Classifying Drinking Water Contaminants

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The continuing presence of contaminants in water supplies, as well as documented outbreaks of waterborne disease and the many other outbreaks thought to go undetected, serve as a clear reminder that unprotected and contaminated drinking water can still pose health risks to the population NRC, a.

Water quality

Continuing public health vigilance is necessary to ensure that drinking water contaminants, especially newly identified ones, are appropriately addressed. Perhaps the most important, comprehensive, and widely enforced law designed to protect the public from hazardous substances in drinking water is the Safe Drinking Water Act SDWA. Enacted in , it was significantly amended in and again most recently in and is administered by the U.

Prior to the passage of the original SDWA, the only enforceable federal drinking water standards were directed at waterborne pathogens in water sup-. Alternatively, Pontius and Clark provide an extensive overview and discussion of this topic, especially as related to the SDWA and its subsequent amendments.

The purpose of the original SDWA was to ensure that public water systems PWSs 1 meet national primary drinking water regulations 2 for contaminants to protect public health. The SDWA also established a joint federal-state system to help administer the nationwide program and ensure compliance with federal standards.

It is important to note that the SDWA does not regulate bottled water. Rather, bottled water is regulated at the federal level by the U. This report is concerned principally with requirements newly established in the SDWA Amendments of Among other changes, the amended SDWA requires EPA to publish a list of unregulated contaminants and contaminant groups every five years that are known or anticipated to occur in public water systems and which may require regulation. For chemical contaminants, a national primary drinking water regulation includes a nonenforceable criterion called the maximum contaminant level goal MCLG that is used to help set an enforceable standard called the maximum contaminant level MCL or treatment techniques if contaminant monitoring is deemed not feasible.

For microbiological contaminants, the original SDWA philosophically established a zero tolerance for disease-causing organisms as the health goal i. In practice, however, treatment performance techniques, rather than specific allowable concentrations of pathogens such as MCLs , historically have served as the basis for regulating microbial contaminants in drinking water NRC, a. The CCL is comprised entirely of chemical and microbial contaminants and contaminant groups.

The original committee consisted of 14 volunteer experts in water treatment engineering, toxicology, public health, epidemiology, water and analytical chemistry, risk assessment, risk communication, public water system operations, and microbiology. During the first phase of the study February through July , the committee convened twice, leading to the development of its first report, Setting Priorities for Drinking Water Contaminants NRC, a. That report recommended a phased decision process, time line, and related criteria to assist EPA efforts to set priorities and decide which CCL contaminants should be subjected to regulation development, increased monitoring, or additional health effects, treatment, and analytical methods research.

It also includes a review of several past approaches to setting priorities for drinking water contaminants and other environmental pollutants. First and foremost, the report emphasizes the need for expert judgment throughout this process.

Mission Statement

However, a cost-benefit analysis and the required determination to regulate or not must be completed within three years after the interim rule, and the rule must be repromulgated or revised if necessary. During the first phase of study, the committee also organized and conducted an NRC workshop on emerging drinking water contaminants and subsequently published a second report entitled Identifying Future Drinking Water Contaminants NRC, b. That report includes a dozen papers presented at the workshop by government, academic, and industry scientists on new and emerging microbiological and chemical drinking water contaminants, associated analytical and water treatment methods for their detection and removal, and existing and proposed environmental databases to assist in their proactive identification and potential regulation.

The workshop papers are preceded by a short committee report that provides a conceptual approach to the creation of future CCLs.

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The committee strongly urged EPA to consider the benefits of a more careful, detailed assessment of the CCL development process, especially regarding the identification of critical drinking water contaminants for regulatory activities from among tens of thousands of potential candidates. This chapter provides a brief summary of the purpose, development, and implementation status of the CCL, an overview of the recommended two-step process for the generation of future CCLs, and an overview of two closely related programs required by the amended SDWA.

Chapter 2 describes important sociopolitical issues that EPA should consider when prioritizing contaminants for inclusion on future CCLs. Chapter 3 provides some initial recommendations for conducting the first step of the CCL development process. Chapter 4 describes in detail the second step of the recommended CCL development process and includes a general discussion of how EPA can implement the recommended approach.

Chapter 5 builds on Chapter 4 and provides an overview and pros and cons of several classification approaches that EPA could use to help develop future CCLs. It also provides and discusses the results of. Shortly after passage of the SDWA Amendments and prior to the development of the first CCL, EPA began work on a conceptual, risk-based approach to identifying and selecting unregulated chemical and microbiological drinking water contaminants as priorities for its drinking water program. This conceptual approach, called the contaminant identification method CIM , was intended to identify and classify potential contaminants into several possible regulatory and nonregulatory categories for future activities EPA, b.

These categories included contaminants to be placed on the CCL for future regulatory determinations , those requiring further toxicological research, those recommended for monitoring, those needing health advisory development or other guidance, and those for which no action was required. The CIM was also intended to be used to reevaluate currently regulated drinking water contaminants as periodically required under the amended SDWA. Its 15 members are appointed by the Office of Ground Water and Drinking Water, represent a broad base of interests and expertise, and serve staggered three-year terms.

At the first meeting of the working group, EPA proposed a total of contaminants including 25 microorganisms taken from 10 lists of potential drinking water contaminants as a reasonable starting point for developing the draft CCL EPA, a. A total of eight lists—most originating from a variety of EPA programs see Table 1—1 —and chemicals and chemical groups were ultimately retained and evaluated by EPA.

EPA also specifically deferred consideration of 21 contaminants for the draft CCL based solely on the possibility of their being endocrine disruptors and of 35 pesticides pending further evaluation of their potential to occur at levels of health concern see Tables 4—2 and 4—3 of NRC, a. At the recommendation of the working group, EPA first evaluated each chemical according to whether it had demonstrated or potential occurrence in drinking water EPA, a.

Only those contaminants that met either of two criteria for occurrence were subsequently and similarly evaluated for evidence or suspicion that they cause adverse health effects via drinking water or other exposure routes. Also at the recommendation of the working group, EPA sought external expertise in identifying and selecting potential waterborne pathogens for inclusion on the draft CCL EPA, a. For this purpose, EPA convened a workshop of microbiologists and public health specialists and provided an initial list of microorganisms for their immediate consideration EPA, b.

The list included bacteria, viruses, protozoa, and algal toxins selected on the basis of disease outbreak data, published literature documenting the occurrence of known or suspected waterborne pathogens, and other related information. The evaluation also assessed the basic research and data needs for each microorganism. When published, the draft CCL included every microbiological contaminant recommended by the workshop participants and subsequently adopted by the full NDWAC.

The NDWAC Working Group on Occurrence and Contaminant Selection consisted of engineers, microbiologists, toxicologists, and public health scientists from government agencies, water utilities, and other stakeholder groups. Excluding disinfection by-products for which regulations were being developed under the Disinfectants and Disinfection Byproducts Rule. List of non-target contaminants identified in public water systems in anticipation of the DWPL. Chemicals that met criteria for assessing the potential of a contaminant to occur in public water; derived from a TRI list of chemicals.

Pesticides and degradates taken from OPP ranking of pesticides from highest to lowest potential to reach groundwater. The draft CCL included 58 unregulated 6 chemical and 13 microbiological contaminants and contaminant groups chemical contaminants were further divided into preliminary data need categories such as those requiring additional health effects data but not occurrence data and was made publicly available for comments in the Federal Register EPA, a. EPA considered all comments, data, and other information provided by the public and several stakeholder groups in preparing the final CCL.

The final CCL EPA, a comprises 60 contaminants and contaminant classes, including 10 microbial contaminants and groups of related microorganisms and 50 chemicals and chemical groups, as alphabetically listed in Table 1—2. A total of four microorganisms and eight chemicals and chemical groups were removed from the draft CCL.

However, one chemical perchlorate and one broad group of microorganisms cyanobacteria, other freshwater algae, and their toxins were added based on public comments and the continued input of the working group. With the exception of sulfate see footnote 6 , the CCL includes contaminants that are not currently subject to any proposed or promulgated primary drinking water regulation, but are known or anticipated to occur in public water systems and may require regulation under the SDWA EPA, a.

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Figure 1—1 summarizes the current time line for the development, promulgation, and implementation of the CCL and future CCLs and two other related programs required under the amended SDWA that are described later in this chapter. In accordance with the SDWA Amendments of , all contaminants on the CCL were not subject to any proposed or promulgated national primary drinking water regulation, with the exception of nickel, aldicarb and its degradates, and sulfate, which were included because of prior obligations to complete regulatory action for them EPA, a.

Triazines and degradation product of triazines including, but not limited to Cyanizine [—46—2], and atrazine-desethyl [—65—4]. As noted by EPA, sufficient data are necessary to analyze the extent of exposure and risk to populations particularly for vulnerable subpopulations such as infants and immuno-compromised persons as mandated by the amended SDWA via drinking water in order to determine appropriate regulatory action EPA, a, b.

If sufficient data are not available, additional data must be obtained before any meaningful assessment can be made for a specific contaminant. In this regard, a table listing several categories of preliminary data needs for all chemicals on the draft CCL EPA, a was expanded to include the microorganisms on the final CCL. It is important to note that there has been periodic reassignment of contaminants into and. Thus, the contaminants in this next-step category will be used to select five or more contaminants for which EPA will make a determination to regulate or not by August This category also includes those contaminants sodium and Acanthamoeba for which EPA intends to develop nonenforceable guidance rather than drinking water regulations.

At present, only those contaminants in the regulation determination priorities category that ultimately receive a decision to be regulated, not regulated, or issued a health advisory will be removed entirely from the CCL process i. As noted previously by the committee NRC, a , the first CCL began as an essentially unranked list of research needs for drinking water contaminants.

Additional research and monitoring must be conducted for many, if not most, of the contaminants on the current CCL as indicated in Table 1—3 EPA, b. Thus, EPA faces a daunting task in assessing the available scientific information about CCL contaminant risks and, based on that assessment, making a risk management decision about which contaminants should be moved off one of the research lists and into regulatory action.

More specifically, this research is intended to identify the scientific and engineering data needed and to characterize the risks posed by CCL contaminants. It is beyond the scope of this report to describe the CCL research strategy in great detail. However, the committee notes that several elements from its first report NRC, a for setting regulatory and research priorities for contaminants already on a CCL have been incorporated by EPA and an overview.

Aldrin b. Dieldrin b. Metolachlor b. Metribuzin b. Organotins c. Caliciviruses e. Coxsackieviruses e. Cyanobacteria blue-green algae e. Echoviruses e. Helicobacter pylori e. Microsporidia e. Acetochlor e. Alachlor ESA e. Diazinon e. DCPA mono-acid degradate b. Triazines and degradation products d. What analytical methods are needed to adequately address occurrence, exposure, health effects, and treatability issues?

What are the occurrence and exposure issues associated with CCL contaminants in source water, finished water, and drinking water distribution systems? Are there significant health risks associated with exposure to CCL contaminants? How effective are candidate treatment technologies for controlling CCL contaminants? Phase I is a screening level effort in which the CCL contaminants are evaluated with regard to available methods, health risk, and treatment information. This screening process involves the examination of minimum data sets that can be used to determine if a contaminant should be moved into the regulatory determination priorities category of the CCL or moved into Phase II.

In Phase II, a more in-depth examination is conducted to determine whether the contaminant should be recommended for regulation, guidance should be developed, or a recommendation not to regulate should be made. In general, Phase II research involves the generation of a comprehensive database for each CCL contaminant on its health effects, analytical methods, occurrence, exposure, and treatment options. In addition, several expert workshops that helped in developing the CCL itself were used to help identify research needs for specific contaminants.

Representatives attended the meeting from the water utility industry, state and federal health and regulatory agencies, professional associations, academia, and public interest groups, and recommendations and results from the meeting were incorporated into the CCL Research Plan. Recommendations from that panel were utilized in developing the two-phased research approach outlined in the CCL Research Plan report. Implementation of the CCL Research Plan will require the coordinated efforts of both government and nongovernment entities, as did its creation EPA, b.

In this regard, EPA intends to make all aspects of CCL research planning, implementation, and communication a collaborative process through a series of public workshops and stakeholder meetings held periodically over the next few years.

Several public commenters on the draft CCL also noted the need for a more systematic and scientifically defensible approach to selecting contaminants for future CCLs EPA, c. Chapter 2 of this report more fully describes these and other limitations, especially as related to various sociopolitical issues surrounding the development of future CCLs. Partly due to these limitations, the committee recommended in its second report NRC, b that a new type of screening process be used to identify and evaluate a broader universe of microbiological, chemical, and other types of potential drinking water contaminants in order to provide a more objective list of contaminants of concern.

The NCOD stores data on the occurrence of both regulated and unregulated drinking water contaminants.


It is intended to support EPA efforts in the identification and selection of contaminants for placement on future CCLs; subsequent and related research, monitoring, and regulatory activities; and the periodic six-year review of existing drinking water regulations for possible modification as required under the amended SDWA EPA, g. EPA requested input from the. The first release of the NCOD became operational in August as mandated and included occurrence data on various physical, chemical, microbial, and radiological contaminants found in public water systems and ambient source water EPA, g. The second release of NCOD became operational in late August and included several changes intended to increase its functionality.

In brief, the public right-to-know query allows a user to query the database for a specific contaminant in specific political jurisdictions i. Last, the regulation revision query also still under construction will allow users to view summary data and to download a data set that could be used in the periodic revision of existing NPDWRs as required under the amended SDWA. The NCOD does not contain occurrence data from every public water system or from every state.

However, not all states and territories, or PWSs within states and territories, have reported data for either type of contaminant data as yet. Furthermore, the historical data goes back only to However, detections do not necessarily mean that the contaminant would be found at the tap. Ambient occurrence data are provided to identify presence in a watershed; however, contaminant occurrence in the ambient data does not imply that the contaminant is also present in a nearby PWS. Although the NCOD data sets will be updated over time, they may still reflect a lag time of at least six months from data provided directly from a PWS.

The amount of occurrence data already stored in the NCOD is quite large and is expected to increase by as much as 1 gigabyte 1, megabytes each quarter. The inventory is updated every year by December More information about the expected development of these water quality standards is available in the work plan for to The rulemaking docket has more information about the status of water quality standards projects in rulemaking Group 1 in the inventory : Public Rulemaking Docket mm-rule Water quality standards are the fundamental regulatory and policy foundation to preserve and restore the quality of all waters of the state.

They consist of three elements:. All groundwater is assigned the Class 1 beneficial use of domestic consumption drinking water. Surface waters that cannot meet Class 2 aquatic life and recreational uses are Class 7 waters, otherwise known as limited resource value waters. Class 7 waters are still expected to meet standards that are protective for downstream waters and other beneficial uses. Numeric standards are allowable concentrations of specific chemicals that, when present in a water body, will protect designated beneficial uses.

They also include measures of biological health. Numeric standards are derived using methods provided in Minnesota rules and are specific to each beneficial use. This means a numeric standard that protects Class 2 waters for aquatic life and recreation may be different from a numeric standard for the same pollutant that protects Class 4 waters for agricultural uses and wildlife. When numeric standards exist for more than one beneficial use class, the most stringent value applies.

Some standards are narrative rather than numeric. A narrative water quality standard is a statement that prohibits unacceptable conditions in or upon a water body.

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Narrative standards address very fundamental and basic forms of water pollution, such as floating solids, scums, visible oil film, or nuisance algae blooms. Some narrative standards are more involved and set water quality goals in connection with specific pollutants or concerns, such as eutrophication, and pollutants that accumulate in fish and are harmful to fish consumers people and wildlife.

The MPCA conducts biological monitoring and employs the recently adopted Tiered Aquatic Life Uses TALU framework to provide a more direct method to assess biological health; biological monitoring complements the information provided by chemical pollutant monitoring. Both data sets are used to assess whether Class 2 aquatic life uses are being met. Numeric and narrative standards are not available for all pollutants and water quality concerns.

When needed, Minnesota rules provide for the development of site-specific criteria to address pollutants and concerns for which standards are not available. Also, numeric standards in rule can be modified based on site-specific data. More information about both is available on the site-specific water quality standards webpage.

Antidegradation formerly referred to as nondegradation is the third element of water quality standards. Antidegradation protections help maintain high quality waters waters better than what is necessary to protect aquatic life and recreation from deterioration. Antidegradation protections were established to provide future generations with the opportunity to enjoy high quality and highly valued recreational and aesthetic resources that might suffer degradation without them.

Preventing degradation is almost always less costly and more effective than restoration, which cannot always be fully achieved. Additionally, all surface waters in the Lake Superior basin are designated as outstanding international resource waters OIRWs.

Water Quality

Antidegradation protections for the Lake Superior basin focus on reducing the contribution of bio-accumulative pollutants to the basin. Determining the specific uses and subclasses for which an individual waterbody is protected requires a little research. Listed waters.

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The listings in Minn. Lakes and wetlands are listed directly in Minn. Minnesota R. The vast majority of surface waters are not listed and will not be in Minn. Unlisted waters.