The EPA's Mercurial Madness

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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Gail Combs
March 31, 2012 12:13 pm

Dang it Willis you beat me to it!
I was just working on a possible submission about the idiocy of the new EPA regs. My points were:
1. The EPA has just come out with a final ruling that includes stricter pollution controls and includes CO2 as a pollutant.
The title of the final ruling is
National Emission Standards for Hazardous Air Pollutant Emissions From Coal-and Oil-Fired Electric Utility Steam Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units: FINAL RULING
2. The EPA is directed by Executive Order (EO) 13563, “Improving Regulation and Regulatory Review,” to estimate the costs and benefits of the final rule.
3. President’s Executive Order 13563 states in part:
“Our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation. It must be based on the best available science. It must promote predictability and reduce uncertainty….least burdensome tools for achieving regulatory ends. It must take into account benefits and costs, both quantitative and qualitative.” exchange.regulations.gov
4. Richard J. Trzupek said of the new rule, “With around 50,000 megawatts of coal-fired power set to be forcibly retired in the next few years—thanks to the draconian policies of Obama’s EPA—this rule ensures that no new modern, efficient coal fired power plants will be built to fill the gap.” http://www.legalnewsline.com
5. So what is the benefit that the EPA sees as out weighing the cost of destroying 50% of the US electrical generation over the next few years?

The benefits of this rule outweigh costs by between 3 to 1 or 9 to 1 depending on the benefit estimate and discount rate used. The co-benefits are substantially attributable to the 4,200 to 11,000 fewer PM2.5-related premature mortalities estimated to occur as a result of this rule. The EPA could not monetize some costs and important benefits, such as some Hg benefits and those for the HAP reduced by this final rule other than Hg. Upon considering these limitations and uncertainties, it remains clear that the benefits of this rule, referred to in short as the Mercury and Air Toxics Standards (MATS), are substantial and far outweigh the costs….
In section 5.6 of the Regulatory Impact Analysis (RIA) we also report the monetized CO2 co-benefits using discount rates of 5 percent, 2.5 percent, and 3 percent (95th percentile).
Total social costs are approximated by the compliance costs for both coal- and oil-fired units. This includes monitoring, recordkeeping, and reporting costs….
http://www.regulations.gov

So the benefits are calculated from reducing mercury (Hg) among other pollutants
The method used to determine the effects of pollution on cancer rates was rather bogus. The EPA looked at cancer in cities vs cancer in rural areas and attributed the difference to pollution. See EPA Fact Sheet
6. So what do the studies on lung cancer tell us?

Environmental Health Perspectives © 1978 The National Institute of Environmental Health Sciences (NIEHS)
Abstract:
The substantial reduction in air pollution, and particularly in components such as benzo[a]pyrene in urban areas of the United Kingdom during the past few decades has presented an opportunity to consider further the possible role of carcinogens in the air in relation to lung cancer. While the overall trends in lung cancer mortality have undoubtedly been dominated by changes in smoking, the marked contrasts that at one time existed between these death rates in urban and rural areas have gradually diminished. This may indicate that air pollution contributed appreciably to the urban/rural differences in lung cancer at one time, but it is still difficult to disentangle any effects it may have had from those of changing smoking habits.
http://www.jstor.org

Diet is the other confounding factor besides smoking.

Abstract
It has been estimated that 30–40 percent of all cancers can be prevented by lifestyle and dietary measures alone. Obesity, nutrient sparse foods such as concentrated sugars and refined flour products that contribute to impaired glucose metabolism (which leads to diabetes), low fiber intake, consumption of red meat, and imbalance of omega 3 and omega 6 fats all contribute to excess cancer risk. Intake of flax seed, especially its lignan fraction, and abundant portions of fruits and vegetables will lower cancer risk. Allium and cruciferous vegetables are especially beneficial, with broccoli sprouts being the densest source of sulforophane. Protective elements in a cancer prevention diet include selenium, folic acid, vitamin B-12, vitamin D, chlorophyll, and antioxidants such as the carotenoids (α-carotene, β-carotene, lycopene, lutein, cryptoxanthin). Ascorbic acid has limited benefits orally, but could be very beneficial intravenously. Supplementary use of oral digestive enzymes and probiotics also has merit as anticancer dietary measures. When a diet is compiled according to the guidelines here it is likely that there would be at least a 60–70 percent decrease in breast, colorectal, and prostate cancers, and even a 40–50 percent decrease in lung cancer, along with similar reductions in cancers at other sites. Such a diet would be conducive to preventing cancer and would favor recovery from cancer as well.
http://www.nutritionj.com

7. What are the negative “Social Costs”?
The soaring energy costs were certainly not included in the calculation of co-benefits from reductions in mortality Unless of course the EPA considers death of the elderly a “Cost Benefit” and given government health care and Social Security it probably is at least secretly.
We can look at the UK and France to figure that out based on actual numbers within the last decade.

Official figures show the number of deaths linked to cold over the four-month period reached 25,400 in England and Wales, plus 2,760 in Scotland…. http://www.dailymail.co.uk

The population of England, Scotland and Wales ~ 59,800,000 so the death toll from too expensive heat was 0.047% of the population in just a four month period.

…heat-wave… death toll estimates in France soared from 2,000 on Aug. 14 to as high as 13,400 last week … 40C (104F) http://www.time.com

France has a population of 65,300,000 so the death toll from too expensive A/C for just a couple weeks was 0.02% of the population.
So the combined total of deaths for those two years is 0.06% of the population due to lack of money for heat or A/C.
OOPS
Looks like we can point to very concrete results from increases in the cost of electric (0.6% increase in deaths among the elderly) but the EPA Rural vs Urban data is not worth a hill of beans.

Dave Wendt
March 31, 2012 12:23 pm

Robert Brown says:
March 31, 2012 at 9:46 am
“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.”
I would suggest that most of those “places and circumstances” would be completely addressable under regulations that were created when the EPA was a pup. If these regulatory Leviathons would focus more of their attentions on situations where real and measurable hazards actually do exist instead of focusing on creating new standards which are well past the point where their increased costs far exceed any possible benefit I would probably have few objections to their continuing existence left. Last year EPA was pushing a new O3 standard that on most days couldn’t be met in the farthest back of beyond of Yellowstone Park. It was so unrealistic that even Obama was forced to step in to block it. Although there was speculation at the time that it was just a “sacrificial goat” offered up to allow him to appear as less of a complete tool of the environmental lobby than he actually is.
The creators of all this incredible flood of new regulations need to be required to do not just a cost/ benefit analysis for each new reg, but even more importantly an “opportunity cost” analysis. Opportunity cost is is the sum of other possibilities that we cannot pursue because we are investing huge amounts of effort and cash in mostly unproductive uses. Even if we were to stipulate to the EPA’s dubious claim of 11,000 lives saved by this new standard, the great costs and economic damage associated with it, if put to a myriad of more productive uses would likely yield vastly greater benefits while avoiding the serious peril introduced by reducing our electrical generation capacity.

Bernie McCune
March 31, 2012 12:26 pm

You would think that it is a regulatory agencies’ job to come up with a better idea of toxicity (or harm) for any of the compounds and processes that they are regulating. In this case the EPA should be the agency to have more research done on this issue rather than spend lots of money trying to fix a problem that is not necessarily a problem. I would be the last to say that this will be an easy task, but it would seem to demand more immediate attention. Perhaps take the physicians creed of “do no harm” to heart rather than to use some well meaning but wrong headed precautionary principle.
Bernie

nvw
March 31, 2012 12:46 pm

Raymond Kuntz above makes a very good point concerning natural volcanic emissions of Hg into the environment. The values cited by Willis are the “conventional wisdom” obtained by measuring SO2 fluxes from volcanoes and using a standard “fudge factor” to estimate the corresponding amounts of Hg. The reason being that actual measurement of Hg is hard to do, but nature is rarely reducible to fudge factors and volcanoes of differing chemistry most certainly can be expected to have wide ranges in Hg content. It is quite possible, perhaps even likely that natural Hg fluxes are far larger than represented, and lest people not appreciate the significance of this, the higher the natural flux in the environment, the less significant human contributions become.
Another source, so far unmentioned in Willis’ article or the comment thread, is Hg from crematoria. Yes, emission controls will soon be required at funeral homes due to Hg emissions from the stacks. There are several ways to consider this observation; one is that humans have a fairly high amount of Hg in their bodies (tooth amalgam and prosthetic joints are sources) which doesn’t seem to be leading to massive mortality and that we are over estimating Hg dangers to public health. Another perspective is that as a society we have effectively removed so much Hg from legitimate pollution sources that what remains is minor amounts from the burning of human corpses after death.

March 31, 2012 12:52 pm

Robert Brown said March 31, 2012 at 7:37 am

It is mad as a hatter to oppose reasonable efforts to reduce the levels of mercury in the environment, or try to claim that the mercury that is there is harmless and that we didn’t put a lot of it there right where it is most dangerous.

That remark seems to have gone over people’s heads Robert 🙂
Mercury as a medicine has been popular with doctors from the 19thC through to the mid 20thC. Calomel (mercurous chloride, horn mercury) was used as a purgative to induce vomiting and diarrhoea. Just in case their patients were ingesting an insufficient quantity of mercury, calomel lotion was also applied directly to the skin. It was a common ingredient in teething powders for infants and was still in use when the Git was born.
A few of those who are known to have suffered and/or died from mercury poisoning at the hands of their physicians:
* Amadeus Mozart who died of the mercury cure he was given for syphilis.
* Ludwig van Beethoven whose deafness and death are thought to have been due to heavy metal poisoning including mercury.
* Napoleon Bonaparte whose hair analysis has revealed high levels of mercury, lead and arsenic.
* Abraham Lincoln whose erratic moods and insomnia are thought to have been due to the mercury medicine ‘blue mass’ he was taking for depression.
* The English King George III who ended up blind, deaf and insane.
* The mother and wife of Ivan the Terrible, the first Russian Tsar who were both poisoned with mercury according to recent analysis of their remains.
Oddly enough, the effect of mercury on those involved in its mining and extraction were known from Roman times at least.
Vermilion (cinnabar) was a popular natural food colouring for many centuries and is the sulphide of mercury. In the 20thC it was replaced by coal tar dyes as they are much cheaper. These, of course, are evil as they are made from coal and not natural.

harrywr2
March 31, 2012 12:58 pm

The EPA scientific assessment is here –
http://www.epa.gov/airquality/powerplanttoxics/pdfs/20111216MercuryRiskAssessment.pdf
Main points –
There is a population of woman in the US who rely on ‘subsistence’ fishing for the majority of their diets. These woman eat up to 12 ounces of fish per day caught in rivers an lakes that have high levels of mercury. These woman may become pregnant. The offspring may suffer a 1 or 2 point IQ deficit. Power stations contribute ‘some’ portion of the mercury in these rivers.
Yep…first determine your political goal…then find some sub population that would be disproportionately effected if your political goal isn’t met…then find some disease or condition that may be exacerbated by this.
/sarc I’m pretty much allergic to flowers and most perfumes(I haven’t been in a department store with a perfume counter in decades)….I’ve banned them in my house….maybe Lisa Jackson can ban them in everyone’s house including hers.

March 31, 2012 1:03 pm

Willis:
Your count of 80 billion light bulbs doesn’t smell right. That would be more than 400 bulbs per household. I’ve no stats, but in my experience, offices, industrial facilities, schools, etc., use fluorescent or halogen. Most of the incandescent bulbs I see are the ones in my home. Our home (1800 square foot 4 bedroom) has about 50 bulbs. About a quarter of those are in areas that are not lit daily and hence do not burn out as quickly. Are you sure it wasn’t 8 billion? That would make sense. If we assume double the lifespan for CFL’s, then we are talking about mercury in the magnitude of 10 tonnes per year rather than 100 tonnes per year. So of the same magnitude as all coal power generation.

March 31, 2012 1:17 pm

Dave Wendt said March 31, 2012 at 12:23 pm

If these regulatory Leviathons would focus more of their attentions on situations where real and measurable hazards actually do exist instead of focusing on creating new standards which are well past the point where their increased costs far exceed any possible benefit I would probably have few objections to their continuing existence left. Last year EPA was pushing a new O3 standard that on most days couldn’t be met in the farthest back of beyond of Yellowstone Park.

I can only agree. The proposed paper pulp mill in Tasmania exceeded pollution guidelines before construction has even commenced. One suspects that will never happen due to opposition from the general public. In what seems mindless pursuit of building the mill where people don’t want it to be built, most of the company’s money-making assets have been sold off. Shares have dwindled from $AU4.50 in December 2004 down to $AU0.11 two months ago (the last time I looked). It’s not only government employees that act in irrational ways it would seem.

Gail Combs
March 31, 2012 1:17 pm

Billy Liar says:
March 31, 2012 at 11:17 am
Can anyone explain why the fish-eating Japanese have the highest life expectancy in the world? Do their fish only contain good mercury?
_______________________________
The Japanese families did not report the death to the government.
It even made it to WUWT: 1,000′s of Japans Centenarians Died Decades Ago, Average Life Expectancy “worse than we thought”…
http://wattsupwiththat.com/2010/09/13/1000s-of-japans-centenarians-died-decades-ago-average-life-expectancy-worse-than-we-thought/

Gail Combs
March 31, 2012 1:21 pm

neill says:
March 31, 2012 at 11:24 am
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….
_______________________
Oh I would love to see them have to do Zero-Based Budgeting every year like some of us in industry had to do.

Crispin in Johannesburg
March 31, 2012 1:24 pm

Willis, no one has mentioned much about the ocean mercury so here goes:
Last April I was privileged to attend a presentation at the globally important air quality measuring station at Cape Point, south of Cape Town. This was presented to the Univ of Johannesburg staff and hangers-on in the room next to the massive complex of equipment that rates as one of the best facilities in the world that monitors the air passing over the tip of Africa. The equipment is fabulous. The scientists in attendance are volunteers from around the world who work for a few months at a time for free.
One of the things they have been measuring is the mercury content of the sea air and also rain, I believe. They have had an instrument for years that read Hg continuously and reported the accumulation once per day. Those records go back years and show a very constant, or slightly cyclic quantity of Hg in the air coming off the Southern Ocean. As there is literally nothing anthropogenic south of Cape Point, the site is considered one of the best places to conduct this measurement of well mixed air.
Not too long ago they put in a new instrument which reported hourly instead of daily. The results were astonishing. Not only did the mercury level vary a great deal during the day, sometimes it dropped to zero for several hours then rose again! They have absolutely no idea how this is happening because it has always been assumed the Hg was constant and well mixed. Our presenter scientist said this added hourly resolution brought the unexpected fluctuation to light and that there is no known atmospheric mechanism for it. The speculation was that some airborne bacterial process might be responsible for taking the Hg out of the air, but completely?? No way. No chance at all.
What it means is that the process might not be an atmospheric one at all, but a short timespan activity in the ocean that gives off mercury, or not, through some as-yet-unknown mechanism in the sea. It probably means the mercury has a very short lifetime in the atmosphere. The fluctuations are large and not particularly related to any observable cause like the position of the sun or the time of day etc. It is clearly natural he said, because there is no anthropogenic cause to the S or SE which is where the prevailing wind comes from. The effect is observed frequently. The Hg flow just shuts off, then turns on again. It is not an instrumental issue. The disappearance is complete.
So….while you are looking at the ‘total produced by the ocean’ be very suspicious that the figure is unreliable. It may be much higher at certain times of the year, and in certain locations and have a very sort lifetime in the air. Trust no one on this because if the figures are given by a daily average, the spot level may be far greater and variable and the true exposure on land or sea unknown.
Something also worth mentioning is that all the mercury from coal is biogenic. Coal has mercury in it from natural sources. As the only requirement to render Hg emissions as safe as the massive output from unknown biogenic sources in the ocean and land, all that is required is dilution to the background level. There is no reason to ‘remove’ it at all, if the background level is reached.
The regulation proposed seems to be more aimed at demonising coal and promoting its commercial rival, natural gas, than actually reducing exposure for anyone or anything. The idiotic pollution of the Great Lakes was not caused by burning coal.
The addition of 40 tons of mercury in twisty lightbulb is still peanuts compared with industrial processes still apparently run by the Homer Simpsons of American industry who are richly deserving of attention from the EPA.

DocMartyn
March 31, 2012 1:30 pm

Hg, metallic mercury is not very toxic, people did swallow it, and it was a very successful treatment for intestinal blockages (which are lethal in many cases).
Hg2+ is very bad indeed, and in the body and biosphere undergoes biotransformation into CH3Hg+, methylmercury. Just submitted a paper on this showing its ability to damage mitochondria and mitochondrial DNA (it is a lipophilic cation).
The majority of oceanic mercury comes from runoff of land based emissions. So the plot shown is rather misleading. HgCL2 and CH3HgCl are dense salts and sink into deep ocean. New Hg2+ enters the oceans via rivers, ends up in estuaries and ends up in the food chain. Eating the top predators of an oily food chain increases your mercury exposure; keep away from Tuna, Seals and Polar Bears. The inuit are at the top of such a food chain and are full of PCB’s, pesticides and methylmercury;
http://www.ncbi.nlm.nih.gov/pubmed/16839831
We would expect, a prior, that methylmercury would to be converted into dimethylmercury by the same bacterial systems that give rise to methylmercury.
Dr Karen Wetterhahn died of dimethylmercury poisoning, and we have no idea of the mechanism.
http://en.wikipedia.org/wiki/Karen_Wetterhahn
I actually wanted to look at DMM toxicity, but the safety committee vetoed it; essentially I would need a lab entirely dedicated to DMM and whose contents could be carted off to toxic waste landfill at the end of the study.
However, the release of long term, persistent, neurotoxins into the environment is very dumb. This is EXACTLY the type of thing the EPA should be looking at and regulating. The fact that the EPA/Obama administration has been increasing the levels of mercury in the environment due to its light-bulb strategy is a disgrace, Indeed, the administration is costing our future selves hundreds of billions in clean-up costs.

R Barker
March 31, 2012 1:41 pm

It is always good to have a realistic perspective on the problem to be addressed so that reasonable solutions may be selected from the array of options. Sometimes just a pause for a sanity check is all that is needed. Of course when the proposed solution does not pass the sanity check, it is not good to press on anyway. This seems to be a regular occurance at the EPA in recent years. I think they just skip the sanity check because there is no one there sane enough to do it any more.

Leg
March 31, 2012 1:43 pm

Willis: If you really want to have some fun, look at how the EPA calculates the so-called number of deaths. Years ago I researched this thoroughly concerning their claims of Radon “deaths”. Their math is serious prestidigitation and based on spurious presumptions, with a whole lot of “err conservatively” without any basis for doing so. With Radon, their math started out by saying 0-5000 deaths/yr (with 100% error bars). This wasn’t getting anyone’s attention, so a few years latere and with a little presto chango math, they revised that to 5000-10,000/yr (still with huge error bars). About a year later they started saying 20,000/yr without publishing any math justification! I suspect the same thing has happened to their “death math” regarding Mercury. After studying the Radon issue, I am more than skeptical of the EPA anytime they put out their death math.
PS: if you should look into the Radon death math, note that the EPA has flat out refused – and I repeat, flat out refused – to factor into their death math any studies that show a positive effect for low doses of Radon – of which there are quite a few. They perfected the art of cherry picking and hiding the decline a long time ago.

Gail Combs
March 31, 2012 1:55 pm

Crispin in Johannesburg says:
March 31, 2012 at 1:24 pm
…..The idiotic pollution of the Great Lakes was not caused by burning coal…..
_______________________________
Way back in the dark ages of my youth, I lived near a great lake. A friend of mine mentioned that ship loads of mercury were sank in the great lake (Ontario) per order of the US government at the end of WWII. He said his father was part of the operation. Also Eastman Kodak dumped a large amount of chemicals, so much that the Genesee River ran all different colors and stank to high heaven.

Crispin in Johannesburg
March 31, 2012 1:57 pm

Martyn
“The majority of oceanic mercury comes from runoff of land based emissions. So the plot shown is rather misleading”
++++++
With respect, I find this really unlikely. HG is part of normal ocean processes. The evidence for this from the Cape Point is very convincing. There is an almost continuous supply in air that literally comes from Antarctica. There is zero chance that this is from runoff.
I am open to any suggestions as to what the origin is, but the whole point of the work being done in South Africa is that there can be no anthropogenic source in the airborne Hg from the Southern Ocean.

Steve from Rockwood
March 31, 2012 2:00 pm

I don’t get the mercury from the ocean bit. Where is the mercury concentrated? At what levels? Or does the mercury jump out of the ocean in very low levels (e.g. non-harmful), hang around in the atmosphere for awhile and then jump back into the water? Does the high amount of mercury from the oceans come about because you are integrating very very small concentrations of mercury over a very very very extensive area (e.g. three verys divided by two verys).