AWWA s Perspective on the Draft CCL3. J. Alan Roberson, P.E. Director of Security and Regulatory Affairs American Water Works Association

Transcription

1 AWWA s Perspective on the Draft CCL3 J. Alan Roberson, P.E. Director of Security and Regulatory Affairs American Water Works Association

2 Presentation Outline The CCL/UCMR/RD Process The CCL/UCMR/RD History AWWA s Comments on the Draft CCL3 Risk Indices Conceptual Implementation Conclusions Future CCLs

3 CCL/UCMR/RD Decision Sequence/Timeline Draft CCL Final CCL Preliminary Regulatory Determinations (RD) Public Review and Comment Draft UCMR Final UCMR Final Regulatory Determinations (RD) Proposed Rule (NPDWR) UCMR Monitoring Results No further action or develop health advisory Final Rule (NPDWR) Six Year Review of Existing NPDWRs

4 CCL/UCMR/RD History Final CCL1 in contaminants: 50 chemicals & 10 microbes Developed primarily through expert judgment process UCMR1 in chemicals on List 1 for required monitoring for systems serving >10,000 people 2001 thru 2003 List 2 Screening and List 3 Pre-Screen First Final Regulatory Determination (RD) in 2003 Decided not to regulate 9 CCL1 contaminants

5 CCL/UCMR/RD History (cont.) Final CCL2 in remaining CCL1 contaminants UCMR2 in chemicals on List 1 monitoring 2008 to 2010 Three EPA actions in 2008 Feb: Draft CCL3 released July: Final RD2-Decided not to regulate 11 contaminants (UCMR1 linkage) Oct: Preliminary determination to not regulate perchlorate EPA plans to finalize by the end of 2008

6 AWWA s CCL3 Comments Commended EPA for substantial effort and increased scientific rigor in draft CCL3 EPA should stay the course with CCL process EPA should state the purpose of CCL3 The CCL process may not work for DBPs EPA should develop an integrated research agenda for CCL3 and other drinking water issues The number of contaminants on final CCL3 should match up with the research resources EPA should work with stakeholders to minimize source water contamtination

7 DBPs and CCL3 Large exposure to DBPs Both surface water and groundwater Draft CCL3 includes 4 nitrosoamines But doesn t include 2 UCMR2 nitrosoamines Many unregulated DBPs are being identified Current regulatory focus on TTHMs/HAAs EC/ES is supposed to address TOC/TOX and the unregulated DBPs But how well is that working? Is EPA done with DBP regulations? Hard to tell from Draft CCL3 and six-year review process

8 Research $ and contaminants Research agenda from Draft CCL3 would be broad Categorize research needs for CCL3 contaminants: Limited: $2 million of research needed Moderate: $5 million of research needed Significant: $10 million of research needed Assume equal split across 104 Draft CCL3 contaminants Total CCL3 research cost approaching $600 million Will take over 20 years to complete, assuming ½ of current EPA drinking water research budget goes to CCL issues EPA s current drinking water research budget of $50M/yr. would support 30 CCL contaminants given the above assumptions

9 One Observation Many think that health effects research is lacking the most and needs more focus For Draft CCL3, more occurrence data was lacking than health effects For many pesticides, concentrations were modelled Focusing analytical method research and more targeted future UCMRs may be the better approach

10 A Few More Observations The CCL is the starting point for regulations CCL/RD/Proposal/Final CCL & RD follow the same 3 SDWA criteria Contaminant has an adverse health effect; Occurs (or likely to occur) at a level of health concern; National regulation offers a risk reduction opportunity The CCL is important, as it has a profound impact on resource allocation Not just EPA, but with utilities Guiding set of priorities for both research and treatment plant design

11 Conceptual Approach

12 Implementing Graphical Approach Water Industry Technical Action Fund (WITAF) contract with Missouri University of Science and Technology to implement conceptual approach Initially developed for 234 chemicals for validation Five databases and other literature used Took awhile to work out the kinks Later developed for the 91 CCL3 chemicals Developed 1 to 10 score for both occurrence and toxicity Used EPA s method of normalization Uncertainty was estimated from both data-type and source of the data

13 Graphical Example

14 Small Amount of Data

15 Moderate Amount of Data

16 Large Amount of Data

17 Graphical Advantages Utilizes all available data Provides an organizational framework to evaluate all of the data Comparisons between contaminants Can evaluate scarcity/abundance of data Scarce data could feed into research priorities Also can evaluate data quality & uncertainty Should not replace the EPA CCL process Another evaluation tool

18 Recommendations Continue using science-based process for future CCLs Future CCLs should be smaller The exact number is a real debate Future drinking water research agenda is daunting to say the least CCL, EDCs, PPCPs, distribution system issues including infrastructure Limited resources problematic Focusing research will be critical

19 Questions? American Water Works Association Government Affairs Office 1300 Eye Street NW, #701W a Washington, DC (202) aroberson@awwa.org