Manganese Requirements in Drinking Water

By Brian Lemay No comments

Thank you, Jack, for that kind introduction, and
good morning everyone. [AUDIENCE]: Good morning. So, I know the questions that must be in your
mind are, well: At what level of manganese do we have to
monitor, do we have to report, and take
corrective action? So, I want to, I want to cover that today, some of
those basic questions. And I want to start with a historical perspective, on manganese. How many of you are familiar with the .05
mg/L…yes…standard? I call it the “aesthetic standard.” When your sampling results exceed .05 mg/L,
as Rich was saying, that’s when some of those
aesthetic issues come in. It’s when some of the consumer complaints
might come up. And, up to now, MassDEP hasn’t had a lot of
requirements, if you exceed .05 mg/L. Only in a case where there are a lot of
consumer complaints, where you might have
been asked as a public water supply, to take corrective action. That’s changed, as of 2014. To start with, you know we’re–everyone knows
that if you exceed .05 mg/L in your sample
results, you might be getting some complaints, on the taste, the color, the staining of laundry or
plumbing fixtures. And the US EPA, you know, has set up a
Secondary Maximum Contaminant Level
(SMCL) because of this reason. Before 2014, it was just voluntary. Our letters would go out and say “voluntary
monitoring,” you know, or if we get a lot of complaints get into, ask you
to do some type of corrective action. Manganese is in food with no apparent side
effects. And manganese is in water, naturally in small
concentrations. So, that’s not an issue. That’s what we have historically have thought. Another thing, which was an operating
assumption of the past, is that “Well if people saw that their water looked dirty
or was discolored, maybe they wouldn’t drink it,
so there couldn’t be any health effects.” And we found that that’s not the case either. So, there was a need to look at the health
effects of manganese, especially when the research was showing that–
that there were more and more health effects
with higher concentrations of manganese. It can be toxic in sufficiently high doses, and
produce neurological effects. And, especially infants, are most susceptible. And this is because infants haven’t developed
the capacity to excrete excess ingested
manganese. So, why we’re mentioning infants, is when you
see some of our guidelines coming up, we
highlight the infant population. We highlight daycares. Do we have anyone here representing a daycare
facility–a daycare public water supply? Probably not today, but we’ll be talking about
that. There are acute exposure health effects
associated with manganese and drinking water. Infants can have acute health effects at levels
greater than 0.30 mg/L And for this reason, US EPA issued a health
advisory, which is 0.30 mg/L And then, MassDEP Office of Research and
Standards Guidelines (ORSG), followed EPA, and also set the ORSG as 0.30 mg/L, and
another guideline health advisory at 1.0 mg/L. So there’s, there are reporting and monitoring
requirements, if it’s greater than 0.30 mg/L up
into 0.1 mg/L– and then if it’s greater than 1.0 mg/L–up into 1.0
mg/L. And if it’s greater than 1.0 mg/L, then
we’ll talk about that too. But in terms of the acute exposure health
effects, besides infants, having acute health
effects, if the levels are greater than 0.30 mg/L, which is why there’s a guidance here, the
general population can have acute health effects
at levels greater than 1.0 mg/L. And then there are chronic exposure health
effects. Adults, over a lifetime, may experience chronic
health effects with levels over 0.30 mg/L. So the MassDEP Office of Research and
Standards Guidelines set the ORSG based on
three target populations. Alright? There’s the general population and the
infant population. To start with, the general population, again for a
lifetime exposure, it’s recommended that the
level that’s in the drinking water is not exceeding 0.3 mg/L. And, for the general population, if your sample
results are showing manganese greater than 1.0
mg/L, and that it’s happening in Massachusetts, not as commonly, but it is happening, in some
public water supplies. It’s recommended the general population doesn’t
drink the water more than a ten day exposure. And for infants, less than one year of age, it’s
recommended that they are not exposed to
drinking water with more than 0.30 mg/L, any more than ten days. So basically less than ten days is the
recommendation for exposure. Some of the language that’s contained in the
public notice is a reference to infants ingesting
this water, and that, perhaps, alternative waters, bottled or
treated water be used for infants. And that’s
what it says here. But that’s language that’s in the standard public
notice that, if you had to issue a public notice,
that would be in there. In many cases it is. So how are the DEP health advisories set? It’s quite a detailed process. The health advisories are based on, first, the
adequate dietary manganese intake levels that
are known to be fine without adverse health effects. But then, as a precautionary measure, these
health advisory guidelines are set. And the general population is considered–is
asked to consider limiting it, their consumption
of drinking water, if the levels higher than the ORSG guideline health advisory, such as
greater than 0.30 mg/L or greater than 1.0 mg/L, and that infants, under the age of one, shouldn’t
be given water over the health advisory, over the ORSG. Alright? So that’s a brief discussion of the health effects. There is, there is a lot more information on the
MassDEP website: if you’re interested in seeing some of the
research studies, they do, there are studies
from all over the world, actually, regarding drinking water and manganese, and you’re
welcome to look at that. I’d like to review, just briefly, what’s–what’s
happened over the past year or so, with the
manganese program. Because it was only, just about a year ago, a
little over a year ago, that the first letters went
out It was actually, it was late in 2013; I think it was
October. All your public water supplies were notified; all
the public water supplies in Massachusetts
were notified that there was going to be some new requirements for monitoring reporting, for
manganese, and introducing this to you. And then in 2014, baseline finished water
sampling from all public water supplies so we know the starting point, where everybody
was starting. And, we’re going to, I’m going to talk about, in a
moment, what–what happened when those
baseline sample results showed that some public water supplies were over 0.30 mg/L or over 1.0 mg/L or over 0.5 in some cases, because that
changed, the monitoring requirements too. And the 2014-2016 sampling schedules have
been revised in some cases because of these
baseline results. The baseline results changed the monitoring
requirements and some of you, if you’re in that
situation, you have, or had, been sent some revised schedules for sampling. In 2014 most public water suppliers in
Massachusetts did submit baseline results. Because it’s a fairly new program, we sent out
forbearance letters, which allowed a thirty day
extension to the sampling requirement in 2014. And, as I said, most public water suppliers have
submitted these baseline sampling results. In 2015 MassDEP will move forward with what
we call a Compliance and Enforcement process for the Drinking Water Program, for the
Manganese Program in Drinking Water. This is not new, or different, for MassDEP. It’s
something that’s done across the board with all
MassDEP programs. And the type of notice that will be sent will
include something called a Notice of Non-
Compliance, something you probably don’t want to receive. But that’s what it’s called. Initially, it would be for failure to sample, failure to public notice, you know, you’ll be
hearing about public notice in about a minute, or failure to take a corrective action. And those requirements are going to be really
clear, clearly explained to you, because when, I should, I’ll explain briefly, and maybe our
regional person will also explain this too. When you submit sampling results to
MassDEP, and you trigger one of these health
advisories, or trigger the 0.05 mg/L aesthetic standard, that
there’s a process that goes into place. There’s a letter that’s sent by the regional office;
it says “You have exceeded this. This is what
you need to do.” All the requirements, the public notice, to
sample, to monitor, to do a corrective action
plan, it’s all in the letter. So it’s not as though you have to guess. But it’s nice that you’re here today, because, at
least you know what’s happening in advance. So you can prepare for it. You don’t even have to wait for the letter. You
could call the region and have a discussion
about it before the letter goes out. Starting in 2014, Baseline Finished Water
Monitoring Samples were required. And that’s finished water versus raw water. And we have had some confusion in that area. There have been some raw water samples
submitted to us from systems were treated for
other contaminants. So, you know, we want to see it. So, we really
want the finished water sample. If the monitoring results that you come up with
in your baseline data for 2014 are in future
sampling that you do, are greater than 0.3 mg/L, then these are the actions: First step is to take a confirmatory sample
within two weeks. And that’s for all public water supplies, but right
up front, everyone takes a confirmatory sample
within two weeks. And if the average is greater than 0.30 mg/L,
then there are a series of actions to take. Here’s an example of a public water supply: They exceeded 0.05 mg/L and they went on
quarterly monitoring. And during that, those– Before we even reach four quarters, in the
second quarter they exceed 0.3 mg/L. So, well they knew they needed to take a
confirmatory sample, and they did, and they still exceed 0.3 mg/L. So, what kind of monitoring they’re on? They’re
still on monitoring, quarterly monitoring. So you’re going to continue quarterly monitoring
and report it to MassDEP to go into the other
requirements, such as public notice, et cetera, et cetera. But you’re continuing quarterly monitoring in the
meantime. For all systems, at least you know that if the
average is over 0.3 mg/L, there are going to be
some actions. And the actions are going to vary whether you’re a TNC (Transient Non-
Community), NTNC (Non-Transient Non-
Community), we’re going to get to that now. First, community public water supplies, and the
other ones are coming up. All right, community public water supplies. Suceeding 0.3 mg/L, you’ve confirmed it, the
average, you’ve confirmed it. It’s over 0.3 mg/L. You’ve notified the regional office. And you’re going to get a letter from the regional
office that says “Okay, do public notice, do Tier
2 quarterly public notice.” This is consistent for all contaminant–drinking
water contaminants. It’s something you’ve heard
before. It’s not different. All Tier 2 public notice requirements are the
same, depending on–no matter what
contaminant it is. So it’s the standard process, public notice
process. There’s the actual notice you notify your public
with, or there’s an exception. If your public water supply has already issued in
your Consumer Confidence Report (CCR), in the previous year, language in it that talks
about the health effects and health– and the manganese, and that you’ve treated the
O–health advisory, the ORSG, if you’ve already issued that information to the
general population prior, in the prior year, then you don’t need to do a public notice again. Okay? Now, I’m assuming all of you are familiar with the
Consumer Confidence Reports (CCR)? You, every year you issue them to MassDEP. In addition, if a community public water supply
exceeds the 0.3 mg/L, you, in your current year, Consumer Confidence Report, there has to be a
notice, and the language of that notice, we have it all written out for you; we can give
you a template of what you put in there. So, it’s not–you don’t have to create the
language in it. It’s–we made–we have
templates, to make it easy for you. And that information is usually, I understand,
sent to you, in that letter that the region sends. There is a quarterly monitoring requirement which will continue if someone asks for a
different kind of system. But say in this case, “How long do you quarterly
monitor?” You continue quarterly monitoring until the level
is less than 0.2 mg/L. And, you’re asked to produce a corrective action
plan, a long-term corrective action plan. There are many different types of actions that
you can take: Source management, you know, taking the
source offline. It could be adjusting treatment that’s already in
your system for the benefit of removing
manganese. Some of the current treatment that systems are
using are finding if they adjust it a little, it’s
actually lowering the manganese levels. So, there are many different ways you can have
a corrective action, including treatment. And so, you’re asked to produce a plan, to
submit it to the regional office for review. And if you’re a community public water system,
and once you’ve done the initial public notices, and the public notices go to the chief elected
officials and they go to the, you know, general
population, and all that, you can get a waiver, you can apply for a waiver
to do future public notice, but there is going to
be a fairly new waiver process. If your manganese exceeds 0.3 mg/L, it’s a
different language that you put in the Consumer
Confidence Report. And this is the text that you’ll be provided in the
information MassDEP gives you, if this text
needs to be in there, that drinking water may naturally have
manganese, et cetera, et cetera. But this is what’s been found in our public water
supply water. So what if you’re a non-transient non-community
public water supply, such as a school? And if your level’s over 0.3 mg/L? It’s the, there are the same Tier 2 Public Notice
requirements. Posting of the public notice for your consumers,
posting it up where it’s visible. A letter to the workers, and that’s depending on
a case-by-case basis that that may be needed. You know, to notify, because the workers are
drinking the water. Quarterly monitoring And a corrective action plan. And now, there are two types of transient non-
community public water supply systems. There are those with daycares, and without
daycares, such as restaurants, gas stations,
campgrounds, First I want to talk about transient with
daycares. If the manganese in the drinking water is 0.3
mg/L or more, the Tier 2 Public Notice. Same thing. Posting of the public notice for the consumers, a letter to the workers, depending on a case-by-
case basis, quarterly monitoring, and a
corrective action plan, which is very similar to the previous one. Now for transient systems without daycares,
say restaurants, gas stations, or campgrounds,
or where the people are transient. Just quarterly monitoring is required. Until the level is greater than 0.3 mg/L up to
when the level is 1.0 mg/L. If the level is greater than 1.0 mg/L, in transient
non-community without daycares, and again, we’re mentioning daycares because
of the infant concern. Okay, that’s one of the most susceptible
populations, so they’re in a different category. But these are transient non-communities without
daycares, such as restaurants, gas stations,
and campgrounds. This is a Tier 2 Public Notice, posting of the public notice for consumers, letters to workers on a case-by-case basis, and
quarterly monitoring. So, to review, you’ve done your monitoring for
manganese and you look at your results. And it’s 0.02 mg/L, under 0.05 mg/L. Does anything have to be done? Well at that
point, you want to contact your regional office. Because it’s under the 0.05 mg/L Secondary
Maximum Contaminant Level (SMCL). They will tell you what the frequency of
monitoring will be required. And if it’s 0.05 mg/L or more, is there additional
action? As of 2014, yeah. See? Before there wasn’t. But as of 2014 there is. And that’s the quarterly monitoring, for four consecutive quarters, until you average less than 0.2 mg/L. If the level exceeded 0.30 mg/L is there
additional action? Yes, and what that action is now, it’s going to
depend on what kind of system you are. Community Non-Community Non-Transient Non-Community Transient Non-Community If you have any questions, call us. Let us know. We’ll help you out. And if the level is greater than 1.0 mg/L, there
are, the requirements can vary. And yes. So for more information, the first contact for you
would be your regional contact person. My contact information and Margaret Finn, who
also works in Boston, her information is also
here. Thank you.

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