Environmental Engineering Reference
In-Depth Information
use or upon disposal. The QSC has expended considerable
efforts to facilitate and encourage progress on these sources.
Two QSC documents published in 2008 summarize state
and local actions to address mercury discharges from the
dental sector. At that time, 11 states reported having legisla-
tion or regulations in place to reduce mercury pollution from
the dental sector. The QSC reports
Dental Mercury Amalgam
Waste Management White Paper
and
Case Studies of Five Dental
Mercury Amalgam Separator Programs
provided background
information about the environmental signifi cance of mer-
cury attributable to the dental sector and specifi c infor-
mation about state and local government programs that
address dental mercury amalgam discharges (QSC 2008a,
2008b). Information-sharing webinars have also been held
to facilitate state actions on this sector. QSC and ECOS also
advocated for stepped-up national efforts to reduce mercury
pollution from the dental sector. In December 2008, the
EPA announced a Memorandum of Understanding with the
American Dental Association calling for voluntary efforts to
reduce mercury amalgam discharges to wastewater (USEPA,
2008). Although supportive of these efforts, the QSC urged
the EPA to take additional steps to ensure timely progress.
In 2010, QSC and ECOS further urged the EPA to back up
the voluntary effort by including dental facilities for rule-
making in its effl uent guidelines program plan and by
requiring the use of best management practices, including
amalgam separator mercury-pollution controls, at dental
facilities (ECOS, 2010; QSC, 2010). Soon thereafter, the EPA
announced that it was initiating an effl uent guideline rule-
making for dental facilities, with a draft rule expected in
2011 and a fi nal rule in 2012 (USEPA, 2010).
The QSC also issued the
Product Labeling: Information
for States
report to stimulate discussion about the value
and effectiveness of state mercury-added product labeling
requirements, which have been adopted by many states.
Labeling helps to ensure that consumers are informed
about the mercury content of various products and serves
as a mechanism to encourage the use of nonmercury alter-
natives (QSC, 2006b). The QSC report provides informa-
tion about labeling activities in nine states. The companion
Mercury-Added Product White Paper
identifi ed fi ve mercury
containing product types in which signifi cant reductions
in mercury use and releases could be achieved through state
and federal pollution prevention initiatives (QSC, 2006a).
The QSC also engaged with car manufacturers, steel
makers, the auto recycling industry, environmental orga-
nizations and the EPA to help establish and implement
the
Memorandum of Understanding to Establish the National
Vehicle Mercury Switch Recovery Program
(NVMSRP)
.
This
agreement was developed to enhance the recycling of mer-
cury switches from automobiles as a mechanism to reduce
mercury emissions from scrap metal furnaces (USEPA,
2006). Prior to 2003, over 200 million mercury switches,
containing approximately 0.5 to 1 g of mercury, were
installed in vehicle lighting applications (e.g., trunk lights),
anti-lock brake sensors, and some airbags. When vehicles
are scrapped, the mercury switches may be broken, imme-
diately spilling their contents, or they may enter scrap
metal wastes destined for high-temperature reclamation.
By 2010, over 3.3 million mercury switches had been
collected from over 9000 participating recyclers. Although
an impressive total, the recycling targets established under
the NVMSRP have not been achieved and the industry-
supported fund established to provide recyclers an incen-
tive payment for each switch diverted from the waste
stream has been depleted. Discussions to further fund and
improve the program, which is scheduled to run through
2017, are ongoing. QSC has worked to evaluate the program
and continues to monitor its implementation (QSC, 2009).
Safe, Long-Term Storage of Excess Commodity
Elemental Mercury Nationally and Internationally
Since its inception, the QSC has voiced its opposition to U.S.
elemental mercury stockpile sales and advocated for a fed-
eral plan to manage the long-term storage of excess com-
modity elemental mercury. To inform QSC positions on
this issue, a series of workgroup assessments were completed
in 2003 addressing commodity mercury management, stor-
age, best management practices, markets, and policy option
issues (QSC, 2003a, 2003b, 2003c, 2003d, 2003e). These
reports were the basis of a set of QSC principles regarding
the collection and management of elemental commodity
grade mercury and ECOS Resolution 06-1: Mercury Retire-
ment and Stockpiling, which advocated against the market
sales and export of elemental commodity grade mercury
from the U.S. federal strategic mercury stockpile. Com-
munications from the QSC and its member organizations
to federal decision makers also contributed to the Defense
National Stockpile Center's environmental impact state-
ment regarding the disposition of the federal stockpile and
the ultimate decision to indefi nitely suspend sales and con-
solidate the stockpile for safe long-term storage (Defense
National Stockpile Center Defense Logistics Agency, 2004).
The ECOS also testifi ed in support of federal U.S. leg-
islation, the Mercury Export Ban Act of 2008 (S.906),
cosponsored by U.S. Senators Barack Obama (D-IL) and
Lisa Murkowski (R-AK), and Representative Tom Allen
(D-ME), among others (Smith, 2007). This Act prohibits the
export of elemental mercury from the United States start-
ing in 2013 as well as commercial sales from the federal
mercury stockpiles held by the Department of Energy and
the Department of Defense. It also directs the Department
of Energy to provide for the permanent safe storage of
collected/recycled U.S. mercury in excess of domestic
demand. In addition to the ECOS, the Natural Resources
Defense Council, American Chemistry Council, National
Mining Association, and Chlorine Institute also supported
this Act. The Act was overwhelmingly approved in both
the Senate and House of Representatives in September
2008 and signed into law by President George W. Bush in
October 2008.
