# E C 

# /

R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Drive, Suite 2 5 0  Chapel Hill, North Carolina 2751 4

Telephone: (919) 484

- 0222  Fax: (919) 484

- 0122 

## MEMORANDUM

TO: Donna Lee Jones, PhD, USEPA/OAQPS/SPPD/MMG

FROM: Phil Norwood, EC/R Incorporated

DATE: March 15 , 2010

SUBJECT: Mercury Emission Reductions and Other Mercury Waste Impacts

– Conversion

from Mercury Cell Chlor

- Al kali to Membrane Cell Chlor Alkali Technology

The purpose of this memorandum is present the mercury air emission and other mercury

waste impacts that would result from the conversion of the four mercury cell chlor

- alkali plants

currently operating in the U.S. to non

- mercury (membrane cell) technology. These plants are

ASHTA Chemicals in Ashtabula, Ohio (ASHTA), Olin Corporation in Augusta, Georgia (OLIN

GA), Olin Corporation in Charleston, Tennessee (OLIN

- TN), and PPG in New Martinsville,

West Virgini a (PPG). The first two sections address the baseline mercury air emissions and

mercury releases to other media. In the event of conversion, these routine releases would be

eliminated. This is followed by a discussion of the mercury releases and mercury

- contaminated

wastes that would be generated during the cleanup and decommissioning of the mercury cell

plants. The final section summarizes these air and other media impacts.

BASELINE MERCURY AIR EMISSIONS

Table 1 shows the mercury air releases reported in EPA’s Toxics Release Inventory

(TRI) for 2007 and 2008 for each of the currently operating mercury cell chlor

- alkali plants.

Table 1. Mercury Air Releases Reported in TRI for 2007 and 2008

Plant TRI Mercury Air Releases (pounds/yr)

2007 2008

F ugitive Stack Total Fugitive Stack Total

ASHTA 0.0 0.0 0.0 0.0 0.2 0.2

OLIN

- GA 119 5 124 77 9 86

OLIN

- TN 353 67 420 241 43 285

PPG 145 55 200 149 58 207

## 2 BASELINE MERCURY AIR EMISSIONS

Table 1 shows the mercury air releases reported in EPA’s Toxics Release Inventory

(TRI) for 2007 and 2008 for each of the currently operating mercury cell chlor

- alkali plants. In

addition to the TRI information available online, the companies operating these four facilities

provided emission estimates (which matched the totals in Table 1 reported to TRI) in

correspondence in the summer of 2009. 1

, 2

, 3 

## Later in 2009, EPA requested documentation of

these emission estimates using their authority under section 114 of the Clean Air Act. In

February of 2010, this documenta tion was submitted to the EPA. 4

, 5

, 6 

## This information, which is

available in Docket EPA

- HQ

- OAR

- 2002

- 0017, was carefully reviewed. More discussion on the

conclusions of this review is provided below.

Summary of Reported Facility Emissions and Supporting I nformation

ASHTA

As shown in Table 1, ASHTA reported no mercury releases to the air in 2007 and

0.2 pounds in 2008. In the June 30, 2009 correspondence, ASHTA submitted emission estimates

for 2007 and 2008. The estimates for 2008 were consistent with those in the 2008 TRI. For

2007, ASTA reported 0.12 pounds of point source emissions. Consistent with the TRI, they

reported “0 (Trace) lbs./yr” fugitive emissions for both 2007 and 2008.

The EPA section 114 requested documentation for the point sourc e emissions reported in

the June 30, 2009 correspondence. It also questioned the report that the fugitive emissions are

zero and requested that ASHTA provide a “precise, substantiated, fugitive emissions estimate.”

In their February 15, 2010 response AS HTA provided details of the calculation of the

point source (i.e., stack) emissions. ASHTA conducted emissions tests on their hydrogen and

cell end box air emission streams in March 2006, and they provided a copy of the report for this

testing. ASHTA usi ng the periodic testing alternative to demonstrate compliance with the

emission limitation for by

- product hydrogen streams and end

- box ventilation systems, which

means that they perform tests three times per week. They use alternative methods for this tes ting

1 

### Letter. Jackson, R.L., ASHTA Chemicals Inc., to Jones, D.L., U.S. Environmental Protection Agency. RE:

Docket No. EPA

- HQ

- OAR

- 2002

- 0017

– National Emission Standards for H azardous Air Pollutants: Mercury

Emissions from Mercury Cell Chlor

- Alkali Plants

– ASHTA Chemicals Inc. Comments and Rebuttal on Recent

EC/R Study . June 30, 2009.

2 

### Letter. Hall, R.K., Olin Chlor Alkali Products, to Jones, D.L., U.S. Environmental Prot ection Agency. June 25,

2009.

3 

### Letter. Smith, T.P., PPG Industries, Inc., to Jones, D.L., U.S. Environmental Protection Agency. Re: Docket No.

EPA

- HQ

- OAR

- 2002

- 0017

– National Emission Standards for Hazardous Air Pollutants: Mercury Emissions from

M ercury Cell Chlor

- Alkali Plants

– Memo: “Updated Cost Impacts Associated with the Conversion from Chlorine

Production Utilizing Mercury Cell Chlor

- Alkali Technology to Membrane Cell Technology,” from Heather P.

Brown, P.E. (EC/R Inc.) to Donna Lee Jones, P hD (USEPA), dated June 5, 2009.” July 13, 2009.

4 

### Letter. Jackson, R.L., ASHTA Chemicals Inc., to Jones, D.L., U.S. Environmental Protection Agency. RE:

Docket Response to USEPA Questions. February 15, 2010.

5 

### Letter. Hall, R.K., Olin Chlor Alkali P roducts, to Jones, D.L., U.S. Environmental Protection Agency. Re:

Information requested pursuant to section 114 of the Clean Air Act. February 2, 2010.

6 

### Letter. Smith, T.P., PPG Industries, Inc., to Jones, D.L., U.S. Environmental Protection Agency. Re: Response

to Request for Information under Section 114 of the Clean Air Act, 42 U.S.C. § 7414, dated December 4, 2009, with

regards to the Mercury Cell Chlor

- Alkali MACT and background data to support the estimates provided to USEPA

by PPG in a lette r dated July 13, 2009.” February 18, 2010.

## 3 which have been approved by EPA. Results for each of the tests conducted in 2007 and 2008

were provided, along with the 52

- week rolling average calculations.

The calculations show point source mercury emissions of 0.09 pounds in 2007 and

0.11 pound s in 2008. These estimates are lower than previously reported because the earlier

estimates included emissions from a noncontact cooling tower and not from the mercury cell

process.

ASHTA did not provide any fugitive emission estimates in response to EP A’s request.

They indicated that, since EPA does not have an approved method for estimating fugitive

mercury emissions from a mercury cell chlor

- alkali plant, they cannot provide emission

estimates. ASHTA indicated that the zero emissions levels reported were determined from the

annual mercury balance, the low floor level mercury levels, and the operation of mercury control

systems. They said that they are “confident that the fugitive emissions collection system

installed on the cell room removes large a mounts of off

- process mercury emissions” but they are

“unable to provide the level of conclusion with any direct measurements.” The EPA estimate of

these emissions is discussed at the end of this section.

OLIN

The mercury emission estimates provided in Olin’s June 25, 2009 correspondence for

2007 and 2008 were consistent with those reported in the TRI for both their Augusta, Georgia,

and Charleson, Tennessee facilities. In their February 2, 2010 correspondence, they provided

documentation for these est imates.

At both facilities, Olin utilizes continuous mercury emission monitoring systems. These

units were produced by Mercury Instruments GmbH Analytical Technologies of Germany, and

are equipped with factory supplied calibration gas generators. Zero calibrations are performed

every hour the units are in operation as well as span checks at least once per day. These units

measure and record the mercury concentrations for both the point sources and throughout the cell

rooms. Stack velocity/flow rates a re monitored for the point sources, and cell room flow rates

are estimates using engineering equations.

For the point sources, Olin provided daily emission results for each point source, along

with detailed ten

- minute readings for representative days to illustrate how the daily emissions

were determined. For the fugitive emissions, Olin provided daily measured concentrations,

estimated flow rates, and emissions. They also provided detailed calculation sheets illustrating

how the emissions were calculate d.

PPG

In their July 13, 2009 correspondence, PPG indicated that the mercury stack air releases

in the TRI include 50 pounds/yr from coal

- fired boilers at the site. For this analysis, only the

mercury emissions from the mercury cell chlor

- alkali plant operations are considered. Therefore,

they indicated that the 2007 stack emissions from the mercury cell chlor

- alkali plant should be 5

pounds for 2007 and 8 pounds for 2008. The fugitive emission estimates reported in this

correspondence were consistent with those reported to TRI for 2007 (145 pounds) and 2008 (149

pounds). Therefore, PPG’s mercury emissions from mercury cell operations total 150 pounds in

2007 and 157 pounds in 2008.

## 4 For their three point sources (Hydrogen De

- gas inlet box ventilatio n system, Chlorine

De

- gas end box ventilation system, and Hydrogen Purification system), PPG operates continuous

mercury emission monitors to measure the mercury concentration and flow meters to monitor the

flow rate. In their February 28, 2010 correspond ence PPG provided daily average measured

concentrations, flow rates, and emission rates for 2007 and 2008. They also provided equations

illustrating the calculations performed.

PPG also utilizes a continuous mercury monitoring system to measure mercury

concentration throughout the cell room, and estimates the flow rate from the building based on

the number of roof exhaust fans operating. They provided average cell room concentrations,

flow rates, and emission rates for each day in 2007 and 2008. They a lso provided equations

illustrating the calculations performed.

PPG has entered into an agreement with the Attorney General of Maryland regarding

their West Virginia facility. As part of this agreement, PPG will limit mercury emissions to no

more than 1 50 pounds/yr in 2011 and 2012, and no more than 145 pounds/yr in 2013 and

beyond. Therefore, in 2011 and 2012 there will be around a 2 percent decrease from the average

2007/2008 levels and around a 6 percent decrease in 2013 and beyond.

Estimating Fugit ive Emissions for ASHTA

Because ASHTA did not provide data documenting and substantiating their claim of zero

fugitive emission estimates, we estimated their fugitive emissions since it is not reasonable to

assume there are no emissions. The approach we used was to develop a fugitive emissions factor

based on the amount of mercury contained in their cells. Since a previous analysis found little

correlation between chlorine production and fugitive mercury emissions, 7 

## this other approach

was not considere d viable.

We developed the emissions factor for fugitive mercury emissions based on the estimated

amount of mercury in the cells for the other three facilities and used this factor to estimate

ASHTA’s fugitive mercury emissions. These data are shown in T able 2. The data used to

calculate the average factor, at approximately 0.5 pounds of fugitive mercury emissions per year

per ton of mercury in the cells, shows reasonable agreement between the factors developed for

the three other mercury cell facilities

.

At ASHTA, there are 24 mercury cells. 8 

## Multiplying this number of cells by the average

factor shown in Table 2 results in an estimated fugitive mercury emission estimate of 62 pounds

per year for ASHTA. For purposes of estimating the emissions for the whole industry, this value

was used for both the 2007 and 2008 in this analysis.

Summary of Baseline Air Emissions

Table 3 summarizes the mercury emissions from the four currently operating mercury

cell chlor

- alkali plants for 2007 and 2008.

7 

### U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park,

NC. “ Summary of 2005 Cell Room Mercury Emissions Data for Occidental Chemical Company Mercury Cel l

Chlor

- Alkali Plants: Delaware City, Delaware and Muscle Shoals, Alabama .” March 2008.

8 

### Reference 8.

## 5 BASELINE NONAIR. MERCURY RELEASES

EPA reports that these four plants generated over 157,000 tons of RCRA wastes and

managed almost 700,000 tons in 2007. 9 

## However, t his report does not identify that the wastes

generated are from the mercury cell process, and it d oes not specify the mass of mercury in these

wastes

.

Table 5 shows the nonair mercury releases reported to the TRI for 2007 and 2008. These

releases include the total amount of mercury released to water, land, and underground injection

wells on or at a facility’s site and the amount that is transferred from a facility site to another site

and then released to the environment via water, land or underground injection wells.

Attachment 1 includes a detailed analysis of TRI mercury release data for these f our facilities

.

WASTE GENERATION FROM CLEANUP/DECOMMISSIONING

In addition to the elimination of the routine mercury releases discussed above, there

would be one

- time environmental impacts associated with the clean

- up and decommissioning of

the mercury c ell chlor

- alkali plants. The discussion and quantification of these impacts are

discussed below.

When cell rooms are closed and decommissioned, there will be some loss of mercury to

the environment. The extent of the loss will be influenced by cell roo m design and geographic

location. However, once the cells are shut down, the cell room temperature will decrease, and

the evaporation rate of any exposed mercury is reduced. 10 

## Therefore, we estimated that there

would not be measured mercury air emissions during cleanup/decommissioning.

There is little quantitative information available to estimate the amount of mercury

containing waste that would need to be disposed of during cleanup/decommissioning. When the

Borregaard mercury cell chlor

- alkali plant i n Norway was decommissioned, a large number of

samples were taken to determine the quantity of mercury

- contaminated wastes. The total

quantity of contaminated waste material was estimated at 1,750 cubic meters, of which around

55 percent was contaminated process equipment such as steel and rubber

- lined steel. 11

9 

### U.S. Environmental Protection Agency , Solid Waste and Emergency Response, Washington, DC . “ List of

Reported RCRA Sites in the United States . The N ational Biennial RCRA Hazardous Wa s te Report (Based on 2007

Data) .” November 2008. http://www.epa.gov/osw/inforesources/data/br07/list07.pdf 

## Assuming this level of waste is representative, this would mean approximately 7,000 cubic

meters of waste could be generated during the conversion/closure of the four currently operation

U.S. plant s.

10 

### European Commission. Integrated Pollution Prevention and Control (IPPC). Reference Document on Best

Avail able Techniques in the Chlor

- Alkali Manufacturing Industry. December 2001. p. 96

11 

### Reference 11, pp. 93, 97.

## 6 Table 2. Development of Fugitive Mercury Emissions Factor Based on Mercury in Cells

Plant Number

of Cells a 

## Mercury

in Cells b



## (tons) Fugitive Mercury Emissions

( lb /yr) Fugitive

Emissions

- to

- Cell

Mercury Factor

(lb/yr emissions per

ton mercury in cells) 

## 2007 2008 Avg

O LIN

– GA 60 298 124 86 105 0.33576

O LIN

– TN 106 527 420 284 352 0.63712

PPG

- WV 54 268 145 149 147 0.52229

Average 0.49839

a 

### From 1997 Directory of Chemical Producers (Reference 12

b 

### Using a factor of 0.506 tons of merc ury per cell, which is the amount of mercury in the Chlorine Institute’s 2008

process inventory (1,376 tons) divided by the number of operating cells in 2008 (264) (Reference ).

13 ).



## Table 3. Baseline Mercury Emission Levels

Plant Mercury Emissions (po unds per year)

2007 2008 Average 2007

– 2008

Point Fugitive Total Point Fugitive Total Point Fugitive Total

ASHTA 0.09 62 62 0.11 62 62 0.10 62 62

OLIN

– GA 5 124 129 9 86 95 7 105 112

OLIN

– TN 67 420 487 43 284 327 55 352 407

PPG 5 145 150 * 8 149 157 * 7 147 154

Total 77 751 828 60 581 641 69 666 735

Note : PPG’s emissions is limited by a court settlement to 150 pounds per year in 2001 and 2012

, and

145 pounds per year in 2013 and thereafter.



## Table 4

. RCRA Hazardous Wastes for 2007

Plant RCRA Tons

Generated Managed

ASHTA 826 0

OLIN

- GA 336 522,616

OLIN

- TN 155,880 155,841

PPG 338 22

Total 157,380 678,479

12 

### 1997 Directory of Chemical Producers

– United States of America. Stanford Research Institute International.

Menlo Park, CA. 1997.

13 

### The Chlorine Institute, Inc. “Chlor

- Alkali Industry 2008. Mercury Use and Emissions in the United States

(Twelfth Annual Report).” August 2009.

## 7 Table 5 . Total Nonair. Mercury Releases Reported in the TRI

Plant Total Non a ir Mercury Releases (pounds/year)

2007 2008 Averag e

ASHTA 202 179 190

OLIN

- GA 82 105 93

OLIN

- TN 414 197 306

PPG 1,408 751 1,080

Total 2,106 1,232 1,669

However, information available for the Borregaard plant provided no estimate of the

mass amount of mercury in the wastes. In order to obtain an estimate of the potential mass, the

release information in the TRI was examined for closed or converted facilities. There are six

former mercury chlor

- alkali plants in the TRI that have at least five years worth of release data to

analyze. For each of t hese facilities, the average air releases during the years prior to the last

year for which release data were reported in the TRI was compared to the air releases in the last

year. If those air releases in the last year were less than 50 percent of the av erage air releases for

the previous years for which TRI releases were reported, it was assumed that the mercury cell

plant had ceased operations during that year and was in the process of cleanup/decommissioning.

For those situations, the ratio of the off site transfers during that year was calculated to represent

an estimate of the amount that offsite transfers could increase during cleanup/decommissioning.

This information is summarized in Table 6

.

In order to estimate the mercury contaminated wastes that would be generated during

cleanup/decommissioning and transferred offsite for the four currently operating mercury cell

chlor

- alkali plants, the average level of nonair releases for reported for all years of operation are

multiplied by 253 percent. T hese estimates are shown in Table 7

.

Therefore, it is estimated that the closure/conversion of the four currently operating

mercury cell chlor

- alkali plants in the U.S. could result in the generation of around 7,000 cubic

meters of hazardous wastes conta ining over 6 tons of mercury. Given the unique aspects of each

mercury cell plants, the extreme paucity of specific data on the wastes generated during mercury

cell closures/conversions, and the major assumptions in this analysis, there is significant

unc ertainty in these estimates.

## 8 Table 6 . Summary of TRI Information Used to Estimate

Mercury Cleanup/Decommissioning Wastes

Plant Last

Yr Air Mercury Releases

( pounds / y r) Offsite Mercury Transfers

( pound s/ y r)

Avg a 

### Last Yr Last

Year ÷

Avg Avg a 

### Last Yr Last

Year ÷

Avg

WESTLAKE

CALVERT CITY, KY 

## 2002 983 6 1% 10,108 27,777 275%

OCCIDENTAL

MUSCLE SHOALS, AL 

## 2008 667 322 48% 4,405 12,806 291%

OCCIDENTAL

NEW CASTLE, DE 

## 2008 649 0.4 0% 3,166 16,520 522%

HOLTRACHEM

ORRINGTON, ME 

## 1999 660 116 18% 2,103 1,612 77%

HOLTRACHEM

REIGELWOOD, NC 

## 1999 1,176 328 28% 171 176 103%

PPG

WESTLAKE, LA 

## 2005 997 1,211 121% b b b



## Average 253%

a 

### A vg = average of all years for which data were reported except for the last year.

b 

### Since the air releases in the last reporting year were greater than 50 percent of the average for the previous years,

it was assumed that the plant was operating during this year and the offsite transfers did not represent

cleanup/decommissioning activities.



## Table 7 . Estimated Cleanup/Decommiss ioning Wastes for Mercury Cell Plants

Plant Av era g e Reported

Nonair Releases

Over All Years

(pounds/yr) Estimated

Cleanup/

Decommissioning

Wastes (pounds/yr)

ASHTA 620 1,571

OLIN

- GA 1,264 3,203

OLIN

– TN 1,364 3,457

PPG 1,651 4,185

TOTAL 12 ,416

## 9 SUMMARY

If the four currently operating mercury cell chlor

- alkali plants converted to membrane

processes, the result would be the elimination of mercury emissions, the elimination of mercury

releases to the water and other media, and the terminat ion of the creation of mercury

contaminated wastes from the routine operation of the mercury cells. As discussed above, the

estimated levels of these routine releases are:

**•** 

## Mercury air emissions of between 600 and 800 pounds per year.

**•** 

## Nonair. mercury rele ases of between 1,200 and 2,000 pounds per year.

During the cleanup and decommissioning, there will be mercury

- contaminated wastes that will

be created and that will need to be treated. A rough estimate is approximately 7,000 cubic

meters of waste create d during this process that contains over six tons of mercury.

## 1

- 1 ATTACHMENT 1

Detailed Analysis o f T oxic Release Inventory (T RI ) D ata

MEMORANDUM

DATE: January 5, 2010

SUBJECT: Summary of Mercury Cell Chlor

- Alkali Plant Mercury Re leases Reported in the

Toxics Release Inventory (TRI)

FROM: Phil Norwood, EC/R

TO: Dr. Donna Lee Jones, EPA/OAQPS/SPPD/MMG

The purpose of this memo is to present mercury release information from EPA’s Toxics

Release Inventory (TRI) ( http://www.epa.gov/tri/ ) from the four currently operating mercury cell

chlor

- alkali plants in the U.S.. These plants are ASHTA Chemicals in Ashtabula, Ohio

(ASHTA), Olin Corporation in Augusta, Georgia (OLIN

- GA), Olin Corporation in Charleston,

Tennessee (OLIN

- TN), and PPG in New Martinsville, West Virginia (PPG). In addition to

presenting historical release information, the final section presents what are estimated to be

“typical” annual levels of Nonair. m ercury releases that would be eliminated in the event that

these facilities ceased to operate.

TRI MERCURY RELEASE INFORMATION

These four mercury cell chlor

- alkali plants have been operating since the 1970s. The TRI

contains mercury release data beginn ing in 1988. Attachment 1 contains annual release

information for each of the four plants for the 21 years from 1988 to 2008. Table 1 shows the

sum of the average annual releases from these four plants for the entire 21

- year period, the most

recent ten y ears (1999

– 2008), and the most recent two years (1997 and 1998), and Figure 1

shows the 21 year trends for total mercury releases for each of the four plants. Table 2 provides

more detailed plant

- specific averages. As can be seen in Tables 1 and 2, Fig ure 1, and

Attachment A, mercury releases from these four mercury cell chlor

- alkali plants have steadily

decreased in the 21 year period from 1988 to 2008.

There appears to be an anomaly in the offsite releases for the PPG facility in 2001 (see

Figure 1 and Attachment A). In 2001, PPG reported almost 17,000 pounds released offsite

(While not shown in the table, the specific release reported was attributed to “Offsite

Landfill/Surface Impoundment). This value is over 12 times higher than the next highest level of

offsite mercury release for any year in the 10

- year period. We believe it is reasonable to assume

the activities in 2001 that resulted in this large release represent a unique and nonroutine event.

Therefore, the PPG average release for the per iod 1999

– 2008 was calculated excluding the

2001 values, and a separate total of the plant

- specific averages calculated. This was shown in

Table 2. Therefore, both the 10

- year total and the 2007

- 2008 total Nonair releases were just

under 2,000 pounds pe r year.

## 1

- 2 Table 1. Total Average Mercury Releases from

Mercury Cell Chlor

- Alkali Plants

Period Sum o f Average Mercury Releases

( p ounds /y r)

Total

Releases Total

Air Releases Total

Non a ir Releases

1988

- 2008 9,410 4,510 4,900

1999

- 2008 6,839 3,459 3,380

2007

- 2008 2,331 661 1,669

Note : These plants are ASHTA Chemicals in Ashtabula, Ohio (ASHTA), Olin Corporation in Augusta, Georgia

(OLIN

- GA), Olin Corporation in Charleston, Tennessee (OLIN

- TN), and PPG in New Martinsville, West Virginia

(P PG).

## 1

- 3 0 2000 4000 6000 8000 10000 12000 14000 16000 18000 20000

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008Total Mercury Releases (pounds) 

## Figure 1. Total Mercury Releases Reported in TRI for 1988

- 2008

for Four Currently Operating Mercury Cell Chlor

- Alkali Plants

ASHTA

OLIN

- TN

OLIN

- GA

PPG

## 1

- 4 Table 2 . Average Mercury Release Values

Average Mercury Releases ( p ounds /y r )

Total

(On & Off Site) Total Nonair

(On & Off Site) Onsite Air Onsite Nonair Onsite Water Offsite

21

- Year Av erage ( 1988

- 2008 )

ASHTA 1,875 620 1,255 10 2 2 518

OLIN

– GA 2,263 1,264 1,000 10 10 1,254

OLIN

– TN 2,583 1,364 1,218 1,333 21 31

PPG 2,689 1,651 1,037 60 59 1,591

Total of Averages 9,410 4,900 4,510 1,505 92 3,394

Total of Averages (excluding PPG 2001) 8,646 4,148 4,498 1,507 94 2,641

10

- Year Av era g e ( 1999

- 2008 )

ASHTA 1,096 212 885 0 0 212

OLIN

– GA 761 106 655 10 10 96

OLIN

– TN 1,716 648 1,068 584 11 64

PPG 3,265 2,414 852 27 25 2,387

Total of Averages 6,839 3,380 3,459 621 46 2,759

Total of Averages (excluding PPG 2001) 5,207 1, 794 3,413 621 46 1,173

2007

– 2008 Av era g e

ASHTA 191 190 0 0 0 190

OLIN

- GA 199 93 105 11 11 82

OLIN

- TN 658 306 352 305 7 1

PPG 1,283 1,080 204 23 23 1,057

Total 2,331 1,669 661 340 41 1,329

## 1

- 5 ATTACHMENT A. Annual Mercury Release Data from TRI 1988

– 2008.

Facility Year Mercury Releases Reported i n T RI ( p ounds /y r)

Onsite Releases

Off Site

Releases Total Releases

(On & Off Site) Total Nonair.

Releases

(On & Off Site) Total Onsite

Releases Fugitive Air Stack Air Total Air Onsite No na ir Water Land

ASHTA 1988 1,569 1,046 516 1,562 7 6 1 1,877 3,446 1,884

ASHTA 1989 1,303 1,046 250 1,296 7 6 1 2,215 3,518 2,222

ASHTA 1990 1,804 1,046 750 1,796 8 6 2 0 1,804 8

ASHTA 1991 1,306 1,046 250 1,296 10 5 5 978 2,284 988

ASHTA 1992 1,6 53 1,046 595 1,641 12 7 5 792 2,445 804

ASHTA 1993 1,652 1,046 596 1,642 10 5 5 551 2,203 561

ASHTA 1994 2,871 1,046 614 1,660 1,211 6 1,205 1,177 4,048 2,388

ASHTA 1995 2,530 1,046 608 1,654 876 5 871 0 2,530 876

ASHTA 1996 1,658 1,046 607 1,653 5 5 0 524 2,182 529

ASHTA 1997 1,654 1,046 607 1,653 1 1 0 347 2,001 348

ASHTA 1998 1,653 1,046 607 1,653 0 0 0 297 1,950 297

ASHTA 1999 1,653 1,046 607 1,653 0 0 0 242 1,895 242

ASHTA 2000 1,390 1,046 344 1,390 0 0 0 219 1,609 219

ASHTA 2001 1,396 1,046 3 50 1,396 0 0 0 100 1,496 100

ASHTA 2002 1,395 1,046 349 1,395 0 0 0 173 1,568 173

ASHTA 2003 1,383 1,046 337 1,383 0 0 0 128 1,511 128

ASHTA 2004 813 464 349 813 0 0 0 134 947 134

ASHTA 2005 813 464 349 813 0 0 0 434 1,247 434

ASHTA 2006 2 0 2 2 0 0 0 306 308 306

ASHTA 2007 0 0 0 0 0 0 0 202 202 202

ASHTA 2008 0 0 0 0 0 0 0 179 179 179

OLIN

- GA 1988 1,329 1,048 271 1,319 10 10 0 6,014 7,343 6,024

OLIN

- GA 1989 1,327 1,046 271 1,317 10 10 0 2,129 3,456 2,139

OLIN

- GA 1990 1,331 1,046 271 1,317 14 14 0 4,730 6,061 4,744

OLIN

- GA 1991 1,285 1,000 270 1,270 15 15 0 5,740 7,025 5,755

## 1

- 6 ATTACHMENT A. Annual Mercury Release Data from TRI 1988

– 2008.

Facility Year Mercury Releases Reported i n T RI ( p ounds /y r)

Onsite Releases

Off Site

Releases Total Releases

(On & Off Site) Total Nonair.

Releases

(On & Off Site) Total Onsite

Releases Fugitive Air Stack Air Total Air Onsite No na ir Water Land

OLIN

- GA 1992 1,329 1,046 271 1,317 12 12 0 5,933 7,262 5,945

OLIN

- GA 1993 1,324 1,046 271 1,317 7 7 0 712 2,036 719

OLIN

- GA 1994 1,328 1,046 271 1,317 11 10 1 23 1,351 34

OLIN

- GA 1995 1,325 1,046 271 1,317 8 8 0 23 1,348 31

OLIN

- GA 1996 1,324 1,046 271 1,317 7 7 0 8 1,332 15

OLIN

- GA 1997 1,323 1,046 271 1,317 6 6 0 5 1,328 11

OLIN

- GA 1998 1,326 1,046 271 1,317 9 9 0 50 1,376 59

OLIN

- GA 1999 1,245 1,046 189 1,235 10 10 0 23 1,268 33

OLIN

- GA 2000 730 562 157 719 11 11 0 21 751 32

OLIN

- GA 2001 773 608 158 766 7 7 0 39 812 46

OLIN

- GA 2002 746 585 154 739 7 7 0 282 1,028 289

OLIN

- GA 2003 742 563 169 732 10 10 0 114 856 124

OLIN

- GA 2004 753 563 182 745 8 8 0 36 789 44

OLIN

- GA 2005 835 563 261 824 11 11 0 136 971 147

OLIN

- GA 2006 591 493 86 578 13 13 0 149 740 162

OLIN

- GA 2007 138 119 5 124 14 14 0 68 206 82

OLIN

- GA 2008 96 77 9 87 9 9 0 96 192 105

OLIN

- TN 1988 4,421 1,046 282 1,328 3,093 26 3 ,067 0 4,421 3,093

OLIN

- TN 1989 5,750 1,045 249 1,294 4,456 25 4,431 0 5,750 4,456

OLIN

- TN 1990 5,236 1,045 240 1,285 3,951 25 3,926 5 5,241 3,956

OLIN

- TN 1991 3,780 1,045 378 1,423 2,357 22 2,335 12 3,792 2,369

OLIN

- TN 1992 4,353 1,045 180 1,225 3,128 17 3,111 3 4,356 3,131

OLIN

- TN 1993 2,777 1,045 192 1,237 1,540 26 1,514 0 2,777 1,540

OLIN

- TN 1994 1,704 1,045 464 1,509 195 53 142 0 1,704 195

## 1

- 7 ATTACHMENT A. Annual Mercury Release Data from TRI 1988

– 2008.

Facility Year Mercury Releases Reported i n T RI ( p ounds /y r)

Onsite Releases

Off Site

Releases Total Releases

(On & Off Site) Total Nonair.

Releases

(On & Off Site) Total Onsite

Releases Fugitive Air Stack Air Total Air Onsite No na ir Water Land

OLIN

- TN 1995 1,719 1,045 488 1,533 186 43 143 0 1,719 186

OLIN

- TN 1996 1,868 1,045 249 1,294 574 40 534 0 1,868 574

OLIN

- TN 1997 2,165 1,045 428 1,473 692 31 661 0 2,165 692

OLIN

- TN 1998 3,279 1,045 255 1,300 1,979 15 1,964 0 3,279 1,979

OLIN

- TN 1999 2,640 1,045 584 1,629 1,011 13 998 0 2,640 1,011

OLIN

- TN 2000 2,185 1,045 369 1,414 771 7 764 1 2,186 772

OLIN

- TN 2001 2,126 1,045 85 1,130 996 8 988 0 2,126 996

OLIN

- TN 2002 2,137 1,045 85 1,130 1,007 14 993 375 2,512 1,382

OLIN

- TN 2003 1,711 1,046 85 1,131 580 18 562 26 1,737 606

OLIN

- TN 2004 1,455 1,049 105 1,154 301 14 287 30 1,485 331

OLIN

- TN 2005 1,5 17 1,046 204 1,250 267 12 255 5 1,522 272

OLIN

- TN 2006 1,440 1,032 109 1,141 299 13 286 198 1,638 497

OLIN

- TN 2007 834 353 67 420 414 8 406 0 834 414

OLIN

- TN 2008 481 241 43 285 196 6 191 1 482 197

PPG 1988 1,500 1,000 250 1,250 250 250 0 4,300 5,800 4,550

PPG 1989 1,500 1,000 250 1,250 250 250 0 750 2,250 1,000

PPG 1990 1,500 1,000 250 1,250 250 250 0 250 1,750 500

PPG 1991 1,145 1,000 85 1,085 60 60 0 1,800 2,945 1,860

PPG 1992 1,163 1,045 85 1,130 33 33 0 250 1,413 283

PPG 1993 1,15 2 1,045 85 1,130 22 22 0 1,340 2,492 1,362

PPG 1994 1,256 1,045 193 1,238 18 18 0 230 1,486 248

PPG 1995 1,266 1,045 192 1,237 29 29 0 250 1,516 279

PPG 1996 1,275 1,045 190 1,235 40 40 0 191 1,466 231

PPG 1997 1,254 1,045 188 1,233 21 21 0 102 1,356 1 23

## 1

- 8 ATTACHMENT A. Annual Mercury Release Data from TRI 1988

– 2008.

Facility Year Mercury Releases Reported i n T RI ( p ounds /y r)

Onsite Releases

Off Site

Releases Total Releases

(On & Off Site) Total Nonair.

Releases

(On & Off Site) Total Onsite

Releases Fugitive Air Stack Air Total Air Onsite No na ir Water Land

PPG 1998 1,258 1,045 189 1,234 24 24 0 80 1,338 104

PPG 1999 1,254 1,045 187 1,232 22 22 0 62 1,316 84

PPG 2000 1,239 1,045 182 1,227 12 12 0 93 1,332 105

PPG 2001 1,301 1,045 227 1,272 29 29 0 16,658 17,959 16,687

PPG 2002 1,267 1,045 188 1,233 34 34 0 900 2,167 934

PPG 2003 1,238 1,045 177 1,222 16 16 0 1,130 2,368 1,146

PPG 2004 1,248 1,045 171 1,216 32 32 0 1,145 2,393 1,177

PPG 2005 425 169 231 400 25 25 0 657 1,082 682

PPG 2006 356 172 134 306 50 34 0 1,115 1,471 1,165

PPG 2007 230 145 55 200 30 30 0 1,378 1,608 1,408

PPG 2008 223 149 58 207 16 16 0 735 958 751