Perhaps using a Toxicity Equivalence Factor aproach as has been vdeveloped for PAHs and Dioxins can be developed for other classes, for example pesticides that are cholinesterase inhibitors. Setting standards for “solvents” as a class will be extremely challenging.

I support research in mechanistic toxicology because it not only improves certainty in risk assessments as well as informing green chemistry for designing safer chemicals.

Therein lays a critical element that must be considered in developing innovative new water treatment technologies and in convincing the private sector to invest in these technologies. It is all very well to throw money into research to develop new technologies to address new contaminants, but unless the barriers to commercializing these technologies are removed the ‘research stimulus’ will be all in vain!

The following are some suggestions to help address these barriers:
1. Create a uniform set of requirements across all US States for the approval of new technologies. Currently permitting requirements for new technologies at the State level varies significantly and many states do not even have procedures for approving new technologies. Manufacturers are therefore required to commit to considerable time and expense in repeating trials and completing the necessary submissions on a state-by-state basis. This is probably most critical barrier that must be overcome.
2. Provide funding for demonstration sites for new technologies that are developed to address new or proposed contaminant regulations. Demonstrations should generate independent data on lifecycle costs for these technologies versus more traditional alternatives so that these costs are more accepted by end users. These technologies should then be exempt from requiring further acceptance testing at the State level.
3. Criteria for the allocation of grant monies often require technologies to be proven locally either via existing installations or extensive trials, or require bonding which disadvantages new technologies in grant funded projects. Remove the requirement for local installations where new technologies have been accepted at the Federal level and require allocation criteria for SFR grants and loans to include favorable consideration of those projects with lowest lifecycle cost. Provide guidelines for determining lifecycle cost to ensure consistency in these determinations.

The above suggestions will also go along way to convincing the public sector to accept and invest in the newly developed technologies where regulatory approval processes are clear and consistent and independent performance data is available. Suggestions to assist making new technologies also available to small systems are as follows:
1. State-specific acceptance criteria requiring extensive trials and permitting requirements for new technologies make it too expensive for small systems to consider new technologies. A uniform Federal acceptance process that eliminates the requirement for separate State acceptance could eliminate this cost barrier.
2. Reducing the up-front expense of introducing new technologies for small systems such as extensive trials and approval processes will also provide a greater incentive for private industry to develop custom technological solutions for this market segment.

I am very encouraged by the objectives of Topic 2 and providing incentives to accelerate new technology development is an excellent initiative but I stress that for there to be any meaningful return on this investment, the subsequent barriers to commercializing the resulting innovations must be addressed.

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?

My City of Malibu needs to address its wastewater treatment problem. For a host of reasons, Malibu, which consists of 21 miles of scenic, geologically fragile mountains and coastline, does not have a centralized wastewater system and almost all of its 7,000 or so homes have onsite wastewater treatment systems (septic systems). Recently, regional water officials prohibited septic systems from operating in the first of many discrete Malibu areas and are requiring the City to implement a centralized system. The City estimates that the cost for the first centralized wastewater treatment system serving only 400-500 homes will be $52 million. Affected homeowners will pay from $500 to $1,000 per month and commercial users will pay significantly more. Even for Malibu, a notoriously affluent community, the cost to implement this first phase plan is staggering. Malibu is desperately seeking alternatives.

We need smaller technology. The centralized wastewater system, like the system for delivery of water, is antiquated. Just as it would be crazy to build a wired system for telephones in say, Africa, when wireless technology is now available, it would be crazy (e.g., energy wasteful and expensive) for the City of Malibu to build an infrastructure to collect sewage, transport it over difficult terrain and treat it in a centralized place before discharging it and smaller technology provides the answer.

Septic system technology has not progressed all that much in the past 100 years. As wastewater from the home flows into the septic tank, the heavier solid materials settle to the bottom (forming a sludge layer), the lighter greases and fats float to the top (forming a scum layer), and the liquid (sewage effluent) flows out of the tank. An outlet baffle (or a sanitary tee at the outlet end) prevents solids from flowing out with the liquids. The tank’s primary purpose is to retain the solids while releasing sewage effluent to the drainfield. As I understand it, the real so called “treatment” of the wastewater occurs in the soil beneath the drainfield. Sewage effluent flows out of the tank as a cloudy liquid that still contains many biological and chemical pollutants, flows into the perforated pipe in the trenches, passes through the holes in the pipe, and then trickles down through the gravel into the soil. As effluent enters and flows through the soil, some of the bacteria are filtered out, and some viruses, and certain of the chemicals, including phosphorus and some forms of nitrogen are absorbed by the soil. Unfortunately in Malibu and around the country, soil-based systems (with a leach or drain field) are often installed at sites with inadequate or inappropriate soils, excessive slopes or high ground water table. These conditions cause hydraulic failures and consequently water resource contamination. This is happening in Malibu and all across the country.

What if septic systems were turned into individual alternate wastewater treatment plants? Consider the technology developed by Dean Kamen for Slingshot http://gloobts.com/site/random-thoughts/4315-dean-kamens-water-purification-system-by-deka-research

Although the public may not be ready to drink reclaimed effluent, use of the purified water for irrigation and other uses would be a no-brainer. In any event, if the effluent was adequately filtered before it was discharged; it would eliminate the contamination which is of primary concern of stakeholders and regional water quality control boards across the county. Just consider what it would mean if wastewater purification systems were put in place on a large scale. Millions of home septic systems could be put to work to clean rather than to contaminate our aquifers and save water at that same time. If the effluent treatment could be accomplished in an energy and cost-efficient manner, the benefits could be astounding.

Incredibly, nearly one in four households in the United States depend on an individual septic (onsite) system or small community cluster systems to treat wastewater? http://cfpub.epa.gov/owm/Septic/index.cfm

Nationwide, decentralized wastewater treatment systems (septic systems, private sewage systems, on-site sewage disposal systems) collect, treat, and release about 4 billion gallons of effluent per day from an estimated 26 million homes and businesses (USEPA, 2002). More than half of these systems were installed over 30 years ago when rules were nonexistent, substandard or poorly enforced.

SAVE THE MALIBU, CHANGE THE WORLD!