ILLINOIS POLLUTION CONTROL BOARD

.April7,• 1971

In the Matter of

)

ft

70—5

MERCURY STANDARDS)

)

Supplemental Comments to Opinion of the Board

Samuel R. Aldrich, Board Member

The opinion written by Mr. Cuirie and adopted by the Board

March 31, 1971 is generally an excellent statement and I

support most of it wholeheartedly.

I desire to comment on four points.

1.

The rationale for setting the standard at the lowest ooint

that can be naasurcd with readily available technique

(atom

~~PL9~12aJ~

thg.~cr~o

ot

mcirciwy).

Because

of

the

hiqh.y

toxic

nature

of

mercury

and

the

known

pathways

by

which

it

is

transforned

azid

cedistributed

throurjhont

the

environment

it

may

be

acceptable

to

set

the

standard

at

the

lowest

feasible

limit

based

upon

available

anclytical

procedures.

The

same

logic may be applied to cadmium and a few other elements.

I feel, however, that with few exceptions, we must be guided

by proven hazard levels, either by direct intake or after

concentration within

the food chiin.

Scientific techno3.ogy

conceivably can deveop

far more sensitive mecsurement techni-

ques but that does not mean that we should baáe standards

upon them.

In the case of mercury, the Board did not set the

standard at the analytical limit of a more sensitiye technique

(neution activation) as discussed in the opinion because it is

not generally available.

The inference is that if neution

activation were readily available,

the standard might be lower

than .5 ppb.

I would not support that as a logical basis for

a lower standard.

2.

Assumptions that guided the ~oard in reaching a standard

of

5

ppb7

The

standard

is

far

lower

than

that

set

or

thus

far

reconunanded

by

other

boards

and

agencies

for

food

or

drinking

water.

The

strict standard was justified at least partially. on the follow-

ing

assumptions

tciich

have

not

been

proven~

a.

That mercury is not detoxified or lost into some inert

natural sink.

1.

aqe

---

b.

‘s’hnt

eventually

all

i~crcury (ol c•nental

or

co:tpounds)

converts

to

solublo

or

volatile

rSthyl

mercury

which

is

highly

toxic.

c.

That

there

is

either

no

thretholcl

of

tolerance

to

methyl

wurcury

or

that

it

is

“as

lot:

au

a

han&ul

of

parts

per

billion”

for

aquat~c life

ar.cl

“nay

be

harmful

to

man

in

the

parts—mir—hiliioiz

range”.

The

majority

opinion

of

the

Board

appears

tc

be

substantially

influenced

by

the

astmmption

that

there

is

no

tolerance

to

methyl

mercury.

d.

That

mercury

use

in

p4dnts

hat;

only

adverse

possible

health

effects.

To

the

contrary,

mercury

in

paints

controls

several

species

of

i.~slc1s

:.:::~

fungi

to

‘ahich

rany

persons

have

allergic

r~~acUons.

Until

tc::?ptable

substitutes

are

found

and

a:ic::!uatci’.’

t:~stcd,

~t

is

enLiroly

tossible

that

the

potontiafly

hanful

uffects

(rem

the

use

of

mercury

in

certain

paints

is

of

:!30t

by

the

benefit

from

the

ccntrcl

c~ nllorçytnic:

organisr.s.

the

concept

of

bencfi 1:/risk

3

r

recog:titr:1

in

tho

majority

c’ui

nictn

‘~~hA:2:

c.~:c::.p1.5

hospi

tnt

.

~rc~a

the

.5

ppb

stcnci:.rc..

3

•

it

zt’rn

g;tasa~3ztjci

ro :iutn

~i in

cc’rL::th

I

ç.~’n

tc.

A

uni

cjuc.~

Si twa t Icn

c’bt:t i~:

s;

WiCfl

~

in ta:c•

~~:ntc’r for

~n

incluctry

or

mimicS Nil

.

ty

i~ aln:n3”

at

U~ e!;tab

I i:thcd

water

guca

Li ty stazt~lttrC for

tit••

rc: zv.

5.vf~:::s•::• ~

!j•Le

~

~

stanektrd

of

the

FC3

Cow.

not

91::.

t.Zw

t.~

t

c..r

w;er

tht~

right:

to

acId

.5

ppb.

In

tha1~case

tin

efCxc2nt.

st:itnzi::::z:

!.~:

~rc:

.

In

the

titl;c:

Cf

morct;r:;,

an~

perhnps

::.an~’ othrr

i;n~c

ti.Lt~’n:n,

th•.~h;tckcjrou::C

level

iLi

to

he

::ubntr~:c.t~.d

irc’::t

Iha

li~z~dttffltte::t

stinsciai

:

in

cic’termin~

1:::

the

tc.~

c:rabl u

c.f:1 i:cnt

1c~

:cl

for

the

inuUbVfl’

or

itunicipality.

lie

know

that

thc

cent

to

rcir:n’e

yr’

tuta::tc

rises

curvili

n~.ar3v.

Tho

last

10

Pt.rC~Zt n.y

‘x’

us

t..~ttly to

tenovo

as

the

first

90

percent:

thc

tJ~rcr:t~jftj’~m

th.

i

ir::t

9Qj~~~p:~.

The

Environr~nt:il

Protuc:tjon

it~t~~:tcy

rc”uires

thu

?oard

to

eonsic~ar

ecoysomi

C

roasc’nablencnf;

in

sett.inr;

u

tan&. nh.

In

ord~~r

(or

the

Doar~ to

on~’r

coriplote

ban

on

any

dipehnrtc

to

a

stream

~r

lake,

x ~

t:,.~.ttht.

i:o:~rdmust

have

irrt.iuUblo

CA’CiCfl:~’.

‘~h~

t

1

~ there i~no :r

U:

e

ci .tc,xifictic~’and

2)

.

.

.

u:nz’

i.z;

at

!.he

lc: .•C

cf

the

t:4,ter

c:uc.iity

&.~

~

1-423

---

The Act requires the Board to consider technical fbasibili.ty and

economic reasonablenons.

Granted that ~tercuryis.an extremely

hazardous element,

I have reservations as to whether we follow

the guidelines in the Act when we require an industry or munici-

pality to do one of the following:

1)

remove 100 percent of their contribution.

2)

install a con~letelyclosed system with attendant waste

disposal problems.

or

3).

close the factory.

Because of the considerations described here, r register misgivings

about the proposal to force all users of mercury to meet the zero

effluent standard where the extremely strict standard of

.5 ppb is

encountered in intakq water.

In the long run it seems to me that

downstream dilution will somehow need to he considered so as to

modify the zero effluent standard for existing industries.

1/

I

~e’~/.

‘;t~

~:

(Ic~i

i-:’:t~

.~

A

samueft

Ald~i~W

--

Member,

Illinois Pollution Control i3oar~

I

Ungina

E.

Ryan,

Clerk

of

the

!Y3 ~noi s

Pollution

Control

Board

certify

that

Dr.

Samuel

ft.

Aldrich

submitted

the

above

opinion

on

7

day

of

April,

1971.

Illinois

Control

Board