Water News

The American Water Works Association (AWWA) and the International Association of Plumbing and Mechanical Officials (IAMPO) have published for public comment, a draft Manual of Recommended Practice for: The Safe Closure and Reopening of Building Water Systems.

You can obtain a copy of the draft Manual at the following location:
https://www.iapmo.org/media/29840/recommended-practice-manual-review-draft-5-20-22-public-input.pdf

Public comments are due by July 15, 2022.

The links below are to the IAPMO website where the draft Manual is posted. Information is provided about submitting public comments:
https://www.iapmo.org/standards-development/iapmo-industry-standards/20-day-public-review

https://www.iapmo.org/group/update/manual-of-recommended-practices-safe-closure-reopening-building-water-systems

The text below is copied from the IAMPO website:
“The manual covers risk management practices for all potable and non-potable water supply systems, water-supplied mechanical systems (cooling towers), wet fire suppression systems, and decorative water feature systems post-construction, during normal operation, when closing, during interruption to normal operation (system shutdown), and reopening all building occupancy types except for single- and two-family residential buildings. It is intended to provide expert guidance on building water system safety and provides sound and effective risk management practices for preparing water systems when buildings must be shut down or put into low use modes, “exercising” building water systems during periods of no or low use and evaluating and preparing water systems for reopening.”
“As the world emerges from the COVID-19 pandemic, there will be countless studies that will consider where proactive efforts could have reduced the health-, safety- and economic-related impacts that resulted,” said Christoph Lohr, IAPMO vice president of Strategic Initiatives. “The pandemic also pushed the plumbing and water-related industries to rethink some common practices. In the manual’s case this meant evaluating construction practices. Indeed, society has learned a great deal and we will be better prepared for the next time we need to respond to a similar threat on a global or regional scale, but only if we take the time to capture the recommended practices that are identified and put them into practice.”

June 14, 2022, today the Environmental Protection Agency (EPA) announced the release of “interim updated Health Advisories” (HAs) for PFOA and PFOS. EPA also announced that they are issuing final HAs for PFBS and GenX chemicals.

The interim HAs for PFOA and PFOS are
PFOA – 0.004 parts per trillion (ppt)
PFOS – 0.02 ppt

The final HAs for PFBS and GenX are:
PFBS – 2000 ppt
GenX – 10 ppt

Text Below is Copied from the Enclosed Federal Register Announcement:
“EPA is releasing interim updated health advisories for PFOA and PFOS based on data and draft analyses that indicate that the levels at which negative health effects could occur are much lower than previously understood when the agency issued its 2016 health advisories for PFOA and PFOS (70 parts per trillion or ppt). Human studies have found associations between PFOA and/or PFOS exposure and effects on the immune system, the cardiovascular system, development (e.g., decreased birth weight), and cancer. These data and draft analyses, which were released publicly in November 2021, are currently undergoing EPA Science Advisory Board (SAB) review. EPA is concerned about the public health implications of these preliminary findings and is therefore issuing interim updated health advisories for PFOA and PFOS.”

Link to a website presenting EPA’s Question and Answers Regarding PFAS
https://www.epa.gov/sdwa/questions-and-answers-drinking-water-health-advisories-pfoa-pfos-genx-chemicals-and-pfbs

Link below is to EPA’s web page on HAs. Scroll down to the middle of the page to find links for the four new PFAS HAs (links will take you to the supporting documents).
https://www.epa.gov/sdwa/drinking-water-health-advisories-has

Text Below is Copied from EPA’s Press Release:
“These advisories indicate the level of drinking water contamination below which adverse health effects are not expected to occur. Health advisories provide technical information that federal, state, and local officials can use to inform the development of monitoring plans, investments in treatment solutions, and future policies to protect the public from PFAS exposure.
EPA’s lifetime health advisories identify levels to protect all people, including sensitive populations and life stages, from adverse health effects resulting from a lifetime of exposure to these PFAS in drinking water. EPA’s lifetime health advisories also take into account other potential sources of exposure to these PFAS beyond drinking water (for example, food, air, consumer products, etc.), which provides an additional layer of protection.
EPA is issuing interim, updated drinking water health advisories for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) that replace those EPA issued in 2016. The updated advisory levels, which are based on new science and consider lifetime exposure, indicate that some negative health effects may occur with concentrations of PFOA or PFOS in water that are near zero and below EPA’s ability to detect at this time. The lower the level of PFOA and PFOS, the lower the risk to public health. EPA recommends states, Tribes, territories, and drinking water utilities that detect PFOA and PFOS take steps to reduce exposure. Most uses of PFOA and PFOS were voluntarily phased out by U.S. manufacturers, although there are a limited number of ongoing uses, and these chemicals remain in the environment due to their lack of degradation.
For the first time, EPA is issuing final health advisories for perfluorobutane sulfonic acid and its potassium salt (PFBS) and for hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt (“GenX” chemicals). In chemical and product manufacturing, GenX chemicals are considered a replacement for PFOA, and PFBS is considered a replacement for PFOS. The GenX chemicals and PFBS health advisory levels are well above the level of detection, based on risk analyses in recent scientific studies.”

In November 2021 EPA published a request that the National Drinking Water Advisory County (NDWAC) “….provide advice and recommendations on key issues related to potential revisions to the following Microbial and Disinfection Byproducts (MDBP) rules: Stage 1 and Stage 2 Disinfectants and Disinfection Byproducts Rules, Surface Water Treatment Rule, Interim Enhanced Surface Water Treatment Rule, and Long-Term 1 Enhanced Surface Water Treatment Rule.” At the same time, EPA requested nominations for an M/DBP Rule Revisions Working Group. The M/DBP Rule Revisions Working Group would make recommendations to the full NDWAC. After reviewing the Working Group’s recommendations, the NDWAC would then submit recommendations of possible M/DBP Rule Revisions to EPA.

The first meeting of the M/DBP Working Group will be May 23, 2022 from 11:00 am until 4:00 pm (ET) and will be hosted virtually through Zoom for Government. The meeting is “intended to make introductions among Working Group members; review previous public engagements and Working Group member interview findings; describe the approach to sequencing meeting topics for the meeting series and supporting discussions with technical information; and share goals for Working Group outcomes/impacts.”

Link to register to listen to the May 23, 2022 meeting:
https://www.eventbrite.com/e/ndwac-mdbp-rules-revision-working-group-meeting-1-tickets-329787602597

EPA intends to propose revised regulations by July 2024 and publish the final revised regulations by September 2027.

Background
Under the SDWA as amended in 1996, EPA is required to conduct a review of drinking water regulations every six years, and if appropriate, revise specific regulations. Previous six-year reviews were concluded in 2003 and in 2010. In December 2016, EPA announced the completion of its third review of existing drinking water regulations. EPA determined that eight regulations are candidates for regulatory revision. The eight regulations are chlorite, Cryptosporidium, Giardia lamblia, haloacetic acids (HAA5), heterotrophic bacteria, Legionella, TTHM, and viruses. These constituents are currently regulated under the Long-term 2 Enhanced Surface Water Treatment Rule and the Stage 2 Disinfection Byproduct Rule and are referred to as M/DBP regulations.

In October 2020, and during 2021 EPA held a series of public meetings to obtain input on possible revisions to the eight M/DBP regulations.

Yesterday, the Environmental Protection Agency (EPA) issued a press release “EPA Delivers on Three Water Commitments in the Agency’s PFAS Strategic Roadmap.”

The press release addresses (1) Clean Water Act analytical method for measuring PFAS, (2) EPA memo on PFAS discharges in EPA-issued NPDES permits, and (3) EPA is developing national recommended ambient water quality criteria for PFAS to protect aquatic life.

Link to EPA’s press release:
https://www.epa.gov/newsreleases/epa-delivers-three-water-commitments-agencys-pfas-strategic-roadmap

The press release contains links to EPA’s PFAS Strategic Roadmap, draft analytical Method 1621, EPA’s NPDES memo and draft aquatic life criteria for PFOA and PFOS.

On April 26, 2022, from 2:00 pm to 5:00 pm (ET), EPA will hold a public listening session on the Consumer Confidence Report (CCR) Rule revisions. From EPA’s announcement and webpage: “EPA’s Office of Ground Water and Drinking Water will provide a brief introduction of the CCR background and goals of the revision, followed by an opportunity for attendees to offer input on considerations for the revisions.”

“EPA encourages input from members of public water systems, environmental groups, public interest groups, risk communication experts, the States, and other interested parties.”
“Potential topics of discussion may include, but are not limited to:
1. Tools that address challenges to developing CCRs.
2. CCR delivery methods, including electronic delivery options.
3. Considerations and concerns related to underserved communities environmental justice.
4. Opinions on biannual delivery, including timing and content of reports.
5. CCR accessibility challenges and solutions.
6. Improving readability, clarity, understandability, accuracy, and risk communication of the information presented in CCRs.”

Link to Register for the April 26, 2022 listening session:
https://www.eventbrite.com/e/consumer-confidence-report-rule-revision-public-listening-session-tickets-322669462047

March 31, 2022, EPA announced they have concluded their review of the July 2020 decision not to regulate perchlorate in drinking water. EPA concluded: “….the 2020 decision is supported by the best available peer reviewed science. EPA’s determination under the Safe Drinking Water Act does not impact any state standards.” This decision was released as part of a larger plan to address perchlorate contamination, please see the enclosed EPA document.

Link to EPA website for additional information on perchlorate:
https://www.epa.gov/sdwa/perchlorate-drinking-water

SAB Meeting on PFOA and PFOS Health Effects
In April 1, 2022 Federal Register EPA announced that on May 3rd (noon to 5:00 pm, ET) and May 6th, (1:00 pm to 5:00 pm, ET), 2022 the Science Advisory Board (SAB) will meet to discuss their review of EPA’s documents regarding: (1) the health effects data to inform the derivation of proposed Maximum Contaminant Level Goals (MCLG) for PFOA and PFOS; (2) the analysis of health risk reduction benefits of potential decreases in drinking water concentrations of PFOA and PFOS and (3) approaches to assess the cumulative risk among mixtures of PFAS.

Copies of the draft EPA documents can be found at the following location:
https://sab.epa.gov/ords/sab/f?p=114:19:13119643651721:::RP,19:P19_ID:970#doc

March 29, 2022, the State Water Resources Control Board (SWRCB) Division of Drinking Water (DDW) sent out a brief notice stating that DDW “….has initiated the process of developing revised notification and response levels for manganese. This process will result in proposed new notification level and response level concentrations for manganese.” At the present time no additional details are available.

The current Notification Level (NL) for manganese is 0.5 mg/L (the Response Level is 10 times the Notification Level).

Manganese also has a secondary Maximum Contaminant Level (MCL) of 0.05 mg/L.

Link to DDW web page with background information on manganese:
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/Manganese.html

EPA announced that on April 19, 2022 they will provide an update to the National Drinking Water Advisory Council
“….on a proposed National Primary Drinking Water Regulation (NPDWR) for per- and polyfluoroalkyl substances (PFAS), including perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS).”

Background On Development of PFAS MCLs:
In March 2021, EPA published a decision to regulate PFOA and PFOS in drinking water (that were listed under the Contaminant Candidate List). Under the Safe Drinking Water Act (SDWA), once EPA made the decision to regulate PFOA and PFOS in drinking water, the Agency had 24 months to propose regulations (i.e., by March 2023) and 18 months after that to publish final regulations (i.e., by September 2024). In October 2021, EPA published a PFAS Strategic Roadmap addressing PFAS contamination in different media. According to the PFAS Strategic Roadmap, EPA intends to move faster on setting the drinking water standards than allowed under the SDWA and plans to propose MCLs during fall of 2022 and publish final MCLs by the fall of 2023.

Wednesday, March 30, 2022,
The State Water Resources Control Board (SWRCB) will hold a workshop on PFAS funding opportunities. In addition to the March 30th workshop, on Tuesday, April 5, 2022, DDW staff will give a briefing to the SWRCB on PFAS issues. As stated in the DDW announcement the April 5th briefing will include: “…an update on the state-wide investigations regarding per and polyfluoroalkyl substances (PFAS). The presentation will also include a summary of upcoming funding opportunities by the Division of Financial Assistance for water-related projects.”

The Division of Drinking Water (DDW) posted an “administrative draft” of the Maximum Contaminant Level (MCL) for hexavalent chromium (CrVI). The draft MCL is 0.010 mg/L.
DDW posted draft revisions to Title 22 regulations, a staff report and attachments, and (3) announcement they will hold workshops on April 5th (at 5:30 pm) and April 7th (at 9:00 am).

The DDW announcement includes the following statement: “The formal procedure for adopting [the] regulation under the Administrative Procedure Act has not yet begun, and these workshops are not part of that process. However, input provided on the proposed administrative draft of the MCL may be used to inform the development of the regulation.”

The draft revisions to Title 22 indicate that the Compliance Date for the CrVI MCL for systems serving a population of 10,000 or more would be two years after the regulation takes effect. The Compliance Date would be three years after the regulation takes effect for systems serving a population from 1,000 to 9,999, and the Compliance Date would be four years after the regulation takes effect for systems serving less than 1,000.

The announcement contains a link to watch the workshops. The workshops will include a presentation by DDW of the draft MCL followed by an opportunity for public comment.

Written public comments on the administrative draft MCL and compliance language are due by April 29, 2022.