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Advocacy Alert 14-24


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To: Members & Affiliates
From: National Office
Date: November 24, 2014
Reference: AA 14-24


To inform its comments on EPA’s proposed Dental Amalgam Separator rule pdf button, NACWA is conducting a survey to collect mercury data and dental amalgam separator program information from publicly owned treatment works (POTWs). The proposed rule would establish pretreatment standards for the over 100,000 dental offices that place or removal amalgam fillings. These dental offices would be required to have dental amalgam separators that achieve a 99 percent reduction of total mercury, follow best management practices (BMPs), and submit annual certification reports to their POTW or other pretreatment control authority.

The rule would have a substantial impact on POTWs with pretreatment programs that would regulate these new “Dental Industrial Users” (DIUs). Since the number of dental offices is about 10 times the current number of categorical industrial users with pretreatment standards, EPA has proposed the new DIU category to prevent standard significant industrial user (SIU) requirements from overwhelming POTWs. Further information about the rule is available in NACWA’s Advocacy Alert 14-21. EPA recently announced a 60-day extension of the public comment period, and comments are now due by February 21, 2015. NACWA has created an initial position statement pdf button on the proposal and believes this data will help to refine and bolster this document and make our comment effort have a greater impact.

NACWA is asking all of its public agency members, as well as non-member POTWs, to complete this survey by Friday, December 19. Questions about the survey and comments about the proposed Dental Amalgam Separator Rule should be sent to Cynthia Finley at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

Purpose of Survey

NACWA believes that EPA has overestimated the environmental benefits of the proposed pretreatment standards, while underestimating the cost for POTWs and other control authorities to regulate DIUs. The NACWA Mercury & Dental Amalgam Separator Program Survey for POTWs will allow the Association to analyze current influent, effluent, and biosolids mercury data from POTWs and draw conclusions about the necessity of the rule to prevent pass-through or interference by mercury from dental offices.

In addition, POTWs that already have voluntary or mandatory dental amalgam separator programs will also be asked to provide information about their programs in the survey. This information will help NACWA determine the resources required by POTWs to implement a dental amalgam separator program.

Instructions for Survey

The online survey must be completed separately for each treatment plant operated by a clean water agency. Partially completed surveys cannot be saved. We recommend that you collect all information necessary to respond to the survey before beginning to complete the online form. The entire survey may be viewed before entering the requested information. However, the three mandatory entries on the front page of the survey must be completed to access the remainder of the survey:

  • Date
  • Name of treatment facility
  • Email of person completing survey

The facility name and email address will be kept confidential and will only be used by NACWA for quality control purposes. This information will not be reported to EPA or any other entity.

Complete instructions for the completing the survey are available at, and are also contained in the online survey. Please complete and submit surveys by Friday, December 19. If you do not have some of the information requested in the survey, or prefer not to answer certain questions, please simply skip these questions and complete as much of the survey as possible. We understand that this is a lot of information, but we need this level of detail to develop our comments and thank you for taking the time to respond. Please contact Cynthia Finley at This e-mail address is being protected from spambots. You need JavaScript enabled to view it with any questions about the survey, or with any comments about the proposed rule.








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