In September 2009, the U.S. Environmental Protection Agency (EPA) released its third “contaminant candidate list” (CCL). This list, similar to versions one and two before it, included substances which are not now regulated in drinking water by the federal government, but which EPA may consider for future regulation.
CCL 3, as it is known, consists of 116 substances, including inorganic chemicals, organic chemicals and organisms. In 1998, EPA released CCL 1 and in 2005, the agency released CCL 2. Currently, it is evaluating nominations for a new list of emerging contaminants (ECs) for CCL 4.
According to epa.gov, “The CCL is a list of contaminants that are currently not subject to any proposed or promulgated national primary drinking water regulations, but are known or anticipated to occur in public water systems. Contaminants listed on the CCL may require regulation under the Safe Drinking Water Act (SDWA).”
For more information on the development of CCL 4, please visit http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl4.cfm.
While some dealers may have used this list inappropriately to alarm some customers, most reputable water treatment dealers are aware that CCL is a guide for potential future — not current — regulation and should be used as a reference/research tool, rather than a sales tool. Still, water professionals cannot help but to notice telling trends of our society and how these are impacting drinking water supplies.
“People should be aware that the U.S. EPA is paying much closer attention to emerging contaminants, especially endocrine disrupting compounds (EDCs) and pharmaceuticals and personal care products (PPCPs). CCL 3 includes 10 PPCPs as well as 40 fungicides and pesticides, eight hormones and seven disinfection byproducts,” educates Leo Zappa, director of marketing – Municipal Business Unit, Calgon Carbon Corporation. “That’s about half of the 116 compounds on the entire CCL 3.”
Furthermore, some Americans as well as some dealers might be misguided when it comes to how such ECs as pharmaceuticals are entering our water supplies. Marianne R. Metzger, business manager for National Testing Laboratories Ltd, asserts that most pharmaceuticals found at low levels, such as parts per billion and parts per trillion, are occurring in surface waters.
“A lot of people think that improper disposal of these medications is the problem. However, especially in big cities that are [dependent on surface water sources], most of it is coming from the sewage itself,” continues Metzger. “It is the result of people taking their medication, the body absorbing only a small portion and passing through the body’s system, eventually ending up in sewage and entering areas that can impact drinking water.”
Understanding and using UCMR
Metzger adds that the purpose of the CCL is not to cause alarm. And, if dealers want to reference a resource to help their end customers better understand contaminants that are one step closer to potential regulation, they should reference EPA’s Unregulated Contaminant Monitoring Rule (UCMR).
In 1996, amendments to SDWA required that EPA establish criteria for a program to monitor unregulated contaminants and to identify a maximum of 30 contaminants to be monitored every five years. According to epa.gov, “UCMR 1 established a tiered monitoring approach and required all public water systems (PWSs) serving more than 10,000 people and a representative sample of PWSs serving less than 10,001 people to monitor for unregulated contaminants from 2001-2005.”
For more information on this program, please visit http://water.epa.gov/lawsregs/rulesregs/sdwa/ucmr/.
Looking ahead, signed by former EPA Administrator Lisa P. Jackson on April 16, 2012, UCMR 3 requires monitoring for 30 contaminants using EPA and/or consensus organization analytical methods during 2013-2015. Together EPA, states, laboratories and public water systems (PWSs) will participate in UCMR 3, according to epa.gov.
“If dealers are going to use it (UCMR) as any type of tool, just make sure you are using it as an education resource and that you are correct in what you are saying,” reminds Metzger.
Looking forward to CCL 4
Some of the contaminants on EPA’s CCL 3 list garnered our industry’s attention, including: Bisphenol A (BPA), which is an ingredient in plastic/EDC; Carbamazepine, an anti-seizure medication; DEET, an insecticide; Estrone, a steroid (estrogen hormone); Ibuprofen; Meprobamate, anti-anxiety medication; Trimethoprim, an antibiotic; and others.
PPCPs were among the leading attention grabbers for CCL 3 and some believe that medications will continue to be prominent on these lists moving forward.
What should we expect EPA to highlight with its next CCL? “Probably more pharmaceuticals because new types of medications are being introduced every year,” believes Metzger. However, in addition to PPCPs and other emerging contaminants, she would like to see a shift of focus more toward an emphasis on disinfection byproducts.
According to Metzger’s research, over 500 disinfection byproducts have been identified in water, but only 12 are currently regulated. For more information on EPA’s stance on disinfection by-products regulation, visit: http://water.epa.gov/drink/contaminants/basicinformation/disinfectionbyproducts.cfm.
Realistic reasoning with industry solutions
While many of the ECs on EPA’s CCLs should be monitored, as mentioned, dealers need to be aware that this information is being presented to the public and often causes unwarranted concern. Your customers and prospects may be impacted by sensational news reports, misleading water treatment dealer information, false data and claims on the Internet and other scare tactic selling sources. However, dealers need to present a reasonable, factual perspective.
“Many emerging contaminants have been present in drinking water for years,” asserts Jenalle Brewer, marketing manager – Specialty Products for Calgon Carbon Corporation. “While the direct impact of most of these compounds on human health has yet to be determined, and much research remains to be done, there are concerns regarding the cumulative exposure to these chemicals.”
This is especially true in regards to potential health impacts on the unborn, children, the elderly or those with compromised immune systems, continues Brewer. “The unintended interactions between different pharmaceutical agents are also a potential concern. Point-of-use (POU) and point-of-entry (POE) systems offer protection against these potentially hazardous, but not yet regulated contaminants,” she adds.
Unfortunately, the conventional treatment processes used at the majority of wastewater and drinking water plants do not effectively remove PPCPs and other ECs.
According to Zappa, dealers should help end users investigate if their local drinking water plant uses an advanced treatment system, such as granular activated carbon or high pressure membranes (i.e., nanofiltration or reverse osmosis). “If their local water plant does not use one of these advanced processes, they should consider getting a POU/POE system, be it their home or office. A filter system utilizing granular activated carbon will effectively remove most PPCPs,” he says.
This gives dealers another opportunity to sell the final barrier approach, concludes Metzger. As EPA gathers data on the contaminants appearing on CCLs, dealers should be mindful of ECs and use that information properly. Industry solutions are available for ECs: Educated customers.