A GUIDE TO MERCURY REDUCTION IN INDUSTRIAL AND COMMERCIAL SETTINGS A Joint Effort By: Inland Ispat Indiana Harbor Works Bethlehem Steel Burns Harbor Division United States Steel Gary Works The Delta Institute Lake Michigan Forum July, 2001 Table of Contents I. Introduction…………………………………………………………………..1 Why Focus on Mercury?………………………………………………...1 Voluntary Approach to Mercury Reduction……………………………..3 II. Guide for Supplier Mercury Reduction Initiatives…………………………..6 Mercury Reduction Step-by-Step………………………………………..6 Finding It—The Mercury Inventory……………………………………12 Mercury in Purchased Materials………………………………………..16 Mercury in Equipment …………………………………………………20 Resources to Assist Your Mercury Reduction Efforts………………….24 III. Results of The Steel Mill Voluntary Mercury Reduction Effort ………….26 Overall Mercury Inventory Results ……………………………………26 Mercury in Purchased Materials ……………………………………….27 Mercury in Equipment …………………………………………………28 Mercury in Waste Streams and Non-Product (Revert) Outputs………..31 Mercury Reduction Plan …………………………………………………………………...32 References……………………………………………………………………..34 Appendices A. NW Indiana Steel Mills Mercury Pollution Prevention Initiative Agreement B. Inland Ispat Inc. Procedure ENV-20: Mercury Reduction and Waste Management Program C. Mercury Switches and Relays and Their Non-Mercury Alternatives ii Tables and Figures Tables Table 1—Voluntary Mercury Reduction Efforts in the Great Lakes Basin………...5 Table 2—Mercury Inventory Scope……………………………………………….13 Table 3—Mercury Inventory Form: Devices and Liquid Mercury………………..14 Table 4—Mercury Inventory Form: Mercury-Containing materials………………15 Table 5—Mercury-Containing Chemicals in the Industrial Setting……………….17 Table 6—Mercury-Containing Equipment in the Industrial Setting………………21 Table 7—Mercury Content of Equipment/Controls……………………………….22 Table 8—Inventory of Mercury and Mercury-Containing Equipment: #7 Blast Furnace…………………………………………………………23 Table 9—Estimated Amount of Mercury in Chemical Products Purchased Annually……………………………………………………...28 Figures Figure 1—The Mercury Cycle………………………………………………………2 Figure 2—Mercury Pledge Form……………………………………………………8 Figure 3—Sample Letter to Supplier Requesting Certificate of Analysis…………18 Figure 4—Sample Certificate of Analysis…………………………………………19 Figure 5—Summary of Mercury Inventory Findings……………………………...27 Figure 6—Estimated Amount of Liquid Mercury in Storage On-Site and Contained in Equipment and Devices……………………………..29 Figure 7—Mercury Pressure Sensing Device……………………………………...30 Figure 8—Ignitron Rectifiers………………………………………………………31 Figure 9—Estimated Mercury in Waste Streams…………………………………..32 iii I. Introduction In 1998, Bethlehem Steel Burns Harbor Division, Ispat Inland Indiana Harbor Works, United States Steel Gary Works, the United States Environmental Protection Agency, the Indiana Department of Environmental Management, and the Lake Michigan Forum – a stakeholders group providing input into the Lakewide Management Plan for Lake Michigan – signed a voluntary agreement known as the Mercury Pollution Prevention Initiative. (See Appendix A) The agreement called for the three participating companies to inventory mercury in storage, mercury-containing equipment and materials, significant waste streams and revert outputs. (“Revert” refers to materials that are internally recycled within the facilities.) It also called for the companies to identify, where possible, alternatives to mercury containing equipment and materials and prepare reduction plans that include reduction goals, planned actions to reach the goals, and an implementation schedule. The purpose of this report is to share the results of this mercury reduction initiative and provide guidance to suppliers and other industrial facilities to assist in their mercury reduction efforts. It begins with background information on mercury—why it is important to reduce its use and release to the environment and why a voluntary approach is the most effective way to accomplish that. Next, a case study of the mercury reduction initiative at the three northwest Indiana steel mills is presented, including inventory findings and reduction schedule. Finally, a guide to developing a mercury reduction program, based on the experiences of the three mills, is presented in order to assist others. Mercury is a pollutant of concern due to its toxic and bioaccumulative properties. Large industrial complexes often use devices such as gauges, relays, switches, manometers, and thermometers that contain mercury. Liquid elemental mercury may also be kept in labs or storerooms. These devices can leak or break, and when they do, the resulting uncontrolled mercury spills may pose dangers to human health and the environment and impact the facility’s ability to meet discharge permit limits. In addition, properly cleaning up a mercury spill in order to meet current safety standards is extremely expensive. The good news is that most uses of mercury are unnecessary. Alternatives exist for most, if not all, mercury containing devices. However, identifying and replacing these devices can be daunting for a large facility. This report presents a pollution prevention approach to mercury in devices and products and steps for constructing a mercury elimination program. It features a case study from three Northwest Indiana steel mills and step-by-step measures for achieving significant mercury reductions at industrial complexes, manufacturing facilities and related operations since many of their mercury uses and scales of operations are probably similar. Why Focus on Mercury? Mercury is released to the environment from many sources. It is used in household and commercial products, as well as industrial processes. Manufacturing facilities, hospitals, dental 1 practices, schools and even some motor vehicles have all been found to contain quantities of elemental mercury that can cause releases to the environment if recognition and proper precautions are not instituted. Most of these sources, individually, may release relatively small amounts of mercury. However, the problem arises from the propensity for mercury to build up, rather than break down, in the environment and the potential for minute concentrations to cause health and environmental impacts. For example, bioaccumulation —the process of chemical magnification up the food chain—can result, over time, in a level of mercury in the topmost consumer up to 10,000,000 times greater than the original amount in surrounding waters.1 Adding to the complexity of mercury build-up is the fact that gaseous mercury can be transported long distances in the atmosphere and can persist there for a long time before being deposited, creating a global reservoir of mercury. The amount of mercury falling on any water body is potentially comprised of contributions from this global atmospheric reservoir, regional sources and local sources. Figure 1 illustrates the different pathways that mercury can take in the environment. Figure 1 The Mercury Cycle (Source: Dr. Steven Lindberg, Oak Ridge National Laboratory) Mercury can be dangerous to aquatic and human life. When mercury is deposited in lakes or streams, natural bacteria action converts it to methylmercury, which makes the mercury available to concentrate in the tissue of fish, wildlife and people who eat the fish. Due to high mercury levels in fish and the potential health impacts for people, most states issue advisories each year cautioning people to limit their consumption of certain species and sizes of fish from certain water bodies. Human exposure to mercury can result in long-lasting health effects, especially on fetal development during pregnancy. In addition, mercury poisoning has been linked to nervous 2 system disorders, kidney and liver damage and impaired childhood development. Nervous system disorders include impaired vision, speech, hearing and coordination.2 Mercury has many applications in industry due to its unique properties, such as its fluidity, uniform volume expansion over the entire liquid temperature range, high surface tension, electrical conductivity and its ability to alloy with other metals. A wide variety of industries including electrical, medical, chemical and mining utilize mercury. Such commercial uses of mercury include barometers, thermometers, switches, fluorescent lamps, and mercury arc lamps. Mercury has been identified as a “critical pollutant” under the Great Lakes Water Quality Agreement (GLWQA) due to its (1) presence in open lake waters, (2) ability to cause or contribute to failure to meet Agreement objectives, and (3) potential to bioaccumulate. Under the GLWQA, Canada and the United States agreed to develop, in consultation with state and provincial governments, Lakewide Management Plans (LaMPs) to address the critical toxic pollutants that contribute to ecological impairments in each Great Lake. Each LaMP focuses on substances such as mercury that persist at levels that are causing or are likely to cause impairments. In recent years, there has been a focus on reducing the use of mercury in products and reducing air emissions that are greater than what is necessary to protect public health. In 1997, the United States and Canada signed the Binational Toxics Strategy Agreement, which seeks to achieve, by 2006, a 50% reduction in the deliberate use of mercury in the United States as well as a 50% reduction in releases of mercury to the atmosphere.3 Mercury is identified as a “Tier 1” pollutant in this agreement, making it a top priority for coordinated efforts between the two countries