----- Forwarded Message ---From: Linda Jo Schierow <LSCHIEROW@crs.loc.gov> To: Randall <randalltmoore@sbcglobal.

net> Sent: Tue, August 10, 2010 9:02:19 AM Subject: Re: question Dear Mr. Moore, Thank you for the information. I have filed it away in case I ever need it. However, because I work for the U.S. Congress, my work is confidential, and I am very busy, please do not contact me again, unless it is through a congressional office. Thank you. Have a great day. Linda Schierow ----- Forwarded Message ---From: Randall <randalltmoore@sbcglobal.net> To: lschierow@crs.loc.gov Sent: Sun, July 25, 2010 2:50:13 AM Subject: Methylmercury Hi Linda I've read several of your terrific Congressional Research Reports and I've been quite impressed. I have a fascination of mercury, so I read with great interest the 2006 report, Mercury in the Environment - Sources and Health Risks. While I found the report very interesting there seemed to be one huge source of anthropogenic mercury left out of your analysis. That of dental mercury. I thought, considering your position, you'd be open to the following information, much of which has been ascertained over the last decade. Dental Mercury in Waste water

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Dental mercury waste is the largest source (up to 50%) of mercury pollution into our nation’s wastewater. The uncaptured waste from placing and removing amalgam, goes down the drain equaling approximately 9 tons a year. Mercury from human excrement also contributes to mercury in wastewater. Mercury vapor released by amalgams is absorbed by the body and a percentage is excreted through body waste. The mercury from dental offices goes into the wastewater, then to local Publicly Owned Treatment Works (POTW) or sewage treatment plant. It is important to note that most of the mercury is removed at the POTW into the sewage sludge which is then applied to the land, incinerated or landfilled. The rest of the mercury leaves the POTW in the effluent discharged to surface waters.

Dental offices discharging waste water to septic systems also have the potential to contaminate surrounding soils and groundwater, including wells.

Dental Mercury in the Air • Waste Incineration: On average, 20% of sewage sludge is incinerated of which 60% of the mercury content is estimated to be emitted to the atmosphere, equaling about 2 tons. Mercury is also captured in the incinerator stack scrubbers, which is then released back into the waste water, deposited in a landfill or sent to a waste water treatment plant. • Land Fill & Fertilizer: Approximately 800,000 acres of land are applied with municipal sewage sludge as fill and fertilizer which release 15-18 pounds of mercury per day into the atmosphere, especially during the warm summer months. Mercury sent to a landfill may contaminate underlying soils and enter groundwater. These releases, as well as smaller releases from sludge disposed to landfills amount to 0.8 tons per year released into the atmosphere just from the application of sewage sludge to land, assuming about 50% of the contribution is due to dental mercury.

Cremation: Mercury vapor from amalgam fillings are released when people are cremated. 2010 estimates for mercury released from crematoria is 3.5 tons. Data provided by the Cremation Association of North America (CANA) estimates that there will be a 14% increase in cremations by 2020 with approximately 1,456,040 cremations.

Direct Air Releases from Dental Clinics: The continuing placement and removal of dental amalgam contributes as much as 1 ton of mercury to the atmosphere annually.

Studies also show high levels of mercury accumulate in sewer pipes from dental offices, presenting potential liability concerns. Following years of use, the plumbing in dental offices and associated sewer pipes can acquire a significant buildup of dental mercury. This mercury often slowly dissolves and continues to be released into the waste water stream (and dental office) for years – even after amalgam separators are installed – unless pipes are replaced or cleaned out. EPA has not developed estimated emissions for several sources, including: dental mercury in sludge that is landfilled, spread on agricultural or forest land, or that is dried before it is used as fertilizer, in infectious and hazardous waste, in generalmunicipal waste, in human respiration, or removed as grit and fines at waste water treatment plants and disposed of in a number of ways, including septic systems and in combined sewer overflows. Factoring in other amalgam air pathways that EPA left out and based on new research, mercury policy project's estimates that atmospheric emissions from dental mercury could be more than six times the 2002 EPA estimate, due primarily to increasing emissions from cremation. The EPA released a report in 1999 titled "Mercury Study Report to Congress" which estimated that anthropomorphic (human caused) emissions of mercury in the U.S. totals 118 tons. At the time the EPA researchers completely failed to account for all sources of dental mercury which contributes roughly 9.4 tons (estimated by Mercury Policy Project) making the dental sector the 4th largest contributor of mercury to our atmosphere, bringing the total mercury emissions to 127.4 tons. Securing accurate estimates of dental mercury air releases is important because the record clearly indicates that the EPA prioritizes its activities based in part on the amount of mercury released from a particular industry sector to the atmosphere. Yet the EPA continues to significantly underestimate the amount of air pollution that dental mercury accounts for, thereby rendering this problem a lower priority in the agency’s comprehensive mercury reduction strategy. Environmental concerns from dental mercury has been well documented with 5 congressional subcommittee hearings on the subject in 2003, 2007, July 2008, October 2008 and 2010. You might also be interested to learn... The EPA allowed the ADA to strip local water treatment plants of their authority to regulate their water • The EPA's Clean Water Act (CWA) designates authority to the local Publicly Owned Treatment Works (POTW) to regulate wastewater discharges to the sewerage system from industrial, commercial and government facilities and to protect receiving waters. The ADA, working through local legislators in Michigan, passed legislation which stripped authority from the local POTW to protect the environment. In other words the local POTW could not take actions beyond requiring amalgam separators even where mercury from dental facilities was causing a direct environmental impact. Two years after the State passed this law, EPA has told them it is in conflict with the Clean Water Act but EPA has not required any action by the State to fix this Law. The EPA allowed ADA to derail national implementation of mandatory amalgam separator technology.

During the last days of the Bush Administration the ADA signed a memorandum of understanding with the EPA, which was designed to allow voluntary installations of amalgam separators even where mercury problems would dictate a mandatory program was needed. The problem with this midnight deal is that it continues to allow significant and preventable mercury pollution releases to the air and water. The deal was based on faulty information from the ADA, left the ADA in charge of developing baseline data before goals could be set, is designed to delay installation of amalgam separators, lacks openness, transparency and follow through by EPA. Voluntary educational outreach program might be justified for a minimal pollution source, but is clearly not adequate for the significant source of mercury pollution from dental amalgam especially when the treatment technology to remove the mercury is widely available and inexpensive.

Linda, I appreciate you looking this information over. I'd be interested in hearing your thoughts. Thanks in advance Randall Moore