Massachusetts Mercury Prohibition

Are you Prepared?

Triumvirate EnvironmentalFebruary 5, 2009

Today’s TopicsMassDEP rules that went into effect on January 12,

2007

Industrial wastewater mercury prohibition regulations

An action plan for complianceFind the source(s)Reduce/eliminate themAddress infrastructurePretreatment

Perils and Pitfalls – the challenges you are likely to face

Successes

Before We Get into the Mercury Issue…Other Regulatory Requirements:

MassDEP Permits for Industrial Sewer Users

Performance standard: pH limits narrowed to 5 – 10 su

Reporting on toxic pollutants

Who Does the Mercury Prohibition Rule Apply to?

All industrial wastewater dischargers located outside the Massachusetts Water Resources Authority (MWRA) sewer service area

Industrial User – An entity that introduces pollutants into a municipal sewer system from a non-domestic source

Including but not Limited to…

HospitalsColleges and

universitiesMedical

schools/laboratoriesManufacturing facilitiesAirportsIndustrial laundries

Commercial physical and biological research

Electric and gas production

Maintenance facilities for motor freight transport

Dry-cleaning, carpet, upholstery cleaning

Automotive services

What are the requirements? 314 CMR 7.05 - Section 2.f

July 12, 2007 – Determine possible sources of mercury in the discharge and take all reasonable steps to eliminate the mercury

May 1, 2009 – No industrial user shall introduce into a POTW or its wastewater collection system the following:

More than one part per billion (ppb) mercury

Reminder…

This is a Massachusetts DEP regulation…you must also comply with local sewer use ordinances and permits issued by the local POTW!

A Little Background…Why is Mercury a Problem?

Atomic weight 200.59Density 13.59

THREE (3) OXIDATIVE STATES:

•Hg(O) mercury, quicksilver

•Hg(I) mercurous ion

•Hg(II) mercuric ion

Crustal abundance 0.08 mg/kg

Native soils concentrations 0.01 - 0.08 mg/kg

Chemistry 101: Mercury (Hg)

Mercury in the EnvironmentMercury in the Environment

The Issue:Hazardous to human health

The Problem:How do we stop releases to the environment?

The Solution:Source reduction / elimination

MERCURY IS A GLOBAL CONCERN

Mercury Reduction Is Everyone’s Responsibility

U.S. EPAStatesCommunitiesConsumersEnvironmental

professionalsSchools

UtilitiesChemical

manufacturersIndustriesHealthcareDentistsEducators

Fish Consumption Advisories

Freshwater FishWomen that are pregnant, of child-bearing age, and children <8 are limited to one meal per month

All OthersOne meal per week

(Dependent on type of fish –

brook trout, salmon, etc.)

Warning – Don’t Eat the Fish!

Ocean Fish Advisories

Also fish-dependent

Swordfish, shark, tilefish and king mackerel are all off-limits to the pregnant, nursing women and children <8 group

Federal Drinking Water Standard

2.0 ppb

What is Massachusetts Doing About it?

Massachusetts Mercury Management Act (July 2006)

Specific mercury-containing devices cannot be sold in MA (May 1, 2008)

Labeling of mercury-containing products required (May 1, 2008)

Schools cannot purchase any mercury-containing products for classroom use (October 1, 2006)

Manufacturers must disclose mercury content to healthcare facilities

Prohibition of disposal in trash or wastewater

Why Pollution Preventionfor Mercury?

Prohibitive costs to add new treatment technology

We cannot totally eliminate mercury emissions with technology

Removal technology only relocates the pollutant

Source: Tim Tuominen, Western Lake Superior Sanitary District

So Let’s Get Started…How Do We Find it and Eliminate it?

Managing the Mercury Monster

Develop an Action Plan

Five components of your plan:Establish a baselineSource identificationSource elimination/reduction Infrastructure control and maintenancePretreatment system

Identifying Mercury SourcesBaseline sampling of the dischargeIdentify potential sources

Laboratories, process chemicals, janitorial/maintenance chemicals, and treatment chemicals

Chemical inventoriesReview MSDS’Compare to known mercury-source listsRequest chemical assays from the manufacturerTest potential chemical sourcesBe aware of intermittent activities / discharges

Establish a Baseline

1. First, you need to know what your current compliance status is, so:Develop a sampling plan

Begin at the end of the pipe and work back towards the potential sources

Develop a Sampling Plan

Chemicals / ReagentsSource AreasLaboratory sinks / trapsIdentify and collect isolated samples from pipe risersCheck holding tanks, chip tanks, treatment system unitsIdentify and sample occasional or intermittent discharges into the system (maintenance, janitorial, utilities, etc.)

Sources of MercuryNatural Sources- Naturally occurring element

Atmospheric Deposition - Coal and oil burning, incinerators

Consumer Products - Batteries, fluorescent lights, electrical switches

Dental and Medical Practices - Mercury amalgam, thermometers, lab reagents, batteries

Industrial Manufacturing & Chemical Use

Mercury-Containing Products

Thermometers (0.5 to 3 grams Hg)Thermostats (3 grams Hg)Thermostat Probes (ovens, clothes dryers, water

heaters, etc.)Fluorescent & High Intensity Lamps (mercury vapor

lamps, neon lamps, etc.)Gauges (manometers, barometers, vacuum gauges)Mercury Switches & Relays ( chest freezers, sump

pumps, auto trunk/hood light switches, etc.)

Mercury in Detergents and Cleaners

Ajax Powder 0.17 ppbComet Cleaner 0.15 ppbAlconox Soap 0.004 mg/kgDove Soap 0.0027 ppbIvory Dishwashing Liquid

0.061 ppb

Sources of Mercury in Medical Facilities

Batteries (defibrillators, hearing aids, pacemakers)

Electrical Equipment (fiber optics, mechanical switches)

Thermometers

Sphygmomanometers

Chemicals: Zenker’s Solution, Mercurochrome

Mercury Reduction and Elimination

Chemical substitution

Waste collection and offsite treatment/disposal

Company-wide prohibition on mercury-containing chemicals, reagents, equipment

Other: pipe cleaning / replacement

Employee / Staff Training

Mercury health effects: neurotoxinFate in the environmental: bioaccumulates

in fishSources in the facilityWaste disposal practicesWaste collection proceduresSink drain prohibitions (postings)

Pretreatment

Evaluate system performance

Tank cleaningTreatment chemicals

(sulfuric acid, sodium hydroxide)

Optimization

Treatment Enhancement and Technologies

First, sample and speciate (elemental, ionic, organic) the mercury entering the system

Control biogrowth within piping and treatment system

Filtration – initial pretreatment to remove particulate matter

Selective ion exchange resinsALWAYS CONDUCT PILOT TESTING BEFORE

INVESTING

Questions??

I have Mercury…

Now what do I do??

I Have Mercury…

October 2002 – Mercury found in discharge

“I don’t buy mercury or anything with mercury in it!”

“As far as I know, I don’t use Mercury at all!”

“It never showed up in previous sample results!”

I have Mercury…

Tested all waste streams, and all chemicals used in wastewater

Sump in the WWT area (0.14 mg/l)Used for hand washingUsed to rinse sample bottles, glassware, ISCO tubingOccasionally used by the company maintaining Water System

Removed – including all pipes leading to the WWTS

I Have Mercury…

Still found mercury

For waste streams that showed detectable amounts of mercury:

Test each sink, discharge, contributing to the wastestreamAll chemicals used in the area – even those that were “not discharged”Found several items that could be sources – eliminated chemical from entering waste stream

I have Mercury……..

Trained all employees in mercury and its problems –one on one with people in the areas that showed mercury

Removed piping, sink traps, rubber gasketsChanged all tubing and containers associated with

sampling unit RetestedTested Hazardous Waste – should be more

concentrated, right?

I Have Mercury…

FoundChemical that was supposed to remove Hg, contained Hg. (thiocarbamate solution)Cleaned all sumps and piping leading to the WWTSRan WWTS so that a sample could be taken prior to discharge – low flow enabled thisStill find mercury on occasion

Remember!

Kept in constant touch with the POTW!Told them about everything that we were doing, sample results, plansHad them in for a plant review

They told us about MASCOHelped us to check chemicals that we had missed previously or thought would not be a problem MSDS did not mention Mercury!

I Have Mercury…

HAZCOM“With regard to mixtures of chemicals, the HCS requires the evaluation of mixtures to be based either on data for the mixture as a whole, or, where that is not available, the mixture's health hazards are to be based on the presence of ingredients with health hazards over a specified percentage. That percentage is 0.1% for carcinogens, and 1.0% for all other types of health effects.”

OSHA – Federal Register September 12, 2006 (Volume 71, Number 176)]

I Have Mercury…

ATSDR – mercury is extremely toxicMethyl mercury and mercuric chloride are possible carcinogens

So, the MSDS only needs to mention methyl mercury and mercuric chloride if it is present at greater than 0.1%, other mercury types if greater than 1%

1% = 10,000 ppm or 10,000,000 ppb0.1% = 1,000 ppm or 1,000,000 ppb

I Have Mercury…

Nitric Acid 1.9 ppbPotassium hydroxide 30 ppbHydrogen Peroxide 1.2 ppbGlacial Acetic Acid 100,000 ppbFormaldehyde 12,000 ppb200 Proof Ethanol 10 ppbCaustic Soda 1 to 500 ppb

I Have Mercury…

Raw materials manufactured by processes that involve mercury, such as the mercury-cell process used by chlor-alkali plants, contain small amounts of mercury

less than 1 ppb7 ppbPotassium Hydroxide

less than 1 ppb10-300 ppbCaustic Soda

MembraneGradeMercury Cell

I Have Mercury…

Materials from production linesAcetone – 52 ppm50 % NaOH - 19.2 ppbNitric/Hydrochloric sol’n – 6.3 ppbSodium hypochlorite – 2.6 ppb30 % H2O2 diluted 1:100 Gave us nd <0.050 ppm!!!

Remember

Talk to your lab!Used two labsBoth had different testing capabilitiesCoagulant interferenceSplit samples – not always as informative as with other metals

I Have Mercury…

Found in two process sumps

Checked chemical sources for bothRemoved one chemical – citronox (soap)Source in other area not foundCleaned lines and sump with HgX

Found mercury in the sludge of the equalization tank

No mixer, no treatment

I have Mercury…

HgX – used to clean out sumps and lines to WWT

Put in ultrafiltration systemCoagulant would decrease chemical useRemove mercuryRemove leadLess sludge producedEasy to operate

I Have Mercury…

pH buffers used in WWT77-141 ppm !!!!!Then tested pH buffers used elsewhere – 16 ppm to one of the sumps.

Solution that we were going to use to solve mercury problem

72 ppbThiocarbamate based coagulant. Interference resulted in a positive Hg result. Removal of interference still showed presence of Hg.

I Have Mercury…

Sample, sample, sample

If it is in your treatment system discharge –sample the waste streams going to the treatment system

Sample every waste stream

Hg Treatment

Techniques employed for the removal of trace levels of mercury from water have included:

the use of a precipitating agent and associated filtration step ion-exchange technology(SR-200 from Resin Tech)selective absorbents (KeyleX from SolmeteX)membrane separation processeselectrolytic methods

Each situation is different and pilot testing should be conducted!

Recap

You WILL need to look at EVERY chemical that may reach the treatment system

Try and match up the day the discharge was sampled with the activities in the area

Test everything used that day – raw materials, rinse waters, soaps, glues, everything!

Recap

Didn’t find mercury sourceDon’t give up!May need to resampleTalk to people in the area; what did they do that they normally don’t?

Keep sampling – try to narrow down the sources

Keep in touch with the POTW

Recap

Find and remove the source

Vendor Certifications

Clean lines

Add treatment

Information Sources

www.mass.gov/dep/toxics/stypes/hgres.htmwww.masco.org/mercury/index.htmwww.newmoa.org/prevention/mercury/www.epa.gov/mercury/

Questions??

Sandra J. PerryConsulting Services

Manager617.686.7713

sperry@triumvirate.com

Martha WikSenior Wastewater

Consultant617.628.8098

mwik@triumvirate.com