Managing mercury mania
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Managing Mercury Mania. Jerald O. Thaler, P.E. Fishbeck, Thompson, Carr & Huber, Inc. Michigan Water Environment Association Annual IPP Seminar September 25, 2008. “Mercury 101”. The Wake-up Call.

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Managing mercury mania

Managing Mercury Mania

Jerald O. Thaler, P.E.

Fishbeck, Thompson, Carr & Huber, Inc.

Michigan Water Environment Association

Annual IPP Seminar

September 25, 2008


Managing mercury mania

“Mercury 101”


The wake up call

The Wake-up Call

  • In the 1950s and 1960s, Japan experienced an epidemic of psychotic disease and deformed/brain-damaged births

  • Traced to mercury poisoning from eating fish in Minamata Bay

  • Tons of mercury chloride was discharged by Chisso Corporation between 1931 and 1968

  • Aquatic organisms convert inorganic mercury to highly toxic methylmercury

  • Methylmercury bioaccumulates up the food chain (~106x for trophic level 5)

Bioaccumulation


Regulatory focus

Regulatory Focus

  • Michigan has strict, long-standing controlson mercury in wastewater discharges

  • Only recently has focus increased on air emissions, where the impact is greater

Tributaries (20%)

Atmospheric Deposition (80%)

Mercury Sources to Lake Michigan

(adapted from Frequently Asked Questions About Atmospheric Deposition, USEPA, September 2001)


Discharge standards

Discharge Standards

  • Rule 57 provides protection against toxicity

  • Wildlife protection controls at 0.0013 μg/L, or 1.3 nanograms per liter (ng/L)

  • No mixing zone credit for BioaccumulativeChemicals of Concern


Effluent monitoring

Effluent Monitoring

  • Method 1631

    • Grab sample

    • “Clean Hands/Dirty Hands”

    • Quantification acceptable for compliance testing

    • $90 each for 3 samples (duplicates plus field blank)

  • Method 245.1

    • Composite sample

    • Normal handling

    • Quantification inconclusive for compliance testing

    • $40-$50 each

(from Sample Collection for Ultra-Trace Concentrations of Mercury, Florida Department of Environmental Protection, ftp://ftp.dep.state.fl.us/pub/labs/assessment/ppt/utmsamp.ppt)


Npdes permit

NPDES Permit

  • Limits generally set at Level Currently Achievable (LCA) under multiple discharger variance

    • Initially 30 ng/L

    • Recently lowered to 10 ng/L

    • Soon to change to user-specific LCA

  • Applied as 12-month moving average

  • Effluent monitoring using Method 1631

  • Mercury Minimization Program required


Mercury minimization program

Mercury Minimization Program

  • Goal to achieve effluent of 1.3 ng/L

  • Formal plan approvable by MDEQ

  • Annual status report

  • Required elements

    • Monitoring of influent, effluent, and biosolids

    • Source identification

    • Source reduction

  • Recommended elements

    • Public education


Managing mercury mania

Minimization

Tips and Techniques


Avoid the regulatory trap

Avoid the Regulatory Trap

  • Mercury in permit if potential effluent quality (PEQ) exceeds 1.3 ng/L

  • Per Rule 1211, PEQ is statistical tool to relate quality/quantity of monitoring data

    where factor set by number of samples (N):

  • PEQ = CMAX * Factor


Avoid the regulatory trap1

Avoid the Regulatory Trap

  • Permit application generally requires minimum of four effluent samples

  • Sometimes more samples may be better

    • If 4 samples with CMAX of 0.7 ng/L, PEQ>1.3 ng/L and permit will include mercury

      PEQ = 0.7*2.6= 1.8 ng/L

    • If 10 samples with CMAX of 0.7 ng/L, PEQ<1.3 ng/L and permit may not include mercury

      PEQ = 0.7*1.7= 1.2 ng/L


Flexible sewer use ordinance

Flexible Sewer Use Ordinance

  • Traditional command-and-control approach: “No discharge of detectable mercury.”

  • May not be feasible for some commercial users

    • Technical limitations

    • Economic factors

  • Strict enforcement may be counterproductive to local economy


Flexible sewer use ordinance1

Flexible Sewer Use Ordinance

  • Alternative case-by-case approach: “No discharge of detectable mercury, except as specifically approved.”

  • Conditions of approval

    • Periodic self-monitoring

    • Minimization program (procedures, training, source identification/reduction, treatment, etc.)

    • All reasonable and cost-effective actions

  • Promotes flexibility and cooperation


Meaningful monitoring

Identified Sources

0.05 MGD

700 ng/L Hg

0.107 lb/yr Hg

Domestic/Background

WWTP Influent

WWTP Effluent

1.26 MGD

1.31 MGD

1.30 MGD

50 ng/L Hg

445 ng/L Hg

7.9 ng/L Hg

0.192 lb/yr Hg

1.773 lb/yr Hg

0.031 lb/yr Hg

Unidentified Sources

Average Removal

By difference…

98%

1.474 lb/yr Hg

Biosolids(6.5%)

396 T/yr

2.2 mg/kg Hg

1.742 lb/yr Hg

Meaningful Monitoring

  • Evaluate monitoring data via mass balance to fully assess overall system

  • Example:

Current Average


Meaningful monitoring1

Identified Sources

0.050 MGD

200 ng/L Hg

0.030 lb/yr Hg

Domestic/Background

WWTP Influent

WWTP Effluent

1.25 MGD

1.31 MGD

1.3 MGD

50 ng/L Hg

63 ng/L Hg

1.3 ng/L Hg

0.190lb/yr Hg

0.250 lb/yr Hg

0.005 lb/yr Hg

Unidentified Sources

AverageRemoval

By difference…

98%

0.073 lb/yr Hg

Biosolids (6.5%)

396 T/yr

0.3 mg/kg Hg

0.255 lb/yr Hg

Meaningful Monitoring

  • Apply mass balance results to prioritize minimization efforts

-0.077 lb/yr

-1.401 lb/yr

Goal


Productive source studies

Productive Source Studies

  • Common sources

    • Domestic sewage (25-50 ng/L)

    • Dental offices

  • Other observed sources

    • Hospitals and medical clinics

    • State prisons

    • Car washes

    • Rainwater (~10 ng/L) and snowmelt

  • Use sampling of collection system to identify significant sources and maintain neutrality


Productive source studies1

S-2

S-1

Source

P-1

P-2

S-1'

S-2'

WWTP

Productive Source Studies

  • Scattered sampling can be inconclusive due to high variability of mercury

  • Most efficient is moving upstream via “primary/secondary” scheme


Deal with the dentist

Deal With the Dentist

  • The most common controllable source of mercury

  • Mercury inherent to dentistry due to mercury-silver amalgams

  • Special challenge for smaller communities with multiple dentists


Deal with the dentist1

Deal With the Dentist

  • Typical mercury generated per office

    0.57 lb/yrAmalgam removal (97%)

    0.02 lb/yrAmalgam placement (3%)

    0.59 lb/yr Total

  • Removals for typical capture processes

    ~ 68%Chair-side traps

    ~ 40%Vacuum filters

    81%Overall

  • Typical sewer discharge per office

    0.59 * (1-.81) = 0.1 lb/year

(ENVIRON International Corp., Evaluation of Mercury in Dental Facility Wastewater, Ver. 3, American Dental Association, Nov. 2002)


Deal with the dentist2

Deal With the Dentist

  • Potential impact on treatment plant

    Assuming 2.5 million gal/day flow


Deal with the dentist3

Deal With the Dentist

  • Amalgam Separator

    • >95% mercury removal for wet vacuum systems

    • Not overly complex or expensive

    • Can produce significant improvement at treatment plant

  • “…[Amalgam separator] systems work well, and we now feel comfortable including them in our best management practice recommendations."

  • Dr. Mark J. Feldman, President

  • American Dental Association

  • October 11, 2007


Deal with the dentist4

Deal With the Dentist

  • Potential impact on treatment plant

    Again assuming 2.5 million gal/day flow


Deal with the dentist5

Deal With the Dentist

  • Proposed Legislation

    • SB-1310/HB-6307 mandate amalgam separators by December 31, 2013

    • Michigan Board of Dentistry to promulgate associated best management practices

    • However, prevents local authorities from pursuing further source reduction where warranted

“This… supersedes any local ordinance… that imposes… additional standards on dentists… including… a permit that limits the discharge of mercury… greater than that capable of being achieved by full compliance with this section.”


Perspective

Perspective

  • Justifiable concern over mercury in waterways

    • Air emissions need same, or greater, scrutiny aswastewater discharges

  • Tips and techniques from experience

    • Avoid the regulatory trap

    • Flexible sewer use ordinance

    • Meaningful monitoring

    • Productive source studies

    • Deal with the dentist

  • Resist legislation that, while well-intended, pre-empts local authority/control


For additional information

For additional information:

  • Questions and Discussion

Jerald O. Thaler, P.E.

Fishbeck, Thompson, Carr & Huber, Inc.

39255 Country Club Drive, Suite B-25

Farmington Hills, MI 48331

[email protected]

248-324-2090


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