One-time compliance Report
The EPA has released their sample copy of the One-Time Compliance Report. This report certifies that if you are subject under the June 14th, 2017 ruling, you have fully implemented the requirements. The format and specifics of this report will differ from region to region. Before submitting it would be advised to read the ruling in it's entirety and consult with your local control authority as to it's applicability.
Find Your Control Authority
Control authorities will vary dependent on your location. If you visit https://www.epa.gov/npdes/contact-us-national-pretreatment-program you will find various POCs for your region.
Best Management Practices
Under the ruling you are prohibited from using waterline cleaners that contain oxidizers. These cleaners have been shown to dissolve mercury amalgam trapped in a separator, releasing it into the public water works. The submission of this compliance report certifies that you are not using any form of oxidizing waterline cleaner that "may increase the dissolution of mercury."
The argument that pH is of any consequence is a moot point with the added verbiage specifying the dissolution of mercury. This can be found in the sample report from EPA at https://www.epa.gov/eg/dental-effluent-guidelines.
Exemptions From the Ruling Are as Follows:
- Oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, or prosthodontics.
- Mobile units
- Dental dischargers that do not discharge any amalgam process wastewater to a POTW, such as dental dischargers that collect all dental amalgam process wastewater for transfer to a Centralized Waste Treatment facility as defined in 40 CFR part 437.
- Dental Dischargers that do not place dental amalgam, and do not remove amalgam except in limited emergency or unplanned, unanticipated circumstances, and that certify such to the Control Authority as required in § 441.50 are exempt from any further requirements of this part.
If you fall the ruling does not apply you must submit a compliance report
Under ISO 11143...
An amalgam separator must be able to achieve a removal efficiency of at least 95 percent of the mass of solids from all amalgam process wastewater.
"The final rule allows dental offices to continue to operate existing amalgam separators for their lifetime or ten years (whichever comes first), as long as the dental discharger complies with the other rule requirements including the specified BMPs, operation and maintenance, reporting, and recordkeeping requirements. Once the separator needs to be replaced or the ten-year period has ended, dental offices will need to replace the amalgam separator with one that meets the requirements of the final rule."