releases estimated using EPA Mercury Study Report to Congress (1997a). Disposal
                               releases estimated using Cement Kiln Dust Report to Congress (USEPA 1993b).
                             Mercury in Product: Estimate not available.
                             Exhibit 4-6.  Mercury in Cement Manufacturing
Product
No data regarding the mercury content of the final
cement  product  is  available.    Because  mercury
evaporates at approximately 660*F  while the  kilns
operate at 2700«F, most of the mercury present in the
raw materials probably volatilizes during production.

Air Release
Most of the mercury emitted during cement production
comes from the kiln and preheating/precalcining steps.
Minor sources  of mercury  emissions  may include
particulate matter (PM) from raw material processing
and  emissions from fuel  combustion.  The mercury
emission rate for the entire cement production process
was estimated to be 1.3xlO"4 pounds of mercury per ton
           of clinker (USEPA 1997a). With 65.1 million tons of
           clinker produced in 1990, this results in approximately
           4.2 tons mercury emitted to the air each year.

           Solid Waste Release
           Particulate  emissions   are   controlled  during  the
           pyroprocessing steps by fabric filters and ESPs.  The
           resultant material from dust collection is cement kiln
           dust, a material that can be reused onsite (i.e., in the
           cement production process) or disposed. A total of 14.2
           million tons of this material was generated in 1990, of
           which 5  million  tons was  not recycled to the system.
           Based on  the analysis  of 17 samples collected by
           USEPA, a mercury concentration range of 0.005 to 14.4
           mg/kg (median of 0.11 mg/kg) was determined.  Using
                                                    49

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the median value and the quantity of 5 million tons
cement kiln  dust that was  not recycled, a mercury
loading of 0.6 tons of mercury is estimated (range 0.03
to 72 tons). There are no additional data on the specific
ability of these systems to capture mercury emissions
from cement kilns, so the quality of this estimate cannot
be compared with other data sources.

4.5.3 Discussion
There are no mercury TRI  data for Portland cement
manufacturing facilities for 1999.

The estimates presented here are based on data from
1990.  An uncertainty is  the trends of the  domestic
production of cement, as well as trends  in raw material
use.  As shown above, coal contributes a significant
amount of mercury to the raw material input of kilns.

Most  of the estimates vary widely, mostly due  to the
large quantities of materials involved. The result is that
the quantity  of a given raw material  used  or  waste
generated is not likely to have  as much error  as the
composition of that material with regard to mercury.
Limited  data  with  wide   ranges were  used  in
characterizing the composition of these materials.  A
more accurate approach would be to consider a plant-by-
plant analysis, considering the composition of mercury
in the raw materials and emissions together with the site-
specific  generation  rate.    However,  such  data (or
immediate plans to obtain it) are not available.

4.6 Coal Combustion Waste Products
4.6.1 Introduction
Large quantities of coal combustion wastes are used or
sold for applications other than disposal. Wastes (such
as  ash)  generated  from   utilities, industries, and
commercial applications can be re-used.  In all cases, any
mercury in the ash is present as a contaminant  which
may potentially be released to the environment during or
following use.

In  1997, the  following  quantities of utility coal
combustion wastes were reused: 19.3 million tons of fly
ash (31.5% of all fly ash generated), 5.1 million tons of
bottom  ash (27.7% of all  bottom ash generated), 2.6
million tons  of boiler slag  (92.9% of all boiler slag
generated),  and  2.2  million  tons   of flue  gas
desulfurization (FGD) wastes (7.9% of all FGD wastes
generated). Although similar quantitative data are not
available  for  non-utility  sources  of  ash,  available
information indicates that the wastes are used in similar
or identical applications. The largest uses of utility coal
combustion wastes are the following (in decreasing order
of quantity used in  1997):  cement  and  concrete;
structural fill;  waste stabilization; road base; blasting
grit;  mining  applications;  wallboard;  snow and ice
control; mineral filler; flowable fill; and agriculture
(USEPA 1999d).

4.6.2 Materials Flow
Using the compositional data presented in Section 4.1,
the quantity of mercury in product uses is estimated to be
3.0 tons per year (median), with a range up to 103 tons
per year (the upper end of the range assumes that all
wastes exhibit their highest concentrations).

By reviewing  the above list of product applications,
many of the uses  involve direct placement on the land
where  the material is not expected to be moved.  For
example, in agricultural uses the waste  is applied directly
to soil, and in structural fill or road base applications the
material is used as a base for further construction that is
expected to last for many years. In waste stabilization,
the ash becomes part of the solid waste matrix which is
subsequently landfilled.

Other uses, including use as wallboard, blasting grit, and
mineral filler, do  not include immediate placement on
the land. Instead, any mercury in the coal combustion
waste would be incorporated into the  commercial or
consumer product and then eventually landfilled.  Using
the  compositional data presented in Section 4.1, the
quantity of mercury in these three uses is estimated to be
0.73 tons (median), with a range up to 22 tons (the upper
end of the  range assumes that all wastes exhibit their
highest concentrations).  Therefore, this  quantity of
mercury is used in commerce, then probably disposed in
a landfill.

Very little information is available discussing the  fate of
contaminants,   including  mercury,  in   product
applications.   For  example,  it is  not known  if the
mercury migrates from its land-based applications to air,
stormwater runoff, or other media.

4.6.3 Discussion
Section 4.1 of this  report identified that solid coal
combustion wastes, such as  fly ash and bottom ash, are
either disposed of or are used as products. The estimates
from Section 4.1 are intended to present all management
methods for coal combustion wastes,  and therefore the
estimates presented in this section necessarily duplicate
                                                   50

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those identified in Section 4.1.  This section is intended
to highlight  specific management methods of coal
combustion wastes.  The same uncertainties  regarding
the quality of the estimates in Section 4.1 are applicable
here.  Chief among these concerns is the variability of
waste composition and the small amount of data that
exists regarding mercury in wastes.   Methods being
considered for reducing mercury in stack air emissions
include  capturing the mercury in fly ash.  The use of
such controls are expected to increase in the future, with
a corresponding increase in the quantity  of mercury
present  in the generated solid wastes. However, the
magnitude of such changes cannot be predicted.

As discussed in this section of the report, many of these
applications involve  placement of the material on the
land so that, regardless of whether the waste is disposed
or used as a product, the mercury present in the waste is
placed on the land. Once on the land, however, there is
no  information  regarding  its  environmental fate  as
staying in the ash matrix, entering the air, or entering the
water.
                                                   51

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                                              Chapter 5
                Incidental Mercury Use Associated With Non-Coal Sources
5.1 Oil Combustion
5.1.1 Introduction
Oil combustion is used by utilities to generate electricity
and is used by industrial and commercial (non-utility)
facilities to generate steam,  electricity,  or heat for
miscellaneous industrial applications (USEPA 1999d).
Additionally, there are  residential applications of oil
combustion as  a  heating  fuel.    Fuel usage   and
technologies differ between each of these three sectors,
and therefore the use and releases of mercury differ in
each as well.

In the utility  sector, the total amount  of  electricity
generated from oil combustion is small relative to the
total  generation of  electricity by  coal  and  other
technologies.  Oil  is used at a much larger number of
industrial and non-utility facilities, and accounts for a
larger capacity as well: oil-fired utilities have a capacity
of 43,000 MW, and oil-fired non-utilities have a capacity
of 54,000 MW, based on 1994 data (USEPA 1999d).

Utilities  predominantly  use  residual (No. 6) fuel oil,
while lighter and more expensive distillate (No. 2) fuel
oil is used for auxiliary or start-up purposes. Residual
oil has a higher ash content than distillate oil, leading to
increased levels of combustion bottom  ash  and air
pollution control fly ash.  However, the majority of oil-
fired  utility power plants do not use air pollution or
particulate control  equipment, and  therefore do  not
collect fly ash.  This is because the ash content of oil
(even residual oil) is much lower than coal and their
emissions characteristics may not require the addition of
air pollution control equipment (USEPA 1999d).  The
predominant  fuel  used  in non-utility and residential
applications is distillate oil. These units are smallerthan
combustion units in the utility sector. Therefore, the
quantity  of ash generation in these sectors are expected
to be even less than in the utility sector.  Nonetheless,
mercury  releases still occur.

5.1.2 Materials Flow
Exhibit   5-1  illustrates  the  flow  of mercury in oil
combustion in  utility,  non-utility,  and  residential
combustion units.

Mercury Consumption
Data are available quantifying the amount of fuel oil
used in utility, non-utility, and residential applications.
For the utility and non-utility sectors, the quantity of fuel
oil used in  1996 is as follows (USEPA 1999d):

•  Utility, residual oil: 3,900 million gallons
•  Utility, distillate oil: 684 million gallons
•  Non-utility, residual oil: 3,100 million gallons
•  Non-utility distillate oil: 5,500 million gallons

For the residential  sector, the quantity of oil is  not
directly available. However, the heating content of oil
used in the non-utility and residential sectors is reported
as 2,180 and  880 trillion Btu, respectively, in  1994.
Assuming that the heating value of oil used in these two
sectors is similar, and that only distillate oil is used for
residential applications, the quantity of oil estimated to
be used in residential applications  is 3,500 million
gallons of distillate oil.

The mercury content of these fuels  is expected to be
variable. Minnesota (1999) provides estimates of the
mercury content of product oils, reporting that residual
oil has 0.004 ppm mercury and distillate oil has 0.001
ppm mercury.  Using the concentration data together
with the above  volume  data  provides the following
estimates for the mercury content of raw materials in
1996:

•  Utility: 0.06 tons of mercury (corresponding to 0.06
   tons from residual oil and 0.003 tons from distillate
   oil)
•  Non-utility: 0.07 tons of mercury (corresponding to
   0.05 tons  from residual  oil  and 0.02 tons from
   distillate oil)
                                                    52

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         Consumption:
          0.06 tons/yr
     U.S.
  Utility Oil
Combustion
Product:
0 tons/yr
                                                      Releases: <0.75 tons/yr
                                                      - Air: 0.2 tons/yr
                                                     • - Water: 0 tons/yr
                                                      - Disposal: <0.55 tons/yr
                                                      Recycling: 0 tons/yr (offsite)
         Consumption:
          0.07 tons/yr
       U.S.
   Non-Utility
Oil Combustion
    Product:
    0 tons/yr
                                                        Releases: 5.1-7.8 tons/yr
                                                        -Air: 5.0-7.7tons/yr
                                                       - - Water: 0 tons/yr
                                                        - Disposal: <0.13 tons/yr
                                                        Recycling: 0 tons/yr (offsite)
           Consumption:
            0.01 tons/yr
       U.S.
   Residential
Oil Combustion
  Product:
  0 tons/yr
                                                        Releases: 2.8-3.2 tons/yr
                                                        -Air: 2.8-3.2 tons/yr
                                                       - - Water: 0 tons/yr
                                                        - Disposal: 0 tons/yr
                                                        Recycling: 0 tons/yr (offsite)
           Source/a   Mercury Consumption: Composition data from Minnesota (1999). Use data from USEPA (1999d).
                    Mercury Release and Recycling: Disposal releases estimated from USEPA (1999d). Air releases
                      estimated from USEPA (1997a) and USEPA (1997b).


Exhibit 5-1. Mercury in Utility, Non-Utility, and Residential Oil Combustion
                                             53

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    Residential: 0.01 tons of mercury (corresponding to
    0.01 tons from distillate oil).

Product
There are no products. In cases where ash is recycled,
these estimates are incorporated as solid waste releases.

Air Releases
The estimates of mercury releases from utility, non-
utility, and residential combustion of oil vary depending
on the mercury emission factors that were used in the
calculations. These estimates are as follows:

Utility: 0.2 tons/year
Non-utility:  5.0-7.7 tons
Residential:  2.8 - 3.2 tons

For utility boilers, mercury emissions were estimated
using emissions  data available from 58 emission tests
conducted by USEPA, the  Electric Power Research
Institute (EPRI), the Department of Energy (USDOE),
and  individual  utilities.    Boiler-specific  emission
estimates  were  then calculated  by multiplying  the
calculated inlet mercury concentration by the appropriate
emission factor for each boiler configuration and control
device.

For non-utility and residential boilers, the ranges account
for the different mercury  emission factors for oil that
were used in the Mercury Study Report to Congress
(USEPA 1997a) and in Locating and Estimating  Air
Emissions from Sources  of Mercury and Mercury
Compounds (USEPA 1997b).  The following factors
were used in the Report to Congress:

    Residual Oil (No. 6): 2.9 kg/1015 J
    Distillate Oil (No. 2): 3.0 kg/1015 J

The following  emission  factors  were  used in  the
Locating and Estimating Air Emissions document:

    Residual Oil (No. 6): 2.7 kg/1015 J
    Distillate Oil (No. 2): 0.02 kg/1015 J

The mercury  emission factors  for residual oil and
distillate oil  were  multiplied  by oil  consumption
estimates in order to estimate the amount of mercury
released to air.

Solid Waste Releases
Air pollution control devices are most frequently used in
the utility sector.  An estimated quantity of 23,000 tons
of oil combustion waste were collected in 1995.  Air
pollution control equipment is less frequently used in the
non-utility  sector, and therefore  fewer oil combustion
solid wastes are produced.  An  estimated quantity of
5,500  tons of oil  combustion  waste  are collected
annually (USEPA 1999d).  Solid waste releases in the
residential  market is assumed to be negligible.  This
sector operates smaller boilers than the utility sector, and
is more likely to use lower ash distillate oil.  As a result
of these factors, this sector is the  least likely to employ
air pollution control devices which generate solid waste.

The  mercury  content  in these wastes is variable,
depending  on  their type and other facility-specific
factors. The overall range for mercury is approximately
0.06 ppm to 24 ppm (USEPA 1999d).  Using the upper
end of this range in conjunction with the waste quantities
listed above, the mercury loadings from these solid
wastes are as follows:

•   Utility: <0.55 ton
•   Non-utility: <0.13 ton
•   Residential: Negligible

 Water Releases
No water releases are expected.  Water is used for air
pollution control, but solids in the water which may
contain mercury are expected to settle prior to discharge
or other release to the environment.

5.1.3 Discussion
In all  cases the  quantity  of mercury  assumed to be
released is less than the quantity of mercury assumed to
be present  in the raw material.  This discrepancy  is
probably due to the variability of mercury in the raw
material.   The data  reported in USBM (1994) are
probably high.

The estimates  for air releases are based on the use of
emission factors.  Emissions are expected to vary from
facility to facility based on the mercury content of the
raw material and the type of control technology in place.

5.2 Carbon Black Production
5.2.1 Introduction
Carbon black consists of fine particles of carbon usually
formed by  incomplete combustion  of hydrocarbons in
the oil-furnace  method.  This substance  is frequently
used as a filler in rubber manufacturing to add both
toughness and abrasion  resistance to the final product.
                                                   54

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The mercury in carbon black production comes from the
hydrocarbon feedstock, similar to Number 6 (residual)
fuel oil, which has an average mercury content of 0.06
ppm (USBM 1994).

The three primary raw materials used in the production
of carbon black are feedstock (either a petrochemical oil
or a carbochemical oil), air, and an auxiliary fuel such as
natural gas.  The feedstock is preheated to a temperature
of between 150 and 250°C, and the air is also preheated.
A turbulent, high-temperature zone  is created in the
reactor  by  combusting  the   auxiliary  fuel  and  the
preheated oil feedstock. The feedstock is introduced into
this zone as an atomized spray.   In this zone of the
reactor, most of the oxygen is used to burn the auxiliary
fuel, resulting in insufficient oxygen to combust the oil
feedstock. Thus pyrolysis of the feedstock is achieved,
and carbon black  is produced (USEPA 1997a). The air
stream containing the product is cooled and the product
is collected in a fabric filter.  It is shipped in dry form,
primarily for use in the rubber industry.
            Mercury Consumption
            Mercury  may be  present  in  the  residual  oil feed.
            Assuming that the concentration of mercury in the feed
            is 0.06 ppm  (USBM  1994), and the quantity  of oil
            consumed is equal to the production capacity  of the
            carbon black (1,830,000 tons/year from USEPA 1997a),
            the quantity of mercury in the feed is estimated as 0.11
            tons/year.

            Product
            The quantity of mercury in the product is not known.  It
            is reasonable to expect that some of the mercury  would
            be collected in the fabric filter.

            Air Releases
            In  1995,  mercury  emissions  from  carbon  black
            production were estimated to  be 0.28 tons (USEPA
            1997a). This estimate is expected to be an overestimate
            because it is based on production capacity (rather than
            actual production, which is not known), and the use of a
            furnace emission factor developed from 1980.
5.2.2 Materials Flow
Exhibit 5-2 illustrates the consumption, release, and
product content of mercury in carbon black production.
            Water and Solid Waste Releases
            No  release  points  for  these  media are  identified.
            Releases are estimated as zero.
                      Consumption:
                       0.11 tons/yr
     U.S.
Carbon Black
 Production
  Product:
Not available
                                                        Releases: 0.28 tons/yr
                                                        -Air: 0.28tons/yr
                                                       • - Water: 0 tons/yr
                                                        - Disposal: 0 tons/yr
                                                        Recycling: 0 tons/yr
                       Source:   Mercury Consumption: USBM, 1994.
                              Mercury Release and Recycling: EPA, 1997a
                              Mercury in Product: No estimate available.
                            Exhibit 5-2. Mercury in Carbon Black Production
                                                    55

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5.2.3 Discussion
The  estimates for the mercury  in  raw material  and
mercury in air releases are both uncertain because of the
limited information each is based upon. Additionally,
the quantity estimated to be released is greater than the
quantity estimated to be fed to the process, indicating
additional difficulties with the data quality. Finally, an
estimate for the quantity of mercury in the product could
not be developed although this may not necessarily be a
zero quantity.

5.3 Gold Mining
5.3.1 Introduction
While the major source of mercury is  supplied by
secondary sources, additional quantities of mercury are
obtained as a byproduct of gold mining.  Mercury is
present in gold ore; one source estimates a concentration
of 9 ppm although the concentration is expected to vary
based on location (USBM 1994). As of 2001, less than
10 gold mines recovered mercury from the ore (USGS
2002a).  The  remaining gold mines did not recover
mercury,  although  some mercury is  expected to be
present in the gold ore and in waste materials.

In gold mining, gold-containing ore is crushed and then,
if necessary, roasted to remove sulfur.  Mercury that is
present in the ore  is vaporized and collected in air
pollution control devices; mercury in these wastes may
be either disposed or recovered in an  onsite retort
furnace. Following roasting, the ore is mixed with water
and reacted with a cyanide leach solution where gold and
mercury are dissolved and solids removed via filtration.
The  purified solution is  sent  to  an  electrowinning
process, where the gold is deposited  on a steel cathode.
If necessary, the cathode is sent to a retort furnace for
mercury removal, then to a smelting furnace to volatilize
and purify the gold. In a retort furnace, the mercury is
collected by a condenser for subsequent sale (USEPA
1997a). Therefore, mercury present in gold ore may be
released  to the land  (e.g.,  in disposed air  pollution
control wastes and spent ore tailings), to the air (e.g., not
removed by air pollution control devices), or in the gold
product (i.e., as an impurity).

Mercury was used through the early 1900's throughout
the western United States during gold mining (i.e., gold
amalgam process). Mercury was added to the ores to aid
in recovery, which resulted in widespread contamination
of mine waters and sediments (USGS 2000b). In the
United  States, mercury is  no longer used  in  gold
recovery operations although such use continues in other
parts of the world.

5.3.2 Materials Flow
Exhibit 5-3 illustrates the consumption,  release,  and
product content of mercury in gold mining.

Mercury Consumption
The mercury input from trace impurities in gold ore to
the gold mining process is assumed to be equal to the
amount released, as estimated below.

Releases
Mercury that is present in the ore can remain in the
waste rock or can be vaporized; the volatile mercury can
be released to the atmosphere or be collected in air
pollution  control  devices for mercury  recovery  or
disposal.  Specific sources of mercury during gold ore
processing have been estimated by one company. Of
1,500 pounds of mercury estimated to be released to air
during processing, 23 percent were from milling (e.g.,
crushing), 29 percent from autoclaves, 31 percent from
electrowinning and retort, and 15 percent from furnace
stack.  Other facilities  reporting significant mercury
releases also operate autoclaves or roasters (Elko Daily
2000b).  An estimated  10 to 50 percent of mercury
contained  in the  rock  is  removed for recovery (or
release) later in the process (Menne 1998).

There is contradictory information regarding the quantity
of mercury recovered during gold mining. USGS (1997)
indicates that this quantity is insignificant in comparison
to the  quantity of mercury produced  from mercury
recyclers  (420  tons in 1997),  while a newspaper
indicates that Nevada mines alone supply 110 to  150
tons per year (Elko Daily 2000a). An industry source
estimates  that total worldwide byproduct production
(from gold, copper, etc.) is 400 tons per year (Lawrence
2000).  Finally, 1999 TRI data shows that four Nevada
facilities reported onsite recycling (recovery) of 21.6
tons of mercury. Onsite recycling data from TRI were
not available for any other  domestic  gold  or silver
mining facility.  The TRI estimate is shown in Exhibit 5-
3 as a recovered product.

Both industry and academic sources suspect that most of
the 1999 TRI air emission estimates for mercury in this
industry are based on estimated, rather than measured,
mercury data (Elko Daily 2000b).
                                                   56

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                         Consumption:
                          1,370 tons/yr
Gold Mining
Product:
0 tons/yr
                                                           Releases: 1,348 tons/yr
                                                           -Air: 6.2 tons/yr
                                                           -Water: 0tons/yr
                                                           '-Disposal: 1,342 tons/yr
                                                           Recycling: 21.6 tons/yr
                                                             (produced on-site)
                                               Mercury Consumption: Equal to releases plus recycling.
                                               Mercury Release and Recycling: 1999 TRI Data.
                                  Exhibit 5-3. Mercury in Gold Mining
Eight facilities, all  from Nevada, reported releases of
mercury (or mercury compounds) in the 1999 TRI. Not
all of these facilities produce  mercury as a product.
Total air releases were  6.2 tons.  Total water releases
were  4  pounds (0.002 tons).  Total (offsite) mercury
recycling was 0.06 tons. Total onsite land releases were
2,700,000  pounds  (1,342 tons).  The high disposal
quantity consists primarily of  tailings in waste rock.
These estimates are shown in Exhibit 5-3.

5.3.3 Discussion
The available estimates of mercury releases from gold
mining vary widely, from 400 tons per year to 1,350 tons
per year, indicating a need for better data.

Beginning  with  the  1998  reporting  year,  mining
operations  (including gold mining) have been required
to complete toxic release inventory (TRI) reports. These
data will show reported releases of mercury (and other
TRI  pollutants),  and  may subsequently serve  as
incentives to better monitor or control these emissions so
that companies can report decreases for these emissions.
Lowering of the reporting threshold for mercury in the
2000  reporting year for TRI will result in many smaller
facilities  (including gold  mining  operations  that
presently do not recover mercury) being  required to
report multimedia emissions, which will improve the
quality of data for this sector.
       5.4 Primary Lead and Zinc Mining and Smelting
       5.4.1 Introduction
       Mercury is potentially present in lead ores.  Lead is
       primarily mined in Missouri  and Alaska for smelting
       (USGS 2000c).  The variability of mercury in lead ore is
       expected to be less than the variability from other mined
       materials that are recovered from a wider area of the
       U.S.

       Zinc  ore  is primarily mined  in  Alaska, with smaller
       quantities  obtained  from Tennessee, New York, and
       Missouri. Ore is processed in one of three domestic U.S.
       smelters (USGS 2000a).

       The ores are mined and then  concentrated, generating
       tailings as a waste.  The concentrate is fed to a sintering
       process, where  sulfides  are driven  off using heat
       (mercury is likely volatilized in this step).  The sintered
       material is  fed  to a blast  furnace with coke  and  slag
       forming constituents.  Crude  metal (elemental lead or
       zinc) is removed as molten material and then refined.

       5.4.2 Materials Flow
       Mercury Consumption
       The concentration of mercury in lead ore concentrate
       (representative of the ore presently mined) is  less than
       0.2 ppm (USEPA 1997a). This results in approximately
       0.18 tons/year; this quantity is reflected in Exhibit 5-4.
       This is based on primary (mined) lead production of
       400,000 tons in 1994, use of emission factors for air
                                                    57

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pollution control equipment following the sintering and
furnace operations, and the assumption that 10 tons of
ore concentrate produces 4.5 tons of lead.  No data are
available for zinc ores.

Air Releases
Based on the lead ore concentration and the use of an
emission factor, USEPA (1997a) estimated annual air
           emissions of mercury from lead smelting as 0.11 ton
           (USEPA 1997a). Evaluation of 1999 TRI data showed
           that one  zinc smelting  company  reported mercury
           releases.  Mercury released into the air was 0.07 ton.
           The TRI air release is  shown in Exhibit 5-4.

           Water Releases
           No water releases were identified.
                       Consumption:
                        0.18tons/yr
     U.S.
Primary Lead
  and Zinc
 Production
Product:
0 tons/yr
                                                           Releases: 7.8 tons/yr
                                                           -Air: 0.18tons/yr
                                                          • - Water: 0 tons/yr
                                                           - Disposal: 7.6 tons/yr
                                                           Recycling: 0 tons/yr
                         Source'.     Mercury Consumption: Based on USEPA (1997a) for lead ore.
                                  Mercury Release and Recycling: Air releases estimated using USEPA (1997a) and 1999
                                    TRI data. Disposal releases estimated using 1999 TRI data.
                       Exhibit 5-4.  Mercury in Primary Lead and Zinc Production
Solid Waste Releases
It is assumed that mercury present in the  lead ore is
either released to the  atmosphere or collected in air
pollution control waste and disposed. The  quantity of
mercury present in such solid wastes and disposed is
estimated as 0.07 tons, which is the difference between
the mercury in the ore and mercury released to air.

Evaluation of 1999 TRI data showed one company in
this sector reported mercury release.  This facility is a
zinc smelter that accepts both ores and waste materials
(electric arc furnace dust from iron production) (USGS
2000a); mercury is a contaminant in these raw materials.
Mercury releases were  7.6 tons as solid waste.  The sum
of these two releases are reflected in Exhibit 5-4.

5.4.3 Discussion
Exhibit 5-4  shows  a  large  discrepancy  between
consumption and release. This is potentially due to the
absence of information regarding the mercury content of
raw materials accepted by zinc processing facilities; only
the mercury content of raw materials accepted by lead
processing facilities are identified in Exhibit 5-4.
           5.5 Primary Copper Mining and Smelting
           5.5.1 Introduction
           Mercury is potentially present in copper ores.  As with
           other ores, copper ore is mined and then concentrated,
           generating tailings as a waste. The copper concentrate
           is fed to a smelting furnace with coke and slag forming
           constituents.  Crude  elemental copper is removed as
           molten material and then is further processed, using heat
           to remove iron and other impurities.  Mercury may be
           driven off in the furnace  or subsequent melting of the
           copper (USEPA 1997a).

           5.5.2 Materials Flow
           Copper was recovered at 27 mines in the U.S. (USGS
           2000d) and loadings of mercury in the ore were reported
           for five facilities. Air releases for seven plants were
           provided, with air releases much less than the reported
           ore loadings on a plant-by-plant basis. The cumulative,
           industry-wide total for mercury in ore concentrate is 6.4
           tons, and the  industry-wide total for mercury  in air
           releases is 0.06 tons (USEPA 1997a).  The remaining
           mercury  is assumed to  be present in the  solid  air
           pollution  control wastes.   Exhibit 5-5 illustrates the
                                                    58

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consumption, release, and product content of mercury in
primary copper mining and smelting.

Evaluation of  1999 TRI  data showed two  facilities
reported mercury.  One facility was an ore concentrator
operation and  the  second facility was  a  smelting
operation. Mercury releases were 16.35 tons as solid
          waste, 0 tons to surface water, and 0.036 tons released to
          the air. The air emissions from the facility were added
          to the industry-wide total for air releases, as shown in
          Exhibit 5-5.

          5.5.3 Discussion
          The discrepancy between consumption and release in
          Exhibit 5-5 may be the result of variation in the ores.
                        Consumption:
                         6.4 tons/yr
     U.S.
Primary Copper
  Production
Product:
0 tons/yr
                                                              Releases: 16.4 tons/yr
                                                              -Air: 0.1 tons/yr
                                                              -Water: 0tons/yr
                                                              - Disposal: 16.35 tons/yr
                                                              Recycling: 0 tons/yr
                                        Mercury Consumption: USEPA1997a.
                                        Mercury Release: USEPA (1997a) for air releases and 1999 TRI data for other releases.
                          Exhibit 5-5. Mercury in Primary Copper Production
5.6 Pulp and Paper Manufacturing
5.6.1 Introduction
Mercury can be present in pulp and paper facilities as a
raw material impurity. It may also be present at facilities
that operate chlor-alkali mercury cells as part of the pulp
and paper manufacturing process; however, the latter
operations are discussed elsewhere in this report.

Pulp and paper plants use a variety of raw materials that
potentially contain mercury.  These include the wood,
purchased   chemicals  containing  mercury  as  a
contaminant, and coal used in onsite boilers for steam
generation.  Key process steps of pulp manufacturing
with  regard  to  potential mercury  use include:  (1)
debarking and chipping of the logs; (2) chemical pulping
using sodium hydroxide and sodium sulfide  as typical
raw materials; (3) bleaching using chlorine, chlorinated
compounds, and sodium hydroxide as raw materials; and
(4) combustion  or recovery  processes  (Kirk-Othmer
1996).  There are approximately 150 pulp mills in the
U.S. (USEPA 1997a).
           5.6.2 Materials Flow
           Based on the above process description, and on available
           mercury content information for several raw materials,
           mercury may be present in the following raw materials:
           coal (used in onsite boilers), sodium hydroxide (mercury
           may be present if generated from chlor-alkali process),
           bark (mercury may be present at levels from 0.08 ppm to
           0.84 ppm [USEPA 1999d]), and sulfuric acid (mercury
           was found to be present in sulfuric acid purchased from
           a lead smelter [USEPA 1997b]). Any mercury present
           in  these raw materials is likely released  to  the
           environment through air, water, or land disposal.

           The quantities of mercury entering a pulp  and  paper
           process are not known.  In  cases where concentration
           data are available, the quantity  of the raw material is
           typically not available. Data for releases are incomplete.
           An estimate of 1.9 tons of mercury per year, presented in
           USEPA's Report to Congress  (1997a), is principally
           based on the combustion of coal and/or waste products
           such as bark.  Quantities of mercury in water and land
           disposal are unavailable; no pulp  and paper facilities
                                                   59

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reported releases to the 1999 TRI.

5.6.3 Discussion
Pulp mills are one of many industries that combust coal
for steam or electricity production.  The combustion of
these industrial sources of coal are presented elsewhere
in this report, and would therefore account for at least
some of the use and release of mercury from this sector.

5.7 Oil Refining
5.7.1 Introduction
Mercury is  present in crude oil in varying amounts
depending on  its source.  U.S. refineries process, or
refine, crude oil  from domestic and imported sources.
The  mercury present in the  crude oil subsequently is
transferred to the products or is released to air, water, or
other media.
5.7.2 Materials Flow
Quantitatively, there are several sources of data available
to estimate the mercury content of crude oil processed in
the U.S.  Recent data from Minnesota (1999) identifies
a range of 2.5 to  13 ppb.  USEPA's (1997a) Mercury
Study Report to Congress reports the mercury content of
crude oil as 0.023  to 30 ppm weight, and USBM (1994)
gives a 'typical' mercury content of 3.5 ppm. Like other
properties of crude oil, it is likely that the mercury
content is extremely variable. The 2000 U.S. refinery
throughput was 5,514 million barrels (USDOE 2001), or
about 865 million tons per year. Using the concentration
range of 2.5 to 13.3 ppb from Minnesota (1999) results
in  a range of 2.2 to  11.5 tons per year.  These data are
summarized in Exhibit 5-6.
                   Exhibit 5-6. Mercury Content of Crude Oil and Petroleum Products
Material
Crude Oil
Gasoline
Distillate Oil
Residual Oil
Jet fuel/ kerosene
Other Products
Mercury Cone., ppb
2.5 to 13.3
1
1
4
1
—
Production, million bbl
5,514
2,910
1,310
255
612
1,224
Total Mercury Throughput, tons
2.2 to 11.5
0.46
0.21
0.16
0.10
E =0.93
—
Source: Mercury content of materials from Minnesota (1999).  Nationwide throughput data for 2000 from U.S. DOE (2001).
Mercury release data for six oil refineries and bulk fuel
terminals  are  available from the  1999 TRI.   Total
releases from these six facilities are 5 pounds to water
and 10 pounds to land. Other estimates are not available,
although additional refineries and bulk terminals are
expected to report mercury releases to the 2000 TRI due
to a change in reporting requirements for mercury (data
expected to be released in Summer 2002).

Refineries produce many products. The 2000 production
volume of these products and their mercury content are
presented  in Exhibit 5-6.   As  shown, the apparent
mercury content of crude oil (2.2 to 11.5 tons) is greater
than the mercury content of the  products (0.93 tons),
indicating that  'missing mercury' is unaccounted for.
Exhibit 5-7 summarizes the mercury flow in petroleum
refining.
5.7.3 Discussion
The quantity of mercury in crude oil can be extremely
variable.   The  release  quantity  in  Exhibit  5-7 is
underestimated because data are available for only six of
more  than  100 US  refineries.  Additionally, mercury
releases to certain media, especially air, are not routinely
measured by refineries and emissions of volatile metals
are difficult to estimate using conventional approaches.
Therefore,  obtaining accurate accounting of mercury
from petroleum refining activities is a particular research
need.

5.8 Rubber and Plastic Products
In rubber manufacturing, carbon black is used as a raw
material.  Carbon black is commonly produced from
petroleum products, which may contain mercury as an
impurity.
                                                   60

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       Consumption:
       2.2 to 11.5 tons
Oil Refining
Products:
 0.93 ton
                                                                  Releases:
                                                                  < 0.01 ton
           Source:   Mercury content of materials from Minnesota (1999).
                    Nationwide throughput data for 2000 from U.S. DOE (2001).
                    Releases: 1998TRI.
                             Exhibit 5-1. Mercury from Oil Refining
There are no data regarding the mercury content of the
carbon black product.  A lack of data regarding the
presence of mercury  in this industry prevents any
estimates of mercury use and release.

5.9 Geothermal Power
5.9.1 Introduction
Geothermal power  accounted for 2,650 megawatts of
power production capacity in 1992(USEPA 1997a). For
comparison, coal combustion (the principal source of
energy in the U.S.) accounted for approximately 300,000
megawatts  of power production  in  1996  (USEPA
1999d).

Geothermal plants operate in the western United States,
specifically in California, Hawaii, Nevada, and  Utah.
Turbines in the plants are  powered by steam that  is
naturally present in the form of hot, high pressure  water
or steam below the earth's surface (USEPA 1997a).

5.9.2 Materials Flow
Sources of mercury in geothermal plants are expected to
result from off-gas ejectors and cooling towers (USEPA
1997a).  Quantitative estimates of air emissions from
these sources are presented in USEPA (1997a) based on
estimates developed from 1977 data. An estimate of 1.4
tons of mercury released to the air was  developed.
Estimates to other media, and estimates of the quantity
of mercury present in the raw materials  (geothermal
steam or water) are unavailable.
        Mercury  may be  present in water or solid  wastes.
        Hydrogen sulfide (present in the raw material) requires
        removal prior to  venting of the gas; the sulfur is
        collected in a solid form for disposal where mercury may
        simultaneously be  collected. Condensed water is also
        collected, where mercury may also be present (Kirk-
        Othmer 1994).  No estimates for these quantities are
        available.

        5.9.3 Discussion
        The estimate for air releases of mercury has uncertainty.
        The data were developed from 1977, when operations
        and air pollution  control  configurations  may  have
        differed from today; which would affect the partitioning
        of mercury to other  media.   Additionally,  mercury
        compounds were used in cooling towers as abiocide and
        it is unknown if the  factor developed in 1977 was
        developed from a site where mercury was present in this
        fashion. If so, present day mercury releases would be
        overestimated because mercury is no longer used in
        cooling towers.

        5.10 Wood-Fired Boilers
        5.10.1 Introduction
        No mass balance estimates are available for wood-fired
        boilers. These boilers are used in both residences and
        industries. On a residential scale, wood is burned as logs
        in a small stove.  On an industrial scale, wastes or
        byproducts from onsite processing of wood are burned
        in an onsite boiler; these wastes could include sawdust
        and wood chips (USEPA  1997a).
                                                 61

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5.10.2 Materials Flow                               comparison to quantities in  other industries as to be
The mercury content of bark is reported to range from    negligible.
0.08 to 0.8 ppm mercury (USEPA 1997a). The mercury
content of other wood products is not available.  The
total quantity of wood burned in industrial boilers is
estimated as 100 million tons per year (USEPA 1997a).
Due to the uncertainty  in mercury composition of the
feed, an estimate is not presented.

Air releases of mercury from  industrial boilers  are
presented as 0.26  tons  per year  (USEPA  1997a).
Another USEPA document estimates that the total 1994
mercury emission from wood combustion are 0.1 tons
(USEPA 1997b), but notes that the data are suspect.
Water releases are likely to be negligible, and estimates
for solid  releases   (e.g., combusted wood) are  not
available. USEPA (1997a) presented air release factors
for industrial and residential boilers.  The release factor
for residential boilers was not used because it was based
on a  single data point (e.g. one wood type and one
burner).    The  value  of this  release  factor  was
approximately 4 orders of magnitude higher than  the
value of the release factor used for industrial boilers.
Use of this release factor would have  resulted  in an
unreasonable estimate of mercury releases and therefore
was not used.

5.11 Utility Natural Gas Combustion
5.11.1 Introduction
Natural gas is used as a fuel at electric generating utility
power plants, and it is the second most significant fossil
fuel behind coal. In the production of electricity from
natural gas combustion, the gas is fed to a furnace with
excess air (USEPA  1999d).  Generated heat is used to
transform water to  steam, which drives a turbine to
generate electricity.

5.11.2 Materials Flow
An estimate for mercury air releases from natural  gas
combustion was provided as  0.002  tons  per year
(USEPA 1997a). Estimates for the quantity of mercury
in the incoming fuel were not available. Additionally,
no  solid or aqueous wastes are expected from  the
combustion of natural gas (USEPA 1999d). Therefore,
any mercury present in the fuel is probably released to
the air.

5.11.3 Discussion
No estimates for the mass balance of mercury in natural
gas combustion  are presented.  Only one number is
available (for air releases), and the value is  so low in

                                                  62

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                                            Chapter 6
 Additional Sources of Mercury Resulting from Disposal or Other Final Disposition
Information in this chapter may overlap in part with
solid waste disposal figures from other sectors and may
also capture data from numerous unreported sources.
Waste management facilities were required to report to
the TRI for the first time in 1998.  In 1999,  seven
hazardous waste management facilities reported releases
of mercury or mercury compounds. These are facilities
that conduct a variety of services such as landfilling,
stabilization, incineration, consolidation, etc. Therefore
the data can not be neatly presented in any one section of
this report.

These seven facilities reported the following releases of
mercury and mercury compounds in  1999. A total of
272 tons were  landfilled, 42 tons were sent offsite for
mercury recovery, and 0.03 tons were released to air.
This is a total of 314 tons.

6.1 Hazardous Waste Combustion
6.1.1  Introduction
USEPA's  hazardous waste regulations  have been in
effect  for approximately  20  years.   Under  these
regulations,  both  commercial  and  captive  (on-site)
facilities  must have a permit in order to  combust
hazardous waste.  The types of facilities that combust
hazardous waste include  incinerators (which almost
exclusively combust hazardous waste) and industrial
furnaces (which have the dual purpose  of destroying
hazardous waste and deriving energy for use in other
industrial processes (USEPA 2000b)).  An example of an
industrial furnace is a cement kiln.

Almost all hazardous wastes must be treated prior to
land disposal, and combustion is a common method to
remove organic constituents  from wastes.  Inorganic
constituents  commonly remain in the  ash or  waste
residue, or are collected by air pollution control devices.
Such wastes would be subsequently treated or disposed.
Hazardous wastes are extremely variable in physical
form and composition, and include spent solvents, tank
bottoms, and electroplating sludge. However, not all of
these   wastes  are  amenable  to hazardous   waste
combustion, or in fact undergo combustion as treatment.
For example, hazardous wastes high in mercury are sent
to mercury recovery and recycling facilities.  Mercury
may be present  in  other hazardous wastes in small
amounts, and contribute to the mercury  loading of a
hazardous waste combustion facility.

6.1.2 Materials Flow
Exhibit 6-1 illustrates the flow of mercury in hazardous
waste combustion.

Mercury Consumption
The quantity of hazardous waste combusted, both onsite
and offsite, is tracked biannually by USEPA. However,
the composition of this waste is not reported; therefore,
assumptions must be made regarding which of these
wastes  are expected  to contain mercury  and  the
concentration of mercury in the wastes.

Approximately 1,800,000 tons per year of hazardous
waste are combusted in commercial combustion units,
based on data from  1993 (USEPA 2000b); additional
waste   is  combusted   in   onsite   (captive  and
noncommercial) units.  Extremely rough estimates can
be made regarding the quantity of mercury present in
these wastes. Specifically, by accounting only for three
hazardous  waste  types  that  are known to  contain
mercury, and ignoring the mercury  content of other
waste types, the total quantity of these wastes combusted
is 58,000 tons in  1995  (USEPA 1998b). These wastes
were  probably  combusted  because they  contained
organic constituents in  addition to mercury.   The
concentration of mercury in these types of wastes can
hypothetically range from less than 1 part per million to
100 percent, although such high  mercury wastes are
typically not incinerated.
                                                 63

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                          Consumption:
                           1.0 tons/yr
 Hazardous
   Waste
Combustion
Product:
0 tons/yr
                                                           Releases: 7.1 tons/yr
                                                           -Air: 7.1 tons/yr
                                                          • - Water: 0 tons/yr
                                                           - Disposal: 0 tons/yr
                                                           Recycling/Reuse: 0 tons/yr
                          Source:   Mercury Consumption: Estimated using USEPA (1998b) and USEPA (1998d).
                                 Mercury Release and Recycling: Estimated using EPA Mercury Study Report to Congress (1997a).
                         Exhibit 6-1.  Mercury in Hazardous Waste Combustion
Based on data from a separate and less comprehensive
survey of hazardous waste treatment operations, an
estimate  for the quantity of mercury  in  mercury-
containing wastes can be made. Over one hundred waste
treaters  (not  all of them conducting  combustion)
provided data regarding the average composition of their
wastes.  Mercury composition data for wastes being
combusted was extracted  from this data set.   The
concentration of mercury ranged from not detected (or
not reported) to 18 mg/kg, with the median concentration
below 1 mg/kg (USEPA 1998d). Applying this high
concentration  of 18 mg/kg  to the  58,000 tons of
mercury-containing waste results in approximately 1 ton
of mercury in the raw material feed.  This estimate has
significant uncertainty. It may be biased low because
other wastes   that  may   contain  mercury  in  low
concentrations are  not  accounted for.  It may also be
biased high because the highest reported concentration
is used as  representative of all wastes.   Finally, the
inherent variability of mercury composition in hazardous
wastes prevents an accurate accounting.

Releases
Air  releases from  hazardous waste  combustion are
estimated  as 7.1 tons  of mercury  in 1995 (USEPA
1997a). Mercury releases to other media are not known.
It can be assumed that all of the mercury in the waste is
vaporized during combustion.  Potential releases include
the collection of mercury in air pollution control devices
for subsequent disposal.
        6.1.3 Discussion
        While the quantities of hazardous waste combusted are
        carefully tracked by USEPA, the quantity of mercury in
        these wastes is largely unknown.  The imbalance in the
        input and output of mercury from hazardous waste
        combustion is the result of using two different sources of
        estimates.

        6.2 Crematories
        6.2.1 Introduction
        This section focuses on crematories, i.e. establishments
        that cremate human corpses.  Facilities may fall under
        the following SIC orNAICS codes.

            SIC Code 7261: Funeral Service And Crematories

           NAICS Codes 81222: Cemeteries and Crematories

        Cremation is the process of reducing a body to ash and
        bone  fragments through the  process of high  heat.
        Mercury associated with crematories  comes from the
        volatilization of amalgam  tooth fillings  that contain
        approximately 50 percent mercury.  The combustion of
        fillings  results  in the vaporization of much of the
        contained mercury and its  release  to  the atmosphere,
        from which it is ultimately deposited in soil  or into
        bodies of water.
                                                   64

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                       Consumption:
                         1.4 tons/yr
Crematories
  Product:
Not Applicable
                                                       Releases: <0.1 tons/yr
                                                       -Air: <0.1 tons/yr
                                                      • - Water: 0 tons/yr
                                                       - Disposal: 0 tons/yr
                                                       Recycling/Reuse: 0 tons/yr
                               Mercury Consumption: Extrapolated from USDHHS (1993) and Yoshida (1994).
                               Mercury Relase and Recycling: Estimated using EPA Mercury Study Report to Congress (1997a).
                                  Exhibit 6-2. Mercury in Crematories.
6.2.2 Materials Flow
Exhibit 6-2 demonstrates the flow of mercury during the
cremation process.

Mercury Consumption
Mercury is a component in tooth fillings used to prevent
further tooth decay in humans.  Amalgam, or "silver
filling," is made from fifty percent elemental  liquid
mercury, thirty-five percent silver and fifteen percenttin,
or tin mixed with copper, and sometimes small amounts
of zinc, palladium, or indium (Kennedy 1996).   The
filling is placed  in the cavity of a tooth after  a dentist
drills out decay.  A Japanese study showed that the
mercury  content per amalgam  filling is 0.6 grams
(Yoshida 1994).  From 1971-74, U.S. adults  18 to 74
years old had an estimated average of 6.9 filled teeth, but
since 1979, amalgam use  has decreased 38 percent
(USDHHS 1993).  Assuming the average number of
cavities per person has similarly  decreased, the 4.3
fillings per  person results  in 1.4  tons  (1260 kg) of
mercury in the teeth of the 488,224 people cremated in
the U.S. in 1995.

Air Releases
There were 488,224 cremations in the United  States
during  1995. Mercury emissions from a body during
cremation range from 3.84 x 10"8to 1.46x 10"6kilograms
(8.45 x  10'8 to  3.21 x  10'6 pounds).  The average
emission is 0.94 x 10"6 kilograms per body (2.06 x 10"6
pounds per body), resulting in 0.46 kilograms (5.1 x 10"4
tons, or 1 pound) of mercury emissions from cremation
in 1995 (USEPA 1997a).
            Solid Waste Releases
            Cremated  remains  are  the   noncombustible  bone
            fragments.   No data  were  available  for  mercury
            concentration in remains.

            6.2.3  Discussion
            Differences between the  input and output could be
            accounted for in several ways . Only one set of data were
            used  to  determine  the  average quantity of  mercury
            emitted during  a cremation (USEPA 1997a). The data
            are inconsistent with previous  literature.  For instance,
            previous USEPA research indicated that, on average, 1
            gram of mercury is emitted during a cremation, but that
            estimate was based on European data that may not
            accurately reflect U.S. dental practices and  thus  is
            somewhat uncertain (Massachusetts 1996).   Using 1
            gram per body  results in 1,076 pounds per year (or 0.5
            tons per year).  In addition, an estimated  40 pounds of
            mercury were  released  via cremation in Michigan in
            1994  (M2P2  1996). Using  cremation  emissions in
            Michigan as  a per capita average emission rate for the
            total U.S. population (USDOC 2001) results  in  1,100
            pounds or 0.6 tons per year of mercury as an air release
            across the country.   This  supports the hypothesis that
            temperatures in a crematory (1400-1800 °F)  are high
            enough to combust all the mercury, which boils at 674
           Mercury vapors are constantly emitted from fillings.
           However, since the average daily intake for a person
           with fillings is  1.24 micrograms of mercury (USDHHS
           1993), the amount of mercury "lost" before cremation is
                                                   65

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minuscule.
POTWs.
No information  regarding pollution  control or other
actions  that  have  been taken  to  address mercury
emissions from crematoria.  While control devices are
present  on stacks, no information regarding mercury
capture is available.

6.3 Sewage Treatment and Sludge Incineration
POTWs are likely to be included under the following
SIC and NAICS codes:

    SIC Code 4952: Sewerage systems

    NAICS Code 221320: Sewage Treatment Facilities

6.3.1 Introduction
Publicly owned treatment works (POTWs) accept and
treat  wastewaters  from   domestic   and  industrial
operations. Mercury may enter these wastewaters from
the sources listed in this report.  Additionally, mercury
emitted to the air may ultimately deposit and be present
in stormwater discharged to the treatment plant.

The sewage treatment process includes the following
steps: (1)  collection  of wastewater for centralized
treatment;  (2) treatment of the  wastewater through
processes including filtration, biological treatment, and
clarification; are  (3) discharge of treated wastewater to
a surface water. The sludge generated may be managed
by land treatment (e.g., in designated treatment areas or
as use on public or private lands for soil enrichment
purposes) or by incineration.

6.3.2 Materials Flow
Exhibit  6-3 illustrates the flow of mercury  in sewage
treatment, accounting for management of sludge by both
incineration and land disposal or land  application.

Mercury Consumption
Due to the varied sources of mercury potentially present
in waters influent to a POTW, it is impossible to identify
the quantity of mercury entering such  a facility without
monitoring data. Monitoring data for industrial facilities
discharging to a POTW are  sometimes available for
mercury; however, the lack of automation for these data
in a national  framework  makes the data  extremely
cumbersome to use for the many industrial sources. Due
to these data limitations, an estimate of the quantity of
mercury entering  POTWs  on  a national  level was
developed from the quantity of mercury released from
Water Releases
The   Permit  Compliance  System  (PCS)  identifies
monitoring data for facilities with NPDES permits (i.e.,
those that discharge to a surface water).  The PCS was
searched for monitoring data relevant to mercury which,
depending on the facility-specific permit, may be present
in the database in a number of forms such as total,
dissolved, etc. Furthermore, the search was limited to
those facilities identified in SIC code 4952 (as identified
above, such facilities conduct sewage treatment). Using
the calculation procedure below, it is estimated that 5.5
tons  of mercury were released to water.

Data were  available from PCS for approximately 700
facilities that reported monitoring data for mercury in
1997. While there are several different forms of mercury
presented in the database, two forms were predominant:
"total mercury" and "total  recoverable mercury."  In
compiling the data, the most complete, recent year's data
were used for each facility. In most cases  this was 2000
or 2001, but in some cases 1999 represented the most
complete monitoring for mercury. For each facility, a
calculation was done to develop a single average value.

PCS presents data as concentrations (e.g., ppm) as well
as quantity loadings (e.g., Ibs.  per  day).  Quantity
loadings were used preferentially; when  not available,
the average concentration was multiplied by the facilities
permitted flow rate (which overestimates  releases).

In measuring mercury, many facilities report non-detect
values.  These are handled in two different ways: the
concentration is assumed to be zero when the facility did
not detect mercury at anytime during the year. If at least
one measurement was detected, then non-detect values
were assumed to be one-half of the detection limit.

The following uncertainties apply to the above estimate:

•  Data are  only  available  for facilities  actually
   monitoring for mercury.  There may be instances
   where additional facilities are discharging mercury
   but are not recorded in PCS.

   Facilities do not conduct continuous monitoring for
   mercury.  These loadings may be calculated from as
   little as a single data point collected during the year.
   Therefore, the collected data may not necessarily be
   representative of the actual discharges.
                                                  66

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                        Consumption:
                          12tons/yr
   Sewage
Treatment and
    Sludge
  Incineration
 Product:
No Product
                                                        Releases: 12 tons/yr
                                                        - Air: <0.9 tons/yr
                                                       - - Water: 5.5 tons/yr
                                                        - Disposal: 5.5 tons/yr
                                                        Recycling/Reuse: 0 tons/yr
                         Source/a   Mercury Consumption: Estimated from releases.
                                Mercury Release and Recycling: Water and disposal releases estimated from 1999-2001 PCS data, and EPA
                                 (1985) sludge partitioning data. Air releases from USEPA (1997a).
                             Exhibit 6-3. Mercury Flow in Sewage Treatment
    Data in PCS may, in some cases, be incorrect due to
    entry errors.   In developing  the  U.S. estimate,
    particular attention was given to double checking
    facilities with significant impacts on the results.

Air Releases
Potential sources of air releases are from the wastewater
treatment itself,  and the  incineration  of the sludge
generated from treatment. No estimates are available for
fugitive air emissions from the  sewage treatment plant;
the release of mercury is  likely to be much less than the
release of mercury from incineration.  The results from
USEPA (1985) indicate that a very small percentage of
mercury volatilizes during treatment (this  source is
explained in  greater detail below).   Estimates  are
available from the incineration  of the treatment sludge,
however. A total of 0.94 tons of mercury  are estimated
to be released to air from incineration (USEPA 1997a).
This estimate is calculated from the estimated quantity of
sludge incinerated in a year, average emission factor for
various  types of combustion and air  pollution control
units, and distributions of the type of combustion units
and air pollution control units.

Solid Waste Releases
Potential  sources of  solid  waste releases (releases to
land) result from the disposal of the generated sludge and
disposal of any  ash or air  pollution  control wastes
generated from  combustion of the sludge.  Estimates
regarding mercury in air pollution control residues are
not available.  The data in  USEPA (1997a)  did  not
indicate the efficiency associated with various control
             devices for sewage sludge incineration.

             The quantity of mercury in sewage  sludge  can be
             roughly estimated based on the results of an USEPA
             study from the 1980s (USEPA 1985).  As part of this
             study, removal efficiencies of various contaminants were
             estimated using data from  40 POTWs as well as from
             other sources (e.g., USEPA research projects). Mercury
             was estimated to partition 50 percent to sludge and 50
             percent  to   released  effluent,  with  negligible  air
             emissions. Applying this percentage to the present-day
             data,  it can  be estimated that 5.5  tons of mercury are
             present in sludge.  This quantity is assumed to be land
             disposed  directly  or remain  in air pollution  control
             residues for incineration.

             The use of the  50  percent figure  likely represents an
             average value of various systems applicable at the time
             of the study.  There is probably variation in mercury
             partitioning on a facility-specific basis.

             6.3.3 Discussion
             As discussed above, estimates for mercury loading to
             water were  available using  PCS.   Using these data,
             loadings to solid waste disposal were  subsequently
             estimated. Releases to air were available from a second
             source.  No  data are available regarding the loading of
             mercury to  POTWs.   This necessitated  the  'back
             calculation' of this quantity using the release data, and
             could not serve as a check for the accuracy of the release
             data.
                                                    67

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To better support the estimate, additional research could
be conducted regarding the PCS data used for the water
release estimate.  This could include determining the
portion  of  POTWs  represented  by  the  data  set,
verification  of the  loadings calculations, and  better
assessing the  influence of non-detect  values on the
calculations.

6.4 Municipal Waste Combustion
6.4.1 Introduction
USEPA has estimated that in  1995 approximately 80
percent of municipal  solid  waste is landfilled and 20
percent is combusted  (this excludes material removed
from the wastestream for recycling) (USEPA 1997c). In
previous  sections of this report, this partitioning was
used to estimate the quantity of a particular product (e.g.,
fluorescent lamps) that was eventually released as a solid
waste (i.e., sent to a landfill) and that which is emitted as
an air release (i.e., sent to a combustion unit).

6.4.2 Materials Flow
Municipal waste combustors were estimated to emit 30
tons of mercury in 1995 (USEPA  1997a).  Mercury is
present in the municipal solid wastes that are burned in
these  units,  such   as  from consumer  products.
Subsequently, mercury may also be present in the bottom
ash (noncombustible)  residue,  in air pollution control
wastes such as collected fly ash,  or in the stack gas
emitted to the atmosphere.

The quantity  of mercury  emitted to the air  during
combustion is estimated to be decreasing. This is due to
the  decrease   of  mercury-containing  products  in
municipal solid waste (due to both source reduction and
recycling) and the implementation of state and federal
laws to  control air emissions from municipal  waste
combustion units. For example, final emission standards
have  been  promulgated for "large" municipal  waste
combustors  in  1995   (60  Federal Register 65387;
December 19,  1995) and proposed for "small" units in
1999 (64 Federal Register 47233; August 30, 1999), as
discussed in
http://www.epa. gov/ttn/atw/129/mwc/rimwc2 .html.  In
both cases, mercury is one of the contaminants addressed
in the regulations.

The quantity of mercury estimated to be present in
incoming wastes to a municipal solid waste combustion
unit can  be developed from examination of the data
presented in Chapter 3  of this report. Specifically, atotal
of  13 to 21 tons  of mercury in  the products were
assumed to enter a combustion unit as part of municipal
solid waste. Finding alternative methods of estimating
the quantities of mercury present in incoming wastes is
difficult due to its heterogenous nature.  Furthermore,
while this report estimates that 13 to 21  tons per year
may enter municipal waste combustion units nationwide,
no estimate is presented regarding the quantity that is
eventually released to the air, to the land (as pollution
control waste), or sent for mercury recovery (if any).

6.4.3 Discussion
Data regarding the mercury content of ash are available
from characterization studies of the late 1980s and early
1990s. However, such data may not be representative of
present-day ash. This is due to changes in the mercury
composition of municipal solid waste, as well as revised
control technologies in place since the 1995 air rules.

Various  control   technologies  are  available  for
controlling mercury emissions. In response to the new
air regulations, such controls are likely to be added or
optimized.  Such controls include removal  of mercury
entrained  on  ash  in particulate  collection  devices
(USEPA 1997a), and the  control of vapor through
activated carbon (Krishnan 1994).

6.5 Landfills
6.5.1 Introduction
As mentioned  throughout this  report,  a  variety  of
mercury-containing  wastes are disposed on the land.
This includes industrial wastes (e .§., from manufacturing
processes where mercury is used), air pollution control
wastes (e.g., where mercury is present in the influent
fossil fuel  or ore), and municipal  solid wastes (e.g.,
where mercury is present in consumer products. These
materials can be disposed in industrial waste landfills,
municipal solid waste landfills, and hazardous  waste
landfills.   Much of the  mercury  containing  waste
described in this report may be managed with general
household trash, which may be combusted or landfilled.

6.5.2 Materials Flow
Mercury may be re-released from these landfills  in the
form  of air  emissions,  runoff, and  leachate.    An
estimated 0.08 tons of mercury is emitted  in air releases
from municipal solid waste landfills (USEPA 1997a).
This is a small quantity in comparison to the  total
quantity of mercury disposed to land. It is also small in
comparison to other air releases.
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6.5.3 Discussion
All  instances  of  landfill  disposal were discussed
previously in this report as part of individual products or
processes involving mercury.  These estimates are not
presented here in order to avoid "double counting" of
such sources.

6.6 Medical Waste Incineration
6.6.1 Materials Flow
There are an estimated 7,000 hospitals in the U.S. with
approximately 34% operating their own incinerator (62
FR 48347;  September 15, 1997).   Sources vary with
respect  to  the  amount  of  waste hospitals generate
annually. High-end estimates indicate 2 million tons of
waste is generated  (Citizens for Environmental Health
2002) while another projection suggests the level may be
as low as 600,000 tons (Valenti 2000). USEPA (1997a)
estimated that the quantity of mercury emitted to the air
from this source is 16.0 tons per year in the 1994 to 1995
time-frame. Since that estimate was made,  USEPA
published a final rule relevant to the control of mercury
and other emissions from this source category (62 FR
48347; September 15, 1997).

6.6.2 Discussion
Several pollution prevention activities are underway for
the reduction of mercury in the medical field, which
should reduce the amount of mercury fed into medical
waste incineration.  For example, a Memorandum of
Understanding was developed between  the American
Hospital Association and USEPA on June 25, 1998.
This memorandum discusses the elimination of mercury
in hospital wastes (AHA 1998).
                                                  69

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                                              Chapter 7
                              Geographic Distribution of Mercury
7.1 Purpose
In previous chapters, data were presented to show how
product and industrial sectors use and release mercury in
the U.S. on a national basis. That profile, or Materials
Flow Analysis (MFA),  shows the flow of mercury
through  the  U.S.  economy  and released  into the
environment. The data obtained from the MFA can be
used to target sectors that emit the largest quantities  of
mercury throughout their product lifecycle.

In conjunction with quantifying mercury use and release
on an industry-specific basis, this chapter presents data
geographically.   Specifically,  the  releases  from  all
industries are identified for each State and for selected
local regions.  This analysis allows for the targeting  of
specific  areas of the country in which the largest
quantities of mercury are released. The profile is useful
in identifying local, regional, and national importance of
mercury activity.

7.2 Data Sources and Limitations
Exhibit 7-1  lists the data sources presented in this
chapter that allow for regional distinctions. Exhibit 7-1
includes  many of the  same  data sources used for
estimating the materials  flow of mercury  on a national
level.  However, not all of the data sources discussed
earlier in this report are presented in Exhibit 7-1.   In
most cases, this  is because insufficient information is
available  to allow for adequate treatment below the
national level. For example, the estimation of releases of
mercury   from  lighting  use  is  dependent  on data
regarding lamp sales at the national level.  Since state-
level sales data are  not available for these and other
products, it is not possible to estimate the geographic
distribution  of mercury use  and release from this
particular source.

An important limitation with a geographic presentation
of data is that a single complete geographic distribution
cannot be presented. This is because the  analysis uses
multiple data sources which vary in scope and objective.
For example, TRI data present multimedia releases  of
mercury but omit a  significant number  of facilities
known  to release  mercury.  Alternatively, the 1996
National Toxics Inventory (NTI), while somewhat dated,
presents a more complete geographic description  of
mercury releases to air but it is not possible to identify
the degree of overlap with other data sources because not
all of the data are facility-specific. It is very difficult to
combine  these  different  data sets  into  a  single
presentation to identify a 'single' release estimate for a
particular locality.

A second limitation of presenting data by geographic
region is that the release estimates cannot be 'rolled up'
to identify national estimates of flow and release. Using
TRI as an example, the data provide differing levels of
coverage  depending  on the industry and therefore
estimates are made using different data sources from one
industry to the next.   In  addition, as  mentioned
previously, estimates used for national estimates such as
lighting sales data do not have a local component.

Each  source identified in Exhibit 7-1  is described  in
detail below,  with descriptions  of the  availability,
completeness, and quality of the data source.  Data from
each source are presented later in this chapter.

7.2.7 Toxics Release Inventory
TRI provides facility-specific environmental data for
mercury, mercury  compounds (this category does not
distinguish between the type of compound), and other
chemicals.  The data include releases to air, water, land,
and solid waste. TRI does not require all facilities that
emit mercury to report emissions; a facility only reports
emissions if it meets thresholds set by the TRI program.
Data are provided annually (the most recent data are for
1999) through Envirofacts
(http://www.epa.gov/enviro/html/tris/). Limitations  of
the data are that, as discussed above, not all facilities
                                                   70

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                Exhibit 7-1.  List of Data Sources For Geographic Distribution of Mercury
Data Source
Toxics Release Inventory
(TRI)
National Toxics Inventory
(NTI)
National Response Center
Database (NRC)
U.S. EPA Utility Information
Collection Request
National Fish and Wildlife
Fish Consumption Advisories
Media
Multimedia
Air
Spills
Air
Environment
Description
U.S. EPA data from 1999 for approximately 80
facilities where relatively large quantities of mercury
are present during a year.
U.S. EPA data from 1996 identifying mercury
releases for virtually all U.S. counties.
Data for accidental releases of about 100 materials
identified as containing mercury as a primary
component in 2000.
Data collected by EPA in 1999 and extrapolated to
each of the approximately 450 U.S. coal-fired power
generation facilities.
Identification of all existing and news wildlife
advisories in 2000 where mercury is identified as the
reason for the advisory.
are required to report mercury or are required to identify
releases from all mercury-related activities. In addition,
the data reported by  the  facilities themselves  are  of
varying quality, being  either estimates  or measured
results.

7.2.2 National Toxics Inventory (NTI) Data
The NTI database provides air release information for
mercury as well as for other chemicals. The inventory
contains estimates  of emissions from major, area, and
mobile source categories. The database is different from
TRI in that no specific reporting threshold is included in
the inventory. Larger sources are identified by facility
and smaller sources (e.g., gasoline stations) are grouped
as area  sources and categorized both by industry and
location.  Major and  area sources both are stationary
sources differing in their potential to release air toxics
(as well as differing in their regulatory requirements and
the availability of data).    Mobile  sources  include
highway traffic, aircraft, etc.  The data are updated every
three  years and the latest data available are from the
1996  inventory.   The  1996 inventory incorporates
information collected  from states, TRI data, other EPA
information, and estimation procedures.  The data are
available from EPA's  web site
(http://www.epa.gov/ttn/chief/net/index.html).

7.2.3 National Response Center Database
The National Response Center (NRC)  manages  the
reporting  of all chemical and  fuel  spills (or  other
accidental  releases) in the U.S.,  consolidating and
simplifying reporting  required  by  many legislative
statutes.   Facilities are  required  to report  spills  or
accidental releases if they are subject to certain statutes,
such as the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA).  These
requirements generally require the reporting of spills
greater than certain quantities although in reviewing the
data for 2000 there is a wide range in the  quantities
reported.  The data are continuously updated with the
most recent whole-year data available for 2000.  The
data are available as data files from the National
Response Center's Internet site
(http ://www.nrc .uscg.mil/index.htm).

These data were reviewed for spills involving mercury.
Identifying  quantities  from   this  data  source  is
problematic for a number of reasons.   First, the data
collected by NRC are based on preliminary information,
and therefore quantities reported may be subj ect to error.
In other instances the quantity of mercury spilled is not
known.  For this reason, data regarding  the number of
incidents are expected to provide a better indication of
accidental mercury releases than the quantities reported.

7.2.4 National  Listing  of Fish and   Wildlife
Consumption Advisories
EPA collects advisory information from states regarding
the consumption  of fish by  general  and  sensitive
populations.
                                                   71

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This data source is unique among the others identified in
this  chapter because  it  identifies  mercury  in  the
environment, rather than  from the  source.   In  this
instance, it  is impossible  to know the source of the
mercury. Data on mercury advisories are available from
fact sheets from EPA's web site
(http://www.epa.gov/waterscience/fish/').

A principal limitation of using the fish advisory data is
in reaching conclusions.   Because  there  are many
species, waterways, and potential contaminants, a state
is limited by the extent of sampling it can conduct.
Therefore, differences in the number of fish advisories
from one year to the next, or from one state to another,
may simply be the result of differences in the number of
assessments conducted or the sampling  and analysis
techniques employed.

7.2.5 U.S. EPA Information Collection Request
EPA has collected extensive data regarding the mercury
emissions of coal-fired power plants and the mercury
content of coals used at coal-fired power plants. These
data were collected in 1999 and 2000 for a one-time  data
collection effort.   These  data are extremely useful
because they can characterize the use and emissions of
mercury  from all coal-fired boilers in  the 1999
timeframe.  Data from this effort are available from EPA
(http: //www. epa. gov/ttnatwO 1 /combust/utiltox/utoxpg.
html).

Data regarding the mercury content of coals, coal usage,
and boiler characteristics were collected from all coal-
fired power plants.  More comprehensive air sampling
data were  collected from 10 to  20 percent  of the
facilities, which EPA statistically  extrapolated to the
population  as a whole.   The  air sampling activity
included quantifying total mercury emissions as well as
the species emitted.

7.3 Findings
The data gathered from the above sources were  used to
map the releases of mercury in the United States. Each
data source provides estimates of the overall quantity of
mercury emitted. The resulting data maps can be used to
identify  local  and regional  hotspots  of mercury
emissions.  Examination of the maps allow researchers
to identify which local and  regional areas of the country
emit the largest quantities of mercury. In addition, the
map will assist in determining which areas of the country
produce mercury of global concern.
7.3.1 State-Level Maps
Each of the five data sources discussed above were used
to generate data for mercury at the State level.  Data for
each parameter identified in Exhibit 7-1 were aggregated
for each state and plotted on a map of the U.S. using a
simple spreadsheet. The results are presented in Exhibits
7-2 through 7-8.

Exhibits  7-2  and 7-3  present  1999  TRI  data for
multimedia releases and air  releases, respectively, for
facilities  reporting for both 'mercury' and  'mercury
compounds.'

Exhibit 7-2 sums all quantities of mercury reported to be
released.   The predominance of releases are from the
Eastern states. Many States have no facilities reporting
mercury releases.  The only Western states that had
significant emissions according to TRI was Nevada and
Arizona. The Nevada emissions are mostly due to gold
and copper mining in the state, and represent by far the
highest emissions.

In the context of TRI, release refers to virtually any
quantity of mercury entering the environment in any
form, regardless of the potential risk posed or the media
impacted.  Therefore, for a more comparable analysis of
TRI  data and to facilitate comparisons with other data
sources, Exhibit 7-3 presents data for air releases  only.
Again, Nevada  leads  the States for air  releases of
mercury.

Exhibits 7-4  and 7-5  present NTI data.  Exhibit 7-4
presents total mercury air releases for each State while
Exhibit 7-5 presents emission density (i.e., emissions per
square mile)  for each state.   While related,  there are
some differences.   For example, small mid-Atlantic
States with moderate  emissions have extremely high
emission densities, while some larger Western States
with low emissions have even lower emission densities.

The  NTI  map  shows the  highest  emissions  and
concentration  of mercury occur in the  Midwest and
Eastern  United States.  The density of mercury are
highest in the following  states: Delaware, Maryland,
Massachusetts, New Jersey, and Rhone Island (Appendix D
B). However, the overall top five state mercury emitters
are Texas, Florida, New York, Pennsylvania, and
Indiana.
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Exhibit 7-2.  Total Mercury Releases by State (1999 TRI)
                                                          Total Mercury Releases
                                                                (tons)

                                                              220to 1,350 (1)
                                                              40 to 220 (2)
                                                              20to  40 (1)
                                                              10to  20 (2)
                                                            D Oto  10 (25)
     Exhibit 7-3.  Total Mercury Air Releases by State (1999 TRI)
                                                               Total Mercury Air Releases
                                                                      (tons)

                                                                    0.3 to 6.22 (10)
                                                                   n 0.05to0.3  (5)
                                                                   n 0.03to0.05 (2)
                                                                   DO.01toO.03 (3)
                                                                   n 0 toO.01 (11)
                                   73

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      Total Mercury Air Release by State (NTI1996)
                                                  Mercury Air Releases
                                                      (short tons)

                                                      4.1 to 23 .6 (10)
                                                      3.2 to  4.1  (8)
                                                      1.4 to  3.2 (12)
                                                      0.8 to  1 .4  (9)
                                                      0  to  0.8 (12)
Exhibit 7-4.  Total Mercury Air Releases by State (NTI 1996)
   Mercury Emission Density by State (NTI 1996)
                                            Mercury Emission Density

                                             • 0.000213 toO.000421 (6)
                                             • 0.000103 toO.000213 (8)
                                             D 7e-005  toO.000103 (7)
                                             D 4e-005  to7e-005   (6)
                                             D 1.7e-005 to4e-005   (8)
                                             D 1.4e-005 tol.7e-005 (5)
                                             D 3e-006  tol.4e-005 (8)
Exhibit 7-5. Mercury Emission Density By State (NTI 1996)
                               74

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Number of Mercury Spills Reported per State (NRC 2000
                                             Number of Mercury Spills
                                                    • 8to14 (5)
                                                    H 7 to 8 (1)
                                                    • 5 to 7 (2)
                                                    D4to 5 (1)
                                                    • 3to 4 (7)
                                                    • 2to 3 (6)
                                                    D 1to 2 (12)
     Exhibit 7-6. Number of Mercury Spills Reported per State (NRC, 2000)
                               75

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         Mercury Fish Advisories by State
                                                              New Hampshire  5
                                                              Massachusetts  89
                                                              Rhode Island   2
                                                              Connecticut    6
                                                              New Jersey    30
                                                              Delaware     5
Exhibit 7-7. Mercury Fish Advisories By State
                           76

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Coal-fired Utility Boilers Release of Mercury by State (ICR 2000;
                                                       y
Mercury Releases by State
         (tons)
                                                                   • 1.74105.03 (7)
                                                                   B 1.12101.74 (7)
                                                                   n 0.86101.12 (7)
                                                                   n 0.53100.86 (5)
                                                                   n 0.34100.53 (5)
                                                                   n O.OStoO.34 (9)
                                                                   n 0  to 0.08 (7)
      Exhibit 7-8. Coal-fired Utility Boilers Releases of Mercury per State
                                      77

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The NTI results are consistent with the TRI data in that
mercury releases are concentrated in the Eastern States,
whether measured by  total emissions  or emission
density. However, two important deviations exist. Most
significantly Nevada is identified from the NTI data as
having virtually no releases, while it was a nationwide
leader for TRI air emissions. This is likely due to the
differences in the age of the data.  NTI data are from
1996 when estimates for releasing mercury from mining
activity were  less available. A second observation with
the NTI data is that estimates are provided for all States
in the continental U.S., versus much less complete
coverage from the TRI.

Exhibit 7-6 presents data for spills from the NRC over
the course of a year (2000). Even in the states with the
highest number of spills, the rate is just over once per
month in the  entire State,  which is not an abnormally
high occurrence.   As stated previously, data for  spill
quantities are  not expected to provide useful information
and therefore were not analyzed.  Therefore, on the
whole, data from the  NRC do not suggest that spills of
mercury  containing   materials  are  particularly
problematic for any State.

Exhibit 7-7 presents the number of fish advisories for
each state in 2000.  Advisories are  highly clustered
around  the Great  Lakes and in general  are not  well
correlated with releases in  a State. For example, of the
ten States identified from  Exhibit 7-4 as having the
highest airborne mercury releases from NTI, only three
(Indiana, Ohio, and Florida) are identified as having the
highest number offish advisories. This information can
be interpreted in several ways. Some states may be more
diligent in their  monitoring and advisory efforts than
others, or it may reflect the fact that mercury emitted
from one location can be transported to another.

Exhibit 7-8 presents air emissions data from coal-fired
utilities. With a few exceptions, these data provide an
excellent correlation with air release  data  from TRI.
Releases in the Appalachian and Great Lakes states and
Texas are similar for both the NTI data and the coal-fired
utility data.   Significant exceptions include California
and the Northeast.

7.3.2 County-Level Data
Only three of the data sources identified above were
evaluated below the aggregate State level: TRI, NTI, and
coal-fired utility  emissions (ICR).
For this  analysis,  county level data were used as a
reasonable aggregate of a local area:  data below this
level  (e.g., ZIP codes) would be expected to be too
'noisy,' while data above this level (e.g., Congressional
District or Regional area) would  be  too difficult to
generate.   NRC  and  Fish advisory  data were not
evaluated below the State level.  The small number of
spills in  each  State would  not  be expected  to be
informative at the County level. For fish advisories, data
would be too cumbersome to analyze when dealing with
bodies of water that transverse multiple counties.

County level data for NTI are presented in Exhibit 7-9.
NTI was expected to be  the  most  informative for
evaluation at the  county  level because  of the  large
number of data points. Exhibit 7-9 presents emission
densities at the county level. As expected, variations are
seen within each  state.  Sometimes higher emission
densities are consistent with higher population densities,
as seen  near cities.   In other cases,  high emission
densities outside of population centers are the result of a
small number of significant point source emissions.

Exhibits 7-10 through 7-12 present tabular data of the 25
counties from each data source where mercury emissions
are highest. In the case of the NTI and ICR data sources,
the top 25 counties represent  about one-third of all air
emissions from all counties.  For TRI however, the top
25 counties represent greater than  99 percent of the
nationwide emissions.  This is  a further result of the
relatively low number of data points available from the
TRI for 1999. Additionally, Table 7-12 shows that two
Nevada counties account for a disproportionate amount
of releases, due to mining activities.

7.3.3 Integration of County-Level Data
County-level data for TRI, NTI, and coal-fired boilers
were aggregated in an attempt to better draw conclusions
from all of the data sources.  The maps in Exhibits 7-2
through 7-8 allow for comparisons at the State level.
However, such a visual comparison is impossible for the
thousands of counties in the U.S. A quick comparison of
Exhibits  7-10 through 7-12 ('top 25' counties  for each
data source) shows very few counties repeating from one
data source to another.  For this reason, an analysis was
conducted which  attempts to combine TRI, NTI, and
ICR air release data for each county.
                                                   78

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          1996  County  Emission Densities
Mercury Compounds  —  United  States  Counties
 Distribution of U.S. Emission Densities
    Highest in U.S. ,	, 0.055
           *5
           90
Percent! le   75
           50
           25
     Lowest in U.S.
                       Pollutant Emission Density by County
                       - -     -      -        -'  *     *
O.O0044
0.000 17

o™3   C tons / yea r/sq. mile)'

O.OOOOO1 0
0
                                                  Source:  U.S. EPA / QAQPS
                                       NATA Nationa I—Sea le Air Toxics Assessment
  Exhibit 7-9. NTI County Density Map for Mercury Compounds
                            79

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Table 7-10. 25 Counties Reporting Highest Mercury Air Emissions from NTI
County
Jasper
Dade
Pinellas
Hillsborough
Westchester
Greene
Noble
Frederick
Whatcom
Broward
Los Angeles
Harris
Cook
Essex
Marshall
Delaware
Grant
Titus
Marion
Fairfax
Rusk
Wood
Tulsa
New York
Calhoun
State
TX
FL
FL
FL
NY
NY
IN
MD
WA
FL
CA
TX
IL
MA
KY
PA
WV
TX
IN
VA
TX
WI
OK
NY
TX
All Others (3, 191 total)
Total
NTI emissions Ib
24,473
5,846
5,683
5,373
4,472
4,384
3,916
3,596
3,536
3,436
3,296
3,240
3,108
2,939
2,768
2,734
2,460
2,452
2,359
2,283
2,277
2,164
2,151
2,109
2,098
222,873
295.707
% of Total NTI Releases
7.51%
1.79%
1.74%
1.65%
1.37%
1.34%
1.20%
1.10%
1.08%
1.05%
1.01%
0.99%
0.95%
0.90%
0.85%
0.84%
0.75%
0.75%
0.72%
0.70%
0.70%
0.66%
0.66%
0.65%
0.64%
68.36%
100%
                                  80

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Table 7-11. 25 Counties Reporting Highest Mercury Air Emissions from Coal-fired Boilers
County
Walker
Armstrong
Titus
San Juan
Indiana
Will
Rusk
Montour
Monroe
Jefferson
Tazewell
Kanawha
Mercer
Beaver
Person
Spencer
Gallia
Grant
Leon
Mason
Monroe
Clearfield
Coshocton
Rosebud
Shelby
State
AL
PA
TX
NM
PA
IL
TX
PA
GA
OH
IL
WV
ND
PA
NC
IN
OH
WV
TX
WV
MI
PA
OH
MT
AL
All Others (368 total)
Total
ICR Hg total Ib
2,490
2,154
2,093
2,089
1,848
1,600
1,363
1,216
1,201
1,179
1,125
1,093
1,057
1,036
1,024
1,018
1,011
974
964
963
936
926
897
891
877
63.747
95.772
% of Total ICR Releases
2.60%
2.25%
2.19%
2.18%
.93%
.67%
.42%
.27%
.25%
1.23%
1.17%
.14%
.10%
.08%
.07%
.06%
.06%
.02%
.01%
.01%
0.98%
0.97%
0.94%
0.93%
0.92%
66.56%
100%
                                        81

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Table 7-12. 25 Counties Reporting Highest Multimedia TRI Releases
County
Humboldt
Elko
Tooele
Eureka
St. Clair
Pershing
Whatcom
Salt Lake
Sumter
Sumter
Beaver
Lorain
King
Harris
Porter
Bradley
New Castle
Ashtabula
Platte
Penobscot
Marshall
Iberville
Colbert
Marshall
Richmond
State
NV
NV
UT
NV
IL
NV
WA
UT
SC
AL
PA
OH
WA
TX
IN
TN
DE
OH
WY
ME
KY
LA
AL
WV
GA
All others (49 total)
Total
Multimedia TRI
Ib
1,231,260
1,190,814
404,140
220,359
81,599
43,008
35,807
32,802
28,325
24,841
15,230
14,943
4,458
3,667
2,800
2,640
2,172
,895
,824
,734
,662
,512
,499
,316
,268
4,996
3.356.571
% of Total
TRI Releases
36.68%
35.48%
12.04%
6.57%
2.43%
1.28%
1.07%
0.98%
0.84%
0.74%
0.45%
0.45%
0.13%
0.11%
0.08%
0.08%
0.06%
0.06%
0.05%
0.05%
0.05%
0.05%
0.04%
0.04%
0.04%
0.15%
100%
                              82

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Exhibit 7-13. 25 Counties Re
County
Humboldt
Elko
Tooele
Jasper
Eureka
Titus
Walker
Armstrong
Indiana
St. Clair
San Juan
Whatcom
Hillsborough
Rusk
Will
Dade
Grant
Pinellas
Beaver
Monroe
Montour
Jefferson
Mercer
Gallia
Person
State
NV
NV
UT
TX
NV
TX
AL
PA
PA
IL
NM
WA
FL
TX
IL
FL
WV
FL
PA
GA
PA
OH
ND
OH
NC
NTI Rank
0.03%
0.00%
0.36%
7.51%
0.00%
0.75%
0.22%
0.45%
0.62%
0.05%
0.25%
1.08%
1.65%
0.70%
0.36%
1.79%
0.75%
1.74%
0.16%
0.34%
0.32%
0.31%
0.37%
0.37%
0.34%
porting Highest Releases from 3 Data Sources
ICR Rank
0.01%
0.00%
0.00%
0.00%
0.00%
2.19%
2.60%
2.25%
1.93%
0.00%
2.18%
0.00%
0.48%
1.42%
1.67%
0.00%
1.02%
0.00%
1.08%
1.25%
1.27%
1.23%
1.10%
1.06%
1.07%
Multimedia TRI Rank
36.68%
35.48%
12.04%
0.00%
6.57%
0.00%
0.00%
0.00%
0.00%
2.43%
0.00%
1.07%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.45%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Cumulative Rank
36.72%
35.48%
12.40%
7.51%
6.57%
2.94%
2.82%
2.70%
2.55%
2.48%
2.43%
2.15%
2.13%
2.12%
2.03%
.79%
.77%
.74%
.70%
.59%
.59%
.55%
.47%
.43%
.41%
83

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Speciation Emission for Coal-Fired Utility Boilers by State
                                                            Speciation Emissions
                                                                   Participate
                                                                   Ionized
                                                                   Elemental
  Exhibit 7-14. Speciation Emissions by State for Coal-Fired Utility Boilers
                                 84

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Simply  adding  the  releases  reported  would  not be
appropriate, because each data source identifies a different
total quantity of mercury across the U.S.  In addition, TRI
provides multimedia release information while the NTI and
ICR data represent air emissions only.

Instead, the far right hand columns in Exhibits 7-10 through
7-12 were used. These columns represent the proportion of
releases from the data source originating from that county,
and serves as a 'score' for the data source. The percentages
from each data source are summed to create a basis for a
final ranking. Exhibit 7-13 presents these results for the top
25 counties. Exhibit 7-13  shows that, in most instances, a
county's score  is  driven  by a single data source.  For
example,  the top  two counties reported extremely  high
releases to TRI but low releases from the other two data
sources.   In addition, in  only two cases does a county
identified in Exhibit 7-13 report a non-zero ICR release and
a non-zero TRI release, indicating that in most instances
these releases occur in different localities.  (NTI data are
available for essentially every county.)

This analysis can be repeated for additional data sources as
new data become available. For example, annual updates to
TRI can be integrated into the analysis,  while additional
mercury release data sources not discussed  in this chapter
can  be  added and integrated into the 'scoring'  system.
However, Exhibit 7-13 shows that data limitations (in this
case, the low number of counties reporting TRI data) can
greatly influence the results.

7.4 Speciation
Methyl mercury is, from an environmental perspective, the
form of mercury which is of most concern. However, methyl
mercury is not known to be emitted from any anthropogenic
source in significant quantities. Instead, methylmercury is
formed within the environment through a complex series of
transformations.    Nevertheless, the  species  of mercury
emitted  from a given source is  important for assessing
geographical impacts.

This section is limited to assessing speciation in air releases.
When released to water,  mercury has an  obvious local
impact.   Landfill  and similar  releases are more complex
because migration  of the mercury through the environment
is dependent on leaching and volatilzation, but nevertheless
is  also of local concern.  Air releases, however, do not
necessarily have immediate local impacts. Oxidized forms
of mercury (mercury compounds such as mercuric chloride)
readily deposit in a localized area once emitted. In contrast,
emissions of elemental mercury can remain airborne for long
periods of time and be transported across the country, or the
world, prior to deposition (Hanisch 1998).

There  are limited data available for mercury speciation.
Speciation data are only available for emissions from two
categories:  utility coal combustion and municipal  waste
combustion. However, these two sources are both significant
in terms of mercury  air releases.  Data from the Mercury
Study Report to Congress (EPA 1997a) show that these two
sources comprise about  50  percent  of  air  emissions
quantified in that report.

The most comprehensive data available is the EPA's ICR
from the coal-fired utility boilers.  The results show that,
nationwide, the average mercury speciation breakdown is 54
percent elemental, 43 percent oxidized,  and  3  percent
particulate.  Therefore, the 48 tons of mercury emitted by
coal-fired utility boilers (see Chapter 4) breaks down to 26
tons elemental, 20 tons oxidized, and 1.5 ton particulate.

The   studies  that  estimated  mercury  speciation had
limitations.  Although sampling was conducted at a large
number of boilers  and facilities, it is difficult to apply data to
individual plants  since it was only a snapshot in time and
may be affected  by  future changes in  coal supply, plant
operations, etc.  Additionally, as facilities install control
devices which  affect mercury  capture,  the  resulting
speciation profile  will change.

Exhibit 7-14 presents speciation data for each state from the
ICR data analysis. Some interesting trends are apparent from
this map.  First, many states in the midwest and west emit
elemental mercury as the  predominant species, while the
ionic form predominates in most states in the Eastern U.S.
One reason is due to the type of coal burned in each area.
Data from the ICR showed that western coals, in general,
emit a higher proportion of elemental mercury than do
Appalachian coals.

Secondly, there is wide variation in speciation results from
one state  to the  next.    This  further  demonstrates that
generalities  concerning  a national  distribution may  not
necessarily apply  to a local condition.

Further data collection for mercury speciation can result in
similar maps  created for emissions.   For example, by
combining  speciation  and  emissions  data for multiple
industries, a map can be created showing areas of the country
emitting a particular species of mercury.  Such a map was not
prepared for this  report because it would essentially only
reflect coal combustion  emissions.   Sufficiently  robust
                                                      85

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speciation and  emissions  data  are unavailable for other
industries.

Limited speciation data for municipal waste combustion are
also available from EPA's Office of Air (phone interview
with Jim Kilgore, EPA). EPA estimated that air emissions
from  MSW combustion consisted of 85  percent ionic
mercury,  <5 percent particulate,  and  10 percent  was
elemental. Due to MACT regulations, many facilities are in
the process of installing mercury control technologies which
will affect the  speciation of  stack  gas.   Additionally,
variation is expected between facilities due to  site-specific
factors such as waste composition, boiler configuration, etc.
Therefore, the estimation has its limitations.

Nevertheless,  these  data  show that municipal  waste
combustion emissions are  significantly different than coal
combustion emissions, with a much higher proportion of
oxidized mercury.  One potential  reason  for this is the
increased chloride loadings in MSW feed, resulting in higher
rates of transformations to mercuric chloride in MSW stack
emissions.

The predominance of oxidized mercury in MWC combustor
stack  gas is confirmed by a European study (Paur 1999),
although  quantitative  estimates  are  not   provided.
Additionally, this source  identified  that  sewage  sludge
incineration resulted in higher levels of elemental mercury.

Data for mercury speciation in mining are available, however
this reflects data only for solid tailings material.  The study
(Kim  2001) estimated the make-up of mercury  from twelve
U.S. mercury and gold mine tailings using X-ray absorption
spectroscopy (XAS).  The  study found that most tailings
consist of cinnabar (HgS, hex) and metacinnabar (HgS, cub).
Other  species   of mercury found  included: montroydite
(HgO),  schuetteite (Hg3O2SO4), corderoite (Hg3S2C12),
and various chlorides which may be more mobile than the
cinnabar.
                                                      86

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                                              Chapter 8
                                            Conclusions
8.1 Conclusions
Even if all mercury use ended today, mercury would be
present well into the future due to the quantities of the
element in reservoirs and stockpiles. For example, some
items in  commerce, such as thermostats, will not be
disposed or removed from service for a long period of
time. Given that the use of mercury in the economy and
its associated health implications will not end for many
years,  mercury management  will continue to be  a
prominent responsibility.

The 3 7 sectors discussed in this report present a thorough
analysis of the life cycle of mercury throughout the U.S.
economy. Ideally, these data will be utilized in some
way to assist mercury management decisions, such as
policy formulation or the prioritization of research and
development  efforts.   This section summarizes the
estimates  calculated  in  the  report and  categorizes
findings by life cycle stages and releases in key sectors.
Additionally, a section devoted to high-profile sectors is
included.   Finally,  observations  concerning  the
application of these findings to prioritize future research
needs are provided.

8.1.1 Life Cycle Stages
Acquisition
Mercury can be  supplied by  secondary  production
facilities (430 tons per year),  imports  (variable), or
government stockpiles, and is often present within raw
materials as a contaminant.  The majority  of mercury
supply  for  use in product manufacturing can  be
accounted for by  secondary  production,  and secondly
from imports. Government stockpiles generally don't
supply mercury but act as a reservoir. In fact, the U.S.
Government stockpiles represent just over  50% of the
total domestic mercury reservoir (9,050 tons), indicating
that at least half of the  US reservoir can be tightly
managed.

According  to the  data in this report, the supply of
mercury to product manufacturing is greater than the
demand. If this observation indicates a trend, then the
main domestic supply of mercury may be compromised
since the industry may become at risk of financial non-
viability in such a business environment. It seems likely
that a  decrease  in mercury demand is inevitable as
product manufacturers gradually use less mercury or
substitute materials,  as  seen  in  electrical  lighting
manufacturing.  A consistent fall in mercury demand
will probably result in decreased prices for mercury and
lower profits for secondary production facilities. In such
a scenario, recycling facilities may close, resulting in
increased use of landfills and incinerators for mercury-
containing wastes.

Product Manufacture
Mercury use among industries can be characterized as
either  intentional  (i.e.,   from  secondary  mercury
production or government stockpiles) or unintentional
(i.e.,  constituent in  raw material).    Mercury  is
intentionally  used  as a raw material in  product
manufacturing, these mercury-containing products are
subsequently used commercially as well as by the
general populace.   Alternatively,  mercury  is  used
unintentionally when present  in trace  concentrations
within  raw materials. The amount of mercury used for
product manufacturing is comparable to the quantity of
mercury present from incidental uses where mercury is
a contaminant. Therefore, both uses (intentional and
unintentional)  contribute  significant  quantities  of
mercury to the total amount consumed.

Approximately 90% of the  1,700  tons per year of
mercury consumption in the U.S. can be attributed to
three sectors:  gold mining (80%), chlor-alkali (5%), and
utility  coal combustion (5%).  The use  of mercury by
gold mining and utility coal combustion is incidental
since the element is a constituent in the raw  materials
used.    These  results  limit  the  ability to rely  on
innovations  in product design as  a solution for the
industrial handling  of mercury.  Industries that use
mercury intentionally have more technological options
                                                   87

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for  reducing  mercury  consumption  compared to
industries that  use mercury unintentionally.   For
example,  a  lamp  manufacturer  has  a   broader
technological  horizon  for manufacturing  a  product
using/releasing reduced or zero mercury. Conversely, a
gold mining or utility coal combustion facility may find
it difficult, if not impossible, to  choose raw materials
without mercury. Consequently, most industries that use
mercury incidentally are limited to managing the releases
of mercury consumed. While eliminating mercury from
production processes is critical,  the  discussion above
demonstrates the importance of continued innovation in
mercury control technologies.

Where sufficient data are available to  estimate the
quantities of both mercury used (consumed) and mercury
leaving the system or process, in most cases the quantity
reported entering is greater than the  quantity reported
leaving.   This  indicates  that   mercury  is  either
accumulating within the system, or an error exists for at
least one of the estimates.  This mercury 'imbalance' is
most evident for  chlor-alkali  manufacturing.  The
estimated consumption is 79.1 tons per year, while the
quantity of mercury leaving  the process in waste or
product is 27.9, a difference of 51.2 tons per year. This
may be partly accounted for by chlor-alkali's large
mercury  reservoir  (22%  of  total domestic  mercury
reservoir).   However,   it  is   unlikely  that these
manufacturers are storing an  additional  51.2  tons of
mercury per year, rather, mercury leaving the system
may  be   under-reported  or  there  is  a  substantial
unaccounted for sink within the system.

Product Use
Mercury is found in various commercial and professional
products that tend to  be long-lived such as thermometers,
electrical  lighting,  and  thermostats.   Dental office
preparations were found to have the highest quantity of
mercury in use accounting for 13% of the total domestic
mercury reservoir.  With the  exception of chlor-alkali
manufacturing and  dental amalgams, mercury can be
contained  or  recovered  following   product  use.
Compared to the manufacturing stage, use of mercury-
containing products is characterized by considerably
higher releases  of mercury  into  the environment.
Despite numerous efforts to collect fluorescent lights,
thermometers, thermostats,  switches, and relays  a
majority of the mercury in use is disposed of as solid
waste. As mentioned above, there are several industry
efforts to decrease the  mercury content  in certain
products  and to develop  mercury-free products. This
does not imply, however, that managing the disposal of
these products has a limited utility since past and present
mercury-containing products are expected to remain in
use for several years.

Final Disposition
The disposition of mercury occurs through recycling,
exports, and releases into the environment.  Much of
present mercury consumption is met by existing recycled
material. However, available data do not provide a full
inventory of the  total  quantity of mercury recycled.
Exhibit  1-2 indicates that 430 tons per year of mercury
is   estimated to  be produced  from  U.S. mercury
recycling.   However,  based  on  examination  and
accounting of mercury-containing materials, only 17
tons of mercury is accounted for as scrap materials sent
to  recycling facilities.  Because most data on recycling
rates are based  on older or unpublished sources, these
estimates are assumed  to be low.  This highlights an
information gap that occurs throughout the report in
estimating the quantities of mercury in scrap and wastes
being recycled.  Data detailing sector-specific quantities
of mercury recycling rates were not available.

Generally,  the  export  of mercury is in  the form of
elemental mercury (220 tons per year) as opposed to
mercury-containing products or scrap.  Accordingly,
exports  do not  currently act as a significant mode of
spent product disposition. It is  conceivable, however,
that if  the  secondary  mercury production  industry
diminishes due to  reasons discussed above,  industries
still generating mercury-containing scrap may prefer to
export the waste to overseas recycling facilities or waste
sites. This situation is  a possibility if the total cost of
exporting the  waste is less than  domestic disposal.
Otherwise, scrap would be disposed of by landfilling and
incineration.

8.1.2 Releases
Segregated by media type, releases to solid  waste are
greatest  (1,500 tons/year),  followed by  air  (125
tons/year) and water (20 tons/year). Gold mining alone
accounts for 90% of solid waste releases. Without gold
mining, annual  releases to solid waste falls to 158 tons.
After gold mining, switches and relays disposal (29-50
tons/year) and  utility coal combustion (33 tons/year)
contribute the greatest amount to solid waste releases.
Management of  mercury-containing solid  waste is
complicated because the mercury is embodied in various
forms such as a switches, flyash, or ore tailings.  Solid
wastes  are generally  stored in  landfills where  the

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possibility of mercury leaching into the environment is
monitored. It is expected that mercury-containing solid
waste will decrease as product manufacturers develop
alternative, mercury-free processes. However, this is not
expected  to be  as  noticeable for  industries  handling
mercury incidentally such as gold mining and utility coal
combustion, particularly as these industries grow and as
mercury removed from air continues to be disposed as
solid waste.

Mercury releases to air are clearly a significant issue
because of their transport over long and short distances.
The most significant input of mercury into air is utility
coal combustion.   This  industry  has already been
identified as  a significant  input  and has  received
substantive attention over the past decade. Second to
this  industry  is  coal  combustion by   residential,
commercial, and industrial sources with 21.2 to 23.6 tons
per year released into air. Based on this report's mercury
use and  release estimates,  utility  coal  combustion
releases approximately 45% of mercury input into the
air, whereas non-utility coal combustion may release 39 -
100%  of the  mercury consumed  into air.   A  lower
effectiveness of mercury capture  by non-utility coal
combustion  renders this sector as  a major source of
mercury releases, particularly if industries utilizing coal
combustion (non-utility) continue to grow.

Similar to air, mercury releases to water can result in
serious health issues.  According to this study's data,
sewage treatment and sludge incineration (5.5 tons per
year) as well as dental offices (7.4 tons per year) release
some  of the highest quantities of mercury into water.
Compared to mercury releases into air and solid waste,
water releases were  considerably lower. However, data
on mercury releases to water were only found for four of
the thirty-seven  industries included  in  this report.
Because data are not available for many industries,
mercury releases to  water may be a larger problem than
depicted in this study. The limited data may reflect a lack
of industry efforts to monitor mercury releases to water.
For example,  laboratories commonly dump chemicals
into sinks in low concentrations but potentially high
volumes.  Ultimately, the burden is passed to POTWs,
which probably explains why this sector has the highest
releases of mercury to water. The problem may not be
the inability of POTWs to handle  mercury-containing
waste, rather, it is the disposal of mercury in places such
as sinks and drains without monitoring.

Data on the geographic distributions of mercury as a
pollutant  demonstrate that total  releases  are  most
abundant  in  the  eastern United States  and Nevada.
Furthermore, available  data revealed differences  in
mercury speciation in air emissions between utility coal
combustion and  municipal waste combustion  sites.
Specifically, the average mercury speciation breakdown
for coal-fired utility boilers is  54% elemental, 43%
oxidized, and 3% particulate.  When broken down by
state, the eastern boilers release mostly oxidized forms
while the west is characterized by higher elemental
releases. This contrast is most likely due to differences
in coal. Average municipal waste combustion releases
are estimated to be 85% oxidized,  5% particulate, and
10% elemental. Given that different mercury species
have varied regional or global impacts, this finding is
significant relative to air pollution control  strategies.
These data have much potential for illustrating the large-
scale patterns and potential  effects of mercury releases.
While  the data in  this report provide  a reasonably
accurate depiction, more consistent data would minimize
uncertainties.

8.1.3 Key Sectors
To  help  identify  research  priorities,   the  sectors
corresponding to the highest quantities in mercury use,
release, and reservoirs are identified.  Sectors included
are those estimated as using  or releasing at least 100 tons
of mercury annually, or representing a mercury reservoir
of at least  100 tons.  The selection of 100  tons is
somewhat  arbitrary, but allows for a narrowing  of
sectors  from the 37  evaluated to a more manageable
number. A summary of this review can be found in
Exhibit 8-1. Ten sectors are listed and discussed below.

Chlor-alkali manufacturing
Chlor-alkali production using the mercury cell process
(the only process that employs mercury) is conducted at
11  U.S. locations accounting  for 12% of total  US
chlorine production capacity. Approximately 79 tons of
mercury are used in chlorine production annually, with
an additional 2,000 tons present in the U.S. operating
plants. These data suggest that the presence of mercury
in the chlor-alkali industry is a concern both in terms of
currently used quantities as well as the large quantities
contained in the plant that might be released into the
economy or the environment at a later date.  The latter
concern is particularly relevant given the 50 ton gap
between mercury consumption and releases discussed in
section  8.1.1.   Mercury  releases from chlor-alkali
production is currently regulated by USEPA air, water,
and solid waste policies.
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             Exhibit 8-1. Summary of Sectors with 100+ Tons of Mercury in a Life Cycle Stage
        Mercury Sector
Mercury Present in
  Raw Materials
> 100 Tons per Year
Mercury Released to All
 Media > 100 Tons per
        Year
Mercury Present as Reservoir
     > 100 Tons Total
        Chlor-alkali
        Manufacturing

        Dental
        Preparations

        Gold Mining

        Landfills

        Secondary
        Mercury
        Production

        Thermometers

        Thermostats

        Switches and
        Relays

        Government
        Stockpiles

        Utility Coal
        Combustion
                                                         2,000
                                                          1,200
       1,370
       430
        1,348
                                                          230

                                                          630


                                                         4,850
       105
        * - There were no available data on mercury quantities in landfills. Presumably, landfills have large mercury reservoirs based on the
        amount of industrial solid waste delivered to the sites.
        ** - Thermometers have an estimated reservoir of 45-85 tons; the sector was included based on the widespread use of these
        instruments and, consequently, its relatively high reservoir.
Ongoing  research needs  include  more  accurately
quantifying the emissions and destination of mercury
used as a raw material. Based on consumption data and
release estimates, much greater quantities of mercury are
consumed per year than are estimated to be released.
More accurate accounting would serve to identify where
pollution prevention  and control activities  could be
targeted, or, if previously unknown, the identification of
mercury 'sinks' within the plants could potentially be
addressed.

Dental Preparations
Up to 1,200 tons  of  mercury are present in the U.S.
population as part of use in dental preparations (i.e.,
amalgam  fillings).   Among  all  sectors,  the use of
mercury in fillings is  the most intimate and direct with
respect to the manner in which it is consumed (i.e., in a
person's mouth).  Unfortunately, very little opportunity
                             exists to  address  this  mercury.   Instead, pollution
                             prevention and control opportunities focus on activities
                             in  dental  offices across the United States, including
                             alternatives to mercury fillings and better management
                             of mercury  wastes  (including  old  fillings).   Many
                             technologies are in use but are not universally adopted.
                             Non-mercury fillings have been  successfully used, but
                             costs are reportedly higher. For facilities that continue
                             to  use mercury, technologies  and  practices can  be
                             employed to reduce the releases  of mercury to the
                             environment. One technology reduces the quantity of
                             mercury  in  washwater, consisting  of an amalgam
                             separator to recover the mercury from the water prior to
                             sewer discharge.  The  development  of less expensive
                             non-mercury alternatives could be one key to increased
                             usage.
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Gold mining
Mercury is present as a contaminant in the ore and
requires removal during processing, typically as mine
tailings (solid waste) rather than as air or water releases.
Among all industries included in this report, gold mining
was  distinguished  by having the highest quantity of
mercury released into solid waste.  Gold is mined at
about 100 locations in the United States, mostly located
in Nevada and Alaska.  Presumably, solid waste from
gold  mining presents  limited  risk  to  the general
population  since  mines  are  typically  located in
population-sparse areas.  Ranking states by population
size  places Nevada at 35th (although it is the  fastest
growing population  in the U.S.) and Alaska at 48th
(USDOC 2001).   However, ecological risk from the
relatively high quantities of mercury in mine tailings
may be an issue.

Several pollution prevention opportunities have been
implemented by a portion of the  gold mining industry.
One such opportunity is mercury recovery. As a result
of processing, mercury becomes concentrated in certain
wastes  which can be managed onsite  in  retorters.
However, not all  facilities have retorting processes.
Therefore,  this may be  a candidate technology for
technology  transfer  emphasis.     Other  pollution
prevention and control opportunities involve removing
mercury early in the process.  In gold processing, the
valuable elements (e.g., gold and silver) are leached from
the ore and concentrated prior to being recovered in solid
form.  Other  impurities such   as  mercury  can be
simultaneously  leached from the rock as well,  and
similarly concentrated and separated.

An additional need is to better  quantify the mercury
actually present and released in order to develop a more
accurate and  consistent measure of both mercury in
incoming ore and  mercury released to air, water, and
solids. Additionally, waiting for more data as relatively
small gold mines are being required to report may  help
clarify uncertainties.   Such  programs will assist in
identifying whether this particular sector should  be a
priority for additional research needs, and may help to
identify facility-specific pollution prevention and control
needs.  Similarly,  information on the extent to which
mercury leaches from tailing piles into the environment
can help gauge the size of the potential problem.

Landfills
Unknown quantities of mercury are present in thousands
of surface landfills used for disposal of municipal and
industrial  waste,  however,  mercury  quantities are
expected be relatively high as a result of previous and
current disposal of products containing mercury. Few
options are available to address the mercury already in
the landfill, however, opportunities exist to decrease the
quantities of mercury entering landfills. As long as the
mercury remains in the landfill, its effects are much less
severe than  if  it migrates  to  air  or groundwater.
Monitoring of mercury in the vented gas and of ground
water from down-gradient wells will identify any site-
specific mercury concerns, and will assist in identifying
necessary remedial actions. Such monitoring technology
already exists, although application of monitoring and
analysis requirements is on a site-specific basis.

Secondary Mercury Production
Over 400 tons per year of mercury is supplied from
secondary mercury sources to satisfy existing demand.
Opportunities to  impact  the  quantity  of mercury
produced depend entirely on mercury demand, which is
better addressed from other sectors. Recovering mercury
from scrap likely  results  in overall  reduced releases,
since without this sector the same scrap would be
landfilled or incinerated. Current estimates of releases
from secondary mercury production are relatively low,
however, aggregate sums may increase as the number of
recovery facilities continues to increase. A more up-to-
date estimate will  be available in summer 2002 when
2000 TRI data are  released. However, the  discrepancy
between the  quantity reported in secondary mercury
facility TRIs and the aggregate recycling rate reported
among various industries is likely to remain.

Thermometers. Thermostats. Switches, and Relays
Up  to  860  tons  of  mercury  is  associated  with
thermostats, switches, and relays in  commerce.  An
additional 45-85 tons of  mercury is estimated to be
associated with  thermometers in commerce.   These
relatively high quantities  are due to a wide array of
manufactured products which utilize  mercury, the
uneven  application  of existing  mercury recycling
programs for such products, and the  long life of these
products (in the case of switches, the device typically
lasts longer than the product containing the switch).

Government Stockpiles
For government stockpiles, management opportunities
are currently being studied and assessed as part of a
government-wide strategy led by the Defense Logistics
Agency.  Almost 5,000  tons of elemental mercury are
stored in locations across the country as part of the U.S.
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Government Stockpiles.  It is likely that stabilization,
treatment, and disposal alternatives will be identified as
potential management options.   These  options may
require additional research to assess their feasibility.

Utility Coal Combustion
Utility coal combustion is practiced at over 400 utility
plants nationwide and has been identified as a significant
source of  mercury air emissions.   USEPA (1997d)
estimates that this  industry accounts for 33% of all
mercury air releases.  An estimated  105 per year is
present in coal that is burned in boilers and 88 tons  per
year enters the environment as air, water, or solid waste
releases (the discrepancy is probably due to different
calculation methods for consumption and release).

Mercury air releases from utility coal combustion  are
approximately 54%elemental (Hg°).  When compared to
other mercury  species, elemental mercury generally has
the largest global impact since it can be carried over long
distances.   The USEPA has  published  its intent to
regulate mercury-containing air releases from utility coal
combustion (65 FR 79825; December  20, 2000).  To
date, mercury associated with utility coal combustion has
received the most attention compared to other sectors in
the report.  Reactions have  included  strong  public
concern, policy actions, and significant R&D efforts.

Energy conservation  measures  represent  the  most
obvious method to  decrease electricity  demand and
therefore   decrease  associated   mercury  emissions.
Additionally, a migration toward existing and emerging
alternative  energy applications represents  substantial
potential for reduction of coal use; such applications
include an array of products and design alternatives,
including passive and active solar building design, and
a variety of distributed generation technologies such as
geothermal heat pumps and fuel  cells.  Changes to  the
coal combustion process itself may also reduce mercury
releases. These process changes could include enhanced
coal pretreatment to precipitate  and capture mercury
from coal prior to combustion.

8.1.4 Prioritizing Research Needs
The estimates  presented in this report act as a balance
sheet or "snap shot" of mercury  in the U.S.  economy.
While  the  data are useful for understanding relative
magnitudes, they  provide little  information  on  the
temporal trends of mercury use.  Changes in the use,
release, and disposal of mercury that occur  over time
from   industry  to  industry  are  important   when
establishing new and ongoing priorities for research and
development efforts. A valuable area for further work
includes generating  updates  to  the  baseline  data
presented in this report so that trends can be identified.
Such data could help reveal important changes that can
have an influence on future mercury priorities.

Appearing from this "snap shot" is a divergence between
the quantity  of mercury supplied and  the  quantity
demanded for use in manufacturing processes.   This
imbalance  may have  significant  ramifications  with
respect to the future of secondary mercury production.
Specifically, if the recycled mercury supply consistently
and  increasingly outpaces demand, the industry will
likely  deteriorate  as prices fall.    Consequently, a
potential research priority  is to analyze current and
future financial solidity of mercury recycling markets in
order to determine if intervention is necessary  to
maintain viability. The secondary mercury market plays
an important role throughout the use of mercury in the
economy.  Most apparent is that secondary  mercury
production reduces the quantities of mercury-containing
products from being incinerated (releasing mercury into
air) and / or reaching landfills. If the industry were to
collapse, there would be significant implications for
mercury reservoir and disposal management.

Clearly, these data alone can be helpful in providing a
foundation  for any  prioritization  of research and
development expenditures. For example, relative sector
rankings of mercury quantities may be sufficient for
high-level  prioritization.   Alternatively,  additional
information can be  overlaid  on this  report's data for a
more refined analysis.   Relevant information could
include the presence (or absence) of regulatory drivers or
the existing level of support by EPA and other entities
going  toward  new technological  developments  in
specific sectors.  Whether the data are used  alone  or
juxtaposed with new information, they can serve two
purposes. First, they can act as away of calling  attention
to sectors  deserving of research  and  development
prioritization. Secondly, the data can serve as a baseline
from which  to project  and  measure the quantifiable
impact of existing and new technological and policy
developments.

While data quality is important, it should not  be given
overriding  emphasis in a prioritization scheme.  The
reasonable accuracy of these estimates may be sufficient
for the purpose of differentiating  between sectors
associated with negligible quantities of mercury and
                                                   92

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those associated with substantial quantities of mercury.
Accordingly, efforts  to improve data should address
significant gaps or inconsistencies rather than trying to
obtain exact estimates in industries that  are already
relatively well-documented.   Examples  of significant
data  gaps  include  estimates of recycled mercury
available  compared to the reported quantities  sent to
recycling facilities or the apparent accumulation of
mercury in chlor-alkali facilities.

Lastly, these data can form the start of a foundation of
mercury use, release, monitoring and exposure data to
begin to draw connections between mercury use, release,
transport, fate,  exposure and risk. This would involve
juxtaposing facility and location-specific data used in
this report with geographically-specific monitoring and
exposure  data  to  detect  patterns  and relationships
between points of release and points of exposure.
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