the role of private enterprise in the reclamation, recycling and storage of mercury presented by...
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The Role of Private Enterprise The Role of Private Enterprise in the Reclamation, Recycling in the Reclamation, Recycling and Storage of Mercuryand Storage of Mercury
Presented byPresented by
Brad J. Buscher, Chairman and CEOBrad J. Buscher, Chairman and CEO
of Mercury Waste Solutions, Inc.of Mercury Waste Solutions, Inc.
Company BackgroundCompany Background
Formed in 1996Formed in 1996
IPO in 1997IPO in 1997
Mercury retortingMercury retorting
Lamp and ballast recyclingLamp and ballast recycling
FacilitiesFacilities
Roseville
Union Grove
Indianapolis
AtlantaKansas City
Albany
Chicago
MWS Minnesota Lamp Recycling Facility
MWS Wisconsin Retorting Facility
Company BackgroundCompany Background
Union Grove Retorting Facility:Union Grove Retorting Facility:
4 stationary ovens – 25 drum capacity4 stationary ovens – 25 drum capacity
1 Continuous flow oven – 1,000 lbs per hour capacity1 Continuous flow oven – 1,000 lbs per hour capacity
Treat over 1,800 tons of waste annuallyTreat over 1,800 tons of waste annually
Recover over 80,000 lbs or 400 tons of Hg annuallyRecover over 80,000 lbs or 400 tons of Hg annually
Is There a Role for Is There a Role for Private Enterprise?Private Enterprise?
GOOD QUESTION!GOOD QUESTION!
To answer that question, an explanation of the history of the mercury recycling industry is To answer that question, an explanation of the history of the mercury recycling industry is necessary…………………..necessary…………………..
Regulatory OverviewRegulatory Overview
1.1. Resource Conservation and Recovery Act of 1976 “RCRA”.Resource Conservation and Recovery Act of 1976 “RCRA”.
Hazardous waste classificationHazardous waste classification
Comprehensive cradle to grave system for generation, transport, storage, treatment and disposal of hazardous wasteComprehensive cradle to grave system for generation, transport, storage, treatment and disposal of hazardous waste
Prior to RCRA, mercury recyclers’ business model was based on resale of Hg as a commodityPrior to RCRA, mercury recyclers’ business model was based on resale of Hg as a commodity
After RCRA, business modeled evolved toward getting paid for liability reductionAfter RCRA, business modeled evolved toward getting paid for liability reduction
Regulatory OverviewRegulatory Overview
2.2. Land Disposal Restriction “LDR” Program --1984Land Disposal Restriction “LDR” Program --1984
Disposal Prohibition – requires treatment standards for haz waste before it can be landfilledDisposal Prohibition – requires treatment standards for haz waste before it can be landfilled
Dilution Prohibition – prevents dilutionDilution Prohibition – prevents dilution
Storage Prohibition – prevents indefinite storageStorage Prohibition – prevents indefinite storage
Regulatory OverviewRegulatory Overview
LDR Treatment Standards:LDR Treatment Standards:
RMERC – retorting of organic and inorganic “high” mercury wasteRMERC – retorting of organic and inorganic “high” mercury waste
IMERC – incineration of organic “high” mercury wasteIMERC – incineration of organic “high” mercury waste
Industry BackgroundIndustry Background
Why did the mercury recycling industry expand in the early 1990’s?Why did the mercury recycling industry expand in the early 1990’s?
Regulatory framework in placeRegulatory framework in place
Anticipation of universal waste rule for fluorescent lampsAnticipation of universal waste rule for fluorescent lamps
Mining industry activityMining industry activity
Choral kali industry activityChoral kali industry activity
Industry BackgroundIndustry Background
What happened to the Mercury Recycling Industry?What happened to the Mercury Recycling Industry?
Delay in Universal Waste Rule for lampsDelay in Universal Waste Rule for lamps
Increased competitionIncreased competition
But primarily due to But primarily due to increased waste shipments to Canadaincreased waste shipments to Canada
What Happened?What Happened?
124k173k
342k383k
467k 487k540k
663k
0
100,000
200,000
300,000
400,000
500,000
600,000
700,000
1992 1993 1994 1995 1996 1997 1998 1999
Haz Waste Sent to Canada (tons)
Source: Environment Canada
What Happened?What Happened?
$0
$500
$1,000
$1,500
$2,000
$2,500
CalciumPhoshpate
Mercury Debris MercuryDevices
Retorting Prices per 55g Drum
1992 Prices 2002 Prices
What Happened?What Happened?
12
5
0
5
10
15
1998 2002
Mercury Retorting Companies Still in Business
Industry BackgroundIndustry Background
Why the Exodus to Canada?Why the Exodus to Canada?
Canada (i.e. Ontario and Quebec) allows untreated waste to be landfilledCanada (i.e. Ontario and Quebec) allows untreated waste to be landfilled
Canadian disposal option much cheaper than retortingCanadian disposal option much cheaper than retorting
Inconsistencies in U.S. treatment standardsInconsistencies in U.S. treatment standards
What Happened?What Happened?
$2,000
$150
$0
$500
$1,000
$1,500
$2,000
U.S. Retort CA Landfill
Price Comparison: U.S. Retorting vs. Canadian Landfill (per ton)
Industry BackgroundIndustry Background
U.S. Treatment Standards:U.S. Treatment Standards:
1.1. TCLP testTCLP test
If > 0.2 mg/l, run analytical for total mercury content If > 0.2 mg/l, run analytical for total mercury content or send to Canadaor send to Canada
If < 0.2 mg/l, no treatment is requiredIf < 0.2 mg/l, no treatment is required
2.2. Total Mercury TestTotal Mercury Test
If > 260 ppm, retorting is requiredIf > 260 ppm, retorting is required
If < 260 ppm, either retort or stabilization prior to landfillIf < 260 ppm, either retort or stabilization prior to landfill
Industry BackgroundIndustry Background
U.S. Treatment Standards continued:U.S. Treatment Standards continued:
3.3. Exclusions from these treatment standards – the DEBRIS RULEExclusions from these treatment standards – the DEBRIS RULE
If waste is classified as “debris”, material can be still landfilled even if > 0.2 mg/l and > 260 ppm.If waste is classified as “debris”, material can be still landfilled even if > 0.2 mg/l and > 260 ppm.
Rule was intended for construction & demolition debris, however, Rule has broad interpretationRule was intended for construction & demolition debris, however, Rule has broad interpretation
Industry BackgroundIndustry Background
Examples of Debris Rule Exceptions:Examples of Debris Rule Exceptions:
Coast Guard batteriesCoast Guard batteries
Nicor cleanupNicor cleanup
Sampling techniquesSampling techniques
Other examplesOther examples
Back to the Question…..Back to the Question…..
Given the current regulatory and industry environment, is there a ongoing opportunity for Private Given the current regulatory and industry environment, is there a ongoing opportunity for Private Enterprise in the Recycling and Reclamation of Mercury?Enterprise in the Recycling and Reclamation of Mercury?
Yes……but on a limited basisYes……but on a limited basis
Back to the Question…..Back to the Question…..
What needs to happen……What needs to happen……
U.S. rules need to be clear, defined and enforcedU.S. rules need to be clear, defined and enforced
Enforcement needs to focus on generatorsEnforcement needs to focus on generators
Canadian treatment standards need to be raised to that of U.S. standardsCanadian treatment standards need to be raised to that of U.S. standards
Back to the Question…..Back to the Question…..
Given the current regulatory and industry environment, is there a Given the current regulatory and industry environment, is there a future future opportunity for Private opportunity for Private Enterprise in the Enterprise in the StorageStorage of Mercury? of Mercury?
Unlikely…………Unlikely…………
Back to the Question…..Back to the Question…..
For the storage industry to evolve….For the storage industry to evolve….
Clear, concise government regulations that govern Hg Storage are needed that answer the following questions:Clear, concise government regulations that govern Hg Storage are needed that answer the following questions: Who’s waste is it?Who’s waste is it? How much Hg can be stored?How much Hg can be stored? How long?How long? Who pays for the storage?Who pays for the storage? Facility design and construction requirements?Facility design and construction requirements? Permitting and insurance requirements?Permitting and insurance requirements?
Conclusions and QuestionsConclusions and Questions