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POINT OF ENTRY POINT OF USE BOTTLED WATER

POINT OF ENTRY POINT 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:

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POINT OF ENTRY POINT OF USE BOTTLED WATER

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  1. POINT OF ENTRYPOINT OF USEBOTTLED WATER Gary Carlson Drinking Water Program EPA Region 8

  2. 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

  3. 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)”

  4. POE/POU/Bottled Water • Coliforms are microbial contaminants. • Giardia lamblia and Cryptosporidium are protozoans.

  5. 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

  6. 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

  7. 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 and maintenance - to ensure compliance with the MCL or treatment technique SDWA Amendments Section 1412(b)(4)(E)(ii)

  8. 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)

  9. 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

  10. 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

  11. POE/POU/Bottled Water • POE devices are still considered emerging technologies - due to waste disposal and cost considerations • POE units are relatively expensive, and not likely an affordable technology for small systems • Waste disposal issues remain - disposal of brine or concentrate stream

  12. 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

  13. 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

  14. 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

  15. 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.

  16. 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.

  17. 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

  18. 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

  19. 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+)

  20. 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

  21. 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

  22. 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

  23. 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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