Drinking Water & Health Newsletter
October 1, 1993

Table of Contents

Bottled Water and Home Filters: Consumer Issues At a Glance
By Linda Golodner

Economic Impact of New Disinfectant/Disinfection By-Product Rule to Be Unevenly Distributed Among U.S. Households

Reg-Neg Committee Reaches Consensus on Disinfectant/Disinfection By-Product Rule

Water Industry Braces to Face Arsenic Juggernaut
By Drs. Marc Edwards and Gary Amy

1993 Floods and Public Health Protection

Bottled Water and Home Filters: Consumer Issues At a Glance
by Linda Golodner

The National Consumers League

In the last ten years, Americans have doubled the amount of bottled water they consume; they drink an average of eight gallons per person each year. The reason? Some consumers prefer bottled water over tap water. Health conscious consumers seek an alternative to alcoholic beverages or to soft drinks. According to a survey by the International Bottled Water Association (IBWA), which asked respondents why they preferred bottled water to tap water, taste was the number one factor.

In the United States, there are more then 600 domestic and 75 imported brands of bottled water. They come in a variety of forms. Some contain dissolved minerals and others have mineral salts such as bicarbonates, citrates or sodium phosphates added for taste or fizz. Some have added sweeteners or flavors such as lemon-lime, strawberry or orange. Prices vary from a few cents a glassful to several dollars for a large jug. They come in fancy glass or plastic containers or in large five gallon jugs.

Bottled water quality standards were originally adopted in 1973, based on the 1962 U.S. Public Health Service standards for drinking water. While the Environmental Protection Agency (EPA) regulates community drinking water, the Food and Drug Administration (FDA) has jurisdiction over bottled water. Under the Safe Drinking Water Act, the FDA is responsible for ensuring that standards are compatible with those the EPA sets for quality and safety of tap water. The FDA also determines acceptable levels for contaminants that may be in bottled water.

But doubts about the safety and quality of bottled water have arisen. According to the FDA, approximately 75 percent of bottled water comes from protected springs and wells. The other 25 percent is derived from municipal water systems. Some bottled water sources have been shown to contain levels of potentially harmful contaminants that are not allowed in municipal tap water. The result is that consumers have little understanding about the source or the quality of the bottled water they purchase.

In response to several state initiatives to better control the chemical and microbiological quality of bottled water, the IBWA petitioned the FDA earlier this year to propose new regulations for the industry. Under the current proposal, nutrients such as iron, sodium and calcium that are present in significant amounts must be disclosed. Unfortunately, the proposed regulations would continue to exclude products labeled as carbonated, seltzer, soda and tonic water, which are considered soft drinks.

The proposed regulations would, however, adopt a consistent national standard for identifying the source of bottled waters, defining various product terms such as distilled, mineral, purified, spring and artesian. These definitions now differ from state to state. For example, in some states spring water refers only to water that has been collected from a natural orifice in the earth's surface. In other states, it can be both water that has been collected from a natural orifice or from a bore hole that taps the spring and is located near where the spring emerges.

Under the proposed regulations, labeling also would be standardized to prevent some existing misleading practices. Current labeling confuses consumers, and the proposed rule changes aim to promote honesty and fair dealing. Most notably, these regulations would require disclosure through a declaration on the label if a bottled water is derived "from a municipal source." The FDA will establish new limits on approximately 50 chemicals and other contaminants including mercury, copper, barium, cadmium and lead that may be present in bottled water.

Bottled water, being a "manufactured" product, is subject to practical qualitycontrol measures that are simply not feasible for community water supplies. Like other foods, bottled water must be processed, packaged, shipped, and stored in a safe and sanitary manner, and must be truthfully and accurately labeled. Filtration, usually with granular activated carbon, is standard procedure when bottling, even for mineral waters and other waters from natural sources. This is a routine industry practice to improve the taste and appearance of bottled water products.

Municipal drinking water suppliers have less control over the quality of their product since the delivery system is partially owned by the consumer (i.e., water service lines and internal plumbing systems). That is one of the reasons public water suppliers use chlorine and filtration to protect against microbial disease organisms from the treatment plant to the consumers' tap. The final water disinfectant used by most of the nation's 430 bottling facilities is ozone which, when compared to chlorine, produces less residual taste and odor, but does not provide a disinfectant residual. Thus, some bottled waters have been shown to contain quantities of bacteria because no residual disinfectant is used in these products.

Since improving the taste and removing impurities such as lead are important to consumers, some people treat their own tap water with an array of water purifiers or filters. These devices range from complex, expensive reverse-osmosis systems to simple carafe filters that work something like drip coffee makers. Consumers should be on guard if someone tries to sell them a water treatment device, for it might not be needed. Consumers should be advised to have their water tested first to find out if there is a problem, and if they do purchase a water-treatment device, to check with the manufacturer to determine how often to change the filter. Filters must be replaced often or impurities will be "filtered" right back into their water.

ECONOMIC IMPACT OF NEW DISINFECTANT/DISINFECTION BY-PRODUCT RULE TO BE UNEVENLY DISTRIBUTED AMONG U.S. HOUSEHOLDS

As the U.S. Environmental Protection Agency's (EPA's) Regulatory Negotiation (Reg-Neg) process for drinking water disinfectants and disinfection by-products (D/DBP) draws to a close, interest is now focused on the economic impact that this and other rules will have on treatment facilities and ratepayers. Estimates submitted to the EPA Reg-Neg Committee suggest that some households may witness dramatic increases in their annual water bills while others may not be affected at all.

Other pending drinking water rules, including the Enhanced Surface Water Treatment Rule (ESWTR) and the Information Collection Rule (ICR) also may result in escalating costs. In fact, some Reg-Neg participants estimate that the ESWTR may be as costly to implement as the proposed D/DBP Rule.

As proposed, the D/DBP Rule, which will reduce limits for disinfection by-products, will be adopted in two phases. Phase I of the Rule would lower the maximum contaminant level (MCL) for total trihalomethanes (TTHMs) from the current MCL of 100 parts per billion (PPB) to 80 PPB and establish a new MCL of 60 PPB for haloacetic acids. Phase II would further reduce these MCLs to 40 PPB and 30 PPB, respectively. Currently, the median effluent concentration of TTHMs at U.S. treatment facilities is 45 PPB in surface water systems and 20 PPB in groundwater systems.

As the proposed Rule stands, states with poor source water quality (i.e. high Total Organic Carbon (TOC) and/or bromide content) and minimal existing treatment systems are likely to be affected the most by the D/DBP Rule. Indeed, more than eight million households may incur annual water rate increases ranging from $50 to over $300. California, Texas and Florida are likely to be affected the most.

Compliance Costs

Water utilities will spend about $4.4 billion on plants and equipment to comply with Phase I of the D/DBP Rule. As a result, nearly 50 million of the 97 million U.S. households will incur increased water rates as a result of the enforcement of Phase I.

Phase II of the D/DBP Rule, which calls for a 60 percent reduction in disinfection byproduct levels from current limits, will result in additional capital costs of up to $3.5 billion for large surface water systems (serving more than 10,000 people).

Additionally, the ICR will add another $130 million to $150 million to the price tag of the D/DBP Rule. The ICR requires certain treatment facilities to conduct pilot studies on different organic precursor removal techniques such as membranes and carbon filters - and to gather occurrence data for disinfection by-products.

The ESWTR and the Groundwater Treatment Rule, which are not yet developed, also are expected to have a significant economic impact on the nation's treatment facilities and ratepayers.

Source: Wade Miller Associates, Inc.

REG-NEG COMMITTEE REACHES CONSENSUS ON DISINFECTANT/DISINFECTION BY-PRODUCT RULE

The U.S. Environmental Protection Agency's (EPA's) Disinfectant/Disinfection By-Products (D/DBP) Regulatory-Negotiation (RegNeg) Committee has reached a consensus on the major provisions of the proposed D/DBP Rule package.

As proposed, the D/DBP Rule will consist of two phases and include new maximum contaminant levels (MCLs) for disinfection by-products which are up to sixty percent lower than existing Rules. Phase I will set MCLs at 80 PPB for trihalomethanes and 60 PPB for haloacetic acids. In Phase II, MCLs for those by-products will be set at 40 PPB and 30 PPB, respectively.

The EPA currently is compiling final comments and completing the draft Rule and preamble. The draft Rule and preamble will be reviewed by Reg-Neg Committee participants before statements of endorsement are signed, and the D/DBP Rule is expected to be proposed later in 1994.

How the 40/30 MCLs are characterized in the draft Rule preamble is of significant importance to the drinking water industry. Throughout the Reg-Neg process, these numbers have been referred to as "backstops" or "placeholders" to encourage all parties to return to the negotiating table for the second round of regulatory negotiations (Reg-Neg 2). Industry representatives have expressed concern that these MCLs may be incorrectly cast in the Rule's preamble as valid targets, based on scientific and technical data.

Also included in the D/DBP Rule effort is the drafting of a separate preamble and regulatory language for the Information Collection Rule (ICR). The ICR is to be proposed in December and adopted in June, 1994, with an 18-month implementation period to follow.

The ICR will require large and medium-size water utilities (all utilities serving more than 10,000 people) to obtain extensive monitoring data on raw water characteristics, including Giardia and Cryptosporidium, as well as data on disinfection by-product occurrence. Bench- and pilotscale testing of precursor removal technologies, such as activated carbon and/or membranes, also will be required. It is estimated that the information collection phase will cost the water industry up to $150 million. (See related story).

The ICR is expected to provide important data for use in Reg-Neg 2, which is expected to occur during 1997 and 1998.

According to the EPA Office of Water staff, the EPA Science Advisory Board (SAB) is expected to review the rulemaking packages in the near future so that the SAB's comments and recommendations can be made available during the public comment period. The SAB had initial discussions concerning its role in the regulatory review at its meeting on August 16-17.

The D/DBP Rule is part of the EPA's mandate under the Safe Drinking Water Act (SDWA) to establish regulations for 25 new contaminants every three years. The SDWA was enacted in 1974 to ensure the safety and quality of the nation's drinking water. For additional information on the Reg-Neg process, contact the U.S. EPA Safe Drinking Water Hotline at 800-426-4791.

WATER INDUSTRY BRACES TO FACE ARSENIC JUGGERNAUT

Results of recent epidemiological research indicates that trace levels (parts per billion (PPB)) of arsenic in public drinking water may be more dangerous than previously suspected. The U.S. Environmental Protection Agency (EPA) is currently considering more stringent regulations to minimize these risks.

Recent concerns are based on evidence collected from studies on long-term exposures to arsenic in drinking water which were conducted in Taiwan. These studies have shown an association between arsenic and liver, lung, kidney, bladder and skin cancers. Earlier studies probably confounded the timely identification of arsenic risk since arsenic is an essential trace nutrient and does not cause cancer in laboratory rodents.

EPA Regulations

Current EPA regulations for arsenic have been established at the EPA maximum contaminant level (MCL) of 50 PPB. However, the new findings have indicated that the lifetime risk of dying from arsenic induced cancer could be higher than initially considered, which is driving the EPA to consider setting significantly lower MCLs. While arsenic toxicity can vary, the proposed regulations likely will establish MCLs for total arsenic at between 0.5 PPB and 5 PPB.

Limitations in available technology have made it difficult to measure the nationwide occurrence of trace arsenic in public water supplies, thus it has been impossible to estimate the impact of a projected EPA MCL of between 0.5 PPB and 5 PPB. However, a 1993 national survey conducted by the Association of California Water Agencies (ACWA) using advanced analytical techniques indicated that about 50 percent of all sampled utilities had drinking water arsenic concentrations above 0.5 PPB. That survey also demonstrated the regional nature of the problem, showing the highest arsenic levels in Western United States' utilities and in some smaller systems that rely on isolated groundwater supplies.

Compliance Costs

While compliance costs also are unclear, the EPA has estimated that meeting an MCL of two PPB will cost about $6 billion nationwide, making the regulation one of the costliest to date. Current treatment options include activated alumna, reverse osmosis, ion exchange, coagulation, lime-softening and electrodialysis. However, not much is known regarding the inherent versus optimized removal attainable using such processes, and it is particularly worrisome that the techniques are largely untested in water sources with very low levels of arsenic.

The water industry is responding aggressively to fill knowledge gaps and to address the technical challenges posed by the anticipated regulation. The American Water Works Association currently is either sponsoring or planning research on improving arsenic detection, new analytical techniques, arsenic occurrence, and improving arsenic removal by treatment through its Research Foundation and Water Industry Technical Action Fund. It is anticipated that these efforts will assist the decision-making process before the new regulation is published in September, 1994, and help utilities meet the new standard when the final Rule is promulgated two years later.

PROTECTION FROM LEAD CONTAMINATION REQUIRES A COOPERATIVE EFFORT

Where's the Lead?

A recent report by the American Water Works Association (AWWA)¹ indicates that 82 percent of large water treatment systems (serving over 50,000 people) reported lead levels below the U.S. Environmental Protection Agency (U.S. EPA) First Draw Action Level (AL) of 15 parts per billion (PPB). First-Draw AL tests, conducted periodically by utilities, indicate whether lead levels are above or below 15 PPB and whether action (i.e. corrosion control) must be taken to lower lead levels.

Of the 18 percent of utilities that exceeded the AL, there is a strong and consistent correlation between AL exceedances and geographic regions of the country. When categorized by U.S. EPA Regions, as in the map below, Regions I, II and X have the highest percentages of AL exceedances and Regions VI through IX have the lowest.

Generally, elevated lead levels in tap water samples are caused by corrosive water that leaches lead from homeowners' plumbing systems. Source waters in Regions I through V and Region X have either a low pH or a low alkalinity (or both), which can cause aggressive corrosion of metal pipe and plumbing fixtures. It is in these regions that water utilities and customers need to act.

What Should Be Done When Elevated Lead Levels are Found?

Though lead in the source water is rare, water utilities must provide removal treatment or find alternative lead-free sources for those areas that have lead problems. Those utilities with corrosive water also must implement treatment to reduce the corrositivity of the finished water. Raising the pH above 7.5, increasing alkalinity, and/or adding chemical corrosion inhibitors all have been effective at accomplishing this.

Customers who use tap water also have an important role in reducing their exposure to lead. Since the utility treats the water until it reaches a residence, homeowners must ensure that their home plumbing systems do not contaminate the water supply.

If corrosive water is allowed to "stand" in a pipe for a long time, extremely high lead levels can result. One of the highest reported lead levels occurred in a seldom used, second-floor bathroom with lead soldered copper plumbing and a lead brass faucet. Tragically, the only time this faucet was used was to make a night-time bottle of infant formula for a baby.

Homeowners can minimize their exposure to lead with some simple steps:

• determine if leaded materials are in your system (check lead pipes, lead soldered joints, and brass faucets)

• before use, flush each cold water faucet where water stands more than a few hours

• do not cook with or consume water from the hot water faucet, as hot water dissolves lead more quickly than cold water

• when plumbing repairs are made, make certain that lead-free solder is used

Finally, utilities and homeowners must work together to remove lead service lines, where necessary. For many years, it was common practice in some places to install lead service lines to connect the home to the water main. Many lead service lines are still in use and can contribute to elevated lead levels. Today, in some cities, lead service lines are owned entirely by private homeowners. In this case, the utilities must rely on homeowners to replace the lines since the utilities have no authority to do so. However, the issue is further complicated in other communities where ownership of the service line is split between the utility and the homeowner.

Water suppliers and homeowners need to work together to ensure that drinking water is healthy and lead-free. Water utilities must inform customers if lead is a problem in their area and customers must take the necessary steps to minimize their exposure to lead.

Based in Houston, Texas, T David (Tim) Chinn is a principal with the environmental consulting firm of Montgomery-Watson (formerly James M. Montgomery Engineers). Prior to joining Montgomery-Watson, Tim was the Assistant Director of Governmental Affairs for AWWA 's Washington, D.C. office.

¹For copies of the report - Initial Monitoring of LArge Water Utilities Underr U.S. EPA's Lead and Copper Rule,, contact: AWWA 6666 West Quincy Avenue, Denver, Colorado, 80235, (303) 794-7711.

1993 FLOODS AND PUBLIC HEALTH PROTECTION

The devastating Midwest floods this summer swept away homes, farms, and communities, and with them, the idea that we can take a safe, healthy lifestyle for granted. Disasters of this magnitude can rapidly remove the comforts of late-twentieth-century living and expose us to the public health verities of America 100 years ago.

For many, the greatest shock of the flooding was how quickly the basic necessities of life were eliminated. A levee would break and suddenly entire towns were faced with inadequate shelter, no food and no safe water. Things we take for granted every day turning on the faucet and having a glass of safe water without a second thought; opening the refrigerator and having access to uncontaminated food; turning on the stove and preparing supper - were no longer possible.

The floods underscore the point that the dangers of unsafe water and contaminated food are not unimaginably distant. Filthy water and sewage running through open gutters in the street were commonplace in Houston following rains in the first decade of this century. Outbreaks of cholera, typhoid and dysentery were frequent 75 people in every 100,000 died annually from typhoid fever. Real, tangible public-health risk was a part of their daily existence.

Risk assessors tell us that risk is defined as encompassing both the likelihood of something negative occurring and the consequences of that occurrence. As the flooding reminds us, we must be prepared for those events with a low probability yet enormous consequence. Natural disasters can quickly break down the barriers. Very quickly, hundreds of thousands of Americans can be exposed to the very real health risks of decades ago.

Public Health Advisory Board

Sanford M. Brown, Jr.
School of Health and Social Work,
California State University, Fresno

Bruce K. Bernard, PH.D.
SRA International
Washington, DC

Linda Golodner
National Consumer League
Washington, DC

Ralph Morris
Galveston County (Texas)
Health District

Fred Reiff
Pan American Health Organization
Washington, DC

The U.S. Environmental Protection Agency Regulatory Negotiation Committee

The U.S. EPA and several other organizations are represented on the Disinfectant/Disinfection By-Product Reg-Neg Committee.

The U.S. EPA
Represented by James Elder
Director
Office of Groundwater & Drinking Water

Stig Regli
Regulation Manager
Office of Groundwater & Drinking Water

Drinking Water & Health Newsletter is a Publication of the Public Health Advisory Board to the Chlorine Chemistry Division of the American Chemistry Council

Other Organizations Represented

Center For Neighborhood Technology
Chicago, Illinois

Commerce Department
Portland, Oregon
Water Bureau

New Jersey Department of Environmental Protection

National Consumer Law Center
Washington, DC

Environmental Defense Fund
Washington, DC

American Water Works Association
Denver, Colorado

National League of Cities
Washington, DC

Association of Metropolitan Water Agencies
Washington, DC

National Water Resources Association
Arlington, Virginia

Association of State and Territorial Health Officials
Washington, DC

Natural Resources Defense Council
Washington, DC

Boston University School of Public Health

Pennsylvania Office of The Consumer Advocate

National Association of Water Companies

County Health Department

Englewood,Colorado

Chlorine Chemistry Division of the American Chemistry Council