"Lamperti, Larry" <Larry.Lamperti@ci.cor

vallis.or.us>

12/21/2007 11:25 AM To Group Ow-Docket@EPA

cc "Hanthorn, Dan" <Dan.Hanthorn@ci.corvallis.or.us>,

"Penpraze, Tom" <Tom.Penpraze@ci.corvallis.or.us>, "Sinclair,

Shane" <Shane.Sinclair@ci.corvallis.or.us>, <gillaspie@oracwa.org>, <bfletcher@oregondental.org>

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Subject Attention Docket ID No. EPA-HQ-OW-2006-0771

December 21, 2007

Water Docket Environmental Protection Agency

Mailcode: 4203M 1200 Pennsylvania Ave., NW Washington, DC 20460

Attention Docket ID No. EPA-HQ-OW-2006-0771

The City of Corvallis is a municipality located in the Upper Willamette Basin of Oregon and provides wastewater treatment to a population of 53,165. The City of Corvallis shares EPA's commitment to a clean and healthy environment. More specifically, the City believes that the discharge of toxic pollutants should be reduced so that water quality is not impaired. The City also believes that mercury discharged from dental offices is effectively reduced through Best Management Practices (BMPs) that are implemented at the local level.

In keeping with the City's Utility Division motto of "Enhancing Community Livability Through Improved Water Quality" the City partnered with the Oregon Dental Association (ODA) in 2003 to implement BMPs for managing dental waste, including mercury and amalgam.

In response to EPA's request for comments regarding dental mercury, the City of Corvallis offers the following comments:

1) EPA's current assumption that amalgam collected in chairside traps and vacuum pump filters is disposed as solid waste is not accurate. In Oregon many jurisdictions with approved industrial pretreatment programs, like Corvallis, have implemented the ODA's BMPs for amalgam. Compliance with the ODA's BMPs require that the amalgam be either picked up by a commercial recycler, or taken or mailed to a commercial recycler. Landfill disposal of amalgam is not acceptable to the City of Corvallis and the Oregon Dental Association.

2) All forty-two (42) dentists practicing in the City of Corvallis have implemented the ODA's BMPs for mercury and amalgam (see attached file) instead of the ADA's BMPs. The cost for a dentist to recycle the amalgam can range from $450 - $950 per year, depending on the recycling service used. This cost is based on a dentist who places 50 amalgam fillings per month and removes 25 amalgam fillings per month.

<<BMP document Revised October 2007.doc>>3) The City believes that the implementation of BMPs is highly effective in reducing the daily mass load of mercury in the influent to the Corvallis Wastewater Reclamation Plant. By the end of 2004, 100% of Corvallis dentists had implemented the BMPs. The data below shows that the daily influent mass load has been reduced 79%.

Before BMPs Implemented: After BMPs Implemented:

Date Influent (lbs/Day) Date Influent (lbs/Day) 03/05/01 0.05 03/09/04 0.02 03/06/01 0.08 03/10/04 0.01 03/07/01 0.06 03/11/04 0.02 07/16/01 0.09 07/20/04 0.01 07/17/01 0.09 07/21/04 0.02 07/18/01 0.09 07/22/04 0.02 03/18/02 0.09 02/23/05 0.02 03/19/02 0.08 02/24/05 0.01 03/20/02 0.03 02/25/05 0.01 07/29/02 0.18 08/15/05 0.01 07/30/02 0.13 08/16/05 0.02 07/31/02 0.09 08/17/05 0.02 02/10/03 0.02 03/06/06 0.01 02/11/03 0.01 03/07/06 0.01 02/12/03 0.01 03/08/06 0.01 07/28/03 0.10 07/17/06 0.01 07/29/03 0.01 07/18/06 0.02 07/30/03 0.02 07/19/06 0.02

02/12/07 0.01

02/13/07 0.01

02/14/07 0.01

08/27/07 0.02

08/28/07 0.01

08/29/07 0.01

Average: 0.0683 lbs/Day Average: 0.0142 lbs/DayPercent Reduction: 79%

4) Cost and burden to POTW: Implementing voluntary BMPs in the City of Corvallis involved approximately 185 hours of staff time and a total

cost of $5000 (includes time and materials).

5) The Corvallis Wastewater Reclamation Plant has not experienced any known interference or pass through problems associated with dental mercury discharges.

6) The City of Corvallis has forty-two (42) dentists practicing within the City's jurisdiction. By the end of 2004, all forty-two dentists voluntarily implemented the BMPs. The City of Corvallis believes that a voluntary program can be very effective in reducing dental mercury discharges. Additionally, the 2007 Oregon Legislature passed Senate Bill 704 that now requires all dentists practicing in Oregon to implement the ODA's BMPs. Whether voluntary or not, dental BMPs are highly effective in reducing mercury discharges from dental offices when implemented at the State or local level.

In conclusion, the City of Corvallis is the recipient of EPA's 2006 National First Place Cleanwater Act Recognition Award for Pretreatment Program Excellence. Obviously, the City takes its pretreatment responsibilities seriously. Although not nationally recognized, many other Oregon pretreatment programs also share the same commitment to pretreatment excellence. This commitment to pretreatment excellence is accomplished through limited budgets. For example, the forty-two dentists located in Corvallis are practicing in thirty-one (31) dental offices. If EPA were to establish national categorical pretreatment standards for dental mercury discharges, the number of Significant

Industrial Users in Corvallis would increase from 3 to 34. As a result, pretreatment oversight for the dental sector would significantly increase due to the time involved in issuing permits, and conducting required annual inspections and monitoring. With a pretreatment staff of one person and a limited budget, the City's resources would be unnecessarily diverted to a sector that can easily and effectively be regulated using BMPs implemented at the local or State level. Based on the evidence presented in this testimony, dental mercury discharges can be reduced without federal regulation.

This concludes the City of Corvallis comments regarding EPA's request for comments regarding the use of BMPs for reducing dental mercury discharges. The City appreciates the opportunity to submit comments on this topic. If you have any questions or would like to discuss these

comments, please contact me.

Larry Lamperti Environmental Analyst City of Corvallis

Public Works

PO Box 1083 Corvallis, OR 97339-1083

Phone: 541-766-6729 x5282

FAX: 541-766-6753 e-mail: larry.lamperti@ci.corvallis.or.us