Draft report Mercury Sources and Regulations, 1999 Update

Appendix A:  Mercury Use Tree

Appendix B: Industrial Sources of Mercury and Applicable Mercury-Specific Regulations

Appendix C:  Regulations on Products that Contain Mercury

Appendix D:  Examples of State Mercury Controls

Appendix E:  Federal Mercury Controls

Appendix F:  Voluntary Initiatives

Appendix G:  Bibliography

Appendix H:  Mercury Waste RCRA Categories

DOWLOAD APPENDICES
NOTE:  these are Adobe PDF files

Appendix A  (Page 1)  (Page 2)  (Page 3)

Appendices B - F

Appendix G

Appendix H

Source

# Fac.
In Gl*

Origin/uses
Of Mercury

Air Releases **

Water
Discharges 
***

Waste
Management
****

Comments

MERCURY PRODUCTION

Primary Hg Production

Hg no longer produced from Hg ore; primary Hg recovered as by-product from gold ores.

NESHAPS: Hg air emissions shall not exceed 2300 grams Hg/24hrs for mercury ore processing facilities (40CFR61.52)

Hg effluent limits for primary precious metals and Hg subcategory (40CFR 421.250) and mercury ore subcategory (40CFR440.40)

Solid wastes from extraction, benificiation, and processing of ores exempt from RCRA hazardous waste regulations under Bevill amendment.

Mining facilities do not report chemical releases under TRI.

Secondary Hg Production

PA--2 IL--1 NY--1

Recycling/recovery of Hg containing products (e.g. dental amalgams, batteries); industrial waste and scrap (e.g. instrument and electrical manufacturing, waste, sludges from research labs).

Designated major source category of HAP emissions (CAA'112(c)).

Hg effluent limits for secondary Hg subcategory (40CFR421.200)--NSPS, PSNS based on amount of Hg produced or processed.

In-house Hg reclamation also occurs at industrial plants.

MN: drafting management standards for facilities recycling hazardous wastes. Hg refining plants in NY, PA, IL. MN also has three lamp recycling facilities.

Hg - Mercury,
CAA - Clean Air Act,
NESHAPS - National Emissions Standards for Hazardous Air Pollutants,
BIF - boilers and industrial furnaces,
TRI - Toxic Release Inventory,
MSW - municipal solid waste,
HAP - hazardous air pollutant,
MACT - maximum achievable control technology

Note: This table shows the significant sources of Hg releases by source category, and how those releases are currently regulated. Appendix A includes five categories of mercury sources: (1) Mercury Production, (2) Use as a Manufacturing Input, (3) Waste Disposal, (4) Release as a By-Product of Manufacturing, (5) Release as a By-Product of Electrical Generation. An asterisk (*) indicates that additional information appears on the last page.

Hg compound production

NY--3
OH--1
PA--1

Hg compounds include mercuric oxide, mercuric chloride, mercuric & mercurous sulfate, mercurous nitrate, organic Hg salt, thimersol

Many mercury compounds are imported.

Source

# Fac.
In Gl*

Origin/uses
Of Mercury

Air Releases **

Water
Discharges ***

Waste
Management****

Comments

MERCURY USE IN MANUFACTURING*****

Chemical And Allied Products

(mercury cell chlor-alkali process)

WI--1 OH--1

Used as a catalyst in mercury cell process at chlor-alkali plants, which manufacture chlorine and sodium hydroxide. Hg cell process accounted for 14% of 1992 US chlorine production.

Hg emissions cannot exceed 2300g /24hrs; prescribed stack sampling methods required, and approved practices to meet specified ventilation emissions. (CAA (40CFR61, NESHAPS))

Existing Sources: BAT, BPT Hg effluent limits New Sources: NSPS, PSNS

No pretreatment standards for existing sources using mercury cell process (40CFR415.60)

Industry Specific: K071 and K106 are chlor-alkali wastes listed specifically for Hg. Land disposal restrictions for chlor-alkali process wastes effective May 1993

Largest single use of Hg in US

Impact of land disposal restrictions: some facilities are building mercury recovery plants; others are shipping wastes to Canada

Many Hg cell plants have changed to diaphragm cell process

Laboratory Uses

Used in instruments as reagent, catalyst, indicator, and for calibration, sealing, and radioactive diagnosis

No restriction --POTWs may develop public education campaigns for labs

Use declined from 32 metric tons in 1990 to 10 metric tons in 1991.

Paint

Mercury compounds used to control microbial growth in latex paint cans; prevent mildew growth on painted surfaces; anti-fouling agent in maritime paint

P092 - Phenylmercuric acetate (Hg compound used in paints) is an acute RCRA waste

$ All registrations for mercury biocides used in paint banned or voluntarily canceled by registrant

$ Hg in paints expected to continue declining as existing supplies depleted. Paint on buildings is demolition waste (not RCRA)

Other Chemical and
Allied Products

(see Table 5 and Appendix B for mercury- containing products.)

Chemical And Allied Products

Pesticides

Mercury compounds used as pesticides, biocides, fungicides

Process wastewater from manufacture of metallo-organic pesticides w/active ingredient containing Hg prohibited, subject to variances approved by EPA (40CFR455.30)

Voluntary cancellation of last two mercury-containing fungicides announced in November 1993

Electrical And Electronic Uses

Electric Lamps

Use: electrical conductor Hg emitted when lamps break

Products: High intensity lamps: mercury vapor lamps (used in motion picture production, photography, heat therapy); metal halide lamps; high pressure sodium lamps; incandescent lamp filaments, fluorescent lights

Waste streams from fluorescent bulb manufacturing exempted from pretreatment regulations (for all chemicals)

Hg levels in some products meet RCRA or state hazardous waste definition and require special management and disposal

Second largest source of mercury in MSW

Fluorescent bulbs are promoted for energy conservation, but considered hazardous waste due to Hg levels; In 1999, EPA included mercury-containing lamps the in universal waste rule.

MN has three lamp recycling facilities.

Wiring Devices & Switches

Hg encased in metal is used as conductor to close electrical circuit

Products: thermostats, Hg cells in smoke detectors, mercury arc rectifiers, silent switches, tilt switches, relays, cathode tubes used for radios, radar, & telecommunications equipment, electric toys

No pretreatment limits for switchgear wastestreams (for any chemicals)

Components found in a wide variety of equipment with electrical parts (e.g. white goods)

These are considered hazardous wastes under RCRA.

Battery Manufacturing

(1) Used as anode or electrolyte to prevent corrosion and hydrogen release; extends shelf-life; improves performance in extreme temperatures. Products: alkaline batteries. (2) used as cathode in Hg oxide batteries.

Products: mercuric oxide (Hg zinc) button batteries, silver oxide, zinc-air, carbon zinc batteries, mercuric oxide cannister batteries. Hg leaches from corrosion in landfill; volatilizes during combustion

Hg effluent limitations for LeClanche subcategory (zinc anode batteries w/acid electrolyte) (40CFR461.40); NSPS, PSNS, PSES based on mg/kg cell produced for specified operations only; no discharge allowed from nonspecified operations

Hg effluent limits for zinc subcategory (40CFR461.70) - BPT, BAT, NSPS, PSES, PSNS specified for various processes

Batteries are largest source of Hg in MSW incinerators.

In 1996, Congress passed the Mercury-Containing and Rechargeable Battery Management Act which phases out the use of mercury in batteries sold in the U.S. The sole exception are button-cell batteries whose mercury content is limited.

Instruments And Related Products

Measuring & Control Instruments

Use: Hg used to measure or control reactions and equipment functions;

Products: thermometers (primary use), pressure sensing devices (barometers, manometers), navigational equipment, seals, valves; medical/ scientific instruments: Hg emissions occur during cleaning and refilling, and from instruments in municipal solid waste

None

None

Digital thermometers are replacing Hg thermometers.

Hg thermometers banned in Sweden.

MN has special management and disposal restrictions on thermostats.

Dental Equipment & Supplies

Uses: forms alloys; chemically binds compounds together to form stable restorative material (amalgam is an alloy) Products: dental amalgam -- fillings for teeth, other dental equipment and supplies.

None

No specific pretreatment regulations --POTWs may develop education programs for dental offices

Dental amalgams may be a major source of elemental mercury vapor exposure to the general population. Dental amalgam in waste water contributes to POTW Hg levels; may contribute to mercury emissions in crematories.

NOTE: For product-specific information, please see Appendix B. Mercury has several thousand applications. Not all products and uses are specifically listed.

Source

# Fac.
In Gl*

Origin/uses
Of Mercury

Air Releases **

Water
Discharges ***

Waste
Management****

Comments

PRODUCT DISPOSAL - INCINERATION AND LAND DISPOSAL

(under CAA, fuel feed stream must be >30% municipal waste)

Hg is present in solid waste (batteries, electric lighting, etc.) - Hg emitted when waste is burned at high temperatures.

EPA has established MACT standards for major stationary sources. Rule compliance date is 12/2000.

MN - proposed waste combustion rules including emissions limits; new incinerator permits with Hg limits will require air monitoring systems and periodic stack testing.

N/A

MSW ash is considered hazardous waste if it exceeds RCRA toxicity levels. Supreme Court decision (Chicago v. EDF, March 1994)

Municipal solid waste includes waste generated from residential, commercial, and institutional sources; equipment installed to trap fly ash and acid rain gases do not control Hg emissions

MN: Hg must be removed from products before disposal. OH: Considering installing Hg emission control equipment and separating Hg containing products; IL: Incinerator technology based on consideration of specific pollutants.

Commercial/ Industrial Waste Incinerators

Hg present in wastes: batteries, lighting, etc.

EPA will issue proposed rules by 12/2000, and final rules by 12/2001 in accordance with CAA'129(a)(4).

N/A

Sewage Sludge Driers & Incinerators

NY--33
PA--21
MI--19

Hg in sludge from wastewater treatment plants.

CAA - Hg emissions limit = 3200g/24hrs; annual monitoring and reporting if Hg emissions exceed 1600 g/24hrs; prescribed emissions testing procedure or procedures for sludge to demonstrate compliance (40CFR61.52, NESHAPS); Listed as source category for HAP emissions limits (CAA '112(c)(1))

(see wastewater treatment)

EPA is considering a revised rule.

Wastewater Treatment

Hg present in wastewater entering facility

No existing standards; not listed as category of HAP sources.

Mercury is eligible for removal credits - POTWs may request removal credits against facility pretreatment limits, as long as POTW meets sludge concentration limits

Sludges for land application or surface disposal must meet specific concentration requirements for agricultural land, forest land, public contact sites, home garden application or landfills

Hg concentration limits in sludge: 57 mg/kg limit for land application of sludge (40CFR503)

EPA will conduct studies to characterize HAP emissions from industries discharging to POTWs

Hazardous waste incinerators may test Hg content in sludge in lieu of emissions testing requirements.

Western Lake Superior Sanitary District (WLSSD) in Duluth, MN has active pollution prevention program

MI - POTWs must have waste minimization plans

Hazardous Waste Incinerators

IL--1

No uniform emissions standards; Hg limits depend on individual permits; facilities shielded from regulatory changes until permit expires (CFR 264.344)

Waste analysis required to determine Hg concentrations unless incinerator has documentation of no Hg presence (40CFR265.341)

Rule expected in 1999.

Residues must meet LDR specifications

EPA is revising draft hazardous waste combustion rules based on MACT standards

Cement kilns also burn hazardous waste

Medical Waste Incinerators

Hg in wastes generated from hospitals, clinics, labs, etc.

In 1997, EPA set mercury emissions limits based on MACT standards for new and exisiting facilities. Rule Comply date is 9/2002..

WI - incinerators with capacity >5 tons/day must be tested for Hg during first 90 day period and following year

Landfills

Mercury in products in the municipal waste stream, especially those subject to breakage such as thermostats, thermometers, and fluorescent lamps.

Under CAA ('112(d)) EPA will issue mercury emission standards for municipal solid waste landfills by 11/2000. Regulations will be based on MACT standards.

Monitor for Hg in groundwater; leachate testing requirements

Subtitle D (non-hazardous) landfills: leachate cannot exceed 0.2mg/l Hg;

Subtitle C (hazardous waste) landfills: disposal prohibited unless waste undergoes prescribed treatment to reduce Hg to regulated levels

Determine Hg concentrations if food chain crops are grown - Hg cannot be transferred to food chain portion of crop

MN - studying Hg content of landfill gas and leachate. IL - Hg components must be removed from discarded white goods (e.g. appliances) before disposal

MN: Hg must be removed from products before disposal.

Ash disposal facilities

Mercury in incinerator ash

permit specific

Auto salvage/ scrap yards

Automobile components have Hg, some automobiles used for illegal disposal; Hg released from crushing switches

MN monitors mercury levels

MN: developing best management practices for yard operators

Crematories

Hg in dental fillings volatilizes during cremation

Crematorium and pathological unit rules will be proposed 11/1999, as required by CAA '129.

Hospitals, Dentists

Mercury in waste streams (water and solid waste)

No pretreatment regs

IL: P5 Bureau gives guidance on Hg disposal

MN: WLSSD has a brochure for dentists

OH: Community volunteer efforts address Hg in waste

Source

# Fac.
In Gl*

Origin/uses
Of Mercury

Air Releases **

Water
Discharges ***

Waste
Management****

Comments

MERCURY AS A BY-PRODUCT OF MANUFACTURING PROCESSES 

Carbon Black Production

MI--1
OH--1

Hg present in oil feedstock

No Hg limits; but discharge of process waste water prohibited except to POTWs. 40CFR458

Coke Production

IL--3
IN--3
MI--1
NY--1
OH--3, PA--3

Hg is By-product present in coal used as feedstock for coke oven batteries (primary feedstock for iron and coal industry)

Petroleum Refining

Hg present in petroleum crude

No specific Hg limits.

Lime Manufacturing

IL--1
OH--1
PA--1

Hg present as impurity in processed stone and from fuel used to heat kilns

Portland Cement Manufacturing

Hg present in ore and minerals used as raw materials; Hg in fossil fuels used in cement kilns

EPA issues proposed rules in 3/98.

Feed rate screening limits for mercury specified under interim standards for burners or industrial furnaces (40CFR266.103 and 266.106)

Cement kiln dust exempt from RCRA hazardous waste definition.

Cement industry is increasing its use of municipal, industrial, and hazardous wastes for kiln firing to replace fossil fuel use (for energy conservation); EPA is revising draft hazardous waste combustion rules

Phosphate-based fertilizer factories

Hg is trace element in rock phosphate

Primary Smelting & Refining of Copper

MI--1

Copper recovered from sulfide ore that contains Hg

Hg effluent limits for copper, lead, zinc, gold, silver ores subcategory (40 CFR 440.100)

Residues exempted from RCRA under Bevill exclusion

Primary Smelting & Refining of Nonferrous Metals, Except Copper & Aluminum

Hg present in almost all minerals; lead recovered from sulfide ore that contains Hg; zinc smelting process generates Hg emissions

No existing regulations for mercury

Many mining facilities are listed as source categories for HAPS

Hg effluent limitations for: primary antimony subcategory (nonferrous metals category). (40CFR421.140); copper, lead, zinc, gold, silver, and molymbdnenum ores (40CFR440.100), and platinum ores subcategory (440.110)

Residues exempted from RCRA under Bevill exclusion

Source

# Fac.
In Gl*

Origin/uses
Of Mercury

Air Releases **

Water
Discharges ***

Waste
Management****

Comments

MERCURY RELEASED AS A BY-PRODUCT IN POWER GENERATION AND HEATING

Electric Power Generation (Utility Boilers)

Hg present in coal, oil, natural gas, or wood used in electric utility steam generating units - emitted as trace contaminant when volatilized at high temperatures.

No current Hg emissions limits under CAA. CAA 112(n)(1)(A) Utility Study Report to Congress (1998) analyzed the public health hazards from utilities; EPA may promulgate regulations based on study results; utilities exempted from list of sources accounting for 90% of Hg emissions that will require MACT standards ('112(c)(6)

No detectable Hg allowed in discharge

Residues exempt from RCRA under Bevill exclusion

Coal has highest Hg content of fossil fuels. 80% of energy consumption in utility boilers is from coal combustion; 95% of coal is bituminous and subbituminous coal.

Commercial & Industrial Boilers

Hg present in fuels

EPA will issue proposed rules 12/2000, and final rules 12/2001.

Residential Boilers and Wood Stoves

Hg present in fuels

Notes:

Source categories used to identify manufacturing uses of mercury follow Bureau of Mines categories, which track U.S. industrial consumption of refined Hg metal.

Mercury releases to air, water and land are reported by manufacturing firms that meet TRI threshold requirements. Manufacturing facilities (SIC codes 20-39) that have 10 or more full time employees and manufacture/process 25,000 pounds of a listed chemical or otherwise use 10,000 pounds of a listed chemical must report chemical release information in TRI. 

*

"# FAC. IN GL" = number of facilities in Great Lakes States.
Source: National Emissions Inventory of Mercury and Mercury Compounds: Interim Final Report, USEPA, 12/93.

**

Air emissions: EPA must list source categories that account for 90% of aggregate Hg emissions by 1995, excluding electric utilities. Sources will be subject to MACT standards within 10 years ('112(c)(6)). EPA has also published a list of major categories and subcategories of sources that emit hazardous air pollutants (including mercury and compounds). Any stationary source emitting more than 10 tons per year of a listed substance or 25 tons per year of any combination of substances will be subject to MACT standards. Major air toxics emitters will require permits.

***

Water discharge: BAT=best available control technology, BPT=best practicable control technology, NSPS=new source performance standards, PSNS=pretreatment standards for new sources, PSES=pretreatment standards for existing sources. States may impose more stringent permit limits to meet water quality standards for mercury (standards vary by state). Facilities must notify POTW of hazardous substances discharged which are not covered by pretreatment standards.

****

Waste management: Mercury is a listed and characteristic waste under RCRA. Any source listed here may be generating D009, the RCRA hazardous waste code that identifies wastes characteristic for mercury. Other RCRA waste codes that identify mercury include U151 (mercury), K071 and K106 (listed for mercury) , F039 (listed for multiple sources), P065 and P092 (mercury compounds). All mercury-containing wastes have land disposal restrictions. Specified treatment for mercury-containing wastes is incineration or thermal processing (40CFR 268.42).

Note: This table highlights regulations that affect the most common mercury-containing products. It is not a comprehensive list of all products that may contain mercury. 
The "Comments" section includes general information that expands on the regulatory information.

Product/Use

Role of Mercury

Regulations/Programs on Mercury Products

Fed/State Regulation

Comments

Chemical and Allied Products

Agricultural Products

Mercury compounds used as pesticides, bactericides, disinfectants, fungicide

Restricted and/or banned under FIFRA

Federal

Turf Products

Pesticide

Calo-chlor and calo-gran, the last mercury-based pesticides registered for use in U.S. voluntarily canceled by manufacturer (Grace Sierra Crop Protection) in November 1993

Federal

Approximately 21,000 pounds used annually on golf course turf and greens to control fungi Pink Snow Mold and Grey Snow Mold; manufacturer may sell and distribute products labeled for release or shipment before 6/93 until 6/94: retailers may sell products until stocks exhausted; users may use products until stocks depleted.

Fungicide

Prohibits use of mercury in fungicides

MN

Paint

Mercury compounds used as biocide to control microbial growth in paint cans and prevent mildew on painted surfaces

Registrations for mercury compounds in indoor and outdoor latex paint banned or canceled (1990, 1991)

Federal

Manufacturers may use up existing stocks

Cancellation of biocide registrations has reduced Hg consumption in paint, and paint residue in municipal solid waste; paint cans w/mercury residue are still discarded

Anti-fouling paints for marine use banned in 1972

Federal

No Hg deliberately introduced into paint intended for use in MN (except in art supplies)

MN

Pigment, Dyes

Coloring (maroon, red, orange) primarily for plastics

Cadmium-mercury pigments no longer manufactured in U.S. (domestic production ceased in 1988); may still be imported

Federal

Many states have laws that phase out metals in pigments

No Hg deliberately introduced into pigments and dyes intended for use in MN (except in art supplies)

MN

Cosmetics

Preservative, antimicrobial

Limited to eye area cosmetics or ointments with concentration <65 ppm (21CFR700.13)

Federal

Pharmaceuticals

Used in antiseptics, ointments, diuretics

Misbranded drug laws - list quantity of mercury in product

IL, IN, NY, OH, PA

Yellow mercuric oxide is not generally recognized as safe and effective, or is misbranded for over the counter use

Federal

Poisons

Restrictions on sale of mercury and mercury compounds

OH

Levels established for Hg products to be considered poisons

PA

Catalysts

Hg used as catalysts for production of vinyl chloride monomers and urethane foams, as well as other products

Packaging

Restrictions on merc contains intentionally introduced Hg content in packaging and packaging components; no products may be sold in packaging that contains intentionally introduced mercury.

FL, IL, MN, NJ, NY, WI

Implementation dates vary by state, and include general exceptions if no feasible alternatives exist; Pennsylvania is considering bill to regulate toxic materials in packaging

Special Paper Coatings

Mercury bromide and mercury acetic acid used in specialized paper and film with cathode ray tubes

Manufacturers plan to phase out use of mercury in coating

Explosives

Mercury fulminate is detonator

Explosives containing mercury are Class A, maximum hazards

MN, WI

In the last 20 years, only the military has used mercury explosives

Fireworks

Catalyst/explosive

Permits required for fireworks with mercury

MN

Fireworks containing mercury are prohibited.

MI, NJ

Livestock and Poultry Remedies

List percentage of mercury on remedy

MI

Product/Use

Role of Mercury

Regulations/Programs on Mercury Products

Fed/State Regulation

Comments

Electrical and Electronic Uses

Electric Lighting

Electric lighting products are second largest component of municipal solid waste (after batteries)

Fluorescent Lamps
(low pressure)

Mercury vapor fluoresces at UV wavelength

Encouraged as replacement for incandescent bulbs for energy conservation (see 10CFR450.31 - energy conservation measures). Included in the Universal Waste Rule.

Federal

Fluorescent lights are largest component of electric lighting discards in municipal solid waste; used bulbs considered hazardous waste because high levels of mercury exceed RCRA toxicity

Lamps in state-owned buildings must be recycled.

MN

characteristic limit (.2 mg/l in leachate)

Viewed as by-product that can be recycled, and exempt from RCRA

OH

Lamps sold to managers of industrial, commercial, office, or multi-unit buildings must be labeled; building contractors must specify mercury management plans for removed lamps

MN

Lamps containing mercury must be labeled.

VT

Mercury Vapor Lamps

Facilitates light production by electric arc

Encouraged for energy conservation (see 10CFR450.31 - energy conservation measures) Included in the Universal Waste Rule.

Federal

Lamps must be self-extinguishing or have protective shield; efficiency standards in public areas (theaters, gyms)

NY

Mercury must be removed before disposal; lamp sellers and contractors responsible for public education about mercury management requirements; limits on production and distribution of lamps

MN

Lamps containing mercury must be labeled.

VT

High Intensity Lamps

Included in the Universal Waste Rule.

Federal

Lamps sold to managers of industrial, commercial, offices, or multi-unit buildings must be labeled; building contractors must specify mercury management plans for removed lamps

MN

Used for outdoor lighting; mercury lamps are more efficient and brighter than other outdoor lights

Lamps containing mercury must be labeled.

VT

Metal Halide Lamps

Included in the Universal Waste Rule.

Federal

Encouraged for energy conservation (see 10CFR450.31- energy conservation measures)

Lamps containing mercury must be labeled.

VT

Incandescent Lamp Filaments

Hg used as continuous electrical contact in tungsten bar sintering

Included in the Universal Waste Rule.

Federal

Lamps containing mercury must be labeled.

VT

Product/Use

Role of Mercury

Regulations/Programs on Mercury Products

Fed/State Regulation

Comments

Wiring Devices and Switches

Thermostats

Temperature measurement

Mercury must be removed for recycling or recovery before disposal; manufacturers must provide information and incentives to ensure recycling or proper management; heating, ventilating and air-conditioning (HVAC) dealers required to properly manage or recycle used mercury thermostats (MN St 115A.93, 115A.9561, 115.932)

MN

Digital thermostats are replacing mercury thermostats; long lag time before old Hg thermostats discarded

Products containing Hg must be labeled, including disposal restrictions

MN

MN has pilot program for HVAC dealers to recycle mercury containing thermostats by returning them to HVAC wholesaler who, in turn, returns them to Honeywell for recycling/reclaiming

White Goods

Mercury components (e.g., switches) may be included in large appliances (e.g., refrigerators, air conditioners, etc.)

Mercury components must be removed prior to disposal

MN, IL

Hg in repaired or replaced items must be reused or recycled

MN

Toys

Ban on toys with Hg; fines imposed for retail sales

MN, WI

Electric Wall Switches

Products containing Hg must be labeled, including disposal restrictions

MN

Electrical Components

May be included in any electrical machinery (e.g., mining, automotive, and industrial equipment, smoke detectors, etc.)

Limits on mercury use in mining equipment

PA

Products containing mercury must be labeled, including disposal restrictions

MN

Product/Use

Role of Mercury

Regulations/Programs on Mercury Products

Fed/State Regulation

Comments

Batteries

General Mercury Containing Batteries

Batteries included in universal waste rule to ease RCRA restrictions on hazardous waste management and divert waste from MSW landfills; states may set up special collection programs not subject to storage, transportation, and permitting requirements of RCRA 1996 Battery Management Act bans all mercury-containing batteries in the U.S., except for button-cells batteries.

Federal

Batteries were largest source of Hg in municipal solid waste. Many states have banned mercury in batteries; manufacturers have reduced mercury use by over 90% since 1988.

EPA is requesting comments on labeling batteries to aid in collection, sorting, and recycling; denied a petition filed under 'TSCA to require deposit on mercury-containing batteries.

Deposit/refund system will begin in 1998: purchasers return used mercury batteries to retailer or approved collection facility

MI

Task force on storage, transport, disposal, recycling

IL

Industry groups have developed uniform voluntary industry labeling standards for lead and cadmium batteries

Alkaline Batteries

Prevents corrosion and hydrogen release, extends shelf life; improves performance over temperature range (batteries used in flashlights, radios, and other electronics)

Hg concentrations <.025% by weight

MN, NY

Battery manufacturers have eliminated mercury in alkaline batteries, except button cells and reusable batteries.

Hg banned in alkaline batteries in 1996

MN, WI

MN

Mercuric Oxide Batteries (also button cell, mercury-zinc button cell)

Mercury used as cathode material and is integral component (button cell batteries contain ~40% mercury)

Sale of dry cell batteries with mercuric oxide, electrode batteries prohibited without exemption; button cell nonrechargeable batteries restricted to <25mg Hg; labeling requirements; disposal prohibited; manufacturers responsible for collection system

MN

Primarily used in hearing aids; also used in calculators, watches, cameras, photographic equipment, electronic games, health/hospital equipment, airplane underwater locator beacons

Hg content of alkaline button cell batteries must be <25 mg by weight

NY

NY is exploring recycling options for these batteries

Some mercuric oxide cells used in military and medical operations (e.g., night vision devices, EKG machines, etc.) are disposed of as hazardous waste. Proposed federal legislation may ban mercuric oxide batteries.

Carbon Zinc (LeClanche)

Contain ~1% Hg; Hg controls chemical reactions between zinc and other battery components

Sale prohibited if Hg concentration >1ppm

NY

Carbon zinc cells have shorter life than alkaline batteries. Mercury is no longer used in certain zinc battery products.

Sale of batteries with Hg banned after 1994

WI

Zinc Air

Hg content ~ 1%

Button cells restricted to <25 mg mercury, labeling

MN

Used in pagers, hearing aids

Product/Use

Role of Mercury

Regulations/Programs on Mercury Products

Fed/State Regulation

Comments

Instruments and Related Products

Measure and Control Instruments

Thermometers

Elemental mercury indicates temperature

Limits on distribution of Hg thermometers; mercury must be removed before disposal; no routine distribution of Hg thermometers by medical facilities

MN

Digital thermometers are replacing mercury thermometers

Barometers

Indicates pressure

Medical, Scientific Instruments

Temperature and pressure measuring devices

Products w/Hg must be labeled, including disposal restrictions

MN

Dental Equipment and Supplies

Dental Equipment/ Supplies

Forms alloys; chemically binds compounds to form restorative material

FDA regulates dental mercury and amalgam alloys separately as class I and class II devices under Federal Food, Drug, and Cosmetic Act

Federal

One of nation's largest manufacturers of mercury amalgam dental fillings will place warnings on amalgam containers shipped to California and provide warning signs for dental patient waiting rooms under California's Proposition 65 (Safe Drinking Water and Toxic Enforcement Act).

Disposal banned unless mercury reused, recycled or managed to ensure compliance

MN

Purchaser must sign agreement of use for medical or dental uses

MN

The Act requires businesses that use or distribute toxics to label or otherwise notify the public about possible exposure to chemicals.

Discontinued Uses

embalming fluid

Preservative

film pack batteries

Use discontinued as of 1988

maritime paints

Antifouling agent

Registrations suspended in 1972

Federal

photographic development

soap

wood preservatives

Mercury Sources/targets

States with Controls

Control/action

ENVIRONMENTAL SOURCES

General

Minnesota

State has established goals of reducing total mercury releases, from new and existing sources, into air and water by 60 percent from 1990 levels by 12/31/2000, and by 70 percent from 1990 levels by 12/31/2005.

Vermont

State has established an advisory committee on mercury pollution.

Air Point Sources

Florida

Mercury emission standard for municipal solid waste incinerators (65 micrograms/m³).

Maine

Minnesota

Proposed waste combustion rules include emission limits.

New Jersey

Mercury emission standard for municipal solid waste incinerators (65 micrograms/m3), with further reductions to be phased in.

Ohio

Considering installing mercury-emission control equipment.

Wisconsin

State will prepare and adopt minimum standards for mercury air emissions.

Medical waste incinerators with capacity greater than 5 tons per day must be tested for mercury during the first 90 day period of operation and once the following year.

Water Point Sources

Maine

After January 1, 2000 mercury dischargers in water from industrial facilities must be less than 1 pound per year, and after January 1, 2002 must be less than 0.1 pound per year.

Michigan

Businesses must report use and discharge information for mercury under the Water Pollution Control Act.

Wisconsin

State will adopt maximum discharge limits on mercury and mercury compounds.

Hg-Containing Wastes

Florida

It is illegal for small quantity generators (SQGs) to knowingly place batteries or products containing a mercuric oxide electrode into their solid waste stream. Also, manufacturers and distributors of mercuric oxide batteries are required to implement a take-back program for these batteries and products with non-removable batteries, without regard to brand.

The incineration of, or landfill disposal of mercury-containing devices and spent lamps is prohibited.

Requires local governments to implement source separation programs at solid waste facilities to remove mercury containing devices.

Minnesota

Management standards for facilities recycling mercury- containing hazardous wastes (currently being drafted).

Mercury must be removed from products before disposal.

New Hampshire

Established a committee to study mercury source reduction and recycling issues.

Vermont

Labeled mercury-added consumer products must be separated and disposed of in