MEMORANDUM

TO: Carey Johnston, EPA/EAD Damon Highsmith, EPA/EAD

FROM: Meghan Camp, ERG

DATE: 23 March 2011

SUBJECT: Dental Recycling North America, In c. (DRNA) Meeting Minutes for 19 January 2011

On 19 January 2011, EPA met with Marc Sussman and Dr. Alfred Frost of DRNA Dentalcare Waste Management to discuss amal gam separator technologies. Discussion topics

included:

 Introductions;

 Background on DRNA Amalgam Separa tors and Services, including:

 Separation Technologies;

 ISO Standard and EPA/ETV Standard;

 Maintenance and Recycling; and

 Regulatory Considerations.

Attachment 1 lists the meeting participants.

Introductions

Dental Recycling North America, Inc. (DR NA) provides waste management services to dental facilities including amalgam separator eq uipment, recycling services, amalgam disposal, sharps and medical waste disposal, x-ray waste recycling and disposal, and pharmaceutical waste disposal. Some of DRNA’s main areas of business include servicing facilities for military, veterans’ affairs, and community centers.

Mr. Sussman provided background informa tion on DRNA’s philosophy regarding the dental amalgam issue, which DRNA views as a waste management issue. DRNA handles dental waste, including but not limited to amalgam, w ith a focus on recycling and providing dentists with a solution for regulatory compliance. He stated that there is a common misunderstanding among dentists, who often believe that simply installing an amalgam separator is enough to comply with state or local requirements. Mr. Sussman asserted that proper maintenance and recycling is equally important to the separator equipment because an amalgam separator will not function if it is not maintained. Purchasing and installing an amalgam separator is only the start of the process.Memorandum

23 March 2011 Page 2 of 5

Background on DRNA Amalgam Separators and Services

Prior to the meeting, EPA sent Mr. Sussman and Dr. Frost a list of questions for discussion. The following summarizes information that Mr. Sussman and Dr. Frost provided in response to these questions.

Please describe the technology- basis of your separator models.

DRNA sells two amalgam separator lines:

 ISO-certified amalgam separators, incl uding BU5 (<8 chairs), BU10 (up to 8 chairs), and BU30 (up to 20 chairs); and

 EPA-ETV certified amalgam separators, including MRU10 (up to 8 chairs) and MRU30 (up to 20 chairs).

The BU models use sedimentation to remove 99.9 percent of solids. The MRU models use the same sedimentation technology as the BU models for solids removal, but also include a sorbent column to remove soluble mercury. Overa ll removal for the MRU models is greater than 99.9 percent of solids and soluble mercury. DRNA is one of the only companies to develop an EPA-ETV certified amalgam separator model. Mr. Sussman stated that there is not much of a

market for the MRU models with th e exception of military facilities.

What are the allowable flow rates and capacities of your various models? What is the basis upon which a separator is determined to be appropr iate? Anticipated flow? Anticipated amount of amalgam? Other?

Amalgam separators are sized based on the num ber of chairs at the dental practice. DRNA’s BU and MRU models are designed to accommodate < 8 chairs or 8-20 chairs. Large facilities can install multiple amalgam separators in series. For example a Louisville, KY dental

school with 130 chairs uses 15 separators in series.

How are your separator efficienci es measured (ANSI, ISO, other)? Do you have any issues with the prevalent test protocols (ANSI, ISO, Other)?

DRNA’s BU line is certified using ISO 11143. Mr. Sussman pr ovided some clarification

on ISO certification. ISO certificati on means that the amalgam separator model was certified to a

standard at the time that it was tested in a lab. It does not guarantee that the purchased unit will operate at 95 percent efficiency in the fiel d. In addition, the ISO-cer tification assumes proper maintenance and change-out of the unit.

DRNA’s amalgam separators undergo an annua l audit to address any new modifications made to the units. DRNA uses a U.S.-based lab, NSF, to perform its IS O certification tests and annual audits. Once per year, NSF conducts an aud it to ensure that the amalgam separator that they tested is the same as the units that DRNA sells on the market. NSF verifies that the list of amalgam separator manufacturers is the same and that the unit components are the same.Memorandum

23 March 2011 Page 3 of 5

DRNA’s MRU line is certified to the EPA/ETV standard. This standard was developed starting in 2000 in response to POTW concer ns regarding mercury le vels. The goal of the standard was to develop a technology that would achieve a mercury concentration of 2 ppb.

Where within the dental facility, are your separat ors usually installed? What type of wastewater goes through your separators?

The amalgam separators are installed next to the vacuum pump, just upstream of the pump. The separator connects to th e suction line. Wastewater enters the separator, which uses a sedimentation technology to remove particles from the wastewater. The solid debris collects in the separator while the treated wastewater flows out of the separator to the vacuum pump. The unit also uses a 6 volt pump, which removes resi dual water from the sedimentation chamber once per night.

On a day to day basis, what needs to be done to efficiently operate and ma intain these systems? Who typically performs maintenance? The dentist or a third party?

Dentists need to change their separator unit every 12 months. After 10 months, DRNA sends a new canister to the facility requesting that the dentist change the ca nister within 2 months of receipt. The dentist then sends the full canister back to DRNA, who transfers the canister to a U.S. recycling facility, where the caniste r is recycled and resin is burned.

Mr. Sussman stated that 100 percent of DRNA’ s customers recycle th eir canisters at the 12-month frequency. Because DRNA is providing comp liance as a service, and because most of DRNA’s customers are located in regulated areas, DRNA has developed mechanisms for ensuring that customers recycle canisters on time. DRNA will send reminder post cards and conduct follow-up phone calls to remind dentists wh en it is time to change their canister. To demonstrate compliance, DRNA provides recycling documents to dentists indicating that waste was received and sent to a recy cling facility, and the approximate weight of waste. Mr. Sussman stated that it is about a one month delay betw een when the dentist sends the full cartridge to when DRNA provides the recycling documentati on to the dentist. In addition, Mr. Sussman noted that DRNA’s recycling services are not limited to amalgam separators. DRNA also manages chair-side and medical waste for its customers.

DRNA also uses their recycling service to track the amount of mercury removed from

dental wastewater. When a full canister arrives at a recycling facility, the recycling facility weighs the canister and determines the percent of the solids weight that is dental amalgam. Then, assuming 50 percent of amalgam is mercury, DR NA determines the amount of mercury collected per facility per year. Using th eir recycling tr acking data, DRNA estimates that 0.5 to 1 pounds of mercury are discharged by each dental facility per year.

Although change-out services are available to dentists, Mr. Sussman stated that most dentists change the amalgam separator themselves. Change-out is very simple and dentists do not

come in contact with the waste material.Memorandum

23 March 2011 Page 4 of 5

Regulatory Considerations

Mr. Sussman and Dr. Frost discussed some re gulatory considerations if EPA were to select amalgam separators as the technology basis for the Dental Amalgam Effluent Guideline.

Scrap amalgam . Dr. Frost asserted that regulations need to clearly distinguish between amalgam separators and scrap amalgam disposal requirements. Amalgam separators and scrap amalgam are two separate issues and both need to be addressed. The way that some State requirements are written, they promote the mi snomer that simply installing an amalgam separator is enough to addr ess the dental amalgam issue. Howe ver, it is equally important that dentists properly dispose of scrap amalgam.

Exemptions . Dr. Frost stated that several stat e programs exempt denture makers and endodontists, claiming that they do not remove amal gam. According to Dr. Frost, dentists in these practices do remove amalgam and should not be exempted. Oral surgeons and periodontists likely do not need to install amalgam se parators, but should follow scrap amalgam

BMPs. Dr. Frost stated that orthodontists can li kely be exempted from both amalgam separator and scrap amalgam requirements.Attachment 1

Table A-1. List of Meeting Participants

Name Affiliation Phone Email

Alfred Frost DRNA 716-207-9081 afrost@drna.com

Marc Sussman DRNA 800-360-1001 mmsussman@drna.com Chrystal Beasley US EPA 202-564- 0904 beasley.chrystal@epa.gov

Leslie Darman US EPA 202-564- 5452 darman.leslie@epa.gov Erik Helm US EPA 202-566-1049 helm.erik@epa.gov Damon Highsmith US EPA 202-566-2504 highsmith.damon@epa.gov Samantha Lewis US EPA 202-566-1058 lewis.samantha@epa.gov Jan Matuszko US EPA 202-566-1035 matuszko.jan@epa.gov Jan Pickrel US EPA 202-564-7904 pickrel.jan@epa.gov Meghan Camp ERG 703-633-1684 meghan.camp@erg.com