&EPA
Mercury:
A Federal Facility Assessment
/X> Recycted/Recydabte
s Printed with Soy/CanoU Ink on papor thai
contacts al least 50% recydod ttwr
-------
Contents
Mercury Assessments:
• Air Force Base
• Portsmouth Naval Shipyard
• New England College
• Environmental Laboratory
Federal Facilities Mercury Questionnaire
Federal Facilities Mercury Log Sheet
-------
&EPA
New England
Massachusetts
Department
ENVIRONMENTAL
PROTECTION
April 5,2001
These case studies represent the culmination of a cooperative effort of the Environmental
Protection Agency New England (EPA NE), Northeast Waste Management Officials'
Association (NEWMOA), Massachusetts Department of Environmental Protection (MA DEP).
and four New England Federal Facilities. The project's purpose was to develop a methodology
to assist Federal Facilities to identify and reduce uses of mercury. Mercury poses a serious threat
to human health and the environment, and is the focus of n'umerous public health, business
assistance, policy, and legislative efforts throughout the New England states.
The Project Team selected four distinct types of operations at which to test our methodology: an
environmental laboratory, an Air Force facility, a Naval facility, and a university setting. These
facilities ranged from a single building to large campuses, which like small towns, included
residences, commercial buildings, office space, medical and dental facilities, elementary schools,
HVAC, metal and wood workshops, power plants, and scientific laboratories.
The Project Team developed a questionnaire and inventory log sheet (included at the end of this
document) to help facilities identify the locations and uses of mercury-containing products as
well as related procurement, management, and disposal procedures. The questionnaire and
inventory were sent to the each facility prior to a site visit by the Project Team. During the site
visit the Project Team viewed firsthand what types of mercury materials are found onsite,
identified purchasing and management practices, and provided some information about
alternatives to mercury products. The case studies were developed to present the results of the
four mercury assessments, the various recommendations made by the Project Team, and the
actions taken by the facilities to address the recommendations. The following outlines some of
the lessons learned from this project.
Lessons Learned
• The process of using the questionnaire and inventory log sheet, and performing an interview
and site visit led to an identification and reduction of mercury at all of the facilities. There
were opportunities for reduction at all facilities; even at facilities that had previously
identified mercury issues as a problem and had taken steps to reduce mercury.
• Federal facilities take mercury in products and their proper disposal seriously. All the
facilities we visited had procedures in place to assure that mercury-containing products were
handled appropriately and had controls for the purchase of hazardous materials, including
those containing mercury. A centralized purchasing system, often called a pharmacy, was
-------
more likely to identify mercury products and non-mercury alternatives than a decentralized
system.
• We did find a few serious situations; mercury spills not being cleaned up properly, staff
uninformed about the danger of mercury exposure, mercury not being carefully stored, and
used fluorescent bulbs disposed in the regular trash.
Take a look through these cases studies. At least one of these facilities will probably have
similar building functions to ones that you have at your federal facility. Your facility can take
action on its own. You do not require a team from the outside to track and reduce mercury at
your facility. You can use the questionnaire and inventory log sheet to identify possible sources
of mercury and use the ideas in the case studies as a starting point for thinking about addressing
any problems that you find. If you have questions, please feel free to call any of the Project
Team members listed below.
Sincerely,
WA-s
Anne Fenn
Federal Facilities Program Manager
EPA New England
(617)918-1805
fenn.anne@epa.gov
Kri Weiss
Mercury Coordinator
EPA New England
(617)918-1568
weiss.jeri@epa.gov
Terri Goldberg
Deputy Director
NEWMOA
(617)367-8558, ext. 302
tgoldberg@newmoa.org
Judy Shope
Mercury Coordinator
MADEP
(617) 292-5597
judy.shope ©state.ma.us
-------
CASE
STUDY
Mercury Assessment »
Air Force Base
Why Should Your Facility Be
Concerned About Mercury?
• Mercury contamination is a serious
environmental and public health
problem. Elemental mercury can
be transformed in the environment
to methyl mercury which is a toxic
and persistent pollutant and
exposure to it may lead to
irreversible neurological effects.
About 60,000 children born each
year in the United States might be
at risk for adverse neurological
effects from in-utero exposure to
methyl mercury, primarily due to
their mothers eating fish during
pregnancy.
• Across New England, more than
80 percent of the inland waters
have fish too polluted with mercury
to eat and all the New England
states have issued health advisories
limiting consumption of certain
freshwater fish.
• Mercury possesses the properties
of both a liquid and a metal, and
is an added component of many
products including fluorescent
lamps and certain types of
thermometers, electrical switches,
and measuring devices.
• Mercury can volatilize at room
temperature enabling it to constantly
circulate in the air, water, and
soil. When spilled mercury is
poured down the drain or a
mercury- containing item is thrown
into the trash, it doesn't disappear.
The mercury enters the circulation
in the environment after it passes
through the waste incinerator,
landfill or wastewater treatment
plant.
Introduction
The project team consisting of federal, state, and interstate representatives
visited a New England Air Force Base to identify the sources and u-r~ .if
mercury-added products at the Base and to learn about the efforts that the
Base has undertaken to reduce or eliminate their reliance on mercury. The
Team met with the Base's Environmental Manager and several members of
the stdft. The Team utilized a mercury management questionnaire to facilitate
discussion ot past and current mercury use at the Base and to the determined
the locations on the Base that were most likely to use mercury-added products.
During the assessment the Team visited the following buildings on the Base:
environmental services, wood shop, metal shop, HVAC shop, energy
management control center, hazardous materials pharmacy, research laboratones,
health clinic, elementary/middle school, and the power plant. This case
study presents the results of this mercury site assessment and recommendations
for additional mercury reduction and controls at this Air Force Base.
Attachment A outlines the measures undertaken by the Base to address the
recommendations.
Facility Overview
Overall awareness of mercury at the Base appears to be high and in general,
the Base has done a considerable amount of work to control and reduce
their use of mercury. The Environmental Services Department receives support
from the base command for its activities, which has produced a strong and
effective environmental program.
The Air Force Base consists of office buildings, research and development
laboratories, a residential community of base personnel, and an elementary/
middle school. Other buildings contain various support shops (e.g. metal,
wood, HVAC), recreation buildings, health clinic, and commercial estab-
lishments. The Base has not supported military aircraft activity since the
1970's, and the airport facilities are no longer within the boundaries of the
military base. The Base receives its water and wastewater services from the
regional authority. There is no on-site wastewater treatment. The Base has
two sewer pump stations and meters and pressure relief valves on the water
supply system.
(
-------
Mercury Reduction Efforts and Current Inventory
The Base has not conducted a base-wide mercury
inventory. However, the quantity of mercury at the
Base was significantly reduced in the 1990's due to
updating and renovation of facilities. Approximately
90 percent of the buildings on the Base have been
renovated since 1993 and therefore, most sources of
mercury have been removed. In addition, as technology
has improved, older mercury-added equipment has
been replaced with state-of-the-art devices that do
not contain mercury. For example, in 1999 two
kilograms of mercury were turned into the hazardous
waste collection system from a diffusion pump that
was converted to oil. Mercury-added materials, such
as chemicals and unused equipment that had
accumulated, were collected and properly disposed
of during the moving and renovation activities.
Support Shops The wood, metal, and HVAC shop
buildings are among the ten percent of the Base's
buildings that have not been recently renovated.
Each shop had a mercury-containing thermostat.
The HVAC shop performs maintenance, repair and
replacement activities associated with the heating,
cooling and ventilation of all buildings. The HVAC
shop reports that they continue to purchase mercury-
containing thermostats for use in residential and
other buildings on the Base that are not serviced by
the central power plant.
Buildings that are not connected to the central plant
have individual oil-fired boilers that tend to have
mercury-containing float switches. When a float
switch needs replacing, the HVAC shop uses mercury-
containing switches because they have had corrosion
problems with electrodes. In addition, HVAC shop
personnel report that there is a mercury-containing
thermometer on the steam and chill line of each boiler.
These thermometers are not Teflon-coated. The HVAC
shop does not purchase thermostats, flow meters, and
thermometers through the HazMat pharmacy. All
mercury-containing devices requiring disposal are
turned into the hazardous waste collection system.
Research Laboratories The research laboratories
underwent a complete mercury audit in 1989, and the
environmental manager of the lab has made a conscious
effort to remove all known, non-essential mercury
sources from the laboratory buildings. This focus on
mercury was prompted when the laboratory manager
noticed that a significant number of mercury-containing
vacuum pumps were being turned in for disposal. All
sink drains in the laboratories have been disconnected
from the wastewater system to ensure that no potentially
harmful material is discharged from the facility. All
HVAC controls are electronic. The only known mercury
in the laboratories are the flourescent light bulbs and
three mercury-containing thermometers that are
required to calibrate equipment.
Health and Dental Clinics The medical/dental clinic
reported that they no longer use any mercury fever
thermometers or blood pressure gauges. However, the
Team did find two mercury-containing thermometers
to monitor minimum and maximum temperature in a
refrigerator. The medical laboratory also has a mercury-
containing reference thermometer that is kept in a
prescribed location. None of these thermometers is
Teflon-coated. The dental clinic uses encapsulated
amalgam and has mercury traps on the rinse drains.
The dental clinic collects excess amalgam and disposes
of it properly.
Elementary/Middle School The elementary/middle
school on the Base is owned and operated by a local
public school system. Approximately four or five
years ago, the school science teacher performed an
inventory and clean-out of hazardous laboratory
chemicals, including mercury. Subsequently, the science
laboratory has instituted micro-scale chemistry to
significantly reduce the quantities of all hazardous
chemicals used. There is a large mercury-containing
barometer/thermometer on the wall in the science
laboratory and two boxes of smaller thermometers,
including approximately ten mercury thermometers.
None of these had physical protection against accidental
breakage or a Teflon coating to prevent the discharge
of mercury in the event of breakage. The school now
has a policy to purchase only non-mercury thermometers.
However, they keep the mercury-containing ther-
mometers that are still useable. The school discards
their flourescent light bulbs in the regular trash which
is not legal under state regulation.
Central Heat Plant and Energy Management
Control Center The central heat plant was
constructed in the 1960s and extensively renovated
-------
in 1988. The central heat plant supplies steam heat
and cooling to approximately 60 of the 98 huildings on
the Base. Generally, the remaining buildings on the
Base have their own oil-fired boilers, and the residential
huildings on the Base are serviced with natural gas.
The central heat plant boilers are fueled by natural
gas and oil. The central heat plant contains several
mercury-containing thermometers and gages. The
central heat plant disposes of their flourescent light
bulbs in with the regular trash which is not legal
under state regulation.
The buildings serviced by the central plant are connected
to an energy management center that controls heating
and cooling to maximize energy efficiency. All flows
are controlled electronically and no mercury-containing
devices are used. In some buildings the control is
limited to whether the heating/cooling is on or off at
a given time, and the building occupants control the
temperature setting locally with a thermostat.
Procurement and Disposal Procedures
The Base established a HazMat pharmacy in 1995 to
reduce the quantity of hazardous materials in storage
and to track the use of hazardous materials used on
the Base. The pharmacy is run as a matrix organization
with affiliated staff in many locations at the Base.
The following summarizes the purchasing process:
• Before ordering, departments on the Base consult
the GSA's "green book" to determine if there is
an environmentally preferable item.
• If no alternative is available, a form to request
the purchase of a potentially-hazardous material
is submitted to the HazMat pharmacy.
• The information is then reviewed for environmental
and biological hazards by the environmental
department. The environmental department
also performs research to determine if a non-
hazardous alternative is available and if so, they
specify it on the order.
• After an item is approved for purchase, it is
delivered to the HazMat pharmacy where a
HazMat label is placed on the product before it is
distributed to the user.
The use of mercury-containing materials is tracked at
the Base under this system.
The Base has a network of 43 hazardous waste satellite
areas, each with a manager and an alternative manager.
These managers and alternative managers receive
training once a year. The Base has a central hazardous
waste storage facility that receives the material from
the 43 accumulation points and controls all hazardous
waste shipments from the Base. Fluorescent light
bulbs from most buildings on the Base are turned into
the hazardous waste accumulation points on a regular
schedule. The bulbs are collected at the accumulation
points every Tuesday and turned into the central
hazardous waste storage area. Fluorescent bulbs are
then sent off the Base for recycling.
Recommendations
The mercury team offers these recommendations for
consideration:
• Conduct a comprehensive base-wide mercury
inventory to capture procurement, uses and waste
streams that are not currently well-documented.
This inventory can serve as a baseline from
which to measure future mercury reduction
efforts. All mercury-containing devices should
be clearly labeled.
• Raise the overall awareness of mercury hazards,
products that contain mercury, and proper disposal
practice through a base-wide educational outreach
or training effort that reaches all employees. In
several instances, employees in the buildings we
visited told the Team that they did not have any
mercury at their facility and then the Team
proceeded to find a mercury-containing device or
illegal fluorescent lamp disposal.
• Expand the HazMat pharmacy to cover mercury-
containing switches, thermostats, thermometers,
and other products.
• Not all purchases come through the HazMat
pharmacy due to Air Force procedures for procuring
different types and classes of material, such as the
use of IMPACT credit card purchasing. The Base
should add a mercury section to the HazMat
training and develop a standard operating procedure
for procurement of mercury-containing equipment.
• The HVAC department and the central heat
plant should discontinue the purchase and use of
mercury-containing thermostats, gauges, and
other devices and switch to their digital alternatives
wherever feasible. Although the upfront cost and
maintenance requirements of non-mercury
alternatives may at first appear significant, when
the lite cycle cost is considered, particularly proper
disposal and the potential for a hazardous spill,
-------
the overall cost of alternatives is significantly
reduced. All remaining mercury-containing
thermostats should be encapsulated to prevent the
release of mercury if they are accidentally broken.
The HVAC department and central heat plant
should receive training on the proper handling of
mercury-containing products, particularly
thermostats, gauges, and measuring devices. The
HVAC department and central heat plant should
also have a mercury spill kit and receive training
on how to use it.
Review the flourescent bulb disposal practices of
each building on the Base and educate all building
managers that it is illegal to throw fluorescent
lamps in the trash. Ensure that the central heat
plant, the elementary/middle school, and any other
building not already doing so, collect their used
fluorescent light bulbs and properly dispose of
them. All building managers should certify that
the collected bulbs are being recycled.
Replace all mercury-containing thermometers
with non-mercury alternatives. Where replacement
is not feasible, all essential mercury-containing
thermometers should be Teflon-coated to protect
against the release of mercury in the event of
accidental breakages.
Mercury traps on dental clinic drains only collect
large particles of mercury. There are amalgam
separators available that can remove both the
solid and suspended mercury from the rinse drains.
The dental clinic should evaluate installation of
these devices.
Replace the barometer/thermometer on the wall
of the science laboratory at the elementary/ middle
school with a non-mercury alternative, or at least
encapsulate it so as to protect against breakage
and release of the mercury.
Expand mercury awareness in the Base community
and provide a greater opportunity for the Base
community to properly discard/recycle mercury-
containing products. Several ideas are: sponsor a
thermometer exchange for employees and residents;
Contacts for More Information
Mercury
Connecticut: Tom Metzner
(860) 424-3242 or tom.metzner@po.state.ct.us
Maine: Ann Pistell
(207) 287-7853 or ann.e.pistell@state.me.us
Massachusetts: Judy Shope
(617) 292-5597 or judy.shope@state.ma.us
New Hampshire: Stephanie D'Agostino
(603) 271-6398 or sdagostino@des.state.nh.us
Rhode Island: Ron Gagnon
(401) 222-6822 or rgagnon@dem.state.ri.us
Vermont: Environmental Assistance Division
(802) 241-3589 or (800) 932-7100
EPA New England: Jeri Weiss
(617) 918-1568 or weissjeri@epa.gov
NEWMOA: Terri Goldberg
(617) 367-8558, ext.303 ortgoldberg@newmoa.org
Federal Facilities Assistance
EPA New England: Anne Fenn
Federal Facilities Program Manager
(617) 918-1805 or fenn.anne@epa.gov
Recyclers/Collectors of
Mercury-Containing Products
www.epa.gov/region01/steward/neeat/mercury/disposal.html
promote bulb recycling to residents and staff by
providing information and appropriate collection
at a convenient location on the Base, such as at
the commissary; and teach the middle school
students about mercury hazards and sources of
mercury and have them conduct a mercury audit
of their homes
Project Team
Anne Fenn, Jeri Weiss and Captain Dongha Yi, EPA
New England; Terri Goldberg and Jennifer Griffith, Northeast
Waste Management Officials' Association (NEWMOA);
Judy Shope, Massachusetts Department of
Environmental Protection (MA DEP)
NEWMOA would like to thank EPA New England for its financial support of this project. The Northeast states provided
in-kind support. NEWMOA, EPA New England, and MA DEP would like to thank the participating federal facilities and
staff for assisting in this important project.
The views expressed in this report do not necessarily reflect those of NEWMOA, NEWMOA member states, or U.S. EPA. Mention of any
company, process, or product name should not be considered an endorsement by NEWMOA. NEWMOA member states, or U.S. EPA.
-------
Attachment A
Facility Response to EPA Visit and Recommendations
The Environmental Services Department appreciates the Assessment and Case Study. Since the Mercury
Assessment, the relationship between the Environmental Services Department and the Air Force has undergone
extensive restructuring. Therefore, they have been unable to devote resources to implementing the recommenda-
tions made in the case study. The Environmental Services Department did meet with building managers to further
educate them on the proper disposal of fluorescent bulbs. Once the restructuring is complete, the Environmental
Services Department plans to develop a strategy to address each of the recommendations.
-------
CASE
STUDY
Why Should Your Facility Be
Concerned About Mercury?
• Mercury contamination is a serious
environmental and public health
problem. Elemental mercury can
be transformed in the environment
to methyl mercury which is a toxic
and persistent pollutant and
exposure to it may lead to
irreversible neurological effects.
About 60,000 children born each
year in the United States might be
at risk for adverse neurological
effects from in-utero exposure to
methyl mercury, primarily due to
their mothers eating fish during
pregnancy.
• Across New England, more than
80 percent of the inland waters
have fish too polluted with mercury
to eat and all the New England
states have issued health advisories
limiting consumption of certain
freshwater fish.
• Mercury possesses the properties
of both a liquid and a metal, and
is an added component of many
products including fluorescent
lamps and certain types of
thermometers, electrical switches,
and measuring devices.
• Mercury can volatilize at room
temperature enabling it to constantly
circulate in the air, water, and
soil. When spilled mercury is
poured down the drain or a
mercury- containing item is thrown
into the trash, it doesn't disappear.
The mercury enters the circulation
in the environment after it passes
through the waste incinerator,
landfill or wastewater treatment
plant.
Mercury Assessment »
Portsmouth Naval Shipyard
Introduction
The project team consisting of federal and interstate representative* vi*ited
Portsmouth Naval Shipyard to identity the source* and u-.es of meruirv-
addecl products at the Shipyard and to research effort-, the Shipyard ha*
undertaken to reduce or eliminate their reliance on mercury. The project
team met with the Shipyard's Environmental Manager, the Pollution
Prevention Program Coordinator, the Mercury Coordinator and other Shipyard
staff members. The Team utilized a mercury' management questionnaire to
facilitate discussion of past and current mercury use at the Shipyard. The
Team also determined the locations at the Shipyard that were most likely to
use mercury-added products. During the assessment the project team visited
the following buildings: Building 72 (power plant), Building 155 (pipe-
shop), Building 240 (metrology calibration laboratory), Building 20 (materials
testing laboratory), Building 300 (tool and machine shop), Building 240
(electrical shop), Building 136 (Defense Reutilization Marketing Office
(DRMO)), Building 337 (hazardous material receiving and storage facility),
Building H-10 (dental clinic) and Building 357 (hazardous waste storage
facility). This case study presents the results of this mercury site assessment
and recommendations for additional mercury reduction and controls at the
Shipyard. Attachment A outlines the measures undertaken by the Shipyard
to address the recommendations.
Facility Overview
Overall, awareness of mercury at the Shipyard is high. Portsmouth Naval
Shipyard repairs and refurbishes nuclear submarines. Contact with mercury
can weaken non-ferrous metals and alloys which can have catastrophic
consequences in the submarine environment. Therefore, the Navy has had
a longstanding Mercury Control Program to identify possible sources of mercury
and reduce their possible contact with the submarines and equipment that is
used on-board. The Shipyard contains many areas and buildings designated
as Mercury Exclusion Areas.
The Shipyard consists of office buildings, laboratories, a power plant, medical
and dental clinics, limited residential housing, and a DRMO that serves the
northeast region. Other buildings contain various functions
necessary to repair Naval Ships such as
pipe repair work, sheet metal work, and
electrical repair. The Shipyard receives
its water and wastewater services from
the local municipal system. The
Shipyard has five wastewater
discharges, and each has an /
NPDES permit.
-------
Mercury Reduction Efforts and Current Inventory
The Shipyard has undertaken extensive mercury
reduction and control activities. The Shipyard has a
written Process Instruction for Mercury Control.
The process instruction covers the purchase, use,
storage, cleanup and disposal of mercury and mercury-
containing materials and components. All new
employees receive general environmental awareness
training that includes information specific to mercury
hazards and management of fluorescent lamps/ In
addition, employees who utilize mercury and those on
the Mercury Spill Team receive detailed mercury-
specific training annually.
The Shipyard conducted an annual Shipyard-wide
mercury inventory from 1958 to 1996. This practice
was discontinued after the 1996 inventory because it
was found to be burdensome, costly or already covered
under other regulation by the NAVSEA Cumbersome
Work Practice Panel. Information about mercury-
containing devices in specific buildings is outlined
below.
Power Plant Mercury-containing devices, such as
flowmeters, pumps, thermometers have all been
removed from the plant. The only mercury noted was
in the thermostat in the plant office, and the fluorescent
bulbs.
Pipe Shop The pipe shop is a Mercury Exclusion
Area. However, the mercury team and the Shipyard's
Environmental Department learned that the new
portable stainless steel waste oil collection tank has a
mercury float switch for overflow detection. There
are nine of these collection tanks at various locations
at the Shipyard. The shop reported that they are
looking into changing out the mercury switch for a
non-mercury switch.
Metrology Calibration Laboratory All precision
mercury-containing thermometers at the Shipyard are
calibrated in this laboratory. Approximately 24
thermometers are calibrated each year, in quantities
of two to six at a time. The Central Tool Crib (Shop
906) is responsible for knowing how many precision
mercury-containing thermometers are at the Shipyard
and to whom they are assigned. The thermometers
are mainly used by the chemistry laboratory (Building
20). Mercury thermometers are stored in a mercury
locker prior to calibration and before shipping to the
user to protect them from breakage.
Materials Testing Laboratory The materials testing
laboratory does not have any elemental mercury.
However, they have precision mercury-containing
thermometers and a quantity of mercuric nitrate
standard that contains 100 parts-per-million of mercury.
These are kept in a mercury storage locker. There is
no inventory, or sign in/out system to keep track of
how many thermometers the laboratory has or who
has them at any given time because the Process
Instruction no longer requires inventories (see the
discussion above in Mercury Reduction Efforts and
Current Inventory introduction). An optical emissions
monitor contains a mercury lamp to keep it aligned
properly.
Tool and Machine Shop The tool and machine
shop has a mercury thermostat on the wall in the
office that is not connected for use. The shop has
three double-door lockers filled with miscellaneous
mercury-containing devices, such as mercury vapor
tubes, mercury relays, and various sizes of fluorescent
bulbs. There is no inventory of locker contents, or
system to keep track of where devices are used at the
Shipyard when they are removed. Shop workers
report that they keep all these mercury devices
because they never know when one will be required
to repair a necessary piece of equipment. However,
the shop has no way to know whether the equipment
for which they are keeping spare parts is at the
Shipyard any longer.
Defense Reutilization Marketing Office (DRMO)
The DRMO does not knowingly accept anything that
contains a hazardous waste. However, personnel at
the Shipyard report that any mercury-containing
devices that are operable are turned into DRMO for
resale. DRMO reports that they do not physically
take custody of hazardous material. DRMO processes
the necessary paperwork and tries to find a buyer for
used products.
Dental Clinic The dental clinic uses self-contained
amalgam capsules and has traps on their rinse drains
The traps are emptied each day and traps are changed
weekly. The collected mercury is accumulated for
recycling. The clinic has mercury thermostats and a
mercury thermometer to monitor temperature in their
sterilizer. The thermometer is not Teflon-coated.
-------
Hazardous Waste Storage Facility The hazardous
waste storage facility opened in August 1996 and is
state-of-the-art. The facility has a special mercury
decontamination room that has not been used in the
last few years. The facility sends approximately
17,000 pounds of fluorescent bulbs out for recycling
each year. The facility also handles some mercury
batteries and, approximately twice a year, a 30 gallon
drum of mercuric/silver nitrate that is produced from
the submarine refurbishing activities.
However, the tracking system is not designed to track
mercury in manufactured products, such as thermometers
an I thermostats. The Shipyard has established a
system to consolidate unused materials and promote
their reuse at the Shipyard. The system reduces the
potential for material to exceed its shelf-life and
become a waste. The system also reduces the need for
satellite hazardous waste storage areas and coordinators.
The system includes pick-up and delivery options to
encourage participation.
Procurement and Disposal Procedures
There are two ways to purchase a hazardous chemical
at the Shipyard: the Job Material List (JML) and the
Credit Card program. Credit card use is limited to
purchases under $2,500. The JML is for purchases
valued at greater than $2,500. The Shipyard has a
screening policy written into its Hazardous Material
Control and Management instruction. Any new
hazardous chemical that has not been used at the
Shipyard in the past must be approved by both the
environmental and OSHA divisions before it can be
ordered. Once a chemical is approved it is listed on
the Shipyard's Authorized Use List (AUL) and can be
reordered without specific approval. In addition,
NAVSEA maintains a list of mercury containing
products and processes that are authorized for use in
mercury exclusion areas and for installation in the
submarines. All such items must be appropriately
identified and labeled.
The Shipyard has a program to purchase environmentally
friendly products. The Shipyard's focus on mercury
includes a standard "mercury clause" that is inserted
into purchasing contracts for items coming in contact
with submarine hardware or supplies. The clause
requires that "Mercury or mercury containing compounds
shall not be intentionally added or come in direct
contact with hardware or supplies under this contract."
The Shipyard's Pollution Prevention Plan has a list of
Targeted Chemicals that are designated for pollution
prevention efforts which includes mercury and mercury
compounds. This designation is considered during
the AUL approval process.
Once ordered and delivered to the Hazardous Materials
Receiving and Storage Facility, the Shipyard uses an
electronic bar code system to identify and track
OSHA-defined hazardous chemicals. Mercury
containing hazardous chemicals are tracked under this
system. The Shipyard maintains a list of all the mercury
containing materials that are at the Shipyard.
xtensive mercury reduction am
ontrol activities/The Shipyard
written Process Instruction
Waste mercury items that cannot be reused, including
mercury-added manufactured items, are labeled and
brought to the individual Hazardous Waste Accumulation
Areas where they are then shipped to the Hazardous
Waste Storage Facility. Mercury-added manufactured
products that remain operable are not handled as
hazardous waste and are turned into the DRMO. All
batteries are collected and handled as a hazardous
waste. The Shipyard has contracted out fluorescent
bulb management services and they are collected and
managed as a hazardous waste. The contract mandates
that the bulbs be recycled.
Recommendations
The project team offers these recommendations for
consideration:
• Establish an inventory of thermometers at the
Materials Testing Laboratory and a sign-in/sign-
out system to keep track of how many thermometers
are at the laboratory and who has them at any
given time
• Establish an inventory of the mercury-containing
items at the Tool and Machine Shop and a sign-
out system to keep track of where the items are
used at the Shipyard. Determine if the various
-------
machinery for which the Tool and Machine
Shop is keeping spare parts currently exists at the
Shipyard and properly dispose of all spare parts
tor which there is no possible need.
• Determine the location of all mercury-containing
manufactured products, such as thermostats, and
replace them with digital alternatives wherever
feasible. Remove and recycle or dispose of any
used items. All remaining mercury-containing
manufactured products should be clearly labeled,
inventoried, and tracked. Wherever feasible,
these items should be encapsulated to prevent the
release of mercury if they are accidentally broken.
• Include mercury-added manufactured products
such as switches, thermostats, and thermometers
in the hazardous materials procurement system
so their purchase and use at the Shipyard is
minimized and tracked.
• Change-out the mercury float switches for non-
mercury switches in the portable stainless steel
waste oil collection tanks. Place a mercury
identification label on the tanks that continue to
have mercury switches.
• Replace all mercury-containing thermometers with
non-mercury alternatives. Where replacement is not
feasible, all essential mercury-containing thermome-
ters should be Teflon-coated to protect against the
release of mercury from accidental breakage.
• Mercury traps on dental clinic drains only collect
large particles of mercury. Amalgam separators
are available that can remove both the solid and
suspended mercury from the rinse drains. The dental
clinic should evaluate installation of these devices.
Contacts for More Information
Mercury
Connecticut: Tom Metzner
(860) 424-3242 or torn.metzner@po.state.ct.us
Maine: Ann Pistell
(207) 287-7853 or ann.e.pistell@state.me.us
Massachusetts: Judy Shope
(617) 292-5597 orjudy.shope@state.ma.us
New Hampshire: Stephanie D'Agostino
(603) 271-6398 or sdagostino@des.state.nh.us
Rhode Island: Ron Gagnon
(401) 222-6822 or rgagnon@dem.state.ri.us
Vermont: Environmental Assistance Division
(802) 241-3589 or (800) 932-7100
EPA New England: Jen Weiss
(617) 918-1568 or weissjeri@epa.gov
NEWMOA: Terri Goldberg
(617) 367-8558, ext.303 or tgoldberg@newmoa.org
Federal Facilities Assistance
EPA New England: Anne Fenn
Federal Facilities Program Manager
(617) 918-1805 or fenn.anne@epa.gov
Recyclers/Collectors of
Mercury-Containing Products
www.epa.gov/region01/steward/neeat/mercury/disposal.htjnl
Project Team
Anne Fenn, Jeri Weiss and Captain Dongha Yi, EPA
New England; Terri Goldberg and Jennifer Griffith, Northeast
Waste Management Officials' Association (NEWMOA)
NEWMOA would like to thank EPA New England for its financial support of this project. The Northeast states provided
in-kind support. NEWMOA. EPA New England, and MA DEP would like to thank the participating federal facilities and
staff for assisting in this important project.
' A copy of the Process Instruction for Mercury Control can be obtained by contacting Jennifer Griffith at NEWMOA at
(617) 367-8558 orjgriffith@newmoa.org.
^ Example mercury training bulletins on are available on NEWMOA's website: www.newmoa.org.
3 The list is included as Enclosure 1.10.1.1 in the Process Instruction for Mercury Control and is also available on NEWMOA's
website: www.newmoa.org.
The views expressed in this report do not necessarily reflect those of NEWMOA. NEWMOA member stales, or U.S. EPA. Mention of any
company, process, or product name should not be considered an endorsement by NEWMOA, NEWMOA member states, or U.S. EPA.
-------
Attachment A
Facility Response to EPA Visit and Recommendations
As a result of the Mercury Assessment, Portsmouth Naval Shipyard has undertaken several efforts to implement the
recommendations made in the case study. The following measures have been completed or are planned:
• The Materials Testing Laboratory conducted a comprehensive inventory of mercury thermometers. 35 percent
of the original inventory has been disposed of as a hazardous waste. Some ASTM test procedures now permit
the use of digital thermometers, so the laboratory should be able to reduce the number of thermometers to six
(an 80 percent reduction from April 2000). Teflon coated mercury thermometers will replace the remaining
thermometers when they come due for calibration.
• The Tool and Machine Shop established an inventory of the mercury containing items in storage.
Approximately one-third of the items observed in April 2000 have been removed for disposal. The remaining
items have confirmed uses.
• The mercury thermometer at the dental clinic has been replaced with a non-mercury thermometer.
• The Shipyard has contacted a manufacturer of mercury removal systems for the dental clinic wastewater.
Drop-in replacements for the current mercury traps at the chairs are not available. The Environmental
Division has established a request to have a mercury removal system placed in the basement of Building H-10
(dental clinic) to collect mercury that goes through the mercury traps at the chairs.
• For demolition and renovation projects, the standard contract specification language currently specifies that
mercury containing lamps must be handled as a hazardous waste. The Shipyard plans broaden the scope of the
specification to include other mercury containing items such as thermostats.
• The Shipyard plans to specify the use of low mercury fluorescent bulbs when relamping or renovating.
• The Shipyard is studying potential new requirements for design contractors that would prohibit specifying
mercury-containing items, such as thermostats.
-------
CAS
STUDY
Why Should Your Facility Be
Concerned About Mercury?
• Mercury contamination is a serious
environmental and public health
problem. Elemental mercury can
be transformed in the environment
to methyl mercury which is a toxic
and persistent pollutant and
exposure to it may lead to
irreversible neurological effects.
About 60,000 children born each
year in the United States might be
at risk for adverse neurological
effects from in-utero exposure to
methyl mercury, primarily due to
their mothers eating fish during
pregnancy.
• Across New England, more than
80 percent of the inland waters
have fish too polluted with mercury
to eat and all the New England
states have issued health advisories
limiting consumption of certain
freshwater fish.
• Mercury possesses the properties
of both a liquid and a metal, and
is an added component of many
products including fluorescent
lamps and certain types of
thermometers, electrical switches,
and measuring devices.
• Mercury can volatilize at room
temperature enabling it to constantly
circulate in the air, water, and
soil. When spilled mercury is
poured down the drain or a
mercury- containing item is thrown
into the trash, it doesn't disappear.
The mercury enters the circulation
in the environment after it passes
through the waste incinerator,
landfill or wastewater treatment
plant.
Mercury Assessment »
New England College
Introduction
The project team consisting ot Federal, state, and interstate representatives
visited n New England College to identity the sources and uses ot mercurv-
added products at the College and to suggest efforts the College might
undertake to reduce or eliminate their reliance on mercury. The projeu
team met with the College's Facilities Engineering Division Chief,
Environment,il Branch Chief, and other members of the staff. The Team
utilized a mercury management questionnaire to facilitate discussion ot p.ist
and current mercury use" at the College. The Team also determined the
locations at the College that were most likely to use mercury-added products.
During the site assessment the project team visited the following buildings:
chemistry and physics laboratories, medical and dental clinic, soils laboratory,
power laboratory, metals lahoratory, electrical laboratory, waterfront area,
simulation lahoratory, garage, boiler plant, huilding and grounds, carpenters
shop, electrical maintenance shop, plumbing and heating shop, paint shop,
and the public works huilding. This case study presents the results of this
mercury site assessment and recommendations for additional mercury' reduction
and controls at the College. Attachment A outlines the measures undertaken
by the College to address the recommendations.
Facility Overview
Prior to preparing tor the Team's visit, overall awareness of mercury at the
College seemed to be low. According to the Environmental Branch, the
mercury assessment effort has significantly raised mercury awareness at the
College. The College is an institution of higher education, and therefore
consists mainly of dormitory and classroom buildings, teaching laboratories,
and academic and administrative offices. There are also numerous support
buildings, such as the boiler plant, the medical and dental clinic, and the
waterfront marina area. The College receives its water and wastewater
services from the local municipal system.
(
-------
Mercury Reduction Efforts and Current Inventory
Prior to the Team's visit, the College had not focused
on any mercury reduction activities. To prepare for the
Team's visit, the Environmental Branch distributed the
EPA mercury survey to all departments at the College.
The Environmental Branch compiled the results of the
survey into a preliminary inventory of mercury at the
College. In response to the survey, several shops and
laboratories expressed an interest in having mercury-
containing items, primarily thermometers, removed.
The College does have a program in place to collect
used fluorescent bulbs and send them for recycling.
Efforts to raise awareness of proper fluorescent bulb
management procedures appear to be significant.
Information about mercury-containing devices observed
by the Team in specific buildings is outlined below.
Chemistry and Physics Laboratories The Team
visited three laboratories in the main classroom/
laboratory building where mercury-containing products
were found: chemistry, organic chemistry, and physics.
Center Preparation Room: The center preparation
(prep) room in the chemistry laboratory is used to
store the chemicals and equipment used by students
in their experiments. The prep room services the
adjoining laboratory classrooms. Students are not
allowed in the prep room. The prep room contains
about 50 different elements and compounds, with
many stored in glass bottles on open metal shelves.
There are two locked flammable liquid storage lockers
in the room and an adjacent locked chemical storage
room that contain about 950 compounds. Many of
the chemicals in the storage room and lockers had
masking tape around the cap with a 1990 date on it,
indicating that the containers had not been opened
since that date. The laboratory technician stated that
many of the stored elements and compounds are not
currently used at the laboratory. They have not been
removed because the laboratory might need them in
the future and also because the laboratory did not
want to incur hazardous waste disposal costs. The
laboratory technician performs a detailed inventory of
all the containers each summer.
Specific to mercury, the prep room contains 93
pounds of elemental mercury in several containers on
the fourth shelf up on an open shelving unit. Most of
the containers are plastic, but one is plastic-coated
glass and another is ceramic. The prep room also
contains several mercury-containing compounds at
various concentrations and in various quantities. There
were two glass manometers high up on top of one of the
open metal shelving units and the Team estimated that
each contains over 10 pounds of elemental mercury.
The prep room also contains over 75 large mercury
thermometers of various types that are stored upright in
a wooden box with dividers to segregate them by size.
This box is located on top of a small refrigerator that
has floor drains located on either side.
The laboratory technician stated that each semester
the students break between five and ten thermometers
in the laboratory classroom. The laboratory supervisor
has a policy that broken thermometers are replaced
with alcohol thermometers. The chemistry laboratory
classroom has a large elemental mercury-containing
barometer that is relatively well encapsulated.
While the Team was in the prep room, a mercury spill
occurred. The laboratory technician was showing the
Team a piece of equipment, a mercury cleanup vacuum
(that is no longer used) when several drops of elemental
mercury fell from it onto the metal shelf. The laboratory
technician used a suction bulb in an attempt to retrieve
the mercury and put it in a small bottle that contained
mercury collected from other mercury spills. The
laboratory technician reported that the same spill
response method is used to retrieve the mercury released
when thermometers are broken in the classroom.
Organic Chemistry Laboratory: The organic chemistry
laboratory had 15 to 20 additional mercury thermometers.
Most of the thermometers were stored loose in a drawer.
Some thermometers were stored in cardboard packaging.
General Chemistry Laboratory: The general chemistry
laboratory contains two of the large elemental mercury-
containing barometers. The lab also utilizes a mercury-
containing gage to measure vacuum.
Physics Laboratory: The physics laboratory has two of
the large elemental-mercury containing barometers. The
laboratory also has a mercury-containing device that was
used in an x-ray experiment that is no longer performed.
-------
Medical and Dental Clinic The medical clinic uses
non-mercury blood pressure gages and fever ther-
mometers. Both clinics use x-ray developer and fixer
that could contain mercury, although the MSDS's do
not list mercury as a constituent. There are small
mercury thermometers in the medical laboratory's
refrigerator and freezer for calibration. However, the
laboratory' plans to purchase non-mercury calibration
thermometers when the existing ones are changed-out.
The incubator already has a non-mercury calibration
thermometer. The dental clinic uses amalgam capsules
and has mercury traps on the rinse drains.
Soils Laboratory The soils laboratory had 16 mercury
thermometers lying together on an open shelf. The
laboratory technician indicated that the mercury ther-
mometers are not needed and that the Environmental
Branch could remove them. The soils laboratory did
not appear to have other mercury-containing items.
Power Laboratory The power laboratory had three
mercury thermometers that the laboratory technician
indicated were not needed and could be removed by
the Environmental Branch. Other than the three
thermometers, the laboratory did not appear to have
other mercury-containing products.
Metals Laboratory The metals laboratory had ten
mercury thermometers that the laboratory technician
indicated were not used and could be removed by the
Environmental Branch. The laboratory technician
uses a digital thermometer, which he prefers.
Waterfront The waterfront marina area had no read-
ily-apparent mercury-containing products. However,
several hard to observe items could contain mercury,
including bilge pump switches, marine auto-pilot
controls, and safety cut-off switches in outboard motors.
In addition, the waterfront stores and uses batteries of
all types, including some that contain mercury.
Simulation Laboratory The simulation laboratory
houses various in-the-field simulation rooms and their
associated classrooms. The laboratory manager
reported that there are four pre-1986 model HVAC
systems on the roof of the building that could utilize
mercury-containing flow control switches and pressure
gages. There are two mercury thermostats in the
radar room and one in the area known as 1CS 1.
Garage The vehicle maintenance garage has a sump
pump and an overflow alarm switch on the oil-water
separator that are most-likely controlled by a mercury
tilt switch. However, the Team was unable to visually
inspect these devices. The vehicles used at the College
are leased and contain anti-lock brake system (ABS)
brakes and trunk light control switches that could
contain mercury.
Boiler Plant The boiler plant has replaced most of its
mercury switches and gages. However, the plant has
17 mercury-containing pressure switches and flow
controllers. Boiler plant personnel report that they plan
to replace most of those, with the exception of six
mercury-containing low water cut-off pump controllers
for which they have not found an acceptable substitute.
Plumbing and Heating Shop Facility personnel
report that mercury thermostats are still used in the
command's housing quarters and they had one spare
thermostat in their inventory. Personnel also reported
that the sewage pump station has two mercury float
switches that will be replaced with a non-mercury
alternative.
Public Works Building A portion of the public
works building serves as a new bulb storage area and
used fluorescent bulb collection area. The door to
the storage and collection area is locked. There were
numerous new mercury-containing lamps of several
different types in storage, including mercury, mercury
vapor, and high intensity discharge (HID). The
Team noted two broken fluorescent bulbs in a trash
barrel outside the locked room.
Procurement and Disposal Procedures
Anyone wanting to purchase a hazardous material
that is not on their shop/laboratory's Authorized
Hazardous Material Inventory must fill out a New
Product Request form and submit it, along with the
MSDS, to the Environmental Branch for approval
before it can be ordered. Where possible, the
Environmental Branch suggests alternative products
that are more environmentally friendly. Once a product
is approved it is listed on that shop/laboratory's
Authorized Hazardous Materials Inventory and can be
reordered by that shop/laboratory without specific
-------
approval. However, all shops and laboratories have
government credit cards on which they can make
independent purchases of less than $2,500.
The College is about to begin a pilot program between
the Waterfront area and a nearby Department of
Defense (DOD) installation to consolidate unused
materials and promote their reuse, known in the Navy
as the Consolidated Hazardous Material Reutilization
Inventory Management Program (CHR1MP). All
material at the Waterfront will be inventoried and bar
coded. When a hazardous material is needed at the
waterfront, they will order it from the CHR1MP facility
at the DOD installation. After use, the unused portion
is sent to the CHRIMP facility at the DOD installation.
CHRIMP reduces the potential for a material to exceed
its shelf-life and become a waste. If the Waterfront
pilot program is successful, the College plans to expand
CHRIMP to encompass the entire facility.
Waste mercury-containing items, including mercury-
added manufactured items, are collected and handled
as a hazardous waste. The College has approximately
30 satellite hazardous waste accumulation areas.
Hazardous Material Coordinators at each location
ensure that hazardous materials and waste are handled
properly. The College collects and manages fluorescent
bulbs as a hazardous waste. The bulbs are recycled.
Recommendations
The project team offers these recommendations for
consideration:
• Establish an overall mercury use and management
policy for the College, including:
Establish a mercury team at the College and
develop a written mercury spill protocol with
clear lines of responsibility. Mercury spill reporting
should be centralized to document trends in the
location and number of spills, and the quantity of
mercury involved. Mercury spill kits should be
distributed to all locations that use mercury or
have mercury-containing products. The spill
response designee(s) at each location should be
trained on the proper use of the kit, and to
record and report all spills.
Develop a standard operating procedure for
procurement of mercury-containing materials and
equipment, including credit card purchases. Include
mercury-added manufactured products, such as
switches, thermostats, and thermometers in the
hazardous materials procurement system so their
purchase and use is identified, minimized, and
tracked.
All unused mercury-containing products should
be retired and properly disposed of, rather than
sent for possible reuse.
Expand overall mercury awareness at the College
and provide ,. greater opportunity for the College
community to properly discard/recycle mercury-
containing products. Potential methods are to:
widely publicize the environmental and health
effects of mercury, and the mercury reduction
efforts that occur at the College; sponsor a fever
thermometer exchange for students and employees;
investigate the feasibility of using cleaning products
that do not contain heavy metals; and investigate
the Thermostat Recycling Corporation (TRC)
take-back program and participate, if eligible.
The chemistry laboratory could constitute an
imminent and substantial hazard. The College
should perform a thorough clean-out of the
chemistry laboratory's prep room and associated
classrooms:
The hazardous materials stored in the prep room
could be a potential liability. The College should
identify the hazardous materials that are utilized
by the classroom experiments and other research
and remove and properly dispose of all unnecessary
items. Use best management practices to minimize
the potential for breakage and spills. For example,
wherever feasible, chemicals should not be stored
on open shelves or in breakable containers.
Evaluate the prep room and associated laboratory
classrooms for residual mercury contamination
and decontaminate, as necessary. This effort
should extend to the various sink drain traps and
floor drains located in those rooms.
Replace all mercury-containing thermometers
with non-mercury alternatives. Where replacement
is not feasible, all essential mercury-containing
thermometers should be Teflon-coated to protect
against the release of mercury in the event of
accidental breakages. All thermometers should
be stored in a secure location and in a manner
that minimizes the potential for breakage. Each
location that uses mercury thermometers should
establish an inventory and a sign-in/sign-out system
to keep track of the total number of thermometers
and who has them at any given time.
-------
• Determine the location of all mercury-containing
manufactured products, such as thermostats, barom-
eters, and switches, and replace them with digital
alternatives wherever feasible. Remove and recycle
or dispose of any used items. All remaining mercury-
containing manufactured products should be clearly
labeled, inventoried, and tracked. Wherever feasible,
these items should be encapsulated to prevent the
release of mercury if they are accidentally broken.
• Evaluate lighting needs to determine if the purchase
and storage of mercury-containing lamps/bulbs
can be reduced.
• Provide greater access to the used fluorescent
bulb collection area to minimize their placement
in nearby trash receptacles.
• Mercury traps on dental clinic drains only collect
large particles of mercury. There are amalgam
separators available that can remove both the solid
and suspended mercury from the rinse drains. The
dental clinic should evaluate installation of these
devices.
• Replace the barometers in chemistry and physics
laboratories with non-mercury alternatives, or
fully encapsulate them to protect against breakage
and release of the mercury.
Project Team
Anne Fenn and Jeri Weiss, EPA New England; Judy Shope,
Massachusetts Department of Environmental
Protection (MA DEP); and Jennifer Griffith, Northeast
Waste Management Officials' Association (NEWMOA)
Contacts for More Information
Mercury
Connecticut: Tom Metzner
(860) 424-3242 or tom.metzner@po.state.ct.us
Maine: Ann Pistell
(207) 287-7853 or ann.e.pistell@state.me.us
Massachusetts: Judy Shope
(617) 292-5597 orjudy.shope@state.ma.us
New Hampshire: Stephanie D'Agostino
(603) 271-6398 or sdagostino@des.state.nh.us
Rhode Island: Ron Gagnon
(401) 222-6822 or rgagnon@dem.state.ri.us
Vermont: Environmental Assistance Division
(802) 241-3589 or (800) 932-7100
EPA New England: Jeri Weiss
(617) 918-1568 or weiss.jeri@epa.gov
NEWMOA: Jerri Goldberg
(617) 367-8558, ext.303 or tgoldberg@newmoa.org
Federal Facilities Assistance
EPA New England: Anne Fenn
Federal Facilities Program Manager
(617) 918-1805 orfenn.anne@epa.gov
Recyclers/Collectors of
Mercury-Containing Products
www.epa.gov/region01/steward/neeat/mercury/disposal.html
NEWMOA would like to thank EPA New Englandor its financial support of this project. The Northeast states provided in-kind
support. NEWMOA, EPA New Englandand MA DEP would like to thank the participating federal facilities and staff for
assisting in this important project.
The views expressed in this report do not necessarily reflect (hose of NEWMOA. NEWMOA member stales, or U.S. EPA. Mention of any
company, process, or product name should not be considered an endorsement by NEWMOA. NEWMOA member states, or U.S. EPA.
-------
Attachment A
Facility Response to EPA Visit and Recommendations
As a result of the Mercury Assessment, the College has undertaken several efforts to implement the recommenda-
tions made in the case study. The following measures have heen completed or are planned:
• Approximately 2^0 pounds of elemental mercury and 45 pounds of mercury-containing items have heen
removed from the chemistry laboratory and sent tor recycling, including the manometers and the mercury from
spill cleanups.
• 108 mercury thermometers have heen removed from the chemistry laboratories and sent for recycling. 60 non-
mercury replacements were purchased to eliminate mercury thermometers from the chemistry laboratories. The
remaining mercury thermomerers were moved away from the floor drains and into the locked storage room.
• The 16 thermometers from the soils laboratory, the 10 from the metals laboratory and the 3 from the power
laboratory have been sent for recycling. An additional 14 thermometers from the marine science department
and 4 from the clinic were also sent for recycling.
• Air monitoring tor mercury vapor was conducted in the chemistry laboratory, including inside sink and floor
drains, cabinets, and drawers. All levels were non-detect or otherwise below Occupational Safety and Health
Administration (OSHA) and American Conference of Governmental Industrial Hygienists (ACGIH) standards
for mercury vapor with the exception of a floor area of approximately 300 square foot and some shelves. The
College hired a cleanup contractor that decontaminated these areas in August 2000. Mercury vapor was not
detected with a Jerome meter after the cleanup was completed.
• The spent fluorescent bulb collection area has been relocated to an accessible area. A newsletter focused on
proper fluorescent bulb management and disposal procedures was distributed to all hazardous material coordina-
tors and building managers.
• Mercury spill kits were purchased and the Environmental Branch updated the College's Spill Response
Procedures to include mercury spills. In addition, during their annual hazwaste management training, all
Hazardous Material Coordinators will be reminded that mercury spills are reportable to the Spill Response Team.
The Chemistry Lab technician was provided with a mercury spill kit and trained on proper cleanup procedures,
including the requirement to report mercury spills to the Spill Response Team.
• The Environmental Branch is working with the various support shops to determine which items contain mer-
cury and if there are suitable non-mercury alternatives available. In August 2000, support personnel received
training on the importance of properly disposing of mercury-containing items and purchasing non-mercury prod-
ucts. The Environmental Branch has also developed stickers that say "Contains Mercury" that were distributed
at the staff training.
• The Chemistry Department no longer stocks mercury-containing compounds. They will only purchase such
compounds on an amount needed basis per use. The use of mercury containing compounds is projected to be
extremely small (less than one use per year, and in milligram amounts). The Environmental Branch disposed of
all ot the mercury-containing compounds that the Chemistry Department had in stock.
• The chemistry laboratory installed a barrier around each barometer to protect them from breakage.
• The two mercury-containing barometers in the physics laboratory have been removed and shipped for recy-
cling.
• The dental clinic is investigating the feasibility of installing a treatment system to remove mercury from the
rinse sink wastewater.
• Four Teflon-coated sling psychrometers were purchased for the marine science section.
-------
Why Should Your Facility Be
Concerned About Mercury?
• Mercury contamination is a serious
environmental and public health
problem. Elemental mercury can
be transformed in the environment
to methyl mercury which is a toxic
and persistent pollutant and
exposure to it may lead to
irreversible neurological effects.
About 60,000 children born each
year in the United States might be
at risk for adverse neurological
effects from in-utero exposure to
methyl mercury, primarily due to
their mothers eating fish during
pregnancy.
• Across New England, more than
80 percent of the inland waters
have fish too polluted with mercury
to eat and all the New England
states have issued health advisories
limiting consumption of certain
freshwater fish.
• Mercury possesses the properties
of both a liquid and a metal, and
is an added component of many
products including fluorescent
lamps and certain types of
thermometers, electrical switches,
and measuring devices.
• Mercury can volatilize at room
temperature enabling it to constantly
circulate in the air, water, and
soil. When spilled mercury is
poured down the drain or a
mercury- containing item is thrown
into the trash, it doesn't disappear.
The mercury enters the circulation
in the environment after it passes
through the waste incinerator,
landfill or wastewater treatment
plant.
Mercury Assessment »
Environmental Laboratory
Introduction
The project team consisting ot Federal, state and interstate representatives
visited a laboratory associated with a tederal agency to (1) test out the effec-
tiveness ot a draft mercury inventory and management questionnaire; (2)
understand the use of mercury-added products at the facility, and O) learn
about the efforts that the laboratory had undergone to comply with mercury
discharge limits and to reduce their reliance on mercury-added products.
The project team met with, the laboratory's senior management, the supervi-
sors and team leaders ot the vanou-- sections ot the laboratory, the facility
manager, and the environmental health and safety official at the facility. The
facility representatives explained the history of compliance-related mercury
controls at the lab, the lay out of the facility, and their preliminary mercury
assessments. This case study presents the results of this mercury site assess-
ment and recommendations for additional mercury controls for the facihtv.
Facility Overview
The following types of laboratories and rooms were reviewed during the site visit:
• Preparatory lab - prepares soil and water samples
• Screening lab - extracts contaminants from the samples
• Wet lab - conducts biological analysis of water samples
• Ambient air monitoring lab - analyzes air samples
• Dish room - area for cleaning and washing glassware
• Sample receipt and storage room - incoming sample receipt/excess
ot samples declare as waste
• Mechanical calibration room - field sampling equipment
and air sampling equipment
• Microbiology laboratory - processing of field
water samples, fecal pathogen analysis
• Technicon laboratory - metals and mercury
analysis field samples
• Hazardous waste storage shed -
central storage area for hazardous
waste materials storage
-------
History of Compliance-Related
Mercury Controls at the Laboratory
Starting approximately ten years ago, the laboratory
found mercury in the sludge that was accumulating in
the facility's acid neutralization tank. To determine
the source of the mercury, the facility analyzed the
influent wastewater to this tank and found that it con-
tained levels of mercury that on occasion exceeded
the facility's wastewater discharge limit. To address
this problem the laboratory cleaned the tank, flushed
the laboratory wastewater piping system with trisodium
phosphate and cleaned sink traps. All material was
collected and disposed of as hazardous waste. Neither
of these measures produced results that made the
management of the laboratory confident that the
laboratory would be able to consistently meet their
mercury discharge limit. They still had sporadic
mercury levels more than one part per billion (ppb).
At that time, the laboratory decided to discontinue
the use of their wastewater discharge system, disconnect
the traps in the pipes, and install another wastewater
system. Around this time the lab also instituted a water
conservation program to minimize their use of water
and reduce their discharge. The new wastewater system
was operated in a batch mode, with all laboratory
wastewater being collected and tested prior to discharge.
At the beginning of 1999, the laboratory changed
their wastewater operations again, and began to drum
all of the laboratory wastewater and ship it out since
the facility found that the cost of doing the batch
testing exceeded the cost of hazardous waste disposal.
The wastewater was classified as a nonhazardous
waste and shipped out on a hazardous waste manifest
with the Massachusetts Waste Code - MA99 ( Non-
Hazardous waste). Therefore, no laboratory wastewater
is currently being discharged.
In addition to working on improving their wastewater
discharge, the laboratory initiated a program to
reduce the number of mercury thermometers and other
mercury devices present in the lab. They collected all
thermometers not in use or used infrequently and
stored them under lock and key. They have also been
collecting batteries for recycling. The Laboratory has
collected all of the old mercury switch thermostats
and replaced them with H/P electronic thermostats.
Flourescent light bulbs are recycled by the lessor
through a local waste recycling firm.
Current Inventory
The management of the facility conducted a quick
audit of mercury-related products in the laboratories
prior to the site assessment by the project team. They
found that the lab still has a large barometer; about a
dozen mercury-added thermometers, including a large
thermometer that is used to calibrate the accuracy of
thermometers used throughout the laboratory; and
mercury lamps that are used in the atomic absorption
spectrometer, the mercury vapor analyzer (Jerome
Meter) and the Tekran field analyzer. The lab has
ordered a plexiglass shelter for the barometer to help
prevent breakage.
The large thermometer is required by the National
Institute for Standards and Testing for calibrating
other thermometers. The lab has six incubators, all
of which require a mercury thermometer. The mercury
thermometers are accurate to a tenth of a degree,
whereas the alcohol thermometers are not as sensitive.
The incubators have a high degree of temperature
sensitivity. The lab has replaced all of the refrigerator
thermometers with alcohol units. There is one mercury
thermometer that is still used in a drying oven. The
lab also keeps a few spare thermometers in case they
need to replace one. The lab has purchased teflon
coated thermometers to prevent the mercury from
dispersing if the unit is broken. The project team did
find a mercury thermometer in the facilities hazardous
waste storage shed of which the laboratory was not aware.
The lab has a Coulter counter that includes a mercury
manometer. This unit has 157 grams of mercury. It is
used for counting algal cells. In one to two years,
Coulter will be phasing out the mercury manometer in
these units. When they make this change the company
will no longer service the older models. At that time
the lab will probably switch to the non-mercury unit.
The only mercury compound that the lab has a 200
ml container of mercury salts. There is also a small
amount, 15-20 ml, of elemental mercury used as a
standard for calibrating the Jerome Meter. This mercury
is stored in a thermos and is locked up. The facility
used to have some mercuric chloride in their inventory,
but they have removed these materials from the site.
-------
The facility collects all batteries and recycles them
through a contractor. The building owner collects
the fluorescent lamps and they are sent to a recycler.
They fill up a box that can hold 85 bulbs approxi-
mately every 4 months. The laboratory rents the
building and they have limited control over the
selection of light bulbs and thermostat switches. The
facility uses a contractor for cleaning, and they use
their own cleaning products.
The outdoor lighting includes 6,400-watt mercury
vapor flood lights on top of the building. Above the
doorways, there are 100 watt mercury vapor lights.
Above the loading dock doors, they have 150 watt
high pressure sodium lamps. Above the boat room
doors they have 500 watt quartz bulbs. In front of the
building, there are 175 watt mercury vapor down
lights. Above the doorway on top of the chemical
shed is a 150 watt high pressure sodium bulb. All
outside lights are controlled by a light sensor to turn
lights on and off.
There are thermocouples in use in a biology walk-in
chamber associated with the wet laboratory and in
the air calibration laboratory in the ambient air
monitoring laboratory.
Procurement Procedures
After a laboratory supervisor has signed off on a
chemical purchase, the laboratory's health and safety
officer reviews all of the new proposals for chemical
purchases. He evaluates them for safety and examines
potentially safer and less toxic alternatives. The officer
reviews the toxicity of all new chemicals and, if they
are toxic, he reviews P2 alternatives or safer substitutes.
If he does not sign-off on the purchase of a chemical,
the materials cannot be ordered. After the health and
safety sign-off the lab manager may also need to
review and approve the purchase. The lab has
removed many hazardous chemicals, such as mercuric
chloride and Nesler's reagant through this approval
system. The lab has established a bar coding system
for keeping track of its chemical inventory and for
keeping track of the chemical as it is used. They
have made an effort to reduce excessive packaging and
overstocking in the liquid and dry chemical storage
areas. The lab is audited once every two years for
environmental compliance.
For purchasing equipment, the health and safety
officer reviews all Material Safety Data Sheets. He
works hard to minimize the lab's inventory of equipment
and materials. If the MSDS indicates that there is
mercury in a product, the facility staff automatically
evaluate whether to purchase it. These efforts have
helped the lab to eliminate its problems with overstocks
of products and chemicals.
This laboratory has m,
an extensive effort in the pa
to eliminate their wastewate
discharges to help them
mee then j , 'rm/i limit.
The laboratory has instituted microscale chemistry-
techniques where they are feasible and allowed under
standard laboratory procedures. They are also mini-
mizing the volume of the samples they collect and
analyze in the lab. The facility staff also use portable
analytical devices to test soil/water/biota/air in the field.
The laboratory has conducted training for its staff to
review pertinent information on chemical health and
safety.
The laboratory uses a certified hazardous waste hauler
to pick up and dispose of the hazardous waste generated
and managed by the facility. From June 1, 1998
through June 30, 1999, the laboratory produced
147.59 pounds (66.936 kg) of soil with mercury levels
greater than 0.2 parts per million (ppm) of mercury.
If all the soils contained mercury at twice the 0.2 ppm
action level, the total amount of mercury would by
5.894 x 10'^ pounds. The laboratory also disposes of
mercuric chloride solutions from the standards
preparation and use. These standards have a maximum
amount of 200 parts per billion (ppb). During this
same period, June 1, 1998 to June 30, 1999, 41 pounds
(18.597 kg) of solution was disposed accounting for a
maximum amount of 8.199 x 10'^ pounds of mercuric
chloride. This does not include any one-time disposal
of mercury containing products, including thermostats
and thermometers.
-------
Recommendations
This laboratory has made an extensive effort in the past to
eliminate their wastewater discharges to help them meet
their permit limit. In addition, they have minimized their
used of mercury-added products and their purchasing of
mercury and mercury compounds. Nevertheless, the
site assessment team did have a few suggestions:
• Develop an information bank on safer substitutes
for common uses of mercury in the lab
• Develop a mercury specific baseline for
tracking reductions
• Improve mercury awareness among employees by
conducting targeted training for employees on the
facility's standard operating procedures for mercury
• Ensure that all mercury thermometers have a
teflon coating to help prevent their breakage and
contain the mercury if they do break
• Work with the landlord on P2 for fluorescent
light bulbs and thermostats
• Develop and disseminate standard operating
procedures for mercury management
• Replace mercury thermometer in the hazardous
waste storage shed with a non-mercury unit
Project Team
Anne Fenn and Jeri Weiss, EPA New England, Terri
Goldberg, Northeast Waste Management Officials'
Association (NEWMOA), Judy Shope, Massachusetts
Department of Environmental Protection (MA DEP)
Contacts for More Information
Mercury
Connecticut: Tom Metzner
(860) 424-3242 or tom.metzner@po.state.ct.us
Maine: Ann Pistell
(207) 287-7853 or ann.e.pistell@state.me.us
Massachusetts: My Shope
(617) 292-5597 or judy.shope@state.ma.us
New Hampshire: Stephanie D'Agostino
(603) 271-6398 or sdagostino@des.state.nh.us
Rhode Island: Ron Gagnon
(401) 222-6822 or rgagnon@dem.state.ri.us
Vermont: Environmental Assistance Division
(802) 241-3589 or (800) 932-7100
EPA New England: Jeri Weiss
(617) 918-1568 or weiss.jeri@epa.gov
NEWMOA: Terri Goldberg
(617) 367-8558, ext.303 or tgoldberg@newmoa.org
Federal Facilities Assistance
EPA New England: Anne Fenn
Federal Facilities Program Manager
(617) 918-1805 or fenn.anne@epa.gov
Recyclers/Collectors of
Mercury-Containing Products
wvwv.epa.gov/region01/steward/neeat/mercury/disposal.html
Attachment A
Facility Response to EPA Visit and Recommendations
As a result of the Mercury Assessment, the Laboratory has undertaken efforts to implement most of the recommen-
dations made in the case study. The following measures have been completed or are planned:
• All new mercury thermometers purchased will be Teflon coated
• Flourescent light bulbs and thermostats are now recycled by the building owner
• Mercury thermometer in the hazardous waste storage shed was removed and disposed of properly
• A standard operating procedure for mercury management will be developed and disseminated that will include a number
of the recommendations from the assessment outlined above, including training staff and encouraging safer substitutes.
NEWMOA would like to thank EPA New England for its financial support of this project. The Northeast states provided
in-kind support. NEWMOA, EPA New England, and MA DEP would like to thank the participating federal facilities and
staff for assisting in this important project.
The views expressed in this report do not necessarily reflect those of NEWMOA, NEWMOA member slates, or U.S. EPA. Mention of any
company, process, or product name should not be considered an endorsement by NEWMOA. NEWMOA member stales, or U.S. EPA.
-------
FEDERAL FACILITIES MERCURY QUESTIONNAIRE
Mercury poses a serious threat to human health and the environment. Mercury is an element and once released to the
environment is persistent and bioaccumulates, increasing its concentration in fish, bird, and/or an.mal tissue as it moves up
the food chain. Advisories to limit consumption of certain freshwater fish have been issued in each of the New England
states due to mercury levels. When mercury contaminated fish are consumed by pregnant women and children they can
be at high risk. Methyl mercury can impair development of the nervous system of fetuses and in young children, affecting
sensory, motor, and cognitive functions, resulting in such problems as difficulty in learning to read and inability to
concentrate. Repeated exposure to elevated levels of mercury can cause neurological problems in adults as well. Although
mercury enters the environment in a variety of ways, one of its primary sources is from disposing of mercury-containing
items in the trash, particularly if that trash is incinerated.
Federal Facilities can play an important role in reducing mercury's environmental impacts by minimizing their use of mercury.
Federal Facilities should identify where mercury can be found in their operations and ensure that mercury-containing
products are properly managed. Instituting polices to minimize the purchase of unnecessary mercury-containing products is an
important next step. This questionnaire and the attached inventory checklist can serve as useful tools to identify the locations
and uses of mercury at your facility. With this information your facility can develop a baseline mercury inventory, identify areas
to target for reduction and disposal efforts, and determine where to focus on improving purchasing and management practices.
r
Effects
Do you feel your facility is aware of the environmental and health impacts of mercury? Q Yes Q No
Historical Questions
Has your facility thought about conducting a mercury inventory? a Yes Q No
To what extent has your facility conducted a mercury inventory?
How has your facility addressed mercury disposal in tfie past?
To what extent has your facility conducted a clean-out of mercury-containing products?
Present Practices
How do you address waste disposal of mercury-containing products?
What products and/or processes may use mercury or mercury-containing products at your facility?
(Examples include analytical laboratory procedures, measurement, temperature, and pressure devices, and switches)
-------
How extensive is the chemical inventory for incoming and shelved mercury-containing devices?
Do you manifest mercury-containing wastes? Q Yes J No
Do you feel your facility is aware of the Executive Orders pertaining to purchasing,
waste minimization, recycling, and Greening the Government? Q Yes J No
Do you feel your facility is aware that fluorescent bulbs are now treated as a
universal waste and can no longer be disposed of as a solid waste? _l Yes Q No
Purchasing Practices
How do the purchasing procedures operate at your facility?
To what extent do you impact the purchasing practices, choices, and decisions at your facility?
Is there a policy in place to screen products? If not, are you in a position to adopt a policy?
Does flexibility exist in selecting alternative products?
(For example, choosing a higher-grade alternative reagent with less mercury)
Do you know where to get additional sources of information, including alternative products, case studies, and guidebooks?
Results
Are you able to summarize the results of any actions that your facility has taken to reduce the use of mercury? For example, can
you describe any changes that have been made due to these efforts, or do you have measures of mercury that has been reduced?
Developed by the Northeast Waste Management Officials' Association (NEWMOA), US EPA Region I, and the Massachusetts
Department of Environmental Protection (MA DEP) for use in a project to assess mercury use and reduction at federal facilities.
For more information on the project and to obtain the resulting case studies, visit the pollution prevention area at www.newmoa.org
-------
FEDERAL FACILITIES MERCURY LOG SHEET
Note: Some devices may contain one of the following farms of mercury: elemental mercury,
inorganic mercury, an inorganic mercury compound, or an organo-mercurv compound.
Quantity
Weight/Unit
Total Weight
Source of Product
Mercury Chemicals
Elemental Mercury
CAS# 7439-97-6
Merthiolate
CAS# 54-64-8
Mercurochrome
CAS# 129-16-8
Mercury Chloride
CAS# 10112-91-1
Mercury (II) Chloride
CAS# 7487-94-7
Mercurous Chloride
CAS# 7546-30-7
Mercuric Iodide (Red)
CAS# 7774-29-0
Mercury (II) Oxide
(Red or Yellow)
CAS# 21 908-53-2
Mercury Nitrate
(Millon's reagent)
CAS# 10045-94-0
Mercury (II) Sulfate
CAS# 1 3766-44-4
Mercuric Sulfate
CAS# 7783-35-9
Nessler's reagent
CAS# 7783-33-8
Zenker's Solution
Arsenic-calcium reagent
Precision reagent
CPK reagent
t
Mercury Containing Products
Latex paint, pre 1991
Oil-based paint (maybe)
Mercury alkaline batteries
Mercury/zinc
"button" batteries
Carbon/zinc batteries
Silver oxide batteries
Mercury oxide batteries
-------
Quantity
Weight/Unit
Total Weight
Source of Product
Pressure and Flow Rate Measurement an Control Devices
Sphygomomanometers
Barometers
Lab and Commercial/
Industrial Manometers
Hydrometers
Gas meters
Flow meters
Pressure gauges
Vacuum gauges
Thermo-Electric
Thermometers
Thermostats
Thermoregulators
Electrical Properties
Tilt switches
Relay switches
Sensors
Timers
Balances
Electrical Discharge Properties
Fluorescent lamps
Mercury vapor lamps
Neon lamps
Metal halide lamps
High pressure sodium lamps
Strobe lights
Germicidal lamps
Mechanical Properties as a High-Density, Low-Friction Fluid
Lighthouse lamp bearing
WWTP Pivot Arm bearing
Telescope mirrors
DC watt hour meters
(e.g. Duncan, no longer
made but still may be in use)
Note: Most of these sources came fromGilkeson, John. Minnesota Products Study. Minnesota Pollution Control Agency. April 1996 (revised August 1998).
------- |