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Advisory Committee on Mercury Pollution
Meeting #55: Friday, October 1, 2004
Time: 9:30 am to 11:30 pm
Location: Conference Room, Environmental Assistance Office
Laundry Building, Waterbury State Complex, Waterbury, Vermont
MINUTES
Members Present:
Bill Bress, Vermont Department of Health
Neil Kamman, Agency of Natural Resources, Water Quality Division
Ruma Kohli, chemical Management Program Manager, IBM, Burlington
Rich Phillips, Vermont Agency of Natural Resources, Environmental Assistance
Guests Present:
Jeff Merrell, Vermont Agency of Natural Resources, Air Toxics Division
Heidi Hales, Vermont Agency of Natural Resources, Air Toxics Division
Gary Gulka, Vermont Agency of Natural Resources, Environmental Assistance
Karen Knaebel, Vermont Agency of Natural Resources, Environmental Assistance
The Committee members and interested parties gathered in the Conference Room of the Environmental Assistance Office, Waterbury State Complex. Rich
Phillips called the meeting to order.
Agenda Item 1-
Possible changes to today's agenda.
- Discuss appointment expiration for Mary Canales
- Discuss letter received from VDH
Agenda Item 2-
Update by Air Quality Division regarding emissions from crematoria - regional efforts and contribution to Vermont's air mercury inventory.
Jeff Merrell and Heidi Hales with the Air Toxics Division of the Department of Environmental Conservation distributed the following document.
Air Pollution Control Division Summary for
Advisory Committee on Mercury Pollution Meeting
October 1st, 2004
- We have begun updating the 2002 Vermont Mercury Emissions Inventory. Updates to the new version include:
- Hg emissions from on-road mobile sources have been added. Since the last version of the inventory, EPA's MOBILE6 model has made it possible
to estimate air emissions of various toxic compounds including Hg. We made model runs with Vermont county-specific, monthly data (min/max
temp, fuel parameters, etc.) using the MOBILE6 model, and then applied the resulting Hg emission factors for each vehicle type to vehicle
miles traveled (VMT) and traffic count data by road type. From this process, we estimate Hg emissions from this sector to be 69.5 lbs in 2002,
which is 41% of the total in state Hg emissions (from inventoried sources). This is a large addition to the inventory.
- Minor modifications have been made to the calculation of emissions from the "Residential Heating" sector. In the course of calculating
emissions for EPA's 2002 National Emissions Inventory (NEI), a better methodology was developed and made available. The updated 2002 Vermont
Mercury Emissions Inventory will use this approach. The methodology change resulted in a slightly lower Hg emissions estimate for this sector
(56 lbs updated method vs. 75 lbs previous method).
- Hg emissions from crematoria in VT:
- At this time we have not updated our estimate for crematoria Hg emissions. However, due to the inventory updates mentioned above, we now
estimate that human cremation is responsible for 4.8% (previously 6.8%) of the Vermont Hg emissions.
- It is important to note that in the 2002 Vermont Mercury Emissions Inventory we have assigned a low 'confidence rating' to our ability to
accurately quantify Hg emissions from crematoria. This is primarily due to widely ranging emission factors.
- Emission standards and regulatory efforts:
- At this time I am not aware of any efforts to regulate Hg emissions from crematoria in the U.S. The State of Washington passed a mercury
bill (HB 1002) during 2003 that actually exempts crematoria from any requirements of the law. Norway & Germany have developed air emissions
standards for crematoria.
- Federal EPA standards for mercury releases from crematoria were to be developed by Nov 2000, but in a Federal Register Notice at that time,
EPA set a new release date of Nov. 15, 2005.
- Germany, Norway, and Sweden have done some development and installation of Hg control technology for crematoria. Mercury emissions from
dental amalgams during cremation may only be reduced by removing the amalgams before cremation (which is not a common practice), or by filtering
the gaseous emissions from a crematorium. Since a flue gas cleaner is an expensive control technique for a crematorium, prevention by substituting
other materials for mercury amalgams during normal dental care might be a preferred approach. Sweden has also begun investigating an alternative
to cremation via a liquid nitrogen freeze-dry process that eliminates mercury emissions to the air.
- Mercury Compounds and Mercury Alkyl Compounds are listed in VT as Category II (causing chronic systemic toxicity due to long-term exposure)
VT Hazardous Air Contaminants (HAC). Any stationary air pollution source having actual air emissions exceeding the established Action Level
(A.L.) for a specific HAC will be subject to the authority of Vermont Air Pollution Control Regulations Section 5-261 (Air Toxics Rule), and
must achieve a determined Hazardous Most Stringent Emission Rate (HMSER).
- Calculations performed by the VT APCD Permits Section using the best available emission factors indicate that individual crematoria operating
in the State of Vermont would not exceed the existing HAC action level for Mercury Compounds (elemental, inorganic, and non-alkyl organic).
This is true assuming either maximum potential or actual operating hours. Speciation data are sparse for Hg emissions from crematoria; however,
if the mercury emissions were in the form of Mercury Alkyl Compounds, then individual crematoria would begin to approach the respective Action
Level. This seems unlikely though as default speciation data from EPA suggest that the majority (~80%) of Hg emissions from similar combustion
activities would be elemental Hg and inorganic compounds, rather than alkyl organic. (See: http://www.dnr.state.wi.us/org/aw/air/staff/hganalysisteam/docs/hgspeciation.pdf)
Based on these results, we do not expect Action Level exceedances at individual crematoria in VT at this time.
See below for updated summary graphics for 2002 Vermont Mercury Emissions Inventory
(As of Oct 1, 2004 - inventory subject to further updates.)
Jeff pointed out to the Committee that since the 2002 Emissions Inventory, there was one substantial change in that the inventory now includes
Vermont specific emissions (auto exhaust) that add about 69.5 pounds into the existing inventory. The only other change was information from the
2002 National Inventory for EPA which showed fuel allocation reduction from 79 to 56 pounds for household burning. Those changes dropped crematoria
down 2% because mobile emissions were added. The largest non-fuel source is crematoria.
The Committee provided the following comments:
- Given the current set of regulations there cannot be any changes regarding crematoria.
- Suggestion to pursue a voluntary approach toward crematoria emissions.
- Suggestion to encourage morticians to voluntarily remove teeth that contain mercury fillings.
- Comment that emission controls for crematoria in Europe provide a range of success in the mid 90% reduction levels.
- If the emissions do not exceed the action level and if they do not exceed the air toxics rule, there is no real ability to regulate or make
change.
- The Committee believes that the technology exists to reduce emissions from crematoria.
- Suggestions that the focus should be on not placing the amalgams in patients in the first place then emissions from crematoria would not be
an issue.
- Average life of a dental filing is from 10-15 years - suggestion to encourage people to make the change to non-mercury fillings at that point.
- Suggestion to set up a voluntary program like the organ donor cards where the mortician is instructed to remove the amalgam fillings prior to
cremation.
- Committee concluded that:
- There is no expectation that crematoria will exceed any emission levels that would trigger non-compliance with emission regulations.
- Mobile source is a new category and emission factor is reflective of automobile emissions - may be a potential area of focus in the future.
- Some technology should be developed regarding home fuel burning.
- Contributions from dental offices are 31 pounds; although amalgam separators do not address air emissions, they address other media sources
such as wastewater. Suggestion to pursue installation of amalgam separators.
- Suggestion to include "trends" in emissions report.
Agenda Item 3-
Updates: School Mercury Video Project, Lamp Recycling Outreach Project, Outreach to Doctors' Offices/Clinics, Outreach to Sensitive Populations.
Karen Knaebel, distributed the following document to update the Committee on work in process on the School Mercury Video Project (MVP), Outreach
to Doctors' Offices/Clinics, and Outreach to Sensitive Populations (MS SPOC).
School Mercury Video Project
- Formed a committee (MVP) - composed of:
- Carlos Haase, worked for DEC air quality, now employed by Green Mountain film festival
- Monica Ostby, 15 years advertising experience in marketing/ and production - clients (AT&T, UPS, Time Inc) - specializing in direct-response
television - Was director of advertising of Time, Inc. in addition to overseeing the creative process and marketing - negotiated media trade
relationships
- Christopher, intern for DEC
- Doug Kievit-Kylar, DEC, school liaison
- Karen Knaebel, DEC mercury education and reduction coordinator
· Viewed several video formats, mercury films
- Started a story board to lay out the 15 minute video and targeted take home messages
- Will be collecting footage, graphics, contact etc. before going out to bid -cost issues
- Target date for completion & distribution - September 2005
Outreach to Sensitive Populations
Mailing to Town Health Officers of fish poster
- Mailing to child care providers of mercury in fish brochure and pregnant woman poster - another mailing of fish poster and card targeted for
January
- Mailing of poster to agents who sell fishing licenses
- Upcoming mailings
- Newlyweds
- Libraries
- Naturopathic Physicians
- Childbirth Educators
- Marinas
- Currently working on survey questions for parents of newborns
- Developed return post card to order materials
- BRFSS survey question denied - may not submit for next year because of only being able to collect information for one year - cannot compare
data from previous year to determine if there is an increase in awareness
Outreach to Doctors' Offices/Clinics
- Database developed to pair doctors with offices
- Survey faxed to each office regarding mercury use in products with letter from VDH and DEC Commissioners
- Currently contractor is following up on survey response
- Information booklet developed as information piece to doctors' offices which includes:
- General information and resources
- Inventorying and planning guidance
- Mercury spill guidance
- Handling, recycling and disposal guidance
- Health care provider information
- Patient information materials to be disseminated with information booklet:
- 175 - Pediatrics, OB/GYN, Family Practice-each will receive 25 mercury in fish brochures, display stand, poster and reorder card
- 250 - Internal Medicine and Specialists (outside of hospital walls) will receive on brochure and an order card
- 15 Hospitals - get 25 brochures and 25 order cards
Gary Gulka updated the Committee on the Lamp Recycling Outreach Project
- DEC obtained a grant from EPA to increase the recycling of fluorescent lamps of approximately $60,000 to be used primarily for outreach and
advertising.
- One year left in the grant - majority of work is already completed such as the development of a brochure and poster, newspaper ads and inserts,
direct mailings, outreach to facility managers, radio ads.
- When calendar year is over the amount of lamps recycled will be compared to last year's numbers to determine the impact of the outreach efforts.
- Two solid waste districts indicate that have already collected more lamps in half of this year as compared to all of the previous year.
- Electrical wholesalers who sell the lamps and take back the spent lamps for recycling also indicate that their recycling rate has increased.
Agenda Item 4-
Updates and other topics not on agenda.
Bill Bress expressed an interest in a PowerPoint presentation that was a communication put together by the state of Washington regarding mercury
risk in their Native American population. The Committee will try to obtain a copy for review if possible.
It was brought to the attention of the Committee that the public health specialist position that was previously filled by Mary Canales was still
vacant since March. The Committee discussed the possibility of a replacement. A suggestion was made for the possibility a staff person from the
Vermont Dept. of Health. The Committee had concern in wanting to obtain a replacement outside of state government. Karen will check with Mary and
others to see if they have any ideas for recommendation.
The Committee briefly discussed a response letter that was received from Donald R. Swartz, Director of the Division of Health Improvement in the
Vermont Department of Health. This letter indicated that the Health Department supported the efforts to inform the consumer of risks, benefits,
and concerns that relate to treatment options through a brochure. The Committee already reviewed the two brochures developed by the ADA and the
Maine brochure. The VDH letter identified that of the three sample brochures, they were in favor of the Maine brochure. The Committee decided to
forward a copy of the letter they received from Donald Swartz to the Dental Society with a cover letter to offer to work with the society toward
providing a brochure to their patients. The letter will be drafted and circulated to the Committee for comment.
Agenda Item 5-
Set date and agenda for next meeting.
The next meeting will be held 9:00 am to 12:00 pm, Friday, November 12, 2004 at the IBM in Burlington, Vermont. IBM will provide a tour of the
facility from 9:00 am to 10:00 am and the Committee will meet afterward
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