POINT OF ENTRY POINT OF USE BOTTLED WATER
Post on 29-Jan-2016
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POINT OF ENTRYPOINT OF USE
BOTTLED WATER
Gary Carlson
Drinking Water Program
EPA Region 8
POE/POU/Bottled Water
• SDWA Section 1412(b)(4)(E)(ii) identifies Point-Of-Entry (POE) and Point-Of-Use (POU) devices as options for compliance technologies to:
- comply with an MCL under certain circumstances
POE/POU/Bottled Water
• Section 1412(b)(4)(E) of the 1996 Amendments to the Safe Drinking Water Act is amended by adding:
“The Administrator (EPA) shall not include in the list of technologies for small systems any point-of-use treatment technology, treatment technique, or other means to achieve compliance with a maximum contaminant level or treatment technique requirement for a microbial contaminant (or an indicator of a microbial contaminant)”
POE/POU/Bottled Water
• Coliforms are microbial contaminants.
• Giardia lamblia and Cryptosporidium are protozoans.
POE/POU/Bottled Water
• POE - treatment device applied to the drinking water entering a house or building for the purpose of reducing contaminants in the drinking water distributed throughout the house or building
POE/POU/Bottled Water
• POU- treatment device applied to a single tap used for the purpose of reducing contaminants in drinking water at that one tap
- typically installed at the kitchen tap
POE/POU/Bottled Water
• POE and POU devices shall be owned, controlled, and maintained by the public water system or by a person under contract with the public water system
- to ensure proper operation andmaintenance
- to ensure compliance with the MCL or treatment technique
SDWA Amendments Section 1412(b)(4)(E)(ii)
POE/POU/Bottled Water
• POE/POU device must be equipped with mechanical warnings to ensure that customers are automatically notified of operational problems
SDWAA Section 1412(b)(4)(E)(ii)
POE/POU/Bottled Water
• Other requirements for POE/POU devices:- must be certified according to product standards of
the American National Standards Institute (if issued)
• Former prohibition of POU devices lifted on June 11, 1998
- Federal Register notice deleted the prohibition on the use of POU device as compliance technology
POE/POU/Bottled Water
• POU devices are listed as compliance technologies for:
- inorganic contaminants
- synthetic organic contaminants
- radionuclides
• POU devices are not listed as compliance technologies for volatile organic contaminants
- not all routes of exposure are addressed
POE/POU/Bottled Water
• POE devices are still considered emerging technologies
- due to waste disposal and costconsiderations
• POE units are relatively expensive, and not likely an affordable technology for small systems
• Waste disposal issues remain
- disposal of brine or concentrate stream
POE/POU/Bottled Water
• Adequate corrosion control
Additionally, EPA needs to investigate if the usage of a limestone contactor after a reverse osmosis unit will be adequate for corrosion control of internal plumbing
POE/POU/Bottled Water• POE treatment as a centrally managed
treatment option was considered by EPA - however, Agency feels POE application for
addressing microbial contamination would be very limited due to the concern for disinfecting water properly (following filtration) and the complexity of monitoring POE systems individually
• POE devices are included on an updated list in Federal Register
POE/POU/Bottled Water
• Other POE requirements under 40 CFR 141.100:
- Public water system must develop and obtain State approval for a monitoring plan before POE devices are installed for compliance
- POE devices must provide health protection equivalent to central water treatment
POE/POU/Bottled Water
• Other POE requirements under 40 CFR 141.100 cont’d:
- Effective technology must be properly applied under a plan approved by the State and the microbiological safety of the water must be maintained.
POE/POU/Bottled Water
• Other POE requirements under 40 CFR 141.100 cont’d:
- The State must require adequate certification of performance, field testing, and, if not included in the certification process, a rigorous engineering design of the POE device.
POE/POU/Bottled Water• Other POE requirements under 40 CFR 141.100
cont’d:
- Design and application of POE must consider possibility of increased heterotrophic bacteria concentrations in water treated with activated carbon
- All consumers shall be protected. Every building connected to the system must have a POE installed, maintained, and adequately monitored
POE/POU/Bottled Water
• Technologies amenable to POE/POU scale treatment include:
- activated alumina to remove fluoride, arsenic, selenium, silica, and natural organic matter
- granular activated carbon has a large sorption capacity for many water impurities, including synthetic organic contaminants (SOCs), taste and odor causing compounds, and some species of mercury
POE/POU/Bottle Water
• Technologies amenable to POE/POU scale treatment cont.:
- reverse osmosis is a highly efficient removal process for inorganic ions, and some organic contaminants
- ion exchange (anion) resins selectively remove anionic species such as nitrate, fluoride
- ion exchange (cation) resins are used to remove undesired cations from water and exchange them for protons (H+), sodium ions (Na+) or potassium ions (K+)
POE/POU/Bottled Water
• Technologies amenable to POE/POU scale treatment cont’d:
- air stripping (aeration) involves the continuous contact of air with the water being treated
- aeration “sweeps” contaminants such as volatile organic chemicals, taste-and-odor- causing compounds, and radon from the water
- many common types of aeration systems
POE/POU/Bottled Water
• Prior to installing POE/POU units, water system operators should evaluate the units for treatment efficacy and efficiency
• If device employs cartridges (GAC and activated alumina), pilot testing is recommended to determine service life for system’s particular source water
• RO may only require confirmation of membrane fouling not being a problem
POE/POU/Bottled Water
• Effective operation, monitoring, and maintenance are vital to the successful use of POE/POU treatment units
- a routine monitoring program is necessary to confirm that the operation and maintenance is adequate and that the treated water meets drinking water standards
• Proper installation of any device is also essential
POE/POU/Bottled Water
• 40 CFR 141.101 Use of bottled water, has been revised to read as follows:
“Public water systems shall not use bottled water to achieve compliance with an MCL. Bottled water may be used on a temporary basis to avoid unreasonable risk to health.”
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