### MEMORANDUM

TO: Public Docket for the Dental Amalgam Effluent Guidelines
EPA Docket Number EPA

- HQ

- OW

- 2014

- 0693

FROM: Jill Lucy, ERG Kimberly Bartell, ERG

DATE: September 22, 2014

SUBJECT: Pollution Prevention Program Costs for Controlling Dental Amalgam Discharges

EPA is proposing technology

- based pretreatment standards under the Clean Water Act (CWA) for discharges of pollutants into publicly owned treatment works ( POTWs ) from existing
and new dental offices that discharge dental amalgam. The proposed rule would require dental
offices to control the discharge of mercury and other metals in dental amalgam into POTWs
based on t he best available technology or best available demonstrated control technology (amalg am separators) and the use of best management practices (BMPs). This memorandum provides supplemental information on costs of dental mercury reduction programs collected from
the literature review in addition to the information presented in the Technical a nd Economic Development Document for the Proposed Effluent Limitations Guidelines and Standards for the Dental Category (EPA 821

- R

- 14

- 006)

.

EPA compiled information on the cost of dental mercury reduction programs, which
included costs associated with t he use of amalgam separators and costs to state and local agencies to implement programs . The costs to local agencies include development of the program and costs for outreach to dentists. Depending on the program, the costs to individual
dental offices wi ll generally encompass purchasing, installing, and maintaining an amalgam separator; recycling the collected amalgam; and other costs, such as time spent educating their employees.

Costs to State and Local Agencies

Table 1 shows the costs of several pollution prevention program elements estimated by
the Association for Metropolitan Sewerage Agencies ( AMSA ) and the Oregon Association of Clean Water Agencies (ACW A). These cost estimates are based on the actual costs to develop and implement pollution prevention programs. Dental offices are t he focus of each of the pollution prevention programs presented in Table 1

.

### Memorandum September 22, 2014 Page 2

Table 1

. Costs to State and Local Agencies to Implement Pollution Prevention Programs Targeted to Dental Offices

Program Description Total Cost ($2010) Number of Participants Source

San Francisco, CA Brochure/fact sheets + distribution $81,631 900 Larry Walker Associates, 2002

San Francisco, CA Site visits $16,306 35 visits Larry Walker Associates, 2002

Palo Alto, CA Brochure/fact sheets + distribution $16,306 500 Larry Walker Associates, 2002

Palo Alto, CA Outreach/advisory group $13,571 500 Larry Walker Associates, 2002

Western Lake Superior District, MN Outreach $40,815 100 Larry Walker Associates, 2002

Salem, OR Staff labor $8,437 109 ACWA, 2007

Salem, OR Inspection or other form of contact $4,942 109 ACWA, 2007
Oregon State All costs a in 2004 $4,001 53 ACWA, 2007
Oregon State All costs a in 2005 $1,438 26 ACWA, 2007
Oregon State All costs a in 2006 $6,462 36 ACWA, 2007

a

– “All costs” include site visits, staff labor, outreach including brochures/fact sheets, and inspections.



### Costs to Dental Offices

The major costs to dental offices to implement mandatory or voluntary pollution prevention programs are the costs to pu rchase and maintain an amalgam separator and the costs to collect and recycle amalgam waste. Most pollution prevention programs recommend, if not require, dental offices to install amalgam separators. Dentists have three options for obtaining amalgam separ ators:

**•** 

### Purchase the unit and maintain it themselves;

**•** 

### Purchase the unit and contract a company to maintain it; or

**•** 

### Lease the unit, with maintenance service inclusive in the fee.

Amalgam separator life

- cycle costs can include (McManus & Fan, 2003; PACE, 200 7; MMSD & University of Wisconsin

-- Extension, 2006):

**•** 

### Purchase or lease cost;

**•** 

### Installation cost;

**•** 

### Replacement parts costs;

**•** 

### Maintenance supplies costs;

**•** 

### Inspection costs;

**•** 

### Maintenance costs;

**•** 

### Recycling preparation; and

**•** 

### Recycling costs.

### Memorandum September 22, 2014 Page 3

Manufacturer suggested retail prices (MSRP) for an amalgam separator range from $210 to $3,984 (depending on the size of the dental office). EPA found little information on lease arrangements; information indicates that purchasing is more common. Table 2 provides a summary of costs of commercially available amalgam separator systems (non

- inclusive), including specific operation and maintenance costs for each model in 2010 dollars. 1



### Cost of amalgam separators can vary, but are relative to the size of the dental practice. The number of amalgam separators to be installed depends on the number of chairs in an office and the amalgam separator model. The wa stewater flow rate determines how often filters and traps need to be cleaned/replaced (Walsh, 2007).

EPA used the data from these two tables to develop compliance cost estimates. Costs include amalgam separator installation and start

- up costs:

**•** 

### Equipment purchase Table 2 : EPA calculated the average retail costs from

.

**•** 

### Equipment installation cost

**•** 

### : EPA estimated installation costs based on meeting with an amalgam separator vendor (ERG, 2010).

Initial baseline monitoring report cost

**•** 

### : EPA calculated the time needed for a dental office representative to complete the initial baseline monitoring report (see U.S. EPA, 2011).

One

- time 90

- day compliance report c ost

Annual (recurring costs) include: : EPA calculated the time needed for a dental office representative to complete the compliance report (see U.S. EPA, 2011).

**•** 

### Replacement parts costs Table 2 : EPA used the average costs from

.

**•** 

### Operation and maintenance (O&M) costs

**•** 

### : Some separator models require weekly maintenance while others require only annual maintenance. EPA assumed maintenance would be performed by the dental office every two weeks and that each maintenance session would take 15 minutes of a dental assistant’s time ($17/hr). O&M costs include recommended routine visual inspections. EPA assumed a dental assistant ($17/hr) would perform a visual inspec tion monthly and that each inspection would require five minutes of the dental assistant’s time.

Recycling preparation
Table 2 : Most separators require that their solids collectors and/or filters be replaced every 12 months. The replacement frequencies in range from quarterly replacement to once every four years. If an office uses a recycling service, then the office will send the replacement parts to th e recycler every time the

1 Mention of product and vendor names does not constitute an endorsement by EPA.

### Memorandum September 22, 2014 Page 4

part is switched out. EPA assumed that a dental assistant ($17/hr) would spend 15 minutes two times per year preparing materials for shipping and recycling.

**•** 

### Recycling service costs Table 2 : EPA calculated the average recycling cost from

. Some manufacturers include the recycling costs as part of the unit purchase price. The range of recycling service costs provided by vendors is $0 (some include recycling costs as part of the original purchase cost) to $316 per recycling event. Assuming a conservative estimate of recycling every two years, the maximum annual cost for recycling service is $158 per year. EPA estimated recycli ng costs as the average of the range ($0 to $158), or $79 per year, for all dental office sizes.

**•** 

### Annual certificati on cost s : EPA calculated the time needed for a dental office representative to complete the annual cer tification (see U.S. EPA, 2011).

### Memorandum September 22, 2014 Page 5

Table 2 . Cost of Purchasing, Operating, and Maintaining Amalgam Separators ($2010)

Model Manufacturer MSRP Maintenance Replacement Parts Recycling? Reference

A1250 Air Techniques $1,000 Replace filter every 6

– 12 months. Filter: $250 Not Included 7

AD

- 1000 American Dental
Accessories $809 Replace filter every 18 months. Filter: $504 Not Included 2

Amalgam Boss M.A.R.S. Bio

- Med

Processes $1,015 Unit switch out after 2 years for 1 chair, 1.5 years for 2

– 3 chairs and 1 year for 4

– 10 chairs. Separator unit: $1,015 Included 1, 3

Amalgam
Collector

— CE18 R & D Services $839

– $1,220 Recycle every 3 years; adjust liquid level tube every 6 months. Recycling service: $254 Not Included 1

Amalgam
Collector

— CE24 R & D Services $1,265

– $1,647 Recycle every 3 years; adjust liquid level tube every 6 months. Recycling service: $305 Not Included 1

Amalgam
Collector

— CH12 R & D Services $605

– $986 Recycle every 4 years; adjust liquid level tube every 6 months. Recycling service: $305 Not Included 1

Amalgam
Collector

— CH9 R & D Services $626

– $1,020 Recycle every 3 years; adjust liquid level tube every 6 months. Recycling service: $316 Not Included 2, 4

ARU

- 10 Hygenitek $770

– $803 Replace ion cartridge every 6 months, replace settlement tank every 2 years. Cartridge, settling tanks: $179 Included 5, 6

Asdex AS

- 10 Capsule Technologies $233 Replace filter every 6

– 8 months. Filter: $99 Not Included 1

Asdex AS

- 20 Capsule Technologies $332 Replace cartridge every 6

– 8 months. Cartridge: $198 Not Included 1

Asdex AS

- 20 American Dental
Accessories $300 Replace filter every 6

– 12 months. Filter: $177 Not Included 1, 8

Asdex AS

- 9 American Dental
Accessories $210 Replace filter every 6 months. Filter: $80 Not Included 8

BU10 Dental Recycling
North America $762 Replace canister every 12 months. Canister: $508 Included 1, 9

### Memorandum September 22, 2014 Page 6

Table 2 . Cost of Purchasing, Operating, and Maintaining Amalgam Separators ($2010)

Model Manufacturer MSRP Maintenance Replacement Parts Recycling? Reference

BU30 Dental Recycling
North America $1,418 Replace canister every 12 months. Canister: $762 Included 1, 9

Catch 1000 Plus Rebec Solutions $2,042 Replace canister every 12 months. Canister: $656 (price is for 2 canisters) Included 1, 10

Catch 400 Plus Rebec Solutions $1,204 Replace canister every 12 months. Canister: $656 (price is for 2 canisters) Included 1, 10

Catch 9000 Plus Rebec Solutions $3,984 Replace canister every 12 months. Canister: $910 (price is for 3 canisters) Included 1, 10

ECO II Pure Water Development $570 Replace canister every 12 months. Canister: $209 Not Included 1

Hg5 SolmteX $762 Replace cartridge every 6

– 12 months. Cartridge: $304 Included 1, 11

Hg5 High Volume SolmeteX $2,500 Replace cartridge every 12 months. Cartridge: $170

– $285 Not Included 1, 11

Hg5 Mini SolmeteX $762 Replace cartridge every 6

– 12 months. Cartridge: $304 Included 1, 11

Liberty Boss M.A.R.S. Bio

- Med

Processes $1,574 Unit switch out after 3 years for 1

– 3 chairs, 2 years for 4

– 10 chairs, 1 year for

11

– 17 chairs. Separator unit: $1,574 Included 1

Merc II Bio

- Sym Medical $1,300 Replace cartridge every 12 months. Cartridge: $495 Included 5

MRU10 Dental Recycling
North America $1,250 Replace canister every 12 months. Canister: $1,195 Included 2, 9

MRU30 Dental Recycling
North America $1,795 Replace canister every 12 months. Canister: $1,395 Included 9

MSS 1000 Maximum Separation Systems $1,288 Replace settling tank every 12 months. Settling tank: $178 Not included 2, 3

MSS 2000 Maximum Separation Systems $1,418 Replace settling tank every 12

– 18
months. Settling tank: $168 Not included 2

MSS 601 Maximum Separation Systems $1,167 Replace settling tank every 12 months. Settling tank: $178 Not Included 3

Rasch 890

- 1000 AB Dental Trends $1,251 Replace canister every 12

– 18 months Canister: $627 Included 2, 4

### Memorandum September 22, 2014 Page 7

Table 2 . Cost of Purchasing, Operating, and Maintaining Amalgam Separators ($2010)

Model Manufacturer MSRP Maintenance Replacement Parts Recycling? Reference

Rasch 890

- 1500 AB Dental Trends $731 Replace canister every 12

– 18 months Canister: $627 Included 1, 4

Rasch 890

- 4000 AB Dental Trends $1,352

– $1,931 Replace canister every 18 months Canister: $660

– $1,319 Included 2

Rasch 890

- 6000 AB Dental Trends $700 Replace canister every 12

– 18 months Canister: $628 Included 1, 4

Rasch 890

- 7000 AB Dental Trends $1,132 Replace canister every 12

– 18 months. Canister: $627 Included 1, 4

Rasch AD

- 1500 American Dental
Accessories $675 Replace filter every 18 months. Filter: $470 Included 1, 8

REM2000
Series/Catch 1000 Rebec Solutions $2,028 Replace cartridge every 12 months. Cartridge: $452 Included 1, 10

REM2000
Series/Catch 400 Rebec Solutions $1,204 Replace cartridge every 12 months. Cartridge: $452 Included 1, 10

REM2000
Series/Catch 9000 Rebec Solutions $3,984 Replace cartridge every 12 months. Cartridge: $808 Included 2, 10

Average Cost for 1 to 2 Chairs $408

– $596 $195

Average Cost for 3 to 5 Chairs $552

– $645 $231

Average Cost for 6 Chairs $1,055

- $1,060 $430

Average Cost for 7+ Chairs $1,509

- $1,552 $629

- $664

Sources: (1)

– U.S. Air Force, 2011; (2)

– MCES, 2009; (3)

– MMSD & University of Wisconsin

- Extension, 2006; (4)

– ADA, 2007; (5)

– McManus & Fan, 2003; (6)

– SF Environment, 2005; (7)

– ERG & Air Techniques, 2011; (8)

– ERG & American Dental Accessories, 2011; (9)

– ERG & DRNA, 2011; (10)

– ERG & Rebec Solutions, 2011; (11)

– ERG & SolmeteX, 2011.

### Memorandum September 22, 2014 Page 8

References

ACWA. 2007. Oregon Association of Clean Water Agencies. EPA Comment Letter

— Docket

ID No. EPA

- HQ

- OW

- 2006

- 0771. December. Document Contro l Number ( DCN)
DA00240

ADA (American Dental Asso ciation). 2007

. ADA Professional Product Review

. DCN DA00043.

ERG (Eastern Research Group). 2010. SolmeteX meeting minutes for 15 December 2010

. Chantilly, VA. DCN DA00081

.

ERG & Air Techniques. 2011. Notes from telephone conversation between Kimberly Landick, ERG, and Air Techniques, March 2, 2011: Subject Amalgam Separator Questions. DCN

DA00060.

ERG & American Dental Accessories. 2011. Email correspondence between Kimberly Landick, ERG, and Am erican Dental Accessories, February 28, 2011: Subject Request for Amalgam Separator Information. DCN DA00061.

ERG & DRNA. 2011. Notes from telephone conversation between Kimberly Landick, ERG, and Marc Sussman and Darwin Moreira, DRNA, March 1, 2011: Subje ct Amalgam Separator Questions. DCN DA00062.

ERG & Rebec Solutions. 2011. Notes from telephone conversation between Kimberly Landick, ERG and Rebec Solutions, March 2, 2011: Subject Amalgam Separator Questions. DCN
DA00063.

ERG & SolmeteX. 2011. Notes from telephone conversation between Kimberly Landick, ERG and SolmeteX, March 2, 2011: Subject Amalgam Separator Questions. DCN DA00064.

Larry Walker Associates . 2002. Mercury Source Control and Pollution Prevention Program Evaluation, Final Report. Prepared f or AMSA (Association for Metropolitan Sewerage Agencies). March (Updated July). DCN DA00006.

MCES (Metropolitan Council Environmental Services). 200 9

. Revised

– Features of Approved Amalgam Separators

. March

. DCN DA000 70

.

McManus, K.R., and P.L. Fan. 2003. Purchasing, Installing and Operating Dental Amalgam Separators. Journal of the American Dental Association 134:1054

- 1065. DCN DA00162

.

MMSD & University of Wisconsin Extension. 2006. Amalgam Management for Dental Offices

. http://www4.uwm.edu//shwec/public ations/cabinet/pdf/DentalAmalgam2.pdf. DCN

DA00232.

PACE. 2007. Partners for A Clean Environment. Amalgam Separator Buyer’s Guide

. Spring

2007. DCN DA00 206

.

### Memorandum September 22, 2014 Page 9

SF Environment. 2005. San Francisco Department of the Environment. San Francisco City and County Li st of Approved Amalgam Separators

. March. DCN DA00077.

U.S. Air Force. 2011. Synopsis of Dental Amalgam Separators

. January 24. Dental Evaluation &
Consultation Service. DCN DA00079.

U.S. EPA. 2011. EPA Analysis: Part 441 Option Cost Calculations

. MS ExcelTM file. Office of Water. Washington, DC. DCN DA00146.

Walsh, William. 2007. The American Dental Association’s (ADA) Comments on EPA’s Study of a Pretreatment Requirement for Dental Amalgam

. Pepper Hamilton, LLP. December

21

. DCN DA00 238

.