POINT OF ENTRY POINT OF USE BOTTLED WATER

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


• 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)”


• Coliforms are microbial contaminants.

• Giardia lamblia and Cryptosporidium are protozoans.


• 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


• 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 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 device must be equipped with mechanical warnings to ensure that customers are automatically notified of operational problems

SDWAA Section 1412(b)(4)(E)(ii)


• 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


• 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 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


• 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


• 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


• 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.


• 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


• 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+)


• 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


• 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


• 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


• 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.”

Documents

POINT OF ENTRY POINT OF USE BOTTLED WATER