Mercury Awareness Training

v.11.2012

Objectives Why it is important Potential impacts to the Tufts HNRCA What Tufts HNRCA has done as corrective

measures thus far What you can do to help Mercury sources

Background Clean Water Act EPA State Deer Island Industry

Tufts MWRA Permit The statewide mercury limit is 0.001 mg/L,

or 1 part per billion (ppb) Tufts HNRCA has violated this limit 5 times

in the past two years, resulting in the current Notice of Noncompliance (NON)

Tufts HNRCA needs to be in compliance by the end of September

Is Tufts Alone? According to the recently published MWRA annual report: Three facilities were fined for Mercury

violations for the 2009 Fiscal Year in the Boston/Cambridge area

− $70,000 − $68,000 − $70,000

What Will Happen? Two options:

1. Fines 2. Install a mercury

treatment system

Penalties/Fines Can be up to $10,000 per day per violation Fines are difficult to negotiate due to the

formal structure Fines are calculated from points assessed

− How far above limit − How much flow − How negligent the facility is

Mercury Treatment Systems Medford Campus Mercury treatment system installed at

Pearson Michael Chemistry Building − Installation cost about $500,000 − Maintenance costs are about $30,000

per year

What Does This Mean For You? Fines and/or a mercury

treatment system means less research money

The amount spent to install the mercury treatment system is equivalent to one lab running for one year!

What Has The HNRCA Done? Working with the MWRA to develop a corrective

action plan

Sampling existing sinks

Reviewing chemical inventories

Replacing piping

Training plan

Diagnostic Testing

Where Are We Now? pH system reagents were replaced with

mercury-free reagents Sinks were sampled Traps were replaced Deliver training Diagnostic sampling will begin once

treatment tanks are cleaned

What You Can Do Managing chemical

inventory Contacting vendors Hazardous waste

management Be diligent!

What Has Happened Elsewhere? Nearby Facility

− All chemical purchases were routed through purchasing

− Mercury products were banned completely

Nearby University − All vendors are required to

certify <0.001 mg/L (1 ppb) for chemicals

− Mercury containing chemicals in higher concentrations are banned

We Don't Want This to Happen Here! Be proactive! Call vendors and

ask for certificates of analysis (COA)

Review COAs and ask for Hg analysis

What Happens if I Need to Use Hg? Tufts does not want you to be limited in

your research. Whenever possible, please use alternate

products or kits. If it is not practical, then Tufts wants you to

be EXTREMELY diligent and follow the hazardous waste disposal procedures

What is Hazardous Waste? EPA

− Listed Waste − Characteristics:

Ignitable (Flashpoint below 140˚F) Corrosive (pH below 2 and above 12.5) Toxic (Fail TCLP Testing) Reactive (unstable compounds capable of violent chemical

change) DO NOT DISPOSE OF CHEMICALS DOWN THE SINK OR IN THE TRASH

• Each site of generation will have a satellite accumulation area (SAA).

•This includes: •Secondary containment •Signage •Labels

Waste Storage (SAA)

• All containers must have a completed hazardous waste label.

•Contain “Hazardous Waste” •Contain Full Chemical Names (No Abbreviations) •Dated when Full •Statement of Hazard

• General names such as “dry waste” must be accompanied by specific chemical names. In addition, original bottle labels do not meet waste labeling requirements.

SAA Management (Labeling)

Waste Pick Up Waste pick-up is needed when:

− The container is old, damaged, bulging, or decomposed

− There is no longer a need for the container

− The container is roughly 80-85% full

Hg Containing or Suspected Hg Containing Chemicals

Chemicals, and first and second rinses should be disposed of into your SAA

Glassware (after rinses) can go into glass washer or be washed in your sink

If you are unsure, err on the side of caution and dispose of the chemical in the SAA

Resources Cheat sheet of suspect chemicals Your chemical vendors TEHS x63615 www.masco.org www.epa.gov/hg/consumer.htm www.sustainablehospitals.org

Suspect Chemicals Cleaning products (often manufactured

using mercury-cell technology) • Alconox (0.07 ppm undiluted) • Bleach (Austin's A-1 and Fisher are okay) • Soft Cide Soap (8.1 ppb) • Cidex ( 1ppm) • Uni-Solve ( 25 ppm)

Fixatives Zenker's Solution B-5 Both contain Mercury (II) Chloride (B-plus fixative may be a reasonable

alternative)

Suspect Chemicals cont'd Hematoxylin (can be prepared with or

without mercury-check with your vendor) Formalin (10% buffered-407 ppm) Thimerosol Phenol Reagent (702 ppm) (Beckman)

Suspect Chemicals cont'd EMD Chemicals Starch Solutions (10-50ppm) RPR Antigen component Protein Conjugates (in solution) Spectroscopy reference solutions Nessler's reagent for NH3 Pepsin reconstitution buffers

Abbott Laboratories − Immunoassay diagnostic reagents − Immunoassay reagents

BD Diagnostic Systems − In-vitro diagnostic reagents

Assay Kits

More chemicals DAB Tris Buffer (Bio Genex Labs) Color reagents for chloride Clinical Diagnostic Chemicals (Abbott Labs) Antigens Acids and bases (reagent grades should be

okay, but check the COA)

Other Mercury-Containing Products • Thermometers • Electrical Switches • Fluorescent Bulbs • Manometers

Going Forward Please check with your chemical manufacturers

about Hg content Please avoid using Hg containing chemicals unless

they are necessary New employees, visiting scholars, and volunteers will

be required to attend this training in addition to the regular new employee orientation

Tufts will conduct ongoing diagnostic sampling to monitor Hg levels in the system

Questions?