1. Promoting Voluntary Efforts to Reduce Dental Mercury Releases to Wastewater Mark McMillan Colorado Department of Public Health and Environment October 29, 2004

2. Objectives Why this project, this place? Project phases Applying project results statewide

3. Why this project, this place? March 2002 - Enforcement action against CF&I Steel (dba Rocky Mountain Steel Mills) $1,800,000 penalty largely applied to Pueblo-based Supplemental Environmental Projects (SEPs): $500,000: Community-Based Projects $500,000: Alternative Energy Projects $500,000: Mercury Removal Projects ($300,000: Civil Penalty)

4. Why this project, this place? Mercury Removal Projects: $400,000 – Mercury Switch Removal Project http://www.cdphe.state.co.us/hm/mercury/ mercuryhom.asp http://www.cdphe.state.co.us/hm/mercury/ mercuryhom.asp $100,000 – Other Pueblo-Based Mercury Pollution Prevention Projects

5. Why this project, this place? Interest and support from CDPHE Water Quality Control Division Hg in surface water can bioaccumulate in fish tissue, posing risk to wildlife and humans that eat contaminated fish 41 states, including Colorado, have issued fish- advisories due to Hg contamination POTWs may face increasing challenges meeting new, lowered discharge limits for Hg (due to new EPA standard test method)

6. Why this project, this place? Dentists are a known source of Hg discharges to wastewater in Colorado An Evaluation of the Source Impacts and Control of Mercury. Al Garcia, Littleton-Englewood Wastewater Treatment Plant, 2002. Dental Hg releases to wastewater can be minimized through best management practices Pueblo-based pilot project results may be transferable throughout the state Project funding: $50,000

7. Project Phases Phase 1: Dental Survey/Data Collection Phase 2: Focused Outreach Effort Phase 3: Measurement of Project Value and Success

8. Phase 1: Dental Survey/ Data Collection Survey Purpose: To assess the use of BMP and BAT among Pueblo dentists, and to identify areas for outreach and improvement Survey results are summarized in: Dental Mercury Pollution Prevention Phase I Summary Report, Tetra Tech EMI Inc., February 2004.

9. Phase 1: Dental Survey/ Data Collection December 2003: Survey mailed to 59 dentists at 51 practices in Pueblo that either use or remove mercury-containing amalgam Survey Response Rate: 41 out of 59 dentists responded (69%) 40 out of 51 practices responded (78%)

10. Phase 1: Dental Survey Results How is Mercury–Containing Amalgam Used in Your Practice? (59 Pueblo dentists surveyed) Description Number Responses Percent of Responses Pre-capsulated Hg amalgam mixed with water for each new filling 2252% Hg is not used in new fillings, but Hg-containing fillings are removed 1638% Elemental Hg mixed w/ other constituents for each new filling 410%

11. Phase 1: Dental Survey Results What Mercury Recovery Equipment is Used in Your Practice? (59 Pueblo dentists surveyed) Description Number Responses Percent Responses Equipment Efficiency Chair-side trap with secondary filter 2766%81% Chair-side trap alone 1332%68% Hg amalgam separator 12%>96%

12. Mercury Amalgam Separators (The Hg5  Mercury Amalgam Separator System by SolmeteX Inc) Typically designed for in-line installation between the chair- side water drain and vacuum pump. Removes particles through physical and chemical processes, including: sedimentation, centrifugation, filtration, and ion exchange. Must be at least 96% efficient to be ISO certified. Required by law in Maine. Under consideration in seven other states. Typical cost: $500 - $7,500 (Ref. Journal of ADA)

13. Phase 1: Dental Survey/ Data Collection American Dental Association: “Best Management Practices for Amalgam Waste,” February 2003: “Amalgam should not be disposed of in the garbage, infectious waste ‘red bag,’ or sharps container…. because some communities incinerate municipal garbage, medical waste, and sludge from wastewater treatment plants.” ADA strongly recommends recycling as a primary best management practice

14. Phase 1: Dental Survey Results How is Mercury–Containing Waste Disposed in Your Practice? (59 Pueblo dentists surveyed) Item DisposedMedical Waste RecycledTrashOther Scrap amalgam 40%46%14%0% Empty amalgam capsules 42%11%39%8% Hg-containing extracted teeth 85%7.5% 0% Screens 52%9%33%6% Traps 64%12%18%6% Filters 66%10%17%7%

15. Phase 1: Dental Survey Results Under What Circumstances Would You Install an Amalgam Separator? (59 Pueblo dentists surveyed) Circumstance Number Responses Percent of Responses Required by Law2846% Encouraging Statement from ADA 1423% Cost below $5001017% No Cost47% Other47%

16. Phase 1: Dental Survey Results How Informed Do You Feel Regarding Hg BMPs and BATs? (59 Pueblo dentists surveyed) How Informed? Number Responses Percent of Responses Highly informed920% Moderately informed2556% Not well informed24% Want more information818%

17. Phase 1: Dental Survey Results What Type of Assistance Would Be Most Helpful? (59 Pueblo dentists surveyed) Type of Assistance Number Responses Percent of Responses Outreach Material1527% Financial Assistance1018% Workshop815% Implementation Assistance815% Training611% Other59% Trial or Money Back Guar.35%

18. Phase 1: Dental Survey Results What Form of Recognition (If Any) Would Be Favorable to You? (59 Pueblo dentists surveyed) Form of Recognition Number Responses Percent of Responses Placard/Certification1024% Newspaper717% Other25%

19. Phase 2: Focused Outreach Dental Hg Fact Sheet Panel Seminar Increased Involvement by the Colorado Dental Association (CDA)

20. Phase 2: Dental Hg Fact Sheet Regulatory Outlook for Pueblo Dentists Mercury Amalgam Separators Vendors, Operation/Maintenance, Cost Mercury Recycling Recyclers, Materials, Methods, Cost BMP Scorecard

21. Phase 2: Panel Seminar May 18, 2004 at Pueblo City-County Library Agenda: Welcome and Introduction by CDA Regulatory Outlook for Pueblo Dentists Mercury Amalgam Separators Vendors, types of separators, installation considerations, operation/maintenance Mercury Recycling Vendors, types of recyclables, how to implement a recycling program Breakout Session

22. Phase 3: Measurement of Project Value and Success Follow-up Survey to Pueblo Dentists – May 2004 Final Summary Report - August 2004 Summary of Project Results: BMPs/BATs implemented, Hg releases prevented, life cycle of Hg captured Lessons Learned: Barriers to amalgam separator implementation Recommendations for project improvement Recommendations for statewide implementation Project Follow-up – 2005

23. Overall Conclusions From Dental P2 Effort Surveys Useful for Gauging Interest, Gathering Information Dentists Thought Fact Sheet, BMP Insert, Meetings Worthwhile Voluntary Programs May Limit Need for Regulations Voluntary Programs Allow Participants to Customize Their Role Efforts Transferable

24. Applying Project Results Statewide Pueblo pilot project is a first-step in providing compliance assistance to Colorado POTWs charged with meeting new, lowered discharge permit limits for Hg. Outreach materials, including dental fact- sheet, vendor information, and panel seminar materials, will be made transferable through out the state. Outreach materials and ongoing summary reports available at: http://www.cdphe.state.co.us/hm/mercury/dental.asp http://www.cdphe.state.co.us/hm/mercury/dental.asp

25. Comments/Questions/Ideas? Contact: Mark McMillan CDPHE Mercury Program mark.mcmillan@state.co.us, 303-692-3140 mark.mcmillan@state.co.us Rick Koplitz Water Quality Control Division, CDPHE rick.koplitz@state.co.us,303-692-3618rick.koplitz@state.co.us Paul Cozetta Water Quality Control, City of Pueblo pcozzetta@pueblo.us, 729-544-3453 pcozzetta@pueblo.us