Treatment Technology Stakeholder Meeting
EXECUTIVE SUMMARY
May 18-19, 1998
Washington, DC
Background
The Environmental Protection Agency held a stakeholder meeting on May
18 - May 19, 1998 in Washington, DC. The goal of the meeting was to obtain
feedback on identifying technologies for the compliance and variance technology
lists due on August 6, 1998. These lists are required by the Safe Drinking
Water Act (SDWA) Amendments of 1996. Representatives from states, water
systems, and equipment manufacturing companies were among the key stakeholders
present.
The objective of the meeting was to receive input on the following issues:
1) Process for determining which existing regulated contaminants may be
eligible for variance technologies; 2) Options for national-level affordability
criteria; 3) Update to the August 1997 Compliance Technology List for
the Surface Water Treatment Rule; 4) Candidate technologies for the compliance
technology lists for the other regulated contaminants; and 5) Point-of-Use
and Point-of-Entry devices as compliance options. The first two issues
were covered on the first day and the last three were covered on the second
day.
Summary
Day One -- Variance Technology Eligibility Process
The first major topic was the process for determining which existing
regulated contaminants may be eligible for variance technologies. Screening
criteria were applied to the 80 regulated contaminants and only 5 contaminants
emerged as candidates for variance technologies. The screening criteria
are as follows: Section 1415(e)(6)(B) of the SDWA; Section 1415(e)(6)(A)
of the SDWA; drinking water regulations that are not technology-based;
unreasonable risk to health (URTH); an initial affordability screen; no
MCL for small systems; and contaminant occurrence. URTH was used as a
screen for the "protective of public health" requirement associated with
variance technologies. URTH is based on a short-term exposure of 7 years
whereas the small system variance can last the expected useful life of
the variance technology. The following two presentations discussed the
procedure for determining URTH values and its relationship with the protective
of public health criteria. Affordability was assumed and no variance technologies
are needed for those contaminants where there were no violations or projected
violations. Stakeholders asked what would happen if a violation did occur
for one of these contaminants. It was explained that the compliance and
variance technology lists are dynamic lists that can be modified based
on new information.
Day One -- National-level Affordability Criteria
The second half of the first day dealt with the national-level affordability
criteria that determine whether a given system will proceed along a compliance
or variance pathway and which technologies would be available for the
system. This session opened with a background presentation on affordability
and variance technologies. It was emphasized that the national-level affordability
criteria determine how much a system should pay and for what level of
protection. Systems installing a variance technology will incur costs
and those costs will need to be recovered from the users. Household costs
will increase under either the compliance or variance pathway. The baseline
of current annual household water bills in each small system size category
was the focus of the next presentation. The three critical parameters
for the baseline are: annual household water consumption, median household
income, and annual sales revenue per connection. Stakeholders preferred
consistency in terms of picking either median or mean values for these
three parameters. EPA asked stakeholders if separate baselines should
be established within each size category based on source type or ownership
type. Source type was viewed as the more important variable in establishing
baselines for annual household water bills. The final presentation in
this session discussed the range of options for national-level affordability
criteria based on comparative household expenditures and a comparison
of those expenditures against income. The identified range of 1.5% to
3% of median household income is based on data in the Bureau of Labor
Statistics Consumer Expenditure Survey. The floor of 1.5% is equivalent
to annual consumer expenditures on alcohol and tobacco. The 3% is based
on rounding down the combination of electricity, fuel oil & other,
and natural gas. One stakeholder expressed concern with the use of the
median household income and stated that the focus should be on disposable
income for lower income levels. EPA stated that it would be inconsistent
to use the higher mean or median annual household consumption and mean
or median annual sales revenue per connections with a lower household
income. Water consumption and current annual water bills for households
with lower incomes would likely be lower than the median or mean households
within each size category. Other stakeholders commented that the affordability
criteria should be set at the lower end of the range of median household
income (1.5%). EPA stated that one limitation of the approach is that
all costs are assumed to be borne by the users. The annual water bill
cost increase used for the affordability determination may not represent
the typical small system because no financial assistance is assumed. This
may support a higher percentage of median household income for the affordability
criteria.
Day 2 -- Update to 1997 Compliance Technology List for the SWTR
The major topic in this session was the disinfection alternatives that
were listed in the 1997 Compliance Technology List Guidance Manual as
being under consideration for the 1998 update. Many of these options involve
the use of two oxidants or ultraviolet plus an oxidant. Many stakeholders
felt that these options added another level of complexity that may not
be necessary to meet the SWTR. Stakeholders did state that systems with
organic contaminants might find these options more practical since multiple
treatment objectives can be met.
Day 2 -- Treatment Technology Issues Specific to Contaminant
Type
This session was organized by arranging the remaining regulated contaminants
into groups. This was done because many of the treatment technology issues
are general and would apply to the use of the technology for any contaminant
in the group. Treatment technology performance issues were discussed for
the following groups: inorganics and corrosion by-products, radionuclides,
volatile organic contaminants, and pesticides and other synthetic organic
contaminants. Stakeholders preferred that EPA list technologies along
with performance limitations rather than exclude candidate technologies.
EPA stated that it would need to specify removal efficiency ranges where
certain technologies could be used. EPA also asked stakeholders about
the format for the compliance technology lists for these groups of contaminants.
Stakeholders preferred one document with chapters by contaminant type
rather than multiple documents.
Day 2 -- Point-of-Use and Point-of-Entry Devices as Compliance
Technologies
The 1996 SDWA Amendments state that Point-of-Use (POU) and Point-of-Entry
(POE) devices can be used as compliance technologies for small systems.
To implement this option, the POE/POU units must be owned, controlled,
and maintained by the public water system or a person under contract to
the water system. This central management plan is critical to implementing
this option. Stakeholders were provided a copy of the draft "Cost Evaluation
of Small System Compliance Options: Point-of-Use and Point-of-Entry Treatment
Units" prior to the meeting. Costs for centrally-managed POU or POE options
were compared with central treatment costs. The breakpoint for POU units
was between 70 and 180 households. The breakpoint for POE units is generally
below 20 households. The central treatment costs do not include residuals
management. Inclusion of those costs would shift the breakpoint to a higher
number of households. Other factors that were identified as affecting
costs for POU and POE options were monitoring frequency and replacement
frequency. The costs are based on monitoring each house once a year for
the contaminant of concern. This is a very conservative approach. Stakeholders
believed that representative sampling could be used to reduce monitoring
costs. The replacement frequency for component parts is based on the volume
of water treated for use. The treated water needs for POU units was assumed
to be 1 gallon per person per day for a 3 person household. This is significantly
higher than the consumption assumed for deriving maximum contaminant level
goals (2 liters/person/day). The treated water needs for POE units was
assumed to be 100 gallons/person/day for a 3-person household. This translated
into approximately 110,000 gallons/household/year. This is considerably
higher than the annual consumption values derived from the 1995 Community
Water System Survey (CWSS). Stakeholders were divided over whether to
use one gallon or 2 liters per person per day for the POU cost estimation.
Stakeholders recommended using the estimates from the CWSS for the POE
cost estimation.
Next Steps
The updated Compliance Technology List for the Surface Water Treatment
Rule and the Compliance Technology Lists for the Other Regulated Contaminants
will be published in the Federal Register
in August 1998. A variance technology list for any of the five contaminants
that meet the criteria will also be published in August 1998. All three
of these lists will be supported by guidance manuals. The Federal Register
notice will also summarize the three guidance documents. A document describing
the national-level affordability criteria will accompany the variance
technology list guidance manual. All three of the lists will be updated
yearly. For more information on treatment technologies, contact Jeffrey
Kempic at kempic.jeffrey@epamail.epa.gov.
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