Guest Post by Willis Eschenbach
In the process of writing my piece about Lisa Jackson and the EPA, I got to reading about the EPA passing new mercury regulations. Their regulations are supposed to save the lives of some 11,000 people per year. So I figured I should learn something about mercury. It turned out to be quite surprising … here was my first surprise:
Figure 1. Natural and anthropogenic sources of atmospheric mercury emissions. About 7,500 tonnes of mercury are emitted into the atmosphere each year. Named countries show anthropogenic (human caused) emissions for that country.
My first surprise was that far and away the largest emitter of atmospheric mercury is the ocean. The ocean? I’d never have guessed that. Other huge emitters are various lightly vegetated land areas. In addition, forests, volcanoes, and geothermal vents are significant emitters … which is the reason for my new religious crusade:
So … what are the anthropogenic sources of mercury emissions, and how much of those are emitted from North America? Figure 2 shows those values:
Figure 2. North American emissions versus the rest of the world.
As you can see, North America is not doing well at all in the mercury emission sweepstakes. The rest of the world is busting our chops, easily out-emitting us in all categories. We’ve fallen way, way behind, the Chinese are kicking our emissionary fundament-als. Not only that, but the residence time for mercury in the atmosphere is about a year, so they get our mercury … but we also get theirs …
Now, the “stationary combustion” figures are what the EPA is targeting with their new restrictions. Those are mostly the coal-fired power plants. So let’s see how much of the global emissions are caused by US power plants:
Figure 3. US power plant mercury emissions, and emissions from all other sources.
As you can see, the US power plants emit less than 1% of the global mercury emissions. Even if the EPA could get rid of every US coal plant, it will not make a measurable difference in the atmospheric mercury.
Now, here comes the fun part. The new EPA regulations will not cut out all the mercury from US power plants. We’re already pretty efficient at removing mercury, and each additional reduction comes with more difficulty.
So let’s assume that the EPA regs will cut out 25 tonnes of mercury per year. This is supposed to save 11,000 lives every year. So that means if we could wave a magical wand and cut out all of the mercury, 100 percent of it, we should expect to save about 11,000 times 7500/25 = 11,000 times 300 = 3,300,000 lives saved every year … and if you believe that three million people die every year from mercury poisoning, you too could get a job with the EPA.
That’s the thing about facts. As Homer Simpson says,
Facts are meaningless. You could use facts to prove anything that’s even remotely true!
w.
All data from N. Pirrone et al., Global mercury emissions to the atmosphere from anthropogenic and natural sources, Atmospheric Chemistry and Physics, 2010
For further reading, see Willie Soon’s excellent analysis of the EPA “science” on which they have based their mercury findings.
[UPDATE] To better illustrate the total natural and anthropogenic mercury emissions, here is a different version of the same data shown in Figure 1.
Natural sources account for about 70% of the world’s total mercury emissions.
w.
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A few years ago Robert F. Kennedy Jr was here in Alberta having a fundraiser where he claimed that Alberta’s fish are too contaminated to eat with Mercury. Eluding that the Mercury contamination of the fish was caused by human activities.
The Alberta government concludes that most of the Mercury in fish likely comes from natural sources.
Greenpeace and other environmental advocacy groups funded by Kennedy insist that Mercury also enter the environment by human activities like pulp and paper processing and the oil production.
Interesting that there is no mention of the twisty lightbulbs as a source of Mercury contamination of the environment as if they would be all properly disposed off.
http://www.ctv.ca/CTVNews/TopStories/20100127/kennedy_fish_100127/
Robert Brown says:
” March 31, 2012 at 7:37 am
Actually, I think mercury is a serious problem with modern civilization.”
Robert, mercury poisoning is no longer a serious problem here in the US. Link me to an article that shows how many deaths of people under the age of 30 there were last year. This should be extremely easy as the EPA implies that there are tens, if not hundreds of thousands, of Americans dieing every year due to mercury poisoning. As other commentors have already clearly shown, the new EPA regs will have no effect on reducing Americans already very low Hg exposure as you are only reducing average Hg exposure by at most 1/4 of 1%. It is all pain for no gain. A cost benefit analysis should be done, which is something the EPA does NOT do. Clearly the cost far outweighs the benefits of these new regs.
How would the numbers work out if you substituted bullshit for mercury?
BTW, the environment also produces dioxins; as much as industry, for the US. Forest fires.
http://www.dioxinfacts.org/sources_trends/forest_fires2.html
As a child I used to love to play with the mercury in my fathers mercury jar. It was about 5 pounds (in weight) worth. I would spill it out on the floor and eventually push the little blobs all back together with my bare hands, somehow I think this concern about mercury is a bit overblown. I turn 65 in a few months if my mercury exposure doesn’t kill me first.
Curiousgeorge says:
March 31, 2012 at 8:21 am
How would the numbers work out if you substituted bullshit for mercury?
Curiousgeorge:
I am not sure your comment passes the sniff test…..:)
My limited understanding is that Mercury was chosen as the target pollutant because it is difficult to remove from a gas stream due to its high vapor pressure (the reason the ocean is the main global source). Other pollutants such as Arsenic can be more easily removed in scrubbers so were not chosen as the culprit. Where they cam up with the number of lives saved is a mystery.
Obama’s goal was to drive up the cost of power, but that is not a likely outcome of this EPA action. The price of power won’t be impacted since natural gas is so cheap and abundant now. The overall effect of this ban on new coal fired plants will likely have no impact on anything except the coal companies and even that will likely be temporary. China will buy up the coal we would have burned here and burn it in their plants, which likely will be less efficient at removing pollutants. Since this is only a ban on new plants (which paradoxically are much cleaner burning than the old ones that will remain), the mercury reduction will happen very gradually.
In the end, only the EPA power grab will have succeeded. Watch for the EPA to find some reason to stop the burning of natural gas in power plants, or tax the hell out of it (perhaps on some pretext of reducing fracking to save the water supply). If that happens, Obama’s goal of doubling the cost of power so that his green energy scheme can be justified will have succeeded.
Our risk adverse society continues to drive us toward idiotic solutions. I DO STRONGLY AGREE that most types of radiation and non elemental mercury (Mike’s probably fairly safe) are very dangerous at “toxic” levels. The difficulty is to discern what exactly those levels might be. I don’t believe the EPA or most of the other regulatory agencies have really gotten that figured out yet. It also well known that certain levels of radiation and mercury have therapeutic effects below these “toxic” levels. It is known as hormesis – to a degree “what doesn’t kill you makes you stronger”. Or in the case of low doses of mercury – “what kills other stuff that might kill us is good”. In the end none of us gets out of this alive.
Bernie
Any biologist can tell you there are two kinds of bacteria – the good kind and the bad kind. There is absolutely no doubt that there is bad Mercury – that which comes out of chimneys – and good Mercury, which comes out of the sea.
Is that so difficult to understand?
Virtually every poison has a low dose range where its effects are healthful. This is called the “hormesis effect,” or the “hormetic range.” The minuscule doses that people are getting from environmental mercury are well down in this range, meaning that minor increments to environmental mercury improve health, so that reducing it will cost lives, not save them.
To claim that current levels of mercury present a danger, the EPA first analyzes a very tiny population (perhaps non existent) that gets enough exposure to environmental mercury to present a known health risk. Since virtually all mercury exposure comes from eating fish, and since only domestic freshwater fish would be significantly affected by changes in power plant mercury emissions, they focus on native American tribesmen who subsist almost entirely on wild caught fish.
A tiny fraction of this already hypothetical population might die from mercury poisoning. That gives the EPA a starting point. Then they do what Art Robinson calls “linear extrapolation to zero,” meaning that they add up the total amount of mercury exposure and count how many lethal doses they can divide it into, and that’s how many people they assume will die!
The virtual universality of the hormesis effect proves that this is not what will actually happen. In particular, mercury is well known to follow the typical hormetic dose-response curve, where very low doses stimulate improved health. Mercury has been studied to death because of the Thimerosol scare where mercury is a component in preservatives for vaccines.
People looking for a culprit for rapidly rising autism diagnoses pointed the finger at childhood inoculations and Thimerosol, but the very small doses involved are not dangerous and to the extent that they have any effect are actually healthful. In particular, thimerosol has been found to actually reduce the risk of autism in children who are inoculated with it. For documentation, click on Edward Calabrese’s reply to this abstract:
http://pediatrics.aappublications.org/content/126/4/656.abstract/reply
Calabrese is the modern pioneer in documenting the virtual universality of the hormetic dose-response. See for instance:
http://works.bepress.com/edward_calabrese/7/
Hamlet’s father was killed by having mercury poured in his ear. Ban it!!
>:-P
Robert, mercury poisoning is no longer a serious problem here in the US. Link me to an article that shows how many deaths of people under the age of 30 there were last year. This should be extremely easy as the EPA implies that there are tens, if not hundreds of thousands, of Americans dieing every year due to mercury poisoning. As other commentors have already clearly shown, the new EPA regs will have no effect on reducing Americans already very low Hg exposure as you are only reducing average Hg exposure by at most 1/4 of 1%. It is all pain for no gain. A cost benefit analysis should be done, which is something the EPA does NOT do. Clearly the cost far outweighs the benefits of these new regs.
I totally agree that a cost-benefit analysis is called for, but as Pamela (?) pointed out, mercury is less of a global problem and more of a local problem. It is also a chronic problem — it doesn’t spectacularly kill people, but people who live in regions with lots of mercury tend to get all sorts of things at higher rates than the general populace. Of course toxic environments are often toxic in lots of ways, and linking it to just mercury is difficult. If you get cancer because of oxidative damage to your DNA, it isn’t really possible after the fact to attribute that damage to its true cause — radiation, mercury, lead, iron (yes, iron is toxic to the human body as well as being essential — I’m a hemachromatosis carrier and know that only too well), halogenated hydrocarbons, or just plain bad luck with nothing but oxygen, a molecule that is simultaneously essential for life and yeah, an oxidant at the cellular level that can damage DNA.
The point I’m making is that Willis’ presentation of the issue isn’t entirely fair — it is easy to point to many places and circumstances where mercury is a serious, anthropogenic, environmental hazard and where at the very least animal studies suggest that it contributes to the overall mortality and morbidity at some rate. So it isn’t silly to want to do something about mercury, and scrubbing mercury from coal is by no means a crazy place to begin, but as you point out in the end it is all about cost-benefit analysis, something that the EPA does not do and neither does anybody else in government, ever, as far as I can tell, in either party. CBA is anathema to politics, which is always about doing the right thing (going for some benefit) damn the cost or opposing the cost damn the benefit. I could wax poetic about gay marriage, the US as a “Christian” country, wars in Iraq, health care, controlling CO_2, and many, many other places where our civilization appear incapable of actually analyzing the total costs and comparing them to the reasonably expected benefits for various alternative decision pathways and using common sense to choose among them.
The problem with a CBA is that it is difficult to do a good one shooting from the hip. One actually has to do a rather large amount of research. Objectivity more or less demands that you not make up your mind about the way it is going to come out (to advance some position that you hold) ahead of time, as well. The EPA’s failure, in other words, should not become our own if we doubt its assertions.
rgb
I asked a coworker who is dealing with these new regulations what the preindusrtial levels were. Things like how much was in the soil or the ever popular fish consumption issue. Her response was noone knows.
So my next question was how does one regulate a contaminant if you do now the base line data. She just smiled.
If the EPA was required to document and justify their work with the same level of due dilegence they require of private industry, they would save money, and due more to help the environment.
But don’t let my boss see this we make lots of money on these regulations.
Robert:
Doing a true CBR on the MACT act would require years. And this is actually what should be done……taking the years.
One would have to include the effect on genergal health of those who live in the northern lats as to sickness rates from prolonged exposure to lower temps in large buildings etc.
The very small amount of Hg emitted from coal at present does not appear to add a substantial amount of Hg to the atomphere/environment in comparison to all sources.
The ability of people to buy fruits and vegetables with the money not spent on higher prices as a result of higher elec rates would also have to be factored in.
So many actual questions/answers needed to make an intelligent decission, which the EPA seems not capable of anymore.
SPPI has a wealth of very good information about environmental mercury. I’ll like to just three articles while I look for the more comprehensive piece I read some time ago. There is a lot of irrefutable fact and some rather specious conjecture in the preceding comments. I wouldn’t hesitate for a moment to eat walleye, trout or salmon from Lake Michigan. A tremendous amount of commercial fishing occurs in Lake Superior, Lake Michigan and Lake Huron. That fish likely contains less mercury per kg than open ocean top predator fish like tuna or swordfish. Lake Erie is the body of water to avoid. Many of you will find this articles interesting:
http://scienceandpublicpolicy.org/images/stories/papers/reprint/scientific_reply.pdf
http://scienceandpublicpolicy.org/images/stories/papers/reprint/critical_comments_epa_clean_air_mercury_rule.pdf
http://scienceandpublicpolicy.org/images/stories/papers/mercury/How_Safe_are_We_From_the_Fish_We_Eat.pdf
I’m going to have to use that on a placard, polistra; thanks.
.
There is a problem with zero tolerance strategies whether with mercury, radiation, or traces of marijuana in a teenager’s backpack that got him suspended from school and possibly killed.
There are several problems that zero tolerance raises, one is: measurement; i.e. increasing ability to measure and whether there is an impact at such concentrations. Zero tolerance is derived from extrapolation of much much higher concentrations where impact can be measured.
Another problem with zero tolerance is that organism adaptation is under-appreciated. Surprising, many organisms have mechanisms to handle heavy metals, we humans are one of them. So the issue is dose; back to the “how much” story again. Surprising also, we produce cancer cells every day, quirks of damaged or mis-shapened DNA, these cells are identified and destroyed. I am not saying a little radiation is good for you, but you do get a little radiation every day whether you are out in the sun or not. We also have DNA repair systems that repair DNA that get damaged in the normal wear and tear of the cell’s work.
I do not want to imply any disrespect to Robert Brown and his excellent review of impacts of mercury and methyl-mercury. I wish to focus a bit on the fishy part. Mercury and methyl-mercury should be having its devastating biological impact on the fish before they are caught by angling enthusiasts. There is very little literature that I am aware, that has identified impacts upon the various fish (fodder fish to Coho Salmon) at levels found in the Tittabawassee River including mercury, PCPs, dioxins.
That these compounds are in the top of the food chain creatures is certain. That I would follow the guidelines of the Michigan DNR or health advisories to pregnant women and a host of other precautionary principles is also certain.
What I object to is the 11,000 number which I believe was derived from the zero-tolerance extrapolations. And here again is a scare tactic to enact a series of regulations which have a tenuous science background. Another black eye for science and the uncertainty monster.
Good article Willis,
one thing you don’t say is how much less Hg Europe is now emitting due to all the coal we are no longer burning since they took a frigging light bulbs away. (And how much more we are putting into the environment because of being forced to use CFLs.)
Maybe the mad hatters at EPA have not finished working out the death toll for that one yet.
Can anyone explain why the fish-eating Japanese have the highest life expectancy in the world? Do their fish only contain good mercury?
Who’s the CBA candidate?
I suspect that if each department of the federal government was subjected to independent cost-benefit analysis on its operations, the results would be shocking. So much that there would be a chorus to shutter them, or at least subject them to something like that Monty Python skit with the Black Knight.
Alec Rawls says:
March 31, 2012 at 9:28 am
The classical student of hormesis is T. D. Luckey, who concentrated on low doses of radiation. I read his monograph years ago. A twenty page overview by Luckey is available at —
http://www.radpro.com/641luckey.pdf
Luckey estimates that about 700 premature deaths per day could be prevented by a low-dose radiation supplement. Even more remarkable is the ‘accidental experiment’ in Taiwan, in which Cobalt 60 contamination of rebars used in an apartment house produced a 96% reduction in cancer — there is a five page paper published in 2004 that explains the details —
http://www.jpands.org/vol9no1/chen.pdf
The incident was well investigated. As usual, the conclusion is that bureaucrats ignore any evidence that does not support total control by regulators, even if extensive morbidity and mortality result. The LNT theory is an analog to AGW politics in that sense. The goal is control.
mizimi says:
March 31, 2012 at 6:24 am
It’s a “back of the envelope” estimate, mizimi, not a hard figure. I estimated 25 pounds of reductions, let me see what I can find …
OK, here’s what I find. The EPA estimates the mercury emissions from power plants to be about 50 tons per year. The regulations are designed to reduce that to about 30 tonnes by 2014 and to 15 tonnes per year by 2018. So they estimate the reduction at about 35 tons, whereas I’d used 25 tons for my rough estimate …
And of course, government estimates are rarely achieved, so I’d say my numbers are reasonable.
w.
Bob W in NC says:
March 31, 2012 at 6:33 am
Not a clue, although it’s certainly an issue. Let me see what numbers I can find … OK, US incandescent light bulb sales are about 40 billion units per year. Assuming a couple year lifespan, that would be about 80 billion light bulbs in the US.
Each bulb holds about 5 milligrams of mercury. So in total, enough bulbs to replace every incandescent in the US will hold about 400 tonnes of mercury … yikes! That number’s probably high, but total mercury from coal fired power plants is about 50 tonnes …
w.
polistra says:
March 31, 2012 at 6:42 am
The problem is that the EPA wants to put ridiculously low levels on genuine and serious pollutants despite the existence of lots of sources for the same genuine and serious pollutants.
There are about 2,700 tonnes of mercury emitted by the ocean every year. Total natural sources are about 5,000 tonnes.
If you think cutting thirty tonnes from US power plant emissions will make the slightest difference in the face of that, the EPA has a job for you.
w.
Doesn’t that regulate energy saving light bulbs out of the home?