P" "7

King County

Wastewater Treatment Division

Department of Natural Resources and Parks

King Street Center, KSC-NR-050 0

201 South Jackson Street

Seattle, WA 98104-3855

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 20460

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 07
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Water Docket ID No . EPA-HQ-OW-2006-077 1

December 19, 2007

Page 2

Economic impacts

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 methods

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 Biosolids
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Water Docket ID No . EPA-HQ-OW-2006-077 1

December 19, 2007

Page 3

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 anticipated

number 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.

Background

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.
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Water Docket ID No. EPA-HQ-OW-2006-077 1

December 19, 2007

Page 4

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