United States
            Environmental Protection
            Agency
            Office Of
            The Administrator
            (A101F)
171-R-92-024
August 1992
vvEPA
Affordable
Drinking Water Treatment For
Public Water Systems
Contaminated By Excess Levels
Of Natural Fluoride

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                           DISCLAIMER

This report was  furnished to the U.S. Environmental Protection
Agency by  the student identified  on the  cover page,  under a National
Network for Environmental Management  Studies  fellowship.

The  contents are essentially as  received from  the  author.  The
opinions, findings,  and conclusions  expressed  are  those  of the author
and  not necessarily  those of the  U.S. Environmental  Protection
Agency.  Mention,  if any, of company, process, or product names  is
not to be considered as an endorsement  by the U.S.  Environmental
Protection  Agency.

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                NATIONAL NETWORK  FOR
         ENVIRONMENTAL MANAGEMENT STUDIES
                   RESEARCH  REPORT
        AFFORDABLE DRINKING WATER TREATMENT
             FOR  PUBLIC WATER SYSTEMS
CONTAMINATED BY  EXCESS LEVELS OF NATURAL FLUORIDE
                          BY
                  CARL MASTROPAOLO
                    DECEMBER 1991
                                       U 3  Environmental Protection Agency
                                       Region 5, Library (PL-12J)
                                       77 West Jackson 6ouiaydid,  IZifl rioor
                                       Chicago, !L  60604-3^90

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                     TABLE OF CONTENTS
                                                        page

STUDY APPROACH	   2


HISTORICAL PERSPECTIVE	  4


SOURCES OF FLUORIDE IN GROUNDWATER	11


GEOGRAPHIC AREAS WITH EXCESS FLUORIDE	13


COMPLIANCE OPTIONS	15


AVAILABLE TREATMENT TECHNOLOGIES	17


MORE ON POINT-OF-USE AND POINT-OF-ENTRY	26


TREATMENT COSTS	 .31


SUMMARY OF CONSTRUCTION COSTS		39


SUMMARY OF ANNUAL COSTS	41


MISCELLANEOUS NOTES REGARDING COST CALCULATIONS	45


APPLICATION TO VIRGINIA PUBLIC WATER SYSTEMS	47


CONCLUSIONS	51


RECOMMENDATIONS	55


REFERENCES	57


APPENDIX A: COST CHARTS FOR TREATMENT  TECHNOLOGIES	A-l

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 STUDY APPROACH

   This study was performed during the period 10 June through
 early September  1991.  The author researched the published
 literature regarding  fluoride occurrence in groundwater,
 remediation techniques associated with its removal, and the dose-
 related health effects associated with exposure.  Sources
 explored  included texts and professional journals, and technical
 articles  written by the United States Environmental Protection
 Agency, or by individuals or companies under EPA contracts.
 Professional papers and water resources investigations prepared
 by the United States  Geological Survey were also consulted.

   In addition,  over fifty telephone conversations unearthed
 information deemed relevant for inclusion in this report.
 Telephone calls  were  placed to other EPA regional offices,
 headquarters EPA in Washington DC, the EPA research facility in
 Cincinnati, various state level drinking or groundwater offices,
 the National Institute of Health, medical and dental experts,
 United States Geological Survey offices, university researchers,
 public water system managers and operators, private contractors
 involved  in the  water industry, and other individuals.  A number
 of these  contacts submitted written or faxed information, a
 considerable amount of which has been referenced in this report.

   An attempt was made*to quantify various  treatment technology
 construction, operation and maintenance, chemical, and disposal
 costs, and to determine whether a centralized treatment facility,
 or a point-of-use/point-of-entry treatment is more cost effective
 based upon the average flow rate of a given public water system.
 Cost figures were primarily generated by updating data contained
 in an extensive  cost study of small water treatment facilities
 performed by Culp/Wesner/Culp under EPA contract during the
 period September 1981 through January 1984  (84-1).

   We feel that  the  cost  and  technology information  acquired in
 this research could be applied to any public water system
 experiencing excessive fluoride concentrations.   We attempted to
 specifically apply this information to a group of southeastern
 Virginia public water systems regulated by the Commonwealth of
 Virginia which experience excessive fluoride groundwater
 concentrations.

   We wish to  note that there were many avenues  which  we  could
 not explore since this research project lasted for only three
 months.   We have tried to highlight some of these in the hope
 that further studies might be performed.   Specifically we hope
 that further research is  able to determine  costs associated with
 the following compliance  options:   drilling a new well;
 connecting or hauling water from another public water system;
point-of-entry treatment;  and distributing  bottled water.

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   A draft copy of this report was  circulated  among various
individuals both within and outside the Environmental Protection
Agency for their comments.  The author of this report agreed to
review these comments and incorporate them into the final version
of this report during a one week period in December 1991.  It was
determined however that a considerable amount of research time
would be required in order to properly address some of the
comments submitted.  The author has attempted to address all
comments and to note within the text of this report those
comments which could not be fully addressed due to the short time
frame set aside for developing the final version.

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 HISTORICAL PERSPECTIVE

   The physiological effects of fluoride upon human health have
 been  studied  since  the  early part  of  this  century.  As  early as
 1925  (25-1) dental  fluorosis,  a condition  characterized by
 discoloration and softening of teeth  (90-4), was  attributable to
 drinking water.

   During the  1930s and 1940s, scientific research established
 that  the incidence  of dental fluorosis was directly related  to
 the fluoride  content of drinking water.  High fluoride  exposure
 was also linked  to  increased bone  density  of the  spine  and
 pelvis, lenticular  opaqueness  of the  eye,  and brittleness and
 blotching  of  fingernails  (53-1).

   In response to growing scientific evidence regarding the
 negative effects of exposure to excessive  fluoride, the United
 States Public  Health Service  (PHS) established a  range  of
 recommended concentrations for fluoride in drinking water (1.4 to
 2.4 mg/L), dependent upon the  maximum daily air temperature  of
 the location  of  the water supply (62-1).  A temperature dependent
 value was  required  to compensate for  increased water consumption
 in warmer  climates.

   Several reports and studies in the 1960s and 1970s established
 both the risks of high fluoride dosing and the benefits of
 minimal exposure.   Low drinking water concentrations of fluoride
 were deemed responsible for inhibiting dental caries (tooth
 decay), while higher concentrations were linked to permanent
 tooth fluorosis, and skeletal  fluorosis, the latter responsible
 for aberrations  ranging from stiffness to crippling rigidity  (65-
 1, 70-2, 70-3, 71-1, 73-2, 73-3,  73-4, 75-2).  One of these
 studies (71-1),  performed by the National Academy of Science,
 determined that  dental tissues and the skeleton accumulate
 fluoride more rapidly during formation and mineralization thus
 negatively impacting children up to about 10 years old  more so
 than the general population.

   Through continued scientific research,  it  became apparent that
 an optimal intermediate concentration of about 1 mg/L would
 produce the benefit of reduced tooth decay without the  risks
 associated with higher doses (70-1).

 1975 National Interim Primary Drinking Water Regulations

   In  1975, pursuant to  the 1974  Safe  Drinking Water Act, the
United States Environmental Protection Agency promulgated the
National Interim Primary Drinking Water Regulations, establishing
maximum contamination levels  (MCLs) for ten inorganic
contaminants,  including fluoride,  as well as for, turbidity,
coliform bacteria,  pesticides,  herbicides,  total trihalomethanes,
and radionuclides.   EPA adopted the Public Health Service

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temperature dependent standards for fluoride (1.4 to 2.4 mg/L).

   As part of its on-going regulatory review process,  EPA
requested the advice of the National Academy of Science
concerning MCLs for fluoride and other contaminants.  In 1980 the
National Academy of Science concluded that while "dental mottling
and changes in tooth structure may develop in children when
fluoride levels exceed approximately .7 to 1.3 mg/L",  consumption
of drinking water with concentrations as high as 4 mg/L provides
a beneficial reduction in osteoporosis (80-2).  Scientific
evidence was therefore suggesting that concentrations between
about 1.3 and 4.0 mg/L produced both positive and negative
effects.

   In 1981,  the state of South Carolina petitioned that EPA
delete fluoride from the Primary Drinking Water Regulation and,
in 1984, formally sued EPA seeking faster action on the petition.
A consent decree signed by both parties on January 18, 1985 set
EPA about the task of re-evaluating the fluoride MCL.

   Considerable scientific evidence had been accumulating in the
interim.  Responding to an EPA request to examine "the issue of
the relationship of fluoride in drinking water and the health
aspects of dental fluorosis", former Surgeon General Koop
concurred with the conclusion reached by the PHS's ad-hoc
committee on dental fluorosis: "No sound evidence exists which
shows that drinking water with the various concentration of
fluoride found naturally in public water supplies in the United
States has any adverse effect on dental health as measured by
loss of function and tooth mortality"  (82-2).

   And in 1984, in response to an EPA request to review the non-
dental effects of fluoride, Koop stated (84-5):

     Adverse health effects were defined by the
     committee as death  (poisoning), gastrointestinal
     hemorrhage, gastrointestinal irritation,
     arthralgias, and crippling fluorosis.  No record
     exists of poisoning death from  fluorides consumed
     in drinking water.  There are no  scientifically
     credible reports of gastrointestinal effects at
     levels found in drinking water.   Clinical
     experience  suggests that arthralgias are not
     likely to occur in patients who are on therapeutic
     regimens of less than 20 milligrams per day.
     Crippling fluorosis has been detected in some
     people who  have consumed 20 mg  or more of fluoride
     per day from all sources for twenty or more years.
     Such a situation does not exist in the U.S. today.

   Meanwhile, in 1984, the World Health Organization deemed
fluoride concentrations exceeding 1.5  mg/L as excessive  on the

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 basis of mottling of teeth (84-4).

 1985  RMCL Proposal

   In proposing a  recommended maximum contamination level  (RMCL)
 for  fluoride in  1985,  EPA extensively reviewed  literature,  public
 comments,  and professional advice  from  diverse  sources  and
 concluded (R85-1):

   * exposure to fluoride  levels of about 1 to 2 mg/L can
     contribute to dental  fluorosis, frequency and severity
     increasing with that  of the fluoride concentration
   * exposure to levels between 1 and 4 mg/L have been
     shown to contribute to reduced dental caries formation
   * exposure to levels greater than 4 mg/L "can result in
     asymptomatic  osteosclerosis (increased bone density) in
     a small percentage of individuals"

 As a  result  of its review,  EPA established an RMCL of 4.0 mg/L to
 prevent  crippling  skeletal fluorosis, and planned to propose a
 secondary maximum  contamination level (SMCL) of 2.0 mq/L to cruard
 against  mottling of  teeth.

   The Office of Management and Budget,  as well as medical
 dental,  and  public health  groups throughout the United  States
 opposed  EPA's handling of  the naturally occurring fluoride  issue
 and its  assessment of negative fluoride effects in the  period
 between  the  promulgation of the National Interim Primary Drinking
 Water Regulations  and the  establishment of the RMCL.

   In October 1979 the American Dental Association House of
 Delegates "resolved, that  based on present knowledge, it is the
 opinion  of the American Dental Association that the natural
 fluoride levels of drinking water in the United States do not
 constitute a health hazard".  The resolution was supported by the
 American Association of Public Health Dentists.

   In March 1980  the Association of State and Territorial Dental
 Directors unanimously approved a resolution that opposed EPA's
 inclusion of fluoride in the primary standards of the National
 Interim Primary Drinking Water Regulations at levels of twice the
 optimum and above  as a contaminant and health hazard.  It further
 requested that "fluoride be changed from the Primary to the
 Secondary Drinking Water Regulations".

   In a May 7,  1982 letter to  the HQ EPA Administrator Anne
 Gorsuch, the American Medical Association concurred with the
 previously stated American Dental Association position indicating
 that AMA was "unaware of any unequivocal evidence showing that
naturally occurring fluorides have adverse effects on the public
health".

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   In March 1985  EPA requested the Office  of  Management and
Budget to review the draft notice of proposed rulemaking (NPRM)
which would establish the RMCL for fluoride.   In response,  the
OMB questioned "the need for national health standards for
fluoride in view of the infinitesimal health risk and quite small
population exposure" (85-5).  Using EPA's own NPRM figures, OMB
indicated that only 184,000 people were served by the 282 public
water systems (PWSs) which then had fluoride concentrations
exceeding 4 mg/L.  "This is less than 0.1% of the total
population of 190-200 million served by the 60,000 drinking water
systems that are subject to the SDWA."  In referring to the fact
that only 17,000 people were then exposed to concentrations
exceeding 6 mg/L, and 3,000 to 4,000 to those exceeding 8 mg/L,
OMB further commented that "at all these concentrations, the
Surgeon General and his "world class" panels have found no
demonstrated cases of adverse affects on the health of persons".

1986 Final Fluoride Rule

   Prior to establishing the primary MCL for  fluoride at 4.0
mg/L, EPA solicited comments relating to three options under
consideration for the regulation of fluoride:

     Option 1: "Propose a National Revised Primary Drinking
               Water Regulation to protect against moderate
               and severe dental fluorosis and set the RMCL
               at 1 or 2 mg/L, as appropriate" (R86-1)
     Option 2: "Propose a National Revised Primary Drinking
               Water Regulation finding that crippling
               skeletal fluorosis (but not dental fluorosis)
               is an adverse health effect and set the RMCL
               at 4 mg/L; propose a National Secondary
               Drinking Water Regulation to warn against
               dental fluorosis (a cosmetic effect),
               setting a secondary MCL at 2 mg/L." (R86-1)
     Option 3: "Delete fluoride from the National Primary
               Drinking Water Regulations based upon a
               finding that levels of fluoride in U.S.
               drinking water are not associated with any
               adverse health effects; propose a Secondary
               MCL of 2 mg/L to warn against the cosmetic
               effects of dental fluorosis." (R86-1)

"The Agency proposed Option 2 for the regulation of fluoride.  In
making this decision, the Agency concluded that 'based upon the
information available at this time, EPA believes that crippling
skeletal fluorosis is an adverse health effect that can be caused
by excessive amounts of fluoride in drinking water, and that 4
mg/L is the level below which no known or anticipated adverse
effect on health of persons occur and which allows an adequate
margin of safety.  Thus, an RMCL is proposed at 4 mg/L' (50 FR
20164).  The Agency stated that it now believed that

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 objectionable (moderate and severe)  dental  fluorosis is not an
 adverse health effect under the Safe Drinking Water Act,  but
 rather a cosmetic effect that would  adversely affect public
 welfare and it should be regulated under the  NSDWRs.   The Aqencv
 therefore stated that at the time  of proposal of the MCL for
 fluoride,  it planned to propose a  Secondary MCL at  2 mg/L."
 (R86—1).

   In  responding to  comments  relating to these three options  EPA
 considered various independent study results,  some  of which were
 submitted by commenters.   Some of  the studies cited in the final
 fluoride rule,  and their impact upon the decision making  process
 follow:                                                 -*  r      ,-

   A draft National  Institute of Dental Health study  (84-8)
 submitted by a  commenter,  concluded  that the  consumption  of'
 drinking water  containing 4  mg/L or  less has  no  adverse effects
 upon the teeth  and that increasing fluoride exposure from .7 to  4
 mg/L results in increasing the level  of  dental attrition,  but
 does not pose a concern of clinical  importance.

   Commenters also noted two independent studies which cited two
 cases  of crippling skeletal  fluorosis suffered by individuals who
 had been exposed to  fluoride  concentration  between  2.4  and 3 5
 mg/L and 4.0 and 7.8 mg/L, respectively  (71-2, 65-2).   it is'
 estimated  that  these individuals consumed about  6 liters  of water
 per day  each, and  consumed large undetermined quantities  of tea
 a beverage with a  considerably  higher fluoride concentration than
 most foods,  97.0 parts  per million (70-2).

   EPA also cited the Knox Report,  an epidemiological study
 performed by the British government  (85-7), and  concurred  with
 its findings  that  there  is no evidence that naturally or
 artificially  occurring  fluoride is capable  of inducing cancer.

   On April 2, 1986, after review of  all pertinent scientific
 data,  EPA promulgated the  final fluoride rule  (R86-1),
 establishing  an enforceable MCL of 4.0 mg/L "to protect against
 crippling skeletal fluorosis" and a non-enforceable SMCL of 2.0
 mg/L "to protect against objectionable dental fluorosis"  (R86-1).
 Activated alumina  adsorption and reverse osmosis were identified'
 as best technologies generally available  (BTGA-this is currently
 known  as BAT: best available technology) for purposes of fluoride
 variances.

 1991 Public Health Service Fluoride Report

   Since the 1986 ruling the most comprehensive toxicological
 analysis of the effects of fluoride was rendered by the Public
Health Service's February 1991 report entitled Review of
Fluoride. Benefits and Risks.  The PHS addressed cancer, dental
 fluorosis, and skeletal disorders as  the significant health

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conditions in their evaluation of the health risks associated
with fluoride intake.  A brief summary of the report's findings
related to each of these conditions follows:

Regarding cancer: Optimal fluoridation does not pose a cancer
risk to humans as evidenced by extensive human epidemiological
data.  Two methodologically acceptable animal carcinogenicity
studies published in 1990 by Proctor and Gamble (90-6), and the
National Toxicology Program, Public Health Service, Department of
Health and Human Services (90-7) "taken together	fail to
establish an association between fluoride and cancer".

Regarding dental fluorosis; Total exposure to fluoride has
increased since the 1940's due to the introduction of fluoride
into dental products.  Accordingly the incidence of dental
fluorosis has increased even in non-fluoridated areas.  The PHS
recommends that unnecessary and inappropriate fluoride exposure
be reduced.

Regarding skeletal disorders; "Crippling skeletal fluorosis is
not a public health problem in the United States, as evidenced by
the reports of only five cases in 30 years."  It was established
that two of these subjects consumed between 15 and 20 mg/day for
20 years.  PHS noted that, in foreign literature, Moudgil, et al
(86-2) had identified 41 children with evidence of crippling
skeletal deformities who had consumed water with fluoride
concentrations ranging from 7.3 to 29 mg/L. PHS concluded "human
crippling skeletal fluorosis is endemic in several countries in
the world, but is extremely rare in the United States".

Current Opinions Regarding EPA Policy

   Some medical and toxicological experts still oppose EPA
regulatory policy regarding fluoride.  While the primary MCL for
fluoride has been established to guard against crippling skeletal
fluorosis, those in opposition refer to studies which indicate
that the probability of occurrence of the disease in the United
States is virtually zero.

   Other opposition centers upon views regarding the effects of
dental fluorosis, with some experts favoring the reestablishment
of a temperature-dependent standard, since water consumption is
known to increase with rising temperatures.  This is the view
still held, for example, by the National Institute of Health in
considering the optimal fluoride exposure to reduce dental
caries.  Other dissenters still view dental fluorosis as a
cosmetic problem and not a health problem, and cite studies
indicating greater incidence of dental fluorosis in non-
fluoridating areas, the result of consumer use of increasing
numbers of fluoridated products, including dental care items.
Further, they note, dental fluorosis only adversely effects teeth
of young children, a known factor which can be readily

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compensated for by means other than to treat an entire
community's water supply.
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SOURCES OF FLUORIDE IN GROUNDWATER

   Fluoride is the most electronegative element having a valence
of negative 1 and is the smallest atom of the halogen family.  It
is not found in nature in the elemental state but rather it
combines with other elements to form fluoride compounds.

   Fluoride is the anion (negatively charged ion)  of the fluorine
atom.  Under the proper conditions in a water environment,
fluoride compounds may dissociate to produce fluoride ions in
solution.

   Fluoride occurrences in groundwater have two sources:
anthropogenic and natural.

Anthropogenic Sources

   Anthropogenic fluoride sources originate with the use of
various forms of fluoride-bearing minerals or reagents  in
industrial processes.  Effluent from electroplating operations
may contain fluoride due to surface preparation or electroplating
with metal fluoborate salts.  Wastewater from steel production
facilities contain fluoride, attributable to pickling of
stainless steel with hydrofluoric acid.  Wet scrubbing  of
emissions from furnaces in which aluminum is separated  from
bauxite ore in the presence of the fluoride-bearing mineral
cryolite results in fluoride presence in the waste stream, as
does the removal of phosphate from fluorophosphate  (fluorapatite-
Ca5F(PO4)3)  during the production of fertilizers.  Glass
manufacturing also produces fluoride-rich effluent  (75-1).
Fluorine and fluoride compounds are also used in the electronics
industries for production of semiconductors or internal washing
of cathode ray tubes.  In the wastewater discharged from some of
these industries, fluoride concentrations can sometimes reach
several hundred mg/L (88-6).

Natural Sources

   Geochemical dissolution of fluoride-bearing minerals is
responsible for the occurrence of natural fluoride in water
supplies of the United States (85-1) .  Fluorite (CaF2)  i's the
most common fluoride-bearing mineral and is usually present  in
sandstone, limestone, dolomite, and granite, all of which are
common in the United States.  Other less common fluoride-bearing
minerals include fluorapatite, cryolite, rhyolite and hornblends.
Fluoride also may displace other ions in the structures of micas
and clays  (85-1, 89-4, 59-1).  Water with high naturally
occurring fluoride is usually found at the foot of mountain
ranges and in areas with certain geological formations,
particularly those of marine origin (88-3).  Fluorite in
sedimentary rocks has been identified in marine carbonates and
related evaporites ranging in geologic age from Cambrian to

                                11

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Cretaceous.  Experiments have shown (51-1) that fluorite could
precipitate from seawater brines.  Subsequent geochemical
dissolution could reintroduce fluoride into fresh water aquifers
upon geologic time-scale marine regressions.  Groundwater
fluoride concentrations may sometimes exceed 100 mq/L as the
result of volcanic activity.
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GEOGRAPHIC AREAS WITH EXCESS FLUORIDE

   Fluoride concentrations in excess  of  the  EPA MCL effect
groundwater-source public water systems throughout the
continental United States.  All EPA regions were contacted to
determine the degree to which excess fluoride in groundwater
poses a problem today.  While EPA regions I and II could identify
no problem areas, all other regions regulate at least one public
water system with fluoride concentrations exceeding the MCL.

   The number of PWSs with high fluoride groundwater is
especially large in both Texas and Virginia.  A 1982 national
survey performed by the American Water Works Association (83-1)
indicated, for example, that 328 Texas and 104 Virginia community
water systems (CWSs) were exceeding the then current fluoride MCL
(1.4 to 2.4 mg/L).  At the time, the total number of CWSs
exceeding the MCL nationally was 907.

   Recent conversations with  EPA Region VI  (Dallas)  personnel
and the Virginia Department of Health, as well as reference to
the Federal Reporting Data System (FRDS II), indicate that Texas
and Virginia PWSs still currently  experience excessive fluoride
concentrations.   For example, 51 Virginia public water systems,
34 in Suffolk City County, have groundwater fluoride
concentrations exceeding the EPA MCL of 4.0 mg/L.  Twenty-nine of
these have concentrations which also exceed the unreasonable risk
to health  (URTH) level of 5.0 mg/L, the highest being 6.60 mg/L.

   A number of PWSs in Oklahoma, Arizona,  New Mexico and South
Carolina also currently experience excessive fluoride levels as
do a smaller number of PWSs in Indiana,  Illinois, Ohio, Missouri,
Wyoming, Nevada, North Dakota and Idaho.  In most of these cases
personnel from the various EPA regions indicate concentrations
are in the 5 mg/L range.  Data from the 1982 AWWA survey, for
example, indicated that 177 CWSs had fluoride concentrations
exceeding 4.0 mg/L while only 85 exceeded 5.0 mg/L.

   Since most sources of fluoride are natural,  and naturally
occurring fluoride concentrations change very slowly (on a
geologic time scale), AWWA's 1982 data should reasonably reflect
the current fluoride concentration distribution among CWSs
nationally.  It should be noted however that the number of CWSs
nationwide with excessive fluoride concentrations has decreased
since the early 1980s.  Contacts at several EPA regional offices
have indicated,  for example, that a considerable number of
smaller water systems have chosen to either locate another
drinking water source, connect to a large local water system, or
pursue other options in order to avoid costly defluoridation
treatment.  As a result the number of CWSs in each concentration
category below probably overstates the current situation:
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       Distribution of Fluoride Concentrations Nationally
                  (source: 1982 AWWA survey:83-1)

            concentrations               number of
           exceeding  fma/L)                 CWSs

                 4.0                         177
                 5.0                          85
                 6.0                          34
                 7-0                          16
                 8.0                           9
                 9.0                           8

     Fluoride-rich groundwater apparently occurs in geographic
 pockets" and normally does not effect groundwater on a regional-
scale.  The North Carolina state water agency's regional office
in the eastern part of the state,  for example,  reports that no
PWSs in the area are in violation of the fluoride MCL, despite
close proximity to the Suffolk Virginia public water systems
experiencing excessive fluoride.   Concentrations are in the 2 0
to 3.5 mg/L range.  A Gates County North Carolina water supply
operator whose wells are about 20 to 25 miles from Suffolk
Virginia, indicates that fluoride levels in his wells are about
3.1 mg/L.
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COMPLIANCE OPTIONS

   The Safe Drinking Water Act (SDWA)  affects  approximately
230,000 public water systems (PWSs).   Of these,  approximately
60,000 are community water systems (CWSs)  which, by definition,
serve at least 15 service connections used by year-round
residents, or regularly serve at least 25 year-round residents.
About 88% of these systems serve 10,000 residents or less,
accounting for 22% of the total population served by CWSs (91-7).
In addition approximately 25,000 non-transient,  non-community
water systems (NTNCWSs) and 145,000 non-community water systems
(NCWSs) are effected by the SDWA.

   PWSs which produce water with excess fluoride may exercise a
variety of options in order to provide water which meets
regulatory standards.  These options can broadly be characterized
as treatment versus non-treatment.

     Treatment                       Non-treatment

  central                     develop a new well which produces
                              water which meets the MCL

  point of use (POU)          connect to or haul water from a
                              PWS which produces water which
                              meets the MCL

  point of entry  (POE)        purchase and distribute bottled
                              water which meets the MCL

   While each of these options is technically capable of reducing
fluoride  concentrations,  current Safe Drinking Water Act
regulations do not permit a PWS to employ POU treatment,  or
purchase  and distribution of bottled water, as compliance options
to attain the MCL.   Rather, POU treatment and bottled water are
only  permissible  as  short-term options.  It should be noted that
the January 30, 1991 final rule  for volatile organic compounds
 (R91-1) allows POE devices to be used to meet regulatory
requirements, although such devices are not considered BAT.

   In most cases the first three compliance options which are
considered acceptable  from a  regulatory standpoint are relatively
expensive operations which can be pursued cost-effectively only
by larger PWSs which can  spread  capital, and operation and
maintenance costs over a  larger  customer base.   For many  of  these
options,  fixed capital costs, which are independent of the number
of customers  serviced by  the  PWS, are  quite large.  For example,
sinking a new well  to develop a  new water source may cost in  the
order of  ten thousand  dollars.   To a  PWS which  services only  50
households, this  represents a one time cost on  the  order  of  $200
per household.  To  a PWS  servicing 500 households,  this cost  is
only  about $20 per  household.   In addition, some marginal costs,

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which are dependent upon the number of customers serviced by the
PWS, are also subject to an economy of scale, in effect
financially penalizing smaller systems.

   A PWS can also comply with SDWA regulations by applying for
and receiving a variance or exemption (SDWA, Sections 1415 and
1416).  While EPA does not consider POU treatment, or purchase
and distribution of bottled water as viable long-term options to
attain regulatory compliance, it does permit the regulatory
agency (usually the State) to require a PWS to pursue such
options as a condition of granting an exemption or variance.

   The feasibility of pursuing any one of these treatment or non-
treatment compliance options is often contingent upon a multitude
of factors including those of geography,  geology, and economics.
Many small South Carolina PWSs in the North Atlantic Coastal
Plain, for example, which had experienced problems with excess
fluoride, opted to connect to larger water systems instead of
adding treatment.  This was technically feasible due to the
relatively dense population along the coast and the subsequent
proximity of larger water systems which were already treating for
fluoride.  By contrast, about 50 PWSs scattered throughout the
Arizona desert,  some servicing as few as 25 to 30 people, have
been required to install POE devices as a condition for receiving
a variance or exemption.  Due to their isolation these systems
did not have an option to connect to a larger system.
                               16

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AVAILABLE TREATMENT TECHNOLOGIES

   The treatment technologies to remove fluoride are,  for the
most part, well documented.  They include:

               adsorption by activated alumina
               adsorption by bone char
               reverse osmosis
               electrodialysis
               alum coagulation
               lime softening
               anion exchange
               nanofiltration

All of these technologies can be applied as central treatment.
Only activated alumina, reverse osmosis and anion exchange
POU/POE treatment are currently commercially available, although
at least one commercial producer of bone char is attempting to
market his product as a POU/POE device ingredient.

   In addition to the treatment technologies listed above,
research for this report revealed a recently developed and
patented defluoridation technique involving adsorption by rare
earth compounds.

   A considerable amount of research has been conducted regarding
operation of, and costs associated with, most of these treatment
technologies.  Gumerman, et al  (84-1) provides a detailed cost
analysis for small centralized systems.  Bellen and Anderson  (85-
1) specifically evaluate the comparative efficiencies and costs
of defluoridation based upon evaluation of a number of
centralized and POU facilities.  Proceedings of a 1987 EPA
sponsored POU conference (88-5) provides discussion of a broad
range of POU related topics as well as unit costs.  Rogers  (90-5,
88-4) relates the development of a POU reverse osmosis pilot
study in New Mexico from prior to request-for-proposal
preparation through cost and efficiency analysis.

   A brief description of each treatment technology follows.

Activated Alumina

   Activated alumina is manufactured by low temperature
dehydration of hydrous aluminum oxide, the process creating a
porous adsorbent of moderately high surface area  (81-2).  The
mechanism of fluoride adsorption involves the attachment  of
fluoride  (F~)  to the activated alumina and the loss of hydroxyl
ion  (OH")  from activated alumina to the water (86-1).   The
optimal pH range for this anion exchange is pH 5 to 6.  Below
this range activated alumina dissolves in the acidic environment
producing loss of adsorbing media.  Above pH 6, the predominant
hydroxyl ions are preferred over fluoride for adsorption.  One

                                17

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 gram of activated alumina is reported to adsorb between 2 3 and
 10.1 mg of fluoride,  dependent upon other raw water conditions
 (81-2).

   In central treatment,  raw water  is adjusted  to the optimal  pH
 range and fluoride is adsorbed until the alumina bed is
 saturated.   Fluoride  is then removed by adding a caustic (usually
 sodium  hydroxide)  to  produce a high pH  water  which  removes
 fluoride in favor of  hydroxyl  (regenerative step).   After
 regeneration the pH is reduced to the optimal range and the cycle
 begins  anew.                                                  J

   POU/POE  activated  alumina treatment uses canisters containing
 approximately .5 to 1.0 cubic  feet  of activated alumina and does
 not  involve pH  adjustment to optimize the canister's adsorption
 capacity.   Once the fluoride adsorption capacity of the medium is
 exhausted,  the  canister is replaced.  The contents  of the spent
 canister can be regenerated by exposure to high alkali  water  as
 is done  in  central  treatment,  and reused.  This is  usually done
 off-site.

   While activated alumina readily adsorbs fluoride, other raw
 water parameters have an impact upon adsorptive capacity   High
 concentrations  of total  dissolved solids  (TDS),  for example  can
 result  in fouling of  the alumina bed and  high concentrations of
 sulfates and  carbonates  can  result  in ionic competition.
 Application of  activated alumina treatment is most  favorable when
 fluoride alone  must be  removed from  drinking  water  (81-2).

 Bone Char

   Bone  char is crushed and burned animal bone, having an
 approximate chemical  composition of hydroxyapatite,  Cain(PO ) (OH)
 (91-1).   This treatment  process normally  also includes  carbon   2
 adsorption  to remove  color and odor.

   The bone char process for fluoride removal  is similar to that
 for activated alumina.   Regeneration of the media,  by removing
 fluoride, can be accomplished  by exposure  to  dilute  caustic  soda
 (84-6),   or  to a  regenerating solution using bone char particles
 too small for use in  the bone  char bed  (91-1).

   POU/POE bone char treatment has been proposed for a number of
 years (see  for example 68-1) and has been practiced  in Third
 World villages  (88-3), in which case media is not regenerated
 the village being supplied instead with replacement  filter bags
 Researchers have expressed the intent of providing villagers with
 high-temperature furnaces to prepare filter ingredients  (88-3).

   A  New Hampshire vendor who has been using a POE bone  char
device to eliminate excessive arsenic, is currently researching
the device's ability to reduce groundwater fluoride levels.  As
                                18

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of the writing of this report no results had been reported.

   Bone char's capacity to adsorb fluoride  is reportedly far less
than that attained by activated alumina (84-6, for example).
However, while a considerable amount of research has been
performed to determine optimal processing parameters for
activated alumina, such as pH, influent flow rate, and
contaminant loading concentration (see for example 79-1), little
in this regard had been done to optimize processing with bone
char.  A recently published study supported in part by the World
Health Organization, however, claims bone char adsorption
capacity of about 9.8 mg fluoride per g of bone char (91-1).
This is comparable with activated alumina capacity.  Furthermore,
after regeneration of spent columns with calcium phosphate at pH
3, the column is reportedly at least as effective as it was
originally.

Reverse Osmosis

   Reverse osmosis (RO)  utilizes a pressure gradient and semi-
permeable membranes to remove a high percentage of almost all
inorganic contaminants, as well as turbidity, bacteria and
viruses.  The membrane essentially operates as a molecular sieve.
Fluoride removal efficiencies greater than 80%, and sometimes as
high as 98% have been documented for both central and POU
treatment techniques (90-5, 88-4, 86-1, 85-1, 85-4).

   RO membranes are susceptible to scaling  or fouling.   Chlorine
also damages certain membrane materials.  As a result chemical
pre-treatment or granular activated carbon adsorption is often
required in the process line prior to the reverse osmosis unit.
Pre-carbon adsorbers are apparently now standard for all POU/POE
units.

   Reverse osmosis units incur substantial  process electricity
costs.  Low pressure units require less electricity than high
pressure units but remove a smaller percentage of contaminants.

   Reverse osmosis units tend to produce a  relatively small
volume of water with respect to the waste stream generated.  A
1983 POU reverse osmosis pilot study resulted in an average waste
stream of 89% for 47 devices  (85-1), that is, only 11% of raw
water influent was eventually processed into product drinking
water.

Electrodialvsis

   In the electrodialysis (ED) process, water flows between
alternate cation permeable and anion permeable membranes, with
direct electric current providing the driving force to cause ions
to migrate through the membranes.  Electrodialysis reversal  (EDR)
is essentially the same process as ED except that the electric

                                19

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 charge on each membrane is occasionally automatically reversed to
 expel  any ions which may have collected.   Virtually all
 electrodialysis plants  constructed since 1975  are  EDR.

   Fluoride removal  efficiencies greater than 80% have been
 reported  (84-3)  for  these processes.

   EDR plants  operate with a relatively high water recovery rate
 especially when compared with RO.   An EDR  defluoridation plant '
 processing 3 million gallons  per day and operated  by the City  of
 Suffolk,  Virginia, for  example, typically  recovers  about 94% of
 influent  as product  water.

   Apparently  POU/POE EDR is not a viable option.  Neither the
 proceedings of the 1987  EPA conference  on  point-of-use  (88-5)  nor
 Gumerman,  et al's extensive review of available  small systems
 completed in 1984  (84-1)  mention an EDR POU/POE  option.

   A contact from the Office of Ground Water and Drinking Water,
 EPA reports that pending regulations may include ED  as BAT for
 fluoride.

 Alum Coagulation

   Upon addition to water, alum (A12 (SO,), 18H,O) dissociates to
 form an aluminum hydroxide complex  which removes fluoride either
 by floe enmeshment or sorption.  The insoluble complex
 precipitates out of  solution.

   EPA has reported that this treatment technique tends to be
 expensive  for  small  system applications  (84-6),  requiring
 addition  of large quantities of alum.  More recently, however
 Nawlakhe  & Bulusu (89-4) have developed a combination alum/lime
 defluoridation treatment  (referred  to as the Nalgonda technique)
 which they contend is inexpensive,   effective, and adaptable to
 both the domestic and community levels.  The technique is
 specifically designed to be operated by illiterate people in
 rural communities in India.

 Lime softening

   Fluoride is  removed by treatment systems which utilize  lime
 softening  (lime is calcium hydroxide)  to remove calcium and
magnesium hardness.  Since fluoride is coprecipitated in this
process with magnesium hydroxide (86-1, 84-6),  this method
 requires the raw water magnesium concentration to be sufficient
to enmesh enough fluoride to produce residual concentrations
below the MCL.   Substantial quantities of magnesium are required
to produce this effect,  as well as  the addition of large
quantities of lime.

   Lime softening treatment can be  performed either as a single

                                20

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stage or two stage process.   As indicated in Gumerman,  et al (84-
1),  the majority of lime softening systems utilize single stage
processing.  Two stage processing is required to remove
significantly high raw water magnesium concentrations.

  While lime softening is primarily used to remove hardness,
considerable fluoride reduction is a by-product.  For example,
the Yuma Bureau of Reclamations Desalting Plant typically removes
about 45% of raw Colorado River water fluoride concentration in
its lime softening operation.

  As indicated in the discussion on alum coagulation,  a small
scale treatment technique which employs alum and lime has
reportedly been developed which is effective and inexpensive at
the domestic and community levels.

Anion Exchange

   Ion exchange is a process in which ions held by electrostatic
forces to charged functional groups on the surface of a solid are
exchanged for ions of similar charge in a solution in which the
solid is immersed  (72-1).

   Though this technique theoretically has potential application
for defluoridation, little information regarding its use could be
obtained either through personal contacts or literature review.
EPA pilot studies in Oregon and Alaska utilized anion exchange as
a POU arsenic removal technique  (87-3) but apparently did not
pursue the device's ability to remove fluoride.  EPA-sponsored
research conducted by the University of Houston (84-3) indicates
that anion exchange resins prefer exchange with chloride rather
than fluoride.  Since chloride is a common major anion in
groundwater  sources, especially  in coastal regions experiencing
varying degrees of salt water intrusion,  its competitive
advantage over fluoride in an anion exchange process would tend
to minimize  this technology's effectiveness for fluoride removal.

Nanofiltration

   Nanofiltration is a relatively new water treatment technique
which has been commercially available since 1986.  The^nanofilter
operates on  a molecular scale, removing molecular  species with
diameters greater than or equal  to  10 angstroms (a nanometer).
The  technology has the ability of removing  smaller materials than
ultrafiltration, but  is incapable of removing  some of the smaller
materials  removable by reverse osmosis. Because of the coarser
membrane with respect to  reverse osmosis, nanofiltration requires
lower operating pressures (typically between 80 to  100 psi) than
RO to force  water through the membrane and  therefore
substantially less energy (89-5, 89-6, 87-2).

   The coarser membrane also produces a substantially higher

                                21

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 water recovery rate than RO resulting in a much smaller waste
 stream.   According to a nanofiltration researcher from the
 University of Arizona,  the process experiences a 95%  water
 recovery rate.   The researcher reports that several Florida
 locations are using this technology,  and the city of  Fort Myers
 is  presently constructing a 20 million gallon per day plant which
 utilizes a groundwater source.

   While  the  researcher's bench scale tests have been designed  to
 determine the effects of the treatment on salinity, hardness
 bacteria, virus,  and organic precursors,  tests with recharged
 municipal effluent in the city of  Phoenix indicate that
 nanoflltration  was able to reduce  fluoride levels  from  7 to 2
 mg/L  (89-5).

   The nanofiltration researcher is currently in the process of
 developing a  nanofiltration device for  home use.

 Adsorption Involving Rare  Earth Compounds

   Nomura et al (90-3, 88-6) have developed and patented a high
 efficiency method of selectively removing fluoride and  fluoride
 compounds at  low  concentrations in water  by adsorption  onto
 hydrated  rare earth  oxides  or  insoluble hydrated rare earth
 salts, particularly  hydrous rare earth phosphates  or hydrous  rare
 earth fluorides,  effective  within  the pH  range  of  2 to  7.  The
 adsorbent can be  prepared as a filtration cake, a  dried powder
 or fabricated as  a pre-formed mold upon a carrier  porous
 material, preferably a polymeric organic  (88-6).

   The mechanism of adsorption, similar to that by activated
 alumina,  is by anion exchange between the hydroxyl groups on the
 adsorbent and fluoride or fluoride compounds in solution   The
 percentage of removal of fluoride  increases abruptly at pH 7 or
 lower, approaching 100% rapidly as pH decreases.  The percentage
 removal of other  common anions, such as chloride, nitrate, and
 sulfate,  is considerably lower and the pH at which these anions
 are optimally adsorbed is at pH ranges less than 4.  As a result
 fluoride  is selectively adsorbed.   Below pH 2, the adsorbent
 itself is highly  soluble, while above pH 7 adsorption capacity
 decreases significantly.

   The selectivity for fluoride is  reflected in data published in
Nomura, et al's patent application (88-6).  In a pH 5 solution
containing equal concentrations of fluoride, chloride, nitrate
and sulfate, fluoride was selectively adsorbed by a ratio range
of 100 to 1000 over chloride, 200  to 5000 over nitrate, and 30 to
200 over sulfate.   Here selectivity is defined  (using chloride as
an example) by the following:
                               22

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                IFlads ICllaq
where: [X]   -=  concentration of species X in solution  (irunol/L)
       [X]ads =  concentration of species X in adsorbent
                 (meq/g of adsorbent)

   Desorption of fluoride and subsequent regeneration of the
adsorbing media is accomplished by exposure of the media to high
alkalinity water (preferably pH 12 or above)  to permit
replacement of fluoride ions by hydroxyl ions on the adsorbing
media.  The desorption and regeneration process is similar to
that for activated alumina treatment.

   Since their initial patent application,  Nomura,  et al have
maximized adsorption capacity by developing a carrier bead of
polyolef inic resin bearing an adsorbent of hydrous cerium oxide
powder.  Optimal adsorption occurs in the 2 to 5 pH range.
Sodium hydroxide is used to regenerate the adsorbent media, with
calcium fluoride precipitating from solution upon addition of
calcium chloride (90-3) .

   Nomura and his  co-workers compared the adsorptive capacities
of activated alumina and hydrous cerium oxide by running tests
with influent containing a fluoride concentration of 100 mg/L.
The water treated with activated alumina was adjusted to pH 6
(optimal for activated alumina adsorption) , while water treated
by hydrous cerium oxide was adjusted to pH 3.  Results indicate
that hydrous cerium oxide is nearly six times as effective as
activated alumina in removing fluoride when compared on the basis
of mole of fluoride adsorbed per mole of metal in the adsorbent:

                        Adsorption Capacity

                   mg fluoride/    mole fluoride/
                   g adsorbent      mole metal

  Ce02 1.6 H2O         105             1.13
  A1203                 69               .20


   It should be noted however that Nomura,  et al have pursued
this technique primarily to treat wastewater and that the
influent fluoride concentration (100 mg/L) of the water used for
testing comparison far exceeds fluoride concentrations normally
encountered in the United States.

   While their patent application indicates their process is
economical, no cost data is presented in their published
material.  Attempts to contact the two editors of the text
containing Nomura, et al's publication were unsuccessful.  Nomura
and his co-workers reside in Japan.

                                23

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Disposal

   Each of these treatment technologies generates a waste stream
of sludge or brine which requires an appropriate disposal
strategy which meets regulatory requirements since each of these
waste streams contains concentrated quantities of removed
contaminants.  Several disposal strategies exist, two or more
applicable to a given treatment technology (following modified
from Gumerman, et al, 84-1):
                                     Disposal strategy
                            sludge
                            laaoon
Treatment technology

activated alumina

bone char

reverse osmosis

electrodialysis reversal

alum coagulation            x

lime softening              x

nanofiltration
sanitary   sand  evaporation
 sewer     beds     ponds
                                        X

                                        X

                                        X

                                        X

                                        X

                                        X

                                        X
                      X

                      X

                      X

                      X
             X

             X
                                                        X
   Disposal into a sanitary sewer system is a realistic strategy
only if a sewer line is available and a centralized treatment
facility can operationally handle the increase in sludge.  Slowly
releasing the sludge over a period of time (equalizing
discharge), would enable the centralized treatment facility to
more efficiently respond to the added sludge volume, and reduce
the probability of producing sudden changes in pH, temperature,
dissolved oxygen concentration, or other physicochemical
characteristics of the system.

   The  State may also approve sludge discharges to surface
waters, or sludge injections into deep wells when contaminant
concentrations are low.  In either case, equalizing the discharge
is recommended.

   Sludge lagoons and evaporation ponds are frequently designed
to accommodate several years of waste before removal of
precipitated solids to a permanent disposal location is required
(84-1).  The economic feasibility of sludge lagoons and
evaporation ponds is dependent upon the availability and cost of
land in the vicinity of the treatment facility, as well as the
                               24

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evapotranspiration rate of the locale.  In southeastern Virginia,
where the average annual precipitation rate, 43 inches per year
(90-2), exceeds the average evapotranspiration rate, 21.5 inches
per year (90-2),  these strategies are not applicable.  By
contrast, these options are favorable in desert locations of
Arizona where annual precipitation is low, evapotranspiration is
high, and land is abundant and relatively inexpensive.
                                25

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MORE ON POINT-OF-USE AND POINT-QF-ENTRY

   POU treatment techniques, and purchasing and distributing
bottled water are both capable of reducing groundwater fluoride
levels below the MCL.  Currently, EPA does not accept these
options as methods of attaining long-term compliance with the
federal fluoride regulations but does permit the regulatory
agency (usually the State) to require a public water system to
use these options as a condition of granting an exemption or
variance from the fluoride MCL.

   The following discussion intends to provide some insight into
the POU and POE options based upon two reports published in 1990
and recent discussions with several contacts, including personnel
at various EPA offices.  The short time frame of this current
research prevented the gathering of detailed information
regarding the bottled water option.

   The final  volatile organic compound rule (R91-1)  defines
specific criteria which a public water system must meet in order
to receive an exemption or variance using these options.   This
rule was promulgated on January 30, 1991, to become effective
July 30,  1992.   A synopsis of these criteria follows:

   Public water  systems that use  POU/POE  devices  as  a
   condition  for obtaining  an exemption or  variance  must:
     1-maintain the POU/POE devices
     2-obtain the approval of a monitoring plan which
       ensures  the devices provide health protection
       equivalent to that provided by central treatment
     3-apply  effective technology and maintain micro-
       biological safety
     4-provide  the State  with certification of performance
     5-consider the potential for heterotrophic
       bacteria and provide a means to assure that the
       microbiological safety of  the water  is not
       compromised
     6-assure the State that the  devices  are sufficient
       in number,  and that  they are properly installed,
       maintained,  and monitored

   Public water  systems that use bottled water as a
   condition  for receiving an exemption or variance must:
     1-develop  a monitoring program for State approval
     2-receive  certification from the bottled water
       company that  the supply is  taken from an
       approved  source
     3-assume full  responsibility  for providing a
       sufficient  supply  of  bottled water to every person
       supplied  by the public  water system  via door-to-door
       delivery
                               26

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   POU/POE  devices both  require  a relatively small capital
investment when compared with central treatment.   While operation
and maintenance costs on a per gallon basis are usually higher
for these devices than for central  treatment,  POU devices treat
only drinking (and possible cooking)  water which is  usually about
10% of the total household water usage.   As a  result overall POU
operation and maintenance costs can be smaller than  that for
central treatment,  especially for small systems.

   Some of the disadvantages of  using POU/POE  devices include:
the potential for bacterial growth on the surface of the media
within the treatment units; inability to optimize process
parameters; and difficulties associated with monitoring, testing,
and servicing.

   Two recently published studies,  one sponsored by  EPA, the
other performed by the National Sanitation Foundation, address
the problems associated with POU/POE drinking water treatment.

   Seventy-two under-the-sink model reverse osmosis  POU units
were installed and monitored in the village of San Ysidro, New
Mexico in an EPA-sponsored study (90-5).  The local groundwater
source contains leachate from geothermal activity and therefore
is high in mineral content.  At the time of the study the
groundwater exceeded EPA primary MCLs for arsenic and fluoride,
and secondary MCLs for  iron, manganese, chloride, and total
dissolved solids.  Eighteen months of operational and_maintenance
data were collected and evaluated.  Study results indicate:

   * POU drinking water treatment is an effective, economical,
     reliable, and viable alternative to central treatment
     for the community
   * A POU treatment system requires a more time-intensive
     monitoring program than that for central  treatment
   * A POU treatment system requires special municipal
     regulations regarding customer responsibilities, and
     water utility responsibilities
   * POU systems require special considerations from regulatory
     agencies to determine appropriate methods for record
     keeping, monitoring, and testing frequencies
   * A POU treatment system requires customers to permit access
     for monitoring, testing, and maintenance of equipment
   * A POU reverse osmosis unit can reduce raw water arsenic and
     fluoride levels which exceed the EPA MCL to below  regulatory
     limits
   * A POU reverse osmosis unit can reduce raw water iron,
     manganese, chloride, and total dissolved solids levels
     which exceed the EPA secondary MCL to below those  regulatory
     limits
   * While the monthly  treatment cost on a per gallon basis  is
     about 3 times that of a central treatment facility, the
     actual household treatment cost is less than half  since POU
                                27

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*
*
     devices treat only that small portion of household water
     demand used for drinking and cooking

   During the testing a few RO-treated water samples tested
 positive for coliforms.   An  investigation revealed  that all  RO
 units  had been  installed  with the RO  drain connected directly to
 the  kitchen sink drain without  an air gap.  This was strongly
 suspected to be causing the  positive  coliform test  results.
 After  the air gap problem was corrected, all coliform test
 results  were negative.

   The National Sanitation Foundation study pursued the viability
 of using POE treatment to reduce radium levels in the town of
 Bellevue, Wisconsin  (90-8).  Results  from this study indicate
 that:

   * Residents did not perceive POE devices as a treatment
     technology
   * Residents were unwilling to permit equipment inspections
     more than twice per year
     The legal issues that will be most difficult to address
     involve access and entry to private property for
     maintenance,  inspection, and monitoring
     Although the capital costs may be favorable when compared
     with central treatment or connection to an existing system,
     the monitoring,  maintenance and administrative costs
     associated with POE treatment would be much greater than
     other possible options

   Due to its  proximity to a central treatment facility in Green
 Bay, the city of Bellevue is currently deciding whether to
 connect to the Green Bay  system.  The study reveals a general
 public uneasiness regarding decentralized treatment.

   People contacted during this  study had varying opinions
 regarding decentralized treatment.  Many people concurred with
 some of the findings of the two previously mentioned studies
 specifically that decentralized treatment is effective but
 presents monitoring,  testing and maintenance problems since
 entrance to the consumer's property is always required for POU
 devices, and usually required for POE devices.   Many contacts
were also concerned about contaminant breakthrough once the
device's media had become saturated.  Should breakthrough occur
undetected,  the consumer is potentially susceptible to larger
contaminant doses than is contained in the raw water due to
contaminant concentration in the device's media.   A contact from
the state of Arizona's drinking water office pointed out that
monitoring a few devices is not effective since it assumes that
devices at each residence respond identically.   This may not be
the case.

   Other  contacts, however argued that, while POU/POE devices may

                                28

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not be preferred over centralized treatment,  they are sometimes
the only cost effective alternative for small systems.  A contact
from the Rural Water Association, for example,  had visited a
number of sites using POE devices managed by a contracted
"circuit-rider", or system monitor, in the Arizona desert and
felt the monitoring system worked well.  He indicated that, for a
POE treatment system to be viable, the state regulatory agency
should specify that a contract must exist between the home owner
and the PWS for reasons of monitoring, testing, and maintenance
so that access to the customer's property is assured.  He feels
in general that management must be more creative and evaluate the
trade offs between centralized and decentralized treatment.  When
this contact was informed regarding the natural fluoride
contamination currently being experienced by small PWSs in
southeastern Virginia, he indicated that the Virginia office of
the Rural Water Association would be available for assistance
should EPA be interested in pursuing a pilot decentralized
program in the state.

   One contact from the National Sanitation Foundation maintains
that EPA should be working with the small public water systems in
determining optimal monitoring procedures and in sharing
decentralized system cost information.  The State of California,
according to a contact in the State's Department of Health
Services, has wholeheartedly adopted the philosophy of the
National Sanitation Foundation.  The State of California contact,
however indicated that California, Iowa, and Wisconsin are the
only states with laws regarding regulation of POU/POE devices.

   The King's Point Subdivision in the City of  Suffolk,  Virginia
is expected to be a test site for POU/POE fluoride removal.  When
contacted in late July 1991 the HQ EPA coordinator for the Low-
cost Innovative Small System Initiative indicated that requests
for proposal (RFPs) should have been disseminated by early August
1991.  He expected that a mix of POU and POE devices would
probably be installed.  The coordinator further indicated that
POU/POE technology is progressing.  Some systems, for example are
currently capable of on-line real-time assessment of treatment
plant operations.  A New Hampshire vendor, for example, indicates
that his company has developed a bone char POE device for arsenic
removal which is automatically backwashed.

   Subsequent comments submitted by the coordinator for the Low-
cost Innovative Small System Initiative (91-12) indicate that
award announcements for the King's Point Subdivision project are
expected sometime in December 1991.  A December 1991 telephone
call to the consulting firm hired to coordinate the project
indicates that the State of Virginia and the Subdivision are
currently reviewing the proposals submitted by four bidders.  The
firm is encouraging the acceptance of all four proposals.

   An EPA Cincinnati contact indicated that he, in conjunction

                                29

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with the Water Quality Association, recently polled between 250
and 300 POU/POE manufacturers nationwide to assess currently
available products.  While many manufacturers were reluctant to
furnish effectiveness data, some significant information was
collected.

   Another HQ EPA contact ventured to predict that POU/POE
devices will one day be considered BAT but probably not for many
years, citing the legal and managerial problems previously
mentioned in this report.

   It  should be noted that in extreme cases  POU/POE may be the
only option available to small public water systems.  A case in
point is an Indiana public water system servicing about 6500
people.  An EPA Region V contact indicated that the system has
been producing groundwater source drinking water with fluoride
levels consistently in the upper 4 mg/L range for the past 13
years.  A contractor hired by the PWS to assess treatment options
determined that he could provide neither centralized activated
alumina nor centralized reverse osmosis (the two BAT choices) at
any reasonable cost.  When the beleaguered system pursued
connecting to another water system it discovered that such action
required approval by Canada and other states bordering the Great
Lakes watershed.  The case has yet to be resolved and is awaiting
action by the US Department of Justice.
                               30

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TREATMENT COSTS

   While nine available treatment techniques have been
identified, we propose to explore related costs for only six of
these as central treatments (activated alumina, reverse osmosis,
electrodialysis, alum coagulation, lime softening, and
nanofiltration), and two as POU treatments (activated alumina and
reverse osmosis).  Bone char and rare earth adsorption costs are
not available in the literature.  Anion exchange costs were not
explored due to the uncertain nature of its application for
defluoridation.  Activated alumina and reverse osmosis are the
only techniques for which POU/POE defluoridation treatment is
currently available.  However only detailed POU costs are
available in the literature.  POE costs are therefore not
included below.

   The following discussion and development of treatment
technology costs is largely based upon cost analysis performed by
Culp/Wesner/Culp Consulting Engineers (Gumerman, et al, 84-1).
Under EPA contract, Culp/Wesner/Culp undertook an extensive two
and a half year study in 1981 to determine costs associated with
unit processes capable of removing contaminants included in the
National Interim Primary Drinking Water Regulations.  The study
(84-1), performed during the period September 1981 to January
1984, considered cost data for 45 centralized and five POU/POE
treatment techniques.

   The discussion and development of disposal strategy costs,
while partially based upon the Culp/Wesner/Culp study, draws also
upon a 1989 feasibility study performed by Engineering-Science,
Inc. (89-7) which studied four west Texas public water systems
experiencing excess fluoride levels and developed cost
projections for remediation using centralized activated alumina
and reverse osmosis at each location.

  Costs related to nanofiltration are derived from a 1989 journal
article (89-8) and telephone conversations with a researcher from
the University of Arizona and his marketing representative.

   Comments submitted by the Office of Ground Water and Drinking
Water (OGWDW), HQ EPA, (91-12), indicate reluctance on the part
of the OGWDW to rely heavily upon the Culp/Wesner/Culp model for
small system costs.  According to OGWDW, the model, which was
developed under contract to the EPA Office of Research and
Development, does not necessarily accurately reflect the method
small systems employ to solve water treatment issues.  Instead of
hiring consulting engineers to design and build treatment
facilities, as the Culp/Wesner/Culp model suggests, smaller
systems tend to rely upon pre-engineered complete systems which
are not custom designed.
                                31

-------
Cost Categories

   Centralized treatment facilities incur costs which can be
separated into four categories:  Construction, operation and
maintenance, chemical, and disposal.  Construction costs demand a
one-time consumer expenditure whereas the other three cost
categories require annual consumer expenditures.  POU/POE
technologies incur only construction, and operation and
maintenance costs.

   Culp/Wesner/Culp developed construction cost data by
segregating costs into eight principal components which were
selected to aid in subsequent cost updating:  excavation and site
work, manufactured equipment, concrete, steel, labor , pipe and
valves, electrical equipment and instrumentation, and housing.
The subtotal of the costs of these components includes the cost
of material and equipment purchase and installation, and a
subcontractor's overhead and profit.  A 15% contingency allowance
is then added to the subtotal to determine the total process
cost.

   It should be noted that Culp/Wesner/Culp construction cost
data do not represent capital cost.  To convert the construction
cost data into capital cost data requires adjustments for the
following, where appropriate:
                     ' j
     - overall site work, interface piping, roads
     - general contractor's overhead and profit
     - engineering
     - land
     - legal, fiscal, and administrative costs
     - interest during construction

   It is also important to realize  that Culp/Wesner/Culp
construction cost data do not include costs associated with
constructing disposal facilities or installing pumps.  While it
is extremely likely that an existing public water system already
has pumps in place (an exception might be a PWS with an artesian
well water supply), it is extremely unlikely that a PWS which is
not currently treating for a contaminant would already have a
sanitary sewer, sand bed, evaporation pond, or sludge lagoon in
place.

   Culp/Wesner/Culp developed operation and maintenance costs
for three separate components: energy, maintenance material, and
labor.  The energy component includes process and building
electrical energy, and diesel fuel  where appropriate.
Maintenance material costs include  those for replacement parts
but does not include chemical costs.  Labor requirements include
both operational and maintenance costs.

   Chemical  costs  are incurred by all centralized treatment

                                32

-------
facilities.   Included are costs for coagulants,  such as alum and
lime,  adsorbers,  such as activated alumina,  and acids and
alkalies, typically sulfuric acid and sodium hydroxide,
respectively.

   Disposal  costs are associated with the various  fluoride
treatment disposal strategies, including sludge lagoons, sanitary
sewers, sand beds, and evaporation ponds.  All centralized
treatment facilities incur such costs.  While technically spent
POU/POE activated alumina canisters require disposition, canister
contents are regenerated and/or disposed off-site.  Labor costs
associated with delivery of spent canisters to off-site
regeneration/disposal facilities are included in operation and
maintenance costs.

Cost Standardization

   In  nearly all  categories,  Culp/Wesner/Culp based costs upon
standardized Bureau of Labor Statistics  (BLS) or Engineering
News-Record  (ENR) indices, or, in the case of electricity, upon
the current cost per kilowatt hour (kWh).

   While all costs are in December 1983 dollars,  the
Culp/Wesner/Culp report provides the means by which cost figures
can be updated.

   Each of the eight construction cost components is associated
with either a Bureau of Labor Statistics  (BLS) or Engineering
News-Record  (ENR) standardized cost index.

   Operation and maintenance costs are segregated into the three
individual components:  energy, maintenance material, and labor.
Since the report provides energy requirements in Kwh/yr, applying
current cost of electricity quantifies energy costs.  Maintenance
material costs are based upon the Producer Price Index  for
Finished Goods.  Operation and maintenance labor costs  can be
updated using the ENR skilled labor index.  Culp/Wesner/Culp
applied labor costs of $11.00 per hour for 1983 operation and
maintenance  costs.

   The Culp/Wesner/Culp report does not explicitly identify
specific BLS or ENR indices for chemical  costs.  However a series
of BLS chemical indices were selected by  this researcher for cost
updating purposes.
                                33

-------
  Construction Cost Component

  Excavation and site work

  Manufactured equipment



  Concrete



  Steel


  Labor

  Pipe & Valves



  Electrical



  Housing
 Index

 ENR Skilled  Labor  index

 BLS General  Purpose
 Machinery and Equipment
 (Code  114)

 BLS Concrete Ingredients
 and Related  Products
 (Code  132)

 BLS Steel Mill Products
 (Code  1017)

 ENR Skilled  Labor  index

 BLS Miscellaneous
 Gen'l  Purpose Equipment
 (Code  1149)

 BLS Electrical Machinery
 & Equipment
 (Code  117)

 ENR Building Cost  index
Operation and Maintenance
       Cost Component

  Energy
  Maintenance materials
  Labor
Index
Current electricity rate
in $/Kwh

BLS Producer Price index
for Finished Goods

ENR skilled labor index
                            34

-------
     Chemical Cost Component

     sodium hydroxide
     carbon dioxide
     sulfuric acid
     alum
     soda ash
     sodium hexametaphosphate
     lime
Index

BLS Sodium Hydroxide
(Code 2812-3)

BLS Carbon Dioxide
(Code 2813-3)

BLS Sulfuric Acid
(Code 2819-3)

BLS Other Aluminum
Cmpnds (Code 2819-671)

BLS Sodium Cmpnds
(Code 2819-7A)

BLS Other Sodium Phos-
phates (Code 2819-739)

BLS Alkali Earth Metal
Cmpnds (Code 2819-9A)
   Disposal costs present a much more complex problem.   For the
purposes of developing comparative costs, this researcher has
decided to update only those disposal costs associated with
disposal to an existing sanitary sewer.  While this is a gross
generalization, several factors influence this decision:

   1-The sanitary sewer disposal strategy is the only strategy
     common to all of the centralized treatment technologies
     under consideration.   It was therefore felt that updating
     sewage disposal costs would be most useful in general.

   2-Since two or more disposal strategies apply to each
     treatment technology, quantifying disposal costs
     would require updating a large volume of data.

   3-Culp/Wesner/Culp construction costs for disposal to
     sanitary sewers is based upon sludge flow rate in
     gallons per day.   Knowing the ratio of average sludge
     flow rate (in gallons per day)  to the average plant
     flow rate (in gallons per day)  would permit a
     relatively straight forward computation of sanitary
     sewer disposal costs.  It is felt that these ratios
     can reasonably be estimated.   For activated alumina
     it is well established that the waste flow is
     between 1 and 4% of plant flow (89-7,  85-1,  84-1,  80-4).
     The average ratio for RO for the four PWSs researched
     in the west Texas study (89-7)  was 13%.   Considering
     the relatively low water recovery of RO when compared
     with other treatment technologies,  this figure should

                                35

-------
     be an upper bound and can be conservatively applied
     to the other treatment technologies.

   4-By contrast, Culp/Wesner/Culp costs for disposal to sludge
     lagoons is based upon lagoon volume,  and to sand beds and
     evaporation ponds upon surface area.   Determining the
     size of these disposal facilities based upon average plant
     flow rate is a complex site-specific computation.  Costing
     these disposal strategies is therefore complex.

   5-The short three month duration of this current
     research precludes exploring all possible options.

Culp/Wesner/Culp determined costs for disposal to sanitary sewers
based upon a 1982 survey of 40 wastewater treatment plants (82-
3).  No standardized indices were used.  This researcher selected
the BLS index for General Purpose Machinery and Equipment for
cost updating purposes:

     Disposal Cost Component             Index

     disposal                            BLS General Purpose
                                         Machinery & Equipment
                                         (Code 114)

The Culp/Wesner/Culp costs for disposal to sanitary sewers is
given for a wide range of groundwater suspended solids
concentration, with costs increasing as suspended solids
concentration increases.  Costs were updated assuming a suspended
solids concentration of 2,000 mg/L as a conservative average.

   It should be noted that disposal to an existing sanitary sewer
is the least costly of all disposal strategies.  Comments
received from the Office of Ground Water and Drinking Water
(OGWDW) HQ EPA,  (91-11) indicate that OGWDW has updated cost
figures (1990) for several disposal options.  The author of this
current report was unaware of this data at the time the draft
report was written.  The short time frame set aside for the final
version of this report precluded investigation into disposal cost
data available from OGWDW.


Updating Costs

   The intent of this current report is to update these  cost
figures based upon current dollars.

   Culp/Wesner/Culp based costs associated with ENR indices upon
the 8 December 1983 index values.  To develop current costs for
ENR categories, it is necessary to divide the current skilled
labor cost index, and current building cost index (values
contained in 91-8) by their respective 8 December 1983

                                36

-------
counterparts (values contained in 83-2).   The resulting factors
are then multiplied by the Culp/Wesner/Culp 1983 costs to
generate 1991 costs.

   Culp/Wesner/Culp based costs associated with BLS  indices upon
the December 1983 index values.  To develop current costs for BLS
categories, it is necessary to divide the current index values
for each of the various BLS indices by their respective December
1983 counterparts  (both sets of values supplied by Philadelphia
BLS office personnel).  The resulting factors are then multiplied
by the Culp/Wesner/Culp 1983 costs to generate 1991 costs.

   The only remaining cost category is for electricity.   Per
Philadelphia area BLS personnel, the June 1991 electricity cost
is $.134 per kwh.  Applying this rate to Culp/Wesner/Culp
electricity requirements generates 1991 electricity costs.

   Computation of the cost factors follows:
                                37

-------
                                   ENR Categories
 Skilled labor index
 Building cost index
 Genl  Purpose Machinery
  &  Equip (Code 114)

 Concrete Ingredients &
  Related Prods (Code 132)

 Steel Mill  Products
  (Code 1017)

 Misc  Genl Purpose
  Equipment  (Code 1149)

 Electrical  Machinery °
  &  Equip (Code 117)
Producer Price  Index  for
 Finished Products

Sodium Hydroxide
 (Code 2812-3)

Carbon Dioxide
 (Code 2813-3)

Sulfuric Acid
 (Code 2819-3)

Other Aluminum  Compounds
 (Code 2819-671)

Sodium Compounds
 (Code 2819-7A)

Other Sodium Phosphates
 (Code 2819-739)

Alkali Earth Metal Cmpnds
 (Code 2819-9A)
!2 Dec 83
3674
2405

2)



r



5


Is

.72
.56
BLS
Dec 83
101.9
101.5
103.0
101.1
105.3
102.3
86.3
124.5
94.2
100.0
102.8
101.4
101.5
38
29 Jul 91
4475.35
2757.18
Categories
Jun 91
128.1
119.0
109.8
136.7
120.9
121.9
167.5
118.4
104.8
131.0
112.4
113.2
114.3

cost facto
1.218
1.146
cost factor
1.257
1.172
1.066
1.352
1.148
1.192
1.941
.951
1.113
1.310
1.093
1.116
1.126


-------
SUMMARY OF CONSTRUCTION COSTS

   A summary of construction costs for both central and POU
defluoridation treatment follows.  Total household cost (THC) is
based upon an average of 3 people per household (HH) using 150
gallons per day (gpd) each.

   Most costs have been derived by updating costs  developed by
Culp/Wesner/Culp  (84-1) by using cost factors generated in this
current report.  Cost estimates for the nanofiltration technology
were provided by a nanofiltration researcher and his marketing
representative and may or may not contain all of the cost
components considered by Culp/Wesner/Culp for the other
technologies.  The smaller of the two POU RO costs is derived
from the EPA-sponsored San Ysidro, New Mexico experience.

   Costs associated with constructing disposal facilities were
not explored due to the short duration of this study, and are
therefore not included in the following construction costs.

   Average plant flow rates are in units of thousands of gallons
per day.
Central Treatment
                             THC  f$ one-time cost per household)
Avg Plant
Flow Rate
1.5
2.5
7
8
10
15
30
40
46
50
63
72
100
150
180
216
300
406
430
500
560
720
>750
Number
of HH
3
6
16
18
22
33
67
89
100
110
140
160
220
330
400
480
670
900
960
1,100
1,250
1,600
>1,700

AA








562



384

293


168


158
142
130
                            RO      ED
                                 12,100
                          9,000
                          3,100
        Alum
         Lime    Nano
                                                               640
                                  4,400
                                  2,400
                                                    3,100
                          1,246


                          1,000   1,100



                                    730


                            700
                                                               680
                          560
                             650
720
600



280


180

160

130
                  490
                  230
170
                          430
340
                                39

-------
POU Treatment
                     	•—THC  fS one-time cost per household'
                     Activated Alumina            Reverse Osmosis

                         407-597                     417_ 547


   The updated construction costs indicate that POU treatment is
more cost effective than central treatment for PWSs servicinq
less than approximately 100 to 200 households  (300 to 600
consumers).  For systems servicing greater than about 200
households (600 consumers)  which have a realistic option of
disposing to an existing sanitary sewer, central defluoridation
treatment becomes increasingly more cost effective than POU
Should disposal to an existing sanitary sewer not be a realistic
option, a greater number of households is required for central
defluoridation treatment to be more cost effective than POU
                               40

-------
SUMMARY OF ANNUAL COSTS

   A summary of  total  annual  costs  for  both  central  and POU
defluoridation treatment follows.   Costs represent the sum of
operation and maintenance, chemical,  and disposal cost
components.  Total household cost is based upon an average of 3
people per household (HH)  using 150 gallons per day (gpd)  each.

   Most costs have been derived by  updating  costs developed by
Culp/Wesner/Culp  (84-1) by using the cost factors generated in
this current report.  Cost estimates for the nanofiltration
technology were provided by a nanofiltration researcher and his
marketing representative and may or may not contain all of the
cost components considered by Culp/Wesner/Culp for the other
technologies.  The smaller of the two POU RO costs is derived
from the EPA-sponsored San Ysidro,  New Mexico experience.

   Comments from the Office of Ground Water  and Drinking Water
(OGWDW), HQ EPA,  (91-11) indicates that strict reliance upon the
Culp/Wesner/Culp report (84-1) for approximating costs based upon
average and design—flow rates will not reflect EPA's best
estimates, contending that OGWDW is developing a new flow regime
which will result in sharply decreased estimates for small system
treatment costs.  OGWDW has been in the process of revising the
estimation of household usage as a function Of flow rate for the
past two years,  using not only the Culp/Wesner/Culp report, but
also a document which is referred to as the "Fluoride Design
Manual" (84-6).   A December 1991 conversation with an employee
from the OGWDW,  however, indicated that OGWDW's revisions are
still in progress, and that the average daily water usage per
person used by this researcher in this current study (150 gallons
per day) is reasonable.  Since the OGWDW anticipates updating
fluoride technology and cost data,  contacting that office at some
future time and applying their cost estimates to this current
study may result  in more refined cost estimate for smaller
systems.

   It should be  noted that the raw water fluoride concentrations
of many PWSs exceed the primary MCL by only a few mg/L  (see chart
on page 14 of this report).  For these systems the blending of
treated and untreated water can result in a product which meets
the primary MCL at a lower cost than treating all of the raw
water.  While this is a valid option for many PWSs, the short
duration of this  study precluded developing costs related to this
option.

   Disposal costs assume disposal to an existing sanitary sewer.
The short time frame of this report and other considerations
prevented the development of costs for other disposal options
(see the discussion on pages 34 and 35 of this report).  It
should be noted that other disposal options would be more costly
than disposal to  an existing sanitary sewer.

                                41

-------

AA




Total H
RO

1553-1780

603-738
OUSGrlol
ED
1395

509

d Cost (S/vrl
Alum Lime





Nano




   Average plant flow rates in the following table are in units
of thousands of gallons per day.

Central Treatment


Avg Plant   Number
Flow Rate   of HH
   1.5         3
   2.5         6
   8          18
  10          22
  15          33                                    599-842
  30          67                      311
  40          89                                              216
  46         100  194-297
  50         110           374-482
  72         160                              162
 100         220  153-198  315-414    243
 150         330                                    113-158
 216         480                              153
 500       1,100                                              158


POU Treatment
                     	Total Household Cost ($/yr)	
                       Activated Alumina     Reverse Osmosis
                             252                H2 - 327

   The  annual  central treatment costs presented  above are
segregated by operation and maintenance, chemical, and disposal
costs for each treatment technology below.  Total household cost
(THC)  is based upon an average of 3 people per household using
150 gallons per day  (gpd)  each.
                               42

-------
Central Treatment
                           Activated Alumina
Avg Plant
Flow Rate
  fgpd)
 45,000
100,000
Avg Plant
Flow Rate
  fgpd)
  2,500
 10,000
 50,000
100,000
Avg Plant
Flow Rate
  fgpd)
   1,500
   8,000
  30,000
 100,000
Avg Plant
Flow Rate
   fgpdl
   72,000
 216,000
Avg Plant
Flow Rate
   (gpd)
   15,000
 150,000
Avg Plant
Flow Rate
   fgpdl
 40,000
500,000
Number
of
H-holds
100
220

O & M
f$/qpd)
.19-. 42
.10-. 20

Chem Disp
.21 .03
.21 .03

Total
f$/gpd)
.43-. 66
.34-. 44

THC
f$/vr)
194-297
153-198
Reverse Osmosis
Number
of
H-holds
6
22
110
220

Number
of
H-holds
3
18
67
220

Number
of
H-holds
160
480

Number
of
H-holds
33
330

Number
of
H-holds
89
1,100

0 & M
(S/gpd)
2.74-3.18
1.08-1.38
.60- .84
.50- .72


0 & M
(S/gpd)
2.98
1.02
.58
.43


0 & M
f$/gpd)
.04
.02


0 & M
($/qpd)
1.21-1.71
.13- .19



Chem Disp
($/gpd) ($/gpd)
.15 .12
.15 .11
.12 .11
.09 .11
Electrodialysis

Chem Disp
0 .12
0 .11
0 .11
0 .11
Alum Coagulation

Chem Disp
f$/gpd) (S/gpd)
.21 .11
.21 .11
Lime Softening

Chem Disp
.01-. 05 .11
.01-. 05 .11
Nanofiltration

0 & M & Chem Disp
f$/qpd) f$/qpd)
.37
.24
.11
.11

Total
f$/gpd)
3.01-3.45
1.34-1.64
.83-1.07
.70- .92


Total
($/gpd)
3.10
1.13
.69
.54


Total
($/gpd)
.36
.34


Total
1.33-1.87
.25- .35


Total
f$/gpd)
.48
.35

THC
f$/vr>
1553-1780
603- 738
374- 482
315- 414


THC
($/vr)
1395
509
311
243


THC
f$/vr)
162
153


THC
($/vr)
599-842
113-158


THC
($/vr)
216
158
                                43

-------
™       uPdated annual costs indicate that POU treatment is more
cost effective than central treatment for PWSs servicinq less
than approximately 100 to 200 households (300 to 600 consumers)
For systems servicing greater than about 200 households  (600
consumers), which have a realistic option of disposing to an
existing sanitary sewer, central defluoridation treatment becomes
increasingly more cost effective than POU.   Should disposal to an
existing sanitary sewer not be a realistic option, a greater
number of households would be required for central defluoridation
treatment to be more cost effective than POU.
                               44

-------
MISCELLANEOUS NOTES REGARDING COST CALCULATIONS
BLS Indices

   The value of Bureau of Labor Statistics index 2812-3,  Sodium
Hydroxide, is not available for the period January 1981 through
November 1985.  In December 1980 the value of the index was 100.0
and in December 1985 it was 86.3 with the value falling
throughout 1986.  For the purposes of updating costs we have
conservatively assumed the December 1983 value to be 86.3.

   The value of BLS index 2819-671,  Other Aluminum Compounds,  is
not available prior to June 1987, when it was 100.0 and remained
100.0 throughout most of 1988.  For the purposes of updating
costs we have assumed the December 1983 value to be 100.0.
Activated Alumina

   Regarding chemical costs,  an economy of scale is apparent in
these figures.  Annual sulfuric acid cost requirements for a
473,000 gallon per day facility may actually be cheaper than that
for an 11,900 gpd operation since the larger facility can buy
sulfuric acid in quantities of tons in lieu of gallons.


Alum Coagulation

   Regarding construction costs,  Culp/Wesner/Culp provides the
following conversion between settling surface area and average
plant flow rate (84-1, p 395):

     surface area      x       rise rate      =       avg plant
                                                      flow rate
      (ft x ft )             fcrod/ft x ft)              fgpdl

           70                    1,030                  72,100
          140                    1,540                 216,000
          250                    1,730                 432,000
          370                    1,560                 576,000
          740                    1,560               1,152,000

   Regarding chemical costs,  researchers have determined that 250
mg/L of alum are required to reduce fluoride concentrations from
3.5 mg/L to 1.5 mg/L, and 350 mg/L to reduce concentrations from
3.5 mg/L to 1.0 mg/L  (78-2).   For cost calculations we will
conservatively assume application of 350 mg/L.

   The following sample calculation will indicate how to
determine annual chemical costs for a 72,000 gal per day
facility:

                               45

-------
350 mg 72,000 gal 365 davs 3.785 L 2.205xl(r6lb = 76.800 Ib  alum
  L       day       year     gal       mg               yr

   Multiplying this figure by current alum costs per Ib yields
annual chemical costs.  Culp/Wesner/Culp used a figure of $.15
per Ib of alum in Dec 1983 dollars.

Reverse Osmosis

   Costs associated with the San Ysidro,  New Mexico POU RO study
have been updated using appropriate BLS and ENR indices and
included in the construction cost summary and operation and
maintenance cost summary.  Since the San Ysidro report was
completed in November 1988, we are assuming all costs were in
November 1988 dollars.

   Construction costs include manufactured equipment (BLS  General
Purpose Machinery and Equipment, Code 114) and labor (ENR Skilled
Labor Index).  Development of construction cost factors follows:

                   Nov 1988  Jun 1991  29 July 1991  cost factor

BLS code 114         115.1     128.1                    1.113
ENR skilled labor   4133.54               4475.35       l!o83

Applying these factors to San Ysidro cost of $290 for equipment
(RO unit) and $36 for labor (installation), yields summer 1991
values of $323 and $40,  respectively.  It should be noted that
the San Ysidro costs for RO units resulted from receiving a
sizeable manufacturer's discount since 80 units were bought at
once.

   About 67% of the operation and maintenance costs associated
with the San Ysidro experience were for labor.  To update San
Ysidro's 1988 costs we have chosen therefore to simply apply the
ENR Skilled Labor Index cost factor of 1.083 as developed above
to San Ysidro's actual monthly operation and maintenance costs of
$8.60 per household.  This yields a summer 1991 value of $9.31
per household per month, or $112 per household per year in summer
1991 dollars.
                               46

-------
APPLICATION TO VIRGINIA PUBLIC WATER SYSTEMS

Areas With Excessive Fluoride

   Information contained in the Federal  Reporting Data System
(FRDS II) was used to determine geographic areas in Virginia
which experience groundwater fluoride concentrations which exceed
the EPA MCL.  Fifty-one Virginia PWSs were so identified.
Twenty-nine of these had concentrations which also exceeded the
unreasonable risk to health (URTH) level of 5.0 mg/L, the highest
being 6.60 mg/L.


       Virginia Public Water Systems with Excess Fluoride

                   # of PWSs  # of PWSs  # of PWSs
                   exceeding  exceeding  exceeding
     County/City   4.0 ma/L   5.0 mq/L   6.0 mg/L   Highest

 Isle of Wight Cnty    10         2          0        5.13
 James City Cnty        1         0          0        4.41
 Southampton Cnty       4         2          2        6.28
 Chesapeake City        2         0          0        4.33
*Suffolk City          34.        25          2.        6.60
                       51        29          4

     source: FRDS II: Summary Violations and Related Enforcement

     * while technically a city, Suffolk has incorporated what
     was formerly Nansemond County

With the exception of the one PWS in James City County which is
just north of the James River on the York-James Peninsula, the
other PWSs all are located in the southeastern corner of
Virginia, in an area bounded by the James River to the north, the
North Carolina border to the south, and Virginia Beach to the
east.

   Fluoride-rich groundwater apparently occurs in geographic
"pockets" and normally does not effect groundwater on a regional-
scale.   For example the North Carolina state water agency's
regional office in the eastern part of the state reports that no
PWSs in  the area are in violation of the fluoride MCL,
concentrations being in the 2.0 to 3.5 mg/L range.  A Gates
County North Carolina water supply operator whose wells are about
20 to 25 miles from Suffolk Virginia, for example, indicates that
fluoride levels in his wells are about 3.1 mg/L.

Hydrogeoloaic Research of Southeastern Virginia

   The reasons for the high fluoride groundwater concentration in
southeastern Virginia groundwater supplies are unclear.  Over the

                                47

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past  few years, however, the United States Geological Survey, has
been  performing a series of hydrogeologic studies of the Virginia
Coastal Plain, of which southeastern Virginia is a part  (see for
example, 90-2, 89-1, 89-2, 88-1, 81-1).  Some of this research
relates to major ion transport, including fluoride.

Recently Published USGS Research

   The most comprehensive of these USGS studies is a 1988 report
(88-1) which defined hydrogeologic characteristics for the water-
table aquifer and seven confined aquifers and intervening
confining units in southeastern Virginia.  The groundwater system
was modeled based upon known prepumping water levels, that is,
prior to 1891.  Using the model, pumping conditions were
simulated to reflect current pumpage rates.  Model results were
consistent with current known water level data, therefore
validating the model.  USGS then tested the response of the
groundwater flow system to increased pumping and determined that
water level decline would be substantial, resulting in
considerable well interference and degradation of water quality.
By testing system response with various pumping scenarios, USGS
determined that year-round pumping at a constant rate would
prevent extreme water level declines normally experienced during
the seasonally dry three month summer period.

   This USGS study divides each of the eight aquifers of the
model area into 4,784 geographic squares, each measuring 1.75
miles on a side (3 square miles per square), and assigns
hydraulic properties, such as transmissivity, hydraulic
conductivity, and specific yield,  to each square, based upon
values quantified in the field, the laboratory, or published
literature.  Isocline maps are included in the report, as well as
maps which demonstrate the effects of increased pumping
simulation, and the resulting creation of,  or increase in, cones
of depression.

   Such analysis  is  included  for the  shallower aquifers  which are
considered lacking in sufficient water to support a PWS, but
provide good quality potable drinking water with fluoride levels
below the MCL.  As a result,  this USGS report represents a
potentially valuable water resources management tool which could
be used to optimize pumping of good quality water from shallower
aquifers by small PWSs.

Current Research

   A contact from  the USGS  Water Resources  Division,  Richmond
office, is currently in the early stages of a review process in
which he is mapping the major ions in the major water producing
aquifers of the area.  This review may take several months to
complete.
                               48

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   Another contact from the USGS Richmond office is currently
writing two reports regarding the hydrogeologic characteristics
of the aquifers of the Virginia Coastal Plain.  One of these
reports discusses the results of water flow and ion transport
(including fluoride) modeling which USGS has performed on the
specific area in southeastern Virginia which is experiencing the
excess fluoride problem.

   The second report is concerned with the decrease in hydraulic
conductivity of the Virginia Coastal Plain from the fall line in
the west to the ocean in the east.  Hydraulic conductivity is a
property of the porous media consistency of a particular aquifer.
When multiplied by aquifer thickness, the resulting quantity,
transmissivity, provides a measure of an aquifer's water yield.
This report will provide transmissivity values for all aquifers
in the Virginia Coastal Plain area, including those shallower
aquifers which have excellent water quality in general, including
low fluoride levels, but are often considered to have
insufficient yields to support PWSs in the area.

   These reports may be available for public review starting in
the fall 1991.

   A graduate researcher at Old Dominion University in Norfolk
Virginia, is exploring the mineralogy of the coastal region to
specifically determine the source of groundwater fluoride.  His
research has indicated that sodium bicarbonate water worldwide
tends to be fluoride-rich, a correlation existing between
concentration of sodium bicarbonate and fluoride solubility.  The
southeastern Virginia fluoride-rich PWSs are in fact in a
hydrogeologic band of sodium bicarbonate-rich water.

   USGS personnel indicated there are no anthropogenic fluoride
sources in southeastern Virginia.

Defluoridation Costs

   The number of consumers serviced by the 51 Virginia PWSs with
fluoride concentrations exceeding the EPA MCL (4.0 mg/L) is
highlighted below:

                     # of         # of        % of total
                   consumers      PWSs        # of PWSs

                     < 300         33           65
                   300 - 600       15           29
                   601 -1080       _3_            6
                                   51

   Before we  discuss the means  by which these PWSs can most cost
effectively defluoridate, it should be noted that, of the four
disposal strategies, only sanitary sewers and sand beds can be

                                49

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considered as realistic options for southeastern Virginia since
sludge lagoons and evaporation ponds are viable options only in
relatively dry locales with high evapotranspiration rates,  in
southeastern Virginia, where the average annual precipitation
rate, 43 inches per year  (90-2), exceeds the average
evapotranspiration rate,  21.5 inches per year (90-2), these
disposal strategies are unrealistic.

   As indicated earlier in this report,  POU is more cost
effective than central defluoridation treatment for PWSs
servicing less than approximately 100 to 200 households (300 to
600 consumers).  POU defluoridation is therefore more cost
effective for at least 65% and possibly as high as 94% of the 51
Virginia PWSs with excessive fluoride groundwater concentrations.

   This cost analysis is based upon central treatment disposal  to
existing sanitary sewers.  This current research has not
determined however whether any of the 51 PWSs are located in
close proximity to an existing sanitary sewer.  Should a PWS be
required to construct either a sanitary sewer or a sand bed, a
greater number of households would be required for central
defluoridation treatment to be more cost effective than POU.

   It is possible that PWSs of a  given size might  more cost
effectively comply with federal fluoride regulations by
exercising other compliance options such as: developing a new
well which produces water which meets the MCL; connecting to or
hauling water from a PWS which produces water which meets the
MCL; or purchasing and distributing bottled water which meets the
MCL.  The short time frame of this current research, however,  has
prevented this researcher from exploring costs related to these
options.
                               50

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CONCLUSIONS

1.   On 2 April 1986 EPA promulgated the final fluoride rule
     (R86-1),  establishing an enforceable primary MCL of 4.0 mg/L
     "to protect against crippling skeletal fluorosis", and a
     non-enforceable secondary MCL of 2.0 mg/L "to protect
     against objectionable dental fluorosis".   The regulation
     also identified activated alumina and reverse osmosis as
     BAT.  This is the currently applicable federal fluoride
     regulation.

2.   Some prominent national medical, dental and public health
     groups did not support EPA's inclusion of fluoride as a
     contaminant to be regulated by the Primary Drinking Water
     Regulations.  Representatives from these organizations still
     maintain opposition.

3.   The most recent comprehensive toxicological analysis of the
     effects of fluoride was published by the Public Health
     Service in February 1991.  PHS concluded there is no
     link between fluoride and cancer, and that crippling
     skeletal fluorosis is extremely rare in the United States.
     EPA review of the PHS and other documents is currently in
     progress.

4.   In 1985 about 185,000 people nationwide were serviced by
     public water systems with fluoride concentrations exceeding
     4 mg/L,  17,000 people by those exceeding 6 mg/L, and 3,000
     people by those exceeding 8 mg/L.  Some of these public
     water systems have since pursued other drinking water
     sources in order to avoid defluoridation costs.  While the
     total number of PWSs with excessive fluoride has decreased,
     this report has not identified whether the total number of
     consumers exposed to excessive fluoride in drinking water
     has changed.

     Comments from the Office of Ground Water and Drinking Water
     (OGWDW),  HQ EPA (91-12), indicate that OGWDW has estimates
     regarding population exposure to fluoride at various
     concentrations and that this information will be updated
     concurrent with the next review of the fluoride rule.

5.   Public water systems faced with excess fluoride in their
     groundwater drinking water supply currently have only
     four options to permanently meet fluoride regulations:
     construction of central treatment; developing a new well
     which meets the fluoride regulations; connecting to or
     hauling water from a public water system which is meeting
     the fluoride regulations; or installing point-of-entry
     (POE) devices.  In most cases these compliance options are
     relatively expensive operations.  Small systems are, in
     effect,  penalized by the principle of economy of scale in

                                51

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     constructing and operating central treatment facilities  and
     in developing new wells.

     This report has not identified costs related to connecting
     to or hauling water from a public water system which is
     already complying with federal fluoride regulations.
     Developing costs associated with drilling new wells and
     connecting to compliant systems, in conjunction with costs
     developed in this report for other compliance options, would
     more completely determine the best compliance option which a
     public water system of a given size should pursue in
     order to meet federal fluoride regulations.

6.   Point-of-use treatment, and purchasing and distributing
     bottled water are not currently acceptable as long-term
     options to meet fluoride regulations.  For small systems
     these are oftentimes the only compliance options which are
     affordable.

7.   The effectiveness of POU/POE activated alumina and reverse
     osmosis -defluoridation techniques has been proven.  Most
     experts agree that legal and managerial problems relating
     to monitoring, testing, and maintenance preclude POU/POE
     as BAT for fluoride.  Some of the operational,  legal, and
     managerial problems associated with POU/POE have been
     addressed by various reports and studies,  particularly,
     the San Ysidro,  New Mexico EPA-sponsored research, and
     solutions to some of these problems have been proposed.

8.   On a per gallon basis, monthly treatment costs for POU/POE
     technologies are substantially higher than that for central
     treatment.  However, while POE technology processes
     100% of household water demand,  POU technology requires
     treatment of only about 10% of such demand.  As a result,
     POU monthly household treatment costs are less than that
     for both central treatment and POE devices.

9.   One time construction costs for POU techniques are
     substantially less than construction costs for central
     treatment facilities,  especially for small water systems.

10.  EPA Cincinnati is currently in the process of writing an
     RFP to hire a contractor to assess performance of the
     San Ysidro test.

11.  POU/POE technology is still in a state of  development but
     some systems are incorporating techniques  approaching state
     of the art.

12.  Construction and annual treatment costs updated for this
     report indicate  that POU defluoridation treatment is more
     cost effective than central treatment for  public water

                               52

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     systems servicing less than about 100  to 200  households
     (300 to 600 consumers).   For public water systems servicing
     greater than about 200 households (600 consumers),  which
     have a realistic option of disposing to an existing
     sanitary sewer,  central defluoridation becomes increasingly
     more cost effective than POU.   Should  disposal to an
     existing sanitary sewer not be a realistic option,  a greater
     number of households would be required for central
     defluoridation treatment to be more cost effective than POU.

13.   The HQ EPA Low-cost Innovative Small System Initiative
     anticipates that a mix of POU and POE  technologies will be
     used at the King's Point Subdivision site in Suffolk
     Virginia to assess the possibilities of defluoridation by
     decentralized technologies.  As of the writing of this
     report the State of Virginia and the Subdivision were in
     the process of reviewing the bids submitted by four
     contractors.

14.   A New Hampshire vendor is currently exploring the
     effectiveness of a POE bone char device to remove fluoride.
     The device's ability to effectively remove arsenic has been
     demonstrated.  It is known that arsenic and fluoride are
     similarly removed, in fact competitively, with arsenic
     removal dominating fluoride removal.  A proven arsenic
     removal technique could potentially remove fluoride,
     especially in a groundwater source which has small arsenic
     concentrations.

15.   Regarding bone char as a treatment technique, little
     research has been done to determine optimal processing
     parameters, though researchers have developed simple
     operating techniques using bone char for use by illiterate
     Third World communities.  A recently published World Health
     Organization study indicates that bone char adsorption
     capacity is comparable to that of activated alumina.
     Activated alumina is BAT for fluoride.  No cost analyses
     regarding bone char are currently available.

16.   A combined alum/lime small-scale defluoridation treatment
     known as the Nalgonda technique has been developed for use
     by illiterate people in rural communities in India.

17.   The nanofiltration treatment technique has been developed
     since the April 2, 1986 promulgation of the final fluoride
     rule.  Researchers indicate that the technology requires
     less energy and produces a substantially smaller waste
     stream than reverse osmosis.  Reverse  osmosis is considered
     best available technology  (BAT) for fluoride.  Home use
     nanofiltration devices are currently being developed.

18.   A defluoridation technique using hydrous cerium oxide has

                                53

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     recently been developed and patented.  While the technique
     has been used predominantly to treat wastewater, it may
     be effective for treating groundwater.  No cost figures are
     currently available.

19.  Fluoride concentrations in excess of the EPA MCL (4.0 mg/L)
     effect groundwater-source public water systems throughout
     the continental United States.  Fluoride-rich groundwater
     occurs in geographic "pockets" and does not normally effect
     groundwater on a regional-scale.  Fluoride in groundwater is
     predominantly a naturally occurring phenomena.

20.  On-going United States Geological Survey research is
     quantifying major hydrogeological and water chemistry
     parameters of the Virginia Coastal Plain on an aquifer
     by aquifer basis using modeling nodes separated by as
     few as two miles.  This data represents a potentially
     valuable water resources management tool which could be used
     to assist local public water systems in selecting well
     sites.  Some of the reports which USGS is currently
     preparing may be available for public view as early as
     fall 1991.

21.  While 51 Virginia public water systems use groundwater
     drinking water sources which exceed the EPA fluoride MCL
     (4.0 mg/L),  only four of these water supplies have
     concentrations exceeding 6.0 mg/L, the highest being
     6.60 mg/L.

22.  POU defluoridation is more cost effective than central
     treatment for at least 65% and possibly as high as 94% of
     the 51 Virginia public water systems with fluoride
     concentrations exceeding the EPA MCL.   Should any of these
     systems be required to construct either a sanitary sewer or
     a sand bed,  the number of systems for which POU is more cost
     effective would increase.   This report has not identified
     the proximity of existing sanitary sewers to any of the 51
     public water systems.

23.  It is possible that some of the 51 Virginia public water
     systems with excessive groundwater fluoride concentrations
     might comply more cost effectively with federal fluoride
     regulations  by either developing a new compliant well,
     connecting to or hauling water from a  compliant public
     water system,  or purchasing and distributing compliant
     bottled water.   This report has not identified costs
     associated with these three options.
                               54

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RECOMMENDATIONS

1.   EPA could profitably gain by continuing efforts to determine
     the number of consumers exposed to excessive fluoride at
     various levels in drinking water in order to determine risk
     factors associated with fluoride exposure in the United
     States today.
     (See conclusion 4)

2.   EPA could profitably gain from efforts to develop costs
     associated with drilling new wells, connecting to compliant
     systems, and purchasing and distributing compliant bottled
     water to determine the best compliance option which a public
     water system of a given size should pursue in order to meet
     federal fluoride regulations.
     (See conclusion 5 and 23)

3.   EPA could profitably gain by continuing to address the
     operational, legal and managerial problems associated with
     POU/POE techniques, as revealed in the San Ysidro, New
     Mexico research and other POU/POE studies.  Resolving these
     problems could lead to eventual inclusion of POU/POE
     defluoridation as BAT.
     (See conclusions 6 through 12, and 22)

4.   EPA could profitably gain by continuing to stimulate
     industry development of POU/POE techniques by encouraging
     industry to engage in the Low-cost Innovative Small System
     Initiative and other creative and alternative programs.  The
     San Ysidro experience should assist EPA in honing RFP
     requirements to achieve better industry response.
     (See conclusions 10, 11 and 13)

5.   EPA could profitably gain from efforts to assess the
     effectiveness of bone char as both a central and POU/POE
     treatment technique.
     (See conclusions 14 and 15)

6.   EPA could profitably gain from efforts to assess the
     effectiveness of the Nalgonda technique as a small-scale
     defluoridation option.
     (See conclusion 16)

7.   EPA could profitably gain from efforts to assess the
     effectiveness of nanofiltration as both a central and
     POU/POE defluoridation option.
     (See conclusion 17)

8.   EPA could profitably gain from efforts to assess the
     effectiveness of adsorption by cerium oxide as a
     defluoridation option.
     (See conclusion 18)

                                55

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9.   EPA could profitably gain by working in conjunction with the
     United States Geological Survey in assisting public water
     systems in selecting well drilling sites.
     (See conclusions 19 and 20)
                               56

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REFERENCES

Regulations:

R91-1     Federal Register, Part II, Environmental
          Protection Agency, 40 CFR Parts 141,142, and 143
          National Primary Drinking Water Regulations;
          Final Rule, January 30, 1991

R86-1     Federal Register, Part II, Environmental
          Protection Agency, 40 CFR Parts 141, 142 and 143
          National Primary and Secondary Drinking Water
          Regulations; Fluoride; Final Rule, April 2, 1986

R85-1     Federal Register, Part II, Environmental
          Protection Agency, 40 CFR Part 141 Fluoride;
          National Primary Drinking Water Regulations;
          Proposed Rule, May 14, 1985


Journals, Technical Articles, Texts and Correspondences:

91-1 Regeneration by Surface-Coating of Bone Char Used for
     Defluoridation of Water, by J. Christoffersen, M.
     Christoffersen, Larsen & Holler, Water Resources, v25, n2,
     1991

91-2 Review of Fluoride Benefits and Risks. Report of the Ad Hoc
     Subcommittee on Fluoride of the Committee to Coordinate
     Environmental Health and Related Programs, conducted by the
     National Toxicology Program of the Public Health Service, US
     Department of Health and Human Services, February 1991

91-3 Completed Questionnaire for Potential Public-Private
     Partnership Demonstration Projects submitted by the Public
     Utilities Manager, Town of Colchester, Connecticut to EPA
     Region I.  Provided by George Mollineaux, P3 contact point,
     EPA Region I

91-4 Fax from Chuck Botdorf, Yuma Proving Grounds, 10 July 1991

91-5 Fax from Chuck Botdorf, Yuma Proving Grounds, 15 July 1991

91-6 Information package re: HMR Black (Bone Char) submitted by
     Pristine Filter Corporation, Melvindale Michigan, contact:
     Mike Szczepanik, 15 July 1991

91-7 Revised Draft Workgroup Version of Variance and Exemption
     Rule Preamble and Regulations, originated by Office of
     Ground Water and Drinking Water, WH550E, HQ EPA, cover
     letter dated 16 May 1991
                                57

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 91-8  Engineering  News-Record,  29 July 1991

 91-9  Producer  Price  Indexes  Data for  April  1991, US  Dept  of
      Labor,  Bureau of  Labor  Statistics, May 1991

 91-10 Fax  from Andrea  Jones, US Dept  of Labor,  Bureau  of  Labor
       Statistics, Philadelphia, 14 August 1991

 91-11 Review Comments  on Draft Fluoride Report, letter from
       James  M. Conlon, Director, Drinking Water Standards
       Division, Office of Ground Water and  Drinking  Water,
       HQ EPA,  October  4, 1991

 91~12  Comments on the  NNEMS  Intern Report on Fluoride  Control
       Options  for Small Water  Systems, letter from David  W.
       Schnare, Office  of Ground Water and Drinking Water, HQ
       EPA, September 20, 1991

 90-1  Environmental Pollution Control  Alternatives; Drinking
      Water Treatment for Small Communitiesf Center for
      Environmental Research  Info, Cincinnati Ohio,
      EPA/625/5-90/025, April 1990

 90-2  Conceptualization & Analysis of  Ground-Water Flow
      System  In the Coastal Plain of Virginia &  Adjacent
      Parts of Maryland and North Carolinar by Harsh  &
      Laczniak, USGS Professional Paper 1404-F,  1990

 90-3 Removal of Fluoride Ion From Wastewater bv a Hydrous
     Cerium Oxide Adsorbent, by Nomura, Imai &  Miyake, in
     Emerging Technologies in Hazardous Waste Management,, edited
     by Tedder &  Pohland, 1990

 90-4 Hazardous Waste Chemistry. Toxicology and  Treatment  by
     Stanley E. Manahan, 1990                           '

 90~5 Point-of-Use Treatment of Drinking Water in San Ysidro. NM
     by Rogers, EPA/600/S2-89/050,  March 1990

 90-6 Dose Determination and Carainocfenicity Studies of Sodium
     Fluoride in Crl:CD-l Mice and CrlrCD (Soraaue Davley^ RT?
     Rats,  sponsored by Proctor & Gamble,  June  28,  1990

 90~7 NTP Technical Report on the Toxicology and Carcinoaenesis
     Studies of Sodium Fluoride in 344/N Rats and B6C3F1 Mice
      (Drinking Water Studies!.  DHHS,  NIH Report No.  90-2848, 1990

90~8 Feasibility Study; Use of POE Treatment for Radium Reduction
     in Bellevue.  Wisconsint  by Stevens and Anderson, National
     Sanitation Foundation,  Ann Arbor, Michigan, March 1990

89-1 Hvdroaeoloaic Framework of the Virginia Coastal Plainr  by

                               58

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     Meng & Harsh, USGS Professional Paper 1404-C, 1989

89-2 The Occurrence & Geochemistry of Salty Ground Water in the
     Northern Atlantic Coastal Plain, by Meisler, USGS
     Professional Paper 1404-D, 1989

89-3 Fluoride in Drinking Water-Evaluation of Health Effects.
     letter from Michael Cook, Director, Office of Drinking Water
     (WH-550), HQ EPA, and Renate Kimbrough, MD,Director, Health
     and Risk Capabilities, 21 February 1989

89-4 Nalgonda Technique-A Process for Removal of Excess Fluoride
     from Water, by Nawlakhe & Bulusu, Water Quality Bulletin,
     v!4, n4, October 1989

89-5 Test of Nanofilter Method of Treating Recharged Municipal
     Effluent. Cluff, et al, February 1989

89-6 Test of Nanofilter Method of Treating Central Arizona
     Project Waterf  Cluff, et al, March 1989

89-7 Summary Report; Fluoride Reduction Feasibility Studies of
     Four West Texas Water Systems, prepared for USEPA,
     Municipal Facilities Div, prepared by Engineering-Science
     Inc.,  Austin Texas, December 1989

89-8 Membrane Softening; A Treatment Process Comes of Age, by
     Conlon & McClellan, Journal AWWA, November 1989

88-1 Hydrogeology & Analysis of the Ground-Water Flow System in
     the Coastal Plain of Southeastern Virginia, by Hamilton &
     Larson, USGS Water-Resources Investigations Report 87-4240,
     1988

88-2 Title unknown,  by Chaturvedi, Pathak & Singh, Appl. Clay
     Sci.,  V3, p 337, 1988

88-3 A Defluoridator for Individual Households, by Phantumvanit,
     Songpaisan & Moller, World Health Forum, v9, 1988

88-4 Point-of-Use Treatment of Drinking Water in San Ysidro. NM.
     by Rogers, in fulfillment of Cooperative Agreement No.
     CR-812499-01 by the Village of San Ysidro under the
     sponsorship of the USEPA, covering the period July 1985
     through January 1988, completed November 1988

88-5 Proceedings; Conference on Point-of-Use Treatment of
     Drinking Water, chaired by Tom Sorg,  Drinking Water Research
     Division, USEPA, Cincinnati Ohio, EPA/600/9-88/012, June
     1988

88-6 United States Patent Number 4,717,554, Process for

                                59

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     Adsorption Treatment of Dissolved Fluoriner by Nomura,
     Imai, Ishibashi & Konishi, 5 January 1988

88-7 Engineering News-Record, 24 November 1988

87-1 Removal of Arsenic From Bedrock Wells bv Activated Aluminar
     by Kessler, masters' report submitted to Department of Civil
     Engineering, College of Engineering, Northeastern
     University, Boston Massachusetts, December 1987

87~2 City of Fort Myers Water Treatment Process Testing and
     Evaluation Program, Boyle Engineering Corporation

87-3 Controlling Arsenic. Fluoride, and Uranium by Point-of-Use
     Treatment, by Fox & Sorg, EPA Cincinnati, Journal AWWA
     October 1987

86-1 Removing Dissolved Inorganic Contaminants from Water, by
     Clifford, Subramonian & Sorg, Environmental Science &
     Technology, v20, nil, 1986

86-2 Fluorosis with Crippling Skeletal Deformitiesr by
     Moudgil, et al, Indian Pediatri, 23(10): 767-73, 1986

86-3 Groundwater Pollution Control, by Canter & Knox, 1986

85-1 Defluoridation of Drinking Water in Small Communities, by
     Bellen & Anderson, National Sanitation Foundation, Sep 85

85~2 Authiaenic Fluorite in Dolomitic Rocks of the Floridan
     Aquifer, by Cook,  Randazzo & Sprinkle,  Geology, v!3,  1985

85-3 Management of Point-of-Use Drinking Water Treatment Systems.
     by Bellen, Anderson & Cottier, National Sanitation
     Foundation, under EPA contract R809248010,  post-September
     1985, undated

85-4 Point-Of-Use Treatment for Removal of Inorganic
     Contaminants,  by Clifford,  Proceedings Fourth Domestic Water
     Quality Symposium, Chicago II, December 1985

85-5 Letter from Douglas Ginsburg,  Administrator,  Office of
     Information and Regulatory Affairs,  Office of Management &
     Budget,  to Lee Thomas,  Administrator,  EPA,  Wash DC,
     26 April 1985

85-6 Drinking Water Criteria Document on Fluoride.  EPA Office of
     Drinking Water, Contract 68-03-3279,  1985

85-7 Fluoridation of Water and Cancer:  A Review of the
     Epidemioloaical Evidence,  by Knox,  1985
                               60

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84-1 Estimation of Small System Water Treatment Costs,  by
     Gumerman,  Burris & Hansen, Culp/Wesner/Culp Consulting
     Engineers, under contract no.  68-0303093,  under EPA
     sponsorship, March 84

84-2 Fluoride in the Ground Water of Northeastern Ohio, by
     Corbett and Manner, Groundwater, v22,  nl,  Jan-Feb 1984

84-3 A Mobile Drinking Water Treatment Research Facility for
     Inorganic Contaminants Removal: Design.  Construction, and
     Operation, by Clifford & Bilimoria, under contract to the
     EPA Municipal Environmental Research Laboratory, Cincinnati
     Ohio, EPA-600/S2-84-018, March 1984

84-4 Guidelines for Drinking-Water Quality. Volume 1.
     Recommendations. World Health Organization, Geneva, 1984

84-5 Letter from Surgeon General Koop to William D. Ruckelshaus,
     23 January 1984

84-6 Design Manual:^Removal of Fluoride from Drinking Water
     Supplies by Activated Alumina, by Rubel, prepared for the
     Drinking Water Research Division, Municipal Environmental
     Research Lab, EPA Cincinnati,  August 1984

84-7 Membrane Separation Processes, by Applegate, Chemical
     Engineering, 11 June 1984

84-8 Effect of Severe Dental Fluorosis on the Oral Health of
     Adults, by Eklund, Ismail, Burt, and Calderone, November
     27, 1984

83-1 Survey of Inorganic Contaminants, by Clifford, Sorg &
     Frank, Proceedings AWWA Seminar on Control of Inorganic
     Contaminants, 1983

83-2 Engineering News-Record, 22 December 1983

82-1 World Health Organization Guidelines for Drinking Water
     Quality, 1982

82-2 Ad hoc Committee Report on Dental Fluorosis. Draft Report
     to the Chief Dental Officer. Public Health Service, by
     Albertini, Bock, Confrancesco, Driscoll, Small & Clark,
     21 July 1982

82-3 Sewer Charges for Wastewater Collection and Treatment-A
     Survey. Water Pollution Control Federation, 1982

81-1 Ground Water Resources of the Four Cities Area. Virginia.
     by Siudyla, May & Hawthorne, Planning Bulletin 331,
     Commonwealth of Virginia, State Water Control Board,

                                61

-------
     Nov 1981

81~2 The Equilibrium Fluoride Capacity of Activated Alumina.
     Determination of the Effects of PH and Competing Ionsr by
     Singh & Clifford, of the University of Houston, prepared
     for the EPA Municapal Environmental Research Lab,
     Cincinnati, May 1981

8 °-l Recommended Dietary Allowances. National Academy of
     Sciences, 1980

80-2 Drinking Water and Health. v3, National Academy of
     Sciences, 1980

8°-3 Water Chemistry, by Snoeyink & Jenkins, 1980

80-4 Pilot Study of Fluoride and Arsenic Removal from Potable
     Water, by Rubel, EPA-600/2-80-100, August 1980

79-1 The Removal of Excess Fluoride from Drinking Water by
     Activated Aluminar by Rubel & Woosley, Water Technology/
     Quality, AWWA Journal, January 1979

78-1 Removal of Excess Fluoride from Drinking Waterr by Rubel
     & Woosley, for the USEPA Office of Water Supply, Technical
     Report EPA 570/9^78-001, January 1978

78~2 Treatment Technology to Meet the Interim Primary Drinking
     Water Regulations for Inorganicsr  by Sorg, EPA Cincinnati,
     Journal AWWA, v70, pp 105-112, February 1978

75-1 Defluoridation of Wastewaterr by Zabban & Helwick,
     Proceedings of the 30th Industrial Waste Conference, Purdue
     University, 1975

75-2 Efficacy and Safety of Fluoridation.  American Medical
     Association, Council on Foods and Nutrition, Chicago, 1975

74-1 Lime.  CaCl..,  Beat  Fluoride  Wastewater.  by  Rohrer, Water and
     Wastes Engineering,  Nov 1974

73-1 Geological Studies.  Coastal Plain of Virginia,  by Teifke &
     Onuschak, Planning Bulletin 83, Parts 1,  2 & 3,  Commonwealth
     of Virginia, Dept of Conservation & Economic Development,
     1973

73-2 A History of Water Fluoridation.  by Murray,  Brit.  Dent.  J.,
     134:250-4, p 299-302,  347-350, 3  April 1973

73-3 Title unknown,  by Waldbott, published by C V Mosby Co,
     St. Louis, 1973
                               62

-------
73-4 The Chemistry of Fluorine,  by O'Donnell,  Pergamon Press,
     Elmsford,  NY, 1973

72-1 Physicochemical Processes,  by Weber,  1972

71-1 Biological Effects of Atmospheric Pollutants:  Fluorides.
     prepared by the Committee on Biological Effects of
     Atmospheric Pollutants,  Division of Medical Sciences,
     National Research Council,  National Academy of Sciences,
     Washington DC, p 209-214, 1971

71-2 Radiculomvopathy in a Southwestern Indian due to Skeletal
     Fluorosis. by Goldman, Sievers,  and Templin,  Arizona
     Medicine,  28:675-677, 1971

70-1 Water Fluoridation-The Search and the Victory, by McClure,
     Human Health Services (then Health, Education & Welfare),
     1970

70-2 Fluoride and Dental Health, by Adler, In Fluoride and
     Human Health, p 323-354, World Health Organization, Geneva,
     1970

70-3 Toxic Effects of Large Doese of Fluoride, by Bhussry,  in
     Fluoride and Human Health,  p 230-239, World Health
     Organization, Geneva, 1970

68-1 A Fluoride Filter for Domestic Use, by Roche,  New Zealand
     Dentistry J, v64, 1968

65-1 Effects of Fluorides on Bones and Teeth,  by Hodge & Smith,
     in Fluorine Chemistry. v4,  p337-693,  New York Academic
     Press, 1965

65-2 Chronic Fluoride Intoxication with Fluorotic
     Radiculomyelopathy. by Sauerbrunn, Ryan,  and Shaw, Ann.
     Intern. Med., 63:1074-1078, 1965

62-1 Public Health Service Drinking Water Standards-1962, USPHS,
     publication 956, US Government Printing Office, Washington
     DC, 1962

59-1 Dana's Manual of Mineralogy, revised by Hurlbut, 1959

53-1 Medical Aspects of Fluorosis. by Shimkin, Arnold, Hawkins &
     Dean, American Association Advancement Sciences, 1953

53-2 The Problem of Providing Optimum Fluoride Intake for
     Prevention of Dental Caries. by Sognnaes, a Report of the
     Committee on Dental Health, publication 294,  p4, November
     1953
                                63

-------
51-1 Condition of the Formation of Fluorite in Sedimentary Rocksr
     by Kazakov & Sokolova, English translation by Skitsky, USGS
     TEI-386, 76 pages, 1951

42-1 Domestic Water and Dental Caries, by Dean, Arnold & Elvove,
     Pub. Health Rep. 57:1155, 1942

25-1 Mottled Enamel; A Fundamental Problem in Dentistry, by
     McKay, Dental Cosmos, v69, p 847, 1925
                               64

-------
TELEPHONE CONTACTS

Note: The following contacts furnished information deemed
      pertinent to this report.


HQ EPA

     Mark Parrotta, Office of Drinking Water and Ground Water

     Dr. Ken Bailey, Office of Science and Technology

     Al Havinga, regarding POU/POE policy

     Dr. David Schnare, regarding low-cost technology initiative


EPA Cincinnati Research Facility

     Tom Sorg

     Jim Smith

     Ben Lykins


EPA Regional Offices

     John Haederlie, Region I, Boston

     George Mollineaux, Region I, Boston

     Steve Gould, Region II, New York

     Kenneth Dean, Region IV, Atlanta

     Harry Pawlowski, Region V, Chicago

     Chris Urban, Region V, Chicago

     Bill Davis, Region VI, Dallas

     Len Pardee, Region VI, Dallas

     Stan Calow, Region VII, Kansas City

     Melanie Abel, Region VIII, Denver

     Bob Benson, Region VIII, Denver

     Bruce Macler, Region IX, San Francisco
                                65

-------
     Alan Hemming, Region, X, Seattle


National Institute of Health, Public Health Service

     John Small, fluoride expert


State Drinking Water Personnel

     Dan Home, Field Office Director, Virginia Dept of Health

     Shahram Mohsenin, engineer, Virginia Department of Health,
     Virginia Beach Regional Office

     Michael Bell, North Carolina State's Regional Drinking Water
     Office in eastern part of the state, Washington NC

     Marvin Murray, South Carolina Drinking Water Office

     John Dahl, Arizona State's Drinking Water Office

     Bob Burns, California Department of Health Services

     Norm Hahn, Wisconsin Department of Natural Resources


Private Research Organizations

     Gordon Bellen, National Sanitation Foundation, Ann
     Arbor, Michigan

     Tom Stevens, National Sanitation Foundation, Ann
     Arbor, Michigan

     Joe Harrison, technical director, Waste Quality
     Association, Lisle,  Illinois

     John Trax, National  Rural Water Association, Washington DC


Water Utility Managers/Operators

     Chuck Botdorf, Yuma  Proving Grounds

     Bud Eure,  Gates County North Carolina Water Supply

     Chester Antonick, Sue Juan Water Co., Arizona

     Tom Werner, engineer in charge of water protection,
     City of Suffolk,  Virginia
                                66

-------
     Wayne Johnson, head of water lab, Yuma Bureau of
     Reclamation Desalting Plant

     William Harrell, Director of Public Utilities, City
     of Suffolk, Virginia
University Research Facilities

     Paul Maciuika, graduate student researching fluoride
     in southeastern Virginia groundwater, Old Dominion
     University, Norfolk, Virginia

     Dr. Brent Cluff, nanofiltration researcher, University
     of Arizona at Tucson
Medical Profession

     Dr. Mike Morgan, Oklahoma State Health Department, State
     Dental Director, former Chairman of the Association of
     State and Territorial Dental Directors

     Dr. Lum Young, Nebraska State Health Department, State
     Dental Director, former Chairman, Fluoride Committee,
     Association of State and Territorial Dental Directors

     Dr. Duncan Clark, American Medical Association, New York
     City

     Tom Reeves, Center for Disease Control, Atlanta Georgia

     Dr. Mel Ringelberg, Florida State Dental Director, Chairman
     Fluoride Committee, Tallahassee, Florida


Water Industry Consulting/Marketing/Production Personnel

     Ron Saylor, marketing representative, nanofiltration
     technology

     Frank Brigano, Culligan

     Bob Lake, Water Treatment Engineers, consulting firm,
     Tucson Arizona

     Mike & Ann Szczepanik, Ebonex Co., producers of bone black
     (bone char), Melvindale Michigan

     Mark Widdison, Culligan of New Hampshire

     Greg Gwaltney, ECOS, consulting firm coordinating the King's

                                67

-------
     Point Subdivision Low-cost Innovative Small System
     Initiative

United States Geological Survey

     Gary Speiran, Richmond Virginia office

     Mike Socazio, Richmond Virginia office

     Bob Mixon, Reston Virginia office


Other


     Joe Carpenter Jr.,  private developer in Suffolk, Virginia
     area

     Chris Mauro, Bureau of Labor Statistics,  Philadelphia PA

     Andrea Jones, Bureau of Labor Statistics, Philadelphia PA

     Debra Darr, Hampton Roads Planning District Commission,
     Hampton Roads, Virginia
                               68

-------
CONSTRUCTION COST SUMMARY - CENTRAL TREATMENT - ACTIVATED ALUMINA
plant capacity (millions of
Cost Category
Excavation and sitework
Manufactured equipment
Equipment
Activated alumina
Concrete
Labor
.046
5,725
16,090
1,834
469
1,462
.102
5,725
30,042
4,061
1,406
1,827
.180
5,725
49,149
7,074
2,110
2,436
.406
5,725
63,604
15,589
2,344
3,410
aallons per day)
.552
5,725
81,077
20,174
2,930
4,019
.720
5,725
91,635
25,676
3,750
4,141
1.080
5,725
126,957
38,514
4,805
5,116
Piping & valves            7,030    8,788     8,788   11,357    17,306    17,982    27,175



Electrical instrumentation 7,347    7,347     7,347    9,184     9,184     9,758    11,021



Housing                    9,970   16,502    19,367   20,513    28,421    39,422    50,309






Subtotal                  49,927   75,698   101,996  131,726   168,836   198,089   269,622






Design contingencies       7,489   11,355    15,299   19,759    25,325    29,713    40,443






TOTAL ***                 57,416   87,053   117,295  151,485   194,161   227,802   310,065






*** based on labor cost of $13.40 per hour






                                          A- 1

-------
OPERATION AND MAINTENANCE COST SUMMARY - CENTRAL TREATMENT - ACTIVATED ALUMINA
avg plant act alumina
flow rate volume
(cfpd) ( cubic feet)

Regeneration
45,000
101,000
180,000
406,000
553,000
722,000
1,083,000

frequency =
31.4
70.7
126
283
385
503
754
bldna

4.5 days
268
469
603
657
978
1,635
2,291
energy
($/yr)
process


590
1,273
2,224
2,452
2,452
2,452
2,452
total


858
1,742
2,827
3,109
3,430
4,087
4,743
maintenance
material
rS/vr)


1,073
1,907
2,980
6,079
8,106
10,370
15,138
labor
($/yr)


17,152
17,152
17,849
17,849
18,546
18,546
24,683
total
cost ***
($/vr)


19,083
20,801
23,656
27,037
30,082
33,003
44,564
Regeneration frequency = 8 days






If
45,000
101,000
180,000
406,000
553,000
722,000
083,000
31.4
70.7
126
283
385
503
754
268
469
603
657
978
1,635
2,291

1
2
2
2
2
2
590
,273
,224
,452
,452
,452
,452

1,
2,
3,
3,
4,
4,
858
742
827
109
430
087
743
834
1,311
1,907
3,576
4,768
5,960
8,702
12
12
12
12
13
13
17
,248
,248
,944
,944
,641
,641
,326
13,940
15,301
17,678
19,629
21,839
23,688
30,771
Regeneration frequency = 12 days
45,000
101,000
180,000
406,000
553,000
722,000
1,083,000
31.4
70.7
126
283
385
503
754
268
469
603
657
978
1,635
2,291
590
1,273
2,224
2,452
2,452
2,452
2,452
858
1,742
2,827
3,109
3,430
4,087
4,743
715
1,073
1,550
2,622
3,457
4,410
6,198
10,398
10,398
11,095
11,095
11,792
11,792
14,539
11,971
13,213
15,472
16,826
18,679
20,289
25,480
***  based upon labor costs of $13.40 per hour and energy costs of $.134 per kwh
                                          A- 2

-------
OPERATION AND MAINTENANCE COST SUMMARY - CENTRAL TREATMENT - ACTIVATED ALUMINA
avg plant act alumina
flow rate volume
(crpd) (cubic feet)

Regeneration
45,000
101,000
180,000
406,000
553,000
722,000
1,083,000

frequency =
31.4
70.7
126
283
385
503
754
bldncr

19 days
268
469
603
657
978
1,635
2,291
energy
($/yr)
process


590
1,273
2,224
2,452
2,452
2,452
2,452
maintenance
material
total r$/vri


858
1,742
2,827
3,109
3,430
4,087
4,743


596
834
1,192
1,907
2,384
2,980
4,172
labor
($/yr)


8,844
8,844
9,541
9,541
10,238
10,238
12,221
total
cost ***
fS/vrl


10,298
11,420
13,560
14,557
16,052
17,305
21,136
Regeneration frequency =33 days
   45,000
  101,000
  180,000
  406,000
  553,000
  722,000
1,083,000
 31.4
 70.7
126
283
385
503
754
  268
  469
  603
  657
  978
1,635
2,291
Regeneration frequency =48 days

   45,000        31.4         268
  101,000        70.7         469
  180,000       126           603
  406,000       283           657
  553,000       385           978
  722,000       503         1,635
1,083,000       754         2,291

***  based upon
  590
1,273
2,224
2,452
2,452
2,452
2,452
                        590
                      1,273
                      2,224
                      2,452
                      2,452
                      2,452
                      2,452
  858
1,742
2,827
3,109
3,430
4,087
4,743
                      858
                    1,742
                    2,827
                    3,109
                    3,430
                    4,087
                    4,743
                                             596
                                             715
                                             954
                                           1,311
                                           1,669
                                           2,026
                                           2,742
                       596
                       596
                       834
                     1,192
                     1,430
                     1,669
                     2,146
 7,772
 7,772
 8,469
 8,469
 9,166
 9,166
10,613
                        7,316
                        7,316
                        8,013
                        8,013
                        8,710
                        8,710
                        9,916
754         2,291     2,452     4,743      2,146        9,916

labor costs of $13.40 per hour and energy costs of $.134 per kwh

                          A- 3
 9,226
10,229
12,250
12,889
14,265
15,279
18,098
            8,770
            9,654
           11,674
           12,314
           13,570
           14,466
           16,805

-------
CHEMICAL COST SUMMARY - CENTRAL TREATMENT - ACTIVATED ALUMINA
avg plant
flow rate
fcrpd)
11,900
473,000
sulfuric *
acid
r$/vr)
535
550
sodium *
hydroxide
r$/vr)
2,017
17,100
total
cost
f$/vr)
2,552
17,650
* see discussion in paragraph entitled MISCELLANEOUS NOTES REGARDING COST CALCULATIONS
                                          A- 4

-------
DISPOSAL COST SUMMARY - CENTRAL TREATMENT - ACTIVATED ALUMINA
avg plant
flow rate
  fqpdl

    670
  1,700
  3,300
  6,700
 16,700
 33,300
 66,700
167,000
333,000
667,000
avg sludge
flow rate
  (cfpd)

     20
     50
    100
    200
    500
  1,000
  2,000
  5,000
 10,000
 20,000
 total
 cost ***
 f$/vr)

    19
    38
    88
   175
   427
   855
 1,760
 4,300
 8,500
17,100
*** assumes a suspended solids concentration on the order of  2,000 mg/L
                                          A- 5

-------
CONSTRUCTION COST SUMMARY  - CENTRAL TREATMENT  - REVERSE OSMOSIS




                                         plant capacity  (gallons per day)




Cost Category               2,500     10,000    50,000     100,000    500,000    1,000,000








Manufactured equipment     25,517     37,710    87,487     154,611    571,684    1,102,892




Labor                         974     1,462     1,827      3,410      9,135      17,783




Electrical instrumentation  3,674     5,281    12-,284     21,468     52,693      71,291




Housing                    13,637     15,929    18,794     21,201     44,006      60,165






Subtotal                   43,802     60,382    120,392     200,690    677,518    1,252,131






Design contingencies        6,570     9,057    18,059     30,104    101,628     187,820






TOTAL  ***                 50,372     69,439    138,451     230,794    779,146    1,439,951






*** based on labor costs of $13.40 per hour
                                          A- 6

-------
OPERATION AND MAINTENANCE COST SUMMARY -CENTRAL TREATMENT- REVERSE OSMOSIS  (Low Pressure)
avg plant
flow rate
  (qpcn
                        bldnq
energy
($/yr)
process
                                                       maintenance
                                                         material
total
                            labor
                            ($/yr)
total
cost***
($/vr)
TDS concentration = 5,000 mg/L
    2,500
   10,000
   50,000
  100,000
  500,000
1,000,000
375
442
549
657
2,090
3,926
1,327
3,524
13,413
24,174
114,329
215,204
1,702
3,966
13,962
24,831
116,419
219,130
                           596
                         2,026
                         9,536
                        17,403
                        79,983
                       140,537
                             4,556
                             4,824
                             6,432
                             8,174
                            11,658
                            15,142
*** based upon labor costs of $13.40 per hour and energy cost of $.134 per kwh
  6,854
 10,816
 29,930
 50,408
208,060
374,809
                                          A- 7

-------
OPERATION AND MAINTENANCE COST SUMMARY -CENTRAL TREATMENT- REVERSE OSMOSIS  (High Pressure)
avg plant
flow rate
(crod)

TDS concentration =
2,500
10,000
50,000
100,000
500,000
1,000,000
TDS concentration =
2,500
10,000
50,000
100,000
500,000
1,000,000
TDS concentration =
2,500
10,000
50,000
100,000
500,000
1,000,000
bldnq

5,000 mg/L
375
442
549
657
2,090
3,926
8,000 mg/L
375
442
549
657
2,090
3,926
10,000 mg/L
375
442
549
657
2,090
3,926
energy
($/yr)
process


2,412
6,459
25,607
46,150
218,286
410,844

2,412
6,459
25,607
49,982
272,851
513,555

2,412
6,459
25,607
59,992
327,429
616,266
total


2,787
6,901
26,156
46,807
220,376
414,770

2,787
6,901
26,156
50,639
274,941
517,481

2,787
6,901
26,156
60,649
329,519
620,192
maintenance
material
r$/vr)


596
2,026
9,536
17,403
79,983
140,537

596
2,026
9,536
17,761
83,678
146,497

596
2,026
9,536
18,476
87,254
152,218
labor
($/yr)


4,556
4,824
6,432
8,174
11,658
15,142

4,556
4,824
6,432
8,442
12,596
16,348

4,556
4,824
6,432
9,112
13,668
17,554
total
cost***
($/vr)


7,939
13,751
42,124
72,384
312,017
570,379

7,939
13,751
42,124
76,842
371,215
680,326

7,939
13,751
42,124
88,237
430,441
789,964
***  based upon labor costs of $13.40 per hour and energy costs of $.134 per kwh



                                          A- 8

-------
CHEMICAL COST SUMMARY - CENTRAL TREATMENT - REVERSE OSMOSIS

avg plant          sodium            sulfuric         sodium           total
flow rate     hexametaphosphate        acid         hydroxide           cost
 (gpd)             ($/vr)	        f$/vr)          ($/vr)            ($/vr)
   2,500              145                134              97               376
  10,000              558                512             388            1,458
  50,000            2,232              2,037           1,514            5,783
 100,000            3,460              3,116           2,329            8,905
 500,000           14,954              13,579          10,093           38,626
                                          A- 9

-------
DISPOSAL COST SUMMARY - CENTRAL TREATMENT - REVERSE OSMOSIS
avg plant
flow rate
  (gpd)

    150
    390
    770
  1,540
  3,850
  7,700
 15,400
 38,500
 77,000
154,000
avg sludge
flow rate
  (gpd)

     20
     50
    100
    200
    500
  1,000
  2,000
  5,000
 10,000
 20,000
 total
 cost ***
 f$/vr)

    19
    38
    88
   175
   427
   855
 1,760
 4,300
 8,500
17,100
*** assumes suspended solids concentration on the order of 2,000 mg/L
                                          A-10

-------
CONSTRUCTION COST SUMMARY - CENTRAL TREATMENT - ELECTRODIALYSIS
plant capacity
Cost Category 1
Excavation and sitework 2
Manufactured equipment 19
Concrete
Labor
Electrical instrumentation 2
Housing 8
,500
,558
,484
352
853
,755
,939
8,000
3,654
45,378
586
1,827
4,936
12,377
30,000
4,263
103,577
1,055
2,071
9,414
20,628
(gallons per day)
100,000
5,725
161,902
1,524
3,167
11,824
25,785
300,000
6,090
349,572
2,696
7,064
22,271
36,787
1,000,000
11,327
1,229,975
5,274
24,725
67,158
48,132
Subtotal                  34,941   68,758   141,008     209,927     424,480     1,386,591






Design contingencies       5,241   10,314    21,151      31,489      63,672       207,989






TOTAL  ***                40,182   79,072   162,159     241,416     488,152     1,594,580






*** based upon labor costs of $13.40 per hour
                                          A-ll

-------
OPERATION AND MAINTENANCE COST SUMMARY - CENTRAL TREATMENT - ELECTRODIALYSIS
avg plant
flow rate
(crod)

TDS concentration =
1,500
8,000
30,000
100,000
300,000
1,000,000
TDS concentration =
1,500
8,000
30,000
100,000
300,000
1,000,000
TDS concentration =
1,500
8,000
30,000
100,000
300,000
1,000,000
bldncr

1,000 mg/L
268
389
791
1,072
1,997
6,553
2 , 000 mg/L
268
389
791
1,072
1,997
6,553
3,000 mg/L
268
389
791
1,072
1,997
6,553
energy
($/yr)
process


348
1,876
7,048
23,477
70,430
234,768

496
2,667
9,983
33,259
99,776
332,588

643
3,444
12,918
43,041
129,122
430,408
total


616
2,265
7,83Q
24,549
72,427
241,321

764
3,056
10,774
34,331
101,773
339,141

911
3,833
13,709
44,113
131,119
436,961
maintenance
material
f$/vr)


238
954
3,338
10,966
27,416
108,830

238
1,073
3,934
13,112
32,661
130,524

238
1,311
4,649
15,258
38,144
152,338
labor
($/yr)


3,618
4,958
6,164
7,370
8,576
14,740

4,020
5,494
6,834
8,174
9,380
16,080

4,422
6,030
7,504
8,978
10,318
17,688
total
cost***
f$/vr)


4,472
8,177
17,341
42,885
108,419
364,891

5,022
9,623
21,542
55,617
143,814
485,745

5,571
11,174
25,862
68,349
179,581
606,987
***  based upon labor costs of $13.40 per hour and energy costs of $.134 per kwh



                                          A-12

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DISPOSAL COST SUMMARY - CENTRAL TREATMENT - ELECTRODIALYSIS

avg plant    avg sludge    total
flow rate    flow rate     cost ***
  fapd)        (qpd)
    150           20          19
    390           50          38
    770          100          88
  1,540          200         175
  3,850          500         427
  7,700        1,000         855
 15,400        2,000       1,760
 38,500        5,000       4,300
 77,000       10,000       8,500
154,000       20,000      17,100


*** assumes suspended solids concentration on the order of 2,000 mg/L
                                          A-13

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CONSTRUCTION COST SUMMARY - CENTRAL TREATMENT - ALUM COAGULATION
average plant
Cost Category
Excavation and sitework
Manufactured equipment
Concrete
Labor - installation
Piping & valves
Electrical instrumentation
Housing
72,100
3,289
39,344
4,805
7,917
1,217
2,985
21,774
216,000
5,116
56,314
7,149
10,109
3,921
3,329
29,108
flow rate
432,000
6,577
73,157
10,079
11,693
5,949
3,559
35,984
(gallons per dav)
576,000
8,891
84,848
12,775
12,667
7,571
4,018
43,548
1,152,000
14,860
161,902
22,385
24,360
11,357
6,084
59,019
Subtotal                     81,331   115,046    146,998    174,318    299,967






Design contingencies         12,200    17,257     22,050     26,148     44,995






TOTAL  ***                   93,531   132,303    169,048    200,466    344,962






*** based upon labor costs of $13.40 per hour
                                          A-14

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OPERATION AND MAINTENANCE COST SUMMARY - CENTRAL TREATMENT - ALUM COAGULATION
settling surface
area
(square feet)

avg plant
flow rate
(cfpd) bldnq

energy
($/yr)
process

maintenance
material
total r$/vr)

labor
($/yr)

total
cost ***
f$/vr)
       70
      140
      250
      370
      740
                 72,000
                216,000
                432,000
                576,000
              1,152,000
  657
1,018
1,461
1,983
3,739
442
442
670
898
1,782
1,099
1,460
2,131
2,881
5,521
  298
  358
  447
  536
1,013
1,742
2,613
2,787
3,484
4,529
 3,139
 4,431
 5,365
 6,901
11,063
***
based upon labor costs of $13.40 per hour and energy costs of $.134 per kwh
                                           A-15

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CHEMICAL COST SUMMARY - CENTRAL TREATMENT - ALUM COAGULATION

avg plant             total
flow rate             cost  *
 (gpd)                ($/vr)
  72,000             15,091
 216,000             45,273


* see discussion in paragraph entitled MISCELLANEOUS NOTES REGARDING COST CALCULATIONS
                                          A-16

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DISPOSAL COST SUMMARY - CENTRAL TREATMENT - ALUM COAGULATION
avg plant
flow rate
  fqpdl

    150
    390
    770
  1,540
  3,850
  7,700
 15,400
 38,500
 77,000
154,000
avg sludge
flow rate
  fcrodl

     20
     50
    100
    200
    500
  1,000
  2,000
  5,000
 10,000
 20,000
 total
 cost ***
 ($/vr)

    19
    38
    88
   175
   427
   855
 1,760
 4,300
 8,500
17,100
*** assumes suspended solids concentration on the order of 2,000 mg/L
                                          A-17

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CONSTRUCTION COST SUMMARY - CENTRAL TREATMENT - LIME SOFTENING
plant capacity (gallons per day)
Cost Category
Single Stage
Excavation and sitework
Manufactured equipment

Concrete
Labor - installation
Piping & valves
Electrical instrumentation
Housing
Subtotal
Design contingencies
15,000
4,263
41,732

1,289
17,052
7,030
9,758
10,085
91,209
13,681
150,000
7,064
62,599
O
2,930
22,168
14,061
14,006
18,794
141,622
21,243
430,000
8,161
83,339

3,750
34,104
19,063
19,516
22,691
190,624
28,594
750,000
10,231
108,353

6,915
44,335
22,578
21,697
34,380
248,489
37,273
1,000,000
11,936
130,477

8,204
53,348
62,057
30,652
37,818
334,492
50,174
TOTAL  ***
104,890
162,865
219,218
285,762
384,666
*** based upon labor costs of $13.40 per hour
                                          A-18

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CONSTRUCTION COST SUMMARY - CENTRAL TREATMENT - LIME SOFTENING
plant capacity (gallons
Cost Category
Two Stage
Excavation and sitework
Manufactured equipment
Concrete
Labor - installation
Piping & valves
Electrical instrumentation
Housing
Subtotal
Design contingencies
15,000
7,064
67,250
2,110
28,501
14,061
17,015
17,878
153,969
23,095
150,000
11,327
100,937
4,922
37,027
28,257
24,682
29,796
236,948
35,542
430,000
13,520
134,499
6,446
56,881
38,126
34,210
35,984
319,666
47,950
per day)
750,000
17,052
174,849
11,720
73,933
44,616
37,884
50,424
410,478
61,572
1,000,000
19,975
210,548
13,830
88,914
124,114
53,841
55,008
566,230
84,935
TOTAL  ***
177,064
272,490
367,616
472,050
651,165
*** based upon labor costs of $13.40 per hour
                                          A-19

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OPERATION AND MAINTENANCE COST SUMMARY - CENTRAL TREATMENT - LIME SOFTENING
avg plant
flow rate
  (qpd)
         bldnq
energy
($/yr)
process
total
maintenance
  material
   ($/vr)
                                                         labor
                                                         ($/yr)
total
cost***
f$/vrl
Single Stage

   15,000
  150,000
  430,000
  750,000
1,000,000
           268
           549
           724
         1,313
         1,568
 1,018
 1,367
 2,090
 4,636
 5,199
1,286
1,916
2,814
5,949
6,767
   2,265
   3,457
   4,649
   5,841
   7,271
14,673
14,673
19,564
19,564
24,522
18,224
20,046
27,027
31,354
38,560
Two Stage
15,
150,
430,
750,
1,000,
000
000
000
000
000

1,
1,
2,
3,
523
099
434
613
136
1,
2,
3,
7,
7,
688
278
484
048
986
2,211
3,377
4,918
9,661
11,122
3,
5,
7,
9,
14,
814
722
629
655
662
19,
19,
24,
24,
29,
564
564
522
522
346
25,589
28,663
37,069
43,838
55,130
*** based upon
labor costs of $13.40 per hour1 and energy costs of $.134 per kwh
                                          A-20

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CHEMICAL COST SUMMARY - CENTRAL TREATMENT - LIME SOFTENING
avg plant
flow rate
(gpd)
Single stage
15,000
150,000
Two stage
15,000
150,000
lime

f$/vrl

195
1,950

330
3,300
soda ash

f$/vr)

0
0

390
3,900
carbon
dioxide
($/vr)

22
220

87
870
total
cost
f$/vr)

217
2,170

807
8,070
                                          A-21

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DISPOSAL COST SUMMARY - CENTRAL TREATMENT - LIME SOFTENING
avg plant
flow rate
  fqpd)

    150
    390
    770
  1,540
  3,850
  7,700
 15,400
 38,500
 77,000
154,000
avg sludge
flow rate
  fgpd)

     20
     50
    100
    200
    500
  1,000
  2,000
  5,000
 10,000
 20,000
 total
 cost ***
 ($/vr)

    19
    38
    88
   175
   427
   855
 1,760
 4,300
 8,500
17,100
*** assumes suspended solids concentration on the order of 2,000 mg/L
                                          A-22

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CONSTRUCTION COST SUMMARY - CENTRAL TREATMENT - NANOFILTRATION

                                   plant capacity (gallons per day)

                  7,000    40,000    63,000    500,000    1,000,000    2,000,000




   TOTAL         10,000    60,000    78,000    475,000*     750,000*   1,250,000
* per reference 89-8;  all other data derived from written material and telephone
  conversations with a nanofiltration researcher and his marketing representative
                                          A-23

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OPERATION & MAINTENANCE / CHEMICAL COST SUMMARY - CENTRAL TREATMENT - NANO FILTRATION

avg plant
flow rate
                         total cost ($/yr)
   40,000                       14,600    (per nanof iltration researcher/marketing rep)
  500,000                      120,450    (per reference 89-8)
1,000,000                      248,200    (per reference 89-8)
                                         A-24

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DISPOSAL COST SUMMARY - CENTRAL TREATMENT - NANOFILTRATION
avg plant
flow rate
  (qpd)

    150
    390
    770
  1,540
  3,850
  7,700
 15,400
 38,500
 77,000
154,000
avg sludge
flow rate
  (gpd)

     20
     50
    100
    200
    500
  1,000
  2,000
  5,000
 10,000
 20,000
 total
 cost ***
 ($/vr)

    19
    38
    88
   175
   427
   855
 1,760
 4,300
 8,500
17,100
*** assumes suspended solids concentration on the order of 2,000 mg/L
                                          A-25

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CONSTRUCTION COST SUMMARY - POU - ACTIVATED ALUMINA

                                   construction cost

cost category                             POU
activated alumina filter                  251
  canister

plastic meter box & 10 in                0-41
  PVC pipe collar

PVC piping to house                      0-27

faucet & fittings                          54

labor - installation                    49 - 146
subtotal                               354 - 519


contingency                             53 - 78


total                                  407 - 597
                                          A-26

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OPERATION AND MAINTENANCE COST SUMMARY - POU - ACTIVATED ALUMINA
labor
cost category ($/yr)
sampling/testing frequency
twice per year
4 times per year
6 times per year
media regeneration
twice per year
once per year
27
80
161
frequency
27
13
once every two years 7
repairs
low
average
high

13
27
40
materials
($/vr)

24
48
72

119
60
30

12
24
36
total cost
specific
condition
51
128
233

146
73
37

25
51
76
f$/vr) ***
mid-range
condition

128



73



51

                                    TOTAL FOR MID-RANGE CONDITION  252
*** based upon labor cost of $13.40 per hour



                                          A-27

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CONSTRUCTION COST SUMMARY - POU - REVERSE OSMOSIS

                                     construction cost

cost category                               POU
manufactured equipment                  323* - 415

labor - installation                     40* -  61


subtotal                                363* - 476


contingency                              54* -  71


total                                   417* - 547

* these figures were derived from updating costs associated with the San Ysidro,  NM
  experience;
  see discussion in paragraph entitled MISCELLANEOUS NOTES REGARDING COST CALCULATIONS
                                          A-28

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OPERATION AND MAINTENANCE COST SUMMARY - POU - REVERSE OSMOSIS

                                                          total cost ($/vr)  ***

                                      labor      materials      specific     mid-range
cost category                        ($/vr)         ($/yr)       condition     condition

sampling/testing frequency

 twice per year                        27            48            75
 4 times per year                      54            95           149           149
 6 times per year                      80           143           223

pre-filter and GAG contactor replacement frequency

 once per year                         13            24            37
 twice per year                        27            48            75            75

RO membrane replacement

 once per year                         13            89           102
 once every 2 years                     7            45            52            52
 once every 3 years                     4            30            34

repairs

 low                                   13            12            25
 average                               27            24            51            51
 high                                  40            36            76

                                         TOTAL FOR MID-RANGE CONDITION   112* - 327

* derived from San Ysidro, NM experience;
  see discussion in paragraph entitled MISCELLANEOUS NOTES REGARDING COST CALCULATIONS
  of this report

*** based upon labor costs of $13.40 per hour

                                          A-29

-------