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                            GUIDANCE MANUAL

                                    FOR

                          COMPLIANCE WITH THE

                FILTRATION AND  DISINFECTION REQUIREMENTS

                                    FOR

                          PUBLIC WATER SYSTEMS

                                   USING

                         SURFACE WATER SOURCES
                                MARCH 1991 EDITION
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                              SCIENCE AND TECHNOLOGY BRANCH

                              CRITERIA AND STANDARDS DIVISION

                                 OFFICE OF DRINKING WATER

                            U.S. ENVIRONMENTAL PROTECTION AGENCY

                                     WASHINGTON, D.C.

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                             GUIDANCE  MANUAL
                                   FOR
                           COMPLIANCE  WITH  THE
                FILTRATION AND DISINFECTION REQUIREMENTS
                                   FOR
                          PUBLIC WATER SYSTEMS
                                  USING
                          SURFACE WATER  SOURCES
                                   for
                      Science and Technlogy Branch
                     Criteria and  Standards  Division
                        Office of Drinking Water
                  U.S. Environmental Protection Agency
                            Washington, D.C.
                         Contract No.  68-01-6989
                                   by
Malcolm Pirnie,  Inc.                       HDR  Engineering,  Inc.
100 Eisenhower Drive                       5175 Hillsdale  Circle
Paramus, New Jersey 07653                  Eldorado  Hills,  CA   95630
                              October, 1990

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                         Acknowledgments


Preparation of this document involved important contributions from
many people  in  two consulting  engineering  firms,  several  private
consultants, and the United States Environmental Protection Agency
(USEPA).    Malcolm Pirnie,  Inc.,  with  technical  contributions
provided  by  HDR Engineering Inc., conducted the  day-to-day work
under contract with the USEPA.

Principal authors from Malcolm  Pirnie were David J. Hiltebrand and
Linda Averell Wancho.   Personnel from HDR  involved  in  this work
were Jerry  Troyan  and Perri P.  Garfinkel.  -Additional  personnel
from Malcolm Pirnie who contributed to either the technical content
or the preparation  of  the manual included:  John  E.  Dyksen, James K.
Schaefer, Scott L.  Phillips and Peter B.  Galant.

Private consultants who contributed to the document included:
Dr. Appiah Amirtharajah,  Georgia  Institute of Technology, Atlanta,
GA; Dr. Ovadia Lev, Hebrew University,  Jerusalem,  Israel;
Dr. Vincent Oliveri, formerly John Hopkins University, Baltimore,
MD; Dr.  Phillip C. Singer, University of North Carolina,  Chapel
Hill,  NC; Dr. Mark Wiesner, Rice University, Houston, TX.

Preparation of the document was overseen by Stig Regli,  the USEPA
project officer. Valuable technical  review and major contributions
to the  text  were  provided  by  Thomas Grubbs,   Office  of Drinking
Water,  USEPA, and  Leigh Woodruff, Region X,  USEPA.

Special thanks are given to the  following individuals working for
USEPA  whose  review  and  comment  on  numerous  drafts  greatly
contributed  to  the evolution  of this  document:   John  Davidson,
Office  of Policy,  Planning and Evaluation;    Edwin Geldreich,
Drinking  Water  Research  Division,   Office   of  Research  and
Development;  John  Hoff,  formerly with  Drinking  Water Research
Division, Office of Research and Development;   Walt Jakubo.wski,
Environmental Monitoring and Support Laboratory, Office of Research
and Development; Dr.  Gary Logsdon,  formerly with Drinking Water
Research  Division, Office of  Research  and   Development;  Kevin
Reilly, Region I; Margaret Silver, Office of General  Council; and
Jim Westrick, Technical Support Division, Office of Drinking Water.

Appreciation  is  also  expressed  to state public health  officials,
representatives of the drinking water industry, academicians, and
the American  public for  their  participation in submitting timely
and insightful comments without which this document would not have
been possible.
Some of the appendices have primary authors which  are  noted on the
corresponding cover pages.

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                            TABLE  OF  CONTENTS
 1.     INTRODUCTION                                                   1-1

 2.     GENERAL REQUIREMENTS                                           2-1
       2.1   Application                                              2-1
            2.1.1 Types of Water Supplies                            2-2
            2.1.2 Determination of Applicable Sources                2-3
       2.2   Treatment Requirements                                  2-13
       2.3   Operator Personnel Qualifications                       2-14

 3.     COMPLIANCE FOR SYSTEMS NOT FILTERING                           3-1
       3.1   Source Water Quality Criteria                            3-1
            3.1.1 Coliform Concentrations                            3-2
            3.1.2 Turbidity Levels                                   3-4
       3.2  Disinfection Criteria                                     3-6
            3.2.1 Inactivation Requirements                          3-6
            3.2.2 Determination of Overall Inactivation
                  for Residual Profile, Multiple
                  Disinfectants and Multiple Sources
                  and Multiple Sources                              3-19
            3.2.3 Demonstration of Maintaining a Residual           3-29
            3.2.4 Disinfection System Redundancy                    3-32
       3.3   Site-Specific Conditions                                3-34
            3.3.1 Watershed Control Program                         2-35
            3.3.2 On-site Inspection                                3-3"
            3.3.3 No Disease Outbreaks                              3-4C
            3.3.4 Monthly Coliforn, MCL                              3-41
            3.3.5Total Trihalomethane (TTHM) Regulations            3-42

4.    DESIGN AND OPERATING CRITERIA FOR FILTRATION AND
        DISINFECTION TECHNOLOGY                                      4-1
      4.1   Introduction                                             4-1
      4.2   Selection of Appropriate Filtration Technology           4-1
            4.2.1 General Descriptions                               4-2
            4.2.2 Capabilities                                       4-3
            4.2.3 Selection                                          4-8
      4.3   Available Filtration Technologies                        4-9
            4.3.1 Introduction                                       4-9
            4.3.2 General                                           4-10
            4.3.3 Conventional Treatment                            4-13
            4.3.4 Direct Filtration          •                       4-17
            4.3.5 Slow Sand Filtration                              4-18
            4.3.5 Diatomaceous Earth Filtration                     4-21
            4.3.7 Alternate Technologies                            4-22
            4.3.8 Nontreatment Alternatives                         4-24
      4.4   Disinfection                                            4-25
            4.4.1 General                                           4-25
            4.4.2 Recommended Removal/Inactivation                  4-25
            4.4.3 Total Trihalomethane  (TTHM) Regulations           4-29

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                      TABLE OF CONTENTS  (Continued)


                                                                    Page

5.    CRITERIA  FOR DETERMINING IF FILTRATION AND DISINFECTION
         ARE  SATISFACTORILY  PRACTICED                                 5-1
      5.1    Introduction                                             5-1
      5.2    Turbidity Monitoring Requirements                        5-1
             5.2.1 Sampling  Location                                  5-1
             5.2.2 Sampling  Frequency                                 5-2
             5.2.3 Additional Monitoring                              5-3
      5.3    Turbidity Performance Criteria                           5-3
             5.3.1 Conventional Treatment or
                  Direct Filtration                                  5-5
             5.3.2 Slow Sand Filtration                               5-7
             5.3.3 Diatomaceous Earth Filtration                      5-7
             5.3.4 Other Filtration Technologies                      5-8
      5.4    Disinfection Monitoring Requirements                     5-8
      5.5  Disinfection Performance Criteria                         5-9
             5.5.1 Minimum Performance Criteria Required
                  Under the SWTR                                     5-9
             5.5.2 Recommended Performance Criteria                  5-10
             5.5.3 Disinfection By-Product Considerations            5-12
             5.5.4 Recommended Disinfection System Redundancy        5-14
             5.5.5 Determination of Inactivation by
                  Disinfection                    '                  5-14
      5.6    Other Considerations                                    5-28

6.    REPORTING                                                      5-1
      5.1    Reporting Requirements for Public Water Systems
             Not Providing Filtration                                 5-1
      6.2    Reporting Requirements for Public Water Systems
             Using Filtration                                         5-3

7.    COMPLIANCE                                                     7-1
      7.1    Introduction                                             7-1
      7.2    Systems Using a Surface Water Source
             (Not Ground Water Under the Direct
             Influence of Surface Water)                              7-1
      7.3    Compliance Transition with Current NPDWR
             Turbidity Requirements                                   7-3
      7.4    Systems Using a Ground Water Source Under
             the Direct Influence of a Surface Water                  7-4
      7.5    Responses for Systems not Meeting -the SWTR Criteria      7-6
             7.5.1 Introduction                                       7-5
             7.5.2 Systems Not Filtering                              7-6
             7.5.3 Systems Currently Filtering                        7-8

B.    PUBLIC NOTIFICATION                                            8-1

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                      TABLE  OF  CONTENTS  fContlnued^

                             LIST  OF  FIGURES

Figure                                                         Following
 No.        Description                                           Page

2-1         Steps to Source Classification                           2-4

3-1         Determination of Inactivation for Multiple
            Disinfectant Application to a Surface Water
            Source                                                  3-22

3-2         Individually Disinfected Surface Sources Combined
            at a Single Point                                       3-25

3-3         Multiple Combination Points for Individually
            Disinfected Surface Sources                             3-25

4-1         Flow Sheet for  a Typical Conventional Water
            Treatment Plant                                         4-13

4-2         Flow Sheet for  Typical Softening Treatment Plants       4-14

4-3         Flow Sheet for  a Typical Direct Filtration Plant        4-17

4-4         Flow Sheet for  a Typical Direct Filtration Plant        4-17
            with Flocculation

                            LIST OF APPENDICES

Appendix    Description                                             Page

   A        Use of  Particulate Analysis  for Source  and Water
            Treatment Evaluation                                     A-l

   B        Institutional Control of Legionella                      B-l

   C        Determination Of Disinfectant  Contact Time               C-l

   D        Analytical Requirements  of  the SWTR  and a Survey
            of the  Current  Status of Residual  Disinfectant
            Measurement Methods  for  all  Chlorine Species  and  Ozone   D-l

   E        Inactivation  Achieved by Various  Disinfectants           E-l

   F        Basis  for CT  Values                                      F-l

   G        Protocol  for  Demonstrating  Effective Disinfection       G-l

   H        Sampling  Frequency for  Total Coliforms  in the
            Distribution  System                                      H-l

    I        Maintaining  Redundant Disinfection Capability            1-1

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                      TABLE  OF  CONTENTS  (Continued^
9.    EXEMPTIONS                                                     9-1
      9.1   Overview of Requirements                                 9-1
      9.2  Recommended Criteria                                      9-2
      9.3  Compelling Factors                                        9-3
      9.4  Evaluation of Alternate Water Supply Sources              9-7
      9.5  Protection of Public Health                               9-7
      9.6   Notification to EPA                                     9-11

                             LIST OF TABLES

Table                                                          Following
 No.        Description                                           Page

2-1         Survey Form for the Classification of Drinking
            Water Sources                                            2-7

4-1         Removal Capabilities of Filtration Processes             4-3

4-2         Generalized Capability of Filtration Systems to
            Accommodate Raw Water Quality Conditions                 4-8

6-1         Source Water Quality Conditions for Unfiltered
            Systems                                                  6-4

5-2         Long Term Source Water Quality Conditions for
            Unfiltered Systems                                       6-4

6-3         CT Determination for Unfiltered Systems -
            Monthly Report to Primacy Agency                         5-4

5-4         Disinfection Information for Unfiltered Systems -
            Montly Report to Primacy Agency                          5-4

6-5         Distribution System Disinfectant Residual Data for
            Unfiltered and Filtered Systems - Monthly Report to
            Primacy Agency                                           5-4

6-5         Monthly Report to Primacy Agency for Compliance
            Determination - Unfiltered Systems                       6-4

6-7         Daily Data Sheet for Filtered Systems                    6-4

5-8         Monthly Report to Primacy Agency for Compliance
            Deterimination-Filtered Systems                          5-4

7-1         Requirements for Unfiltered Systems                      7-3

7-2         Requirements for Filtered Systems                        7-3

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                      TABLE OF CONTENTS
                           LIST OF APPENDICES
"Spendix    Description                                             pjne
   J        Watershed Control Program                                j-1
   K        Sanitary Survey                                          K_l
   L        Small System Considerations                              L-l
   M        Protocol for Demonstration of Effective Treatment        M-l
   N        Protocols for  Point-of-Use Treatment Devices             N-l
   0        Guidelines to  Evaluate Ozone Disinfection                0-1

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                            1.  INTRODUCTION

      This Guidance  Manual  complements  the filtration and  disinfection
treatment  requirements  for  public water  systems  using  surface  water
sources  or ground water  under the  direct influence  of  surface  water
promulgated  in  40  CFR  Part  141,  Subpart  H.    In  this  manual,  these
requirements  are  referred  to  as   in  the  Surface  Water  Treatment  Rule
(SWTR).
      The purpose of this manual is to provide  guidance to  United States
Environmental Protection Agency  (USEPA) Regional Offices, Primacy Agencies
and affected  utilities  in the  implementation of  the SWTR,  and  to  help
assure  that  implementation  is consistent.  For  example,  the  SWTR  sets
treatment  requirements  which  apply  to  a  large  range  of  source  water
conditions.  The guidance manual suggests design,  operating  and perform-
ance criteria for  specific surface water quality conditions to provide the
optimum protection from microbiological  contaminants.  These recommenda-
tions are presented  as advisory  guidelines  only; unlike the  provisions of
the SWTR, these recommendations are not  mandatory  requirements,  In many
cases,  it  will   be  appropriate   to  tailor  requirements   to  specific
circumstances; the guidance  manual  is  designed to give the Primacy Agency
flexiDility in establishing  the most  appropriate  treatment  requirements
for the systems within  their jurisdiction.
      Throughout  this document,  the  term  "Primacy  Agency"  refers  to  a
State with primary enforcement  responsibility for public water systems or
"primacy," or to  mean EPA in the  case of  a State that has  not obtained
primacy.
      In  order to  facilitate  the use  of  this   manual,   it  has  been
structured to  follow the  framework of the SWTR as  closely  as  possible.
Brief descriptions of  the contents of  each  section of this manual  are
presented in the following paragraphs.

Section 2
      This  section  provides  guidance for  determining  whether  a  *ater
supply  source  is  subject  to the requirements of the  SWTR  including the
determination  of  whether  a  ground  water  source   is  under the  direct
                                   1-1

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influence of surface water,i.e.  at  risk  for the presence of Giardia cysts
or other large microorganisms.   The overall treatment requirements of the
SWTR are also presented, along with recommendations for the qualifications
of operator personnel.
Section 3
      For systems which are  subject  to  the requirements  of the  SWTR and
which do not currently  provide filtration, this section provides guidance
to the Primacy Agency for determining if a given system:
            Meets the source water quality criteria
            Meets the disinfection requirements including:
                  99.9 and 99.99 percent inactivation of Giardia cysts and
                  viruses and application of the CT (disinfectant residual
                  concentration x contact time) concept
                  Point of entry to distribution system requirements
                  Distribution system requirements
                  Provision for disinfection  system redundancy
            Maintains an adequate watershed control  program
            Meets the on-site inspection requirements
            Has not had an identified waterborne disease outbreak
            Complies with the requirements of the revised Total  Coliform
            Rule
            Complies with Total  Trihalomethane (TTHM) Rule

Section 4

      This section pertains  to  systems which  do not meet the requirements
to avoid filtration  outlined in  Section 3  and  therefore  are required to
install filtration.   Guidance is given for the selection of  an appropriate
filtration technology based  on  the  source water quality and the capabili-
ties of various technologies to achieve the required performance criteria.
In addition,  recommended  design  and  operating  criteria are provided for
different filtration technologies.
                                   1-2

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Section 5
      Section 5 presents guidance to the  Primacy  Agency  for  determining
compliance with the turbidity and disinfection performance requirements,
and  in  turn,  whether  filtration  and  disinfection  are  satisfactorily
practiced.  Recommendations are made for the level of disinfection to be
provided in order to meet the overall treatment requirements of the SWTR.
This section describes how  to evaluate the adequacy of disinfection using
CT or other methods.

Section 6
      Section 6 provides guidelines to the Primacy  Agency for establishing
the reporting  requirements  associated  with  the SWTR.  The requirements
include report content and frequency, and are applicable to both filtering
and nonfiltering systems.

Section 7
      This  section  provides an  overview of the  schedule  for  Primacy
Agencies and utilities to meet the requirements of  the SWTR.  Examples are
presented to provide guidance for corrective measures which can be taken
by systems which are not in  compliance with  the treatment requirements.
Section 8
      This section presents  guidance on public notification.   Included are
examples of  events  which would  require notification,  language  for the
notices and the methods of notification.

Section 9
      Section 9 provides guidance to  the  Primacy  Agency  for determining
whether  a  system  is  eligible  for  an  exemption.   The  criteria  for
eligibility for an exemption include:
            Compelling factors (economic or resource limitations)
            No available alternate source
            Protection of public health

This  section  also   provides  guidance  for  evaluating  the  financial
capabilities  of  a water system,  reviewing the availability of alternate
sources and suggests  interim measures for protecting public health.
                                   1-3

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Appendices
      The manual  also contains  appendices  which  provide more  detailed
guidance in specific areas.  These include:

Appendix A - EPA Consensus
Method for Giardia cyst Analysis
      Several procedures  are available for Giardia  cyst analysis in water.
In  1983  the USEPA  held  a conference  to establish  a  consensus  on  the
procedure to be used in the future.  This consensus method would promote
uniformity in  testing  and  provide a basis for future conparisons.   The
consensus method and the  background data  used to develop it are presented
in this appendix.

Appendix B - Institutional
Control of Legionella
      Filtration and/or disinfection provides protection from Legionel la.
However, it  does not assure  that  recontamination or regrowth  will  not
occur  in  the  hot  water  or  cooling  systems  of  buildings  within  the
distribution system.  This appendix provides guidance for monitoring and
treatment which can be used by  institutional systems  for the control of
Legionella.

Appendix C - Determination of Disinfectant
Contact, Time
      In many  cases,  the  determination  of  disinfectant  contact times
needed to evaluate the CT  of  a  water system will  necessitate the use of
tracer studies.   This appendix  provides guidance for  conducting these
studies.  In  some cases it  may not be practical  to  conduct  a tracer study.
For such cases guidance is given for estimating the detention time based
on the physical configuration of the system.
                                   1-4

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Appendix D - Analytical Requirements
of the SWTR and A Survey of the Current
Status of Residual Disinfectant
Measurement Methods for all Chlorine
Species and Ozone	
      This appendix includes a  listing  of the analytical methods required
under  the  SWTR.   An  executive  summary  of a  report  on the  analytical
methods  used  to  measure  the  residual  concentrations of  the  various
disinfectants is included.   The reliability and  limitations of each of the
methods are presented.

Appendix E - Inactivations Achieved
by the Various Disinfectants	
      This appendix presents the  log  inactivations  of  Giardia  cysts and
viruses which  are achieved at various CT levels by chlorine,  chlorine
dioxide,  chloramines and ozone.  Inactivations  of viruses  achieved by UV
absorbance are also included.

Appendix F - Basis for CT Values
      This appendix  provides the  background  and rationale  utilized in
developing the  CT values  for the various  disinfectants.   Included  is  a
paper by Clark and Regli,  1990, in  which  a  mathematical model was used in
the determination of CT values for free chlorine.

Appendix G - Protocol  for Demonstrating
Effective Disinfection	
      This appendix provides the recommended protocols for demonstrating
the effectiveness of  chloramines,  chlorine dioxide  and ozone as primary
disinfectants.

Appendix H - Sampling Frequency for
Total Colifonns in the Distribution System
      The sampling frequency required  by the revised Total Colifonn  Rule
54 FR 27544 (June 29,  1989) is presented in this appendix.
                                   1-5

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Appendix  I  - Maintaining
Redundant Disinfection Capability
      This  appendix details the conditions and equipment which should be
maintained  by  a  system  using  chlorine,  chlorine  dioxide,  ozone  or
chloramines  to  assure  that  compliance  with  the  SWTR  requirement  for
redundant disinfection is met.

Appendix J  - Watershed Control Program
      This  appendix provides  a  detailed  outline  of  a watershed program.
This program may be adjusted by the Primacy Agency to serve the specific
needs of a  particular water system.

Appendix K  - Sanitary Survey
      This  appendix  provides  guidance  for  conducting  a  comprehensive
sanitary survey of a supply source and its treatment and delivery to the
consumer.  Suggested elements of an annual on-site inspection are included
in Section  3.

Appendix L  - Small System Considerations
      This  appendix describes  difficulties  which may  be  faced  by  small
systems in  complying with the  SWTR along with guidelines for overcoming
these difficulties.

Appendix M  - Protocol  for the
Demonstration of Effective Treatment
      This  appendix  presents  pilot  study  protocols   to  evaluate  the
effectiveness  of  an  alternate  filtration  technology  in  meeting  the
performance requirements of  the  SWTR.    It presents  the  use  of particle
size  analysis   for  demonstrating  the  actual  removal   of Giardia  cyst
achieved  by a  treatment  train.    Guidance  for  conventional  and  direct
filtration  plants to  demonstrate  that  adequate filtration  is  being
maintained  at   effluent  turbidities  between  0.5 and  1  Nephelometnc
Turbidity Unit  (NTU)  is also included.
                                   1-6

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Appendix N - Protocol  for
Point-of-Use Treatment Devices
      In some limited  cases, it may be  appropriate to install point-of-use
(POD) or point-of-entry (POE)  treatment devices as  an  interim measure to
provide  protection  to  the public  health.    This   appendix provides  a
protocol for evaluating and determining the efficacy of POU/POE treatment
devices.

Appendix 0 - Guidelines to
Evaluate Ozone Disinfection
      The CT evaluation used for other disinfectants is inappropriate for
ozone.   This appendix presents alternative  methods for  evaluating  the
disinfection effectiveness of ozone systems.
                                   1-7

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                        2.  '-NFRM REQUIREMENTS
2. 1  ^DDl ication
     The SWTR pertains to all public water systems  wnich utilize a surface
Abater source or ground water source  under  the direct influence of surface
water.  The SWTR defines  a surface water as all waters which are open to
the  atmosphere  and subject to  surface  runoff.   Ground water  under  the
direct  influence of  surface water is  defined  as:   any water beneath  tne
surface of the ground with (i)  significant  occurrence of insects or other
macroorgani sms ,  algae, organic  debris, or large-diameter pathogens such as
Giardia lamblia, or (ii) significant and relatively rapid shifts in water
characteristics such as turbidity, temperature,  conductivity, or pH which
closely correlate to cl imatological  or surface water conditions.  Direct
influence must be determined for each individual source in accordance with
criteria established by the Primacy Agency.  The Primacy  Agency criteria
may provide for  documentation of well construction  and  geology, with field
evaluation, or site-specific measurements of water quality as explained in
Section 2.1.2.
     Saline water sources such as the ocean are not generally considered
to be subject to the requirements  of the SWTR because of the low survival
time of pathogens  in  a saline  environment (Geldreich,  1989).   Pathogens
generally can only survive a few hours in saline water and  any remaining
pathogens should be removed or  inactivated  during  desalination.  However,
-: -'s  JP  to  the Primacy  Agency's discretion  to determine  which systems
must meet  the-  SWTR requirements.   In cases  where  there  is  a  sewage
discharge  located  near the water intake,   it may  be  appropriate for the
?rimacy Agency to require the system to comply with the SWTR.
     The traditional concept that all water in subsurface aquifers is free
from pathogenic  organisms is  based  upon  soil  being  an effective filter
that  removes  microorganisms  and other  relatively  large   particles  by
straining  and  antagonistic  effects  (Bouwer,  1978).   In  most  cases
pathogenic bacteria  retained  in the  soil  find themselves  in  a hostile
environment,  are not able to multiply and eventually die.   However, some
jnderground sources of  drinking water may be subject to contamination by
pathogenic organisms from the direct influence of nearby surface waters.
     Only those subsurface sources which are at risk to  contamination from
Giardia cysts will  be  subject  to  the requirements of the  SWTR.  G
                                  2-1

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cysts generally  range in size from 7 to 12 urn.  Suosurface sources  /.men
:nay  De  at  ris* to contamination from bacteria and  enteric  viruses,  out
Anicn are not  at  risk from  Giardia  cysts  will  be  regulated  either  under
tne 7ota1  Coliform Rule or fortncoming disinfection treatment requirements
for  ground Caters.   EPA  intenas  to  promulgate disinfection  requirements
for ground water systems  in  conjunction with regulations for disinfection
by-products by 1992.
     2.1.1  Types of Water SUDD!ies
     Surface Waters
     Surface water  supplies  that  are often used as  sources  of  drinking
water include  two major  classifications,  running and  quiescent  waters.
Streams, rivers  and  brooks  are  examples  of running  water,  *hile lakes,
reservoirs,  imooundments  and ponds  are examples of quiescent waters.  The
exposure of  surface waters  to  the  atmosphere results  in   exposure  to
precipitation events, surface water  runoff  and  contamination with  micro
and macroorganisms resulting from activities in their surrounding areas.
These sources are subject to the requirements  of the SWTR.
     Systems with  rain  water catchments  not  subject to  surface runoff
;e.g. roof catchment  areas) are not  considered  vulnerable to contamination
from animal  populations  which carry protozoan  cysts  pathogenic to humans
and are  thus  not  subject  to  the  SWTR  requirements.  However,  such systems
snou:d at  least provide disinfection  to treat  for potential bacterial  and
;iral contamination coming from  bird populations.'
     Ground Caters under Direct  Infuence of Surface Water
     Ground  *ater sources  whicn  may be  subject  to  contamination  with
:athogemc organisms from surface waters  include,  sorings,  infiltration
gai'eries,   wells  or other  collectors  in subsurface  aquifers.    The
*oilowing  section presents a recommended procedure  for determining wnether
a  source  will  be  subject   to  the  requirements  of  the  SWTR.    These
determinations  are  to  be  made  for  each  individual  source.   If  the
determination will involve an evaluation of water quality,  eg. particulate
analysis,  it  is   important  that  these  analyses be  made  on  water  taken
           One  study  (Markwell  and  Shortridge,  1981) indicates  that  a
           cycle of waterborne transmission and maintenance of influenza
           virus  may exist  within  duck  communities,  and  that  it  is
           conceivable for virus transmission to occur in this manner to
           other susceptible animals, including humans.
                                   2
                                    -

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directly  from  tne source  sna not  on  :1ended *ater  or water  *-:in  :re
distribution system.
     2.1.2  Determination of  Applicable Sources
     The Primacy Agency has the responsibility for determining which -\ater
suoplies must  meet  the  requirements  of the  SWTR.   However,   it  ^s  the
responsibility of the water purveyors to provide th-3 Primacy Agency with
the information needed to make this  determination.  This section provides
guidance to the  Primacy  Agency  for  determining which  water supplies  are
surface waters  or ground  waters directly influenced by  a  surface water and
are  thereby  subject   to  the  requirements  of  the  SWTR.   Following  the
determination that the  source is subject to  the SWTR,  the requirements
enumerated in Sections 2.2 and 2.3 must be met.
     The Primacy Agency must develop a program for evaluating ground *ater
sources for direct influence  by December 30,  1990.  All  community ground
water systems must be  evaluated  by June  29,  1994, while  all non-community
systems must be  evaluated by June  29,  1999.  Primacy  Agencies  with an
approved Wellhead Protection  (WHP)  Program, may be able  to  use the  WHP
program's requirements which  include  delineation of  wellhead  protection
areas,   assessment of  sources  of  contamination  and  implementation  cf
management control measures.   These  same  requirements  can be -sea  -"or
meeting the requirements  of the watershed control  program for ground /.ate*-
^rder the direct  influence of a surface water.
     A multiple step aoproach  has been developed as the recommended r.etncd
of determining  whether a ground  water  source is under direct influence cf
a  surface  warter.   This approach  includes  the  review  of  information
garnered during  sanitary surveys.   As  defined by  the  USEPA,  a sanitary
s-rvey  is  an on-site  review  of  the water  source,  facilities,  equipment
operation  and  maintenance of a  public  water  system for  the  purpose of
evaluating the adequacy  of such source, facilities, equipment,  operation
and  maintenance   for  producing  and  distributing  safe  drinking  water.
Sanitary surveys  are  required under the Total Coliform Rule  and may be
reauired under the forthcoming disinfection  requirements for ground water
systems as a condition for obtaining a  variance or  for determining  the
level of disinfection  required.   Therefore,  it  is recommended that  the
determination of direct influence be correlated with the sanitary surveys
conducted under these other requirements.
                                   2-3

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A.  Source Evaluation Protocol
     As illustrated on Figure 2-1,  the determination  of  ^nether  a  source
-, s SuDject to tne requirements  of tne  SVnR may "ivc'ive one or more  of  tne
folI owing steos:
     1.    A review of the  records  of  the system's source(s)  to determine
           wnether the source  is  obviously  a surface water,  i.e.  pona,
           lake,  streams, etc.
     2.    If the source  is a well,  determination  of whether it is clearly
           a ground water source,  or  whether  T"urther  analysis is  needed
           to determine possible direct surface  water influence.
     3.    A complete  review of the system's files followed  by a  field
           sanitary survey.   Pertinent information to gather in  the file
           review and field survey  includes: source design and construc-
           tion;  evidence of  direct surface  water contamination;  water
           Quality analysis;  indications of  wateroorne disease outbreaks;
           operational procedures (i.e. pumping rates,  etc.); and  customer
           complaints regarding water  quality  or water related infectious
           i1Iness.
     4.    Conducting  particulate   analyses  and  other  water  quality
           sampling and analyses.

     Step 1.   Records Review
     A review of information pertaining to eacn  source should be carries
out to  -centify  those sources  which are obvious  surface  waters.   "These
Aould  include  ponds,  lakes,  streams,   rivers,  reservoirs,  etc.    If  tre
source is a surface water,  then tne S'wTR would apply,  and criteria  11 tre
ru^e wou;d reea to  De  applied to Getermine  if filtration  is necessary.  ~.~
the source  is  n-ot  an  obvious  surface water,  then further  analyses,  as
presepted in Steps 2,  3, or 4,  are needed to  determine  if the SWTR wi'l
appl>.  If tre source  is a  well  (vertical or horizontal),  go to Step 2.
If the source is a spring,  infiltration gallery,  or any other subsurface
source, proceed to Step 3 for  a more detailed analysis.

     Step 2.  Review of Well Sources
     while  most  well  sources  have historically  been  considered  to ce
ground water, recent  evidence suggests that some wells, especially shaTow
wells  constructed  near  surface waters,  may  be  directly  influenced oy
surface water.  One approach in determining whether a well is subject to
contamination by surface water  would  be to  evaluate the water quality :'
the well  by the criteria in Step 4.  However,  this process  is  rather  :-,-ne
                                   2-4

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consuming and labor intensive.   In an attempt to reduce the effort "eeaed

to evaluate well  sources,  a set of criteria has oeen Developed to identify
-veils in deep, /veil protected aquifers which  are not suDject to contamina-
tion from surface water.  While  these criteria are not  as  definitive  as
water quality analysis,  it  is  believed  that  they provide  a  reasonable

degree of accuracy,  and allow for a  relatively rapid  determination for a

large number of  well  sources in the  U.S.

     Wells with  perforations or  a well  screen less than or  equal  to  50

feet in  depth are considered to  be shallow wells,  and should be evaluated

for direct surface influence  according  to  steps  3 and/or  4.   For wells

greater  than 50  feet in depth,  State or  system files  should be reviewed

for the  criteria listed below:


     1.     The well  construction should  include:

                 A surface sanitary  seal using bentonite  clay,  concrete
                 or other acceptable material.

                 A well casing that  penetrates a  confining bed.

                 A well   casing  or  collector laterals that  are  only
                 perforated  or screened  below a confining  bed.

           The  importance  of evaluating  the hydrogeology of wells  or
           collectors,  even  those more than 200 feet from a  surface water,
           cannot be  overstated.   The   porosity  and transmissivity  of
           aquifer materials,  hydrologic gradients,  and   continuity  of
           confining  layers  above screens or perforations  may need to  be
           considered in detail for some  sources.   Porous aquifer material
           is more likely to  allow  surface water  to  directly influence
           groOrrrd water than finer grained materials.  In  addition, nigh
           well  pumping rates may alter the existing hydrologic gradient.
           Ground water flow direction may change  sucn that surface water
           is drawn into a collector, whereas under low pumping rates  it
           may not.  Evaluating pumping rate  effects and other hydrogeolo-
           gic information must be done  on a site specific basis.

           If  information  on   well  construction  or  hydrogeology  are
           incomplete or raise questions  regarding potential surface water
           influence,  a more detailed analysis in  steps  3 and 4 should  be
           considered.

     2.     The casing  or  nearest collector  lateral  should  be located  at
           least 200  feet from any surface water.

     3.     The water  quality records should indicate:
                                   2-5

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                 No record of total  coliform or -'seal coliform contamina-
                 tion in untreated samples collected over  tne past  tnree
                 years.

                 No  history  of turpidity  proplems  associated with  the
                 source.

                 No history of known or suspected outbreak of Giardia. or
                 other pathogenic  organism associated with surface  water
                 (e.g. Cryptosporidium), which has been attributed to that
                 source.

           If data is available for particulate matter in  the well  there
           should be:

                       No evidence of particulate matter  associated *itn
                       surface water.

           If data is  available for turbidity or temperature from the «ell
           and a nearby  surface water there should be:

                       No turbidity or temperature data  which correlates
                       to that of a nearby surface water.
     .N'ells that meet all  of the criteria listed above are not subject to

the  requirements  of  the  S'w'TR,  and  no additional evaluation  is  reeded.

.•.'ells  tnat  do  not  meet  all   the  requirements  listed   reouire  *urtre"

evaluation in  accordance with Steps 3 and/or 4 to determine whether cr not

they are directly influenced by surface water.


     Step 3.   On-site Inspection

     For  sources  other  than  a  *ell   source,  the State   or  system  files

should  5e  reviewed  for   the   source construction  and  -\ater  quality

conditions as  listed in Step 2.   Reviewing  historical records  in State cr
system  files  is  a valuable information  gathering tool   for  any  source.

However, the  results may be inconclusive.   A  sanitary survey  in the field

may be  helpful in establishing  a more definite determination of whether

the  water source  is  at  risk  to  pathogens  from direct  surface  *ater

influence.


     Information to obtain during an  on-site  inspection  include:


           Evidence that surface .%ater enters  the source through defects

           in the source such as  >ack of a surface seal  on wells, infi'-

                                   2-6

-------
           tration gallery 'atera's exposed to sj^face ,\ater, springs open
           to  tne  atmosphere,  surface  runoff  entering  a  spring  or  otner
           collector, etc.

           Distances to obvious surface water sources.

     If the  survey  indicates  that  the  well  is subject  to direct surface
water  influence,  the source  must  either be  reconstructed  as  explained
later  in  this  section  or  it must  be treated  in  accordance   with  the
requirements  for the  SwTR.    If the  survey does  not  show conclusive
evidence of direct surface water influence,  the analysis outlined in Step
4 should be conducted.
     The Washington  State Department of Social  and Health  Services  has
developed a form to guide  them and provide consistency in their evaluation
of sources  for surface water influence  (Notestine & Hudson,  1988).   Table
2-1 provides a copy of this form as a guide for evaluating sources.

     Step 4.   Paniculate Analysis and Other  Indicators
     a.  Surface *'ater Indicators
     Paniculate  analysis  is  intended  to identify  organisms whicn cn'y
occur in surface waters as opposed to ground waters,  and wnose presence ^n
a ground water /vould  clearly indicate that at least some surface water 135
:een mixed with  it.  The  EPA  Consensus Method in Appendix  A can be .sea
~or 3jardia cyst analysis.
     In 1986-Hoffbuhr  et. al.  listed  six parameters  identifiable  in  a
particulate analysis which were  believed to be valid  indicators of sjrt'ace
contain1, nar'on of ground water.  These were:  diatoms, rotifers,  coccicr, a,
plant debris,  insect parts, and  Giardia  cysts.   Later  work by  Notestine
and Hudson  (1988)  found  that  rnicrobiologists did not all  define  plant
debris  in the  same  way,  and  that deep wells  known  to  be free  of airect
surface water  influence  were  shown  by particulate analysis to contain
"plant  debris" but none of the other five indicators.  Their work suggests
that "plant  debris"  may  not  currently be a  useful tool  in determining
direct  surface water influence, but may be in the future when a stancara
definition of  "plant debris"  is developed.  Therefore,  it is recommended
that only the  presence of the other  five parameters; diatoms and certa-n
other  algae,  rotifers,  coccidia,  insect parts,  and Gia^dia. be used ;s
                                   2-7

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                               TABLE 2-1

      SURVEY FORM "OR THE CLASSIFICATION OF  DRINKING  dATER  SOURCES
General
      Utility Name (ID*)
 2.    Utility Person(s)  Contacted
 3.    Source Type (As snown on state inventory)

      	 Spring                   	 Horizontal  Well     	 Vertical
      	 Infiltration System      	 Shallow Well              Well

 4.    Source Name                             Year constructed
 5.    Is  this  source  used  seasonally or intermittently?  No 	  Yes	
      If  yes,  are water quality problems  the reason?   No 	  res	

 5.    Has there ever been a waterborne disease outbreak  associated with
      this  source?  Yes 	 No 	  If yes, explain 	
      Have  there been turbidity or bacteriological  MCL violations  witmn
      the last  five years associated with this  source?  No 	 res  	
      If  yes, describe  frequency,  cause,  remedial action (s) taKen  	
 3.    nave  there  been  consumer  complaints  within  the  past five  years
      associated with this source?  No 	 Yes  	  If yes,  discuss
      nature, frequency, remedial action taken	
 9.    Is  there any evidence of surface water intrusion (pH,  temperature,
      conductivity,  etc. changes) during the year?  Yes 	 No 	
      Ifyes, describe	
      If not,  submit supporting data.

10.    Sketch of source in plan view  (on an additional  sheet)
                                   -1-

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Sha11cw Wei 1s

 1.    Does the /veil  meet good sanitary practices regarding location,  con-
      struction,  seal  etc.  to prevent the entrance of  surface  water?
      Yes 	  No 	  If no, describe the deficiencies  	


 2.    What is the depth  of  the well?  	 (ft)
      Elevation of  top of  casing?      	 (ft msl)
      Elevation of  land  surface?       	 (ft msl)

 3.    Hydrogeology  (Attach  copy of well  log or summarize  it  on reverse)
      a.     Depth to static water level? (Feet) 	
      b.     Drawdown?  (Feet)
      c.     What  is  the depth  to  the  highest  screen  or  perforation?
            (Feet)  	
      d.     Are there  impervious  layers  above  the  mghest  screen  of
            perforation?
            Yes 	 No 	 Unknown 	
            If yes, please describe	

 4.    Is  there a permanent  or intermittent surface water within  200  feet
      of  the well?  Yes 	  No 	  If yes,  describe (type,  distance
      etc.)  and submit location  map
      rthat  is  the elvation  of normal  pool?
      Elevation of 100 year flood level?
      Elevation of Dottom of lake or  riverT

      Additional comments: 	
                                   -2-

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Sori
      a.    what is  the size of the  catcnment area (acres)? 	
      b.    Give a general  description of the  area  (terrain;  vegetation;
            soil etc.)
 2.    What is the  vertical  distance between the ground surface  and  the
      nearest point of entry to the spring collector(s) (feet)? 	
 3.    How rapidly  does rainfall  percolate  into the  ground around  the
      spring?

      	 Percolates readily;  seldom if ever any  runoff.
      	 Percolates readily but there is  some runoff in  heavy rain.
      	 Percolates slowly.  Most local  rainfall  ponds  or runs off.
          Other     	
 4.    Does  an impervious layer prevent direct percolation of surface water
      to the collector(s)?  Yes 	 No 	 Unknown  	

 5.    Is the  spring  properly  constructed  to prevent  entry  of  surface
      «ater?  Yes  	 No 	

 6.    Sediment
      a.    Is  the spring  box free of debris and  sediment?  Yes 	 No 	
      D.    when was it last cleaned  (Date)
            How often does it need to be cleaned? (month)
            How much sediment  accumulates between cleaning?
            inches)
      Additional comments:
                                   -3-

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 [nitration Systems
      ,vhat are the shortest distances  (vertical and horizontal  separating
      the collector from the nearest surface water?  (Feet)	
 2.   Does turbidity  of  the  source  vary 0.2 NTU or more throughout  the
      year?  Yes 	 No 	 Not measured 	
      If  yes,  describe  how  often  and  how  much   (pH,   temperature,
      conductivity, etc.)
 3.   Additional Comments
Survey Conducted By: 	Date:
Decision? Surface  Impacted  Source       Yes 	  No 	  If
further evaluation needed (paniculate analysis,  etc.)

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indicators of direct surface contamination.   In audition,   7 jm) organisms /vhich are clearly of surface water origin sucn
as  Diphilobothrium  are  present,  these snould  also  be  considered  as
iraicators of direct surface water influence.
     b.  Interpretation
     Since  standard methods  have  not  been  developed specifically  for
particulate analysis, there  has  not  been consistency  in  the way samples
have been collected and analyzed.  Differences in the degree of training
and experience of the microbiologists has added further to the difficulty
in comparing  results  from  sample to sample, and system to  system.   The
current limitations in sample collection and  analytical procedures must be
considered when interpreting the  results.  Until standardized methods are
developed,  the EPA Consensus Method included  in Appendix A is recommended
as the analytical  method  for particulate analysis.   The  following  is a
discussion of the  significance of  finding the six  indicators identified
above.
     Identification  of  a  Giardia  cyst  in  any  source  water  should  be
considered conclusive evidence of  direct surface water  influence.   The
seated presence  of diatoms  in source water  should be  considered  as
conclusive evidence  of  direct  surface water  influence.   However,  it  is
•-iportant that this determination be  based on  live diatoms,  and not e^ptv
5''ica  skeletons which  may only  indicate   the  historical   presence  of
s-rface water.
     Bluegreen,  green,  or  other  chloroplast  containing  a'igae  reduire
sjn light for"~their  metabolism  as do  diatoms.    For that  reason  tre-r
^eoeated presence in source water should also  be considered  as conclusive
ev-cence of direct surface water influence.
     Hoffbuhr  (1986)  indicates   that  rotifers  and  insect  parts  are
indicators of surface water.  Others have pointed out  though  that rotifers
do not  require sunlight, and not all rotifers require a food source sacn
as algae which originates  in  surface water.'  Their nutritional require-
ments may be satisfied by organic matter such  as bacteria, or decomposing
soil  organic  material,  not  necessarily associated with  surface  *ater.
More precise  identification  of rotifers, i.e. to  the species  level,  -s
necessary  to determine  the  specific  nutritional  requirements  of  tne
rotifer(s)  present.   Further  information on identifying  rotifer species
and on which  species  require  food  sources  originating in surface *ater
                                   2-8

-------
would  be  vaiuao'e,  but  is  not readily availaole at this time,   .-nthcut
knowledge of .\nich species is present, the finding  of  rotifers  indicates
that the source 's either a)  directly influenced by surface  water,  or  D)
it contains organic matter sufficient to support the growth  of  rotifers.
It could be conservatively  assumed  based on this evidence alone that such
a  source   is  directly  influenced  by  surface   water.    However,  it  is
recommended that  this determination  be  supported by other evidence,  eg.
the source  is near  a  surface  water,  turbidity  fluctuations  are  signifi-
cant,  etc.
     Insects or insect parts likewise may originate  in surface water, from
the soil,  or they may be airborne  in  uncovered  sources.   If insects  are
observed  in a particulate analysis  sample,  it  should  be  confirmed  if
possible that there is no other route by which  insects could contaminate
the source other than  surface water.  For example, if a spring is sampled,
and the cover is not well constructed, it  is  possible  that  insects  found
in a sample were airborne rather than waterborne.   Insects which spend a
portion of  their  lifecycle in water  are  the best   indicators  of  direct
surface water  influence,  for  example,  larvae   of  mayflies,  stoneflies,
damselflies, and dragonflies.  Terrestrial  insects should not be ruled out
as surface  water  indicators  though,   since their accidental  presence  ;n
surface water is common.
     riowell,  (1989) has  indicated  that some  insects may burrow  and  the
finding of  eggs  cr burrowing  larvae  (eg.  chironormds)  may not  be good
indicators  of direct surface water influence.  For  some insects this rcay
be true, but the-distance which  insects  burrow in subsurface sediments is
expected to be small,  and insect  larvae  are generally large in comparison
to G ^ a r_d i a  cysts.   Until  further research  suggests  otherwise,   it  -is
recommended that insects or insect  parts be considered strong evidence of
surface water influence if not direct evidence  in and of themselves.  The
strength of this evidence would be  increased  if  the source in question is
near a surface water,  and particulate analysis of the surface water found
similar insects.
     Coccidia are intracellular parasites  which  occur primarily  in verte-
brates, eg. animals  and  fish,  and  live  in  various tissues  and  organs
including   the  intestinal   tract  (eg.  Cryptosporidium).    Though  not
frequently  identified by normal  particulate analysis techniques, coccidia
are good  indicators  of direct  surface  water   contamination  since they
                                   2-9

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'-equire a vertebrate host or hosts and are generally  large in  size  (10  -

20 urn or greater).   Cryptosporidium  is  commonly  found  in  surface water,
but due to  its small  size (4-6 urn)  it is  not normally identified without

specific antibody staining techniques.
     Other macroorganisms (>7  urn)  which  are parasitic to animals and fish

may be found and  are  good indicators of surface water influence.  Examples

include, but are  not  limited  to,  helminths  (e.g.,  tape worm  cysts),

ascaris, and Diphyllobothrium.


     c. Sampling Method

     A suggested protocol for collecting samples is listed below.
           Sampl ing -Procedure

           Samples should be collected using the equipment  outlined  in the
           EPA Consensus Metnod included in Appendix A.

       -  , Location
           Samples should always  be  collected  as  close to the source as
           possible, and prior to  any treatment.  If samples must be taken
           after disinfection,  samples  should  be  noted and  analyzed as
           soon  as possible.

           Number
           A minimum of two samples  should be collected during the period
           the  source  is most  susceptible  to  surface  water  influence.
           Such critical periods will vary from system  to  system and will
           need  to be determined case by case.   For some systems,   it may
           be one or more days  following  a  significant rainfall  (eg. 2"
           in 24 hours).  For  other systems  it may  be a period of maximum
           flows and stream   turbidities  following spring snowmelt,  or
           during the summer  months  when  water  tables  are elevated as a
           resiTlt of irrigation.   In each case, particulate samples should
           be collected when the source in question is most effected.  A
           surrogate measure  such  as  source  turbidity  or  depth to water
           table may be useful in  making the  decision to monitor.   If
           there is  any ambiguity in the particulate  analysis results,
           additional  samples  should  be collected  when  there is  the
           greatest  likelihood  that the source will be contaminated by
           surface water.

           Volume
           Sample  volume should  be  between 500  and   1000 gallons,  and
           should be collected over a  4  to  8  hour time  period.   It is
           preferable to analyze a similar (+/- 10%) volume of water for
           all sources, preferably a  large volume, although this may not
           always  be possible  due  to elevated  turbidity  or sampling
           logistics.   The  volume  filtered  should be  recorded  for all
           samples.
                                  2-10

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     d. Other  Indicators
     A  number  of other  indicators  could  be used to provide  supportive
evidence  of surface  influence.   While  particulate  analysis probably
orcvides the most direct evidence  that pathogens from surface water could
be  migrating  into  a  ground  water source,  other parameters  such  as
turoidity, temperature,  pH and conductivity  could provide supportive,  but
less direct, evidence.
     Turbidity  fluctuations of  greater than 0.5  -  1 NTU  over  the course
of  a year may  be  indicative  of surface water influence.   Considerable
caution should be used when evaluating turbidity changes though, since the
turbidity could be caused by  very  small particles (< lum)  not originating
in a surface water or it could be that larger particles are being filtered
out and only the  very smallest  particles  migrate into  the  water  source.
Only ground water sources at risk to contamination from Giardia or other
large pathogens (> 7 urn) are subject to the SWTR requirements.
     Temperature fluctuations may also indicate surface water influence.
Fortunately  these  are easy to  obtain  and  if  there  is a  surface water
within   500  feet  of  the water  source,  measurements of  both  should  be
recorded  for comparison.   Large changes  in  surface  water  temperature
closely  followed by  similar  changes   in  source  temperature would  be
indicative  of  surface water  influence.   Also,  temperature  changes  (in
degrees F) of greater than 15 to 20% over the course of a year appear to
be a characteristic of some sources  influenced  by surface water (Randall,
1970).   Changes in  other chemical  parameters  such  as  pH,  conductivity,
haraness,etc.  e-ould  also be monitored.   Again,  these  would  not give a
direct  indication of whether pathogens originating in surface water  were
present, but could  indicate  whether the water chemistry was  or  was not
similar to  a nearby  surface  water and/or whether source water chemistry
changed in a similar pattern to surface  water  chemistry.  At this time no
numerical  guidelines  are available  to  differentiate  what  is  or  is not
similar, so these comparisons are more qualitative than quantitative.

B.  Seasonal Sources
     Some sources may only  be used for  part  of the  year,  for example
during the  summer months when water  usage is high.  These  sources should
not  be excluded  from  evaluation  and,  like  other  sources,  should  be
evaluated during  their  period(s)  of highest susceptibility.   Particular
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attention should  be  given  to  those  sources  which appear to  ba  directly
influenced by surface water during part of  the  year.   There  may  be  times
during which these subsurface  water sources are not influenced by surface
-vater and other times when they are part or all  surface water.  If that is
the case,  then it is  critical  that  careful  testing  be done prior  to,
during and at the end of the use of the source.   This should  be done over
several seasons  to account  for  seasonal  variation.   In practice,  it is
preferable to use sources which are less vulnerable to contamination  since
susceptible  sources   will   necessitate  ongoing  monitoring  and  close
attention to operation.

C.  Modification of Sources
     Sources directly influenced by surface water may  be altered in some
cases to eliminate the surface water contamination.  Primacy  Agencies may
elect to allow systems with such sources to modify the construction of the
source and/or the area  surrounding the source  in  an effort  to eliminate
surface water  contamination.    Since  this  could  be  expensive  and  take
considerable time  to evaluate for effectiveness, careful consideration
should be given to the decision  to modify a  source.   In deciding whether
source modification  is  appropriate, systems and  Primacy Agencies snoula
consider the following points:
           Is the cause of  the surface  water contamination known?  If the
           specific cause or point of  surface  water  contamination is not
           known,  it will   not  be possible  to  determine   an  effective
           control strategy.  Further, there may  be several reasons why
           the source  is susceptible to  direct  surface water influence.
           For~example, an  infiltration gallery may receive surface water
           because some of  its laterals are exposed in  the bed  of a nearby
           stream, and also because laterals  distant from the stream are
           shallow and are  affected by surface  runoff.   Simply modifying
           or eliminating one or  the other set  of laterals  in this case
           would not  entirely  eliminate surface water  influence.
           What is the likelihood  that  modification of the source will be
           effective?  Assuming  that the  source of contamination has been
           identified,  the  expected  effectiveness  of  control  measures
           should be  evaluated.   If  the cause  is relatively evident,  a
           crack in a well  casing  or an uncovered spring box  for example,
           then there  is a  high degree of confidence  that  an effective
           solution could be developed.  Should  the nature of the contami-
           nation  be more  diffuse, or widespread,  then  the merits of
           spending time and money to modify the source  should  be careful-
           ly considered.  In  the case of the  example  above, eliminating
           the use of the laterals under the stream will  solve part of the

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           problem.   However,  without  considerably  more  hydrogeologic
           information about the aquifer and the placement  of  the  otner
           laterals, it is  not  clear what, if any,  control  measures  would
           effectively eliminate  direct surface water influence in  those
           laterals distant from  the stream.

     If a  source  is identified as being directly influenced by  surface
water,  and it  is  decided  to attempt to modify  it, interim disinfection
practices which will ensure at  least 99.9% inactivation of Giardia should
be considered.  Methods and  levels of  disinfection which  can be  used  to
achieve such  removals  can  be  found  in S141.72 (a)  of  the SWTR and  in
Section 3.2 of this manual.
     A partial  listing  of types of modifications which could be undertaken
includes:
           Diverting surface runoff from springs by trenching,  etc.
           Redeveloping springs to capture them below a  confining layer.
           Covering open spring collectors.
           Reconstructing  wells  to  install  sanitary  seals,   and/or  to
           screen them in a confined (protected) aquifer.
           Repairing cracks or  breaks in any  type of source collector trat
           allows the entry of surface contaminants.
           Discontinue the use of  infiltration laterals  which  intercept
           surface water.

     An extended period of  monitoring  should  follow  reconstruction (eg,
through at least two years  or  critical  periods) to evaluate whether the
source  is still   directly   influenced  by  surface   water.    Preferably
particulate analysis would  be used to make such  evaluations,  but it  may te
helpful to use  simpler measures, such as temperature  and turbidity,  as
screening tools.  Longer term monitoring  at critical  times may  also be an
appropriate agreement between the system and the Primacy Agency  if there
is still  doubt about the long term effectiveness of the solution.
     If modification is not feasible,  another alternative  to avoid  having
to comply with the  SWTR may be to develop a new well  either deeper or at
a different location.
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2.2  Treatment  Requirements
     According  to  the SvJTR,  all  community and noncommunity  public water
systems  which use  a  surface water source  or a ground water  under  the
direct influence of a surface water must achieve a minimum of 99.9 percent
(3-log)  removal  and/or inactivation of Giardia cysts, and  a  minimum of
99.99 percent (4-log) removal and/or inactivation of viruses.   In the SWTR
and  this  manual,   "viruses"  means  viruses  of fecal  origin  which  are
infectious  to  humans  by  waterborne  transmission.    Filtration  plus
disinfection  or disinfection  alone may  be  utilized  to achieve  these
performance  levels, .depending  on  the source water  quality and  site
specific conditions.  The SWTR establishes these removal and/or inactiva-
tion  requirements  based  on  G1 ardia and  viruses  because this  level  of
treatment  will  also  provide protection from  heterotrophic plate count
(HPC) bacteria  and  Legionella' as required in the  SDWA amendments.
     Guidelines for meeting  the requirements  of the SWTR are provided in
the remainder of this manual  as outlined  in Section 1.  All  systems must
meet the operator qualifications presented  in  Section 2.3.

2.3  Operator Personnel Qualifications
     The SWTR requires that  all  systems  must  be  operated  by qualified
personnel.    It  is  recommended that  the Primacy Agency set  standards  for
operator qualifications,  in  accordance with the system type and size.   In
order to accomplish  this,  the Primacy  Agency should develop a method of
evaluating an operator's competence  in operating a water treatment system.
Primacy Agencies which  do not currently have  a certification program are
thereby encouraged to implement  such a program.  An  operator certification
program  provides   a  uniform base  for operator  qualifications   and  an
organized system for  evaluating these qualifications.
     It  is  recommended that  plant  operators have a  basic  knowledge of
science, mathematics and  chemistry involved  with water treatment  and
supply.  The minimum requirements  for at least one  key  staff member should
include an understanding  of:
           In  the SWTR  and  this manual  "Legionella"  means a  genus  of
           bacteria, some species of which have caused a type of pneumonia
           called Legionnaires Disease; the etiologic agent of most cases
           of  Legionnaires Disease  examined has been L_.. pneumophila.
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           The principles of ^ater treatment  and  distribution  and  their
           characteristics

           The uses of potable water  and variations in  its  demand

           The importance of water quality to public health

           The equipment, operation and maintenance  of  the distribution
           system

           The  treatment process  equipment  utilized,  its  operational
           parameters and maintenance

           The principles of each process  unit (including  the scientific
           basis and purpose of  the operation  and the  mechanical  compo-
           nents of the unit)

           Performance criteria such  as turbidity, total coliform,  fecal
           coliform, disinfectant residual,  pH, etc. to determine  opera-
           tional adjustments

           Common operating  problems encountered in the  system and actions
           to correct them

           The current National  Primary Drinking  Water Regulations,  the
           Secondary  Drinking  Water  Regulations  and  monitoring  and
           reporting requirements

       -  'Methods of sample collection and sample preservation

           Laboratory equipment and tests  used to analyze samples  (where
           appropriate)

           The use of laboratory results to analyze plant efficiency

           Record keeping

           Customer relations

           Budgeting and supervision  (where appropriate)


     Training in the areas  listed  above and others is  available through

the American  Water  Works Association  (AWWA)  training  course series for

*ater  supply  operations.   The  course series  includes a set of  four

training manuals and one reference book as follows:

           Introduction  to Water Sources and Transmission  (Volume 1)

           Introduction  to Water Treatment  (Volume 2)

           Introduction  to Water Distribution  (Volume 3)

           Introduction  to Water Quality Analyses  (Volume  4)

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           Reference Handbook:  Basic Science Concepts and ADD 1 '.canons
           Instructor Guide and Solutions Manual for Volumes  1,  2,  3  and
           4
     These manuals are available through the American Water Works Associa-
tion, 6666 West Quincy Avenue, Denver, Colorado 80235 USA, (303) 794-7711.
     The State of California also  offers a  series of training manuals for
water  treatment  plant  operators  prepared  by  the  California  State
University School of  Engineering in Sacramento.  The manuals include:
     1.    Water Supply System Operation.   (1 Volume)
     2.    Water Treatment Plant Operation.  (2 Volumes)
     These operator training manuals are available from California State
University, Sacramento, 6000  J Street, Sacramento,  California 95819, phone
(915) 454-6142.
     Completion of an established  training  and  certification program will
provide the means of  assuring that the operators have received training in
their  respective  area,  and  are   qualified  for  their  position.    The
education  and  experience  requirements  for  certification  should  be
commensurate with the size  and the complexity of the treatment system.  At
the  present  time,  some states  have instituted a  certification  program
wnile others have not.  Following  is a  summary  of the basic contents of a
certification program, which can serve  as a guide to the  Primacy Agency in
developing a complete program.
           Board of  examiners for  the  development  and  implementation of
           the program.
           Classification  of  treatment  facilities  by  grade according to
           the size and technology  of the facilities.
           Educational  and  experience  requirements for  operators of the
           various treatment facilities according  to grade.
           A written/oral  examination to determine  the knowledge, ability
           and judgement  of the applicants  with  certification obtained
           upon receiving  a passing grade.
           Renewal program for the license of certification,  including the
           requirement  of  additional   coursework  or   participation  in
           workshops.

     The  certification  program  should   provide   technica^y  qualified
personnel for the operation of the  plant.
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     The  extensive  responsibility which  is  placed  on  the  operating
personnel warrants the development of an outline of the  responsibilities
and  authority  of  the  personnel members  to  aid  them  in the  efficient
operation  of the  plant.    The major  responsibilities  which  should  be
delegated  in  the outline  of  responsibilities  include:    the  normal
day-to-day operations, preventive  maintenance,  field  engineering,  water
quality monitoring, troubleshooting, emergency response,  cross-connection
control, implementation of  improvements, budget formulation, response to
complaints and public/press  contact.  A reference which the Primacy Agency
may  utilize  in  developing  the outline  is  "Water Utility  Management
Practices" published by AWWA.
                                   2-17

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                 3.  CRITERIA FOR SYSTEMS NOT FILTERING

      The  provisions of  the  Surface  Water  Treatment  Rule  (SWTR)  require
that  filtration  must  be included in the treatment train  unless  certain
criteria  are  met.   These criteria are described in  this  chapter.   They
include:
      Source  Water Quality Conditions
      1.    Colifonn concentrations (total  or fecal).
      2.    Turbidity levels.
      Disinfection Criteria
      1.    Level of disinfection.
      2.    Point of entry disinfection.
      3.    Distribution system disinfection.
      4.    Disinfection redundancy or automatic shutoff.
      Site-Specific Criteria
      1.    Watershed control program.
      2.    On-site inspections.
      3.    No waterborne disease outbreaks.
      4.    Complies with the total coliform MCL.
      5.    Complies with  the  Total  Trihalomethane  (TTHM)  regulation.
            Currently  this  only  applies  to  systems serving  more  than
            10,000 people.

      The purpose of this section  is  to provide guidance  to the Primacy
Agency for determining compliance with these provisions.

3.1  Source Hater Quality Criteria
      The first step in determining if filtration is  required for a given
surface water supply is to determine whether the supply meets the source
water quality criteria as specified in the SWTR.  If the  supply does not
meet the source water quality criteria, changes  in operation to meet the
site-specific criteria may  improve  the water quality so that the source
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criteria will be met.  However,  if the Primacy Agency believes that the
source water quality criteria  and/or the site-specific criteria cannot  be
met, or that filtration is  appropriate regardless, the Primacy  Agency may
require the  installation of filtration without a complete evaluation  to
determine  whether  the system meets all  the  criteria required to  avoid
filtration.
      Sampling Location
      The SWTR requires that  source water samples be collected  at  a  loca-
tion just  prior to  the "point of disinfectant  application," i.e.,  where
the water  is  disinfected  and  no longer subject to surface runoff.  For
example, a system which has multiple reservoirs in  series,  where  each  of
the  reservoirs  has  previously  been  disinfected  and  receives  surface
runoff, must  take  the raw water sample(s)  just prior  to  the point  of
disinfection  or disinfection  sequences  used  for  calculating  the  CT
[disinfectant residual (mg/L) x contact time (min.)].  Disinfected  water
in reservoirs receiving surface  runoff cannot be counted toward CT  credit.
It is also not appropriate for systems to monitor the source water  after
the "point  of disinfectant application"  even  if disinfection from this
point is not used for  calculating CT credit.
      3.1.1   Coliform Concentrations:   The  SWTR states that, to  avoid
filtration,  a system  must demonstrate that  either  the fecal  coliform
concentration is less  than 20/100 ml fir the total coliform concentration
is less than  100/100  ml  in the  water  prior  to the  point of disinfectant
application  in  90  percent  of the samples taken  during  the  six previous
months.  Where  monitoring  for both  parameters has  been  or is  conducted,
the rule requires that only the  fecal coliform limit be met.  However, EPA
recommends that the analytical results for both total coliforms and fecal
colifomis  be  reported.   In addition,  if the turbidity of a surface water
source  is  greater  than  5  NTU  and  the surface source is blended with a
ground water source to reduce the turbidity,  EPA  recommends that  the high
turbidity  water prior to  blending meet  the  fecal  coliform source water
qua!ity criteria.
      Elevated coliform levels in surface water indicate  higher probabili-
ties  of fecal  contamination,  some  of  which could be protected from
exposure to disinfection by embodiment in particulate matter.   Blending of
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 the  surface water with ground water to reduce coliform levels may obscure
 the  indication of such possible effects.   Thus,  EPA  does  not  recommend
 blending  to reduce coliform levels in the source water.  Furthermore,  EPA
 does  not  recommend  blending  to reduce turbidity levels in  cases  where
 elevated  fecal  contamination  may be  masked.
       Ongoing monitoring is required  to ensure that these requirements are
 continually met.   The samples may  be analyzed  using either the multiple
 tube fermentation method or the membrane filter test  (MF) as described in
 the  16th  Edition of  Standard  Methodj.
       Sampling  Frequency
       Minimum  sampling frequencies are as follows:
            Population Served             Coliform Samples/Week
                  <500                             1
                  501-3,300                        2
                  3,301-10,000                     3
                  10,001-25,000                    4
                  >25,000                          5

       Grab samples  must  be taken  on different  days.   In  addition,  one
sample must be  taken  every day  during which the turbidity exceeds 1 NTU,
unless  the  Primacy  Agency  determines  that  the   system,  for logistical
reasons outside the  system's  control,  cannot  have  the  sample analyzed
within 30 hours of collection.  If taken,  these samples count towards the
weekly sampling requirement.   Also, under the Total Coliform Rule, systems
must take one  coliform sample in the distribution system near the first
service  connection  within  24  hours  after  a  source  water  turbidity
measurement exceeds 1 NTU.  This measurement must be  included  in the total
colifonn compliance  determination.   The  purpose of  these requirements is
to ensure that  the monitoring  occurs during worst case conditions.
       The initial evaluation  of the  source water  quality is  based on the
data from the  previous 6  months.  After the initial evaluation, systems
must continue  to conduct sampling each  month  to demonstrate compliance
with  the  source water quality  criteria  on an  ongoing  basis.   If the
criterion has  not been met, the system  must filter.
       Use of Historical Data  Base
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      Some systems may already monitor their source water for total  and/or
fecal coliform concentration.  The resulting historical  data base  may  be
sufficient  for  the Primacy Agency to make  the  initial  determination  of
whether  the  system  meets  the  source  water  quality  criteria.    The
historical data base  is considered sufficient for making this determina-
tion if:
            The raw water  sampling  location  is  upstream  of  the  point  of
            disinfectant application as previously defined.
            The monthly samples  represent  at  least  the  minimum  sampling
            frequency previously mentioned.
            The sampling period covers  at  least  the previous six months.

      3.1.2  Turbidity Levels;   To avoid filtration, the turbidity of the
water prior  to  disinfection cannot  exceed  5  NTU,  on an  ongoing  basis,
based on grab samples  collected every four hours  (or more frequently) that
the system is in operation.  A  system may substitute continuous turbidity
monitoring for grab sample monitoring  if  it validates such  measurements
for  accuracy with grab  sample  measurements  on  a  regular basis,  as
specified by the Primacy Agency.1  If a public water system uses contenti-
ons monitoring,  it must  use turbidity values recorded every four hours (or
some shorter  regular  time  interval) to  determine whether  it  meets trie
turbidity limit  for raw water.  A system occasionally may exceed the  5 NTU
limit  and  still  avoid filtration  as  long  as   (a)  the  Primacy  Agency
determines that each  event occurred  because of  unusual  or unpredictable
circumstances -and  (b)  as a result of this  event,  there have not been more
than two such events in the past twelve months the system  served water to
the public or more than  five such events in the past  120  months the system
      Validation  should be performed  at least  twice  a week  based  on the
      procedure  outlined  in  Part  214A in  the  16th  Edition  of Standard
      Methods.  Although the 17th Edition is-available, the 16th  Edition is
      that  which  is  referred  to  in  the rule.    Improper  installation of
      continuous  monitors  may  allow for air bubbles  to  enter the monitor
      resulting in false turbidity spikes.  To avoid air bubbles reaching the
      turbidimeter, the sample tap should be installed  below the center  line
      of  the  pipe and  an  air  release  valve may  be  included  on  the sample
      1 ine.
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served  water to  the public.   An  "event"  is  defined  as  a  series  of
consecutive  days  in which at  least  one  turbidity measurement each  day
exceeds 5 NTU.
      It is important to note that every event, i.e., exceedance of the 5
NTU limit,  regardless of whether the  system must filter as a consequence,
constitutes  a violation  of    a treatment technique  requirement.    For
example, if the turbidity exceeded 5  NTU in at least one measurement each
day for three consecutive days, this would constitute one  event  and one
treatment technique violation.   If this was the third event  in the past 12
months the system  served water  to the public, or  the  sixth  event in the
past  120 months  the system  had served water  to the public,  the system
would also be required  to install filtration.   In  all  cases,  the system
must inform the Primacy  Agency when the turbidity exceeds  5 NTU as soon as
possible,  but no later than the end  of the next business day.
      The Primacy Agency should evaluate additional  data from the utility
to determine the significance of the event with respect to the potential
health risk to the community  and determine whether  a boil water notice is
necessary.    The additional  data  may include  raw water  fecal  coliform
levels,  duration and magnitude of the turbidity excursion, nature of the
turbidity  (organic  or  inorganic),   disinfectant  residual  entering  tne
system during  the  excursion  and/or  coliform  levels  in  the distribution
system following the excursion.  Boil water notices are not required uncer
the SUTR,  they may be issued at the  discretion of the Primacy Agency.
      In order  to  determine  if the   periods with  turbidity greater than
5 NTU are unusual or unpredictable,  it is  recommended that  in addition to
the historical  turbidity data,  the water  purveyor should  collect and
provide to  the Primacy Agency current and historical information on flows,
reservoir water levels,  climatological conditions,  and any other  informa-
tion that the Primacy Agency  deems relevant.  The Primacy  Agency will then
evaluate this  information  to  determine  if  the  event  was  unusual  or
unpredictable.    Examples  of  unusual  or  unpredictable  events  include
hurricanes, floods and earthquakes.   High  turbidity events  may be avoided
by:
            Use of an alternate source which  is not a surface water  and
            does not have to meet the requirements  of the SWTR.

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            Use of an alternate source which is not a surface water and
            does not have to meet  the requirements  of  the  SWTR.
            Use of an alternate  source which is a surface water and which
            does meet the requirements  of the  SWTR.
            Utilization of stored  water to supply the community until the
            source water quality meets  the criteria.

3.2   Disinfection Criteria
      3.2.1  Inactivation Requirements
      To  avoid  filtration,  a system must demonstrate that  it maintains
disinfection conditions which inactivate 99.9 percent of Giardia cysts and
99.99 percent of viruses  every  day  of operation except  any  one  day  each
month.  If the disinfection conditions  provide less than these inactiva-
tions during more than  one day of the month,  the system is in violation  of
a treatment technique requirement.  If the system incurs such a violation
during any two months in the previous 12 months,  the system must install
filtration,  unless   one  of  the violations was  caused by  unusual  and
unpredictable circumstances as determined by the Primacy Agency.   Systems
with  three or more  violations  in  the previous  12 months  must install
filtration  regardless  of the  cause of  the violation.    To demonstrate
adequate  inactivations, the system must monitor and record the disinfec-
tant^)  used, disinfectant residual(s),  disinfectant contact time(s),  pH
(for chlorine),  and  water temperature,  and  use  these data to determine if
it is meeting the minimum total inactivation requirements  in the rule.
      A number of disinfectants  are  available,  including ozone, chlorine,
chlorine  dioxide  and chloramines.  The  SWTR  prescribes CT  [C,  residual
disinfectant  concentration  (mg/L)  x T,  contact  time  (min)]  levels for
these disinfectants  which will  achieve  different  levels of inactivation
under various conditions.  The disinfectant(s)  used to meet  the  inactiva-
tion requirements is  identified  as the primary  disinfectant throughout the
remainder  of this document.
      To determine compliance with the inactivation requirements, a system
must calculate the CT value(s) for its disinfection conditions  during peak
hourly flow  once  each  day that  it is delivering water to its customers.
For  the purpose of  calculating CT  value, T is the time (in minutes)  it

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takes  the  water,  during  peak hourly flow,  to move between the  point  of
disinfectant  application  and  a  point where,  C,  residual disinfectant
concentration  is  measured  prior   to  the  first  customer.     Residual
disinfectant concentration  is  the  concentration of  the  disinfectant  (in
mg/L)  at   a  point  before  or  at  the  first  customer.   Contact time  in
pipelines  must  be  calculated based on plug flow  (i.e., where  all  water
moves  homogeneously in time between two points)  by dividing the internal
volume of the pipeline by the peak hourly  flow  rate through that pipeline.
Contact time within mixing basins, settling  basins  storage reservoirs,  and
any other  tankage  must be  determined  by  tracer  studies  or an  equivalent
method as  determined by the Primacy Agency.  The contact time  determined
from  tracer  studies  to be  used  for calculating  CT  is  T10.   T10  is  the
detention time corresponding to the time for which  90  percent of the water
has been in contact with at  least the residual  concentration, C.  Guidance
for determining contact times for basins  is provided in Appendix C.
      The  first  customer  is the  point at which finished  water is first
consumed.   In  many cases this will  include the  treatment plant itself.
This  definition of  first  customer  pertaining  to   the  point  of  first
consumption assures that  the water  has  received the required disinfection
to provide protection from microorganisms for  all  consumers.  Peak hourly
flow should be considered as the  greatest volume of water passing through
the system during any one hour in a consecutive 24 hour period.  Thus, it
is not meant to be the absolute peak flow occurring at any instant during
the day.
      Systems  with  only  one  point  of  disinfectant  application  ^ay
determine  the total inactivation based on one point  of residual measure-
ment  prior  to  the  first   customer,  or  on  a profile  of the residual
concentration  after  the  point of  disinfectant  application.   Methods of
disinfection  measurement  are  presented  in  Appendix  D.   The residual
profile and the  total  inactivation  is  calculated  as  follows:
            Measure the disinfectant residual, C,  at  any number of  points
            within the treatment train.
             Determine  the  travel time, T,  between the point of  disinfec-
             tant  application and the  point where C  is measured for  the
             first  section.   For  subsequent measurements of "C," T  is  the
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            time it takes for water to move from the previous "C" measure-
            ment point to this point of measurement.
            Calculate CT for each point of residual  measurement (CT.   ).
            Determine the inactivation ratio  (CT.JiC/CT39 3)  for each sec-
            tion.-
            Sum the inactivation ratios for each section,  i.e.  C,T,/CT,9  9
            + C,T,/CT99 9  + CnTn/CT99 9 to determine the total inac'tivation
            ratio".

If the total inactivation ratio  (sum  (CTcm/CT99 9))  is equal to or greater
than  1.0,  the system  provides  greater  than 99.9 percent inactivation of
Giardia  cysts),  and the system meets  the disinfection  performance  re-
quirement.  Further explanation  of CT calculations is  presented in Section
3.2.2.
      Systems need only calculate one CT  (CTCJ|£)  each day,  for a point at
or prior to the  first customer; alternatively they have the  option of cal-
culating  numerous  CTs after the  point of disinfectant  application  but
prior to the first  customer to determine the inactivation ratio.   Profil-
ing the residual gives credit for the higher  residuals which exist after
the disinfectant is applied  but before  the first  customer.  Profiling the
residual may not be necessary  if  one CT  is calculated (CTcm), and this
exceeds the applicable  CT99 s.   In this case,  the  system is  meeting the
disinfection performance requirement.  For  systems with a very  low oxidant
demand in the water and long  contact  times, this  approach may be the most
practical to usjs.
      For systems with multiple points of  disinfectant application, such
as ozone followed by chlorine, or chlorine  applied at  two different  points
in  the  treatment  train, the  inactivation  ratio  of  each disinfectant
section  prior  to  the first  customer is  used  to   determine  the total
inactivation  ratio.   The  disinfectant   residual  of  each disinfection
      CT99 9 is the CT value  required to achieve 99.9 percent or 3-log Giardia
      cyst  inactivation  for the conditions of pH, temperature and residual
      concentration  for each section.  A section is the portion of the  system
      with  a  measurable  contact time between  two  points  of disinfection
      application or residual monitoring.
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section and the corresponding contact  time must be measured at  some  point
prior to the subsequent disinfection application point(s) to determine  the
inactivation ratio  for each  section,  and whether  the  total  inactivation
ratio  is  1.0 or more.   For  example,  if the first disinfection  section
provided an inactivation  ratio of 2/3 (or 99 percent inactivation)  and  the
second disinfection section provided an inactivation  ratio of  1/3 (or 90
percent inactivation), the total inactivation ratio would  equal  1.0 (2/3
+  1/3  =  1) indicating  that 99.9%  inactivation  was  provided   and  the
disinfection requirements are met.   Further explanation of  the  determina-
tion of total inactivation provided is contained  in Section 3.2.2.
      Maintaining Inactivation Level
      The SWTR establishes CTs for chlorine,  chlorine dioxide,  ozone  and
chloramines which will achieve 3-log inactivations  of Giardia cysts and at
least 4-log  inactivation  of  viruses.   Appendix E  presents CTs  for  these
and other  log inactivations.  A system must  demonstrate compliance with
the inactivation  requirements based on  conditions  occurring during peak
hourly flow.  Since a  system  generally  can only identify peak hourly flow
after it  has  occurred,  hourly residual measurements   during the  day  are
suggested.  If the sampling points  are  remote, or manpower  is limited and
collection of hourly grab samples is impractical, continuous monitors may
be  installed.   In cases  where  continuous monitors are impractical,  the
Primacy  Agency   may establish  an   acceptable  monitoring   program  on  a
case-by-case basis; where possible  this should be based on  historical flow
patterns.   Measurements  for  the hour  of  peak  flow can then  be  used in
calculating CT.   The pH  (for  systems using chlorine) and temperature must
be  determined  daily for  each disinfection  sequence   prior to  the  first
customer.
      Since  the  system's inactivation  is determined  during  peak  hourly
flow, the disinfectant dosage applied  to meet CT requirements may  not be
necessary during  lower flow  conditions.  Continuing to apply a disinfec-
tant  dosage based  on the peak  hourly flow  could   possibly  result in
increased   levels   of  disinfectant  by-products,  including  TTHMs   and
increased  costs.   Under  lower flow conditions,  a higher contact time is
available  and  a  lower  residual may  provide  the  CT   needed to  meet  the
inactivation requirements.  The system may therefore  choose to adjust  the
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disinfectant  dose with changes  in  flow.   The system should,  however,
maintain  a  disinfectant   residual  which  will  still  provide  a  3-log
inactivation  of Giardia  cysts  and  a 4-log  inactivation  of viruses  at
non-peak hourly flows.  The system should therefore evaluate the residual
needed  to  provide  the   required  inactivation  under  different  flow
conditions  and  set the dosage  accordingly.   The following  provides  an
example of maintaining the required inactivation.
      Example
      A 5 mgd non-filtering system disinfecting with free chlorine at one
point of application,  has  a contact time of 165 minutes  during a peak flow
of 5 MGD.   The  flow varies from 1 to  5  MGD.   The pH and  temperatures of
the water are 7 and 5  C, respectively.  At a residual of 0.9 mg/L, a CT of
148 mg/L-min  is required  to  meet the  disinfection  requirements.   The CT
for 0.9 mg/L residual  is determined by straight line interpolation between
0.8  mg/L  and  1.0 mg/L  residuals.    Under  lower  flow conditions,  the
available contact  time is  longer and  a  lower residual  would provide the
required disinfection.    Based  on  existing  contact  time  and  using  the
appropriate CT tables  (in  this case,  Table  E-2)  in Appendix E for a 3-log
Giardia cyst inactivation, the required  disinfection would be provided by
maintaining the following  chlorine residuals for the indicated flow:
                   Contact       CT (mg/L-min)        Free Chlorine
Flow fHGD^       Time  (min^        Required          Residual (mq/L^
   5               165                 148                0.9
   4               206                 145                0.7
   3               275                 143                0.5
   2          -    412                 139                0.4
   1               825                 139                0.2

      This  table   indicates  the variation of residuals  needed  for the
system to provide the  required inactivation.   For chlorine, the disinfec-
tant residual cannot be adjusted in  direct  proportion to the  flow because
the CT needed for  disinfection  is dependent  upon the residual.  Since it
is  not practical  to  continuously  adjust  the  residual   and,  since  a
disinfection  level  for  a  3-log   Giardia  cyst  inactivation must  be
maintained  under   all  flow  conditions,  it  is  suggested  that  the  flow
variation at the utility be divided into ranges and the residual needed at

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the higher flow rate of each  range  be maintained for all  flows within  the
range to ensure the required  disinfection.  The following flow ranges  and
residuals are suggested for the system:
                                           Free Chlorine
      Flow Range  (MGD)                    Residual  fmg/L)
            1 - 1.9                              0.4
            2 - 3.9                              0.6
            4-5                                0.9

By maintaining these residuals, the utility is ensuring  the provision of
the required disinfection while minimizing the disinfectant application,
which should result in lower disinfection by-products and costs.
      Although these residuals  will meet  the  inactivation  requirements,
maintaining a residual  in the distribution system must also be considered.
If no other  point  of disinfection exists  prior  to  the distribution system,
the residual  for  disinfection  must be maintained at a  level  which will
also provide a residual throughout  the distribution system.  The complete
range of flows occurring at  the plant should be evaluated for determining
the required residual.   A utility may establish the residual requirements
for as many flow  ranges as is practical.
      The CTs determined from the  daily  system data  should be compared to
the values  in the  table  for  the  pH  and  temperature  of the  water,  to
determine if  the required  CT  has been  achieved.   Only  the analytical
methods prescribed in the SWTR,  or  otherwise approved by  EPA, may be usea
for measuring disinfectant  residuals.  Methods prescribed  in  the SWTR are
listed in Append4x D.  The  Appendix also contains a paper which describes
monitoring methods for various  disinfectants  and conditions.
      The Primacy Agency should make periodic checks on its  utilities to
assure that they  are maintaining  adequate disinfection  at non-peak  flow
conditions.
      Meeting the Inactivation  Requirement Using Free Chlorine
      When  free  chlorine is  used  as  a  disinfectant, the efficiency of
inactivation  is influenced by the temperature  and pH of  the  water.  Thus,
the measurement of the temperature and pH for  the determination of  the CT
is required.  The SWTR provides the CT  requirements  for  free chlorine at

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 various  temperatures  and  pHs  which may occur in a source water.   These
 values  are  presented  in  Table E-l  through  Table  1-7  in  Appendix  E.   The
 basis for these values is discussed in Appendix F.   For free chlorine,  a
 3-log  inactivation  of Giardia cysts  will  provide  greater  than  a  4-log
 inactivation of viruses,  thus  meeting  the SWTR inactivation requirements.
      As indicated in Table E-2,  a raw water temperature of  5 C,  a  pH of
 7.0, and a residual chlorine concentration of 1.4 mg/L require a CT of 155
 mg/L-min to provide a 3-log inactivation of Giardia cysts.  Therefore, to
 meet the inactivation requirement under these conditions  with one point of
 residual measurement, a contact time of 111 minutes [(155 mg/L-min)/ (1.4
 mg/L)] prior to the first customer would be required.
      Meeting the Inactivation Requirement Using Chloramines
      Chloramines are a much weaker oxidant than free chlorine,  chlorine
 dioxide and ozone.  The CT values  for  Chloramines presented  in Table E-12
 are based on disinfection  studies using preformed Chloramines and in vitro
 excystation of Giardia muris  cysts (Rubin,  1988).   No safety factor was
 applied to the laboratory data on which the CT values  were based since EPA
 believes that chloramination,  conducted  in  the  field, is more effective
 than using preformed Chloramines.
      In the laboratory testing using preformed Chloramines, ammonia and
 chlorine were  reacted to  form Chloramines  before  the addition of the
microorganisms.  Under field conditions, chlorine is usually added first
 followed by  ammonia  addition  further downstream.  Also,  even  after the
 addition of ammonia,  some free chlorine residual  may  persist for a period
of time.  Therefore,  free chlorine is present for a period  of time prior
 to the formation of Chloramines.  Since this free chlorine contact time  is
not duplicated in the laboratory when  testing  with preformed  Chloramines,
 the CT values obtained by such tests may provide  conservative values when
 compared to those CTs  actually  obtained in the field with chlorine applied
 before ammonia.  Also, other  factors  such as mixing  in  the  field (versus
 no mixing in the laboratory) may contribute to disinfection effectiveness.
 For  these  reasons,   systems   using   Chloramines for  disinfection  may
 demonstrate  effective  disinfection in accordance with  the  procedure  in
 Appendix G  in lieu of meeting  the  CT  values  in Appendix  E.
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       If a system  uses chloramines and  is able to achieve the CT  values
for  99.9  percent   inactivation  of  Giardia  cysts,  it  is   not   always
appropriate  to assume  that  99.99 percent  or greater  inactivation  of
viruses was also achieved.  New data  indicate that Hepatitis A virus  is
more sensitive than Giardi? cysts to inactivation by preformed chloramines
(Sobsey,  1988).    The  CT  values required  to  achieve  99.99   percent
inactivation  of Hepatitis  A with  preformed chloramines  are lower  than
those needed to achieve 99.9 percent inactivation of Giardia cysts.  These
data  contrast with  other  data which  indicate  that  rotavirus  is  more
resistant  than Giardia  cysts  to  preformed chloramines  (Hoff,  1986).3
However, rotavirus  is  very  sensitive to inactivation by  free chlorine,
much more  so  than  Hepatitis A  (Hoff,  1986;4  Sobsey,  1988).   If  chlorine
is applied  prior  to ammonia,   the  short term presence of free  chlorine
would  be  expected  to  provide  at  least 99.99  percent  inactivation  of
rotavirus  prior to the  addition of ammonia  and subsequent  formation  of
chloramines.   Thus,  EPA believes  it  is appropriate  to use  Hepatitis A
data,  in lieu  of rotavirus data,  as  a  surrogate  for  defining minimum  CT
values  for  inactivation  of  viruses by  chloramines,  under the  condition
that chlorine  is added to the water prior to the addition  of ammonia.
      A system  which achieves  a 99.9  percent or  greater inactivation  of
Giardia cysts with  chloramines  can be considered  to  achieve at least 99.99
percent inactivation of  viruses,  provided that chlorine  is  added to the
water prior to the  addition  of  ammonia.  Table E-13 provides CT values for
achieving different levels of  virus inactivation.  However, if ammonia is
added  first,   the  CT  values   in  the  SWTR   for  achieving 99.9  percent
inactivation of Giardia cysts  cannot  be  considered adequate for achieving
99.99 percent  inactivation of  viruses.
      Under such cases of chloramine production,  the SWTR requires systems
to  demonstrate through  on-site  challenge  studies,  that  the  system  is
      CT values  in excess of  5,000 are  required for a 4-log inactivation of
      rotavirus  by preformed  chloramines but no minimum CT values have been
      determined.
      CT values  ranging from 0.025 to 2.2 achieve  99 percent inactivation of
      rotavirus  by free chlorine  at  pH  = 6  -10 and 4  - 5°C  (Hoff, 1986).
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achieving  at  least   a  4-log  inactivation  of  viruses.    Guidance  for
conducting  such  studies  is  given  in  Appendix G.   Once conditions  for
achieving  a 4-log  inactivation  of  viruses  has  been  established,  the
Primacy  Agency  should   require  systems  to  report  their  disinfection
operating conditions on an ongoing basis.  These conditions should verify
that  the  system  is operating at CT values  in  excess of that needed to
achieve a  4-log  virus inactivation  or 3-log Giardia cyst  inactivation,
whichever is higher.
      Meeting the Inactivation Requirement Using Chlorine Dioxide
      Under the SWTR,  the CT values for the inactivation of Giardia cysts
using chlorine dioxide  are independent  of pH.   Under the  SWTR  the only
parameter  affecting   the  CT  requirements  associated  with the  use  of
chlorine dioxide  is  temperature.   Table E-S in Appendix E  presents  the
chlorine dioxide CT values required for the inactivation of Giardia cysts
at different temperatures.  The basis  for these CT values is discussed in
Appendix F.   Systems which use  chlorine  dioxide are  not required  to
measure the pH of the disinfected water for  the calculation of  CT.  For
chlorine dioxide,  a  3-log inactivation  of Giardia cysts'will  generally
result in greater than a 4-log  virus inactivation, and assure meeting the
SWTR  inactivation  requirements.   However,  for chlorine  dioxide,  unlike
chlorine where this relationship always holds  true,  at  certain  tempera-
tures, the 4-log  virus CTs may be higher than the 3-log Giardia cyst CTs.
      The Primacy Agency may allow lower CT values  than those specified in
the  SWTR  for individual  systems  based on  information  provided  by  the
system.   Protocols for  demonstrating  effective  disinfection at  lower CT
values is provided in Appendix G.
      As indicated in  Tables  E-8 and E-9, the CT requirements for chlorine
dioxide are  substantially lower  than those  required for free chlorine.
However, chlorine dioxide is not as stable as free  chlorine or chloramines
in  a water  system and  may not be  capable  of  providing  the  required
disinfectant residual throughout the  distribution system.   In addition,
out of concern for toxicological effects,  EPA's current guideline is that
the sum of the  chlorine dioxide,  chlorate and chlorite residuals, be  less
than 1.0 mg/L at  all  consumer taps.  This guideline may  be lowered as more
health effects data become available.  These concerns further reduce the
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feasibility  of  using chlorine dioxide  as  a secondary disinfectant  for
distribution systems.  Therefore, the use of chlorine dioxide as a primary
disinfectant may  result  in  the need for the application of a  secondary
disinfectant, such as  chlorine or  chloramines, that will persist  in  the
distribution system and provide the required residual  protection.
      Meeting the Inactivation Requirement  Using  Ozone
      Another disinfectant  to inactivate  Giardia  cysts  and viruses  is
ozone.  As with  chlorine  dioxide, under  the SWTR,  the CT values for ozone
are independent of pH.  Tables E-10 and E-ll present  the  CT requirements
for ozone at different source water temperatures.  The basis  for the CT
values for ozone  is  given in  Appendix  F.   As  for free chlorine,  a 3-log
Giardia cyst inactivation with ozone will result  in greater than a 4-log
virus  inactivation.   Unlike chlorine,   for  cases where only a  1-log or
lower Giardia inactivation is needed with ozone,  the CT values for virus
inactivation may  be  higher than the CT  for Giardia.   The Primacy Agency
may allow  lower CT  values  for  individual  systems based on information
provided by the system that demonstrates that CT values lower than those
specified  in  the rule achieve  the same inactivation  efficiencies  (see
Appendix G).
      Ozone  is  extremely  reactive  and  dissipates quickly after applica-
tion.  Therefore,  a  residual5 can only be expected to persist a short time
      The  residual  must be  measured  using the  Indigo  Trisulfonate Method
      (Bader & Soigne,  1981) or automated methods  which  are calibrated in
      reference to the results obtained by the Indigo Trisulfonate method, on
      a  regular  basis  as  determined by  the  Primacy  Agency.    The Indigo
      Trisulfonate  method  is  included  in  the  17th  Edition   of  Standard
      Methods.  This method  is preferable to current standard  methods because
      of the selectivity of the  Indigo Trisulfonate indicaor  in  the presence
      of most interferences found in ozonated waters.  The ozone degrades an
      acidic  solution of  indigo trisulfonate  in   a  1:1  proportion.   The
      decrease in absorbance is  linear with  increasing ozone concentrations
      over  a wide  range.   Malonic  acid can  be added to block  interference
      from  chlorine.    Interference  from  permanganate,   produced  by  the
      ozonation of manganese, is corrected by running a  blank in which ozone
      is destroyed prior to addition of  the indigo  reagent.   The samples can
      be analyzed using a spectrophotometer at a 600 nm  wavelength  which can
      detect residuals as low as 2  ug/L or a  visual color comparison method
      which can measure down to 10 ug/L  ozone.  Although currently  availacie
      monitoring probes do  not use  the  Indigo Trisulfonate Method,  they can
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after  application.   In addition,  the  application  of ozone to water  is
dependent  on  mass   transfer.    For these  reasons,   the  method  of  CT
determination  used for the other disinfectants is impractical  for ozone.
The CT:alc must be determined for the ozone contactor alone.  The contactor
will have some portions where the ozone is applied and other portions  of
the contactor  where  ozone is no longer applied,  which are referred to  as
the reactive flow chambers.
      For many ozone contactors, the residual  in the contactor will  vary
in accordance  with the method and rate of application, the residual  will
be nonuniform  and is likely to be zero  in  a portion of the contactor.  As
previously  indicated,  the  CT  value is  based on  the  presence  of  a known
residual during a specific contact time.  Thus  disinfection credit is only
provided for the time when a residual is present.  Besides the nonuniform-
ity of the residual,  monitoring the residual will be difficult because of
the ozone's high reactivity and the closed design of the contactors.
      In addition to the difficulty in  determining  the ozone residual for
the CT calculation,   the contact time will vary between basins depending
on their flow  configuration.  Several types of devices are available for
adding  ozone  to water  including  porous  diffusers,  submerged turbines,
injector, packed  towers  and  static mixers.   Each  type  of device can  be
used in either single or multiple chamber contactors.  The flow through a
single chamber turbine  contactor will approximate a completely  mixed unit,
while  flow  through   a  single  chamber diffused contactor,  or  a multiple
chamber diffused contactor, will more closely represent plug  flow.  This
variation in flow in different contactors  makes the use of Tlo  inappropri-
ate for some contactors.
      The differences  between  ozone  contactors and  other disinfection
systems resulted in  the development of  several approaches  for  determining
the inactivation provided by ozone, including:
            Evaluation of C and T
            Segregated Flow Analysis (SFA)
            Continuously Stirred Tank Reactor (CSTR)
            Site Specific Evaluation
      be calibrated via this method.
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The  method  which is appropriate for  a  particular system will depend  on
system  configuration  and the required  level  of inactivation.   Another
significant difference  is  that  ozone may be  applied  to provide only  a
portion of  the  overall  3-log Giardia cyst and  4-log  virus  inactivation
with the remainder of the inactivation provided by another disinfectant.
Appendix  0  provides  details for  selecting  the  appropriate method  of
evaluation for specific conditions.
      The evaluation of  C  and T involves separate determination of  the
ozone  residual   concentration,  C,  and  the   contact  time,  T,   in  the
contactor.  C can  be determined for  individual chambers of  a contactor
based on the residual measured at several points throughout  the  chamber,
or at the exit of the chamber.  The  T value can be determined through a
tracer  study or  an  equivalent method as approved  by  the  Primacy Agency
with air or  oxygen applied during testing, using the same feed gas rate as
used during operation.  Appendix 0 provides  details for  the CT approach.
      SPA is based on the results  of  a  tracer study  used  in  conjunction
with the measured ozone  residual to determine the survival  of microorgan-
isms  exiting  the  contactor.   The  survival  corresponds  to a  certain
inactivation.   Guidelines for this approach  are included in Appendix 0.
      The CSTR approach  is  applicable for contactors which  have a high
degree  of  mixing.   Experience has  shown  that  for  contactors   such  as
turbine units,  the  ozone residual  is generally uniform  throughout  the
contactor.  The  ozone residual measured  at the exit  if  the contactor is
used  in  an  equation for CSTRs  to determine  the  inactivation provided.
Appendix 0 provides details for conducting CSTR analysis.
      Site specific evaluations may include:
            Measurement of an observable parameter to correlate with C
            Mathematical model for disinfection efficiency
            Microbial indicator studies for disinfection efficiency

to  more closely  determine   the  inactivation   provided  in a particular
system.  Appendix 0  provides details  for applying site  specific evalua-
tions.
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      Summary
      Many systems which do not provide filtration will have difficulty in
 providing  the  contact  time  necessary  to  satisfy  the  inactivation
 requirements prior  to the  first customer.   For  example,  a  system using
 free chlorine  at  a  water temperature  of  5  C,  a  pH  of 7.0  and  a chlorine
 residual of 1.4 mg/L would  require 111 minutes of contact time to meet the
 inactivation requirement.   Potential options for these systems include:
            Installation of storage facilities  to provide  the required
            contact time under maximum flow conditions.
            Use of  an alternate primary  disinfectant such as  ozone or
            chlorine dioxide which has CT values  lower than those required
            for free chlorine for the required inactivation.

      For  some   systems,   the  difficulty  in  obtaining  the  required
 inactivation may only be a  seasonal  problem.   A  system that has raw water
 temperatures which reach 20 C during the summer months at  a pH of 7.0, may
 have sufficient contact time to  meet the  CT of 56 mg/L-min (Table E-5) at
 a chlorine concentration of 1 mg/L.  However,  assuming the same  pH and
 chlorine concentration,  it  may  not  have  sufficient contact  time to meet
 the  CT  requirement  at  5  C,  149 mg/L-min (Table  E-2),  or  at  0.5 C,
 210 mg/L-min (Table E-l).   Under those conditions,  a system could choose
 to use  ozone  or  chlorine  dioxide   on a  seasonal basis,   since  they are
 stronger disinfectants requiring a  shorter contact time.
      As indicated  in  Table E-12,  the CT  values for chloramines  may be
 impractical to attain for most systems.  Systems which currently utilize
chloramines as a primary disinfectant may need to use either free chlor-
 ine,  chlorine  dioxide  or ozone in  order to  provide  the  required disin-
 fection.  However, systems  using chloramines as a primary disinfectant may
 chose  to   demonstrate  the  adequacy  of  the  disinfection.    Appendix G
 presents a method for making this demonstration.
      Meeting the Inactivation Requirement Using Alternate Disinfectants
      For  systems using  disinfectants other than chlorine, chloramines,
 chlorine dioxide, or ozone,  the.effectiveness of the disinfectant can be
 demonstrated using the protocol  contained in Appendix G.   The protocol in
 Appendix G.3  for  batch testing should be  followed for any disinfectant

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which can be prepared in an aqueous solution and will be stable throughout
the  testing.   For disinfectants  which  are not  stable, the  pilot  study
protocol outlined in Appendix G.4 should be followed.

      3.2.2  Determination of Overall  Inactivation for Residual Profile,
             Multiple Disinfectants and Multiple Sources	
      For systems which apply disinfectant(s) at more than one point, or
choose  to profile the  residual  from one point of application, the total
inactivation  is  the  sum of the  inactivation  ratios between  each  of the
points of disinfection or between each of the  residual monitoring points,
respectively.  The portion of the system with a measurable contact time
between two points of disinfection application or residual monitoring will
be referred to as a  section.  The calculated  CT  (CTcalc) for each section
is determined daily.
      The CT  needed  to fulfill  the disinfection requirements is CT99 9,
corresponding to a 3-log inactivation  of Giardia cysts and  greater than or
equal to  a 4-log  inactivation  of  viruses (except for  chloramines and
sometimes chlorine dioxide as explained in  Section 3.2.1).  The inactiva-
tion ratio for each section is represented by CTCIIC/CT99 9,  as  explained  in
Section 3.2.1,  and   indicates  the portion  of the  required  inactivation
provided by the  section.   The  sum  of the  inactivation ratios from each
section  can  be  used  to  determine the overall  level of  disinfection
provided.   Assuming  inactivation  is  a first order  reaction, the  inac-
tivation ratio corresponds to log and percent inactivations  as follows:
C_L3i./£!99 9     -       Log  Inactivation         Percent Inactivation
   0.17           =           0.5 log     =            68%
   0.33           =           1   log     =            90%
   0.50           »            1.5 log     =            96.8%
   0.67           =           2   log                 99%
   0.83           *           2.5 log     =            99.7%
   1.00           =           3    log     =            99.9%
   1.33           *            4   log                 99.99%
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      CT99 9 can be determined for  each section by referring to Tables  E-l
through E-13 in Appendix E, using the pH (when chlorine is the disinfec-
tant) and temperatures  of  the water  for the  respective sections.   These
tables present the log inactivation of Giardia cysts and viruses achieved
by CTs at various water temperatures  and pHs.
      Log inactivations are additive, so:
            0.5 Log + 1.0 Log » 1.5 Log or
            0.17CT99 , + 0.33CT999  = 0.5CT99 9

      If the sum  of the inactivation ratios  is  greater than  or equal to
one, the required 3-log inactivation  of Giardia cysts has been achieved.
An inactivation ratio of at least  1.0 is  needed to demonstrate compliance
with the Giardia cyst inactivation requirements for unfiltered systems.
      The total log inactivation can  be  determined by multiplying the sum
of the inactivation ratios  (sum (CTCilc/CT99 9)),  by  three.  The total  log
inactivation can be determined in  this way  because CT99 9 is equivalent to
a 3-log inactivation.  The total  percent  inactivation can be determined as
follows:
            y * Iflfi - Iflfl                       Equation    (1)
                101
      where:      y = % inactivation
                  x = log inactivation
      For example:
            x = 3.0 log inactivation
            y * 100 - 100     * 99.9 %  inactivation
                      10""

      As explained in Section 3.2.1,  the CTcllc determined  for each disin-
fection section is the  product  of the  disinfectant residual  in mg/L and
the detention  time in minutes through  the section  at peak hourly flow.
However,  for many water systems,  peak  hourly flow  will not necessarily
occur simultaneously in all sections.  The  extent to which  the  occurrence
of peak hourly  flow will  vary between  sections of the system  depends  on

                                  3-20

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the characteristics of an  individual system  including its size,  storage

capacity  within the  distribution  system,   the  number of  sources,  and
hydraulic capacities between different sections.   In order to  simplify the
determination of peak hourly flow for the system, it should be taken  as
peak hourly  flow  in the last section of the system  prior to the first
customer.

      The CT values  for all the sections  should be calculated  for the flow

and the  residuals  occurring during  the  hour of peak flow  in the last
section.   The  most  accurate way to  determine  the  flow  in a  particular

section is through the use of a flow meter.  However, some sections of the

system may not  have  a  flow meter.  The following guidelines can be used  to
determine the flow to be used in calculating CT:

            For sections which  do not have  meters,  the  flow should  be
            assumed  to be  the  higher of the two flows occurring  in the
            closest  upstream and downstream sections  with  meters.

            In  cases where  a  section  contains a pipeline and  a basin with
            the flow meter located prior to  the  basin, the  metered  flow
            does not  represent the  discharge  rate of the  basin.  The
            difference in  inlet and discharge  rates  from a  basin will
            impact the water  level in the basin.   As explained in Appendix
            C,  falling water levels will result in  lower  T10 values.

                  To  assure  that  the detention  time  of  a basin  is  not
                  overestimated, the discharge flow from a basin should be
                  used in lieu of the influent flow,  unless  the influent
                  flow is higher.

                  To estimate the discharge flow  from a basin the closest
                  flow meter downstream of the basin  should  be used.


      The  following  example  presents   the  determination of the  total

percent inactivation for multiple points of disinfection,  with variation

in flow between sections.

      Example
      A community of  6,000 people obtains its water  supply  from a lake

which  is  10 miles  from the  city  limits.   Two 0.2 MG storage tanks   are

located along  the  12-inch  transmission  line to  the  city.   The water is

disinfected  with  chlorine dioxide  at  the exit  from the lake  and with

chlorine  at  the discharge  from the first and second  storage tanks.   The


                                  3-21

-------
 average water demand of the community is 1 MGD with a peak hourly  demand
 of  approximately 2 MGD.   For the calculations  of the overall percent
 inactivation, the supply system is divided into three  sections as shown on
 Figure 3-1.
      Section 1  -  from  the  lake  to the  discharge  from the first  storage
      tank,
      Section 2  -  from  the  discharge  from  the  first  storage  tank  to  the
      discharge  from the second tank
      Section 3  -  from  the  discharge of the second  storage  tank  to  the
      first customer
The overall inactivation is computed daily for the peak hourly flow condi-
tions.  Sections  1  and  3  contain  flow meters  to monitor the water being
withdrawn from the lake and the water  being delivered to the distribution
system as  shown on  Figure 3-1.  On  the day  of this example calculation,
the peak hourly flow in section 3  was  2 MGD.   During this hour, water was
being withdrawn  from the lake  at a  rate of  1.5  mgd.   Considering  the
placement of flow meters, the flow of 2 mgd measured in section 3 should
be used for  calculating CT  for that  section.  Since  section  2 does  not
have  a  flow  meter,  the  meter  in  section 3  serves as a measure  of  the
discharge  from storage tank  2  and  should  be  the  flow  used   in  the
calculation of CT for section 2.  The  flow meter in section  1 records the
flow through  the transmission main which should be used  in the calculation
of CT for the  pipeline.  However,  this meter  does  not  represent  the
discharge  from-storage  tank  1.  Since the water is being  pumped to the
distribution system  at a higher rate than the flow entering storage tank
1, the flow of 2 mgd measured in section 3 should be used for calculating
the CT for storage tank 1.
      The  pH,  temperature and  disinfectant  residual  of the  water were
measured  at  the  end of each  section just  prior  to  the  next  point  of
disinfection and  the first  customer during the hour of  peak  flow.  The
water travels  through  the  12-inch transmission main at  177 ft/min  at
                                  3-22

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             STORAGE
             TANK 1
            STORAGE
             TANK 2
                                              111 CUSTO
                                              FM
   T
CHLORINE
 DIOXIDE
CHLORINE
CHLORINE
         SECTION
         SECTION
    SECTION I
             1
 FIGURE 3-1-DETERMINATION OF INACTIVATION FOR
            MULTIPLE DISINFECTANT APPLICATION
            TO  A SURFACE WATER SOURCE

-------
                                                                       .0
Section 1
15,840
1.5
2.0
89
116
205
chlorine
dioxide
0.1
5
8
Section 2
26,400
2.0
2.0
111
114
225
chlorine

0.2
5
8
Section 3.
10,560
2.0

45
0
45
chlorine

0.4
5
8
1.5 MGO.   The detention times of the  storage  tanks  were  read off  the  T

vs. Q plots generated from tracer studies conducted on the storage tanks
(see Appendix  C).    The data  for the  inactivation calculation  are  as
follows:
 length  of pipe (ft)
 flow (mgd)
   pipe
   tank
 contact time (min)
   pipe
   tank
   total
 disinfectant

 residual  (mg/L)
 temperature  (C)
 pH


 This  information is then  used in conjunction  with the CT99 9  values  in

 Appendix  E to  determine  the  (CTcalc/CT99 9)  in  each  section  as  follows:
 Section  1    - Chlorine  dioxide

 CT:a!. - 0.1 mg/L x 105 minutes =  20.5  mg/L-min

 From Table E-8 at a  temperature of 5 C and pH * 8,
 CT59 3  is 26 mg/L-min

CT:a  =/CT99 9 = 20.5 mq/L-min = 0.79
               26 mg/L-min


Section 2 -  Chlorine

CT,il: = 0.2 mg/L x 225 minutes *  45 mg/L-min

From Table E-2 at a  temperature of 5 C and pH * 8,
 CT99 9 is 198 mg/L-min
CT.J)C/CT99 9 * 45 mg/L-min » 0.23
                198 mg/L-min
  6    Q = 1.5 X  106 gal/dav X   1 ft3   X    dav   » 177 ft/rain
      A     (1 ft'   /4)       7.48 gal    1440  min
                                   3-23

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;
        Section 3 - Chlorine

        CT:j,: = 0-4 mg/L-min x 45 min = 18 mg/L-min

        From Table E-2 at a temperature of 5 C and pH * 8,
          CT99 9 is 198 mg/L-min

        CT-m/CTs9 9 =  18 mg/L-min = 0.09
                       198 mg/L-min


        The  sum of  CTCJlc/CT9g 9   is  equal  to  1.11,   which  is  greater  than  1,

        therefore,  the  system  meets  the  requirements of  providing  a  3-log

        inactivation of Giardia cysts.  The log inactivation  provided is:

              x = 3 x    CJ_CJIC *  3 x 1.11 « 3.33


        The percent inactivation can be determined using equation 1.
              y = 100 - IflQ = 100 - IfiO = 100 - 0.05  =  99.95% inactivation
                        IF33     2,138
        The system meets the requirement  of providing a 99.9 percent inactivation

        of Giardia cysts.

              The SWTR also requires that the public be provided with protection

        from Legionella as well as Giardia cysts and viruses.  Inactivation levels

        have not  been  set  for Legionella  because the required  inactivation  of

        Giardia cysts  will  provide protection from  Legionella.7   However,  this

        level of disinfection cannot  assure  that  all  Legionella will  be inacti-

        vated and that no recontamination or regrowth in recirculating hot water

        systems of buildings or cooling systems will occur.  Appendix B provides
              Kuchta et al.  (1983) reported a maximum CT requirement of 22.5 for a
              99 percent inactivation of Legionella  in  a  21  C tap water at a pH of
              7.6-8.0 when using free chlorine.  Using first order kinetics, a 99.9
              percent inactivation requires a CT of 33.8.  Table A-5 presents the CTs
              needed for  free  chlorine to  achieve  a 99.9 percent inactivation of
              Giardia cysts at 20 C.  This table indicates that the CT required for
              a  3-log  inactivation of  Giardia at  the temperature  and pH  of the
              Legionella test ranges from 67 to 108 depending on chlorine residual.
              These CT's are two to three times higher than that which is needed to
              achieve a 3 log inactivation of Legionella.
                                          3-24

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guidance  for  monitoring  and  treatment  to  control  Legione1 la  in  institu-
tional systems.
      The  above discussion  pertains  to  a system  with  one source  with
sequential disinfection.  Another system may blend more  than  one source,
and disinfect one or more of  the  sources independently prior to blending.
System conditions which may  exist include:
            All the sources  are combined at one point prior to supplying
            the community but one or more of the sources are  disinfected
            prior to being combined, as shown on Figure  3-2.
            Each  source  is   disinfected   individually  and  enters  the
            distribution  system  at  a different point,   as  shown  on  Fig-
            ure 3-3.

      For all  systems combining sources, the first step in determining the
CT should  be  to determine the CT.m provided  from the point  of blending
closest to the first customer using  the contact  time and residual at peak
hourly flow for that portion  of the distribution system.  This corresponds
to section D on Figure 3-2 and section E on Figure 3-3.  If the CTca:. for
section D or E provides the required inactivation, no additional CT credit
is needed and no further  evaluation  is required.  However, if the CT for
section D  or  E is not sufficient to achieve  the required inactivation,
then the inactivation ratio  (CT;alc)/(CT99 9) should be determined for each
section to  determine  the overall  inactivation provided  for each source.
The  total  inactivation  must be  greater  than or  equal  to one  for all
sources in order to  comply with the requirements for 3-log  inactivation of
Gi a rdi a cysts. "
      On Figure 3-2, sections A,  B,  C and D contain sampling points  a, b,
c and d,  respectively.   The  sum  of the inactivation  ratios for sections
A+D,  B+D  and  C+D  must  each be  greater  than or  equal to one for the
disinfection  requirements to be met.
      The  total inactivation  for  each source  on Figure  3-2 should be
determined  as  follows:
Source I
            Determine  CTcalc  for  sections A and  D based on the  residual
            measurements  at  sample points a  and d,  and the  travel  time
                                   3-25

-------
Source  II
Source III
             through each section under peak hourly flow conditions for the
             respective  section.

             Determine CT99 , for the pH and temperature  conditions in each
             section using  the tables  in Appendix E

             Calculate the  inactivation  ratios  (CTciic/CT99 9) for sections
             A  and  D.

             Calculate the  sum  of the inactivation  ratios  for sections A
             and D  to determine  the total  inactivation  for source I.

             If the sum of the inactivation ratios is greater than or equal
             to  1.0,  the system  has  provided  the required  3-log Giardia
             cyst inactivation.
            Determine  CT.J|C for section B based on the  residual measured
            at  sample point b  and  the travel  time  through the  section
            under peak hourly flow conditions.

            Determine  CT99 9 for  section  B  for the  pH and temperature
            conditions in the  section  using the  appropriate  tables  in
            Appendix  E.

            Calculate  the inactivation ratio (CTC|U/CT99 9)  for  section  B.

            Add the inactivation ratios for sections B and  D to determine
            the total  inactivation for source  II.

            If the sum of the inactivation ratios is greater than or equal
            to  1.0,  the system has  provided the required  3-log  Giardia
            cyst inactivation for the source.
            Determine  CT,4lc  for  section  C  based  on  the  residual  measured
            at  sample point c  and the  travel  time through the  section
            under peak hourly flow conditions.

            Determine  CT99 9 for  section  C  for the  pH and  temperature
            conditions in the  section using the  appropriate tables  in
            Appendix  E.

            Calculate  the inactivation ratio (CTC||C/CT99 9)  for section C.

            Add the inactivation ratios  for sections C and D to determine
            the total  inactivation for Source  III.
                                   3-26

-------
                                            1st CUSTOUEF
               FIGURE 3- 2 INDIVIDUALLY DISINFECTED
                          SURFACE SOURCES COMBINED
                          AT A SINGLE POINT
                                            1 at CUSTOMER I
OltlNPffCTANT
APPLICATION
COMBINATION POINT

SAMPLING POINTS
FIGURE 3-3  MULTIPLE COMBINATION PO
            FOR INDIVIDUALLY DISINFEC
            SURFACE SOURCES

-------
             If the sum of the inactivation ratios is greater than or equal
             to  1.0,  the system has provided the  required 3-log  Giardia
             cyst inactivation for the.source.
      The  determination  of the total  inactivation  for each  source  may

require more calculations for systems such as that on Figure 3-3 than on

Figure 3-2.  On  Figure 3-3 sections A, B, C, D,  and E contain sampling

points  a,  b,  c,  d,   and  e  respectively.    In  order  to minimize  the

calculations needed, the  determination  of  the total  inactivation should

begin with the source  closest to the first customer.

      The  total  inactivation for  each source on  Figure 3-3  should be

determined as follows:

Source III

            Determine  CT     for  sections  C and E based  on  the residual
            measurement at sample points c and e and the detention time in
            each  section  under   peak  hourly  flow   conditions  for  the
            respective section.

            Determine  CT99 , for the pH  and  temperature  conditions in each
            section using the tables in Appendix E.

            Calculate  the inactivation  ratios (CT,JIC/CT99  9)  for sections
            C and E.

            Calculate  the sum  of  the inactivation ratios for  sections C
            and E to determine the total inactivation  for source III.

            If the sum of the  inactivation ratios is greater  than  or equal
            to 1.0,  the  system has  provided  the  required 3-log Giardia
            cyst inactivation for source III.
Source II
            Determine CT  ,  for section D based on the residual measured
            at sample point d and the detention time through the  section
            under peak hourly flow conditions.

            Determine  CT,, ,  for  section  D  for  the pH  and temperature
            conditions  in  the section  using the  appropriate  tables  in
            Appendix E.

            Calculate the inactivation ratio (CTelle/CT99 9)  for  section  D.

            Add the inactivation ratios for sections D and  E  to determine
            the overall inactivation.

                                  3-27

-------
             If the sum of  the inactivation ratios is greater than or equal
             to  1.0,  the  system has provided the required 3-log  GJardia
             cyst inactivation for source  II, as well as source I since the
             water  from each  of  these  sources  are  combined  prior  to
             sections D and E.

             If the total  inactivation ratio for sections D and E is less
             than  1.0,  additional calculations  are needed.    Proceed  as
             follows for source II.

             Determine CT.3IC for section B based on  the residual measured
             at sample point b and the detention time  through the section
             under peak hourly flow conditions.

             Determine  CT99 9  for  section  B for  the  pH  and  temperature
             conditions  in the section  using  the appropriate  tables  in
             Appendix E.

             Calculate the inactivation ratio (CTcm/CT99 9) for section B.

             Add  the  inactivation  ratios  for  sections  B,  D  and  E  to
             determine the total  inactivation for source II.

             If the sum of  the inactivation ratios is greater than or equal
             to  1.0,  the  system has provided  the required 3-log Giardia
             cyst inactivation for the source.

Source I

      As  noted  in  the  determination of  the  inactivation  provided for

source II, if the sum of  the inactivation ratios for sections D and E is

greater than or equal to  1.0, the system has provided the required 3-log

Giardia  cyst inactivation.    However,   if  this sum is  less  than  1.0

additional calculations will  be needed to determine the overall inactiva-

tion provided "for source  I.  The calculations  are as follows:

Source I

             Determine CT,1IC for section A based  on the residual measured
             at sample point a and the detention time  in  the section under
             peak hourly flow conditions.

             Determine  CT99 9  for  section A  for the  pH  and temperature
             conditions  in the section  using  the appropriate tables in
             Appendix E.

             Calculate the inactivation ratio (CTcalc/CT99 g) for  section A.

             Add  the  inactivation  ratios  for  sections A,  D,  and  E to
             determine the total  inactivation for source  I.


                                   3-28

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             If the sum of the inactivation ratios  is greater than or equal
             to  1.0,  the  system has provided the required 3-1og Giardia
             cyst inactivation for the source.

      3.2.3  Demonstration of Maintaining a Residual
      The SWTR establishes  two  requirements concerning the maintenance of
a residual.   The first requirement  is  to  maintain a  minimum  residual  of
0.2 mg/L entering the distribution  system.  The  second  is to maintain a
detectable residual  throughout  the  distribution system.  The disinfectant
used to meet  these requirements is identified  as  the  secondary  disinfec-
tant throughout the  remainder  of this  document.   These  requirements  are
further explained in the following sections.
      Maintaining a Residual Entering the Distribution System
      To avoid filtration,  the disinfectant residual in water entering the
distribution  system cannot  be less than 0.2 mg/1 for more than four hours,
with one exception noted below.  Systems serving more than 3,300 persons
must monitor continuously.   If there  is a  failure in  the  continuous
monitoring equipment, the system may substitute grab  sampling every four
hours for up  to five working days  following the failure of the equipment.
Systems serving 3,300  or fewer people may monitor continuously or take
grab samples  at the frequencies prescribed below:
      System Size by Population           Samples/day*
                <500                           1
              50l-1,000                        2
             1,001-2,500                        3
             2,501-3,300                        4
     'Samples cannot be taken  at the same time.
      The  sampling  intervals  are  subject to Primacy  Agency  review  and
      approval.

If  at  any  time the  residual disinfectant concentration falls below  0.2
mg/1 in a system using grab sample monitoring, the system must continue to
take  a grab sample  every  four hours  until  the  residual  disinfectant
concentration is equal to  or greater than 0.2 mg/1.   For  all systems,  if
the  residual concentration is not  restored to  at least 0.2 mg/1 within
four hours after a value of less than 0.2 mg/1  is observed, the system is

                                   3-29

-------
in  violation of  a treatment  technique requirement,  and  must  install
filtration.  However,  if the Primacy Agency finds that the exceedance was
caused by  an  unusual  and unpredictable  circumstance,  the Primacy  Agency
may choose not to  require filtration.  EPA expects Primacy Agencies to use
this provision sparingly; it is intended  to encompass catastrophic events,
not  infrequent  large  storm events.   In addition, any  time  the residual
concentration falls below 0.2  mg/1,  the system must  notify  the Primacy
Agency.  Notification must occur as soon  as  possible,  but no later than
the end of the next business day.  The  system  also must notify the Primacy
Agency by the end  of the  next business  day whether or  not the residual was
restored within four hours.
      Failure of a monitoring or reporting requirement does not trigger a
requirement to filter although they are violations.
      Maintaining a Residual Within the System
      To avoid filtration, the disinfectant residual  in the distribution
system cannot be undetectable in more  than five percent of the samples in
a month,  for  any  two  consecutive months  that the system  serves water to
the public.   Systems  may measure HPC instead of disinfectant residual.
Sites  with HPC  concentrations of  less  than or  equal   to  500/ml  are
considered equivalent to sites with detectable residuals  for the purpose
of  determining  compliance.   Public water  systems  must  monitor  for the
presence of a disinfectant residual  (or  HPC levels) at the same frequency
and locations as total coliform measurements taken  pursuant to the Total
Colifonn Rule.  However,  if the Primacy  Agency determines, based on site-
specific  considerations,  that  a system  has no means  for  having a sample
transported and  analyzed for  HPC  by  a certified laboratory within the
requisite time and temperature conditions  (Method 907,  APHA, 1985), but
that the  system  is  providing  adequate  disinfection  in the  distribution
system, this requirements does not apply to that system.
      For systems which  use both  surface and ground water  sources, the
Primacy Agency may allow the system to take disinfectant residual or HPC
samples at points other  than the total colifonn sampling locations  if it
determines that such  points are more representative of  treated  (disin-
fected) water quality within the distribution system.
                                  3-30

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      Disinfectant  residual  can  be measured  as  total  chlorine,  free
chlorine, combined chlorine or  chlorine  dioxide  (or HPC level).  The SWTR
lists the approved  analytical  methods for  these analyses.   For  example,
several  test  methods  can be used  to  test  for  chlorine residual  in  the
water,  including  amperometric  titration,  DPD colorimetric,  DPD  ferrous
titrimetric method and iodometric method, as described  in the 16th Edition
of  Standard  Methods.8   Appendix  0  provides a review and  summary  of
available techniques to measure disinfectant residuals.
      If a system fails to  maintain a detectable disinfectant residual or
an HPC level of less.than or equal to 500/ml in more than 5 percent of the
samples during a month, for any two consecutive months the system serves
water to the  public, the system is in violation of a  treatment technique
requirement.  In addition,  this system must  install filtration unless the
Primacy Agency determines that the violation was not  due to a deficiency
in  treatment  of  the  source water (e.g.,   the  violation   was  due  to  a
deficiency in  the  distribution system, such  as cross-connection contamina-
tion or failure in the pipeline).
      The absence of a detectable disinfectant  residual in the distribu-
tion system may be due to a number of factors,  including:
            Insufficient chlorine applied at the treatment plant
            Interruption of chlorination
            A change in chlorine demand  in  either the  source water  or the
            distribution system
            Long  standing times and/or,  long transmission distances

      Available  options  to correct  the  problem of  low disinfectant
residuals in  distribution  systems  include:
            Routine flushing
      Also, portable  test  kits  are  available which can be  used  in  the  field
      to detect residual upon the approval  of the Primacy Agency.  These kits
      may  employ  titration or colorimetric test methods.  The  colorimetric
      kits employ either a visual detection of a residual  through the  use  of
      a color  wheel,  or the detection of the residual through  the use  of  a
      hand held spectrophotometer.
                                   3-31

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             Increasing disinfectant doses at the plant
             Cleaning of  the  pipes  (either mechanically  by  pigging  or  by
             the  addition  of  chemicals to dissolve the  deposits)  in  the
             distribution system to remove accumulated debris which may be
             exerting a disinfectant demand;
             Flushing and disinfection of the portions of the distribution
             system in which a residual is not maintained;  or
             Installation of satellite disinfection feed facilities within
             the distribution system.

For  systems  unable  to  maintain  a  residual,  the  Primacy  Agency  may
determine that it is  not feasible for the system to monitor HPC and judge
that disinfection is adequate based on site-specific conditions.
      Additional information on  maintaining a  residual  in  the  system is
available  in  the  AWWA  Manual  of  Water  Supply  Practices  and  Water
Chlorination Principles and Practices.
      3.2.4  Disinfection System Redundancy
      Another  requirement   for   unfiltered   water   supply  systems   is
disinfection facility redundancy.  A system providing disinfection  as the
only treatment  is  required  to  assure  that  the  water  delivered  to  the
distribution system is continuously  disinfected.  The  SWTR requires either
redundant  disinfection   equipment   with  auxiliary  power   and  automatic
start-up and alarm; or an  automatic shutoff  of delivery of water to the
distribution system when the disinfectant residual level drops below 0.2
mg/L.    In   order  to fulfill  the  requirement  of   providing  redundant
disinfection facilities, the following system  is recommended:
             All components have  backup units with capacities equal to or
             greater than the largest  unit on-line.
             A minimum of  two storage units  of disinfectant which  can be
             used alternately • e.g.,  two cylinders  of chlorine gas, two
             tanks of hypochlorite solution
             Where the disinfectant  is generated on-site,  such as  ozone,
             backup units with a capacity equal to or  greater  than  that of
             the largest unit on-line.
             Automatic switchover equipment  to change  the  feed from one
             storage unit to the other before the first  empties  or  becomes
             inoperable
                                  3-32

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            Feed  systems  with  backup units with capacities equal  to  or
            greater than the largest unit on-line.
            An alternate power  supply such as a standby generator with the
            capability  of  running all  the  electrical  equipment at  the
            disinfection  station.   The generator should be on-site  and
            functional with the capability  of  automatic start-up on  power
            failure
      Systems providing disinfection may have several different configura-
tions for  type  and  location  of disinfectant application.   The following
guidelines  are provided  to assist  Primacy Agencies  and utilities  in
determining the need for redundancy.  Possible disinfection configurations
include:
            one disinfectant used for primary and secondary disinfection
              -  one point of  application
              -  multiple points of application
            two different  disinfectants used for  primary and secondary
            disinfection

      In many  cases one disinfectant will  be  used to  fulfill  both the
total inactivation  and residual requirements.    One  or more  application
points may be used  to accomplish this.  When one application point  is used
to meet  both the  primary  and secondary  disinfection  requirements, the
system is  required  to  include  redundant disinfection facilities.
      When  multiple  points  of  application  are  used,  redundancy  is
recommended fOF-the disinfection facilities  at each point of  application
which  is   essential  to meet  the  total  inactivation requirements.   In
addition,  to assure the maintenance of a residual entering and throughout
the distribution system, either:
            the last point of application prior to the distribution system
            should  have redundancy, or
            the  point   of  application  immediately  prior to  this  point
            should  have redundancy and  sufficient  capacity   to assure  a
            residual entering  the distribution  system.

      Systems may also use two  different disinfectants, one to fulfill  the
inactivation  requirements and the second  to  maintain a residual.  An
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example of this would include a system using ozone as a primary disinfec-

tant and chloramines as a secondary disinfectant.   EPA recommends that:
            the  disinfection facilities at  each  point  of  disinfectant
            application in the primary system essential in providing the
            overall  inactivation requirements include redundancy, and

            the  secondary disinfection  facilities  include  redundancy,
            unless  the  disinfectant  used  for primary  disinfection  can
            provide  a residual  for  the distribution  system  as well.   If
            the primary disinfectant can be used for residual maintenance,
            the  last point  of  primary disinfectant  application should
            include  redundancy  and  sufficient   capacity  to  assure  a
            residual entering the distribution system.


      Appendix I contains more specific information to  assist the Primacy

Agency in establishing requirements for providing redundant disinfection

facilities.
      Providing automatic shutoff of water delivery  requires approval by

the Primacy Agency.   The  Primacy Agency must determine that this action

will not result in an unreasonable  risk to health or interfere with fire

protection.   This  determination should  include  the  evaluation  of the

system configuration to protect against negative pressures in  the system,

and providing  for  high  demand periods including fire  flow requirements.

Automatic  shutoff  should be  allowed  only  if  systems have   adequate

distribution system  storage  to maintain positive pressure for continued

water use.
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3.3   SITE-SPECIFIC CONDITIONS
      In addition to meeting source water quality  criteria  and  disinfec-
tion criteria, nonfiltering  systems using surface water supplies must meet
the following criteria:
            Maintain a watershed control program
            Conduct a yearly on-site inspection
            Determine that no waterborne disease  outbreaks  have occurred
            Comply with the revised annual  total  coliform MCL
            Comply with  TTHM regulations (currently applies to  systems
            serving >10,000 people)

Guidelines for meeting  these other criteria are  presented  in the following
sections.
      3.3.1  Watershed Control Program
      A watershed control  program is a surveillance and monitoring program
which is conducted to protect the quality of a surface water source.  An
aggressive  and  detailed  watershed  control   program  is  desirable  to
effectively limit or eliminate potential contamination by human viruses.
A watershed  program may  impact parameters  such  as turbidity,  certain
organic compounds, viruses,  total  and fecal coliforms, and areas of wild-
life habitation.  However,  the  program  is  expected  to  have little or no
impact  on  parameters  such  as naturally occurring  inorganic  chemicals.
Limiting human  activity  in  the  watershed  may reduce the  likelihood of
animals becoming infected with pathogens and  thereby reduce the transmis-
sion of pathogens by wildlife. Preventing animal activity near the source
water intake  prior  to disinfection may  also  reduce the  likelihood of
pathogen occurrence at the  intake.
      The effect  of  a watershed program  is  difficult  to quantify  since
many variables  that influence  water quality are beyond the  control or
knowledge of the water supplier.  As a result,  the benefit  of a watershed
control program or specific  control  measures must in many cases be  based
on accumulated cause and effect data  and on  the general  knowledge of the
impact  of  control measures  rather than on  actual  quantification.   The
effectiveness of  a program  to limit  or  eliminate  potential contamination
by human viruses  will  be determined based on:  the comprehensiveness of
the watershed review; the ability  of the water system to effectively  carry

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out and monitor the management decisions regarding control of detrimental
activities  occurring  in  the watershed;  and the potential for  the  water
system  to maximize  land  ownership  and/or  control  of  land use within  the
watershed.   According to the  SWTR,  a watershed  control  program  should
include as  a minimum:
            A  description of the watershed including  its hydrology  and
            land ownership
            Identification,  monitoring and control  of watershed character-
            istics  and  activities  in  the watershed  which  may have  an
            adverse effect on the source water quality
            A program to gain ownership  or control of the land within the
            watershed through written  agreements with land owners, for the
            purpose of controlling activities which will adversely affect
            the microbiological quality of the water
            An  annual  report which  identifies  special concerns  in  the
            watershed and how they are being handled, identifies activi-
            ties in the watershed, projects adverse activities expected to
            occur in  the  future and how  the utility  expects  to address
            them.
      Appendix  J contains  a  more detailed  guide  to a  comprehensive
watershed program.
      In  preparing  a watershed  control  program, surface  water systems
should draw upon the  State watershed assessments and  nonpoint source (NPS)
pollution management  programs  required by S319  of  the  Clean  Water Act.
Information  on   these  programs  is  available  from  State  water quality
agencies or EPA's regional offices.  Assessments identify NPS pollutants
in  water  and   assess  the  water  quality.    Utilities  should   use  the
assessments when evaluating pollutants in their watershed.  Surface water
quality assessments can also be obtained from the lists  of waters  prepared
under  $304(1)   of  the Clean  Water Act,  and State  biennially   prepared
S305(b) reports.
      State  NPS management programs  identify  best  management practices
(BMPs)  to be  employed  in  reducing  NPS pollution.    These  management
programs can be  incorporated in  the watershed program to protect against
degradation of  the source water  quality.
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      For  systems  using  ground  water  sources  under  the  influence  of
surface water, the  control measures delineated in the Wellhead  Protection
(WHP) program encompass the requirements of the watershed control  program,
and  can  be used to  fulfill  the requirements  of  the watershed  control
program.  Guidance on the content of  State  Wellhead  Protection  Programs

and  the delineation of wellhead protection  areas  is  given  in:  "Guidance
for  Applicants  for State Wellhead  Protection  Program Assistance  Funds
Under  the  Safe  Drinking  Water Act,"  June, 1987,  and "Guidelines  for
Delineation of Wellhead  Protection Areas," June, 1987, available from the

EPA office of Ground-Water Protection (WH-550G).
      As a minimum, the WHP  program must:

            Specify the  duties of  State  agencies,   local  governmental
            entities and public water supply systems with  respect to the
            development and  implementation  of Programs;

            Determine   the wellhead   protection   area  (WHPA)   for  each
            wellhead  as   defined  in  subsection  1428(e)   based  on  all
            reasonably available hydrogeologic information, ground-water
            flow, recharge and discharge and other information the State
            deems necessary  to adequately  determine the WHPA;

            Identify within each WHPA  all potential anthropogenic sources
            of  contaminants  which  may  have any  adverse  effect  on  the
            health of persons;

            Describe a program that  contains,  as  appropriate,  technical
            assistance,  financial  assistance,  implementation  of control
            measures,  education, training and  demonstration  projects to
            protect the water supply  within  WHPAs  from such contaminants;

            Present contingency plans  for locating and providing alternate
            drinking water supplies  for each public water system in the
            event of well  orwellfield contamination by such contaminants;

            Consider all  potential sources of such contaminants within the
            expected wellhead  area  of  a new water  well  which  serves a
            public water supply system; and

            Provide for public participation.


      3.3.2  Qn-site Inspection

      The  watershed  control   program  and  on-site  inspection  are  inter-

related preventive strategies.  On-site inspection  is  actually  a  program

which  includes  and surpasses  the  requirements of  a watershed  program.

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While  the  watershed  program is mainly concerned with the water  source,
on-site inspection includes some additional requirements for source water
quality control  and  is  also concerned  with  the disinfection  facilities.
As defined by the EPA,  an on-site inspection includes review of the water
source, disinfection facilities and  operation and maintenance of a public
water  system  for  the purpose  of evaluating  the adequacy  of  such  systems
for producing safe drinking water.
       The  SWTR  requires  an annual  on-site inspection  to evaluate  the
watershed  control  program and disinfection facilities.   The  inspection
must be performed by a  party approved by the Primacy Agency.  The inspec-
tion should  be  conducted by competent individuals such  as  sanitary  and
civil  engineers,  sanitarians,  and  technicians who have  experience  and
knowledge  in the operation, maintenance, and design of water systems,  and
who have a sound understanding of public health principles and waterborne
diseases.  Guidance for the contents of an inspection are included in the
following  paragraphs.    Appendix K  presents guidelines  for  a  sanitary
survey  which includes  and  surpasses  the  requirements  of   an  on-site
inspection.
       As the first step in determining  which SWTR requirements, if any, a
source is  subject  to,  EPA recommends  that  utilities  conduct  a detailed,
comprehensive sanitary survey.  Appendix K presents a comprehensive list
of water system features  that the person conducting the survey should be
aware  of  and  review as appropriate.   This  initial  investigation estab-
lishes the quality of the water source, its treatment and delivery to the
consumer.  EPA"recommends  that this comprehensive evaluation be repeated
every  three years for systems serving  4,100  people  or less and every five
years  for  systems serving  more than 4,100 people.  Also, under the Total
Coliform  Rule,  ground  water systems  which  take  less  than  5 coliform
samples per month must  conduct such  sanitary surveys within every  5 or 10
years  depending upon whether  the  source is protected and disinfected.
       The  annual  on-site  inspection  to  fulfill  the  SHTR requirements
should include as a minimum:
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      1.    Source Evaluation

            a.    Review  the  effectiveness  of  the  watershed  control
                  program (Appendix J).

            b.    Review  the  physical  condition  and  protection of  the
                  source intake.

            c.    Review  the  maintenance  program  to  insure  that  all
                  disinfection equipment is appropriate and has received
                  regular maintenance and  repair to assure a high operat-
                  ing reliability.

      2.    Treatment Evaluation

            a.    Review improvements and/or additions made to disinfec-
                  tion  processes  during  the previous  year to  correct
                  deficiencies detected in earlier surveys.

            b.    Review the condition of disinfection equipment.

            c.    Review operating procedures.

            d.    Review data  records  to  assure  that  all  required tests
                  are being  conducted  and recorded and  disinfection is
                  effectively  practiced  (CT  calculations  should be spot
                  checked to ensure that they were done correctly).

            e.    Identify  any needed  improvements  in  the  equipment,
                  system maintenance and operation, or data collection.


      In addition  to these  requirements,  a  periodic  sanitary  survey is

recommended for all systems,  including  those  with  filtered  and unfiltered
supplies.  The s.anitary survey should include the  items  listed  in  1 and 2

above as well as:
      3.    Distribution System Evaluation

            a.    Review the condition of  storage facilities.

            b.    Determine  that  the  system  has  sufficient   pressure
                  throughout the year.

            c.    Verify  that  system  equipment  has  received  regular
                  maintenance.

            d.     Review  additions/improvements  incorporated during  the
                  year  to correct deficiencies  detected  in the  initial
                   inspection.


                                   3-39

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             e.    Review  cross  connection  prevention  program,  including
                  annual  testing of backflow prevention devices.
             f.    Review  routine flushing program for effectiveness.
             g.    Evaluate the corrosion control program and  its impact on
                  distribution water quality.
             h.    Review  the adequacy of the  program for periodic storage
                  reservoir flushing.
             i.    Review  practices in  repairing water  main breaks  to
                  assure  they include disinfection.
      4.     Management/Operation Evaluation
             a.    Review  the  operations to assure  that any  difficulties
                  experienced  during  the  year  have  been  adequately
                  addressed.
             b.    Review  staffing  to assure adequate numbers of properly
                  trained and/or certified personnel are available.
             c.    Verify  that a regular maintenance schedule  is followed.
             d.    Audit systems records to verify that they are adequately
                  maintained.
             e.    Review bacteriological data from the distribution system
                  for  coliform  occurrence,  repeat  samples and  action
                  response.

      3.3.3  No Disease Outbreaks
      Under  the provisions of the SWTR, a surface water system which does
not  filter  must  not  have  been  identified  as  a  source of waterborne
disease,  or  if it  has been  so identified, the system must  have been
modified sufficiently to prevent another such occurrence,  as  determined by
the Primacy Agency.   If a  waterborne disease outbreak has  occurred and the
outbreak was or is attributed to a treatment deficiency, then the system
must  install filtration  unless the  system  has upgraded  its  treatment
system to remedy the deficiency which led to the outbreak and the Primacy
Agency has determined that the system is satisfying this  requirement.  If
the Primacy  Agency has determined the disease outbreak was the  result of
a  distribution system problem  rather than  a  source  water  treatment
deficiency,  the system  is not required to  install filtration.
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      In order to determine whether the above requirement  is being met,

the  responsible  federal,  state  and  local  health  agencies  should  be

surveyed to obtain the current  and historical information  on waterborne
disease outbreaks which may  have occurred within a given system.   Whether
conducted by the Primacy  Agency or submitted by  the  water  purveyor, this
information should include:

      1.    Source of the Information:

            a.    Name of agency
            b.    Name and phone number of person contacted
            c.    Date of inquiry

      2.    Outbreak Data

            a.    Known   or  suspected  incidents  of  waterborne  disease
                  outbreaks
            b.    Date(s) of occurrence(s)
            c.    Type or identity of illness
            d.    Number  of  cases

      3.    Status of Disease Reporting:

            a.    Changes in  regulations;  e.g.,  giardiasis  was not  a
                  reportable disease until 1985

      4.    If a Disease  Outbreak has Occurred:

            a.    Was the  reason  for  the  outbreak   identified;  e.g.,
                  inadequate disinfection?

            b.    Did the outbreak occur  while  the  system was  in  its
                  current configuration?

            c. -  Was remedial  action taken?

            d.    Have there been  any further outbreaks since the  remedial
                  action  was taken?
      If a review of the available information indicates that the system

or network for disease reporting is inadequate within the  Primacy Agency's
area of responsibility,  efforts should be made to  encourage the appropri-

ate  agencies  to upgrade the  disease  reporting capabilities  within  the

area.
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      3.3.4  Monthly Coll form MCL
      To  avoid  filtration,  a system must comply with the MCL  for  total
 coliforms, established in the Total  Coliform Rule, for at least 11 out of
 the previous 12 months  the system served water to the public on an ongoing
 basis,  unless  the Primacy  Agency determines  that  failure to  meet  this
 requirement  was  not  caused  by  a  deficiency in treatment of  the source
 water.   If the  Primacy Agency  makes such a  determination, the system is
 not  required to install  filtration.   The Total Coliform Rule requires
 systems using surface water  or ground water under the influence of surface
 water which  do  not  filter  to  collect  a  sample at or  near  the  first
 customer each day that the  turbidity level exceeds  1 NTU  within 24 hours
 of learning  of the result and  to  analyze the sample  for  the  presence of
 total coliforms.   (If  the Primacy Agency  determines  that  it is  not
 possible for the system  to  have such  a sample analyzed within 24 hours,
 this time limit may be  extended  on a case-by-case basis.)  This sample may
 be used to fulfill the routine  compliance monitoring requirements of the
 Total Coliform  Rule.    The results of  the  additional  sample  must  be
 included  in  determining  whether  the  system  is  in  compliance  with  the
monthly MCL for  total  coliforms.
      3.3.5  Total Trihalomethane (TTHM) Regulations
      For  the  system  to   continue to  use  disinfection  as  the  only
treatment,  it must  comply  with the  total  trihalomethane   (TTHM)  MCL
 regulation.  The current regulation established an MCL for total TTHM of
0.10 mg/L for systems serving a  population greater than  10,000.    Both the
MCL and the  system population  covered  may be reduced  in  the  future,  and
this should be considered when  planning  disinfectant application.
      One  alternative  to meet  the CT  requirements of  the  SWTR  is to
 increase the disinfectant dose.  For many systems, a higher chlorine dose
will result  in  increased formation of TTHMs.   Changes  in  disinfection
practice should  maintain TTHM levels of  less  than 0.10 mg/L.    In lieu of
 increasing chlorine dose, use of an  alternate disinfectant which  produces
 fewer TTHMs could be  considered.  Alternate  disinfectants include the use
of ozone  or  chlorine dioxide as  primary disinfectants with  chlorine or
chloramines  as  secondary (residual) disinfectants.   It  is  important to
 note that  EPA  also  will promulgate  regulations for  disinfectants  and
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disinfection  by-products  which may  limit  application  of some  of these
disinfectants.  EPA recommends  that Primacy Agencies  keep informed through
communication with  EPA on  interim  guidance  on  how to avoid  conflict for
systems to comply  with both  the  SWTR and the forthcoming regulations on
disinfectants and disinfection by-products.  Any changes which appear to
not meet the by-product regulations should not be implemented.
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                  4.   DESIGN  AND  OPERATING CRITERIA FOR
                      FILTRATION AND DISINFECTION  TECHNOLOGY
4.1   Introduction
      To comply with the SWTR, public water systems must include filtra-
tion, or  some other approved  particulate  removal  technology,  in  their
treatment  process  unless they are  able  to satisfy  certain  conditions.
Those conditions include compliance with source water  quality criteria and
site-specific criteria.  Guidance for determining whether these conditions
are  met  is  provided  in Section 3  of  this manual.   Systems  unable  to
satisfy  these  conditions  must  provide  particulate removal  and  meet
criteria pertaining to operation,  design and performance.  These criteria
are specified in part  in the definitions of technologies in the SWTR and
more specifically as determined by the Primacy Agency.
      This section provides  guidance both  for those  water systems which
currently  do not have filtration  equipment  and  must  add it,  and  for
systems which have existing  filtration  processes.  Guidance on additional
alternatives for small systems is presented in Appendix L.
      This section includes guidance on the following topics:
      a.      Filtration  Technology:   Descriptions,  capabilities,  design
             criteria and operating requirements for each technology, and
             a  listing  of  major  factors  to be  considered  in  their
             selection, including raw water quality considerations.
      b.      Disinfection:   Descriptions of  the  most  applicable disin-
             fection  technologies  used  with   filtration  systems,  and  a
             presentation of the relative effectiveness of these disinfec-
             tion technologies  with  respect to inactivation of bacteria,
             cysts and  viruses.
      c.      Alternate  Technologies:    Descriptions   of some  currently
             available  alternate filtration technologies.
      d.      Other Alternatives:  Includes  a description  of  some nontreat-
             ment  alternatives  including  regionalization  and  use  of an
             alternate  source.

4.2   Selection of Appropriate Filtration  Technology
      Filtration is generally  provided by  passing water through  a bed of
sand, a layer of diatomaceous earth  or a combination bed  of  coarse anthra-

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cite coal overlaying finer sand.  Filters are classified and named  in  a

number of ways.   For example, based on application rate,  sand filters can
be classified as  either slow or rapid;  yet  these two types of  filters
differ  in many  more characteristics than just  application rate.   They

differ  in their  removal  process,  bed material,  method of  cleaning,  and
operation.  Based on the type of bed material,  filters can  be classified
as sand, diatomaceous earth, dual-media  (coal-sand) or  even multi-media

in which a third layer of high density  sand  is  used.


      4.2.1   General Descriptions
      Current technologies specified by the  SWTR are:

      a.    Conventional  Treatment:    A  series  of processes  including
            coagulation, flocculation,  sedimentation  and filtration.

      b.    Direct Filtration:  A series  of  processes  including coagula-
            tion (and perhaps flocculation) and filtration, but excluding
            sedimentation.

      c.    Slow Sand Filtration:  A process  which involves  passage of raw
            water through a  bed of  sand  at  low  velocity,  generally less
            than 0.4 meters/hour  (1.2  ft/hr),   resulting  in substantial
            particulate removal by physical  and biological  mechanisms.

      d.    Diatomaceous  Earth  Filtration:    A  process  that  meets the
            following conditions:

                  A precoat  cake  of diatomaceous  earth filter media  is
                  deposited on a support membrane  (septum)

                  The water is filtered by passing it  through the cake on
                  the septum; additional  filter media,  known as  body  feed,
                  is continuously  added  to  the  feed  water  in order to
                  maintain the permeability of the filter  cake.
                                   4-2

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      e.    Alternate  Technologies:   Any  filtration process other  than
            those listed above.  Available alternate filtration  technolo-
            gies include, but are not limited to:
                  Package Plants1
                  Cartridge Filters

      4.2.2  Capabilities
      Filtration  processes  provide  various  levels  of  turbidity  and
microbial contaminant  removal.  When properly designed and  operated and
when  treating  source waters of  suitable  quality,  the above  filtration
processes are capable of achieving at least a 2-log (99 percent)  removal
of Giardia  cysts  and at  least  a  1-log (90 percent)  removal of  viruses
without disinfection (Logsdon,  1987b; USEPA, 1938b; Roebeck, 1962).  The
exception  is  cartridge  filters  which may  not  provide  effective  virus
removal.  A summary of  the removal  capabilities of the various filtration
processes is presented in Table 4-1.
      As indicated in Table 4-1, conventional treatment without disinfec-
tion  is capable of  achieving up  to a 3-log removal  of Giardia  cysts and
up to a 3-log removal of viruses.  Direct filtration can achieve up to a
3-log removal  of  Giardia  cysts  and up to  a 2-log  removal  of viruses.
Achieving the maximum removal efficiencies  with these treatment processes
requires the raw water  to be properly coagulated  and filtered.  Factors
which can adversely affecy removal efficiencies include:
            Raw water turbidities  less than 1 NTU
            Cold water conditions
            Non-optimal or no coagulation
            Improper filter operation  including:
  1    Depending  upon  the type  of  treatment units  in  place,  historical
      performance and/or pilot plant work,  these plants  could be categorized
      as one of the technologies  in  a-d above at the discretion  of the State.
      Several  studies  have   already indicated  that  some package  plants
      effectively  remove  Giardia cysts.   If  such  plants provided adequate
      disinfection  so  that the complete treatment train  achieves at least  a
      3-log removal/inactivation of Giardia cysts and a 4-log removal/inacti-
      vation  of  viruses,  use of  this  technology  would satisfy the minimum
      treatment  requirements.
                                   4-3

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                  No filter to waste
                  Intermittent operation
                  Sudden rate changes
                  Poor housekeeping
                  Operating the filters after turbidity breakthrough
      Studies  of slow sand  filtration  have shown that  this  technology
 (without  disinfection)   is  capable of  providing greater  than a  3-log
 removal  of Giardia.  cysts and greater  than a 3-log  removal  of viruses.
 Factors which  can adversely affect removal efficiencies include:
            Poor source water quality
            Cold water conditions
            Increases in filtration rates
            Decreases in bed depth
            Improper sand size
            Inadequate ripening
      Diatomaceous earth (DE) filtration can achieve  greater than a 3-log
 removal of Giardia cysts when sufficient precoat and body feed are used.
 However, turbidity and total colifonn removals are strongly influenced by
 the grade of DE employed.  Conversely, DE filtration is  not very effective
 for removing  viruses  unless the  surface  properties  of the diatomaceous
 earth have been  altered  by  pretreatment of the  body  feed with alum or  a
 suitable polymer.   In general,  DE filtration is assumed to achieve only
 a 1-log removal of viruses  unless demonstrated otherwise.  Factors which
can affect the removal of Giardia cysts and viruses  include:
            Precoat thickness
            Amount of body  feed
            Grade of DE
            Improper conditioning of septum
        -   Improper pretreatment of the body feed
      Package  plants can be used  to treat  water  supplies for  communities
as well  as  for recreational  areas, parks, construction camps,  ski resorts,
military installations  and  other facilities where potable water is not
 available  from a municipal  supply.   Operator requirements vary signifi-
cantly with specific situations.  Under unfavorable raw water  conditions,
                                   4-4

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                                   TABLE  4-1
                REMOVAL CAPABILITIES OF FILTRATION PROCESSES''1'
Process
Conventional
Direct Filtration
Slow Sand Filtration
Diatomaceous Earth
  Filtration


Giardia;2)
Cvsts
atment 2
n 2
tion 2
- 3
- 3
- 3(5>

Yi
1
1
1
Log Removals
ruses
. 2(3)
- 3<4>

Total a]
Col i form
>4
1 - 3
1 - 2
                         2 - 3
                              (5)
1 - 2
     (2)
1 - 3
Note:
      1.    Without disinfection.
      2.    Logsdon,  1987b.
      3.    Roebeck si il  1962.
      4.    Poynter and Slade,  1977.
•+.     ruynicr aim Jiauc, i7//.
5.     These technologies generally achieve greater than a 3-log  removal.

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package plants could demand full-time attention.  Package plants are most
widely used to treat surface supplies for  removal of turbidity, color and
coliform  organisms  prior  to disinfection.   They are currently available
in capacities up to 6 mgd.
      Colorado State University conducted  a series of tests on one package
plant  over a  5-month  period  during the  winter of  1985-86  (Horn  and
Hendricks, 1986).  Existing installations in Colorado had proven effective
for  turbidity removal,  and the tests at  the university  were designed to
evaluate  the  system's  effectiveness  in  removing coliform  bacteria  and
Giardia cysts from low turbidity, low temperature source  waters.  The test
results  showed   that  the  filtration  system could  remove  greater than
99 percent of Giardia cysts for waters which had less than 1 NTU turbidity
and  less  than 5 C temperatures, as long as proper chemical treatment was
applied,  and  the filter  rate  was  10 gpm/ft2  or less.   In  addition, an
alternate water source having a turbidity  ranging from 3.9 to 4.5 NTU was
used in 12 test  runs with  coagulant doses ranging from 15 to  45 mg/l.  The
effluent turbidities from these runs were consistently less than 0.5 NTU.
      Surveys of existing facilities indicate  that  while package plants
may be capable of achieving effective treatment, many have not consistent-
ly met the interim MCL  for turbidity,  and in some cases, coliforms were
detected  in the  filtered water (Morand et  al.,  1980;  Morand and Young,
1983).   The  performance  difficulties  were primarily the result  of the
short detention  time  inherent  in  the design of the treatment units, the
lack of skilled  operators with sufficient  time  to devote to  operating the
treatment facilities, and the  wide-ranging variability  in quality of the
raw water source.  For instance, raw water turbidity was  reported to often
exceed, 100 NTU at  one site.  Improvements in operational techniques and
methods at this  site resulted  in  a  substantial improvement in effluent
quality.  After adjustments were made,  the plant was capable of producing
a  filtered water with  turbidities  less  than  1  NTU,  even when influent
turbidities increased from 17  to 100 NTU within  a 2-hour period, as  long
as proper coagulation was provided.
      One of the major conclusions  of these surveys was that  package water
treatment plants  manned  by  competent  operators can consistently  remove
                                   4-5

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 turbidity  and  bacteria  from surface  waters  of  a  fairly  uniform  quality.
 Package  plants  applied  where raw water turbidities  are  variable require
 a  high degree  of operational  skill  and nearly  constant  attention  by  the
 operator.  Regardless of the quality  of the  raw water source,  all package
 plants require  at least a minimum level of maintenance  and  operational
 skill and  proper chemical  treatment  if they are  to  produce satisfactory
 water quality.
      Cartridge  filters using microporous filter elements (ceramic, paper
 or fiber) with pore sizes as  small as 0.2 urn may be suitable for producing
 potable  water  from  raw water  supplies containing  moderate levels  of
 turbidity, algae and microbiological  contaminants. The advantage to small
 systems  of  these cartridge  filters  is  that,  with the  exception  of
 disinfectant,  no other chemicals are  required.   The process is  one of
strictly physical  removal  of small   particles by straining  as  the water
 passes through  a porous cartridge.   Other  than occasional  cleaning or
cartridge replacement, operational requirements are not complex and do not
 require skilled  personnel.   However, the  SWTR  does  require each surface
water system to be operated by a qualified operator,  as determined by the
Primacy Agency.   Such a system may  be suitable for some  small systems
where, generally, only maintenance personnel are available for operating
water supply facilities.  However, the use of cartridge filters  should be
 limited to low turbidity source waters because of their susceptibility to
rapid headless  buildup.    For  example,  manufacturer's guidelines  for
achieving reasonable filter run lengths with certain  polypropylene filter
elements are that the raw water  turbidity be 2 NTU or less (USEPA,  1988b).
      Long (1983) analyzed the efficacy of  a variety  of cartridge  filters
using  turbidity  measurements,  particle  size   analysis,  and  scanning
electron  microscope  analysis.    The   filters  were  challenged  with  a
suspension of microspheres  averaging 5.7 urn in diameter which is  smaller
than a Giardia cyst.  The microspheres were  applied  at a concentration of
40,000 to 65,000 spheres per ml.  Ten of 17  cartridge filters  removed over
99.9 percent of  the microspheres.
      In tests using live infectious cysts  from a human source,  cartridge
filters  were found  to be  highly efficient in  removing  Giardia cysts
                                   4-6

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 (Hibler,  1986).   Each'  test  involved  challenging a filter with  300,000
 cysts at a concentration of 10,000 cysts/ml.  The  average removal for five
 tests was 99.86 percent, with removal  efficiencies ranging from 99.5 per-
 cent to 99.99 percent.
      The  application of cartridge  filters  to  small water systems  using
 either cleanable  ceramic or  disposable  polypropylene  cartridges  appears
 to be a  feasible  method for  removing  turbidity and  most  microbiological
 contaminants.  However,  data regarding  the  ability  of cartridge  filters
 to remove  viruses are not available.  Since disinfection  by itself could
 achieve a  4-log inactivation of viruses, if the cartridge filter removes
 greater  than or  equal  to   3  logs of  Giardia.  then the filter  plus
 disinfection would  achieve the  overall  minimum requirements,  regardless
 of whether only negligible Giardia  inactivation  is  achieved (e.g., less
 than 0.5 log).  However, consideration should be  given to the feasibility
 of providing  multiple  barriers of  treatment for each target organism,
 i.e., some Giardia and  virus removal by each barrier (i.e., some removal
 by filtration and  some inactivation by disinfection)  as protection in case
 one of the barriers  fails.   The efficiency and economics of the process
must be closely evaluated for each  situation.   Pretreatment in the form
 of roughing filters  (rapid sand or multi-media)  or fine mesh screens may
be needed  to remove  larger suspended solids which, if not  removed, could
 cause the rapid buildup of headloss  across the  cartridges  (USEPA, 1988a).
      In general,  conventional  treatment,   direct  filtration,  slow sand
 filtration and diatomaceous  earth filtration can  be designed and operated
 to achieve the-maximum  removal of the water quality parameters indicated
 in Table  4-1.  However, for the  purpose   of  selecting  the appropriate
 filtration  and disinfection technologies  and  for  determining  design
 criteria, these filtration processes should be assumed to achieve a 2-log
 removal of-Siardia cysts  and a  1-log  removal of  viruses.   This conserva-
 tive  approach will   assure  that  the  treatment facility  has adequate
 capability  to respond to non-optimum  performance due to   changes  in raw
 water quality, plant upsets, etc.   The balance  of the required removals
 and/or inactivation of Giardia cysts and viruses would be  achieved through
 the application of  appropriate  disinfection.
                                   4-7

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      The performance of alternate technologies such as cartridge filters,
and possibly package plants, depending upon the unit  under consideration
cannot be stated with certainty at this time.  Because of these perform-
ance  uncertainties,  pilot studies should  be used to  demonstrate  their
efficacy for a given water supply.

      4.2.3  Selection
      For  any  specific  site and  situation,  a number  of  factors  will
determine which filtration technology  is most appropriate.   Among  these
are:  raw water quality  conditions, space and  personnel availability, and
economic constraints.  A discussion of  the  impact of raw water quality on
the technology selection is presented here.  The impact of site-specific
factors  and economic  constraints is  presented in  the  USEPA  document
"Technologies and  Costs for the Removal of  Microbial  Contaminants  from
Potable Water Supplies"  (USEPA, 1988b).

      Raw Water Quality Conditions
      The number  of  treatment barriers provided .should  be commensurate
with the degree of contamination in the source water.  The four technolo-
gies specified in the SWTR vary in their ability to meet the performance
criteria when a wide range of raw  water quality is considered.  While the
numerical values of raw water quality that  can be accommodated by each of
the four technologies will vary from site  to site,  general guidance can
be provided. General guidelines for selecting filtration processes, based
on total  coliforra count, turbidity, and color are presented  in Table 4-2.
It is not recommended that filtration systems  other than those listed in
Table 4-2 be used when the general  raw water quality conditions exceed
the values listed, unless it has been demonstrated through  pilot testing
that the technology can meet  the performance  criteria  under the raw water
quality conditions expected to occur at the site.
      The  filtration  processes  listed in   Table  4-1  are capable  of
achieving the  required  performance criteria  when  properly designed and
operated if they  are  treating  a source water of suitable quality (i.e.,
generally within  the  ranges  indicated  in  Table 4-2).   One  of the causes
                                   4-8

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                                TABLE 4-2

               GENERALIZED  CAPABILITY  OF  FILTRATION SYSTEMS
               TO  ACCOMMODATE  RAH  WATER QUALITY CONDITIONS
                      	General  Restrictions	
                      Total
                      Coliforms          Turbidity               Color
Treatment             (1/100  m]\           (NTU1                   (CU)

Conventional with
  predisinfection     <20,000(3)          No restrictions^'       <75'2)

Conventional without
  predisinfection     <5,000(3)           No restrictions(3)       <75'-Z)

Direct filtration
  with flocculation     <500k3)           <7-14(1)                 <40(4)

In-line filtration      <500(3)           <7-14a)                 <10(3)

Slow sand filtration    <800l5)           <10(5)                   <5(3)

Diatomaceous earth
  filtration             <50(3)           <5{3)                    <5;3)
Notes;
   1.    Depends  on  algae  population,  alum or cat ionic polymer
         coagulation --  (Cleasby et al.,  1984.)

   2.    USEPA,  1971.

   3.    letter-man,  1986.

   4.    Bishop  et al.,  1980.

   5.    Slezak  and  Sims,  1984.

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of filtration failures is the use of inappropriate technology  for a given
raw  water quality (Logsdon,  1987b).   These criteria  are  general  guide-
lines.   Periodic occurrences of raw water coliform,  turbidity  or color
levels  in excess of the values presented  in Table 4-2 should not preclude
the  selection or use of a particular  filtration technology.  For example,
the  following alternatives are available  for responding to occasional raw
water turbidity  spikes:
      a.    Direct Filtration
                  Continuous  monitoring and coagulant dose adjustment
                  More frequent backwash of filters
                  Use of presedimentation
      b.    Slow Sand Filtration
                  Use of a  roughing filter
                  Use of an  infiltration gallery
      c.    Oiatomaceous Earth Filtration
                  Use of a  roughing filter
                  Use of excess body feed
      For the  above  alternatives,  EPA recommends  that  pilot  testing be
conducted to demonstrate the  efficacy of the treatment alternative.
      The characteristics of each filtration technology are a major factor
in the selection  process.  Significant characteristics  include performance
capabilities (contaminant removal  efficiencies), design and construction
requirements,  and  operation  and  maintenance   requirements.     Details
regarding each of the  four  filtration technologies are presented in the
following section.

4.3   Available Filtration  Technologies
      4.3.1  Introduction
      As  indicated in the preamble to the SWTR, the historical  responsi-
bility of the States  to establish design and operating criteria  for public
drinking  water  plants  will  continue.    The purpose  of  the   following
sections  is to provide guidance on how the design  and operating criteria
may  need  to  be changed  in order to assure that the performance criteria
in the  SWTR are met.
                                   4-9

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      The design criteria  for  the  various  filtration technologies  found

in the 1987  edition of Recommended Standards for Water Works (Great  Lakes,

1987)  are  the minimum  design  criteria  that  a majority  of  states  are

currently following.2   These  standards  are referred to  as  Ten  States

Standards in the  remainder of this manual.  The design criteria  contained

in the Ten  States Standards  have not been  duplicated here.  Rather,  the

reader is referred to the Ten States Standards directly.   EPA recommends

the following additions  and/or changes to the Ten State Standards in order
to assure compliance with the performance criteria of the  SVTR.


      4.3.2  General

      The following  recommendations apply to all  filtration plants:

      a.     All  filtration  plants   should  provide continuous  turbidity
            monitoring  of  the  effluent  turbidity from each individual
            filter.3•*   If  continuous monitoring  is impractical,  routine
            monitoring of individual filters is recommended as a minimum.

      b.     All  filtration  systems  should be concerned  with  the  peak
            turbidity levels in the filtered water after backwashing and
  2    Based upon the  results  of a survey conducted for  the  American  Water
      Works Association Research Foundation  (AWWARF), some 38 states use the
      Ten States Standards entirely or in modified form (AWWARF,  1986).
      Although "this  is  not  a  requirement of  the  SWTR,  it  is  recommended
      because of the possibility that not  all  filters  in  a treatment plant
      will  produce the sane effluent turbidity.  This nay be due to a variety
      of conditions  that  include bed upsets,  failure  of  media  support  or
      underdrain systems,  etc.  Although the combined effluent from all the
      filters may meet the turbidity requirements of the SWTR, the turbidity
      level from an  individual  filter may  substantially exceed  the limits.
      This  may result in the passage of Giardia cysts or other pathogens.

      Validation should be performed at  least twice  a week based  on the
      procedure outlined in Part 214A in the 16th Edition of  Standard Methods.
      It should be noted  that  improper  installation  of continuous monitors
      may  allow  for  air  bubbles  to enter  the monitor resulting  in false
      turbidity spikes.   To avoid air bubbles reaching the turbidimeter the
      sample tap should be installed below the center  line of the pipe and
      an air release valve may be included on the sample line.

                                  4-10

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            make  every  attempt to operate  the  filters  to minimize  the
            magnitude and duration of these turbidity spikes.5


      Individual  filters  should  be  monitored as  discussed  in  Section

4.3.2.a and when excessive turbidity spikes are found, corrective actions

taken.  During  these  turbidity  peaks, Giardia cysts  and  other  pathogens

may be passed into  the  finished water.   There is evidence  that  a 0.2 to

0.3 NTU increase  in the turbidity during the  first period  of the filter

run can be associated with rises in Giardia  cyst concentrations by factors

of twenty to forty  (Logsdon, 1985).   Special  studies  should be  conducted
to determine the extent of the turbidity spike problems.

      There  are  basically  four  approaches  available  for correcting

problems with turbidity spikes  after backwashing.  These  are as follows
(Bucklin,  et al  1988):

            Proper  chemical  conditioning of  the  influent  water  to  the
            filter  can  minimize  the magnitude  and  duration  of  these
            turbidity spikes.   This could  include  proper  control of  the
            primary coagulant chemicals  such  as  alum or  iron  compounds.
            In  some cases filter aids  using  polymers may be  needed to
            control the turbidity spikes.

            Gradually increasing  the filtration  rate in  increments when
            placing the filter in  operation.  Starting the  filter at a low
            flow  rate and then increasing the flow  in small  increments
            over 10 to 15 minutes has been shown to reduce the  turbidity
            spikes  in some cases  (Logsdon,  1987).

            Addition of coagulants  to  the backwash  water  has  also been
            shown to reduce the  extent of turbidity  spikes after backwash.
            Typically the same primary  coagulant  used  in the  plant is
            addeb1 to the backwash  water.  Polymers alone or  in combination
            with the primary coagulant may also be used.

            Filter-to-waste  may  be  practiced  where a  portion  of  the
            filtered  water  immediately after  starting   the   filter is
            wasted.   This is only possible where  the filter  system has
      For  most  high rate  granular  bed  filters,  there  is  a  period  of
      conditioning,  or  break-in immediately  following  backwashing,  during
      which turbidity and particle  removal  is at a minimum, referred to as
      the break-in period.  The turbidity peaks  are thought to be caused by
      remnants  of  backwash  water within  the pores of  and  above the media
      passing  through  the  filter,  and/or  floe  breakup during  the filter
      ripening  period before  it can adequately remove influent turbidity.
                                  4-1.1

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            provided  the  necessary valves  and  piping  to  allow  this
            procedure.  There is some concern whether or not this practice
            is beneficial.  The extra valve operations needed for filter-
            to-waste can disrupt the filter flow rate to the extent that
            they create their own turbidity spikes.  Some knowledge of the
            time actually needed for filter-to-waste is also needed before
            it can be determined that this is an effective procedure for
            controlling  turbidity  spikes.   If the  length  of  time  the
            filter-to-waste  is  practiced is  less  than  that  before  the
            turbidity spike  passes, the disruption  caused by  the  valve
            operation may actually  increase the turbidity spike.


      Different plants  and  the individual filters within the  plant  may

have  different turbidity  spike  characteristics.   The four  approaches

presented  above,  therefore,  must  be evaluated  on  a case-by-case basis.

Special  studies  will be required  to  identify  those  filters  with  the
turbidity  spike   problems  and assist  in  selecting which  of  the  four

approaches  is  best for correcting  the  problem.   It has  been generally

found that turbidity spikes can be  minimized  through  one or a combination

of the first three approaches.

      In  order to establish  filter-to-waste operating  guidelines,  the
following procedure is suggested:

            Review the effluent turbidity data for  each filter and deter-
            mine which filter historically has  the highest effluent tur-
            bidity.

            Following backwashing of the  filter with the poorest perfor-
            mance, place that filter into service and collect crab samples
            every 5 to 10 minutes for a period  of at least 60 minutes.6

            Analyze the grab samples for turbidity  and determine how long
            the filter must be in operation before  the effluent  turbidity
            drops

                  to less than or equal to 0.5  NTU

                  or 1 NTU  in cases where a filtered water turbidity  of
                  less than or equal to  1 NTU is allowed.
  6   Continuous turbidity monitoring can be used in place of grab  sampling.


                                   4-12

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      Limited information exists on the typical magnitude and duration of
peak  turbidity  levels  after backwashing  and what  levels are  considered
acceptable to assure that these turbidity spikes are not  associated  with
passage  of  Giardia cysts.   Information from plant  scale tests,  showing
the typical magnitude and duration  of these turbidity spikes is available
from two plants (Bucklin et  al.. 1988).  Studies  conducted at these plants
over a year showed that these  peaks occurred within the first few minutes
after the filter was placed back in operation,  their  effects  lasted for
several hours, and varied in magnitude from 0.08 to 0.35  NTU on average.
      For  existing plants  without  provisions  for  filter-to-waste,  the
decision to add the necessary  piping to provide this capability should be
made only after  carefully evaluating the other three approaches.  If the
results  of  special studies show  that  the  other three options  are not
effective in minimizing  the turbidity  spikes then  the expense of adding
the filter-to-waste capabilities may be justified.
      For new plants the capability of filter-to-waste may be required by
the Primacy  Agency or  should  be considered.   By having this capability,
additional  flexibility  will be  available  for  turbidity spike control.
This flexibility may  also be useful  for other filter maintenance functions
such as after media replacement or when heavy chlorination  of the filter
is needed after  maintenance.

      4.3.3  Conventional Treatment
      Conventional  treatment   is  the  most  widely  used technology for
removing turbidity and microbial contaminants from surface water supplies.
Conventional  treatment  includes  the  pretreatnent  steps  of  chemical
coagulation,  rapid nixing, flocculation  and sedimentation  followed by
filtration.  These conventional  treatment  plants typically use aluminum
and iron  compounds in  the  coagulation processes.   Polymers may also be
used to enhance  the  coagulation and filtration  processes.   A flow  sheet
for a conventional treatment plant  is presented  on  Figure 4-1.
      Lime softening is  a  treatment process used to remove hardness and
turbidity from surface waters.  Treatment is typically accomplished with
conventional  process  units.    The lime  softening process  removes the
                                   4-13

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calcium  and  magnesium from  the  water by precipitating them  as  calcium
carbonate and magnesium hydroxide.  Turbidity levels in  the water are also
reduced  by this process.  Lime and possibly soda ash is added to the raw
water to raise  its  pH to a  point at  which these precipitates are formed
and then removed from the water during sedimentation and filtration.  Lime
softening may  be used for  the  removal  of carbonate hardness  in  the  pH
range of 9 to 10 through a single stage  process.  Two-stage lime/soda ash
softening at a pH of 10 to 12 can be used for the removal of non-carbonate
hardness and  magnesium.   Two-stage  softening  includes recarbonation  to
neutralize the caustic alkalinity, reducing the pH  to the range of 8.5 to
9.5.   A flow sheet  for  typical  one- and  two-stage softening plants  is
presented on Figure 4-2.
      Each of these  three conventional treatment processes uses filtration
following sedimentation.  Three different types of filters  are used.  Sand
filters, normally found  in  older plants, use  a single media of sand to
form a  filter bed,  and are  generally designed with a  filtration rate of
2 gpm/ft2.   Newer plants normally use dual-media or mixed media filters.
Dual media filters use a combination  of  anthracite  coal along  with a sand
to form  the filter bed.  Mixed media  filters use coal, sand,  and a third
material to  form  the  filter bed.   Dual  and mixed  media  filters  can be
designed to operate  at higher  filtration rates than sand filters, i.e.,
4 to 6 gpm/ft2.

      Design (Criteria
      The  minimum  design  criteria  in  the   Ten   State  Standards  for
conventional  treatment  are  considered   sufficient  for the  purposes  of
complying with the SHTR  with the  following addition:
            The criteria for sedimentation should  be expanded to  include
            other  methods  of  solids  removal  including dissolved  air
            flotation.    Plate   separation   and   upflow-sol ids  contact
            clarifiers included  in the  1987  Ten  State Standards should
            also be considered.

      Operating Requirements
      In addition  to  the  operating   requirements  in   the  Ten  State
Standards, a coagulant should be used at all  times  the treatment  plant is

                                   4-14

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COAGULANTS


RAPIO MIX
30 SEC 2 IMM
DETENTION
— ^
FLOCCULATION
20-45 MIN
— ^
SEONMENTATIOM
1-4 HOURS
                                         FILTRATION

                                          RAPID SAND 2 9pm ft?

                                           DUAL AND TRI-MIXEO
                                            MCCXA 4-< gpm ft?
FIGURE 4-1-FLOW SHEET OF A  TYPICAL CONVENTIONAL

                   WATER TREATMENT PLANT

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    SINGLE STAGE SOFTENING  I1!
     LIME
|aA»io MIX
JO SEC 2 M4M
3ETCNTION
•— ^
FUOCCULATION
:o-4$ MIN
i— ^i
[21
SEOIMCMTATION
« HOURS
— ^
FILTH AT IQN
flAPIO SAMO. 2 •••/««*
DUAL ANO MULTI
MCQIA 4.4 «««/n 1
     1] PH RANGE 9-10
    [2]  OR ALTERNATE SOLIDS REMOVAL PROCESS
    TWO STAGE SOFTENING [1
        LIME
INFLUENT
                                               SODA ASH
                           \
FLOCCULATOR-
 CLARIFIER    /
                                  RECARBONATION
    1J PH RANGE 10-12
FLOCCULATOR-\
 CLARIFIER    /'
                                                         SOFTENED WATER
      FIGURE 4-2-FLOW  SHEET OF TYPICAL SOFTENING  TREATMENT PLANTS

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             ^         ;
 in operation.'  Conventional and direct filtration plants must be monitored
 carefully because  failure  to  maintain optimum  coagulation  can  result  in
 poor filter performance and breakthrough  of cysts and viruses.8  Although
 the detention time provided by the settling  basins results in some margin
 of safety, the loss of coagulation control at the chemical  feed or rapid
 mix points may not  be  noticed until  the  poorly coagulated  water reaches
 the filters,  after the process has failed.  Failure to effectively monitor
 and  control   filter operation  can  result  in undetected  poor  filter
 performance (Logsdon, 1987a;  Logsdon, 1987b).
      Effective  operation  of  a  conventional  treatment  plant  requires
 careful monitoring and control of:
            Chemical Feed
            Rapid Mix
            Flocculation
            Sedimentation
            Filtration
      For  the  purposes  of  the  SWTR,  the  requirements  for  effective
operation of a conventional  water treatment plant can be  summarized  as
 follows:
      a.    The  application  of  a  coagulant   and  the  maintenance  of
            effective coagulation and  flocculation at all  times when a
            treatment plant   is in  operation.9  Proper  process control
  7    Dependable removal of Giardia  cysts  can  not  be guaranteed if a water
      is filtered without being properly coagulated  (Logsdon, 1987b; Al-Ani
      et al., 1985).   This  is  true even if the raw water turbidity is less
      than 1 NTU.
      As indicated  in  the  preamble  to the proposed SWTR,  33 percent of the
      reported  cases of  giardiasis  in  waterborne disease  outbreaks  were
      attributed to  improperly operated  filtration plants.

      Some  conventional  water treatment plants which treat  low turbidity
      source  waters  (<1  NTU)  reportedly discontinue  the  application  of
      coagulant(s) during periods of low turbidity since the raw water already
      meets the turbidity MCL. However,  studies have shown that cyst removal
      for low turbidity waters is the most difficult to achieve and  requires
      optimum pretreatment including coagulation to achieve effective removals
                                  4-15

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      procedures should be used at the plant to assure that chemical

      feeds are adjusted and maintained in response  to variations
      in raw water temperature and turbidity.

      Maintenance  of effective   filtration  will   require   proper

      operation procedures to meet the turbidity requirements of the
      SWTR.  Proper operation should  include:

            Proper chemical  conditioning of the water ahead  of the
            filter to assure  adequate turbidity removal through the
            filter.

            Control  of  the   flow  rates and  elimination  of  rapid
            changes in flow  rate  applied to the filter.

            Backwashing of filters before the filtered water quality
            is degraded  to the point that the plant  fails  to meet
            the turbidity requirements  of the SWTR.   The criteria
            on which to base  initiation of backwash will have to be
            determined for each plant.   Experience  with  operation
            cycles including run  times  and headless  data  may serve
            as the basis  for this site  specific criteria.

            After backwash bringing the clean filters back  on line
            so that excessive turbidity  spikes in the filtered water
            are  not  created.    Section   4.3.2.B  of  this  manual
            discusses  these   turbidity   spikes   and  approaches
            available to  minimize them.
      Filters removed from service generally  should  be backwashed
      upon start-up.   However,  in some cases, it may be impractical
      to backwash filters each time they are removed  from service.
      Accordingly,  the Primacy Agency may choose to allow start-up
      without backwash ing under certain conditions on a site-by-site
      basis.    In making  this decision,  the  following  should  be

      considered:
      _  -   the length of time the filter was off-line
            performance of the filter while being put on-line
      The filter should be brought back on-line in  such a way that

      no turbidity spikes that could be associated  with passage of
(Al-Ani et al., 1985).


                            4-16

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            Giardia  cysts  and  other pathogens occur.    If  problems  with
            turbidity  spikes  are  found when starting up dirty  filters,
            special  studies  should be  used to evaluate  if  any of  the
            approaches discussed  in Section 4.3.2.B of this manual  are
            effective  in minimizing the turbidity spikes.

      4.3.4  Direct  Filtration
      A direct filtration plant can include several different pretreatment
unit processes depending upon the  application.  In its simplest form, the
process  includes only  in-line filters preceded  by chemical  coagulant
application  and  mixing.    The mixing  step,  particularly in  pressure
filters,  can  be satisfied by  influent pipeline  turbulence.   In larger
plants  with  gravity  filters,  an   open  rapid-mix basin with  mechanical
mixers typically  is  used.   Figure 4-3  illustrates  the  unit processes of
a typical direct filtration plant.
      Another variation of the direct filtration process consists of the
addition  of  a coagulant to  the raw water followed by  rapid  mixing and
flocculation, as  illustrated  on Figure 4-4.  The chemically conditioned
and flocculated water  is then applied directly to a dual- or multi-media
filter (USEPA,  1988b).

      Design Criteria
      The 1987 edition of the Ten State Standards  recommends pilot studies
to determine most design criteria.  For the purposes of  implementation of
the SWTR  this requirement is considered  sufficient   with the following
exception:
      a.    A coagulant must be used at  all times when the treatment  plant
            is  in operation.
                             10
  10  Optimum coagulation is critical for effective turbidity and microbiolog-
      ical  removals  with  direct  filtration  (Al-Ani  et  al.,  1985).

                                   4-17

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      Operating Requirements
      Operating considerations for direct filtration plants are essential-
 ly  identical  to  those for  conventional  treatment  plants.   The  major
 difference  is that  a  direct  filtration  plant will  not have a clarifier,
 and may or may not have a flocculation or contact basin.  In addition, EPA
 recommends  that all direct  filtration plants,  both new and existing,  be
 required  to make  provisions to minimize  the break-in time  of  a  filter
 being put on-line.11
      As  with  conventional  treatment,  the  initiation of  backwashing  a
 filter should first be based on filter effluent  turbidity values, then by
 headloss and run time.  Effluent turbidity monitoring  equipment should be
 set to initiate filter backwash at an effluent  value of 0.5 NIL) or less,
 in order to meet  filtered water quality requirements.  Also, any filters
 removed from service should be backwashed upon  start-up.  In some cases,
 it may not  be practical  to  backwash  filters every time they are removed
from service.   This decision should be made by the Primacy Agency on a
case-by-case basis,  based on the same considerations  as for conventional
systems.

      4.3.5  Slow Sand Filtration
      Slow sand filters differ from single-media rapid-rate  filters in a
number of  important characteristics.    In addition to the difference of
flow rate, slow sand filters:
      a.    Function using biological  mechanisms as well as physical-che-
            mical  mechanisms
      b.    Use smaller sand particles
      c.    Are not backwashed,  but rather  are cleaned by removing the
            surface media
      d.    Have much  longer run times  between  cleaning
  11   As with conventional  treatment, direct filtration produces a relatively
      poor  quality  filtered  water  at the  beginning  of filter  runs  and
      therefore a filter-to-waste period is recommended.  In  some cases, the
      addition of  a filter aid or  bringing  filters on-line  slowly will be
      appropriate  (Cleasby et al.,  1984).

                                  4-18

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     COAGULANTS
 INFLUENT'
 RAPID MIX
30 SEC  2 MIN
 DETENTION
DUAL OR MIXED
 MEDIA FILTER
 4-5 gpm ft *
                   FIGURE 4-3 FLOW SHEET  FOR A TYPICAL
                                DIRECT  FILTRATION PLANT
     COAGULANTS
•NFLUENT
.

RAPID MIX
30 SEC • 2 MIN
DETENTION
—
FLOCCULATION
15-30 MIN
— -^
DUAL OR MIXED
MEDIA FILTER
4-5 gpm ft 2
           FIGURE 4-4-FLOW  SHEET FOR A  TYPICAL DIRECT
                     FILTRATION PLANT WITH FLOCCULATION

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       e.     Require  a  ripening period  at the beginning of each run

       Although  rapid rate filtration  is the  water treatment technology
 used  most extensively  in  the United  States,  its use has  often proved
 inappropriate  for small  communities  since  rapid-rate filtration  is  a
 technology  that requires skilled operation by  trained operators.   Slow
 sand  filtration requires very little control  by  an operator.  Consequent-
 ly, use of this technology may be more appropriate for small systems where
 source  water quality  is within  the guidelines  recommended  in  Section
 4.2.3.
      As  indicated  in  this  section,  slow  sand  filtration  also  may be
 applicable to other  source water quality conditions with the addition of
 pretreatment such  as a  roughing filter or presedimentation.

      Design Criteria
      The minimum design criteria  presented in the Ten State Standards for
 slow sand filters are considered sufficient  for  the purposes  of implemen-
 tation of the SWTR with  the  following  exceptions:
      a.    Raw water quality limitations should be changed to reflect the '
            values given in  Table 4-2.12
      b.    The effective sand  size should  be between 0.15mm and 0.35mm
            rather than  the  current  0.30 mm to 0.45 mm.13

      Additional  guidance  on  the  design  of  slow  sand  filtration  is
available in the design manual entitled Slow Sand Filtration for Community
Hater Supplies  Technical Paper 24.  1987  published by the International
  12   Without pretreatment,  limitations  exist in the quality of water  that
      is suitable for slow sand  filtration  (Logsdon,  1987b; Cleasby et  al.,
      1984; Bellamy et al.,  1985;  Fox et al.,  1983).

  13   Significant decreases in total coliform removals were shown at effective
      sand sizes less than 0.35 mm (Bellamy  et al., 1985).  As  defined  in the
      AWWA Standard for Filtering Material, effective size is the size opening
      that will pass 10 percent  by weight of  a sample of filter material.
                                   4-19

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Reference  Centre  for  Community  Water  Supply  and  Sanitation  (IRC),
P.O.  Box 5500,  2280  HM  Rijswijk, the Netherlands.

      Operating  Requirements
      Maintenance of a  slow sand filter involves two periodic tasks:
      a.    Removal  of  the top  2 to  3 cm (0.8 to  1.2 inches)  of the
            surface  of the sand bed when the headloss  exceeds 1 to 1.5 m.:<
      b.    Replacement of the sand when repeated scrapings have reduced
            the  depth of the sand to  approximately one-half of its design
            depth (Bellamy et al., 1985).

      Following  scraping,  slow  sand  filters   produce  poorer  quality
filtrate at  the beginning of  a  run, and  a  filter-to-waste  or ripening
period of one to two days is  recommended before  use to supply the system.
The ripening  period  is  an interval  of  time  immediately after a scraped
filter is put back on-line, when the turbidity or particle count results
are significantly higher than the corresponding  values for the operating
filter.    During this  time,  the  microorganisms  multiply  and  attain
equilibrium in  the   "schmutzdecke."   Filter  effluent monitoring results
should be used to determine the end of the ripening period.  For example,
a turbidimeter  could be set at 1.0 NTU or less  to initiate start of the
filter run.
      When repeated  scrapings  of the sand have  reduced the depth of the
sand bed to approximately  one-half of its design depth, the sand should
be  replaced. „  Filter bed  depths  of  less than  0.3  to 0.5 m  (12  to  20
inches) have been shown to result  in poor  filter performance (Bellamy et
al.,  1985).   The  replacement procedure  should include  removal  of the
remaining sand down to the  gravel support,  the addition of new sand to one
half of the design depth and placement  of  the sand previously  removed on
top of the new sand.15
  14   Removal  of this top  layer  of the  "Schmutzdecke"  should restore the
      filter to  its operational capacity  and  initial headloss.
  15   This procedure  results  in clean sand being placed in the bottom half
      of the filter bed and biologically active sand in the top half  reducing
      the amount of  time required for the curing period.  It  also  provides
                                   4-20

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       The amount of time for the biological  population to mature in a new
 sand filter (also called curing) and to provide stable and full treatment
 varies.    The  World  Health  Organization   (1980)  reported  that  curing
 requires  a few weeks  to  a few months.   Fox et al., (1983)  found  that
 "about 30 days" were  required to bring particle and bacterial effluents
 down to  a stable level.   All  researchers agree  that a curing  time for a
 new  filter  is required before  the filter operates  at  its fullest potential
 (Bellamy  et al., 1985).

       4.3.6  Diatomaceous  Earth Filtration
       Diatomaceous  earth  (DE)   filtration,  also  known   as   precoat  or
 diatomite filtration, is  appropriate for  direct  treatment  of  surface
 waters for  removal of  relatively low  levels of turbidity and microorgan-
 isms.
       Diatomite  filters  consist of a  layer of DE  about  3 mm (1/8 inch)
 thick  supported on a septum or filter element.  The  thin precoat layer of
 DE must be  supplemented by a continuous  body feed of diatomite, which is
 used  to  maintain the  porosity  of  the filter cake.    If no  body  feed is
 added, the  particles  filtered  out  will  build  up on  the  surface  of the
 filter cake and cause  rapid increases in headless.   The problems inherent
 in maintaining the proper film of DE on the septum have restricted  the use
of  diatomite  filters  for  municipal  purposes,  except  under  certain
favorable  raw water  quality  conditions, i.e.,  low  turbidity  and  good
bacteriological  quality.    Specific upper  limits  of raw  water  quality
parameters  are-not well-defined  because diatomaceous  earth  filtration
performance depends on the nature,  as well  as  the concentration,  of the
 raw water particles and the grades of diatowite employed.   Logsdon  (1987b)
 reported that filtered water turbidities above 1 NTU and  short  filter runs
were  observed for  several diatomaceous  earth plants having maximum raw
water  turbidities above 20 NTU.
      for  a complete  exchange  of sand  over time,  alleviating potential
      problems of excessive silt accumulation and clogging of the filter bed
      (Bellamy et al.,  1985).

                                   4-21

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       Design Criteria
       The minimum design criteria presented  in the Ten State Standards for

 diatomaceous earth  filtration  are  considered sufficient for the purposes
 of compliance with  the  SWTR  with the  following exceptions:

       a.     The recommended quantity of precoat is 1 kg/m2  (0.2  pounds per
             square  foot) of filter area, and the  minimum thickness of the
             precoat filter cake  is 3mm  to 5mm (1/8 to 1/5-inch).ls

       b.     Treatment plants should be  encouraged to provide a coagulant
             coating (alum or suitable polymer) of the body feed.17


       Operating Requirements

       Operating requirements specific to DE filters  include:
             Preparation of body  feed  and precoat

             Verification that  dosages are proper

             Periodic backwashing and  disposal of spent filter  cake

             Periodic inspection of the septum(s) for cleanliness or damage

             Verification that  the filter is producing  a  filtered water
             that meets the performance  criteria


       4.3.7  Alternate Technologies

       The  SWTR  allows the use of filtration  technologies other  than those

specified  above provided  that the system  demonstrates  to  the Primacy

Agency using  pilot  studies or  other means that the filtration  technology

when combined with  disinfection  achieves at least 3-log Piardia cyst and

4-log  virus  removal/inactivation.   Such technologies must also meet the
turbidity  performance  criteria for slow sand  filtration.  Guidance for
  16   Studies have shown that a precoat thickness of 1 kg/m2 (0.2 lbs/ft:)  was
      most effective  in Giardia cyst  removal and that the precoat  thickness
      was more important than the  grade size in cyst removal  (DeWalle et al.,
      1984; Logsdon et al.,  1981; Bellamy et al.,  1984).

  17   Although enhancement of the DE is not required for Giardia cyst removal,
      coagulant  coating  of  the body  feed has  been  found to  significantly
      improve  removals of  viruses,  bacteria and turbidity.    (Brown  et al.,
      1974; Bellamy et al.,  1984).

                                  4-22

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conducting pilot studies to demonstrate this effectiveness is provided  in
Appendix M of this manual.
      Reverse osmosis  is  a  membrane  filtration method which  is  used for
desalination and/or  the  removal of organic  contaminants.   The  treatment
process is effective for the removal  of Giardia cysts and viruses  and  no
demonstration is necessary.
      Alternate  filtration  technologies which  are  currently  available
include, but are not limited to:
            Package Plants
            Cartridge Filters
      Package plants in principle are not a separate technology from the
preceding technologies.  However,  in  many cases they  are different  enough
in design criteria, and operation and maintenance requirements  that they
should be considered  as  an alternate technology.   The  package  plant  is
designed as a factory-assembled, skid-mounted unit generally incorporating
a single,  or at most, a few process units.  A complete treatment process
typically consists  of chemical coagulation,  flocculation,  settling and
filtration.   Package plants  generally can be applied to flows ranging from
about 25,000 gpd to  approximately 6  mgd  (USEPA,  1988b).   In cases where
the Primacy Agency believes that the  design  criteria of the package plant
corresponds to the  design  criteria of  the processes established earlier
in this section  (i.e.,  that the package plant qualifies as conventional
or direct filtration), the  requirement of pilot  testing may be waived.
      The application of cartridge filters  using  either cleanable ceramic
or disposable polypropylene cartridges to snail water  systems  may be a
feasible method for removing turbidity and some  microbiological contami-
nants, such  as  Giardia  cysts  although no data  are available   regarding
their ability to remove viruses.  Pilot  studies are required  to  demon-
strate the efficacy of this technology for a given  supply.  However,  if
the  technology  was  demonstrated to be  effective  through  pilot plant
studies  at  one  site,  then the  technology could  be  considered  to  be
effective  at  another  site  which  had  similar  source water quality
conditions.  Therefore,  pilot  plant  testing  at the  new site might  not be
necessary.
                                   4-23

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       It is important  to  note  that the demonstration of achieving the 3-
 log   Giardia  cyst  and  4-log  virus  removal/inactivation  requirements
 includes disinfection.  Thus,  if a cartridge  filter is demonstrated to
 achieve a  3-log  removal of Giardia cysts  and it is determined by CTs that
 the   disinfection  achieves  at  least  a  4-1og  virus  inactivation,  the
 effectiveness  of the  technology would be  demonstrated.   The technology
 must  also  maintain  turbidities less  than  1 NTU in 95 percent  of the
 monthly samples.   Meeting  this  turbidity  requirement  assures  a  high
 probability that turbidity will not interfere with disinfection and that
 the inactivation efficiencies  predicted by  the CTs are reliable.

       Design Criteria
       After any  necessary pilot studies are conducted  and a successful
 demonstration  of performance  has been  made, design  criteria  should be
 established and approved by the Primacy Agency.   Eventually, a sufficient-
 ly large data  base  will  become available,  making it easier to apply the
 alternate  technologies to other water supplies of similar quality.

       Operating  Requirements
       After any  necessary pilot studies are conducted  and a successful
 demonstration  of performance has been  made,  operating requirements should
 be established and approved  by  the Primacy  Agency.

       4.3.8 Nontreatment Alternatives
       Under certain  circumstances,  some  systems may have other alterna-
 tives  available.  These alternatives  include regionalization and the use
of alternate sources.
       For  small  water  systems  which must provide filtration, a feasible
option way  br  to join with other small or large systems  to  form a region-
 al water supply  system.   In  addition, alternative water sources located
within  a reasonable distance of a community which would allow the system
to meet  the requirements of  the SWTR  and other applicable drinking water
 regulations, may be developed  to  provide  a satisfactory  solution  to a
 community water  quality problem.  The availability of alternative ground
                                  4-24

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water  sources  will  depend upon the size and location of the  system  and
the costs  involved.

4.4    Disinfection
       4.4.1  General
       The  SWTR requires  that  disinfection  be  included  as  part of  the
treatment  of  surface  water for  potable use.   As  noted  earlier,  EPA
recommends that the number of treatment barriers be commensurate with  the
degree of contamination in the source water  in accordance with Table 4-2.
For example, as  indicated in  Table 4-2,  when  the  total  coliforms in  the
source water are  greater  than  5,000/100  ml,  conventional  treatment with
predisinfection  is  recommended.   However, the  selection of  appropriate
disinfection requires consideration of other factors in addition to than
those  included in Table 4-2. These considerations include:
      a.    Source water  quality and the overall removal/inactivation of
            Gjardia cysts and viruses desired.
      b.    Likelihood of TTHM formation.
      c.    Potential  need  for  an oxidant  for  purposes  other  than
            disinfection   including   control   of  taste,   odor,  iron,
            manganese, color, etc.

      4.4.2  Recommended  Removal/inactivation
      The SWTR requires a minimum 3-log removal/inactivation of Giardia
cysts and a minimum 4-log removal/inactivat ion of viruses:
      a.    We 1,1-operated conventional  treatment  plants which have been
            optimized for turbidity removal  can  be expected to achieve at
            least a 2.5-log removal of Giardia cysts.
      b.    Well-operated  diatomaceous  earth,  slow  sand  filtration and
            direct filtration plants can be expected to achieve  at least
            2—log removal of Giardja cysts.

       EPA recommends that:
       a.    Conventional  filtration systems provide sufficient disinfec-
            tion  to  achieve a minimum of 0.5-log Giardia cyst and 2-log
            virus inactivation.
                                   4-25

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      b.    Slow sand filtration systems provide  sufficient  disinfection
            to achieve  a  minimum  of 2-log Giardia cyst and 2-log  virus
            inactivation.
      c.    Systems  using  diatomaceous  earth  and direct filtration,  or
            other filtration methods, should provide sufficient disinfec-
            tion to  achieve a minimum  of  1-log  Giardia cyst  and  3-log
            virus inactivation.
      Further  guidance on  the  disinfection  level  to be  provided  is
contained in Section 5.  CT values for achieving these inactivations are
presented in Appendix E.  As indicated in this Appendix:
      a.    A  comparison   of  Tables  E-l  through   E-6  with  Table  E-7
            indicates that systems which achieve a 0.5-log  inactivation
            of Giardia cysts, using free chlorine,  will  achieve greater
            than a 4-log inactivation  of viruses.
      b.    Ozone and  chlorine  dioxide are generally more  effective at
            inactivating  viruses  than  Giardia  cysts.     However,  as
            indicated  in  Tables  E-8  through  E-ll,  there  are  some
            conditions under which the disinfection needed to provide the
            recommended virus inactivation  is  higher than that needed for
            the  recommended  Giardia  cyst  inactivation.    Therefore,  a
            system using ozone or chlorine dioxide for disinfection must
            check  the  CT  values needed  to  provide  the  recommended
            inactivation of both Giardia cysts and viruses and provide the
            higher of  the  two disinfection levels.   Systems may demon-
            strate their efficiency for overall removal/inactivation using
            the protocol in Appendices G and M.
      c.    As indicated  in  Tables  E-12 and  E-13,  chloramines  are much
            less effective for inactivating Giardia cysts and viruses than
            the other disinfectants.   Also, chloramines may  be applied to
            the system in several ways, either with chlorine added prior
            to ammonia, ammonia added prior to chlorine or preformed.  For
            systems applying chlorine ahead of ammonia, the required level
            of disinfection may be determined as follows:
                  determine  the  CT  needed  to   provide   the  required
                  inactivation of Giardia and  viruses and  provide the
                  higher of the two levels or
                                  4-26

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                   follow the  protocol  in  Appendix  G  to  demonstrate
                   effective   inactivation   to   allow   lower  levels  of
                   disinfection.

             For systems  applying ammonia ahead of chlorine or preformed
             chloramines,  the EPA recommends that the  system demonstrate
             effective  virus  inactivation  according to the  protocol  in
             Appendix  G,  since the  CT values for  virus  inactivation  in
             Table  E-13  only  apply to the  addition of  chlorine prior to
             ammon i a.
      Although  the SWTR requires  a minimum of a  3-log removal/inactivation
of Giardia cysts and a minimum of a 4-log removal/inactivation of viruses,
it may be appropriate for the Primacy Agency to  require greater removals/-
inactivations depending upon  the  degree of contamination within  the source
water.
      Rose (1988) conducted a survey of water sources to characterize the
level of  Giardia cyst occurrence for "polluted"  and  "pristine" waters.
Polluted  waters are  defined as  waters  in  the  vicinity of  sewage and
agricultural  wastes,  while  pristine  waters are  those  originating  from
protected  watersheds  with   no  significant  sources  of  microbiological
contamination from human  activities.  EPA  believes that treatment should
be  provided  to  assure  less  than  one case of microbiologically-caused
illness per  year per 10,000  people.  In order to provide  this level  of
protection,  3,  4 or  5-log  Giardia cyst  removal/inactivation  should  be
provided for ttie following source water qualities:
            Giardia Cyst  Removal/inactivation  Required Based11  19
           	on Source Hater Cvst Concentration	
Giardia Inactivation                       3-log       4-log       5-log
Allowable daily  avg
  cyst concentration/100  L                 <1          >1-10       >10-100
  (geometric mean)
  18   Rose, 1988.
  19   10"4  annual risk per person based on consumption of 2  liters of *ater
      daily.
                                  4-27

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      According to these guidelines,  systems with sewage and agricultural
discharges  to the source water  should  provide treatment to  achieve  an
overall  5-log removal/inactivation  of Giardia cysts, while  the  minimum
required  3-log  removal/inactivation is  sufficient  for sources  with  no
significant microbiological  contamination from human  activities.  A 4-log
removal/inactivation of cysts should be provided for source waters whose
level of microbiological  contamination is between these  two extremes.  The
location of discharges  or other activities polluting  the water supply with
respect  to the  location of  the intake  should also  be considered  in
determining the level of removal/inactivation  needed.  For instance, long
travel  times  and  substantial  dilution  of a  discharge will  lessen  the
impact of the discharge  on  the  intake water  quality,  in  which case less
of  an increase  in the  overall  treatment recommended  above, would  be
warranted.  It  is important to note that these  levels of  treatment for
different generalized  source water  characterizations are presented only
as guidelines. The Primacy Agency could  develop disinfection requirements
based on these or other  guidelines.   It could also  require systems with
available  resources  to  conduct  raw water monitoring  for  Giardia cyst
concentrations to establish  the appropriate level of  overall treatment and
disinfection  needed.
      The  Primacy Agency may  also  review the nature of  occurrence  of
Giardia-sized particles  in the raw water supply and the association with
turbidity occurrence.  If it can be demonstrated that a higher degree of
removal of  particles  in the size range  of Giardia  is  accomplished when
turbidity levels  and associated  Giardia levels are  elevated, then a log
removal  credit  higher  than  3  could   be  allowed  for  that  particular
treatment plant,  during such occurrences.  This credit should correspond
to the log  particle  removal  efficiencies accomplished, as determined by
particle counting  data, or turbidity data if  properly qualified.   In all
cases, a minimum of 0.5 log reduction  of Giardia  should be achieved by
disinfection  in   addition  to the  removal  credit  allowed  for  by other
treatment.
                                  4-28

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       Until a risk analysis for exposure  to viruses is developed,  a rough
guideline  for virus  removal/inactivation, can be considered as  follows:
       a.    For  a 4-log Giardia. cyst removal/inactivation,  a 5-log virus
            removal/inactivation is recommended.
       b.    For   5-log  Giardia   removal/inactivation,   a   6-log  virus
            removal/inactivation is recommended.

       These guidelines  assume  that  virus  occurrence  in  the source water
is roughly proportional to Giardia cyst occurrence, and that
            viruses  occur at higher concentrations in source waters, or
            are  more infectious than Giardia cysts and
            infections from viruses may have more health risk significance
            than Giardia cysts.

Based  on these assumptions, higher levels of protection are warranted.
       To meet  the levels of  inactivation  recommended here, significant
changes in the  system  may be  required.   To  avoid  changes  in the system
which may result in conflicts with  future regulations, the  Primacy Agency
may wish to establish  interim disinfection levels to provide protection
of  the public   health  prior  to  the promulgation  of  the disinfection
by-product regulations and then reconsider whether these  levels are  still
appropriate after the disinfection by-product regulations are promulgated.
Guidance for establishing  interim disinfection requirements is  provided
in Section 5.5.

       4.4.3  Total Tribalomethane  fTTHEn  Regulations
       In addition to complying with  disinfection requirements,   systems
must  meet  the  requirements  of the  TTHM regulations.   Currently,  this
regulation includes  an MCL for TTHMs of 0.10  mg/L for systems which  serve
greater than 10,000  people.  EPA expects  to  issue  new regulations with a
lower  MCL  in the  near future.   These regulations may  also pertain to
systems serving  less than  10,000 people.   Therefore,  the selection  of an
appropriate  disinfectant  or disinfection  strategy must include consid-
eration of current  and  future  regulations.
                                   4-29

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                5. CRITERIA FOR DETERMINING  IF  FILTRATION
                  AND DISINFECTION ARE SATISFACTORILY PRACTICED
5.1    Introduction
       Under  the  SWTR,  new  and existing  filtration  plants  must  meet
specified  monitoring  and performance  criteria  in order  to  assure  that
filtration and disinfection are satisfactorily practiced.  These criteria
include:
            Turbidity monitoring requirements
            Turbidity performance criteria
            Disinfection monitoring requirements
            Disinfection performance criteria

       The overall objective  of  these  criteria  is to provide control of:
Giardia cysts; viruses;  turbidity;  HPC; and  Legionella  by  assuring a high
probability that:
       a.    Filtration  plants  are well-operated  and achieve  maximum
            removal efficiencies of the above parameters.
       b.    Disinfection will  provide adequate  inactivation  of Giardia
            cysts, viruses, HPC and Legione!la.

5.2    Turbidity Monitoring Requirements
       5.2.1 Sampling Location
       The purpose  of  the  turbidity  requirements for  systems  which use
filtration is to indicate:
       a.    Giardia cyst and general particulate removal for conventional
            treatment and direct filtration
      b.    General particulate removal for  diatomaceous earth filtration
            and slow sand filtration
       c.    Possible  interference  with disinfection for  all  filtration
            processes

       To accomplish the purposes of the turbidity requirements, the SWTR
requires  that  the turbidity  samples  be representative of  the system's
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 filtered  water.    The  sampling  locations  which  would  satisfy  this
 requirement  include:
       a.     Combined  filter effluent prior to entry into a clearwell,

       b.     Clear-well effluent;

       c.     Plant effluent or immediately prior  to entry into the distri-
             bution system; or

       d.     Average of measurements from each filter effluent.


       The  selection  of sampling locations for  demonstrating  compliance
with  the  turbidity performance  criteria is  left to  the system  or the
preference of the Primacy Agency.


       5.2.2  Sampling Frequency

       The turbidity of the filtered water must be determined:
       a.    At least  once every  four hours that the system  is in opera-
            tion, or

       b.    The Primacy Agency may reduce the sampling frequency to once
            per day for systems using slow sand filtration or filtration
            treatment other than conventional  treatment, direct filtration
            or diatomaceous earth filtration, if it determines that less
            frequent  monitoring  is  sufficient to  indicate  effective
            filtration performance.   For  systems  serving 500  or fewer
            people, the Primacy Agency may reduce the sampling frequency
            to once per day regardless of the type of filtration used if
             it determines that less frequent monitoring is sufficient to
            indicate effective filtration performance.


      A system may  substitute continuous turbidity monitoring  for grab
sample monitoring if it validates the continuous measurement for accuracy
on a regular basis using a protocol approved by the Primacy Agency.  EPA

recommends  that  the  calibration  of  continuous  turbidity  monitors  be
verified at least twice per week according to the procedures established
in Method 214A of the 16th Edition of Standard Methods.1
  1    Although the  17th  Edition  of  Standard  Methods is available, the 16th
      Edition is referred to  in the SWTR.  Continuous turbidity monitors must
      be installed properly to prevent air bubbles from reaching the monitor.

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       5.2.3  Additional Monitoring
       As  indicated  in Section 4.3.2, EPA recommends that  systems  equip
each  filter with a continuous turbidity monitor.   This  recommendation is
not  part  of  the  requirements  of  the  SWTR and  is not  required  for
establishing compliance.  Rather,  it  is  recommended as a tool  for systems
to  use to better monitor their treatment  efficiency  and  to provide  a
method for detecting  a deterioration in filter performance.
       If  continuous  monitoring  of  each  filter  effluent   cannot  be
implemented, then EPA recommends that at  least the following be conducted
on a quarterly basis:
       a.    Monitor  each  filter,  either  by  grab samples  or  continuous
            monitors, through the course of  a routine cycle of operation,
            i.e.:  from restart to backwash
       b.    Visually inspect each filter where appropriate for indications
            of physical deterioration of the filter

       These are general suggestions.  The Primacy Agencies are encouraged
to  work  with  the  systems  to  determine  the best  overall  monitoring
program(s) for their  particular filtration plants in order to assess the
status  of the  filter units.   Each filter within  a  system should be
maintained so that each  filter  effluent meets the turbidity performance
criteria  for  the combined  filter  effluent   (i.e., the  turbidity limits
specified in the SWTR).

5.3    Turbidity Performance Criteria
       The SWTR establishes turbidity performance  criteria for each of the
filtration technologies.  As previously  indicated, these criteria provide
an indication of:
       a.    Effective particle  and microbial removal
       b.    Potential  for  interference with disinfection

       In  filtration,  effective  particle  removal depends on both physical
and chemical factors.  The particles to be removed must be  transported to
the  surface of  the  media and  they must  attach to  the  media.    When
efficient particle  removal does not occur,  the  deterioration of filter

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performance  can  be  due to either physical problems with the  filters  or
problems with the treatment chemistry.
      Physical  problems  which can result  in  a deterioration of  filter
performance  include:
      a.     Media loss
      b.     Media deterioration
      c.     Mud ball formation
      d.     Channeling or surface cracking
      e.     Underdrain failure
      f.     Cross-connections

      In addition,  the treatment chemistry has a  significant  impact  on
filtration.   Specifically,  effective particle removal is a  function  of
the:
      a.     Raw water chemistry and the changes induced by  the chemicals
             added
      b.     Surface chemistry of the particles to be removed
      c.     Surface chemistry of the media

Consequently, when a filter experiences particle or  turbidity breakthrough
prior to the development of terminal headless,  the search for alternatives
to  correct  the  problem  must include  not only  an  evaluation  of  the
potential physical causes but the treatment chemistry  as well.  Generally
this involves an evaluation of one or more of the following:
      a.     Alternate coagulant type and/or dose
      b.     Alternate coagulant aid or flocculant aid type and/or dose
      c.     Need for an alternate oxidant  type and/or dose
      d.     Need for a filter aid or alternate dose
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      5.3.1  Conventional Treatment or Direct Filtration

      The  minimum  turbidity  performance  criteria  for  systems  using
conventional treatment or direct filtration are:

      a.    Filtered water turbidity must be less  than or equal to 0.5 NTU
            in 95 percent of the measurements taken every month.

      b.    Filtered water turbidity levels of less than  or equal to 1 NTU
            in 95  percent  of the measurements taken every month  may be
            permitted  on a  case-by-case basis  if the Primacy  Agency
            determines that the system (filtration with  disinfection) is
            capable of achieving the minimum overall performance require-
            ments of 99.9 percent removal/inactivation of Giardia cysts at
            the  higher  turbidity  level.   Such a  determination  could be
            based  upon  an  analysis   of  existing  design  and  operating
            conditions and/or performance relative to certain water quali-
            ty characteristics. The design and operating conditions to be
            reviewed include:

                  the adequacy of treatment prior to filtration,
                  the  percent   turbidity  removal  across  the  treatment
                  train, and
                  level of disinfection.

            Water quality analysis which  may  also be used to evaluate the
            treatment effectiveness include particle size counting before
            and after the filter.   Pilot plant challenge studies simulat-
            ing  full  scale  operation  may also  be used  to  demonstrate
            effective treatment.   Depending  on the source water quality
            and system size,  the Primacy  Agency will determine the extent
            of the  analysis  and whether a pilot  plant  demonstration is
            needed.    For  this  demonstration,  systems  are  allowed to
            include  disinfection   in  the determination  of  the  overall
            performance by the system.2

      c.    Filtered water turbidity may not exceed 5 NTU at any time.

      The Primacy  Agency can  assume  that  conventional  treatment plants

that are meeting the minimum performance criteria are achieving at  least

a 2.5-log removal of GJarojia  cysts  and at least a  2-log removal of viruses

prior to disinfection.3
      Recommended protocol for this demonstration is presented in Appendix M.

      The  literature indicates  that  well operated  conventional  treatment
      plants can achieve  up to 3-log reduction of Giardia cysts and viruses
      (Logsdson,  1987b  and Roebeck et al.,  1962).   Limiting the credit to
      2.5-logs for Giardia cysts and 2-logs for viruses provides a margin of
      safety by  requiring more disinfection.   This  is consistent with the

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      The Primacy Agency can  assume that direct filtration plants that are
meeting  the  minimum  performance  criteria  are  achieving  at  least  a  2-log
removal  of Giardia cysts  and a 1-log removal  of viruses.4
      Although  the minimum turbidity  performance  criterion  allows  for a
maximum  filtered water  turbidity  of  0.5  NTU,  treatment  facilities  using
conventional treatment or direct filtration, whose raw water supplies have
turbidity  levels of  1  NTU  or  less,  should   be  encouraged to  achieve
filtered water  turbidity  levels of less than 0.2 NTU.5
      Primacy  Agencies  may  allow systems which  believe  that they  are
actually achieving greater than  a 2-  or  2.5-log  Giardia cyst  removal to
demonstrate  the actual  removal  achieved using the  protocol outlined in
Appendix M.   It is reasonable  to expect  that  systems  using conventional
treatment for high turbidity  source water  (e.g., turbidities in excess of
100 NTU), and which optimize chemical treatment prior to filtration,  may
be  achieving a 3-log  or greater Giardia  cyst removal  if  their filter
effluent is  substantially below  the  0.5  NTU turbidity  limit.   Softening
plants using  conventional processes  and  2-stage  treatment  processes may
also achieve  a  3-log  Giardia cyst removal/inactivation.   The  high  pH of
softening may result  in  inactivation  of  Giardia  cysts  and  viruses  which
can be  demonstrated  according to the protocol outlined  in Appendix G.
Appendix M can be used to demonstrate the Giardia cyst removal  achieved.
      multiple barrier concept.
  *    Literature indicates  that  well  operated  direct filtration plants can
      achieve  up  to a  3-log removal  of  Giardia cysts  and  up to  a 2-log
      removal of viruses  (Logsdon,  1987b;  Roebeck et al.,  1962).   Limiting
      the credit to 2-log for Giardia cysts and  1-lpg for viruses provides a
      margin of safety  by  requiring  more  disinfection.   This is consistent
      with the multiple barrier concept.
  5    Research has demonstrated that filter effluent turbidities substantial-
      ly  lower than 0.5 NTU are  needed  to  obtain  effective  removals of
      Giardia cysts  and  viruses  with low turbidity source waters (Logsdon,
      1987b; Al-Anl et al.,  1985).
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      5.3.2  Slow Sand Filtration

      For systems using  slow  sand  filtration,  the turbidity  performance
requirements are:

      a.    The  filtered water  turbidity  must  be less than or  equal  to
            1 NTU in 95 percent of the measurements for each  month.

      b.    At  the  discretion  of  the Primacy  Agency,  a higher  filter
            effluent turbidity  may  be allowed  for well  operated  plants
            (Section  4.3.5)  on  a  case-by-case  basis,  if there  is  no
            interference with disinfection  and the turbidity level never
            exceeds 5 NTU.   Noninterference with disinfection  could  be
            assumed if the finished water entering the distribution system
            is meeting the coliform MCL and HPC  levels  are less than 10/ml
            during times of highest turbidity.

      c.    Filtered water turbidity may not exceed 5  NTU at  any time.


      Slow sand filtration plants,  with appropriate design and operating

conditions and which meet the minimum turbidity performance criteria can

be considered to be well operated and achieving at least a 2-log removal

of Giardia  cysts and  2-log  removal  of  viruses  without disinfection.6

Primacy Agencies may allow  systems  which  believe that they  are actually

achieving greater than  a 2-log Giardia cyst removal  to  demonstrate the

actual removal achieved using the protocol outlined in Appendix M.


      5.3.3  Diatomaceous Earth Filtration

      For  systems  using  diatomaceous earth  filtration,  the  turbidity

performance criteria are:
      a.    The  filtered water  turbidity  must  be less than  or equal  to
            1 NTU in 95 percent of the measurements for each month.

      b.    The  turbidity  level of  representative samples  of filtered
            water must at no time exceed  5 NTU.


      Diatomaceous earth systems,  with  appropriate design and operating

conditions and which meet the minimum turbidity  performance criterion can
      As indicated  in  Section  4,  pilot studies have shown that with proper
      nurturing of  the schmutsdecke, operation at a maximum loading rate of
      0.2  m/hr will provide optimum  removal  of Giardia  cysts and viruses
      (Logsdon, 1987b; Bellamy et al.,  1985).

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be considered to be well operated and  achieving at least 2-log removal  of
Giardia cysts and at least 1-log  removal of viruses without disinfection.
Systems which believe that they are actually achieving greater than a  2-
log Giardia cyst removal may demonstrate the actual removal achieved using
the protocol outlined in Appendix M.

      5.3.4  Other Filtration Technologies
      The turbidity performance criteria for filtration technologies other
than those presented above,  are the same as for slow  sand filtration.  The
Giardia cyst removal  achieved by these systems must be demonstrated to the
Primacy Agency.   The protocol  outlined in  Appendix M may be used  as a
basis for this demonstration.
      Reverse osmosis   is a  membrane  filtration method  used to  remove
dissolved solids from water  supplies.   Desalination is  a  typical  use  of
the  process.    Application  to  potable water treatment  is   limited  to
extremely high  quality  raw  water supplies of  low  turbidity (1  NTU  or
less), or following pretreatment to produce a supply of low turbidity.
      The membrane  excludes particles  larger than  0.001  to 0.0001  urn
range, thereby effectively removing bacteria, Giardia cysts and viruses.
Credit can  be given for at  least  a 3-log Giardia  cyst and  4-log virus
removal,  with no demonstration.    It  should be noted that  this removal
credit assumes the membranes are  in tact  with no  holes  in the membranes
allowing the passage of organisms.

5.4   Disinfection Monitoring Requirements
      Each system must  continuously monitor the disinfectant residual  of
the water  as  it enters the distribution  system  and record  the  lowest
disinfectant residual each day.  If there is a failure in the continuous
monitoring equipment, the  system may substitute grab  sample monitoring
every 4 hours for up to 5 working days  following  the equipment failure.
Systems serving  3300  people or  fewer may take grab samples  in lieu  of
continuous monitoring at frequencies as follows:
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             System  Population                Samples/Day
             <500                                  1
             501-1,000                             2
             1,001 - 2,500                         3
             2,501 - 3,300                         4

      The grab  samples  must  be  taken  at  different  times during the day,
with the sampling intervals subject to Primacy Agency  review and approval.
If the residual concentration falls below 0.2 mg/L, the system must take
another  sample  within  4-hours  and notify the Primacy  Agency  as  soon as
possible, but no later than the  end of the next business day, even if the
residual  is  restored to  0.2 mg/L  or greater within  4 hours.   If the
residual is not restored to 0.2 mg/L or greater within 4 hours,  the system
is in violation  of  a  treatment  technique requirement.   Each system must
also measure the disinfectant residual in the distribution system at the
same frequency and locations  at which total coliform measurements are made
pursuant to  the requirements in the  revised  Total Coliform  Rule  (54 FR
27544; June  29,  1989).    For systems  which  use both surface  and  ground
water sources,  the Primacy  Agency  may allow substitute  sampling sites
which are more  representative of the  treated surface water supply.

5.5   Disinfection Performance Criteria
      5.5.1  Minimum Performance Criteria Required bv  the SWTR
      For systems which provide  filtration,  the disinfection requirements
of the SWTR  are:
      a.     Disinfection  must  be  provided to  ensure  that   the total
             treatment  processes  of  the  system  (including  filtration)
             achieves at least a 3-log  removal/inactivation of Giardia cyst
             and  a 4-log  removal/inactivation  of  viruses.   The  Primacy
             Agency must determine what level of disinfection is required
             for each system  to meet this criterion.
      b.     The  system must demonstrate by continuous  monitoring and
             recording that a disinfectant residual in  the water entering
             the distribution system is never  less than  0.2 mg/L for more
             than  4  hours.   If at  any time  the  residual falls below 0.2
             mg/L  for more than  4 hours the  system is  in violation.  The

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             system must  notify  the Primacy Agency whenever the residua]
             falls below 0.2 mg/L before the end  of the next business day.
      c.     The system must demonstrate detectable disinfectant residuals
             or  HPC  levels  of  500 or  fewer  colonies/ml  in at  least  95
             percent of the samples from the distribution system each month
             for any two consecutive months.

      5.5.2  Recommended  Performance Criteria,
      Disinfection must be  applied to  assure that the overall  treatment
provided  achieves at  least  a 3-log removal/inactivation  of Giardia cyst
and a 4-log removal/inactivation of viruses.   As outlined in Section 5.3,
well operated  filter  plants achieve at least a 2 to 2.5-log  removal  of
Giardia cysts and between a 1 to 2-log  removal of  viruses.  EPA therefore
recommends that the Primacy Agencies adopt additional  disinfection perfor-
mance criteria that include:
      a.    As  a  minimum,  primary disinfection  requirements   that  are
            consistent with the  overall  treatment  requirements  of  the
            SWTR,  or preferably;
      b.    Primary disinfection  requirements as  a function of raw water
            quality as outlined  in Section 4.4.

      Recommended Minimum Disinfection
      The  required  minimum  primary disinfection  is the   disinfection
needed for the  entire treatment  process to  meet  the  overall  treatment
requirement of 3-log  Giardia and 4-log virus removal/inactivation.  The
following  table  provides  a summary of the  expected minimum  level  of
treatment performance in  well operated  filter systems and the recommended
level  of disinfection.
                       Expected                 Recommended Disinfection
                     Log Removals                  (Log Inactivations)
Filtration        Giardia     Viruses           Giardia            Viruses
Conventional         2.5          2.0                0.5               2.0
Direct              2.0          1.0                1.0               3.0
Slow Sand           2.0          2.0                1.0               2.0
Diatomaceous
  Earth             2.0          1.0                1.0               3.0

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       In cases where the system believes that the treatment processes  are
achieving  greater  removals  than those listed above, the  actual  removal
provided  by the processes  can be  demonstrated  through the  procedures
outlined  in Appendix  M.   However,  EPA  recommends that,  despite  the
removals demonstrated,  systems  should provide a minimum of 0.5 log Giardia
cyst inactivation to supplement  filtration and maintain a second treatment
barrier for microorganisms.
      Recommended Disinfection as a Function of  Raw Hater Quality
      Although  the  SWTR  requires   the  overall  treatment  to  provide  a
minimum of a 3-log  Giardia cyst and a 4-log virus removal /inactivation, it
may be appropriate  for  the  Primacy  Agency  to require greater  removal s/-
inactivations depending on  the degree of contamination in the source water
as presented in  Section  4.4.   Following  is  a summary of the recommended
overall treatment  which  should be  provided based on an  estimate of  the
Giardia cyst concentration in the source water:
   Allowable daily avg
   cyst concentration/100 L
      ^geometric mean^                    <1          >1-1Q     >10-100
   Giardia cyst Removal/Inacti vation    3-log        4-log      5-log
   Virus Removal/Inactivation           4-log        5-log      6-log

      If a slow sand filtration plant must achieve a 4-log removal/inacti-
vation of Giardia cysts and a 5-log removal/inactivation of viruses, and
credit for 2-log  Giardia  cyst and 2-log  virus  removal  by filtration is
granted,  disinfection  for a  2-log  Giardia cyst  inactivation  and 3-log
virus inactivation would  be needed to meet  the overall removal/inacti-
vation.   However,  Primacy Agencies  may allow systems which use particle
size analysis outlined in Appendix M to demonstrate greater than a 2-log
Giardia cyst removal  to provide less  than  2-log  Giardia cyst inactivation
through disinfection.
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       5.5.3   Disinfection Bv-Product Considerations
       Although  the EPA  suggests increased  levels  of disinfection  for
 various^source  water  conditions, a utility  should not implement  such  a
 change without considering the potential conflict with  the requirements of
 existing or   future disinfection by-product regulations.   EPA intends to
 promulgate National Primary Drinking Water Regulations to regulate levels
 of  disinfectants  and  disinfection  by-products  when  it  promulgates
 disinfection  requirements for ground water systems (anticipated in 1992).
 EPA  is  concerned  that  changes  required  in  utilities'   disinfection
 practices to  meet  the recommended inactivations for the SWTR   might be
 inconsistent  with treatment changes needed to comply with the forthcoming
 regulations  for disinfectants and  disinfection by-products.   For  this
 reason,  EPA  recommends  that   Primacy  Agencies  exercise  discretion,
 sensitive to  potential  disinfection  by-product  concerns,  in determining
 the level of disinfection needed  for filtered systems to meet the overall
 treatment  requirements  specified  in  the  rule  or recommended  based on
 source water  quality.
       Until the  promulgation  of  the disinfection by-product regulation,
 EPA recommends that the Primacy Agency allow more credit for Giardia cyst
 and virus  removal  by  filtration than  otherwise  recommended if  a)  the
 Primacy Agency determines that a  system is not currently at a significant
 risk   from  microbiological  contamination  at  the  existing  level  of
disinfection  and  b)  less stringent  interim  disinfection  conditions are
necessary for the system to modify its disinfection process to optimally
achieve compliance with the SWTR as well  as the forthcoming disinfection
by-product regulations.   The following paragraphs outline the recommended
disinfection  levels for systems meeting the above conditions.
       For well-operated conventional  filtration plants  that  meet  the
minimum  turbidity  requirements  at  all  times,   the  Primacy  Agency  may
consider giving the system credit for 3-log Giardia cvst removal  (in  lieu
of the generally recommended 2.5-log credit).   Also,  for well-operated
direct  filtration  plants,  the  Primacy Agency  may consider  giving the
 system credit for 2.5-log Giardia cyst  removal  in lieu of the generally
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 recommended 2.0-log credit.  EPA recommends that these additional credits

 be given  for conventional or direct filtration only if:

      a.    The  total  treatment train  achieves  1) at least 99  percent
            turbidity removal, or filtered water turbidities are consis-
            tently less  than  0.5  NTU,  whichever  is lower,7  21  2)  a 99.9
            percent removal of particles in the size range of 5 to 15 urn
            is demonstrated as outlined in Appendix M;3 and

      b.    The  level of heterotrophic plate count (HPC)  bacteria in the
            finished (disinfected) water entering the distribution system
            is consistently less than 10/ml.


      Systems using slow sand  filtration or diatomaceous earth filtration

may be given interim credit for up  to  3-log  Giardia cyst removal  if the

system meets  the recommended  conditions  listed above for  conventional

systems.  Pilot  plant studies have demonstrated that these technologies,

when well operated, generally  achieve  at  least 3.0-log  removals (USEPA,

1988a).

      The EPA believes that interim level of disinfection  requirements may

be  appropriate  in  some cases  depending  upon   source  water  quality,

reliability of system operation and  potential  increased health risks from

disinfection by-products.    EPA intends  to  regulate disinfectants  and

disinfection by-products in 1992.   At  this  time  it will  become apparent

how systems with disinfection by-product problems can optimally meet the

disinfection requirements  of  the SWTR  and  the disinfection by-products

regulations, concurrently.
  7    For  example,  a system  with a  raw  water turbidity  averaging  20 NTU
      maintaining a filtered water turbidity  less than 0.2 NTU can  be granted
      3-log Giardia cyst removal  credit with no further demonstration.

  8    In  cases where  the   Primacy  Agency has  a data  base which  shows   a
      correlation between turbidity and Giardia cysts  removal,  turbidity may
      be used  in lieu of particle size analysis.  Turbidity removal require-
      ments should  be  set  to assure  99.9  percent Giardia cyst removal.    A
      correlation between turbidity and Giardia cyst  removal was  shown in  a
      study reported by Hendricks et  al  (1984).

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      5.5.4  Recommended Disinfection System Redundancy
      The  SWTR does  not require  a redundant  disinfection  system  for
filtered supplies.  However, in order to assure the continuous  provision
of disinfection to meet the  overall  removal/inactivation requirements and
to maintain  a  residual  entering  the distribution  system,  EPA recommends
that redundant disinfection equipment be provided.   As  contained  in the
1987 edition of Ten State Standards, where  disinfection  is  required for
protection  of  the  supply,  standby  equipment  is  required.    Automatic
switchover should  be provided as needed,  to assure continuous disinfectant
application.
      Recommendations for providing  redundant disinfection are outlined in
Section 3.2.4 and detailed in Appendix I.

      5.5.5  Determination of Inactivation bv Disinfection
      The desired  level  of inactivation can be achieved  by disinfection at
any  point  in the  treatment  or distribution  system prior to  the first
customer.   Disinfection provided prior to filtration  is  referred to as
pre-disinfection while  disinfection after filtration  is  referred to as
post-disinfection.   As  presented  in Section  3.2,  the  inactivation of
Giardia cysts  and  viruses  provided by disinfection  are  indicated by CT
values.
      The SWTR  defines CT as the residual  disinfectant concentration(s) in
mg/L multiplied by the  contact  time(s)  in minutes.   The contact time is
measured  from  the point of  disinfectant  application  to the  point of
residual  measurement  or between  points of  residual  measurement.   The
inactivation efficiency  can be determined by calculating CT  at any point
along  the process  after disinfectant  application  prior to  the first
customer.
      A system may determine  the  inactivation efficiency  based  on one
point of residual  measurement  prior  to the first customer, or on a  profile
of the residual concentration after the point of disinfectant  application.
The  residual profile  is generated  by monitoring the residual  at  several
points  between the point(s)  of disinfectant  application  and  the  first
customer.  The system can then  use the method described in Section  3.2 for
determining the total inactivation credit.   Profiling the residual  allows
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 for  credit  of  significantly  higher  residuals  which  may  exist  before  the
 water  reaches  the first  customer.   Methods  for  determining  various
 disinfectant residuals are described in Appendix 0.
       In  pipelines,  the contact time  can  be  assumed equivalent to  the
 hydraulic detention time and  is calculated by dividing the internal volume
 of the pipeline by the peak hourly flow rate through the  pipeline.   In
 mixing  basins  and storage  reservoirs,  the  hydraulic  detention  time
 generally does not represent the  actual  disinfectant contact time because
 of  short circuiting.    The contact  time  in  such   chambers  should  be
 determined  by  tracer  studies or an equivalent demonstration.   The  time
 determined from the tracer study  to  be used for calculating  CT  is T10.  T,0
 represents  the time that  90 percent  of  the  water  (and  microorganisms
 within the water) will  be exposed to disinfection within the disinfectant
 contact  chamber.   Guidance  for determining  detention  time  in  contact
 chambers is provided in Appendix C.
       The residual disinfectant  concentration  should  be measured daily,
 during peak hourly flow,  for each disinfectant section prior to the first
 customer  in  the  distribution   system.    Unless a system   knows  from
 experience  when  peak  flow will  occur,  a system can only  identify  peak
 hourly flow after  it has occurred.   Therefore,  EPA suggests that residual
measurements be  taken  every  hour.   If  it  is  not practical  to take  grab
 samples each hour,  the  system may take grab samples during the  period peak
 flow  is  expected  to  occur,  or  continuous monitors may  be  used.   The
measurements taken during  the  hour of  peak  flow  can  then  be  used  to
 determine the  CT for each  section  (CTcau).   The determination of CTs is
 explained in Section 3.2.1.
      Although  the inactivation  maintained in the  system  is determined
 during peak hourly flow,  the disinfectant dosage  applied to maintain this
 inactivation may  not  be necessary  under lower  flow conditions.   Under
 lower  flow  conditions,  a higher  contact time  is generally available and
 the CT needed  to meet  the  required inactivation may be met with a lower
 residual concentration.  Continuing to  apply a disinfectant dosage based
 on the peak hourly flow may provide more  disinfection  than is needed,
 increasing  costs and possibly resulting  in  increased levels of disinfec-
 tant by-products.  However,  the  system  should also  maintain the  required
                                   5-15

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 inactivation levels at non-peak hourly flows.  The system should therefore
 evaluate the dose needed to provide the CT necessary for maintaining the
 required inactivation  under different flow conditions and set the dosage
 accordingly.   The  following  example provides  guidelines  for determining
 flow ranges and disinfection levels to maintain the required disinfection.
      Example
      A  20-mgd  direct filtration  plant applying  free  chlorine  as  a
 disinfectant has a  contact time of 27.5 minutes under  peak  flow condi-
 tions.  As  noted  in Section  5.3,  well-operated direct filtration plants
 achieve 2-log  Giardia  cyst removal  and  1-log  virus  removal.   Therefore,
 disinfection   for   1-log   Giardia  cyst  inactivation  and  3-log  virus
 inactivation is recommended.  The pH  and  temperature  of  the  water are 7
 and 5 C,  respectively.   Using  Table 1-2, a CT of 55 is  required to achieve
 1-log Giardia  cyst  inactivation at  a  residual  of 2  mg/L.   This level of
 treatment  is  more   than   adequate  for  3-log  inactivation  of  viruses
 requiring a CT of 6, as indicated in Table E-7.  However, under low flow
 conditions the available contact time is longer, and lower residuals are
 needed to provide the same  level of inactivation. Based on the calculated
 contact time under  various flow rates  and  the CT  values  in  Table E-2,
adequate disinfection  would  be  provided by  maintaining  the  following
chlorine residuals  for the indicated flows:
                                      CT90
                                                      Free Chlorine
                                                      Residual frog/L)
                                                          2.0
                                                          1.5
                                                          1.0
                                                          0.5

      CT90  corresponds  to  a 1-log  inactivation.  If a different level of
 inactivation were needed,  CT  values  for that  inactivation would be read
 from the tables corresponding to the pH and temperature of the water.
            Section 3.2.2 lists the percent inactivations  corresponding to
            log inactivations, i.e., 0.5-log equals 68 percent requiring
            CT68.
                                  5-16
Flow fMGD)
20
15
10
5
Contact
the (min}
27.5
36
54
108
(mg/L-min)
Required
55
52.5
50
47

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             In cases where the residual, pH or temperature of the water is
             an  intermediate value  not  reported  in  the tables,  linear
             (straight-line) interpolation may be used.                        I

             For example, in the above  listing, 0.5 mg/L residuals are not
             included  in  the  Appendix  E  tables.    The  CT90  value  was
             determined by interpolating between  the <0.4 mg/l value of 46
             mg/L-min and the 0.6 mg/l value of 48 mg/L-min.

             CT values for intermediate pH and temperature values may also
             be interpolated; or

             The CT values for  the higher pH or lower temperature listed in
             the table may be used instead of interpolation.

             CT99 9  tables  in the SWTR can  be used  to  calculate  the CT
             required to achieve any log inactivation by:

                               log inactivation
                  CTrequired =     required     x CT,, .
                                   3.0 log


      The  variation in  CT required  with  respect  to  the  residual  for

chlorine makes it  impractical  for  the utility to continually change the

disinfectant dose as the flow changes.  Therefore, EPA suggests that the

flow variation  at  the utility  be  divided  into ranges  and  the residual

needed at the higher flow of the range be maintained  for all flows within      '

the range to assure adequate disinfection.  The  following flow ranges and

residuals at the given pH and temperature are suggested for this plant:

                                          Free Chlorine
             Flow Range  fMGD)              Residual fmg/U

                  5-10                          1.0
                  10-15                         1.5
                  15-20                         2.0


      In this way,  the utility is assuring the provision of the required

disinfection while minimizing the disinfectant costs and possibly lowering

disinfection by-products.

      Although these  residuals will  meet the required CT, maintaining  a

residual in  the distribution system must also be considered.   If there  is

no  other point of  disinfection prior  to the  distribution  system, the

residual for disinfection must be  maintained at a level which will  also


                                   5-17

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provide a residual throughout the distribution system.  The complete range
of  flows  occurring  at the plant should be evaluated  for determining  the
required  residual.  The utilities may establish the residual needs for as
many  flow ranges  as  is practical.
      The Primacy Agency  should make periodic checks  to assure that  the
utility  is  maintaining adequate disinfection at both peak  and non-peak
flow  conditions.
      In  contrast to  this close control  of disinfectant addition and CT
monitoring,  for  filtered  systems  which  have  long  detention  times  and
regularly exceed  the  CT requirements for the inactivation needed, it  may
be  unnecessary  for the system  to  calculate CTs each day  of operation.
Unlike  unfiltered systems where  CTs must  be  calculated each  day,  for
filtered  systems, monitoring  the residual at the end of the contact time
may be sufficient to indicate that  the required disinfection is provided.
However,  this results in  much higher CTs  in the summer than is needed,
which adds  to.costs  and  possibly  unnecessary  increased  production of
disinfection by-products.   The following example outlines one scenario for
which this would  apply.
      Example
      A utility  disinfects with chlorine ahead of a  reservoir prior to
direct filtration.   The Primacy Agency may  give a  well-operated direct
filtration plant  credit  for 2-log Giardia  cyst removal  and  1-log virus
removal.   Therefore,  1-log  Giardia  cyst  and  3-log  virus  inactivation
through disinfection  is  needed.   For free chlorine, the  CTs  for 1-log
Giardia cyst  inactivation exceed the  CTs  for  3-log  virus inactivation.
Therefore, CTs for Giardia cyst  inactivation are the  controlling CTs.  The
following water quality conditions occur in the reservoir during the year:
            pH                                  7 - 7.5
            Temperature (° C)                   5-20
            Chlorine  residual (mg/L)            0.2 - 0.8
The required CT for chlorine  increases with:
            increasing residual,
            increasing pH, and
            decreasing temperature

                                  5-18

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       Thus,  for  a  residual of 0.8 mg/L the CT needed for a 1-log Giardia
cyst  inactivation  is as follows:                                              I

      fiH                Temperature (C\               mg/L-min
       7.5                      5                      58 (Table E-2)
       7                       20                      18 (Table E-5)

      Tracer  studies  conducted  on the reservoir  indicated  a T10  of  150
minutes at the system's maximum flow.  For the maximum CT of 58 mg/L-min
required,  the minimum residual  needed to'meet this  requirement  is  0.4
mg/L, calculated as:
                        58 mo/L-min = 0.4 mg/L
                          150 min

At a  residual of 0.4 mg/L, CT90  is 55 mg/L-min.  Thus, any residual >0.4
mg/L  will  provide  the needed disinfection  throughout the year  and  the
Primacy  Agency  may  require  the  system to  report  only the  residual
maintained,  reducing the  effort  needed to  determine effective disinfec-
tion.  Maintaining this  residual in the summer,  however,  provides much       i
higher CTs  than  needed,  possibly  resulting  in  unnecessary  costs  and
increased disinfection by-products.
      Meeting the  Recommended Inactivation Using Free Chlorine
      As previously indicated in Section  3.2.1,  the effectiveness of free
chlorine as a disinfectant is influenced by both the temperature and pH of
the water  and by  the  concentration of  chlorine.   The  inactivation  of
Giardia  cysts by  free chlorine at  various  temperatures  and  pHs  are
presented in Appendix E (Table E-l through  Table E-6).  The CT values for
the inactivation of viruses by free chlorine are presented in Table E-7.
      To determine whether a  system is meeting these inactivations,  the
free chlorine residual, pH and temperature  must be measured,  at one point
or several points  prior to the  first customer, where contact time(s)  is
measured.  The contact time  should  be  determined  from  the  point  of
application  of  the disinfectant  to  the  point(s) where  the  residual  is
measured  for determining  CTs  prior  to the first  customer.    The  CTs
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actually achieved  in the system should then be compared to the values  in
the  table  for the  pH  and  temperature of  the  water  at the point(s)  of
residual measurement.   Guidance on  calculating  the  CT for chlorine  is
presented  in  Section 3.2.1.
      Meeting the  Recommended Inactivation Using Chlorine Dioxide
      CT values for the inactivation  of Giardia cysts by chlorine dioxide
are  presented in  Table  E-8  and the CT  values  for the  inactivation  of
viruses are presented  in Table E-9.  As shown in Tables E-8 and E-9,  the
only  parameter  affecting  the  CT  requirements  for chlorine  dioxide  is
temperature.  However,  the  disinfection efficiency of chlorine dioxide may
be significantly increased at higher pHs.  Since the CT values in Tables
E-8 and E-9 were based on  data at pH 7 and 6, respectively, and chlorine
dioxide appears to be more  effective  at higher pHs, systems with high pHs
may  wish  to  demonstrate that  CT  values  lower  than  those  presented  in
Tables E-8 and E-9 may achieve the desired level of inactivation.
      Chlorine dioxide residuals are short-lived.  Therefore, sampling and
residual analysis at various points in the treatment process downstream of
the point of  application may be necessary to establish the last point at
which a residual  is  present.   Subsequent sampling and residual analyses
conducted upstream of this  point can be used to determine  the CT credit by
using the demonstrated detention time between the point  of application and
the sampling location.  Methods for calculating CT values  are presented in
Section 3.2.  Systems using chlorine  dioxide  may  conduct pilot studies to
demonstrate effective  disinfection  in  lieu of  calculating CT,  or  for
determining that lower CT values than those in Appendix  E are appropriate.
Guidelines  for conducting  these studies are presented  in Appendix G.
      Meeting the  Recommended Inactivation using Ozone
      CT values  for  the  inactivation  of  Giardia cysts  by   ozone  are
presented in  Table E-10 for various temperatures and inactivation rates.
As indicated  in this table, the CTs required for inactivation with ozone
are  substantially  lower than  those  required  for  free chlorine.   This
reflects the  fact  that ozone is  a more  powerful  disinfectant.   The CT
requirements  for inactivation of  viruses  using ozone are presented in
Table E-ll.   In cases  where only a 1-log or  lower  Giardia cyst inactiva-
tion  is needed,  the  CT values  for virus  inactivation  may be higher than
                                   5-20

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the  CTs  for Giardia cysts.  Because  of  the reactivity  of ozone,  it  is
unlikely  that  a residual  will  exist  for  more than a few minutes.  As  a
result, the application of a persistent disinfectant such  as  chlorine  or
chloramines is  needed  to  maintain  the required  disinfectant  residual  in
the distribution system.   Guidance for calculating CT values for ozone  are
presented in Section 3.2.1 and  Appendix 0.   In lieu of calculating the  CT
for an ozone contactor or  demonstrating that  lower CTs are effective,  the
disinfection  efficiency  can be  demonstrated through pilot  studies  as
presented in Appendix G.
      Meeting the Recommended Inactivation Requirements using  Chloramines
      CT values for the inactivation  of Giardia  cysts by chloramines  are
presented in Table  E-12.   The  high CT values associated with the use  of
chloramines may be  unachievable  for some  systems.    In these  cases,
chlorine, ozone, or chlorine dioxide should  be used for primary disinfec-
tion, and chloramines  for  residual disinfection,  as necessary.  Table E-13
presents CT values  for the inactivation of viruses with chloramines.  This
table is  only applicable for indicating virus inactivation efficiencies if
chlorine is added  prior to ammonia.   Systems which  add  ammonia prior  to
chlorine  or  ammonia   and  chlorine  concurrently,   can  determine  viral
inactivation efficiencies  using  the  protocol given   in  Appendix  G.   For
systems applying chloramines to meet the virus inactivation requirements,
EPA recommends  that they  also  monitor for  HPC in the finished water,  as
presented  in   Section 5.6.    Systems also  may demonstrate  effective
disinfection with chloramines  in lieu of calculating CT, or to determine
that lower CT values than  those indicated in Appendix E are appropriate.
The protocols outlined in  Appendix G can be  used for this demonstration.
Further guidance on chloramines is given in  Section  3.2.1.
      Meeting the  Inactivation Requirement
      Usiny Ultraviolet (UV^ Radiation
      Ultraviolet  radiation is  a  method of disinfection which  can  be
applied to meet the virus  inactivation requirements  of the SWTR.
      UV  disinfectant dose,   expressed  in  terms  of  UV  intensity  and
exposure time/unit  area (mW-sec/cm2)   incorporates the elements of the CT
concept and therefore can  be considered as analogous  or equivalent to a CT
value.   UV  disinfection   usually  employs  commercially  available units

                                   5-21

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 designed  to  deliver  doses of  25 to  35  mW-sec/cm2.    The  dose  can  be
 increased by  reducing water flow rate and/or by adding  additional units in
 series.    UV  disinfection efficiency  differs  from  that  of  chemical
 disinfectants in  that  it  is  not affected  by  water temperature.   UV
 radiation does not effectively penetrate solids and is  absorbed by certain
 dissolved  substances.   Therefore,  turbidity and  other water  quality
 factors are  important determinants of UV disinfection efficiency,  and UV
 should be applied  after turbidity removal.
      CT  values for  the   inactivation of  Giardia cysts  by UV are not
 included in Appendix'E.  The results  of two studies (Rice and Hoff,  1981;
 Carlson e_t il,  1985)  indicate that Giardia cysts are extremely resistant
 to  inactivation  by  UV with doses  greater than 60 mW-sec/cm2 causing less
 than  80%  inactivation.   Because  UV  appears  to  be very  ineffective for
 Giardia cyst  inactivation  and  in the absence of sufficient data showing
 the doses needed to inactivate 0.5 to 3.0 logs of cysts, UV must be used
 in combination with other  disinfectants to provide evidence of effective
 cyst  inactivation.
      CT values  for the inactivation of viruses  by  UV are presented in
 Table £-14.  Units used for UV  disinfection should be  equipped with  fail-
 safe devices that will provide automatic shutdown of water flow  if UV dose
 decreases to  levels lower  than those specified in Table E-14.
      Meeting the  Inactivation Requirement Using Alternate Disinfectants
      For system using  disinfectants other  than chlorine,  chloramines,
 chlorine dioxide, or ozone, the effectiveness of the disinfectant can be
 demonstrated using the protocol  contained  in  Appendix  G.  The protocol in
 Appendix G.3  for batch  testing should be  followed  for any disinfectant
which can be prepared  in an aqueous solution and will be stable throughout
 the testing.   For disinfectants  which  are not  stable,  the pilot  study
 protocol outlined  in Appendix G.4 should be followed.

      Examples for Determining the Disinfection to be Providej)

      1)    Recommended  0.5-1og  Giardia.  2-1og  Virus  Inactivation
      A community  of  70,000 uses a  river as  its drinking water source.
 Ozonation prior  to a conventional treatment  plant is used  to  treat the
                                  5-22

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water.  The source has a protected watershed with limited human  activity
and no sewage discharge.   The river water has the following water quality
characteristics:
            Turbidity                             10 - 200 NTU
            Total estimated Giardia cyst level     <1/100 /I
            pH                                    7.0 - 7.5
            Temperature                           5-15
      The treatment plant  has  a  design  capacity  of  15  mgd and treats  an
average flow  of 10 mgd.   A three chamber ozone contactor  precedes  the
rapid mix.  Alum and polymer are added as a coagulant and coagulant aid,
respectively.   The  finished water turbidity at  the  plant is  maintained
within the  range  of  0.1  to 0.2 NTU.  Chloramines are  applied after  the
filters, but prior to the clearwells,  to maintain a residual entering  and
throughout the distribution system.
      Based on  the raw  water quality  and  source water  protection,  an
overall  3-log  Giardia  cyst   and  4-log virus   removal/inactivation  is
appropriate for  this  water source.   However,  as noted  in  Section  5.3,
Primacy Agencies may credit well operated conventional filtration plants
with 2.5-log  Giardia  cyst removal and  2-log virus  removal.   Therefore,
disinfection for 0.5-1og  Giardia  cysts and 2-log viruses is recommended to
meet the overall treatment  requirements of the SWTR.
      On the day of this  example calculation, the peak hourly flow rate of
the plant was  13 mgd.   The  contact  time  of the ozone basin, T10 determined
from tracer study data is 6 minutes for  this  flow.  The water  had a pH of
7 and a temperature of 5  C  on the day of  the calculation.   For  ozone under
these conditions of pH and  temperature,  the following  CTs are needed for
the required inactivation  (Tables  E-10,  E-ll):
                  0.5-log  Giardia                2-log  virus
      CT                 0.3                         0.6

The CT  values indicate  that  viruses are  the  controlling parameter  for
disinfection  and  the  overall  inactivation provided  will be calculated
based on  viruses.  The overall virus inactivation provided by the ozone
contactor is determined  as follows:
           Average
                                   5-23

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            Residual    '    T,0      CT..lie      CT99 9       CT.llc/CT99 9
 Chamber     C  (mg/L)      (minutes)   fm'g/U     (mg/L-min.l	
    1          0.1            2         0.2        0.9            0.22
    2          0.2            2         0.4        0.9            0.44
    3          0.2            2         0.4        0.9            0.44

The sum of CTcalc/CT9g 9 is  1.1.  This corresponds to more than a 3-1og virus
inactivation  determined as 3 X CTC1|C/CT39 9 » 3 X 1.1 « 3.3-log. Therefore,
the system exceeds  the  recommended  inactivation.
      2)    Recommended  l-1og Giardia Cvst. 2-log Virus  Inactivation
      A 2 MGD slow sand filtration plant  treating  reservoir water, fed  by
mountain streams with no  nearby wastewater  discharges, provides  drinking
water for a community of 8,000 people.   The water quality  at the intake
has the following water  quality characteristics:
      Turbidity                                 5-10 NTU
      Total coliforms                           Not measured
      Total estimated Giardia cyst  level        <1/100 L
      pH                                        6.5 - 7.5
      Temperature                               5 - 15 C

      The filtered water turbidity ranges  from 0.6 - 0.8 NTU.  Considering
the source water quality  and  plant  performance, an overall  3-log Giardia
cyst and  4-log  virus removal/inactivation  is  considered sufficient for
this system.  As  noted in Section  5.3,  the Primacy Agency may credit  slow
sand plants with 2-log  Giardia cyst and  2-log virus removal.  Therefore
disinfection  for  1-log  Giardia  cyst  and  2-log  virus  inactivation  is
recommended for the system  to meet  the overall treatment requirements.
      Chlorine is added prior to  the clearwells to provide  disinfection.
The clearwells have a capacity of  80,000  gallons.   A one  mile, 16-inch
transmission  main transports  the  water from the  treatment plant to the
first customer.   The inactivation  provided is  determined  daily for the
peak hourly   flow conditions."  Tracer studies  have been  conducted  to
determine the T10  for the clearwells for different flow rates.   For the
purposes of calculating the inactivation the system is divided  into two  sections.
      Section 1 - clearwell
                                   5-24

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      Section 2 - transmission main
      The flowrate at peak hourly flow from the clearwell  was 1.5 mgd on
the day of this example.   At  this flowrate, the T,0 of the clearwell is 67
minutes, as determined from the results of the tracer studies.    At this
flowrate, water travels through the transmission main at 99 ft/min.  The
data for the calculation of the inactivation is as follows:
                                  Section 1          Section 2
length of pipe (ft)                   0                5280
contact time (min)
      pipe                            0                  53
     basin                           67                   0
     total                           67                  53
disinfectant                      chlorine            chlorine
residual (mg/L)                     1.0                 0.6
temperature C                         55
       pH                           7.5                 7.5

For free chlorine,  a  1-log Giardia cyst inactivation  provides  greater than
a 4-log virus  inactivation;  therefore,  Giardia cyst inactivation is the
controlling parameter, and the inactivation provided is determined based
on Giardia cysts.  The calculation is as follows:
      Section 1 _ - Chlorine
      CT,m =  1.0 mg/L x 67 minutes * 67 mg/L-min
      From Table E-2, at  a  temperature of 5 C and a pH of 7.5,  CT55 9 is
      179 mg/L-min
      CTcau/CT99 a  B   67 mg/L-min *  0.37
        w               179 mg/L-min
      Section 2  - Chlorine
      CTC|U =   0.6 mg/L x  53 minutes = 32 mg/L-min
      From Table E-2, at  a  temperature of 5 C and a pH of  7.5,  CT39 9 is
      171 mg/L-min
      CTC1U/CT99 9 »   32 mg/L-min.'  0.19
                        171 mg/L-min

The sum  of CTcllc/CT99 9  is equal  to 0.56. This  is equivalent  to  a  1.7-log
Giardia  cyst  inactivation determined as  3-log  x CTcllc/CT99 9  « 3 x  0.56  =
                                   5-25

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 1.7-logs.  Therefore, the system exceeds the disinfection recommended to
 meet the overall treatment requirements.
      3)    Recommended 2-1og Giardia Cvst. 4-log Virus Inactivation
      A  community  of 30,000 people  uses  a reservoir  treated  by direct
 filtration «for  its  water  supply.   The  reservoir  is  fed by a river which
 receives the discharge from a wastewater treatment plant 10 miles upstream
 of the reservoir.   The reservoir water quality is as follows:
      Turbidity                           5 - 15 NTU
      Total coliforms                     100 - 1000/100 ml
      Total estimated Giardia cyst level  5/100 L
      pH                                  6-7
      Temperature                         5 - 15 C
      Based on the  source water quality, an overall  removal/inactivation
of 4-log  Giardia  cyst  and 5-log  virus is  recommended as  outlined in
Section 4.4.
      The source water flows  by  gravity  to  a 3 MG storage reservoir prior
to pumping  to the  water  treatment  plant.   Chloramines  are produced by
first adding  chlorine then ammonia  to  the  water  within the inlet of the
storage reservoir.  Chlorine  dioxide is  added to  the filtered water prior
to the  clear-wells.   Chloramines  are  applied after  the  clearwells to
maintain a residual  in the distribution system.  The  system design flow is
8 mgd with an average flow of 5 mgd.  For the calculation of the overall
inactivation,  the system is divided into 2 sections.
      Section 1 - the storage reservoir and the transmission to the
            treatment plant
      Section 2 - the clearwells

      The overall  inactivation  for the system is computed daily at the
peak  hourly   flow  conditions.    The pH,  temperature,  and disinfectant
residual is measured at the end of each section prior to the next point of
disinfectant application and  the first  customer.   The  flow  is measured in
the transmission main entering the plant and exiting the clearwells.  On
the day of this  example calculation, the peak hourly flow was 6 mgd  in the
transmission mains  entering and  leaving the plant.   If the  flowrates were
different, the T,0  corresponding  to  the  respective flowrate  would be used
                                  5-26

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 in  the calculation.   Guidance  for determining CTs when  flowrates  vary

 within  a  system  is  given  in Section 3.2.  The water velocity through the

 20-inch  transmission main  is  256 ft/min at  a flow  of  6 mgd.   Tracer
 studies  were conducted  on the  storage reservoir  and  clearwells.    As
 determined  from  the testing the  detention times, T,0,  of* the basfns  at a

 flow  of 6  mgd  are  380  and  130 minutes  for  the storage  reservoir and

 clear-wells, respectively.  The data for the calculation of  inactivation is
 as follows:

                            Section 1                    Section 2

 length of pipe (ft)  •          4500                         0
 contact time  (min)
      pipe                       18                         0
     basin                      380                       130
     total                      398                       130
disinfectant                chloramines               chlorine dioxide
 residual  (mg/L)                 1.5                       0.2
temperature C                     5                         5
pH                                7                         7


      For each of the disinfectants used, the following CTs are  needed for

2-log Giardia and  4-log  virus  inactivation for the  pH  and temperature

conditions of the system.

                                  CT for 2-log         CT for  4-log
                                    Giardia                Virus

chloramines                          1430                  1988

chlorine dioxide                        17                    33.4


      The CT  required  for the virus  inactivation  is higher  than  that

needed for Giardia  inactivation for each of  the disinfectants.   Since the

viruses are the controlling parameter,  the  inactivation calculation will

be based on the viruses.   The calculation is  as  follows:

      Section 1   -  Chloramines

      CTcllc » 1.5 mg/L x  398 minutes «  597 mg/L-min

      From  Table  E-13,  at a temperature of 5 C  and a pH  of 7, CT99 99  is
      1988 mg/L-min

      CTc.ic/CT99  99 •   597 mq/L-min »  0.3

                                   5-27

-------
                         1988 mg/L-min
       Section  2   - Chlorine Dioxide
       CT.alc =  0.2 mg/L x 130 minutes = 26 mg/L-min
       From  Table  E-9,  at a temperature of 5  C  and  a pH of 7, CT39 99 is
       33.4  mg/L-min
       CT:au/CT99 99 s   26   mp/L-min = 0.78
                       33.4 mg/L-min

The sum of CTC4U/CT9999 is equal to 1.08,  which is  equivalent to a 4.3-log
inactivation of viruses, determined as follows:
                x = 4-log x  crca1c  =  4  x  1.08  =  4.3-1ogs
                             CTg9  99

Therefore, the system provides  sufficient disinfection to meet  the overall
recommended treatment performance.

5.6   Other Considerations
      Monitoring  for heterotrophic  plate  count  (HPC)  bacteria  is not
required  under the  SWTR.   However,  such monitoring may  provide  a good
operational tool for:
            Measuring microbial breakthrough
            Evaluating process modifications
            Detecting loss of water main integrity
            Detecting bacterial regrowth conditions within the distribu-
            tion system
            Determining interference with the coliform measurements  (AWWA,
            1987)

      Therefore,  EPA  recommends  routine  monitoring  for HPC in the  plant
effluent  and   within  the  distribution system  whenever  the  analytical
capability  is  available  in-house or nearby.   Systems  which  do not have
this capability should consider using a semi-quantitative bacterial  water
sampler kit, although this  is  not  acceptable  for  compliance monitoring.
                                  5-28

-------
      As discussed  in the preamo,e to the SWTR, EPA believes that  it  is
inappropriate to include HPC as a treatment  performance  criterion  in  the
rule since small systems would  not have in-house analytical  capability to
conduct the  measurement,  and  they would need  to  send  the  samples to  a
private laboratory.   Unless  the analysis is conducted  rapidly, HPC  may
multiply and the results may not be representative.
      EPA recommends an  HPC level of less than  10/ml in the finished water
entering the distribution system and levels of  less than 500/ml  throughout
the distribution system.
      Legionella is another organism which is not included as a treatment
performance criterion.  Inactivation information on Legionella is limited.
EPA  believes that  treatment which  complies with the  SWTR will  remove
and/or inactivate  substantial  levels of  Legionella which might  occur in
source waters,  thereby  reducing chances that  Legionella will  be  trans-
ported through the system and reducing the  possibility that growth might
occur in the distribution system or hot water  systems  within  homes  and
institutions.  Since Legionella are similar  in  size to coliform organisms,
removals by  filtration   should  be similar   to  those  reported  for total
coliforms.   In addition,  the available disinfection information indicates
that the CT  requirements for inactivation   of  Legionella are  lower than
those required  for the  inactivation  of Giardia cysts.   EPA recognizes,
that  regardless  of  the  treatment provided,  some  Legionella  may enter
plumbing and air conditioning systems and subsequently multiply  (Muraca et
al., 1986).  EPA believes that these concerns are best addressed through
guidance contained  in Appendix B.
                                   5-29

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                              6.   REPORTING
6.1   Reporting Requirements for Public Water Systems
      Not Providing Filtration
      The SWTR requires unfiltered systems  to prepare monthly reports for
the Primacy Agency to determine compliance with the requirements for:
            source water fecal and/or total coliform levels
            source water turbidity levels
            disinfection level
            disinfectant residual entering the distribution system
            disinfectant residuals throughout the distribution system.

      The monthly reports must be  prepared and submitted  to the Primacy
Agency  within  10 days  after the  end  of  the  month.   The  utility  must
maintain a daily or monthly  data  log  used to prepare the monthly reports.
Tables  6-1  through  6-5 are  examples  of  daily data  sheets which  the
utilities may find useful for logging the  data needed to prepare reports
for the Primacy Agency.
      Table 6-6 presents a concise format which can be used by the system
for the monthly  reports  to  the Primacy Agency.  Tables  6-3 and 6-4 must
also be submitted with  the  monthly report.  After  the initial 12 months
of reporting,  the Primacy Agency  may  remove the requirement for reporting
the information contained in Table 6-3  if it  is satisfied that the system
is  computing  compliance  with   the  CT  requirements  correctly.    The
individual sample results summarized  in the monthly  reports  should be kept
on file at the utility for  a minimum of 5  years.
      In addition to the monthly reporting requirements for source water
quality conditions and disinfection information, systems with unfiltered
supplies  are  also required  to submit  annual  reports for  the watershed
control program and the on-site inspection, within 10 days after the end
of the federal fiscal year.
      The Primacy Agency will review the  reports to determine whether the
system  is  in  compliance.   A possible  report  format for  the watershed
control program  is:
                                   6-1

-------
      1.    Summarize all activities in  the watershed(s) for the previous
            year.

      2.    Identify  activities  or  situations  of  actual  and  potential
            concern in the watershed(s).

      3.    Describe how the utility is  proceeding  to address activities
            creating potential health concerns.


      EPA recommends that the Primacy Agency submits the annual  watershed

reports to the State Water Quality Managers.   The reports will  be useful

in updating statewide assessments and management programs.

      The SWTR requires each system to provide the  Primacy Agency with a
report of the  on-site  inspection unless the inspection is conducted by the
Primacy Agency.  EPA suggests that:

      1.    A report of the inspection containing the findings,  suggested
            improvements and dates  by which  to complete  improvements is
            to be prepared following the initial  system review.  When and
            how system has  resolved  problems  identified  in the previous
            report should also be included.

      2.    To lessen  the burden on utilities,  a report containing results
            of the general  survey should be submitted in subsequent years.


      In addition to these reporting requirements, the SWTR requires that

the reporting  requirements of the Total  Trihalomethane Regulation and the

Coliform Rule also be met.

      Records  of  waterborne disease outbreaks  also  must  be maintained.

In the event  &f a  waterborne disease outbreak, as  defined in part 141.2

of the SWTR,  the  Primacy  Agency must be notified by the  end of the next

business day.
      The report of the outbreak should contain:

      1.    Date of occurrence
      2.    Type of illness
      3.    Number of cases
      4.    System  conditions  at  the   time  of the  outbreak,  including
            disinfectant  residuals,  pH,  temperature,  turbidity,  and
            bacteriological  results.


      The records of an outbreak should be maintained permanently  or until

filtration is installed.


                                   6-2

-------
6.2   Reporting Requirements for Public Water Systems  Using  Filtration


      The SWTR requires filtered water systems to submit  monthly  reports
to the Primacy Agency  for  determination  of  compliance with  the  require-
ments for:

            treated water turbidity
            disinfectant residual entering the distribution  system
            disinfectant residuals throughout the distribution system


Tables 6-7 and 6-8 present a format which the utility  can use as  a daily

data log and to submit monthly reports to the Primacy  Agency.

      Recommended Reporting Not Required by the SWTR

      The Primacy Agency may  also  want  filtered  water  systems to report

some information  associated with recommendations made in this manual which
are not  requirements  of the  SWTR.   EPA recommends that  filtered water

systems:


      1.    Report the  log inactivation  of Giardia cysts  and  viruses,
            required by the Primacy Agency.

      2.    Report point of application for all disinfectants used.

      3.    Report the daily CT(s)  used  to calculate the log inactivation
            of Giardia cysts and viruses.

      4.    If more than one  disinfectant  is  used,  report the CT(s) and
            inactivation(s) achieved for each disinfectant and the total
            percent inactivation achieved.

      5.    Note  any  difference between  the  measured CT(s)  and  the CT
            required to  meet  the  overall  minimum treatment performance
            requirement specified  by the Primacy Agency.


Tables 6-3  and 6-4 can  be used  to  maintain the  records necessary for

numbers 2 through 5.
      This  information  can be used  to  determine the  disinfection  level

maintained by the system to assure that  the overall removal/inactivation

required  is maintained.
                                   6-3

-------
      The Primacy Agency  may make provisions to minimize  the  reporting
requirements for systems with reservoirs, large amounts of storage or long
transmission mains which  provide a long  disinfectant contact time.  Since
these systems typically provide  inactivation in excess of that needed, the
Primacy Agency may  require  the  system only to report the  minimum daily
residual at the end  of the disinfectant contact time.   The CT maintained
can then be  estimated based  on  this  residual  and  the  contact time under
the system design flow.   This method  of CT determination  will  eliminate
the need for the system to determine the contact time  under maximum flow
conditions each day.
                                   6-4

-------
Month .
Year
                                                 	TABLE  6-1	
                                                                                           1
                       SOURCE WATER QUALITY CONDITIONS FOR UNFILTERED SYSTEMS
                                          (For system use only)
System/Treatment Plant.
PWSID	
                                                                                                    TjrbiO:r\ \Icjs.r;
                                                                                                        3
                              Coliform Measurements
                                                                                              Maximum
1 i
Date '
No.
Fecal
of Samples

1 :
-i i
Total
No
Fecal( < =

ol' Samples Meeting Specified
20/100 mL)

Total ( < =
Limits
100/100 mL)
Turbidity E..
iNTUI ••.. -

i
 10
 12
 13
 15
 25
• 23
29
30
31
1
Totals '











1
1
i
Maximum daily :-:?., • =
Total number of :-:- - - - -
Notes-
         Samples are taken from the source water immediately prior to the first disinfection point included in the CT deter-
         As specified in 40 CFR 141  74(b)(l), a fecal or total coliform sample must be taken on each day that the
        system operates and a source water turbidity measurement exceeds 1 NTU.
         For each day that the maximum turbidity exceeds 5 NTU. the date should also be entered for the day that the Sta:j
        of this exceedance. e.g., "7 3-22 Apr"
         A "yes" response is  required each day the  maximum turbidiry exceeds 5 NTU and the previous day did not   Th.s
        of the beginning of a rurbidity "event"  The :otaJ  nunber of ">es" responses equals the number of turbidity   cse--

-------
	TABLE 6-2	
1.ONG-TERM SOURCE WATER QUALITY CONDITIONS FOR
               UNFILTERED SYSTEMS
                 (For system use only)
Year


Systern/Treaiment Plant
PWSID



Coliform Measurements
i No of Samples
Month Fecal Total
January i
February
j
March
April ;
May
No oi Samples Meeting Specified Limits
FecaiK = 20.100 nL)



Total (< = 100/100 mL)


i
i


Turbiditv Measjrer.^r.rs
Days with N^i-rcr .,
Turbidity T-rru.^
>5STU E.^:.:,




i
i
June <
-•-:,
August
i
Ssptenoer
Octooer
NoemDer
December :
-.










1

                                                     Total

-------
                                                          TABLE  6-3
CT DETERMINATI
Month
YSMT
ON FOR UNFILTERED SYSTEMS -- MC
System/T realm
PWSID
Disinfectant/Sequence of Application
i
! Disinfectant
j Concentration.
Date ' C (mg/L)
1
2 i
3
4
5
6
i
S
3 ,
Disinfectant ! 4
Contact Time. i CTcalc
T (min.) ! (=CxT)
[
1
•
1
!
1.2
>NTHLY REPORT TO PRIMACY AGENCY
ent Plant


3.5
PH





1


9 : i
10

3 i
Water ;
Temp 6
(deg C) CT99 9 ' 'CTcalc CT99 9'.

I
1


i |

1
;
! i
a i
12
13
• 14
is ;
16

1

i
j
1
|
]
17
IS , ;





19
20 i
2!
I
_.
1 «
i I
24 ' I
25
26
2?
25
29
' 30
31
! i
— i i
' i !
i i

'

i
1




Prepared by
Date
^'otes
         1  To be included in the monthly report for it least 12 months after the initiation of reporting.  After that time, the Pr-.rar.
              rr.ay no longer require thi* form.
         2  Use a separate form for each disinfectant/sampling site   Enter disinfectant and sequence position, e.g., "ozone/ i»t  ^r
         3  Measurement taken at peak hourly flow.
         4  CTcalc = C (mg/L) x T (min ).
         5  OnJv required if the disinfectant is free chlorine.
         6  FromTables 1 1 -  1 6. 2 Land 3 1.40CFR 141  •4,t,i3)

-------
                                      	TABLE 6-4	
                                             DISINFECTION INFORMATION
                         FOR UNFILTERED SYSTEMS -- MONTHLY REPORT TO PRIMACY AGENCY
Month
Year
1
Mimnun Dismtwt-ant Residual
at Poim-ot'-Entry to
Date Distribution System !mg/L)
1
2
3
a
5
6
Sysiemn'rcatraent PI
PWSID 	
ant



'CTcaic/CT99 9) (from Table 6-3)
Disinfectant
1st






2nd






3rd






Sequence
4th






5th






i i i
3





6th
1
2 SUM (CTcalc CT99 9' <1
SUM (CTcalc/CT99 9) (YesorN'oi

I !
1




1 1


9 ' : <
:o
1 1












1
> : i i
:• ; ! i
1 i i \
:5



.1 ' !
-









.i :
,y















i
1^ i ! ! !
- • I !
2 - ' ' i
_3








""^ i'ii j
_, ^ : i
15
:*
2 5
19
30
3 i





i



i |



















Prepared by
Due
Votes
        1  If iess than 0 2 mg/L. the lowest level and duration of the period must be reported, e.g., "0.1-3 hrs.".
        2  To determine SUM (CTc4lc/CT99 9), add (CTcalc/CT99.9) values from the firs disinfectant sequence to the last
        3  If SUM .'CTcaic/CT99 9) < 1, a treatment technique violation has occurred, and a "yes" response must be entered

-------
                      	TABLE 6-5	
DISTRIBUTION SYSTEM DISINFECTANT RESIDUAL DATA FOR UNFILTERED AND FILTERED SYSTEMS
                           MONTHLY REPORT TO PRIMACY AGENCY
Month
Year

Date No of Sites Where
Disinfectant Residual
. *as Measured (=4)
;
T ,
1
4
5
o
-
3
9
"-,

i •>
! ;
4
( >
t *1
-
:s
i -i
; y
2C
_ ,
--
_ _*
I-
^ >
26
** "*
:s
29 '
• 30
• 31
Total <3 =
Syjtem/Treatraent Pltnt _
pwsro

No. of Sites Where no - No. of Sites Where
Disinfectant Residual Disinfectant Residual
Measured, but HPC ! Not Detected, no HPC
Measured (=b) | Measured (»c)
i
i
i


'


^












i
i
I
1
I

1

i
1
!
b= 'C =



No of Sites Where
Disinfectant Residual
Not Defected.
HPC > 500/ml( = d)































d =



No of Sires Where
Disinfectant Residual
Not Measured,
HPC > 500nU=e>







i























e =
                                                                 100
                                              Prepared by.
                                                   Date .

-------
                                                      TABLE
 Month .
 Year_
               MONTHLY REPORT TO PRIMACY AGENCY FOR
          COMPLIANCE DETERMINATION -- UN FILTERED SYSTEMS
                  System/Treatment Plant	.	
                  pwsro
  Source Water QuaJiry Conditions
  \  Cumulative number of months for which results are reported
        For source water cohforn  monitoring	;N'o  of months)
        For turbidity monitoring .
                     I
    Coliform Criteria
        Previous 6 months':
        Percentage of samples < •
        Percentage of samples < '
        Is F < 90% '.  Yes:	
                 (No of monthsi
                                          No  of Samples
                                                          No  of Samples Meeting Specified Limits
                                        Fecal
                                    TotaJ
 FecaJ (<» 20/100 mL)
                    Total «=  IOC  ,JGnL,
                                                                             z =
           : 20/100 mL fecal coliforms. F = yw x 100
           • 100/100 mL total coliforms. T = z/x x 100
           No:	N/A	is T < 90% ?• Yes: _
.No:
.N/A:
    Turbidity Criteria
        Maximum turbidity level for reporting (current) month =	NTU
        Enter the month  120 months prior to the reporting month or January 1991 (whichever is later)_
                               Dates of 5 NTU Exceedances Since Latest Month Recorded Above
| Beginning Dace
I
j
i
Duration (days)



Date Reported



 Disinfection Criteria
 •\  Point-ol'-Emrv Minimum Disinfectant Residual Criteria
                                            Davs the Residual was <0 2 mg/L
                              Dav
                           Duration of Low Level (hrs
     Date Reponed
   to Primacy Agency
 B  Distribution S>stem DisinfectanrReiidual Criteria
       The value of a, b. c, d, and t from Table 6-5, as specified in 40 CFR 141 75 (b)(2)(in)(A)-(E)
       a =	b = 	, c  = 	,  d =	, e = 	
                   a + b
       For previous month, V = _____ %

 C  Disinfection Requirement Criteria
<       Record the date and value of SUM (CTcak/CT99.9) for any SUM (CTcalc/CT99.9) < 1 (from Table 6-4):
       If none, enter "none"  	
;                           |   Date    ! SUM (CTcalc/CT99 9)|
                                                                  Prepared by .
                                                                        Date .
 Notes
The current 6-month cumulauves are required to determine whether compliance with the eohform :r
has been achieved. These totals are calculated from   the previoui 6-month cumulative*, the current
month's, and totals from the earliest of 5 previous months.

-------
                                                            TABLE 6-7
                                          DAILY DATA SHEET FOR FILTERED SYSTEMS
                                                        (For iy*era u»e only)
Month .
Year
System/Treatment Plant.
Filtration Technology	
PWSID	
1
Minimum Disinfectant Residual
at Pomt-of-Entry to
Date1 Distribution System (rng'L)
I
i
3
1
Maximum Filtered Water Turbidity
Filter
*



.i |
5
Combined Filter
Effluent
Clearweil
Effluent
Plant
Effluent
3 : 4 5
1 No of Turbidity No ot' Turbidity
No of Turbidity Measurements < =i Measurements
Measurements ! Specified Limit ' > 5 N'T I'
1 !
|
|
!


i
i

!

0 I
"* ! '
3 ;
5 i • ;
:o
i ;

i: 1
13
U


;i i
A \
' J




i i





t
t





!

1
j

                                                                        Totals-
       For  multiple disinfectants, this column mu« only be completed for the la« disinfectant added prior to entering the distribution
       svstem  If less than 0 2 mg/L, the duration of the period must be reported, e.g., "0.1-3 hn".
       For  systems  using conventional treatment, direct filtration, or technologies other than slow sand or diatomaceous earht filtration.
       turbidity measurements may be taken at the combined filter effluent, clearwell effluent, or plant effluent prior to entry into the
       distribution system. The turbidity may also be measured for each individual filter with a separate sheet maintained for each
       For  continuous monitors count each 4-hour period as 1 sample
       Depending on the filtration technology employed, the number of turbidity samples meeting the following levels must be recorded
       conventional  treatment or direct filtration-0 5 NTU. slow sand filtration-1 NTU, diatomaceous earth filtration-1 NTU   The S'ste na>
       specify dlternate performance levels for conventional treatment or direct filtration,  not exceeding  1 NTU, and slow sand :"J:ra:..:n.
       not enceedmg 5 NTU, in which ease the number of turbidity measurements meeting these levels must be recorded
       IP reco'dirg the number of turbidity measurements exceeding 5 NTU. the turbidity values should also be recorded,  eg    ' 5 3  5 2. 3

-------
                                                       T \BLE6-8
  Month .
  Year
                                    MONTHLY REPORT TO PRIMACY AGENCY FOR
                                COMPLIANCE DETERMINATION - FILTERED SYSTEMS
                                 System/Treatment Plant	
                                 Type of Filtration	
                                 Turbidity Limit	
                                 PWSID	
 Turbiditv Performance Criteria
 A   Total number of filtered water turbiditv measurements =
B  Total number of Tillered water turbidity measurements that are less than or equal to the specified limits
   for the  filtration technology employed « ___^_

C  The  percentage of turbidity measurements meeting the specified limits = B/A x 100 = _ / _
                                                                                               100
 D   Record the date and turbidity value for any measurements exceeding 5 NTU' If none, enter "none"
! Date i Turbiditv. NTU
| i
i , 1
1
! '
DjsiRt'ecnon Performance Criteria
\ Pomt-of-Entry Minimum Disinfectant Residual Criteria
: Minimum Disinfectant Residual \ Minimum Disinfectant Residual
'at Pomt-of-Entry ! |at Pomt-of-Entry |
Date to Distribution System (mg/L) • Date 'to Distribution System f rng/L)
i
Minimum Disinfectant Res:;,.*!
iat Pomt-of-Entry
Date to Distribution Svsten — s L
1 ,11 ' ' 21 :
2 ' 12
3 13 j
4 14
5 ; 15
6 16
; 17
S .. 18
9 19 ,
10 20 •
22
23 i
24 i
25
26 ,'
L 27 '
28 '
29 i
30 i
! 3l
Days the Residual *as <0 2 ng L
Day




Duration of Low Level (hrs ) Date Reported to Primacy Agency



1
i
 B  Distribution System Disinfectant Residual Criteria
!       The value of a, b, c. d, and e from Table 6-5, as specified in 40 CFR 141  75 (b)(2)(ui)(a)-(e):
               , b
                           c =
                          *100
                                    d =
                                           _, e =
                 a - b
       For previous month, V
                                                                     Prepared by,
                                                                          Date .

-------
                             7.  COMPLIANCE

7.1   Introduction
      This section provides guidance on when and how the requirements of
the  SWTR  will  go into effect, including determinations made  by Primacy
Agencies.

7.2   SYSTEMS USING A SURFACE WATER SOURCE (NOT GROUND WATER
      UNDER THE DIRECT INFLUENCE OF SURFACE WATERS	
      The SDWA requires, within  18  months  following the promulgation of
a  rule,  that Primacy Agencies  promulgate  any  regulations  necessary to
implement  that  rule.   Under  S1413,  these  rules must be  at  least as
stringent  as  those   required  by  EPA.    Thus,   Primacy  Agencies  must
promulgate regulations  which  are at  least  as  stringent as the  SWTR by
December  30,  1990.   By  December  30,  1991,  each  Primacy Agency  must
determine which  systems  will  be  required  to filter.   If  filtration is
required, it must be installed within 18 months following the determina-
tion or by June 29,  1993,  whichever is  later.   In cases where it is not
feasible  for  a system  to  install  filtration  in  this  time  period,  the
Primacy  Agency  ~ay allow  an  exemption to  extend the  time  period   (see
Section 9).
      If a Primacy Agency fails to comply with  this  schedule for adopting
the criteria and applying them to determine who must  filter, systems must
comply  with  the  "objective"  or  self-implementing  criteria  (i.e.,  the
requirements that are clear on  the face of the rule and do not require the
exercise of Primacy Agency discretion).  Unfiltered supplies must comply
beginning December 30, 1991  and filtered supplies beginning June 29, 1993.
      Monitoring requirements  for unfiltered systems must be met beginning
December 30, 1990  unless the  Primacy  Agency  has already determined  that
filtration is necessary. This coincides with the Agency's requirement to
promulgate regulations for making filtration  decisions by that date under
the SDWA.  Primacy Agencies may specify which  systems should conduct the
monitoring  necessary  to  demonstrate  compliance  with the  criteria  for
avoiding filtration.     For some  systems  where an  historical  data   base
exists, and where it is apparent that the system would exceed the source

                                  7  -  1

-------
water quality criteria (or that some other criteria would not be met, such
as an adequate watershed control  program), no monitoring may be necessary
for  the  Primacy  Agency to determine that filtration is required.   If a
particular  system  (and/or  the  Primacy  Agency)  knows  that  it  cannot meet
the  criteria for avoiding  filtration, there is no reason to require that
system to conduct the source water monitoring prior to the formal decision
by the Primacy Agency  that filtration is required.  This is true because
the only purpose of that monitoring would be  to  demonstrate whether or not
the  criteria to avoid  filtration are being met.
      In reviewing the data for determining which systems must filter, the
Primacy Agency will have to decide  on a case-by-case basis the conditions
which will  require filtration.   For example,  a  system may not  meet the
specified  CT  requirements for  the first few  months of monitoring and
upgrades  its  disinfection  to meet  the CT  requirements   in  subsequent
months.  In this case, the Primacy Agency could conclude that the system
will be  able  to  meet this criterion for avoiding  filtration.   The time
periods  specified  for  in  the criteria  to  avoid  filtration  (e.g., six
months for total coliforms, one year and ten years for turbidity and one
year for CT requirements)  do not  begin  until  December 30, 1991 unless the
Primacy Agc-cy specifies an earlier date.
      Beginning December 30,  1991 the requirements for avoiding filtration
specified  in  S141.7l(a)  and (b)  and the  requirements  of  S141.71(c) and
5141.72(a) go into effect  unless the Primacy Agency already has determined
that filtration  is required.   Beginning December  30,  1991,  if a system
fails to meet  a"hy  one of the criteria for avoiding filtration, even  if the
system were meeting  all  the criteria up to  that point,  it must install
filtration and comply with the requirements for  filtered systems includ-
ing the general  requirements in S141.73  and  the disinfection requirements
in S141.72(b), within 18 months of the failure.  Whenever a Primacy Agency
determines that filtration is  required,  it  may specify interim require-
ments for the period prior to installation of  filtration treatment.
      Following the determination that  filtration is  required, the system
must develop a plan to implement  its installation.  The plan must include
consideration for  the  following:
                                  7 - 2

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            Providing   uninterrupted   water   service   throughout   the
            transition period
            Siting for the future facility
            Financing options and opportunities
            Scheduling of design and construction

Systems which are unable to install filtration within the  specified time
frame  may  apply for  an  exemption to  extend  the period  for  installing
filtration.
      Table 7-1 summarizes the  requirements for  the  SWTR  for  unfiltered
systems noting  conditions which  require  the  installation  of filtration.
It is important to note that only treatment technique violations trigger
the  requirement to install  filtration while violations  of monitoring,
reporting or analytical  requirements do not.  The monitoring requirements
for  unfiltered  supplies are  presented  in  Section  3 and  the  reporting
requirements are presented in Section  6.
      All  systems  with  filtration  in  place  must  meet   the  treatment
technique  requirements  specified  in  S141.73  (filtration  criteria)  and
S141.72(b)   (disinfection  criteria),  and  the  monitoring   and  reporting
requirements  specified  in  S141.74(c)  and  S141.75(b),   respectively,
beginning June  29,  1993.  Table 7-2 summarizes the SWTR requirements for
filtered  systems,   including  conditions  needed  for  compliance  with
treatment requirements.  Monitoring requirements for filtered supplies are
enumerated  in   Section 5  and  reporting  requirements  are  presented  in
Section 6.

7.3   Compliance Transition with Current NPDWR Turbidity Requirements
      The  current   (interim)   NPDWR  for  turbidity  under  5141,13  (MCI
requirements)   and  S141.22  (monitoring   requirements)  will  apply  for
unfiltered  systems  until  December 30,  1991  unless the  Primacy Agency
determines that filtration is required.  In cases where  filtration  is re-
quired, the interim NPDWR applies until June 29,  1993 or until filtration
is  installed,   whichever  is  later.    Unfiltered  supplies  will  also  be
                                  7 - 3

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subject  to  the  turbidity  monitoring  requirements  of  S141.74(b)(2)
beginning December 30,  1990  coincidently  with  the  interim requirements.
Beginning June 29, 1993, the turbidity performance  criteria for filtered
systems  (S141.73),  and the  monitoring  requirements  under S141.74  will
apply.

7.4   Systems Using a Ground Water Source
      Under the Direct  Influence of Surface Water
      Part of the Primacy  Agency's program revisions to  adopt  the  SWTR
must  include procedures for  determining,  for each  system in  the Primacy
Agency served by  a ground water source, whether that  source is under the
direct influence-of surface  water.  By  June 29,  1994 and June 29,  1999,
each  Primacy  Agency  must  determine  which  community and  non-community
public water supplies,  respectively, use ground water which is under the
direct influence  of surface water.  EPA recommends  that these determina-
tions be made  in  conjunction with related activities required  by  other
regulations (e.g., sanitary surveys pursuant to the final coliform rule,
vulnerability assessments pursuant  to the volatile organic chemicals rule,
the forthcoming disinfection requirements for ground  water systems).  In
addition, EPA-approved  wellhead  protection programs   required  under the
Safe Drinking Water Act Section  1428 may contain methods and criteria for
determing zones of contribution, assessments of potential contamination,
and management of sources  of contamination.  These programs  may be used
as a  partial  basis  for the  vulnerability assessment  and  for making tne
determination <5f  (a)  whether a system is under  the  direct influence of
surface water and  (b)  if direct  influence  is determined, whether there is
adequate watershed control  to avoid filtration.  Guidelines  for developing
and implementing  a wellhead  protection  program are found in "Guidelines
for Applicants  for State  Wellhead Protection  Program  Assistance  Funds
under the Safe Drinking Water Act" (U.S. EPA,  1987a).
      A system using a ground water source under  the  influence of surface
water that does not  have  filtration  in place  must begin monitoring and
reporting in accordance with S141.74(b) and S141.75(a),  respectively, to
determine whether it meets  the  criteria for avoiding  filtration beginning
December 30,  1990 or six months after the Primacy  Agency determines tHat

                                  7 -  4

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the ground water source is under the influence of surface water,  whichever
is later.  Within 18 months following the determination that a  system is
under the  influence of  surface water, the Primacy Agency must determine,
using  the same  criteria that apply  to systems  using  a surface  water
source,  whether the system must  provide  filtration  treatment.  As  for
systems using a surface water source, the Primacy Agency must evaluate the
data on  a  case-by-case basis  to  determine  conditions  which  will  trigger
the need for filtration.
      Beginning December 30,1991 or 18 months after the determination that
a  system is  under the  direct  influence of surface water,  whichever is
later, the criteria for avoiding  filtration  in S141.71(a) and (b)  and the
requirements for unfiltered systems in S141.71(c)  and S141.72(a)  go into
effect,  unless  the  Primacy Agency  has determined  that filtration  is
required.   As  with  systems  using  a  surface  water  source,  subsequent
failure  to comply  with any one of the  criteria  for  avoiding filtration
requires  the  installation  of filtration  treatment.    Thus,  beginning
December 30, 1991 or  18 months after the  Primacy  Agency determines that
a  system  is  using a ground  water source under the  direct  influence of
surface water,  whichever is  later,  a  system which fails to  meet  any one
of the criteria to  avoid filtration must  install  filtration and comply
with the requirements  for filtered systems within  18 months of the failure
or by  June 29,  1993,  whichever  is  later.   As for  unfiltered systems,
systems  under  the direct  influence  of surface water may  apply for an
exemption to extend the^time period for installing filtration.
      Any  systeln using  a  ground water  source  that  the  Primacy Agency
determines is under the direct influence of surface water end that already
has filtration  in place at  the time  of the Primacy Agency  determination
must meet the treatment  technique, monitoring and reporting  requirements
for  filtered systems  beginning  June  29,  1993  or  18 months  after the
Primacy Agency determination, whichever is later.
                                  7 - 5

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7.5   Responses for Systems not; Mating SWTR Criteri?

      7.5.1  Introduction

      Systems which presently fail  to meet the SWTR  criteria  may  be  able

to upgrade the system's design and/or operation and  maintenance  in order

to achieve compliance.   The purpose of  this section is  to present  options

which may be followed to achieve compliance.


      7.5.2  Systems Not Filtering

      Systems not  filtering  must meet the criteria to  avoid  filtration

beginning  December 30,  1991  and on  a continuing  basis thereafter  or

install   filtration.    Systems not  filtering  can  be  divided  into  two

categories:

      A.    Those systems not  currently meeting the SWTR criteria but  with
            the ability to  upgrade  to meet them.

      B.    Those systems not able  to meet the SWTR  criteria  by  December
            30,  1991.  If the installation of filtration is not  possible
            by June 29, 1993 the system may  request an  exemption and  take
            interim measures to provide safe water to  avoid violation of
            a treatment technique requirement.

      Systems in Category A


      Example A - Response  Situation
      Condition;    System  is not meeting  the source water  fecal  and/or
      total  coliform concentrations but has not received judgment on the
      adequacy-of its watershed control.

      Response Options;

            Monitor for fecal  coliforms rather than total  coliforms  if
            this   is  not  already  done.   Fecal coliforms  are  a  direct
            indicator of  fecal  contamination where total  coliforms are
            not.   If total coliform levels are exceeded but fecal levels
            are not,  the system meets the criteria.

            Take  appropriate action in the watershed to assure fecal and
            total coliform concentrations  are below the criteria, such as
            elimination of animal  activity near the source water intake.
                                  7  -  6

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Example B - Response Situation

Condition!    System meets  the  source  water  quality  criteria,
watershed control requirements, and  is maintaining  a  disinfectant
residual within the  distribution system, but is not able to meet the
CT  requirements  due to  lack  of  contact time prior to  the  first
customer.
Response Options:

      Increase the application of disinfectant while monitoring THM
      levels to ensure they remain  below the MCL.

      Add  additional  contact time  through  storage  to obtain  an
      adequate CT.

       Apply a more effective disinfectant such as ozone.
Systems in Category B

Example A - Response Situation

Condition;   System meets the  source  water turbidity but  not  the
fecal colifonn requirements.   A  sewage  treatment  plant  discharges
into the  source  water.   A determination  has  been made  that  the
system does not have adequate watershed control.

Response Options;

      Purchase water  from a nearby  surveyor  or use  an  alternate
      source such as ground water if available.

      Take steps to  install  filtration,  applying  for an  exemption
      (time delay)  as presented in Section 9 where appropriate.

Example B

Condition;  The source water exceeds a turbidity of 5 NTU for more
than two  periods  in  a  year under  normal  weather  and  operating
conditions.

Response Potions;

      Purchase water  from a nearby  purveyor  or use  an  alternate
      source such as ground water if available.

      Take steps to  install  filtration,  applying  for an  exemption
      (time delay)  as presented in Section 9 where appropriate.
                            7 - 7

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       In  the interim prior to adoption of either  of  the  above options,
       certain  protective measures may  be  appropriate.   One  protective
       measure which  can  be used would be the issuance of a public notice
       to boil all water for consumption  during periods when the turbidity
       exceeds  5 NTU.   If such a  notice  is  issued,  the  utility should
       continue  sampling the distribution system  for chlorine residual and
       total  coliforms, and initiate measurement of HPCs in the distribu-
       tion system.  These data and the raw water turbidity should be used
       to determine when  to lift the boil water notice.
       The notice could be lifted when:

             The historical (prior to high turbidity) disinfectant residual
             concentration is reestablished in the distribution system;
             The total coliform requirements are met;
             The HPC count is  less than 500/ml; and
             The turbidity of the raw water is less than 5 NTU.

       7.4.3  Systems Currently Filtering

       Systems which  are  currently  filtering  must  meet the SWTR criteria
within 48 months of the SWTR to be in compliance, after which the criteria
must be continually met  for the system to be in compliance.

       Example A - Response Situation
      Condition;  A  direct  filtration plant  is  treating a surface water
      which  is not compatible with this  treatment  process.  The system is
      not achieving  its  required  turbidity  performance or disinfection
      criteria.
      Response Potions;
             Optimize coagulant dose.
             Reduce filter loading  rates.
             Evaluate the effect on performance of  installing flocculation
             and sedimentation ahead of the filters.
                                  7 - 8

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      Example B - Response Situation
      Condition:   A filtration  plant  is using  surface  water which  is
      compatible with its treatment system.   The system is not achieving
      disinfection performance criteria required  by the Primacy Agency to
      achieve  a 1-log  inactivation of  Giardia  cysts;  however,  it  is
      meeting the requirements of the Total  Coliform Rule.
      Response Options:
            Increase disinfectant dosage(s).
            Install storage facilities  to  increase  disinfectant  contact
            time.
            Ensure optimum filtration efficiency by:
                  Use of a filter aid.
                  Reduction in filter loading rates.
                  More frequent backwashing of filters.

      The Primacy Agency may grant additional removal credit for optimum
filtration.
      EPA intends to promulgate  National  Primary Drinking Water Regula-
tions to regulate levels of disinfectants and disinfectant  by-product when
it  promulgates  disinfection  requirements  for  ground  water  systems
(anticipated  in 1992).    EPA  is   concerned  that  changes required  in
utilities' disinfection practices to meet the required inactivations for
the SWTR  might  be  inconsistent with treatment changes  needed to comply
with  the  forthcoming  regulations  for  disinfectants  and  disinfection
by-products.   For  this  reason,  the EPA  is allowing  Primacy Agencies
discretion in determining the level  of  disinfection required for filtered
systems to meet the overall treatment performance requirements specified
in the rule or recommended based on source  water quality.
      During the interim period,  prior to promulgation of  the disinfection
by-product regulation, EPA recommends that  the Primacy Agency  allow more
credit  for  Giardia cyst  and  virus removal  than generally recommended.
This  interim level  is  recommended  in cases  where the  Primacy Agency
determines  that a  system  is  not  currently at  a  significant risk from
microbiological concerns  at  the existing level of disinfection and that

                                  7 - 9

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                         8.   PUBLIC NOTIFICATION

      The SWTR specifies that the public notification requirements of the
Safe Drinking Water Act (SDWA) and the  implementing regulations of 40 CFR
Paragraph  141.32 must  be  followed.   These  regulations  divide  public
notification  requirements  into two tiers.   These tiers are  defined  as
follows:
      1.    Tier 1:
            a.    Failure to  comply with MCL
            b.    Failure to  comply with prescribed treatment technique
            c.    Failure to comply with a variance or exemption schedule
      2.    Tier 2:
            a.    Failure to  comply with monitoring requirements
            b.    Failure to  comply with  a  testing procedure prescribed
                  by a NPDWR
            c.    Operating  under a  variance/exemption.    This  is  not
                  considered  a  violation   but  public  notification  is
                  required.
      The  SWTR classifies  violations of  Sections   141.70,  141.71(c),
141.72 and 141.73 (i.e.,  treatment technique  requirements as specified in
Section 141.76) as Tier 1 violations and violations of Section 141.74 as
Tier 2 violations.   Violations of 141.75 (reporting  requirements) do not
require public notification.
      There are certain general requirements which all  public notices must
meet.   All  notices must provide  a clear  and  readily  understandable
explanation of the  violation,  any potential  adverse  health effects,  the
population  at risk,  the  steps   the  system  is  taking  to correct  the
violation, the necessity of seeking alternate water supplies (if any) and
any preventative measures the  consumer  should take.   The notice must be
conspicuous, not contain  any unduly technical language, unduly  small print
or similar problems.  The notice  must include the  telephone number of the
owner or operator or designee  of the public water system as a source of
additional  information concerning the violation  where appropriate.   The
notice must be bi- or multilingual if appropriate.
      In  addition,   the   public   notification  rule  requires  that  when
providing information on  potential adverse health effects in Tier 1 public

                                  8 - 1

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a deferral  is necessary for the system to upgrade its disinfection process
 . op ,„ ,y achieve compliance „,«, the SWT* as „,„ as the fort
                                     i.    Section 5.5.3
guidelines for establishing interim disinfection
                                                requirements.
                              7 - 10

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 notices  and in  notices  on  the  granting  and  continued  existence of  a
 variance or exemption, the owner or operator of a public water system must
 include  certain  mandatory health effects  language.   For  violations  of

 treatment  technique requirements for  filtration  and disinfection,  the
 mandatory health effects  language is:

      Microbiological Contaminants

 The  United  States  Environmental  Protection  Agency (EPA)  sets  drinking
 water standards and has determined that microbiological  contaminants  are
 a health concern at certain levels of exposure.  If water is inadequately
 treated, microbiological  contaminants  in  that water may  cause  disease.
 Disease  symptoms  may  include  diarrhea,  cramps,   nausea,  and  possibly
 jaundice  and  any  associated headaches,  and  fatigue.    These  symptoms,
 however,  are  not   just  associated  with   disease-causing  organisms  in
 drinking water, but also may be caused by a number of factors other than
your drinking water.   EPA has  set enforceable requirements for treating
 drinking  water to reduce  the  risk of  these  adverse   health  effects.
 Treatment such  as filtering and disinfecting the water removes or destroys
microbiological contaminants. Drinking water which is treated to meet EPA
 requirements is associated with  little  to none of this risk and should be
considered safe.
      Further, the owner or operator of a community water system must give
a copy  of  the most recent notice  for any Tier 1 violations  to  all  new

billing units or hookups prior to or at the time service begins.
      The medium for  performing  public  notification  and  the time period
in which notification must be sent varies with the type of violation and
is specified in Section  141.32.  For Tier 1 violations (i.e., violations
of Sections 141^.70, 141.71, 141.72 and 141.73), the owner or operator of
a public water system must give notice:
      1.    By publication in a local  daily newspaper  as soon as possible
            but  in no case  later  than  14 days  after the  violation or
            failure.   If the  area  does  not have  a daily newspaper, then
            notice shall be given by publication  in a  weekly newspaper of
            general circulation in the area,  and

      2.    By either direct mail delivery or hand delivery of the notice,
            either by itself or with the water bill not later than 45 days
            after the violation or failure.  The Primacy Agency may waive
            this requirement  if it determines that the owner or operator
            has corrected the violation within the 45 days.
                                  8 - 2

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      Although the SWTR does not specify any  acute violations, the Primacy
Agency may specify some Tier 1 violations as  posing  an acute risk to human
health;  for example these violations may include:
      1.    A waterborne disease outbreak in an unfiltered supply.
      2.    Turbidity of the water prior  to  disinfection of an unfiltered
            supply or the turbidity of filtered water exceeds  5 NTU at any
            time.
      3.    Failure to  maintain a  disinfectant  residual of  at  least 0.2
            mg/1 in the water  being delivered to the distribution system.
For  these violations  or  any others  defined by  the  Primacy Agency  as
"acute" violations,  the system must  furnish  a  copy  of  the  notice to the
radio and television stations serving the area  as  soon as possible but in
no case later than 72 hours after the violation.  Depending upon circum-
stances particular to the system, as determined by  the Primacy Agency, the
notice may instruct that  all  water  should be  boiled prior to consumption.
      Following the initial notice, the owner or operator must give notice
at least  once  every  three  months by mail delivery  (either  by  itself cr
with the  water bill),  or by  hand delivery,  for as long as  the violation
or failure exists.
      There are two  variations on  these  requirements.   First,  the owner
or operator of a community water system in an area not served by a daily
or weekly newspaper  must give notice within  14 days after  the violation
by hand delivery or continuous  posting of a notice of the violation.  The
notice must be in  a conspicuous place in the area served by the system and
must  continue for  as long  as   the  violation  exists.   Notice  by hand
delivery must be repeated at  least  every  three  months for the duration of
the violation.
      Secondly, the  owner or  operator of  a  noncoitrounitv  water  system
(i.e.,  one serving  a transitory  population)  may  give  notice  by hand
delivery  or continuous posting of the notice  in conspicuous  places  in the
area served by the system.   Notice  must be given within 14 days after the
violation.  If notice  is given by posting, then it must continue as long
                                  8 - 3

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as the violation exists.  Notice given by hand delivery must be repeated
at least every three months for as long as the violation exists.
      For Tier 2 violations  (i.e., violations of 40 CFR 141.74, analytical
and  monitoring  requirements)  notice must  be given  within  three  months
after  the  violation  by  publication  in  a daily newspaper of  general
circulation,  or  if there  is  no daily  newspaper,   then   in  a  weekly
newspaper.   In addition, the owner or operator shall  give notice by mail
(either by  itself  or  with the water bill) or  by hand  delivery at least
once every  three months  for as  long  as  the violation  exists.   Notice of
a variance or exemption must be given  every three months from the date it
is granted for as  long as it remains in effect.
      If the area is not served by a daily  or weekly newspaper, the owner
or operator  of  a  community  water system must  give notice  by continuous
posting in conspicuous places  in the area served by the  system.  This must
continue  as long  as  the violation  does  or  the  variance  or  exemption
remains in  effect.  Notice by  hand  delivery must be  repeated at least
every three  months  for  the  duration  of  the violation  or the variance of
exemption.
      For  noncommunity  water  systems,  the owner or  operator  may give
notice by  hand delivery or continuous  posting in conspicuous  places;
beginning within 3 months of the violation or the variance or exemption.
Posting must continue  for the duration of  the violation  or variance or
exemption  and  notice  by hand  delivery  must be repeated  at least every
3 months during this period.
      The Primacy Agency may allow for owner or operator to provide less
frequent  notice  for  minor  monitoring  violations  (as  defined,  by  the
Primacy  Agency if EPA  has  approved  the  Primacy  Agency's   substitute
requirements contained in a program revision application).
      To provide further assistance in preparing public notices, several
examples have  been provided.   However,  each  situation  is  different and
may  call  for differences in  the  content  and  tone  of the  notice.   All
notices must comply with the general requirements specified above.
                                  8 - 4

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Example 1 - Tier 1 Violation-Unfilled $upp1y

      Following  is  an  example  of  a  Tier  1  violation  which  may  be
considered by the Primacy Agency to pose an acute risk  to  human health.

      A system which does  not  apply filtration experiences  a breakdown in

the chlorine feed systems  and  the switchover system fails to activate the
backup systems.  A number  of hours pass before the operator discovers the

malfunction.  The operator, upon discovery of  the  malfunction,  contacts

the local television and radio stations and announces that the public  is

receiving untreated water.  The announcement  may  read as follows:

      We  have just  received  word  from the  Aswan Water  Board that  a
      malfunction of the disinfection system has  allowed untreated  water
      to pass into the distribution system.  Thus,  this system providing
      drinking water is  in violation of a treatment technique requirement.
      The  United  States   Environmental  Protection  Agency  (EPA)   sets
      drinking water  standards  and has determined that microbiological
      contaminants are  a  health  concern at certain levels  of exposure.
      If water is  inadequately  treated, microbiological contaminants  in
      that  water  may  cause  disease.   Disease  symptoms  may  include
      diarrhea, cramps,  nausea,  and possibly jaundice and  any associated
      headaches,   and  fatigue.   These symptoms,  however,  are  not  just
      associated with disease-causing organisms  in drinking  water,  but
      also may be caused by a number of factors other than your drinking
      water.  EPA has set enforceable requirements  for  treating drinking
      water to reduce the  risk of these adverse health effects.  Treatment
      such as  filtering and  disinfecting  the water removes  or destroys
      microbiological contaminants.   Drinking  water which is treated  to
      meet EPA requirements is associated with little to none  of this risk
      and should be considered safe.

      The temporary  breakdown in  disinfection  may have  allowed micro-
      organisms to pass into  the distribution  system.   The operation  of
      the syst«ra  has  been restored so  that  no further contamination  of
      the distribution  system will  occur.   Any  further changes will  be
      announced.

      Additional   information  is  available   at  the   following  number:
      235-WATER.

      A direct mailing  of the notice  is provided  within  45 days of the
      occurrence.


Example 2 - Tier 1 Violation-Unfiltered Supply

      Following  is  an  example  of  a  Tier   1  violation  which may  be

considered by the Primacy Agency to pose an acute  risk  to human  health.
                                  8 - 5

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      A  system  supplies  an unfiltered  surface  water to its  customers.

During a  period of unusually heavy rains  caused  by  a hurricane  in  the
area, the turbidity of the water exceeds 5  NTU.  The turbidity data during
which the heavy rains occur is as follows:

      Dav 1 NTU     Dav 2 NTU     Dav  3 NTU     Dav 4 NTU      Dav 5  NTU

         0.4              0.8       0.7           0.7               7.6
         0.4              0.5       0.4           7.6               3.1
         0.5              0.5       0.4           11.3               2.7
         0.7              0.4       0.5           9.6               0.7
         1.1              0.4       0.4           7.2               0.8
         0.9              0.6       0.6           5.0               0.5


      The following public  notice was prepared and submitted to the local

newspaper,  television and  radio stations within  72  hours  of the  first
turbidity exceedence of 5 NTU.

      The occurrence of  heavy  rains  in  our watershed  is causing a rise in
      the  turbidity of  the  drinking   water  supplied by  Fairfax  Water
      Company.

      Turbidity is  a measurement of particulate matter  in water.   It is
      of  significance   in  drinking  water  because  irregularly  shaped
      particles can both harbor microorganisms  and  interfere directly with
      disinfection  which destroys  microorganisms.   While the particles
      causing the  turbidity  may not be harmful  or even visible  at  the
      concentrations measured,  the  net effect of a  turbid water  is to
      increase the survival rate of microorganisms  contained in the water.
      This  is  of  concern because  several  diseases  are associated  with
      waterborne microorganisms.

      Because of  the high turbidity  levels,  the  Fairfax  system is in
      violation of a  treatment requirement  set  by the  Environmental
      Protection Agency (EPA).

      The  United   States   Environmental   Protection  Agency   (EPA)  sets
      drinking water standards  and has determined that microbiological
      contaminants  are a health concern at certain  levels  of exposure.
      If water  is  inadequately  treated, microbiological contaminants in
      that  water   may  cause  disease.     Disease   symptoms  may  include
      diarrhea,  cramps,  nausea,  and possibly  jaundice and  any associated
      headaches,  and  fatigue.   These  symptoms,  however,  are  not  just
      associated with disease-causing  organisms  in  drinking  water,  but
      also may be caused by a number of factors  other than  your drinking
      water.  EPA has set enforceable  requirements for treating drinking
      water to reduce the risk of these  adverse health effects.  Treatment
      such  as filtering  and  disinfecting  the water  removes  or  destroys
      microbiological contaminants.  Drinking water  which  is  treated to


                                 8  - 6

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       meet EPA requirements is associated with little to  none of this risk
       and should  be  considered safe.

       In  order to  protect yourself  from  illness,  all  water from  the
       Fairfax system used for drinking,  cooking  and washing dishes should
       be boiled at a rolling  boil for one minute.

       The system  is  being  closely monitored  and a  notice will  be issued
       when the water returns to an acceptable quality and no longer needs
       to be boiled.
      The utility continues sampling the distribution system for chlorine

residual and total coliforms,  and initiates measurement of the HPCs in the

distribution system.  The notice is  lifted when all  the  following are met:

            The historical (prior to high turbidity) disinfectant residual
            concentration  is  reestablished in the distribution system.

            The total coliform requirements are met.

            The HPC count  is  <500/ml.

            The turbidity  of  the raw water is less than 5 NTU.


The Primacy Agency most decide whether the turbidity event was unusual or
unpredictable and whether  filtration should be installed.


Example 3 - Tier  1 Violation  - Filtered Supply

      A  conventional  treatment plant  is treating  a  surface water.   A

malfunctioning  alum  feed  system resulted in an increase  of  the filter

effluent turbidities.  The effluent turbidity was between 0.5 and 1.0  NTU

in 20 percent of  the samples  for the month.  The utility  issued a notice

which was published  in  a local  daily newspaper within 14 days after  the

violation.  The notice  read as follows:
      During  the  previous  month,  the  Baltic  Water  Treatment   Plant
      experienced  difficulties  with  the chemical  feed  system.     The
      malfunctions caused  an effluent turbidity level  above 0.5 NTU  in 20
      percent  of  the  samples  for  the  month.   The  current  treatment
      standards require  that  the  turbidity must  be less than 0.5 NTU in
      95 percent of the monthly samples.   The Baltic drinking water system
      has thus  been  in  violation of a  treatment  technique  requirement.

      The  United  States  Environmental  Protection  Agency  (EPA)   sets
      drinking  water standards and has  determined that  microbiological


                                  8 - 7

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contaminants are  a  health  concern at certain  levels of  exposure.
If water  is  inadequately treated,  microbiological  contaminants  in
that  water  may   cause  disease.   Disease  symptoms  may  include
diarrhea,  cramps,  nausea,  and possibly jaundice and any associated
headaches,  and  fatigue.    These symptoms,  however,  are not  just
associated with disease-causing organisms in drinking water,  but
also may be caused by a number of factors other than your drinking
water.  EPA has set enforceable requirements for treating drinking
water to reduce the risk of these adverse  health effects.  Treatment
such  as filtering and  disinfecting the water  removes  or destroys
microbiological  contaminants.   Drinking water which  is treated  to
meet EPA requirements is associated with little to none  of this risk
and should be considered safe.

The chemical, feed and switchover components  of the  system have been
repaired and are  in working order and turbidity levels  are meeting
the standard.   It is unlikely  that  illness will  result  from the
turbidity  exceedences   previously  mentioned  because  continuous
stringent disinfection  conditions were in  effect and the system was
in compliance with other microbiological  drinking  water standards
pertaining  to  microbiological  contamination.   However,  a  doctor
should  be contacted  in  the  event  of  illness.    For additional
information call,  1-800-726-WATER.
                            8 - 8

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                             9.  EXEMPTION^


9.1   Overview of Requirements

      Section 1416 of the Safe Drinking Water Act allows a Primacy Agency
to  exempt  any  public  water  system  within  its  jurisdiction  from  any
treatment  technique  requirement  imposed  by a  national  primary  drinking
water regulation upon a finding that:

      1.    Due  to  compelling  factors   (which  may  include  economic
            factors), the public water system is unable to comply with the
            treatment technique requirement;

      2.    The public water system was in operation on the effective date
            of the treatment technique requirement or, for a system that
            was  not  in operation by that date,  only if no  reasonable
            alternative source of drinking water is available to the new
            system; and

      3.    The granting of the exemption will  not  result in an unreason-
            able risk to health.
      If a Primacy Agency grants a public water system an exemption, the

Agency must prescribe,  at the  time  the exemption  is granted,  a schedule

for:

      1.    Compliance  (including increments  of progress)  by  the public
            water system with  each  treatment  technique requirement with
            respect to which the exemption was granted; and

      2.    Implementation by the system of such control measures as the
            Primacy Agency may require during  the period the exemption is
            in .effect.
      Before  prescribing a  schedule,  the  Primacy Agency  must provide
notice and opportunity for a public hearing on the schedule.  The schedule
prescribed must  require  compliance by the public  water system with the

treatment technique  requirement  as  expeditiously as practicable,  but  in
no case  later than one year  after the exemption is issued  (except that,

if the system meets  certain  requirements,  the final date for compliance
may be extended  for  a  period not  to exceed three years  from the date the
exemption  is  granted).    For  systems  serving  less  than  500 service
                                  9 - 1

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connections,  and meeting  certain  additional  requirements,  the  Primacy
Agency  may  renew  the  exemption  for  one or  more additional  two-year
periods.
      Under  the  SWTR,  no  exemptions  are  allowed  from  the requirement to
provide  disinfection  for  surface  water  systems,  but  exemptions  are
available to reduce the degree of disinfection required.  Exemptions from
the filtration requirements are available.  The following sections present
guidelines for evaluating conditions  under which exemptions are appropri-
ate.

9.2   Recommended Criteria
      In order to obtain  an exemption  from  the  SWTR,  a system must meet
certain minimum criteria to assure  no unreasonable  risk to health.  These
should  be  applied before  looking  at  other  factors such as  economics.
Recommended minimum criteria for assuring no unreasonable risk to health
exists are listed below.
      Systems which do not  provide filtration
            Practice disinfection to  achieve at least a 2-log inactivation
            of Giardia cysts; or comply with the disinfection requirements
            for  the distribution system  as  defined in Section 141.72(b)
            of the SWTR.
            Comply with the monthly coliform MCL; or provide bottled water
             (or another alternate water source)  or  point of use treatment
            devices  for their customers  in which  representive  samples
            comply with all  the   MCL  National  Primary Drinking  Water
            Regulations.
      EPA recommends that in order to obtain an extension to the initial
1 year exemption period  in  addition  to  the required elements in Section
1416, the system would need to be in  compliance with the monthly coliform
MCL, satisfy the above disinfection criteria and not have any evidence of
waterborne disease outbreaks attributable  to the system at the end of that
first exemption  period.   If at  any  point  during  the  extended  exemption
period the system did not meet these conditions,  the exemption  should be
withdrawn and the system should  be subject  to an enforcement action.
                                  9 -  2

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      Systems whi^h provide filtration
            Practice disinfection to achieve  at least a 0.5 log inactiva-
            tion  of  Giardia  cysts;  or  comply  with  the  disinfection
            requirements  for  the  distribution  system  as  defined  in
            Section 141.72 of the rule.
            Comply with the monthly coliform MCL;  or provide bottled water
            (or another alternate water source) or point of use treatment
            devices  for their customers  in  which represent!ve  samples
            comply  with all  the MCL  National  Primary  Drinking  Water
            Regulations.
              ^
            Take  all  practical  steps  to improve the performance  of i
            filtration system.
ts
      In order to obtain an extension  to the initial exemption period, in
addition to the  required  elements  in  Section  1416,  the system should be
in  compliance with  the  colifortn  MCL,  satisfy  the above  disinfection
criteria  and   not  have  any evidence  of  waterborne   disease  outbreaks
attributable  to  the  treatment  system  at the end  of that first exemption
period.  If at any point during the extended exemption period the system
did not meet  these conditions,  the exemption should be withdrawn and the
system  should be subject  to  an enforcement  action.    In  addition,  the
system must continue to be taking  steps to  improve  the  performance of its
filtration system to achieve the criteria specified in the SWTR.
      Once these minimum  requirements are applied, the  Primacy Agency
should  look at the  other  factors  as  described in Sections 9.3,  9.4, and
9.5.

9.3   Compelling Factors
      Compelling  factors  are  often  associated with small  systems. The
major  compelling  factor  tends  to  be economic.    In  some cases  the
compelling factor may not  be solely economic,  but  rather the contractual
and physical  infeasibility of having a required treatment installed within
the time period  specified  in the regulation.   For  example, it may not be
feasible for  a very large system  to  install  filtration by June 1993 if
required.   In such  cases exemptions are  also appropriate.   Additional
considerations for  small  systems are  presented in  Appendix L.

                                  9 - 3

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       If system improvements  necessary to comply with the SWTR incur costs
which  the Primacy Agency determines pose an economic  barrier to acquisi-
tion   of  necessary  treatment,   the  system  fulfills  the  criteria  of
demonstrating  a  compelling hardship which makes  it  unable to  meet  the
treatment requirements.  In such  cases,  the EPA believes it is reasonable
to grant  an  exemption  if the system also meets the criteria  in 9.4 and
9.5.
       The USEPA  document,  "Technologies  and  Costs for  the  Removal  of
Microbial  Contaminants  from Potable  Water  Supplies,"  contains  costs
associated with  available  treatment  alternatives  (USEPA,  1988b).   Costs
found  in this  document,  or those  generated  from  more  site-specific
conditions,   can  be  used as  the  basis  for determining the  ability  of a
system to afford treatment.  The total  annual  water production costs per
household for a system  can  be estimated based on the household water usage
and the production costs per  thousand gallons.  As estimated in the above
cited USEPA document, each cent per thousand  gallons  of treated water is
approximately equivalent to $1 per year per household  if a household water
usage of 100,000 gallons per  year is assumed.1   This estimate will need to
be adjusted according to water usage for cases where  the household usage
differs from 100,000 gallons per year.
      The  following  examples   are  presented  to  provide  guidance  in
estimating costs for a  system to upgrade its system or install filtration.
This cost information could be used for determining whether  a system might
be eligible for an exemption.
      Example 1
      A water system which supplies an average daily  flow of 0.05 mgd to
a small urban community receives  its water supply from a  lake.  The system
currently  provides   disinfection with  chlorine  but does not provide
filtration.   The  system reviewed  its source water quality and found  the
characteristics to be as follows:
  1    This is the national average residential household consumption reported
      in:  Final  Descriptive Summary - 1986 Survey of Community Water Systems.
      October 23, 1987.  USEPA:  Office of Drinking Water.
                                  9 - 4

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            Total coliforms         1,000/100 ml
            Turbidity               10 - 13 NTU
            Color                   6 - 9 CU
      Based upon the criteria  in the SWTR,  this  source requires filtration
and  a  review  of  the  water  quality  criteria  presented  in  Table 4-2
indicates  that   the treatment  technique  best  suited  to these  source
conditions  is  conventional  treatment.   A  conventional  package treatment
plant with  a  capacity of   0.068  MGD  may be purchased  and put on line at
a  cost  of $277/household-year not including real  estate,  piping  or raw
water  pumping  costs  which may  be significant  depending  on  the  plant
location.2  EPA has estimated that,  on  average, these  costs  might add
another 50% depending on site specific factors  (USEPA, 1989)
      Thus  the  cost  estimate  for implementing  filtration indicates that
the  increase  in  the  average  annual  household  water bill  would  be
approximately  $277  plus the cost of real  estate,  piping,  and raw water
pumping as needed.   The  incomes of people in the community and the current
water  bills  can  be  reviewed  by  the  Primacy  Agency  along  with  these
estimated costs to determine if an undue economic hardship  is incurred by
these treatment methods.  Upon determination  that an economic hardship is
incurred,  the  Primacy  Agency may grant  an exemption  from  filtration,
provided that  the  system  can  assure  the  protection of the health of the
community.  However,  if the water supply  system for  a nearby community
meets the drinking water standards ajnd there is the ability to  hook up to
that system,  an exemption  generally  should not  be granted  unless such
costs also presented an economic hardship.
      Example 2
      A large urban community, with a median annual income  of $25,000 per
family, is supplied with water from  lakes  and  reservoirs.  The community
places  an average  daily  demand  of 3 mgd  on   the  supply system.   The
watershed of  the system is  moderately populated  and used for farming and
      Table  VI-3  ("Technologies  and  Costs  for  the Removal  of Microbial
      Contaminants From Potable Water Supplies," USEPA, 1988b) lists the total
      costs as 277.4 cents/1000 gal.  Estimated costs for real estate, piping
      and  raw water pumping as a  function  of  site specific conditions are
      available  in  Table  E-l,  E-2, and  E-3 of  this  same document.
                                  9 - 5

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grazing.   The  system  currently provides filtration  using  diatomaceous
earth  filtration and disinfection with chloramines.
       A  review  of the source and finished water quality was conducted to
evaluate the plant's performance.  The source water quality was determined
to be:
            Total coliforms         30 - 40/100 ml
            Turbidity               2 - 3 NTU
            Color                   1 - 2 CU
       Diatomaceous  earth  is  therefore an acceptable filtration method.3
However,  review of  the finished water  showed that  a residual  in  the
distribution  system is  only  maintained  80 percent  of  the  time.    In
addition to  this,  coliforms  were detected  in  10  percent  of  the samples
taken  over the  twelve  month  period.    Inspection of the  chlorination
equipment  showed the  equipment is deteriorated.   Review  of  the monthly
reports  showed  that the  coliforms  appeared in the  distribution  system
shortly after the chlorinators  malfunctioned.  This observation  led to the
conclusion that new disinfection facilities were needed.
      The source water quality  and available contact time after disinfec-
tion were then used  to determine the most appropriate disinfectant for the
system.  As described in Section 5.5,  ozone,  chlorine or chlorine dioxide
can be used as primary disinfectants given these conditions.   A prelimi-
nary  review  of  costs  for  applying  the  various disinfectants  showed
chlorine to  be  the  most economical  at  a  cost  of $2.8/household/year*
(USEPA,  1988b).  This  cost does not  include backup  equipment; however,
even with providing duplicate equipment  doubling this cost to $5.6/house-
hold/ year, the  improvement  incurs  minimal  cost  and  the  Primacy  Agency
should not grant the system an  exemption based on economic hardship.
      As determined from Table 4-2 of Section 4.
      Table VI-12 (USEPA,  1988b)  lists a total cost of 2.8 cents/1000 gal for
      a plant capacity of 5.85 mgd.
            (2.8 cents)  (Sl/household-vear) « $2.8/household-year
            (1,000 gal)   (cents/1000 gal)
                                  9 -  6

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9.4   Evaluation of Alternate Water ^uaplv Sources
      Systems which would incur very high costs for installing a  required
treatment  to  comply with the  SWTR,  should  evaluate the possibility  of
using an alternate source.  These alternate sources  include:
            The use of ground water
            Connection to a nearby water purveyor
            Use of an alternate surface water supply
      When  considering  the  use  of  ground water,  the  purveyor  must
determine the capacity of the underlying aquifer for supplying the demand.
The water  quality characteristics of  the  aquifer  must be evaluated  to
determine what treatment may be needed  to  meet existing  standards.   The
cost  of the  well  construction and  treatment  facilities  must then  be
determined and converted into a yearly cost per household.
      The connection to a nearby purveyor involves contacting the purveyor
to determine their capacity and willingness to  supply the water.  Once it
has  been  determined  that  the alternate  source meets  all  applicable
drinking water standards, the cost of the transmission lines, distribution
system,  and  other facilities  (e.g. disinfection, repumping,  etc.)  must
then be determined and amortized into a yearly  cost per household.
      If the cost  for  using an alternate source  is  found by  the Primacy
Agency to present an economic hardship, and the purveyor can  demonstrate
that there will be no unreasonable risk  to  health, the Primacy Agency may
grant an exemption to the SWTR  for the  purveyor and develop a schedule of
compliance.

9.5   Protection of Public Health
      Systems which apply for an exemption  from the SWTR must demonstrate
to the Primacy Agency that the  health of the community will not be put at
risk by  the  granting of such an exemption.  A system  should  be able to
provide  adequate protection for the public health by meeting the minimum
suggested EPA requirements in Section 9.2.   However, a Primacy Agency may
specify  additional  measures or criteria a system must  meet  to protect
public health, depending  on  the  particular circumstances.   Systems *itn
currently unfiltered surface water supplies which fail  to meet  the source

                                  9 - 7

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water quality criteria will be required to install  filtration as part of
their treatment process.   However, it may take 3  to 5 years or more before
the  filtration  system  can be  designed,  constructed  and  begin operation,
thereby  justifying  the granting of  an  exemption.   During  this period,
possible interim measures which the system could take to further satisfy
the  Primacy Agency's concern include one or more of the following:
      a.    Use of higher disinfectant  dosages without exceeding the TTHM
            MCL (even for systems not currently subject to this MCL)
      b.    Installation  of  a  replacement  or  additional  disinfection
            system  which  provides  greater disinfection efficiency and
            which can be  integrated into the new filtration plant
      c.    Increasing the monitoring and  reporting to the Primacy Agency
      d.    Increasing protection of the watershed
      e.    Increasing the frequency of sanitary surveys
      f.    Temporarily purchasing water from a nearby water system
      g.    For  small  systems,  temporary  installation  of  a  mobile
            filtration (package) plant
      h.    Increasing contact time by  rerouting water through reservoirs

      In some cases  systems may be able  to  increase  their disinfection
dosages during the interim period to provide additional protection against
pathogenic  organisms.    This  alternative  should  be  coupled  with   a
requirement for increased monitoring for colifortns, HPC and disinfectant
residual within the distribution system.   However,  disinfectant dosage
should not be increased  if  this  would  result in a violation of the TTHM
MCL, even for systems not currently subject to  this MCL.
      Systems which  are  planning to  install  filtration may  be able to
utilize a more  efficient  disinfectant  that can  later be integrated  into
the filter plant.   Currently ozone and  chlorine  dioxide  are considered to
be the most efficient disinfectants.
      For all systems which do not meet the source water quality criteria
ajui must install filtration, EPA recommends that during the  interim period
the  Primacy  Agency  increase its surveillance of  the  system and require

                                  9 - 8

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increased  monitoring  and  reporting  requirements  to  assure  adequate
protection of the public health.
      Any  required   increases   in  watershed   control   and/or   on-site
inspections will not  alleviate  the  need  for  more  stringent  disinfection
requirements and increased monitoring of the effectiveness  of the system
employed.  Their purpose would be to identify and  control all sources  of
contamination so that the existing system will  provide water of  the best
possible quality.
      For some systems,  it may be possible to  purchase water from a nearby
system on  a  temporary basis.   This  may involve no more than  the use  of
existing interconnections or it  may  require the installation of temporary
connections.
      Trailer mounted filtration units  (package  plants)  are sometimes
available from state agencies for emergencies or may be rented or leased
from equipment manufacturers.
      Systems may  also be required to  supply  bottled water  or install
point-of-entry (POE)  treatment  devices.   For the reasons  listed below,
these alternatives  should  only  be utilized  if  the  previously mentioned
alternatives are not feasible:
            In many  states  bottled  water  is subject  only   to the water
            quality requirements of the FDA as  a beverage and not to the
            requirements of the Safe Drinking Water Act.
            Point-of-entry treatment devices  are not currently covered by
            performance or certification requirements which would assure
            their effectiveness or performance.

      If the installation of  POE devices is required, the selection of the
appropriate treatment device  should be  based upon a laboratory  or field
scale evaluation of  the  devices.  A guide for  testing the  effectiveness
of POE units in  the microbiological  purification of contaminated water is
provided in Appendix N.
      Several issues  arise  with the use of  POE devices.   These include
establishing who or  what agency (1)  has the responsibility for ensuring
compliance with standards; (2)  retains ownership of the treatment units;
(3) performs monitoring,  analyses and maintenance;  and (4) manages the

                                  9  -  9

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treatment program and maintains insurance coverage for damage and liabil-
ity.   It should also be considered that there is no significant increase
in  risk over centrally treated water.
       These  issues  should  be borne  in mind  when POE  as  a  treatment
alternative is being considered.
       Systems with currently unfiltered surface water supplies which meet
the  source  water  quality criteria, but do  not  meet one or more  of the
other requirements for watershed control, sanitary survey, compliance with
annual  coliform  MCL or  disinfection  by-product regulation(s), will  be
required to install filtration  unless  the  deficiencies  can  be corrected
within 48 months of  promulgation of the SWTR.  Interim protection measures
include those previously listed.
       Systems with currently unfiltered surface water supplies which meet
the source water quality criteria and the site specific criteria but which
do  not  meet  the  disinfection requirements, will be required  to install
filtration  unless  the  disinfection  requirements   (adequate  CT  and/or
disinfection system redundancy) can  be met.  During the interim period,
available options include:
       a.    Temporary installation of a mobile treatment plant
      b.    Temporary purchase of water from a nearby purveyor
      c.    Increased monitoring of the system
      d.    Installation of temporary storage facilities to increase the
            disinfectant contact time

      Currently filtered  supplies  which fail  to meet  the  turbidity or
disinfection performance criteria  presented in Section 5 will be required
to  evaluate  and  upgrade their  treatment  facilities in  order to attain
compliance.  During  the interim period available options  for  improving the
finished water quality include:
      a.    Use of a filter aid to improve  filter effluent turbidities
      b.    Increased disinfectant dosages
      c.    The addition of an alternate disinfectant is an option  after
            the disinfection by-products rule is promulgated
                                 9 - 10

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      d.    Reduction in filter  loading  rates  with  subsequent reduction
            in plant capacity
      e.    Installation of temporary  storage  facilities  to  increase
            disinfectant contact time
9.6   Notification to EPA

      The SDWA requires  that each Primacy Agency which grants an exemption
notify  EPA  of the granting  of this  exemption.   The  notification  must
contain the reasons for  the exemption, including the  basis for the finding
that  the  exemption will  not  result  in  an  unreasonable risk  to public
health and document the need for the exemption.
                                  9 - 11

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REFERENCES

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                               REFERENCES


Ali-Ani, M.;  McElroy,  J.  M.;  Hibler,  C.  P.;  Hendricks,  D.  W.  Filtration
of Giardja Cysts and other Substances, Volume 3:  Rapid Rate Filtration.
EPA-600/2-85-027, U.S. Environmental Protection  Agency, WERL, Cincinnati,
Ohio, April,  1985.

American  Public Health Association;  American  Water  Works  Association;
Water Pollution Control Federation.  Standard  Methods  for the Examination
of Water and  Wastewater.  16th ed.,  pp. 134-6, 298-310, 827-1038, 1985.

American  Public Health Association;  American  Water  Works  Association;
Water Pollution Control Federation.  Standard  Methods  for the Examination
of Water and  Wastewater.  17th ed.,  1989.

American Water  Works Association.   Manual  of Water Supply Practices and
Water Chlorination Principles and  Practices,  1973.

American Water Works Association Research Foundation  (AWWARF).  A Summary
of State Drinking Water Regulations and Plan Review Guidance. June, 1986.


Bader, H.;  Hoigne,  J.  Determination  of Ozone  in Water  by the  Indigo
Method, Water Research 15; 449-454, 1981.

Bellamy, W. D.;  Lange,  K.  P.; Hendricks, D. W. Filtration of Giardia Cvsts
and  Other   Substances.   Volume 1:     Diatomaceous   Earth   Filtration.
EPA-600/2-84-114, U.S.  Environmental Protection  Agency, Cincinnati, Ohio,
1984.

Bellamy, W. D.;  Silver-man, G. P.;  Hendricks,  D. W. Filtration of Giardia
Cysts and Other Substances. Volume  2:  Slow Sand Filtration.  EPA-600/2-
-85-026, U.S. Environmental  Protection Agency, MERL, Cincinnati,  Ohio,
April, 1985.

Bishop, S.;  Craft,  T.  F.; Fisher,  D.  R.;  Ghosh,  M.;  Prendiville, P.W.;
Roberts, K. J.;  Steimle, S.; Thompson, J. The Status of Direct Filtration,
Committee Report. J.AWWA, 72(7):405-411, 1980.

Bouwer,  H.  Ground  Water  Hvdroloov.  McGraw  Hill Book  Co.,   New York,
pp. 339-356,  1978.

Brown, T. S.; Malina, J.  F., Jr.;  Moore, B. D.  Virus  Removal by Diatoma-
ceous Earth  Filtration  -  Part  1  & 2. J.AWWA  66(2):98-102,  (12):735-738,
1974.

Bucklin, K.;  Amirtharajah,  A.; Cranston,  K.  Characteristics  of Initial
Effluent Quality and Its  Implications  for the Filter-to-Waste Procedure.
AWWA Research Foundation  Report.   November, 1988.
                                   -1-

-------
 Carlson,  D.A.; Seabloom, R.W.; DeWalle,  F.D.; Wetzler, T.F.; Evgeset,  J.;
 Butler,  R.;  Wangsuthachart,   S.; Wang,  S.   Ultraviolet  Disinfection  of
 Water  for Small  Water Systems.   EPA/600/2-85-092, U.S.  Environmental
 Protection Agency, Water Engineering Reserach Laboratory, Drinking Water
 Research  Division, Cincinnati, Ohio, September, 1985.

 Clark,  R.M.;  Regli,  S.   A  Mathematical  and Statistical  Analysis for the
 Inactivation  of  Giardia  Iambiia by Free  Chlorine.   Submitted  to  the
 Journal of Environmental Science Engineering,  1989.

 Clark,  R.; Regli,  S.;  Black,  D.  Inactivation  of Giardia 1 amb1ia by Free
 Chlorine:  A  Mathematical   Model.    Presented  at  AWWA  Water  Quality
 Technology Conference.  St. Louis, Mo.,  November 1988.

 Cleasby, J. L.; Hilmoe,  D. J.; Dimitracopoulos, C.  J. Slow-Sand and Direct
 In-Line Filtration of a Surface Water.  J.AWWA, 76(12):44-55, 1984.

 DeWalle,  F. 8.;  Engeset,  J.;  Lawrence,  W.   Removal of  Giardia Iambiia
 Cysts  by  Drinking Water Plants.   EPA-600/S2-84-069, United  States  En-
 vironmental Protection Agency, MERL, Cincinnati, Ohio,  May 1984.

 Fox, K. R.; Miltner,  R.  J.;  Logsdon, G.  S.;  Dicks,  D.  L.;  Drolet, L. F.
 Pilot  Plant Exploration  of Slow Rate Filtration. Presented  at  the AWWA
 Annual Conference Seminar,  Las Vegas, Nevada,  June  1983.

 Fujioka,  R.;  Kungskulniti, N.;  Nakasone, S.   Evaluation of the Presence
 -  Absence Test  for  Coliforms  and the Membrane  Filtration Method  for
 Heterotrophic Bacteria. AWWA Technology  Conference Proceedings, November,
 1986.

Geldreich, E.   Personal  communication  to  Linda Averell, Malcolm Pirnie
 Engineers, Paramus, New Jersey, July 1989.

Great  Lakes-Upper Mississippi  River  Board of  State Public  Health  and
 Environmental  Managers Committee.  Recommended Standards  for Water Works.
 1987 Edition.   -

Hendricks, D.; Al-Ani, M.;  Bellamy, W.; Hibler, C.; McElroy,  J.  Surrogate
 Indicators for Assessing Removal  of Giardia Cysts, AWWA  Water Quality
Technology Conference, 1984.

 Hoff, J.  C. Inactivation of  Microbial  Agents  bv Chemical Disinfectants.
 EPA-600/S2-86-067, U.S. Environmental Protection Agency, Water Engineer-
 ing  Research  Laboratory,  Drinking Water  Research Division, Cincinnati,
Ohio, September  1986.

 Hoffbuhr, J. W.; Blair, J.; Bartleson, M.;  Karlin,  R.  Use of Particulate
 Analysis  for  Source  and  Water Treatment Evaluation.  AWWA Water Quality
 Technology Conference Proceedings, November 1986.

 Horn,  J.  B.;  Hendricks,  D.  W.   Removals of  Giardia  Cysts  and other
 Particles from Low Turbidity Waters Using  the  Culligan Multi-Tech  Filtra-

                                   -2-

-------
tion  System.    Engineering  Research  Center,  Colorado  State  University,
Unpublished,  1986.

Joost,  R.  D.;  Long,  B.  W.;  Jackson,   I.   Using  Ozone  as  a  Primary
Disinfectant  for  the Tucson  CAP  Water Treatment  Plant,  presented at the
IOA/PAC Ozone Conference, Monroe, MI, 1988.

Kuchta, J. M.; States,  S. J.; McNamara, A. M.; Wadowsky, R. M.;  Yee, R. B.
Susceptibility  of Legionella pneumophila to Chlorine in Tap Water. Appl.
Environ.  Microbiol., 46(5):  1134-1139,' 1983.

Letter-man,  R. D.  The  Filtration Requirement in  the Safe Drinking Water
Act Amendments  of 1986.  U.S. EPA/AAAS Report,  August 1986.

Logsdon,  G.  S.;  Symons,  J.  M.;  Hoye,  Jr.,  R.   L.;  Arozarena, M. M.
Alternative  Filtration Methods  for  Removal  of  Giardia  Cysts  and  Cyst
Model.  J.AWWA, 73:111-118,  1981.

Logsdon, G.; Thurman, V.;  Frindt, E.;  Stoecker, J.  Evaluating Sedimenta-
tion  and  Various  Filter Media for  Removal  of  Giardig Cysts.   J. AWWA,
77:2:61,  1985.

Logsdon,  G.  S.   Report  for  Visit to Carrollton, Georgia,  USEPA travel
report, February 12, 1987a.

Logsdon,  G. S.  Comparison  of  Some  Filtration  Processes  Appropriate for
Giardia Cyst Removal.  USEPA Drinking Water Research Division; Presented
at Calgary Giardia Conference,  Calgary; Alberta,  Canada,  February 23-25,
1987b.

Long, R.  L.   Evaluation  of  Cartridge Filters for the Removal  of Giardia
lamblia Cyst  Models  from  Drinking Water  Systems.  J.  Environ.  Health,
45(5):220-225,  1983.

Markwell,  D. D., and Shortridge,  K. F.  Possible Waterborne Transmission
and Maintenance of  Influenza  Viruses in  Domestic  Ducks.  Applied and
Environmental Microbiology.  Vol.  43, pp. 110-116, January, 1981.

Morand, J.( M.; C.  R.  Cobb;  R. M. Clark; Richard, G. S.   Package Water
Treatment Plants, Vol. 1,  A  performance Evaluation.  EPA-600/2-80-008a,
USEPA, MERL, Cincinnati,  Ohio,  July 1980.

Morand, J. M,; Young, M.  J.  Performance Characteristics  of Package Water
Treatment  Plants,   Project   Summary.    EPA-600/52-82-101,  USEPA,  MERL,
Cincinnati, Ohio,  March,  1983.

Muraca, P.; Stout,  J.  E.;  Yu,  V. L.  Comparative  Assessment of Chlorine,
Heat, Ozone,  and  UV Light  for Killing  Legionella  pneumophila  Within a
Model Plumbing  System. Appl. Environ. Microbiol., 53(2):447-453,  1987.

Notestine,  T.,  Hudson, J.    Classification of  Drinking Water  Sources as
Surface or Ground Waters.  Final  Project Report.  Office  of Environmental

                                   -3-

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 Health  Programs.   Washington Department of Social  and  Health  Services,
 August  1988.

 Poynter,  S.  F. B.; Slade,  J.  S.   The  Removal  of Viruses by  Slow  Sand
 Filtration,  Prog.  Wat. Tech. Vol. 9,  pp.  75-88, Pergamon Press,  1977.
 Printed  in Great Britain.

 Randall,  A.D.  Movement of Bacteria From a River to a Municipal Well - A
 Case History.  American Water Works Association Journal.  Vol. 62, No. 11,
 p.716-720., November 1970.

 Rice,  E.W.;  Hoff, J.C.     Inactivation  of  Giardia Iambi la  cysts  by
 Ultraviolet Radiation.  Appl. Environ. Microbiol. 42: 546-547,  1981.

 Robeck, G. G.;  Clarke, N.  A.;  Dostal,  K.  A.   Effectiveness   of  Water
 Treatment Processes in Virus Removal.   J.  AWWA,  54(10):1275-1290,  1962.

 Robson, C.; Rice,  R.;  Fujikawa, E.;  Farver,  B.   Status  of U.S. Drinking
 Water Treatment  Ozonation Systems,  presented at  IOA Conference,  Myrtle
 Beach, SC, December 1988.

 Rose, J.  Cryptosporidium  in Water;  Risk of  Protozoan Waterborne  Trans-
mission.   Report prepared for  the Office  of Drinking  Water,  U.S.  EPA,
 Summer, 1988.

 Rubin,  A.  Factors  Affecting   the   Inactivation of Giardia  Cysts  by
Monochloramine and Comparison with other Disinfectants.  Water Engineering
Research Laboratory, Cincinnati, OH,  March 1988a.

Rubin, A. "CT Products for the  Inactivation of Giardia Cysts by Chlorine,
Chloramine, Iodine, Ozone and Chlorine Dioxide" submitted for publication
 in J. AWWA, December 1988b.

 Slezak,  L.; Sims,  R.    The  Application  and  Effectiveness of  Slow  Sand
 Filtration in the United States.  J.AWWA, 76(12):38-43,  1984.

Sobsey,  M. Detection  and  Chlorine  Disinfection  of Hepatitus  A  in Water.
CR-813-024.  EPA Quarterly Report.  December  1988.

Stolarik, G.;  Christie,  D.  Projection  of Ozone C-T Values  Los Angeles
Aqueduct Filtration Plant, 1988.

 U. S. Environmental Protection  Agency, Office of  Drinking Water, Criteria
 and  Standards  Division.   Manual  for Evaluating Public  Drinking  Water
 Supplies, 1971.

 U. S. Environmental Protection  Agency, Office of Drinking Water.  Public
 Notification Handbook  for  Drinking Water Suppliers,  May 1978.

 U. S. Environmental Protection  Agency, Office of  Ground  Water Protection.
 Guidelines for Applicants for State Wellhead Protection Program  Assistance
 Funds Under the  SDWA,  June 1987a.

                                   -4-

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U. S. Environmental  Protection  Agency, Office of Ground Water Protection.
Guidelines for Delineation of Wellhead Protection Area,  June 1987b.

U. S. Environmental  Protection Agency, Office of Drinking Water.  Workshop
on Emerging Technologies for Drinking Water Treatment, April, 1988a.

U.  S.  Environmental  Protection  Agency,   Office  of  Drinking  Water.
Technologies  and  Costs for the  Removal  of Microbial Contaminants from
Potable Water Supplies, October,  1988b.

World Health  Organization Collaborating Center.  Slow Sand  Filtration of
Community Water Supplies in Developing Countries.  Report of an Interna-
tional Appraiser  Meeting,  Nagpur,  India,  Bulletin  Series  16,  September
15-19, 1980.
                                   -5-

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        APPENDIX A

  EPA CONSENSUS METHOD
FOR GIARDIA CYST ANALYSIS

-------
To be^o:  till •ccv^-.C'up-i ;v. Caitoi-j, Ja.y iAzic :•>".:: 2 d:-i ^e a  i:e Rc^n 12 Lafco-.a^v-.:/.   T^.e  ^:-^i.
                   C i^^-xtczc r.ci     "
Methods of Testing  for {Tiardia  in '.'.ater    (George  i'Jay    .sccnceios,  F.e;:;r.^i
                                           Micrcbiologis:.  Region 10 Laj:r-:::
                                           Manchester, '.'.ashingtcnj


Background:

Although recent development of  an excystation  technique  by Drs.  Bin^har,
Meyer, Rice and Schaefer could  in future  lead  to developing cultural  .-nerr.cci,
at this tir.e nn leliable methods exist for culturing  Ciardia cysts iror, -,>a:e:
sairples.  At present, the only  practical  method  for determining the presence
of cysts in water is by direct  r.icroscopic examination  cf  sartple concentrate:
Microscopic detection in water-sample  concentrates  isn't an ideal process.
Finding and identifying the cysts  relies  almost  entirely on the training,
skill, experience and persistence  of the  examiner.   (And it is a skill not
widespread ar.ong water-supply  laboratories.)   But despite its limitations,
microscopic identification is  currently  the best method ue have.

Years ago, the basic assumption was made  that  in order to find Giardia cv~:5
in water, some form of sample  concentration was  necessary.  .As early as l.:3^,
labs ^ere using membrane filters with  a porosity of 0.45 jjr..  V.ith :e.. e^ceptirns,
these attempts uere unsuccessful.  The center  for Disease Centre! has :r:e-
partic^late filtration, with diatomaceous earth  as  the '..odium.  This re:"\ed
the cvsis from the water, but  the  cysts  couldn't be separated from the
particles of diatomaceous earth.

'.••ith the recer.t increase in the incidence of waterbome giardiasis, furtr.er
efforts nave seen made to improve  the  detection  method.  .An ideal metr.c,- •.,;-!-
be one mat recovers all cysts in  a water sample  rapidly, cheaply and si~ly;
allows rapid detection, identification and quantification; and provides
information on the viability of and/or infectivity  potential cf cysts detected..
Unfortunately, no such method exists.   The  methods presently available
can be broadly separated into two  general stages:   primary concentration a:
processing  (see Table 1 on next page),  and  detection and identification
(see Table  2 on next page).

-------
  Methods  of  Testing  for  Ciarciia  in  A'ater  (Continued...)
               HETHC3

               "e-norare
               Ctl iulenc
               PelyCdrsinjte
               !293:afli-5uni)
               P«rv:.i|ie  *i l t.-iti
               vauti-
                etc.)
                   f; ana
-S?nS.  1956

'/per,  OuFfjin 4 nenry
1562, i^njuo'isnea)
                               Sna« et al.  197?
                                    T.T979
                                                    et.jj..  1983
                                             3re*er, wriqnt Sute UN.
                                                  oi isneoj
                                                   . C3HS no,
                                                   l isneo)
                              MSLLTS
                                                                     1  91! /mm ?
                                                              i: PS:.  i5-;ac3  3*1
                                                              ICtii .
                              Generjlly 5002
                              Out poor eUm
                               Gooa '43ij recovery,

                               use.

                               Generally uiisucesjf.


                       , CA    Ovtriil recovery 20'
               y':-:;;-o.s  *a"'woytn Seam.
               • • ':e-s                         196C,  EPA-Ci
               , 7  i ».n srlsn  i pol>5rs!yiene)
                     1979 &    Recovery 3-15i
                               £urac:icn ave. 531
                                              "i!' '.oore Csrj.
                                               .npyoii»n»a;
                               lay  oe '.sefyi 'sr

                               •jsnings

3'.«a''«, j. of «asrt.,  1982      C'.a-irs 75i -ecsve^/
;«"S.sl isnee)                   ?rsis srlcr f  :ers
                                     TAI
                 HETHQD


                 Itwunofluorescen
  11535,  CSCn$  LID, Berkley. CA
  1933
                                                                                R-S'J.'S
                                                                                Gooa prep.. Cross
                 ;FA
  S«ucn, E?».Ctncinn»t1
                                                                  Sti11 unaer stuOy
                                               S
-------
Methods of Testing for Giardia in Water ("Continued...';


Copies of Table 1 and Table 2 are also shown in Appendix C, along with
further detail about the methods.
EPA Consensus Method:

In September, 198C,  the EPA convened a workshop en Giardia methodology in
Cincinnati.  Its main purpose was to identify the best available rr.etr.cdclogy,
and to agree on a reference method.  The five labs in attendance reco^nne-
that any proposed method would be based in large part on opinions and personal
preferences rather than on hard data, but that agreeing on a consensus r.e--.;c
would promote uniformity and provide a basis for future comparisons.  Cur
lab has modified the EPA consensus method slightly for our use.  This method
is outlined below.
                        Filter  unwound  into quarters

                                     I
                Rinsed  in  distilled water with polysorbate 20

                                     I
                     Settled  overnight, or centrifuged

                                     i
               Collect  sediment and add 2' Formaldehyde in PBS

                                     i
                     Settled  overnight, or centriruged
                            Collect  sediment

                                     i
   Sucrose  or                                             . „
  Percoll-sucrose
   gradient
                   ^licroscopic observation of the entire
                  concentrate  (Bright fie Id/Phase- contrast)

-------
AP?EM'I\
CGN'CENTRATINC,  PROCESSING, DETECTING AND IDENTIFY I \G
riARTTA CYSTS  IN '.•,'ATER
Tk
                                ac^-iou/id -t /:;(:• -via -tec/:  iacoc-x
                      fe,  "Mctni'ii  ;•,'  Teittr.g  fo-i G-c^iica -c>i
          c-Ki, a^d  •';-. a;:  :'u.t£-o:c o-'  the mcd<.«<.id E?A  C-
            J      W                  *.           trf

-------
   £MDIXC:  CONCEMTRATING, P?OCESS!VJG
nE'ECTING AMD IDENTIFYING GIAPHIA 'CYSTS 'N WATE7
    "ETHQD
PJVFS'IGATOP (S)
P.£SULTS
    DO! vcirM nate
    '293mm-Sum)
2.  Participate Filtration
    (diatomaceous earth,
    etc. )
    Alga* (Foe^st) C
4.   Aninnic and Cationic
    Exchange Resins
                     Ralston
                                    Chang and Kabler
DyDer,  DuFrain and Henry  Eng
19«?, (unpublished)
Shaw et al ,  1977
    Tube F1' 1 ters
Holman et a]_, 1983
DHHS,  VJaTliington
Brewer,  Wright State UN.
(unpublished)

Riggs, CDHS Lab, Berkley, CA
(unoublished)
                                 Generally unsuccessful
Passing 1 gal/mi o a
10 PSI. 15-1800 gal
total

Generally gooc1
but poor eluation
Good rapid recovery,
but 1 i mi tod in fie! d
use

Generally unsuccessful
Overall  recovery  20-80
percent
    C" -i i t o r 2
    '" anr( ijn orlon anc^
    00"! voro1 vl ena)
              ^ssette
    F i Tterwashing Apparatus
J?i-jjbowski,  Erickson, 1979 and
1980, EPA-Cincinnati
Milliner* Corp.
(unpuM ish
DuWalle, U. cf Wash., 1982
       i sh*d)
Recovery  3-15 oe^c
Extraction  ave.  38
percent
'lay  be  useful  -or
process:ng  fi1ter
v/ashings

Claims  "5 percent
recovery  fron orl
filters"
                                     TABLE 1

-------
SETECTI^G AND :DE.kr:-Y?jG GIASDIA CY$~  IN  V
                    PRIMARY CONCENTRATION  AMP  PROCESSES METHODS
1.  MEV3RAME FILTER (MH METHODS

     a.   rqiulosic (!m'xed esters of ce1
              Cham and fabler ;n 1955
              First to use '-'F for cyst recover/.   Recovered 20-42 oercent  3t
              concentration of 3, 5,  and 10 cyst/gal.  - nn c>'St *oun-t at
              \ cyst/gal.

              M»tnrM was used 1-n 1965 Colorado outbreak 'Moore, _e_t aj_,  1959)
              ? liter size water samples from 10  sites.  No cysts~~wei"e  de*2:
              Use i* cellulosic filters have generally not been successfu1  *
              Demonstrating cysts vn  drinkinq w^ter.
         Polycarbonate
         1.    Luchtel  and folleaqes  {n  I960 used 293 mm,  5.0 jm pore size
              nudeooor-? f»C)  filters to  concentrat0 fomali n-fixe^.  G.
              c.vsts fron 20 L  tap  water samples.   Recovery rates o£ ap5"ro
              75 percent were  reoortel.

         2.    pyper of OuFrain ^nd Henry  Engineers c^in  good recovery witn
              nucleoporp filt?r at =»  Tow rate of 1 gal. /mi n.,  not cv-sr II
              oassing  15-1800  gal.  in  iust over 24 hours.

         Even  with these claims v ^j^^  and Luchte1, the  'IF '1ethod h^s j"'
         (Asoen,  19^^) been successful  in demonstrating cysts in water--;--:
         Decause:

         1.    Inability to process a  sirf";cient volume.

         2.    Inability to remove  "ysts from M^ter.

         "?.    Cysts weren't present  at  time of sampling during  cr afte" c>t
     a.   S°.t|f)  -  CDC  (Shaw,  1977)  used  high-vol  filtration through
         TarF filter (280,000 qal.  tota^ove" 10 days) - was backf1ush3^  --.: '
         gal.  drums  and coagulated  w/alum.   Concentration fed to beagle D..::'5;
         an^ after treatment  (chees^oth  to wire screening to 30 »m '•'•' t:
         centrifuge)  was examined microsconically.   First time cysts obs«srvr: •
         water suooly after concentration.

     b.   niatomaceous earth (HE)  -  CDC iJuranek, 1979) used DE to remove :-s:;
         fro-  seeded '.vat er.  PFob^m was  fat cysts couldn't be removes •'-:- ~~
         Darticles.   3rewer (1983)  claims  5.2-31.1  percent recovery frcri I:
         backwash.   Retention thro'ign  3  'o"*^ (celit'j ^05, HyFl o-Sucer:e'  j- •
         c°lite  5^0)  at cyst  concentration Banging  from 6-15,000 cyst/^.   : '  •
         rjnge hetweon 66-100 percent.

-------
                     ,  PROCESS IMP,,
         IDENTIFYING GIARHIA CYSTS  IN  UAT-
V.GAE CENTRIFUGE

a.  '/.'as found to recover more cysts  (10X)  than  a  series  of  MF-f liters and
    nylon screens: 3 vs. 1 day by  MF.

b.  Mav be impractical  in field because  of power  requirement.

c.  If 'jsed in lab, 1 large single sample  collected  in  the  field  could niss
    cyst.

* .  May *ind application for concentration cysts  from orlon filter  washings.

ArO'lIC AMD CATIOUIC EXCHANGE RESIMS (Brewer -  unpublished)

a.  ^ased on hypothesis t*at cysts could be attracted to charged  surfaces,
    cvsts have a charg0 of approximately 25mV at  pH  5.5  which  increases  in
    3lectro-neqativity as the pH rises to  8.0.

b.  Charge attraction techniques have been used for  concentration of  both
    bacteria and viruses in water.

c.  Five °xchanQe resins were tested:
         (1.  4° percent recovery  fron anionic  Oowex 1-XY  colunns
         (2.  38 percent recovery  from cationic Dowex 50W-X8 columns

*.  Conoared to parallel tests w/diatomaceous earth, exchange resins  'ess
    qcficient in retention.

RALC'QH E?Oyv-FIBF.RGLAS$ TUBE FILTERS
a.   Riggs of CSHD, Viral and Rick.  Lab.,  can ^ilter 500 gallons dr^'nXT-g
    water thru VO" - 9 wn Balston tube filter.

b.   Backflushes w/1 L 3 percent beef extract or solution of 0.5 percent
    potassiun citrate.

c.   Concentration is centrifuged w/40 oercent potassium citrate and -id-' 2
    layer filtered thru *> u polycarbonate filters.

d.   Uses direct irriunofluorescence antibody technique for detection and
    identification.

e.   Claims ?0-30 percent efficiency in collection, coprocessing and ::.

            YARN'-IOVEN nEPTH FILTERS
a.  In 1975 E°A develooed a concentration-extraction method invoiv
    volumes of water thru .Tiicroporous  yarnv/oven orlon-fiber fil'ers

b.  This nethod has been tenatively adopted as the "method of chc-:-:
    concentrating cysts from water Sij

-------
0£TECTIV."3 AND ^ENT
                                 , PROCESSING,
                                 GIA^OIA CYS'S IN '.'ATE*
C4;
7.
8.
            c.  Since initial studies which showed onlv 3-15 percent recovery  wi tn  a  mean
                o* 6.3 percent an* a 53 percent extraction rate, several  chang2s  have Deen
                made which may have increase;! the retention rate to >20 percent.

                     1.  Gone from 7 to 1 urn porsity filter
                     2.  Limited the ra*e of flow to 1/2 gallon/min
                     3.  Limited the pressure head to 10 PSI
                     4.  Have gone to po
-------
          AMD  IDENTIFYING dlARPIA CYSTS IN W.VER
                                  HETECTIOM METHODS

l.a.  niRECT CLUORESCEMT ANTIBODY (QRA^  TECHNIQUE

     1.  Riggs has oroduced a high titer purified inrnune  ssra  to  Gi'ardi'a  lamblia
         cysts in guinea pigs and labeled it with Huorecein  isotfiio  cyanate"   iera
         is puri'ied thru NfyOH and DEAE sefadex fractionation.

     2.  Obtained cross reactions with Chilonastix mesnili  cysts  but  claims  it  can
         be easily distinguished from Giardia by its  smaller  size.

i.b.  INDIRECT FLUORESCENT ANYBODY (IFA) TECHNIQUE

     1.  Sauch using IFA with immune sera from rabbits  (unourif ieri) .   It  is  reacted
         with commercially available fluorescent-labeled  goat  anti-rabbit gamna
         globulin.

     2.  Some cross-reactions with certain algal  cells.

I.e.  MONOCLONAL AMTIROOIES
     1.  Using clones of hybridoma cell  lines obtained by  fusing  mouse myeloma
         cells with sn^en cells from mice (BALB/c)  immunized  with G.  lamsi ia
         troohozoites.
     2.   ^ro^uced eight monoclonal  antibodies evaluated by IFA against 3oth trcnns
         3PH cysts.
         a.   3/8 stained the ventral  d-'sk
         b.   2 staine^ the nuclei
         c.   2 stained cytoplasm^'c  granules
         ri.   2 stained membrane comnon^nts

     3.   Variaoility in staining may  be due to differences in stages of eicystrer.t.

     4.   Preliminary results ind;>;ate nonoclonal  ABs may give rapid and specific ID
         o* cysts.
     5.   Rx may be too specific, not reacting with all  human forms of G_. lanbli
         may have to go to polyclonal
?..    EL ISA
     a.   Hungar at John Hopkins (unpublished) has produced a Detection method by
         ELISA using a intact "sandwich" technique in 96-wel1  microtiter olatos.

     b.   Using antisera from 2 different animals (may present problen).

     c.   He«d a minimum of 12 cysts/we!1 for color Rx .

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            APPENDIX B
INSTITUTIONAL  CONTROL OF LEGIONELLA

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                               APPENDIX B
                   INSTITUTIONAL  CONTROL  OF  LEGIQNELLA

       LegionelU is a genus name for bacteria commonly found  in  lake and
river  waters.   Some species of  this  genus  have been identified  as  the
cause of the disease legionellosis.  In particular, Legione 11 a  pneumophila
has  been  identified as  the cause of Legionnaires  disease, the  pneumonia
form of legionellosis and  with  Pontiac  Fever,  a nonpneumonia  disease.
Outbreaks  of legionellosis are primarily associated with inhalation  of
water   aerosols  or,  less  commonly,  with  drinking  water  containing
Legionella  bacteria with  specific  virulence  factors  not  yet  identified.
Foodborne outbreaks have not been reported (USEPA, 1985).
      As discussed in  this document,  treatment requirements for  disinfec-
tion of a municipal water supply are thought to provide at least a 3 log
reduction  of Legionella  bacteria  (see  Section  3.2.2).   However,  some
recontamination  may  occur in  the  distribution system due  to  cross
connections  and  during  installation and  repair of water mains.   It has
been  hypothesized  that  the low  concentrations  of   Leoionella  entering
buildings  due  to  these  sources  may  colonize and  regrow  in hot  water
systems  (USEPA,  1985).    Although  all  of  the  criteria  required  for
colonization are not known,  large institutions, such as hospitals, hotels,
and public buildings with recirculating hot water systems seem  to be the
most susceptible.  The control  of LegloneVIa  in health care institutions,
such  as  hospitals,   is  particularly  important  due to  the  increased
susceptibility of many of the patients.   The colonization and  growth of
Legionella  in  drinking  water primarily occurs  within  the consumer's
plumbing  systems  after  the  water  leaves  the  distribution  system.
Therefore,  the  control   of  these  organisms  must  be  the  consumer's
responsibility.  This appendix is  intended  to provide guidance  to these
institutions for the detection and control of the Legionella  bacteria.

B.I   MONITORING

       It  is  suggested  that   hospitals,  and  other  institutions  *un
potential  for  the  growth  of  Legionella. conduct routine monitoring  of
                                   8-1

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   their hot water systems at least quarterly.1  The analytical procedures
   for  the  detection of  these  organisms  can  be  found  in  Section  912.1
   "LeglQne11a.ceag" of the 16th edition of Standard  Methods.  Samples should
   be taken at, or closely following,  the  hot  water storage reservoir and
   from a number of shower heads.   It is recommended that showers with the
   least frequent usage  be  included  in  the sampling program.   Follow-up
   testing  is suggested for all positive indications prior to the initiation
   of any remedial measures. If the the presence of  Leoionella is confirmed,
   then  remedial  measures should  be  taken.    Although  the  regrowth  of
   Lec-ionella  is commonly associated with hot  water systems,  hot and cold
   water interconnections may  provide a pathway for cross contamination.  For
   this reason, systems detecting Leoionella  in hot water systems should also
   monitor  their cold water systems.

   B.2    TREATMENT

         Because  the  primary   route  of exposure to  Legionella  is probably
   inhalation,  rather than ingestion,  it  is recommended  that disinfection
   procedures include an  initial shock  treatment period to disinfect shower
   heads  and hot water taps where  the bacteria may colonize and  later become
   airborne.  The shock treatment  period should  also include disinfection of
   hot  water tanks.  After this time,  a point-of entry treatment system can
  be installed to provide continual disinfection of the hot water system.

         B-2.1   Initial Disinfection
         The most applicable method  for the initial disinfection of shower
  heads and water taps  is heat eradication.  The fittings  can  be removed and
  held  at temperatures greater than 60 C for at least 24 hours.  Disinfec-
   tion  of fittings can also be achieved by soaking  or rinsing with a strong
  chlorine solution.  When soaking the fittings, a minimum chlorine strength
  of 50 mg/L should be used for a period of no less than 3 hours.  Rinsing
Monitoring frequency based on the reported rate of Legionella regrowth observed
during disinfection studies  (USEPA, 1985).

                                     B-2

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with chlorine should be performed with  more concentrated solutions.  Care
must  be  taken  not  to  corrode  the  finished  surface  on  the  fittings.
Commercially available bleaches, for example, are typically  5.25 percent
chlorine  by weight.

      B.2.2  Long-Term Disinfection
      Heai  -  Numerous  studies have shown that  increasing the  hot water
temperature to 50 - 70 C over  a period of several hours may help to reduce
and inhibit Legionella populations.  However, some instances of regrowth
after 3 to 6 months have been  reported.  In these cases, the authors have
concluded that a periodic  schedule of short-term temperature elevation in
the hot water may  be an  effective control  against legionellosis (USEPA,
1985; Muraca, 1986).  Disinfection by  this method also requires periodic
flushing  of faucets and  shower  heads with  hot  water.   Although  heat
eradication is easily implemented and relatively inexpensive, a disadvan-
tage is the potential need for periodic disinfection.  The potential for
scalding from the unusually hot water also exists (USEPA, 1985; Muraca, et
al. 1986).
      Chlorination - Several  studies have suggested that a free chlorine
residual of 4 mg/L will eradicate Legionellq growth.  There is, however,
a  possibility  for  recontamination  in areas  of the  system  where  the
chlorine residual drops below  this level.  A  stringent monitoring program
is therefore required  to  ensure that  the proper residual  is maintained
throughout the system and under varying flow conditions.  It may also be
necessary to apply a large  initial  chlorine  dose to maintain the 4 mg/L
residual.   This  may  cause problems of pipe  corrosion  and,  depending on
water quality, high  levels of trihalomethanes  (THMs).
      Ozone -  Ozone is  the most powerful oxidant  used  in  the  potable
water industry. One  study indicated  that  an  ozone dosage  of 1 to 2 mg/L
was sufficient to provide a  5  log reduction of  legionella (Muraca, et al.
1986).  Ozone is  generated by  passing a high voltage  current of electrici-
ty through  a stream of dry  air or oxygen.   The  use of  high voltage
electricity  requires  proper  handling  to   avoid  creating  hazardous
conditions.  The ozone  is applied by  bubbling the  ozone  containing gas
through the water  in a chamber called  a contactor.

                                   B-3

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      One  of the  disadvantages  of  this system  is  its complexity.   it
requires a dry air or oxygen source,  a generator,  and a contactor sized to
provide 2 to 5 minutes of contact time  and an ambient ozone monitor.  All
materials  in contact with the ozone must be constructed of special  ozone
resistant materials to prevent leakage.  Leak detection is also required
because of the toxic nature of ozone  and possible explosive conditions if
pure oxygen  is used for generation.
      Another  disadvantage  of ozonation is  the  rapid decomposition  of
ozone residuals.   The  half-life  of ozone in  drinking  water is  typically
around  10  minutes.    This  makes it  difficult,  if  not   impossible,  to
maintain a residual throughout the water system and may require the use of
a supplementary disinfectant such as  chlorine or  heat.  For these reasons
it is not thought  that ozonation is viable for institutional applications.
      Ultraviolet  Irradiation - Ultraviolet  (UV)   light,   in  the  254
nanometer wavelength  range   can  be  used as  a  disinfectant.   UV systems
typically contain  low-pressure mercury vapor lamps  to maximize output in
the 254 nm  range.   Water entering the unit passes  through a clear cylinder
while the lamp is  on, exposing bacteria to the UV  light.  Because UV light
can  not  pass  through  ordinary  window glass,  special  glass  or  quartz
sleeves are used  to assure adequate exposure.
      The intensity of UV  irradiation is measured  in microwatt-seconds per
square centimeter (uW-s/cm2).   Several studies  have  shown  a 90 percent
reduction of Legionella with a UV dosage of  1000 - 3000 uW-s/cm2, compared
to 2000 to 5000 uW-s/cm2  for E. coli. Salmonella and Pseudomonas (USEPA,
1985).  In  another study,  a 5  log reduction of  Legionella was achieved at
30,000 uW-s/cm2;  and the reduction was more rapid than with both  ozone and
chlorine disinfection  (Muraca, et al. 1986).
      The major advantage of UV disinfection is  that  it does not require
the addition of chemicals.  This  eliminates the storage and feed problems
associated with the use of chlorine, chlorine dioxide and chloramines.  In
addition, the only maintenance required  is periodic  cleaning of  the quartz
sleeve and replacement of bulbs.   UV  monitors are available which measure
the  light  intensity reaching  the water  and provides a signal to the user
when maintenance  is required.  These monitors  are strongly suggested for
any  application of UV  irradiation for disinfection.   It should  be noted,

                                   3-4

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 however,  that these monitors measure  light  intensity which may  not  be
 directly  related  to  disinfection  efficiency.    The UV  lamps  should
 therefore not  be  operated  past  the  manufacturers  use  rating  even  with a
 continuous UV  monitor  installed.
      Another  disadvantage of UV disinfection,  as with ozonation, is that
 a residual is not provided. A supplementary disinfectant may therefore be
 required  to   provide  protection throughout  the system.   In  addition-,
 turbidity may  interfere  with UV disinfection  by blocking  the passage of
 light to the microorganisms.

 B.3   OTHER CONTROL METHODS

      In  addition to  chemical  and  heat disinfection, there  are  system
modifications  which can  be made to  inhibit  Legionella  growth.    Many
 institutions have large hot water tanks  heated  by coils located midway in
the tank.  This type of design may result  in areas near the bottom of the
tank which are not  hot enough  to kill  Leoionella.   Designing tanks for
more even distribution of heat may help  limit bacterial colonization.  In
addition, sediment  build-up in  the bottom  of  storage tanks  provides a
surface for colonization.   Periodic draining  and cleaning may therefore
help control  growth.   Additionally,  other  studies have  found  that hot
water systems with stand-by hot  water tanks used for meeting peak demands,
still tested  positive  for  Legione11 a  despite  using elevated temperature
 (55 C)  and chlorination  (2 ppm) (Fisher-Hoch,  et  al.  1984.)   Stringent
procedures for the cleaning,  disinfection and monitoring of these stagnant
tanks should be set up and followed on  a regular basis.
      In  another  study,  it  was reported  that  black  rubber  washers and
gaskets supported Legione11 a growth by  providing habitats protected from
heat and chlorine.   It was found,  after replacement  of the black rubber
washers with  Proteus 80  compound washers,  that it was not  possible to
detect Leqionella from any of the fixtures (Colbourne, et al. 1984).
                                   B-5

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 B.4    CONCLUSIONS

       LeQionella bacteria have been identified as the cause of the disease
 legionellosis,  of  which the most serious form  is  Legionnaires  Disease.
 Although conventional water treatment  practices  are sufficient to provide
 disinfection  of Legionella.  regrowth  in buildings with  large hot  water
 heaters,  and  especially  with  recirculating hot  water systems,  is  a
 significant problem.  This problem is of particular concern to health care
 institutions, such as hospitals, where patients may be more susceptible to
 the disease.
       This  guideline  suggests  a program  of 'quarterly monitoring  for
 Legionella.   If the monitoring program suggests a potential  problem with
 these organisms, a two stage disinfection program is suggested consisting
 of an  initial  period  of shock treatment followed  by long term disinfec-
 tion.
       Four  methods  of disinfection for the control of  Legionella were
 presented in this appendix; heat, chlorination,  ozonation, and ultraviolet
 irradiation.   All  four of the methods  have  proven  effective in killing
 Legionella.    Ultraviolet  irradiation  and  heat  eradication  are  the
 suggested  methods   of  disinfection  due,  primarily,   to advantages  in
monitoring  and maintenance.   However, site  specific  factors  may make
chlorination  or ozonation more  feasible  for certain  applications.   In
 addition, it is recommended  that all outlets, fixtures and shower heads be
 inspected and all black rubber washers and gaskets  replaced with materials
which do not  support  the growth of Legione11 a organisms.
      One  problem  associated with  the  application   of point-of-entry
 treatment  systems   is  the  lack  of  an  approved program  for certifying
 performance claims.   However, the National  Sanitation  Foundation  (NSF),
 Ann Arbor, MI an unofficial, non-profit organization, does have  a testing
 program to verify disinfection efficiencies and materials of construction.
 Certification by the NSF, or other equivalent organizations,  is  desirable
 when selecting  a treatment  system.
                                   B-6

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References

Colbourne, J.; Smith, M. G.; Fisher-Hoch,  S.  P. and Harper, D.  Source of
Legionella  pneumophila   Infection  in  a  Hospital  Hot  Water  System:
Materials  Used  in Water  Fittings  Capable of Supporting  L.  pneumophila
Growth.   In:  Thornsberry,  C.; Balows, A.; Feeley, J. C. and Jakubowski,
w.  Legione 11 a -  Proceedings of the 2nd International  Symposium.  American
Society for Microbiology, pp. 305-307, 1984.

Fisher-Hoch, S. P.;  Smith,  M.G.; Harper, D. and Colbourne, J.  Source of
Legionella  pneumonia  in  a  Hospital  Hot  Water  System,  pp. 302-304  in
Thornsberry, C.; Balows,  A.; Feeley, J.C. and Jakubowski,  W.  Legionella
Proceedings of  the  2nd  International  Symposium,   American  Society for
Microbiology,  pp. 302-304,  1984.

Muraca,  P.;  Stout,  J. E.  and   Yu,  V.  L.    Comparative  Assessment  of
Chlorine,  Heat,  Ozone,  and UV Light  for  Killing  Lepionella pneumophila
Within a Model  Plumbing System.   Appl.  Environ. Microbiol.  53(2):447-453,
1986.

U.S. Environmental Protection Agency, Office of Drinking Water.  Control
of Legionella in Plumbing Systems, Health Advisory (1985).
                                   B-7

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         APPENDIX C

DETERMINATION OF DISINFECTANT
        CONTACT TIME

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                               APPENDIX C
               DETERMINATION OF DISINFECTANT CONTACT TIME

      As indicated in Section 3,  for pipelines, all fluid passing through
the pipe is assumed to have a detention time equal to the theoretical  or
mean residence time at a particular flow rate.  However, in mixing basins,
storage  reservoirs,  and  other treatment plant process  units,  utilities
will be required to determine the contact time for the calculation of CT
through tracer studies or other methods approved by the Primacy Agency.
      For  the purpose of  determining  compliance with  the  disinfection
requirements  of the SWTR,  the contact  time  of mixing basins  and storage
reservoirs used in calculating CT should be the detention  time at which 90
percent  of the water  passing  through  the  unit  is  retained within  the
basin.   This  detention  time  was  designated as  Tlo  according  to  the
convention adopted by Thirumurthi (1969).  A profile of the flow through
the basin  over time  can  be generated  by  tracer studies.   Information
provided by these studies is used for estimating  the detention  time,  T,0,
for the purpose of calculating CT.
      This appendix  is divided  into  two sections.   The  first section
presents a brief  synopsis  of  tracer study  methods,  procedures, and data
evaluation.   In  addition,   examples are presented  for  conducting hypo-
thetical tracer studies to determine the T10 contact  time in a clearwell.
The second section presents a method of  determining  T10 from theoretical
detention  times  in systems  where it   is impractical to  conduct  tracer
studies.

C.I  Tracer Studies
      C.I.I  Flow conditions
      Although detention  time is proportional to flow, it  is not generally
a  linear  function.    Therefore,  tracer studies  are  needed  to  establish
detention  times  for  the  range  of  flow  rates  experienced within  each
disinfectant section.
      As discussed in Section 3.2, a single flow  rate may  not characterize
the  flow  through  the entire  system.   With a  series  of  reservoirs,
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cleanvells, and storage tanks flow will vary between each  portion of the
system.
       In  filter  plants,  the plant  flow is relatively uniform  from the
intake  through the  filters.   An  increase or  reduction  in the  intake
pumping capacity will impart  a proportional change in flow through each
process unit prior to and including the filters.  Therefore, at a constant
intake pumping rate  flow variations between disinfectant  sections within
a treatment plant, excluding clear-wells, are likely to be  small, and the
the design  capacity  of  the plant,  or plant flow,  can  be  considered the
nominal flow rate through each individual process unit within the plant.
Clearwells  may operate  at  a  different flow rate  than the rest  of the
plant, depending on  the pumping capacity.
       Ideally, tracer tests should be performed for at least  four flow
rates  that  span  the  entire range of flow  for the  section being tested.
The flow  rates should be separated by  approximately  equal  intervals to
span the range of operation, with one  near  average  flow, two greater than
average,  and  one  less  than  average  flow.   The  flows  should  also be
selected so that  the  highest test flow rate is at leaste 91 percent of the
highest flow  rate expected to  ever occur  in  that section.   Four data
points will assure a  good definition of the section's hydraulic profile.
      The results of  the tracer tests performed for different flow  rates
should be  used to generate plots  of  T10 vs.  Q for each  section in the
system.  A smooth  line is drawn through the points on each  graph  to create
a curve from which T10 may  be  read  for  the  corresponding Q at peak hourly
flow conditions. This procedure is presented in Section C.I.8.
       It may not be  practical for all systems to conduct studies at  four
flow rates.  The number of  tracer tests that are practical to conduct is
dependent on  site-specific restrictions and resources available to the
system.   Systems with  limited  resources  can  conduct a  minimum of one
tracer test for each disinfectant section at a  flow rate of not  less  than
91 percent of the highest flow rate experienced  at  that section.  If only
one tracer  test  is  performed,  the  detention time determined by the  test
may be used to provide a conservative estimate in CT calculations for that
section for all  flow rates  less  than or  equal to the tracer  test  flow
rate.  T10 is  inversely proportional to  flow rate,  therefore, the T10 at a
                                   C-2

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 flow  rate other than that which the tracer study was conducted (Tlos) can
 be  determined  by  multiplying  the  T10 from the tracer  study  (T,OT)  by the
 ratio of the tracer study flow rate to the desired flow rate, i.e.,
                         Tios * TIOT x QT/OD where
      T!l3S » T,3 at system flow rate
      Tior s Tio at tracer flow rate
      QT   » tracer study flow rate
      Q0   » system flow rate

      The most accurate tracer test  results  are obtained when  flow is
constant through  the section  during  the  course  of the test.   Therefore,
the  tracer  study  should   be  conducted  at  a   constant  flow  whenever
practical.  For  a treatment plant consisting of  two  or more equivalent
process trains, a constant flow tracer test  can be performed on a section
of the plant by holding the flow through  one of the trains constant while
operating the  parallel  train(s)  to absorb any  flow  variations.   Flow
variations during tracer tests in  systems without  parallel trains or with
single clearwells and storage reservoirs  are more difficult to avoid.  In
these instances,  Tlo should  be  recorded at the average  flow rate over the
course of the test.

      C.I.2  Other Tracer Studv Considerations
      In addition to flow conditions, detention times determined by  tracer
studies are dependent  on the  water level in the contact basin.   This is
particularly pertinent  to storage tanks, reservoirs,  and clear-wells  which,
in addition to being contact basins for  disinfection are also often used
as  equalization   storage  for distribution  system  demands.    In such
instances, the water  levels  in the  reservoirs  vary  to meet the  system
demands.  The actual detention  time of these contact basins will also vary
depending on whether they are emptying or filling.
      For some process units,  especially sedimentation basins which are
operated at a near constant level, that  is, flow  in equals flow out, the
detention time determined by tracer tests is valid for calculating CT when
the basin is operating  at water levels greater than  or equal  to the level
at which the test was  performed.    If  the water level during testing is

                                   C-3

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higher  than  the normal  operating  level,  the  resulting  concentration
profile  will  predict an  erroneously  high detention time.   Conversely,
extremely low water levels during  testing  may lead to an overly conserva-
tive  detention  time.    Therefore,  when  conducting  a  tracer study  to
determine the detention time,  a water  level  at or slightly below,  but not
above, the normal minimum operating level  is recommended.
      For many  plants,  the water level in  a  clear-well or storage  tank
varies between  high and  low  levels  in response to distribution  system
demands.  In such instances, in order to obtain a conservative estimate of
the contact  time,  the  tracer  study should be conducted during a  period
when  the  tank  level is  falling (flow  out greater  than flow  in).   This
procedure will  provide  a detention  time for the contact  basin which  is
also  valid when  the water level is rising  (flow out less  than flow in)
from a level  which is at or above the level when the T10 was determined by
the tracer study.   Whether the  water  level  is  constant or variable, the
tracer study  for each  section should be  repeated  for  several different
flows, as described in the previous section.
      For clearwells which are operated with extreme variations in water
level, maintaining  a CT  to comply with inactivation requirements  may be
impractical.  Under such operating conditions,  a reliable detention time
is not provided for disinfection.  However,  the system may  install a weir
to ensure a minimum water level and provide a 'reliable detention  time.
      Systems comprised  of  storage reservoirs that  experience seasonal
variations in water levels may perform tracer studies during the  various
seasonal  conditions.  For these systems, tracer tests should be conducted
at several flow rates and representative water  levels that  occur for each
seasonal  condition.  The results  of these  tests can be used to  develop
hydraulic profiles of the reservoir for each water  level.   These profiles
can be plotted on the same axis of T10 vs.  Q and may  be  used for calculat-
ing CT for different water levels and flow  rates.
      Detention  time may also be  influenced by  differences in water
temperature  within  the  system.   For plants with  potential  for  thermal
stratification,  additional tracer studies  are  suggested under  the various
seasonal  conditions which  are  likely  to occur.    The  contact   times
determined  by  the tracer studies under the various seasonal conditions
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 should  remain valid as long as no physical  changes are made to the mixing
 basin(s)  or  storage reservoir(s).
      As  defined  in  Section 3.2.2,  the  portion  of the  system  with  a
 measurable  contact time between two points of  disinfection  or residual
 monitoring   is  referred  to  as  a  section.    For  systems  which  apply
 disinfectant(s) at more than one point,  or choose to profile the residual
 from  one  point of application, tracer  studies  should  be conducted  to
 determine T10 for each section  containing process unit(s). The T10 for a
 section may or may not include  a length of pipe and is used along with the
 residual  disinfectant concentration prior to the next disinfectant appli-
 cation or monitoring point to  determine the CTCJ|C for that section.  The
 inactivation  ratio for  the   section  is then  determined.    The  total
 inactivation  and  log  inactivation  achieved  in the  system  can  then  be
 determined  by  summing  the  inactivation  ratios for   all  sections  as
 explained in Section 3.2.2.
      For  systems that  have  two or more units  of identical  size  and
 configuration,  tracer  studies   only  need  to  be conducted on  one  of  the
 units.  The  resulting  graph  of T10 vs. flow can be used to determine  T,.
 for all identical units.
      Systems  with more  than   one  section in  the  treatment  plant  may
 determine T10 for  each  section
            by  individual tracer studies through each section, or
            by  one tracer study across the system

      If possible, tracer studies should be conducted on each section to
determine the T10  for each section.   In order to minimize  ihe time needed
to conduct studies on each section,  the tracer studies should be started
 at the last section of  the treatment  train prior to the first customer and
completed with  the first section of the  system.  Conducting the tracer
 studies in  this order will prevent  the  interference  of residual tracer
material with subsequent  studies.
      However,  it may  not  always be  practical  for systems  to conduct
 tracer studies  for each section because of time  and manpower constraints.
 In these  cases, one tracer study may be used to determine the T   values
                                   C-5

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for  all  of the sections at one flow rate.   This  procedure  involves the
following  steps:
         1.  Add tracer at the beginning of the furthest upstream disinfec-
            tion section.
         2.  Measure the tracer concentration at the end of each disinfec-
            tion section.
         3.  Determine the T10 to each monitoring point as outlined in the
            data evaluation examples presented in Section C.I.7.
         4.  Subtract Tlo values of each of the  upstream sections from the
            overall  Tlo  value  to determine  the Tlo  of  each  downstream
            section.
      This  approach  is valid  for a series  of two or  more consecutive
sections as long as all process units within the sections experience the
same flow  condition.   This approach is  illustrated by  Hudson (1975) in
which  step-dose tracer  tests were  employed  to  evaluate  the  baffling
characteristics of flocculators and settling basins at  six water treatment
plants.  At one plant, tracer chemical was added to the rapid mix, which
represented the beginning  of the furthest upstream disinfection section in
the  system.   Samples  were  collected from the  flocculator  and settling
basin outlets and analyzed to determine the residence-time characteristics
for each section.   Tracer  measurements at the flocculator outlet indicated
an approximate  T10  of 5 minutes through the rapid mix,  interbasin piping
and flocculator. Based on tracer concentration monitoring  at the settling
basin outlet,  an   approximate  T10 of  70  minutes was  determined  for the
combined sections,  including  the rapid  mix,  interbasin piping,  floccu-
lator,  and settling basin. The flocculator T10 of 5 minutes was subtracted
from the combined sections'  T10 of 70 minutes,  to determine the T,0  for the
settling basin  alone,  65  minutes.
      This  approach may  also be applied  in  cases  where  disinfectant
application  and/or  residual  monitoring  is  discontinued   at  any  point
between two or  more sections  with known  T10 values.  These Tlo values may
be summed  to obtain an equivalent T]0 for the combined sections.
      For  ozone contactors, flocculators  or any basin containing mixing,
tracer  studies  should be conducted  for  the  range of  mixing  used in the
                                   C-6

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process.   In ozone  contactors, air or oxygen should be added  in  lieu  of
ozone  to  prevent degradation of  the  tracer.   The flow  rate  of air  or
oxygen  used  for  the  contactor should  be  applied during  the study  to
simulate actual  operation.   Tracer studies should then be conducted  at
several air/oxygen to water ratios to provide data for the complete  range
of ratios used at the plant.  For flocculators,  tracer studies should  be
conducted for various mixing intensities to provide data for the complete
range of operations.

      C.I.3  Tracer Study Methods
      This  section  discusses  the  two  most  common   methods  of  tracer
addition employed in water treatment evaluations,  the step-dose method and
the slug-dose method.   Tracer study methods involve  the  application  of
chemical  dosages  to  a  system   and  tracking  the  resulting  effluent
concentration as a function of time.  The effluent concentration profile
is evaluated to determine the detention time,  Tlo.
      While both tracer test methods can use the same tracer materials and
involve measuring the  concentration of tracer with time, each has distinct
advantages and disadvantages with  respect  to  tracer  addition  procedures
and analysis of results.
      The step-dose method entails introduction of a tracer chemical at a
constant dosage until the concentration at the desired end point reaches
a steady-state  level.  Step-dose tracer studies are frequently employed in
drinking water applications for the following  reasons:
            the  resulting  normalized  concentration  vs. time  profile  is
            directly used to determine, T10, the  detention time required
            for calculating CT
            very  often,  the  necessary  feed equipment  is available  to
            provide a constant rate of  application of  the tracer chemical

      One other advantage of the  step-dose  method is that the data may be
verified by comparing  the  concentration  versus  elapsed time profile for
samples collected at  the  start of dosing  with  the profile obtained when
the tracer feed  is discontinued.
                                   C-7

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      Alternatively, with the slug-dose method,  a  large instantaneous dose
of tracer is added to the incoming water and  samples are taken at the exit
of the unit over time as  the tracer passes through the unit.   A disadvan-
tage of this technique  is  that  very concentrated solutions are needed for
the  dose  in order  to  adequately define  the concentration   versus  time
profile.   Intensive  mixing  is  therefore required to minimize  potential
density-current  effects  and to  obtain  a  uniform distribution  of  the
instantaneous tracer dose across  the basin.  This is inherently difficult
under water  flow conditions often  existing  at inlets to basins.   Other
disadvantages of using the slug-dose method  include:
            the concentration and volume of the instantaneous tracer dose
            must  be  carefully  computed  to   provide  an  adequate  tracer
            profile at the effluent of the basin
            the resulting concentration vs. time profile cannot be used to
            directly determine T,0 without further manipulation
            a  mass  balance  on  the   treatment  section   is   required  to
            determine whether the tracer was completely  recovered

      One  advantage  of  this  method  is  that  it may  be applied  where
chemical feed equipment is not available at the desired point of addition,
or where the equipment  available  does not have the capacity to provide the
necessary  concentration  of the  chosen tracer  chemical.    Although,  in
general,  the  step-dose procedure  offers  the greatest simplicity,  both
methods are theoretically equivalent  for determining T,0.   Either method
is acceptable for conducting drinking water tracer studies, and the choice
of  the  method  may be determined  by  site-specific  constraints  or the
system's experience.
      C.I.4  Tracer Selection
      An important step in any  tracer  study is the selection  of a chemical
to be used as the tracer.  Ideally,  the selected tracer chemical should be
readily available, conservative  (that is, not consumed or removed during
treatment), easily monitored, and acceptable  for use in potable water sup-
plies.  Historically, many chemicals have been used in tracer studies that
do not  satisfy  all  of  these criteria, including potassium  permanganate,
alum, chlorine,  and sodium carbonate.   However,  chloride  and fluoride are
                                   C-8

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the most  common  tracer  chemicals  employed  in  drinking  water  plants  that
are nontoxic and approved  for potable water use.  Rhodamine WT can be used
as  a  fluorescent tracer  in  water flow studies  in  accordance with  the
following guidelines:
            Raw  water  concentrations  should  be  limited to  a  maximum
            concentration of 10 mg/L.
            Drinking water concentations should  not  exceed 0.1  ug/L.
            Studies which results  in human exposure to the dye  must  be
            brief and infrequent.
            Concentrations as low as  2 ug/L can be used in tracer studies
            because of the low  detection level in the range of 0.1 to 0.2
            ug/L.

The use of  Rhodamine  B  as a tracer  in  water  flow studies is  not recom-
mended by the EPA.
      The choice of a tracer chemical can  be made based,  in  part, on the
selected dosing method  and also  on the availability of chemical  feeding
equipment.  For example, the high density  of concentrated salt solutions
and their potential  for  inducing density currents,  usually  precludes
chloride and fluoride  as the selected chemical  for slug-dose tracer tests.
      Fluoride can  be a convenient tracer  chemical  for step-dose tracer
tests  of clearwells because  it  is  frequently  applied for finished water
treatment.  However, when  fluoride is used  in  tracer tests on clarifiers,
allowances  should  be made  for  fluoride  that is absorbed  on  floe  and
settles out of water (Hudson, 1975).  Additional considerations when using
fluoride in tracer studies include:
                  it is difficult to detect at low levels
                  many states impose  a finished water limitation of 1 mg/L
                  the   federal   secondary  and  primary  drinking  water
                  standards (MCLs) for fluoride  are  2 and 4 mg/L,  respec-
                  tively

The use of fluoride is only  recommended in  cases where  the feed equipment
is already in place for safety reasons.
                                   C-9

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       In instances where only  one of two or more parallel units is tested,
 flow  from the other units would dilute the tracer concentration  prior to
 leaving the  plant  and  entering  the  distribution  system.   Therefore,  the
 impact of drinking water standards on the use of fluoride and other tracer
 chemicals can be alleviated in some cases.

      C.I.5  Tracer Addition
      The tracer  chemical  should be added  at  the same point(s)  in  the
 treatment train as the disinfectant to be used in the CT calculations.
            C.I.5.1  Step-dose Method
      The duration of  tracer  addition  is  dependent on  the  volume of  the
basin, and hence,  its  theoretical  detention  time.  In order to approach a
 steady-state concentration  in  the water exiting the basin, tracer addition
and sampling  should  usually be continued  for  a  period of two  to three
times the theoretical  detention  time (Hudson,  1981).  It is not necessary
to reach a steady state concentration  in the exiting water to determine
T,0,  however,  it   is  necessary   to  determine  tracer recovery.     It  is
recommended that the tracer recovery be determined to identify hydraulic
characteristics or density  problems.  Generally,  a 90 percent recovery is
considered to provide reliable results for the evaluation of T,0.
      In all  cases,  the tracer  chemical  should  be  dosed  in sufficient
concentration to easily monitor  a residual  at the basin outlet throughout
the test.  The required tracer chemical  concentration,  is generally depen-
dent  upon  the^ nature  of   the  chosen  tracer chemical,   including  its
background concentration, and the mixing characteristics of the basin to
be tested.   Recommended  chloride  doses  on the order  of 2& mg/L  (Hudson,
 1975)  should be used for step-method tracer studies where the background
chloride level is  less  than  10 mg/L.  Also, fluoride concentrations  as  low
as 1.0 to 1.5 mg/L are practical  when the raw water fluoride  level  is not
 significant (Hudson,  1975).  However, tracer studies  conducted on systems
 suffering from serious shortcircuiting of flow may require substantially
 larger step-doses.  This would be necessary to detect the tracer  chemical
 and to adequately define the  effluent tracer concentration profile.
                                  C-10

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            C.I.5.2     Slug-dose Method
      The duration of  tracer  measurements  using  the  slug-dose  method  is
also  dependent  on the volume  of  the basin,  and hence,  its  theoretical
detention time.   In general,  samples  should  be collected for  at  least
twice the basin's theoretical detention time,  or until  tracer concentra-
tions  are  detected near  background  levels.    In  order to get  reliable
results for Tlo  values  using the slug-dose method, it is recommended that
the total mass of  tracer recovered be approximately 90 percent of the mass
applied.   This  guideline presents the  need  to sample until  the  tracer
concentration recedes  to the background level.  The total mass recovered
during  testing  will  not  be  known until completion  of the  testing  and
analysis of the data collected.  The sampling period needed is very site
specific.  Therefore,  it may be helpful to conduct a first run tracer test
as a screen  to identify the appropriate sampling period  for gathering data
to determine T10.
      Tracer addition  for slug-dose method tests should be instantaneous
and provide uniformly mixed distribution of the chemical.  Tracer addition
is considered instantaneous if the dosing time does not exceed 2 percent
of the basin's theoretical detention time (Marske and Boyle,  1973).  One
recommended procedure  for achieving  instantaneous  tracer dosing  is  to
apply the chemical by  gravity  flow  through  a  funnel  and  hose apparatus.
This method  is also beneficial because it provides a means of standardiza-
tion, which is necessary to obtain reproducible results.
      The mass....of  tracer chemical to be added is determined by the desired
theoretical  concentration and  basin  size.   The mass of  tracer added in
slug-dose  tracer  tests  should be  the  minimum mass  needed  to  obtain
detectable residual measurements to  generate a concentration profile.  As
a guideline, the theoretical concentration for the slug-dose method should
be comparable  to  the  constant  dose  applied  in  step-dose  tracer tests,
i.e., 10 to  20 mg/L and 1 to 2 mg/L for chloride and fluoride, respective-
ly.    The   maximum  mass  of  tracer  chemical  needed  is calculated  by
multiplying the theoretical  concentration by the total basin volume.  This
is  appropriate  for systems  with  high  dispersion  and/or mixing.   This
quantity  is diluted  as  required  to apply  an instantaneous  dose,  and
minimize density effects.   It  should  be noted that the mass applied  ib not
                                  C-ll

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 likely to get completely mixed throughout the total  volume  of  the  basin.
 Therefore, the detected concentration might exceed theoretical  concentra-
 tions based on the total volume of the basin.  For these  cases,  the mass
 of chemical to be added can be determined by multiplying  the theoretical
 concentration by only a portion of the basin volume.   An  example of this
 is shown in Section C.I.7.2 for a  slug-dose tracer study.   In cases where
 the  tracer concentration  in  the  effluent  must be  maintained  below  a
 specified  level,  it  may be necessary to conduct a preliminary  test  run
 with a minimum tracer dose  to  identify the appropriate dose for determin-
 ing Tlo without  exceeding this  level.

      C.I.6  Test Procedure
      In  preparation  for  beginning a  tracer  study,  the  raw  water
 background concentration  of the  chosen  tracer chemical  must be  estab-
 lished.  The  background  concentration is essential,  not only for aiding in
the  selection  of  the  tracer  dosage,  but  also  to   facilitate  proper
evaluation of the data.
      The  background  tracer  concentration  should  be   determined   by
monitoring for  the tracer  chemical  prior to  beginning  the  test.   The
sampling point(s) for the pre-tracer study monitoring should  be  the  same
as the points to be used for residual monitoring to determine  CT values.
The monitoring procedure is outlined in the following steps:
            If  the  tracer  chemical  is  normally  added  for  treatment,
            discontinue its addition to  the  water in  sufficient time to
            permit the  tracer  concentration  to recede to its  background
            level before the test  is begun.
            Prior  to  the  start of the  test,  regardless of whether  the
            chosen tracer  material is a treatment  chemical,  the  tracer
            concentration in the water is monitored at the sampling point
            where  the  disinfectant  residual  will  be measured  for CT
            calculations.
            If a background tracer concentration is detected,  monitor it
            until  a  constant  concentration,  at  or below  the  raw water
            background  level is achieved.  This measured concentration is
            the baseline tracer concentration.
                                  C-12

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Following  the  determination of  the  tracer dosage,  feed  and  monitoring
point(s),  and a baseline tracer concentration,  tracer testing  can begin.
      Equal  sampling  intervals,  as  could be  obtained   from  automatic
sampling, are not required  for either tracer study method.  However, using
equal sample intervals for the  slug-dose method can simplify the analysis
of  the  data.   During  testing,  the  time  and  tracer  residual  of  each
measurement  should  also  be recorded on a  data sheet.   In addition,  the
water level, flow,  and temperature should be recorded during the test.
            C.I.6.1  Step-dose Method
      At time zero, the tracer chemical feed will  be started and left at
a constant  rate  for the duration of  the  test.   Over the  course of  the
test, the  tracer  residual  should be monitored  at the  required sampling
point(s) at a frequency determined  by  the overall detention time and site
specific considerations. As a general guideline, sampling  at intervals of
2 to  5  minutes should  provide data  for  a well-defined  plot  of tracer
concentration vs. time.  If on-site analysis is available, less frequent
residual monitoring may be possible  until a change in residual  concentra-
tion is  first detected.  As a guideline, in  systems with a  theoretical de-
tention time greater than 4 hours,  sampling may  be conducted every 10
minutes for  the first  30 minutes,  or  until a tracer concentration above
the  baseline level  is first  detected.    In general,   shorter sampling
intervals  enable  better  characterization  of  concentration  changes;
therefore,  sampling  should  be  conducted  at 2 to 5-minute intervals from
the time that a  concentration  change is first observed until the residual
concentration  reaches  a   steady-state value.   A  reasonable  sampling
interval should be chosen based on  the overall detention time of the unit
being tested.
      If verification of the test  is  desired,  the  tracer feed should be
discontinued, and the receding tracer concentration at the  effluent should
be monitored at the  same frequency until tracer concentrations correspond-
ing to the background level are detected.  The time at which tracer feed
is stopped  is time zero for the receding  tracer test and must be noted.
The receding racer test will provide a replicate set  of measurements which
can be  compared  with data derived  from  the  rising  tracer concentration
versus time curve.  For systems which  currently  feed the tracer chemical,
                                  C-13

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the receding curve may be generated from the time the feed  is  turned off
to determine the background concentration level.

            C.I.6.2  Slug-dose Method
      At time zero for the slug-dose method,  a  large instantaneous dose of
tracer  will  be added to the  influent of the  unit.   The  same  sampling
locations and frequencies described for step-dose method tests  also apply
to slug-dose method  tracer  studies.  One exception with this method is
that the  tracer concentration  profile will  not equilibrate to  a  steady
state concentration.   Because of  this,  the tracer should be monitored
frequently enough  to  ensure acquisition  of  data needed to identify the
peak tracer concentration.
      Slug-dose method tests should  be checked by  performing  a  material
balance to  ensure that  all  of  the tracer  fed  is  recovered,  or,  mass
applied equals mass discharged.

      C.I.7  Data Evaluation
      Data from tracer studies  should be  summarized in tables of time and
residual concentration.  These data are then analyzed  to  determine the
detention time, T10,  to be used in  calculating CT.  Tracer test data from
either  the  step  or  slug-dose  method  can  be  evaluated  graphically,
numerically, or by a combination of these techniques.
            C.I.7.1  Step-dose Method
      The  graph-ical  method of evaluating  step-dose test  data  involves
plotting a graph  of  dimensionless  concentration  versus  time  and reading
the value for T,0 directly from the  graph  at  the appropriate dimensionless
concentration.  Alternatively,  the  data from step-dose tracer studies may
be evaluated  numerically by developing  a semi-logarithmic plot  of the
dimensionless data.  The semi-logarithmic plot allows a straight line to
be drawn through the data.   The resulting equation  of the line is used to
calculate  the  T10  value,   assuming  that  the   correlation  coefficient
indicates a good  statistical  fit (0.9 or above).  Scattered data points
from step-dose tracer tests are discredited  by drawing a smooth  curve
through the data.
                                  C-14

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      An  illustration  of the T10  determination  will  be presented  in  an
example of the data evaluation required for a clearwell  tracer study.
            C.I.7.2  Slug-dose Method
      Data from slug-dose tracer tests is analyzed by converting it to the
mathematically equivalent step-dose data and using techniques discussed in
Section C.I.7.1 to determine Tlo.  A graph of dimensionless concentration
versus time should be  drawn  which represents  the results  of  a slug-dose
tracer test.  The key  to converting  between  the  data  forms  is obtaining
the  total  area  under the slug-dose  data  curve.   This area  is  found  by
graphically or  numerically   integrating the  curve.   The conversion  to
step-dose data is then completed in  several mathematical  steps involving
the total area.
      A graphical technique  for converting the  slug-dose data  involves
physically measuring the  area using  a  planimeter.  The  planimeter is  an
instrument used to measure the area of a plane closed curve by tracing its
boundary.  Calibration  of this  instrument to the scale of the  graph  is
required to obtain meaningful readings.
      The rectangle rule  is  a simple numerical integration  method which
approximates the total  area  under the  curve as  the sum of the  areas  of
individual rectangles.   These rectangles  have  heights and widths equal  to
the  residual  concentration   and sampling  interval  (time)  for  each  data
point on the curve, respectively.  Once  the  data has been converted,  T,0
may be determined in  the same manner  as data  from step-dose tracer tests.
      Slug-dose, concentration profiles  can have many shapes,  depending on
the hydraulics of the basin.   Therefore,  slug-dose data points should not
be discredited by drawing a smooth  curve  through the data prior to its
conversion to step-dose  data.   The   steps  and specific  details involved
with evaluating data  from both tracer study methods are illustrated in the
following examples.
      Example for Determining T10  in  a  Clearwell
      Two tracer studies employing the  step-dose  and slug-dose methods of
tracer  addition  were   conducted  for  a  clearwell  with  a  theoretical
detention time, T, of 30  minutes at an average flow of 2.5 MGD.  Because
fluoride  is  added at  the inlet to  the  clearwell as a  water treatment
chemical,  necessary  feed equipment   was  in place for dosing  a constant
                                  C-15

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concentration of fluoride throughout  the step-dose tracer test.  Based on
this  convenience,  fluoride was  chosen  as the  tracer chemical  for  the
step-dose method test.  Fluoride was  also  selected as the tracer chemical
for the slug-dose method test.   Prior to the start of testing, a fluoride
baseline concentration of 0.2 mg/L was established far the water exiting
the clearwell.
      Step-dose Method Test
      For the step-dose  test a  constant fluoride  dosage of 2.0 mg/L  was
added to the clearwell inlet.  Fluoride levels in the clearwell effluent
were monitored and recorded every 3 minutes.   The raw tracer study data,
along with the results of further analyses are shown in Table C-l.
      The steps in evaluating the  raw data shown  in the first column of
Table C-l are as  follows.   First, the baseline  fluoride concentration,
0.2 mg/L,  is subtracted  from   the  measured   concentration  to  give  the
fluoride concentration  resulting from the tracer study  addition alone.
For example,  at  elapsed time = 39 minutes, the tracer fluoride concentra-
tion, C, is obtained as follows:
                        C = C       - C
                             measur efl    ban i i in
                          = 1.85 mg/L - 0.2 mg/L
                          = 1.65 mg/L
This calculation was  repeated  at each time interval  to obtain the data
shown  in  the third  column of  Table C-l.   As  indicated,  the fluoride
concentration rises from 0 mg/L  at t = 0 minutes to the applied fluoride
dosage of 2 mg/L, at t = 63 minutes.
      The next step  is to develop dimensionless concentrations by dividing
the tracer concentrations in the second column of Table C-l by the  applied
fluoride dosage, Co - 2 mg/L.   For time = 39 minutes, C/Co  is calculated
as follows:
                        C/Co *  (1.65 mg/L)/(2.0 mg/L)
                              =  0.82
The  resulting dimensionless  data,  presented in the fourth  column of
Table C-l, is the basis for completing the determination of Tlo  by either
the graphical or numerical  method.

                                   C-16

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                                     TABLE C-l

                     CLEARHELL DATA--STEP-DQSE  TRACER TEST0 : 3)
t.  minutes

     0
     3
     6
     9
    12
    15
    18
    21
    24
    27
    30
    33
    36
    39
    42
    45
    48
    51
    54
    57
    60
    63
Fluoride Concentration
Measured. mg/L
0.20
0.20
0.20
0.20
0.29
0.67
0.94
1.04
1.44
1.55
1.52
1.73
1.93
1.85
1.92
2.02
1.97
1.84
2.06
2.05
2.10
2.14
Tracer. mg/L Dimensi
0
0
0
0
0.09
0.47
0.74
0.84
1.24
1.35
1.32
1.53
1.73
1.65
1.72
1.82
-1.77
1.64
1.86
1.85
1.90
1.94
onless. C/Co
0
0
0
0
0.045
0.24
0.37
0.42
0.62
0.68
0.66
0.76
0.86
0.82
0.86
0.91
0.88
0.82
0.93
0.92
0.95
0.96
Notes:
      1.   Baseline cone. = 0.2 mg/L,  fluoride dose = 2.0 mg/L
      2.   Measured cone. = Tracer cone. + Baseline cone.
      3.   Tracer cone. = Measured cone. - Baseline cone.

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       In order to determine T,0 by the graphical method, a plot of C/Co vs.
 time  should  be generated  using  the  data in Table C-l.   A  smooth curve
 should be drawn through  the data  as shown on Figure C-l.
      T10 is  read directly  from the graph at  a dimensionless concentration
 (C/Co) corresponding  to  the time for which  10  percent of the tracer has
 passed at  the effluent  end  of the contact basin  (T10).   For step-dose
 method tracer studies,  this dimensionless  concentration  is  C/Co * 0.10
 (Levenspiel,  1972).
      T10 should be read directly from Figure C-l at C/Co = 0.1 by first
 drawing  a  horizontal  line  (C/Co  =  0.1) from the Y-axis  (t  *  0)  to its
 intersection with the smooth curve drawn through the data.  At this point
 of intersection, the time  read from the X-axis  is T10  and may be found by
 extending  a  vertical  line downward  to the X-axis.    These  steps were
 performed as  illustrated on Figure C-l, resulting in  a  value  for Tlo of
 approximately  13 minutes.
      For the numerical method of data analysis,  several  additional steps
 are required to obtain T10 from the data in the fourth column of  Table C-l.
 The  forms  of  data necessary  for  determining  T10  through  a  numerical
 solution  are  1oglo(l-C/Co) and  t/T,  the  elapsed  time divided  by the
 theoretical residence time. These are obtained by performing  the  required
mathematical  operations  on the data in  the fourth  column of Table C-l.
 For  example,  recalling  that  the theoretical  detention time, T,  is 30
minutes,  the values for loglo (1-C/Co) and t/T are computed as follows for
the data at t j* 39 minutes:
                  loglo(l-C/Co)  * Iog10  (1-0.82)
                                 •  1og,0 (0.18)
                                 =  -0.757
         t/T  « 39 min/30 min     » 1.3

      This calculation was repeated at each time interval to  obtain the
 data  shown  in Table  C-2.   These data should  be  linearly regressed as
 log,0(l-C/Co)  versus   t/T to obtain the fitted straight-line parameters to
 the following  equation:
                                   C-17

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                     FIGURE C-1

                  C/Co vs. Time

                Graphical Analysis for T10
o
O

O
   0.1	
            10
20     30     40

   TIME (MINUTES)
60

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                       TABLE C-2
        DATA FOR NUMERICAL DETERMINATION OF T
                                             10
I/I                                        1aflia(l-C/Co)
 0                                           0
0.1                                          0
0.2                                          0
0.3                                          0
0.4                                         -0.020
0.5                                         -0.116
0.6                                         -0.201
0.7                                         -0.237
0.8                                         -0.420
0.9                                         -0.488
1.0                                         -0.468
1.1                                         -0.629
1.2                                         -0.870
1.3                                         -0.757
1.4                                         -C.854
1.5                                         -1.046
1.6                                         -0.939
1.7                                         -0.745
1.8                                         -1.155
1.9 -                                       -1.125
2.0                                         -1.301
2.1                                         -1.532

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                   log,0(l-C/Co)  = m(t/T)  + b                       (1)

       In  equation  1,  m and b are the slope and intercept, respectively,
for  a plot  of  log10(l-C/Co) vs.  t/T.    This equation  can  be  used to
calculate  T10, assuming that  the correlation  coefficient for the  fitted
data  indicates a good  statistical fit (0.9  or above).
      A linear regression analysis was performed on the data in Table  C-2,
resulting  in  the following straight-line  parameters:
                                 slope = m * -0.774
                             intercept * b * 0.251
              correlation  coefficient = 0.93

      Although  these  numbers  were  obtained  numerically,  a   plot of
log10(l-C/Co)  versus  t/T  is shown for illustrative purposes on Figure C-2
for the data  in Table C-2.  In this  analysis,  data  for time = 0 through  9
minutes were  excluded  because fluoride concentrations  above the  baseline
level were not observed in the clearwell  effluent until  t  = 12 minutes.
      Equation 1 is then rearranged in the following form to facilitate  a
solution for  T,0:

                   T,0/T =  (log,0  (1  - 0.1) - b)/m                   (2)

      In equation  2,  as  with graphical  method, T10 is determined  at the
time  for  which- C/Co  » 0.1.   Therefore,  in  equation 2,  C/Co   has  been
replaced  by 0.1  and  t (time) by  T.Q.  To obtain a  solution  for Tu,  the
values  of the  slope,  intercept,  and   theoretical  detention  time  are
substituted as follows:

            T10/30  min. »  (loglo(l -  0.1)  -  0.251)/(-0.774)
                      T10  = 12 minutes

      In  summary  both  the  graphical   and numerical  methods  of  data
reduction  resulted  in  comparable  values for Tlo.    With the  numerical
method, T10 was  determined as the  solution to  an  equation based  on the
                                   C-18

-------
straight-line parameters  to  a linear regression analysis of the  tracer     .

study data instead of an "eyeball" estimate from a  data  plot.                 *


      Slug-dose Method Test

      A slug-dose  tracer  test was also performed on the clear-well  at  a

flow rate of 2.5 mgd.  A theoretical clearwell  fluoride  concentration  of
2.2 mg/L was selected.   The fluoride dosing volume and concentration were
determined from the following considerations:

      Dosing Volume

            The fluoride injection apparatus consisted of a  funnel  and a
            length of copper tubing.  This apparatus provided a constant
            volumetric feeding rate of 7.5 liters per minute (L/min) under
            gravity flow conditions.

            At a flow  rate  of 2.5 mgd, the clearwell has a  theoretical
            detention time of 30  minutes.   Since the  duration  of tracer
            injection should  be  less  than 2 percent  of  the  clearwell's
            theoretical detention time for  an   instantaneous  dose,  the
            maximum duration of fluoride injection  was:

                  Max. dosing time * 30 minutes x .02 =  0.6  minutes
                                                                              I
            At a dosing  rate of 7.5 L/min, the  maximum  fluoride dosing
            volume is calculated to be:

                  Max. dosing volume = 7.5 L/min. x 0.6  minutes = 4,5  L

            For this tracer test,  a  dosing  volume of 4 liters was select-
            ed,  providing an  instantaneous fluoride dose  in 1.8 percent of
            the-theoretical detention time.
      Fluoride Concentration

            The theoretical detention time of the clearwell, 30 minutes,
            was  calculated  by  dividing  the  clearwell  volume,  52,100
            gallons or 197,200  liters,  by  the average flow rate through
            the clearwell, 2.5 mgd.

            Assuming  the  tracer is completely  dispersed  throughout the
            total volume of the clearwell, the mass of fluoride required
            to achieve a theoretical concentration of 2.2 mg/L is calcu-
            lated as  follows:

            Fluoride  mass  (initial) = 2.2 mg/L x 197,200 L  x J__g = 434g
                                                            1000 rag

                                   C-19

-------
                         FIGURE C-2
                     1-C/Co vs. t/T
                   Numerical Analysis for T10
O
   0.01
                                                      2.5
Slope. m • -0.774
Intercept, b-0.251
CorritatJon Co«ffld«nt • 0.93

-------
             The  concentration  of the  instantaneous  fluoride  dose  is
             determined  by dividing  this  mass by  the  dosing volume,  4
             liters:
                   Fluoride concentration * 434 g = 109 g/L
                                            4 L
       Fluoride  levels in the  exit  to the clearwell were  monitored and
recorded every 3 minutes. The  raw slug-dose tracer test  data are shown in
Table  C-3.
       The  first  step in evaluating  the  data for different times  is to
subtract the baseline fluoride concentration,  0.2  mg/L,  from the measured
concentration at each sampling interval  (Table C-3).  This  is the same as
the  first  step  used to evaluate  step-dose method  data and  gives the
fluoride concentrations resulting from the tracer addition alone, shown in
the third column of Table C-3.    As  indicated,  the fluoride concentration
rises  from 0 mg/L at  t = 0 minutes to the peak concentration of 3.6 mg/L
at t = 18 minutes.   The  exiting  fluoride concentration  gradually recedes
to  near  zero  at t  = 63 minutes.    It  should be  noted that  a  maximum
fluoride concentration of 2.2 mg/L is based on assuming complete mixing of
the tracer added  throughout the total clear-well volume.   However, as  shown
in  Table C-3,  the  fluoride  concentrations  in   the clean-veil effluent
exceeded 2.2 mg/L  for about 6  minutes between 14  and 20 minutes.    These
higher  peak  concentrations   are caused  by  the   dispersion   of  tracer
throughout only  a portion of  the  total  clearwell  volume.  If  a   lower
tracer concentration is needed  in the effluent because of local  or federal
regulations, the mass to be added should be decreased accordingly.
       The dimensionless  concentrations in the  fourth column of Table C-3
were obtained by  dividing the tracer concentrations in the third column by
the  clear-well's  theoretical   concentration,  Co   » 2.2  mg/L.     These
dimensionless concentrations were then plotted as a function of time, as
is shown  by  the slug-dose data  on  Figure C-3.   These  data  points were
connected by straight lines, resulting in a somewhat jagged curve.
       The next step in evaluating slug-dose data is to determine the  total
area under the slug-dose data curve on Figure C-3.  Two  methods exist for
finding this area --  graphical and numerical.   The  graphical  method is

                                  C-20

-------
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-------
             FIGURE C-3
          C/Co vs.  Time
 Conversion of Slug-to Step-Dose Data
.3 p
  r
  i
5 r
 h
-> •
     10   20   30   40   50
          TIME (MINUTES)
                         60   70
                                   A

-------
based  on  a physical measurement of  the  area using a planimeter.   This
involves calibration of the instrument  to define the units conversion and
tracing the  outline of  the curve to  determine  the  area.   The results of
performing this  procedure  may  vary depending on  instrument  accuracy and
measurement  technique.  Therefore,  only an illustration  of the numerical
technique for finding the area under the slug-dose curve will be presented
for this example.
      The area obtained by  either the graphical or numerical method would
be similar.   Furthermore,  once the  area  is found, the  remaining steps
involved with converting the data to  the step-dose response are the same.
      Table C-4 summarizes  the results of determining the  total area using
a numerical  integration technique called  the rectangle  rule.   The first
and  second  columns  in Table  C-4  are  the  sampling  time  and  fluoride
concentration  resulting  from tracer  addition  alone,  respectively.   The
steps  in  applying these data are  as follows.  First, the  sampling time
interval,  3  minutes,  is multiplied by  the fluoride concentration at the
end of  the  3-minute interval to give the  incremental area,  in  units of
milligram  minutes  per  liter.    For  example,  at  elapsed  time,  t  = 39
minutes, the incremental area is obtained as follows:
      Incremental area = sampling time interval x fluoride cone.
                       = (39-36) minutes x 0.4 mg/L
                       = 1.2 mg-min/L

This calculation  was repeated  at  each time  interval  to  obtain  the data
shown in the third  column  of Table C-4.
      If the data had  been obtained  at unequal sampling intervals,  then
the incremental  area for each  interval  would be obtained by multiplying
the  fluoride concentration  at the  end  of  each  interval  by  the  time
duration  of the interval.    This   convention also  requires  that the
incremental  area  be zero at  the first  sampling point, regardless of the
fluoride concentration at  that time.
      As  is  shown  in  Table C-4,  all  incremental  areas were  summed to
obtain  59.4  mg-min/L,  the total  area  under  the  slug-dose  tracer  test
curve.   This  number  represents  the  total  mass  of  fluoride  that was
                                  C-21

-------
detected during the course of the tracer test divided by the average flow
rate through the clear-well.
      To  complete  the  conversion  of slug-dose  data  to  its  equivalent
step-dose  response requires two  additional  steps.   The  first  involves
summing, consecutively, the incremental  areas in the  third column of Table
C-4 to  obtain  the  cumulative  area  at  the end  of each  sampling interval.
For example,  the  cumulative  area  at  time,  t  *  27  minutes is  found  as
follows:

      Cumulative area = 0 + 0 + 0 + 0  +  3 +  10.2  + 10.8 + 5.4 + 5.7 + 3.6
                      = 38.7 mg-min/L

The cumulative areas for each  interval  are recorded in the fourth column
of Table C-4.
      The final  step  in converting slug-dose  data  involves dividing the
cumulative area  at each interval  by the total  mass  applied.   Total area
based on applied mass is calculated as  follows:

    Total area mass applied/average flow  = 434 g x 1000 ifl/6,570  L
                                                        g        min
                                          » 66.1 trig-mi n
                                                   L

For time = 39 minutes, the  resulting step-dose data point  is calculated as
follows:
                        C/Co = 49.5 mg-min/L / 59.4 mg-min/L
                               = 0.83
The result of performing this  operation at each  sampling interval  is the
equivalent step-dose  data.   These data  points  are shown  in the  fifth
column  of Table  C-4  and are also  plotted on  Figure C-3  to facilitate  a
graphical determination of T10.  A smooth curve was fitted  to the step-dose
data as shown on the figure.
      T10  can be  determined by the methods illustrated previously  in this
example for  evaluating  step-dose  tracer test data.  The graphical method
illustrated  on Figure C-3  results  in  a  reading  of T10  =  15 minutes.

                                   C-22

-------
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-------
            C.I.7.3  Additional Considerations
       In addition to determining T10 for use in CT calculations, slug-dose
 tracer  tests provide a more general measure of the basin's hydraulics in
 terms of the fraction of tracer recovery.  This number is representative
 of  short-circuiting and  dead  space  in  the  unit  resulting  from  poor
 baffling conditions and density currents induced by the tracer chemical.
 A  low  tracer  recovery  is  generally indicative  of inadequate hydraulics.
 However,  inadequate  sampling  in which  peaks  in tracer passage  are not
 measured will  result in an under estimate of tracer recovery.  The  tracer
 recovery  is calculated by dividing the  mass of  fluoride detected by the
 mass of fluoride dosed.
      The dosed fluoride mass was calculated previously and was 434 grams.
 The mass of detected fluoride can be calculated by multiplying the total
 area under the slug-dose  curve by  the  average flow, in appropriate units,
 at the  time of the  test.   The average  flow in  the clearwell during the
 test was 2.5 mgd or 6,570 L/min.  Therefore, the mass of fluoride tracer
 that was detected is calculated as follows:
            Detected fluoride mass = total area x average flow
                                   = 59.4 mg-mjn x   1 g   x 6,570  [,
                                            L      1000 mg       min
                                   = 390 g

 Tracer recovery is than calculated as follows:
      Fluoride recovery » detected mass/dosed mass x 100
                              * 390 g / 434 g x 100
                              = 90 %
This is a typical tracer recovery percentage for a slug-dose test, based
on the experiences of Hudson (1975) and Thirumurthi (1969).

      C.I."8 "flow Dependency of T10
      For systems conducting tracer studies at four or more flows, the T,0
detention time should be determined by  the above procedures for each of
the desired flows.   The detention times should then  be  plotted versus
 flow.   For the example presented in the previous section, tracer studies
                                  C-23

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were  conducted  at additional flows of  1.1,  4.2, and  5.6 MGD.   The T10
values  at the various flows were:                                            *
                   1.1                    25
                   2.5                    13
                   4.2                     7
                   5.6                     4

T10 data for these  tracer  studies were plotted as a function of the flow,
Q, as shown on Figure C-4.
      If only one tracer test is performed,  the flow rate for the tracer
study  should be  not  less  than 91  percent  of the  highest flow  rate
experienced  for the  section.    The  hydraulic  profile to  be used  for
calculating CT would  then be generated  by drawing  a line through points
obtained by multiplying the T10  at the tested flow rate by  the  ratio of the
tracer study flow rate to each of several different flows in the desired
flow range.
      For  the example presented in the  previous  section,  the clearwell
experiences a maximum flow  at  peak hourly  conditions of 6.0 mgd.   The
highest tested flow rate was 5.6 mgd,  or 93 percent of the maximum flow.
Therefore, the detention  time,  T,0  =  4 minutes,  determined by the tracer
test at  a flow rate  of 5.6 mgd may  be used to  provide  a conservative
estimate of T,0  for all  flow  rates  less  than or  equal  to the maximum flow
rate, 6.0  mgd.  The  line  drawn  through  points  found by multiplying  T'" =
4 minutes  by th« ratio of 5.6 mgd to each of several  flows less than 5.6
mgd  is   also  shown  on Figure  C-4  for comparative  purposes with  the
hydraulic  profile  obtained  from  performing  four  tracer   studies  at
different  flow rates.

C.2  Determination of  T10  Without Conducting a Tracer Study
      In  some situations, conducting  tracer studies  for determining the
disinfectant  contact  time,  T10,   may   be  impractical or prohibitively
expensive.   The limitations  may   include a lack of  funds,  manpower or
equipment  necessary  to conduct the study.   For these  cases,  the  Primacy
Agency  may allow the  use of  "rule of thumb" fractions  representing the

                                   C-24

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                   FIGURE C-4
           Detention Time vs. Flow
   35
   30
   25

CO*
LJJ  „_
h-  20
Z
2
a  ^
   10
                 X
      Average   X
4-Flow profile
1-Flow profile
  Maximum
  Extrapolation
                   345
                    FLOW (MGD)
        6

-------
ratio of  T10 to T, and  the  theoretical  detention  time,  to  determine the
detention time, T10, to be used for calculating CT values.  This method for
finding T10  involves multiplying the theoretical detention time by the rule
of thumb  fraction, T10/T, that is representative of the particular basin
configuration  for  which Tlo  is desired.  These  fractions  provide rough
estimates of the  actual  T10  and  are recommended  to  be  used only  on  a
limited basis.
       Tracer  studies  conducted by  Marske  and Boyle  (1973)  and  Hudson
(1975)  on chlorine contact  chambers and  flocculators/settling  basins,
respectively,  were used as a  basis  in  determining representative  T10/T
values for various  basin configurations. Marske and Boyle  (1973) performed
tracer studies  on  15  distinctly different  types  of full-scale  chlorine
contact chambers to evaluate design characteristics that affect the actual
detention time.   Hudson (1975)  conducted  16  tracer tests on  several
flocculation and settling basins at six water treatment plants to identify
the effect  of  flocculator baffling and settling  basin  inlet and  outlet
design characteristics  on the  actual detention time.

      C.2.1  Impact of  Design  Characteristics
      The significant  design  characteristics  include:   length-to-width
ratio, the degree of baffling  within the basins, and the effect of  inlet
baffling and outlet weir configuration.  These  physical characteristics of
the contact  basins affect  their  hydraulic  efficiencies in  terms of dead
space, plug  flow,  and mixed  flow  proportions.  The dead space zone of  a
basin is basin volume  through which  no  flow  occurs.  The  remaining volume
where flow  occurs  is  comprised of plug flow  and  mixed  flow zones.   The
plug flow zone  is the portion  of the remaining volume in which no mixing
occurs in the direction of flow.   The mixed  flow zone  is  characterized by
complete •ixing in the  flow  direction  and  is the complement to the plug
flow zone.   All of these zones were identified  in the studies  for each
contact basin.  Comparisons  were  then  made between the basin configura-
tions and the observed  flow conditions  and  design  characteristics.
      The ratio T10/T was calculated from the data presented  in the studies
and  compared to  its  associated  hydraulic  flow  characteristics.   Both
studies resulted in T10/T values which ranged from 0.3 to 0.7. The results
                                  C-25

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of  the  studies  indicate  how basin  baffling conditions  can  influence the
T,0/T ratio,  particularly baffling  at the inlet and outlet  to the basin.
As  the  basin  baffling  conditions  improved,  higher T10/T  values  were
observed,  with  the outlet conditions generally having  a greater impact
than the  inlet conditions.
      As  discovered  from the  results of the tracer studies performed by
Marske  and Boyle  (1973)  and Hudson (1975), the effectiveness of baffling
in  achieving  a  high T10/T fraction is more related  to  the geometry and
baffling  of the basin than the  function of the basin.   For this reason,
T10/T values may be defined for three  levels of  baffling conditions rather
than for particular types of  contact basins.   General  guidelines  were
developed  relating the TIO/T values from these  studies  to the respective
baffling  characteristics.  These guidelines can be used to determine the
T10  values for specific basins.

      C.2.2  Baffling Classifications
      The purpose of baffling is to maximize utilization of basin volume,
increase  the plug flow zone in the basin,  and minimize short circuiting.
Some form of baffling  at the inlet  and  outlet of  the  basins is used to
evenly  distribute flow  across  the  basin.   Additional baffling  may be
provided within the  interior of the  basin  (intra-basin) in circumstances
requiring  a greater  degree  of  flow distribution.   Ideal baffling design
reduces  the  inlet and  outlet flow velocities, distributes the water as
uniformly  as  practical   over the  cross  section of  the basin,  minimizes
mixing  with the water already  in the basin, and prevents entering water
from short circuiting to  the basin  outlet as the result  of *ind  or density
current effects.  Three general  classifications of  baffling conditions --
poor, average,  and superior -- were developed to categorize  the  results of
the  tracer  studies  for use  in  determining  T10  from  the theoretical
detention  time of a  specific basin.   The T10/T fractions associated  with
each degree of baffling are  summarized in Table C-5.  Factors  representing
the  ratio  between T10 and the theoretical detention time for  plug flow in
pipelines  and flow in a  completely  mixed  chamber  have been included in
Table C-5  for comparative purposes.  However,  in  practice the theoretical
T10/T values of   1.0  for plug  flow  and 0.1  for mixed  flow are seldom
                                   C-26

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achieved because of the effect of dead space.  Conversely,  the T10/T values
shown  for  the intermediate baffling conditions already  incorporate  the
effect of the dead space zone, as well as the  plug flow zone,  because they
were derived  empirically rather than from theory.
      As indicated  in Table  C-5,  poor  baffling  conditions consist  of an
unbaffled inlet and outlet with no intra-basin baffling.  Average baffling
conditions consist of intra-basin baffling and  either a baffled inlet or
outlet.  Superior baffling conditions consist of at least a baffled inlet
and outlet,  and  possibly  some intra-basin baffling  to  redistribute  the
flow throughout the basin's cross-section.
      The three basic types  of  basin inlet  baffling  configurations are:
a  target-baffled  pipe inlet, an  overflow weir entrance, and  a baffled
submerged orifice or port  inlet.   Typical  intra-basin baffling structures
include:  diffuser  (perforated)  walls; launders; cross, longitudinal, or
maze  baffling to cause  horizontal  or  vertical   serpentine   flow;  and
longitudinal  divider walls,  which  prevent mixing   by  increasing  the
length-to-width  ratio  of  the  basin(s).    Commonly used baffled  outlet
structures  include  free-discharging weirs,  such as sharpcrested  and
V-notch, and  submerged ports or weirs.  Weirs that do not span the width
of the contact basin, such  as Cipolleti  weirs,  should not  be considered
baffling as their use may substantially increase weir overflow rates and
the dead space zone of the basin.

      C.2.3   Examples of Baffling
      Examples of these  levels of baffling conditions  for rectangular and
circular basins are  explained and illustrated  in  the following section.
Typical uses  of various forms of baffled and unbaffled inlet and  outlet
structures are also  illustrated.
      The-plan and section of a  rectangular basin with po.oj baffling  con-
ditions, which can be attributed to the unbaffled  inlet and outlet  pipes,
is illustrated on Figure  C-5.  The  flow  pattern  shown in  the plan  view
indicates straight-through flow with dead space occurring in the regions
between the individual pipe inlets and outlets.  The  section view reveals
additional dead space from a vertical perspective  in  the upper  inlet and
lower outlet corners of the contact basin.  Vertical mixing  also occurs as
                                  C-27

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                PLAN
             SECTION
FIGURE C-5 POOR BAFFLING CONDITIONS --
          RECTANGULAR  CONTACT BASIN

-------
  71
i  ' •
  71

                                                 A
                      PLAN
                   SECTION
      FIGURE C-6  AVERAGE BAFFLING CONDITIONS
                  RECTANGULAR CONTACT BASIN

-------
/
          XI

             H   /
"J
                                                     -A
                              PLAN
             V

                                             i — f
                                                            x

                                                  / / A
                            SECTION

            FIGURE C-7   SUPERIOR BAFFLING CONDITIONS
                        RECTANGULAR CONTACT BASIN

-------
              PLAN
             SECTION
FIGURE C-8  POOR BAFFLING CONDITIONS
           CIRCULAR CONTACT BASIN

-------
                PLAN
               SECTION
FIGURE C-9 AVERAGE BAFFLING CONDITIONS
          CIRCULAR CONTACT BASIN

-------
       Superior baffling conditions are attained in  the basin configuration
 shown on Figure C-10 through the addition of a perforated inlet baffle and
 submerged orifice outlet ports.  As indicated by the  flow pattern, more of
 the basin's volume is utilized due to uniform flow  distribution created by
 the perforated baffle.  Short circuiting  is  also minimized because only a
 small portion of flow passes directly through the perforated baffle wall
 from the inlet to the outlet ports.

      C.2.4  Additional Considerations
      Flocculation basins and ozone contactors represent water treatment
 processes with slightly different characteristics  from those presented in
 Figures C-5 through C-10 because of the additional effects of mechanical
 agitation and mixing from ozone addition,  respectively.  Studies by Hudson
 (1975) indicated that a single-compartment  flocculator had  a  T10/T value
 less than 0.3, corresponding to a dead  space zone  of about 20 percent and
 a very high mixed flow  zone of  greater than 90 percent.   In this study,
 two  four-compartment  flocculators,   one  with  and  the  other  without
mechanical agitation, exhibited  T,0/T  values  in the range of 0.5 to 0.7.
 This observation indicates  that not only will compartmentation result in
 higher T,0/T  values  through better flow  distribution, but  also that the
 effects  of  agitation  intensity on  T,0/T  are reduced where  sufficient
 baffling  exists.    Therefore,   regardless  of  the extent  of  agitation,
 baffled  flocculation basins  with  two  or  more  compartments  should  be
considered to possess average baffling conditions (T10/T » 0.5), whereas
unbaffled, single-compartment  flocculation  basins are  characteristic of
poor baffling conditions (T10/T  = 0.3).
      Similarly,  multiple   stage  ozone  contactors  are baffled contact
basins which-show characteristics of  average baffling conditions.  Single
 stage  ozone  contactors should  be considered as  being  poorly baffled.
 However,  circular, turbine ozone contactors may exhibit flow distribution
characteristics which approach  those  of  completely  mixed basins, with a
T10/T  of  0.1,  as  a result of the intense  mixing.
      In  many cases,  settling  basins  are  directly  connected  to the
 flocculators.  Data   from   Hudson  (1975)  indicates   that   poor baffling
conditions at  the  flocculator/settling  basin  interface  can  result  in
                                  C-29

-------
               PLAN
             SECTION
FIGURE C-10 SUPERIOR BAFFLING CONDITIONS
           CIRCULAR CONTACT BASIN

-------
References

Hudson, H. E.,  Jr..  "Residence Times in Pretreatment", J. AWWA, pp. 45-52,
      January, 1975.

Hudson, H. E.( Jr.. Water Clarification Processes;  Practical Design and,
Evaluation. Van Nostrand Reinhold Company, New York,  1981.

Levenspiel, 0..  Chemical  Reaction Engineering.  John  Wiley  &  Sons,  New
York, 1972.

Marske, D. M.  and  Boyle, J. D.. "Chlorine Contact Chamber Design - A Field
Evaluation", Water and Sewage Works,  pp. 70-77, January,  1973.

Thirumurthi, D..  "A Break-through in the Tracer Studies of Sedimentation
Tanks", J. WPCF, pp. R405-R418, November, 1969.
                                   C-31

-------
                      APPENDIX D

        ANALYTICAL REQUIREMENTS OF THE SWTR AND
A SURVEY OF THE CURRENT STATUS OF RESIDUAL DISINFECTANT
 MEASUREMENT METHODS  FOR ALL CHLORINE  SPECIES AND OZONE

-------
                               APPENDIX D
                         ANALYTICAL  REQUIREMENTS


      Only the  analytical  method(s)  specified  in  the SWTR,  or otherwise
approved  by  EPA,  may  be  used  to demonstrate  compliance  with  the
requirements of the SWTR.  Measurements of pH, temperature, turbidity, and
residual disinfectant concentrations must be conducted by a party approved
by the Primacy Agency.  Measurements for total coliforms, fecal coliforms,
and heterotrophic  bacteria  as  measured  by  the  heterotrophic plate  count
(HPC), must be conducted by a  laboratory certified by the Primacy Agency
or EPA to do such  analysis.  Until  laboratory certification criteria are
developed for  the analysis of HPC  and fecal  coliforms,  any laboratory
certified for  total  coliform  analysis  is  acceptable for HPC  and  fecal
coliform analysis.  The test methods to be used for various analyses are
listed below:
      (1)   Fecal  coliform  concentration  -  Method 908C (MPN Procedure),
            908D  (Estimation  of  Bacterial  Density), or  909C (Membrane
            Filter Procedure)  as  set forth in Standard  Methods  for the
            Examination of  Water  and Wastewater.  American Public Health
            Association, 16th  edition.

      (2)   Total  coliform  concentration   -  Methods  908A,  B,  D   (MPN
            Procedure) or 909A, B  (Membrane Filter Procedure) as set forth
            in  Standard  Methods   for  the  Examination  of  Water  and
            Wastewater. American Public Health  Association,  16th edition;
            Autoanalysis Colilert (EPA  refers  to  this as Minimal Medium
            ONPG-MUG Method),  as  set forth  in  Applied and  Environmental
            Microbiology, American  Society  for Microbiology, Volume 54,
            No. 6, June 1988.  pp.  1595-1601.

      (3)   Heterotorphic Plate Count - Method 907A  (Pour Plate Method),
            as set forth in Standard Methods for the  Examination of Water
            and  Wastewater. American   Public  Health  Association,   16th
            edition.

      (4)   Turbidity - Method  214A  (Nephelometric Method) as set  forth in
            Standard Methods for the Examination of Water  and Wastewater.
            American Public Health  Association, 16th  edition.

      (5)   Residual disinfectant concentration  - Residual   disinfectant
            concentrations for free  chlorine and combined chlorine must be
            measured  by Method  408C   (Amperometric  Titration  Method),
            Method 408D (DPD Ferrous Titrimetric Method),  Method 408E  (DPD
            Color-metric  Method),  or  Method 408F  (Leuco  Crystal Violet


                                   D-l

-------
            Method) as set forth in Standard Methods for the Examination
            O-f Water and Wastewater. American Public Health Association,
            16th  edition.   Disinfectant  residuals  for  free chlorine and
            combined  chlorine   may   also   be   measured   by  using  DPD
            colorimetric  test  kits if  approved by the  Primacy  Agency.
            Disinfectant  residuals for  ozone  must be  measured  by the
            Indigo   Trisulfonate  Method   (Bader,   H.,    Hoigne,   J.,
            "Deternination  of  Ozone  in  Water  by  the  Indigo  Method;  A
            Submitted Standard Method;"  Ozone  Science and Engineering,
            Vol.  4, pp. 169-176,  Pergamon Press  Ltd., 1982), or automated
            methods  which are calibrated  in  reference  to  the  results
            obtained  by  the  Indigo  Trisulfonate  Method,  on  a  regular
            basis, as determined by the  Primacy Agency.   This method is
            described  in  section of the manual.  (Note:   This method is
            included  in  the 17th  edition  of  Standard Methods  for the
            Examination of  Water and  Wastewater.  American Public Health
            Association; the Idiodometric Method in the 16th  edition may
            not  be  used.)   Disinfectant residuals  for chlorine dioxide
            must  be measured  by Method 410B   (Amperometric  Method)  or
            Method 410C (DPD Method)  as set  forth  in Standard  Methods for
            the  Examination of  Water  and  Wastewater.  American Public
            Health Association,  16th edition.

      (6)   Temperature - Method 212 as set  forth  in Standard  Methods for
            the  Examination of  Water  and  Wastewater.  American Public
            Health Association,  16th edition.

      (7)   pH  - Method  423  as  set  forth  in  Standard  Methods  for the
            Examination of  Water and  Wastewater,  American  Public Health
            Association,  16th edition.

References

Edberg et al,  "National Field Evaluation  of a Defined Substrate Method for
the Simultaneous  Enumeration of Total  Coliforms and Escherichia Coli from
Drinking Water:"- Comparison with the  Standard Multiple  Tube Fermentation
Method," Applied and Environmental Microbiology, Volume 54,  pp. 1595-1601,
June 1988.
                                   0-2

-------
PREFACE

      The AWWA paper entitled "A survey  of the current status of residual
disinfectant measurement method for all  chlorine species and ozone" will
be included in the final document.   It has not been included here for the
sake of  brevity.   However,  the publication  is  available  from  the AWWA
Customer Services Department,  6666  W. Quincy  Avenue,  Denver,  Co.  80235;
Telephone (303) 794-7711.  The  document publication number is 90529.
      The above publication summarizes the AWWA Research foundation's 816
page publication  entitled  "  Disinfectant  Residual  Measurement Methods",
publication  number  90528.   This  document  is  also  available  from the
customer services department listed above.
                                   D-3

-------
A SURVEY OF THE CURRENT STATUS CF RESIDUAL DISINFECTANT
MEASUREMENT METHODS FOR ALL CHLORINE SPECIES AND OZONE
                    Gilser: Gorion
                Department of Chemistry
                   Miami University
                   Oxford, CH 45055
                   William J. Csooer
            Drinxing Watap R"eseapc.n Ca.ncar
           Flcrica Incsrnacional Um'vers*'/
                 Miami , "Icriaa 23139
                      Rip 3. Rica
                  Rica, Inccrcorarad
                Asnton, yarylana 2C361
                   oilbert E. Pacay
                "esart-ent of Chemistry
                   Miami University
               AWWA Raseapc.*! "cunaaticn

                 5ccc W. Ouincy Avenue
                   "envoi-  r" 3P2"S
                   ^«-'''«  | WW wUC«*tf
                     fiovemcep 1937
             by tne American Water WOPICS Association

-------
                          DISCLAIMER
This study was furcec :y trie American Watar  Wcr
-------
                                  FOREWORD
'ill's resort is oart of tr.e on-going rssearc.i orccm of t.ie Air.i'A ^ssaarc.i
Foundation.  The rssaarc.n cescnoec in tre fell owing paces was furceo- oy
t.ie Foundation 1.1 benalf of its -emBers and suoscrieers 1.1 oartieular arc
t.ie water sues!;/ industry in general.  Selectaa for funning ay AWUARF's
Soars of Trustees, t.ie project was identified as a practical, prior-it/ neec-
of Me incustry.  It is hosed tr.at t.iis puolicaticn will receive wice arc
serTous attant:on and tnat its findings, conclusions, anc raccraencaticns
will be acoliaa in csnnumties inrougnout "ne Unitsd Statas ana Car.aca.

The .Resaarc.n Founaat:cn was craatad by :re watar sucoly iicustry a
canter for ccocerative rasaarcn and development.  The Foundation i
coes not conduct rasearcn; it functions as a planning and ^anacsne
agency, awarding contract: to ctner institutions, SUCH as water u
universities, engineering fins, and ctner organizations.  The sc:
and tacnnical  expertise of
t~e staff
                                     is further ennancaa  by  industr
volunteers wno sarve on Project Advisory Cerrmittees  and  on  otr.er  s
committees arc councils. •-n extensive planning process  involves  m
hundreds of water professionals in t.ie imoortant  tas*  cf '
-------
                                 PREFACE
7:iis socument surrniar: :ss :r:a AWWA  Researcn  Founcaticn's 315 :acs
puolication "Cisinfactant Resiaual  Measurement  Met.ncas.'   "nat
puolicjtion (?'jfilic3t:cn Numoer  90523)  can  be  orsarac frtsi :na -UWA
Cjstcner Services Deoaptsenc, 6566  w. Quincy Avenue,  Denver, CC 3C225;
talesnone, (203) 794-7711.

71-!e ourpose of this summary document  is  to  provide  tr.e  wa*ar utnity
laooratory analyst witn cuicanca  in selecting  ais:nfactant rastcual
•neasurament metnoas.  Eitner tnis  document  or  trie  full  racort is
reccrrr.enaed as a ccmoanicn to Standard  Metnoas  for  trte  Examination of
Watar ana

-------
                              ACKNOWLEDGEMENTS
The autrcps wisn to exsrsss tneip acapeci at: on to t.~e Amep'can Watap WOP'<
Assoc: acion - Resaarcn Founaat:on for the opportunity :o carry oui :ms
     'ai rav:ew of :r;e li
           , :r.e auc.icrs would like to pay tn'buta :o t.ie  really
peoola •- all t.^ose wno did t.ta.e origlna] WOPK and mace  tr.is  sacondapy
SCUPCS of inforaaf.cn possible.

Finally, tfie autfiops wisn to exopass tneip apppeciaticn  :o :.ie mercers  of
:ne Prcjec1: Acviscpy Ccranttaa:

   1)   ;'ap'< Captap, Ph.D.
       Rcci
-------
                               EXECUTIVE SUMMARY
 BACKGROUND
    The objective  of  this Report  is  to review and summarize all disinfectant ra-
sidual aeasurement  techniques currently available for free chlorine  (along  •-••_cr.
the  various  chloraaines),  combined  chlorine, chlorite ion, chlorine dioxice,
chlorate  ion, and  ozone.

    Presently, both chlorine dioxide and ozone are gaining considerable favor as
alternatives  to chlorine disinfection (1).  The analytical chemistry  for  these
disinfectants  when compared with chlorine is even more complex and  less readily
understood as evidenced by various surveys (2-5) and detailed  research  carried
out in various laboratories (6-10).

    Chlorine dioxide  is manufactured at the site of its use by reactions involv-
ing sodium chlorite,  chlorate ion, chlorine gas and/or hypochlorite  ion and sul-
furic acid or hydrochloric acid (11-12).  Consequently, chlorate  ion,  chlorite
ion,  hypochlorite  ion and/or hypochlorous acid frequently will be  found occur-
ring as by-products or unreacted starting materials.  These materials are strong
oxidizing agents which are very reactive and behave  in  many  ways  similar  to
chlorine dioxide itself.

    There are more than 2,000 wat«r treatment plants today using ozone, and less
than half of them are applying ozone solely for disinfection.  The large  major-
ity  of  water  treatment  plants  use ozone as a chemical oxidant.  Many of t.-.e
plants applying ozone for disinfection also are using ozone, in the  sase  slant,
for  chemical  oxidation.   Analyses  for residual ozone in water are asplicaole
only in the treatment plant, either  in  the  ozone  contactor(s)  or  at  t.-.eir
outlets.    Residual   ozone is never present in the distribution system; however,
its by-products may be.

    There have been numerous attempts to evaluate the  relative  advantages  ar.d
disadvantages  associated  with  the  measurement of free and combined chlorine.
Different criteria are frequently used for  the  evaluation  of  the  analytical
measurements  and ..often suggestions for the improvement of test procedures have
gone largely ignored.  No comprehensive and objective review of  the  literature
appears  to be available.  This Report is aimed at providing such a  review along
with guidance and recommendations as to what criteria water utilities should use
in selecting residual monitoring techniques based on circumstances by category.
OBJECTIVES
    1.  To review and summarize all residual measurement  techniques
        currently available for free chlorine-- caking  into account
        the roles of chloraaines.

    2.  To review and suaaarize all residual measurement  techniques
        currently available for combined chlorine.

-------
    3.  To briefly  review the present understanding of the chlorir.e-
        amaonia chemistry and in particular, in relationship to che
        measurement of chlorine and combined chlorine.

    •*.  To review and summarize all residual measurement techniques
        currently available for chlorine dioxide, chlorite ion and
        chlorate ion.

    5.  To review and summarize the analytical procedures currently
        used by operating water utilities to control ozone treatment
        processes,  considering disinfection as well as the many oxid-
        ative applications of ozone in water treatment applications.

    6.  To discuss  common interferences associated with the measurement
        of each of  the disinfectants/oxidants described above (free
        chlorine, combined chlorine, chlorite ion, chlorine dioxide,
        chlorate ion, and ozone).

    7.  To provide  guidance and recommendation for water utilities  in
        selecting residual monitoring techniques for each of the above
        disinfectants/oxidants.

    8.  To recommend future research for development of monitoring  and
        analytical  methods to improve accuracy, and reduce tise ar.d cost
        requirements for the measurement of the above disinfectants.


    In che full report, we present as complete as possible an examination of :.-.e
world-wide body of  literature on analytical methods used by  the  water  utility
industry  in  order  to elaborate on the various problems, advantages, cisadvan-
tages and known interferences for each of the currently used analytical zetr.ccs

    Foremost in our objectives has been a better understanding of the  reliabil-
ity of various measurements which have been carried out.  Since there are inr.er-
ent limitations in  all measurements, it becomes apparent chat there are specific
needs  for  some  indication of the reliability of the result, i.e., what is c.-.e
precision and accuracy of the reported value, and are these acceptable?

    The volatility  of mosc  of  the  disinfectants  makes  sampling  and  sasoie
handling  a  major  contributor  to  imprecision  and  inaccuracies.   "Standard
additions" is a questionable technique; it  should be  avoided  if possible,  since
the pipetting and dilution process causes potential loss of disinfectant.

    The relative usefulness of each method, along  with  descriptions  of  known
interferences such  as  turbidity, organic matter,  ionic materials, solids, color,
buffering  capacity,  as  well  as  the nature  of  the  sample and the  time between
collection of the sample and the actual analysis, are described in  this  report.
It  must  be  emphasized,  however,  that   almost invariably  each of  the methods
described is based  on  the  total   oxidizing   capacity  of  the  solution  being
analyzed  and   is   readily  subject  to interferences from  the presence of other
potential  oxidizing   agents  and/or   intermediates   from   concomitant  chemical
reactions.   Under   ideal  conditions  some  of  the methods are  accurate to be::er

-------
 chan  ±1%--especially  in  the   absence   of   common   interferences--whereas  ::r.er
 methods   are   alaosc   semi-quantitative in nature  with  many   common  spec.es
 intertering with both Che precision  and accuracy of  the measurements.

    V« have also included chlorate ion   as   a   residual  species   in   chat  sr.lv
 recently   have  reliable   analytical methods   begun to appear in the  literature
 (5,6,10).  . Ve  also  report on  the  chemistry  of  the   chlorine-ammonia  system  and
 the associated breakpoint reactions, because one of  the most common  inteferer.ces
 in  the aeasurement  of free chlorine  is  monochloraoine.

    The most  important development for  this report  has been the decision to  in-
 clude a   preliminary  section describing an "idealized" analytical  method.  The
 need  for  this  section became  apparent as our writing progressed describing  eacn
 of  the analytical methods for chlorine.  Specific  items included  in  this "ideal-
 ized" method   are  accuracy,   precision, reproduciblity,  lack of interferences,
 ease  of use of the  method,  lack of false positive values,  and so  forth.

    The benefit of  the "idealized" analytical  method is to allow  individual com-
 parisons  and to allow the choice  between various  methods  based   on  ir.divicual
 aethod  shortcomings.   For  example, a particular  method  might have as  its or.lv
 difficulty interference by manganese and iron.  In  many circuastar.ces.  this r.-se
 of  interference might be  a major  problem.    However,   should  the water   surplv
 under consideration  not  have  any manganese or iron, it is quite  likely  chat  :r.e
 aethod might be very  usable--and  as  a matter of face  well aight be   the  best
 aethod of  choice.

    In other cases, speed of  analysis rather than   potential  interferences    or
 choice  of  some  other important characteristic) might be the guiding factor  :r.
 choosing an analytical method.  In this  way rational choices can  be  cade  :sseci
 on potential and/or real  difficulties and/or interferences and as compared co  in
 "idealized" aethod  --  rather  tnan a  possibly controversial existing zetr.oc.

    Table  I has  been  constructed  as  a quick reference  guide  to   the  availaale
 methods  for   the   determination  of  water disinfection chemicals  and bvprocuccs
 Included are pertinent analytical characteristics   such   as  detection  lisits,
 working  range,   interferences,   accuracy   and precision estimates.  The current
 status of  the  method,  as  gleaned  from this   report.  is  given.     The  r.ecessarv
 operator   skill   level  is  given to aid the laboratory manager in assessing c.-.e
 manpower   requirements  for  a  particular   method.    Additional  informal::. or.
 concerning  the  reasons for  the  current  status  is contained in the Recommendation
 Section of  the  Executive  Suaaary  and the coisplete report.

    As each of  the  methods  is described in  detail in the full  report,  specific
 conclusions  are  drawn--along with appropriate recoanendations- -by comparing cr-.e
 method against  the  "idealized"  analytical method for that  species.

    One additional  benefit  of  this direct comparison is the possibility of  aid-
 ing   or subtracting a method  to the  list of Standard Methods for  rhe Exanirat-.c^.
 of 'Jater ard Wastewater. (13), based  on  a rational set  of   criteria.    It  snou^d
 also  be   possible  in  the future to decide on the  viability of  various rretr.ccs
based on their  meeting specific criteria rather than based only   on  corr.pansors
between  analytical   laboratories (and personalized subjective reactions :o :r.e
various mecnods  themselves

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 TA3LZ I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS'5

                   Species'      DETECTION  WORKING  EXPECTED  EXPECTED
TYPE OF TEST       MEASURED        LIMIT     RANGE   ACCURACY  PRECISION  SKI1
 (METHOD)*          DIRECTLY       (mg/L)    (mg/L)     (± %)    (± %)     LIVE
                                                                 k

FREE CHLORINE
           f

  "Ideal-       Cl, + HOC1/OC1-   0.001   0.001 - 10    0.5      O.I

  UV/VISI3LE    C12 + HOC1/OC1-     - 1  (   1-100      NR       NR       3


    Continuous  C12 + HOC1/OC1'     1.5    1.5-300     NR       NR       3


  AMPEROMETRIC TITRATION:

    Forward     C12 -(• HOC1/OC1'   0.00181     > 10       NF       NT       2
                                0.02 - 0.032  > 10       NF     3-50     2

    Sack        C17 t- HOC1/OC1'   0.002       > 10     3-50     NF       2

    Continuous  C12 + HOC1/OC1'   0.005       > 10       N*R      1.0      2/3


  IODOMETRIC  TITRATICN:

    Standard    (Total Chlorine)   0.073     0.1-10     Ml       :,-R       :


                                  0.354     0.5-10     N-R       NR       ;

  DPD

    FAS  Tit'n   C12 -*• HOC1/OC1'   0.004s    0.01-10    NT     2-7

                                  0.0114    0.01-10    NT     2-7

    Color'atrc  Cl, •»• HOC1/OC1'   0.01s     0.01-10  1-15   1 - U

    Steadifac   Cl, + HOC1/OC1"   0.01s     0.01  - 10    NF       NR      1/2
    Black  and
     Whittle   Cl, * HOC1/OC1-   0.01      0.25-3     NF       NR

    Whittle  &
     Lapceff   Cl, * HOC1/OC1'   0.01      0.25-10    NR     0 - 10

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    TASLI I.  CHARACTERISTICS (conc'd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   ?H RANGE
FIELD
TEST   AUTOMATED
CURRENT
5 YRS
NA
NA
1-2 yrs
1-2 yrs
1-2 yrs
1-2 yrs
1 yr
1 yr
powder
stable*
powder
stable8
powder
stable8
powder
stable8
months
months
> 1 DAY
NA
NA
NA
NA
NA
NA
10 nin
or less
10 min
or less
30 oin
30 min
30 min
30 min
NR
Ml
NONE
ClNHj - C13N
backgnd Abs
C1NH, - CljN
C1NH, - CljN
C1NH, - CljN
C1NH, - CljN
C1NH, - C13N
All oxidizing
species
All oxidizing
species
C1NH, - CljN
oxid species
C1NH, • CljN
oxid species
C1NH, - C13N
oxid species
C1NH, - C1,H
oxid species
rl *TH n v
uivTiA • w i • fct
oxid species
Oxidizing
species
Independent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
Requires
buffer
Requires
buffer
Requires
buffer
Requires
buffer
Requires
buffer
Buffering
YES
NO
NO
YES
YZS
YES
YES
NO
NO
NO
NO
YES
YES
YES
YES
YES
NO
YES
YES
YES
YES
YES
NO
NO
NO
NO
NO
NO
NO
NO
RECOMMENDED
RECOMMENDED
(LAS TEST)
CONT'D STVDY
RECOMMENDED
RECOMMENDED
RECOMMENDED
RECOMMENDED
(LAS TEST:
RECOMMENDED
(LAS TEST:
RECOMMENDED
(LAS TEST)
RECOMMENDED
(LAS TEST)
RECOMMENDED
(FIELD TEST)
RECOMMENDED
(FIELD TEST)
ABANDON
RECOMMENDED
(LAS TEST)

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    :ABL£ :.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHOD
TYPE OF TEST
 (METHOD)*
Species*      DETECTION  WORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RA^NGE   ACCURACY  PRECISION  S:
-------
    TABLZ  I.  CHARACTERISTICS (cons'd)
STABILITY
REACE.NT PRODUCTS
2 years7 30 min
at high
2 years7 30 min
ac high
NF NF
NF NF
NF 15-20 min

NF 55 min

INTERFERENCES
Oxidizing
CL, species
Oxidizing
C17 species
Oxidizing
species
Oxidizing
species
Oxidizing
species
Oxidizing
species
pH RANGE
Buffering
critical
Buffering
critical
Buffering
required
Buffering
required
NR

NR

FIELD
TEST
YES
YES
YES
YES
NO

NO

CURRENT
AUTOMATED STAG'S
NO RECOMMENDED
NO RECOMMENDED
NO ABANDON
NO A3ANDCN
NO ABANDON

NO A3ANDCN

Ml
  NR
  NR
          1 sec
            sec
            sec
None
                   Oxidizing
                    species

                   Non«
Independent   NO    POSSIBLE     A3ANDON


pH Dependent  NO    POSSIBLE   CONT'D STUD


pH Dependent  NO       YES     CONT'D srJD
  NA
  NA
  NA
          NA       Oxidizing
                    Cas species

          NA       Oxidizing
                    species, Cl'
3 months    NA
Dependent POSSIBLE  POSSIBLE
  on pH
                                              CONT'D STUDY
   NR
                         POSSIBLE  POSSIBLE   CONT'D STUDY
                   Oxidizing
                    species Cl"
          NA       Oxidizing
                    species, Cl"
               pH Dependent  YES      YES     RECOMMENDED


               Buffer    POSSIBLE  POSSIBLE
                required

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    TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL .".ETKCCS0 icor.r'i

                   Species*      DETECTION  '-ORKING  EXPECTED  EXPECTED
TYPE OF TEST       MEASURED        LIMIT     RANGE   ACCURACY  PRECISION  SKIL
 (METHOD)*         DIRECTLY       (mg/L)    (mg/L)     (± %)     (± %)     LEVE


TOTAL CHLORINE•

  •Ideal"       Cl, + HOC1/CC1-   0.001     0.001-10   0.5    0.1
                NH,C1 NHC1, NCI,


  AMPEROMETRIC TITRATION:

    Forward     Cl, -t- HOC1/OC1'   0.00181     > 10        NF     NF         2
                NH,C1 NHC1, NCI,
                Cl, + HOC1/OC1-  0.02  -0.032  > 10        NF   3 - 50       2
                NHjCl NHC1, NC13

    Sack        Cl, * HOC1/OC1-   0.002       > 10       3-30   NF         2
                NH,C1 NHC1, NCI,

    Concinuous  Cl, -t- HOC1/OC1"   0.005       > 10        NR    1.0        2/3
                NH3C1 .N*HCla NCI,


  IODOMETRIC TITRATION:

    Standard    Cl, f HOCl/OCl'   0.073     0.1-10      MR     rrR         ;
                NH,C1 NHC1, NCI3
                Clj f HOC1/OC1-   0.35«     0.5 - ICO     N'R     N"R         :
                NH,C1 NHC1, NClj


  DPD

    FAS  Tic'n   Cl, + HOC1/OC1-   0.0043    0.01 - 10     NF   2-7        l
                NH,C1 NHC1, NCI,
                ci, + Hoci/ocr   0.11*     0.01-10     NF   2-7        i
                NH,C1 NHC1, NCI,

    Color'mcrc  Cl, t- HOCl/OCl'   0.001s    0.01 - 10    1 - 15 1 - lu
                NH,C1 NHC1, NCI,


  LCV

    Black 6.
      Vhiccle   Cl, f HOCl/OCl-   0.005     0.25-3      NF   A - 10       1
                NHJC1 NHC1, NCI,

-------
    TABLE I.  CHARACTERISTICS (cont'd)
    STABILITY                                   FIELD               CURRENT
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE   TEST   AUTOMATED    STATUS
5 YRS

1 - 2 yrs
1 - 2 yrs
1 - 2 yrs
L - 2 yrs
1 yr
1 yr
powder
stable*
powder
stable*
powder
stable8
months
> 1 DAY NONE

NA Oxidizing
Species
NA Oxidizing
Species
NA Oxidizing
Species
NA Oxidizing
Species
10 ain All oxidizing
species
10 min All oxidizing
species
30 min . Oxidizing
Species
30 min Oxidizing
Species
30 min Oxidizing
Species
.'«*R Oxidizing
Species
Independent YES
of pH
pH Dependent YES
pH Dependent YES
pH Dependent YES
pH Dependent YES
?H Dependent NO
pH Dependent NO
Requires NO
buffer
Requires YES
buffer
Requires YES
buffer
Requires YES
buffer
YES RECOMMENDED

YES RECOMMENDED
YES RECOMMENDED
YES •3.ECCwrVi'EN'DrD
YES RECOMMENDED
NO RECOMMENDED
(LA3 "ST^
NO RECOMMENDED
(LAB TEST}
NO RECOMMENDED
(LAB TEST)
NO RECOMMENDED
(FIELD TES'
NO RECOMMENDED
(FIELD TES
NO ABANDON

-------
     TASLZ  I.   CHARACTERISTICS  AND  COMPARISONS  OF ANALYTICAL METHC2S'9  'c=n:'i^
TYPE  OF  TEST
  (METHOD)*
Species'      DETECTION  WORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACC'JRACY  PRECISION  SKILL'
DIRECTLY       (mg/D    (aig/L)     (± %)      (± %)    LEVEL
    Vhiccle  &
       Lapceff    Cl_  -t-  HOC1/OC1'    0.01       0.25-10     NF    i  -  10       2
                 NHJC1  NHC12  NCI,
  FACTS

    Color'acre   Cl,  + HOC1/OC1"    0.1
                 NH,C1 SHCla NCI,
                         0.25 -10   5 - 20 1 - 11
    Specc'phoco Cl, -t- HOC1/OC1-    0.012      0.05  -  10      SF
                            NC1
  ELECTRODE METHODS

    Pot'=ecric  Cl, -t- HOC1/OC1'   0.005      0.01  -  1     1  -  6   7  -  10
                NH2ci jmcij NCI, •
MONOCHLORAMINE9

  "Ideal'
               0.001
          0.001-10   0.5    0.1
  L'V/VISISLE
   NH,C1
- 1
      100
NTl
  AMPERCMETRIC TITRATION:

    Forward           NH2C1

    Back              NH2C1
                NR

                MR
           > 10

           > 10
                NF   0-10

                NF     NF
  DPD

    FAS Tic'n

    Color'acre
   NH,Cl
   NHjCl
 NR

 NR
0.01 - 10

0.01 - 10
NF   2  • 7       1

NF   5  - 75      1
                                       10

-------
    TABLE 1.  CHARACTERISTICS  (conc'd)
    STABILITY
REAGENT   PRODUCTS    INTERFERENCES   pH RANGE
                                     FIELD               CURRENT
                                     TEST   AUTOMATED     STATUS
 aonths     .S"R
          Oxidizing
           Species
 Buffering    YES
                                      NO      RECOMMENDED?
                                               (LAB TEST)
 2 YRS
 2 YRS
30 min
at high
C13

30 min
ac high
Cl,
Oxidizing
 Species
Oxidizing
 species
 Buffering     YES      NO
  critical
                                              RECOMMENDED
                Buffering    YES
                 critical
                       NO
3 months    NA
          Oxidizing      pH Dependent  YES
           Species, Cl*
                       YES      RECOMMENDED
 5 YRS    > 1 DAY
              NONE
Cndependent   YES
 NA       CljNH -  CljN
           backgnd Abs
                                    pH Dependent  NO
                                      NO
                               RECChru~'l.'~r"'
 1-2 yrs    NA

 1-2 yrs    NA
          C1,NH - CljN   pH Dependent  YES      YES

          C1,KH - CljN   pH Dependent  YES      YES
                               RECOMMENDED

                               RECOMMENDED
powder     30 min
  stable9
powder     30 min
  stable4
          C1MH,  -  CljN
           oxid species
          C1NH,  -  CljN
           oxid species
 Requires
  buffer
 Requires
  buffer
                             NO

                             YES
                                      NO

                                      NO
RECOMMENDED
 (LAB TEST)
RECOMMENDED
 (FIELD TES1
                                       11

-------
    TABLE  ..   CHARACTERISTICS AND COMPARISON'S OF ANALYTICAL METHODS3  [ccr.t'd;
TYPE OF TEST
  (METHOD)*
Species*      DETECTION  VORXING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACCURACY  PRECISIC'J
DIRECTLY       (mg/L)    (rag/L)     (± %)      (* %)
    Whittle &
      Lapteff
   NH,C1
          0.25-10     NF
  ELECTRODE METHODS

    Silver iodide
    Voltaooetrie
   NH7Cl
 .VR
0.1 - 10
DICHLDRAMINE^

  •Ideal-
               0.001     0.001 - 10   0.5
                                                                 0. 1
  UV/VISI3LE
   NHC1,
- 1
1 - 100
  AMPERCMETRIC TITRATICN:

    Forward           N"HC12

    Back              NHC1,
                .VR
           > 10

           > 10
              NF      3

             3-50   NT
  DPD

    FAS  Tic'n

    Color'mtrc
   NHC1.
   NHC1,
 NR
0.01

0.01
10

10
NF

NF
                                                                 0 - 100
  LCV
    Whittle  &
      Lapccff
  NHC1.
 NR
0.25 - 10
       NF
      10 -  150   2

-------
    TABLE I.  CHARACTERISTICS (cont'd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE
                                    FIELD
                                    TEST   AUTOMATED
                                               CURREN:
                                               STATUS
months
NR
Oxidizing
 species
 Requires
  buffer
YES
                                                           NO
                                                                   g rr^v»v«r>"«r-»
  NA
NA       Oxidizing       Requires   POSSIBLE  POSSIBLE  CONT'D  STUDY
          species         buffer
 5 YRS    > 1 DAY
  NA
NA
             NONE
C1NH, & CljN
 backgnd Abs
               Independent
                  of pH
              YES
?H Dependent  NO
         YES      RECOMMENDED
         NO       RECOMMENDED
                   ,LAB  TEST:
 1-2 vrs

 1-2 vrs
S'A       C1NH, & C13N   pH  Dependent   YES

NA       C1NH, & CljM   ?H  Dependent   YES
                                       YES      RECCMMENDE2

                                       YES      RECOMMENDED
powder     30 ain
  stable4
powder     30 ain
  stable*
months
NR
INH, & CljN
oxid species
INK, & C13N
oxid species
Oxidizing
species
Requires
buffer
Requires
buffer
Requires
buffer
NO
YES
YES
NO
NO
NO
                                                        RECOMMENDED
                                                         (LAB TEST)
                                                        RECOMMENDED
                                                         (FIELD TEST:
                                               RECOMMENDEDD
                                                (LAB TEST)
                                       13

-------
    TABLE  I.   CHARACTERISTICS  AND  COMPARISONS OF ANALYTICAL METHODS*  (cor.fi

                    Species'      DETECTION  ','CRKING   EXPECTED   EXPECTED
TYPE OF TEST        MEASURED         LIMIT     RANGE    ACCURACY   PRECISION  SKILL'
  (METHOD)*          DIRECTLY        (ng/L)    (mg/L)      (±  %)      (± %)    LEVEL


TRICHLORAMIKE9

  "Id«al"              NCI,         0.001     0.001  -  10   0.5     0.1         i


  UV/VISI3LE           NCI,          NR         NR           :TR      N"R         3


  AMPEROMETRIC TITRATION:

    Forward            NC13          NR        >  10          NF    5 -  ICO      2
  DPD

    FAS TiC'n         NCI,         NR       0.01  -  10      Ml      Ml        1

    Color'acre        NC13      •   NR       0.01  -  10      Ml      Ml


  LCV

    Vhitrle &         NC13         Ml       0.25  •  10      NR      N"R        ;
      Lapceff


CHLORINZ DIOXIDE

  •Ideal'             CIO,        0.001     0.001-10   0.5      0.1        1

  ICDOMETRIC      "    CIO,        0.002     0.002  -  95   1  - 2    1-2       2


  AMPEROMETRIC        CIO,10      0.012     0.02  -  ??    1  - 15   1  -  15      3


  DPD                 CIO,10'11   0.008     0.008  -  20

  UV

    Manual            CIO,        0.05      0.05-500      5


    FIA               CIO,        0.25      0.25  -  142      2

-------
TABLE I.  CHARACTERISTICS (cont'd)
STABILITY
REAGENT PRODUCTS INTERFERENCES
5 YRS
NA
1-2 yrs
powder
stable8
powder
stable8
xonchs
5 YRS
1 VR
good
solid
stable8
none
none
> 1 DAY NONE
NA GINK, - CUNH
backgnd Abs
HOC 1/0 CL-
NA C1NH7 - C1,NH
30 Bin C1NH, - C12NH
oxid species
30 min C1NH, - C1,NH
oxid species
NR Oxidizing
species
> 1 DAY NONE
Subject to Oxidizing
oxidation species
Subject to Metal ions &
oxidation nitrite ion
< 30 oin Oxidizing
species
none Other UV
absorbers
none none
FIELD CURRENT
pH RANGE TEST AUTOMATED STATUS
Independent YES
pH Dependent NO
pH Dependent NO
Requires NO
buffer
Requires YES
buffer
Requires YES
buffer
Independent YES
2-5 NO
7 NO
7 NO
Independent NO
Independent NO
YES RECOMMENDED
NO RECCMMENDED
(LAS TIST/
YES RECCXMENDED
/T .3 ••— C"" ^
1 t>O . ^0 . ;
NO RECCMME1IDED
r.\3 TEST)
NO RECOMMENDED
(LA3 TEST^
NO RECCXXENDED
i, — -k3 T i 3 . /
YES RECOMMENDED
NO NOT RECOMMENDED
NO CURRENTLY USED
NO NOT RECOMMENDED
YES RECOMMENDED
(H3 TEST)
YES RECOMMENDED
(LAS TEST)
                                   15

-------
   TABLE I.   CHARACTERISTICS AND  COMPARISONS CF ANALYTICAL METHODS'* (ccr.c'
Species' DETECTION VCRKING EXPECTED EXPEC'
TPE OF TEST MEASURED LIMIT RANGE ACCURACY PRECI.
(METHOD)' DIRECTLY (mg/L) (ag/L) (± %) (± '
ACVK12
CHLOROPHENOL RED
o-TOLIDINE
INDIGO BLUE
CHEMILUMINESCENCE
Luoinol
CDFIA13
ELECTROCHE.M.
CIO, 0.04 0-25 NR .N"R
CIO, 0.003 0.003 - 1 10 5
CIO, 0.1 NR NR Ml
CIO, 0.01 NR N*R 1.5

CIO, 0.3 0.3-1 NR 3
CIO, 0.005 0.005-74 2

PC Microelec. CIO, + CIO,* -1.3 NR 7 N"R
Vic. Carbon
Volcaa. Mem.
CIO, 32 NR NR NR
CIO, 0.25 NR N-R NR
    Rotating Vole.
    Membrane         CIO,         0.30       0.30-3     NR     5.4
CHLORITE ION

  •Ideal-            CIO,"        0.001     0.001 -  10   0.5     0,1
  AMPEROMETRIC

    lodomecric       CIO,'        0.05      0.05  -  95    5        5
  IODOMETRIC

    Sequential       CIO,'        0.011        > 1        1        1

    Modified         CIO,'        0.3        0.5-20     0.5     1-3


 DPD                 CIO,"         0.01       0.01   •  10    5        5
                                                                           2/3
                                     16

-------
    TA3LE I.   CHARACTERISTICS (conc'd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   ?H RANGE
                                        FIELD               CURREN1
                                        TEST   AUTOMATED     STATUS
NR
6 months
NR

good
1 DAY
1 DAY

none
none
none
NR
NR
NR

good
< 1 sec
< 1 sec

none
none
none
minimal
unknown
Oxidizing
species
0, Cl,
NR
ci,

cio7-
cio,-
HOC1
3.1-3.4 NO
7 YES
ra NO

> 4 NO
NR NO
> 12 NO

5-5.5 NO
3.5-7 NO •
7.8 NO
NO
NO
NO

NO
NO
YES

NO
NO
NO
~ <^ »»^« » -^ ^ ^» «^«
-v.i ^ J i i , -
NOT RECOMMEND
NOT RECOMMEND

NOT RECOMMEND
NOT ?,ECCMyrND
RECOMMENDED
:ONT'D STUD
CONT ' D S i wD
uONT ' D ST". D
CCNT'D Sr.'D
i
ID
ID

•""S
«•/
12

;Y
Y
'•

 none
           none
                        HOC1
                            5 -  5.5
                           NO
                     NO
 5  YRS
 > I DAY
 NONE
Independent   YES
         YES
                             RECOMMENDED
 1 YR
Subject co
oxidation
Oxidizing
 species
2 - 5
NO
                       NO    NOT RECOMMENDED
 good
 good
 Solid
 stable8
Subject to
oxidation

Subject to
oxidation

 < 30 min
Metal ions &
 nitite ion

Metal ions &
 nitite ion

Oxidizing
 species
            NO       NO    RECOMMENDED AT
                              HIGH CONC.

            NO       NO      CONT'D STUDY
            NO       NO    NOT RECOMMENDID
                                      17

-------
 TA3L2 I.   CHARACTERISTICS AND COMPARISONS  CF  ANALYTICAL METHODS5
TYPE CF TEST
 (METHOD)'
CHLORATE ION

  •Ideal"


  IODOMETRIC

    Sequencial


    Modified-


    FIA


    DPD


OZONE

  •Ideal'
 ARSENIC  BACK
 TITRATICN
  FACTS


  DPD

  INDIGO

   Spect'phoco
Species'
MEASURED
DIRECTLY
c:o,-
cio3-
ClOj-
ciOj-
cio3-
°3
°3
o,
°3
Qj
°3


DETECTION
LIMIT
(ag/L)
0.001
0.064
0.3
0.03
0.01
0.01
0.002
0.002
0.02
0.1
0.001
0.006
0.1
WORKING EXPEC
RANGE ACCUR,
(ag/L) (±
0.001 - 10 0
> 1
0.3 - 20
0.08 - 0.3 3
0.01 - 10
0.01-10 0
0.5 - 100
0.5-65
0.5-5 5
0.2-2 5
0.01 - .1
0.05 - .5
> 0.3
•»«•<
* w<
AC
%)
.5
2
1
. 5
5
. 5
-
-
•
•
1
1
1
                                                                          c •.•••• «
                                                                 (± %)
                                                                 3.1
                                                                1  -  3
                                                            35   1
                                                                 0.5

                                                                 0.5

                                                                 0.5
                                      13

-------
    TABLE I.  CHARACTERISTICS (cont'd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE
FIELD               CURREN:
TEST   AUTOMATED    STATUS
5 YRS
good

good

1 year

Solid
stable*
5 YRS
1 YR


1 YR

2 YRS

Solid
stable8
good

good

good
> 1 DAY
Subject to
oxidation
Subject to
oxidation
1 day

< 20 min

> 1 DAY
subject co
oxidation

subject to
oxidation
no fading
first 5 aiin
< 30 min

good

good

good
NONE Independent YES
Metal ions & 7 NO
nitrite ion
Metal ions & 2 NO
nitrite ion
Oxidizing < 1 NO
species
Oxidizing 7 NO
species
NONE Independent YES
All ozone < 2 NO
by products
and oxidants
Oxidizing 6.8 NO
species
Oxidizing 6.6 NO
species
Oxidizing 6.4 NO
species
Cl,, Mn ions 2 NO
Br, I,
Cl,, Mn ions 2 NO
Br, I,
Cl,, Mn ions 2 NO
YES RECOMMENDED
NO RECOMMENDED AT
HIGH CCNC.
NO CONT'D STUDY

YES USED AFTER ALL
'"'D " "* 3 " — «x.-.
NO NOT RECOMMENDED

VIS R£CC— C-
NO ABANDON


NO CONT'D STUDY

NO NOT RECOMMENDED

NO SOT RECOMMENDED

YES RECOMMENDED

YES RECOMMENDED

YES RECOMMENDED
                       Br2 I.
                                       19

-------
TA3LE I.  CHARACTERISTICS AND COMPARISONS 0? ANALYTICAL METHODS5 (conc'd;
                                                                (±
Species'
V?E OF TEST MEASURED
(METHOD)* DIRECTLY
INDIGO (cont'd)
Visual 03

GDFIA 03

LCV 03
ACVK 03
o-TOLIDINE 03
3ISTERPYRIDINE 03
CARMINE INDIGO 03
ELECTROCHEM
Aaperonecric Total
oxidants
Amperometric
iodometric - Total
Oxidants
Bare electrode 03
Membrane elect. 0,
Differential
Pulse Dropping
Mercury 03
Differential
Pulse Polar-
ography 03
Pocenciometnc 03
DETECTION FORKING EXPECT!
LIMIT RANGE ACCURAf
(mg/L) (ag/L) (± %

0.1 0.01 - 0.1
> 0.1
0.03 0.03 - 0.4
other ranges
possible
0.005 NR
0.25 O.C5 - 1
NOT QUANTITATIVE
' 0.004 0.05 - 20
< 0.5 NR

- 1 NR
- 0.5 NR

0.2 NF
0.062 NF

NR NR


0.003 NR
NR NR

5
5
1

SR
N-R
N"R
2.7
NR

5
5

5
5

Nl


Nl
V
                                                                0.5
                                                                 NR
                                                                 5




                                                                 5








                                                                 NH
                                     20

-------
    TA3LZ I.  CHARACTERISTICS  (conc'd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE
FIELD               CURREN
TEST   AUTOMATED    STATJS
good
good
good

Stable
MR
NR
Good
NR
r.one
1 YR
none
none
none
none
none
good
good
good

Stable
NR
NR
Good
NR
NA
Subject to
oxidation
NR
NR
NR
NR
NR
Cl, , Mn ions 2
Br, I,
Cl, . Mn ions 2
Br, I2
Cl, at > Img/L 2

S2' SO3' Cr*" 2
Mn > 1 mg/L 2
Cl, > 10 mg/L
Metal ions, N02' 2
C12 < 7
NR 2
Oxidizing 2
species
Oxidizing 4-4.5
species
NR NR
NR NR
NR NR
NR 4
NR NR
YES
YES
NO

NO
NO
YES
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO RECOMMENDED
NO RECOMMENDED
YES COMPARISON
STUDIES
NEEDED
NO CONT'D STUDY
NO CONT'D STUDY
NO A3ANDCN
YES RECOMMENDED
NO CO NT ' D STUDY
YES RELATIVE
MONITORING
NO NOT RE CC MM END ED
YES CONT'D STUDY
POSSIBLE CCNT'D STUDY
NO RESEARCH LA3
NO CCNT'D STUDY
YES CCNT'D STUDY
                                       21

-------
 TABLI I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS5
 •YPE OF TEST
 (METHOD)*
Species'      DETECTION  -ORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACCURACY  PRECISION
DIRECTLY       (mg/L)    (fflg/L)      (± %)     'r %)

  UV
               0.02
> 0.02
0.51'
  ISOTHERMAL
  PRESSURE CHANCE
               x 10-s  4 x 10-s  -  10 0.5
                     0.5
OZONE GAS PHASE

  "Ideal"

   uv
                1      1 -  50,000     I

               0.5     0.5  -  50,000   2
                     2.5
Stripping
Absorption
lodoaetry 03
Chemiluainescence 03
Gas phase titration 03
Rhodaaine S/
Gallic Acid 03
Aaperoaetry Os


0.002 0.5 - ICO 1-35 1-2 2
0.005 0.005 - 1 7 5 1,2
0.005 0.005 • 20 . 3 35 2

0.001 Ml Ml 5
Ml Ml Ml Ml
    '   for page nuabers in the full report, refer co che Alphabetical Ir.ciex
    f   direct determination of the species measured without interferences
    *   Operator Skill Levels:  1 - minimal, 2 - good technician,
                                            3 - experienced chemist
    SA Not applicable
    Ml Not reported
    NF Not found
    1   Using research grade electrochemical equipment
    2   Using commercial cicracor
    3   Speccrophocomecric endpoint detection
    >4   Visual endpoinc detection.
    5   Using tesc kic
    6   Liquid reagent is unstable
    7   Scablility is very dependent on the purity of the 2-propanol used

-------
    TABLE I.  CHARACTERISTICS (cor.t'd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE
 none
 none
good
           Other
         Absorber
                      none
            Ir.deoendent
            Independent
                                        FIELD
                                        TEST   AUTOMATED     STATUS
                N'O
YES     ESTABLISH
      MOLAR ABSORB -
        TIVITY

YES     COMPARISON
        STUDY
 none

 none
none

none
none

none
Independent     YES      YES

      NA        YES      YES
        RECOMMENDED

        RECOMMENDED
 good     good

 stable  < 1 sec

 stable  stable


problems
 none
          none
SO, NO;
none
none
MR
NR
NA
NA
NA
NA
NA
                                        YES      NO        ABANDON

                                        YES      YES     RECOMMENCED

                                        YES      NO   NOT RECOMMENDED


                                        YES  POSSIBLE SOT RECOMMENDED

                                        YES      YES  NOT RECOMMENDED
    8  Total Chlorine is all chlorine species with +1 oxidation state
    9  Very little^accual work has been carried out on selective determination
       of chloraaine*.  The values reported are from extrapolated studies char
       had objectives other than the selective determination of chloraair.es.
       Most methods are indirect procedures which are not recommended
   10  Indirect method
   11  1/5 of CIO, determined
   12  Acid chrome violec potassiua (ACVK)
   13  Gas diffusion flow injection analysis (GOFIA)
   14  Based on current molar absorbtivity and proper saaple handling tecniques
       Current best estimates of molar absorbtivity  of 2900-3300 give a.
       possible error of > 10%.
    ®  Taken from Cordon, Cooper, Rice, and Pacey, AWA-RF Review on
       "Disinfectant Residual Measurements Methods"  (1987)

-------
    Chapter 4  (Indexed Reference Citations) has been included in this report  in
order  to  assist   readers   in  locating  particular papers of interest.  7r.e -3
categories for  chlorine, chloranines. and the oxy-chlorine species,  along  vitn
the  additional 60   categories  for  ozone, should make the task of finding ir. •
dividual papers of  interest  considerably less cumbersome.  Papers vnich deserve
several methods have  been  included  in each of the appropriate  categories.   .-.11
togetr.er.  the   1,400 references   cited  in Chapters  1-3 r.uzoer ;ore than 2. 120
individual citations  when  distributed in the indexed fora of Chapter V

    Chapter 5  is an alphabetical listing of the individual references citations
Finally, a detailed Index  has been   included  in  order  to  assist  readers  in
locating  subjects  of   specific  interest,  '-e hope the readers -'ill find t.-.ase
additional chapters as useful as have we in preparing  this report.


RECOMMENDATIONS
    General  Statements  on  Comparisons.

    There have been and will continue  to be  reports of aethods  corranson.    7r.e
of  the most  important  considerations  for a  method  is accuracy,  i  2.  tr.e  asili;-.-
of the method to determine  the  correct  concentration   of  a   disinfectant   :n
solution.  An equally  important consideration  is  precision,  i.e.  r.ow veil cicas
the analytical method reproducibly measure the   saam  concentration.  Frequer.tlv
experiments   are  conducted to determine the  "equivalency" of  the  zetr.ccs.  ~r--z
such results, methods may be found to  be equivalent,  but the   only  aralvti:a.
considerations  tested  were  accuracy,  as   judged by   a  Referee   .a.etr.oc.  —£
precision, judged for each metnod based on the experimental design.

    No considerations were given to specificity  or  analyst preference.  Vac   ere
of  the  most  difficult   tasks  in  the area of disinfection analytical  metr.oss
development  is comparison  testing.    It  is  recomn«nd«d that  a  protocol   ;e
developed  to  initiate comparison  of the  disinfectants.  This protocol should
include all  of the factors delineated  in  the   "Ideal  Method"  and  snould   be
undertaken   in  both  laboratory  controlled  conditions  and   at  selected wacer
treatment plants around the country.

    Chlorine  Chemistry.

    Clearly,  the conversion to moles,  equivalents,  or normality  fron  units   of
mg/L  (as  C12)  or  mg/L  (as  other  oxidants)  can  easily   be  confused (and
confusing). Our recommendation is that all oxidizing agents be  reported in molar
units (M) and, if necessary, in mg/L of that  oxidizing agent as  measured  (i  e.
ag/L  (as C17) or mg/L  (as C10S") or mg/L (as C10S") .  Furthermore, we recotsreend
that  oxidizing  equivalents  per  mole  of   oxidant  be  reported  to  minimize
additional  potential   confusion.   For  example, when CIO, is  reduced to CIO.',
this corresponds to one equivalent/mole; on  the  other hand, when CIO; is  reduced
to Cl" ,  this  corresponds to  five  equivalents/mole.   A  sugary  of  molecular
weights  and  oxidizing  equivalents for the various  chlorine species,  oxychlorire
species and ozone is given in Table II.

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TA3L£ II. EQUIVALENT WEIGHTS FOR CALCULATING CONCENTRATIONS
BASIS OF MASS.
Molecular Zaui
Species
Chlonr.t
Monochlo raaine
Dichloraaine
Trichloraaine
Chlorine dioxide
Chlorine dioxide
Chlorite ion
Chlorate ion
Ozone
Ozone
'-eight
g/nol
70.906
51.476
85.921
120.366
67.452
67.452
67.452
33.451
47.998
47.998
Electrons
Transferred
2
2
4
6
1
5
4
6
2
6
ON THE
valent
'-eight
s/eq
35.
25.
2i
20.
67.
13.
4 1"
13.
23.
3.
453
733
430
061
452
490
363
909
999
000
    Several mechanisms have been proposed for the decomposition of dichloramir.e ,
but the complete aecnanism ac the breakpoint has not been resolved. Cleariv. the
chemistry is complicated and  varies  markedly  with  solution  composition.   -\
detailed  understanding  of  the specific reactions involved requires a detailed
knowledge of the concentration of all chloraaune species in the system.

    Nitrogen-containing organic compounds may b« present in  surface  water  and
ground-water.   Because  of  analytical  complexities, very few detailed studies
have been undertaken to determine  the  individual  compounds  present  and  the
concentration   at  which  they  exist.   KJeldahl  nitrogen  analysis  is  used
frequently, but this dots noc provide any dtcailtd information  with  regard  to
individual  compounds.   The  area  of organic nitrogen and the determination of
specific compounds in natural waters is  one  of  the  increasing  interest  ar.d
requires considtrably aore research in characterization and methods development.

    Ultraviolet Methods.

    In general, because the molar absorptivities are quite low for chlorine  and
chloramine  species,  ultraviolet  methods  are noc considered useful in routine
monitoring of chlorine residuals.  In addition co the low molar  absorptivities.
there  is often background absorbance that may interfere with the measurement in
various natural waters.  However, these measurements are of use in standardising
the chlorine species in distilled waters and are often used in experimental vortc
                                      25

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related to chlorine  speculation.  This method docs  have  considerable  pocert.a.
for   the   determination   of   relacively  high  concentrations  of  halogens.
particularly   in   relatively  clean  water.   This  method  night  find  use  ir.
monitoring  chlorine  species   in  water treatment plants.  However, with a r.ora
elaborate aultiwavelength   spectrophotoneter  and  computer-controlled  spectral
analysis, it mignt be possible  co analyze several halogens simultaneously.

     Ir is also possible that additional methods using permeable nembrar.es ccu.d
be developed for  the simultaneous determination of chlorine species  in  aqueous
solution.   Additional  work  is  necessary  in  this  area.  Alchougn the rsoLar
absorptivities of  the species is not of a magnitude as to lend it to the routine
determination  of  the dilute (less than 10"s  M)  chlorine  and  chlonr.e-araor.ia
species,  it is potentially helpful in determining the concentration of stansara
solutions.  Absorption spectrophotometric analysis has and will continue  to  ;e
very  important   in  the  area  of  chlorine  chemistry.   It can be used in the
unambiguous determination of relacively high concentrations of  rr.e  species  in
relatively purt water.

     Continuous Aarperomecric Titration Method.

    Interferences appear to be  reduced using the continuous arr.perometnc  zetr.sc.
because  the   reagents  are  added  to  the  saople just prior to contacting tr.e
indicating electrode. Thus, when compared to  the  amperometric  titration.  tr.e
amount  of  interference  by iodate ion, bromate ion. copper(II), ironilll), ana
manganese( IV)  is reduced by approximately one-tenth.  N'o reports  appear  to  ;e
available  in  the  literature  -on the determination of mixed oxidants using the
amperometric method.  Such experiments need to be carried out. In addition.  few
experiments  have  been  reported  which clearly demonstrate that the electrodes
remain uncontarainated for drinking water or waste water systems.  In tr.e absence
of  such  comparisons,  the  accuracy  of  any  electrode   proceoure   -av   :a
quescionaole.

    However, the amperometric deration determination of  chlorine  species  ra-
mains  the  standard  for routine laboratory measurements.  Given proper analvst
training and experience, the commercially available instrumentation is sensitive
and precise.   This method should remain as the method  for  laboratory  use  and
accuracy  comparisons.   It  requires  more analyst experience than coloriaetric
methods, but can b« relied on to give very accurate  and  precise  measurements
It  should  be noted that car*  oust be exercised when using one titrator for tr.e
measurement of both free and combined chlorine.  Small quantities of iodide  ion
can  lead  to  errors  wh«n  differentiating between free and combined chlorine.
Careful rinsing with chlorine demand free wattr (COFV) is  a  must!   Additional
development  of automated back-titration equipment with the goal of lowering the
limit of detection and improving the reproducibility would be highly beneficial.

    lodometric Titration Method.

    The iodometric titration is useful for determining  high  concentrations  of
total  chlorine.   The most useful range is 1 ng/L (as C17) or greater.  It is  a
common oxidation-reduction  titration analytical method and provides a  reference
procedure  for  total  chlorine.   Although not necessarily used routinely, r.ost
laboratories use  it as a reference method and  it  is  not  likely  ever  to  be
eliminated from use.
                                      26

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    Coloriaecric Methods.

    Ic  is reported  in Standard ^ethods (13) that  nitrogen  trichloride  can  be
measured  using  the  D?D  metnod; however, the method has not been confirmed by
independent  investigations and should be used  only  as  a  qualitative  method
Additional   research  is  necessary  to  determine  the effectiveness of the j?D
method  for nitrogen trichloride.   The  effect  of  the  presence  of  nercur-.:
chloride  in  the reagents for air.iaizir.g the breakthrough of laor.ochLoraraine ir.ro
the free chlorine reading vith the  DPD  methoa  has  been  shovn.  It  is  very
important  that  the  addition of mercuric chloride to tne buffer be followed to
minimize the  direct reaction of monochloramine with DPD.  This phenomenon is not
thoroughly understood.  This effect should be scudied more  thoroughly  and  tr.e
principle may be applicable to all of the colorimetric methods.

    The use of  thioacetamide  was  evaluated  for  monochloraaine  (using  2?D-
Steadifac).   It  was  shovn  under  these  conditions  to eliainate any positive
inteference  in the  free residual measurement.  These  results  are  not  as  ye:
understood,   but the implication is chat the chemistry of oxidation is different
for monochloramine  and free chlorine.  These results suggest that more  work  is
necessary  to  better define the reactions involved, and this may lead to a aore
usable analytical procedure. This procedure is recommended  for  use   in  waters
that are suspected  to be relatively high in combined chlorine.

    The DPD-Ethyl Acetate Extraction Procedure is  a  modification  of  the  2?D
chemistry.    The  method  is  based  on  the  oxidation  of iooide ion by active
chlorine followed by extraction of the iodine species into ethyl acetate.   This
procedural  modification  may  be  of use in the determination of total residual
chlorine in both the field and laboratory.  Additional work is necessary  Before
it  can  be   used   to any great extent.  It does not appear to offer SUBS tart:2!
advantages to  the  already  well  tested  colorimetnc  method  for   Laboratsrv
measurements.

    The DPD methods have become the most widely used procedures for the measure-
ment of chlorine.   This is not likely to  change.  The  DPD  color  reagent,
liquid form,  has been shovn to be quite unstable and is not recommended for use.
It  is sensitive to oxidation by oxygen and thus requires a control measurement.
Clearly, it is better to use dry reagents.

    Leuco Crystal Vlolec, LCV.

    No studies have been reported that  examine  the  interference  of  chlorine
dioxide  and/or ozone in the LCV method.   It is anticipated that these oxidancs
would interfere in  the method, and studies should be conducted to quantify  these
potential interferents.

    Syringaldazine; FACTS.

    A study using syringaldazine in a continuous method   to  differentiate  free
from coaoine  chlorine has been reported.   It vas concluded that it could be used
and  was useful in  controlling free chlorination.   Further work would  have  to be
conducted to  use this or any coloriaetric  method  in  continuous analyzers.

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    Cheailufflinescence.

    Several papers have  appeared  that detail the reaction of  hydrogen  reroxiie
and  hypochlorous  acid  and  the  resulting chemiluninescence.   The recnanisrs .".as
been relatively well established  and the chemiluainescence is thougr.t  to  occur
as  a  result of the formation of singlet oxygen.  The light emitted is reel ,fJ5
run), and occurs aost readily  in   alkaline  solution.  This  reaction  is  ratr.er
insensitive  to  low concentrations and is not suitable for the determination of
hypochlorous acid in aqueous  solution.  However,  the  studies  tr.at  have  bear.
reported can serve as a  guide for those interested in pursuing other -ethods far
the determination of hypochlorous acid by chemiluainescence. It is not sensitive
enough to be considered  as an analytical method for chlorine in vater traacrer.t.

    A study  has  been   reported  chat  details  the  use  of  luainoi  for  the
measurement of hypochlorite ion.  The optimum pH for analysis was between 9.0 ar.d
11.0   Luainol  also  has  been used for the determination of hydrogen peroxide.
4, 5 ,6 , 7 , - tetramethoxyluminol  is 30 I more  sensitive  than  luair.ol.  Zither  of
these compounds may be more sensitive in the determination of free chlorine.  As
these  compounds  have   not   been tried  it appears  that acditional studies are
necessary.  From the limited  data available, it appears that this  reaction  .-.as
considerable  promise  as  an  analytical  aethod.  It say very veil be t.-.e rose
sensitive method to date.

    Ic is reported thac  lophine,  in a reaction with hypochlorite   ion.  produces
light.    Very few details were given in the study for this  reaction.   It  appears
that lophine also may be good as.  a chemiluainescence  reaction  systera   for   free
chlorine.   Additional   work  should  be  undertaken  to better characterise  t.-.e
details of this reaction.

    Luminol and some of  its derivatives, or lophine,  raay be well  suites  :or   r.-.a
very  sensitive measurements  of chlorine species.  Additional researcr.  s.-.ou.c  -e
undertaken to develop the use of  chemiluainescence  for use  in t.-.e  ieterr.ir.acior.
of  chlorine  in  water.   The  potential exists for  rapid, sispie, ani  specific
methods for chlorine and possibly other oxidants.   Vith  the  acver.t   of   firer
optic   sensors   and  their  application  in  chemiluainescence   rethocis,   t-is
technology will be important  in the future.

    Fluorescence.^

    The use of rhodamine B has been reported as a low level fluoroaetnc  ~etr.od
for  the  determination  of  bromine.  This method  is qualitatively specific for
bromine,  although chlorine will react to decrease the fluorescence.  The  advant-
age of this method is chac it is  capable of determining  oxidants  at  very  low
concentrations.   This   method  could  be  applied  to chlorine analysis by  first
using the free chlorine  to oxidize the bromide  ion  to bromine,  an  irreversible
reaction.  followed  by  the  determination  of  bromine.   This  aetr.od was rot
developed fully and very little  work  has  been  undertaken  since  tr.e   first
publication.   It does appear to  have considerable  potential and  future researcr.
in the  area of methods development should not exclude additional  work  on  t-.-. s
fluorometric procedure.
                                       23

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    Other Electrode Methods.

    Additional studies are required to  better  understand  the  limitations  of
membrane  electrode  methods.   It appears that they say have prominent roles to
play in chlorine residual measurements in the future.

    In a series of  experiments  carried  out  for  :he  determination  of  fraa
chlorine  in  tap  vater,  it  was  observed  that  there  was  a  statistical!'.'
significant difference between the results of the amperometric titracion and tr.e
membrane electrodes.  It was thougnt to be a problem in the membrane electroces.
However, on reconsideration, it is possible that the  electrodes  were  actuallv
giving  a  free  chlorine reading and the amperomecric titration was reading t.-.a
sua of free and organically combined chlorine.  The study was conducted on water
which is relatively high in organic nitrogen.  It is possible that  consideraoLe
chlorine  is  present  as  organically  combined  chlorine ano interferes in the
amperometric titracion procedure, but  does  noc  interfere  with  the  aeraorar.e
electrode  measurements.   This  question  oust b« resolved.  Carefully designed
experiments to expicitly resolve these differences would be most appropriate.

    There have been no reports of experiments using bare-electrode  acperometnc
analyzers where other oxidants such as chlorine dioxide, chlorite ion,  chlorate
ion  or  ozone have been tested with the bare-electrode.  Additional studies are
required to expand  these  bare-electrode  aaperometric  studies  to  quantitata
interferences  with  oxidants  otner  than  those tested, and to expar.c to  oc.-.er
natural waters.

    Since  the  accuracy  of  the  potentiometric  electrodes  is  affected.   .:
temperature  corrections  are  noc  used,  it is recommended that temperature  :e
either controlled or rseasured simultaneously.  Additional   indepeneent  reasura-
ments of accuracy should be undertaken for the potentiometric eiectroces.

    It  appears  that  the  potentiosetric  electrode  can  be  used   for   :r.e
determination  of  total  residual  oxidant.   It  is  suitable  for  continuous
measurements and appears to give results that are acceptable  when  ccstarec.  :c
the acperomecric titracor.

    General Suzmary and ReconaendaCions for Chlorine.

    In comparing air of the methods to the "Ideal Method" we find that none co~e
very close to our ideal standard.  Continued development of the various  methods
will, however, com* closer and closer to the ideal.

    For the present, the  aaperometric  titration  techniques  will  remain  :.-.e
laboratory  standard  used  for  the  basis  of  comparisons of accuracy.  These
methods, with proper precautions can differentiate between  the common  inorganic
chorine/chlorine  ammonia  species,  and  in  general  suffer from as few inter-
ferences as any of the methods.

    Of the three cotsaon colorimetric procedures. DPD,  LCV,  and FACTS, the DPD is
by far the most cotaaonly used method.  From  the available  literature it is  clear
that the DPD procedure has a nunber of weaknesses.   In particular,  the  colored
product  is  a  free  radical which limits the stability of the colored reaction
product.  The direct reaction with rsonochloraffline.  to  form  a  product  :cen::cal
                                       29

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 to   ;.-.e  reaction  with   free chlorine, is also a drawback.  This pros lea car. :e
 reduced by the addition of  thioacetamide.  Liquid reagent instability  precl'_-es
 their use in most cases;  care should be taken to determine blanks frequently.

     The present LCV method  that appears in Standard Methods (13) is outdated ar.s.
 has  been substantially improved upon by Whittle and Lapteff (Li).   This  remod.
 allows  for  the  differentiation  of  the  common  free  and combined inorganic
 chlorine  species.   However,  because  only  one  comparison  study  has   :aen
 conducted, additional collaborative  testing is recommended.

     The FACTS test procedure appears to be very useful for the determination  of
 free  chlorine in the presence of relatively high concentrations of coaomea in-
 organic chlorine.  A severe drawback of the FACTS test procedure is the  insolu-
 bility  of the syringaldazine in either 2-propanol or water.  This leads to  cif-
 ficulties in reagenc preparation, and presumably to the color stability  proalea
 encountered  at  the  higher concentrations of chlorine (greater tnan 6  • 3  az/L
 (as  C12)).  Although a method for the use of the FACTS test for  total   chlorine
 has  been reported, it should be tested further.

     Electrode  methods have been developed employing several different concerts.
 The  membrane electrodes appear to have potential as specific aethods  for  h;.-po-
 chlorous  acid.   Common  interferences  are  other nonionized molecules sue.-, as
 chlorine dioxide and ozone.  Potentiometric electrodes for  the determination of
 total  chlorine  are  icproving  in  both  detection liait  and staoility.  These
 electrodes appear to have   promise  in  the  area  of  process   control.   Their
 inclusion as methods for  routine-use in the laboratory and  field is warranted

    Both fluorescence and chemiluainescence methods also show  prcaisa   for  me
 specific determination of free chlorine at very low concentrations,  '-imir.  mis
 area  of  spectrofluorometric  methods,  there  is  considerable  worn vec co re
 initiated.   Continued development work is  warranted  and   recommended   in   mis
promising area.

    From the review of analytical procedures for the determination  of   cr.lorire
 in  aqueous  solution, it is readily apparent that only a  few of the aetr.ods are
 used routinely.  Nevertheless, there is certain to be a  continued  interest  in
 developing new and better methods of analysis.  We would strongly recoeaend  mat
 new  aethods  be presented  in terms of the "Ideal Method" and that whenever  pos-
 sible,  comparisons with real samples and interlaboratory comparisons be  =ade.

    Flow injection analytical techniques are  becoming  very  common.  Continuea
 development  should lead  to the automation of many colorimetric  and fluororsetric
analytical methods for the measurement of free and  combined  chlorine   and  irs
various  species in water.  With the current emphasis on automation, the eethocs
 that are to be developed  and those already developed can readily exceed  present
 standards  of  accuracy   and  precision.   Automation will  also  lead to  ooeracor
 independent methods and should lead  to  improvements  in   process  control  and
monitoring.

    Chlorine Analytical Methods Comparative Studies.

    The reader is cautioned against accepting the results  of any or all  of  me
 above tests without some  reservations.  Where possible we  have tried co  add  co^-
                                       30

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aencs,  parenthetically,  based upon our knowledge of che field.   '.- is verv :--
portant in reviewing data froa comparison cescs chac the analyse be aware of the
objectives of the comparison  testing.   For  example,   a  test  ;?.ay  be  juczea
unacceptable  because of an unacceptable lower limit of detection chat is bevor.c
che need for concern for other investigators.

    In general when testing several test procedures it is important co  idencify
che  objective  of  che  testing.  Squally important is Che use of che daca.  In
reporting che results of the above tests, it should be kept in  nind  chat  r.any
manufacturers  of  chemicals  for  analytical methods and Test Kits change their
procedures as a result of the testing.  The concerned analyst needs co determine
if the results are still valid.  This change is not  necessarily  applicable  to
other  studies  where  the  chemistry  of  an analytical method is examined.  Ir.
general, the more the test studies chemistry and not merely che test procedures.
the more applicable the results are for future reference.

    Another area of confusion concerns precision and  accuracy.   An  analytical
method may be judged acceptable based on the precision of the results, while che
same  aethod  may give poor accuracy.  These statistical parameters are separaca
and must be tested using different experimental designs.  Comparisons  with  c.-.e
•Ideal Method* would require that both be at acceptable levels.

     In general, there is a lack of comprehensive studies co  betcer  understand
che chemistry associated with the individual test procedures.  Investigations of
this nature are necessary on a continuing basis, because of the advances  in ana-
lytical  instrumentation and our-continued improvements in understanding  che ce-
cails of the underlying chemistry.

    Chlorine Dioxide Analytical Methods.

    The iodometric aethod is a questionable method even for carefully ccr.crclled
researcn laboratory chlorine dioxide standards.  In real samples wnere  a   large
number  of  potential interferences can exist, che method is destined ro proauce
erroneous results.  Newer, sore species specific methods are better cr.oices.

    Any cethod which determines  concentrations  by  difference  is  potentially
inaccurate  and  subject to large accuaulative errors--both in ceras of accuracy
and precision.  The-subtraction of two large numbers to produce a  small  number
means  chat the errors associated with those large numbers are propagated co che
small nuaoer.  The result in many cases is chat the error  is  larger  chan  cr.e
smaller  number,  therefore,  giving  meaningless  information.  Methods such as
this,  which obtain values by differences, should be avoided.

    The OPD aethod uses the difference  method  in  the  evaluation  of  concen-
trations.   The  direct  measurement  of species by means of a more reliable ar.d
accurate method to determine chlorine dioxide  is  needed.   The  same  questions
raised about the OPD aethod for chlorine also apply here.

    Ultraviolet spectrophotometry, utilizing continuous flow automated  methods.
has  a  great  potential  for  accurate  and precise measurements with che  added
advantage of ease of operation  and  high  sample  throughput.   Flow  injection
analysis  methods  (FIA)  should be carefully  evaluated against existing nechods
for accuracy and precision.  The method should be field tested and  che pocenc;ai
                                       31

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problem of memorane  reliability should be evaluated for long terra operators.

    Additional bench studies using continuous flow aethods with chemilumir.escar.t
detection must be carried out.  The superior selectivity of this aethod needs  :o
be utilized.  Comparison lab testing and field study should be carried out.

    Chlorite/Chlorate  Ion Analytical Method*.

    The iodometric/amperometric methods are indirect determinations of  chlorite
ion  and  cannoc  be   recommended.  The  DPD  raethod for chlorite ion can not :e
recommended because  ic is unreliable.

     The iodometric  sequential methods appear to be  very  workable  on  samoles
containing  greater  than 1 ag/L chlorite ion or chlorate ion with good precision
and accuracy resulting.  The method requires  considerable  operator  skill  ana
experience  to  obtain good  precision and accuracy for samples containing less
than 1 mg/L chlorite ion or chlorate ion.  The method  should  be  field  testae;
with  other  methods   using both high and low ratios of chlorate ion to chlorite
ion. The method should be used with caution on low  level  samples  of  crir.kir.s
water  and/or  wastewacer,  although  direct  methods requiring less specialised
skills are preferred.

    Interlaboratory  comparisons  should  be  carried  out  for   the   Codified
iodometric method for  the direct analysis of chlorite ion and chlorate ion.  The
detailed effects of various potential interferences need to be evaluated.

    The argentometric  titration method is to be recoaeended only for  relative'.-/
high concentrations of oxy-chlorine species (10-100 mg/L) but aay be verv ^serul
in  establishing  inter-laboratory  bench mark comparisons at these hiir. concen-
tration ranges.  No such comparisons are currently available.

    A highly precise,  automated FIA method for low level chlorate ion  reeds  :o
be developed possibly  using various masking agents such as glycine, oxalic acid,
aalonic  acid,  and  nitrite  ion to initially remove other possible oxv-haiogen
interfering species.   The method appears to be very promising in that it can  ce
used to directly determine low level chlorate ion concentrations.

Difficulties Vith Ozone Measurements: Heed For Ideal Method.

    As a consequence of the nature of ozone, its continuous  self-decomposition,
volatility  from  solution,  and  the  reaction  of  ozone and its decomposition
products with many organic and  inorganic  contaminants  in  water.  the  deter-
mination of dissolved  residual ozone is very difficult.  A detailed knowledge of
the  mechanism  of  aqueous  ozone  decomposition  and the potential role of the
various highly reactive intermediates, is  imperative  in  order  to  accurately
evaluate  the  analytical methods (15).  In this context it should be noted that
most  ozone  methods   are  modifications  of  chlorine  residual  methods  •-•hich
determine  total  oxidants  in  the  solution.   Therefore,  ozone decomposition
products such as hydrogen peroxide and the like are also measured.

    lodometry can be used as an  example  of  the  difficulties  encountered  .r.
making  aqueous  ozone  measurements  (16).  Iodide ion is oxidized to :odir.e bv
ozone in an unbuffered  potassiura iodide solution.  The pH then is adjusted to  :

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with  sulfuric acid and the liberated iodine is titrated with soaiuzi cr.iosuj.fa-a
co a search end point. The ozone/iodine stoichiomecry for this reaction has oeen
found =o range from 0.65 Co 1.5.  Factors affecting the  stoichioraetry  induce
pH, buffer composition, buffer concentration, iodide ion concentration. sampling
techniques,   and  reaction  time.   The  pH  during the initial ozone/iodide icn
reaction and the pH during the iodine deterainacion have been shown to  aarkea'.y
alter  the ozone/iodine scoichioaecry.  The formation of iodate ion and hydroeen
peroxide have been implicated specifically as factors affecting the ozone/iocir.e
stoichio::etry .(17) .   Modifications in the iodine determination  include  char.zes
in  end  point  detection,  pH,  and  back-titration  techniques,  "one of these
modifications has been demonstrated to be totally sacisfaccory.

    The biggest difficulty in interpreting the existing ozone literature is that
no one method has been accepted as the Referee  Method.   Therefore,   coraoanson
between  several  different  methods  can  create  false  conclusions  about tr.e
accuracy of the methods.  The method most often used for comparative purposes  ir.
the research laboratory is UV measurement of ozone at 260 no.   Even   with  this
method  there"  is  apparent  confusion  over  the molar absorptivity for aqueous
ozone, with the values ranging from 2900 to 3600 M"lca'1 (16).

    All analytical methods reported, particularly chose of early vintage,  should
be reevaiuated, considering the recent information about  oxidative  by-procucts
from  ozone  decomposition  and  the  ozonation  process  itself.  Sore of  these
factors may  not  have  been  considered  during  development  of  tr.e  origi.-.ai
analytical  procedures.  Certainly,  more  detailed  information and comparisons
should be available. Because of che  difficulties  of  establisnir.g  a  reliable
Referee  Method  we  propose  chat  che  existing and future setnocs oe cor.parec
against an "Ideal Method".  This "Ideal Method" would  incorporate  all  o:  :.-.e
characteristics  that  are  desired for an ozone method, caking into account all
other potential interferences, decomposition products, and  saapies  arijir.at;.-^
from various sources.  Finally, automation, while not an absolute necessitv  -3.r.
add co che selectivity and ideal nature of a method for ozone determination.

Ozone Measurement: Gas Phas*.

    The many uses of ozonation in the treatment of drinking water are  control lei
by monitoring a number of parameters.  Dissolved residual ozone is only  one   of
these parameters, and its measurement controls only disinfection conducted after
filtration,   but before addition of a residual disinfectant for the distribution
system.   However, it is  very  clear  that  the  cost,  efficiency,  safety  arc
improvements  in  design  of  ozone  water  purification  systems  is  extremely
dependent  on  che  accurate  determination  of  gas  phase  ozone.    Therefore
analytical  methods  muse be developed that will accurately measure ozone  in cr.e
gas phase and residual  ozone  in  the  aqueous  phase.  At  this  point   it   LS
unrealistic to believe thac one single method will be acceptable for both  sarole
matrices.

    lodomecry, UV absorption and chemilurainescence are  the  three  =ost   coT.-.on
methods employed for gas phase measurements  (16). Each of these has been acpliei
to  determine che afflounc of ozone present  in generator exit  gases, when scrippec
from solution to the gas phase, or the amount  of ozone  in  a   contactor  e\naust
gas.
                                       33

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    These techniques of aonitoring concentrations in contactor exr.aus: gases  are
quite promising as a method of controlling the production of adequate quantises
of ozone. This provides considerable savings  in  electrical  energy  coses  for
ozone generation.  Direct  incer-comparisons of the various gas pnase ieasurer:er.t
techniques are needed  in order to evaluate accuracy.

    Determination of stripped ozone in the gaseous state  was  reported  in  ~r.s
15th   Edition  of Standard Methods (13) for measuring ozone dissolved in wa;er.
However, in addition to the procedure being subject to the sane  liaitations   of
UV  absorption and chemiluainescence procedures in aqueous solution, t.-.e effects
of the gas stripping process itself aust be taken into consideration.

    Although  the  iodometric  stripping/aqueous  absorption  method  has   been
approved  in Standard  Methods (13), we question the accuracy of the metnod.  .-.11
evidence would  suggest  that  the  method  is  problematic.   Even  though  the
impurities  are substantially left behind by the stripping, the actual procedure
and the continual decomposition of ozone does introduce inaccuracies  ir.to  :his
method.   This  method can  be  used as a relative measure of ozone for control
purposes.

    This basic stripping approach followed by  absorption  in  acueous  solution
(and  colorimetric measurement) may deserve to be studied further.  However,  rr.e
biggest potential proolem  appears to be that at high concentrations of stone :.-.e
coloriaetric compounds may react by a mechanism different  from   rr.at  used  for
residual  ozone  measurements.   Research should be concentrated on  t.-.e reagents
that have already exhibited ozone selectivity.

lodometry (Aqueous Phase).

    If the performance of  ozone in a specific creataent application  is  -.0:  De-
pendent  only on the ozone, but is instead a collective function of  its reactive
decomposition products as  well, then iodometry can  give  a  representative  ana
reproducible reading of the tocal oxidancs.  For example, aost European srinkir.g
water  treatment  plants   employing  ozonation as the priaary disinfectant, have
relied  on  iodometric  measurements  as  the  basis   for   insuring   adequate
disinfection,  attaining   a  residual  "ozone"  level  of  0.4 mg/L  in :r.e first
contact chamber and maintaing this level for at least four minutes).

    However, it is now abundantly clear that the 0.4 mg/L value is a measure  of
the  amount  of  total  oxidants  present,  and  not  necessarily  ozone  alone.
Therefore,  either the  absolute level of ozone required to  attain  the  expected
degree  of disinfection is lower than 0.4 mg/L over the required period of tiae.
or some of the decomposition/oxidation products formed upon ozonation also  have
disinfecting  properties,  or  both.   Clearly,  detailed experiments r.eed to be
carried out to  demonstrate the efficacy of disinfection  by  the  decomposition
products of ozone.  Similar efficacy data for ozone decomposition products could
be developed for other uses of ozone (e.g., chemical oxidation) when measurement
of  residual  ozone levels must be made to control  the process.  Such data would
help to justify the continued use of  iodometry  to  measure  "total  oxidants',
rather than only ozone.

    Historically, iodometry has been used as the  reference  method  for  de:er-
mining   ozone,   and  against  which  other  analytical  procedures  nave  been

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"standardised".  It is now quice clear thac because of its  lack of  seieccivi:v
che  use of iodomecry should be liaiced to that of only a control  procedure.   Ir.
cerms of ozonacion processes, measurement-for control purposes-of  che  produccicr.
race of ozone generators and bacterial disinfection/viral  inactivacion  say   be
based  upon  iodomecry, provided the user recognizes che many lioitacions of  the
method. The reevaluacion of chis method must be carried ouc  with   the  specific
goal  being to define when che method is reliable and the situations where it is
not accurate.

    Many authors have tactfully pointed out the many disadvantages of iodometrv,
leaving it to the reader to decide whether or not to use the  procedure.    In  a
detailed  conparison  of  eight  analytical  methods  for  the  determination o:
residual ozone it was concluded (16):

         "No iodometric method is recommended for the determination
          of ozone in aqueous solution because of the unreliability
          of the method and because of the difficulty of the com-
          parison of results obtained wtch minor modifications in
          the iodometric method itself."

Arsenic(III) Direct Oxidation.

    In the  direct  oxidation  of  arsenic(III),   ozone  reacts  vich  inorganic
arsenic(III)  at pH 4-7, the pH is adjusted to 6.5-7 and the excess arsenic(III)
species is back-titrated with standard iodine to a starch end point.  Values  for
residual ozone determined by the .arsenic direct  oxidation  method  and  by   ;.-.e
indigo  method  agreed within 61 of  the UV values. The primary advantages of  the
arsenic direct oxidation procedure are minimal interferences, good precision  :n
che  hands of experienced operators, and apparently good overall accuracy.  This
procedure continues to be recommended along with the indigo method.   Additional
comparisons  of  this method should be made with the indigo method under various
conditions.

SyringaldLazine, FACTS.

    The FACTS procedure, which was developed for the selective determination  of
free  available chlorine (hypochlorous acid  + hypochlorite ion) in the presence
of combined chlorine (chloraaines), has been adapted for  the  determination  of
residual  ozone  (19).  In this procedure, an aqueous solution of ozone  is added
to a solution of potassium iodide, and the liberated iodine is  added  to  a  2-
propanol  solution of syringaldazine ac pH 6.6.  The resulting color is measured
spectrophotooetrically ac 530 na.

    The FACTS procedure has the major advantage  of  providing  a  spectrophoto-
setrie procedure for the determination of ozone.  However,  the major limitations
of  the  FACTS  method are still   those of the iodometric procedure.  Due to  the
observed changes in slope  and  intercept  which  are  problems  caused  by   the
interferences, self-decomposition  of ozone, and stoichiometry, this method could
be  reviewed  in  order  to  fully   evaluate its potential usefulness.  However.
considering  :he  other  colorimetric  methods  that   are   available    further
development  of  the  FACTS  method  does  not  seem   to give any promise of  tr.e
improved selectivity that is needed.
                                       35

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N,N-Di«chyl-p-phenyienediaaine. DPD.

    The DPD procedure  is based on "he ozone oxidation of iodide ion  present   ir.
excess phosphace buffer ac pH 6.4 co produce iodine, which then oxidises  che  DPD
cacion  co  a  pink  burster cation wnich is measured speccrophotooecrically,  or
titrated. . The interferences include all oxidants capable  of  oxidising   iodide
ion  co  iodine, including ozone decomposition products, halogens,  and manganese
oxides (20).

    One advantage of the DPD method  is  thac  determinations  can  be  aade   by
ferrous  ammonium sulfate (FAS) titriaetry, spectrophocoraetrically or by  a color
comparator.  Ozone concentrations of less  than  or  equal  ro  2  ag/L  can   be
determined  colorimetrically.  Clearly, the procedure requires the difference of
differences and is limited by the saa* factors which limit iodometry,  specific-
ally the presence of materials which can oxidizt iodide ion to iodine.

    Although evaluation of this procedure versus the  standard  ultraviolet  and
indigo  procedures  would  seem to be necessary to make a more educated decision
about the continued use or abandonment of this  method,  the  recommencacion  is
chat  other  colorimetric  methods  are  considerably  aore  reliable  :han DPD.
Therefore development  or testing is neither recommenced nor considered necessary
at this time.

Indigo Trisulfonate.

    The indigo method  is subject to fewer interferences than  most   coloriaecric
methods  and  fewer interferences than all iodometric procedures (21-23).  AC r.-i
2, chlorite, chlorate, and  perchlorace  ions,  and  hydrogen  peroxide  do  -cc
decolorize  Indigo  Reagent  when  observed  within  a  few  hours   ar.s --hen :.-.e
concentrations of the  interferents are within a factor  of  10  of  thac  of  che
ozone co be determined.

    Ozone decomposition products and   the  products  of  ozonolysis  of  organic
solutes  do  not appear to interfere.  However, chlorine, bromine, and iodir.e do
cause some interference, as do the oxidized forms of manganese.  The acdicicr. of
aaIonic acid to the sample* will mask  the interference  of chlorine.

    For the Indigo Trisulfonate  Method,  it  should  be  noted  that  when  che
ultraviolet  absorption  method is used to standardize  the indigo method (or ary
method) for ozone, the choice of molar absorptivity is  very  critical.   It  is
recommended  that  the  equations  of  Hoigne continue  to be used since chey are
based on a molar absorptivity of 2950 M"lcm~l.  If and  when  a   different  value
for  molar  absorptivity  is reported and confirmed, the  (calibration) equations
would  have  to  be  appropriately  changed.   In   this  manner,   all   current
measurements using the indigo method would continue to  be comparable.

    The advantages of  the indigo procedure is that  it  is based on a  measure  of
discoloration  which   is rapid and stoichiometric.  This analytical  procedure is
recommended for use over any other procedure for  che determination   of  residual
ozone.    Its  primary  attributes  are  its  sensitivity, selectivity, accuracy,
precision,  speed,  and  simplicity of operation.
                                      36

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    The gas diffusion flow  injeccion analysis (CD-FIA) procedure eliminates   t.-.e
 interference  of oxidized foras of manganese, and aarkedly reduces the interfer-
 ence of chlorine (24).  Other than interference of chlorine which can be recuces
 to zero by addition of malonic acid, there are no  known  interferences  to   r.-.e
 determination of ozone by this*GD-FlA procedure using the indigo method.

    The  primary  advantages  of  the  CD-FIA  procedure   are   its   accuracv,
 selectivity,  lack  of  interferences, reproducibility,  and rapidity.  Thus,  ;-e
 method is well suited  for  laboratory  research  studies  and  for  use  as  an
 automated analytical procedure.

    More studies should be  conducted  with  specific  gas-perseable  membranes.
 particularly  with respect  to repeated and/or continuous exposure to ozone solu-
 tions.  The use of FIA equipment in a process control environment also  nust  be
 evaluated.   The GD-FIA indigo procedure might well be adopted as the analytical
 method of choice.

 o-Tolidine

    The o-tolidine method (addition of  1-2  drops  of  o-tolidine  solution  to
 ozone-containing  water  to develop the yellow color) is very sirole. and easily
 adapted to field color comparators, suitable for unskilled  analysts.   However.
 this advantage cannot compensate for the lack of quantitation of the zechod, r.or
 for  the  carcinogenicity of the reagent (o>tolidine).  The recocaencation is to
abandon this method.

Carmine Indigo.

    The carmine indigo procedure has been used in Canadian  water  wortcs  plar.ts
for  the  past 15 years.   The ozone containing water  is titrated with a solution
of carmine indigo until a faint blue color persists indicating that all  of  the
ozone  has  been destroyed.  Specific interferences are unknown, but ar.v oxidar.t
 capable of decolorizing the carmine indigo dye most likely will interfere.

    Effects of interferents should be determined, as  should precision,  accuracv,
 and effects of reagenc scorage and pH.  The method should be studied  in  direct
comparison  with  other  methods,  such as the indigo and UV absorption methods.
Automation of this method could lead to improved selectivity for ozone.

Aoperoaetry.

    With bare electrode amperemeters, either the solution or  the  electrode   is
 rotated  to  establish a diffusion layer, and the electrical current measured  is
 directly proportional to Che concentration of dissolved oxidant   (25).   Commer-
 cial  amperomecric  analyzers  give  satisfactory  results  provided  there is no
 oxidant other than ozone present in the sample.  In many  situations  they provide
 adequate monitoring of total  oxidant.   The  bare  electrode   system   has  good
 sensitivity,  and  is applicable as a continuous nonselective monitor  for ozone.
 '-hen other oxidants such as chlorine, chlorine dioxide, bromine,  and  iodine  are
 present,  the  technique  has  difficulties.   The exact  nature  and  magnitude  of
 these interferences requires additional research.
                                       37

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    Due  co  "he accumulation of surface impurities at che electrode surfaces,  all
bare amperometric eleccrode systems are subject to Loss of sensitivity vith use.
With uncovered electrode surfaces, fouling has been observed to be a significant:
problem  as  was the case in earlier tests with oxygen electrodes.   Additionally.
the  response  is influenced by numerous surface-active agents and also halogens
and oxygen.

    An improvement in the development of araperometric methods for ozone analysis
has been the application of gas-permeable membranes for  increasing  selectivity
and  preventing  electrode  fouling  (26-27).   These Teflon membrane electrodes
exhibit  less than 2% interference (in terms of current response)  from  bromine,
hypobroraous acid, chlorine dioxide, hydrogen peroxide, nitrogen trichloride, ana
hypochlorous acid (26-27).

    This type of araperomecric membrane sensor  needs  to  be  developed  further
based  on   the  exhibited  selectivicies.   The most disturbing attribute  is tr.e
temperature dependence.  If different membranes could maintain  selectivity vnila
minimizing  the temperature effect, this  type  of  sensor  could  become  higr.ly
recommended.

    The  application of positive voltage potentials and the use  of polymeric =en-
branes that are selectively permeable to gases has enhanced  the opportunity  far
selective   measurement  of  ozone.   This is a very significant improvement over
bare aaperooetric electrodes as well as  most  older  colorimetric/spectrophoto-
metric  and  titriaetric methods.  With an applied voltage of +0.6  V  (vs SCE) at
the  cathode,  only  the  most  -powerful  oxidizing  agents  can  overcome   the
"resistance" of this anodic voltage and cause electron flow  cathodicai.lv thrcuer.
the  electrochemical  circuit.  This general approach should continue  to se -sec
in future electrochemical developments.

Other Electrochemical Methods.

    In the differential pulse  polarography  procedure  (DPP),  a   predeterrv.r.ad
amount  of  phenylarsine  oxide (PAO) is added in excess to  an ozone solution -a
reduce the  levels of dissolved ozone  present.   Excess  PAO  Chen  is  measured
quantitatively   by   pulse   polarography.   The  DPP  method  may  under  scr.e
circumstances be useful in the research laboratory.  The prospeccs  of  its use in
the plant or field-are not as promising since a higher degree of operator  stciil
is required.

    Potentiometry involves the  cathodic  reduction  of  dissolved  ozone.    The
diffusion-limiting  current  measured  is  proportional  to  che concentration of
ozone in the water.  Further evaluation of  potentiometric   systems  r.ay  be  in
order.     However,  the  fundamental  problems  of  electrode   fouling  must  be
addressed.   Perhaps a combination  of  membranes  and  potentiometric  detection
would  produce  a promising system for ozone determinations.  The system appears
to have modest potential for development.

Ultraviolet Measurements.

    Ultraviolet absorption measurements also can be used  for   residual  aqueous
ozone   at  258-260  nra.   There  is  uncertainty  with  respect  to   the  -olar
absorptivity for aqueous ozone.   In che literature, values ranging  frora 2?CO  :D
                                       38

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3600 M"'ca"1 are reported.  This ur.cercai.ncy in che molar aosorpriviry ;s
critical  co  che  future  use and calibration uses of che UV aecnods.  Clear 1-
further work co verify this value is strongly recommended.

    If che solar absorptivity for ozone is known unarabigiously,  'JV absorption
in principle an absolute method for che determination of  ozone,  which  is  r.<
dependent  upon calibration or standardisation against other analytical mec.-.cc:
Therefore, it can be used for calibration of other analytical methods for ocor.i
It is specific to che determination of ozone, and is applicable  to  =easure?.ei
in gaseous and aqueous phases.

Physical Methods.

    The  calorimetric  aethod  is  based  on  the  enthalpy  of  the   cacalvz
decomposition  of  ozone (AH  - 144.41 KJ/mole).  The calorimetric deterair.aci
of  ozone  is  calibration-independent.   The  technique  is  specific   to   c
determination  of  molecular ozone, but is applicable to measurement  only  in c
gas phase.  However, the higher che concencracion of ozone in che gas phase, z
more accurate the method appears to be, since a greater  temperature  cifferer.
is observed.  Potential interferents have not been reported.

    The method has been shown to agree with  iodometric and  UV  absorption  pr
cedures.  particularly  for  the measurement of ozone in  the gases exiting 0=3
generacors.  Therefore, che procedure can  be  used  co  monicor  applied   ozo
dosages.   Additional  decailed  incerlaboratory  comparisons need co oe cam
out.

    The isochernal differencial pressure procedure' is based on  che generation
an increased nuaber of gas molecules during  the  UV  destruction  of  osor.e
constant  temperature.   '-"hen  this  reaccion   is  carried out  isocherrallv :r.
closed vessel, che increase in pressure of the concained  gas is proport.3r.al
che  ozone  concencracion.   In  principle,  chis  procedure  achieves  a rocal
physical ozone  measurement  without  requiring  calibracion  using   a   chesuc,
method.   Various  automated  instrumental   checks  such  as  che  scored   sol,
absorptivity,  che  age  of  che  UV  light  source,  che  zero  poinc   readir.;
aeasuremenc of che flow of che cesc gas and  che flushing gas, and che reading c
che diagnostic display are possible.

    No specific comparisons are reported.  However, in principle it appears  ch,
chis physical method is the best candidate for calibrating che  gas  phase   ozor
instruments  currently being used for ozonation control.  As long as  pure  oxygi
is used for ozone generation this method would  be  free  of  interferences  a:
would  be  subject  only  to strict temperature control of the  measurement:  eel?
Furcher study of chis system would be necessary before it could be   recomnier.st
for further consideration.
General Summary and Recommendations  for Ozone.


    In comparing all  che methods  co  che "Ideal  Method" we  find   chac   rone  co-
close  co  our  ideal  scandard.  Concinued development  of che  various  selecciv
mechods will, however, come closer and closer  co  che  ideal.
                                       39

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    In terns  of  gas  phase  measurements, none  of   the  existing  r.ethods  can  be
recommended   for  accurace  determinations of ozone.  If a relative value of tr.e
ozone concentration  is  needed  for control purposes, aost of  the aethocs reported
could be applicable.

    The accurace determination of ozone in the aqueous  phase  is   corr.olicatea  ;v
the decomposition of ozone,  its  reactivity to the  other species present, ar.d tr.e
by-produces   of   the ozonation  reactions.   Most  current methods  were  developed
without a clear  knowledge  of the associated ozone  chemistry.  Therefor: aost  of
the  methods   are unacceptable  or  cannoc   be   recoesended.   In  particular, -o
io dome trie based chemistry is  acceptable for  the  determination  of  aqueous ozc-r.e.
Indigo trisulfonace  and arsenic(III) direct oxidation   are   acceptable  -etr.ccs.
Aaperometery  continues  co  improve •- especially as an automated control zet.-.oa.

    The stripping techniques  have  some  merit   in  terms   of   improved   o::r.e
selectivity.   However,  automated  chemical  systems   such   as   flow   ir.jectisn
analysis offer considerably more promise.  The current  GD-rlA  ir.sigo   prscec-re
is superior for  residual ozone measurements due to its  selectivity for  ozone.

    The most  important  aspect  of any potential new or improved  ozone   sr.alvtical
method  will   be  speed of analysis and selectivity of the  aetect-.on  svstea  for
only ozone.   As  a point of comparison, we strongly recommend that ail  future  ar.a
existing methods be  compared against the 'Ideal Method".
LITERATURE
 1.     Symons, J.M.;  et  al   "Ozone,  Chlorine  Dioxide  and Chloraair.es  is
             Alternatives  to  Chlorine  for  Disinfection  of  Drinking  Vacer"   .n
             Water   Chlorination:   Environmental Irrpaet and Health  Effects , v ?". .
             2., Jolley, R.L.;  Gorchev,  H.  and  Hamilton,  D.H.,  Jr.,  Editors,  vAr.n
             Arbor,.  MI: Ann Arbor  Science  Publishers,  Inc.,  1979)    pp.   535-560
             and  Complete Report  entitled "State of the Art ..."  (Cincinnati.
             OH: U.S.  EPA, November,  1977),  84 pp.

 2.     Proceedings  of Seminar on  "The Design  and Operation of Drinking '."ater
             Facilities Using Ozone or Chlorine Dioxide",  Rice.   R.C.,   Editor,
             (Dedhaa,  MA:  New England Water Works Assoc., 1979).

 3.     Miller. C.tf, ;  Rice, R.C. ;  Robson,  C.M.; Scullin,  R.L. ;  Kuhn. '-. and
             Uolf,   H.,    "An  Assessment   of    Ozone    and   Chlorine   Dioxide
             Technologies  for  Treatment   of   Municipal  Water  Supplies". '.'  S.
             Environmental Protection Agency,   EPA  Project  Report,  EPA-600/2-
             78/018.  1978, 571 pp.

 4.     Miltner, R.J.   "Measurement of Chlorine Dioxide and Related Products',
             in Proceedings   of  The   'Jarer Quality  Teehr.olee;gal   '".'-fe!••-?•;.
             (Denver,  CO:  American Water Works ASSOC.. 1976).  pp.  1-il.

-------
 5.     Gordon. C.  "Improved Methods of Analysis  for  Chlorate, Chlorite,
             and Hypochlorite Ions at the Sub-rag/L  Level",  U.S.   Environmental
             Protection Agency,  EPA Technical Report.  EPA-600/4-85/079, October.
             1985, 35 p. and Presented at AWWA WQTC,  in ?roe.  AVTJA  Vater Quali-v
             Technology Conference. December. Nashville,  IN,  1982.  pp.  175-139.

 6.     Aieta,  E.M.;  Roberts. P.V.  "Chlorine Dioxide  Chemistry:  Generation
             and Residual  Analysis"  in  Chemistry  in  Vater  Reuse.  Vo^.   ^,
             Cooper,   W.J., Editor (Ann Arbor, MI: Ann Arsor  Science Publishers,
             Inc., 1981). pp. 429-452.

 7.     Hoigne. J.; Bader, H. "Sestimmung von Ozon und Chlordioxid  in Vasser
             mit der  Indigo-Methode"  ("Determination  of Ozone  and Chlorine
             Dioxide  in  Water With the Indigo Method"),  Voo Uasser,  1980.  H,
             261-280.

 8.     Gilbert, E. ;  Hoigne, J.   "Messung von Ozon in Wasserwerken; Vergleich
             der DPD- und Indigo-Methode" ("Ozone  Measurement in Water Treatser.t
             Plants:   Comparison  of  the  DPD  and   Indigo    Methods"),    GFV-
             Wasser/Abwasser, 1983. 124. 527-531.

 9.     Schalekaap, M.  "European Alternatives and Experience" in Proceedings
             of  the  National  (Canadian)  Conference  on  Critical  Issues  in
             Drinking   Vater  Qualify. (Ottawa, Ontario, Canada:  federation of
             Associations on Canadian Environment, 1984), pp.  140-159.

10.     Ikeda.  V.; Tang. T-F.;  Gordon, G.  "lodometric Method of Determination
             of Trace Chlorate Ion", Anal. Chem..  1984, i£. 71-73.

11.     Ernnenegger F. ; Gordon,  G.   "The Rapid Interaction between Sodiua
             Chlorite and Dissolved Chlorine", Inorg.  Chem.,  1967,  6, 633-635.

12.     Aieta.  E.M.;  Berg, J.D.   "A Review of Chlorine Dioxide in Drinking
             Water Treatment",  J.  Am. Water Works Assoc.. 1986, 7$, 62-72.

13.     Standard Methods for The Examination of Water and tfastevacer. 16th
             Editioc. Creenberg, A.E.; Trussell. R.R.; Clesceri, L.S.;   Franson,
             M.A.H.,   Editors (Washington, D.C.:  American Public Health ASSOC.,
             1985), 1268 pp. and 15th Edition. Greenberg, A.E.;  Connors.   J.J.;
             Jenkins,  D.;  Franson.  M.A.H.. Editors (Washington,  DC:   American
             Public Health Assoc., 1980), 1134 pp.

14.     Whittle, G.P.: Lapteff. A.. Jr.  "New Analytical Techniques for the
             Study  of  Water  Disinfection"  in  ghe,mistrv  of  Water   Supply.
             Treatment,  and  Distribution.  Rubin, A.J.. Editor, (Ann Arbor,  MI:
             Ann Arbor Sci. Pub.,   Inc..  1974), pp. 63-88.

15.     Tomiyasu, H.; Fukutorai, H.; Cordon,  G.  "Kinetics and Mechanism of
             Ozone Decomposition  in Basic Aqueous Solution".  Inorg. Chem., 1985,
             24, 2962-2966.
                                      41

-------
16.     Grunwell, J.; Senga, J.; Cohen, H., Cordon, G. "A Derailed Comparison
             of Analytical Methods for Residual Ozone Measurement",   Ozone  Sci.
             Eng.,  1983. I, 203-223.

17.     Flanm. D.L.; Anderson. S.A.  "lodace Formation and Decomposition in
             lodometric Analysis of Ozone",  Environ. Sex.  Technol.,  1975,   3..
          •   660-663.

18.     Rehme. K.A.; Purak, J.C.; Beard. M.E.; Smith. C.F.; ?aur, R.J.
             "Evaluation of Ozone Calibration  Procedures",  U.S.  E?.viror-T.er.:al
             Protection   Agency,   EPA    Project   Summary,  EPA-600/S4-80-C30.
             February, 1980, 277 pp.

19.     Liebennann, J.. Jr.; Roscher, tf.M.; Meier, E.P.; Cooper. W.J. Develop-
             ment of the FACTS Procedure for  Combined  Forms  of  Chlorine  ar.d
             Ozone  in  Aqueous  Solutions".  Environ.  Sci. Technol., 1980.  1^,
             1395-1400.

20.     Palin. A.T.; Derreumaux, A.  "Determination de 1'Ozone Residuel dar.s
             1'eau" ("Determination of  Ozone  Residual   in  Water"),  L'Zau  e:
             1'lndustrie. 1977, 12, 57-60.


21.     Sader, H.; Hoigne, J.  "Colorimetric Method  for the Measurement
             of Aqueous Ozone Based on the Decolorization of Indigo
             Derivatives", in Ozenization  y.ar.ual  for  Water and '-'asrevarer
             Treatment. Masschelein. W.J..  Editor, (Sew York. N"Y:  Jonn
             Wiley & Sons. 1982). pp. 169-172.

22.     Sader. H.; Hoigne. J.  "Determination of  Ozone  in Water  by the
             Indigo Method", Water Research 1981.  15_. 449-456.

23.     Bader, H.; Hoigne, J.  "Determination of  Ozone  in Water  by rhe  Indigo
             Method; A Submitted Standard   Method",   Ozone:  Science  and  Er.g ,
             1982. 4, 169-176.

24.     Scraka, M.R.; Cordon, G.; Pacey, G.E.  "Residual  Aqueous  Ozone  Deter-
             mination by Gas Diffusion Flow Injection Analysis",  Anal.   Chen.,
             1985, H, 1799-1803.

25.     Masschelein, W.J.  "Continuous Amperometric  Residual Ozone Analysis
             in the Tailfer (Brussels, Belgium) Plant",   in  Ozonyzation   "arual
             for Water and Wastewater Treatment.  Masschelein. W.J.,  Editor,  (.v.'ew
             York, NY:  John Uiley & Sons,  1982).  pp. 187-188.

26.     Stanley, J.H.; Johnson, J.D.  "Amperometric  Membrane Electrode  for
             Measurement of Ozone in Water". Anal. Chem. .  1979.  5_1,  2144-2147.

27.     Stanley, J.W.; Johnson, J.D.  "Analysis of Ozone  in Aqueous  Solution",
             in Handbook of Ozone Technology and   Applications.   Vol.  1,  Rice,
             R.C.  and Netzer, A., Editors (Ann Arbor, MI:  Ann  Arbor Sci. Pub.,
             Inc., 1982), pp. 255-276.
                                      42

-------
A GUIDE FOR EFFICIENT USE OF THIS REPORT (AND A BRIEF GLOSSARY OF TERMS)


    This Report  contains a very detailed review  of  all  disinfectant  residual
aeasuremenc mtchods.  The Executive Summary is intended to give readers  a brie:
overview of the  advantages and disadvantages of each method.  To that end, Table
I (Characteristics  and Comparisons of Analytical Methods) has been  included  :o
summarize   each   of our findings and to recommend possible directions for future
research.    In   addition,  Table  II   (Equivalent   Weights   for   Calculating
Concentracions on the Basis of Mass) describes the equivalent weights of each of
che  disinfection  species  in  terms  of  the  actual reactions involved in :.-.e
disinfection process.

    Each chapter contains individual recommendation* following the discussion of
the method.  A summary of all of the recommendations is also given at rhe end of
each chapter.  Additional help is  given  by  means  of  an  alphabetical  Ir.cex
containing   more than 2500 individual terms.  Specific cross referencing for ail
recoanendations  can be found in the Index either under the "recommendation", or,
in terms of the  subject of the numbered recommendation itself.

    The  term Referee Method is used to  describe  appropriate  comparisons  with
existing  methods   and  Standard  Methods  refers  to a specifically recocsenced
method.  The Index  should be  an  additional  aid  to  finding  rhe  details  of
specific methods.

    In this  context,  it should be noted that the individual literature ciratior.s
are specific to  each  individual chapter -- and are either numbered   individuallv
within chapters  2 and 3, or alphabetically sequenced within chapters -* ar.c  :

    Chapter  4 (Indexed Reference Citations) has been included in this report  :-
order  to   assist   readers  in  locating  particular papers of interest.  The -5
categories  for chlorine, chloramines, and the oxy-chlorine species,  along  vim
the  additional   60 categories  for  ozone, should make the task of finding in-
dividual papers  of  interest considerably less cumbersome.  Papers which describe
several  methods  have  been included in each of the appropriate  categories.   All
together,   the   1.400  references  cited  in Chapters 1*3 number more than 2.CCO
individual  citation* when distributed in the indexed form of Chapter 4.

    Chapter S is an alphabetical listing of the individual  references citations.
finally, a  detailed Index has been  included  in  order  to  assist  readers  in
locating subjects   of  specific  interest.  We hope the readers will find  these
additional  chapters as useful as have we in preparing this  reporc.

    A brief Glossary follows on the next page in order  to assist readers  in  :i-.e
various  specialized terms and abbreviations used in  this reporc.  For additional
terms,  the  reader is referred to the  Index.

-------
GLOSSARY

    Accuracy -- the ability co determine the correct concentration

    3AKI •• boric acid buffered potassium iodide method for ozone

    Breakpoint •• the inorganic reaction of chlorine with asaonia r.irrijen

    CDFV -• chlorine demand free water

    Combined Chlorine •- inorganic and organic chloraaines

    Detection Limit •- a signal that is 3 times the noise level of the system

    DOC •- dissolved organic carbon

    DPD -- (N.N-diethyl-p-phenylenediamine)

    FACTS •- free available chlorine tesc with syrir.galdazine

    FIA •- flow injection analysis, an automated analysis procedure

    Free Chlorine -- the species,  C17 +• HOC1 •«• OC1"

    KI  ••  potassium iodide method for ozone

    LCV -- leuco crystal violet

    aL  --  ailliliter(s).  standard unit of volume

    Molar  Absorptivity (O reported in units of M~'cm"1

    N5KI -- neutral buffered potassiua iodide method for ozone

    Precision -- how wall the method reproducibly measures the sane
                 concentration

    Reactive Intelnaediate -• species such as 02~, HO.," , H02,  OH, 03~,  etc.

    Referee Method •-  the method aqainsc which a working method is compared

    Sensitivity -- th« change in signal per unit concentration  [i.e. Aaps/taol]

    Standard Methods -•  the  book,  Standard  Methods  for  the  Exar!i-3tion._
                 tfater_.and Uastewater published by APHA. AW"»A, and U'PCF

    THM's  -- trih*lom«thanes

    Total Chlorine -- Che combination of Free Chlorine and Combined Chlorine

    TOC •- total organic carbon

    TOX •- total organic halogen

-------

-------
       APPENDIX E

 INACTIVATIONS ACHIEVED
BY VARIOUS DISINFECTANTS

-------
             z

             M
               u
—  3 iT 9
a  z * Q
a  — » ~*
•J  * £ a

<2feS
   2 > *<
   3 ^. O
                     O

           =  1
           o. — w>

              r
                          i/^

                        • CM
                     vO  «

                     M
HLORI

CONCENTRATION

<-R/L)
S
§
                                     OO
                                           « — (nvo«o —
                                           S — — — — (N
                                   SfM^r~
                                   — — —
                      »  J 5 S  5 8
                                P  P P

                                II

                                V

                                                        (StMCSCN
     CM

9 I o




4i3
     o
   S"
2|5
CRINE

CONCENTRAT


(«*/D
                                                                                   SSh  ^^
                                                                                   MK
                                                                                — «CMCMCM«MCMfMNtM^{MCMO ^*  ^» to ^  ^ P  p
           CMOt«M(S«Me>if«){M
-------
           a
           z
         z *
         2 S
- * M ^
SSS*
  UJ CJ
  Zj <
  > °
  i- <
  o 3
                 !o
               m a <^
               r- .2
               - I
               •s.^
                 I-
               41
                 S
                 .
               = 1
               ^. - *>
                 - 9
                 > N
                — "^
                1"
                  o
HLORINE
CONCENTRAT
(,nR/L)
                                            M «M (S
                                        — m >e •

                             o. — min«o
§
                       oeo — r»>nf^«eOfs''^'nf~9»~
                       r-««o«o«e«e«8*»<>o\a*o
                       CM R R~-r5 S
                       OOO   —
                                ^«» > '
                                           n
                                           *m "^ *^
                                           '1-
da
                                                   1
                                           sia
                                            l
CHLORINE
CONCENTRATIO
(«"J!/U
                                                           O*Ownmo«o>O — n » in
                                                          tStS«NtSJMtS(NP4
                                                          — »>o«!«Ncs«
-------
   UJ
   Z

Z *

2 S

< 0
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SI
z >
U (j

_; <


> S
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            .


            1
            — «•>


            I"

         il
            I
=  1
a. —  <«

   5"
               PM

E
RATION
HLORI


CONCEN


(niR/L)
S                        — «vn>«r»o\ —
                                                        O>  —
                                   ?3 S N r>i  01  «M
               RO —  —  M  «
               ft m  ^  f*l  ^i




            m >n wi  >e  >o  t^irt
r%rtrtft*^r^r»*^r
                                                                                  w  e*  «s  es ts ts ts
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Si
                                                                                                                  I

                                                                                                                  z

-------
  aj
  z
z i
;;
>|
^ UB
Z >
2 <
< 5
^ *v
o 3
  o
pH=7.5
Log IfUKlivatiun
1.5 2.0
         i°
         s <•*
      is.  *>
         >
      1  1
          o
         • f<
      iris
p
Log In
0 1.5
CHLORINE
CONCENTRATION
(mR/L)
               *«rt/iiAvt«^r<»«««oe>


               OiWRtSNtMCMPXCSSMpSfMN

               O O O — — — — — (N(MP*{SeS
               O O O   —
               II
               V
                           — •-   «srxes«M
                                            5 -
                                                -
                                              I
U
.0
pH
Log laa
I.S
E
  I
  et
i^
ae a
3^
S8
                                                    in«'«««*r~r»r»r-i--r-
                                                            es w (S
                                                                         {S (N (N CM
                                                    6d6
                                                    II
                                                    V
                                                          •»CM«r^f*CM(S«>0**
,2
t
ii
                                                                                 3

-------
    LU
    Z
ll
M
M
U  ae
<  u.
z  >
~  a
O  52
"•  K
s§
<  a
>  at
i_  <
 e. — ir>
    I"

2 IS
iJ.
i
25
=
iv
2.0
pll<=6
Log liwctivation
.5
CRINE
CONCENTRATION
(raR/L)
                        ~£i'*9n'$P~ii9&O'~mt*
                        mmfnmm«>t<)(mnKK9«<*
              m»»i«»n«SR?5»o>«r-r-r^«««o*o>.
                                    »«»»»»  O
                 Sp*mfn«»in«r»f"-«o«
                 ««nfnr>i*ienM«^«^««t
             ni»»m»»>«o^r-r«r»p-r-(^r-r-«»«««««»
             O  O  O     —  •—  — —     WCMfSN
              II
              V
9.0
vatiooi
2.0 2.5
Log
5
vrti
2.0
pH
Log liM
I.S
vatKMM
2.0 2.S 3.0
Log
   I
.1
   UJ  ^
j 8  1
                                                                         win^r*te
                                                                         fnr^n«»v5r<»^'»*fr«rv^
                                                                        csrtm^««minin««
-------
TABLE E 6
CT VALUES 1 OR INACTIVATION
Or GIARDIA CYSTS BY FREE CHLORINE
AT 25 C (I)

9
i o
>/•> 1 is
5 2
» ~ VI
*fi M
i/i
d
e
M
• X O
9 a N
i- .5
U,
r
0
o
p
1/1
•» is
*•> 1 °
III
0
W1
O
p
l\"
'i-
P
vr
O
CHLORINE
CONCENTRATION
(•"R'M





";;^^»r.!!"
„„„„„„„,,.,«„„


•a»aBa«saB»»»«









O O O •.-.-.— is is is is
II
V

p
«^
m
(S
H
p | 9
p
d
pit =8 5
Log liMctivalioni
05 1.0 15 20 25 30
p
• (S
iK
sl
6
ErilLORINE
XJNCENTRATION
mB/L)





9 R R S A ft S S 3 S S S S 5




OOO —••••-•«• tscsr-ip*
II
V
N.rtc*
(1) CT = CT for 3 log iiwciivation
?;

-------
                                   TABLE E-7

                                 CT VALUES FOR
                   INACTIVATIQN OF  VIRUSES  BY FREE CHLQRINE(1)
Loa Inactivation


Temperature (C)
0.5
5
10
15
20
25
2.0
pH
^
6
4
3
2
1
1


14
45
30
22
15
11
7
3.0
oH
fiz*
9
6
4
3
2
1


14
66
44
33
22
16
11
4.0
DH
6=2
12
8
6
4
3
2


14
90
60
45
30
22
15
Notes:
     1.   Basis for values given  in Appendix  F.

-------
                                   TABLE E-8

                                 CT VALUES FOR
                         INACTIVATION OF GIARDIA CYSTS
                             BY CHLORINE DIOXIDEU)
Temoerature (C^
Inactivation
0.5-log
1-log
1.5-log
2-1og
2.5-log
3-log

-------
Notes:
                                   TABLE E-9

                                 CT VALUES FOR
                            INACTIVATION OF VIRUSES
                           BY CHLORINE DIOXIDE oH 6-9("
Temoerature (C)
Removal
2-log
3-log
4-log
£•1 5_ ifl
8.4 5.6 4.2
25.6 17.1 12.8
50.1 33.4 25.1
15
2.8
8.6
16.7
22
2.1
6.4
12.5
25
1.4
4.3
8.4
      1.    Basis for values given  in Appendix F.

-------
                                   TABLE E-10

                                 CT VALUES FOR
                          INACTIVATION OF GIARDIA CYSTS
                                   BY  QZQNE(1)
Temoerature 1C]
Inactivation <»1
0.5-log
1-log
1.5-log
2-log
2.5-log
3-log
0.48
0.97
1.5
1.9
2.4
2.9
-5.
0.32
0.63
0.95
1.3
1.6
1.9
UL
0.23
0.48
0.72
0.95
1.2
1.43
Ifi.
0.16
0.32
0.48
0.63
0.79
0.95
2Q_
0.12
0.24
0.36
0.48
0.60
0.72
25_
0.08
0.16
0.24
0.32
0.40
0.48
Note;

     1.   Basis for values given  in Appendix  F.

-------
            TABLE E-ll

          CT VALUES FOR
INACTIVATION OF VIRUSES BY OZONE
(i)
Temperature (C)
Inactivation <=1 5 }Q 15
2-log 0.9 0.6 0.5 0.3
3-log 1.4 0.9 0.8 0.5
4-1og 1.8 1.2 1.0 0.6
Note;
1. Basis for values given in Appendix F.
2P_ £5_
0.25 0.15
0.4 0.25
0.5 0.3



-------
         TABLE E-12

        CT  VALUES  FOR
INACTIVATION  OF  GIARDIA CYSTS
   BY CHLORAMINE DH 6-9(1)
Temoerature (C]
Inactivation <*1 5 10
0.5-log
1-log
1.5-log
2-log
2.5-log
3-1og
Note;
1.
635
1,270
1,900
2,535
3,170
3,800

Basis for
365
735
1,100
1,470
1,830
2,200

values giver
310
615
930
1,230
1,540
1,850

i in Appendix F.
15
250
500
750
1,000
1,250
1,500


20
185
370
550
735
915
1,100


25
125
250
375
500
625
750



-------
                                   TABLE  E-13

                                 CT VALUES  FOR
                    INACTIVATION OF VIRUSES BY CHLORAMINE
O)
Temoerature (C)
Inactivation 
-------
                               TABLE  E-14

                             CT VALUES  FOR
                    INACTIVATIQN OF VIRUSES BY UV(1)
                 	Log  Inactivation	
                   2.0                            3.0

                    21                            36
Note:

     1.    Basis for values given  in  Appendix  F,

-------
     APPENDIX  F
BASIS FOR CT VALUES

-------
                               APPENDIX F
                           BASIS OF CT VALUES

F.I    Inactivation of Giardia Cvsts

       F.I.I  Free Chlorine
       The CT values for free chlorine in Tables E-l through E-6 are based
on a statistical analysis  (Clark et al., 1988;  attached to this appendix),
which considered both animal  infectivity studies (Hibler  et al., 1987) and
excystation studies  (Jarroll  et  al., 1981; Rice et al.,  1982;  Rubin et
al.,  1988).   A multiplicative model was selected to best  represent the
chemical  reactions  during  the inactivation  process.    This model  was
applied to each  of the  data  sets,  listed  above,  and  in  various  combina-
tions.   The  animal   infectivity data were included in  all  combinations
studied".   The animal  infectivity  data  was  considered essential  for
inclusion in all the  analysis  of  combined  data sets  because it  included
many more data points than the other data sets, all  of which represented
inactivation levels  at  99.99 percent.  Because  of  limitations  with the
excystation methodology,  only  data  for achieving less  than  99.9 percent
inactivation was available from such studies.
      Statistical analysis supported the choice of combining  the Hibler et
al. and the Jarroll  et al. data (and excluding the Rice  et al. (1981) and
Rubin et al. (1987) data),  to  form the best  fit  model  for predicting CT
values for different  levels of inactivation.  As a conservative regulatory
strategy, Clark and Regli (1990) (attached at the end of thsi appendix),
recommended  that CT  values  for  different   levels  of   inactivation  be
determined by  applying  first  order  kinetics to the  99 percent  upper
confidence interval  of the CT99 99  values  predicted by the model.
      The model was applied using the above strategy as a safety factor,
to determine the CT values ranging from 0.5-log to 3-log inactivation at
0.5 and 5 C.  CT values for temperatures above 5 C were estimated assuming
a twofold decrease for  every 10 C.   CT values for temperatures  at 0.5 C
were estimated  assuming a 1.5  times  increase  to  CT  values at 5  C.   This
general principle is  supported by  Hoff (1986).   It  is  important to note
that  the CT  values   for  free chlorine  are  sensitive  to  the  residual
                                   F-l

-------
concentration, C.  For example, at a pH  of  7 and a temperature of 10 C,  a
3-log Giardia cyst inactivation results from a CT of 107 mg/L-min  with  a
free residual of 0.6 g/L and a CT  of 124 mg/L-min with a free residual of
2.0 mg/L.
      Application of  the  model to pHs above 8, up  to  9, was  considered
reasonable because the model is substantially sensitive to  pH  (e.g.,  CTs
at pH 9 are over three times greater than CTs at pH 6 and over two times
greater than CTs at pH 7).   At a  pH of  9,  approximately four  percent of
the hypochlorous acid fraction of  free chlorine is still present.  Recent
data indicate that in terms  of HOC1  residuals  (versus total  free chlorine
residuals including HOC1  and OC1") the CT products required  for inactiva-
tion of Giardia muris and Giardia lamblia cysts decrease with  increasing
pH from 7 to 9 (Leahy et al.,  1987;  Rubin et al.,  1988b).  However, with
increasing  pH,  the  fraction of  free chlorine existing as  the  weaker
oxidant  species  (OCT)  increases.    In terms  of  total  free  chlorine
residuals (i.e.,  HOC1  and OCV)  the-CT products required for inactivation
of Giardia muris cysts  increase with increasing pH from 7  to 9 by less
than  a  factor   of  2  at  concentrations  of  less  than  5.0 mg/L  (see
Table F-l).   Also,  the significance  of  pH on the  value of CT products
achieving  99  percent  inactivation  appears  to decrease  with  decreasing
temperature and free chlorine concentration.   The relative effects of pH,
temperature, and chlorine concentration,  on inactivation of Giardia muris
cysts appears to be the  same  for Giardia  lamblia  cysts (Rubin et al.,
1988b), although not  as much data for Giardia lamblia cysts for high pH
and temperature values as for Giardia muris cysts is yet available.

      F.I.2  Ozone and Chlorine Dioxide
      The  CT  values  for  ozone in Table E-10 are  based on disinfection
studies    using   in    vitro   excystation    of    Giardia   lamblia
(Wickramanayake, G. B., et  al.,  1985).   CT99  values at 5 C and pH 7 for
ozone ranged from 0.46 to 0.64  (disinfectant  concentrations ranging from
0.11 to  0.48 mg/L).    No  CT values  were available for other pHs.   The
highest CT99  value, 0.64,  was used as a  basis  for extrapolation  to obtain
the CT values at 5 C,  assuming first order  kinetics  and applying a  safety
factor of  2,  e.g.,  (0.64 X  3/2 X 2  = 1.9).   CT values for temperatures
                                   F-2

-------
7


8


9
                                      TABLE  F-l

                           CT VALUES  TO ACHIEVE  99  PERCENT
                INACTIVATION OF GIARDIA HURIS CYSTS BY FREE CHLORINE
Temperature
1
15
1
15
1
15
(Source: Rubin,
0.2-0.5
500
200
510
440
310
et al., 1988b)
Concentration
0.5-1.0
760
290
820
220
1,100
420

1.0-2.0
1,460
360
1,580
1,300
620

2.0-5.C
1,200
290
1,300
320
2,200
760

-------
above 5 C were estimated assuming a twofold decrease for every 10 C.  CT
values  for  temperatures at  0.5  C were  estimated  assuming a  1.5  times
increase to CT values at 5 C.
      The  CT values  for  chlorine  dioxide  in  Table E-8  are based  on
disinfection  studies  using in  vitro excystation of  Giardia  muris CT99
values at pH 7 and 1 C,  5 C, 15 C and 25 C (Leahy, 1985 and Rubin, 1988b).
The average CT99  value at each temperature  (27.9 at 1 C, 11.8 at 5 C, 8.5
at 15 C, and 4.7 at 25 C) was  extrapolated  using first order kinetics and
multiplied by a safety  factor of 1.5 to obtain the CT99 9 values,  e.g.,
                  at  1 C, C999 «  27.9 x  1.5 x  1.5 » 63.
Because of the limited data available at pHs other than pH 7, the same CT
values are  specified  for  all  pHs.   Although  most  of the CT99 data were
determined at pH 7,  it is known that chlorine dioxide  is more effective at
pH 9.  Thus,  the  CT values  in the rule are more conservative  for higher
pHs than for  lower pHs.
      A lower safety factor is used for chlorine dioxide than  for ozone,
because the data  was  generated using Giardia  muris  cysts  which are more
resistant than Giardia  lamblia  cysts.   CT  values  at  other temperatures
were estimated, based on the  same rule of  thumb multipliers assumed for
ozone.
      A larger safety  factor was applied to the ozone and chlorine dioxide
data than to the chlorine data because:
      a.    Less data were available for ozone and chlorine dioxide than
            for chlorine;
      b.    Data available for ozone and chlorine dioxide, because of the
            limitations of  the excystation procedure,  only  reflected  up to
            or slightly beyond 99 percent  inactivation.   Data for chlo-
            rine, based on animal infectivity studies  rather than excysta-
            tion  procedures,  reflected  inactivation of  99.99 percent.
            Extrapolation of data to achieve  CT values for 99.9 percent
            inactivation with ozone and chlorine  dioxide, involved greater
            uncertainty than  the direct determination of  CT  values for
            99.9 percent inactivation using chlorine.
      c.    The CT values for ozone and chlorine dioxide to achieve 99.9
            percent inactivation are feasible to achieve;  and
      d.    Use of ozone and  chlorine  dioxide is  likely to occur within
            the  plant  rather than   in  the distribution  system  (versus
            chlorine  and chloramines which are  the likely disinfectants
                                   F-3

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            for  use  in  the  distribution  system).   Contact  time measure-
            ments within the plant will involve greater uncertainty than
            measurement of contact time in pipelines.

      EPA recognizes that the CT values for ozone and chlorine dioxide are
based  on limited  data.   Therefore,  EPA  encourages  the  generation  of
additional data in accordance with the protocols provided  in Appendix G to
determine conditions  other  than the specified  CT  values,  for providing
effective disinfection  at a particular system.

      F.I.3 Chloramines
                                               - >*
      The CT values for chloramines in Table E-12 are based on disinfec-
tion  studies  using  preformed  chloramines and  in vitro excystation  of
Giardia muris (Rubin,  1988).  Table F-2 summarizes  CT  values for achieving
99 percent inactivation of Giardia muris cysts.  The highest CT values for
achieving 99 percent inactivation at 1 C (2,500) and 5 C (1,430) were each
multiplied by 1.5  (i.e.,  first  order  kinetics were assumed)  to estimate
the CT99  9 values at 0.5 C and  5 C,  respectively, in Table E-12.   The CT99
value of 970 at  15 C  was  multiplied by 1.5 to estimate the CT99 9 value.
The highest CT99 value of 1,500 at  15  C and pH 6 was  not used because it
appeared anomalous to the other data.   Interesting to note is that among
the data in Table F-2 the CT  values  in the lower residual  concentration
range (<2 mg/L)  are higher than those in the higher  residual concentration
range (2-10 mg/L).   This is opposite to  the  relationship  between these
variables for free chlorine.  For chloramines,  residual concentration may
have greater influence  than contact time on  the inactivation of Giardia
cysts within the range of chloramine residual  concentrations practiced by
water utilities  (less than 10 mg/L).   No safety  factor was  applied  to
these data since chloramination, conducted  in the field, is  more effective
than using preformed chloramines.   Also,  Giardia muris appears to be more
resistant than Giardia  lamblia to chloramines  (Rubin,  1988b).
      The  protocol  in  Appendix G can  be used to demonstrate  if less
stringent  disinfection conditions than  those  cited  in Table  E-12  can
achieve  comparable levels of inactivation for specific system characteris-
tics.
                                   F-4

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                                   TABLE F-2

                           CT VALUES FOR 99 PERCENT
             INACTIVATION OF GIARDIA MURIS CYSTS BY MONOCHLORAMINE*
EH

6
8
(Source:
Temperature
(C)
15
5
.1
15
5
1
15
5
1
15
5
1
Rubin, 1988)
Monochloramine
<0_^
1,500
>1,500
>1 , 500
>970
>970
2,500
1,000
>1,000
>1,000
890
>890
>890
Concentration fmp/L)
2.0-10.0
880
>880
>880
970
1,400
>1,400
530
1,430
1,880
560
>560
>560
*CT values with ">" signs are extrapolated from the known data.

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F.2    Inactivation of Viruses

       F.2.1 Free Chlorine
       CT values for free chlorine are based on data by Sobsey (1988)  for
inactivation of Hepatitus A virus (HAV), Strain HM175, at pH 6,7,8,9 and
10,  chlorine concentrations of  0.5  to  0.2,  and  a  temperature of  5 C,  as
contained  in Table  F-3.   The highest CT value for the pH  range  6-9  for
achieving 2, 3, and 4-log inactivation  of HAV were multiplied by a safety
factor of  3  to obtain the CT values listed in Table  E-7.  (e.g.,  the  CT
value  for achieving  4-log  inactivation at pHs  6-9  was  determined  by
multiplying 2.55 X 3 = 7.6 = 8).  The CT values at  pH 10 were significant-
ly higher  than those  for  pHs  6-9  and are considered  separately.   The  CT
values in  Table  E-7  for  pH  10  also include a  safety factor of  3.   CT
values at temperatures other than  5  C were determined  assuming a two fold
decrease for every 10 C increase.   CT values for inactivating viruses  in
general are based on HAV data  since  they give higher CT values than those
for  inactivation of polio and rotaviruses under similar conditions of pH
and  temperature (Hoff, 1986).

       F.2.2 Chlorine Dioxide
       Data by Sobsey (1988)  for  inactivation of Hepatitus A virus, strain
HM 175, by a  chlorine  dioxide  concentration of 0.5 mg/1 at pH 6 and 5 C is
shown  in Table F-4.  The CT values in Table E-9 for pHs 6-9 and tempera-
ture = 5  C  were determined by  applying a safety  factor  of  2 to the average
CT values  presented  in  Table  F-4  at pH 6.   This  safety  factor is lower
than  that  used  to  determine CT  values for  chlorine because  chlorine
dioxide appears to be significantly  more effective  at  higher pHs and most
waters are assumed to have a  higher pH than 6.
       CT  values   at   temperatures  other than  5  C  in  Table  E-9  were
determined by  applying a  twofold  decrease for  every  10 C increase.   The
data  for  pH  9  was not  considered because  it is very limited  and other
viruses are more resistant to chlorine dioxide than Hepatitus A is at pH
9.   According to Hoff (1986)  at  a  pH of 9 and a temperature  of 21 C, a CT
of 0.35 provides a 4-log inactivation of poliovirus 1.  Applying the same
safety factor and rule of thumb multipliers to this data results in a CT
                                   F-5

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. of 2.8  for  a  4-log  virus  inactivation  at 0.58C,  in contrast to a CT of
 50.1 resulting from the Hepatitus A data  at pH 6.   Therefore,  in  order to
 assure  inactivation  of Hepatitus A,  the higher CT  values  are needed.
 Systems  with  high  pHs may  wish to  demonstrate  the  effectiveness of
 chlorine dioxide at lower CT values  based on  the  protocol  in  Appendix G.
 Chlorine dioxide  is  much  more effective for inactivating rotavirus and
 polio virus than it is for inactivating HAV (Hoff 1986).

       F.2.3 Chloramines
       The CT values in Table E-13 at 5 C were based  directly on data by
 Sobsey  (1988)  using preformed chloramines at  pH 8.   No  safety factor was
 applied to the  laboratory data since chloramination  in the  field, where
 some transient  presence  of  free chlorine  would  occur,  is assumed  more
 effective than preformed chloramines.
       HAV  is  less  resistant  to preformed chloramines  than are other
 viruses.  For  example,  CTs of 3,800-6,500 were needed for 2-log  inactiva-
 tion of simian  rotavirus  at  pH  » 8.0  and temperature « 5 C  (Berman and
 Hoff,  1984).   However, these  same  viruses are  very sensitive to  free
 chlorine.  CT  values  ranging from less  than 0.025  to 2.16 were required  to
 achieve 99  percent inactivation of rotavirus by free chlorine at pH =  6-10
 and temperature  « 4-5 C  (Hoff,  1986).   HAV  is  more resistant to  free
 chlorine than  are rotaviruses.
       The  CT  values  in  Table  E-13 apply  for  systems  using  combined
 chlorine where-chlorine  is added  prior  to  ammonia  in  the  treatment
 sequence.  This should provide sufficient  contact  with  free  chlorine  to
 assure  inactivation of rotaviruses.  CT  values Table E-13 should  not  be
 used for  estimating the  adequacy  of  disinfection in  systems  applying
 preformed chloramines or ammonia  ahead  of chlorine, since CT values based
 on HAV  inactivation  with  preformed  chloramines  may  not  be  adequate for
 destroying rotaviruses.  In  systems applying preformed chloraraines, it  is
 recommended that  inactivation  studies  as outlined  in  Appendix G  be
 performed  with  Bacteriophage MS2  as  the  indicator virus  to  determine
 sufficient CT values.   Also,  the protocol in Appendix G  can be used  by
 systems applying chlorine ahead of ammonia to demonstrate less stringent
 disinfection conditions than those indicated in Table E-13.
                                    F-6

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                   TABLE F-3

CT VALUES FOR INACTIVATION OF HEPATITUS A VIRUS
            BY FREE CHLORINE
(Source: Sobsey 1988)
LOG INACTIVATION DH
& z a a
2 1.18 0.70 1.00 1.25
3 1.75 1.07 1.51 1.9
4 2.33 U43 2.03 2.55


IP.
19.3
14.6
9.8

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                                 TABLE F-4
              CT VALUES FOR INACTIVATION OF HEPATITUS A VIRUS
                   BY CHLORINE DIOXIDE (SOBSEY 1988)
pH6
pH9

Experiment
No.
1
2
3
4
1
2
_£1Q,
' t
Concentration (ma/L^

Initial Average
0.49
0.50
0.51
0.51
0.5
0.5
0.32
0.33
0.36
0.37
0.5
0.5
Inactivation Time
           Log
      Inactivation
pH6
pH9
>2.5
>3.6
                       Experiment No.
            1

           12
           30
           55
       9
      29
      59
0.33  --
0.33  --
 3

 5
22
43
 7
20
39
Exoeriment
1
3
9
17
<0
<0
.8
.4
.17
.17
2
3
9
20
.0
.6
3
1
7
16
.8
.9
No
4
2
7
14

.6
.4
Average
  CT

  2.8
  8.6
 16.7

 <0.17
 <0.17
Note;
      1.   CT values were obtained by multiplying inactivation time  by  the average
           concentration shown above for each experiment.

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       F.2.4  Ozone
       No  laboratory  CT  values  based on inactivation of HAV virus are yet
 available for ozone.  Based on data from Roy (1982),  a mean CT value of
 0.2  achieved  2-log inactivation  of poliovirus 1 at 5 C and pH 7.2.  Much
 lower  CT  values  are  needed to achieve a 2-log inactivation of rotavirus
 (Vaughn,  1987).  No  CT values were available for achieving greater than a
 2-log  inactivation.   The  CT  values  in  Table E-ll for  achieving 2-log
 inactivation  at  5 C  were determined  by applying  a safety factor of 3 to
 the  data  from Roy (1982).   CT values  for  3 and  4-log inactivation were
 determined  by applying  first order kinetics and assuming the same safety
 factor of 3.   CT values  were adjusted for temperatures other than 5 C by
 applying  a twofold  decrease  for  every  10  C increase.   Based  on  the
 available data,   CT   values for ozone  disinfection   are  not  strongly
 dependent on pH.   Therefore, data obtained at pH =  7.2  is  assumed to apply
 for pHs in the range of 6.0 to 9.0.   However,  it should be noted that the
maintenance of an ozone  residual is affected by pH.

      F.2.5   Ultraviolet Light (UV)
      The CT values for  inactivation of viruses by UV are  based on studies
by Sobsey (1988)  on  inactivation of Hepatitis  A virus  (HAV) by UV.  These
data were used because HAV  has been established as an important cause of
waterborne  disease.   The  CT values were  derived by  applying  a safety
factor of 3 to the HAV inactivation data.  The CT values in Table E-14 are
higher than the CT values for  UV inactivation of poliovirus 1 and simian
rotavirus from previous  studies  (Chang et al., 1985).

      F.2.6   Potassium Permanganate
      Potassium  permanganate  is  a  commonly  used  oxidant  in  water
treatment.   Preliminary testing by  Yahya, et  al 1988,  indicates  that
potassium permanganate  may  contribute to virus inactivation.   The test
data included in  Table  F-5  indicates the  inactivation of bacteriophage
MS-2 using  potassium permanganate with  a pure  water-buffer  solution.
These data do not  include safety  factors.  It is likely that CT values for
actual  water treatment processes  will differ from these values.  This data
has only been provided here  as  an indication of the potential of potassium
                                   F-7

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                    TABLE F-5

         CT  VALUES  FOR  2-LOG  INACTIVATION
OF MS-2 BACTERIOPHAGE WITH POTASSIUM PERMANGANATE
KMn04
(mg/L)
0.5
1.5
2.0
5.0
Notes;
1.
2.
oH 6.0
27.4 a(1)
32.0 a
ND(I)
63.8 a

Letters indicate different experimental
Not determined.
pH 8.0
26.1 a
50.9 b
53.5 c
35.5 c
conditions.


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THE BASIS FOR GIARDIA C T  VALUES  IN THE  SURFACE WATER
      TREATMENT RULE:   INACTIVATION BY CHLORINE
                         by
              Robert  M.  Clark,  Director
          Drinking Water Research Division
        Risk Reduction  Engineering  Laboratory
                Cincinnati, OH 45268
                         and
                     Stig Regli
              Office of Drinking Water
        U.S. Environmental Protection Agency
                Washington, DC 20460
        RISK REDUCTION ENGINEERING LABORATORY
         OFFICE OF RESEARCH AND DEVELOPMENT
        U.S. ENVIRONMENTAL PROTECTION AGENCY
                CINCINNATI, OH 45268
                    February 1991

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             THE BASIS FOR GIARDIA C T VALUES  IN THE SURFACE WATER
                   TREATMENT RULE:   INACTIVAT10N BY CHLORINE

                                      by
                       Robert M. Clark,' and Stig  Reglib

                                 INTRODUCTION

     The 1986 amendments to the Safe Drinking Water Act (SDWA) require EPA to
promulgate primary drinking water regulations (a)  specifying criteria under
which filtration would be required, (b)  requiring  disinfection as a treatment
technique for all public water systems,  and (c) establishing maximum
contaminant levels (MCLs) or treatment requirements for control of Giardla
1amblia.  viruses, Leqionella. heterotrophic plate  count bacteria, and
turbidity.   EPA has promulaged treatment technique requirements to fulfill the
SDWA requirement for systems using surface waters  and ground waters under the
direct influence of surface water.1  Additional  regulations specifying
disinfection requirements for systems using ground water sources not under the
direct influence of surface water will  be proposed and promulgated at a later
date.  This paper presents a model that relates pH, temperature, chlorine
concentration, and inactivation level  to Giardia inactivation by free
chlorine.  Because Giardia lamblia is known to be  one of the most resistant
organisms to disinfection by chlorine found in water, much interest and effort
Director,  Drinking Water Research Division,  Risk Reduction Engineering
 Laboratory, 26 W. Martin Luther King Drive, Cincinnati, Ohio 45268
bUSEPA,  Office  of Drinking Water,  401 M Street,  S.W.,  Washington,  DC 20460

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has been devoted to determination of C't values  for  Giardia  lamblia.   The
model has been used to predict *C t"  values  that  have  been  included  as part  of
EPA's Surface Water Treatment Rule (SWTR).
BACKGROUND
     Under the SWTR all  community and non-community  public  water systems using
surface water, or ground water under the direct  influence of surface water,
are required to provide  minimum disinfection to  control  Giardia lamblia.
enteric viruses and bacteria.1   In addition,  unless  the  source  water is well
protected and meets certain water quality  criteria (total or fecal  coliforms
and turbidity limits), treatment must also include filtration.   The treatment
provided, in any case, is required to achieve at least 99.9 percent removal
and/or inactivation of Giardia 1ambli a cysts and at  least 99.99 percent
removal and/or inactivation of viruses (i.e., virus  of fecal origin and
infectious to humans).  Unfiltered systems are required to  demonstrate that
disinfection alone achieves the minimum performance  requirements by monitoring
disinfectant residual(s), disinfectant contact time(s),  pH  (if chlorine is
used), and water temperature. These  data must be applied to determine if their
"C t"  value  [the  product of disinfectant concentration (mg/L)  and disinfectant
contact (minutes)] equals or exceeds the C't values  for  Giardia 1ambli a
specified in the SWTR.1   With the exception  of chloramines,  where ammonia  is
added prior to chlorine, these C't values  are also adequate  to  achieve greater
than 99.99 percent inactivation of viruses.   For filtered systems,  states are
required to specify the  level of disinfection for each system to ensure that
their overall treatment  achieves at  least  99.9 and 99.99 percent removal
and/or inactivation of Giardia 1ambli a cysts and viruses, respectively.1
     In the Guidance Manual to the SWTR, EPA recommends C't  values  for

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different disinfectants to achieve levels of inactivation for unfiltered
systems.  Filtered systems will be required to achieve less inactivation then
required for unfiltered systems.  The percent inactivation that filtered
systems should achieve as a function of the filtration technology in place and
source water quality conditions is also recommended.2
PROBLEM
     The destruction of pathogens by chlorination is dependent on a number of
factors, including water temperature, pH, disinfectant contact time, degree of
mixing, turbidity, presence of interfering substances, and concentration of
chlorine available.  The pH has a significant effect on inactivation
efficiency because it determines the species of chlorine found in solution,
each of which has a different inactivation efficiency.
     The impact of temperature on disinfection efficiency is also significant.
For Example, Clarke's work in virus destruction by chlorine indicates that
contact time must be increased two to three times when the temperature is
lowered 10°C.3  Disinfection by chlorination can  inactivate  Giardia  cysts,  but
only under rigorous conditions.   Most recently,  Hoff et al. concluded that (1)
these cysts are among the most resistant pathogens known, (2) disinfection at
low temperatures is especially difficult, and (3) treatment processes prior to
disinfection are important.4
     Typical C t  values  for 99 percent  inactivation  of Giardia lamblia by free
chlorine at different temperatures and  pH values are shown in Table 1.

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             TABLE  1.  C T VALUES FOR 99%  INACTIVATION OF GIARDIA4
                        LAMBLIA CYSTS BY FREE CHLORINE

Ranae

Temp
(°c
5


15


25




PH
6
7
8
6
7
8
6
7
8
Disinfectant
Concentration
(mg/L)
1.0-8.0
2.0-8.0
2.0-8.0
2.5-3.0
2.5-3.0
2.5-3.0
1.5
1.5
1.5

Time
(min)
6-47
7-42
72-164
7
6-18
7-21
< 6
< 7
< 8


Ct
47-84
56-152
72-164
18-21
18-45
21-52
< 9
<10
<12

Mean
C t
65
97
110
20
32
37
< 9
<10
<12

No. of
Experiments
4
3
3
2
2
2
1
1
1
     Jarroll et al.,  using  in vitro excystation to determine cyst viability,
showed that greater than 99.8 percent of Giardia lamblia cysts can be killed
by exposure to 2.5 mg/L of  chlorine for 10 minutes at 15°C  and pH 6,  or after
60 minutes at pH 7 or 8. At 5°C,  exposure to  2 mg/L  of  chlorine  killed at
least 99.8 percent of all cysts at pH 6 and 7 after 60 minutes.5   While it
required 8 mg/L to kill the same percentage of cysts at pH 6 and  7 after 10
minutes, it required 8 mg/L to inactivate cysts to the same level at pH 8
after 30 minutes.  Inactivation rates decreased at lower temperatures and at
higher pH values as indicated by the higher C t values.
     Because of the obvious interactions among these variables it is essential
that a model be developed for predicting C t values under the various
conditions that may exist in drinking water systems.

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OBJECTIVE
     As Indicated, many factors influence Giardia lamblia reaction kinetics.
The objective of the study described in this paper therefore is to develop an
equation that will relate f/t values for Giardia inactivated by chlorine to
such factors as pH, temperature, level of inactivation and chlorine
concentration.  As mentioned previously, this equation ultimately provided the
values presented in the SWTR and associated Guidance Manual for disinfection
of Giardia 1amblia by free chlorine.
SIGNIFICANCE
     The significance of these efforts relates to the fact that EPA's Office
of Drinking Water has adopted the C't concept to quantify the inactivation of
Giardia 1ambli a by disinfection with free chlorine.  Whether or not a utility
is forced  to install  surface water treatment will depend on its ability to
meet the C't values specified by the SWTR.   Even if the utility is not
required to install filtration a utility may have to make significant
investments in holding basins and disinfection capacity in order to meet these
requirements.  Therefore C't values  established  under the SWTR will  be
extremely  important to the drinking water industry and the authors believe it
                   »-k
is important that the industry understand the basis for the procedures used to
estimate these values.  This paper describes the way in which C t values were
calculated for the SWTR.  It is unlikely that utilities can directly use the
models developed in this paper, although it is important that they understand
the mechanism by which C't values  have been derived.   Tables generated from
the model  will be useful as they provide the C't values for Giardia inacti-
vation by  chlorine that utilities must achieve.   These tables are presented at
the end of the paper.

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                                    THEORY
      Current disinfection theory is based on the Chick or Chick-Watson model.
Chick's  law expresses the rate of destruction of microorganisms based on a
first-order chemical reaction.6
      dN/dt - -kt                                          (1)
which when integrated yields
      In  (Nt/No)  - -kt                                       (2)
where
      Nt - number of organisms present at time t (minutes)
      NQ « number of organisms present at time 0
      k   » rate constant characteristic of type of disinfectant,
          microorganism, and water quality aspects of system (minutes'1)
                                 «
     t - time (minutes)
     Watson, using Chick's data, refined this equation to produce an empirical
relation that included changes in the disinfectant concentration:7
     In  (N/No) - r Cnt                                       (3)
where
     C = concentration of disinfectant [(milligrams/liter)17"]
     r - coefficient of specific lethality (liters/milligram '  minutes)
     n « coefficient of dilution (liters/milligrams '  minutes)
or
      (1/r) In (Nt/N0) -  Cnt                                  (4)

For a given level of survival such as Nt/No « 0.001  (3 log reduction)  the  left
hand side of equation 4 is a constant K, or
     K - Cnt                                                (5)
The value K will vary depending on the level  of inactivation.

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EFFECT OF OTHER VARIABLES
     As indicated previously C't values have been found to be a function of
pH, temperature, disinfectant concentration and level of  inactivation.8
Therefore in this study equation 5 was reformulated as follows:
     C t « C'(n'n K                                           (6)
where
     K    - f (pH, temp, I)
     I    » ratio of organisms at time t to the organisms at time 0  (Nt/NQ)
     temp « temperature at which experiment was conducted in °C
     pH   - pH at which experiment was conducted in pH units
Equation 6 can be rewritten in the form:
     C t - R I'CbpHctempd                                   (7)
where
     R,a,b,c,  and d are coefficient to be determined.
A more convenient form for coefficient estimation and the one used in  this
paper is as follows:
     t » R I'Cb'1pHctempd                                    (8)
As will be discussed in the following sections these coefficients will  be
                   •»-.
determined by a statistical analysis using appropriate data bases.
                            COEFFICIENT  ESTIMATES
     Several data sets are available for estimating the coefficients  in
equation 8.   Data sets have been developed by Jarroll, Hibler, Rice  and
Rubin.5'9'11U1
     Much of the available Giardia inactivation data is based on excystation
rather than animal infectivity since it is an easier measure of cyst
viability.11  Hoff et  al. compared mouse  infectivity  and  excystation  for

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determining the viability of £. murls cysts exposed to chlorine and reported
that both methods yielded similar results.12  Hibler et  al. used Mongolian
gerbils to determine the effects of chlorine on £. 1amblia cysts.9  In a
series of experiments, cysts were exposed for various time periods to free
chlorine concentrations ranging from 0.4 to 4.2 mg/L at 0.5,  2.5,  and 5.0°C
and pH 6, 7, and 8.  Each of 5 gerbils was fed 5 x 104 of the chlorine exposed
cysts and subsequently examined for evidence of Infection.  Since the test
animals had each received a dose of 5 x 10* of the chlorine exposed cysts and
subsequently examined for evidence of infection and since infectivity studies
with unchlorinated cysts showed that approximately 5 cysts usually constituted
an infective dose, the following assumptions were made depending on the
infectivity patterns occurring in the animals.  If all five animals were
infected, it was assumed that C t had produced less than 99.99 percent
inactivation and if no animals were infected, that it had produced greater
than 99.99 percent inactivation.9  If,  however,  1-4 animals were infected it
was assumed that the level of viable cysts were 5 per animal  and that 99.99
percent of the original cyst population had been inactivated.   Hibler
interpolated from the results and provided comprehensive tables showing C t
values at 0.5°C temperature intervals.9   Because  of observations indicating
that C t values increased as chlorine concentration increased within the range
of chlorine concentrations used, Hibler et al. advised against use of the C t
values for chlorine concentrations above 2.5 mg/L.
     Table 2 summarizes Hibler's data for the different experimental
conditions examined.  Column 3 shows the range of chlorine concentrations in
mg/L to which cysts were exposed before being fed to the gerbils, and Column 7
shows the number of experiments which yields 1-4 infected gerbils out of 5.

                                       8

-------
Column 4 shows the range of cyst exposure times and Column 5 contains the
range of C t values that are the product  of  the chlorine concentration and
cyst exposure time.
           TABLE 2.   C T VALUES FOR 99.99 PERCENT INACTIVATION BASED
                          ON ANIMAL INFECTIVITY DATA
                         Range of
            Range of  Cyst Exposure     Range of      Range of  Number of
     Temp    Cone.        Time       C't values  from   Predicted  Observa-
      °C    (mg/L)        (min)          Data         C't Values   tions
6
6
6
7
7
7
8
8
8
0.5
2.5
5
0.5
2.5
5
0.5
2.5
5
0.56-3.96
0.53-3.80
0.44-3.47
0.51-4.05
0.64-4.23
0.73-4.08
0.49-3.25
0.50-3.24
0.84-3.67
39-300
18-222
25-287
76-600
55-350
47-227
132-593
54-431
95-417
113-263
65-212
50-180
156-306
124-347
144-222
159-526
175-371
200-386
136-192
107-151
93-134
205-295
169-235
156-211
294-410
233-324
209-299
25
15
26
14
14
15
22
21
15
     Hibler's data set,  based on animal  infectivity,  is appealing because it
is a more direct indicator of cyst viability than  data based on excystation.
However the C t values in  this data  set  are  based  solely  on  99.99 percent
inactivation.  The o£her three data sets,  based on excystation, have values
calculated for all four  parameters in  equation  8.   Table  3 contains a summary
characterization of the  studies  on which these  data sets  were based.  Because
no one individual experiment provided  the exact characteristics required for
this study an attempt was  made to find the "most consistent* set of data for
parameter estimation, which might include several  of the  data sets discussed.

-------
            TABLE 3.   CHARACTERIZATION OF fi.  LAHBLIA  FREE CHLORINE*
                 INACTIVATION STUDIES USED IN PREDICTIVE MODELS
Reference
No.
5
Cyst
Source
Symptomatic
human
Viability
Assay
excy station
Comments
Conventional
survival curves
         8
Gerbils, adapted
from infected
humans.  (CDC
isolate)

Symptomatic and
nonsymptomatic
humans
                     Gerbils adapted
                     from infected
                     humans.  (Several
                     isolates used)
                                                         based on multiple
                                                         samples.  End
                                                         point - 0.1%
                                                         survival

                                         gerbil  infec-   No survival  curves.
                                         tivity  (5       Endpoint sought
                                         animals/sample)     - 0.01% survival
excystation
                    excystation
Conventional
survival curves
based on multiple
samples.  End
point - 0.1%
survival

Conventional
survival curves
based on multiple
samples.  End
*Data provided by DrT John Hoff formerly of USEPA
     The Hibler data set was included in all combinations considered because

it was the largest data set, the data set was based on animal  infectivity, and

the data reflected higher percent inactivation than required under the SWTR.

Since the data based on excystation, with the exception of a few data points,

only reflected percent inactivation up to 1 log or less than that required

under the SWTR, inclusion of the Hibler data was considered essential for

developing a model that could predict disinfection conditions for achieving

                                      10

-------
99.9 percent inactivation with minimum uncertainty.   Filtered systems will
need to know disinfection conditions for achieving less than 99.9 percent
inactivation.  Therefore data from at least one of the excystation studies was-
considered essential since the C't values in the SWTR may be used for
calculating partial inactivation levels (i.e., less than 99.9 percent).
     A fundamental question that needed to be addressed was the statistical
compatibility of the data sets.  Initial regression estimates for each of the
data sets were made using equation 8.13   High  V* were obtained for these
fits but significant differences were found for the *R* coefficient or slope.
This indicated that the basic model was adequate but that there were
differences in the coefficients as defined by the individual estimates using
equation 8.  It was decided to "anchor* all of the data sets to the Hibler
data set.  The approach used was to construct an indicator random variable to
move the regression intercept or slope to compensate for data set
differences.13  The  significance of  the  indicator  random  variable  would
support the hypothesis of different regression surfaces,  i.e., incompatibility
of the data sets chosen.  The indicator random variable was created in such a
way as to always differentiate between the Hibler data set and other data sets
considered and to move the regression intercept not the slope.  The indicator
random variable was defined as follows:
            o if Hibler data
     Z -  [                 ]                          -                  (9)
            1 if other data
Therefore equation 8 was modified as follows:
     t » R I*Cb'lpHeteropd10-l                                               (10)
where t, I, C,  pH, temp are defined as in equation 8, and R,a,b,c,d,e are
constants determined from regression.

                                      11

-------
         Equation  10  can be  transformed as follows:
         log t • log  R + a log  I +  (b-1) log C + c log pH + d temp + ez       (11)
    In  equation 11 when z «  0 equation 10 is defined over the Hibler data set,
    and
         t  - R I* C6"1 pHc tempd                                                (12)
    When  z  • 1 equation 10 is defined over the remaining data and
         t  - (R ' 10e) I* Cb'1 pHc tempd                                        (13)
    Table 4 displays  the data set combinations and regression diagnostics.  Note
    that  z  is  the  indicator  random  variable.
         In Table 4,  the first  column shows the various data sets considered  in
/    the analysis.  Column two contains the "r2" values based on equation 13 for
    each  of the data  combinations.  Column three indicates major results of the
    analysis.   For example it was found, for the first data set combination,  that
    the intercept, and temperature  variable were not significant.  Column 4 shows
    the test that was used to determine whether or not the equation yields biased
    results.
         As indicated in Column 4 of Table 4 residual plots were used  to determine
    constant variance and normality.  Fortunately a strict assumption  of normality
    is  not  required.  As stated in  Neter, Wasserman and Whitmore "Small departures
    from  normality do not create any serious problems.14  Major departures,  on the
    other hand, should be of concern".  Further they write, "Unless the departures
    from  normality are serious, particularly with respect to skewness, the actual
    confidence coefficients  and risks of error will be close to the levels for
    exact normality".  In addition  because of the large sample size one would
    expect  the central limit theories would apply and symmetry would not be an
    issue.

                                         12

-------
      It was found that 90% of the data fell within plus/or/minus 1.64 standard
deviations of the mean.  In addition 75% of the data fell within plus or minus
1 minus standard deviation which gives support for the normality assumption.
[For  a perfect normal distribution we would expect 68% of the data to lie
within plus or minus 1 standard deviation.  Similarly, we would expect 90% to
lie within plus or minus 1.64 standard deviation of the mean].
      The indicator random variable for the intercept variable using the
Hibler, Jarroll data base was not significant (p-value » 0.3372).  All other
data  bases considered had a significant indicator random variable at the 0.095
level of significance.  A formal test for differences of intercept and/or
slope between the Hibler and Jarroll data sets was conducted and no difference
was detected.
     As mentioned previously the Hibler data set does possesses some desirable
characteristics and it is the largest data set among all data sets available.
However one might argue that by forcing the Hibler data set into the analysis
the possibility has been ignored that the other data sets may be mutually
consistent, and the Hibler data set may represent an "outlier*.  In addition,
one might hypothesize that data from different experimental situations
prohibits us from making a reasonable comparison among these excystation
studies.   Table 4 shows that the Hibler and Jarroll  data sets are compatible.
Since Table 4  also shows that Hibler-Rice and Hibler-Rubin is not consistent,
then  it is reasonable to assume that the Jarroll  date is not consistent with
the Rice and Rubin data so that the Hibler data is not alone in being
inconsistent with the other data sets.   It seems reasonable therefore to start
with the Hibler data set, the largest one, then incorporate other smaller data
sets  into the  modeling process.  Thus logic supports the use of the Hibler,

                                      13

-------
Jarroll data base for extending the model  development and the coefficients in
equation 8 were estimated using these data as shown in Table 5 in the log
transformed form.13
TABLE 4. DIAGNOSTIC RESULTS FROM
Data sets considered
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Hibler,
Rice, Jarroll, Rubin
Rice, Jarroll, Rubin, z
Rice, Rubin
Rice, Rubin, z
, Jarroll, Rubin
Jarroll, Rubin, z
Rice, Jarroll
Rice, Jarroll, z
Rubin
Rubin, z
Rice
Rice, z
Jarroll
Jarroll, z
R-Square
0.6801
0.7316
0.6649
0.7899
0.6424
0.6879
0.8619
0.865
0.6483
0.7593
0.8548
0.8578
0.8452
0.8459
DATA SET COMBINATION ANALYSIS
Variables
intercept, temp
not-significant
Intercept, temp
not-slanificant
intercept, temp
not-significant
intercept
not-significant
intercept, temp
not-significant
intercept, temp
not-significant
all variables
significant
all variables
significant
temp
not-significant
intercept
not-significant
all variables
significant
all variables
significant
all variables
significant
z not significant
Plots
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
non-constant var
non-normal data
constant var
non-normal data
constant var
non-normal data
constant var
non-normal data
constant var
non-normal data
                                                              constant var
                                      14

-------
                TABLE  5.   COEFFICIENT ESTIMATES  FOR  EQUATION 8.
Statistical Analysis
Standard T for HO:
Variable
DF
Coefficient
Error
Parameter«0
PROB > 0 1
Vari
Infl
ance
ation
Factor
INTERCEP
LOGI
LOGCHLOR
LOGPH
LOGTEHP
1
1
1
1
1
-0
-0
-0
2
-0
.902
.268
.812
.544
.146
0
0
0
0
0
.200
.014
.042
.221
.028
-4
-19
-19
11
-5
.518
.420
.136
.535
.117
0
0
0
0
0
.0001
.0001
.0001
.0001
.0001
0.
1.
1.
1.
1.
000
183
033
032
179
     In Table 5 column 7 entitled the 'Variance Inflation Factor (VIF)* is
defined as (l-R^) where Rk2 is the coefficient of multiple determination when
Xk is  regressed on the other variables  in  the  model.   The minimum value of VIF
is 1 if there is no  multicollinearity.   As shown in column 7 all of the
variance inflation factors are close to one.
                              DISCUSSION OF MODEL
     As discussed in the previous sections the coefficients for equation 8
were determined by a combination of log transformation and linear regression.
An issue to consider is the probability that  there is measurement error in the
model's independent  variables and the effect  that this could have on estimates
of the parameters.~
     Regression is intended to fulfill  the dual purposes of prediction and
explanation.   The purpose of equation 8 is primarily to predict by providing
water utilities guidance as to what C't values will  be needed  for a desired
level  of inactivation.  The purpose of this model  is to predict C't values and
will not be hampered by measurement error as  long as consistency is
maintained.15   Since any measurement  is subject to some type of  error,  the
approach taken to deal with this issue was to provide safe  or "conservative
estimates* of C t  values.
                                      15

-------
     As one of the diagnostic procedures applied to the analysis equation 13
was evaluated for multicolinearity.  As can be see from Table 5 all of the
coefficients are highly significant and there is no multicolinearity.
TABLE 6. COLLINEARITY DIAGNOSTICS
Condition
Number
1.000
2.495
2.801
10.662
45.636
VAR PROP
Intercep
0.0002
0.0001
0.0003
0.0147
0.9847
VAR PROP
LOG I
0.0031
0.0063
0.0067
0.9266
0.0574
VAR PROP
LOGCHLOR
0.0214
0.0138
0.9285
0.0029
0.0334
VAR PROP
LOGPH
0.0003
0.0001
0.0004
0.0253
0.9739
VAR PROP
LOGTEMP
0.0174
0.7833
0.0005
0.1918
0.0071
     In Table 6 VAR PROP is the variance-decomposition proportion (VDP) and
has a maximum value of 1.   A high condition number coupled with high VDP
values for two or more coefficients is an indication of multicollinearity
between those variables.  A condition of 45.636 in conjunction with an
intercept VDP of 0.9847 and Log(pH) VDP of 0.9739 indicated a dependency
between the intercept and  Log(pH) variable, however, multicollinearity among
the other coefficients were nonexistent.
     The final equation used for predicting C t values in the SWTR was based
on equation 8 as follows:
     C t - RI'CbpHctempd                                    (14)
     Confidence intervals  of the coefficients estimate for equation 14 based
on the Bonferroni method at a 99% confidence interval are:14'16
                              R:  ( 0.384,   0.4096)
                              a:  (-0.2321, -0.3031)
                              b:  ( 0.0792,  0.2977)
                              c:  ( 1.9756,  3.1117)
                              d:  (-0.2192, -0.0724)
                                      16

-------
                                    RESULTS
     There are many uncertainties regarding the various data sets that might
be considered for calculating C't values.   The random variable analysis shows  '
the statistical incompatibility among most of these data sets.  More work
needs to be done to define the impact of strain variation and in vivo versus
in vitro techniques on C't values.   In order to provide conservative estimates
for C t values in the SWTR and the  guidance  document the authors used the
approach illustrated in Figure 1.
     In Figure 1 the 99% confidence interval of the 4 log inactivation level
is calculated.  First order kinetics are then assumed so that the inactivation
"line* goes through 1 at C't  - 0  and a C't value equal  to the  upper  99% con-
fidence interval at 4 logs of inactivation.   As can be seen the inactivation
line consists of higher C't values  than all  of the mean predicted C't  values
from equation 14, most of the Jarroll et al., and most of the Hibler data
points.  Conservative C't  values,  for a specified  level of  inactivation, can
be obtained from the inactivation line prescribed by the disinfection condi-
tions.  For the example indicated in Figure 1, the appropriate C't for
achieving 99.9% inactivation  would be 105.  This approach (assumption of first
order kinetics) also provides the basis for establishing credits for sequen-
tial disinfection steps allowed under the SWTR.  It should be noted that this
approach provides very conservative estimates at mid range levels of C t.
     Note in Figure 1 that some of the individual  data points fall outside the
99% confidence interval estimated at the four logs of inactivation.  This is
to be expected since the confidence intervals constructed were for mean C't
values, but also indicated the high variability of the Hibler data.
     Equation 14 was applied  using the above strategy, as a safety factor,  to
determine the C't "alues for  99.9 percent  inactivation at 0.5°C  and  5°C  in the

                                      17

-------




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final SWTR.1  C t  values  for  temperatures above 5°C were estimated assuming a
twofold decrease for every 10°C increase in  temperature since  all  the Hibler
data was generated at 5°C or  less.   This general  principle is  supported by
Hoff.
     Application of equation 14 to pHs above 8,  up to 9, was considered
reasonable because the model  is substantially sensitive to pH (e.g., C ts at
pH 9 are about three times greater than C ts at pH 6  and about two times
greater than C ts  at pH 7).   At a pH of 9, approximately four  percent of the
hypochlorous acid fraction of free chlorine  is still  present.   Other data
indicate that in terms of HOC1 residuals (versus  total free chlorine residuals
including HOC1 and OC1~)  the  C t  values  required  for  inactivation  of Giardia
muris and Giardia 1amblia cysts decrease with increasing pH from 7 to 9.10
However, with increasing pH,  the fraction of free chlorine existing as the
weaker oxidant species (OCT) increases.  In terms of total  free chlorine
residuals (i.e., HOC1 and OC1") the  C't  values required  for  inactivation  of
Giardia muris and Giardia lamblia cysts increase  with increasing pH from 7 to
9 but generally less than by a factor of 2  at concentrations of less than 5.0
mg/L.'°   Table  7 compares  the C t values in the proposed SWTR to those given
in the SWTR.  The C't values  in the  proposed SWTR were based only on the
Hibler data and included different safety factors.2'8
                                      19

-------
             TABLE 7.  COMPARISON BETWEEN MODIFIED APPROACH (MEANS) AND RULE C TS
                 AT 99.9% INACTIVATION AND 5°C  IN  THE  PROPOSED AND FINAL  SWTR


        	pjj	
        Concentration          6                 789
           mg/l       Proposed  Final   Proposed Final  Proposed Final  Proposed  Final
1
2
105
116
108
122
149
165
165
186
216
243
238
269
329
371
312
353
             The C't values in the final SWTR are 0-10 percent  lower than  in  the

        proposed SWTR.   Table 8  presents representative  C't values determined by

        application of  the  above described  approach.
                  TABLE 8.  CALCULATED C'T VALUES FOR GIARDIA INACTIVATION
                              USING  USING EQUATION  14  AT  0.5°C and  5°

                               Values for Inactivation of Giardia Cysts
                                      by Free Chlorine at 0.5°C
 hlorine
 centration
       pH » 6
 Log  Inactivation
0.5  1.0  2.0  3.0
      pH  «  7
  Log  Inactivation
0.5  1.0  2.0  3.0
      pH  -  8
 Log  Inactivation
0.5  1.0  2.0  3.0
      pH = 9
 Log  Inactivation
0.5  1.0  2.0  3.8
0.4
1
2
3
23
25
28
30
46
49
55
60
91
99
110
121
137
148
165
181
33
35
39
44
65
70
79
87
130
140
157
174
195
210
236
261
46
51
58
64
92
101
115
127
185
203
231
255
277
304
346
382
65
73
83
92
130
146
167
184
260
291
333
368
390
437
500
552
                               Values for Inactivation of Giardia Cysts
                                      by Free Chlorine at 5°C
:hlorine           pH - 6             pH - 7              pH - 8              pH « 9
icentration   Log Inactivation    Log Inactivation    Log Inactivation    Log Inactivation
 mg/L        0.5   1.0   2.0  3.0  C.5   1.0   2.0   3.0   0.5   1.0   2.0  3.0   0.5  1.0  2.0   3.8
0.4
1
2
3
16
18
19
21
32
35
39
42
65 97
70 105
77 116
84 126
23
25
28
30
46 93
50 99
55 110
61 121
139
149
165
182
33
36
41
45
66 137
72 144
81 162
89 179
198
216
243
268
47 93
52 104
59 118
65 130
186 279
208 312
235 353
259 389
                                              20

-------
     Because calculations  for the SWTR C t values are  the upper  limit  on  the
error bounds associated with equation 14 (Table 8),  an equation  was developed
to estimate these C't values for 0.5 and 5°C directly.  C t  values above 5°C
can be estimated by using  the method given below  to  estimate  C't  values at
5°C,  then the assumption that there is a twofold decrease in  C t values for
every 10°C increase in temperature can be applied.  The equation  for the
estimated C't values at 0.5 and 5°C  is  as follows:
     C't - 0.36 pH2'69temp'°'15C° 15(-log I)1'00    (R2 - 0.998}         (15)
where the variables in equation 15 are as defined previously.
     Table 9 compares the  values estimated by  equation 15 and the SWTR values
shown in Table 8.
           TABLE 9.   CALCULATED C T  VALUES  FOR  GIARDIA INACTIVATION
                       USING EQUATION 15 AT 0.5 AND 5°C

Chi orine
Concentration
mg/L
0.4
1
2 •
3

Chlorine
Concentration
mg/L
0.4
1
2
3

Log
0.5
22
25
27
29

Log
0.5
15
17
19
20

Values
pH - 6
Inactivation
1.0 2.0 -3.0
43
49
55
58

86 129
99 148
109 164
116 174
Values
pH - 6
Inactivation
1.0 2.0 3.0
31
35
39
41
61 91
70 104
77 116
82 123
for Inactivation of
bv Free Chlorine at
pH - 7
Log Inactivation
0.5 1.0 2.0 3.0
33 65 131 196
37 75 149 224
41 83 165 248
44 88 175 263
for Inactivation of
bv Free Chlorine at
pH « 7
Log Inactivation
0.5 1.0 2.0 3.0
23 46 92 138
26 53 106 158
29 58 117 175
31 62 124 186
Giardia
0.5°C
Cysts

pH - 8
Log Inactivation
0.5 1.0 2.0 3.0
47 94
54 107
59 118
63 126
Giardia
5°C
187
214
137
251
Cysts
281
321
355
377

pH « 8
Log Inactivation
0.5 1.0 2.0 3.0
33 66
38 76
42 84
44 89
132
151
167
178
198
227
251
266

Loq
0.5
64
74
81
86

LOQ
0.5
46
52
58
61


pH = 9
Inactivat
1.0
129
147
163
173

2.0
257
294
325
345

pH = 9
Inactivat
1.0
91
104
115
122
2.0
182
208
320
244

ior
3.
3S
4-
4J
5;

ior
3.
27
31
3'
36
                                      21

-------
                                  FUTURE WORK
     Because of the importance from an economic and a public health viewpoint
of the calculation of C't  values  for  the  inactivation of Giardia  1amblia by
free chlorine, much effort has been expended in developing models that
interrelate the important  variables effecting these values.8  The work
reported in this paper reflects the authors attempts to develop such a
relationship for inclusion in the SWTR.  However,  it also  raises  a very
interesting point regarding the application of statistical methodology to
public policy decision problems.   There is no perfect "regulatory* experiment
that answers all of the textbook questions that could be raised regarding
regulatory decision making.  One has  to use available data and incorporate the
best judgment that can be  brought to  bear on a given issue to insure that
public health and welfare  is protected. 'The need  to combine data sets from
different investigations and then develop a decision rule  based on the data,
as shown in this paper, as an example of the this  process.
     There is no doubt in  the authors' mind that other better models may be
developed.  For example, Haas'  work in applying the Horn model to  inactivation
data and incorporating the method of  Maximum Likelihood for estimating
parameters is promising.17  The authors believe that  the public is  best  served
by examining problems from many different points of view and encourage others
to pursue these difficult, frustrating but extremely challenging  problems.
                           SUMMARY AND CONCLUSIONS
     Amendments to the Safe Drinking  Water Act clearly require that all
surface water suppliers in the U.S.  filter and/or  disinfect to protect the
health of their customers.  G.  lamblia has been identified as one of the
leading causes of waterborne disease  outbreaks in  the U.S.  G. lamblia cysts
are also one of the most resistant organisms to disinfection by free chlorine.

                                      22

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EPA's Office of Drinking Water has adopted the C t  concept  to  quantify  the
inactivation of £. lamblia cysts by disinfection.  If a utility can assure
that a large enough C't can be maintained to  ensure adequate disinfection
then, depending upon site specific factors, it may not be required to install
filtration.  Similarly, the C't concept can be applied to filtered systems  for
determining appropriate levels of protection.
     In this paper, an equation has been developed that can be used to predict
C't values for the inactivation of fi.  lamblia by free chlorine based on the
interaction of disinfectant concentration, temperature, pH, and inactivation
level.  The parameters for this equation have been derived from a set of
animal infectivity and excystation data.  The equation can be used to predict
C't values for achieving 0.5 to 4 logs of inactivation,  within temperature
ranges of 0.5 to 5°C,  chlorine concentration  ranges up to 4 mg/L,  and pH
levels of 6 to 8.  While the model was not based on pH values above 8, the
model is still considered applicable up to pH level of 9.  The equation shows
the effect of disproportionate increases of C't versus inactivation levels.
Using 99% confidence intervals at the 4 log inactivation levels and applying
first order kinetics to these end points a conservative regulatory strategy
for defining C't at various levels of inactivation has been developed.   This
approach represents an alternative to the regulatory strategy previously
proposed.
                                      23

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                               ACKNOWLEDGMENTS

     The authors would like to acknowledge Ms.  Patricia Pierson and Ms.  Diane
Routledge for their assistance in preparing this manuscript.   The authors are
grateful to Dr. John Hoff,  formerly of USEPA,  Ms.  Shirley Pien and Ms.  Eleanor
Read of the Computer Sciences Corporation, Mr.  Dennis Black of the University
of Nevada, Las Vegas, and Dr. Charles Haas of the Illinois Institute of
Technology for their review and suggestions to improve the manuscript.   The
authors would like to extend a special  acknowledgement to Ms.  Dianne Wild for
her assistance in the preparation of this manuscript.
                                      24

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                                  REFERENCES

1.   National Primary Drinking Water Regulations:  Filtration, Disinfection,
     Turbidity, Giardia lamblia. Viruses, Leaionella. and Heterotrophic
     Bacteria.  Final Rule, 40 CFR parts 141 and 142.  Fed. Reg. 54:124:27486
     (June 29, 1989).

2.   U.S. Environmental Protection Agency, Office of Drinking Water, Criteria
     and Standards Division.  Guidance Manual for Compliance with the Filtra-
     tion and Disinfection Requirements for Public Water Systems Using Surface
     Water Sources, October 1987.

3.   Clarke, N. A., Berg, C., Kabler, P. W., and Chang, S. I., "Human Enteric
     Viruses in Water:  Source, Survival, and Removability*.  International
     Conference on Water Pollutions Research, Landar, September, 1962.

4.   Hoff, J. C., Rice, E. W., and Schaefer III, F. W. "Disinfection and the
     Control of Waterborne Giardiasis", In Proceedings of the 1984 Specialty
     Conference, Environmental Engineering Division, ASCE, June 1984.

5.   Jarroll, E. L., Bingham, A. K., and Meyer, E. A.  "Effect of Chlorine on
     Giardia Lamblia Cyst Viability".  Applied and Environmental Microbiology.
     Vol. 41, pp. 483-48, February, 1981.

6.   Chick, H., "an Investigation of the Laws of Disinfection:, J. Hygiene, 8,
     92 (1908).

7.   Watson, W. E., "A Note on the Variation of the Rate of Disinfection with
     Change in the Concentration of the Disinfectant", J. Hygiene, 8, 536
     (1908).

8.   Clark, R. M., Read, E. J., and Hoff, J. C. "Analysis of Inactivation of
     Giardia Lamblia by Chlorine". Journal of Environmental Engineering, ASCE,
     Vol. 115, No. 1, February, 1989, pp. 80-90.

9.   Hibler, C. P., Hancock, C. M., Perger, L. M., Wegrzyn, J. G. and Swabby,
     K. D. "Inactivation of Giardia Cysts with Chlorine at 0.5°C to  5.0°C.
     american Water Works Association Research Foundation, 6666 West Quincy
     Avenue, Denver, Colorado 80235, 1987.

10.  Rice, E. W., Hoff, J. C. and Schaefer III, F. W. "Inactivation of Giardia
     Cysts by Chlorine", Applied and Environmental Microbiology. Jan. 1982,
     Vol. 43, No. 1, pp. 250-251.

11.  Rubin, A. J., Evers, D. P., Eyman, C. M., and Jarroll, E. L.,
     "Inactivation of Gerbil-Cultured Giardia Lamblia Cysts by Free Chlorine",
     Applied and Environmental Microbiology. Oct. 1989, Vol. 55, No. 10, p.
     2592-2594.

12.  Hoff, J. C., "Inactivation of Microbial Agents by Chemical Disinfectants"
     EPA/600/2-86-067.

13.  Draper, N. and Smith, H. (1981) Second Edition, Applied Regression
     Analysis. Wiley: New York.

                                      25

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14.  Neter,  J.  and Wasserman,  W.  (1974),  Applied  Linear Statistical  Models.
     Irwin:  Homewood,  IL.

15.  Fuller, Wayne,  Measurement Error Models.  John Wiley & Sons,  1987.

16.  Belsley, D.  A.,  Kuh,  e.  and  Welsch,  R.  E.  (1980),  Regression Diagnostics.
     Wiley:  New York.

17.  Haas,  Charles W.,  and Hillar,  B.  Statistical Analysis of Data on
     Chlorine Inactivation of Giardia Lamblia.  Final  Report prepared for U.S.
     EPA Office of Drinking Water,  January 6,  1988.
                                      26

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                                   GLOSSARY

d Nt/dt « rate of change of organisms  with  respect to time
k       - inactivation rate in minutes"1
t       * time in minutes
Nt      « number of organisms  at  time  t
N0      « number of organisms  at  time  0
r       - coefficient of specific lethality (liters/milligram - minutes)
C       « concentration of disinfectant [milligrams/liter]17"
n       -  coefficient of dilution
K       « constant at given level temperature, pH and inactivation level
pH      - pH in water phase
temp    « temperature in °C
I       * level of inactivation
C t      - concentration  in  mg/l times  time  in  minutes
R       - coefficient to be determined
a       » coefficient to be determined
c       * coefficient to be determined
d       - coefficient to be determined
e       - coefficient to be determined
z       - coefficient to be determined
VIF     » variance inflation factor.  If VIF is 1 there is no multicolinearity
VDP     - variance decomposition  number.  If VDP  is high for two or more
   variables there is an induction of multicolinearity between
variables
Bonferroni technique - a conservative method of estimating confidence
         intervals
                                      27

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permanganate as a disinfectant.  It  is not meant to be used as a basis for
establishing CT requirements.


References

Berman, D.; Hoff,  J.  Inactivation of Simian  Rotavirus SA 11 by Chlorine,
Chlorine   Dioxide   and   Monochloramine.     Appl.   Environ.   Microbiol.,
48:317-323, 1984.

Chang,  J.C.H.;  Ossoff,   S.F.;  Lobe,  D.C.;  Dorfman,  M.H.;  Dumais,  C.M.;
Quails,  R.G.;  Johnson,   J.D.   Inactivation of  Pathogenic  and  Indicator
Microorganisms.  Applied Environ. Micro., June 1985, pp. 1361-1365.

Clark,  R.M.; Read,  E.J.; Hoff,  J.C.   Inactivation of Giardia Iambi la by
Chlorine:  A Mathematical and Statistical Analysis.  Unpublished Report,
EPA/600/X-87/149, DWRD,  Cincinnati, OH, 1987.

Clark,  R.; Regli,  S.; Black, D.   Inactivation of Giardia lamblia by Free
Chlorine:  A  Mathematical  Model.    Presented  at   AWWA  Water  Quality
Technology Conference.   St. Louis, Mo., November 1988.

Clark,  M.R.; Regli,  S.   The Basis for Giardia  CT  Values  in the Surface
Water Treatment Rule:  Inactivation by Chlorine.   Submitted  to Journal of
Water Supply Research and Technology-Aqua, August 1990.

Hibler, C.P.;  C.M.  Hancock;  L.M. Perger; J.G. Wegrzn;  K.D. Swabby Inacti-
vation  of  Giardia  cysts with Chlorine at  0.5 C to 5.0 C  American Water
Works Association Research Foundation, In press, 1987.

Hoff, J.C.  Inactivation of Microbial Agents bv Chemical  Disinfectants.
EPA/600/52-86/067, U.S.  Environmental Protection Agency,  Water Engineering
Research Laboratory, Cincinnati, Ohio, September,  1986.

Jarroll,  E.L.;  A.K. Binham;  E.A. Meyer  Effect  of  Chlorine  on Giardia
1amb1ia Cyst Viability.  Appl.  Environ. Microbiol.,  41:483-487, 1981.

Leahy, J.G.; Rubin,  A.J.;  Sproul, O.J.   Inactivation  of  Giardia muris.
Cysts by Free Chlorine.  Appl,  Environ. Microbiol.,  July 1987.

Rice,  E.;  Hoff,  J.; Schaefer,  F.   Inactivation  of Giardia  Cysts  by
Chlorine.  Appl. and Environ. Microbiology, 43:250-251, January 1982.

Roy, D., R.S.  Engelbrecht,  and E.S.K.  Chian.  Comparative Inactivation of
Six Enteroviruses by Ozone.  J. AWWA, 74(12):660,  1982.

Rubin,  A.   Factors  Affecting  the Inactivation  of  Giardia Cysts by Mono-
chloramine and Comparison with  other Disinfectants.  Water Engineering Re-
search  Laboratory, Cincinnati,  OH March 1988a.
                                   F-8

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Rubin, A. "CT Products for the Inactivation of Giardia Cysts by Chlorine,
Chloramine, Iodine, Ozone and Chlorine Dioxide" submitted for publication
in J. AWWA, December, 1988b.

Sobsey, M. Detection  and  Chlorine  Disinfection of Hepatitus  A in Water.
CR-813-024.  EPA Quarterly Report.  December 1988.

Vaughn, J.; Chen,  Y.;  Lindburg, K.; Morales,  D.  Inactivation of Human and
Simian Rotaviruses by Ozone.   Appl. Environ. Microbiol., 53(9):2218-2221,
September 1987.

Wickramanayake, G.; Rubin, A.; Sproul, 0.   Effects of Ozone  and Storage
Temperature on Giardia Cysts.  J.AWWA,  77(8):74-77, 1985.

Yahya, M.T.,  Landeen,  L.K., Forsthoefel, N.R., Kujawa,  K., and Gerba, C.P.
Evaluation of  Potassium Permanganate for Inactivation  of  Bacteriophage
MS-2  in Water  Systems.   Copyright  1988,  Carus  Chemical  Company, Ottawa,
Illinois.
                                   F-9

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                 APPENDIX S-l
DETERMINING CHLORAMINE INACTIVATION OF 3IAP.DIA

     FOR THE SURFACE WATER TREATMENT RULE
       Microbiological  Treatment Branch
    Risk 'eduction Engineering Laboratory

                     and

      Parasitology and  Immunology Branch
 invironmental Monitoring Systems Laboratory
     U.S. Environmental  Protection Agency
       26 West Martin Luther King Drive
           Cincinnati,  Ohio  45263

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                              TABLE OF CONTENTS





  I.  Materials	3



 II.  Reagents	4



III.  Giardia muris Assay	7



 IV.  Disinfection Procedures for Giardia	10



  /.  Procedure for Determining Inactivation	;....12



 VI.  Bibliography	13



VII.  Technical  Contacts	14



  Appendix



      A.  Use of the Hemocytometer	15



      3.  Preparation and Loading of Chamber Slides	20

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     The Surface Water Treatment Rule  requires 39.9%  or  greater removal/
inactivati'on of Giardia.   The following protocol  may be used  to  determine
the percentage  of Giardia  inactivation obtained  by  a  treatment  plant
using ciloramine disinfection.

I.   yATEDIALS

    A.  Materials for Disinfection

         1.   Stock chlorine solution
         2.   Stock ammonia solution
         3,   Stirring'device
         4.   Incubator  or  water  bath  for  temperatures  below  ambient
         5,   Water fro.n treatment plant
         6.   Giardia  muris cysts
         7.   Assorted glassware
         8.   Assorted pipettes
         9.   Reagents and instruments for determining disinfectant residual
        10.   Sterile  sodium thiosulfate solution
        11.   Vacuum filter device,  for 47mm diameter filters
        12.   1.0  jm   pore  size  polycarbonate  filters,  47  mm  diameter
        13.   Vacuum source
        14.   Crushed  ice  and ice bucket
        15.   Timer

    3.  M.aterials for Excystation

         1.   Exposed  and  control Giardia muris cysts
         2.   Reducing solution
         3.   0.1 M sodium bicarbonate
         4.   Trypsin-Tryode's solution
         5.   15  ml  conical  screw cap centrifuge tubes
         6.   Water bath,  37°C
         7.   Warm air incubator or  slide warming  tray, 37'C
         8.   Aspirator flask
         9.   Vacuum" source
        10.   Assorted pipettes
        11.   Vortex mixer
        12.   Centrifuge with swinging bucket rotor
        13.   Chamber  si ides
        14.   Phase contrast microscope
        15.   Differential  cell  counter
        16.   Timer

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II.   REAGENTS
     A.   Reducing Solution

               Ingredient               	Amount
               glJtathione (reduced form)0.2  g
               L-cysteine-HCl                                 0.2  g
               IX Hanks'  balanced salt solution             20.0  ml

               Dissolve the dry ingredients in the IX Hanks'  balanced  salt
               solution and warm  to  378C  before  use  in the  experiment.
               Prepare fresh,  within 1 hour of use.

     3.   Sodiuoi Bicarbonate Solution, 0.1  H

               Ingredient	Amount
               Sodium bicarbonate0.42 g

               Dissolve the salt  in  10 to 15 ml  distilled  water.   Adjust
               the volume  to  50  ml  with  additional  distilled  water  and
               warm to 37'C before  use in the experiment.   Prepare  fresh,
               within 1 hour of use.

     C.   Sodium Bicarbonate Solution, 7.5*

               Ingredient	Amount
               Sodium bicarbonate7.5  g

               Dissolve the sodium  bicarbonate in 50 ml distilled  water.
               Adjust the  volume  to  100 ml   with  additional  distilled
               water.  Store at room temperature.

     D.   Sodium Thiosulfate Solution, 10%

               Ingredient	Amount
               Sodium thiosulfate10.0 g

               Dissolve the sodium  thiosulfate in 50 ml distilled  water.
               Adjust the  volume  to  100 ml   with  additional  distilled
               water.  Filter   sterilize   the  sol ution - through  a 0.22  urn
               porosity membrane  or  autoclave  for  15  minutes  at  1213C.
               Store at room temperature.

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E.  Tyrode's Solution, 20X
Ingredient
Nad
KC1
CaCl2
MgCV6H20
M a L! ^ f\ tU A
• 1 Q i o r U /i n o j
Glucose
Amount
160.0 g
4.0 g
4.0 g
2.0 g
1.0 g
20.0 g
          Dissolve the dry ingredients  in the  order  listed  in  750 ml
          distilled water.  Adjust the volume to 1.0 liter with addi-
          tional distilled  water.   If  long  term  storage  (up to  1
          year) is desired,  filter  sterilize the  solution  through a
          0.22 u;n porosity membrane.
F.  Tyrode's Solution, IX
Ingredient
20X Tyrode1 s solution
Dilute 5 ml of the 20X Tyrode's
of 100 ml with distilled water.
Amount
5.0 ml
solution to a final
                                                               volume
    Trypsin-Tyrode's Solution
Ingredient
Trypsin,
Na'HC03
IX Tyrode
i :
's
100,
sol
U
ut
.S. Biochemical Co.
ion
Amount
0.
0.
100.
50
15
00
g
g
ml
          '-.'ith continuous mixing on a stirplate, gradually add 100 ~1
          IX Tyrode's  solution  to  the   dry  ingredients.   Continue
          stirring until  the dry ingredients are completely dissolved.
          Adjust the  pH  of  the solution  to  8.0  with  7.5"  NaHC03.
          ChiVl  the trypsin Tyrode's solution to 4°C.  NOTE:  Trypsii
          lots must  be  tested  for  their  excystation  efficiency.
          Prepare fresh,  within 1 hour of use.
H.
Polyoxyethylene Sorbitan  Monolaurate (Tween  20)
(v/v)

      Ingredient	
Solution, 0.01'
                                                        Amount
          Tween 20

          Add the
          well.
                                                    O.TmT

               Tween  20  to  1.0  liter of  distilled water.   Mix

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I.   Vaspar
          Ingredient	Amount
          Paraffin                                     1  part
          Petroleum jelly                             1  part

          Heat the  two ingredients in a boiling water  bath  until melt-
          ing and mixing is  complete.

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III.   GIARDIA MURIS  AS5AY

      A.   Cysts
          Giardia muris  cysts  may be  available  from  commercial  sources.
          The  cysts  may  be  produced  in  Mongolian  gerbils  (Meriones unguicu-
          1atus) or  in  mice.   Mus  musculus,  the laboratory  mouse,   CF-1,
          BAL3c, and C3H/he  strains  have  been  used to  produce  j2.   muris
          cysts.  The  method is labor  intensive and requires a good animal
          facility.

          In order  for the disinfection procedure to work properly, the _G.
          muris cysts  used  must be of  high  quality.   Evaluation  of a cyst
          suspension is  a subjective  procedure  involving  aspects of morpho-
          logy and microbial  contamination as  well  as  excystment.  A good
          quality G_. muris  cyst preparation should  exhibit  the following:

          1.   Examine cyst stock suspension microscopically for  the presence
              of empty cyst  walls  (ECW).   Cyst  suspensions containing  equal
              to or  greater than  1%  ECW should not be used  for determining
              inactivation  at   any  required level.   However,  if  a   99.9»
              level  of  disinfection  inactivation is  required,  the   stock
              cyst suspension must contain  <0.1*  ECW.

          2.   Excystation should be  90* or  greater.

          3.   The  cyst  suspension  should  contain little or no detectable
              microbial  contamination.

          4.   Good Jj. muris cysts are phase bright with  a  defined  cyst  wall ,
              peritrophic space,  and  agranular cytoplasm.   Cysts  which  are
              phase  dark, have  no  detectable p.eritrophic  space, and have  a
              granular cytoplasm may  be non-viable.  There generally should
              be no  more than 4 to 5% phase  dark  cysts  in the cyst prepara-
              tion.  -

              3ood G.  muris  cyst  'preparations  result  when  the   following
              guideTines are  followed  during cyst purification from feces:

              a.  Use  feces collected  over a  period of  24  hours or  less.

              b.  The  isolation of the  cysts from the  feces  should be done
                 immediately after  the fecal material  is collected.

              c.  Initially,  G. muris  cysts  should  be  purified  from  the
                 fecal  materfal by  flotation  using  1.0 M sucrose.

              d.  If the £. muris  cyst suspension contains an undesirable
                 density of  contaminants  after  the first  sucrose float,
                 further purification  is  necessary.  Two methods  for
                 further purification  are  suggested.

                 1)   Cysts  may be  reconcentrated  over  a  layer  of 0.85  M
                      sucrose in  a  50 ml  conical centrifuge  tube.  If this

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                second exposure to sucrose  is  not done  quickly,  high
                cyst losses can occur due to their  increased  bcuyant
                density in  the  hyperosmotic   sucrose   medium.    The
                cysts must be  thoroughly  washed  free of the  sucrose
                immediately after collection of the  interface.

            2)  Cysts can be separated from  dissimilar  sized  contami-
                nants by  sedimentation  at unit  gravity,  which  will
                not adversely affect cyst bouyant density, morphology,
                or viabil ity.

B.  Maintenance of Cysts

    1.  Preparation of stock suspension

        Determine the suspension  density of  the £. muris cyst  prepara-
        tion using a henocytometer (see  Appendix  A"H  Adjust  the  cyst
        suspension density with distilled water  to  approximately  3-5
        x 106 cysts/ml.

    2.  Storage

        Store cysts  in  distilled  water  in  a  refrigerator  at  4°C.
        Cysts should not be used  for  disinfection experiments if  they
        are .nore  than  2 weeks old  (from  time  of  feces deposition).

C.  Excystation Assay

    A nunber of 3. muris excystation procedures  have been described in
    the scienti fie 1 iterature (see Bibliography,  Section VI).   Any of
    these procedures nay be  used  provided 90S  or greater  excystation
    of control,  undisinfected  _G.   muris   cysts  is  obtained.   The
    following protocol  is  used  to  evaluate the suitability of cysts in
    the stocL suspension , and to  determine excystation  in  control  and
    disinfected cysts.

    1.  For evaluating  a cyst  suspension or  for  running an  unexposed
        control , transfer  5  x 10^  G.  muris  cysts fron  the  stock
        preparation to  a 15 ml  conical screw cap  centrifuge  tube.   An
        unexposed control  should  be processed at  the same  time as the
        disinfectant exposed cysts.

    2.  Reduce the volume of G. muris cyst  suspension  in  each 15 ml
        centrifuge tube to 0.5~ml  or less by centrifugation  at 400 x
        g for 2 minutes.   Aspirate and  discard the  supernatant to no
        less than 0.2 ml above the pellet.

    3.  Add 5 ml  reducing  solution,  prewarmed  to 37°C, to each tube.

    4.  Add 5 ml  0.1  M NaHCOs,  prewarmed to 37°C,  to each tube.  NOTE:
        Tightly close the  caps to prevent the loss  of C02.   If  the
            escapes, excystation  will  not  occur.
    5.   Mix  the  contents  of each  tube by  vortexing  and  place  in
        a  37°C water bath for 30 minutes.

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 6.  Remove the tubes  from the water bath and centrifuge each  for
     2 minutes at 400  x  g.

 7.  Aspirate and discard the  supernatant  to  no less than 0.2 ml
     above the pellet  and resuspend the pellet  in each tube  in 10
     ml  trypsin-Tyrode1s solution chilled  to 48C.

 8.  Centrifuge the  tubes for 2 minutes at  400  x g.

 9.  Aspirate and discard the  supernatant  to  no less than 0.2 ml
     above the pellet.

10.  Add 0.3 ml  trypsin-Tyrode1 s  solution,  prewarmed *o 37°C, to
     each tube.  Resuspend the _G. muris cysts  by low  speed  vortex-
     ing.

11.  Prepare  a   chamber  slide  for each  tube  (see  Appendix  S).

12.  Seal the  coverslip on  each chamber slide  with  melted vaspar
     and incubate at 37'C for  30 minutes  in an  incubator  or  on  a
     si ide warmer.

13.  After incubation,  place  a  chamber slide on  the stage  of an
     upright phase contrast  microscope.  Focus on the slide with  a
     low power objective.   Use a  total magnification of  490X or
     more for the actual quantitation.   NOTE:   Be careful  to  keep
     the objectives  out  of the vaspar.

13.  lihile scanning the  slide  and  using a differential  cell  coun-
     ter, enumerate  the  number of empty cyst walls (ECVJ),  partial-
     ly excysted  trophozoites (PET), and intact cysts  (1C)  observed
     (see Section V for  a  further  description  of these forms  and
     the method  for calculating percentage excystation).   If the
     percentage excystation   in the stock suspension  is  not 90* or
     greater, do   not  continue  with  the disinfection  experiment.

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IV.   DISINFECTION PROCEDURES FOR  GIARDIA

     A.   The treatment plant water  to  be used  should  be  the  water  influent
         into the chloramine disinfection unit process  used  in  the  plant.
         If chloramine disinfection is  performed  at more than  one  point  in
         the treat-lent  process,  e.g.,   prefiltration  and  postfiltration,
         the procedure  should   simulate  as  closely  as  possible  actual
         treatment practice.

     B.   Prepare stock ammonia and chlorine  solutions  to be added  to  the
         treatment plant water  to achieve  the same stoichiometric relation-
         ship between   chlorine  and  ammonia   that  is  used  in  the   water
         treatment plant.  These  solutions should  be concentrated  enough
         so that no more than 2 ml  of  each  solution will be  added  to  the
         treatment plant water  being  disinfected.

     C.   Determine the contact  tine by the methods described in the Surface
         '..'ater Treatment  Rule   and/or   the   associated   Guidance  Manual.

     D.   Rinse a  600  ml  beaker with treatment  plant water to  remove  any
         extraneous material that  may  cause disinfectant  demand.    Then
         add 400 ml  treatment plant water to  the  beaker.

     E.   Mix the contents of the  beaker  short  of  producing a vortex  in  the
         center and  continue  until  the  conclusion  of  the  experiment.

     F.   Equilibrate the 600ml beaker and its contents  as well  as  the dis-
         infectant reagents  to  the  desired experimental  temperature.

     3.   Adjust the  stock _G. muris  cyst  suspension  with  distilled  water  so
         that the concentration  is  2-5  x 10"  cysts/ml.

     H.   Add 0.5 ml  of the  adjusted cyst suspension  to  the contents  of the
         600 ml  beaker.

     I.   Add the disinfectant reagents  to the beaker using the  same rea-
         gents, the  same  sequence  of addition of  reagents, and  the sane
         time interval  between addition of  reagents that is used  in  the
         disinfection  procedure  in  the  treatment  plant.

     J.   Just prior to the  end  of the exposure time, remove  a  sample ade-
         quate for determination of  the disinfectant residual  concentra-
         tion.  Use  methods  prescribed  in the  Surface Water  Treatnent ^ule
         for the determination  of combined chlorine.  This residual  should
         be the  sane  (±20*) as  residual  present  in the treatment plant
         operation.

     K.   At the end  of the exposure time, add  1.0 ml  10% sodium thiosulfate
         soljtion to the contents of the 600  ml  beaker.

     L.   Concentrate the _G. muris  cysts  in  the beaker by filtering  the
         entire contents through  a  1.0 urn porosity  47 mm diameter polycar-
         bonate filter.

-------
M.  Place the filter, cyst  side  up, on the side of a  150  ml  beaker.
    Add 10 ill 0.01* Tween 20 solution to the beaker.   Using a Pasteur
    pipette, wash the _G.  myri s  cysts from the surface  of  the filter
    by aspirating and Fxpel 1 ing  the  0.01%  Tween  20  solution over the
    surface of the filter.

N.  Transfer the  contents of the  150  ml   beaker to  an  appropriately
    labeled 15 ml screw cap conical centrifuge tube.

0.  Keep  the tube  on crushed   ice  until  the  excystation  assay  is
    performed (see Section  III,  C) on  the disinfectant exposed cysts
    and on an unexposed  control  preparation  obtained  from the stock
    cyst suspension.

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V.   PROCEDURE FOR DETERMINING INACTIVATION

    A-   Giardia muris Excystation  Quantitation  Procedure

        The percentage excystation is  calculated  using  the  following  for-
        mula:

                 • excystation   =   . ECV].!_PET..  x  100,
                                  ECW  + PET  +  1C

    where        ECW is.the number of  empty  cyst  walls,

                 PET is the number of partially excysted trophozoites, and

                 1C is the number  of intact  cysts.

        An  ECW is defined  as a  cyst wall which is  open at  one  end  and  is
        completely devoid  of a  trophozoite.   A  PET  is a  cyst  which  has
        started the excystation  process and  progressed  to  the point where
        the trophozoite has  either  started  to emerge  or  has  completely
        emerged and  is  still attached to  the  cyst wall.   An  1C  is  a
        trophozoite rfhich   is  completely  surrounded  with  a  cyst  wall
        showing no evidence of emergence.   For  the  control, generally 100
        forms are counted  to determine the percent  excystation.

        The number of  cysts that  must  be  observed and classified  (ECW,
        PET, 1C)  in the disinfected sample  is  dependent  on the level  of
        inactivation desired and  on  the excystation percentage obtained
        in  the control.

             ror  3.5,  1  and 2 login,  reductions,  (68*, 99*  and 99*  inacti-
             vation, respectively],  the  minimum  number  of  cysts  to  be
             observed  and  classified is determined  by dividing  100  by the
             percentage excystation  (expressed  as  a decimal) obtained  in
             the  control.

             For  a  3  logio  reduction   (99.9%  inactivation)  the  minimum
             number of cysts to  be observed and  classified is  determined
             by dividing  1,000  by the percentage  excystation  (expressed
             as a decimal)  obtained  in the control.

    B.   Determining Inactivation

        The amount of  inactivation is determined by  comparing  the  percent-
        age excystation of the exposed cyst  preparation to  the  percentage
        excystation in the  control  preparation using the   following  for-
        mula :

    % inactivation = 100% - [(exposed % excysted/control % excysted) x  100]

        If  the percentage  excystation  in the exposed preparation  is zero,
        i.e., only 1C  (no  ECW or ?ET)  are observed  and  counted, use <1  as
        the value for  "exposed % excysted"  in  the formula  for calculating
        I inactivation.

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                                                                       13
VI.   BIBLIOGRAPHY

     Anerican Public  Health  Association; American Water Works Association;
     Water Potation  Control  Federation.  Standard Methods for the Examina-
     tion of Uater and  Wastewater,  16th ed.  (1985).

     Belosevic,  M. &  G.M.  Faubert.  Giardia muris:   correlation  between
     oral  dosage,  course  of  infection, and  trophozoite distribution in the
     mouse small  intestine.   Exp. Parasitol., 56:93 (1983).

     Erlandsen,  L.S.  and  E.A.  Meyer.   Giardia  and   Giardiasis.   Plenum
     Press, new  York, (1984).

     Faubert, G.M. et  al.   Comparative  studies on the  pattern  of infec-
     tion with Giardia spp.  in  Mongolian  gerbils.   J. Parasitol., 69:802
     (1983).

     Feely, D.E.   A   simplifed method for  in vitro  excystation of G i ardia
     muris.   J.  Parasitol.,  72:474-475 (198T).

     Feely, D.E.   Induction  of excystation  of Giardia muris by CO?.  62nd
     Annual  Meeting  of the  American  Society of Parasitologists, Lincoln,
     Nebraska, Abstract No.  91  (1987).

     Gonzalez-Castro, J.,  Bermejo-Vicedo,  M.T.  and  Palacios-Gonzalez,  F.
     Desenquistaniento  y  cultivo de  Giardia  muris.  Rev.  Iber. Parasitol.,
     45:21-25 (1986).

     Melvin,  C.M.  and M.M. Brooke.  Laboratory Procedures  for the Diagnosis
     of  Intestinal Parasites.   3rd  ed., HHS  Publication No.  (CDC) 32-8282
     (1982).

     Miale,  J.8.   Laboratory Medicine Hematology,  3rd ed.   C.  V.   MosDy
     Company, St.  Louis,  Missouri (1967).

     Roberts-Thomson, I.e.  et  al..   Giardiasis  in the  mouse:  an  ani'ma1
     model.   Gastroenterol.,  71:57  (1976).

     Sauch,  J.F.   Purification  of  Giardia  muris cysts  by  velocity  sedi-
     mentation.  Appl.  Environ.  Microbiol.,  48:454  (1984).

     Sauch,  J.F.   A   new  method for  excystation  of Giardia.  Advances in
     Giardia  Research.  University  of Calgary,  Calgary, Canada (In Press).

     Schaefer, III,   F.W.,  Rice, E.W.,  &  Hoff, J.C.   Factors  promoting
     In  vitro excystation of Giardia muris cysts.  Trans. Roy. Soc.  Trop.
     Med.  Hyg.,  78:795  (1984).

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VII.  TECHNICAL CONTACTS:
          Eugene W. Rice
          Microbiological Treatment Branch
          Risk Reduction Engineering Laboratory
          U.S. Environmental °rotection Agency
          26 West Martin Luther King Drive
          Cincinnati, Ohio  45258

          Phone: (513) 569-7233

          Frank W. Schaefer, III
          Parasitology and  Immunology Sranch
          Environmental Monitoring Systems Laboratory
          U.S. Environmental Protection Agency
          26 West Martin Luther King Drive
          Cincinnati, Ohio  45268

          'hone: (513) 559-7222

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                                                                       15
                  Appendix A:  Use of the Hemocytometer

Suspension Density Determination Using the Improved Neubauer  (Bright-line)
HemocytO'ieter

     The hemocytometer consists of two chambers separated by a  transverse
trench and  bordered  bilaterally by longitudinal trenches.   Each  chamber
is ruled  and consists  of nine  squares, each 1  x  1  x 0.1  mm  with  a
volume of 0.1 mrn^.   Each square  mm  is  bordered  by  a  triple  line.   The
center line  of   the  three  is  the  boundary line  of  the  square.   (See
Figure 1).

     According to the U. S.  Bureau of  Standards'  requirements, the  cover
glass must  be  free  of  visible defects  and must be  optically plane  on
both sides  within  plus  or  ninus  0.002  mm.   ONLY HEMOCYTOMETER  COVER
GLASSES MAY BE USED.  ORDINARY  COVER GLASSES AND SCRATCHED HEMOCYTOMETERS
ARE UNACCEPTABLE, as they introduce errors into the volume relationships.

     The suspension  to be counted must  be evenly distributed and  free of
large debris, so that the chamber  floods  properly.   The  suspension  to be
counted should contain  0.011 Tween  20 solution to prevent  Giardia  cysts
from sticking and causing improper hemocytometer chamber flooding.   Cyst
suspensions should be  adjusted  so that there are a  total  of 60 to 100  cysts
in the four  corner  counting  squares.  Counts  are  statistically accurate
in this range.   If the  suspension is too  numerous  to'be counted, then it
must be diluted  sufficiently to bring it into this  range.  In some cases,
the suspension will  be too dilute after concentration to give a statisti-
cally reliable count in the 60-130 cyst range.   There is nothing that can
be done about this situation  other than to record the result as question-
able.

     To use the  hemocytometer:

     1.  Dilute  or^concentrate  the suspension as required.

     2.  Apply a  clean  cover  glass  to  the hemocytometer  and  load  the
         hemocytometer chamber   with  8-10 yl of vortexed suspension  per
         chamber.  If  this   operation  has  been  properly   executed,  the
         liquid  should amply fill the  entire chamber  without  bubbles or
         overflowing Into the surrounding moats.  Repeat this step with a
         clean,  dry  hemocytometer  and  cover glass,  1f  loading  has  been
         incorrectly done.   See  step  (12)   below  for  the  hemocytometer
         cleaning procedure.

     3.  Do not  attempt to adjust the cover glass, apply clips, or in any
         way disturb  the  chamber after  it  has  been filled.   Allow  the
         Giardia  cysts  to  settle  30  to 60  seconds  before  starting  the
         count.

     4.  The Giardia cysts may  be counted using a magnification 200-600X.

     5.  Move the chamber  so the  ruled  area  is centered  underneath  it.

     6.  Then, locate  the objective close to the cover glass "^Uln^Se"
         ing it   from  the  side of  rather  than through the  microscope.

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                                                                   16
 7.  Focus  up  from  the  covers!1p  until  the  hemocytometer   ruling
     appears.

 8.  At each  of the  four corners of  the  chanber  is  a 1 mm? divided
     into 15  squares in  which Giardia  cysts  are  to  be counted  (see
     Figure 1).  Beginning  with  the top row  of four squares,.count
     with a hand tally  counter in the directions indicated in  Figure
     2.  Avoid  counting  Giardia  cysts  twice  by counting only  those
     touching the top and left boundary  lines and none of  those  touch-
     ing the lower and  right boundary lines.   Count each  square  mm  in
     this fashion.

 9.  The formula for determining  the  number  of Giardia cysts  per  ml
     suspension 1s:

        ft of cysts  counted  x  10   x dilution factor  x  1,000 mnr   _
        # of sq. mm counted    1 mm           1           1 ml

                                 if cysts/ml

10.  Record  the result  on  a  data  sheet  similar to  that  shown  in
     Figure 3.

11.  A total of six different  hemocytometer chambers  -nust  be  loaded,
     counted, and then  averaged  for each  Giardia  cyst suspension  to
     achieve optimal  counting accuracy.

12.  After each use, the  hemocytometer  and coverslip  must  be  cleaned
     immediately to prevent the  cysts and debris  from drying  on  it.
     Since this apparatus is  precisely  machined,  abrasives cannot  be
     used to clean  it  as they will  disturb  the flooding andvTTune
     relationships.

     a.  Rinse  the hemocytometer   and  cover  glass   first  with  tap
         water-, then 70% ethanol  , and finally with acetone.

     b.  5ry  and  polish  the  hemocytometer  chamber  and  cover  glass
         with lens  paper.  Store it in a secure place.

13.  A number of factors are known to introduce errors into hemocyto-
     meter counts.   These include:

     a.  Inadequate  suspension mixing  before flooding the  chamber.

     b.  Irregular  filling   of  the  chamber,  trapped  air  bubbles,
         dust, or oil  on the chamber or coverslip.

     c.  Chamber coverslip not flat.

     d.  Inaccurately ruled chamber.

     e.  The  enumeration procedure.   Too many or  too   few  Giardia
         cysts  per square, skipping or  recounting  some Giardia cysts.

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                                                              17
f.  Total   number  of  Giardia  cysts  counted  is  too  low  to
    give statistical  confidence in result.

g.  Error in recording tally.

h.  Calculation  error;  failure  to   consider  dilution  factor,
    or area counted.

i.  Inadequate cleaning  and  removal   of  cysts  froin the previous
    count.

j.  Allowing filled chamber to sit too long so that chamber sus-
    pension dries and concentrates.

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                                                                    18
                                      I mm.
                          1/5 mm.
                                                 of Chomfev * 0.1 mm.
   Figure 1.  Hemocytometer platform ruling.   Squares 1,  2,  3,  and  4  are
              used to count Giardia cysts.   (From Miale,  1967)
Figure 2.   Manner of counting  Giardia  cysts  in  1  square mm.   Dark  cysts
           are counted and light cysts  are omitted.   (After Miale,  1967)
                                                                          rtt

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Date













Person
Counting













!












Count
1
1
2
3
4
5
6
7
e
9
10
11
12
13
14
15
~16
17
18
19
20
* Cells
Counted













* IW2
Counted













!












Dilution
Fictor




















1 Cysts*
ml




















Rourfcs









1










cysts/ml . # of cysts counted  x  10  x dilution factor  x  1.000 mm3
           # of sq. mm counted   1 mm          I
                                                      TniT
Figure 3.  Hemocytometer Data Sheet for Glardla Cysts

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y
i *
    Appendix B.   Reparation  and  Loading  of Excystation Chamber  Slides

    'Jsing tape which is sticky on both sides, cut strips  approximately  12
    x 3 mm.

2.  Apply a  strip of  the  tape  to one  side  of a  22  x 22 mm  covers! i?.

3.  Apply a  second  strip of  tape  to  the opposite edge but same  side  of
    the covers! ip.

4.  Handling the covers!ip by the edges only, attach the  covers!ip to  the
    center of a 3x1  inch glass  slide  by  placing  the  taped sides of  the
    covers! ip down along the long edge of the glass slide.

5.  Make sure the covers! ip  is  securely attached  to the  slide  by lightly
    pressing down on the edges of the  coverslip  with  your fingers.   Care
    should be taken to keep finger prints off the center of the coverslip.

5.  To  load  the  chamber  slide,  place  a  Pasteur  or   micro!itar  pipette
    containing at least 0.2 ml of the  Giardia  cyst suspension  about  2  ^m
    from an  untaped edge of the covers!ip.Slowly allow  the cyst suspen-
    sion to   flow  toward  the  coverslip.  As  it touches the coverslip  it
    will be  wicked or drawn rapidly under the  coverslip  by adhesive forces.
    Only expel!   enough of  the  cyst  suspension to  completely  fill  the
    chanber  formed by the tape, slide, and  coverslip.

?.  '.-Jipe away any excess cyst suspension which is not  under the covers!'c
    with an   absorbant  paper  towe! ,   but  be  careful   not  to  pull  cyst
    suspension from under the covers!ip.

3.  Seal all  sides of the coverslip with vaspar to prevent the slide f^on
    drying out djring the incubation.
                   Figure  1.   Excystation  Chamber  Slide

    NOTE:   Prepared  excystation  chamber  slides  may be  commercially  avail-
           able  from Spiral  Systems, Inc., 5740 Clough  Pike,  Cincinnati,
           Ohio   45244,  (513)  231-1211 or 232-3122, or from other sources.

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                  APPErnix 3-2
DETERMINING CHLORAMIfJE INACTIVATION OF VIRUS

      FOR THE SURFACE WATER TREATMENT RULE
        Microbiological  Treatment Branch
     Risk Reduction Engineering Laboratory

                      and

       Parasitology and  Immunology Branch
  Environmental  Monitoring Systems Laboratory
      U.S. Environmental  Protection Agency
        26 '/Jest Martin Luther King Drive
            Cincinnati ,  Ohio  45268

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                              TABLE OF CONTENTS







  I.  Materials	3



 II.  Reagents and Media	.....4



III.  MS2 Sacteriophage Assay	6



 IV.  Disinfection Procedure	8



  V.  Procedure for Determining Inactivation	9



 VI.  Bibliography	10



VII.  Technical Contacts	11

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     The Surface Water Treat-ient Rule  requires  99.99%  or  greater removal/
inactivation of viruses.   The following  protocol  may be used to determine
the percentage of virus  inactivation  obtained  by a treatment plant using
chloramine disinfection.

I.   MATERIALS

    A.  Materials for Disinfection

         1.   Stock chlorine solution
         2.   Stock ammonia solution
         3.   Stirring device
         4.   Incubator .or  water bath for  less than  ambient temperature
         5.   Water from treatment plant
         6.   MS2 bacteriophage
         7.   Assorted glassware
         8.   Assorted pipettes
         9.   Aqueous, sterile sodium  thiosulfate  solution
        19.   Refrigerator
        11.   Vortex  mixer
        12.   Timer

    B.  Materials for MS2 Assay

         1.   MS2 bacteriophage and its Escherichia coli host
         2.   Assorted glassware
         3.   Assorted pipettes
         4.   Incubator, 37°C
         5.   Refrigerator
         6.   Petri  dishes, 100 x 15 mm,  sterile
         7.   Vortex  mixer
         3.   Water bath,  453C
         9.   Sterile rubber spatula
        10.   EDTA, disodium salt
        11.   Lyso^yme, crystallized  from egg white
        12.   Centrifuge with swinging bucket rotor

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II.   PEAGENTS  AND  MEDIA

     A.   Tryptone-Yeast Extract  (TYE)  Broth
Ingredient
Bacto tryptone
Yeast extract
Glucose
NaCl
1.0 M CaC12
Amount
10.0 g
1.0 g
1.0 g
8.0 g
2.0 ml
               Dissolve  in  distilled  water  to a  total volume of 1.0 liter,
               then add  0.3 ml of 6.0 M NaOH.  This medium should  be steri-
               lized either by  autoclaving for  15 minutes  at  121'C  or
               filtration  through  a  0.22   jm  porosity  membrane  and  then
               stored at  approximately  4°C.    It  is  used  in   preparing
               bacterial  host  suspensions  for viral assays.

     B.   Tryptone-Yeast  Extract  (TYE) Agar

               Ingredient                                     Amount
               TYE  broth                                      1.0  liter
               Agar                                         15.0  g

               The  agar should be  added  to  the broth prior  to  steriliza-
               tion.   The  medium  should  be  sterilized by autoclaving  for
               15 minutes  at 121°C.  This medium  is  used to  prepare  slant
               tubes  for  maintenance  of  bacterial   stock  cultures.   The
               prepared slant tubes should be  stored  at  approximately 4C

         Bottom Agar  for  Sacteriophage  Assay
I 0 f
Ingredient
Bacto tryptone
Agar -
NaCl
KC1
1.0 M CaCl2
Amount
10.0 g
15.0 g
2.5 g
2.5 g
1.0 ml
               Dissolve the  ingredients   in  distilled  water  to  a  total
               volume of  1  liter.   The  medium  should  be  sterilized  by
               autoclaving for 15 minutes at 1219C.  After autoclaving and
               cooling, store at  4°C.   Immediately prior to  use,  liquefy
               the medium by  heating.   Add  approximately 15 ml  of  lique-
               fied agar into each  Petri  dish.   This  bottom  layer  serves
               as an anchoring substrate for the top agar layer.

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D.  Top Agar for Bacteriophage Assay
Ingredient
Bacto tryptone
Agar
MaCl
veast extract
Glucose
1.0 M CaCl2
Amount
10.0 g
8.0 g
8.0 g
1.0 g
1.0 g
1.0 ml
          Dissolve the  ingredients   in  distilled  water to  a  total
          volume of 1  liter.  This  medium  should  be   sterilized  by
          autoclaving 15 minutes  at  1218C.   After cooling,  store  at
          4°C until  needed  in  bacteriophage  assays.    Immediately
          prior to use  in  assays,  liquefy the medium by heating  and
          then cool  to  and  maintain  at  a  temperature   of  45'C.

    Salt Diluent for Bacteriophage Assay

          Ingredient	Amount
          NaCl                                          8.5 g
          1.0 M CaCl2                                   2.0 ml

          Dissolve in distilled  water to  a total volume of  1  liter.
          This diluent  should  be  sterilized  either by  autoclaving
          for 15 minutes  at 12TC  or  filtration  through  a  0.22  .m
          porosity membrane.  Store at room temperature.

    CaCl?, 1.0 M

          Ingredient                                   Amount
Ingt
"cTn
          Dissolve in distilled  water  to a total  volume of  100  ml.
          Autoclave 15  minutes  at   1218C  or  filter  sterilize  the
          solution through  a   0.22  urn  porosity  membrane.   Store  at
          room temperature.

G.   Sodium Thiosulfate, 1%

          Ingredient     	Amount
          Sodium thiosulfate1.0 g

          Dissolve the  sodium  thiosulfate  in 50 ml  distilled  water.
          Adjust the  volume  to  100 ml  with  additional   distilled
          water.  Filter  sterilize   the  solution  through  a 0.22  jm
          porosity membrane or  autoclave  15  minutes at 121°C.   Store
          at room temperature.

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III.-   MS2  SACTERIOPHAGE  ASSAY

      A.   Microorganisms

          1.   MS2  bacteriophage:   catalog  number  15597-81,  American  Type
              Culture  Collection, 12301 Parklawn Drive, Rockville, MD  20352

          2.   Bacterial   host:   Escherichia  coli.   catalog   number  15597,
              American Type  Culture  Collection.

      B.   Growth and Maintenance of  Microorganisms

          1.   Preparation  of bacterial host stock cultures

              Inoculate  host  bacteria onto TYE agar  slant tubes, incubate
              24 hours at 37°C to allow bacterial growth,  and  then refriger-
              ate at  4°C.   At  monthly  intervals  the cultured  bacterial
              hosts should be  transferred to a  new  TYE agar slant.

          2.   Preparation  of bacteriophage  stock suspension

              Melt top agar  and  maintain at 45°C.   Add 3 ml   of the agar to
              a 13 x  100 mm test tube contained in  a  rack in a 458C water
              bath.  Add  0.5  to  1.0  ml  of  the bacteriophage  suspension
              diluted  so  that  the host  bacterial   "lawn"  will  show nearly
              complete lysis after overnight incubation.   Add 0.1 to 0.2 ml
              of a TYE broth  culture of the  host  bacteria  that  has  been
              incubated  overnight.   Mix gently  and  pour the contents on the
              surface  of  bottom agar contained in  a  Petri   dish  that has
              been prepared  previously.   Rock  the  Petri dish to spread the
              added material evenly  over the agar  surface.   After the top
              agar solidifies  (about  15  minutes),   invert the  Petri  dish
              and incubate  overnight at 376C.   Repeat the above procedure
              so that  a  minimum  of 5  but no  more  than 10 Petri dishes are
              prepared^.

              Following  this incubation and using a  sterile rubber spatula,
              gently scrape  the  top  and  bottom  agar  layers  into  a large
              beaker.  Add  to  this  pool  of agar  layers   an  amount  of TYE
              broth sufficient to  yield a  total volume  of 80 ml.  To this
              mixture  add  0.4  g  of  EDTA  (disodium salt)  and 0.052  g  of
              lysozyme (crystallized  from egg white).  Incubate this mixture
              at room  temperature  for 2 hours with  continuous mixing.  Then
              centrifuge  the mixture  for 15 minutes  at 3,000  x g.  Carefully
              remove the  upper fluid layer.  This fluid layer constitutes  a
              viral stock  suspension  for  use  in   subsequent  testing and
              assays.  The   viral  stock  suspension  may  be  divided  into
              aliquots and  stored  either frozen or  at  4°C.

      C.   Performance  of Sacteriophage Assay

          A two-week  supply of Petri dishes may be poured with  bottom agar
          ahead of time  and refrigerated inverted  at  4°C.  If stored in  a
          refrigerator,  allow  agar plates to equilibrate to room  temperature

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before use.   Eighteen  hours prior  to  beginning a  bacteriophage
assay, prepare a bacterial host suspension by inoculating  5  nl  of
7YE broth with  a  snail  amount  of bacteria taken directly from  a
slant tube culture.  Incubate the broth containing  this  bacterial
inoculum overnight  (approximately  13  hours)  at  37°C  immediately
prior to  use  in bacteriophage  assays  as described  below.   This
type of  broth  culture  should be prepared freshly  for each  'day's
bacteriophage assays.  If  necessary,  a volume greater  than  5  inl
can be prepared in a similar manner.

On the day  of assay, melt  a sufficient  amount  of top  agar  and
maintain at 45°C in a water bath.  Place test tubes (13  x  100 mn)
in a rack in the same water bath and allow to warm, then add 3 ml
of top agar  to each  tube.   Inoculate the test  tubes containing
top agar  with  the  bacteriophage  samples  (0.5 to  1.0  ml  of  the
sample/tube) plus  0.1 to  0.2 ml  of the  overnight  bacterial  host
suspension.  Dilute the  bacteriophage  samples from  10*^  to 10'4
in salt  diluent  prior  to  inoculation  and assay  each  dilution in
triplicate.  In addition, assay  the  uninoculated salt diluent as
a negative control.  Agitate the test  tubes  containing  top  agar,
bacteriophage inoculum, and bacterial  host suspension gently on a
vortex mixer,  and   pour  the  contents  of  each  onto a  hardened
bottom agar  layer  contained in  an appropriately  numbered  dish.
Quickly  rock the Petri  dishes to spread the added material  evenly,
and place on  a  flat surface at  room  temperature  while the agar
present  in the  added  material   solidifies  (approximately  15 min-
utes).   Invert and incubate  the  dishes  at 37°C overnight  (approxi-
mately 13  hours).   The  focal   areas   of viral  infection  which
develop during this incubation are  referred  to as  "plaques" and,
if possible, should be enumerated immediatly after the incubation.
If necessary, the  incubated  Petri  dishes can  be refrigerated at
4°C overnight  prior  to  plaque  enumeration.   As  a  general  rule,
count only those plates that contain between  20  and 200 plaques.

-------
IV.   DISINFECTION PROCEDURE

     A.   The treatment plant  water  to  be  used  should  be  the water  influent
         into the chloramine disinfection unit process  used  in  the  plant.
         If chloramine disinfection is performed  at more than one  point  in
         the treatment process,  e.g.  prefiltration and  postfiltration, the
         procedure should simulate  as  closely  as  possible actual treatment
         practice.

     3.   Prepare stock ammonia and chlorine solutions  to be  added  to the
         treatment plant  water to achieve the same stoichiometric relation-
         ship between  chlorine  and  ammonia   that  is  used  in  the   water
         treatment plant;  These solutions should  be concentrated  enough
         so that no more than 2 ml  of each solution will be added  to the
         treatment plant  water being  disinfected.

     C.   Determine the contact time by the methods described in  the Surface
         Water Treatment   Rule  and/or  the  associated   Guidance  Manual.

     D.   Rinse two 600 ml beakers  with treatment  plant  water  to  remove any
         extraneous material  that  may cause disinfectant demand.  Then add
         400 ml   treatment  plant  water  to  the beaker.   The  first  beaker
         will  be  seeded  with MS2   before  the  contents   are chloraninated.
         The second beaker  will  be an  indigenous  virus control  and will
         be chloraninated without  addition of  extraneous phage.

     E.   Mix the contents of the beaker short  of  producing a  vortex  in  the
         center and  continue  until   the   conclusion  of  the  experiment.

     F.   Equilibrate the  600 ml beakers  and their contents as  well  as  the
         disinfectant reagents  to  the  desired   experimental   temperatjre.

     G.   Dilute the stock MS2 bacteriophage so that  the bacteriophage con-
         centration is 1  to 5 x  10s PF'J/ml.

     H.   Add 1.0 ml  of the diluted  MS2 bacteriophage  to  the contents  of  the
         first 600 ml  beaker.

     I.   Remove a 10 ml sample from the contents  of the first beaker after
         2  minutes  of mixing.   Assay the MS2 bacteriophage  concentration
         in this sample  within  4  hours and record the  results  as PFU/ml.
         This value is the initial  MS2 concentration.

     J.   Remove  a  10 ml   sample from  the  contents  of  the  second  beaker
         after 2  minutes  of mixing.   Assay  the  indigenous  bacteriophage
         concentration in this  sample within  4 hours (at the  same time  as
         you assay  the  sample  from   the  first   beaker)  and   record  the
         results as PFU/ml.  This  value is the initial  unseeded concentra-
         tion.

     K.   Add  the  disinfectant reagents  to the  contents of  both beakers
         using the  same  sequence,  time,  and  concentrations as are used in
         the actual treatment plant operations.

-------
L.  Just prior to the end of the contact  time, remove a volume of sam-
    ple adequate for  determination  of  the  disinfectant  residual  con-
    centration from  both  beakers.   Use  methods  prescribed  in  the
    Surface Jater  Treatment  Rule for  the  determination  of  combined
    chlorine.  This  residual   should  be  the  same  (t20%)   as   the
    residual present in the treatment plant operation.

M.  At the  end  of  the exposure time, remove a  10  ml  sample  from the
    first 500 ml beaker  and  neutralize  with 0.25 ml  of 1.0*  aqueous,
    sterile sodium   thiosulfate.   Assay   for  the  MS2  bacteriophage
    survivors and  record  the  results  as PFU/ml .  This value  is the
    exposed MS2 concentration.

N.  At the  end  of  the exposure time, remove a  10  ml  sample  from the
    second 500 ml beaker and neutralize with 0.25 ml of 1.0%  aqueous,
    sterile sodiu/n  thiosulfate.   Assay  for the  indigenous  bacterio-
    phage survivors and  record  the  results as PFU/ml .   This  value is
    the exposed unseeded concentration.
V.  PROCEDURE FOR
DETERMINING
                          INACTIVATION
A.  Calculation of Percentage Inactivation

    Use the following  formula to calculate  the  percent inactivation
    of MS2:

    1.  %  inactivation  =  130%  - [(exposed  MS2/initial MS2)  x  100]

    'Jsing values from Section  IV  steps  I, J,  M and N calculate initial
    MS2 and exposed MS2 as follows:

    2.  Initial MS2 (PFU/ml)  = I  - J.

    3.  Exposed MS2 (PF'J/ml)  = M - N.

    If the number of  PFU/ml  in exposed MS2  is  zero, i.e.,  no plaques
    are produced after assay of undiluted and diluted samples, use <1
    PFU/ml as  the value in the above formula.

5.  Comparison  of  Percentage Inactivation  to  Log^Q  of Inactivation

    68% inactivation is equivalent to 0.5 login, inactivation
    90% inactivation is equivalent to 1 log^n. inactivation
    99% inactivation is equivalent to 2 log^n. inactivation
    99.9% inactivation is equivalent to 3 log^n inactivation

-------
VI.   BIBLIOGRAPHY

     Adams, M.H.   Bacteriophages.  Interscience Pub!ishers, New York  (1959).

     American Public Health Association;  American Water  Works Association;
     'Jater Pollution Control  Federation.  Standard Methods  for the Examina-
     tion of Water and Wastewater. 16th ed.  (1985).

     Grabow, U.O.K. et al.   Inactivation of hepatitus A virus, other enter-
     ic viruses and  indicator  organises  in  water by  chlorination.  Water
     Sci. Techno!., 17:657 (1985)

     Jacangelo, J.D.; Qlivieri, V.P.; & Kawata,  K.   Mechanism of  inactiva-
     tion of microorganisms  by  combined  chlorine.   AWWARF Rept.,  Denver,
     CO (1987).

     Safe Drinking Water  Committee.   The disinfection of drinking water.
     In:   Drinking Water and Health,   National  Academy Press,   Washington,
     D.C., 2:5 (1980).

     Shah, P. & Me Garnish,  J.  Relative  resistance of poliovirus  1  and coli-
     phages *2 and T2 in water.   Appl. Microbiol. 24:658 (1972).

     'J.S. Environmental Protection Agency.   Guidance Manual  for Compliance
     with the  Filtration  and Disinfection Requirements  for  Public Water
     Systems Using Surface  Water  Sources.   Appendix'G.  U.S.  EPA, Office
     of Water, Criteria  and  Standards Division, Washington, D.C.  (1983).

     Ward, fl.R.;   Wolfe,  R.L.;   *  Olson,  S.H.   Effect of pH,  application
     technique, and chlorine-to-nitrogen  ratio on disinfectant  activity  of
     inorganic chloranines  with  pure  culture  bacteria.   Appl.  Environ.
     Microbiol .,  48:508 (1984).

-------
VII.   TECHNICAL CONTACTS;
          Donald Bernan
          Microbiological  Treatment Branch
          Risk Reduction Engineering Laboratory
          U.S. Environmental  Drotection Agency
          25 West Martin Luther King Drive
          Cincinnati,  Ohio  45268

          Phone: (513) 569-7235

          Christon J.  Hurst
          Microbiological  Treatment Branch
          Risk Reduction Engineering Laboratory
          U.S. Environmental  Protection Agency
          26 West Martin Luther King Drive
          Cincinnati ,  Ohio  45263

          "hone:  (513) 569-7331

-------
              G.3 DETERMINING CHLORINE  DIOXIDE  INACTIVATION
                     OF GIARDIA CYSTS AND VIRUS
Giardia Cvsts

      The basis for the  chlorine  dioxide  CT  values  for  Giardia  cysts  in
the Guidance Manual is given in Appendix F.I.2.  The CT  values are based
on data collected  mainly  at pH  7. Very little data was available at other
pHs.  A review of data  from  Hoff  (1986)  indicates  that  the disinfection
efficiency  of  chlorine  dioxide   for bacteria  and  viruses  increases
approximately 2 to 3 fold as  pH increases  from 7 to 9.  Data on which the
CT  values  in the  SWTR  are  based  indicate that at  25 C, £.  muris  cyst
inactivation CTs  were approximately  2 fold higher at pH 7  than  at  pH 9
(Leahy, 1985).  In addition,  the data also  indicate that  chlorine dioxide
efficiency  increases as  disinfectant concentration  increases within the
range studied.
      Because the  data on effects  of chlorine dioxide concentration and
water pH on Giardia cyst inactivation efficiency were very limited,  they
were not considered in calculating the Giardia cyst CT values in Appendix
E.  However, the  data suggest  that  site  specific  conditions, i.e. water
pH  and disinfectant  concentration,  can  have significant  effects  on
chlorine dioxide  effectiveness.   Therefore,   the option  of  allowing the
Primacy Agency  to consider  the use of  lower  CT  values  by individual
systems has been provided.
      This  approval  should  be based on  acceptable experimental  data
provided by the system.   The data should be collected using the protocol
provided in  Appendix  G-l for  determining Giardia cyst  inactivation  by
chloramine with appropriate changes  in Section IV A,  B, I  and  J to reflect
the use of chlorine dioxide rather than chloramines.  This procedure can
be used for any disinfectant  which can be prepared in an aqueous solution
and is  stable  over the  course of  the testing.  To  do  this, chloramine
should be  replaced with the test disinfectant in the above noted sections.
                                 G.3  -  1

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      Virus
      The basis for the chlorine dioxide CT values for virus  in  Appendix
F.2.2 consists of limited data  from Sobsey  (1988).  Because the pH 9 data
available were very limited, the CT values are based on the pH 6 data with
a  safety  factor  of 2  applied.   As indicated  previously, review  of data
from  a  number  of  studies  (Hoff,  1986)  shows  that  chlorine  dioxide
efficiency increases 2 to 3 fold as pH increases from 7 to  9.
      Because the virus CT values  for chlorine dioxide are very conserva-
tive and most systems  operate at water pHs  higher than those on which the
CT values are based, the option of allowing the Primacy Agency to consider
the use of lower CT values has  been provided.
      Th:   approval  should  be based  on  acceptable experimental  data
provided by the system.  The data should be collected using the protocol
provided in Appendix G.2  with  appropriate  changes  in Sections  I  A,l and
2 and IV A, B, D, K, and L to reflect the use of chlorine dioxide rather
                           «
than chloramines.  This procedure can be used for any disinfectant which
can be prepared  in an  aqueous  solution  and is stable over  the course of
the testing.   To do this,  chloramine  should be replaced  with  the test
disinfectant in the above noted sections.
 REFERENCES
 Hoff, J.C.  Inactivation  of Microbial Agents  By  Chemical  Disinfectant's,
 EPA/600/52-86/067, U.S. Environmental Protection Agency, Water Engineering
 Research Laboratory, Cincinnati, Ohio, September,  1986.
 Leahy, J.G.  Inactivation of Giardia  Mun's  Cysts  by Chlorine and Chlorine
 Dioxide.  Thesis, Department of Civil Engineering, Ohio State University,
 1985.
 Sobsey, M.D. Detection and Chlorine  Disinfection  of Hepatitis A Virus in
 Water.  CR813024, EPA Quarterly Report, Dec.  1988.
                                 G.3 - 2

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       G.4 DETERMING  OZONE  INACTIVATION OF GIARDIA CYSTS AND VIRUS

G.4.1  'BACKGROUND

      The  basis  for  the ozone CT  values  are given in Appendices  F.I.2
fGiardia cysts) and F.2.4 (Virus).  As indicated,  both sets of CT values
are based on limited  data and  because of this, the values established are
conservative and employ large safety factors.  In addition, the difference
between the way the laboratory experiments used to develop the CT values
and  how  ozone is  used in  water  treatment  presents  a  problem  with
translating the data  for field use.  The laboratory studies were conducted
using  steady  state  ozone  concentrations with  ozone continually  added
during the contact period.  In contrast, steady state ozone concentrations
are  not maintained  in  field  use.    Also,  the  effectiveness of  ozone
contactors used in field applications may vary from  each  other and from
the mixing  efficiencies applied  in the  laboratory experiments  used  to
establish the CT values.
      The net effect of  all of these differences  is  to  limit  the appli-
cability of the CT values in  the  SWTR and Guidance Manual  to  individual
systems.  Therefore,  the option of allowing the Primacy Agency to consider
the use of lower CT values  by individual  systems  has  been provided.
      This  approval  should  be based  on acceptable  experimental  data
provided by the^system.  In general, the  procedures provided in Appendix
G.I  for determining  Giardia  cyst  inactivation  and Appendix G.2  for
determining virus inactivation can be used.   However,  unlike chloramines
ozone is not a  stable disinfectant.  Because  of ozone's rapid dissipation,
a pilot study  must  be used  in  lieu of the batch system to demonstrate the
disinfection efficiency.   General  considerations  for conducting  pilot
studies to  demonstrate the disinfection ability  of  ozone or  any  other
unstable disinfectant are enumerated below.

G.4.2  GENERAL CONSIDERATIONS FOR PILOT  TEST
        A.  All microorganisms, reagents  and  media are prepared  as  in-
            dicated in sections G.I for Giardia and G.2 for virus.

                                 G.4-1

-------
         B.   The disinfectant should be prepared, measured and added to the
             test  water as it would  be added to  the  water at the  water
             treatment  plant.
         C.   Specific reactor design should be a function of the disinfec-
             tant  and  reflect  how the disinfectant is added at the  water
             treatment  plant.    Provisions  should be made to determine
             concentration  of  disinfectant  and  microbial  survival  to  be
             measured with  contact  time.

      An example of conducting a pilot test for a plug flow reactor  using
ozone or another unstable  disinfectant  is  provided below.

      Example - Plug Flow  Reactor  Protocol
      The size of the plug  flow  reactor can be approximated from the  table
below.  Glass, stainless steel,  copper,  plastic  tubing  or  other  material
compatible with the  disinfectant can be used to  construct  the plug flow
reactor.   Table  1  shows the approximate  length  of pipe for a plug flow
reactor  to  yield  10 minutes  contact at  flow rates  between  50 and  500
ml/nrin.  Depending on pipe size and material an economical  reactor can be
constructed.
         TABLE 1   APPROXIMATE LENGTH AND DIAMETER OF PIPE
                      BASED ON FLOW





LINEAR
PIPE. LENGTH. METERS
NOMINAL PIPE DIAMETER, CM
FLOW
ml/mi n
50
100
200
300
400
500
TIME
MIN
10
10
10
10
10
10
VOLUME
L 1 TE£S
0 5
1
2
3
4
5

cc
500
1000
2000
3000
4000
sooo
0 6
0 28
17 7
35 4
70 7
206 1
141. 5
176 I
1 2
1 31
4 4
8 t
17 7
26. 5
3S.4
44 2
1 8
2.54
2 0
3 9
7 9
11. (
15.7
19 6
2 54
5 07
1 0
2 0
3 9
5 9
7.9
9 9
3 81
11 40
0 4
0 9
1 1
2.6
3 5
4. 4
5 08
20 27
0 2
0 5
1 0
1.5
2 0
2.5
        Additional  information on the design of specific pilot studies can
be found in the following references  by Thompson (1982), Montgomery (1985),
and Al-Ani  (1985).

Additional  Materials  to those in G.I and/or G.2

plug flow  reactor
cyst suspension, 2xl07  cysts/trial
                                  G.4-2

-------
        cyst  quantity  - cysts are prepared as indicated in G.I.
        103 cysts/ml X 20,000 ml = 2xl07 cysts  required/trial
MS2 stock, 2xl010/trial
2-20 liter (5 gal) carboy
test water pump, mid range 200 ml/min
disinfectant generator
disinfectant pump, mid range 10-20 ml/min
disinfectant residual reagents and equipment

Test Procedure
A.      Reactor  conditions
        1.    Test Water Flow rate* 200 ml/min (this may vary from 50 to 500
             ml/min with  20 1  reservoir total  experimental  time* 100 min)
        2.    Disinfectant flow
             gas-requires specific contactor designed for disinfectant
             Liquid*10 to 20  ml/min
        3.    Temperature
             controlled
        4.    Prepare 20 liter reservoir  (5 gal) of test water at the pH and
             temperature  of the CT trial.  Do not add microorganisms
        5.    Prepare 20  liter  reservoir (5  gal)  of test water  and  equi-
             librate to the temperature  of the CT  trial.  Add Giardia muris
             cysts at  an  initial density of 103 cysts/ml and/or MS2 bacter-
             ial virus at an initial density of 10s  PFU/ml.  Mix thoroughly
             and adjust pH to the pH of the CT trial.  Continuous mixing of
             the test  water  feed  stock should be  carried  out over  the
             course of the  CT trial  to prevent  the Giardia cysts  from
             settling.
B.      Disinfection Procedure  - Prior to Disinfection Trial
        1.    Determine contact time for the sample ports in  the plug flow
             reactor under conditions  of the CT trial by methods described
             in the SWTR.
        2.    Determine disinfectant concentration with no microorganisms in
             the feed test water.
                                 G.4-3

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C.     CT Trial Procedure
       1.    Start test water feed without cysts and or  virus  (approx. 200
             ml/min),  start  disinfectant  feed  (gas  or liquid).
             Allow system to equilibrate.
             Monitor disinfectant residual by  appropriate  method during
             this  time.   Samples for disinfectant residual should  be  taken
             directly  into tubes or bottles containing reagents to fix the
             disinfectant at the time the  sample is collected.  Keep a plot
             of disinfectant residual  vs  running time to evaluate steady
             state conditions.
       2.    After the disinfectant residual has stabilized, switch to the
             reservoir containing  the  test  microorganism(s).
       3.    Allow system to equilibrate for  a time « 3 X final  contact
             time.
             example
             final contact time  =10 min,  allow 30 min.
       4.    Monitor disinfectant residual by appropriate method during
             this  time.    If the  disinfectant  residual  is stable  begin
             chemical  and biological  sampling  for calculation of  CT.
       5.    Sampling
             a.    Chemical
                   A  sufficient volume (about  250  ml  should  be collected
                   from the  sampling  tap  prior  to the biological composite
                   to determine:
                        pH
                        Residual disinfectant - Samples
                        should be collected directly
                        into tubes or bottles containing
                        reagents to fix the disinfectant
                        at the time the sample is collected.
             b.     Biological
                    Samples  for  microbial  analysis are collected as  short
                    time  composite samples over a  10  to 20  minute time
                    period.   Several  trials may  run for  a  given  20  liter
                    test water preparation as  long as sufficient equilibra-

                                  G.4-4

-------
            tion  and  flow  recovery  times  are  allowed  between
            trials.
              -  Zero time samples  should  be  collected as 250 ml
                 composite samples  either  directly  from the test
                 water feed reservoir or in line prior to the addi-
                 tion of the disinfectant.
              -  Four 250 ml  samples are collected separately into
                 a 2  1  sterile  bottle  containing  a  neutralizing
                 agent  for  the  particular  disinfectant.   Each
                 sample  is  thoroughly  mixed  upon  collection  and
                 stored at 4  C.   If multiple sample ports are used,
                 the order of collection should be from longest to
                 shortest contact time to minimize flow changes  due
                 to sampling.
6.    Giardia cyst recovery and assay.
      Concentrate  the  1000  ml  composite  sample  by  filtration
      according to the  method  given in  section  G.I.    Record  and
      report the data as  described  in  section G.I.   The  expected
      cysts/sample is given below:
      Cysts/sample =  4 x 250 ml X 103 cyst/ml  * Ixl08cyst/samp1e.
7.    Virus Assay
      Before  filtration  for  Giarcjia.   remove 10.0  ml  from  the
      biological  composite sample to  a sterile screw  cap  culture
      tube containing 2 to 3  drops chloroform.    Assay for  MS2,
      record and  report  the virus data according to the methods and
      procedures  described in G.2.   Be  sure to correct the Giardia
      sample volume to 990 ml.
8.    Calculation of  CT
      Calculate CT in a  manner  described in Section G.I for Giardia
      and Section G.2 for virus.  The  residual disinfectant should
      be the average  of  the four residual  determinations performed
      prior to the individual samples  collected for the biological
      composite and the  time should  be the time determined for the
      sample port under  similar flow conditions.
                          G.4-5

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REFERENCES


Al-Ani,  C.S.U.,  Filtration  of  Giardia  Cysts  and  other  substances:
Volume 3.  Rapid Rate Filtration (EPA/600/2-85/027) 1985.

Montgomery, James M.  Consulting  Engineers Inc., Water Treatment Principles
and Design. John Wiley and Sons, May 1982.

Wallis, P.M.,  Davies, J.S., Nuthonn, R.,Bichanin-Mappin, J.M., Roach, P.O.,
and Van  Roodeloon,  A.   Removal and Inactivation  of Giardia Cysts  in  a
Mobile Water Treatment Plant Under  Field Conditions:  Preliminary Results.
In Advances in Giardia Research. P.M. Wallis and B.R. Hammand, eds, Union
of Calgary Press, p. 137-144, 1989.

Wolfe, R.L., Stewart, M.H., Liange, S.L., and McGuire, M.J., Disinfection
of Model  Indicator Organisms in  a Drinking Water Pilot Plant  by Using
PEROXONE, Applied Environmental  Microbiology, Vol 55, 1989,  pp 2230-2241.

Olivieri, V.P. and Sykora,  J.L., Field and Evaluation of CT for Determining
the Adequacy  of  Disinfection.   American  Water Works Association Water
Quality Technology Conference.  In press, 1989.
                                  G.4-6

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              APPENDIX H

SAMPLING FREQUENCY FOR TOTAL COLIFORMS
      IN THE DISTRIBUTION SYSTEM

-------
                         TABLE H-l

           TOTAL COLIFORM SAMPLING REQUIREMENTS
                   BASED UPON POPULATION





Population
Served

1,
2,
3,
4,
4,
5,
6,
7,
8,
12,
17,
21,
25,
33,
41,
50,
25
001
501
301
101
901
801
701
601
501
901
201
501
001
001
001
001
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
Notes:
1.
1
2
3
4
4
5
6
7
8
12
17
21
25
33
41
50
59
,000
,500
,300
,100
,900
,800
,700
,600
,500
,900
,200
,500
,000
,000
,000
,000
,000
Minimum
Number

of Samples
Per Month11"*'-1'
1
2
3
4
5
6
7
8
9
10
15
20
25
30
40
50
60
Non-community systems ui
59
70
83
96
130
220
320
450
600
780
970
1,230
1,520
1,850
2,270
3,020
3,960
sing all or j




Population
Served
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
,001
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
or
70
83
96
130
220
320
450
600
780
970
1,230
1,520
1,850
2,270
3,020
3,960
more
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000

?art surface water
Minimum
Number
of Samples
Per Month
70
80
90
100
120
150
180
210
240
270
300
330
360
390
420
450
480
and community
systems'" oust monitor  total  colifora  at  this  frequency.   A  r.on-
community water  system  using  ground water  and serving 1,000 persons
or fewer must monitor quarterly,  beginning 5 years after the rule's
promulgation, although  this  can be reduced  to  yearly if a sanitary
survey shows no  defects.  A  non-community  water system serving mere
than 1,000 persons during any month, or a non-community water system
using surface water, must monitor at the  same  frequency as a like-
sized  community  public water  system  for  each  month   the  system
provides water to the public.

Unfiltered  surface  water systems  must analyze  one  coliform sample
each day the turbidity exceeds 1NTU.

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                              TABLE H-l

                TOTAL COLIFORM SAMPLING REQUIREMENTS
                  BASED UPON POPULATION (Continued)
3.    Systems collecting fewer than 5 samples per month on a regular basis
     must conduct sanitary surveys.  Community  and  non-community systems
     must conduct the initial  sanitary  surveys  within 5 and  10  years  of
     promulgation,  respectively.   Subsequent surveys  must be  conducted
     every 5 years, except for non-community systems  using protected  and
     disinfected  ground  water,  which  have  up   to  10  years  to  conduct
     subsequent surveys.

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                                   TABLE H-2




                    MONITORING AND REPEAT SAMPLE FREQUENCY
System Size
NCWS(1)
25 - 1,000
1,001 - 2,500
2,501 - 3,300
3,301 - 4,100
4,101 - 4,900
>4,900
# Routine
Samples
Quarterly (2)
Monthly (2)
2/mo
3 /mo
4/mo
5 /mo
Table 1
* Repeats
4
4
3
3
3
3
3
More Monitoring For
5 /mo for 1 additional
5/mo for 1 additional
5/mo for 1 additional
5/mo for 1 additional
5/mo for 1 additional
None
None
r.o
mo
mo
mo
mo


Notes;




     1.   Non-community Water systems.




     2.   For exceptions, see Table 1.

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      APPENDIX  I

 MAINTAINING REDUNDANT
DISINFECTION CAPABILITY

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                               APPENDIX I
                    REDUNDANT DISINFECTION CAPABILITY

      The SWTR  requires  that unfiltered  water  systems provide redundant
disinfection  components  to  ensure  the continuous  application  of  a
disinfectant  to the water  entering the distribution  system.    In  many
systems, both filtered and unfiltered, a primary disinfectant is used to
provide  the overall, inactivation/removal  and  a  secondary  residual  is
applied to maintain a residual in the distribution system.  As outlined in
Sections 3.2.4  and 5.5.4,  redundancy  of the disinfection  system(s)  is
recommended to  ensure that  the  overall  treatment requirement  of  3-1 og
Giardia  cyst  and  4-log  virus removal/inactivation  is  achieved, and  a
residual  is  maintained   entering  the  distribution   system.   This  is
particularly important for  unfiltered  supplies  where  the  only treatment
barrier is disinfection.  Redundancy of components is necessary to allow
for disinfection during  routine  repairs, maintenance  and  inspection and
possible failures.
      In  reviewing water  disinfection  facilities  for compliance  with
redundancy requirements,  the following items should be checked:

  I.  General
      A.    Are  the capacities   of  all components of both  the primary
            system  and  the  backup system equal  to or greater  than the
            required capacities?
            Some systems may have  two or  more  units that  provide the
            required dosage rates when all units are operating.  In these
            cases,  an  additional unit is needed as  backup,  during the
            downtime of any of the operating units.  The backup must have
            a capacity  equal to or  greater than that  of  the largest
            on-line unit.
      B.    Are adequate  safety  precautions being followed,  relative to
            the type of disinfectant being used?
      C.    Are redundant components  being  exercised  or  alternated  with
            the primary components?
      D.    Are all components being properly maintained?
      E.    Are  critical spare  parts on   hand  to repair  disinfection
            equipment?

                                   1-1

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      F.    Are spare parts available for components  that  are  indispens-
            ible for disinfecting the water?

 II.  Disinfectant Storage

      A minimum of  two storage units capable of being  used  alternately
should be  provided.   The  total  combined  capacity  of the storage  units
should provide as a minimum the system design capacity.
      A.    Chlorine
      Storage for gaseous chlorine will normally be in 150-lb  cylinders,
2,000-lb containers, or larger on-site storage vessels.
            1.    Is there automatic switchover equipment if one cylinder
                  or container empties or becomes inoperable?
            2.    Is  the  switching  equipment  in  good  working  order,
                  (manually tested on  a  regularly  scheduled basis),  and
                  are spare parts on hand?
            3.    Are the  scales  adequate for at  least  two  cylinders or
                  containers.

      B.    Hvoochlorite
      Storage of calcium hypochlorite or sodium hypochlorite is normally
provided in drums or other suitable containers.   Redundancy requirements
are not applicable to  these by themselves, as long as the required minimum
storage quantity is on hand at all times.
      C.    Ammonia
      An hydrous ammonia is usually stored in cylinders as a pressurized
liquid.  Aqua ammonia  is  usually stored as a  solution of ammonia and water
in a horizontal pressure vessel.
            1.    Is the available storage volume divided into  two or more
                  usable units?
            2.    Is automatic switching equipment  in  operation to change
                  over  from  one  unit  to another  when  one is  empty or
                  inoperable?
            3.    Are there spare  parts for the switching equipment?
                                   1-2

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 III.   Generation
       Ozone and chlorine dioxide are not  stored on-site.  Rather, because
 of their  reactivity, they are generated and used immediately.
       To  satisfy the redundancy  requirements for these disinfectants it is
 recommended that  two generating units, or  two  sets  of  units, capable of
 supplying the  required  feed rate be provided.  In systems where there is
 more than one  generation  system,  a  standby unit should be available for
 times  the on-line  units  need  repair.   The backup  unit should  have  a
 capacity  equal to or greater than the unit(s) it may replace.
       A.    Chlorine Dioxide
       Chlorine, sodium  chlorite, or sodium hypochlorite should be stored
 in accordance  with  storage guidelines previously described.
       B.    Ozone
       Are all  generation components  present and  in working order for both
 the primary and the redundant units (whether using air or oxygen)?
       C.    Common
       Is  switchover  and  automatic  start-up   equipment  installed  and
 operable  to change  from the  primary generating  unit(s) to the redundant
 unit(s)?

 IV.    Feed Systems
       Redundancy in feed systems requires two separate  units, or systems,
each capable of supplying the required dosage  of disinfectant.  If more
 than one  unit  is  needed to  apply  the required feed rate,  a spare unit
should be available to  replace any of the operating units during times of
malfunction.   The  replacement  unit should, therefore,  have a capacity
equal  to  or greater than  that of the largest unit which it may replace.
 This  requirement   applies to   all  disinfection  methods,   and is  best
 implemented by housing  the on-line  and  redundant components in separate
 rooms, enclosures, or areas,  as appropriate.
       In  reviewing these systems for redundancy,  the  following components
 should be checked:
       A.    Chlorine
            1.    Evaporators
            2.    Chlorinators
            3.    Injectors

                                   1-3

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       B.     Hvpochlorite
             1.    Mixing tanks and mixers
             2.    Chemical feed pumps and controls
             3.    Injectors

       C.     Ozone
             1.    Dissolution equipment,  including compressor and delivery
                  piping systems
       D.     Chlorine Dioxidg
             1.    Chlorine feed equipment
             2.    Sodium chlorite mixing and metering equipment
             3.    Day tank and mixer
             4.    Metering pumps
             5.    If a package C102 unit is used,  two must be  provided

       E.     Chloramination
             1.    Chlorine feed equipment
             2.    Ammonia feed equipment, including applicable equipment
                  for either:
                  a.    Anhydrous ammonia (gas)
                  b.    Aqua ammonia (solution)

  V.   Residual Monitoring

       The best method of monitoring a disinfection  facility for continuous
operation is by continuous recording equipment.  To improve reliability,
it is suggested that duplicate continuous monitors  are present for backup
in the event of monitor  failure.   However,  if there is a failure in the
monitoring  system for  indicating  that  a  continuous residual  is  being
maintained,  the SWTR allows systems to  take grab samples every four hours
for up to five days  during monitor repair.   For systems without 24 hour
staffing  it will  not  be practical to  take grab  samples and redundant
monitoring  equipment  is recommended.    Failure of continuous  monitoring
would  be  a violation  of  a  monitoring requirement,  not a treatment
requirement.
       A.     Chlorine
             1.    Does the facility have a continuous monitor for chlorine
                  residual at  the disinfection system site with an alarm
                                   1-4

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                  or  indicator to show when the monitor is not function-
                  ing?   For added assurance,  the provision of  a  backup
                  monitoring unit is also recommended.

            2.    Is  there  instrumentation  in  place to  automatically
                  switch  from one monitor  to  the other if the first one
                  fails?
      B.    Hvpochlorite

      Same as for chlorine system.

      C.    Ozone

            1.    Does the facility have a continuous ozone monitor with
                  automatic switchover capability and alarms?

            2.    Does  the facility  have a  continuous  ozone  residual
                  monitor with automatic switchover capability and alarms?


      D.    Chlorine Dioxide

            1.    Does the  facility have a  continuous  chlorine dioxide
                  monitor with automatic switchover capability and alarms?

            2.    Does the  facility have a  continuous  chlorine dioxide
                  residual monitor  with  automatic switchover capability
                  and alarms?


      E.    Chloramination

            1.    Does the facility  have a continuous ammonia  monitor with
               _  automatic switchover capability and alarm?

            2.    Does  the  facility  also  have  a  continuous  chlorine
                  residual  monitor  on-site   with  automatic  switchover
                  capability and alarms?


 VI.  Power Supply

      A permanently installed  standby  generator,  capable of running all

electrical  equipment   at  the  disinfection  station, and equipped  for

automatic start-up on power failure, should be on-site and functional.

      Alternatives  to  a  standby generator,  such  as a feed  line  from a

different power source, are acceptable if they can be shown to have equal

reliability.
                                   1-5

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VII.  Alarms
      Indicators and alarms, both local and remote,  should be capable of
promptly   alerting   operating   and   supervisory   personnel   of  problem
conditions.
      A.    Local
      Lights, buzzers,  and  horns  should  be  installed  and  functioning to
alert on-site personnel to problem conditions.
      B.    Remote
      Alarm signals should be relayed to  a central control  panel which is
manned 24 hours per day and  whose  operators can notify response personnel
immediately.
      C.    Problem Conditions
      A minimum  list of problem conditions  which should have indicators
and alarms,  both locally and at  a  24-hour per  day switchboard,  are as
follows:
            1.    Disinfectant  leak
            2.    Feeder pump failure
            3.    Power outage
            4.    Generator or  alternate power source on
            5.    Disinfectant  residual less than setpoint value

VIII.  Facility Layout
      Maximum reliability is ensured when  redundant  units are separated
from primary unfts.  The type of separation should be appropriate to the
type of potential malfunction.   For example,  any area within a building
subject to a chlorine leak should have primary components  separated from
redundant  components by an  airtight enclosure,  i.e.,  separate rooms of
varying sizes.

 IX.  Separate Facility
      Under  certain conditions,  such  as  location   of  a  disinfection
facility in an area of  high  earthquake potential, the most reliable means
of  providing  redundant facilities may be to  house them in a completely
separate structures at  a different  site.
                                   1-6

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        APPENDIX J



WATERSHED CONTROL PROGRAM

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                               APPENDIX J
                        WATERSHED CONTROL  PROGRAM

      The  following  is  a guideline for documenting a watershed  control
program.    The  SWTR  only  requires  a watershed  control  program  for
unfiltered  supplies.   A  watershed  control  program can  also benefit  a
filtered system by providing protection for maintaining  the source water
quality, minimizing  the  level of  disinfection to be provided.    It  is
therefore  recommended that  all  systems conduct the basic  elements  of  a
watershed  control  program.    However,  the scope  of  the  program  should
increase as the  complexity  and size of the  watershed/ system increases.
The program could  be  more or less comprehensive than this  outline,  and
will be determined on a  case-by-case basis by the utility and the Primacy
Agency.    In  addition  to the  guidelines below,  a wellhead  protection
program could  be the  basis of  a watershed control program in many states.
All of  the elements  found below  would also be part of a  local  wellhead
protection program.
      A.    Watershed Description
            1.    Geographical  location and  physical  features  of  the
                  watershed.
            2.    Location  of  major components of  the  water system  in
                  relationship to the watershed.
            3.~   Hydrology:  Annual precipitation patterns, stream flow
                  characteristics,  etc.
            4.    Agreements and delineation of land use/ownership.
      B.    Identification of the Watershed Characteristics
            and Activities Detrimental to Water Quality
            1.    Naturally Occurring:
                  a.     Effect of precipitation,  terrain,  soil types and
                        land cover
          *
                  b.     Animal populations  (describe) --  include  a dis-
                        cussion of  the Giardia contamination potential,
                        any other microbial contamination transmitted by
                        animals
                                   J-l

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            Other - any  other  activity which can  adversely
            affect water quality
2.    Man-Made:
      a.    Point sources of contamination such as wastewater
            treatment plant, industrial discharges, barnyard,
            feedlots, or private septic  systems

      The  impact  of  these  sources  on  the  microbiological
      quality of the  water  source  should be evaluated.   In
      cases  resulting  in  identifiable  degradation,   the
      discharges should be eliminated in  order to minimize the
      treatment of the water needed.

      b.    Nonpoint Source  of Contamination:

            1)     Road construction - major  highways,  rail-
                  roads

            2)     Pesticide  usage

            3)     Logging

            4)     Grazing  animals

            5)     Discharge  to ground water  which  recharges
                  the surface  source

            6)     Recreation activities

            7)     Potential  for unauthorized activity in the
                  watershed

            8)     Describe any  other  human  activity  in  the
                  watershed  and its potential impact on water
                  quality

      It should be noted that grazing animals  in the watershed
      may  lead  to  the  presence of  Crvptosporidium  in  the
      water.  Crvptosporidium is a pathogen  which may result
      in a  disease outbreak upon ingestion.  No information is
      available on  its resistance  to  various disinfectants,
      therefore it is recommended that grazing should not be
      permitted  on  watersheds  of  non-filtering  systems.
      Sewage discharges will introduce viruses into the water
      source which  may  be  occluded in  solids  and protected
      from inactivation through disinfection.  It is, there-
      fore, recommended that sewage discharges should not be
      permitted within watersheds of non-filtering supplies.
      Although it is preferable to  not have grazing or sewage
      discharges within the watershed, Primacy Agencies will

                       J-2

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            need to evaluate  the  impact  of these activities on  a
            case-by-case basis.   In cases where  there is  a  long
            detention time  and a high degree of dilution between the
            point of the activity and the water intake, these activ-
            ities may be permissible for  unfiltered  supplies.   The
            utility should  set priorities to address the impacts in
            B.I. and 2.,  considering their health  significance  and
            the ability to  control  them.
C.    Control of Detrimental  Activities/Events

      Depending on the activities occurring  within  the  watershed,
      various  techniques  could  be used  to eliminate or  minimize
      their effect.   Describe what  techniques  are  being used  to
      control the  effect of activities/events  identified  in B.I. and
      2. in its yearly report.

      Example:

            Activity;  Logging in the watershed.

            Management Decision;  Develop program to minimize impact
            of logging.

            Procedure; Establish agreements with logging companies
            to  maintain   practices   which  will  minimize  adverse
            impacts  on water  quality.    These  practices  should
            include:

                  limiting access to  logging  sites
                  ensuring cleanup of sites
                  controlling erosion from site.

            Monitoring;   Periodically  review  logging  practices  to
            ensure they are  consistent with  the agreement between
            the utility and the  logging companies.

      Example:

            Activity;    Point sources   of  discharge  within  the
            watershed.

            Management Decision;   Eliminate  those  discharges  or
            minimize their impact.

            Procedures;   Actively participate  in  the  review  of
            discharge permits to alert the reviewing agency of the
            potential  (actual) impacts of  the discharge and lobby
            for its elimination  or strict control.
                             J-3

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            Monitoring:     Conduct  special  monitoring  to  ensure
            conditions of the permit are met and to document adverse
            effects on water quality.
D.    Monitoring
      1.     Routine:  Minimum specifications for monitoring several
            raw water quality parameters are listed in  Section  3.1.
            Describe  when,  where and  how these  samples  will  be
            collected.    These  results  will  be  used  to  evaluate
            whether  the  source may  continue  to  be  used  without
            filtration.

      2.     Specific:  Routine  monitoring  may  not provide  informa-
            tion about  all  parameters of interest.  For example,  it
            may be valuable to conduct  special  studies  to measure
            contaminants  suspected of being present (Giardia. pesti-
            cides,  fuel products, enteric viruses, etc.).  Frequent
            presence  of  either Giardia  or enteric viruses  in  raw
            water samples prior to disinfection  would  indicate  an
            inadequate  watershed control program.  Monitoring  may
            also be useful  to assess  the effectiveness of  specific
            control techniques, and to  audit  procedures or opera-
            tional  requirements  instituted within the  watershed.
            Utilities are encouraged to conduct additional  monitor-
            ing as  necessary to aid them in controlling the quality
            of the source water.

E.     Management/Operations

      1.     Management

         .,  a.    Organizational  structure
            b.    Personnel and education/certification requirements

      2.     Operations

            a.    Describe system operations and design flexibi 1 ity.
            b.    The utility should  conduct  some  form of ongoing
                  review or survey in  the watershed to identify and
                  react to potential  impacts on water quality.  The
                  scope  of  this  review  should  be documented  and
                  agreed upon by the utility and Primacy Agency on
                  a case-by-case basis.

            c.    Specifically  describe  operational  changes which
                  can be made to adjust for changes in water quali-
                  ty.   Example:   Switching to  alternate sources;
                  increasing  the  level  of  disinfection;  using
                             0-4

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                  settling basins.   Discuss what  triggers,  and  who
                  decides to make,  those changes.

      3.    Annual Report:   As  part of the watershed program,  an
            annual report should be submitted to the Primacy Agency.
            The contents of the report should:

            a.    Identify special  concerns  that  occurred  in  the
                  watershed  and  how  they  were  handled  (example:
                  herbicide usage,  new construction,  etc.).

            b.    Summarize other activities in  the watershed such
                  as logging,  hunting,  water quality  monitoring,
                  etc.

            c.    Project what adverse  activities  are  expected to
                  occur in the future and describe how the utility
                  expects to address them.

F.    Agreements/Land Ownership

      The goal of a watershed management program is to achieve  the
      highest  level  of  raw  water  quality  practicable.   This  is
      particularly critical to an unfiltered surface supply.

      1.    The utility  will  have  maximum opportunity  to  realize
            this  goal   if  they  have  complete  ownership  of  the
            watershed.   Describe efforts to obtain ownership, such
            as  any  special  programs or  budget.    When  complete
            ownership of  the watershed is not  practical,  efforts
            should be taken to gain  ownership of critical elements,
            such as,  reservoir or stream shoreline, highly erodable
            land,  and access areas  to water system facilities.

      2.    Where  ownership  of land  is  not  possible,  written
            agreements should be obtained recognizing the watershed
            as part of a public water supply.   Maximum flexibility
            should be  given  to the  utility  to control  land uses
            which could  have  adverse  effect on  the water,quality.
            Describe such agreements.

      3.    Describe how the utility  ensures  that  the  landowner
            complies with these agreements.
                             J-5

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  APPENDIX K



SANITARY SURVEY

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                               APPENDIX K

                             SANITARY  SURVEY


      The SWTR requires that an  on-site  inspection be conducted each year

as  outlined  in  Section 3.   It  is  recommended  that  at  the onset  of

determining the classification of a  source water that a detailed sanitary

survey  be  conducted.    In  addition,  it  is  recommended that  a  sanitary
survey such as contained in this appendix be conducted every 3 to 5 years

by both filtered and unfiltered  systems  to ensure that the quality of the

water and service is, maintained.  This time period is suggested since the

time  and  effort  needed to  conduct the comprehensive  survey makes  it
impractical for it to be conducted annually.   A periodic  sanitary survey

is  also  required  under the  Total  Coliform  Rule for systems  collecting

fewer than 5 samples/month.   The  survey must  be  conducted  every  5 years

for all  systems  except for protected ground water systems which disinfect.

These systems must conduct the survey every  10 years.

      The sanitary survey  involves  three phases,  including  planning the

survey,  conducting  the survey  and compiling  the final  report   of the

survey,  as will  be presented in the following pages.

      1.    Planning the Survey

            Prior to conducting or  scheduling a sanitary  survey,  there
            should be  a detailed review of  the  water system's  file  to
            prepare for the survey.   The  review should pay  particular
            attention to past sanitary survey reports  and correspondence
            describing previously identified problems and their solutions.
            These should be noted,  and action/inaction  regarding these
            problems should be specifically verified in the field.  Other
            information to  review includes:   any other  correspondence,
            water  system  plans,  chemical  and microbiological  sampling
            results, operating  reports,  and  engineering  studies.   This
            review will  aid in the familiarization with the system's past
            history and  present  conditions,  and the agency's past interac-
            tions with the system.

            The initial  phase of the water quality review will be carried
            out  prior to conducting the survey as well,  and will  consist
            of reviewing the water system's  monitoring  records.   Records
            should be reviewed for compliance with all applicable microbi-
            ological, inorganic  chemical, organic chemical, and radiologi-
            cal   contaminant  MCLs,  and  also  for  compliance  with  the
            monitoring  requirements for those contaminants.   The survey


                                  K-l

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      will provide an opportunity to review these records with the
      utility, and to  discuss  solutions to any  MCL  or monitoring
      violations.  The survey will  also provide  an  opportunity to
      review  how  and where samples  are collected,  and  how field
      measurements (turbidity, chlorine residual,  fluoride, etc.)
      are made.  Points to cover include:

      a.    Is the system  in  compliance with all  applicable MCLs
            (organic chemical, inorganic chemical, microbiological,
            and radiological)?

      b.    Is the system in compliance with all monitoring require-
            ments?

      The pre-survey  file  review  should  generate  a list of items to
      check in the field,  and a list of  questions about the system.
      It will  also help  to plan the  format  of the survey  and to
      estimate how much time it may  take.   The next step is to make
      the initial contact with the  system  management  to establish
      the survey date(s)  and time.   Any records,  files,  or people
      that will be referenced during the survey should be mentioned
      at the outset.  Clearly laying out the intent of the survey up
      front will  greatly  help  in  managing  the  system,  and will
      ensure that the survey goes smoothly without a need for repeat
      trips.

2.    Conducting the Survey

      The on-site portion of the survey is the most important and
      will  involve  interviewing  those  in  charge of  managing  the
      water system as  well as  the  operators and  other technical
      people.  The survey  will  also review all  major system compo-
      nents  from  the  source(s)  to  the distribution  system.    A
      standard form  is frequently used  to ensure that  all major
      components  and  aspects  of   each system  are  consistently
      reviewed.  However,  when in the field,  it is best to have an
      open-jnind and  focus  most  attention  on the specifics  of the
      water system,  using the form  only as a guide.   The surveyor
      should  be certain to be on time  when  beginning the survey.
      This consideration  will help get the survey started smoothly
      with the operator and/or manager.

      As the  survey  progresses,  any deficiencies that are observed
      should  be   brought  to  the attention  of  the  water   system
      personnel,  and the problem  and  the corrective measures  should
      be discussed.  It is far better to clarify technical details
      and solutions while  standing next  to  the problem than it is to
      do so over the telephone.   Points to cover include:

      a.    Is the operator  competent  in performing the necessary
            field testing for operational  control?
                             K-2

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b.    Are testing facilities  and  equipment  adequate,  and do
      reagents used have an unexpired shelf life?

c.    Are field and  other analytical  instruments properly and
      regularly calibrated?

d.    Are records  of field  test  results and  water  quality
      compliance monitoring results being maintained?

e.    Conduct any sampling which will be part of the survey.

Also, detailed notes of  the  findings  and conversations should
be taken so that the report  of the  survey will be an accurate
reconstruction of the survey.

Specific components/features of  the system to review and some
pertinent questions to ask are:

Source Evaluation

All of the elements for a source evaluation enumerated below
may also be part of a Wellhead Protection Program.

      1.    Description:   based  on  field  observations  and
            discussion with the operator,  a general  charac-
            terization  of  the  watershed   should  be  made.
            Features which could be included in the descrip-
            tion are:

            a.    Area of watershed or recharge area.

            b.    Stream flow.

            c.    Land  usage (wilderness,  farmland,  rural
                  housing,  recreational,  commercial,  indus-
                  trial, etc.).

            d.    Degree of  access by the public to watershed.

            e.    Terrain and soil type.

            f.    Vegetation.

            g.    Other.

      2.    Sources  of   contamination  in  the  watershed  or
            sensitive areas surrounding wells or well fields
            should  be identified.   Not only should  this be
            determined  by  physically touring  and  observing
            the watershed and its  daily  uses, but the survey-
            or should also actively question the water system
            manager  about  adverse  and  potentially  adverse

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activities in the watershed.  An example of types
of contamination includes:
a.    Man Made.
      1.    Point  discharges  of sewage,  storm-
            water,  and other wastewater.
      2.    On-site  sewage  disposal  systems.
      3.    Recreational   activities  (swimming,
            boating,  fishing,  etc.).
      4.    Human  habitation.
      5.    Pesticide usage.
      6.    Logging.
      7.    Highways  or  other roads  from  which
            there  might be  spills.
      8.    Commercial  or industrial activity.
      9.    Solid  waste or other disposal facili-
            ties.
     10.    Barnyards,   feed  lots,   turkey  and
            chicken  farms and other concentrated
            domestic  animal  activity.
     11.    Agricultural  activities  such as graz-
            ing,  tillage,   etc.,  which  affects
            soil erosion, fertilizer usage, etc.
    12.     Other.
b.    Naturally Occurring.
      1.    Animal populations,  both domestic and
            wild.
      2.    Turbidity fluctuations  (from precipi-
            tation,  landslides,  etc.).
      3.    Fires.
      4.    Inorganic  contaminants  from  parent
            materials  (e.g., asbestos fibers).
      5.    Algae blooms.

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            6.    Other.
            This  list  is  by  no  means all  inclusive.
            The surveyor should rely principally on his
            observations   and   thorough   questioning
            regarding  the  unique  properties  of  each
            watershed to completely describe what  may
            contaminate the  source water.
3.    Source Construction.
      a.    Surface Intakes.
            1.    Is the  source  adequate  in quantity?
            2.    Is the best quality source or  loca-
                  tion in  that source  being used?
            3.    Is the  intake  protected  from  icing
                  problems if appropriate?
            4.    Is  the  intake  screened to  prevent
                  entry of   debris,  and  are  screens
                  maintained?
            5.    Is animal  activity controlled within
                  the immediate vicinity of the  intake?
            6.    Is there a raw water sampling tap?
      b.    Infiltration  Galleries.
            1.    Is the  source  adequate  in quantity?
            2.    Is the best quality source being used?
            3.    Is the  lid over the gallery  water-
                  tight and  locked?
            4.    Is the collector  in sound  condition
                  and maintained as necessary?
            5.    Is there a raw water sampling tap?
      c.    Springs.
            1.    Is the source adequate  in quantity?
            2.    Is there adequate protection  around
                  the spring such  as fencing to  control
                  the area within 200  feet?
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3.    Is  the  spring  constructed  to  best
      capture the spring flow  and  exclude
      surface water infiltration?

4.    Are there  drains  to divert  surface
      water  from  the  vicinity   of   the
      spring?

5.    Is the collection  structure  of sound
      construction with  no leaks or cracks?

6.    Is  there   a screened  overflow  and
      drain pipe?

7.    Is  the  supply  intake  located  above
      the floor and screened?

8.    Is there a raw water sampling tap?

Catchment and Cistern.

1.    Is source adequate in  quantity?

2.    Is the cistern of  adequate size?

3.    Is the catchment area  protected  from
      potential  contamination?

4.    Is  the  catchment  drain   properly
      screened?

5.    Is the catchment area  and cistern of
      sound construction and  in good condi-
      tion?

6.    Is catchment constructed  of  approved
      non-toxic,  non-leaching material?

7.    Is the cistern protected from contam-
      ination -- manholes,  vents,  etc?

8.    Is there a raw water tap?

Other Surface Sources.

1.    Is the source adequate in quantity?

2.    Is  the  best  possible source  being
      used?

3.    Is  the  immediate vicinity  of  the
      source protected from contamination?

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            4.    Is  the  structure in good  condition
                  and properly constructed?

            5.    Is there a raw water sampling tap?

4.    Pumps, Pumphouses, and Controls.

      a.    Are  all  intake  pumps,  booster pumps,  and
            other pumps of sufficient capacity?

      b.    Are all pumps and controls operational  and
            maintained properly?

      c.    Are  check  valves,  blow off  valves,  water
            meters and other appurtenances operated and
            maintained properly?

      d.    Is emergency  power backup with  automatic
            start-up  provided  and  does  it work  (try
            it)?

      e.    Are  underground compartments  and  suction
            wells waterproof?

      f.    Is the  interior  and  exterior of  the pump-
            house  in  good   structural  condition  and
            properly maintained?

      g.    Are there any  safety hazards  (electrical or
            mechanical) in the pumphouse?

      h.    Is  the  pumphouse  locked  and  otherwise
            protected against vandalism?

      i.    Are water production records  maintained at
            the pumphouse?

5.    Watershed  Management  (controlling  contaminant
      sources):  The  goal of the watershed management
      program  is  to identify  and  control  contaminant
      sources  in  the watershed  (see  Section 3.3.1  of
      this  document,  "Watershed  Control  Program").
      Under ideal conditions each source  of contamina-
      tion  identified  in  2  will  already have  been
      identified  by the  utility,  and some  means  of
      control  instituted,  or  a  factual  determination
      made that  its  impact  on  water  quality  is insig-
      nificant.   To  assess the degree  to which  the
      watershed  management   program  is  achieving  its
      goal, the  following types  of inquiries  could be
      made:
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            a.     If the watershed is not entirely owned  by
                  the utility,  have written agreements  been
                  made with other land owners to control  land
                  usage to the satisfaction of  the utility?
                  Are  appropriate  regulations  under   the
                  contract  of  state/local  department   of
                  health in  effect?

            b.     Is the utility making  efforts  to  obtain  as
                  complete ownership  of  the  watershed  as
                  possible?   Is effort  directed to  control
                  critical elements?

            c.     Are there  means  by which the  watershed  is
                  regularly   inspected  for  new  sources  of
                  contamination  or trespassers where  access
                  is limited?

            d.     Are  there  adequately  qualified  personnel
                  employed by  the utility  for  identifying
                  watershed  and water  quality problems  and
                  who are given the responsibility to  correct
                  these problems?

            e.     Are  raw  water  quality  records kept  to
                  assess trends  and to assess the  impact  of
                  different  activities  and contaminant  con-
                  trol techniques  in  the watershed?

            f.     Has  the  system  responded  adequately  to
                  concerns  expressed  about  the  source  or
                  watershed  in  past  sanitary  surveys?

            g.     Has the  utility  identified  problems  in its
                  yearly watershed control  reports,  and  if
                  so,  have  these  problems  been  adequately
                  addressed?

            h.     Identify what other agencies  have  control
                  or jurisdiction  in the watershed. Does the
                  utility  actively interact with these agen-
                  cies to  see that their policies or  activi-
                  ties are consistent with the utility's goal
                  of maintaining high raw water quality?
B.    Treatment Evaluation

      1.    Disinfection.
            a.    Is the disinfection equipment and disinfec-
                  tant   appropriate   for  the   application
                  (chloramines,  chlorine, ozone, and chlorine

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      dioxide  are  generally accepted  disinfec-
      tants)?

b.    Are  there back-up  disinfection  units  on
      line  in  case  of  failure,   and  are  they
      operational?

c.    Is  there auxiliary  power with  automatic
      start up  in  case of power outage?   Is it
      tested  and  operated  on  a regular  basis,
      both with and without load?

d.    Is there an adequate quantity of disinfec-
      tant  on hand  and  is  it properly  stored
      (e.g.,  are  chlorine  cylinders  properly
      labeled and chained)?

e.    In the  case of gaseous chlorine,  is there
      automatic switch  over equipment when cylin-
      ders expire?

f.    Are critical  spare parts  on hand to repair
      disinfection equipment?

g.    Is disinfectant feed proportional  to water
      flow?

h.    Are  daily  records   kept  of  disinfectant
      residual near the first customer from which
      to calculate CTs?

i.    Are production records kept  from  which to
      determine CTs?

j.    Are CTs  acceptable  based on the  level  of
      treatment  provided   (see   Surface   Water
      Treatment   Rule   for  CT   values,   and
      Sections 3 and 5 of  this  guidance  manual
      for calculation of CT).

k.    Is a  disinfectant residual  maintained  in
      the distribution  system,  and  are  records
      kept of daily measurements?

1.    If  gas  chlorine is used,  are  adequate
      safety  precautions  being  followed  (e.g.,
      exhaust fan with  intake  within six inches
      of  the  floor,  self-contained  breathing
      apparatus that  is regularly tested, regular
      safety  training  for  employees,   ammonia
      bottles  and/or automatic  chlorine  detec-
      tors)?   Is  the system adequate to ensure

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                  the  safety  of  both  the  public  and  the
                  employees in the event of  a  chlorine leak?
      2.    Other.

            a.     Are other treatment processes  appropriate
                  and are  they  operated to produce  consis-
                  tently high  water quality?

            b.     Are  pumps,  chemical  feeders,  and  other
                  mechanical  equipment in  good  condition and
                  properly maintained?

            c.     Are controls and  instrumentation  adequate
                  for the  process,  operational, well  main-
                  tained and  calibrated?

            d.     Are accurate records maintained (volume of
                  water  treated,  amount  of  chemical  used,
                  etc.)?

            e.     Are adequate supplies of chemical  on hand
                  and properly stored?

            f.     Are adequate safety devices  available and
                  precautions  observed?

            Sections  of  a sanitary  survey  pertaining  to
            systems  containing  filtration  facilities  have
            been omitted,  as  this  section  of  the  guidance
            document pertains  to non-filtering  systems.

C.    Distribution  System Evaluation

      After water  has been treated,  water  quality  must  be
      protected  and  maintained   as   it  flows  through  the
    ^  distribution  system to the customer's tap.  The follow-
      ing questions pertain to the water  purveyor's ability to
      maintain  high water quality during  storage and distribu-
      tion.

      1.    Storage.

            a.     Gravity.

                  1.    Are storage  reservoirs  covered and
                        otherwise  constructed   to   prevent
                        contamination?

                  2.    Are all  overflow lines, vents, drain-
                        lines, or cleanout pipes  turned down-
                        ward and screened?

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 3.     Are all reservoirs inspected regular-
       ly?

 4.     Is  the  storage  capacity  adequate  for
       the system?

 5.     Does the  reservoir  (or  reservoirs)
       provide sufficient pressure through-
       out the system?

 6.     Are surface  coatings within the  res-
       ervoir  in  good  repair  and acceptable
       for potable  water contact?

 7.     Is  the  hatchcover for the tank water-
       tight and  locked?

 8.     Can the reservoir be  isolated  from
       the system?

 9.     Is  adequate  safety equipment  (caged
       ladder, OSHA approved safety  belts,
       etc.) in place  for climbing the tank?

10.     Is  the  site fenced,  locked,  or other-
       wise protected  against vandalism?

11.     Is  the  storage  reservoir disinfected
       after repairs are made?

12.     Is   there  a  scheduled  program   for
       cleaning storage reservoir sediments,
       slime on floor  and side  walls.

 Hydropneumatic.

 1,     Is  the  storage  capacity  adequate  for
       the system?

 2.     Are instruments, controls, and equip-
       ment adequate,  operational, and main-
       tained?

 3.     Are the interior and  exterior surfac-
       es  of the  pressure tank  in  good  con-
       dition?

 4.     Are tank supports structurally sound?

 5.     Does the low pressure  cut in provide
       adequate  pressure  throughout   the
       entire  system?

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            6.    Is  the  pump  cycle rate  acceptable
                  (not more than 15 cycles/hour)?

2.    Cross Connections.

      a.    Is the  system  free of  known  uncontrolled
            cross connections?

      b.    Does the  utility  have a cross  connection
            prevention program, including annual  test-
            ing of backflow prevention  devices?

      c.    Are backflow prevention  devices  installed
            at all  appropriate locations  (wastewater
   ;         treatment  plant,   industrial   locations,
            hospitals, etc.)?

3.    Other.

      a.    Are proper pressures  and flows  maintained
            at all  times of the year?

      b.    Do all  construction materials meet AWWA or
            equivalent standards?

      c.    Are  all  services  metered  and are  meters
            read?

      d.    Are  plans for  the system  available  and
            current?

      e.    Does the  system have  an adequate mainte-
            nance program?

                  Is there  evidence of  leakage  in  the
                  system?

                  Is there  a pressure testing program?

                  Is there  a regular flushing program?

                  Are  valves   and  hydrants  regularly
                  exercised and maintained?

                  Are AWWA  standards for disinfection
                  followed  after all repairs?

                  Are  there  specific  bacteriological
                  criteria   and limits   prescribed  for
                  new line  acceptance or following line
                  repairs?
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                        Describe the corrosion control  pro-
                        gram.

                        Is  the  system  interconnected  with
                        other  systems?

D.    Management/Operation

      1.     Is there an  organization that  is  responsible for
            providing the  operation, maintenance,  and manage-
            ment of the  water  system?

      2.     Does the utility regularly summarize both current
            and long-term  problems identified in their water-
            shed, or other  parts  of the system,  and  define
            how they intend to  solve the problems  i.e.,  is
            their  planning  mechanism   effective;   do  they
            follow through with  plans?

      3.     Are customers  charged user fees  and  are collec-
            tions satisfactory?

      4.     Are  there  sufficient  personnel  to operate  and
            manage the system?

      5.     Are personnel  (including management)  adequately
            trained, educated, and/or certified?

      6.     Are operation  and maintenance manuals  and manu-
            facturers technical specifications readily avail-
            able for the system?

      7.     Are  routine preventative maintenance  schedules
            established  and  adhered  to  for all  components of
            the water system?

      8.     Are sufficient tools,  supplies,  and  maintenance
            parts on hand?

      9.     Are sufficient operation and maintenance records
            kept and readily available?

     10.     Is an  emergency plan  available  and  usable,  and
            are employees  aware  of it?

     11.     Are all facilities free  from safety defects?

      When the survey is completed, it is always preferable to
      briefly summarize the survey with the  operator(s)  and
      management.  The main  findings of  the survey  should be
      reviewed so  it  is clear that  there are  not  misunder-
      standings about findings/conclusions.   It is  also good

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            to thank  the utility for  taking  part in  the  survey,
            arranging  interviews with  employees,  gathering  and
            explaining their records, etc.  The information and help
            which  the utility  can  provide an   invaluable  to  a
            successful survey,  and every attempt  should be  made to
            continue a positive relationship with the system.

3.    Reporting the Survey

      A final report of  the  survey should  be completed as  soon as
      possible to formally notify the system and  other agencies of
      the findings.  There is no  set or necessarily best format for
      doing so,  and  the  length of the  report  will depend  on  the
      findings of  the  survey and size  of  the  system.   Since  the
      report may be used  for future compliance  actions and  inspec-
      tions, it  should include as a  minimum:  1)  the  date  of  the
      survey; 2)  who was  present  during the survey; 3) the findings
      of the survey; 4) the recommended improvements  to identified
      problems;  and 5)  the dates for completion of any improvements.
      Any differences between the findings discussed at the  conclu-
      sion of the  survey and what's  included in  the  final  report
      should be discussed and clarified with the  utility prior to
      sending out  the  final  report.   In other words,  the  utility
      should be  fully  aware of  the  contents of  the  final  report
      before receiving it.
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        APPENDIX L
SMALL SYSTEM CONSIDERATIONS

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                               APPENDIX L
                       SMALL SYSTEM CONSIDERATIONS

Introduction
      Under  the provisions  of the  SWTR,  systems with  fewer  than  500
service connections  may  be eligible for an exemption.   Guidance on the
requirements for an exemption is provided in Section 9.  For systems which
are not eligible for an exemption,  compliance with  the SWTR is mandatory.
It is recognized that the majority (approximately 75 percent) of people in
the  United  States  are served  by  a  relatively small  number  of  large
systems.  However,  most water systems in the United  States are small.  For
small systems,  compliance  with the  various  provisions  of the  SDWA has
traditionally  been  a  problem.    Records  show  small   systems  have  a
disproportionately  higher   incidence  of  drinking  water  quality  and
monitoring difficulties.  The reasons for these difficulties can generally
be broken down into the following three categories:
            Economics
            Treatment Technologies
            Operations (lack of qualified personnel)

      Small  water  systems   typically  face severe  economic  constraints.
Their lack  of  operating  revenues results  in significant limitations on
their ability to respond to the requirements of the SDWA.  These systems
cannot benefit from the economies of scale which are available to larger
systems.
      The second difficulty facing the  small systems has  been the lack of
appropriate treatment technologies.  Although methods for  removing most of
the contaminants known to occur in drinking water are available, many of
these technologies  have  only recently been scaled down  for  the smaller
systems.
      The third problem which has traditionally plagued  small  systems is
the lack of  well  trained operators.  This deficiency is the result of many
combined factors.  First of  all, many of these operators are employed only
on a  part-time  basis or  if they are employed on a full-time  basis they
have a myriad  of additional  duties.  In  addition, the operator's technical
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 background  may  be  limited  as  well.   This  results  from the low salary of
 the  position, which is uninviting to qualified operators.  Also, in spite
 of the requirement of  retaining certified operators upheld  in many states,
 it seems  to be  difficult to enforce this requirement in small  systems.
      The purpose of this appendix is to provide  assistance to the Primacy
 Agency  in  defining  the   problems   and  potential  solutions  typically
 associated  with small  systems. It is beyond the  scope  of this document to
 provide an  indepth dicussion of the needs of small  systems.  However, over
 the  past  several  years the needs of the  small  water  systems  have been
 recognized  to be of primary concern and numerous workshops,  seminars and
 committees  have been attempting to more clearly define workable solutions.
 A partial  listing  of  the  papers, reports  and proceedings which  discuss
 problems  and solutions  pertaining to small  systems beyond that which is
 possible  in this  manual   is  presented in  the  reference  list of this
 appendix.

 Economics
      One of the  most severe  constraints  of small  systems  is  the small
 economic base from  which to draw funds.   Certain  treatment  and services
must be provided for a community  regardless of how few  people are served.
 Thus, as the number of  connections  to the  system  decrease,  the cost per
connection  increases.   The economic limitations of small  utilities makes
 it difficult  to_ provide needed  upgrading  of existing facilities  or an
 adequate  salary to maintain  the employment of a  qualified  operator to
monitor and maintain  the system.   Adding to the severity of the economic
 hardships  of small systems  is   the  fact  that  many  of the  small  water
 systems are privately owned, with private ownership increasing as  system
 size decreases.   The  ownership of the plant presents difficulties since
 privately owned systems are subject to rate controls by the local  public
 utility commission, are not eligible for public  grants  and loans, and may
 find commercial loans hard to obtain.
      Financing options for small systems  include; federal and  state  loan
 and  grant  programs,  federal  revenue  sharing  and  revenue  bonds  (for
 municipal  systems)  and loans through the  United  States  Small Business
 Administration  (SBA) and use of industrial  development bonds  or  privatiza-
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tion  (for  private utilities).   These  options  are explained  in  greater
detail  in  the "Guidance  Manual  - Institutional  Alternatives  for  Small
Water Systems" (AWWA, 1986).  The following paragraphs  will  explain some
existing options  which  may ease  the  hardship  of financing  small  water
treatment facilities.
      The major cause of small system difficulties arises from the lack of
funds  and  resources.   It  is therefore  in the  best  interest of  small
utilities to  expand  their economic base and the  resources  available to
them,  to  achieve the economies  of scale  available  to larger  systems.
Regionalization is the physical  or operational  union  of small systems to
effect  this goal.   This  union can be  accomplished through  the physical
interconnection  of  two  or  more  small  systems  or the  connection  of  a
smaller system to a  pre-existing  larger system.  Water supply systems can
also join together for the  purchase of supplies,  materials,  engineering
services,   billing and  maintenance.    The  union  of the  small  systems
increases the population served,  thereby dispersing the operational costs
and decreasing the cost  per consumer.
      The creation of utility satellites is another form of regionaliza-
tion.   A  satellite  utility is one which  taps  into the resources  of an
existing larger facility without being physically connected to,  or owned
by,  the larger  facility.   The  larger system  may provide  any of the
following for the smaller system:
      1.    Varying  levels  of   technical  operational,   or  managerial
            assistance on  a contract basis.
      2.    Wholesale treated water with or without additional services.
      3.    Assuming ownership,  operation and maintenance responsibility
            when the small system is physically separate with a separate
            source.

      The formation  of a  satellite offers many  advantages  for  both the
satellite and the parent utility.   These advantages include:  an improved
economy of scale for satellites,  an expanded revenue base for the parent
utility, provisions  of needed resources to satellites,  the retention of
the satellites' local autonomy,  improved water quality management of the
satellite,  improved use of public funds for publicly owned satellites.
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      In  order  to  create  a more  definite  structure  for  the union  of
resources of water treatment facilities,  water districts  may be created.
Water districts are formed  by county officials and provide for the public
ownership of the  utilities.   The utilities  in any given district  would
combine  resources  and/or physically connect  systems  so that one or  two
facilities would provide water for the entire district.   The creation of
water districts creates eligibility for public monies,  has  the potential
for economies of size,  facilitates  the takeover or contract  services with
publicly owned non-community systems and  small privately owned systems,
and offers a tax advantage.  Drawbacks include subjection to politics, a
strong local planning effort is needed for success,  and competition with
private enterprises.
      The  centralization  of  utilities  can  be  taken  one   step  further
through  the creation of  county utilities or even state  utilities.   The
government will create a board which may then act to acquire, construct,
maintain  and operate  any public water  supply within  its  district,  the
system may provide water on its own or purchase water from  any municipal
corporation.  The board may adopt and  administer rules for  the construc-
tion, maintenance,  protection  and  use of public water supplies  and  the
fixation of reasonable  rates for water supplies.   The cost of construction
and/or upgrading  of  facilities may be defrayed  through  the issuance of
bonds and/or  property assessment.   As with  all  the  alternatives,  the
creation of government  control of the utilities has  its advantages  and
disadvantages.     The  advantages  include:    the  creation  of  central
management, creation of economy  of scale  for utilities,  eligibility for
public grants and loans, savings through centralized purchasing, manage-
ment,  consultation, planning  and  technical  assistance,   and  possible
provision for pool  of  trained  operators.   The disadvantages include the
subjectivity to  politics,  the  slow response  caused  by bureaucracy,  and
competition to private contractors.

Treatment Technologies
      The high cost of available treatment technologies has  limited their
use in small water supply systems.   Recently  prefabricated package plants
and individual  treatment units have been  developed to  lessen these costs.
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At  the present time, the treatment  technologies  which  are available to
enable systems to comply with the Safe Drinking Water Act are identified
to  be  the following:
            Package  plants
            Slow-sand filters
            Diatomaceous earth filters
            Cartridge filtration

       A brief discussion of each treatment method is provided below.
       Package Plants
       Clarification and filtration units which require minimal assembly in
the field can  now be manufactured.   To minimize required operator skill
level  and  operational  attention,   the equipment  should  be  automated.
Continuous effluent  turbidity and disinfectant residual monitoring systems
with alarms and emergency shutdown provisions  are  features that safeguard
water  quality and should be provided for unattended plants.
       Slow-Sand Filters
       Slow-sand  filters  are applicable  to small' water  supply  systems.
Their  proven record  of effective removal  of turbidity and Giardia cysts
makes  them  suitable for  application  where  operational  attention  is
minimal.  Since no chemicals other than a  disinfectant are needed, and no
mechanical equipment is  involved, the required operator skill  level is the
lowest of the filtration alternatives available to small systems.
       Diatomaceous Earth Filters
              "*•>•
       Diatomaceous earth (DE) pressure and vacuum filters can be used on
relatively low turbidity  surface waters (less than 1  to 2  NTU) for removal
of  turbidity  and  Giardia  cysts.    DE filters  can  effectively  remove
particles as small  as  1  micron,  but would require coagulating chemicals
and special filter aids to provide significant virus removal.
       Cartridge Filters
       Cartridge  filters  using  microporous ceramic  filter  elements  with
pore sizes as  small  as 0.2 urn may be  suitable for producing potable water,
in  combination  with  disinfection,  from  raw water  supplies  containing
moderate levels of turbidity, algae,  protozoa and bacteria.  The advantage
to a small system, is, with the exception of chlorination, that no other
chemicals are required.  The process is one of strictly physical removal
                                  L-5

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of  small  particles  by straining as the water passes  through  the  porous
membranes.    Other  than  occasional  cleaning or membrane  replacement,
operational  requirements  are  not  complex  and   do  not require  skilled
personnel.
      Selection of a Filtration Technology
      The criteria for  selection of  a  filtration technology  for  a small
community are essentially the same  as those  for a  larger community.  That
is,  the  utility  must  first  screen  the  complete   list  of  available
alternatives to eliminate  those which are either not technically suited to
the  existing  conditions  (Table 4-1)  or  not affordable by the  utility.
Remaining  alternatives  should  then be  evaluated  based   on  both  cost
(capital,  annual,  and  life-cycle)  and  non-cost  bases  (operation  and
maintenance, technical requirements versus personnel available; flexibili-
ty regarding future needs; etc.).  In these evaluations it should be noted
that even though automated package plants are cost-competitive with slow
sand filters,  their  operation requirements to achieve optimum performance
could be  complicated.   Also,  the  maintenance requirements  for  package
plants would be mechanically and electrically oriented and might require
a maintenance agreement with the manufacturer.
      During  the  process of installing  the  treatment system,  interim
measures should be taken to ensure the delivery of a reasonably safe water
to the consumers.  In  addition to the available interim measures listed in
Section 9.3,  temporary  installation  of mobile filtration  plants  may be
possible.  These trailer-mounted units  are sometimes available from state
agencies for emergencies, but more often may be  rented or leased from an
equipment manufacturer.
      Modification of Existing Filtration Systems
      Small treatment systems that  are  already in existence should comply
with the performance criteria of the SWTR.  If the systems are not found
to be performing satisfactorily, modifications to the existing  process may
be required.   Improvement in treatment efficiency depends on the type of
filtration system in use.  Operation  of slow sand filters could be checked
for  bed depth, short-circuiting, excessive hydraulic loading,  and for the
need to pretreat  the raw water.   Infiltration  galleries,  or sometimes,
roughing  filters  ahead of   a  slow sand  filter  may  provide  for  better
                                   1-6

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 performance  by  reducing the solids  load  on  the filters.   However,  the
 design criteria and costs for this  alternative  have not yet been defined.
 Site  specific  studies  may be required before  roughing  filters  could be
 used  to  achieve  compliance with the regula- tions.   Diatomaceous  earth
 (DE)  filters should be  checked for appropriate  precoat and  body  feed
 application,  hydraulic  loading,  grade  (size) of  DE  being  used,  and
 possible need for chemical pretreatment.   Package plants would have to be
 checked process-by-process, similar to  the system used for a conventional
 plant.  Other filtration processes  would have to be checked for hydraulic
 loading  rate,  appropriateness  of  the  filter  material  (pore  size),  and
 possible need for additional pretreatment.
      Disinfection
      Disinfection  (CT)  requirements  for small  systems  can  be met in
 several  different  ways.    The  most  obvious  method of maintaining  a
 disinfectant residual  in the distribution system is  to add disinfectant at
 one or more additional  locations.  An alternate method is to increase the
 disinfectant  dose  at  the existing  application  point(s).    The  latter
 alternative,  however,  may  increase  disinfectant  byproducts,  including
 THMs, in the system.
      If it  is a  relatively  short  distance between the  treatment system
 and the  first customer,  additional contact time  can  be  provided so that
 the  disinfectant  dose does  not have  to  be increased  beyond desirable
 residuals.    Two  specific methods  of increasing  contact  time  for  small
 systems  are  1)  installing a pressure  vessel  or closed  storage vessel,
 baffled  to  provide adequate contact time, or 2) constructing  a looped
pipeline, on the finished water  line between the filtration-disinfection
 system and  the first customer.  The feasibility of either of these methods
would depend on system specifics that  include  size, physical conditions,
 and cost.
      If it is not practical to provide additional storage time to achieve
 the desired CT, an alternate, more effective disinfectant may be  used.  An
 alternate disinfectant may provide a sufficient  CT without altering the
 system configuration.
                                   L-7

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Operations
      Water treatment facilities need  to be operated properly in order to
achieve maximum treatment efficiencies.  There is currently a lack of well
trained operators at many small  treatment  plants.  The main cause is lack
of  awareness  of  the  importance  of  correct  plant  operation,  lack  of
training programs, lack of enforcement of the requirement for employment
of a certified operator and lack of funds to employ such an  operator.
      Small  systems  may wish  to  implement  a  circuit  rider/operator
program.   In  this program a qualified, certified,  experienced  operator
works for  several  water supply  systems.   The rider  can  either  directly
operate the plants,  or  provide  technical  assistance  to  individual  plant
operators, by acting as a trainer through on-the-job supervision.   The
latter would be preferable since  it could create  a  pool  of  well  trained
operators.
      The main cause of  inadequately trained operators is  the lack of well
established training  programs.  Until  such  training  programs  are  begun,
systems must depend on other training  means,  such as seminars and  books.
One  resource  which   may  be  helpful   in  running  the plant  is  "Basic
Management Principles for Small  Water  Systems  - An  AWWA  Small-Systems
Resource Book",  1982.
      Most package plant manufacturers' equipment manuals  include at least
brief sections on  operating  principles, methods for establishing  proper
chemical dosages, instructions for operating the equipment,  and trouble-
shooting guides.  An  individual  who studies these basic instructions and
receives comprehensive  start-up training  should be  able to  operate the
equipment  satisfactorily.   These  services  are  vital to  the successful
performance of a package water treatment plant and should  be a requirement
of the package plant  manufacturer.  The engineer  designing a package plant
facility should specify that  start-up and training services be provided by
the manufacturer, and also should consider requiring the manufacturer to
visit the plant at 6-month and  1-year  intervals after start-up to adjust
the  equipment,   review  operations,   and  retrain  operating  personnel.
Further, this program should  be  ongoing and funds should  be budgeted every
year for at least one revisit by  the package plant manufacturer.
                                   L-8

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      Another way  for  small  systems  to  obtain  qualified  plant  operation
*ould be  to  contract  the  services  of administrative,  operations,  and/or
maintenance  personnel   from  a  larger  neighboring  utility,  government
agencies,  service  companies  or consulting  firms.   These  organizations
could supply assistance in  financial  and legal planning,  engineering,
purchasing   accounting  and  collection  services,   laboratory   support,
licensed  operators or  operator  training, treatment  and water  quality
assurance, regulatory liaison,  and/or emergency assistance.   Through the
contracting  of  these  services  the  utility  provides  for the  resources
needed,   improves   water  quality management  and  retains its  autonomy.
However,  if  and when the contract  is terminated, the  utility returns to
its original  status.

References
American Water Works Association.   Basic Management Principles  for Small
Water Systems. 1982.
American Water Works Association.   Design  and Construction of Small Water
Systems. 1984.
Kelly,  Gidley,  Blair and  Wolfe, Inc.   Guidance Manual  -  Institutional
Alternatives  for Small  Water Systems.  AWWA Research Foundation Contract
79-84,  1986.
                                   L-9

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        APPENDIX M



PROTOCOL FOR DEMONSTRATION



  OF EFFECTIVE TREATMENT

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                               APPENDIX M

                       PROTOCOL FOR DEMONSTRATION
                         OF EFFECTIVE TREATMENT

      This appendix presents approaches which can be taken to demonstrate
overall effective removal and/or inactivation of Giardia cysts.

M.I   Demonstration for Alternate Technology
      Systems using a  filtration  technology  other  than  those enumerated
in the  SWTR  may demonstrate the effectiveness  of  the  treatment process
through pilot  or full  scale testing.   As a minimum, testing  should  be
conducted when the source exhibits its worst case annual conditions.  Some
systems may have two periods of "worst case" water quality including the
cold water in winter or algae blooms during the summer.
      Pilot units should include the following:
                  filtration rate of the pilot  system equal to filtration
                  rate on full scale unit
                  pilot filter diameter greater than  or equal to 50 times
                  the media diameter,  (Robeck,  et al  1959)
                  media  diameter,  depth,  and  size gradation  should  be
                  identical to full scale,
                  coagulant dosing identical to full  scale
                  any mixing and settling occurring before filtration in
                  the full scale plant should be reproduced as closely as
                  possible  in the pilot.  Mixing should be of the same G
                  value(s), and the detention time  for settling  should be
                  close  to  the   average flow  detention  time  for  the
                  projected full scale plant.

      According  to  the SWTR,  alternate  technologies must be capable of
meeting the  same turbidity  performance criteria of slow sand filtration
systems.   Thus  the filtered water from  the  process  should be monitored
continuously  or with  grab samples every  four  hours  for turbidity.   The
requirement  for meeting turbidity  performance has  been  established to
                                   M-l

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ensure  that  there  will  be  no  interference  of  turbidity  with  virus
inactivation through disinfection.
      Following the demonstration of meeting the turbidity  requirements,
the  level  of  GJardia  cyst removal  achieved  must be  determined.    The
protocol in M.2 may be followed for this demonstration.

M.2   Particle Size Analysis Demonstration for Giardia Cyst Removal Credit
      Particle  size analysis  may  be  used to  demonstrate  the level  of
actual Giardia  cyst removal provided by  the  system.   This  demonstration
can be done using samples from the full  scale plant or a  pilot unit.
      In the case  of  either a full scale or  pilot  scale  demonstration,
removal of  particles  in  the range of 5  to  15 urn  in diameter  should  be
determined using an electronic particle counter that has  been calibrated
with latex spheres.  If a light blockage device is used (e.g. HIAC) this
calibration should have been done during  installation of the device.  The
calibration should be  checked  before taking measurements for the purposes
of this demonstration.   Samples should be diluted appropriately to ensure
that measurements  do  not  reflect  coincident  error.   Coincident  error
results when  more than  one  particle passes  the detector at  one  time,
causing  an  inaccurate particle count  and  diameter  measurement.    An
electrical  sensing zone device (e.g.  Coulter Counter or Elzone) may also
be used.   Appropriate  dilutions,  electrolyte  strength,  and  calibration
procedures should be followed (these are scheduled to be  outlined in the
17th edition of Standard Methods).  When using  an electrical sensing zone
instrument,  an  orifice no  larger than  125 urn  and  no  smaller than  40 urn
should be used since   only particles between  2% and 40% of  the  orifice
diameter are accurately sized and counted (Karuhn et al 1975).
      Samples  of  the  filter  influent  and  effluent  should  be  taken 5
minutes after the backwashed filter is placed  in operation, and every 30
minutes thereafter for the first  3  hours of operation, followed by hourly
samples up until backwash (Wiesner et al 1987).  All samples should show
at  least  a  2-log  removal.   The  SWTR  establishes an  overall  treatment
requirement of  3-log Giardia cyst  removal/inactivation.  Thus, disinfec-
                                   M-2

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tion  must be provided to supplement the particulate removal and meet this

requirement.
      Samples  from repeated filter runs may be averaged at each sampling

time, but samples should not be averaged within one filter run.

      Additional  suggestions   on  particle  counting technique  (Wiesner
1985):

             1)    If  particle counts are not determined immediately upon
                  sampling (within 10 minutes)  samples should be diluted.

             2)    For an  electrical  sensing  zone  measurement,  samples
                  should be diluted  1:5 to 1:20  with  a "particle-free1
                  electrolyte solution (approximately 1% NaCl) containing
                  100 particles per ml or fewer.

             3)    For a light  blockage measurement,  particle free w-ater
                  should be used to dilute samples.

             4)    Dilutions should be done to produce particle concentra-
                  tions as close to the tolerance  for coincident error as
                  possible to minimize background counts.

             5)    Particle counts should be determined within 8 hours of
                  sampling.

             6)    All  sampling  vessels  should  be  washed with laboratory
                  detergent, double  rinsed  in particle free water,  and
                  rinsed twice  with  the water  being sampled  at the time
                  of  sampling.


      The log  reduction of  particles  in the size  range  of 5  to 15 urn in

size can be  assumed  to correspond  to the  log  reduction  of Giardia cysts

which would  be achieved.


M.3  Demonstration for Increased Turbidity Allowance
      Based  upon  the  requirements  of the  SWTR,  the  minimum turbidity
performance  criteria  for  systems  using conventional  treatment or direct
filtration is  filtered  water  turbidity less  than  or  equal to 0.5 NTU in
95 percent of  the measurements taken  each month.  However,  at the dis-
cretion of the Primacy Agency, filtered water  turbidity  levels  of less
than or equal to 1 NTU in  95 percent of the  measurements taken  every month
                                   M-3

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may be permitted on  a  case-by-case basis  depending on  the  capability  of
the total  system to remove and/or inactivate  at  least 99.9 percent  of
Giardia 1amb1i$ cysts.
      Treatment plants that use settling followed by filtration,  or direct
filtration  are  generally  capable of producing  a  filtered  water  with  a
turbidity of 0.2 NTU or less.   The most likely  cause  of high  turbidities
in  the  filtered water is incorrect coagulant  dosing  (O'Melia,  1974).
Regardless  of  the  turbidity  of  the  raw or  finished water,  coagulant
addition at  some point prior  to  filtration  is required to  destabilize
particles for removal  in the filter.   Only plants  documenting continuous
coagulant feed prior  to filtration should be eligible for  being allowed
higher filtered water turbidities  than the 0.5 NTU  requirement.  At plants
that continuously feed coagulant  and do  not meet the 0.5 NTU requirement,
a series of jar  tests,  and perhaps sand  column filtration tests (in batch)
should be performed to evaluate the optimum coagulant dose  for  turbidity
removal.
      In the event  that plants can document continuous  coagulant feed,
and, after running the plant under conditions determined in batch testing
to  be  optimal   for  turbidity  removal,  still   do  not  meet  the  0.5  NTU
requirement, effective filtration status may still be appropriate.  This
would further be supported if  it  can be shown  that the full  scale plant
is capable of achieving at  least  a 2-log reduction  in the  concentration
of particles between  5 and  15  urn  in  size through  particle  size analysis
as outlined in Section M.2.  Where a full  scale  plant does not yet exist,
appropriately ~~ scaled-down  pilot  filters might  be   used   for   such  a
demonstration.

Disinfection
      The level of disinfection could also be considered for determining
when to allow a higher turbidity  performance criterion for  a  system.  For
example,  if  a system  achieves 3-log  Giardia  cyst  inactivation  through
disinfection, as determined by CT values, it may  be appropriate  to allow
higher filtered  water turbidities (i.e., greater than 0.5 NTU but less
than 1 NTU  in 95 percent  of the measurements and  never exceeding  5 NTU).
                                   M-4

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       The   expected   level  of  fecal  contamination  and  Giardia  cyst
 concentrations  in the  source  water should  be  considered in  the above
 analysis.   High  levels  of disinfection (e.g., 2 to 3-log inactivation of
 Giardia cysts), in addition  to filtration which achieves  less than 0.5 NTU
 in  95 percent of the  measurements  may  be  appropriate,  depending  upon
 source water quality.  Further guidance on the level  of disinfection to be
 provided for various source  water conditions is provided  in Section 4.4.2.
 In all cases the  minimum disinfection to be provided must supplement the
 particulate  removal   to ensure at   least  a  3-log  Giardia  cyst  remov-
 al/inactivation.


 References

 American  Public   Health Association;  American Water Works  Association;
 Water Pollution Control Federation.   Standard Methods for the Examination
 of Water and Wastewater. 17th ed.  (supplement), September 1989.

 Coulter Electronics 600 W.  20th Street, Hialeah, FL  33010-2428

 Karuhn,  R.;  Davies,  R.;  Kaye,  B.;  Clinch,  M.  Studies on  the Coulter
 Counter Part I.   Powder Technology Volume II, pp. 157-171, 1975.

 O'Melia, C. The  Role  of Polvelectrolytes  in Filtration  Processes. EPA -
 67012-74-032, 1974.

 Robeck, G.;  Woodword,  R.  L. Pilot  Plants  for Water Treatment Research,
 Journal of Sanitary Engineering ASCE Vol. 85;SA4; 1, August 1959.

 Wiesner, M. "Optimum  Water  Treatment Plant  Configuration Effects of Raw
Water Characteristics," dissertation John Hopkins University,  Baltimore,
MD, 1985.

Wiesner, M.; Rook, J. J.; Fiessinger, F. Optimizing the Placement of GAC
 Filters, J. AWWA  VOL 79, pp. 39-49,  Dec 1987.
                                   M-5

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        APPENDIX N

PROTOCOLS FOR POINT-OF-USE
         DEVICES

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             ITITED STATES
    ENVIRONMENTAL PROTECTION AGENCY
         Registration Division
     Office of Pesticide Programs
    Criteria and Standards Division
       Office of Drinking Water
    GUIDE STANDARD AND PROTOCOL TOR
rESTING MICROS 1C LOGICAL WATER PL'RIFIERS
         Report of Task Force
         Submitted April, 1986
          Revised April, 1987

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                                   CONTENTS



                                                                      Page

PREFACE

1.   GENERAL                                                          r.-l

2.   PERFORMANCE REQUIREMENTS                                         N-6

3.   MICROBIOLOGICAL WATER PURIFIER TEST PROCEDURES                   N-8

APPENDIX N-l   SUMMARY FOP. BASIS OF STANDARDS AND                     N-21
  TEST WATER PARAMETERS

APPENDIX N-2   LIST OF PARTICIPANTS IN TASK FORCE                     N-29

APPENDIX N-3   RESPONSE BY REVIEW SUBCOMMITTEE TO                     N-21
  PUBLIC COMMENTS

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Preface
     The protocol presented  in this paper  can  be applied to demonstrate  the
effectiveness  of new  technologies  as  well  as  point-of-use  devices.    The
evaluation  presented  here  deals  with  the   removal  of   particulates   and
disinfection.    In  areas  which  pertain   to   disinfection,  the   guidelines
contained in Appendix G take precedence.

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                                   1.  GENEPAL


 1.1   Introduction


      The  subject of  microbiological purification for waters of unknown micro-

 biological quality repeatedly presents itself to a variety of governmental =r.d

 non-governmental agencies,  consumer groups, manufacturers  and  others.  Exam-

 ples  of possible application of such purification capabilities include:

       -  Backpackers and campers

          Non-standard military requirements

          Floods and other natural  disasters

       -  Foreign travel  and  stations  (however, not for extreme contamination
          situations outside of the U.S.)

          Contaminated individual  sources, wells and springs (however, net for
          the conversion of waste  water to microbiologically potable water)

          Motorhomes and trailers

      Hatch methods of  water purification based  on  chlorine  and  iodine disin-

 fection or  boiling  are  well  known, but  many situations  and  personal choice

 call  for  the consideration  of water  treatment equipment.  Federal agencies

 specifically  involved  in  responding to  questions  and  problems  relating to

microbiological purifier equipment include:

       -  Registration Division, Office  of Pesticide Programs  (OPP), Environ-
          mental  Protection Agency (EPA):   registration of  microbiological
          purifiers  (using chemicals);

       -  Compliance  Monitoring   Staff,   EPA:    control  of  microbiological
          purifier device claims   (non-registerable products  such  as  ultra-
          violet units, ozonators, chlorine generators, others);

       -  U.S. Army Medical Bioengineering Research and Development Laboratory
          (USAMBRDL),  U.S.  Army Natick  Research  and  Development  Center  and
          other  Army and  military  agencies:    research  and development  for
          possible field applications;

       -  Criteria and  Standards  Division,  Office  of Drinking water  (CCW),
          EPA:  Consideration  of  point-of-use technology  as acceptable tech-
          nology  under  the  Primary  Drinking  Water  Regulations;  consumer
          information and service;
                                      N-l

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          Drinking  Water  Research,  Water  Engineering  Research  Laboratory
          (WERL), EPA; responsible for water treatment technology research;
       -  Microbiology Branch, Health Effects Research Laboratory (HERD, EPA;
          responsible  for  study of health  effects related to  drinking water
          filters.
     A  number of  representatives of  the above  mentioned agencies  provided
excellent participation  in  the  task force to develop  microbiological testing
protocols for  water  purifiers.   Major participation was also provided  by the
following:
       -  A technical representative from the Water Quality Association;
       -  A  technical representative  from  the  Environmental   Health  Center,
          Department of Health and Welfare of Canada;  and
       -  An   associate  professor   (microbiology)  from   the   University  of
          Arizona.
1.2  Basic Principles
     1.2.1  Definition
     As set  forth  in EPA Enforcement  Strategy  and as supported  by  a Federal
Trade  Commission  (FTC)  decision  (FTC v.  Sibco Products  Co.,  Inc., et al.,
Nov. 22,  1965) ,  a   unit,  in  order  to  be   called a  microbiological  water
purifier, must remove, kill or  inactivate all types of disease-causing  micro-
organisms from the water,  including bacteria, viruses and  protozoan  cysts  so
as to  render  the processed  water  safe for drinking.  Therefore, to qualify, a
microbiological water purifier must  treat  or  remove  all  types  of  challenge
organisms to meet specified standards.
     1.2.2  General Guide
     The standard and protocol will be a general guide and, in some cases, may
present  only  the minimum  features  and framework  for testing.  While basic
features of the standard and protocol have been tested, it was not feasible to
conduct full-fledged  testing  for all possible  types  of  units.   Consequently,
protocol  users should include  pre-testing of  their  units in  a  testing rig,
including the sampling  techniques  to be used.   Where users of  the protocol
find  good reason  to alter or add  to the  guide  in  order to  meet specific
operational problems, to use an alternate organism  or  laboratory procedure, or
to  respond   to innovative  treatment  units  without decreasing the  level  of
                                      N-2

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 testing  or altering the  intent  of the protocol, they  should  feel free to do
 so.   For example,  the  OPP Registration  Division  might find  it  necessary to
 amend  the guide  somewhat  for  different types  of treatment  units.   Another
 example  would be ultraviolet  (U.V.)  units, which may  have specific require-
 ments  in  addition to the  guide protocol.
     1.2.3   Performance-Based
     The  standard will be performance-based,  utilizing realistic worst case
 challenges and  test conditions  and use of  the standard  shall  result in water
 quality   equivalent  to   that   of   a  public   water   supply   meeting  the
 microbiological requirements and intent of  the National Primary Drinking Water
 Regulations.
     1.2.4  Exceptions
     A  microbiological water  purifier  must  remove, kill  or  inactivate  all
 types  of  pathogenic organisms  if claims are made  for any organism.  However,
 an  exception for limited claims may  be  allowed for units removing specific
 organisms to  serve  a definable  environmental  need (i.e., cyst reduction units
 which  can be  used on otherwise disinfected  and microbiologically safe drir.kir.g
 water,  such  as  a disinfected but  unfiltered surface water containing cysts.
 Such units are not  to be  called microbiological water purifiers and should r.ct
 be used as sole treatment  for an untreated  raw water.)
     1-2-5  Not to  Cover  Non-Microbiological Reduction Claims
     The treatment of water to achieve removal of a specific chemical or ether
 non-microbiological- substances from water will not be a part of this standard.
 National Sanitation Foundation  (NSF)  Standards 42  (Aesthetic  Effects)  and 53
 (Health Effects) provide  partial guides  for chemical removal and  other claims
 testing.
     1.2.6  Construction  and Information Exclusions
     while the  standard  recommends safe,  responsible  construction  of units
with non-toxic materials  for optimum  operation,  all such items and associated
 operational  considerations are  excluded  as  being  beyond  the  scope  of  the
 standard.  Included in the exclusion are materials of construction, electrical
 and safety aspects, design and  construction details, operational  instructions
 and information, and mechanical performance testing.
     1.2.7  Research Needs Excluded
                                      N-3

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     The  guide  standard  and  protocol  must  represent  a  practical  testing
program and  not include research recommendations.   For example,  consideration
cf  mutant organisms  or differentiation  between injured  and dead  organisms
would be  research  items at this  time and not appropriate for inclusion in the
standard.
     1.2.8  Not to Consider Sabotage
     Esoteric problems  which  could be presented by a  variety of hypothetical
terrorist  (or wartime)  situations,  would provide an unnecessary complication,
and are not appropriate for inclusion in the standard.
     1.2.9  Continuity
     The  guide  standard and protocol  will be  a living document,  subject  to
revision  and updating with the onset of new  technology  and  knowledge.   It  is
recommended  that  the  responsible authorities  for  registration  and  drinking
water quality  review potential needs  every two to three years  and reconvene
the task  force  upon  need or upon request  from  the  water quality industry,  to
review and update the standard and testing protocol.

1.3  Treatment Units Coverage
     1.3.1  Universe of Possible Treatment Units
     A review of  treatment units that might  be considered  as microbiological
purifiers discloses  a number  of  different  types covering treatment principles
ranging from  filtration and  chemical disinfection  to ultraviolet light  ra-
diation.
     1.3.2  Coverage of This Standard
     In view of the  limited technical  data available and in order to expedite
the work  of  the task  force,  the initial  coverage  is  limited,  on  a  priority
basis,  to three  basic  types  of  microbiological water  purifiers or  active
components with their principal means of action  as follows:
     1.3.2.1  Ceramic Filtration Candles or Units (may or
              may not contain a chemical bacteriostatic agent)
     Filtration,  and adsorption,  and chemical  anti-microbial activity  if  a
chemical  is included.
     1.3.2.2  Halooenated  Resins and Units
                                      N-4

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     Chemical   disinfection   and   possibly   filtration.    (Note:    While  not
included  in  this  guide  standard,  halogen products for disinfection or systems
using  halogen  addition and  fine  filtration may  be  tested using many  of  its
elements, i.e., test water parameters, microbiological challenge and reduction
requirements, analytical techniques and other pertinent elements.)
     1.3.2.3  Ultraviolet  (UV) Units
     UV irradiation with possible add-on treatment for adsorption and filtra-
tion (not applicable to UV units  for  treating  potable water from public water
supply systems).
     1.3.3  Application of Principles to Other Units
     while only three types of units are covered  in this standard, the princi-
ples and  approaches outlined should provide an initial guide  for  the testing
of any of a number of other types of units and/or  systems for the microbiolog-
ical purification of contaminated water.
                                      N-5

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                         2.  PERFORMANCE REQUIREMENTS

2.1  Microbiological Water Purifier
     In  order to  make  the claim  of "microbiological water  purifier," units
must be  tested and demonstrated to meet the microbiological reduction require-
ments  of  Table  1  according  to the  test procedures  described  in  Section 3
(Appendix  N-l) for the specific type of unit involved.

2.2  Chemical Health Limits
     Where  silver  or some other pesticidal  chemical  is used in  a  unit,  that
chemical  concentration  in the  effluent  water  must meet any  National Primary
Drinking Water Maximum  Contaminant Level (MCL) ,  additional Federal guidelir.es
or otherwise  be  demonstrated not  to constitute  a threat  to  health  from con-
sumption or contact where no MCI* exists.

2.3  Stability of  Pesticidal Chemical
     Where a pesticidal  chemical  is  used in the  treatment unit, the stability
of the  chemical  for disinfectant  effectiveness  should be  sufficient  for the
potential  shelf  life and the  projected  use  life  of the unit based on manufac-
turer's  data.   Where  stability cannot  be  assured  from  historical  data and
information, additional  tests will be required.

2.4  Performance Limitations
     2.4.1  Effective Lifetime
     The manufacturer must provide an explicit indication  or assurance of the
unit's effective use lifetime  to warn  the  consumer of potential  diminished
treatment capability either through:
     a.   Having the unit terminate discharge of treated water, or
     b.   Sounding an alarm, or
     c.   Providing  simple,  explicit instruction  for servicing  or  replacing
          units within the recommended use life  (measurable in terms of volume
          throughput, specific time frame or other appropriate method).
     2.4.2  Limitation on Use of Iodine
                                      N-6

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     EPA policy  initially  developed in 1973 and  reaffirmed in 1982  (memo  of
March 3, 1982  from J.  A.  Cotruvo to G. A. Jones, subject:   "Policy  on Iodine
Disinfection") is  that iodine  disinfection is  acceptable  for short-term  or
limited  or emergency  use  but  that it is  not  recommended for  long-term  or
routine community water supply application where iodine-containing species may
remain in the drinking water.
                                       N-7

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               3.  MICROBIOLOGICAL WATER PURIFIER TEST PROCEDURES

3.1  Purpose
     These  tests  are performed on ceramic  filtration  candles  or units, halo-
genated  resins and  units and ultraviolet  (UV) units  in  order  to substantiate
their microbiological  removal  capabilities  over  the effective  use life of the
purifier  as defined in Table 1 and,  where a pesticidal chemical  is  used,  to
determine  that said chemical is  not present  in  the  effluent  at excessive
levels  (see Section  3.5.3.4, Appendix N).

3.2  Apparatus
     Three  production  units of a  type are  to  be  tested,  simultaneously,  if
feasible; otherwise, in a manner as similar to that as possible.
     Design of  the  testing  rig must parallel and simulate projected field use
conditions.  For  plumbed-in units a  guide  for  design of  the  test  rig may be
taken from  "Figure 1:  Test Apparatus-Schematic"  (p. A-2 of Standard Musiber 53
"Drinking  Water  Treatment  Units  —  Health Effects,"   National  Sanitation
Foundation).   Otherwise, the  test  rig must be designed  to simulate field use
conditions  (worst case) for the unit to be tested.

3.3  Test waters — Non-Microbiological Parameters
     In addition  to  the  microbiological influent challenges,  the various test
waters  will be constituted  with chemical  and  physical   characteristics  as
follows:
     3.3.1  Test Water »1 (General Test Water)
     This water is  intended for the  normal non-stressed (non-challenge) phase
of testing  for all  units  and shall  have  specific characteristics  which nay
easily  be  obtained  by the adjustment  of  many  public  system  tap  waters,  as
follows:
     a.    It shall be free of any chlorine or other disinfectant residual;
     b.    pH — 6.5 - 8.5;
     c.    Total Organic Carbon (TOC)  0.1 - 5.0 mg/L;
     d.    Turbidity 0.1-5 NTU;
                                      N-8

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     e.   Temperature 20 C * 5 C; and
     f.   Total Dissolved Solids  (TDS) 50 - 500 mg/L.
     3.3.2  Test Water *2 (Challenge Test Water/Halogen Disinfection)
     This water is  intended  for  the stressed  challenge phase of testing where
units involve halogen disinfectants (halogen  resins or other units)  and shall
have the following specific characteristics:
     a.   Free of chlorine or other disinfectant residual;
     b.   (1)  pH 9.0 * .2,  and
          (2)  for  iodine-based  units a pH of 5.0  *  .2  (current information
          indicates  that  the low pH will be  the  most severe  test  for virus
          reduction by iodine disinfection);
     c.   Total Organic Carbon (TOO not less than  10 mg/L;
     d.   Turbidity not less than 30 NTU;
     e.   Temperature 4 C "  1 C;  and
     f.   Total Dissolved Solids  (TDS) 1,500 mg/L *  150 mg/L.
     3.3.3  Test Water *3 (Challenge Test Water/Ceramic Candle
            or Units With or without Silver Impregnation)
     This water  is  intended for  the stressed challenge phase  of testing for
the indicated  units but not  for such units  when   impregnated  with  a halogen
disinfectant (for"the latter, use Test Water #2).   It shall have the following
specific characteristics:
     a.   It shall be free of any chlorine or other disinfectant residual;
     b.   pH 9.0 *  .2;
     c.   Total Organic Carbon (TOO — not less than 10 mg/L;
     d.   Turbidity — not less than 30 NTU;
     e.   Temperature 4 C * 1 C;  and
     f.   Total Dissolved Solids  (TDS) — 1,500 mg/L * 150 mg/L.
     3.3.4  Test Water »4 (Challenge Test Water for Ultraviolet Units)
     This water is intended for the  stressed phase  of testing for UV units and
shall have the following specific characteristics:
                                      N-9

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     a.   Free of chlorine or other disinfectant residual;

     b.   pH 6.5 - 8.5;

     c.   Total Organic Carbon  (TOO — not less than 10 mg/L;

     d.   Turbidity — not less than 30 NTU;

     e.   Temperature 4 C * 1 C;

     f.   Total Dissolved Solids  (TDS) ~ 1,500 mg/1 * 150 mg/L;

     g.   Color  U.V.  absorption  (absorption  at 254  run)  —  Sufficient para-
          hydroxybenzoic acid (PHBH) to be just below the trigger point of the
          warning alarm on the U.V. unit.   (Note that Section 3.5.1.1 provides
          an alternative of adjusting the U.V. lamp electronically, especially
          when the U.V. lamp is preceded by activated carbon treatment.)

     3.3.5  Test Water *5 (Leaching Test Water for Units Containing Silver)

     This water  is  intended for  stressed  leaching tests of  units containing

silver to  assure that excess levels  of silver will  not  be  leached  into the

drinking water.  It shall have the following specific characteristics:

     a.   Free of chlorine or other disinfectant residual;

     b.   pH — 5.0 * 0.2;

     c.   Total Organic Carbon  (TOO — approximately 1.0 mg/L;

     d.   Turbidity — 0.1 - 5 NTU;
                 i*..
     e.   Temperature —• 20 C "  5 C; and

     f.   Total Dissolved Solids  (TDS) — 25 - 100 mg/L.

     3.3.6  Recommended Materials for Adjusting Test Water Characteristics

     a.   pH:   inorganic acids or bases (i.e., HC1, NaOH);

     b.   Total Organic Carbon  (TOO:   hmnic acids;

     c,   Turbidity:   A.C. Fine Test Dust (Park No. 1543094)

               from:      A.C. Spark Plug Division
                         General Motors Corporation
                         1300 North Dort Highway
                         Flint,  Michigan 48556;

     d.   Total Dissolved Solids  (TDS):  sea  salts,  Sigma Chemical Co., S9683
          (St. Louis,MO)  or another equivalent source of TDS;
                                     N-10

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     e.   Color  U.V.  Absorption:   p-hydroxybenzoic  acid  (grade:    general
          purpose reagent).

3.4  Analytical Methods
     3.4.1  Microbiological Methods

     Methods in this section are  considered  "state-of-the-art"  at  the  time  of
its preparation and  subsequent improvements  should be  expected.  Methods  used

for microbiological  analyses should be compatible with  and equal to  or better
than those given below. .

     3.4.1.1  Bacterial Tests
     a.   Chosen Organism:   Klebsiella terrigena (ATCC-33257).

     b.   Method of  Production:   Test organism will be prepared by  overnight
          growth in nutrient broth or equivalent to obtain the  organism in the
          stationary  growth  phase  (Reference:   Asburg,  E.D.,   Methods  of
          Testing Sanitizers and  Bacteriostatic  Substances In:   Disinfection,
          Sterilization and Preservation, Seymour S. Block,  ed., pp. 964-930,
          1983) .  The organism will be collected by  centrifugation ar.d washed
          three times in phosphate buffered saline  before use.   Alternatively,
          the  organisms  may be  grown overnight  on nutrient  agar  slants  or
          equivalent  and washed   from  the  slants  with  phosphate   buffered
          saline.   The suspensions should be filtered  through  sterile  what.ran
          Number 2  filter   paper   (or equivalent)   to  remove  any  bacterial
          clumps.   New batches of organisms  must be  prepared daily for use  in
          challenge testing.

     c.   State of  Organism:   Organisms  in  the stationary  growth  phase  and
          suspended in phosphate buffered saline will be used.

     d.   Assay Techniques:   Assay may be  by the spread  plate, pour plate  or
          membrane filter technique on nutrient agar,  M.F.C. or m-Endo medium
          (Standard Methods for the Examination  of Water  and Wastewater,  16th
          edition,  1985,  APHA).   Each  sample  dilution  will   be  assayed  in
          triplicate.

     3.4.1.2  Virus Tests

     a.   Chosen Organisms:  Poliovirus  type 1  (LSc)  (ATCC-VR-59) ,  and Rota-
          virus Strain SA-11 (ATCC-VR-899)  or WA (ATCC-VR-2018).

     b.   Method  of Production:   All  stocks   should  be  grown by  a  method
          described  by Smith and  Gerba (in Methods in Environmental  Virology,
          pp. 15-47,  1982)  and purified by  the procedure  of Sharp,  et al.
          (Appl.  Microbiol.,  29:94-101,  1975),  or  similar procedure   (Berman
          and  Hoff,  Appl.   Environ.  Microbiol., 48:317-323,  1984),   as these
          methods will produce largely monodispersed virion particles.
                                     N-ll

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c.   State  of  the Organism:  Preparation procedure  will  largely produce
     monodispersed particles.

d.   Assay Techniques:  Poliovirus type 1 may be grown in the 3GM, MA-104
     or other cell line which will support the growth of this virus.  The
     rotaviruses  are best  grown in  the  MA-104  cell  line.   Since  both
     viruses can be assayed on the MA-104 cell line, a challenge test may
     consist of equal amounts  of both viruses  as  a mixture  (i.e.,  the
     mixture must contain  at  least  1.0 x 10 /mL  of  each  virus).  Assays
     may be  as  plaque forming units  (PFU) or  as immunofluorescence foci
     (IF)  (Smith and Gerba,  In:   Methods  in   Environmental  Virology,
     pp. 15-47, 1982).  Each dilution will be assayed in triplicate.

3.4.1.3  Cyst Tests
a.   Chosen Organism

     1.   Giardia lamblia or  the related  organism,  Giardia muris, may be
          used as the challenge  cyst.

     2.   Where filtration.is involved, tests  with  4-6  micron  spheres or
          particles have been found to be satisfactory and may be used as
          a substitute for  tests of occlusion using live  organisms  (see
          Table 1).    Spheres  or particles may only be used  to evaluate
          filtration  efficacy.   Disinfection efficacy can  only be evalu-
          ated with the use of viable Giardia cysts.

b.   Method of  Production:   Giardia muris may be produced in  laboratory
     mice  and   Giardia  lamblia  may  be  produced  in Mongolian  gerbiis;
     ir.activation results   based on  excystation measurements  correlate
     well with animal infectivity results.

c.   State  gj£   the  Organism:   Organisms  may  be  separated  from  fecal
     material  by  the  procedure  described  by  Sauch  (Appl,  Environ.
     Microbiol.,  48:454-455,  1984)   or  by  the   procedure described  by
     Bingham, et al.  (Exp.  Parasitol., 47:284-281, 1979).

d.   Assay Techniques:  Cysts are first  reconcentrated  (500 ml., minimum
     sample  size)  according  to the  method  of  Rice,  Hoff  and Schaefer
     (Appl.  Environ.  Microbiol.,   43:250-251,   1982).   The  excystation
     method described by  Schaefer,  et al.   (Trans., Royal Soc.  of Trop.
     Med.  &  Hyg. 78:795-800,  1984)  shall  be used to evaluate Giardia
     muris  cyst  viability.   For  Giardia  lamblia cysts,  the excystation
     method described by Bingham and Meyer (Nature, 277:301-302, 1979) or
     Rice and Schaefer  (J.  Clin. Microbiol.,  14:709-710,  1981)  shall be
     used.   Cyst  viability may also  be  determined by an  assay method
     involving  the  counting  of  trophozoites  as well .as  intact  cysts
     (Bingham,  et al., Exp. Parasitol., 47:284-291, 1979).

3.4.2  Chemical and Physical Methods
                                N-12

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     All physical and chemical analyses  shall be  conducted  in  accordance  with
procedures  in  Standard  Methods for  the  Examination of Water  and  Wastewater,
16th Edition, American Public Health Association,  or equivalent.


3.5  Test Procedures

     3.5.1  Procedure - Plumbed-in Units
     a.   1.   Install three production  units  of  a type as  shown  in Figure 1
               and  condition  each  unit  prior  to  the  start  of  the  test  in
               accordance with the  manufacturer's  instructions with  the  test
               water without  the addition  of  the  test  contaminant.   Measure
               the flow rate through each  unit.  The unit  shall be  tested  at
               the  maximum  system pressure  of 60  psig  static and  flow  rate
               will not be artificially controlled.

          2.   Test waters shall have the defined characteristics continuously
               except for  test waters 2, 3  and 4  with  respect  to turbidity.
               The background  non-sampling  turbidity  level  will  be maintained
               at  0.1-5 NTU  but  the  turbidity  shall  be   increased to  the
               challenge  level  of   not  less  than  30 NTU   in the  following
               manner:

                    In the "on" period(s) prior to  the sampling "on" period.

                    In the sampling  "on" period when  the sample  actually will
                    be taken.   (Note:  at least 10  unit void volumes of the 30
                    NTU water  shall  pass  through  the  unit prior  to actual
                    sampling  so   as  to  provide  adequate  seasoning  and  uni-
                    formity before sample collection.)

     b.   1.   Use  appropriate techniques  of  dilution  and  insure  continual
               mixing to prepare a challenge solution containing the bacterial
               contaminant.   Then  spike  test water continuously  with  the
               influent concentration specified in  Table 1.

          2.   Use  appropriate techniques  to  prepare concentrated  virus and
               Giardia suspensions.   Feed  these suspensions into the  influent
               stream so  as  to achieve  the  influent concentrations specified
               in Table 1 in the  following manner:

                 -  In the "on" period(s) prior to  the sampling "on" period.

                 -  In  the sampling  "on" period when the sample actually will
                    be taken.  (Note:  at least 10  unit  void volumes  of seeded
                    water shall pass through the  unit prior to sampling  so as
                    to provide adequate  seasoning and uniformity before sample
                    collection.)
                                      N-13

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     c.   Purge  the  system of the uncontaminated water with a sufficient flow
          of  contaminated  test water.   Start an operating cycle of 10 percent
          on, 90 percent off with a 15 to 40 minute cycle (Example:  3 minutes
          on, 27 minutes  off) with  the  contaminated  test  water.   This cycle
          shall be continued for not more than 16 hours per day (minimum daily
          rest period of 8 hours).   The  total program shall extend to 100% of
          estimated  volume capacity for halogenated  resins or units  and  for
          10-1/2 days for  ceramic candles or units and U.V.  units.

     d.   Sampling:  Samples  of influent and effluent water  at the specified
          sampling points  shall be collected  as shown below  for the various
          units; these  are minimum sampling  plans  which may  be  increased in
          number  by the   investigator.   All  samples shall  be  collected  in
          duplicate  from the flowing water during the  sampling "on" portion of
          the cycle  and they shall be one "unit void volume" in quantity (or
          of  appropriate  quantity for  analysis)  and  represent worst  case
          challenge  conditions.   Effluent samples shall  usually  be collected
          near  the  middle  of  the sampling  "on"  period   (or  the  whole volume
          during one "on"  period) except for  samples following the specified
          "stagnation"  periods,  for which sampling shall be  conducted on  the
          first  water volume out of the  unit.   Each  sample  will  be  taken in
          duplicate  and shall  be  retained  and  appropriately preserved,  if
          required,  for chemical or  microbiological analysis  in the event
          verification  is  required.   (For units where the  volume of  a single
          "on" period is insufficient  for the required analysis, samples frcn
          successive "on" periods nay be accumulated  until  a sufficient volume
          has been collected.)

l(a).  Sampling Plan:  Halogenated Resins or Units (Non-iodine Based)
                                                       Tests
Test Point
(% of Estimated
Capacity)

Start
  25%
  50%
After 48 hours
  stagnation
               Influent
               Background
General
Active
Agent/
Residual  k

   X
   X
   X
Microbiological

       X
       X
       X
  60%
  75%
After 48 hours
  stagnation
  100%
Chal-
lenge
pH -
9.0 " 0.2
   X
   X

   X
   X
       X
       X

       X
       X
Kb).  Sampling Plan:  lodinated Resins or Units
                                     N-14

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                                                       Tests
Test Point
 (% of Estimated
Capacity)

Start
  25%
  50%
After 48 hours
  stagnation
General
               Influent
               Background
Active
Agent/
Residual

   X
   X
   X
Microbiological

       X
       X
       X
  60%
  75%
After 48 hours
  stagnation
Chal-
lenge
PH -
9.0 ' 0.2
   X
   X
       X
       X
  90%
 100%
After 48 hours
  stagnation
Chal-
lenge
PH -
5.0 * 0.2
   X
   X
       X
       X
2.  Sampling Plan:  Ceramic Candles or Units and U.V. Units
                                                       Tests
Test Point

Start
Day 3  (middle)
Day 6  (middle)
After 48 hours
  stagnation
                         Influent
                         Background
          General
               Microbiological

                      X
                      X
                      X
Day 7  (middle)
Day 8  (near end)
After 48 hours
  stagnation
Day 10-1/2
          Chal-
          lenge
                      X
                      X

                      X
                      X
 (Note:  All days are "running days" and exclude stagnation periods,  when
 the units contain silver, a leaching test shall be conducted as shown in
 Section 3.5.1.e and silver residual will be measured at each microbiological
 sampling point.)
                                     N-15

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     e.   Leaching  Tests  for  Silverized  Units:    Where  the  unit  ccntair.
          silver,  additional  tests utilizing Test Water #5  will  be conducted
          as follows:

                                                  Tests
                                   Influent
Test Point                         Background               Silver/Residual

Start                                  X                          X
Day 2                 •                                            X
After 48 hours
  stagnation                                                      X
     f.   Alternate Sampling Plans:

          1.   Since some  laboratories  may find it  inconvenient  to  test soir.e
               units on a  16  hour  on/8  hour off  cycle, two  alternates are
               recognized:

                    Go  to  a shorter operational day but  lengthen the days of
                    test proportionally

                 -  Use up  to  20 percent "on"/80 percent  "off"  for  a propor-
                    tionally shorter operational day

          2.   Sampling points must be appropriately adjusted in  any alternate
               sampling plan.

     g.   Application  of  Test  Waters:   The  application of  test  waters  is
          designed to provide information on performance under both norrai and
          stressed  conditions;  it  should be  the same  or equivalent  to the
          following-:

          1.   a.   Halogenated Resins or Units  (Non-iodine based) —

                    First 50% of test period:     Test Water 1  (General)
                    Last 50% of test period:      Test Water 2  (Challenge)
                                                   (pH - 9.0 * 0.2)

               b.   lodinated Resins or Units  —

                    First 50% of test period:     Test Water 1  (General)
                    Next 25% of test period:      Test Water 2  (Challenge)
                                                   (pH - 9.0 ' 0.2)
                    Last 25% of test period:      Test Water 2  (Challe ge)
                                                   (but with pH -  5.0  * C.2)

          2.   Ceramic Candles or Units —

               First 6 days of testing:           Test Water 1  (General!
                                     N-16

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          Last 4-1/2 days of testing:

     3.   Ultraviolet (U.V.) Units —

          First 6 days of testing:
          Last 4-1/2 days of testing:

h.   Analyses and monitoring:
Test Water 3 (Challenge)
Test Water 1 (General)
Test Water 4 (Challenge)
     1.   Microbiological sampling and analysis shall be conducted of the
          specified  influent  and  effluent  sampling  points  during  each
          indicated sampling period.

     2.   Test Water Monitoring:  The specified parameters of the various
          test waters (see Section 3.3) will be  measured and recorded at
          each microbiological  sampling  point; the  specified  parameters
          will be  measured  at least  once on  non-sampling days  when the
          units are being operated.

     3.   Background chemical  analyses of  influent  watsr shall  be  con-
          ducted  at  least  once  at  the  start of  each  test  period  to
          determine the  concentration  of the  U.S. EPA  primary inorganic
          contaminants,   secondary contaminants  and  routine  water  para-
          meters, not otherwise covered in the described test waters.

     4.   In addition, quality  assurance testing shall  be conducted for
          the seed bacteria  under environmental conditions  on the  first
          and last days  of testing to make sure that there is no signifi-
          cant change over  the test  day.   Populations  will be measured
          (for example,  as dispersed in the  supply tank) at the beginning
          and end  of the test day to  detect possible incidental effects
          such as  proliferation,  die-off,  adsorption to  surfaces,  etc.
          Relatively stable bacterial seed  populations  are  essential to
          an acceptable  test program.

     5.   When a .unit contains  a halogen  or silver,  the  active  agent
          residual will  be measured in the effluent at each microbiologi-
          cal test (sampling) point.

     6.   Silver will additionally be  measured three times in  the efflu-
          ent as specified in Section 3.5.I.e.

     Neutralization  of   Disinfection  Activity:   Immediately  after  col-
     lection, each test  sample  must  be  treated to  neutralize residual
     disinfectant.  For  halogen-  and  silver-based disinfectants this may
     be  done  by  addition   of  thioglycollate-thiosulfate   neutralizer
     solution (Chambers, et al., J. Amer. Water Works Assoc., 54:208-216,
     1962).   This  solution should  be prepared  daily.   All  results are
     invalid unless samples are neutralized immediately upon collection.

     Special Provisions  for Ceramic Candles or Units:
                                N-17

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     1.   Provisions  for slow  flow:   Ceramic  units may  be  subject  to
          clogging  and greatly reduced  flow over  the  test period.   An
          attempt  should  be  made  to  maintain  manufacturer  rated  or
          claimed  flow  rates,  but even at  reduced  flows  the  sampling
          program set  forth in Section 3.5.1.d.2 shall be maintained.

     2.   Cleaning of  ceramic units:   Units  should be  cleaned according
          to  manufacturer's  directions.   Two  cleanings  should  occur
          during  the  period of   test   (in  order  to prove  the  unit's
          durability through  the  cleaning  procedure).   However,  near the
          time  of  microbiological sampling,  the  units  should  not  be
          cleaned until  after the sampling.  Further,  no anti-microbial
          chemical  (for  cleaning  or  sanitizing)  may be applied  to the
          units during the  test period unless the manufacturer specifies
          the same as part of routine maintenance.

k.   Halogenated units or U.V. units with mechanical filtration processes
     separate from the microbiological disinfection components shall have
     the  mechanical  filtration  components  replaced or  serviced  when
     significant flow  reduction  (clogging)  occurs  in  accordance  with the
     manufacturer's instructions in order to maintain the test flow rate.
     Units  with  non-removable mechanical  filtration components  will  be
     run  until  flow  is below  that considered  acceptable  for  consumer
     convenience.   (If  premature  clogging  presents  a  problem,  some
     specialized units may require a customized test plan.)

1.   Special Provisions  for Ultraviolet  (U.V.) Units:

     1.   The units will be  adequately challenged by the prescribed test
          waters; consequently they will be operated at normal intensity.
          However,  where the U.V.  treatment component  is preceded  by
          activated carbon  treatment,  the  output of  the  U.V.  lamp shall
          be adjusted  electronically,  such as by  reducing the current to
          the lamp or other appropriate means, to be just above the alarm
          point.  This option shall be available for use under other U.V.
          configurations, at  the  choice of the persons  responsible for
          testing, as  an alternative to the use of  the  U.V.  absorbent,
          p-hydroxybenzoic acid.

     2.   Fail/safe:  Units will provide and will be tested for fail/safe
          warnings  in  the event  of water quality changes  or equipment
          failures which may interfere with its microbiological purifica-
          tion function.

     3.   Cleaning:   Manufacturer's guidance with  respect to  cleaning
          will be followed.

3.5.2  Procedure;  Non-Plumbed Units
a.   General:  The basic procedures given  in Section 3.5.1 shall  be used
     with necessary adaptations  to allow  for the  specific design of the
                                N-18

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          unit.   In any event,  the  testing procedures  shall provide a  test
          challenge equivalent to those for plumbed-in units.

     b.   Test conditions and  apparatus  should be  adapted  to  reflect proposed
          or  actual use  conditions  in  consultation  with the  manufacturer,
          including flow rate  and number of people to be  served per day.   In
          some cases  variable flow  or other non-standard conditions may  be
          necessary to reflect a worst-case test.

     3.5.3  Acceptance and Records

     3.5.3.1
     To  qualify  as  a microbiological water purifier,  all  three  production
units of a type must continuously meet or exceed the reduction requirements of

Table 1, within allowable measurement tolerances for not more  than ten percent
of influent/effluent sample pairs, defined as follows:
          Virus:         one order of magnitude
          Bacteria:      one order of magnitude
          Cysts:         one/half order of magnitude

     The geometric mean of  all microbiological  reductions  must meet or exceed

the requirements of Table 1.  An example is given as follows:


          Unit:  iodinated resin.

       -  Number of sample pairs over the completed test program:
          10 per unit — 3 units » 30.

       -  Number of  allowable sample  pairs where  log reduction  is  insuffi-
          cient:  10% of 30 « 3 sample pairs.

       -  Allowable minimum log reductions in these 3 pairs:

               Bacteria  -  5 log
               Virus     -  3 log
               Cyst      -  2-1/2 log

       -  Conclusion:   If  the  geometric  mean  of  all reductions meets  or
          exceeds  the  requirements of  Table 1,  the  indicated insufficient
          sample pairs will be allowed.

     3.5.3.2  Records
                                     N-19

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     All pertinent procedures  and  data  shall  be  recorded in a standard format
and  retained  for possible review  until the  report  of results has  been  com-
pletely accepted by review authorities, in no case for less than a year.
     3.5.3.3  Scaling Up or Down
     Where  a  manufacturer  has  several similar  units using  the same  basic
technology  and  parallel  construction  and  operation,  it may  sometimes  be
appropriate to  allow  the  test of one unit  to be considered representative of
others.   Where  any  serious  doubt exists,  all   units of  various  sizes  may
require  testing.  A  "rule  of three"  is  suggested  as a matter  of  judgment.
Scaling up to three times larger or on-third,  based  on the size  of either the
test unit or of  its operative element, may be allowed.  However,  for UV units,
any  size  scale-up must  be accompanied by a  parallel increase  in  radiation
dose.
     3.5.3.4
     Where silver or  some other chemical is  used in the unit, concentrations
in the  effluent water must meet any  National Primary  Drinking  Water Maximum
Contaminant Level  (MCL),  additional Federal guidelines, or otherwise must rot
constitute a threat to health where no MCL exists.
                                     N-20

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                                 APPENDIX N-l

           SUMMARY FOR BASIS OF STANDARDS AND TEST WATER PARAMETERS


A.   Microbiological Reduction Requirements

     1.   Bacteria

               Current  standards  for the  microbiological  safety  of  drinking
          water  are based on  the  presence of  coliform bacteria of  which
          Klebsiella is  a member.   Members  of  the genus Klebsiella  are also
          potential pathogens of man (Vlassof, 1977).  Klebsiella terrigena is
          designated  as  the  test  organism  since it  is commonly found  in
          surface waters  (Izard, et  al., 1981).

               Experience  with  the use of  coliform bacteria to  estimate  the
          presence of  enteric bacterial pathogens in drinking water  as per-
          formed over the  last  75 years indicates a  high degree  of reliabil-
          ity.  Required  testing  of more than one bacterial  pathogen appears
          unjustified  since  viral  and Giardia   testing  will  be  required.
          Enteric viruses  and Giardia are known to be more resistant to common
          disinfectants than enteric bacterial pathogens and  viruses  are more
          resistant  to  removal by  treatments such  as filtration. Thus,  any
          treatment which  would give a  good  removal of both  virus and Giardia
          pathogens  would most  likely  reduce enteric bacteria  below levels
          considered infectious (Jarroll, et al.,  1981; Liu,  et al., 1971).

               The concentration of  coliform bacteria in raw sewage is approx-
          imately 10 /100  ml.   Concentrations in  polluted stream waters have
          been found to exceed 10  per 100 ml (Culp, et al.,  1978, Table 10).

               Based on the over  10  /100 ml  concentrations observed in highly
          polluted stream water and a  target effluent concentration  of less
          than 1/100 ml, a 6 log reduction is recommended.

     2.   Virus

               In the United  States  concentrations of enteroviruses are esti-
          mated to range  from 10  -10 /liter  in  raw sewage (Farrah and Schaub,
          1971).   Based  on  this  observation it  is  estimated  that, natural
          waters  contaminated with  raw sewage  may contain  from 10   to  10
          enteric viruses  per liter.

               There are  currently  no  standards  for viruses  in drinking water
          in  the  United  States.   However,  EPA has proposed  a non-enforceable
          health-based  recommended  maximum  contaminant  level  (RMCL)  of zero
          for viruses (EPA, 1985) .   Several  individuals and organizations have
          developed  guidelines  for the presence of viruses  in drinking water
          and various experts have  proposed  standards (WHO,  1979, 1984; Berg,
          1971;  Melnick,   1976).   It has  generally  been  felt  that  drinking
                                     N-21

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     water  should  be free  of  infectious virus  since  even one  virus  i.-
     potentially infectious and .suggested standards  are  largely  based  on
     technological  limits  of  our  detection  methodology.   Guidelines
     suggested  by  the  World  Health  Organization  (1984)  and  others
     recommend  that  volumes to be  tested be  in the order  of  100-1,000
     liters and that viruses be absent in these volumes.

          Assuming a target effluent  level of  less  than  one virus in 100
     liters of  water  and a concentration of  10  enteric viruses  in 100
     liters  of  sewage-contaminated  waters,   the  water  purifier  units
     should achieve at least 4 logs of virus removal.

          The relative  resistance of  enteric  viruses to  different dis-
     infectants varies greatly  among  the enteric viruses  and  even among
     members of the same group  (i.e.,  enteroviruses).  For example, while
     f2 coliphage is one of the most resistant viruses to inactivation by
     chlorine it is one  of  the  most susceptible to inactivation by ozone
     (Harakeh and Butler, 1984).  Ionic conditions and pH can also affect
     the  relative  resistance  of  different  viruses to  a  disinfectant
     (Engelbrecht,  et al.,  1980).   On  this  basis  it  is felt  that more
     than one enteric  virus should be  tested to ensure the  efficacy  of
     any disinfection system.   Poliovirus typ« 1 (Strain LSc)  was chosen
     as one of  the  test viruses because it has  been extensively used in
     disinfection  and  environmental  studies  as  representative of  the
     enterovirus  family.   It  is  recognized  that  it  is   not   the  most
     resistant virus to  inactivation  by  chlorine,  but  is  still  resistar.t
     enough to serve as a useful indicator.   Rotavirus is selected as the
     second  test  enteric  virus  since   it  represents another   group  of
     enteric viruses in  nucleic acid  composition and size.   It  is also a
     major cause of  viral gastroenteritis and has been documented  as a
     cause  of  water borne  gastroenteritis  (Gerba,  et al. , 1985).   The
     human rotavirus or  the  similar Simian  rotavirus may be used in the
     test procedure.   A  net  4-log reduction  for  a joint  challenge  of
     1  x 10 /L each for poliovirus and rotavirus is recommended.

3.   Cysts (Protozoan)

          Over the past  several years,  giardiasis  has  consistently been
     one of the most frequently reported waterborne diseases transmitted
     by drinking  water  in the  United  States  (Craun,  1984).    EPA  has
     proposed a RMCL of zero for Giardia (EPA, 1985).  Its occurrence has
     generally  been  associated with  treatment  deficiencies  including
     either inadequate or  no filtration.  Giardiasis has  not been known
     to occur from  drinking water  produced  by  well-operated  filtration
     treatment plants.   De Walle,  et al. (1984), in a study of filtration
     treatment plant efficiencies, cited percent removals  for  Giardia  in
     pilot plant tests as follows:

       -  Rapid  filtration with coagulation-sedimentation:   96.6-99.9%;

       -  Direct filtration with coagulation:  95.9-99.9%.
                                N-22

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               From  this  research and  from  the  lack  of  Giardia cases  in
           systems where  adequate  filtration  exists, a 3-log (99.9%) reduction
           requirement  is  considered  to be  conservative  and  to provide  a
           comparable   level   of   protection   for  water   purifiers    to   a
           well-operated  filtration treatment plant.

               Data  on  environmental  levels  for  cysts  in natural waters  is
           limited  because  of  the  difficulties  of  sampling  and  analysis.
           Unpublished  data  indicate very low levels  from less than 1/L to less
           than 10/L.   Here  a 3-log reduction would provide an effluent of less
           than 1/100 L,  comparable to the recommended virus reduction require-
           ments.

               Either  Giardia  lamblia  or the  related organism,  Giardia muris,
           which  is reported to be a  satisfactory test organism (Hoff,  et al.,
           1985) , may  be  used  as  the  challenge organism.  Tests  will  be con-
           ducted  with a challenge of  10   organisms  per  liter  for  a  3-log
           reduction.

               Where the treatment unit or component for cysts is based on the
           principle of occlusion  filtration  alone, testing for a 3-log reduc-
           tion of 4-6  micron particles or spheres  (National Sanitation Founda-
           tion Standard  53, as an example)  is acceptable.  Difficulties in the
           cyst  production  and measurement   technologies  by  lesser-equipped
           laboratories may require  the  use of such  alternative  tests  where
           applicable.

B.   Microbiological Purifier  Test Procedures

     1.    Test Waters

           a.   The ^general test  water  (test  water *1)   is  designed  for  the
               normal, non-stressed phase of testing with  characteristics that
               may easily  be obtained  by the adjustment  of many public system
               tap waters.

           b.   Test  water #2   is  intended  for  the stressed phase of  testing
               where units  involve halogen disinfectants.

               1.   Since  the   disinfection  activity "of some  halogens  falls
                    with a rising pH,  it  is  important  to stress  test  at an
                    elevated pH.   The recommended  level  of  9.0 * 0.2,  while
                    exceeding  the recommended  secondary level  (Environmental
                    Protection Agency,  1984)  is  still within  a  range  seen in
                    some  natural  waters   (Environmental  Protection  Agency,
                    1976).  However,  for iodine-based units, a second stress-
                    ful  condition  is provided  — a pH  of.  5.0 * 0.2  since
                    current information  indicates   that  the   disinfection
                    activity of iodine falls with  a low pH  (National  Research
                    Council, 1980).   While beneath the  recommended secondary
                    level  (Environmental Protection Agency, 1984) a pH of 5.0
                                      K-23

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          is not unusual in natural waters (Environmental Protection
          Agency, 1976).

     2.   Organic matter as  total organic carbon  (TOO  is  known to
          interfere with  halogen disinfection.  While  this TOC is
          higher than  levels  in  many  natural  waters,  the designated
          concentration of  10 mg/L  is cited  as  typical in  stream
          waters (Culp/Wesner/Culp, 1978).

     3.   High concentrations of turbidity can shield microorganisms
          and  interfere  with disinfection.   While the  recommended
          level of not less than  30 NTU is  in the  range  of  turbidi-
          ties seen in secondary wastewater effluents, this  level is
          also  found  in  many   surface  waters,  especially  durir.g
          periods of heavy rainfall and snow melt (Culp/Wesner/Culp,
          1978).

     4.   Studies with  Giardia  cysts have  shown decreasing halogen
          disinfection  activity  with  lower  temperatures   (Jarroll,
          et al.,  1980);  4  C,   a common  low  temperature  in  many
          natural waters,  is recommended for the stress test.

     5.   The  amount  of   dissolved   solids   (TDS)  may  impact  the
          disinfection effectiveness of units that  rely on displace-
          afale or exchange  elements  by displacement  of  halogens or
          resins, or  it may  interfere with   adsorptive  processes.
          While TDS  levels  of 10,000 mg/L are  considered  unusable
          for drinking, many  supplies with  over  2,000 mg/L  are used
          for  potable  purposes   (Environmental  Protection  Agency,
          1984).  The  recommended level  of 1,500 mg/L represents  a
          realistic stress challenge.

c.   Test water #3 is  intended for the stressed  phase of testing of
     ceramic  filtration candles  or  units  with or  without  silver
     impregnation.

     1.   Since viruses are typically eluted from adsorbing  media at
          high pHs (Environmental Protection Agency, 1978) it may be
          concluded that a  high  pH will provide the  most stressful
          testing for  a ceramic-type  unit;  consequently,  the high
          natural water pH of 9.0 is recommended.

     2.   Expert  opinion   also   holds that  organic  material  will
          interfere with adsorption of viruses.  Thus, a high total
          organic carbon  level  of not less  than 10  mg/L is  recom-
          mended .

     3.   Turbidity  may  enhance  the  entrapment   and  removal  of
          microorganisms   but   it   also   may  stimulate   "short-
          circuiting"  through some  units.   A  turbidity   level  of
          30 NTU will  provide stress  at  time  of  sampling but the

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               non-sampling level of 0.1-5  NTU will  allow routine opera-
               tion of units.

          4.   Expert opinion holds that  low water temperatures  and high
               TDS would  most likely interfere  with virus  reduction  by
               adsorption; consequently, a 4 C temperature and 1,500 mg/L
               TDS are recommended.

     d.   Test water #4 is intended for the stressed phase of testing for
          ultraviolet (UV) units.

          1.   In general, high  TOC,  turbidity and  TDS  and  low tempera-
               ture  are  considered most  stressful  for  UV,  and  the in-
               dicated  challenge  levels   are  the   same  as  for  test
               water #2.

          2.   The pH is not critical and may range from 6.5 to 8.5.

          3.   In order  to test  the  UV  units at their  most vulnerable
               stage of operation, a color challenge (light absorption at
               254 run)  is to  be maintained  at a  level where  UV  light
               intensity is just above the unit's low  intensity warning
               alarm  point.   However,  an  alternate to the  absorption
               challenge is provided through adjusting the light intensi-
               ty  output  of  the UV   lamp  electronically  by  red-jcir.g
               current to  the lamp,  or other appropriate  means,  to  be
               just  above  the  alarm  point;  this  approach  would  be
               particularly necessary  where the  UV  lamp is  preceded  by
               activated carbon treatment.

     e.   Test water  #5  is intended for  the  stressed  leaching  tests  of
          units containing silver.   Low pH, TOC,  turbidity,  and TDS ar.d
          higher temperature  are felt  to be  the  characteristics associ-
          ated  with  increased  leachability.   The  recommended  pH  of
          5.0 * .2, while  being  beneath  the  recommended secondary  range
          of  6.5-S.5 (Environmental  Protection Agency,  1984)   is  still
          found in some natural waters.

2.   Test Procedures

          The plan  for  testing  and  sampling is designed  to reveal unit
     performance under both "normal" and "stressed"  operating conditions.
     The stressed phase  would utilize a  set  of water quality and opera-
     tions conditions to give the units a realistic worst case challenge.
     Testing  plans  for a  specific  model might  involve modifications  to
     the recommended plan; more  samples could  be taken and analyzed; more
     units  could  be  studied.   The  principle of  demonstrating  adequate
     performance  even under  realistic worst  case  conditions  should  be
     maintained and  the  final selected test  procedures should be agreed
     as between investigators and reviewers or regulators.
                                N-25

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     While some aspects of the testing procedures have been utilized
in actual  experiments,  the proposed protocol has  not been verified
or utilized  for the various  units  that may be  considered..  Conse-
quently, investigators  and users of this protocol may find reasons
to alter  some  aspects  through  their  practical experience;  needed
changes should  be discussed  and cleared with  involved reviewers/-
regulators.
                           N-26

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REFERENCES;

Berg,  G.   Integrated approach to  the  problem of viruses in water,   j.  ASCE,
Sanit. Eng. Div. 97:867-882, 1971.

Culp/Wesner/Culp.   Guidance  for  planning  the  location of water supply intakes
downstream from municipal wastewater treatment facilities.  EPA Report, Office
of Drinking Water.  Washington, DC, 1978.

Craun, G. F.  1984.  Waterborne outbreaks of giardiasis:  Current status.  In:
Giardia and  giardiasis.   D.  L. Erlandsen and E. A. Meyer Eds.,  Plenum Press,
New York, pp. 243-261, 1984.

DeWalle,  F.  B.;  j.  Engeset;  Lawrence,  W.  Removal  of Giardia  lamblia cyst by
drinking  water  treatment  plants.   Report No.  EPA-600/52-84-069,  Office  of
Research  and Development, Cincinnati, OH, 1984.

Engelbrecht, R. S. ,  et al.   Comparative  inactivation of  viruses  by chlorine.
Appl. Environ. Microbiol.  40:249-256, 1980.

Environmental Protection Agency.  Quality criteria for water.  Washington, DC,
1976.

Environmental   Protection   Agency.    National   secondary   drinking   water
regulations.  EPA-570/9-76-000, Washington, DC, 1984.

Environmental Protection Agency.  National primary drinking water regulations;
synthetic organic chemicals,  inorganic chemicals and microorganisms;  Proposed
rule.  Federal Register, Nov.  13, 1985.

Farrah, S. R. ,  and  S. A. Schaub.  Viruses in wastewater sludges.   In:  Viral
Pollution  of  the Environment, G.  Berg,  Ed.   CRC Press,  Boca  Raton,  Florida.
pp. 161-163, 1983. ~"

Gerba, C. P.; Rose,  J. B.; Singh,  S.  N.   Waterborne gastroenteritis and viral
hepatitis.  CRC Critical Rev.  Environ. Contr.  15:213-236, 1985.

Harakeh,  M.;  Butler,  M.   Inactivation  of human  rotavirus,  SA-11 and  other
enteric viruses in effluent by disinfectants.  J. Hyg. Camb. 93:157-163, 1984.

Hoff, J.  C.;  Rice,  E. W.; Schaefer,  F.  W.  Comparison  of  animal infectivity
and  excystation  as  measures  of  Giardia muris cyst  inactivation  by chlorine.
Appl. Environ. Microbiol.  50:1115-1117, 1985.

Izard, D.;  Farragut,  C.;Gavini,   F.;  Kersters,   K.;  DeLey,  J.;   Ledere,  H.
Klebsiella terrigena, a  new  species  from water and soil.  Intl. J. Systematic
Bacteriol.  31:116-127, 1981.

Jakubowski, w.   Detection  of  Giardia  cysts  in drinking  water.   In:   Giardia
and  Giardiasis,  Erlandsen,   S.  L.;  Meyer,  E.  A.   Eds.,  Plenum  Press,  NY.
pp. 263-286, 1984.
                                      N-27

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Jarroll, E. L.;  Bingham,  A.  K.;  Meyer,  E.  A.    Giardia  cyst  destruction:
Effectiveness of  six  small-quantity  water disinfection methods.   Am.  j. Trop.
Med.  29:8-11, 1980

Jarroll, E. L.; Bingham,  A.  K.; Meyer,  E.  A.  Effect  of  chlorine  on Giardia
cyst viability.  Appl. Environ. Microbiol.  43:483-487, 1981.

Liu, 0.  C.,  et al.  Relative resistance  of 20 human  enteric  viruses to free
chlorine in Potomac River water.  Proceedings of 13th Water Quality Conference
Snoeyink, V.; Griffin, V. Eds., pp. 171-195, 1971.

Melnick, J. L.    Viruses   in  water.    In:    Viruses  in  Water   Berg,  G.;
Bodily, H. L.;  Lennette,  E. H.; Melnick,  J. L.;  Metclaf  T.  G.,  Eds.   Amer.
Public Hlth. Assoc., Washington, DE, pp. 3-11, 1976.

National Research  Council.   The disinfection of  drinking water,  In:  Drinking
Water and Health, Volume 2.  Washington, DC, pp.  5-137, 1980.

National  Sanitation  Foundation.   Drinking  water   treatment  units:   Health
effects.  Standard 53.  Ann Arbor, MI, 1982.

Vlassoff, L. T.    Klebsiella.    In:    Bacterial   Indicators/Health   Hazards
Associated with Water Hoadley, A. W.; Dutka, B. J., Eds.  American Society for
Testing and Materials, Philadelphia, PA.  pp. 275-288,  1977.

World  Health  Organization.    Human  Viruses  in  Water,   Technical  Support
Series 639, World Health Organization, Geneva, 1979.

world Health Organization.  Guidelines  for  Drinking Water Quality.   Volume 1.
Recommendations.  World Health Organization, Geneva, 1984.
                                     N-28

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                                 APPENDIX N-2

     LIST OF PARTICIPANTS;  TASK FORCE ON GUIDE STANDARD AND PROTOCOL FOR
                    TESTING^MICROBIOLOGICAL WATER PURIFIERS


Stephen A. Schaub, Chairman — U.S. Army Medical Bioengineering Research and
     Development  Laboratory  (USAMBRDL),  Fort Detrick,  Maryland  21701,  FTS:
     8/935-7207 — Comm:  301/663-7207.

Frank A. Bell; Jr., Secretary — Criteria and Standards Division,  Office of
     Drinking  Water  (WH-550),  Environmental  Protection Agency,  Washington,
     D.C. 20460, Phone:  202/382-3037.

Paul Berger, Ph.D. — Criteria and Standards Division, Office of Drinking
     Water  (WH-550),  Environmental  Protection Agency, Washington,  D.C. 20460,
     Phone:  202/382-3039.

Art Castillo — Disinfectants Branch, Office of Pesticide Programs (TS-767CO,
     Environmental Protection Agency, Washington, D.C. 20460, Phone:  703/557-
     3695.

Ruth Douglas — Disinfectants Branch, Office of Pesticide Programs (TS-767O,
     Environmental Protection Agency, Washington, D.C. 20460, Phone:  703/357-
     3675.

Al Dufour — Microbiology Branch, Health Effects Research Laboratory,
     Environmental Protection Agency, 26 W. St. Clair Street, Cincinnati, Ohio
     45268, Phone:  FTS:  8/684-7870 — Comm:  513/569-7870.

Ed Geldreich — Chief, Microbiological Treatment Branch, Water Engineering
     Research  Laboratory,  Environmental  Protection Agency,  26  W.  St.  Clair
     Street,  Cincinnati,  Ohio  45268,  Phone:   FTS:   8/684-7232  —  Conm:
     513/569-7232.

Charles Gerba — Associate Professor, Department of Microbiology and
     Immunology,   University   of  Arizona,   Tucson,   Arizona  85721,  Phone:
     602/621-6906.

John Hoff — Microbiological Treatment Branch, Water  Engineering Research
     Laboratory,  Environmental  Protection  Agency,  26 W.  St.  Clair Street,
     Cincinnati, Ohio 45268, Phone:  FTS:  8/684-7331 -- Comm:  513/569-7331.

Art Kaplan — Office of Research and Development  (RD-681) Environmental
     Protection Agency, Washington, D.C. 20460, Phone:  202/382-2583.

Bala Krishnan  —  Office  of  Research  and Development  (RD-681)  Environmental
     Protection Agency, Washington D.C. 20460, Phone:  202/382-2583.

John Lee — Disinfectants Branch, Office of Pesticide Programs  (TS-767C)
                                      N-2 9

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     Environmental   Protection  Agency,   Washington,   D.C.   20460,   Phone:
     703/557-3663.

Dorothy Portner — Disinfectants Branch, Office of Pesticide Programs
     (TS-767-C),  Environmental  Protection  Agency,   Washington,  D.C.  20460,
     Phone:  703/557-0484.

Don Reasoner — Microbiological Treatment Branch, Water Engineering Research
     Laboratory,  Environmental Protection  Agency,  26  w.  St.  Clair  Street,
     Cincinnati, Ohio 45268, Phone:  312/654-4000.

P. Reguanthan  (Regu) — EVerpure, Inc., 660 N. Blackhawk Drive, Westmont,
     Illinois 60559, Phone:  312/654-4000.

David Stangel — Policy and Analysis Branch, Office of Compliance Monitoring,
     Environmental Protection Agency, Washington, D.C., Phone:  202/382-7845.

Richard Tobin — Monitoring and Criteria Division, Environmental Health
     Center, Department  of Health  and Welfare  of  Canada,  Tunney's Pasture,
     Ottawa, Ontario, K1A OL2, Canada, Phone:  613/990-8982.
                                     N-30

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                                 APPENDIX N-3

    PZSPONSE BY REVIEW SUBCOMMITTEEfl) TO PUBLIC COMMENTS ON GUIDE STANDARD
           AND PROTOCOL FOR TESTING MICROBIOLOGICAL WATER PURIFIERS
A.   Recommendation for the use of  Giardia  lamblia cysts as a replacement for
     Giardia muris cysts as the protozoan cyst test organisms.

Recommendation;

     The subcommittee concurs with the recommendation and further endorses the
     use of  Giardia  lamblia as the preferred cyst  test  for evaluation of all
     treatment  units  and  devices.  Obviously the  use of the  protozoan orga-
     nisms  of actual  health  concern  in  testing  is  most  desirable.   Anyone
     finding  the  Giardia  lamblia   strain   feasible  for   testing  and  cost-
     effective  to work with  is  encouraged to  use  same  instead  of  Giardia
     nuris.

B.   Substitution of 4-6 micron bead  or particle tests  as an alternate option
     instead of the Giardia cysts for evaluating devices that rely strictly on
     occlusion  filtration  for  microbiological  removal:   Several  commenters
     criticized  the  use  of beads  or particles  (e.g.,  A.C.  fine dust)  and
     recommended only use of live Giardia cysts for performance tests.

discussion;

     The  subcommittee  recognizes  and favors  the  use   of  the natural  human
     parasite, Giardia lamblia, but was not aware of any convincing scientific
     data  which would  disallow  the  optional  use  of testing  with beads  or
     particles for units or devices  using only  occlusion filtration to remove
     microorganisms.  Previous development of the National Sanitation Standard
     (NSF) 53  (1982)  requirement  for cyst reduction  (using 4-6 micron parti-
     cles as  cyst models) was based on engineering and scientific opinion and
     experimental  evidence  at  that  time.   Specifically,  Logsdon     used
     radioactive  cyst  . models  in  the initial  phase of a  study  of  removal
     efficiencies for  diatomaceous  earth  filters;  subsequent experiments with
     Giardia  muris  cysts  confirmed  the  efficacy  of the  diatomaceous earth
     filters.   Further studies by  Hendricks     and  DeWalle     with  Giardia
     lanblia   cysts   also  showed   comparable  reduction   efficiencies  for
     diatomaceous earth filters.
     l.S.A. Schaub;     F.A.  Bell,  Jr.;     P.  Berger;     C. Gerba;    J. Hoff;
     P. Regunathan;  and R. Tobin.   [Includes  additional  revision pursuant to
     Scientific  Advisory  Panel  review  (Federal  Insecticide,  Fungicide,  and
     Rodenticide Act).]
                                     N-31

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     Subsequently  confirmatory parallel  testing results have  been developed
     vis-a-vis  4-6 micron  particles  as  compared  to  Giardia  lamblia  cysts.
     Specifically,  two  units  listed  by  NSF  for  cyst  reduction  (using  4-6
     micron particles)    have also been tested  and lifted for 100% efficiency
     reduction  (using Giardia lamblia  cysts) by  Hibler   :

          1.    Everpure  Model QC4-SC
          2.    Royal Boulton Model F303.

     Again we prefer the use  of  the human pathogen, Giardia lamblia; however,
     no experimental data has  been  provided regarding the lack of validity or
     of failure in previous tests utilizing beads or particles of 4-6 microns.
     In most cases  the  bacterial  or viral challenges to occlusion filters ill
     represent  a  greater  problem  in  terms   of  microbiological  reduction
     requirements  than  will  cysts.    Therefore,   without  substantiation  of
     deficiencies, the  use  of  4-6 micron beads  or  particles  is considered to
     be as  feasible  as the use of  live cysts  for routine performance testing
     of water filtration  (occlusion) devices.

Seeonmendation;

     Recommend  retaining  the optional  use of 4-6 micron particles or beads for
     cyst reduction testing in occlusion filtration devices only.

References;

          Logsdon, G. S. ,  et al.   Alternative Filtration Methods for Removal
          of Giardia Cysts and Cyst Models, JAWWA, 73(2)111-118, 1981.

          Logsdon, G. S.; Hendricks,  D.  W., et  al.  Control  of Giardia Cysts
          by Filtration.-  The Laboratory's  Ro'se.  Presented at the AWWA Water
          Quality Technology Conference, December, 1983.

          DeWalle, et al.  Removal  of  Giardia  lamblia  Cysts by Drinking Water
          Treatment  Plants,  Grant  No. R806127,  Report  to  Drinking  Water
          Research Division, U.S. EPA  (ORD/MERL), Cincinnati, Ohio.

     (4)
          National Sanitation Foundation,  Listing of Drinking Water Treatment
          Units, Standard 53.  May, 1986.

          Hibler, C. P.   An  Evaluation of  Filters  in the  Removal  of Giardia
          lamblia.  Water Technology,  pp. 34-36.  July, 1984.

C.   Alternate assay techniques for cyst tests (Jensen):  Proposed alterations
     in cyst tests include a different method  for separating cysts from fecal
     material and  an  assay method  involving the counting  of trophozoites as
     well as intact cysts.  Both alterations have been used by- Bingham, et -al.
     (Exp. Parasitol.,  47:284-291, 1979).

Recommendation:
                                     N-32

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     These alterations appear to be reasonable laboratory procedures,  support-
     ed  by a  peer-reviewed  article  and  will be  included in  the  Report  as
     options for possible development and use by interested laboratories.

D.   The use  of pour plate  techniques  as an option for  Klebsiella  terrigena
     bacteria analyses.

Recommendation;

     The pour plate technique adds a  heat  stress factor  to the  bacteria  which
     constitutes a possible  deficiency.   However,  it is  a recognized standard
     method and probably  will  not adversely affect the  Klebsiella  terrigena.
     Consequently, it  will be  added  to the Report as  one of  the  acceptable
     techniques.

E.   Option of using Escherichia  coli in  lieu  of  Klebsiella terrigena for the
     bacterial tests.

Discussion;

     Appendix N-l, Section A.I. of the  Guide  Standard and Protocol  sets  forth
     the basis for  selection  of K.  terrigena as  the  test  bacteria.   The
     selection was made along pragmatic  line  emphasizing the occurrence  of K^
     terrigena  in  surface  waters and  that  it  would  represent  the  enteric
     bacteria.  It was also pointed out  that  the tests with virus and Giardia
     were expected to be more severe  than the bacterial  tests.   For comprehen-
     siveness, bacterial tests were included in the protocol but were not felt
     to be as crucial as the virus and Giardia tests.

     E.  coli,  or  any number of other generally accepted  indicator  bacteria,
     could  be used  for  the  test program  if they  were  shown  to  have  good
     testing and survival  characteristics  (equivalent to K. terrigena)  by the
     interested research laboratory.

Recommendation;

     The intent of the Guide Standard  and Protocol is  to provide  a baseline
     program subject to modification  when properly supported by an interested
     laboratory.   Consequently,  any  laboratory could propose and with proper
     support  (demonstrating  challenge and  test  equivalency to  K.  terrigena)
     use Escherichia  coli or  one of the  other enteric  bacteria.   This idea
     will be included in revised working in Section 1.2.2,  "General Guide."

F.   Performance requirements  for Giardia cysts and virus in relation to the
     EPA-Recommended Maximum Contamination Levels  (RMCLs)  of zero.

Discussion;

     The RMCLs of  zero for Giardia and viruses which have  been proposed by EPA
     are health goals.  They are no enforceable standards since to assure the
     presence  of  "no  organisms"  would  require   an  infinite   sample.   The
                                      N-33

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      rationale  for  the  recommended performance requirements for Giardia cyst i
      and  virus  is set  forth  in  Sections A.2 and A.3 of  Appendix A.   We feel
      that  these requirements  together  with  the application of realistic worst
      case  test  conditions will provide a conservative test for units resulting
      in  treated effluent water  equivalent  to that  of  a public water supply
      meeting  the  microbiological  requirements  and  intent  of the  National
      Primary  Drinking Water Regulations.

Recommendation;

      Retain recommended performance (log reduction)  requirements  for cyst and
      virus reduction.

G.    Rotavirus  and  its proposed  assay:   One commenter states  that  the rota-
      virus tests are impractical  because Amirtharajah  (J. AWWA,  78 (3) :34-49,
      1976) cites "no satisfactory  culture procedures available for analysis of
      these pathogens and, therefore, monitoring would not be feasible."

Discussion;

      Section  3.4.1.2,  "Virus  Tests" of  the  Report,  presents means  for cul-
      turing  and assaying  rotaviruses.  This means  for  doing the  rotavirus
      tests are  available and  are practical  for application in the laboratory.
      Dr. Amirtharajah was referring to the field collection, identification in
      the presence of  a wide variety of  microorganisms,  and quantification as
      not being  "satisfactory."   Laboratory  analysis  of  rotaviruses  is practi-
      cal but  their field monitoring may not yet be feasible.

      Further, the selection  of both poliovirus and  rotavirus  as  test viruses
      was necessitated by  the fact  that  the  surface  adsorptive properties and
      disinfection resistance of  the various enteric viruses have been shown to
     differ significantly by  virus group and by  strains  of a specific virus.
     while all  enteric viruses  and their  strains  could not  be  economically
      tested,   it was determined by the  task  force that at least two distinctly
     different  virus  types  should be  tested  to achieve  some  idea  of  the
     diversity of removal by  the various types of water purifiers.   Polio and
      rota  viruses  have distinctly different physical  and  chemical  charac-
     teristics  representative of  the  viruses  of concern.   Polioviruses  are
      small singl« stranded RNA viruses with generally good adsorptive proper-
     ties  to  surfaces  and  filter media while  rotaviruses are over twice as
      large, are double  stranded  RNA and in  some  studies have been found to
     possess  less  potential  for  adsorption  onto surfaces  or filter media.
     These two  viruses  also have been  demonstrated to have somewhat different
     disinfection kinetics.

Recommendation;

     Retain the rotavirus test requirements.

H.   Definition  of  microbiological  water  purifier:   One  general  comment
     requested  redefinition based on  "lack of  any  virus removal "requirement
                                     N-34

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     in the EPA primary drinking water regulations, so that no virus reduction
     requirement should be included.  Also, it was claimed that the separation
     of purifiers  from non-purifiers would be a  "disservice  to  consumers  and
     other users."

Discussion;

     viruses are recognized in the EPA regulations vis-a-vis a proposed recom-
     mended maximum contaminant level  of zero.   Since virus monitoring  for
     compliance with a possible MCL  is  not yet feasible,  a treatment require-
     ment is necessary.  Virus control will be considered in the Safe Drinking
     Water Act filtration and  disinfection treatment  regulations.   The reduc-
     tion  of  viruses  by treatment  is  discussed by  Amirtharajah  (J.  AWWA,
     78:3:34-49, 1986).

     With  respect   to  consumers and  other users,  we  feel  that  the  current
     definition is  appropriate  and necessary.  The average consumer cannot be
     expected to know  the  difference between viruses,  bacteria  and cysts, or
     when a raw water will or will not  contain  any  of these  organisms.   In
     order to protect  the average consumer,  the  subject units either alone or
     with supplementary  treatment,   should be able  to cope  with  all of  the
     specified organisms.

Recommendation;

     Retain the current definition for microbiological water purifier.

I.   Coverage of units:   Several comments related to  the  coverage  of units.
     These questions are addressed individually as follows:

     1.   Ultraviolet units that are used for supplemental treatment of  water
          from public  water system  taps would not be  covered.   We agree that
          such  units  are  not  covered  and  parenthetical  language has  been
          included in Section 1.3.2.3 to clarify this point.

     2.   A special  status should be given to units which remove  Giardia  and
          bacteria but not virus.  Specifically, the meaning of Section 1.2.4,
          "Exceptions," was addressed.   The  "Exceptions"  section  was  specif-
          ically developed to  relate to  the  problem of public  water  syster.s
          having disinfection  but  no filtration  on a  surface  supply.  Cysts
          alone have been found to survive disinfection treatment and could be
          present  in such treated  waters.   In  this  case an  effective cyst
          filter serves  an  independent, beneficial purpose and  should not be
          required  to  be a microbiological  water purifier.  However, such  a
          unit should  not be  used as sole treatment  for  untreated raw water.
          Additional parenthetical language has been added to Section 1.2.4.

     3.   The entire treatment unit  or system should  be  tested,   not  :ust  a
          single component.   We  agree  but  believe that  it is  sufficiently
          clear without providing additional language.
                                     N-35

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     4.   The protocol should be expanded  to  cover units  for the reduction  of
          TCE, EDB and other chemical pollutants.   We  felt  that the introduc-
          tion of non-microbiological claims  to  the  standard  would make  it
          large, unwieldy and duplicateve of an existing third-party standards
          and testing program (see Section 1.2.5).

J.   Alleged  preference  of National  Sanitation  Foundation  (NSF)  over  other
     laboratories  for conducting the  microbiological  water purifier  testing
     protocol.   The  comment indicated  that we  were giving NSF preferential
     treatment  "to  the  detriment  of other  laboratories  well  qualified  to
     perform the required protocol."

Discussion;

     we have  made appropriate  references to existing  standards  (#42  and *53)
     developed by the NSF standards development process.   Standard 53,  the
     health effects  standard, was developed by  a broadly  based  Drinking Water
     Treatment Units Committee, including  representatives  from  local,  State
     and Federal health and environmental agencies, universities, professional
     and   technical   associations,   as   well   as  water   quality  industry
     representatives.  It  was  adopted  in  1982  and  the  only  test  from  it
     utilized in  our Report  has been substantiated  as  described in Part E  of
     this "Response."

     Nowhere in our  report have we  advocated  NSF  (or any  other  laboratory)  as
     the prime or only laboratory for implementing "the required protocol."

Recommendation;

     No action needed.

K.   Instruction  concerning effective   lifetime.   One comment  described  an
     alternate  mea.ns  for  determining  lifetime  where  a  ceramic  unit  is
     "brushed" to  renew  its  utility and is gradually  reduced in diameter.   A
     gauge is provided to  measure diameter and  to determine when replacement
     is needed.

Recommendation;

     Where a manufacturer provides a satisfactory  "other" means of determining
     lifetime, this  should be accepted.   Appropriate words  have been added to
     Section 2.4.I.C.

L.   Ceramic  candles  should  not  be cleaned   during testing   because  some
     consumers would not  clean  them and  this  would provide the "worst case
     test."  One comment asserted this point.

Discussion;

     There is some truth to this proposition.  However, the other approach nay
     also have validity.   Frequent  brushing may reduce filtration  efficiency.
                                     N-36

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      In  any  event,  where a manufacturer prescribes filter cleaning and how to
      do  it,  and provides  a  gauge  to determine lifetime, we  feel  the testing
      program is bound to  follow the manufacturer's directions.

Recommendation;

      No  change needed.

M.    Scaling up  or down.   One  comment points out  that one  or  more manufac-
      turers  may  vary  size of treatment units  by  increasing or decreasing the
      number  of  operative  units  rather than the  size of the operative unit.
      The comment suggests  allowing scaling based on size of operative unit.

Recommendation;

      We  agree  with  the  comment  and  have added  clarifying  words  to  Sec-
      tion 3.5.3.3.

N.    Turbidity level  of "not less that  30  MTU"  for ceramic candles or units.
      One comment states  that "Such levels are  impossible to utilize in testing
   •   mechanical  filtration devices which will clog  entirely or require  such
      frequent  brushing  as  to   render the  test  impossible  as  a  practical
      matter."

Discussion;

      We  recognized the  potential  "clogging problems"  in  Section 3.5.1.a(2)
      where  the  30  NTU  water  is only  to be  applied  immediately  before ar.d
      during  each sampling event;  the non-sampling turbidity  level, which will
      be  applied  over  90% of the "on"  time,  is currently set at no less  than
      10  NTU.

      Turbidity levels of  30 NTU are  commonly  found  in surface  waters during
      heavy  rainfall or  snow melt.   Treatment units  may be  used  under these
      circumstances, so this challenge  level  should be retained.  However, most
      usage   will   occur  under   background  conditions  so   the  non-sampling
      turbidity levels should be 0.1-5  NTU.

Recommendations;

      1.   Retain sampling  turbidity level of not less than  30 NTU, and

      2.   Change  non-sampling  turbidity to 0.1-5 NTU.  Appropriate wording
          changes  have  been  introduced in  Section 3.5.1.a(2)  and  in Appen-
          dix N-l, Section B.

0.    Chlorine in test water #5.  One  comment  asserts that  chlorine "tends to
      increase silver  ion  leaching  activity"  and  that a high chlorine level
      should  be  included  in the  silver  leaching  test;  but  no  reference  or
      evidence, however,  is provided to back  this assertion.
                                     N-37

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Discussion;

     We  have  no compelling evidence  or reason to  expect that chlorine  will
     enhance  the  leaching  of  silver.   However, the prescribed.low pH  and 7ES
     levels will provide a clearly severe test for silver leaching.

Recommendation;

     No change needed.

P.   Unnecessary difficulty and  expense of test protocols.   Several  comments
     were made  under this general heading.   These  comments are  outlined and
     discussed as follows:

     1.   Too many  sampling events are required; sampling  of a  few units  at
          start, middle and finish should  be  satisfactory:   The committee has
          carefully laid out the standard and protocol and we feel the  minimum
          sampling  plan must  be maintained  for the  consumers'  health  pro-
          tection.

     2.   Three units  are too many  to study; parallel  testing  of two  units
          should be  satisfactory:  For  consumer  protection,  the Disinfectants
          Branch, Office of Pesticide Programs, has traditionally required the
          testing of three units.   The committee  recognizes  the  additional
          cost  involved in testing  a  third  unit  but  feels  that this  will
          provide a  minimum level  of assurance to  prevent  infectious  disease
          and recommends retention of the 3-unit requirement.

     3.   The protocol requires large tanks and microbiological reseeding or. a
          daily  basis:   We  feel  that the  tank  size  requirements  are  not
          extreme and can be met by an interested laboratory.  With respect to
          reseeding, it should be pointed out that virus and cyst seeding r.eed
          only be conducted  immediately before  and during  the sampling  "on"
          period (s~ee Section  3.5.1.b(2)), equivalent  to less  that  10%  of the
          "on" time.  This "spot" seeding for viruses and cysts recognized the
          expense and .difficulty  of  maintaining large  populations of  these
          organisms.  Continuous seeding  was provided  for bacteria  because
          they are easier  to grow  and  maintain and  might have the capacity to
          grow through some units, given enough time and opportunity.

     4.   Challenge  levels of  contaminants  are  too  high  compared to  known
          environmental conditions and the required log reductions exceed Safe
          Drinking  Water  Act  requirements:   As  explained  in  a footnote  to
          Table 1, Section 2,  the  influent challenges may  constitute  greater
          concentrations  than  would  be  anticipated in  source  waters.   These
          levels are  necessary to test properly  for  the required  log reduc-
          tions  without  having  to  utilize  sample concentration  procedures
          which are  time/labor intensive  and which may,  on  their own,  intro-
          duce  quantitative  errors  to the microbiological  assays.   As  men-
          tioned in  Part I of  this  paper, the  log reductions  for  bacteria,
          virus  and  Giardia   have  been  suggested  for  public  water  system
                                     N-38

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treatment in a paper by Amirtharajah (1986, JAWWA, 78:3:34-49).   The
reductions  in  the  microbiological  purifier  standard are  entirely
compatible  with  the  reductions  cited  for  public  water  supply
treatment.
                           N-J9

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                               APPENDIX 0

               GUIDELINES TO EVALUATE OZONE DISINFECTION
Principal  Technical Author:  Dr. Ovadia Lev
                             Division of Environmental Sciences
                             Hebrew University of Jerusalem
                             Jerusalem, Israel

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                               APPENDIX 0

                GUIDELINES TO EVALUATE  OZONE  DISINFECTION

                            TABLE OF CONTENTS

                                                                    Page

0.1  INTRODUCTION                                                  0.1-1
     0.1.1  Background                                             0.1.1
     0.1.2  Objectives of the Recommended Guidelines               0.1-2
     0.1.3  EPA's Approach  in Setting the Recommended
            Guidelines                                             0.1-3
     0.1.4  Typical Ozone Disinfection Units                       0.1-4

0.2  DETERMINATION OF CONTACT TIME  (T)                             0.2-1
     0.2.1  Background                                             0.2-1
     0.2.2  T10 Analysis                                            0.2-1
     0.2.3  Additional Considerations for T10:
            Multiple Chamber Contactors                            0.2-3
     0.2-4  Alternative Analysis  of Disinfection Kinetics          0.2-7
     0.2.5  Continuously Stirred  Tank Reactor  (CSTR) Approach      0.2-9
     0.2.6  Segregated Flow Analysis (SFA)                        0.2-10
     0.2.7  Relative Inactivation of Giardia Cysts and Viruses    0.2-12
     0.2.8  Examples of Determining Contact Time (T)              0.2-13
            0.2.8.1 Evaluation Using T.0                          0.2-13
            0.2.8.2 Evaluations  Using CSTR Calculations           0.2-16
            0.2.8.3 Evaluations  Using SFA                         0.2-18
     0.2.9  Estimating T                                          0.2-21

0.3  DETERMINATION OF OZONE CONCENTRATION (C)                      0.3-1
     0.3.1  Introduction                                           0.3-1
     0.3.2  Direct Measurement of C                                0.3-2
     0.3.3  Estimating C Based on Residual Measurements
            at the Outlet                                          0.3-6
            0.3.3.1  First  Chambers                                0.3-6
            0.3.3.2  Subsequent  Chambers                           0.3-7
     0.3.4  Estimating C                                         0.3.-10

0.4  SITE SPECIFIC EVALUATION OF OZONE  CONTACTORS                  0.4-1
     0.4.1  Introduction                                            0.4-1
     0.4.2  Site  Specific Correlations  of  C with  an
            Observable Variable                                     0.4-2
            0.4.2.1 Utilizing Off-Gas Measurements                  0.4-4
     0.4.3  Modeling the Performance of  Full  Scale Operations       0.4-7
     0.4.4  Microbial  Indicator Studies  to Model  Inactivation
             Contactors                                            0.4-9

REFERENCES

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                      TABLE OF CONTENTS  (Continued)
                             LIST  OF  FIGURES
Figure                                                         Following
  No.   Title                                                    Page
0-1     Turbine Contactor, Haworth Water Treatment Plant  .         0.1-5
          Hackensack, NJ
0-2     Multiple-Chamber Ozone System,  Los Angeles
          Aqueduct Filtration Plant                                0.1-5
0-3     Multiple-Chamber Ozone System,  City of Tucson, Arizona     0.1-5
0-4     Multiple-Chamber Ozone System.   East Bay Municipal
          Utility District, Oakland,  California                    0.1-5
0-5     Schematic of Deep U-Tube Ozone  Contactor                   0.1-6
0-6     Schematic of In-Line Static Mixer                          0.1-6
0-7     Principal of Segregated Flow Analysis                     0.2-11
0-8     Segregated Flow Analysis of an  Ozone Contactor
          Tracer Study                                            0.2-14
0-9     Tracer Study of Sturgeon Bay Ozone Contactor              0.2-15
0-10    Segregated Flow Analysis of Ozone Contactor
          - Integration of Survival Efficiency.                   0.2-20
0-11    Segregated Flow Analysis of Ozone Contact Chamber         0.2-20
0-12    Decision Tree for Estimating T                             0.2-21
0-13    Flow Configurations in Ozone Contact Chambers.             0.3-1
0-14    Direct Measurements for Determining T                      0.3-5
0-15    Ozone Concentration Profiles                               0.3-8
0-16    Decision Tree for Estimating T                             0.3-10
0-17    Example of Empirical Correlation of Residual Ozone
          and Off-Gas                                              0.4-6

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                      TABLE OF CONTENTS (Continued)
                              LIST OF TABLES
Table                                                          Following
 No.    Title                                                    Page
0-1     Recommended  Procedures  to Calculate Contact Time  (T)       0.2-2
0-2     CT Values  for  Inactivation by  Ozone                        0.2-7
0-3     k Values for Inactivation by Ozone                         0.2-7
0-4     Spread Sheet Notations  for SFA                           0.2-18
0-5     Segregated Flow Analysis of an Ozone Disinfection
        Contactor  at Hackensack                                  0.2-20
0-6     Correlations to Predict C Based on Outlet Ozone
          Concentrations                                           0.3-6
0-7     Henry's Constants  for Ozone                                0.4-5
0-8     Empirical  Correlation Between  Cout  and  yout                 0.4-6

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                            0.1  INTRODUCTION

      0.1.1  Background
      The  Surface  Water Treatment Rule  (SWTR)  specifies  overall  minimal
removal/inactivation  efficiencies  by  filtration  and disinfection   for
Giardia  cysts  and viruses.   The  SWTR uses the "CT"  concept  to  predict
inactivation  efficiencies  of  microorganisms  by  disinfection.    "CT"
represents  the  product  of  contact  or  exposure  time   ("T")  and  the
concentration of  disinfectant ("C")  during  disinfection.   The Guidance
Manual suggests design,  operating  and performance  criteria for specific
surface  water  quality conditions  to  provide compliance  with  the SWTR.
Appendix  C  of  the  Guidance  Manual   recommended   guidelines  for  the
determination of contact  time  (T10)  for the disinfection of drinking water.
T10  is the time defined to assure that 90 percent of the water that enters
the  disinfection  chamber  will  remain  for  at least  T10  minutes.   This
appendix recommends additional procedures which may be used for consistent
determination of the C and T  for systems using disinfection by ozone.
     Ozone has unique characteristics and warrants special consideration
for estimating inactivation efficiencies.  In developing these recommended
procedures, EPA addressed the  following complications that are specific to
ozone disinfection  and distinguish  it from  other  typical disinfection
processes.
           Despite  the long  operational  experience  with ozone disinfec-
           tion, the data regarding performance of ozone  as a disinfectant
           are rather  limited.   Most  of the available inactivation rate
           data are derived  from  laboratory conditions  which  are sub-
           stantially  different than  full   scale continuous  operation,
           generally more so  than for other disinfectants.
           From a technical point of  view,  disinfection of drinking water
           by ozone is more complicated than disinfection by other common
           disinfectants  because  of  ozone's  unique  gas-liquid  mass
           transfer characteristics.   Ozone requires sophisticated mass
           transfer equipment  to introduce  it into water,  because of the
           relatively low ozone concentration in the  feed  gas.  Ozone is
           a  powerful  oxidant,  that  reacts rapidly with organic  and
           inorganic substances present in  the water  and  undergoes auto-
           decomposition.   Therefore,  it's  residual  is  much less stable
           than that of other  disinfectants  and dissipates rapidly.
                                  0.1-1

-------
            Ozone  contactors  exhibit  more  diversified  types  of  flow
            configurations  relative  to  the  flow pattern in contactors for
            the other disinfectants.  The flow configuration often ranges
            from an almost  continuously stirred tank reactor (CSTR) to an
            almost ideal plug flow configuration,  making the determination
            of contact  time  for ozonation more  complex  than  for other
            disinfectants.
            Ozone contactors are closed vessels because of ozone's toxici-
            ty.   The  contactors have limited access  for measurement of the
            ozone concentration profile within the contactor.  Gas bubbles
            also may  interfere with  the  determination of  the  dissolved
            ozone  concentration,  if the  bubbles  are entrapped  during
            samp!ing.
            Ozone technology is  still  evolving  and  new  types  of ozone
            contactors are  being  developed.   These  guidelines should not
            set   unnecessary  obstacles  that  will   inhibit  engineering
            progress   and   prevent   innovative  designs  of  disinfection
            systems.

     EPA's  procedures for determining C and T  for disinfection  with ozone
differ from those recommended for systems  using  chlorine, chloramines or
chlorine  dioxide  as  disinfectants.    The  CT  evaluation   procedures
presented in previous chapters of the Guidance Manual  are not appropriate
for  ozone  disinfection because  they  would  result   in  excessive ozone
dosages.   Excessive ozone doses  result  in high  energy requirements and
costs  and may  1-ead  to unnecessary  production  of  ozonation by-products
which may have associated health  risks.  Additionally,  excess dissolved or
entrained ozone  should  be  destroyed  or removed before reaching  the first
drinking  water consumer or plant personnel,  in  order to prevent health
risks.   Therefore,  excessive dosage of  ozone may  require an  additional
unit operation  to destroy  the remaining  residual ozone.  This  process is
expensive and may not be necessary  if  guidelines such as those presented
in this  section   are used  for compliance with  the  SWTR.

     0.1.2  Objectives  of  the Recommended  Guidelines
     The  recommended guidelines  were developed to  assure compliance  with
the SWTR  for the  whole  range of flow rates, flow configurations and water
quality  conditions  that may  be encountered  with  ozone  disinfection of
drinking  water.   The primary goal of these guidelines is to  assure
                                  0.1-2

-------
 compliance with the  SWTR even under  "worst  case"  conditions.   Without
 compromising this  primary goal,  these guidelines were developed to meet
 the  following criteria:


      1.     Simplicity:  The guidelines  for  selecting  contact time (T) and
            concentration.(C)  have to be easily understood by practitio-
            ners, even by  those who do not have an  engineering background.

      2.     Implementation:  The procedure  to  estimate concentration and
            time should be easily implemented,  even by water utilities that
            have only  limited  engineering and  technological means.

      3.     Economics: The  guidelines  should be  designed to  minimize
            capital  and operating costs and to minimize ozone consumption.
            The guidelines should be flexible enough to allow systems to
            take advantage of  site specific characteristics of the treated
            water and  the  various  designs of  ozone contactors.


      0.1.3   EPA's Approach  in. Setting  the  Recommended  Guidelines

      EPA is aware that the current technological knowledge is insufficient

 to formulate  a consistent  and efficient  single set-of  general rules that

 will  achieve  these  conflicting goals and still guarantee  compliance with

 the  SWTR.    Therefore,  EPA developed two alternative  sets of guidelines

 that  systems  may use  depending on their  technological  resources:

            Alternative 1: General guidelines which assure compliance with
            the SWTR regardless of the  site specific  conditions,

            Alternative 2: A sophisticated evaluation  procedure that water
            utilities  may  use  to  take  advantage  of  their site specific
            conditions.

      These  guidelines are  considered  to be  state-of-the-art.   As more

 information becomes available, more accurate approaches and models may be

 developed.  A  brief description of  the current alternatives follows.


      Alternative 1  -  General  Guidelines

      This alternative consists of a simple set of  general  guidelines that

 assure compliance with the  SWTR even under worst  case  conditions.  These

guidelines  were  developed   to  emphasize  generality  and  simplicity.

However, they  may not result  in the lowest cost alternative(s).
                                  0.1-3

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     The  second and  third  sections of  this  Appendix contain  detailed
descriptions of the general guidelines.  Section 0.2 contains procedures
to estimate  the contact  time  (T)  and  Section  0.3  contains  procedures  to
calculate  the   concentration  (C)  in  ozone contactors  based on  simple
measurements of some oarameters.  The basis for these general guidelines
is discussed in two papers (Lev and Regli, 1990a,b).

     Alternative 2 - Site Specific Evaluation Procedures
     This alternative consists of a more sophisticated set  of evaluation
procedures to characterize the performance of ozone contactors and thereby
take advantage of site specific conditions.  EPA recommends that systems
be given opportunity to prove  by further  experimental and analytical data
that  the  performance  of  their ozone  contactors  are  better  than  the
performance predicted by the  first alternative,  thereby allowing a system
to minimize costs while providing adequate treatment.
     Section 0.4 outlines  recommended  procedures  for demonstrating that
ozone contactors achieve better performance than that  predicted  by the
first alternative.

     0.1.4  Topical Ozone Disinfection Units
     Several types of ozone contactors are currently in use for disinfec-
tion of drinking-water  in  the  United  States.   Other types  of contactors
are being designed or  are  being used  for disinfection of treated sewage
effluents.   The following characteristics illustrate the  diversity  of
ozone contactors:
           The  capacity of ozonation  systems  ranges  from  less  than 1
           million gallons per  day  (mgd)  up to  600  mgd.
           The volume of ozone  contactors  ranges  from less than 35 cubic
           feet up to more than 35,000 cubic  feet for a  single  chambers.
           The  ozone gas  stream may  be  introduced  into  the  water  by
           several ways including  porous  diffusers, submerged turbines  and
           gas  injectors.
           Ozone contactors include single or multiple gas/liquid  contact
           chambers.
                                  0.1-4

-------
      Four  typical  ozone  contactors  currently  in  use  or  in  design  in the
United States are  shown on Figures 0-1 through 0-4.  Figure 0-1 presents
a schematic of an  aspirating turbine contactor, operating in countercur-
rent  flow.   A turbine agitator is used to  introduce  the ozone into the
contactor  and to mix  the liquid phase.  This unit may serve as the first
ozone chamber in a series  of  chambers  or  as a single chamber.   The unit
shown in this figure is from the Hackensack  Water Company's Haworth Plant
at Haworth,  New  Jersey.   The turbine  chamber  is  followed  by a reactive
chamber to provide  additional  contact time.  Studies conducted in the full
scale turbine  agitated contactor  demonstrated that  even when  the ozone
demand was  high,  the dissolved ozone  concentration  was  almost constant
throughout the contactor as a  result of the vigorous action  of the turbine
(Schwartz et al,  1990).
     The 600 mgd ozone system of the city of Los Angeles is comprised of
four parallel contactors each consisting of  six chambers.  A  schematic of
one  of   these  contactors  is  presented  on Figure  0-2.   (Stolarik  and
Christie, 1990)  As indicated on this  figure:
           An oxygen  stream containing a  few percent by weight of ozone
           is compressed through bubble diffusers into the first and third
           chambers of the contactor.
           The second and fourth chambers  are used  to  provide  contact
           time,  without  supplying  additional  gas to the liquid stream.
           The size of the  first  three gas/liquid  contact  chambers is
           20,400  cubic feet each.
           The fifth and sixth chambers are  the ozonated  water channel and
           the rapid  mixer basins.
           The liquid and gas  streams  in the first and third chambers  flow
           in a counter-current pattern;  the gas  stream flows  upward and
           the water  stream flows downward.

     As  illustrated on Figure 0-3,  a similar design approach  was taken by
the  City  of  Tucson,  Arizona.    This  contactor  is  comprised of  five
chambers, all of  which are  equipped with gas diffusers.  The sixth chamber
has no diffusers.   The flow in all  six chambers  is counter-current flow.
These counter-current chambers are separated by narrower  co-current  liquid
channels in which the water flows upward to  the inlet  of  the next chamber.
                                  0.1-5

-------
     The  East  Bay  Municipal  Utility  District  Oakland,  California  is
currently designing two 60 mgd ozone  contactors,  the first of which is to
be  operational  in 1991.   As  illustrated on  Figure  0-4, the  contactor
includes three ozone gas/liquid chambers followed by  three more reactive
chambers to provide additional  contact time.   The  first and third chambers
are counter-current and the second chamber is co-current. In the latter,
the water  and  the gas bubbles  flow in the  same  direction.   Hydrogen
peroxide can  be added at  the  outlet of the contactor to dissipate  any
residual dissolved ozone.
     The following types of contactors  are already used in other parts of
the world,  but have not yet been installed in the United States:
           The Deep U Tube contactor  shown on Figure 0-5, is comprised of
           two concentric  flow tubes.   Water  and gas  streams are intro-
           duced  at the top  of the inner tube  and the mixture is pumped
           10 to  30 meters downwards at a velocity greater than the rise
           rate  of  the  gas.    After  reaching  the very  bottom  of  the
           contactor  the  mixture flows  up  in  the outer  section  of  the
           contactor.  The Deep U-tube is basically a co-current operation
           taking  advantage  of the increased  mass   transfer at  high
           pressures.

           The Static Mixer (shown on Figure 0-6) consists of a flow tube
           equipped with baffles to produce  efficient  contact between the
           liquid and the  gas streams.   This  installation  is gaining
           popularity  in  Europe particularly for  small  and medium size
           disinfection units.  Here  the flow is basically co-current, the
           liquid and  gas  flow is  in the same direction, through a tube
           equipped with baffles that create turbulence and thus increases
           the rate of gas-liquid mass transfer.   The  ozone  is  applied to
           the water  prior to the mixer either  through  an  eductor or a
           diffuser.   Following dissolution through the mixer, the water
           flows  through  a pipeline  in  plug flow.

           Some  contactors,  particularly for disinfection of  wastewater
           effluents,  use packed beds  to  increase mass  transfer.   Co-
           current or  counter-current  flow  configuration may be used.


     The  guidelines   were developed  to represent  four  different  flow

conditions  in  ozone  contactors.  However,  other types of contactors or

flow conditions  may still  use  the same  guidelines  if  the  features  of the

gas-liquid flow configuration as presented in Section 0.4 of  this appendix

are taken  into  account.
                                  0.1-6

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                  0.2   DETERMINATION OF CONTACT TIME (T)


      0.2.1  Background

      The  hydraulic characteristics  in ozone  contactors  range  from  an

 almost  Continuous  Stirred-Tank  Reactor  (CSTR)  to an  ideal  plug  flow

 configuration.  Because the T10 approach may not be  adequate for determin-

 ing the inactivation.provided for systems resembling a CSTR, and because

 the T10  approach is overly conservative in other cases,  EPA recommends the

 following three numerical methods to predict the contact time (T)  in ozone

 contactors:
     T10:   The  T10 method discussed  in Appendix C (and in Section 0.2.2) is
     a  good measure  to characterize  the contact  time in  most  cases.
     However,  this  method  reduces  the possibility of complying with the
     SWTR  for  systems  that have relatively high back-mixing and require
     high  inactivation  levels.

     Segregated Flow Analysis (SFA):  (See  Section 0.2.6) This is an alter-
     native procedure  to calculate the disinfection contact time.   This
     procedure  is applicable only to  systems that  have good  data from
     tracer studies of  high  resolution  as explained  in  Section 0.2.6.

     CSTR:  The Continuously Stirred-Tank Reactor (CSTR) method described
     in Section  0.2.5,  assumes  the  ozone contactor behaves  as  a  CSTR.
     This  procedure is  extremely  conservative.   However,  no  apparent
     simplified analysis is currently available to make it  less conserva-
     tive.  The-CSTR approach should be used  only when:

           Other  predicting  techniques  are not recommended,

           The required  inactivation level is very low, or

           Systems cannot  afford to get good  tracer  study  data for other
           methods.
     Systems may  choose  the optimal  method for their situation based on

the available data to perform the calculations.  A discussion of each is

presented below.


     0.2.2  T10 Analysis
     The simplest method of calculating the contact time, T, of microor-

ganisms  in  a contactor  is  by the T10 approach.   T10  is  defined  as the

detention time  to assure that 90 percent  of  the liquid that enters the

                                  0.2-1

-------
 contactor  will  remain at least T,0 minutes in the contactor.   A system
 achieving  a CT10 corresponding to X percent inactivation, will assure that
 90  percent of  the  water  passing  through the contactor  is  receiving  at
 least X percent inactivation, while 10 percent of the water will receive
 less than  X percent  inactivation.
     When  conducting  a step-input tracer study,  T,0 is the 'time interval
 required for the outlet tracer concentration to achieve 10 percent of its
 ultimate response,  following an inlet step addition.   Appendix C of this
 manual contains procedures to conduct  and evaluate tracer studies for the
 determination of T10.  Appendix C also  contains procedures to estimate the
 T10  of  contactors based on their baffling conditions  and flow configura-
 tion.
     The results of  tracer studies conducted  on several ozone contactors
 (Stolarik and Christie,  1990, Schwartz et al,  1990,  Rosenbeck et  al, 1989)
 indicate that high quality tracer data on ozone contactors can be obtained
 and that T10 can be  estimated with  high precision, but to a lesser degree
when T10  is less than one  minute.
     T,0  is a  good measure of the contact time in most contactors and the
 safety margin provided  by using T10 compensates for the inferior perfor-
mance of contactors with a high  degree of short-circuiting and backmixing
 relative to contactors  that approach plug flow conditions,   (see Lev and
 Regli,  1990a, for further detail.) However,  for contactors with a high
degree of short-circuiting and a need to provide a high level  of  inactiva-
 tion, this safety margin fails to compensate for the effect  of backmixing.
 In such cases,  approximately 10 percent  of  the water  passing through the
 contactor  receives  significantly less than  the inactivation  indicated by
 CT10.   In  these  cases,  either the SFA or  the CSTR approach  should  be used
 for determining the  contact time.
     The recommended alternatives for determining the contact time (T) for
various  conditions  of  T10  versus  hydraulic detention  time  (HOT)  are
presented  in Table  0-1.   HOT is determined  by dividing the  liquid volume
of the contactor by  the  rate of flow through the contactor.   As illustrat-
ed in this table:
                                  0.2-2

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                                TABLE 0-1

                  Recomended  Procedures  to Calculate  the
                      Disinfection Contact Time (T)
 Condition:       T10<(HDT)/3          T,0<(HDT)/3          T10>(HDT)/3

                       )(1)  <  2.5    -Log(I/Ift)<1) >•  2.5
Notes:
Recommended
Methods:           T«T10                                     T«T10


                   SFA(2)                  SFA(2)             SFAC2)


                  CSTRC3)                 CSTR(3)           CSTR<3>
     1.    Required  level  of  inactivation in  logs  of either  Giardja
           lamblia cysts  or viruses whichever  value is greater;
           I   -   # live organisms in outlet of ozone contactor and
           I0 »   # live organisms in inlet to  ozone contactor

     2.    High resolution  tracer characterization of the ozone contactor
                be available.
     3.    The-CSTR method is extremely conservative and should be avoided
           when  alternative  approaches are possible.

-------
            The T10 method  is applicable for  systems that are required to
            achieve less than a 2.5-log inactivation of Giardij  cysts even
            if the flow configuration in their  ozone contactor  approaches
            that  of  a  CSTR,  such  as  disinfection in  contactors using
            turbine agitators.
            Likewise,  the T10  approach  is  appropriate  for systems demon-
            strating  T.Q/HDT greater than  1/3 regardless of the required
            level  of  disinfection.
            Systems for which  the T10 approach  is appropriate to have the
            option of applying either the SFA  or CSTR analysis.   The method
            resulting  in the highest T value,  or thereby the lowest  C value
            may then  be followed.
      The  SFA  or CSTR  should be  used in lieu  of T10 when the:
            Level  of inactivation required  for Giardia cysts and/or  viruses
            is  2.5-log  or higher
            T10/HDT is less than 1/3.

Systems should  be aware  that the 2.5-log  inactivation  guideline refers to
the  inactivation  provided  by  the ozone   system  alone  regardless  of
inactivation  provided  by other disinfectants.   For example, if a system
requires an overall inactivation of 3-log  and provides 1-log inactivation
by chlorine,  then a  2-log inactivation is required by  ozone  and  the  T10
approach can be used.
     Examples  for applying the different methods of calculation for T are
included in Section 0.2.8.
     0.2.3  Additional Considerations  for T10:  Multiple Chamber Contactors
     This  section  provides  guidelines  for  computing  T10  for  several
contactors  in  series.  The main  shortcoming of the T10 approach is  the
inherent non-linearity of this measure.  In contrast to the HOT,  which is
a linear measure,  T10's of individual subunits do not  sum  up  to  give  the
T10  of  the  overall  unit.   For example:
           The HOT of two equal CSTRs in series  is  exactly twice the  HOT
           of each CSTR.
           The T.p  for the same two CSTRs in series is more than  twice  the
           sum of  the individual  T10's.
                                  0.2-3

-------
 This  raises  some  practical  questions:
           How should the T10  of  a multiple-chamber contactor be deter-
           mined  using  tracer  studies?
           Is  it  necessary  to  conduct  individual tracer studies for each
           chamber  or is  it sufficient to conduct an overall study of the
           whole  contactor?
           How can  the  contact time of one chamber be determined based on
           the T10 of the overall  system?
      Conducting tracer  studies  of  individual   chambers  in  a  multiple
 chamber  ozone  contactor  is likely  to be difficult.   In  addition,  an
 analysis conducted by Lev and Regli (1990a) indicates that the computation
 of the contact time (T)  based on tracer studies of the individual chambers
 is likely to lead to over design.   The excess volume of  a system designed
 by summing the T10s  of the separate chambers may be up to 9.5 times higher
 than one designed by  the overall  T10  approach.  Therefore, EPA.recommends
 the use  of an overall tracer  study  of the whole contactor,  in order to
 lower operation costs and to avoid overly  complex  tracer studies.
     Disinfection credits for a multiple chamber contactor should  be based
 only on the active chambers, those which have a detectable ozone residual.
 Based on the  recommendation to use overall  tracer studies, guidelines are
 needed for determining  the  disinfection  credit for the active part of a
 system based on overall  tracer studies.  The  average concentration in the
 individual chambers of a multiple-chamber system may deviate considerably
 from  one  another.   Therefore, systems  must be able  to  assign contact
times for each  chamber.
     Lev and Regli,  (1990a) evaluated  the  consequences  of using  a linear
 approximation based on relative contact chamber volumes  and overall T10 of
 the contactor  to determine  the contact time  of  individual chambers in an
ozone contactor:
                                  0.2-4

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            Tv
      Where:
            TIO,eh«(*«r *  An  approximation  for  the contact  time  of  one
                        chamber.
            ^10.total   "   T10 °f tne entire multi-chamber ozone contactor as
                        determined  by  tracer  studies
            VCh»iTto«r   *   Volume  of the  individual  chamber
            vtotai     "   Overall  volume of the multi-chamber  ozone  conta-
                        ctor

They demonstrated that such linear  extrapolation  may lead to an underesti-
mate  of  the  required T.  This underestimate can  be significant  when the
concentration  in the different  chambers  deviate considerably from each
other.   This would  be the case when  the  residual ozone  concentration in
one chamber  is zero.
      Considering  the various safety margins  that are included in the T,0
approach, and considering the practical complexity involved in conducting
separate tracer  studies,  EPA recommends the  use  of  the linear approxima-
tion  described  in Equation 1 provided that the  volume of  the portion of
the  contactor  that  has zero  residual  ozone  is less than  half of the
overall  volume o^ the ozone  contactor:
           V            /V     < 0  5
            'inactivt chtwbtK 'total  , u ' J
     Where:
           Vir»ctivt chwtwr *    Tne volume °f the chambers  in the contactor
                              where the ozone concentration is zero
           V. . ,            - The volume of the  chambers with a  residual
             totii

     The  following  examples  illustrate  the  computation of  the overall
inactivation  performance  of multiple-chamber systems  using  the  linear
approximation of Equation  1:
Example 0.2-1  Linear  approximation  to  predict T
                                                      10
           An ozone contactor  has three chambers  in series.  Each chamber
           has  a  volume of 353 cubic feet.
                                  0.2-5

-------
      The average ozone concentration  in each chamber is:
            First chamber: C,«0 mg/L ozone.
            Second chamber: C2»l mg/L ozone.
            Third chamber: C3 -0.5 mg/L ozone.
      Cv C? and  C3  are  the average  concentrations,  determined as
      described in Section 0.3.
      The utility measured T10 - 5  min for the  entire  ozone con-
      tactor.
      The volumetric fraction  of the  chamber  which has  no ozone
      residual is  V1/(V,+V2+VJ))  - 0.33 which is  less  than the 0.5
      guideline.  Therefore  it is permissible to use Equation 1 in
      order to estimate the CT achieved in  the ozone contactor.
      The total CT achieved by the ozone contactor  is:
      CT - (C2)[(T10>tot-l)(V,)/(VMtil)] + (Cs)[(T10ftotil)(V,)/(Vtotil)]
      CT - (1)[(5)(10)/(30)] + (0.5)[(5)(10)/(30)]  • 2.5
      The CT achieved by the ozone contactor  is 2.5 mg-min/L.
Example 0.2-2  Linear approximation not applicable
      An ozone contactor consists of:
            A chamber with  a volume of 70  cubic feet and equipped
            with a turbine agitator
            Followed by a second  chamber with a volume of  200 cubic
            feet.
      The first chamber  has  an ozone  residual  of 0.5 mg/L and the
      second chamber has an ozone residual  of zero
      The T10ftotil - 8 min for both chambers at the  peak flow rate
      The volumetric fraction  of  the chamber with no ozone residual
      is 200/270  •  0.74  which  is  greater  then  0.5 of  the total
      volume.  Therefore, the  use of Equation 1  to approximate the
      T10  of the  chamber that contains an ozone  residual  is not
      recommended.
      The system  may estimate  its  performance by  either  the CSTR
      approach taking  into  account only the  detention  time of the
      first  chamber or conduct tracer  studies of  the first chamber.
                             0.2-6

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     0.2.4  Alternative Analysis of Disinfection Kinetics
     The CSTR and the SFA approaches utilize the Chick-Watson inactivation
rule directly rather than  relying  on the CT  approach.    The  following
section describes this alternative  approach to represent the disinfection
kinetics.
     The  Guidance Manual  recommends  that  systems should  calculate  the
inactivation  level  in their disinfection contactors  by  the CT approach.
Table 0-2 presents CT data corresponding to specified inactivation levels
of Gjardia cysts and viruses by ozone.  An  alternative way to present the
same  information  is  by  tables of the  kinetic  coefficients  used  to
calculate the CT values.
     The CT values presented in Table 0-2 were calculated based on batch-
reactor  experimental  information  that was  fitted  into  a  logarithmic
correlation according to a  first order Chick-Watson's rule  (Chick, 1907;
Watson 1908; and Hoff, 1987):
           log(I/I0) - - k  CT                                  (2)
     Where:
           I/I0 -      Survival ratio of the Giardia cysts or viruses
           C    -      Residual concentration of  ozone in mg/L
           T    »      Exposure time  in min.
           k    -      A  kinetic  coefficient  which characterizes  the
                       specific  rate  of  inactivation of the microorgan-
                       isms  at  the  appropriate temperature and pH.
     Solving Equation 2 for  k  yields:
           k - -loo (I/IJ                                            (3)
                  CT

     Equation 3 can be used to calculate k values corresponding to the CT
values in Table 0-2.  Table  0-3 summarizes  these k values.  Equation  3 may
also be used to transform inactivation levels  (I/I0) to CT values  and vice
versa.
     The following example  illustrates the use of the values presented in
Table  0-3  to  calculate   the  performance   of   multiple-chamber  ozone
contactors:
                                  0.2-7

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Example 0.2-3  Multiple-chamber Ozone  Contactor
      An ozone contactor consists  of three  chambers  in  series
      Temperature is 5 C.
      The first chamber has  a 10 percent  survival  ratio for  Giardia
      cysts,  or (I/I0) - 0.1, which also corresponds to  90  percent
      inactivation
      The second chamber has an I/I0 » 0.07
      The third chamber has  an I/I0  «  0.03
      The total  inactivation may be calculated by either summing CT's
      or summing logs of inactivation,  as presented  below.
      Summing CT's:
            At 5 C the k for Giardia cysts  -1.58
                       <
            The survival  fractions are:
            First Chamber  - 0.1
            Second Chamber - 0.07
            Third Chamber  - 0.03
            Therefore, the CT values in  each of  the  chambers are:
                  First chamber:
                  CT - -log(I/I0)/k  -  -log  (0.1)  /(I.58)  • 0.63
                  Second chamber:
                  CT - -log  (I/I0)/k - log  (0.07)/1.58  -  0.73
                  Third chamber:
                  CT - -log(I/I0)/k  -  -log  (0.03J/1.58  -  0.96
        -   Total  CT is :  0.63 + 0.73  +  0.96 -  2.32
            As indicated in  Table  0-2, a  CT of 2.32 is sufficient to
            achieve a 3-log  inactivation of Giardia  cysts.
      Summing logs of inactivation:
        -   First chamber: -log (I/I0) -  -log(O.l) -  1
        -   Second chamber:  -log(I/I0) *  -log  (0.07)  -  1.15
                            0.2-8

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                                      TABLE  0-2

                                    CT VALUES  FOR
                                INACTIVATION BY  OZONE
Giardia
Tefficerature (C)
Inactlvation
0.5 log
1 log
1.5 log
2 log
2.5 log
3 log
Virus
Inactivation
2 log
3 log
4 log
0.48
0.97
1.5
1.9
2.4
2.9

0.9
1.4
1.8
0.32
0.63
0.95
1.3
1.6
1.9

0.6
0.9
1.2
0.23
0.48
0.72
0.95
1.2
1.4

0.5
0.8
1.0
0.16
0.32
0.48
0.63
0.79
0.95

0.3
0.5
0.6
0.12
0.24
0.36
0.48
0.60
0.72

0.25
0.4
0.5
0.08
0.16
0.24
0.32
0.40
0.48

0.15
0.25
0.3

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                               TABLE 0-3

                    k Values for Ozone Inactivation05
TEMPERATURE (C)         0.5     5	    10       15      .20         25


Inactivation            1.03    1.58    2.08     3.12     4.17       6.25
of Gia-dia cysts

Inactivation            2.22    3.33    4.00     6.67     8.00       13.3
of Viruses
     (1)    k « -log(I/I0)/(CT)  in L/mg-min.   When Chick's rule is repre-
           sented by  the formula  ln(I/L)  - -K CT  (In  stands  for  the
           natural logarithm)  then  k should be calculated  by  k * 2.303(K)

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                 Third chamber: -log(I/I0)  - -log (0.03)  «  1.52
                 The total logs of inactivation is:
                    -log  (I/I0) - 1 + 1.15 + 1.52 - 3.67,
                 The 3.67-log inactivation of Giardia cysts  is higher than
                 the required 3-log inactivation

     0.2.5  Continuously Stirred-Tank Reactor (CSTR1 Approach
     The  CSTR  method assumes that  the  flow configuration  in the  ozone
contactor approaches that of completely stirred reactor.   In most cases,
this calculation method  is the most conservative  approach.   Studies  by
Schwartz  et al  (1990)  suggest that  well-operated turbine  contactors
approach ideal  CSTR characteristics and  the  CSTR calculation is appropri-
ate.  In some cases, CSTR calculations offer the only apparent method to
evaluate  the  performance  of the  ozone  contactors.   CSTR calculations
should be used  under the following conditions  if  systems  have  no other
means for demonstrating the  inactivation efficiency.
           Tracer data are not  available,
           The  required  inactivation  level  is  greater  than 2.5-log, and
           ozone disinfection  is  applied in a  single  chamber contactor
           with T10/HDT < 1/3.
           If ejther the required inactivation  level is less than 2.5-log
           g_r  T10/HDT  >  1/3  then the  inactivation predicted by CT1p is
           appropriate provided that tracer data are available.  If nigh
           resolution  tracer  data  are  available then the SFA method can
           be applied regardless of the level of inactivation required or
           the  ratio of T10/HDT.
     In some cases, systems may actually receive more credit by using the
CSTR approach then by using the T10 approach.  Higher credits result when
a low level of  ozone disinfection such as 0.5-log  is required and mixed
contactors are  used.
     When using the CSTR approach, the inactivation performance should be
evaluated for viruses  and Giardia  cysts, regardless of which required CT
is  higher.    This  recommendation results  from  the  influence  of flow
characteristics on contactor  performance, as discussed in  Section  0.2.7.
     The  performance  equation  for  a CSTR  is  based  on  two important
assumptions:

                                  0.2-9

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        1.   The   concentration  of  disinfectant  and  microorganisms  is
            homogeneously distributed in the contactor.
        2.   First order Chick-Watson's law applies.  That is, the rate of
            inactivation of the microorganisms is approximately proportion-
            al to the  concentration of the microorganisms and the concen-
            tration  of disinfectant.
     The performance  of a  CSTR contact chamber  is given by:
            (I/I0) - 1/[1 t 2.303(k)C(HDT)]                        (4)
     Where:
              k   -     kinetic coefficient for microorganism inactivation
                       [k  values  are listed  in Table 0-4  (L/mg-min)]
            (I/I0) -    Survival ratio of  organisms
            C     »     Average concentration  of disinfectant (mg/L)
            HOT   «     Hydraulic detention time (min)

     Equation 4 may also be used to calculate the ozone concentration  that
is required to achieve a specified level  of inactivation for a given HOT
or to compute the HOT  required to achieve a desired inactivation level for
a given ozone concentration.   Equation  5 restates Equation 4 for use in
determining C or HOT

            C(HDT) - [1-(I/I0)]/[2.303 k (I/I0)]               (5)

     The effects of mixing on improving  disinfection effectiveness may be
very significant in CSTR  contactors, and are not accounted for in  this
model.
     Examples demonstrating  how  to  calculate  the  operating conditions
necessary to  meet  the required  inactivation levels by the  CSTR approach
are included  in Section 0.2.8.2.

     0.2-.6  Segregated Flow Analysis (SFA1
     SFA  is  a   method  that  is  often  used  to   characterize  chemical
reactions.  Better  approximations may be  determined  through analysis and
modelling  of the  specific  details  of  the  flow  pattern   in  the  ozone

                                 0.2-10

-------
contactor,  but such  modelling  cannot be done  based on tracer  studies
alone, as the SFA can. Comprehensive descriptions of the SFA can be found
in several references including Levenspiel (1972) and Seinfeld and Lapidus
(1984).   The  SFA  assumes  that the  inactivation  in a contactor'can  be
determined  by the  product of  the  probabilities  of two  events:    the
probability  distribution  for  water to remain in  the  contactor;  and  the
probability distribution for organisms to survive as they pass through the
contactor.
     The  first probability  function  describes the chances  of a microor-
ganism remaining in the contactor for a  specified  time period.  The water
passing through the contactor has a probability distribution, determined
by tracer studies which indicate the detention time for each fraction of
the flow through the  contactor.
     The second probability function describes the chances of a microbio-
logical  species  surviving  following exposure  to a disinfectant  for a
certain  amount of  time.    This probability  function  is  given  by  the
modified Chick's  equation:  (I/I0) » 10""ct.  Each fraction of  the  flow would
have a different  "t" for which this equation would apply.  For example, a
virus that is exposed for  1 minute to C-l mg/L ozone when k-1  L/mg-min has
0.1 (10 percent)  chances to survive.
     The following illustrates the intuitive origin of the SFA approach:
           The flow in an  imaginary contactor may be viewed  by flow lines.
           A microorganism that is introduced at time t«0 will  follow one
           of  these flow lines.
           For simplicity,  consider that only  four flow  lines exist as
           represented on Figure 0-7.
           A microorganism that is  introduced in the feed to the contactor
           has some  probability  (PI) of following any one  of these four
           lines.
           The microorganism  will  then remain  for a specific detention
           time, characteristic of each flow line,  in the contactor.
           This concept  is  presented schematically on Figure 0-7, where
           the flow  lines  are represented by four  different tubes whose
           lengths  (or detention times) correspond to the  lengths  of  the
           flow lines on Figure 0-7.
                                  0.2-11

-------
           Microorganisms  that  are  introduced  into  various tubes  have
           different probabilities of survival  (P2), because of different
           susceptibilities to disinfection in each of these tubes.
           The  product  of the probability that a  microorganism will  be
           carried  into a specific  tube  (PI)  times the  probability  of
           survival after being exposed to the hostile environment for the
           appropriate  time (P2) is the probability that a microorganism
           introduced  into the  feed inlet will  get out  alive from  a
           specific tube  (P1)(P2).
     For example,  if  20 percent  of the flow  is directed  into  the  first
flowline and I/I0 for this  fraction of the  flow equals 0.25, a microorgan-
ism has  (0.2)(0.25)  or a  5 percent  chance of emerging alive  from  this
specific  flowline.    The total  survival  of microorganisms  that  are
introduced  into the inlet  to the entire  contactor  can be  computed  by
summing up all  four survival  probabilities (P1)(P2).
     Complete  examples  for the  application  of the SFA are  included  in
Section 0.2.8.3.   For  SFA to  be  applied,  a high resolution tracer study
must be available.  The requirements for  a high resolution tracer study
are:
           Appropriate  time distribution of sampling points.
           Limited degree  of  scatter  in sample points.
     The first  requirement is to have several  sample points prior to the
occurrence of T10 and  less frequent sampling points thereafter.  Several
sampling points~pnor to T10 are  essential  to get in accurate representa-
tion of what  is occurring in  the early flow through the contactor,  when
organisms are most likely  to  exit the contactor while still viable.   The
second requirement if for  a limited degree of  scatter between the sample
points.  The plotted curve should ideally  be  continuous  to  allow for more
accurate integration to predict  the  survival of microorganisms.

     0.2.7  Relative Inactivation of  Giardia Cvsts and  Viruses
     In most cases, when  the  CT  required  for the inactivation of Giardia
cysts  is greater than  the CT required  for the inactivation of viruses,
compliance with  the inactivation requirements  for  Giardia  cysts will
                                 0.2-12

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       A. FLOW LINES IN A CONTACTOR
         INPUT
                                              OUTPUT
         B. SCHEMATIC REPRESENTATION OF THE FLOW LINES
          C.  SURVIVAL PROBABILITY FOR AN ORGANISM
Flow
Line

 1

 2

 3

 4
p,
Fraction of Flow
into the Flow! ine
2/10
4/10
1/10
3/10
d/50)
Survival Ratios
1/4
1/8
1/16
1/32
p p
12
Overall
Survival Ratios
16/320
16/320
2/320
2/320
          SUM   1
37/320
   FIGURE 0-7  - PRINCIPLE OF  SEGREGATED FLOW ANALYSIS

-------
 assure compliance with the virus inactivation requirements.  Specifically,
 this  is true when:

      kv,rus/kcyst > 1 °9( I/ I0) virus/ l<>g( I/I0)cygt               (6)

      The SWTR, however, requires a higher level of inactivation of viruses
 than  Giardia cysts.  Therefore, ozone contactors that are characterized by
 a  high degree of  turbulence will find  that,  as  the flow  configuration
 approaches  that of  a CSTR  (T10/HDT <  1/3),  compliance  with the  virus
 inactivation requirements may be a more demanding task than  meeting  the
 inactivation requirements  for Giardia  cysts.    Consequently,  an  ozone
 contactor that has a  T10/HDT < 1/3 and a low (I/I0)  should be  checked  for
 compliance with the inactivation of viruses as well as for cysts.   Another
 way  to  understand this   is  that as the  inactivation  indicated  by CT10
 increases, the 10 percent of the water passing through the contactor with
 less  contact time  than   T10 becomes  more significant  for lowering  the
 overall  inactivation  efficiency  for  all the water  passing  through  the
 contactor.

      0.2.8   Examples  of Determining Contact Time  (T)
      This  section  presents  examples  for 'the application  of the  three
 general  approaches -  T10,  SFA, and CSTR - for determining contact time.

      0.2.8.1  Evaluation  Using T,0
      The  following four examples illustrate when  the T10  approach should
 be used  and  when alternate  approaches  are appropriate.   Procedures  for
 calculating  the  required  ozone residual based on  the T10 approach  are
 outlined  in  the examples.

      Example 0.2-4  Inactivation  Required >2.5-1oq
      The  Haworth Water Treatment  Plant,  Hackensack,  New Jersey,  uses  a
 turbine ozone chamber followed by a contact chamber to provide additional
contact time.  A schematic of  the  contactor is  shown  on Figure 0-1.   The
treatment plant provides  filtration  after the ozone contactor.   For  the
purposes of this example,  although it is not the case for Hackensack,  the
                                 0.2-13

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ozone  system must provide disinfection for 2-log Giardia and 3-log virus

inactivation to supplement filtration.  The following conditions apply:

                 Water Temperature •     0.5 C
                 CT for 2-log Giardia  • 1.9 mg-min/L
                 CT for 3-log virus    - 1.4 mg-min/L

           A tracer study was conducted on  one of the four ozone contact-
           ors.   Figure  0-8  depicts the chart recorder  of  the raw data
           that were collected during the tracer study.

           The HOT at the flow rate of the study was 20 minutes, and the
           T10  occurs  at  11 min.

           The  T10/HDT  of 0.55,  is  greater  than  1/3,  making  the  T10
           approach valid for this system.

           The CT for Giardia inactivation is the controlling CT because
           it is greater than the CT for virus inactivation.

           Using the  T10 of  11  min,  the residual needed to meet the CT
           requirement of 1.9 mg/L-min is determined as  follows:

                       C " 1.9 ^q-min/L - 0.17 mg/L
                              11 min

           As a result of using  the T.0 approach,  the system  must maintain
           an ozone concentration of 6.17 mg/L in the contactor to provide
           the necessary disinfection.

     The application of the SFA method for this contactor is presented in

Section 0.2.8.3.^


     Example 0.2-5  Low Detention Time. Inactivation Required  <2.5-1og

     A system using slow sand filtration must  provide disinfection  for 1-

log Giardia cyst and  2-log virus inactivation.   The system  has an ozone

contactor equipped with a turbine mixer.   The  following conditions  apply:

                 Water Temperature «     25 C
                 CT for 1-log Giardia  • 0.16 mg-min/L
                 CT for 2-log virus    « 0.15 mg-min/L


           The CT for Giardia cyst  inactivation is greater than the CT for
           virus inactivation and  is therefore the  controlling CT.

           A  tracer  study  was  conducted  for  the  ozone  contactor  and
           resulted in a T10  of 30 seconds.
                                  C.2-14

-------
           The HOT of the contactor at the flow rate of the study was 150
           seconds.

           Thus T10/HDT  - 30/150 - 0.2, is less  than 1/3, however, because
           the  required  inactivation  is  less  than  2.5-log,  the T10
           evaluation for this system is  appropriate.

           Based on the T10 evaluation, the residual needed to meet the CT
           requirement  is determined as follows:

                        CT « 0.16 mg-min/L

                 C - 0.16 mq-min/L - 0.32 mg/L
                        0.5 min

           Thus, according to  this  approach,  the system must provide an
           ozone  concentration of  0.32  mg/L  to meet  the  inactivation
           requirements.

           Because of  the low T10/HDT  value  for this  system,  the  CSTR
           approach is an alternative for determining  C.  This example is
           presented in Section 0.2.8.2.


     Example 0.2-6  Low Detention Time. Inactivation Required >2.5-1oq

     An  unfiltered water system must  provide disinfection  for  a 4-log

inactivation of viruses  and  a  3-log  inactivation of  Giardia  cysts.   The

ozone system uses a single chamber turbine contactor for disinfection:

           The hydraulic detention time measured at peak flow rate  is 30
           minutes and T10 determined by a tracer study  is 9  minutes.

           The Lp approach  is  not  recommended  for this  system because
           T10/HDT of 0.3 is less than 1/3 and the required level of 4-log
           virus inactivation  is higher than the 2.5-log level.

           SFA or the more conservative CSTR calculations may be used to
           determine the  required  ozone  concentration  for  this system.
           Examples of  the  CSTR and SFA calculations  are  presented in
           Sections 0.2.8.2 and 0.2.8.3,  respectively.

     Example 0.2-7  High Detention Time.  Inactivation Required <2.5-1og

     The  Sturgeon  Bay  Water Treatment  system  (Rosenbeck, 1989)  uses   a

series of two submerged turbine  ozone contactors followed by a reactive

chamber to disinfect ground water:

           The results  of a  tracer study conducted on  one  of the mixed
           contactors is shown on Figure  0-9.

           The T,,  from  this  study  is approximately 30 seconds while the
           hydraulic detention time  is 62 seconds.

                                 0.2-15                        /   .
                                                               i

-------
                     30/62  -  0.48 which  is  greater than  1/3.   Therefore,
             e T10 approach is  appropriate  for this system.

     In this case, the SFA  method is not recommended as an alternative to
the T10  approach  because of the minimal detention times in the contactor.
With such  a short  period  for  the collection of samples,  the data  are
insufficient for  the  SFA method.   The resolution of  the tracer  studies,
apparent in Figure  0-9, will lead  to  an  overly  conservative  estimate of
the inactivation  if differentiation is conducted by a forward algorithm.

     0.2.8.2  Evaluations Using CSTR Calculations
     The following two examples demonstrate the CSTR approach.  One illus-
trates the benefit of the CSTR analysis  over the T10 analysis.  The other
identifies conditions for which the CSTR approach is  not practical.

     Example 0.2-8  Low Detention Time.  Inactivation  Required <2.5-log
     The system  identified in Example 0.2-5 is  a slow sand filtration
plant,   using  ozone to  provide for a 1-log Giardia  cyst  inactivation.
Chlorine provides the 2-log virus  inactivation.  Because the  level of
inactivation required from ozone disinfection is  less than <2.5-log, the
system may choose any method for the determination of the contact time.

           A tracer study conducted on the ozone  contactor resulted  in a
           T10  of 30 sec for  a  HOT of  150 sec.
           The  fraction of  T10/HDT   is  0.2, which   is  less than  1/3,
           indicating that the CSTR approach may be appropriate.
           Chlorine provides disinfection  for the viruses, therefore the
           CSTR  calculation for  the ozone  disinfection  requirements  will
           be based on  Giardia cyst inactivation.
           The following conditions apply:
                  Water  Temperature         -      25 C
                  CT for 1-log  Giardia cyst   -      0.16 mg-min/L

        -   Equation 5 from Section 0.2.5  applies for the CSTR  calculation:
           C(HDT)  -  [1  - (I/I0)]/[(2.303)k

                                  0.2-16

-------
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-------
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-------
            The  parameters  are determined as follows:
            1.     From  Table 0-3, keym - 6.25  for CT - 0.16 min/L  at  25c
            2.     For 1-log inactivation, I/I0  » 0.1
            3.     HOT -  150 sec or 2.5 min
            C  is determined as follows:
            C(HDT) - (0.9]/[(2.303)(6.25) (0.1)]  - 0.625 mg-min/l
                        C» 0.625/2.5 » 0.25 mg/L
     Thus,  according  to the CSTR  approach,  the system must  provide an
ozone concentration of 0.25  mg/L to meet the  inactivation requirements.
For  this  case,  the  system would prefer  to  use  the CSTR approach rather
than the  T10  approach  since  the T10 approach  would  require  a 0.32 mg/L
ozone residual, as shown in Example 0.2-5.

     "Example 0.2-9  Low Detention Time.  Inactivation  Required >2.5-log
     An  unfiltered  water  system  must  provide  disinfection  for 4-log
inactivation  of viruses and 3-log  inactivation of  Giardia  cysts.   The
system uses a  single chamber turbine ozone contactor.  Hydraulic detention
time measured at peak  flow  rate  is 30 minutes and T10 determined by tracer
studies is  9 minutes.   T10/HDT is less than 1/3  and greater than  2.5-log
inactivation is-required,  therefore the  T10 approach  should not be used.
The CSTR or SFA methods 'are appropriate.

            The CSTR calculation  must be  conducted  for both Giardia cysts
            and viruses  to determine the  controlling  parameter
            Compute the  C required for  inactivation  of Giardia cysts:
             -    k cysts - 6.25  (Table 0-3).
                  For 3-log inactivation, I/I0 • 0.001
            Using  the CSTR equation:
            C(HDT) - [1-0.001]/[2.303(6.25)(0.001)]  •  69.5  mg-min/L
            C -  (69.5 mg-min/L)/(30 min)  • 2.3 mg/L
                                 0.2-17

-------
           Compute the required C for inactivation of viruses:

             -   *v,vu. •  13-3 (Table 0-3)

                 For 4-log inactivation I/I0 - 0.001

           Applying the CSTR Equation:

           C(HDT) - [1 -  0.0001]/[(2.303)  (6.25)  (0.0001)] - 326 mg-min/L

           C - (326 mg-min/l)/(30 min) - 10.8 mg/L

     As  indicated,  virus  inactivation  is  the  controlling  parameter,
requiring a C of 10.8 mg/L.  Because of the higher ozone residual needed
for the virus  inactivation,  this  example  illustrates why systems should
verify compliance with the inactivation requirements for viruses as well
as for the inactivation requirements for Giardia cysts.  Since obtaining
an ozone residual  of  10.8  mg/L is unrealistic, this example illustrates
how stringent disinfection  conditions can  become  assuming CSTR character-
istics.  Consequently, the SFA would result in a more feasible residual
requirement for this system.


     0.2.8.3  Evaluations Using SFA

     The SFA method can be conducted  on spread sheets.  Table 0-4 presents
the calculation  procedure  in  spread sheet notations  for  a  step tracer
input:
           The  first  column  of  Table  0-4  represents the  sequential
           numbering of consecutive  tracer  study measurements or digital
           measurement points  fed into the  computer.

           The second  column represents  the  time  interval that elapsed
           between  the  step  change in  tracer  concentration  and  the
           sampling of the specific  tracer  point.

           The third column  represents the  tracer effluent concentration
           at  a  point in  time determined  by the  analyzer (spectropho-
           tometer conductivity meter, etc.)  reading.

           The fourth column represents the tracer response on  a scale of
           0-1, where 0 corresponds to background reading of the analyzer
           and 1  to ultimate  response  after a  long  time  interval.   In
           other words,  it is  C   /Cjn where C^,  is the tracer  concentra-
           tion  in  the  outlet of the  contactor and Cin is the  basal me
           tracer concentration in  the inlet.
                                  0.2-18

-------
            The   fifth column represents   the  forward  derivative  of the
            F(t)  response.   It  is  the  slope of  the  tracer curve  at  a
            specific  time interval,  or the rate at which C^/C,  changes
            with respect to time at different  intervals in time.  Note that
            by  forward  evaluation of the  derivative:  E(t)  «  [F(t+dt)-
            F(t)]/dt  the E(t) curve  Is  shifted  by half  a  dt toward the
            origin.

            This method of differentiation introduces  an inherent safety
            margin  to the  calculation.   Systems can  reduce  this  safety
            margin  by collecting more  tracer  points at the  initial period
            of  the tracer response,  when  the  response  is  starting  to
            increase.

            This  period has  the  largest effect  on  the  accuracy  of the
            tracer  analysis because  most of the contribution  to the total
            survival of microorganisms comes from the organisms that remain
            only for  short  time  interval in the contactor.

            The sixth column represents Chick's inactivation  rule, computed
            at the  concentration and the appropriate 10"kct.

            The seventh column represents the  survival  expectancy function
            (Es(t)  -  E(t)(10"kct) which is the  product of columns 5 and 6.

            The  eighth column represents  the organism  survival  in each
            segment passing through the contactor.  It is also known  as the
            integral  of  the survival expectancy function  (Es  presented in
            the 7th column).

            The  survival  ratio  (I/I0)  is  the  sum  of  column  8.   This
            represents  the sum  of  organism  survival   in  all  the  water
            segments  passing  through the contactor.

            Table 0-4 Illustrates only one form of performing  the integra-
            tion (i.e., quadratic integration).  Other  integration methods
            can also  be  used.

            The  corresponding  log  inactivation  and   the  corresponding
            calculated  CT may be  computed  by the procedures outlined in
            Section 0.2.4.
     The  following examples  illustrate  the  use of  the SFA  method to
calculate conditions in ozone contactors,  and a situation where SFA cannot

be used.


     Example 0.2-10  Turbine  Contactor
     As  noted  in  Example  0.2-4,  the  ozone  system  at  Haworth Water

Treatment  Plant,  uses  a  turbine  ozone  chamber followed  by a  reactive

                                  0.2-19

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chamber to provide additional contact time.  A tracer study was conducted
on one of the contactors  resulting in a T10 value  of  11 minutes for a HOT

of 20 minutes.  Using the same conditions as the above cited example, the

SFA will  be  conducted on the  tracer  data.   The following illustrates a
step by step procedure  for  conducting a  SFA:


           The digitized tracer response (F(i))  is depicted in  Figure 0-10
           as a  function  of t(i) where:

                  i stands for the consecutive numbering of randomly chosen
                  points  from the tracer  study  chart,  and

                  t(i)  is  the corresponding  time coordinate.

           The slope of the tracer  curve,  also  known as the density of the
           expectancy   function,   E(t)   approximated  by  the  following
           equation  is  depicted in Figure 0-10.
           The  digitized  points  were not translated into a smooth curve
           in order to  avoid  numeric compromises.

           The  survival expectancy (Es(t)) was then calculated by Es(i)=Et
           (i)(10'kct0)) and   summed  to  give  the survival  ratio  (I/I0) as
           shown  in Table  0-5.

           Figure 0-11  depicts  the integration for conditions  where  the
           ozone  residual  is  C -  0.15 mg/l.

           The  cumulative  survival  ratio is  0.00982 which is below 0.01
           assuring compliance with  the  2-log or 99 percent  inactivation
           requirement  for Giardia  cysts.    A  survival  ratio  of <0.01
           corresponds  to  an  inactivation  of greater than 99 percent or
           2-log.

     The residual value determined from  this method .is  lower  than  O0.17

mg/l predicted  by the  T10 approach presented in Example 0.2-4.   Although

this example only shows a  small difference in C values needed,  other cases

may result in a greater reduction of C compared to the C resulting from

the T1Q  approach.
                                  0.2-20

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                   TABLE 0-5

            Segregated Flow Analysis
of an Ozone Disinfection Contactor at Hackensack
time
(min)
0
1
2
3
4
5
6
6.5
7
8
9
10
11
12
13
14
15
16
17
18
19
21
23
25
27
34
36
41
45
height
(mm)
0.0
0.0
0.0
0.0
0.0
0.0
0.3
0.5
2.0
3.0
5.0
8.0
12.0
19.0
26.0
31.0
36.0
42.0
51.0
59.0
69.0
80.0
90.0
94.0
98.0
113.0
114.0
124.0
124.0
F(t)
0.000 •
0.000
0.000
0.000
0.000
0.000
0.002
0.004
0.016
0.024
0.040
0.065
0.097
0.153
0.210
0.250
0.290
0.339
0.411
0.476
0.556
0.645
0,726
0.758
0.790
0.911
0.919
1.000
1.0000
E(t)
0.000
0.000
0.000
0.000
0.000
0.002
0.014
0.013
0.008
0.016
0.024
0.032
0.056
0.056
0.040
0.040
0.048
0.073
0.065
0.081
0.044
0.040
0.016
0.016
0.017
0.004
0.016
0.000
0.000
10'kct
(C-0.16
k-1.03)
1.000
0.708
0.502
0.355
0.252
0.178
0.126
0.106
0.089
0.063
0.045
0.032
0.022
0.016
0.011
0.008
0.006
0.004
0.003
0.002
0.001
0.001
0.000
0.000
0.000
0.000
0.000
0.000
0.000
Es-
-E(t)10'kct
0.00000
0.00000
0.00000
0.00000
0.00000
0.00043
0.00173
0.00143
0.00072
0.00102
0.00108
0.00102
0.00127
0.00090
0.00045
0.00032
0.00029
0.00027
0.00018
0.00016
0.00006
0.00003
0.00001
0.00000
0.00000
0.00000
0.00000
0.00000
0.00000
(Es)At
0.00000
0.00000
0.00000
0.00000
0.00000
0.00013
0.00035
0.00215
0.00072
0.00204
0.00324
0.00408
0.00889
0.00630
0.00225
0.00160
0.00174
0.00243
0.00144
0.00160
0.00066
0.00030
0.00004
0.00000
0.00000
0.00000
0.00000
0.00000
0.00000
                                                      0.00982

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0.2.9  ESTIMATING T

     The results  of  this section  are summarized  in  Figure 0-12.   The
decision tree  shows  the  applicable  methods  of estimating  T for  each
approach,  and provides a quick means  to  compare  alternatives  and  make a
selection.
                                 0.2-21

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              0.3   DETERMINATION  OF  OZONE  CONCENTRATION  (C)

     0.3.1 Introduction
     This  section  presents  ways  to  measure  or  estimate  the  ozone
concentration,  C,  for  the  calculation  of  CT.    An  alternative,  more
elaborate concept,  requiring better  characterization of the hydrodynamics
of the ozone contactor is presented in Section 0.4 of this appendix.
     EPA recommends use  of  the average dissolved  ozone  concentration in
the water for C  for all types of ozone contactors.  The average concentra-
tion may be determined by one of  following methods:
     1.    Direct  measurement of  the concentration  profile of dissolved
           ozone in each contact  chamber
     2.    Indirect prediction of the  average concentration by assuming
           a set of conservative correlations between an observed variable
           such as  the concentration of ozone in the outlet  from the ozone
           chamber and the average concentration within the  ozone chamber.
     The application of these methods to estimate the average concentra-
tion should  take  into  account the gas/liquid  flow  configuration  in the
ozone contactor.   The  next  section  presents  a short discussion  of the
types of liquid/gas contact  in  ozone  chambers,  followed by two sections
that describe  the  methods  to estimate the  average  concentration  in the
chamber based on simple measurements.

     Classification of Ozone Chambers
     Ozone contactors currently  in use or  in  design stage in the US may
be classified  into  four  types of flow configurations as  illustrated on
Figure 0-13.   This,  of course, does not preclude the  use  of other types of
contactors. The four configurations are as follows:

     1.    Continuously Stirred-Tank Reactor  (CSTR):
           Ozone contactors using turbine agitators, where the water may
           be considered uniformly mixed  as  shown on Figure 0-13, diagram
           1.  Studies conducted in a full scale turbine contact chamber
           indicate that turbine contactors may be considered uniformly
                                  0.3-1

-------
           mixed (Schwartz et,  al., 1990). This study was conducted in the
           first contact  chamber  under  conditions  of  high  ozone demand.
           Therefore,  it  is assumed  that  under less  stringent  kinetic
           conditions, turbine contactors can still  be considered uniform-
           ly mixed.

     2.    Counter-Current Flow Chambers

           In these  chambers,  the  water flows opposite the direction of
           the gas bubbles. For example, the first and third chambers in
           the Los-Angeles ozone treatment system, as shown  on Figure 0-2.

     3.    Co-Current plow Chambers

           In these  chambers,  the  gas bubbles  and  the  water flow in the
           same direction. For example,  the  Deep U-Tube contactor shown
           in Figure 0-5 and the Static  Mixer  contactor. This is the case
           also for  the conventional  gas/liquid contact chambers such as
           the second contact  chamber in  the configuration designed for
           the East Bay MUD water disinfection system,  as shown on Figure
           0-4.

     4.    Reactive  Flow Chambers

           In these chambers,  no gas  (and ozone)  is  being introduced into
           the chamber or conduit. The second and fourth chambers of the
           Los Angeles water disinfection  system  are reactive chambers
           (Figure 0-2).
     0.3.2 Direct Measurement of C

     Direct  measurement  of  the  dissolved  ozone  concentration  is  the
preferred method  to  determine the ozone  concentration  in  ozone contact
chambers.    However,  very  little full  scale  experience   is  currently
available with this type of measurement.  Some guidelines were developed

based on the limited  studies conducted at the Haworth,  NJ (Schwartz et al.
1990)  and  Los Angeles  water  treatment systems  (Stolarik  and Christie,
1990).    The  guidelines  developed   for  direct  measurement  of  ozone

concentration in the liquid phase are detailed  in the  following sections.


     Analyze  Each Chamber Separately
     Every chamber of a  multiple-chamber unit should be analyzed separate-

ly. Different chambers in series exhibit different ozone  consumption rates
and reactivities  and,  therefore,  are likely to have different dissolved

ozone profiles.
                                  0.3-2

-------
      1  TURBINE CHAMBER
      2 COUNTER-CURRENT    4-
        CHAMBER

                                  J  L
       3 CO-CURRENT CHAMBER


       4. REACTIVE FLOW
         CHAMBER
                                                         L: Liquid
                                                         G: Ga*
FIGURE 0 13- FLOW CONFIGURATIONS IN OZONE CONTACTOR  CHAMBERS

-------
      Avoid  Interference From Gas Bubbles
      Gas  bubbles may strongly  interfere  with the measurement  of  ozone
concentration, particularly if some bubbles  are carried into the sampling
taps.   This interference  may be reduced  by directing  the  sampling port
opposite to the direction of the bubble flow in order to prevent gas from
entering the sampling tube. Additionally, the operator should verify,  by
visual  inspection, that the sample water does not contain gas bubbles.
      Systems using in-situ  ozone  analyzers  should  be  careful  to prevent
direct  contact of gas bubbles with the  measuring  probe which is usually a
gas permeable membrane.  Such contact may bias the measurements and give
high  results.

      Minimize Distance to Ozone Analyzers
      Minimize the distance from the sampling ports to the ozone analyzer
to  limit  ozone  consumption  by reducing  agents  in  the  water.    This
consideration is particularly important when evaluating the concentration
profile in  chambers with high  ozone  demand  such  as the first chamber in
multiple-chamber units.

      Provide Proper Soacial Distribution
      The vertical  profile  of  the  ozone concentration in  ozone contact
chambers should  be measured in at least  five vertical  locations  and at
least two different horizontal  locations for each vertical sampling point
within  the  contact  chamber.   Each  sample  should  represent  the time
averaged concentration at the specific  location. This may be achieved by
sampling a large volume of water into a container and analyzing the water
by  the  indigo trisulfonate  method (Bader  and  Hoigne,  1982).   In-situ
measurement of ozone  should  be carried out over a  sufficient time interval
to suppress temporal  fluctuations.  Such  instruments should be initially
calibrated by the indigo trisulfonate method.  Facilities that have more
than  25 percent  deviation  between the  average  concentration at  two
horizontal  locations  should collect additional   measurements  at a  third
location.   The  average of all measurements may  be taken as the average
concentration  of dissolved  ozone in  the ozone  contact chamber.    For
systems with a  symmetrical  vertical  distribution of ozone concentration
                                  0.3-3

-------
 the  vertical  sampling  points  should be  equidistant.   Systems  with  an
 asymmetrical  distribution of  available  sampling  points can  perform  an
 integration  of  the  data  to estimate  the average concentration  in  the
 chamber.  An  example of this is given at  the end of this section.
     Some  contact chambers,  such  as  the Deep U-Tube  chambers,  static
 mixers and reactive flow chambers have a high length to width ratio, where
 the length of the chamber in the direction of fluid flow is greater than
 four times  the  cross section  length.  These  chambers  have more uniform
 radial  concentration  profiles,  eliminating  the  need to measure  the
 concentration at  various  vertical  or  horizontal  locations.   Therefore,
 measuring the concentration profile at  several  points along the flow path
 should be sufficient to accurately determine the average concentration.

     Select Representative Locations
     All sampling positions should be placed  in  representative locations,
 avoiding stagnant zones and zones  near  the wall. Measurements  in stagnant
 locations will lead to low values  of  the  average residual concentrations.
 While measurements at  the wall may result in either  an underestimate or
 overestimate  of the residual depending on  the ozone flow pattern.
     Systems  having two or more identical  parallel  ozone contact chambers
 may determine the average ozone concentration  by measuring  the concentra-
 tion profile  at  one  horizontal location  in  each  contact  chamber. These
 systems should,  however,  show by dual or triple horizontal measurements  in
 at  least one of-the parallel  chambers  that  the  measurement  in  the
 particular horizontal  location adequately represents  the concentration
 profile in the contact chamber.

     Example  0.3-1
     A system with a  co-current chamber with dimensions of 10'  X  10' x 20'
was sampled to  determine the  average concentration  in  the chamber.    In
 accordance with  the  recommended guidelines,  the  following samples were
 taken:
                                  0.3-4

-------
             Water               Ozone Residual (mg/t)
           Depth  (ft)                H.          H,
                2                   0.1         0.12
                6                   0.15        0.17
               10                   0.15        0.14
               14                   0.3         0.25
               18                   0.6         0.65

           The  horizontal   sampling  point  measurements  are within  25
           percent of each  other indicating  that no additional horizontal
           sampling' is needed.  Figure  0-14a shows the sampling locations
           and the resulting ozone profile.

           Average the  H,  and  H,  sampling  points  to determine C   :
           Cava "  (0-1  + 0-15 + 0.15 + 0.3  +  0.6  +  0.12 + 0.17  + 1).14 +
           O.Z5 + 0.65)/10 = 0.26.  Cavg equals 0.26 mg/L, which is C for
           the chamber.
     Example 0.3-2

     A system with  a  co-current chamber and  the  same dimensions of the

system in Example 0.3-1 has sampling results as follows:
            Water                  Ozone Residual  (mq/L)
           Depth (ft)
             2
             8
            14
            16
            18
H.
0.1
0.16
0.27
0.70
0.52
H,
0.12
0.14
0.3
0.73
0.61
Averaae10
0.11
0.15
0.285
0.715
0.615
     (1)
        Average ~ (H, + H2)/2

           The  sampling  points  are not  vertically equidistant  so the
           system  will  plot  the   average  ozone  concentration  of the
           horizontal  sampling points versus depth  to calculate the area
           under  the  curve.    This  approach should only  be  used  if the
           sampling points cover the range  of the water depth.

           As shown on Figure  0-14b,  the area under the curve  is deter-
           mined for the range of depths  sampled from 2 to 18 ft.

           Several methods can be  used  for calculating the area  includ-
           ing:

                       Measurement  with  a planimeter
                       Mathematical methods such as:
                             Simson's Rule
                             Runge  Kutta
                                  0.3-5

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           The area under the curve is in units  of mg/L-ft.  C   is deter-
           mined as:
                             	area (mq/L-ft)	
                             range of depth sampled (ft)
           For this data, use of a planimeter results in  an area of 5.44
           mg/L-ft, with the concentration determined as  follows:
                       5.44 mq/L - ft    *     0.34 mg/L
                        18 ft - 2 ft
     0.3.3 Estimating C Based on Residual Measurements at the Outlet
     For many systems, measuring ozone profiles in their ozone chamber may
be  impractical   because  of  physical  constraints.    These  systems  may
estimate C in the chamber based on measurements of the ozone residual at
the  outlet  from the  chamber.  EPA  has  established  correlations  for
different types of gas-liquid contact configurations currently in use in
ozone contactors.  These  relationships were derived based on conservative
assumptions  regarding the  type of flow  configuration  in the contactor.
Due to the highly reactive  nature  of  ozone  the  values  for C vary slightly
between  first  chambers  and  subsequent  chambers.    The  recommended
concentrations for first and subsequent chambers are summarized in Table
0-6.

     0.3.3.1 First Chambers
     A  first  chamber is  the chamber in  which  ozone is initially intro-
duced.  In establishing guidelines for determining C values for the first
ozone contact chamber, the  following items were  considered:
      1.    The relationship between C and the outlet concentration in the
           first chamber of a multiple-chamber system  (or single chamber)
           may  be very  sensitive to  the reaction  order  of  the ozone
           consumption kinetics.
           The average concentration in the contactor may be  less  than 10
           percent of the outlet  concentration.  This was demonstrated in
           pilot  plant studies conducted  in  a  multiple chamber system by
           Stolarik  and Christie, 1990.   Therefore,  general relationships
           between the residual ozone concentration at the outlet from  a
           first  (or  single)  ozone contact  chamber  and  the   average
           concentration in this  chamber cannot  be  developed.
                                  0.3-6

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                                    TABLE 0-6

                         CORRELATIONS TO PREDICT C BASED
                        ON OUTLET OZONE CONCENTRATIONS'1-3)
                               FLOW CONFIGURATION
CO-CURRENT
TURBINE FLOW
First Chamber
C PARTIAL'2'
CREDIT
Subseauent Chambers
C • Cout C • Cout
or
COUNTER-CURRENT
FLOW

PARTIAL(2)
CREDIT

C - C^/2
REACTIVE
FLOW

NOT
APPLICABLE

c - cout
                                           Cfn)/2
1.  Definitions:

  C     Characteristic Concentration   (mg/L)

  CQLJt   Dissolved ozone concentration  at the outlet from the chamber  (mg/L)
C
        Concentration of ozone at the  inlet to t  » chamber  (mg/L)
2.  1-log of virus inactivation providing that Cout  >    1 mg/L and 1/2-log Giardia
    cysts inactivation providing that CM >  0.3 mg/L.


3.  Alternatively,  C  may equal the average concentration as evaluated by  the direct
    measurement method (Section 0.3.2).

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     2.    The rate of disinfection of viruses  (coliphage) by ozone often
           decreases  with  respect to  contact  time whereby  the  initial
           inactivation rate is very fast and deteriorates afterwards.
     3.    Pilot  plant experiments  reported by   Wolfe  et al,  (1989)
           suggest  that the  inactivation  of  organisms  including  MS2
           bacteriophages,  Giardia muris cysts,  R2A bacteria and E. Coli,
           in  the  first chamber  of  a multiple-chamber reactor  is  very
           rapid even when high ozone demand waters are used.

     Considering  these, items,  EPA  recommends  a  general   guideline  of
crediting  the  first ozone chamber  with CT credits equivalent to 1-log
virus  inactivation  and  0.5-log  Giardia cyst inactivation,  provided  that
the residual concentration measured at the outlet from the first  contact
chamber exceeds  0.1  mg/L  and 0.3 mg/L,  respectively,  regardless  of the
contactor  configuration.   However,  this guideline does  assume  that the
volume of the first  chamber is equal to the volume of subsequent chambers.
The credit for 1-log virus  inactivation at  an outlet residual of 0.1 mg/L
may appear conservative with respect to MS2 bacteriophage data, however.
only limited data for ozone  inactivation of the  animal viruses of concern
is currently available.  Preliminary test results indicate that bacterio-
phage may not be an  appropriate  indicator for virus inactivation by ozone
(Finch, 1990).
     Systems may prove higher performance of their  first contact chambers
by measuring the concentration profiles in  the  first chamber, as outlined
in Section 0.3.2t>r  by applying the more sophisticated methods that are
presented  in Section 0.4.

     0.3.3.2   Subsequent Chambers
     The correlations in Table 0-6 are based on analysis of  the dissolved
concentration profile in liquid/gas contacting chambers. All correlations
rely on  the  accurate measurement of  ozone concentration  outside of the
gas/liquid contacting regime.  Concentrations at the outlet from the ozone
contact chambers can be measured accurately without interferences  from the
ozone bubbles.  The correlations  represent  the  highest possible estimate
of  C  that  can  be  supported without  site-specific  test  data.   These
estimates  are conservative and systems may choose to determine  C  based on
                                  0.3-7

-------
direct measurement of the concentration profile in the contact chamber, or
use one of  the procedures recommended in Section 0.4.
     Correlations  were developed for the four  types  of flow configura-
tions:
                 Turbine
                 Counter  Current Flow
                 Co-current Flow
                 Reactive Flow

     Turbine
     For  turbine  chambers  or  rigorously  mixed  chambers,  the  flow
characteristics in the chamber  approach that of a CSTR and, therefore, the
concentration at  the outlet from the  contactor (Cout)  is assumed  to be
representative of the dissolved concentration of ozone in the liquid phase
(C).  Currently,  contactors  using turbine agitators appear to approximate
CSTR characteristics  (Schwartz et al,  1990).  Other  systems  with  T10/HOT
values less than 0.33 may use  the same  correlations.   This correlation is
applicable  to every chamber, including turbine contactors used for first
chambers or as a single chamber contactor.
     The measurement of ozone concentration in the gas phase  is a possible
alternative for determining C  although such  correlations will  be highly
site specific.  A procedure  to  develop  site specific correlations between
the average ozone concentration and the off-gas concentration  is presented
in Section 0.4.2.1.
               *-^

     Counter-Current  Flow
     In counter-current  flow,  the water  flows opposite to the direction
of bubble rise.   Measurement of the  concentration profile in such systems
revealed that the  concentration  in  the liquid phase uniformly increased
with depth  in the ozone  chamber as shown  in Figure  0-15.  The  maximum
concentration in the  chamber  is  achieved  near the water outlet from the
ozone chamber.
     Measurement of the ozone  concentration  in an ideal  plug flow chamber
reveals that  the  average concentration is only  25 to 50 percent of the
outlet concentration  for these chambers under  typical operating condi-
tions.  Additional  contributions to the  average concentration that are not
accounted  for by  the plug  flow  analysis,  include  the contribution of
                                  0.3-8

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         TOP
    Q.
    LU
    o

    QC
    UJ
     BOTTOM
                  INCREASES
            DISSOLVED OZONE RESIDUAL


   A  COUNTER-CURRENT FLOW PROFILE
         TOP
     z
     K-
     a.
     UJ
     o

     QC
     UJ
     BOTTOM
                      INCREASES
               DISSOLVED OZONE RESIDUAL

      B. CO-CURRENT FLOW PROFILE


FIGURE 0-15-020NE  CONCENTRATION PROFILES

-------
turbulence and the contribution of the inlet concentration. Based on these
considerations, EPA recommends the use of one-half the outlet concentra-
tion of ozone as  an estimate for C.
     The measurement of ozone concentration in the off gas is a possible
alternative for determining  the  average ozone concentration although the
correlations will  be  highly site specific. A procedure  to  develop site
specific correlations between the average ozone concentration  and the off-
gas concentration  is presented in Section 0.4.2.1.

     Co-Current Flow
     In  co-current  flow,   both  the  water and  gas  flow  in  the  same
direction.   The  ozone  concentration profile  in  co-current  operation
increases until  it reaches a maximum and then decreases along the contact
chamber  as  shown  on  Figure 0-15.    The  dissolved  ozone  concentration
increases at the  beginning of  the column  due  to  dominant  mass transfer
from the ozone  rich bubbles.  Then the gas  phase becomes depleted of ozone
and the  impact  of ozone  consumption  in  the liquid  phase  dominates the
ozone profile.   C  can be estimated as the concentration of dissolved ozone
at the outlet or by the  average of  the inlet and outlet concentrations of
dissolved  ozone,  whichever  is  higher.  This  estimate  should  still  be
conservative, particularly for  systems exhibiting  high transfer efficien-
cies.
     The measurement of ozone concentration in the off gas is a possible
alternative for determining the average ozone concentration although the
correlations will  be  highly site specific. A procedure  to develop site
specific correlations between the average ozone concentration and the off-
gas concentration is presented in Section 0.4.2.1.

     Reactive Flow
     In ozone  chambers  operated  in  a reactive flow configuration, the
water contains  dissolved ozone residual  from previous  chambers  but no
additional ozone  is  being introduced. Reactive flow chambers  are used:
for other disinfectants,  such as chlorine,  chlorine dioxide and chloramin-
es; for the decay of ozone  following  a contactor  or a static mixer; and
for combining ozone with hydrogen peroxide.
                                  0.3-9

-------
     For  static  mixers,  the mixer  acts  as a  turbine  chamber with  the
pipeline following the mixer acting as the reactive chamber.  The pipeline
is in effect the second chamber  and the guidelines in Table 0-6 apply  for
the  determination of  C.   The  contact   time  in  the  pipeline  can   be
calculated by assuming plug flow.
     In order  to be  consistent  with the  recommendations  for  monitoring
other disinfectants  in  reactive flow chambers,  and in order  to  assure
compliance under  worst case  conditions,  the use of the  residual  outlet
from the chamber (C^) is recommended as a conservative  measure  of C.  The
CT for  reactive  flow chambers  may be estimated  by  dividing the  chamber
into subunits,  measuring  the concentration at the  end of each subunit,  and
adding the CT credits.
     Estimates of C based on the  outlet concentration were conservatively
developed based on available test data.   EPA's recommended values for C
                            <
are summarized in Table 0-6.  A  system may choose  to  perform  additional
testing for  direct  measurement  of ozone residuals to support  a  higher
value,  if appropriate.    In  addition, a reactive  flow  chamber  may  be
subdivided into smaller units with ozone measurements at the end of each
unit to improve CT credit.

     0.3.4 Estimating C
     The  results  of   this  section  are summarized  in  Figure 0-16.   The
decision tree shows the applicable methods of estimating C for each flow
configuration, and provides a quick means to compare alternatives and make
a selection.
                                 0.3-10

-------
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-------
            0.4  SITE-SPECIFIC  EVALUATION  OF OZONE  CONTACTORS

     0.4.1  Introduction
     The  second  set of guidelines  is  designed to prevent  systems  from
costly  over-design and use  of overdoses of  ozone,  by performing  site
specific  characterization of their  ozone  contactors.   This  approach was
partially utilized  in the previous two sections by recommending a direct
measurement of the ozone concentration  profile  and  by allowing systems to
use  the  SFA  or  CSTR  approaches.  In   this  section  the  site  specific
evaluation  procedure  will be further developed by presenting additional
options to improve disinfection credits or simplify  monitoring procedures.
EPA  recommends  the  following  three   alternatives  for  site  specific
evaluations:
            Estimating C by measurement of another  variable
            Modeling performance of field scale operation
            Use of microbial  indicator  studies
     C  may  be estimated by  measuring  an easily  monitored  (observable)
variable. Systems should develop site specific  correlations  between C and
another  observable parameter  such  as   the  gas or liquid  concentration
exiting  (Cout)  the chamber  and  monitor  this  observable parameter instead
of C.   Guidelines  to develop such site  specific  correlations  are presented
in Section  0.4.2
     Modelling the. performance  of full  scale operations  is an alternative
to the  separate  C and T  approach. The  first procedure  separated the
analysis  into two separate  issues  related   to   determining  C  and T.
Extensive modelling of the  system may predict higher inactivation levels,
even  for the  same C  and  T.    EPA recommends  that  systems  construct
mathematical models of their ozone contactors  to predict the disinfection
performance,  provided  that  the  models  are  confirmed by  experimental
observation  of the actual  ozone concentration  profile  in the contact
chambers, as discussed  in Section 0.4.3.
     Microbial indicator studies may be used to determine the inactivation
of viruses  and Giardia cysts  in  ozone contactors.  EPA  recommends  that
systems  be  allowed to evaluate  the   performance  of  their  disinfection
systems by  spiking  a pilot  of the contactor  with an indicator microorgan-
ism and  predicting the actual  inactivation  of Giardia cysts and  viruses
                                  0.4-1

-------
based on the inactivation of the  indicator microorganisms. Guidelines   to
conduct such pilot scale performance  evaluations are presented in Section
0.4.4.

     0.4.2 Site Specific Correlation of C with an Observable Variable
     Section  0.3  recommends determining  the  concentration  of  ozone  in
contactors by one of the following ways:

     1.    Measure the concentration  profile in the chambers and determine
           the average dissolved ozone concentration for C.
     2.    Measure  the dissolved  concentration  of ozone  in the  water
           outlet from each chamber  (C  ) and estimate C by  the correla-
           tions presented  in Tables O-o.

This section presents  an alternative method to determine C.
     The SWTR requires unfiltered  systems to report a daily  CT for their
disinfection  systems.    Similar requirements  may be  specified  by  the
Primacy Agency for filtered systems.  Measuring the concentration in  the
ozone  chambers  each  day   may  be  difficult.    Determining  the  ozone
concentration in a chamber  by  continuous  or daily measurements of other
variables is probably  preferable.   Likewise,  many systems may prefer  to
monitor the ozone concentration  in the  off  gas (Y^)  or via the applied
ozone dose rather than monitor C^.  However, based on available data, a
non-site specific correlation between the average ozone concentration in
the  chamber  and  an  observable  variable other  than taut  could  not  be
developed.
     EPA encourages systems  to develop such site specific  correlations and
use  them  instead  of  the general procedures.   These  correlations may  be
developed in one of the following  ways:
     1.    Determine site specific correlations  between  C^. and  another
           variable that can be easily monitored.  Measure the  variable.
           estimate C0 t and then use the correlations  presented  in Tables
           0-6 to predict C.
     2.    Determine  site  specific  correlations  directly between C  and
           another variable such as the ozone concentration in the off gas
           (Y  .} or  C  t.  Measure  that  variable  and  estimate C.
           * OUt'     OUt
                                  0.4-2

-------
      Correlations between C or Cout and  a measurable parameter may vary  in
complexity  from  a  simple  empirical  linear  correlation  to  a  highly
sophisticated mathematical  model  accounting  for  the  ozone  concentration
profile  in the contact chamber.  Development of appropriate correlations
depends  on the engineering  capabilities of  the utility.   Therefore,  EPA
does  not  recommend  any  particular mathematical relationships.   However,
the following sections present guidelines  to  assist systems in developing
appropriate correlations.

      Correlations for Specific Chamber^
      The  correlations  should  refer  to a  specific  contact  chamber  and
should be verified to fit the  performance  of  this chamber. For example, a
correlation for the  first chamber should not be used to predict C in the
second chamber of a  multiple-chamber system.

      Developing the  Correlation
      When fitting the correlation with  experimental data, a record of the
following variables  should  be kept:

             a.  Water flow rate
             b.  Gas flow rate
             c.  Ozone concentration in the  gas feed
             d. "bzone transfer efficiency
             d.  Water temperature and pH
             e.  Concentrations  of  all  major  inorganic reducing agents,
                 if  they constitute a substantial  proportion  of  the total
                 ozone  demand,  such  as  iron(II)  and  manganese,  TOC,
                 alkalinity and  turbidity.
             f.  C^ or  whatever  is  being correlated
             g.  The measurable variables such as ozone dosage  or C^

      The system should also record the dependent  {C or C^)  and indepen-
dent  measurable variables.
                                  0.4-3

-------
     Application of the Correlation
     The  correlation  should  be evaluated  with  at  least  a 90  percent
confidence  level.  Since  confidence  margins are  very  sensitive to  the
number of observations used to develop the relationship, this requirement
will prevent the use of correlations that are based on a limited amount of
observations.   On  the other  hand,   because systems usually make  daily
records of  most of the parameters needed to develop a  correlation,  the
number of  observations  will  usually be very high,  thereby,  providing  a
high confidence level  for  the correlation.   Simple  procedures to determine
confidence  intervals are  presented in statistical  textbooks.
     The correlation nust be checked  periodically,  such as monthly,  as an
additional  precaution against unexpected shifts in water conditions.
     The correlation should be applied only  to  conditions that are within
the parametric range for which the correlation  was  developed, as noted in
the second  guideline.   Interpolation is permitted but  extrapolation is
not.  Correlations  developed during the  winter  time should not be used to
evaluate performance in the summer.
     EPA believes  that by permitting  such  correlations,  systems will be
encouraged to apply sophisticated mathematical models in order to decrease
the confidence  interval and  administer  smaller doses of ozone.  EPA also
expects that systems will  develop correlations between C in the contactors
and measurable parameters to simplify their operations.  Small  or lesser
               "***
equipped systems will  then be able to use these relationships to estimate
the performance of  their ozone contactors.  EPA intends  to follow advances
in  this  field and issue  updated  examples  and guidelines  regarding  the
selection of efficient site specific correlations. ..

     0.4.2.1  Utilizing Off-Gas Measurements
     In ozone contactors,  the gas  and liquid streams  equilibrate when the
contact between the gas and liquid is intimate enough and for sufficient
time,  otherwise the concentration  in  the  water phase will  be much lower
than the  equilibrium concentration.   It can  be   assumed that  close to
equilibrium conditions are  reached,  when  the  transfer efficiency in the
contactors  is  greater  than 85 percent  ((Y^-Y^J/Y,,, >  0.85).   When the
transfer efficiency is greater than 85 percent, systems  may use solubility

                                  0.4-4

-------
constant  data  to calculate Cout  from the contactor, based on  the  ozone
concentration  in the off gas. This may lead to a slight over  estimate of
the concentration in the liquid phase but this  over estimate is justified,
in view of the better reliability of gas phase measurements.
     Henry's constants for ozone at  various temperatures are presented in
                                                               «
Table 0-7. The residual concentration of ozone may be estimated by:
     Where:
           Yc^t  =       The concentration of ozone in  the gas phase (ppm -
                       volume or partial pressure-atm)
           C    =       The  concentration  of ozone  in the  liquid  phase
           H    =      Henry'^s constant (atm/mg/L)
      When applying off-gas modelling, liquid phase measurements must be
made  periodically  to check  the  correlation,   as  the  ozone  transfer
efficiency has a high  impact on the results of this correlation.
      Systems must  be  cautioned  against  the use of off-gas measurements
for  multiple chamber  contactors  with  a  common  headspace.    As  noted
previously, modelling must be specific to  individual chambers.  Thus, if
a contactor has a common head space between chambers, no distinction can
be made  as to  the  concentration  in  each chamber.   Therefore, off-gas
measurements  for  modelling are  recommended for  use with single chamber
contactors.

      Example 0.4-1
      The  Metropolitan Water  District of Southern California  conducted
off-gas monitoring on a single chamber co-current flow pilot contactor to
determine  the dissolved ozone concentration:
            Operating  conditions were as  follows:
                  source water: Colorado  River
                  feed gas ozone concentration  *  2  percent by weight
                  off  gas  ozone concentration -  0.185 percent by weight
                  (or  0.123 percent by volume)
                                  0.4-5

-------
                  transfer efficiency - 90.8 percent
                  temperature » 16.5 C
                  observed ozone residual « 1.04 mg/L
                  Henry's constant 16.5°C - 0.001179 atm/mg/L
            The ozone  residual  estimated  from  the  off gas concentration
                  Cout-Yout/H  « 0.00123/0.001179
                      ,  - 1.04 mg/L
            The measured  residual  is the same as  that  predicted by the
            off-gas measurement  indicating that this approach  is appropri-
            ate for this system.

      Example 0.4-2  Empirical Correlation between Cout  and Yout
      A system using two counter-current contact  chambers  in  series wants
to predict Cout in the second  chamber  by  the concentration  of  ozone in the
off-gas (Yout).  Daily observations  of the  pertinent parameters during tne
first month of operation are presented  in Table 0-8.
            The system chose  to  correlate  £M and Yout  by linear empirical
            correlation.
            The daily observations, and  the best  linear  fit are presented
            in Figure 0-17.
            The 90 percent confidence interval  is  presented  by the lower
            1 ine"~in Figure 0-17.
            The system  may use  the 90  percent confidence level  line to
            estimate Cout based  on  measurements of  Y^.
            For example when  Yout -  0.4 percent then the system may use Cout
            - 0.36 mg/L.
            Although  the  best  estimate is  C^  «  0.4  mg/L,  the system
            should predict Cout  - 0.36 mg/L.
            Now, according to Table  0-6,  the  system may predict C using
            the recommended guideline of C - C^/2  - (0.36J/2  » 0.18 mg/L.
            The system  measures the  ozone concentration  at  the chamber
            outlet monthly,  to check the  model  correlation.
                                  0.4-6

-------
                          TABLE 0-7

                HENRY'S  CONSTANTS  FOR OZONE<1)
        Water
      Temperature       Henry's Constant        Henry's Constant
         (°C)           atm/Mole Fraction       (a.tm/mq/1 ozone)

           0                  1,940                 0.00073
           5                  2,180                 0.00082
          10                  2,480                 0.00093
          15                  2,880                 0.00108
          20                  3,760                 0.00141
          25                  4,570                 0.00171
          30                  5,980                 0.00224
NOTE: {1) EPA,  1986

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                               TABLE 0-8

                         Empirical Correlation
                          Between C   and Y
                                            Temp. 8C       YjnS

 0.5             0.5            2.0                 20          20
 0.47            0.43           2.8                 15          2.0
 0.38            0.41--          2.5                 17          2.0
 0.39            0.4            2.3                 18          2.0
 0.28            0.32           2.4                 18          2.0
 0.2             0.17           2.6                 20          2.0
 0 25            0.23           2.0                 20          2.0
 0.32            0.27           2.0                 21          1.9
 0.29            0.27           2.0                 18          1.9
 0.2             0.18           2.0                 17          2.0
 0.22            0.2            1.9                 18          2.1
 0.30            0.33           1.8                 20          2.0
 0.32            0.34           1.9                 17          2.0
 0.28            0.27           1.9                 18          1.8
 0.29            0.32           2.5                 18          1.9
 0.4             0.42           2.4                 19          1.9
 0.47            0.45           2.3                 19          1.8
 0.35            0.37           2.4                 21          1.9
 0.30            0.29           1.9                 19          1.8
 0.20            0.17           1.9                 19          1.8
 0.15            1.19           2.0                 19          2.0
 0.12            0.20           1.9                 17          2.0
 0.17            0.17           1.9                 19          1.9
 0.14            0.16           2.0                 19          2.0
 0.13          J3.12           1.9                 18          2.0
 0.25            0.27           1.9                 17          2.0
0.29            0.32           1.9                 18          2.1
0.30            0.29           1.8                 17          2.0
0.22            0.20           1.9                 17          2.0
0.22            0.20           1.9                 18          1.9

-------
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-------
             If  this system had  the  means to monitor  the  concentration
             profile  in  the contactor and determine C  directly  it  could
             develop a correlation between  C and Y^, instead of using Table
             0*6.

      0.4.3  Modeling the  Performance of  Full Scale Operations
      More extensive  site  specific  mathematical  modelling  of  the actual
performance  of the  ozone  contactor  may  determine higher  inactivation
levels than  those determined by the  separate  C and T approach.  Therefore,
systems  should  be  allowed  to  use such advanced modelling,  provided that
these models are confirmed by direct measurement of the dissolved ozone
profile  in the contactor.  Only after  the  model is confirmed to correctly
estimate  the concentration profile  in  the  contactor  can it  be  used to
estimate  the inactivation  performance  of the contactor.   Systems with
multiple chamber contactors must develop models  for  each  of the chambers.
      Various types of mathematical  models for reaction-diffusion systems
were reported (Danckwerts,  1976) and some  were  shown to be applicable for
ozone  contactors   (Gurol  and  Singer,  1982). This  section  deliberately
avoids giving preference to any type of mathematical  modelling  in  order to
encourage engineering  innovations.    The  guidelines presented below may
help systems to select appropriate modelling  that will  be consistent with
the requirements of the SWTR.
      The model should  account for the ozone demand  of the water being
treated  in the -contactor.  The rate  of  ozone reaction and decomposition
should be  based on batch  experiments,  on-site  pilot  plant  columns, or
full-scale measurements.
      The model  should represent  the  actual flow distribution in  the ozone
contact  chambers   by  incorporating  a  dispersion  term  and/or  a  three
dimensional  velocity distribution term  in the contactor.
      The modelled profile of the concentration  of dissolved ozone  in the
contactor  should   fit  the   actual  distribution  of  dissolved  ozone,  as
verified by  direct  measurements,  with a variation of  less than  10 to 20
percent.   This difference  between the model  and  measured residual  allows
for the inherent inaccuracies  in measuring the actual ozone residual.  The
mathematically modelled concentration profile should not be used without
comparing it with  actual measurements. Even elaborate mathematical  models

                                  0.4-7

-------
are  not  considered  reliable  enough  to  estimate  the  concentration
distributions  of  dissolved  gasses  in  complex  gas/liquid  operations,
without additional verification of the actual  concentration profile in the
contactor.
      In addition to the above  guidelines,  the model may also account for
other phenomena  that may  affect  the  performance  of the ozone  contact
chambers, such  as:  the  effects of  varying  bubble diameter during  its
movement  through  the.contactor, the  effect  of stagnant regions  in  the
contactor and the variation of the hydrostatic pressure.
      For example,  a system may  use  the  two  film theory  coupled  with
reaction kinetics to estimate the performance of an  ozone contact chamber.
Using the two film theory the relevant differential equations are:
         L dC/dz - Mt + Mr + Md
         G dy/dz - Mt
         L dl/dz - Md - KCI

      Where:
      C   *  Concentration of dissolved ozone (mg/L)
      G   «  Gas  flow rate  per cross  section  of  the  contactor (m2.Kg
            gas/min)
      I   -  Concentration of the target microorganism (Giardia or viruses)
                *••*
      L   «  Water flow rate per cross section area of the reactor (Kg wat-
            er/min.m )
      y   -  Concentration of ozone in  the gas phase (mg/L)
      z   «  Length coordinate of the contactor
      Mt »  An expression for ozone transfer from the  bubble phase to the
            water phase.  For example,  kta(Ci-C) where kta stands  for the
            volumetric  mass  transfer  coefficient,  C,  represents  the
            interfacial concentration  of ozone, given by solubility data
            (Table 0-10).
      Mr *  An expression  for  the rate of  ozone consumption in the water
            due to auto-decomposition and the ozone demand of the  treated
            water.  For  example, Mr-  k,C  -k2(C)(R).  Where   k, and k2 are
            kinetic  coefficients,  and  R represents  the variable ozone
            demand,  such as TOC. An additional equation may be required  to
            represent the  variation  of R along the contactor.
                                  0.4-8

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      Md -  An expression for the dispersion by turbulence and bubble flow
            of dissolved  ozone  in  the specific contactor.  For  example,
            OdzC/dzz the dispersion coefficient (D) may be  evaluated  by
            analysis of tracer study data. The third equation describing
            the microorganism concentration (dl/dz) should incorporate the
            same dispersion coefficient (0).
      KCI-  Chick's inactivation term (K«2.303k, where k » Chick-Watson's
            inactivation coefficient presented in  Table 0-4, C represents
            the local concentration of ozone and I represents the concen-
            tration of microorganisms).

      The  validity of  these equations  is  subject  to the  appropriate
boundary conditions at the bottom and top  of the contactor.  The signs of
the various terms depend on the  definition of coordinates and the type of
flow configuration  (co-current or counter-current flow configuration).

      0.4.4 Microbial Indicator Studies to Model  Inactivation Contactors
      According  to  the  recommendations   in  Appendix  G,  systems  may
demonstrate the  actual  performance  of a  disinfection system rather than
rely on the CT approach. The  procedures outlined  in Appendix G recommend
the use of Giardia muris cysts as indicators  of Giardia inactivation and
bacteriophage (MS2) as  indicators for virus  inactivation by disinfection
in  general.    However,   recent  data  indicate  that  MS2  phages may  be
substantially  more  sensitive  to   ozone   disinfection  than  pathogenic
viruses, and therefore are not a good indicator for determining adequate
ozonation conditions  for  inactivating pathogenic  viruses (Finch, 1990).
Additional  research  is  needed to determine  which coliphage species, if
any, can be  used as an appropriate  indicator for virus inactivation by
ozone.   Pilot scale inactivation experiments  using appropriate  indicator
microorganisms can serve as powerful tools to indicate  the performance of
the ozone  contactors.  This  section contains  guidelines  for conducting
indicator  studies.   At  this time,  full-scale  testing  with  indicator
organisms is not feasible  because of  the  high volume of organisms needed
and  the concern  for  introducing  organisms  into  the  finished  water.
However, with the  development of naturally occurring indicators such as
resistant species of coliphage,  demonstration on the  full-scale  level may
be feasible in the  future.
                                  0.4-9

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       Systems  may  determine  the  performance of their disinfection basins
 by  demonstrating  levels  of  inactivation of indicator microorganisms such
 as  Giartji? muris  cysts,  or other indicator microorganisms provided that
 such  demonstrations  are based  on  solid  engineering  principles.    The
 following  steps can  be used  for  conducting indicator studies:

       1.     Batch  Experiments
       On-site  batch disinfection experiments  are  recommended with treated
 water  spiked with  indicator  microorganisms to determine the inactivation
 kinetics of  the indicator used in the pilot scale experiments.  Microor-
 ganisms  should be used  as indicators preferably  in  the  range where the
 inactivation kinetics approximate Chick's  law.  This protocol  assumes that
 within  the desired  inactivation range,   the  inactivation  kinetics will
 approximate Chick's law.   It is important  to  note that other disinfection
 kinetic  models,  not yet  apparent,  may  be developed  to  more accurately
 predict  ozone  inactivation  efficiency  than the   Chick-Watson  model.
 Evidence that  other models  may  be  more  appropriate  is  shown with data
 generated  by several researchers  for different organisms (Wolfe, R.L. et
 al, 1989;  Finch G., et al 1988;  Finch G.  and  Smith, D.W. 1989).

      2.     Pilot  Scale  Indicator Experiments
      Pilot-scale  experiments  should then be  conducted  using  identical
 strains of biological indicators to those used in the batch experiments.
The pilot-scale experiments  should be repeated  under identical gas and
water  flow conditions with  and  without  introducing  ozone  into the gas
 stream. The actual performance may then be calculated by subtracting the
 inactivation achieved in the control experiment  (without ozone) from the
 inactivation achieved in the ozone disinfection  experiments.

      3.    Evaluation of Inactivation Performances
      Systems  may choose  direct or  indirect methods to  interpret the
 inactivation performance of  ozone contactors  based on indicator studies.
The direct method  is  more  conservative  and simple  while  the indirect
method  is   more  accurate  but  requires   mathematical  modelling  of the
 contactors. The two  procedures are outlined  below:
                                  0.4-10

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       1.     Direct  prediction  of  inactivation performance
             a.    Determine  k<  (where k,  is Chick-Watson's  inactivation
                  coefficient  of  the  indicator microorganism) from batch
                  test  data  with  the  expression:
            where:
                  indicator    ' Survival ratio of  indicator microorganism
             as       .         determined by batch  experiments.
             C                 - Dissolved ozone concentration in the  batch
                               experiment  (mg/L)
             t                 - time  (minutes) elapsed  from the beginning
                               of the batch experiment
             Note: This  assumes that  the inactivation data will  provide  a
                  reasonable  fit  for this  equation.  If this is not  true,
                  then  the following is not applicable and other relation-
                  ships should be developed.
             b.    Determine  the  disinfection  performance of  the  pilot
                  scale disinfection system on the indicator microorganism
                  ( I/Jo' indicator'
             c.    Calculate the  inactivation of Giardia cysts  or viruses
                  (I/I0) using the appropriate k' values from  Table 0-3:
                   log(I/I0) - log(I/I0)indic.tor (k'/k,) I
               ^   log  (I/IO)  «  log  (I/I0)indieitor (k1 < k)    (8)

      This equation still represents an approximation because it  neglects
dispersion  effects.  The  laws  used  in deriving the above  equations  are
based  on  conservative   similarity  approaches.     When  the  indicator
microorganism  is  less resistant  to ozone  disinfection than  the  target
organism  (k,  > k),  then  the plug  flow"deration  represents the  more
conservative prediction  approach.   Equation J is  based on the assumption
that the flow configuration irv the chamber approaches plug flow.  When the
indicator microorganism  is'more vulnerable then the target microorganism
(k, > k)  then  the CSTR  approach  provides a  more  conservative estimate.
Equation 4 represents a conservative approximation to the CSTR similarity
                                  0.4-11

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rule.  A more  accurate  determination  of  the  inactivation  performance  of
the contactor may be calculated by the following approach:


      2.     Indirect determination of the disinfection performance

            a.     Determine k, (where  k.  is  Chick-Watson's  inactivation
                  coefficient of the indicator microorganism) from batch
                  test data with the expression:

            ^9 U/10) indicator ' •*««

            where:

            (I/Io).nd.c«top  •   Survival  ratio  of  indicator micro-organisms
                              as  determined by batch experiments.

            C           -     Dissolved ozone concentration in the batch
                              experiment (mg/L)

            t           -     time (minutes)  elapsed  from the beginning
                              of the batch experiment

            b.     Determine  the  disinfection  performance of  the pilot
                  scale inactivation level of the  indicator microorganism
                  (I/Ifl' indicator1

            c.     Determine  the  actual   concentration profile   in  the
                  disinfection chamber (see  Section 0.3.2).

            d.     Construct  a  mathematical   model   that  estimates  the
                  concentration profile  in the  contactor  as discussed in
                  Section 0.4.3

            e.     Confirm the mathematical model by fitting its  parameters
                  such as dispersion or  kinetic coefficients to describe
                  accurately  the  concentration profile of  ozone in the
                  contactor and the overall Inactivation of  the indicator
                  microorganism.  A  model  that  predicts  within  10-20
                  percent the inactivation of the  indicator microorganism
                  and the concentration profile of dissolved ozone in  the
                  contacyfe#$?*4£ be considered  to  be valid and can be
                  used  bf^ncoffr&GM&M  k   values  from  Table  0-3  to
                  estimate the inactivaJTon of Giardia  cysts or viruses in
                  the contactor.
                                  0.4-12

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Method, A  Submitted Standard Method, Ozone:  Science and Engineering,  pp
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Cams, K, Design of East  Bay Municipal Utility District ozone disinfection
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Chick, H.,  An investigation  of the laws of disinfection,  J.  Hygiene, 8,  92
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Danckwerts, P.V. Gas  Liquid Reactions, McGraw Hill Inc. (1976)

Finch, G.R., Smith, D.W., Stiles,  M.E., Dose  Response of Escherichia Coli
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Finch, G.,  University of Alberta, Canada, Private Communication (1990).

Hoff, J.  C.,  Strengths  and weaknesses of  using  CT values  to evaluate
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Gurol M.D.  and  P.C.  Singer, Kinetics  of  ozone decomposition,  A dynamic
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Joost,  R.D.,  1.A.  Jackson and  L.J.  Bollyky,   Optimization  of  ozone
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        Rosenbeck, G.L, McMahon Associates,  Inc., Private communication (1989)

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        Stolarik,  G.L.  and J.  D.  Christie,  Projection of  ozone  C-T  values,  Los
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