Toilets Are Not Trashcans! Protecting Our Pipes, Pumps, Plants, & Personnel

Transcription

1 Toilets Are Not Trashcans! Protecting Our Pipes, Pumps, Plants, & Personnel Cynthia A. Finley, Ph.D. National Association of Clean Water Agencies September 12, 2016

2 National Association of Clean Water Agencies (NACWA) Represents nearly 300 publicly owned treatment works (POTWs) Members serve: Populations ranging from 1,700 to 7.5 million The majority of the sewered population in the U.S.

3 NACWA Public Agency Members

4 EPA/ADA/NACWA MOU Memorandum of Understanding (MOU) signed December 29, 2008 Promote use of the American Dental Association (ADA) Best Management Practices (BMPs) Reduce mercury discharges to POTWs Voluntary approach no new requirements

5 From MOU to a Rule Preliminary 2010 ELG Plan (Dec. 28, 2009) Reaffirmed EPA s decision to not pursue rulemaking for dental amalgam Press Release (Sept. 27, 2010): EPA will propose rule to protect waterways by reducing mercury from dental offices Final 2010 ELG Plan (Oct. 26, 2011): Given the human health and aquatic-life impacts associated with mercury, the level of stakeholder interest, and the availability of a technological solution, EPA decided to initiate rulemaking to develop pretreatment standards for dental mercury to more thoroughly and expeditiously address this water pollution problem.

6 Proposed rule: Dental offices Proposal published Oct. 22, 2014 Dental offices that place or remove amalgam must: Install amalgam separators that are certified to achieve 99% reduction of total mercury according to 2008 ISO standard Follow BMPs for scrap amalgam disposal and chair-side trap cleaning Certify compliance with baseline report and annual certification Existing separators grandfathered for 10 years

7 Proposed rule: Control Authorities General Pretreatment Regulations revised to establish Dental Industrial User (DIU) category POTWs with pretreatment programs are Control Authority, otherwise state or EPA Region provides oversight of DIUs DIUs that are out of compliance for 90 days become Significant Industrial Users (SIUs) No explanation of how a dental office classified as an SIU becomes a DIU again

8 NACWA Mercury & Dental Amalgam Survey Based on North Carolina Pretreatment Consortium survey Collected influent, effluent, & biosolids mercury concentration information for 2011, 2012, & 2013 Collected information about existing dental amalgam separator programs 123 utilities responded, with information from 211 wastewater treatment facilities

9 Sizes of Utility Respondents Population Served Number of Utilities 25, ,001 50, , , , , , , ,001 1,000, >1,000, Did not report 16 TOTAL 123

10 Facilities by EPA Region Number of Facilities Total Facilities = 211 (from 123 utilities) EPA Region

11 Influent & Effluent Mercury Concentrations Avg. Influent Conc. (ng/l) Avg. Effluent Conc. (ng/l) No. of Influent Samples No. of Effluent Samples (Only samples tested with Method 1631 were used in this analysis.)

12 NPDES Permit Violations for Mercury Number of Facilities Reporting Data Total Number of Effluent Samples Number of Facilities with NPDES Permit Violation for Mercury * 3* *Violation occurred in 2012 and 2013 for one facility that had very low default interim limits that were applied when the facility s NPDES permit expired. The new permit has higher limits that would not have led to violations in 2012 and 2013.

13 Mercury Removal Efficiencies Number of Facilities Facilities each year used Method 1631 for both influent and effluent. 72% of facilities had removal efficiencies of 94% or more <80 Removal Efficiency (%)

14 Biosolids Data No. of Facilities Reporting Data Total No. of Biosolids Samples 1,973 1,879 1,871 No. of Facilities with Biosolids Violations Max. Biosolids Hg Content from Facility with Violation (mg/kg dry wt) Max. Biosolids Hg Content from Facilities without Violations (mg/kg dry wt) 0 1* *Violation occurred at 1.51 mg/kg dry weight because the facility has a low mercury limit to ensure that its sewer sludge incinerator reliably meets air emission requirements.

15 Average Concentration of Mercury in Biosolids Number of Facilities CFR Part Table 3: High Quality biosolids mercury limit is 17 mg/kg. < >3 Average Hg Concentration (mg/kg dry weight)

16 NACWA s Position The proposed rule is unnecessary and should be withdrawn POTWs currently meet all mercury requirements for effluent and biosolids pass through/interference are not occurring Successful state and local dental amalgam separator programs have been established when needed EPA overestimates the environmental benefits and underestimates the costs of the rule

17 Follow up to comments BUT Final Rule expected December 2016

18 2016 Preliminary ELG Plan NACWA asked EPA to consider further study of Centralized Waste Treatment (CWT) Category EPA currently studying for oil & gas extraction wastewater Expand to all CWT facilities? Landfill Category Currently no pretreatment standards Interference with UV disinfection from leachate Soap & Detergent Manufacturing Category Are pretreatment standards still needed?

19 Pesticides: Diquat Dibromide Root control important for sewer line maintenance Potential interference with biological treatment NACWA recommended requiring 24-hour advance notice to POTW for all root treatment chemicals

20 Pesticides: Lithium Hypochlorite Used in swimming pools, spas, and hot tubs NACWA supports: Statement of risk to aquatic environment Label language: contact your local sanitary sewer and storm drain authorities and follow their discharge instructions. Do not discharge pool or spa water to any location that flows to a gutter or storm drain or natural water body unless discharge is approved by state and local authorities.

21 Pesticides: Malathion Used to treat head lice usage will peak during outbreaks NACWA recommended that EPA s biological evaluation include: Indoor use to treat lice Formation of malaoxon, which is more toxic to aquatic organisms, in wastewater disinfection process Potential to interfere with wastewater treatment processes

22 FDA Triclosan Ban FDA banned Triclosan in consumer soaps and washes on September 6 Triclosan not shown to be safe and effective Review of healthcare uses and hand rubs coming next

23 Thank you! Cynthia Finley Director, Regulatory Affairs ational Association of Clean Water Agencies