Evaluation of Domestic Sources of Mercury

http://www.amsa-cleanwater.org/pubs/mercury/mercury.cfm

Click Here To Download The Report (PDF FORMAT) 

http://www.amsa-cleanwater.org/pubs/mercury/mercury.pdf

Household Mercury Poses National Clean Water Compliance Concerns - August 2000

The Association of Metropolitan Sewerage Agencies (AMSA) reports that mercury levels in household wastewater are sufficiently high to pose Clean Water Act compliance problems for the nation's wastewater treatment plants. The findings of the AMSA study underscore the need for a comprehensive, priority-based, cost-effective national strategy to reduce mercury in the environment.

Mercury contamination is the leading cause of fish advisories in the country. Because mercury “bioaccumulates” in the fatty tissues of fish and wildlife as it passes up the food chain, the U.S. Environmental Protection Agency (EPA) is expected to recommend significantly stricter national water quality criteria for mercury later this year — at or near the level of 1 part per trillion, which is already in place in the Great Lakes.

Mercury from domestic wastewater and municipal treatment plants accounts for less than 1 percent of mercury entering the environment. Still many wastewater treatment agencies are concerned that compliance will require the application of advanced treatment at their publicly owned treatment works (POTWs) that have been shown to cost $10 million - $100 million for every pound of mercury removed. In addition, such advanced treatment may not have much impact on resolving water quality issues as long as mercury continues to enter the environment from other sources such as air pollution or abandoned mines. EPA believes that by using new analytical and sampling techniques and pollution minimization, POTWs should have no difficulty in attaining these more stringent requirements. EPA's conclusions in large part are based on a 1994 mercury sampling project that showed four of nine wastewater treatment plants had non- detectable mercury levels. This approach, however, assumes that there is no background mercury concentration in domestic wastes. Until recently there has been very little information on mercury concentrations in domestic waste, mainly due to a lack of monitoring at a sufficiently low level.

To better understand the relative contributions of mercury in domestic wastes and potential source control options, AMSA initiated a study to collect information on concentrations of mercury in domestic wastewater, to identify the sources of mercury in domestic wastewater, and to evaluate the feasibility of controlling those mercury sources. Sources evaluated included common household products and food items, as well as research on mercury contributions from individuals with amalgam fillings.

Click Here To Download The Report (PDF FORMAT)

http://www.amsa-cleanwater.org/pubs/mercury/mercury.pdf

Clean Water Advocacy -
Mercury Source Control and Pollution Prevention Program Evaluation - Final Report

http://www.amsa-cleanwater.org/advocacy/mercgrant/

Two years ago, AMSA approached the U.S. Environmental Protection Agency (EPA) with an idea for a project that would evaluate the effectiveness of pollution prevention programs at reducing the amount of mercury entering the nation's publicly owned treatment works (POTWs). With a grant from EPA, and the consulting assistance of Larry Walker and Associates, AMSA set out to determine whether pollution prevention or some form of source control could sufficiently reduce influent mercury levels to enable POTWs to comply with increasingly stringent limits for mercury. The project also sought to identify any beneficial impacts of wastewater source control programs on other pathways by which mercury enters the environment.

While the project did not involve implementation of actual pollution prevention programs, it did rely on a handful of POTWs from across the country to serve as case studies for the evaluation. Extensive effort was made to accurately estimate the mercury contributions from the major sources, including dental offices, domestic wastewater, and hospitals, which were then used to estimate the influent mercury load for each POTW case study. From there, the analysis estimated the load reductions achievable through the implementation of a control strategy, accounting for participation and effectiveness. The resulting effluent levels, based on the potential reductions, were compared to a list of mercury criteria to determine whether the source control programs could help POTWs comply with more stringent mercury limits. Finally, the costs to implement these programs and any additional treatment that might be necessary to ensure compliance were also evaluated.

At its conclusion, the project clearly demonstrated that mercury source control and pollution prevention programs have the potential to achieve measurable reductions in influent levels of mercury, and to have positive impacts with respect to reducing other environmental releases of mercury. The extent to which these source control programs alone will enable POTWs to meet increasingly stringent effluent limits, however, appears limited. During the course of the project a number of questions were raised that may ultimately have an impact on the effectiveness of pollution prevention programs for mercury. AMSA hopes that these questions will be answered through future projects like this one, and that together, these projects may provide us with a more complete understanding of how to curb releases of mercury to the environment.

AMSA would like to thank those agencies that served as case studies for the project and extend a special thanks to those individuals who served on the project oversight committee.

About - AMSA Year in Review - 2000-2001 -
AMSA Seeks Improvements to EPA’s Mercury

http://www.amsa-cleanwater.org/about/00year/8.cfm

AMSA took the lead during the past year in ensuring that the U.S. Environmental Protection Agency’s (EPA) effort to reduce mercury in the environment will not disproportionately impact the nation’s wastewater treatment agencies. With the promulgation of new, more sensitive mercury detection methods, and EPA’s tightening of water quality criteria for mercury, AMSA worked extensively to gather additional data and inform EPA about the mercury compliance issues publicly owned treatment works (POTWs) face.

Margaret Nellor, Assistant Department Head for the Los Angeles, Calif., County Sanitation Districts, serves as Co-Chair of AMSA’s Mercury Workgroup which addresses source control and compliance issues related to the regulation of mercury in the environment.

Throughout the year, AMSA actively engaged in a number of projects that provided further information on the sources of mercury entering sewerage systems and detailed the effectiveness of local pollution prevention programs in reducing mercury. AMSA also sought EPA approval of a less costly mercury sampling method that could save POTWs nationwide significant resources.

AMSA Mercury Study Produces Startling Results
In Summer 2000, AMSA’s Mercury Workgroup completed a report, Evaluation of Domestic Sources of Mercury, which provided valuable information to EPA and the public about the compliance issues that mercury levels in domestic wastewater pose for POTWs. This study was conducted to determine the domestic – as opposed to industrial or commercial – contribution to mercury levels in POTWs’ influent. The results showed an average mercury level in domestic wastewater of 138 parts per trillion (ppt), 80 percent of which comes directly from humans, both from mercury-containing foods and amalgam dental fillings.

At 100 ppt, the report noted, mercury from domestic sewage alone presents compliance issues for POTWs. This is because POTWs remove 95–99 percent of mercury from wastewater before discharge and new water quality standards for mercury are expected to be set at or below a 1 ppt level. Although municipal wastewater discharges account for an estimated 1 percent of mercury entering the environment, POTWs would likely have to make huge capital expenditures in order to meet a mercury standard of 1 ppt.

The report supported AMSA’s recommendation that a national mercury compliance strategy be developed for POTWs because pollution minimization efforts alone may not be adequate to produce the desired level of permit compliance sought by regulatory authorities.

AMSA, EPA Work Cooperatively to Study Source Control of Mercury
In a study being funded by an EPA cooperative agreement, AMSA has begun work to conduct an 11-month study on the effectiveness of source control measures in reducing mercury levels in POTW effluent and biosolids. The report will build on a previous AMSA report on domestic prevention of mercury pollution and seeks to demonstrate and evaluate the feasibility and environmental benefit of implementing source control measures. AMSA has formed a Project Steering Committee, which includes representatives from EPA, states, industry and POTWs, to assist in developing the study.

EPA Undertakes Mercury Method 245.7 Validation
In another important victory for POTWs, AMSA convinced EPA to move forward with validation tests of mercury method 245.7. AMSA successfully secured an EPA review of the alternative sampling method, which is significantly less costly than the only currently approved low-level detection method, method 1631. The AMSA National Office estimates that approval of method 245.7 would save POTWs over $17 million per year in lab costs.

AMSA Supports Mercury Bill as Important First Step
AMSA expressed its support for the Mercury Reduction and Disposal Act of 2001 (S. 351) introduced by Sen. Susan Collins (R-ME) in February 2001. The bill would limit the use of mercury fever thermometers and improve collection, recycling, and disposal of mercury. It also establishes an Interagency Task Force on Mercury. AMSA’s letter of support recognizes the bill as an important first step in reducing releases of mercury into the environment and encourages expansion of the bill to include a national mercury reduction strategy and POTW involvement in the Interagency Task Force. AMSA will continue to garner additional support for the bill and work with Sen. Collins’ office to ensure the voice of the POTW community is heard.

AMSA’s 2000–01 achievements with regard to the mercury issue provide another sterling example of how the Association draws upon the technical expertise of its members and its historically strong working relationship with EPA and members of Congress to benefit POTWs nationwide.

Clean Water Advocacy - News Releases - August 22, 2000

August 22, 2000
Contact: John Millett, 202/833-4651, AMSA

Household Mercury Poses National Clean Water Compliance Concerns

http://www.amsa-cleanwater.org/advocacy/releases/82200.cfm

Washington, DC — The Association of Metropolitan Sewerage Agencies (AMSA) reports that mercury levels in household wastewater are sufficiently high to pose Clean Water Act compliance problems for the nation's wastewater treatment plants. The findings of the AMSA study underscore the need for a comprehensive, priority-based, cost-effective national strategy to reduce mercury in the environment. The complete report, “Evaluation of Domestic Sources of Mercury,” is available on AMSA's web site.

Mercury contamination is the leading cause of fish advisories in the country. Because mercury “bioaccumulates” in the fatty tissues of fish and wildlife as it passes up the food chain, the U.S. Environmental Protection Agency (EPA) is expected to recommend significantly stricter national water quality criteria for mercury later this year — at or near the level of 1 part per trillion, which is already in place in the Great Lakes.

Mercury from domestic wastewater and municipal treatment plants accounts for less than 1 percent of mercury entering the environment. Still many wastewater treatment agencies are concerned that compliance will require the application of advanced treatment at their publicly owned treatment works (POTWs) that have been shown to cost $10 million - $100 million for every pound of mercury removed. In addition, such advanced treatment may not have much impact on resolving water quality issues as long as mercury continues to enter the environment from other sources such as air pollution or abandoned mines. EPA believes that by using new analytical and sampling techniques and pollution minimization, POTWs should have no difficulty in attaining these more stringent requirements. EPA's conclusions in large part are based on a 1994 mercury sampling project that showed four of nine wastewater treatment plants had non-detectable mercury levels. This approach, however, assumes that there is no background mercury concentration in domestic wastes. Until recently there has been very little information on mercury concentrations in domestic waste, mainly due to a lack of monitoring at a sufficiently low level.

To better understand the relative contributions of mercury in domestic wastes and potential source control options, AMSA initiated a study to collect information on concentrations of mercury in domestic wastewater, to identify the sources of mercury in domestic wastewater, and to evaluate the feasibility of controlling those mercury sources. Sources evaluated included common household products and food items, as well as research on mercury contributions from individuals with amalgam fillings.

About - AMSA Year in Review - 2001-2002 - AMSA Takes Strides Toward a National Mercury Policy

http://www.amsa-cleanwater.org/about/02yir/17.cfm

While publicly owned treatment works (POTWs) are on the front lines of the fight to reduce the level of mercury in our nation’s waters, they find themselves, more and more, on the receiving end of stringent mercury permit limits, where end-of-pipe treatment simply will not be the solution. As a result, AMSA has been very involved over this past year in urging the U.S. Environmental Protection Agency (EPA), Congress and fellow associations and organizations to support a national mercury strategy that will take into account not only the appropriate role for POTWs in reducing mercury levels – but also the responsibility of domestic and industrial users of mercury to do the same.

AMSA Gathers Evidence, Seeks to Enlist EPA’s Support on Mercury
On March 8, 2002, AMSA released its Mercury Source Control and Pollution Prevention Program Evaluation – Final Report. The Report, funded by EPA, is the product of two years of cooperative effort between AMSA and EPA to evaluate the effectiveness of pollution prevention programs to control the amount of mercury discharged by dental offices, hospitals, and other sources into the sewer system. The Report provides evidence that neither POTWs – nor industrial or commercial sources of mercury – can be singled out to solve this complex issue. This Report will serve as a significant and lasting factor in AMSA’s ongoing advocacy efforts and the critical importance of making progress toward a national mercury strategy.

Critically, AMSA has been on the front lines of explaining that there is currently no method available that can meet mercury levels of less than 1 part per trillion, which some states have considered mandating, and that such a level would automatically, and arbitrarily, force POTWs into noncompliance. AMSA has also written EPA Administrator Christine Todd Whitman urging her to work with a coalition of leaders from state environmental associations (known as the Quicksilver Caucus), as well as leaders from the POTW community, to craft a viable a national strategy.

AMSA-Backed Mercury Legislation Garners Important Attention
This year, AMSA staunchly supported the Mercury Reduction and Disposal Act of 2001, S. 351, introduced by Sen. Susan Collins (R-ME). The legislation would create an Interagency Task Force on Mercury to guide the development of a national environmental mercury compliance strategy. AMSA launched a successful campaign in June 2001 urging Association members to send letters to their Senators in support of S. 351 to ensure that mercury controls look beyond traditional end-of-pipe controls. These efforts resulted in increased support for S. 351 from key Senators including Kay Bailey Hutchison (R-TX), Dianne Feinstein (D-CA), and George V. Voinovich (R-OH) who continue to vocally support the need for a national strategy. While action on the bill itself has been overtaken by other events, AMSA will continue to explore both regulatory and legislative means to push for a national mercury policy.