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NSF Standard 245 making waves in the wastewater treatment industry
By Lori Lovely
NSF International Standard 245 officially went into effect on April 14,2007, but the controversy surrounding it rages on. The Nutrient Reduction Standard has been in the works since early 2004, when a task group began developing a testing method for nutrient reduction along the lines of the NSF/EPA ETV Protocol. At this time, it focuses on nitrogen reduction; phosphorous reduction will be addressed at a later date.
Under the EPA, the ETV Source Water Protection Pilot Program (now the Water Quality Protection Center) was developed due to concern about drinking-water safety in light of much-publicized outbreaks of waterborne disease and a link to cancer. This arose from the impacts nutrients have on drinking-water sources and the environmental impacts resulting in eutrophication of surface waters. To address concerns about the protection of ground and surface waters from nutrient contamination as a result of onsite wastewater treatment systems, the EPA established guidelines for equipment verification testing for systems designed to provide for nutrient reduction.
But when the EPA cut funding for the ETV program, according to Adriana Mastronardi, business unit manager for the NSF wastewater treatment unit program, the NSF wastewater joint committee created a new standard based on the ETV protocol for nutrient reduction. NSF is a non-profit testing and certification organization. For 52 years, it has developed consensus standards to promote and protect public health and the environment, in addition to providing testing and certification services to ensure that products meet those standards.
“When funding was cut,” Mastronardi explains, “the EPA couldn’t supply manufacturer testing; the manufacturers no longer had financial aid from the government. They had to fund testing on their own. The necessity for Standard 245 arose from a regulatory need for a certification program, the benefits arising from certification, and the assurances that the systems being installed are the same as were tested.”
The new standard, which applies to manufacturers with products that have a capacity of 400 to 1,500 gallons per day, incorporates some changes from the ETV Protocol. The length of time for monitoring has been reduced from 12 months under ETV to six months under 245. The frequency of sampling has also changed: 245 requires sampling three days per week. An additional stress test has been incorporated. Total incoming nitrogen must meet a 50% reduction, with 35 milligrams per liter as a minimum concentration. Mastronardi notes that manufacturers must be Standard 40–certified already or complete certification for both standards simultaneously and follow the same dosing schedule.
The main difference between the Standard 245 and the ETV Protocol, Mastronardi emphasizes, is that Standard 245 contains pass/fail criteria, which are not included in the ETV Protocol. In addition, ETV has been considered a one-time test; modifications made to the treatment system after the testing was completed did not require NSF oversight. The new certification obligates a manufacturer to gain approval for any modifications completed after the certification process. In addition, there is continued surveillance of a manufacturer’s product through a certification program as opposed to a verification program in ETV.
The Debate
There was a need for Standard 245, Mastronardi believes, not only because funding for ETV ran out, but also because Standard 40 applies only to biological oxygen demand, total suspended solids, and solids, and many people are looking for more. “More states want nutrient removal,” she reveals. “More manufacturers ask for samples to be evaluated for nitrates, total nitrogen, and ammonia. Many states have new classifications and requirements for the performance of systems.”
According to Jason Churchill, a government relations representative at Orenco Systems Inc., an increasing number of regulatory jurisdictions are imposing tougher restrictions on effluent systems, due to concerns about ecological effects and a public health risk. He recently submitted a paper to the American Society of Agricultural and Biological Engineers about what he calls the “perceived health risks.
“There is an exaggerated concern due to misinformation about nitrate toxicity,” he says. “The health risk of nitrate in drinking water is not as it’s represented. The assumption is made that nitrogen will be converted to nitrate as it works through topsoil. You must make a distinction between professional literature and information published for the general public.”
Scheduled for publication in accordance with the Eleventh National Symposium on Individual and Small Community Sewage Systems (2007), Churchill’s paper challenges adoption of restrictive rules limiting nitrogen levels in effluent discharged to land from decentralized wastewater treatment systems. He claims the rules are modeled after federal drinking-water standards for nitrates, set at 10 milligrams per liter of nitrate-N. However, he interprets the federal drinking-water standard as a water-supply standard, requiring that water be treated, if necessary, in order to meet the targeted 10 milligrams per liter. In Churchill’s opinion, under the law that standard does not apply to private wells or wastewater treatment system effluent.
“Single-family residential septic systems and non-residential septic systems that are used solely for sanitary waste and have the capacity to serve fewer than 20 persons a day are specifically excluded from the Underground Injection Control requirement.” Churchill feels it is wrong to set restrictive, “highly conservative” nitrogen effluent limits based on drinking-water standards.
Churchill contends that the EPA adopted the standard in 1992 to prevent infant methemoglobinemia, noting that other health concerns (including a cancer link) have subsequently been raised and investigated.
Tom Kallenbach of Eliminite in Belgrade, MT, considers the standard “ridiculous” because “it doesn’t address the issue. I’d have no problems with NSF if they incorporated real-world applications, but the costs are off the scale.” Kallenbach, who admits he’s still “wrestling with NSF for approval,” says, “It’s like an exclusive club; you pay the money to get it. It costs about $13,000 to maintain. Bigger companies can do it, but we’re a tiny company—just a bunch of engineers. These systems aren’t cheap, but you don’t want it to be ridiculously expensive.” He believes the standard can be met by “almost anything. You can take a coffee filter to get a 50% reduction. It’s not a concern; it’s just ridiculous to spend $100,000 to hit 50% reduction.”
Classified as a Level 2 (highest treatment level) advanced onsite wastewater treatment system in Montana, Eliminite is a nutrient reduction system that removes nitrogen from wastewater. The all-in-one design, with septic tank, pump chamber, and filter in one tank, saves space. Using lightweight metarocks, a proprietary medium composed of a customized blend of polyurethane resins engineered to endure years of exposure to wastewater without degrading or becoming saturated, the system reproduces the property of sand to create a longer contact time between wastewater and media as well as better air flow to improve aeration and reduce clogging. “Finer media can be problematic,” Kallenbach explains. “It gets clogged easily, creating an anaerobic environment. Metarocks don’t degrade. There’s no need to pull out the media to clean it, and there’s no odor.”
Explaining the Nitrogen Connection
Nitrogen is a colorless, odorless, tasteless, non-flammable gas that makes up 78.09% (by volume) of the air we breathe. Forms of nitrogen include nitrate, nitrite, ammonia, ammonium, and total Kjeldahl nitrogen. Although it is an essential element in plant and animal growth, high levels of nitrate can become a pollutant and upset the natural balance of receiving water through a process called eutrophication.
New nitrogen isn’t being created; instead, nitrogen is being concentrated in certain areas. Sources of nitrogen include fertilizer, agriculture (particularly manure), stormwater, atmospheric deposition, drainage wells, and wastewater residuals. Synthetic nitrogen fertilizers are the most important source of nitrate contamination of groundwater in this country. Agriculture is another one of the most significant sources of nitrate in groundwater. Livestock farming that concentrates animals in one locale also contributes heavily to groundwater contamination.
Excess nitrogen in water can cause acute toxicity to most species of fish and stimulate plant growth to an unhealthy level, creating algal blooms. It leads to odors, accumulation of unsightly biomass, and dissolved oxygen depletion due to decay. Many municipal wastewater treatment plants are required to nitrify their effluent in order to avoid ammonia toxicity in receiving waters.
Its affects on humans can include contributing to the development of methemoglobinemia, or blue baby syndrome; birth defects and spontaneous abortion; early onset of hypertension; thyroid hypertrophy and non-Hodgkin’s lymphoma; and gastric, stomach, and esophageal cancer.
“Several scientific studies have shown a positive correlation between some types of cancers and nitrate intake in animals,” claims Roxanne Groover, the director of the Education, Public Relations, and Engineering Department for the Florida Onsite Wastewater Association, in a presentation titled “Effects of Nitrogen and Phosphorous.”
Nitrogen Levels Versus Blue Babies
Blue baby syndrome, or methemoglobinemia, is a condition in which an abnormally high percentage of the blood’s hemoglobin has been converted to an inactive form that is unable to transport oxygen. One of the most noticeable symptoms is a bluish discoloration of the skin and mucus membranes; thus, because infants less than six months old are particularly susceptible, methemoglobinemia has been nicknamed blue baby syndrome.
It gained public awareness in the 1940s, thanks to a report published by an Iowa physician named Hunter Comly. The report focused on infants from rural homes fed with formula prepared with well water. “They were sick from contaminated wells,” Churchill explains. “Their diarrhea was caused by internally produced nitrite from high levels of nitrates in the well water. But does drinking water even contribute significantly to the condition? The evidence indicates not.
“There has never been a demonstrated link between blue baby syndrome and nitrate in drinking water. There are all kinds of causes: It could be inherited; It could be caused by chemicals—antibiotics, topical anesthetics, or copper. There’s evidence that suggests infection causes it. There’s always evidence of diarrhea and/or bacteria-infected wells.”
According to Churchill’s research, nitrate doesn’t react directly with hemoglobin to form methemoglobin; however, it can be converted into nitrite by certain types of bacteria often found in the digestive tract. The nitrite oxidizes hemoglobin into methemoglobin.
He charges health officials with wrongly assuming that blue baby syndrome is caused by conversion of nitrate from drinking water into nitrite in a baby’s digestive tract. Calling it an outdated theory, he points to observations that suggest other factors are responsible—principally, fecal microorganisms that contaminate unsanitary wells.
Churchill substantiates his claims by quoting a 1995 report by the National Research Council, an arm of the National Academy of Sciences that found infection to be the major contributor to methemoglobinemia from nitrate exposure and considered the contribution of drinking water to be “negligible.” Instead, Churchill reiterates, methemoglobinemia “correlates closely with unsanitary wells and diarrhea, not nitrate concentration. There has never been a case of blue baby syndrome attributed to nitrates in the public water supply.”
In light of the lack of evidence linking nitrate and health risks, Churchill calls for a “more rational approach to setting effluent limits for wastewater treatment systems … that considers costs/benefits and recognizes factors that act to limit nitrogen buildup in groundwater.”
Ron Suchecki, general manager of Hoot Systems and committee member on Standard 245, acknowledges the controversy over blue baby syndrome but says it’s not the only issue in regards to Standard 245. “We had more pressing reasons to develop it. It’s a water-quality issue. We’re worried about the receiving environment and water degradation. Eutrophication is degrading surface and drinking waters.”
“Several scientific studies have shown a positive correlation between some types of cancers and nitrate intake in animals,” elaborates Groover. Although a cause and effect for risk of cancer has not been conclusively demonstrated, Suchecki suggests “safe” drinking water with 10 milligrams per liter of nitrate or less as a safety factor to prevent health risks.
Churchill’s research is at odds with Suchecki’s findings. Churchill maintains that no link between drinking-water nitrate exposure and cancer—or various other health issues—has been demonstrated. He credits better construction and placement of wells with the dramatic decrease in blue baby syndrome since the 1960s, not the establishment of a federal drinking-water standard in 1962, increased use of water filtration devices, public education, or reduced use of powdered baby formula.
The Battle Over Water
“People think they have to comply with a drinking-water standard,” Churchill states, “but it’s not proper to do so. They hide behind the EPA and the water-supply standard.”
He estimates that septic systems reduce nitrogen to 50 to 65 milligrams per liter. “Advanced treatment systems get it down to 10 parts per million. To get it to 10 milligrams per liter—drinking-water standard—costs more because you need an additional device to aerate and treat the water, special components, special design features, carbon feed because the bacteria need a fuel source, an anoxic compartment, and additional tankage for retention. The real worry is the increased cost of the system and maintenance. To go from 20 parts per million to 10 parts per million costs a big chunk, considering you’re not removing a lot more. We’re very concerned; we can build a system to do it, but is it the best use of money? You’re removing a little more nitrogen for a lot more cost. We could make money from the health scare, but we’re not sure it’s the best use of public money. Babies aren’t dying. There’s no evidence of adverse health effects. Resources are being squandered against the wrong culprit.”
“It’s not a drinking-water standard,” Suchecki responds. “Standard 245 is considered an addendum to Standard 40 that adds nitrogen. Standard 245 is a 50% reduction standard of the range of 35 milligrams per liter on influent, not a 10 standard [referring to the 10-milligram-per-liter drinking-water standard]. That’s more than the national drinking-water standard for prolonged exposure.”
Suchecki acknowledges the ongoing controversy regarding undefined health risks that are related to nitrogen pollution. Citing documented studies of twins in which elevated levels of nitrogen created early onset of hypertension, cancer, and thyroid problems, he emphasizes that the standard was developed in answer to environmental effects more than in response to health concerns. Health issues are “not why we focused on nitrogen reduction. It has to do with surface- or spring-water degradation.”
As an example, he indicates specific areas of Florida where spring protection is a hotbed of activity. “Some springs are severely impacted. There are areas already at 1 to 3 milligrams per liter.” Recommended is 0.1 milligram per liter. Predominantly due to overdevelopment, he says the problem stems from receiving areas that are too small for primary treatment [septic systems]. Some areas are concentrated with four to six homes per acre. There’s a demand for smaller lots: Less land equals smaller yards to maintain.” He believes zoning restrictions could police that, but that’s the kind of political move Churchill claims Standard 245 targets. “Some jurisdictions use restrictive standards for an agenda: to restrict growth. That’s using bad science to achieve a goal. It leads to mass hysteria and waste of taxpayer dollars. Common sense doesn’t get mileage if people don’t get the facts. That’s why we’re trying to get the word out and disseminate the facts. After all, it doesn’t benefit us to put this out there.”
“Companies who haven’t figured out how to solve the issue are against the standard,” Suchecki counters. “We can do it for a small additional amount. It can be an inexpensive add-on.” Hoot Systems has been in business for more than 30 years, focusing on the development of nitrogen reduction equipment for the last nine.
The Cost of Future Accordance
“Not all areas have problems,” Mastronardi recognizes. “Our main concern is using technology to a specific level in areas where there are concerns—areas where there’s already a high level in large bodies of water, several small bodies of water, or a high water table, for instance.” Of course, she adds, regulators choose whether to enforce the standard. “If the area is sensitive to nutrient loading, I would expect city or county regulators to rely on our data on how to handle it.”
Kallenbach believes “regulation will come. Some states require it now.” The issue, as he sees it, lies in educating the public that not all systems are the same. “You can state all the altruistic reasons in the world, but everyone is in business to sell products.”
Churchill claims there are currently no regulatory jurisdictions requiring adherence to the standard and therefore it doesn’t affect Orenco. Orenco Systems Inc. designs and manufactures advanced onsite (decentralized) wastewater technology for individual properties and small communities that aren’t on central sewer systems.
As Suchecki notes, without standards, regulators don’t have a benchmark by which to approve products. But Standard 245 gives people a basis for implementing programs aimed at protecting and preserving the water supply. “Not everyone needs it. There’s no fear of the standard being mandated everywhere. It’s for use only in the most sensitive areas.”
Nevertheless, Suchecki believes the standard is a step in the right direction at a time when it’s needed more than ever. “All the good land is gone. We’re using spoiled farmland or land we wouldn’t have used before. More obscure pieces of land are being developed.”
Again, Kallenbach concurs. “There’s an exodus of people leaving cities.” Unfortunately, he continues, that has led to a proliferation of decentralized systems, which, in his opinion, require creativity to maintain. He considers onsite systems very personal. “People don’t want someone monkeying around in their septic system. They don’t want a team of engineers to have to dial up on the Internet to monitor the system. Online calculations are onerous. There’s a move to simple. A system has to be simple and reliable.”
As stated in the protocol, “The primary reasons for nutrient reduction are to protect water quality for drinking water purposes, as there is a drinking water standard for nitrite and nitrate, and to reduce the potential for eutrophication in nutrient-sensitive waters by the reduction of nitrogen and/or phosphorous.”
But Churchill thinks the standard goes too far. “The standard is the same,” he insists. “It’s the drinking-water standard, but now it’s applied to other water.” Churchill considers the nitrate drinking-water standard to be overly conservative, writing, “It is generally recognized that the evidence for any link between drinking water nitrate and health effects is at best weak and un-reproduced. For that reason, most authorities understand that the government’s maintenance of the 10 mg/L nitrate-N drinking water standard is not based on persuasive evidence of health risk, but rather on acceptance of the standard as a ‘prudent measure’ to protect infant health.”
He suggests that the 10-milligram-per-liter standard is based on a “hierarchy of assumptions” that nitrate health risks are real, that nitrate is not attenuated in the subsurface environment, and that cost-effective technology is available to achieve the additional nitrogen removal needed to meet the restrictive limits. “There needs to be a proper cost-benefit analysis,” he elaborates. “In fact, the EPA is required to do one, under the Safe Drinking Water Act, and compare it with the expected health benefits. The cost must be justified to be prudent. It’s not fair to use a drinking-water cost analysis on wastewater effluent. It’s cheaper to remove nitrates from drinking water than from wastewater.”
Churchill says sensible standards would take into consideration the cost to the consumer, long-term maintenance requirements, and the expected life of a system. “It should also be recognized that treating groundwater to comply with the federal drinking-water standard, as required for water suppliers, is probably considerably less expensive than treating wastewater.” He complains that “agencies with restrictive nitrate limits usually make no allowance for nitrogen removed by denitrification in the soil—an approach that in effect disregards an important component of the treatment process.”
Kallenbach believes that Standard 245 focuses on nitrogen because “if you’re getting nitrogen out as it moves through the soil to groundwater, you’re probably getting everything else out. Nitrogen is merely an indicator.” However, he agrees that onsite wastewater is a complicated issue, even for regulators, who “don’t think about costs and maintenance.”
Some areas are currently trying to remediate groundwater due to contamination by septic tanks and wastewater, Suchecki says. “Different nutrients affect the water. Water is limited by nitrogen or phosphorous on receiving levels. One or the other is out of balance. The ETV Standard was developed in the mid- to late-’90s to address concerns about nitrogen and phosphorous levels.” Indeed, reduction of nutrients, principally nitrogen and phosphorous, has been an issue since the 1960s in areas where nutrient reduction was necessary to protect the water quality.
Suchecki says there’s a small demand for nutrient reduction systems but says people are willing to pay the difference to protect the environment. “The general population is more receptive. As we move into environmentally sensitive areas, there’s more worry about degradation. People want to preserve the view or the pristine nature of the area; it’s why they moved there, so they want to protect it.
“If we maintain our current discharge levels into the environment,” he continues, “we can’t add any more. For further development, we must reduce the concentration of the new systems we’re adding. Future treatment systems will have to be better. We must do our part or people will get rid of onsite systems everywhere.”
Residing in Indianapolis, IN, Lori Lovely writes authoritatively on transportation and technical subjects.
OW - July/August 2007 |
