Micro Pollutants from Septic Systems

Traces of pharmaceuticals, hormones and personal care products associated with everyday life in the United States are finding their way into groundwater through septic systems and these micro pollutants can find their way into drinking water supplies. This is exactly what is happening in New York and New England, according a recently published study by the U.S. Geological Survey (USGS). The paper, “Concentrations of hormones, pharmaceuticals and other micropollutants in groundwater affected by septic systems in New England and New York” by Patrick J. Phillips, Irene J. Fisher, et. al. details the findings at two different locations that were studied, one in New England and the other on Fire Island in New York.

This study was the first to be published that used a new highly sensitive analytical method developed by the USGS National Water Quality Laboratory that identifies more than 100 pharmaceuticals, pharmaceutical degradates and related contaminants in trace concentrations. This method has detection limits for many compounds in the low nanogram/liter (that is about one thousandth of a part per billion) range, and significantly advances the abilities of the USGS to assess the presence and concentrations of pharmaceuticals in the environment.

The two sites were chosen because high nitrate concentrations in groundwater samples down gradient of these septic systems begged the question of what other chemicals might also be present. Though nitrate can contaminate groundwater from fertilizer use; leaking from septic tanks, sewage and erosion of natural deposits, increased nitrate concentration is usually a sign of improperly operated or failing septic systems and is an indication that septic system waste is contaminating groundwater. The MCL for nitrate is 10 mg/L and easily tested for. The NO3 dissolves and moves easily through soil. Due to plant uptake, there is a seasonal variation, and testing in the spring will usually produce the highest levels of nitrate. Elevated nitrate usually indicates contamination from septic tanks as it did here. What is important about this study is that the USGS scientists also found traces of other chemicals in the groundwater and demonstrated that these pharmaceuticals and related contaminants do not just disappear, but are spreading through groundwater into the environment.

The USGS scientists looking for micropollutants in groundwater collected samples down gradient of septic systems. The scientists tested for items such as pharmaceuticals, personal care products, and plasticizer compounds used in plastics. In New England a series of existing down gradient groundwater wells and wells installed to monitor the leach field were used to collect samples to measure the effect of a single large septic system that serves a nursing home with 65 patient beds and staff. Samples were collected from below the septic system leach field in addition to samples from wells down gradient of the septic system. The USGS scientists found numerous prescription drugs in the groundwater samples, such as anesthetics; a muscle relaxant; an antifungal; an antiepileptic; an antibiotic; a sleep aid; and also a floor cleaner. Total concentrations for these compounds generally ranged from 1 to over 20μg/L in the groundwater samples. High tris(2-butoxyethyl phosphate) plasticizer concentrations in wells beneath and down gradient of the leach beds (>20μg/L) were thought to reflect the presence of this compound in cleaning agents used at the nursing home.

On Fire Island in New York, groundwater samples were collected from an area of dense summer populations (5 dwellings/acre). The Fire Island septic systems have minimal treatment of wastewater (they are essentially tank only systems) before mixing with shallow groundwater that moves towards a large, estuary where a decline in fisheries and shellfish along with a higher ratio of female-to-male fish had been reported.

Shallow groundwater samples collected along the beach of this estuary down gradient of the septic systems were found to have hormones; detergent degradation products; galaxolide, a fragrance found in various products; insect repellent; sunscreen additives; floor cleaner; and two pharmaceuticals (lidocaine, a local anesthetic; and carbamazepine, an anti-convulsant and mood stabilizing drug). The highest micropollutant concentrations for the Fire Island study found in one of the shoreline wells that had personal care/domestic use, pharmaceutical, and plasticizer concentrations ranging from 0.4 to 5.7μg/L.

Most micropollutant concentrations increased with increasing total nitrogen concentrations for the shoreline well samples. The USGS scientists draw narrow conclusions stating that “these findings suggest that septic systems serving institutional settings and densely populated areas in coastal settings may be locally important sources of micropollutants to adjacent aquifer and marine systems.” The potential for measurable groundwater contamination and environmental impact from septic systems clearly places these systems within the expanded EPA definition of “navigable waters of the United States” and makes regulatory action possible if not likely.

Septic systems are common in rural areas and those lacking connection to larger scale sewage treatment plants. Septic systems consist of holding tank where raw sewage collects and separates into a sludge (solid) and liquid effluent. The liquid effluent either leaches directly into the surrounding soil or goes into a leach field for final treatment by the soil. The liquid effluent from septic systems ultimately moves into the groundwater. There are also alternative septic systems that have a secondary treatment system (be it a secondary aerobic tank or other treatment media) to remove pollutants. Though more than 30% of households are served by onsite septic systems, a significant numbers are quite old and many are not properly operated or maintained. Proper maintenance of septic systems (both traditional and alternative) is essential for protection of public health and local water resources. With new more sensitive testing methods it is possible to measure the impact of these systems on groundwater supplies and the environment. However, a simple annual nitrate measurement would indicate a problem and can be used as a proxy for the more expensive tests.

The article discussed:

Concentrations of hormones, pharmaceuticals and other micropollutants in groundwater affected by septic systems in New England and New York, Science of The Total Environment, Volume 512-513, Issue null, Pages 43-54,P.J. Phillips, C. Schubert, D. Argue, I. Fisher, E.T. Furlong, W. Foreman, J. Gray, A. Chalmers.

Toxic Chemicals in Chesapeake Bay -Expanding the Pollution Diet

from EPA report

The U.S. Environmental Protection Agency’s Chesapeake Bay Program just released a report that outlines the extent and severity of toxic contamination in the Chesapeake Bay and the Watershed. This report by Scott Phillips (USGS) and Greg Allen (EPA) is based on a review and compiling of water-quality reports from the various Chesapeake Bay watershed states (Delaware, Maryland, New York, Pennsylvania, Virginia, West Virginia) and Washington, D.C., and scientific work performed by the U.S. Geological Survey and U.S. Fish and Wildlife Service who have been doing extensive studies on contaminants in surface and groundwater and also the cause of observed impact on fish, plants and wildlife.  The authors of the EPA  report focused on summarizing studies conducted after 2000 with an emphasis on the 2010 water-quality assessment reports from the states to define the extent and severity of occurrence of: polychlorinated biphenyls (PCBs); dioxins and furans; polycyclic aromatic hydrocarbons (PAHs); petroleum hydrocarbons; pesticides; pharmaceuticals; household and personal care products; polybrominated diphenyl ethers (PBDEs); biogenic hormones; and heavy metals in the Chesapeake Bay watershed and ultimately in the source drinking water for millions of people.

This report was issued under the “Strategy for Protecting and Restoring the Chesapeake Bay Watershed” released in May 2010 and is first in a series of actions to control pollution, restore habitat and wildlife, conserve land, and increase public awareness and accountability in the Chesapeake Bay Watershed. The federal ‘Strategy” for the Chesapeake Bay region of the 64,000-square-mile watershed includes using federal regulations to restore clean water, implement new conservation practices on four-million acres of farms, conserve an additional two-million acres of undeveloped land, and restore the habitat for key species such as oysters, black ducks, and brook trout. Under the “Strategy” the states will be held accountable to achieve specific milestones every two years to ensure measurable progress.

While there is overlap between the so called “settlement agreement” and “Strategy,” they are not the same. The settlement agreement resolved the lawsuit brought by former Maryland State Senator Bernard Fowler, the Chesapeake Bay Foundation, Maryland and Virginia watermen’s associations, and others filed against the EPA in January 2009 alleging the Agency failed to fulfill its duties under the Clean Water Act (CWA) and the Chesapeake 2000 Agreement. EPA settled the lawsuit with the “settlement agreement,” which required EPA to:  “Establish and implement a Chesapeake Bay total maximum daily load, TMDL, for nutrients and sediments.”  The TMDL required the creation of watershed implementation plans (WIPs) approved by EPA under threat of  “back step measures” by all of the Chesapeake Bay watershed states and the District of Columbia to ensure they achieve the nutrient and sediment allocations under the TMDL.

The TMDL addresses only pollution from excess nitrogen, phosphorus and sediment. The TMDL does not address toxic, carcinogenic or endocrine disruptors that may be present in the watershed. The excess nitrogen, phosphorus and sediment in the Chesapeake Bay cause algae blooms that consume oxygen and create “dead zones” where fish and shellfish cannot survive, block sunlight that is needed for underwater Bay grasses, and smother aquatic life on the bottom. The result is fish kills and murky water that threaten the aquatic industry and recreational use of the bay. 

The TMDL sets a total Chesapeake Bay watershed limit for the six states and Washington DC of 185.9 million pounds of nitrogen, 12.5 million pounds of phosphorus and 6.45 billion pounds of sediment per year which is a 25% reduction in nitrogen, 24% reduction in phosphorus and 20 %t reduction in sediment from the current levels. The pollution limits are then partitioned to the various states, DC and river basins based on the Chesapeake Bay modeling tools and monitoring data. The estimated cost of implementing the WIPs in Virginia and Maryland were $13.6-$15.7 billion and $14.8 billion respectively. Now EPA is preparing to address the toxic pollutants.

This new report addresses toxic pollutants in the watershed and is the first step in a new round of regulations and requirements for the Chesapeake Bay watershed states and Washington DC. In the Chesapeake Bay watershed, both largemouth and smallmouth bass show signs of feminization (testicular oocytes and vitellogenin in males), skin lesions and impaired immune systems. The scientists of the USGS and Fish and Wildlife discovered that the smallmouth bass have the most impacted with a higher incidence of intersex (male fish with eggs)occurrence and a high incidence of skin lesions and large fish kills in the Potomac and James Rivers. Smallmouth bass may be the most sensitive indicator of environmental health in the Chesapeake Bay watershed. The smallmouth bass have been a warning, but the pollution problems they represent remain beyond our understanding at this time. The USGS and Fish and Wildlife have not succeeded in identifying the cause or causes of the feminization, skin lesions and impaired immune systems.

from EPA report

The EPA report found that PCBs, PAHs, herbicides (primarily atrazine, simazine, metolachlor, and their degradation products), and mercury were widespread throughout the Chesapeake Bay watershed. Other contaminants like dioxins/furans, petroleum, hydrocarbons, some chlorinated insecticides (aldrin, chlordane, dieldrin, DDT/DDE, heptachlor epoxide, mirex), and some metals (aluminum, chromium, iron, lead, manganese, zinc) were known in localized occurrences. Finally, for atrazine, some pharmaceuticals, some household and personal-care products, some PBDEs, and biogenic hormones, the extent and amount of contamination could not be assessed based on the information available.

The Chesapeake Bay Program intends to develop toxic contaminant reduction strategies to be added to the Chesapeake Bay TMDL by 2015, but first more data needs to be gathered to identify the extent of contamination for many of the chemicals. The impact on human life and the ecosystem of these and other emerging contaminants is not understood. As the EPA report and previous work done by the USGS point out we need to determine the impact and fate of these micro pollutants before we implement the watershed cleanup plans to make sure we are implementing the right strategies for the health of the entire ecosystem which may include eliminating the use of certain chemicals, upgrading waste water treatment systems and other actions. 

Update on Endocrine Disruption in Water Supplies

From USGS paper cited below

Earlier this month Vicki Blazer of the U.S. Geological Survey published a new paper, “Indicators of Reproductive Edocrine Distruption in Fish in the Chesapeake Bay Watershed.” Dr. Vicki Blazer is a mairine biologist and researcher at the U.S. Geological Survey, USGS. Dr. Blazer received the American Fisheries Society 2010 Publications Award for her article investigating the mortality of fish in the Potomac River basin and is a fish biologist at the West Virginia Science Center studying the impact of contaminants of emerging concern in rivers and streams of the lifecycle and health of fish on the Chesapeake Bay and its tributaries. This paper is a summary of the most recent research (previously published) by the USGS and others on endocrine disruption in fish in the Chesapeake Bay watershed and the implications to our lives.

The Chesapeake Bay watershed feed the Chesapeake Bay, the largest and most productive estuary in the United States. It serves as a nursery ground for the fish and shellfish industry and protects the coast from storm surges and filters pollution. The estuary filters water that is carrying nutrients and contaminants from the surrounding watershed. The nutrients in proper balance bring fertility, but excess nutrient contamination to the Chesapeake Bay has caused degradation in the habitat and impact to fish and other animals. As a result, US EPA has taken control of the situation and has developed a new federally mandated TMDL (total maximum daily load) to try to restore the natural balance in the estuary by controlling nutrients in the local waters. The TMDL addresses pollution from phosphorus, nitrogen and sediment and allocates a pollution budget among the states which will decrease over time. However, according to Dr. Blazer, the fish (and other aquatic organisms) in the Chesapeake Bay watershed are being exposed to a complex mixture of chemicals that may have additive, synergistic or antagonistic effects.

In the Potomac River watershed, largemouth bass show signs of feminization (testicular oocytes and vitellogenin in males) but appear to be less sensitive than smallmouth bass to the effects of estrogenic compounds. The scientists discovered that the smallmouth bass have both a higher incidence of intersex (male fish with eggs) occurrence and a high incidence of skin lesions and large fish kills in the Potomac and James Rivers. Smallmouth bass may be the most sensitive indicator of environmental health in the Chesapeake Bay watershed. The smallmouth bass is a warning that should not be ignored, but the pollution problem they represent are beyond our understanding at this time. More work needs to be done.

Although feminization of male fish has most commonly been associated with exposure to human wastewater-treatment-plant effluent, the prevalence of male smallmouth bass with intersex characteristics is not consistently higher downstream from these point sources than upstream in the areas of the Potomac River watershed that were studied. It is not simply the residue of birth control pills in human waste. However, some additional biomarkers, such as the ratio of gonad weight to body weight and plasma vitellogenin concentrations in female bass, do appear to be adversely affected by the presence of wastewater-treatment plants upstream from the study site, but more is going on.

The sources of the endocrine-disrupting chemicals associated with intersex smallmouth bass appears to be BOTH effluent from wastewater-treatment plants and runoff from agricultural land, animal feeding operations, and urban/suburban land. All impacts of mankind. Other factors, including wastewater-treatment-plant effluent flow, number of animal feeding operations, and number of poultry houses were also associated with an increased intersex severity. Within the Potomac River basin the data showed that the higher the human population density the higher the incidence of intersex in the smallmouth bass. Also, the higher the percentage of agricultural land use density the higher incidence of intersex in smallmouth bass. The data appears to suggest beyond a certain density of agricultural land and/ or human population, the smallmouth bass population is impacted.

The USGS plans to work with the Chesapeake Bay Program to identify the chemicals that are causing the intersex, skin lesions and fish kills. The Chesapeake Bay Program intends to develop toxic contaminant reduction strategies to be added to the Chesapeake Bay TMDL by 2015. The impact on human life and the ecosystem of these and other emerging contaminants is not known, but now is the time to find out the impact from the substance we’ve been allowing to enter the waters of the earth. We need to determine the impact and fate of these micro pollutants before we implement the watershed cleanup plans to make sure we are implementing the right strategies for the health of the entire ecosystem which may include eliminating the use of certain chemicals and other actions.

Endocrine Disruption and What’s in the Potomac River Watershed

Recently in the Susquehanna River in Pennsylvania, smallmouth bass have been found with benign skin tumors. Two skin samples of lesions from fish removed from the river were sent to Dr. Vicki Blazer a mairine biologistand researcher at the U.S. Geological Survey, USGS. Dr. Blazer who received the American Fisheries Society 2010 Publications Award for her article investigating the mortality of fish in the Potomac River basin and is a fish biologist at the West Virginia Science Center studying the impact of contaminants of emerging concern in rivers and streams of the lifecycle and health of fish,  found that one of the samples  tested positive for a type of benign skin tumor. These samples were sent to the USGS because an ongoing collaborative effort between the USGS, the U.S. Fish and Wildlife Service, state agencies in West Virginia, Maryland, and Virginia, and the Potomac Riverkeeper has been studying the impacts of trace contaminants on fish health. Areas of study have been endocrine disruption, immune system impact, cancer/neoplasia promotion, secondary sex characteristics, oxidative damage and behavior. I follow Dr. Blazer’s talks at conferences.

Endocrine disruptors are chemicals that may interfere with the body’s endocrine system and produce adverse developmental, reproductive, neurological, and immune effects in both humans and wildlife. Research evidence suggests that these chemicals, can mimic hormones or interfere with the function of the body’s own hormones. Endocrine disruptors are found in many of the everyday products we use, including some plastic bottles and containers, food can liners, detergents, flame retardants, toys, cosmetics, and pesticides. These hormones and hormone like substances are typically highly soluble in water and are easily transported in the blood. These compounds are of particular concern because they can alter the critical hormonal balances required for proper health and development. The glands that make up the endocrine system are: pituitary gland, thyroid glands, adrenal glands pancreas, ovaries, testies, pineal gland and the thymus.

The marine life work in this area began with the studies of fish kills more than 15 years ago. Preliminary analysis at that time did not find any chemicals or pesticides in concentrations that were sufficient to stress fish and be a cause of the fish kills. Yet there were fish kills. As Dr.Blazer pointed out in a recent conference almost all of our knowledge about concentrations likely to cause a health impact are based on acute toxicity or gross impact such as size. In most cases there are no criteria for sub-lethal effects such as immune modulation or endocrine disruption. Dr. Blazer and others believe that methodology used to detect these chemicals in recent studies may not have been sensitive enough, and may indeed be above the concentration thought to impact these fish. Two examples given by Dr. Blazer at a recent conference were that based on research studies in more than 25 fish species, scientists have suggested that 1 ng/L (parts per trillion) may be the “no effects level” for natural estrogen concentrations on fish. Unfortunately, all the river studies performed in the Potomac River and Shenandoah River passive sampler studies use 1.3 ng/L as the lower detection limit. The detection limit for Potomac and Shenandoah Rivers studies for ethynylesradiol is almost twice the level recently set as the aquatic “no effects” level. Studies along the Potomac and Shenandoah Rivers have only studied smallmouth bass that were found to be intersexed and have measurable amounts of vitellogenin (a protein that is a precursor to egg yoke) in their blood. Vitellogenin is normally only found in the blood of sexually matures egg-laying females, though males typically carry an inactive gene that is “turned on” by the presence of estrogen. Further research is necessary to not only determine if the problem is more widespread geographically and among species, but to identify the mode and mechanism of impact.

Fish health turns out to be a way to track ecosystem health. The smallmouth bass population has been presenting a variety of skin lesions, bacterial, viral and fungil infections, high parasite loads and intersex in normally gonochorist fish ( where embryonic gonad subsequently divides into ovaries or testes). The findings are not at all consistent, but show wide spread biological impact. Scientists like Dr. Blazer are looking to determine if these impacts to fish are being caused by something being put in or released from wastewater treatment plants, farms, or storm water runoff. Until the cause is identified, nothing can be done to stop them and prevent impact to animal and human populations.

Slide taken from Dr. Viki Blazer of USGS presentation

The Potomac fish kills studied by Dr. Blazer and others suggest that there are stressed populations of fish that at some point are overwhelmed by environmental stressors such as increased water temperatures, low dissolved oxygen, excess nutrients, high pH, or chemicals that cause immuno-supression leading to a wide variety of opportunistic infections and the large fish kills. There is increasing evidence that estrogenic chemicals and other endocrine disrupting substance modulate the immune response and disease resistance. In a study of female bass from the Shenandoah River south fork scientists found the BDE (a flame retardant), triclosan (an antibacterial and antifungal agent used in a wide variety of consumer products including toothpaste, mouthwash, deodorant and cleaning supplies) and pesticides had accumulated selectively within the endocrine system with lower concentrations in the brain, skin, kidneys. In talking about the bass, it is reported by Marcia Moore of the Daily Item that Dr. Blazer said, “The good news, for people anyway, is the muscle has the lowest concentration,” indicating that the fish could be eaten. “It’s not such good news for the fish because we’re finding it in the brain, ovaries, kidneys and skin.” The location of the increased concentrations seen in Dr. Blazer’s slide and potential sources of contaminants raises questions about potential human exposure.  

All water on earth is part of the hydraulic cycle and is reused over the course of time. These traces of chemicals have managed to slip through the earth’s natural filtration and some of them through treatment systems to be released into rivers and consumed by humans. Finished and source water (as well as food and beverages) have been found to have low levels of these emerging chemicals, but whether this low level of exposure is bio-accumulating in humans and can cause any health or developments effects is yet unknown. Endocrine disruptors can sometimes affect reproduction, development, and behavior, certainly these impacts on fish is being studied. These potentially endocrine disrupting chemicals come from a variety of sources and have diverse molecular structures. If these chemicals are introduced into water systems from human waste and food, then it is possible that human tissues might also contain detectable levels of contaminants. We might be experiencing subtle population impacts from chemical exposure during fetal and newborn development. Potential human effects from chemical contaminants in tissues of the endocrine system are cancer (particularly breast cancer and testicular cancer), infertility, disorders of sex development, asthma and other immune related syndromes, autism, ADHD, learning and behavioral disorders, diabetes, thyroid disorders, and testicular dysgenesis syndrome (poor semen quality, testis cancer, undescended testis and hypospadias).

The endocrine system of fish bears some similarity to the human endocrine system, but we do not live our lives in the waters of the Potomac. Two million people rely on the Washington Aqueduct for their drinking water and millions of people in other parts of the country drink source water with similar observed occurrences of endocrine disruption. The impact on human life and the ecosystem of these emerging contaminants is not known, but now is the time to find out the impact from the substance we’ve been allowing to enter the waters of the earth. We need to determine the impact and fate of these micro pollutants before we implement the watershed cleanup plans to make sure we are implementing the right strategies for the health of the entire ecosystem which may include eliminating the use of certain chemicals.  

Emerging Contaminants in Your Drinking Water

Chemicals are everywhere, they exist in pharmaceuticals, household products, personal care products, plastics, pesticides, industrial chemicals, human and animal waste; they are in short, all around us. These chemicals include organics, inorganic, polymers, complex reaction products, and biological materials. The technology used for chemical analysis has advanced to the point that it is possible to detect and quantify nearly any compound known to human kind down to less than a nanogram per liter or parts per trillion (1/1,000,000,000,000). This enhanced analytical ability has allowed scientists to discover that trace levels of pharmaceuticals, potential endocrine disrupting compounds (EDC) and other emerging contaminants exist in much of our surface water and is appearing in some groundwater and persists in the water through conventional and some advanced treatments to also appear in our finished drinking water. The list above have all been found by testing performed by Fairfax Water.

All water on earth is part of the hydraulic cycle and is reused over the course of time. These traces of chemicals have managed to slip through the earth’s natural filtration and some of them through treatment systems to be identified in finished drinking water at extremely low levels. Finished and source water (as well as food and beverages) have been found to have low levels of these emerging chemicals, but whether this low level of exposure can cause any health effects or developments effects is unknown. Some of the emerging chemicals are or maybe endocrine disruptors, a class of chemicals that can mimic, block, or otherwise alter animal hormone responses. Endocrine disruptos can sometimes affect reproduction, development, and behavior, this is actually, how some pest control treatments are designed to work. A diverse group of chemicals called endocrine disrupting chemicals (EDCs) come from a variety of sources. These chemical have diverse molecular structures. BPA is just one of these chemicals. These chemicals become of great concern when they are discovered to be potential human endocrine disruptors as DDT, dioxin, PCBs and the drug DES were found to be in the past. Traces of endocrine disrupting chemicals are seemingly found in every part of our world, including dust, soil, water, air, food, manufactured products, wildlife, and even ourselves.

 Findings in the Fourth National Report on Human Exposure to Environmental Chemicals by the Center for Disease Control (CDC) in December 2009 and updated in 2012 indicate widespread exposure to some commonly used industrial chemicals. This exposure may have existed for decades but our ability to identify parts per trillion has allowed us to become aware of the ubiquitous exposure. The CDC measured 212 chemicals in the blood and/or urine of the participants. The samples were collected from participants in CDC's National Health and Nutrition Examination Survey (NHANES), which is an ongoing survey that samples the U.S. population every two years. Each two year sample consists of about 2,400 people. What the report found was widespread exposure to some chemicals throughout the population tested. The implications of this ubiquitous exposure are unknown, but of concern. The detection of a chemical in a person’s blood or urine does not mean that it will cause health effects or disease. The guiding principal of toxicology is that there is a relationship between a toxic reaction (the response) and the amount of poison received (the dose). An important assumption in this relationship is that there is almost always a dose below which no response occurs or can be measured. So if the concentration of the contaminant was low enough there would be no toxic reaction, but that principal is being tested with endocrine disruption and advances in analysis.

The occurrence of intersex fish in the Potomac River, and in other areas of the US resulted in Congressional hearings in the fall or 2006 to inquire about the “State of the Science on EDCs in the Environment,” as well as the US EPA’s activities associated with EDCs. The hearings resulted in a White Paper; “AQUATIC LIFE CRITERIA FOR CONTAMINANTS OF EMERGING CONCERN” and validation of analytical methods. In 2009, a final list of 67 chemicals and the schedule for issuing Test Orders for Tier 1 screening was issued. EDSP Tier 1 screening requires a battery of assays tests to identify chemicals that have the potential to interact with the estrogen, androgen, or thyroid hormonal pathways. The battery consists of 11 assays that have been developed and validated by the Office of Chemical Safety Pollution and Prevention. EPA intends to evaluate the results of the Tier 1 screening assays to determine whether or not a chemical has the potential to interact with the estrogen, androgen or thyroid hormonal pathways and to assess the need for Tier 2 testing. The work proceeds slowly.

 Meanwhile, water utilities are left not knowing how to address findings of emerging contaminants in their source and finished drinking water. A study conducted by the Water Research Foundation concluded that using a combination of ozone and granular activated carbon in addition to coagulation, sedimentation, filtration and disinfection is effective in removing some of the broad categories of EDCs, personal care products and pharmaceuticals found in drinking water. The American Water Works Association Research Foundation developed an Acceptable Daily Intake level for many of the emerging contaminants that are being found in drinking water supplies. An Acceptable Daily Intake level or ADI is a measure of the amount of a specific substance in food or drinking water that can be ingested orally over a lifetime without an appreciable health risk. Unfortunately, the reference doses ADI levels were the historic levels established by the EPA based on non-endocrine toxicity and cancer risk. These screening levels were not developed to determine whether certain substances may have an effect in humans on estrogen, androgenic or thyroid-related pathways, but were developed to protect populations from acute toxicity or cancer.

 In addition to finding intersexed fish in the Potomac, researchers have found male amphibians with ovaries and female frogs with male genitalia and frogs with six legs and other mutations. The endocrine system of fish bears some similarity to the human endocrine system, but we do not live our lives in the waters of the Potomac. Two million people rely on the Washington Aqueduct for their drinking water and millions of people in other parts of the country drink source water with similar observed occurrences of endocrine disruption. The impact on human life and the ecosystem of these emerging contaminants is not known, but according to Dr. Robert Lawrence of the Johns Hopkins School of Public Health and other scientists there is the potential to for humans to develop premature breast cancer, have problems with reproduction, and develop congenital anomalies of the male genitalia. Some believe these kinds of impacts are happening at a broad and low level in society so that the occurrence is not alarming to the general public or easily noted without detailed statistics, other scientists can find no measurable risk. We can no longer live in the happy world where we believed that our water was contaminant free. In truth, we do not know these trace chemicals are hazardous and how pure water (and food) needs to be. More research is needed on these emerging contaminants. Resources are limited and we need to make wise use of our economic and natural resources that is impossible without information.

Is Our Drinking Water Safe?

The short answer is it depends on where your water comes from, and how it is treated. The drinking water supply can be broken down into three parts: the source water, the drinking water treatment system, and the distribution system which carries the treated water to homes and other buildings. The first steps towards a clean water supply and public health was to disinfect drinking water in the cities (and develop sewer systems). Treating drinking water with either Chloramine or chlorine lowered microbial densities of coliform bacteria, heterotrophic bacteria, Legionella bacteria preventing disease and death. However, these bacteria and the other substances on the primary drinking water list are not the whole story, nor are they the only substances in our water today. Our modern world is filled with chemicals, they exist in pharmaceuticals, household products, personal care products, plastics, pesticides, industrial chemicals, human and animal waste; they are in short, all around us. According to the Toxic Substances Control Act (TSCA) inventory of chemicals there are more than 84,000 chemical substances, as defined in TSCA today (or the last time they updated it). These chemicals include organics, inorganic, polymers, and UVCBs (chemical substances of Unknown or Variable composition, Complex reaction products, and Biological materials).

Public drinking water supplies are still typically treated with either Chloramine or chlorine both are disinfectants. (Disinfection by products are tested for in drinking water supplies.) Chloramine is a combination of chlorine and ammonia that is currently considered best technology for controlling the formation of certain regulated organic disinfection byproducts and has come to replace the use of chlorine in many locations. Since the revisions to the clean water act in the 1990’s chloramine has returned to common use as a distribution system disinfectant after being replaced in 1940’s with chlorine when there were ammonia shortages. Chloramine lowers microbial densities of coliform bacteria, heterotrophic bacteria, Legionella bacteria in the source water and distribution system while minimizing the formation of regulated disinfection by-products.

Under the authority of the Safe Drinking Water Act (SDWA), EPA sets standards for approximately 90 contaminants in drinking water including bacteria from human waste, industrial discharge streams (of great concern back in 1974 when the SDWA was first created) and water disinfection by-products and distribution system contaminants. For each of these contaminants, EPA sets a legal limit, called a maximum contaminant level. EPA requires that all public water supplies be tested for this list of contaminants on a regular basis (from daily, to quarterly, to every other year or longer depending on the contaminant and water system) and meet these minimum standards on average. In addition, EPA sets secondary standards for less hazardous substances based on aesthetic characteristics of taste, smell and appearance, which public water systems and states can choose to adopt or not. Though 90 contaminants is a lot, it is just a small fraction of the chemicals in large scale commercial production in the United States which EPA estimates to be over 7,000 chemicals.

Several of the substance controlled under the SDWA are natural occurring contaminants, 6 are bacteria and 8 are by-products or additives of water treatment; however, the greatest problem is pollution caused by mankind. Anthropogenic pollutants contaminate surface and groundwater as a result of manufacturing, combustion and incinerations air emissions, landfills and spills, stormwater runoff carrying agricultural and surface pollutants and waste water treatment water carrying a wide range of chemical containing substances into surface water and groundwater. The SDWA is a product of its time, in 1974 industrial waste discharge and release was far more common, and the last significant review of the SDWA was 1991. Six of the chemicals regulated under the SDWA have been banned for more than 20 years, but the US Geological Survey (USGS) found traces of at least one banned pesticide in groundwater during the recent study of the quality of the nation’s ground water supply.

The USGS ground water testing found that 10 contaminants were detected at concentrations greater than human-health recommended levels in 1% of the groundwater. Of the ten contaminants, seven were from natural sources and three were man-made. The seven contaminants from natural sources included four geological trace elements (arsenic, manganese, strontium, and boron) and three radionuclides (radon, radium, and gross alpha-particle radioactivity). The three contaminants that exceeded MCLs that were from man-made sources were nitrate (a nutrient), dieldrin (an insecticide that has been banned by the US EPA), and perchloroethene (PCE). Naturally occurring elements, radionuclides and pesticide compounds were extensively found at extremely low concentrations (about 10% of any existing health standard). Trace levels of an herbicide (atrazine or simazine) or an herbicide degradate (deethylatrazine), and the solvents perchlorethene or trichloroethene were widely found in samples from shallow unconfined aquifers without a confining geological layer, though the deeper confined groundwater aquifers remained mostly free of man-made contamination.

In their study of surface water used for drinking water supplies the USGS found a diverse group of contaminants in the source water. The concentrations were low, but the contaminants were ubiquitous. This would indicate a variety of different sources and pathways for these contaminants to reach our drinking water supplies. The concentrations were low, (about 95% of the concentrations were less than one-part per billion); nonetheless, the most commonly detected contaminants in source water were generally detected in finished water at about the same frequency and concentration. Our drinking water treatment systems do not remove these contaminants. The USGS found that as the amount of urban and agri-lands increased within the water shed, the numbers of contaminants in the rivers also increased. Rivers receiving municipal and industrial discharge, as well as discharges from other point and non-point sources from stormwater runoff are impacted by man-made organic contaminants, most of which are unregulated. Only about 40 of the 260 substances the USGS tested for are regulated the rest are unregulated.

The safety of our drinking water system is predicated on the basic assumption of toxicology that “dose makes the poison.” This relationship between exposure and risk has been challenged in the study of endocrine disruptors. Now, there is growing concern for potential endocrine disruptors at extremely low levels. Endocrine disruptors are chemicals that can mimic, block, or otherwise alter animal hormone responses, sometimes affecting their reproduction, development, and behavior, this is actually, how some pest control treatments are designed to work on bugs. A diverse group of chemicals called endocrine disrupting chemicals (EDCs) come from a variety of sources. These chemical have vastly different molecular structures, and become of great concern when they are discovered to be human endocrine disruptors.

The US Fish and Wildlife Service (USFW) and US Geological Survey (USGS) studied the relationship between waste water treatment plants, agricultural chemicals, and the immune-suppressed and inter-sexed fish in the Potomac River (and other locations). Hormones were not detected in the samples, but analysis using yeast screening assays found estrogenic endocrine-disrupting chemicals throughout the sections of the rivers tested, yet their specific source has not yet been identified. The extremely low concentrations of chemicals that was almost undetectable caused significant biological and health impacts among the fish and amphibian populations. Though they cannot identify a single chemical or group of chemicals responsible, the USFW and USGS have embarked on further study to gain greater understanding of the implications of their findings to the earth’s ecosystem.

The structural diversity of potential endocrine disruptors is enormous and it is not known which of these substances might adversely affect living things in subtle ways. Testing for new chemicals is for gross and acute impact, subtle impact is very difficult to identify. The growing class of known endocrine disrupting chemicals can disturb a staggering range of hormonal processes. Like natural hormones, some EDCs bind directly with hormone receptors. The impostors can mimic or block hormone messages with the same, weaker, or stronger responses. Others are more subtle, they interfere with hormone maintenance to prevent or enhance hormones from being made, broken apart, or carried in the bloodstream.

Recycled or reclaimed water is former wastewater (sewage) that has been treated to remove solids, bacteria and certain impurities, and then is used in irrigation, discharged to surface water that is a source of drinking water or injected into the ground to recharge groundwater aquifers. In order to make our river, lake, stream and ocean water safe for fishing and recreation, the Clean Water Act of 1972 mandated elimination of the discharge of untreated waste from municipal and industrial sources. This was the first great success of environmental regulations. Modern waste water treatment plants, usually using sand filtration and chlorination in addition to primary and secondary treatment, were required to meet certain standards. These standards were never designed to render the waste water potable nor to remove the vast number of chemicals and drugs that find their way down our drains today. The design of the combined sewer systems in the largest cities results in regular discharge of raw sewage during storm events. In the United States the cryptosporidium parasite has caused outbreaks of diarrheal disease in the 1990’s and boil water alerts are frequent occurrences in the in the 21st century. We are having difficulties maintaining our most basic water quality let alone protect the population from emerging contaminants. The Environmental Working Group has called for the EPA to do a national assessment of drinking water quality and establish new safety standards, set priorities for pollution prevention projects, and inform the public of the full range of pollutants in their water. In the meantime, while the EPA spends it time addressing carbon dioxide in the atmosphere you need to carefully consider source water quality, and treatment when selecting where to live.

Bottled Water is Not the Answer

The purity of bottled water cannot be trusted. The Food and Drug Administration (FDA) regulates bottled water as a packaged food under the Federal Food, Drug and Cosmetic Act and has established standards for testing bottled water that are not as stringent as the EPA’s Safe Drinking Water Act (SDWA) standards. While the FDA has established requirements for processing and bottling water to be sold for drinking, the FDA rules do not require disinfection and require only once a year testing for bacteria and other substances. The FDA requires using an approved source of water, but without a definition or control of what an approved source of water that requirement is practically meaningless.

The safest source water is a protected groundwater aquifer with a confining geological layer. When used as the source of the bottled water a protected groundwater aquifer could go a long way to ensuring the water quality, consistency of taste and the absence of cryptosporidium, a microscopic parasite that lives in the intestine of infected animals and humans and occurs mainly in surface water sources, such as lakes, streams and rivers. The safest bottled water like the safest source of any drinking water is from a protected groundwater aquifer or spring, though groundwater aquifers are potentially vulnerable to a wide range of man-made and naturally occurring contaminants, including many that are not regulated in drinking water under the SDWA, or by the FDA for bottled water.

Research performed by the US Geological Survey (USGS) on the quality of the nation’s groundwater found low levels of several chemicals and compounds (at least 10% of the MCL or other human health screening levels). Naturally occurring elements, radionuclides and pesticide compounds were extensively found at these low concentrations. Trace levels of pesticide compounds or VOCs were detected in a slight majority of the groundwater samples from public wells. Pesticides and VOCs were detected in a significantly greater proportion of samples from unconfined aquifers than in samples from confined aquifers. The groundwater with the greatest number of contaminants were consistently from shallower unconfined aquifers demonstrating the natural protection provided by a confining geological layer. Knowing the source of bottled water could provide insight into the quality and safety of the water.

Back in 2007 the Environmental Working Group (EWG) had laboratory analysis performed on bottled water and found that 10 popular brands purchased from grocery stores and other retailers in 9 states and the District of Columbia, contained in total 38 chemical pollutants, with an average of 8 contaminants in each brand. The analyses was conducted by the University of Iowa Hygienic Laboratory and found a wide range of pollutants, including not only disinfection byproducts, but also common urban wastewater pollutants like caffeine and pharmaceuticals (Tylenol); heavy metals and minerals including arsenic and radioactive isotopes; fertilizer residue (nitrate and ammonia); and a broad range of other, tentatively identified industrial chemicals used as solvents, plasticizers, viscosity decreasing agents, and propellants. These are all contaminants that are more characteristic of large system tap water that includes surface water in their water mix rather than a protected groundwater source. In fact, it appeared likely in at least two instances that the water was tap water.

More than one-third of the chemicals identified by the EWG were substances that are not regulated in bottled water by the FDA. Whether a particular contaminant in water is potentially harmful to human health depends on the contaminant’s toxicity and concentration in drinking water. Other factors include the susceptibility of individuals, amount of water consumed, and duration of exposure. Some of the chemicals found are regulated in California in drinking water and exceeded the maximum contaminant level (MCL) under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). California has one of the most extensive and stringent lists of chemicals with MCLs for drinking water and their list is used as a standard for human exposure of substances not regulated under the FDA or SDWA, but many substance found in the bottled water samples are not regulated in water at all. Some of the bottled water tested by the EWG was found to be contaminated with bacteria. EWG’s report did change the regulatory awareness of the problem, increase public awareness of the problem and ultimately nudged some in the bottled water industry to disclose the source of their water or some indication of the source of the water.

The EWG report was followed by a Governmental Accountability Office (GAO) report criticizing the FDA and by Congressional Hearings. There seems to have been little progress the 2009-2010 EWG survey of 173 unique bottled water products found some improvements in product identification and labeling. Despite California’s bottled water law, SB 220, intended to provide transparency as to source and treatment for bottled water there seemed to be little improvement. The EWG found many popular brands of bottle water stated on their labels that water testing results were available from web sites or customer service numbers only to find that the results were, in fact, not available. The purity of bottled water remains in question yet many continue to buy bottled water. There are two independent certifications that often appear on bottled water. The International Bottled Water Association (IBWA) is a trade organization for water bottlers. IBWA members must meet the organization’s “model code” and are subject to annual inspections by an independent third party. Bottlers belonging to IBWA frequently indicate membership on their labels. NSF International - Bottled water certified by NSF undergoes additional testing by unannounced annual plant inspections. NSF certifications mean that the bottler complies with all applicable FDA requirements, including good manufacturing practices.

People may prefer bottled water because of its taste or simply as a healthier drink choice. The taste of all water has to do with the way it is treated and the quality of its source water, including its natural mineral content. According to the EPA, most bottled water comes from groundwater, where water quality varies less from day to day. The water is treated and immediately bottled. Bottled water from a dedicated source may have a more consistent taste than tap water, which in the large population centers is mixed and predominately comes from surface sources and must travel through pipes to reach homes. One of the key taste differences between tap water and bottled water is due to how the water is disinfected. Tap water may be disinfected with chlorine, chloramine, ozone, or ultraviolet light to kill disease-causing germs. Water systems use these disinfectants chlorine and chloramine because they are effective and inexpensive, and they continue to disinfect as water travels through the system pipes and pumps. There is often a residual taste. There are many groundwater sources that do not need to be disinfected and when necessary or desirable the bottled water industry typically uses ozone or ultraviolet light to disinfect the water. These methods leave no residual taste.

EWG and Good Housekeeping recommend that consumers drink filtered tap water or well water that has also been tested and filtered. Though there are no home filters that are certified to remove pharmaceuticals and certain other (emerging) contaminants, Good Housekeeping found some home filters do a great job of removing contaminants. The GH Research Institute, working with the Arizona Laboratory for Emerging Contaminants at the University of Arizona, tested the effectiveness of a group of filters at removing a group of these emerging contaminants. The water was spiked with low levels of Atrazine (herbicide), BPA (bisphenol A, used in production of plastics and in resins in many metal can liners), Carbamazepine (anticonvulsant), DEET (insect repellent), Estrone (hormone), Fluoxetine (Prozac, an antidepressant), Ibuprofen (pain reliever), PFOA (perfluorooctanoic acid, used to make nonstick-cookware coatings and other products), PFOS (perfluorooctanesulfonic acid, a key ingredient in stain repellents), Primidone (anticonvulsant), Sucralose (artificial sweetener), Sulfamethoxazole (antibiotic), TCEP (flame retardant), Tonalide (fragrance), and Trimethoprim (antibiotic) and the effective removal of contaminants by various commercially available home filters was measured. They found that many were very effective, but the best was the Whirlpool Filter 1 Refrigerator Filter which removed more than 92% for all contaminants over the life of the filter. ZeroWater 8-Cup Pitcher, $35 was found to be the best pitcher type filter. See http://www.goodhousekeeping.com/product-reviews/health-products/water-filters#slide-5 for the full report.

Filtering your tap water and using your own stainless steel bottle saves money, it’s purer than tap water and it helps shrink the global glut of discarded plastic bottles. If your home’s water comes from a public water system, the best way to learn more about your water quality is to read your water supplier’s annual water quality report which should be sent to you annually. If your water comes from a private drinking water well, EPA recommends testing the water regularly for bacteria, nitrates, and other contaminants. At a minimum you should test your drinking water for the 90 SDWA primary contaminants at least every few years and for a shorter list of contaminants including bacteria and nitrates annually.

Solution to Pollution is Dilution

When I worked at the US EPA in the 1970’s there was a sign on the wall of the adjacent office that said, “The Solution to Pollution is Dilution.” There was both truth and cynicism in that sign. At the time we were determining the likely contaminates in a waste stream and the levels of those contaminants that would be acceptable based on the potential impact to life. The guiding principal of toxicology is that there is a relationship between a toxic reaction (the response) and the amount of poison received (the dose). An important assumption in this relationship is that there is almost always a dose below which no response occurs or can be measured. So if the concentration of the contaminant was low enough there would be no toxic reaction.

In addition, there is another factor that has been observed for generations and studied in the recent decades. The planet is able to filter and heal itself from limited amounts of pollution. There have been numerous studies of groundwater and surface water systems that have documented this. In Dutchess County New York and North Carolina studies documented that the most important factor in septic regulation is controlling nitrogen pollution from septic systems was average density. Both studies demonstrated that density of on-site waste disposal should not exceed one unit per 2-3 acres for an average size house (and household) to ensure water quality. Adequate dilution, soil filtration and time are necessary to ensure sustainable water quality. These studies were performed on nitrate concentrations as a proxy to achieve adequate dilution and natural attenuation of all contaminants.

Historically, horizontal and vertical setbacks for septic systems were developed without consideration of the dilution for wastewater components like nitrate, pharmaceutical residue, caffeine and other substances we humans consume, process or produce. The overall regional density of septic systems was examined to ensure that groundwater resources would not be overwhelmed by the total load of contaminants. The density recommendations were developed based on the nitrate concentration in traditional septic wastewater. Nitrate was used as a proxy because all humans produce about 10 pounds of nitrate per year, it does not easily break down and there is a drinking water standard and an inexpensive analytical test. Dilution was really the goal here.

An estuary is a coastal area where freshwater from rivers and streams mix with saltwater from the ocean. Estuaries are protected from the full force of the ocean by mudflats, sandspits and barrier islands. One of the least appreciated functions of estuaries is to help control pollution. Water from upland areas often carries sediment and pollutants. The marshy land and plants in estuaries filter these pollutants out of the water. The plants in estuaries help prevent shoreline erosion. Estuaries also protect inland areas from flooding and storm surges. When a storm hits, estuaries often absorb water from the storm before it can reach upland areas. The Chesapeake Bay is an estuary. Right now we are engaged in a major effort to reduce the nitrogen, phosphorus, and sediment pollution that enters the estuary through its tributaries in an attempt to restore the estuary to some arbitrary historic state.

The Chesapeake Bay and its tidal waters are impaired by the release of excess nitrogen, phosphorus and sediment. These pollutants are released from waste water treatment plants, from agricultural operations, urban and suburban runoff, wastewater facilities, air pollution and other sources, including septic systems that enter the tributaries and Chesapeake Bay. These pollutants cause algae blooms that consume oxygen and create dead zones where fish and shellfish cannot survive, block sunlight that is needed for underwater grasses, and smother aquatic life on the bottom. Over the past quarter century the excess nutrient contamination to the Chesapeake Bay has decreased, primarily because of regulation of wastewater treatment plants and improved farm practices, but the Bay’s waters remain seriously degraded.

The “strict pollution diet” that EPA is imposing on the six Chesapeake Bay Watershed states only addresses nitrogen, phosphorus and sediment it does not address other contaminants that have been noted in the tributary waters by the US Geological Survey. The USGS began looking into skin lesions on bass in the southern branch of the Potomac River. Some fish had bacterial lesions, some fungal lesions, and some fish had parasite. The USGS concluded that there was no specific cause of the lesions and that the fish appeared to be immunosupressed so that any pathogen in the water could attack the fish. A series of studies were performed over a period of years and it was discovered that the bass suffering from lesions were intersexed. This prompted further sampling of the river that identified higher concentrations of wastewater chemicals near the wastewater plants. Pesticides currently used in agriculture were detected at all locations sampled and traces of estrogenic endocrine-disrupting chemicals were found at all locations examined though their source is not yet known. Though they cannot identify a single chemical or group of chemicals responsible, USGS have embarked on further study to gain greater understanding of the implications to the earth’s ecosystem.

Who is Going to Control Your Water?

Water shortages are nothing new a consistent and clean supply of water has been problematic throughout human history. Climate does change, the Sahara Dessert had adequate surface water only 5,000 to 6,000 years ago. There were lakes and rivers and the Sahara was green. Water supply will not just be a problem in developing countries and does not even require the climate to change. Today the combination of inadequate supply of water in some locations, mismanagement of resources and the pollution of fresh water supplies with endocrine disruptors and trace chemicals from recycled water and runoff will grow into an outcry. Non-point source pollution and water ownership will become the issues in the United States and the developed world. After reducing point source pollution over the past 40 years, we are faced with the more difficult problem of non=point source pollution, Suddenly, everyone will be aware that the fresh water in some locations has annual limits (in truth we have impacted the recharge rate of our fresh water resources) and that the water supplied to their tap by public water companies includes the output stream of the waste treatment plant, urban and agricultural runoff still containing all the trace elements not tested for in our water supplies. There are limits to this renewable resource and it needs to be managed. Political influence is the recipe for mismanagement of water resources. There will be rationing in critical locations and ownership of water rights will become contested. Groundwater and surface water are tied in ways that are not yet fully understood. Changes, diversions, pumping can effect quantity of the water supply.

Non-point source (NPS) pollution is a major factor impacting the quality of the water supply in the United States today. These pollutants are transported to surface water bodies by runoff, which results from precipitation or snow melt (Leeds et al., 1993). Storm water is part of the natural hydrologic process; however, human activities, especially urban development and agriculture, cause significant changes in patterns of storm water flow and infiltration and the type and quantity of contaminants carried from land into receiving waters. The Federal Clean Water Act gives regulatory authority to restrict pollutants discharged into rivers from point sources, such as waste water treatment plants. When the regulations were created 40 years ago, they were intended to address the 85% of pollution believed to be caused by large industrial polluters. Recently William Ruckelshaus (first administrator of the EPA) wrote in the Wall Street Journal “The current generation of (environmental) problems that we are facing, though, is much more subtle, much less visible to the naked eye- and often not nearly as susceptible to a top-down, command-and-control approach.”

Federal authority does not extend to non-point sources, such as farms and septic systems, and in truth Mr. Ruckelshaus is right those problems could not be solved by federal or state regulation. The states need to address these non-point sources using other approaches. Reductions in discharge of contaminants can be achieved through the implementation of “agricultural best management practices” operations and good environmental stewardship practices; however there is building support for direct control of non-point source contaminants and control of water supplies. The suggestions for regulation made by advocacy groups are invasive and far reaching including ownership of the water itself. This will never work. A citizen collaboration between farmers and citizens needs to be created that will encourage and enable prosperous farms, safe drinking water, healthy fish and estuaries and sustainable development. These collaborations are slow to form and function and must begin with knowledge.

Water regulation movements are moving quickly, but they are of the command-and-control variety. Virginia is one of the 40 states with water ownership always assumed to pass with the land. Water is wealth and having the government assume control of water allocations either in a permitting process or direct allocation is frightening, but that is what is happening. The Virginia Ground Water Management Act of 1992 mandates the regulation of large groundwater withdrawals in certain portions of the Commonwealth to prevent adverse impacts due to over utilization of the resource. In the past year there were two proposed changes to the regulations. It was proposed that the Eastern Virginia Ground Water Management Area be expanded to include area beyond the eastern shore and even the confines of the Tidewater, west of the fall zone, into other groundwater basins. The second proposed change was ambiguous and seemingly ambitious in its reach: the Board and DEQ propose “to consider amending the Ground Water Withdrawal Regulation, 9 VAC 25 610 to address the increasing demand on limited groundwater resources, changes to the administrative review process, and regulatory changes necessitated by new information on the coastal plain aquifer system.” Towards that goal the Commonwealth is forming a State Water Plan Advisory Committee without any citizenship/landowner representation. Who is going to control your water?

Your Chemical Exposure

Chemicals are everywhere, they exist in pharmaceuticals, household products, personal care products, plastics, pesticides, industrial chemicals, human and animal waste; they are in short, all around us. According to the Toxic Substances Control Act (TSCA) inventory of chemicals there are more than 84,000 chemical substances, as defined in TSCA today. These chemicals include organics, inorganic, polymers, and UVCBs (chemical substances of Unknown or Variable composition, Complex reaction products, and Biological materials). According to poll of 2,016 British women by deodorant-maker Bionsen, the typical woman applies 515 chemicals daily to her body between perfume, soaps, shampoos, styling lotion, skin lotions, face creams, makeup, and the list goes on. This may or may not be alarming, because these chemicals are applied to the skin and need to pass the barrier to become bioavailable, but it is certainly an indication of how pervasive chemicals are in our lives.

In December the Center for Disease Control released their most recent National Report on Human Exposure to Environmental Chemicals. Thought the report was incomplete at the time of release, it is the most comprehensive assessment to date of the exposure of the U.S. population to chemicals in our environment. CDC measured 212 chemicals in the blood and/or urine of the participants. The samples were collected from participants in CDC's National Health and Nutrition Examination Survey (NHANES), which is an ongoing survey that samples the U.S. population every two years. Each two year sample consists of about 2,400 people. What the report found was Widespread Exposure to Some Industrial Chemicals throughout the population tested. The implications of this ubiquitous exposure are unknown, but of concern. The detection of a chemical in people's blood or urine does not mean that it will cause health effects or disease. It has been believed for hundreds of years that the toxicity of a chemical is related to its dose, in addition to a person's individual susceptibility. The philosophy that small amounts were of no health consequence has been the cornerstone of toxicology and regulation, but that has recently come into question. For most of the environmental chemicals included in the CDC Report, more research is needed to determine whether exposure at the low levels reported is a cause for health concern.

Findings in the Fourth National Report on Human Exposure to Environmental Chemicals indicate widespread exposure to some commonly used industrial chemicals. This exposure may not be new, per sea but our ability to identify parts per trillion has opened the door to a raft of concerns and questions. Though you might want to read the entire report or just the executive summary, I’ve included some highlights.

Polybrominated diphenyl ethers are fire retardants that accumulate in the environment and in human fat tissue. One type of polybrominated diphenyl ether, BDE-47, was found in the serum of nearly all of the NHANES participants.
Bisphenol A (BPA), a component of epoxy resins and polycarbonates, and a potential endocrine disruptor was found in more than 90% of the urine samples of the participants.
Another example of widespread human exposure included several of the perfluorinated chemicals. One of these chemicals, perfluorooctanoic acid (PFOA), is a byproduct from the manufacture of polytetrafluoroethylene, which is used to create non-stick coatings in cookware. Most participants had measurable levels of this contaminant.
The gasoline additive methyl tert-butyl ether (MTBE) has been eliminated in gasoline formulations, but a high percentage of the NHANES participants showed detectable levels of MTBE.
The chemical perchlorate is both naturally occurring and manmade and is used to manufacture fireworks, explosives, flares, and rocket propellant. For decades, scientists have known that large doses of perchlorate affect thyroid function. Low-level exposure to perchlorate from the environment has been under investigation in recent years. All NHANES participants were found to have detectable perchlorate in their urine.
Total blood mercury levels, primarily composed of methyl mercury, which enters the body mainly from dietary seafood sources. Findings show that total blood mercury levels increase with age for all groups and begin to decline after the fifth decade of life.
A big bright spot in the report was the continued decline in Lead levels in blood.

Many questions were raised by the CDC data, one that has not been fully addressed is the route of exposure. The CDC believes that for most chemicals, people are exposed to low levels through foods or by breathing in air that contains the chemical or consuming water, plants or animals that contain the chemical. The CDC suggests that MBTE could have potentially contaminated water sources. I have seen perchlorate as a groundwater contaminant all over California during site investigations. People can also be exposed by using products with chemicals in them or which have been stored in containers made with the chemicals. The Agency for Toxic Substances and Disease Registry (ATSDR), the National Institute of Environmental Health Sciences (NIEHS), and the U.S. Environmental Protection Agency (EPA) sponsor research that addresses sources and effects of chemical exposures. The EPA has recently launched investigations into BPA and other endocrine disruptors.

Endocrine disruptors are a class of chemicals that can mimic, block, or otherwise alter animal hormone responses, sometimes affecting their reproduction, development, and behavior, this is actually, how some pest control treatments are designed to work. A diverse group of chemicals called endocrine disrupting chemicals (EDCs) come from a variety of sources. These chemical have diverse molecular structures. BPA is just one of these chemicals. These chemicals become of great concern when they are discovered to be potential human endocrine disruptors as DDT, dioxin, the drug DES and PCBs were in the past. Traces of endocrine disrupting chemicals are seemingly found in every part of our world, including dust, soil, water, air, food, manufactured products, wildlife, and even ourselves. So, as congress considers revising the Toxic Substances Control Act, EPA and NIEHS begin their investigations into endocrine disruptors.

Agriculture a Source of Pollution and Environmental Impact

Non-point source pollution is cumulative in nature. While any single contributor of non-point source contamination may be insignificant, the cumulative effect of many such sources is measurable and leads to significant pollution of ground and/or surface waters. Surface and groundwaters are interrelated. Groundwater is surface water (lakes, rivers, streams, or overland flow from precipitation) that has percolated into and then through the ground to an aquifer. Groundwater may move back into surface water bodies through seepage, springs, or base flow into a river or lake depending on the geology of an area. Contaminated groundwater can move into uncontaminated aquifers or return to surface water, depending on the geology. Section 319 of the Federal Clean Water Act mandates development of programs for control and reduction of non-point source pollution of both surface and ground water.

Non-point source contamination comes from run off both agricultural and urban as well as other small sources such as septic and AOSS. Agriculture is reported to be one or the main non-point sources of water pollution and in studies done in the Chesapeake Bay Watershed and Sacramento River Delta and other locations the contamination from agriculture runoff has been the major source of contamination. Pesticide runoff is a large contributor of known pollutants to the watersheds and may be a significant contributor of endocrine disruptors to the freshwater supply. Both rain feed and irrigated agriculture are sources of contamination of fresh water. In April of 2009 the US EPA issued the Final List of Initial Pesticide Active Ingredients and Pesticide Inert Ingredients to be Screened Under the Federal Food, Drug, and Cosmetic Act as potential endocrine disruptors. These pesticides need to be further investigated and our use of pesticides reexamined and rethought.

In rain fed agricultural land, the precipitation washes agricultural chemicals (pesticides and herbicides) along with soil sediment to surface water. In addition, irrigation of the fields can increase the run off. Other sources of non-point souce contamination are confined animal feed lots, grazing, plowing, pesticide spraying , fertilizing, planting and harvesting a crop which can all contribute to run off of contaminants and sediment. The National Water Quality Inventory Report to Congress was intended to identify widespread water quality problems of national significance. This has served as a proxy for the quality of the waters of the nation despite a non systematic approach to identifying water quality by the states and significant limitations to the substances tested for. Many states target their limited monitoring resources to waters they suspect are impaired and, therefore, assess only a small percentage of their waters. These may not reflect conditions in state waters as a whole and tend to reflect areas of concern in the “water community.” The US-EPA in its last report to Congress identified agriculture as the leading cause of water quality impairment of rivers and lakes in the United States. Agriculture is also cited as a leading cause of groundwater pollution in the United States.

There are other significant environmental impacts from agriculture. When agricultural land is irrigated, the water balance in nature is altered. Water is withdrawn from a river, spring, or groundwater and added to agricultural fields. The environmental impact of an irrigation system is dependent on the nature of the water source, the quality of water, the method of delivery and the local geology and climate. Withdrawing ground water beyond the recharge rate may cause the land to subside as happened in the Central Valley of California. Aquifers may become saline. All water contains dissolved salts that attached to the water molecules as it washed over the land or percolated in the ground. Rain also contains some salts. The salts are generally at very low concentrations in “fresh” water’ however, evaporation of water from dry earth leaves much of the salts behind. Over time the salts concentrate. The problem is acute in the Central Valley of California, in China’s North Plain, in Soviet Central Asia (the –istans), parts of the Middle East and the Colorado River Basin. These are all semi-arid areas where irrigation is the basis of agriculture.

Withdrawing both groundwater and surface water can dramatically change the natural hydrology of rivers and water streams, water temperature, and can impact the aquatic ecosystem associated with the surface water. The San Joaquin River in California has been dewatered as has been Owens Lake. The Colorado River runs dry before it reaches the Ocean most years as does the Yellow River in China. The riparian ecosystems and delta estuaries associated with these areas no longer receive fresh water recharge and have been destroyed.

However, irrigation has vastly improved crop yields in many semi-arid climates. As population grows, and the demand for food increases irrigation is unlikely to be discontinued. Methods and control of irrigation can determine the extent of the environmental impact from the irrigation. Improved field irrigation practices are critical to limiting the impact. It is reported that irrigated agricultural land is two and a half times more productive than rain fed agricultural land and the limits of irrigation really are the fresh water resources, the capital costs and the saline buildup over time in the farm land and aquifers. To feed the populations of the earth and protect the earth mankind needs to utilize intelligent and environmentally balanced farming practices employed .

Water is still the Fluid of Life

Our quality of life and life itself is dependent on our access to water. Mankind cannot survive without water. One of the world’s most critical problems is a lack of quality water. More than a billion people lack access to safe drinking water, and 1.5 million deaths, mostly among children underage five, are attributed to unsafe drinking water each year. People are dying today for lack of clean water. The projections for 2030 are for significant and potentially life threatening water shortages in parts of the world.

Though I tend to distrust all long term modeling efforts for their simplifications and straight line projections; however, water planning ten and twenty years out is a standard practice in the US west and other water critical areas of the world. Water supply projection a decade or two out is a much simpler model than say climate projections, but still are impacted by non correlated variables and limited knowledge of groundwater recharge and reserves that would make it difficult to accurately projects water demand and availability.

In California, the combined demand for irrigated agriculture, expanding suburban footprint, habitat protection, and drought have stressed the water supply. For more than a half a century the Central Valley of California has been one of the most productive agriculture regions of the world. On less than 1% of the total farmland in the U.S. the Central Valley produces 8% of the agricultural output (as measured by value). In 2002 this translated to $17 billion in crop value. This is all made possible by irrigation. Approximately one sixth of the irrigated land in the United States is in the Central Valley of California (Bureau of Reclamation, 1994) and approximately one eighth of all groundwater pumped in the United States is pumped in the Central Valley. According to the US Geological Survey the Central Valley of California was mining groundwater at approximately 1,900 cubic feet per second from 1962 to 2003. As California learned this is an unsustainable practice.

In Virginia, the Water Resource Research Center at Virginia Polytechnic Institute and State University, WRRC, has been studying the projected future demand for water in the Commonwealth and examining the options. From 1999 to 2002 many localities in Virginia experienced a severe drought, but periodic droughts in Virginia are not unusual. In the past, the groundwater had served as the backup resource during critical water shortages. The recent drought was note worthy because the population shifts and growth had caused declining groundwater levels and increased demand in some regions. The WRRC states that there is a high probability that the costal areas and northern Virginia face a sever water shortage in coming decades because of the periodic droughts and increased water demand. Traditionally, building dams and reservoirs and inter-basin transfer of water were used to supply the state. However, these methods would face significant economic, environmental, regulatory and societal challenges in the future.

The WRRC suggests several options to supplement water supplies in these critical areas: water conservation, water reuse, groundwater recharge and desalination. Water conservation is the low lying fruit, but is unlikely to meet the increased demand. Water is the fluid of life and should never be wasted. My years in California make me acutely aware of and careful of my water use. It is important to teach the next generation to use water more wisely than the current generations have. Nonetheless, conservation alone will not be enough. Though we could limit population density by water carrying capacity of the area, the WRRC makes other suggestions.

Desalination techniques are being developed and planned in Florida and California. Their pressing needs will allow others to learn from their experiences, but their ability to supply any significant amount of drinking water is many years in the future. Enhancing groundwater recharge would improve groundwater supplies by an unknown amount. Certainly, elements of long-term water supply planning should be part of all development and growth planning. Groundwater sustainable development would include protection of aquifer recharge zones along with increasing subsurface infiltration and groundwater recharge by implementing low-impact development techniques, such as forestation and bioretention in urban and suburban areas. However, recharging groundwater with reclaimed water and the reuse of the reclaimed water, though practiced in many areas, is of real concern.

When the USGS began looking into a series of fish kills in the southern branch of the Potomac River, they found fish suffering from a variety of lesions. Some fish had bacterial lesions, some fungal lesions, and some fish had parasite. The USGS concluded the fish appeared to be immunosupressed so that any pathogen in the water could attack the fish. A series of studies were performed over a period of years. During the investigation it was discovered the bass suffering from lesions were intersexed. It had previously been demonstrated that estrogen and estrogen mimicking compounds can cause intersex. The occurrence of intersex among the lesioned fish prompted further studies. Since 2004, unexplained fish kills have occurred in the Shenandoah River basin. During 2007 and 2008 similar events took place in the upper James and Cowpasture rivers. Fish kills occur in various parts of the country and seem to occur for a variety of reasons.

The studies of the Potomac fish kill found the problem of endocrine disruption in fish to be widespread within the study area, a portion of the Chesapeake Water Shed, but increased in proximity to and downstream of the waste water treatment plants. Chemical sampling that took place along with the fish sampling found higher concentrations of waste water chemicals near the waste water plants. Pesticides currently used in agriculture were detected at all locations. Hormones were not detected in the samples, but analysis using yeast screening assays found estrogenic endocrine-disrupting chemicals at all locations their specific source is not yet known. Though they cannot identify a single chemical or group of chemicals responsible, the US FW and US GS have embarked on further study.

This reclaimed water implicated in the study is the same reclaimed water the WRRC suggests we all drink and forcibly use to recharge previously pristine groundwater. Due to its protected location underground, most groundwater is naturally clean and free from pollution. Recharging groundwater with reclaimed water may not be the best of ideas until more is known about the causes of the lesions and intersexed fish and the implications to human life. In April of 2009 the US EPA issued the Final List of Initial Pesticide Active Ingredients and Pesticide Inert Ingredients to be Screened under the Federal Food, Drug, and Cosmetic Act as potential endocrine disruptors. Pesticide runoff is a large contributor of known pollutants to the watershed. Water is the fluid of life.

Virginia’s Emergency Alternative Onsite Septic System Regulations Comments 1

On September 28, 2009 the Virginia Department of Health published their proposed Alternative Onsite Septic System, AOSS, regulations for public comment. There was a 30 day comment period that closed on October 28th 2009. On Friday, November 6, 2009 the Department of Health posted the comments. I was a little surprised to see both my comments and what I thought was a personal e-mail to Alan Knapp posted as comments. Nonetheless, I learned a lot reading through the comments and was really pleased with all the sheer number of people who participated in the regulatory process. The comments and emergency regulations are posted on the VDH website for your review. There are 187 pages of comments from designers, regulators, manufacturers, environmental groups, consultants, and homeowners. Some of the comments are so technical in nature that I fear the resolution would require a multi year experimental program. Many comments are interesting.

Thomas Crow of the Fairfax Co. Health Department points out that “In the initial stages finding an operator for home owners will be difficult and expensive. There are very few operators for a home owner to choose from in today’s market. We suggest providing an effective date for this paragraph to allow time for the infrastructure to be built to meet the demand.” He goes on to suggest that Emergency Regulations require that “…operating permits must be renewed every five years by the Health Department. We believe that requirement is necessary because local Health Departments lack the staff necessary to adequately provide oversight to the program as described in the regulations. Requiring a renewable permit will make it ensure that the Health Department is able to evaluate each AOSS at least every five years.” So, every year the Health Department will have to issue or renew operating permits complete with sampling for 20% of all AOSS in the state and every new system built. I do not think that will alleviate the staffing issue. Furthermore, if the operating permit lapses is the occupancy permit voided or must the homeowner begin pump and haul until such time that the department of health renews the permit. I think the idea of outside licensed operators and computer systems was intended to automate compliance someday, not create a system where the VDH needs to manually review and issue a new permit for an ever growing number of systems each year.

Scott Fincham also of the VDH points out that according to his reading of the regulations “Low Pressure Distribution System’s will be considered Alternative (AOSS) and thus require maintenance and monitoring.”

W. Todd Benson of the Piedmont Environmental Council points to the USGS research on the Potomac River that identified intersexed fish. Researchers identified the presence of endocrine disruptors. “Evidence is mounting that trace levels of prescription drugs in rivers and streams may be harming fish, tadpoles, frogs, mussels and oysters. Obviously, the same constituents in the solid and liquid waste stream of conventional waste water treatment works should be expected in AOSS effluent. One might assume that the risk posed by and individual AOSS is the same or better than individual, traditional septic system and, therefore, the permitting of individual AOSSs should be allowed. But the assumption of no greater harm dissipates as the systems grow in size.” Emerging chemicals of concern will be an issue to septic systems, AOSS, clustered systems and sewage treatment plants in the future. It is unknown which of these systems will prove most protective of human health and the environment. Soil filtration may prove to be more effective that point source release. There is still much research to be done in this emerging area of investigation. Todd is correct when he states “These regulations are prepared without any analysis of or attention to the problem of endocrine disruptors or other chemicals of concern.” The PEC recommends that all AOSSs other than individual AOSSs should be banned.

Several different investigations within the Fish and Wildlife Service and US Geological Survey studied the relationship between wastewater treatment plants, other chemicals, and the impacted fish. The study Todd refers to found the problem of endocrine disruption in fish to be widespread in the limited study area of a portion of the Chesapeake Water Shed, but increased in proximity to and downstream of the wastewater treatment plants. Chemical sampling that took place along with the fish sampling found higher concentrations of wastewater chemicals near the wastewater plants. Pesticides currently used in agriculture were detected at all locations. Hormones were not detected in the samples, but analysis using yeast screening assays found estrogenic endocrine-disrupting chemicals at all locations their specific source is not yet known. Though they cannot identify a single chemical or group of chemicals responsible, the US FW and US GS have embarked on further studies.

Anish Jantrania, Ph.D., P.E, a former VDH employee, is a supporter of the clustered systems and today makes his living designing and operating those systems. I should give him the opportunity to counter the PECs recommendation against clustered systems, but as always Anish’s comments are way beyond my knowledge base, but he does state “It is important that Lab Sampling be required for ALL types of AOSS, large and small, at frequency that does not create undue financial burden on either type of AOSS… It’s all about Performance WITH Verification.” I like the philosophy which would allow the regulations to evolve with the knowledge base. However, I am still thinking about that, after all, for at least the single family homeowner the requirements of the Emergency Regulations are intended to ensure that these systems perform to protect public health and the waters of the Commonwealth of Virginia. For single family homes the typical homeowner cannot afford a gold plated regulatory system with every potential system and regulatory failure, monitored for, tested for, permitted and re-permitted on the homeowner’s nickel. As Todd elegantly points out, highly regulated point source generators, waste water treatment plants, may not provide adequate protection of the waters of the state from man. We as a state could not afford the infrastructure necessary to monitor and verify performance and operation, and the homeowner can only afford essential protections to protect public health and the environment, not those that make a regulator's life easier. The Department of Health needs to determine the reasonable compromises that will protect public health and the environment in a less than perfect world.