A Viable Inorganics Compliance Strategy for Small Systems
By Warren Swanson, P.E.
The most economical source of potable water for very small systems run by rural municipalities, isolated residential communities and similar, isolated entities has long been groundwater tapped by a few wells. Often, there are limited concerns related to disinfection, disinfection by-products, or synthetic organic chemicals for such sources. However, recent regulatory activity focused on reducing exposure to naturally occurring inorganic constituents, such as arsenic, radon, and radionuclides, has begun to force the smallest of systems into making tough decisions about how to stay within the law and continue to provide service to customers. Because the burden of centralized treatment can force a small water provider out of business, regulatory bodies, including USEPA and CDPHE, are increasingly allowing point-of-use (POU) treatment as a viable compliance strategy.
This paper will present a case study of the recent approval by CDPHE for a POU treatment approach for a small, rural community struggling to comply with the fluoride MCL. The approval is one of the first of its kind in Colorado, and comes at a time when CDPHE is still in the process of developing its complete guidelines for such approvals.
Mount Princeton Homeowners? Association, Inc. (MPHOA) provides water service to approximately 50 homes. Its raw water source, Mount Princeton Hot Springs, is by most measures, pristine, except for 10 mg/L of fluoride. MPHOA had an easy time deciding to pursue POU treatment when faced with the steep price tag of constructing a centralized treatment facility. POU treatment is attractive due to its efficiency - only drinking and cooking water is treated (in the case of fluoride), units are pre-engineered, and no new land, structures, or residual handling facilities are required. Furthermore, for a system with a small number of homes (<100, or so), the administrative and maintenance burdens associated with a POU approach are still manageable.
MPHOA gained CDPHE approval in March 2004 for installation of under-the-sink reverse osmosis treatment units for fluoride removal. Units have been ordered and will be installed in May and June. This paper will present the project background and completed pilot testing program and approval processes. Most importantly, the development of a CDPHE-required management plan will be featured. Additional focus will be placed on the USEPA and CDPHE requirements that, although POU treatment devices are installed in private homes, the water provider is fully responsible for their proper installation, operation, regular maintenance, and routine performance monitoring. This creates multiple managerial challenges. The water provider (often not experienced in managing a treatment system) is required to use certified installers and water system operators, stock replacement parts, track compliance, train homeowners, deal with less-than-eager participants, and arrange for access to residences. Finally, lessons learned from installation and initial operational/management experiences during summer 2004 will be shared.
The experience at MPHOA reinforces that POU treatment provides a viable compliance option but certainly has its own set of challenges that cannot be ignored.
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