### 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 situat ions where a Mercury Minimization Program (MMP) has been required through a Louisiana Pollutant Discharge Eliminati on System (LPDES) permit. Traditional approaches to pollution control have emphasized treating for pollutants thro ugh end-of-pipe effluent limitations. Through a MMP, LDEQ anticipates that mercury pollution prevention and waste minimiza tion rather than end-of-pipe controls will result in the most efficient reduction of mercury discharges to surf ace 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 me rcury 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 merc ury at trace levels, allowing more exact data to be collected and utilized in determining co mpliance with applicable water q uality 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 A ppendix 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 revi sions 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 discha rge some mercury, this guidance document focuses on minimization from the TWTDS perspective. However, this doc ument 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 Pot ential Sources of Mercury II. Monitoring Plan

III. Control Measures – Deve lopment and Implementation IV. Resources and Staffing

V. Public Outreach/Stakeholder Involvement VI. Reporting Requirements

The Mercury Minimization Program Plan shall be developed and pr ovided to the LDEQ within one year of the effective date of the LPDES permit requiring the MMP. The follo wing detailed sections are to serve as guidelines for development of each section, conditions at each fa cility should be utilized to develop a progra m best suited for that facility.

For those entities where more than one facility is requir ed 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 limi ted to; processing, raw materials, treatment chemicals, industrial users, commercial users, domestic users, st ormwater, inflow and infiltration, groundwater, atmospheric deposition, source water and other wast estreams 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 cont ributing 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 discha rge mercury into the treatment system.

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

a. Appendix B contains mercury surveys for m edical 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 so urces of pollutants; howe ver traditional controls are not appropriate. Pollution prevention for residential users would be better achieved through educational campaigns.

4. Chemicals, processes and mate rials 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 spec ify 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 Loui siana 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 determi ne mercury levels entering the system through

stormwater flows.

a. Identify what steps the treat ment 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 point s 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 ma y be present in the system.

1. Monitoring of the treatment plant influent should be conducted. Because concentrations of mercury entering the treatment plant are expe cted to be significantly higher than effluent concentrations, influent sampling should be conducted using EPA Met hod 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 vicini ty 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 c oncentrations 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 ma y be more useful in monitoring progress than chemical analysis. Alternative monitoring mech anisms other than chemical analysis may be acceptable.

4. Direct monitoring of industrial users discharging into the treatme nt system can serve both as a tool to identify a source of mercury contribut ion and to eliminate any sources that may be considered targets.



### II. Monitoring – Monitoring should be conducted of the f acilities 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 quarter ly for major LPDES facilities using the most sensitive EPA approved test methods and clean sa mpling 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 ye ar, this information shall be submitted with the annual report.

C. Sampling of the treatment system influent and th roughout the treatment syst em should be performed to establish baselines and goals for reduction. See Part I.B above for infl uent 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 implementati on of cost-effective control measures for those

identified sources.

The program plan should illustrate the treatment sys tems 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 c ontrol measures should be based on the potential of those activities to reduce mercury loadings into the system and ultima tely 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 e ffort 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 regard ing the reduction of mercury from an identified

source.

D. Treatability considerations may a pply to specific sources. A co mplete descriptio n of any such

consideration should be documented.

E. Control measures should be tracked to det ermine 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 t hat 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 e ffective, 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 su ccessful 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 prov e effective in removing st ocks 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 repres ents 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 th e 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 gr oups 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 distributio n 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 t he effective date of the permit), and annu ally thereafter. The report should include a summary of all potential sour ces 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 Merc ury 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. Considerati on 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 Pr otection 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 Sani tary District, Great Lakes Pr otection Fund and the Great Lakes Pollution Prevention Centre. Revised January 2000.

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

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

Mercury in Your School and Community: A National Issue, Mercury in Schools Education Team, sponsored by the USEPA and the University of Wiscon sin – 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 th e basic requirement of the MMPP and can be customized to fit specific circumstances. It is intended to be used for both sani tary and non-sanitary permits th at 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 O ffice 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 ther eafter, 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 facilit y (# of beds, # of patients/day):

Please provide the following mercury contac t information for your medical facility:

Name:

Title:

Phone:

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



###  Yes 

###  No 

###  N/A – not a hospital

Please indicate if the following mercury source s 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 ot her 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 secti on 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 pu rchasing mercury containing products? 

###  Yes 

###  No

If yes, please attach a copy of the policy.

Do you currently require disclosure by vendo rs 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 produc ts in your facility currently recycled? 

###  Yes 

###  No

If there are other facility practices that you think should be a concern for mercury pollu tion, 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 contac t 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 pum p 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 recove red, please indicate the method of disposal.



###  wash down the sink



###  recycled



###  other:

How do you dispose of pulled t eeth 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 followi ng percentages based on the am ount 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 pull ed teeth, estimate the following percentages based on total amount of amalgam removed. Please include t he 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, pamphlet s, 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 fact ors 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 associ ation 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 co ntact 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 me ters, 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 bour don 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 temper ature control, refrigerators



###  vacuum gauges; needle or bourdon gauges, manometers



###  other possible mercury sources, pl ease 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 co ntact information for your school:

Name:

Title:

Phone:

Please indicate if the following mercury source s 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 ther mometers



###  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 Pr ogram Annual Report

### Mercury Minimization Programs in LPDES Permits – Appendix C Page 19 

### Louisiana Department of En vironmental Quality

Mercury Minimization Pr ogram Annual Report

This document is submitted to fulfill the requirements as se t forth in the LPDES permit requiring the development of a mercury minimization program. The Annual Report serves bo th as a compliance monitoring tool for the LDEQ, and as a revising process for the discharger to make necessary re visions 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 submi tted to LDEQ followed completely during the past year?



###  Yes 

###  No

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

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

variation.

2. List any confirmed sources of mercury to the treatment syst em including an average annual loading to the treatment system (may be estimated) and me thod by which the source was identified.

3. List any potential sources of mercury to the treatment syst em 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 elimin ate 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 s ources of mercury to the treatment system, please explain why.

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

7. Provide additional comments or information on the tr eatment 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 Practice s 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/resour ces/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 participator y curriculum can be found at: http://www.mercuryinschools.uw ex.edu/curriculum/index.htm