The Drinking Water Standards (Part 2)

In spite of the multitudinous regulations and standards that an existing public water system must comply with, the principles of conventional water treatment process have not changed significantly over half a century. Whether a filter contains sand, anthracite, or both, slow or rapid rate, constant or declining rate, filtration is still filtration, sedimentation is still sedimentation, and disinfection is still disinfection. What has changed, however, are many tools that we now have in our engineering arsenal. For example, , a supervisory control and data acquisition (SCADA) system can provide operators and managers with accurate process controI variables and operation and maintenance records. In addition to being able to look at the various options on the computer screen, engineers can conduct pilot plant studies of the multiple variables inherent in water treatment plant design. Likewise, operators and managers can utilize an ongoing pilot plant facility to optimize chemical feed and develop important information needed for future expansion and upgrading.

Technology and ultimately equipment selection depends on the standards set by the regulations. Drinking water standards are regulations that EPA sets to control the level of contaminants in the nation's drinking water. These standards are part of the Safe Drinking Water Act's "multiple barrier" approach to drinking water protection, which includes assessing and protecting drinking water sources; protecting wells and collection systems; making sure water is treated by qualified operators; ensuring the integrity of distribution systems; and making information available to the public on the quality of their drinking water. With the involvement of EPA, states, tribes, drinking water utilities, communities and citizens, these multiple barriers ensure that tap water in the U.S. and territories is safe to drink. In most cases, EPA delegates responsibility for implementing drinking water standards to states and tribes. There are two categories of drinking water standards:

A National Primary Drinking Water Regulation (NPDWR or primary standard) is a legally-enforceable standard that applies to public water systems. Primary standards protect drinking water quality by limiting the levels of specific contaminants that can adversely affect public health and are known or anticipated to occur in water. They take the form of Maximum Contaminant Levels (MCL) or Treatment Techniques (TT). 

A National Secondary Drinking Water Regulation (NSDWR or secondary standard) is a non-enforceable guideline regarding contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. EPA recommends secondary standards to water systems but does not require systems to comply. However, states may choose to adopt them as enforceable standards. This information focuses on national primary standards. 

Drinking water standards apply to public water systems (PWSs), which provide water for human consumption through at least 15 service connections, or regularly serve at least 25 individuals. Public water systems include municipal water companies, homeowner associations, schools, businesses, campgrounds and shopping malls. EPA considers input from many individuals and groups throughout the rule-making process. One of the formal means by which EPA solicits the assistance of its stakeholders is the National Drinking Water Advisory Council (NDWAC). The 15-member committee was created by the Safe Drinking Water Act. It is comprised of five members of the general public, five representatives of state and local agencies concerned with water hygiene and public water supply, and five representations of private organizations and groups demonstrating an active interest in water hygiene and public water supply, including two members who are associated with small rural public water systems.

NDWAC advises EPA's Administrator on all of the agency's activities relating to drinlung water. In addition to the NDWAC, representatives from water utilities, environmental groups, public interest groups, states, tribes and the general public are encouraged to take an active role in shaping the regulations, by participating in public meetings and commenting on proposed rules. Special meetings are also held to obtain input from minority and low-income communities, as well as representatives of small businesses.

The 1996 Amendments to Safe Drinking Water Act require EPA to go through several steps to determine, first, whether setting a standard is appropriate for a particular contaminant, and if so, what the standard should be. Peer-reviewed science and data support an intensive technological evaluation, which includes many factors: occurrence in the environment; human exposure and risks of adverse health effects in the general population and sensitive subpopulations; analytical methods of detection; technical feasibility; and impacts of regulation on water systems, the economy and public health. Considering public input throughout the process, EPA must (1) identify drinking water problems; (2) establish priorities; and (3) set standards.

EPA must first make determinations about which contaminants to regulate. These determinations are based on health risks and the likelihood that the contaminant occurs in public water systems at levels of concern. The National Drinking Water Contaminant Candidate List (CCL), published March 2, 1998, lists contaminants that (1) are not already regulated under SDWA; (2) may have adverse health effects; (3) are known or anticipated to occur in public water systems; and (4) may require regulations under SDWA. Contaminants on the CCL are divided into priorities for regulation, health research and occurrence data collection. 

In August 2001, EPA selected five contaminants from the regulatory priorities on the CCL and determined whether to regulate them. To support these decisions, the Agency determined that regulating the contaminants presents a meaningful opportunity to reduce health risk. If the EPA determines regulations are necessary, the Agency must propose them by August 2003, and finalize them by February 2005. In addition, the Agency will also select up to 30 unregulated contaminants from the CCL for monitoring by public water systems serving at least 100,000 people. Currently, most of the unregulated contaminants with potential of occurring in drinkmg water are pesticides and microbes. Every five years, EPA will repeat the cycle of revising the CCL, making regulatory determinations for five contaminants and identifying up to 30 contaminants for unregulated monitoring. In addition, every six years, EPA will re-evaluate existing regulations to determine if modifications are necessary. Beginning in August 1999, a new National Contaminant Occurrence Database was developed to store data on regulated and unregulated chemical, radiological, microbial and physical contaminants, and other such contaminants likely to occur in finished, raw and source waters of public water systems.

After reviewing health effects studies, EPA sets a Maximum Contaminant Level Goal (MCLG), the maximum level of a contaminant in drinking water at which no known or anticipated adverse effect on the health of persons would occur, and which allows an adequate margin of safety. MCLGs are non-enforceable public health goals. Since MCLGs consider only public health and not the limits of detection and treatment technology, sometimes they are set at a level which water systems cannot meet. When determining an MCLG, EPA considers the risk to sensitive subpopulations (infants, children, the elderly, and those with compromised immune systems) of experiencing a variety of adverse health effects.

SOME IMPORTANT DEFINITIONS

Maximum Contaminant Level (MCL) - The highest level of a contaminant that is allowed in drinking water. MCLs are set as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration. MCLs are enforceable standards.

Maximum Contaminant Level Goal (MCLG) - The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals.

Maximum Residual Disinfectant Level (MRDL) - The highest level of a disinfectant allowed in drinking water. There is convincing evidence that addition of a disinfectant is necessary for control of microbial contaminants.

Maximum Residual Disinfectant Level Goal (MRDLG) - The level of a drinking water disinfectant below which there is no known or expected risk to health. MRDLGs do not reflect the benefits of the use of disinfectants to control microbial contaminants.

Treatment Technique - A required process intended to reduce the level of a contaminant in drinking water.

Non-Carcinogens (excluding microbial contaminants) : For chemicals that can cause adverse non-cancer health effects, the MCLG is based on the reference dose. A reference dose (RFD) is an estimate of the amount of a chemical that a person can be exposed to on a daily basis that is not anticipated to cause adverse health effects over a person's lifetime. In RFD calculations, sensitive subgroups are included, and uncertainty may span an order of magnitude. The RFD is multiplied by typical adult body weight (70 kg) and divided by daily water consumption (2 liters) to provide a Drinking Water Equivalent Level (DWEL). Note that the DWEL is multiplied by a percentage of the total daily exposure contributed by drinking water to determine the MCLG. This empirical factor is usually 20 percent, but can be a higher value.

Chemical Contaminants (Carcinogens): If there is evidence that a chemical may cause cancer, and there is no dose below which the chemical is considered safe, the MCLG is set at zero. If a chemical is carcinogenic and a safe dose can be determined, the MCLG is set at a level above zero that is safe.

Microbid Contaminants: For microbial contaminants that may present public health risk, the MCLG is set at zero because ingesting one protozoa, virus, or bacterium may cause adverse health effects. EPA is conducting studies to determine whether there is a safe level above zero for some microbial contaminants. So far, however, this has not been established.

Once the MCLG is determined, EPA sets an enforceable standard. In most cases, the standard is a Maximum Contaminant Level (MCL), the maximum permissible level of a contaminant in water which is delivered to any user of a public water system. The MCL is set as close to the MCLG as feasible, which the Safe Drinking Water Act defines as the level that may be achieved with the use of the best available technology, treatment techniques, and other means which EPA finds are available(after examination for efficiency under field conditions and not solely under laboratory conditions) are available, taking cost into consideration. When there is no reliable method that is economically and technically feasible to measure a contaminant at particularly low concentrations, a Treatment Technique is set rather than an MCL. A treatment technique (TT) is an enforceable procedure or level of technological performance which public water systems must follow to ensure control of a contaminant. Examples of Treatment Technique rules are the Surface Water Treatment Rule (disinfection and filtration) and the Lead and Copper Rule (optimized corrosion control). After determining a MCL or TT based on affordable technology for large systems, EPA must complete an economic analysis to determine whether the benefits of that standard just the costs. If not, EPA may adjust the MCL for a particular class or group of systems to a level that "maximizes health risk reduction benefits at a cost that is justified by the benefits."