Volume 45 Number 4
A Matter of Public Trust -- A Review of the NSF Conference on POU/POE for SDWA Compliance
Florida Conference Gathers Prominent Stakeholders to Review POU/POE Treatment for Achieving Public Water System Compliance
Is it practical for central treatment facilities to use point-of-use/point-of-entry (POU/POE) water treatment as a means to achieve compliance with the Safe Drinking Water Act (SDWA)?
In light of the recent change to the regulated arsenic standard, dropping the maximum contaminant level (MCL) for drinking water from 50 parts per billion (ppb) to 10 ppb, many now view POU/POE technologies as being not only practical, but quite possibly a necessity.
To facilitate both education and action on this issue, NSF International and the NSF Center for Public Health Education recently held a conference, “Public Water System Compliance Using Point-of-Use and Point-of-Entry Treatment Technologies,” on Feb. 13-14, in Orlando, Fla. More than 120 professionals attended the conference representing a cross-section of the stakeholder community. A total of 16 experts—ranging from state and federal regulatory officials, utilities, consultants and industry representatives—presented on the many aspects of using POU/POE as a compliance tool. This was the second NSF conference in a series targeted at specific risk management issues affecting the POU/POE industry, with the first being the “NSF International and World Health Organization Symposium on HPC Bacteria in Drinking Water – Health Effects?” held in Geneva, Switzerland, April 21-23, 2002.
While we often think in terms of the utilities and the POU/POE industry as being the drivers behind this initiative, the USEPA was quick to point out the importance of the consumers and, more specifically, their veto power. Considering these devices need to be installed and maintained in the home, consumers have ultimate control over the ability to provide treated water. Emphasis was placed on developing consumers’ confidence in advance through proper education. Participation of 100 percent remains a requirement of the SDWA, i.e., all homes and businesses must receive potable water whether by central treatment or POU/POE. Achieving this will be difficult, but more likely obtained through demonstration of an affordable and credible program with limited burden on the consumers. Independent product testing and certification to the ANSI/NSF standards was emphasized as a key element in achieving consumers’ confidence as well as a requirement of the SDWA.
Recognizing the primary benefit of using POU/POE devices as a compliance tool was affordability, the USEPA also reviewed its cost analysis studies. Equipment purchase vs. rental were both analyzed and compared to central treatment, taking into consideration POU/POE installation, maintenance, sampling, pilot demonstration, public education, waste disposal, record keeping and other factors. In the case of POU treatment for arsenic using reverse osmosis (RO), the point of convergence for all three options was approximately 100 households. Below 100, use of POU was more economical and, above that, central treatment was more economically feasible. In comparison to POE, the point of convergence came much earlier at around 25-50 homes due to the added cost of treating all water in the home rather than at a single tap. The comparison of rented vs. purchased equipment showed little difference in the break-even point when averaging cost over time, but clearly has an impact on initial cost to the homeowner. While the break-even point of 100 households for POU treatment may seem to be a limiting factor, the USEPA pointed out that 30 percent of all community water systems affected by the new arsenic rule serve fewer than 100 people.
The state perspective, as presented by representatives of Utah and Illinois, reflected on the added burden to states using POU/POE. As a compliance issue, states are given primacy by USEPA to implement the SDWA. In the case of POU/POE devices, new rules need to be drafted to allow for this option. In consideration of limited state resources, there was a need expressed to develop draft rules states can adopt more easily. The agency is considering a further rule adoption that would complement the existing SDWA while also providing additional assistance to states for simplifying their local adoption of appropriate regulations for the use of POU/POE.
Using a pilot study, the LADWP learned some of the challenges inherent with home installations. First, it found that equipment vendors and installers vary in how they approach the consumers. Some provided helpful information and education while others offered very little, impacting overall consumers’ confidence and comfort. Second, installation options can vary due to the age of the home, type of plumbing and ease of access. This brings into question the idea one technology can meet a community’s needs. Another finding related to the home environment and the realization utilities cannot control cleanliness of the home. This could impact issues such as proper sample collection.
While recognizing the shortcomings, LADWP voiced optimism POU devices can be used effectively for improving water quality and customer satisfaction. LADWP is updating its website to include information relating to POU including links to other related sites. Long-term considerations include vendor partnerships, rebate programs for those customers who make their own POU purchase, partnerships with consumer groups for enhanced education, and others.
NSF provided a detailed review of the available standards that exist today, the role of the American National Standards Institute (ANSI), and the process of achieving product certification. The 1996 amendment to the SDWA specifies use of only those products certified to the ANSI/NSF standards, where available. With nearly 5,000 models certified to NSF standards, it was made clear that there were many vendor and product options available to satisfy the need for use of POU/POE as a compliance tool.
Learning by example
Two of the pilots are targeted at POU devices for the treatment of arsenic. The performance of the selected technologies was shown to be acceptable to-date in both cases, demonstrating that the delivery of safe water from a POU installation can be achieved. Treatment technologies included RO, activated alumina, and granular ferric hydroxide. Cost analyses demonstrated a similar result to that of the USEPA, showing a break point between POU and central treatment somewhere under 200 connections, and clearly more cost effective using POU at 80 and fewer.
The third pilot is reviewing the use of POU/POE technologies in a more general scope including but not limited to compliance. Use of these devices in conjunction with all central treatment operations was evaluated, similar to the applications and opportunities identified above by LADWP. Consumers’ acceptance and confidence were again emphasized as major factors, and the advantages that utilities have with achieving customer confidence when introducing new approaches to water treatment. All three pilots are continuing in their investigations and will be publishing final reports later this year.
Future utility POU/POE use
The above issues, however, were balanced by the benefits, needs and opportunities POU/POE treatment can offer including the following:
(For more information on the USEPA’s role efforts, download “Guidance for Implementing a Point-of-Use or Point-of-Entry Treatment Strategy for Compliance with the Safe Drinking Water Act” at the USEPA website. To download copies of the presentations from the NSF Conference, visit the NSF website.)
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