NSF/ANSI 61

Report
New Public Water Testing, Certification
and Verification Programs
Bruce Bartley, NSF International
Michigan Section AWWA Conference
August 2010
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
NSF = National Sanitation Foundation
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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
NSF Standards
Development Process
Users
Manufacturers
Regulators
Regulators
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.
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
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.
Effect of Age on perchlorate in NaOCl
Perchlorate in sodium hypochlorite
(normalized to at-the-tap values)
Normalized Perchlorate Result - ug/L
12
10
8
6
4
2
1 ug/L
0
0
15
30
45
60
75
90
105
120
Age of NaOCl - days
135
150
165
180
195
210
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
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)
NSF/ANSI 61 – 2004
NSF/ANSI 61
Drinking water system components ―
Health effects
NSF International Standard/
American National Standard
Drinking Water System Components
– Health Effects
Developed by a consortium of:
 NSF International
 The American Water Works Association Research Foundation
 The Association of State Drinking Water Administrators
 The American Water Works Association
NSF/ANSI 61 – 2004
With support from:
 The U.S. Environmental Protection Agency
under cooperative agreement #CR-812144
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.
NSF/ANSI 61 – 2004
NSF/ANSI 61
Drinking water system components ―
Health effects
NSF International Standard/
American National Standard
Drinking Water System Components
– Health Effects
Developed by a consortium of:
 NSF International
 The American Water Works Association Research Foundation
 The Association of State Drinking Water Administrators
 The American Water Works Association
NSF/ANSI 61 – 2004
With support from:
 The U.S. Environmental Protection Agency
under cooperative agreement #CR-812144
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.
NSF/ANSI 61 – 2004
NSF/ANSI 61
Drinking water system components ―
Health effects
NSF International Standard/
American National Standard
Drinking Water System Components
– Health Effects
Developed by a consortium of:
 NSF International
 The American Water Works Association Research Foundation
 The Association of State Drinking Water Administrators
 The American Water Works Association
NSF/ANSI 61 – 2004
With support from:
 The U.S. Environmental Protection Agency
under cooperative agreement #CR-812144
What does it cover …
Products or materials that come into contact with drinking water or
drinking water treatment chemicals, such as;
• Pipes and fittings
• Joining & sealing materials
• Paints and coatings
• Process media
• Mechanical devices
• Mechanical plumbing devices
– process equipment
– faucets,
– water meters, valves
– drinking fountains
Standard 61 Requirements
1. What contaminants migrate or extract into water?
2. Are they below maximum allowable level?
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Formulation disclosure by manufacturer.
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Formulation review of product.
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Extract contaminants from product into water.
•
Analyze extraction water for contaminants.
•
Perform toxicology evaluation of contaminants.
•
Inspection of manufacturing facility.
New Lead acceptance criteria
The lower acceptance criteria resides in Annex F
of Standard 61 with an implementation date of
July 1, 2012.
NSF/ANSI 61 Criteria
Total Allowable Concentration
Single Product Allowable
Concentration
Q Value
1
Current
New
15 ug/L
5.0 ug/L
1.5 ug/L
0.50 ug/L
11 ug
5 ug (3 ug)1
– Supply stops, flexible plumbing connectors, and miscellaneous
components
New lead content restrictions
3.5 Restriction on use of lead containing materials
Optional lead content evaluation
(Annex G)
Core requirement:
Weighted average lead content < 0.25%
Formula:
n
WLC =

c=1
where;
WLC
LC
WSA
n
=
=
=
=
(LC
c
x
[
n
WSAc

WSAt
t=1
])
weighted average lead content of product
percentage lead content of component
wetted surface area of component
number of wetted components in product
Example
Faucet
Example weighted average lead content calculation
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%
®
Certified to
NSF/ANSI-61, Annex G
OR
NSF-61-G
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.
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.
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.
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
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.
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
Questions?
C. Bruce Bartley
NSF International
[email protected]
734-769-5140
Website Listings of Certified Products
http://www.nsf.org

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