East Bay Municipal Utility District’s Dental Mercury 

Permit Program 

Mercury is one of the 12 toxic pollutants identified 

by the Federal Environmental Protection Agency that 

is impairing Central San Francisco Bay, and is listed 

in Section 303 (d) of the Clean Water Act. Mercury 

persists in the environment and bioaccumulates in the 

food chain in the form of methyl mercury. Currently, 

fish consumption advisories are issued in 41 States. 

The San Francisco Bay is included on the fish 

consumption advisory list. 

Wastewater treatment plants, including East Bay Municipal Utility District’s (EBMUD), are 

designed to treat wastewater containing conventional pollutants such as human waste and 

food waste. Heavy metals, including mercury, are not readily removed by the treatment for 

conventional pollutants. As a result, the fate of mercury is to end up in the wastewater 

discharged to the San Francisco Bay or more typically in the biosolids, which are used for 

land application and landfill cover. In addition to its National Pollutant Discharge 

Elimination System Permit (NPDES) requirements, EBMUD has to comply with federal, 

state and local biosolids regulations for heavy metals, including mercury. These regulations 

ensure that biosolids can be safely reused for land application and landfill cover. 

Through its NPDES Permit, EBMUD is required to develop a source control and pollution 

prevention program to maximize control over the District’s mercury sources. In addition to 

dental practices, EBMUD is developing mercury pollution prevention programs for hospitals, 

medical facilities, educational institutions, industrial sources, and residential outreach. 

Since the inception of its Dental Mercury Program 

(November 2001) EBMUD has worked with 

representatives from the California Dental Association 

and local dental societies in determining how to manage 

this source. 

Although the amount of mercury used by dentists has 

decreased significantly during the past ten years, there is 

still a substantial legacy of amalgam fillings that will 

remain in the environment for the next several decades. 

Studies have demonstrated that amalgam separator 

technology can remove ≥95% of the mercury amalgam

particulates in the dental process wastewater. 

In addition to including dental amalgam best management practices, EBMUD is revising its 

Dental Mercury Pollution Prevention Permit Program to require dental practices that handle 

amalgam as part of their core business to install amalgam separators. (Note: There is no fee 

associated with the permit or this revision). 
EBMUD’s criteria are that the installed amalgam separator meets 

the International Organization of Standardization (ISO) 11143 

Standard and be properly maintained. 

EBMUD is working with representatives from the California 

Dental Association and local dental societies to develop the 

permit terms and conditions. 

In February 2004 a local amalgam separator vendor fair will be 

held, so that general dentists may make an informed decision on 

what type of technology is best suited for their practice. Based on 

the District’s recent review, the cost of certified amalgam separators can range from $500 to 

$1,900 for the first year (unit purchase and installation). Subsequent years would be at a 

much lesser cost for maintenance and amalgam disposal. 

If you have any questions regarding EBMUD’s Dental Mercury Pollution Prevention Permit 

Program, please contact Deirdre Mena at (510) 287-1559.