Page
1
of
10
Memorandum
From:
Carey
A.
Johnston,
P.
E.
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
(
www.
epa.
gov/
edockets/)

Date:
August
4,
2005
Re:
Industry
Sectors
Being
Evaluated
under
Proposed
"
Health
Services
Industry"
Category
Overview
EPA
establishes
technology­
based
national
regulations,
termed
"
categorical
pretreatment
standards,"
for
categories
of
industry
discharging
pollutants
to
Publicly
Owned
Treatment
Works
(
POTWs)
that
may
pass
through,
interfere
with
or
are
otherwise
incompatible
with
POTW
operations.
CWA
section
307(
b).
Generally,
categorical
pretreatment
standards
are
designed
such
that
wastewaters
from
direct
and
indirect
industrial
dischargers
are
subject
to
similar
levels
of
treatment.
EPA
has
promulgated
such
pretreatment
standards
for
35
industrial
categories.

EPA
is
reviewing
various
indirect
discharging
industries
without
categorical
pretreatment
standards
to
determine
whether
their
discharges
were
causing
pass
through
or
interference,
in
order
to
determine
whether
categorical
pretreatment
standards
are
necessary
for
other
industrial
categories.

As
discussed
in
the
2005
Annual
Screening­
Level
Analysis
(
see
DCN­
02173),
stakeholder
comments
and
pollutant
discharge
information
have
helped
EPA
identify
industrial
sectors
for
this
review.
In
particular,
EPA
has
looked
more
closely
at
sectors
that
are
comprised
entirely
or
nearly
entirely
of
indirect
dischargers,
and
is
grouping
them
into
the
following
seven
industrial
categories:
Food
Service
Establishments;
Industrial
Laundries;
Photoprocessing;
Printing
and
Publishing;
Independent
and
Stand
Alone
Laboratories;
Industrial
Container
and
Drum
Cleaning;
and
Health
Services
Industry.

EPA
is
including
within
the
Health
Services
Industry
the
following
activities:
Independent
and
Stand
Alone
Medical
and
Dental
Laboratories,
Offices
and
Clinics
of
Doctors
of
Medicine,
Offices
and
Clinics
of
Dentists,
Nursing
and
Personal
Care
Facilities,
Veterinary
Care
Services,
and
Hospitals
and
Clinics.
This
memorandum
describes
the
rationale
for
this
grouping
by
examining
the
type
of
operations
performed,
pollutants
and
wastewaters
generated,
and
available
pollution
prevention
and
treatment
options
for
each
industry
sector.
1U.
S.
Census
Bureau.
2002
NAICS
Definitions.
Available
online
at:
http://
www.
census.
gov/
epcd/
naics02/
def/
NDEF62.
HTM#
N62.

Page
2
of
10
Type
of
Operations
Performed
All
six
industry
sectors
are
grouped
under
the
two
digit
SIC
code
80,
"
Health
Services,"
and
the
two
digit
NAICS
code
62,
"
Health
Care
and
Social
Assistance."
The
Census
Bureau
defines
the
Health
Care
and
Social
Assistance
industrial
sector
as:

The
Health
Care
and
Social
Assistance
sector
comprises
establishments
providing
health
care
and
social
assistance
for
individuals.
The
sector
includes
both
health
care
and
social
assistance
because
it
is
sometimes
difficult
to
distinguish
between
the
boundaries
of
these
two
activities.
The
industries
in
this
sector
are
arranged
on
a
continuum
starting
with
those
establishments
providing
medical
care
exclusively,
continuing
with
those
providing
health
care
and
social
assistance,
and
finally
finishing
with
those
providing
only
social
assistance.
The
services
provided
by
establishments
in
this
sector
are
delivered
by
trained
professionals.
All
industries
in
the
sector
share
this
commonality
of
process,
namely,
labor
inputs
of
health
practitioners
or
social
workers
with
the
requisite
expertise.
Many
of
the
industries
in
the
sector
are
defined
based
on
the
educational
degree
held
by
the
practitioners
included
in
the
industry.

Excluded
from
this
sector
are
aerobic
classes
in
Subsector
713,
Amusement,
Gambling
and
Recreation
Industries
and
nonmedical
diet
and
weight
reducing
centers
in
Subsector
812,
Personal
and
Laundry
Services.
Although
these
can
be
viewed
as
health
services,
these
services
are
not
typically
delivered
by
health
practitioners.
1
As
described
in
this
definition,
all
six
industry
sectors
identified
by
stakeholders
require
services
to
be
delivered
by
trained
professionals
for
the
purpose
of
providing
health
care
and
social
assistance
for
individuals.
These
entities
may
be
free
standing
and
perhaps
privately
owned
or
may
be
part
of
a
hospital
or
health
system.
These
services
can
include
diagnostic,
preventative,
cosmetic,
and
curative
health
services
and
may
include
the
following
seventeen
operations,
not
all
of
which
generate
wastewater:


Administrative
Activities
and
Services;


Support
Services;


Facilities
Management,
Maintenance,
and
Plant
Operations;


Laboratory
Services;


Diagnostic
Services;


Surgical
Services;


Inpatient
Care
Services;
2U.
S.
EPA.
Profile
of
the
Healthcare
Industry.
Available
online
at:
http://
www.
epa.
gov/
compliance/
resources/
publications/
assistance/
sectors/
notebooks/
health.
pdf.
EPA/
310­
R­
05­
002.
February
2005.

3Ibid,
Page
52.

Page
3
of
10

Critical
Care
Services;


Emergency
Care
Services;


Respiratory
Care
Services;


Dialysis;


Physical
Therapy/
Occupational
Therapy;


Outpatient
Services
(
Nonsurgical);


Oncology/
Cancer
Care
Services;


Dentistry;


Animal
Research
and
Testing;


Clinical
Research;
and

Construction
and
Renovation.
2
These
seventeen
operations
are
defined
in
more
detail
in
the
following
document,
"
Profile
of
the
Healthcare
Industry,"
EPA/
310­
R­
05­
002,
February
2005.

Pollutants
and
Wastewaters
Generated
The
healthcare
industry
provides
a
variety
of
services
to
support
the
healthcare
needs
of
a
community
or
individuals.
Many
of
the
activities
in
healthcare
result
in
waste
outputs
and
air
or
water
pollution.
In
order
to
understand
which
activities
generate
polluting
waste
outputs,
it
is
necessary
to
look
at
various
functions
within
healthcare,
and
understand
the
products
and
supplies
used
and
the
resulting
wastes.

Healthcare
is
vastly
different
from
the
many
industries
that
have
a
defined
`
product
line,'
a
finite
number
of
input
materials
and
defined
and
consistent
`
waste
outputs.'
There
are
thousands
of
procedures,
tests,
processes,
and
activities,
which
encompass
as
many
materials.
The
hazardous
component
in
healthcare
waste
tends
to
be
made
up
of
small
amounts
of
many
different
wastes,
emanating
from
many
different
departments.
Due
to
the
decentralized
nature
of
service
delivery
in
healthcare,
there
can
be
various
departments
with
different
functions
all
generating
various
amounts
of
hazardous
waste.

In
addition
to
the
wide
variety
of
the
operations
within
this
sector
is
the
fact
that
comparatively
little
information
exists
on
the
pollutant
discharges
from
the
six
industrial
sectors
identified
by
stakeholders.
This
is
due
to
the
fact
that
most
facilities
in
this
proposed
grouping
are
indirect
dischargers
(
i.
e.,
no
discharge
data
collected
by
PCS)
and
few
facilities
in
this
category
are
TRI
reporters
(
only
federal
facilities
in
the
healthcare
industry
are
required
to
report
pollutant
release
and
other
waste
management
information
to
TRI).
3
4U.
S.
Department
of
Defense.
Handbook
Nondomestic
Wastewater
Control
and
Pretreatment
Design
Criteria.
MIL­
HDBK­
1005/
17.
Available
online
at:
http://
www.
afcesa.
af.
mil/
ces/
cesc/
wastewater/
1005_
17.
PDF.
October
30,
1998.

5Giger,
Walter,
Alfredo
C.
Alder,
Eva
M.
Golet,
Hans­
Peter
E.
Kohler,
Christa
S.
McArdell,
Eva
Molnar,
Hansrudolf
Siegrist,
and
Marc
J.­
F.
Suter.
Occurrence
and
Fate
of
Antibiotics
as
Trace
Contaminants
in
Wastewaters,
Sewage
Sludges,
and
Surface
Waters.
Chimia
57
(
2003)
485
 
491
©
Schweizerische
Chemische
Gesellschaft.
ISSN
0009
 
4293.
Available
online
at:
at
http://
www.
sach.
ch/
doc/
chimia/
sept03/
giger.
pdf.

6Endocrine
Disrupting
Chemicals
(
EDCs)
and
Pharmaceuticals
and
Personal
Care
Products
(
PPCPs)
in
Reclaimed
Water
in
Australia.
Australian
Water
Conservation
and
Reuse
Research
Program.
Available
online
at:
www.
clw.
csiro.
au/
priorities/
urban/
awcrrp/
stage1files/
AWCRRP_
1H_
Final_
27Apr2004.
pdf.
January
2004.

7U.
S.
Department
of
Defense.
Handbook
Nondomestic
Wastewater
Control
and
Pretreatment
Design
Criteria.
MIL­
HDBK­
1005/
17.
Available
online
at:
http://
www.
afcesa.
af.
mil/
ces/
cesc/
wastewater/
1005_
17.
PDF.
October
30,
1998.

Page
4
of
10
However,
currently
available
data
suggest
some
common
pollutants
in
wastewaters
from
these
six
industrial
sectors.
These
pollutants
include
metals
(
e.
g.,
silver
and
mercury),
inorganic
compounds
(
e.
g.,
barium),
organics
(
e.
g.,
phenols,
acetone,
solvents),
pharmaceutical
(
including
antibiotics,
genotoxins,
antineoplastics,
hormones,
and
other
organic
wastewater
contaminants),
biological
agents
(
e.
g.,
pathogens,
viruses),
and
other
chemical
(
e.
g.,
cleaning
agents,
solvents).
Source
of
some
of
these
pollutants
include:
(
1)
photoprocessing
(
e.
g.,
silver);
4
(
2)
improper
disposal
of
mercury
containing
equipment
or
disposal
of
dental
mercury
amalgam
(
e.
g.,
mercury);
(
3)
sewage
disposal
of
spent
or
unused
drugs
(
e.
g.,
pharmaceuticals,
endocrine
disrupting
chemicals);
5,6
and
diagnostic
testing
(
e.
g.,
barium).
Many
more
examples
are
given
in
the
Profile
of
the
Healthcare
Industry.

Photograph
and
X­
ray
processing
is
carried
out
in
dental
clinics,
hospitals,
and
photo­
processing
laboratories.
Silver­
based
photographic
materials
consist
of
solid
crystals
of
silver
chloride
or
silver
bromide
suspended
in
gelatin
and
coated
on
a
film
or
paper
support.
The
processing
of
photographic
films
and
papers
may
vary
somewhat,
but
generally
consists
of
the
following
three
steps:
(
1)
Development
of
the
image,
in
which
metallic
silver
is
formed
in
the
image
areas;
(
2)
Removal
of
some
or
all
of
the
silver,
in
which
silver
is
converted
to
crystals
of
silver
bromide
or
silver
chloride
and
then
removed
as
a
soluble
silver­
thiosulfate
complex
in
a
fix
solution;
and
(
3)
Stabilizing
the
image
by
rinsing
residual
thiosulfate
and
silver­
thiosulfate
complexes
out
of
the
emulsion
layers
with
water,
or,
in
the
case
of
washless
processing,
with
a
stabilizer
solution
instead
of
water.
7
Silver
is
the
primary
contaminant
of
concern
in
photo
processing
wastewater.
Discharges
may
also
contain
elevated
concentrations
of
ammonia,
bromide,
chromium,
cyanide,
iron,
selenium,
and
zinc.

Dentistry
services,
including
oral
surgery,
periodontics,
and
oral
healthcare,
are
provided
in
a
wide
range
of
settings
from
individual
private
practices
to
dental
surgery
centers
that
are
free
standing
or
located
within
large
teaching
and
research
hospitals.
It
is
estimated
that
dental
facilities
in
the
United
States
used
40
metric
tons
of
mercury
in
1997,
which
may
be
placed
in
8Stone,
Mark
E.,
DDS.
"
The
Effect
of
Amalgam
Separators
on
Mercury
Loadings
to
Wastewater
Treatment
Plants,"
CDA
Journal,
Vol.
32,
No.
7,
July
2004.

9Association
of
Metropolitan
Sewerage
Agencies.
Mercury
Source
Control
&
Pollution
Prevention
Program
Evaluation:
Final
Report.
March
2002
(
Amended
July
2002).

10Stone,
2004.

11U.
S.
EPA
Office
of
Water
Regulations
and
Standards.
Preliminary
Data
Summary
for
the
Hospitals
Point
Source
Category.
EPA
440/
1­
89/
060­
n.
September
1989.

12U.
S.
Department
of
Defense.
Handbook
Nondomestic
Wastewater
Control
and
Pretreatment
Design
Criteria.
MIL­
HDBK­
1005/
17.
Available
online
at:
http://
www.
afcesa.
af.
mil/
ces/
cesc/
wastewater/
1005_
17.
PDF.
October
30,
1998.

Page
5
of
10
teeth,
recycled,
discharged
into
wastewater,
or
disposed
of
as
waste.
8
About
50
percent
of
dental
amalgam
is
mercury.
A
study
by
the
Association
of
Metropolitan
Sewerage
Agencies
found
that
dental
offices
are
the
largest
source
of
mercury
to
POTWs,
contributing
more
than
35
percent
of
mercury
influent
to
the
POTWs
studied.
9
Other
studies
have
estimated
the
contributions
to
be
as
high
as
80
percent.
10
Other
wastes
from
dentistry
include
X­
ray
wastes
(
developer
chemicals,
silver
discharges,
lead
shields),
high­
level
disinfectants,
chemical
sterilizers,
nitrous
oxide,
and
biohazardous
wastes,
especially
sharps.

Two
data
sources
for
the
Hospitals
and
Clinics
industrial
sector
include
the
EPA
document
titled
Preliminary
Data
Summary
for
the
Hospital
Point
Source
Category,
EPA
440­
1­
89­
060­
n,
September
1989,11
and
the
U.
S.
Department
of
Defense
document
titled,
Handbook
Nondomestic
Wastewater
Control
and
Pretreatment
Design
Criteria,
MIL­
HDBK­
1005/
17,
October
1998.12
These
documents
state
that
hospital
wastewater
is
primarily
domestic
in
nature.
Although
some
additional
pollutants
are
added
to
the
wastewater
(
e.
g.,
solvents,
metals,
and
chemical
products),
they
are
generally
treated
at
the
point
of
generation
or
mixed
with
other
wastewaters
and
diluted
prior
to
discharge.
As
a
result,
effluent
concentrations
for
hospitals
are
very
similar
to
domestic
wastewater
without
the
need
for
a
centralized
on­
site
wastewater
treatment
system.
These
documents
did
not,
however,
address
the
concern
of
pharmaceuticals
or
endocrine
disrupting
chemicals
in
wastewater.

Available
Pollution
Prevention
and
Treatment
Options
There
are
a
variety
of
resources
on
pollution
prevention,
wastewater
treatment,
and
water
conservation
available
to
the
six
industrial
sectors
in
the
proposed
grouping.
There
are
similarities
in
the
potential
pollution
prevention,
wastewater
treatment,
and
water
conservation
across
the
six
industrial
sectors.
For
example,
some
the
options
available
to
the
proposed
Health
Services
Industry
category
revolve
around
pollution
prevention
and
treatment
at
the
unit
operation
as
opposed
to
a
centralized
on­
site
wastewater
treatment
system.
The
following
documents
a
number
of
these
examples.
Page
6
of
10

Resources
are
presented
on
the
Hospitals
for
a
Healthy
Environment
web
page
(
http://
www.
h2e­
online.
org)
for
water
conservation
fact
sheets.


The
document
titled
"
Water
Conservation
Checklist:
Hospitals/
Medical
Facilities;
Every
Drop
Counts!"
published
by
the
North
Carolina
Department
of
Environment
and
Natural
Resources
Division
of
Pollution
Prevention
and
Environmental
Assistance
contains
a
list
of
water
use
areas
throughout
a
hospital
and
ways
to
reduce
water
consumption
in
each
of
those
areas.
This
document
can
be
found
at:
http://
www.
p2pays.
org/
ref/
23/
22006.
pdf.

Based
on
this
document
water
use
in
hospitals
can
be
reduced
considerably
as
shown
in
the
following
table:

Types
of
Water
Uses
Average
Water
Use
(%
of
total)
Potential
Savings
(%
of
total)

Cooling
53
32
Domestic
24
10
Cleaning
10
9
Kitchen
5
­­

Process
4
­­

Other
4
­­

TOTALS
100%
51%

139,214
gpd
71,000
gpd
Source:
ICI
Conservation
in
the
Tri­
County
Area
of
the
Southwest
Florida
Water
Management
District
(
SWFWMD).
SWFWMD.
Available
online
at:
http://
www.
swfwmd.
state.
fl.
us/
conservation.
waterwork/
checkhospital.
htm.
Accessed
August
10,
2005.
November
1997.


The
New
Hampshire
Department
of
Environmental
Services
developed
an
environmental
fact
sheet
titled
"
Water
Efficiency
Practices
for
Health
Care
Facilities"
which
also
presents
practices
by
water
use
area.
This
document
can
be
found
at:
http://
www.
des.
state.
nh.
us/
factsheets/
ws/
ws­
26­
14.
htm.


Southwest
Florida
Water
Management
District
(
SWFWMD)
also
has
a
similar
factsheet
titled
"
Water
Conservation
@
Work:
Hospitals."
This
document
can
be
found
at:
http://
www.
swfwmd.
state.
fl.
us/
watercon/
waterwork/
checkhospital.
htm.


Healthcare
Purchasing
News
has
developed
a
Self
Study
Series
to
evaluate
environmentally
preferable
products.
One
item
in
this
series
discusses
microfiber
mops
which
use
less
water
than
conventional
cotton
mops.
The
article
discusses
the
economic,
environmental,
employee,
and
patient
benefits
of
using
microfiber
mops.
This
document
can
be
found
at:
http://
198.151.15.185/
pubs/
ShouldYouMicrofiber.
pdf.
13North
Carolina
Department
of
Environment
and
Natural
Resources.
Environmental
Best
Management
Practices
for
Small
Businesses.
October
2004.
Available
online
at:
http://
www.
smallbizenviroweb
org/
html/
pdf/
BMP_
HealthCare­
4.
pdf.

Page
7
of
10

The
University
of
Wisconsin
Cooperative
Extension
developed
a
hospital
waste
reduction
checklist
which
includes
strategies
for
reducing
wastewater
discharges.
These
strategies
include
substitution
of
less
toxic
materials,
procedures
for
moving
or
cleaning
sewer
lines,
traps,
or
sumps,
and
chemical
storage
and
disposal
options.
This
document
can
be
found
at:
http://
www.
uwex.
edu/
shwec/
Pubs/
pdf/
425­
9602.
pdf.


The
Medical
Academic
and
Scientific
Community
Organization
prepared
a
pretreatment
manual
for
use
by
hospitals
to
help
solve
a
sewer
discharge
compliance
problem.
The
manual
outlines
the
elements
of
typical
source
reduction
programs
and
a
wastewater
pretreatment
strategy.
This
document
can
be
found
at:
http://
www.
masco.
org/
mercury/
pretreatment/
index.
html.


EPA's
Small
Business
Ombudsman
developed
a
fact
sheet
for
walk­
in
urgent
care
facilities
and
smaller
hospitals.
The
fact
sheet
explains
some
of
the
best
management
practices
(
BMPs)
related
to
toxic
chemicals
or
hazardous
materials
used
as
part
of
the
diagnostic,
treatment,
and
cleaning
processes
used
in
these
smaller
facilities.
This
document
can
be
found
at:
http://
www.
smallbiz­
enviroweb.
org/
html/
pdf/
BMP_
HealthCare­
4.
pdf.
13

EPA
Regions
1
and
2
have
on­
going
programs
to
provide
information
to
help
healthcare
facilities
reduce
environmental
impacts
of
their
operations
and
improve
their
understanding
of
and
compliance
with
environmental
regulations.
The
EPA
programs
also
help
facilities
realize
the
cost
savings
and
environmental
benefits
that
can
be
attained
through
improvements
in
recycling,
energy
efficiency
and
water
conservation.
More
information
can
be
found
at:
http://
www.
epa.
gov/
region1/
healthcare/
and
http://
www.
epa.
gov/
region2/
healthcare/.

With
respect
to
controlling
mercury
discharges,
healthcare
facilities
contain
mercury
in
some
medical
equipment
(
e.
g.
pressure
gauges,
thermometers),
laboratory
reagents,
and
common
facility
items
(
e.
g.,
fluorescent
lights,
thermostats,
cleaning
supplies).
Some
hospitals
approached
the
problem
of
mercury
use
within
their
facilities
by
following
some
basic
steps,
including:


Conducting
inventories
to
identify
sources
of
mercury
within
their
facilities;


Making
recommendations
to
existing
hazardous
waste
and
safety
committees
and
the
administration
for
reducing
or
eliminating
these
sources;


Instituting
immediate
steps
for
mercury
reduction;
and,


Devising
long­
term
goals
for
the
virtual
elimination
of
mercury
from
their
facilities.

An
example
of
this
approach
was
documented
at
two
major
Detroit
hospitals
that
instituted
14Williams,
Guy.
Mercury
Pollution
Prevention
in
Healthcare.
Available
online
at:
http://
www.
newmoa.
org/
prevention/
topichub/
22/
Mercury_
Pollution_
Prevention_
in_
Healthcare_
NWF.
htm.
1997.

15U.
S.
EPA
Office
of
Water.
Second
Preliminary
Technical
Assessment
of
the
Best
Available
Technology,
Best
Demonstrated
Technology
and
Pretreatment
Technology
for
the
Printing
and
Publishing
Point
Source
Category.
Docket
OW­
2003­
0074.
December
1997.

Page
8
of
10
mercury
pollution
prevention
plans.
Wastewater
sampling
was
conducted
to
evaluated
their
performance.
Before
the
mercury
pollution
prevention
program,
mercury
measures
at
these
sites
were
in
the
range
of
0.28
ppb
to
0.96
ppb.
After
the
program
was
instituted,
these
figures
dropped
to
0.09
ppb
to
0.15
ppb.

With
respect
to
photoprocessing,
EPA's
Preliminary
Data
Summary
for
the
Photoprocessing
Industry,
199715,
identified
control
and
treatment
technologies
that
are
available
to
photoprocessing
operations
in
the
health
services
category.
These
include
source
reduction,
water
reduction,
and
silver
recovery
technologies.
The
following
table,
which
is
reproduced
from
the
1997
PDS,
provides
a
comparison
of
various
silver
recovery
and
management
systems.
According
to
the
PDS,
silver
recovery
is
almost
always
practiced
to
some
extent.
The
most
common
methods
are
metallic
replacement
and
electrolytic
recovery.
16Association
of
Metropolitan
Sewerage
Agency
(
AMSA)
and
the
Silver
Council.
Code
of
Management
Practices
for
Silver
Dischargers.
Available
online
at:
http://
www.
p2pays.
org/
ref/
02/
2003/
11­
17/
features/
digital_
2003.
html.
Accessed
January
25,
2004.

Page
9
of
10
Silver
Recovery
Technologies
Technology
Advantages
Disadvantages
Metallic
Replacement
Can
achieve
99%
recovery;
Can
be
used
for
all
silver
rich
solutions;
Low
capital
and
operating
and
maintenance
costs;
Simple
operation
Must
be
replaced
on
schedule;
Tendency
to
channel
and
cause
concentrated
silver
discharge;
efficiency
diminishes
with
use;
High
smelting
and
refining
costs;
effluent
not
suitable
for
re­
use
Electrolytic
Recovery
Can
achieve
90%
recovery;
No
additional
chemicals
released;
fix
solution
can
be
recycled;
Moderate
capital
costs
Low
refining
costs
Cannot
achieve
5
mg/
L;
Not
suitable
for
silver­
poor
solutions
Precipitation
Can
attain
0.1
mg/
L
Little
maintenance
Low
to
moderate
capital
costs
High
smelting
and
refining
costs;
complex
operation;
operation
costs
vary
from
moderate
to
high;
treated
solution
not
suitable
for
reuse
Evaporation/
Distillation
Can
reduce
wastes
up
to
90%
Virtually
zero
overflow
of
silver
High
energy
requirements;
Moderate
to
high
capital
cost
Reverse
Osmosis
Efficiently
recovers
silver
from
dilute
silver
wastestreams;
Reduces
effluent
volume
significantly;
No
water
treatment
chemicals
required;
Purified
water
is
recyclable
Capital
and
O&
M
Costs
vary
significantly;
Frequent
maintenance
of
membranes
and
pumps;
works
best
with
dilute
solutions
Virtually
all
discharging
photoprocessors
discharge
indirectly
to
POTWs.
Many
POTWs
have
stringent
silver
limits
in
their
NPDES
permits
or
need
to
reduce
metals
concentrations
in
biosolids.
POTWs
have
identified
photographic
facilities
as
a
whole
as
a
major
source
of
silver.
In
an
attempt
to
provide
photoprocessing
facilities
and
POTWs
with
a
cost­
effective
alternative
to
numeric
limits
and
monitoring,
in
1997,
AMSA,
the
Silver
Council
and
two
industry
groups
for
the
Photographic
industry
developed
a
"
Code
of
Management
Practices
for
Silver
Dischargers"
(
Silver
CMP)
16.
The
Silver
CMP
provides
recommendations
on
control
technologies
and
management
practices
for
controlling
silver
discharges
to
POTWs,
and
encourages
pollution
prevention
technologies
such
as
water
conservation.
The
recommended
practices
are
defined
by
a
minimum
recovery
of
silver
from
silver­
rich
processing
solutions
(
e.
g.
90%,
95%,
and
99%).
The
minimum
recovery
and
recommended
practices
vary
with
the
size
of
the
photoprocessor,
defined
17U.
S.
EPA.
"
Environmental
Technology
Verification
Report:
Removal
of
Mercury
from
Dental
Office
Wastewater".
Available
online
at:
http://
www.
epa.
gov/
etv/
pdfs/
vrvs/
09_
vr_
drna.
pdf.
NSF
02/
01/
EPAWQPC­
SWP.
September
2002.

18Anastas,
P.
T.;
Warner,
J.
C.
Green
Chemistry:
Theory
and
Practice,
Oxford
University
Press:
New
York,
1998,
Cited
at:
www.
chemistry.
org/
portal/
a/
c/
s/
1/
acsdisplay.
html?
DOC=
greenchemistryinstitute\
gc_
principles.
html.

Page
10
of
10
by
flow
volume
of
silver­
rich
solution
and
wash
water.
Four
POTWs
documented
loadings
reductions
of
20%
to
52%
over
historical
baselines
after
CMP
implementation.

Technology
exists
to
remove
dental
mercury
amalgam
discharges.
EPA's
Environmental
Technology
Verification
program
demonstrated
mercury
removals
for
an
amalgam
separator
at
99.6%­
99.9%.
17
Finally,
common
techniques
available
for
all
six
industrial
sectors
for
reducing
or
eliminating
pollutant
discharges
from
laboratory
wastewaters
include
the
following:
18

Substitute
chemicals
with
less
toxic
alternatives.


Use
the
minimum
amount
of
chemical
required.


Label
all
chemical
containers
properly.


Store
glassware
and
breakable
containers
on
textured
rubber
mats.


Order
chemicals
in
plastic­
coated
bottles.


Transport
solvent
bottles
in
protective
holders.


Keep
doors
of
chemical
storage
cabinet
latched.


Equip
chemical
storage
shelves
with
barriers
one­
fifth
the
height
of
the
tallest
container.


Keep
all
counter­
top
chemicals
in
a
tray
or
within
bermed
areas.


Never
store
chemical
bottles
and
containers
in
sinks.


Surround
sinks
and
counter
tops
with
a
protective
lip.


Plug
all
floor
drains.


Protect
safety
shower
drain
from
chemical
spills
with
temporary
plugs
or
sumps.


Maintain
adequate
and
readily
available
supply
of
spill
cleanup
materials.


Check
chemical
disposal
guidelines
and
POTW
acceptance
criteria
prior
to
discharging
to
a
drain.


Keep
work
areas
clean
and
well
organized
to
help
prevent
accidents.


Use
drip
pans
and
splash
guards
where
spills
frequently
occur.
Attachment
1:
Independent
and
Stand
Alone
Medical
and
Dental
Laboratories
Memorandum
Page
1
of
4
Memorandum
From:
Carey
Johnston
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
(
www.
epa.
gov/
edockets/)

Date:
August
11,
2005
Re:
Independent
and
Stand
Alone
Medical
and
Dental
Laboratories
Activities
at
medical
and
dental
laboratories
differ
from
those
of
other
types
of
standalone
laboratories.
These
operations
are
only
covered
by
40
CFR
Part
460,
Hospitals
Point
Source
Category,
if
they
are
located
at
a
directly­
discharging
hospital
with
greater
than
1,000
beds.

Industry
Profile
Medical
and
dental
laboratories
include
SIC
codes
8071
and
8072.
The
1987
SIC
Code
Manual
defines
these
SIC
codes
as
follows:


8071:
Establishments
primarily
engaged
in
providing
professional
analytic
or
diagnostic
services
to
the
medical
profession
or
to
the
patient
as
prescribed
by
a
physician.
Laboratories
engaged
in
the
manufacture
of
medical
or
pharmaceutical
products
are
classified
in
Manufacturing.
Laboratories
engaged
in
commercial
medical
research
are
classified
in
Industry
8731,
and
those
engaged
in
noncommercial
medical
research
are
classified
in
Industry
8733.


8072:
Establishments
primarily
engaged
in
making
dentures,
artificial
teeth,
and
orthodontic
appliances
to
order
for
the
dental
profession.
The
manufacture
of
teeth
other
than
to
order
is
classified
in
Manufacturing.
Establishments
providing
dental
x­
ray
laboratory
services
are
classified
in
Industry
8071.

SIC
Code
8071
includes
medical
laboratories
that
test
blood
and
other
tissue
samples
for
pathogens,
viruses,
and
chemicals
such
as
HIV,
blood
sugar,
and
drugs.
Two
prominent
laboratories
include
Quest
Diagnostics
and
American
Medical
Laboratories.
SIC
Code
8072
includes
labs
that
manufacture
crowns,
bridges,
dentures,
veneers,
orthodontic
appliances
and
other
dental
prosthetics.

Table
1­
1
shows
Census
data
for
medical
and
dental
laboratories.
No
stand­
alone
medical
Page
2
of
4
or
dental
laboratories
reported
to
TRI
in
2000.
Table
1­
2
shows
that
only
three
medical
laboratories
have
data
available
in
the
2000
PCS,
and
all
three
are
minor
dischargers.
Almost
all
facilities
discharge
indirectly:
only
three
of
the
approximately
18,000
stand­
alone
medical
and
dental
laboratories
discharge
directly.
No
dental
laboratories
have
data
available
in
2000
PCS.

Table
1­
1.
Census
Data
SIC
Code
NAICS
Code
Number
of
Facilities
in
1997
Number
of
Facilities
in
2002
8071:
Medical
laboratories
621511:
Medical
laboratories
4,655
5,513
621512:
Diagnostic
imaging
centers
4,421
5,577
8072:
Dental
laboratories
339116:
Dental
laboratories
7,609
7,089
Table
1­
2.
TRI
Facility
Counts
SIC
Code
Number
of
Facilities
Reporting
to
2000
TRI
Number
of
Facilities
Reporting
to
PCS
in
2000
(
Minors)
Direct­
Only
Indirect­
Only
Both
No
Discharge
Reported
8071
0
0
0
0
3
8072
0
0
0
0
0
Wastewater
Characteristics
Wastewater
Quantity
Table
1­
3
presents
the
information
available
for
the
three
medical
laboratories
in
the
2000
PCS
database.

Table
1­
3.
Wastewater
Flows
in
PCS
SIC
NPID
Flow
(
MGY)

8071
ME0001635
5.22
8071
MT0028487
69.0
8071*
WV0105112*
28.8*

*
This
NPID
belongs
to
a
U.
S.
Fish
and
Wildlife
Service
office
in
West
Virginia.
The
SIC
code
designation
is
most
likely
an
error.

At
this
time,
EPA
did
not
locate
other
data
sources
for
wastewater
quantity
for
these
types
of
laboratories.
1U.
S.
EPA
Office
of
Enforcement
and
Compliance
Assurance.
Profile
of
the
Healthcare
Industry.
February
2005.
Available
online
at:
http://
www.
epa.
gov/
Compliance/
resources/
publications/
assistance/
sectors/
notebooks/
health.
pdf.

2U.
S.
Department
of
Defense.
1998.
Handbook
Nondomestic
Wastewater
Control
and
Pretreatment
Design
Criteria.
MIL­
HDBK­
1005/
17.
Available
online
at:
http://
www.
afcesa.
af.
mil/
ces/
cesc/
wastewater/
1005_
17.
PDF.
Accessed
October
30,
1998.

Page
3
of
4
Raw
and
Treated
Wastewater
Quality
Table
1­
4
lists
the
facilities
in
the
2000
PCS
database.
The
U.
S.
Fish
and
Wildlife
Service
office
in
West
Virginia
SIC
code
designation
is
most
likely
an
error.

Table
1­
4.
List
of
Facilities
in
PCSLoads2000
(
All
Minors)

SIC
Name
Major/
Minor
City
State
TWPE
8071
Mount
Desert
Island
Biological
Minor
Bar
Harbor
Maine
21.2
8071
Rocky
Mountain
Laboratories
Minor
Hamilton
Montana
1.86
8071
U.
S.
Fish
&
Wildlife
Service
Minor
Shepherdstown
West
Virginia
0
Casting
molds
of
dental
or
medical
prosthetics
generates
wastewater
with
plaster
solids,
and
therefore
greater
TSS,
in
wastewater.
EPA
does
not
believe
that
amalgam
or
any
other
mercury­
containing
materials
are
used
in
dental
laboratory
processes
(
Galsky).
OECA's
2004
Healthcare
Sector
Notebook1
notes
that
molding
casts,
prosthetics,
and
other
medical
lab
items
may
use
Cerrobend
®
,
a
ductile,
formable
metal
that
includes
lead.

Photograph
and
X­
ray
processing
is
carried
out
in
dental
clinics,
hospitals,
and
photo­
processing
laboratories.
Silver­
based
photographic
materials
consist
of
solid
crystals
of
silver
chloride
or
silver
bromide
suspended
in
gelatin
and
coated
on
a
film
or
paper
support.
The
processing
of
photographic
films
and
papers
may
vary
somewhat,
but
generally
consists
of
the
following
three
steps:
(
1)
Development
of
the
image,
in
which
metallic
silver
is
formed
in
the
image
areas;
(
2)
Removal
of
some
or
all
of
the
silver,
in
which
silver
is
converted
to
crystals
of
silver
bromide
or
silver
chloride
and
then
removed
as
a
soluble
silver­
thiosulfate
complex
in
a
fix
solution;
and
(
3)
Stabilizing
the
image
by
rinsing
residual
thiosulfate
and
silver­
thiosulfate
complexes
out
of
the
emulsion
layers
with
water,
or,
in
the
case
of
washless
processing,
with
a
stabilizer
solution
instead
of
water.
2
Silver
is
the
primary
contaminant
of
concern
in
photo
processing
wastewater.
Discharges
may
also
contain
elevated
concentrations
of
ammonia,
bromide,
chromium,
cyanide,
iron,
selenium,
and
zinc.
At
this
time,
EPA
did
not
locate
any
other
data
sources
on
raw
or
treated
wastewater
quality.

On­
Site
Wastewater
Treatment/
Pretreatment
From
OECA's
2004
Healthcare
Sector
Notebook,
in
rooms
where
casts
are
fitted
and/
or
Page
4
of
4
plaster
molds
are
made,
plaster
recovery
systems
may
be
used.
A
phone
conversation
with
a
dental
laboratory
confirmed
the
use
of
plaster
recovery
systems
(
Galsky).
Silver
recovery
is
one
method
of
pollution
prevention
for
photoprocessing
wastewaters.
More
details
on
this
and
other
technologies
are
documented
in
the
Photoprocessing
profile.
Common
techniques
at
reducing
or
eliminating
pollutant
discharges
from
laboratory
wastewaters
are
also
detailed
in
the
Independent
and
Standalone
Laboratories
profile.

References
1.
National
Association
of
Dental
Laboratories
web
page.
Available
at
http://
www.
nadl.
org/.
As
accessed
on
October
22,
2004.

2.
Phone
conversation
from
Ellie
Codding,
EPA,
to
Mr.
Larry
Galsky,
CDT,
of
Galsky
Dental
Laboratories.
Dental
Laboratory
Processing.
November
2,
2004.

3.
U.
S.
EPA
Office
of
Enforcement
and
Compliance.
Profile
of
the
Healthcare
Industry.
EPA/
310­
R­
04­
001.
February
2005.
Available
online
at:
http://
www.
epa.
gov/
Compliance/
resources/
publications/
assistance/
sectors/
notebooks/
healt
h.
pdf.

4.
Valuations
Resources.
com
web
site
on
Medical
Laboratories.
Available
online
at
http://
www.
valuationresources.
com/
Reports/
SIC8071MedicalLaboratories.
htm.
Accessed
October
22,
2004.
Attachment
2:
Offices
and
Clinics
of
Dentists
Memorandum
Page
1
of
2
Memorandum
From:
Carey
Johnston
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
(
www.
epa.
gov/
edockets/)

Date:
August
11,
2005
Re:
Offices
and
Clinics
of
Dentists
Industry
Profile
Dental
facilities
include
facilities
in
SIC
Code
8021,
Offices
and
Clinics
of
Dentists.
The
1987
SIC
Code
Manual
defines
SIC
Code
8021
as
follows:


This
industry
comprises
establishments
of
health
practitioners
having
the
degree
of
D.
M.
D.
(
Doctor
of
dental
medicine),
D.
D.
S.
(
Doctor
of
dental
surgery),
or
D.
D.
Sc.
(
Doctor
of
dental
science)
primarily
engaged
in
the
independent
practice
of
general
or
specialized
dentistry
or
dental
surgery.
These
practitioners
operate
private
or
group
practices
in
their
own
offices
(
e.
g.,
centers,
clinics)
or
in
the
facilities
of
others,
such
as
hospitals
or
HMO
medical
centers.
They
can
provide
either
comprehensive
preventive,
cosmetic,
or
emergency
care,
or
specialize
in
a
single
field
of
dentistry.

Table
1­
1.
Census
Data
SIC
Code
NAICS
Code
Number
of
Facilities
in
1997
8021
:
Offices
and
Clinics
of
Dentists
6212:
Offices
of
Dentists
114,178
Table
1­
2
shows
the
facility
counts
available
from
TRI
and
PCS.

Table
1­
2.
Facility
Counts
SIC
Code
Number
of
Facilities
Reporting
to
2000
TRI
Number
of
Facilities
Reporting
to
PCS
(
Minors)
Direct­
Only
Indirect­
Only
Both
No
Water
Discharge
Reported
8021
0
0
0
0
2
Page
2
of
2
Wastewater
Characteristics
Wastewater
Quantity
Table
1­
3
summarizes
the
wastewater
flow
data
available
in
the
2000
PCS
database.
No
facilities
reported
to
the
2000
TRI.

Table
1­
3.
Wastewater
Flow
Data
from
PCSLoads2000
SIC
NPDES
ID
Flow,
MGY
8021
FL0033154
0.120
8021
MD0053155
1.43
Raw
and
Treated
Wastewater
Quality
Almost
all
dental
facilities
discharge
to
POTWs.
Of
the
114,178
facilities
in
the
1997
Census,
only
2
appear
in
the
PCS
database,
both
of
which
are
minor
discharges.
Table
1­
4
lists
the
facilities
noted
as
SIC
Code
8021
in
the
2000
PCS
database.
By
name,
both
appear
to
be
treatment
plants,
not
dental
facilities.

Table
1­
4.
List
of
Facilities
in
PCSLoads2000
SIC
Name
City
NPID
Major/
Minor
8021
Oak
Lane
Building
Sewage
Treatment
Plant
Jacksonville
FL0033154
Minor
8021
Thunderbird
Motel
WWTP
Newburg
MD0053155
Minor
On­
Site
Wastewater
Treatment/
Pretreatment
Dental
facility
pretreatment
usually
includes:


Silver
recovery
for
X­
ray
wastes
and

Simple
drain
traps
in
patient
chair­
side
sinks
to
recover
solid
particles
of
amalgam
and
other
tissue.
Attachment
3:
Hospitals
and
Clinics
Memorandum
1U.
S.
EPA
Office
of
Water
Regulations
and
Standards.
Preliminary
Data
Summary
for
the
Hospitals
Point
Source
Category.
EPA
440/
1­
89/
060­
n.
September
1989.

2U.
S.
EPA
Office
of
Enforcement
and
Compliance
Assurance.
Profile
of
the
Healthcare
Industry.
EPA/
310­
R­
04­
001.
Available
online
at:
http://
www.
epa.
gov/
Compliance/
resources/
publications/
assistance/
sectors/
notebooks/
health.
html.
February
2005.

Page
1
of
16
Memorandum
From:
Carey
Johnston
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
(
www.
epa.
gov/
edockets/)

Date:
August
11,
2005
Re:
Hospitals
and
Clinics
Introduction
40
CFR
Part
460,
promulgated
in
1976,
applies
to
effluent
discharges
to
surface
water
from
hospitals
with
greater
than
1,000
occupied
beds.
In
1989,
EPA
published
a
Preliminary
Data
Summary
(
PDS)
for
the
Hospitals
Point
Source
Category1.
EPA's
Office
of
Enforcement
and
Compliance
Assistance
(
OECA)
developed
a
Healthcare
Sector
Notebook
in
February
20052.

Industry
Profile
Hospitals
include
facilities
in
SIC
codes
8062,
General
Medical
and
Surgical
Hospitals,
8069,
Specialty
Hospitals,
Except
Psychiatric
(
children's
hospitals),
and
8063,
Psychiatric
Hospitals.
The
1987
SIC
Code
Manual
defines
these
SIC
codes
as
follows:


8062
General
Medical
and
Surgical
Hospitals
­
Establishments
primarily
engaged
in
providing
general
medical
and
surgical
services
and
other
hospital
services.
Specialty
hospitals
are
classified
in
Industries
8063
and
8069.
This
SIC
code
includes
only
General
Medical
and
Surgical
Hospitals

8063
Psychiatric
Hospitals
­
Establishments
primarily
engaged
in
providing
diagnostic
medical
services
and
inpatient
treatment
for
the
mentally
ill.
Establishments,
known
as
hospitals,
primarily
engaged
in
providing
health
care
for
the
mentally
retarded
are
Page
2
of
16
classified
in
Industry
8051.
This
SIC
code
includes:
Mental
hospitals,
except
for
the
mentally
retarded
and
Psychiatric
hospitals.


8069
Specialty
Hospitals,
Except
Psychiatric
­
Establishments
primarily
engaged
in
providing
diagnostic
services,
treatment,
and
other
hospital
services
for
specialized
categories
of
patients,
except
mental.
Psychiatric
hospitals
are
classified
in
Industry
8063.
This
SIC
code
includes:
Alcoholism
rehabilitation
hospitals;
Cancer
hospitals;
Children's
hospitals;
Chronic
disease
hospitals;
Drug
addiction
rehabilitation
hospitals;
Eye,
ear,
nose,
and
throat
hospitals:
in­
patient;
Hospitals,
specialty:
except
psychiatric;
Maternity
hospitals;
Orthopedic
hospitals;
Rehabilitation
hospitals:
drug
addiction
and
alcoholism;
and
Tuberculosis
and
other
respiratory
illness
hospitals.

Table
1­
1.
Census
Data
SIC
Code
NAICS
Code
Number
of
Facilities
in
1997
Number
of
Facilities
in
2002
8062:
General
Medical
and
Surgical
Hospitals
622110:
General
Medical
and
Surgical
Hospitals
5,487
5,404
8063:
Psychiatric
Hospitals
622210:
Psychiatric
and
Substance
Abuse
Hospitals
801
605
8069:
Other
Specialty
622310:
Specialty
(
Except
Psychiatric
and
Substance
Abuse)
Hospitals
397
316
Total
6,685
6,325
EPA's
1989
PDS
states
that,
using
1985
data,
97
percent
of
the
hospitals
are
indirect
dischargers.
This
was
an
increase
from
1975,
when
92
percent
of
hospitals
were
indirect
dischargers.

Table
1­
2
shows
the
facility
counts
available
from
the
2000
TRI
and
PCS
databases.
Using
2002
U.
S.
Census
and
2000
PCS
data,
34
of
6,325
hospitals
are
direct
dischargers,
and
99.5
percent
of
hospitals
are
indirect
dischargers.
Note:
hospitals
are
exempt
from
TRI
reporting
unless
they
are
federal
facilities.

Table
1­
2.
2000
TRI
and
PCS
Facility
Counts
SIC
Code
Number
of
Facilities
Reporting
to
2000
TRI
Number
of
Facilities
Reporting
to
PCS
2000
Direct
Indirect
Both
No
Discharge
Reported
Direct
(
Major/
Minor)

8062
0
0
0
1
2
20
8063
0
0
1
0
1
7
3Centers
for
Medicare
and
Medicaid
Services
Web
Page.
Available
online
at:
http://
www.
cms.
hhs.
gov/
charts/
healthcaresystem/
chapter2.
asp.
Accessed
October
22,
2004.

4Southwest
Florida
Water
Management
District.
November
1997.
Water
Conservation
Facts
@
Work:
Hospitals.
Available
online
at:
http://
www.
swfmd.
state.
fl.
us/
watercon/
waterwork/
checkhospital.
htm.
Accessed
August
10,
2005.

Page
3
of
16
8069
0
0
0
0
0
4
Total
0
0
1
1
3
31
Wastewater
Characteristics
Wastewater
Quantity
EPA
located
wastewater
volume
data
from
the
1989
PDS,
textbooks,
TRI,
and
PCS.
Table
1­
3
summarizes
the
wastewater
flow
data
from
the
PDS
and
textbooks.

Table
1­
3.
Typical
Wastewater
Flow
Rates
from
Hospitals
Type
of
Establishment
Wastewater
Flow
Range
(
gal/
day
per
unit)
Unit
Textbook
Source
Hospital
242
Bed
1989
PDS*

Hospital,
medical
125
­
240
Bed
Metcalf
&
Eddy
Hospital,
mental
75
­
140
Bed
Hospital
150
­
250+
Person
Standard
Handbook
of
Environmental
Engineering
*
The
1989
PDS
cites
1976
data
from
the
American
Hospital
Association
(
AHA),
that
approximately
242
gallons
of
wastewater
are
generated
per
bed
per
day
at
hospitals.
The
PDS
also
states
that,
"
based
on
the
latest
information,
this
figure
has
not
changed."

From
the
Center
for
Medicare
and
Medicaid
Services
(
CMS)
web
site3,
the
number
of
hospital
beds
in
2000
was
983,628.
Using
the
data
in
Table
3,
hospitals
discharge
an
estimated
120
to
240
MGD
of
wastewater,
or
43,800
to
87,600
MGY.

Based
on
a
survey
of
26
Florida
hospitals,
conducted
by
the
Southwest
Florida
Water
Management
District
(
SWFWMD)
4,
hospitals
use
an
average
of
139,214
gallons
per
day
(
GPD)
of
water.
Table
1­
4
shows
the
types
of
water
use.

Table
1­
4.
Types
of
Hospital
Water
Use
Types
of
Water
Uses
Average
Water
Use
(%
of
total)
Page
4
of
16
Cooling
53
Domestic
24
Cleaning
10
Kitchen
5
Process
4
Other
4
TOTALS
100%

139,214
gpd
Source:
Southwest
Florida
Water
Management
District.
November
1997.
Water
Conservation
Facts
@
Work:
Hospitals.

Table
1­
5
summarizes
the
2000
PCS
data
available
for
flow.

Table
1­
5.
2000
PCS
Data
Available
for
Flow
SIC
Code
Flow,
MGY
8062
Max
3,150
Min
0.27
Median
18.7
8063
Max
12,300
Min
0.34
Median
24.8
8069
Max
15.8
Min
2.77
Median
12.9
Raw
Wastewater
Quality
Hospital
wastewater
is
expected
to
contain
normal
sanitary
wastewater
contaminants
plus
cleaning
agents,
germicides,
acids,
and
chemicals
associated
with
laboratory
and
health
care
services.
The
various
medical
industry
wastewaters
include
wastewaters
from
clinical
laboratories,
research
laboratories,
medical
waste
incinerators
equipped
with
fume
scrubbers,
vehicle
maintenance
facilities,
and
hospital
laundries.
Silver
may
be
present
in
the
combined
hospital
5U.
S.
Department
of
Defense.
1998.
Handbook
Nondomestic
Wastewater
Control
and
Pretreatment
Design
Criteria.
MIL­
HDBK­
1005/
17.
Available
online
at:
http://
www.
afcesa.
af.
mil/
ces/
cesc/
wastewater/
1005_
17.
PDF.
Accessed
October
30,
1998.

6Barnes,
Kimberlee
K.,
Dana
W.
Kolpin,
Michael
T.
Meyer,
E.
Michael
Thurman,
Edward
T.
Furlong,
Steven
D.
Zaugg,
and
Larry
B.
Barber.
Water­
Quality
Data
for
Pharmaceuticals,
Hormones,
and
Other
Organic
Wastewater
Contaminants
in
U.
S.
Streams.
U.
S.
Geological
Survey.
1999­
2000.
Available
online
at:
http://
toxics.
usgs.
gov/
pubs/
OFR­
02­
94/.

7Giger,
Walter,
Alfredo
C.
Alder,
Eva
M.
Golet,
Hans­
Peter
E.
Kohler,
Christa
S.
McArdell,
Eva
Molnar,
Hansrudolf
Siegrist,
and
Marc
J.­
F.
Suter.
Occurrence
and
Fate
of
Antibiotics
as
Trace
Contaminants
in
Wastewaters,
Sewage
Sludges,
and
Surface
Waters.
Chimia
57
(
2003)
485
 
491
©
Schweizerische
Chemische
Gesellschaft.
ISSN
0009
 
4293.
Accessible
at
http://
www.
sach.
ch/
doc/
chimia/
sept03/
giger.
pdf.

8Australian
Water
Conservation
and
Reuse
Research
Program.
Endocrine
Disrupting
Chemicals
(
EDCs)
and
Pharmaceuticals
and
Personal
Care
Products
(
PPCPs)
in
Reclaimed
Water
in
Australia.
Available
online
at:
http://
www.
clw.
csiro.
au/
priorities/
urban/
awcrrp/
stage1files/
AWCRRP_
1H_
Final_
27Apr2004.
pdf.
January
2004.

Page
5
of
16
wastewater
as
a
result
of
X­
ray
processing,
5
This
unit
operation
is
described
in
more
detail
in
the
Independent
and
Stand­
alone
Medical
and
Dental
Laboratories
and
Photoprocessing
profiles.
Wastewater
produced
by
hospitals
and
by
hospital­
related
industries
originates
from
many
sources.

The
1989
PDS
states
that
EPA
sampled
four
hospitals
to
better
characterize
the
contents
of
hospital
wastewater,
and
determine
if
hospitals
should
be
selected
for
further
study.
Criteria
for
selection
for
further
study
included
the
presence
of
unexpected
chemicals
or
chemical
concentrations
above
wastewater
treatability
levels.
Analysis
included
over
400
toxic
and
hazardous
pollutants.
Based
on
sampling
results,
neither
criteria
were
met,
although
five
pollutants
were
detected
at
levels
higher
than
expected
for
non­
industrial
wastewater.
These
pollutants
were
silver,
phenols,
barium,
acetone,
and
mercury.

Since
the
1989
PDS,
many
studies
world
wide
raise
the
question
of
the
fate
of
pharmaceuticals,
including
antibiotics,
genotoxins,
and
antineoplastics,
in
hospital
and
domestic
wastewater.
In
2003,
the
USGS6
published
a
study
of
139
streams,
which
they
tested
for
pharmaceuticals,
hormones,
and
other
organic
wastewater
contaminants
(
OWCs).
At
least
one
OWC
was
detected
in
80%
of
the
streams
sampled,
with
82
of
the
95
analyzed
OWCs
determined
in
this
study
detected
in
at
least
one
sample.
The
antibiotics
erythromycin
and
lincomycin
were
two
of
the
most
commonly
detected
OWCs.
In
addition
to
antibiotics
there
may
be
other
pharmaceuticals
and
personal
care
products
in
the
untreated
effluent
including
potential
endocrine
disrupting
chemicals.
7,8
Although
antibiotics
are
excreted
in
urine
from
households,
hospital
toilet
waste
has
a
greater
likelihood
of
containing
antibiotics.

Hospital
may
operate
laundry
facilities
which
typically
process
linens,
gowns
and
lab
coats
that
will
contribute
a
certain
amount
of
organic
material,
fats,
oils
and
grease
(
FOG)
and
an
alternating
range
of
pH
(
alkaline
detergent
followed
by
an
acidic
sanitizer)
to
the
wastestream.
9Medical
Academic
and
Scientific
Community
Organization,
Inc.
End­
of­
pipe
Subcommittee,
Technology
Identification
Subgroup
Report.
Available
online
at:
http://
www.
masco.
org/
mercury/
techid/
index.
html,
December
1997.

Page
6
of
16
Depending
upon
the
processes
employed,
the
hospital
laundry
wastestream
can
have
elevated
temperatures
and
pH
extremes
and
can
contain
starch,
particulate
(
including
lint),
proteins
(
blood
products),
detergents,
and
oxidizers
(
bleach
or
other
disinfectant).
BOD
and
COD
concentrations
from
laundry
wastewater
are
usually
in
the
normal
range
for
domestic
sewage.
Some
laundry
chemicals
(
sodium
hydroxide
and
bleach)
are
known
to
often
have
significant
levels
of
mercury
contamination.
In
addition,
just
one
broken
mercury
thermometer
can
cause
temporary
high
levels
of
mercury
in
the
laundry
wastewater.
Hospital
laundry
wastewater
flows
can
vary
from
a
few
hundred
gallons
per
day
to
many
thousands
of
gallons
per
day.
9
Treated
Wastewater
Quality
Tables
1­
6
and
1­
7
show
flow
data
available
from
the
2000
TRI
and
PCS.
Tables
1­
8,
1­
9,
and
1­
10
show
the
top
pollutants
reported
to
the
2000
TRI
and
PCS,
based
on
TWPE
and
total
pounds
reported.

Table
1­
6.
Discharges
Reported
to
TRIReleases2000
for
One
Facility*

SIC
Code
Discharge
Status
Pounds
to
Stream
TWPE
8063
D
750
365
8063
I
736
358
Note:
Only
one
facility
reported
water
discharges
to
the
2000
TRI.

Table
1­
7.
Discharges
Reported
to
PCSLoads2000
SIC
Pounds
to
Stream
TWPE
8062
20,458
4.51
8063
4,891
0.36
Table
1­
8.
Top
Pollutant
from
TRIReleases2000
Data*

SIC
Code
Chemical
TWPE
%
of
Total
SIC
TWPE
Pounds
%
of
Total
SIC
Pounds
8063
Chlorine
724
1
1,486
1
*
Note:
Only
one
facility
reported
water
discharges
to
the
2000
TRI.
Page
7
of
16
Table
1­
9.
Top
Pollutants
from
PCSLoads2000
by
TWPE
SIC
Parameter
TWPE
%
of
Total
SIC
TWPE
8062
Chlorine,
Total
Residual
4.42
98%

Total
for
SIC
Code
8062
4.51
8063
Nitrogen,
Ammonia
Total
(
As
n)
0.14
38%

8063
Copper,
Total
(
As
Cu)
0.13
37%

8063
Zinc,
Total
(
As
Zn)
0.053
15%

8063
Nitrogen,
Nitrate
Total
(
As
n)
0.034
10%

Total
for
SIC
Code
8063
0.36
Table
1­
10.
Top
Pollutants
from
PCSLoads2000
by
Pounds
SIC
Parameter
Pounds
%
of
Total
SIC
Pounds
8062
Solids,
Total
Dissolved­
180
Deg.
c
5,730.92
28%

8062
Oxygen
Demand,
Chem.
(
Low
Level)
(
COD)
4,960.54
24%

8062
Solids,
Total
Dissolved
4,824.45
24%

8062
Solids,
Total
Suspended
3,081.54
15%

Total
for
SIC
Code
8062
20,458.27
8063
Solids,
Total
Suspended
1,083.09
22%

8063
Bod,
5­
day
(
20
Deg.
C)
639.36
13%

8063
Nitrogen,
Nitrate
Total
(
As
N)
544.63
11%

8063
Oil
&
Grease
Freon
Extr­
Grav
Meth
114.85
2%

8063
Phosphorus,
Total
(
As
P)
94.92
2%

8063
Nitrogen,
Ammonia
Total
(
As
N)
74.24
2%

Total
for
SIC
Code
8063
4,891.19
Tables
1­
11
and
1­
12
list
the
facilities
reporting
to
the
2000
TRI
and
PCS.

Table
1­
11.
List
of
Facilities
in
TRIReleases2000
SIC
Facility
Name
City
State
Discharge
Type
TWPE
8062
U.
S.
VA
Togus
VA
Med/
Regional
Office
Center
Togus
ME
No
Disch
8063
VA
Hudson
Valley
Health
Care
System
Castle
Point
Castle
Point
NY
??

8063
VA
Hudson
Valley
Health
Care
System
Montrose
Camp
Montrose
NY
Direct
365
Page
8
of
16
8063
VA
Hudson
Valley
Health
Care
System
Montrose
Camp
Montrose
NY
Indirect
358
Table
­
12.
List
of
Facilities
in
PCSLoads2000
SIC
Facility
Name
City
TWPE
NPID
Major/
Minor
8062
Castaner
General
Hospital
Lares
4.4
PR0025283
Major
8062
U.
s.
m.
c.
Development
&
Education
Quantico
0.069
VA0002151
Major
8063
Marlboro
Psychiatric
Hosp
Stp
Marlboro
0.36
NJ0022586
Major
8062
Caritas
Southwood
Hospital
Norfolk
0.364039
MA0102288
Minor
8062
Clara
Maass
Medical
Center
Belleville
6.72E­
02
NJ0032280
Minor
8062
Diagnostic
&
Treatment
Center
Naguabo
194.5359
PR0023183
Minor
8062
Franciscan
Medical
Center
Dayton
OH0127019
Minor
8062
Gibson
General
Hospital
Princeton
IN0056626
Minor
8062
Harbor
Hospital
Center
Baltimore
0
MD0064475
Minor
8062
Huron
Memorial
Hosp
Bad
Axe
7.916473
MI0037508
Minor
8062
Jefferson
Co
Medical
Ctr
Plt
Louisville
1.912969
KY0053783
Minor
8062
Miami
Valley
Hospital
Dayton
OH0115762
Minor
8062
Montana
Behavioral
Health
Inc.
Butte
24.86648
MT0021431
Minor
8062
Morton
Plant
Health
System
Clearwater
5.862706
FL0168831
Minor
8062
Owensboro
Mercy
Health
System
Owensboro
KY0100498
Minor
8062
Quality
Health
Service
of
Pr
Ponce
327.0937
PR0025895
Minor
8062
Red
Bird
Mission
Hospital
Queendale
0.176617
KY0026000
Minor
8062
Ri
Mhrh
Facilities
&
Maint.
Cranston
8.68E­
02
RI0020176
Minor
8062
Rockford
Memorial
Hospital
Rockford
0.572972
IL0073580
Minor
8062
Union
Co
Methodist
Hospital
Morganfield
2.90E­
02
KY0022993
Minor
8062
Usvah
­
Ft
Lyon
(
E)
Fort
Lyon
70.80236
CO0020249
Minor
8062
Veterans
Administration
Medica
Togus
10.07631
ME0000736
Minor
8062
Zambarano
Dr.
U.
E.
Mem.
Hosp.
Wallum
Lake
209.9387
RI0100129
Minor
8063
Brook
Lane
Psychiatric
WWTP
Hagerstown
MD0053198
Minor
8063
Carrier
Foundation
STP
Belle
Mead
0.174901
NJ0023663
Minor
8063
Choate
Mental
Health&
dev
Ctr
Anna
0.205647
IL0070033
Minor
8063
Greystone
Park
Psych
Hospital
Greystone
Park
0.271731
NJ0026689
Minor
8063
Hastings
Regional
Center
Hastings
NE0125016
Minor
8063
Logansport
State
Hospital
Logansport
0
IN0038521
Minor
8063
Muscatatuck
State
Dev.
Center
Butlerville
0.111432
IN0038539
Minor
8069
McDowell
Appalachian
Reg
Hosp
McDowell
6.10E­
02
KY0085791
Minor
SIC
Facility
Name
City
TWPE
NPID
Major/
Minor
10U.
S.
EPA
Office
of
Enforcement
and
Compliance
Assurance.
Profile
of
the
Healthcare
Industry.
EPA/
310­
R­
04­
001.
September
2004.
Available
online
at:
http://
www.
epa.
gov/
Compliance/
resources/
publications/
assistance/
sectors/
notebooks/
health.
html.

Page
9
of
16
8069
No
Princeton
Developmental
Ctr
Skillman
2.108294
NJ0022390
Minor
8069
Nursing
&
Personal
Care
Home
Bruce
2.150472
MS0032051
Minor
8069
Woodward
Resource
Center
Woodward
IA0063916
Minor
On­
Site
Wastewater
Treatment/
Pretreatment
EPA's
1989
PDS
states
that
hospital
wastewater
is
primarily
domestic
in
nature.
Although
some
additional
pollutants
are
added
to
the
wastewater
(
e.
g.,
solvents,
metals,
and
chemical
products),
they
are
generally
treated
at
the
point
of
generation
or
mixed
with
other
wastewaters
and
diluted
prior
to
discharge.
As
a
result,
effluent
concentrations
for
hospitals
are
very
similar
to
domestic
wastewater
without
the
need
for
a
centralized
on­
site
wastewater
treatment
system.
The
PDS
did
not
address
the
concern
of
pharmaceuticals
in
wastewater,
which
is
discussed
in
the
Raw
Wastewater
Section
of
this
report.

Pretreatment
at
hospitals
may
consist
of
the
following
technologies:


Solvent
recycling
and
reclamation
(
through
distillation)
for
xylene
and
ethanol;


Dilution
or
decay
of
radioactive
materials;


Silver
recovery
for
X­
ray
wastes;


Acid
neutralization
(
through
use
of
limestone)
in
the
laboratories;


Grease
traps
in
the
cafeteria
and
kitchen;
and

Plaster
recovery
in
the
room
where
casts
are
fitted.

A
majority
of
healthcare
facilities
discharge
wastewater
to
POTWs.
These
facilities
complete
discharge
monitoring
reports
(
DMR)
according
to
their
state,
tribal
and
local
water
discharge
guidelines,
but
there
is
not
a
centralized
data
collection
system
for
the
information.

Hospitals
that
discharge
directly
and
have
greater
than
1,000
occupied
beds
are
covered
by
40
CFR
Part
460.
They
generally
have
on­
site
biological
treatment
in
addition
to
the
pretreatment
listed
above.
The
most
common
type
of
biological
treatment
is
the
trickling
filter.
Other
technologies
in
use
include
activated
sludge
and
aerated
lagoons.

Multimedia
Environmental
Releases
Hospitals
generate
infectious
(
red
bag
or
biohazard)
waste,
hazardous
waste,
solid
waste,
and
volatile
air
emissions.
OSHA
and
RCRA
regulate
the
largest
hospital
waste
stream:
solid
and
hazardous
waste.
OECA's
Healthcare
Sector
Notebook10
provides
detailed
information
on
Page
10
of
16
8
10
12
14
16
1980
1984
1988
1992
1996
2000
Source:
CMS,
Office
of
the
Actuary,
National
Health
Statistics
Group.
Calendar
Years
Percent
of
GDP
Period
of
accelerated
growth
Period
of
stabilization
multimedia
releases
from
hospitals.

Industry
Trends
and
Trade
Associations
The
following
is
a
summary
of
information
on
Economic
Trends
from
OECA's
Healthcare
Sector
Notebook
(
Section
6.1).

Healthcare
Expenditures
as
a
Share
of
the
Gross
Domestic
Product
According
to
the
Centers
for
Medicare
and
Medicaid
Services
(
CMS),
the
healthcare
industry
currently
accounts
for
approximately
13
percent
of
the
Gross
Domestic
Product
(
GDP)
of
the
United
States.
By
the
year
2010,
healthcare
expenditures
are
expected
to
increase
to
17
percent
of
the
GDP.
As
shown
in
Figure
1­
1
below,
the
growth
of
spending
has
stabilized
since
1993
because
medical
prices
averaged
only
a
2.9
percent
annual
growth
between
1993
and
1999.
This
growth
is
relatively
minimal
compared
to
the
11.2
percent
average
annual
growth
between
1980
and
1982,
and
the
6
percent
average
annual
growth
between
1982
and
1993.
Another
factor
to
consider
in
this
stabilization
is
the
growth
in
the
complementary
care
industry
(
i.
e.,
nonallopathic
healthcare
services),
which
was
reported
to
be
approximately
42
billion
dollars
in
the
mid
1990'
s.

Figure
1­
1:
National
Healthcare
Expenditures
as
a
Share
of
the
GPD
Source:
June
2002
Centers
for
Medicare
and
Medicaid
Services
Report.
Page
11
of
16
Other
Spending
24%

Nursing
Home
Care
7%
Prescription
Drugs
9%
Program
Administration
and
Net
Cost
6%
Hospital
Care
32%

Physician
and
Clinical
Services
22%

Note:
Other
spending
includes
dentist
services,
other
professional
services,
home
health,
durable
medical
products,
over­
the­
counter
medicines
and
sundries,
public
health,
research
and
construction.

Source:
CMS,
Office
of
the
Actuary,
National
Health
Statistics
Group.
Total
Health
Spending
=
$
1.3
Trillion
*
Healthcare
Spending
In
calendar
year
2000,
the
United
States
spent
$
1.3
trillion
on
healthcare
(
NAICS
code
62).
Most
of
this
money
was
split
between
hospital
care
(
32
percent)
and
physician
and
clinical
services
(
22
percent).

As
shown
in
Figure
1­
2
below,
prescription
drugs
accounted
for
9
percent
of
the
total
healthcare
spending
in
2000.
According
to
the
CMS,
between
1990
and
2000,
prescription
drug
spending
increased
by
more
than
3
percent
while
the
amount
of
money
spent
at
hospitals
decreased
by
4.8
percent.
Figure
1­
2:
The
Nation's
Health
Dollar,
CY
2000
Source:
June
2002
Centers
for
Medicare
and
Medicaid
Services
Report.
Page
12
of
16
87
76
63
13
24
37
0
20
40
60
80
100
1980
1990
2000
Inpatient
Outpatient
Note:
Community
hospitals
are
all
non­
federal,
short­
term
general,
and
special
hospitals
whose
activities
are
available
to
the
public.

Source:
CMS,
Office
of
the
Actuary,
National
Health
Statistics
Group.
Percent
Inpatient
Care
Versus
Outpatient
Care
The
implementation
of
Medicare
prospective
payment
systems
and
the
increased
enrollment
into
various
managed
care
programs,
has
been
a
contributing
factor
in
the
decreased
length
of
patient
hospital
stays
since
1980.
According
to
the
CMS,
in
1980,
the
average
length
of
a
hospital
stay
was
between
7
and
8
days.
In
1999,
it
was
approximately
2
to
3
days.
These
factors,
along
with
advances
in
technology
and
pharmaceuticals
available
to
treat
diseases,
have
also
led
to
a
decline
in
the
number
of
inpatient
hospital
procedures.
As
shown
in
Figure
1­
3
below,
inpatient
care
accounted
for
87
percent
of
hospital
procedures
in
1980.
In
2000,
that
number
was
down
to
63
percent.

Figure
1­
3:
Community
Hospital
Expenditures:
Inpatient
and
Outpatient
Shares
for
All
Payers
Source:
June
2002
Centers
for
Medicare
and
Medicaid
Services
Report.

Pollution
Prevention
In
1998,
EPA
entered
into
a
MOU
with
the
American
Hospital
Association
which
calls
for:
(
1)
virtually
eliminating
mercury­
containing
waste
by
2005;
(
2)
reducing
the
overall
volume
of
all
environmental
releases
by
33
percent
by
2005
and
by
50
percent
by
2010;
and
(
3)
identifying
hazardous
substances
for
pollution
prevention
and
waste
reduction
opportunities,
including
hazardous
chemicals
and
persistent,
bioaccumulative,
and
toxic
pollutants.
The
H@
E
effort
educates
health
care
professionals
about
pollution
prevention
opportunities
in
hospitals
and
health
care
systems.
Through
activities,
such
as
the
development
of
best
practices,
model
plans
for
total
Page
13
of
16
waste
management,
resource
directories,
and
case
studies,
the
project
hopes
to
provide
hospitals
and
health
care
systems
with
enhanced
tools
for
minimizing
the
volumes
of
waste
generated
and
the
use
of
persistent,
bioaccumulative,
and
toxic
chemicals.
Such
reductions
are
beneficial
to
the
environment
and
health
of
our
communities.
Furthermore,
improved
waste
management
practices
will
reduce
the
waste
disposal
costs
incurred
by
the
health
care
industry.
For
more
information
see
the
web
site
for
Hospitals
for
a
Healthy
Environment
(
H2E)
at
http://
www.
h2e­
online.
org/
and
http://
www.
hercenter.
org/.

The
web
site
for
Sustainable
Hospitals,
http://
www.
sustainable
hospitals.
org/
provides
technical
support
to
the
healthcare
industry
for
selecting
products
and
work
practices
that
reduce
occupational
and
environmental
hazards,
maintain
quality
patient
care,
and
contain
costs.
This
site
focuses
on
mercury­
free
products
and
other
pollution
prevention
opportunities.

The
web
site
for
the
American
Society
for
Healthcare
Environmental
Services
(
ASHES),
http://
www.
ashes.
org/,
provides
information
on
environmental
excellence
and
advances
in
healthcare
environmental
services,
textile
care
professions
and
related
disciplines.

There
are
also
a
variety
of
resources
on
water
conservation
available
to
the
healthcare
industry.
Many
of
these
resources
are
presented
on
the
Hospitals
for
a
Healthy
Environment
web
page
for
water
conservation
fact
sheets
().
Several
of
these
resources
are
described
below
in
additional
detail:


The
document
titled
"
Water
Conservation
Checklist:
Hospitals/
Medical
Facilities;
Every
Drop
Counts!"
published
by
the
North
Carolina
Department
of
Environment
and
Natural
Resources
Division
of
Pollution
Prevention
and
Environmental
Assistance
contains
a
list
of
water
use
areas
throughout
a
hospital
and
ways
to
reduce
water
consumption
in
each
of
those
areas.
This
document
can
be
found
at:
http://
www.
p2pays.
org/
ref/
23/
22006.
pdf.

Based
on
this
document
water
use
in
hospitals
can
be
reduced
considerably
as
shown
in
the
following
table
(
also
discussed
in
Section
2):

Types
of
Water
Uses
Average
Water
Use
(%
of
total)
Potential
Savings
(%
of
total)

Cooling
53
32
Domestic
24
10
Cleaning
10
9
Kitchen
5
­­

Process
4
­­

Other
4
­­

TOTALS
100%
51%
Page
14
of
16
139,214
gpd
71,000
gpd
Source:
ICI
Conservation
in
the
Tri­
County
Area
of
the
Southwest
Florida
Water
Management
District
(
SWFWMD).
SWFWMD,
November
1997.


The
New
Hampshire
Department
of
Environmental
Services
developed
an
environmental
fact
sheet
titled
"
Water
Efficiency
Practices
for
Health
Care
Facilities"
which
also
presents
practices
by
water
use
area.
This
document
can
be
found
at:
http://
www.
des.
state.
nh.
us/
factsheets/
ws/
ws­
26­
14.
htm

Southwest
Florida
Water
Management
District
(
SWFWMD)
also
has
a
similar
factsheet
titled
"
Water
Conservation
@
Work:
Hospitals."
This
document
can
be
found
at:
http://
www.
swfwmd.
state.
fl.
us/
watercon/
waterwork/
checkhospital.
htm.


Healthcare
Purchasing
News
has
developed
a
Self
Study
Series
to
evaluate
environmentally
preferable
products.
One
item
in
this
series
discusses
microfiber
mops
which
use
less
water
than
conventional
cotton
mops.
The
article
discusses
the
economic,
environmental,
employee,
and
patient
benefits
of
using
microfiber
mops.
This
document
can
be
found
at:
http://
198.151.15.185/
pubs/
ShouldYouMicrofiber.
pdf

The
University
of
Wisconsin
Cooperative
Extension
developed
a
hospital
waste
reduction
checklist
which
includes
strategies
for
reducing
wastewater
discharges.
These
strategies
include
substitution
of
less
toxic
materials,
procedures
for
moving
or
cleaning
sewer
lines,
traps,
or
sumps,
and
chemical
storage
and
disposal
options.
This
document
can
be
found
at:
http://
www.
uwex.
edu/
shwec/
Pubs/
pdf/
425­
9602.
pdf.


The
Medical
Academic
and
Scientific
Community
Organization
prepared
a
pretreatment
manual
for
use
by
hospitals
to
help
solve
a
sewer
discharge
compliance
problem.
The
manual
outlines
the
elements
of
typical
source
reduction
programs
and
a
wastewater
pretreatment
strategy.
This
document
can
be
found
at:
http://
www.
masco.
org/
mercury/
pretreatment/
index.
html.


EPA's
Small
Business
Ombudsman
developed
a
fact
sheet
for
walk­
in
urgent
care
facilities
and
smaller
hospitals.
The
fact
sheet
explains
some
of
the
best
management
practices
(
BMPs)
related
to
toxic
chemicals
or
hazardous
materials
used
as
part
of
the
diagnostic,
treatment,
and
cleaning
processes
used
in
these
smaller
facilities.
This
document
can
be
found
at:
http://
www.
smallbiz­
enviroweb.
org/
html/
pdf/
BMP_
HealthCare­
4.
pdf.


EPA
Regions
1
and
2
have
on­
going
programs
to
provide
information
to
help
healthcare
facilities
reduce
environmental
impacts
of
their
operations
and
improve
their
understanding
of
and
compliance
with
environmental
regulations.
The
EPA
programs
also
help
facilities
realize
the
cost
savings
and
environmental
benefits
that
can
be
attained
through
improvements
in
recycling,
energy
efficiency
and
water
conservation.
More
information
can
be
found
at:
http://
www.
epa.
gov/
region1/
healthcare/
and
11Williams,
Guy,
1997.
Mercury
Pollution
Prevention
in
Healthcare,
http://
www.
newmoa.
org/
prevention/
topichub/
22/
Mercury_
Pollution_
Prevention_
in_
Healthcare_
NWF.
htm.

Page
15
of
16
http://
www.
epa.
gov/
region2/
healthcare/.

With
respect
to
controlling
mercury
discharges,
healthcare
facilities
contain
mercury
in
some
medical
equipment
(
e.
g.
pressure
gauges,
thermometers),
laboratory
reagents,
and
common
facility
items
(
e.
g.,
fluorescent
lights,
thermostats,
cleaning
supplies).
Some
hospitals
approached
the
problem
of
mercury
use
within
their
facilities
by
following
some
basic
steps,
including:


Conducting
inventories
to
identify
sources
of
mercury
within
their
facilities;


Making
recommendations
to
existing
hazardous
waste
and
safety
committees
and
the
administration
for
reducing
or
eliminating
these
sources;


Instituting
immediate
steps
for
mercury
reduction;
and,


Devising
long­
term
goals
for
the
virtual
elimination
of
mercury
from
their
facilities.

An
example
of
this
approach
was
documented
at
two
major
Detroit
hospitals
that
instituted
mercury
pollution
prevention
plans.
Wastewater
sampling
was
conducted
to
evaluated
their
performance.
Before
the
mercury
pollution
prevention
program,
mercury
measures
at
these
sites
were
in
the
range
of
0.28
ppb
to
0.96
ppb.
After
the
program
was
instituted,
these
figures
dropped
to
0.09
ppb
to
0.15
ppb.
11
References
1.
Centers
for
Medicare
and
Medicaid
Services
Web
Page.
http://
www.
cms.
hhs.
gov/
charts/
healthcaresystem/
chapter2.
asp,
accessed
10/
22/
04.

2.
Hospitals
for
a
Healthy
Environment
Web
Page
for
Water
Conservation
Fact
Sheets
(
http://
www.
h2e­
online.
org).

3.
U.
S.
EPA
Office
of
Water
and
Hazardous
Materials.
Development
Document
for
Interim
Final
Effluent
Limitations,
Guidelines
and
Proposed
New
Source
Performance
Standards
for
the
Hospital
Point
Source
Category.
EPA
440/
1­
76/
060n.
April
1976.

4.
U.
S.
EPA
Office
of
Enforcement
and
Compliance
Assurance.
Profile
of
the
Healthcare
Industry.
EPA/
310­
R­
04­
001.
February
2005.

5.
U.
S.
EPA
Office
of
Water
Regulations
and
Standards.
Preliminary
Data
Summary
for
the
Hospitals
Point
Source
Category.
EPA
440/
1­
89/
060­
n.
September
1989.

6.
Barnes,
Kimberlee
K.,
Dana
W.
Kolpin,
Michael
T.
Meyer,
E.
Michael
Thurman,
Edward
T.
Furlong,
Steven
D.
Zaugg,
and
Larry
B.
Barber.
Water­
Quality
Data
for
Pharmaceuticals,
Hormones,
and
Other
Organic
Wastewater
Contaminants
in
U.
S.
Page
16
of
16
Streams,
1999­
2000.
U.
S.
Geological
Survey.
Available
at
http://
toxics.
usgs.
gov/
pubs/
OFR­
02­
94/.
