Mercury Work Group
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FOOTNOTES

Guidebook Text:

  1. Refer to the MWRA Sewer Use Regulations, 360 CMR 10.021.

  2. The concentration unit of µg/L is often referred to as "parts per billion" (ppb).

  3. Noncompliant mercury dischargers are sewer users with discharges containing more than 1.0 µg/L of mercury.
  4. The Massachusetts State Sanitary Code, Section VIII (105 CMR 480.200(A)(1) and (E)) states that free-draining blood, blood products, and liquid pathological wastes (body fluids) can be disposed of directly to a municipal sewer system if they meet requirements of the responsible regulatory agency. For MWRA purposes, such wastes are considered Industrial Waste (360 CMR 10.004) because they would be discharged to the sewer because of an action taken by a medical facility. For example, blood waste is Industrial Waste because it would be discharged after extraction by the medical facility. Common human waste, such as urine, would not be Industrial Waste unless the facility had chemically processed it in any way. Because of the potential for intrinsically high mercury levels in these types of waste, an effective Mercury Management Plan might specify pretreatment or segregation and alternate disposal of such waste that would be considered Industrial Waste.
  5. The Massachusetts State Sanitary Code, Section VIII (105 CMR 480.100(F)) allows the use of compactors or grinders for processing medical and biological wastes (including tissues) after the wastes are rendered noninfectious by sterilization or disinfection. While the Code does not specifically authorize or prohibit their use prior to discharge to a municipal sewerage system, the processed wastes would apparently have to be considered liquid pathological wastes for discharge to the sewerage system to be allowed (by 105 CMR 480.200 (E)). Even if taken as liquid pathological wastes, such wastes may be chemically disinfected and would therefore qualify as Industrial Waste according to the MWRA Sewer Use Regulations (360 CMR 10.004). They would also tend to have intrinsically high mercury levels. Therefore, an effective Mercury Management Plan might specify an alternate method of disposal of such wastes.

  6. Special Waste is generally defined in the Massachusetts State Plumbing Code, 248 CMR 2.13, as wastes from other than standard plumbing fixtures. In Section (1)(e), Special Waste is more specifically defined as including, but not limited to:

organisms containing recombinant DNA molecules, chemical, nuclear, radioactive, deionized, acids, perchloric, solvents and alkalines from laboratories and industrial activities.

  1. Possible facility infrastructure mercury sources in Special Waste piping include residual accumulations from past mercury disposal and biomass accumulations. Refer to the following page, Section 2.5.4, and Appendix B of this Guidebook for further information.

  2. Massachusetts Regulations 248 CMR 2.13 (6) (d).

  3. Massachusetts Regulations 248 CMR 2.13 (9) (f).

  4. GalinstanTM, developed in Germany, is a liquid eutectic mixture of gallium, indium, and tin that is being promoted as a replacement for mercury in laboratory and clinical thermometers, blood pressure devices, dental fillings, switches, fluorescent lamps, and other applications. The thermometers are available in the US under the trade name GerathermTM. Mention of these products is not an endorsement or recommendation. Refer to Section 3.0 for supplier information.

  5. For guidance on source reduction concepts and economic evaluations, refer to the MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Pretreatment Guidance Manual, December 1997, Sections 5.0 and 11.0.

  6. MWRA/MASCO Mercury Work Group, Phase II, Mercury Management Subcommittee, Facilities Loading Subgroup Report, December 1997.

  7. Many hospital laundries have found that high mercury discharges are usually caused by singular events such as mercury thermometers that have been left in the pockets of lab coats.

  8. MWRA/MASCO Mercury Work Group, Phase II, Mercury Management Subcommittee, Facilities Loading Subgroup Report, December 1997, page 27.

  9. For a block process flow diagram depicting source segregation and a schematic diagram depicting an equalization tank intended for both flow and concentration equalization, refer to Figure 3 and Figure 4 of the MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Pretreatment Guidance Manual, December 1997, pages 26 and 27, respectively.

  10. While often used in waste piping systems, copper is not an approved material for Special Waste piping systems in Massachusetts. Refer to 248 CMR 2.13 (2).

  11. For the collection and offsite disposal of industrial wastewater in an area served by a sewer system, refer to Appendix C, Section 1.3.2, for MA-DEP permitting requirements.

  12. MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Technology Identification Subgroup Report, December 1997.

  13. MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Pretreatment Guidance Manual, December 1997.

  14. In May 1998, the EPA proposed that Method 1631 be approved for mercury measurement with a detection limit as low as 0.5 nanograms per liter, i.e., 0.5 parts per trillion.

Appendix B:

  1. The Massachusetts State Plumbing Code is found in 248 CMR 2.00, and Special Waste is covered in Subsection 2.13.

  2. 248 CMR 2.13 (8)(e).

  3. 248 CMR 2.13 (4).

  4. 248 CMR 2.13 (10).

  5. For further information, refer to the MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Pretreatment Guidance Manual, December 1997.

  6. Massachusetts Regulations 248 CMR 2.13.

Appendix B-1:

  1. The Massachusetts State Plumbing Code is found in 248 CMR 2.00, and Special Waste is covered in Subsection 2.13.
  2. 248 CMR 2.13 (8)(e).
  3. 248 CMR 2.13 (4).
  4. 248 CMR 2.12 (10).
  5. For further information, refer to the MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Pretreatment Guidance Manual, December 1997.
  6. Massachusetts State Plumbing Code, 248 CMR 2.13 (2), limits fixture and piping materials in Special Waste systems to high silicon (14.5%) cast iron, polypropylene, polyethylene, glass, chemical stoneware, lead, stainless steel (Type 316, 18-8), and chemical resistant monolith epoxy resins.
  7. MWRA/MASCO Mercury Work Group, Phase II, End-of-Pipe Subcommittee, Pretreatment Guidance Manual, December 1997. Refer to Sections 1.2 and 3.0 for information on obtaining a copy of the Pretreatment Guidance Manual and other Phase II reports.
  8. As part of a special project investigating sources of copper in its sewer system, the MWRA began in September 1998 to collect samples of discharges from various permitted facilities to analyze them for copper content. Several medical and biotech facilities were sampled and found to have elevated copper levels in their discharges. It is not yet known if the copper originated from copper compounds in waste medical reagents or from corrosive reagents contacting copper piping materials in the facility Special Waste systems. Regardless, as shown in a previous footnote, copper is not an allowed piping material in Massachusetts Special Waste systems.

Appendix B-3:

  1. Refer to Appendix B-1, footnote 6, for a listing of approved fixture and piping materials in Massachusetts Special Waste systems.
  2. For example, some brands of bleach have the active ingredient, sodium hypochlorite, derived from chlorine that is manufactured in a mercury cell process. Preferred brands would instead have their chlorine manufactured in a diaphragm cell or membrane cell.

  3. For the collection and offsite disposal of wastewater, refer to Appendix C, Section 1.3.2, for MA-DEP permitting and collection tank design requirements.

  4. For general and specific prohibitions and discharge limits, refer to MWRA Sewer Use Regulations at 360 CMR 10.021, 10.023, and 10.024.

  5. MA-DEP Hazardous Waste Regulations: 310 CMR 30.000.

Appendix C:

  1. EPA Hazardous Waste Management Regulations: 40 CFR Parts 260 to 2XX.

  2. MA-DEP Hazardous Waste Regulations: 310 CMR 30.000.

  3. MWRA Sewer Use Regulations: 360 CMR 10.000.
  4. 40 CFR 261.24 (b).
  5. Because mercury is not considered a carcinogen, OSHA does not require mercury in concentrations below 1.0 percent to be listed in a MSDS.
  6. This example is for illustration only. Caution is strongly advised here because a TSDF license is generally required before a facility can engage in any treatment of a hazardous waste.
  7. Currently, the MA-DEP BWP IW 29 Permit Application and general requirements can be downloaded from the MA-DEP Web site: http://www.state.ma.us/dep.
  8. Currently, new rules are under review as part of the MA-DEP Environmental Results Program and the revised Industrial Wastewater Sewer Connection Program. It is possible, therefore, that submittal of the BWP IW 29 industrial wastewater holding tank permit application would not be required by one or all of the MA-DEP regional offices.

  9. The regulation (in 360 CMR 10.004) defines Industrial Waste as:

any solid, liquid, or gaseous Wastes or Wastewater, resulting from an industrial or manufacturing process, or from a commercial, governmental, or institutional activity, or from the development, recovery, or processing of natural resources.

  1. Refer to Massachusetts Regulations 310 CMR 7.00.

  2. Note that other requirements apply to contaminated soils.

Appendix D:

  1. Note that for hazardous waste sampling, the EPA allows only grab sampling.

  2. In addition, if a discharge needs but does not have a sewer use permit or if a sampled location is the equivalent of a permitted location, the data must be submitted to the MWRA if the data meets the other requirements for submission as listed above.

  3. In May 1998, the EPA proposed that Method 1631 be approved for mercury measurement of samples of wastewater streams that are directly discharged to surface waters. The full impact on POTW’s, sewer-discharging industries, and directly-discharging industries from the potentially required use of this proposed method is not yet known.

  4. Refer to the previous footnote about proposed Method 1631. If Method 1631 becomes EPA-approved and required for mercury measurement of samples of wastewater streams that are directly discharged to surface waters, awareness of and compliance with all the Clean Hands techniques will become crucial.

Appendix F:

  1. The volume or wastewater superficial residence time of the activated carbon adsorbers is not known. Typically, large volume adsorbers having long superficial residence times are required for the very low effluent mercury concentrations as required for compliance.

  2. Refer to the following page for results of follow-up analyses on the electrophoresis waste.

  3. BQL = Below Quantitation Limit with an unknown numerical value.

   

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