Regulatory Update 2018 Daniel B. Horne, PE VDH – Office of Drinking Water Southeast Virginia Field Office VA AWWA Plant Operations Conference 4 May 2018 1
It’s Time for all Geeks to Celebrate!! 2
Goals • Provide an update on Rules or Regulatory Activities already in process • Provide some insight into what’s coming down the pipe (pun intended) 3
1. SDWA Regulatory Process From Steve Via, “Regulatory Update”, AWWA Webinar, Dec 2016 4
Setting a Regulation Under SDWA Section 1412 (b) (1), the Administrator of EPA is required to establish a national drinking water regulation if: • The contaminant may have an adverse effect on the health of persons; • The contaminant is known (or suspected) to occur with a frequency and in amounts of public health concern; and • There is a meaningful opportunity for health risk reduction. 5
Formal vs. Informal (Regulation vs. Guidance) EPA establishes “standards” in two ways: • Formal regulations • Maximum Contaminant Levels (MCLs) • Treatment Technique Requirements • “Informal” Guidance • Health Advisories • Other Guidance Documents 6
2. Unregulated Contaminant Monitoring Rule 4 • Final Rule published 20 Dec 2016 • Participating waterworks will monitor for: • 10 cyanotoxins (surface water systems only) • 2 metals • 3 brominated HAA groups • 8 pesticides and 1 byproduct • 3 alcohols • 3 SVOCs • 2 indicator chemicals 7
UCMR 4 Monitoring Some changes to the monitoring framework: • Monitoring is year-round, except for cyanotoxins (those are July – October) • Cyanotoxins – sampled at same time, but only analyzed sequentially (based on results) – no source water monitoring • Only do DBP monitoring if you monitor DBPs under existing rules. • Monitoring has already started 8
UCMR 4 Timeline From EPA , “UCMR 4 Stakeholders Meeting & Webinar”, Apr 2017 9
3. Cyanotoxins (the stuff that made Toledo famous) 10
Why Are We Concerned? • Neurotoxins (nerves) • Anatoxin, saxitoxin • Hepatoxins (liver, maybe kidney) • Microcystin, cylindrospermopsin • Dermatoxins (skin) • Reaction to many algal types • Adverse health effects can be through ingestion, inhalation, or skin contact 11
Current Status • No federal regulations covering drinking water • EPA issued Health Advisories for 2 toxins on 17 June 2015 • EPA also issued a Guidance Document • Several states have set threshold levels for toxins, several are moving to formally adopt a standard • These states and some others have formal HABs monitoring programs • ODW is developing HABs guidance 12
EPA’s Health Advisories • Issued on 17 June 2015 • 10-Day Health Advisory Values: • Microcystins and cylindrospermopsin • Exposure Pathway: oral ingestion of drinking water • Take necessary actions within that 10-day period chemical 10-day advisory Bottle-fed infants and young School-age children and adults children of pre-school age microcystins 0.3 µg/L 1.6 µg/L cylindrospermopsin 0.7 µg/L 3 µg/L 13
Potential Cyanotoxin Management Steps 14
Treatment for Cyanotoxins Intracellular Toxins and Extracellular Toxins Require different treatment processes 15
In-Plant Cyanotoxin Treatment Strategies 1. Remove intact cells first 2. Minimize pre-oxidation 3. Add (or increase) powdered activated carbon 4. Increase post-chlorination 5. Install permanent treatment upgrades 16
Some Things to Remember • Multiple species can produce the same toxin • Same species can produce multiple toxins • Brown water and Taste & Odor does not automatically mean toxins • Intracellular vs. extracellular 17
Suggested Resources • AWWA – Cyanotoxins Resource Community http://www.awwa.org/resources-tools/water- knowledge/cyanotoxins.aspx • Utility Managers Guide • Calculators • EPA – CyanoHABs page http://www2.epa.gov/nutrient-policy-data/cyanohabs • Health Affects documents • Guidance document 18
4. Perfluorinated (and Polyfluorinated) Alkyl Substances (PFAS) Potentially the next “Big Thing” in drinking water issues 19
PFAS • Perfluorinated (or polyfluorinated) chemicals are a family of fluorinated organic chemicals – two main types – PFCAs and PFSAs • Extensively produced and used in many applications – a few examples: • Firefighting foam (AFFF) • Clothing, carpet protection • Food wrap and microwave popcorn bags • Teflon (and similar coatings) • The best known examples are PFOA and PFOS • But…there are new compounds coming 20
Family Tree of PFAS There are hundreds of chemicals in the PFAS family, with various chain lengths and differing “add - ins” • Carboxylic acids • Sulfonic acids • “New shorter chain models” – “Gen X” versions 21
Why the Concern? • The carbon-fluorine bond is shortest & strongest chemical bond in nature • PFAS are persistent – don’t break down naturally and are hard to remove from water – can easily move into the food chain • Possible health effects currently indicated: • Developmental effects to fetuses or breast-fed infants • Thyroid, prostate, kidney, liver, and testicular effects (including cancer) • Immune effects (antibody production) 22
EPA’s Health Advisories • Lifetime Health Advisories issued 16 May 2016: • Covers PFOA , PFOS, and PFOA+PFOS – doesn’t address any of the other PFAS • Exposure Pathway: oral ingestion of drinking water by pregnant or lactating women • Protects the most sensitive populations • “Non -enforceable, non- regulatory” Chemical Advisory Level PFOA 70 ng/L (ppt) PFOS 70 ng/L (ppt) PFOA + PFOS 70 ng/L (ppt) 23
Exposure Routes 24
Are PFAS REALLY a Problem? • Harvard University study (published in Aug 2016) – 66 water systems – 6 million people – samples > 70 ng/L • June 2016 – Colorado – 3 cities – 80,000 people with PFCs > 70 ng/L (SW and GW) • May 2016 – New Hampshire – 50 public wells, 11 private wells – PFCs > 70 ng/L • May 2016 – Alabama – 8 cities (SW) – PFCs > 70 ng/L • Jan 2016 – Naval Landing Field Fentress (Chesapeake VA) – GW contamination > 70 ng/L • May 2017 – NASA Wallops Flight Facility (Accomack County VA) – GW contamination > 70 ng/L • 2005 – Ohio River Valley – OH & WV – numerous SW & GW sources (C8 – early name for PFOA) 25
PFCs Occurrence (early 2016) From Andrew Eaton, “ PFAS Monitoring in a Post- Advisory World”, AWWA WQTC, Nov 2016 26
What Should Waterworks Do? • Take steps to assess potential for contamination • Begin preparing to inform (develop messages and delivery methods) • VDH – both the Office of Drinking Water and the Local Health Department • Consumers • Look at possible steps to limit exposure • Change water sources (or the blend) • Treatment (GAC, IX, RO or NF) • Bottled water/home treatment 27
Suggested Resources • AWWA – Health Effects Community page http://www.awwa.org/resources-tools/water- knowledge/health-effects.aspx • PFCs Fact Sheets • Water Research Foundation • Research project reports, webinars, etc. (#4322, etc.) • EPA – PFAS page https://www.epa.gov/pfas • Basic information with links to additional pages for Health Advisories and other documents 28
5. Long Term 2 (LT2) Surface Water Treatment Rule The focus is on Cryptosporidium • Round 1 Source Water Monitoring is complete (ended mid-2012) • 174 sources monitored and evaluated • Only 8 were deemed in other than Bin 1 • All of these were Bin 2 • Seven are meeting Bin 2 via filtration performance • 2 UV units have been installed • 1 additional UV project under consideration 29
LT2 Source Water Monitoring Round 2 Crypto monitoring is now well underway 30
Impact of LT2 Rounds 2 Results • If results show stay in same Bin – OK • If results show move up a Bin – have to meet the requirements of the new Bin - VDH sets timeline EPA “Anti - Backsliding” Policy • This affects sources that were not Bin 1 following Round 1 monitoring • If sampling in Round 2 shows Bin 1 results, the source may NOT be reclassified from a higher bin into Bin 1, UNLESS something has changed in the watershed to improve water quality 31
6. Lead and Copper Rule (Life After Flint) 32
EPA’s Number 1 Priority 33
Quick Review of LCR • The LCR (original 1991 and revisions) substantially lowered levels through corrosion control • The Action Level for lead was not set to protect public health – it was set to demonstrate that corrosion control was working (along with meeting Water Quality Parameters) • EPA has determined a need to revise and update the LCR again – the Long Term Revisions 34
Sources of Lead 35
LCR Sampling Procedures - 1 EPA guidance (29 Feb 2016) – addressed tap sampling • EPA guidance (20 Oct 2006) – faucet aerators • Recommends homeowners routinely clean aerators, but… • DO NOT remove aerators prior to LCR sample collection • Pre-stagnation flushing • LCR requires a minimum 6-hour period of no use • DO NOT flush tap prior to that period 36
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