Category Archives: Regulations

Prioritizing unregulated disinfection byproducts for risk mitigation, Canadian Perspective

Mian HR, Hu G, Hewage K, Rodriguez MJ, Sadiq R. Prioritization of unregulated disinfection by-products in drinking water distribution systems for human health risk mitigation: A critical review. Water Res. 2018 Sep 29;147:112-131. doi: 10.1016/j.watres.2018.09.054

Water disinfection involves the use of different types of disinfectants, which are oxidizing agents that react with natural organic matter (NOM) to form disinfection by-products (DBPs). The United States Environmental Protection Agency (USEPA) has established threshold limits on some DBPs, which are known as regulated DBPs (R-DBPs). The human health risks associated with R-DBPs in drinking water distribution systems (DWDSs) and application of stricter regulations have led water utilities to switch from conventional disinfectant (i.e., chlorination) to alternative disinfectants. However, the use of alternative disinfectants causes formation of a new suit of DBPs known as unregulated DBPs (UR-DBPs), which in many cases can be more toxic. There is a growing concern of UR-DBPs formation in drinking water. This review prioritizes some commonly occurring UR-DBP groups and species in DWDSs based on their concentration level, reported frequency, and toxicity using an indexing method. There are nine UR-DBPs group and 36 species that have been identified based on recent published peer-reviewed articles. Haloacetonitriles (HANs) and haloacetaldehydes (HALs) are identified as important UR-DBP groups. Dichloroacetonitrile (DCAN) and trichloroacetaldehye (TCAL) are identified as critical UR-DBPs species. The outcomes of this review can help water regulators to identify the most critical UR-DBPs species in the context of drinking water safety and provide them with useful information to develop guidelines or threshold limits for UR-DBPs. The outcomes can also help water utilities in selecting water treatment processes for the mitigation of human health risk posed by UR-DBPs through drinking water.

California Drowning in the Swamp of SB 32 Emission Goals

“The emissions reduction leadership role for California championed by the L A Times is touted despite the fact that our state doesn’t have the foggiest idea of how it can achieve its SB 32 emissions goals nor does it have any idea of how many tens of billions it will cost nor care at all about how the state will end up dictating how all Californians must live their lives.” click here

USEPA Seeking Input on Regulations that may be Appropriate for Repeal – Submit on or Before May 15, 2017

In accordance with Executive Order 13777, “Enforcing the Regulatory Reform Agenda,” EPA is seeking input on regulations that may be appropriate for repeal, replacement, or modification. Click here to submit.

The USEPA GHG Endangerment Finding is Flawed

Regardless of whether you are for or against attempting to control long-term weather patterns (by the way, that’s what climate is) by regulating CO2 (a futile quest) the EPA endangerment finding is both technically and legally flawed. Even a simple analysis such as mine (e.g. here) came to that conclusion in June 2013. But more knowledgeable people than I (e.g. here) have submitted comments ignored by USEPA revealing the inadequacy of USEPA’s GHG endangerment finding. In her 2012 appeals court opinion Justice Janice Rodgers Brown explained the situation well (here) .

USEPA Clean Power Plan Claim is Simply False

The USEPA Clean Power Plan (here) issued August 3 makes the following claim in the very first paragraph:

“These final emission guidelines…will lead to significant carbon dioxide (CO2) emission reductions from the utility power sector that will help protect human health and the environment from the impacts of climate change.”

This is simply untrue (aka false).



Implementing Drinking Water Ordinance Amendments; Frankfurt

Westphal T, Voigt K, Heudorf U. [Amendments to the Drinking Water Ordinance: Legionellae in Hot Water Systems – Data from the Public Health Authority Frankfurt am Main, Germany]. Gesundheitswesen. 2015 Jul 8. [Article in German]

Background: The first and second amendment to the Drinking Water Ordinance came in to force in the years 2011 and 2012 causing additional tasks and responsibilities for operators of commercial large-scale systems, usually hot water systems in large residential buildings, and for the local health authorities. This article describes the experiences of the health authority in Frankfurt/Main with these new regulations. Some of the revisions in the first amendment of the ordinance (TrinkwV 2001 (2011)) were omitted in the second revision (TrinkwV 2001 (2012)) such as the obligation to notify for large-scale systems. Furthermore, the intervals between the obligatory inspections were extended from 1 to 3 years and merely exceedances of the legal limits were to be notified in contrast to the previous obligation to notify all values.

Results: On the basis of the TrinkwV 2001 (2011) a large additional staff requirement had been estimated (13/21 positions). After the TrinkwV 2001 (2012) the tasks can be accomplished by less than 2 employees. While the notification obligation was still in force, the health authority received 4 461 notifications of large-scale systems, since then a further 477 have been notified. Of a total of 1 335 initial analyses, 794 (60%) exceeded the technical action value and in 113 properties with values exceeding 10 000/100 ml a usage restriction was necessary. Conclusions: Due to the suspension of the notification obligation to report any result of the analyses performed the assessment of the reports on large-scale systems has become difficult. An appropriate assessment of the implementation of the regulation is not possible, since the total number of large-scale systems is not known and a failure to report may result from a measured value below the technical action value as well as from a not inspected system. The large number of usage restrictions is an indication for the necessity to inspect and if required to treat and restore the system.

Obama Administration Climate Regulations Do Not Meet “Best Available Science” Threshold

New EPA regulations intended to address “global warming” will have no measurable impact. This has been known for several years, and now the EPA Administrator in effect admits it. All cost, and no benefit, simply so the rich can get richer while the poor suffer.

Every water and wastewater system in the US will be adversely affected by EPA climate-related rules because of higher energy costs, which in turn must be passed on to customers.  The Safe Drinking Water Act requires best available science when setting drinking water regulations. Further, the benefits must justify the costs. (In this case, there apparently are little or no quantifiable benefits for regular Americans who will have to pay a high cost so others can get richer.)

The Clean Air Act has no direct requirement for regulations to be based on best available science but it should. The practical result is that EPA can (and has) issued a scientific “snow job” on its new climate rules. Apparently, the Agency feels no obligation whatsoever to address the real science. It is long over due for EPA to be held to a higher science standard.

h/t: Climate Depot