News

March 03, 2011

Supplemental Proposal to Air Toxic Standards for Mercury Emissions from Mercury Cell Chlor-Alkali Plants

FACT SHEET
Supplemental Proposal to Air Toxic Standards for
Mercury Emissions from Mercury Cell Chlor-Alkali Plants
ACTION
• On March 3, 2011, the Environmental Protection Agency (EPA) issued a supplemental
proposal for existing mercury cell chlor-alkali facilities under Clean Air Act standards known
as Maximum Achievable Control Technology standards (MACT). These facilities produce
chlorine and other chemicals.
• The supplemental proposal presents and seeks public comments on a new proposed option to
prohibit mercury emissions from mercury cell chlor-alkali facilities.
• The new proposed amendments would prohibit the emissions of mercury from these plants.
Plants could comply with this requirement by either converting to nonmercury technology or
by ceasing their chlorine production operations.
• This action also again publishes the original June 11, 2008 proposal as an option which
requires more monitoring for existing chlor-alkali plants in their cell areas, but does not
prohibit the emissions of mercury.
• When EPA issued the original MACT standards in 2003, the industry consisted of 12
mercury cell facilities. Currently, there are only four facilities in operation in four States:
(Augusta) Georgia; (Charleston) Tennessee; (New Martinsville) West Virginia; and
(Ashtabula) Ohio. The Georgia and Tennessee plants are both owned by Olin Corporation.
The Olin Corporation announced on December 10, 2010 that it will convert its Tennessee
plant to a nonmercury technology, and also eliminate mercury from its Georgia plant, thereby
leaving 2 facilities remaining that would be affected by this rule.
• EPA will take public comment on the proposed rule for 60 days following publication in the
Federal Register.
Petition For Reconsideration
• The proposed amendments are the result of EPA’s continued reconsideration of the 2003
Mercury Cell MACT. The National Resources Defense Council (NRDC) submitted a petition
for reconsideration that claimed EPA should require conversion of the remaining mercury
cell chlor-alkali plants to nonmercury technology to produce chlorine.
• One of the issues raised by NRDC was that in the 2003 MACT, EPA had failed to consider
nonmercury technology as a ‘beyond-the-floor MACT’ control measure for existing mercury
cell chlor-alkali plants . The 2003 rule already prohibits mercury emissions from new and
reconstructed sources.
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• In EPA’s 2008 proposed response to NRDC, the Agency conducted an analysis to consider
nonmercury technology as a beyond-the-floor MACT control measure, but rejected the
option because at that time we viewed the cost imposed on existing facilities in the industry
as being too high.
• In public comments on the 2008 proposal, members of the public continued to object to
EPA’s rejection of a requirement that chlor-alkali plants eliminate mercury emissions.
• The Agency has revised the analysis based on the additional information received since the
2008 proposal and developed a benefits and cost assessment of a mercury emission
prohibition that represents the best estimates given the available information.
Benefits and Costs
• The regulatory impact analysis performed for the new proposed option indicates that there
are co-benefits from the reduction of fine particles due to decreased energy consumption.
These co-benefits range from $14 million to $37 million, depending on the assumed discount
rate.
• The capital costs to convert all four mercury cell chlor-alkali plants would be nearly $300
million, with individual plant capital costs ranging from a low of $28 million to a high of
approximately $160 million.
• The EPA analysis estimates the total annual costs to be around $13 million per year, ranging
from a low of $800,000 per plant per year to almost $7 million per plant. The estimate of the
cost-effectiveness of a conversion is around $20,000 per pound of mercury emission
reduction.
• The nonmercury membrane cell process that is considered in the new proposed option
requires less energy than the mercury cell process. Therefore, if all four existing mercury
chlor-alkali plants convert to membrane cells there would be a savings in energy of at least
22 percent, for a total of around 350,000 megawatt hours per year, which is approximately
equivalent to the energy produced by a 40 megawatt power plant.
Additional Information
• EPA estimated that the total mercury emissions from the four mercury cell operating
facilities to be around 640 pounds per year. This is approximately 0.3 percent of the total
inventory of mercury emissions into the air in the United States.
• The four chlor-alkali plants reported almost 2,000 additional pounds of on-site and off-site
mercury releases to media other than air per year. These releases would be eliminated in the
longer term, with consequential benefits for non-air quality related health and environmental
values under the new proposed option.
• In addition, the handling of over 1,200 tons of virgin mercury that is used in the cells at these
four chlor-alkali plants would also be eliminated along with the approximately two tons of
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mercury per year that the industry reported as unaccounted for, based on the latest (2008)
data.
• More than 95% of chlorine produced in the Unites States is currently made in facilities using
nonmercury methods
BACKGROUND
• The original 2003 MACT standards for mercury cell facilities established emission limits for
mercury emissions from stacks, and an optional monitoring program to address fugitive
mercury emissions from the cell rooms as an alternative to the cell room work practice
program.
• In February 2004, NRDC filed a petition with EPA for the Agency to reconsider the 2003
MACT, specifically relating to control of fugitive mercury air emissions. NRDC also filed a
petition for judicial review of the NESHAP, and that litigation has been stayed pending
EPA’s response to the petition for reconsideration.
• One of the issues raised by NRDC was that in the 2003 MACT, EPA had failed to consider
nonmercury technology as a ‘beyond-the-floor MACT’ control measure for existing mercury
cell chlor-alkali plants . The 2003 rule already prohibits mercury emissions from new and
reconstructed sources.
• We have revised our analysis based on the additional information received since the 2008
proposal.
FOR MORE INFORMATION
• Interested parties can download the supplemental proposal from EPA’s web site on the
Internet under recent actions at the following address: http://www.epa/gov/ttn/oarpg.
• Today’s supplemental proposal, the June 11, 2008, proposed amendments and other
background information are also available either electronically at
http://www.regulations.gov, EPA’s electronic public docket and comment system, or in
hardcopy at the EPA Docket Center’s Public Reading Room.
o The Public Reading Room is located in the EPA Headquarters, Room Number
3334 in the EPA West Building, located at 1301 Constitution Ave., NW,
Washington, DC. Hours of operation are 8:30 a.m. to 4:30 p.m. eastern standard
time, Monday through Friday, excluding Federal holidays.
o Visitors are required to show photographic identification, pass through a metal
detector, and sign the EPA visitor log. All visitor materials will be processed
through an X-ray machine as well. Visitors will be provided a badge that must be
visible at all times.
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o Materials for this action can be accessed using Docket ID EPA-HQ-OAR-2002-
0017.
• Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2002-0017, by one
of the following methods:
􀂃 http://www.regulations.gov. Follow the on-line instructions for submitting
comments.
􀂃 E-mail: [email protected]
􀂃 Fax: 202-566-9744.
􀂃 Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC),
Air and Radiation Docket and Information Center, Mail Code: 6102T,
1200 Pennsylvania Ave., NW, Washington, DC, 20460. Please include
two copies.
􀂃 Hand Delivery: U. S. Environmental Protection Agency, EPA West (Air
Docket), 1301 Constitution Avenue, Northwest, Room 3334, Washington,
DC. Such deliveries are only accepted during the Docket’s normal hours
of operation, and special arrangements should be made for deliveries of
boxed information.
• For further information about the proposed amendments regarding Mercury Cell Chlor-
Alkali Plants, contact Sharon V. Nizich of EPA’s Office of Air Quality Planning and
Standards (OAQPS) at (919) 541-2825 or [email protected]

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