December 16, 2002

TO: Department Heads, Faculty and Staff

FROM: Ben E. Woods, Vice President for Human and Physical Resources

SUBJECT: Pollution Prevention Mandate

The purpose of this memo is to inform the university community about apparent recent accidental releases of hazardous material into the campus sanitary sewer system, and to request your immediate assistance
in locating and eliminating the source of this release. New Mexico State University collects all sanitary sewer waste waters generated on campus through our sanitary sewer system. Included in that waste stream are flows from campus buildings and laboratories. This waste stream eventually leaves the campus and is treated by the City of Las Cruces. Under our agreement with the city, NMSU actively monitors and tests the leaving (exiting) sanitary sewer waste stream for a wide variety of potential contaminants.

The operational limits for sanitary sewer discharge of heavy metals such as mercury are stringent. Our permit for wastewater discharge does not allow mercury levels to exceed 0.0002 mg/l, which is one part in five billion. During the past three months, testing of the campus wastewater discharge showed mercury concentrations which exceeded the regulatory limit. As a result, NMSU has received a formal Notice of Violation, directing corrective measures and investigation to determine the source.

All NMSU personnel need to exercise great care in disposal of hazardous or unknown materials. This is particularly true of anybody working in a laboratory, given the variety and quantity of potentially hazardous substances that might be encountered. Mercury or mercury compounds must never be poured down the drain, even in a minute quantity. I encourage everybody to work with Environmental Health & Safety (EH&S), which offers training classes for hazardous materials and provides the campus with hazardous material disposal at no charge to the generator.

As part of the required source investigation, Office of Facilities & Services is sampling effluent from buildings which may be a source of mercury. If mercury is detected in the effluent from a building, all labs in that building will then be inspected by EH&S and OFS. Inspection may include testing areas around sinks with a mercury vapor detector, removing, inspecting, and cleaning or replacing traps, and other cleaning as appropriate where vapor is detected.

The required corrective measures and investigation are costly, and the university’s ongoing cost of treatment by the city is likely to increase as a result of this release. However, it could get far worse. If discharge limits continue to be exceeded, or if a similar incident happens again, penalties of $10,000 per day could be assessed, as well as possible civil and criminal actions. If it continues, NMSU could also be required to build and operate a pre-treatment plant for our sanitary sewage waste water. Such a plant would be extremely expensive to build and operate. 

A potential source of mercury release to the sewer results from broken thermometers. One lab thermometer contains enough mercury (about 2.7 grams) to cause NMSU to exceed acceptable concentration levels in our sewer discharge continuously for a month. It could easily persist even longer. Elemental mercury can collect in a drain trap and remain for some time, with sporadic release any time an acidic solution is washed down the drain. It is critical that any suspected release of mercury be reported immediately to EH&S, as required by NMSU procedures. 

In an effort to reduce the potential for accidental release of mercury, both the Chemistry and Biology Department have voluntarily been working to phase out mercury thermometers. It is essential, however, that immediate steps be taken in response to the Notice of Violation issued to the university. I am, therefore, directing that all mercury thermometers in general labs be removed from service and turned over to EH&S for disposal as quickly as possible. I am also directing that any remaining mercury, or mercury-containing compounds, be identified and reported to EH&S (via web inventory system at  NO LATER than January 31, 2003. 

Those areas which have an updated hazardous materials inventory on the EH&S database require no further action. In addition, I ask all principal investigators to evaluate their facilities for mercury contamination and other potential pollutant sources. Please note that there are numerous mercury compounds and other mercury-containing equipment that can also be pollutant sources If any contamination is found or suspected, immediately contact EH&S for assistance in mercury detection and removal. 

Thank you for your cooperation in this effort to protect NMSU and to maintain our good environmental stewardship. If you have any questions about disposal of materials, or to schedule a time to have hazardous materials picked up, please call Andrew Kaczmarek of EH&S Office at 646-3327.

Questions regarding the incident mentioned or our sanitary sewage collection system and our agreement with the City of Las Cruces should be directed to Rich MacRorie, Director of Facilities Operations and
Utilities, at 646-2101.

Waste Minimization - Mercury Policy

NMSU Mercury Remediation Plan