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MWWCA Position Concerning Standards for Mercury Discharge Vivian G. Matkivich of the Mercury Task Force has submitted the following paper detailing the MWWCA's position regarding Mercury discharge regulation. This letter was prepared for MWWCA. Click here to view a copy of the proposed bill.
The
Maine WasteWater Control Association is submitting a bill to the 119th
Maine Legislature which amends 38 MRSA 420 section 1 because the
Association believes the standard established is not explicit or
precise enough to be implemented. The MWWCA supports the goals of
mercury reduction in Maine’s waters leading to the lifting of fish
consumption advisories based upon mercury. In order to move the State
forward in a rational, productive manner the following points should
be considered: The current law (38 MRSA 420) prohibits the discharge
of mercury which "increases the natural concentration of mercury
in the receiving waters". The problem with this is that there is
no way to establish the "natural concentration". Is it the
concentration before the industrial age? When the pilgrims landed?
Because even remote areas are impacted by atmospheric deposition, and
test methods capable of measuring low enough to detect mercury in
ambient surface waters have only recently been developed (and are
still being reviewed for approval), this is a standard that is not
definable. It is widely agreed by the Maine Department of
Environmental Protection (DEP) and others knowledgeable in this area,
that atmospheric deposition is a significant source of the mercury in
Maine waters. Until we are able to quantify the impacts that come from
airborne mercury on water supplies and runoff into receiving waters,
any standard that limits point sources to concentrations below ambient
levels in a facility’s receiving water needs to be viewed
critically. The DEP has begun an ambitious sampling program that
promises to yield sound information that can be used to develop a
rational, scientifically based mercury reduction program for the State
of Maine. Unfortunately, due to the short time frame that DEP has had
to work in, the nature of the sampling and analytical method (which,
as a practical matter, necessitates "grab" rather than
"composite" samples) and the potential for seasonal as well
as diurnal variations, the data available at this time is not suitable
for its intended purpose. There has not been a solid correlation
established for the State of Maine between fish consumption advisories
and the level of mercury in point source discharges. To the best of
our knowledge, no one is able to state what level of discharge from
point sources will allow mercury concentrations in fish tissues to
decrease enough to allow the lifting of the advisories. The DEP
believes that pollution prevention is the most fruitful means to
reduce mercury in the discharge from publicly owned treatment works
(POTWs) and other point sources. The MWWCA agrees that due to the wide
range of products that contain mercury and its frequent occurrence as
a trace ingredient or contaminant in process materials, that pollution
prevention and public education are the most sensible means to address
this problem. It is important, however, to realize that these programs
require a significant investment of personnel and other resources.
Before POTWs and other point sources are required to enact pollution
prevention programs, it is only fair that the boundaries for the
programs be established, including at what point is the concentration
of mercury in a given discharge low enough that no further pollution
prevention program efforts are needed. In the absence of the language
in section 1 of 38 MRSA 420, the waters of Maine are still protected
from excessive discharges of mercury by the federal limits commonly
referred to as the "Gold Book" standard of not greater than
12 parts per trillion in fresh receiving waters and 25 parts per
trillion in marine receiving waters. Discharges which raise the
concentration of mercury in the receiving water above this level would
remain subject to enforcement by DEP, EPA and others. Finally, it is
our belief that the program the DEP has presented as its plan to
reduce mercury in the waters of the State of Maine is best pursued
through the regular rule making process before the Board of
Environmental Protection and not through legislation. This course of
action would allow time for the kind of thoughtful debate and
refinement that will be critical to gaining the support of the people
that serve our citizens in the front lines of protecting Maine’s
waters from pollution. Vivian Matkivich
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