1. Provide a preliminary inventory of potential uses and sources of mercury in all buildings and departments, as well as a preliminary identification of known mercury-bearing equipment, wastestreams, and mercury storage sites. The following checklist* includes many of the chemicals, equipment, locations, etc. where mercury may be present at your site. For the purpose of satisfying the requirements of this section, you may submit the completed checklist as a preliminary inventory/identification. While the checklist is intended to facilitate the inventory/identification process, it should not be considered as all-inclusive for purposes of establishing a complete inventory. (see 327 IAC 5-3.5-9(a)(1) and 327 IAC 5-3.5-9(a)(2))

☐ Elemental mercury for refilling

    mercury-containing equipment

assembly on gas-fired furnaces, boilers, unit heaters

and space heaters)

 
 
* This checklist was borrowed from the Delta Institute.

         and motors) 

          float controls

2. Provide a plan and schedule for providing a complete inventory initiated under Section A. above.  (see 327 IAC 5-3.5-9(a)(1))  The schedule required under this part should be expressed in terms of months from the date of NPDES permit issuance, renewal, or modification that incorporates the approved SMV.  It is recommended that the schedule required under this part be developed in conjunction with the other schedules for action required by the SMV application.  
    
   A complete inventory should include an estimate of quantities (i.e., volume of chemicals used annually, or numbers of mercury containing equipment) for each item identified in Part II.A.  Additionally, a complete inventory should include documentation from chemical suppliers and equipment suppliers of the mercury content in your most commonly purchased items. Mercury may not be present in a concentration great enough to appear on an MSDS, yet still contribute to the overall level of mercury in the influent.

C. Provide the results of a preliminary evaluation of possible mercury sources in the facility's influent. The preliminary evaluation must include an initial list identifying all potential sources of mercury in the POTW’s influent by name and address. The preliminary evaluation shall take into consideration, at a minimum, the following: (see 327 IAC 5-3.5-9(b)(1)) 

            1. Medical facilities, for example, the following:

                  a. Hospitals.

                  b. Clinics.

                  c. Nursing homes.

                  d. Veterinary facilities.

      2. Dental clinics.

      3. Public and private educational laboratories.

      4. General industry and all SIU’s.

      5. Significant sources of residential and retail contributions of mercury, for example, the following:

            a. Heating, ventilation, and air conditioning contractors.

            b. Automobile and appliance repair.

            c. Veterinarians.

            d. Others specific to the community served.

   6. An identification of the responsibilities under P.L.225-2001 (also known as House Enrolled Act 1901 of the 2001 legislative  session) for the significant industrial users for the POTW.  P.L.225-2001 outlines the restrictions on the sale or supply of mercury- added novelties, mercury-added products, and mercury commodities, and on the use or purchase of mercury commodities,  compounds, or mercury-added instructional equipment and materials by public and non-public schools.  In order to satisfy the  requirement of this part, include a written statement that attests to the fact that an identification of the responsibilities under 
        P.L.225-2001 has been undertaken. 
 

D. Provide a plan and schedule for completion of the evaluation initiated under Section C. above.  A complete evaluation should include a list identifying all confirmed sources of mercury in the POTW’s influent by name and address. The schedule required under this part should be expressed in terms of months from the date of NPDES permit issuance, renewal, or modification that  incorporates the approved SMV. It is recommended that the schedule required under this part be developed in conjunction with the other schedules for action required by the SMV application. (see 327 IAC 5-3.5-9(b)(1)) 
 

1. Provide a list of planned activities to be conducted to eliminate or minimize the release of mercury to waters of the state. The list of 
   planned activities may consider technical and economic feasibility and must include, at a minimum: (see 327 IAC 5-3.5-9(a)(3))

   1. A review of purchasing policies and procedures.

   2.  Necessary training and awareness for facility staff including an education program.

   3. An education program for the public within the service area of the facility.

   4. Evaluation of alternatives to the use of any mercury-containing equipment or materials.

   5. Other specific activities designed to reduce or eliminate mercury loadings. 
 
6. An identification of the facility's responsibilities under P.L.225-2001 (also known as House Enrolled Act 1901 of the 2001  legislative session).  Under P.L.225-2001, a municipality may, in cooperation and with the support of IDEM, implement  education programs for the public regarding the reuse and recycling of, or independently implement collection programs  for, mercury commodities and mercury-added products.  In order to satisfy the requirement of this part, include a written  statement that attests to the fact that an identification of the responsibilities under P.L.225-2001 has been undertaken.

B. For each planned activity identified under section A. above, include the following: (see 327 IAC 5-3.5-9(a)(4))

   1. The goal to be accomplished.

   2. A measure of performance. 

   3. A schedule for action. The schedule required under this part should be expressed in terms of months from the date of NPDES  permit issuance, renewal, or modification that incorporates the approved SMV. It is recommended that the schedule required  under this part be developed in conjunction with the other schedules for action required by the SMV application. 

C. Provide a list of planned activities designed to reduce or eliminate mercury loadings from each sector identified in Part II.C. of the application, including the goal to be accomplished, a measure of performance, and a schedule for action. (see 327 IAC 5-3.5-9(b)(2))  The schedule required under this part should be expressed in terms of months from the date of NPDES permit issuance, renewal, or modification that incorporates the approved SMV.  It is recommended that the schedule required under this part be developed in conjunction with the other schedules for action required by the SMV application.  An example of planned activities, goals, measures of performance and schedules for action for the sectors identified in Part II.C. is provided in Attachment A. 
 

D.     Provide an identification of the resources and staff necessary to implement the Pollutant Minimization Program Plan (PMPP). (see 327 IAC 5-3.5-9(a)(6)) The identification should indicate the source and amount of funding available to implement the PMPP, as well as the number and position of employees that will be devoted to PMPP implementation.  
 

PART FOUR – MERCURY MONITORING DATA

PART FIVE – POLLUTANT MINIMIZATION PROGRAM PLAN (PMPP) ADDITIONAL REQUIREMENTS

1. Proof of Public Notice Activities:  Provide proof of the public notice activities identified below: (see 327 IAC 5-3.5-9(c))

         For the notice of availability required under Section A.1. provide a copy of the notice as it appears in the newspaper. 
         For the posting requirements under Section A.2. attest to that fact that the information was posted as required in a 
         written statement.

1. Publish notice of the availability of the draft pollutant minimization program plan (PMPP) in a daily or weekly newspaper of general circulation throughout the area affected by the discharge. 
    
   
2. Post a copy of the information required by this section at the following:

              a. Principal office of the municipality or political subdivision affected by the facility or discharge.  
         b. The United States post office. 
         c. If one is available, the library serving those premises.

3. All notices published under this section shall contain the following information: (see 327 IAC 5-3.5-9(d))

a. The name and address of the applicant that prepared the PMPP. 
b. A general description of the elements of the PMPP. 
c. A brief description of the activities or operations that result in the discharge for which an SMV is being requested. 
d. A brief description of the purpose of this notice and the comment procedures. 
e. The name of a contact person, a mailing address, an Internet address, if available, and a telephone number where 
     interested persons may obtain additional information and a copy of the PMPP.

      4.      The applicant shall do the following:  (see 327 IAC 5-3.5-9(e))

a. Provide a minimum comment period of thirty (30) days. 
b. Include a copy of the comments received and the applicant's responses to those comments in the SMV application 
     submitted to the department.

2. Annual Reports:  Provide a schedule for the submission of the annual reports required under 327 IAC 5-3.5-9(a)(8).  Generally, the annual reports should be submitted each year on the anniversary of the effective date of the NPDES permit that incorporates the approved SMV.  A proposed schedule with an alternative submittal date is subject to IDEM's approval.  The annual reports shall include a description of the facility's progress toward fulfilling each PMPP requirement, mercury monitoring results, and steps taken to implement each planned activity developed under the PMPP.

• hospitals
• clinics
• nursing homes
• veterinary facilities

• heating, ventilation, and air conditioning contractors
• automobile and appliance repair
• veterinarians
• others specific to the community served