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

2. 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

3. 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

4. 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

5. 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

6. 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

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

8. A Little Background…Why is Mercury
a Problem?

9. 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

10. 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

11. MERCURY IS A GLOBAL CONCERN

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

13. 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.)

14. Warning – Don’t Eat the Fish!

15. 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

16. Federal Drinking Water Standard
2.0 ppb

17. 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

18. 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

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

20. Managing the Mercury Monster

21. Develop an Action Plan
Five components of your plan:
Establish a baseline
Source identification
Source elimination/reduction
Infrastructure control and maintenance
Pretreatment system

22. 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

23. 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

24. 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.)

25. 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

26. 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.)

27. 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

28. Sources of Mercury in Medical
Facilities
Batteries (defibrillators,
hearing aids, pacemakers)
Electrical Equipment (fiber
optics, mechanical switches)
Thermometers
Sphygmomanometers
Chemicals: Zenker’s
Solution, Mercurochrome

29. 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

30. 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)

31. Pretreatment
Evaluate system
performance
Tank cleaning
Treatment chemicals
(sulfuric acid, sodium
hydroxide)
Optimization

32. 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

33. Questions??

34. I have Mercury…
Now what do I do??

35. 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!”

36. 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

37. 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

38. 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?

39. 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

40. 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!

41. 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)]

42. 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

43. 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

44. 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

45. 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!!!

46. 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

47. 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

48. 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

49. 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.

50. 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

51. 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!

52. 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!

53. 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

54. Recap
Find and remove the source
Vendor Certifications
Clean lines
Add treatment

55. Information Sources
www.mass.gov/dep/toxics/stypes/hgres.htm
www.masco.org/mercury/index.htm
www.newmoa.org/prevention/mercury/
www.epa.gov/mercury/

56. Questions??
Sandra J. Perry Martha Wik
Consulting Services Senior Wastewater
Manager Consultant
617.686.7713 617.628.8098
sperry@triumvirate.com mwik@triumvirate.com