JULY 1997
'One Down, Seventeen to GoP
ICR Update
, Jim Walasek, Editor
, Technical Support Center
: August 1997
ICR Monitoring Begins!
ICR Update ISSUe Number 4 - This information sheet, the ICR Update, is the
fourth one to be issued by the Technical Support Center (TSC) of the Office of Ground Water and
Drinking Water (OGWDW). Future issues will be distributed as needed to maintain information flow
related to the ICR. ; *
NO More Diy RunS - That's right, ICR sampling has started in earnest! All ICR utilities
should have received formal approval hi late June to begin sampling in July. Sampling will continue for
18 months. Chapter 6 of the ICR Water Utility Database System Users' Guide covers monthly sampling.
The first step in monthly sampling is to develop a Monthly Sampling Plan to provide your field operators
with a list of the treatment information they will need to gather and the samples they will collect that
month. A summary of the procedure for conducting monthly sampling is on page 92 of the Users' Guide.
Remember to use the worksheets to record operational information at the tune of sampling and carefully
check the sample numbers on.the bottle labels to ensure that the proper bottles are being filled.
Message from EPA Sampling Coordinator - "The USEPA has been
receiving samples from plants using ozone, chlorine dioxide or chloramines for the last two weeks and I
want to commend the samplers on an excellent job. Most of the ;samples have been received before
10:00am and have arrived cold. To ensure the samples will be cold upon arrival, be sure to freeze the ice
packs solid. EPA includes 4 to 8 ice packs per kit. Please remember to return all the ice packs in the kit
when shipping the samples to the EPA. If samples are collected hi the morning then shipped late in the
afternoon, check the kits to see that the ice packs are still frozen before you ship. I realize it is difficult to
keep samples cold hi the hot summer months, but I also know the samplers are doing their best to keep the
samples cold. A waterproof black marker is included in each kit to record the date/time the samples are
collected and the samplers initials on the label. (Using a pencil or pen usually results hi a unreadable label
at this end.) And finally, please remember to send the D.I Monthly Sample Allocation to Laboratories
report with the collected samples. If you forget to include the D.l report in the kit, simply send it by FAX
to the Sampling Coordinator at (513) 569-7191."
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Lab Approval Nearly Complete -With the exception of a few Water Quality
Parameters (WQP) for utilities, ICR Chemistry Lab approval is now complete. As of July 15, 1997, 369
labs had been approved for chemical parameters. The list contains 62 commercial, 15 state, 289 utility,
and 3 labs classified as "other." Recall that there are 20 different parameters for which approval is
granted with a total of 52 different method/analyte combinations. Therefore, current approvals represent
3,903 method/analyte group approval decisions. As in the past, the list of approved labs is available from
the Safe Drinking Water Hotline (800-426-4791) or browse the OGWDW Home Page on the Internet at
http://www.epa.gov/OGWDW/regs.html.
Virus and Protozoa Lab Approval Complete - TSC has completed the
initial virus and protozoa lab approval process. Twenty-three analysts from thirteen labs have been
approved for virus analysis (4 commercial, 3 utility, 3 state/city, and 3 university labs). Fifty analysts
from 30 labs have been approved for protozoa analysis (9 commercial, 16 utility, and 5 city/state labs).
As always, the list of laboratories will be available through the Safe Drinking Water Hotline and also
appears on the OGWDW Home Page.
Lab Approval - TSC has completed approval of a total of 310 laboratories to
perform coliform analysis for ICR monitoring. This list includes 232 utility labs, 62 commercial labs, 7
state labs, and 9 other kinds of laboratories. The application period for approval of coliform labs is now
closed. Therefore, utilities which do not have an approved laboratory in-house will be required to
"contract" their samples to an ICR approved laboratory for analysis. The list of approved labs is available
through the Safe Drinking Water Hotline and is also accessible on the OGWDW Home Page.
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Ongoing Chem Lab Approval StatUS - Remember, since it is possible that a
lab could lose its approval status sometime during the 18 month sampling period, it is still important that
you check with your labs prior to each monthly sampling period to be sure that 'they are still approved.
We are hopeful that the labs will take the initiative and notify their clients if approval is "lost," but better
to be safe than sorry. The lab approval list on the Internet may also be used, but there is no guarantee that
it will always be "up to the minute" accurate.
If it does become necessary to use another lab, enter that lab name and lab ID into the utility
software (Laboratory Identification List window). It is then a simple matter to reassign the analyte groups
to the new lab in the monthly sampling plan. Remember, EPA does not learn which lab a utility has used
until the monthly data diskette is submitted (approximately 4 months after sampling).
ICR approved coliform labs must maintain state certification to remain approved for the entire 18-
month ICR monitoring period.
Ongoing PE Studies - Ongoing performance evaluation (PE) studies for protozoa and
virus laboratories consist of two PE samples per month per principal analyst (and per analyst for virus
labs) for the duration of ICR monitoring. Ongoing PE sample shipments for protozoa labs began in May
'97; ongoing PE sample shipments for virus began in July '97.
On the chemistry side, ongoing PE studies for the disinfection byproducts (DBFs) and surrogate
parameters consist of 6 quarterly sets of samples. Study 4 (designated PE 4) was the first of the six
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"required" PE studies for laboratories approved to perform ICR analyses for the DBPs and surrogates
(TOC, UV, Br and TOX). Samples were sent to all laboratories that had received approval or that had an
application in the review process. (The study samples were mailed only to laboratories that had submitted
a completed application by the February 14, 1997 deadline, because EPA is not reviewing late
applications for the DBF and surrogate parameters.) Laboratories, that failed one or more of the PE
samples for a method/analyte group for which they were seeking to obtain/maintain ICR approval, were
sent a make-up sample (PE 4M). The majority of the labs passed their make-up samples, but as a result of
the PE 4M, 22 labs lost approval for a method/analyte group for which they had been approved. The labs
were notified of these results on 7/8/97 and they were instructed that approval was lost effective that day.
A revised approval report has been posted on the Internet and at the Hotline reflecting these latest changes
in lab approval.
.P iL Study 5 - Talk about anxious, it seems as if we just finished PE 4M and already people are
calling to find out when the next study will be conducted! EPA intends to ship the next round of PE
samples (PE 5) during the week of September 8th. As in previous studies, EPA will send an
announcement letter to the approved labs approximately one month prior to the shipment date. The labs
will also have 1 month to analyze the samples and report their data back to EPA.
Demand TeSt - Several utilities and laboratories have called for clarification
on this test. The ICR Sampling Manual (pages D-3 and D-4) summarize the criteria that must be applied
for the test. These supersede the criteria published in Standard Method 2350 B. Therefore, you do
not need to do the calculations specified in 5a. of SM 2350 B. If you do not have a significant inorganic
oxidant demand, it is very likely that you cannot meet both the ICR and the SM 2350 B requirements.
(EPA has recently learned that there are commercially available chlorine standards which can be used for
low chlorine demand dosing.)
- The ICR Sampling Manual (EPA 814-B-96-001) incorrectly listed the
concentration for the TOX dechlorination agent hi Table 4-2 (page 4-13). It should have read... "Dechlor:
0.05 mg Na2SO3/mL of sample. (Use crystalline Na2SO3.) (A minimum of 0.005 mg Na2SO3/mL of
sample is required in SM 5320 B.)"
On a related topic, sample preservation for TOX, some labs have reported receiving improperly
acidified samples (see Tales from the Trenches). Please check that the correct (HNO3 or H2SO4) acid is
being used. Samplers may also need to predetermine the correct amount of acid necessary to lower the pH
to <2 by performing a "test" on a separate sample bottle to determine the proper volume of acid needed.
551.1 Buffer CallS - We have received several phone calls concerning the
buffer used in Method 551.1. Unfortunately, the buffer does not appear to be strong enough to overcome
the natural buffering capacity of all drinking waters. Here are some suggestions if you are having
problems meeting the 4.8 to 5.5 pH limits:
+ Make sure that the buffer is being prepared with 1% sodium phosphate, dibasic and 99%
potassium phosphate monobasic, by weight.
+ Use only fresh, ACS grade reagents.
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f
4 If you still can't meet the pH criteria after following the first 2 steps, increase the amount of buffer
added to 2 grams per 60 mL of sample.
If after folio whig these recommendations you continue to experience problems meeting the pH
requirements in Method 551.1, please contact David Munch at (513) 569-7843.
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PrOtOZOan Method Clarification - A number of analysts have asked if the
sample can be held after resuspending the pellet (Step 6, page VII-19) and prior to preparing the
membranes. Percoll-sucrose is osmotically stressful to the organisms, therefore the Percoll-sucrose
should be washed away as soon as possible, which is accomplished when the membranes are prepared.
Therefore the membranes should be prepared immediately after the flotation purification. If a break must
be inserted, do so before the flotation purification steps as indicated in the manual on page VII-19.
Correction to Protozoan Sampling Requirements -ihejo water
Utility Database System Users' Guide (EPA 814-B-96-004) requires the pH and temperature to be
reported when entering protozoan sampling information. Although this information is not explicitly
required by the method or the sampling guide, one cannot exit the sample data entry screen without
providing it Therefore, it is EPA's recommendation that the sampler take the pH and temperature when
sampling for protozoa if at all possible. Normally, protozoan sampling will probably be done
simultaneously with virus and/or chemistry where these parameters are required anyway. If protozoan
sampling is done at another time and it is a real hardship to lug along a pH meter (a thermometer could
hardly be called a hardship), then pH paper will do (or use a pocket pH meter, if available). If the
samples have been taken and no temperature or pH has been recorded, then the pH and temperature from
water quality parameters sampling can be used as a last resort.
Foiled by Decimal Place - The Protozoan and Enteric Virus Sampling Guide states on
page 15 that "at least 26 gallons/100 liters" of water should be sampled for protozoa in raw water and then
the tap should be turned off. Unfortunately, 26.4 gallons actually equals 100 liters and the method
requires that you sample 100 liters. Consequently, some of you have been making a valiant effort to
sample exactly 26 gallons of water and falling a little short (98.4L) of the 100 liters required. Please
sample at least 26.4 gallons and no more than 31.7 gallons (120 L) in the future.
The same holds true for the finished water, 264.2 gallons equal 1000 liters. For virus, 52.8 - 79.3
gallons equal 200-300 liters and 396.3 - 476.6 gallons equal 1500 - 1800 liters. See the correspondence
from Mary Ann Feige to the ICR Technical Contacts dated July 2,1997 for more information on volumes
to be sampled. *
V irilS Archiving - There are two criteria which trigger virus archiving: 1) any virus detection
in finished water; and 2) virus detection in raw water at a level of 1000 MPN/100 L or greater. If either of
these triggers is exceeded, both raw and finished water samples must be archived for the remainder of the
18-month monitoring period.
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If archiving is "triggered," the lab should contact the utility immediately. It is the utility's
responsibility to arrange to have the "archive triggered sample" sent directly to EPA by the laboratory. It
would behoove the utility to make arrangements with their laboratory before sample data are expected
regarding how to handle this possible situation.
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Data Entry Screens -For first time readers, this item doesn't refer to tiny
computer screens, but to the entering of protozoan and virus data into the ICR Water Utility Database
System. In the Utility Database System software there is a field named "Amount of Sample Assayed (L)"
on the protozoa and virus data entry screens. (The respective screens are shown on pages 121 and 123 in
the Users' Guide [EPA 814/B-96-004A]). The amount of sample assayed is the amount of the original
sample volume collected that is represented by the concentrated floated sediment that is examined under
the microscope, expressed in liters. The amount of sample assayed is computed as V*F*R, where V is
the sample volume collected, F is the fraction of eluted packed pellet volume subjected to flotation, and R
is the fraction of the floated sediment examined under a microscope. Your laboratory should report the
Amount of Sample Assayed and it should be entered into this field.
Coliform Data Reporting - All coliform samples (source and finished) must be
analyzed quantitatively in order to determine the level of organisms in each sample. You must enter your
total coliform data from your water samples but have a choice of entering data from either fecal coliforms
orE. coli. !..'..
If Colilert values are reported using the ICR Water Utility Database software for total coliform and
E. coli. they must be quantitative numbers and reported in the software database under "Multiple Tube
Fermentation Technique" (see p. 122 of the Users' Guide) since the Colilert values are estimated using
Most Probable Number (MPN) tables as are the MTF values.
Coliform data analyzed by the MF method is reported in the software database under the
"Membrane Filter Technique."
Initial Sampling PlanS Approved -Approval of Initial Sampling Plans(ISP) is
complete. You should have received an "official" approval letter from EPA stating that your ISP was
received and reviewed and was found to be acceptable. According to the rule [§141.141(f)(2-4)] your
system must begin monitoring in the month following receipt of the approval letter, which would be July
1997.
As. a reminder, the Initial Sampling Plan did not require a valid ICR Lab ID number to be entered
into the software because a finalized list of approved labs was not yet available. If you were among the
many that did not enter a valid ICR Lab ID into the ISP then please do so before generating your first
monthly sampling plan. Neither the "revised" ISP nor the monthly sampling plan should be submitted to
EPA. By the way, the Lab ID for the Cincinnati EPA lab is ICROH031.
Reporting TOC MonitOrhlg ReSUiltS - Many of you have dmgently been
monitoring TOC (and in some cases THM4/HAA5 or UFC-TOX) for about ten months now to
determine whether or not your treatment plant will be required to conduct a treatment study. In just a
few months it will be tune to mail the results to EPA to determine whether you're in or out of the
treatment study requirement. Here are a few tips to make the reporting process a breeze.
+ The results must be submitted by October 14, 1997. Early submissions are encouraged!
4 The data should be in a hard-copy format. !
+ Use Tables 5-1 and 5-2 in Section 5.0, Part 1 of the ICR Manual for Bench and Pilot-Scale
Treatment Studies. Table 5-1 includes general information for your PWS and plant, and Table
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5-2 is used to report the actual TOC, THM4/HAA5 and/or UFC-TOX data.
Be sure to include the results for each monthly or quarterly analysis as well as the average
values.
TOC concentration below the minimum reporting level should be reported as " <0.70" in Table
5-2. For the purpose of computing an annual average, assign a value of zero to entries of
<0.70.
Make sure you include the name, ICR Laboratory ID Code, and laboratory official contact
information for the lab which conducted your TOC analyses.
3. iStamp - If you know which treatment study option you plan to pursue by October,
save a stamp and send hi the proper application along with your TOC results. The application forms
can be found in Section 5.0, Part 1 of the Treatment Studies Manual. For example, if your annual
average TOC concentration is below the threshold requiring a study, then you can submit Table 5-5
along with Tables 5-1 and 5-2 to apply to avoid the treatment study requirement! Alternatively, if you
will be required to conduct a study, you can submit Table 5-11 and a Study Plan along with Tables 5-1
and 5-2.
Still Time tO Apply - The deadline to submit letters of intent to conduct joint studies or
to contribute funds to a cooperative research effort in lieu of conducting a study was May 14th. The
purpose of requiring these letters was to provide EPA with an indication of the number of joint studies
and treatment study alternatives to expect. However, these letters of intent are not binding since the
common source data necessary to pursue either of these options was not available at the tune the letters
of intent were required. Thus, a PWS can modify its proposal or pursue another treatment study option
in a formal application regardless of what was proposed in the letter of intent. Furthermore, a PWS
can submit a formal application to conduct a joint study or to contribute funds to a cooperative research
effort hi lieu of conducting a study even if a letter of intent was not submitted by the May 14th
deadline.
TDS - Total dissolved solids (TDS) measurements conducted during
membrane treatment studies are intended to provide a quick indication of membrane performance (with
respect to the rejection of inorganic parameters). The ICR Manual for Bench- and Pilot-Scale
Treatment Studies (Part 1, Section 4.5) states that either a conductivity meter or a TDS meter can be
used to measure TDS concentrations. However, if a conductivity meter is used, the conductivity
reading in //S/cm must be converted to TDS in mg/L when reporting the results. Standard Methods
(19th ed., 1995) lists method 2510 B for measuring conductivity with a probe, and the measurement of
TDS with a meter follows a similar procedure. The gravimetric method, Standard Method 2540 C,
should not be used for routine monitoring of membrane system performance during ICR
treatment studies. Although method 2540 C is an accepted method for measuring TDS, it is labor
intensive and is not well suited for routine monitoring of pilot- and bench-scale membrane systems.
JStUdy - For surface water plants, the one-tune tracer study on the clearwell to
determine the T10 must be completed before the first set of monthly ICR results are submitted. The
clearwell Tl 0 value in folio whig months is determined by flow-proportional interpolation of the clearwell
tracer study results. The tracer study should be conducted according to the SWTR Guidance Manual. We
encourage tracer studies to be performed at multiple flows, however, the results from a tracer study
conducted at a single flow will be accepted.
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.Rllll TlMie - The average filter run time, i.n hours, that must be reported with each set
of monthly sampling results is averaged over the one month sampling period, and is averaged over all
operating filters hi the plant.
Question Of the Month - When inputting monthly sampling data into the ICR Utility
Database and average monthly flow is requested, does a utility:
a) use the average for the previous month (e.g., June for July samples)
b) wait till the end of the month and then use that data
c) use the average flow for the month up to the date of sampling
d) make up a number
TSC's intrepretation is that "Average Monthly Flow" refers to the current calendar month; Therefore, if
samples are collected on July 7th then use the monthly average from July 1st through July 3 1st. Answer
b) .*
Want to try another one? When is a sample "Collection Date" not the date the sample is collected? The
ICR Water Utility Database software requires that a sample collection date and time be entered. The
"Collection Date" is used to determine when the sample holding time has expired. In the case of the SDS
sample the beginning of the sample holding tune is after the sample has been incubated and quenched.
Thus, the sample "Collection Date" and time for a SDS sample is when the sample is quenched. Answer:
When it's the SDS sample!
ICR, TSC, WQTC - Alphabet SOUlp? -TSC is planning to present an update
on the ICR hi a session at the American Water Works Association, Water Quality and Technology
Conference that will be held in Denver, Colorado, November 9 - 12, 1997. The title of the session is
"ICR Monitoring - Full Steam Ahead." The ICR session will include discussions of USEPA's
perspective about the progress of the 18-month monitoring, laboratory approval, treatment studies and
data reporting. The utility's perspective will be presented by the City of Phoenix, Water Service
Department. Come and join us!
from the Trenches" - Even though most utilities (and labs) piloted their ICR
procedures in the last few months, things still can and often do go awry hi the real world. Here are some
"Oops" items that were submitted by Andy Eaton of Montgomery Watson. Suggested "fixes" are also
included.
Protozoan - Utilities neglect to mark whether their meters are calibrated in gallons or liters and
the lab assumes volumes are out of the specified range. Fix - Be sure to mark units on form (and
don't forget to send form back with samples).
Utility sends protozoan equipment to lab hi addition to virus equipment. Fix - Know what gets
cleaned on site and what gets returned to the lab.
TOX - Utility neglects to adjust pH properly (not sufficiently acidic or uses wrong acid or
accidently uses base) Fix - Check pH with pH paper after adjusting. Be sure to use proper acid
(be sure instructions are clear).
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Sampling - Utility doesn't sample all locations from a single plant in 3-day window (or samples
micro in a different week from chemistry) Fix - Utility must understand the ICR requirement and
arrange changed schedules with all affected labs (in-house, contract, EPA). NOTE: Exception
to the above is for a plant sampling for Cyanogen Chloride, Aldehyde, and Low-Level Bromate.
These plants have been scheduled for a specific sampling date and must collect (and ship) the
samples on this day.
Hypochlorite - Utility thinks the hypochlorite sample is the solid hypochlorite stock chemical, not
the diluted chemical feed. Fix - Review the ICR Sampling Manual.
SDS - Utility runs WQP on SDS sample before incubation, not after. Fix - Remember that all
SDS analyses are after incubation.
MISC - Sample bottles re-labeled by utility for different test, therefore, improper preservative.
Fix - Call lab for additional bottles, or guidance.
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Sample numbers incorrect (e.g., XXX-01-97-XX raSTer than XXX-07-97-XX) leading to error in
D.I report and improper check digit. Fix - month is the calendar month, not the sampling period
number.
FedEx mistakes Roswell, NM for Roswell, GA and sends sample bottles to "aliens," therefore,
bottles not delivered to utility when scheduled. Fix - Use FedEx tracking and keep utilities
informed of expected delivery dates for bottles.
Continued Good Luck!
United States
Environmental Protection Agency
Office of Ground Water and Drinking Water
Cincinnati, OH 45268
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No G-35
Official Business
Penalty for Private Use
4300
EPA 815-N-97-004
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