Mercury Storage and Packaging in Hawthorne Amy Depot Essay

Background

When federal environmental assessments are performed early in the planning phase of an agency, they can aid in ascertaining that environmental issues, as well as social and economic issues, are incorporated into decision-making. According to Gibbons, since environmental risks are also hazardous to the financial capability and social suitability of the agency, environmental assessments, whether mandated by law or not, are now regarded as excellent business practices (3). At Hawthorne Amy Depot, the Defense Logistics Agency Strategic Materials (DLA) is charged with the responsibility of ensuring “secure, safe, and environmentally friendly management especially in a stockpile of mercury” (DLA iii). According to DLA, the consolidation of stockpiles of mercury at Hawthorne Army Deport resulted from a decision of the Defense Logistics Agency. This stockpile contains about 4,890 tons of mercury. This mercury is put in drums that are placed on drip pans, which are later placed on pallets.

The mercury is then put into flasks that are then stored in drums that carry the flask. Surprisingly, the current packaging of mercury at Hawthorne Amy Depot has lasted for years now with no one with an idea of any leakages and or wearing and tearing of the drums. Therefore, environmental assessments are necessary to carry out in agencies in which the federal government is concerned under precise circumstances illustrated in the act. If any of these legislative requirements are absent, there is no power to carry out an environmental assessment even in what may otherwise be considered as undeniable circumstances. As the paper reveals, there is a need for an environmental assessment concerning mercury storage at Hawthorne Amy Depot. The paper presents the assessment together with its underlying triggers. Following the evident consequences of such triggers in Hawthorne Amy Depot, the paper suggests the possible purposed actions required to minimize the emissions besides presenting appropriate alternative measures that should be adopted by the environmental protection agency to ensure that the emissions are managed. However, it will give the scope of the problem of mercury storage and packaging in Hawthorne Amy Depot.

Scope of the Problem

Mercury emission is one area that has raised concern not only at Hawthorne Amy Depot but also among people in general. The environmental and social impacts relating to these emissions are the main reasons for the relentless efforts to eradicate further emissions (Heinzerling and Steinzor 2). Mercury is one of the heaviest and most toxic metals that have adverse effects on the environment. The reason for its extraordinary toxicity is that it breaks easily into harmful substances that are detrimental to the health of living organisms, man included. The most toxic form of mercury is denoted as MeHg whose effect is evident when it mixes with microorganisms in water and soil.

Environmental Assessment

The Defense Logistics Agency (DLA) is one of the key agencies that are involved in controlling mercury emissions and or any hazard associated with mercury at Hawthorne Amy Depot. The current packaging of mercury at this depot is raising questions based on the length of time it has lasted without assessing the status of the packaging drums. There is a need to

Put in place legal frameworks to prohibit any poor storage of mercury not only at Hawthorne Amy Depot but also in any other place or depot. This entails creating specific laws aimed at ensuring that organizations/depots that store mercury as raw materials partly or wholly are tried in a court of law on allegation of improper storage, packaging, and or treatment of mercury.

• Empower environmental protection agencies to give operation licenses to organizations seeking to use mercury as part of raw materials or organization that produce mercury contaminated industrial wastes. As a criterion for issuing the licenses, environmental assessment of the impacts of operation of such organizations is critical. Therefore, in Hawthorne Amy Depot, the Defense logistics Agency (DLA) strategic Materials will need to be accorded the following mandates:
• Get involved in the implementation of environmental assessment of mercury storage and packaging
• Ensure that the general environment is clean and free of mercury pollutants
• Come up with standards for acceptable and up-to-date mercury storage containers. The agency should also have the power to enforce compliance to these set standards by ensuring that laws and regulations concerning environmental conservation are adhered to.
• Make it the responsibility of Environmental Protection Agency to stress on proper mercury storage as per various federal environment statues that concern Clean Air Act, Resource Conservation and Recovery Act, and Clean Water Act among many others.
• Conduct environmental assessment on mercury storage containers upon imposition of the mercury packaging regulation standards at Hawthorne Amy Depot. The objective for the assessments is to scrutinize whether the proposed actions will offer solutions. Based on the results of the assessments, the laws that are established to ensure that the environment is kept clean will be assessed and reviewed in case they do not fulfill the requirements set.
• Review the application of Mercury Export Ban Act of 2008. This step is necessary in a bid to stress on the urgency of renewing mercury storage containers at Hawthorne Amy Depot
• The act has requirements that concern “the exportation of mercury and the long-term mercury storage and management” (Heinzerling and Steinzor 8). The act is aimed at reducing the amount of mercury leaking to the environment because of poor and old storage containers.

Triggers of Environmental Assessment

Several things trigger the need for environmental assessment concerning mercury storage and packaging at Hawthorne Amy Depot. Firstly, The Defense logistics Agency (DLA) Strategic Material at Hawthorne Amy Depot reported that its current mercury storage containers are very old. Another trigger is that some of the flasks that contain mercury contents may have spilled their contents into their drums especially during the process of transportation. In addition, according to DLA, evaluating and dealing with this situation will fulfill the arrangement terms with “Nevada as a state, Bureau of air pollution control, and Division of Environmental Protection” (DLA iii). In addition, mercury is one of the persistent metals that circulate and re-circulate from air, soil, and water and back without losing its level of intoxication. This makes it produce global mercury cycles, which are the amounts of mercury that circulate in the environment of the world at any particular time. High exposure to mercury has adverse effects on the health of people. It mostly affects those people who are exposed to it, mostly unborn and young children.

The metal MeHg is transmitted to human beings through feeding of foods such as fish. Therefore, the substance mostly affects people when they are exposed to such foods. They take mercury in their body systems leading to health complications (Heinzerling and Steinzor 2).The effects of the disease include cerebral palsy, mental redundancy, deafness, and blindness (Heinzerling and Steinzor 8). Adult persons are also at a risk if they are exposed to mercury contents. They suffer from less severe ailments or and motor impairments. If the affected persons are exposed to low dosage, they are at the risk of developing more subtle neurotic effects, which may include poor performance on neurobehavioral, language development, visual impairment, fine motor function and others. Most recent studies have revealed that MeHg exposure can lead to severe causes of cardiovascular conditions (Heinzerling and Steinzor 9). Therefore, it is important that people diagnosed with these symptoms relating to mercury exposure feed on fish compared to meat. Because of the effects of the emissions on environment and social scale, various studies have been carried out to investigate how its emissions can be alleviated. Therefore, there is a need to assess mercury storage at Hawthorne Amy Depot.

Moreover, because of its nature, mercury has the potential of remaining in soil and water for a long time compared to other metals. Mercury is also emitted from natural sources. Nothing can be done to avoid this behavior. For instance, in the world, total air emissions that come from anthropogenic and natural sources average at 5500 tones in every year (Heinzerling and Steinzor 7). For instance, according to the environmental protection agency, in 1999, industrial sources emitted over 25 million tons of nitrogen oxide, 97 million tons of carbon dioxide, and 18 million tons of volatile organic compounds (Heinzerling and Steinzor 7). Even though, natural sources contribute to these emissions, there is growing evidence that manufactured or anthropogenic sources are the most dominant sources of mercury emissions. Scientists who have carried out studies on ice cores that were transported from the Upper Fremont Glacier in Wyoming estimate that for the last 100 years, 70 percent or around 3800 tons of worldwide mercury emissions are from fabricated or anthropogenic sources (Heinzerling and Steinzor 8). Of the total emissions, Hawthorne Amy Depot is also one of the contributors though with the least amount of emission. The Defense logistics Agency (DLA) strategic Material has estimated that a larger percentage of around 87% comes from leakages associated with poor and old storage containers such as those at Hawthorne Amy Depot. The leaked mercury has the capability of moving from far areas or regions (Heinzerling and Steinzor 7). Out of the amount of mercury found in America, 60% of the mercury deposition is from synthetic sources and not from anthropogenic sources. Hence, knowledge on the possible sources of mercury emissions is imperative to ensure that appropriate measures are adopted to curb its effects.

Purposed Action

• For the environment to be protected, it is important for laws and regulations to be enacted. These laws and regulations set the standards or threshold on the amount of toxins that needs to be emitted in the environment. These laws can only be set when the lawmakers are aware of the likely causes of mercury emissions. It also provides a guideline on how companies or countries can adapt the best practices to ensure that they protect the environment from such emissions and general pollution. In the United States, laws are set or made by the congress house. This indicates that the environmental laws that govern Hawthorne Amy Depot are also made here. Congress has the prerogative to authorize various government agencies to effect or implement certain laws to ensure that certain things or issues are met. Hence, reviewing the act has the potential of creating new improvement procedures for handling and safe exportation of mercury or customizing the current ones. Therefore, based on the condition at Hawthorne Amy Depot, there is need for the following actions to be done.
• DLA suggests to change the current small storage containers (3-Liter containers) to a one big container with a capacity of 1 metric ton. The action will give room for new and quality storage containers whose chances of leaking are low. The action has been found crucial since the storage containers that are currently used at Hawthorne Amy Depot are out of date. They were bought a long time ago (40 years ago). Secondly, the containers have been transported many times. Therefore, they have been exposed to a lot of wearing and tearing, which on the other hand raises the probabilities of leakages of the mercury, a case that DLA seeks to curb, as it is becoming a health hazard. Secondly, as DLA reveals, “performing this action would satisfy the terms of its agreement with the state of Nevada, Division of Environmental Protection, Bureau of Air Pollution Control, which allowed the consolidation of the mercury stockpile at HWAD conditioned upon progress being made toward constructing and operating a mercury repackaging facility” (iii).
• DLA will design quality assurance programs to include both compliance monitoring and quality control. In this endeavor, the Defense logistics Agency (DLA) strategic Material will produce various reports and proposals concerning environmental assessment. These reports will help in spreading awareness about the issues of environmental conservation. They will also help in educating the public on the need to ensure proper environmental conservation besides helping those who live in or near Hawthorne Amy Depot to avoid exposure to these mercury emissions.
• DLA will conduct environmental assessment to ensure that all areas in Hawthorne Amy Depot that require improvement are well taken care of such as storage issue. This has the impact of making sure that the amount of mercury leaking is reduced drastically. Mercury is mainly used in artisanal and the mining of gold especially in small-scale basis. The effects of mercury have continued to loom mostly affecting the health status of people who use it in mining.
• DLA will promote environmental conservation in Hawthorne Amy Depot through enactment of an appropriate act. Such an act should have three major necessities including:

1. 1. “Barring any federal state from conveying, selling, or distributing any elemental mercury that is under its custody or jurisdiction” (Heinzerling and Steinzor 9)
   2. Banning any “exportation of elemental mercury from the Hawthorne Amy Depot as from January 1, 2013” (Environmental Protection Agency) (EPA Para. 3)
   3. Providing guidelines for the department of energy to designate a place that will store any mercury that is manufactured inside Hawthorne Amy Depot: The act also needs to enhance the efforts for rechecking and phasing out old mercury storage containers. It should further provide the best approaches of discharging or disposing off used nickel cadmium batteries, small used sealed lead acid batteries, and other regulated batteries. This law will cover many stakeholders in the industry of production of batteries including “manufacturers, product importers and retailers, and waste battery handlers” (EPA Para 4).

Environmental Laws that Limit Mercury Exposures

One of the laws that set limits of mercury exposure is the clean water act. This act is aimed at regulating approximately 1889 air toxics or rather hazardous air pollutants. Mercury is one of the toxics that are under the air toxins. This legislation gives the Defense logistics Agency (DLA) Strategic Material authority to institute technology-oriented principles to regulate various generators of the harmful contents in the atmosphere. Manufacturers, for instance, are therefore “required to obtain operating permits to comply with all regulations and standards that have been set concerning their emissions” (EPA Para. 5). It also gives EPA powers to institute regulations in power plant emissions companies through the establishment of performance standards commonly known as maximum achievable control technology, MACT (EPA Para. 7). EPA issued the clean air mercury rule in 2005. Clean water act is yet another act aimed at ensuring environmental safety on mercury emissions. The act seeks to ensure that all water bodies are safe.

The law establishes the level of pollutants that need to be met such as mercury in order to protect the health of people who depend on water, as well as the living organisms that come from water such as fish and wildlife. No individual is permitted to discharge any toxins in water bodies unless that the individual has a permit authorizing him/her to do that. At Hawthorne Amy Depot, the Defense logistics Agency (DLA) strategic Material has the prerogative to ensure that water is free from any mercury toxins and to warn people to avoid using water that has been intoxicated with pollutions such as mercury (EPA Para. 9). They warn the public on using and eating fish or animals from water that has high levels of methyl mercury because it is harmful to their health. Resource conservation and recovery act is another law, which requires Hawthorne Amy Depot, to ensure proper management of hazardous wastes, mercury toxins included. The law has given EPA the authority to ensure that wastes or mercury toxins generated are well stored with proper storage avenues being used until the chemicals are treated and disposed.

The major aim of this act is to ensure that such chemicals are well disposed to avoid influencing negatively the environment and the health of persons. EPA has also come up with “treatment and recycling standards that require that all laws and regulations be met in the treatment until the point the chemicals are disposed” (Jackson 42368). Safe drinking water act is yet another law that seeks to ensure that the society accesses safe clean drinking water that is free from any mercury intoxication. EPA sets laws and standards relating to drinking water that relate to the public water systems. The act aims at minimizing the amounts of mercury besides other substances that tamper with the safety of drinking water. Pollution that arises from mercury emerges from “discharges that come from factories and refineries, erosion of natural deposits of mercury, runoff from landfills, and those that result from croplands” (Jackson 42369). In this case, Hawthorne Amy Depot is part of these emitters. Therefore, they enforce standards that drinking water needs to have.

Mercury Regulations and Standards

EPA has issued various regulations and standards that are required to be met to ensure that mercury emission and other dangerous toxins are not emitted to the environmental. This was the first Defense logistics Agency (DLA) strategic Material in Hawthorne Amy Depot, which concerned mercury pollutions that came from power plants (EPA Para. 12). This law aimed at protecting the families living near Hawthorne Amy Depot from exposure of mercury and toxic air pollution that emanated from power plant emissions. Other air pollutions include acid gas, arsenic, nickel, cyanide, and selenium among many other toxics. The standards aimed at slashing or reducing the emissions of dangerous pollutants from coal fired power plants and other sources of emissions such as municipal wastes. In 2009, EPA issued other standards that aimed at controlling emissions that came out of Portland cements plants. Other standards that had earlier been passed by EPA included those that aimed at curbing emissions that came from steel and iron foundries and many other areas (Heinzerling and Steinzor 8). The most recent regulations and standards that have been enacted by EPA were the significant new use rule that was under the toxic substances control act TSCA that was aimed at regulating the use of elemental mercury in manometers, barometers, psychrometers, and hydrometers.

The rule demanded that any company that wanted to “manufacture, import, or process elemental mercury for any use was to notify environmental protection agency” (Gibbons Para. 6) in advance to be granted permission to go ahead. EPA was to evaluate the intended use of the mercury besides limiting or prohibiting the use before any negative impact occurred (Collin 15). The final clean air mercury rule that was enacted in 2005 under the Bush administration has played a significant role in ensuring that the environment is conserved and or has improved the public health besides promoting the development of new technologies that are environmental friendly (Heinzerling and Steinzor 8). This act was aimed at curbing mercury emissions that emanated from coal-fired powered plants in a bid to cut down the rate of mercury emissions to 38 tons to achieve a 21-percent mark from that figure of 1999 (Heinzerling and Steinzor 8).

The Defense logistics Agency (DLA) strategic Material in Hawthorne Amy Depot assessed the most important and controversial environmental issue concerning mercury emissions. Furthermore, it was to formulate policies and procedures to install and operationalize this program in a bid to ensure that mercury emissions are regulated to avoid environmental effects. Before, the Defense logistics Agency (DLA) strategic Material in Hawthorne Amy Depot was required to issue its proposal on the regulation of mercury, it had suggested that mercury reduction could be reached by granting an industry the permission for a wide emission trading as opposed to planting specific pollutions controls that stirred mixed reactions from various parties concerned. The head of EPA was thought to have departed from the course and aims, which the agency was established in 1990 to execute. Because of these views, 11 states filed a lawsuit against the agency on what its chief assessor had affirmed. He had indicated that mercury-release parameters did not conform to the clean air act. Therefore, companies purported to be dealing with mercury emissions were to continue with their activities (Mercury Para. 1).

Alternatives

In case of failure of the purposed plan, other strategies for improving mercury storage can be put in place. Therefore, Hawthorne Amy Depot can:

• Continue storing mercury backlogs in the steel 3-L containers that already in place. Keeping them in six flasks for every steel container before they are transferred to the warehouses
• Employ a thorough and regular inspection of the containers for outflows and corrosions
• Ensure that the corroded containers are substituted and that all mercury outflows in the depot are washed up by experienced cleaners
• Carry out an everyday upkeep of the godown and the carbon dioxide fire extinguishers after review
• Put in place surveillance systems within the organizations whose operation involves handling of mercury and its associated products
• Use awareness conventions concerning the cumulative environmental risks of mercury pollution worldwide, as well as having follow-up programs for the environmental assessments agency’s imposed laws and regulations. Arguably, the follow-up programs already in place were meant to authenticate the precision of the agency’s environmental assessment. They were also to determine the efficiency of any actions taken to alleviate the unpleasant environmental effects by the agency without compromising on conservation of the environmental (Croitoru and Sarraf 146). Through the program, the agency would reach many people to educate them on the risks that mercury has to make them avoid being exposed to mercury or any products that have mercury. This program could also be directed to some of the industries that are engaging in the production of the substance to inform them on the consequences, the set rules, and regulations concerning its production. This could help in reducing or discouraging its manufacturers because they could be exposed to stiffer penalties if got or proved to be involved in production of mercury (Harris 12). The magnitude of the problem is that mercury emissions pose dangers to human beings, living creatures, and plant life. Exposure to mercury has a great health implication to children and even adults especially when the exposure is high.
• Examine environmental mercury pollution test results as the basis for putting in place even stricter rules and regulations meant to discourage improper mercury storage. Through the test results, counteractive actions could also be taken, if necessary. For instance, the assessment could assist Defense logistics Agency (DLA) strategic Material in Hawthorne Amy Depot in formulating its policies to deal with reduction of mercury emission by improving its storage conditions. The effectiveness of this alternative is evidenced by the financial clean air mercury rule established in 2005, which helped EPA to estimate that, by 2018, it could have managed to reduce mercury emissions by 69 percent (Mercury 3).

Consequences of Failure to Carry out Environmental Assessment

If there were a failure to carry out a deliberate environmental assessment, this would result to intolerable environmental harm worldwide, as well as a high cleanup and other costs in the future. Environmental degradation would eventually rise to the levels higher than it is now without any environmental assessment (Costanza and Jorgensen 210). The assessment was essential because it helped EPA to access information about the prevalence of these emissions, which helped in coming up with appropriate measures that helped to alleviate the increasing rate of mercury evaluation (EPA Fact Sheet 1). Those companies or institutions that were engaging in the production and distribution of these toxins came into limelight hence helping the government to deal with the cases, which helped in the reduction of mercury emissions in the environment. Another important legal case was between the North American Free Trade Agreement NAFTA and the United States’ EPA regulations of mercury emission discharges. NAFTA raised complains over EPA’s measures to control air emissions and waste discharges that contained mercury. NAFTA included several Canadian environmental groups and the US. They filed a case in September 2004 under the umbrella of NAFTA. They complained that EPA was not exercising its mandate and duties as it failed to enforce the clean air and clean water acts that would see the rate of mercury and water discharges reduced in Hawthorne Amy Depot.

Other alternatives that could be used to ensure that their demands were met are to engage in national campaigns besides lobbying to raise awareness of the risks that are inherent in the use of mercury products or the effects of its exposure. Such avenues could also be effective in determining the efficiency of actions taken to alleviate the effects of such emissions by the Defense logistics Agency (DLA) strategic Material in Hawthorne Amy Depot. The environmental groups under NAFTA had a driving force that compelled them to lodge their complaints to the body they deemed had authority to ensure that the environment was safe from any actions that threaten it (Austin 1). They were motivated to act in this manner because they understood the health implications that exposure to mercury brings to the society. Therefore, they wanted to ensure that such challenges and risks did not happen. Their intentions for the complaints were to ensure that people and the future generations are liberated from the chains of environmental pollutions caused by mercury emission. This action would trigger EPA to carry out environmental assessments in the future that would ensure that the environment is kept clean. It would help in coming up with new development or strategies that could be applied in the future to ensure that the environment in which people lived was free from any forms of intoxication (EPA Fact Sheet 1). In case these assessments would have failed, the results could be detrimental. The world would be exposed to high risk of developmental health complications due to the high exposure to these mercury emissions.

Conclusion

In conclusion, over the years, mercury emissions in Hawthorne Amy Depot have been a threat to the lives of many people based on the existing poor storage containers that have been in use for the last 40 years. Its use has become a central issue of debate that elicited mixed reactions on its containment. Mercury is one of those metals that are toxin, which can last for long period without losing their levels of intoxication (Austin 1). However, knowledge on its causes and effects is paramount in ensuring that it is dealt with accordingly. For instance, it can be transmitted to human beings through the consumption of fish that has the mercury elements. Furthermore, various products are manufactured with mercury components thus posing a threat to human lives. Combustion and increased solid wastes are also some of the causes of mercury emission. Therefore, the high concerns about this metal have triggered the formulation the Defense logistics Agency (DLA) strategic Material, which has formulated legislations that aim at ensuring a safe environment free of toxins. The agency has been marred with controversies and challenges. However, despite all these, it has managed to expedite its duties with diligence to attain high levels of success in fight against eradication of mercury emissions in the environment and other related toxins.

Works Cited

Austin, Sydley. Environmental update: Nafta complaint challenges EPA stances on air Emissions and water discharges of mercury, 2006. Web.

Collin, Robert. The Environmental Protection Agency: Cleaning up America’s Act. Westport, Connecticut: Greenwood Press, 2006. Print.

Costanza, Robert, and Steve Jorgensen. Understanding and Solving Environmental Problems in the 21^st Century; Toward a New, Integrated Hard Problem Science. Amsterdam; Boston: Elsevier, 2002. Print.

Croitoru, Leila, and Maria Sarraf. The Cost of Environmental Degradation: Case Studies from the Middle East and North Africa. Washington, DC: World Bank, 2010. Print.

DLA. Final Mercury Management Environmental Impact Statement. US: Defense Logistics Agency, 2012. Print.

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EPA Fact Sheet. Mercury and air toxics standards: Benefits and costs of cleaning up toxic air pollution from power plants, 2011. Web.

Gibbons, Whit. What are our top 10 Environmental Problems?. London: Routledge, 2006. Print.

Harris, Frances. Global Environmental Issues. Chichester, West Sussex, Hoboken, NJ: Wiley-Blackwell, 2012. Print.

Heinzerling, Lisa, and Rena Steinzor. “ELR News and analysis: A perfect storm, mercury and the Bush administration.” Environmental law institute 34.1(2004): 1-17. Print.

Jackson, Lisa. “National Emission Standards for Hazardous Air Pollutants for the Portland Cement Manufacturing Industry and Standards of Performance for Portland Cement Plants.” Federal Register 77.138(2012): 42368-42412. Print.

Mercury. The National Vehicle Mercury Switch Recovery Program, 2012. Web.