Open Letter to the EPA’s Drinking Water Strategy Discussion Forum

Posted by Peter Fiske on 9/7/10 8:32 PM

The EPA recently announced a new strategy to provide clean, safe drinking water and a novel means by which those of us in the water industry, and citizens in general, can comment on it: an on-line discussion forum.

EPA ForumWe at PAX Water Technologies are encouraged that the EPA is seeking out comment and feedback as it formulates its strategy, and we posted this comment to the discussion group today under Topic 2: (Foster development of new drinking water technologies to address health risks posed by a broad array of contaminants).

Focus on the Distribution System

We at PAX Water have noticed that the EPA tends to be somewhat “treatment-centric” in its approach to drinking water technologies. Most of the funding and technical focus for drinking water at the EPA appears to be on treatment technologies targeting very specific regulated contaminants in the treatment plant itself. The potable water distribution system, in contrast, appears to be thought of as a passive system of pipes and tanks – capable only of transporting drinking water from the treatment plant to the customer (and often with some degradation in water quality along the way). This narrow focus misses the potential synergies where new technologies combined with emerging best management practices can have profound impacts which may mitigate the need for many complex and costly treatment systems altogether.

 

We think the EPA is missing a strategic R&D opportunity.  Potable water distribution systems provide municipalities the opportunity to intervene at multiple points and measure and improve water quality all along the way.  In-line sensors can continuously monitor water quality and adjust treatment parameters, and distributed disinfectant boosters can “right-size” disinfection to minimize the production of disinfection by-products. 

 

Active mixing is another example. Presently, fewer than 1% of potable water storage tanks in the United States are equipped with active mixers.  Yet studies have shown that active mixing in water storage tanks can significantly reduce disinfectant loss, lower DBP production and improve water quality.  Similarly, a regular schedule of tank maintenance, clean-out and recoating can preserve the integrity of distribution infrastructure indefinitely.  By integrating these practices and technologies into the distribution system, water quality can be increased, and energy and disinfectant chemical use can be lowered.

 

We encourage the EPA to adopt a strategic approach to distribution system technology. The EPA’s Environmental Technology Verification Program is nice, but it focuses on singular technologies, and not systems of technologies and practices. Similarly, EPA’s SBIR program seems to focus largely on individual technologies and not systems of technologies and how they interact. The Department of Energy has recognized that out-of-the-box technological solutions to critical problems can’t be funded by small-scale programs like SBIR, which is why they created the highly successful ARPA-E program to support innovative energy technologies. Why not an ARPA-W for water?

 

What do you think?  We welcome your comments.

 

Sincerely,

Peter S. Fiske, Ph.D.

CEO, PAX Water Technologies

Topics: Water Quality, storage tanks, mixing systems, dbp formation

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