New Public Water Testing, Certification and Verification Programs

1. New Public Water Testing, Certification and Verification Programs Bruce Bartley, NSF International Michigan Section AWWA Conference August 2010

2. Existing NSF Programs • Public Water Systems • Treatment Chemicals • NSF/ANSI Standard 60 • Treatment and Distribution System Materials • NSF/ANSI Standard 61 • Performance of Treatment Equipment • NSF/EPA ETV

3. NSF = National Sanitation Foundation • Founded 1944 • University of Michigan • Today independent not-for-profit • Standards Development • Food, Water, Public Health • Product Certification • Food Safety • Drinking and Recreational Water Safety

4. Users Manufacturers Regulators Regulators NSF Standards Development Process

5. NSF/ANSI Standard 60 • Drinking Water Treatment Chemicals Health Effects. • Developed to ensure treatment chemicals do not add unsafe levels of chemicals or contaminants to drinking water. • Chemical is safe at its maximum use level. • Contaminants associated with the chemical are below maximum allowable levels.

6. NSF/ANSI Standard 60 • Testing of sample. • Dosed into water at 10 x maximum use level. • Analyze water for contaminants. • Contaminant levels < SPAC • SPAC = single product allowable level • SPAC typically is 1/10 total allowable level • For example, the As MCL = 10 ppb • so the SPAC = 1 ppb

8. New Developments NSF 60: Contaminants in Hypochlorite • Bromate – • Proposal pending to reduce single product allowable concentration (SPAC) to 3 ppb. (currently 5 ppb) • Task group forming to investigate establishing a SPAC for bromide in NaCl used for electrolytic on-site generators. • Perchlorate – • Task group has identified analytical methods, and working on proposals for SPAC, warning and use instructions for users.

9. Effect of Age on perchlorate in NaOCl

10. Effect of Age on perchlorate in NaOCl • Perchlorate is unique in that it is at extremely low levels in newly produced hypochlorite but increases with age. • Rate of decomposition effected by; • Temperature • Concentration • pH • Ionic strength • Other factors

11. Effect of Age on perchlorate in NaOCl • NSF 60 requirements will address: • Concentration of perchlorate as new product is shipped from manufacturers. • Require production date and any repackage date on product container. • Reference AWWA B-300 recommended storage and handling practices (currently being drafted and balloted into B-300)

12. NSF/ANSI 61 • Drinking Water System Components • – Health Effects • Two new developments … • Average Weighted Lead Content 0.25% to correspond with regulations in CA and VT • Criteria for the evaluation of facilities that regenerate and reactivate process media.

13. NSF/ANSI 61 • Drinking Water System Components • – Health Effects • What it is … • American National Standard for evaluating health effects of products used in drinking water applications. • Covers all products with drinking water contact from source to tap. • Concerned with all potential extractants, not just lead. • Does not evaluate product performance.

14. NSF/ANSI 61 • Drinking Water System Components • – Health Effects • What does it cover … • Products or materials that come into contact with drinking water or drinking water treatment chemicals, such as; • Pipes and fittings • Paints and coatings • Mechanical devices • process equipment • water meters, valves • Joining & sealing materials • Process media • Mechanical plumbing devices • faucets, • drinking fountains

15. Standard 61 Requirements • 1. What contaminants migrate or extract into water? • 2. Are they below maximum allowable level? • Formulation disclosure by manufacturer. • Formulation review of product. • Extract contaminants from product into water. • Analyze extraction water for contaminants. • Perform toxicology evaluation of contaminants. • Inspection of manufacturing facility.

16. New Lead acceptance criteria The lower acceptance criteria resides in Annex F of Standard 61 with an implementation date of July 1, 2012.

17. New lead content restrictions 3.5 Restriction on use of lead containing materials

18. Optional lead content evaluation(Annex G) Core requirement: Weighted average lead content < 0.25% Formula:

19. Example Faucet

20. Example weighted average lead content calculation

21. NSF-61-G OR ® Certified to NSF/ANSI-61, Annex G NSF Marks for Low Lead Content NSF 61 G Mark • Products meet all requirements of NSF 61 plus Annex G weighted average lead content <0.25%

22. Regenerated Media Increasing number of companies offering offsite: • reactivation of spent granular activated carbon • regeneration of other adsorptive medias (arsenic reduction, ion-exchange, etc.) Products lose traceability and when they are removed from treatment plant. Requirements added to NSF 61 in 2008 to address regenerated media.

23. Regenerated Media Requirements Each shipment of spent media: • Only used for drinking water applications. • Only from public water systems per USEPA def. • Shall not be a RCRA hazardous waste 40 CFR261. • Shall not be classified as hazardous waste in state or province. • Transportation containers suitably protected from contamination. • Commingled media shall be of comparable type and function.

24. Regenerated Media Requirements Each regeneration/reactivation facility: • Facilities and equipment classified as potable water and/or food grade. • Samples from each batch retained for 2 years. • Provide a description of process and process controls. • Procedure detailing the evaluation of review of water quality data from spent media sources.

25. Regenerated Media Requirements Each facility retains records for each batch of spent media: • Identifying media type, source, use application. • Mfr trade designation, mesh size, NSF 61 compliance of original virgin media. • Primary contaminants removed from water, including contaminant spills or unusual water conditions. • Verification statements about spent media source and exposure to prohibited contaminants.

26. Regenerated Media Requirements New Minimum Testing established in table 7.1 of NSF61 • Expanded list of metals • GC/MS scan for trace organics • Radionuclides • VOC scan Labeling Requirements • Identify media as regenerated or reactivated. • Identify if media is commingled.

28. NSF EPA ETV Program Environmental Technology Verifications • Developed protocols with EPA & US States • Treatment Equipment. • Performed one time on-site testing • Published report of performance, operation and maintenance requirements. • List of reports: • www.epa.gov.etv • www.nsf.org/info/etv

29. Public Drinking Water Treatment Equipment (PDWTE) • New Certification Program evolved from NSF/USEPA ETV program. • Concerns from stakeholders: • One time test might not be enough. • Desire for on-going verifications that design, materials are not changing or are re-validated.

30. PDWTE - Components • Testing to EPA ETV protocols. • Ongoing inspections of certified products at manufacturing facilities. • Also requires NSF 61 certification. • Any changes must be reviewed prior to authorization. • Any changes that might impact performance will require retesting. • NSF Report has same information as ETV Reports.

31. PDWTE Reason for Transition from ETV • The Long Term 2 Enhanced Surface Water Treatment Rule (LT2): • Requires product specific testing of membrane filters and UV disinfection units. • Recommends testing by independent third party. • Non-testing requirements like confirming quality controls in place during manufacturing and product retesting if modified. • ETV only tests and can not address non-testing requirements.

32. LT2 Language in Guidance • Sec. 3.2 of Guidance Manual: “Any significant modification to the membrane media (e.g., a change in the polymer chemistry), hydraulic configuration (e.g., changing from suspension to deposition mode), or any other modification that could potentially affect removal efficiency …. would require additional challenge testing to both demonstrate the removal efficiency of the modified module . . . ” • NSF’s audits assure conformance to requirement.

33. EXAMPLE Membrane Filtration and LT2 • LT2 requires random performance testing (log reduction) using live Crypto or surrogate. • A log removal value (LRV) established from performance testing. • LRV is directly linked to the manufacturer’s QC of its modules. • All modules used for drinking water shall meet the QC value that is directly linked to the LRV. • NSF will oversee and monitor QC in the production facility.

35. EXAMPLE UV Disinfection Reactor Validation and LT2 • LT2 requires each make and model of a UV reactor to be performance tested or “validated” to confirm dose. • EPA – UV Design Guidance Manual - UVDGM • The UV dose in mJ/cm2 must be validated for log removal Crypto using a surrogate (reduction equivalent dose or RED). • Validation should be done by independent third party.

36. UV Disinfection Reactor Validation and Certification • LT2 UV Guidance manual has long list of components that if changed will require revalidation. • NSF will audit for component changes for Certification that could affect the RED. • NSF will validate UV reactors in accordance to the new ETV protocol that allows use of surrogates with UV sensitivity close to Crypto & validates to international dose of 40 mJ/cm2.

37. PDWTE Certification Summary • NSF Certification reports meet the need for independent third party requirements of LT2. • NSF Certification reports are identical to the high quality ETV reports. • NSF Certification addressed the non-testing requirements in LT2. • Certification audits will address: • Whether the product tested is the same as that being produced and; • Critical product / component changes affect performance and if so the amount of retesting.

38. Conclusion • NSF 60 • New requirements for bromate and perchlorate in hypochlorite products. • NSF 61 • Optional Lead content requirements. • Requirements for off-site regenerated media. • Performance Certifications to LT2 requirements • Membrane Filtration • UV Disinfection Systems

39. Questions? C. Bruce Bartley NSF International bartley@nsf.org 734-769-5140 Website Listings of Certified Products http://www.nsf.org