Ubiquitous Sources of Bis2ethylhexylphthalate Its in our Foods and Sewers

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Ubiquitous Sources of Bis(2-ethylhexyl)phthalate
Its in our Foods and Sewers

• Bis(2-ethylhexyl)phthalate, or DEHP, is an EPA
  Priority Pollutant that is frequently detected in
  sewer trunk lines and treatment plants.
• The recently promulgated California Toxics Rule
  set very stringent limits, 5.9 µg/L and 1.8 µg/L.
• Compliance with new limits will be very
  difficult DEHP sources are everywhere and
  uncontrollable.
• POTWs will face mandatory minimum fines and other
  requirements per the Migden Bill, and might
  ultimately have to install additional treatment.

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Should my POTW be concerned about this?Will
DEHP be a big problem to control or treat?Yes,
and Yes.
Ubiquitous Sources of Bis(2-ethylhexyl)phthalate
Its in our Foods and Sewers
C24H38O4 CAS 117-81-7
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Bis(2-ethylhexyl)phthalate Lets review so
far

• a) RWQCB will soon revise your NPDES permit to
  include  (among other things) numerical limits
  for DEHP
• b) historical data probably indicates little
  chance of  meeting the DEHP limits
• c) the Migden Bill will require development of
  Pollution  Minimization Plans PMPs in response
  to recurring  discharge violations
• d) sources of DEHP to your POTW are
  non-industrial and  are not controllable sources
• e) potentially facing mandatory fines, and
  development of  PMPs that have essentially zero
  chance of success.

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• Furthermore,
• The RWQCB has no discretion to waive or ignore
  violations of the NPDES permit whether the
  sources are controllable or not.

• And if you cant control the sources,
       youll have to treat them
  the approved
  treatment technology for DEHP is Granular
  Activated Carbon.
• Hmm looks grim.

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Bis(2-ethylhexyl)phthalate What can we do about
it? Let's learn a little more about
DEHP

• 1) physical and chemical properties,
• 2) uses of DEHP and sources to the sewer,
• 3) interferences with collection and analysis
  of DEHP,   and difficulty collecting
  representative samples,
• 4) doing the math with your analysis results
     interpreting the data.

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Bis(2-ethylhexyl)phthalate
1) physical and chemical properties

• insoluble in water,
• easily associates with fats, oils and grease,
• soluble in most organic solvents,
• strongly adsorbs to sediments,
• lighter than water, clear,
• has a half-life in water of three (3) weeks,

• DEHP is a semi-volatile organic compound,
• leaches and volatizes from plastic in minute
  quantities throughout the life of the product,
• can be liberated from plastic more quickly at
  higher temperatures or acidic pH levels.

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Bis(2-ethylhexyl)phthalate
2) uses and sources to the sewer
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Bis(2-ethylhexyl)phthalate
2) uses and sources to the sewer

• drinking water bottles,
• drinking cups,
• shower curtains,
• clothes, shoes,
• dishwashing machines,
• clothes washers,
• bathroom fixtures,
• kitchen appliances,
• vinyl flooring, paint,
• furniture, toys,
• automotive interiors,
• electrical wire insulation,

• food containers, plastic wrap,
• various rubber plastic products,
• sewer drains and water supply lines in homes,
• public sewer mains,
• water distribution lines,
• trenchless sewer rehabilitation (pipe
  bursting, lining),
• manhole rehabilitation, linings,
• wastewater sampling equipment,

• analytical equipment,
• tubing, gloves,
• wastewater treat-ment plants, (weirs, tanks,
  vessels, pipes),
• inks, pesticides, cosmetics, vacuum pump oil,
• test media for HEPA filters and protective face
  masks,
• kidney dialysis equipment,
• blood storage bags,
• etc...

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Bis(2-ethylhexyl)phthalate
2) uses and sources to the sewer

• Industrial uses of the chemical DEHP are very
  few, essentially limited to only the manufacture
  of rubber and plastic resins.
• There are no DEHP chemical manufacturing
  facilities in California.
• Plastic formers and molders do not discharge DEHP
  in treatable quantities.

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Bis(2-ethylhexyl)phthalate
3) interferences with collection and analysis

• Collecting representative samples for DEHP in
  wastewater is difficult, and so might call in
  question past and future analysis results.
• The Sampling Location, the Collection Method and
  Equipment are all potential sources of sample
  contamination.
• Many other factors interfere with collecting
  representative samples...

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End view of a sewer main
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Bis(2-ethylhexyl)phthalate
3) interferences with collection and analysis

• insoluble in water, soluble in fats, OG, and
  strongly adsorbs to sediments,
• low microgram/Liter (µg/L) range, at or near the
  MDL,
• plastic suction line generally pulls wastewater
  samples from well below surface of the
  wastestream,
• turbulence and sewer lines might affect
  homogeneity,
• PVC or PVC lined components upstream of sample
  point,

• composite sampling vs. grab sampling,
• 24-hour composite sampling is usually conducted
  with vinyl plastic suction tubing (40 DEHP),
• background water concentrations.

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Bis(2-ethylhexyl)phthalate
3) interferences with collection and analysis

• Documentation - plan ahead, could be a big asset
                        when RWQCB reviews your
  data
• Can you demonstrate historic data was not
  collected with vinyl plastic tubing?
• Perhaps even more useful, can you show that it
  was ?
• Can you demonstrate that samples are/arent
  representative (sampled from PVC stilling well,
  sample bottle was plastic, sewer pipe was PVC)
  ?

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Bis(2-ethylhexyl)phthalate
4) doing the math interpreting the data

• Laboratory uncertainty, contamination, sampling
  conditions, will affect your ability to collect
  representative samples.
• It might not be possible to produce
  representative analysis results despite your best
  efforts.
• If you start "doing the math" with bad data,
  you will get meaningless results - or
  worse,    misleading or erroneous results.

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Bis(2-ethylhexyl)phthalate
4) doing the math interpreting the data

• Apply your knowledge of sources and uses (use
  common sense).
• There is every reason to believe that DEHP will
  continue to be consistently discharged from
  residential sources.
• You should be surprised if you don't find it.
• It's in our foods, our houses, our water, our air
  -            and it's in our sewers.

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Bis(2-ethylhexyl)phthalate Will this
information help guarantee that I
wont have a DEHP violation?

• Nope. No it wont.
• Not at all.
• But you cant ignore the dismal prospect of
  incurring violations, fines, development of PMPs,
  escalating enforcement by the RWQCB, and
  ultimately attempting to treat DEHP at the sewage
  treatment.

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So, how can you guarantee that you wont have a
DEHP violation?
Simple,

• Option 1 Avoid having the limit in the first
  place.
• Option 2 Have the limit deemed invalid due to
  inadequate technical and scientific
  basis.

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Bis(2-ethylhexyl)phthalate Option 1 Avoid
having the limit in the first place

• Convince the RWQCB that, "there is no reasonable
  potential to have it in the treated effluent."
• develop data that demonstrates there is no
  significant levels of DEHP in the raw influent
  and/or treated effluent.
• Negotiate with your NPDES permit writer and RWQCB
  before your next permit is adopted.

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Bis(2-ethylhexyl)phthalate Option 1 Avoid
having the limit in the first place
Why is it so important to avoid having a limit?
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Bis(2-ethylhexyl)phthalate Option 2 Have
the limit deemed invalid - throw it out

• There are two ways to approach this
• a) Convince the State to develop a Site-specific
  Objective to supercede the federal CTR standards.
• b) Convince the US-EPA to revise the current DEHP
  standards in light of worldwide scientific
  consensus the 1982 rodent studies are not
  valid.
• Both will require supporting data, and a lot of
  participation from your trade organizations,
  RWQCBs, fellow POTWs and the EPA.

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Bis(2-ethylhexyl)phthalate The Good News
DEHP less toxic than previously thought

• Since 1982, national and international agencies
  worldwide have determined that DEHP is neither a
  human carcinogen nor an endocrine disrupter
• World Health Organization
• Commission of the European Communities
• International Agency for Research on Cancer
• Health Canada
• American Council on Science and Health
• former US Surgeon General Dr. C. Everett Koop
• EPA Integrated Risk Information System
• EPA Office of Health and Environmental Assessment
• other EPA scientists

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Bis(2-ethylhexyl)phthalate More Good News

• The current DEHP standards are based on an
  uncertainty factor of one-million (10 6).
• This is the largest uncertainty factor that EPA
  is allowed to use, which is not an uncommon
  practice for probable human carcinogens.
• If the US-EPA could revise the uncertainty factor
  (from 1,000,000 to 100,000 for example) then
  the DEHP standards would be 10-fold less
  stringent.

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Bis(2-ethylhexyl)phthalate The Bad News

• There is no process or procedure for challenging
  the Scientific and Technical Basis of numerical
  limits other than suing in a court of law.
• A State Site-specific objective for DEHP would
  replace the Federal limit even if the numerical
  value became less stringent, but the process
  takes several years, is very expensive, and the
  State has no plans or intentions to do so at this
  time.

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Bis(2-ethylhexyl)phthalate Be part of the
solution for your POTW and community

• Proposing to sue the US-EPA will not make you a
  popular person, so this might seem like a
  non-starter.
• However, options are limited. A discharge limit
  without a sound technical basis has many negative
  impacts on the community and the environment
• increased use of alternative more toxic
  pollutants,
• increased risk to public health and environment,
• liability and exposure to possible future law
  suits,
• economic waste,
• obligation to address issues that affect us and
  our sewer customers.

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Bis(2-ethylhexyl)phthalate Be part of the
solution for your POTW and community

• Consider approaching this issue together with
  other affected POTWs and stake holders.
• Utilize your trade associations and peer groups
  to gather consensus and develop the supporting
  data we will need.
• Be proactive. Prepare to participate with the
  State and/or EPA to revise the DEHP limit using
  the best available science to-date.
• Better government and a safer environment
  requires our participation.

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• This presentation, speech, and a whole lot of my
  reference materials are available on-line.
• These materials can be accessed for free for
  CWEA IHW Conference attendees.
  http//www.HostingMojo.com/Shawnp
• I thank you for the opportunity to speak here
  with you today.
• Shawn Perumean,
• CUCAMONGA COUNTY WATER DISTRICT