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 Wastewate r 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 a nd 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 requeste d 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 perm it. 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 authori ze 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.

Ple ase 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 t he 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 Manag er

KMB:sm

Enclosures

cc: Kyle Gannon

# WASTEWATER DISCHARGE PERMIT

Permit Number: P9400

- 280

- 09 14 Company Name: DRS. RUBINSTEIN & DUCOFF, INC. Facility Address: 362 Ives Street, Providence, RI 02906 Mailing Address: 362 Ives Street, Provid ence, RI 02906 Facility President: Dr. Michael L. Rubi n stein 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 (A ct) 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 referr ed 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 limitat ions, 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 th e permit. This permit consists of 1 4 pages with

conditions A

- T and Attachment A.

This permit is effective o n October 1, 200 9 and expires on September 30, 20 14

.

Noncompliance with any term or condition of this permit shall constitute a violation of th e 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 fi ne 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 pers on(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 p er 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 desi gnated 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 Permi ttee . 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 Fe deral 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 subst itute 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. Permit ted 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 wastewa ter 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 Solution s ; b. Dental Amalgam;

c. Elemental Mercury;4

d. Untreated Dental Wastewater Containing Amalgam;

e

. Acidic Solut ions with a pH less than 5.0 Standard Units;

f

. Caustic Solut ions with a pH greater than 1 1 .0 Standard Units;

g

. Solvents;

h

. Sludges.

2. The permittee is strictly prohibited from discharging any process wastewater streams other than those specified in Se ction 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 Se ction 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 sai d 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 specifi ed 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 th e process wastewater sampling location.

The disc harge 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 maintaini ng 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, adequa te 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 Amalga m.

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 accorda nce 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 a re 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 repla ced 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

a pproved 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

evo lved.

9

. The permittee has designated one (1) sink for sanitary use only. The permittee shall post signs at th is sink stating “Sanitary Use Only”. Washing of equipment instrument s filters and capsules in this sink is strictly prohibited.6



### E. Certif

ication of Compliance with Best Management Practice:

The permittee shall submit written annual certification of compliance with B est Management Practices for the M anagement of Waste Dental Amalgam for the period from

November to October . The Certificatio n 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 wa stewater 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 Requir ements:

1. The permittee shall be responsible for maintaining a logbook documenting all records pertaining to the operation of the x

- ray process or 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 eac h 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 activit y.7

3. Records which substantiate any information supplied in permit applications, Self

Monitoring 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 pe rmittee 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 inci dent immediately by calling the Pretreatment Section at 461

- 8848 or during non

- business hours at its twenty

- four (24) hour Emergency Hotli ne 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 t hat 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 wastewate r 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. T his 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 spill8

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 o peration 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 fail ure 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 malfun ction 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 presen ting 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 o therwise 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 per mittee 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 wast e 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 u ser, 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 fourte en (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 again st 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, R IPDES, 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 wh o 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 impr isonment 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 perm it 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 comp liance 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 intend ed 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 r evoked. 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 d ischarge 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 NB C'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 incl uding 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 co urse 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 br ochure 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, Stat e, 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

collect ion 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/ope rator;

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

reis suance, 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 pe rmit 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 he reto 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 la w, 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 Form13 

### Table 1

NBC Effluent Discharge Limitations

Field’s P oint District

Parameter Limitation (Max)

Total Toxic Organics (TTO) 2.13

Biochemical Oxygen Demand (BOD 5 ) 300.00*

Total Suspended Solids (TSS) 300.00*

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

Oil and Grease (mineral origin) 2 5.0

Oil and Grease (animal/vegetable origin) 100.0

pH range (at all times) 5.0

- 1 1 .0 s.u.

Parameter Daily Maximum (Composite for 1 day) ( mg/l ) Average (10 day) ( mg/l )

Cadmium (Total) 0.11 0.07

Chromiu m (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

- chlorona phthalene 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

- dichl orobenzene 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 phth alate 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 hexachl oroethane 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 her e by 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. Rubi n stein & Ducoff, Inc.

362 Ives Street

Providence, RI 02906

PER MIT 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 d ischarge 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