The Pennsylvania State University. The Graduate School. Environmental Pollution Control EXTENDED PRODUCER RESPONSIBILITY PROGRAM FOR

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1 The Pennsylvania State University The Graduate School Environmental Pollution Control EXTENDED PRODUCER RESPONSIBILITY PROGRAM FOR HOUSEHOLD HAZARDOUS WASTE MANAGEMENT AND HUMAN HEALTH RISK ASSESSMENT IN DEVELOPING COUNTRIES: ULAANBAATAR CITY, MONGOLIA A Thesis in Environmental Pollution Control by Temuulen Murun 2015 Temuulen Murun Submitted in Partial Fulfillment of the Requirements for the Degree of Master of Science December 2015

2 ii The thesis of Temuulen Murun was reviewed and approved* by the following: Shirley Clark Associate Professor of Environmental Engineering Program Coordinator, Master`s of Science in Environmental Pollution Control Thesis Advisor Yen-Chih Chen Associate Professor of Environmental Engineering Kathleen Raffaele Senior Science Advisor Office of Solid Waste and Emergency Response, U.S. EPA *Signatures are on file in the Graduate School

3 ABSTRACT iii Over two decades ago, the European Union developed and started implementing the Extended Producer Responsibility (EPR) policy to prevent household hazardous waste (HHW) pollution and its environmental and human health risks. Because of the increase in population, rapid urbanization, and the amount of importing hazardous waste in developing countries, appropriate solid waste management and disposal are needed especially for HHW treatment. As a developing country, Mongolia does not have specific regulations and treatment requirements for HHW. Unlike developed countries, the mandatory EPR policy run by government will be necessary for Mongolia because small and familyowned businesses are not willing to handle waste voluntarily due to the cost of collection, recycling, and final disposal. Moreover, a Producer Responsibility Organization (PRO) will face difficulties if advanced recycling fees and end-of-life fees from consumers fund the organization, since the country`s GDP per capita in 2014 was only US $11, (Trading economics). Therefore, under the EPR program, cooperation between a municipality and PROs is necessary and mutually beneficial, especially in waste collection and transporting. This is especially important because of the potential health risks resulting from incineration of HHW. Due to open burning fluorescent bulbs in the central waste facility, it is estimated that 69,637kg Hg/yr could be released into the atmosphere directly. Human health risks from mercury exposure, using a traditional risk characterization procedure, showed potential neurological concerns (hazard quotient: 14.42, exposure time: 12hr/d) for children who live within 500m of this municipal waste incineration. In contrast, renal effects due to lead exposure (82.28kg Pb/yr) from lead-acid vehicle battery recycling factories showed a low health risk for children. To prevent this children`s neurological effect implementation of the mandatory EPR program for HHW such as automobile batteries, fluorescent bulbs, and used tires is necessary in developing countries because most of municipal solid waste facility are designed poorly to capture emissions of hazardous substances.

4 iv TABLE OF CONTENTS List of Figures....v List of Tables.....vi Abbreviation.vii Chapter 1 INTRODUCTION Chapter 2 HOUSEHOLD HAZARDOUS WASTE MANAGEMENT....4 Background of Extended Producer Responsibility program The EPR program implementation in developing countries Municipal solid waste and household hazardous waste management in Ulaanbaatar city, Mongolia Municipal solid waste Household hazardous waste General EPR policy framework in developing countries: Ulaanbaatar city, Mongolia Chapter 3 MERCURY RISK ASSESSMENT Mercury exposure from municipal solid waste incineration 28 Hazard identification 35 Physical and chemical properties of elemental mercury..35 Toxicology: Neurological effects in children...36 Risk characterization 40 Chapter 4 LEAD RISK ASSESSMENT Lead exposure from recycling lead-acid car battery factors 43 Hazard identification Physical and chemical properties of lead Toxicology: Renal effects in children Risk characterization Chapter 5 CONCLUSIONS References 58

5 LIST OF FIGURES v Figure 1: Trends of e-waste generated in the U.S..2 Figure 2: Extended Producer Responsibility program Figure 3: EPR program adoption... 5 Figure 4: Recycled material components from e-waste...11 Figure 5: E-waste management in Switzerland Figure 6: The recovery rate for some household wastes..15 Figure 7: Electronic waste composition by weight..18 Figure 8: EPR policy by product type..20 Figure 9: PROs and municipal participation in the EPR program (Mongolia) Figure 10: EU Battery Directive (labels).27 Figure 11: Compact FL driver..29 Figure 12: The former MSW facility Figure 13: The former MSW facility location and the city center...33 Figure 14: The metallic mercury airborne exposure pathway..34 Figure 15: Dose and renal and neurological effects of mercury airborne exposure (chronic) Figure 16: Dose-response of elemental mercury vapor (inhalation) 39 Figure 17: The pollutant zone within the 500 m radius...40 Figure 18: Internal structure of a lead-acid battery Figure 19: The chemical reaction in a lead-acid battery Figure 20: Typical recycling process of used LABs in developing countries.47

6 LIST OF TABLES vi Table 1: Urban waste generation by regions..1 Table 2: Factors to develop the EPR policy Table 3: The EU classification of e-waste Table 4: Japanese waste management laws.13 Table 5: Annual municipal waste generation in Ulaanbaatar city, Table 6: E-waste export and import. 20 Table 7: Energy saving from recycled materials.. 26 Table 8: Mercury source in MSW Table 9: Mercury containing lamps...30 Table 10: Mercury emission from waste incineration..34 Table 11: The amount of mercury released into environment. 33 Table 12: Physical and chemical properties of mercury..35 Table 13: NOAEL and LOAEL of animals and the human...37 Table 14: The mean wind velocity and average mixing height Table 15: Consumption of lead for batteries (1993) Table 16: Lead components in automobile batteries Table 17: Lifetime of automobile batteries (1995) Table 18: The annual amount of lead from LABs (Ulaanbaatar city). 47 Table 19: Physical and chemical properties of lead.50 Table 20: LOAELs for neurological disorders.51 Table 21: Lead nephrotoxicity in humans (Dose-Response) Table 23: Matrix application for the EPR policy framework...54

7 ABBREVIATIONS vii ADF ASTDR AT BW BC CDI CFL CA FL EOL EPA ED EF ET EPR GASI GDP HQ HHW IR IMERC JICA LAB LCD LOAEL MRL MSW NOAEL NGO NPO Advanced disposal fees Agency for Toxic Substances and Disease Registry Averaging time Body weight British Columbia Chronic daily intake Compact fluorescent lamps Contaminant concentration in air Fluorescent Lamp End-of-life Environmental Protection Agency Exposure duration Exposure frequency Exposure time Extended Producer Responsibility General Agency of Specialized Inspection Gross domestic product Hazard quotient Household hazardous waste Inhalation rate Interstate Mercury Education and Reduction Clearinghouse Japan International Cooperation Agency Lead acid battery Liquid Crystal Display Lowest-Observed-Adverse-Effect Levels Minimum response level Municipal Solid Waste No-Observed-Adverse-Effect Levels Non-governmental organization Non-profit organization

8 OERR OECD PC PCA PRO PbB RfC RoHS SENS TPL UB UF UNEP WEEE WHO Office of Emergency and Remedial Response Organization for Economic Co-operation and Development Personal Computer Paint Care Association Producer Responsibility Organization Blood Lead Reference concentration Restriction of Hazardous Substances Sustainability Expertise Network Solution Toxicology Profile for Lead Ulaanbaatar Uncertainty Factor United Nations Environment Programme Waste Electrical and Electronic Equipment World Health Organization viii

9 Chapter 1 INTRODUCTION 1 Because of the rapid increase in population in developing countries, appropriate solid waste disposal is needed. This will both protect residents` health and upgrade a city s sanitation and hygiene. For those cities that use incineration without air control equipment as a final waste disposal option, air quality of the cities will be polluted significantly. Thus solid waste management has become a crucial problem especially in developing countries in recent years. According to East Asia and Pacific Region of World Bank (What a Waste: Solid Waste Management in Asia, 1999), The urban areas of Asia produce about 760,000 tons of municipal solid waste per day. In 2025, this figure will increase to 1.8 million tons of waste per day, or 5.2 million cubic meter per day. This data shows how dramatically the solid waste generation is increasing in cities in developing countries. Table 1 shows that waste generation in urban areas will be doubled by (The World Bank, What a Waste: A Global Review of Solid Waste Management, 2012) Table 1. Urban waste generation by regions Region Urban waste (2012) Urban waste (2025) Africa 169,119 (t/d) 441,840 (t/d) East Asia and Pacific 738,9958 (t/d) 1,865,379 (t/d) OECD countries 1,566,286 (t/d) 1,742,417 (t/d) Latin America and the 437,545 (t/d) 728,492 (t/d) Caribbean region Therefore, to decrease the environmental burden, increase living conditions, save expenditures on unsophisticated disposal methods and resulting health problems, the developing countries have been working on how to create efficient municipal solid waste (MSW) treatments. Household hazardous waste (HHW) treatment in developing countries is the main issue in a municipal waste line because it contains potential hazardous chemicals, which will need advanced treatment and most of the countries burn it outside or dump it to open-sites. According to the U.S. EPA, HHW includes paints,

10 2 consumer electronic products, batteries, fluorescent bulbs, pesticides, etc. All these products can cause similar problems to industrial hazardous waste in the environment if there is enough accumulation or inappropriate treatment for the waste. HHW has been increasing in both developed and developing countries due to economic development and rapid urbanization in cities. For example, according to Baeyens (2010), Non-rechargeable batteries contribute up to 90% of the total battery consumption in Europe. For the paint and related products, it also could contain heavy metals such as cadmium, chromium, selenium, and lead. Paintcare (2012) states in the U.S., approximately 10% of paint sold in California is classified as leftover paint, which equaled 6 million gallons in 2010, with approximately 70% being latex paint. Figure 1 shows the increase in electronic waste from consumer and industrial usage in the U.S. (e-wasteregulation2, 2010). The same increasing pattern of personal and office computer ownership and use that is one of the main HHWs at the end of their life can be seen in developing countries. Fig 1. Trends of e-waste generated in the U.S. To prevent HHW pollution and human health effects, especially in developing countries, the waste policy, regulations, and standards have to be systematic. Also it should include responsibilities for consumers and producers as to how they will handle the post-consumer waste. According to the OECD report, the most developed and sustainable HHW management is the Extended Producer Responsibility (EPR) program, which requires producers to take all the physical and financial

11 3 responsibilities for their products` waste. However, in developing countries like Mongolia, it is anticipated that it will need municipality participation in the EPR policy for it to be effective. To assess the risk of inappropriate disposal of HHW, risk assessment can be used to analyze and characterize human and environmental health risks from toxic substances and other stressors. Overall, risk assessment can be divided into two groups: human health assessment and ecological risk analysis (U.S. EPA). In the EPA guidance, to assess human health risk, several steps are needed: Planning and scoping processes, Hazardous identification, Dose-Response, Exposure Assessment and Risk Characterization. This paper will focus on the potential and benefits from implementing the Extended Producer Responsibility policy framework for HHW management in a developing country, Mongolia, to identify human health risks from heavy metals in waste by analyzing exposure and risk assessment.

12 Chapter 2 HOUSEHOLD HAZARDOUS WASTE MANAGEMENT 4 Chapter 2 will introduce the key factors of developing the EPR policy, based on the OECD manual for governments. Then the chapter analyzes the EPR program implementation in developed regions/countries (the European Union, Germany, Japan, Swiss, and British Columbia in Canada) to develop lessons that can be used in developing countries to create their own EPR programs. Municipal solid and household hazardous waste management, and regulations in Ulaanbaatar (UB) city, Mongolia also are introduced in this chapter. Finally, the chapter will discuss EPR policy implementation in the city and its general framework, legislation, and operational management. Background Information of Extended Producer Responsibility program According to a guideline manual for governments on extended producer responsibility published by the OECD in 2001, a definition of EPR is an environmental policy approach in which a producer`s responsibility for a product is extended to the post-consumer stage of a product`s life cycle. In other words, the EPR program is the most sustainable waste management policy because it states a responsibility for producers to handle and treat the post-consumer waste of their products to prevent environmental pollution and human health risks due to the hazardous waste and toxic substances. Upstream and downstream waste management in the EPR policy is shown in Figure 2 (McKerlie, Knight, and Thorpe, 2006). Fig 2. Extended Producer Responsibility program Manufacture Recycled and raw materials Retail/Sale Recycling/ Reuse Waste collection Trasportation

13 5 Is the Extended Producer Responsibility program necessary? Due to rapid urbanization especially in developing countries, the amount of solid waste and household hazardous waste has been increasing; however, municipal waste management and treatment capacity are not able to handle the waste. The municipal revenue from taxpayers is not enough because of increased waste loading; therefore, it needs to be funded by outside investment/non-tax revenue. Thus, to meet the demand, there will be a need for a new waste management policy to reduce the municipality s burden physically and financially (OECD, 2001). In 1994, the OECD began working and developing the EPR framework and the member countries initiated implementation of the approaches in their national level policy (OECD, 2014). Since then, the number of waste and environmental policies that have adopted the EPR program has been increasing around the world. Figure 3 shows an increasing trend of EPR program adoption (OECD, 2014). Fig 3. EPR program adoption A Guidance Manual for Governments on Extended Producer Responsibility In the manual (OECD, 2001), the governmental EPR framework and individual participant`s responsibilities, cost and benefits are written in detail. The main concerns that the EPR program has to answer are increasing collection and recycling rates, producer`s financial responsibility, and improvement of product design to consider the environmental impact. Further broader categories for designing an EPR framework would include (OECD, 2014): Product take-back process:

14 6 This program requires manufacturers to take back their products after usage and it can be through retailers or contractors that are paid by producers. Sometimes, to increase the collection and recycling rate, different kinds of incentives can be given to consumers for bringing back the post-consumer products (OECD, 2014). If the producers have to meet targets for collection and recycling, the operation will be more efficient in order to meet the target. Market-based instrument: The EPR program should be economically beneficial to each party: private industry, communities, and government authorities. For instance, deposit-refund programs, advanced disposal fees (ADF), and natural material taxes can be incentives for stakeholders. 1. Deposit-refund programs: In the OECD guideline (2001), the deposit-refund system is defined as a program where a payment (deposit) is made when the product is purchased and is fully or partially refunded when the product is returned to a dealer or specialized treatment facility. Retailers return the deposit when they receive the same brand which they sell. It seems that a higher deposit price encourages a higher return rate (OECD, 1994). 2. Advanced disposal fees (ADF): According to the OECD guidance (2001), an advanced disposal fee would be a fee levied on certain products or product groups based on estimated costs of collection and treatment methods. Government, a private industry, or a Producer Responsibility Organization (PRO) could collect the fee; however, it should be clarified in the planning of the EPR program. Even though some OECD member countries have ADFs at the point of sale, they have a system to return a portion of the fee due to reduction of recycling fees for the products (OECD, 2001). 3. Virgin material taxes: The goal of the material tax is to increase recycled material usage and reducing the virgin material proportion in the products. Also, a special tax can be levied on potential hazards and toxic materials to encourage reducing environmental pollution (OECD, 2001). The revenue from these taxes

15 7 would be used for waste collection, treatment, and the cost for managing the system. Regulations and standards: The EPR program can be mandatory or voluntary based on the country`s economic growth, infrastructure, and socio-cultural situation, including residents` education and public support. Voluntary programs can be established between industries and public authorities or private sectors and non-governmental organizations (NGOs). Some countries in the EU have a target percentage for several post-consumer waste categories to be recycled and minimum recycled content requirements for paper products, beverage bottles, and plastic containers (OECD, 2001). Information-based instruments: Public awareness for environmental policies and human health effects due to pollutants is important to implement the EPR program successfully on the national level. Therefore, to raise this awareness, producers annual reports of recycled rates, clear labels for the products having a potential hazard to humans and the environment, waste separation reports, communication between producers and consumers, and the rate of second hand or recycled materials usage in products can be strong measurements for producers to comply with EPR policy. The OECD Global forum on environment (2014) stated several important factors are necessary to develop the EPR program. Based on different factors/targets, the program`s outcome will be various. Type of product The program covers only one product such as televisions and car batteries or a group of products like any electronic waste or used vehicle oil. According to the OECD (2014), small electronic waste is easily covered by an EPR program. Voluntary or Mandatory Whether the EPR program can be voluntary or mandatory is based on agreement between government authorities and private sectors. If the producers are willing to participate the program, it may not be necessary to legislate the EPR policy. A voluntary EPR program can be referred to as a Stewardship program (OECD, 2014). Nicol and Thompson (2007) stated the Product Stewardship program is a shared responsibility system; therefore, producers do not have financial and physical

16 8 responsibility of post-consumer waste for disposal and treatment. They argue that the policy fails to prevent pollution from waste and reduce consumption. Operation of waste management The manufacturer could handle the collection and recycling process individually or producers could establish a PRO that is funded by member producers based on their products` recycling methods, hazardous substance content, and weight. The organization acts on behalf of their member manufacturers; therefore, PROs could collect and recycle post-consumer waste (OECD, 2014). More than 260 PROs were established in Europe in between 1998 and 2007 (Mayers, 2007). Financial or Organizational responsibility At the global forum (OECD, 2014), it stated the producers could select the financial or organizational responsibility for their products` waste management. 1. Financial responsibility: Producers or PROs pay municipalities annually for handling the post-consumer waste. Recycling and collection could be treated by specific contractors or municipalities. 2. Organizational responsibility: Producers or PROs finance and operate waste management and treatment or contract with recyclers directly. Responsibility among stakeholders: The goal of the EPR program is to shift the responsibility for waste management from municipalities to manufacturers. However, in most countries, municipalities are still in charge of the collection and sorting due to their capability. The municipality has sufficient storage and infrastructure to handle waste. Once post-consumer waste is sorted, then it is transferred to the manufacturers for recycling treatment. Different countries have various responsibilities for stakeholders; however, even for consumers, the responsibility should be clarified. For instance, in Japan, final consumers are in charge of separating their waste and paying a recycling fee for electronic wastes: television, washing machine, etc. (OECD, 2014). Cost for full operation: The main concern is how to calculate the full cost of end-of-life coverage and how much the producers should cover fees for handling waste. The OECD manual (2001) discusses the full cost including collection, sorting, recycling, awareness campaigns, public advertisement, monitoring, and reporting. For the small businesses and

17 importers, the full cost of waste management and operation will be a burden, so it needs to discussed and defined clearly in the EPR context. Free riders, orphan and existing products In the guideline, free riders are defined as the actors in EPR system who do not pay for the benefits they receive (OECD, 2001). If the product`s producer has gone bankrupt or does not exist anymore, the product is an orphan product. Existing products also were produced before the EPR policy was implemented. All these products obtain advantages that are not regulated under the EPR program, which can make a negative impact on the system. According to the OECD manual (2001), peer pressure, monitoring, reporting, and sanctions can be tools for avoiding free riders. Moreover, government authorities would make standards and rules for minimizing and eliminating them. Management of the orphan and existing products depends on cost of waste treatment, recycling methods, and the numbers of products that are in the market (OECD, 2001). Based on the above several factors, examples of different types of approaches for development of the EPR program are shown in Table 2 (OECD, 2001). Table 2. Factors to develop the EPR policy Take-back program Legislations Economic approaches Factors 1. Mandatory 2. Voluntary 1. Target percentage for recycling 2. Disposal bans 3. Prohibition for hazardous substances 4. Usage of recycled material 1. Deposit-refund 2. Advance recycling fees 3. End of life fees 4. Natural material taxes The EPR program implementation in developed countries European Union and Germany Under the EPR policy, the European Union`s waste management has been leading the world in sustainable management and reduced environmental burden. The main legislations are: End-of-life Vehicles Directive, Packaging and Packaging Waste Directive, Waste Electrical and Electronic Equipment (WEEE) Directive, and 9

18 10 Restriction of Hazardous Substances (RoHS) (McKerlie, Knight, and Thorpe, 2006). According to the WEEE Directive (2003), member countries` manufacturers have to take responsibility for all costs of collection, sorting, recycling, reusing, and disposal stages for the products` post-consumer waste. This system leads to innovative recyclable designs for the products in early manufacturing stages (McKerlie et al, 2006). Moreover, the Directive reduces the amount of e-waste going to landfills and incinerators by promoting the recycled material proportion and the target-recycling rate. Overall, European countries have around 114 PROs for packaging waste management, 17 PROs for batteries` end-of-life disposal, and 129 WEEE PROs (Mayers, 2007), which indicates the PRO system is well developed financially and operationally. Table 3 illustrates the EU classification of WEEE and its labeling information (Khetriwal, Kraeuchi and Widmer, 2009; Nnorom and Osibajo, 2008). Table 3. The EU classification of e-waste WEEE Category Special label 1. Large home appliances Large HH 2. Small home appliances Small HH 3. IT and telecommunication equipment ICT 4. Consumer equipment CE 5. Lighting equipment Lighting 6. Electronic tools E&E tools 7. Toys and sports equipment Toys 8. Medical devices Medical equipment 9. Monitoring and control instruments M&C 10. Automatic dispensers Dispensers The RoHS Directive was initiated in 2002 and began in July It limits six potential hazardous substances: lead, mercury, cadmium, hexavalent chromium, two flame retardants added to plastics: polybrominated diphenyl ethers and polybrominated biphenyls in order to prevent their use in electronic products ranging from small electric toys to washing machines (McKerlie et al, 2006; Kahhat et al, 2008; Sthiannopkao and Wong, 2013). The European Directives have had a significant impact on the international electronic market by requiring producers to

19 11 redesign products with fewer hazardous materials and in preparation for easy recycling and dismantling processes. The Green Dot program for packaging waste is the first and largest EPR program in Germany and the EU. According to the program, every producer of packaged products is required to establish their own take-back program or participate in PRO: Duales System Deutschland (McKerlie et al, 2006). Member manufacturers have to pay an annual fee to use the eco-label that indicates that there is a free collection program. This program and labeling make it easy to notice and convenient for consumers. The fees are different based on the material and weight of products; for instance, tin or paper products have low fees because they are made of highly recyclable materials (McKerlie et al, 2006). In total, Germany has eight PROs for packaging waste, three PROs for end-of-life of batteries, and twenty PROs for WEEE management (Mayers, 2007). McKerlie et al (2006) concluded that the Green Dot program for packaging waste has resulted in more efficient recycling package design and waste reduction to final disposal. Switzerland The European Union`s WEEE Directive was legislated in 2003; however, the Swiss have had take-back e-waste legislation since 1998 (Khetriwal et al, 2009). The largest two PROs: SWICO Recycling Guarantee and SENS Swiss Foundation for Waste Management collect and dispose of waste for their member producers and importers. Figure 4 shows the recycled material from WEEE under the two PROs: SENS and SWICO (Widmer et al, 2005). Fig 4. Recycled material components from e-waste

20 12 In 2007, four PROs in Switzerland that are all non profit organizations (NPOs) treat most of the e-waste from households to offices, including the categories 1-5, 6, and 7 of the EU classification of WEEE (Table 2). Consumers are obligated to return used products to retailers or collectors and to pay the advanced recycling fee (ARF) for newly purchased products. Therefore, there should be less illegal electronic waste dumping because no disposal fees need to be paid in the post-consumer stage. According to Khetriwal et al (2009), the recycling fee paid by consumers is calculated by two methods: product price index (SWICO) and six different fee categories (SENS). Under the Swiss law, retailers should inform consumers that the price includes the ARF; moreover, PROs recommend putting a visible recycling fee to raise awareness about recycling in the end-of-life stage. The ARF is collected from consumers, manufacturers, and importers to PROs to fund collection, transport, storage, dismantling and recycling of disposed products. Figure 5 shows the electronic waste EPR system in Switzerland (Khetriwal et al, 2009). Fig 5. E-waste management in Switzerland Japan: In 1998, the Japanese government enacted the Home Appliance Recycling Law and implemented it nationwide in Under the law, producers and importers are responsible for managing the recycling of four types of home appliance: televisions, refrigerators, washing machines, and air conditioners (Kahhat et al, 2008). The last consumers are obligated to pay a part of the fee for recycling, transportation and to sort the appliance from municipal waste. The end-of-life fee is based on the

21 type of products and is around US $23-44 for recycling processes and US $4-18 for transportation (Ogushi and Kandlikar, 2007). The main disadvantage of the end-oflife (EOL) fee paid in the disposal stage is that it could increase illegal dumping. Around 2 percent of EOL home appliances (172,000 units) were illegally discharged in 2004 and it is higher than illegal dumping in 2001 (Ogushi and Kandlikar, 2007). Mostly municipalities are in charge of collecting and transferring the end-of-life electronic products, but the individual sector`s role in collecting e-waste has been increasing. The Association for Electric Home Appliances of Japan handles orphan products (Nnorom and Osibanjo, 2008). In 2001, Japan legislated the Law for Promotion of Effective Resource Utilization to cover used computers from the business sector and individual consumers. A Personal Computer (PC) 3R (Reduce, Reuse, Recycle) Promotion center was established by manufacturers to collect and recycle PCs sold after Oct PCs covered by the program have a PC Recycling Mark to indicate a nonrefundable recycling fee and the payment is paid at the point of sale. However, for the computers sold before Oct 2003, the final consumers need to pay recycling and collection fees of products (Kahhat et al, 2008). In 2004, at the G8 Summit, Japan introduced the 3R program to the international stage to promote sustainable waste management (Sthiannopkao and Wong, 2013). The program prioritizes reducing the waste generation at source points, reusing valuable materials from products, and recycling materials from waste for different purposes. The End of Life Vehicle Recycling Law requires the customer to pay a recycling fee at the time of the new car purchase (Ogushi and Kandlikar, 2007) to prevent illegal disposal. Under the EPR policy, the success of the Japanese recycling process is due to environmentally focused development in the manufacturing stage and central recycling factories around the country. Table 4 shows the main waste management laws in Japan (Ogushi and Kandlikar, 2007). Table 4. Japanese waste management laws Law Content Year enforced Fundamental Law for Products are need to be 2001 Establishing a Sound recycled Material Cycle Society Recovery rate (Fiscal yr) 13

22 Waste Management Law Law for Promotion of Effective Utilization of Resources Containers and Packaging Recycling Law Home Appliance Recycling Law Required 3R program in 10 industries and 96 products Desktop PCs Laptop PCs Cathode ray tube Liquid crystal display Ni-Cd batteries Ni-MH batteries Li ion rechargeable batteries Small lead batteries Cans, bottles, cartons and boxes Air conditioners Televisions Refrigerators and freezers Washing machines (2005) 54 (2005) 78 (2005) 68 (2005) 74 (2004) 77 (2004) 55 (2004) (2004) (2005) 77 (2005) 66 (2005) 75 (2005) Food recycling Law Food waste (2004) Construction Material Recycling Law Concrete Wood (2002) 89 (2002) End of Life Vehicle (EOL) Recycling Law Asphalt 99 (2002) EOL vehicles (2005) 14 British Columbia, Canada: The British Columbia (BC) government started developing a municipal waste management plan in 1989 and the strategy was approved in The main goal of the plan was to prevent pollution from household hazardous waste such as paints, pesticides, and batteries (Driedger, 2002). In 1994, the Waste Reduction Commissioner required manufacturers and producers to take back and recycle the eight HHW; therefore, the producers of paints and related products established the BC Paint Care Association (PCA) to treat and dispose of used paints. The manufacturers need to pay an eco-fee (C$0.50/4L container and C$0.10/aerosol container) to the PCA for the collection, recycling, and final disposal (Driedger, 2002). Similar to the paint treatment system, the EPR program for HHW such as hazardous pharmaceuticals, drugs, pesticides, and automobile oil products has been expanding significantly. Due to the successful closed-loop waste management system in BC Canada, the recovery rate on household waste is more than 70 percent. Figure 6

23 15 illustrates the recovery rate for some common household wastes: containers, car batteries, tires etc. (McKerlie, 2006). Fig 6. The recovery rate for some household wastes 120% 100% Recovery rate 80% 60% 40% 96% 91% 75% 99% 96% 20% 0% beer containers wine and spirit containers non- alcohol beverage containers car batteries tires The unique feature for the membership fee system in the Paint and Product Care Association is that the fee is based on producer`s market share capacity (Driedger, 2002). This can be a useful approach for the small manufacturers and importers to collect a fee, plus there is a potential reduction in the number of free riders and orphan products. The eco-fee paid by consumers is not a federal tax in Canada, so the fee is a part of the price charged by the manufacturers and retained by the manufacturers. This requires the manufacturers to highlight the reasons for and uses of the eco-fee. Municipal solid waste and household hazardous waste management and treatment in Ulaanbaatar city, Mongolia Municipal solid waste Between 2006 and 2010, a new landfill plant funded by Japan International Cooperation Agency (JICA) was built in UB city to treat municipal solid waste. The city has five waste treatment centers and population is approximately 1372 (National Plan for Waste Management Improvement, 2014 and Statistics Department of Ulaanbaatar city, 2014). However, open dumping of waste from construction and open burning of household solid wastes are common nationwide. General consumption also has been increased due to mining sector development and foreign investment; for example, in 2011 the percent from the previous year was increased 8.9

24 16 percent for imported chemical substances, 28.6 percent for office equipment and electronic products, 28.1 percent for vehicle batteries and tires, and 71.8 percent for secondhand vehicles (National Plan for Waste Management Improvement, 2014). Due to an overwhelmed waste generation and treatment system in UB city, in 2012, the Mongolian government passed a new waste law that includes municipal solid waste, industrial waste, and hazardous waste (Waste Law, 2012). According to the law, each city`s authority is responsible for collecting only municipal waste that is generated within its territory and treating the disposed waste in a centralized waste facility. For industrial waste and hazardous waste, manufacturers are required by the law to transport waste to the centralized treatment facility and to pay a fee for the final disposal. The fee depends on the weight and hazardous components of the waste (Waste Law, 2012). The budget for MSW treatment consists of mostly tax revenue and the disposal service fee from industries. Therefore, there has been a huge burden on the municipality to handle both consumer and industrial waste given the small budget for waste treatment. According to the final JICA report for waste management improvement in UB city (2012), the MSW facility, the preferred option for household waste disposal, has high emissions of pollutant gases, and increased risks for both human health and environment. The amount of waste generated in the city is shown in following Table 5 (Final JICA report, 2012). Table 5. Annual municipal waste generation in Ulaanbaatar city, 2012 Household waste generation (ton/day) Waste from business activities (ton/day) Waste from public cleaning (ton/day) 31.8 Total (ton/day) Due to the rapid movement of people from the countryside to the city and the construction boom in the capital city, the annual amount of waste likely has increased since For instance, in 2009 the amount of annual solid waste was 820,000 tons at the national level; in 2013 the amount was up to 2.4 million tons (National Plan for Waste Management Improvement, 2014). Under the National Plan (2014), the waste improvement strategy is going to be implemented in two phases.

25 17 1. The first phase ( ): To develop the legal environment for waste reduction, management improvement, infrastructural and financial enhancement, and community participation in waste reduction activity 2. The second phase ( ) To strengthen environmental remediation, green products usage, and systematic waste management Household hazardous waste According to the Waste Law (2012), hazardous waste is the waste that has negative impacts on humans, animals, plants, and their descendants, is hazardous, corrosive, flammable, explosive, contagious, radioactive, pollutes the environment and can be solid, liquid, and gas state. In the law, the hazardous waste from industries has to be separated from MSW and treated in a facility that has advanced technologies to reduce the hazard. Once treated, the waste can be transferred in landfills (Waste Law, 2012). However, the law does not legislate what is household hazardous waste (HHW) and whether it is included in the definition of hazardous waste or not. Since there is no legislation on HHW, the city has no segregation and sorting programs for any HHW from municipal solid waste. Therefore, the UB city municipality has no specific data on the annual HHW generation. In the U.S., according to the EPA, regarding wastes generated by households and household-like areas, Leftover products that contain corrosive, toxic, ignitable, or reactive ingredients are considered to be household hazardous waste. Therefore, HHW could be consumer electronic waste, old solvents, oil-based paints, batteries, pesticides, fertilizers, or fluorescent lamps. In addition, medical sharps, pharmaceuticals and poisons from households can contain toxic substances and heavy metals (EPA, Non-hazardous waste report). Unlike Mongolia, the EPA specifies these wastes as HHW. Under the Waste Law (2012), there is no specific recycling target for HHW and municipal solid waste and it states recycling and reusing processes are recommended if producers are willing to do it. It is not a mandatory program;

26 18 therefore, manufacturers and importers have no incentive to recycle their products` post-consumer waste. WEEE contains potential hazardous heavy metals such as lead, mercury, cadmium, and nickel; reusing and recycling the rare metals from e-waste would reduce energy requirements for natural resource extraction and processing of crude materials. According to Widmer et al (2005), 40 percent of consumer personal computers end up in landfill and heavy metals from e-waste are 70 percent of the total heavy metals in the U.S. landfills. Figure 7 illustrates the material compositions in e- waste (Widmer et al, 2005). Fig 7. Electronic waste compositions by weight As shown in Figure 5, e-waste weight contains more than 50 percent metals, including both ferrous and non-ferrous metals that could be recycled. The final JICA report (2012) mentioned there are a few small e-waste recycling businesses in the city; however, the recovery rate is only about 20 percent of e-waste generated. For example, sometime individuals usually go to a computer shopping center to sell broken personal computers or to purchase secondhand computers or recycled one. In 2002, a new guideline for the medical waste separation, collection, storage, transportation and final disposal was legislated by the Ministry of Health and the Ministry of Environment of Mongolia. Under the law, the specific medical waste includes blood from humans and animals during medical treatment, medicine and related products, bioactive and radioactive products, syringes, and medical equipment (Enactment 249/201, Ministers of the Ministry of Health and the Ministry of Environment, 2002). The enactment (249/201, 2002) states the specific medical waste

27 19 from national hospitals funded by the government is collected, stored, and treated by tax revenue. However, waste from medicine and related products` in individual households are not included in the law; therefore, pharmaceutical and medical waste is mixed with municipal solid waste. The list below shows the situation and resulting problems of HHW management in UB city: No specific HHW management and policy exists in UB city HHW is treated in the municipal solid waste facility There is no advanced technology in MSW treatment The primary treatment is incineration without controls After incomplete incineration, the waste mostly goes into landfills Mongolia has specific laws, rules, and standards for industrial hazardous waste management; however, there has been a lack of regulation for HHW and less monitoring for industrial hazardous waste treatment. Due to not having advanced air control technologies and landfill leachate systems in MSW treatment, the potential hazard for human health is increased dramatically. General EPR policy framework in developing countries: Ulaanbaatar city, Mongolia Due to a variety of including cost benefit, restrictive regulation, and a lack of recycling infrastructure, most of the waste such as e-waste, used tires and plastic waste is transported from developed countries to China, India, Pakistan, and Nigeria to final disposal (Schiannopkao and Wong, 2013). These waste-importing countries may not have systematic waste regulations or advanced treatments; therefore, treatment in these countries likely results in increased industrial pollution. For example, open burning of coated fires, heating of printed circuit boards to remove IC chips, and acid baths for extracting gold are well known in China (Kojima et al, 2009). Table 6 shows the amount of e-waste is exported and imported (Schiannopkao and Wong, 2013). Table 6. E-waste export and import Countries Household waste Exported Imported or region (millions of tons) (millions of tons) (millions of tons)

28 20 USA EU Japan China India As seen in Table 6, there is no imported waste in developed countries; thus, importing countries need to develop hazardous waste regulations and standards for preventing human health risks caused by e-waste pollution. Legislation and restriction Since Mongolia has no legislations/regulations or classifications on HHW and less monitoring of industrial hazardous waste treatment, the government needs to initiate classifying, regulating, and developing the EPR policy for hazardous waste collection and treatment from consumers and manufacturers. Kaffine and O`Reilly (2013) concluded the EPR program is suitable for consumers` e-waste, automobile batteries, packaging, and tires. Figure 8 illustrates the products are covered by the EPR policy in globally (Kaffine and O`Reilly, 2013). Fig 8. EPR policy by product types 20% E- waste 35% Vehicle batteries 17% Tires Packaging 17% 11% Other The other (20%) includes used oil, paints and related products, and pesticides (Kaffine and O`Reilly, 2013). Mongolia could implement the EPR policy for e-waste and automobile batteries, since both e-waste and imported vehicle parts such as batteries has been increasing. In terms of developing the EPR program for hazardous waste, the scope of the program, a consensus goal and target, objectives and

29 21 responsibilities must be determined clearly and understandably for each actor (OECD guideline, 2001). Otherwise, there will be misunderstandings between government agencies and producers; for instance, Brazil has faced many difficulties: less supportive legislations and confusion on prohibition of imported tires to implement the EPR policy for used tires (Milanes and Buhrs, 2009). After the EU`s countries, Japan, Canada, and Switzerland successfully implemented the EPR program for their waste management, some developing countries are trying to embrace this policy. One of the biggest recycling countries, China, has legislated the management of waste household electrical and electronic products recycling and disposal with its content being both mandatory recycling of WEEE: TV sets, refrigerators, washing machines, air conditioners, and personal computers under the EPR policy, and certifying second hand products and recyclers (Kojima, Yoshida, and Sasaki, 2009, Hicks, Dietmar and Eugster, 2005). Another effective legislation in China is management measure for the prevention of pollution from electronic products. The law restricts toxic substances from products, requires labeling for hazardous materials, and promotes green products. (Hicks et al, 2005). These restrictions are established in the EU RoHS and the WEEE Directive in terms of hazardous substance restrictions and e-waste disposal. The following are the six toxic chemicals for which China restricted usage in electronic products: Lead, mercury, chromium IV, cadmium, polybrominated biphenyls and polybrominated diphenyl ethers (Hicks et al, 2005). Not only China but also several countries such as Japan, Taiwan, South Korea, and Brazil developed their EPR policy based on the EU WEEE Directive and RoHS; therefore, these regulations could be valuable information and an important guideline for Mongolia to implement the EPR policy at national level. Most electronic products and automobile related products or second hand vehicles are imported to Mongolia from China and Japan, respectively. Therefore, under the hazardous component restriction of an EPR program, imported appliances are easy to monitor, control, and ban through the custom office. Moreover, a tax increase on imported products could be established based on the proportion of hazardous substances and recyclable content to encourage usage of less environmental impactful products. Mandatory EPR program

30 22 Similar to other developing countries, Mongolia has many small importers and family businesses, plus a few big importing companies; thus it can be seen the market is not mature and most producers and importers likely will not be willing to comply with a voluntary EPR policy due to the cost for collection, recycling, and final disposal. Therefore, there should be the government involvement in the EPR program as it relates to electronic product and automobile battery importers. According to the OECD seminar on EPR in France in 2001, under the mandatory program, the free rider problem is going to decrease, and higher collection and recycling rates are more achievable compared to the voluntary program. Moreover setting a collection target is an effective way to meeting the target; for example, in Belgium this way has increased collector`s responsibility for batteries under the mandatory EPR program (OECD seminar, 2001). In the voluntary EPR policy, there have been free rider issues caused by non-participating producers and the competitive disadvantages for member companies compared to the non-participants. Furthermore, several benefits of the mandatory EPR program run by the government (OECD guideline, 2001, Nnorom and Osibanjo, 2008) include the following: Eliminating hazardous substances and improving Designed for the Environment products Clarifying the producer`s financial responsibility Implementing EPR supportive policies Raising awareness of the policy Establishing mandatory targets for the collection and recycling to promote technological innovations It could be both more flexible and time consuming for waste compliance and permission if the EPR program is mandatory because city authorities and different government agencies have a consensus national regulation and rule that are easily spread throughout the country. This leads to less confusion between the government and producers. Mayers (2007) mentioned that if there are no targets and specified treatment requirements, the policy does not send a direct and clear signal to manufacturers. For example, it should clarify in the WEEE Directive what kind of separation treatment would need to be used if LCD backlights contain mercury (Mayers, 2007). Therefore,

31 23 under the mandatory EPR program, the government could provide general treatment requirements, standards, and specific methods for recycling and final disposal in order to increase efficiency and reduce company investment in treatment. A guidance document or manual can be discussed and developed between producers and government agencies to satisfy both party`s demands. Producer Responsibility Organization: In terms of post-consumer waste treatment, individual producers and importers are not able to handle all the required processing in Mongolia due to a lack of technical equipment, qualified employees, and an efficient collection system. The same situation is occurring in China and other developing countries, where individual collection and treatment systems are not feasible (Nnorom and Osibanjo, 2008). Therefore, PROs become an integral part of the EPR program in these locations because they can address these limitations. Also, PROs can treat a broader type of products than individual manufacturers, especially when those individual manufacturers/processors are small family businesses. Finally, the PRO can save time and reduce the cost of recycling and final disposal (Spicer and Johnson, 2004). Therefore, the EPR policy would require all the actors to join a PRO that is funded by a member companies` annual fee. The fee should be based on their market share, products` size, weight, and hazardous substances, because a flat fee does not promote waste reduction in general and a gap between small businesses and larger group companies is expanding in Mongolia. Further, the flat fee penalizes the companies that improved their products in relation to their environmental impact. These producers in a PRO are not going to receive any financial benefits from the EPR program (McKerlie et al, 2006). In developed countries such as Japan, Germany, and Switzerland, most of PRO activities are fully dependent on participating company`s funds and recycling fees from consumers; however, in Mongolia, this system may not work successfully. The recycling fees paid by consumers are a particular challenge. Consumers are unlikely to accept the rule since the country`s GDP per capita (US $11, in 2014) is much lower than the European countries (GDP per capita US $32,789 in Dec 2014) (Trading economics). Therefore, in a developing country like Mongolia, using the advanced recycling fee and the end-of-life fee from consumers could be

32 24 challenging if they are the only revenue sources to fund a PRO. Moreover, e-waste may be disposed to informal recycling factories since it has valuable metals and is useful for reuse in secondhand electronic products. For the above the reasons, the PRO operation requires municipal participation, especially in waste collection and transportation, because the municipality already has the collection operation and the PRO likely does not have the funding to establish a second collection and transport system. Since UB city`s municipality has waste storage locations, developed transportation and collection system, and waste return locations, incorporating the municipality into the EPR program will reduce costs for building infrastructure. In fact, in some countries such as the United Kingdom, China, and Taiwan, a local municipality is responsible for the collection, separation, and transportation of HHW (He et al., 2006, Nnorom and Osibanjo, 2008). Further, the Ulaanbaatar city authority could allow PROs to use disposal facilities and collection centers for recycling, which gives producers and importers a feasible management location for waste treatment. Therefore, unlike other developing country`s cases, PROs (producer and importers) would be responsible for only recycling and final disposal. For the recycling processes, PROs would need to cooperate with informal small recycling businesses to develop efficient waste treatment. This is because the secondhand products especially used tires, vehicles, and personal computers are still valuable in the market; therefore, many small familyowned companies have been operating in the city. These small businesses must be included in the PRO because the technologies used in this informal recycling sector are not environmentally friendly and not meeting with the country`s standards. The PROs could provide the International Organization and Standardization standard technologies and advanced equipment for recycling. In terms of the waste handling processes, PROs should not have brand-specific rules in a developing country like Mongolia because the market itself is small comparing with developed countries and there is not enough fund for each brand`s post-consumer waste, especially personal computers, televisions, and refrigerators. Under the full industry-responsible EPR waste management program, there is a direct feedback loop from the recycling processes to the manufacturing or product design phases. This could allow designers to change product`s recyclability and to use

33 25 alternative materials. On the other hand, in the PRO system, especially one not focused on specific brands, there is no direct feedback loop and feedback from PROs may not be an effective influence on a product design (OECD, 2001, Spicer and Johnson, 2004). To avoid this problem, PROs should report regularly to manufacturers and importers to discuss improvement of a material design and alternative importing products that are more recyclable and/or that have less environmental impacts. A brief potential structure of cooperation of a PRO and the municipality in Mongolia is shown in Figure 9. Fig 9. PROs and municipal participation in the EPR program (Mongolia) Monitoring by a third party The OECD guidance (2001) stated the EPR program has to be monitored and reported by a third party to improve quality and efficiency. One of the key reasons for the successful EPR policy in Canada is that it addresses needs, evaluates performances, and tracks operations. In British Columbia, an annual audited report including recovery rate, revenues, and cost is submitted by the third party (Driedger, 2002), which means there will be no outside pressure. In Mongolia, the General Agency of Specialized Inspection (GASI) is in charge of overall inspections, risk assessment of health, and occupational safety. Therefore, the third party could be the GASI or a NPO. In Mongolia, the importance of having the third party in the EPR system is to monitor PRO operations and treatment technologies, and to report to the

34 26 customs office about more suitable imported products having less hazardous substances. Based on the valuable feedback from the third party, the national guideline for imported products under the EPR policy will be improved with the needs for different stakeholders being clearly addressed. Monitoring both the sale of products as well as HHW in treatment facilities is one of the effective ways of determining the EPR policy achievement (Driedger, 2002). Awareness of the EPR policy Increasing the number of recycled products and materials in the market is essential in order to achieve the EPR program goals. The market-driven program is only effective for highly valuable recovered material; however, there is less valuable material that has a high environmental impact. Therefore, some level of government intervention is needed for increasing the use of recycled materials. In China, the Government Procurement Law was legislated and implemented in 2003 to promote purchasing and using green products in all government agencies. According to this law, the purchased products must meet Chinese environmental protection standards (Qiao and Wang, 2007). Table 7 shows energy saving by using recycled materials instead of raw materials (Nnorom and Osibanjo, 2008). Table 7. Energy saving from recycled materials Material Energy saving (%) Aluminum 95 Copper 85 Plastic >80 Iron and steel 74 Lead 65 Paper 64 Zinc 60 One of the ways of improving consumer awareness in HHW is by producers labeling their products based on hazardous components and recycled material proportions. The labels on hazardous components in products should include information about potential toxicity and requirements for specific treatment. This will raise consumer awareness of hazardous waste collection, recycling, and treatment. For

35 27 instance, under the EU Battery Directive, all batteries containing hazardous chemicals are required to be labeled with crossed-out wheelie bin and chemical symbols (Mayers, 2007). Figure 10 shows the labels (Energizer, 2009). Moreover, this label on products can be a tool for promotion of green purchases. The labels and advertisements are producer`s responsibilities and the campaigns could be funded by PROs. Fig10. EU Battery Directive (labels) Another way to increase consumer awareness of green products is environmental education in public schools and advertising of green purchases through television, radio, and newspaper. In Mongolia, the national broadcasting television and public radio stations funded by the government should campaign for new legislated policies and regulations, and against the environmental pollution caused by HHW and effects on human health. Moreover, if producers and importers comply with the EPR policy, the Mongolian National Broadcaster could advertise their products and services for free through its environmental programs, could promote companies` participation in the EPR program, and increase companies` social responsibility. In Japan, children in kindergarten learn how to sort PET into the proper trashcans. According to the elementary school curriculum in Mongolia (Minister enactment, A/311, the Ministry of Education and Science of Mongolia, 2013), a program about human interaction with the environment that extents until sixth grade. The program includes natural phenomenon, the earth and the solar systems, plant and fruit growths, forest, and atmospheric movement, etc. The program does not cover practical activities to increase environmental awareness; however, practical programs in the education system are necessary in both public and private elementary schools.

36 Chapter 3 MERCURY RISK ASSESSMENT 28 Chapter 3 will identify current disposal methods, typically incineration, for fluorescent bulbs containing elemental mercury in UB city. Given these disposal technologies and the estimated releases mercury from the disposal into the atmosphere, the risk of potential mercury exposure from municipal waste incineration will be analyzed. The human health risk characterization part will focus on only neurological risks for children by airborne exposure of elemental mercury vapor (inhalation). Mercury exposure from MSW incineration Mercury exposure from MSW incineration is from batteries such as Hg-Cd and Hg-Zn batteries, electric lighting such as fluorescent lamps and high intensity discharge lamps, and dental amalgam (Velzen, Langenkamp, and Herb, 2002). In 1990 in the U.S., 70 percent of all produced mercury could be found in the waste stream, which means tons of mercury was disposed per year. At that time, the total amount of MSW in the U.S. was around 200 million tons per year with 3-4 mg of mercury per kg waste (Velzen et al., 2002). According to Velzen et al (2002), mercury in MSW treatment in the U.S. between is illustrated in Table 8. Table 8. Mercury sources in MSW Batteries 67.3% Fluorescent lamps 9.0% Thermostats 8.7% Plastics 5.4% Latex paint residues 4.8% Miscellaneous 2.9% Food, paper 1.9% In 1996, the Mercury-Containing and Rechargeable Battery Management Act was enacted, which banned mercuric oxide batteries in the U.S.; since then, the

37 29 mercury component in the waste stream (7.12 ton in 2010) has been decreasing and non-mercury alternative batteries like alkaline manganese oxide batteries, alkaline batteries, lithium ion button cell batteries and silver oxide batteries have increased in market share (IMERC, Mercury use in Batteries, 2014). Li et al (2010) mentioned that in China, mercury batteries have been decreasing in use since 2001; however, 153 tons of mercury was used in batteries in Unlike mercury-containing batteries, the usage of fluorescent bulbs has been increasing globally in recent years because of their energy efficiency and reduced greenhouse gas emissions comparing with traditional incandescent lamps. In the U.S. and EU, there is a ban on incandescent on (Lim, Kang, Oguseitan, and Schoenung, 2013). The similar growing pattern of fluorescent lamp (FL) use can be seen in Ulaanbaatar city due to government promotion of FL usage in offices and public places. However, the energy-efficient compact FLs have a potential mercury exposure hazard. The mechanism of lighting up compact fluorescent lamps (CFL) can be described as the alternating current (AC) is used to make electrons collide with mercury atoms to release ultraviolet (UV) light, which is changed to visible light through the phosphor coating on the inside of the glass tube (Lim et al., 2013). A general structure of compact FLs is illustrated in following Figure 11 (Lim et al., 2013). Fig 11. Compact FL driver AC: Alternating current, EMI: Electromagnetic interface, IC: Integrated current

38 30 There have been the different amount of mercury and its amalgams in CFLs; for instance, Raposo and Roeser (2001) mentioned that the average amount of mercury per lamp is being reported as mg of Hg/lamp in Brazilian fluorescent lamp manufacturers. Based on their estimation, 1000 kg of Hg per year is released into the environment in Brazil due to mercury-containing used lamps (Raposo and Roeser, 2001). In the United States, according to the Association of Lighting and Mercury Recyclers, approximately 670 million fluorescent bulbs were disposed of or recycled in the United States in (EPA, Fluorescent Lamp Recycling, 2009). Due to an increase in usage of fluorescent lamps, in 2009 annually two to four tons of mercury from FLs is released into the atmosphere in the U.S. (EPA, Fluorescent Lamp Recycling, 2009). In China, approximately 200 tons of mercury is used in fluorescent lamps and thermometers in each year. Over 90 percent of mercury containing products end up in the MSW stream for treatment (Li et al., 2010). The amount of mercury in a lamp is based on lamp types (Linear or CFL), a brand, and wattage. Table 9 shows the amount of mercury in different kind of fluorescent lamps (Nance, Patterson, Willis, Foronda, and Dourson, 2012). Table 9. Mercury containing lamps Country or region Lamp type Mercury (mg/lamp) Europe Halophosphate lamps 10 Europe Triphosphate lamps 5-8 Canada Linear fluorescent tubes 3-50 USA Linear fluorescent tubes (a) (b) Australia CFL Canada CFL 1-25 United Kingdom CFL <10 USA CFL Avg. 4 USA CFL 5-50 (b) a: Culver, 2008, b: NEWMOA

39 31 Globally, the main forms of total mercury emission to the atmosphere are gaseous elemental mercury (53%) and divalent mercury (37%). Carpi (1996) states that, in general, percent of elemental mercury (Hg 0 ) and percent of divalent mercury (Hg II) result from coal combustion; and percent of Hg 0 and percent of Hg (II) result from municipal waste incineration. For instance, according to the EPA Emission Test Report (EPA/600/SR-93/181), the concentration of mercury in Camden county MSW stack is µg/m 3, all of which is divalent mercury. With the exhaust steam, elemental mercury reacts with HCl and Cl 2 or is oxidized into HgO. Increasing the temperature and the concentration of HCl and Cl 2 results in higher concentrations of oxidized mercury compounds and mercuric chloride (HgCl) (Carpi, 1996). HCl and Cl 2 are produced from chlorine-containing plastic products in waste stream. Studies in China showed that MSW incineration resulted in percent of mercury being in the fly ash (Zhou et al., 2015) and around 4 percent of the total mercury is in the bottom ash (Carpi, 1996). According to Zhou et al (2015), the average concentration of total mercury in fly ash from 15 different samples is 10 mg/kg; however, the total mercury in 7 samples from eastern China had a much higher than the average concentration (10 mg/kg). Zhou et al (2015) mentioned this is because rapid economic growth in that area led to an increase in mercury components in MSW. Table 9 shows different forms of mercury emissions from waste incineration in North America and Asia. As seen in Table 10, in both regions, divalent mercury emission in gas state is dominant (E. G. Pacyna and J. M. Pacyna, 2002). Table 10. Mercury emissions from waste incineration North America Asia Gaseous mercury (Hg 0 ) elemental 13.3 ton 6.5 ton Gaseous divalent mercury (Hg (II)) 39.5 ton 19.6 ton Particulate mercury 13.3 ton 6.5 ton

40 32 In UB city, FLs from offices and consumer usages are disposed into MSW stream. Based on different studies (Carpi, 1996, Zhou et al. 2015, E. G. Pacyna and J. M. Pacyna, 2002), gaseous elemental and divalent mercury in MSW fly ash is a major way for mercury to be released into the environment. Therefore this exposure is the main pathway in UB city; moreover, the city`s solid waste disposal methods are open burning or landfilling after incomplete incineration. Aucott et al (2003) estimated a typical broken fluorescent bulb containing approximately 20 mg of mercury releases 3-8 mg of mercury in two weeks. Moreover, they found during FLs final disposal and recycling processes approximately 1-80 percent of the total mercury is released from the bulbs (Aucott et al., 2003). Another study (Johnson et al., 2008) reported that the 13W FL released 30 percent (1.34mg) of the total amount of mercury in the bulb, and old lamps tend to release less mercury than a new one (Nance et al., 2012). Figure 12 shows the map of the former municipal landfill in UB city, which is close to residents and the location is 47 56'42"N '54"E (wikimapia). On the map, every white dot represents Mongolian traditional house that has a stove inside and it burns coal to heat the house in cold winter (average temperature in winter from -33.4C to -18.9C) (WeatherSpark, Average Weather for Ulaanbaatar, Mongolia). Fig 12. The former MSW facility

41 33 Figure 13 shows how close the former MSW facility is to the city (center of UB city coordination: 47 55'13"N '2"E). The facility was located in the northeast part of the city and up in the mountains. In the city, the annual average wind direction is from the northern side (23%) and the northwest side (16%) for a total of 39 percent, which means 61 percent of the annual wind comes from the northern side (WeatherSpark, Average Weather for Ulaanbaatar, Mongolia). Fig 13. The MSW facility location and the city center This landfill was overwhelmed with the waste load and was closed due to the amount of waste from consumers and industries and a lack of land for disposal. Even though it is closed currently, the main treatment for the waste is open burning and then disposal in a landfill. Based on the average amount of 20 mg mercury (Raposo and Roeser, 2001, Aucott et al., 2003) in a fluorescent lamp, the total amount of mercury in imported FLs into the country can be estimated. However, it is not possible to determine the amount of FLs in the city because the customs office manages and reports only the total amount of imported lamps nationwide. Therefore, the amount of FLs in UB city is estimated based on population, where at least half of the populace lives in the city. Because of urbanization and population in the capital city, this risk assessment assumes approximately 60 percent of the total FLs are used in UB city. Aucott, McLinden, and Winka (2003) showed that when the temperature is between 5-30 C, approximately 17-40% of the mercury is volatilized from a broken fluorescent lamp during a two-week period; therefore, open burning of FLs in the

42 34 MSW facility will accelerate gaseous mercury emission into atmosphere. Table 11 shows the total amount of FLs and of mercury released from FLs in the MSW treatment. Table 11. The amount of mercury released into the atmosphere Average imported FLs Mercury in the imported FLs Mercury into air released National yr 20mgHg = mg/yr 90% kg =116, kg/yr Ulaanbaatar city %= yr 20mgHg = mg/yr 90% kg = 69,637 kg/yr The elemental mercury vapor and divalent mercury exposure pathways are shown in Figure 14. As seen in the figure, the most of divalent mercury vapor is deposited in regional and local areas; therefore, residents who live near to the MSW incineration are at greater risk of developing detrimental health effects by inhalation of mercury vapors. Fig 14. The metallic mercury airborne exposure pathway

43 Hazard Identification 35 Physical and chemical properties of elemental mercury Mercury is a transition metal, so it has different valence electrons, which result in various complex compounds such as mercuric (II) chloride (HgCl 2 ) mercury (I) chloride (Hg 2 Cl 2 ), and mercuric (II) acetate (HgC 4 H 6 O 4 ) (Agency for Toxic Substances and Disease Registry (ASTDR), 1999). Since elemental and inorganic (metallic) mercury are the main forms inside FLs, this chapter and risk calculation will focus on only their characteristics. Elemental and divalent mercury`s physical and chemical properties are in Table 12 (ASTDR, 1999). Table 12. Physical and chemical properties of mercury Characteristic Mercury Mercuric (II) chloride Mercury (I) chloride Chemical formula Hg HgCl 2 Hg 2 Cl 2 EPA hazardous U151; D009 D009 No data waste Molecular weight Color Silver white (liquid White White metal) tin white (solid) Physical state Heavy, liquid metal Crystal, granule or Heavy powder, powder rhombic crystal Melting point C 277 C 302C Boiling point C 302 C 384C Odor Odorless Odorless Odorless Solubility in water 0.28µmoles/L at 1 g/35ml, g/100ml at 25 C 6.9g/100cc at 20 C 25 C Solubility in 2.7mg/pentane, 1g/3.8ml alcohol, Insoluble in organic solvents soluble in lipids 1g/200ml C6H6, alcohol, ether 1g/22ml ether 1g/12ml glycerol LogKow 5.95 No data No data

44 36 Vapor pressure Henry`s law constant at 24.8 C Degradation reaction rate constant mm Hg at 25 C 1mm Hg at 136 C No data No data No data No data Gas-phase reaction No data No data with ozone cm 3 /mol/s As shown in Table 12, elemental mercury (Hg 0 ) has a high vapor pressure at room temperature, which means that, during burning processes in a MSW plant, it is easily vaporized to the atmosphere and becoming highly toxic gas. Hg 0 is soluble in lipids so it is stored in fatty tissues in humans and animals. Due to low water solubility, the residence time Hg 0 in atmosphere is years (Carpi, 1996). In general divalent mercuric salts are soluble in water; for instance, waster solubility of mercuric (II) chloride is 1g/35ml H 2 O (ASTDR, 1999, and Bose-O`Reilly et al., 2010). Toxicology: Neurological effects in humans According to the Toxicological Profile for Mercury (ASTDR, 1999), inhalation exposure is the primary route of concern for metallic mercury vapor (elemental mercury) 70%-85% of inhaled mercury vapor is absorbed by the lungs into the bloodstream (Bose-O`Reilly et al., 2010). The main organs for the elemental mercury exposure are the lung, kidneys, and the central nervous system. Several studies have mentioned that a high level of mercury vapor can lead to death in humans, which means the acute exposure (14 days or less) of mercury is highly toxic (ASTDR, 1999). Minimal Risk Levels (MRLs) are derived for acute (1 14 days), intermediate ( days), and chronic (365 days and longer) durations and for the oral and inhalation routes of exposure. Table 16 shows Lowest-Observed-Adverse- Effect Levels (LOAELs) and No-Observed-Adverse-Effect Levels (NOAELs) for chronic exposure to mercury for some animals and humans (ASTDR, 1999).

45 37 Table 13. NOAEL and LOAEL of animals and humans Species Exposure duration System NOAEL Rat 71wk Renal 0.1 mg/m 3 5d/wk 7hr/d Dog 83wk Renal 0.1 mg/m 3 5d/wk 7hr/d Rabbit 83 wk Renal 0.1 mg/m 3 5d/wk 7hr/d Species Exposure duration System LOAEL Human 1-5yr Neurological mg/m 3 (Male) Human 1-41yr (mean: 15.3yr) Neurological mg/m 3 (Male) Human yr Neurological mg/m 3 According to the toxicology profile for mercury (ASTDR, 1999), The central nervous system is probably the most sensitive target organ for metallic mercury vapor exposure. McFarland and Reigel (1978) showed that exposure (less than 8 hours) to elemental mercury vapor concentration at 44 mg/m 3 gave workers long-lasting feelings of irritability, lack of ambition, and lack of sexual desire (Toxicology profile for mercury, 1999). Based on Table 13 data, Figure 15 illustrates neurological and renal effects on both humans and animals due to chronic exposure of elemental mercury vapor (ASTDR, 1999).

46 38 Fig 15. Dose renal and neurological effects of mercury airborne exposure At high concentrations of mercury vapor exposure over 2 days, a 54-year-old man exhibited a syndrome resembling amyotrophic lateral sclerosis, characterized by slowed conduction velocities (suggestive of peripheral nerve damage) (Toxicology profile for mercury, 1991). According to Rowens (1991), low-level chronic exposure to elemental mercury affects the neurologic system resulting in symptoms of tremor, neuropathy, and changes in personality referred to as mercurial erethism (ASTDR, 1991). The toxicology profile for mercury (ASTDR, 1991) states chronic-duration exposures to metallic mercury vapor have resulted in tremors (which may be mild or severe depending on the degree of exposure), unsteady walking, irritability, poor concentration, short-term memory deficits, tremulous speech, blurred vision, performance decrements in psychomotor skills (e.g., finger tapping, reduced hand-eye coordination), paresthesias, decreased nerve conduction, and other signs of neurotoxicity. Figure 15 shows the mercury vapor concentration in the air and its human neurological effects (Friberg, WHO, 1991).

47 Fig 16. Dose-response of elemental mercury vapor exposure (inhalation) Symptoms (%) Nervous disorders Mercury vapor concentration (mg/m 3 ) 1: Control group, 2: < , 3: , 4: , 5: Metallic mercury vapor can damage on the kidneys and respiratory systems in humans. The following shows the effects on these systems. 1. Renal effects The proximal tubules are the major target in the kidneys. A study shows (NTP, 1993) mice were given 20 mg Hg/kg/day in five days in a week increased kidney weights at 3.7 mg Hg/kg/day and acute renal necrosis at 59 mg Hg/kg/day (ASTDR, 1999). Due to a high dose exposure of elemental mercury, the tubular cells are not able to regenerate, meaning the function of the kidneys is going to fail (ASTDR, 1999). The study (Nielsen et al. 1991) on mice shows 10mg/Hg/kg of mercuric chloride led damages to renal tubular cells (ASTDR, 1999). 2. Respiratory Effects Several studies have reported death in humans following acute exposure to high concentrations of elemental mercury vapor (Campbell 1948; Kanluen and Gottlieb 1991; Matthes et al. 1958; Rowens et al. 1991; Soni et al. 1992; Taueg et al. 1992; Teng and Brennan 1959; Tennant et al. 1961). The deaths were correlated to respiratory failure due to high-level exposure of mercury. The common symptoms are cough, dyspnea, and tightness or burning pains in the chest (ASTDR, 1999). According to the Mercury toxicology profile (1999), the lungs exposed to mercury vapor show diffuse infiltrates or pneumonitis and impaired pulmonary function.

48 Risk Characterization 40 Elemental mercury risk calculation 1. Mercury concentration in the air The total amount of mercury in the air (Table 10) is estimated to be 69,637kg Hg/yr (190,786.30g Hg/d). To estimate the mercury concentration in air, this assessment used the mean yearly mixing height over the urban area since municipal solid waste is burned outside in the city. Therefore, we need to have the total volume of air around the former MSW. Chen et al (2012) used the zone of 0-500m distance from the pollutant source (the lead-acid battery recycling factory) as a pollutant area; therefore, the zone can be used in our risk calculation is approximately within the 500 m radius. The actual 500 m radius from the former MSW plant is illustrated in Figure 17. Fig 17. The pollutant zone within the 500 m radius Several studies have used average mixing heights to calculate pollutant concentrations in urban areas, as shown in Table 14 (Holzworht, U.S. EPA, 1972; Benarie, 1974). UB city`s has an annual average wind velocity of 8.1 mile per hour (3.62 meter per second) (WheatherSpark), which is close to the mean wind speed in Tokyo (3.7 m/s)

49 so this assessment used Tokyo as the example city for the assumptions of a mixing height of 830m (±100m) (Benarie, 1974). Table 14. The mean wind velocity and average mixing height Cities Mean wind velocity (meter per second) Los Angeles 2.14 m/s * 680 m Average mixing height New York 5.45 m/s * m Las Vegas 4.06 m/s * 1382 m Pittsburg 3.97 m/s * 1010 m Washington D.C. 4.2 m/s * 1049 m Paris 4.1 m/s 690 m Bordeaux 3.1 m/s 745 m Tokyo 3.7 m/s 830 m Osaka 2.9 m/s 920 m Lyon 3.3 m/s 620 m Ulaanbaatar 3.62 m/s 830m (±100m) * Wind-spees.weatherdb.com Based on the mixing height (Table 20) and the radius of the polluted zone (Figure 17), the total volume of the contaminated area is: V= πr 2 h = m 3 Therefore, the mercury concentration per day in the contaminated area is: Mass Hg concentration = Volume 190,786.30g Hg = 65, = mg Hg/m3 m3 2. Chronic exposure of neurological damages in humans (Table 2) Exposure duration: yr LOAEL concentration: mg/m 3 3. Reference concentration (RfC) RfC = LOAEL UF UF (Uncertainty Factor): mg/m3 RfC = = mg/m

50 4. Chronic daily intake (CDI) by inhalation CDI = CA IR ET EF ED BW AT CA: Contaminant concentration in air: mg Hg/m 3 IR: Inhalation rate: 0.019m 3 /hr (children) ET: Exposure time: 12hr/day (only daytime) EF: Exposure frequency: 365d/yr (MSW treatment operation time) ED: Exposure duration: 70yr (lifetime exposure) BW: Body weight: 33kg (6-12yr children) AT: Averaging time: 365d/yr 70yr 42 CDI 1 = mg Hg/m m 3 /hr 12hr/d 365d/yr 70yr 33kg 365d/yr 70yr CDI 1 = mg/kg/d When exposure time is 24hr per a day, chronic daily intake is: CDI 2 = mg/kg/d 5. Hazard Quotient (HQ) HQ= CDI RfC HQ 1 = HQ 2 = mg/kg/d mg/m 3 = mg/kg/d mg/m 3 = The both hazard quotients are bigger than one meaning there is a potential hazard for children`s neurological damages.

51 Chapter 4 LEAD RISK ASSESSMENT 43 Chapter 4 will analyze and summarize current recycling methods and technologies for used lead-acid vehicle batteries containing lead in UB city. The last part of the chapter will cover the lead hazard identification and risk calculation based on the airborne exposure for lead from used LABs recycling factories. Even though the main health concerns of lead toxicity is the nervous system, to identify health effects for different organisms the renal effects on children will be discussed in toxicology of the hazard identification. Lead exposure from lead-acid battery recycling factors Lead-acid batteries are used for various, such as powering/starting heavy trucks, buses, boats, and backup power for building lightings and electronic equipment. In 2015, the total lead production in the U.S., Canada, and Mexico is estimated to be 2,090,000 tons. In this estimation, recycled lead consumption is approximately 86 percent (1,800,000 tons) of all lead consumption (Queneau, Leiby and Robinson, 2015). Moreover, 100 million lead acid car batteries were sold in the U.S. and Canada in 1999 and 1,000,000 tons of lead were used for these automobile batteries in the U.S. at the same time. Total usage of recycled lead in the U.S. was 76 percent of all produced lead in 1999 (Commission for Environmental Cooperation, 2007). According to the estimation, by 2015, lead from used lead-acid batteries will account for 95 percent of total recycled lead in North America (Queneau et al. 2015). Battery industries use more than 75 percent of all lead consumption globally. Table 15 shows the consumption of lead for batteries in different countries (Basel Convention and UNEP report, 2003). Table 15. Consumption of lead for batteries (1993) Country Percentage U.S. 83 Japan 69 France 65

52 44 Germany 56 Italy 46 UK 34 In China, there are approximately three hundred lead recycling plants in 2013 and most of them are located in Jiangsu, Shandong, Henan, Hubei, Hunan, Hebei, and Anhui provinces. These recycling factories produce 80 percent of all lead production in China. The annual lead consumption for lead-acid batteries from secondary lead was approximately 60 tons in 2000 and it has been increased by approximately 100 tons in 2010 (Zhang, 2013). There are different types of batteries based on their purpose; however, as shown in Figure 18, a typical lead-acid battery has positive and negative terminals, sulfuric acid solution, positive and negative plates, and plate separators (Basel Convention and UNEP, 2003). Fig 18. Internal structure of a lead-acid battery (1) and (2): terminals made of lead; (3): one for each battery element, where distillated/deionized water can be replaced; (4): made of lead that makes electrical contact between plates of same polarity; (5) and (11): originally made of ebonite, but now more commonly made from either polypropylene or co-polymer; (6): the electrolyte of the battery; (7): usually a part of the box, provide chemical and electrical isolation between the electrical elements; (8): made of PVC or other porous

53 45 materials, avoid physical contact between two contiguous plates but, at the same time, allowing free movement of ions in the electrolyte solution; (9): constituted by a metallic lead grid covered by a lead dioxide (PbO2) paste; (10): constituted by metallic lead plates; (11): a series of negative and positive plates; (Basel Convention and UNEP report, 2003). In the positive terminals, lead dioxide (PbO 2 ) is converted to lead sulfate (PbSO 4 ) and in the negative terminals, elemental lead is converted into lead sulfate (PbSO 4 ). Sulfuric acid (H 2 SO 4 ) acts as the electrolyte, providing the SO 4- ion to both reactions. The chemical reaction in a lead battery is seen in Figure 19 (Basel Convention and UNEP report, 2003 and Vest, 2002). Fig 19. The chemical reaction in a lead-acid battery After the discharge-recharge process, the lead dioxide (PbO 2 ) plates become contaminated by lead sulfate (PbSO 4 ), resulting in the eventual loss of the ability to operate.. In the bottom of the battery, a sludge layer containing percent of PbSO 4, percent of PbO 2, 1-5 percent of PbO, and 1-5 percent of metallic Pb develops (Basel Convention and UNEP report, 2003). The lead-containing component varies based on the brand, battery size, and usage or purpose. Generally the amount of lead is approximately 60 percent to 80 percent of the weight of a lead-acid battery. An average automobile battery weights 17.2 kg, and contains kg of lead (Office of Emergency and Remedial Response, EPA, 1992). Lead percentages in varies types of batteries are shown in Table 16 (Basel Convention and UNEP report, 2003 and Vest 2002). Table 16. Lead components in automobile batteries Battery type Lead component Total weight 12V-44Ah-210A-starter battery in a 58.8% (8.82 kg) 15kg hard rubber casing 12V-44Ah-210A-starter battery in a 63.9% (8.62kg) kg

54 46 PP casing 12V-44Ah-220A vehicular battery 63.2% (8.4kg) 13.3 kg As seen in table 13, the battery`s lifetime varies in different countries and regions; typically in developing countries, it averages months. The useful life of batteries depends on different factors such as: incomplete charging process; remaining too long without use, hot weather, deep discharging process, and low electrolyte level (Basel Convention and UNEP report, 2003). As seen in Table 17, India estimates that its battery lifetime is 1.8 years, which may be a result of the quality of the batteries and the extreme hot weather. Table17. Lifetime of automobile batteries (1995) Country/Region Lifetime (yr) Western Europe 5.3 Canada 5.0 Japan 4.5 Australia 3.1 USA 3.0 Brazil 2.4 India 1.8 Based on the above estimation (Table 12), 60 percent (8kg) in a weight of an automobile battery in Mongolia can be considered as lead. Generally, Mongolia imports most of its automobiles from Japan due to their high fuel efficiency. UB city covers 0.3 percent ( km 2 ) of all the land of Mongolia; however, due to the rapid urbanization, in 2014, 60.9 percent (411,408) of all vehicles including buses, trucks, and automobiles are in the city (Ulaanbaatar city Traffic Police, 2014). According to Table 13, the lifetime of lead-acid batteries in Mongolia can be estimated to be 2 years; therefore, a half of the total vehicles in the city will dispose of used lead-acid batteries (LABs). Based on the above estimation, the total discharge of lead from used LABs per year in UB city is shown in Table 18.

55 47 Table 18. The annual amount of lead from LABs (Ulaanbaatar city) Total automobile Total amount Pb in Discharge of Pb based on batteries in UB city automobile batteries in UB battery lifetime (2014) city 411, ,408 8kg=3,291,264kg =1,645,632 kg/yr According to Table 18, approximately 1645 tons of lead only from vehicle batteries is going to be disposed in every year in the city. In Mongolia, several smallscale recycling lead-acid battery factories exist throughout the country; however, the specific data and information about the recycling process is not publicly available due to the company`s secret processes. The lack of information means that the treatment or lack of treatment cannot be determined. According to our interviews (2015) of automobile importers and small repair businesses in UB city, most of the recycling factories are in the countryside where the inspection and environmental regulations are less restrictive than in the city. Therefore, we assume that the recycling process in Mongolia is similar to a general process of used LABs recycling in developing countries. Figure 20 shows the recycling stages of a lead-acid battery in general (Vest, 2002). Fig 20. Typical recycling process of used LABs in developing countries As shown in Figure 20, after dismantling the batteries, the grids and lead pastes are separated in the screening stage and processed individually because grids are in metal

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