Enclosure (1) TO COMDTINST 16478.12
Potential Human Health Hazard from Discarded AtoN Batteries
Based on comparison to conservative and accepted media specific standards,
mercury from discarded AtoN batteries do not pose a hazard to human health
from pathways related to air, soil, surface water, sediment, or consumption
of aquatic biota.
Multiple measurements of mercury vapor from batteries at terrestrial AtoNs in
the Tampa Bay area revealed levels well below levels of concern. The
measurements were taken directly over the batteries and thus represent the
most exposed pathway. Consequently exposure by inhalation pathways does not
pose a hazard.
Soil samples were also taken at Tampa area terrestrial AtoNs. Samples were
taken under, adjacent to, and at increasing distances from batteries.
Although the mercury levels were slightly elevated at the batteries they well
below levels considered by the U.S. Environmental Protection Agency to pose a
health hazard.
As discussed above, batteries in aqueous situations are not expected to result
in measurable levels of mercury in the water column. Thus the only potential
hazard from dissolved mercury would be through ingestion by aquatic organisms
and human consumption of the organisms. The same is true for sediments where
the most critical exposure pathways from sediments to human receptors is
through consumption of aquatic organisms.
The laboratory analysis of batteries indicate the mercury is not in the
available form. This is substantiated by the low percentage of methylmercury
in sediments associated with lighted AtoNs. It is also directly confirmed by
the measurement of low tissue levels of aquatic organisms in the vicinity of
AtoNs.
During the prototype investigation mercury levels in aquatic organisms was
only a fraction of the levels considered by the U.S. Food and Drug
Administration (FDA) to result in a hazard from consumption. During all the
prototype investigations, approximately 200 biological samples were analyzed
for mercury. None of these samples were more than 10 percent of the FDA level
and most were closer to 1 percent. Even this is a very conservative
comparison because only total mercury was measured in the tissue and the FDA
limit is based on methylmercury (which is generally on about 40 to 60 percent
of the total in invertebrate tissue). Consequently consumption of aquatic
organisms from areas around AtoNs is not expected to pose a health hazard to
humans.
Mercury Concentrations in Sediments Associated with AtoNs
4-4
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