Chlor-Alkali Sector Mercury Reduction Accomplishments
Binational Toxics Strategy Mercury Work Group Meeting
May 17, 2006 Art Dungan, President The Chlorine Institute, Inc.
1
Agenda
• Context – some duplication of earlier presentation • CI Commitment to the BTS • Mercury use in chlor-alkali facilities • Why some facilities are adding mercury • Commitment to enhanced monitoring of cell room emissions • Commitment to full accounting for mercury we use • Chlorine – Mercury MACT Regulatory Issues
May 17, 2006 The Chlorine Institute, Inc. 2 2
Commitment to BTS
• In 1996, the USA Mercury Cell Chloralkali industry committed to a 50% reduction in mercury use by 2005 in support of the US Binational Toxics Strategy Goal
– In July 1997, industry representatives met with high EPA officials to discuss the commitment in detail
May 17, 2006 The Chlorine Institute, Inc. 3 3
Commitment to BTS
(con’t)
– CI/Industry committed to provide EPA with an annual progress report – CI has just issued its Ninth Annual Progress Report
May 17, 2006
The Chlorine Institute, Inc. 4
4
Mercury Use Since 1990
Mercury Use by Year
Thousands of Pounds of Mercury 500 400 300 200 100 0
Actual Base Period
1990 1992 1994 1996 1998 2000 2002 2004 2006
May 17, 2006
The Chlorine Institute, Inc. 5
5
Mercury Use Since 1990 Per Ton of Chlorine Capacity
Mercury Used per Ton of Cl2 Capacity
Pounds of Mercury/ Ton of Cl 2
0.32 0.28 0.24 0.20 0.16 0.12 0.08 0.04 0.00
Base Period
Actual
1990 1992 1994 1996 1998 2000 2002 2004 2006
May 17, 2006
The Chlorine Institute, Inc. 6
6
Mercury Purchases vs. Mercury Use
• In the long term mercury purchases should approximate mercury use • Near term issues – New more stringent Mercury MACT are requiring process changes – Dec 2006
– Fugitive emissions from cell rooms likely will be reduced significantly as part of the new regulation
May 17, 2006 The Chlorine Institute, Inc. 7 7
Sources of Fugitive Emissions
Equipment Maintenance [Major]
– Cell openings – Decomposer openings – Other maintenance (e.g., piping, vessels)
Process Leaks [Minor]
(e.g., Hydrogen process stream)
May 17, 2006
The Chlorine Institute, Inc. 8
8
Actions to Reduce Fugitive Emissions
• Larger Equipment to Reduce Cell Openings
– Decomposers – in some cases - up to 1/3 – Means more mercury in inventory
• Improve Electrical Distribution System to reduce primary cell maintenance
– Poor electrical distribution can damage anodes requiring repair (cell openings)
• More reliable equipment
– Sealless mercury pumps – Hydrogen coolers (larger, better design)
May 17, 2006 The Chlorine Institute, Inc. 9 9
Larger Equipment Means More Mercury in Inventory
• Mercury purchases in the last four years exceeded mercury use by 351 tons • This mercury is present in the process and the increased inventory can be observed by physical measurement
May 17, 2006 The Chlorine Institute, 10 Inc. 10
Surplus Mercury From Closed Facilities
• Since the commitment was made, the number of mercury cell facilities decreased from 14 to 8
– We consider mercury obtained at an operating site to be a purchase even if the mercury is obtained from a closed site – If we credited ourselves for surplus mercury from closed sites, mercury purchases since 1999 would be negative.
May 17, 2006 The Chlorine Institute, 11 Inc. 11
Closure vs. Conversion
• Company must consider economics • Is the high cost of conversion justified? • Power cost, salt/brine supply, and customer base are key issues • 30 mercury cell chlor-alkali plants have closed in the last 37 years.
May 17, 2006 The Chlorine Institute, 12 Inc. 12
Closure vs. Conversion
(con’t)
• Three converted to membrane and are still operating. • One attempted to convert to membrane but was unsuccessful and closed. • One converted to diaphragm and subsequently closed. • Three had other non - mercury processes operating and are still operating today. • Twenty two sites simply closed resulting in some impact in the local economies.
May 17, 2006
The Chlorine Institute, 13 Inc.
13
Enhanced Monitoring of Cell Room Emissions
• Third parties have raised concerns that unaccounted for mercury is escaping to the environment via cell room emissions • All measurements conducted on cell room emissions have shown that emissions are within the current NESHAP allowance – In many cases, emissions were measured to be only 50-60% of allowable limits
May 17, 2006 The Chlorine Institute, 14 Inc. 14
Enhanced Monitoring of Cell Room Emissions (con’t)
• Techniques have been developed to measure cell room emissions a on a continuous basis. • Two facilities completed installations in 2005 • Several others in progress • EPA verified methodology – within MACT limits
May 17, 2006
The Chlorine Institute, 15 Inc.
15
Full Accounting for Mercury Used
• 2,600 tons of mercury inventory in the eight plants currently operating • Use is slightly less than 1% (average 24 tons/year 2001-2005) • Physical measurement of mercury inventory is difficult
– Increases emissions to environment – Increases risk of personnel exposure – Increases potential for a spill
May 17, 2006 The Chlorine Institute, 16 Inc. 16
Unaccounted for Mercury
• Began reporting in 2004 back to 2002 • Declined 89% from 28 tons in 2002 to three tons in 2005 • Unaccounted for mercury is within the statistical accuracy of measuring mercury inventories
May 17, 2006 The Chlorine Institute, 17 Inc. 17
Regulatory Issues
• New, more stringent MACT promulgated in December 2003 – effective December 2006 • Legal challenges to MACT
– Earthjustice lawsuit challenging the rule – NRDC petition for EPA to reconsider – EPA has agreed to reconsider – scope unknown [minor changes or major rewrite?]
May 17, 2006 The Chlorine Institute, 18 Inc. 18
Regulatory Issues (con’t)
• Legal challenges to MACT (contd)
– CI has been allowed to intervene – EPA plans to do additional testing at other facilities – CI fully cooperating with EPA
May 17, 2006
The Chlorine Institute, 19 Inc.
19
Summary of Commitments
• Work to continue to fully account for the mercury in our process inventory • Continue to work to reduce the amount of mercury used • Develop methods to more accurately measure emissions from the cell rooms at each chlor-alkali facility
May 17, 2006 The Chlorine Institute, 20 Inc. 20
Summary of Commitments (con’t)
• Further reduce the emissions from point sources so emissions are less than 10% of currently allowed limits • Implement the extensive new MACT work practices, monitoring, and reporting requirements
May 17, 2006 The Chlorine Institute, 21 Inc. 21
Goals / Path Forward
• Fully comply with the new MACT • Continue mercury reduction activities • Integration of BTS reporting with UNEP reporting
May 17, 2006
The Chlorine Institute, 22 Inc.
22
Questions?
Art Dungan - 703-741-5764 arthurdungan@CL2.com The Chlorine Institute, Inc. 1300 Wilson Boulevard Arlington, VA 22209 www.chlorineinstitute.org
May 17, 2006
The Chlorine Institute, 23 Inc.
23