Critical Design Elements for an On-Site Mercury Concentration and Holding Facility - 20175

Abstract

Administrative changes and funding issues have delayed the Department of Energy (DOE) from establishing and commissioning a National Repository for mercury as required under the Mercury Export Ban Act (MEBA) of 2008. In the interim, a few hazardous waste Treatment, Storage, and Disposal Facilities (TSDFs) have been authorized to accept mercury classified as a hazardous waste as under Subtitle C of the Resource Conservation and Recovery Act (RCRA). Waste generators are charged (either by weight or by volume) for the waste they manifest to these TSDFs. In many cases, mercury and mercury compounds have chemically sorbed to (or physically lodged into) the interstitial spaces of a substrate material. This almost always causes the amount of waste generated to be unnecessarily large, due to the extra volume (or weight) of the accompanying, non-mercury materials. Depending on a multitude of factors, it could be financially beneficial for waste generators to take greater control of their mercury affairs by separating these substrate materials from the mercury and mercury compounds that have become associated with them. Building and operating an on-site mercury Concentration and Holding Facility (CHF) could help relieve a waste generator's overall cost burden. The purpose of such CHFs is not to treat or dispose of mercury, but to recover and concentrate mercury from bulky mercury-laden materials to the extent that the host substrate to which the mercury may have previously been sorbed could pass a Toxicity Characteristic Leaching Procedure (TCLP) test and either be disposed of at a conventional landfill, or be disposed of at a hazardous waste landfill, but absent additional restrictions specifically for mercury. A CHF represents a way for waste generators to save money by separating mercury from common host materials, concentrating it, and then safely storing it until transportation to an authorized TSDF takes place This paper focuses on the critical design elements waste generators should consider when designing and operating a mercury CHF. (authors)