Economic Cost of Mercury/Toxic Metals Emissions in Florida 6-1-07

High levels of mercury have been found in the rain throughout Florida and the U.S.(42,11), resulting in accumulation of mercury in the environment, water bodies, fish, wildlife, and people of Florida. Approximately 30 % of Floridians tested for mercury in 2 studies had dangerous levels of mercury body burden(32).

The largest sources of emissions have been found to be coal power plants and incinerators(11). The level of mercury in rain ranged from 1.3 to 81.2 nanograms per liter depending on location and weather conditions, with an average of 12.6. This resulted in average annual deposition of about 17.6 micrograms of mercury per square meter, much higher than the U.S. EPA health criteria to prevent harm to wildlife and humans (42,43). The Electric Power Research Institute(38) and other studies have found that only ½ gram of mercury is required to contaminate all predator fish in a 10 acre lake to the extent that fish consumption warnings are required, and enough mercury is being released into the environment of Florida to raise levels in all predator fish to such a level. From past monitoring and laboratory experiments, it is projected that another significant source of mercury in the environment is from temperate/boreal forest fires and from all

biomass burning(51). "The combustion of litter and green

vegetation under controlled burn conditions resulted in essentially complete release of mercury contained in fuel. This is different and higher than releases reported for some coal and biomass burning. Highest mercury concentrations were found in litter, reflecting accumulation of dry and wet deposition mercury over growing seasons. A suggested regional difference in mercury concentrations in vegetation coincides with the known highest dry/wet deposition rates in the US northeast and northwest. Mercury is emitted almost exclusively as elemental mercury (TGM, >95%) and thus joins the global pool. ..." (51)

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Another significant source of mercury in Florida water bodies is dental amalgam. Dental amalgam is documented by medical lab tests to be the largest source of mercury in most people with several amalgam fillings, and the largest source of mercury in sewers and sewer sludge , and thus a significant source of mercury in fish and wildlife. Since mercury vaporizes continuously at room temperature, mercury in sewer sludge outgases and there are significant air mercury emissions from crematoria.

The majority of lakes and rivers in Florida tested and thousands in other states have been documented to have dangerous levels of mercury and other toxic metals accumulating in sediments and in the fish and food chain (3,6,9,10,11,28,36). Health warnings have been issued against eating fish in the hundreds of lakes or rivers affected(9,36,6), as well as against eating sharkmeat caught throughout Florida or several types of saltwater fish from areas of the Florida East Coast or Panhandle Gulf Coast due to dangerous levels of mercury in the fish (28,29,33,36). Florida commercial fishermen sold 6.8 million pounds of sharkmeat in 1989, 36% of the U.S. total. Over 1/3 of the shark meat tested in Florida has been found to have dangerous levels of mercury(33). Twenty seven other commercially important coastal fish or seafoods have dangerous levels of mercury according to experts and tests(28,36). High levels of toxic metals have been found in shellfish in many areas of the state (36,28). This represents a major economic cost to both Florida and the U.S.

The level of mercury emissions of Florida coal plants and incinerators prior to the addition of improved emission controls (over 4 tons per year (20)), as well as the current levels of emissions appear to be far above the level required for depositions over large areas of Florida to be above the level previously documented to be sufficient to bioaccumulate to dangerous levels in fish (20,38,11,42,43). There is consensus among researchers that the main source of the mercury in lakes is from air emissions, with the largest sources being municipal incinerators, medical waste incinerators, and coal plants in most areas (6,9,11,29,31,34-39,20). Emission levels had been found to be increasing since the 1900s with the largest increases in since the 1940s(30,35,39). Toxic levels of aluminum and other toxic metals also appear to be the main factor adversely affecting fish and other organisms in lakes or streams that are becoming acidic throughout the U.S. Florida has the most acidic lakes in the U.S. Commercial fishermen and the sportsfishing sector have already been seriously adversely affected. There is also consensus that acidity and acid pollutants are major factors in the level of toxic metals getting into fish and the food chain (6,11,35,46). Mercury emissions from incinerators have been significantly reduced in recent years due to a requirement to improve emission controls. However mercury and other toxic levels in ash have likely thus increased, making the ash more toxic than before.

According to the Fla. Fish & Wildlife Commission(40,41), the freshwater(bass) fishery in Fla. is responsible for over $1 billion in direct sales per year to the Florida economy in 1990 . According to a 1980 survey of sports fishermen by the U.S. Fish and Wildlife Service(40), there were over 23 million freshwater fishing trips by sports fishermen with the average trip spending $26.79 on bait, tackle, gas for boats, and lodging alone. This $615 million would have been only a portion of the total value of the fishery, which would be at least double that amount now for all freshwater fishing expenses affected. Over half of the fishery has been affected by health warnings and studies have indicated a decline of approx. 20 % in fishing in areas studied that have well publicized advisories. The adverse publicity has affected the entire state. This means a loss of approx. $400 million in reduced expenditures on freshwater fishing trips and equipment each year alone. If 50% of the estimated 40 million pounds of bass caught and eaten in Florida each year during the early 1980s are now not eaten and had their economic value subtracted at $1 per pound due to the hazardous levels of mercury, this would be $20 million in reduced value of bass meat. This would not include the other types of freshwater fish affected which would add at least $10 million more. Over 1 million acres of streams and lakes are affected by health advisories in Fla., with the affected areas producing approx. 20 harvestable bass(> 10 inches) per acre per year. This alternative calculation of the value of the bass gives 20 million bass affected in affected areas and at an average of 1.5 pounds per bass(40) gives 35 million pounds of bass affected. At $1per pound this would give $35 million. Thus the direct impact on the Fla. freshwater and saltwater fisheries appears to be over $445 million, not counting any indirect economic effects or adverse health effects on people eating such fish.

A study by the Florida Fish and Wildlife Conservation Commission found that direct sales and taxes related to saltwater fishing were over $4.4 billion per year(41), representing over 3 million anglers(45,42). If a 20% reduction in economic value similar to the one found for fresh water fish warnings were assumed, this would amount to $880 million in losses per year. Counting shark meat alone, over 2 million pounds of salt water fish per year are estimated to be contaminated with dangerous levels of mercury alone, and at $1.50 per pound would give at least $3 million, not counting adverse health effects. Since it has been found that most Florida saltwater commercial species have dangerous levels of mercury, the total losses are likely many times this amount. There have likely been at least this much in additional losses in lower amounts of saltwater fish and shellfish being eaten due to the adverse publicity.

The U.S. Center for Disease Control(CDC) and other federal agencies rank toxic metals as the number one environmental health threat to children, adversely affecting millions of children in the, U.S. each year(1-4,7-11,18). According to an EPA assessment, the toxic metals mercury, lead, arsenic, cadmium, chromium, and nickel are all ranked in the top 12 toxics having the most adverse health effects on the U.S. public based on toxicity and current exposure levels(2). EPA and CDC indicate that over 3 million children have their health significantly adversely affected or learning ability significantly adversely affected by lead in drinking water, mercury in fish, or other toxic metals from emissions(1-4,7,8,18). Evidence indicates that over 60,000 children are born each year with neurodevelopmental impairment due to methylmercury(4,18). As noted, emissions are the main source of mercury in lakes and streams and acid pollutants are a major factor in the level of mercury or other toxic metals in fish and of lead or cadmium in drinking water(11,20,9).

Some persons have been diagnosed with mercury poisoning from saltwater fish, as well as from freshwater fish. Studies (36,32) have also found that the level in most large predator species on the Gulf Coast is higher than levels found to adversely affect health(25) with mercury contamination being pervasive along the whole coastal area, and that people who eat Gulf Coast fish at least once per week usually have dangerous levels of mercury(36,32). 29% of a coastal sample from Florida, Alabama, and Mississippi ate fish at least once per week(36,32). Thus would indicate that over 1 million Floridians likely have dangerous levels of mercury exposure. A U.S. CDC study found that it is likely that well over 1000 Florida babies per year have received exposures sufficient to cause developmental disabilities(4,18,36).

Based on large numbers of medical studies and government assessments of these studies, it appears that over 1 million Floridians likely have significant developmental or adverse health effects related to mercury(or other toxic metals)(18,32,36,1-4,7,25). If a very conservative estimate of the average annual cost per person having a significant adverse learning disability or health effect were estimated at $3,000, the annual health cost due to mercury or toxic metals would be over $3 billion per year. Florida appears to be one of the states most adversely affected(9-11,28,36) and health authorities believe mercury exposure from fish is the most significant source.

Mercury, lead, aluminum, and other toxic metals have been found to be accumulating in forest floors at levels high enough to cause forest declines and diebacks in some areas of Europe and the Eastern U.S(5). Both inorganic and methyl mercury are toxic to spruce seedlings at levels of 0.4 to 0.5 ppm. Many areas of Europe have passed this point in cumulative mercury buildup and some areas of the Eastern U.S. are approaching this level(5). Toxic metals have also reached levels in food crops in Europe documented to be causing health problems, and vegetables cannot be grown in some regions or eaten safely in grown in other regions. Levels are building up in the food chain in the U.S.-especially in urban/industrial areas(39,36) and including areas in south Florida with documented high deposition levels(29,36). Gov’t studies have found that mercury deposited on soil has mercury methylated to methylmercury by soil bacteria of which some is transferred to crops and some is outgased when the sun shines to later come down in rain(50). This represents another large potential economic loss, as well as from health effects.

High levels of mercury have been found to evaporate from fly ash piles at temperatures higher than 70 degrees F. Temperatures above 86 degrees would likely produce levels of mercury in the vicinity violating EPA ambient air guidelines(11,12). This could cause health effects on site, as well as being a regional mercury source. Florida ash piles can reach 140 degrees in the summer(11), and ash piles of plants using lime to control sulfur often get much hotter than this due to hydration. Additionally, mercury from ash piles that is land spread or landfilled has been found by government studies to be methylated to highly toxic methyl and di-methyl mercury and be outgassed, being a factor in the high levels found in rain througout Florida(36,11).

The coal and ash piles from coal plants or incinerators contain large amounts of toxic metals(as well as dioxins, furans,etc.) which can affect both ground and surface water, as well as considerable particulate and toxic air emissions. Widespread serious health effects have been documented for plant workers working with ash at the facility or ash piles(11). This has been confirmed both in Florida and other states with ash piles. A coal plant with scrubbers per megawatt of power generated produces about 308 tons of fly ash, 77 tons of bottom ash, and 364 tons of flue gas desulfurization waste for landfilling- all containing toxic metals and other toxic constituents(13). Many coal ash laboratory tests have found cadmium and arsenic at levels considered hazardous per EPA RCRA standards(13). Many toxic constituents from coal combustion waste disposal sites have been detected in both on-site and off-site ground water and surface water. Where the depth to groundwater is less than 30 feet, "there is a reasonably high potential that leachate will reach groundwater" unless extensive precautions are taken(13). The high PH that often characterizes Western coal tends to cause the release of harmful toxic metals such as arsenic, selenium, and manganese. In Florida, radionuclides, mercury, and other toxic metals have been found in sediments and the food chain in rivers and bays near coal and ash piles.

The average cost of disposing of hazardous waste in the Midwest is $210 per ton(26). The Dept. of Environmental Regulation reports that the cost of recent contracts in Florida has ranged between $250 and $360 per ton, including transportation and taxes. Assuming that a conservative $250 per ton is the public cost of disposing of fly ash(or of related health effects), that $100 per ton is the cost of disposing of bottom ash, and $50 per ton is the cost of disposing of desulfurization waste gives a total cost of ash disposal per MW of coal plant power of (308 x $250 + 77 x $100 + 364 x $50) = $102,900 per year. Assuming a 70 % capacity factor gives 6132 megawatt-hours per MW of power. Thus the ash disposal cost would be 1.7 cents per kwh.

The ash from incinerators contains more toxic metals, and other toxics such as dioxins or furans, than coal ash; most incinerator fly ash tested has been shown to be toxic under EPA toxicity standards and much is in a soluble form(14, 15, 21-24). The metals most commonly failing the toxicity test are cadmium and lead, but high levels of mercury, arsenic, and chromium have also been found(24). Some states already require ash to be tested and disposed of as toxic waste. Tests by the State of New York showed more than half of its incinerator waste tested was "hazardous" and all waste in New York will be disposed of in hazardous waste sites or special sites with additional precautions(19a). Bottom ash has also been found to have relatively high levels of toxics(24). The toxics in ash has been documented to have widespread and serious health effects on those working with the ash at facilities, and the health effects on the public from trace metals and dioxins have been shown to be higher than for the traditional pollution emissions normally considered(16). Ash disposal has also been found to face much higher cost than normal landfilling due to: abrasive impact on equipment & tires, corrosive effect on equipment, unworkability when wet, and health effects on workers(19b). Many researchers think ash disposal and pollution cleanup from ash pile toxics will become increasingly expensive.

The 160 MSW incinerators operating in the U.S. produce about 8 million tons of ash each year containing, by rough estimate, some 18,000 tons of lead, over 50 tons of mercury, plus lesser quantities of other potent toxins such as cadmium, arsenic and dioxin.[ Assuming the 8 million tons are 90% bottom ash containing 2000 ppm lead and 10% fly ash containing 4000 ppm lead](23). Ash containing 2000 ppm lead is contaminated at a level more than 5 times as high as the "level of concern" EPA recently set for lead in soil.

Hazardous waste can cost up to $300 per ton for burial at a legally-designated hazardous waste dump. Judi Enck of the New York Public Interest Research Group estimates that ash can be placed in an "ash monofill" for only $70 or $80 per ton(23).

A 1000 ton per day mass burn incinerator at 76% capacity produces 25 megawatts

of power and 138 million kwh per year, along with 100 tons of fly ash and 200 tons of bottom ash per day. At $100 per ton for fly ash disposal(26,23) and $50 per ton for bottom ash disposal, the total disposal cost would be $7,300,000 per year. This gives a cost of 5.3 cents per kwh.

Florida utilities burned 33,654,000 tons of coal in 1999(27). Based on the EPA estimate of .21 ppm mercury in Eastern coal, this would give approx. 7 tons of mercury in the coal burned in Florida per year. The mercury not emitted in the flue or from the ash piles would end up in the ash pile, which would be highly toxic. Fla. utilities burned 56.3 million barrels of oil in 1999, and using EPA estimates for .06 ppm mercury in residual oil and .4 ppm in distillate oil, would give approx. 0.62 tons of mercury in oil burned by Fla. utilities. Based on current technology it appears likely that the majority of such mercury was emitted directly or indirectly.

Similarly municipal solid waste incinerators were projected to burn approx. 5.8 million tons of garbage in 1991, with an average mercury content of 2 ppm according to EPA data. This would give a content of approx. 10 tons of mercury, much of which would be emitted. Currently more tons are burned with a lower mercury level but the total amount may be similar. FDEP estimates of MSW incinerator mercury emissions are lower due to additional emission controls added a few years ago . But high levels of mercury and toxic metals would be in the ash. Based on this and previous studies by the Dept. of Environmental Regulation, it is assumed that coal power plants are responsible for approx. 25 % of Florida mercury emissions and MSW incinerators for 10% of mercury emissions. Fla. coal plants generated 78,413,000,000 kilowatt hours of electricity in 1999 and MSW incinerators generated 2,684,000,000 kwh of electricity. If economic cost due to mercury(and other toxic metals) emissions is assumed to be $1251 million per year, with coal plants responsible for 25% of emissions and MSW incinerators for 10% of emissions, then the economic cost related to coal plant emissions would be 0.4 cents per kwh of electricity generated. Likewise for MSW incinerators, the economic cost would be 4.7 cents per kwh generated. So the total metals related environmental cost for coal plants would be approx. 2.1 cents per kilowatt-hour, while the corresponding cost for municipal incinerators would be 12.9 cents per kilowatt-hour. Since biomass plants are generally less efficient than coal plants and often have less effective controls, biomass plant mercury emission cost may be somewhat similar to those for coal plants, but it would also depend on the mercury deposition levels and patterns in the area of the fuel source and whether litter from tree cutting is also burned.

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