By Carlos David Mogollón, WC&P Executive Editor

Orphaned in the hustle of weeklong, back-to-back meetings, seminars and events at the Water Quality Association’s Long Beach Convention, three weighty issues were missing from the final agenda at the WQA Board of Directors meeting March 25.

  • Activated carbon’s ability to meet materials safety aspects of an impending tighter federal arsenic rule for drinking water,
  • Tradeoffs between salt and water efficiency with respect to new WQA softener guidelines agreed to in California, and
  • A surprise, confrontational inspection on the WQA trade show floor by the USEPA Office of Pesticides Program of products claiming to kill bacteria.
    Once broached, they were the topic of much hallway chatter and speculation. WC&P followed up after the convention on these issues and here is what it found:

Carbon and arsenic
KX Industries’ Evan Koslow dropped what appeared to be a bomb at the Small Systems Committee meeting when he pointed out some carbons would have a problem—if not an “insurmountable” one—to meet a new arsenic rule below 20 parts per billion (ppb).

Current wisdom, via the American Water Works Association, suggests the proposed maximum contaminant level (MCL) will come in at 5 ppb with comment sought at 3 and 10 ppb. The current standard is 50 ppb. The World Health Organization lowered its guideline from that to 10 ppb several years ago. Originally scheduled for release in December, the U.S. rule has been delayed until June for further review because of its potential impact on a number of community water systems, particularly in the West, that may find it cost-prohibitive to comply with.

That said, Koslow said arsenic is an occasional extractable from activated carbon and raised three points on the subject:

  1. “It doesn’t appear the carbon companies or EPA have accounted for the fact that municipal carbons are not typically acid washed. A fairly high percentage of these commodity grade carbons, generally, are contaminated with arsenic and it doesn’t appear anybody has been modifying their quality as they go into our cities because most exceed the arsenic standard on an episodic basis; i.e., there are episodes where you get a load of carbon and it has a lot of arsenic in it.”
  2. “The POU industry has generally used a higher quality carbon, most often acid-washed; but some manufacturers don’t use acid-washed carbon… Unless you’ve got a program to handle this, you’ve got no way of guaranteeing arsenic won’t show up in your product from time to time. Now, if you acid wash, you reduce  chances of an arsenic episode but, in most cases, you haven’t eliminated it.”
  3. “This is where we get into real trouble. If the arsenic standard is reduced from 50 ppb to 20 ppb or below, this goes from episodic to a large-scale continuous problem. And as the standard is reduced to 5-to-10 ppb, there doesn’t exist a reliable technology to produce activated carbon at those levels—even with acid washing. It’s physically not posible to wash it down to that level on a consistent basis. If it were to be implemented…I see it as having a cripling effect on the industry.”

Koslow said this is true for coconut—although less so—as well as coal-based carbons, and said he mentioned it to the WQA about eight months ago and has discussed it with a few carbon manufacturers.

“I see it as a SNAFU or oversight on the part of the EPA that it never realized this and it appears no one from the POU or carbon industries ever mentioned this to them during all these government hearings,” he said. “And we’re now only a few more months away from the proposal coming out.”

Contradicting some of his earlier points, though, Koslow added that his company has developed a proprietary process to eliminate arsenic as an extractable problem for carbon several years ago when it did a risk assessment on a contract to supply General Electric with carbon for its water treatment products.

Other carbon experts agreed with parts of Koslow’s contention, but disagreed with his main thrust.

One was Dr. Steve Ragan, Brita Corp.’s research and development manager, who spoke up at the committee meeting to say that: 1) yes, it’s a problem for municipal grade carbon, but 2) no, it’s not insurmountable for the POU industry.

Mohamed Bayati, Western regional sales manager for Waterlink/Barneby & Sutcliffe Corp. and its former technical director, agreed with Ragan’s assessment—particularly the inability of the POU industry to meet an arsenic standard below 20 ppb.

“That’s wrong. That’s a mistake. For point-of-use/point-of-entry, it’s not going to be an issue,” Bayati said. “We’ve been making carbon for several years and monitor for arsenic, antimony and aluminum. We water wash our coconut carbons…. On coal-based, you have to acid wash it in a special process to remove these metals. It may show up occasionally… which just means you have to do a better job of washing it. That’s all.”

After the WQA meeting, Bayati said he had three of his largest customers call “in a panic” and had to assure them that the “problem” was overblown.

Rick Farmer, senior research manager for Calgon Carbon Corp.—the largest carbon producer—said his company too has dealt with this issue.

“Calgon Carbon has studied arsenic leaching from whole and coconut-based product since the early ’90s,” he said. “We’re confident our acid-washed product will meet arsenic leaching requirements of the ANSI/NSF drinking water treatment protocols in the event the EPA lowers the arsenic MCL to 20 ppb. Even if it’s set at a lower level, we’ve developed technology to make certain our carbon product will meet these more stringent leaching levels.”

Salt vs. water efficiency
With passage last fall of California Senate Bill 1006, the WQA and industry agreed to meet a stricter efficiency rules for salt efficiency in its compromise victory to assure communities seeking to restrict or ban water softeners first address other contributors to the waste stream. The first level of this went into effect Jan. 1 at 3,350 grains of hardness removal per pound of salt used for regeneration. The second takes effect in January 2002 when only softeners with a minimum efficiency of 4,000 grains can be sold in the state.

Still, it was pointed out at the Ion Exchange Task Force that there’s a tradeoff. Higher salt efficiency means greater water use or less water efficiency, according to Lance FitzGerald, Culligan product development director, in discussing ways to reach the second level of efficiency demanded.

Task force chairman C.F. “Chubb” Michaud said this was true, but that while softeners would regenerate more frequently that meant a more dilute waste stream which is better for the environment. Newer smart valves, he also noted, will help save water along with improved salt efficiency.

Since the higher efficiency guideline currently applies only to California, the task force voted not to change the WQA Gold Seal standard for minimum efficiency from 3,350 grains. Rather, softeners would simply receive efficiency ratings, as is done now, to be marked on the unit, said association technical director Joe Harrison.

“I was surprised because this came up more strongly at the Mid-Year meeting than here,” Harrison added. “But that’s where the industry is leaning—just leave the efficiency standard the way it is and list on the certificate what the actual numbers are to meet the efficiency rule in California.”

He added that water use is part of the Gold Seal standard, which tests for how much water is used per 1,000 grains of hardness removal. Softeners have to be below a set amount of water use to earn the efficiency rating.

Pesticides and pests
Several exhibitors on the trade show floor complained of being approached March 23 by USEPA Office of Pesticides Program (OPP) inspectors and asked if they had anything that killed bacteria. If exhibitors said yes, they were flashed an ID and asked if they were registered under FIFRA (the Federal Insecticide, Fungicide and Rodenticide Act) as a pesticides or pesticidal devices. If not, they were told they were in violation of federal laws and risked fines of $5,000 a day.

Needless to say, being “accosted” in front of potential customers did not set well with them and they complained to the WQA about abusive treatment. They were also upset the issue hadn’t been taken up with the association instead of on the trade show floor. In particular, ultraviolet and ozone disinfection devices were being singled out, it was said.

WQA’s Harrison said he was aware of a number of exhibitors that have the FIFRA registrations: “Our whole argument is not that we have a problem with the EPA rule or compliance. It’s just with the awkward way they went about confronting exhibitors.”

In following up on this issue, WC&P spoke with one of the inspectors who had been in Long Beach, Yvette Hopkins. She said the operation was a “neutral inspection scheme” where state inspectors come in and informally look around.

“It wasn’t as if we expected WQA members to be out of compliance,” she said. “This was a convention and we were going to see the lay of the land as we’ve done at other conventions. What happened at the WQA was there was such widespread violation, we would have had to call in the troops to do it properly. We decided not to take the enforcement approach because it didn’t lend itself in such great terms.”

She said people were screaming at her about changing the rules and others saying the WQA works very closely with the USEPA and even had agency officials as speakers that afternoon: “To the public, the EPA may seem very monolithic, like ‘the Borg,’ where everyone knows what everyone is doing, but that’s not the case.”

Peter Caulkins, OPP Registrations Division assistant director, said the issue is not trivial: “If a product makes a claim to kill a pest then it needs to be licensed, whether it’s a bacteria or otherwise.”

Dr. David Liem, of the Antimicrobial Division, noted that if something is imparted to the water such as from silver-impregnated carbon or iodinated resin, it would be considered a pesticide—whereas an ozone generator or UV unit is considered a pesticidal device. Requirements differ for each.

Hopkins said pesticides require registration and efficacy data must be submitted for approval; devices simply need to have that information available in case additional information is ever requested. Certain aspects of record and bookkeeping, labeling and facilities inspections are more strict for pesticides; devices simply need an “establishment” number, that must be listed on the device and packaging—inspections aren’t the norm. There’s no fee for establishment numbers, she said; however, maintaining registration runs in the neighborhood of $1,600 per year per product with a cap of $35,000 a year per registrant for companies like DuPont with multiple products.

Additional details on registration requirements and FIFRA are at the following websites:

Conclusion
It was unusual not to have the above three topics included in the lively discussions that often occur at the WQA’s final convention board meeting. After all, it’s only by being aware of a problem that one is able to address it. The entire industry needs to be aware of these issues.

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