United States
Environmental Protection
Agency
Office of Water
4601
EPA/814-F-9 6-003
May 1996
&EPA ICR Implementation
EPA ICR Fact Sheet Series
#3 - Treatment Studies
This fact sheet summarizes the treatment studies requirements for the
Information Collection Requirements (ICR) Rule as promulgated in May
1996. Treatment study applicability monitoring must begin no later than
August 1996 and the treatment studies must begin no later than April
1998.
Plants Required to
Conduct Applicability
Monitoring
Start of Treatment
Study Applicability
Monitoring
TOC monitoring
UFCTOX monitoring
Monitoring locations
Distribution System
DBF option
Public Water Systems Affected
Plants in Categories A, B, C, D and G (defined in Tables 1 and 2 of
§141.141(b)) must conduct treatment study applicability monitoring.
These categories include the following treatment plants:
• All treatment plants which serve 100,000 persons or more (Categories
A&B).
• The largest treatment plant operated by a PWS which serves 100,000
persons or more if no plant operated by the PWS serves 100,000
persons or more (Categories C & D).
• The largest ground water plant operated by a PWS with a ground water
population served of 50,000 to 99,999 persons (Category G).
Monitoring Required
In August 1996, plants in Categories A, B, C, D and G must begin
treatment study applicability monitoring to determine: (1) if the treatment
plant precursor levels are low enough to avoid the treatment study
requirement, and in some cases (2) if two or more plants qualify for a
common source designation. The applicability monitoring requirements are:
• 12 consecutive monthly total organic carbon (TOC) samples are
required for all A, B, C, D and G Category treatment plants.
• 12 consecutive monthly total organic halide (TOX) samples evaluated
under uniform formation conditions (UFCTOX) may be necessary to
demonstrate that two or more plants are using a common source.
• Surface water plants monitor influent water while plants using only
ground water monitor finished water.
• In addition to TOC monitoring, surface or ground water plants using
only chlorine as the primary and residual disinfectant may conduct
quarterly monitoring of trihalomethanes (THM4) and haloacetic acids
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Avoidance based
onTOC
Avoidance based
on Distribution System
DBFs
5 Study Options
Individual Study
Common Source Study
Joint Study
Buy Out
Grandfathered Study
Data Deadline
Application Deadline
Study Deadlines
(HAAS) at four points in the distribution system to determine if the
plant qualifies to avoid the treatment study requirement.
Treatment Study Avoidance
Results from the 12 months of applicability monitoring can be used to avoid
the treatment study requirement if:
• The influent TOC concentration does not exceed 4.0 mg/L for
treatment plants using surface waters or ground waters under the direct
influence of surface water.
• The finished water TOC concentration does not exceed 2.0 mg/L for
treatment plants using only ground waters.
• The treatment plant is using only free chlorine as the primary and
residual disinfectant AND the mean of four quarterly average THM4
samples is less than 40 jig/L AND the mean of four quarterly average
HAAS samples is less than 30
Treatment Study Options
Treatment plants that do not qualify to avoid the treatment study requirement
have the following options:
• Plants can conduct individual treatment studies: plants serving
^500,000 persons must conduct a pilot-scale study, and plants serving
< 500,000 persons must conduct either a bench- or pilot-scale study.
• Multiple plants using a common source and operated by a single PWS
are only required to conduct a single treatment study. .
• Multiple plants using a common source and operated by different PV/Ss
may apply to conduct a joint treatment study.
• Plants may apply to buy out of the treatment study requirement by
contributing to a cooperative research fund if another common source
plant is conducting a treatment study.
• Plants may apply to grandfather data from a previous treatment study to
meet the treatment study requirement.
Applying for Treatment Study Options and Important Deadlines
• Part 1 of the "ICR Manual for Bench- and Pilot-Scale Treatment
Studies" describes the application process for treatment studies.
• All treatment study applicability data must be submitted no later than
October 1997.
• An application to grandfather data from a previous study must be
submitted no later than February 1997.
• Applications for all other treatment study options must be submitted no
later than November 1 997.
• Treatment studies must begin no later than April 1998.
• The final study report must be submitted no later than July 1999.
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Bench, RBSMT studies
must evaluate 2
membranes at 4
recoveries during each
quarter of 1 year
Bench, SEBST studies
must evaluate 2
membranes during
each quarter of 1 year
Bench, long-term
SEBST studies must
evaluate 1 membrane
for at least 6600 hours
Pilot-scale membrane
studies must evaluate
1 membrane for at
least 6600 hours
Evaluate membrane
productivity & product
water quality including
SDS-DBPs
Bench-Scale Membrane Study Requirements
Three (3) options are provided for bench-scale membrane studies:
1. Rapid Bench-Scale Membrane Test (RBSMTV
• Evaluate 2 membranes with molecular weight cutoffs (MWCO) less
than 1000 Daltons.
• Evaluate four recoveries (30%, 50%, 70% and 90%) for each
membrane, with all other operating parameters held constant.
• Evaluate each membrane at each recovery during each quarter of one
year.
2. Single Element Bench-Scale Test (SEBST)
• Evaluate 2 membranes with MWCOs less than 1000 Daltons.
• Evaluate a minimum element size of 2.5 inches in diameter by 40
niches in length (2.5" x 40").
• Operate the system at a recovery of 75 ± 5 %.
• Operate each membrane continuously for four weeks during each
quarter of one year.
3. Long-Term Single Element Bench-Scale Test
• Evaluate 1 membrane with a MWCO less than 1000 Daltons.
• Evaluate a minimum element size of 2.5" x 40".
• Operate the system at a recovery of 75 ± 5 %.
• Operate the system for at least 6600 hours over the course of one
year. . . .
Pilot-Scale Membrane Study Requirements
• Evaluate 1 membrane with a MWCO less than 1000 Daltons.
• Evaluate a minimum element size of 2.5" x 40".
• Operate the system at a recovery of at least 75 %.
• Operate the system for at least 6600 hours over the course of one year.
• The system must consist of at least 2 stages with at least 2 pressure
vessels in the first stage and at least 1 pressure vessel in the second
stage (i.e., a 2-1 array).
• Each pressure vessel must contain at least three elements.
Monitoring Membrane Systems
• The productivity of membrane systems must be assessed hi terms of
water flux, required net driving pressure and cleaning frequency.
• The feed and permeate streams must be analyzed for pH, temperature,
turbidity, total dissolved solids, alkalinity, total hardness, calcium
hardness, TOC, UV^ and bromide.
• Simulated distribution system tests must be conducted on the feed and
permeate streams to evaluate the chlorine demand and the formation of
TOX, THM4 and HAA6.
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Bench-scale GAC tests
using the RSSCT
Evaluate EBCTs of 10
and 20 minutes
12 effluent samples
Pilot-scale columns
Evaluate EBCTs of 10
and 20 minutes
15 effluent samples
Evaluate influent and
effluent SDS-DBPs as
well as other water
quality parameters
Data collection
software
Summary report
For more information
Bench-Scale GAC Study Requirements
• Use the rapid small-scale column test (RSSCT) for the bench-scale
evaluation of GAC.
• Evaluate two empty bed contact times (EBCT): 10 and 20 minutes.
• Evaluate each EBCT each quarter of one year.
« Operate each column until 70% breakthrough of TOC or the attainment
of steady-state precursor removal.
• Sample the effluent from each column at least twelve times over the
course of a quarterly run for simulated distribution system DBFs and
other water quality parameters.
Pilot-Scale GAC Study Requirements
• Use continuous-flow columns with a minimum diameter of 2 niches for
pilot-scale GAC studies.
• Evaluate two empty bed contact times (EBCT): 10 and 20 minutes.
• Operate each column until 70% breakthrough of TOC or the attainment
of steady-state precursor removal.
• If breakthrough occurs for the 20-minute EBCT prior to 4000 hours
runtime, men a second run shall be conducted at both EBCTs.
• Sample the effluent from each column at least fifteen times over the
course of a run for simulated distribution system DBFs and other water
quality parameters.
Monitoring GAC Systems
• The influent to the RSSCT or pilot-scale GAC column must be analyzed
for pH, temperature, turbidity, alkalinity, total hardness, calcium
hardness, ammonia, TOC, UV^ and bromide.
•. The effluent from the RSSCT or pilot-scale GAC column must be
analyzed for pH, temperature, TOC and UV^.
• Simulated distribution system tests must be conducted on the influent
and effluent streams from the GAC column to evaluate the chlorine
demand and the formation of TOX, THM4 and HAA6.
Treatment Study Final Reports
• A diskette containing data collection software will be sent to PWSs
conducting treatment studies.
• The treatment study data must be entered in this data collection
software and the diskette returned to EPA.
• A summary report must be submitted along with the data diskette.
• Both process performance and cost information must be submitted.
Contact the Safe Drinking Water Hotline, 1-800-426-4791.
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