Region 8 Conference Amalgam Separators What s New? 101 Review May 11 14, 2009



Similar documents
Kelly Beauregard Na-onal Marke-ng Manager. SolmeteX A division of Layne Christensen 50 Bearfoot Road Northborough, MA

Why is a Dental Amalgam. Reduction Program Being Implemented Now? PROGRAM OVERVIEW TOPICS

Mandatory Amalgam Separator Program Frequently Asked Questions

Technical and Economic Development Document for the Proposed Effluent Limitation Guidelines and Standards for the Dental Category

CALIFORNIA ASSOCIATION of SANITATION AGENCIES

Chairman Dan Burton, Subcommittee on Human Right and Wellness President Parin Shah, San Francisco Commission on the Environment

Best Management Practices for Mercury Waste Management in Dental Offices

Dentistry and the Environment

ON-SITE WASTEWATER TREATMENT SYSTEMS ACT

Best Management Practices For Dental Office Waste

How To Get A Stormwater Discharge Permit In A City Of Scottsdale

PHARMACEUTICAL WASTE UPDATE ON HANDLING AND DISPOSAL ASTSWMO MEETING August 11, 2011

BEST MANAGEMENT PRACTICES FOR DENTAL OFFICES CLEAN WATER INDUSTRIAL WASTE MANAGEMENT DIVISION OF THE CITY OF LOS ANGELES

UTILITIES DEPARTMENT

Subject: Comments on the Final 2010 Effluent Guidelines Program Plan

Health Services Industry Detailed Study

IC24. DISPOSAL OF WASTEWATER GENERATED BY MOBILE BUSINESSES AND OUTDOOR ACTIVITIES

INDUSTRIAL WASTEWATER PERMIT APPLICATION (SHORT FORM DENTAL OFFICE OR CLINIC)

Procedures for Storing Dental Amalgam Waste and Requirements for Amalgam Waste Storage/Shipment Containers N295

DRAFT Public Outreach Document for What s an SSMP?

Even collection systems with high-performing operation and maintenance programs will eventually

City of Los Angeles Bureau of Sanitation Business Development Services

NESEMC Top Solar Policies

Environmental Technology March/April 1998

San Luis Obispo County Los Osos Wastewater Project Development TECHNICAL MEMORANDUM SEPTAGE RECEIVING STATION OPTION TABLE OF CONTENTS

Grease Trap Maintenance, Procedures and Cleaning Logs

Environmental Regulations & Best Management Practices CARPET CLEANING OPERATIONS. Carpet Cleaning Operations in the Capital Regional District

RLI ENVIRONMENTAL INSURANCE Environmental Solutions for a Greener World

Florida Department of Environmental Protection

medentex Dental Recycling & Utility Room Solutions

Pursuant to Department of Environmental Protection Rules Chapter 555, effective March 9, 2009

City of Monroe Wastewater System Report

NEVADA CITY WASTEWATER TREATMENT INQUIRY

WASTEWATER TREATMENT OBJECTIVES

RULE DRY CLEANERS USING SOLVENT OTHER THAN PERCHLOROETHYLENE

Guidance on applying for approval of installation of a commercial onsite wastewater system

VEHICLE IDLING AT SCHOOLS

Electronics Recycling Coordination Clearinghouse Harmonization Workshop at E-Scrap 2011

TCLP Analysis of Waste Dental Amalgam April 2004

Certification and Verification of Offset and Trading Credits in the Chesapeake Bay Watershed

Cambridge Wastewater Treatment Facility

Application Form 2E. Facilities Which Do Not Discharge Process Wastewater

DRAFT Guidelines for Manually Diverting Outdoor Wastewater to the Sanitary Sewer

Best Management Practices Fats, Oils, & Grease

El Paso Water Utilities Public Service Board. Application for Renewal Industrial Wastewater Discharge Permit

Appendix C3: Response Plan for Investigations of Illegal Discharges, 2016

THE ADVANCED DENTAL DRY VAC DENTAL SYSTEMS

To: A. Hal Key, Jacqueline E. Schafer May 9, Question Presented

Appendix H. Toxicity Control Options for Organophosphate Insecticides

Legislative Summary Sheet: Bills Related to Military Families Recently Introduced into State Legislatures

VCF Program Statistics (Represents activity through the end of the day on June 30, 2015)

NPDES Phase II Small MS4 Permit Program

N.J.A.C. 7:9A Amendments

SECTION 1 PURPOSE AND POLICIES

Issue Status Chart: 2005/2006 Viatical and Life Settlement

NPDES Permit No. IL Notice No. IL TTL. Public Notice Beginning Date: June 15, Public Notice Ending Date: July 16, 2012

Mercury in Waste Dental Amalgam: Why Is It Still a Problem?

City of Dallas Wastewater Collection System: TCEQ Sanitary Sewer Outreach Agreement City Council Briefing January 17, 2007

pennsylvania Mr. Shawn Garvin Regional Administrator U. S. Environmental Protection Agency Region III 1650 Arch Street Philadelphia, PA

Creating Secure Medicine Return Programs to Reduce Misuse of Medicines in King County & Washington State

Dental Office P2 WRPPN 2005

Bio-Clean. for Septic Systems. Tips for Using Bio-Clean. Page Index METRIC CONVERSIONS

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C DEC

Best Management Practices

Brewery Wastewater: 2010 Water and Wastewater Conference Page 1

DOCKET NO. D CP-2 DELAWARE RIVER BASIN COMMISSION

City of Mebane Wastewater Collection and Treatment Facility

The Vermont Legislative Research Shop

2006 Standard Application Processing Time. 10 months. 14 months

INTRODUCTION AND BACKGROUND

Marketplaces (Exchanges): Information for Employers and Individuals Lisa Klinger, J.D.

NPDES Permit No. IL Notice No. JCH: bah. Public Notice Beginning Date: November 27, Public Notice Ending Date: December 27, 2012

Technical Information Paper No

DRAFT Solid Waste and Sustainability Advisory Panel Proposals. June 17, 2016

Environment. Dealing with Hazardous Waste and Processing Effluents at Photographic Processing Facilities. Some used. photographic processing

Connecticut Department of Energy and Environmental Protection

Removing Heavy Metals from Wastewater

Dental Therapist Initiatives, Access, and Changing State Practice Acts The ADHA Perspective: An Update

WASTEWATER DISCHARGE PERMIT APPLICATION FOR DRY CLEANING SERVICES. City: State: Zip: City: State: Zip:

ENDODONTOLOGY. Best management practices for hazardous dental waste disposal. Review Article ABSTRACT

Prevent Blockages in the Sanitary Sewer System

KODAK Developer System Cleaner and Neutralizer

A METRO VANCOUVER POSITION PAPER ON BILL S 8: THE SAFE DRINKING WATER FOR FIRST NATIONS ACT

GUIDELINES FOR LEACHATE CONTROL

Improper storage of potential pollutants will increase the risk of water pollution that may occur because of spills.

AAIS Mobile-Homeowners 2008 Series

Removing Thallium from Industrial FGD Scrubber Water with Sorbster Adsorbent Media

California Wastewater

PUBLIC LAW AUG. 6, 1996 DISTRICT OF COLUMBIA WATER AND SEWER AUTHORITY ACT OF 1996

NEW JERSEY SMALL BUSINESS ENVIRONMENTAL ASSISTANCE PROGRAM

Amalgam Management FOR D E N T A L O F F I C E S

State Annual Report Due Dates for Business Entities page 1 of 10

Fats, Oil, and Grease (FOG) Best Management Practices (BMP) For Food Service Facilities. Guidance Manual

Placement and removal of dental amalgam restorations

Best Management Practices (BMPs) Ideas for School Districts. Presented by: Donald Lussier

Asbestos Storage Facility Plan Examples

TARP Section 2.2 Stormwater BMP Screening for Validation

Notices of Cancellation / Nonrenewal and / or Other Related Forms

Department of Legislative Services Maryland General Assembly 2012 Session

40 CFR Hazardous Waste Determination

Transcription:

Region 8 Conference Amalgam Separators What s New? 101 Review May 11 14, 2009 AL Dube National Sales Manager SolmeteX, a division of Layne Christensen (adube@solmetex.com)

What s New in the Amalgam Separator world? EPA, NACWA and ADA sign a Memorandum of Understanding Dec 29, 2008. Data gathering on systems installed, voluntary installation of amalgam separators. Michigan Legislature passes unprecedented law limiting and removing local POTW authority to regulate the dental community Jan 12, 2009. Special interests at its best.

Lets Split Them Apart

The Basics of the MOU http://www.epa.gov/guide/dental/files/mou.pdf Have Dentists follow ADA BMP s Voluntarily install separators (ADA BMP s do not require separators only recommend) ADA intends to establish a tracking system (Fox governing the hen house) Any special interest reporting data or self regulating A contradiction, demonstrate a significant increase in the use of amalgam separators however only suggesting a 10% increase per year ~ 120,000 facilities / ~ 30,000 installations 3000 per year would take 30 years.

Lets Break them out American Dental Association a. ADA will promote compliance with the ADA BMPs by dentists and other members of the dental team. b. ADA will prepare and submit to EPA and NACW A for review and comment, the baseline report described in subparagraph B.2., above. Thereafter, ADA resolves to submit reports to EPA and NACW A according to plan they will form when interim goals are established. The parties also resolve to continue to consult and coordinate, as appropriate and agreed upon by the signatories. ADA will revise the reports, as appropriate, and submit the final reports to EPA and NACW A.

ADA will prepare and submit to EPA and NACW A for review and comment, the baseline report described in subparagraph B.2., above. Thereafter, ADA resolves to submit reports to EPA and NACW A according to plan they will form when interim goals are established. The parties also resolve to continue to consult and coordinate, as appropriate and agreed upon by the signatories. ADA will revise the reports, as appropriate, and submit the final reports to EPA and NACWA.

c. ADA will continue and expand its programs to raise awareness and provide training, outreach, and implementation resources to dentists and other members of the dental team, and where possible, dental students, on the benefits of following the ADA BMPs and the proper ongoing operation and maintenance of the ADA BMPs. This effort includes working with EPA and NACW A in developing seminars, continuing dental education courses and web based compliance assessment information.

d. ADA will facilitate meetings between EPA, NACW A, and the American Dental Education Association and other appropriate associations, to discuss methods by which these other dental related associations could contribute to the accomplishment of the goals ofthe Voluntary Dental Amalgam Discharge Reduction Program.

Environmental Protection Agency a. EPA resolves to promote to dentists and NACW A members the benefits of dentists voluntarily adopting the ADA BMPs. b. EPA resolves to submit data it believes is relevant to the ADA to assist in the preparation of the baseline report and the tracking reports.

c. EP A resolves to review and provide comments on the draft baseline report and the tracking reports. d. EPA plans to raise awareness of this Voluntary Dental Amalgam Discharge Reduction Program with EPA Regional pretreatment personnel, state pretreatment personnel, and POTWs and, as appropriate, provide tools and report progress to these stakeholders and the public. e. EPA resolves to work, in conjunction with the ADA, to develop a program to provide recognition to dentists who comply with the ADA BMPs, e.g., by providing a certificate to dentists who comply with the ADA BMPs.

f. EP A resolves to work in coordination with ADA and NACW A to develop training tools and information for dentists, States, Tribes, and POTWs. g. As appropriate, EPA resolves to meet with the American Dental Education Association and other appropriate associations and relevant entities to discuss methods by which these other dental related groups could contribute to the accomplishment of the goals of the Voluntary Dental Amalgam Discharge Reduction Program.

National Association of Clean Water Agencies a. Where an individual POTW already has data on the degree of compliance with either a mandatory program or a voluntary program, NACWA will encourage its members to submit such data to the ADA to assist in the preparation of the baseline report and the tracking report. b. NACWA resolves to review and provide comments on the draft baseline report and the tracking reports.

c. NACW A resolves to continue to provide information to its members on the various methods of reducing the discharge of amalgam to POTW s, including through the Voluntary Dental Amalgam Discharge Reduction Program, as well as other programs and requirements.

Joint Activities a. All signatories resolve to work to encourage compliance with the ADA BMPs. b. All signatories resolve to use their best efforts to work cooperatively to achieve the goals of the Voluntary Dental Amalgam Discharge Reduction Program.

Limitations No limitation to any Federal, State or POTW to regulate. No funds to support the document

What does it all mean Signed by Ben Grumbles the out going EPA Assistant Administrator for Water of the Bush Admin. ADA did not want to deal with the Obama Admin. A lot of words and ADA suggestion of providing the data A lot of words with little hope of action

Questionnaire Questionnaire Dental Amalgam Separator State: Date of Legislation: 1. Number of practicing dentists: 2. Data source for the number of dentists: 3. Do the dentists have to certify with the State? 4. Who has oversight of this? 5. Who has enforcement of this? 6. Are best management practices required? 7. Are best management practices enforced? 8. Number of dentists that have certified they have installed an amalgam separator:

9. Number of dentists that have certified they are in compliance with the State law: 10. Number of dentists that have not complied with the regulation: 11. Overall compliance % rate: 12. Number of Dental certifications submitted by year Prior to date of legislation: Each year after: Comments: Date information collected: Certifying contact from State:

2001 2008 Sales Analysis 2,000 1,800 1,600 2001 2008 Sales Analysis 1,400 States with legislation(9) 1,200 1,000 800 600 States with partial legislation(7) States with no legislation(34) 400 200-2001 2002 2003 2004 2005 2006 2007 2008

Sales of System Regulation Sales Trend 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Maine Dental Association Connecticut State Dental Association Massachusetts Dental Association New Hampshire Dental Association New York Dental Association -24-22 -20-18 -16-14 -12-10 -8-6 -4-2 0 2 4 6 8 10 12 14 16 18 20 22 24 Months Prior to Effective Regulation Date Months After Effective Regulation Date

Current Amalgam Separators Regulations 10 States have mandatory Amalgam Separator regulations (ME, NH, MA, VT, RI, CT, NY, NJ, OR, MI) *MN and WA have programs in place but there is no formal regulation Several other States have local mandatory programs

Michigan Legislation http://www.legislature.mi.gov/documents/2007 2008/publicact/pdf/2008 PA 0503.pdf On or before December 31, 2013, a dentist described in subsection (1) shall install or have installed and use on each wastewater drain in the dentist s office that is used to discharge dental amalgam a separator that has an efficiency of 95% or more as determined through testing in accordance with standards published by the international organization for standardization in ISO 11143:2008 Dental equipment Amalgam separators. On or before the expiration of 90 days after the effective date of this section, the department, in consultation with the department of environmental quality, shall promulgate rules regarding best management practice for dental

Reality Committee to decide the rules have not even met yet. reality is 12 18 months before rules announced for public comment.

Pay Attention Beginning on the effective date of this section and subject to this subsection, this section preempts and supersedes any local ordinance, regulation, or resolution that imposes conflicting, different, or additional standards or requirements on dentists than those contained in this section or rules promulgated by the board under this section. A local unit of government may enact, adopt, maintain, amend, or enforce an ordinance, regulation, or resolution that requires implementation of the requirement in subsections

Watching Not done yet you (2) and (3) before the date required in subsection (2). A local unit of government shall not enact, adopt, maintain, or enforce an ordinance, regulation, or resolution that imposes conflicting, different, or additional standards or requirements on dentists than those contained in this section or rules promulgated by the board under this section, including, but not limited to, the requirement to obtain a permit that limits the discharge of mercury into wastewater with a limitation greater than that capable of being achieved by full compliance with this section. This act is ordered to take immediate effect.

Why Should You Care? This could happen to you

Effects of amalgam separator installations Security Water and Sanitation District, Colorado Springs CO State of Colorado issued the POTW a cease and desist order. (For not meeting NPDES mercury limits) Required the installation of amalgam separators Influent and Effluent total mercury number dropped and now they operate with in the NPDES permit.

Security Water and Sanitation District 2008 SSD Influent Mercury Data 1/10/2008 80.0 ng/l 2008 SSD Effluent Mercury Data 1/10/2008 9.90 ng/l 2/6/2008 141 ng/l 3/4/2008 91.7 ng/l 2/6/2008 12.8 ng/l 2/19/2008 8.5 ng/l 3/4/2008 11.5 ng/l 4/8/2008 7.87 ng/l 4/8/2008 113 ng/l 5/1/2008 138 ng/l 6/3/2008 782 ng/l 7/1/2008 150 ng/l 8/4/2008 87.7 ng/l polishing unit installed 8/15/08 9/3/2008 86.8 ng/l 10/1/2008 75.7 ng/l 11/3/2008 62.1 ng/l 12/3/2008 55.3 ng/l 1/7/2009 55.8 ng/l 2/4/2009 82.9 ng/l 3/3/2009 87.5 ng/l 5/1/2008 8.41 ng/l 6/3/2008 11.7 ng/l 6/17/2008 8.61 ng/l 7/1/2008 8.82 ng/l 8/4/2008 7.01 ng/l polishing unit installed 8/15/08 9/3/2008 6.31 ng/l 10/1/2008 5.41 ng/l 11/3/2008 4.60 ng/l 12/3/2008 6.70 ng/l 1/7/2009 6.31 ng/l 2/4/2009 7.88 ng/l 3/3/2009 6.88 ng/l

Review What is an Amalgam Separator? First: The Amalgam Separator name is incomplete. THESE ARE SOLIDS COLLECTORS Separate amalgam and every other solid material suctioned down the vacuum line. Second: Mercury is not the target, solids are.

What do they do? Treat contamination at its source Most from just before the Vacuum Pump Separate suspended solid and water from air flow Capture the solids. Captured solids can be recycled or disposed of properly

Mercury removal systems? Amalgam Separators capture Mercury by default not by design (Important relative to MI Law) Designed to meet an ISO Particle Standard. Designed to capture 99% of solids by weight not total mercury

ISO 11143 Certification International Standards Organization A protocol for testing systems in a laboratory environment It is a particle standard by weight (Not mercury) Weigh at the start Weigh after drying Results based on a % of solids removal Standard is 95% All but one in the US 99% ISO ISO Standard reissued in 2008 with not significant changes (ADA, SolmeteX on committee)

What does that mean? Based on the MI Law potential numeric limits would be thwarted. Separators are not designed to meet numeric limits but if they were 1 ppm equates to 10 ppb at 99% capture rate if it were dissolved mercury. 1 gram would equate to 10 ppm at 99% mercury removal rate. SolmeteX found greater than 6 grams from one dental facility over a 24 hr period.

Types of Amalgam Separators Sedimentation Centrifugal Mechanical Chemical Combination

Rebec Rasch The Guardian DRNA Metasys M.A.R.S.

R & D Services SolmeteX

Vacuum Systems Wet System Dry System

Why Understand Vacuum? Wet ring vacuum pumps discharge up to ¾ a gallon of water per minute 360 gallons of clean water per 8 hour day Delusion might be the unintended solution in dental offices Dry vacuum only discharges what comes from the chair 1 liter per day per chair A four chair practice a gallon per day.

Installations

System easy to install Generally installed by dealers or plumbers Systems costs from as little as $330 $1200 for 90% of the dental industry.

Potential Issue With Separator System can and do clog If separator is a black box without an indicator, how do you know the system is functioning? The opportunity to install and forget it is a possibility

Vacuum Flow Flow under vacuum is not the same as flow under positive pressure Chair #1 Chair #2 Chair #3 Vacuum Pump Flow only happens when air moves Suction must be open at the chair for liquid and solids to move High speed suction is open only a few seconds each time Flow to amalgam separators normally a trickle not a flood

Line Cleaners There are approximately 35 vacuum line cleaners used in dental facilities Line cleaners have different ph ranges from 1 11.5 Some line cleaners have oxidizers Oxidation will break down an amalgam release mercury. Chlorine

Line Cleaners Non oxidizing cleaners Discharge to Publicly Owner Treatment Works (POTW s) require neutral ph between 5 10.5. A dentist could be out of compliance for discharge to sewer. In Massachusetts the regulation requires the use of neutral ph line cleaners 6.5 9

What is there to maintain? Separators capture Solids Maintenance is to remove the collected solids and responsibly recycle or dispose of the waste Amalgam Separator waste can be sent by common carrier

Disposal Logistics Some companies have developed simple and easy packaging, transportation, tracking, recycling, and waste characterization to dispose of the waste properly. Others separator companies following procedures or having waste haulers pick them up. Recycle or Land Fill

What to do with the waste? Recycling / Retorting Landfill

Survey of Regulated States Data showed that 92% of all dentists within five of the six New England States have complied with the legislation and 94% of dentists required to install a separator have done so. Furthermore, Maine and Vermont have installation rates of 100 % and 99 % respectively. These numbers prove that a mandatory amalgam separator program provides effective RI did not provided sufficient enough data to be included in this study

Maintaining Amalgam Separators and BMP s Certification Documentation Education Clarification

Servicing Separators Each Separator has a capture volume. When capacity reached, the collection container needs to be replaced. No standard for replacement as each dental practice is different and creates different volumes of waste. Frequency of change is established by the manufacturer

Servicing the separators: Containers should be replaced a least once a year Container sales are at.8 per year. Conclusion is not being replaced timely

Conclusion Regulations perpetuate installations of amalgam separators. Certification is one way to know installations have occurred Annual certification will assist in replacement of collection containers Amalgam separators have an impact on both influent and effluent numbers