A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 September 1992
Standards for Acceptable Daily Intake (ADI)
Micrograms of mercury per kilogram of weight per day of exposure = ug/kg/day.
U.S. EPA = 0.3 ug/kg/day (EPA has recently withdrawn this standard for re-evaluation)
New Jersey: proposed = 0.07 ug/kg/day
ATSDR*: proposed = 0.04 ug/kg/day
* Agency for Toxic Substances and Disease Registry of the U.S. Department of Health and Human Services. While the US EPA sets standards the ATSDR proposes minimum risk levels to the EPA. The ATSDR’s Draft Toxicological Profile on Mercury is available by written request to: ATSDR, Division of Toxicology, 1600 Clifton Road NE, Mail Stop E-29, Atlanta, GA 30333. Fax requests acceptable. Fax to: Suzie Tucker, ATSDR, Fax #: 404-639-6315.
** “There is evidence to indicate neurologic development damage to infants who are exposed ‘in utero’ through maternal ingestion. The current EPA RfD may not be protective against the occurrence of these effects...”
** “Based on probablistic calculations using national population data (i.e. fish consumption and methylmercury levels in fish) a small fraction of the New Jersey population may already be ingesting mercury in amounts which exceed the RfD established by EPA due to consumption of saltwater fish.”
** “If child-bearing women are already potentially at risk for fetal harm from seafood consumption alone, then it is incumbent upon the state to protect them from additional sources while simultaneously determining how to reduce exposure to current seafood mercury levels. The latter does not justify allowing additional exposure from anthropogenic sources.”
** Note from Waste Not: If the State of New Jersey believes the results of their own reports then it is incumbent and imperative for the NJ Department of Health to issue a Public Health Alert so that this information is immediately and continually available to all women of child-bearing age. Unfortunately, New Jersey is proposing a technology-based-on-least-cost standard and not a health-based standard.
The N.J. Mercury Task Force was charged with developing a mercury emission standard for MSW incinerators. The Task Force’s report, considered preliminary at this time, found “that potential methylmercury ingestion from fish contaminated by mercury from incinerators could exceed” even the N.J.-proposed Allowable Daily Intake (ADI) of .07 ug/kg/day. They also found that one of the three models they were using calculated that even with a 95% reduction in mercury emissions from MSW incinerators there would be an “increase equal to 18% of the proposed” New Jersey-proposed standard. Nevertheless, the Task Force recommends the .07 ADI as “the health basis [sic: technology basis] for the establishment of a mercury emission standard for MSW incinerators...To accomplish this, mercury emissions from MSW incinerators should be reduced by greater than 95% of current levels...The cost of achieving the recommended level of mercury emission reductions is considered to be reasonable. Installing MSW incinerators’ air pollution control systems, is estimated to cost 50¢ per ton of solid waste burned.” [Note: the cost for a 1,000 tpd incinerator would be $500 a day.] Thus said, the report goes on to suggest that the most effective pollution control for MSW incinerators is the use of deep carbon beds. Apparently because of the considerable “capital costs” of deep carbon beds, NJ recommends carbon injection.
Country Permitted Limit NEW JERSEY Permitted Limit
(ug/dscm at 7% oxygen) (ug/dscm at 7% oxygen)
Sweden 65 Camden County 520
39 (annual goal) Essex County 140
Austria 65 (over 400 TPD) Glouscester County 723
130 (under 400 TPD) Warren County 356
Netherlands 65
Germany 65 NOTE: Mercury in flue gas released
Denmark 65 from MSW incinerators estimated to be:
Switzerland 120 Mercuric Chloride = 70 %
European Community 260 (mercury plus cadmium) Elemental Mercury = 7 %
Water to Fish Bioconcentration Factors: “Laboratory studies indicate a range of 2,000 to 5,000 for inorganic mercury and a range of 10,000 to perhaps as high as 100,000 for organic mercury. Selected field data, for levels of total mercury, indicate a range of 100,000 to 200,000.”
Sediment-to-Fish Bioconcentration Factors: Bioconcentrations: “approximately 1 to approximately 12. These factors are for total mercury levels in both sediment (dry weight basis) and fish tissue (wet weight basis).”
Background to the N.J. Mercury Task Force: The New Jersey State process to appoint a Mercury Task Force began after Camden County, NJ, officials voted to approve the first health-based mercury emission standard in the U.S. on 9-19-91 This health-based mercury standard was initiated by then County Freeholder Mark Lohbauer. (Mark was later appointed to the Mercury Task Force.) The Commissioner of the NJDEPE denied the right of Camden County to enact this health-based standard on 12-10-91 citing “insufficient technical and scientific analyses to support” Camden County’s proposal. At the same time the Commissioner called for an investigation into developing a statewide standard. This report (published date: September 1992) is the first public preliminary report of that investigation. The draft to this report was, according to those who reviewed it, much stronger in its comments and recommendations. 31 people were appointed to the Task Force by the NJDEPE. They included: representatives of the N.J. regulatory community, county waste authorities, environmentalists, scientists, 2 medical doctors and representatives from Foster Wheeler, Wheelabrator, Ogden Martin & American Ref-Fuel.
Note on OGDEN MARTIN’S 800 tpd Incinerator in Stanislaud County, California. While Ogden flaunts the results of very high mercury capture rates at its Stanislaus County incinerator we were shocked to learn that those results were taken from a short-term experiment using a carbon injection system to capture the mercury. After the experiment Ogden Martin stopped using carbon injection at their Stanislaus County incinerator, and currently no mercury, or very little mercury, is being removed by Ogden’s air pollution equipment. A clear case of Ogden Martin’s greatest concern with public relations than public protection.