EPA 814-B-96-001
April 1996
ICR Sampling Manual
April 1996
Technical Support Division
Office of Ground Water and Drinking Water
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
Printed on Recycled Paper
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FOREWORD
The Information Collection Rule (ICR), found in Subpart M to 40 CFR Part 141 -
National Primary Drinking Water Regulations, requires each public water system (PWS) that
meets certain applicability criteria to collect specified information for a limited period of time.
The ICR establishes specific data collection requirements and designates the manner of
collecting and transmitting the required data to the United States Environmental Protection
Agency (EPA). Additional ICR requirements are found in four technical manuals:
• "ICR Sampling Manual," EPA 814-B-96-001
• "DBP/ICR Analytical Methods Manual," EPA 814-B-96-002
• "ICR Manual for Bench- and Pilot-Scale Treatment Studies," EPA 814-B-96-003
• "ICR Microbial Laboratory Manual," EPA/600/R-95/178
These technical manuals serve as "rule by reference" documents, and have two main
objectives: (1) To complement the ICR by further specifying the details of the rule
requirements; and (2) To provide guidance on how to comply with the ICR requirements.
Therefore, each manual typically designates a requirement through the use of terminology such
as "shall," "will," or "must," whereas guidance is generally offered through the use of terms
such as "may" or "should." Copies of the manuals are available for a fee from the National
Technical Information Service (NTIS), U.S. Department of Commerce, 5285 Port Royal
Road, Springfield, VA 22161. The toll free number for NTIS is (800)336-4700.
The target audience for the "ICR Sampling Manual" is the person(s) located at each
affected PWS who is/are responsible for understanding and complying with the sampling
requirements of the ICR. Therefore, the purpose of this manual is to provide detailed
requirements and guidance for affected PWSs to accomplish the following in accordance with
the ICR:
• Develop an Initial Sampling Plan and utilize it to develop Monthly Sampling Plans and
generate Final Design data.
• Utilize Monthly Sampling Plans and reports to collect appropriate samples and
supporting information.
• Utilize suitable sampling techniques (and containers) to collect and ship representative
samples to EPA-approved laboratories for analyses.
• Report appropriate data electronically to EPA at required intervals.
This document was prepared by the EPA's Office of Ground Water and Drinking
Water (OGWDW), Technical Support Division (TSD), Cincinnati, Ohio. Principal
contributors to this document are Steven C. Allgeier, Eric M. Bissonette, Michael D.
Cummins, Patricia S. Fair, Richard J. Lieberman, Bonita S. Newport, Richard Tomaskovic,
and James B. Walasek.
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DISCLAIMER
Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
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ACKNOWLEDGMENTS
The authors gratefully acknowledge the contributions of the following individuals
during the preparation of this document.
For conducting a formal review and providing comments on the entire document:
Blake Atkins; EPA, Region 6, Dallas, TX
Wendy Marshall; EPA, Region 10, Seattle, WA
Eva C. Nieminski, Ph.D.; UT Department of Environmental Quality, Salt Lake City, UT
Thomas J. Sorg; EPA, OGWDW, TSD, Cincinnati, OH
For conducting an informal review and providing comments on all or some components
of the document:
Bernard Bubnis, Ph.D.; Novatek, Oxford, OH
Sanwat Chaudhuri, Ph.D.; UT Department of Health Lab Services, Salt Lake City, UT
Nilda Cox; Montgomery Watson Laboratories, Pasadena, CA
Daniel R. Dahling; EPA, Office of Research and Development (ORD), National Exposure
Research Laboratory (NERL), Cincinnati, OH
Andrew Eaton, Ph.D.; Montgomery Watson Laboratories, Pasadena, CA
Kara R. Fox, EPA, ORD, National Risk Management Research Laboratory (NRMRL),
Cincinnati, OH
G. Shay Fout, Ph.D.; EPA, ORD, NERL, Cincinnati, OH
James W. Messer, Ph.D.; EPA, ORD, NERL, Cincinnati, OH
Laura L. Oilier; University of Cincinnati College of Engineering, Cincinnati, OH.
Eugene W. Rice, Ph.D.; EPA, ORD, NRMRL, Cincinnati, OH
Frank W. SchaeferlH, Ph.D.; EPA, ORD, NERL, Cincinnati, OH
Lois C. Shadix; EPA, OGWDW, TSD, Cincinnati, OH
R. Kent Sorrell; EPA, OGWDW, TSD, Cincinnati, OH
Ronald E. Stetler; EPA, ORD, NERL, Cincinnati, OH
R. Scott Summers, Ph.D.; University of Cincinnati College of Engineering, Cincinnati, OH
James J. Westrick; EPA, OGWDW, TSD, Cincinnati, OH
Barbara M. Wysock; EPA, OGWDW, TSD, Cincinnati, OH
For providing word processing support and preparation of graphics:
Phyllis A. Branson; EPA, OGWDW, TSD, Cincinnati, OH
Cynthia A. Bultman; EPA, OGWDW, TSD, Cincinnati, OH
Lillian Holmes; EPA, OGWDW, TSD, Cincinnati, OH
A. Kent Neathery; EPA, OGWDW, TSD, Cincinnati, OH
IV
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Contents
Foreword ii
Disclaimer in
Acknowledgments iv
Figures viii
Tables ix
Appendices x
1.0 Introduction 1-1
1.1 Who Should Read This Manual? ,.......,,..,,.,.., 1-1
1.2 Regulatory Background 1-1
1.3 Overview of ICR Implementation from Promulgation to Start of Sampling 1-3
1.3.1 Notification of Applicability 1-3
1.3.2 Notice of ICR Final Applicability Determination 1-4
1.3.3 Initial Sampling Plan Preparation and EPA Approval 1-5
1.4 Data Quality 1-6
1.4.1 Data Management Tools 1-6
1.4.2 Lab Approval ' 1-7
1.4.3 Sampling, Laboratory Data and Reporting 1-7
1.5 Where to Get Additional Technical Assistance 1-8
2.0 Developing an Initial Sampling Plan 2-1
2.1 Purpose of EPA Review 2-1
2.2 Submittal of the Initial Sampling Plan . 2-2
2.2.1 Letter of Transmittal 2-2
2.2.2 ICR Water Treatment Plant Schematic 2-2
2.2.3 ICR Distribution System Schematic 2-7
2.2.4 Initial Sampling Plan Diskette 2-7
2.3 Data Entry Using the ICR Water Utility Database System 2-8
2.4 Initial Sampling Plan Reports . . 2-11
2.5 Final Design Data 2-11
3.0 Treatment Study Applicability Monitoring 3-1
3.1 Applicability Monitoring Requirements 3-1
3.2 Treatment Plants that Must Conduct Applicability Monitoring 3-2
3.2.1 Each PWS Serving a Population of 100,000 or More 3-2
3.2.2 Each PWS Using Ground Water and Serving
50,00 to 99,999 Persons 3-2
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Contents (continued)
3.3 TOG Monitoring Requirement 3-3
3.4 DBF Monitoring Option 3-3
3.5 Monitoring Required to Demonstrate a Common Source 3-3
3.6 Reporting Requirements 3-4
4.0 General ICR Sampling Requirements 4-1
4.1 Develop a Monthly Sampling Plan 4-1
4.2 Coordinate with ICR Approved Laboratories 4-2
4.2.1 ICR Laboratory Approval . 4-2
4.2.2 Laboratory Capacity 4-3
4.2.3 Sample Collection and Handling 4-3
4.3 Collect and Ship Samples 4-3
4.3.1 Monthly ICR Samples 4-3
4.3.2 Quarterly ICR Samples 4-4
4.3.3 Sample Identification Labels 4-4
4.3.4 Sample Containers 4-7
4.3.5 Sample Preservatives and Dechlorinating Agents 4-7
4.3.6 General Sampling Procedures 4-14
4.3.7 Sample Handling, Packaging, and Shipping 4-15
4.4 Record Appropriate Information 4-20
4.4.1 Forms and Worksheets 4-20
4.4.2 Analytical Data from Laboratories 4-22
4.5 Verity Monthly Sampling Information 4-22
4.6 Report Monthly Sampling Information to EPA 4-23
5.0 ICR Sampling Requirements - By Location 5-1
5.1 Samples Required for ICR Monitoring 5-1
5.2 Monitoring Requirements 5-1
5.2.1 General 5-1
5.2.2 Treatment Plant Influent 5-5
5.2.3 Before the First Point of Oxidant Addition 5-10
5.2.4 Washwater Return 5-10
5.2.5 Additional Water Sources 5-11
5.2.6 Before and After Filtration 5-11
5.2.7 Before Each Point of Disinfection 5-11
5.2.8 After Every Unit Process Downstream from
the Addition of Chlorine 5-12
5.2.9 Finished Water Sample Point 5-12
5.2.10 Entry Point to the Distribution System 5-14
5.2.11 Simulated Distribution System 5-14
VI
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Contents (continued)
5.2.12 Distribution System 5-15
5.2.13 Full Scale GAC or Membrane Treatment 5-16
6.0 Additional Sampling Requirements for PWSs Using Alternative Disinfectants ... 6-1
6.1 Treatment Plants Using Chloramines 6-1
6.1.1 Treatment Plant Influent 6-1
6.1.2 Finished Water . 6-2
6.1.3 Distribution System 6-2
6.2 . Treatment Plants Using Hypochlorite Solutions 6-2
6.2.1 Treatment Plant Influent 6-3
6.2.2 Hypochlorite Stock Solution 6-3
6.2.3 Finished Water 6-4
6.3 Treatment Plants Using Ozone ". . 6-4
6.3.1 Ozone Contactor Influent 6-5
6.3.2 Each Ozone Contact Chamber Effluent 6-5
6.3.3 Ozone Contactor Effluent 6-5
6.3.4 Finished Water 6-6
6.4 Treatment Plants Using Chlorine Dioxide 6-7
6.4.1 Treatment Plant Influent 6-8
6.4.2 Before First Chlorine Dioxide Application 6-8
6.4.3 Before First Point of Downstream Chlorine/Chloramine
Application; After Chlorine Dioxide Application 6-9
6.4.4 Before Application of Ferrous Salts,
Sulfur Reducing Agents, or GAC 6-9
6.4.5 Finished Water 6-9
6.4.6 Distribution System 6-10
6.5 Arranging for Special EPA ICR Analyses: Cyanogen Chloride,
Aldehydes and Low-Level Bromate 6-12
6.5.1 Scheduling Sample Analyses 6-12
6.5.2 Shipping/Sample Kits 6-14
6.5.3 Analytical Data from the EPA Laboratory 6-15
7.0 Particle Counting 7-1
7.1 Alternative Monitoring Requirements 7-1
7.2 Discrete Sample Container Selection and Preparation 7-2
7.3 Sampling 7-3
7.4 Sample Storage/Holding Conditions 7-4
7.5 Sample Preparation and Analysis 7-4
7.6 Quality Assurance/Quality Control 7-5
7.7 Particle Counting References 7-6
VII
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Figures
Figure 2-1 ICR Water Treatment Plant Schematic (Example) 2-5
Figure 2-2 ICR Distribution System Schematic (Example) 2-10
Figure 5-1 Treatment Plant Influent Sample - Single Intake 5-7
Figure 5-2 Treatment Plant Influent Sample - Multiple Intakes 5-8
Figure 5-3 Treatment Plant Influent Sample - Multiple Intakes
with Chemical Addition 5-9
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Tables
Table 4-1 ICR Analyte Group/Codes ; . . . . . . 4-5
Table 4-2 Sample Collection Containers and Preservatives/Dechlorinating Agents . •. 4-8
Table 4-3 Sample Collection, Handling, and Storage 4-16
Table 5-1 Monthly Monitoring Requirements for Treatment Plants 5-3
Table 5-2 Quarterly Monitoring Requirements for Treatment Plants 5-4
Table 5-3 Monitoring Required Across Full-Scale GAC or Membrane Processes . . .5-16
Table 6-1 Additional Quarterly Monitoring for Treatment Plants
Using Chloramines 6-2
Table 6-2 Additional Quarterly Monitoring for Treatment Plants
Using Hypochlorite Solutions 6-4
Table 6-3 Additional Monthly Monitoring Required of
Treatment Plants Using Ozone 6-7
Table 6-4 Additional Quarterly Monitoring for
Treatment Plants Using Ozone 6-7
Table 6-5 Additional Monthly Monitoring for
Treatment Plants Using Chlorine Dioxide 6-11
Table 6-6 Additional Quarterly Monitoring for
Treatment Plants Using Chlorine Dioxide 6-12
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Appendices
Appendix A ICR Water Utility Database System Reports: A-Series A-l
Appendix B ICR Water Utility Database System Report:
B.I—Monthly Sampling Plan by Location B-l
Appendix C ICR Water Utility Database System Reports: C-Series C-l
Appendix D Procedural Requirements for SDS and CLD Samples D-l
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1.0 Introduction
1.1 Who Should Read This Manual?
The purpose of this "ICR Sampling Manual" is to provide the detailed information
necessary for affected public water systems to accomplish the following in accordance with the
ICR requirements:
• Follow the procedure that has been established to submit responses to presumed ICR
applicability.
• Conduct monitoring to determine applicability of the ICR treatment study requirements.
• Develop an EPA-approved Initial Sampling Plan and utilize it to develop Monthly
Sampling Plans and the generation of Final Design data.
• Utilize Monthly Sampling Plans to collect appropriate samples and supporting
information.
• Utilize suitable sampling techniques and containers to collect and ship representative
samples to EPA-approved ICR laboratories for analyses.
• Report appropriate data to EPA at required intervals.
Therefore, the target audience for this manual is the person(s) located at each affected
PWS who is/are responsible for understanding and complying with the sampling requirements
of the ICR.
1.2 Regulatory Background
EPA is currently developing several rules that will: 1) address chemical byproducts that
form when disinfectants used for microbial control in drinking water react with various
organic chemicals in the source water, and 2) maintain or improve protection against microbial
contaminants. To address the risk/risk trade-offs inherent in these rulemaking activities EPA
initiated a formal regulation negotiation (Reg/Neg) process with representatives from water
utilities, State and local agencies, environmental groups, consumer groups, and EPA. During
the negotiations, a number of the members of the negotiating committee expressed their view
that adequate data were not available to address some of the DBFs on EPA's priority list.
Also of concern were the limited data available for microbiological contaminants. The
committee agreed that additional monitoring data should be collected to re-assess the adequacy
of the Surface Water Treatment Rule (SWTR) [40 CFR Part 141, Subpart H] and develop
appropriate strategies to prevent increased risk from microbial disease when systems are
required to begin complying with the D/DBP Rule.
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The Negotiating Committee agreed to propose three rules:
• An Information Collection Rule (ICR)
• An interim Enhanced Surface Water Treatment Rule (ESWTR)
• D/DBP regulations, to be proposed concurrently with the interim ESWTR
The ICR is designed to obtain both microbial and DBF occurrence data and to collect
water treatment plant design and operating information. An evaluation of the occurrence of
DBFs in plant process streams and finished water will be conducted, as well as a
determination of source water characteristics and treatment processes that influence DBF
formation. Analyses of chemical monitoring data will help EPA and the water industry better
understand the relationships between source water quality and disinfection chemicals (and
processes) during the creation of disinfection byproducts.
During an 18 month period, each PWS will sample and analyze water at various points
in their water treatment and distribution systems. Information collected under this rule will be
used to update the Water Treatment Plant (WTP) predictive model. This model, used to
predict trihalomethane (THM) and haloacetic acid (HAA) levels, was initially calibrated on
fewer than 100 studies (including bench, pilot, and full-scale studies). It used raw water
quality and limited process data to predict THM and HAA formation. Data collected during
the ICR will provide a sufficiently large database to upgrade the model to include additional
processes, predict other DBPs, and further calibrate the model. Plant treatment data will be
coupled with the monitoring data to assess how treatment affects precursor removal and the
formation of THMs, HAAs, and other DBPs. In addition, the monitoring data will allow for
an assessment of how parameters like total organic carbon (TOC),, total organic halides (TOX)
and simulated distribution system-disinfection byproducts (SDS-DBPs) compare to distribution
system compliance parameters. Relationships among the process data, the water quality data,
and the chemical data will be evaluated and analyzed to provide the basis for possible changes
to the current SWTR and to develop drinking water regulations for disinfectants and
disinfection byproducts.
Microbial contamination of source and treated water will also be investigated. Recent
outbreaks of cryptosporidiosis, a disease caused by the protozoan Cryptosporidium, has
emphasized the need to establish treatment requirements for this protozoan. Only limited
occurrence data are currently available to support development of a regulation for
Cryptosporidium. Therefore, Cryptosporidium monitoring will be an integral part of the ICR.
Also, recent investigations indicate that the 3-log (99.9%) removal/inactivation of
Giardia and the 4-log (99.99%) removal/inactivation of enteric viruses specified in the SWTR
may be inadequate when a water treatment system is supplied with poor quality source water.
New data suggest that Giardia cyst concentrations in the source waters of many systems may
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be too great for the specified minimum treatment to adequately control waterborne Giardiasis.
As a result,of this uncertainty, EPA will collect additional occurrence data via the ICR for
Giardia cysts and viruses in various source waters, under temporal and seasonal influences, to
determine whether additional treatment is necessary to provide adequate public health
protection against Giardia and virus contamination.
Data which will be collected are also expected to help EPA characterize occurrence
relationships among Giardia cysts, Cryptosporidium oocysts, and viruses. These data will be
used in various ways; such as to help the Agency evaluate the merits of using Giardia as the
primary target organism to define treatment requirements, as it did in the SWTR.
1.3 Overview of ICR Implementation from Promulgation to Start of Sampling
1.3.1 Notification of Applicability
Following promulgation and publication of the ICR in the Federal Register,
EPA will send a Notification of Applicability (notification) letter to each PWS
presumed to be affected by the requirements of the ICR. The purpose of each
notification letter is to:
• Formally announce the ICR.
• Notify each PWS of its presumed status relevant to ICR applicability.
• Request each PWS to verify EPA estimates of the population it serves.
• Request each PWS to determine the official and technical PWS ICR contacts
and identify them for EPA.
• Request each PWS to verify its mailing address.
• Request each PWS to list the treatment plant(s) it operates, and to determine
ICR applicability for each plant.
The notification letter shall serve as a formal request from EPA to which each
affected PWS shall be required to respond, as stated in the ICR [§141.142(c)]. A PWS
which meets the applicability criteria is subject to the requirements of the ICR even if it
does not receive a notification letter from EPA. Therefore, a PWS which in fact,
meets the applicability criteria of the ICR must contact the EPA Safe Drinking Water
Hotline (see Section 1.5 of this manual below) and request a notification letter from
EPA in the event one was not received by the PWS.
Each PWS will have 5 weeks (35 calendar days) to respond to the EPA
notification letter. The PWS response must provide EPA with the information
requested as well as verify the information contained in the notification letter. If
relevant, the response to the notification letter may also specify the PWS's initial
decision to conduct particle counting in lieu of finished water monitoring for Giardia
and Cryptosporidium as described in the ICR [§141.143(a)(2)(iii)]. In addition, should
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a PWS wish to request an exemption from conducting virus monitoring for a particular
treatment plant as described in the ICR [§141.143(a)(2)(iv)], it shall indicate its desire
for the exemption in the written response to the notification letter and submit the
appropriate six consecutive months of coliform data.
If the event that a PWS challenges the presumed ICR applicability, it must
provide written justification for excluding the PWS and/or its plant(s) from the
requirements of the ICR in their response to the EPA notification letter.
The applicability section of the ICR [§141.141(b)(l)] summarizes the criteria
used to place treatment plants into categories (referred to as categories A through G).
Further, the ICR [§141.140] defines a treatment plant to include facilities in which
ground water or purchased finished water is disinfected prior to entering a distribution
system. For example, a site where disinfectant is added to purchased finished water
prior to entering a distribution system could realistically serve a very small population
but still be classified as an "F" category treatment plant. The monitoring requirements
for such a facility as identified in the ICR [§141.141(b)(2)] may not substantially
contribute to the objectives of the ICR. Therefore, the costs incurred by a PWS may
not be justified by the limited benefits gained through the collection of ICR monitoring
data at those treatment plants.
In response to the notification letter, each PWS must identify every facility that
meets the ICR definition of a treatment plant. Each PWS shall review every treatment
plant in its system, including those in categories E and F, and identify all treatment
plants which should be included in the ICR. A PWS may request that one or more of
its treatment plants be excluded from the ICR requirements, however, it shall also
provide the rationale to fully justify such an exemption. The EPA reviewing officials
shall have the authority to grant exemptions. The rationale for an exemption may
include, but not be limited to, criteria such as: a plant treated an average annual 1995
flow of 3 million gallons per day (MOD) or less; a plant serves a small percentage of
the PWS population; a treatment plant is scheduled to go out of service in the near
future; and/or a plant is not physically connected to the main distribution system of the
PWS. The rationale must show that inclusion of a particular plant would not be
consistent with the intent of the ICR.
1.3.2 Notice of ICR Final Applicability Determination
EPA will process the information provided by each PWS in response to the
notification letter to determine ICR applicability. Each PWS will then receive an
Notice of ICR Applicability Determination (applicability) letter which will state
EPA's final decision on how each treatment plant within a PWS is affected by the ICR.
The applicability letter will state which plants are required to conduct ICR
microbiological monitoring, DBP monitoring, water quality monitoring, treatment
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process monitoring, and treatment studies applicability monitoring. An estimate of
requirements for distribution system monitoring will al§o be included.
NOTE: Treatment studies applicability monitoring is to begin within 3 months
of promulgation of the ICR, and is not contingent upon preparation and EPA review of
an Initial Sampling Plan as is the 18-month ICR monitoring. Section 3 of this manual
provides more detailed information on treatment studies applicability monitoring.
Each PWS which utilizes chloramines, ozone, or chlorine dioxide as a
disinfectant at any treatment plant affected by the ICR will receive a sample date
reservation form from EPA as an enclosure to the applicability letter. This form must
be completed by the PWS and returned to EPA within 5 weeks (35 calendar days) of
receipt by the PWS. The purpose of the form is to help establish a sampling schedule
with the EPA laboratory conducting special ICR analyses (for cyanogen chloride,
aldehydes and low-level bromate).
1.3.3 Initial Sampling Plan Preparation and EPA Approval
Each PWS will have 8 weeks from receipt of the applicability letter to prepare
and submit one (1) Initial Sampling Plan to EPA for review. An Initial Sampling
Plan shall include the location and analytical parameters to be monitored at each
sampling point within each plant and distribution system. Detailed information about
the design parameters of each plant, its unit processes and distribution system shall also
be included. Distribution system monitoring is based on the configuration of each plant
feeding into the distribution system, so it is important to clearly identify this
plant/distribution system arrangement in the Initial Sampling Plan. Further
requirements of the Initial Sampling Plan are covered in Section 2, "Developing an
Initial Sampling Plan," of this manual.
A PWS can apply for exemptions from individual ICR sampling requirements
by including the rationale to justify such an exemption in a cover letter along with its
Initial Sampling Plan submittal. The rationale for an exemption may include, but not
be limited to criteria such as: a disinfectant applied by a PWS does not achieve the
residual assumed in the ICR, therefore monitoring requirements are not consistent with
the objectives of the ICR; and/or the configuration of a PWS is such that some
distribution system sampling points are in very close proximity to each other, but are
not located at the same physical sampling location.
An American Water Works Association (AWWA) Assistance Team (A-
Team) has been assembled to provide direct, individualized assistance, upon request, to
each PWS for developing its Initial Sampling Plan. AWWA is also planning to provide
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group assistance through training sessions covering topics such as "Understanding the
ICR," sampling, and "hands-on" instruction for using the data entry software necessary
for developing an Initial Sampling Plan.
EPA will assess the validity of each Initial Sampling Plan through the use of a
formal review process. The results of this review process will be communicated in
writing to each PWS, wherein EPA will indicate the status of the Initial Sampling Plan
and provide recommendations for modifications when appropriate. EPA approval will
be granted to a valid Initial Sampling Plan, whereas an unstisfactory plan will not be
granted approval status until it is corrected according to instructions provided by EPA.
Each PWS will have four (4) weeks following receipt of the written formal review
letter from EPA to correct and resubmit its Initial Sampling Plan, if required, for
approval. EPA will then reassess the validity of the revised Initial Sampling Plan and
provide a written response to the PWS stating the status of the plan.
Each PWS shall begin ICR monitoring at its plant(s) in the first full month
following receipt of the results of the EPA review of the Initial Sampling Plan,
regardless of the approval status of the Initial Sampling Plan submittal. Therefore, lack
of Initial Sampling Plan approval shall not delay the start of monitoring. However, the
monitoring shall be conducted in conformance with the modifications to the Initial
Sampling Plan as recommended by the EPA review process. The EPA
recommendations will specify sampling locations and analytical parameters which must
be included in the modified plan. The PWS shall amend the Initial Sampling Plan and
subsequently resubmit it to EPA for official approval.
1.4 Data Quality
The following brief summary describes some of the implementation tools and processes
that EPA has developed and put in place to help ensure the collection of ICR data which meets
established quality objectives.
1.4.1 Data Management Tools
EPA initiated the development of three separate data management systems for
gathering and managing ICR data:
• The ICR Water Utility Database System - to facilitate sampling plan
development, entry of treatment plant design data, analytical results and
data reporting by each PWS.
• The ICR Laboratory Quality Control Database System - to facilitate
data entry and reporting of Quality Control (QC) data by ICR approved
laboratories.
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• The ICR Federal Database System - to manage and analyze all
collected data.
1.4.2 Lab Approval
To ensure that accurate and valid data are collected, EPA initiated a process to
evaluate and approve chemical and microbiological laboratories to perform analyses for
the ICR. EPA will produce, and routinely update, a list of ICR approved laboratories.
The list will be available through the EPA Safe Drinking Water Hotline (see Section
1.5 of this manual below).
1.4.3 Sampling, Laboratory Data and Reporting
The folio whig describes the flow of samples and data during the 18 month ICR
sampling period:
• Each PWS will make arrangements with ICR approved laboratories for
the analyses of ICR monthly and quarterly samples.
• Each PWS will collect and ship ICR monthly and quarterly samples to
ICR approved laboratories.
• The ICR approved laboratories will analyze the samples.
• The ICR approved laboratories will provide the results of the analyses to
the PWSs along with the Quality Control (QC) data that must be
reported by each PWS. EPA recommends that the laboratories also
provide the PWSs with copies of all QC data that are associated with the
ICR samples.
• The ICR approved laboratories will forward applicable laboratory QC
data to the EPA. (Reports are on a monthly basis. The data must be
reported within 2 months after the month in which the analyses were
performed.) Laboratories will use the ICR Laboratory Quality Control
Database Software to record, manage, and report QC data to the EPA.
• Each PWS will verify and validate its ICR monitoring data, and forward
these data and the associated plant operating information on diskette to
EPA using the ICR Water Utility Database System. Public Water
Systems will use the Water Utility Database Software for managing the
data, including the verification and validation of the data.
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The ICR Federal Database System will perform QC checks on the
monitoring data by evaluating the associated QC data (received from
each PWS and ICR approved laboratory), complete various validation
and verification processes, and perform review operations to ensure
completeness for all data required to be submitted. Monitoring data that
do not pass the QC checks will be deleted from the ICR Federal
Database.
1.5 Where to Get Additional Technical Assistance
• EPA Assistance:
• The EPA Safe Drinking Water Hotline:
(800) 426-4791, or HOTLINE-SDWA@EPAMAIL.EPA.GOV
• The ICR Data Management System Hotline:
(703) 908-2155, or 102351.2062@compuserve.com;
AWWA Assistance via the ICR Assistance Team (A-Team):
(800) 200-0984, or 103327,2057@compuserve.com
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2.0 Developing an Initial Sampling Plan
Before any ICR water samples are collected, each PWS participating in the ICR is
required to submit an Initial Sampling Plan package for EPA review and response. The Initial
Sampling Plan package is to be sent to:
USEPA (ICR 4600) - ICR Data Center
Room 1111 East Tower
401 M Street SW
Washington, DC 20460
Utilities shall use the ICR Water Utility Database System software, provided by EPA,
in developing their Initial Sampling Plan. The software is "user friendly" by providing user
prompts to assist the utility in developing the sampling plan, and in entering required data into
the system. A handbook entitled, "ICR Water Utility Database System Users' Guide," EPA
814/B-96-004, provides detailed instructions and additional information, and will be provided
to each PWS. It is suggested that the individual responsible for preparing the Initial Sampling
Plan thoroughly review this handbook before attempting to prepare the Initial Sampling Plan.
In addition to the "User's Guide," AWWA training courses on the use of the data entry
software have been planned. Furthermore, EPA has developed a one-hour "data-entry"
videotape which will be available to each PWS.
2.1 Purpose of EPA Review
The Initial Sampling Plan review process will allow each PWS to confirm with EPA
that the appropriate sample locations and corresponding analytical requirements have been
identified for each treatment plant. Although the rule language goes into great detail on
sampling requirements, EPA recognizes that each treatment plant is a unique combination of
unit processes that may have been constructed over many years. It is likely that situations
exist where it is virtually impossible to collect samples at certain locations exactly as specified
in the rule. The Initial Sampling Plan review process will allow EPA the flexibility to approve
sampling plans on a case by case basis which may deviate from otherwise "impractical" rule
requirements. For example, if the configuration of a particular treatment plant prevents the
collection of a required sample at a particular location, the PWS can explain the situation in
the cover letter of the Initial Sampling Plan submittal package to EPA. The EPA reviewing
official shall have the authority to approve a modification of the sampling requirements which
will be consistent with the objectives of the ICR.
A second objective of the Initial Sampling Plan review process is to ensure that each
PWS understands how to properly use the software to configure their process trains, to locate
sampling points, and to identify samples to be collected and analyses to be performed. The
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Initial Sampling Plan (captured on a diskette) which must be sent to EPA prior to the start of
sampling will provide the information needed to assess the capability of a PWS to properly
utilize the software. Developing an appropriate Initial Sampling Plan is therefore a crucial
step toward providing meaningful ICR data. Therefore, prior to the EPA Initial Sampling
Plan review process, EPA and AWWA plan to provide technical support, training materials
and training courses to help ensure that Initial Sampling Plans are properly prepared.
2.2 Submittal of the Initial Sampling Plan
Each PWS shall submit an Initial Sampling Plan package to EPA. This will include the
information captured on diskette through use of the software in addition to plant schematic(s)
and a distribution system schematic which portray each treatment process configuration,
sampling location, and all monitoring requirements which conform with the intent of the ICR.
The cover letter and complete Initial Sampling Plan package shall be submitted to EPA as
specified in the ICR [§141.142(c)(2) and §141.143(c)(3)].
The Initial Sampling Plan "package" shall include the following elements:
2.2.1 Letter of Transmittal
A letter of transmittal shall accompany submission of the Initial Sampling Plan
diskette. If pertinent, the letter of transmittal shall point out any discrepancies between
ICR requirements and the proposed Initial Sampling Plan. The letter of transmittal
shall also verify the PWS's final decision to comply with the alternative monitoring
requirements (particle counting and in-plant monitoring for protozoa) in lieu of finished
water monitoring for protozoa as described in the ICR [§141.143(a)(2)(iii)]. The PWS
shall apply appropriate signature authority to the letter of transmittal.
2.2.2 ICR Water Treatment Plant Schematic
A PWS shall submit an ICR water treatment plant schematic for each
treatment plant affected by the ICR as determined by the EPA applicability letter
(see Section 1.3.2 of this manual). An ICR water treatment plant schematic should not
be confused with any existing schematics the PWS may already have on file. The
specifications for an ICR water treatment plant schematic are detailed below.
NOTE: The ICR A-Team (see section 1.5 of this manual) is available to assist
each PWS hi developing the required ICR schematics.
Each ICR water treatment plant schematic must provide a pictorial
representation of all the unit processes hi the treatment plant, depicting the flow of
water through each unit process in the plant. Each unit process, sampling location and
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the analytes to be monitored at each location must be clearly identified for each water
treatment plant. Figure 2-1 contains an example of a hypothetical ICR water treatment
plant schematic consisting of a single treatment train. However, in situations where the
flow is split into two or more treatment trains, the schematic must display this as well
as the unit processes in each of the treatment trams. Although two or more treatment
trains may be employed at a single treatment plant, the sampling locations shall be
identified for only one treatment train determined as the most representative of the
water treatment plant.
An ICR plant schematic will most likely deviate from the standard format/layout
of any plant schematics that may already reside at a PWS. The format/layout of each
ICR plant schematic should adhere to the guidelines that follow: A minimum of a one-
inch margin should be maintained at the top, bottom, right and left sides of each page.
In the upper right-hand corner of each plant schematic, include the utility (system)
name, system PWSID number, plant name, plant PWSID number (if any), ICR Plant
ID number (assigned by EPA), and the design flow in million gallons per day (mgd).
Each ICR plant schematic shall show all applicable water resources, water
intakes, plant influent and finished water (as ovals connected by lines). All unit
processes shall be depicted by labeled rectangular boxes connected by lines. Each
sampling point is to be associated with the unit process directly upstream of it. When
possible, sampling locations shall be shown at the effluent of a unit process. Chemicals
fed into the process train shall be shown as an arrow feeding into a particular unit
process (rectangle). To avoid confusion when using the software, disinfectant addition
shall be shown on the schematic as a separate unit process (not a chemical being fed
into a unit process). Another unique characteristic of the software is that the
washwater return sample point is automatically created when you add a washwater
return unit process to the sampling train. It is depicted as a unit process in the
schematic to assist the user of the software. Samples collected at the washwater return
sample point (#15 in Figure 2-1) reflect the quality of the combined flows. However,
the washwater return sample location (#02 in Figure 2-1) reflects the quality of the
washwater being added to the process train. Each sampling location shall be identified
by a unique two-digit number (see Section 4.0 of this manual). The analytical
specifications depicted on each schematic shall be based on monthly and quarterly
monitoring requirements.
The schematics are to show only disinfectants and chemical feed points that are
anticipated to be in use at the time of monitoring, and should not show all possible
disinfectant and chemical feed points. Operational changes that occur over the 18
month monitoring period should be reflected in the monthly sampling plans (see
Section 4.1 of this manual).
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Finally, the plant schematic is not intended to show detailed design or operating
information. The detailed information required by the ICR [§141.142(a)(6)] will be
entered into the ICR Water Utility Database software and submitted to EPA on diskette
as part of the Initial Sampling Plan package.
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Anytown, USA
PWSID: OH1234567
East WTP
ICR Plant ID: 101
Design Capacity: 100 MGD
Page 1 of 2
01) WQP, Br, NHa, TOC, UV, CLD, Bact, Prot, Virus, TOX
Cli
Disinfectant Addition
Washwater Return
Washwater Sample Point
|02) WQP, Br, NHj, TOC, UV, Ck, TOX
PAC,OFC
Clz
HFS, Alum. PAC
«
)
»15) Cli
f
Intake Basin
> 03) WQP, Ck, TOC, UV
Disinfection
Rapid Mix
CaOH
Flocculation
f 05) Ck
KEY:
WQP = pH, Alkalinity, Turb,
Temp, Calcium and
Total Hardness
DBP=THM, HAA, CP, HK,
CH, HAN
CLD = Chlorine Demand
Sampling Location
UnitProcess
Notes: 1./(alfec indicate
quarterly samples.
2. For the East WTP,
sample locations #09
(Finished Water) and
#10 (SDS)areatthe
same physical location.
Figure 2-1. ICR Water Treatment Plant Schematic (Example)
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OPF,
sox>
Sedimentation
Anytown, USA
PWS1D: OH1234567
East WTP
ICR Plant ID: 101
Design Capacity: 100 MGD
Page 2 of 2
90S) WQP, Clz, TOG, UV
Y
Filtration
07) WQP, Ch, TOC, UV, TOX, DBF
Disinfection
Clear Well
Y 08) WQP, Clz, TOC, UV
1.
Disinfection
>
f
09) WQP, Cli, TOC, UV, TOX, DBP
Figure 2-1. (continued)
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2.2.3 ICR Distribution System Schematic
An ICR distribution system schematic should not be confused with any
existing schematics the PWS may already have on file. The specifications for an ICR
distribution system schematic are detailed below. In addition, the ICR A-Team (see
section 1.5 of this manual) is available to assist each PWS in developing the required
ICR schematics.
An ICR distribution system schematic (see Figure 2-2) will most likely deviate
from the standard format/layout of any distribution system schematics that may already
reside at a PWS. A PWS shall submit one ICR distribution system schematic showing
the complete system as described below. In the upper right-hand corner of the
schematic, include the utility information (system name and system PWSID number).
The ICR distribution system schematic shall show each treatment plant (as a labeled
box or other graphic notation), the sample locations between the end of the process
train and the distribution system (excluding the finished water sample location which
appears on the ICR plant schematic), distribution system sampling locations associated
with each treatment plant, and the analytical parameters to be measured at each
sampling location. Sample locations between the end of the process train and the
distribution system which should appear on the ICR distribution system schematic
include the entry point to the distribution system (Entry Point) sample location and the
simulated distribution system (SDS) sample location. The Entry Point sample location
is only identified when water is blended from two or more treatment plants before it
enters the distribution system. Figure 2-2 does not identify an Entry Point sample
because water from the two plants is not blended in this hypothetical example.
However, an SDS sample point is identified in Figure 2-2 and is at the same physical
location as the Finished Water sample point (#09 in Figure 2-1). Even though they are
physically located at the same sample point, they represent two different samples and
will therefore have different sample location numbers.
Unlike the ICR plant schematics, the analytical parameters hi the ICR
distribution system schematic are generally the same for each sample location and can
be shown one tune for all sample locations. In addition, sampling location numbers in
an ICR distribution system schematic may not be unique if more than one plant is
feeding the distribution system. In the hypothetical example depicted in Figure 2-2,
two plants are feeding a common distribution system. Each plant defines its own
distribution system sampling points.
2.2.4 Initial Sampling Plan Diskette
All Initial Sampling Plan information, with the exception of the transmittal letter
and the schematics for the plant(s) and distribution system, are to be submitted to EPA
via computer diskettes as required by the ICR [§141.142(c)(2) and §141.143(c)(3)].
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Each PWS shall therefore submit an Initial Sampling Plan diskette that is generated by
the ICR Water Utility Database System software. Use of the software is important
because it confirms (for EPA and the PWS) the sampling locations in the treatment
plant(s) and distribution system. The software is also used to record detailed
information on the design of the treatment facilities and on the samples to be collected
routinely over 18 months of ICR data gathering. The software will be used by each
PWS to report data to EPA for the duration of the ICR, and the Initial Sampling Plan
diskette is the first set of ICR data to be submitted.
2.3 Data Entry Using the ICR Water Utility Database System
Sampling location and analyte information shall be entered from the plant schematic(s)
and distribution system schematic into the ICR Water Utility Database System. The PWS
shall also enter information specified in the ICR [§141.142(a)(6)]. It is advisable to collect all
needed information on the data entry worksheets provided in the "ICR Water Utility Database
System Users' Guide" prior to actual data entry utilizing the software. The software provides
a series of internal completeness checks to assist the PWS in providing all of the information
required by the ICR [§141.142(a)(6)]. However, the software does not systematically check
sampling locations or analytical requirements which are found in the ICR [§141.142(a)], or in
Sections 5 and 6 of this manual. The Initial Sampling Plan diskette, generated by the
software, will contain all information entered into the software up to that point in time.
Each PWS must assign a unique sample location number to each sampling point
associated with a treatment plant. However, sample location numbers for one treatment
plant may be the same as those from another treatment plant. A sample location number can
be any two-digit number (01 to 99) applied to any sample location within a treatment plant, as
long as the numbers are unique. The ICR Water Utility Database System software is designed
to ensure the assignment of unique sample location numbers. If the software user discovers
that a sample location number entered into the software does not match a number shown on a
schematic, the user must change one of the numbers to ensure that they match. It is advisable
to change the number on the schematic because it is more difficult to change the number in
the software.
The ICR Water Utility Database System was developed by EPA in conjunction with the
AWWA and contains many features to aid the PWS in planning and collecting samples. It is
recommended that the utility refer to the software documentation in the "ICR Water Utility
Database System Users' Guide" and enter additional information, such as Laboratory ID
numbers, when developing the Initial Sampling Plan. Such additional information, however,
does not commit the PWS to sending samples to a particular laboratory.
More detailed information on the content of the Initial Sampling Plan, and on how to
develop an Initial Sampling Plan can be found in the "ICR Water Utility Database System
Users' Guide", and in the software itself. The software provides detailed instructions and
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user-friendly computer screens to guide the PWS data entry person through the development of
the various elements of the Initial Sampling Plan, the monthly updating of the process train
and the Monthly Sampling Plan, and the monthly data entry process.
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Anytown, USA
PWSID: OH1234567
WestWTP
East WTP
Sampling point
SDS = Simulated Distribution System
DSE = Distribution System Equivalent
Avg = Average Residence Time In the Distribution System
Max = Maximum Residence Time in the Distribution System
NOTE: Each sample to be taken quarterly and analyzed for
each of the following: WQP, DBF and Ch.
Figure 2-2. ICR Distribution System Schematic (Example)
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2.4 Initial Sampling Plan Reports
The software will allow a user to print a set of predefined reports for verification of
data that has been entered into the software. Each PWS shall generate Reports A. 1 through
A. 5 and verify that the information entered into the software from the schematics is correct
prior to submittal of the Initial Sampling Plan to EPA. Upon receipt of the Initial Sampling
Plan diskette, EPA will also print reports A.I through A.5 to assist in the sample plan review
process. Therefore, these reports do not need to be submitted to EPA because EPA will
generate its own copies from the diskette provided by the PWS. A description of these reports
is found below. Example reports for the hypothetical PWS illustrated by the schematics in
Figure 2-1 and Figure 2-2 are located in Appendix A.
• Report A. 1 - Initial Sampling Plan by Location - This report lists the samples to
be collected at each sample location, from the plant influent through the
distribution system. The user should compare this report to the sampling
schematic to ensure that all of the requisite unit processes, sample locations and
samples have been properly identified.
• Report A.2 - Design Plant Parameters - This report lists the design parameters
for the plant influent, each process train, each unit process, and the finished
water.
• Report A.3 - Design Plant Chemical Parameters - This report specifies the
types, measurement formulae, and design doses of the chemicals and
disinfectants used at every unit process in each process train.
• Report A.4 - Design Distribution System Information - This report documents
the design information for the entry point, SDS, and distribution system sample
locations.
• Report A.5 - Design Water System Information - This report-summarizes the
basic water system and treatment plant data at the start of the 18 month ICR
data collection period.
2.5 Final Design Data
A Final Design data transfer package (a diskette and summary report containing
treatment plant and process train information) must be submitted to EPA along with the last
monthly reporting package. Final Design data are similar to the Initial Sampling Plan
information, except that sampling location and analytical parameters are not included. Final
Design data should accurately reflect the design of each PWS at the end of the 18 month ICR
sampling period. Design data are important to the EPA and the water industry for they are
used in cost-benefit analyses of treatment processes hi operation at PWSs across the nation.
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Please refer to the "ICR Water Utility Database System Users' Guide" for directions on how
to prepare and submit the Final Design data transfer package to EPA.
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3.0 Treatment Study Applicability Monitoring
Each treatment plant in any PWS that meets the "population served" applicability
criteria in the ICR [§141.141 (e)(l)], which is also explained below in section 3.2 of this
manual, must conduct treatment study applicability monitoring. The purpose of this
monitoring is to determine whether the level of DBF precursors in their water will require
them to conduct percursor removal studies. Treatment plants with high levels of DBF
precursors, as determined by total organic carbon (TOC) measurements, will be required to
conduct precursor removal studies to determine the effectiveness of GAC and/or membrane
technology to remove the DBF precursors.
3.1 Applicability Monitoring Requirements
All treatment study applicability monitoring includes twelve (12) consecutive months of
TOC monitoring. In some cases treatment study applicability monitoring will include twelve
(12) consecutive months of uniform formation condition total organic halide (UFCTOX)
monitoring to demonstrate a common water resource. Treatment study applicability
monitoring will include quarterly monitoring of distribution system trihalomethanes (THM4)
and haloacetic acids (HAAS) if the PWS desires to apply to avoid the treatment study
requirement on the basis of distribution system DBFs. THM4 is the sum in micrograms per
liter of the trihalomethanes chloroform, bromodichloromethane, dibromochloromethane, and
bromoform, rounded to two significant figures. HAAS is the sum in micrograms per liter of
the haloacetic acids mono-, di-, and trichloroacetic acid; and mono-, and di-bromoacetic acid,
rounded to two significant figures.
NOTE: Uniform formation conditions (UFC) are a set of standard chlorination
conditions. Under UFC conditions, the sample is buffered to a pH of 8.0±0.2, dosed to
achieve a 24-hour free chlorine residual of 1.0+0.4 mg C12/L, and incubated headspace free
for 24+1 hours at 20.0±1.0°C. For UFCTOX, TOX samples are collected and the chlorine
residual quenched at the end of the UFC incubation period. The uniform formation conditions
procedure is described in greater detail in Part 1 of the "ICR Manual for Bench and Pilot-Scale
Treatment Studies," EPA 814-B-96-003.
Monthly monitoring for TOC, and UFCTOX if applicable, must begin no later than
three (3) months after the date of publication of the final rule in the Federal Register. If
distribution system THM4 and HAAS monitoring is to be conducted to determine treatment
study applicability, the first quarterly sample must be collected no later than six (6) months
after the date of publication of the final rule in the Federal Register. The results from all
treatment study applicability monitoring must be submitted no later than seventeen (17) months
after the date of publication of the final rule in the Federal Register. Treatment study
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applicability monitoring is independent of the Initial Sampling Plan review process and the
start of applicability monitoring is only triggered by rule promulgation (i.e., 3 months after
promulgation).
All treatment study applicability monitoring shall be conducted using the methods and
the mandatory quality control procedures contained in the "DBP/ICR Analytical Methods
Manual," EPA 814-B-96-002. Additionally, the TOC analyses shall be conducted by
laboratories that have received approval from EPA to perform TOC analysis for compliance
with this rule. Although not a requirement, it is recommended that EPA approved laboratories
also analyze the UFCTOX, THM4 and HAAS samples collected during treatment study
applicability monitoring.
3.2 Treatment Plants that Must Conduct Applicability Monitoring
3.2.1 Each PWS Serving a Population of 100,000 or More
Each public water system that serves 100,000 persons or more must conduct
monitoring at each plant that provides finished water for 100,000 persons or more,' to
determine whether they are required to conduct precursor removal studies at any of
these plants (Treatment Plant Categories A & B in the ICR [§141 . 141(b)]). If a PWS
serves 100,000 persons or more, but does not have any one plant that treats water for
100,000 persons or more, the applicability monitoring must be conducted at the largest
plant operated by the PWS (Treatment Plant Categories C & D hi the ICR
Plants treating surface water or ground water under the direct influence of
surface water are to monitor treatment plant influent (water that represents the water
quality challenge to a particular plant) for TOC to determine whether precursor
removal studies are required.
Plants treating only ground water shall monitor finished water for TOC to
determine whether precursor removal studies are required. As defined in the ICR
[§141.140], finished water is water that does not undergo further treatment by a
treatment plant other than maintenance of a disinfectant residual.
3.2.2 Each PWS Using Ground Water and Serving 50,000 to 99,999 Persons
Systems serving from 50,000 persons to 99,999 persons with at least 50,000
persons served by ground water shall conduct the treatment study applicability
monitoring at the largest ground water plant owned by the system (Treatment Plant
Category G hi the ICR [§141.141(b)]). For purposes of the ICR, an example of a
ground water plant may include one composed of multiple wells with no treatment
other than chlorination, or it may be a central treatment plant (such as a softening
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plant) treating water from one or more wells. For multiple wells with treatment on a
single aquifer and without a central point of entry to the distribution system, only one
(1) well from each aquifer will be required to be sampled.
Plants treating only ground water shall monitor finished water for TOC to
determine whether precursor removal studies are required. As defined in the ICR
[§141.140], finished water is water that does not undergo further treatment by a
treatment plant other than maintenance of a disinfectant residual.
3.3 TOC Monitoring Requirement
All treatment plants described in the preceding section shall conduct TOC monitoring
monthly for twelve (12) months. These treatment plants are not required to conduct precursor
removal studies if:
• The average TOC value from the 12 consecutive months of sampling is less
than 4.0 mg/L in the influent to a plant treating surface water or ground water
under the direct influence of surface water.
• The average TOC value from the 12 consecutive months of sampling is less
than 2.0 mg/L hi the finished water from a plant treating only ground water.
3.4 DBF Monitoring Option
A treatment plant may also determine treatment study applicability based on the level of
DBFs formed in the distribution system. Treatment plants that use only chlorine as both the
primary and residual disinfectant and have, as an annual average of four quarterly averages,
levels of THM4 less than 40 Mg/L and levels of HAAS less than 30 ^g/L need not conduct
treatment studies. Quarterly averages are the arithmetic averages of the four distribution
system samples collected at the following points: one (1) sample location representative of the
maximum residence time hi the distribution system for the treatment plant and three (3)
sample locations representative of the average residence time in the distribution system for
the treatment plant.
3.5 Monitoring Required to Demonstrate a Common Source
Plants that are required to conduct individual precursor removal studies, based on the
results of their applicability monitoring, can apply for an alternative to the individual study if:
• They demonstrate a common water resource with at least one other plant
conducting a study on that source [§141.141(e)(5)], and contribute to a
Disinfection Byproducts/Microbial Research Fund (buyout option).
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• They conduct a joint study with other treatment plant(s) - if they have similar
treatment trains and treat water from a common water resource
[§141.141(e)(4)]. (Similar treatment plants, for example, would be plants that
are all softening plants, all conventional plants, etc.)
Monthly determination of total organic halides (TOX) formed under uniform formation
conditions (UFCTOX) may be required if treatment plants intend to qualify for common
source designation under certain conditions described as follows:
• A common water resource for all types of surface water resources, including
ground waters under the direct influence, requires the mean treatment plant
influent TOC or UFCTOX (depending on the surface water type and the
distance between intakes) of each of the cooperating treatment plants to be
within 10% of the average of the mean treatment plant influent TOCs or
UFCTOXs of all the cooperating plants.
• A common water resource for all types of ground water resources requires the
mean treatment plant finished water TOC of each of the cooperating plants to be
within 10% of the average of the mean TOCs of all the cooperating plants.
The mean is calculated from the twelve (12) consecutive months of monitoring to
determine treatment study applicability as described previously.
3.6 Reporting Requirements
A form for reporting the results from treatment study applicability monitoring is
included in Part 1 of the "ICR Manual for Bench and Pilot-Scale Treatment Studies," EPA
814-B-96-003. Monitoring results are to be submitted on this form no later than seventeen
(17) months after the date of promulgation of the ICR to the following address:
USEPA, Technical Support Division
ICR Precursor Removal Studies Coordinator
26 W. Martin Luther King Drive
Cincinnati, OH 45268
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4.0 General Sampling Requirements
Each PWS is to monitor its influent, water treatment plant process streams, and
distribution system sampling points for a period of eighteen (18) consecutive months as
specified in the ICR [§141.141(c) and 141.141(d)]. Furthermore, each PWS is to monitor
monthly for eighteen (18) consecutive months at each treatment plant (see Section 5 of this
manual for monitoring requirements). The first month of monitoring will be designated
sampling period 01, and subsequent monthly periods will be consecutively numbered up to
sampling period 18. ICR monitoring is not to start until EPA has reviewed and provided
written comments back to the PWS regarding the ICR Initial Sampling Plan.
The main steps involved in ICR sampling following receipt of the Initial Sampling Plan
EPA review letter are listed below. These steps will be repeated each month during the course
of the 18 month monitoring period.
Develop a Monthly Sampling Plan
Coordinate with Approved Laboratories
Collect and Ship Samples
Record Appropriate Information
Verify Monthly Sampling Information
Report Monthly Sampling Information to EPA
4.1 Develop a Monthly Sampling Plan
The Monthly Sampling Plan is a tool which is to be used by field operators/sample
collectors and is not to be submitted to EPA. The Monthly Sampling Plan is developed using
the ICR Water Utility Database System by copying information over from the Initial Sampling
Plan (or a previously developed Monthly Sampling Plan). It can be a useful tool for the
sample collectors because it provides them with a list of the treatment information they will
need to gamer and the samples they will collect for the sampling period. It can also be used as
a planning aid for many of the other activities associated with sample collection such as
arranging for analyses from ICR approved labs. The Initial Sampling Plan, from which the
first Monthly Sampling Plan is developed, contains design data for the treatment plant,
however, the Monthly Sampling Plan must reflect the operating conditions hi the plant at the
time of sampling. Therefore, the Monthly Sampling Plan must be altered as necessary to
reflect changing conditions at the water system. Data copied from the Initial Sampling Plan
may require updating to reflect the current operating conditions hi the plant and the samples
which must be collected for the current sampling period. Reports can then be generated from
the Monthly Sampling Plan that can be used by the sample collectors. The Monthly Sampling
Plan must include all quarterly samples (samples required to be collected four times a year)
that happen to fall in the particular monthly sampling period.
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NOTE: Sampling locations, once defined in the Initial Sampling Plan, cannot be
changed. Once a sample location number is established, it cannot be changed or reassigned to
a different location. However, because of potential variations in plant operating conditions
during a particular month, samples at given sampling locations may not be required for that
monthly sampling period, and the samples for a particular location can be deleted for any
particular month. New sample locations can also be added. Therefore, variations in plant
operating conditions, such as a change hi the type of disinfectant applied, can be reflected in
the Monthly Sampling Plan. For example, the Monthly Sampling Plan must reflect a change
from the application of chloramines at a treatment plant to the application of chlorine. A
change in the supplier or product line for the same type of disinfectant does not need to be
reflected in the Monthly Sampling Plan .
4.2 Coordinate With ICR Approved Laboratories
Each PWS should contact its laboratories as soon as possible after determining what
analyses are required and when the first ICR sample collection will occur. Early
communication with the laboratories can help ensure the PWS that:
• Laboratories have the required ICR lab approval.
• Laboratories have sufficient capacity to analyze the samples hi the required
tune-frame.
• Proper sample collection and handling procedures are followed.
4.2.1 ICR Laboratory Approval
ICR laboratory approval is granted on a method by method basis, and must be
obtained by a laboratory prior to performing analyses on ICR samples. EPA will also
evaluate laboratory performance throughout the 18-month monitoring period. Details
on the initial approval process and the on-going evaluation during the 18-month period
are described in the DBP/ICR Analytical Methods Manual, EPA 814-B-96-002.
A PWS must be aware of the approval status of the laboratories performing its
analytical work. Monitoring data generated by laboratories that are not ICR approved
will be deleted from the ICR Federal Database.
Laboratories that have been approved by EPA to conduct ICR analyses will be
identified on a list which will be periodically updated. This list will be available from
the EPA Safe Drinking Water Hotline (see section 1.5 of this manual) for the duration
of the ICR 18-month sampling period. Furthermore, if a laboratory loses its approval,
EPA will attempt to notify each PWS which may be affected by such action.
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4.2.2 Laboratory Capacity
Many of the samples that a PWS is required to collect for the ICR must be
analyzed within a relatively short time-frame in order to ensure that sample integrity is
maintained between sample collection and analysis. Laboratories have a finite capacity
to analyze samples and must therefore plan the work load in order to ensure that they
can provide sample analyses within specified periods of time. If the laboratory is not
routinely performing the necessary analysis, it may require several days of preparatory
work before it can perform a requested analysis. Therefore, it is in the best interest of
the PWS to contact its laboratories and establish a sample analysis schedule. This will
help prevent the loss of data due to samples not being analyzed according to specified
holding times. Data from samples that were analyzed after the specified holding time
will not be included in the ICR Federal Database.
4.2.3 Sample Collection and Handling
Analytical methods generally describe proper sample collection techniques and
requirements for storing samples after collection. Since laboratories must be familiar
with the methods, they can be very helpful to PWS personnel who are responsible for
the actual sample collection. Some laboratories provide their clients with sample
collection kits which include sample bottles containing the necessary dechlorinating
agents and/or preservatives, sample collection instructions, gel packs for keeping the
samples cold during shipment, etc. If the PWS does not desire this assistance, then it
is recommended that the PWS check with the laboratory to be sure the proper
containers, etc. are being used. Samples that are collected or stored improperly must
not be analyzed. ICR approved laboratories have been directed to reject all samples
that do not conform to the specifications and to notify the PWS that the samples are not
being analyzed. Data resulting from the analysis of improperly collected or stored
samples will not be accepted into the ICR Federal Database.
4.3 Collect And Ship Samples
The exact samples that need to be collected at a specific location .can be
determined through use of the ICR Water Utility Database System. This software
allows for the development of reports such as Report B.I, Monthly Sampling Plan by
Location (also lists the quarterly samples). An example of Report B. 1 is included in
Appendix B, and was generated for the hypothetical PWS illustrated in the schematics
in Figures 2-1 and 2-2.
4.3.1 Monthly ICR Samples
Ideally all the samples representing a particular monthly sampling period can be
collected within a working day, so that both the plant operating data and the collected
4-3
-------
samples are reflective of the treatment conditions within the plant at the time of
sampling. However, this may not be practical in all cases, especially when sampling
must be coordinated with several water plants and laboratories. Therefore, all samples
representing an individual sampling period shall be collected within a three-day (72
hour) time period. Furthermore, samples are to be collected when the plant operating
mode and water quality conditions are representative of that particular sampling period.
Similarly, it is desirable to have monthly samples collected approximately one month
apart. This may not always be practical due to abnormal conditions within the water
system or scheduling logistics with the laboratories performing the analyses.
Therefore, consecutive monthly (72 hour sampling period) samples shall be collected
with at least 14 days tune between the completion of one sampling period and the
subsequent initiation of the next sampling period. Examples of monthly ICR samples
(analyte group codes) are: TOC, UV254, WQP, and microbiological influent samples
(PROT, VIRU, BACT, COLI). The analyte group names associated with these codes
are listed in Table 4-1.
4.3.2 Quarterly ICR Samples
A PWS shall collect 6 quarterly samples during 18 months of ICR monitoring.
Ideally, quarterly samples will be collected approximately three (3) months apart.
Again, this may not always be practical due to unusual conditions in the water system
or for a variety of other reasons. Therefore, consecutive quarterly samples shall be
collected with at least two months (and not more than four months) between sampling
periods. For example, if quarterly samples were collected on May 15,1997, the next
set of quarterly samples must not be collected before July 15, 1997 nor later than
September 15, 1997. Examples of quarterly ICR samples (analyte group codes) are:
THM/HAN, HAA, CH, and TOX. The analyte group names associated with these
codes are listed in Table 4-1.
4.3.3 Sample Identification Labels
Sample identification labels, whether printed, or hand-written (in waterproof
ink) must be securely affixed to all sample bottles and/or vials. The labels must
contain the ICR sample identification number.
NOTE: Each water sample collected during the ICR monitoring period must be
assigned a unique sample identification number. This number will be assigned by
the data entry software when the sampling points are defined and will uniquely define
the sample by plant, date, location, and analyte. For example, a typical sample
identification number might look something like this:
4-4
-------
239049707HAA
where,
• The first three digits, 239, indicate the ICR Treatment Plant ID Number,
• The next four digits, 0497, indicate the month and year (i.e., April,
1997) that the sample was collected,
• The next two digits, 07, indicate the sampling location number (for
example, 07 might indicate a sample obtained after filtration), and
• The last three characters, HAA, indicate the analyte group (Haloacetic
acids)
NOTE: The ICR Plant Identification Number is a unique three digit number
assigned by EPA to each water treatment plant participating in the ICR. This number
will be assigned by EPA upon receipt of the PWS response to the notification letter
(see Section 1.3 of this manual).
NOTE: In the above example, the analyte group HAA is only sampled for on a
quarterly basis. The complete list of ICR Analyte Group Codes is shown below:
Table 4-1. ICR Analyte Group/Codes
Analyte Group
Code
ALD1
BACT
Br
CL2
CLO2
CNC11
EPABrOS1
Analyte Group
Name
Aldehydes
Bacteria
Bromide
Chlorine Residuals
Chlorine Dioxide
Residual
Cyanogen Chloride
Low Level Bromate
Analyte Group
Code
AOC*
BDOC*
CH
CLD
CLOST
COLI
HAA
Analyte Group
Name
Assimilable Organic
Carbon
Biodegradable
Organic Carbon
Chloral Hydrate
Chlorine Demand
Clostridium*
Coliphage*
Haloacetic Acids
4-5
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Analyte Group
Code
HAN
IONC
O3
PROT
THM/CH
TOG
UV254
WQP
Analyte Group
Name
Haloacetonitriles ,
Haloketones and
Chloropicrin
Bromate, Chlorite,
Chlorate
Ozone Residual
Protozoan
Trihalomethanes/
Chloral Hydrate
Total Organic Carbon
Ultraviolet (UV)
Absorbance at 254
nanometers (nm)
Water Quality
Parameters
Analyte Group
Code
HYPO
NH3
PART
THM
THM/HAN
TOX
VIRU
Analyte Group
Name
Hypochlorite
Analyses
Ammonia
Particle Size Count
Trihalomethanes
Trihalomethanes/
Haloacetonitriles ,
Haloketones and
Chloropicrin
Total Organic Halide
Virus
1. ALD, CNC1, EPABrOS are collected by the PWS and sent to EPA for analysis.
* The analyses represented by these analyte groups are optional, i.e., not required for monitoring as specified in the
ICR. Analyte groups representing optional analyses are functional in the software and can be used if needed.
Additional information that water systems or laboratories should find desirable to put
on the labels includes:
• space hi which to write sample collection date and time (with AM and PM
designations)
• sample collection location
• space in which to write sampler's name or initials.
• dechlorinating agent and/or preservative contained in the bottle
Before collecting the water sample, the sampler should complete the information (if
required) on the sample identification label. Waterproof ink should be used. Note that if the
bottle is filled first, condensation on the surface of the bottle may make it very difficult to
write on the label.
4-6
-------
4.3.4 Sample Containers
*
The result of any laboratory analysis is only as good as the sample collected.
The objective of sampling is to obtain a sample that "represents" the true character of
the water being tested. The ICR samples are no exception. To achieve this goal, ICR
samples should be collected at the proper location, in the right container, and labeled
properly, using consistent methods. This representative sample must also receive
proper handling (preservation, transport, storage, etc.) after it has been collected, to
ensure that its composition will not be altered before being analyzed.
In order to ensure the integrity of the sample, analytical methods often specify
or provide guidance concerning sample containers. The PWS should use containers
that are consistent with the information provided in the methods. A summary of the
methods information concerning appropriate containers is given in Table 4-2.
NOTE: Laboratories often take additional precautions when selecting sample
containers. For example, amber glass is often used when collecting samples for the
organic DBFs because it protects the samples from light.
4.3.5 Sample Preservatives and Dechlorinating Agents
To ensure that the analytes of interest do not deteriorate between sample
collection and sample analysis, preservatives must be added to certain samples either
prior to or immediately following sample collection. Dechlorinating agents are also
added to certain samples prior to, during, or immediately following sample collection
to eliminate free residual chlorine. (Disinfection byproducts will continue to form in
samples that contain a free residual chlorine. Therefore, DBF concentrations can
increase during the tune between sample collection and analysis, and won't be
representative of concentrations at the time of sampling. Therefore, the residual
disinfectant must be eliminated to obtain representative results). Requirements for
adding preservatives and dechlorinating agents to samples are defined in the analytical
methods and are summarized in Table 4-2. Samples collected for ICR analyses must
contain appropriate preservatives and/or dechlorinating agents consistent with those
described in this table.
NOTE: The analytical methods vary in their recommended quantities of
dechlorinating agent. However, recommended amounts are provided as guidance for
dechlorinating a "typical" sample. The actual requirement is to dechlorinate the
sample, and deviations from specified amounts of dechlorinating agents may be needed
to achieve dechlorination of an "atypical" sample. The laboratory should be able to
assist the PWS in determining the quantity of dechlorinating agent needed for its
samples.
4-7
-------
The laboratory must measure the pH of certain samples (TOC, TOX, CH,
HAN, THM/HAN, and THM/CH) before it begins the analysis. If the pH is not in the
range specified in Table 4-2, the sample was not collected or stored properly and must
not be analyzed. The laboratory must report this situation to the PWS, so that the
mistake is not repeated when samples are collected during the next sampling period. If
the problem is determined within the three day sampling window for a sampling
period, it may be possible to re-sample to prevent loss of data.
Table 4-2. Sample Collection Containers and Preservatives/Dechlorinating Agents
Annlyte
Group
Code
ALD
AOC*
BACT
Analytes in Group
(Abbreviation for Analyte)
Aldehydes:
Acetaldehyde (Acetald)
Butanal
Formaldehyde (Formald)
Glyoxal
Methyl glyoxal (Methyl Gly)
Pcntanal
Propanal
Additional aldehydes that EPA may
include in the analysis:
Benzaldehyde (Benzald)
Decanal
Hexanal
Heptanal
Nonanal
Octanal
Assimilable Organic Carbon (AOC)
Mean PI 7
MeanNOX
P 17 AOC
NOXAOC
Total AOC
Incubation Temperature
Incubation Time
Bacteria:
Total coliform
Fecal coliform
E. coli
Bottle
Material
Glass
Borosilicate
glass
Sterile,
nontoxic:
- glass, or
- rigid plastic
or
- other
approp.
material
Cap/Septa
Material
Teflon lined
polypropylene
screw caps
Teflon lined
silicone septa
Leak-proof
lid;
Non-toxic
liner
Preservative/Dechlorinating
Agent
(Recommended amount)
Dechlor: 0.1mLofa20%
NH4C1 or (NH4)2SO4 soln/ 40
mL sample. (0.5 mg NH4C1 or
(NH4)2SO4/ mL of sample)
When an ozone residual is
present: O.lmLofa 0.3% KI
soln/ 40 mL vial (7.5 A
-------
Analyte
Group
Code
BDOC*
Br
CH
CL2
CLD
CLO2
CLOST*
CNCL
COLI*
Analytes in Group
(Abbreviation for Analyte)
Biodegradable Organic Carbon
(BDOC)
TOC before BDOC Reactor
DOC before BDOC Reactor
DOC after BDOC Reactor
Incubation Time
Bromide ion (Br-)
Chloral hydrate (CH)
Chlorine residuals:
Free residual chlorine (Free C12)
Total residual chlorine (Total C12)
Chlorine demand (C12 Demand)
Chlorine dose
Free residual chlorine
pH
Contact time
Chlorine dioxide residual (C1O2)
C. perfringens
Cyanogen chloride (CNC1)
Coliphage
Somatic coliphage
Male-specific coliphage
Bottle
Material
Acid cleaned
glass
Plastic or glass
Glass
Field analysis
Glass
Field analysis
Sterile,
nontoxic:
- glass, or
- rigid plastic
or
- other
approp.
material
Glass
Filter
cartridge, pos.
charged:
1MDS,
Virosorb
Cap/Septa
Material
Teflon lined
silicone septa
No specified
material
Teflon lined
septum
Not
Applicable
Not
Applicable
Not
Applicable
Leak-proof
lid;
Non-toxic
liner
Teflon lined
septum
Cartridge
Housing:
Cuno
#APllTor
equivalent
Preser vati ve/Dech lor in ati n g
Agent
(Recommended amount)
Dechlor: If a chlorine residual
is present, add 0.5 mL of a
freshly prepared 3% Na2S2O3
soln/ 500 mL sample (0.03 mg
Na2S2O3/ mL of sample)
None specified
Preserve & Dechlor: 1 g
phosphate buffer & Na2SO3
mixture 760 mL sample
(mixture consists of 1 part
Na2HPO4, 99 parts KH2P04 , &
0.6 parts Na2SO3. lg/60mL
results in apH of 4.5-5.5 and
0. 1 mg Na2SO3/ mL of sample.)
None
None
None
Dechlor: If a chlorine residual
is present, add 0.1 mL of a
freshly prepared 10% Na2S2O3
soln/ 120 mL sample
Dechlor: 0. 1 mg ascorbic acid /
mL of sample
pH adj: Inject 0.1, 1.0, or 5 M
HC1 at appropriate flow rate to
attain a sample pH of 6.5 - 7.5
Dechlor: If a chlorine residual is
present, inject sterile, freshly
prepared 2% Na2SO3 at a rate of
2.5mL7Liter of sample.
4-9
-------
Analytc
Group
Code
EPABrOS
IIAA
HAN
HYPO
Analytes in Group
(Abbreviation for Analyte)
Low level bromate (LowBrOS)
Haloacetic acids (HAAs):
Bromochloroacetic acid (BCAA)
Dibromoacetic acid (DBAA)
Dichloroacetic acid (DCAA)
Monobromoacetic acid (MBAA)
Monochloroacetic acid (MCAA)
Trichloroacetic acid (TCAA)
Additional acids that may be included
in analysis:
Bromodichloroacetic acid (BDCAA)
Chlorodibromoacetic acid (CDBAA)
Tribromoacetic acid (TBAA)
Chloropicrin (CP)
Haloacetonitriles (HANs):
Bromochloroacetonitrile (BCAN)
Dibromoacetonitrile (DBAN)
Dichloroacetonitrile (DCAN)
Trichloroacetonitrile (TCAN)
Haloketones (HKs):
1,1-Dichloropropanone (DCP)
1,1,1-Trichloropropanone (TCP)
Hypochlorite Stock:
Chlorate (C1O3)
Free residual chlorine
PH
Temperature
Bottle
Material
Plastic or glass
Glass
Glass
See individual
analyses
Cap/Septa
Material
No specified
material
Teflon lined
septum
Teflon lined
septum
See individual
analyses
.'
Preservative/Dechlorinating
Agent
(Recommended amount)
If sample contains an ozone
residual, add 0.05 jJL
ethylenediamine (EDA)/ mL of
sample
If sample contains a C1O2
residual, purge the sample
(approx 10-15 min) with an
inert gas (N2 or Ar) to remove
C1O2 and then add 0.05 fjL
EDA/ mL of sample.
The addition of EDA to all
samples is recommended.
Dechlor:
0. 1 mg NH4C1/ mL of sample
for Methods 552.1 & 552.2;
65 mgNH4Cl/ 40-60 mL
sample for Method 6251 B.
Preserve & Dechlor: 1 g
phosphate buffer & NH4C1
mixture /60 mL sample
(mixture consists of 1 part
NajHPO,,, 99 parts KH2PO4, &
0.6 parts NH4C1. lg/60mL
results in a pH of 4.5-5.5 and
0.1 mgNH4CI/mL of sample.)
See individual analyses
4-10
-------
Analyte
Group
Code
IONC
NH3
03
PART
PROT
Analytes in Group
(Abbreviation for Analyte)
Bromate Ion (BrO3)
Chlorate Ion (C1O3)
Chlorite Ion (C1O2)
Ammonia
Ozone residual
Particle Size Count:
3-5 urn
5-7 urn
7-10 urn
10-1 5 urn
>15um
Giardia
Empty cysts
Cysts with amorphous structures
Cysts with 1 internal structure
Cysts with >1 internal structure
Total count
Cryptosporidium
Empty oocysts
Oocysts with amorphous structures
Oocysts with >1 sporozite
Total count
Bottle
Material
Plastic or glass
Glass or
plastic
Field Analysis
Supercleaned
borosilicate
glass
Filter:
25.4 cm long,
1 um nominal
porosity
polypropylene
cartridge
Cap/Septa
Material
No specified
material
No specified
material
Not
Applicable
No specified
material
Filter Holder:
Commercial
LT-10 or
Filterite
LMO10U-3/4
Preservative/Dechlorinating
Agent
(Recommended amount)
If sample contains an ozone
residual, add 0.05 mg
ethylenediamine (EDA)/ mL of
sample
If sample contains a C1O2
residual, purge the sample
(approx 10-15 min) with an
inert gas (N2 or Ar) to remove
C1O2 and then add 0.05 mg
EDA/ mL of sample.
The addition of EDA to all
samples, except the
hypochlorite solution, is
recommended. The laboratory
should add EDA to the
hypochlorite sample after it is
diluted for analysis.
Preserve: If immediate analysis
is not possible, acidify with
H2SO4 to pH to <2.
None
None
Dechlor: If a chlorine residual is
present, inject sterile, freshly
prepared 2% Na2SO3 at a rate of
250mL/100 Liter of sample.
4-11
-------
Analytc
Group
Code
SDS1
Sample
Location
THM
THM/CH
Analytes in Group
(Abbreviation for Analyte)
Individual Analyte Groups to be
analyzed from this sample after
incubation include:
THM
HAA
HAN
CH
TOX
CL2
WQP
Incubation time is also reported.
Trihalomethanes (THMs):
Bromodichloromethane (BDCM)
Bromoform (CHBrS)
Chloroform (CHC13)
Dibromochloromethane (DBCM)
Chloral hydrate (CH)
Trihalomethanes (THMs):
Bromodichloromethane (BDCM)
Bromoform (CHBrS)
Chloroform (CHC13)
Dibromochloromethane (DBCM)
Bottle
Material
Glass during
incubation
See individual
analyses for
after
incubation
Glass
Glass
Cap/Septa
Material
Teflon lined
septum during
incubation
See individual
analyses for
after
incubation
Teflon lined
septum
Teflon lined
septum
Preservative/Dechlorinating
Agent
(Recommended amount)
None during incubation.
After incubation, transfer to
sample bottles containing
preservatives/dechlorinating
agents appropriate for the
individual analyses (See
individual analyses for
recommendations)
Dechlor:
For 502.2 & 524.2:
1. 3 mg Na2S2O3/40 mL sample
or
2. 3 mg Na2S2O3/40 mL sample
and immediate acidification
using HC1 to pH < 2 or
3. 25 mg ascorbic acid/40 mL
sample and immediate
acidification using HC1 to
pH<2.
(Note: Samples must be
dechlorinated prior to
acidification)
For 551:
0.1mgNa2SO3 or 0.1 mg
Na2S2O3 or 0.1 mgNH4Cl/mL
of sample.
For 551.1:
Preserve & Dechlor: 1 g
phosphate buffer & NH4C1 or
NajSOs mixture /60 mL sample
(mixture consists of 1 part
Na2HPO4, 99 parts KH2PO4, &
0.6 parts NH4C1 or Na2SO3.
lg/60 mL results in a pH of 4.5-
5.5and0.1mgNH4Clor
Na2SO3 / mL of sample.)
Preserve & Dechlor: 1 g
phosphate buffer & Na^C^
mixture /60 mL sample
(mixture consists of 1 part
Na2HPO4, 99 parts KH2PO4, &
0.6 parts NajSOj. lg/60 mL
results in a pH of 4.5-5.5 and
0. 1 mg Na2SO3/ mL of sample.)
4-12
-------
Analyte
Group
Code
THM/HAN
TOC
TOX
UV254
VIRU
WQP
Analytes in Group
(Abbreviation for Analyte)
Chloropicrin (CP)
Haloacetonitriles (HANs):
Bromochloroacetonitrile (SCAN)
Dibromoacetonitrile (DBAN)
Dichloroacetonitrile (DCAN)
Trichloroacetonitrile (TCAN)
Haloketones (HKs):
1,1-Dichloropropanone (DCP)
1,1,1-Trichloropropanone (TCP)
Trihalomethanes (THMs):
Bromodichloromethane (BDCM)
Bromofonn (CHBr3)
Chloroform (CHC13)
Dibromochloromethane (DBCM)
Total organic carbon (TOC)
Total organic halide (TOX)
Ultraviolet absorbing organics at 254
nm (UV254)
Total Culturable Virus
Water Quality Parameters:
Alkalinity (Alk)
Water Quality Parameters:
Calcium Hardness
Total Hardness
Bottle
Material
Glass
Amber glass
bottles
Amber glass
bottles
Glass
(Amber
preferred)
Filter
cartridge, pos.
charged:
1MDS,
Virosorb
Polyethylene
or borosilicate
glass
Polypropylene
or linear
polyethylene
or borosilicate
glass
Cap/Septa
Material
Teflon lined
septum
Teflon lined
septum
Teflon lined
septum
Teflon lined
septum
Cartridge
Housing:
Cuno#APllT
or equivalent
No
specifications
Polyethylene
cap
Preservative/Dechlorinating
Agent
(Recommended amount)
Preserve & Dechlor: 1 g
phosphate buffer & NH4C1
mixture 760 mL sample
(mixture consists of 1 part
Na2HPO4, 99 parts KH2PO4 , &
0.6 parts NH4C1. lg/60mL
results in a pH of 4.5-5.5 and
0.1 mg NH4C1/ mL of sample.)
Preserve: Adjust to pH z 2
using phosphoric or sulfuric
acid (or alternate acid if
recommended by the instrument
manufacturer).
Dechlor: 5 mg Na2SO3 /mL of
sample. (Use crystalline
Na2SO3)
Preserve: Aqidify with nitric or
sulfuric acid to pH <.1.
Sample must be dechlorinated
prior to acid addition.
None
pH adj: Inject 0.1, 1.0, or 5 M
HC1 at appropriate flow rate to
attain a sample pH of 6.5 - 7.5
Dechlor: If a chlorine residual
is present, inject sterile, freshly
prepared 2% Na2SO3 at a rate of
2.5mL/Liter of sample.
None
Preserve: Acidify with nitric
acid(l:l)topH<2
4-13
-------
Analyte
Group
Code
WQP
Analytes in Group
(Abbreviation for Analyte)
Water Quality Parameters:
pH
Water Quality Parameters:
Temperature
Water Quality Parameters:
Turbidity
Bottle
Material
Field Analysis
Field Analysis
Field Analysis
Cap/Septa
Material
Not applicable
Not applicable
Not applicable
Preservative/Dechlorinating
Agent
(Recommended amount)
None
None
None
* Optional sample; not a requirement of the ICR
I. SDS is not an ICR analyte group code. It is included here to provide guidance on collection and handling of the sample
collected at the SDS sample location.
4.3.6 General Sampling Procedures
In order to ensure that representative samples are collected, a few general
sampling techniques must be observed (only the first item applies to samples for
protozoan and virus analyses, because they are collected by passing large volumes of
water through filters):
• The sampling line must be flushed immediately prior to sample collection, so
that stagnant water in the line is not collected.
• If the sample bottle contains preservatives or dechlorinating agents, care must
be taken to not flush them out of the bottle.
• Bottles should not be overflowed.
• The sample should be shaken after filling and capping the container in order to
dissolve preservatives and/or dechlorinating agents.
• In order to avoid breaking the sample caps, they must not be over-tightened.
Sampling techniques must also take into account the general characteristics of
the components) to be measured. For example, if the component is volatile, then care
must be taken to not aerate the sample as the bottle is filled. The bottle must be
completely filled (head-space-free), so that the component does not volatilize into the
air remaining in the bottle.
Detailed sampling guidance may be found hi the analytical methods since they
generally provide instructions concerning proper sample collection techniques. A
summary of the method specific information concerning appropriate sample collection
techniques is also provided in Table 4-3 of this manual. Each PWS must use
techniques that are consistent with the information provided in this table. In addition,
4-14
-------
many laboratories provide their clients with sample collection containers which have
been prepared with the proper preservatives/dechlorinating agents. Specific sampling
instructions are typically provided with the sampling containers.
The ICR does not require the PWS to collect duplicate samples, but the PWS
should work with the laboratory to ensure that enough sample volume is collected to
allow a backup analysis if something happens to the first analysis. This will minimize
the loss of data due to a QC failure at the laboratory. The laboratories are required to
perform duplicate analyses on all TOC, TOX and UV254 samples. These duplicates are
laboratory duplicates which means that two analyses are performed on water from the
same sample bottle. Laboratories are also required to analyze a minimum of 5% of
several other sample types in duplicate and as fortified samples. The laboratory may
ask the PWS to fill a second bottle in order to meet this requirement for some types of
analyses. (If two bottles are filled for the same analysis, they must be assigned the
same sample ID number.) More information identifying the analyses which are subject
to requirements of duplicate and fortified analyses is contained in the DBP/ICR
Analytical Methods Manual EPA 814-B-96-002.
4.3.7 Sample Handling, Packaging, and Shipping
In order to maintain the integrity of the samples after they are collected,
samples must be stored under conditions that won't change the analyte concentrations.
The analytical methods usually provide specific instructions both on storage conditions
and length of time the sample is stable under those conditions. A summary of these
method recommendations are listed in Table 4-3.
NOTE: Table 4-3 contains information identifying the maximum holding
times for alkalinity, UV254, aldehydes, and cyanogen chloride as "ASAP" followed
by the maximum number of days allowable under the ICR. However, since sample
stability is matrix-site dependent, it is preferable to analyze'these parameters before the
maximum tunes. This will ensure that the data obtained for these analytes are
representative of the actual conditions at the treatment plant. Until more effective
methods of preservation are developed for these four parameters, rapid analysis is the
best means of obtaining representative data.
Many of the ICR analytical methods require that the samples be kept cold after
collection. The methods' specify temperatures ranging from 4°C to less than 10°C. To
ensure that samples are maintained properly, they should be packed in ice or frozen gel
packs immediately after collection for transporting from the field back to the PWS. At
the PWS, the samples should be refrigerated if they are not immediately packaged for
shipment to the lab. Prior to shipping to an approved laboratory, samples should be
carefully packaged in an insulated shipping container (Styrofpam, or commercial ice
chest), and packed with sufficient ice or frozen gel packs to ensure that they will be
4-15
-------
received at the laboratory in a chilled condition. The samples should also be protected
from freezing.
A lack of visible ice or gel packs that have completely thawed when the samples
arrive at the laboratory indicates that the samples were not properly packed for
shipment. The integrity of samples that are not received in a chilled condition would
be questionable hi such cases, so these samples must not be analyzed. The laboratory
must notify the PWS as soon as possible if this occurs. The samples should be
collected again, if the three day sampling window for the sampling period has not
expired.
The maximum holding time for samples is listed hi Table 4-3. Sample shipping
decisions must reflect sample holding tunes. It may be necessary to ship some samples
to the laboratory via overnight carrier, whereas other samples cannot even be held
overnight, i.e., source water BACT samples.
NOTE: Ice should not be treated as an effective packing material because as
the ice melts, the bottles may be able to move freely within the package, potentially
breaking during shipment. Instead, wrap the bottles individually in "bubblepack" or
some other protective material before packing them in ice.
Table 4-3. Sample Collection, Handling, and Storage
Analytc
Group Code
ALD
AOC*
BACT
Analytical
Method
SM 6252 B
SM 9217 B
SM 9060A&B
or
ICR Microbial
Laboratory
Manual
(Section X)
Storage
Temp
Keep at 4°C
Keep below
10°C
Keep below
1-4°C
Max
Hold
Time
ASAP1;
not to exceed
2 Days
24Hrs
Up to 72 hrs.
if sample is
pasteurized in
the sealed vial
8 Hrs.
Special Sample Collection Guidelines
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free.
Flush & disinfect sample ports and use
aseptic techniques to avoid contamination.
Keep sample bottle closed until it is to be
filled. Fill container without rinsing and
replace cap immediately. Leave at least
2.5 cm air space at top of bottle to
facilitate mixing.
Flush & disinfect sample ports and use
aseptic techniques to avoid contamination.
Keep sterile sample bottle closed until it is
to be filled. Fill container without rinsing
and replace cap immediately. Leave at
least 2.5 cm air space at top of bottle to
facilitate mixing.
4-16
-------
-Analyte
Group Code
BDOC*
Br
CH
CL2
CLD
CLO2
CLOST*
CNCL
COLI*
Analytical
Method
Servais et al,
1987
Joretetal, 1988
Mogren et al,
1990
Frias et al, 1992
Summers, 1993
EPA 300.0
EPA 551,1
Free Chlorine2:
SM 4500-C1 D
SM 4500-C1 F
SM 4500-C1 G
SM 4500-C1 H
Total Chlorine2:
SM 4500-C1 D
SM 4500-C1 E
SM 4500-C1 F
SM 4500-C1 G
SM 4500-C1 1
SM 2350 B
SM 4500-C1O2 C
SM 4500-C102 D
SM 4500-C1O2 E
ICR Microbial
Laboratory
Manual
(Section XI)
Modified EPA
524.2
ICR Microbial
Laboratory
Manual
(Section IX)
Storage
Temp
Keep at 4°C
None
specified
Keep at 4°C
Field
Analysis
Perform test
on a freshly
collected
sample.
Field
Analysis
Keep below
10°C
Keep at 4°C
Keep at 4°C
Max
Hold
Time
2 Days
28 Days
14 Days
Not applicable
Do not store
sample.
Mot applicable
8Hrs.
ASAP1;
not to exceed
2 Days
72 Hours
(See VIRU)
Special Sample Collection Guidelines
None specified
None specifed
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free
Do not expose samples to sunlight or
bright light. Avoid excessive agitation.
Analyze immediately after sampling, do
not store samples.
None specified
Do not expose samples to sunlight or
bright light. Do not aerate to mix. Analyze
immediately after sampling, do not store
samples.
Flush & disinfect sample ports and use
aseptic techniques to avoid contamination.
Keep sterile sample bottle closed until it is
to be filled. Fill container without rinsing
and replace cap immediately. Leave at
least 2.5 cm air space at top of bottle to
facilitate mixing.
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free.
Samples collected during enteric virus
sampling. No additional requirements.
4-17
-------
Annlyte
Group Code
EPABrOS
HAA
HAN
HYPO
IONC
NH3
O3
PART
PROT
SDS3
Sample
Location
Analytical
Method
Selective Anion
Concentration
(SAC) Procedure
EPA 552.1
EPA 552.2
SM 6251 B
EPA 551.1
See individual
analyses
EPA 300.0
EPA 350.1
SM4500-NH3D
SM 4500-NH3 G
379-75 WE
SM 4500-03 B
SM2560
(Proposed)
ICR Microbial
Laboratory
Manual
(Section VII)
SM 5710 C
Storage
Temp
4°C
recommended
Keep at 4°C
Keep at 4°C
See individual
analyses; and
in addition to
the methods
listed under
CL2 in this
table, SM
4500-C1 B
may be used.
4°C
recommended
Keep at 4°C
Field
Analysis
Keep at
2-5°C
Distribution
system
temperature
during
incubation.
Also see
individual
analyses.
Max
Hold
Time
28 Days
14 Days
(ICR
Specification)
14 Days
See individual
analyses
14 Days
(ICR
Specification)
28 Days (if
preserved)
Not applicable
96 Hours
(Start of
sampling thru
filter elution)
Within ±
25%ofDSE
retention time
during
incubation.
Also see
individual
analyses
Special Sample Collection Guidelines
None Specified.
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles. Do
not overfill. Seal sample vials with no
headspace.
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free
See individual analyses
None specified.
None specified
Do not aerate sample. Analyze
immediately after sampling, do not store
sample.
•
specific storage and holding permissable.
(See section 7 of this manual)
Target sample volume to pass through
filter:
100 L Raw Water
1,000 L Finished Water
Fill bottle completely with a minimum of
turbulence.
After incubation, carefully fill sample
bottles for individual analyses. Do not
aerate sample. Fill THM, TOX, HAN,
and CH sample bottles first. See
individual analyses for additional
recommendations .
4-18
-------
Analyte
Group Code
THM
THM/CH
THM/HAN
TOC
TOX
UV254
VIRU
WQP .
Analytical
Method
EPA 502.2
EPA 524.2
EPA 551
EPA 551.1
EPA 551.1
EPA 551.1
SM5310B
SM 5310 C
SM5310D
SM 5320 B
SM 5910
ICR Microbial
Laboratory
Manual
(Section Vm)
Alkalinity:
SM 2320 B
ASTM D1067-
92B
1-1030-85
Calcium
Hardness:
EPA 200.7
SM3111B
SMS 120 B
SM 3500-Ca D
Total Hardness:
SM 2340 B
SM 2340 C
Storage
Temp
Keepat4°C
Keep at 4°C
Keep at 4°C
Keep at 4°C
Keep at 4°C
Keep at 4°C
(ICR
Specification)
Keep at
2-5°C
Keep at 4°C
(ICR
Specification)
Keep at 4°C
Keep at 4°C
Max
Hold
Time
14 Days
14 Days
14 Days
28 Days
14 Days
ASAP1;
not to exceed
2 Days (ICR
Specification)
72 Hours
(Start of
sampling thru
filter elution) .
ASAP1;
not to exceed
14 Days
28 Days
(ICR
Specification)
28 Days
(ICR
Specification)
Special Sample Collection Guidelines
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample must be head-space-free
Fill bottle to just overflowing but do not
flush out preservatives. No air bubbles.
Sample should be head-space-free
Completely fill sample bottles but take care
not to volatilize any organic halogen
compounds. Minimize exposure to light.
Store in a dark place if amber bottles are
not used. Sample must be head-space-free
Fill bottle to just overflowing. No air
bubbles. Sample must be head-space-free
pH adjustment required if water is not
between pH 6 to pH 8. Prefilter if
necessary.
200 L £. Source water samp vol z 300L
1500 L s Finished water samp vol <:
1800L
Fill bottle completely & cap tightly. Avoid
sample agitation & prolonged exposure to
air.
None specified.
None specified
4-19
-------
Analyte
Group Code
Analytical
Method
Storage
Temp
Max
Hold
Time
Special Sample Collection Guidelines
WQP
pH:
SM 4500-H*
EPA 150.1
EPA 150.2
ASTM D1293-
84
Field
Analysis
Not applicable
None specified
Temperature:
SM 2550 B
Field
Analysis
Not applicable
None specified
Turbidity:
EPA 180.1
SM2130B
GLI Method 2
Field
Analysis
Not applicable
None specified
* Optional Sample; not a requirement of the ICR
1. ASAP means As Soon As Practical
2. 40 CFR §141.74(a)(2) states: "If approved by the State, residual disinfectant concentrations for free and
combined chlorine also may be measured by using DPD colorimetric test kits." Therefore, water sytems that are
using these test kits to perform drinking water compiance monitoring under approval from the State, may also
use the test kits to perform analyses for the ICR.
3. SDS is not an ICR analyte group code. It is included here to provide guidance on collection and handling of the
sample collected at the SDS sample location.
4.4 Record Appropriate Information
An important piece of information that needs to be collected at the time of sampling is
the Sample Quality Assurance (QA) Code. This code is used to summarize the sampler's
assessment of the quality of the sample. The available codes are: Acceptable (A),
Questionable (Q), Rejected (R), Lost (L), and No Sample Collected (N).
Various forms and worksheets have been developed to assist the samplers in collecting
the appropriate information along with their ICR samples. These tools are described below.
Once the samples have been collected, and the appropriate information has been captured on
the forms, the information must be entered into the ICR Water Utility Database using the data
entry software.
4.4.1 Forms and Worksheets
Each month, a Monthly Sample Data Collection Form (see Appendix C, Form C.I)
should be created from the Monthly Sampling Plan using the ICR Water Utility Database
software. This form is intended to be a handy reference document which will be used by the
sample collector. The use of this form will ensure that the sample collector takes the required
4-20
-------
samples and collects the necessary sampling data in the treatment plant. The form identifies
all the samples that are to be collected for the ICR sampling period, the location in the water
treatment system where the sample is to be taken, the sample identification number" of each
sample, and the date on which each sample was taken. Furthermore, since many water quality
characteristics (e.g., turbidity, temperature, etc.) are measured immediately after collecting
ICR samples, the form also provides a space for the sample collector to permanently record
such data. These data will be entered into the ICR database at a later date by the PWS.
The date and time the sample was collected must be entered hi the ICR Water Utility
Database System, for each analyte group. To facilitate the collection of these data, it should
be recorded on the appropriate data collection form. It may also be recorded on the sample
identification label.
The three data collection forms which can be generated via the ICR Water Utility
Database System for use hi the field include:
• C.I - Monthly Sample Data Collection Form - Use this form to ensure that the required
samples and necessary sampling data are collected.
• C.2 - Monthly Process Data Collection Form - Use this form to collect the required
unit process data.
• C.3 - Monthly Chemical Data Collection Form - Use this form to collect the required
data on chemical feed and disinfectant addition.
Worksheets located hi an appendix to the ICR Water Utility Database System Users'
Guide may also be used to collect process and chemical data during the sampling activities.
Some of the information which must be collected during the sampling period includes:
• Population and Flow Rate - Retail and wholesale population equivalents.
• Treatment Plant Operating Conditions - Record additional treatment plant operating
information and changes to the existing information to reflect current conditions for the
following items:
Basic Plant Configuration
Water Resource and Intakes
Influent
Process Tram Configuration
Unit Processes
Finished Water
Hypochlorite Stock
Distribution System
4-21
-------
4.4.2 Analytical Data from Laboratories
The laboratories will report the results of their analyses to the PWS hi hard
copy reports. The PWS may find it helpful to provide their laboratories with a copy
of the various data entry screens that will be used to enter the sample analytical data, so
that the laboratories can report the data hi a similar format. In addition to the
concentrations of the various analytes, the laboratories will report:
• The analytical method that was used to analyze each sample.
• The pH that was measured hi TOX, TOC, HAN, CH, THM/HAN and
THM/CH samples prior to their analyses.
• The % recovery of surrogate and internal standards that were added to certain
samples prior to analysis.
• Any samples or analytes within samples that failed to meet the QC criteria and
the reason for failure.
The PWS must enter the above information into the Water Utility Database
System, because monitoring data will be deleted from the ICR Federal Database if the
specified QC information is not available. Monitor ing data should not be entered into
the Water Utility Database System for samples (or analytes within samples) that the
laboratory reports as failing QC criteria. (The QC information from the laboratory
should be entered instead.) Should monitoring data be reported under these
circumstances, such data will be deleted from the ICR Federal Database when EPA
performs its verification and validation analysis.
Laboratories are required to submit QC reports to EPA on a monthly basis. It
is the responsibility of each PWS to request a copy of the portion of the QC reports
that are associated with its samples if the PWS wishes to review the performance of its
laboratory. Reviewing the QC reports will enable the PWS to gauge laboratory
performance and therefore keep track of a laboratory's ICR approval status.
4.5 Verify Monthly Sampling Information
The ICR Water Utility Database System allows for the generation of two types of
Monthly Sampling Results Reports to assist hi verification of data prior to submitting the data
to EPA. The PWS shall verify monthly analytical results (which also includes results from
quarterly samples) received from the laboratory prior to submittal of ICR data to EPA. The
two types of reports provide for:
• Verification of sample analytical results for a selected sampling period.
• Through plant analysis to reveal changes in sample data across the treatment train.
4-22
-------
4.6 Report Monthly Sampling Information to EPA
After the PWS has thoroughly reviewed all of the information from a monthly sampling
period, it must generate an electronic report for the period using the Water Utility Database
System. The report must be submitted to EPA within four months of completion of the
sampling period. The process for preparing this report is fully documented in the Water
Utility Database System Users' Guide. The diskette is submitted to EPA at the address
specified in the Users' Guide.
4-23
-------
-------
5.0 ICR Sampling Requirements - By Location
5.1 Samples Required for ICR 18-Month Monitoring Period
The ICR [§141.142(a) and §141.143(a)] requires monthly and quarterly water samples
to be collected at a series of locations hi the water treatment plant and water distribution
system. Water samples are to be analyzed for a specific series of analytes to determine the
levels of these contaminants at these locations.
The ICR [§141.14i(b)] describes how a PWS determines applicability. If a PWS is
required to conduct monitoring for disinfection byproducts and related contaminants, then the
affected treatment plants shall monitor monthly for 18 consecutive months at each treatment
plant (even when a treatment plant was not used for one or more months). Treatment plant
influent monitoring is the only monitoring requirement when the plant is not operating. A
category "F" plant (a ground water or purchased finished water plant serving less than
100,000 people which is not the largest plant hi the system) does not have to monitor when the
plant is not hi use. A PWS must also monitor for microbiological contaminants for certain
treatment plant categories (A, C, and E) that treat surface water. This microbiological
monitoring shall also be conducted for 18 consecutive months (even if the plant is not operated
each calendar month). The basic microbiological parameters to be monitored include: total
culturable viruses, total coliforms, fecal coliforms or E. coli, Giardia, and Cryptosporidium in
the treatment plant influent and the finished water. Some types of monitoring (such as finished
water microbiological monitoring) may be avoided if the PWS meets special conditions (see
Finished Water Sample Point below).
Throughout this section, when a sampling point is described, the types of samples to be
collected at that location will be listed by an "analyte group code" as they are described hi
Table 4-1 of this manual. For example, CL2 refers to chlorine residual, CLD to chlorine
demand, TOX to Total Organic Halide^ whereas, WQP refers to the Water Quality Parameters
and includes: pH, alkalinity, turbidity, temperature, calcium and total hardness. Refer to
Figure 2-1 for an example of a plant schematic which displays the sampling points and types of
samples to be collected in a hypothetical conventional water treatment plant (WTP).
5.2 Monitoring Requirements
References : §141.142(a) DBP monitoring
§141.143(a) Microbiological monitoring
5.2.1 General
If a treatment plant configuration results in the placement of two sampling
points at a single location, duplicate analyses are not required for the same location
5-1
-------
and time. An example of two sampling points being placed in the same physical
location is found in Figure 2-1 with the Influent Sample (sample #01) and a "before
point of disinfection" sample. Another example is the entry point to the distribution
system (Entry Point) sample, which is only required for treatment plants that blend
finished water with finished water from other treatment plant(s) prior to entry into the
distribution system. For the hypothetical example in Figure 2-1, however, the finished
water sample collection point (sample #09) is the same as the Entry Point, in which
case the Entry Point sample should not be collected (and is not shown in Figure 2-2).
A PWS shall collect a complete set of samples at the frequency and location
noted hi Tables 5-1 and 5-2, and summarized hi the ICR [§141.142(a)(l)]. Also refer
to Table 4-2 and Table 4-3 hi this manual for additional information on the collection
and handling of the ICR samples. The general locations, and the rationale for
collecting samples at these locations are described below.
5-2
-------
Table 5-1. Monthly Monitoring Requirements for Treatment Plants
Sampling Point
+ -
Treatment plant influent for
nonfinished water
Treatment plant influent for
purchased finished water4
Before first point of oxidant
addition
Washwater return between
washwater treatment plant and
point of addition to process train
Additional water sources added to
process tram, after treatment plant
influent. The sample point is
before additional water is blended
with the process train.
Before filtration
After filtration
Before each point of disinfection6
After every unit process that is
downstream from the addition of
chlorine/chloramines
Finished water sample point
(plant effluent)
Entry point to distribution
system8
WQP
•
•
•
•
•
•
•
•
TOC
•
•
•
•
•
•
•
•
W254
•
•
•
•
•
•
•
•
Br
•
•
NH3
•
•
CL21
•
•
•
•
•
co>
•
PROT2
•
•7
YIRUZ
•3
•7
BACT2
•
•7
1. Free chlorine residual and total chlorine residual shall be measured in treatment systems using free chlorine. Total
chlorine residual, but not free chlorine residual, shall be measured in systems using chloramine as the residual
disinfectant.
2. For water treatment plant categories A, C, and E only.
3. See section 5.2.2 of this manual for requirements to avoid virus monitoring at this sampling point.
4. Samples of purchased finished water shall be taken prior to addition of any more disinfectant.
5. Disinfectant residual is measured if disinfectant is used to treat the washwater.
6. For utilities using ozone or chlorine dioxide, Tables 6-3, 6-4, 6-5 and 6-6 show additional monitoring requirements at
this sampling point. Addition of ammonia for the purpose of converting free chlorine to chloramines is considered a
point of disinfection addition. PWSs that disinfect just before filtration may use the "before filtration" sampling point
analytical results to meet the monitoring requirement for this point.
7. See section 5.2.9 of this manual for conditions that trigger microbiological monitoring at this sampling point.
8. Entry point to the distribution system only required for treatment plants that blend finished water with finished water
from other plants prior to the entry point to the distribution system. For most treatment plants, the finished water
sample point and the entry point to the distribution system are the same.
5-3
-------
Table 5-2. Quarterly Monitoring Requirements for Treatment Plants
Sampling Point
TOX
HAAS
HAN
CH
WQP
CL2;4
Treatment plant influent
Treatment plant influent for
purchased finished water
Washwater return between
washwater treatment plant and
point of addition to process train
After filtration if disinfectant is
applied at any point in the
treatment plant prior to filtration
Finished water sample point
(Plant Effluent)
Entry point to distribution system1
Simulated distribution system
sample2 (SDS)
Four monitoring points in
distribution system3'5
1. Entry point to the distribution system only required for treatment plants that blend finished water with finished
water from other plant(s) prior to the entry point of the distribution system. For most treatment plants, the fmishec
water sample point and the entry point to the distribution system are the same.
2. SDS sample shall be collected at the finished water sampling point (or entry point to the distribution system if
finished water from two or more plants are blended prior to entering the distribution system) and analyzed using
the method specified in §141.142. PWSs using purchased finished water are not required to take an SDS sample ai
treatment plants that use only purchased finished water.
3. For each treatment plant, 1 distribution system equivalent sample location (DSE) shall be chosen to correspond to
the SDS sample, 1 sample location shall be chosen to be representative of maximum residence time for the treatme
plant, and the remaining 2 sample locations shall be representative of the average residence time in the distributioi
system for the treatment plant. PWSs using purchased finished water shall take 3 samples representing the average
residence time in the distribution system for the treatment plant and 1 representing the maximum residence time foi
the treatment plant (no DSE sample required).
4. Free chlorine residual and total chlorine residual shall be measured in treatment systems using free chlorine. Total
chlorine residual, but not free chlorine residual, shall be measured in systems using chloramines as the residual
disinfectant.
5. A PWS may use TTHM compliance monitoring locations and analytical results under the THM Rule [§141.30] to
the extent that such locations and analytical results are consistent with the requirements of this section.
6. PWSs are encouraged to also analyze for the additional haloacetic acids bromodichloro-, chlorodibromo- and
tribromo- acetic acid, and to report the results as part of the reports specified in the ICR [§141.142(c)(l)].
5-4
-------
5.2.2 Treatment Plant Influent
References: [§141.142(a)(l)(ii)]& [§141.143(a)(2>]
Treatment plant influent samples are collected to provide an indication of
baseline water quality and to determine the water quality challenge it presents to the
treatment plant. The sampling frequency was chosen to provide data on the variation
over time and seasons. The influent may be either non-finished water or finished water.
• Non-Finished Water
(Monthly - WQP, TOC, UV254, Br, NH3)
(Monthly Micro - PROT, VIRU, BACT, COLP, CLOST* for plant categories
A, C and E only)
(Quarterly - TOX)
*Optional
An ICR sample of treatment plant influent for a PWS that treats untreated water
(non-finished water) shall be collected at a location at the upstream (head) end of a
treatment plant where waters from all intakes are blended prior to any treatment or
chemical addition. Figures 5-1, 5-2, and 5-3 illustrate the proper sampling location for
some typically encountered plant influent configurations. These figures also illustrate
the how an ICR schematic should depict these different physical sampling locations.
• Single Intake samples are collected after the intake, before addition of
chemicals or any treatment. Refer to Figure 5-1.
• Multiple Intakes without Treatment or Chemicals Added prior to
blending. Collect one complete set of samples at the upstream (head) end of
treatment plant where waters from all intakes are blended prior to any
treatment or chemical addition. Refer to Figure 5-2.
• Multiple Intakes with Chemicals Added - For treatment plants that have
multiple intakes and add chemicals at or near the intake, a flow proportional
composite sample (complete set of ICR samples) before chemical addition or
pretreatment must be collected. However, if the intakes are expected to
have the same source water quality, one representative sample may be
taken. Refer to Figure 5-3.
A PWS must conduct monthly microbiological monitoring as specified in the
ICR [§141.141(d)] for 18 consecutive months at each treatment plant that is classified
as an A, C, or E plant (even if it is not operated each calendar month). Samples shall
5-5
-------
be analyzed for total culturable viruses, total coliforms, fecal coliforms or E. coli,
Giardia, and Cryptosporidium. Analyses for Clostridium and coliphage may also be
performed at the discretion of the PWS. Results from these samples will provide a
better understanding of the seasonal variation hi the microbial "challenge" to treatment
plants as well as general occurrence information.
A PWS may, however, avoid virus monitoring if they have monitored total
coliforms, fecal coliforms or E. coli in the source water for at least five (5) days every
week for any period of six (6) consecutive months beginning after January 1, 1994, and
90% of all samples taken hi that six month period contained no greater than 100 total
coliforms/lOOml, or 20 fecal coliforms/lOOml, or 20 E. cott/lQQnal.
• For micro samples [§141.143(a)(2)(B)L if me plant has multiple intakes
and adds chemicals at the intake, the PWS shall take an intake sample of the
water resource with the poorest microbiological quality (or if that cannot
be determined, the water resource with the highest flow) collected before
chemical addition and before pretreatment.
• If a disinfectant is added at or before the intake (e.g., for zebra mussel
control) take the sample in the vicinity of the intake, but avoid
contaminating the sample with the disinfectant. This is important for
microbiological samples as well as for the water quality parameters (WQP),
TOX, and Bromide.
• Finished Water
(Monthly - WQP, TOC, UV254, CL2)
(Quarterly - TOX, THM, HAA, HAN, CH)
• Collect the sample of purchased finished water before the purchased
finished water is further treated (e.g., addition of any more disinfectant). A
PWS shall only collect a sample of purchased finished water if the
purchasing PWS redisinfects the purchased water.
NOTE: PWSs are encouraged to measure nine (9) HAAs, even though the rule
only requires HAA6 (six (6) HAAs). The additional three haloacetic acids are:
bromodichloroacetic acid, chlorodibromoacetic acid, and tribromoacetic acid.
5-6
-------
Example of Standard Schematic
Example of ICR Schematic
First
Unit Process
to other
downstream processes
First
Unit Process
to other
downstream processes
KEY:
Physical location of influent water sample tap.
Influent sampling location as depicted by an
1 ICR Schematic.
Figure 5-1. Treatment Plant Influent Sample - Single Intake
5-7
-------
Example of Standard Schematic
Example of ICR Schematic
1
—>
•^
1
i. Induant J)
First
Unit Process
(~ Influ
^~~1
>
.... ~\^
|oi
First
Unit Process
T
to other
downstream processes
to other
downstream processes
KEY:
H) Physical location of influent water sample tap
„ Influent sampling location as depicted by an
W01 ICR Schematic.
Figure 5-2. Treatment Plant Influent Sample - Multiple Intakes
5-8
-------
Example of Standard Schematic
Example of ICR Schematic
Water Resource
Water Resource
Water Resource
Water Resource
to other
downstream processes
to other
downstream processes
KEY:
Physical location of influent water sample tap
Influent sampling location as depicted by an
1 ICR Schematic.
Figure 5-3. Treatment Plant Influent Sample - Multiple Intakes w/Chemical Addition
5-9
-------
5.2.3 Before First Point of Oxidant Addition
(Monthly - CLD)
A sample shall be collected before the first point of oxidant addition and tested
for chlorine demand to determine the inorganic oxidant demand of the water.
Inorganic compounds in the influent water quickly react with oxidants (e.g., potassium
permanganate and the primary disinfectants used in drinking water treatment).
Therefore, once consumed, the disinfectants are no longer available to provide
disinfection or to react with organic material (precursors) to form disinfection
byproducts (DBFs). The chlorine demand test used in the ICR will permit the
determination of how much disinfectant is available to react with the organic precursors
to form DBFs after the inorganics have been oxidized. This is critical for predicting
DBF formation. Therefore, it is important to know the inorganic oxidant demand of
the water at the point of the first addition of oxidant. Basically, the chlorine demand
test involves dosing an aliquot of water collected prior to this point in the treatment
process with a known amount of chlorine and then measuring the chlorine residual after
a known contact time. The test is conducted under conditions (chlorine dose,
temperature, and pH) specific to each water treatment plant. Furthermore, since the
water sample should be at the same temperature as the process water, the test should be
conducted on a freshly collected aliquot of water. The pH of the water should not be
adjusted. Contact time is less than 10 minutes.
NOTE: This test must be conducted in accordance with the DBP/ICR Analytical
Methods Manual requirements. It is also included in Appendix D of this manual.
5.2.4 Washwater Return
(Monthly - WQP, TOC, UV254, Br, NH3, and C12 if disinfectant is used)
(Quarterly - TOX)
Filter backwash water may or may not be treated before it is returned to the
main process stream, and it may not be returned to the main process stream at all. If it
is returned, however, washwater return could represent a significant change in the
water quality within the process stream. The purpose of this sample is to be able to
predict how washwater will impact the water quality and thereby provide better
modeling of DBF formation in the process stream. It should be sampled prior to
blending with the process train for the water quality parameters (pH, Alkalinity,
Turbidity, Temperature, Calcium and Total Hardness), TOC, UV254, Bromide, and
Ammonia, and Disinfectant residual (if a disinfectant is used) on a monthly basis.
TOX should be monitored quarterly.
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5.2.5 Additional Water Sources
(added to process train after treatment plant influent)
(Monthly - WQP, TOC, UV254, Br, NH3, and CL2 if disinfectant is added)
(Quarterly - none)
This sample is collected from the main process stream before additional water is
blended with the process stream. An example of an additional water source is the
addition of ground water to the process stream after a surface water source has
undergone preliminary treatment such as chemical addition, rapid mix, coagulation,
and sedimentation. Then the blended (combined) flow would undergo filtration and
any other subsequent treatment in the main process stream. In this hypothetical
example, the next sampling point (before filtration) would capture the water quality of
the blended flow at that point. Comparison of the results from this sample point and
the next one will indicate the impact the additional water source had on the water
quality of the process stream. This information is critical for modeling DBF
formation.
5.2.6 Before and After Filtration
(Monthly - WQP, TOC, UV254)
(Quarterly - None unless disinfection is applied prior to filtration. Then after
filtration - THM, HAA, HAN, CH, TOX)
Comparison of these sample results will provide data on changes in water
quality across the filtration process. Of particular importance are data on how the
organic precursor material (as represented by TOC and UV254) is removed prior to and
through filtration. The quarterly parameters, THMs, etc. in the filter effluent are also
important in trying to relate DBF formation to water quality and treatment practices.
This data point (filter effluent) will be compared to the plant effluent sample to get an
indication of how formation increases concentrations in the final stage of treatment, for
example, in the clearwell where additional disinfectant is added. Parameters and
analytes to be evaluated at these locations are similar to those collected at the plant
influent.
5.2.7 Before each Point of Disinfection
(Monthly - WQP, TOC, UV254)
Most data currently available for determining DBP formation are based on
source water parameters. Since many utilities apply some form of treatment to the
water prior to the first addition of disinfectant, source water parameters do not always
accurately reflect the quality of the water prior to the point where disinfectant is added.
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Ammonia (NH3) addition is also considered a point of disinfection for purposes of
determining this sample point. The ICR data will provide for a more accurate
determination of how water treatment processes influence DBF formation, because the
water quality will be known at each point where disinfectant is applied. Again,
monthly parameters and analytes measured at this point hi the treatment scheme are
similar to those of the plant influent sample.
5.2.8 After Every Unit Process Downstream from the Addition of Chlorine
(Monthly - CL2)
Free chlorine and total chlorine residual will be measured at these ICR sampling
locations (in plants using free chlorine or chloramines) to provide a better
understanding of the decay of chlorine through the water treatment plant and to give a
more accurate picture of DBF formation.
5.2.9 Finished Water Sample Point
(Monthly - WQP, TOC, UV254, CL2)
(Monthly Micro - PROT, VIRU, BACT, COLP, CLOST* for Water Treatment
Plant Categories A,C & E only)
(Quarterly - THM, HAA, HAN, CH, TOX)
*0ptional
The previously mentioned samples have tracked the changes in water quality
characteristics through the treatment plant in order to better predict DBF formation.
This finished water sample now provides a comparison of actual DBF concentrations to
what is predicted by modelling the formation through the plant. In addition, the micro
samples provide occurrence data.
Monthly and quarterly DBF samples are required for the ICR [141.142(a)(l)] at
the finished water sample collection point. In addition, microbiological sampling of
the finished water is also required under the ICR [§141.143(a)(2)(ii)] if, during any of
the first twelve (12) months of monitoring at the treatment plant influent the PWS
detects:
• 10 or more Giardia cysts, or
• 10 or more Cryptosporidium oocysts, or
• 1 or more total culturable viruses, in one liter of water; or a PWS:
• calculates a numerical value of the Giardia or Cryptosporidium concentration
equal to or greater than 1000 per 100 liters, or
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• a virus concentration equal to or greater than 100 per 100 liters; or
• detects no pathogens in the sample and calculates a numerical value of the
detection limit for Giardia or Cryptosporidium concentration equal to or greater
than 1000 per 100 liters or virus concentration equal to or greater than 100 per
100 liters;
Then the PWS shall also collect one sample of finished water per month. The
first sample shall be collected beginning in the first calendar month after the PWS
learns of such a result as described above. This finished water monitoring must then
continue until the full 18 months of treatment plant influent monitoring has been
completed.
The finished water sample collection point [§141.143(a)(2)(B)(ii)] is also
referred to as the plant effluent sample and represents the single point in the treatment
plant where a sample may be collected that is representative of the treated water
leaving the plant following all treatment process units (including the clear well and
final point of disinfection).
NOTE: Finished water monitoring for Giardia and Cryptosporidium may or
may not be required, depending on the results of the influent monitoring as stated
above. In lieu of having to conduct any finished water monitoring for Giardia and
Cryptosporidium, the ICR [§141.143(a)(2)(iii)] stipulates that the PWS may conduct
particle count measurements at three (3) locations in the process stream; hi the
treatment plant influent, and at points immediately prior to and after filtration.
However, each PWS which elects to conduct particle counting must also collect
and analyze at least four consecutive months of Giardia and Cryptosporidium samples
at the same locations specified for particle counting. (See Section 7.0 of this manual
for details of the particle counting procedure). The PWS must also continue to conduct
the required finished water monitoring for all other microorganisms (total coliforms,
fecal coliforms, E. coli, and possibly total culturable viruses. Coliphage (both somatic
and F-specific and Clostridium analyses at this sample point are optional.
Any PWS which elects to conduct particle counting may notify EPA of this
decision in its response to the notification letter, and/or must confirm this decision in
its Letter of Transmittal of its Initial Sampling Plan. (See sections 1.3.1 and 2.2.1 of
this manual). Commitment to comply with the particle counting requirements of the
ICR [§141.143(a)(2)(iii)] must be communicated prior to the start of ICR sampling and
will apply throughout the eighteen (18) month monitoring period, regardless of the
results of influent monitor ing for protozoa.
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5.2.10 Entry Point to the Distribution System
(Monthly - WQP, TOG, UV254,CL2)
(Quarterly - THM, HAA, HAN, CH, TOX)
The entry point to the distribution system (Entry Point) sample(s) is only
required for treatment plants that blend finished water with finished water from other
treatment plant(s) prior to entry into the distribution system. For most treatment
plants, however, the finished water sample collection point is the same as the entry
point to the distribution system, in which case the Entry Point sample should not be
collected.
5.2.11 Simulated Distribution System
(Quarterly - WQP, THM, HAA, HAN, CH, TOX and CL2)
The Simulated Distribution System (SDS) sample is a finished water sample
which is incubated at the same temperature and detention time as a Distribution System
Equivalent (DSE) sample collected from the distribution system. It is collected at the
entry point to the distribution system sampling point or the finished water sampling
point, if an entry point sample is not required. Analytical results of the SDS sample
will be compared with the DSE sample to determine how well the SDS sample predicts
disinfection byproduct formation in the actual distribution system (sample). The SDS
and DSE samples are not required for plants that only redisinfect purchased finished
water.
This sample is collected for two reasons: (1) To look at DBF formation under
controlled conditions; and (2) To determine if SDS samples could be a cost effective
monitoring tool in place of distribution system sampling.
The volume of the SDS sample must be large enough to accommodate all the
analyses listed above. A single, large ( — 0.5 gallon), amber glass container with a
Teflon lined cap is preferable to several smaller containers. The container must be
filled completely, that is, with zero head-space, sealed tightly, and protected from light
during storage. The SDS sample should be stored for a time period comparable in
length to the DSE sample's detention time. The storage temperature should be
comparable to the temperature of the water in the distribution system (between the
treatment plant and the DSE sampling point). At the end of the storage time, the SDS
sample must be divided for analysis (the reason for the large sample) by pouring it into
sample bottles containing the appropriate dechlorinating agents/preservatives. Be
careful not to aerate the sample during transfer to prevent the loss of volatile
compounds.
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NOTE: The DBP/ICR Analytical Methods Manual describes the procedural
requirements for the SDS sample (Standard Method 5710 C). A copy of the procedure
is also included hi Appendix D of this manual. In most cases the incubation part of this
test, and dividing the sample into smaller bottles for the individual analyses will be done
at the treatment plant.
5.2.12 Distribution System
(Quarterly - WQP, THM, HAA, HAN, CH, TOX, CL2)
Four (4) monitoring points are to be sampled quarterly in the distribution
system for each treatment plant. These data will provide occurrence information on the
DBFs thereby assisting in making national exposure estimates. The DSE sample
results will also be used in conjunction with the SDS sample results in order to evaluate
the usefulness of SDS for future regulatory purposes. Figure 2-2 contains an example
ICR Distribution System Schematic, depicting the four samples, which are:
• Maximum Residence Time - Collect one sample at a location in the
distribution system that represents the maximum residence tune. This point will
often be the point farthest from the plant or possibly at a dead end in the
system.
• Average Residence Time - Collect samples from two (2) locations within the
distribution system that are representative of the average residence time hi the
distribution system.
• Distribution System Equivalent (DSE) - Collect one sample at a location hi the
distribution system that corresponds to the "simulated distribution system"
(SDS) sample. The following criteria should be used in the selection of this
sampling location:
• No additional disinfectant added between the treatment plant and the
sampling location,
• Approximate residence tune of the water at the sampling location is
available, and
• There is no blending with finished water from other treatment plants.
Plants that only redisinfect purchased finished water must substitute an average
residence time sample for the DSE sample, because they are not collecting an
SDS sample for comparison to the DSE sample.
NOTE: A PWS may use TTHM compliance monitoring locations and
analytical results gathered to conform with Part 40, §141.30 (the THM Rule) to satisfy
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this requirement if the sampling locations and analytical results are consistent with the
ICR requirements.
5.2.13 Full-Scale GAC or Membrane Treatment
V
For a treatment plant that already uses full-scale GAC or membrane technology
capable of achieving precursor removal, a PWS shall conduct the monitoring listed in
Table 5-3 and submit full-scale plant data, as per the ICR [§141.141(e)(3)(iv)L
ensuring that the GAC or membrane processes are included in the process train being
monitored.
Table 5-3. Monitoring Required Across Full-Scale GAC Or Membrane Processes
Sampling Point
Before GAC or membranes
After GAC or membranes
Sampling Point
Before GAC or membranes if
disinfectant is applied at any point hi the
treatment plant prior to these processes
After GAC or membranes if disinfectant
is applied at any point hi the treatment
plant prior to these processes
Monthly Analyses
WQP, TOC and UV254
WQP, TOC and UV254
i
i
Quarterly Analyses
THM, HAA, HAN, CH, TOX
THM, HAA, HAN, CH, TOX
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6.0 Additional Sampling Requirements for PWSs
Using Alternative Disinfectants
The foregoing sampling requirements for DBF samples (Section 5.0 of this manual)
are for all PWSs required to monitor under the ICR. However, for treatment plants that use
alternative disinfectants such as chloramines, hypochlorite solutions, ozone, or chlorine
dioxide, additional monthly and/or quarterly monitoring is required. The additional samples
are required to determine the disinfection byproducts that are likely to be formed when the
alternative disinfectants are used.
NOTE: When preparing or checking a sampling schematic, check each sample point
against the requirements in the rule. For example, if a plant uses chlorine dioxide as its
disinfectant, the ICR [§141.142(a)(5>] requires that chlorine dioxide residual (CLO2),
Chlorite, Chlorate, Bromate (collectively, IONC) be monitored on a monthly basis hi the
finished water. Furthermore, if more than one disinfectant is applied within a plant, the
monitoring requirements associated with each type of disinfectant will apply. As an additional
example, if ozone is applied at a treatment plant and followed downstream by chloramines,
additional samples will need to be collected and analyzed for the presence of cyanogen
chloride.
Following is a brief discussion of the additional monitoring required at treatment .plants
using various alternative disinfectants. Each section is further broken down by sampling
location as in Section 5.0 of this manual.
6.1 Treatment Plants Using Chloramines
Treatment plants using chloramines are required by the ICR [§141.142(a)(2)] to
analyze for cyanogen chloride at the locations described below (also see Table 6-1) on a
quarterly basis. Cyanogen chloride is formed when chlorine reacts with organic material in
the presence of the ammonium ion. Little data are currently available on the occurrence of
cyanogen chloride and the factors influencing its formation. Therefore, additional data are
necessary to determine how the distribution of byproducts would change if utilities switched
from free chlorine to chloramines to meet the proposed D/DBP Rule MCLs for TTHM and
HAAS. An EPA laboratory in Cincinnati will analyze the ICR water samples for cyanogen
chloride (See Section 6.5 of this manual).
6.1.1 Treatment Plant Influent
(Quarterly - CNCL)
There is only one case when the treatment plant influent must be sampled for
cyanogen chloride under the ICR, and that is when the wholesale water provider is
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using chloramines. The samples collected at this point will be sent to EPA in
Cincinnati for cyanogen chloride analysis. All of the other purchased water influent
samples required by the ICR must also be collected (see Section 5.0 of this manual).
6.1.2 Finished Water
(Quarterly - CNCL)
The finished water sample point (plant effluent) must be sampled quarterly at
plants using chloramines. This sample will be sent to EPA for analysis. All of the
other finished water ICR samples described in Section 5.0 of this manual must also be
collected at this sampling point.
6.1.3 Distribution System
(Quarterly - CNCL)
For treatment plants using chloramines, an additional sample must be collected
in the distribution system and analyzed for cyanogen chloride. This sample must be
collected at the distribution system sampling point representing the maximum
residence tune in the distribution system. As with the other cyanogen chloride samples
' described above, this sample must be sent to EPA for analysis.
Table 6-1. Additional Quarterly Monitoring for Treatment Plants Using Chloramines
Sampling Point
Treatment plant influent for purchased finished water
(only if wholesaler uses chloramines)
Finished water sample point (plant effluent)
Distribution system sample point representing a maximum residence
time in distribution system relative to the treatment plant
1. EPA is to analyze water samples for Cyanogen Chloride. See paragraph "/
Cyanogen Chloride1
•
•
•
Arranging for special EPA ICR Analyses.
6.2 Treatment Plants Using Hypochlorite Solutions
Treatment plants using hypochlorite solutions are required by the ICR [§141.142(a)(3)]
to analyze for chlorate at the locations described below (see also Table 6-2) on a quarterly
basis. The plant influent sample is necessary because chlorate has been measured in both
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surface and ground water sources. Therefore, the influent sample will provide information on
the background level of chlorate.
EPA anticipates that chlorate may be regulated as part of the Stage 2 DBF Rule.
Chlorate is a decomposition product found in hypochlorite feedstock, and is not a DBF
resulting from chlorine reactions under drinking water treatment conditions. Therefore, its
concentration in drinking water is not expected to change unless additional hypochlorite
solution is added to the process stream. To better understand the factors that influence
chlorate formation, water treatment plants using hypochlorite solutions will be required to
analyze quarterly samples collected from the influent and effluent for chlorate.
6.2.1 Treatment Plant Influent
(Quarterly - IONC (Chlorate only))
Treatment plants that use hypochlorite solutions for treatment or disinfection
residual maintenance shall collect an additional influent sample and have it analyzed for
the presence of chlorate on a quarterly basis. In addition, treatment plants that
purchase finished water from another provider (wholesaler) that uses hypochlorite
solutions shall analyze their influent for chlorate.
6.2.2 Hypochlorite Stock Solution
(Quarterly - HYPO (pH, Temp., Free Residual Chlorine, & Chlorate))
The hypochlorite solution that is being used at the plant to feed chlorine into the
process stream shall be analyzed quarterly for pH, Temperature, Free Residual
Chlorine, and Chlorate. The hypochlorite "stock" solution to be sampled is the one at
the treatment plant that is being used to feed chlorine into the process stream at
the time of sampling, and not the stock solutions at booster stations in the distribution
system. In some instances, this may be a dilution from the feedstock that is purchased
(i.e., a 15% solution diluted to 5% OR a solution of calcium hypochlorite).
NOTE: If a plant is utilizing more than one stock solution to feed chlorine into
the process stream at the time of sampling, the PWS must obtain a composite sample of
the stock solutions being used. Therefore, only one (1) "representative" sample will be
submitted to the laboratory for analysis.
EPA will use the chlorate data from this sample and the influent and finished
water samples to do a mass balance on chlorate. The temperature, pH and free residual
chlorine measurements will provide information concerning the quality of the stock
material.
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6.2.3 Finished Water
(Quarterly - IONC (Chlorate only))
An additional sample shall be collected at the finished water sampling point
(plant effluent) of plants using hypochlorite solutions and it shall be analyzed for
chlorate.
Table 6-2. Additional Quarterly Monitoring for Treatment Plants Using Hypochlorite
Solutions
Sampling Point
Treatment plant influent
Treatment plant influent for purchased finished water
(only if wholesaler uses hypochlorite solutions)
Hypochlorite stock solution
Finished water sample point (plant effluent)
Chlorate
"
*
^S
*f
pH
"
Temp,
"
Free
Residual
Chlorine
"
6.3 Treatment Plants Using Ozone
Treatment plants that use ozone are required under the ICR [§141.142(a)(4)] to
monitor for specific DBFs that are known to form as the result of oxidation reactions
(specifically, bromate and aldehydes). These plants are also encouraged (by EPA) to
determine either assimilable organic carbon (AOC) or biodegradable organic carbon (BDOC),
since ozonation increases the biodegradable fraction of organic material available to support
bacterial growth. Refer to Table 6-3, Additional Monthly Monitoring for Treatment Plants
Using Ozone, and Table 6-4, Additional Quarterly Monitoring for Treatment Plants Using
Ozone.
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6.3.1 Ozone Contactor Influent
(Monthly - Br, EPABrO3, and NH3)
(Quarterly - ALD, AOC* or BDOC*)
*Optional
Treatment plants using ozone are required to collect samples from the ozone
contactor influent and have them analyzed for bromide, low-level bromate, and
ammonia. These samples, in addition to the samples collected upstream of this point
as described in Section 5.0, will characterize the quality of the water at this point in
the process stream.
This sample is not expected to contain bromate at concentrations that can be
measured using the routine method (EPA Method 300.0). Therefore, EPA will not
require the PWS to have it analyzed by that method. Instead, EPA will analyze the
sample for low-level bromate using a research technique that can measure bromate
concentrations down to less than 1 vg/L. The PWS shall, therefore, collect the ozone
contactor influent bromate sample in bottles provided by EPA and ship them to EPA
for analysis. See Section 6.5 of this manual for additional information concerning this
sample.
The utility does not have to collect a separate contactor influent bromate
sample for analysis by their ICR approved lab. They must, however, collect samples
and have them analyzed for bromide and ammonia.
6.3.2 Each Ozone Contact Chamber Effluent
(Monthly - O3)
Treatment plants using ozone shall monitor the ozone residual in the effluent of
all contact chambers (each ozone contactor can be subdivided into its individual
contact chambers) until less than 0.05 mg/L of ozone is measured in two consecutive
chambers. If the residual is >0.05 mg/L ozone exiting the last chamber, then it is
recommended (not required) that the O3 residual be measured after the downstream
processes until it is <0.05 mg/L after 2 consecutive processes. These extra data will
provide a better understanding of ozone decay.
6.3.3 Ozone Contactor Effluent
(Monthly - IONC (Bromate only) and EPABrOS)
(Quarterly - ALD, AOC* or BDOC*)
*Optional
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The PWS shall collect two (2) samples of the ozone contactor effluent for
bromate analyses. It is the responsibility of the PWS to have one sample analyzed for
bromate (using EPA Method 300.0) by an ICR approved lab. The PWS shall collect
the other bromate sample hi bottles provided by EPA and ship them to EPA for the
low-level bromate analysis.
Quarterly samples for aldehydes shall also be collected from the ozone
contactor effluent. Optional samples for AOC or BDOC analyses may also be
collected quarterly at this sampling point. Analysis of the aldehyde samples will be
done by EPA.
NOTE: EPA will use the data generated from the IONC (Bromate only)
samples to evaluate the performance of the analytical method proposed for compliance
monitoring under the Stage 1 D/DBP Rule. Bromate data from the EPABrOS samples
will be used to further research bromate issues, such as to determine how treatment
practices and source water characteristics influence bromate formation.
6.3.4 Finished Water
(Monthly - IONC (Bromate only) and EPABrOS)
(Quarterly - ALD, AOC* or BDOC*)
*Optional
Treatment plants using ozone shall also collect two (2) samples of finished
water (plant effluent) for bromate analysis monthly. It is the responsibility of the
water system to have one sample analyzed for bromate (using EPA Method 300.0) by
an ICR approved lab. The PWS shall collect the other bromate sample hi the bottles
provided by EPA and ship them to EPA for the low-level bromate analysis.
Quarterly samples for aldehydes shall be collected from the finished water
sampling point (plant effluent). Optional samples for AOC or BDOC analyses may
also be collected quarterly at this sampling point. Analysis of the aldehyde samples
will be done by EPA.
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Table 6-3. Additional Monthly Monitoring Required of Treatment Plants Using Ozone
Sampling Point
Ozone contactor influent
Each ozone contact chamber effluent2
Ozone contactor effluent
Finished water sample point (plant
effluent)
Br
•
IONC
(Bromate only)
•
•
EPABrOS*
•
•
•
NH3^
•
O3
•
1. EPA is to analyze water samples for low-level Bromate. See section 6.5 of this manual.
2. Each ozone contactor can be subdivided into its contact chambers. Measure ozone residual in effluent of all contact
chambers until <0.05 mg/L is measured in two consecutive chambers. If the residual is >0.05 mg/L exiting the
last chamber, then it is recommended (not required) that the O3 residual be measured after the downstream processes
until it is <0.05 mg/L after 2 consecutive processes.
Table 6-4. Additional Quarterly Monitoring for Treatment Plants Using Ozone
Sampling Point
Ozone contactor influent
Ozone contactor effluent
Finished water sample point (plant
effluent)
ALD1
•
•
•
AOC* or BDOC*
(optional)
•
•
•
1. EPA is to analyze water samples for the following aldehydes: formaldehyde, acetaldehyde, propanol, butanol,
pentanol, glyoxal, and methyl glyoxal, and potentially, for other aldehydes. See section 6.5 of this manual.
* Analysis and submission of data for both assimilable organic carbon (AOC) and biodegradable organic carbon
(BDOC) are optional. Analytical methods for AOC and BDOC are listed in "DBP/ICR Analytical Methods
Manual, "EPA 814-B-94-002.
6.4 Treatment Plants Using Chlorine Dioxide
Treatment plants using chlorine dioxide are required by the ICR [§141.142(a)(5)] to
collect additional -samples at several locations in the treatment plant as well as in the
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distribution system. Refer to Tables 6-5 and Table 6-6 of this manual for locations and
analytes.
6.4.1 Treatment Plant Influent for Purchased Finished Water
(Monthly - CLO2, IONC (chlorite & chlorate only))
There are very little data currently available on the concentrations of chlorite
and chlorate in drinking water as a result of chlorine dioxide use. Treatment plants
that purchase finished water from a wholesale water provider that uses chlorine
dioxide shall monitor their treatment plant influent monthly for chlorine dioxide
residual, chlorite, and chlorate.
6.4.2 Before First Chlorine Dioxide Application
(Monthly - IONC (chlorate only) and EPABrOS)
(Quarterly - ALD, AOC* or BDOC*)
*Optional
Low levels of chlorate have been reported in source water. Therefore,
treatment plants will be required to monitor for chlorate in a sample of water collected
at a point prior to the addition of chlorine dioxide in order to provide data on the
relative amounts of chlorate from source water versus the amount produced as the
result of chlorine dioxide use.
There are limited data indicating that bromate may be formed as a result of
sunlight catalyzed reactions between chlorine dioxide and bromide ion. In order to
confirm or disprove this, EPA must also understand whether bromate is present in the
water prior to the application of chlorine dioxide. Therefore, EPA is requiring
treatment plants that use chlorine dioxide to collect a sample from a location before
the first chlorine dioxide application and have it analysed for low-level bromate.
PWSs are not required to analyze a bromate sample collected at this location. They
will only have to collect a bromate sample, in a bottle provided by EPA, and submit it
to EPA for low level bromate analysis.
Chlorine dioxide oxidizes organic material in the water, so oxidation
byproducts such as aldehydes are expected to be formed. The nutrient levels available
to support microbial growth (as indicated by AOC and BDOC) may also increase as a
result of these oxidation reations. In order to understand the changes in water quality
as a result of chlorine dioxide use, it is critical to know the water quality prior to its
use. Therefore, Hie PWS shall also monitor quarterly for aldehydes at the sampling
point before chlorine dioxide is applied to determine background concentrations.
Optional samples for assimilable organic carbon (AOC) or biodegradable organic
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carbon (BDOC) analyses may also be collected at this sampling point. Analysis of the
aldehyde samples will be done by EPA.
6.4.3 Before First Point of Downstream CMorine/Chloramine Application:
after chlorine dioxide addition
(Quarterly - ALD, AOC* or BDOC*)
*OptionaI
Chlorine can also oxidize organic material in the water to form oxidation
byproducts such as aldehydes. In order to determine the levels of aldehydes produced
from chlorine dioxide versus chlorine, it is important to determine aldehyde
concentrations in the water before chlorine or chloramines are applied. Therefore,
plants that use chlorine dioxide shall also monitor for aldehydes before the first point
of downstream chlorine/chloramine application after chlorine dioxide addition.
Assimilable organic carbon (AOC) and biodegradable organic carbon (BDOC)
analyses are optional at this sampling point (but the data will be accepted if the
analyses are performed).
6.4.4 Before Application of Ferrous Salts, Sulfur Reducing Agents, or GAC
(Monthly - CLO2, IONC (chlorite & chlorate only) and pH)
The application of ferrous salts or sulfur reducing agents changes the
concentrations of chlorine dioxide byproducts. Therefore, treatment plants are also
required to monitor monthly for chlorite and chlorate prior to and following these
treatment processes. Monitoring will also be required before and after granular
activated carbon (GAC) filtration to provide a better understanding of the formation
and control of these by-products. The affected water treatment plants are also
required to monitor the chlorine dioxide residual concentrations, and pH at this
sampling point(s).
6.4.5 Finished Water
(Monthly - CLO2, IONC, and EPABrOS)
(Quarterly - ALD, AOC* or BDOC*)
*Optional
Treatment plants shall monitor their finished water (plant effluent) by
collecting samples and having them analyzed monthly for chlorine dioxide residual,
chlorite, chlorate, and bromate. Affected PWSs are also required to submit a sample
6-9
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collected from the "finished water sample point" to EPA for low-level bromate
analysis. The PWS will collect this finished water bromate sample in bottles provided
by EPA.
The PWS shall also monitor quarterly for aldehydes at this point. Assimilable
organic carbon (AOC) or biodegradable organic carbon (BDOC) analyses are optional
at flu's sampling point (but the data will be accepted if the analyses are performed).
Analysis of the aldehyde samples will be done by EPA.
The concentrations in the finished water sample will be compared with those
measured at earlier points hi the treatment process hi order to understand how the
byproducts from chlorine dioxide are formed and affected by the various treatment
processes.
6.4.6 Distribution System
(Monthly - CLO2, IONC (chlorite & chlorate only), pH, Temp.)
The concentrations of chlorite and chlorate are expected to change as the water
is distributed through the system, so distribution system samples are needed to assess
the magnitude of the changes. In addition, there is evidence that chlorine dioxide may
be generated within the distribution system as a result of reaction between chlorite and
chlorine. Therefore, treatment plants using chlorine dioxide shall monitor for chlorine
dioxide residual, chlorite, chlorate, pH, and temperature at three locations in the
distribution system:
• near first customer
• middle of distribution system
• max residence time
These sampling points were chosen hi order to be consistent with the proposed
chlorite monitoring requirements hi the Stage 1 D/DBP rule, which is on a monthly
basis.
6-10
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Table 6-5. Additional Monthly Monitoring for Treatment Plants Using Chlorine Dioxide
Sampling Point
Treatment plant influent for purchased finished
water
(only if wholesaler uses chlorine dioxide)
Before first chlorine dioxide application
Before application of ferrous salts, sulfur
reducing agents, or GAG
Finished water sample point
(plant effluent)
Three (3) distribution system sampling points2
CLO2
^f
^f
*f
*
IONC
Chlorite
and
Chlorate
only
Chlorate
Only
Chlorite
and
Chlorate
Only
'
Chlorite
and
Chlorate
Only
pH
^S
^f
EPABrOS
^f
^S
Temp.
'
1 . EPA is to analyze water samples for Bromate. See section 6.5 of this manual.
2. One near first customer, one in middle of distribution system, and one representative of maximum residence time in
the distribution system.
6-11
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Table 6-6. Additional Quarterly Monitoring for Treatment Plants Using Chlorine
Dioxide
Sampling Point
Before first chlorine dioxide application
Before first point of downstream
chlorine/chloramine application after chlorine
dioxide addition
Finished water sample point
(plant effluent)
ALD*
•
•
•
AOC* or BDOC*
(optional)
•
•
•
1. EPA is to analyze water samples for the following aldehydes: formaldehyde, acetaldehyde, propanol, butanol,
pentanol, glyoxal, and methyl glyoxal, and potentially, for other aldehydes. See section 6.5 of this manual.
* Analysis and submission of data for both assimilable organic carbon (AOC) and biodegradable organic carbon
(BDOC) are optional. Analytical methods for AOC and BDOC are listed in "DBP/ICR Analytical Methods
Manual," EPA 814-B-94-002.
6.5 Arranging for Special EPA ICR Analyses: Cyanogen Chloride, Aldehydes, and
Low-Level Bromate
Each PWS that uses chloramines as a disinfectant must collect samples for
cyanogen chloride analysis. In addition, a PWS which uses ozone, as well as a PWS
which uses chlorine dioxide, must collect samples for aldehydes and low-level bromate
analyses as required by the ICR [§141.142(a)]. The EPA laboratory in Cincinnati,
OH is the only ICR laboratory approved for cyanogen chloride, aldehydes and
low-level bromate analyses. Therefore, each affected PWS must coordinate with the
EPA laboratory hi Cincinnati, OH to monitor for these compounds.
6.5.1 Scheduling Sample Analyses
Cyanogen chloride and aldehyde samples have very short holding times as
indicated hi Table 4-3 of this manual. Therefore, the EPA laboratory will begin
sample analysis on the day of receipt of the samples, which allows for no errors in
scheduling. This being the case, sample collection and delivery must be closely
coordinated with the USEPA laboratory capacity. Coordination with the EPA
laboratory will involve the following activities:
• Reserving Calendar Dates: Each PWS must reserve a week of the month,
(from any of the first four weeks in a month) and one or more days of the week
6-12
-------
(Monday through Thursday), for collection of their samples. This reservation
will be maintained for the 18 month ICR monitoring period. Reservations will
be secured on a first-come, first-served basis. Therefore, as the calendar fills
up, a PWS may not receive its first choice for a sampling date, and should
provide at least two other choices of dates to reserve.
Sampling date reservation requests shall be submitted to EPA by each PWS
within 5 weeks (35 calendar days) following receipt of an applicability letter
which communicates EPA's final decision on how each treatment plant within a
PWS is affected by the ICR. A reservation request form will be enclosed with
the applicability letter for use by the PWS. The reservation request form should
be submitted by the PWS via letter or facsimile to the EPA at the following
address:
ICR Sample Coordinator
U.S. EPA/Technical Support Division
26 West Martin Luther King Dr.
Cincinnati, OH 45268
ATTN: Room 188
Facsimile No: (513)569-7191
The contents of the sampling date reservation request must include:
• The PWS name, address and public water system identification number
(PWSID)
• The name, street address, phone and facsimile numbers, and E-mail
address (if available) of the person(s) responsible for receiving each
sample kit.
• The treatment plant name(s), street address(es), ICR Plant ID
number(s), and types of disinfectants currently being used at each
affected treatment plant. In addition, any plans to change the
disinfectants currently utilized at an affected treatment plant, such as for
seasonal changes in raw water quality or other reasons, must be
identified by the PWS.
• First, second, and third choices for a sampling date reservation.
NOTE: Subsequent to receipt of a PWS reservation request, the EPA will
develop a schedule and contact each PWS to confirm its sampling date
reservation.
Start of Sampling: Each PWS shall begin ICR monitoring at their plant(s)
following receipt of their Initial Sampling Plan review letter from EPA.
Therefore, the EPA ICR Sample Coordinator will contact the PWS to confirm
6-13
-------
receipt of the EPA review letter and establish the month in which the PWS will
begin sampling. Unscheduled samples will not be accepted by the EPA
laboratory.
• Routine Sampling: Once the initial sampling date has been established, the
PWS should maintain contact with the EPA ICR Sample Coordinator for
routine communication such as acknowledging receipt of sample kits (with
appropriate contents) and confirming upcoming monthly and/or quarterly
sampling dates. Should a PWS miss a scheduled sampling day, the EPA ICR
Sample Coordinator will work with them to reschedule. However, each PWS
should notify the EPA ICR Sample Coordinator of any sample delivery
problem no later than the morning after a scheduled sampling day. In addition,
each PWS must notify the EPA ICR Sample Coordinator five (5) weeks (35
calendar days) in advance of any change hi the type(s) of disinfectant(s) being
applied at any affected treatment plant. For example, EPA must be notified of
a change from the application of chloramines at a treatment plant to the
application of chlorine. A change hi the supplier or product line for the same
type of disinfectant does not require notification by the PWS.
6.5.2 Shipping/Sample Kits
The EPA will ship an appropriate sample kit(s) to each PWS one week prior to
a scheduled collection date. The sampling kit will contain:
• Two (2) sample bottles for each analyte with preservatives for each sampling
location
• Gel ice packs (to be frozen upon receipt)
• Shipping and sampling instructions
• An information card and return address labels.
Sampling personnel will be instructed to fill two sample bottles for each
sampling location as a precaution. The second bottle will act as a back up should the
first bottle be lost due to breakage or other problem. Sampling personnel will also be
instructed to open each sampling kit upon receipt and to place the enclosed gel packs
in a freezer. The frozen gel packs should subsequently be used for shipping samples
to the EPA. Problems encountered with the sampling kits, such as receipt of an
incorrect sampling kit, missing components, or failure to receive an expected kit,
should be brought to the attention of the EPA ICR Sample Coordinator immediately to
correct the problem.
Return of the sampling kits after samples are collected will require the
repacking of sample bottles with the frozen gel packs from the kit. The kit should
then be sealed with the return address label attached to the outside. Finally, the kit
6-14
-------
should be sent via overnight carrier (priority - before noon delivery) to the ICR
Sample Coordinator at the address listed in Section 6.5.1 above.
Cyanogen chloride, adehydes and low-level bromate analyses will be provided
by EPA at no cost to the PWS. However, the PWS is responsible for the shipping
costs associated with sending the filled sample bottles to EPA.
6.5.3 Analytical Data from the EPA Laboratory
The EPA laboratory will report the results of their analyses to the PWS in hard
copy reports. In addition to the concentrations of the various analytes, the EPA
laboratory will report:
• The analytical method that was used to analyze each sample.
• The percent recovery of surrogate and internal standards that were added to
certain samples prior to analysis.
• Any samples (or analytes within samples) that failed to meet the QC criteria
and the reason for failure.
The PWS must enter the above information into the Water Utility Database
System, because monitoring data will be deleted from the ICR Federal Database if the
specified QC information is not available. Monitoring data will not be provided to the
PWS for samples or analytes within samples that the EPA laboratory determines as
failing QC criteria. (The QC information from the laboratory should be entered
instead).
The EPA laboratory will submit QC reports for entry into the ICR Federal
Database on a monthly basis. Copies of the applicable portion of the QC reports that
are associated with its samples will also be provided to the PWS to keep with its
records.
6-15
-------
-------
7.0 Particle Counting
For each treament plant required to conduct microbiological monitoring under the
provisions of the ICR [§141.141(b)], a PWS may choose to comply with the alternative
monitoring requirements described in the ICR [§141.143(a)(2)(iii)(A) and (B)] and in section
7.1 of this manual. This decision should then be communicated to EPA in the PWS response
to EPA's notification of applicability. A PWS which selects this approach for a treatment
plant does not have to submit finished water monitoring data for Giardia and
Cryptosporidium for that plant as required in the ICR [§141.143(a)(2)(ii)]. Instead, to comply
with the alternative monitoring requirements, the PWS must provide Giardia and
Cryptosporidium data, along with particle count data, for three (3) monitoring locations in
the treatment train. Furthermore, the PWS shall still comply with the microbiological
monitoring requirements for all other microorganisms except for Giardia and
Cryptosporidium, as described in the ICR [§141.143(a)(2)(ii)].
7.1 Alternative Monitoring Requirements
The alternative monitoring approach entails simultaneous monitoring of Giardia and
Cryptosporidium and collection of particle count samples under specific conditions and
locations in the treatment train. The simultaneous monitoring/sampling must occur in three
(3) required locations, and be designated by the PWS in the Initial Sampling Plan. Sampling
locations designated in the Initial Sampling Plan may be placed in a single treatment train but
must be representative of the treatment plant. The three (3) required locations are as follows:
• Treatment Plant Influent - Sampling location must reflect source water conditions prior
to any chemical additions or influences due to washwater return.
• Prior to Filtration - A single site representative of "on top of the filters" or in the
sedimentation basin effluent weirs.
• Immediately After Filtration - A single site prior to the addition of post-filtration
chemicals (e.g., pH adjustment, corrosion inhibitors, or disinfectants).
Giardia and Cryptosporidium samples must be collected one day per month for four
months during the 18-month monitoring period. These four months, however, must be
consecutive and occur during the first 12 months of the 18-month monitoring period. Giardia
and Cryptosporidium sampling and reporting must be conducted at the three (3) required
locations as specified in the ICR [§141.143(a)(2)(iii) and §141.143(c)(2)(i)] and in this
manual.
Particle count samples must be collected one (1) day per month for each month of the
18-month monitoring period. Also, the particle count samples must be collected on the same
7-1
-------
day and at the same sites where the Giardia & Cryptosporidium samples are collected. The
PWS choosing to conduct grab sampling is required to collect twelve (12) particle count
samples per day per sample site. A day is defined as 24 hours or the length of the filter run
(on the day sampled), whichever is shorter. The twelve particle count samples are to be
collected at equal increments throughout the sampling period (e.g., every 2 hours for a 24-
hour sampling period or every 1.5 hours for an 18-hour sampling period, etc.). Systems with
in-line continuous particle counters installed at each of the required sampling locations may
record twelve readings obtained at equal increments throughout the sampling day.
Utilities may use any type of particle counter capable of counting and sizing particles
in five specific size ranges. These size ranges are as follows:
Range 1: £3.00jLtm-4.99Aim
Range 2: k5.00/im-6.99/m
Range 3: k7.00/im-9.99/*m
Range 4: klO.OOjitm-14.99J[tm
Range5:
The utility must report the mean value of the twelve samples for each of the specified
size ranges. Particle counts are to be reported hi units of counts per milliliter (#Counts/mL)
for each size range. It is not necessary to report each of the twelve particle counts used to
determine the mean value for each size range.
All particle count data should be reported as specified in the ICR Water Utility
Database System.
7.2 Discrete Sample Container Selection and Preparation
Discrete samples are susceptible to particle contamination from sloughing of the
interior container surfaces. Recent studies conclude that supercleaned glass containers result
in less particle contamination than plastic or polytetrafluoroethylene (PTFE)[AWWA, 1992].
All samples should be collected in "supercleaned" borosilicate glass containers as described
below. Selected glass containers should be of adequate size to ensure multiple replicates of
each sample.
Properly cleaned glassware should contribute less than 5 particles per milliliter in the
lowest size range of interest (k3.00^m-4.99|imi). Any sample container cleaning technique
which meets this criterion is acceptable. A proven "supercleaning" technique is described
below [Goldgrabe, 1992 and Oilier, 1995].
7-2
-------
• Glassware "Supercleaning" Technique
Step 1. - Soak glassware for 30 minutes in a cleaning solution of distilled water and
2% Conrad (ultrasonic soap) solution.
Step 2. - Sonicate glassware containing cleaning solution for 5 minutes.
Step 3. - Rinse glassware with distilled water to remove visible traces of
cleaning solution.
Step 4. - Sonicate glassware with distilled water for 2 minutes.
Step 5. - Rinse glassware twice with particle-free water and invert to dry. Particle-
free water is reagent grade water which contributes less than one percent of
the number of particles anticipated for the size range of interest.
Step 6. - Cap bottles loosely for storage.
Selection of capping material is also important in minimizing contamination of the
sample. Research [AWWA, 1992] has shown that most contributions of particles from
various types of caps typically occur in the < 1.00 /mi size range. Users should select a
procedure that assures whatever caps they choose do not contribute particles in the specific
size range of interest.
7.3 Sampling
Collection of discrete particle count samples is straightforward. Samples of desired
volume are collected in supercleaned borosilicate glass containers and capped. Users should
follow manufacturer's recommended procedures for sampling and collection of appropriate
volumes for sample replicates. Prior to sample collection any particle contamination
attributed to the sample taps, lines, or the surrounding environment needs to be minimized.
Sample lines and taps should be constructed of materials that minirmre contribution of
particles to the sample stream. Replace sample lines which are encrusted, contain obvious
biological growth, or have become discolored. All sample tap materials and components
should be cleaned and lines thorqughly flushed prior to sampling. Care must also be taken to
collect samples in a dust-free environment.
Placement of sample taps and length of sample lines is also critical in assuring minimal
interferences to particle count samples. Sample taps should not be placed near points of
agitation which may cause particle shear and alter the particle size distributions of the sample
source. Pumping of samples through sample lines has also demonstrated particle shear and
should be minimized. Long running horizontal sample lines offer opportunities for particle
settling regardless of flow rate and should be avoided.
7-3
-------
Placement of sensors for continuous particle counters is also critical. Users should
install or place sensors in locations free from sources of electrical and mechanical
interference.
7.4 Sample Storage/Holding Conditions
Studies have shown that particle counts and subsequent particle size distributions can
change significantly when analysis is not performed immediately upon sample collection
[Oilier, 1995]. Numerous techniques involving variations of storage and analysis,
temperature and mixing conditions have shown limited success in re-establishing original
particle count characteristics. Ideally, samples should be analyzed immediately with no
holding or storage. For certain situations, immediate sample analysis may not be practical
(e.g., a utility having access to a single particle counter but responsible for particle count
analyses for several plants, etc.). Studies have shown that filter effluent samples can be held
longer (<8 hours) than filter influent samples (<4 hours) while maintaining particle counts
or particle size distributions within +/- 5 percent of the original condition [Oilier, 1995].
However, these studies were very limited and demonstrated the need for in-situ determination
of storage capabilities.
Utilities choosing to hold, store, or ship samples prior to analysis need to demonstrate
that particle counts and particle size distributions do not deviate more than 10 percent from
the results obtained if immediate analysis had been performed. This +/- 10 percent value
should be the deviation of the mean values (hi the particle size ranges of interest) of replicate
samples (2 runs of 3 replicates per run) analyzed immediately (or as quickly as conditions
allow) after sample collection. This demonstration will require conducting immediate on-site
particle counting of samples. The evaluation should include samples held under desired
conditions for various lengths of tune and determinations of maximum holding tune under
these conditions such that deviations less than +/-10 percent from original conditions are
maintained. Ideally, the same particle counter should be used for the entire storage/holding
study.
Techniques for sample storage have included cold storage of samples at 4°C with
acclimation of samples to ambient temperatures prior to analysis. Mixing of the sample prior
to analysis is also important. Sonication has been shown to be extremely destructive to
sample particle size distributions and should be avoided. Gentle swirling of the sample prior
to analysis produced the best results for maintaining original particle size distributions.
7.5 Sample Preparation and Analysis
All particle counter manufacturers provide guidance on acceptable procedures for
obtaining particle counts from samples. Care needs to be taken to ensure that contamination
7-4
-------
of the sample is minimized. Also, each particle count sensor has bee*h calibrated at a speWie
flow rate and must be operated within the allowable flow rates or results will not be' accUMe,
Particle counter manufacturers are very specific on the particle concentration limits of each
sensor. Do not exceed this allowable concentration. Users should conduct an over-
concentration check if they suspect samples will exceed allowable concentrations.
Specifications on conducting an over-concentration check may be obtained from particle
counter manufacturers or referenced material [AWWA, 1992].
Samples should be gently inverted prior to sampling to assure even distribution of
particles throughout the sample volume. Be careful not to over mix, agitate, or contaminate
the sample with the stir bar or other mixing apparatus.
7.6 Quality Assurance/Quality Control
Several parameters impact the use of laser particle counting to achieve an accurate and
precise depiction of numbers and sizes of particles contained hi a water sample. Instrument
calibration, standard sampling procedures, proper glassware preparation and minimization of
contamination of the samples are key to assuring good quality data. Particle counting is
typically very unforgiving. No corrections can be made in counts to account for use of a
sensor out of calibration or for analysis of a sample that exceeds allowable concentration
limits. Users need to adhere to. manufacturer's recommended sampling procedures and to
periodically verify instrument calibration and the use of contaminant-free sample containers
and caps.
Particle counters are calibrated by manufacturer's technicians either in the field or at a
central calibration laboratory. Daily calibration by utilities is usually not possible. Utilities,
however, should periodically verify the instrument calibration using monodisperse polystyrene
beads or spheres of certified size. Prepare a suspension of monodisperse spheres and analyze
using normal procedures. Repeat the process several tunes using different size monodisperse
spheres. Be careful not to exceed the concentration limits of the sensor for the prepared
suspensions. Should results deviate in excess of 10 percent hi all size ranges from the
calibration curve provided by the manufacturer, arrange for calibration of the sensor. Most
particle count manufacturers recommend annual calibration of sensors. Sensors must always
be calibrated following any mechanical changes or repairs.
Blank samples should be run for each sample set to assure that particle-free water,
glassware and caps are contributing less than 5 particles per milliliter in the particle size
ranges of interest [AWWA, 1992 and Standard Methods, 19th Ed.]. Fill each sample
container with particle-free water and analyze according to normal procedures. Should counts
exceed 5 particles per milliliter hi the lowest size range of interest repeat the cleaning process
or select another cleaning procedure.
7-5
-------
Particle count sensors have been calibrated using precise flow rates for sample input.
Flow rates of samplers should be measured and adjusted several times during analysis of a set
of samples. No deviation from the acceptable flow rate is permissible.
7.7 Particle Counting References
American Water Works Research Foundation, 1992. Evaluation of Panicle Counting
as a Measure of Treatment Plant Performance.
Goldgrabe, J.C., 1992. Particle Counting as a Method of Evaluating Conventional and
Biological Filter Performance - Master of Engineering Thesis, University of Cincinnati -
Department of Civil and Environmental Engineering.
Oilier, L.L., Bissonette, E.M., Summers, R.S. 1995. Interim Report - Evaluation of
Parameters Affecting Discrete Particle Counting - US EPA/OGWDW Technical Support
Division and University of Cincinnati College of Civil and Environmental Engineering.
Standard Methods for the Evaluation of Water and Wastewaster, 19th Edition, 1995.
Method 2560 - Particle Counting and Size Distribution (Proposed).
7-6
-------
APPENDIX A
Information Collection Rule (ICR) Water Utility Database System Reports:
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Information Collection Rule (ICR) Water Utility Database System Reports:
B.I « Monthly Sampling Plan by Location
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C-Series
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APPENDIX D
Procedural Requirements for Simulated Distribution System (SDS) and
Chlorine Demand (CLD) Samples
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Simulated Distribution System (SDS) Test. This test involves storing a sample of disinfected
water for a set period of time at a known temperature and pH and then analyzing the sample
for certain parameters. The ICR specifies Standard Method 5710 C for the SDS test. This
method provides a general description of the test, but users are given many procedural options
depending upon the purpose of conducting the test. For the ICR, the DBF concentrations in
the SDS sample will be compared to the DBF concentrations measured in a sample from the
distribution system. Therefore, the conditions under which the SDS test is conducted for the
ICR are specific to each water treatment plant.
The SDS test conditions (i.e., storage time and temperature) are selected based on information
about the distribution system equivalent (DSE) sample which is collected from the distribution
system of each water treatment plant. The DSE sample's detention time (time the water has
spent traveling from the water treatment plant to the sampling point in the distribution system)
is used as the basis for establishing the SDS storage time. The SDS sample should be stored
for a time period comparable in length to the DSE sample's detention time. The storage
temperature should be comparable to the temperature of the water in the distribution system
between the treatment plant and the DSE sampling point. In order to accomplish this, the SDS
sample should be maintained at the temperature measured at either the SDS sampling point or
the DSE sampling point. The goal should be to achieve a temperature within +2°C of one of
these temperatures.
The contact time of the SDS test begins when the sample is collected. Therefore the storage
part of the test is best conducted at the treatment plant where the sample is collected. If this is
not possible, then the sample should be transported to a nearby site for the test. The SDS
sample must not be iced or treated hi any other manner and shipped to off-site laboratories
until after the storage part of the test is completed and the sample is divided into aliquots with
the appropriate dechlorinating agents for the individual analyses.
There are many techniques available to maintain the SDS sample at a constant temperature
during the storage period. Some examples include (but are not limited to):
• using an incubator or constant temperature water bath set at the appropriate
temperature
• placing the SDS sample container(s) in an insulated container (e.g., an ice chest) and
allowing a constant flow of finished water to pass through the container to maintain the
sample at the finished water temperature
• placing the SDS sample container(s) hi a bucket in a sink and allowing a constant flow
of finished water to pass around the sample to maintain it at the finished water
temperature
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• suspending the SDS sample container(s) in the treatment plant clearwell to maintain it
at the finished water temperature
The goal should be to store the SDS sample for the same length of time as the detention time
of the DSE sample. Since the DSE detention time is estimated, the SDS storage time should
reasonably approximate (within ±25%) the DSE detention time.
At the conclusion .of the storage time, the SDS sample must be analyzed for several
parameters. The SDS sample must be divided by pouring it into sample bottles containing the
appropriate dechlorinating agents/preservatives. (This may be done at the storage site or at a
nearby laboratory, if the sample temperature is maintained during transport and the transport
time is factored into the storage time.) Care must be taken to not aerate the sample during this
transfer, in order to prevent the loss of volatile compounds such as THMs. (The samples for
THM, HAN, TOX, and CH analyses should be transferred first, because they contain volatile
analytes which can be easily lost during the pouring process.) The subsamples must be
analyzed by ICR approved laboratories using the appropriate analytical methods. Three
analyses must be conducted as soon as possible after the conclusion of the storage period:
chlorine residual, pH and temperature. Holding times for the remainder of the analyses begin
when the SDS sample is divided for individual analyses.
Chlorine Demand Test. The method cited in the ICR is Standard Method 2350 B. This
method describes how to perform the test, but it leaves the choice of chlorine dose,
temperature, pH and contact time up to the discretion of the person performing the test. In
order to meet the objectives of determining the chlorine demand resulting from the presence of
inorganics, specific guidelines are established which must be followed in order to comply with
the ICR. The test is to be conducted under conditions specific to each water treatment plant.
Chlorine Dose. If the first disinfectant (or oxidant) used in the treatment process is
chlorine and breakpoint chlorination is practiced, selection of an appropriate chlorine
dose should be based on what is used at this point in the treatment process to achieve a
desired free chlorine residual. Ideally, the same dose should be used, with the
exception that the goal for this test is to obtain a final free residual chlorine
concentration (as measured in this test) between 0.5 and 1.0 mg/L. In order to
consider the test results valid, the residual must be no less than 0.2 mg/L and no
greater than 1.5 mg/L.
If breakpoint chlorination is not practiced at the first point of chlorine application, then
the dose used for the chlorine demand test must be based on a dosage that will result in
a free residual chlorine between 0.2 and 1.5 mg/L (goal is between 0.5 and 1.0 mg/L,
as described above). Selection of an appropriate dosage may require several iterations
in the test. If the water contains ammonia-nitrogen as the major contributor to
inorganic chlorine demand, then the chlorine dose necessary for this test can be
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estimated by multiplying the ammonia concentration (as mg nitrogen/L) by 7.6 and
then adding an additional 1.0 mg/L. (This should provide a free residual chlorine
concentration near 1 mg/L.)
If chlorine is not the first disinfectant (or oxidant) used in the treatment process, then
the chlorine dose must be determined using the same guidelines as for when breakpoint
chlormation is not practiced.
Contact Time. Free residual chlorine should be measured approximately 5 minutes
after the chlorine is added to the sample. If the residual cannot be measured in the
dosed sample within 10 minutes, then the test must be repeated with a fresh sample.
This short tune period was chosen because reactions with the inorganics are expected to
occur quickly and it is physically feasible to make the free residual chlorine
measurement within the 10 minute time frame.
The free residual chlorine measurement must be made using the same method as is used
to make other free residual chlorine measurements for the ICR.
Temperature. The water sample must be at the same temperature as the process
water. This means that the test should be conducted on a freshly collected aliquot of
water. The temperature of the sample should be determined after the free residual
chlorine measurement is completed.
pH. The pH of the water must not be adjusted for this test. It should reflect the pH of
the water at the point of first disinfectant/oxidant addition in the treatment process.
The pH of the sample should be determined after the free residual chlorine
measurement is completed.
Reporting Requirements. The following data must be reported for this test:
Chlorine dose (mg/L)
Contact time (min)
Analysis date
Chlorine residual (mg/L)
pH (after contact time)
Temperature (°C) (after contact time)
EPA will calculate the chlorine demand by subtracting the chlorine residual from the chlorine
dose.
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