Enclosure 2 to COMDTINST 16478.12
3.0 Ranking Criteria
To perform the proirity rankings, we selected objective criteria based on
data collected in the Scientific Assessment that we believe reasonably
measure the most commonly expressed concerns about discarded AtoN primary
batteries. As discussed in the Scientific Assessment, no evidence of
actual harm to people or the environment was found that could be directly
attributed to discarded AtoN batteries. We nonetheless felt it appropriate
that the selected criteria reflect potential and perceived effects as well
as actualities to ensure that primary concerns are adequately addressed in
the Coast Guard's decision making process.
3.1 Potential Human Health Effects
For the purposes of this study, we concentrated on three potential mercury
exposure pathways from discarded AtoN batteries:
Inhalation from exposed mercury or intentional/accidental burning
of a battery;
Ingestion by drinking mercury contaminated water; and
Uptake through eating fish with mercury levels above Food and Drug
Administration maximums.
The site attributes selected to indicate the potential for human health
effects are the projected number of batteries (total mercury potential),
the bottom type (indicative of the potential for broken batteries) and
sediment type (indicative of the potential for mercury retention and
Methylization), whether the site is terrestrial or under water (indicative
of the potential for human contact), the proximately of the AtoN site to
population concentrations and its salinity (indicative of possible use as a
3.2 Potential Environmental Quality Effects
The concern is that discarded AtoN batteries could potentially affect
discussed in the Scientific Assessment, some aquatic areas may be
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Volpe National Transportation Systems Center
Priority Ranking Plan for Aton Battery Recovery