Preparing for Compliance with MassDEP Mercury Prohibition for Industrial

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Information about Preparing for Compliance with MassDEP Mercury Prohibition for Industrial

Published on February 6, 2009

Author: triumvirate


Massachusetts Mercury Prohibition Are you Prepared? Triumvirate Environmental February 5, 2009

Today’s Topics MassDEP rules that went into effect on January 12, 2007 Industrial wastewater mercury prohibition regulations An action plan for compliance Find the source(s) Reduce/eliminate them Address infrastructure Pretreatment 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… Hospitals Commercial physical and biological research Colleges and universities Electric and gas production Medical schools/laboratories Maintenance facilities for motor freight transport Manufacturing facilities Dry-cleaning, carpet, Airports upholstery cleaning Industrial laundries 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?

Chemistry 101: Mercury (Hg) Atomic weight 200.59 Density 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

Mercury 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 Reduction Is Everyone’s Responsibility U.S. EPA Utilities States Chemical Communities manufacturers Industries Consumers Healthcare Environmental professionals Dentists Schools Educators

Fish Consumption Advisories Freshwater Fish Women that are pregnant, of child-bearing age, and children <8 are limited to one meal per month All Others One 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 Prevention for 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 baseline Source identification Source elimination/reduction Infrastructure control and maintenance Pretreatment system

Identifying Mercury Sources Baseline sampling of the discharge Identify potential sources Laboratories, process chemicals, janitorial/maintenance chemicals, and treatment chemicals Chemical inventories Review MSDS’ Compare to known mercury-source lists Request chemical assays from the manufacturer Test potential chemical sources Be 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 / Reagents Source Areas Laboratory sinks / traps Identify and collect isolated samples from pipe risers Check holding tanks, chip tanks, treatment system units Identify and sample occasional or intermittent discharges into the system (maintenance, janitorial, utilities, etc.)

Sources of Mercury Natural 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 ppb Comet Cleaner 0.15 ppb Alconox Soap 0.004 mg/kg Dove Soap 0.0027 ppb Ivory 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: neurotoxin Fate in the environmental: bioaccumulates in fish Sources in the facility Waste disposal practices Waste collection procedures Sink drain prohibitions (postings)

Pretreatment Evaluate system performance Tank cleaning Treatment 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 resins ALWAYS CONDUCT PILOT TESTING BEFORE INVESTING


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 washing Used to rinse sample bottles, glassware, ISCO tubing Occasionally 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 wastestream All 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 gaskets Changed all tubing and containers associated with sampling unit Retested Tested Hazardous Waste – should be more concentrated, right?

I Have Mercury… Found Chemical that was supposed to remove Hg, contained Hg. (thiocarbamate solution) Cleaned all sumps and piping leading to the WWTS Ran WWTS so that a sample could be taken prior to discharge – low flow enabled this Still find mercury on occasion

Remember! Kept in constant touch with the POTW! Told them about everything that we were doing, sample results, plans Had them in for a plant review They told us about MASCO Helped 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 toxic Methyl 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 ppb 0.1% = 1,000 ppm or 1,000,000 ppb

I Have Mercury… Nitric Acid 1.9 ppb Potassium hydroxide 30 ppb Hydrogen Peroxide 1.2 ppb Glacial Acetic Acid 100,000 ppb Formaldehyde 12,000 ppb 200 Proof Ethanol 10 ppb Caustic Soda 1 to 500 ppb

I Have Mercury… Raw materials manufactured by Membrane Mercury Cell Grade processes that involve mercury, 10-300 ppb less than 1 ppb Caustic Soda such as the mercury-cell Potassium Hydroxide 7 ppb less than 1 ppb process used by chlor-alkali plants, contain small amounts of mercury

I Have Mercury… Materials from production lines Acetone – 52 ppm 50 % NaOH - 19.2 ppb Nitric/Hydrochloric sol’n – 6.3 ppb Sodium hypochlorite – 2.6 ppb 30 % H2O2 diluted 1:100 Gave us nd <0.050 ppm!!!

Remember Talk to your lab! Used two labs Both had different testing capabilities Coagulant interference Split samples – not always as informative as with other metals

I Have Mercury… Found in two process sumps Checked chemical sources for both Removed one chemical – citronox (soap) Source in other area not found Cleaned 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 system Coagulant would decrease chemical use Remove mercury Remove lead Less sludge produced Easy to operate

I Have Mercury… pH buffers used in WWT 77-141 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 ppb Thiocarbamate 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 processes electrolytic 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 source Don’t give up! May need to resample Talk 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

Questions?? Sandra J. Perry Martha Wik Consulting Services Senior Wastewater Manager Consultant 617.686.7713 617.628.8098

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