Pollution Prevention Program in Oregon

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Executive Summary
The EPA has requested input from state officials on what policy measures, if any, should be taken to help in the mitigation of mercury pollution from the dental sector. The Oregon Department of Environmental Quality has produced this memorandum to assist in the analysis, as well as possible solutions to the amalgam issue. Data from this memorandum pertains specifically to the State of Oregon, but can be extrapolated for nationwide analysis. We examined three policy options: status quo, mandatory amalgam separators, and Significant Industrial User status. Each policy option took focuses on aspects of effectiveness, efficiency, equity and feasibility. Effectiveness and efficiency of policy options looks and potential pollution mitigation and costs on a quantities level, while equity and feasibility take a more qualitative approach.
Our analysis finds that of the three options, mandating the installation and maintenance of amalgam separators would be the optimal option for the EPA. This policy option provides a more effective pollution prevention program than the status quo, at a cheaper cost than the SIU option, is fair in which stakeholders bear the risks and costs, and is politically feasible based on current state initiatives. The key points of this policy can be outlined below:
• 11,500 less pounds of mercury flowing to POTWs
• 600 less pounds of mercury entering the ecosystem
• 850% less expensive than the SIU option
• 316,000% less expensive than the
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