**1** 

## Madison Metropolitan Sewerage District Mercury Pollutant Minimization Program (PMP)

A) Summary **The surface water quality criterion for mercury as specified in NR 106 is 1.3 ng/l (ppt). In 2002,**  **DNR determined that utilizing wastewater treatment technology to achieve dis charge**  **concentrations necessary to meet the 1.3 ppt water quality standard would result i n substantial**  **and widespread adverse social and economic impacts. DNR further concluded that appr opriate**  **mercury source reduction activities are environmentally preferable to w astewater treatment**  **technology, in many cases. Provisions in NR 106 allow DNR to establish alternative m ercury**  **effluent limitations, conditioned in part on the permittee agreeing to develo p and implement a**  **mercury pollutant minimization program (PMP).**

**The District’s WPDES permit anticipates that the District w ill not meet the 1.3 ng/l criterion and**  **that an alternate mercury effluent limitation would be necessary. The perm it requires that a draft**  **PMP be submitted to DNR by March 31, 2007. PMP implementation must begin by Sep tember**  **30, 2007. In accordance with NR 106 and WPDES provisions, the District has developed and will implement a mercury pollutant minimization program.** 

B) Background **The District’s PMP recognizes and builds upon the significant voluntary effor ts already**  **undertaken by the District to address mercury contributions to the collect ion system. These**  **efforts began in 1997, when the District was one of three wastewater treatment facilities that**  **agreed to work with DNR to perform community outreach and education. Their goal was to minimize mercury use. During this time, District staff members worke**  **d cooperatively with POTW and recycling staff throughout Wisconsin and the Midwest to reduce mercury pr**  **oduct usage and to encourage recycling of existing products. Today, District staff memb**  **ers uphold the minimization efforts by continually providing assistance to POTW staff**  **and others as they are**
**able.**

**Prior to 1997, District staff members were aware of activities and devi ces within the treatment**  **plant that were actual or potential sources of mercury to wastewater. Since 1997, the District has** 
**taken efforts to minimize the use of these sources. Staff members eliminat ed the use of a**  **mercury compound as a catalyst in Kjeldahl nitrogen analysis and as the Nessler ’s ammonia**  **reagent. The electrical department collected mercury containing tilt sw itches and float balls for**  **proper disposal and have removed thermometers and manometers from plant e quipment**  **wherever possible. In 1998, a recycling program was established for recyc ling fluorescent**  **lamps, and District staff members also assisted in the clean up of a com minuter water seal**  **mercury spill in recent years.**

**The mass of mercury in the District’s influent has decreased significan tly since the late 1980’s**  **(Figure 1 and Appendix A). Factors contributing to this decrease include: product substitution,**  **ordinance changes, mercury collection activities such as the Clean Sweep Progr am, and the**  **additional outreach and education activities described in Appendix B. Biosolids merc ury**  **concentrations peaked in the mid 1980’s and have significantly decreased since the n (Figure 2).** **2** Figure 1: Influent Hg Mass Loads

0 20 40 60 80 100 120 140 160 1801987198919911993199519971999200120032005

YearHg Mass (grams/day)

Figure 2: GBT Biosolids Mercury Concentration (Yearly Average)

0 2 4 6 8 10 12 1419791981198319851987198919911993199519971999200120032005

YearHg concentration(mg/kg dry weight)

**The average biosolids mercury concentration for 2006 (through September) is 1.1 mg/kg, w ell**  **below the 17 mg/kg concentration limit used by the Wisconsin Department of Natur al Resources**  **to define “High Quality” biosolids. Efforts to reduce influent mercury concentra tions have also**  **impacted effluent mercury concentrations.**

**The average effluent mercury concentration since testing began in March, 2004 using t he EPA**  **low level mercury method (Method 1631) is 2.3 ng/l (See Appendix C). While effluent concentrations are low, monthly grab samples have exceeded the 1.3 ng/l surface wate**  **r criterion in all but one case since March, 2004. For comparison purposes, Appendix C also pr**  **esents the monthly influent, effluent and biosolids mercury concentrations for the past 3 years**  **and shows the average percent removal from the effluent.** 

C) Current sources of mercury to collection system **The daily influent mercury load to the Nine Springs Wastewater Treatm ent Plant in 2005 was**  **24.4 grams, based on an average flow of 39.3 MGD and an average influent mercury concentration of 164 ppt. Using analytical data when available, along with values found in the**  **literature, mercury loads have been estimated from residential, commerci al, industrial and**  **infiltration contributions and these estimations are given in Table 1. The comm ercial category** **3**

**accounts for about 81 percent of the daily influent mercury load. The commercial load includes**  **contributions from dentists, hospitals, schools and other sources. The mercury loa d from hauled**  **wastes (e.g. septage, holding tanks, grease traps) was estimated at 1.3 grams per day, but was not**  **included in Table 1 since septage enters the treatment plant after the influent sampling point.** 

Table 1: Mercury Loads to MMSD influent

Sector Flow

(MGD) % of Total Hg conc. (ppt) (grams/day) % of base load

Residential 23.1 58.9 49 4.3 17.6

Commercial 11.3 28.7 461 a 19.7 a 80.7
Industrial 3.0 7.5 26 0.3 1.2
Infiltration 1.9 4.8 20 0.1 0.6

Subtotal 39.3 99.9 24.4 100.0

**a Grams by difference, from known contributions. Hg concentration back calcula**  **ted.**

D) PMP Focus **DNR has developed a guidance manual to assist agencies with PMP development. DN R states** 
**that the manual is “** intended solely as guidance and does not contain any mandatory requirements except where requirements found in statute or administrative rule are mentioned **.” The guidance document specifically identifies dental clinics, hospitals, sc**  **hools (primarily post secondary schools) and industry as sectors that should be addressed in a PMP. The D**  **istrict’s PMP focuses on controlling mercury contributions from all four of these sectors. Th**  **e level of effort spent in addressing each of these sectors is commensurate with the m**  **agnitude of the contributions and the degree to which control can be accomplished using reasonable a**  **pproaches. The PMP builds upon the considerable effort that the District has alrea**  **dy voluntarily invested to control mercury contributions from these sectors. The District has also ide**  **ntified residential contributions as an additional targeted sector. The approach used to address merc**  **ury contributions from each of the above sectors is identified below:** 

(i) Dental Sector **The dental sector represents the largest controllable source of me rcury to the District’s collection**  **system, and therefore will receive the greatest focus in the initial PM P. Detailed sampling to**  **characterize dental contributions has not been conducted, given the difficult ies associated with**  **sample collection and analysis. However, the District estimates that 45% to 68% of the total**  **influent mercury load (56% to 84% of the commercial load) in 2005 was contributed by the dental sector (See Figures 3 and 4).** 

**This estimate is based on data from a variety of sources, including the Distri ct’s 2005/2006**  **dental survey, information on “per dentist” mercury discharges reported in studie s conducted by**  **other agencies, and information on the mercury capture efficiencies of chair si de traps and**  **amalgam separators (60% and 98%, respectively). Actual contributions could be higher or**  **lower, but the range is in reasonable agreement with figures cited by DNR and WDA.** **4**

Figure 3. Figure 4.

Breakdown of Commercial Contributions (Based on low estimate of dental contribution)

Other=
8.6 grams/day

or 44% Dental=
11.1 grams/day

or 56% Other Dentists Breakdown of Commercial Contributions (Based on high estimate of dental contribution)

Other=

3.1 grams/day

or 16%

Dental=

16.6 grams/day

or 84% Other
Dentists

**The District will address mercury contributions from the dental sector through four approaches:** 

**1. Require clinics that place or remove amalgam to follow WDA best mana**  **gement practices for amalgam wastes** 
**2. Require clinics that place or remove amalgam to install and maintain am**  **algam separators**
**3. Conduct on-site inspections to evaluate BMP implementation and waste handling a**  **t dental facilities. Target will be 20% inspection rate of the dental cl**  **inics/year (100% during the five year WPDES permit cycle)** 
**4. Require clinics to complete and submit an annual form summarizing the status**  **of amalgam separator installation/maintenance and implementation of BMP.** 

**Data from the District’s 2005/2006 survey of dental clinics shows that there ar e 103 clinics in the**  **service area that can be expected to place and/or remove significant amount of amalgam. These**  **clinics are either general or pediatric clinics. Twenty three (2 3) of these clinics have already**  **installed amalgam separators.**

**Prior to PMP implementation, the District will revise its Sewer Use O rdinance to require dental**  **clinics that place or remove amalgam to properly install and mainta in ISO 11143 certified**  **amalgam separators by December 31, 2008. The SUO will also require that these dental clinics**  **implement WDA best management practices by December 31, 2008. A copy of t he draft SUO is**  **given in Appendix D. On-site inspections and annual reporting by the dental clin ics will be used**  **to document compliance with these requirements. Annual reporting by the dental cli nics will be**  **accomplished by completing a form developed by the District (Appendix E). The District**  **reserves the right to revise this form as necessary to ensure that rele vant and useful information** 
**will be obtained from the dental clinics. District staff will wor k cooperatively with the Dane**  **County Dental Society to accomplish the above initiatives.**

(ii) Hospitals/Medical Sector **Limited sampling data from 2006 at three hospitals in the District’s servic e area showed mean**  **and median mercury concentrations of 394 ppt and 114 ppt, respectively. The median concentration is about 3.4 times higher than the median concentration from resident**  **ial sources. There have been efforts within the medical sector to reduce mercury use. The D**  **istrict approach to addressing mercury contributions from the medical sector will foc**  **us primarily on information 5** 

**and education efforts. District staff will initially meet with repre sentatives from each of the four**  **hospitals to determine each facility’s current status relative to me rcury minimization activities.**  **Each facility will be asked to provide a brief initial report summ arizing steps already taken to**  **address mercury contributions to the collection system and any additional steps (i f any) that they**  **anticipate taking. As part of this initial report, they will be asked t o complete a best management**  **practices checklist. At least one meeting will be held each subsequent year with appropriate**  **hospital staff. Each hospital will also be asked to submit a letter or r eport on an annual basis**  **summarizing mercury related activities and initiatives which have be en undertaken during the**  **previous year.**

(iii) School Sector **School sector related activities will focus primarily on the post-sec ondary schools within the**  **District’s service area. An emphasis will be placed on information a nd education activities, with**  **the goal of minimizing mercury contributions to the collection system from the se schools.**  **District staff will initially meet with representatives from e ach of the three post-secondary**  **schools in 2007 to discuss mercury related issues. Each facility will be asked t o submit a brief**  **report summarizing steps already taken to address mercury contributions to the collection system**  **and any additional steps (if any) that they anticipate taking. Meetings will then be held with**  **appropriate school staff on an annual basis. Each post-secondary school wil l be asked to submit**  **a letter or report on an annual basis summarizing mercury related initia tives that they have taken**  **during the past year.**

**Elementary, middle and high schools within the District’s service area will initially be sent**  **information on best management practices for mercury. Fact sheets to be s ent to key staff**  **members in public school districts will include: information on WDNR’s “Green and Healthy**  **Schools” criteria, potential hazards of mercury, possible sources of mercury, and how to safely**  **dispose of and recycle mercury. The targeted audiences will include maintenance or buildings**  **and grounds managers (spill response, demolition of science rooms, inspection of dra ins and**  **traps), lead nursing staff (fever thermometers and sphygmomanometers), and s cience curriculum**  **coordinators (elimination of mercury-containing devices and chemicals). Addit ional information** 
**and education activities for these schools will be conducted on an “as needed” basis as**  **determined by District staff.**

(iv) Industrial Sector **Analytical testing over the last several years (since low level testing w as initiated at MMSD) has**  **shown no significant mercury discharges from the industrial community in our service a rea.**  **Contributions from this sector are estimated to be approximately 1% of the t otal mass of mercury**  **entering the wastewater system (Table 1). At no point over the last 10 years ha s any regulated**  **industry violated the mercury limit in the District’s Sewer Use Ordinance. The District will**  **continue to monitor the industrial sector as required by NR 211 for industrial p retreatment**  **purposes. Permitted industries are inspected annually by the pretre atment coordinator. District**  **staff will distribute informational materials to the industries during t he annual inspection process.**  **New industries/businesses that may be potential sources of mercury will be identified and**  **addressed consistent with existing procedures in the District’s pretr eatment program.** 

(v) Residential Sector **Testing during 2005-2006 of residential only wastewater type samples indicates a contribution of**  **mercury from this sector that could account for nearly 18% of mass loadings to our tre atment**  **plant (Table 1). Given the diffuse nature of contributions from this sector, PM P control** **6**

**strategies will focus on information and education activities. The District will continue to take**  **advantage of partnerships with Clean Sweep and the EnAct (Environmental Ac tion Teams)**  **program, which is organized by the Madison Environmental Group. EnAct teams ar e formed on**  **a neighborhood basis, with a key objective of encouraging and empowering team mem bers to**  **take actions in their daily lives to reduce the environmental impact of their households. In**  **accordance with NR106, District information and education activities wil l alert the sectors,**  **particularly the public, to mercury recycling opportunities via Clean Swe ep, vendors, and special**  **programs (e.g. TRC-Thermostat Recycling Corporation) for lamps, thermostats, and other**  **mercury-containing products.**

**Information and education activities deemed reasonable and appropriate wi ll be undertaken by**  **the District. Options include:**

• **Bill insert to customers**

• **Informational page insert in local newspapers**

• **Informational meetings**

• **Displays at Home Shows**

• **Interview with local TV**

• **Brochures provided at plant tours**

• **Participate in mobile collection events**

• **Establish informational web-site**

• **Partner with Dane County Department of Public Works and Recycling**

**The Wisconsin PMP guidance document identifies fluorescent bulbs, auto switche s and**  **thermostats as known sources of mercury. Fluorescent bulb recycling is already addressed in a**  **Dane County ordinance and will not be addressed in the District’s PMP other than a s part of the**  **publication of information on recycling opportunities. Auto switches and thermos tats will be**  **addressed through information and education activities.**

**Planned collection system monitoring is not being considered for the first yea rs of the District**  **mercury PMP. The PMP, as presented herein targets known major sources; coll ection system**  **monitoring can be performed, as situations present themselves, for identi fying general loadings**  **from residential areas or perhaps from targeted business/industri al developments.** 

E) Data Management **A database developed in-house dedicated to the mercury PMP is functional and wi ll be further**  **developed to manage contact data, facility identification and practices , survey data, and report**  **generation. Relevant summary data may be provided in annual reports submit ted to DNR.**  **Detailed information will be available upon request.**

F) Resources **The District will allocate resources as necessary to effectively im plement this PMP. PMP efforts**  **will be led by the District’s Pretreatment and Waste Acceptance Coordinator. Laboratory staff**  **will play a key role in multiple areas, including sample collection/anal ysis, inspection of dental**  **clinics, and information/education activities with other sectors. Databa se development to**  **support PMP activities will be led by Information Services staff . Administrative Services staff**  **will be responsible for administrative tasks including preparat ion of informational materials, plan**  **evaluation, record keeping and annual reporting. Other staff will be involved in PMP r elated** **7**

**activities on an as needed basis. Monetary needs will be identified dur ing the District’s annual**  **budgeting process and allocations will be made as appropriate.**

G) PMP Goals **Sector specific initial goals for the PMP are given below. The goals may be r evised as**  **experience is gained in implementing the PMP.**

**1) Dental Sector** 

**a. 100% compliance with WDA BMPs by December 31, 2008** 
**b. 100% compliance with the amalgam separator installation requirement by**  **December 31, 2008**

**c. 20% inspection rate annually** 

**2) Hospitals/Medical Sector** 

**a. Hold annual meetings with hospital personnel** 
**b. Receipt of Hg PMP and/or annual report received from all hospitals by Dec**  **ember 31, 2007** 

**c. Scheduled inspection rate of 25%** 

**3) Schools** 

**a. Hold annual meetings with each post-secondary facility** 
**b. Receipt of Hg PMP and/or annual report received from all post-secondary school**  **s by December 31, 2007** 

**c. Send mercury fact sheets** 

**4) Industrial** 

**a. Distribute a mercury fact sheet to permitted industries during annual in**  **spections**

**5) Residential a. Provide mercury reduction resource information to ENACT on an annual basis for**  **publication/distribution in newsletters**
**b. Cooperate in mercury reduction activities with the Clean Sweep Program** 

**c. Participate in information and education activities as appropriate throughout**  **the year. Examples could include posting information on the District’s web site a**  **nd providing mercury reduction information to District customers for inclusion in** 
**water and sewer bills**

**The timeline for key milestones (through December, 2008) of the PMP is given below . The**  **dates shown for PMP submittal by the District, subsequent approval b y DNR, and submittal of**  **the first annual report are consistent with dates specified in the Dist rict’s WPDES permit.** **8**

H) Timeline

I) Annual Report to DNR **An annual report summarizing PMP activities conducted by the District during t he previous**  **twelve (12) month period will be submitted to DNR by March 31 st**  **of each year. The first report will be submitted by March 31, 2008. Annual reports will include the following infor**  **mation:**

**1) Analytical data for effluent, influent and biosolids 2) Staffing and other resources allocated to the mercury PMP effort**  **3) Progress made towards reaching the goals within the specific sectors (Se e Section F)**  **4) New and/or revised PMP goals 5) District contact information** 

**Where reasonable and appropriate, forms provided in DNR Mercury PMP Guida nce Document**  **or the functional equivalent will be used when submitting information in the annual r eport.**  **Revisions/adjustment to the approaches identified in previous sections of this PMP may be**  **necessary based on experience gained during implementation of the PMP. Revisions, if**  **necessary, will also be identified in the annual reports. 3/31/07**  **6/30/07 9/30/07 12/31/07 3/31/08 6/30/08 9/30/08 12/31/2008** 

**WDA BMP’s Compliance**
**Date**

**100% Separator Installation**

**Newsletters out to Dental, Hospital, & School Sectors.**  **Request Annual Reports**  **from Hospitals**
**and Schools Educational** 
**Mailer Sent**
**Out to Sectors Acceptance of PMP by DNR**  **& Implementation of BMP’s**

**Meet with Hospitals & Schools**  **PMP Submitted to** 
**DNR for**
**Review and Approval**  **Hold 1st Dental**

**Assessments Run a preliminary** 
**audit of BMP status**
**in different sectors Dental** 
**Sector**
**Reminder 9**  

## Appendix A

Nine Springs Wastewater Treatment Plant Influent Mercury Loadings (1987-2005)

Year Flow (MGD) Average Mercury Concentration (ppb) Influent

Mercury Loading (grams/day)
1987 35.86 1.13 153 1988 34.94 0.99 131 1989 34.49 0.85 111 1990 34.92 0.92 122 1991 36.83 0.93 130 1992 36.77 0.93 85 1993 42.69 0.36 58 1994 39.53 0.34 51 1995 39.18 0.27 40 1996 39.56 0.26 39 1997 38.03 0.41 59 1998 41.16 0.25 39 1999 41.53 0.25 39 2000 42.10 0.33 53 2001 41.76 0.33 52 2002 40.14 0.44 67 2003 38.56 0.29 42 2004 42.96 0.27 43 2005 39.32 0.16 24**10** 

## Appendix B

Summary of District Efforts to Reduce Influent Merc ury Loadings

**The following is a list of mercury reduction activities that the District h as been involved**  **in over the last fifteen years, in an effort to bring about reductions in the le vel of mercury**  **entering wastewater.**

• **“Charter Member” DNR Community Mercury Reduction Group**

• **Informational insert distributed to Madison area residents (70,000+)**

• **Thermometer exchanges. (4900 collected). Included groundbreaking work at pharmacies** 

• **Safety Saturday (collected 274 thermometers, 33 thermostats, 20 other)**

• **Dane County, and local ordinances to ban sale of thermometers, 2000**

• **Local ordinance requiring acceptance of fluorescent lamps and Hg thermostat s at**  **retailers**

• **1997 Wisconsin Mercury Round Up**

• **P2 week**

• **Sierra Club letter**

• **NARI Home Remodeling Expo 2001**

• **3/23/01 news conference at MMSD**

• **Informational newsletters**

• **Educational plant tours to UW and Edgewood Nursing students**

• **Talks given at elementary schools**

• **Brochures**

• **Cooperative work Clean Sweep**

• **WORT radio interview held**

• **Mailings distributed to schools**

• **Mailings distributed to medical facilities**

• **Several informational meetings with Dane County Dental Society (DCDS)**

• **Letters and other outreach published in DCDS monthly newsletter**

• **Surveys distributed to dental facilities in our treatment area, summer 2005**

• **Alternative laboratory method developed, eliminating use of mercury in our lab**

• **Elimination of mercury from chemical storage areas in lab**

• **MMSD electrical department identifying and recycling pressure and tempera ture**  **gauges and tilt switches 11**  

## Appendix C

Nine Springs Wastewater Treatment Plant Influent, Effluent and Biosolids Mercury Concentrat ions

(March 2004* to September 2006)

Month Year Influent (ppt) Effluent

(ppt) %

Removal GBT Biosolids

(mg/kg dry wt.)

March 2004 253 2.16 99.1 1.0 April 2004 211 1.58 99.3 1.1 May 2004 314 2.89 99.1 1.2
June 2004 210 1.55 99.3 1.9 July 2004 213 2.64 98.8 1.7 August 2004 209 1.72 99.2 1.5 September 2004 164 1.54 99.1 1.5
October 2004 1.4
November 2004 176 2.80 98.4 1.6
December 2004 142 1.92 98.6 1.2
2004-Ave 209 2.11 99.0 1.4

January **2005 227 1.95 99.1 1.5** February **2005 173 2.20 98.7 1.1**

March **2005 149 2.04 98.6 1.1** April **2005 75 2.32 96.9 2.2** May **2005 246 1.97 99.2 1.1**

June **2005 136 1.10 99.2 1.8** July **2005 161 2.17 98.7 2.5** August **2005 149 1.98 98.7 1.5** September **2005 236 1.89 99.2 1.5**
October **2005 133 6.54 95.1 1.3**

November **2005 160 2.68 98.3 1.5**

December **2005 126 2.28 98.2 1.4**
2005-Ave 164 2.43 98.4 1.5

January **2006 110 4.96 95.5 1.0** February **2006 209 1.86 99.1 1.0**

March **2006 136 1.86 98.6 1.0** April **2006 117 1.47 98.7 1.1** May **2006 98 2.42 97.5 0.9**

June **2006 192 2.65 98.6 1.1** July **2006 128 1.82 98.6 1.3** August **2006 276 1.37 99.5 1.0** September **2006 181 2.93 98.4 1.1**

2006-Ave 161 2.37 98.3 1.1

* Low level testing of effluent by EPA Method 1631 be gan in March, 2004**12** 

## Appendix D Sewer Use Ordinance Language Regarding Amalgam Sepa rator Installation/Maintenance and Implementation of Wisc onsin Dental Association BMPs for Amalgam Waste

Section 5.1.6 Discharges from dental clinics

**(a) This section applies to discharges from dental clinics where amalgam is**  **placed or removed. This section does not apply to the specialties orthodontics, periodontics, o**  **ral and maxillo-facial surgery, endodontics, prosthodontics or to other clinics that do no**  **t place or remove amalgam, or which are identified by the District as de-mi**  **nimus contributors. For the purpose of this section, a dental clinic is defined as a non-m**  **obile facility dedicated to the examination and treatment of patients by healthc**  **are professionals specializing in the care of teeth, gums, and oral tissues.** 

**(b) Within the shortest reasonable time, but no later than (INSERT DATE if not**  **December 31, 2008), dental clinics that place or remove amalgam shall implement bes**  **t management practices for amalgam as established by the Wisconsin Dental Associati**  **on.**

**(c) Within the shortest reasonable time, but no later than (INSERT DATE if not**  **December 31, 2008), dental clinics shall install, operate and maintain an amalgam sep**  **arator meeting the criteria of the International Standards Organization (ISO 11143) for every vac**  **uum system receiving amalgam waste. Amalgam separators shall be install**  **ed, operated, and maintained according to instructions provided by the manufacturer. The amalga**  **m separator shall have a design and capacity appropriate for the size and t**  **ype of vacuum system.** 

**(d) If a dental clinic is implementing the requirements in 5.2.5(b) and 5.2.5(c), any numeri**  **cal discharge limit for mercury established in this chapter does not apply.** 

**(e) Starting (INSERT DATE if not June 1, 2007) and annually thereafter, dental clinics**  **will submit reporting information to the District using forms provided by the Dis**  **trict. Reporting information will include:** 

**1. The date the amalgam separator was installed** 
**2. The manufacturer name and model number of the separator** 
**3. Certification that the amalgam separator was installed and is bei**  **ng operated and maintained in accordance with instructions provided by the manufacturer.** 
**4. Certification that best management practices for amalgam as esta**  **blished by the Wisconsin Dental Association are being implemented.** 
**5. The person responsible for assuring compliance with the Amalgam Separat**  **or requirements in the District’s Sewer Use Ordinance.** 

**(f) Dental clinics shall obtain records from the contractors used to remove ama**  **lgam waste for each shipment. The records shall show the volume or mass of amalgam waste**  **shipped, the name and address of the destination, and the name and address of the**
**contractor. Dental clinics shall maintain these records for a minimum of three years.** **13**

**(g) Dental clinics shall allow the District to inspect the vacuum system, am**  **algam separator, amalgam waste storage areas, and other areas deemed necessary by the Di**  **strict to determine compliance with this section. Inspections shall occur by appoint**  **ment during the normal operating hours of the dental clinic as long as advance notice does not imp**  **ede**
**enforcement of this section. 14**  Appendix E Dental Facility Mercury Checklist

Best Management Practices are those defined by the WDA and Installation, Operation, and Maintenance of an Amalgam Separator meeting ISO 11143 Standards.

Facilities complying with the WDA Criteria and the inst allation/maintenance of an amalgam separator meeting ISO 11143 standards shall be considered in compliance with the local sewer use ordinance limit for mercury. It is the inten tion of the Mercury Pollutant Minimization Program to encourage implementation of mercury BMPs.

If you do not place or remove amalgam fillings, check her e_____ sign the bottom of the form, and return it to the following
address:

Directions: Please check either YES or NO , and fill in the date field for each question. When answering YES fill in the date when the BMP was fully implemented in the DATE colum n. When answering NO (a BMP is not fully implemented) fill in the date anticipated in the DATE column.

YES NO DATE

mm/dd/year 1. Has all bulk mercury been eliminated from your stock at your

dental clinic?
2. Does your dental clinic use precapsulated allo ys?

3. Does your dental clinic recycle disposable ama lgam capsules?

4. Does your dental clinic capture and recycle no n-contact scrap

amalgam?
5. Does your dental clinic capture and recycle co ntact amalgam

including the contents of chair-side traps?
6. Does your dental clinic recycle contact amalga m retained by

the vacuum pump filter?
7. Does your dental clinic disinfect and recycle extracted teeth

with amalgam fillings?
8. Does your dental clinic use non-chlorine, non- bleach line

cleaners that minimize the dissolution of amalg am?
9. Does your dental clinic have and maintain an a malgam

separator meeting ISO standards?
9a. If you currently have an amalgam separator, pl ease provide us with the following information.

Manufacturer: ______________________________________________Model :___________________________

Date Installed:

9b. Name and address of vendor where amalgam is re cycled:

Comments:

I have personally examined and am familiar with the i nformation submitted in this document and attachments. B ased upon my inquiry of the individuals immediately responsible f or obtaining the information reported herein, I bel ieve that the submitted information is true, accurate and complete.

Name of Facility _________________________________

______________________________________ Address __________________________________________

_____________________________ Phone _________________________________Fax_______

____________________________ Email of Contact Person ___________________________

____________________________________________

___________________________________________________ __________________________________________ Printed Name Signature Title Date **MMSD Attn: Pretreatment Dept.** 
**1610 Moorland Rd. Madison, WI 53713**