Whaf could wafer regulafions cod? A look at Illinois effluent standards for mercury could give an idea in terms of dollars and jobs
Echo1 E. Cook Lee Rogers John H. Yopp Southern Illinois University Carbondale, Ill. 62901 The Illinois State organization for pollution control, formed by the 1970 Illinois Environment Protection Act, is composed of three separate, but interrelated agencies responsible for curbing pollution. Two of the agencies-the Illinois Environmental Protection Agency (IEPA) and the Illinois Institute for Environmental Quality (IIEQ), known as the Illinois Institute of Natural Resources ( I I N R ) since last July-were established as a part of the executive branch of government. T h e third agency-The Pollution Control Board (PCB)-is independent, although its members are appointed by the Governor, subject to specific qualifications, and advice and consent of the state senate. The IEPA is the state’s permit, inspection and enforcement branch. The IIEQ, now the I I N R is the research arm of the state for environmental matters. The PCB is both quasi-legislative and quasi-judicial; it both adopts regulations of environmental importance and sits as a sort of pollution court to hear alleged violations of regulations and the Environmental Protection Act. In 1971, the Pollution Control Board adopted effluent standards for the waters of the state. These effluent standards established the maximum allowable concentrations of various contaminants that may be discharged to the state’s waters. Subsequently, several proposals have been made by industry, the Illinois EPA, and other parties to change the maximum allowable concentrations of various contaminants, modify certain times for compliance, and delete reporting re656
Environmental Science & Technology
quirements of various types. Each change legally requires action by the three agencies of the state. I n 1975 the State adopted legislation (Public Act 79-790, Senate Bill 805) requiring the IlEQ to perform economic impact statements on all proposed new regulations and regulation changes. Upon completion of the economic impact statement, public hearings would be conducted throughout the state to allow industry and the populace to hear and present testimony on the proposed new regulation or regulation change. Since a number of state and federal agencies have expressed an interest in the use of economic impact statements in Illinois, it is felt that a case study of a portion of one such statement would be beneficial. In November 1976 the Illinois Institute for Environmental Quality proposed an effluent regulation change which would, in effect, change the mercury effluent standard from 0.5 p g / L to 3.0 p g / L . The authors were contracted by the Illinois Institute for Environmental Quality to perform the economic impact study of the rqgulation change.
How dischargers were selected A list of single-sample mercury effluent data since 1974 was obtained from the IEPA. From the list, it was found that 170 dischargers were in violation of the present 0.5 p g / L mercury effluent standard on the single sample. Of the 170 samples, 33 were found to be in excess of the proposed 3 p g / L effluent standard. Illinois EPA historical data on mercury discharges in Illinois from January 1972 to February 1977 were obtained; from the data, it was found that I23 dischargers had mean values of effluent mercury in excess of the present 0.5 p g / L effluent standard. The data indicated that the vast majority of dischargers having mean
mercury effluent values in excess of 0.5 p g / L was attributable to a single very high value which made the mean in excess of 0.5 pg/L. I n most cases, all other sample values were below the present 0.5 p g / L standard. In any case, it is highly improbable that the one high mercury value could be explained. Because of the realization that 123 dischargers were far too many to investigate, a discriminator was applied in hope of narrowing the list to a reasonable number. The discriminator was obtained by throwing out the high mercury concentration value for each discharger, and calculating an “adjusted” mean mercury effluent concentration from the remaining effluent mercury values, i.e.: Maximum Mercury xcidJ = Concentration - Concentration N-l I n some cases, only one sample had been taken, and if it exceeded the 0.5 p g / L value, that discharger was chosen for further investigation. This manipulation reduced the number of dischargers who equalled or averaged greater than 0.5 pg/L mercury in their effluent from 123 to 2 2 . The 22 remaining dischargers consisted of five industries, five sewage treatment plants, seven educational institutions, one nursing home, one recreational facility and one correctional institution. The recreational facility was included as a discharger, even though its adjusted mean mercury effluent concentration was only 0.46 p g / L . -
1Mercury
Cost basis The economic impact analysis performed on the various dischargers is based on treating or removing mercury via ion exchange. That technique can
0013-936X/79/0913-0656$01 .OO/O @ 1979 American Chemical Society
achieve a mercury effluent of 3.0 pg/L and has been cited by Patterson and other members of the Illinois Effluent Standards Advisory Group (IESAG) as the best practicable control technology currently available ( B PCTCA). The analysis is based on the proven Osaka ion-exchange process which has a capital cost of $20000/1000 gpd capacity, and operating costs of $ 1 .OO/ 1000 gallons, in terms of 197 1 dollars. With a 6% per year inflation rate, these cost figures at 1977 dollars become $28 370/1000 gpd and $1.421 1000 gallons, respectively. All other dollars are 1977 dollars; interest is 6% per annum, and a 20-year life is assumed for all capital goods. With these assumptions, the capital cost for the ion-exchange process becomes $2473/y/ 1000 gpd capacity, and the operating costs remain $1.42/ 1000 gallons. These figures were used in all calculations of effluent mercury treatment costs for all discharger categories. There are essentially 2 cases to consider, in order to determine the economic impact of changing the mercury effluent standards from 0.5 p g / L to 3.0 p g / L : Consider the “adjusted mean mercury effluent concentration” as a quasi-composite sample, and an “ad-
justed mean mercury effluent concentration” in excess of 0.5 p g / L dictates that mercury treatment must be accomplished. Consider the “adjusted mean mercury concentration” as a quasicomposite sample, and if it is in excess of 3.0 p g / L , then mercury treatment must be accomplished. All dischargers and their treatment costs will be considered in light of these 2 cases and are shown in Table 1 . Industries
There were five industries in the state whose “adjusted mean mercury effluent concentration” exceeded the present 0.5 p g / L mercury effluent standard. They included a recycled box board plant, a secondary refiner of copper, a cement plant, a producer of laundry and cleaning products, and a highly integrated chemical plant complex which includes a chlor-alkali plant. I f the “adjusted mean mercury effluent concentration” is a quasi-composite sample, and an adjusted mean mercury effluent concentration is in excess of 0.5 pg/L, which dictates that mercury treatment must be accomplished, then all five industries must treat for mercury at a statewide cost of almost $28.9 million/y. On the other hand, if the “adjusted mean mercurj
effluent concentration” is a quasicomposite sample, and an adjusted mean mercury effluent concentration in excess of 3.0 p g / L dictates that mercury treatment must be accomplished, then only one discharger must treat for mercury. at a cost of $733 OOO/y. This represents a 97.5% decrease in treatment costs. statewide. Most industries considered their 1976-77’ fiscal year budget as proprie t a r j ; therefore treatment costs are reflected as a percentage of the respective industries’ 197’6corporate net income after taxes. Treatment costs varied from 0.04%-184% of the respective industries‘ 1976 corporate net income. Municipal sewage treatment plants
As shown in Table 1 . there were five municipal sewage treatment plants in the state whose “adjusted mean mercury effluent concentration” exceeded the present 0.5 p g / L mercury effluent standard. Of the individuals interviewed at the sewage treatment plants, most indicated the), could not positively identify the source of mercurq in their effluent. Two of the five plants received large uastewatcr volumes from industry. and there \vere numerous possible sources of mercury from industry. Three of the five plants used
TABLE 1
Discharger data and mercury treatment costs for various sectors in the State of Illinois Parameter
Dlscharger:
Number of dischargers . Range of flow volumes (1000 gpd) Range of number of samples taken from ‘72-’77 Range of number of samples >0.5 pglL Hg Range of number of samples >3.0 pg1L Hg Range of adjusted mean mercury effluent concentrations (pg1L) Mercury treatment Range costs if adjusted mean Hg concn. exceeds Statewide 0.5 pg1L ($lOOO/y) costs Mercury treatment Range costs if adjusted mean Hg concn. exceeds Statewide 3.0 pgIL ($lOOO/y) costs Range of fiscal year ‘76-’77 budgets (lOOO/y) Range of mercury treatment costs as % of FY ’76-’77 budget Range of mercury treatment costs as % of 1976 corporate net profits (after taxes) a
Industry
Sewage treatment plants
Educational lnstltutlons
Miscellaneous dischargers
Total
5 4.5-5875 3-25
5 50-43 600 10-38
7 6-384 1-1 1
3 57-98 7-1 1
N/A N/A N/A
2-24 0-17 0.53-49
3-14 0-3 0.6-6
1-8 0-7 0.5-18.5
3-7 0- 1 0.46-1.3
N/A N/A N/A
13.5-18 251
0-130 451
0-1 148.5
0-294.4
N/A
28 895
134 568
2183
465.8
166 112
0-733
0-377
0-598.2
0
N/A
733
377
724
0
1834
N/A a N/A
NIA N/A
1067-33 168 N/A 1.7-8.2 N/A
N/A N/A
0.04-184
NIA
NIA
N/A
N/A
N/A = Not available or not applicable.
Volume 13, Number 6 , June 1979
657
trickling filters, and one still had the mercury seal intact. I n the two possible cases dictating treatment for mercury: If the “adjusted mean mercury effluent concentration” is taken as a quasi-composite sample, and one retains the criterion that 0.5 p g / L of mercury i n the effluent dictates treatment for mercury, then four of the five dischargers must treat for mercury, at a cost of nearly $134.6 million/y. If. however, the “adjusted mean mercury effluent concentration” is considered to be a quasi-composite sample, and 3.0 p g / L is the mercury effluent standard, then only one discharger must treat. Treatment costs for the sole discharger would be $377 OOO/y. This represents a 99.7% decrease in mercury treatment costs, as compared to costs incurred by retention of the 0.5 p g / L mercury effluent standard. Thus, as can be seen, the change of the mercury effluent standard from 0.5 to 3.0 p g / L would be a great help to the municipal sewage treatment plants. Educational institutions Also in Table I , it is indicated that seven educational institutions were in violation of the present 0.5 p g / L mercury effluent standard based on the “adjusted mean mercury effluent concentration.” Most of the responsible individuals interviewed surmised that any mercury in their effluent would emanate from the science or chemistry labs. None of those surveyed had any ongoing testing or analysis for mercury in their effluents, nor did they have the facilities or equipment for conducting such a test. Four of the seven educational institutions indicated that no special care was taken to eliminate mercury or mercury compounds from their laboratory drains. However, representatives of three of the seven educational institutions explained that in their science laboratories, collection containers were placed around the lab for the collection of mercury and silver compounds, with ultimate disposal to the sanitary landfill. Two of the seven institutions had laboratory drains which entercd dilution chambers beneath the laboratories. None had ever been cleaned. Also, none of the institutions conducted periodic inspections of the sink traps to look for mercury, and two institutions indicated their greatest source of mercury in the laboratory came from broken thermometers . In the two possible cases dictating niercu r y treat men t : 658
Environmental Science & Technology
cational institutions would be $724 000, which would represent a 66-67% decrease in mercury treatment costs when compared to the costs incurred by retaining the 0.5 p g / L mercury effluent standard. The two institutions requiring mercury treatment, in this case, could greatly reduce the amount of mercury in their effluents by starting a vigorous program of mercury control in the laboratory. It was found that if mercury treatment is required at the institutions, the treatment costs would vary from 1.7-8.2% of their fiscal 1976-77 budget, depending on the institution.
If the “adjusted mean mercury effluent concentration” is taken as a quasi-composite sample, and the 0.5 p g / L mercury effluent standard is retained, then six of the seven educational institutions would have to treat for mercury at a cost of $2.183 million/y. If, however, the “adjusted mean mercury effluent concentration” is accepted as a quasi-composite sample, and the mercury effluent standard is relaxed to 3.0 p g / L , only two of the seven educational institutions would have to treat for mercury. Mercury treatment costs incurred by the edu-
Miscellaneous dischargers There were three dischargers of mercury in this category whose “adjusted mean mercury effluent concentration’’ exceeded the present 0.5-pglL mercury effluent standard. The Corps of Engineers has two small activated sludge plants, of 20 000 and 40 000 gpd capacity, located at Rend Lake. Both plants are in operation during peak usage periods, and only the 20 000-gpd plant is operated during the winter months. There are no known sources of mercury in the influent flow. The Illinois Masonic Home has two plants in operation. One is a Walker process-activated sludge unit combined with an existing trickling filter which now has a non-mercury seal. There are no known sources of mercury. The Vandalia Correction Center is served by a trickling filter with a mercury seal. The seal leaks, and mercury must be added from time to time. Other than this known source of mercury, there are no others. For the two possible cases dictating mercury treatment: I f the “adjusted mean mercury effluent concentration” is taken as a quasi-composite sample, and the 0.5 p g / L mercury effluent standard is retained, then two of the three dischargers would have to treat at a cost of $465 800/y. If the “adjusted mean mercury effluent concentration” is accepted as a quasi-composite sample, and the mercury effluent standard is relaxed to 3.0 p g / L , all dischargers would be relieved of mercury treatment costs. I n Table 1 is also shown the total of statewide mercury treatment costs for all dischargers in the two possible cases dictating treatment. I f the “adjusted mean mercury concentration” is used as a quasi-composite sample, then changing the mercury effluent standard from 0.5 to 3.0 p g / L decreases the statewide mercury treatment costs
TABLE 2
Probable actions of dischargers having the option of closing all or part of their plants Approximate 1976-77 Of payroll employees ($ milllons/y) Number
Company A
540
5.5
Company B Company C Company D
182 155 530
3.5 2.3 10
Company E
1350
Illinois Masonic Home
24
165
from $166.1 million/y to $1.83 million/y. This represents a 98.9% decrease in mercury treatment costs.
Non-industry options I n addition to the statewide cost savings realized for mercury treatment by changing the mercury effluent standard from 0.5 to 3.0 y g / L , there are other considerations. Some dischargers have, as a viable alternative to mercury treatment, the liberty of closing all or part of the plant. The educational institutions' costs for mercury treatment varied, at worst, from 1.7-8.2% of their 1977 budgets. With inflation in excess of 6% per annum, and energy costs increasing even faster, it is unlikely any of the educational institutions would close their doors in lieu of treatment for mercury, regardless of where the effluent standard is set, within the range of 0.5 to 3.0 p g / L . Therefore a loss of jobs a t these institutions caused by changing mercury effluent standards is highly improbable. The municipal sewage treatment plants are rather unique in that the services they provide must be provided, and it would be infeasible to close them. It does not matter what the treatment costs are or where the mercury effluent standard is set; these plants must operate. It was pointed out by Patterson, and by representatives of the Chicago Metropolitan Sanitary District at earlier hearings on mercury, that because of large flow volumes, there is no known economically feasible method of mercury removal from municipal sewage treatment plants. During the course of this investigation, the authors have not found any evidence contrary to those findings. Therefore, it is assumed that there is
Mercury treatment costs based on adj. mean mercury concn. ($lOOO/y) 0.5 pg/L 3.0 pg/L
10 472 104.7 13.5 53.8 18 251 171.4
Mercury treatment costs as YO of F Y '76-'77 budget
0
Not available
0 0 0
0.9 0.1
733
0
Mercury treatment Probably action costs as YO if mercury of '76 corporate effluent stds net proflts not changed from (after taxes) 0.5 to 3.0 pg/L ($
Not available Not available 5
no potential for loss ofjobs at the municipal sewage treatment plants. The miscellaneous dischargers had three installations for study: the U S . Corps of Engineers' Rend Lake Facility, the Vandalia Correction Center, and the Illinois Masonic Home. Because of the nature of the first two facilities, it is unlikely that they would close if treatment for compliance at the 0.5 y g / L level were required. However, closure is a distinct possibility in the case of the Illinois Masonic Home.
Industry options Faced with an increase in cost in treating wastewater, each industry must reassess its competitive position within the industry. I f the added cost is appreciable, a detailed study of alternatives would be the normal course of action. Alternatives might include, among other things, closing all or part of the plant, changing product mix, study of alternative treatment methods, or programs of legal delays to gain time. The detailed study would involve a number of items of a proprietary nature. Without knowledge of these proprietary items, it is impossible, in this study, to predict with accuracy which alternative company directors would choose. Table 2 indicates those dischargers that do have as a viable option the closing of all or part of their plant. I f this option is exercised in lieu of effluent mercury treatment, there is a potential loss of jobs and an economic impact on the surrounding area. Of those dischargers shown, it appears that few would close their plants, since mercury treatment costs represent 0.1-5% of their fiscal year
184
Close plant
0.04
None None None
0.2
Variable
-
None
Payroll loss to area milllon/y)
5.5
Variable 0-24
1976-77 budget. This evaluation assumes that the standard is not changed from 0.5 to 3.0 y g / L . I f the mercury effluent standards are not changed from 0.5 to 3.0 p g / L , Company D would likewise not close, since its mercury treatment costs of $53 SOO/y represent only 0.04% of its 1976 corporate net profits; $53 800 also represents only 0.5% of the firm's 1976-77 payroll. It appears that Company A would most likely close its plant if the standard is not changed to 3.0 y g / L , since its mercury treatment costs would represent 184% of its 1976 corporate net profits after taxes. I f this occurs, 540 employees would be out of work, and there would be a loss of a $5.5million/y payroll in the area. That loss would be extremely unfortunate; since this particular area is one of the most economically depressed in the state. For Company E, the difference in treatment costs at the 0.5 y g / L mercury effluent standard, as compared to the proposed 3.0 y g / L standard, is more than $17.5 million/y. This represents 62.6% of the 1976-77 payroll. It is possible that the plant would shut down if the effluent standard is not changed, but it probably would not do so in its entirety. Presently, Company E produces approximately half of its needs for chlorine and caustic in-house by its mercury cell chlor-alkali process. The remainder of the chlorine and caustic that the company needs is purchased elsewhere, and this purchasing could possibly be expanded to fill all needs. If this option were exercised, and the chlor-alkali plant were closed, the area could lose 0-1350 jobs, and $0-24 million in payroll. The chlor-alkali plant is the producer of raw materials Volume 13, Number 6, June 1979
659
TABLE 3
Summary of benefits for all sectors from changing the mercury effluent standard from 0.5 pg/L to 3.0 pg/L Sector
Cost savings
Industry Municipal wastewater Educational Miscellaneous
$172 000 to $17 690 000
Total benefits per year
$134 191 000 $1 459 500 465 800 $153 806 300 to $136288300 cost savings
Benefits (for year) Jobs saved
540 to 1890
Payroll saved
$5 500 000 to $29 500 000
-
-
-
540 to 1890 jobs retained
$5 500 000 to $29 500 000 payroll retained
N.B. The higher cost savings would occur in coincidence with the lower job and payroll figures, and vice versa.
(mainly chlorine, caustic, and hydrogen) for some 70 product lines in Company E. Therefore it is very difficult, if not impossible to assess realistically what the economic impact of closing the chlor-alkali facility would have within the plant proper, and the area. Cost savings from not having to treat wastewaters, because of change of the mercury effluent standards from 0.5 to 3.0 p g / L , can be considered as benefits. A summary of benefits to all sectors is displayed in Table 3. Increasing the mercury effluent standard from 0.5 to 3.0 p g / L would result in a cost saving of $1 36.3- 153.8 million; retention of 540-1890 jobs, and of $5.5-29.5 million/y in payroll in one particularly depressed area.
Environmental benefits and costs Some forms of mercury are very toxic to humans and other life forms. Historically, however, even when mercury effluent concentrations were higher, there were no recorded instances of mercury toxicity to humans in Illinois, attributable to mercury in effluents. I n Japan, 151 cases of mercury toxicity were recorded in the late 196O's, which resulted in 51 deaths. These were attributable to the discharge of mercury from two industries, the biomagnification of mercury in the aquatic food chain. and the ultimate consumption, by the victims; of large quantities of fish and seafood over a long period. Mercury is a neurological toxin and is a suspected cause of chromosomal aberrations. However, at the levels extant in Illinois, and at those projected under the proposed change, the potential health impact is negligible. It should be borne in mind that mercury is ubiquitous, usually at very low concentrations. In aquatic systems, there is a strong natural tendency to maintain low concentrations in solu660
Environmental Science & Technology
tion through mercury vaporization, and through adsorption on benthic or suspended solids, especially soil and organic particulate matter. I f this fact is taken into consideration, together with the IEPA sampling data, one concludes that the effect on the natural environment, of granting the proposed change in effluent standard, is negligible. Although the proposed change increases the allowable discharge by a factor of six, there are only a few effluent stations that are likely to increase the mass of mercury discharged annually, or even in any short time period. The effect on the environment is further mitigated by the non-linear relationship between the mercury concentration and the quantity of mercury situated in any component of the aquatic food chain. Consequently. the marginal effect is quite small.
Economic benefits Compliance with the existing rule or the proposed rule will require some institutions to treat by means of the best available technology: ion exchange. The state-of-the-art is such that consistent reduction of mercury effluent concentration to a level of 0.5 p g / L cannot be achieved with ion exchange, under all conditions. However, attempting to achieve the existing standard will require considerably higher treatment costs than those of achieving compliance with the proposed standard. The difference between the two cost figures represents a benefit. This benefit accrues from payrolls and jobs saved, and from reduced treatment capital and operating costs, as previously explained. Thus, compliance with the proposed cffluent standard will result i n some general environmental improvement over the status quo. It will also result in significant benefits to industry, educational institutions, municipal
wastewater treatment districts, and the people of Illinois through reduced costs required for compliance with the existing standard.
Additional reading The Environment in Illinois, Enciron. Sci. 7echnol., 7 (3). 192-196 (1973). Patterson, J . W., Technolog), and Econot?iics of Industrial Pollution Ahatenient. Illinois Institute for Environmental Quality Document No. 76/22, pp 319-331, 1976. Cook, E. E., Rogers, C. L., Economic Impact of Proposed Amendments to Mercury Effluent Standards in Illinois, IlEQ Docurncnt No. 77/33, 1977.
Echo1 E. Cook is an assistant profkssor of therr?ial and encironmental engineering at Southern Illinois Unicersitj,. H e has published papers, taught, and held industrial positions i n the w t e r pollution cwntrolfiPld. Lee Rogers ( I ) is an assistant proj'essor at Soirrhern Illinois Unirersitj~at Carbondale. H e has done research projects in mercurj' rffluent standards, and in strip i?iine lalid benefit cost systems. John H. Yopp (r) is in Southern Illinois L'tiii.ersitj''s botany department. He has hwn h d i i n g in thefi'rld.7 of encironniental tj>ct.~ on plant nietabolisni and niorphogencsi.c. and plant phj*siologj. Yopp also hris presented nunierous papers, and run N nutiiher of research projects. Coordinated by J.I
