POINT OF ENTRY POINT OF USE BOTTLED WATER

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POINT OF ENTRYPOINT OF USEBOTTLED WATER

• Gary Carlson
• Drinking Water Program
• EPA Region 8

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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

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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)

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POE/POU/Bottled Water

• Coliforms are microbial contaminants.
• Giardia lamblia and Cryptosporidium are
  protozoans.

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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

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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

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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)

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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)

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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

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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

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POE/POU/Bottled Water

• POE devices are still considered emerging
  technologies
• - due to waste disposal and cost consideratio
  ns
• POE units are relatively expensive, and not
  likely an affordable technology for small systems
• Waste disposal issues remain
• - disposal of brine or concentrate stream

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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

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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

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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

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POE/POU/Bottled Water

• Other POE requirements under 40 CFR 141.100
  contd
• - Effective technology must be properly
  applied under a plan approved by the State and
  the microbiological safety of the water must be
  maintained.

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POE/POU/Bottled Water

• Other POE requirements under 40 CFR 141.100
  contd
• - 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.

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POE/POU/Bottled Water

• Other POE requirements under 40 CFR 141.100
  contd
• - 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

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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

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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)

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POE/POU/Bottled Water

• Technologies amenable to POE/POU scale treatment
  contd
• - 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

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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 systems particular
  source water
• RO may only require confirmation of membrane
  fouling not being a problem

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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

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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.