Comment Submitted by
Richard Carrier
2008-04-16 07:33:25
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3.2.1.1 Incoming shipments of media to be regenerated/reactivated
The following information shall be provided by the water system and maintained by the processing plant for each shipment of spent media received for regeneration/reactivation:
– Identification of the type of the spent media, spent media source, and application of use (e.g. production of drinking water);
– Identification of the original media, including manufacturer, trade designation, mesh size and NSF/ANSI 61 compliance for each spent media source;
– Primary contaminants removed from water, including any contaminant spills or unusual water quality conditions;
– Statement as to whether the spent media has been knowingly exposed to:
o Activated carbon: polychlorinated biphenyls (PCBs), dioxins or 1,2 dibromo-3chloropropane (DBCP);
o Other media: herbicides, pesticides, polychlorinated biphenyls (PCBs), dioxins or 1,2 dibromo-3chloropropane (DBCP);
– Statement to verify that the spent media source is from a public water system (publicly or pri-vately owned) as defined by US EPA or applicable regulations.
7.3.3 Additional requirements for reactivated/regenerated media
Only reactivation/regeneration facilities and equipment used to handle spent and reactivated/regenerated media, classified as potable and/or food grade, shall be used. Transportation containers shall be suitably protected from environmental contamination and suitably cleaned, by evidence of wash-out tickets that are presented to the purchaser or certifying agency on demand.
Comment: This can be construed as a certification issue/requirement and thus should not be in the standard. It should be framed as quality assurance/quality control requirements if that is the intent.
Samples from each reactivated/regenerated batch of media shall be retained at the facility for a period of at least 2 years, and be made available for analysis by the purchaser or a certification organization. Re-tained samples shall contain at least twice the weight in table 7.2.
Commingled spent media shall be of comparable type and function.
Transportation containers are shall be suitably protected from environmental contamination and suitably cleaned prior to use. (this is a requirement and the wording needs to match the last sentence of first para in 7.3.3 )
Reactivation/regeneration facilities shall have written verification from each water system that each ship-ment of spent media to be processed meets the following criteria.
- The spent media shall only have been used only for drinking water applications;
- The spent media shall not be is not a RCRA hazardous waste as defined by 40CFR Part 261;
- The spent media is not classified as a hazardous waste in the facility’s state or province or territory; (Note: Canada has provinces and territories)
- The spent media shall not have knowingly been exposed to:
– Activated carbon: polychlorinated biphenyls (PCBs), dioxins or 1,2 dibromo-3chloropropane (DBCP);
– Other media: herbicides, pesticides, polychlorinated biphenyls (PCBs), dioxins or 1,2 dibromo-3chloropropane (DBCP);
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