Louisiana Department of Environmental Quality February 2007 

Mercury Minimization Programs in LPDES Permits Page 2 

Background and Overview

The following guidance has been developed to address situations where a Mercury Minimization Program (MMP) has 

been required through a Louisiana Pollutant Discharge Elimination System (LPDES) permit. Traditional approaches to 

pollution control have emphasized treating for pollutants through end-of-pipe effluent limitations. Through a MMP, LDEQ 

anticipates that mercury pollution prevention and waste minimization rather than end-of-pipe controls will result in the 

most efficient reduction of mercury discharges to surface waters of Louisiana. Pollution prevention and waste 

minimization are more reasonably accomplished and cost productive than the implementation of controls and 

technologies to meet mercury effluent limitations. 

Until recently, EPA’s approved method for the analysis of mercury was not sensitive enough to measure mercury at trace 

levels. Consequently, there is little reliable data available on mercury loadings discharged from LPDES point sources. In 

1998 EPA adopted a new analytical procedure that detects mercury at trace levels, allowing more exact data to be 

collected and utilized in determining compliance with applicable water quality standards. The MMP employs EPA 

approved analytical methods (EPA Methods 1631, 245.7) through effluent sampling and system wide monitoring 

programs to locate and identify potential sources of mercury in the treatment system. Once identified the MMP integrates 

cost-effective reduction controls, either treatment or prevention based, to reduce or eliminate mercury from the source. 

While it is expected that specific permit language (see Appendix A, Sample LPDES Permit Language) may vary, there are 

two key elements for a MMP. 

- The Mercury Minimization Program Plan (MMPP) which shall lay out guidelines for: 

o identification of potential sources 

o monitoring of processes, influent, effluent and the entire treatment system 

o development and implementation of cost-effective control measures 

o resources and staffing 

o public outreach/stakeholder involvement; and 

- The Annual Report which shall serve both as a compliance monitoring tool for the LDEQ, and as a revising 

process for the discharger to make necessary revisions to the MMPP where problems were discovered and 

where new areas need investigation. 

Because existing mercury Total Maximum Daily Loads (TMDLs) in Louisiana have assumed all discharges from 

Treatment Works Treating Domestic Sewage (TWTDS) do discharge some mercury, this guidance document focuses on 

minimization from the TWTDS perspective. However, this document is also intended to provide guidance for other facility 

types required to implement a MMP through their LPDES permit. 
Louisiana Department of Environmental Quality February 2007 

Mercury Minimization Programs in LPDES Permits Page 3 

The Mercury Minimization Program Plan

The Mercury Minimization Program Plan may consist of the following sections. 

I. Identification of Potential Sources of Mercury 

II. Monitoring Plan 

III. Control Measures – Development and Implementation 

IV. Resources and Staffing 

V. Public Outreach/Stakeholder Involvement 

VI. Reporting Requirements 

The Mercury Minimization Program Plan shall be developed and provided to the LDEQ within one year of the effective 

date of the LPDES permit requiring the MMP. The following detailed sections are to serve as guidelines for development 

of each section, conditions at each facility should be utilized to develop a program best suited for that facility. 

For those entities where more than one facility is required to implement a mercury minimization program, one program 

and annual report will satisfy the requirements for each facility. 

I. Identification of Potential Sources of Mercury – the facility should develop specific plans to identify and 

eliminate potential sources of mercury to the discharge. 

The LPDES permitted facility required to develop a MMP needs to examine all potential sources of mercury to the 

discharge. Sources of mercury include, but are not limited to; processing, raw materials, treatment chemicals, 

industrial users, commercial users, domestic users, stormwater, inflow and infiltration, groundwater, atmospheric 

deposition, source water and other wastestreams that contribute to the discharge. Two basic methods can be 

utilized to identify potential sources: 

A. Data gathering and review of existing information. 

1. Review existing information on industrial users. An Industrial User is any user who introduces 

pollutants into a treatment system from a non-domestic source including commercial users. 

a. For any categorical industrial users contributing to the treatment system, review EPA 

standards in 40 CFR Parts 405-471 to determine if mercury is a pollutant of concern for 

that industrial category. EPA Development Documents and Industrial Sector Notebooks 

on specific industrial categories are useful. 

b. For those non-categorical users, determine if processes, materials or products stored or 

handled at the site have the potential to discharge mercury into the treatment system. 

2. Gather new or additional information from all industrial users. 

a. Appendix B contains mercury surveys for medical facilities, schools, dental offices and 

other general industrial users. 

b. Have industrial users provide the MSDS or Certificate of Analysis (COA) for all 

chemicals/materials stored or handled on site. 

3. Domestic/residential sources can be potential sources of pollutants; however traditional controls 

are not appropriate. Pollution prevention for residential users would be better achieved through 

educational campaigns. 

4. Chemicals, processes and materials stored or handled at the facility should be examined for the 

potential to contain mercury. Review the MSDS for processes or chemicals to provide grosslevel information on mercury. Requesting a COA from the manufacturer of any chemicals 

handled or stored at the facility should specify the mercury content in ppb or ppm. 
Louisiana Department of Environmental Quality February 2007 

Mercury Minimization Programs in LPDES Permits Page 4 

5. There are currently four ambient air monitoring stations in Louisiana that are part of the National 

Atmospheric Deposition Program – Mercury Deposition Network. Results of mercury 

concentrations in precipitation are available online at http://nadp.sws.uiuc.edu/. Review average 

mercury concentrations in precipitation to determine mercury levels entering the system through 

stormwater flows. 

a. Identify what steps the treatment system is taking to reduce I & I problems in the 

collection system. 

6. Review collection system cleaning practices. Large amounts of mercury reside in sediments that 

are introduced to the treatment system during collection system flushing. 

B. Monitoring for mercury at various points within the facility/treatment system. 

A system wide monitoring strategy is dependant upon the objective. Establishing levels associated 

with normal domestic and industrial sources are done to provide a baseline to measure progress and 

identify any hot spots that may be present in the system. 

1. Monitoring of the treatment plant influent should be conducted. Because concentrations of 

mercury entering the treatment plant are expected to be significantly higher than effluent 

concentrations, influent sampling should be conducted using EPA Method 245.1. If the results of 

the influent sampling yield results higher than the minimum quantification level, steps should be 

taken to conduct sampling of the collection system at various locations to isolate the potential 

source. 

2. Monitoring throughout the treatment system as a result of elevated influent concentrations should 

be conducted working backwards from the headworks. Sampling for mercury at lift stations can 

allow for easy and quick identification of the vicinity of a potential source of mercury throughout 

the system. Identifying a general vicinity can allow for quick review of contributing industries in 

that area for possible independent sampling. Where practicable sampling should be conducted 

within a given area simultaneously. Because concentrations of mercury in the treatment system 

are expected to be significantly high, system wide sampling should be conducted using EPA 

Method 245.1. 

3. In some cases, mass-balance calculations may be more useful in monitoring progress than 

chemical analysis. Alternative monitoring mechanisms other than chemical analysis may be 

acceptable. 

4. Direct monitoring of industrial users discharging into the treatment system can serve both as a 

tool to identify a source of mercury contribution and to eliminate any sources that may be 

considered targets. 

II. Monitoring – Monitoring should be conducted of the facilities effluent, influent, biosolids and throughout 

the treatment system to establish base levels and goals for mercury reduction. 

A. Effluent monitoring shall be not less than quarterly for major LPDES facilities using the most 

sensitive EPA approved test methods and clean sampling techniques. Minor LPDES facility 

sampling requirements will be determined on a case by case basis. Results of these tests shall be 

submitted with the annual report. 

B. If sampling of the sludge is conducted during the year, this information shall be submitted with the 

annual report. 

C. Sampling of the treatment system influent and throughout the treatment system should be performed 

to establish baselines and goals for reduction. See Part I.B above for influent and treatment system 

sampling protocol. 
Louisiana Department of Environmental Quality February 2007 

Mercury Minimization Programs in LPDES Permits Page 5 

III. Control Measures – Development and implementation of cost-effective control measures for those 

identified sources. 

The program plan should illustrate the treatment systems approach for development of cost-effective 

control strategies for those sources identified as contributors of mercury to the treatment system. 

Activities selected by the treatment system for control measures should be based on the potential of 

those activities to reduce mercury loadings into the system and ultimately its effluent. For each control 

measure goals should be established and communicated to the source. Performance measures should 

be established to determine attainment of set goals. 

A. The term source is loosely defined so that all inputs of mercury into the system, not just pinpointed 

users of the system, are considered for control measures. Sources can include raw materials, 

chemicals used, atmospheric deposition, stormwater inputs and sewer cleaning practices, along with 

domestic and industrial users. A control can be anything that reduces the amount of mercury 

contributed to the system. 

B. Source significance should be considered. An effort to quantify to load potential from each identified 

source should be made. This quantification should assist in prioritizing sources for mercury 

reduction and elimination efforts. 

C. Economic considerations should be given regarding the reduction of mercury from an identified 

source. 

D. Treatability considerations may apply to specific sources. A complete description of any such 

consideration should be documented. 

E. Control measures should be tracked to determine the measure of performance and goal 

achievement for each type of source. Tracking may indicate the need to change course as 

necessary for any given source. 

F. Examples of Mercury Control Measures 

Source Control Measure Activity Performance 

Measure Goal 

Medical Facilities 

(hospitals, clinics, nursing 

homes, veterinarians) 

Deliver AHA BMP literature 

Conduct workshops 

Onsite visits 

Require participation in H2E 

Date Contacted 

Content Given 

Participation 

Progress 

Mercury Free 

Spill Management 

Dental Clinics 

Deliver ADA BMP literature 

Meet with dentists 

Onsite visits 

Conduct workshops 

Require mercury recycling/capture 

Date Contacted 

Content Given 

Participation 

Progress 

Quantity Recycled 

Mercury 

Capture/Recycling 

Schools 

Deliver BMP literature 

Conduct teacher workshops 

Onsite visits 

Hg Inventory 

Date Contacted 

Content Given 

Participation 

Progress 

Quantity Recycled 

Mercury Free 

Spill Management 

General Industrial Users 

Deliver Chemical Literature 

Deliver Equipment Literature 

Application of BMPs 

Onsite visits 

Conduct workshops 

Date Contacted 

Content Given 

Progress 

Phase out mercury 

containing devices and 

chemicals 

Spill Management 
Louisiana Department of Environmental Quality February 2007 

Mercury Minimization Programs in LPDES Permits Page 6 

Source Control Measure Activity Performance 

Measure Goal 

Facility/Treatment 

System 

Evaluate chemical usage 

Evaluate equipment usage 

Evaluate septic haulers 

Evaluate sewer cleaning practices 

Evaluate industrial users 

Progress 

Phase out mercury 

containing devices and 

chemicals 

Plumbers 

Evaluate pressure Devices 

Evaluate equipment usage 

Deliver Chemical Literature 

Deliver Equipment Literature 

Application of BMPs 

Date Contacted 

Content Given 

Phase out mercury 

containing devices and 

chemicals 

General Public – 

Residential Areas 

Promote mercury clean sweeps 

Displays at local events 

Public Service Announcements 

Outreach to Schools 

Local website mercury content 

Local recycling day 

Local household hazardous recycling 

day 

Date Contacted 

Content Given 

PSA Dates 

Website Hits 

Participants 

Reduced use of mercury 

containing products 

Spill Management 

Recycling of mercury 

containing products 

IV. Resources and Staffing – the plan should summarize resources and staff that will commit time and 

funding to development and implementation of the plan. 

A. Indicate the source and amount of funding that will be available to carry out the plan. 

B. Indicate the number and position of employees that will devote time to planning and implementation. 

C. Where other entities will devote time and funding to planning or implementation, those resources 

should be included as well. 

V. Public Outreach/Stakeholder Involvement – to be effective, a mercury minimization plan should include 

partnerships with the public and stakeholders. Participation in a system wide program or a regional effort 

will greatly improve a treatment systems successful ability to reach its sources/users. 

A. The treatment system itself is a potential source of mercury and can serve as a role model for 

addressing mercury in the community. 

B. Collection programs for community residents can prove effective in removing stocks of mercury from 

the community that otherwise end up in wastewater or solid waste, and serve to raise awareness for 

mercury reduction efforts. 

C. Identify mercury recycling vendors that otherwise would not be known to the public. 

D. Determine if a local professional group represents a number of similar sources to the treatment 

system and work through this channel to gain understanding and support. 

E. Build community support by providing tours of the treatment facility, supporting science education in 

schools and the community, and supporting community environmental activities. 

F. Issue news releases to let the public know about the program. 

G. Speak to local service groups and community clubs. 

H. Place information on utility bills. 
Louisiana Department of Environmental Quality February 2007 

Mercury Minimization Programs in LPDES Permits Page 7 

I. Develop informational fact sheets for distribution where mercury containing products are purchased 

or used. 

A public outreach/stakeholder involvement campaign can be simple or elaborate. Many educational materials are 

available on the internet for modification to your program. 

VI. Reporting Requirements – Mercury Minimization Program Annual Report 

The annual report is an important element of a MMPP. It is to be submitted within one year of the submittal of the 

annual report (within two years of the effective date of the permit), and annually thereafter. The report should 

include a summary of all potential sources of mercury, control measures developed and implemented results of 

source reduction activities and monitoring, sampling results and any adjustments made to the Program Plan. See 

Appendix C for example formatting of the Annual Report. 

LDEQ Approval of the Mercury Minimization Program Plan

LDEQ will review the MMPP to ensure that implementation of the plan moves the treatment system toward the goal of 

minimizing mercury concentration in its effluent. Consideration will be given to those activities that address sources 

outside of the treatment facilities jurisdictional boundaries. Implementation is maintained as a condition of the LPDES 

permit. However, LDEQ encourages treatment facilities to begin implementation activities such as monitoring and 

outreach prior to approval and supports those treatment facilities that choose to implement a MMPP without the 

requirement regulated through their LPDES permit. 

The treatment system is responsible for implementation of the plan, its mercury reduction strategies and defined 

monitoring. The treatment system is encouraged to review available information and adopt approaches that others have 

already found to be effective. 

References:

Pollutant Minimization Program Guidance, Ohio Environmental Protection Agency, Division of Surface Water, Revision 0, 

August 13, 1998. 

Holly, Michigan Pollutant Minimization Program, March 12, 2003. 

Blueprint for Mercury Elimination, Western Lake Superior Sanitary District, Great Lakes Protection Fund and the Great 

Lakes Pollution Prevention Centre. Revised January 2000. 

Mercury Pollutant Minimization Program Guidance, USEPA Region 5, NPDES Programs Branch, November 2004. 

Best Management Practices for Amalgam Waste, American Dental Association. September 2005. 

Mercury in Your School and Community: A National Issue, Mercury in Schools Education Team, sponsored by the 

USEPA and the University of Wisconsin – Extension. March 2002. 
Mercury Minimization Programs in LPDES Permits – Appendix A Page 8 

Appendix A 

Sample Permit Language 

The following permit language is a template that contains the basic requirement of the MMPP and can be customized to fit 

specific circumstances. It is intended to be used for both sanitary and non-sanitary permits that have identified mercury in 

their effluent. This language shall be required in Part II of the permit. 

Part II – Standard Conditions 

A. Mercury Minimization Program 

The permittee shall develop and implement a Mercury Minimization Program Plan within one year of the effective 

date of this permit. The plan shall be submitted to the Office of Environmental Compliance at PO Box 4312, Baton 

Rouge, LA 70821-4312. The plan may be formatted in accordance with the attached LDEQ Mercury Minimization 

Program Guidance Document, February 2007. Yearly thereafter, the permittee shall submit an annual report to 

the LDEQ, Office of Environmental Compliance at the above address. The annual report may be formatted in 

accordance with the attached LDEQ Mercury Minimization Program Guidance Document, February 2007, 

Appendix C. [Insert the following for multiple facilities covered under one program] The Mercury Minimization 

Program was initially permitted under the ENTITY NAME, FACILITY NAME. The Mercury Minimization Program 

elements are developed and tracked under LA00XXXXX. 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 9 

Appendix B 

Mercury Surveys
Mercury Minimization Programs in LPDES Permits – Appendix B Page 10 

Medical Facility Mercury Survey 

What Type of Medical Facility are you (hospital, clinic): 

What is the size of your facility (# of beds, # of patients/day): 

Please provide the following mercury contact information for your medical facility: 

 Name: 

 Title: 

 Phone: 

Does your facility participate in the Hospitals for a Healthy Environment (H2E) Program 

 Yes  No  N/A – not a hospital 

Please indicate if the following mercury sources are located or used in your facility: 

 Fever Thermometers  Gastrointestinal diagnostic equipment 

 Sphygmomanometers  Feeding Tubes 

 Commercial manometer  Thermostats 

 Switches (relay, silent, tilt)  Barometers 

Chemicals 

 Zenker’s solution  Histological Fixatives 

Staining Solutions and Preservatives 

 Mercury Chloride  Mercury (II) Oxide 

 Mercury (II) Chloride  Mercury (II) Sulfate 

 Mercury Nitrate  Mercury Iodide 

 Other 

Lamps 

 Fluorescent  Metal Halide 

 Ultraviolet  High Pressure Sodium 

 Mercury Vapor  LCD Projectors 

Batteries 

 Mercuric Oxide  Button Batteries 

Please list any other possible sources of mercury or any other materials that could be a concern for mercury pollution. 

Have you considered or adopted mercury free alternatives for any of the products listed above? Please explain. 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 11 

Medical Facility Mercury Survey (continued) 

Please complete the following section on practices at your facility: 

Is staff training provided on the health and environmental concerns of mercury?  Yes  No 

Is staff training provided on mercury spill prevention or management?  Yes  No 

Is there a mercury spill clean-up kit on site?  Yes  No 

Have there been any mercury spills within the last ten years?  Yes  No 

Does your facility have a policy on purchasing mercury containing products?  Yes  No 

 If yes, please attach a copy of the policy. 

Do you currently require disclosure by vendors of mercury concentrations in solutions?  Yes  No 

What is the current procedure for disposal of medical waste?  Autoclave  Incineration  Other 

Have your sewer drain traps/catch basins been cleaned to remove mercury?  Yes  No 

If yes, was mercury discovered?  Yes  No 

Are any mercury products in your facility currently recycled?  Yes  No 

If there are other facility practices that you think should be a concern for mercury pollution, please list them here: 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 12 

Dental Office Mercury Survey 

Dental Office Name: 

Please provide the following mercury contact information for your dental office: 

 Name: 

 Title: 

 Phone: 

Do you use amalgam: 

 Yes 

 No 

Please indicate if the following equipment or materials are used in your office: 

 raw mercury 

 pre-capsulated amalgam capsules 

 water-injected vacuum pump 

 dry turbine vacuum pump 

 recycler on vacuum pump 

For materials collected on cuspidor, evacuation unit, vacuum pump and saliva ejector filters that are not recovered, please 

indicate the method of disposal. 

 wash down the sink 

 recycled 

 other 

For scrap (non-contact) amalgam that is not recovered, please indicate the method of disposal. 

 wash down the sink 

 recycled 

 other: 

How do you dispose of pulled teeth containing amalgam fillings? 

 recycled. Provide the name of your recycler: 

 washed down the sink 

 put in infectious waste (red) bag 

 hazardous waste hauler. Provide the name: 

 other: 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 13 

Dental Office Mercury Survey (continued) 

Are chair-side traps, or some type of pre-filter used?  Yes  No 

If yes: 

 How often are your traps/filters cleaned? 

 recycled. Provide the name of your recycler: 

 washed down the sink 

 put in infectious waste (red) bag 

 hazardous waste hauler. Provide the name: 

 other: 

Of the amount of new amalgam placed, estimate the following percentages based on the amount of amalgam mixed. 

Please include amalgam recovered from traps and filters. 

 % of amalgam mix that is actually placed in teeth 

 % of amalgam mix that is recycled 

 % of amalgam mix that is lost to the sewer 

 % of amalgam mix that is disposed of as infectious waste 

Of the total old amalgams removed including those in pulled teeth, estimate the following percentages based on total 

amount of amalgam removed. Please include the amalgam recovered from traps and filters. 

 % of amalgam removed that is recycled 

 % of amalgam removed that is lost to the sewer 

 % of amalgam removed that is disposed of as infectious waste 

What is your preferred method for learning about waste management? (check three) 

 printed information (brochures, pamphlets, manuals, professional newsletters) 

 on-site consultation with a waste specialist 

 informational hotline 

 speakers at dental society meetings 

 trade fairs 

 other 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 14 

Dental Office Mercury Survey (continued) 

If not currently recycling, what factors below would help you to change the way you presently dispose of waste? 

 consistency of information 

 concern about governmental enforcement 

 concern about liability 

 concern about public image 

 concern for the environment 

 concise disposal guidelines 

 professional association endorsement 

 no cost increase 

 concern for employee safety and health 

 concern for public safety and health 

 pick up services available for wastes 

 drop off services available for wastes 

 ease of disposal 

If not currently recycling, what factors keep your dental office from doing so? 

 lack of information 

 no regulatory requirement to do so 

 to difficult 

 to expensive 

 difficulty in finding recyclers 

 not aware that I should 

 no or very little use of amalgam 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 15 

General Industry Mercury Survey 

Facility/Company Name: 

Please provide the following mercury contact information for your facility: 

 Name: 

 Title: 

 Phone: 

Please indicate if the following mercury sources are located or used in your business. Place a check in the box and circle 

the specific source listed. If you have identified a source of mercury that is not listed, please add it to the list. 

 barometers 

 batteries, list the types: 

 DC watt hour meters, flow meters, vibration meters 

 displacement/plunger relay 

power supply switching, 1 to 4 poles, NO, NC, many voltage and current ratings, generally for high-current, 

high-voltage applications such as lighting, resistance heating, commercial welders 

 flame sensors/safety valves 

some infrared heaters, some furnaces, stainless steel bulb, capillary tube, bellows/control device, Used for 

unsupervised burners in certain gas-fired devices with standing pilot or electronic ignition pilot 

 lamps; fluorescent, high-pressure sodium, metal halide, ultraviolet 



switches; relay switches, pressure control (mounted on bourdon tube or diaphragm), tilt switches, silent light 

switches (single pole and three way) temperature control (mounted on bimetal coil or attached to bulb device), 

fire alarm box switch, sump pump floats 

 reed relays; used for low voltage, high precision analytical equipment 

 thermometers 

 thermostats; ovens, room temperature control, refrigerators 

 vacuum gauges; needle or bourdon gauges, manometers 

 other possible mercury sources, please list here any other materials that you think should be a concern for 

mercury pollution. 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 16 

Mercury Survey for Schools 

School Name: 

Please provide the following mercury contact information for your school: 

 Name: 

 Title: 

 Phone: 

Please indicate if the following mercury sources are located or used at your school. 

Science, Chemistry, Physics, Biology Rooms/Labs: 

; Item How much or many? Items use? 

 elemental mercury 

 mercury thermometers 

 mercury barometers 

 mercury vacuum gauges 

 mercury spectral tubes 

 mercury molecular motion device 

 mercury sling psychrometer 

 mercury oxide 

 mercury (II) chloride 

 mercury (II) sulfate 

 mercury nitrate 

 mercury iodine 

 Zenkers solution 

 other mercury containing materials 

Facilities: 

; Item How much or many? Items use? 

 fluorescent lamps 

 mercury thermostats 

 mercury vapor lamps, metal halide 

lamps 

 mercury gauges 

 silent light switches 

 mercury float control switches 

 flow meters with mercury switches 

 other equipment with mercury 

switches 

 older fungicides and pesticides 

(prior to 1991) 
Mercury Minimization Programs in LPDES Permits – Appendix B Page 17 

Mercury Survey for Schools (continued) 

Medical: 

; Item How much or many? Items use? 

 mercury fever thermometers 

 sphygmomanometers with silver 

liquid (blood pressure) 

Home Economics and Art: 

; Item How much or many? Items use? 

 mercury cooking thermometer 

 true vermillion paint 

 cadmium vermillion red 

Other: 

; Item How much or many? Items use? 



mercury oxide/mercury zinc 

batteries (old alkaline prior to 

1996) 
Mercury Minimization Programs in LPDES Permits – Appendix C Page 18 

Appendix C 

Mercury Minimization Program Annual Report 
Mercury Minimization Programs in LPDES Permits – Appendix C Page 19 

Louisiana Department of Environmental Quality 

Mercury Minimization Program Annual Report 

This document is submitted to fulfill the requirements as set forth in the LPDES permit requiring the development of a 

mercury minimization program. The Annual Report serves both as a compliance monitoring tool for the LDEQ, and as a 

revising process for the discharger to make necessary revisions to the MMPP where problems were discovered and 

where new areas need investigation. 

Date: 

Permit Number: LA 

Additional Permits covered by this Annual Report: 

Agency Interest Number: 

Company Name: 

Facility Name: 

Contact Name: 

Contact Phone: ( ) 

1. Was the Mercury Minimization Program Plan as submitted to LDEQ followed completely during the past year? 

 Yes  No 

If no, attach supporting documentation that clearly describes any and all deviations from the program. Include a 

list of all actions or conditions that lead to the variation as well as any interaction with LDEQ relation to the 

variation. 

2. List any confirmed sources of mercury to the treatment system including an average annual loading to the 

treatment system (may be estimated) and method by which the source was identified. 

3. List any potential sources of mercury to the treatment system including an average annual loading to the 

treatment system (may be estimated). 

4. Attach all analytical results from all monitoring performed during the last year for mercury, including 

detection/quantification level, method used and location of sample (ex: influent, effluent, sludge, Main Street Lift 

Station, XYZ Cleaners, etc..) 

5. Attach a list of all actions taken to reduce or eliminate sources of mercury from the treatment system. Actions 

may include treatment, remediation, investigation, operation, management activities, public outreach, 

distribution of materials, implementation of BMP’s, contact with industrial users, inspection of industrial users, 

etc. If no actions were taken to reduce or eliminate sources of mercury to the treatment system, please explain 

why. 

6. Attach a list of all actions planned to further reduce or eliminate sources of mercury. 

7. Provide additional comments or information on the treatment systems progress using the Mercury Minimization 

Program Plan to proceed toward achievement of the goal to reduce effluent concentrations of mercury. 
Mercury Minimization Programs in LPDES Permits – Appendix D Page 20 

Appendix D 

Best Management Practices for Amalgam Waste 

American Dental Association 
Mercury Minimization Programs in LPDES Permits – Appendix D Page 21 

The ADA BMPs for amalgam waste can be found at: 

http://www.ada.org/prof/resources/topics/amalgam_bmp.asp
Mercury Minimization Programs in LPDES Permits – Appendix E Page 22 

Appendix E 

Mercury in Your School and Community: A National Issue 

Mercury in Schools Education Team 
Mercury Minimization Programs in LPDES Permits – Appendix E Page 23 

The Mercury in Schools participatory curriculum can be found at: 

http://www.mercuryinschools.uwex.edu/curriculum/index.htm