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Elizabeth Toot-Levy 

<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 

~ 

tel: 216.641.6000 Re~n 5 He PMP c~~t~ ~m~x:.ao~ 
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(u,epamail.epa.Qov ~

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 We are pleased by the flexibility the draft Guidance provides, 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additional comments on the draft Guidance: 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 ~ 6) 64~ -8118 
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1~~1-~ L~ I_.: _, ~ ;a MADISON METROPOLITAN __ ~ '~ ' ' ; ~ 

SEWERAGE DISTRICT - ;~~ I.~Ui~ 2, 4 200. ~ , i ~ __:: u 

1610 Moorland Road ~_------- N?f~ •` ` S ~i "~~ 

Madison,Wl 53713-3398 _ -_.: .~ ECHr~ rCALF_7 ~ ~ ' ~~1 

Telephone (608) 222-1201 ~ ~^=-" EP.4, viG ~ . ~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 ~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 

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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 ep 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 Management 

wisconsin.gov Through Excellent Customer Service ~ 

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The Clean Water Peeple r/ 

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SF° t~ 1 2009~' 

August 26, 2004 

NPDES SUPPORT & 

U.S. Environmental Protection A enc TECHraicA ~ 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 ~nt collection containers. ~ 

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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 

~ 

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 ~, _ 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. w. 

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Preserving The Emironment • 

Impmving Water Qualiry ExcEnsion 

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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 ~~_ '~. 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 58m 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; ~rs time between shipments and recycling just Ure waste, rather than a whole canister or = 

CartCldge, minimi ~rs cOStS. . m -