Maine
Wastewater Control Association Position Regarding
Reduction of Mercury in the Environment
Submitted by Vivian Matkivich, MWWCA Government Affairs Committee
March 15, 2000
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 interested in
environmental protection of water resources. Our mission is to
promote environmental management practices that protect and improve
the waters and related environments in the State of Maine.
As representatives of a regulated community primarily serving the
municipalities of Maine, MWWCA believes that public environmental
policy and regulation must be based on need, scientific criteria and
a common sense assessment of environmental benefit vs. economic
impact. Thus, in 1998 MWWCA asked the Legislature to repeal an
old, unscientific standard for mercury in wastewater discharges, and
replace the law with a requirement for the State to adopt federal
water quality standards for mercury, as it has for other toxic
metals. Instead, the Legislature stayed the old law for three
years, and directed the Maine Department of Environmental Protection
(DEP) to design science based wastewater standards for mercury for
Maine waters. Additionally, the Legislature instructed the DEP
to set interim limits for all wastewater dischargers, and require
all wastewater dischargers to conduct mercury pollution prevention
activities.
Currently,
all municipal publicly owned wastewater treatment plants and most
industrial and agricultural wastewater license holders are in the
process of determining their effluent mercury concentrations with a
test that measures mercury at extremely low levels, in nanograms per
Liter (parts per trillion). The DEP will use the results of
these tests to set individual Interim Mercury Limits for each
licensee. Later this Spring, many Maine municipal, industrial
and agricultural wastewater dischargers will be issued the lowest
mercury limits in the nation.
MWWCA
supports and encourages the Mercury Pollution Prevention Plans being
developed. These help prevent the discharge of mercury into
wastewater treatment plants. And, we continue to champion the
need for science based water quality standards for mercury that are
protective of human health and water resources. But, MWWCA
members are alarmed by the current administration's environmental
policy on mercury that results in technologically and economically
unachievable mercury limits for Maine municipalities and businesses,
regardless of the environmental benefit to be gained at so much
cost.
Toxic
amounts of mercury in the environment are not only a Maine problem.
It is a national and global problem. Respected scientific
studies show that an overwhelming 90 per cent of anthropogenic
(introduced by human activities) mercury comes from air pollution.
Unfortunately, the Clean Air Act does not have the strong support or
enforcement record of the Clean Water Act. So, to alleviate
the public’s justifiable concerns about threats to public health
and wildlife conservation, several States, including Maine, have
zeroed in on the much smaller percentage of mercury being discharged
by licensed wastewater dischargers.
Almost
all controllable amounts of mercury from industry have already been
removed from wastewater, as a result of national effluent standards
and municipal pretreatment programs. Most mercury in municipal
wastewater comes from non-traditional industry (dentists, hospitals)
and from domestic, or household, sources. The Clean Water Act
specifically exempts household wastewater from regulation.
While better management of wastes will result in reductions, it is
not feasible for dentist offices or hospitals to treat their
individually small discharges of mercury to zero, or natural
background level. Therefore, a municipal wastewater treatment
plant has few options to reduce mercury discharges any lower than an
effective pollution prevention plan can take them.
MWWCA
believes that Maine is currently the only State requiring all
licensed dischargers to demonstrate compliance with a test that
measures mercury at extremely low levels, in nanograms per Liter
(parts per trillion). We understand that the State of Ohio
adopted stringent mercury limits based on a controversial study of
the threat to wildlife in the Great Lakes. New wastewater
permits there require the use of the low level mercury test.
Ohio found that wastewater treatment plants couldn't remove tiny
amounts of mercury in their effluent. Thus, Ohio has granted
compliance “variances, ” allowing a pollution prevention plan
and a higher mercury limit instead of the low mercury limits.
Ohio has also ruled that household septage is not subject to
pollution prevention planning and is entreating municipal wastewater
plants to accept septage from unsewered communities. The
plants feel forced to refuse septage because of untreatable amounts
of mercury. The States of Michigan, California and Minnesota
are in the process of lowering permit limits on mercury, but they do
not mandate use of the low level test method to demonstrate
compliance.....Yet.
On
a national level, a lot of public resources are being used to chase
down about 10 per cent of anthropogenic mercury in the environment.
Yet, these extraordinary efforts are unlikely to result in the
lifting of fish advisories or in a measurable reduction of the
threat to public health or wildlife. This is because the
overwhelming threat from mercury to human health and wildlife comes
from air pollution, which continues almost unabated. MWWCA
finds there is no common sense, economic sense, or environmental
sense in this situation.
Therefore,
MWWCA supports a national, concerted policy on reducing mercury in
the environment. The national policy should include:
-
Prohibition
on all non-essential use of mercury, either during production
of a product or as part of the product.
-
A
nationwide public education effort by federal and state
environmental agencies that informs about the amount of
mercury in household products, includes ways to properly
discard these products, and promotes the use of
alternative products.
-
Strict
controls on the import of mercury added and mercury
contaminated products.
-
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.
-
National
water quality standards for mercury in wastewater treatment
plant effluents, based on peer reviewed scientific data, which
are achievable by pollution
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