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Great Lakes Binational Toxics Strategy

Stakeholder Forum - 1998

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Mercury Workgroup

First Annual Report of the Chlorine Institute  

To:  United States Environmental Protection Agency
May 8, 1998


This is the first annual report of the Chlorine Institute to the United States Environmental Protection Agency (U.S. EPA) detailing the Institute's member chlor-alkali mercury cell plants' progress towards meeting the commitment made to U.S. EPA on July 10, 1997. During that meeting, the Chlorine Institute, on behalf of its members, committed to reduce mercury use in the chlor-alkali industry by 50%. The average annual mercury usage for the 1990 - 1995 period was 160 tons. This is the basis for the reduction. The goal is to reduce mercury usage by 80 tons per year by the year 2005. In addition, it was agreed to submit to U.S. EPA, on an annual basis, a report describing the progress made by the various task groups in their technical activities.

The chlor-alkali mercury cell producers and the Chlorine Institute are dedicated to continuous improvements in the protection of human health and the environment connected with the production of chlorine by mercury cell technology. The Institute believes that the industry is in compliance with existing regulations governing releases of mercury to the environment, and that no significant harm to human health and the environment exists as a result of mercury releases from the chlor-alkali industry. Driven by the industry's commitment to Responsible CareŽ, the Institute will strive for further improvements, always guided by sound science, risk management principles, and cost/benefit analysis.

To insure that appropriate oversight is given to the monitoring of progress being made to achieve the commitment, the Institute's Board of Directors established an ad hoc Board Committee on Mercury Issues (BCMI). Reporting to the BCMI is a technical subcommittee, the Mercury Issues Management Subcommittee (MIMSC). All chlor-alkali producers using mercury cell technology are represented on both these committees.

The mission of MIMSC is to address proactively safety, health, and environmental issues that will impact the manufacture and use of chlor-alkali products produced by the mercury cell process. The subcommittee will develop and promote practices that will assist the users of this technology in the achievement of the goal to reduce mercury usage by 50% and in the continued protection of human health and the environment.

MIMSC established seven (7) technical task groups to carry out its mission:

MIMSC and the technical task groups expended considerable effort in the first year of activities related to achieving the 50% reduction commitment. An estimated 23 meetings involving some 29 individuals and amounting to more than 1,400 work hours were expended in 1997 in working to achieving the commitment. Additionally two workshops addressing the mercury reduction commitment held over a total of three days and attended by nearly 150 people were held in 1997. Countless work hours were expended by the member companies in doing work resulting from and in preparing for these meetings.

The attached Table 1 is an updated mercury use report covering both 1996 and 1997 as discussed in the July 10, 1997 meeting. We are pleased by the reduced usage for two consecutive years, but the significance of these reductions should not be overstated. Mercury usage can be highly variable in any given time period because of 'in process' accumulations that can understate or overstate mercury usage during the time frame of concern. Such accumulations require plant shutdowns or maintenance outages to recover and properly account for the mercury. Activities being undertaken by the Mercury Balance Task Group should help to reduce such effects in future years.

While the mercury cell chlor-alkali producers are fully committed to achieving the mercury usage reduction goal, the extensive resource commitment made in 1997 has given us additional confirmation that achievement will not come quickly or easily. Below is a summary of the various task groups' technical activities in 1997.

The Mercury Issues Management Subcommittee has also been very active managing the efforts of the various task groups and in planning the annual Mercury Workshop as part of the annual meeting of the Chlorine Institute.

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