2 Ernest Street Providence, Rhode Island 02905 401 461-8848 401 461-0170

September 18, 2009

Dr. Michael L. Rubinstein Certified Mail

Drs. Rubinstein & Ducoff, Inc. Return Receipt Requested

362 Ives Street 91 7108 2133 3935 5478 7224

Providence, RI 02906

Dear Dr. Rubinstein:

Your application for issuance of a Wastewater Discharge Permit has been reviewed and 

processed in accordance with the Rules And Regulations For The Use Of The Wastewater 

Facilities Within The Narragansett Bay Water Quality Management District (Rules and 

Regulations).

Enclosed please find Wastewater Discharge Permit #P9400-280-0914 which becomes effective 

on October 1, 2009 and covers the wastewater discharges from the above-referenced facility into 

the Narragansett Bay Commission's (NBC) sewer system. All discharges from this facility and 

actions and reports relating thereto must be in accordance with the terms and conditions of this 

permit.

If you wish to appeal or challenge any conditions imposed by this permit, a petition must be filed 

within fifteen (15) days from receipt detailing all requested modifications or revisions. Failure to 

petition for reconsideration of the permit is deemed a waiver by the permittee of the right to 

challenge the terms of the permit. Filing a petition shall not relieve you of your obligation to 

comply with this permit. You must comply with the terms of this permit until the permit is 

modified, terminated, or revoked.

The NBC will only accept submittals on behalf of your firm from the individuals indicated on the 

cover page of the permit. Should you wish to authorize someone other than the persons indicated 

on the permit to make submittals on behalf of your firm, you should complete the enclosed 

Designation of Authorized Agent form and return it to this office within fifteen (15) days of 

receipt of this permit.

Please note that the NBC can assess Civil and Administrative penalties of up to $25,000 per 

violation per day should violations of the NBC Rules and Regulations or permit conditions 

occur. The enclosed Certificate of Discharge must be prominently posted on the wall in your 

firm.
Page 2

If you have any questions regarding this letter or provisions of your discharge permit, feel free to 

contact the Pretreatment Office at 461-8848, ext. 490.

Sincerely,

/s/ Kerry M. Britt

Kerry M. Britt

Pretreatment Manager

KMB:sm

Enclosures

cc: Kyle Gannon
WASTEWATER DISCHARGE PERMIT

Permit Number: P9400-280-0914

Company Name: DRS. RUBINSTEIN & DUCOFF, INC.

Facility Address: 362 Ives Street, Providence, RI 02906

Mailing Address: 362 Ives Street, Providence, RI 02906

Facility President: Dr. Michael L. Rubinstein

Facility Authorized Agent: Dr. Robert J. Ducoff

User Classification: Dental Operations

Categorical Standards Applicable: None

By virtue of Rhode Island's General Laws Title 46 Chapter 25 (Act) and in accordance with the 

Rules And Regulations For The Use Of Wastewater Facilities Within The Narragansett Bay 

Water Quality Management District (Rules and Regulations), Dr. Michael L. Rubinstein and 

Drs. Rubinstein & Ducoff, Inc. hereinafter referred to as Permittee, is hereby authorized to 

discharge process wastewater from the above identified facility in accordance with the terms and 

conditions set forth in this permit.

All discharges authorized herein must be consistent with the effluent limitations, monitoring 

requirements and other conditions set forth in this permit. The discharge of any pollutant not 

identified in this permit or any pollutant identified in this permit at a level in excess of that 

authorized shall constitute a violation of the permit. This permit consists of 14 pages with 

conditions A - T and Attachment A.

This permit is effective on October 1, 2009

and expires on September 30, 2014.

Noncompliance with any term or condition of this permit shall constitute a violation of the 

NBC's Rules and Regulations and may subject the user to an Administrative or Civil Penalty of 

up to $25,000 per violation per day as defined in R.I.G.L. §46-25-25.2. Willful or criminally 

negligent violations shall be punishable by the aforementioned fine and/or imprisonment as 

defined in R.I.G.L. §46-25-25.3.
2

For the Narragansett Bay Commission:

/s/Kerry M. Britt September 18, 2009

Kerry M. Britt, Pretreatment Manager Date

Narragansett Bay Commission

NOTE: The NBC will accept the person(s) named on this permit as the Permittee's

authorized agent(s) until notified otherwise.

An authorized agent or authorized company representative is a person who is a

principal executive officer or other corporate officer with signatory powers as per the

Permittee's by-laws or per a vote of the directors if the Permittee is a corporation;

a general partner or proprietor if the Permittee is a partnership or sole proprietorship

respectively; or a duly authorized representative of an individual designated above

if such representative is responsible for the overall operation of the facility and has

the authority to sign contracts, permits, permit applications, monitoring results and

other documents in the company's name and otherwise bind the Permittee. The

Permittee may designate additional or new authorized agents by completing and

submitting the enclosed Designation of Authorized Agent form.

The NBC will not accept documents signed by persons other than the Company's

authorized agent(s) or authorized representative(s).
3

CONDITIONS TO PERMIT

A. Effluent Discharge Limitations:

1. The permittee shall at all times comply with the effluent limitations specified in Table 1 on 

page 13, attached hereto and incorporated herein.

2. The permittee shall comply with all discharge limitations and prohibitions contained in 

Article 5 of the NBC's Rules and Regulations, as well as all other provisions of those Rules, 

and any other applicable State or Federal standards, including but not limited to the Federal 

Water Pollution Control Act, 33 U.S.C. §1251 et seq. and R.I.G.L. §46-12-1 et seq. The 

permittee shall at all times comply with 40 CFR §403.5 and may not introduce into the 

NBC's facilities any pollutants which shall violate the general or specific prohibitions 

including but not limited to discharges resulting in pass through or interference situations at 

the NBC's facilities.

3. The permittee shall not increase the use of process water or dilute a discharge in any way as 

a partial or complete substitute for adequate treatment to achieve compliance with the 

above standards.

4. The permittee is classified as a dentist and therefore, must at all times comply with the 

NBC Best Management Practices for the Management of Waste Dental Amalgam.

B. Permitted Discharges:

1. The permittee is authorized to discharge the following tanks, solutions or process 

wastewater streams to the NBC's facilities:

a. Treated Dental Wastewater Containing Amalgam;

b. Dental Process Wastewaters.

2. No other process wastewater is to be discharged to the sewer unless specifically approved 

by the NBC in writing.

C. Prohibitions:

1. The permittee is strictly prohibited from discharging any prohibited substances as detailed 

in the Rules and Regulations of the Narragansett Bay Commission. Prohibited discharges 

include, but are not limited to, the following:

a. X-Ray Processing Rinsewater, Developer, and Fixer Solutions;

b. Dental Amalgam;

c. Elemental Mercury;
4

d. Untreated Dental Wastewater Containing Amalgam;

e. Acidic Solutions with a pH less than 5.0 Standard Units;

f. Caustic Solutions with a pH greater than 11.0 Standard Units;

g. Solvents;

h. Sludges.

2. The permittee is strictly prohibited from discharging any process wastewater streams other 

than those specified in Section B(1) of this permit or wastestreams containing pollutants 

with concentrations in excess of the effluent limitations specified in Table 1 on page 13, 

attached hereto and incorporated herein.

3. Non-sanitary discharges other than those specified in Section B of this permit are 

prohibited unless specifically approved by the NBC in writing.

4. No chemicals, oils, solutions and/or materials including solid substances such as towels, 

casts, etc. in quantities or of such size capable of causing obstruction to the flow in sewers 

may be discharged to the sewer unless specifically approved by the NBC in writing.

5. Discharging of chemicals or solutions containing materials listed in the attached list of 

Toxic Pollutants (Table 2) is strictly prohibited if said discharge would result in violation of 

NBC limitations in Table 1.

D. Pretreatment Requirements:

1. The permittee must provide and maintain an easily accessible sample location downstream 

of each process discharge specified in Section B(1) of this permit. A total of one (1) 

sample location must be provided and must collect wastewater from the process operations 

indicated as follows:

Sample Location #1 – Sample port on the discharge line of the amalgam separator, 

collecting all process discharges specified in Section B(1)(a) of 

this permit.

The permittee is prohibited from discharging dilution wastestreams, such as sanitary and 

non-contact cooling water into any process wastewater sampling location. Dilution 

wastestreams must discharge downstream of the process wastewater sampling location. 

The discharge through Sample Location #1 must be in compliance with the effluent 

limitations specified in Section A and Table 1 of this permit. 

2. The permittee is responsible for properly operating and maintaining the pretreatment 

system to achieve and ensure compliance with the conditions of this permit. Proper 

operation and maintenance shall include but not be limited to: effective performance, 

adequate funding, adequate operator staffing and training, adequate laboratory and process 

controls, including appropriate quality assurance procedures.
5

3. The permittee shall adhere to Option 1 and all mandatory best management practices of the 

NBC’s Best Management Practices on the management of Waste Dental Amalgam.

4. In accordance with Option 1 of the NBC’s Best Management Practice for the Management 

of Waste Dental Amalgam, the permittee shall install, operate and maintain an amalgam 

separator which is ISO 11143 certified to an efficiency of 99% removal in accordance with 

the plans submitted to the NBC on May 5, 2004. The amalgam separator shall be fully 

operational whenever discharges from dental procedures are occurring. 

5. The permittee shall maintain the amalgam separator. Maintenance activities include but are 

not limited to the following:

a. The permittee must inspect the separator weekly to ensure proper operation;

b. The permittee must adhere to all manufacturers specifications for maintenance of 

the separator;

c. The maintenance activities must be documented in a logbook as required by Section 

G(2) of this permit.

6. The permittee shall maintain chair side traps on all dental chairs to capture large amalgam 

particles from cuspidors and vacuum systems. Chair side traps must be inspected daily and 

cleaned or replaced as necessary. Disposable traps or material from reusable traps must be 

placed in a labeled storage container. The permittee may only rinse a trap if necessary and 

only in a designated sink that is plumbed with appropriate flow restriction to an NBC 

approved amalgam separator.

7. The permittee shall ensure that all vacuum pumps are equipped with filters. The permittee 

shall replace the filter at least once per month or more frequently if necessary. Removed 

filters should be held over a spill tray to capture any accumulated water from the trap. The 

water should be carefully decanted without losing any visible amalgam. The decant water, 

if free of visible amalgam, may be discharged to the sewer through an NBC approved 

amalgam separator. Dry-turbine vacuums must be inspected to ensure there is no built up 

sludge in the air/water separator. Collected sludge must be disposed of properly as a 

mercury containing waste.

8. The permittee shall use a NBC approved cleaner for disinfection of amalgam and/or 

mercury contaminated vacuum lines, instruments or equipment. The use of bleach or 

bleach containing cleaners is strictly prohibited as methyl mercury may be evolved. 

Corrosive and oxidizing cleaners are also prohibited to ensure methyl mercury is not 

evolved.

9. The permittee has designated one (1) sink for sanitary use only. The permittee shall post 

signs at this sink stating “Sanitary Use Only”. Washing of equipment instruments filters 

and capsules in this sink is strictly prohibited.
6

E. Certification of Compliance with Best Management Practice:

The permittee shall submit written annual certification of compliance with Best 

Management Practices for the Management of Waste Dental Amalgam for the period from 

November to October. The Certification must be made on the form designated as Best 

Management Practice Certification, Attachment A, and must be received within thirty (30) 

days after the period for which the certification is being made.

F. Monitoring Requirement:

No regularly scheduled wastewater monitoring reports are required of the permittee. The 

NBC may, at any time, require monitoring. Conditions that may result in the imposition of 

monitoring include, but are not limited to, the following:

a. Failure to meet effluent limitations;

b. Change in production processes;

c. Expansion or reduction of production;

d. Change in water usage;

e. Discovery of additional information on monitoring or production unavailable to the 

NBC at the time this permit was prepared.

G. Record Keeping Requirements:

1. The permittee shall be responsible for maintaining a logbook documenting all records 

pertaining to the operation of the x-ray processor including but not limited to, the 

following:

a. Amount of chemicals used (i.e. fixer, developer, etc.);

b. Completed manifest forms for hazardous materials.

2. The permittee shall be responsible for maintaining a logbook documenting all records 

pertaining to the amalgam separator including but not limited to the following:

a. Date (month, day and year) of each trap and separator inspection and service 

activity;

b. The location of each trap and separator being serviced;

c. All routine and non-routine activities conducted (i.e. cleaning, maintenance, filter 

replacement);

d. Signature of person conducting activity.
7

3. Records which substantiate any information supplied in permit applications, SelfMonitoring Compliance Reports and any other informational requirements of the Rules and 

Regulations or any applicable State or Federal law are to be kept by the permittee for a 

period of at least three (3) years unless a dispute or litigation involving the subject of those 

records is pending, in which case these records are to be kept by the permittee for a period 

of at least three (3) years following resolution of such litigation or dispute.

H. Emergency/Routine Notification Requirements:

1. Emergency Notification of Accidental/Incidental Discharge

The permittee must maintain all associated facilities to ensure that incidental and accidental 

spills are not able to enter the NBC sewer system. In the case of an accidental discharge 

into the NBC facilities, including any discharge that would violate a Federal 

prohibition under 40 CFR 403.5(b), it is the responsibility of the permittee to notify 

the NBC of the incident immediately by calling the Pretreatment Section at 461-8848 

or during non-business hours at its twenty-four (24) hour Emergency Hotline 

Number, 222-6781. Within five (5) days following an accidental discharge, the permittee 

shall submit to the NBC a detailed written report describing the cause and volume of the 

discharge and the measures to be taken by the user to prevent similar future occurrences by 

the permittee.

2. Routine Notification of Operational Changes

The permittee must notify the NBC in writing at least thirty (30) days prior to instituting 

any changes in operations that may affect the quality or quantity of the process wastestream 

discharged to the sewer system or may affect the adequacy of spill control measures. 

Operational changes that may affect the quality or quantity of the process wastestream or 

the adequacy of spill control measures include, but are not limited to, the following:

a. Addition, removal, or relocation of process tanks or solutions;

b. Installation of new wastewater generating process operations;

c. Relocation of process operation piping or valving resulting in a new or different 

point of discharge;

d. Modification of any pretreatment process or procedure;

e. Installation or modification of pretreatment equipment or associated piping.

Should the permittee be unsure as to whether an operational change requires written NBC 

notification, it is strongly recommended that the permittee contact the NBC by telephone 

prior to instituting the proposed change in operations. This will ensure that the proper 

notification is provided to the NBC. With respect to the thirty (30) day written notification 

requirement, should the permittee require immediate approval to make an operational 

change in order to accommodate business, the NBC will make every effort to accommodate 

the permittee so as to not impede operations at the facility. The discretion used by the NBC 

with respect to this issue is dependent on the magnitude of the proposed operational 

changes and the resulting effect on the characteristics of the wastestream and/or the spill 
8

control measures at the facility. The permittee may notify the NBC of the following 

operational changes by telephone rather than in writing as required above:

f. Change from the hours of facility operation specified in the discharge permit 

application;

g. Change in the personnel responsible for the proper operation of pretreatment 

equipment.

3. Routine Notification of Pretreatment Equipment Malfunctions

In the event of pretreatment equipment failure or malfunction, the permittee must notify the 

NBC of the incident by the close of the next full business day by calling the NBC's 

Pretreatment Section at 461-8848. Pretreatment equipment failure includes, but is not 

limited to, the following:

Amalgam Separator Failure

Any equipment failure or malfunction which results in a spill and/or accidental discharge 

must be reported immediately in accordance with the NBC Emergency Spill Notification 

Procedure. Should a pretreatment equipment failure or malfunction occur, the permittee is 

strictly responsible for complying with all other permit conditions, including, but not 

limited to, maintaining full compliance with effluent limitations and monitoring 

requirements.

I. Right of Entry:

The NBC, upon presenting identification and appropriate credentials, is authorized to enter 

the premises of the permittee during working hours and at other reasonable times for the 

purposes of inspection, sampling, reading water meters, records inspecting and copying and 

as otherwise authorized under R.I.G.L. §46-25-25.1. Reasonable hours in the context of 

inspection and sampling include any time the NBC has reason to believe that violation of 

the permit or of the Rules and Regulations is occurring.

J. Permit Fee:

The permittee agrees to pay an annual permit fee and all sewer user fees assessed by the 

NBC in accordance with rates and fees approved by the Public Utilities Commission 

pursuant to R.I.G.L. §39-1-1 et seq. and §46-25-1 et seq.
9

K. Closing, Selling, Moving the Business:

If the permittee intends to close, liquidate, sell or move the permitted premises, located as 

referenced on page 1 of this permit, the permittee must notify the NBC in writing at least 

thirty (30) days prior to disposing of any process waste associated with the move or the 

cessation of business.

L. Transfer of Permit Prohibited:

Wastewater discharge permits are issued to a specific user for a specific operation. This 

permit may not be reassigned, transferred or sold to a new owner, new user, different 

premises, or a new or changed operation without the express written permission from the 

NBC. The permittee shall provide a copy of this permit to any prospective purchaser of 

said facility referenced on page 1 of this permit at least fourteen (14) days prior to closing 

on the business or property.

M. Permit Violations:

1. Enforcement Costs

The permittee agrees to reimburse the NBC for the cost of enforcing the permit, including 

reasonable attorneys' fees, if violations of the permit are found by a hearing officer during 

the course of an administrative hearing or if such decision is appealed, then in a court of 

competent jurisdiction.

2. Damage to the Facilities

The permittee agrees to indemnify and hold harmless the NBC from and against any 

liability, loss, cost, expense or actual damage (including reasonable attorneys' and 

accountants' fees incurred in defending or prosecuting any claim for any such liability, loss, 

cost, expense or damage) suffered by the NBC and caused by discharges from the 

permittee, either singly or by interaction with other wastes.

3. Violations of the NBC's Permit

The permittee agrees to reimburse the NBC for any penalty and additional operating 

expense incurred by the NBC for violations of the NBC's NPDES, RIPDES, or any other 

state or federal permit which were caused by discharges from the permittee, either singly or 

by interaction with other wastes.
10

4. Penalties for Violations

Article 10 of the NBC's Rules and Regulations provides that any person who violates a 

permit condition is subject to an administrative or civil penalty of up to $25,000 per 

violation per day as defined in R.I.G.L. §46-25-25.2. Willful or criminally negligent 

violations shall be punishable by the aforementioned fine and/or imprisonment as defined 

in R.I.G.L. §46-25-25.3.

N. Revocation/Suspension of Permit:

1. Violations of the conditions of this permit, the NBC's Rules and Regulations, Act, and 

applicable state or Federal regulations may result in the revocation of this permit in 

accordance with the due process requirements of the NBC's Rules and Regulations. 

Violations that may result in revocation of this permit include, but are not limited to, the 

following:

a. Failure to accurately report the wastewater constituents and characteristics of the 

discharge;

b. Failure to report changes in operations or wastewater constituents;

c. Failure to allow NBC personnel statutorily authorized access for the purposes of 

inspection or monitoring;

d. Failure to adhere to an approved compliance schedule;

e. Failure to comply with administrative orders or settlement agreements;

f. Failure to pay authorized fees and user charges;

g. Violation of any other applicable permit conditions.

This list is for illustrative purposes and is not intended to be inclusive.

2. The Executive Director may suspend this wastewater discharge permit should the permittee 

cease operations for any period exceeding one (1) month. The suspension will not act as a 

revocation of the permit, but rather as a temporary suspension of the user's rights under the 

permit while operations have ceased. During such suspension, the user's connection to the 

facilities shall be plugged. The user shall still be required to pay the permit fee, since the 

permit itself will not be revoked. During such suspension, the user shall be disconnected 

from the facility. The Commission shall have the authority to make periodic inspections 

during this time to determine whether the user is continuing to discharge regulated 

wastewater. Such discharge may be considered grounds for revocation of the wastewater 

discharge permit.

O. Civil and Criminal Liability:

Nothing in this permit shall be construed to relieve the permittee from civil and/or criminal 

penalties for noncompliance with the NBC's Rules and Regulations or State or Federal laws 

or regulations.
11

P. Duty To Comply:

1. The permittee must comply with all conditions of this permit. Failure to comply with the 

requirements of this permit may be grounds for enforcement proceedings including 

administrative, civil and/or criminal penalties, injunctive relief and summary abatements.

2. Compliance with this permit does not relieve the permittee of its obligation to comply with 

any or all pretreatment regulations, standards or requirements under local, State and Federal 

laws, including any such regulations, standards, requirements, or laws that may become 

effective during the term of this permit.

Q. Removed Substances:

Solids, sludges, filter residue or other pollutants removed in the course of treatment or 

control of waters or wastewaters shall be disposed of in accordance with §405 of the Clean 

Water Act and subtitles C and D of the Resource Conservation and Recovery Act. A 

Resource Conservation and Recovery Act (RCRA) informational brochure is attached to 

this permit to inform you of your RCRA obligations.

R. Permit Modification/Renewal:

1. This permit may be modified for various reasons, including but not limited to the 

following:

a. To incorporate any new or revised Federal, State, or local pretreatment standards or 

requirements;

b. Material or substantial alterations or additions to permittee's process operations, 

discharge volume or discharge characteristics which were not considered in the 

drafting of this permit;

c. A change in any condition regarding either the industrial user or the POTW that 

requires either a temporary or permanent reduction or elimination of the authorized 

discharge;

d. Information indicating that the permitted discharge poses a threat to the NBC 

collection or treatment system, POTW personnel, the general public, or the 

receiving waters;

e. Violation of any terms or conditions of the permit;

f. Misrepresentation or failure to disclose fully all relevant facts in the permit 

application or in any required reporting;
12

g. Revision of or a grant of variance from such categorical standards pursuant to 40 

CFR §403.13;

h. To correct typographical or other errors in the permit;

i. To reflect transfer of the facility ownership and/or operation to a new 

owner/operator;

j. Upon request of the permittee, provided such request does not create a violation of 

any applicable requirements, standards, laws, or rules and regulations.

The filing of a request by the permittee for a permit modification, revocation and 

reissuance, termination, or a notification of planned changes or anticipated noncompliance, 

does not stay any permit condition.

2. If the permittee wishes to continue to discharge after the expiration date of this permit, an 

application must be filed for a permit renewal in accordance with the requirements of 

Article 8 of the NBC's Rules and Regulations a minimum of ninety (90) days prior to the 

expiration date.

S. Integration:

This permit represents the entire agreement and understanding of the parties hereto to those 

matters contained herein. No prior oral or written understanding shall be of any force or 

effect with respect to those matters covered hereunder. This permit may not be modified or 

altered except in accordance with the provisions of Article 8 of the Rules and Regulations. 

All terms used in this permit shall be construed as defined under Article 2 of the Rules and 

Regulations.

T. Jurisdiction:

This permit shall be administered and interpreted under the laws of the State of Rhode 

Island. Jurisdiction of litigation arising from this permit shall be in the State of Rhode 

Island. If any part of this permit is found to be in conflict with applicable laws, such part 

shall be inoperative, null and void insofar as it is in conflict with said law, but the 

remainder of this permit shall be in full force and effect.

KG:NJD:sm

Attachments:

Designation of Authorized Agent Form

RCRA Handbook

Twenty-four (24) Hour Violation Notification Fax Form
13

Table 1

NBC Effluent Discharge Limitations

Field’s Point District

Parameter Limitation (Max)

Total Toxic Organics (TTO) 2.13

Biochemical Oxygen Demand (BOD5) 300.00*

Total Suspended Solids (TSS) 300.00*

Total Oil and Grease (fats, oils and grease) 125.0

Oil and Grease (mineral origin) 25.0

Oil and Grease (animal/vegetable origin) 100.0

pH range (at all times) 5.0 - 11.0 s.u.

Parameter Daily Maximum

(Composite for 1 day)

(mg/l)

Average

(10 day)

(mg/l)

Cadmium (Total) 0.11 0.07

Chromium (Total) 2.77 1.71

Copper (Total) 1.20 1.20

Cyanide (Total) 0.58 0.58

Lead (Total) 0.60 0.40

Mercury (Total) 0.005 0.005

Nickel (Total) 1.62 1.62

Silver (Total) 0.43 0.24

Zinc (Total) 2.61 1.48

All limitations are in units of mg/l unless otherwise specified.

* Exceeding this discharge limitation may be permitted but would be subject to a surcharge in accordance with rates 

approved by the Public Utilities Commission and in accordance with R.I.G.L. §39-1-1 et seq.

.
14

Table 2

List of Toxic Pollutants

The following list of Toxic Pollutants has been designated pursuant to Section 307(a)(1) of the 

Clean Water Act.

VOLATILES

EPA METHOD 624

BASE/NEUTRAL -

EPA METHOD 625

PESTICIDES -

EPA METHOD 625

acrolein acenaphthene * aldrin

acrylonitrile acenaphthylene * alpha-BHC

benzene anthracene * beta-BHC

bromoform benzidine gamma-BHC

carbon tetrachloride benzo (a) anthracene * delta-BHC

chlorobenzene benso (a) pyrene * chlordane

chlorodibromomethane 3,4-benzofluoranthene * 4,4'-DDT

chloroethane benzo (ghi) perylene * 4,4'-DDE

2-chloroethylvinyl ether benzo (k) fluoranthene 4,4'-DDD

chloroform bis (2-chloroethoxy) methane dieldrin

dichlorobromomethane bis (2-chloroethyl) ether alpha-endosulfan

1,1-dichloroethane bis (2-chloroisopropyl) ether beta-endosulfan

1,2-dichloroethane bis (2-ethylhexyl) phthalate endosulfan sulfate

1,1-dichloroethylene 4-bromophenyl phenyl ether endrin

1,2-dichloropropane butylbenzyl phthalate endrin aldelyde

1,3-dichloropropylene 2-chloronaphthalene heptachlor

ethylbenzene 4-chlorophenyl phenyl ether heptachlor epoxide

methyl bromide chrysene * PCB-1242

methyl chloride dibenzo (a,h) anthracene * PCB-1254

methylene chloride 1,2-dichlorobenzene PCB-1221

1,1,2,2-tetrachloroethane 1,3-dichlorobenzene PCB-1232

tetrachloroethylene 1,4-dichlorobenzene PCB-1248

toluene 3,3'-dichlorobenzidine PCB-1260

1,2-trans-dichloroethylene diethyl phthalate PCB-1016

1,1,1-trichloroethane dimethyl phthalate toxaphene

1,1,2-trichloroethane di-n-butyl phthalate

trichloroethylene 2,4-dinitrotoleune OTHER TOXIC

vinyl chloride 2,6-dinitrotoleune POLLUTANTS AND

di-n-octyl phthalate TOTAL PHENOL

ACID COMPOUNDS - 1,2-diphenylhydrazine

EPA METHOD 625 (as asobenzene) Antimony, Total

fluoranthene * Arsenic, Total

2-chlorophenol fluorene * Beryllium, Total

2,4-dichlorophenol hexachlorobenzene Cadmium, Total

2,4-dimethylphenol hexachlorobutadiene Chromium, Total

4,6-dinitro-o-cresol hexachlorocyclopentadiene Chromium, Hexavalent

2,4-dinitrophenol hexachloroethane Copper, Total

2-nitrophenol indeno (1,2,3-cd) pyrene * Lead, Total

4-nitrophenol isophorone Mercury, Total

p-chloro-m-cresol naphthalene * Nickel, Total

pentachlorophenol nitrobenzene Selenium, Total

phenol N-nitrodimethylamine Silver, Total

2,4,6-trichlorophenol N-nitrosodi-n-propylamine Thallium, Total

N-nitrosodiphenylamine Zinc, Total

phenanthrene * Asbestos

pyrene * Cyanide, Total

1,2,4-trichlorobenzene Phenols, Total

* = Polynuclear Aromatic

 Hydrocarbons

TCDD (Dioxin)
Attachment A

Best Management Practice Certification

For the Year 20____

Company Name:

RETURN TO:

Address: Narragansett Bay Commission

Pretreatment Program

2 Ernest Street

Providence, RI 02905-5502

I, _______________________________________, as authorized representative of 

________________________________________, do hereby decree that the Narragansett Bay 

Commission Best Management Practices for the Management of Waste Dental Amalgam have 

been fully complied with for the past twelve month period. 

I certify under penalty of law that this document and all attachments were properly prepared 

under my direction or supervision in accordance with a system designed to assure that qualified 

personnel properly gather and evaluate the information submitted. Based on my inquiry of the 

person or persons who manage the system, or those responsible for gathering the information, the 

information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I 

am aware that there are significant penalties for submitting false information including the 

possibility of fine and imprisonment for known violations.

Authorized Representative Signature Date
 

C E R T I F I C A T E T O D I S C H A R G E

the following types of process water:

Treated Dental Wastewater Containing Amalgam/Dental Process Wastewaters

into the facilities of the

Narragansett Bay Commission

is hereby granted to:

 Drs. Rubinstein & Ducoff, Inc.

 362 Ives Street

 Providence, RI 02906

PERMIT NUMBER: P9400-280-0914

PERMIT EXPIRATION DATE: 09/30/2014

The discharge permit must be kept at the above address for inspection. Failure to comply with the rules 

and regulations of the Narragansett Bay Commission or with the conditions of the discharge permit will 

subject the permittee to fines of up to $25,000 per violation per R.I.G.L. 46-25-25.3.

September 18, 2009 /s/ Kerry M. Britt

Initial Date of Issuance Kerry M. Britt, Pretreatment Manager