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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.
V. PROTOCOL AND TRAINING
Problem Definition:
The best means for ensuring that compliance with the mercury prohibition
is adequately addressed lies in the education of responsible personnel.
The best way to educate personnel and to make them knowledgeable
of the myriad number of sources that can contribute to the problem
is by an ongoing program of training. In general, hospitals, institutions
and other industries have all used similar training techniques.
While some individual programs may be exceptionally detailed in
certain areas, they may be lacking in others. The Subcommittee,
therefore, set out to incorporate the best aspects of each program
when developing a standardized Training Protocol for use by its
members. This effort would help ensure that the necessary information
could be passed on to affected employees within each Institution
so that they could gain an appreciation for the problem and an
understanding of how their individual efforts and diligence might
help in the mitigation of future exceedences.
Approach:
The Operations Subcommittee compiled the Protocol and Training
Report, as contained in Appendix I, based on the input received
from its various members. The Introduction section discusses
what mercury is and describes some of its uses. It also contains
a brief history on the MWRA's and EPA's combined efforts with
the Boston Harbor Clean-up project and how the mercury content
in the effluent to the Harbor has an effect on the MWRA's NPDES
Permit. The prohibition of mercury, as per 360 CMR 10.024(1)(a)
is discussed, as is the relationship between the detection limit
of 0.2 ppb and the enforcement threshold of 1.0 ppb.
This is followed by an overall discussion of prohibited substances,
as per EPA's National Pretreatment Standards (40 CFR 403), plus
an explanation of how numerous contaminants, solids, liquids and
gasses can create specific hazards at a POTW. In addition, the
Report notes that all MWRA Industrial User Discharge Permits (IUDPs),
through the Regulations (360 CMR 10), expressly prohibit the discharge
of polychlorinated biphenyls (PCB's), pesticides, phenanthrene
and MERCURY to the sewer.
The Report also contains a chart which lists currently regulated
pollutants along with their maximum discharge limits. This can
be utilized when following the process flow diagram for the facility
chemical inventory process as shown on page 4 of the Protocol
and Training Report. Though this chart focuses on mercury, it
can also be used generically for any pollutant of concern.
Another section of the Report provides information on the management
of mercury sources. The primary elements discussed are procedures
for identification, reduction and substitution, appropriate disposal
practices and methods for managing a current database.
Educational approaches, in the form of training program outlines,
are included, as are educational resources such as Agency/Institutional
listings and associated telephone numbers. A glossary of terms
explains several of the acronyms frequently used and the Appendix
includes a general listing of many common, as well as not so common,
mercury containing compounds.
Findings:
It is generally recognized that most of the hospitals and institutions
have good hazard communication (HAZ-COM) programs along with other
well established health and safety related protocols. The presence
of written chemical inventory and tracking mechanisms along with
methods for the screening of products for mercury content prior
to their introduction or use at the facility, however, is limited.
Since MSDS are required to divulge component information on only
those products which contain concentrations of 1% or more (10,
000 ppb) of a hazardous constituent, they will not serve as an
adequate basis for identifying all significant sources of mercury
within the facility.
Preparation of a written Standard Operating Procedures (SOP),
which contains clear, concise and accurate information, is an
essential tool for use in training laboratory, facility and other
operating personnel about the pervasiveness of mercury in the
products they use on a daily basis. More importantly, the SOP
details the methods for restricting the use of certain existing
(and all new) products once they have been identified as mercury
bearing. The collection and proper disposal (regulated, non-hazardous
or hazardous waste collection) of these products is critical when
one is trying to achieve discharge compliance through a program
of source reduction/waste minimization. This basic training of
personnel should be provided at the time of hire and then be reinforced
by periodic refresher training.
The key elements of a successful Protocol and Training program
are:
- A policy statement by management that the awareness program
applies to ALL employees.
- An explanation of the deleterious impacts that improper use
of mercury products can have upon the environment.
- A definition of prohibited substances.
- A statement of the facility's sewer discharge limitations.
- A means for establishing a usable chemical inventory system
and management process.
- A good HAZ-COM program which provides details on the origin,
movement and fate of mercury in the environment.
- Techniques for the successful management of mercury sources.
- Recommended solutions for cleaning up mercury contaminated areas
and names and contact phone numbers of emergency personnel.
- Describing product substitution initiatives.
- Outlining waste minimization approaches.
- Providing information on sources of additional educational
resources.
- Creating a policy that allocates sufficient time and resources
for employee's education on mercury abatement.
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