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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Dr. Dave
March 31, 2012 2:37 pm

A few questions for DocMartyn,
How do you know that “The majority of oceanic mercury comes from runoff of land based emissions?” This sounds like speculation to me. Then I wonder is you actually read the abstract you linked to. It does not support the assertions made in your comment. Further, we know EXACTLY what killed Dr. Wetterhahn. Given that she spilled dimethyl mercury on her gloves and later had a serum concentration of 4,000 mcg/mL it’s quite apparent she died from accidental toxic exposure. LOTS of drugs and toxins display this kind of potency. Albert Hoffman, who first synthesized LSD, accidentally ingested what is guessed to as little as 100 mcg of LSD and he was higher than a big dog on his bicycle ride home. I don’t know what the theoretical volume of distribution is for LSD, but I would imagine it was probably not until the 1980s when accurate quantitative serum concentrations could be made following a 100 mcg dose. So with serum concentrations dimethyl mercury at 4,000 mcg/mL there’s not too much mystery surrounding her death.
Mercury has been ubiquitous in our environment for thousands of years. Mankind has been consuming fish with mercury levels comparable to those found today for literally hundreds of years. Your call to avoid tuna (I already avoid seal and polar bear and have cut way back on walrus because it’s so damn hard to find fresh walrus in New Mexico) is based on speculation and your opinion, not on scientifically supported evidence. Look these articles over before you rush to judgment with your fish opinions:
http://scienceandpublicpolicy.org/images/stories/papers/mercury/Making_Sense_of_State_Fish_Advisories.pdf
http://scienceandpublicpolicy.org/images/stories/papers/mercury/How_Safe_are_We_From_the_Fish_We_Eat.pdf

Florian Schach Engage America
March 31, 2012 2:47 pm

EPA while it is an overbearing agency is at least trying to fix what mistakes it has made in the past. For example their attempt at applying new standards to newer plants is a step in the right direction. Applying these new plant rules to newer built plants rather than power plants over all may be somewhat daunting to power plant owners however overall it is a little less of a blow to everyone. At least by only applying it to new plants you acknowledge that there is a need for transition when it comes to regulatory policy. In the past costs of regulation can be astronomical and very daunting on businesses (http://bit.ly/w1yk0F), with this you at least give businesses a fighting chance to stick around and also change their operations so that they can stay afloat. It’s not perfect, but its at least something to help us go forward.

Dr Burns
March 31, 2012 2:50 pm

A “green” mercury lightbulb, that our government now forces us to use instead of the “dangerous” incandescent ones, if broken in the average sized bedroom, will produce 3 times the mininimum lethal concentration in the air.

Oatley
March 31, 2012 3:27 pm

So we are chasing a long tail risk like mercury from a large stationary source like a coal fired electric plant. At the same time major cities across the nation are overflowing raw sewage into rivers during storms and the EPA turns a blind eye. This EPA is THE most politicized agency on record. It is time we open up the Clean Air Act and let some sanity in…

Oatley
March 31, 2012 3:30 pm

Dear Florian:
Don’t be naive. This EPA will propose greenhouse gas rules on existing power plants next. Then all hell will break loose when America gets the bill for that one.

David A. Evans
March 31, 2012 4:09 pm

We know there are coal seams burning. Are there any environmental controls on these?
I often wonder why they don’t self extinguish due to CO2 build up. perhaps someone could enlighten me.
DaveE

March 31, 2012 4:32 pm

David A. Evans said March 31, 2012 at 4:09 pm

We know there are coal seams burning. Are there any environmental controls on these?
I often wonder why they don’t self extinguish due to CO2 build up. perhaps someone could enlighten me.

From the Wikibloodypedia”

“One theory asserts that in May 1962, Centralia Borough Council hired five members of the volunteer fire company to clean up the town landfill, located in an abandoned strip mine pit next to the Odd Fellows Cemetery. This had been done prior to Memorial Day in previous years, when the landfill was in a different location. The firefighters, as they had in the past, set the dump on fire, and let it burn for a time. Unlike in previous years, however, the fire was not extinguished.”
“The fire remained burning underground and spread through a hole in the rock pit into the abandoned coal mines beneath Centralia. Attempts to extinguish the fire were unsuccessful and it continued to burn throughout the 1960s and 1970s. Adverse health effects were reported by several people due to the byproducts of the fire, carbon monoxide and carbon dioxide and lack of healthy oxygen levels.”

Coal pits usually have multiple entrances and lots of tunnels and are designed such that toxic gasses such as firedamp do not accumulate. Hot air rising from one or more shafts draw fresh air in through others thus providing plenty of oxygen.
A note on Wikipedia’s lack of accuracy. The Git notes that it states “Tasmania contributes 90% of Australia’s Cotton yield”. The truth is zero percent of Australia’s cotton is grown here.

DocMartyn
March 31, 2012 5:27 pm

Dr. Dave,
1) We know where we are or have been generating mercury and where it ends up. You can measure the levels in the outfall of the Mississippi and observe the concentration up of fresh-water derived mercury in estuaries.
http://www.lwrri.lsu.edu/downloads/publications/devai_science.pdf
Estuaries have a very rich microbiological flora/fauna which cycle mercury between organic and inorganic mercury (note that cinnabar (HgS) is not inert in the presence of ferrous ion which is part of the hypoxic shunt).
http://www.aslo.org/lo/toc/vol_53/issue_3/1064.pdf
An overview of the movement of mercury into and out of the gulf of Mexico is here;
http://www.whitehouse.gov/sites/default/files/methylmercurygulfmexiconstc04.pdf
Mercury is dense and its concentration increases with ocean depth. The deeper fish live, the more mercury they accumulate, per unit time of life.
http://www.pnas.org/content/106/33/13865.full.pdf+html
2) “Further, we know EXACTLY what killed Dr. Wetterhahn. Given that she spilled dimethyl mercury on her gloves and later had a serum concentration of 4,000 mcg/mL it’s quite apparent she died from accidental toxic exposure”
http://www.nejm.org/doi/full/10.1056/NEJM199806043382305
She stated she spilled 3 drops of DMM on her glove, DMM has a density of 2.96 g/ml, so 3 drops is about 150 μl and so we have 0.45 grams on her glove max. NEJM think this was the dose she received 0.44 ml of liquid dimethylmercury.
Assuming the very unlikely possibility that all when in, and she had a blood volume of about 5 liters we have a maximum initial incident of 0.1 gram/liter or 100,000 μg/liter blood.
At 70 days post exposure she had 1,000 μg per liter blood, chelation treatment raised this to 4,000 μg per liter. She was excreting 57 μg in urine per 24 hours before chelation therapy, 1/8,000th of maximum initial dose, which rose to 39,800 μg per 24 hours, approximately 1/10th initial dose per day. Her hair showed a biological t1/2 of about 75 days, which is almost exactly the same as for methymercury.
Now, back to DimethylMercury, this is a neutral species. Hg2+ and CH3Hg+ are toxic cations that react with thios/selenols and iron/sulfur centers. Their reactivity is inversely proportional to halide concentration, as Cl- binds to both species mono/di valent cations and stops the -SH/-SeH reactivity. Blood has 100mM Cl-, cells 2 mM Cl- and mitochondrial, low nM, and so Cl- acts as a shield for Hg2+/CH3Hg+ in the same way as it does for cis-Platins. So they do most of their damage inside cells, specifically inside mitochondria.
Dimethylmercury will not react with thiols, selenols as it has cationic Hg, nor should it chelate to standard mercury chelators like dimercaptosuccinic acid. DMM must be converted to methylmercury, somewhere, somehow, into methylmercury.
This methylation could be very interesting in its own right, especially if dimethylmercury chelates to the phosphate ester backbone of DNA. It would be very nice to know if DMM methylates DNA and is converted to methylmercury.
Note also the very long latency of toxicity in Dr. Wetterhahn, the DMM took a long time to cause symptoms, far longer than methylmercury. Treatment didn’t do any good at all, they chelated and boosted her antioxidants with vitamin E and that failed. Long latency and then huge, uncontrolled crash.
DMM partitions into brain far better than MM, the DMM Log octanol/water partition coefficient at approx 100 mM Cl- for methylmercury is 1.7, but for DMM it is 2.26.
My guess is that DMM hides in brain and other fatty tissues, demethylates to MM, which then does its normal, nasy, thiol/selenol chemistry.
What I would like to know is the Hg2+ CH3Hg+ (CH3Hg)2 rates and partition coefficients, in the flora/fauna of the gut (especially in the newborn) and in brain.
In astrocytes/neurons I want to know the rate that DNA is damaged and methylated by both MM and DMM; I also want to know if methylation/damage to the mitochondrial genome is long term and additive.
I am interested in the long term effects of low levels of Hg2+, MM and DMM. I am interested in the pulse of lipid soluble toxins, like DMM, during maternal lipid mobilization that happens during gestation and lactation; especially on fetal/neonate brain.

Rob Crawford
March 31, 2012 6:10 pm

“Lake Erie is the body of water to avoid.”
And, yet, Port Clinton, OH has a walleye festival every year, and restaurants all over the area serve the locally caught fish.

Rob Crawford
March 31, 2012 6:12 pm

“Can anyone explain why the fish-eating Japanese have the highest life expectancy in the world? Do their fish only contain good mercury?”
The lauded Mediterranean diet is also high in fish.

Heystoopidone
March 31, 2012 6:34 pm

Now let me check, according to peer reviewed science papers :
“Estimates show that 20% of global mercury emissions are from natural emissions, 40% from global re-cycling of previous anthropogenic activity, and 40% from current anthropogenic25 emissions 26. As shown in Table 4, North America contributed approximately 11% of the total global anthropogenic mercury emissions in 1995.”
As for the toxicity of mercury, in low concentrations, in the real world, one merely has to google/bing the words “Minimata Disease”.
This above all — to thine ownself be true;
And it must follow, as the night the day,
Thou canst not then be false to any man. Polonius (Hamlet Act 2 Scene #3)

Peter Laux
March 31, 2012 7:12 pm

If mercury is so evil then why does the EPA allow “compact fluorescent bulbs” that are so beloved by alleged enviromentalists ? Each bulb contains 3 – 7mg of mercury and as most will end up in landfill, they will poison groundwater.

John
March 31, 2012 7:52 pm

Robert Brown and several other argue that mercury, today, is an important health problem, linked perhaps to people dying before they otherwise would. I am happy to say that this viewpoint is incorrect, except for the type of extreme “hot spot” that Robert referred to (mercury pits at an abandoned chlor-alkali plant).
Please see the link to EPA’s Regulatory Impact Analysis, from my post above at 7:47 AM. EPA nowhere claims that mercury kills. Many studies, of which I noted but one above, find that there is no relationship between mercury and cardiovascular diseases and stroke, for example.
The only benefit EPA claims, that it states is can be sure of and measure, is an increase in IQ, for children borne of mothers who eat fish whose methyl mercury concentrations will decrease when the new mercury reduction rules are in effect. These rules call for a 90% reduction in US power plant emissions of mercury, or about a 30 to 35 ton reduction. The benefit that EPA claims for this reduction in mercury emissions is 2/1000 of an IQ point reduction per child, or a total of 511 IQ points in a year across the entire US. EPA’s valuation of this “benefit” is between $500 K and $6.1 million, based upon reduced lifetime earnings, when the national total IQ is 511 points lower.
It makes sense that people, including those on WUWT, would think that mercury’s effects are much worse that EPA states, because we have been bombarded with environmental scare stories for 15 years.
There seem to be at least two reasons for why people think that mercury at today’s levels is so bad.
First, back in the day, when people were exposed to incredibly large amounts of mercury (think the actual “Mad Hatters,” making felt hats and handling liquid mercury day in and day out), people really did go mad. Those levels of exposure are tens of thousands of times higher than today. The dose makes the poison.
Secondly, propaganda matters. Wasn’t it Bill Clinton who famously said, “Perception is Reality”? If you repeat something enough times, people will believe it — even people at WUWT.
People throughout history have been exposed to mercury, for as long as there have been humans.
Several hundred tons are emitted every year by volcanos above ground, and probably twice that from undersea vents and volcanos, given that the ocean is about 70% of the earth’s surface. That is why the ocean is so high in mercury levels, and why so much evaporates from the ocean surface, Willis.
This historical level of exposure means that we can deal with the trace amounts that are always in our body; exposure throughout history means that our bodies have learned to live with reasonable amounts of mercury. Most mercury leaves the body after about 2 months, so if you eat fish steadily, incoming and outcoming mercury are roughly in balance.
Women in the Seychelles islands, whose steady state mercury levels are about 10 times EPA’s “danger” level, show no harm to themselves or to their kids, vs. low mercury controls. These kids for many years took tests of cognitive and emotional well being, in studies by the University of Rochester (Dr. Clark et al.), but showed no differences vs. controls.
Where Robert Brown is correct is where there has been an historical dump, with huge levels of mercury relative to what is deposited from air pollution — conditions like the dump pits at the chlor-alkali plant he mentions. But it is incorrect to conflate the damage from a megadump, with the lack of damages from the trace amounts of deposition from air pollution.
One last and different point. By now, many readers have found that the huge calculated economic “benefits” from EPA’s mercury rule are “co-benefits.” If they aren’t steeped in EPA-speak, they might think that such “co-benefits” somehow relate to mercury.
Translated, “co-benefits” means that the measures that will be used to reduce mercury emissions also reduce tiny particles in the air, in this case sulfates. This is because the control systems for mercury reduce emissions of sulfur dioxide (SO2), which is transformed over hours and days into a particle, ammonium sulfate.
EPA’s official position is that any type of particle kills, regardless of chemical activity, or has any known biological activity, or not.
Further, EPA values any death it believes occurs from exposure to a particle of any type, at about $9.3 million per life lost. That “benefit” is the same, whether the person dies a day or a week before they otherwise would have, or 20 years.
On this point, many science advisors, including some of EPA’s, have advocated use of “Quality Adjusted Life Years,” or QALYs, in valuing mortality benefits. All this means is that you have a value for each year of life lost, so that someone dying a week before they would, at age 85 for example, is given a smaller valuation than someone dying in the prime of life.
I won’t belabor these last two sentences, I just want readers to reflect upon them for now.
Bottom line: the reason people aren’t harmed by the tiny amounts of mercury from US power plants (again, the reduction will be about 30 to 35 tons per year), is because people aren’t harmed by the roughly 7400 tons per year of emissions from other sources, mostly natural (volcanic emissions and re-emissions from oceans of hundreds of millions of years of mercury emissions into the oceans, from volcanos above and below the oceans). Human beings have had to become used to these emissions, that is why we aren’t damaged by them, IMHO.

kforestcat
March 31, 2012 8:25 pm

Willis
You are on target with regard to the amount of Hg reduction related to utilites. However, most people don’t know largest cost to meeting the Utility MACT standard is related to the EPAs decision to regulate HCl… not Hg or the other so called toxins. One of the EPA’s dirty little secrets is that it regulated HCl knowing full well that utility HCl emissions were well below established health standards. The EPA justified its regulation based on, get this, reducing… ocean acidification. Never mind that it didn’t have any data supporting the proposition that the proposed HCl reductions would in any way reduce ocean acidification & had not made a finding that ocean acidification was as problem.
So here’s the kicker, If Congress repeals regulation of CO2 on green house gases, then I would look to the EPA re-regulating CO2 based solely on a ocean acidification claim, using the Utility MACT as precedence.
Incidentally, had the EPA used the MACT to regulate only Hg, then the capital cost would have been minimal. Basically it would have required the installation of Activated Carbon Injection (ACI) systems.
Moreover, had the EPA provided sufficient time, under the new CSAPR rules, for utilities to install Wet Flue Gas Desulfurization (Wet FGD) systems (for SO2 removal); then the wet FGDs would have reduced Hg emissions by about 90% with no need to use ACI systems. It take a minimum of five years to design, permit, and install a Wet FGD. Under the worst case scenario a utility would have had to install and operate an ACI system until it could have installed a wet FGD.
Instead, the EPA only provided sufficient time under CSAPR rules to install Dry FGD systems. Dry FGD systems don’t remove Hg , force utilities to use medium sulfur coals, and require the use of high cost lime as a feedstock. Wet FGDs reduce Hg, use low cost limestone, and allow the use of less expensive high sulfur coals. In short, the Jackson EPA used the rule making process to force utilities to use higher cost coals, high cost reagents, and reduce Hg emission by the most expensive route.
The short version is that Americas could have had a substantive reduction in Hg emissions with little to no additional cost.
Incidentally, I participated in the inter-agency review of the Utility MACT rule. I can tell you there was deep concern that the EPA could only find ~$6 million/yr in cost benefits for Hg reduction against a cost of many billions. The Utility MACT is a travesty and an example of bad public policy created by ideological zealots.
Regards, Kforestcat

DocMartyn
March 31, 2012 8:45 pm

John, there is a mineralization sink for mercury, the formation of Cinnabar (mercury(II) sulfide (HgS)) and an input, volcanoes. Between the input and sink, we would have a steady state level in different habitats. inorganic mercury is not volatile, but methymercurychloride is, but only just.
Burning coal does introduce more mercury into the atmosphere, which then gets into the ground, into water, into rivers, lakes, estuaries and finally the ocean. There is sinks, ends up as cinnabar, and essentially disappears from the biosphere,
Much of the mercury on land and in the oceans comes from human activity, it is mercury that is kicking around the biosystem being chemically and biologically transformed between organic/inorganic forms. It will all end up mineralized underground or in the bottom of the ocean.
However, mercury is a toxin, it does attack the brain and we can stop dumping in the areas we live with low cost measures.
The scandal is not that people do not like mercury in the environment, but that the politicization of the EPA means instead of trying to get the biggest bang for buck, attempting to phase out mercury in light sources, they are attacking coal powered power stations.
Trying to stop mercury entering ground water and the food chain is a very good idea, as many people eat seafood, this means stopping mercury getting into the oceans. .

TRM
March 31, 2012 9:03 pm

So humans contribute about 50% of the mercury polution. Oceans were a big surprise to me as well. China, wow. (Europe + North America)*2=China. I thought India would be higher.
So maybe the focus should be to get the other countries to clean up. Mexico is part of North America and is dragging our average down. Need them to clean up but then where would the advantage be for companies wanting to do things cheap and stupid?

March 31, 2012 9:22 pm

If you want to confound a ‘green’ advocate touting CFLs, try this line of questioning:
Wouldn’t it be great if everyone replaced every lightbulb in their house with a CFL? (of course!)
The average house has between 50 – 100 lightbulbs (don’t forget the exterior flood lights!). (ok)
Did you know that Hurricane Katrina destroyed an estimated 340,000 homes, many washed out to sea, in less than 48 hours? (ummm)
How many CFLs would that have been? How many hundreds of kgs of mercury released, much of it into the Gulf of Mexico, concentrated over perhaps just a hundred miles? (errr)
And of course that area is a major fishing/shrimping/oyster producing region. (uh oh).
Isn’t that nice. You’ve just destroyed an industry, destroyed thousands of jobs, and poisoned a major source of this nation’s seafood.
Still like CFLs? (^&**$)

March 31, 2012 9:42 pm

“Environmentalists” seek an immaculate world free of chemicals and elements and such . It wasn’t that long ago that Greenpeace declared war on chlorine . Apparently that was so dumb they gave up after a couple of years .
All these various metals and compounds are naturally occurring . Hg is in coal because , and in the proportions it is , because it was in the biosphere that became the coal in about those proportions . These substances are part of the fabric of life and fear of them greatly exaggerated , If they can declare the very building block of life a pollutant , and salt and calories dangerous to the diet , what chance do trace metals have ?

Larry in Texas
March 31, 2012 9:50 pm

Robert Brown says:
March 31, 2012 at 9:46 am
Dr. Brown, I respect your scientific knowledge and I learn a lot every time you post something here. But I think the point must be made here again. EPA approaches what are essentially local problems with an extremely broad sweep, without really assessing what the real problem is and whether or not it really accomplishes anything with the real costs that will be incurred.
Methyl mercury and mercuric cyanide are indeed, dangerous and toxic chemicals. But is it really fair to single out coal-fired power plants when such plants are probably operating at their maximum effectiveness now? Is it fair to just go after the low hanging fruit?
I also think that you are being unfair to Willis, because you have not cited anything that would contradict the Pirrone paper that Willis cited. Perhaps there is something, I would like to learn about it if there is evidence to the contrary; but it is interesting to learn here that the largest sources of mercury are natural. I don’t want to dismiss the dangers of mercury or mercury poisoning. But I don’t want EPA killing gnats with sledgehammers, only to find that the gnats remain AND that the big bugs are still out there screwing us up even worse.
Thanks, Willis, for your fine work.

Larry in Texas
March 31, 2012 9:59 pm

Willis Eschenbach says:
March 31, 2012 at 5:39 pm
The high incidence of environmental groups such as EDF suing EPA, and then receiving grants from EPA, is an old political trick. Often, EPA encouraged environmental groups to sue them in order to provide EPA with political cover. This is because many of the things they wanted to do were either legally dicey in their minds, or were politically unpalatable to either industry or to Congress. So it is not any surprise to see EPA giving groups like EDF grants. It is the most satisfying mutual back-scratching operation in all of the Federal bureaucracy.

kadaka (KD Knoebel)
March 31, 2012 10:00 pm

From TRM on March 31, 2012 at 9:03 pm:

So humans contribute about 50% of the mercury polution. (…)

Nah. From the Abstract of the paper Willis used:

(…) On an annual basis, natural sources account for 5207Mg of mercury released to the global atmosphere, including the contribution from re-emission processes, which are emissions of previously deposited mercury originating from anthropogenic and natural sources, and primary emissions from natural reservoirs. Anthropogenic sources, which include a large number of industrial point sources, are estimated to account for 2320Mg of mercury emitted annually. (…) Therefore, our current estimate of global mercury emissions suggests that the overall contribution from natural sources (primary emissions + re-emissions) and anthropogenic sources is nearly 7527Mg per year, the uncertainty associated with these estimates are related to the typology of emission sources and source regions.

Mg is Mega-gram = 1000 kilograms = 1 metric tonne.
2320/7527=0.3082, human contribution is only 31% (rounded up).