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Mercury
Work Group
Phase I Reports >> Operations Report
Executive Summary | End-of-Pipe Report |
Operations Report | Infrastructure Report
For more information,
contact David Eppstein by email at
deppstein@masco.harvard.edu,
or by calling 617-632-2860.
I. EXECUTIVE SUMMARY
Problem Definition:
The Massachusetts Water Resources Authority (MWRA) regulations
prohibit the discharge of mercury from industrial, commercial
and/or institutional sources to the sewerage system. The MWRA
will enforce this regulation at a level of five (5) times the
method detection limit (MDL) of 0.2 parts per billion (ppb) {based
on US EPA analytical method 245.1} which presently results in
an effective discharge limit of 1.0 ppb.
For the past year, the MWRA has been working with area hospitals
and MASCO (a consortium of Longwood Medical and Academic Area
Institutions) in a collaborative process that stresses cooperation
and the pooling of resources to identify and address the problem
of mercury contained in hospital and medical facilities' wastewater
streams. To this end, the MWRA \ MASCO Hospital Mercury Work Group
was formed with its charge to investigate the source(s) of the
problem and to explore methods for its abatement.
The Work Group approached the problem from three directions. The
Infrastructure Subcommittee focused on developing guidelines for
the removal of residual mercury from hospital wastewater conveyance
systems. The End of Pipe Alternatives Subcommittee concentrated
on the identification and evaluation of potential mercury pretreatment
systems. The Operations Subcommittee has been working to identify
sources of mercury contamination and to develop source reduction
management policies for their control. This Report describes the
process employed, the resultant findings and recommendations for
mercury abatement based on a policy of waste minimization and
exclusion.
Approach:
In formulating a source control approach to the mercury issue,
the Operations Subcommittee identified the following four basic
project areas for study:
The initial Reagent Identification process was key in documenting
existing data from available sources. As part of this process,
a database worksheet was developed to capture the wide range
of information known to, or produced by, the Member Hospitals
and Institutions with regard to the mercury content of specific
products. Next, a letter to major reagent vendors was developed
to elicit supplier support in identifying the trace levels of
mercury contained in their products. A follow-up vendor letter
was also sent out to reinforce the significance of the issue and
to stress the need for vendor cooperation. Chemical alternatives
and product substitutions were requested for those products found
to contain mercury.
In addition to this investigation of typical laboratory reagents,
the group worked to identify Other Sources of mercury contaminants.
A team of individuals from the Operations Subcommittee formed
a task force to identify other potential sources of mercury ranging
from Ajax Powder to Zinc-Form E Lids. The charge of this group
was to look at the possibility that common products, not otherwise
thought to be of significant importance or concern, might contain
low levels of mercury. Thus far, a total of 118 such products
have been identified by the twelve hospitals participating in
the survey. Some of the results are explained in Section III.
To help ensure the technical validity of obtained data, this Subcommittee
developed a standardized protocol for the Sampling and Analysis
of reagents, biomass, products and wastewater effluents for mercury
content. The Operations Subcommittee was asked to make the protocol
flexible enough so it could be used by its individual members
when soliciting future services from commercial laboratories for
field sampling and analytical services. The Request For Proposal
(RFP) which was subsequently developed was written to ensure consistency
in sampling and analytical technique for all hospitals and institutions
during the existence of the Work Group and beyond, so that additional
information obtained could be incorporated into the Database.
The Operations Subcommittee also realized that there would be
a need to develop a written Protocol and Training policy that
could be used by its members to implement the Group's findings.
Since the primary goal of this protocol would be to make the
individuals using these materials more knowledgeable and aware
of the mercury issue and proper disposal techniques, significant
emphasis was placed on making the written materials user friendly
and easily understood. The Group believes that 80% of their discharge
issues can be solved through employee training initiatives and
subsequent adherence to standard operating procedures (SOP's)
designed for the management of defined sources.
Findings:
The Subcommittee has found the presence of mercury in the workplace
to be pervasive. Source control and reduction is the best way
to address the problem since, as reported by another of the MASCO
Hospital Mercury Work Group Subcommittees, there is no end-of-pipe
solution. Further, we have also learned that we can not successfully
manage the mercury discharge using even the most rigorous infrastructure
maintenance program so long as we continue to pour mercury bearing
products down the drain. Employees must become better educated
about the mercury content of all the products they use...from
the most sophisticated chemical reagents to the simplest cleaning
products...if they are to properly manage their disposal.
The compiled Database provides the most current and complete information
available on the sources of mercury present within the products
consumed by the Member Hospitals and Institutions. Using all
available inputs, a total of 5,504 products have been identified
and inventoried. A significant number of these products have also
been tested and found to contain mercury at some level. In addition,
118 common products, such as bleach, alcohol, laboratory lids
and embedded tissue samples, have been identified as significant
sources of mercury that were unknowingly being discharged to the
sewerage system.
The Database was augmented by more than 61 vendor responses to
the Subcommittee's request for product certification of mercury
content. Although some of the responses failed to provide any
new information, others proved to be quite useful. These positive
replies helped to foster communication with some chemical suppliers
which served to heighten their awareness of the issue and the
emphasis being placed upon it by the participating hospitals and
the MWRA. One vendor even pledged to develop mercury free alternatives
for all of their products by the end of 1996.
The need to standardize the manner in which data on the mercury
content of products is collected was also highlighted through
the vendor information solicitation process. The differences in
sampling methodology and analysis varied to such an extent that
some of the initially reported results had to be remanded back
for further evaluation.
Recommendations:
Based on their collaborative efforts, the Operations Subcommittee
has developed the following recommendations to assist its members
and/or affected facilities in formulating their own source reduction
strategy for mercury:
Reagent Identification:
- Continue to work with the MWRA, Member Hospitals and Institutions,
and others, to maintain and upgrade the Mercury Products Database.
- Continue to work with the MWRA, vendors and other suppliers
of chemicals to identify mercury free substitutes for identified
problematic compounds and effect their use wherever appropriate.
- Disseminate the Database information on the mercury content
of products to other industries, trade groups and public agencies
and encourage their use of this valuable resource.
- The Database file should be updated and sent to the Member Hospitals
and Institutions on a semi-annual basis. Future methods for electronic
transfers of the Database need to be developed and implemented.
- In order to provide the information required to complete the
Database, a coordinated program to test all products for mercury
content should be developed. A joint effort involving the MWRA,
the Member Hospitals and Institutions and the vendors should be
pursued.
Other Sources:
- As in the case of reagents, Other Sources need to continue
to be identified through the efforts of users in cooperation with
vendors. Use of the standardized procedures for sampling and testing
should be employed to help ensure the uniform quality of the information
entered into the Mercury Database.
- Testing of all brands of bleach, neutralization tank reagents,
several brands of saline and incoming water should proceed as
soon as possible.
- All laboratories should be made aware of the mercuric oxide
presence in some types of hematoxylin stains. Also, fixers and
developers, the T3 (Wallac) Kit containing thimerosol, and embedded
tissues (all of which are used frequently in laboratories) must
be managed appropriately. Provisions must be taken to ensure
their proper disposal.
Sampling and Analysis:
- All Member Hospitals and Institutions should implement the prepared
RFP when analyzing sources for mercury content to ensure the technical
integrity of data obtained prior to its entry into the Database.
- All MWRA industrial discharge permit holders need to be made
aware of method detection limit (MDL) for mercury and the MWRA's
current interpretation of that limit.
Protocol and Training:
- All Member Hospitals and Institutions should maintain a complete
and accurate inventory of chemicals known to contain mercury and
refer to it when purchasing products. First line users of the
wastewater system should also be required to consult the products
Database before discharging waste materials down the drain. A
mercury management policy, as a component of a complete chemical
inventory plan, needs to be developed and/or strengthened by the
Member Hospitals and Institutions.
- Steps should be taken to ensure that appropriate Standard Operating
Procedures (SOP) for the proper disposition of products containing
mercury be developed and implemented.
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