PFAS, Bottled Water, Risk and Resilience Assessment

Incineration of Fire Fighting Foam (PFAS)

Article posted on the Guardian website regarding incineration of AFFF foam containing PFAS; concerns being expressed by environmental groups:

https://www.theguardian.com/environment/2020/jan/20/defence-department-toxic-pollution-pfas-foam

Bottled Water vs Tap Water

Article posted on the Medical News Today website comparing tap water vs bottled water:

https://www.medicalnewstoday.com/articles/327395.php

American’s Water Infrastructure Act (AWIA) – Upcoming Deadlines

The AWIA was signed into law in October 2018.  The AWIA included a requirement that community water systems serving a population greater than 3,300 update their Vulnerability Assessments (VA) prepared under the 2002 “Public Health Security and Bioterrorism Preparedness and Response Act.”  Under the AWIA the updated VAs are referred to as “Risk and Resilience Assessments.”  Community water systems are also required to update their Emergency Response Plans (ERPs).

Upcoming Deadlines.  Community water systems serving greater than or equal to 100,000 must certify to EPA by March 31, 2020 that they prepared the “Risk and Resilience Assessment.”  Six months after that (September 30, 2020), those systems must certify to EPA that they prepared an updated ERP.

Risk and Resilience Assessments.  AWIA specifies the following topics be addressed in the Risk and Resilience Assessment:

  • Risk to the system from malevolent acts and natural hazards,
  • Resilience of pipes and conveyances, physical barriers, source water, water collection and intake, pretreatment, treatment storage and distribution facilities, electrical, computers, or other automated systems;
  • Monitoring practices,
  • Financial infrastructure,
  • Use, storage, and handling of various chemicals, and
  • Operation and maintenance.

Emergency Response Plans. AWIA Section 2013 specifies the following topics to be addressed in ERPs:

  • Strategies and resources to improve resilience of the system (including physical security and cybersecurity);
  • Plans and procedures that can be implemented and equipment that can be utilized in the event of a malevolent act or natural hazard that threatens ability to provide safe drinking water,
  • Actions, procedures and equipment that can lessen the impact of a malevolent act or natural hazard including development of alternative source water options, relocation of water intakes and construction of flood protection barriers, and
  • Strategies to help detect malevolent acts or natural hazards.

Deadlines for other sized systems:

  • 50,000 to 99,999 population: Risk and Resilience Assessment certification due December 31, 2020, updated ERP certification due June 30, 2021.
  • 3,301 to 49,999 population: Risk and Resilience Assessment certification due June 30, 2021, updated ERP certification due December 31, 2021.
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About Dan Askenaizer

Dr. Askenaizer leads WQTS’ work on regulatory compliance support for many of our water agencies clients. Dr. Askenaizer tracks water quality and treatment regulations at the Federal and State levels and provides regulatory updates to our clients. Dr. Askenaizer has strong expertise in the development of Regulatory Monitoring and Compliance Plans (RMCPs), which he has completed for a number of water agencies. He has also been working on a number of projects dealing with the development of distribution system monitoring plans and review of nitrification control strategies. Prior to joining WQTS, Dr. Askenaizer was the Water Quality Manager for the Glendale Water and Power. Under his leadership, the Water Quality Group conducted a demonstration-scale study of chlorite for nitrification control and a pilot-scale study of biological treatment for removal of nitrate. Dan has 30 years of experience working on projects dealing with regulatory, water quality and public health issues. Dan has given numerous presentations at workshops and round-tables across the country for water utilities. Dan was instrumental in developing and implementing a Mentoring Program for water staff and was involved in a Sustainable Development team.