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Mercury Work
Group
About
the Mercury Work Group
The Massachusetts Water
Resources Authority (MWRA) currently prohibits the discharge of
mercury by industrial facilities to its sewer system and imposes
an effective discharge limitation for mercury of 1.0 part per
billion (ppb) from its regulated sources, including hospitals
and institutions. Meeting the MWRA's standard for sewer
discharge presents a formidable challenge for hospitals because
of the nature of the testing performed and the type of equipment
used by health care providers in their effort to effectively
diagnose and treat disease. Key substances used in research and
diagnostic work, reagents in particular, often contain trace
amounts of mercury that are usually not listed in the content
descriptions.
These trace amounts of
mercury tend to collect in the organic material (biomass) that
may be present in waste piping systems and, as a consequence,
can slough off into the wastewater stream at any time. This
problem is further complicated by the fact that laboratory
testing procedures vary significantly, depending upon the type
of testing or research being conducted, making standardization
of procedures exceedingly difficult.
To address this complex
issue, the MWRA established a Mercury Products Work Group in the
Fall of 1994 to examine the problem and develop strategies to
reduce the amount of mercury being discharged. Hospital
participation in this process was coordinated through MASCO (a
not-for-profit provider of services and technical assistance to
Longwood Medical and Academic Area institutions), and involved
the active participation of twenty-eight (28) hospitals.
One of the innovative
aspects of this project involved the MWRA's and hospitals'
willingness to suspend their usual rules of engagement by moving
beyond the traditional use of enforcement mechanisms including
fines as the primary means of pursuing compliance. Specifically,
the MWRA distributed a memorandum stating that the MWRA would
not fine a hospital for mercury violations, so long as they were
actively participating in Work Group activities. This not only
provided direct economic relief to some of the institutions
(prior to formation of the Work Group, one of the members had
received a fine in excess of $100,000), but it served to create
a climate in which all parties were able to focus more clearly
on the search for solutions to the problem at hand. The
repercussions of this paradigm shift caused institutions to also
consider and change their normal ways of interacting with each
other. Rather than competing, as is so often the case these
days, the participating institutions focused on bringing their
collective resources to the table. The pooling of knowledge and
the allocation of staff in this fashion has helped to produce
results much more quickly and thoroughly than would have
otherwise been possible. In addition, this collective approach
to addressing common concerns has thus far saved those
institutions more than $2 million through the elimination of
duplicate efforts that would have been required as part of
individual compliance programs.
The Work Group (with a
new name of the MWRA/MASCO Mercury Work Group) approached the
problem from three directions:
- Identify sources of
mercury contamination and develop recommendations for their
control.
- Develop guidelines
for the removal of residual mercury from wastewater systems.
- Identify and
evaluate potential mercury pretreatment systems.
In the course of their
work, the various Subcommittees of the Work Group drew from
public data bases, researched the literature, performed
analytical testing of products to assess mercury content, issued
letters to chemical manufacturers requesting their support,
completed facility audits, reviewed Material Safety Data Sheets
(MSDS), conducted interviews with suppliers of wastewater
pretreatment systems and technologies, generated new analytical
data from actual points of discharge from its members'
facilities, and directed a bench-scale feasibility test program
with six participating pretreatment technology vendors. As a
result of implementing lessons learned during the Work Group
process, the average hospital mercury discharge has fallen by
83% since 1994 and from approximately 8 ppb in MWRA FY1997 to
less than 4 ppb in FY1998.
In 1997, the MWRA
issued another memorandum creating penalty "safe
harbors" for those institutions that continued to make
progress toward compliance with the mercury discharge
prohibition under enforcement orders and schedules. In response,
several facilities have been implementing mercury pretreatment
systems to bring their discharges into compliance.
A relational database
containing information on the mercury content of products used
in various facilities, including clinical and research
laboratories has been developed and is available on this
website. This Mercury
Products Database can be accessed via the Phase II Reports
menu and allows for both the review and input of information.
Use this document to get critical mercury content information on
products by name or type of use. You can also check to see if
there are known mercury-free alternatives. And, we encourage you
to take advantage of the "interactive" capability of
our web site and help us improve the database by using the
database input forms to share information you might have on
particular products.
During Phase II of this
project that began in 1996, the MWRA/MASCO Mercury Work Group
produced four important documents. The
Facilities
Loadings Subgroup Report details what we have learned about
the levels of mercury discharge from five types of facilities.
The
Pretreatment Guidance
Manual contains useful information intended to help
facilities understand the various steps that may be necessary as
part of a comprehensive source reduction program. The Manual
pays particular attention to the selection, design,
installation, and operation of an industrial wastewater
pretreatment system. The
Technology
Identification Subgroup Report is a companion document to
the Pretreatment Guidance Manual and presents information on the
chemistry of mercury in wastewater and on the results of
bench-scale feasibility tests of six mercury pretreatment
technologies on samples of clinical laboratory wastewater.
Recognizing the need to
integrate all that we have learned about reducing mercury
discharges, the Work Group completed the
Mercury
Management Guidebook in May 1999. The Guidebook was written
to help all types of facilities in overall management of mercury
to reduce and control the mercury content of sewer discharges.
While directed toward facilities discharging to sewers in the
MWRA sewer service area, the Guidebook should be an important
resource to any facility in an effort to reduce mercury
discharges.
Oustide the MWRA/MASCO
Mercury Work Group, MASCO prepared a Generic RFP for the Testing
of Mercury Removal Technologies that outlines one approach to
pretreatment system vendor selection. This RFP is intended to
help institutions that find it necessary to pursue pretreatment
options in addition to source reduction.
As a follow-up to the
Work Group's bench-scale pretreatment feasibility testing
project, the Massachusetts Strategic Envirotechnology
Partnership (STEP), operating under the Massachusetts Executive
office of Enfironmental Affairs (EOEA), conducted a pilot-scale
project of four mercury removal technologies at threee
wastewater generating facilities. The STEP project report is
expected to be published in late 1999.
For more information,
contact David Eppstein by email at deppstein@masco.harvard.edu,
or by calling 617-632-2860.
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