A discussion with the U.S. EPA’s Office of Water Deputy Assistant Administrator Bruno Pigott.

0:03 It would be really great to see some Trend analysis, some dashboard, you know, some Community, if you could drill into a local community, you could see results. I mean, so much of that information you have at your, in your, you know, databases somewhere. It would be, wonderful to see some analytics done on that stuff. Well, and we will do analytics on it. The data will be used to support our Regulatory determination, that's the whole reason for you. See, Mr. Is, let's look at the data and then make a determination about whether we should regulate these chemicals. And so we'll be using that data will be sifting through.

0:44 It will be analyzing it and so that we can make a determination about whether or not, we should be regulating that remember, their unregulated currently. Welcome to the environmental transformation podcast where we talk with industry leaders, climate Champions and sustainability professionals, who are making an impact and their businesses. Today, each leader solving complex challenges and provide Solutions within the respective areas of expertise. And here's our host, Sean Grady. Hello ET Nation.

1:26 I'm excited to announce that. I've updated my website. That provides listeners more access to episode content and information about the podcast. Please take a moment and visit the website and sign up for email notifications and blog postings also check out our sponsors page to see who supports the show. We can't thank these industry leaders enough. Finally, I would really appreciate if you would take a moment and post a review and rate the podcast episodes, either from my website or from within your podcast app, This helps the podcast get more exposure on Apple podcast and other podcast networks. Also please send me comments and recommendations on topics that you want to hear about. I hope you enjoy the new website so check it out at www.shawnacoronado.com.

2:19 Welcome to the environmental transformation podcast. I'm your host, Sean gradient, today's guest is a Bruno Piggott. Bruno is the Deputy assistant administrator for the US EPA and of the office of water. And the office of Water Works to ensure that drinking water is safe. The wife's water safely returned to the environment and service waters are properly managed and protected, you know, before Bruno join the EPA, he held multiple multiple roles at the Indiana Department of Environmental Management. Most Serving as the commissioner of the agency and the chief of staff and the assistant, commissioner of the office of water quality. He started his service career as a chief of the state revolving Loan Fund program in Indiana and Bruno holds a bachelor's degree in political Theory and economics from James Madison College, at Michigan State University, and a master's degree in the in public environmental public affairs from the Indiana University of environmental public affairs.

3:15 So, Bruno, welcome back to the show. The last time. Yeah. The last time we had you on the show was almost two and a half years ago, it's hard to believe. It's been that long. I know you were you were navigating the pandemic, you are navigating the idem through the pandemic transitioning to working from home and man, that was a big challenge for you at the time. If I recall. Yeah, as it was for everybody, you know, it was, it was definitely a big challenge for the work. Place and I'm glad we're through it. And people are getting back to some semblance, although, you know, our workplace is changed as a result.

4:00 I think. Isn't that right? Yeah, a lot more remote work than ever before and workplaces are adapting. How's that happening? I mean, how's that? Look at the EPA level there in Washington, d.c., well, it's the same as it is. In many other places. There's an ability. He of a lot of folks to work from home. And for some people it's really especially people in the labs and research roles that they're going to be in the office. But for a whole host of other people, the workplace has become a much more flexible workplace. So people are in and out 3 days a week, let's just say that they come into the office and as a time where you're doing a lot of in-person meetings, which actually, I think is a really good thing.

4:48 So It's been it's been a great transition to this new kind of format and I think we're going to see a more flexible workplace at least that's what we're doing right now. Yeah we see the same thing here in the Private Industry and and you know I think we're all being aware of the challenges of what Kobe has brought to our work life. And I think most companies are adapting quite well with this kind of flexible work schedule. It's great. I'm I think it's good. Think we're realizing we can be sustainable working from home more sustainable and, you know, still being productive. So it's a good thing.

5:28 You know, the one thing that I think we do miss that that it's worth commenting on. You know, this conversation we're having right now. It's a, it's kind of a free-flowing conversation when you're on a team, typical teams meeting in a in the workplace. I think that there's less opportunity to have a free-flowing Conversation where you might be able to talk about issues that are kind of tangential to the one you just met about but but really you get a lot of work done. So the in-person component I think is critical still to being collaborative and working together, but I think we're figuring out what the balance is between the in-person collaboration and then the remote work stuff and we'll settle on something going forward but I'm the smartest guy.

6:19 I didn't know exactly how that's going to shake out. Well, that's good, that's good. So, all right. Well, let's dive in. Tell us, you know, what is, you know, what, what, what's your new role like? You know, tell us a little bit about the difference between being the commissioner of an agency a state agency and now you're the, you know, the deputy assistant administrator of office water. Yeah. So I'm Deputy assistant administrator in the office of water. And what it means is, I'm part of a senior staff at u.s. CPA. Work with the assistant administrator, who's Senate confirmed appointee to the role and I work on the wide range of issues that we're facing at EPA in the office of water.

7:06 What what's different or one thing that's different is I work at an agency. Now that is about 16 times as big as the agency. I worked in previously right here are Ten Regional Offices Across the Nation. Then, there are 10 offices of research and development Across the Nation. In addition to that and then there are 10 Laboratories around the nation as well. So it's a pretty it's a pretty big organization. You got about 16,000 people who work here and the role that I have in this agency which is Is big and has a nationwide impact, is in the area of putting together, kind of our regulations, and our guidance is that then are implemented by States and our Regional Offices. So in the, in the job that I had working at the Department of Environmental Management, we really implemented, the federal regulations that is We put them in place in writing through our rulemaking process at the state, but then we carried them out and writing permits, and doing all of the work of putting in place enforcement and inspection and permitting. And here in Washington, d.c.

8:40 were more about setting, the guardrails writing the rules and then providing the assistance to States. And entities around the country. Yeah, that's a different perspective of understanding. You know, where you play into the whole mix of, you know, governance or implementing, you know, pretty PA protection or Environmental Protection. So, that's got to be a challenge, just learning the differences. I'm sure, you know, what is the mission of the office of water manager of the office of water at the EPA right now? Well, it fits within the agency's larger Mission, which is Is It ultimately to protect human health and the environment we do that in a number of ways?

9:24 We're in our focus is, of course water quality. We do it to, we work to ensure that we have clean water, that the efforts we make reduce the environmental risks based on the best available scientific information that we put in place and implement or interpret the federal laws that are designed To protect human health and the environment and that we administer them and enforce them fairly effectively and as Congress intended. And environmental stewardship is integral to policies concerning human health, economic growth energy, Transportation, all of those areas.

10:11 And to do that, we develop and enforce regulations. We give grants to States. And in entities, we study environmental issues and I was referring to our office of research and development. They really are our focus on studying environmental issues and we also engage in Partnerships Partnerships with a wide variety of folks. From the private sector to folks in not-for-profit environmental organizations and Industry. We also do some teaching of environmental Consciousness around the Country, and then we publish information. Those are the big, the big things that we do to carry out the mission in the office of the spot. So that's a lot that mean that's a lot of responsibility. So what are some of the big agenda items that the office of water has at the EPA?

11:05 Well, we have a number of big items that we've been working on and I'll talk about a number of them, one of the big ones that we've talked about. Well, So first of all, it pays to talk a little bit about where we've come from. We're this past year, we've celebrated the 50th anniversary of the Clean Water Act and during that 50-year period between the Inception of the Clean Water Act. And today we've done a lot to improve the environment we put in place, secondary and tertiary treatment techniques that have been employed by municipalities Combined sewer discharges have been addressed through Technologies and tunnel.

11:54 Water reuse has become a common strategy for meeting water. Needs in the west. Green infrastructure has become an integral part of treatment and so today, 50 years in water and wastewater so much more advanced than at the beginning of the Clean Water Act, we've had so many laudable Clean Water Act successes over the past 50 years. And I've been lucky to be able to travel around the nation and and see them in action. And so the question is, what do we doing moving forward and there are several big agenda items. We've been working on most recently. We've been working on P fasts and I'll be the first to acknowledge that states really led the charge when it comes to pfos, but I'm here today to report that EPA is doing more than this.

12:49 Been done at the federal level to address these forever. Chemicals, just last month, we took a key step to protecting drinking water from pfos with a proposal of a national drinking water rule for pifo and pfos. And as the lead Federal agency responsible for ensuring Safe, Drinking Water for Americans. We're leveraging most recent science and building on existing state efforts to limit pfos to provide a nationwide. Wide Health protective level for these specific pfos and drinking water. And and so, what we're doing is proposing to establish legally. Defensible levels for six P, Phi is known to occur in drinking water and the proposal we put out there it will regulate p foa and pfos pfoa and pfos is individual contaminants and then will regulate for others.

13:47 PFA. For other p. P Foss, pfn a PF H, XS p, f BS, and Gen-X chemicals as a mixture and if finalized its new rule will result in less pfos and drinking water across the u.s. and and we believe prevent thousands of deaths and tens of thousands of illnesses. We're in a process right now of putting the rule out and getting public feedback. So, We're really interested in the folks who watch your podcast to take a look at that rule, and provide comments to better, inform our rule, which we hope to conclude by just the end of this year.

14:32 And we're not just setting, new standards were helping communities meet these challenges. And you remember, Sean, in the past when new requirements were added to everybody's plates, they were rarely funded. In the words, Unfunded mandates were always on the lips of every state and municipality. But today, thanks to President Biden's leadership and the bipartisan action and Congress. The bipartisan infrastructure law provides an unprecedented. Nine billion dollars to invest in drinking water systems impacted by pfos and other emerging contaminants.

15:15 We're also working. We've got a whole pfos. A road map if you will in so that drinking water standards. Just one piece of it, we're working on pfos and bio. Bio solids, we're putting together an npdes permitting memo that we've actually sent out to a regions about the npdes permitting program and what can be done to address ppas discharges and so people has been a real Big issue. Another big one is eleven copper. We're working hard to improve the lead and copper rule revisions that were established in the last Administration.

16:00 The lead and copper rule improvements rulemaking. Aims to faster and further protect citizens from lead and drinking water and simplify. What is admittedly by all accounts? A confusing trigger level Action, level notification, requirement system. That's currently in place. And then we're also working to ensure funding is available to states that need it to address this issue. We just issued a new revised formula for Distributing money. Through the srf program designed to ensure that the states that really need those dollars. Can get them. So those are some of the regulatory things we've been working on.

16:45 Of course, I can talk about The billions of dollars that we've been Distributing through the state revolving fund program to ensure that we make progress updating our water and wastewater infrastructure. Fully half of those dollars are available as grants and fully forgivable loans. In as you mentioned at the beginning, Sean I worked in the srf program when I first worked at the Department of Environmental Management and During that time period, I can remember looking at the needs, we had over twenty year period and realizing we just didn't have enough money to meet.

17:27 Those needs. Never in the history of my 25 years working in the environmental Arena. Have we had this much money devoted to making water and wastewater infrastructure improvements as we have today. So that's that's the good news we, that's encouraging. Yeah, that's really good. That's really good. I mean it's a whole host of other things. I could go on and on about, oh yeah. Well if I don't stop you, I don't think I'll get a word in edgewise. So let me let me dive in here because you cover a lot of really great things here. Today's podcast is sponsored by Cascade environmental. The only Field Services contractor with the experts and equipment to support you from Project conception to completion. Even when it comes to pfos contamination, their field Personnel are experienced in the stringent protocols required for p.

18:19 Phosphorylated drilling their proprietary Waterloo app. System can support the most complete delineation of pfos contamination in soils and groundwater and now their thermal Team is preparing for their first field demonstration of thermal pfos treatment. If you'd like to learn more about Cascades pfos delineation and Remediation capabilities, contact them at www.caucusnj.org and v.com. That's www.krsna.org nve.com You know, I just recently saw that there's a big push here in Indiana and I'm sure it's in the other states as well to, you know, really help communities replace their lead pipes, you know that are being used as service, you know, supply lines and stuff.

19:09 You know, I think this is created a huge focus with the EPA and other states, especially around, like, Flint. Michigan, was a huge issue that popped up, and that wasn't probably a big surprise, because I'm sure there's a lot of other communities. Just like flat that's out there that are struggling to like a dress. Like how do they actually reap? You know, go about replacing all these financially, it's a major lift right? You know, are there you talked about the state revolving funds having more money than ever before? But you know what, how fast can that money be actually deployed to local communities who need it and and or maybe not every there's some probably not. Governmental agencies as well.

19:54 Like, you know, that are privately, run utilities that you know, are supplying large communities. That also need help because of the old infrastructure that they've adopted or taken over from, you know, utility, you know, I mean this valid before. So how does that? How's that going to work? And how fast can people get this money? Well, the good news is, money's already been delivered to States across the country. Okay, we devoted week distributed more than four point nine billion dollars through the srf. Capitalization grants to all 47 States, six tribes and territories. And so we're working to ensure that that money is made available and even more specifically that their specific pots.

20:37 So those communities that have a need for lead service line replacement, not every Community has one but for those that do that, they have an opportunity to get it and if they're disadvantaged communities, that is to say they've just Some communities either. Just don't have the technical, the managerial and financial capacity and getting through that loan application process is a big lift for them. So what providing a hundred million dollars? A hundred fifty million dollars in technical assistance? Just help get those grants written for them. On your contractor. Somebody to do that for them, right? Exactly. Let's get them in the system and help to fund this in.

21:21 So Money is available. It's it's out there today and we know that it's not a One-Shot deal 20:23. We've got money out, the door 2024 2025 and 2026 and each distribution of funding that we send out states have a two-year period for delivering those dollars to communities throughout their states. And I will say, and the srf program in the years I've worked as Has been just a tremendous resource for communities. As I mentioned, fully half the funding is for Grants or forgivable loans, but the other half of the funding is at rates that are better than Market rates and these days with marker, it's going up fluctuate.

22:10 Yeah. That's a good thing. It's really important. Yeah, that's a good thing. I mean yeah. I think that's where a lot of the local, you know, states are wanting to help these communities. And as long as that money is sitting there, that's going to To really help them Advance these these, this infrastructure getting replaced. I really like that, you know, you talked about the proposed, pfos drinking water limits that are you know been released for those six compounds. You know what has been the initial feedback from? You know, the public utilities or the regulated Community or environmental groups so far? I mean, because it's only been out for about a month now, right? So Any feedback so far? Well initial feedback from some words.

22:52 What took you so long? Yeah well I was going to ask that question next, right? I mean it's been, it's been several years ten or so easy. And so there was a recognition and I will say, is a state director. I participated in a lot of conversations with my friends from Michigan, who's been in the lead in pfos as well. As other states, that already put in place, standards that require. They're both their Wastewater discharges in their Drinking Water Systems to do stuff to, to do this and and and Tuda to address people us.

23:33 And not only that but State states have gone out and tested their systems to try to figure out well, how much pfos is in our systems and and organizations like the Ohio River? And Tatian commission have already been out in the waters, trying to get a sense of what the ambient water quality is like in terms of pfos levels. So yeah, a lot of states were said to us. Well, it's time, that's good. That you're finally coming out with this rulemaking other reactions across the board. There is a recognition that the, the numbers would come out with, which if level detection for parts per trillion is lower than probably, any of the other standards that are out there today. There's also a recognition that over time science has given us a better understanding of the effects of pfos, on our, our systems, our human systems.

24:41 And therefore, it's important to regulate down to those levels to ensure that the Water that people are consuming is is clear from this and their Technologies available to put in place to deal with it. Yeah, yeah. I mean, yeah, it's no sense in creating a, you know, a cleanup level. They can't be achieved through treatment Technologies and, you know, today, I mean, it's a, I mean, I've been looking and reading and watching this unfold over the past few, you know, year and a half two years now. We did with everything that's really happening around pfos but it's really been going on for quite some time as we kind of mentioned. I mean, you know, tell me your take on, did you see that movie? Dark waters, you know, I did not. Are you kidding me?

25:34 I just Bruno. You have to watch that movie. I think your eyes will be quite open to some of the realities. That is a true story. So you're going to get Perspective of this, in a way that might really impact you. I think in a positive light. I think I really highly recommend it. Well, I will watch it just because you asked and because it's a slightly embarrassing to say. I haven't when so many other people have it's fantastic. You know, we actually had Robert blot who's the attorney on the show and it was just he was just fantastic, you know, efforts that he has put in To protecting you know local citizens and from exposure have been remarkable.

26:23 You know. He and to me he needs a Nobel Peace Prize as you know provided given to this man for what he's done to support the cause here. But you know, there's a long period of time that you know, the actual epidemiology data has been out there and, you know, I'm glad that the EPA has finally come out with these rules. Are these proposed levels? I'm not sure that you feel like we could go and add more to this as far as more chemicals. You know there's thousands and thousands of these chemicals out there, I'm curious. What is the epa's purse, you know, approach or perspective of just having six? Do they think if I just get sick?

27:05 So I'm going to get a whole bunch of other ones in the mix. If I'm just monitoring for 6 or, or if I have to treat to that level, I'm going to be treating all the other ones out as well. I mean, because there are a lot of chemicals that we don't know a lot of information about yet, right. And I think I'm just curious what epa's approaches to just only doing 64 right now. 22, thoughts. One is, we want to make sure and we're required to it's part of our rulemaking process to ensure that the science is pointing this out. So that any regulation we put in place is defensible and for those six, we feel we've got great scientific evidence that shows The, we need to treat at the levels that we are putting in the proposed rule.

27:54 But if so, that's one thing. The other thing is, as you mentioned, when you treat for pfos, often times, you remove more than one type of pfos and that's kind of reflected in the regulation or proposing. So we understand that the technology that's used to treat. For pfos removes not just pifo or p''f fos but a variety of other pfos as well. So we're expecting that will capture more as we treat the third thing and so that was a really important Insight. Sean that this is this technology will remove more.

28:37 The other thing is the way we structured, the rule pfoa and pfos are are regulated individually. But We've got the four others that were regulating as a mixture. So it'll be easier as the science progresses. And as we understand more to I think add that all the other constituents in as we go. And we believe we'll be treating for those other compounds with the technology. We've got that. We put in place at systems around the country. So a variety of Reasons that we're starting with six science.

29:19 First follow the science, follow the law, make sure defensible. Then secondly, we know the technology will remove it and third. We're building a rule in a way that helps make it possible to add others as we learn more. Well, that's kind of what I was getting ready to ask. Is this new proposed rule, good. Once it's in place because eventually, you know, it will become a rule at some point. You know, once you get all the feedback and you evaluate this, will it Will there be a mechanism to be able to add new compounds that are become? You know, you know that we that we become aware of right that are more toxic or things like that that are going to have negative effects to add them to the rule and in a more more quickly, you know, expedited fashion. So to speak, instead of this protracted review process, well I won't promise that there won't be a review process. I'm sure that's the one thing I've learned is that the process is extensive and there's good reasons for that, and that's all defensible.

30:26 But yes, the idea would be that when we put in place, this system, that will be able to do this more expeditiously than we might otherwise do. Because we'd be adding to the mixture if you will. Some of the, you know, little I guess less talked about Aspects of the proposed rule that can strike me is that, you know, there is this concept of if pfos is a toxic, not a hazardous waste, but a listed toxic chemical is under cercla. How does that affect the treatment disposal process of the media for the end users of, you know, that are processing and treating these chemicals out of the out of the water whose responsibility is that going to rely you know real be you know to do that.

31:16 That effectively I mean do you envision also pfos chemicals becoming you know, hazardous wastes in a way like you know, down the road and right now it's not. But well that's a whole Snowball Effect of new additional regulatory implications for for operators and managers of these types of chemicals. I expect that these these issues will require us to think about how we're we're dealing with this. We're finding pfos. In just about every place where, right? And, and you're right. The question is what about pfos and biosolids? What about the land app of biosolids. A major way of disposing of biosolids about biosolids. It's critical for municipalities to be able to do this land application and we recognize that, which is why we're going to be working with our partners.

32:16 I talk About Partnerships in the beginning, the partners at the National Association of Clean Water agencies. The municipalities that are tasked with cleaning our water to think about the effects of pfos and biosolids and figure out. Well what's the best way to move forward? With those things? I think it will take us all working together to think through all of the possibilities, because we've got a list I mean we've got chemicals that have been used in. Use the fact of lie in so many different ways in the country so yes it would.

32:57 There are there implications in a wide variety of areas? That's as you know we've already dealt with pfos or been thinking about pfos and firefighting foam for goodness sake and in Indiana, for example, they've collected pfos Laden Fire Phone firefighting foam and their disposing of that. And so there has to be substitutes in place and there are a lot of issues to work through, but but we're starting to tackle that and and one of the big things to tackle that Michigan's already been working on. For example, is is let's go to the source. You know what, what what's, what are the sources of pfos that are being discharged into our Wastewater systems?

33:40 And let's see if we can work with those. Those entities to reduce their loadings of pfos and or Wastewater. Hands on the front end so that the biocells don't contain that information. That's the ultimate way to address this in Michigan. They had electroplating facilities where where they identified, pfos loadings and they've worked with those systems to reduce the loadings of pfos into wastewater treatment plants. And so we're going to need to take a whole of agency approach toward pfos from our office of land and Emergency Management to water. Two are in other areas to figure out how to deal with this, in a way that doesn't transfer the problem from one entity to with the other. Did, you know, e-tank is the only environmental Rental Equipment company in the industry that offers a 100% certified clean guarantee and no additional cost. Well, this gives customers the Peace of Mind knowing that container contents from the previous renter isn't going to cross contaminate the contents of the current And potentially cause liability concerns.

34:50 You know. E-tank also provides a one-of-a-kind complete maintenance program for all its rental items including liquid, tight roll off containers, fluid transfer pumps and filtration system components to learn more about the types of containers, of pumps, e-tank supplies. Check out their website at www.esa.int. So, the next time you are faced with an environmentally challenging project, give e-tank a call to help solve your Problem, it's just that easy. And I'm definitely commend the EPA for getting this. This new rule out, this proposed rule for the MCL is fantastic. Are you guys in also in the planning stages of you know submitting a new proposed rule for Wastewater discharge we don't have a rule in process now but we did recently come out with guidance for States and and to say here are the things you could do that would help with this. And one of the Asians was the Michigan system of working with their pre-treating systems.

35:56 The other was, yeah, you could put in place limits and and here's how you could do it. And here are the mechanisms that would be legally defensible. So, so you push it to the state's, push you to the states, to let them implement the, the actual limits under their npdes permit process and and give the control a little bit to them to help manage the exposure in the waters, the state. Yeah. And at the same time, We are, of course, working on water quality standards, and we'll be doing that as well for, for pfos and people. So a variety of tools as are there anything else, any other little nuggets in the proposed rule that you know, we should be aware of or hadn't really talked about that's important to this Coast for some who work in the municipalities. They're going to look at it and say, wow, four parts per trillion but that's solo how we supposed to comply with that. When that's the level of detection and what's the what's the way that the agency's doing that? One of the things I was really proud of was the fact that the agency thought about that and they first of all they're going to put in place requirements for monitoring. But that for communities that have already been monitoring for pfos under the you see Mr. And in other ways they'll be able to use that data.

37:18 So they won't have to reinvent the wheel. That's one thing. Which will help reduce costs. But the other is that compliance will be based on a rolling annual average. And, and anything that is listed below, the four parts per trillion will count when they do the analysis and the analysis of compliance in a way, that doesn't just automatically, throw a municipality in the non-compliance with the, with the So I'm really proud of the fact that we thought through how can this be effective for a municipality that's putting in place the treatment to deal with this stuff. Yeah, you got to feel for these guys, to be honest with you, they're not the ones that are causing the problem. I mean, let's, you know, and here's my biggest, I think frustration of a lot of this is the fact that we're going to, we need these facilities to improve their a capability. So the consumers are not exposed but the end of the day. What's happening is is those costs are getting passed down to the consumers to deal with this you know treatment technology and infrastructure that needs to be built to support, you know, safe drinking water.

38:39 All the while Hoot, the polluter is not getting penalized or at least, you know, having to pay for these things at the moment right now. And I think most people in, a lot of the communities are really struggling with this. Whole process and why, you know, like big companies like, you know, Du Pont and chemours. And those guys who are, you know, and who and others, right? I mean there's others, right? They're not being addressed. They're not being required to pay for these type of upgrades for these local communities, at least in a way that seems, you know, Fair. Yeah. And let me just say we recognize that and that concern and that's why partly why under the bipartisan infrastructure Sure law.

39:22 We've got devoted dollar amount for these allowing our Drinking Water Systems to put in place these Technologies. So there's money available number one. But number two, there's a recognition that you're right. The, where's the part that the polluter has it in this? And therefore we are looking at pollution the polluters and dealing with that with our different mechanisms enforcement in, Particular to ensure that the polluters do pay and that the cost of compliance isn't just shifted onto our residents as they as it has in other situations, where you know, new treatment has to be put in place.

40:11 Yeah I just feel like that is the I guess the travesty of the the situation where we see, I mean granted I love the fact that the infrastructure bills, you know, allocating lots of money. Millions and millions of dollars. I mean I kind of looked at the allocation distribution for FY 2223 for you know these emerging contaminants for disadvantaged Community you know allotments and it's great. I mean you know Indiana is getting 26 million dollars, it says here and you know and and a lot of the other it's all broken down. It's really great information and it's great to see that these communities are getting funding but I just scratch my head and go. Wow. But those polluters are not really Paying what's for the damage they've caused and the exposure to human health and environment. And and you know, there's a lot of cancers and things like that are being caused by these, you know acute and or you know, chronic exposure, you know, it's like, wow, what are we going to do?

41:05 I mean I really like the cdep a ramp up enforcement actions on some of these polluters well we're determined to do that and we're determined to address that concern which is a legitimate one to ensure that we take action. Where we've got real evidence that many that there that there's been a polluter that's caused the these problems. And you know, I will say pfos, is ubiquitous in our environment? It's in the water. It's in the land. It's in a variety of other areas. So you have to make sure that you appropriately Engage The enforcement tools that you've got in a way that's defensible, but that's what we're going to do. Well, like if it's listed in cercla under circle, is a toxic, you know, chemical there.

41:53 I mean, there are thousands of thousands of these chemicals out there, if we only have six, there's a lot of, you know, thousands that aren't going to be listed that won't be quote, unquote attributable, to enforcement action. I mean, I think the sooner that, you know, the agency starts to add these chemicals to the list, it's going to ease up everything to make you I think enforcement action easier for, you know, these polluters for you guys for with polluters because it currently Still like unregulated, right? And that the big challenge. That's right. That's, that's exactly right. So that is definitely the challenge. That's why we're trying to get this rule out there before the end of this year. And that's why we will use the existing framework to put in place as we get better science on the others, put them into the mix and then we can take the enforcement action that that we need to take to ensure that it's not just the citizens that are paying. Pay for improvements to their water quality, but the polluter that caused the problem also is required to come up and help pay.

42:59 Now, that's, that's good to hear. You know, how does the unregulated contaminant monitoring role? Do you see Mr? Work and should there be more pfos chemicals added to that list? I think currently there's like twenty nine on that list now. And so my question with that, you know, monitoring program for drinking water, you know, utilities and municipalities is Is do they is that a quarterly monitoring program? Is that a annual monitoring program? Is it? You know what are the parameters around when samples are collected? You know, to be submitted for evaluation, you know, in this program and you so that way you guys can start understand and track, you know, hey, we have an impact in these communities with these types of pfos.

43:48 Yeah. Let me start with the big picture. What, what is this whole rule? Because a lot of people are not aware, but as part of the, under the Safe Drinking Water Act EPA has to implement Implement a section of the The act that requires a monitoring program for unregulated contaminants, and it requires that once every five years we issue a list of priority unregulated, contaminants, to be monitored by certain Public Water Systems across the states. The tribes, and territories in these contaminants may be present in drinking water, but are not yet subject to EPA, drinking water standards right under this. Rule EPA, Collects representative drinking water, occurrence data to support our future Regulatory determinations and assist in the development of national primary drinking water regulations.

44:47 Like the proposed pfos were, all right, right? And. And for each cycle, right now, we're working on, you see mr5 for each cycle. We establish a new list of contaminants for monitoring and specifies, which Systems are required to monitor identifies sampling locations in defines the analytical methods that we are to use, and the administrator at the end of 2021 signed. The, the fifth revision to the unregulated monitoring contaminated.

45:28 The content contaminant monitoring rule. It's a mouthful. So what what systems Going to be participating in. You see Mr. 5, so this is the way it works. EPA, has must require all Public Water Systems serving between three thousand, three hundred and ten thousand people to Monitor and ensure that a nationally representative sample of systems that are serving fewer than 3000 monitor, 300 monitor for contaminants in in future. Oils. So anybody's serving a population of more than 10,000 people. We call that a large system are responsible for participating in this program.

46:18 Excuse me. We anticipate a third of all systems, will collect samples between 2023 and 2025, and if we don't receive the Appropriations we need In a given year, we reduce the number of small systems that will be asked to perform monitoring. So the way it looks right now is in terms of small systems, those are fewer than 3,300 will have 800 systems. That collect samples, the somewhere in between 3302 10,000.

47:03 We got about 5,000. Systems. That will be collecting samples and then large systems of 10,000 and over will be looking at 4364 systems and there's a huge bunch of pfos chemicals. That will be looking at will be collecting samples at entry points to the distribution system at a water. System is that? How often? How often would that happen? Is it once a year or twice, a year quarterly? What does that look like? Yeah, the this systems must monitor four times during a consecutive 12-month, monitoring period, okay? And and they events must occur three months apart. Okay, so poorly that's good, that's good. I mean, that that gives a representative seasonal. Action.

48:06 That's, you know, I think representative of the you know what the normal drinking water intake would look like. That's good. I should I should clarify Shawn. That's for surface water systems or groundwater systems that are under the influence of surface water. But groundwater systems are little different, those systems monitor two times during a consecutive 12-month monitoring period and we can guess why we write that the answer to that is. Well, it's a Water system that the kind of seasonal changes that you see in surface water aren't as apparent in a groundwater system. Yeah, that makes sense. That makes sense.

48:46 Okay, if you're listening to this podcast I'll bet you may be thinking how can I level up in advance my career? If you want to get that promotion, increase your regulatory knowledge gain. Professional recognition and earn more money. Then it's time to obtain a new An industry credential from The Institute of hazardous material management. The I hmm offers eight credentials that are antsy approved for students experience, skilled employees without a degree and for the degree, professional looking to set themselves apart from the pack, their credentials, focus on three main areas. Certified, hazardous material manager, the see. Hmm. The certified dangerous goods, professional the CD GP, and the certified safety and health manager. The CSS.

49:33 Hm, if you And I, hmm, credential professional. Then you will be in the top 1% of your profession and your credential will have a global reach. Check out their programs, they offer at www.ihs.gov/scholarship today. Well, that's good to hear. So so the you seem R5 rule that's out now. It's got about twenty nine or so pfos chemicals. I mean it was funny. It was like they were all pfos chemicals except lithium so that was that was like okay you guys are really going all in on those contaminants that are unregulated. You know, I think when this data comes back to you guys I mean are what type of like data analytics? Are you guys running on all this information? Because one of the things I was looking at on the The website on epa's website is that you guys are collecting so much data. So much data that, I believe, you know, geez, it would be really great to see some Trend analysis, some dashboard, you know, some Community, if you could drill into a local community, you could see results. I mean, so much of that information you have at your, in your, you know, databases somewhere. It would be, wonderful to see some analytics done on that stuff.

50:59 Well, and we will do analytics on it. The data will be used. Is to support our regulatory, determination. That's the whole reason for you. See, Mr. Is, let's look at the data and then make a determination about whether we should regulate these chemicals. And so we'll be using that data will be sifting through. It will be analyzing it and so that we can make a determination about whether or not, we should be regulating that remember, there are unregulated currently, right? Yeah. In addition to that the results from the you see Mr. R. Stored in. What we call our national contaminant occurrence database for drinking water, which is good, because that means that the public can go take a look at that as well.

51:48 And then, in addition to that, there's a public notification rule that requires that all systems notify, their customers of the availability of the results from this data, no later than 12 months after the results are known. So, we use it for our regulatory determinations, but the public can use it as well, and we'll do the analysis necessary to determine whether or not we need to regulate these things. But the cut consumer, I think it kind of empowers them to say, oh, wow. Look, we do or don't have these contaminants in our drinking water.

52:29 Yeah. I mean, affected communities. Now that don't really have the, the treatment utilities that are really treating, the contaminants of pfos at levels that, you know, would be safe. They're relying on those Public Utilities to prepare to provide that data has publicly somehow Just To See, Is it safe this month? Or how is the treatment plant, really operating? And I still need to drink bottled water. I mean, there's all those kind of concerns and I think more of a real-time access to the data that people could, you know, like glean. Like the the The concern, the exposure concern would be really. I think helpful for Citizens know, I think you're right about that and not only is that important for Citizens, but also, how would we get it out to Citizens?

53:19 And as I mentioned, the community water systems are required to notify, the customers of the availability of this. But also, they're required to report these results in their consumer confidence report, which I mean, some people don't pay attention to but other people really do even when those can unregulated contaminants are detected. And I will say we're also working on our consumer confidence report rulemaking and one of the things that were we will be doing on the consumer confidence report. Rule is ensure that drinking water systems. Don't just report it once a year but do it twice a year. So That any changes in the system can be identified for residents in the system and they understand better what they're drinking Waters like.

54:14 Yeah. No. Yeah, that's that's great. I mean, I'd like this that would be fantastic. I'm, you know, I do a bunch of, you know, digital work. Now, in our practice, I in my business that I'm working for. And so we're all about data analytics and doing high-level Trend analysis of data. And, and I see this This as a huge opportunity for the EPA and work with Partners to maybe help them, get that information out. So well, it's a critical data analytics is critical for you guys and it's critical here at EPA. We must understand what what the data looks like. In order to put in place, the regulations that we put in place in because they've got to be defensible.

54:59 We can't just throw a number out there, right? And so we have a group of people. Within the office of water, called our office of Science and Technology, and those folks do analyze the results. In addition to that, they work with our office of research and development. I will put in a shout out for our friends at the office of research and developments location in Cincinnati Ohio. They do a lot of work on lead, for example. Okay. And then we've got we've got a location up and Duluth Minnesota as well. That does a lot of Of water work. So you're absolutely right data analytics, and Trend, analysis of drinking water, such a great thing, to emphasize, and, and we must do that in order to defend the rules that we put in place. Yeah.

55:49 I agree. I mean, we create dashboards for our customers and Trend analysis come in, and they can see the operating systems and that's the kind of stuff that really helps make decisions and helps operators, manage their business. And so I think just having that data for consumers is see to be so valuable. But I want to, I want to Pivot another question here for you. Just, you know, we're on this topic about the new proposed rule is the EPA considering establishing classes for the pfos chemicals. Like pcbs are kind of, you know, the president's kind of set it that way, you know. So that's already in a way, you know, to account. For some of these long chains, short chain type, you know, variants of the of the various, you know, pfos chemicals to really help. Protect our citizens, and we're doing a lot of thinking about that, Sean.

56:38 I think it's a an insightful question and we are thinking about that and that's part of the reason for the restructure, the rule as is with the mixtures. Yeah. Aside from the first, the pifo and pfos that that helps establish that and that that class is certainly something. We've been thinking through. Gotcha, no, that's good to hear because I think it could help. help, you know, manage this, this this situation More exactly down the road. I mean, there's so many of these these types of chemicals. How do you really cover it? All right, I mean what if we say Hey you know, add these up, get your total. Now, you got a problem, you know, you know, now you need to start treating mean, I think that could be a really good effective way to address some of this. Although, you know, let's let the science and then, you know, some of the smart kids in the room, know to kind of figure this out, but I really feel like that could be a good option for people and that's essentially what our mixture. Provision does in the rule.

57:43 It's exactly that it assigns a numeric value. Not based on the and there's a an interesting formula in the rule that helps to do that for that mixture. Yeah. It was good. Yeah, it's kind of cool. You kind of laying the groundwork in a way. Yeah, that's that's kind of what I kind of took out of that. So that was really good. See what else did I have for you? Do you feel like, I mean, you know, hey, 50 billion dollars for the bipartisan infrastructure Bill. There was like 5 billion allocated to small disadvantaged communities, you know, is there enough funding to go around for all the states and to address all the issues you think, or what you need more? I will as as a person who understands the needs out there acknowledge that, there's always more that we could do both. To this, I will say blown away this it I've never seen so many dollars devoted to this when I was in Indiana, the typical cap grant that we got through.

58:56 Srf was 18 million dollars for drinking water and 32 million dollars for Waste Water projects on a yearly basis. This, this is so much higher than that. I know that we have needs too. Soak up that money at, there's no doubt about it and will want more for sure. And I just, I understand that the challenges that communities face will be tough and that it will come at a cost to insure that we have safe and clean water. And part of that cost will be will be paid for through the the money in the bipartisan infrastructure law and then the the community, Will chip in, and then we hope the polluter pays helps with the P5 stuff. Is there enough?

59:51 There's never enough, but we've made a really incredible down payment now. That's really great to see that, you know, the EPA and Congress have allocated this, this bipartisan funding for these types of projects. I mean, they're so so needed. I mean, you know our, our infrastructure, you know, for Wastewater ER, and sewers, and things like that and and around our country, in a lot of locations, there's just, you know, it's so outdated. It's, you know, 100 years old, or more some, in some places or, you know, or they're just challenged like, you know, it's been 1950 design and, you know, things are breaking down and now the capital costs are more than the tax base, that, you know, can even fund to fix it because, you know, things have happened, right? I mean, Dad are those are real issues. I think most of some of our communities are facing so it's great to see.

1:00:45 It you guys have put together and with the by demonstration put this together, so kudos to the EPA and Congress for that really appreciate all that. Well Bruno you know, hey what else is there? I mean we've covered some good ground here, super excited that you came on the show today. I mean, I don't know where else we could go here. I mean, we could probably get into some weeds if we needed to, but we might want to, you know, pause for a second and I'll let you know, give a parting shot too. To the listeners. Will they? Let me just save this Sean. There's a lot more work were engaged in. We've talked a lot about pfos. We talked about lead and copper. One of the things we didn't talk about was Waters of the United States.

1:01:27 That's a rulemaking, we just finished up. And at the end of the year, we're looking forward to a Supreme Court decision in that matter. But we're also working in a wide variety of other areas, one of the big things that's going on as climate and the trying to figure out new ways to Questor carbon and we're at the Forefront of that as well in the office of water because we issue what we call class 6 well permits to facilities that want to sequester carbon underground. So we are working to do that and we just put out a rule making that will give Louisiana Primacy over the classics program. We are also working as a mention on the consumer confidence rule We've got a number of LG's.

1:02:18 We've been working on, WE issued a proposal for a steam electric LG. We're were coming out with nutrient. Trading ideas will be coming out with a proposal sometime next year for microbial. Disinfection byproducts rule. There's just a whole host of things that were working on And there's so many that you know, it can make your head spin on. Yeah. Oh, I can imagine. I think one thing we didn't touch on is, you know, circular economy and water. You know, the sustainability perspective.

1:02:59 You know, what are the initiatives that EPA is going to push or promote for recycling? You reuse water. You know, there's so much that I think, you know, to manage water more effectively, you know? So So that seems to be a big area that a lot of our clients are also asking us about, you know, how do we address circular economy in the water space? Yeah and and in the west water is a very very pretty. Yeah. That's right. We've read about the Colorado River. I know that states in the west are working to deal with the water shortages and And reuse water and I've been out to California where I've been lucky to be at groundbreakings for water reuse projects. That takes treated Wastewater from one treatment plant and sends it to the reservoir for drinking water in another. And then Super treats it to ensure that we reuse the water in a way that's effective and conserves water as well. There's desalination is issues.

1:04:15 There's just a whole host of issues and it's at the Forefront of folks in the west. How are we going to deal with the lack of water? We've got you know this past winter, California. It got a lot of snow and that's helped but still water issues will remain in that state. So creative thinking will have to be done in order to deal with the water availability Christ. Is in California and Arizona and think about this Sean, the number of cities that we've got that are in areas that are really deserts, Arizona.

1:04:56 Nevada, California is, those those communities are growing rapidly. We will come to grips with. How are we going to best provide the water? That's necessary for residents for Industries and for the economy in those? Areas as well. It's a big deal. It's a big deal. It's a big deal. Well Bruno, hey, thank you for coming onto the show today. Thank you for, you know, having a great candid conversation with me, kudos to you and to the EPA. All the hard work you're doing there and we're looking forward to, you know, how this new proposed rule gets implemented and finalized and and how you know the the the lead pipe replacement Supply that That you know, gets enacted and supported through local community. So thank you for coming on and really, really appreciate it. Well, it's my pleasure.

1:05:52 It's great to see you and look forward to our next chat. That's right, we'll do it again soon hopefully. Yeah, great. All right. Thank you. Thanks, Bruno. I want to thank our guests, a Bruno pigott for coming on to the show. Today if you have questions for Bruno and want to learn more about what the EPA is doing to protect human health and the environment and the Waters of the United States, you can check out their website at www.opm.gov/tribalprograms know at pigot dot Bruno at epa.gov will also put a link to his contact information on my website to listen to Future environmental transformation.

1:06:33 Cremation podcast, you can check us out on all the major podcast networks or from my website at www.shawnacoronado.com. Remember, don't forget to follow us and we'd really appreciate if you would write a review for us about the podcast. It also helps increase our podcast placement, in all the podcast networks. Also, if you're watching on YouTube, don't forget to subscribe to our Channel. Thanks for listening. And until next time, make a positive impact in someone's life today.