Prescription for Mercury and PCB Elimination

Mercury and PCB Reduction Guidance for Oil Refineries

A joint project between City of Superior Wastewater Division of Public Works and Murphy Oil USA Superior Refinery

Mercury and PCB Reduction Guidance for Oil Refineries

Report prepared and printed using funds from the following grant: Environmental Protection Agency Great Lakes National Program Office Grant # GL-97516901-0

Acknowledgements: Thanks to Murphy employees: Liz Lundmark (Environmental Manager), Corey Mead (Environmental Engineer), Paul Velin (Warehouse), John Peterson (Laboratory) and Brad Carlson (Instrument Department) for their help at Murphy Oil Refinery. Special thanks goes to Zada Talus, formerly at Superior’s Wastewater Division of Public Works (WDPW), for her work establishing contacts, conducting the mercury inventory, compiling the information for this report, and contributing several early drafts of the report. Diane Thompson, Jane Ed- wards, and Bonita Martin from the WDPW also provided helpful reference material, information, and guidance. Kari Jacobson Hedin prepared the final version of this report.

Report prepared by: City of Superior Wastewater Division of Public Works Pollution Prevention Team Kari Jacobson Hedin Zada Talus Diane Thompson Jane Edwards

See the Murphy Project online and obtain an electronic copy of the report at: http://www.ci.superior.wi.us/publicwks/wastewater/MurphyProject.htm

Printed on recycled paper

March 2005

Contents

Introduction…………………………………………………………………. 1 A Voluntary Pollution Reduction Program at Murphy Oil Refinery………... 2

Diagnosis: Mercury and PCBs Cause Environmental Distress………………….. 3 What You Should Know About Mercury…………………………………………………… 3 What You Should Know About PCBs……………………………………………………… 9

Collaborating to Devise a Treatment Plan for a Healthy Lake Superior………… 12

Take Your Medicine: A Voluntary Approach to Fix the Pollution Problem………. 13

How to Write Your Own Prescription for Mercury and PCB Elimination………… 14

A Remedy for Mercury Use at Murphy Oil…………………………………………. 18

Tracking Down the Source of the Disease………………………………………………... 22 How Serious is the Disease?...... 22 Keeping the Laboratory Disease-Free…………………………………………………….. 24 What to do if the Disease Spreads…………………………………………………………. 26 Prevent the Disease at its Source………………………………………………………….. 26

Results of the Mercury Inventory at Murphy Oil…………………………………… 28

A Remedy for PCB Use at Murphy Oil……………………………………………... 30 A PCB Checkup………………………………………………………………………………. 30

The Healing Process………………………………………………………………………… 32 Healthy Alternatives …………………………………………………………………………. 32

A Long-Term Plan for Staying Healthy……………………………………………… 33

Appendices……………………………………………………………………………. 35

References……………………………………………………………………………. 57 Introduction

Imagine several biologists in northern Wisconsin studying the reproductive success of fish-eating water birds such as herons and loons. Over several years of the study, the biologists notice certain patterns: some the adults are not producing as many young as they once did, and several birds are displaying behavioral abnormalities. To find the causes for what they see, the biologists run tests to determine the concentration of mercury and polychlorinated biphenyls (PCBs) in the tissues of some of these birds. When the tests show the concentrations of these toxins are high, the biologists are faced with new questions: Are the patterns they have been noticing due to these pollutants? If they are, what can be done to reduce mercury and PCBs release into the environment, where they can get into the food chain and affect the health of predators that eat fish, including humans? These biologists are much like doctors, only they are not diagnosing the causes of a disease in an indi- vidual patient, but the factors that are causing ailments in entire ecosystems. Just like doctors, they must first find what is causing the problem. Then they must determine a course of action to reduce or eliminate the problem, though it is much more difficult than simply writing a prescription for a bottle of medicine. Most environmental problems have many sources, and it takes the combined efforts of governments, communities, and independent organizations to decide on an effective and comprehensive cure.

A biologist studies levels of mercury and PCBs in loons

1 A Voluntary Pollution Reduction Program at Murphy Oil Refinery

This guidance manual is a prescription to reduce mercury and PCBs in the environment. It gives direction to employees at oil refineries and other industries who want to learn how to reduce the mercury and PCBs they use in their daily operations, and it also shows how voluntary partnerships between industry and governmental organizations can work to enhance pollution prevention initiatives. This guide uses as a case study the PCB- and mercury- reduction efforts at Murphy Oil USA Superior Refinery (Murphy Oil), a 35,000 barrel-a-day refinery on Stinson Avenue in Superior, Wisconsin.

In 2001, Murphy Oil and the City of Superior Wastewater Division of Public Works (WDPW) entered into a voluntary partnership to develop a pollution prevention guidebook for refineries and other industries interested in reducing use of mercury and PCBs. WDPW staff, with the assistance of Murphy employees, conducted an inventory of mercury at Murphy and reviewed Murphy’s removal activities for PCBs. This was done in an effort to work towards the elimination of devices containing mercury and PCBs at Murphy Oil and provide a case study for the guidebook. Murphy Oil is joining other industries, including three steel mills in Indiana (Ispat Inland, USS Gary Works, and Bethlehem Steel) that partnered with the United States Environmental Protection Agency (US EPA) and the Indiana Department of Environ- mental Management in efforts to reduce the use of mercury- and PCB-containing products and incidental releases of these pollutants.

HOW CAN YOU USE THIS PRESCRIPTION?

1) To learn about the environmental and health problems caused by mercury and PCBs.

2) To put together a voluntary pollution reduction plan for mercury and PCBs, develop partnerships with other groups, and gather funding.

3) To use Murphy Oil Refinery’s pollution reduction efforts as a guide to discover ways to reduce mercury and PCBs in your own refinery.

4) To conduct an inventory of devices and products containing mercury and PCBs on site, properly document the results of this inventory, and insure the proper disposal of these products.

5) To develop a spill policy for mercury, phase out use and identify alternatives to mercury- and PCB-containing products, and organize a mercury-free purchasing policy.

2 Diagnosis: Mercury and PCBs Cause Environmental Distress

The usefulness of mercury and PBCs and their many applications in industry is well known – their negative impact on the environment has been much harder to recog- nize. Only in the recent past have we begun to understand the risks posed by these materials when they are used in industry.

What You Should Know About Mercury

The expression “mad as a hatter” comes from 19th-century hat makers who used mercuric nitrate until the 1940s to aid in the felting process. 1, 2 Hat-makers in Dan- bury, Connecticut developed a reputation for strange behavior that was eventually traced to their exposure to mercury, and the “Danbury shakes” was a term that re- ferred to the tremors that resulted from mercury poisoning. In extreme cases, people who have had repeated or excessive contact with mercury or mercury vapors have experienced a range of health and behavioral problems, from tremors, head- aches, insomnia, stumbling, and depression, to brain, liver, and kidney damage. 2.Many hatters eventually died of mercury poisoning. 1, 3 However, mercury doesn’t just cause health problems in people; it can get into the environment and lead to wide-ranging troubles, especially in aquatic ecosystems.

Mercury: A Useful but Dangerous Metal:

Even during Roman times, mercury’s usefulness and toxicity were well known. Slaves who were sent to mine cinnabar, the mineral that contains mercury, were basically given a death sentence — they only survived 2 or 3 years in the mines. Mercury is most familiar in its elemental form, often called quicksilver, where it exists as a shiny silver-white liquid at room temperature. The letters “Hg” represent the ele- Elemental mercury droplets ment mercury on the Periodic Table of the Ele- sitting atop cinnabar ments. As the only liquid metal, it is a good electrical conductor and it expands and contracts uniformly in response to changes in temperature and pressure. 2 Elemen- tal mercury is used in many instruments, including thermometers, barometers, and electrical switches (Table 1).

3 All the mercury in use today was originally acquired from natural sources; it continues to be mined from mercuric sulfide (cinnabar) in the earth. 2 Though mercury can also be released from natural sources such as volcanic eruptions, much of the mercury that makes its way into the environment comes from anthropogenic (human-caused) sources (Table 1). Mer- cury can be released from coal-burning power plants, during the manufacture of mercury- containing products, metal mining, and the use of chemicals. And humans don’t just put mercury in the air. Mercury can also make its way from wastewater into our lakes, rivers, and oceans (Figure 1).

The deposition rates of mercury from the atmosphere today are 1.5 to 3 times higher than they were before the Industrial Age. 2, 3, 4 Because it is an element, mercury cannot be broken down — when it is released into the environment it remains there permanently, circulat- ing through the soil, water bodies, and the atmosphere. Mercury vapors released from coal- burning can travel thousands of miles from where they were emitted. When the mercury is flushed from the atmosphere during rain events, it can fall on countries and isolated locations where no man-made pollutants are produced. Though mercury cannot be broken down, it exists in the environment in many different forms. Mercury commonly binds with other compounds to make inorganic or organic salts, including mercuric sulfide, (HgS), mer- 2 curic chloride (HgCl2), and methylmercury (HgCH3) . Methylmercury causes many long-

TABLE 1. PRIMARY SOURCES OF MERCURY RELEASE 2, 3

1. Natural sources: mercury that is mobilized from the earth’s crust; through volcanic activity; evaporation from the ocean; weathering of rocks; and forest fires. 2. Anthropogenic sources: • Release of mercury from raw materials, such as coal-fired power plants. • Mercury is discharged with wastewater into lakes and rivers. • Release of mercury from products and processes during manufacture, leakage during use, and during disposal. Some products that intentionally contain mercury: • Mercury-silver amalgam used in dental fillings • Thermometers and blood-pressure cuffs • Electrical switches in thermostats • Batteries • Manometers for measuring and controlling pressure • Fluorescent lamps • Manufacture and use of chlorine and caustic soda • Remobilization of historic anthropogenic mercury from releases previously deposited in soils, sediments, water bodies, and landfills.

4 term environmental problems because it is readily absorbed into the tissues of living organisms, and it is the reason that so many efforts are being made to reduce the production and use of mercury worldwide. 3,4

At room temperature, liquid metallic mercury will evaporate and form mercury vapors. Mercury vapor is colorless and odorless, and inhaling the invisible vapor in sufficient quantity and over long periods can lead to chronic mercury poisoning. Some people who have breathed mercury vapors report a metallic taste in their mouths and tingling in their fingers. Mercury vapor does not usually escape the instruments in which they are contained unless they break or are used improperly. 2 If they are broken and disposed down the drain or in the trash, the mercury is released, and even a small amount of mercury can lead to environmental problems.

One teaspoon of mercury, under the right conditions, is enough to cause fish consumption advisories in a 1,400- acre lake for a year.

Mercury Can Escape From Everyday Items

Though most anthropogenic mercury in the U.S. is emitted to the air by coal-burning power plants, a surprising amount of mercury is contained in equipment commonly used in industries such as oil refineries. In US industry in 2000, the total amount of mercury in equipment was estimated at more than 3,000 metric tons. Between 70 and 140 tons of mercury are recycled per year from this equipment, but mercury in new equipment accounts for approximately 250 to 300 tons per year. 13 Simply manufacturing mercury-bearing equipment can lead to ½ ton of mercury emissions into the atmosphere per year in the US, while mercury production for this equipment accounts for an additional ½ ton of mercury emissions. Once the equipment is in- stalled, the possibility of a release is present because the equipment can leak, break, or be disposed of improperly. Though these emissions are small compared to coal burning, they are important because they can lead to disproportionate human and environmental health problems. 13 Any effort to prevent the use of this equipment or to encourage proper disposal can have positive effects for human health and the environment. By controlling the use and disposal of mercury-containing equipment, refineries have the opportunity to control the fate of a major portion of all mercury present on site. 13

5 Bioaccumulation and Biomagnification of Mercury:

Once mercury has made its way into a water body either through atmospheric deposition or by discharge from wastewater treatment plants, it is deposited in the sediment where mi- crobes convert it to methylmercury (Figure 1). 2 From there, mercury has the capacity to build up in the tissues of organisms (a process called bioaccumulation) and to concentrate up the food chain (a process called biomagnification). 2 The mercury taken up by fish is present throughout its body, so it cannot be removed by cutting away a certain portion of a fish. 5 When people and animals eat a lot of fish from mercury-polluted waters, high methylmercury exposure can have many adverse effects. 3, 5 Methylmercury can cross the placen- tal barrier in mammals and affect the fetal brain and nervous system, leading to irreversible developmental problems and learning disabilities that affect memory, attention span, and language skills. 2 Methylmercury buildup in wildlife can result in reduced reproductive success, impaired growth and development, behavior abnormalities, and even death. 4

Figure 1. Mercury cycles through the environment, where it is converted into methylmercury and incorporated into the food chain.

6 In 2003, 45 states had mercury-related fish consumption advisories ; some advisories were statewide, while some applied to certain lakes, rivers, or coastal areas. Since 2001, all of Wisconsin’s lakes have had fish consumption advisories, including the Lake Superior basin. 6 Because of the impact of mercury on the developing nervous system, children, pregnant women and women of childbearing age (16 to 49 years of age) are advised to carefully monitor their fish consumption, though the nutritional benefit of fish can outweigh the risk as long as advisory guidelines are followed. 2, 6

The most likely way for people to get mercury poisoning is

by eating contaminated fish.

Efforts to Reduce Mercury in the Environment:

Because Lake Superior has such a large surface area, a lot of mercury ends up in the lake through atmospheric deposition from local and international sources; many programs, agencies, and corporations are making efforts to reduce mercury use and release in the areas surrounding the lake. The Great Lakes Water Quality Agreement (GLWQA), signed by the U.S. and Canada in 1972, seeks to restore and maintain full beneficial uses of the Great Lakes System. 7 GLWQA commits the two nations to virtually eliminate the input of persistent toxic substances in order to protect human health and living aquatic resources. GLWQA lists mercury as a critical pollut- ant for its presence in open lake waters, its ability to cause or contribute to the failure to meet GLWQA objectives, and Mercury can be released during the manufacture of mercury- its potential to bioaccumulate. containing products such as the switch above. The Lake-wide Management Plans (LaMPs) were put together under GLWQA by the US and Canada to reduce critical pollutants and restore beneficial uses to the Great Lakes. These plans include a reduction schedule of 80% reduction of loading of mercury and a 95% reduction of

7 PCBs by 2010. In addition, the US and Canada signed the Binational Toxics Strategy in 1997, which sets a challenge of 50% reduction of mercury released to the air and water na- tionwide by 2006. 3 Such efforts have resulted in a 60% reduction of mercury use and release in the Lake Superior Basin between 1990 and 2000. 7 Ultimately, the cost is less to both the economy and the environment when the effort is made to prevent the use and release of mercury rather than trying to remove it through end-of-pipe controls. 2

Substituting products and processes that contain mercury with those that do not can be a very effective way of reducing the amount of mercury in the industrial and private sectors and ultimately the environment. Usually these substitutions are cost-effective, especially as demand for mercury-free products increases. 2 Because more industries and manufacturers are aware of the problems associated with mercury and available alternatives, demand for mercury declined 75% between 1988 and 1996. 4 The US EPA promotes voluntary rather than regulatory approaches to reduce mercury, and a voluntary agreement like the one between Murphy Oil and WDPW is a very effective way to reduce mercury. 3 Such an agreement raises awareness and introduces safer alternatives to mercury-containing products. 2

Elemental mercury

8 What You Should Know About PCBs:

PCBs were first manufactured commercially in the late 1920s, and it wasn’t long before workers at the Monsanto Chemical Com- pany developed chloracne, a painful and dis- figuring skin condition that consists of pus- tules on the face and body. They also com- plained of loss of energy and appetite. When several workers died from PCB exposure in the 1930s, they were found to have severe liver damage. 8 Parts of the Hudson River in New York are designated superfund sites by the US EPA because the GE Corpo- ration discharged 1.1 million pounds of PCBs into the water during a 30-year period that ended in 1977, and these chemicals have accumulated in the riverbed sediments. PCB discharge into rivers and bays was halted in the 1970s with the enact- ment of the Clean Water Act. Despite early evidence that PCBs were very harmful chemicals, they continued to be produced and used until Congress passed the Toxic Substances Control Act in 1976, which made illegal the manufacture, sale, and distribution of PCBs within three years in the U.S. 8 Since then, PCBs have been classified as probable carcinogens, and they also have been shown to damage the nervous system development in mammalian fetuses, leading to behavioral and learning defects. These chemicals often mimic hormones and are documented disruptors of the human endocrine system. 8

PCBs: Man-made Chemicals with Hidden Hazards:

The acronym PCBs stands for a group of chemical compounds called polychlorinated biphenyls, which consist of chlorine atoms attached to a carbon ring. These organic chemicals have a strong chemical structure, so PCBs break down very slowly. 9 PCBs can exist as 209 possible chemical compounds. Most PCB mixtures are Chemical Structure: General structure C12H10-nCln where n = 1 to 10 usually light colored liquids that feel like thick, oily molasses. The more heavily chlorinated types can appear as yellow or black resins. Other chemicals are often mixed in with PCBs. 9 They are resistant to breakdown, non-corrosive, and non-flammable. 9 Before their dangers became com-

9 mon knowledge, PCBs were widely used in electrical equipment, and can still be found in some contained systems, including transformers, generators, hydraulic equipment, and capacitors. 9, 10 Today, PCB-containing equipment, such as transformers, must be regularly inspected to be sure they are not releasing PCBs. 9 Other products that may contain PCBs include old fluorescent lighting fixtures, old microscopes, hydraulic oils, plasticizers in paints, plastics and rubber products, and carbonless copy papers. People who might be exposed to PCBs include those servicing some types of electrical equipment, maintenance workers who clean up spills or leaks of PCB fluids, employees of scrap metal or salvage companies, and waste collection workers. 24

PCBs in the Food Chain:

PCBs have been and can be released into the environment from many sources: • during their use and disposal; • during accidental spills and leaks while being transported; • during leaks or fires in equipment that contains PCBs. • from hazardous waste sites; • illegal or improper disposal of industrial wastes and consumer products; • leaks from old electrical transformers; • from burning of some wastes in incinerators.

Even though PCBs have not been around for long, they have spread to every part of the world; they are a particular problem in the Polar Regions where people and animals have diets that are likely to have high concentrations of PCBs. 8 Just like mercury, PCBs have the ability to bioaccumulate and biomagnify in the food chain (Table 2). These chemicals take many years to biodegrade and are easily absorbed into fat tissue, so that animals at the top of the food chain, such as eagles, polar bears, and humans, can have PCBs in their tissues at highly concentrated levels. 8 In 2003, thirty-nine states issued PCB-related fish consumption advisories, including the Lake Superior basin in Wisconsin. 6 Unlike mercury, PCBs

TABLE 2. BIOACCUMULATION AND BIOMAGNIFICATION

BIOACCUMULATION BIOMAGNIFICATION

The accumulation over time of chemi- The progressive buildup of chemicals by cals within an organism from eating successive levels in the food chain (i.e., other contaminated organisms, and the amount of mercury or PCBs in the tis- from uptake through the soil, water, sue of the predator organism is greater and air. than that in its prey because the predator eats many prey organisms).

10 tend to accumulate in fatty tissue, so one can reduce the risk of PCB exposure by cutting away the fat on any fish that is caught and eaten.

Efforts to Reduce PCBs in the Environment:

More than 1.5 billion pounds of PCBs were manufactured in the United States prior to cessation of production in 1978. In 1976, Congress passed the Toxic Substances Control Act (TSCA), which outlawed the manufacture, sale, and importation of PCBs. 10,11 TSCA helped phase out many uses of this chemical, but allowed PCBs to remain in existing equipment as long as the PCBs were “totally enclosed.” To- tally enclosed systems “ensure that any exposure to human beings or the environment to a PCB will be insignificant as determined by the EPA Administrator.” 11 This means that PCBs continue to be used in old transformers, electromagnets, voltage regulators, switches, circuit breakers, and capacitors. 8-11 Once a transformer or other equipment starts to leak and there is a detectable escape of PCBs to the environment, the EPA regulates the decontamination and disposal of the equipment.

In 2000 the United Nations Environment Program completed international treaty ne- gotiations between 120 nations for a global, legally binding ban on 12 persistent organic pollutants (POPs), which included PCBs. POPs are toxic substances that remain in the environment, causing problems with ecosystem health. 8 In 2001 this treaty was ratified and entered into force. The POPs Convention requires, among other actions, the immediate elimination of PCB production, as well as elimination of the use of PCBs in equipment by 2025. Companies all over the world are phasing out equipment that contains PCBs and making sure that PCB waste is properly treated, stored, and destroyed through high-temperature incineration (greater than 1,200 C for two seconds dwell time). 10, 12 Incineration is the best way to destroy any remaining PCBs so they do not disperse into the environment. When properly done, incineration destroys 99.99% of PCBs, leaving behind an inorganic ash. Smoke stack scrubbers are used to remove the hydrogen chloride gas and other compounds that can be formed as by-products of combustion. 24 The U.S. has a phase- out system where PCBs are being replaced as quickly as possible by less harmful substances, such as transformer-grade mineral oil and silicon fluids. These alternatives may increase the risk of fire and make electrical equipment less energy- efficient, but these costs do not outweigh the health and safety benefits gained from reducing PCBs in the environment. 12

11 Collaborating to Devise a Treatment Plan for a Healthy Lake Superior

The United States and Canadian federal governments, along with Minnesota, Michigan, Wisconsin, and Ontario, developed a non-binding treaty called A Binational Program to Re- store and Protect the Lake Superior Basin (hereafter Binational Program) as recommended by the International Joint Commission. 14 The Binational Program’s purpose is to protect the high-quality waters of the Lake Superior Basin. One objective is to achieve zero discharge of the designated persistent and bioaccumulative toxic substances from point sources in the basin by halting inputs from all human sources and pathways. 14 Not all persistent toxic substances can be completely removed from the environment because several can be produced by natural processes. Virtual elimination, whereby contaminants are removed from the environment to the greatest extent possible, is a more realistic objective than zero discharge. Therefore, the ultimate goal of the Binational Program is virtual elimination of nine POPs in the Great Lakes Basin: aldrin, chlordane, DDT, dieldrin, endrin, heptachlor, hexa- chlorobenzene, PCBs, and toxaphene.

To achieve virtual elimination, everyone must help, including refineries and their partners. A voluntary internal inventory of all sources of mercury and PCBs in a refinery can demonstrate that the company is properly managing all potential sources of pollution. 15 This sort of inventory can be done with the industry’s own resources, or, as in the case of Murphy Oil, a voluntary partnership can be formed between industry and governmental agencies or other groups to help promote pollution prevention activities.

The remainder of this guidebook provides information to oil refineries and other industries needing assistance to: 1) enter into voluntary pollution prevention agreements with outside groups, and 2) conduct on-site inventories and reduction activities for mercury and PCBs.

12 Take Your Medicine: A Voluntary Approach to Fix the Pollution Problem

In 2001, Murphy Oil began participating in a voluntary initiative with WDPW to reduce mercury and PCB use at the refinery. A voluntary agreement like this one is an op- tional pollution reduction effort that goes beyond legal requirements for pollution prevention. It is designed to challenge the source to develop their own reduction efforts, use trial and error, and conduct their own innovative research. 13, 15 Instead of a formal, complicated contract for pollution reduction, a voluntary agreement can be simple and flexible. 13 Such agreements have led to the collection and management of hundreds of pounds of mercury in switches and other products found at industrial sites. Voluntary partnerships are seen as “bridge” efforts that cover the period between the present and when new, stricter federal regulatory requirements may be put in place. 15 The US EPA’s Great Lakes National Program Office (GLNPO) provided funding for this guidance manual, which uses the pollution prevention partnership between Murphy Oil and WDPW as a case study. Murphy Oil provided resources and staff hours to help WDPW conduct the mercury and PCB inventories. .

TABLE 3. GOALS AND BENEFITS OF A VOLUNTARY APPROACH GOALS OF A VOLUNTARY BENEFITS TO A VOLUNTARY APPROACH TO REDUCE APPROACH TO REDUCE MERCURY MERCURY AND PCBS: AND PCBS: 1) Identify all possible sources of 1) Creates a cost-effective and time- mercury and PCBs on site. effective pollution reduction initiative. 2) Replace equipment containing 2) Improves refinery’s image in the mercury after its functional life community and among environ- ends with mercury-free alterna- mental regulators. tives. 3) Increases public’s awareness about 3) Adopt a mercury-free purchasing the dangers of mercury and PCBs policy. through publicity about the refinery’s 4) Maintain a recycling policy to re- program. cycle mercury-containing fluo- 4) Decreases chance of mandatory re- rescent bulbs and other Univer- ductions required by regulators. sal Wastes. 5) Minimizes mercury spills, clean-up costs, and worker exposure. 6) Raises employee awareness of pollution prevention efforts that both protect the environment and improve worker safety.

13 How to Write Your Own Prescription for Mercury and PCB Elimination

When doctors prescribe a medication to a patient, they make sure the prescription will work for the ailment they are trying to treat, and they also give the patient a schedule for complet- ing the course of drugs. The same can be said for a refinery when it puts together a plan for reducing mercury and PCBs.

Once the Diagnosis is Clear, Devise a Treatment Plan

To receive approval from managers at your refinery, your oil refinery will need a clear plan for reducing mercury and PCBs on site. Who will conduct the inventory? Who would be a good partner in the pollution prevention effort? Who will dispose of the mercury and PCBs that are found? How will this effort be funded? What sort of timeline should be considered? Most importantly, what are the reduction goals for your refinery, the planned actions to reach the goals, and the ways in which the results will be reported? These questions need to be answered in an organized way before any action can be taken. This manual shows how Murphy Oil conducted its mercury and PCB reduction plan, and it can be used as a guide for your refinery.

Consult Resources

When a doctor is confronted with a difficult case, he or she may consult the medical litera- ture or talk to colleagues. Likewise, managers at an oil refinery can learn from the experiences of other industries that have implemented similar plans, rather than starting from scratch 16. Employees at your refinery should ask, “Has anyone else tried to reduce mercury and PCBs? How might their experiences help us gain insight?” Check Appendix 1 at the back of this guidebook for other helpful resources.

Form a Partnership

Don’t wait for outside agencies to come to you – if your refinery needs help with pollution prevention, contact groups in your area that have experience with reducing mercury and PCBs in the community. An outside group may have the resources a refinery needs to get a pollution prevention program off the ground. However, employees at the refinery shouldn’t expect the outside group or agency to do all the work. Your partnership could be modeled on the one between Murphy Oil and WDPW, where Murphy Oil provided WDPW access to their facilities, training, information, and documentation, and WDPW helped Murphy Oil conduct a thorough inventory and put together policies for mercury and PCB management, mercury spills, and mercury-free purchasing. Make sure to develop an agreement that is feasi-

14 ble for both groups. For instance Murphy Oil reserved the right to preview the guidance document, as well as any web pages and press releases.

Get Support

If your oil refinery is going to partner with another agency such as the local wastewater treatment plant, pollution control, environmental protection agency, or Depart- ment of Natural Resources (DNR), make sure the key people in all participating organizations are in favor of such a partnership. Administrators at the treatment plant, agency directors, refinery managers, and refinery environmental health and safety officers may need to be educated as to the nature of the pollution problem and how the partnership will reduce pollution problems for both groups. 16 People at the top should be sure to communicate the goals of the plan to their employees and solicit input.

Try a Case Study

Doctors prescribe medications that have been tested in study groups to identify side effects. Perhaps a facility-wide approach to mercury/PCB reduction may be too daunting or costly at first. In that case try a pilot project, where pollution reduction may be done one department or building at a time. From there, the les- sons learned, the pitfalls, and the successes from the pilot project can be ex- panded to include the entire facility. Murphy Oil, Superior Find the Money to Pay for the Prescription

WDPW received a grant from GLNPO to produce a guidebook on how oil refineries can use voluntary partnerships to reduce mercury and PCBs, and WDPW staff were paid by the GLNPO grant to become familiar with operations and policies at Murphy Oil. However, much of the pollution inventory and reduction work itself was funded by Murphy Oil; they were willing to make their facilities, employees, chemical inventories, and data sheets accessible WDPW staff. An oil refinery interested in taking on a similar voluntary pollution prevention initiative with an outside agency must be willing to fund all or part of the inventory and other pollution reduction activities. Fi-

15 nancial assistance may include technical support, paying for refinery employees while they are involved in inventories and pollution reduction, providing disposal options for mercury and PCBs, and promoting environmental stewardship. Grant funding can help partners like the local wastewater treatment plant, the DNR, or the Pollution Control Agency deliver assistance to the refinery. However, grant funds are not necessary for such a partnership to go forward if the refinery or agency already has money they can use to conduct pollution prevention activities.

Find Someone to Administer the Treatment

Once a mercury/PCB inventory and reduction plan has been approved and funding has been supplied, the processes and goals of the plan should be communicated to employees who will be involved in any part of the plan. 16,19 Set up a mercury/PCB inventory and reduction team (hereafter called “the team”) to collect, interpret, and communicate findings. This team should be able to get into the refinery during normal operation hours so they gain access to the information and facilities needed to conduct their inventory and pollution prevention activities. 17,20

The team at Murphy Oil consisted of the Environmental Department staff, Lab, Warehouse, and Facilities Maintenance personnel from Murphy Oil; and the Safety and Pretreatment Co- ordinator and two Research Assistants from WDPW. The team met to discuss the project and set up a schedule for the inventory and writing the phase-out and purchasing plans; they also were in weekly contact by e-mail, visits, or phone calls during the inventory process. Murphy Oil allowed WDPW staff to take pictures of mercury-containing devices and gave them access to any documents that might relate to their mercury- or PCB-reduction activities. WDPW staff were also supplied with a monthly inventory of chemical stock found on Murphy Oil’s premises. Without such an open policy and communication between WDPW and Murphy Oil, such a comprehensive and successful inventory would not have been possible.

Ensure that the People Administering the Treatment Know What They’re Doing!

We have all heard of physicians or pharmacists giving patients the wrong medication, either through negligence or lack of knowledge. Your pollution prevention team should have enough information about the refinery to be able to identify and remove sources of mercury and PCBs on site. Otherwise the inventory and reduction effort may not be complete enough to create any real cure to the pollution problem at the plant. 17

Before the inventory began, WDPW team members took safety training courses and reviewed publications on oil refining, hazardous waste management, and safety regulations at

16 the plant (Appendix1). Murphy Oil staff gave tours to WDPW staff to familiarize them with the refinery’s facilities, operations, and security guidelines and safety issues.

Was the Treatment a Success? Make Sure Everyone Knows!

Many cancer survivors know that even if their chemotherapy works and they are cancer-free, they are not officially cured even 5 to 10 years later — the disease can re- turn. The same can be said of any pollution prevention program. To make sure the treatment continues to be a success, a new inventory should be conducted whenever changes occur, such as when regulations or pollution disposal costs change; when a new product is implemented in the refinery; when the price of raw materials such as mercury changes; or when a new process is put into use. 17,20 The pollution reduction program should be reviewed during and after the process to insure the project stays in focus. To determine if the treatment was a success, the team will need to ask if the pollution prevention project has met requirements and projected outcomes, and they should discuss what worked well and what did not.

Documentation of the mercury/PCB inventory should include a description of processes and equipment associated with mercury/PCB waste, an inventory of mercury/ PCB sources, and a management plan for any mercury- or PCB-containing materials that will minimize or eliminate mercury/PCB discharge. This gives the refinery the opportunity to show others how it is managing materials and processes to prevent the release of mercury and PCBs. 17

Now is the time to let your community know how you’ve worked to reduce pollution, and that you’ve done it voluntarily! A final report that gives the amount of mercury and PCBs removed from a refinery can be given to agencies such as the DNR and the US EPA to show how the refinery has followed simple guidelines to reduce mercury and PCBs. An easy-to-read handbook or advertisement could be disseminated to educate the public about these pollutants and show the strides their local refinery has made to reduce their emissions of mercury and PCBs to the global pool.

Preventive Measures Always Help

As doctors like to say, an ounce of prevention is worth a pound of cure, which for a refinery could be translated to a dollar of prevention is worth a thousand dollars of cure. Three to seven years before this voluntary partnership, Murphy Oil had begun a slow phase-out of mercury switches and hadn’t ordered a mercury switch in as many years. This preventive measure certainly helped cut the cost of the formal in-

17 ventory and mercury reduction plan, and it prevented a larger amount of mercury from having the potential to escape into the environment. Most mercury switches had been eliminated before the inventory began, but unfortunately they did not have clear documentation of this effort. Having records of such actions makes it easier to report successes. Murphy Oil now has an up-to-date mercury inventory on file, and they can show definitively how it will work to reduce the mercury remaining on site. They also have very good documentation of their PCB-removal activities, though this documentation was difficult to organize. Oil refineries and other industries should keep organized documentation of their pollution prevention activities so they can easily access this information when they want to share it with outside agencies and their community. In the 1980s, Murphy Oil worked to remove PCBs from their transformers, so by the time the partnership was formed with WDPW, no PCB-reduction measures were needed. By removing PCBs earlier rather than later, Murphy Oil prevented a larger amount of PCBs from having the potential to escape into the environment. Not only did this earlier PCB-removal cut the cost of the pollution prevention actions during this partnership, it also showed WDPW and the community that Murphy Oil is committed to pollution reduction.

A Remedy for Mercury Use at Murphy Oil

By following the mercury management guidelines listed on the previous pages, the team was able to conduct a successful mercury inventory at Murphy Oil and target remaining sources of mercury that could be removed to prevent its potential release into the environment (Table 4, Appendices 2-9). The guidelines on the following pages are based on the team’s experiences at Murphy Oil.

Are There Any Prescriptions Already in Place?

If a medication is already working to treat a patient’s malady, it wouldn’t make sense for a doctor to prescribe another, different medication to treat the same ailment — but this could happen if the doctor didn’t check the patient’s medical history to see what prescriptions a patient already has. In the same way, an oil refinery should determine what kinds of mercury/ PCB reduction measures are already in place before embarking on a reduction project.

To promote proper collection and recycling of widely used materials that contain mercury, the US EPA developed the Universal Waste Rule, which relaxes requirements for handling, storage times, and transportation of certain mercury-containing wastes under the Resource and Conservation and Recovery Act. 13,21 Universal wastes are commonly generated, low risk hazardous wastes, including batteries, certain pesticides, mercury thermostats, and mercury- containing fluorescent bulbs. 21 Industries would normally treat these items as hazardous waste and would be required to follow the proper disposal guidelines set down by law. By

18 putting mercury-containing products in the Universal Waste category, it changes the regulations that apply. The Universal Waste Rule separates these “universal” wastes from the municipal waste stream and ensures proper waste management. It also helps protect the environment by keeping mercury out of municipal landfills and incinerators. It is important to remember, however, that contaminated materials including mercury and cleanup residues from broken thermostats, fluorescent bulbs, or thermometers must be managed as hazardous, not universal, waste. 21

First, determine whether your refinery is a Large-Quantity Handler of Universal Waste (LQHUW) or a Small-Quantity Handler of Universal Waste (SQHUW) (Table 5). Murphy Oil is a SQHUW and has a special universal waste collection area within their plant. Universal wastes can be stored on site for a maximum of one year without a permit; this year time period is measured from the date the material is removed from service. The container holding the universal waste must be marked with the earliest date that any universal waste is put into it and must then be disposed of all at one time. Conversely, each universal waste item can be labeled and disposed of individually as the expiration date arises. The next few pages outline the specific Universal Waste guidelines for fluorescent bulbs, thermostats, and batteries.

TABLE 5. CATEGORIES FOR WASTE HANDLERS LARGE-QUANTITY HANDLER OF SMALL-QUANTITY HANDLER OF UNIVERSAL WASTE UNIVERSAL WASTE

1) Facilities that accumulate 5,000 1) Facilities that accumulate less kg (11,000 pounds) or more of than 5,000 kg (11,000 pounds) of waste at any one time. waste at any one time. 2) A LQHUW is required to notify 2) A SQHUW is not required to no- the EPA regarding universal tify the EPA regarding any univer- waste activities, and must pre- sal waste activities. vent release of any universal waste to the environment.

19 Fluorescent Bulbs

The EPA issued a final rule in July 1999 to add mercury-containing lamps to the Universal Waste Rule, which allows for expedited collection and handling of this type of waste. Why use fluorescent bulbs if they contain mercury? They are more energy-efficient than incandescent bulbs that do not contain mercury. Power plants that burn fossil fuels release mercury and other environmental pollutants, and these releases are greater when incandescent bulbs are used. 2 There are low-mercury alternatives to regular fluorescent bulbs, including low-mercury content lamps and high intensity discharge (HID) lamps. In addition, fluorescent bulbs can be recycled, keeping the mercury out of the waste stream. 21

1) Containment: Bulbs that contain mercury are collected by the electrical department at Murphy Oil and stored in properly labeled cardboard boxes in a designated storage area. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. The bulbs must not be crushed. If a lamp is accidentally broken, store all the debris in a sealed and labeled plastic container and request pick-up by the hazardous waste management coordinator. 21

2) Labeling: The boxes of bulbs must be labeled with, “Universal Waste -- Lamps” or “Waste Lamps.”

3) Recycling: At a fluorescent lamp recycling center, lamps are crushed to extract the white phosphor powder where most of the mercury is contained. The extracted mercury is then used to make new fluorescent lamps. All parts of the lamp can be recycled.

Thermostats

Thermostats can contain as much as 3 grams of liquid mercury and are present in nearly every building at the refinery. Used mercury-containing thermostats must be collected and placed in the appropriately labeled container in the Universal Waste Collection Area. Mer- cury-containing thermostats should be replaced with mercury-free thermostats whenever possible.

1) Containment: All Universal Waste handlers must contain any universal waste thermostat that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the thermostat, and must lack evidence of leakage, spillage, or damage that could cause leakage under rea-

20 sonably foreseeable conditions .21

2) Labeling: Each universal waste thermostat, or the container in which the thermostats are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste -- Mer- cury Thermostat(s)," or "Waste Mercury Thermostat(s)," or "Used Mercury Thermostat(s)".

3) Recycling: Bring the used thermostat to a recycling facility.

Batteries The following batteries are listed under the Universal Waste Rule: used recharge- able batteries, and lead-acid batteries. Inside a battery, heavy metals react with chemical electrolyte to produce the battery's power. Because these batteries contain heavy metals, they can contaminate the environment when they are improperly disposed of. When incinerated, certain metals can be released into the air or can be concentrated in the ash produced by the combustion process. 22 Recycling batteries keeps heavy metals out of landfills and the air. 22

1) Containment: All universal waste handlers must contain any universal waste battery that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. Pallets of batteries should be kept upright and must not be stacked.

2) Labeling: Universal waste batteries, or the container in which the batteries are contained, must be labeled clearly with any one of the following phrases: "Universal Waste Battery(ies), or "Waste Battery(ies)," or "Used Battery(ies);"

3) Recycling: Bring the used batteries to a recycling facility. When lead-acid batteries are replaced they should be turned in to the vendor from whom the replacement battery was purchased.

21 Tracking Down the Source of the Disease

Even if a doctor knows the flu is caused by a virus, they still need to find the source of the disease. An incomplete list of mercury switches was given to WDPW staff before the official inventory began. WDPW staff and employees from Murphy Oil (the team) generated an up- to-date list by conducting a thorough inventory for mercury-containing items. The inventory began in the chemical laboratory and proceeded to the warehouse, storage area, operations and electrical units, tank fields, and the refinery's wastewater treatment plant. Murphy Oil’s employees helped a WDPW employee find the mercury-containing switches on process and other equipment. Every time the team found a mercury-containing item, they recorded the location, manufacturer, serial number, and amount of mercury on an inventory sheet (Appendix 5). Mercoid and Honeywell switches continue to be used on some tanks, but most have been slowly phased out and replaced with mercury-free switches (mostly Barksdale brand). The mercury-containing items were either replaced with mercury-free alternatives or labeled so they will be recycled when they become obsolete.

Once the inventory was complete, WDPW staff wrote up a mercury management policy to facilitate the use and disposal of devices on site. They also worked with Murphy Oil to com- pile a mercury-free purchasing policy. A mercury spill policy was instituted to insure appro- priate handling and disposal of any broken equipment; this policy fits well in the on-site spill section of Murphy Oil’s existing hazardous waste policy. All of these policies had to be approved by managers at Murphy Oil before they were incorporated into their operating procedures.

How Serious is the Disease?

Sometimes a person may be ill without even knowing it, especially if they don’t have any symptoms. It’s the same way for any equipment or chemical that contains mercury – people may not even know it is present. If the concentration of mercury in a chemical is less than 1% of the whole, most Material Safety Data Sheets (MSDS) do not include information about the mercury content. It is common for manufacturers to change ownership and contact information frequently, making it difficult to get in touch with the chemical suppliers using the information supplied on the MSDS. When it is time to inquire about the mercury content in a particular chemical, check the Internet for updated contact information for each manufacturer. Write to the company and request a Certificate of Analysis (see Appendix 4 for sample letter and Certificates of Analysis). Replies from chemical vendors should include the exact amount of mercury in each product. Vendors should also include their method of testing; Cold Vapor Atomic Absorption is most frequently used to analyze mercury content. Once the concentration of mercury in the product has been determined, the environmental department at your oil refinery should decide whether this level of mercury is

22 TABLE 4. STEPS TAKEN TO INVENTORY AND REDUCE MERCURY AT MURPHY OIL

1) Researched general information about mercury and oil refineries (Appendix 1). Learned about everyday procedures and mercury management practices at Murphy.

2) Conducted an inventory of all products and processes that contained or used mercury within the plant. Searched various resources and locations in the refinery with the help of Murphy Oil staff (Appendix 2).

3) Identified chemicals in use at the refinery that contained mercury (Appendix 3). In some cases the supplier of the chemical had to be contacted to request a Certificate of Analysis detailing the concentration of mercury in their product (see Appendix 4 for copy of sample letter and Certificates of Analy- sis).

4) Identified mercury-containing devices or process; logged them onto a data sheet (see Appendix 5 for copies of inventory sheet).

5) Labeled mercury-containing equipment that remain in use. Labels notify employees to properly recycle end-of-life equipment.

6) Brought elemental mercury found on site to a recycling facility in Spooner, WI.

7) Identified cost-effective alternatives to many of the mercury-containing products and processes at the refinery (Appendix 6).

8) Developed a mercury management policy (Appendix 7) and a mercury-free purchasing policy (Appendix 8).

9) Developed a standardized mercury spill policy as part of the safety procedures at the plant (Appendix 9).

acceptable; if not, a new supplier with lower mercury levels in its products should be chosen. Several factors should be considered when determining an acceptable mercury concentration in products for purchase: 1) what is the chance of that prod-

23 uct entering the wastewater stream, and 2) what volume of the product is being used in processes that might enter the wastewater stream? Because this process is complicated, Murphy Oil is still determining mercury limits for purchase on a case-by-case basis.

Keeping the Laboratory Disease-Free

Common practices for preventing the spread of disease include washing our hands, cover- ing our faces when we sneeze, and trying to eliminate disease-causing agents by keeping our water clean. Whenever mercury-containing chemicals are used in laboratories, releases of mercury into wastewater are possible. The EPA pretreatment limit for mercury in drinking water is approximately 2 ug/L (equivalent to 2000 ppt), while the new limit for mercury in wastewater for Wisconsin is 1.3 ppt. 19 Release of mercury from laboratory processes should not exceed regulated levels 19. What- ever cannot be saved for recovery or recycling should be handled as hazardous waste and sent to a Resource and Conservation and Recovery Act (RCRA) approved waste facility.

Mercuric Nitrate Mercuric nitrate is commonly used in Murphy Oil’s lab to test the chloride concentration in the overhead water. This test, called the Mer- curic Nitrate Method (Standard Number 4500 Cl-C), involves titrating chloride with mercuric nitrate, which results in the formation of mercuric chloride. 18 Mercuric chloride is soluble in water, so it is present in the wastewater ef- fluent. The chemists at Murphy Oil use 20-30 mL of mercuric nitrate solution on a daily basis to monitor chlorides in overhead water. Lab staff are unable to eliminate all mercury- containing instruments because they must be used for calibration purposes, and some methods require specific instrumentation.

Caustic Soda Murphy Oil uses caustic soda (sodium hydroxide) for water conditioning in boilers, among other uses. Some caustic soda is produced by the mercury-cell process through electrolysis of salt brine because it produces high-quality, low-salt caustic soda. 13 Other methods of producing caustic soda can generate trace amounts of mercury. After the inventory, WDPW staff requested a Certificate of Analysis from OxyChem, the caustic soda supplier for Mur- phy Oil (Appendix 4). OxyChem’s specification for trace mercury in caustic soda is less than 100 ppb; the mercury level in their caustic soda was less than 0.5 ppb. This makes it clear their product was not produced by the mercury-cell process, which would likely lead to a de-

24 tection of a higher amount of mercury. Though this level is small, Murphy Oil could consider asking for a more sensitive test if they use a large amount of caustic soda in their daily operations. However, when large amounts of caustic soda with a low or undetectable amount of mercury are used, the mass of mercury reaching the wastewater treatment facility from a refinery has the potential to be relatively large. 20 Re- fineries should take this into consideration when they decide which chemicals to purchase.

Goals for reducing mercury in the laboratory:

1) Eliminate the use of mercury-containing compounds unless there is no compa- rable alternative.

2) Eliminate all non-essential mercury devices, such as thermometers, barometers, hydrometers, etc., and replace with non-mercury containing alternatives.

3) Clear laboratory and storage areas of obsolete or unnecessary mercury compounds.

4) Remove the dissolved mercury in wastewater, such as mercuric chloride, using a sorption process or separating the mercury from the rest of the sample waste by precipitating the metal and filtering it out.

5) Use other methods for testing water at your facility. Alternatives for the Mercu- ric Nitrate Method include: • Argentometric Method • Potentiometic Method • Ion Chromatography Method (ion-specific electrodes)

6) Develop policies that focus on purchasing chemicals that contain little or no mercury. For instance, caustic soda is also produced by the porous- diaphragm process and the ion exchange membrane process, both of which do not involve mercury.

7) Recycle recovered mercury: • Many mercury recycling companies across the country will deliver empty 5-gallon drums and pick up full drums for a nominal fee.

25 What to do if the Disease Spreads

Employees at an oil refinery are at risk if they don’t know what to do in the event of a mercury spill. There was no mercury spill policy in the lab when the team came to investigate, but lab personnel said that if there is a spill they use plastic pipettes and a Scienceware Mercury Collector from Bel-Art Products (Cat No. 36250-0000) to pick it up. The mercury is then stored in Murphy Oil’s 90-day Haz- ardous Waste Storage. If a mercury-containing device breaks, they put it in a container with a lid in the satellite storage area for later placement in the 90-day Hazardous Waste Storage. WDPW put together a more comprehensive spill policy, which Murphy Oil adopted (Appendix 9).

Educating employees about careful use and disposal of mercury-containing products is one of the most important ways to remove and keep mercury out of daily operations at a refinery. For instance, one of the employees at Murphy wasn’t aware there was mercury equipment on the shelves, indicating the need to heighten knowledge of what equipment and processes within the refinery do contain mercury. Once the employees know what to look for, they are more likely to document, report, and dispose of mercury-containing equipment properly. Murphy Oil is in the process of implementing their mercury spill policy, which will include a training session on the health effects of mercury and how to use the proper spill clean up procedures.

Prevent the Disease at its Source

Developing a mercury-free purchasing policy is a major step toward keeping mercury out of an oil refinery. It’s the same as telling a smoker that they have to stop buying cigarettes if they want to reduce their chances of getting cancer. Rather than trying to deal with mercury at a refinery when it becomes a problem, it is much easier to prevent the mercury from being there in the first place. Such preventive measures will help avoid future mercury spills and associated costs, prevent environmental hazards caused by mercury, and increase the positive public image of the refinery in the community.

Manufacturers and suppliers of mercury-containing equipment are often unable to give information on the precise amount of mercury present in their products, making it difficult to decide whether to purchase a certain product or not. As more industries develop mercury-free purchasing policies, manufacturers and suppliers will have to provide more accurate mercury content information. 13 When cost-effective alternatives do not exist and the use of mercury cannot be avoided, it’s important to develop sound policies for safe use of the products and for proper recycling when the equipment becomes obsolete. Recycling will minimize primary production of mercury.

Another helpful way to keep mercury out of the wastewater stream is to label mercury-containing equipment still in use. The label should specify that an item contains mercury and that it must be properly recycled when it becomes obsolete, and it should include the contact information for the recycler. All employees should make sure all mercury-containing items are labeled and recycled properly.

Examples of mercury-containing switches

Examples of mercury-free switches

27 Results of the Mercury Inventory at Murphy Oil

Although Murphy Oil has removed a lot of their mercury-containing equipment, much of it remains in service, and all of it has been inventoried (Table 5). As long as it is safely used, there is little chance the equipment will break and release mercury. The equipment has been labeled so it will be disposed of properly when it becomes obsolete.

TABLE 5. RESULTS OF THE MERCURY INVENTORY AT MURPHY OIL REFINERY

FACILITY ITEM DEVICES COMMENTS DATE REMOVED Laboratory: 250 g. bottle of Hg Used to fill up the barometer or McLeod Chemical stor- gauge in the knock room or for laboratory age room vacuum distillations Laboratory: 2 mercury switches Furnace Room on a Chromalox Electric Boiler Laboratory: Barometer with Eberbach, Ann Arbor, MI. Knock engine ~500 g. of Hg room Laboratory: McLeod gauge ~ Meriam Instrument Company, Type W, Knock engine 600 g. of Hg Model A-32A, Serial # H33341 Laboratory: Thermo regulator ~ Model #62510 Precision Scientific Co. N 16376 Testing Room 200 g. of Hg (broken, in satellite storage) and Model #62541 (with collar ad- juster) Laboratory: 75 broken or end-of- Three sizes (15, In lab and outside in waste barrel. Non- Testing Room life thermometers 25, 43 cm) mercury thermometers also on site Laboratory: 100 hydrometers Hydrometers Non-mercury thermometers also present Testing Room contain small Hg in some hydrometers thermometers Laboratory: Mercuric Nitrate Purchased in 10-12 L bulk every 3-4 Testing Room months from Bel-Art catalog # 37251. 20-30 ml used daily to monitor chloride normality in overhead water. Laboratory: 400 g. Caustic Pot- Possible sources of mercury, if contami- Testing Room ash Anhydrous, 1-2 nated. L. concentrated Sulfuric Acid, 10 L. dilute Sulfuric Acid, Potassium Hydrox- ide, Polyphosphoric Acid, Potassium ferricyanide, Silver Nitrate Chlorine Chlorine, 500 ml. Possible source of mercury. Chlorine cylinders cylinders used as part of cooling towers. Operations/ Mercury-containing Continual phase-out of mercury switches. 1998 Maintenance switches Mercury-free switches come from United Electric Control Company H105-9596 and from Barksdale. Operations/ Tank 104, Air switch 2 Mercoid Maintenance: on Asphalt Heater switches: H23, Tank Field H24 28 TABLE 5 CONTINUED

FACILITY ITEM DEVICES COM- DATE MENTS REMOVED Operations/Maintenance: Tank 100, Air switch on 3 Mercoid switches: H16, Tank Field Asphalt Heater H17, H18 Operations/Maintenance: Tank 90, Air switch on 1 Mercoid switch: H09 Tank Field Asphalt Heater Operations/Maintenance: Tank 91, Air switch on 2 Mercoid switches: H12, Tank Field Asphalt Heater H13 Operations/Maintenance: Tank 88, Air switch on 3 Mercoid switches: H106, Tank Field Asphalt Heater H107, H108 Operations/Maintenance: Tank 87, Air switch on 1 Mercoid switch: H105 Tank Field Asphalt Heater Operations/Maintenance: Tank 86, Air switch on 1 Mercoid switch: H103 Tank Field Asphalt Heater Operations/Maintenance: Tank 106, Air switch on 5 Mercoid switches: H28, Tank Field Asphalt Heater H29, H3-, H31, H32 Operations/Maintenance: Tank 112, Air switch on 6 Mercoid switches: H34, Tank Field Asphalt Heater H35, H36, H37, H38, H39 Operations/Maintenance: Tank 105, Air switch on 3 Mercoid switches: H25, Tank Field Asphalt Heater H26, H27 Operations/Maintenance: Tank 104, PSI switch 1 Mercoid switch on gaso- line feeder Operations/Maintenance: Main Air Blower 1 Mercoid switch:15FC1 Fluid Catalytic Cracking Unit Operations/Maintenance: #2 Hydrobon 1 Mercoid switch:15PC2 Compressor Operations/Maintenance: #1 Hydrobon 1 Mercoid switch:15PC1 Compressor Operations/Maintenance: Main Fire Pump 1 Mercoid switch:21P06 For water Tank Field PSI Operations/Maintenance: Diesel Fire Pumps 2 Mercoid switches in red Tank Field North and South cabinets Operations/Maintenance: Sulfur Recovery Unit 1 Honeywell switch North Side of 25V5 Fresh Amine Tank Wastewater Thermal Oxidizer Gas 2 Mercoid switches Treatment Plant PSI Wastewater Heat Recovery Unit #1 1 Mercoid switch Treatment Plant Wastewater Heat Recovery Unit #2 1 Mercoid switch Treatment Plant Wastewater Water PSI, Fire Pump 1 Mercoid switch Treatment Plant Controller Warehouse 1 Mercoid switch Switch Ninety-Day 15 out-of-use switches Stored 1999 Storage prior to being recycled

29 A Remedy for PCB Use at Murphy Oil

A PCB inventory in 2004 was unnecessary at Mur- phy Oil because they had already taken the initiative to remove all PCB-containing fluid from their transformers in the 1990s. Because PCBs are more heavily regulated than mercury, the location and amount of PCBs that had been on site was well documented, as was the date and amount of PCB removal and incineration. When the PCBs were removed they were sent to waste incinerators, including Aptus Inc. in Coffeyville, Kansas. When the PCB fluid was incinerated, Murphy Oil received a Certificate of Destruction from the incin- erator. Murphy Oil also put up labels on each transformer, showing that it was classified as “non- PCB.” A transformer is legally considered to be free of PCBs if the PCB content of the dielectric fluid is less than 50 ppm. 23

Even though PCBs are legally allowed to remain in “totally enclosed” systems such as transformers, Murphy Oil was willing to share information to prove that they had voluntarily removed PCBs from their transformers and used the correct legal procedures to destroy their PCBs. Oil refineries and other industries should keep detailed, organized records about their PCB-removal activities so they can show regulators and citizens the progress they are making towards pollution reduction.

A PCB Checkup

Between 1987 and 1994, Murphy removed all of their PCB capacitors and PCB transformers from service; they sent the PCB fluid contained in this equipment to a facility where it was destroyed (Table 6). An inventory conducted in 1998 showed that some PCBs are still present in transformer oil, but all are well below the 50 ppm mark. In total, 9,658.3 kg of fluid PCBs were removed from Murphy Oil and destroyed. Though all PCB transformers have been removed from service, pole-top transformers containing PCBs may remain on site. If the pole-top transformers fail, the soil surrounding the area must be tested to determine if PCB levels remain below EPA-defined criteria or other prescribed levels. Any PCB waste must be disposed of properly.

TABLE 6. DOCUMENTATION OF PCB-REMOVAL ACTIVITIES AT MURPHY OIL REFINERY YEAR ACTION TAKEN CAPACITORS IN PCB TRANSFORM- PCB TRANS- WEIGHT (KG) PCB SERVICE ERS IN SERVICE FORMERS RE- FLUID REMAINING IN MOVED FROM SERVICE SERVICE 1983 Westinghouse proposes removal of inerteen filled transformer 1983 Annual Inventory 35 large capacitors 6 PCB transformers 9658.3 remaining in service remaining in service

1984 Annual Inventory 35 large capacitors 6 PCB transformers 9658.3 remaining in service remaining in service

1985 Annual Inventory 35 large capacitors 6 PCB transformers 9658.3 remaining in service remaining in service

1986 Annual Inventory 35 large capacitors 6 PCB transformers 9658.3 remaining in service remaining in service

1987 Annual Inventory 35 large capacitors 6 PCB transformers 2 removed from 9658.3 remaining in service remaining in service service

1988 Annual Inventory 35 large capacitors 4 PCB transformers 6079.3 removed remaining in service 1989 Annual Inventory 4 PCB transformers 6079.3 remaining in service 1990 Annual Inventory 4 PCB transformers 1 removed from 6079.3 remaining in service service

1991 Annual Inventory 3 PCB transformers 2 removed from 5136.9 remaining in service service 1994 Aptus receives PCB waste from Murphy, will send Certificate of Disposal

1994 Certificate of Disposal re- PCBs destroyed ceived to prove proper disposal of PCBs 1994 Annual Inventory 1 PCB transformer 1519.9 remaining in service

1994 Last PCB transformer removed from service

1995 Annual Report for total 0 kg PCBs in trans- weight of PCBs at Murphy formers and storage

1998 Cutler-Hammer Engineer- 9658.3 kg PCBs ing reports PCBs still pre- removed in total. sent in transformer oil, but all are below 50 ppm.

31 The Healing Process

Transformers with a PCB content between 50 ppm and 500 ppm, are considered PCB- contaminated. 23 Transformers with PCB concentrations over 500 ppm are simply called PCB transformers. See Appendices 10 and 11 for information on how to identify PCB- containing transformers and how to determine their PCB concentration. During PCB removal, PCB transformers must be drained and flushed, and the casing and coils of the transformer must be disposed of in an EPA-approved Secure Chemical Management Facil- ity. A PCB-contaminated transformer must also be drained and flushed, but it can be refilled with a non-PCB fluid. Three months of operation after the initial refilling, the fluid must be tested for PCB content. 23

Fluids containing between 50 ppm and 500 ppm PCBs must be disposed of in an incinera- tor, a Secure Chemical Management Facility after solidification, or a high-efficiency boiler. PCB fluid with a concentration greater than 500 ppm PCBs must be disposed of in an incin- erator. 23 Both PCB transformers and PCB-contaminated transformers must be drained of all free-flowing liquid and filled with a solvent. PCB transformers must be land-filled, while PCB-contaminated transformers can be scrapped, rebuilt, or sold. 23

Healthy Alternatives

If a transformer is to remain in service at your oil refinery after PCBs have been removed, the next step is selecting a suitable insulating fluid that could be used in place of PCBs (Table 7). 24 This requires a thorough understanding of the importance of the toxicity and potential for environmental problems. Several non-PCB insulating fluids are available commercially that have been accepted on their engineering qualities. The effect these electrical insulating fluids will have on the public and the environment remains to be considered .24

Even if a PCB-free alternative is used in a transformer, PCB concentrations may increase in the dielectric fluid over time as PCBs leach from the transformer core. A successful retrofill program must filter PCBs faster than they leach from the windings and paper products in the core of a transformer and maintain PCB levels below EPA defined criteria or other prescribed levels. 24

TABLE 7. ALTERNATIVES TO PCBS 23

Dielectric Fluid Properties

1. Mineral oil Satisfactory electrical insulating qualities, but it is a flammable liquid and as an aro- matic hydrocarbon it could have potential problems with toxicity and environmental complications.

2. Polydimethylsiloxane or silicone fluid An acceptable insulating fluid; no known harmful effects other than as a flammable liquid. Represents the lowest potential for adverse effects to the public and the environment.

3. Perchloroethylene or tetrachloroethylene Good electrical insulating qualities; low flammability. As a chlorinated hydrocarbon it may bioaccumulate in the environment and is regarded as a toxic substance and suspected carcinogen.

4. Paraffin-based, high molecular weight hydro- Good electrical properties, but it is a flam- carbon oil mable liquid and, like mineral oil, may have some future problems due to trace amounts of polyaromatic hydrocarbons

Smaller transformers can be replaced with dry-type transformers

A Long-Term Plan for Staying Healthy:

When oil refineries take voluntary initiatives to reduce pollution on site, everyone wins. Industries with safety and purchasing policies provide a healthier working environment for everyone, and such efforts can enhance the refinery’s public image. Such voluntary efforts may also mean that oil refineries will not have to face fines as regulations become stricter for pollutants such as mercury and PCBs. The community benefits from these voluntary pollution reduction efforts by having an oil refinery in their area that has reduced pollution in the surrounding air and water. Because mercury and PCBs can both travel through the atmosphere, a voluntary reduction in these pollutants also means that the environment will benefit on a national and global level.

33 Just as health professionals often work together to prevent disease outbreaks from spreading, so do oil refineries need to collaborate with other sectors to prevent the spread of pollution. Mur- phy Oil worked with the City of Superior’s Wastewater Division of Public Works to reduce mercury at the refinery, and Murphy Oil worked on its own to get rid of PCBs on site. To eliminate substances like mercury, it is important that industries, governments, and other stakeholder groups work together to create effective programs that can achieve pollution reduction goals in a financially viable manner. Ultimately, it is up to industries to come up with programs that work for them, and then look for guidance and collaboration in the greater community.

Murphy Oil is one of a few industries participating in voluntary efforts to reduce pollution, but other oil refineries and industries ought to participate. For instance, Northern States Power (now Xcel Energy), limited the amount of mercury allowed in sodium hydroxide to 5 ppb and the amount allowed in sulfuric acid to 100 ppb; they were able to reduce mercury releases to the environment through these efforts (Appendix 1). This document provides the guidance needed to undertake such an effort at other facilities. Voluntary pollution reduction programs like Murphy Oil’s represent the increasing efforts made by many industries, including Ispat Inland, USS Gary Works, and Bethlehem Steel, to demonstrate leadership internationally on the reduction of mercury and PCBs.

34 Appendix 1

Useful Resources for Your Pollution Reduction Team

1. Petroleum Refining for the Nontechnical Person. 2nd ed. William Leffler. PennWell Publishing Co. Tulsa, OK. 3. The Northeast Waste Management Official’s Association Mercury Program. URL: www.newmoa.org/Newmoa/htdocs/prevention/mercury/ Gives information on equipment that might contain mercury and lists mercury- free alternatives. 4. An Investigation of Alternatives to Mercury Containing Products. 2003. Lowell Center for Sustainable Production, University of Massachusetts Lowell. 5. Conducting an Internal Mercury Audit for Manufacturing Facilities. University of Wisconsin Extension Solid and Hazardous Waste Education Center Waste Management Series. Stevens Point, WI. 6. Mercury: Managing, Recycling, Disposing. A Business Guide to Conducting a Mercury Audit. P3ERIE. URL: www.dep.state.pa.us/dep/deputate/pollprev/ p3ERIE/mercbroch.pdf 7. Blueprint for Mercury Elimination, Mercury Reduction Guidance for Wastewa- ter Treatment Plants. 1997. Western Lake Superior Sanitary District, Duluth, MN. 8. Preventing Mercury Pollution: General Guidelines. Audit Your Program and Facility Regularly. 2003. US EPA. URL: www.epa.gov/seahome/mercury/src/audit.htm#conduct 9. A Guide to Mercury Reduction in Industrial and Commercial Settings. A Joint Effort by: Ispat Inland Indiana Harbor Works, Bethlehem Steel Burns Harbor Division, United Steel Gary Works, the Delta Institute, and the Lake Michigan Forum. 2001. URL: www.delta-institute.org/publications/Steel-Hg-Report- 0627011.pdf. 10. Northern States Power’s Voluntary Mercury Reduction Plan. 2000. URL: www.xcelenergy.com/ 11. Environmentally Preferable Purchasing. Background and Policy: EPP Final Guidance. 2004. http://www.epa.gov/oppt/epp/documents/docback.htm

35 Appendix 2 Resources and Locations Searched at the Murphy Oil for Mercury: • Operations/Maintenance rooms • Wastewater treatment facility • Operating units • Sulfur recovery unit • Boiler room • Compressors • Bone yard • Ninety-day hazardous waste storage • Warehouse • Chemical supply room and laboratories • Monthly chemical inventory lists • Material Safety Data Sheets (MSDS) files in main office • List/map of mercury-containing switches • Any place where switches or controllers might be used. Mercury is most likely to be found in older equipment.

Items That May Contain Mercury : (Source: A Business Guide to Conducting a Mercury Audit, P3ERIE 20 ) Lamps: Fluorescent, high-pressure sodium, metal halide, mercury arc, mercury vapor, ultra- violet, high intensity discharge, and neon (except red, orange, and pink) Batteries: Mercury-zinc, mercury-cadmium, mercury alkaline, mercury oxide, and button Measuring Instruments: Switches, thermostats, thermometers, accustats, counterweights, manometers and vacuum gauges, thermoregulators, barometers, pyrometers, hydrometers, hygrometers, float switches, gas-operated relays in transformers, pressure regulators, level guards, flow meters, wattage meters, flame sensors, rectifiers, shunt trips, ring bal- ances, gas regulators, gyroscopes, and microwave relays/transmitters Equipment: Heating units, refrigeration units, bends in old pipes where mercury can collect, distribution boxes, electrical surrounding equipment, sumps, machinery, industrial welding equipment, and semiconductors.

Also: if your refinery has a medical station, check for mercury-containing thermometers and blood-pressure gauges.

36 Appendix 3 Common Laboratory Chemicals That May Contain Mercury (Source: Draft Wisconsin Mercury Sourcebook: Industry25) This list should not be considered complete. Request that vendors disclose mercury concentration on a Certificate of Analysis for all chemicals ordered.

Caustic potash anhydrous Caustic soda (sodium hydroxide) Chlorine COD reagent Dechlorination chemicals (indicate which one is used) Ferric chloride Histological fixatives Hydrochloric acid Mercuric acetate Mercuric bromide Mercuric iodate Mercuric sulfide Mercurous bromide Mercurous chloride Mercury chloride Mercury iodide Mercury nitrate Mercury (II) chloride Mercury (II) oxide Mercury (II) sulfate Merthiolate Nessler reagent Polyphosphoric acid Potassium ferricyanide Potassium hydroxide Silver nitrate Sulfuric acid (concentrated or dilute) Zenker’s solution

Also: many industrial sites may have elemental mercury on site for refilling mercury- containing equipment.

37 Appendix 4 Sample Letter to Supplier Requesting Certificate of Analysis (replies to letters such as this one appear on the following pages). (Template for letter: Blueprint for Mercury Elimination, Western Lake Superior Sanitary District, Duluth, MN)

38 39 40 41 42 Appendix 5 Mercury inventory checklist (Make copies of this sheet for your own mercury inventory) COMMENTS

LOCATION LOCATION (Operating unit/Storage location) location) unit/Storage (Operating Est. total total Est. mercury (g) (g) mercury (lbs) (lbs) mercury Est. total DEVICES each each Quantity WeightQuantity

INFO (Source) (Source) DATA/

ITEM (Description) (Description)

Appendix 6 Possible Mercury-Containing Products and Alternatives (Source: An Investigation of Alternatives to Mercury Containing Products 26)

1. Float Switches used for liquid monitoring and control in tanks, wells, chambers, drillings, and other containers, as well as liquids such as water, sewage, wet sludge, oil, chemicals, grease, and liquid nitrogen. Alternatives to mercury float switches include: Mechanical switches Magnetic dry reed switches Optical float switches Metallic ball switches Conductivity switches Sonic/Ultra sonic switches (choice preferred by Murphy) Pressure transmitter switches Alloy switches Thermal switches Capacitance switches

2. Hydrometers are used to measure the density or specific gravity of a liquid. They are calibrated based upon the specific gravity of water at 60 degrees Celsius being 1.000. Alternatives to mercury hydrometers include: Alcohol/Spirit filled hydrometers

3. Hygrometers are used to measure the moisture content of air or any gas. Alternatives to mercury hygrometers include: Digital hygrometers Alcohol/spirit filled hygrometers

4. Flow Meters are used in many areas for measuring the flow of gas, water, air and steam. Alternatives to mercury flow meters include: Digital flow meters Ball actuated flow meters

5. Manometers are used to measure air, gas and water pressure. Alternatives to mercury manometers include: Needle/bourbon gauge Aneroid manometer Digital manometer

44 6. Thermometers are used to measure the temperature of a substance. Alternatives to mercury thermometers include: Galinstan thermometers (combination of gallium, indium and tin) Digital thermometers Liquid thermometers Bi-metal thermometers Infrared thermometers

7. Pyrometers are used to measure the temperature of extremely hot materials and are used primarily in foundries. Alternatives to mercury pyrometers include: Optical pyrometers Digital pyrometers

8. Industrial Thermostats and Temperature Switches provide temperature control in manufacturing and industrial settings. Mercury thermostats use a mercury switch to activate the heating/cooling device. The mercury in the switch is part of an electric current relay to activate and deactivate the heating/cooling device when the mercury in the switch is tipped. Alternatives to mercury thermostats include: Digital electronic thermostats Mechanical temperature switches Solid-state temperature switches

9. Tilt Switches sense changes in position or rotation and actuate a switch based upon these changes. Alternatives to mercury tilt switches include: Metallic ball switches Electrolytic switches Potentiometers switches Mechanical switches Solid-state switches Capacitive switches

10. Pressure Switches are devices that convert a pressure change into an electrical switching function. Alternatives to mercury pressure switches include: Solid-state pressure switch Mechanical pressure switch

45 11. Relays are electrically controlled devices that open or close electrical contacts to effect the operation of other devices in the same electrical circuit. Alternatives to mercury displacement relays and mercury wetted reed relays include: Dry magnetic reed relays Electro-mechanical relays Solid-state relays Silicon controlled rectifiers Hybrid (Electro-mechanical and solid-state)

The following website is a valuable tool for finding alternatives for the aforementioned mercury-containing items: www.newmoa.org/prevention/mercury/imerc/notification/

46 Appendix 7 Proposed Mercury/PCB Management Policy for an Oil Refinery

Above all, a mercury/PCB reduction plan should be simple and efficient. Most of the guidelines listed below were used at Murphy Oil, though additional helpful guidelines have been added. Murphy Oil did not need to use this management policy for PCBs since they had already removed most of the PCBs on site. Following these guidelines should help speed and smooth the pollution reduction process at your own refinery.

Best Management Practices for Reducing Mercury/PCBs at an Oil Refinery:

1) Recycle or safely dispose of mercury/PCB-containing products. 2) Label mercury/PCB-containing products that remain. 3) Substitute mercury/PCB-containing products and processes with mercury/ PCB-free items. 4) Avoid purchasing products or using processes that contain mercury/PCBs. 5) Learn about mercury spill and PCB release prevention and obtain the proper clean-up tools. Provide training to employees on how to safely handle and dispose of mercury/PCB-containing products. 6) Develop mercury/PCB management procedures as well as mercury-free purchasing policies and mercury spill policies

Target These Departments to Support Best Management Practices:

1) Refinery Management 2) Environmental Department 3) Purchasing Department 4) Laboratory Staff 5) Wastewater Treatment Department 6) Electrical Equipment Operators 7) Operations Personnel

Implementing Best Management Practices:

1) Start with easy, effective initiatives: a. Look for elemental mercury in storage. b. Is elemental mercury present in obsolete or broken equipment? Could PCBs be removed from non-essential electrical equipment?

47 c. Identify recycling policies already in place. Understand the refinery’s management practices for broken equipment.

2) Identify mercury/PCBs sources and develop an inventory: a. Examine mercury/PCB inventories on file. Update the files after a more complete inventory. b. Tour the refinery to identify potential sources of mercury/PCBs in products and processes. c. List location, type, brand name, and model/product number of mercury/PCB- containing products and processes. Label equipment the remains in use and recycle obsolete equipment. Send PCBs to the proper disposal facility. d. Call the manufacturer/supplier if needed with questions. Refer to resources listed in Appendix 1 and the lists of mercury-containing items in Appendix 2.

3) Evaluate mercury/PCB-free alternatives 13: a. Determine how the alternatives would affect everyday procedures within the refinery. See Appendix 6 for a list of mercury-free alternatives. b. Evaluate the performance of the substitute compared to the original. If the performance is not as good, determine if it is adequate for the purpose? En- sure the substitute is allowed by the methodology for lab testing equipment or other processes and procedures. c. Determine the costs for purchase, calibration, and maintenance of the substitute. d. Determine the new handling and disposal practices for the substitutes. e. Determine the risks of retiring the mercury/PCB-containing device.

4) Develop a three-part phase-out plan prioritized by the potential risk of mercury- or PCB-containing items at the refinery 13: a. High risk: Devices that have immediate potential harm to the environment if damaged. b. Medium risk: Devices with potential harm, but controllable in their current set- ting. c. Low risk: Devices that pose no threat if inventoried and properly disposed of when removed. Some devices will remain in service as long as they are functional. During that period, the facility will continue to track the location of each of these devices in the plant to keep an up-to-date inventory to prevent improper disposal.

5) Establish a purchasing policy for mercury (it is illegal to obtain PCB-containing equipment): a. Require purchasers to get permission from management when purchasing mercury-containing equipment (Make sure management knows that the company does not want to buy mercury-containing equipment — reserve time for management education and buy-in for this program). b. Determine what level of mercury in a sample is significant and use that level as a cut-off for purchasing department to consider that item. This is not something that Murphy Oil has determined for their own facility, but such a limit can be used as a helpful cut-off point for other industries. c. Put mercury-free preferences in product specifications for ordering equipment and chemicals. An example of Murphy Oil’s mercury-free purchasing policy appear in Appendix 8. d. Ask vendors to verify in writing that their products are mercury/PCB- free. Require vendors to provide a Certificate of Analysis with all lab chemicals to verify quantity of mercury, even in trace amounts.

6) Educate and inform staff: a. Put mercury/PCB labels on all mercury/PCB-containing equipment. b. Post educational signs in the cafeteria. c. Conduct a survey about mercury/PCB awareness among employees. d. Distribute an internal employee newsletter about safe use of mercury/ PCB-containing equipment, and outline the refinery’s initiatives to reduce these pollutants within the plant. Describe the benefits of the reduction plan. e. Institute an incentive program to reward mercury-reduction activities. f. Make sure the following information is in the procedures manual: i. Maintenance and handling of mercury/PCB equipment. ii. Mercury spill prevention and management. iii. Recycling and disposal procedures for mercury/PCB equipment. iv. Purchasing and phase-out rules. g. Determine what mercury waste identified in the inventory falls under Universal Waste Rules, such as batteries and fluorescent bulbs, and follow those guidelines for use and disposal. h. Keep a record of how much mercury has been spilled, recovered, recycled, disposed of, or discarded. Keep a record of the amount of PCBs removed from equipment, as well as the quantity that remains on site.

49 Appendix 8 Proposed Mercury-Free Purchasing Policy for an Oil Refinery

I. Purpose To provide guidelines for purchasing activities to minimize mercury sources at Murphy Oil Re- finery.

II. Policy As part of the ongoing efforts to be an environmentally sound company, Murphy Oil Refinery will at minimum limit and to the extent possible avoid the purchase of equipment or materials that contain mercury.

III. Guidelines

A. Responsibilities

1. Purchasing Department In an effort to minimize mercury hazards, personnel shall adhere to the guidelines set forth in this policy when making purchasing decisions. The Purchasing Department will participate in establishing goals, policies and procedures to reduce mercury- containing equipment and materials in the facility.

2. Environmental Department The Environmental Department will provide necessary support to the purchasing personnel regarding mercury hazards and product evaluation. The En- vironmental Department shall review new equipment or material containing mercury or mercury compounds prior to purchase.

3. Department Managers Individuals in all departments must work with Purchasing Depart- ment personnel and the Environmental Department to evaluate the feasibility of mercury alternatives.

B. Purchasing Policy

1. Establish mercury-free guidelines with vendors. Tell vendors that mercury-containing equipment and materials at the refinery will be minimized and/or eliminated whenever possible. In complying with this policy the refinery will request that suppliers specify the amount of mercury contained in any products to be purchased and indicate the feasibility of mercury-free alternatives. Once a chemical is approved, a new vendor can be chosen without going through another MSDS review process.

2. Select vendors willing to meet mercury-free goals. Purchasing Department personnel will

50 incorporate a mercury disclosure requirement into the standard purchase agreement. The disclosure will require the supplier to specify the amount of mercury contained in products to be purchased and provide alternatives if available. a. New Materials Approval Process: When a new vendor is selected, they will be required to include Certificates of Analysis stating the mercury content of their product before the Purchasing Department will buy the new product.

3. When mercury-free alternatives are not feasible, evaluate hazards of mercury- containing products, equipment or materials prior to purchase. This includes proper disposal/recycling of mercury-containing products and review of mercury spill response procedures. This should be conducted in conjunction with Environmental De- partmental and other personnel who have the application knowledge. Any new chemical or hazardous product brought onto the refinery should be evaluated by the MSDS review committee.

4. Identify mercury reduction goals through purchasing efforts. A mercury assessment will be conducted to evaluate equipment and materials that use or contain mercury. Based on the outcomes of the mercury assessment, goals will be established to reduce mercury-containing equipment and materials in the refinery environment. Periodically, Environmental Department personnel, in cooperation with all chemical purchasers, will evaluate and modify the purchasing process based on the previous efforts to reduce mercury and the results of such efforts at Murphy Oil Refinery.

51 Appendix 9 Proposed Policy for Mercury Spills at an Oil Refinery

Purpose: The purpose is to protect human health and the environment by properly cleaning any accidental releases of mercury.

Spill Assessment: If the spill contains less than 10 grams (a pool the size of a quarter) the spill is considered small and can be cleaned up by any trained employee. Thermometers, thermostats and light bulbs all contain less than 10 grams of mercury. Procedure: • Push the mercury into a pile with note cards or stiff paper. • Suck mercury into a non-needle containing syringe or eyedropper. • Syringe or eyedropper and its contents should be placed in an airtight container and properly labeled. • Sprinkle sulfur powder on the spill area after cleaning. The powder changes from yellow to brown if there is still mercury present and more cleanup is needed.

Spill Assessment: If the spill contains more than 10 grams of mercury, the shift foreman should be notified and the area evacuated. Procedure: • Contain the mercury by damming the spill with rags or other disposable items to prevent spreading. Cover the mercury and any cracks or crevices the mercury can leak into with Mercury Vapor Absorbent, sulfur powder, or zinc or copper flakes. • Evacuate the spill area and be sure that shoes, clothing and other articles have not been contaminated. • Secure the scene (use barrier tape if necessary) and restrict admission to only those per- sons who need access to clean up the spill. • Lower the temperature of the room to 70 degrees F or less, to minimize the amount of mercury that vaporizes.

Special Comments: Areas that use mercury-containing equipment must have a mercury spill kit on hand. Re- move all jewelry before cleaning a mercury spill, so the mercury does not amalgamate with the precious metals.

52 Appendix 10

How to identify PCB-containing transformers (From: Environment Canada: Polychlorinated Biphenyls 27)

1. Rule out dry transformers. Transformers that are not filled with liquid are known as “dry transformers” and are not likely to contain PCBs. They most likely do not need to be checked.

2. Check the manufacturer. Any transformer that was manufactured in North America and has a large conservator tank (a large cylindrical object mounted on top of the transformer) was not designed to use PCBs. These transformers are likely to be filled with mineral oil and can be eliminated from the search. If the transformer was manufactured in Europe, check the nameplate for type of fluid contained in the transformer.

3. Rule out small outdoor transformers. These tend to be pole-mounted individually or in a cluster. They contain mineral oil and are not likely to contain PCBs, but may need to be checked anyways. Small canister-type transformers mounted on the wall of a building may contain PCBs because of the fire hazard. In these cases the nameplate should be checked.

4. Check nameplates on all sealed-tank transformers. The “type” of transformer is usually shown in the upper corner of the nameplate: a. If the type of transformer is “LNS” or “LNAN” or any other type starting with a capital “L”, the transformer is likely to have been designed to use PCBs. If the type is “ONS” or “ONAN” or any other type starting with a capital “O”, the transformer is a non-PCB transformer. b. If the type starts with a capital “L”, check the nameplate to see what type of “liquid” or “coolant” is inside the transformer. Fluids manufactured by any of the following companies, then the unit contains PCBs: Apirolio (Italy), Aroclor (U.S. & Great Britain), Aroclor B, Asbestol, Askarel, Askarel Eec18,Chlorextol,Chlorinol,Chlopen (Germany), DK decachlorodiphenyl (Italy), Diaclor,Dykanol, Elemex, Eucarel, Fenclor (Italy), Hyvol, Inclor, Inerteen (Canada & U.S.), Kanechlor (Japan), Nepolin, No-flamol, Phenoclor (France), Pyralene (France), Pyranol (Canada & Great Britain), Saf-t-kuhl, Santotherm FR (Japan), Santovec 1 and 2, Sovol, Therminol FR series (U.S.)

53 Appendix 11

How to Determine the Concentration of PCBs in Transformer Fluid (From: United States Environmental Protection Agency Laws and Regulations: Polychlorinated Biphenyls. Manufac- turing, Processing, Distribution in Commerce and Use Prohibition 28)

EPA code 761.2 PCB Concentration Assumptions for Use:

• Any person may assume that transformers with less than three pounds (1.36 kg) of fluid, circuit breakers, reclosers, oil-filled cable and rectifiers whose PCB concentration is not established contains PCBs at less than 50 ppm. • Any person must assume that mineral oil-filled electrical equipment that was manufactured before July 2, 1979 and whose PCB concentration is not established is PCB Contaminated Electrical Equipment (contains more than 50 ppm PCBs but less than 500 ppm PCBs). All pole top and pad-mounted distribution transformers manufactured before July 2, 1979, must be assumed to be mineral oil filled. Any person may assume that electrical equipment manufactured after July 2, 1979 is non-PCB (less than 50 ppm PCB). If the date of manufacture of mineral oil-filled electrical equipment is unknown, any person must assume to be PCB- contaminated. • Any person must assume that a transformer manufactured prior to July 2, 1979 that contains 1.36 kg (3 pounds) or more of fluid other than mineral oil and whose PCB concentration is not established, is a PCB transformer (greater than 500 ppm). If the date of manufacture and the type of dielectric fluid are unknown, any person must assume the transformer to be a PCB transformer. • Any person must assume that a capacitor manufactured prior to July 2, 1979 whose PCB concentration is not established contains more than 500 ppm PCBs. Any person must assume that a capacitor manufactured after July 2, 1979 is non-PCB (less than 50 ppm). • If the date is unknown, any person must assume the capacitor contains more than 500 ppm PCBs. Any person may assume that a capacitor marked at the time of manufacture with the statement “No PCBs” is non-PCB.

How to establish PCB concentration: 1) Check for a permanent label, mark or other documentation from manufacturer of the equipment indicating its PCB concentration at the time of manufacture. 2) Check service records or other documentation indicating the PCB concentration of all fluids used in servicing the equipment since it was first manufactured. 3) Test the equipment

54 Appendix 12 Glossary: aneroid - Operates by the effect of outside air pressure on a diaphragm forming one wall of an evacuated container. Uses no liquid. anthropogenic mercury emissions - The atmospheric emission of mercury by human activity (e.g. emission of mercury in fossil fuels such as coal). bioaccumulation - The process in which industrial waste and toxic chemicals gradually accumulate in living tissue. biomagnification - Chemicals that bioaccumulate become more concentrated at each successively higher level of the food chain. Bioaccumulative chemicals can be toxic to organisms at the upper end of a food chain, such as predatory fish, loons, eagles, otters, or humans that eat certain fish. cinnabar - Mercury sulfide. HgS, a heavy bright-red mineral, the principal ore of mercury; artificial mercuric sulfide, used as a red pigment. elemental mercury - Also known as metallic mercury, it can combine with other ele- ments or compounds, but elemental mercury itself cannot be broken down. Once it gets into the environment, it can build up in the tissues of organisms. food chain - A community of organisms in which each member of the chain feeds on the member below it. incandescent light bulb - a light bulb that uses an illuminated filament to provide light. Although incandescent bulbs do not contain mercury like fluorescent light bulbs do, they are less energy-efficient, so more mercury-containing coal is burned to provide energy than for fluorescent bulbs. inerteen - one of several PCB compounds methylmercury - Extremely toxic compounds formed from other types of mercury by the action of microorganisms; it is capable of entering the food chain. It is the most toxic form of mercury and, once in the body, can affect the fetal and adult nervous systems. natural mercury emissions - The atmospheric emission of geologically (naturally)

55 bound mercury through natural processes (e.g. emission of mercury from volcanoes, oceans, forest fires) neurotoxin - A poisonous substance that affects the nervous system. Mercury is a neurotoxin.

PCB article - A manufactured item other than a PCB container that contains PCBs. These may include capacitors, transformers, electric motors, pumps, and pipes.

PCB equipment - A manufactured item that contains PCB articles. These articles are necessary for the function of the machine.

PCB transformers - Transformers that contain 500 ppm or more of PCBs.

PCB-contaminated transformers - Transformers that contain between 50 ppm and 500 ppm PCBs. persistent organic pollutants (POPs) - A term used by the United Nations Environment Pro- gram, which refers to organic chemical substances that persist in the environment, bioaccumulate through the food web, and pose a risk of causing adverse effects to human health and the environment. With the evidence of long-range transport of these substances to regions where they have never been used or produced and the consequent threats they pose to the environment of the whole globe, the international community has called for urgent global actions to reduce and eliminate releases of these chemicals. PCBs are among the POPs listed by the United Nations Environment Program. persistent and bioaccumulative toxic substances - A term used by the Great Lakes Binational Program, which refers to a set of designated toxic substances, both organic and inorganic, that remain in the environment, causing problems with ecosystem health. Mercury and PCBs are among these substances. virtual elimination - the goal of eliminating toxic chemicals to the greatest extent possible. Zero discharge and zero emission projects have been established, but voluntary pollution prevention and source reduction are preferred approaches. Persistent toxic substances cannot be completely removed from the environment because some of them can be produced by natural processes and/or by the release of toxins from contaminated sediments. Because of these impedi- ments, virtual elimination is seen by many as a more realistic objective than zero discharge. zero discharge - Halting all inputs from all human sources and pathways to prevent any opportunity for persistent toxic substances to enter the environment from human activity. To completely prevent such releases, the manufacture, use, transport, and disposal of these substances would have to stop.

56 References

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58 An electronic version of this report can be found at: http://www.ci.superior.wi.us/publicwks/wastewater/MurphyProject.htm Report funded by a grant from Environmental Protection Agency Great Lakes National Program Office