State Leadership In the Fight Against Mercury Pollution

1
State Leadership In the Fight Against Mercury
Pollution

• Arleen ODonnell, Deputy Commissioner
• Massachusetts Department of Environmental
  Protection

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PRESENTATION OVERVIEW

• Why is mercury a priority for the states?
• State leadership on mercury
• Regional State Cooperation and Accomplishments
  NEG-ECP Mercury Action Plan
• National State Cooperation and Accomplishments/
  ECOS and the Quicksilver Caucus
• Hot state issues TMDL/CAMR
• Conclusions

3
WHY IS MERCURY A PROBELM

• Childrens Health brain damage risk. More than
  400,000 newborns exposed to unsafe levels each
  year in US.
• Adult Health Increasing evidence of heart attack
  risk
• Wildlife also at risk loons, otters, even some
  songbirds
• 44 states with fish consmption advisories in
  effect 2,426 waterbodies 13 million lake acres
  767,000 river miles
• TMDL estimates gt90 reduction in inputs likely
  needed in many waterbodies

C. Mark Smith PhD, MS. 2003.
4
States with Mercury Fish Consumption Advisories
(2002)
NOTE This map depicts the presence and type of
fish advisories issued by the states for mercury
as of December 2002. Because only selected
waterbodies are monitored, this map does not
reflect the full extent of chemical contamination
of fish tissues in each state or province.
5
Economic Impacts Are Significant

• Mt. Sinai School of Medicine Mercury Health Cost
  Study (2005)
• Costs from mercury exposure from all
  anthropogenic sources
• Only considered neurotoxicity (decreased IQ) in
  children
• US costs 2,200,000,000 43,800,000,000/ year
• Costs per pound of mercury pollution (based on
  utility emissions) 13,000 (range 1,000 -
  66,000)
• Harvard Center for Risk Analysis/NESCAUM Study
  (2005)
• Addressed utility emissions only.
• Benefit estimate 100,000,000 to 5,000,000,000/
  year
• 1,500 to 74,000 per pound of mercury emissions
  prevented.

6
Mercury Hotspots Exist
7
STATE LEADERSHIP

• 16 states implementing mercury reduction
  strategies
• Extensive interstate/regional cooperation
• Binational Toxics Strategy EPA/Envir. Canada/
  Great Lakes States/ Provinces established
  virtual elimination goal for mercury
• New England Governors/ Eastern Canadian Premiers
  Mercury Action Plan Adopted in June 1998
• Goals
• By 2003 50 or greater reduction in emissions in
  the NE region
• By 2010 75 reduction
• Long-term virtual elimination
• Quicksilver Caucus

C. Mark Smith PhD, MS. 2003.
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Emissions Reduced Through State Leadership

• Regional 2003 goal exceeded estimated 55
  reduction in regional emissions
• MA reductions gt 60 (close to 70)
• Achieved through aggressive regulations on major
  sources
• Trash incinerators limit 3-fold more stringent
  than USEPA gt90 (10-fold) reduction in MA
  through new controls and mandatory source
  separation
• Medical Waste Incinerators limit 10-fold more
  stringent 100 reduction in MA ME

C. Mark Smith PhD, MS. 2003.
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NE-ECP Regional Emission Reductions by Sector
84
84
10
98
93
C. Mark Smith PhD, MS. 2003.
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Actions To Address Remaining Emissions

• Utility sector (2003 emissions 1,100 lbs)
• MA (85 control 2008 and 95 2012) CT (90
  control 2007)
• Region seeking stronger USEPA regulations
• Oil combustion (2003 emissions residential,
  1,800 lbs commercial, 1,100 lbs.)
• Regional project to improve baseline emission
  factor for heating oil and assess possible
  multi-pollutant improvements from lower sulfur
  fuel

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Actions To Address Remaining Emissions

• Products related
• Dental sector
• 66 regionally, exceeding 2005, 50 goal.
• 80 MA dentists w amalgam separators
  regulations now in place. 98 compliance. 75
  2007 goal adopted.
• MSWC source separation requirements in MA ME
  legislation across NE to further reduce emissions
  related to products

C. Mark Smith PhD, MS. 2003.
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MA Deposition Hotspot Monitoring
Yellow 10-30 ug/m2 Lt red 30-100 Red gt100
Northeast Total Deposition (1998 NE Regional
Mercury Study)
Regional Langrangian Model of Air Pollution
(RELMAP) output
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Estimated MA Statewide and High Dep. Area Mercury
Emissions
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Total Mercury Deposition
Pre NEG-ECP Mercury Action Plan (1996 Northeast
Hg Emissions)
Post NEG-ECP Mercury Action Plan (2002 Northeast
Hg Emissions)
Based on REMSAD model using 1996 and 2002
Northeast emission inventory data. Draft,
December 2005.
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EPA Fish Criterion 0.3 mg/kg
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Quicksilver Caucus Group

• Formed in May 2001
• Caucus members are comprised of state
  environmental leaders which include
• Environmental Council of the States (ECOS)
• Association of State and Territorial Solid Waste
  Management Officials (ATSWMO)

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Quicksilver Caucus Group (cont.)

• Association of Local Air Pollution Control
  Officials (ALAPCO)
• Association of State and Interstate Water
  Pollution Control Administrators (ASIWPCA)
• Association of State Drinking Water
  Administrators (ASDWA)
• National Pollution Prevention Roundtable (NPPR)

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Recent Accomplishments

• Conducted a survey on State Activities related to
  Mercury. Published the 2005 Compendium of
  States Mercury Activities
• Hosted teleconference workshops on state
  approaches to auto switch collection and
  recycling
• Continue to facilitate state input to EPAs
  efforts re national auto switch program
• Completed report on state mercury product
  labeling programs
• Working with EPA on International Mercury
  Products Partnership (e.g. Ned Brooks (MN) and
  Maria Peeler (WA) assisted with products workshop
  in Mexico)

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Recent Publications

• Mercury Product Labeling Information for States
  (March 2006)
• 2005 Compendium of States Mercury Activities
  (October 2005)
• Removing Mercury Switches from Vehicles- A
  Pollution Prevention Opportunity for States
  (August 2005)

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Quicksilver Caucus Priorities

• Strengthen State Capacity to Reduce and Manage
  Mercury in the Environment
• Educate and Engage Key Public and Private Sector
  Leaders
• Share state expertise and experience nationally
  and internationally to reduce atmospheric
  deposition sources
• Plan and Hold Technical Workshops
• Position QSC to Implement Action Plan
• Plan and Hold Third Educational Workshop for
  States

22
Hot State Issues

• Mercury TMDLs
• TMDL alternative proposal
• Regional-statewide TMDL
• CAMR
• Many states pursuing/adopting alternatives
• Mercury in products
• States across US implementing labeling
  requirements phase-outs of unnecessary uses
  collection-recycling requirements

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MERCURY TMDLs WHAT IS THE ISSUE?

• Most mercury impaired water bodies impacted
  primarily by atmospheric deposition
• In NE estimated 60 of mercury coming from
  out-of-region and cannot be addressed by impacted
  states
• New England and other states already implementing
  aggressive strategies to eliminate
  in-state/in-region sources.
• Efforts go well beyond federal requirements
• Requiring state derived TMDLs for waterbodies
  impacted by such out-of-state sources wastes
  resources
• Federal action needed to address air transport

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MASS/RI/MAINE Hg TMDL 4B Proposal

• Submitted as Innovations Project
• Aggressive regional/state mercury action plans in
  lieu of TMDLs for air impacted waterbodies
• Accountability
• Waters would remain on category 4(B) of
  Integrated List until advisories lifted
• Contingent on documentation of continued
  commitment and effective progress.
• Highlights need for comparable federal air limits

C. Mark Smith PhD, MS. 2003.
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STATE CONCERNS ABOUT CAMR

• Trading may contribute to hotspots
• Some state emission caps exceed their actual
  current emissions

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STATE CONCERNS ABOUT CAMR (continued)

• TMDL analyses by MN, MA, ME, RI indicate that
  emission reductions of 80 or greater are needed
• CAMR falls short
• 2010 emission cap of 38 tons per year (TPY)
  represents 21 reduction
• 2020 emissions are predicted to be about 24 TPY,
  a 50 reduction (due to banking)
• In contrast, several existing state regulatory
  programs will achieve 80-90 reductions over
  shorter timeframes

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STATE CAMR OPTIONS AND ALTERNATIVES

• ü  limiting emission caps so they do not exceed
  current emissions
• ü  opting out of, or restricting, the federal
  trading program to limit the sale of local
  in-state reductions to up-wind sources
• ü   requiring faster reductions
• ü   imposing more stringent emission limits
• ü   adopting provisions to retire or buyout
  banked emission credits.

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Controls For Mercury Pollution Cost Less Than
Controls For Other Pollutants

Mercury control using carbon injection estimated
to cost 0.02 to 0.08 cents per kilowatt-hour
(kWh), or about 15 to 60 cents per month for a
typical residential electric bill.
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CONCLUSIONS

• Mercury impacts including costs are significant
• States in the lead, individually and collectively
  
• QSC/ECOS enabling progress join us!
• Monitoring demonstrates success NE regional
  deposition reduced and mercury levels in
  fish/loons down
• But fish still unsafe
• Further reductions needed CAMR, although a step
  in the right direction, unlikely to be sufficient
  for many states to meet TMDL objectives
• Many states pursuing alternatives to improve on
  CAMR