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: - 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 and maintenance - 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 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

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.”