Notice from the
American Water Works Association - Pennsylvania Section
Source: http://www.paawwa.org/legreg.shtml
October 23, 2007
Very important information for PA water suppliers
PADEP's Position on Possible Fluoride Shortages
Pennsylvania American Water
Company (PAWC) recently notified the Division of Operations Monitoring
and Training, as well as all DEP regional offices about a potential
fluoride shortage. PAWC's supplier notified the water company that they
will be severely limiting deliveries of Fluorosilicic Acid over the next
few months. The supplier stated that causes for the market balance are
as follows:
-
The U.S.
has noted unusually hot and dry conditions during the spring and
summer causing increased demand.
-
Producers
are close to anticipated volumes; however production has been
inconsistent and less than last year at this point.
-
Production
issues during the last half of 2006 depleted inventories,
resulting in current order patterns that suggest users are
attempting to replenish their inventories to the two-three month
levels that they normally attempt to maintain.
-
Some
phosphate plants are closed or have been idle during the last 14
months due to industry consolidation, reducing the Fluorosilicic
Acid supply at the source. Producers are evaluating additional
capacity at their existing plants.
The Centers for Disease Control
(CDC) has added a page to their web site specifically addressing the
temporary shortage of Fluoride. The Web site is:
http://www.cdc.gov/fluoridation/fact_sheets/shortages_faq.htm
This presents a potential problem
for water suppliers that have a permit to fluoridate and must meet
permit conditions stipulating optimum fluoride levels that must be
maintained in their distribution systems – generally 0.7 – 1.2 mg/L.
The question arose as to whether water systems that fluoridate should
cut back their levels to sub-optimum levels to conserve chemical, or
continue to fluoridate at permit-required levels and hope that they will
be able to replenish their inventories before they run out.
PA DEP’s position is that these
water suppliers should continue to fluoridate at the required permit
levels for two reasons:
-
If water
suppliers reduce the level, they could be voluntarily and
perhaps unnecessarily putting themselves in violation of a
permit condition, and the possibility exists that they might not
run out of fluoride anyway.
-
Based on
available literature, including a CDC table that displays
recommended levels based on average daily maximum air
temperature, the intended beneficial effect of fluoride at
sub-optimal levels (below 0.7 mg/l) is lost, so it might just be
a waste of fluoride.
If a water supplier runs out of
Fluorosilicic Acid, and they are unable to meet permit-required limits
due to extenuating circumstances beyond their control, the regions are
advised to use prudent enforcement discretion. Systems should not
incur a permit violation for failure to maintain fluoride levels if they
are unable to replenish their inventories due to the inability of
suppliers to fill orders within supplier-requested lead times.
Cessation of fluoridation is considered a water treatment process
interruption, so water suppliers that fluoridate are required to notify
DEP within one (1) hour and provide advance notice to their customers
regarding any pause and subsequent resumption of fluoridation.
Last modified: 24 November 2007
http://www.actionpa.org/fluoride/chemicals/shortagesandrisingcosts.html
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