CCL, UCMR, Monitoring Results, and Development of Regulations AWWA PA Section /

Transcription

1 CCL, UCMR, Monitoring Results, and Development of Regulations AWWA PA Section / WWOAP Conference Exton, PA April 7, 2016 Charles D. Hertz, Ph.D.

2 Drinking Water Regulations Outline Development of regulations Plans set forth in SDWA Systematic approach Other avenues Definition of terms UCMR data national local

3 Drinking Water Regulations Regulatory Development Process Prior to 1996 SDWA amendments 25 new MCLs every 3 years After 1996 SDWA amendments Outlined process for Contaminant Candidate List (CCL) Unregulated Contaminant Monitoring Rule (UCMR) Regulatory Determination Health Advisories systematic, science-driven process

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5 2001 publication National Academies Press

6 Contaminant Candidate List Used by EPA to identify priority contaminants for regulatory decision making and information collection Known or anticipated to occur in drinking water Must be published every 5 years Wish list SDWA defines "contaminant" as any physical, chemical, biological or radiological substance or matter in water

7 Unregulated Contaminant Monitoring Rule Allows EPA to collect data on parameters suspected to be present in drinking water Occurrence data Up to 30 parameters Suitable analytical method List 1: assessment monitoring List 2: screening survey List 3: pre-screen testing

8 Three Criteria Required in SDWA Regulatory Determination 1. The contaminant may have an adverse effect on the health of persons 2. The contaminant is known to occur or there is substantial likelihood the contaminant will occur in public water systems with a frequency and at levels of public health concern 3. In the sole judgment of the Administrator, regulation of the contaminant presents a meaningful opportunity for health risk reductions for persons served by public water systems EPA is not limited to making regulatory determinations from CCL

9 Drinking Water Regulations Six Year Review: primary standards First 6-year review: 2003 Candidate for revision: Total Coliform Rule No revision: 68 chemical MCLs Second 6-year review: candidates for revision, 2010 acrylamide epichlorohydrin Tetrachloroethylene (PCE) Trichloroethylene (TCE)

10 systematic, science-driven process

11 Criticism of regulatory development process Too slow overly systematic overly science-driven Few new standards Few candidates for review Low rate of occurrence UCMR rounds have had questionable impact Not much to show

12 EPA drinking water strategy 2011 Purpose: streamline decisionmaking and expand protection under existing laws and promote cost-effective new technologies groups

13 EPA Drinking Water Strategy Goal 1. Address contaminants as groups rather than one at a time so that enhancement of drinking water protection can be achieved costeffectively. Goal 2. Foster development of new drinking water technologies to address health risks posed by a broad array of contaminants. Goal 3. Use the authority of multiple statutes to help protect drinking water. Goal 4. Partner with states to develop shared access to all public water systems (PWS) monitoring data.

14 Groups Identified for Potential Regulation Carcinogenic VOCs Up to 16 cvocs Projected in 2018 Nitrosamines Disinfection by-products

15 Headlines in the news can impact regulations Cryptosporidium Milwaukee, 1993 Hexavalent chromium EWG, 2010 Cyanotoxins Toledo, 2014 Lead Flint, 2015 Can by-pass systematic process

16 Ohio EPA proposed rule Harmful Algae Bloom

17 Cr 6 added To UCMR3

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19 Sometimes the systematic, science-based process can be by-passed Microcystins / cyanotoxins Cr-6 Strontium, Chlorate

20 Although not part of regulatory process, Health Advisories can be important

21 informal technical guidance

22 Health Advisory table informal technical guidance

23 Health Advisories Provisional Health Advisories Exist for just two compounds PFOS: 0.2 ug/l PFOA: 0.4 ug/l UCMR3 data Impact on at least three local water systems Provisional Health Advisory for PFOS became defacto acute MCL

24 Review of UCMR Data

25 UCMR1 2,4-dinitrotoluene 2,6-dinitrotoluene Acetochlor DCPA mono-acid degradate DCPA di-acid degradate 4,4'-DDE EPTC Molinate MTBE Nitrobenzene Perchlorate Terbacil DCPA was most frequently detected parameter on UCMR1 MTBE and perchlorate: low rates of occurrence

26 nitrosamines UCMR2

27 NDMA was key parameter detected in UCMR2

28 UCMR3 Data Unlike previous UCMRs, Most parameters detected Strontium Chromium Chromium 6 Vanadium Molybdenum Chlorate

29 UCMR3 Data Compared with previous UCMRs many organic parameters detected 1,4-Dioxane HCFC-22 Halon ,1-Dichloroethane Chloromethane PFOA PFOS 1,2,3-Trichloropropane

30 UCMR3

31 UCMR3 Unlike previous rounds, UCMR3 had many parameters detected (hits)

32 UCMR3 For PFOS and PFOA Reference Concentration = Provisional Health Advisory

33 UCMR3

34 Sample coolers for UCMR3

35 Aqua PA Bristol CCR Utilities needed to devote significant space in Consumer Confidence Reports for UCMR3 data Unregulated Contaminants Detected During 2013 and Average Range of Unregulated Contaminant Detection Detections MCL 1,4-Dioxane, ppb ND ND NA Perfluorooctanoic acid, ppb ND ND NA Chlorate, ppb 135 ND NA Chromium, ppb ND ND NA Hexavalent chromium, ppb NA Strontium, ppb 98 ND NA Molybdenum, ppb ND ND NA Vanadium, ppb 0.27 ND NA 8 parameters detected

36 Aqua PA Main System CCR Unregulated Contaminants Detected During 2013 Unregulated Contaminant Average Detection Range of Detections MCL 1,1-Dichloroethane, ppb ND ND NA 1,4-Dioxane, ppb ND NA 1,2,3-Trichloropropane, ppb ND ND NA Chlorate, ppb 122 ND NA Chromium, ppb 0.20 ND NA Hexavalent chromium, ppb 0.28 ND NA Molybdenum, ppb ND ND NA Strontium, ppb NA Vanadium, ppb 0.46 ND NA 9 parameters detected

37 Horsham Water and Sewer Authority CCR Unregulated Contaminants Detected During Results in ppb. Average Range of Unregulated Contaminant Detection Detections MCL Perfluorooctane sulfonate (PFOS) 0.06 ND - 1 NA Perfluorooctanoic acid (PFOA) ND ND 0.29 NA Perfluoro 1-butanesulfonic acid ND ND 0.11 NA Perfluoro 1-hexanesulfonic acid ND 0.59 NA Perfluoro heptanoic acid ND ND NA 1,4-Dioxane 0.07 ND 0.57 NA 1,1-Dichloroethane ND ND NA Chlorodifluoromethane ND ND NA Chlorate 34 ND NA Chromium 1 ND - 30 NA Hexavalent chromium 0.08 ND 0.27 NA Cobalt ND ND 1.5 NA Molybdenum 2.8 ND 9.6 NA Strontium ,820 NA Vanadium NA 15 parameters detected

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39 UCMR4, likely issues Cyanotoxins Analytical methods Monitoring Interpretation of data Communication with customers Brominated haloacetic acids

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41 Example Calibration Curve Detector Response ` Concentration Minimum Reporting Level

42 Problem: ELISA method MRL is same concentration as Health Advisory Results less than MRL are reported as Not Detected Detector Response ` Effectively becomes a Concentration Presence / Absence Test MRL = HA for microcystins ELISA does not have linear calibration

43 Regulatory Determination: requirements Adverse health impact Occur in drinking water Meaningful opportunity for risk reduction

44 Regulatory Determination 3 No regulation needed for Dimethoate 1,3-dinitrobenzene Terbufos Terbufos sulfone Delay in decision for Strontium Preliminary Yes Oct Final Maybe Jan Delay

45 Standards under review Chromium / hexavalent chromium Prior to UCMR3 Perchlorate: 2011 projected rule 2017 Preliminary regulatory determination, 2008 do not regulate Final regulatory determination, 2011 regulation warranted

46 Drinking Water Regulations Summary Regulatory Development In principle, systematic and science-driven Process can be derailed Potential improvements have been suggested UCMR process can be costly Especially for water systems with many entry points EPA will be under pressure to show something for the efforts

47 Charles Hertz April 7, 2016