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King County Wastewater Treatment Division Department of Natural Resources and Parks King Street Center, KSC-NR-050 0 201 South Jackson Street Seattle, WA 98104-385 5 December 19, 2007 Water Docket, Environmental Protection Agency Attention : Docket ID No . EPA-HQ-OW-2006-0771 Mail Code : 4103 M 1200 Pennsylvania Avenue NW Washington, DC 2046 0 Preliminary Effluent Guidelines Program Plan for 2008 To Whom It May Concern : King County Wastewater Treatment Division (WTD) appreciates the opportunity to submit these comments on the Preliminary Effluent Guidelines Program Plan for 2008 proposed by the U .S . Environmental Protection Agency (EPA) in the October 30, 2007 Federal Register (72 Fed . Reg . 209) . This letter summarizes our comments on effluent guidelines implementation issues
. Background King County operates three regional sewage treatment plants that serve a population of over two million people, and treats more than 190 million gallons per day of wastewater . Since approval of our pretreatment program by the EPA in 1981, we have achieved significant reductions in heavy metal pollutants in both influent and biosolids . The quality of effluent and biosolids produced at King County wastewater treatment plants meets or surpasses the National Pollutant Discharge Elimination System limits and biosolids criteria . The existing combination of local and federal limits is providing sufficient protection for the environment
. The King County Industrial Waste Program (KCIW) has a 2 .7 million dollar annual budget, which includes 18 .5 full-time equivalent employees . We are part of the Wastewater Treatment Division of King County's Department of Natural Resources and Parks

. Comments Our comments on the Preliminary Effluent Guidelines Program Plan for 2008 pertain primarily to industrial categories not currently subject to pretreatment standards . We do not have facilities that fall under three of the four categories that are the focus of detailed studies : Steam Electric Power Generating (Part 423), Coal Mining (Part 434), and Oil and Gas Extraction (Part 435)

. We do have facilities in the Health Services Industry
. 1 . Health Services Industry - sources of dental mercury : King County WTD believes that national categorical standards addressing Health Services Industry sources of dental mercury are unnecessary at this time, for the following reasons : CREATING RESOURCES FROM WASTEWATER DEC 24 2 0 07p . 2

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Economic impact s We are particularly concerned about the potential economic impacts if categorical standards are promulgated for sources of dental mercury. King County has been able to work with the local dental community and its citizens to develop a relatively low-cost method of achieving measurable reductions of mercury in our biosolids with a continued, documented 94 percent compliance rate . We do not believe the additional resources that would be required of local pretreatment programs to implement categorical standards are justified
. Pollution prevention method s Categorical limits may hinder local adoption of pollution prevention models, including Best Management Practices that achieve each region's goals for mercury reduction

. Effectiveness of local voluntary programs vs . enforcement In 1995, King County decided to implement an extensive voluntary program for dental offices, administered by the Local Hazardous Waste Management Program in King County (LHWMP) . This voluntary program ultimately proved ineffective . After five years of extensive outreach, less than 25 of the approximately 900 general practice dental offices in our service area had installed amalgam separator units (ASUs) to reduce mercury discharges in their wastewater . In 2001, KCIW elected to enforce existing pretreatment regulations and require that dentists demonstrate compliance with regulations either by installing an approved ASU or applying for a permit to discharge wastewater . Dental offices choosing to install an ASU were not required to sample their wastewater or submit any paperwork documenting compliance

. In 2004, the first complete year after full implementation of this program, the loading of mercury had declined dramatically in our biosolids . (See graph below .) We have not seen any evidence of pass-through resulting from mercury sources from dental offices

. It is most likely that mercury from this source ends up in the biosolids

. King County Biosolids Data 3
` ■ West Treatment Plant (primarily residential ) di South Treatment Plant 2 (more industrial ) O

0 2000 2001 2002 2003 2004 2005 2006 Annual Median Mercury Concentration in Biosolidsp . 3

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KCIW was able to pursue its no-permit-needed approach because : • research indicated dental offices could meet local discharge limits for mercury (0 .2 mg/1) if they installed an ISO certified ASU ; • Seattle & King County Public Health Department planned site visits to each dental office that KCIW could use to distribute information and track initial compliance ; • KCIW, as a relatively small program, had insufficient staff to process the anticipatednumber of applications that would have been submitted had a permit or selfcertification process been required ; and, • the uniformly high level of education and prescribed ethical standards of the dental community created the expectation that it would comply with required regulations . Backgroun d During the past 13 years, LHWMP and KCIW have worked extensively with the area dental industry's wastewater discharges to the sewer system . KCIW has gained the experience to assess effectiveness of local programs for reducing mercury discharges from dental facilities . We have not seen any evidence of pass through resulting from mercury sources from dental offices . It is most likely that mercury from this source ends up in the biosolids . Program documentation and data is available per request . 2 . Health Services Industry
- unused pharmaceuticals : King County WTD believes that categorical standards addressing unused pharmaceuticals may not be necessary at this time . The following supports our opinion : • King County already explicitly prohibits the disposal of pharmaceuticals to the sewer from hospitals . • The county is successfully administering discharge approvals to area hospitals that discharge wastewater to the King County sewage system . • Local hospitals are currently managing their unused pharmaceuticals by returning them to reverse distributors or designating them as hazardous waste . • The Washington State Department of Ecology has recently developed an Interim Enforcement Policy for Pharmaceutical Waste with a goal of "easiest on-site management for pharmaceutical waste ." KCIW has advised hospital pharmacies to employ this policy . It is our conclusion that these methods can be successfully employed to control the disposal of unused pharmaceuticals to the sewer as effectively as, or even more so than, the use of categorical standards . Note that our comments are restricted to the hospital sector (where we have experience) and not doctors' offices, laboratories, and other health service facilities cited in the preliminary plan.p . 4

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Background By 2002, KCIW developed and issued industrial wastewater discharge authorizations to area hospitals after considerable study and collaboration with this sector . The discharge authorizations stated that all pharmaceuticals were not acceptable to the sewer, advising that hospitals instead manage their unused pharmaceuticals by returning them to reverse distributors, or designating them as hazardous waste and disposing of them suitably
. The authorizations listed Best Management Practices for the substances most commonly found in hospitals that were in some cases discharged to the sewer . In 2007, KCIW renewed all of the hospital discharge authorizations with the same restrictions
. Program documentation and data is available per request
. If you have any questions regarding these comments, please contact Despina Strong, KCIW program supervisor, at 206-263-3010 or despina.strong@kingcounty .gov. Thank you for your consideration. Sincerely,

C Division Di ecto r King County Wastewater Treatment Division