Great Lakes Binational Toxics Strategy

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Implementation

Stakeholders Forum
November 16-17, 1998 - Chicago, Illinois

Presentation
Chlorine Institute Presentation

Arthur E. Dungan
Direct Line: 202-872-4730)
e-mail: <adungan@CL2.com>

The Chlorine Institute, Inc.
2001 L Street, NW - Suite 506
Washington, DC 20036

Facsimile: 202-223-7225
Web site: www.CL2.com

I am pleased to be here today to give a perspective on the Chlorine Institute and the USA based mercury cell chlor-alkali industry's commitment to the Binational Strategy as it pertains to mercury. I am not going to discuss the details of the Institute's commitment. If you are interested in hearing about specifics, come to the mercury work group meeting this afternoon. Mr. Bill Rankin of Olin Corporation will be discussing activities related to the commitment. Additionally, EPA has posted on its Great Lakes National Program Office web site the Institute's First Annual Report which we submitted in May.

First a little background on the Chlorine Institute. The Chlorine Institute, Inc., founded in 1924, is a 225-member, not-for-profit trade association of chlor-alkali producers worldwide, as well as packagers, distributors, users, and suppliers. The Institute's mission is the promotion of safety and the protection of human health and the environment in the manufacture, distribution and use of chlorine, sodium hydroxide, potassium hydroxide and sodium hypochlorite, plus the distribution and use of hydrogen chloride. The Institute's North American Producer members account for more than 98 percent of the total chlorine production capacity of the U.S., Canada, and Mexico.

The output of the Institute is embodied in the more than 150 pamphlets, videos, training materials, and engineering drawings pertaining to our mission chemicals. Our Chlorine Manual is a compendium of these publications as they relate to chlorine and is designed to provide technical information pertaining to safe practices in all aspects of chlorine handling.

In the United States there are fourteen mercury cell chlor-alkali facilities that produce about 12% of the total USA output of these two building block chemicals. The industry is committed to responsible management of mercury used in chlor-alkali production. The industry is in compliance with or exceeding the rigorous and protective safety, health and environmental standards set by the various government agencies.

In addition to government regulation, the industry has long practiced pollution prevention and surveillance measures to minimize the release of mercury and their effect in the workplace and the environment.

Since concerns were first raised in the United States nearly thirty years ago about the adverse effects caused by mercury, the mercury cell chlor-alkali facilities have taken costly, highly effective steps to dramatically reduce both mercury use and releases. Discharges to the environment have been significantly reduced through a programmatic approach focusing on recycling and mercury use reduction. The EPA's Mercury Report to Congress estimates that chlor-alkali facilities account for only 4.5% of all anthropogenic releases to the atmosphere.

We believe that mercury cell Chlor -alkali technology, when practiced in accord with laws, regulations, and the Principles of Responsible Care^®, and in accordance with Chlorine Institute recommendations, has no adverse effects on human health and the environment.

You might now, rightfully, ask, "Why are the Chlorine Institute and the chlor-alkali industry here?" The answer is simple. We know that we must continue to seek improvement. The Institute and the chlor-alkali industry believe the Canada - United States Strategy for Virtual Elimination of Persistent Toxic Substances in the Great Lakes Basin pertaining to mercury as drafted in August, 1996 and later approved by both parties with only minor revisions provided an opportunity for the industry to publicly commit to continuous improvement as it relates to mercury use by and releases from the chlor-alkali industry.

While we still have concerns about what is necessary to achieve the long range goals of the strategy, we were particularly heartened by the focus on specific measurable intermediate term goals to reduce mercury use and releases that, through diligent efforts, can be achieved. We viewed this as a step change in the strategy from the prior draft.

Simultaneously with the development of the Binational Strategy, there was already an effort underway to build consensus among the mercury cell chlor-alkali producers to proactively address increasing concerns about mercury through voluntary programs and information sharing that would allow for reductions in mercury use and releases to the environment.

This industry led initiative allowed us to view the revised draft strategy as an opportunity to proactively committing the mercury cell chlor-alkali industry to reduce, in a measurable way, uses and releases of mercury. In September of 1996, the mercury cell producers, through the Chlorine Institute, made the commitment to EPA. In the spring and summer of 1997 two meetings were held between agency and industry representatives to discuss what was meant by this commitment and how the industry would provide progress. As stated earlier, Bill Rankin will be summarizing the progress at this afternoon's meeting. However, I want to briefly restate the Institute's commitment and present the data which have been updated from our May submittal to include newly released government data.

The Chlorine Institute's Commitment

• Reduce mercury use in the chlor-alkali industry by 50%. The annual average mercury usage for the 1990-1995 period was 160 tons. This is the basis for the reduction. The goal is to reduce mercury use to 80 tons per year or less by 2005.

• Submit to EPA on an annual basis a report including the progress made by the various task groups in their technical activities.

We are only in the second year of a nine year commitment. It's too early to measure any success of lack of success. I can say, the industry intends for the commitment to be successfully implemented. As we enter into the new millennium, and see substantial progress in the achievement of these mercury reduction goals, we can see what else might be necessary to reduce the environmental concerns from mercury.

Chlor-Alkali Mercury Cell Process - USA Only