Emerging Regulations and Water Quality Concerns

Transcription

1 Emerging Regulations and Water Quality Concerns October 22, 2013 Keith Cartnick Sr. Director Water Quality and Compliance United Water 1

2 Today s Speaker Keith Cartnick Senior Director of Water Quality and Compliance, United Water New Jersey Keith Cartnick is a past Partnership for Safe Water Steering Committee member, serving as the National Association of Water Companies (NAWC) representative from Mr. Cartnick has a BS in Chemistry and MS in Environmental Science as well as more than 30 years of experience in the environmental field. His background includes compliance with drinking water regulations; optimization of water treatment plant operations to improve water quality; and oversight of United Water s Haworth Laboratory. He is also responsible for more than 80 water and wastewater companies throughout the US on matters pertaining to environmental compliance and drinking water regulations and has worked with the USEPA and the American Water Works Association (AWWA) on matters associated with safe drinking water. 2

3 Enhance Your Webinar Experience Close , instant messenger, other programs not in use Go to Webinar support: Attendees are muted but we do want to hear from you! Ask questions using the Question Pane at the lower right hand side of your screen Specify your name when submitting questions Keith will periodically stop to address attendee questions 3

4 Just so that you are aware The regulatory information contained in this presentation is based on USEPA information. Please consult your local regulatory agency for any additional details that may be specific to your area. The mention of specific products or services in this webinar does not represent Partnership for Safe Water or AWWA endorsement. The Partnership for Safe Water and AWWA do not endorse or approve products or services. 4

5 The Safe Drinking Water Act SDWA (1974) Microbial Coliform, Micro-organisms Disinfectants Chlorine Chloramines Disinfection By-products (1979) Inorganic Chemicals Metals Minerals, Nutrients Organic Chemicals Pesticides Herbicides VOCs SOCs Radionuclides (1976) 5

6 The Safe Drinking Water Act and Beyond SDWA (1974) Microbial Coliform, Micro-organisms Disinfectants Chlorine Chloramines Disinfection By-products (1979) Inorganic Chemicals Metals Minerals, Nutrients Organic Chemicals Pesticides Herbicides VOCs SOCs Radionuclides (1976) 6 Beyond SDWA Perchlorate (by December 2013) Chromium 6 (100 ppb or 0.02 ppb) NDMA, Nitrosamines Pb&Cu Rule Revisions Acrylamide and Epichlorohydrin PPCP s and EDC s Algal Toxins (UCMR4?) Right Now Turbidity Requirements Trend <1.0 <0.5 <0.3 <0.1 NTU Arsenic (<50 <10 <5 ppb) Online Instrumentation Calibration Turbidity, Chlorine Stage 2 D/DBP Rule LT2ESWTR GWUDI / GWR

7 EPA s New Approach to Protecting Water and Public Health (March, 2010) EPA s Current Objectives include: Go beyond the traditional approach of addressing individual contaminants (address contaminants as groups ) Improve drinking water treatment technology to better address health risks posed by a broad array of contaminants Use the authority of multiple laws to help protect drinking water Federal Insecticide, Fungicide, Rodenticide Act (FIFRA), Toxic Substance Control Act (TSCA) See example - Appendix 1a and 1b of this document 7

8 Where Are We Headed? EPA must remain mindful of the basic SDWA Principles SDWA requires EPA to publish a Maximum Contaminant Goal (MCLG) and promulgate an NPDWR for a contaminant if the Administrator determines that all three of the following SDWA criteria are met considered: The contaminant may have an adverse effect on the health of persons; The contaminant is known to occur or there is substantial likelihood that the contaminant will occur in public water systems with a frequency and at levels of public health concern; and In the sole judgment of the Administrator, regulation of such contaminant presents meaningful opportunity for health risk reduction for persons served by public water systems. See appendix 2 for more details on this process 8

9 Slide, courtesy of EPA 9 5

10 Regulations we are Dealing with Right Now o Stage 2 Disinfection By-products Rule (Stage 2 DBPR) o Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) 10

11 Stage 2 DBP Rule o Stage 2 strengthens DBP 1 requirements by moving from a: SYSTEM running annual average (RAA) concentration for DBPs to a LOCATIONAL running average concentration (LRAA). o MCLS did not change TTHMs = 80 ppb and THAAs = 60 ppb. o Sampling requirements are at fixed intervals (i.e. every 90 days) o OEL 11

12 Stage 2 DBP Rule (cont.) Monitoring began/begins on these dates: o Systems serving >100,000 April 1, 2012 o Systems serving 50,000-99,000 October 1, 2012 o All others October 1, 2013 Compliance Considerations: LRAA will determine compliance one year later Exceeding the OEL will trigger the need for a corrective action/management plan There could be some non-compliance with this Rule if: - treatment is not managed properly, or - where issues exist within the distribution system (dead ends, tanks, low use areas) 12

13 Stage 2 DBP Rule Corrective Actions Treatment changes could require enhanced or improved coagulation to increase organics removal (ph adjustment, alternate coagulants), or possibly a whole new process. Or, switching disinfectant practices from chlorine to chloramines and/or ozone. Could effect the operation and/or placement of disinfectant booster stations, since additional chlorine can increase DBPs. Could require piping changes in the distribution system (ex. Eliminate critical dead ends by looping them) Could require implementation of routine flushing programs for certain areas of the distribution system or automatic flushing device 13

14 LT2ESWTR Monitoring Schedules Systems that serve... Must begin the first round of source water monitoring no later than the month beginning Must begin the second round of source water monitoring no later than the month beginning (1) At least 100,000 people Oct 1, 2006 Apr 1, 2015 (2) From 50,000 to 99,999 people Apr 1, 2007 Oct 1, 2015 (3) From 10,000 to 49,999 people Apr 1, 2008 Oct 1, 2016 (4) Less than 10,000 and monitor for E. coli (filtered systems) Oct 1, 2008 Oct 1, 2017 (5) Less than 10,000 and monitor for Crypto (filtered and unfiltered systems) Apr 1, 2010 Apr 1, 2019 Compliance Considerations: Strengthens turbidity requirements based on Cryptosporidium levels Second round of sampling could cause reclassification of your Bin #, resulting in the need for additional treatment United Water Delaware is utilizing the watershed protection option of the toolbox 14

15 Long Term 2 ESWTR Corrective Actions Potential capital improvements include: Improved treatment processes better removal (better settling, DAF, etc.) Filter upgrades/additions (to take advantage of toolbox turbidity credits) UV for cyst inactivation (chlorine is NOT effective) Ozone and Chlorine dioxide are questionable. Watershed Management Plan, where applicable 15

16 New Frontiers Regulatory Action Proposal Final UCMR RTCR (Total Coliform Rule revisions) Compliance by Apr 2016 Lead-free Plumbing Rule (Jan 4 th ) LT-LCR (Long Term revisions to the Lead and Copper Rule) ? 2016? TCE/PCE MCL Update ? 2016? Perchlorate 2013? ? Chromium 6 UCMR? (CA MCL 10 ppb, August 2013) EPA has indicated that regulatory delays are likely in

17 Unregulated Contaminant Rule III (UCMR3) Proposed on March 3, 2011 Final in 2012, monitoring in hormones / pharmaceuticals - 8 volatile organic compounds - 4 metals, plus Chromium 3 and 6 - Chlorate - 1,4-dioxane - PFOS, PFOA, - 5 other perfluorinated chemicals - 2 viruses 17

18 UCMR3 Contaminants Hormones / Pharmaceuticals 17-β-estradiol 17-α-ethynylestradiol (ethinyl estradiol) 16-α-hydroxyestradiol (estriol) equilin estrone testosterone 4-androstene-3,17-dione Perfluorinated Compounds perfluorooctanesulfonic sulfonate (PFOS) perfluorooctanoic acid (PFOA) perfluorononanoic acid (PFNA) perfluorohexanesulfonic acid (PFHxS) perfluoroheptanoic acid (PFHpA) perfluorobutanesulfonic acid (PFBS) VOCs 1,2,3-trichloropropane (can occur with TCE/PCE, and in agricultural areas (GW) potential health impact at low dose) 1,3-butadiene chloromethane (methyl chloride) 1,1-dichloroethane bromomethane µg/l chlorodifluoromethane bromochloromethane (halon 1011) 1,4-dioxane (prevalent, hard to treat) Metals vanadium molybdenum cobalt strontium chromium-3 chromium-6 Other chlorate enteroviruses noroviruses 18

19 UCMR3 Sample Collector Training Eurofins Eaton Analytical, the leading U.S. water testing laboratory, in collaboration with American Water College, is offeri ng clients access to online no-cost UCMR3 sampler training that is eligible for continuing education credit. American Water College will issue a completion certificate for.1 CEUs (1 training hour) for completion of this sampler training course. Enrollment is sponsored by Eurofins Eaton Analytical at no cost to the student. For further information visit American Water College or contact Eurofins Eaton Analytical at (800) 566-LABS or us20_sales@eurofinsus.com. In addition to this remote training, Eurofins can also offer you/your team onsite hands on sampler training (which they have done for Aqua America, Aquarion Water and other multi-system UCMR3 participants). Training is important because false positives can cost you $money$ Per AWWA, there have been field blank hits and sample detects for Strontium and Chromium 6 (will need to be included in your CCR) 19

20 What Utilities Should Be Doing to be Certain That They are Prepared UCMR3 and Emerging Contaminants o o Emerging Contaminants Evaluate current sources of supply for vulnerability, and prepare for UCMR3 sampling: - Are existing sources of supply obviously vulnerable to any emerging parameters ex. Downstream of wastewater treatment plant (pharmaceuticals) Near military base (perchlorate) Systems using chloramines, chlorine systems with high nitrite, or nitrification in the network, poly DADMAC polymers (nitrosamines) Elevated total chromium levels could indicate the likely detection of chromium 6 still not certain what the final MCL will be (California MCL=10ppb, August 2013) - Unregulated Contaminant Rule (UCMR 3) monitoring scheduled for Remember, utilities will need to go online and approve the data Managing Concerns Analytical detection limits are very low we will find something! Per AWWA, there have been field blank hits and sample detects for Strontium, Chromium 6. Also, sample detects for 1,4-Dioxane. Detected Compounds will need to be reported in your CCR how/what will we communicate to customers? Costs of analysis will need to budget for UCMR3 sampling. Cost of treatment plan early! 20

21 EPA Likely Candidates for Future Regulation Nitrosamines Chlorate N-nitrosodimethylamine (NDMA) N-nitrosodiethylamine (NDEA) N-nitrosodi-n-propylamine (NDPA) N-nitrosopyrrolidine (NPYR) N-nitrosodiphenylamine (NDPhA) Molybdenum Strontium Vanadium 1,2,3-Trichloropropane (TCP) / cvocs 1,4-Dioxane Perchlorate (already proposed) Chromium 6 21

22 EPA Likely Candidates for Regulatory Update Trichoroethylene (TCE) Tetrachloroethylene (PCE) EPA proposed Rule likely in 2013 Final rule in 2015? MCLs could be reduced by an order of magnitude (5 ppb -> 0.5 ppb) The current maximum contaminant levels (MCLs) are based on analytical feasibility as both compounds have zero MCL goals (MCLGs). With improved analytical techniques, the current MCLs of 5 ppb could potentially go down by an order of magnitude How will these contaminants impact the carcinogenic VOCs group? What about EPA s recent risk assessment of PCE (2/10/12) indicating that 20 ppb may be OK (1 in 1 million health risk)? 22

23 What Utilities Should Be Doing to be Certain That They are Prepared Lower MCLs for TCE and PCE o TCE and PCE Evaluate existing levels of TCE and PCE in current sources of supply: - Are existing treatment strategies effective for complying with potentially new MCLs? - Are there sources of supply with TCE and PCE levels detected, but below current MCL? o Managing Concerns Air Strippers may require carbon polishing to meet new MCLs Detected Compounds will need to be reported in your CCR how/what will we communicate to customers? For new treatment installations, Air Strippers (followed by carbon polishing)? 23

24 Total Coliform Rule Revisions (RTCR) Rule revisions to enhance public health protection by ensuring the integrity of the drinking water distribution system and monitoring for the presence of microbial contamination. o Promulgated December, 2012 o Compliance due date April 1, 2016 Rule Provisions: o Establishes a health goal (Maximum Contaminant Level Goal, or MCLG) and an MCL of zero for E. coli and o Eliminates the MCLG and MCL for total coliform, replacing it with a treatment technique for coliform that requires assessment and corrective action Well managed systems (i.e. history of clean coliform samples) will experience minimal impact. 24

25 Key Elements of the Revised Total Coliform Rule Provides flexibility in the location of sites for repeat samples Allows the use of dedicated sampling stations Places emphasis on sample siting plan. Flow modeling to determine upstream / downstream sites at different times of the day Allows additional RT (routine) samples in calculating compliance System will transition to new rule at their current monitoring frequency 25

26 Key Elements of the Revised Total Coliform Rule (cont.) Systems must identify and correct sanitary defects when monitoring results show vulnerability to contamination Ties to Ground Water Rule (GWR) a defect that could provide a pathway of entry for microbial contamination into the distribution system 26

27 RTCR Assessments Assessments Level 1 and Level 2: o Level 1 and Level 2 assessments consider the same elements but the depth of consideration of those elements differ, based on the severity of the trigger that initiated the assessment o Triggering a Level 2 assessment implies that a contamination event may be more complicated and pose a greater risk. A Level 2 assessment is a more detailed examination of the system, its monitoring program and results, and its operational practices 27

28 RTCR Assessments Assessment components: o Review of Coliform results, chlorine and other water quality data o Sampling protocol and sampling sites o Treatment process and review of any operational changes o Distribution system (pressure, backflow prevention, valves, tanks) o Flushing Program o Main breaks/repairs o Pump stations o Hydrants o Sources of supply and storage facilities o Environmental events (rainfall, snowmelt, etc.) 28

29 RTCR Assessment Details Assessment Triggers: The PWS must conduct a Level 1 assessment if it exceeds any of the following triggers: o For systems collecting 40 or more samples per month, the PWS exceeds 5.0% total coliform-positive samples for the month; or o For systems collecting fewer than 40 samples per month, the PWS has two or more total coliform-positive samples in the same month; or o The PWS fails to take every required repeat sample after any single routine total coliform-positive sample The PWS must ensure that a Level 2 assessment is conducted either by the State or a State-approved party (which could include a qualified PWS employee(s)) if it exceeds any of the following triggers: o The PWS has an E. coli MCL violation o The PWS has a second Level 1 trigger within a rolling 12-month period, or in 2 consecutive yrs for systems on annual monitoring 29

30 RTCR Level 2 Assessment Form (examples) 5 page assessment form covering sampling/sites, sources, treatment, distribution system, storage, etc. 30

31 What Utilities Should Be Doing to be Certain That They are Prepared RTCR o o Distribution System Assessment Evaluate current coliform compliance, and distribution system vulnerability: - Is your system vulnerable? What is your current status with regards to existing TCR compliance? Are there areas of the distribution system that are vulnerable to bacteriological problems? Are you currently sampling these areas? o Low chlorine residuals o High HPCs (Heterotrophic Plate Counts) o Problem dead ends / storage tanks Start thinking about hydraulic modeling for upstream/downstream determination Managing Concerns Ensure that you know the vulnerable areas of your distribution system. Cost of remediation and/or capital improvements (if required) plan early! o Cleaning and lining problem areas of the distribution system o Looping of dead ends o Backflow prevention plans o Flushing program in place 31

32 Lead Free Plumbing Rule Effective January 4, 2014 New definition of lead free for plumbing fixtures, fittings, etc. o The new definition of lead free is calculated differently (and is much lower) than the current lead free requirement (<8.8% lead). After January 4, 2014 the term lead free will mean 1. not containing more than 0.2 percent lead when used with respect to solder and flux; and 2. not more than a weighted average of 0.25 percent lead when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures.. As of 1/4/14 it will be illegal to use any pipe, any pipe or plumbing fitting or fixture, any solder, or any flux, in the installation or repair of a public water system or customer s drinking water plumbing unless it meets a new definition of lead-free. EPA still considering how to handle repairs, meters removed for testing, etc. 32

33 What Utilities Should Be Doing to be Certain That They are Prepared Lead Free Plumbing Rule o o In the interim, water systems will need to take a number of steps including using the somewhat confusing wording of P.L as a guide: 1. Establish procurement processes, 2. Develop inventory control mechanisms, and manage 2013 inventory 3. Adopt maintenance practices, 4. Prepare installation and construction specifications, and 5. Effect internal controls. Manage your inventory now (2013) - remember the small parts/fittings! o Be wary of bargains in

34 Revisions to the Lead and Copper Rule Long-Term, Proposed Possible Changes for Lead o Remove date requirements o Update tiering to reflect current variety of lead sources o New requirements could cause non-compliance in some systems Possible Changes for Copper o Maintain lead and copper site selection criteria, but include additional sampling for new copper installations Public education component, regular monitoring until passivation o Separate site selection criteria for copper Form a tiering criteria for copper which reflects the behavior of copper in newer plumbing 34

35 Revisions to the Lead and Copper Rule Long-Term, Proposed (continued) o Modify the Lead and Copper Rule to include sampling protocol for nonresidential buildings. o Require all community water systems to sample a specific number of schools and child care facilities in the compliance monitoring period as a part of compliance sampling and included in the 90th percentile calculation; or o Modify the Lead and Copper Rule to include a separate sampling protocol where all community water systems must sample a specific number of schools and child care facilities in the compliance monitoring period. These samples are not included in calculating the 90th %; or o Modify section to include additional actions for systems that exceed an action level for lead or copper. Provide specialized public education to schools and child care facilities Require the public water system to offer to collect samples from schools and child care facilities in the affected areas. 35

36 Partial Lead Service Line Replacements Science Advisory Board report to EPA o o o Based on the current scientific data, partial lead service line replacements have not been shown to reliably reduce drinking water lead levels in the short term (ranging from days to months, and potentially even longer) Additionally, PLSLR is frequently associated with elevated drinking water lead levels for some period of time after replacement, suggesting the potential for harm, rather than benefit. Available data suggest that the elevated tap water lead levels tend to then gradually stabilize over time following PLSLR, sometimes at levels below and sometimes at levels similar to those observed prior to PLSLR 36

37 What Utilities Should Be Doing to be Certain That They are Prepared Revisions to the Lead and Copper Rule o o Corrosion Control Efficacy Assessment Evaluate current compliance with the Lead and Copper Rule: - Is your system vulnerable? What is your current status with regards to existing Pb&Cu Rule compliance? Are you sampling vulnerable sites? o Lead service lines and other appropriate sites (lead solder) o The revised Rule may include new sampling protocols Systems close to the Action Level for lead may exceed with the new Rule requirements Managing Concerns Ensure that your sampling plan addresses vulnerable sampling sites Lead exceedance (> 15 ppb at 90 th percentile) will lead to a lead service line replacement program and public notification requirements Cost of remediation and/or capital improvements (if required) plan early! o Ensure that your corrosion control strategy is appropriate and adequate o Lead service line replacements can be costly if there are a lot of lead service lines in your system 37

38 cvocs and Addressing Contaminants in Groups EPA has developed a list of 20 groups tentatively identified for regulation, with three selected for near-term (undefined) regulation, the first two having been confirmed for action in 2013: o carcinogenic volatile organic compounds (eight unregulated; eight regulated, including trichloroethylene and tetrachloroethylene which are currently being revised) o nitrosamines (including NDMA) o disinfection byproducts (some regulated, hundreds unregulated) Other candidates for future consideration with defined data gaps include: organophosphates (31), perfluorinated compounds (7) and carbamates (11). Other candidates for long-term consideration with significant data gaps include: triazines (6), chloroacetanilides (9) and cyanotoxins (3). Factors in the grouping include similarity of health effects, potential for removal by common treatment or control processes, identification by common analytical methods, and tendency to occur together. 38

39 Carcinogenic VOCs 2011 list Compound cvoc List to Study Currently Regulated UCMR3 CCL3 1,2-Dichloroethane Yes Yes 1,2-Dichloropropane Yes Yes Benzene Yes Yes Carbon Tetrachloride Yes Yes Methylene Chloride Yes Yes Tetrachloroethylene (PCE) Yes Yes Trichloroethylene (TCE) Yes Yes Vinyl Chloride Yes Yes 1,1,1,2- tetrachloroethane Yes 1,1,2,2- tetrachloroethane Yes 1,1-Dichloroethane Yes Yes Yes 1,2,3-Trichloropropane Yes Yes Yes 1,3-Butadiene Yes Yes Yes Bromochloromethane Yes Bromomethane Yes Chlorodifluoromethane Yes Chloromethane Yes Aniline Yes Benzyl chloride Yes Methyl oxirane Yes Nitrobenzene Yes Urethane Yes Regulation likely in 2016, List may change based on further health effects studies 39

40 Chromium 6 (Hexavalent Chromium) The MCL Debate o Total chromium regulated at 100 ppb in 1991 o California set a public health goal of 0.02 ppb in 2011, and now an MCL of 10 ppb in 2013 o Erin Brokovich increased interest in Chromium 6 o Draft risk assessment by EPA expected this year (2013) o Final risk assessment thereafter. EPA will then have to decide if regulation needs to be revised to address Chromium 6 (a likely outcome) Risks o Right now we detect total chromium in many of our systems. UCMR3 monitoring will determine potential future compliance issues and concerns (many systems are seeing sample detects) o Treatment is challenging and expensive (per AWWA total treatment costs for a potential chromium 6 regulation could be more expensive than all other SDWA regulations to date) 40

41 Six-Year 2 (3/2010) Carcinogenic VOCs Proposal (2013?) Six-Year 3 Proposal (3/2014) Round 2 LT2ESWTR Monitoring (10/ /2017) Carcinogenic VOCs Final (2016?) Six-Year 3 (3/2016) RTCR Final Summer, 2012 RTCR Effective Summer, 2015 UCMR3 Proposal UCMR3 Monitoring (1/ /2015) LT-LCR Proposal (2012) ClO 4 - Proposal (2013) LT-LCR Final (Spring 2014) ClO 4 - Final (2/2015) Reg Det 3 Proposal (<7/2012) Reg Det 3 Final (<7/2013) CCL3 Final (5/2011) Proposed Rule(s) (<7/2015) 1 Final Rule(s) (<1/2017) 1 Note (1): EPA can propose a rule at the same time as it makes a determination to regulate. This would truncate the rule timeline for any given contaminant by 2 years. Delays are expected in Note (2): As yet unassigned (fluoride, acrylamide, epichlorohydrin, total chromium / Cr-6) 41

42 Thank You! Join AWWA at an upcoming conference: WQTC November 3-7, 2013 Long Beach, CA Utility Management Conference February 25-28, 2014 Savannah, GA AWWA/AMTA Membrane Conference March 10-13, 2014 Las Vegas, NV ACE14 June 8-12 Boston, MA Partnership for Safe Water Annual Awards Luncheon Partner with us. Subscribe to Partnership for Safe Water optimize treatment plant and distribution system operations and improve water quality performance Volunteer with the Partnership and expand your network of utility professionals! 42

43 Thank You! Keith Cartnick and the Partnership for Safe Water appreciate your attendance! Follow up questions may be directed to: Keith Cartnick Partnership for Safe Water 43

44 Appendix 1a ex. Use the authority of multiple laws to help protect drinking water Breaking News (BNA Reporter August, 2011) EPA Releases Chemical Data Reporting Rule With New Requirements Set to Start February 1, 2012 Posted August 2, 2011, 1:16 P.M. ET o A final rule that requires expanded data reporting from chemical manufacturers for a large number of chemicals was issued Aug. 2 by the Environmental Protection Agency. o The rule will require more frequent reporting of critical information and will require submission of new and updated information on potential chemical exposures, current production volume, manufacturing site-related data, and processing and use-related data. Companies will be required to start following the new reporting requirements in the next data submission period, which will be February 1 to June 30, o The rule amends the Inventory Update Reporting (IUR) Rule under the and changes its name to the Chemical Data Reporting Rule. o More information, including a copy of the rule, is available at 44

45 Appendix 1b EPA Headquarters News Release 2/13/12 EPA s FY 2013 Budget Proposal Focuses on Core Environmental and Human Health Protections WASHINGTON Today the Obama Administration proposed a FY 2013 budget of $8.344 billion for the U.S. Environmental Protection Agency (EPA). This budget reflects a government-wide effort to reduce spending and find costsavings, and is $105 million below the EPA s enacted level for FY The FY 2013 budget is the result of EPA s ongoing efforts to carefully consider potential cost savings and reductions while continuing its commitment to core environmental and health protections -- safeguarding Americans from pollution in the air they breathe, the water they drink and the land where they build their communities. This budget is focused on fulfilling EPA s core mission to protect health and the environment for millions of American families. It demonstrates fiscal responsibility, while still supporting clean air, healthy waters and innovative safeguards that are essential to an America built to last, said EPA Administrator Lisa P. Jackson. It has taken hard work and difficult choices to reach this balanced approach, and while we had to make sacrifices, we have maintained our commitment to the core priorities of this agency and ensured the protections the American people expect and deserve. More information: 45

46 Appendix 2 EPA s Process for the 3 SDWA Criteria 1. Assess Health effects data to develop Health Reference Level (HRL) 2. Analyze data from nationally representative occurrence studies and compared to HRL (and ½ HRL) 3. Evaluate the potential health risks above the HRL to determine if a national drinking water regulation provides a meaningful opportunity for risk reduction Meaningful Opportunity assessment criteria - Number of people who may be exposed - Number of systems impacted - Extent of occurrence (number of states, national distribution) - Sensitive sub-populations - Exposure from water versus other sources (food, air, etc.) 46