Mercury Policy in the Great Mercury Policy in the Great Lakes Basin: Past Successes Lakes Basin: Past Successes

and Future Opportunitiesand Future Opportunities

Joy Taylor Morgan,Michigan Department of Natural Resources and Environment

Alexis Cain, USEPA Region 5Ned Brooks, Minnesota Pollution Control Agency

Integrating Multimedia Measurments in the Basin Funding provided by GLAD Program

Ann Arbor, MichiganJuly 13-15, 2010

OutlineOutline

Mercury Reduction Progress in BasinMercury Reduction Progress in BasinGreat Lakes StrategiesGreat Lakes StrategiesHow Big a Priority is Mercury?How Big a Priority is Mercury?Remaining SourcesRemaining SourcesRecommendations for Future PoliciesRecommendations for Future Policies

Background

Great Lakes States have been a leader in Hg Reduction ActivitiesGreat Lakes States have been a leader in Hg Reduction Activities MI - 1970s with the recognition and prevention of tons of mercury being MI - 1970s with the recognition and prevention of tons of mercury being

discharged to the Basin from chlor-alkali plants discharged to the Basin from chlor-alkali plants Lead the effort towards national registration cancellation for PMA use in Lead the effort towards national registration cancellation for PMA use in

latex paint formulations. latex paint formulations. Voluntary release of information by the automobile sector that 9.8 metric Voluntary release of information by the automobile sector that 9.8 metric

tons of mercury enter domestic automobiles each year in 1996 tons of mercury enter domestic automobiles each year in 1996 MN ex. – Duluth WWTP – caustic cleaners, first thermometer ban – in US MN ex. – Duluth WWTP – caustic cleaners, first thermometer ban – in US

andand TMDLhttp://www.pca.state.mn.us/index.php/topics/mercury/mercury.html

Major U.S. Mercury Emissions Source Categories, 1990 and 2005

0

10

20

30

40

50

60

70

To

ns

1990 2005

Great Lakes Region of USGreat Lakes Region of US

8 States -21% of US Population8 States -21% of US Population34 % of US Mercury Emissions34 % of US Mercury Emissions38% of US Electric Utility Emissions38% of US Electric Utility EmissionsHigher share of heavy industry, coal useHigher share of heavy industry, coal use34.9 tons/yr mercury emissions34.9 tons/yr mercury emissions

Great Lakes State Mercury Emissions, 2005Metals Production

14%

Non-Utility Fuel Combustion

9%

Waste Incineration

8%

Portland Cement4%

Chlor-Alkali 3%

Other5%

Utility boilers57%

Total: 34.9 tons

Sources of Mercury Emissions Sources of Mercury Emissions

within the Great Lakes Stateswithin the Great Lakes States

Fossil Fuel Combustion Fossil Fuel Combustion mostly coal for electricity, steammostly coal for electricity, steam

Mining and metal smelting Mining and metal smelting mostly iron mostly iron

Mercury use in Mercury use in productsproducts Mercury cell chlor-alkali plantsMercury cell chlor-alkali plants Releases to air water and landReleases to air water and land

mostly airmostly air

Great Lakes Binational Toxics StrategyGreat Lakes Binational Toxics Strategy

•US-Canada Agreement, Signed US-Canada Agreement, Signed 19971997•Virtual Elimination of PBTs to Virtual Elimination of PBTs to Great LakesGreat Lakes•Creation of Stakeholder Creation of Stakeholder Workgroup to Identify Cost-Workgroup to Identify Cost-effective Reductions; promote effective Reductions; promote voluntary actionvoluntary action

U.S. Mercury Emissions: 2006 Challenge, 1990 Baseline

0

50

100

150

200

250

300

1990 2002 2006Challenge

ton

s

Challenge

Other

Gold Mining

Chlor-alkali

Industrial Boilers

Municipal Incin.

Medical Incin.

Utility Boilers

U.S. Mercury UseU.S. Mercury Use

050

100150200250300350400450500

1995 1997 2003 est 2006Challenge

ton

s

Challenge

Other

Lighting

Dental

Measurement &ControlElectrical

Chlor-alkali

Source: US Geological Survey, Minerals Yearbook, 1996, 1997. Chlorine Institute Annual Report to EPA, 2004; National Electrical Manufacturer’s Association, direct communication, 2004.

Created in 2004 by Presidential OrderCreated in 2004 by Presidential Order Overseen by: Federal Interagency Task Force; Overseen by: Federal Interagency Task Force;

Mayors; Governors; Tribal Leaders; GL Congressional Mayors; Governors; Tribal Leaders; GL Congressional DelegationDelegation

December 2005 GLRC Report called for “basin-wide December 2005 GLRC Report called for “basin-wide mercury product stewardship strategy”mercury product stewardship strategy”

Products strategy team: included all GL State Products strategy team: included all GL State environmental agencies, tribes, citiesenvironmental agencies, tribes, cities

Products Strategy completed —June 19, 2008Products Strategy completed —June 19, 2008

Great Lakes Regional CollaborationGreat Lakes Regional Collaboration

Recommendation Recommendation

Mandated best management practices for Mandated best management practices for mercury containing wastes for dental offices mercury containing wastes for dental offices (including amalgam separator installation)(including amalgam separator installation)

Mercury Emissions Reduction Mercury Emissions Reduction Strategy-Strategy- Mission: To write a Basin- Mission: To write a Basin-

wide strategy to reduce mercury wide strategy to reduce mercury emissions in the Great Lakes Regionemissions in the Great Lakes Region

(Council of GLs Governors Rec)(Council of GLs Governors Rec)

Focus on 7 Broad Sector Focus on 7 Broad Sector CategoriesCategories

Utility boilersNon-Utility fuel combustion Mercury cell chlor-alkali

plantsMetals production Mercury emission related to

product use and disposal Cement production Waste incineration

Cross-Cutting Cross-Cutting RecommendationsRecommendations

All states should require BACT for new All states should require BACT for new & modified sources – considering a & modified sources – considering a threshold < 10 lbs/yrthreshold < 10 lbs/yr

Recommend to EPA under CAA 112(a)Recommend to EPA under CAA 112(a)(1) a lesser quantity definition of major (1) a lesser quantity definition of major source for Hgsource for Hg

Consider mandatory reporting for Consider mandatory reporting for sources 5 lbs or <sources 5 lbs or <

How Big a Priority?How Big a Priority?

Depends...Depends...

Contributions of In-Region and Out-of-Region Sources to In-Region

Deposition

1998 2002Source: NESCAUM, based on REMSAD modeling

Global Background (67.1%)

Non-Northeast States (14.7%)

Northeast States (13.6%)

Re-emission (2.8%)

Canada (1.8%)

Source Attribution of Mercury Deposition to the Northeastern States *

* Based on August 2008 results described in: http://www.epa.gov/owow/tmdl/pdf/final300report_10072008.pdf

• Approximately 70% originates from outside the US

_______________

7

Relative Contributions among US States* (without global sources)

Northeast (48.2%)

PA (21.7%)

NJ (5.6%)

OH (5.5%)

WV (3.9%)

MD (3.7%)

MI (2.0%)

VA (1.5%)

IN (1.3%)

KY (1.2%)

NC (1.1%)

IL (0.9%)

Rest of US (3.4%)

• The contribution from Northeast States is roughly equal to that from the 11 States mentioned in the petition: 48%

* Values shown cited in Northeast States’ 319(g) Petition & based on Nov. 2006 EPA Office of Water Draft modeling results. Results are virtually identical to that from the Aug. 2008 final EPA modeling for the eastern US found at http://www.epa.gov/owow/tmdl/pdf/final300report_10072008.pdf

8

_________________

CWA § 319(g)(1) 33 U.S.C. § 1329(g)(1)

“If any portion of the navigable waters in any State which is implementing a management program approved under this section is not meeting applicable water quality standards or the goals and requirements of this chapter as a result, in whole or in part, of pollution from nonpoint sources in another State, such State may petition the Administrator to convene, and the Administrator shall convene, a management conference of all States which contribute significant pollution resulting from nonpoint sources to such portion.”

How Big a Priority Should Mercury Reduction Be?

Economic analyses show wide variation of cost estimates for methylmercury exposure, based on: Whether or not neurological effects exist below a

threshold Whether mercury is believed to have cardiovascular

impacts Most analyses don’t include wildlife/ecosystem impacts

Most mercury abatement policies can be justified using the higher estimates of mercury damages

How Big a Priority?

Mercury Damage Cost Estimates (as share of GDP) Global: 0.005% (neuro only)– Sundeth, et al. U.S.-only

0.03% of GDP (neuro only)– Rice&Hammit 0.2% of GDP (neuro + cardiovascular)– Rice&Hammit 0.02-0.4% (neuro only)– Trasande, et al.

High costs for a single pollutant– at the high end of the range, comparable to lead poisoning

Lower costs than those estimated for ozone and fine particulate pollution, or for climate change

Remaining SourcesRemaining Sources

Manufacturing Facilities Iron and Steel Facilities - Fe mines - EAFs - Shredders Life Cycle Product Emissions Crematories

Remaining OpportunitiesRemaining Opportunities

Linking CWA and CAA effortsLinking CWA and CAA effortsEngaging EPA with current priorities such Engaging EPA with current priorities such

as children’s healthas children’s health Incorporating energy and climate change Incorporating energy and climate change

goalsgoalsUtilizing all the tools under Section 112 CAAUtilizing all the tools under Section 112 CAAFurthering international relations through the Furthering international relations through the

QSC and partnerships with EPA, etc.QSC and partnerships with EPA, etc.

Contacts:Joy Taylor Morgan, MDNRE

taylorj1@michigan.gov(517) 335-6974

Alexis Cain, EPA (312) 886-7018cain.alexis@epamail.epa.gov

Ned Brooks, MPCA (651) 757-2247ned.brooks@state.mn.us

For Further Information:

www.michigan.gov/dnrewww.michigan.gov/dnre

GLRC Mercury Strategies GLRC Mercury Strategies Available at:Available at:

http://www.glrc.ushttp://www.glrc.us

http://glrppr.orghttp://glrppr.org

The End

Scope of the ProblemScope of the Problem

3

Mercury Exposure Pathway

methylationmethylation

Impacts • Best documented

impacts on the developing fetus: impaired motor and cognitive skills

• Possibly other impacts

Wet and Dry Deposition

Emissions and

Speciation

AtmosphericTransport and

Deposition

Ecosystem Transport, Methylation, and Bioaccumulation

Consumption Patterns

Dose Response

Fishing• commercial• recreational • subsistence

Mercury transforms into methylmercuryin soils and water, then can

bioaccumulate in fish

Atmosphericdeposition

EmissionsFrom Power

Plants and Other Sources

Humans and wildlife affected primarily by eating fish containing mercury

OceanLake

Why is Mercury a State, Regional and Global Why is Mercury a State, Regional and Global Priority?Priority?

Very Toxic: brain; kidneys; immune system; possibly cardiovascular system.

Developing brain of fetus/children particularly at risk

several hundred thousand newborns per year at risk in U.S

Adults: possible cardiovascular risk Contributes to antibiotic resistant

bacteria

Minnesota’s Statewide Mercury TMDL

Most (>99%) of mercury contamination comes from air sources

90 % of mercury deposited in state comes from outside of the state

Total Maximum Daily Load: 93% reduction in manmade deposition (from 1990) to

allow more frequent fish consumption Reduce MN air sources to 789 lb/yr Water point sources not to exceed 1% of total

mercury load allocation (24 lb/yr)

1,8581,661

500358 301

695

565

437

304181

736

841

841

841

211

25

25

25

25

25

0

500

1,000

1,500

2,000

2,500

3,000

3,500

2005 2010 2015 2018 2025

Year

Mer

cury

in

pou

nds

Difficult to Categorize

Emissions Incidental to Material Processing (mostly mining)

Largely Resulting from the Purposeful Use of Mercury

Incidental to Energy Production

TMDL goal of 789 lb

Hypothetical actual emissions.Emission may rise temporarily between goals. Reductions may occur earlier than target date.

Projected Mercury EmissionsProjected Mercury Emissions2005-20252005-2025

Based on reduction targets establishedby the Strategy Work Group

0

2,000

4,000

6,000

8,000

10,000

12,000

1990 2005 2010 2015 2018 2025

Year

Mer

cury

in p

ound

s

Incidental to energy production

Largely resulting from the purposeful use of mercury

Emissions incidental to material processing (mostly mining)

Projected Mercury EmissionsProjected Mercury Emissions1990-20251990-2025

Great Lakes States’ Mercury Great Lakes States’ Mercury Emissions Reduction StrategyEmissions Reduction Strategy

Where consensus exists, develop Where consensus exists, develop recommendations for regulatory/non-recommendations for regulatory/non-regulatory approachesregulatory approaches

Where consensus is not possible, list Where consensus is not possible, list available optionsavailable options

Stakeholder input: “solicit input from Stakeholder input: “solicit input from stakeholders on an ongoing basis using the stakeholders on an ongoing basis using the existing Great Lakes Binational Toxics existing Great Lakes Binational Toxics Strategy mercury workgroup.”Strategy mercury workgroup.”

U.S. Mercury Product and Process Use Trends

U.S. EPA. EPA’s Roadmap for Mercury, available at http://www.epa.gov/mercury/pdfs/FINAL-Mercury-Roadmap-6-29.pdf, p. 37.

Other category includes batteries, paints, laboratory applications, biocides, pesticides, pharmaceuticals, and

as a preservative in cosmetics

US Mercury Emissions, 2005US Mercury Emissions, 2005102.7 tons/yr.102.7 tons/yr.

Source: U.S. EPA

Achievements: Voluntary Achievements: Voluntary AgreementsAgreements

Chlorine Institute: commitment to reduce chlor-Chlorine Institute: commitment to reduce chlor-alkali industry mercury use 50% between 1995 alkali industry mercury use 50% between 1995 and 2006and 2006 Submitted 12 annual reports to date, documenting 94% Submitted 12 annual reports to date, documenting 94%

reduction in use (beyond reductions from shutting reduction in use (beyond reductions from shutting capacity)capacity)

Improvements in mercury accountingImprovements in mercury accounting American Hospital Association, 1998 AgreementAmerican Hospital Association, 1998 Agreement

Virtual elimination of mercury Virtual elimination of mercury from hospital wastefrom hospital waste

Formation of Hospitals for a Formation of Hospitals for a Healthy EnvironmentHealthy Environment