EPA Arsenic Treatment Compliance Deadline
Water and Wastewater Solutions interviewed Tom Carmody, Arsenic Treatment Program Manager for Severn Trent Services, regarding the federal arsenic maximum contaminant level (MCL) standard for drinking water.
Note: Arsenic is a naturally occurring
chemical released into water supplies from the erosion of rocks and soil.
Long-term exposure to arsenic has been proven to result in serious health
effects such as cancer, cardiovascular disease, diabetes and reproductive
problems. There are two different forms of arsenic – arsenite (arsenic
III) and arsenate (arsenic V). Arsenic V is the most common form and is
easier to remove from drinking water. Arsenic III is more difficult to remove
and is more hazardous to human health. High concentrations of arsenic are
found mostly at the foothills of mountain ranges in the United States. Western
states and parts of the Midwest and New England show increasing arsenic
levels well above the approved U.S. Environmental Protection Agency (EPA)
arsenic standard of 10 parts per billion (ppb).
Why did the U.S. Environmental Protection Agency (EPA) release a lower arsenic standard?
Tom Carmody: It’s been about a decade since the USEPA recommended lowering
the arsenic maximum contamination level (MCL) from the 50 ppb standard to
10 ppb based on the potential for arsenic to cause unnatural and dangerous
health effects when released into drinking water supplies. Under the Safe
Drinking Water Act, the EPA is authorized to evaluate the health risks
associated with a known and potential contaminant in an effort to quantify,
manage and lower the risk of serious illness and fatality associated with
it. After analyzing various third party data about arsenic, its concentration
in drinking water and associated health effects, the USEPA eventually settled
on an MCL of 10 ppb in 2001.
What was the general reaction to the lower MCL?
TC: Since the associated compliance costs were high, the arsenic rule received
a great deal of attention and reaction, not always positive, from public
water systems that would be affected by the revised ruling. The EPA initially
estimated the total national annualized costs of treatment, monitoring,
reporting, recordkeeping, and administration for this rule to be approximately
$181 million.
In the U.S., about 5.5% of the nation's 54,000 community water systems – serving 15 locations or 25 residents year round – and 20,000 non-transient, non-community water systems such as schools and churches – serving at least 25 of the same people more than six months of the year – are regulated by the revised arsenic MCL. Approximately 4,000 systems will need to install treatment or take other steps to comply with the 10 ppb standard by the compliance date.
Depending on the size of the system, the financial impact to the end-user
can vary. Initial estimates determined the household water costs in a small
community water system (those serving fewer than 10,000 people), to increase
to between $38 and $327. Household water cost estimates for community water
systems, serving greater than 10,000 people, are expected to increase to
between $0.86 to $32.
When is the compliance date for the federal arsenic removal standard?
TC: The deadline for U.S. public water systems to achieve the EPA’s regulation of a 10 ppb arsenic MCL is January 2006. However, individual states are able to grant exemptions to this deadline in their efforts to enforce the federal guideline. It is the EPA’s general belief that state exemptions will be granted only for the amount of additional time needed to build capacity and come into compliance with the 10 ppb arsenic rule.
All public water systems that meet minimum criteria under the Safe Drinking Water Act are eligible for an exemption up to three years. However, eligible water systems serving less than 3,300 may be granted up to three exemption extensions of two years each - allowing up to nine total years.
When asking for an extension, federal regulation mandates that a utility
demonstrate to the state that forward progress towards achieving the new
standard has been attempted but not yet achieved. That demonstration could
be in the form of a pilot project, preliminary investigations or, possibly,
proof that the utility has put together a bid specification indicating they
are in the procurement process.
Does the revised MCL regulate arsenic levels in private wells?
TC: The federal government is not responsible for establishing rules and
MCLs that govern private wells. Nonetheless, private wells can be and are
affected by the same types of contaminants found and treated in public water
systems – including arsenic. To ensure the protection of public health,
private wells can be regulated for arsenic contamination on a state-by-state
level. In fact, every state has the authority to implement an arsenic standard
that is more stringent or broader reaching than the federal 10 ppb guideline,
but they do not have the ability to establish less stringent standards for
a municipality or even the homeowner.
New Jersey is a great example of a state that recognizes the effects of
arsenic contamination, whether in a municipal or private water source, and
is diligently working to get all its water supplies into compliance. The
New Jersey Department of Environmental Protection (NJDEP) has ordered its
Water Supply Administration to develop a regulation that mandates a 5 ppb
arsenic MCL in drinking water.
Homeowners in the state must prove that their wells meet the 5 ppb arsenic
MCL when the house is sold.
Although arsenic contamination is a real threat to private well water supplies
in various states, New Jersey is the only state that I’m aware of that
currently regulates private water sources.
Are there penalties for non-compliance?
TC: Yes, there will be penalties and there is a process in place to monitor
compliance. In January 2006, utilities must report their current arsenic
levels to the EPA. If it is determined that the utility has not met the
10 ppb requirements, the state will give them approximately six months to
correct the problem.
What are the options for arsenic treatment?
TC: Before even considering the available options, a municipality might
be able to avoid treatment by blending available water sources to reduce
the overall arsenic contamination level. Another option is to abandon the
current water source and review options for obtaining a completely new source
that is arsenic-free. But if operational changes cannot be implemented,
arsenic removal treatment options must be evaluated.
Current arsenic removal treatment options include ion exchange, activated
alumina, reverse osmosis, coagulation/microfiltration and adsorption. When
the EPA released the federal regulation it listed coagulation filtration,
alumina adsorption, ion exchange and reverse osmosis as the Best Available
Technologies (BATs), but since it can take up to ten years to develop a
regulation from conception to final ruling, BAT designation can’t always
keep up with commercially available technology. For example, ferric oxide
’s Bayoxide® E33*, are not listed as BATs, but commercially available products using adsorption technology are viable treatment options for arsenic in drinking water.
Do any programs exist to establish the validity of arsenic removal treatment
technologies?
TC: In effect, the EPA validated the four arsenic removal technologies listed as BATs in the final arsenic ruling. As previously mentioned, though, the development process of a regulation is long and viable treatment options can be overlooked during the evaluation process. Typically, once a regulation has been issued, a company can get the equivalent of a BAT designation for its technology by going through the National Science Foundation (NSF) approval process. Severn Trent’s Bayoxide® E33 media, for example, has received Standard 61 approval by the NSF for use in drinking water applications.
However, when it comes to arsenic removal, there is another option to validate
a technology. Since the cost associated with compliance of the revised arsenic
rule, particularly for small water systems, was a concern, Congress allocated
over $5 million for Small System Arsenic Removal Research, where the money
could be used to find cost-effective and commercially available arsenic
removal treatment options. With this funding, the EPA established the National
Arsenic Treatment Demonstration Project, which evaluates drinking water
treatment technologies and engineering solutions for a number of small water
systems across the U.S. seeking to comply with the 10 ppb arsenic MCL.
Has this National Arsenic Treatment Demonstration Project been successful?
TC: Although the program began soliciting technology proposals for Phase I just over a year ago, it recently commissioned the first pilot unit in Anthony, New Mexico, and a great deal more has been accomplished. The EPA recently accepted technology proposals for thirty-two demonstration sites chosen for Phase II of the project.
Of the twelve demonstration sites chosen during Phase I, over half were awarded to ferric oxide media, adsorptive technology. In fact, Severn Trent’s SORB 33™ arsenic removal technology and Bayoxide® E33 media were awarded six of the twelve demonstration sites. This is a big endorsement for the technology and its ability to treat arsenic contamination.
The program will test the reliability of Severn Trent’s technology
for small systems; assess the simplicity of its operation, maintenance,
and required operator skills; determine its cost-effectiveness; and characterize
its treatment residuals.
Where do you see the role of adsorption as municipalities continue to evaluate
treatment technologies in their efforts to meet the January 2006 deadline?
TC: Adsorption, especially technologies using ferric oxide media, will continue
to be at the forefront of arsenic treatment options that a municipality
evaluates in its efforts to comply with the 10 ppb arsenic MCL. Adsorption
technology is proven across varying water quality conditions and offers
a treatment solution that is simple and cost effective. This isn’t
to say that under certain, difficult water quality conditions, that a competitive
technology wouldn’t be more beneficial, it’s just to say that
adsorption will be able to treat the majority of arsenic contamination problems
in the U.S.
The economics of implementing an adsorption solution are much lower than original technology implementation estimates released by the EPA during the final arsenic rule. In fact, depending on the size of the system, implementation cost of the SORB 33 arsenic removal technology is approximately 1/3 to 1/2 of the cost of some BATs. And the lifecycle cost for the SORB 33 system is dramatically lower than BATs for many source waters.
What is the first step to a successful arsenic removal program?
At the onset of the evaluation process, it’s recommended that you characterize
your own systems in terms of the number of wells, arsenic levels and a detailed
water quality analysis of a wide range of parameters for each location.
Well waters in similar regions can differ significantly. The water analysis
should consist of both basic values and special analysis for species that
have the potential to interfere with a treatment technology. For example,
vanadium is a species that affects ferric oxide arsenic adsorption. If the
water quality analysis reveals similar results to water previously tested
by the manufacturer, a pilot study could be deferred.
As 2006 rapidly approaches, do you have any words of wisdom for municipalities?
TC: Begin evaluating your arsenic removal treatment options today! If you have to lower arsenic concentrations to meet the January 2006 10 ppb MCL implementation deadline, it’s important to realize that the technology evaluation process can take up to two years to complete. The evaluation process can include treatment pre-qualification (3-6 months), technology selection review (3-6 months), pilot validation (0-12 months), full scale system procurement (4-6 months), installation and start-up of first system (3-12 months) and installation of remaining systems (6-9 months). A systematic approach to this process will ensure adequate time to meet the compliance deadline.
* Bayoxide E33 is a registered trademark of Bayer AG