3
Highest Priority Issues

The second major task of the committee was to identify the highest priority issues for consideration during TCR revision to encompass distribution system integrity. The issues considered for prioritization stem directly from nine white papers created during a series of expert and stakeholder workshops convened by EPA and others from 2000 to 2003. The nine white papers focused on the following events or conditions that can bring about water quality degradation in public water supply distribution systems:

  1. Cross-Connections and Backflow (EPA, 2002b)

  2. Intrusion of Contaminants from Pressure Transients (LeChevallier et al., 2002)

  3. Nitrification (AWWA and EES, Inc., 2002e)

  4. Permeation and Leaching (AWWA and EES, Inc., 2002a)

  5. Microbial Growth and Biofilms (EPA, 2002d)

  6. New or Repaired Water Mains (AWWA and EES, Inc., 2002e)

  7. Finished Water Storage Facilities (AWWA and EES, Inc., 2002c)

  8. Water Age (AWWA and EES, Inc., 2002b)

  9. Deteriorating Buried Infrastructure (AWWSC, 2002)

In addition to these papers, the committee considered the summary of the Distribution System Exposure Assessment Workshop (ICF Consulting, Inc., 2004), held in Washington, DC in March, 2004, which attempted to collate all of the information gathered in the previous workshops. Additional white papers are currently being written on the following topics, but were not available to the committee in time to be considered for this first report:

  • Indicators of Drinking Water Quality

  • Evaluation of Hazard Analysis and Critical Control Points

  • Causes of Total Coliform Positives and Contamination Events

  • Inorganic Contaminant Accumulation

  • Distribution System Inventory and Condition Assessment.

Some qualitative outcomes of the many workshops, as communicated by EPA officials, are that there are demonstrated adverse health effects and large potential exposure result-



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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report 3 Highest Priority Issues The second major task of the committee was to identify the highest priority issues for consideration during TCR revision to encompass distribution system integrity. The issues considered for prioritization stem directly from nine white papers created during a series of expert and stakeholder workshops convened by EPA and others from 2000 to 2003. The nine white papers focused on the following events or conditions that can bring about water quality degradation in public water supply distribution systems: Cross-Connections and Backflow (EPA, 2002b) Intrusion of Contaminants from Pressure Transients (LeChevallier et al., 2002) Nitrification (AWWA and EES, Inc., 2002e) Permeation and Leaching (AWWA and EES, Inc., 2002a) Microbial Growth and Biofilms (EPA, 2002d) New or Repaired Water Mains (AWWA and EES, Inc., 2002e) Finished Water Storage Facilities (AWWA and EES, Inc., 2002c) Water Age (AWWA and EES, Inc., 2002b) Deteriorating Buried Infrastructure (AWWSC, 2002) In addition to these papers, the committee considered the summary of the Distribution System Exposure Assessment Workshop (ICF Consulting, Inc., 2004), held in Washington, DC in March, 2004, which attempted to collate all of the information gathered in the previous workshops. Additional white papers are currently being written on the following topics, but were not available to the committee in time to be considered for this first report: Indicators of Drinking Water Quality Evaluation of Hazard Analysis and Critical Control Points Causes of Total Coliform Positives and Contamination Events Inorganic Contaminant Accumulation Distribution System Inventory and Condition Assessment. Some qualitative outcomes of the many workshops, as communicated by EPA officials, are that there are demonstrated adverse health effects and large potential exposure result-

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report ing from distribution system contamination. The stakeholder and industry experts who attended the workshops agreed on the need to evaluate and prioritize potential health risk. The approach to prioritization taken by the committee was based on a careful assessment of the issues presented in the nine white papers, critical evaluation of other materials, and on the committee’s assessment of the health importance of the various events. Given limited data on the specific causes of waterborne disease outbreaks, the best professional judgment of the committee was used to assess the magnitude of the health problem associated with an event, including how often the event occurs and how much contamination results when an event occurs. In addition to prioritizing the issues presented in the nine white papers, the committee also considered whether any significant issues had been overlooked by EPA when the white papers were written. It should be noted that EPA had a difficult task in developing these white papers. A water distribution system is a complex engineering and ecological system wherein multiple adverse changes may result from the same or similar underlying causes. For example, water that has a long residence time in the system (high water age) may also have the potential to lose disinfectant residual and undergo biological nitrification. Considering any of these occurrences in the absence of the others oversimplifies the nature of the problem. However, the committee decided to follow the structure of the EPA white papers in preparing this report, with the recognition that overlaps and difficult-to-separate phenomena exist. Of the issues presented in the nine white papers, cross connections and backflow, new or repaired water mains, and finished water storage facilities were judged by the committee to be of the highest importance based on their associated potential health risks. In addition, there are two other issues that should also be accorded high priority: premise plumbing and distribution system operator training. CROSS CONNECTIONS AND BACKFLOW Points in a plumbing system where non-potable water comes into contact with the potable water supply are called cross connections. A backflow event occurs when non-potable water flows into the drinking water supply through a cross connection, either because of low distribution system pressure (termed backsiphonage) or because of pressure on the non-potable water caused by pumpage or other factors (termed backpressure). Backflow incidents have long been recognized as significant contributors to waterborne disease. From 1981 to 1998, the CDC documented 57 waterborne outbreaks related to cross-connections, resulting in 9,734 detected and reported illnesses (Craun and Calderon, 2001). EPA compiled a total of 459 incidents resulting in 12,093 illnesses from backflow events from 1970 to 2001 (EPA, 2002b). For the period 1981 to 1998, EPA found that only 97 of 309 incidents were reported to public health authorities, demonstrating that the magnitude of the public health concern due to cross-connections is underreported. The situation may be of even greater concern because incidents involving domestic plumbing are even less recognized. In a study of 188 households, the University of Southern California’s Foundation for Cross-Connection Control and Hydraulic Research reported that

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report 9.6 percent of the homes had a direct cross connection that constituted a health hazard, and more than 95 percent had either direct or indirect cross connections (USC, 2002). Cross-connections are also of great concern where a potable system is in close proximity to a reclaimed water system (such as in dual distribution systems like that of the Irvine Ranch water district). A direct cross connection is a permanent physical interconnection between potable and non-potable water sources whereas an indirect cross connection has the potential for an interconnection (e.g., a janitor’s utility sink without a vacuum breaker on the hose bib). In most cases, the extent of the health problem caused by cross connections in homes is unknown—knowledge that could be obtained through epidemiological studies. Although most state and primacy agencies require that utilities have a cross connection control program, the elements of such programs, their implementation, and oversight vary widely. Because of inconsistent application of these programs, cross connections and backflow events remain a significant potential cause of waterborne disease. Proven technologies and procedures are available to mitigate the impact of cross connections on potable water quality. State plumbing codes define the type of plumbing materials that are approved for use, including cross connection control devices, but whether these codes are adhered to is questionable. Regulatory options that could be considered include requiring inspections for household cross connections at the time of home sale. Furthermore, training programs such as those offered by the New England Water Works Association to train and certify backflow device installers and testers have been successful in gaining support from the plumbing community and in developing local plumbing codes that require cross connection control. Given the availability of effective technologies for preventing cross connections, opportunity exists for substantial reductions in public health risk through the implementation of more effective cross connection control programs by primacy and state agencies. At the current time, it is unknown how effective various state programs are in actually preventing cross connections—an issue that is also ripe for further investigation. Because of the long history of recognized health risk posed by cross connections and backflow, the clear epidemiological and surveillance data, and the proven technologies to prevent cross connections, cross connection and backflow events are ranked by the committee as the highest priority. Efforts to provide implementation of a more uniform national cross connection program would have clear public health benefits. NEW AND REPAIRED WATER MAINS This section focuses on contamination arising from the exposure of distribution system water and pipe interior, appurtenances, and related materials to microbial and chemical contaminants in the external environment (1) during water main failures and breaks and (2) due to human activities to install new, rehabilitate old, or repair broken mains and appurtenances. When a pipe break or failure occurs, there is immediate potential for external contamination from soil, groundwater, or surface runoff (see Kirmeyer et al., 2001) to enter the distribution system or come into contact with the pipe interior in

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report the area of the failure. Furthermore, the storage, installation, rehabilitation, and repair of water mains and appurtenances provide an opportunity for microbial and chemical contamination of materials that come into direct contact with drinking water. Pierson et al. (2001) confirmed the possibility of such events by surveying distribution system inspectors and field crews. This section does not address contamination from the external environment that enters through cracks or leaks in pipe, pipe joints, or appurtenances (even though these can exist undetected for long periods of time), as these are covered under the intrusion section. Furthermore, periodic changes to the operation of the distribution system, such as valving the local water system to shut down mains for work and then reloading the mains before their return to use, can allow for contamination of the drinking water supply from backflow through unprotected domestic and fire connection services, which is covered under the section on cross connections and backflow. Craun and Calderon (2001), in summarizing waterborne outbreaks from 1971 to 1998, found that of the 12 largest outbreaks caused by distribution system deficiencies, one in Indiana was associated with contamination of main interiors during storage in the pipe yard or on the street prior to pipe installation. This review also recalled the well-documented 1989 waterborne disease outbreak in Cabool, Missouri, which was associated with water meter repair and two large water main breaks during the winter (see Clark et al., 1991; Geldreich et al., 1992). The loss of system pressure and ineffective system controls allowed external contamination, such as sewage, to come in contact with the water meters and pipe interior. In addition, the insufficient use of best practices such as post-repair disinfection allowed the contamination to spread through the distribution system. Although yet to be verified, the EPA white paper, New and Repaired Water Mains (AWWA and EES, Inc., 2002e), states that about 5 percent of reported waterborne disease outbreaks in the United States over a 27-year period were associated with main construction and repair activities. Over 200,000 water main breaks occur every year (over 555 breaks per day) according to Kirmeyer et al. (1994). Over 4,000 miles of pipe are replaced every year and over 13,000 miles of new pipe are installed every year. These numbers, along with the fact that disease occurrence is underreported and contamination from such activities would be highly localized and undetectable in most cases, suggest that exposure to contaminated drinking water from main breaks and installation, repair, and replacement activities is likely to be significantly greater than has been documented. ANSI/AWWA standards, particularly C600-99 for the installation of ductile iron mains and C651-99 for the disinfection of mains, are commonly employed to prevent microbial contamination during main rehabilitation and replacement (Pierson et al., 2001). However, the actual documentation and inspection of sanitary practices varies widely. Even well-run utility operations, for example, can experience a 30 percent failure rate in the approval of new mains based on water quality testing (Burlingame and Neukrug, 1993). Haas et al. (1998) reported that interior pipe surfaces are not free of microbial contaminants even under best case conditions. Thus, when a new main is installed or a valve is repaired, it is advisable to act as if some level of contamination has occurred to both the water and the materials. In both cases testing is required, and care should be

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report taken to address potential contamination before the affected portion of the water system is returned to use. Prevention of contamination can also be facilitated by including the existing standards and additional training on sanitary practices in distribution system operator training requirements and sanitary survey guidelines. There is more variability in practices when it comes to preventing contamination during main breaks and failures than with the installation of new mains. Haas et al. (1998) reported that while 90 percent of utilities surveyed said that new mains must meet water quality criteria before they are released back to service, only 29 percent said samples were required to be collected in response to a main break. One common practice is to simply flush hydrants on the water mains in the affected area until the water runs clear. Because water main repairs are of varying complexity and occur under a variety of environmental conditions, and due to their unplanned nature may require quick response and return to service, the application of the same level of specifications used for new water mains may not be feasible. The chemical and microbial contamination of distribution system materials and drinking water during mains breaks and during the installation, rehabilitation, and repair of water mains and appurtenances is a high priority issue. As discussed above, there have been many documented instances of significant health impacts from drinking water contamination associated with pipe failures and maintenance activities. The improved application of best practices, and operator training and certification, can reduce this risk. FINISHED WATER STORAGE Treated water storage facilities, of which there are 154,000 in the United States (AWWA, 2003), are of vital importance for drinking water distribution systems. Storage facilities are traditionally designed and operated to secure system hydraulic integrity and reliability, to provide reserve capacity for fire fighting and other emergencies, to equalize system pressure, and to balance water use throughout the day. To meet these goals, large volumes of reserve storage are usually incorporated into system operation and design, resulting in long detention times. Long detention times and improper mixing within such facilities provide an opportunity for both chemical and microbial contamination of the water. One of the most important manifestations of water quality degradation during water storage is a loss of disinfectant residual, which can be further compromised by temperature increases in water storage facilities under warm weather conditions. Internal chemical contamination can also occur due to leaching from coatings used in the storage facility, or solvents, adhesives, and other chemicals used to fabricate or repair floating covers. Until recently, water quality issues associated with such facilities have usually been considered as only secondary maintenance items such as cleaning and coating. In addition to the internal degradation of water quality that occurs over time in water storage facilities, they are also susceptible to external contamination from birds, animals, wind, rain, and algae. This is most true for uncovered storage facilities, although storage facilities with floating covers are also susceptible to bacterial contamination due to rips in the cover from ice, vandalism, or normal operation. Even with covered storage facilities, contaminants can gain access through improperly sealed access

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report openings and hatches or faulty screening of vents and overflows. The white paper, Finished Water Storage Facilities (AWWA and EES, Inc., 2002c), identified four waterborne disease outbreaks associated with covered storage tanks. In particular, in Gideon, Missouri, a Salmonella typhimurium outbreak occurred due to a bird contamination of a covered municipal water storage tank (Clark et al., 1996). Water quantity and quality requirements in distribution storage management decisions are frequently in conflict. While water quantity objectives promote excessive storage, water quality objectives are geared toward minimizing residence times and frequent exercising of treated water facilities to maximize the stored water disinfectant residual. Appropriate balancing is therefore required to ensure disinfection effectiveness and sufficient level of service (Boulos et al., 1996; Hannoun and Boulos, 1997). Numerous standards prepared by ANSI/AWWA, Ten States Standards, and the National Sanitation Foundation (NSF) are available for the design, construction, and maintenance of water storage facilities. However, if retention times are long, disinfectant residual can drop, via reaction with oxidizable material in the water, to a level that is non-protective of microbial contamination. To minimize this potential problem, adequate turnover of the water in the facility is an essential operational parameter. It is also desirable to adequately mix (to eliminate dead zones) or prevent the short circuiting of the water entering and leaving the facility to shorten the water age in the facility. The documented cases of waterborne disease outbreaks and the potential for contamination due to the large number of these facilities make this a high priority distribution system water quality maintenance and protection issue. ADDITIONAL ISSUES OF CONCERN Two distribution system issues not mentioned in the nine white papers that the committee believes are of significance to public health protection include the management of premise plumbing and the training of distribution system operators. Premise Plumbing Premise plumbing is that portion of the water distribution system from the main ferrule or water meter to the consumer’s tap in homes, schools, hospitals, and other buildings. Virtually every problem identified in potable water transmission systems can also occur in premise plumbing. However, due to premise plumbing’s higher surface area to volume ratio, longer stagnation times, and warmer temperatures (especially in the hot water system), the potential health threat can be magnified (Edwards et al., 2003). This is an important problem because it requires that individual homeowners be responsible for making decisions that will affect the safety of their drinking water. Premise plumbing is also a valuable asset, with more than 5.3 million miles of copper tube installed in buildings since 1963 (CDA, 2004). The estimated replacement value of premise plumbing in buildings is over 1 trillion dollars (Parsons et al., 2004) and the cost of a plumbing failure

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report to an individual homeowner can exceeded $25,000. The problems of greatest concern within premise plumbing include microbial regrowth, leaching, permeation, infiltration, cross connections, leaks and the resulting indoor mold growth, scaling, and the high costs of failure. Regrowth problems are exacerbated in premise plumbing due to very long stagnation times resulting in a loss of chlorine residual, to the presence of numerous microclimates, and to nutrient release from some pipes. Some clear links have been established between regrowth of opportunistic pathogens such as Legionella and Mycobacterium and waterborne disease amongst immunocompromised patients in hospitals (EPA, 2002b). A special concern is regrowth of pathogens within water heaters and showers, which may be exacerbated by recent efforts to reduce temperatures to prevent scalding and save energy (Spinks et al., 2003). The impact of low-flow shower fixtures on consumer exposure to airborne aerosols (a potential route for Legionella exposure—Blackburn et al., 2004) and endotoxins is unclear and in need of examination (see Rose et al., 1998, and Anderson et al., 2002). A subset of the regrowth issue in homes deals with the presence of granular activated carbon in point-of-use treatment devices that can accumulate bacterial nutrients and neutralize disinfectant residuals, thus providing an ideal environment for microbial growth (Tobin et al., 1981; Geldreich et al., 1985; Reasoner et al., 1987; LeChevallier and McFeters, 1988). Several coliform bacteria (Klebsiella, Enterobacter, and Citrobacter) have been found to colonize granular activated carbon filters, regrow during warm-water periods, and discharge into the process effluent (Camper et al., 1986). The presence of a silver bacteriostatic agent did not prevent the colonization and growth of HPC bacteria in granular activated carbon filters (Tobin et al., 1981; Reasoner et al., 1987). Rogers et al. (1999) reported the growth of Mycobacterium avium in point-of-use filters in the presence of 1,000 μg/mL silver. While general microbial parameters such as HPC are also higher after point-of-use devices, there is currently no evidence that these microbes cause significant human health problems (WQA, 2003). Leaching and permeation mechanisms within premise plumbing are the same as for public water supply transmission lines. However, the wide variety of materials used in building plumbing and associated treatment devices, the higher surface area to volume ratio, very long stagnation times, and lessened dilution increase the potential severity of the problem in premise plumbing. If permeation were to occur through the consumer’s service line it would rarely be detected by routine monitoring of the distribution system. For new materials, levels of allowable contaminant leaching have been established through health based standards in ANSI/NSF Standard 61. However, ANSI/NSF Standard 61 is a voluntary test for premise plumbing, ANSI/NSF certification may not be required in all states for materials installed in buildings, and it is not clear whether states are applying materials tested under Standard 61 to premise plumbing. Indeed, there is reason to believe that certain existing NSF standards may not be sufficiently protective of public health in the context of lead leaching from in-line brass devices (Abhijeet, 2004). Problems with infiltration and cross connections are also greater in premise plumbing than in the main distribution system. Premise plumbing is routinely subject to pressure and flow transients and is the site of minimum pressure in the distribution sys-

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report tem. Moreover, the pressures measured in distribution systems during high flow events are an upper bound for pressures that occur in premise plumbing. Considering that direct or indirect cross connections are likely to be found in a majority of household plumbing systems (see previous discussion of backflow events and USC, 2002), and the known occurrence of leaks in premise service lines, there is significant potential for backflow and intrusion. Previous EPA white papers on intrusion and cross connections (LeChevallier et al., 2002; EPA, 2002b) do not explicitly include risks in premise plumbing. Thus, additional research is needed to determine the potential impacts of building hydraulics on intrusion and contamination from cross connections. Other problems beyond the scope of the current effort, but which are nonetheless important, include reduced flow and high energy costs associated with scaling in pipes and water heaters, leak-induced mold growth in buildings, and the high cost of water damages and re-plumbing due to material failure. The premise plumbing issue poses unique challenges because there is no obvious single party who could assume responsibility for the problem, which might be best addressed through changes in and enforcement of plumbing codes, third party standards, and public education. Utility involvement in overseeing solutions may be appropriate where distribution system water quality directly contributes to the problem, as is currently the case with the Lead and Copper Rule. Distribution System Operator Training Traditionally, training of drinking water distribution system operators has focused primarily on issues related to the mechanical aspects of water delivery (pumps and valves) and safety. However, system operators also are responsible for ensuring that the operation of the system from a quantity perspective does not cause degradation of water quality (EPA, 1999), and it is important that they receive adequate training to meet this need. The training should include an understanding of constituents that affect public health, such as disinfectants, disinfection by-products (DBPs), and metals, and how distribution system operations affect their concentrations. It should also include guidance on meeting water quality monitoring and reporting requirements, on how to interpret monitoring results, and on actions that should be taken when “positive” hits are detected (such as increased levels of coliforms or turbidity and decreased or depleted chlorine residuals). Most importantly, the distribution operator must be trained to make decisions regarding the proper balance of quality and quantity issues, such as in proper operation of distribution system storage facilities (Smith and Burlingame, 1994; Kirmeyer et al., 1999). The need to train operators is more pronounced in small systems where there are fewer staff members to aid operators in day-to-day decisions. The need for the continuing and intensive training of operators of distribution systems has increased recently for three reasons. First, recent federal and state regulations (EPA, 1990) are more sophisticated and require enhanced skills for proper sample collection and preservation, as well as better understanding of aquatic chemistry and biology. Second, in many systems the new regulations (EPA, 1998) created a shift in the use of

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Public Water Supply Distribution Systems: Assessing and Reducing Risks - First Report disinfectants in the distribution systems from a relatively simple application of chlorine to rather complicated application and maintenance of chloramines. Finally, with an increase in the importance of security of drinking water pipes, pumps, reservoirs, and hydrants, there is a corresponding increase in the responsibility of operators to make decisions during perceived security events.