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Emerging Contaminants identify triggers) for a specific EC to the five DoD functional areas. The Phase I Impact Assessment process consists of three primary activities: ��� Verify triggers and assess the likelihood of regulatory/policy/toxicity value change. ��� Develop background data on the EC. ��� Consult with subject matter experts (SMEs) to integrate the information developed in the first two activities and evaluate the risks the EC poses. Scan step because of potential drinking water regulations or water quality criteria revisions. Of the 30 ECs that have been through the Phase I Impact Assessment, several were identified as contaminants of concern within the water community, including beryllium, hexavalent chromium, lead, nanomaterials, nickel, NDMA (N-nitrosodimethylamine), PFOS (perfluorooctane sulfonate), PFOA (perfluorooctanoic acid), RDX (cyclotrimethylenetrinitramine), TCE (trichloroethylene), and vanadium. Phase II Impact Assessments have been conducted for beryllium, hexavalent During the Phase I Impact Assessment process, SMEs with chromium, lead, perchlorate, PFOA, RDX, and TCE. Many of qualifications and knowledge of the EC meet to estimate these have also been on EPA���s drinking water Contaminant the risk it poses (in terms of probability and severity) to Candidate Lists. However, the subsequent risks identified each of the five functional areas. The results and recomto the DoD mission during the Phase I and/or Phase II mendations from the assessment Impact Assessments are often are documented in a Phase I occupational or environmental Similar to planning Impact Assessment Report, risks that do not necessarily which includes a description of directly reflect water-related timelines for public and the primary risk trigger or trigregulatory concerns. private water agencies, gers (e.g., pending health criteria assessment or an agency rule Conclusion DoD���s risk management under development). Similar to planning timelines strategies and investments The Phase I Impact Assessment for public and private water produces one of the following agencies, DoD���s risk management must be responsive to three recommendations: strategies and investments must potential public-health or ��� Low risk ��� Remove the be responsive to potential publicEC from the Watch List. health or mission concerns. As a mission concerns. ��� Unclear risk ��� Keep the result, risk management options EC on the Watch List for and actions are often accounted continued monitoring and future re-assessment. for in requirements planning and timelines that are well ��� Elevated risk ��� Place the EC on the Action List for ahead of regulatory actions. further analysis. The EC program is continually identifying new contaminants and moving others through the second and If it is determined that the EC poses an elevated risk, it is third steps of the process. There will continue to be ample presented to DoD Senior Leaders for approval to be placed sources of potential contaminants for screening, including on the ���Action List.��� EPA���s recent identification of 10,000 potential chemicals Once approved, a Phase II Impact Assessment is perfor its Endocrine Disruptor Screening Program and its formed. The Phase II Impact Assessment has three objectives: forthcoming Regulatory Determinations on the Third ��� Verify, update, and validate the risks identified Contaminant Candidate List. To date, 556 contaminants in the Phase I Impact Assessment associated with have been screened. Currently there are 20 contaminants past, present, and future use of the EC, and/or on the EC Watch List and 7 on the Action List; 18 RMA���s are items or materials that contain the EC. being implemented to reduce risk from these ECs. ��� Describe in qualitative and quantitative terms the By implementing the Scan-Watch-Action process, the adverse impacts associated with these risks. DoD identifies and manages the risks associated with ECs ��� Develop, score, and rank risk management options and mitigates potentially adverse consequences ��� offering (RMOs) to address medium and high risks. a framework for water utilities to do the same. ��� RMOs can include research projects, guidance development, and communication and coordination within the DoD Services or with other agencies. RMOs are presented to Senior Leaders for approval and, once endorsed, become Risk Management Actions (RMAs). As a civil engineer and manager at the Noblis Center for Sustainability, Erica Brown focuses on strategic planning and implementation for federal projects related to sustainability, homeland security, climate change, emerging contaminants, environmental health, regulatory compliance, and water policy. Andrew Rak is a senior principal scientist for Noblis. Rak has more than 20 years of experience addressing complex environmental and public health problems. Currently, he leads Noblis��� efforts to support the Office of the Deputy Under Secretary of Defense (Installations & Environment) Emerging Contaminants Program. The Process in Practice ��� Ties to Water So what does the Scan-Watch-Action process look like in practice? Many ECs enter into the process through the wateronline.com ��� Water Online The Magazine 39