New Mexico Mercury Reduction Action Plan 

Prepared by the Task Force 

Created Pursuant 

To House Memorial 5 

November 10, 2006 

Participating Agencies: 

New Mexico Environment Department (NMED) 

And 

New Mexico Department of Health (DOH) 
Mercury Reduction Plan 

Executive Summary and Recommendations 

Page i 

New Mexico Mercury Reduction Action Plan 

Executive Summary........................................................................................................................ ii 

Legislative Recommendations for Mercury Reduction .................................................................. ii 

Recommendations to NMED.........................................................................................................iii 

Recommendations to DOH............................................................................................................iii 

Recommendations to NMED and DOH ........................................................................................ iv 

Mercury Reduction Action Plan ..................................................................................................... 1 

Background................................................................................................................................. 1 

Part 1: Air Exposure Pathways.................................................................................................. 2 

Federal Clean Air Mercury Rule............................................................................................. 2 

Crematoria............................................................................................................................... 4 

Portland Cement Plants/Kilns................................................................................................. 5 

Large Municipal Waste Combustors ...................................................................................... 5 

Part 2: Human Exposure Pathways............................................................................................ 5 

Food - Commercial Fish ......................................................................................................... 5 

New Mexico Fish and Surface Water Needs.......................................................................... 6 

Dental Amalgam..................................................................................................................... 7 

Vaccines.................................................................................................................................. 8 

Part 3: Mercury-Containing Equipment..................................................................................... 9 

Household Hazardous Waste .................................................................................................. 9 

Hazardous Waste Regulation................................................................................................ 10 

Universal Waste Rule – Fluorescent Lights.......................................................................... 10 

Mercury in Auto Switches.................................................................................................... 11 

Fever Thermometers............................................................................................................. 12 

Thermostats........................................................................................................................... 13 

Part 4: Other Mercury Sources ................................................................................................. 14 

Consumer Products............................................................................................................... 14 

Medications (other than vaccines)........................................................................................ 14 

Cosmetics.............................................................................................................................. 15 

Food, Dietary Supplements, Herbs....................................................................................... 15 

Mining and Mercury in New Mexico ................................................................................... 15 

Federal Facilities and Mercury Emissions............................................................................ 16 

Conclusion .................................................................................................................................... 17 
Mercury Reduction Plan 

Executive Summary and Recommendations 

Page ii 

 

Executive Summary 

During the 2006 legislative session, Representative Peter Wirth introduced memorials asking the 

New Mexico Environment Department and the Department of Health to look at mercury issues 

facing the state. House Memorial 5 required the departments to develop a Mercury Reduction 

Plan for New Mexico. A Mercury Reduction Plan Task Force worked in collaboration with the 

Dental Mercury Workgroup, convened pursuant to House Memorial 13, to develop a state 

Mercury Reduction Action Plan. The two working groups1

 have completed a Mercury 

Reduction Action Plan that includes this executive summary, the recommendations, and the 

supporting report. 

The Task Force proposes the following state policy regarding mercury and asks that this policy 

be adopted by the State of New Mexico: 

It is the policy of the State to minimize harm from exposure to mercury in New Mexico by 

reducing or eliminating emissions, discharges, and use of mercury and/or mercury-containing 

products to the greatest extent possible, when such measures are technically and economically 

feasible, taking into account the health and environmental costs of exposure to mercury. 

This report and its recommendations provide mechanisms for implementing this policy. 

Legislative Recommendations for Mercury Reduction 

The Task Force recommends that the State of New Mexico: 

a. Adopt the mercury policy recommended above: 

“It is the policy of the State to minimize harm from exposure to mercury in 

New Mexico by reducing or eliminating emissions, discharges, and use of 

mercury and/or mercury-containing products to the greatest extent possible, 

when such measures are technically and economically feasible, taking into 

account the health and environmental costs of exposure to mercury.” 

b. Allocate $200,000 to NMED and DOH (through an appropriation to NMED) to fund: 

i. staffing and resources to implement the reduction strategies that can be done 

immediately; 

ii. a mercury study including 

1. a comprehensive and quantitative inventory of mercury sources, waste 

and emissions; 

2. a comprehensive mercury exposure study on pathways for mercury 

exposure; and 

3. a monitoring program to assess air, water, soil and biota for mercury 

contamination. 

iii. to educate the public on the hazards of mercury exposure; and 

iv. to develop a state fish consumption advisory program, including both commercial and 

locally caught fish advisories, which will provide public information and outreach. 

1

 A list of the members of the Mercury Reduction Plan Task Force and Dental Mercury Workgroup is attached as 

Attachment 1. In addition, the two memorials, House Memorial 5 and 13, which convened the two working groups 

are attached as Attachment 2. Please note that there is a separate report for House Memorial 13. 
Mercury Reduction Plan 

Executive Summary and Recommendations 

Page iii 

c. Make a statutory change to require that all dental facilities in New Mexico be equipped 

with amalgam separators to assure that little or no solid mercury drains into municipal 

wastewater or septic systems and that the separators be properly maintained by the 

dental facilities. 

d. Fully support the Solid Waste Bureau legislative request to refund the grant and loan 

fund to safely remove and recycle mercury from the waste stream, where possible; to 

educate the public on mercury removal from the waste stream; and to assist local 

governments in conducting household hazardous waste collection programs. 

e. Give preference to power generating plants that use renewable sources of energy, and 

evaluate economic incentives to promote sources of energy that emit minimal or no 

mercury emissions, such as renewable energy sources and advanced coal emission 

reduction technologies. 

Recommendations to NMED 

The Task Force recommends that the New Mexico Environment Department: 

a. Conduct a comprehensive and quantitative inventory of mercury sources, waste and 

emissions, initiate action steps identified and report back to the Legislature with 

recommendations, if necessary, regarding statutory changes suggested by NMED. 

b. Create initiatives to recover and recycle mercury-containing equipment and products, 

including but not limited to, automotive switches, fluorescent lights, relay switches and 

measuring devices. These initiatives should include increasing public awareness of the 

hazards of mercury, encouraging the public to buy non-mercury-containing products, 

and informing the public of the proper disposal of mercury-containing products. 

c. Increase business and governmental awareness regarding the hazards of mercury, 

mercury-containing equipment, alternatives to this equipment and proper disposal of 

mercury-containing materials. 

d. Work with states, tribes and at a national and international level to reduce airborne 

mercury emissions. 

e. Provide adequate staffing and resources for enforcement of mercury-related 

regulations, including NM wildlife habitat standards, and promotion of storm-water 

best management practices. 

f. Consider crematoria initiatives, including adoption or adaptation of the best 

management practices being developed by Colorado for crematoria. 

Recommendations to DOH 

The Task Force recommends that the New Mexico Department of Health: 

a. Conduct a comprehensive mercury exposure study on pathways for mercury exposure 

and report back to the legislature with recommendations, if necessary, regarding statutory 

changes suggested by DOH after input from stakeholders; 

b. Identify and publish a list of all products containing mercury that are ingested or applied 

to the body, provide education to the public and medical community, and consider a ban 

on mercury-containing products, where appropriate. The list shall include: 

• Dietary supplements, herbs, homeopathic and Ayurvedic medications that contain 

mercury 
Mercury Reduction Plan 

Executive Summary and Recommendations 

Page iv 

• Medications marketed in New Mexico that contain mercury 

• Any cosmetics sold in New Mexico that contains mercury 

c. Avoid use of dental mercury amalgam in vulnerable patients in the following ways: 

1. Avoid placing, removing or polishing amalgam in the teeth of pregnant women, or 

women who may become pregnant, as the developing brain of the fetus is the most 

sensitive receptor to mercury toxicity; 

2. Avoid using mercury to restore children’s teeth as their developing central nervous 

systems are particularly susceptible to mercury impairment; 

3. Avoid using mercury in other vulnerable patients including those with kidney disease, 

central nervous system disorders, autoimmune disorders, and allergic/chemical 

hypersensitivity, and breastfeeding women; and 

4. Avoid placing amalgam in patients with other kinds of metal surfaces in their mouths. 

d. Minimize exposures to airborne mercury in dental offices. 

1. Promote the use of methods and equipment to reduce the exposure to mercury vapor 

in dental patients and staff; and 

2. Inform dental practitioners of the health and environmental risks of mercury 

exposures. 

e. Reduce exposures to mercury from vaccines containing mercury preservative by: 

1. Implementing a plan to make influenza vaccine that contains no mercury preservative 

available for pregnant women, with support from health care providers; 

2. Educating providers who care for pregnant women on the availability and benefits to 

their patients of influenza vaccine that contains no mercury preservative; 

3. Continuing to promote the production and use of vaccines that contain no mercury 

preservative; and 

4. Introducing a resolution at the Association of State and Territorial Health Officers 

meeting calling on vaccine manufacturers to move toward all vaccines that contain no 

mercury preservative. 

f. Educate the public on the risks and benefits of dental mercury amalgam and vaccine 

containing mercury preservatives. 

Recommendations to NMED and DOH 

The Task Force recommends that the both departments: 

a. Reduce exposures from food containing mercury, including fish, by developing a 

state fish consumption advisory program for both commercial and locally caught 

fish, providing public information and outreach, and studying the feasibility of 

requiring mercury labeling of food products and posting warnings at all commercial 

establishments and restaurants that sell fresh, frozen, packaged or cooked fish. 

b. Create an ongoing Mercury Reduction Advisory Committee that is similar in 

structure and function to the Task Force established by House Memorial 5. 

c. Create a comprehensive fact sheet on mercury that includes exposures from fish, 

dental amalgam, vaccines, and other common sources. 
Mercury Reduction Action Plan 

Background 

During the 2006 New Mexico Legislative Session, House Memorial 5 and 13 were 

introduced by Representative Peter Wirth and approved by the legislature. House 

Memorial 5 required the New Mexico Environment Department and Department of 

Health (NMED and DOH, respectively) to convene a task force to develop a state 

mercury reduction action plan for presentation to interim legislative committees in the 

fall of 2006. The task force convened had representation from a broad spectrum of 

stakeholders, including physicians, nurses, state agency staff, representatives of tribal 

government, representatives of academia, representatives of industry, representatives 

from national laboratories, representatives of environmental advocacy groups and 

concerned citizens. The following is the result of discussion and collaboration of these 

groups to recommend measures for reducing the exposure of humans and wildlife to 

mercury to the greatest extent possible. The Task Force also recommends further 

identifying the extent of mercury use and the extent of mercury contamination in the 

state. 

Mercury is a metallic element that can take many chemical forms. All forms of mercury 

are toxic. Mercury can be found at low concentrations throughout the environment and 

can be transported globally by upper atmospheric air currents. The primary route of 

human exposure to mercury is through consumption of mercury-containing fish and 

having mercury-containing dental amalgams. People are also exposed to mercury found 

in some vaccines and other medications. 

When mercury gets into water bodies, some of it can be converted into methyl mercury 

and enter the aquatic food chain, where it bioaccumulates in fish tissue. Mercury is 

released into the environment by natural sources such as volcanoes, oceans, and soils. 

Mercury also occurs naturally in certain ores. Processes such as coal combustion, gold 

mining (and some other kinds of mining), municipal and hazardous waste combustion, 

cement manufacturing, and pulp and paper milling release mercury into the environment. 

Additionally, many common household and industrial products contain small amounts of 

mercury. The mercury in these products can be released to the environment when these 

products are incinerated, put into landfills, broken, or end up in our waste water systems. 

All sources of mercury exposure are cause for concern. Mercury affects the human brain, 

kidneys, liver and cardiovascular system. Because mercury impairs the development of 

the brain and nervous system, unborn and young children are particularly sensitive to 

mercury toxicity. In adults, mercury can cause nervous system problems and have 

adverse effects on the cardiovascular system. Wildlife that live in an aquatic 

environment and consume fish, such as ducks and osprey, may contain elevated levels of 

mercury, too. Many water bodies in New Mexico have fish consumption advisories due 

to the elevated levels of mercury in the fish residing in these waters. Human 

consumption of these fish (or waterfowl that may consume these fish) may result in 

Mercury Reduction Plan

Page 1 
adverse health impacts. Pregnant women who eat fish from these water bodies may 

jeopardize fetal development of their unborn children. 

It is important to consider both the large generators of mercury releases, such as mercury 

releases from coal-fired power plants, national and international transport of mercury by 

air, and the numerous small releases of mercury from everyday products such as mercury 

releases from dental amalgams and broken fluorescent light bulbs. Therefore, efforts to 

control mercury releases range from working with large companies to educating the 

public. 

Part 1: Air Exposure Pathways 

Federal Clean Air Mercury Rule

The U.S. Environmental Protection Agency (EPA) promulgated the Clean Air Mercury 

Rule (CAMR) in March 2005. When fully implemented, CAMR and the federal Clean 

Air Interstate Rule (CAIR)2

 together are estimated to reduce nationwide emissions of 

mercury from coal-fired power plants from 48 tons per year to 15 tons per year. Mercury 

emissions from power plants are presently one of the largest sources of mercury 

emissions. However, after the full implementation of the CAMR, the relative 

contribution of mercury from other sources will increase. 

CAMR includes federal New Source Performance Standards (NSPS)3

, which pertain to 

coal-fired electricity generating units and an optional market-based cap-and-trade 

program for states. CAMR requires reduction of nationwide mercury emissions in two 

phases. The first phase cap, beginning in 2010, is 38 tons nationwide and emissions will 

be reduced through mercury reductions achieved by reducing sulfur dioxide and nitrogen 

oxides emissions. In the second phase, due in 2018, coal-fired power plants will be

subject to a second cap, which will reduce emissions to 15 tons nationwide. 

Like other states, New Mexico was assigned an annual “budget” for mercury emissions in 

the Clean Air Mercury Rule. Two tribes were assigned a mercury emissions budget. 

Table 1, below, shows the annual mercury budget for New Mexico, neighboring states, 

and the Navajo Nation. 

New Mexico presently has two coal-fired power plants under the jurisdiction of NMED. 

The total mercury emission from coal-fired plants is estimated to be 880 lbs or less than 

half a ton per year. PNM operates the four unit San Juan Generating Station which 

currently emits approximately 780 lbs of mercury per year. Tri-State operates the one 

unit Escalante Generating Station which is estimated to emit 90-100 lbs of mercury per 

year. Much of the mercury found in New Mexico air originates elsewhere. Mercury 

emitted in New Mexico contributes to the global pool of mercury.

 

2 The federal CAIR rule applies to approximately the eastern half of the continental United States and does 

not apply to New Mexico. 

Mercury Reduction Plan

Page 2 

3

 Subparts HHHH and Da
Table 1: Annual Mercury Budgets Under the Clean Air Mercury Rule and Current 

Proposals of Select States and Tribe 

Select 

States/Tribe 

2010-2017 

(Tons per year) 

2018 and after 

(Tons per year) 

Proposed New

Unit Set-Aside 

Proposed Joining 

Trading Program? 

Arizona 0.454 0.179 TBD4 TBD 

Colorado 0.706 0.279 36% Yes

Navajo Nation 0.601 0.237 TBD TBD 

New Mexico 0.299 0.118 5% (2010-2017); 

3% (2018 and 

after) 

No 

Utah 0.506 0.2 5% (2010-2014);

3% (2015 and 

after) 

Yes 

New Mexico will submit a state plan to meet its budget for reducing mercury from coalfired power plants by April 2007. Currently, two coal-fired utilities are eligible for a 

portion of the state’s mercury budget, PNM San Juan Generating Station and Tri-State 

Escalante Generating Station. The allocation method is not yet finalized. 

 

PNM’s Mercury Reduction Program at San Juan Generating Station. The PNM San Juan 

Generating Station (SJGS) is the largest power plant that is regulated by New Mexico for 

air emissions. On March 10, 2005, Public Service Company of New Mexico (PNM) 

entered into a Consent Decree with the Grand Canyon Trust, the Sierra Club, and NMED 

regarding emission of pollutants from SJGS. 

As part of this Consent Decree, PNM is required to design an activated carbon injection 

(ACI) technology, or comparable mercury reduction technology, for all four SJGS units. 

The purpose of this requirement is to maximize mercury reduction of each unit. 

As part of the Consent Decree, PNM submitted the required report describing the 

mercury removal technology planned for installation at SJGS to NMED and Plaintiffs for 

their approval on May 9, 2006. PNM has proposed the use of ACI technology for the 

removal of mercury from the flue gas. The year and a half test period on Units 3 and 4 

will indicate the level of mercury removal possible. Continuous emission monitors will 

measure the total mercury air emissions from each of the units. 

The schedule in the Consent Decree for the startup of mercury controls on each of the 

four units is: 

Unit 4 - 10/31/2007 Unit 2 - 12/31/2009 

Unit 3 - 4/30/2008 Unit 1 - 12/31/2009 

 

Mercury Reduction Plan

Page 3 

4 TBA - to be determined 
Renewable Portfolio Standard. On March 4, 2004, Governor Richardson signed SB43, an 

act providing for renewable energy5

 rules for public utilities. The Renewable Portfolio 

Standard requires that public utilities include renewable energy as a percent of energy 

retail sales in energy supply portfolios. By January 1, 2006, 5% of the annual energy 

retail sales must be generated by renewable energies. This increases 1% per year to a 

goal of 10% in 2011 and thereafter. 

The Renewable Portfolio Standard may reduce mercury emissions if alternative energy

sources are developed and used. This would reduce the demand for electricity generated 

by coal-fired utilities. Potential opportunities exist for solar, wind and biomass 

generation. The Renewable Portfolio Standard provides a 3 credit multiplier for solar 

power, and the Public Regulatory Commission is actively encouraging utilities to develop 

projects. 

One promising concept, Concentrated Solar Power (CSP), is already being bid to PNM. 

CSP focuses solar heat with large mirrors to boil water, instead of burning coal. CSP 

projects are under construction both nationally and internationally. CSP plants can use 

fossil energy or biomass as backup, and can therefore provide baseload generating 

capability. A CSP plant that displaces coal-fired generation will drastically lower 

mercury emissions in addition to NOx , SOx and CO2 emissions which could impact 

climate change. Environmental impacts due to coal-mining would also be less with CSP. 

Studies by the Western Governors’ Association and the U.S. Department of Energy 

predict a bright future for CSP once costs are reduced by large scale implementation. 

Crematoria

Crematoria emit mercury emissions when human corpses that contain mercury amalgams

are incinerated. There are 20 licensed crematoria in NM. The amount of mercury 

emitted by New Mexico crematoria is estimated to be 40 pounds per year6

. Mercury 

emissions from crematoria likely constitute about 4% of air emissions in New Mexico at 

present. 

Since individual crematoria emit amounts of air pollutants below state permitting 

thresholds (including mercury and other toxic chemicals), air quality permits are not 

required, nor are there state or federal air quality standards that apply specifically to 

crematoria. Efforts to reduce mercury emissions from crematoria are hampered by the 

fact that technology to reduce emissions can be expensive and removal of amalgams prior 

to incineration is fraught with social discomfort and religious objections. 

The Colorado Department of Public Health and Environment is working on a project to 

develop best management practices that may be a model for New Mexico. This plan 

includes capturing mercury before it enters the cremation cycle and is part of the 

 

5

 Renewable energy is defined as energy generated from solar, wind, hydropower, geothermal or biomass,

and fuel cells that are not fossil fueled. 

Mercury Reduction Plan

Page 4 

6

 Using Colorado estimate of 3 grams/cremation and extrapolating data on the number of 2003 cremations 

from the Cremation Assn of North America to estimate about 6,500 cremations per year in NM. 
Crematoria Initiative of the Mercury-Free Colorado Campaign7

. They may recommend 

that dentists remove teeth containing mercury amalgams prior to cremation. 

Portland Cement Plants/Kilns 

Mercury can be present to varying degrees in portland cement plants' raw materials, 

including the main feed material (limestone) and the primary fuel (coal). Mercury can 

pass through the cement manufacturing process and avoid containment in the cement 

product. As a result, mercury may be emitted as solid or gas in the process exhaust 

stream. The EPA reports that nationwide there are 118 cement plants. GCC of America's 

Rio Grande Portland Cement Plant in Tijeras, New Mexico is a local example. 

In 1999, the EPA promulgated national emission standards for new and existing sources 

in the portland cement manufacturing industry. These now have been challenged in 

court. At present, these emissions standards do not contain MACT (maximum achievable 

control technology) standards or emission limits for mercury from portland cement 

plants. It remains to be seen if the final amendments remain the same as the proposal and 

require no measures be taken by cement plants to control or limit mercury emissions. 

Large Municipal Waste Combustors 

Section 129 of the Clean Air Act required the EPA to develop and adopt New Source 

Performance Standards (NSPS) and emissions guidelines for Municipal Waste 

Combustors (MWCs) based on application of MACT. These regulations were adopted 

by the EPA in 1995 and were fully implemented by 2000. The regulations were highly 

effective in reducing emissions from MWCs. When compared to the 1990 baseline, the 

MACT regulations reduced metal emissions (cadmium, lead, and mercury) by more than 

93 percent. On April 28, 2006, the EPA adopted revised emission limits in the NSPS for 

large MWC units8

 that should provide more reductions. 

Part 2: Human Exposure Pathways 

The primary pathways that people are exposed to mercury include fish/seafood ingestion, 

dental mercury amalgam, and mercury-containing vaccines. Informed consumers and 

medical/dental providers are a critical component in decreasing human exposure to 

mercury and avoiding negative health impacts. 

Food - Commercial Fish 

While fish and shellfish can be an important part of a healthy diet, nearly all fish and 

shellfish contain traces of mercury (primarily methyl mercury). Mercury is transferred 

up the foodchain and bioaccumulates in predator fish species, i.e., fish that eat other fish. 

Fish sequester mercury primarily in muscle tissues, away from vital organs that would 

otherwise be damaged. This protects the fish from mercury’s toxic effects, while 

increasing the risk to humans who eat fish. Mercury is found throughout fish muscle 

 

7 www.cdphe.state.co.us/hm/mercury/crematoria.htm 

Mercury Reduction Plan

Page 5 

8

 Large MWC units are those that burn more than 250 tons per day of municipal solid waste (about 25

garbage trucks). 
rather than in the fat or skin. Cleaning the fish does not reduce the mercury exposure and 

mercury is not destroyed by cooking. Therefore, the only way to reduce mercury 

exposure is to reduce the amount of contaminated fish eaten. 

Pregnant or nursing women, women who may become pregnant, and young children 

should avoid eating some types of fish. The developing fetus, infants and young children 

are particularly sensitive to mercury toxicity due to their developing nervous systems. 

The EPA and Food and Drug Administration (FDA) issued the following guidance: 

2004 EPA and FDA Advice for Women Who Might Become Pregnant, Women Who are 

Pregnant, Nursing Mothers, and Young Children9

1. Do not eat Shark, Swordfish, King Mackerel, or Tilefish because they contain 

high levels of mercury. 

2. Eat up to 12 ounces (2 average meals) a week of a variety of fish and shellfish 

that are lower in mercury. 

o Five of the most commonly eaten fish that are low in mercury are shrimp, 

canned light tuna, salmon, pollock, and catfish. 

o Another commonly eaten fish, albacore ("white") tuna has more mercury than 

canned light tuna. So, when choosing your two meals of fish and shellfish, you 

may eat up to 6 ounces (one average meal) of albacore tuna per week. 

Follow these same recommendations when feeding fish and shellfish to your 

young child, but serve smaller portions. 

A more recent study recommended that pregnant women consume NO canned tuna, after 

tests revealed large variability between the mercury content in various cans10. The state 

of California requires stores selling fresh fish to post signs identifying the kinds of fish 

that typically contain higher levels of mercury. 

New Mexico Fish and Surface Water Needs 

Mercury is generally present at very low concentrations in New Mexico surface waters. 

Its presence is due in large part to atmospheric deposition of industrial emissions. Once 

in surface water and associated sediments, mercury can concentrate through aquatic food 

chains and bioaccumulates in fish tissue. Because of this concern, many states have fish 

consumption advisory programs to inform citizens. New Mexico has an advisory 

program without dedicated funding. The New Mexico Departments of Health; 

Environment; Game and Fish; and Energy Minerals and Natural Resources collaborate on 

this program. 

Since mercury in surface water cannot be significantly reduced without reducing 

atmospheric deposition, efforts must first be directed to reduce air-borne mercury 

 

9 Excerpted from www.cfsan.fda.gov/~dms/admehg3.html

10 http://www.npr.org/templates/story/story.php?storyId=5454772

Mercury Reduction Plan

Page 6 
emissions. To accomplish this, emerging technologies to reduce or eliminate mercury 

emissions from power plants must be implemented world-wide. 

Funding is needed to establish mercury deposition monitoring stations, especially in the 

Four Corners area, to assess the contribution to the local atmospheric flux of mercury 

from the coal-fired power plants. There is already one mercury deposition monitoring 

station in southern New Mexico, at Caballo Reservoir. Also, the State of New Mexico 

does not have the capability to analyze water for low ambient levels of mercury. Funding 

should be made available for mercury analyses of water using modern laboratory 

methods that can measure New Mexico’s actual ambient mercury concentrations. 

To be effective, the advisory program needs re-occurring funding to monitor fish tissue 

levels around the state and keep the public informed of risks associated with consumption 

of fish. Funds should be provided to support the collection, processing, analysis, 

reporting, and posting of fish tissue mercury levels around the state. 

There are primarily two non-atmospheric sources of mercury inputs to surface waters of 

the state: municipal waste water effluents and certain mining run-off. The most probable 

significant source of mercury discharged into municipal waste water systems is dental 

waste. Mercury used in dentistry contributes to mercury pollution of surface water and 

resulting fish warnings. 

Metals mines, particularly precious metals mines and some coal mines, can potentially 

release mercury into the environment. There are no known mines in New Mexico that 

currently release mercury in surface water at levels that exceed state standards. 

Dental Amalgam 

A separate House Memorial to address dental mercury amalgam was also passed during 

the 2006 New Mexico Legislative Session. House Memorial 13 was introduced by 

Representative Peter Wirth and approved by the legislature. The memorial required the 

DOH to conduct a study on the dangers of dental mercury amalgam and develop 

recommendations for public informational materials and environmental safety for 

presentation to interim legislative committees in the fall of 2006. A Dental Mercury 

Workgroup was convened with representation from applicable stakeholders. The 

recommendations described previously in this document are the result of these efforts. 

The purpose of the recommendations is to identify legislative measures for determining 

the hazards of dental mercury exposure in New Mexico and to implement state initiatives 

to reduce the exposure of residents to mercury where possible. 

There is consensus in the technical literature that dental mercury amalgam can release 

mercury into the body. Estimating the amount of mercury exposure is difficult because 

of the high variability in the number, size, placement, and condition of amalgam fillings 

as well as differences in chewing, eating, and breathing habits. According to the federal 

Agency for Toxic Substances and Disease Registry, dental amalgams would be the most 

significant source of mercury exposure in the absence of fish consumption and proximity 

to incinerators. Several studies have been conducted with a consensus that dental 

mercury exposure typically ranges from 1 – 30 ug/day with an average generally reported 

Mercury Reduction Plan

Page 7 
as 5-10 ug/day. The threshold for mercury toxicity is still being determined, with some

neurological effects potentially occurring at very low levels in sensitive individuals such 

as children and the developing fetus. 

In addition to the direct exposure potential from the amalgams in patients, there is also 

occupational exposure for dentists and dental staff, as well as exposures to the public 

from environmental releases. Environmental releases occur from wastewater, sludge and 

crematoria. These releases can lead to exposure in water and air and subsequently be 

taken up into the food chain, particularly fish. 

Vaccines 

Thimerosal (ethyl-mercury) has been used as a preservative in some vaccines. The 

preservative helps prevent contamination by harmful microbes in multi-dose vials. 

Thimerosal has been completely removed from, or reduced to trace amounts (<1μg/dose), 

in all vaccines routinely recommended for children, with the exception of multi-dose 

inactivated influenza vaccine. Influenza vaccine that contains mercury preservative 

contains 25 μg of mercury per dose. A few other vaccines may also contain thimerosal as 

a preservative, but these vaccines are not purchased for use in children in New Mexico by 

the state Vaccines for Children Program (VFC)11. The Food and Drug Administration is 

working with vaccine manufacturers to reduce or eliminate thimerosal as a preservative 

from influenza vaccines12. Influenza vaccines that contain no mercury preservative are in 

short supply for children over three and adults due to their limited availability from

manufacturers. 

Pregnant women are recommended to receive influenza vaccine because they are at 

increased risk of serious complications from influenza infection. The developing fetus is 

most sensitive to the toxicity of mercury. As such, it is preferable that pregnant women 

be prioritized to receive the limited supplies of influenza vaccine that contains no 

mercury preservative. The DOH has ordered 20,000 doses of adult influenza vaccine that 

contains no mercury preservative and will give pregnant women priority for this vaccine. 

Young children are also at increased risk of serious complications from influenza 

infection and are recommended to receive the influenza vaccine. Young children are also 

recognized to be particularly sensitive to the toxicity of mercury. The DOH VFC 

Program purchases nearly all pediatric vaccines in New Mexico, with the exception of 

influenza vaccine (VFC provides approximately 80-85% of pediatric influenza vaccine). 

Vaccines purchased through this program are given to VFC providers without charge. 

To the extent that such vaccine is available, the DOH preferentially purchases influenza 

vaccine that contains no mercury preservative. This preference is not based on cost, it is 

based on supply. Influenza vaccine for children 6 to 35 months of age contains no 

mercury preservative and there is an adequate supply. Influenza vaccine that contains no 

mercury preservative for children 3 to 18 years of age is more limited in its availability. 

 

11 See http://www.vaccinesafety.edu/thi-table.htm for a complete listing.

Mercury Reduction Plan

Page 8 

12 http://www.fda.gov/cber/vaccine/thimerosal.htm 
DOH, the New Mexico Medical Society and the Pediatric Society, through the Clinical 

Prevention Initiative, agreed to support efforts to encourage the production of influenza 

vaccine that is free of mercury preservative and prioritize children and pregnant women 

for receipt of this vaccine as long as supplies remain limited. 

Part 3: Mercury-Containing Equipment 

Household Hazardous Waste 

As mentioned previously, mercury emissions fall generally into two categories – a small 

number of large mercury emitters such as power plants and numerous common items

which contain smaller amounts of mercury. Both groups contribute significant amount of 

mercury and neither should be ignored. Many common items that contain smaller 

amounts of mercury are disposed as Household Hazardous Waste. 

Some sources of mercury emissions are not regulated at all. The requirements for 

hazardous waste management vary depending on the point of generation; whether the 

waste is household hazardous waste (HHW), conditionally exempt small quantity 

generator (CESQG) waste, or small quantity generator (SQG) waste13. 

New Mexico solid waste regulations mirror the federal requirements which allow 

household hazardous waste to be thrown away and be disposed of in a permitted landfill. 

If a program accepts only waste from households, there are no applicable federal 

hazardous waste regulations. However, liquid wastes, including any characterized 

hazardous wastes, cannot be accepted for disposal at transfer stations or landfills. Many 

landfill operators are refusing to accept HHW with increasing frequency. 

Waste generated by a commercial or industrial establishment, even if it is the same waste 

as generated by a household, is not exempt from federal hazardous waste regulations. 

Small businesses are regulated under New Mexico Hazardous Waste requirements. 

The following are the common sources of mercury in the home which are unregulated: 

a) Thermometers (fever, candy, deep fry, oven, indoor and outdoor with a silvery 

temperature indicator); 

b) Barometers, tilt-switch thermostats, fluorescent lighting, HID lamps, and 

major gas-fired appliances such as ranges, ovens, clothes dryers, water heaters, 

furnaces, and space heaters that have pilot lights and a flame sensor or gas safety 

valve; 

c) Some pharmaceuticals and older fungicides, pesticides and paints; and 

d) Button batteries from older hearing aids, pre-1990- household batteries, irons 

with tilt safety switches, jewelry with a glass ampoule containing mercury, 

weights in grandfather clocks, some gas flow meters, bilge and sump pumps and 

older silent switches, and lights in some older model children’s tennis shoes. 

 

13 The Environmental Protection Agency (EPA) has issued regulations governing hazardous and solid

waste under the Resource Conservation and Recovery Act (RCRA). Hazardous waste is also governed by

the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund). 

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To prevent the disposal of HHW that include products containing mercury, several local 

governments in New Mexico have established periodic or on-going HHW collection 

programs to remove hazardous items from the waste stream. Collected materials are 

handled by approved contractors and the hazardous materials are recycled or treated in a 

hazardous waste landfill to protect environmental and public health. 

Hazardous Waste Regulation 

NMED has adopted the federal hazardous waste regulations which define and establish 

requirements for management of hazardous waste. The federal Toxicity Characteristic 

Leaching Procedure (TCLP) is a test that is used to determine if a waste exhibits the 

characteristic of toxicity14. NMED has an aggressive compliance and technical assistance 

program to ensure all hazardous wastes, including mercury-contaminated waste that fail 

the TCLP, are properly managed. However, conditionally-exempt small quantity 

generators (CESQG) are exempt from state and federal regulations even though they 

generate significant amounts of hazardous waste, including mercury. Current NM law

prohibits the state from establishing standards that are more stringent than federal 

standards, so we currently are not able to create our own standards for CESQG. 

Universal Waste Rule – Fluorescent Lights 

NMED has adopted the federal Universal Waste Rule, developed to regulate the 

management of widely generated wastes that contain toxic materials, such as batteries, 

lamps, thermostats, and mercury-containing equipment. The rule imposes less stringent 

requirements for storing, transporting, and collecting these wastes to promote better 

management practices such as recycling. Exempt users may continue to dispose of these 

wastes as non-hazardous waste unless the local solid waste facility restricts their disposal. 

For non-exempt users, universal waste may only be sent to another universal waste 

handler or a destination facility that treats, disposes of, or recycles universal waste. 

Spent lamps are the most common type of universal waste. Only lamps that fail the 

federal TCLP are considered a hazardous waste. Most fluorescent bulbs are hazardous 

due to their mercury content. Other lamps that, when spent, are commonly classified as

hazardous waste include: high-intensity discharge (HID), neon, mercury vapor, high 

pressure sodium, and metal halide lamps. NMED allows cathode ray tubes (CRT) to be 

managed as universal waste. The Rule does not apply to TCLP-passing “green” lamps. 

Lamps being handled as universal waste must be handled in a way to minimize breakage 

and under the federal Rule may not be deliberately crushed. The EPA considers crushing 

a form of hazardous waste treatment. Incidental breakage does not constitute treatment. 

NMED is proposing to allow crushing if certain conditions are met to minimize 

exposures to mercury released such as using commercially available lamp crushing 

 

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14 If a solid waste exhibits a concentration of 0.2 mg/L or greater of mercury, it is considered a hazardous

waste and is subject to stringent storage, treatment and disposal requirements. 
systems. NMED believes that allowing handlers of spent lamps to crush lamps under 

controlled conditions will actually reduce releases of mercury in the workplace and to the 

environment by minimizing accidental and deliberate breakage of mercury-containing 

lamps. It should be noted, however, that lamp crushers can leak small amounts of 

mercury and contaminate the space where the crushers are located. 

To provide users with more environmentally-friendly options, most manufacturers have 

developed “green” families of lamps that have either reduced or eliminated the use of

mercury and/or lead. Examples include Osram Sylvania’s ECOLOGIC® lamps, General 

Electric’s ECOLUX® lamps, and Philips’ ALTO® lamps. While the heavy metal content 

and labeling varies among lamp brands, these “green” brands pass the TCLP test and, 

while they still contain some mercury, may be managed as a non-hazardous waste. 

NMED strongly encourages businesses and individuals to use these “green” lamps to 

minimize the generation of mercury in waste. 

In addition to lamps, the Universal Waste Rule also covers waste batteries, thermostats,

and other mercury-containing equipment (MCE), such as switches, when they end up in 

the waste stream. NMED is currently planning to adopt new federals regulations that 

expand the types of MCE that may be handled as universal waste. One of the main 

problems confronting consumers and regulators with regard to MCE is that it is often 

difficult, if not impossible, to tell when such equipment contains mercury. Most are not 

labeled. NMED encourages businesses to elicit input from vendors or read product 

literature for information on mercury content. 

Mercury in Auto Switches 

Many American-made cars contained mercury switches until the year 2002, when the 

practice was discontinued. These cars are now being recycled and in 10 years the 

opportunity to recover this mercury will be essentially gone. The mercury enters the 

environment in auto salvage yards (when cars are crushed or shredded) and when the 

scrap metal is remelted in furnaces. Nationally, this release of mercury to the 

environment is estimated to be 10 tons per year. 

It is possible to establish an auto switch program in New Mexico. We propose the 

following ideas for consideration when developing a program: 

• A voluntary program with incentives is best and less resource-intensive. Since 

New Mexico is geographically large and has a low population density, the 

cost of enforcing a mandatory program would be significant. 

• It would be more efficient to focus capture efforts on end-of-life cars, though 

the program should accept switches from any source willing to turn them in. 

• If switches are kept intact, they can be processed, and shipped as universal 

waste rather than hazardous waste, greatly reducing cost and complexity. 

• Consider every possible kind of incentive, not just financial. There may be 

methods to reward participating businesses with public recognition, 

certificates of appreciation, or other methods of public recognition. 

• To quantify the success of any vehicle switch program, it would be useful to 

track several parameters: number of participating (and non-participating) 

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businesses, number of auto’s recycled each year, and number of switches

recovered. The vehicle identification number of recycled autos would 

establish a success rate, but the desire for data must be carefully balanced 

against discouraging participation with onerous recordkeeping requirements. 

• Borrow training material from those states that have already adopted programs

and adapt it to unique features of our program. Auto Recyclers must be made 

aware of the program, convinced of the importance of recovering/recycling 

and told how to participate. It is crucial that they be trained in what cars have 

which switches, and how to remove them safely. 

• Partner with industry groups or associations in outreach to their members. 

The most basic message should be: “This won’t cost you anything. You can 

earn a few bucks by removing these switches and selling them back to us.” 

• The physical work of switch removal will occur at auto recycling businesses, 

but only after a program and infrastructure are in place. Some funding is 

available from a national agreement with the Automobile Manufacturers 

Association. State funding may be needed to augment. 

New Mexico recycled cars, particularly from the northern part of the state, are shipped to 

the steel mill in Pueblo, Colorado. It is probable that cars from the southern part of the 

state and along the eastern and western borders are shipped to either Texas or Arizona, 

though the existence of a re-melt mill in Arizona has not been confirmed. Rather than 

work at cross purposes, it will be important to coordinate with the neighboring states to 

ensure that New Mexico’s program works smoothly with theirs. 

Fever Thermometers 

According to several national experts15 on mercury in products, the problem of mercury 

in fever thermometers is largely resolving itself, in terms of new mercury thermometers

entering the market and municipal solid waste (MSW) stream. Five years ago, all U.S. 

retailers and manufacturers of mercury fever thermometers discontinued making and 

marketing these products. Indeed, there are no mercury fever thermometers still 

manufactured in the Western Hemisphere. (Information is not available on products 

manufactured in China and India.) Non-mercury fever thermometers are fully developed 

and widely available. 

For New Mexico, the main problem of mercury reaching the MSW stream from fever 

thermometers will arise from the backlog of these products in New Mexico households 

and medical facilities. There have been at least three mercury fever thermometer 

exchanges done by the waste division of the City of Albuquerque, funded through the 

EPA, which resulted in the collection of approximately 2000 mercury-containing 

thermometers. The EPA estimated amounts of mercury from discarded thermometers in 

1997 was seventeen tons nationally. Data for New Mexico are unknown, and additional 

information is needed. 

 

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15 Alexis Cain, Region V EPA, Chicago, IL, and John Reindl, Dane County, WI, Solid Waste Dept, 

personal communications, May 2006. 
Thermostats 

According to the EPA mercury specialist previously cited, it is largely a matter of

conjecture to estimate: (1) the quantity of mercury thermostats presently in U.S. housing 

stocks that will enter the waste stream in the future; and (2) the quantity of mercury 

thermostats being disposed in landfills at present. 

A Washington study done in 200216 found 444 pounds of mercury entered the waste 

stream from thermostat disposal. Data for New Mexico are unknown, and additional 

information is needed. 

According to a U.S. EPA specialist, about two-thirds of U.S. states have passed 

legislation targeting mercury thermostats for bans or phase-outs. Ten northeastern states 

worked together on model legislation, and variations of this law were passed in enough 

states around the country that Honeywell, the manufacturer of 75 percent of mercury 

thermostats sold in the U.S., just stopped making mercury thermostats this year (2006). It 

is not known what the 2 other manufacturers — GE and White — will do. Again, the 

widespread availability of non-mercury thermostats facilitated the passage of these laws 

calling for a phase-out process which will reduce the future flow of thermostats to MSW. 

The three main thermostat manufacturers formed TRC, “The Thermostat Recycling 

Corporation,” in 1997, which facilitates recovery of old thermostats. Under this program, 

wholesalers serving the heating, ventilation and air-conditioning (HVAC) contractor 

community have collection barrels at their stores for discarded thermostats. This 

program is an excellent initiative by industry, which pays the costs of aggregating and 

processing the recovered mercury. In 2006, TRC recovered a total of 839 pounds of 

mercury through this program. However, the TRC effort is only as good as its collection 

network and publicity. The TRC website shows only 2 drop-offs for the entire state of 

NM (Alamogordo, Albuquerque). Also, the program does no outreach to contractors, 

home improvement stores, and the public to promote the effort. To remedy this, many 

state environment agencies have underwritten multi-year education campaigns for 

thermostat recovery. Two states (Oregon and Indiana) are running pilots where they pay 

for the added incentive to contractors of coupons worth discounts on Energy Star nonmercury thermostats in return for old thermostats turned in. 

Despite the TRC program, EPA’s flow model (mentioned above) shows a disappointing 

mercury thermostat recovery outlook for 2005 to 2010. For the U.S. as a whole, EPA 

predicts: 

• Mercury recovery – 6 percent 

• Mercury disposal to landfills – 75 percent 

• Mercury emissions to other media – 19 percent 

 

16 Washington State Mercury Chemical Action Plan Draft, August, 2002, Department of Ecology 

Publication No. 02-03-042

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At this rate, mercury recovery from thermostats would be 6 pounds per year in New

Mexico. 

Part 4: Other Mercury Sources 

Consumer Products

Mercury can be found in a variety of products, in addition to vehicle switches, 

thermostats, fever thermometers and fluorescent lights. These include, but are not limited 

to batteries, blood pressure cuffs, dairy manometers, computer parts, electrical switches 

and relays, and some novelty items. 

The Wisconsin Mercury SourceBook contains comprehensive information on sources of 

mercury according to specific sectors, such as educational institutions, business or

commercial establishments, households, etc17. The above products contain mercury that 

is added during the manufacture or assembly of the product. There are other consumer 

and household products that contain mercury as a contaminant18. 

Switches are found in thermostats, motor vehicles, and appliances, among other places. 

Relays are a type of switch that opens or closes electrical contacts, such as can be found 

in some ovens. Measuring devices include manometers, blood pressure cuffs, and 

thermometers. 

In Maine, most mercury-containing switches, relays and measuring devices are banned. 

These products account for 70% of mercury in mercury-added products. There are 

functionally equivalent nonmercury alternatives available for most products19. In 

Vermont, hospitals are required to submit a plan for mercury reduction to the state every 

three years, unless the hospital is achieving a 95% reduction in mercury. Similar 

requirements could be enacted in New Mexico. 

Medications (other than vaccines) 

Thimerosal (ethyl mercury) is present in some plasma-derived products. Mercury can 

also be found in some other medications20. Homeopathic medications may also have 

ingredients which may be derived from mercury compounds. During the past year, 

DOH’s Lead Poisoning Prevention program conducted a search for information regarding 

lead and other heavy metals in foods and medicinal products. The search found 

“potentially harmful levels of lead, mercury and/or arsenic” in Aryuvedic herbal 

medicine products. 

 

17 www.epa.gov/glnpo/bnsdocs/hgsbook 18 Examples are some toothpaste, deodorants, shampoo, laundry detergent, bleach, and others. 

(www.hgtech.com/Data/Other/Hg%20house.htm) 

19 LCSP Report (http://www.maine.gov/dep/mercury/lcspfinal.pdf) and the cover report to the Maine 

Legislature: (http://www.maine.gov/dep/mercury/productsweb.pdf). 

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20 See FDA list at www.fda.gov/cder/fdama/mercury300.htm. The FDA suspects that many of the products 

listed at this site are no longer on the market. It is not clear whether the products listed are prescription or

over-the-counter medications.
Federal pre-emption may prevent states from passing any law or regulation regarding any 

medications, whether prescription or over-the-counter, regulated by the FDA. 

Cosmetics 

It is difficult to determine if any cosmetic products legally sold in the U.S. contain 

mercury. Mercury-containing skin-whitening creams are sold in Mexico and are known 

to have caused mercury poisonings in the border areas of the U.S. These skin-whitening 

creams were banned from sale in New Mexico in 1996. 

Food, Dietary Supplements, Herbs 

The FDA is not aware of any mercury being intentionally added to food or dietary 

supplements. It is aware of a warning that some Chinese herbs contain unacceptable 

levels of mercury21. Food that may contain trace amounts of mercury, other than fish, 

include fruit juice, vegetables, rice/grains, processed meat, beef, chicken, waterfowl, salt, 

and sugar. Food coloring and soft drinks that contain yellow or red dyes may also 

contain mercury22. 

Other sources of the general public exposure to mercury include its use in spiritual or 

ritualistic practices and in herbal remedies. It has been found in commercially produced 

herbal ball preparations of Chinese origin. Religions that use mercury include Santeria, 

Voodoo and Espiritismo, and mercury is sold in “botanicas” under the name “azogue”. 

Mining and Mercury in New Mexico 

Associations between mercury contamination and mining activity are well documented. 

These can result from abandoned or active mining of mercury itself, smelting of ores 

which contain mercury as a by-product, and in the mercury amalgamation process of gold 

extraction23. About .05% of the annual amount of mercury released in the U.S. is due to 

lead and copper smelting (0.16 of 296.16 tons per year) and a much smaller amount can 

be attributed to mine-related releases. There is no active smelting activity in New 

Mexico, nor has there ever been mercury mining in the state because there are no ore 

quality mercury deposits. The amount of mercury emissions associated with gold mining 

in the state appears to be minimal, but there is scant data on historical mining or 

smelting-related mercury releases to the environment. 

Mining-Related Mercury in New Mexico. Analysis of ground and surface waters at hard 

rock mines throughout New Mexico has not shown mercury contamination that exceeds 

water quality standards. The largest likely source of mining-related mercury in New 

Mexico, although currently not identified, is that associated with historic gold mining. 

Such operations are responsible for mercury contamination in notable examples from 

California and Nevada. This is due to the mercury amalgamation process, in which 

mercury binds to gold in ore and then is vaporized by heating. Mercury emissions from 

 

21 www.fda.gov/cder/fdama/mercuryreport.htm 22 www.hgtech.com/Data/Other/Hg%20house.htm

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23 Releases from coal-fired electrical power plants (e.g., those in the Four Corners region), which are 

responsible for ~46 % of the total mercury deposited in the U.S.4

, are not included in this list. 
gold mining can also occur from mercury existing in primary mercury-gold ore, which is 

released in the smelting process. 

The New Mexico Bureau of Geology and Mineral Resources recognizes 40 or so gold 

mining regions in the state, some of which were discovered by the Spanish in the 1600’s. 

Most of these were small operations and were abandoned by the turn of the century. 

Examples include mid-1800’s gold placer mining at Pinos Altos, Sylvanite, Orogrande, 

Jicarilla, and the Cerrillos Hills. The largest and longest operating gold mine in the state 

is that at the LAC Cunningham Hills Mine in the Ortiz Mountains, which has been 

undergoing active reclamation since the mid-1990’s. Cyanide extraction replaced the 

mercury amalgamation process for U.S. gold mines in the 1960’s; therefore, mercury 

releases from the initial gold extraction process should not be a significant issue at any 

potential future gold mines in New Mexico. Currently, there are no existing or proposed 

gold refining/smelting facilities in New Mexico that could be a source of mercury 

emissions to the atmosphere. Should these types of activities be proposed for New 

Mexico, it is unclear that our state law would require them to obtain an air quality permit. 

Federal Facilities and Mercury Emissions 

There are 22 RCRA Subtitle C facilities in New Mexico with over 200 hazardous waste 

“operating units” cleaning up over 3000 contaminated sites. Half of these facilities are 

owned by the federal government. In addition, there are over 250 former Department of 

Defense sites with environmental contamination, of which about 50 are currently being 

actively investigated and cleaned up. Most of the contamination at these sites is the result 

of past practices that resulted in releases of hazardous constituents to the environment. 

Site investigation and clean up activities at these “legacy” sites receive considerable 

attention from NMED staff. Surface and subsurface, including groundwater, 

investigations have identified a wide-variety of hazardous constituents of concern. 

NMED will continue to evaluate new site investigation data to identify all significant 

contamination, including mercury, and ensure that appropriate remedial action responses 

are taken to protect public health and environment. 

Of all federal facilities, Los Alamos National Lab (LANL) has the most comprehensive 

database that is publicly available. Additional water quality data from the other facilities 

should be gathered and compiled to determine if there is a concern about mercury levels 

at those sites. 

A query24 of the LANL water quality database for storm water samples collected in Los

Alamos watershed (Los Alamos & Pueblo Canyons) from 2001 through 2004 shows eight 

exceedances of the mercury wildlife habitat standard from ranging from 0.91ug/L (parts per 

billion (ppb)) to 3.51ug/L (ppb) with an average concentration of 1.55ug/L (ppb). 

While other canyons at LANL (Ancho, Canada del Buey, Pajarito and Mortandad) show 

levels of mercury in storm water above the State Wildlife Habitat standard, they generally 

 

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24 Done by the DOE Oversight Bureau of NMED 
do not generate large enough flows to reach the Rio Grande as frequently as Los Alamos 

Canyon or Pueblo Canyon. Los Alamos Canyon and Pueblo Canyon consistently 

generate storm water flows that reach the Rio Grande. This suggests that of the mercury 

discharges that originate on LANL property, the bulk appear to enter the Rio Grande 

through the Los Alamos/Pueblo Canyon watershed. 

Conclusion 

The Mercury Task Force members believe that a great deal of progress can be made in 

reducing mercury statewide. There are several planned activities, particularly in power 

plant emissions, that should result in reduced mercury in the air. With some modest 

additional resources, the state can make great gains in identifying the extent of mercury 

products used and disposed of in New Mexico and in reducing these sources. 

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