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<toote@neorsd.org > 09/03/04 09:18 AM 

### To Mr. Gluckman, Attached are comments from the Subject Northeast Ohio Regional Sewer District concerning the


### Mc Gluckman, 

### Attached are comments from the Northeast Ohio Regional Sewer District concerning the Region V Draft Mercury Poilutant Minimization Program Guidance. Please respond in acknowledgment of receipt of this email. Is in necessary that a hard copy is sent as well? 

## Thank you, Elizabeth R. Toot-Levy Investigator Northeast Ohio Regional Sewer District Water Quality and Industrial Surveillance Environmental and Maintenance Services Center 4747 East 49th Street 

### Cuyahoga Heights, Ohio 44125

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### tel: 216.641.6000 Re
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## September 3, 2004

Mr. Matthew Gluckman Pretreatment Program Manager U.S. EPA Region 5, WN-16J 77 W. Jackson Blvd. Chicago, IL 60604 VIA Electronic Mail: Gluckman.Matthew(

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## Re: Draft Mercury Pollutant Minimization Program Guidance 

## Dear Mr. Gluckman: We at the Northeast Ohio Regional Sewer District appreciate the opportunity to review and provide comments on the July 2004 Draft Mercury Pollutant Minimization Program (PMP) Guidance. We are pleased by the flexibility the draft Guidance provides, in that it enables states and POTWs to develop mercury minimization plans that adequately address site-specific concerns. We are also pleased to see that our previous comments of March 11, 2004 have been taken into account. Following are some additional comments on the draft Guidance: In Table 1, "Mercury Free" may be an inappropriate goai for the sector containing hospitals, clinics, nursing homes, and veterinary clinics. The sewer control authority should not be responsible or liable for encouraging the removal of medical treatment options from such facilities. The goal should be revised to "Proper storage, proper use, and proper disposal of necessary mercury-containing devices and chemicals, and phase-out of unnecessary mercury-containing devices and chemicals." • Table 1 also includes "hauled waste" as a part of a sector selected for mercury reduction. If "hauled waste" is meant to include "domestic septage" a distinction must be made between "hauled waste" and "domestic septage". The Code of Federal Regulations excludes domestic wastes from pretreatment requirements (40 CFR 403(b)(1)). Therefore " domestic septage" should be located in the General Public sector.

4747 E. 49e 8G I Cuyahoga Heights, OH 44125 I P: (216) 641-6000 I P: (2

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~ . ~ o Fax (608) 222-2703 ~ ~ ~ ~ ~ ~ Jon W. Schellpieffer Chiet Engineer 8 Director COMMISSIONERS
Edward V. Schfen Presidem Thomas D. Hovel Vice President P. Mac Berthoue>< Secretary Caryl E. Terrell Commissioner John E. Hendrick Commissianer
Protecting Public Health and the Environment



### August 20, 2004

N 

### Mr. Matthew Gluckman Pretreatment Program Mgr U.S. EPA Region 5, WN-16J 77 W.Jackson Blvd Chicago,IL 60604 

### Mr. Gluckman: The Madison Metropolitan Sewerage District is providing these comments following our review of the draft Region 5 mercury pollutant minimization program guidance document. 

### Dental Amalgam Obviously, pretreatment of dental clinic wastewaters via amalgam sepazators in Region 5 is the way of the future. We feel that water quality mercury standazds that aze "right" for our Great Lakes region in regazds to mercury contributions should be and will be "right" for the entire country. I'hereYOre, we urge you to push for national pretreatment regulafion regarding dental amalgam sepazators. You have seen that cities and states outside of the Great Lakes region aze taking on separator rules. Please push the issue on the national level at EPA. Do not expect each and every community (over some flow criteria) to create, opetate, and enforce a local separator program. Certainly, the dental community would prefer uniform state, or even national, separator standards. Problems with Local Amalgam Sepazator Programs: 1. Small and medium sized communities with inexperienced, less than enthusiastic, POTW operators as regulators will be expected to create their own programs. 2. Larger existing programs are currently experiencing problems with oversight of programs and review of ISO certifications and the problems encountered with vendors achieving certification and modifying approved models. New vendors breaking into a 

### growing market brings problems too.



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### 3. Engineering and plumbing considerations regarding proper sepazator sizing and

installation have lead to difficulties and concems in the current large-community sepazator programs. Don't expect small, lesser-staffed, communities to be as successful as the lazger existing separator programs with mandated local separator programs. Small city staffing and experience may not be up to the task in effectively running self-created local programs. Certainly, state or national separator standards will lead to unifonnity in regulation and the mazket. Section 2.4: Monitoring of Potential Sources of Mercury We suggest that EPA provide ciarification of what is intended for collection system 

# C sampling. Is the intent to chazacterize regional levels of hg? Is the intent to characterize domestic-only azeas or industrial pazks or institutional complexes? Is the intent to perform mass-balance calculations in the entire sewer system or local sewersheds? Based on limited sampling experience, we have encountered considerable difficulties in performing mass balance sampling via tazgeting key sewer intersections and pumping stations. These are some of the issues we have with mandated mass-balance sewer sampling: 1. Key points aze often located in manholes that have never previously been used for sampling. Difficulties include: traffic, lack of ladder rungs, tributary connections, and poorly mixed conditions
2. Sampling lazge interceptor sewers is imperfect. Mercury, as you know, is present in several forms in the sewer system. Amalgam residue is dense and we expect it to roll along the bottom of sewers. Inorganic (ionic) mercury is expected to be dispersed throughout the water column. The problem in lazge sewers is that a sampler strainer will be suspended into the flow and allowed to be swept downstream. The probe will likely catch rags and tend to ride the surface of the flow, thereby missing heavy mercury containing debris on the bottom. Weighting the strainer to sit on the bottom probably skews results to the high side as the bulk of the flow in the mid and upper depths is missed.
3. We have no experience in locating and sampling sediment azeas in collection systems. We have the feeling that there are "old" historical sources ofinercury in the collection system. These probably reside in the sediments_ The best sampling to characterize historical loadings might be accomplished at the POTW from grit collection following high flow (flushing) events. What can we do about these old deposits but wait for them to flush out over (many) years?
4. Sampling small sewers is even more imperfect. Sampling 

### an inch of flow leaving 

### an office building in a six-inch sewer is 

### an inexaat science. The flow is poorly mixed, operation of 

### an automatic sampler is difficult in shallow water, and grabbing samples very likely leads to excess mercury-containing slime and debris being collected within the sampling container.

### 5. Volume data is often not available. Picking some key points and running samplers on

time-proportional compositing is pre'Cty straightforwazd. However, if one wants to perform mass balance work, one must ensure that the entire water column is sampled (#2 above) and one must have accurate flow data. Obtaining flow data in sewer sampling is tdcky work, adds costs where it can be done, and is probably not currently an option for many small communities that will need to perform mercury PMP activities.
6. Use of BMPs, outreach towazds households, and installation of approved/certified sepazators aze intended to allow the POTW to avoid sewer system sampling. That's our take on the subject of sewer system sampling in Wisconsin. In summary, do not require sewer system sampling in PMP guidance. Certainly do not expect mass-balance level work with the intent to locate sources. Sewer system "chazacterization" is more easily performed at lower cost and with less likelihood of sample contamination. Recall that mercury is very ubiquitous, coming from all sources of wastewater in detectable levels; do not ezpect communities to waste time and resources tracking down sources via collection system sampling; mercury is found everywhere. Major source-sectors of inercury aze well known; allow the communities to focus reduction measures on those source-sectors without putting resources into sewer system sampling. Thank you for allowing Madison Metropolitan Sewerage District to provide these comments. You can reach me at 608-222-1201 ext 362 to discuss these matters.

~f C~ri~'~ Ralph Erickson Pretreatment and Waste Acceptance Coordinator

## State of Wiscon

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## in 1 DEPARTMENT OF NATURAL RESOURCES

WISCONSIN __ DEPT.OFNATURALRESOURCES Jim Doyle, Governor Scott Hassett, Secretary 101 S. Webster St. Box 7921 Madison, Wisconsin 53 70 7-7921 Telephone 808-266-2621 FAX 608-287-3579 TTY Access via relay - 711


### September 3, 2004
U.S. Environmental Protection Agency ATTN: Mc Matt Gluckman WN-16J 77 West Jackson Boulevard Chicago, II, 60604 ^ r ~ q s~ 9 ii-_' ir'-

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### Subject: EPAV Draft Mercury Pollutant Minimization Program Guidance
Deaz Mr. Gluckman: My comments on EPAV's "Draft Mercury Pollutant Minimization Program Guidance — July 2004" as posted on the Region V website aze as follows: General Comment. The general layout and direction of the guidance is consistent with our anticipated Wisconsin guidance on Mercury Pollutant Minimization Programs and wi[h our Community Mercury Reduction experience to date. Adminishative Comment. The EPAV guidance would be improved by including checklists for the Mercury Pollutant Minimization Program Plan and for the Annual Report. In addition, I do not find guidance for evaluating the adequacy of a municipal Mercury Pollutant Minimization Program,.i.e., what EPAV would consider a"compliant" or "noncompliant" program, nor direction on how States are to report their municipal mercury program evaluations to EPAV. Technical Comment — Wastewater Samplin¢ and Analysis. There is a tendency in the guidance to call for collection system and individual user wastewater sampling and analysis for mercury. That is an experisive proposition. Our intention in Wisconsin will be to emphasize oversight of inercury source reduction activities rather than monitoring of wastewater streams. But I think the EPAV guidance has enough flexibility to accommodate our source reduction accomplishment approach. Technical Comment — Dental Amalgam Mana e p ment. While EPAV's guidance uses an example of a dental office using good amalgam housekeeping practices plus installation of an amalgam separator as a satisfac[ory "Best Management Practice" that would function as a mercury local limit, with which I agree, Table 1 does not go far enough in expressing the need for the installation of amalgam separators in the Great Lakes Basin. A stronger statement presuming the need for the installation of separators in this part of the country, unless a municipality can demonstrate 1.3 ng/1 compliance without them, would result in more consistent management of waste amalgam discharges in the Basin than the less explicit language in Table 1. Let me go on. "Best Management Practices" for waste dental amalgam at this time is really the "good housekeeping" called for by the American Dental Association plus the installation and maintenance of an amalgam sepazator in the dental office wastewater line. This simple and relatively low cost technology is now universally required in all of Canada, in much of Europe, and is increasingly common in the United
dnr.wi.gov 

### Quality Natural Resources 

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## ~ ' August 26, 2004 NPDES SUPPORT & 

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### AssisT eR. g Y EPA,ftEVIO N5 

### Attention: Mr. Matthew Gluckman NPDES Programs Branch 77 West Jackson Boulevard Chicago, Illinois 60604 Subject: Mercury Minimization Program Guidance Dear Mr. Gluckman: Please amend the proposed Mercury Minimization Program Guidance to promote the implementation of best management practices (BMPs) and the installation of separators for dental amalgam. A community should be able to avoid this requirement only if the community identifies unique circumstances, such as the absence of dental offices that use amalgam or that specific work with other specific sources will achieve the applicable limit. The following reasons support the universal implementation of BMPs and separators: 1. Amalgam from dental offices is likely to be the dominant source of inercury. 2. Where dental offices have implemented separators, significant reductions in loadings, effluent concentrations, and biosolids concentrations have occurred. 3. A regulatory program requiring separators is simple to administer because: A. The requirements aze general, allowing them to be implemented by rule rather than individual permits. B. ISO 11143 provides a standard for the device. C. The regulated community is well-educated, interested in public health, already highly regulated, and already using sophisticated equipment. D. Enforcement can be done using quick inspections to view the sepazator and review recycling records. 4. Separators aze available from numerous suppliers. 5. Sepazators are available for only $600 to $1,500 for devices that serve the most common sizes of offices. b. Separators can be installed in less than two hours in most cases.

Milwaukee Metropolitan Sewerage District 260 W. Seeboth Street, Milwaukee, WI 53204-1446 414-2725100 ~ www.mmsd.com

# Milwaukee Metropolitan

Sewerage District Rules
11.214 Amalgam Management at Dental Offices ( I) This section applies to any dental office that places or removes amalgam. If work in a dental office is limited to work that does not involve placing or removing amalgam, such as orthodontics, periodontics, oral and maxillo-facial surgery, endodontics, or prosthodontics, then this section does not apply. (2) All dental offices shall implement best management practices for amalgam as established by the Wisconsin Dental Association. (3) Within the shortest reasonable time, but not later than February 1, 2008, every vacuum system where amalgam is placed or removed shall include an amalgam separator that meets the criteria of the International Standards Organization (ISO 11143). Dental offices shall install, operate, and maintain the amalgam separator according to instructions provided by the manufacturer. The amalgam separator shall have a design and capacity appropriate for the size and type of vacuum system. , (4) On or before February 1, 2005, each dental office shall submit a report that certifies the implementation of the management practices required by sub. (2) and identifies the contractors used to remove amalgam waste within the last twelve months. (5) On or before February 1, 2006, each dental office shall provide a schedule for the installation of the amalgam separator required by sub. (3). (6) On or before February 1, 2007, each dental office shall provide a report providing the following information. (a) If installation of the amalgam separator is complete, then the report shall identify the installation date, the manufacturer, and the model name. (b) If installation of the amalgam separator is incomplete, then the report shall briefly explain the delay, provide an installation schedule, and identify the manufacturer and the model name of the amalgam separator that will be installed. (7) If a dental office has provided a report according to sub. (6)(b), then the dental office shall notify the District of the completion of installation within five days after completion. (8) The District shall provide forms for reporting the information required by subs. (4), (5), (6), and (7).

# Amaigam Separator Case Study 1

Of[ice of Doctors William aod Nicholas Stathas 2300 North Mayfair Road Suite 345 Wauwatosa, Wisconsin53226 414-456-9020 (voice) 414-456-9021 (fax) Practice type: General Office size: 3 Operatories, 1 hygiene only Building type: High rise Vacuum system type: Wet Vacuum system loca[ion: Ufility closet Source of supplies: Patterson Amalgam Separator Manufacturer: Sohnetex Model: Hg5 Purchase price: $695 Power required: No Treatment chemicals required: No Size: 30 inches tali, 14 inches wide, 10 inches deep Primary reason for selecting model: Ease of installation , - 

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zr_; Recycling cost, including freight, is included in the cost of new filters. With the purchase of a new filter, Sohnetex

~ provides pre-addressed, freigh[-paid contaiaers for the old filter. Replacement filtets are $250. " ~ Separator Installation Time between ordering and delivery: 2 weeks Plumbing contractor: Protel Installation date: June 3, 2003 Time needed: I hour 7nstallation cost: $250 Problems encountered during installation: None Amalgam Recycler Mercury Waste Solutions
-_ 21211 Durand Avenue Union Grove, Wisconsin 531g2 Shipper Fed Ex

_ Expected frequency of shipments: Every 4 months

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# Amalgam Separator Case Study 3

East Towne Dental Associates Doctors Vali Kiaie, Jerome Gildner, and Jemy Barry I 1501 North Port Washington Road Mequon, Wisconsin 53092

~ 262-241-8880(voice) 262-241-5250 (fax) Practice type: General Oftice size: 8 Operatories, 3 hygiene only Building type: Multi-tenant professional Vacuum system type: Dry Vacuum system location: Basement 

### Source ofsupplies: Sullivan-Shein Amalgam Separator -',: 

## ~ Manufacturer: Air Techniques , Model: A/T A1047 ` Purchase price: S 1,500 Power required: No

~ Treatment chemicals required: No Size: 6 inches x 12 inches x 8 inches

~ Primary reason for selecting model: Small size fi[s available space and compatibility with existing equipmen[

. Warran[y: 1 year _. Separator Installation Time between ordering and delivery: 3 weeks Installation date: January 14, 2004

~ . Time needed: 1 hour installation cost: $200 Problems encountered during installation: None Amalgam Recycler Betlilehem Apparetus Company 890 Froa[ Street Hellertown, Pennsylvania 18055 

### Shipper Fed Ex Expected frequency of shipments: Every 9 to 12 months The cost of shipping and recycling the fust collection container is iacluded in the purchase price. Air Techaiques x ~ provides shipping containers with replace

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# Amalgam Separator Case Study 4

Office of DoMors Thontas E. Raimann and Richard A. Mueller 

### 1180t WestJanesville Road Hales Comers, W isconsin 53130 414-025-1510 (voice) 414-425-7810 (fax) Practice type: General Oftice size: 5 Operatories, 2 hygiene only Building type: Multi-[enant commercial building Vacuum system type: Wet Vacuum system location: Basemen[ Source ot supplies: Patterson or Holt Amalgam Separator Manufacturer: Solmetex ., Model: Hg5 Purchase price: $695

. Power required: No Treatcnen[ chemicals required: No Size: 30 inches tall, 14 inches wide, 10 inches deep Priroazy reason for selecting modeL• Ease of installation, Low cost Waaanty: Two years 

### Separator InstaBation

~~ ~~ Time be[ween ordering and delivery: 1 week Plumbing contractor: JM Plumbing Installation da[e: March 1, 2004 Time needed: 2 hours L

~ stallation cost: $289

_ Problems encountered during installation: None Amalgam Recycler

_ Mercury Waste Solutions



### - 21211 Durand Avenue Union Grove, Wiscousin 53182 

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Shipper Fed Ex

_ " ' Recycling cost, including freight, is included in the cost of new filters. With the purchase of a new fdter, Solmetex
~ - provides pre-addressed, &eight-paid containers for the old filter. Replacement filters are $250. }
~ Altltough the manufacturer expected the filter replacement frequency to be every 4 months, the fust filter filled in m
- only 1 month. The cause was a new line cleaner that removed lazge amounts of residuai solids. A subsequent

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_ problem was the constant filling of the upper chamber with water. Increasing the air flow through the separator eventually solved this problem. In response to these problems, Solmetex agreed to supply a new "high volume"
~ Ag5 at no cost for the device. This device was installed on July 26, 2004. To further reduce the risk of problems,
~ the lines from the hygiene opetatories were red'uected around the amalgam separator. A total of three filteis were ~ shipped before the installation of the new sepazator. 

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# Amalgam Separator Case Study 6 Burleigh Dental

~ Doctors Monica Hebl and Mike Donohoo
~ - 7623 West Burleigh Street Milwaukee, Wisconsin 53222 414-444-4334 (voice) 

# ~ 414-444-3222 (fax)

_ hebldds@aoLcom , _ Practice type: Genenl

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~ . Oftice size: 6 Operatories, 0 hygiene only Building type: Sole occupant Vacuum system type: Wet Vacuum system location: Basement Source of supplies: Holt Dental Amalgam Separator , ~ " ` Manufacturer: R&D Services
~ Model: The Amalgam Collector CE24 Purchase price: $1075 Power required: No
~ Treatment chemicals required: 8 ounces of cold sterilizing solution once per week through suction line Size: 10 inches in diameter, 36 inches tall Primary teason for selecting model: Can see the amount of collected amalgam Recycling costs are reduced because only the collected waste is recycled, not a whole canistec Larger size takes longer to fill. Warranty: 1 yeaz ".;. Separator Installation Time between o

~ dering and delivery: 1 week Installer: Holt Dental Installation date: April 26, 2004 Time needed: 30 minutes Lutallation cost: $90 Problems during installation: None Amalgam Recycler 

### DRNA 145 West 58 m Street New York, New York ]0019 Shipper 

### UPS Expected &equency of shipments: Yeazly or less often Cost per shipment: $125 for a 1 gallon con[ainer, $400 for a 5 gallon container

~ ' The collected material is put into the same type of amalgam container as is used for other recycled amalgam. 

# ~ Removing the amalgam involves closing valves, draining away the water, opening the unit, and then removing the
~ collected waste. Although this effort is tnore than required by some other uni[s, being able to see [he arnount of ` waste collected max;m;

~ r s time between shipments and recycling just Ure waste, rather than a whole canister or =

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