FRWA Comments on Proposed PFAS National Primary Drinking Water Regulation to EPA
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RE: Comments on PFAS National Primary Drinking Water Regulation
As a representative of Florida’s drinking water systems, the Florida Rural Water Association is providing feedback to EPA regarding PFAS regulation. We are proud that Florida is a national leader in protecting public health by regulating contaminants in drinking water. However, the financial impact of addressing contaminants on water utilities also poses a threat to public health. This is especially the case for our small, rural system members.
In particular, the proposed regulations of PFAS places an undue burden on the resources of utilities that are impacted. Collecting the PFAS water sample requires extensive training or hiring a contractor. Sample analysis is expensive, especially since there are few labs within the state certified to perform EPA Methods 537 or 537.1. Those systems found to have PFAS levels exceeding the MCL will spend large amounts on engineering services and remediation in addition to the social consequences of issuing a Do Not Drink, public notice or messaging on “forever chemicals” in the water order to their customers. The consequences of the regulation will cause water rates to rise, which will often harm our most vulnerable populations.
Based on the experiences of Florida small systems, EPA has significantly underestimated the costs of monitoring and remediation. Engineering analyses did not recommend POU treatment systems as a remediation option, even for NTNCs and TNCs. Monitoring costs for very small systems with any detectable level of PFOA or PFOS will average close to $2000 per sample (counting all costs) (EPA estimates $900). GAC/Resin treatment costs for very small systems were estimated by EPA to be $25,000. FRWA engineers estimate that very small systems are realizing a total project remediation cost around $125,000, on average. For community systems that may have to construct treatment facilities to house and support the necessary filters and equipment, costs can range into the millions. An example, a Florida system with a max daily demand of 2 MGD is incurring a cost of $3 million just for GAC filters. In addition, supply chain issues, skyrocketing construction and transportation costs, and unknown media (lack of availability of disposal facilities) disposal fees have been increasing the actual cost of remediation far exceeding preliminary estimates. In some situations, the GAC is only lasting 6 months with much higher Operation and Maintenance, disposal and logistics fee’s to truck to Texas for approved disposal. more
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UTILITY CUSTOMER RELATIONS |
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As reported in last week's eNews, FRWA is starting a new feature in eNews with topics you can use as proactive messaging to your customers on timely issues and requirements that may affect their water service, rates, water availability etc. You are welcomed to copy the information provided and use the graphics for inclusion on your billing information, on your website, or where ever you choose to use it. We have also listed links to some flyers in Word that you can customize for your system by just inserting your information.
Please contact FRWA at frwa@frwa.net with your suggestions/comments on information that you would like covered.
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A sanitary sewer overflow (SSO) is any overflow, spill, release, discharge or diversion of untreated or partially treated wastewater from a sanitary sewer system. A sanitary sewer overflow can spill domestic wastewater out of manholes and onto streets and into storm water systems, surface water bodies or into toilets, sinks and drains before it can reach a treatment facility.
FOG (fats, oil and grease) is the leading cause of sanitary sewer overflows, and more of it comes from houses than you might think. Some of the things that you can do to help us keep our system from having an sanitary system overflow are: never pour fat, oils, or grease down the drain, don't use the toilet as a trash can, don't flush wipes, put table scraps in the trash can, etc.
Links to information in Word that you can personalize for your use:
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With the start of the 2023 Hurricane Season, the Florida Rural Water Association is keeping a close eye on the Tropics. We have been on the watch as a tropical depression formed in the Gulf. Thankfully, as of this issue, Tropical Depression Two is moving slowly southward with little change in strength.
The Florida Rural Water Association in partnership with Water Tracker and FlaWARN are always here to help systems when an emergency strikes. If you haven't updated your information in Water Tracker lately, click here and do so today so that you will not be caught off guard if disaster strikes. Click on the graphic below to hear about Evelyn with Hardee County Utilities experience with Water Tracker.
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With the increasing crisis in the utility workforce, it is interesting to get some background into the issues that systems are facing. |
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FACTS AND FIGURES OF THE FL UTILITY INDUSTRY
The publication on the right was created by the Florida Public Service Commission as a reference manual for anyone needing quick information about the utility industry in Florida. The facts have been gathered from in-house materials, outside publications, and websites. Efforts were made to accurately reference the source of the information used. Though most of the data refers specifically to Florida, some data from other states and national averages are included for comparison purposes.
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APWA Water Workforce Research
Click on the graphic on the left to explore facts about water workforce demographics, job opportunities and qualities, and industry needs. Stats regarding every aspect of the industry including:
- Utility share of total water workforce employment
- Diversity in the workplace
- Salary ranges
- Educational requirements
- On the job training
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The 2022 CCR Report Template is posted on our website. To access the information, click here. Please contact the water circuit rider in your area if you need additional assistance by calling FRWA at 850.668.2746.
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NATIONAL NEWS
AG Rosenblum Files Lawsuit Against Companies For PFAS Contamination From Firefighting Foam Attorney General Ellen Rosenblum has initiated legal action against 21 companies, including DuPont and 3M, alleging their responsibility for PFAS contamination in Oregon caused by aqueous film-forming foam (AFFF) and its components. more
Maryland Files Lawsuits Against Chemical Manufacturers for PFAS Contamination Maryland Attorney General Anthony G. Brown has filed two lawsuits for the State of Maryland, the Maryland Department of Environment, the Maryland Department of Natural Resources, and the Maryland Department of Health. more
Supreme Court Rules Against U.S. EPA Authority To Curb Pollution Of Source Water In a ruling about the U.S. EPA’s authority to govern pollution in national wetlands, the Supreme Court limited the agency’s ability to enforce Clean Water Act protections. more
US Air Force pays $9M for water treatment facility in Fountain due to PFAS - YouTube After the United States Air Force paid $9M for a water treatment plant in Fountain due to PFAS, CBS News Colorado investigator Kati Weis got an exclusive look inside the facility. more
PFAS contamination may be more widespread than thought Background levels of toxic PFAS “forever chemicals” in the ground and air may be much higher than previously thought, federal testing of spatially random soil samples from across New Hampshire suggests. more
AI Helps Wastewater Utilities Prepare For Extreme Weather As extreme weather events increase around the globe, cities are looking to create more resilient infrastructure to withstand and protect against floods, hurricanes, wildfires and other high-risk events. more
ASDWA Releases Cost of State Transactions Study for Proposed PFAS Regulation ASDWA recently finished development of its PFAS CoSTS (PCoSTS) model, an adaptation of the Cost of State Transactions Study (CoSTS) developed for the Revisions to the Lead and Copper Rule (LCRR). PCoSTS estimates the additional burden for primacy agencies associated with the recent proposed PFAS regulation. more
ASDWA Submits FY24 Senate Appropriations Testimony On Wednesday, May 24, ASDWA submitted FY24 appropriations testimony (below) to the Senate Appropriations Subcommittee on Interior, Environment, & Related Agencies for EPA funding. ASDWA recommended that all Congressionally Directed Spending (CDS) be funded without cutting funding for the State Revolving Loan Fund (SRF) capitalization grants. more
STATE NEWS
Suwannee County awarded $9.5 million for wastewater treatment plant - WCJB The state is awarding $15 million to five rural communities for infrastructure. One of the recipients is Suwannee County. more
Governor Ron DeSantis Awards More Than $15 Million to Five Rural Communities Through the Rural Infrastructure Fund Governor Ron DeSantis announced more than $15 million in awards to five rural communities through the Rural Infrastructure Fund (RIF) program to support community economic development projects that will strengthen public infrastructure and expand job opportunities for residents. more
DeSantis signs legislation to protect water resources, support conservation | The Ponte Gov. Ron DeSantis has signed House Bill 1379, which enhances protections for the Indian River Lagoon (IRL), expands the existing wastewater grant program, strengthens Basin Management Action Plans (BMAPs), improves local government long-term comprehensive planning and creates dedicated funding for the state’s land conservation efforts. more
Zephyrhills' growth is the Florida story | Editorial - Tampa Bay Times People think the Florida story is told through its bustling metros. Well, sure, but what’s happening in Zephyrhills is a snapshot of Florida, too, as even smaller communities look to balance growth, resources and their quality of life. more
St. Johns County to celebrate $6.76 million Hastings wastewater treatment plant improvement project | Action News Jax St. Johns County will hold a ribbon-cutting ceremony to celebrate the completion of the $6.76 million improvement project for the Hastings wastewater treatment plant located at 900 N. Main St. more
Based current conditions, the arrival of rainy season is something to celebrate | Naples Daily News Dust off the umbrella, or find a good waterproof hat. Based on the weather forecast for the remainder of this week, the transition to the rainy season in Southwest Florida is underway. more
Tampa Bay gets EPA grant money to help environment | WMNF Disadvantaged areas in the Tampa Bay area are set to receive money for environmental improvements because of a series of measures passed during the Biden administration. more
Miami-Dade County taking critical steps to stop human waste from seeping into waterways | Local 10 Last week, Local 10 News reported on fish in South Florida waters that are swimming around in a cocktail of drugs, a direct result of human waste leaching into our waterways. more
Gov. DeSantis puts $1M toward Macclenny’s deteriorating water treatment plant at Northeast Florida State Hospital | News4Jax Gov. Ron DeSantis on Wednesday announced more than $15 million in awards to five rural communities through the Rural Infrastructure Fund (RIF) program to support community economic development projects aimed at strengthening public infrastructure and expanding job opportunities for residents. more
Back-to-back hurricanes are likely to happen more often, study finds | KGBT What used to be a rare one-two punch of consecutive hurricanes hitting about the same place in the United States weeks apart seems to be happening more often, and a new study says climate change will make back-to-back storms more frequent and nastier in the future. more
Sanford city leaders prepare for hurricane season | WESH Heavy rain from an area of low pressure in the Gulf could mean flooding for some vulnerable parts of Sanford hit hard last hurricane season. more
It's time to prepare for the 2023 Atlantic hurricane season | Messenger-Inquirer It’s time for residents along the southeastern U.S. coastline to get plans in place as the 2023 Atlantic hurricane season gets underway on Thursday. more
Florida county drills new super wells to ensure future water supply - YouTube A shortage in the drinking water supply is a growing concern in Polk County as the county sees a huge population boom. As water becomes increasingly scarce, drilling projects are underway to ensure a sustainable water supply for the region for the next two decades. more
Haines City ordered by FDEP to complete wastewater improvement projects to prevent future spills | ABC Action News June 30 is the deadline the Florida Department of Environmental Protection has given Haines City to have construction completed for the first of its newest RIB, or rapid infiltration basins. more
Deltona fights to dismiss lawsuit filed by residents who blame city for Hurricane Ian flooding | Florida Politics The city of Deltona is fighting back after a group of homeowners filed suit, blaming the government for unleashing Hurricane Ian’s floodwaters in their direction to protect the rest of the community. more
Hillsborough County offers free program to hook some residents up to city water | WFLA Hillsborough County is taking steps to improve water quality for University Area residents by converting properties from septic to sewer. more
How hurricane warnings will be different this year | WJCT As the 2023 hurricane season starts, memories are still fresh of Hurricane Ian causing billions of dollars in damage and pushing water across Southwest Florida barrier islands. more
Fla. city eyes development ban over water concerns The “City of Pure Water” isn’t sure how much more it can promise to future development. more
Opinion: Septic to sewer benefits outweigh the costs | Citrus County Chronicle Since the 1990s, Citrus Countians have made the protection and restoration of the county’s springs, lakes and rivers their mission. Key to the accomplishment of their mission is the reduction of nitrate pollutants. more
Ocala residents to receive water quality report notice with utility bill | WCJB Officials say the notice will let consumers know they have multiple ways to view a water quality report. more
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This Week in Water History |
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Although the quality of the photo on the left is not of the best quality, it is interesting to see what a horse drinking fountain looked like in 1915. This photo was taken from an old newspaper where the article first appeared.
June 1, 1915: Municipal Journal article. Watering Horses in Cities. “The years 1914 and 1915 saw an epidemic of glanders in several sections of the Atlantic coast states, and many cities closed their existing horse drinking fountains, as it was believed that the disease was spread by the common use of bowls or troughs. Instead, drivers were asked, or required by ordinance, to carry with each horsedrawn vehicle a pail for watering horses. It remained to provide facilities for filling these pails, and this was done in different ways.
In Boston, New Bedford and some other cities, fountains of the horse bowl type known as the H. F. Jenks pattern were adapted as follows: The bowls were removed and replaced with new castings containing three or more self-closing faucets, designed with a special view to being non-freezable. This appears to have given entire satisfaction.
Commentary: This article is interesting on at least two levels. Transportation of goods and people by horse was still prevalent in 1915 in cities. The automobile was making definite inroads but there were still millions of horses in cities across the U.S. (21.5 million in one estimate of all domestic horses in 1915). In 1908, Henry Ford started production of the Model T automobile that would revolutionize transportation in the U.S.
Glanders is an infectious disease in horses and other animals that is caused by the bacterium Burkhoderia mallei. The disease can result in coughing, fever and the release of an infectious nasal discharge. The serious form of the disease can result in death of the animal. The bacterium can infect humans. In 1915 with the heightened awareness of human diseases passed by intimate contact with contaminated items, it is only reasonable to protect horses from the same contamination route. If banning the common cup for humans makes sense, it sure makes sense for our equine friends.
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2970 Wellington Circle | Tallahassee FL 32309 | 850.668.2746 | Contact Us
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