The DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) recently announced it’s intent to simplify the hazardous materials regulations for reverse logistics. Reverse logistics is the process that is initiated when a consumer product goes backwards in the distribution chain. It may be initiated by the consumer, the retailer, or anyone else in the chain. The process may involve consumers, retailers, manufacturers, and even disposal facilities. To fully engage the broad spectrum of stakeholders affected by reverse logistics, the ANPRM solicits comments and input on several questions in the context of reverse logistics. Comments must be received by October 3, 2012.
EPA to Keep Greenhouse Gas Regulatory Focus on Largest Emitters
The EPA announced that it will not revise greenhouse gas (GHG) permitting thresholds under the Clean Air Act (CAA). The final rule maintains a focus on the nation’s largest emitters that account for nearly 70% of the total GHG pollution from stationary sources, while shielding smaller emitters from permitting requirements. EPA is also finalizing a provision that allows companies to set plant-wide emissions limits for GHGs, streamlining the permitting process, increasing flexibilities, and reducing permitting burdens on state and local authorities and large industrial emitters. A fact sheet is available at:
After consulting with the states and evaluating the phase-in process, EPA stated that it believes that current conditions do not suggest that the Agency should lower the permitting thresholds. Therefore, EPA will not include additional, smaller sources in the permitting program at this time.
The final rule affirms that new facilities with GHG emissions of at least 100,000 tons per year (tpy) carbon dioxide equivalent (CO2e) will continue to be required to obtain Prevention of Significant Deterioration (PSD) permits. Existing facilities that emit 100,000 tpy of CO2e and make changes increasing the GHG emissions by at least 75,000 tpy of CO2e, must also obtain PSD permits. Facilities that must obtain a PSD permit, to include other regulated pollutants, must also address GHG emission increases of 75,000 tpy or more of CO2e. New and existing sources with GHG emissions above 100,000 tpy CO2e must also obtain operating permits.
EPA’s GHG permitting program follows the same CAA process that states and industry have followed for decades to help ensure that new or modified facilities are meeting requirements to protect air quality and public health from harmful pollutants. As of May 21, 2012, EPA and state permitting authorities have issued 44 PSD permits addressing GHG emissions. These permits have required new facilities, and existing facilities that make major modifications, to implement energy efficiency measures to reduce their GHG emissions.
The GHG Tailoring Rule will continue to address a group of six GHGs: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). The PSD permitting program protects air quality and allows economic growth by requiring facilities that trigger PSD to limit GHG emissions in a cost effective way. An operating permit lists all of a facility’s CAA emissions control requirements and ensures adequate monitoring, recordkeeping, and reporting. The operating permit program allows an opportunity for public involvement and to improve compliance.
DOT Releases Determination of Preemption for Common Law Tort Claims Concerning Design and Marking of DOT Specification 39 Compressed Gas Cylinders
PHMSA has determined that federal hazardous material transportation law preempts a private cause of action which seeks to create or establish a State common law requirement applicable to the design, manufacture, or marking of a packaging, container, or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce when that State common law requirement would not be substantively the same as the requirements in the HMR. Federal hazardous material transportation law does not preempt a tort claim that a packaging, container, or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material failed to meet the design, manufacturing, or marking requirements in the HMR or that a person who offered a hazardous material for transportation in commerce or transported a hazardous material in commerce failed to comply with applicable requirements in the HMR.
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Natural Resource Injury Case Settled for Freeport-McMoRan Morenci Mine
The US District Court for the District of Arizona has approved a $6.8 million settlement among the State of Arizona, the Department of the Interior through the US Fish and Wildlife Service (FWS), and Freeport-McMoRan Corporation and subsidiaries (Freeport) for natural resource damages under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) resulting from the release of hazardous substances from the Freeport Morenci mine, located in east-central Arizona. The settlement money will be used for the restoration of Arizona wildlife populations and their habitat.
The settlement is the result of several years of negotiations among Freeport-McMoRan Corporation, the FWS, the Arizona Department of Environmental Quality (ADEQ), and the Arizona Game and Fish Department. Settlement negotiations began in 2003 after the FWS investigated the bird mortalities at Freeport’s Morenci tailings ponds.
The Morenci mine site is located near the Arizona communities of Clifton and Morenci near the New Mexico border. The mine site has numerous open pits, leach rock stockpiles, tailings impoundments, and uncovered ponds. Five smelters also have operated historically at the site.
Rainwater-formed ponds on the tailings were documented to be highly acidic in 2000 and 2001, and to cause death and other injuries to migratory birds through exposure and ingestion. Hazardous substances at the mine, located between the San Francisco River and Eagle Creek, have included sulfuric acid, copper, and other dissolved metals.
Negotiations included the results of field investigations, documentation of injuries reported in 2000–2001, and the modeling of injuries that preceded the documented event and resulting future loss of wildlife productivity.
The settlement money will be held in the Interior Department’s Natural Resource Damage Assessment and Restoration Fund until restoration projects are selected. A trustee council consisting of ADEQ, Arizona Game and Fish Department, and FWS will solicit project ideas and prepare one or more draft restoration plans for public review and comment before selecting projects for implementation.
Restoration projects will be designed to restore, rehabilitate or replace injuries to terrestrial, aquatic, and avian habitats. These plans will be made available for review at a later date.
DOT’s Largest Civil Penalty Issued for Oil Spill
The DOT’s PHMSA has proposed a record $3.7 million civil penalty and 24 enforcement actions against Enbridge Energy for the July 25, 2010, crude oil spill near Marshall, Michigan.
PHMSA’s investigation found multiple violations of its hazardous liquid pipeline safety regulations related to integrity maintenance, failure to follow operation and management procedures, and reporting and operator qualification requirements. PHMSA issued its notice and proposed civil penalty to Enbridge in a Notice of Probable Violation.
Enbridge’s Line 6B ruptured on the evening of July 25, 2010, while the pipeline was in the process of a scheduled shutdown. Despite control center alarms, there were several attempts to restart the line, resulting in more pressure that expelled more oil. On July 26, a local natural gas company employee notified the Enbridge control center about the spill. By that time, more than 20,000 barrels of crude oil had been spilled. Enbridge has 30 days to respond to PHMSA.
Pipeline safety is a top priority at PHMSA. In April 2011, Secretary LaHood issued a Call to Action on pipeline safety, asking pipeline operators to replace and rehabilitate aging pipelines. PHMSA closed a record number of enforcement cases in 2011 and is collecting more data about pipelines and stepping up efforts to educate the public about staying safe around pipelines. The new Pipeline Safety Act gives PHMSA even more ways to hold pipeline operators accountable as well as the ability to issue civil penalties double that of previous statutory amounts for operators that violate pipeline safety laws.
Dairyland Power Cooperative Agrees to Reduce Emissions by More Than 29,000 Tons Annually
DPC has agreed to invest approximately $150 million in pollution control technology that will protect public health and resolve violations of the CAA. The settlement will also require that DPC spend $5 million on environmental mitigation projects and pay a civil penalty of $950,000.
Under the settlement, DPC must install pollution control technology on its three largest units and will be required to comply with stringent emission rates and annual tonnage limitations. The settlement also requires DPC to permanently retire three additional coal-fired units at the Alma plant, which have been out of operation since last year. The permanent retirement of these units will ensure that they do not restart without first complying with the CAA. The actions taken by DPC to comply with this settlement will result in annual reductions of sulfur dioxide (SO2) emissions by 23,000 tons and nitrogen oxides (NOx) emissions by 6,000 tons from 2008 levels, in addition to significant reductions of particulate matter emissions. This settlement covers all seven coal-fired boilers at DPC’s three power plants.
The settlement also requires DPC to spend $5 million on projects that will benefit the environment and human health in communities located near the DPC facilities. DPC must pay $250,000 each to the US Forest Service and the National Park Service, to be used on projects to address the damage done from DPC’s alleged excess emissions. At least $2 million will be spent on a major solar photovoltaic development project. The remaining mitigation funding will be spent on one or more of the following projects; 1) installation of solar photovoltaic panels, 2) home weatherization projects, and 3) the replacement of DPC’s standard vehicle fleet with cleaner burning vehicles. The Sierra Club is a party to the settlement, which will also resolve violations alleged by Sierra Club in related litigation.
Reducing air pollution from the largest sources of emissions, including coal-fired power plants, is one of EPA’s National Enforcement Initiatives for 2011–2013. SO2 and NOx, two key pollutants emitted from power plants, have numerous adverse effects on human health and are significant contributors to acid rain, smog, and haze. These pollutants are converted in the air to fine particles of particulate matter that can cause severe respiratory and cardiovascular impacts, and premature death. Reducing these harmful air pollutants will benefit the communities located near DPC facilities, particularly communities disproportionately impacted by environmental risks and vulnerable populations, including children. Because air pollution from power plants can travel significant distances downwind, this settlement will also reduce air pollution outside the immediate region.
The total combined sulfur dioxide and nitrogen oxides emission reductions secured from these settlements will exceed nearly 2 million tons each year once all the required pollution controls have been installed and implemented.
Caterpillar, Inc. Pays $510,000 for Shipping, Selling Uncertified Equipment
Caterpillar, Inc., will pay a fine of $510,000 to the California Air Resources Board (ARB) for shipping more than 590,000 on-road and off-road engines that did not have legally required emissions controls installed.
The investigation of these violations was conducted with the EPA and the DOJ based on similar conduct outside of California. The settlement calls for the Illinois-based company to pay a total of $2.55 million in penalties nationwide for violations of the CAA.
California’s $510,000 portion is based on its share of the engines sold. Caterpillar, which manufactures construction equipment and diesel and natural gas engines, also agreed to recall and correct noncompliant engines and to reduce excess smog-forming and diesel emissions.
Caterpillar recalled the affected engines from August 2002 to April 2005. In 2010, in accordance with the federal Consent Decree, the company reopened and continued the recalls until December 31, 2011.
The federal government’s claims were resolved in 2011. The state’s recent agreement concludes California’s portion of the investigation.
In addition to shipping engines without proper emission controls, Caterpillar also failed to comply with reporting and engine-labeling requirements.
Under the settlement, Caterpillar will pay the $510,000 fine to the California Air Pollution Control Fund to support air quality research.
Engines lacking proper emission controls can produce excess smog-forming pollutants that can exacerbate cardiac and respiratory ailments such as asthma.
Fairhaven Shipyard Companies, Inc. to Pay $175,000 to Resolve Violations of the CWA
EPA has announced that Fairhaven Shipyard Companies, Inc., (Fairhaven Shipyard) has agreed to pay a civil penalty of $175,000 to resolve violations of the federal Clean Water Act (CWA), which occurred at two of their facilities in Fairhaven, Massachusetts. They have also agreed to undertake measures to achieve compliance with the Act and applicable regulations.
The settlement is contained in a consent decree that was filed in federal district court this week, along with a civil complaint, filed on behalf of the EPA. According to the complaint, Fairhaven Shipyard discharged untreated wastewater generated from pressure washing vessel hulls to New Bedford Harbor, without the required National Pollutant Discharge Elimination System (NPDES) permit between December 2005 and July 2010. As a result, the Coast Guard in 2008 was called to investigate reports of large areas of red-stained water in New Bedford Harbor, which was caused by the discharge of wash washer containing high levels of paint residues.
In addition, from December 2005 to January 2009, during rain events, Fairhaven Shipyard allowed storm water that had come into contact with pollutants from industrial activities to flow to New Bedford Harbor, without obtaining or complying with the terms of a federal storm water permit. After it obtained permit coverage for the storm water discharges in January 2009, Fairhaven Shipyard failed to perform certain required sampling and failed to control its storm water discharges as needed to minimize discharge of pollutants and to ensure that applicable water quality standards were met in New Bedford Harbor. Finally, Fairhaven Shipyard did not prepare and implement Spill Prevention Control and Countermeasure (SPCC) Plans at their two Fairhaven facilities. The amount of the civil penalty is based in part on Fairhaven Shipyard’s inability to pay a more substantial penalty.
Pressure wash water from vessel cleaning contains paint residues, including copper, lead, and zinc from anti-fouling paint, oil and grease, and detergents. Without adequate on-site controls, stormwater runoff from shipyards can flow directly to waterways and contribute to water quality impairments such as wildlife habitat degradation, fishing restrictions, and beach closings.
EPA issued an order requiring the company to come into compliance with NPDES requirements in March 2009. After receiving the order from EPA, Fairhaven Shipyard constructed systems to collect its pressure wash water at both facilities. The shipyard began sending the pressure wash water from its two facilities to the Town of Fairhaven’s wastewater treatment facility for treatment starting in September 2009 and September 2010.
Hawaii Cites Navy for Hazardous Waste and Used Oil Violations
The Hawai’i State Department of Health (DOH) has issued a notice of violation with a penalty fine totaling $80,000 against the US Navy Public Works Center Makalapa Compound for alleged violations of the state’s hazardous waste and used oil rules. Makalapa Compound operates as a base yard for maintenance activities for Pearl Harbor Navy Region Hawai’i.
Makalapa faces four counts of failure to make a hazardous waste determination and two counts of storage of hazardous waste without a permit. During a routine inspection on August 31, 2011, DOH found Makalapa failed to make a hazardous waste determination for corrosive wastes generated during coil cleaning of refrigerant equipment and for wastes generated from the use of solvents containing methyl ethyl ketone and perchloroethylene. These wastes were disposed of in the trash instead of handling them as hazardous wastes. Makalapa also stored hazardous waste paints and fuels in open containers, thereby violating the requirements for a permit for storage of hazardous waste. The Navy has 20 days to contest its notice of violation and request a hearing.
New Mexico Reaches Settlement with Advantage Asphalt
The New Mexico Environment Department (NMED) has announced that it has entered into a Settlement Agreement with Advantage Asphalt and Seal Coating, LLC, to resolve the violations contained in an Administrative Compliance Order issued by the Department on September 20, 2010.
The settlement includes payment of a $75,000 civil penalty and voluntarily termination of Advantage Asphalt’s commercial solid waste hauler registration. NMED Secretary Dave Martin signed a Stipulated Final Order approving the Settlement Agreement.
The Compliance Order alleged violations of the New Mexico Solid Waste Act and Rules, citing the improper handling, transportation, and disposal of regulated asbestos waste in Bloomfield, New Mexico. The Department determined through additional investigation that while regulated asbestos waste was improperly disposed, such waste was not disposed at the Bloomfield High School, as originally alleged in the Compliance Order. Advantage Asphalt does not contest, and accepts responsibility for, the allegations in the Compliance Order.
Boston University to Pay $30,750 in Suspended Penalties for Repeated Violations
The Massachusetts Department of Environmental Protection (MassDEP) issued a demand for a previously suspended $30,750 penalty to the Trustees of Boston University (BU) for repeated asbestos violations that occurred on its campus by hired contractors. The demand letter was issued after repeated asbestos violations occurred on the campus in violation of a consent order the university signed with MassDEP.
In May 2011, MassDEP penalized the Trustees $74,250 for asbestos violations that occurred at three of its Boston properties: Robinson Medical Building, the Student Union, and a residence hall. The Trustees paid $33,500 at that time and agreed to comply with state asbestos regulations. The remaining penalty, $30,750, was suspended as long as there were no additional violations at Boston University properties over the next 12 months.
However, a month after that consent order was signed—June 22, 2011, and again on August 9, 2011—MassDEP observed a contractor hired by Boston University conducting demolition and renovation activities at the two properties located on campus. The contractors were hired by the university to conduct the work, and this work resulted in asbestos-containing material being removed. No prior notification had been filed to abate, handle or dispose of this material properly, a violation of the consent order between the Trustees and MassDEP.
Property owners or contractors with questions about asbestos-containing materials, notification requirements, proper removal, handling, packaging, storage, and disposal procedures, or the asbestos regulations are encouraged to contact the appropriate MassDEP Regional Office for assistance.
Bronx County Recycling Enters into Plea for a Class E Felony; Facility to Stop Handling Construction Debris and Other Solid Wastes
The Bronx County Recycling, LLC, and its principal Salvatore Cascino, have entered into an Administrative Order that prohibits the company from handling construction and demolition debris and related solid wastes in New York state, the Department of Environmental Conservation (DEC) announced. The order is part of a plea agreement under which Cascino pleaded guilty to Offering a False Instrument in the Second Degree, a class E felony.
Additionally, the defendant paid a $20,000 fine. The order also resolved outstanding civil violations at the facility from 2008 and assessed an additional $5,000 penalty paid at the time of the plea.
In 2009, Bronx County Recycling, LLC, was a registered construction and debris processing facility. A registered construction and demolition debris processing facility is permitted to accept only uncontaminated rock, asphalt, dirt, and concrete and reprocess it for limited designated and permitted uses. Any other waste is designated as unauthorized solid waste.
Under regulations administered by DEC, all registered construction facilities must submit yearly annual reports, which identify the amount of unauthorized waste the facility receives and where it is disposed. In 2009, Cascino failed to report the receipt of large amounts of unauthorized waste, some of which he disposed of at a site in Claremont, Columbia County. The waste included wood, glass, and plastics.
Nisso America to Pay $6,864 Civil Penalty for Failure to Label and File Notice of Imported Pesticide
Nisso America, Inc., a subsidiary of Nippon Soda Co., Ltd., of Tokyo, Japan, has agreed to pay a $6,864 civil penalty to the US for failing to properly label 44 drums containing 880lb of imported pesticides from Italy as well as failing to provide EPA with a required notice that it had imported the drums.
According to an administrative consent agreement filed by EPA Region 7 in Kansas City, Kansas, Nisso America, Inc., imported 44 drums of Tebufenozide Technical on December 8, 2011. The Notice of Arrival (NOA) form that Nisso America was required to submit to EPA before any shipment of pesticides arrives at a US port of entry was submitted five days after the 44 drums of pesticide were released from the port of entry into commerce.
On December 27, 2011, an inspector from the Missouri Department of Agriculture found that none of the drums had an EPA-accepted label, therefore missing an EPA registration number, an EPA establishment number, directions for use, a first aid statement, an ingredient statement, a precautionary statement, a signal word, and a child hazard warning statement.
Nisso America, Inc., violated the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) by failing to properly label the 44 drums of imported pesticide and failing to timely submit to EPA the NOA.
The sale or distribution of misbranded or mislabeled pesticides can pose serious risks to human health, plant and animal life, and the environment. Without proper labeling or safety instructions on packaging, users can unintentionally misapply pesticides and may not have adequate information to address needs for first aid in the event of emergency.
Under the FIFRA, importers of pesticides must ensure that pesticides containers imported into the US bear the required FIFRA labeling and must file notices with EPA prior to importation of pesticides. Violation of the FIFRA regulations impacts EPA’s ability to track potentially hazardous and toxic pesticide products.
The pesticide involved in this case, Tebufenozide Technical, is a toxic chemical used in the formulation of other insecticides.
As a result of EPA’s enforcement action, Nisso America, Inc., was required to re-label all 44 drums in the shipment of Tebufenozide Technical. The company has also instituted changes in its practices to prevent similar violations, and has certified that it is presently in compliance with the FIFRA and its regulations.
The Bonds Company Fined for Violating the CWA
The EPA has fined The Bonds Company of Magnolia, Arkansas, $6,000 for violating federal SPCC regulations at three of its oil production facilities.
Federal inspections at the facilities found numerous violations including: Personnel working at two of the facilities had no training on discharge procedure protocols, no training on applicable pollution control laws, rules, and regulations, and training records were not maintained for three years as required by federal law. The inspections also found that records were not available for review and the size of secondary containment at the same two facilities appeared to be inadequate.
A third oil production facility was found to have no contingency plan, inspection records were not available for review, and the size of secondary containment appeared to be inadequate.
As part of an Expedited Settlement Agreement with the EPA, the company has provided certification that all identified deficiencies have been corrected.
SPCC regulations require onshore oil production facilities provide spill prevention, preparedness, and response to prevent oil spills. The SPCC program helps protect our nation’s water quality since a spill of only one gallon of oil can contaminate one million gallons of water.
Tennessee Gives Free Pass to Dirty TVA Coal Plant
Community and environmental groups have appealed a pollution permit issued to Tennessee Valley Authority (TVA) for its Gallatin coal-fired power plant to prevent toxic discharges of heavy metals and other harmful waste byproducts of burning coal. The plant’s polluted wastewaters are dumped into unlined ponds that allow pollution to continue to harm the environment.
In addition to the toxic discharges, Gallatin’s water cooling intake system routinely kills tens of thousands of fish and other aquatic life that become trapped in the structures every year. The group is asking that Gallatin use better technology to protect fish and other aquatic life.
The appeal, filed with the Tennessee Water Quality Control Board, challenges the wastewater discharge permit from the Tennessee Department of Environmental Conservation (TDEC) based on its failure to include any limits at all on the discharge of toxic metals. EPA, which has recognized that coal plants are among the top dischargers of toxics in the nation, had informed TDEC that these discharge limits were required, but TDEC has refused to set them.
The groups also challenges TDEC’s refusal to impose any permit conditions designed to protect fish. While the CWA requires coal plants to minimize harm to fish and other aquatic life, the Gallatin Fossil Plant uses an outdated cooling system with water intake structures that suck enormous numbers of fish into the works of the coal plant and kills them.
The Tennessee Valley Authority (TVA) historically has operated some of the dirtiest coal-fired power plants in the country. After years of litigation, TVA recently entered into a settlement that requires installation of modern air pollution controls, but the utility has not yet addressed its major water pollution and waste problems.
Almost four years ago, the TVA’s Kingston Fossil Plant spilled over one billion gallons of toxic coal ash, killing nearby fish and wildlife and causing a mudflow wave of water and ash that covered 12 homes. Cleanup of that spill continues today. Weeks later, TVA’s Widows Creek Plant spilled over 10,000 tons of waste into in the Tennessee River in Alabama.
EPA Proposes Major Clean Air Updates to Three Aging Arizona Coal Power Plants to Protect Health and Parks
Three aging coal-fired power plants in Arizona will need to upgrade their smokestack pollution control equipment under a plan proposed by the EPA.
The Cholla, Coronado, and Apache coal power plants together spew out tens of thousands of tons of sulfur and nitrogen oxides each year. This kind of pollution is linked to serious health harms, and also to haze that clouds the skies of national parks and wilderness areas in the southwest.
According to the National Park Service, Arizona Public Service’s (APS’s) Cholla plant, whose first coal unit was built some 50 years ago, has significant cumulative impacts on air quality across 13 ‘Class I’ park and wilderness areas, including Petrified Forest National Park and Grand Canyon National Park.
In rejecting the state’s proposal for the three coal plants as inadequate under the requirements of the Clean Air Act, EPA’s plan will require a total of seven coal boilers at the three plants to be retrofitted with selective catalytic reduction controls, a technology now in wide use at over 200 coal-fired units around the country. Selective catalytic reduction can cut nitrogen oxide pollution by 90%.
The EPA proposal comes in response to a lawsuit on behalf of conservation groups including National Parks Conservation Association, Sierra Club, Grand Canyon Trust, Environmental Defense Fund, San Juan Citizens Alliance, Our Children’s Earth Foundation, Plains Justice, and Powder River Basin Resource Council. The suit was brought after the state and EPA missed legal deadlines for limiting haze-causing pollution from power plants and factories in Arizona. Action to clean up haze pollution in the state is required as part of a court-enforceable settlement of the suit.
Low levels of exposure to nitrogen oxides can irritate the eyes, nose, throat, and lungs, and cause shortness of breath; high levels of exposure can cause serious respiratory system damage. Both nitrogen oxides and sulfur dioxide from coal plant smokestacks are also chemically converted in the atmosphere to form ozone and fine particulate pollution, one of the deadliest air pollutants because it can penetrate deep into the lungs. Particulate matter exposure can cause heart attacks, strokes, asthma attacks, and premature deaths.
In April, the Arizona Corporation Commission required APS to evaluate coal plant retirements as part of a systematic review of the economic and environmental risks throughout its coal fleet. The commission’s order was part of its approval for APS to buy two coal units at Four Corners Power Plant from Southern California Edison (APS has proposed retirement of three units).
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Trivia Question of the Week
The RCRA hazardous waste regulations provide an alternative set of requirements for universal wastes. Universal wastes are commonly recycled wastes with special management provisions intended to facilitate recycling. Federally, there are four recognized categories of universal wastes. Which of the following waste categories is not included in the federal definition of universal waste?
a. Electronic equipment
b. Batteries
c. Pesticides
d. Mercury-containing equipment
