# Presentation: 854626

## 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/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

- 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/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/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

- 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

- 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/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

- 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

- 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

- 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

- 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

- 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

- 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

- 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.”