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Mercury
Work Group
Phase I Reports >> Infrastructure Report
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For more information,
contact David Eppstein by email at
deppstein@masco.harvard.edu,
or by calling 617-632-2860.
10.0 WASTE DISPOSAL
The following section provides an explanation and general overview
of mercury waste disposal. All waste disposal activities should
be approved by an Environmental, Health and Safety Officer or
the person responsible for waste disposal. The MWRA prohibits
the disposal of chemicals into the sewer system except aqueous
solutions of non-toxic and non hazardous chemicals. The Massachusetts
Department of Environmental Protection (DEP) prohibits the improper
disposal of hazardous wastes. The following waste disposal guidelines
were established to satisfy both the MWRA and the DEP regulation
requirements.
Based on TCLP test data, the Massachusetts Hazardous Waste Regulations
at 310 CMR 30.00 consider a concentration of waste with less than
200 ppb of mercury to be a non-regulated material (MA99).
Non-regulated materials are exempt from all of the DEP's hazardous
waste regulations and can be accepted by landfill for final disposal.
Wastestreams determined, from TCLP testing, to have mercury concentrations
equal to or greater than 200 ppb are hazardous waste which are
given the code number D009.
The MWRA has a more stringent limit for total mercury which is
prohibited. As a matter of policy, however, at the present time
the MWRA will not enforce the discharge limitation for wastewater
discharges containing less than one ppb.
It is possible that significant mercury concentration will be
found in infrastructure piping where old biomass is present.
Powerwashing and trap cleaning operations typically yield wastewater
mercury concentrations in the 1 to 200 ppb range. This means
that most infrastructure cleaning operations will require the
wastewater to be collected and, in most instances, to be handled
as a non-hazardous waste. The determination of whether a waste
material is hazardous waste or non-regulated material should be
made based on TCLP analytical testing. It is possible to use
generator knowledge to assume a waste is a hazardous waste if
it is based on accurate and available information regarding similar
wastestreams. Some of this experience and information could be
previously analyzed wastewater samples, chemical vender material
safety data sheets (MSDS) and testing. Due to potential liability,
extreme care should be taken when deciding that a wastestream
is not a hazardous waste without the benefit of analytical testing.
Analytical testing is the most conservative method for waste characterization.
Although this is the best method for determining if a waste is
regulated, it can be very expensive when the generator has no
knowledge of the waste. This means that several different analytical
test would be required to ensure that all potential waste characteristics
have been evaluated.
The combination of generator knowledge and analytical testing
are the most common procedures used for hazardous waste determination.
Using generator knowledge of the waste enables a generator to
eliminate a majority of analytical testing for materials that
are known not to be present.
After the waste has been collected and a determination made about
the waste, one of the following methods of disposal may occur:
- Discharge to the MWRA
- Off-Site Disposal as Non-Regulated Material (MA99)
- Off-Site Disposal as a hazardous waste (D009)
Discharge to the MWRA
If it is determined that the collected wastewater contains mercury
below one ppb and that all other pollutant concentrations are
below discharge limits, this waste can be discharged to the sewer
only after written approval from the MWRA has been obtained.
The MWRA requires a notification prior to all non-typical wastewater
discharges.
Off-Site Disposal as Non-Regulated Material (MA99)
If the waste contains mercury at a concentration greater than
1 ppb, but less than 200 ppb, it is most likely a non-regulated
material under the Hazardous Waste Regulations 310 CMR 30.00.
Although non-regulated, the mercury concentration is above the
MWRA's discharge limit and must be disposed off-site.
Prior to transporting a waste material to a licensed waste disposal
facility the material usually will require pre-approval. The
pre-approval process is a requirement of most licensed disposal
facility and typically includes analytical testing and generator
knowledge of the waste.
It is important that each waste shipment have all the same characteristics
as initially approved by the licensed disposal facility. If the
original waste approval was for powerwashing with water only and
the next time powerwashing is performed but now with bleach and
water, a new approval for disposal may be required. The addition
of the bleach has now possibly changed the characteristics of
the waste.
Off-Site Disposal as Regulated Material
Wastes that contain mercury concentrations equal to or greater
than 200 ppb are characteristic hazardous wastes (D009). Regulations
governing the handling and storage of hazardous waste in Massachusetts
are located at 310 CMR 30.00.
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