1. Mercury TMDL Implementation Plan Progress Report
By Rebecca Place, MPCA
October 26, 2016

2. History highlights April 19, 1994 MPCA memo: Mercury TMDL in the metro
“it will be the first outright multi- source TMDL or “phased” TMDL for a toxic pollutant that we have attempted. It will be involved and complex, and probably take a number of years and considerable planning.”
- Gary Kimball, Water Assessment and Planning section
Reasons why MPCA staff wanted a mercury TMDL be considered:
Increased availability of low level water monitoring techniques and availability of fish monitoring data.
1989 mercury concentrations appeared to exceed our water quality standards in the Minnesota River
And the fish tissue data supported it
There were many people to bring to the table and create a shared vision in order for this TMDL to be successful.
13 years later the TMDL study was complete and approved by the EPA.

3. Year 1989 (27 years ago)
We are hear today because we are leaders here in Minnesota. We knew what had to be done and we were willing to start while expecting others to follow.
Mercury Research in Minnesota conference OVER 20 Years Ago. (1993 and 1995)
“Mercury controls at Herc (Covanta waste incinerator) will be ONE the FIRST of it’s kind in the US. “
We have been researching, cataloging mercury air emissions and reducing mercury discharges and for a long time.
At this time in 1989:
There is already fish consumption advice from MDH restricting number of meals of fish upstream from the metro area.
1989/1990 MPCA began putting Water quality based effluent limitations in permits for mercury.
Research was able to establish of a background concentration to be used in subsequent permits.

4. Mercury is a bioaccumulative toxin
Year 2004
1,239 impairments for mercury
Year 2016
1,670 impairments for mercury
78 new water bodies listed this year
Mercury bioaccumulates in the environment. It occurs naturally AND is emitted from man made sources all over the world, comes down with rain from the atmosphere, converts to methyl mercury within water and then is taken up by micro-organisms. Bruce has a slide showing the exposure pathway
2/3 of the lakes monitored are impaired for mercury
As I said there have been fish consumption advisories for a long time. Currently Children under the age of 15 are limited to one Walleye or northern a month
(99%)Pollution is coming from the air
90% is coming from outside Minnesota , Minnesota’s mercury emissions are going elsewhere, it is a national and global problem.
*TMDL (Total Maximum Daily Load) study is a tool to bring a body of water back into compliance with clean water standards.
The statewide mercury TMDL is unique because it uses a water tool to fix an air emissions problem.
Minnesota has 14,000 lakes and 92,000 river and stream miles

5. What must a TMDL Study include?
LA(s) + WLA(s) + Margin of Safety + Reserve Capacity = Total Maximum Daily Load Where: LA = Load allocations from nonpoint sources WLA = Waste load allocations from point sources Margin of Safety = to account for potential scientific error Reserve capacity = set aside for future development
Assess Waters for impairments
Complete pollutant load allocation calculations
Develop restoration strategy
Submit to EPA for Approval
Develop Implementation Plan
Now I have 3 slides on the basics of our mercury TMDL
A public participation plan to ensure engagement, collaboration, success
An assessment of what’s causing impairment (may include biological, chemical, habitat, flow, etc.)
A technical analysis of existing pollutant loads from point and nonpoint sources
Taking into consideration that there will be future pollution
PUBLIC PROCESS

6. Hg TMDL Creates No New Regulatory Authority
Water Point Sources addressed in Water Quality Permits
Air Emission Sources as Non-Point Sources agree to meet commitments, without new permit authority
Stakeholder Group
TMDLs in general do not create additional authority
The distinction with the statewide Hg TMDL is that air emissions are included and emission reduction goals have been set.
Up until 2009 when the implementation plan was complete mercury reductions had been mostly voluntary. Other than policies directed towards electric utilities
One Year of relying on stakeholder involvement is typical in TMDL Implementation planning in order to develop a comprehensive reduction strategy.
stakeholder-recommended strategies to meet TMDL goals
Two-tiered stakeholder engagement
group of 17 met almost every three weeks for one year
all known stakeholders invited to attend two input sessions and comment on drafts.

7. Main Objectives of the Implementation Plan
Water – Total Point Source Discharge Goal remains below 24 lb/yr
Air - Strategies for meeting MN share of air emission goal (789 lb/yr)
Approximately 76% reduction in air emissions from 2005 levels
Sector targets and timeframes
How to address new air sources
Acknowledgement that Hg emissions would fluctuate through 2025
Approved in 2007! By the Federal EPA
The TMDL documented the linear relationship between mercury air emissions and mercury contamination in fish tissue.
Goal were set at 24 lb per year for water discharges and 789 lbs for air emission releases
Stakeholders helped develop guidance for new emission sources
Update: We met in 2012 and this past year to hear stakeholder input on the new and modified source guidance.
From that process MPCA has agreed that the next time a project is proposed to which the guidance applies, the oversight committee will be invited to provide input.   (The guidance has not been used since 2013.) 

8. Statewide Wastewater Mercury Trends
Strategy to keep point-source discharges below 24 lb/yr
Current discharges 15 lb, allowing 9 lb for growth
Specifies process for distributing “unallocated load”
Lake Superior – Great Lakes Initiative 1.3ng/L
Variances
Must show bench scale testing verifying infeasibility
Most of the strategies and the time we spent as a group dealt with meeting the air reduction goals.

9. MN Hg Rule Annual reporting if “mercury emission source”
Defines a mercury emission source
Actual Hg emissions of 3 lbs a year or more
Hg emissions inventory reporting and testing
Reduction plans for some sources
Incorporate federal performance standards for mercury
Up until this point many reductions were voluntary and the TMDL did not create authority.
Another milestone is the mercury rule
The rule requires Annual reporting for “mercury emission source”. Started in 2015
Annual reporting if “mercury emission source”
Smaller sources on 3-year cycle
Baseline and periodic testing if “mercury emission source”
If no other requirement for test or CEMs

10. Mercury reduction plans
Industrial Sector
Reduction Required
Plan Due
Reduction Due
Metal Melting *
June 2015
2018
Industrial Boilers gt 5 lbs
70%
Other Sources
2025
Ferrous Mining
72%
December 2018
Many facilities with plans due in June 2015 conducted testing to improve emission factors
Result: Lower mercury emission estimates within all sectors.
Reflected in 2014 statewide emissions inventory
Performance test results submitted for MPCA review
We thought there would be 17 providing reports by June 2015.
Re- evaluated, switch fuel sources and processes, some performed a stack text to provide the EPA emission factor was too high. Only 2 facilities had to submit plans.
* Rule proposed an emissions rate of 35mg/ton of metal melted; comparable to a reduction of about 50% from today’s emissions rate.

11. MPCA Mercury Emission Categories
Energy Production
Material Processing
Purposeful Use
Coal
Taconite processing
Volatilization: solid waste
Petroleum refining
Mineral Products (lime)
Burn barrels
Petroleum product use
Thermal treatment of soil
Spills of liquid mercury
Wood combustion
Landfill volatilization
Natural gas
Land application of MSW compost
Asphalt manufacturing
Land application of sludge
Agriculture, food
Shredders of cars/appliances
Wood, pulp, & paper
Arc furnace melting of Fe scrap
Lamp recyclers
Non-ferrous metal recycling (Al, Pb)
Dental preparations
Cremation
Municipal solid waste incineration
Sludge incineration
Medical waste incineration
Hazardous waste incineration
Industrial incineration
Mercury product manufacturing
This how we categorize the MN mercury emissions inventory

12. 2015 Draft Distribution between sectors
Total mercury air emissions lb
Reductions in Energy Sector:
Mercury Reduction Rule – required 90% reduction
Mercury Air Toxics Standard
Minnesota Legislature required large electric generating units to figure out how to reduce mercury by 90% starting in Again, this is nation-leading; many states and utilities admire the partnership represented by this statute between the state, environmental groups, and the utilities.
Emissions from Electric Utilities are down 3,314 in 2005 to in 2015
Minnesota DNR and MPCA helped secure $1.5 million in grant money from EPA to being field-level research at taconite facilities to control their mercury. Studies are now being finished, and are demonstrating that mercury controls are available.
Bans on mercury in products – batteries, toys, games, apparel, thermostats
Disposal and management requirement – disposal banned in solid waste
Lamps required to be recycled
We’ll discuss reductions when we go through the emissions inventory

13. Xcel Energy high bridge smokestack demolition

16. Statewide mercury tmdls
Minnesota (March 2007)
Northeast Regional—Connecticut, Maine, Massachusetts, New York, New Hampshire, Rhode Island, Vermont (December 2007)
New Jersey (June 2010)
North Carolina (October 2012)
Florida (October 2013)
Michigan (2013)
“Minnesota is doing it’s part expecting other states and nations will do the same”
These states have completed Mercury TMDLS

17. More Information MPCA Website Mercury TMDL Implementation Plan
Mercury TMDL Implementation Plan
Rebecca Place, Mercury Coordinator
These slides will be on line

18. USEPA Mercury Emission Categories
AREA
POINT
Combustion
Manufacturing
Miscellaneous
Electric lamp breakage
Utility Boilers
Chlor-alkali production
Oil shale retorting
Paints use
Commercial/industrial boilers
Lime manufacturing
Mercury catalysts
Laboratory use
Residential boilers
Mercury production
Pigment production
Dental Preparations
Municipal waste combustors
Battery production
Explosives manufacturing
Mobile sources
Medical waste incinerators
Electrical apparatus production
Geothermal power plants
Agricultural burning
Sewage sludge incinerators
Byproduct coke production
Turf products
Landfills
Hazardous waste combustors
Primary copper smelting
Sludge application
Wood-fired boilers
Primary lead smelting
Residential woodstoves
Petroleum refining
Crematories
Instrument manufacturing
Zinc mining
Fluorescent lamp recycling
Pulp and paper mills
From: Mercury Study Report to Congress. USEPA (Table ES-1)

19. MPCA Mercury Emission Categories
Energy Production
Material Processing
Purposeful Use
Coal
Taconite processing
Volatilization: solid waste
Petroleum refining
Mineral Products (lime)
Burn barrels
Petroleum product use
Thermal treatment of soil
Spills of liquid mercury
Wood combustion
Landfill volatilization
Natural gas
Land application of MSW compost
Asphalt manufacturing
Land application of sludge
Agriculture, food
Shredders of cars/appliances
Wood, pulp, & paper
Arc furnace melting of Fe scrap
Lamp recyclers
Non-ferrous metal recycling (Al, Pb)
Dental preparations
Cremation
Municipal solid waste incineration
Sludge incineration
Medical waste incineration
Hazardous waste incineration
Industrial incineration
Mercury product manufacturing

20. USEPA Mercury Emission Categories
AREA
POINT
Combustion
Manufacturing
Miscellaneous
Electric lamp breakage
Utility Boilers
Chlor-alkali production
Oil shale retorting
Paints use
Commercial/industrial boilers
Lime manufacturing
Mercury catalysts
Laboratory use
Residential boilers
Mercury production
Pigment production
Dental Preparations
Municipal waste combustors
Battery production
Explosives manufacturing
Mobile sources
Medical waste incinerators
Electrical apparatus production
Geothermal power plants
Agricultural burning
Sewage sludge incinerators
Byproduct coke production
Turf products
Landfills
Hazardous waste combustors
Primary copper smelting
Sludge application
Wood-fired boilers
Primary lead smelting
Residential woodstoves
Petroleum refining
Crematories
Instrument manufacturing
Zinc mining
Fluorescent lamp recycling
Pulp and paper mills
From: Mercury Study Report to Congress. USEPA (Table ES-1)