Sodium Hypochlorite Regulatory Considerations – Continued

Further to my blog of November 15, following is addtional information related to the regulatory threshold levels that are being considered for the future.  Please note that none of this is finalized, however, these are some of the contaminants and thresholds that are being considered.

-Mark Nelson

The following are the current or proposed regulatory actions or regulations for each of the three contaminants or byproducts:

  1. Bromate. The maximum level of bromine allowed in sodium hypochlorite is expected to be reduced to a level of about 39 ppm by January 2013.  Currently, 69 ppm of bromated is the maximum contaminate level allowed in sodium hypochlorite.  Because bromated is produces in the ozonation process, the use of ozone in the treatment process may be reconsidered.
  2. Perchlorate. Several states have established regulatory limits for perchlorate in drinking water.  Standard 60 is expected to have a perchlorate limit established by January 2013.  The U.S. Environmental Protection Agency has an advisory 15 ppb of chlorate per
    liter of water, but there is no deferral regulation for percholate in drinking water at this time.  California has a maximum allowable level is 6 ppb; in Massachusetts’s, the maximum allowable is 2 ppb.  New Jersey has a proposed maximum contaminant level of 5 ppb.
  3. Chlorate. Limits are being considered for addition to Standard 60, with a target date of January 2013.  No current federal regulations have been used for chlorate.  Canada currently has maximum allowable contaminant level of 1 ppm for drinking water.

CASE STUDY: Sodium Hypochlorite Dilution

Location: City Corporation, Russellville, AR

Engineers: Garver, USA

Written by:    Michael Donn, Force Flow

The Water Treatment Plant in Russellville, Arkansas, is operated and maintained by City Corporation. It rests on the edge of Lake Dardanelle, just about 100 yards from the dam that separates the lake from the beautiful Illinois Bayou. The issue arises with the public access for fishing, allowing people within 20 yards of the water treatment facility. With the heightened security awareness of the world we live in, the staff of City Corporation realized that chlorine gas could possibly be a safety concern for the personnel at the Water Treatment Plant, as well as for the general public in the surrounding area. After researching alternative disinfection methods, Sodium Hypochlorite was determined to be the best solution.

Like buying orange juice and detergents, water treatment chemicals are almost always less expensive to purchase in higher concentrations. Unfortunately, this introduces a new set of issues to deal with. Sodium Hypochlorite degrades rapidly with heat, sunlight, and time. Also, feeding high strength Hypo into process water can create problems for the water treatment operator. These problems may stem from things like extremely low feed rates, chemical off-gassing, hard process water and safety or regulatory concerns in handling high strength chemicals. An innovative engineer, along with the progressive staff of City Corporation, set out to solve these problems with a chemical dilution system that met both their budget and design criteria.

The Project
Early in 2005, City Corporation contracted Garver Engineers in Little Rock, AR to design a Sodium Hypochlorite facility for their main water treatment plant. Garver Project Engineer, Kyle Breckenridge & Senior Project Manager Ron Pierce, teamed up with key personnel from City Corporation, Craig Noble, General Manager, Larry Collins, Operations Manager, and Jonathan Shipley, Lead Operator, to create a state of the art water treatment facility, that would meet the current and future needs of City Corporation. The end product of this collaboration was a safe, reliable and cost effective Sodium Hypochlorite dilution and feed system.

Merlin Sodium Hypochlorite Dilution SystemSafety & maintenance concerns from using high strength Hypo (12% Sodium Hypochlorite)
Garver knew that chemical suppliers typically deliver Hypo in the range of 12-12.5% chemical strength. Although it is far more cost effective to purchase this chemical in the higher strengths, Hypo degrades rapidly when stored in high strength. The degradation rate that Hypo would experience during the hot Arkansas summers, was something that needed to be addressed. Considering the degradation issue, as well as the safety concerns Garver and City Corporation had about operating and servicing a chemical feed system with high strength Hypo, a creative solution was needed. It was therefore decided to feed low strength Hypo in the range of 6% concentration, or less.

Buy chemicals, not water
In order to feed low strength Hypo, City Corporation had three choices:

(1) purchase low strength Hypo which is mostly water

(2) manually dilute high strength Hypo when it arrives on site

(3) devise an automated chemical dilution system to reduce the Hypo strength on site.

Option (1) (buying diluted Hypo) was quickly disregarded when they realized that purchasing pre-diluted chemical would be far too costly due to the transportation costs for shipping a product that is mostly water. Option (2) (manual dilution) was disregarded because it was labor intensive, could potentially produce inconsistent results, and would further expose operators to the dangers of high strength Hypo. It was therefore decided to go with an automated dilution system.

The system
As built, the system has two 5250 gallon tanks for storing the Hypo as it comes off the truck. This Merlin Dilution System (MDS-500D) utilizes a 500 gallon dilution tank, and is capable of creating approx. 1500 gallons of dilute per hour. After the Hypo is diluted it is pumped into one of nine 5250 gallon tanks to be stored until needed. With the current storage capacity of over 47,000 gallons, they have the equivalent of over 23,000 pound of liquid chlorine available. At the present time this facility has the ability to treat over 19 MGD.

Weight based batching system
Having used weighing systems to monitor chemical tanks in the past, Garver Engineers knew that a weight based system would be extremely accurate and reliable. They therefore contacted Force Flow Inc in Concord, CA in regards to providing a weighing system and controller that would allow Hypo and water to be automatically batched into a dilution tank by weight.

The most important design criteria were:

(1) Diluting the Hypo in a short period of time, so that it would not begin degrading in the heat of the summer.

(2) The ability to dilute an entire truckload of 12% Hypo with the push of a single button.

(3) The ability to accommodate different starting and ending solution strengths,

(4) System accountability through inventory control and process alarms

(5) Accuracy and consistency of the diluted chemical strength

(6) Safety & Redundancy in the event that the dilution system should fail.

Merlin Dilution ControllerAny strength at the touch of a button
With prior experience in designing dilution systems, Force Flow was able to accommodate all of City Corporation’s needs through some minor changes to existing hardware and software. Force Flow’s Merlin Dilution System automatically calculates the necessary amounts of water and Hypo based on the chosen beginning and ending chemical strengths. The system was designed for the operator to easily accommodate different “neat” (beginning) Hypo strengths at will. If City Corporation changes chemical suppliers or if their current supplier changes the strength delivered, they can easily accommodate this at the touch of a button. Additionally, it is just as easy to change the diluted (ending) strength of the Hypo. If process conditions change or the operators need to fine tune what strength is easiest to feed to their water stream, they can do so at the touch of a button. Another benefit to this flexibility is the fact that they can keep their metering pumps operating in their “optimum” range simply by adjusting the chemical strength.

Inventory control & process alarms
Because many state and federal agencies require the tracking of chemical usage, detailed accounting was extremely important. By tracking nine different variables such as chemical usage, feed rates and remaining chemical quantities, the Merlin dilution controller is able to give City Corporation a full accounting of their chemical feed and dilution process. In addition, by tracking throughput and using timers to track the dilution process, six different process alarms give operators early warning of potential problems with their Hypo feed system.  Remote monitoring of chemical feed rates and remaining chemical supplies is accomplished through 4-20ma signals back to the operators control room.

Conclusion
City Corporation’s concerns about chemical degradation were alleviated through feeding a low strength Hypo solution. By devising an automated onsite chemical dilution system, they were able to avoid the cost of purchasing pre-diluted chemical, eliminate the operator contact with high strength chemicals, as well as the labor and safety concerns that manual dilution would demand. They also avoided potential maintenance problems due to scaling and off-gassing. They also have the added features of integrated inventory control and process alarms to make their system safe and reliable for many years to come.

Noteworthy accomplishment
Garver received the prestigious ACEC of Arkansas Engineering Excellence Award for Water and Wastewater for the Sodium Hypochlorite Facility, in Russellville, Arkansas.

Michael Donn is the Manager of Product Development for Force Flow Inc. in Concord, CA. For more information on this case study or other chemical dilution systems, he can be contacted at 800-893-6723 or michael.donn@forceflow.com.

New Drinking Water Standards May Target Hypochlorite Contaminants

Following is a Chlorine Chemistry Council  summary of a recent article in Waterworld Magazine that discusses potential regulation of hypochlorite contaminants in drinking water.  If these changes to NSF Standard 60 are implemented, it may make it more difficult for some sodium hypochlorite sources (including onsite generators) to meet federal drinking water standards.  The article suggests that, in some cases, mitigating the regulated contaminants may be acheived by a switch to chlorine gas which does not produce these contaminants.  Both the NSF standard and subject article are available by clicking the below links.  Contact: Mark Nelson, Force Flow 800-893-6723

“Changes to the NSF/ANSI Standard 60 for drinking water may impact the use of sodium hypochlorite in drinking water systems, reports Waterworld.com (November issue). “New rules are being considered for the contaminates bromate, perchlorate and chlorate, all of which can be traced to sodium hypochlorite,” states the publication; “new changes that can impact the disinfection process are anticipated to be effective in the year 2013.” By January 2013, the maximum contaminant level (MCL) for bromate in sodium hypochlorite is expected to be lowered from the current level of 69 ppm to around 39 ppm, with a perchlorate limit also expected to be established, notes  Waterworld.com. The publication points out that “the EPA has an advisory of 15 ppb of [per]chlorate…but there is no deferral regulation for perchlorate in drinking water at this time. California has a maximum level of 6 ppb and in Massachusetts the maximum allowable is 2 ppb for perchlorate. New Jersey has a proposed MCL of 5 ppb.” For chlorate, Waterworld.com notes that “limits are being considered for addition to Standard 60 with a target date of January 2013. No current Federal regulations have been issueed for chlorate. Currently Canada has guidelines established for drinking water for a MAC [Maximum Acceptable Concentration] of 1 ppm.” CCD and the Chlorine Institute are working with member companies to advocate for science-based product standards for bleach. Contact: Mary Ostrowski, (202) 249-6705.”

Database On Various Chemical Feed Regulations

Information regarding the various State requirements relating to chemical inventory management & use can now be found at http://www.forceflow.com/regs/default.html.  Force Flow has collected a wealth of information relating to the various State regulations, recommendations and guidelines that govern the use of scales and other devices used to document daily chemical usage and inventory.  Among others, you will find specific information on the 10 States Standard as it relates to documenting daily chemical inventory and usage.  This database is particularly useful for consulting engineers and equipment distributors whom are selling or designing projects in multiple states.

Force Flow website now available in multiple languages

Visitors to our website will see that we have added a Google translation feature to our homepage and product pages.  Simply click the “select language” drop down menu and select the preferred language.  Although the Google translation feature is not perfect, it does a reasonable job at making our product information more accessible to our overseas customers and non English speaking domestic customers.  Please go to www.forceflow.com for more information.

Force Flow to Exhibit at WEFTEC 2011

As we have for over 40 years, Force Flow’s sales and marketing staff will be attending the upcoming WEFTEC conference and exhibit in Los Angeles CA.  From October 17-19, Force Flow will have all of our new and existing products on display in Booth 1733.  This is a great opportunity to come by and meet some of the staff face to face, as well as get aquainted with products that you may not be familiar with.  Whether you used our equipment for years, or are new to the industry, we encourage all attendees to come by to learn more about our Chemical Inventory management solutions!

WEFTEC Conference Hours

Force Flow Booth Number: 1733

Monday, October 17:  9-5

Tuesday, October 18:  9-5

Wednesday, October 19:  9-5

CFATS Extension Approved By House Committee, Moves To Senate

Good news for those who are using or plan to use chlorine gas to disinfect.   Below is an update from the Chlorine Chemistry Council on the pending CFATS reauthorization.  The Chemical Security Anti Terrorism Standards (CFATS) if reauthorized in it’s current form will continue to exempt water  plants who are using chlorine gas to disinfect.  Water plants were required under a separate law after 9/11 to secure the perimeter of their plants and it is our opinion that CFATS would unnecessarily duplicate this effort.  -Mark Nelson, Force Flow

The House Committee on Homeland Security has approved by a bipartisan 26-5 vote legislation that would extend the Chemical Facility Anti-Terrorism Standards (CFATS) program (Chemical & Engineering News, June 27). The bill (H.R. 901) would give the Department of Homeland Security seven additional years to fully implement CFATS, which began in 2007, states C&EN. E&E Daily (June 28) quotes industry sources as saying that legislation to reauthorize CFATS is now expected to “sail through a Senate committee markup” on June 29. The Senate Homeland Security and Governmental Affairs Committee will vote on a measure (S. 473) from ranking member Susan Collins (R-Maine) that would reauthorize CFATS for three years, notes E&E Daily. The newsletter writes that ACC’s Scott Jensen “applauded Collins’ bill, which is co-sponsored by Sens. Mary Landrieu (D-LA), Rob Portman (R-Ohio) and Mark Pryor (D-AK). ‘We clearly support the approach of Senator Collins’ bill and really commend her on her leadership to pull together bipartisan support in the committee,’ Jensen said.” Contact: Jeff Sloan, (202) 249-6710.

Force Flow Website Adds Chemical Safety Information

New to the Force Flow website are resources & facts related to the safe use and handling of Chlorine Gas, Fluoride and Sodium Hypochlorite.  From any page, go to the “download” tab, then scroll down to  “Chemical Safety Info” where you will have access to various documents that you may download for future use.  Included on these pages is information related to facility design, safety tips, safety handbooks, helpful websites and various other documents.

Unique to these pages you will find an accident database & analysis that gives the historical realities of incidents related to the use of  disinfection chemicals in water treatment.  Sodium & Calcium Hypochlorite are widely considered to be “safer” when compared to chlorine gas; however, this is not necessarily the case.    As with chlorine gas, good safety practices must be taken with sodium/calcium hypochlorite in order to protect workers and the surrounding community. This especially relates to preventing the unintended mixture with other chemicals which can lead to hazardous chlorine gas releases.

Fluoride Safety: http://www.forceflow.com/downloads/fluoride_safety.html

Hypochlorite Safety: http://www.forceflow.com/downloads/sodium_hypochlorite_safety.html

Chlorine Safety: http://www.forceflow.com/downloads/chlorine_gas_safety.html

Chemical Security Legislation update

Below is an update from the Chlorine Chemistry Council regarding the latest on CFATS reauthorization.  CFATS is the chemical security legislation enacted a number of years ago to secure chemical facilties from the possibility of a terrorist attack.  Chlorine gas facilities at Water treatment plants were exempted in the initial temporary law because they were covered by the Bio Terrorism Act of 2002 which required plants to secure their perimeters.  To avoid duplicative regulation, the Chlorine Chemistry Council supports Republicans who are pushing for an extension of the current law that would continue to exempt chlorine gas use at water plants.

- Mark Nelson May 10, 2011

House Democrats To Press For CFATS To Cover Water Treatments Plants:

House Democrats say they will push the House energy and transportation committees to subject drinking water and wastewater facilities to the Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS), reports Inside EPA (April 15).  The move comes “after Republicans on the Homeland Security Committee rejected an amendment mandating a new EPA program to require security rules at the treatment facilities on par with similar requirements at other facilities,” writes the newsletter.

During an April 14 markup of H.R. 901, which would authorize the CFATS program for seven years, a House Committee on Homeland Security panel rejected an amendment allowing EPA to apply CFATS to drinking water and wastewater facilities, notes Inside EPA.  The amendment was offered by the panel’s ranking member, Rep. Yvette Clarke (D-NY), who told Inside EPA that “working with the other relevant committees is ‘the next step we’ll have to take, obviously.’”  The House Committee on Energy and Commerce is poised to mark up its bill, H.R. 908, also extending CFATS by seven years, says the newsletter; “currently, the energy committee could have the upper hand in any jurisdiction fight because H.R. 901 is set to be referred to the energy committee, but H.R. 908 would not need to be referred to the homeland security panel.”

In the Senate, among several bills on CFATS, industry “supports Sen. Susan Collins’ (R-ME) bill, S. 473, to extend CFATS through 2014. Collins’ bill would not address the water facilities exemption.” The newsletter says that “regardless of how or whether water facilities are addressed…sources say the bills will most likely not include any mandate that facilities subject to security rules adopt inherently safer technology (IST)…which can require facility changes to reduce risks, for example requiring companies to switch from chlorine to a substance that would pose less of a health risk if released following a terrorist attack.”

- Chlorine Chemistry Council April 20, 2011

Force Flow to Exhibit at AWWA 2011

As we have for over 40 years, Force Flow’s sales and marketing staff will be attending the upcoming AWWA ACE conference and exhibit in Washington DC.  From June 12-15, Force Flow will have all of our new and existing products on display in Booth 1117.  This is a great opportunity to come by and meet some of the staff face to face, as well as get aquainted with products that you may not be familiar with.  Whether you used our equipment for years, or are new to the industry, we encourage all attendees to come by to learn more about our Chemical Inventory management solutions!

AWWA Conference Hours

Sunday, June 12:  3-6

Monday, June 13:  9-5

Tuesday, June 14:  9-5

Wednesday, June 15:  9-12