Maine Wastewater Control Association 
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Maine Wastewater 
Control Association

Position on the Control of Mercury in the Environment



Submitted at the NEWEA Congressional Briefing
February 2001

  The Maine Wastewater Control Association (MWWCA) is a not for profit professional organization made up principally of municipal, but also industrial, wastewater treatment plant personnel, and a consortium of environmental consultants and other persons working to safeguard Maine’s water resources. Our mission is to promote environmental management practices that protect and improve the waters and related environments in the State of Maine.

   Currently, all privately owned and publicly owned wastewater treatment plants in Maine have site-specific discharge limits for mercury.  These interim limits are based on existing conditions at each plant in the Spring of 2000, and are set at extremely low levels, in parts per trillion (nanograms per Liter). In 2001, the Maine Legislature is  considering a proposal from the Maine Department of Environmental Protection (DEP) to set a statewide specific limit for mercury of 0.2 parts per trillion parts of water, which is bellow the level that laboratories can measure with any degree of certainty.

   The DEP’s proposal incorporates the controversial United States Environmental Protection Agency “fish tissue residue” standard that is based on a study of two fish eating populations; one in the Seychelles Islands and one in the Faro Islands. The proposed statewide Maine limit would be lower than any of Maine’s permittees could reasonably achieve under current conditions.  There is no known technology for achieving such a low level in discharges of this size (volume).   Technologies that may get wastewater treatment plants' discharges into the single nanograms per Liter range are estimated to cost municipal taxpayers and ratepayers from $10 million[1] -$100 million[2] dollars per pound of mercury removed.

   MWWCA members are dismayed to know that even if all wastewater treatment plants stopped discharging wastewater to Maine's rivers today, it would still be unsafe for people to eat the fish in Maine's rivers tomorrow. That is because more than 90% of the mercury found in Maine's waters comes from air pollution[3].  Thus, the MWWCA vigorously supports and encourages our congressional delegates’ work to control mercury air pollution, including Congressman Tom Allen’s sponsorship of H.R.2667, The Omnibus Mercury Emissions Reduction Act of 1999 and H.R. 2980, The Clean Power Plant Act of 1999.

   Nearly all controllable amounts of mercury from traditional industry have been addressed, as a result of national effluent standards and municipal pretreatment programs. Now, most mercury in municipal wastewater comes from non-traditional industry (dentists, hospitals) and from domestic, or household, sources. While better management of wastes will result in reductions, it is not feasible for dentist offices or medical laboratories to treat their individually small discharges of mercury to zero, or “natural background” level.  MWWCA supports and encourages continuing the practice of  “pollution prevention” in lieu of trying to achieve unattainable standards.  Aggressive source reduction can significantly reduce the discharge of mercury into wastewater treatment plants.  

   However, to make source reduction work, there is a need for both federal and state assistance, especially in the areas of public policy and public education.   Up to 138 parts per trillion of the mercury coming into wastewater treatment plants originates in private households, mostly from dental amalgam deterioration, but also from many common household products.[4]     Therefore, MWWCA enthusiastically applauds and supports Senator Susan Collins’ proposal[5] for a nationwide ban on mercury fever thermometers that includes a comprehensive plan for reducing or eliminating many other mercury added products.    MWWCA encourages this kind of dynamic federal leadership which gets out the message that consumers can significantly reduce mercury in the environment by making informed choices.

   On a national level, a lot of public resources are being used to identify and contain the sources of the mercury that is discharged from wastewater treatment plants.  Yet, these extraordinary efforts cannot by themselves result in the lifting of fish advisories or in a measurable reduction of the threat to public health or wildlife.  In order to succeed, our nation’s leaders must also assure that there are simultaneous efforts to identify and remove sources of mercury in our homes and businesses, and to significantly curtail mercury emissions from utility and waste combustors.   Therefore, MWWCA asks our Congressional delegates to continue their support of a concerted national policy for removing toxic mercury from the environment. This national policy should include:

 

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Prohibition of all non-essential use of mercury in industry, either during the manufacturing process or as part of the finished product.  

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A nationwide public education effort, led by federal and state agencies, that provides information to consumers about the amount of mercury in household products, promotes the use of alternative products, and provides information about recycling and proper disposal methods for waste products.  

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Strict controls on the importation of mercury-added and mercury-contaminated products.  

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Support of a federal repository for recycled mercury that will eliminate new mercury mining activity, and keep toxic mercury wastes out of the environment.  

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A national goal of significant reduction in mercury air emissions, bolstered by changes to the Clean Air Act that set measurable, enforceable standards for mercury.  

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National water quality standards for mercury in wastewater treatment plant effluents, based on peer reviewed scientific data, which are achievable by implementing concerted pollution prevention and source reduction measures.

If you have questions about MWWCA's position on the Control of Mercury in the Environment or other issues involving clean water, please contact us:

Vivian Matkivich
MWWCA Government Affairs Committee

c/o Lewiston-Auburn 
Water Pollution Control Authority

535 Lincoln Street
Lewiston, Maine 04240

Telephone: (207) 782-0917 
FAX: (207) 782-9877 
e-mail: lawpca@gwi.net 

Footnotes

[1] Reash, Robin J., Loeffelman, Paul H., Hollback, John E., Tiell, Jennifer and Martin, Gary. “Now You Can Choose: Treat Mercury in Water at $10 Million Per Pound or Take Ohio EPA’s Statewide Variance with Pollution Minimization”, Environmental Regulation and Permitting, Spring 1998, pgs. 29 - 38.

[2] “Economic Impacts of EPA’s Draft Final TMDL Rule San Francisco Bay Case Study” July 6, 2000.

[3] Northeast States and Eastern Canadian Provinces “Mercury Study; A Framework for Action” February 1998, pg. VIII-30.

[4] Association of Metropolitan Sewerage Agencies “Evaluation of Domestic Sources of Mercury” August 2000, p. 3.

[5] “A BILL to amend the Solid Waste Disposal Act to reduce the quantity of mercury in the environment by limiting use of mercury fever thermometers and improving collection, recycling, and disposal of mercury, and for other purposes.” February 15, 2001

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