WATEfl
UNITED STATES ENVIRONMENTAL PROTECTION! AGENCY
WASHINGTON. O.C. 20460
HAR 27 199C
Announcement of Public Meeting to Discuss
cmaiVJUAAf RULE FOR GROUND WATER DISINFECTION
The office of Drinking Water would like to invite you
to attend « public meeting on June 21, 1990 from 1:00 p.m.
X S-oo B B. at the Andrew W. Breidenbach Environmental
JL^rch Center Auditorium located at 26 West Martin Luther
5iIS Drive Cincinnati, Ohio 45268. If public comments or
Sic?u2sio! warrant it, the meeting will continue at the same
T^arien on June 22, 1990 from 9:00 a.m. to 12 Noon. This
ieetiia will focus on aspects of the development of Primary
Slinking Water Regulations for disinfection of ground water
suDDlies. Specifically, we would like to discuss the
technical criteria including conditions necessary for
variances.
Attached are a fact sheet with more meeting details and
a copy of "Draft Ground Water Disinfection Requirements."
The meeting will begin with a brief summary of the
approach EPA is currently considering. Members of the
public will then be given an opportunity to make brief
statements on issues concerning the ground water
disinfection rule. Most of the program will allow informal
discussion of the issues.
If you plan to attend, please contact Sharon Church
(202-382-3030) as soon as possible, preferably before
June 14, 1990.
Comments on the strawman rule and on the discussion in
the meeting will be solicited from the public for .
consideration in developing the regulation.
If you wish to discuss any of these criteria,
contact Stig Regli (202-382-7379).
Sinceely,
please
«„,«,.. n- Cotruvo, Ph.D., Director
Criteria and Standards Division
Office of Drinking Water
Attachments
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Public Meeting to Discuss
. STRAWMAN REGULATION FOR
GROUND WATER DISINFECTION REQUIREMENTS
PACT 8HBBT
DATE AND TIME: 1:00 p.m. to 6:00 p.m. EDT
Thursday, June 21, 1990
If warranted, the meeting will continue at:
9:00 a.m. to 12 Noon EDT
Friday, June 22, 1990
LOCATION: Andrew W. Breidenbach Environmental
Research Center Auditorium
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
REGISTRATION:
Call Sharon Church (202-382-3030), preferably
before June 14, 1990. We need to know total
attendance as well as who is intending to
make presentations.
BACKGROUND:
"Draft Ground Water Disinfection
Requirements"
PURPOSE:
To have an open public discussion of the
strawman rule. The public will -be encouraged
to comment on EPA's background document and
any presentations, make relevant statements
and presentations, and discuss any
information or ideas presented. The meeting
will be informal.
COMMENTS!
Written comments can be sent to:
Stig Regli . .
Criteria and Standards Division
U.S. Environmental Protection Agency
Office of Drinking Water (WH-550D)
401 M Street, S.W.
Washington, D.C. 20460
CONTACT:
For further information contact Stig Regli at
the above address or by phone (202-382-7379).
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5TpfitJMAN GROUND WATER DISINFECTION REQUIREMENTS (GWDR^
"(4/18/90)
Fulfills f9llowina Statutory Requirements OF Safe Drinking Water
Act fSDWAL
EPA must promulgate disinfection requirements for all public
water supplies by June 19, 1989. (EPA promulgated disinfection
requirements for systems using surface water on June 19, 1989).
EPA must promulgate regulations for Giardia lamblia. viruses,
Leoionella, and heterotrophic plate count bacteria (HPC) , and
turbidity by June 19, 1989. (EPA promulgated treatment
requirements in systems using surface water or ground water under
the direct influence of surface water for Gjardia Iambi xa,
viruses LfiSiflnfilla, HPC and turbidity on June 19, 1989.) Since
Giardia lamblia, and turbidity are not characteristic of ground
water supplies' (i.e., those not under the direct influence of
surface water) they do not need to be regulated in ground water
supplies.
NOTE- THIS RULE IS. NOT INTENDED TO REGULATE FOR CRYPTOSPORIDIUM.
EPA IS CURRENTLY EVALUATING WHETHER THE SURFACE WATER TREATMENT
RULE (SWTR) , WHICH REGULATES FOR CTARDTA LAMBLIA IN SYSTEMS US IMG
SURFACE WATER OR GROUNDWATER UNDER THE DIRECT INFLUENCE OF
SURFACE WATER, ALSO PROVIDES. ADEQUATE PROTECTION FOR CONTROLLING
CRYPTQSPORIDiyM. IF EPA DETERMINES THAT THE EXISTING SWTR DOES
NOT PROVIDE ADEQUATE PROTECTION FOR rpyfTOS PORI DIUM EPA WILL
PROMULGATE AMENDMENTS TO THE SWTR TO ENSURE THAT IT DOES.
Maximum Contaminant Level Goals fMCLGs)
Viruses
Leaionella
Heterotrophic Plate Count (HPC)
0
0
none
Under the SWTR no MCLG was published for HPC because this
represents both innocuous and pathogenic bacteria and there fc
EPA could not set a particular HPC (other than at zero) at J-h
no, adverse health effects occur. EPA believes an MCLG of zer
inappropriate since the SDWA would then require EPA to promu
an MCL as close to zero as feasible; the health benefits of
meeting a level near zero versus some higher level (e.g., 500
100ml) are unquantif iable and probably negligible, if any. A
excessive amounts of disinfectant would be needed to achieve
a level and thus could result in excessive disinfection by-
products in the finished water.
e
- is
pe.
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General Requirements
Coverage: All public water systems (including non-community)
using any ground water source must disinfect unless they obtain a
variance from the State according to Section 1415 (a) (B) of the
SDWA. Before a variance may be granted by the State, it oust be
determined that the system can meet the variance criteria of this
rule (see pg. 7) , and the State must provide notice and
opportunity for public hearing on the proposed variance. (Note:
variances to treatment technique requirements are different than
those to MCL requirements in that no determination by the State
of best available technology (BAT), compliance schedule, and no
unreasonable risk to health is needed.)
Disinfection treatment technique requirements are established in
lieu of MCLs for viruses, heterotrophic plate count bacteria, and
Leqionella. Treatment technique requirements are established for
viruses and Leaionella because it is not economically or
technologically feasible to measure the levels of these
contaminants. Treatment technique requirements are established
for HPC to limit their growth in the distribution system; no MCL
is established for the same reasons as not publishing an MCLG
(see above).
All systems using disinfection must be operated by qualified
operators as determined by the State. (ALTERNATIVE OPTION:
requirement does not apply to non-community systems unless they
serve more than 100 people.)
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Specifi"' •pgeruirements
i) level of inactivation
Option 1 - State discretion on inactivation rate/State specifies
design and operating conditions
System must provide disinfection on all water delivered to the
distribution system, unless a variance is granted by the State
(see pg 6). States must specify the appropriate level of
disinfection and enforceable design and operating conditions for
each system based on site specific characteristics. For example,
depending upon the probability of risk from fecal contamination
in the source water, the State would specify a minimum level of
inactivation (e.g., disinfection but with no minimum rate
specified, or 1 (90%), 2 (99%), 3 (99.9%), 4 (99.99%), or 5 logs
(99.999%) of inactivation. The State would be reguired to
specify enforceable design and operating conditions (e.g.,
appropriate contact time and dosage depending upon the
disinfectant used) for the system to meet the appropriate level
of inactivation.
The design and operating conditions specified by the State would
depend upon CT values recommended by EPA, or other -information
that the system made available to the State. "CT" is the product
of residual concentration (mg/1) and contact time (minutes)), ana
UV disinfection conditions. See Tables E7, E9, Ell, E13, and £14
for CT values and UV conditions necessary to achieve different
levels of inactivation for different disinfectants (Note: these
CT values are taken from the 10/89 guidance manual to the Surface
Water Treatment Rule. They may change depending upon new data
that becomes available within the next year).
EFA will provide guidance to States for determining appropriate
levels of inactivation in a Guidance Manual to the ground water
disinfection requirements. EPA will define different levels of
risk for different characteristics of ground water systems.
(NOTE: UNDER THIS OPTION THE MINIMUM LEVEL OF INACTIVATION IS
ONLY ENFORCEBLE BY THE STATE; IT IS NOT FEDERALLY ENFORCEABLE)
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level of disinfection con'd
Option 2 - EPA specifies the minimum level of inactivation for
all systems/State specifies design and operating
conditions for meeting this level
This is the same as option 1 except that all systems would be
required to disinfect (except those able to get a variance) to
achieve at least some minimum specified level of inactivation of
viruses (e.g., 4 logs). The State must specify enforceable
design and operating requirements which, if met, will ensure that
this minimum level of inactivation is achieved. EPA would also
recommend higher levels of inactivation for very high risk source
waters.
EPA will provide guidance to States for developing such criteria
in a Guidance Manual to the ground water disinfection
requirements.
Option 3 - hybrid of option 1 and 2
(lead)
EPA specifies the minimum level of inactivation for all systems
but State can specify lower level depending upon site specific
characteristics. State specifies design and operating conditions
for meeting this level.
(NOTE: UNDER THIS OPTION THE MINIMUM LEVEL OF INACTIVATION IS
FEDERALLY ENFORCEABLE, UNLIKE OPTION 1 WHERE IT IS NOT).
Option 4 - EPA specifies CT values rule / utilities demonstrate
compliance
Systems must meet the operating conditions (CT values) specified
in the rule, for the particular disinfectant that they use, to
achieve at least 99,99 percent inactivation of viruses. If
conditions for a disinfectant are not given, the system must
demonstrate to the State that the disinfection conditions
provided are achieving at least a 99.99 percent inactivation.of
viruses.
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2) continuity of disinfection
Option 1 - State discretion on monitoring and enforceable (lead)
criteria
must provide continuous disinfection on all water
no the distribution system and provide adequate monitoring,
determined by the State, to demonstrate this. The State must
scecifv enforceable criteria for ensuring that systems are
Soviding continuous disinfection. EPA will provide guidance for
States to specify such criteria.
ontion 2 - EPA specifies monitoring and enforceable criteria
option 2 *adop£ siinilar provisions to SWTR and expand to allow
for UV) .
svstems must provide a detectable disinfectant residual or UV
dosaSin the water entering the distribution system,
demonstrated by continuous monitoring. If there is a failure in
the Sonlinuous monitoring, the system may substitute grab sample
monitoring every four hours for up to five days.
If there is an absence of a disinfectant residual or UV dosage
for any time, the system must notify the State as soon as
possible but no later than the end of the next business day.
Notification must include whether or not the residual or_UV
dosage was restored within four hours. If disinfection is not
restored to the required operating levels within four hours, it
is a violation.
systems serving 3300 people or less from one fr»°n!LWSiil
using disinfectants other than UV light, can take . J""**11
sample per well per day in lieu of continuous monitoring. If
any time the residual is absent, the system must conduct grab
sample monitoring every four hours until the residual is
restored.
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3) distribution system requirements
Option 1 - EPA specifies residual requirements
(adopt same provisions as SWTR)
Disinfectant residuals in the distribution system cannot be
undetectable in more than five percent of the samples, each
month, for any two consecutive months. Samples must be taken at
the same frequency as total coliforms under the coliform rule,
but no less than one sample per month,"during which the system is
in operation. A system may measure for HPC in lieu of
disinfectant residual. If the HPC measurement is less than 500
colonies/ml, the site is considered to have a "detectable"
residual for compliance purposes. For systems which cannot
maintain a residual or practically monitor for HPC. the State can
•judge whether adequate disinfection is provided, or is needed, in
the distribution system and this requirement does not apply.
Option 2 - State discretion
No requirement unless State specifies residual or HPC monitoring
is needed to demonstrate adequate protection.
Option 3 - hybrid of Option 1 and 2
(lead)
Adopt Option 1 for community systems serving greater than 3300
people. No requirement for smaller systems unless specified by
State.
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Variance Criteria for Avoiding Disinfection
1} svstems must not have had any waterborne disease outbreaks,
or if they have, such systems must have been modified to prevent
another such occurrence, as determined by the State.
y\ within every 5 years system must have a sanitary survey which
indicates that the source water is not vulnerable to viral or
bacterial fecal contamination as determined by the State.
Guidance will be provided for determining an adequate sanitary
survey in the Guidance Manual to the ground water disinfection
requirements.
(NOTE- FREQUENCY OF SANITARY SURVEYS IS CONSISTENT WITH THAT
REQUIRED UNDER THE TOTAL COLIFORM RULE FOR GROUND WATER SYSTEMS
WHTCHCOLLECT FEWER THAN 5 SAMPLES PER MONTH. EPA ANTICIPATES
¥S?THE^N1TARV SURVEY COULD ALSO BE CONDUCTED AT THE SAME TIME
THAT OTHER REGULATORY NEEDS ARE MET, E.G., VULNERABILITY
ASSESSMENTS TO REDUCE MONITORING FOR VOLATILE ORGANIC AND
SYNTHETIC ORGANIC CHEMICALS. EPA IS DEVELOPING GUIDELINES FOR
HOW BEST TO COORDINATE SUCH EFFORTS.)
3} All wells within the system must meet the well construction
code(s) specified by the State. The State must have an active
well construction code subject to EPA approval. Guidance will be
provided for determining an adequate well construction code.
4) The system must have a cross connection control program in _
place which is approved by the State. Guidance will be provides
for determining an adequate sanitary survey in the Guidance
Manual to the ground water disinfection requirements.
5) The system must be designed, as approved by the State, to
ensure high probability that a positive pressure is maintained
throughout the distribution system.
6) The system must comply with monitoring requirements of the
Total Coliform Rule.
Analytical Requirements
Testing and sampling must be in accordance with Standard Methods,
17th edition, or methods approved by EPA for disinfectant
residuals.
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All monitoring required in the .rule must be reported monthly to
the State.
Compliance
All community systems must meet monitoring and performance
requirements by December 29, 1995. All non-community systems
must meet monitoring and performance requirements by December 29,
2001. (Note: Under the SWTR, States must determine whether all
ground water sources are under the direct influence of surface
water for community systems by June 29, 1994 and for noncommunlty
systems by June 29, 1999.
Exemptions Allowed. ' . .
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TABLE E-7
CT VALUES FOR ., ,.
TioN or VIRUSES ir rare CHLCRISE '
0.5
5
10
15
2°
25
Lee Inaetiration
2.0
PH
6-9
«
4
3
2
1
!
12
45
30 .
22*
15
11
7
3.0
PH
«=»
»
6
4
3
2
1
'10
««
44
33
22
1C
11
4.0
pH
«-f 10
12 90
• 60
6 45
4 30
3 22
2 "
NotM:
1. 0»ta «
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TABLE E-9
CT VALUES FOR
INACTIVATION OF VIRUSES
BY CHLORINE DIOXIDE oH 6.
Removal
2 log
3 log
4 log
Notes:
» 1.
y
€i 5. la IS 2* 2£
8.4 5.6 4.2 2.8 2.1 1.4
25.6 17.1 12.8 8.6 6.4 4.3
50.1 33.4 25.1 16.7 12.5 8.4
Data adapted from Sobsey (1988) for inactivation of Hepatitus A Virus
_ . ..I * f* - u A ___ _ «... A.._^ _ C ^ ^T » • 1 *IA» * ««^ 1 itM A A e A IA+ \s T »c^
2.
CT values adjusted to other temperatures by doubling CT for each 10 C drop
in temperature.
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TABLE I'll
t
CT VALUES FOR
TNACTIVAT10N OF VIRUSES JBYQ2QN£a-Z)
2 log
3 log
4 log
Notes:
.1.
Temoerature (C^
on Al -5- 10- IS. 2fi- 25_
0.9 0.6 0.5 0.3 0.25 0.15
1.4 0.9 0.8 0.5 0.4 0.25
1.8 1.2 1.0 0.6 0.5 0.3
Data adapted from Roy (1982) for •inactivation of poliovirus for pH
and temperature • 5 C. CT values include a safety factor of 3.
2. CT values adjusted to other temperatures by doubling CT for each 10 C drop
in temperature.
U
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TABU; E-I3
CT VALUES FOR
VIRUSES BY CHLORAMINE
(1,2,3)
Jnietivation
2 log
-3 log
4 log
41
1,243
2,063
2,883
5
857
1.423
1.988
10
643
1,067
1,491
15
428
712
994
321
534
746
214
356
497
Motes:
2.
Dtta from Sob.«y (1988) for inactivatien of H.patitu. A Virus (HAV)
for pH - 8.0 and ttmp«ratur« - 5 C, «nd Msrad to apply for pHs in
th« rang* of 6.0 to 10.0.
CT valu.s «dju«t«d to eth«r t«mp«ratur«. by doubling CT for «ach
10 C drop in t«mp«ratur«.
tabl« of CT valu.t appli«> for syst«ns uting conbin.d chlorint
chlortn. i. «ddtd prior to ««oni» in th. tr.awtnt ..«^.nc..
in thi« tmbl. .hould not b« u.«d for «.ti»ating th«
cf d!.infJction in .y.t«n. applying pr.fonn.d
or awnonia *h«ad of chlorin*.
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TABLE E-14
CT VALUES FOR
IHACILVATION OF VIRUSES BY UVO)
Loo Inactivities
2.0
21
3-D
36
Note:
1.
Data adapted from Sobsey (1988) for UY Inactlvation of
Hepat1tu$ A Virus (HAV). Units of CT values are eH-sec/cn?
CT values Include a sartey factor of 3.
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AFFECTED UNIVERSE
SYSTEM TYPE ^SYSTEMS POP (MIL)
COMMUNITY
UNDISINFECTED 22,658 11.4
PARTIALLY DIS 4,323 3.9
DISINFECTED 19,221 55.7
TOTAL 46,202 71.0
NONCOMMUNTTY
UNDISINFECTED 110,052 20.6
DISINFECTED 26,489 4.5
TOTAL 136,541 25.1
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(:- ..i1'-'^3*!,^
•! :.'!'•''2 i.;:'.'V
COMMUNITY GW- SYSTEMS
NUMBERS OF SYSTEMS AND
POPULATION BY SIZE CATEGORY
25-600
92433
>3300
3546
>601-3300
10223
#'S OF SYSTEMS
>3300
53.4
601-3300
13.9
25-600
4.8
POP (MILLIONS)
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O
O O
>*J O
CO Co
*<
CO
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Waterborne Disease 71-88
Cases (reported) in Thous. by Etiology
UNTREATED GW
INADEQ DI3 GW
34.8
3W TREAT DEFIG
54.7
MI3C
0.3
DI3T * STORAGE DEF.
18.5
INTERRUPT DI3 GW
12.3
0o*pll*d by Craun 3/27/00
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