Mercury Method 1631: Its Not As Bad As We Thought It Would Be Dana Folley, PERCS Unit 2005 NC Pretreatment Workshop August 23, 2005 Charlotte, NC Mercury Sources Natural Sources - volcanoes, forest fires, soils Manmade Sources - coal-fired power plants, incinerators, manufacturing, dental amalgam WWTP
sewer pipe slime bio-accumulates Hg, releases Hg when slough off Sediments accumulate Hg, heavy flow sends Hg to WWTP WWTP equipment with mercury bearings, switches - seals fail Mercury crosses state, regional, global boundaries Minamata Disease Japan 1956 Minamata Memorial MAYBE DELETE??
EPA Saves Snowball in Vegas (2004)! Waynesville 10/04 1/2 cup spilled, cleaning lady to hospital, house decontaminated Asheboro 2005 resident collects periodic table elements - 39 lbs, plus!
Mean Mercury Levels in Largemouth Bass (Micropterus salmoides) (Fillet data collected since 1990) Note: This map does not reflect complete monitoring data and should not be used to assess the absolute extent of contamination of fish in the state. Boone Greensboro Raleigh Asheville
Greenville Charlotte Fayetteville Wilmington Data completeness <=3 samples >3 samples Concentration (mg/kg) <0.4 0.4 - 1.0
1.0 - 1.5 1.5 - 2.0 > 2.0 North Carolina Fish Consumption Advice Issued in April 2002 Advises restricted consumption of largemouth bass, chain pickerel, bowfin caught from NC waters
Establishes range of south and east of I-85 Water Bodies on 303(d) List for Mercury 303(d) list to EPA of impaired NC waters based on actual fish tissue analysis Entire Lumber River Basin Roanoke River (Va portion too?) Parts of Neuse River main stem (NEW) Albemarle Sound Atlantic Ocean - for King Mackerel only 7 other creeks, rivers, and lakes in the Cape Fear, Roanoke, Pasquotank, White Oak and
Yadkin Basins Water Quality Standards - Water NC WQS: Aquatic Life (Freshwater chronic): 12 ng/l (0.012 ug/l) Aquatic Life (Saltwater chronic): 25 ng/l Great Lakes WQS: Human Health: 1.8 ng/l Wildlife: 1.3 ng/l EPA Criteria Aquatic Life (Freshwater acute): 1,400 ng/l
Aquatic Life (Freshwater chronic): 770 ng/l Drinking Water Standard - 2,000 ng/l NC Groundwater WQS 1,100 ng/l Water Quality Criteria- Fish Tissue EPA Human Health Criterion: 0.3 mg Methyl Hg/kg fish NC DHHS Fish Advisory: 0.4 mg Total-Hg/kg fish Compare to Japan 1956 Minamata Exposure: Residents consumed fish with 20 mg methyl mercury per kg of fish during several meals per week for years
How to convert fish tissue criteria to water column criteria? EPA Method 1631- Why use it? 250 200 Hg conc, ng/L 200 150 100 50
0 0.5 Method 1631 DL 12 W Q Standard 4.9 Method 245.1 DL
Mean Mid CPF EPA Method 1669- Clean Sampling NC Method 1631 Requirements Based on EPA agreement, DWQ required Method 1631 for effluent sampling at applicable NPDES facilities beginning September 1, 2003. Current or potential NPDES limit is 200 ng/l or below (see mercury limit calculator on PERCS mercury webpage) And
Mercury is pollutant of concern (on NPDES limits page, pretreatment program, or major municipal) Method DMR Effluent 1631 Results NEEDS A LOT OF WORK TO BRING UP TO DATE First Year Results - 96% of effluent samples below the WQS (<12 ng/l). Why such good results? Clean sampling, pretreatment, pollutant removal, etc.
NC Mercury NPDES Permitting Requirements Mercury limit now expressed as Weekly Average Class III and IV WWTPs - Weekly effluent Class I and II WWTPs -Twice per month effluent For new limits, propose compliance schedule to allow for source evaluation, budgeting, etc. NC NPDES Permitting for Non-Impaired Waters
WWTP Receiving Waterbody is not Hg-impaired i.e, not on 303(d) list Calculate NPDES limit in normal fashion, taking into account dilution at 10 year drought stream flow (7Q10) Perform normal Reasonable Potential Analysis (RPA) with 7Q10 dilution If reasonable potential exists for WWTP to violate limit, add limit and Compliance Schedule NC NPDES Permitting for Hg-Impaired Waters WWTP Receiving Waterbody is Hg-impaired and
on 303(d) list EPA assumes upstream is already at NC WQS, so do not allow 7Q10 dilution NPDES limit will be equal to NCWQS = 12 ng/l Perform Reasonable Potential Analysis (RPA) with NO dilution If reasonable potential exists for WWTP to violate limit, add limit and Compliance Schedule Facility can collect upstream samples to test assumption. NC NPDES Permitting for HgImpaired Waters with TMDLs Current TMDLs (Lumber, Cashie) have shown
point sources to be minimal contributor to mercury load. TMDL can be expressed in NPDES permits as a mass load limit (eg. grams/day) or require implementation of a Pollution Prevention (P2) strategy. PERCS and Division of Pollution Prevention and Environmental Assistance (DPPEA) currently preparing P2 language. NC NPDES Compliance For those with limits already,
generic SOC with P2 requirement is being developed for any non-compliant facilities. Regions continue with civil penalty discretion. NC NPDES Discharge Monitoring Reports (DMRs) Enter mercury data in same units as are on NPDES limits page. Enter all effluent mercury
data, even LTMP/STMP. NPDES Compliance - Pretreatment Remember MSDSs dont tell you about inactive ingredients or contaminants. What if mercury is in ambient or raw water supplies? Drinking Water Standard - 2,000 ng/l NC Groundwater WQS 1,100 ng/l If Mercury is everywhere, what good will slapping zero limits on a few big bad SIUs do? Dentists!!!!!!
Method 1631 and Pretreatment Requirements NC DWQ PERCS will only require 1631 for other locations (Influent, Uncontrollable, SIU, etc.) if there is a problem at your effluent, i.e., you are having significant limits violations December 18, 2002 Memo @ PERCS webpage Method 1631 and Pretreatment Of the few Pretreatment POTWs that had
been having detections above 200 ng/l using 245.1, most are NOT having any hits any where near 200 ng/l with 1631 and 1669!!!!!!! 24 HWAs using 1631 for effluent, 9 also using 1631 influent 18 approved, 6 more in house Method 1631 and Pretreatment ave of ave Influent 224 Only 1631
only 245.1 Effluent range of ave 27.7 - 430 189 244 6.06 35 0.68
Max individual effluent 102.4 Method 1631 and Pretreatment ave of ave range of ave Removal Rate 96% 87% - 99% MAHL triples or quadruples 5 without tertiary filters no real difference Method 1631 and Pretreatment Uncontrollable ave of ave range of ave Sampling
195 43.9 - 510 Mass balance 206.5 71 470 EPA Literature 300 NC Water Quality Standard (WSQ) Current NC WQS adopted in 1989 based on EPAs 1988 Water Quality Criteria EPAs new (January 2001) Ambient Water Quality Criteria is expressed as 0.3 mg/kg methyl mercury in fish tissue
Need Bio-accumulation Factors (BAFs) to translate WQC into total mercury surface water quality target/standard EPA Guidance on this still not out NC Eastern Regional Mercury Study (ERMS) Gather NC specific stream and fish tissue data needed to calculate BAFs and perform translation Implemented Nov 2002-Aug 2003 Final Report on web-site next year Mercury Study Extension covers the French Broad to the Pasquotank
ERMS Target water column levels to protect human health (fish consumption) Concentration, ng/L Figure 5-?. ERMS: Range of Target Total M ercury Levels (All largemouth bass) 100 10 1 0.1
1st quartile Median 3rd quartile Goal 3a: Target water levels NC WQS Low er CL Upper CL
Series7 ERMS Measured Total Mercury in WWTP effluentMAYBE NOT USE if DMR sum shows same Mercury Concentrations by Waste Stream 1000 Total mercury, ng/L 100
Schools (n=4) Industries (n=8) Water plants (n=3) DWQ Water Quality Standard Using Method 1631, NC Mercury WQS will be exceeded in surface waters in some cases. Appears existing WQS is not protective of consumption of largemouth bass except for smaller fish, and even then not in all cases.
Although recommended by EPA, BAF approach assumes relationship between mercury fish tissue and mercury (or methyl mercury) in water column is linear. This may not be true. Need EPA WQC Implementation Guidance And now for the big picture Houston, we have a problem ... Total Hg conc, ng/L 1000.0
1st quartile ERMS effluent Median 3rd quartile Waccamaw MDN Rainwater Mercury Questions? All emails are [email protected]
PERCS - Pretreatment: ?????????, NC DWQ, PERCS Unit (919) 733-5083 ext. ???, http://h2o.enr.state.nc.us/Pretreat/Mercury/mercury.html NC DWQ Mercury 1631 letters (NPDES - 8/30/02 and 8/1303; Pretreatment 12/18/02) Mercury NPDES limit calculator Method 1631 and 1669 (clean sampling) documents Presentations, guidance, and links Mercury Questions? NPDES: Tom Belnick, NC DWQ, Point Source Branch (919) 733-5083 ext. 543 http://www.esb.enr.state.nc.us/NPDES/index.htm
NC DWQ Laboratory (919) 733-3908 Metals Unit Roy Byrd, Lead Chemist, ext 213 http://www.esb.enr.state.nc.us/lab/mib.htm DWQ 1631 lab up and running!!! Laboratory Certification Unit James Meyer, Supervisor, ext. 207 http://www.esb.enr.state.nc.us/lab/cert.htm Mercury Questions? ERMS/TMDL/303(D) List: Michelle Woolfolk, NC DWQ, Modeling&TMDL Unit (919) 7335083 ext. 505
http://h2o.enr.state.nc.us/tmdl/ WQS: Connie Brower, NC DWQ Standards Unit (919) 733-5083 ext. 380, http://h2o.enr.state.nc.us/csu/swstdsfaq.html Fish Advisories: Luanne Williams, NC Dept Health and Human Services (919) 715-6429 Mercury Questions? Biological Assessment (Fish tissue) Mark Hale, http://www.esb.enr.state.nc.us/BAU.html Planning - Basinwide Plans
http://h2o.enr.state.nc.us/basinwide/index.html Ambient & Coalition Monitoring http://www.esb.enr.state.nc.us/EU.html Mercury - Summary Mercury can be bad in the environment and to human health, especially as Methyl mercury Incidents of Mercury Contamination are still occurring Some NC waters have fish exceeding health criteria, DHSS issued fish consumption advice notices for half of
NC Mercury - Summary Most NC NPDES facilities below NC WQS Those in significant violation can get P2 SOCs NPDES Civil Penalty Discretion Continues New/Renewal NPDES Limits will be weekly averages New NPDES Limits will include compliance schedule TMDL Limits may be expressed as P2 schedules
Mercury Summary (continued) Method 1631 works well on WWTP influent, uncontrollable, and SIUs WWTP site-specific 1631 removal rates much higher than EPA Literature Site-specific 1631 Uncontrollable within range of EPA literature DWQ PERCS may adopt NC literature removal rate and uncontrollable Mercury Summary (continued)
DWQ continues to study NC sitespecific mercury water body conditions and basis for NC WQS Questions?
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