xvEPA
              United States      Water Engineering Research Laboratory
              Environmental Protection  Cincinnati, OH 45268
              Agency
                             EPA/600/9-88/012
                             June 1988
              Research and Development
Proceedings:

Conference on Point-of-Use
Treatment of  Drinking Water
              Cincinnati, OH
              October 6-8, 1987

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                                           EPA/600/9-88/012
                                                June 1988
                Proceedings




  CONFERENCE ON POINT-OF-USE

TREATMENT OF DRINKING WATER

       CINCINNATI, OHIO, OCTOBER 6-8, 1987


                   Co-Sponsored by

             Drinking Water Research Division
          Water Engineering Research Laboratory
           Office of Research and Development
           U.S. Environmental Protection Agency
                 Cincinnati, Ohio 45268

                Office of Drinking Water
           U.S. Environmental Protection Agency
                Washington, D.C. 20460

            American Water Works Association
                6666 W. Quincy Avenue
                Denver, Colorado 80235

                   In Cooperation With:

        Center for Environmental Research Information
           U.S. Environmental Protection Agency
                 Cincinnati, Ohio 45268

      WATER ENGINEERING RESEARCH LABORATORY
        OFFICE OF RESEARCH AND DEVELOPMENT
       U.S. ENVIRONMENTAL PROTECTION AGENCY
                CINCINNATI, OHIO 45268

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                                      Disclaimer

The following papers have been reviewed in accordance with the U.S. Environmental Protection
Agency's peer and administrative review policies and approved for presentation and publication:
•  Point-of-Entry and Point-of-Use Devices  for Meeting  Drinking Water Standards
•  Regulatory  Requirements for Point-of-Use  Systems
•  Microbiological Studies of Granular Activated Carbon Point-of-Use Systems
•  Health  Studies  of Aerobic  Heterotrophic Bacteria Colonizing  Granular  Activated Carbon
   Systems
•  Community Demonstration of POU Systems Removal of Arsenic and Fluoride
•  POU/POE Point-of-View (Discussion  by  F.  Bell)
The remaining papers were not prepared with U.S. EPA financial support and  the contents do
not necessarily reflect the views of the Agency; therefore, no  official endorsement should be
inferred.

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                                       Foreword


The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land,  air, and water systems. Under a mandate  of national environmental laws, the  Agency
strives to formulate and implement actions leading to a compatible balance  between .human
activities and the ability of natural systems to support and nurture life. The Clean Water Act, the
Safe Drinking Water Act, the Resource Conservation and Recovery Act, the Federal Insecticide,
Fungicide and Rodenticide Act, and the Toxic  Substances Control Act are five of the major
congressional laws that  provide the framework for restoring and maintaining the integrity of our
Nation's  water, for preserving and  enhancing the water  we drink,  and for protecting  the
environment  from hazardous  and toxic  substances. These laws direct the  EPA to perform
research to define our environmental problems, measure the impacts, and search for solutions.

The  Water  Engineering Research  Laboratory  is  that component of  EPA's Research  and
Development Program  concerned with  preventing,  treating,  and  managing municipal  and
industrial wastewater  discharges; establishing practices to control  and remove contaminants
from drinking water; preventing deterioration during storage and distribution; and  assessing the
nature and  controllability of  releases of toxic  substances to the  air, water, and land  from
manufacturing processes and subsequent product uses. This publication is  one of the products
of that research and provides a vital communication link between the researcher and the  user
community.

The Conference on Point-of-Use Treatment of Drinking Water was  held because of a national
interest  in the application of point-of-use  (POU)  and point-of-entry   (POE) systems  to
improve drinking water quality. The role of POU/POE Systems has broadened substantially  over
the past 8-10 years from use principally to improve  the taste and odor of  drinking water to
consideration for solving specific contaminant  problems. The purpose of this conference was to
present  information  on  various administrative  and technical  aspects of  utilizing  POU/POE
systems to solve  individual and small community drinking water problems. The conference also
provided a forum for dialogue and interaction between the manufacturers, distributors, regulatory
officials,  and users of  point-of-use treatment technology.  These proceedings document the
information presented to assist, not only those who attended the conference, but also those
who had a vital interest in the conference information but were unable to attend.

                                 Francis T.  Mayo, Director
                          Water Engineering Research Laboratory
                                           in

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                                      Contents
Foreword 	   iii
Preface  	   iv
Abstract 	   v
Acknowledgments	   viii

Overview of Point-of-Use  and  Point-of-Entry  Systems
   Lee T. Rozelle, Olin Corporation	   1

Point-of-Entry  and Point-of-Use  Devices for  Meeting  Drinking Water Standards
   Stephen W. Clark, U.S. Environmental Protection Agency	   4

Regulatory Requirements  for  Point-of-Use  Systems
   Ruth Douglas, U.S. Environmental Protection Agency	   10

Control of Point-of-Use  Water Treatment Devices in Canada:
Legal and Practical Considerations
   Richard S. Tobin, Health and Welfare Canada  	   25

The Regulation of Water Treatment Devices in  California
   Robert F. Burns, California Department of Health Services	   15

Wisconsin Regulation of Point-of-Use  and  Point-of-Entry Water  Treatment Devices
   Loretta Trapp, Wisconsin Dept. of Industry, Labor and Human Relations   	   18

Household Water Quality Education: The Cooperative Extension System Role
   G.  Morgan Powell, Kansas State University  	   22

Federal Trade Commission Regulation of Water Treatment Devices
   Joel Winston, Federal Trade Commission  	   25

POU/POE Product Promotion Guidelines and Code of Ethics
   Maribeth M. Robb, Water Quality Association	   27

NSF's Listing Program for POU/POE DWTUs
   Randy A.  Dougherty, National Sanitation Foundation   	   31

Water Quality Association Voluntary Product Validation Program and
Voluntary Certification Program
   Lucius Cole, Water Quality Association  	   35

Guide Standard and Protocol for Testing Microbiological Water Purifiers
   Stephen A. Schaub, U.S. Army Biomedical Research and Development Laboratory
   Charles P. Gerba, University of Arizona  	   37

Performance and Applications  of Granular Activated Carbon Point-of-Use Systems
   Karl Van Dyke and Roy W. Kuennen, Amway Corporation	   44
Performance and Application of RO Systems
   Donald T. Bray, Desalination Systems, Inc   	   62
                                          VI

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                               Contents (continued)


Performance and Application of Ultraviolet Light Systems
  Clyde Foust, Ideal Horizons, Inc  :	   69

Precoat Carbon Filters as Barriers to Incidental Microbial Contamination
  P. Regunathan, W.H. Beauman, D.J. Jarog, Everpure, Inc   	   71

Microbiological Studies of Granular Activated Carbon  Point-of-Use Systems
  Donald J. Reasoner, U.S. Environmental Protection Agency  	   81

Health Studies of Aerobic Heterotrophic Bacteria Colonizing Granular
Activated Carbon Systems
  Alfred P. Dufour, U.S. Environmental Protection Agency 	   84

Activated Alumina for POU/POE Removal of Fluoride and Arsenic
  Robert L. Lake, Water Treatment Engineers   	   88

Modelling  Point-of-Entry Radon  Removal by GAG
Jerry D. Lowry, University of Maine, Sylvia B. Lowry,  Lowry Engineering, Inc  	   90

Point-of-Entry Activated Carbon Treatment Lake  Carmel -  Putnam  County
  George A. Stasko, NY State Department of Health	   99

Community Demonstration of POU Systems Removal of Arsenic and
Fluoride: San Ysidro, New Mexico
  Karen Rogers, Leedshill-Herkenhoff, Inc   	   106

Florida's Funding for Contamination Correction
  Glenn Dykes, Florida Dept. of Envirommental Regulation	   111

Monitoring and Maintenance Programs for POU/POE   •
  Gorden E. Bellen, Thomas G. Stevens, National Sanitation Foundation	   113

Point-of-Use and  Point-of-Entry Treatment  Devices Used  at Superfund
Sites to Remediate Contaminated Drinking Water
  Sheri L. Bianchin, U.S. Environmental Protection Agency, Region V  	   118

New  Developments  in Point-of-Use/Point-of-Entry Drinking Water  Treatment
  Gary L. Hatch, Ametek, Inc  	   129

POU/POE Point of View
  Frank A. Bell, Jr., U.S. Envirommental Protection Agency  	   136

AWWA Viewpoint  on Home Treatment Units
  Jon DeBoer, American Water Works Association 	   138

POU/POE - Point of View - Association of State Drinking Water Administrators (ADWSA)
  Barker G. Hamill, New Jersey Dept. of Environmental Protection  	   141

POU/POE: An Industry Perspective
  Donna Cirolia, Water Quality Association	   143

Point-of-Use Treatment of Drinking Water: Comments
  Sue Lofgren	   145
                                          VII

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                                 Acknowledgments


Numerous individuals were responsible for the success of this conference. Planning  of the
program was accomplished by Tom Sorg,  Kim Fox, Frank Bell, and James Smith of the U.S.
EPA and Jon DeBoer of the AWWA.

A special thanks is given to Patricia Cooke who arranged for the conference facilities and to all.
the U.S. EPA employees who helped during registration  and  provided other support throughout
the conference.

Sincere appreciation is extended  to Lisa Moore, Carolyn McGill, and  other members  of the
JACA Corporation who were responsible for preregistration and preparation of the Proceedings,
and who also provided help throughout the entire Conference.

Sincere gratitude is  expressed to the Water Quality Association  (WQA) who sponsored and
arranged for the excellent equipment  exhibit.  Through the efforts of Donna Cirolia,  Maribeth
Robb, and Lu Cole of the WQA, and the participating manufacturers,  the equipment exhibit was
considered one of the highlights of the conference.

Last, but, not least,  all the speakers and  moderators  are  acknowledged for their  excellent
presentations and the preparation of their written papers.
                                          VIII

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                OVERVIEW OF POINT-OF-USE AND POINT-OF-ENTRY SYSTEMS
                                           Lee T. Rozelle
                                          Olin Corporation
                                         Cheshire, CT 06410
The  1986 amendments to the Safe Drinking Water
Act require that 83 contaminants must be regulated
within three years of signing the act, that is by June,
1989. EPA has set up a schedule to comply with the
amendments  including the  eight  volatile  organic
chemicals currently finalized.

The greatest regulatory burden will be on the 38,000
community systems serving  less than  500 people.
When  violations  are  incurred,  modification  or
installation of conventional water treatment  systems
may be too costly and these communities may apply
for variances or exemptions. Although  unregulated by
the Safe Drinking  Water Act, the  850,000  rural
systems  with two to  14 connections and an additional
9,000,000 individual rural systems, will certainly  be
affected by this act.

The utilization of proven water treatment technologies
at  the  point-of-use/point-of-entry  (POU/POE)
offers a potentially viable and  cost effective method of
reduction of  chemical contaminants  to  acceptable
levels  in drinking water.  In fact, in situations where
contaminants pose an unreasonable  risk to health, the
option of point-of-use or  bottled water is  being
proposed by  U.S. EPA as a condition for receiving a
variance or exemption. This would be on a temporary
basis  until   compliance  with  the regulations is
achieved. Also there are certain conditions for use
such as certification, bacterial safety, etc.

Point-of-entry is acceptable  to EPA  for  long  term
use  in contaminant removal  from drinking  water
supplies, although  it has   not been  given  Best
Available Technology status. Again  there are certain
conditions for use,  similar to those of point-of-use.

A point-of-use treatment  device  consists  of
equipment applied  to selected taps used for the
purpose of reducing contaminants  in water at  each
tap.

A point-of-entry  treatment  device consists  of
equipment applied   to water entering  a house or
building  for  the purpose of  reducing contaminants
distributed throughout the house or building.
Point-of-use systems  are commonly  placed  in  the
following locations at the sink:
• Counter  top. A counter top device normally fits
  through a connection to the faucet on the sink and
  rests on the counter or in the sink.
• Faucet Mounted.  A  faucet  mounted filter is
  attached directly to the end of the faucet.

• Under Sink Cold Tap. This device fits onto the cold
  water line and treats all the cold water that flows
  through the faucet.
• Under the Sink Line Bypass. This device taps onto
  the cold water line, and after  flowing through the
  lines  to a reservoir (in some cases),  exits through a
  special spigot attached to the sink.

Point-of-entry  systems  are  placed  where  the
household water enters the house (but normally after
the outside outlets).

Common POU/POE technologies and their placement
are shown  in Table 1. Ultraviolet radiation is also an
effective  POU/POE technology for  reduction of
microorganisms. Placement could include  counter top
and under  the  sink as well  as point-of-entry.

Table 1.  Common POU/POE  Technologies  and Their
        Placement
 Technology
Normal Placement
 Paniculate Filters

 Adsorption Filters

 Reverse Osmosis

 Ion Exchange

 Distillation
All POD Placements
POE
All POU Placements
POE
Countertop
Undersink Line Bypass
POE
Potentially All POU Placements
Countertop
Paniculate filters at the point of use normally have 3
to 60 iim (0.0001  to 0.002 in) ratings.  These filters
consist of media  such as spun bonded materials,
foam  (molded  in place),  wound  string,  fabric,
membranes,  and  granular activated carbon  (GAG).
The point-of-use paniculate filters are typically 25.4

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 cm (10 in) in height and 7.6 cm (3 in) in diameter.
 Point-of-entry  paniculate  filters  resemble
 household softeners with media consisting of sand,
 granite, anthracite, etc.
 The most common adsorption filter for contaminant
 reduction in drinking water is  granular  activated
 carbon  (GAC). These  filters reduce common  tastes
 and odors, some turbidity,  residual chlorine,  radon,
 and many organic contaminants with varying degrees
 of  efficiency based  on  molecular structure and
 equipment design.  The most common design is  a
 cartridge  containing a loose carbon bed. This bed-
 type filter could also contain activated alumina  as the
 media for fluoride and arsenic (V)  reduction.  Fused
 carbon  filters and  precoat  filters  also  are utilized.
 Precoat filters usually consist of powdered activated
 carbon  and/or  diatomaceous earth applied  to  the
 influent side of the filter.

 Reverse osmosis (RO) is considered the "high tech"
 method for reduction of dissolved solids. Currently it
 is more applicable at the  point-of-use than  point-
 of-entry.  Typical  RO membranes remove total
 dissolved solids (TDS) with such efficiency that the
 treated  water may  become aggressive and dissolve
 metals  from the water  pipes; blending  may be
 necessary. Also, at the point entry for RO there would
 be a need for a holding tank and a recirculation pump
 resulting in a more expensive treatment system.
 The reverse  osmosis  systems normally consist of a
 particulate filter followed  by an  optional  activated
 carbon  filter  (if a chlorine  sensitive membrane is
 used), an RO module,  a water reservoir containing a
 pressurized  rubber  bladder  (approximately  9.5 I [2-
 1/2 gal]  capacity), a final activated  carbon filter (to
 remove any residual taste and odor), and the special
 spigot on the sink. Household under-the-sink units
 operate efficiently at pressures between 2.8 and 4.9
 kg/cm2  (40 and 70 psi) on nonbrackish raw waters
 with up to 2,000 mg/I  of TDS. The flow rate through
 the spigot is  typically between 0.03  and 0.06 l/s (0.5
 and 1 gpm).

 Cation exchange  has  been used for water softening
 for over 50 years. However ion exchange can apply
 to selective  inorganic contaminant removal  using
 either cation or anion exchange resins.
 Distillation has historically been known to be effective
and has been utilized for producing  contaminant free
 water.

The maintenance  of point-of-use and  point-of-
entry systems is necessary  to   maintain  their
effectiveness for contaminant removal. The following
summarizes  maintenance procedures of  current
point-of-use/ontry  devices  utilizing  proven
technologies:

• Particulate filters. Particulate filters at the  point-
  of-use  are replaced before clogging, when slow
   flow  is  observed. At  the  point-of-entry these
   filters are backwashed periodically.

•  Granular activated  carbon. Granular  activated
   carbon  filters  must  be replaced  before
   breakthrough  df  the contaminants.  Many units
   contain a shutoff  or alarm device to indicate when
   a certain volume  of water has been  filtered. If no
   shutoff device is on the  unit, the  filter either
   periodically  replaced by a  qualified  dealer or,  if
   listed by the National Sanitation  Foundation (NSF)
   Standard 53, a 100  percent safety factor is used
   for replacement based on volume flow. That is, if a
   3,790-1 (1,000-gal) capacity is  claimed,  it must
   be effective for 7,580-1 (2,000-gal) to pass  NSF
   Standard 63.

•  Point-of-use  RO systems require  a  periodic
   replacement  of filters and  the  RO  modules (to
   avoid loss of efficiency due to membrane fouling or
   deterioration).  According to NSF Standard 58, the
   RO module  must  be  replaced  when  the
   conductivity rejection is  below 75 percent or at  a
   value  necessary to  maintain drinking  water
   compliant with the Safe Drinking Water Act. With
   proper maintenance of the prefilters,  the cellulose
   acetate modules  are normally replaced after one
   and a  half to two  years  of  service  and the
   polyamide modules replaced  between two and four
   years of service.  The GAC  and particulate filters
   are normally replaced every six to 12 months.

•  Ion Exchange. Ion exchange  units  are normally
   regenerated with sodium chloride.

•  Distillation.  Distillers must  be  cleaned  due  to
   scaling.

•  Activated  Aluminia.   Activated  aluminia  is
   regenerated  by  sodium hydroxide  and  then
   acidified for adsorption.

The costs of  point-of-use/point-of-entry  units
and their replacement follow:

•  Particulate  filters  typically  cost  between  $20 and
   $100.

•  Granule)' activated carbon  filters typically cost
   between $50  and $300 with  the  lowest
   replacement cost  about $20.  For the  point-of-
   entry the cost range of granular activated carbon
   filters  is $800 to '$1,000,  with $200  to  $400
   replacement costs.

•  Reverse osmosis devices  vary in  price.  The
   counter top devices  range  from $100  to $300.
   Under-the-sink RO devices  containing  cellulose
   acetate membranes range from $300 to  $600 with
   replacement cost at $50  to  $60  for  the CA
   membrane  element.  Under-the-sink  RO devices
   containing thin film composite membranes range
   from $400  to  $800 with replacement cost of the
   membrane element at around $100. .

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• Ion exchange  costs  vary  from $300  to $2,000
  depending on  the  resin (anion exchange resins
  cost more than cation exchange resins) and type of
  equipment.

• Distillation typically costs between $200 and $600.

• Ultraviolet units typically cost between $300 and
  $700.

Reverse osmosis is the best technology for  reduction
of inorganic contaminants considering no energy
input. It may be  indispensable for lead and copper,
which may contaminate water from household pipes.
It should  be remembered,  however,  that reverse
osmosis efficiency depends on the type of membrane
used. Cellulose acetate membranes normally do not
reject some contaminants as effectively as the newer
thin film composite membranes. For example, nitrates
are rejected up  to 65 percent by cellulose acetate
membranes, but  up to  94 percent  by  thin  film
composite  membranes   under  point-of-use
conditions.

Selective reduction of inorganic contaminants can  be
carried out by cation  exchange resins for ions  such
as radium and barium and by anion exchange resins
for nitrates and arsenates.

Activated alumina is effective for reduction of fluoride
and  arsenic.  Granular activated carbon  is  very
effective for reduction  of radon. With proper design
virtually 100 percent  reduction has been  observed.
Disposal and shielding remain  an issue for general
use. Distillation is also effective for inorganic removal.
Granular activated carbon is known to be  the  most
effective and  inexpensive method for removal  of
organic contaminants in drinking water.  It  must  be
remembered, however, that it is not perfect and the
adsorption capacity for various contaminants varies.
Thus,  it  is important  to  know  which  organic
contaminants are present  and their  adsorption
capacities for effective maintenance.

Reverse osmosis is not known for effective  reduction
of volatile organic chemical or  low molecular weight
organic contaminants. Reduction efficiency varies
based on molecular weight, charge, size, shape, and
relationship with the chemistry of the membrane.
There are  indications,  however, that  total organic
carbon is  more  consistently  reduced  (80 to  90
percent) by reverse osmosis when  compared  to
granular activated carbon.
When GAC is used with RO, as in many line bypass
RO systems, organic reductions increase, specifically
for low molecular  weight organics including VOCs.
This combination can result in a very effective point-
of-use device for removal of contaminants.

Several field studies have been carried  out  using
point-of-use/point-of-entry.  In  Suffolk  County,
Long Island 3,000 GAC units have been used for over
four  years  to  treat water with  an average aldicarb
concentration of 87 iig/l. Based on this experience, at
a 100 pg/l influent concentration using 0.028 m3 (1 cu
ft] of GAC, the GAC filter life was calculated  to be
170,325 I (45,000 gal) before breakthrough of 7 ug/l
aldicarb.

In Rockaway Township, New Jersey  12 GAC units
were used to remove concentrations  from  water
above 100 ng/l  of TCE and 1,1,1-trichloroethane.
After  24  months  of  testing,  no  significant
concentrations were observed in the effluent (less
than 1 ug/l [1 ppb]). In Silverdale, Pennsylvania 47
GAC devices  were tested  using five models. With
influent concentrations  of TCE above 100 pg/l (100
ppb), no  significant concentrations were  observed in
the effluent after 14 months of operation.

In Emmington, Illinois  63 reverse osmosis  devices
were tested for  removal of fluoride and  high total
dissolved solids. In this one year test, the fluoride was
reduced by 86 percent  (from raw water concentration
of 4.5 mg/l [4.5  ppm])  and the TDS  reduced 79
percent (from a  raw  water concentration of  2,620
mg/l).

The  actual costs  of  the  point-of-use purchase,
operation,  and   maintenance   in  Rockaway and
Silverdale varied from $5.98  a month jn  Silverdale to
$4.23  a  month  in  Rockaway.  An  estimate  of an
additional  $1.23  per  month was  made  for
administrative  costs if used  in a community of 650
customers.

In Emmington,   Illinois  the  actual point-of-use
reverse osmosis costs  were $12.48 a month.  It was
estimated that if reverse osmosis was used for central
treatment,  the cost to the homeowner  would be
$28.50 a month.
As a comparison,  bottled water used in a family  of 2.8
people at 3.8 I per day (1 gpd) per person at a price
of $0.22  per liter ($0.85  per gal) would  cost $67.00
per month.

The  following conclusions result from the study:

• Use of  proven technologies  at the  point-of-use
   and point-of-entry  is effective  for  reducing
   contaminants from drinking water supplies.

• Reverse osmosis  and  distillation are  most
   universally effective for inorganic reduction.

• Granular activated  carbon  is most universally
   effective for organic contaminant reduction.

• Costs  for small communities appear to be attractive
   particularly  if these devices can be leased  to the
   community avoiding up front costs.

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       Point-of-Entry and Point-of-Use Devices for Meeting Drinking Water Standards
                                        Stephen W. Clark
                             U.S. Environmental Protection Agency
                                     Washington, DC 20460
BACKGROUND

The Safe Drinking Water Act Amendments of 1986
require the Environmental Protection Agency (EPA) to
set standards for 83 contaminants by June of 1989.
These contaminants include inorganic  chemicals,
radionuclides, and organic chemicals. The microbial
contaminants listed by Congress will be regulated by
requiring  filtration as  a treatment technique  for
surface waters,  and disinfection  of all waters. The
chemical contaminants will  be regulated by  setting
maximum contaminant levels (MCLs). MCLs generally
apply at the tap and represent an achievable, safe
level of contaminants in public water supplies.

The public water supplies regulated under the Safe
Drinking  Water Act  include all systems serving  at
least 25 people or 15 service connections. The EPA
has by regulation created  three  subcategories  of
public  water  systems.  Community water  systems
service fifteen or  more connections.  There are
approximately  65,000 community  water systems  in
the  U.S. They range in  size from  very  small
communities  to large cities like  New  York and
Chicago. The other major category is  noncommunity
water systems, which  serve  at  least 25 persons.
There are  over  200,000  noncommunity  water
systems, a category which  includes restaurants,
parks, factories, and other places frequented  by the
public. Nontransient, noncommunity water  systems
such as schools or workplaces serve the same 25 or
more people at least six months of the  year. There
are approximately 20,000 nontransient,  noncommunity
water systems  that  will have to meet  the  same
standards  as  community water systems.  The
remaining noncommunity water systems  will have to
meet standards for microbial contaminants and some
acutely toxic chemicals like nitrate. The reason  for the
difference is that some toxicants  (e.g., fluoride)
require lifetime exposure to increase risk of diseases,
whereas acute  toxicants  can  theoretically  cause
diseases like hepatitis after one drink of contaminated
water. The majority of all kinds of water systems are
small, that is they serve less than 3,300 people or
600 service connections. Compliance is good  among
large, metropolitan  systems, but small systems have
historically lacked the money and the technical skill to
operate complex water treatment plants.

Recognizing the difficulty that small  systems would
have  complying with the many new  drinking water
standards,  EPA considered  allowing  a variety of
decentralized approaches.  These  approaches
included  point-of-entry  devices,  point-of-use
devices, and bottled water.

Public  comment was  first  sought on  these
decentralized approaches in the Federal Register of
November 1985 (1). This notice proposed  MCLs for
eight volatile organic chemicals  as well as criteria for
the use of decentralized approaches in public drinking
water systems.

MAJOR  ISSUES
Although the Federal Register notice sought comment
on  these  along with other issues,  the U.S. EPA
decided to conduct a public hearing on decentralized
approaches in June of 1986. The three major issues
discussed at this meeting were;

• Should  point-of-entry  (POE)  devices treating all
  the water entering buildings connected to a public
  water system be considered  a suitable means of
  compliance?

• Should  point-of-use  (POU) and  bottled water in
  addition to POE be considered suitable means of
  compliance?
• Should POE, POU, or bottled water be considered
  Best Available Technology (BAT) for small systems
  (less than 600 persons)?

Three options were presented at this meeting. They
are discussed below.

Option 1
Consider  POE  to be  an acceptable means of
compliance.

Explanation
Allow  the application of  POE devices to treat all the
water in every  building  for compliance purposes.

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Bottled  water  and  POU could  be considered  as
interim  means  of  reducing  excessive  risks during
emergency situations. However,  POE  would not be
considered BAT under this  option. EPA was leaning
toward this option, at that time.

Discussion
1) From a human exposure  standpoint POE  could be
  considered equivalent to central treatment.

2) POE  treatment methods  are similar to the central
  treatment options that would  be used  for  small
  systems.

3) From  a practical  perspective  there are  some
  differences:

  a) Monitoring would have  to be increased to assure
     that  each device  is  functioning  properly (i.e.,
     producing water meeting the MCL).

  b) Operation  and  maintenance  is  much  more
     difficult than for a central treatment system.
  c) POE is less likely to be suitable for compliance
     with the microbiological standards because:

     •  Microbiological safety  is  assured  by
        maintaining  good  source  waters,  the
        application of  filtration  and  disinfection
        technologies as appropriate (including the
        maintenance of a disinfectant   residual
        throughout  the  distribution system),  and
        maintenance of the integrity of the distribution
        system.

     •  Protection  from  acutely  hazardous
        contaminants  (such  as microbes) is critical,
        and more difficult to assure in a decentralized
        operation (which would  naturally  have  less
        supervisory control).
     •  POE  devices might not  be able  to provide
        protection equivalent  to central treatment
        because of these considerations.

  d) Compliance for  some  contaminants would be
     determined by  multiple in-building samples for
     the POE mode.

  e) There might not be any cost advantage for the
     POE option over for central treatment, especially
     as the  hydraulic capacity  of  the  system
     increases.
  f) Tradition  in  the industry  and some of the
     legislative history of the Safe Drinking Water Act
     suggest  that the  trend toward regionalization
     versus decentralization.
  g) Compatibility of  POE  devices with the central
     treatment technologies currently in   place  or
     required in the future needs  to be considered.
     • Without post-disinfection, GAC adsorption
       POE   devices   would    contribute
       microorganisms to the water supply (as  with
       POU).

     • In  addition, this could result in exposure to
       microbes via inhalation as well as by drinking.

4) Because POE would not be considered to be BAT,
  EPA would  not require its  installation  before  a
  variance could be granted to a water system. If a
  system could install  POU to gain near term benefit,
  it  would be  allowed to do so.  However,  if the
  system desired  a variance, it would have to install
  central  treatment  (BAT)  to  fulfill  the  statutory
  conditions for variances.

5) Concern was expressed that persons  may  still
  consume water  from untreated taps of systems are
  allowed to use  bottled water  or POU devices for
  long-term compliance  purposes.  This  is  one
  reason why EPA was leaning toward  requiring that
  all water provided to the consumer be treated.

Conditions for Choosing Option 1
1) Public  water systems would have to  maintain
  control  and  responsibility  for  the operation  and
  maintenance of the POE devices.

2) A monitoring and  maintenance  program  that
  assures  protection of all consumers  equal to that
  provided by the central treatment option.
3) Effective  technology  must  be properly  applied
  including provisions for microbiological safety.

4) All consumers in every building must be protected
  (i.e., have a device  installed, maintained,  and
  adequately monitored by the responsible party).

5) The POE mode of  compliance  must provide
  protection equivalent to that provided  by central
  water treatment.

Option 2
Allow POE, POU, and bottled water as  acceptable
means of compliance.

Explanation
Allow POU and bottled water in  addition to POE as
suitable  means  of  compliance   under  defined
circumstances  and criteria.  None of these would be
considered BAT under this option.

Discussion
1) Since respiratory and dermal  exposure have been
  identified as  concerns for  volatile chemicals and
  microbiological  contaminants, then all but central
  treatment or POE  would  be ruled  out  for these
  substances.  Under certain circumstances  POE

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   might not be acceptable for biological contaminants
   (see Option 1 discussion).

2) To allow both bottled water and POU:

   a) Bottled water, meeting all standards, should be
     delivered to the consumers in order to be similar
     to POU.

   b) A special monitoring scheme for bottled water
     would need to be developed.

   c) Because POE would  not be considered  to be
     BAT,  EPA would  not require its  installation
     before a variance could be granted to a water
     system. If  a  system could install POU to gain
     near-term benefits,  it would be  allowed  to do
     so. However, if the system desired a variance, it
     would have to install central treatment (BAT) to
     fulfill the statutory conditions for variances.

Conditions for Choosing Option 2
1) The public  water system would  have  to maintain
   control  and  responsibility for the operation and
   maintenance of the POU or quality control over the
   contents and delivery of the bottled water.

2) A special  monitoring  program that  assures
   protection of all consumers  equal to that provided
   by the central treatment would be  required. It could
   consist of application  of the Part 141 monitoring
   requirements.
3) Effective  technology  must  be  properly  applied
   including  provisions  for microbiological  safety -
   bottled water  must meet the microbiological safety
   standards, too.

4) All consumers in every building must be protected
   (i.e., have a POU or bottled  water device installed,
   maintained,  and* adequately monitored  by the
   responsible party).

S) Bottled  water is not  "piped water"  for human
   consumption, thus  arguably excluding these
   systems from the  definition of  a  public  water
   system. To allow bottled water for  drinking  water
   systems EPA would therefore, have to determine
   that  provision  of bottled water, under  certain
   conditions,  is equivalent  to  provision of "piped
   water" by a public water system.

Option 3
Consider POE, POU, and bottled water  to be Best
Available Technology (BAT) for small  systems (less
than 500 persons).

Explanation
On a  compound-by-compound basis,  criteria would
be set by which small systems could be  required to
use POE, POU, or bottled  water in lieu of central
treatment prior to being granted a variance.  That is,
for purposes of receiving variances to specific MCLs,
POE,  POU,  or bottled  water would  have  to  be
installed by small systems.

Discussion/Conditions for Choosing Option 3
1) The  criteria  used to  determine  BAT for
   decentralized treatment would differ from that for
   the  central  treatment  option,  and may  vary by
   contaminant.

2) As  an  example,   consider  criteria for  the
   determination of BAT for fluoride. The POU, POE,
   or bottled water must be:

   a) Commercially  available,  and capable  of
     satisfactorily removing fluoride from  drinking
     water.

   b) Affordable by large  metropolitan public water
     systems.

   c) "Best" based upon the following factors:

     • Wide applicability,

     • High cost efficiency,

     • High degree of compatibility with other water
       treatments in use or needed for the system,
       and

     • The ability to achieve compliance for all water
       in a public water system.

3) Affordability  criteria would be different for large and
   small systems.

4) Central treatment would still be available.

5) The amount of space  required for installation of
   POE could limit the applicability of POE throughout
   a system, and hence, its designation as BAT.

6) The high degree of compatibility criterion would be
   considered  on a  compound-  and technology-
   specific basis.

7) EPA would need  evidence  that  costs  are
   reasonable.
SUMMARY OF EPA DECISION
After considering all public comments and through a
variety of discussions at  all levels of management,
EPA  decided  that  point-of-entry devices were
suitable for compliance, but they were not  BAT. It
was also decided that POU and  bottled water could
be used as interim measures, but were  not to be
considered BAT or a mearis of compliance.

The decentralized approaches cannot be considered
BAT because of difficulties associated with monitoring

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compliance  and  assuring  effective  treatment
performance  in  a manner comparable  to  central
treatment. Most of the public comments received by
EPA  were against considering the  decentralized
approaches BAT. The commenters cited difficulties in
controlling installation, maintenance, operation, repair,
and  potential exposure through  untreated taps.
However,  other  commenters  felt that decentralized
technologies  were BAT for very small systems, as
these methods were often more cost effective for
some small systems than central treatment.

In the final rule,  POE and  POU were not designated
as BAT because: 1) it is more difficult to monitor the
reliability of treatment  performance and to  control
POU  and POE than for central  treatment; 2) these
devices are  generally  not affordable  by large
metropolitan water systems; and 3)  in the case of
POU, not all the water  is treated. In addition, POU
and  bottled water are not considered acceptable
means  of  compliance  with  MCLs.  Neither these
devices nor bottled water treat all the water in the
home and could result in health risks due to exposure
to untreated  water. Consequently,  POU and  bottled
water are  only  considered acceptable  for  use as
interim measures. That is, they may be required by a
state  primacy agent as a condition  of obtaining a
variance or exemption, if necessary  to  avoid an
unreasonable  risk to  health before full compliance
could be  achieved. Under this rule,  however, POE
devices are  acceptable  means of  compliance,
because  POE provides  drinking  water  meeting
standards at all taps in the house. Furthermore, these
devices might be cost effective for small public water
systems  or  nontransient, noncommunity  water
systems. The ultimate goal for the EPA drinking water
program is to have water meeting  all standards
through regionalization, pure source water, or central
water treatment.

FINAL REGULATIONS  ALLOWING POE
FOR COMPLIANCE
Introduction
The EPA promulgated  a final rule  in July 1987 that
allowed POE devices as a means of compliance with
the final MCLs for volatile organic chemicals. POU or
bottled water could  only be used  to  alleviate
unreasonable  risks to  health  during a  variance or
exemption period  - that is, while the public water
systems were attempting to come into full compliance
with the MCL using POE or central treatment. A more
detailed discussion of the criteria for the use of  POE
as a means of compliance follows.

Definitions
The  final rule (Code of  Federal  Regulations,  Part
141.2) defines POU and POE.  These definitions are
worth repeating here for clarity (2):
 "'Point-of-entry  treatment device' is  a treatment
 device applied to drinking water entering a house
 or  building  for  the  purpose  of  reducing
 contaminants  in the  drinking  water distributed
 throughout the house or building."

 "'Point-of-use  treatment device' is  a treatment
 device applied to a single tap used for the purpose
 of reducing contaminants in drinking water at that
 one tap."

Criteria and Procedures
EPA is required to establish conditions for treatment
and  control  of public water  supplies that  assure
protection of public health. Specifically,  EPA's primary
drinking water  regulations are  to  contain criteria and
procedures to assure a supply of drinking water that
dependably complies with MCLs, including  quality
control and testing procedures to insure compliance
with such levels and to insure proper  operation and
maintenance of the  system. It is  under this authority
that EPA promulgated  criteria and procedures
allowing  the use of POE for compliance with the
volatile organic chemical  MCLs.  As was mentioned
earlier,  EPA feels  that  philosophically the  Safe
Drinking  Water Act, including  the legislative  history,
emphasizes  the goal  of providing  pure  water
throughout a centrally controlled facility. Realizing that
this  philosophical  goal is not  always attainable,
especially for small  systems that lack  the necessary
financial  and technical resources, EPA is seeking  to
allow innovation in order to gain increased compliance
among  these systems.  Historically, the  largest
number of violations have occurred  among the very
small systems. It is hoped that this  rule will allow
them a more accessible  means  of compliance, and
would, in turn, increase their  compliance rate.  The
rule specifies  criteria and  procedures  that will
hopefully assure quality  and  safety  when  POE  is
applied for compliance purposes.

The five criteria necessary for compliance using POE
are summarized below.

Central Control
Originally, in the November 13,  1985 rule,  central
ownership and control were required. It would  be the
responsibility of the public water system (PWS)  to
own, operate,  and maintain all  parts  of the treatment
system. This appeared  appropriate and necessary  to
ensure adequate control of the treatment devices  so
that they were working properly.

Public comments noted that while central control and
responsibility  were  necessary,  ownership  of the
devices  was  not.  The  PWS,  while  maintaining
responsibility and control, could  lease the treatment
devices  and also possibly have  them operated and
maintained by  a service company. The  major concern

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 of  EPA was that the property owners would  not
 individually become responsible for these devices.

 The final rule requires the public water system to be
 responsible for operating and maintaining all parts of
 the treatment system  including each  POE device.
 Central ownership is not necessary  so long as the
 public water system maintains control of the operation
 and maintenance of the device. This includes being
 responsible for and supervising any service contractor
 acting on behalf of the public water  system. Central
 control is appropriate  and necessary to ensure that
 the treatment device is always functioning properly.

 Effective Monitoring
 The public  water system must develop an effective
 monitoring  plan  and obtain  state  primacy agent
 approval  before  POE  devices  are  installed  for
 compliance  with drinking  water  standards.  POE
 devices are  fundamentally  different  from central
 treatment in that many more devices are installed at
 different locations. All mechanical devices have some
 theoretical or empirical failure rate. As the numbers of
 devices applied at one public water system increase
 so  does  the probability of  some  devices failing.
 Typically, at  the  central water plant,  the  operator
 makes observations and measurements. This clearly
 becomes more difficult with POE devices since they
 are numerous and are generally  located on private
 property.

 A monitoring program would include some proportion
 of  the devices,  for example,  10 percent. Monitoring
 might rotate throughout the population on a quarterly
 basis.  In some cases, physical inspections  and flow
 measurements  could  be  made  on  the  entire
 population,  with  the  proportionate  sampling being
 done for more expensive chemical analyses.  The cost
 of analyses for volatile  organic chemicals is so high
 and probability  of failure in  a well-designed,  well-
 operated treatment device so low that a small number
 of samples should be adequate. The details of this
 requirement remain to  be determined by the state.
 The state and  the utility should work  together  to
 formulate an adequate, yet affordable program.

 Application of Effective Technology
 Design review  of plans  and  specifications  for
 modifications  or  additions  to water works are
 generally required under state authority.  Almost every
 state  requires reviews and permits for  this kind  of
 activity. EPA recognized this and mandated  a similar
 kind of review. This review should include certification
 that the device  will perform  adequately to protect
 public  health  in the  individual  application
 contemplated. Most  states  are  likely, and  it  is
 certainly appropriate,  to accept  recognized third-
 party certification  of these  devices.  Third-party
 certification  should not preempt a  review to assure
that the application of certified device is appropriate.
There are, then, two responsibilities: 1) certification of
 the device for various contaminant removal situations,
 and 2) review to assure  that the  device is  being
 applied to an appropriate situation.

 Maintenance of Microbial Safety
 The design  and  application of POE  devices  must
 consider the tendency  for increases in  bacterial
 concentrations in water treated with granular activated
 carbon and possibly some  other technologies. At a
 central treatment plant, provisions can be made for
 granular  activated  carbon  adsorbers  to  be
 backwashed and  post-disinfection  is   generally
 practiced.  In  a POE situation, the disinfectant, if
 present, is in the incoming water. GAC is an effective
 media for removal of chlorine from water. It also has
 been shown  to provide  a surface for the  attachment
 and growth of heterotrophic bacteria. Heterotrophic
 bacteria are  not  usually harmful  to  health, but do
 present two concerns. The first is that they may  infect
 people who are sickly and have a low resistance to
 bacterial infection, especially of the respiratory  tract.
 Secondly,  high  concentrations  of  heterotrophic
 bacteria (greater than 500 per ml), can interfere with
 the  examination of the water  for coliform bacteria.
 The state  might  require  additional  monitoring  for
 heterotrophic bacteria to  evaluate  for possible
 interference with the required coliform bacterial  tests.
 If interference is suspected  or  counts are  high
 enough to be of concern  via  respiratory  exposure,
 then the state might require post disinfection.

 Post disinfection after a GAC adsorption  unit would
 require an  ultraviolet device, or a chlorinator with an
 adequate  contact tank.  The contact   tank  and
 chlorinator can be  designed  in  accordance with
 standard procedures used for providing disinfection of
 single  buildings, using  noncommunity water wells.
 Post disinfection would  clearly  increase  the cost  of
 POU treatment and might bias the  economics toward
 central treatment.
 Protection of All Consumers
 Every  building connected  to a public  water system
 must have a POE device installed,  maintained, and
 adequately monitored.  The device  should provide
 treated water to every potable water tap within  each
 building. It is up to the state to determine if some taps
 within  or  outside certain  buildings  may  remain
 untreated. For example, if the state allows nonpotable
 water to be used for car washing, then this portion  of
 the water can be untreated. Other nonpotable  uses
 might  include fawn  watering devices,   aesthetic
fountains, industrial cooling, and  fire protection.  As
previously mentioned there is concern, especially with
volatile  chemicals, for  respiratory  exposure.
Therefore,  the definition of nonpotable water should
 never extend  to living or nonindustrial working spaces
where these kinds of exposure are possible.

SUMMARY
The  goal of these five criteria is to assure that when
POE devices are applied by public water systems for

-------
compliance with drinking water standards, the water is
as safe as the time-tested methods of central water
treatment. These criteria provide for adequate public
health protection, while at the same time allowing for
an innovative, decentralized approach  (i.e.,  POE).
Hopefully, this approach  will  allow a cost effective
means of compliance for smalj systems that have had
the most violations of EPA's drinking water standards.
The  criteria developed by EPA will be  adopted and
implemented by the states with the goal of providing
safe  drinking water to all communities.


REFERENCES
1. National Primary  Drinking  Water  Regulations,
  Volatile Synthetic  Organic  Chemicals,  Final Rule
  and Proposed Rule.  Fed.  Reg. 50:219:46880-
  46933. November 13, 1985.

2. National Primary  Drinking  Water  Regulations,
  Synthetic  Organic  Chemicals,  Monitoring for
  Unregulated Contaminants, Final Rule.  Fed. Reg.
  52:130:25690-25717. July 8, 1987.

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                  REGULATORY REQUIREMENTS FOR POINT-OF-USE SYSTEMS
                                            Ruth Douglas
                                       Registration Division
                             Office of Pesticides and Toxic Substances
                              U.S. Environmental Protection Agency
                                          Washington, DC
There are three general categories of water treatment
units: 1) units not intended to prevent, destroy, repel,
or mitigate any microorganisms or other pests (e.g.,
carbon  or some other coarse filtering  material); 2)
units that consist  of  only  a  physical or mechanical
means  of  preventing, destroying, repelling,  or
mitigating any microorganisms or  pests  (e.g.,
devices);  and 3)  units that  incorporate a chemical
antimicrobial agent  or  units  that consist of  a
combination  of physical  and chemical treatment
intended  to  prevent,  destroy,  or  mitigate
microorganisms or pests (e.g., pesticides).

Products in the first category are subject to neither
registration  nor  regulation under the  Federal
insecticide, Fungicide, and Rodenticide  Act (FIFRA).
Products in the  second category  are only subject to
regulation under FIFRA. Products in the third category
are  subject  to  both  registration  requirements and
regulation under FIFRA.

There  are  approximately  147  registered  water
treatment  products. The first registration was issued
in 1965 by the  U.S.  Department  of Agriculture. The
remaining products were registered by  the  U.S.
Environmental Protection Agency beginning in 1975.

The majority of the  water treatment products  are
registered for use in conjunction with  municipally
treated  or microbiologically potable  water. Five  of
these products are registered for use on untreated or
raw  water (i.e., water of unknown quality or source).
Types of registered water treatment products are as
follows:
• Water filters              118
• Filtering media            13
• Replacement cartridges    11
* Water purifiers             5
Prior to 1979,  data  requirements for bacteriostatic
water filters consisted of bacteriological and chemical
data. These data requirements were published in the
Federal  Register (1) as the Interim Requirements for
Registration of  Bacteriostatic Water Treatment Units
for Home Use.  Since  the  promulgation of  the
conditional registration regulations in  1979, we have
only required  chemical  data  demonstrating that  no
more than 50 yg/l (50 ppb) silver are re/eased  into
the  effluent  water.  This is  because  with  the
promulgation  of the   conditional  registration
regulations, microbiological  data  are  no  longer
required  for pesticide  products with  non-public
health related uses. Bacteriostatic water filters are in
this  category  because   they  can  only  be
recommended for use in  conjunction with municipally
treated water or water that is already microbiologically
potable. The only pesticidal claim allowed for this type
of product is that it "inhibits (slows down) the growth
of bacteria with the filter  medium." Other acceptable
claims  for bacteriostatic water  filters  are  of an
aesthetic nature, such as, "removes chlorine, makes
the water taste better, clarifies the water, and filters
out suspended particles."

On the other hand, water purifiers fall in the category
of pesticide products with public health-related uses
because  they are  recommended for  use  on
raw/untreated water or  water  of  unknown source or
quality.  Therefore,  bacteriological and  chemical  data
are still required  for those products.  The products
currently registered as water purifiers are only for
emergency use. They are not  registered for use on a
continuous basis.

In 1984, EPA formed a  task force for  the specific
purpose of developing definitive guidance and specific
test  parameters  for  demonstrating effectiveness  of
water treatment  units claiming  to microbiologically
purify water under conditions  that simulated actual
use. This  task force, which consisted of 17 people,
was chaired by Dr. Stephen Shaub of  the U.S. Army
Medical Bioengineering R&D Laboratory in Frederick,
Maryland.  The culmination of the efforts of this task
force  resulted in  the Guide Standard and Protocol
dated April 1986 and revised in April 1987.

Our  current requirements for  microbiological water
purifiers consist of  data showing effectiveness of the
                                                 10

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product against bacteria,  viruses, and protozoan
cysts.

In summary, the requirements for  registration  of
bacteriostatic water filters have not  changed  since
1979.  On  the other hand,  we now  have  more
definitive guidance and specific testing parameters for
products claiming  effectiveness as microbiological
water purifiers - the Guide Standard and Protocol for
Testing Microbiological Water Purifiers.


REFERENCE
1. Federal Register, Volume 41, No. 152, August 5,
  1976.
                                                 11

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            CONTROL OFPOINT-OF-USE WATER TREATMENT DEVICES IN CANADA:
                            LEGAL AND PRACTICAL CONSIDERATIONS

                                         Richards. Tobin
                                Environmental Health Directorate
                                   Health and Welfare Canada
                                    Ottawa, Ontario K1A OL2
                                              Canada
Introduction

With a natural resource of about 25 percent of the
world's  fresh water,  Canada  can be  considered a
water-rich country. Over 7.6  percent  of Canada's
surface is covered by water, although it is not always
located  where water demand is highest. With this
tremendous  supply   of  water,  about  2,500
communities are served  by a water distribution
system  covering 87  percent  of the population (1).
Most of the remaining  13 percent of the population
are served by private  wells or other small  private
sources.  It has  been estimated that  there are as
many as  1.38 million private wells in Canada, serving
about 4 million people.

Unfortunately, this seeming  abundance has resulted
in reckless use of water. While  Canadians consume
only 1.3 L of water per person per day (0.3 gpd) (2)
the average  rural household  uses  about  150
L/person/day (40 gpd),  and the average demand for
municipal systems averages about 500 L/person/day
(132 gpd).


Water Jurisdictions
In Canada, the legislative base  is derived from the
Constitution  Act  of  1981  (including  previous
Constitution Acts, referred to in this act). Although the
acts do not specifically address water, the ownership
of natural resources,  including water,  is vested with
the provinces. The provinces, therefore,  have the
right to enact legislation with regard to water and to
have exclusive Jurisdiction over municipal institutions,
local works  and undertakings,  and other  matters
within the province. Under the Department of National
Health  and  Welfare Act,  this  department  has a
responsibility to  investigate  and  conduct  programs
related to public  health. In conducting  this program,
under Section 5 of the act,  the department must
coordinate its efforts with those of the provinces. For
example, although there is no national safe drinking
water act, the Guidelines for Canadian Drinking Water
Quality are  developed  by  a Federal-Provincial
Subcommittee that reports  to  a Federal-Provincial
Advisory  Committee  on  Environmental  and
Occupational  Health (in turn reporting  to  the
Conference of Deputy Ministers of Health). Thus, the
provinces  assume the lead  role in  ensuring a  safe
supply of  drinking  water  whereas  the Federal
government provides  leadership  in  ensuring
guidelines  for drinking water quality.

In some circumstances,  the  Federal government  is
entirely responsible for the provision and quality  of
drinking water. These include administering potable
water regulations  for  all  common  carriers
(transportation crossing Canadian Interprovincial and
International  borders),  and  on Canadian coastal
shipping vessels, and the provision  of potable water
in the Territories, Indian reservations, national parks,
and military bases.

Under  the  Food and Drugs Act,  administered by
Health and Welfare Canada, a  "food" is defined (in
Section 2) as including  "any article  manufactured,
sold  or represented for use as a food  or drink for
man, ..., and any ingredient that may be mixed with
food  for any purpose whatever."  It is an offense
under this  act to sell  a food that contains harmful  or
poisonous  substances,  that  is unfit  for human
consumption, or that has  been  prepared  under
unsanitary  conditions.  The Minister, therefore, has the
authority to prescribe regulations for water, although
this has only been done for bottled and spring waters
(Division 12, Food and Drug  Regulations), due to the
primary role generally  assumed by the provinces.


Point-of-Use  Devices
Point-of-use devices  are becoming  common
household  appliances in Canada, as they are in the
U.S.  Total sales of all types of devices have been
estimated at about 100,000 per year. By means  of a
telephone  survey of  over  16,000  homes  in cities
across Canada, we  learned that the  use of activated
                                                12

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carbon filters alone ranged from about 0.3 percent to
16 percent (3), largely depending upon the perception
of the water quality. Interestingly, the  highest value
was  found in a city with a notorious taste and odor
problem, but with no particular chemical problem.

In Canada, there is no specific legislation controlling
the sale,  use, or  performance  of point-of-use water
treatment devices. A number of  acts, however,.do
have provisions that  could be  related  to  these
devices. Some of these are briefly described below.

The  Pest  Control  Products Act  (1968-69,  c.   50,
S.1),  administered  by Agriculture  Canada, regulates
products that are intended to control any kind of pest.
A pest is "any injurious, noxious,  or troublesome
insect, fungus, bacterial organism, virus, weed, rodent
or other  plant  or  animal pest,  and  includes  any
injurious,  noxious or troublesome organic  function of
a plant or animal" (Section 2 of the act).

An exemption (Regulations, Section  3(a)) to the  act
stipulates that it may not be applied when the product
is a  food. Since "drink"  is defined as a food  in  the
Food and Drugs  Act, an administrative  agreement
between Agriculture Canada and  Health and Welfare
Canada has exempted water treatment chemicals and
devices from consideration under the provisions of
the act (4). The agreement states that for  "chemicals
or devices for water purification," the  Environmental
Health Directorate of' Health and Welfare Canada
should be consulted.  In fact, water  treatment
chemicals are not currently covered by legislation at
the Federal level,  except for emergency  disinfection
chemicals which may be considered as food additives
or  drugs (depending on  claims made)   under
Regulations of the Food and Drugs Act.  Thus,  it is
conceivable that  such  devices  (e.g.,   ozonators,
chemical  feeders) may be covered by the Act when
they are used for nonpotable water (e.g., swimming
pools, spas) but  not for potable water.
The Medical Devices Regulations (established by PC
1976-2031 and revised periodically) of the Food and
Drugs Act  are  used  to control  devices that  are
"manufactured,  sold  or represented  for  use  in  ...
prevention of disease ...." Thus,  depending on  the
exact  claims  made,  devices  may come under  the
provisions of these regulations. If the device claims to
disinfect  water  and  prevent enteric  disease,  for
example,  it could well be  interpreted  to fall  under
these provisions.  The regulations  require  the
manufacturer to notify  the department when a device
is put on the market and to furnish certain information
including a statement of purpose of the device,  and a
copy of instructions. The department may also require
evidence of the safety  and effectiveness of the device
(Regulations,  Section 27(1)).  Thus  far,  these
provisions  have  not  been  used for  point-of-use
devices.
The  Hazardous Products Act (1968-69, c.  42,  S.1),
administered  by Consumer and Corporate  Affairs
Canada (and naming Health and Welfare Canada in
certain sections) authorizes the Minister to  carry out
investigations and  demand  information  regarding
consumer  products,  to determine  whether  such
products are likely to be a danger to the  health or
safety of the public. Where it is considered necessary
to remove  a product from  the  market entirely, it is
included in  Part I of the Schedule to the Act. Where it
is considered  that  specific  regulations can  be
prescribed  to which the products must comply in
order not to present a hazard, then the products are
listed in Part II of the Schedule.

In 1981, it was proposed to prohibit the sale of
activated carbon water filters because of the problem
of bacterial growth on the  filters (5). As a result of
negotiations with industry, an agreement was reached
whereby such filters would be labeled to prevent their
use on microbiologically unsafe waters. Subsequently,
the proposal  to ban these devices was discontinued
(6).

Another piece  of  legislation  administered  by
Consumer  and  Corporate  Affairs  Canada  is the
Competition Act (R.S.,  c.  C-23, S.1; 1986,  C-26,
S.19) which supersedes the Combined Investigation
Act. Parts  of  this  act have  been  used  where
misrepresentation of devices has been alleged.

Section 36(1) states that

  "No person shall ...  (a) make  a representation to
  the public that is false or misleading in  a material
  respect; (b) make a representation to the public in
  the form of a statement, warranty or guarantee of
  the performance, efficacy or  length  of  life  of  a
  product that is  not based  on an  adequate  and
  proper  test thereof, the proof  of which lies upon
  the  person  making the  representation;  ...  the
  general impression  conveyed  by  a representation
  as well as the literal meaning thereof shall be taken
  into account in determining  whether or  not  the
  representation is false or misleading in any material
  respect."

Anyone found guilty of such an offense on conviction
or indictment is subject  to  a fine in the discretion of
the court or to imprisonment for five years, or both.

Since  these provisions  require  the  representations
made for a device to be  true and backed by adequate
and  proper proof, it is clear that these are powerful
tools against misleading advertising  for all types of
devices. The Department  has  worked closely with
officials of  Consumer and  Corporate Affairs Canada
and  lawyers  in the Justice Department by advising
them  on technical  matters and suggesting test
protocols for testing of  devices. In  many cases  we
have been asked to be prepared to  serve  as expert
                                                  13

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witnesses in the event that the case went to court,
which in most cases was not required. Often a guilty
plea  was entered by  the defendants, obviating the
need for a trial.


Nonlegislative Activities
Although these legislative tools are at our disposal for
more serious problems, the departmental policy has
been to avert problems before they occur. Thus, our
program  on  point-of-use  devices  includes  the
following aspects: testing and evaluation of devices;
provision of  advice  and educational  materials;  and
cooperation with industry and nonprofit organizations.

In our  program of testing devices, summarized
elsewhere  (7),  we  have elucidated  a basic  test
protocol  and have applied it on a number of water-
disinfectant  devices, including  ultraviolet  (UV),
filtration,  and  iodine-releasing  devices. Bacterial
growth studies have been conducted on several types
of activated  carbon water  filters:  normal  granular
activated carbon,  silver  containing,  compressed
carbon, precoated carbon,  etc.  Results  from these
studies were qualitatively similar; all types of carbon
filters supported bacterial growth, and these  bacteria
contaminated the finished water.

Evaluation  of devices  is conducted on  an  ongoing
basis at the request of the public, governmental and
nongovernmental agencies, and industry. Normally an
evaluation involves the review of data  and  claims
made for a device and provision of an opinion on the
suitability of  the device  for a given  purpose,  the
validity of claims, adequacy of the test protocols, etc.
Often we  find  that  there  is  not sufficient good
evidence on which an evaluation can be based.

Advice on  the  choice and  use  of devices is often
sought  by  members  of the  public.  Sometimes
individual advice is required,  but often the educational
Tearsheets,  Dispatches,   Information Letters,
Environmental   Health Directorate Reports,  and
scientific articles can be sent to the  person for in-
depth study.

A number of cooperative efforts have been made with
industry associations and nonprofit organizations. For
example, numerous discussions have been held with
the Canadian  Water Quality Association to  discuss
perceived  problems  with  the  advertising  and
promotion of water  treatment devices. They have
published voluntary guidelines for use by the  industry
for the  advertising and promotion  of  carbon  water
filters (8) and all products (9). In another area, we
have  worked closely with the  National Sanitation
Foundation (NSF), who has  assumed a lead  role in
development of performance  standards and  the
testing  and listing  of  devices.  Departmental
representatives  have served  on NSF Working Groups
during preparation of the draft UV standard,  on the
revision  of  the standards on health effects  and
easthetic effects devices, and on the Joint Committee
on water treatment units and on the Council of Public
Health Consultants. It  is  considered  that the NSF
listing  of  devices  provides the consumer with  an
easily identifiable proof of performance for removal of
specific contaminants.  .Ultimately,  compliance with
these voluntary performance standards should make
the  selection  of an  appropriate  device more
straightforward for the consumer.

Conclusion
Although there is  no specific Canadian legislation
respecting point-of-use  water treatment devices,
there are a few pieces of legislation that have  been or
could be used for particular problems. At the  present
time less formal  methods are  generally used  to
provide information on these devices and to ensure
their safety and efficacy in use.

References
1. Anon. National  inventory of municipal waterworks
  and wastewater systems in  Canada  1981. Supply
  and Services Canada, Ottawa, 1981.

2. Environmental  Health  Directorate.  Tapwater
  consumption in  Canada. 82-EHD-80, Health  and
  Welfare Canada, Ottawa, 1981.

3. Tobin, R.S., Junkins, E.A. 'and Eaton, F.E. Survey
  of the  use of  activated carbon  water filters  in
  Canadian  homes. Can  J. Public Health.  76:384-
  387, 1984.

4. Health and Welfare Canada.  Antimicrobial products
  subject to the Pest Control Products Act and Food
  and Drug Act. Information Letter No. 536. Health
  Protection Branch, 1978.

5. Health  and Welfare  Canada.  Point-of-use water
  treatment  devices.  Information  Letter  No.  601.
  Health Protection Branch, 1981.

6. Health  and Welfare Canada.  Activated  carbon
  water  treatment devices.  Information Letter  No.
  635. Health Protection Branch, 1982.

7. Tobin, R.S. Testing  and  evaluating point-of-use
  treatment  devices in  Canada. JAWWA (In press),
  1987.

8. Canadian  Water Quality  Association.  Canadian
  water filter industry voluntary guidelines for carbon
  water  filter  advertising  and promotional  claims.
  CWQA, Waterloo, Canada, 1982.

9. Canadian  Water Quality Association.  Voluntary
  water quality industry product promotion guidelines.
  CWQA, Waterloo, Canada, 1984.
                                                 14

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              THE REGULATION OF WATER TREATMENT DEVICES IN CALIFORNIA
                                          Robert F. Bums
                                      Sacramento, CA 95814
During 1986, the California legislature introduced two
legislative measures regarding  point-of-use (POU)
and  point-of-entry  (POE) water  treatment devices.
One measure,  Senate Bill  SB  2119(1)  by Senator
Torres,  addressed  the  performance  of POU/POE
water treatment devices for which a claim relative to
the health or safety of drinking water is made.  The
other  measure,  SB 2361(2)  by  Senator
McCorquodale, addressed advertising claims made in
the sale of POU/POE  water treatment devices. Both
bills  were passed by  the legislature, signed by the
Governor, and became effective on January 1, 1987.

In general, the two bills were considered to be tough
pieces of legislation. A  frequently asked question is
why the legislature decided to  regulate the water
treatment device  industry. Since the California
legislature does  not  maintain  a  record of  their
committee proceedings,  one can only speculate  why
these bills were passed. What  is known  is that  a
number of events, preceding the introduction of the
bills, had come to the attention of the legislature.

Since the late 1970s,  Californians have realized that
their ground water  sources  of  drinking  water were
potentially vulnerable  to chemical  contamination. In
1978, a large number of wells  in  the  San Joaquin
Valley  were found to  be contaminated  with the
agricultural fumigant, dibromochloropropane (DBCP).
Many of these wells were found to exceed the state's
action level for DBCP of 1 ug/l (1  ppb).

During  1980, wells in  the heavily populated  San
Fernando Valley and San  Gabriel Valley  in  Los
Angeles County, were found to  be  contaminated by
industrial solvents such  as trichloroethane (TCE) and
perchloroethylene  (POE).  These  same  industrial
solvents were also detected  in  wells in the Santa
Clara Valley, which is  often  referred to as Silicon
Valley.

In 1985, the California Department of Health Services
(DHS) sampled over 3,000 wells  used by large public
water  systems  (over  200 connections) for  organic
chemical contaminants (3). A significant number (18.3
percent)  of  the wells sampled had measurable
concentrations  of  one  or more organic chemicals.
One hundred  and sixty  five  of  these wells (5.6
percent) had concentrations of chemicals that exceed
the State  Maximum Contaminant Level (MCL) or a
State Action  Level (4).  When contamination  levels
were found to exceed an MCL or State Action  Level,
public notification was initiated by means of a  public
news release.

During 1985 and 1986, the newspapers and television
stations, particularly in  Southern California, frequently
reported on drinking water contamination problems.
The public was alarmed by these news stories and
became very concerned  about the quality- of their
drinking water.

As  a result of the increased public concerns  about
drinking water quality,  the bottled water  industry
recorded a significant increase  in sales in 1985 and
1986. The water treatment device industry appears to
have experienced a similar increase in sales  during
the same period. Unfortunately, there were a number
of cases of consumer abuse and fraud as a result of
the overly  aggressive mart^ting efforts by  a few
companies selling water treatment devices.

The  introduction of  SB  2361  by  Senator
McCorquodale has not  been tied to any  specific
consumer problems.   However,  the  Senator
represents the Santa Clara Valley and his office had
been contacted by constituents about the marketing
techniques used by the water  treatment industry in
that area.

SB 2361  enacted  a statute which  provides  "truth-
in-advertising"  as it  relates  to  water treatment
devices. The statute addresses false or misleading
advertising with key provisions which make it unlawful
to:

•  Make false claims or statements about the  quality
   of water provided by a public water system.
•  Make false  claims  about the  health  benefits
   provided by the use of a POU/POE water treatment
   device.

•  Make any product performance claims unless such
   claims are based on actual, existing factual data.
                                                 15

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• Make any other attempts to mislead the consumer
   or misrepresent the product.

This  statute  is  expected to  deter  unscrupulous
salespersons and reduce the number of complaints
relative to fraudulent sales. The statute will also assist
the consumers who are victims of fraudulent sales by
providing them  with  a  means  to  file  a criminal
misdemeanor action  and recover damages. The
statute does not assign enforcement responsibility to
any specific agency. It is expected that local  district
attorneys  and the State Attorney General will take
legal  action against companies acting in  violation of
this new law.

The introduction  of SB 2119 by Senator Torres is
often described as a response to a consumer  abuse
problem in McFarland, California. A water treatment
device company was reported to have advertised and
convinced customers in  McFarland that  their  water
treatment device could  remove  all cancer-causing
chemicals. This  marketing effort occurred at  a time
when this community  was very concerned about a
cluster  of childhood cancer  cases that were  being
investigated by state and local health agencies. The
company was successfully prosecuted  by the State
Attorney General and the settlement allowed  the
consumers to rescind their sales contracts.

SB 2119 enacted a statute which requires that any
water treatment device for  which a health benefit
claim is made, cannot be sold in  California unless the
device  had performance testing that  has  been
certified by the Department of Health Services (DHS).
This law further  requires  DHS to adopt regulations
setting forth  the  criteria  and  procedures  for
certification of  water treatment devices. These
regulations must include appropriate testing protocols
and  procedures to determine the performance  of
these devices. The cost of this new program is to  be
paid for through fees imposed on the applicants. The
law also assigned responsibility for enforcement to
DHS or local health departments.

This statute outlines  a very specific Plan for  the
regulation  of  POU/POE  water treatment devices
(WTDs). The general provisions of this statute include
the following:

•  The DHS is required to adopt regulations which set
   forth the criteria and  procedures for the certification
   of WTDs  that are claimed to affect the health and
   safety of drinking water.

•  A "water treatment  device" (WTD) is defined  to
   mean  any point-of-use  or point-of-entry
   instrument or contrivance sold or offered for  rental
   or lease for residential, commercial, or  institutional
   use, without being connected to the plumbing of a
   water supply intended  for  human consumption in
   order to improve  the water supply by any means,
   including, but not limited to, filtration, distillation,
   adsorption,  ion  exchange,  reverse  osmosis, or
   other treatment.

•  No WTD which makes product performance claims
   or  product benefit claims that the device affects
   health or the safety of drinking water, shall be sold
   or  otherwise distributed  unless the  device has
   been certified.

•  WTDs which are not  offered for sale or distribution
   based  on   claims   of  improvement  in  the
   healthfulness of drinking  water  need  not be
   certified.

•  A WTD initially installed prior to the operative date
   of the statute is not required to be certified.

•  The requirement that a WTD be  certified does not
   become operative until one year  after the effective
   date of the regulations.

•  The DHS or any testing organization designated by
   the DHS may agree to evaluate test data in a WTD
   offered  by  the  manufacturer, in  lieu  of the
   requirements of the   statute, if  the  DHS or the
   testing  organization  determines  that  the testing
   procedures  and standards used to  develop the
   data are adequate to  meet the requirements of the
   statute.
•  The DHS may accept a  WTD certification issued
   by  an agency of another  state, by an independent
   testing organization, or by the Federal government
   in lieu  of its own  if the  DHS  determines  that
   certification program meets the requirements of the
   statute.

The provisions  that are to  be included  in the DHS
regulations were  defined  in  the  statute   with
considerable detail. The provisions  that are required
or allowed as part of the regulations  are as follows:

•  The regulations  shall include  appropriate testing
   protocols and  procedures to determine  the
   performances  of WTDs  in  reducing  specific
   contaminants from public or private water supplies.

•  The regulations may adopt,  by reference, the
   testing procedures and standards of  one or more
   independent testing  organizations  if the  DHS
   determines that  they are adequate  to  meet the
   requirements of the statute.

•  The  regulations may   specify  any  testing
   organization  that  the DHS has designated to
   conduct the testing of WTDs.

•  The regulations are required to  include minimum
   standards for (a) performance  requirements, (b)
   types of  tests to be performed,  (c)  types of
   allowable material, and (d) design and  construction.
                                                 16

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• The  regulations  are  required  to  include
  requirements relative to product instructions and
  information,  including  product  operation,
  maintenance, replacement, and the estimated cost
  of these items.

• The  regulations  may  include any  additional
  requirements, not  inconsistent with the statute,  as
  may be necessary to carry out the intent of the
  statute.

Finally,  the  statute specifies  procedures  for  the
enforcement  of the act. Key enforcement provisions
include the following:

• The DHS,  or  any local health  officer  with  the
  concurrence of the DHS, is  responsible for the
  enforcement of the act.

• The  DHS  may  suspend, revoke,  or deny  a
  certificate upon its determination that either (a) the
  WTD does not perform in accordance with the
  claims  for  which certification is based,  or (b) the
  manufacturer, or any employee or agent thereof,
  has violated the statute.

• The act provides that any person, corporation, firm,
  partnership,  joint  stock company, or any  other
  association that violates any provision of the act, is
  liable for a civil penalty not to exceed $5,000  for
  each violation.

The DHS Public  Water Supply Branch (PWSB) has
been given the responsibility for the implementation of
SB  2119 and is  currently  developing  policy and
regulations for the implementation of the certification
program.  The  PWSB  has established  an informal
advisory committee consisting of representatives  for
industry, water utilities, and  consumers to assist in
identifying and addressing issues. The following  are
some of the elements of the program and regulations
that are being considered:

• The  DHS  plans to adopt existing protocols  and
  standards   such  as  those established  by  the
  National Sanitation Foundation (NSF).

• A "health  or safety claim"  will be defined in terms
  of the  Primary Drinking Water Standards  adopted
  by the  DHS or the U.S. Environmental Protection
  Agency.

• Certification  of a  WTD  will be  based  on specific
  contaminants for which the manufacture has made
  a health or safety claim.

• The  DHS  will  not establish a state laboratory  to
  conduct the testing required for certification. The
   DHS plans to contract  with outside laboratories or
  testing  organizations  for  the testing  and  other
  administrative tasks relative to certification.

• The  DHS  may choose  not  to  accept  any
  manufacturer's data  relative  to  the performance
  testing that will be required for state certification.

The water  treatment  device  industry  is  very
concerned as to how the WTD certification program
will  impact the marketing and sales of their product in
California. The advisory committee has  been very
helpful in bringing the  industries concerns to  the
attention of the  PWSB.  Some of the concerns that
have been identified are as follows:

• The failure  to accept manufacturer's data would
  impose a substantial cost on the industry.

• If retesting  by a third-party laboratory or testing
  organization is  required, the  manufacturers  will
  have to pass  on the  added expense  to  the
  consumers.

• The cost  of  testing under NSF  or  equivalent
  standards will be very  expensive.

• The one year grace period in which all testing must
  be completed may exceed the capacity of  State
  contract laboratory or laboratories  designated to
  conduct WTD  performance testing.

• In order to  reduce  the  costs  associated  with
  performance testing, consideration must be  given
  to  testing  approaches  such  as  the use  of
  surrogates and the extrapolation of data whenever
  possible.

It is evident that the California  legislature has  given
the  DHS a  difficult assignment.  However,  the
Department  is committed to the establishment of  a
WTD certification program that will serve the needs of
the California  consumers and  still  be responsive to
some of the unique problems of the water treatment
device industry.  The DHS is  also confident that the
California program will  not be in  conflict with  any
efforts to establish  a national certification program.


REFERENCES
1. SB 2119 (Chapter  1247, Statutes of 1986).

2. SB 2361 (Chapter  1278, Statutes of 1986).

3. Organic Chemical  Contamination  Of Large Water
  Systems  In California.  California  Department of
  Health Services, April  1986, page ii.

4. Drinking   Water  Action  Levels  set  by  the
  Department of Health  Services.
                                                  17

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             WISCONSIN REGULATION OFPOINT-OF-USE AND POINT-OF-ENTRY
                                 WATER TREATMENT DEVICES
                                         Loretta Trapp
                     Department of Industry, Labor and Human Relations
                                       State of Wisconsin
                                       Madison, Wl 53707
Wisconsin's  involvement  in regulating point-of-use
and point-of-entry water treatment devices involves
five different state agencies. Two of those  state
agencies,  the Department of Justice (DOJ) and the
Department  of  Agriculture, Trade and  Consumer
Protection (DATCP),  have  consumer  protection
sections. Water treatment device manufacturers and
dealers only become involved with DOJ and DATCP if
their advertising literature or sales practices appear to
bo false or misleading.

A third state agency, the Department  of  Health and
Social  Services (DH&SS),  is  responsible for
recommending  enforcement  standards  for  ground
water contaminants  of public health  concern.  The
enforcement standard  may be the actual maximum
contaminant  level (MCL)  set by the  United States
Environmental Protection  Agency or  may be below
the MCL if scientific evidence for the lower number is
presently available but was not considered when the
MCL was  established.  When an MCL has not  been
set for a  contaminant  of  public  health concern, the
enforcement standard  will establish the  upper  limit
concentration for the contaminant in ground water.

Water treatment device manufacturers and  dealers
rarely become involved with any DH&SS activities.
However,  the  Department  of Natural  Resources
(DNR), the fourth state agency, uses the enforcement
standards  to establish whether or not a water supply
is contaminated. After  a public hearing process, the
DNR usually adopts the recommended enforcement
standard  into  its regulations.  If a  water  supply
contains a contaminant of public health  concern in
excess of  an enforcement standard, the water supply
is  deemed  contaminated.  The DNR  develops
regulations for methods to be pursued in obtaining
pure  or noncontaminated drinking water  for human
consumption.

If a water supply contains  a contaminant in excess of
an enforcement standard, the  DNR requires the
owner of that water supply  to first seek  a naturally
safe water supply which can involve:
• Extending a well casing;
• Drilling a new well; or
• Connecting to a  public water  supply  or other
  noncontaminated well.

The DNR requires all water for human consumption
to be noncontaminated. [Department of  Industry,
Labor and Human  Relations (DILHR) regulations
essentially require all water going to plumbing fixtures
to be  noncontaminated.]  Point-of-use or point-
of-entry water treatment devices  used to reduce the
concentration of contaminants below the enforcement
standard  may only be installed upon approval of the
DNR.  The DNR  also  has  the authority to  require
sampling  and maintenance for these water treatment
devices.   Point-of-use devices  are  usually  not
designed  to produce the volume or  flow  rate of
noncontaminated  water needed and so at  this time
are not  allowed for use  on contaminated water
supplies.  The  DNR also  considers  point-of-entry
water treatment devices at this time to be the  last
resort or  at best  an  interim solution until a  naturally
safe water supply can be obtained.

Water treatment  device manufacturers and  dealers
may become involved  with DNR  regulations if they
want their devices to  be  used to  reduce  the
concentration   of  a  contaminant  below  the
enforcement standard.

The fifth state agency is the Department of  Industry,
Labor and Human Relations (DILHR), which  reviews
all  point-of-use  and  point-of-entry  water
treatment devices for the following:

• Rendering  inactive  or removing  aesthetic  and
  health related contaminants;

• Suitability of construction materials  for  use with
  potable water;
« Ability of the device  to withstand the pressures to
  which it will be  subjected; and

• Proper installation instructions.
                                                18

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The  information that  DILHR  requires for review  is
contained in Appendix A.

Presently DILHR has adopted  into regulation only one
nationally  recognized  standard,  the Water Quality
Association  Standard  S-100.  DILHR has proposed
additional regulations,  a copy of which is contained in
Appendix B.

In conclusion, water treatment device manufacturers
and  dealers  will  most often  become involved  with
DILHR regulations, and to  a lesser  extent DNR
regulations.  Appendix C contains  a list  of contact
people for each of the five state agencies.
Appendix A

APPLICATION FOR PLUMBING PRODUCT
REVIEW - REQUIRED INFORMATION FOR
WATER TREATMENT DEVICES
                                                \

A letter,  requesting approval, must  be submitted by
the device manufacturer  or  distributor. Each letter
may contain  only  one product review request. The
following information  shall be submitted with each
request for product review:

1.  Product trade name and model number.

2.  Manufacturer's name, address  and telephone
    number.

3.  Product engineer's name, address and telephone
    number.

4.  Two  copies of sales brochure, catalog and other
    promotional literature.

5.  Written detailed  description  of  the  composition
    and function of device.

6.  Detailed assembly drawings.

7.  Information regarding marking of  device:

    a.  Method of marking.

    b.  List of marking information on  device.

    c.  Location of markings on device.

8.  Complete  installation  instructions,  including
    detailed  installation  drawings  indicating all
    connections between  the device and  plumbing
    system.

9.  A  list and copy of all national standards to which
    the device, or the device's construction materials,
    conforms.
10. A list  of  material specifications if  other  than
   construction  materials  in  referenced  national
   standards.  Documentation shall also be  provided
   indicating  that  the  construction  material is
   accepted  for use with  potable water,  by the
   National  Sanitation  Foundation (NSF) or other
   national agency.

11. The trade  name, scientific name and chemical
   formula of  any chemical used in the device that
   may be  added  or  leached  into the  water.  A
   toxicity rating and the source of the toxicity rating
   must also  be provided. Documentation  shall be
   included showing  that  these  chemicals  are
   accepted for  use with potable water, by  the U.S.
   Environmental Protection Agency (EPA),  U.S.
   Food and  Drug Administration (FDA),  National
   Sanitation  Foundation (NSF)  or  other  national
   agency.

12. A signed report, by an approved testing laboratory
   or  the manufacturer, which concludes  that the
   device functions and performs in accordance with
   assertions  submitted to the  department.  This
   report must  include but is not  limited to the
   following:

   a. A detailed  explanation of the test method(s).

   b. The influent temperature, pH,  hardness,  total
      dissolved  solids and  concentration of
      contaminants.

   c. The effluent temperature,  pH,  hardness,  total
      dissolved  solids and  concentration of
      contaminants.

   d. The minimum detection concentration of the
      contaminants that may be achieved by the test
      method.

   e. Test results of at least one duplicate sample.

   f. Test results of a reagent blank.

   g. Test results of a spiked sample.

   h. The percentage of influent disposed as waste.

   i. An estimate of the error in the test results.

   j. A sample calculation.

   k. Test  results  proving  conformance to
      referenced national standards

   I. Test results indicating the burst pressure.

   m.Test  results indicating the working water
      pressure and temperature range.
                                                  19

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    n. The name, address and telephone  number of
      the laboratory.

    o. The name of the individual(s)  performing the
      test(s).

13. Disposal  requirements  of  any  wastewater,
    backwash  fluid,  filter,  membranes or  other
    replaceable device components.

14. A graph  indicating the pressure  loss, in psig,
    through the device, over  the  entire flow rate
    range, in U.S. gallons per minute.

15. An  operation  and maintenance  manual  or
    instructions,  including  but not limited  to  the
    following:

    a. Maintenance cycle under given influent
      conditions.

    b. Maintenance procedures.

    c. Operating pH range.

    d. Operating pressure range.

    e. Operating temperature range.

    f. Operating flow rate range.

    g. Operating total dissolved solids range.

    h. Any influent conditions that will adversely affect
      the stated performance of this device.

Appendix B

PROPOSED DRAFT REGULATIONS

Section ILHR 82.11 (181)  "Water treatment device"
means a device which:

   Renders inactive or removes microbiological,
   particulate,  inorganic, organic or radioactive
   contaminants from water which  passes  through
   the  device  or  the water supply  system
   downstream of the device.

Section ILHR 84.20 (6) (o) Water treatment devices.

1.  Water softeners shall conform to WQA S-100.

2a. Except as provided in subpar. b., water treatment
    devices shall function and  perform in accordance
    with the assertions submitted to the department
    under s. ILHR 84.10, relating to rendering inactive
    or removing contaminants.

2b. A water treatment device  which injects a water
    treatment compound into a water  supply system
    shall maintain the compound concentration in the
    system over the working flow rate  range  and
    pressure range of the device.

3.  Except as specified in  subd. 4., water treatment
    compounds introduced into  the  water supply
    system by a water treatment device shall be listed
    as an  acceptable drinking water  additive  by a
    listing  agency  approved  by  the department.
    Listing  agencies  approved by the  department
    shall include:

    a. United  States  Environmental   Protection
      Agency;

    b. United  States  Food  and Drug  Administration;
      and

    c. National Sanitation Foundation.

4.  A water supply system shall  be protected from
    backflow  when  unlisted  water   treatment
    compounds, which may affect the potability of the
    water,  are  introduced  into the  system.  The
    department shall  determine  the  method of
    backflow protection. Water  supply  outlets  for
    human  use or consumption may not be installed
    downstream of the introduction of  an unlisted
    water treatment compound.

6.  Water  treatment  devices  designed   for
    contaminated water supplies shall  be labeled to
    identify the following information:

    a. The name of the manufacturer of the device;

    b. The device's trade name; and

    c. The device's model number.

Appendix C

PEOPLE TO CONTACT

Department of Agriculture,  Trade  &  Consumer
Protection
Trade & Consumer Protection Division
Consumer Protection Bureau
801 W. Badger Road
Madison, WI53713
Jane Jansen, Director
(608) 266-8512

Department of Health & Social Services
Health Division
Community Health & Prevention Bureau
Section of Environmental  and  Chronic  Disease
Epidemiology
1 West Wilson, Rm. 318
P.O. Box 309
Madison, Wl 53701-0309
                                                20

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Henry Anderson, M.D., Section Chief
(608) 266-1253

Department of Industry, Labor and Human Relations
Safety and Buildings Division
Office of Division Codes and Applications
201 E. Washington Avenue
P.O. Box 7969
Madison, Wl 53707
Loretta Trapp, Plumbing Product Review
(608) 266-2990

Department of Justice
Legal Services Division
Consumer Protection Bureau
123 W. Washington Avenue
Madison, Wl 53703
Kevin O'Conner, Assistant Attorney General
(608) 266-2426

Department of Natural Resources
Environmental Standards Division
Water Supply Bureau
Private Water Supply Section
101 S.Webster
P.O. Box 7921
Madison, Wl 53707
William Rock, Section Chief
(608) 267-7649
                                                21

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                          HOUSEHOLD WATER QUALITY EDUCATION:
                         THE COOPERATIVE EXTENSION SYSTEM ROLE

                                        G. Morgan Powell
                                 Cooperative Extension Service
                                     Kansas State University
                                      Manhattan, KS 66506
Water quality is one of the national priority initiatives
for the Cooperative Extension Service System. This
paper addresses  household  water quality education
through the Kansas Cooperative  Extension Service. It
focuses on  education  relating to  one portion  of a
broader statewide water quality subject. To help you
understand  why  Kansas  household  water  quality
programs  may not be transferred  directly to other
states, I will begin with a discussion of the extension
system  organization using some specific examples
from Kansas.

THE  COOPERATIVE   EXTENSION
ORGANIZATION
The extension system  in this country consists of the
50 state  Cooperative Extension  Services  and
Extension  Service of the  U.S.  Department of
Agriculture   (USDA).  The  1862 land-grant
universities,  the 1890  land-grant  universities, and
Tuskegee  Institute operate  the  state  Extension
Services. These total 67 State Cooperative Extension
Service organizations. These extensions are generally
funded jointly  by  Federal,  state, and local sources,
which explains the name Cooperative  Extension
Service (two  states  use the  term  "Agricultural
Extension Service").

Federal  funds come through the Extension Service
USDA, while state funds come through the respective
university systems. Typically,  Federal and  state funds
support  the state and area  offices consisting of
directors, administrators, subject matter  specialists,
technicians, and support staff. State  and  local  funds
support  county offices,  which consist  of county
agents,  paraprofessionals,  and  support staff.  Local
funds come from local governments, usually counties,
but sometimes including cities/counties.

The Cooperative  Extension  Service  is the informal,
noncredit education arm of the land grant universities.
Much of this education occurs  at the county level.
Subject  matter specialists  at  state and area levels
provide  support   to  county  extension  agents,
paraprofessionals,  and  volunteer  teachers  and
leaders. Because education  programs cover broad
areas including agriculture,  home  economics, 4-H,
horticulture, and community development, the support
must also  be  broad  based.  The  Cooperative
Extension  Service includes  a very broad range of
disciplines to support county education  programs.
Table 1  shows the number of full time specialists by
program area and discipline for Kansas.
Table 1.  Extension Subject Matter Specialists in Kansas

Agriculture
Agriculture Economics
Agriculture Engineering
Agronomy
Animal Science
Entomology
Grain Science
Horticulture
Plant Pathology
Veterinary Medicine
Sub Total
Forestry
Home Economics
Community Development
Energy
4-H and Youth
Information (writers,
editors, radio, TV, etc.)
Sub Total
Total
Discipline
Specialists

20
8
13
16
10
3
5
5
2

12
20
9
6
13
21



Program Area
Specialists










82
12
20
9
6
13
21

81
163
COUNTY EXTENSION PROGRAM
The county extension education effort helps people:

• Understand, evaluate, and solve problems;

• Learn through informal,  out-of-school  education
  opportunities; and

• Work together to develop personally and develop
  leadership skills.
                                                22

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To  achieve these  goals, county programs include a
wide variety of efforts to reach their clientele. These
efforts include public  meetings, workshops,  short
courses,  symposia,  tours,  and  demonstrations.
Extension programs also reach the  public  through
radio, television, newspapers, and newsletters.

Extension also  works closely  with clubs  and
organizations such  as  4-H clubs,  Extension
Homemaker  Units,  conservation tillage  clubs,
agricultural commodity clubs,  and marketing  clubs in
Kansas.  However,  extension also  has  a  history  of
working  closely  with the   Farm  Bureau,  soil
conservation  districts, drainage  districts,  land
improvement contractors, rural  water  districts, and
many other similar groups.

In Kansas, more  than  300 county agents  conduct
county extension  programs (Table 2).  Kansas also
has thousands of volunteer teachers and leaders who
add immeasurably to the extension program. A recent
survey showed nearly  38,000 part-time volunteers
serving   in  extension sponsored  and  related
organizations, equa) to 1.5 percent of the population.

Table 2.   County Professional Staff in Kansas
Agricultural Agents
4-H/Youth Agents
Home Economic Agents
Horticulture Agents
Total Agents
Paraprofessionals
113
37
127
12
289
21
 Total County Staff
310
               because they are man-made and the result of fairly
               recent activity. This suggests that the presence and
               concentration of organics in private  as well as public
               water.supply wells may be  increasing and will likely
               be of more concern in the future.

               Table 3.   Inorganic Contaminants in Farmstead  Wells  -
                        Parameters Abvove  Maximum  Contaminant Level
                        (MCL)
                                         Percent       Confidence"
                Nitrate
                Selenium
                Fluoride
                Lead

                Total Inorganic
28
 9
 2
 2~
             37 + 9
                  *  95 percent confidence level.
                  **  Lead was found to be a result of plumbing in the well water.
               Table 4.  Organic Contaminants in Farmstead Wells

                                         Percent       Confidence*
Atrazine
2,4-D
2,4,5-T
Tordon
Chlordane
Heptachlor Epoxide
Alaohor
Wells with Pesticides?*
1 ,2-Dichloroethane
Benzene
4
1
• 1
1
1
1
1
8 ±6
1
1
                                                      Wells with VOC
                                                                                              ±3
                                                          95 percent confidence level.
                                                          Two pesticides were found in each of two wells.
KANSAS WATER QUALITY SITUATION
Kansas  has  relatively few  serious water  quality
problems. However, it does have conditions that are
cause for concern  and that need careful monitoring.
Central water systems  roughly serve 80 percent  of
Kansas residents.  Over half of this  supply  is from
ground water. For two years, the Kansas Department
of Health and Environment has checked public supply
wells for volatile organics and pesticides that are
mandated  by new  regulations  of  the  Safe Drinking
Water Act to be implemented from 1987 to 1991. The
state has shut down 52 (2.9 percent) of 1,800 wells
checked because of contamination.

The Kansas Department of Health and  Environment,
in cooperation with  Kansas State University, randomly
surveyed 104 private farmstead wells. They found
nitrates in  28 percent of the wells, selenium in  nine
percent,  and fluoride  in two  percent, where the
inorganic contaminants  exceeded the MCL  (Table 3).
They found pesticides and volatile organic  chemicals
(VOCs) respectively in  eight and two percent of the
wells  (Table 4).  These organics  are worrisome
                According  to  the  1980  census,  Kansas  has about
                125,000 private water supplies,  almost  all wells.
                Based on 3.9 persons per well, the numbers served
                by private wells in the survey, roughly 500,000 people
                (about 20 percent of the state's  population) depend
                on private water supplies. No  regulations  or testing
                requirements  apply to these private water  systems.
                Users or owners are  responsible for  the  quality  of
                these supplies. They are  the operators  and the
                sanitarians. An optimistic estimate is that owners test
                only a few of these wells  each year.

                Another concern in  Kansas  is the large  number  of
                abandoned wells that  remained unplugged.  The
                Kansas  Department of  Health  and  Environment
                estimated that the  state has  250,000 abandoned
                wells. We believe  Kansas  could  have  500,000  or
                more abandoned wells.

                At Kansas State University,  we have determined that
                a coordinated extension  program  is essential  to
                address the  problems  related to  private water
                supplies and  agriculture's impact on  water quality,
                                                  23

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especially  that  of ground water.  The Kansas
Department  of Health and Environment is  also
concerned  about,  and  supports, this  extension
education effort.


WATER QUALITY TASK FORCE
The Kansas Cooperative Extension Service initiated a
five-member Water  Quality Task Force in 1985. This
task force began as a component of the agricultural
programs portion of extension.  The goals were  to
address the impact of agriculture on water quality and
to initiate publications and other educational material
that would be needed. In 1986, the task  force was
expanded to involve other extension program areas.
Ten  persons  representing  agriculture,  home
economics,  4-H,   and  youth  and  community
development now serve on this task force.

The task force is an efficient and effective way  of
bringing   persons from  different disciplines  and
responsibilities together for discussion, information
sharing,  program planning,  and task  assignments.
Some persons as they became involved on the task
force were reluctant participants. However, as  they
learned more  about specific water quality problems,
effects on people, and how corrective action can be
taken, these people became enthusiastic participants.
Task force  members are all involved in preparing
extension publications,  education programs,  and
water quality training.

HOUSEHOLD   WATER  QUALITY
PROGRAM
The Extension  Household Water Quality Program  at
Kansas  State  is coordinated  through the  Water
Quality Task Force. It involves preparation of a wide
range of  extension publications and supporting media
(video and slide/tape) materials, agent and lay leader
training, and news stories for newspaper, magazine,
radio, and TV.

To date,  12 extension publications are completed and
30 others planned. These publications plus materials
from  several  other sources  now  make up the
Household Water Quality Resource Notebook.

We conducted 10  agent  training  classes for  more
than 150 people in October and November 1987. We
trained agriculture, home economics, and 4-H/youth
agents as well as health  services  personnel  in
household water quality.

These one-day training sessions familiarized people
with private  household water quality and  acquainted
them  with the resource notebook,  agency contacts,
and how  to use  them. Our goal was  to give local
professionals a background so  they  can  be  local
resources for those with water quality problems.
SUMMARY

The extension system is a complex organization of
the 50 state Cooperative Extension Services and the
Extension Service, LJSDA. Federal,  state,  and local
sources  fund  extension programs. The extension
system is the noncredit informal education arm of the
land-grant  universities.  It  includes substantial
professional staff but many volunteer teachers help to
make extension a dynamic and important educational
tool for adults and youth.

Kansas  has water quality  problems among the
125,000  private water wells that serve 20 percent of
its population. A recent survey  found that 37 percent
of the wells exceeded the MCL  for inorganics, and 10
percent contained organic contaminants. Although, no
data were collected on bacteriological contaminants,
based on data from some counties, they could also
be  substantial.  We expect that at least half  of the
state's  private water  supplies  would  not  meet
standards established by the Safe Drinking Water Act
and amendments.

The Kansas Cooperative Extension Service conducts
an educational program on  household water quality. It
provides  information on quality  of  water from private
water wells  and in all  homes.  It includes training of
county agricultural, home economics, 4-H and youth
agents, and county health services personnel as local
sources of  information. New  extension  bulletins and
leaflets address water quality,  water  testing, water
treatment,   and water  quality  protection.  Other
resource materials include  video tape  and  slide/tape
sets and news programs (radio, TV,  newspaper, and
newsletter).

Safe drinking water is an important issue.  Until more
people  have  safe water, this  will-likely  be  an
increasingly  important  issue. Our household  water
quality program addresses  the  questions,  helps
people evaluate their problems,  and shows them how
to seek solutions.
                                                 24

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        FEDERAL TRADE COMMISSION REGULATION OF WATER TREATMENT DEVICES
                                           Joel Winston
                                    Federal Trade Commission
                                      Washington, DC 20580
The  Federal  Trade Commission (FTC)  is  a small
independent Federal agency established in  1914. It
has  a broad mandate:  to  promote free and open
competition and protect consumers from unfair  and
deceptive practices. The FTC's  mission includes the
regulation of  anticompetitive practices such  as price
fixing and monopolization,  as well as regulation of
business practices that deceive consumers, including
false  advertising. The FTC works  with  private  and
governmental consumer agencies including the Better
Business Bureaus,  U.S.  Postal Inspectors, state
attorneys general, and other Federal agencies.

Generally, the FTC can  act only in the broad public
interest,  i.e., when a problem affects large groups of
consumers  or  causes significant  harm to  smaller
groups. Advertising regulation by the FTC tends to
focus on national or regional ad campaigns.

The  FTC has strong remedial powers when it finds a
practice  to be  unfair  or deceptive. While  it cannot
impose criminal penalties,  it can issue  broad cease
and  desist  orders to prevent  recurrence  of  the
violations or similar practices. In some cases the FTC
can  obtain  Federal  court orders  enjoining violations,
imposing civil  penalties,  and/or  requiring  the
wrongdoer  to make  restitution  to  deceived
consumers.

In determining whether an advertisement is deceptive,
the FTC first  looks at the ad itself to determine what
message it  conveys  to consumers.  That message
may be explicit or implicit. The FTC then determines
whether the ad is likely  to  deceive  reasonable
consumers.  Both affirmative misrepresentations  and
omissions of  fact may be  deceptive. In  either case,
the  FTC will act  only when the  representation or
omission is material, i.e., likely to affect consumers'
purchase decisions.

The  FTC also enforces  its advertising substantiation
doctrine. Advertisers making objective claims about
their products must have a reasonable basis for  the
claims prior to making them. The type and amount of
substantiation that is required will depend on several
factors, including the type of claim, the  product,  the
consequences if the claim is false, the benefits if the
claim is true, the cost of developing substantiation for
the claim, and the amount of substantiation experts in
the field believe is reasonable.

The FTC  does not have  the  resources  to  pursue
every  potentially deceptive  practice.  The  FTC
considers the following factors in deciding whether to
exercise its discretion to act in a particular case:

•  The seriousness of the deception;

•  The extent of consumer injury,  including  physical
   and economic injury;

•  The number of consumers misled; and

•  The type of product involved, i.e.,  whether it is a
   tow-cost,   repeat-purchase  or  high-cost,
   infrequently purchased item.

The FTC has no specific  regulations  governing the
advertising  of water treatment devices.  Like other
advertising, claims for these devices must be truthful
and substantiated. Claims for these devices are often
credence claims. This means that consumers are not
able to evaluate the truth of the claims themselves.
For example,  a representation that a water treatment
device protects users from the hazards of chemical
pollutants cannot be evaluated by  consumers. Under
these  circumstances  the  FTC  scrutinizes  the
advertising  more closely.

In recent months,  the FTC has brought two formal
actions against  advertisers  of  water  treatment
devices.  In the  summer   of  1987,  New  Medical
Techniques, Inc. was charged  with false advertising
of its Aquaspring Home Water Distiller. The company
made a variety of claims about  the capabilities of the
Aquaspring — that  it produces pure  water, that it
will remove all contaminants from the  water,  and that
it will remove all chemicals. In fact, the FTC alleged,
the devices were not  capable of filtering volatile
organic chemicals (such as chloroform and benzene),
many of  which  may be hazardous  to health. The
company agreed to sign   a consent order which
                                                 25

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prohibits the deceptive claims and  requires certain
affirmative disclosures in future advertising.

In August  1987, the FTC issued an  administrative
complaint against North American Philips Corporation,
maker of the Norelco Clean Water Machine, a table-
top activated  carbon filter device. The  company's
advertisements allegedly represented that the Clean
Water Machine  would make  tap water  clean  or
cleaner, and would help remove organic chemicals.
According to the FTC complaint, the machine actually
introduced  a potentially  hazardous organic  chemical,
methylene  chloride,  into the water  it  treated. The
company is charged with false advertising and failing
to  disclose  the  alleged  methylene  chloride
contamination. The case is scheduled for trial before
an administrative judge in early 1988.

In addition  to these  cases,  the FTC  continues  to
monitor advertising for water treatment issues. They
are assisted in this effort by the EPA, with which they
share authority in this area. EPA  has, and continues
to provide, scientific expertise to  enable the FTC to
evaluate and prosecute cases.

In general,  the types of advertising  claims  that the
FTC may be  concerned about in this area are  as
follows:

• Claims that a device will purify the water or remove
  all  contaminants.  These  claims  should  be
  supported by  reliable evidence and appropriately
  qualified.

• Claims  that ordinary tap water is hazardous  to
  health.  These  claims  should  be carefully
  substantiated and qualified.

•   False   claims  of  consumer  or   expert
    endorsements. Consumer testimonials should be
    representative or qualified clearly.
                                                 26

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             POUlPOE PRODUCT PROMOTION GUIDELINES AND CODE OF ETHICS

                                       Maribeth M. Robb
                                   Water Quality Association
                                          Lisle, IL 60532
INTRODUCTION

To gain perspective on our subject, we have to go
back  about  50 years,  when  the  point-of-use/point-
of-entry  (POU/POE)  water  quality improvement
industry was born.  It was hardly  the  time to be
developing  a new consumer  product. The  country
was  still in the  depths  of  the  depression,  and
economic prospects in  any industry were  uncertain.
Founding an emerging industry in water quality,  in a
country  known  for some  of the best water in  the
world, made the venture even more speculative.

But,  those  early  entrepreneurs saw a niche they
thought needed filling: to take  what many considered
perfect water and tailor it to  the specific, individual
needs of the user. So they took their ideas and their
products into  homes  and  businesses. They
demonstrated  product  effectiveness and,  through
aggressive  marketing, the POU/POE water quality
improvement industry evolved.

The success of the industry in the decades since has
validated the judgment  of those pioneers.  For them
and for POU/POE, pounding the pavement, talking to
customers,  and  marketing  their  products  were
dominant activities for many years.

As the industry grew, so did the number of members
representing it. The need for  training and  education
also  grew  as  the  many purveyors of  POU/POE
needed to keep pace with the rising sophistication of
the industry. Industry-sponsored organizations, like
the Water Quality Association  (WQA), were  born to
help fill  that need. WQA continues to  fulfill  that
function today.


ANSWERING CONSUMER CONCERNS
The  influences  of the marketplace began to  change.
Because new testing techniques permitted scientists
to determine very low levels of toxicity, the quality of
the nation's  water supply was  being reassessed on a
daily  basis  in  our  newspapers.  Many Americans
became concerned about the quality of their  drinking
water. So more products were added to the original
lines to meet those consumer needs as  well.  The
industry took on yet another dimension.

Today, experts disagree on the seriousness  of the
water quality problem. Some argue that the chemical
compounds are in  such minute quantities that they
pose  little or no risk  to health. Others are more
concerned.  They worry  about  long-term  exposure to
many of the chemicals now detectable.

Even though the issue is unresolved, the  fact remains
that many individuals find their water unacceptable:
too hard, cloudy, smelly, or funny tasting. They  may
have  health concerns  about water 'quality for their
family, their infants and young children, and  during
pregnancies or times of special illnesses.

As  a result, there  is a growing  demand  for home
treatment systems and for bottled water. Due  to this
demand, the water  quality improvement  industry has
been thrust from its traditional  role of aesthetic water
treatment into the  role  of  reducing  health-related
contaminants. This,  in turn, has raised new questions
about promotional claims made for various industry
products.

VOLUNTARY  INDUSTRY  PRODUCT
PROMOTION GUIDELINES
The promulgation of the Voluntary  Industry Product
Promotion Guidelines and the  creation of  the Water
Quality Industry  Review Panel was prompted by
concerns expressed to WQA by various agencies of
the Federal  governments of the  United States and
Canada, state and  provincial enforcement agencies,
and members of  the  water  quality improvement
industry. They questioned the general level of
industry advertising and promotional claims,  and
expressed the view that the  ads  often fall  below
acceptable norms of accuracy and completeness.

Although WQA was not necessarily  in full agreement
with these opinions, it nevertheless believed it  should
respond to them on behalf of the industry in a positive
and effective manner. It was hoped that this response
would  also stimulate companies in the industry to
                                                27

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undertake a thorough and comprehensive review of
their promotional material. There is plenty of evidence
that this occurred and that this activity is ongoing.

The guidelines are not intended to provide all or any
part of the wording of anyone's specific promotional
material.  They  are merely designed to  provide  a
general framework within which more accurate and
informative  advertising,  promotional, and  sales
presentation material can be prepared in such a way
as  to avoid  misleading  consumers  about  the
capabilities of water quality improvement products.

Companies in the POU/POE industry are fully aware
that they cannot,  acting either through WQA or
otherwise, agree on  matters relating to the form or
content of their promotional material or their policies
in these areas.

The industry recognizes that  promotional material,
including advertising and sales presentation material,
is a key  element in competition and  must be left to
each individual company to develop for itself.


EPA SUPPORT
From  the beginning, the U.S. EPA encouraged WQA
to develop a private  sector program  to address this
issue.  In a  letter dated and signed by three  EPA
officials, we received much needed support.

  "Over the past ten years, we have experienced a
 variety of questionable advertising and sales claims
 by manufacturers or salespeople  of water
 treatment units.

 "Unfortunately,  the 'wildest' claims have come to
 be associated with the water quality industry in the
 mind of public water supply professionals.

 "Yet, this is probably not a true characterization of
 the major companies operating in the water quality
 field.  It  would appear  that WQA's  program  is a
 substantial  forward  step in correcting  this  false
 image.

 "Perhaps one  of the greatest contributions of the
 WQA Review  Panel would  be the preparation of
 short  'state-of-nation'  assessments   of
 advertising  and sales  claims  at  the start of  the
 project  and periodically in such  a  way as  to
 enhance public understanding and  knowledge. It
 will also be worthwhile to have an industry forum to
 which  questionable  advertising  claims  can  be
 referred.

 "We realize that the WQA Panel will be trying to
 cope with a difficult problem,  but  its  importance
 emphasizes the need  for the work.  Please  be
 assured of our support for your efforts."
GUIDELINES PROVISIONS

The guidelines were adopted  in March of 1985 and
revised in April of 1987.

The painstaking process which led to these guidelines
assured the participants of the following:
   Complaints that are based on factual data;
   Product performance and  benefit claims  that are
   verifiable;
   Visuals that are clear and unambiguous;
   Prohibition  of untrue, misleading,  deceptive,
   fraudulent, or falsely disparaging claims;
   Prohibition of sweeping, absolute statements;
   True and accurate advertisements;
   Inclusion of pertinent facts;
   Avoiding confusing terminology;
   Performance claims that are based on fact; and
   Problem/solution  scenarios  that   enumerate
   circumstances and specifics.
Other provisions are spelled out in the handling of:
   Warranties, guarantees, equivalent terms;
   Layouts and illustrations;
   Asterisks;
   Abbreviations;
   Comparisons/disparagement of competition; and
   Testimonials and endorsements.
GUIDELINES REQUESTS

Two types of requests can be submitted through the
Voluntary Industry  Product Promotion  Guidelines
process.  They are a Complaint Request, filed on an
existing advertisement or  promotion  which can  be
voluntarily resolved  or can  move on  the Review
Panel; and an Advisory Request, in which a company
submits its promotional  material or advertising for
compliance prior to printing or releasing it.

As you can see from Figure 1, communication among
involved parties is important to this process from the
very beginning. In  fact,  many of the Complaint
Requests submitted are voluntarily resolved before
they leave the Staff Review Committee.


REVIEW PANEL

For those that do progress to the Review Panel, the
complaint  is  heard  by  a  highly qualified  and
conscientious independent panel.  This  panel  forms
the  "teeth" of  the program.  Their experience,
impartiality,  and thorough consideration  of each
request give the program credibility and consistency.

The guidelines are specific on the credentials of the
Review Panel members. It calls for:
                                                28

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Figure 1. Procedures for POU/POE voluntary product promotion guidelines.
                                            Complaint Request
                                           Mailed to the Subject
                                                    20 days
                    _L
               Subject Agrees
           Mailed to Complaining Party
                      15 days
          _L
Subject C

)isagrees

I No Re

sponse

      No Response
Withdraw Request
  Refer to Staff
Review Committee
  Refer to Staff
Review Committee
      Ends Request
  Ends Request




Complaint is

•
Subject Agrees



Decision is Communicated
to Both Parties
I


1 5 days


Subject Disagree
I
s No Response
> Unjustified

Ends Request
      Ends Request
                              Lj
           Review Panel
                        n
                                     Calendar
                                   Panel Option
• A citizen/consumer - Currently that post is filled
  by Linda  Elwell, who brings her  background and
  experience  in direct  consumer marketing  to her
  position;

• An  educational  institution-connected  water
  chemist - This position is well served by  Roger  E.
  Machmeier,  Ph.D.,  P.E.,  of the  University  of
  Minnesota;

• A  water  treatment equipment  specialist--
  nonindustry  - Nina  McClelland,  Ph.D.,  brings
  years of experience with regulation, validation and
  testing to bear on her panel considerations;

• A  water  treatment equipment  specialist--
  industry,  but no  longer actively  employed by
  industry member - Wes  McGowan  now  works as
  a consultant and  brings  years  of  industry
  experience to his panel decisions; and

• A current former  Federal  or  state government
  regulatory person  who has or is working  on
  consumer and/or misleading advertising  problems
  -  Ron Graham of the Better Business Bureau  of
  Minnesota,  Inc. combines  his technical  prowess
                               with  a  working  knowledge  of small-business
                               operations.
                             COMPLAINT REQUEST CRITERIA
                             The Complaint  Requests heard  by the  panel
                             never frivolous. The criteria includes:
                                                       are
                               Name,  address, and telephone number of source
                               material company;
                               Written and dated entries;
                               Copy of all materials to be reviewed;
                               Details-how,  when,  where  the  material  was
                               used;
                               Particular guidelines possibly violated;
                               Explicit request for opinion;
                               Full legal  name, address, and telephone number of
                               submitting party; and
                               The requesting party agrees to not misrepresent
                               and to limit reference to opinion or results.
                             Figure 2 represents the first two years of the program
                             to  date.  As  you  can  see, the  total number  of
                             Complaint Requests increased by two in the second
                             year  of  the  program. However, during  the  same
                             period, those cases voluntarily resolved increased by
                                                 29

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four and  the  total  number of Advisory  Requests
increased by three.

Figure 2.  Voluntary guidelines history.
  20
  10
       Total CR
VRCR
Panel
        CR  - Complaint Requests
        VRCR- Voluntarily Resolved Complaint Requests
        Panol - Panel Review Cases
        AR  - Advisory Requests
VOLUNTARY COMPLIANCE
What we seem to be seeing is a  trend  toward
voluntary compliance,  either  after a complaint has
been filed or before the material is released.  These
are encouraging figures for  the industry  and  for
consumers as well.

There is also a question of perspective that I would
like to stress here. Of the millions  of dollars spent by
the  industry on  advertising  every year,  of the
thousands of promotional pieces and the hundreds of
advertisements, fewer than 80 have been submitted
to the  Voluntary  Industry  Promotion  Guidelines
Review  Program during its two years of operation. A
substantial proportion  of those  advertising materials
that did reach the  Review Panel were submitted by
their own companies  to assure compliance prior to
publication.

So, changes are being made,  and they are being felt
in the marketplace.


CODE OF ETHICS
Building on the  encouraging response to  the
Voluntary  Industry  Product Promotion  Guidelines,
industry  members  have  now  taken  another
courageous  step. Using the guidelines  as a nucleus,
they have launched a Voluntary  Industry Code of
Ethics program.
Although it is strictly voluntary,  it is hoped  that the
marketplace, which fueled this industry from the start,
will see the benefits of trading with Voluntary Industry
Code of  Ethics  signature companies,  and  will
embrace it as a stipulation for doing business.

The formal hearings procedure for the Code of Ethics
will be the same as for the Voluntary Industry Product
Promotion Guidelines.

The Voluntary  Industry  Code   of  Ethics  will  be
published in early  1988,  with the  first  list of
subscribers-in-good-standing  published   in  the
second quarter of 1988.


LOOKING AHEAD
Times have changed,  and  the point-of-use/point-
of-entry water  quality  improvement  industry  has
changed as well.

That  change is  apparent from  marketing,  the
Voluntary Industry Product Promotion Guidelines  and
Code of Ethics, and Product Validation.

Water quality is no longer a simple issue. It demands
a complex approach to  problem  solving as well as a
blending of industries and specialties  to  assure
optimum quality for all  consumers, in  all  regions of
the country.

The  point-of-use/point-of-entry  water  quality
improvement industry is poised to meet  that challenge
with  accountability, confidence,  and  technical
expertise.

We have the industry products,  the  industry people
and  the drive.  By  working  with professionals  like
yourselves .-- the  regulators,  the 4educators,  the
resource people, and  the water utility managers  --
we can provide the  solutions demanded and  needed
by  consumers today.  Together,  we can bring
economical, customized, quality water to every tap in
this country.
                                                 30

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                        NSF's LISTING PROGRAM FOR POUlPOE DWTUs
                                      Randy A. Dougherty
                                National Sanitation Foundation
                                      Ann Arbor, Ml 48106
The  National  Sanitation  Foundation  (NSF)  was
chartered  in 1944 in  the  State  of  Michigan  as a
private, independent,  not-for-profit organization.
The  mission of NSF  is to develop and administer
programs  relating  to public  health  and  the
environment in  areas of service,  research,  and
education.  NSF  is best known  for its  consensus
standards  and  third-party certification programs.
The subject of  this article is NSF's listing program for
point-of-use  and point-of-entry  drinking  water
treatment units (POU/POE DWTUs).

NSF standards are consensus  standards  and, as
such, are  part  of the public domain.  A company can
self-certify  to  NSF  standards, or another
organization may certify them. The standards specify
the minimum requirements for a  product to  satisfy
public health concerns. Additional  requirements that a
company   must  meet  to  obtain  and maintain
authorization for listing and  use  of  an  NSF  Listing
Mark are  specified  by contract  and administrative
policy. The key elements  of NSF's  listing programs
(how NSF certifies initial and  continuing conformance
to NSF standards) are:
   NSF standards;
   Registered Listing Marks;
   Public listings information;
   Evaluation and testing by an independent, objective
   third-party;
   Monitoring;
   Corrective action; and
   Enforcement.
NSF STANDARDS
NSF standards are voluntary,  consensus standards
developed by  a Joint Committee (comprised  of
regulators, users,  and industry  representatives),
reviewed  and accepted by  the  Council of Public
Health  Consultants (CPHC), and reviewed  and
formally adopted by  NSF's Board of Trustees.

The standards are developed or revised by the Joint
Committee (or  task groups appointed by the Joint
Committee)  with  the  active participation of public
health  and other  regulatory  officials,  users,  and
industry.

The  role  of  the  CPHC  is  to  assure  that  the
requirements  of  a standard  satisfy  public  health
concerns.  CPHC  has 36  members from  Federal,
state, and local  regulatory agencies  in the  United
States and other countries,  and academia. Industry is
not represented.  The  expertise of  the  members
includes  public   health,  medicine,  chemistry,
toxicology,  epidemiology,  microbiology,  and
engineering.  CPHC  reviews  and  must accept  a
standard or revision before  it is sent to the board for
adoption; however, it does not make any changes  to
a standard. If the council does  not accept a standard,
it is sent back to the  Joint  Committee. The CPHC is
not a  "rubber stamp." For  example, the  council
rejected proposed  Standard 55 (for ultraviolet drinking
water treatment systems) in 1985 because it did not
satisfy  public  health concerns  about cysts,  turbidity,
and viruses.

The  Board of Trustees reviews  the  standards for
business and  legal consideration. As with the CPHC,
the board does not make changes  in a standard. If
the board does not accept a standard,  it is  sent back
to the Joint Committee.

NSF has the only standards for  POU/POE DWTUs
that have widespread recognition and acceptance by
public health officials. These are:

•  Standard 42: Drinking Water Treatment Units  -
   Aesthetic Effects;

•  Standard 53: Drinking Water Treatment Units  -
   Health Effects; and

•  Standard 58: Reverse  Osmosis  Drinking  Water
   Treatment Systems.

Shortly after adoption of Standard  53  in  1981,
Canadian  authorities  proposed a ban on  point-of-
use  carbon  units  because  of  concern  for
bioaccumulation  - specifically, of  opportunistic
pathogens. NSF organized  and hosted a meeting  of
                                                31

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 Canadian and  U.S. regulatory  representatives,
 manufacturers, and recognized expert consultants. It
 was reported at the  meeting that  no known illness
 could be traced to carbon filters. There was general
 agreement to add to the standards, and to the labels
 on carbon units, the  following statement: "Activated
 carbon filter units covered by this standard are  not
 intended to   be used where  the  water   is
 microbiologically unsafe  or with  water of  unknown
 quality." A revision to Standard 53, to incorporate this
 statement and  additional labeling requirement, was
 adopted in June 1982. Standard 42 was first adopted
 in  1973, but was revised in  June  1982  to be a
 companion document to Standard 53. Standard 42 is
 consistent with Standard 53,  but is for aesthetic
 claims. Although these standards (42 and 53) are  not
 limited  to specific treatment  technologies,  the  test
 protocols are appropriate for carbon or mechanical
 filtration units only.

 Standard 58,  for reverse-osmosis  systems, was
 adopted in November 1986.

 Them are three other  standards being developed:

 * Proposed  Standard 44: Cation Exchange  Water
   Softeners;

 • Proposed  Standard 55: Ultraviolet Disinfection
   Systems; and

 • Proposed Standard 62 (for distillation systems).

 The standards  are for units designed to be  used  for
 the reduction of specific contaminants from  public or
 private  drinking water supplies. The standards have
 detailed requirements and protocols  for testing  the
 units to verify  claims for the reduction of specific
 chemical, particulate, or microbiological contaminants,
 bacteriostasis, disinfection (Standard 55 only), or  for
 the addition of  polyphosphates or silicates (Standard
 42 only).

 While  the primary focus is verification  of water
 treatment claims, the  standards include requirements
 for materials, design, and construction  of  units  to
assure that:

 • Materials in contact with the drinking water do not
   impart toxic substances, taste, odor, or color to the
   water; and

•  The  units  accomplish the intended purpose when
   installed and operated  in  accordance  with  the
   manufacturer's instructions.

For  DWTUs  with water  treatment  claims  for  the
reduction of  contaminants that are established  or
potential  health hazards, the standards  include
requirements for performance indicators, warnings, or
other means to alert  the  user when  the unit is not
functioning properly.  This  may be  by the  DWTU
having  a shut-off  to terminate the  discharge of
treated water,  sounding  an  alarm,  50 percent
reduction in flow, or by providing a test kit. For carbon
units, one alternative is to have a 100 percent safety
factor, which is verified by  testing to twice the rated
capacity.  For reverse osmosis  systems for  nitrate
reduction,  Standard  58 requires either  a  nitrate
monitor on the unit, or the manufacturer must  provide
a test kit for nitrates with the system.

The standards also have  detailed requirements  for
installation and operating instructions,  dataplate
information and labeling, and  other information about
the function and capability of a unit, including specific
warnings for users.


NSF LISTING MARK
NSF Listing  Marks are  formally registered with the
U.S. Patent  Office, and  in Canada.  NSF owns the
mark, but  doesn't use it on  products.  The mark is for
use by other companies,  on listed  products  and in
conjunction with listed products, as  authorized  by
NSF. A company applies for and contracts  with NSF
for authority  to use an NSF mark;  and specifically
agrees to use the mark on only new  products fully
complying with all NSF requirements. NSF has legal,
contractual, and ethical obligations and responsibilities
to monitor and verify that only authorized companies
use the mark, and use it properly. This is the basis of
NSF's authority relating to listed products.

To be considered listed, a DWTU must bear the NSF
Listing Mark,  and must also bear a model number (or
serial  number)  that  distinguishes it  from  nonlisted
units.  Consumers  and regulators can look for the
mark as evidence that a unit is listed by NSF.

The listing program for  DWTUs differs  from  other
NSF listing programs in that listed units do not have
to  meet the  same requirements  -  we verify the
specific water  treatment  claims  made by  the
manufacturer for a unit. So the water treatment claims
must be directly associated with the mark. The listing
mark  with an example  of  verified water treatment
claims is shown in Figure 1.


PUBLIC LISTINGS INFORMATION
One goal of listing services is  to make current  listings
information readily available  and easily accessible.
This is achieved by publishing and widely distributing
seven annual listing books  (see Table 1). NSF also
publishes  up to nine supplements  to each  annual
book.  These  supplements  include complete   listing
information for new companies, and for companies
that cancel listing  services; for revised listings, the
supplements have the changes only. Because  listings
change  daily, it is impossible  to provide current
listings information  by  publication.  Therefore,
                                                 32

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Figure 1.  NSF listing mark on a DWTU.
                               Listed  under  NSF
                               Standard 53  for the
                               reduction of TTHMs,
                               Cysts, and Turbidity
                               only.
                               Listed  .under  NSF
                               Standard 42 for  the
                               reduction of Taste, Odor,
                               and Chlorine only.
 Caution:  Do not use where the water is microbiologically unsafe
         or with water of unknown quality, without adequate
         disinfection before and after the unit.
              EVALUATION  AND  TESTING   BY  AN
              INDEPENDENT,  OBJECTIVE  THIRD-
              PARTY

              NSF evaluates and tests products as an independent,
              objective third-party.  As  a third-party, NSF  serves
              the interests  of  regulators and  users,  as  well  as
              industry.  NSF has five  regional  offices, four in the
              continental United  States,  and  one in  Brussels,
              Belgium.  NSF  regional  personnel  visit  each
              production location  (point  of final  assembly  or
              production) to evaluate products  and select  samples
              for laboratory testing.  NSF has its  own modern,
              state-of-the-art laboratory  in Ann  Arbor,  Michigan,
              and   provides   a  full  range   of  chemical,
              physical/performance,  and microbiological  testing.
              (NSF  also  has  procedures for  qualifying  and
              authorizing other  laboratories as  subcontract  or
              alternate testing  laboratories for testing products  for
              listing  by NSF.)
Table 1.  NSF Listing Publications

 Title
Distribution
 Food Service Equipment and Related Products,       6,500
 Components, and Materials

 Plastics Piping System Components and Related      3,600
 Materials
 Drinking Water Treatment Units and Related         3,200
 Products, Components and Materials
 Swimming Pools, Spas, and Hot Tubs Circulation      3,000
 System Components
 Special Categories of Equipment, Products, and      2,800
 Services
 Wastewater Treatment Units and Related           2,400
 Products and Components
 Class II Biohazard Cabinetry                    1,600
     Total                                 23,100
beginning in January  1987,  NSF provides for direct
electronic access by  computer. Any  person with a
compatible computer and modem can apply for this
service and directly access official listings information,
which is updated daily. The only cost to a  user for
this service is the cost of the telephone call.

Another goal is to provide listings information  that can
be useful to someone selecting a DWTU; therefore,
the listings  for DWTUs   include  the  following
information: the  company  name and address, a
description of the unit or system, the model number
of  the DWTU and replacement element,  and the
function (the verified  water treatment claims).  The
listings information also includes the service  cycle or
capacity in gallons, flow rate, and other information.
MONITORING
Listing is on an annual  basis. The listing program is
not a one-shot  deal, but an  ongoing program  with
continuous   monitoring  of  listed  products'
conformance  to NSF standards. The listing program
for DWTUs  includes  a requirement  for  annual
unannounced inspections by our regional personnel to
verify that there have been no unauthorized changes
in  materials,  components,  design,  or production  of
listed units. NSF also requires periodic retesting (at
least once every five years) of listed DWTUs.

NSF  investigates complaints  of  noncompliance  of
listed units. The complaints may be from public health
or other regulatory officials,  or from  users.  NSF also
investigates complaints from other manufacturers - a
mechanism for effective self-policing by industry. In
all cases, NSF  conducts its own investigation, and
takes action with the manufacturer if, and only if,  NSF
confirms that the product doesn't comply.


CORRECTIVE ACTION
The goal  of the listing  program  is to assure that a
listed product conforms to an NSF standard. If  NSF
determines that a listed unit does not conform with
the standard,  NSF requires the listed  company to take
appropriate corrective action, which  may include the
fpllowing:

•  Evaluation  or  testing  to  quality  changes  to
   products,
•  Modification of equipment,
•  Destruction of product,
•  Product recall, and
•  Public notice.
                                                   33

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 ENFORCEMENT

 NSF zealously strives  to maintain the  integrity  and
 credibility of the mark; therefore, for  repetitive or
 serious noncompliance,  NSF  takes  specific
 enforcement action as follows:
   Increased monitoring,
   Administrative hearings,
   Delisting,
   Legal action, and
   Cancellation of contract.
CURRENT STATUS OF THE LISTING
PROGRAM AND FUTU.RE
DEVELOPMENTS
The listing program for DWTUs is small. As shown in
Table 2, there are  only 13  companies with listed
units. But,  this is one of the fastest growing listing
programs.  Twenty-one additional companies have
applied for listing;  and two  additional  standards
(Standard 44 for water softeners and Standard 55 for
ultraviolet systems)  are  expected  to be adopted by
the end of 1987. Although the program is small, it has
the third largest distribution of listing publications (see
Table 1), which is an indication of the interest  and
importance of this program to regulatory officials  and
consumers.

One exciting item is the development  of a  "model
compound" concept  for testing  carbon  units  for
volatile  organic compounds  (VOCs). Under  the
guidance of a Standard 53 task  group, NSF  and a
listed  company have developed  isotherm  data  and
dynamic testing data which demonstrate  that
chloroform  can  be  used as  a satisfactory model
compound for verifying the reduction of a number of
specific  VOCs  (regulated  and  nonregulated)  by
carbon units. This will result in reduced  testing costs
for verifying contaminant reduction claims for a large
number of  organic  chemicals, producing  increased
participation by industry and an increased number of
listed models. But of even greater importance, as new
organic  contaminants are  found  in drinking  water
supplies, it  may be possible  to  demonstrate that
chloroform  is  a satisfactory model compound  for
verifying effective reduction by carbon  units - which
means that  there may be a large  number of listed
units immediately available as a remedy.
Table 2. Listing Service Programs
Program
Food Service Equipment
Plastics Piping System Components
Swimming Pools, Spas, and Hot Tubs
Class II Biohazard Cabinetry
Drinking Water Treatment Units
Wastewater Treatment Units
Flexible Membrane Liners
Special Categories
Total
(9/1/87)
Number o
Standards
21
1
1
1
3
4
1
5
37
f Listed
; Companies
1,033
275
49
12
13
12
3
31
1,428
SUMMARY
The  listing programs  are  voluntary. But  a listing
program  becomes  more than voluntary  when  NSF
standards are  referenced in regulations or codes.
Regulations or codes  usually do not require that a
product be listed by  NSF,  but  a listed product is
usually  accepted  by  the  responsible  regulatory
agency.  By  voluntarily participating  in  the listing
program, with required testing,  retesting,  and
unannounced plant inspections  by  a third-party, a
company demonstrates the  intent and capability  to
manufacture  a product  conforming to  an   NSF
standard.  The advantage  to  a  company  is  wide
acceptance of its  listed  product(s)  by regulatory
officials and consumers.

Regulatory officials and consumers have assurance
that  a  credible,  objective  third-party,  widely
recognized  by public  health officials,  has  actually
tested and verified that listed products comply with
specific  standards;  and the  cost of  the  program is
placed in the private sector rather than adding to the
cost of official regulation.
                                                34

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      WATER QUALITY ASSOCIATION VOLUNTARY PRODUCT VALIDATION PROGRAM
                         AND VOLUNTARY CERTIFICATION PROGRAM
                                           Lucius Cole
                                   Water Quality Association
                                          Lisle, IL 60532
PRODUCT VALIDATION

One of the basic purposes of the Water Quality
Association (WQA) is to promote the acceptance and
use  of  point-of-use/point-of-entry  industry
equipment,  products, and services.  One of the most
successful programs to promote this concept was the
development of voluntary industry standards.

Consistent with  the  goals  expressed  in WQA's
corporate charter, which are "to foster  the further
development of equipment, products and services in
the industry for the purpose of providing a better way
of life for all mankind," the procedures set out in both
the Guide  for Product Standards Development and
the Guide  for Product  Validation  Program  were
established and are followed in the development of
voluntary industry standards. The  WOA developed
five voluntary industry standards:

•  S-100-85  for household  commercial  and
   portable exchange water softeners;

•  S-101-80 for efficiency-rated water softeners;

•  S-200-73 for household and  commercial  water
   filters;

•  S-300-84  for  point-of-use  low  pressure
   reverse osmosis drinking water systems; and

•  S-400-86 for distillation drinking  water systems.

Under this  program, a manufacturer may voluntarily
submit a specific  type of equipment or  system to the
WQA  laboratory  where its  performance will  be
carefully evaluated in accordance with the appropriate
standard. When a system has successfully performed
to the specific testing protocol, it is then qualified to
receive the appropriate "gold seal." This seal alerts
the  consumer  that the  equipment  he/she  is
considering  purchasing  complies  with  the
specifications of a very  rigorous testing program. At
the present time, over  300  products produced  by
companies  in the  water quality improvement industry
have  been  validated  by  the  WQA laboratory. A
directory of these validated  water  conditioning
products is published semi-annually,  and  is available
to both consumers and regulatory officials.

A 10-page  brochure published  by  the  Council  of
Better Business Bureaus, Inc., entitled Tips on Water
Conditioners, makes the following statement:

  "When choosing  a water  conditioner,  look  for
  equipment that bears the gold seal of the Water
  Quality Association. This seal indicates that  the
  Water  Quality Association  has judged that  the
  equipment complies with the specifications of  the
  industry standards for water softeners (S-100)."

A great deal of effort has  been made  by the point-
of-use/point-of-entry  industry  to provide  the
consumer with products that are reliable and perform
to basic standard requirements. It has also been the
industry's desire to have these systems installed in a
safe and economic fashion.
PROFESSIONAL CERTIFICATION
The  WQA certification program was established  by
association  members  to  provide industry-wide
standards  for evaluating the knowledge of point-of-
use/point-of-entry water  treatment personnel  and  to
improve the knowledge  of  those who  service the
consumer, thereby encouraging professionalism and
integrity in the industry. Since the inception of  WQA's
certification program  in  1977,  nearly 1,800  people
have been certified in one of three categories:  dealer,
specialist, or installer.

In order  to  provide  support  for industry-wide
standards  for evaluating knowledge, it was  vital  to
develop proper study materials.  The water treatment
fundamentals correspondence course was  prepared
to provide comprehensive study materials  for the
dealer or specialist. This course was divided  into  12
lessons. Each  lesson  consists  of a pre-lesson
questionnaire to evaluate one's knowledge about the
subject, exercises to  help evaluate  one's knowledge
                                                35

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while preparing a lesson, and finally, questionnaires
(hat  are  completed  and  mailed to  the  WQA
headquarters  for  correction.  The  corrected
questionnaires are then returned to the student for his
review. This study material has been widely used by
individuals  who desire to raise  their level of
technological  competency  in  the  point-of-
use/point-of-entry industry,  wish  to participate  in
the WQA certification program, and want to be able to
display the coveted certification emblem.

The  necessity and function  of various  water
conditioning systems are well  recognized.  Equally
important to the consumer is the correct installation of
the equipment  into  the plumbing system, since the
equipment usually connects to a potable water supply
and to an appropriate drainage system.

Improper installations are not only hazardous, but also
costly when corrections  must be made.  In order to
prevent such problems from occurring,  it  is essential
that the  installer be  knowledgeable in  acceptable
installation  procedures  as well  as local  code
requirements.

The purpose  of the WQA  installers  home  study
course is to  provide  installers  with  generally
acceptable installation  procedures relating to  point-
of-use/point-of entry water  conditioning systems.
With  such knowledge, an installer may perform the
installation procedures correctly  so that a safe and
efficient  installation  is made.  Similar  lesson
procedures  as  previously discussed  for the
fundamentals course are used to assist and evaluate
the student's knowledge.
A national directory of certified personnel is published
every  two years  listing the  three  categories  of
certification - certified  dealers, certified specialists,
and  certified  installers.  Each  individual  listed has
completed a specific study course and demonstrated
his  knowledge  by  successfully  passing  the
appropriate examination. As a certified individual, he
agrees to maintain  high  standards of service. The
Water Quality Association Certification and  Education
Committee may revoke an individual's right to use the
seal  of certification if evidence of failure to maintain
these standards is established.

The  members  of the Water Quality Association
continue  to demonstrate their interest in serving the
consumer with  both certified  specialist/  installer
programs and validated products. WQA  members
over the last 32 years have  provided funding  in
excess  of $250,000  for  the  development  and
implementation of five WQA standards and six  NSF
standards to meet the association's goal  "to foster
the development of equipment, products and services
by the  industry for the purpose of providing a better
way of  life for all mankind."
                                                 36

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  GUIDE STANDARD AND PROTOCOL FOR TESTING MICROBIOLOGICAL WATER PURIFIERS
                                       Stephen A. Schaub
                U.S. Army Biomedkal Research and Development Laboratory
                                      Frederick, MD 21701

                                        Charles P. Gerba
                        Department of Microbiology and Immunology
                                      University of Arizona
                                        Tucson, AZ 85721
INTRODUCTION

Over the past several decades, a number of water
equipment manufacturers have developed technology
for  the  removal of  chemical  and  microbiological
constituents  from waters  to  be used  for personal
consumption. The  need  for this  capability arises
principally from consumer interest in improving the
quality  of untreated or partially treated waters like
those used  by hikers,  campers, recreational home
and boat owners, and families or communities having
individual home or small system water sources.

One of the major concerns in water treatment is the
need to remove pathogenic microorganisms (bacteria,
viruses, protozoa,  fungi,  and  helminths) from the
water before its consumption, since it is recognized
that  infectious disease transmission by  water is  a
significant public health concern.

It is important that water  treatment units or  devices
designed for the protection of  human health  be
effective against  pathogenic  microorganisms in
untreated or partially treated water,  and be capable of
providing this service over the designed operational
life  of  the equipment  in  waters  likely  to  be
encountered  in  the   United  States.  These
requirements are necessary for protection  of the
public's health by  both the  water industry and the
government.

A multidisciplinary task force was formed in  1984 to
develop a Guide  Standard and Protocol for Testing of
Microbiological Water  Purifiers. The task force was
comprised of persons representing the interest  areas
of academia, industry, and government  for research
and development, product evaluation and registration,
and product  regulation  and  enforcement.  The
objective of  this task force was the development of a
standard and protocol that industry, government, and
consumers  could agree  with  and  which could  be
attained with current knowledge and technology. The
primary emphasis was to protect the consumer.

At this time,  the  guide standard and  protocol  has
been prepared by the task force, has been technically
reviewed (notice in Federal Register of May 29, 1986;
and U.S. EPA Science Advisory Panel), and has been
appropriately  revised in  consideration  of  these
reviews. It has been accepted  on a provisional basis
by the U.S. EPA's Office of Drinking Water and Office
of Pesticide  Programs,  pending  experimental
verification of the  efficacy of the protocol  under the
prescribed parameters.

The  intent of  this paper is to  provide  the major
features and considerations of the guide standard and
protocol  in  its  current  configuration.  It  is
recommended that persons or organizations  wishing
to use the guide standard and  protocol  for testing
purposes, obtain the complete,  detailed package from
the above U.S. EPA program offices.

REQUIREMENTS  FOR  A   MICRO-
BIOLOGICAL WATER PURIFIER
The  current definition of a  microbiological water
purifier is  that it must remove, kill, or inactivate all
types of disease-causing microorganisms from water
to make the product safe to drink.

Units or  devices  having  limited claims for  the
treatment or removal of a specific type of organism,
or use in a specific, limited application, can be tested
for that use in accordance with  the protocol, however,
such equipment  cannot be  called a microbiological
water purifier. For example, a protozoan cyst removal
unit could be tested against the protocol  and could
demonstrate acceptable cyst removal,  but unless it
also met the  required removals for the bacteria and
viruses, it  could not claim  to be a microbiological
water purifier.
                                                37

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 PRINCIPLES   FOR   THE
 STANDARD AND PROTOCOL
GUIDE
 The guide standard and protocol is to be considered
 a general  guide,  presenting only  the  minimum
 features and  framework  for  testing,  and may  be
 amended or added  to for the evaluation  of unique
 units  or specific operational problems  (including
 alternative organisms and  procedures) as long as the
 level of testing and intent  of the protocol  are not
 diminished. It  is performance-based, utilizing realistic
 worst  case conditions.  The  goal  is to ensure that
 microbiological requirements  of the National Primary
 Drinking Water Regulations  are met by  equipment
 defined as microbiological  water purifiers.

 The guide standard and protocol is intended to be a
 living document, subject  to revision and  update  as
 new knowledge and  technology arise. The document
 should  be  capable  of addressing  appropriate test
 challenges  for other types  of purifiers when  they
 become available,  and  would consider new  or
 evolving pathogens of concern if they represent  an
 increased  challenge to technology covered by the
 protocol.

 It was  intended  that  the  test  conditions  or
 requirements  of the  protocol could  be  met  in
 reasonably well-equipped  laboratories  when
 performed  by  competent scientists and engineers. It
 is known that there  are at least several commercial
 and  university laboratories in the U.S.  that currently
 have the capability to meet the test  requirements.

 The protocol  does not  and  cannot address  all
 conceivable microbiological  and   physical/chemical
 challenges that could be possible in water.  Presently,
 the  test  protocol addresses  the  following
 technologies:

 • Ceramic filtration candles  or units (with  or without
   chemical bacteriostatic agents),

 • Halogenated  resins and  units  (with or  without
   filtration capabilities), and

 • Ultraviolet (UV) units   (with or  without filtration
   and/or chemical adsorption capabilities).

 MICROBIOLOGICAL CHALLENGES  FOR
WATER PURIFIERS
The  microbiological challenges for testing  were
chosen to  be representative of bacterial,  viral, and
protozoan pathogens of the gastrointestinal tract, and
are believed to cover the treatment requirements
presented by most other human pathogens from the
gastrointestinal tract  or other origins, including fungi
and  helminths.  It is recognized  that  there  are a
number of alternative organisms that could have been
selected, and  which  would be equally representative
for testing. A detailed rationale  for the use and test
levels of the challenge organisms is  provided in the
complete guide standard and  protocol, which can be
obtained from the U.S. EPA offices mentioned in the
Introduction.

Table  1 provides  a brief  summary of the  test
organisms and  the  culture/assay conditions required
for testing. In all cases the microbiological procedures
chosen  represented well  documented protocols or
standard methods, which could  easily be attained in
the laboratory.

Table  2 provides  the  minimum  microbiological
challenge levels to be used. A major point which must
be emphasized is that the challenge  levels in most
instances exceed the  highest  concentrations  that
would be found in typical  source  waters. It was the
task force  opinion  that  the  higher challenge levels
were less  of  a  concern  to  the  evaluation of
purification  units than  the  complications arising  from
the introduction of analytical errors, which could be
introduced from the effluent (product) water sample
concentration procedures. Low challenge levels would
necessitate  sample concentration to quantitatively
assay the product waters if microbial removals were
significant, especially for the viruses and protozoa.

NONMICROBIOLOGICAL     TEST
PARAMETERS
It  was   determined  that,  in  addition  to  the
microbiological  challenges  to  the  various  water
purifiers, there was  a need to evaluate the treatment
capabilities  of units in the presence of associated
physical/chemical  parameters in water,  which  may
impact on the overall microbial removal capabilities of
each type of treatment  technology.  It was decided
that, for the first half of  the testing  procedure a
general  challenge, typical of most tap waters, would
be utilized  for  all testing. The  second half of  the
testing program would use the worst  case challenge
in  which pH; Total Organic Carbon (TOC); Turbidity;
Total Dissolved Solids (TDS); Temperature; and for
UV light units,  a UV Quenching Test  Component,
would be added. Table 3 provides the test conditions
required for the  various types of  purifier tests and the
recommended materials or chemicals  for adjusting
the water characteristics. Additionally,  silver leaching
test conditions for units containing silver bacteriocide
are  included.  While  many of  the  worst case
challenges appear to be on the high  side of normal
conditions, they are  not thought to be  out of line  with
conditions   brought  about  by   seasonal  or
meteorological events or significant pollution events in
surface  waters. The worst case  challenges  will be
maintained over the total duration  of the second half
of  the  testing program with  the  exception of  high
turbidity conditions,  which  would be introduced  only
during sampling periods to prevent excessively rapid
clogging of units containing filtration components.
                                                 38

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Table 1.   Microbiological Methods for Test Protocol
 BACTERIA:
   Organism
   Culture Requirements
   Assay
 VIRUSES:
   Organism

   Culture Requirements
   Assay
 PROTOZOA:
   Organism

   Culture Production
   Assay
Klebsiella terrigena
Overnight broth cultures to obtain stationary growth phase cells
Spread/pour plate or membrane filter techniques using nutrient agar, M.F.C., or M-Endo Medium*

Poliovirus Type 1  (LSc) and Rotavirus, Strain SA-11 or WA (both viruses will be tested together using equal
proportions to seed the challenge water)
Grown on tissue culture and prepared to provide monodisperse virus particles for tests
Plaque or immunofluorescent foci assays on continuous cell cultures

Giardia lamblia or Giardia muris where disinfection is principal mechanism; 4 to 6 jim spheres can be used
where occlusion filtration is the exclusive removal mechanism
Obtain and prepare cysts from feces of laboratory-infected animals
Count physical  particles for filtration: determine viability of cysts (or trophozoites) for disinfectant-containing units
  * Use procedures in Standard Methods for the Examination of Water and Wastewater, 16th Edition, APHA, or equivalent.
Table 2. Microbiological Challenge (testing according to NSF Standard 53 for cyst reduction
Organism Influent Challenge*
BACTERIA
Klebsiella terrigena (ATCC-33257)
VIRUS
Poliovirus 1 (LSc) (ATCC-VR-59), and
Rotavirus (WA or SA-1 1) (ATCC-VR-899 or VR-2018)
CYST (PROTOZOAN): G/ard;a~*
Girdia muris or Giardia lambia, or
As an option for units or components based on occlusion
particles or spheres, 4 to 6 ym
107/100 ml
1 x 107/l
1 x 107/l
10.6/1
filtration: 107/l
will be acceptable)
Minimum
Log
6
4
3
3
Required Reduction
Percent
99.9999
99.99**
99.9
99.9
    * The influent challenge may constitute greater concentration than would be anticipated in source waters, but these are necessary to
      properly test, analyze and quantitatively determine the indicated log reductions.
    ~ Virus types are to be mixed in roughly equal 1 x 107/I concentrations and a joint 4-log reduction will be acceptable.
   *** It should be noted that new data and information with respect to cysts (i.e., Cryptosporidium or others) may in the future necessitate a
      review of the organism of choice and of the challenge and reduction requirements.
Test Waters
General
Halogen Disinfection Tests
Chlorine and Others
Iodine
Ceramic Candle Tests
Ultraviolet Tests*
Silver Leaching Tests
PH*
6.5-8.5
9.0 + 0.2
5.0 ±0.2
9.0+0.2
6.5-8.5
5.0 + 0.2
TOG*", mg/l
0.1-5.0
>10
>10
£10
>10
-1.0
Turbidity*", NTU
0.1-5.0
>30
>30
>30
>30
0.1-5.0
Temperature, °C
20 + 5
4±1
4±1
4 + 1
4 + 1
20 + 5
TDSt, mg/l
50-500
1,500>150
1, 500 > 150
1,500 >. 150
1, 500 > 150
25-100
  Recommended Materials for Adjusting Water Characteristics:
     *  Inorganic acid or base.
    **  Humic acids.
    ***  AC fine dust (part No. 1543094).
    t  Sea Salts (Signma Chemical Co. or equivalent).
    $  p-hydroxybenzoic Acid (general purpose reagent).
       Quench UV to just above alarm point. (Add color or reduce light intensity to just above point where low UV intensity alarm would be
       triggered.
                                                                39

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 PURIFIER TEST PROCEDURES

 For testing of a purifier, it is recommended that three
 units be  set  up  in  parallel,  according  to
 manufacturer's instructions for normal line pressures
 (~60 psig), but the flow rates through the units would
 not be controlled. The  required  physical/chemical
 characteristics  for  the  tests  would be maintained
 continuously  with  the exception of  turbidity  as
 mentioned above. The bacterial  challenge should be
 maintained continually during  operation  of the  units,
 but virus and  protozoa would  only be  introduced
 during the sampling "on" periods of the test. Samples
 are to be taken  in  duplicate from each sampling
 position  (influent  and  product water)  at the
 appropriate  sampling "on" periods specified in the
 protocol.  Sufficient void volumes will  be passed
 through the units before samples are taken to ensure
 the uniformity  of the challenge, especially for the
 virus,  protozoa, and  turbidity, which are  introduced
 only  during the  sampling  periods. An  exception is
 sampling  after the programmed  48-hour stagnation
 periods when samples  are taken immediately  upon
 start-up.  Disinfectant-containing  purifier samples
 (microbiological) will be immediately neutralized with
 respect to that chemical.

 The  testing program will  be conducted for  100
 percent  of the  estimated treatment  capacity of
 halogenated resin-containing  units and  for a 10-1/2
 day operating  period with ceramic candle and UV
 units.  The operating cycles  for the  purifier  units
 should be representative  of use (e.g.,  intermittent).
 For example, a use cycle of every 15 to 40 minutes
 during each operating day with  an actual operating
 "on" period  of  10 percent for each cycle is
 considered appropriate.  (For example, if a 30-minute
 cycle is  used,  the operating  "on"  period would  be
 three minutes/cycle.) If necessary, due to  time or
 laboratory constraints, a shorter operational day with
 an  extended test period can be substituted, or a daily
 operating  cycle of 20 percent "on" and 80 percent
 "off" can be used.

 A schematic of a typical test stand for the evaluation
 of  plumbed-in units is presented  in Figure 1.  This
 schematic is essentially that of the National Sanitation
 Foundation (NSF) Standard 53  for  Drinking Water
 Treatment Unit  Health  Effects.  This  set-up  allows
 good control of total test operations and sampling with
 a minimum of  variables  entering the  procedure.
 Sampling  can be performed on an automated basis.
Testing of portable or hand-held purifier units can be
set  up in a  batch testing procedure,  which would
 follow the test schematic of plumbed units as closely
as possible, although a number of the features of the
system such as  flow meters, automated sampling
procedures, and delivery of virus, cyst,  and turbidity
challenges would have to be modified.

Tables 4, 5, and 6 illustrate the sampling plans for the
various types of units. For units containing halogens,
the sampling of residual halogen in the product water
is conducted at the same times and frequencies as
the  microbiological  challenges. Additionally,  at  the
start of each test, the waters to be used for testing of
all  type  units are to  be examined for  U.S.  EPA
primary  and secondary pollutant  constitutents in
accordance with standard analytical procedures.  The
challenge conditions for iodine versus chlorine  and
other halogen-containing units are  identical  except
after the 48-hour stagnation period  at 75  percent of
the  life of the  units,  wherein  the  pH challenge for
iodine-containing units  becomes pH 5.0 rather than
9.0. The sampling for ceramic  candles and UV units
is  straightforward.  Leaching tests  for  silver-
containing units are also necessary to make sure  that
no dangerous levels of silver reach the product water.

MINIMUM     MICROBIOLOGICAL
REMOVAL   FOR   ACCEPTANCE  OF
PURIFIERS
In  order  to meet  the  standards of  acceptable
microbiological  removal, the  three duplicate units
tested  must continuously meet  or exceed the defined
microbiological removal requirements, within allowable
tolerances  as determined from paired  influent  and
product water samples.  Not more than 10  percent of
the sample  pairs from the three units  can fall below
the tolerances for removal:

• Bacteria: 99.999 percent removal,
• Virus: 99.9 percent removal,  and
• Protozoa: 99.5 percent removal.

If the geometric mean of all sample pairs meets or
exceeds  the microbiological removal  requirements,
the deficiencies of the 10 percent of the sample pairs
falling  below tolerances will  be  allowed  and  the
purifier capabilities will be considered acceptable.

It is important to keep records  of the test  procedure
and the data if there is a claim to be made for units to
be considered microbiological water purifiers.

PRELIMINARY TEST  RESULTS  OF  THE
FEASIBILITY OF THE  PROTOCOL
Recently, studies have been conducted  on cartridge
type filters,  using the  protocol for ceramic  candle
units to help ascertain  the feasibility of  the protocol
for  water purifier testing. The  tests were conducted
specifically to evaluate the virus testing component of
the  protocol. Several  modifications to the protocol
were made  to simplify the testing procedure.  These
included elimination  of.the in-line mixer  and booster
pump,  elimination of  the pack-pressure  regulator,
addition of  a 380-I (100-gal)  reservoir to contain
the challenge waters, and another similar reservoir to
collect  the  product  water for  disinfection prior  to
discharge. The viruses  were  added to the  proper
concentration in the  reservoir  in a  batch  mode  for
                                                 40

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Figure 1.     Test apparatus - schematic (adapted from NSF Standard 53).

                                                    Back Pressure Regulator
                                                               T

  Water
   Line
 Pressure
 Vacuum
 Breaker
                                          PressureGauge
                                                                          Pressure Regulator
              Flow Control or
               Control Valve
                                                    Turbidity
                                                    Booster
        Any Suitable
     Bacterial, Chemical
       and Paniculate
      Delivery System
Virus and Cyst
Delivery System  \I/
                                                                              Effluent Sampling
                                                                                   Points
                                                                                                   Electrical Supply
                                                                    Flow
                                                                   Control
                                                                                                                Multiple Cam Timer
                                                                                                                   or Equivalent
   NOTES:

   1.   Faucets are to be used in testing all units under the sink or over the sink. (Regular kitchen faucets for stationary units and faucet
        attached units and smaller third faucets for by-pass units.

   2.   Faucet attached units and portable units are to be placed after the solenoid.

   3.   Whole house or similar large units need not use faucets. Flow can be regulated with valves placed on the effluent side.

   4.   All materials of construction must_be suitable for use with drinking water.                                !
     Y   Shut Off Valves (not to be used for regulating flow


     /_   Solenoid Valve


    (X)  Check Valve
                                                                41

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Tablo 4. Sampling Plan Halogen-Containing Units
Tost Point
(as % of tola!
slated capacity)
0
25
SO
After 48-hr stagnation
60
75
Aftor 48-hr stagnation
30
100
Altor 48-hr stagnation
Influent
Background (all
Test Water Halogens)
General X
Challenge
pH 9.0 ±0.2
Challenge
pH 9.0 ±0.2
(chlorine & olhers) or
pH 5.0 ±0.2
(iodine)
Residual
Halogen,
Chlorine &
Others
X
X
X
X
X
X
X
X
Tests
Iodine
X
X
X
X
X
X
X
X
X
X

Microbiological
Chlorine &
Others
X
X
X
X
X
X
X
X

Iodine
X
X
X
X
X
X
X
X
X
X
Table 5.  Sampling Plan - Ceramic Candles or Units and UV
         Units

                                      Tests
Tost Point*
Slart
Day 3 (middlo)
Day 6 (middlo)
After 48-hr stagnation
Day 7 (middlo)
Day 8 (near end)
After 48-hr stagnation
Day 10.5
Test Influent
Wafer Background
General X
Challenge
Micro-
biological
X
X
X
X
X
X
X
X
    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
    bo measured at each microbiological sampling point
Tablo 6.  Sampling Plan - teaching Tests for Silver-
         Containing Units

                                      Tests
Tost Point
Stan
Day 2
Altor 48-hr stagnation
Influent
Background
X
Silver/
Residual
X
X
X
The test apparatus is shown in Figure 2. The results
of the virus  challenge  are shown  in Table 7. The
results indicate that the  units can remove at least 99
percent  of the virus from  the regular  challenge
(Tucson tap water), which was used in the first half of
the test,  and  greater than 99.9 percent removal from
worst case challenge water used in the second half of
the tests.

CONCLUSIONS
The Guide  Standard  and  Protocol  for Testing
Microbiological  Water Purifiers  provides the  water
industry,  consumers, and  government  a common
approach  to  the  evaluation  of  existing  and
developmental products  for  their  microbiological
removal  capabilities.  While the standard and  testing
protocol  is rigorous in terms of both microbiological
removal  requirements  and challenge requirements
(both  microbiological  and physical/chemical), it should
provide a high degree of confidence  in" terms  of
protection to consumers  wishing to use  point-of-
use microbiological water purification units or devices
to remove disease-causing  organisms  from their
drinking water.
introduction to the filters. When worst case challenge
waters were applied, the virus inoculum was added to
the water only at the sampling time. The testing cycle
was every 30 minutes for an  eight-hour daily  run
with an operating "on" period of three minutes. Virus
samples were taken when  approximately  10 bed
volumes of the seeded water had passed through the
system units except for 48-hour stagnation samples.
                                                  42

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Figure 2.  Test apparatus.
                                                 Pressure or
                                                  Bladder
                                                   Tank
        Flow
       Meters
                                Cartridge Filters
                                 and Housings
Table 7.
              Effluent
              Reservoir
Virus Removal by  Cartridge  Filter  Units Using
EPA Water Purifier Protocol
Time
(days)
1
3
6
7
8
10
10
Water Type
Tap Water
Tap Water
Worst Case Water
Worst Case Water
Worst Case Water
Worst Case Water
Worst Case Water (stagnant)
Average Percent
Removed
99.32
98.33
99.89
99.91
> 99.99
99.93
- > 99.99
                                                            43

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               PERFORMANCE AND APPLICATIONS OF GRANULAR ACTIVATED
                               CARBON POINT-OF- USE SYSTEMS
                              Karl Van Dyke and Roy W. Kuennen
                              Research and Development Division
                                      Amway Corporation
                                         Ada, Ml 49355
Point-of-use (POU)  water treatment devices based
on  granular  activated carbon  (GAC)  have  been
around for many years. Most were traditionally used
to improve the aesthetic quality of drinking water:
color, turbidity, taste, and odor. As the knowledge of
trace organic chemicals in drinking water has grown,
so has the public's awareness of the problem. As the
issue of chemical contamination grows, the traditional
aesthetic claims are being  supplemented by claims
for  chemical  removal.  This requires more cjearly
defined ways to evaluate the validity of these claims.
The addition of the VOCs to the Safe Drinking Water
Act, with  their low maximum  contaminant levels
(MCLs),  places more stringent  requirements  on
devices claiming to remove them to  below  MCL
concentrations (1,2).

It has been said one can filter anything from water if it
is filtered  through enough money.  This means that
the technology is available, however,  it  may be  too
expensive  to employ on a  full scale.  Point-of-use
water filters offer options of technology that could be
prohibitively expensive on a large scale.  They offer a
means to  achieve filtration if properly  designed  to
remove even low pg/l  (ppb) levels of contaminants
that are below MCLs. POU devices containing GAC
are designed in one of three  basic  configurations:
GAC in single or sequential  housings, GAC and PAC
in sequential  housings, and pressed carbon blocks.
They may be  installed  in  several configurations
including faucet, stationary,  faucet diverter, and line
bypass.
The purpose of  this  paper is to summarize results of
Jab  and field studies on POU devices to support  the
concept  of  using  chloroform   as  a  surrogate
compound  for making  removal claims  for  specific
VOCs found in drinking water.

POINT-OF-USE  PERFORMANCE  --
TEST DATA
GULF SOUTH RESEARCH INSTITUTE
The first significant evaluation of POU devices began
with the Gulf South Research Institute (GSRI) studies
sponsored by the U.S. EPA Office of Drinking Water
and  reported between May 1979 and October 1981
(3). This study consisted of three phases progressing
from lab to field. It was set up to develop basic data
and  information on the performance of  a  variety of
small home  treatment units with respect to organics
removal and bacterial/endotoxin  aspects. The
philosophy was to stress the units under simulated
home use.

Phase 1
Phase 1 addressed protocol development and pilot
testing using spiked and unspiked New  Orleans  tap
water. The basic  procedure was to run  units on an
accelerated  program, sampling  at several  points
throughout the rated life. Influent and effluent samples
from filter tests were run for trihalomethanes (THMs),
nonpurgeable total organic carbon (NPTOC), bacterial
standard plate count  (SPC), endotoxin, and  silver
(where appropriate). Unspiked tapwater was selected
as the main means of testing based  on pilot  tests.
Preliminary  results on  seven  units in  Phase 1
included two faucet filters (one  bypass, one
nonbypass),  one  portable pour-through, one
•stationary filter, and three line bypass POU devices.

Results for trihalomethanes showed:

« Small faucet and  pour-through filters  removed
  amounts  ranging  from  negligible  to about  25
  percent  of the  influent  THM during  the
  manufacturer's recommended filter life.

» Larger stationary and  line bypass filters removed
  greater percentages, ranging from  43 percent to
  over 90 percent for one filter.  The extent of THM
  removal appeared  to  be  a  function of  several
  factors, including the quantity of carbon relative to
  treated water, contact time, and design factors.

Phase 2
A total of 25 commercially available units and one
experimental unit were evaluated in Phase 2. Influent
and effluent tests were run for THMs,  NPTOC,  SPC,
                                                44

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endotoxin,  silver, and peripheral substances. Each
model was challenged  with  ambient New  Orleans
municipal drinking water during three replicate tests.

Results for trihalomethanes showed:

• Small  faucet  and  pour-through filters  removed
  from four percent to 69 percent of the influent THM
  during the rated lifetime of units.

• Larger stationary and line  bypass filters removed
  greater  percentages,  ranging from  15 to  98
  percent. Six line bypass units (including one  unit
  containing an  experimental material) removed over
  85 percent of the influent THM. The descriptions of
  the five commercially available line bypass  units
  (Table 1) allows a comparison of rated capacities:
  from 3,785 to 15,140  I (1,000 to 4,000 gal), carbon
  weights from 300 to 1,708 grams (0.7 to  3.76 Ib),
  and iodine numbers from 434 to 1,223.  Units are
  ranked based  on carbon weight and iodine number,
  a measure  of capacity.  Breakthrough  curves
  (Figure  1) show performance as expected with
  three  models performing well for 3,785  I (1,000
  gal), and two  past 7,570  I (2,000 gal). Removal
  here should be noted  as percent of total chloroform
  applied to the  filter, not influent versus  effluent at
  any one point.
Table 1.   Line Bypass Units (Phase 2)
Unit
Culligan
SG-2
Aqualux
CB-2
Everpure
QC4-THM
Aquacell
Bacteriostatic
Seagull IV
Description
1 cartridge
w/GAC
2 cartridges
w/GAC
2 cartridges
(1 PAC, 1
GAC)
2 cartridges
w/GAC
1 cartridge
w/pressed
block
Rated
Capacity
(gal)
4,000
2,000
1,000
2,000
1,600
Carbon
Weight
(9)
1,708
1,150
765
417
300*
Iodine
Number
980
966
1,223 (GAC)
798 (PAC)
867
434*
   * Carbon and binder.

Phase 3
Phase 3 included a ground water study, field study,
home study, and an addendum covering removal of
halogenated organics.

In the ground water study, 10 models were evaluated
with well water  spiked with  1,1,1-trichloroethane,
carbon  tetrachloride,  trichloroethylene, and
tetrachloroethylene at target levels of 50, 20, 50, and
50 yg/l  respectively. The five commercial line bypass
models previously detailed in Phase 2 were among
the 10 selected.
The results were:

• The selected models  (from each of the four basic
  configurations) removed from 76 to 99 percent of
  the spiked halogenated organics in the well water.
  The five line bypass models highlighted in Phase 2
  removed  from  93 to 99 percent of the  spiked
  organics.

• Generally, carbon  tetrachloride  and  1,1,1-
  trichloroethane broke through the carbon filter first
  while trichloroethylene and tetrachloroethylene did
  not break through at all for some units.

The Phase 3 field  study involved units tested in the
cities of Miami, Florida; Atlanta, Georgia; Pico Rivers,
California; and Detroit, Michigan.

The results were:

• Upon reviewing the THM reduction data, it appears
  that  the  relative unit  performance ranking
  determined in the laboratory  test  is  maintained
  throughout the field study.

• The overall level of specific organic chemical
  removal  appears to be adversely  affected  by
  increased  levels of  background  organic  material
  present in the water matrix.

The conclusions drawn were:

• Filter unit percent removals  of THM compounds
  can  be  predicted with  some confidence  using
  results based on laboratory tests. The total organic
  background level, NPTOC, in water may affect
  percent reduction levels  of  THMs slightly  (to
  approximately  10 to 20 percent) over the range of
  background organic levels experienced in the field
  study (0.6 to 7.1 mg/l  NPTOC).

• The ranking of filter units appears to be maintained
  regardless of the source water. The ranking could
  change  if one were   monitoring  the  filter's
  effectiveness in  removing a different  contaminant,
  since many carbon adsorbents are  manufactured
  with some degree of selectiveness.  The  GSRI
  experience has  been that this  occurs infrequently
  and  one can   be  fairly certain  that  units
  demonstrating  effective  removals  of  THM
  compounds will  also  demonstrate strong affinities
  to most other halogenated compounds.

In the home study, three filter types were challenged
with New  Orleans tap  water under nonaccelerated
conditions.  One  of the line bypass models was
included in this test. Limited data indicated the validity
of using accelerated laboratory testing to provide an-
accurate assessment of the effectiveness of carbon
filtration  in removing trace  organic  chemical
contaminants from drinking water. A larger data base
                                                  45

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would be  required to  assure the positive correlation
between  laboratory (accelerated) tests and home
(actual use) tests  although preliminary  data  indicate
the lab tests provide valid assessment data.

The  Phase  3  addendum  covering  removal of
halogenated organics  involved testing the same 10
POD  devices  with additional  organic  spikes.  The
study was flawed due  to the presence of  organic
solvents used to get  the  halogenated  organics into
water.  It  was felt that the organic removal  data
provided  useful  information  regarding  the removal
capabilities under very severe conditions.

The selected models were effective in  removing the
spiked level of  halogenated  organics from New
Orleans  tap water  (49  to  99  average percent
removal).  Line  bypass  units,  generally,  are  more
effective in removing  halogenated organics than the
other models.
 Line Bypass
 Faucet Mount
 Stationary
 Pour-through
65-99  percent
50-60  percent
  49 percent
  66 percent
The conclusion was that it was reassuring to observe
significant reductions of  halogenated  organics  and
THM  contaminants  (49 to 99 percent and 24 to 99
percent, respectively) despite the adverse conditions
of the test water challenge.
EPA/NSF JOINT STUDY

A more in-depth study of POD devices in the home
was run using  five of the units tested in the GSRI
study.  An  EPA-sponsored  study performed by the
National Sanitation Foundation (NSF) to study point-
of-use  reduction of volatile halogenated organics  in
drinking water involved two communities. The project
was conducted  in  1983 and  1984,  in  Silverdale,
Pennsylvania,  and in Rockaway Township,  New
Jersey  to  determine  whether point-of-use carbon
treatment is cost effective for the control of volatile
halogenated organic chemicals in  small  water
systems and also  to study  water  quality district
management techniques  for  point-of-use  treatment
(4).  Criteria for selection of  devices  for this study
included, among others:

• The devices  must have demonstrated greater than
  95 percent  reduction  of   halogenated organic
  demonstrated  in  the  GSRI  Phase 3 study  or
  equivalent.

• The  manufacturers  were  required  to  certify  that
  their  products met NSF Standard 53 Section 3, for
  structural  integrity,  corrosion  resistance,
  nontoxicity, etc.
                             •  Point-of-use  devices were  required  to have a
                                rated  capacity exceeding  2,650 I  (700 gal)
                                (estimated one-year  service life).

                             Only line bypass models were selected.

                             SILVERDALE
                             For the Silverdale study, the summary of influent VOC
                             results (Table 2) covering March 1983 through April
                             1984 shows trichloroethylene and tetrachloroethylene
                             as  primary  contaminants, with  smaller amounts  of
                             carbon tetrachloride and chloroform.

                             Table 2.   Influent VOC Results - Silverdale
                              Compound    ,             Mean Cone. Predevice (iig/l)
Trichloroethylene
Tetrachloroethylene
1 ,1 ,1 -trichloroethane
1,2-dichloroethane
Carbon tetrachloride
Chloroform
Bromodichloromethane
Dibromochloromethane
Bromoform
80.4
20.6
1.1
<1.0
8.0
6.7
1.5
1.4
<1.0
                             Breakthrough was defined as detection of the same
                             VOC  in  consecutive postdevice samples from the
                             same location at a  concentration above the routine
                             detection limit of 1.0 pg/l. Breakthrough did not occur
                             for any of the devices tested during the 14 months of
                             sampling for TCE and PCE.

                             ROCKAWAY TOWNSHIP
                             For the Rockaway Township study, 12 POU devices
                             were  installed on private wells in October 1981. The
                             type and concentration of VOCs was varied, with the
                             primary  contaminants  being  1,1,1-trichloroethane
                             and trichloroethylene. See Table 3.

                             Table 3.   VOC Results - Rockaway Township
VOC
1,1,1 -trichloroethane
1 ,2-dichloroethane
Tetrachloroethylene
1 ,2-dichloroethane
Trichloroethylene
Trans-1 ,2-dichloroethylene
Chloroform
Trichlorofluoromethane
Range of Cone.
Found (ug/l)
1.0-240.0
6.7-20.7
1.0-12.3
< 0.4-1 0.1
0.7-240.2
0.8-5.1
1.7-2.1
<25.0
Number of
Wells wA/OCs
8
4
7
6
4
2
2
1
                             The local  health  department did  sampling  and
                             analysis from October 1981 to October 1982 with 100
                             percent VOC reduction. After beiqg included in the
                             study, four sites were monitored in October 1983, the
                                                 47

-------
24th  month  of  operation. There  were  no VOCs
measured in postdevice samples after 24  months of
operation.

Data  from the  study indicates that point-of-use
granular  activated carbon  (GAG) treatment devices
effectively  reduced   concentrations  of
trichloroethylene,  tetrachloroethylene,  carbon
tetrachloride,   1,1,1-trichloroethane,  1,1-
dichloroethylene, 1,1-dichloroethane, and chloroform
at influent concentrations studied. These results
confirm bench and field results from the Gulf South
Research Institute study.


NSF STANDARDS 42 AND 53
The National Sanitation  Foundation has issued
several standards relating  to POU devices,  the two
most  relevant being Standard 42 for Drinking Water
Treatment Units  -  Aesthetic Effects, and  Standard
number 53 - Health Effects (5). The contaminants
covered in Standard 42 include such things as taste,
odor,  and color and  specific chemicals  such as
foaming  agents, hydrogen sulfide, and  phenol.
Particulate reduction, while not an inherent quality of
GAG, is also covered.

The contaminants  covered in  Standard  53 include
total trihalomethanes,  six  pesticides, soluble ions -
nitrate and fluoride, eight heavy metals, plus cysts,
turbidity,  and asbestos. Total trihalomethanes are run
at a 450 pg/I challenge to a 100 pg/l effluent limits.
This standard does not yet cover the newly regulated
VOCs.

DEFINITION OF END  OF LIFE
Determining  when  a POU  device is exhausted for
taste and odor can  be  done by consumer perception.
NSF standard determines it by chlorine reduction. For
the trihalomethanes  -(MCL  100  pg/l),  the  NSF
Standard 53 challenges at 450 pg/l and rates capacity
based on breakthrough to  100 pg/l, with a  100
percent safety margin. End of rated life for the other
VOCs may be based on a  breakthrough equal to the
MCL with an evaluated challenge of perhaps 300 pg/l.
The VOCs and MCLs are listed in Table 4 (2).
Table A. Regulated VOCs and MCLs
Compound
V«iyl Chtonde
Bonzono
Carbon Toirachkmde
1,2-dicWoroGliiane
Tnchtofoethytone
1,1-dicliforoethyIene
p-dtchtorobonzono
1,1,1-tnchloroclhano
MCL (mg/1)
0.002
0.005
0.005
0.005
0.005
0.007
0.075
0.200
To perform to these levels, a POU device will need to
be well designed and constructed.


AMWAY  DATA   ON  A   POU  WATER
TREATMENT SYSTEM
Amway  has  developed considerable data on  POU
water  treatment  system  performance. In  our
laboratories  we  have  been  working  heavily  on
evaluation and claims documentation for GAC-based
POU devices  for  the past five years  (6,7).  The
following data is from a unit containing  a unique
pressed carbon block  design.  Performance is  rated
on the  conservative position that the  only way  to
prove the filter's ability  to remove chemicals from
water throughout its rated life, is to test against every
chemical claimed.  Testing  is carried  out to  150
percent of rated  life to provide  an extra  margin  of
safety.  The  filter  is effective for removal of  116
compounds,  including  100  of  the  EPA priority
pollutants, plus several pesticides including aldicarb,
EDB and DBCP, fuel hydrocarbons, and others.

CHEMICAL CLASSIFICATION
In order to test that many compounds, they  were
placed  into chemically  similar  classes,  then  into
groups,  and then a group was tested together.  The
classes and groups (Table 5) are based on chemical
similarity and analytical technique. Some groups were
subdivided for easier analysis.

Table 5.  Chemical Classification
Class
1 . Acids
2. Base/Neutrals
3. Hydrocarbons
4. PBBs
5. PCBs
6. Pesticides
7. PNAs
8. Purgeables
Group
Phenols
a) Biphenyldiamines
b) Chlorinated Hydrocarbons
c) Cyclohexenone
d) Hatoethers
e) Nitro compounds
f) Phthalates
Gasoline/Kerosene/Diesel Fuel
PBBs
Aroclors
a) Halogenated Alkanes
b) Nitrogen/Phosphorous
c) Organochlorine
d) Organonitrogen
Polynuclear Aromatics
a) Aromatics
b) Halogenated Alkanes
c) Halogenated Alkenes
d) Trihalomethanes
Analytical
Method
EPA-625
HPLC-UVD
EPA-625
EPA-625
EPA-625
EPA-625
EPA-625
GC-FlD
HPLC-UVD
EPA-608
GC/ECD
GC/NPD
EPA-608
HPLC-UVD
HPLC-UVD
EPA-624
EPA-624
EPA-601
EPA-601
                                                   TEST PROTOCOL
                                                   The test protocol is similar to the GSRI and the NSF
                                                   test Protocol (6). All testing was  done on duplicate
                                                   devices. The main test stand  (Figure 2) provides
                                                   control of the critical parameters.  The  contaminants
                                                   are injected  under  control of an  HPLC pump. This
                                                48

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Figure 2. Main test stand.
            back-pressure adjustment
                         recirculation loop
     2OO gal.
                                      electrical valve


                                      mechanical valve
          jet pump
                                                                                           effluent
                                                                                           sampling
                                                                                           point
                        motionless mixer    Influent
                                           Sampling point
provides very consistent influent concentrations. The
flow is  controlled,  influent  and  effluent  samples
collected for every sample point, and the temperature
monitored. The test was  run  continuously  for eight
hours  per day  with  an overnight stagnation period.
Influent concentrations were generally chosen to be
approximately 100 to 200 \IQ/\.  Chloroform was higher
to approximate the NSF standard requirement.

RESULTS
The results are contained in  Tables  6 to 10.  The
trihalomethanes  group  shows  only  chloroform
breaking  through,  at a concentration  below 5  yg/l.
The halogenated alkanes were subdivided for testing.
The detection limit for 1,2-dibromoethane (EDB) was
reduced to 5 ng/l to accommodate states with limits
of 20  qg/l. The  detection of trichlorofluoromethane
and carbon tetrachloride  are  near detection limits.
The halogenated alkenes  include  trichloroethylene
and tetrachloroethylene,  common pollutants.  The
aromatics group includes benzene, which based on
Dobbs isotherm data (8) would be expected to break
through. Our data contradicts that expectation. The
other  aromatics  are removed.  The  chlorinated
hydrocarbons,  including  1,4-dichlorobenzene  are
removed as would be expected based on efficacy for
benzene.
These compounds provide a glimpse of the diversity
of chemical compounds  that can  be removed  by
GAG. The  difficulty  of completing  a  project of this
magnitude several times  forced a good  look at the
trends. The potential use of  a surrogate  for most of
the compounds tested appeared feasible although not
yet adequately  documented or accepted by the
scientific or regulatory community.

GRANULAR   ACTIVATED  CARBON  -
PERFORMANCE
THEORETICAL CONSIDERATIONS
A brief look at the basic principles of GAG adsorption
and some of the  molecular  properties  affecting
adsorbability  of  chemicals is  helpful.  Granular
activated carbon  has been demonstrated  to adsorb a
wide variety  of  organic  chemicals.  It  has limited
capacity for some classes of organic compounds, and
for water soluble ions and metals. Carbon  has  been
referred to as "black magic,"  but  this is  not  really
true. There  is a good base of information on how
GAG works (9,10,11). For a chemical to be adsorbed
onto carbon, the attractive  forces must be strong
enough to overcome repelling forces.  The forces of
attraction are generally agreed to be primarily due to
Van der Waals forces, which  are relatively weak. First
                                                 49

-------
Tablo 6.  Class: Purgeables - Group: Trihalomethanes
Compound
Chloroform
Bromodichloromethano
Oibromochloromethane
Bromform
Tablo 7. Class: Purgeables - Group:
Compound
1,2 Dichloroethane
1,1-DiclitorocUtans
1 ,1 ,2-Tnchtoroetriane
1,2-Dibfomooltiano (EDB)
1,1.1-Tnchtoroethane
1 ,2-DichlofOpropane
Trichlorolluoromelnane
1 ,1 ,2,2-Tetrachtoroelhane
1 ,2,3-Trichloropropane
Carbon TetrachtorWe
1 ,2'Dibromo-3-Chloropropane (DSCP)
Tablo 8. Class: Purgeables - Group:
Compound
1,2-Dicriloroethytene
(ftiris-1 ,2-OichloroGlriene
irans-1 ,3-Dichtoropropylone
Tnchtoroelhytene
1 , 1 ,2,2-Tolrachloroelhylene
Tablo 9. Class: Purgeables - Group:
Compound
Bonzono
Tduono
Chforobonzone
Xytono
EtliylborKeoa
Average Influent Effluent Effluent
(ug/l) @ 500 gal (ug/l) @ 750 gal (ug/l)
414 1.25 1.25
129
115 - -
204
Halogenated Alkanes
Average Influent Effluent Effluent
(ug/l) @ 500 gal (ug/l) @ 750 gal (ug/l)
112
120
164
59 " -
116
118
112 " 0.8
151
146 • -
78 " 0.2
258
Halogenated Alkenes
Average Influent Effluent Effluent
(ug/l) @ 500 gal (ug/l) @ 750 gal (ug/l)
109
96
170 * -
100
92
Aromatics
Average Influent Effluent Effluent'
(ug/l) @ 500 gal (ug/l) @ 750 gal (ug/l)
113
114
107
292
163
Detection Limit
(ug/l)
0.28
0.11
0.13
0.93

Detection Limit
(ug/l)
0.5
0.25
0.5
0.005
0.16
0.34
0.51
0.31,
2.7
0.22
0.09

Detection Limit
(ug/l)
0.17
0.11
0.14
0.28
0.27

Detection Limit
0.82
1.0
0.19
3.9
1.6
Total Loading
(mg)
1,253
366
327
580

Total Loading
(mg)
320
340
467
169
329
334
318
430
413
222
733

Total Loading
(mg)
309
272
482
284
262

Total Loading
(mg)
320
325
304
830
462
 * Indicates value below detection limit (99 percent Cl).
                                                            50

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Table 10. Class: Base/Neutrals - Group: Chlorinated Hydrocarbons
Average Influent Effluent Effluent
Compound (lig/l) @ 500 gal (ug/l) @ 750 gal (ug/l)
1,2 Dichlorobenzene
,3-Dichlorobenzene
1 ,4-Dichlorobenzene
Hexachloroethane
1 ,2,4-Trichlorobenzene
2-Chloronaphthalene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachlorobenzene
150 * -
184
120
111
313
109
154
58
66
Detection Limit
(ng/D
0.75
0.49
1.05
1.06
0.35
0.5
0.24
1.03
0.48
Total Loading
(mg)
429
526
342
318
313
110
444
171
192
 * Indicates value below detection limit (99 percent Cl).
the molecules must be brought close to the carbon
surface.  Particle  size  and design are  important to
minimize the  water thickness  around the  carbon
particles. Then the chemical must diffuse through the
boundary layer to the carbon surface. It must diffuse
into  the  pores,  until  it is tightly retained in the
micropore region of the GAG.  The kinetics of the
surface diffusion or pore diffusion are limiting steps.
Crittenden, Snoeyink,  and  Weber,  among  others,
have developed theories and applied them to explain
GAG behavior in  actual  use  (12-15). For  single
solute  models, predictions  work quite well.  When
multiple solutes are being adsorbed on GAG, there is
a  competition for  available  sites,  with  the  more
strongly  attracted  molecules displacing  the  more
weakly retained ones.  These competitive effects are
beginning to  be understood, such that  prediction of
orders of desorption and capacity can be made when
detailed  information is available on  the GAG  being
used. This is of great  value to a manufacturer when
designing  POU  devices and  selecting  a  carbon
source.  It  is  not  practical  for  evaluation  of many
different completed  units  due to the  detailed
information that must be  developed for  the GAG.
However,  the  principles will be important in
understanding results of dynamic testing.

It  is important to note that GAG is not a  generic
commodity. The source of the carbon  and how it is
prepared for  use provides a  range of capacities,
selectivities, and kinetics that must be evaluated.

Evaluation of GAG  includes numerous tests. Surface
area is  important  since adsorption is basically a
surface phenomena. The surface area  of carbon is
very high, generally in the range of 500 to 1,500 m2/g
(2,445,500 to 7,327,600 sq  ft/lb) mostly  in internal
pores  which  are like  a maze of  interconnecting
channels. Pores below 20 angstroms (7.87 x 10'8 in)
in  radius,  called  micropores,  are  where  most
adsorption  takes place with  larger  transition pores
from 20 to 500  angstroms (7.87 x 10-8 to 1.97 x
10-6 in)  providing access and some  additional
adsorption. Micropores over 500 angstroms (1.97 x
10'6 in) have little capacity for small molecules. The
distribution of pore sizes and the percentage in the
range of interest determine the actual performance of
carbon. A BET  nitrogen  surface area  measurement
provides a great deal of information on surface area
and  pore  size distribution.  Particle size and particle
size distribution  are also important influences in the
kinetics of adsorption.

Characterization  of carbon pores includes traditional
tests such as  iodine values, generally" agreed  to
measure small pores, with a pore radius of less than
20  angstroms (7.87  x 10-8 jn).  Carbons  may  have
iodine  values  of 600 to  1,200. Molasses number,
based on decolorization  of  molasses  solutions,
represents pore volume in the range of 20 to 500
angstroms (7.84 x  10-8 to  1.97  x 10-6  in).  Dye
adsorption,  such as methylene  blue,   provides
additional data on capacity for large molecules.

All of these measurements are useful for preliminary
evaluation of GAG,  but must be used  with caution
due to the  multiplicity of  interactions taking  place
under dynamic conditions.
APPLICABILITY
To determine whether GAG is applicable to removal
of a chemical, it is necessary to look at some of the
properties of the chemical  that affect its adsorption.
Removing a chemical from  water is easier if it is not
ve/y soluble  (Table  11). The  solubility  versus GAG
capacity for several  VOCs  (capacities expressed as
Freundlich adsorption isotherm values), shows a good
correlation  between  low  solubility  and  good
adsorption. While  the  capacity in mg/g  (Ib/lb) of
carbon may vary with carbon type, the relative order
of elution is predictable.

Other factors, such as the substitution of bromine for
chlorine increase adsorption,  as evidenced for the
THMs:
                                                  51

-------


CHCIs
CHC^Br
CHCIBr2
CHBrs


Adding chlorine to a molecule



CHCIa
CHCIs
CCI4
Benzene
1 ,4-Dichlorobenzene


Addition of double bonds to
adsorbability:



1,2-Dichloroethane
transl ,2-Dichloroethane


Capacity
X/MCo (5) 100 ug/l
3.05
5.9
10.3
17.0


increases adsorbability:
Capacity
X/MCo @ 100ua/l

0.45
3.05
9.78
13.47
196.4


a molecule increases


Capacity
X/MCo <5> 100 uq/l

2.88
8.32


Capacity
X/MCo @ 100 ug/l
CL CL
\ /
1,1,2-trichloroethylene C = C 25.17
/ \
CL H
Capacity
X/MCo @ 100 ug/l
CL CL
\ /
tetrachloroethylene C = C 122.9
/ \
CL CL



Table 11. Solubility vs. Capacity
Capacity
Compound Solubility® X/MCo @ 100
oompound 20<>c (mg/|) ^ (mg/g)
Methylene Chloride 18,236 0.454
1,2-Dichloroethane 8,690 2.88
Chloroform 8,000 3.05
1,1,1 -Trichloroethane 4,400 7.72
trans 1 ,2-Dichloroethylene 2,190 8.32
Benzene 1,780 13.47
Trichloroethylene 1,100 25.17
1 ,4-Dichlorobenzene 70 196.38
As several of the factors are considered, a significant
increase in capacity results:




CL
Chloroform CL - C -
1
CL






Capacity
X/MCo (5) 100 UQ/I


H 3.05



Capacity
X/MCo @ 100 ug/l


Based on capacity values obtained from Freundlich
adsorption isotherms, it is obvious why chloroform or
1,1,1-trichloroethane would break through first, and
why trichloroethylene and tetrachloroethylene did not
break through in GSRI or field studies.
CAPACITY
Activated carbon has a finite capacity for any one
compound. When multiple compounds occur, they
compete to some extent for the available sites on the
carbon, reducing the capacity for the less strongly
adsorbed compound. Estimating capacity involves a
number of considerations including:
 CL H

. - C - C - H    7.7
1,1,1-trichloroethane   CL-C-C-H    7.72

                        CL H
o Which chemicals are present?

• What is the concentration of each?

• What is  the maximum capacity of the carbon  for
  the chemicals?
• What  is  the  maximum effluent concentration
  allowed?
                       52

-------
• What are the kinetics of the compound with the
  carbon?

• What are possible competing materials?

• How  does the design  of the  POU device  affect
  adsorption?

• How is capacity to be expressed?
CRITERIA  TO  DESIGN AND EVALUATE
GAC-POU   DEVICES

There are basically two main criteria that determine
the efficacy of a GAC-based POU device:

• The  capacity  of  the  GAC  used (isotherm
  capacities),

• The design  of the final unit to approach maximum
  capacity (dynamic testing).

Capacity  of  the  carbon  is obviously  critical.
Performance cannot be achieved without a GAC that
has  a  significant  capacity for  the chemicals  of
concern.  One driving  interest  presently  is  the
category of VOCs as proposed by EPA. This group is
of special interest due to the difficulty of removal from
water.  It is a limiting factor in GAC performance. A
GAC  can  be  selected for  a POU  that provides a
maximum  adsorptive capacity  for  the smaller
molecular  weight VOC  compounds.  Generally,  this
comes  at the expense of  capacity for the  higher
molecular  weight compounds, but this is not the
limiting factor.

FREUNDLICH ADSORPTION ISOTHERMS
The capacity values used have been isotherm values
that are maximum values at an effluent concentration
of 100 ug/l. To discuss maximum theoretical capacity,
it  is  necessary to  bring in  batch  equilibrium
experiments,  referred  to as  Freundlich adsorption
isotherms  (11,16). Bottle point isotherms are run in a
series  of  bottles containing  different  amounts of
carbon, and a water solution of the chemical  (e.g. 1
to 2 mg/l of VOC).  The bottles are sealed and mixed
for  seven days, the  carbon  filtered out,  and the
concentration remaining  in the water measured. The
carbon  weights  and VOC  concentrations  must  be
adjusted to yield final solution concentration of 1 to
200  ug/l.  This allows calculation of  the quantity
adsorbed on the carbon, expressed as mg/g carbon.

The Freundlich equation is expressed as:

                  X/M  = KC1/N

Plotted as a straight line:

         Log(X/M)  =  Log K + (1/N) Log C
where,

  X/M = the amount  of component adsorbed  (mg/l)
        divided by the weight of carbon (g/l)

  C  = the  equilibrium concentration  of the
        component (mg/l  or ug/l)

  1/N = slope of  the  line for the component  in
        solution

  K  = Constant for each compound:
        (mg/g) x (l/mg)1/N Or (ng/g) x (l/ug)i/N

It must also  be  stated that to  compare  isotherm
behavior, the  chemicals must be grouped such that
the  similar molecules are  compared. The adsorption
isotherm curve, when plotted as the logarithm of both
sides of the equation, yields a straight line providing
significant information (Figure 3).  One can:

• Screen potential activated carbon samples for use.

• Provide an  estimate of the adsorption capacity of a
  component by activated carbon.

• Determine  if the desired effluent can be obtained
  with a given amount of activated carbon.

• Estimate the capacity difference when equilibrium
  concentrations are changed.

• Predict  the relative  breakthrough  order  of
  adsorbates  during  column studies  by comparing
  the capacity values obtained from isotherms.

From the isotherm of chloroform, one can  find the
capacity of that  carbon at  an  equilibrium
concentration of 100  ug/l, the current MCL for total
trihalomethanes.  This carbon could hold 3.05  mg
CHCIa/g carbon (0.003 Ib  CHCIa/lb carbon). One can
also readily  see  the  impact  of decreasing the
equilibrium concentration to 25 pg/l; capacity is now
1.29 mg/g  GAC  (0.0013 Ib/lb  GAC).  Reducing  it
further to 5 jig/I, the  MCL concentration for most of
the VOCs,  the capacity is now down  to 0.47 mg/g
GAC (0.0005 Ib/lb GAC).  These values may change
with  different carbons  or different operating
conditions.

Absolute  values for adsorption isotherms for the same
chemical can show  significant  variations between
published data, which may be due to any  one or a
combination of factors including the carbon  used,
pore size  distribution, particle size, the  time  to
equilibrium, the water  temperature,  pH, analytical
techniques,  and  the number  of  points  used  to
determine the line, among other factors. One factor is
the presence of hardness ions and TOC. The effects
of deionized  water versus  a municipal water were
investigated.   No   significant difference is  seen,
                                                 53

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however, the effects of temperature make a dramatic
difference in capacity (Figure 4).  As the water  gets
colder,  the  capacity of  the carbon  increases.
Temperature control, or at least measurement, is an
important element of capacity evaluation.

RELATIVE ISOTHERM VALUES
The real  value  in using  adsorption  isotherms for
predicting performance of a POD device is in using
the relative  capacities for related compounds. By
plotting the isotherms for related compounds  (Figure
5),  one can readily see  that a  unit that removes
chloroform to a  concentration of 5  ng/l  will  also
remove  1,1,1-trichloroethane, trichloroethylene,  and
1,4-dichlorobenzene. While  the  total  quantity  of
compound absorbed  may differ from unit to unit, the
relative capacities, or the order of breakthrough of the
compounds  will  remain the  same. These  general
observations were  made during the  Gulf  South
Research  Institute  study,  and also during  the
NSF/EPA studies at  Silverdale  and  Rockaway. A
review of the literature on isotherms supports the
relative ranking, although  absolute  values differ
(8,9,11,17,18).

Therefore, if one compound is chosen  as a model, or
surrogate compound, adsorption  for the other
compounds  is  rather certain.   By  selecting  the
concentration  of  the  model  compound,  e.g.
chloroform,  at  the  highest  level anticipated for a
known contaminant,  removal is assured for at  least
the rated capacity of  chloroform, and longer if the
compound is more tightly retained.

DYNAMIC TESTING AND ISOTHERM
CORRELATION
The gap between theory, that is maximum capacity as
determined by isotherm, and practice is a measure of
how well  a  POD device has been designed.  This is
done  by  dynamic testing. The isotherm capacity is
determined on the GAC under near ideal conditions.
The actual performance of the unit takes all factors
into consideration. The contact time  between water
and carbon  in POU devices is typically short, in the
order of seconds rather than minutes  for large scale
GAC  contactors.  Kinetics become  a factor in
selecting the carbon source. Since the active  sites in
GAC  are internal and  the pores very small, it takes
time for molecules to diffuse into  them. Design  must
take into  account the  pore  size distribution,  particle
size,  and particle size distribution.  As particle size
gets smaller, adsorption gets faster but backpressure
gets  higher  and flow rate  drops.  This may be a
limiting  factor.  The  chromatographic  effect, where
strongly adsorbed materials are retained at the  early
portion  of the bed,  reduces competition so  only
similar compounds  of similar capacity  compete  for
pores. The  mass transfer zone is created where the
first GAC contacted is loaded to its capacity first and
the concentration decreases through the bed until the
compound is completely removed. This  wavefront, or
mass transfer zone moves through  the  carbon bed
until the  compound .elutes. Either a long bed, or a
short mass  transfer  zone  is needed for optimum
performance. Again, this is an important criteria when
designing a unit to remove VOCs to below 5 ng/l.

Results of dynamic tests are shown for chloroform
well past the  point of  breakthrough (Figure  6). It
illustrates that  a  lot  of capacity  may be left after
breakthrough reaches 5 ug/l. The typical single solute
chloroform curve with an average influent of 108 pg/l
is  shown plus  a  typical chloroform curve at an
average influent of 442 ug/l. The capacity decreases
significantly  as  the influent concentration is  raised.
The multisolute curve  for  chloroform  at 102 vig/l
shows a  reduction  in  capacity but  not as severely as
the 442  ug/l curve.  The point of  breakthrough is
sooner as the  load on  the filter  increases,  but  the
difference is less at the low ug/l concentration. This
demonstrates that  competition can be accounted for
by  increased  challenge concentrations, and  the
multisolute  curve also demonstrates a  limited
competition  since  the total  challenge  greatly
exceeded the 442 ug/l level.

The effects of multisolute interactions can be seen in
Figure 7. Here, the chloroform curve can be seen in
relation to the other VOCs as part  of a 14 component
run. Seven  of  the VOCs are plotted  here.  This
illustrates the predictive power of relative isotherms
since the components of the multicomponent mixture
elute in the same relative order as that shown by the
isotherms summarized in Table 12.
In these cases,  testing capacity of  the POU device for
chloroform  would represent  a worst case. If
chloroform  is  removed, so too  is every  other
compound. If CHCIa testing for capacity  is done at a
level equalling  the  concentration of  any  single
component it could provide a minimum capacity of
the POU device.

FURTHER EVALUATION TECHNIQUES
The data from  dynamic studies  provides  practical
data, but limited to the specific chemicals tested.  The
use of isotherm data to predict elution orders lends
support to the surrogate  concept.  There are other
theoretical treatments that  lend further  confirmation
that the  practical behavior complies  with theory.  The
use of Polanyi liquid phase adsorption potential theory
deals  with the  energy  involved  in  the adsorption
process (10). From limited isotherm data  it is  possible
to  predict capacity for other related  compounds.
Further  theoretical  modelling  based on complex
computer  programs   can provide   predicted
performance for single solute or multisolute situations
to  compare to actual  dynamic  data.  Successful
prediction of performance for several of the  VOCs
confirms that  the basic theoretical treatments  are
correct.  Use   of minicolumns to predict  the
performance of  full  scale operations  has  great
advantages for  large  scale operations (19,20).  It  also
                                                 55

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                      PERFORMANCE AND APPLICATION OF RO SYSTEMS

                                          Donald T. Bray
                                    Desalination Systems, Inc.
                                       Escondido, CA 92025
BASIC CONCEPTS

Figure 1  shows  some basic concepts  related to
reverse osmosis (RO). On the top of the figure there
is a  scale in angstroms (A) and  pm. These are
referenced  to  the   pore  size  ranges of  the
membrane-filtration  business. An angstrom is about
the size  of a hydrogen atom (10-8  cm [3.87 x  10-9
in]) and a water molecule is around 2 A (7.9 x  10-9
in). The RO field is at the extreme lower end of the
pore size  range, and covers the range  1 to 5 A (3.94
x 10-9 to 2 x 10-8  in). Ultrafiltration (UF) covers the
range from about 10 A to about 1,000 A (3.9 x  10-8
to 3.9 x  10"6 in) micro  filtration from 0.1 to 1 pm
(3.9 x 10-6 to 3.9  x   10-5 jn) and  general filtration
above about 1 pm (3.9 x 10-5 jn). Other people  may
use slightly  different divisions.  My subsequent
discussions will be concerned with the RO range.

Also shown on Rgure 1 is an important concept: the
basic difference between  RO/UF devices and filtration
devices. RO/UF devices are separative devices;  they
take a feed stream  and separate it  into two parts  -
a product and a reject.  There is no accumulation
within the unit.  It can operate continually without
buildup. Filters, on the other hand are accumulators.
Particles are removed from the feed and accumulate
in the unit itself.  Hence,  the  filters have a finite life
and the characteristics of the product are continually
changing. A shut-off  provision  after  a  given
throughput is being  considered for accumulator  type
devices. Such a concept does not apply to separative
devices such as RO, and  a  different safeguard
approach needs to be taken here.

Rgure 2  shows a  highly stylized  rendering of the
surface  of cellulose acetate (CA). Note  the  long
roundish  particles of CA  with  various bumps
protruding. Actually the  CA molecules  are  much
longer relative to their diameter and of course are
more twisted and intertwined. One  might  represent
thin film  membranes (TFM) in somewhat  the same
fashion but more crooked and with occasional cross
links.  The spacing  between  molecules  might vary
from 0 to 5 A (0 to 2 x 10-8 in). The  molecules are
in rapid motion, vibrating several  thousand times  a
second so the spacings are continually changing.
Hence, we have  no pore size per se  in RO. Only
when we get to UF do we start having definable pore
sizes.  Also shown is a water molecule. It is moving
very fast, making  thousands of collisions per second,
and  under influence of a driving  force  (in this case
pressure), can  enter the spacings between the CA
molecules and diffuse through the network essentially
one  at a time. Also  shown is a Na+ ion surrounded
by a group of water molecules.  Water molecules,
being dipolar,  will attach themselves to the  +  charged
surface of the Na + ion forming a molecule several
times as large.  It  will move through the  lattice in the
same way as water.  However, it can't move nearly as
readily as water since it is much larger.  Hence, there
is, in effect, a separation of Na + and water molecules
with  the water  molecules going through  the
membrane and the Na+  accumulating on the surface
until  back diffusion through the laminar layer  to the
reject  stream  removes  it from  the unit. One  can
imagine that a virus would look like a huge boulder on
the surface. One  might also  note that the separation
efficiency of the membrane will vary with the shape of
the  molecule --  e.g.,  whether  rod-,  sheet-,  or
ball-shaped.  Basically,  however, the  larger  the
molecule,  the  better the rejection. The above is  a
simplistic picture. Surface  effects  such  as  the
electron structure of both membrane  and  diffusing
molecule also come into play, but the physical size
approach is a  good first approximation.


TYPES OF  SYSTEMS
Figure 3 lists  the three types of RO  point-of-use
(POU) systems in'use today. I should  note that all
use   a  spiral-wound  membrane  assembly
configuration. The first commercial  unit on the market
was  an  over-the-counter (OTC) type  made and
marketed by Culligan in 1965 to 1966. ft hung on the
wall  of the kitchen as  shown schematically in  Figure
4. The spiral-wound element and pressure vessel
were located  inside  the product storage tank. Note
locations of feed,  reject, overflow,  and product. This
unit  had several  drawbacks  and was never very
successful due in part  to installation  difficulties of
feed, reject, and  especially  the  gravity overflow.
                                                62

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Figure 1.  Reverse osmosmis - basic considerations.
            10
100
 1
                           1,000
                          	I
  1

10,000
  10

100,000
   I
                                                             100
                                                  1

                                                1,000
mm - milimeter

li - micron

A - angstrom
                                                                                  I
  RO
*	*
                    UF
          Separative Devices
     Feed
  Product
                   Reject
                                     MF
                                      Filtration
                                        Feed
         Accumulative Devices


                     *• Product
Figure 2.  CA membrane surface schematic.

                             Na+ ion
                                                                        Water Molecule
These early units had no post carbon filters so there
were some taste  problems. Also, the gravity flow  of
product from the spigot was replaced by air in the top
of the storage tank which introduced  dust particles
with each use, so the heterotrophic bacteria species
within the storage tank kept changing. Further, and in
hindsight, the marketing and selling techniques of RO
POL) still needed to be developed.

The next generation  of OTC units were counter-top
models that sat on the counter with feed connections
to the sink faucet, and drained directly into the sink.
                                 Figure 3.  Types of RO/POU systems.

                                         UTC    -     Under the Counter
                                         OTC    -     Over the Counter
                                         OU     -     Office Unit
                                 This eliminated the installation and overflow problems
                                 of the original, wall mounted unit but resulted in use
                                 of valuable counter space and retained the continued
                                 taste and contamination problem. The third generation
                                 of OTC, as shown in Figure 5 and made by Nimbus
                                                   63

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Figure 4. OTC concept.
                   FEED

                 REJECT

             OVER FLOW
 DOMESTIC WATER SUPPLY
Water Systems, is  of more recent vintage in  which
the unit is attached  directiy to the faucet with a quick
disconnect.  Reject  goes to the  sink;  product  to  a
collection bottle.  The  unit is  hooked  up at  night,
removed in the morning and stored in the refrigerator,
as is the product water container. It overcame  most
of the difficulties  encountered  in  the other two
approaches but adds the  inconvenience of hookup
and removal.

The second type of RO POD system developed was
the office unit (OU), the first  of which appeared in
1966. It was really an adaptation of the wall-mounted
unit  but utilizing  the  olla,  or water storage
compartment,  of the conventional  bottle water stands.
Most of the original limitations of the wall-mounted
unit  still applied,  but were offset to some extent by
increased revenues per  unit  (to  compensate for
installation costs), and use of a product level operated
shut-off valve  and post carbon filter. More recently,
there has been a  trend toward  use of pressurized
product storage  tanks, as  used in the  under-the-
counter (UTC) systems.

The  UTC was developed  in  1966 and  1967 in an
effort to  overcome  the limitations of the over-the-
counter and office units. Figure 6 shows the basics of
a UTC unit. All the components except the faucet are
located  under-the-sink.  Tap  water feed  under
pressure  enters  a  pressure vessel  containing a
spiral-wound  membrane element.  The reject flows
through a small capillary tube to drain. The pressure
is  reduced  from line pressure  at entrance  to
discharge pressure at outlet over the length  of the
capillary-  The amount  of reject is determined  by the
inside diameter and length of the capillary tubing. It is
generally set  at four to five times product flow  rate.
This ratio was  chosen based  on  field  experience.
Basically,  one can only take out that  percentage of
water until saturation of the least soluble component
occurs, which in San Diego, is calcium carbonate at
about 20  percent water removal. The product flows
                                                 64

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Figure 5.  Mint II - hang-on  unit.
out  of  element  into  a sealed  storage tank .at a
continuous but slow  rate (10 to 20  ml/min  [0.34 to
0.68 oz/min]). The tank has a rubber diaphragm  with
a low air pressure on one side (35 to 55 kPa [5  to 8
psi]  when tank contains no product water). As  the
product flows  into the tank, it moves the rubber
diaphragm down, compressing  the  air. When   the
faucet is opened the water is forced out of  the  tank
by the  compressed air to  point-of-use.

Some additional  accessories need to  be added to
make a working sytem, as shown in  Figure 7. A  post
carbon unit is placed in the product line between the
storage tank and faucet. It  serves  as a final polisher
to remove any tastes which were picked up  from the
tank material or  that  came through  the membrane.
There needs to be either a pressure relief valve on
product side or  a shut-off valve  on  the feed  line
operated by  tank pressure.  If a relief  valve is used, it
is generally set at about 1/2 line pressure. When the
tank pressure  reaches this point it  opens the relief
valve allowing the product to join the reject line.  The
unit  continues to operate  producing good  water --
it just goes down the drain. When water is drawn from
the  storage  tank and  the  pressure  is  reduced,  the
valve closes and good  quality product refills the tank.
Figures. UTC -  basics.
                                   /I f
                                      Point of Use
    RO
   Element
                                    iragm
    Pressure
    Vessel
                      Capillary Flow Control
      Feed       Reject
                                                   65

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Figure 7.  UTC - complete system.
                                                             Air Gap
                                                           Post Carbon
                                                             Polisher
                    J.
                                                                                Point of Use
      Foed
                                            i—i
                                         Pressure
                                          Relief
                                          Valve
                                                          Diaahragm
Product
                                                     Air
                         Sediment Filter
                                                   Storage
                                                    Tank
                              Reject
If a shut-off valve is used, it is located in  the feed
line, is operated by tank pressure, and is set at 1/2 to
2/3 line pressure. In many locations, a sediment filter
(25 pm) needs to be added. When a TFM is used, a
precarbon filter is also added to the feed line after the
sediment filter  to removal chlorine  (which damages
the polyamide TFM). The reject is shown flowing to
an air gap above the sink. This is needed to meet
plumbing codes requiring a positive break  between
the potable water and  the sewer -- i.e., an air gap.
The above UTC concept  was developed in 1967 and
is little changed to this  day. Essentially, all UTC units
made and in use today, utilize this concept.


USE DATA
Figure 8 shows my estimates of some key use data.
There  are  about  500,000 units  in use today.  Total
1987 income to manufacturers was between $15 and
25 million  from new units and about $20 million from
replacement parts and  elements, for a total  of about
$40 million per year. The total income to dealers and
distributors  was  $50 to 75   million from  new
placements and perhaps $20 million from rental or
leased units for a total of about $100 million per year.
The cost to consumers to rent or buy is also given in
the figure.  Note  that the  little  Mini  II hang-on
competes  very well in production  and quality, at a
much lower price. It was developed to bring lower
cost, good quality drinking water to the lower income
and elderly as replacement for store  or  vending
machine-purchased  drinking  water.  To  a large
extent, it has succeeded in doing so.
 MEMBRANE TYPE

 There are two types of membranes on  the  market
 today that account for essentially all the  membranes
 used in RO POU units. These are the CA types and
 the  TFM polyamide types.  I  have grouped  all the
 cellulosic base  membranes into  "CA Types."  This
 includes cellulose acetate, diacetate, blend, triacetate,
 and  cellulosic esters.  There  are  only  minor
 differences in their performance or limitations. Most of
 the  units in  the  field today  use  CA, but  the
 percentage of TFM  is increasing and perhaps half of
 the new units placed in 1987 were TFM. Figure 9 lists
 the characteristics of the two types.

 BACTERIA  - VIRUS
 No discussion of RO POU would be complete  without
 a comment on bacteria/virus. When referring to Figure
 2, I noted that viruses are huge compared  to the
 spacings between molecules. When the membrane is
 sound there is no leakage. Membranes today  can be
 made virtually  defect-free. However, current  POU
 systems cannot be sold as removing all bacteria and
 viruses for a few reasons. First, bypass leakage exists
 in all elements including the spiral-wound type.  This
 leakage historically has been on the order of 0.1  to
 0.5 percent; i.e., 0.1 to 0.5 percent of the product
 does not  go  through  the membrane  but through
 nonmembrane locations such as the glue lines, leaks,
 glue  area weepage,  O-ring leaks, etc.  Secondly,
 there is no readily  available fast  response fail-safe
 systems such as a  conductivity meter that tells us
                                                 66

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Figure 8. Miscellaneous data.
Item
Units Placed in 1987
Total Units in Use, end 1987
Manufacturer's Selling Price, $
Cost to Consumer, $ to buy
$/month to rent
Production, gpd
General Ionic, percent CR
General Inorganic Reduction
UTC
60,000-100,000
300,000-400,000
150-250
500-700
16-20
3-10
80-95
Varies
OTC
25,000-50,000
70,000-100,000
30-70
70-150
NA
3-6
85-97
Varies
OU
5,000-10,000
30,000-50,000
350-450
NA
25-40
6-15
80-95
Varies
Figure 9  Membrane types - comparison of merits.

                        CA Types   	
                                                TFM Polyamide Types
 Advantages
 Disadvantages
More experience
Low cost
Good ionic rejection
pH range limited to 3-8
Temperature limited (<100°F)
Subject to bacteria attack
Only fair organic rejection
High flows
High rejections
WidepH range (4-11)
High temperature (120°F)
Bacteria resistant
More expensive
Less experience
Needs carbon prefilter
Tendency to foul
Figure 10.   Nimbus N-3A - a 20-year service call record.

 Customer Months
 per Service Call
   25  r-
    5   -
                                                                              Records from Cal Pure
                                                                              San Diego, CA
                                                                              (based on local service calls)
      68
                 70
                           72
                                      74
                                                76
                                                           78
                                                                     80
                                                                               82
                                                                 84
                                                                                                    86
                                                     Year
when a unit fails as  regards bacteria/virus removal.
Therefore, for  these  two  reasons,  the  RO  POU
cannot warrant use on a nonpotable water supply. On
the other hand,  if I lived on a farm and had no readily
available potable source,  I would surely use  an RO
POU unit.

As shown in Figure 7, bacteria are always present in
the product part of  the system. They are  introduced
                                 during installation from  dust particles in the  air,  from
                                 handling, etc. They will build up to a semi  steady
                                 state  population  depending  on amount  of  use,
                                 temperature,  species,  amount of organics  present,
                                 etc. Dr.  Lee Rozelle, in his article in this publication,
                                 refer to the July 1987 standard setting a heterotrophic
                                 plate count of  500/ml or  less.  This  number  was
                                 related to the ability to  accurately test for E. coli and
                                 not the health aspects of heterotrophic bacteria in the
                                                      67

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drinking  water. Several years ago, I  tested  several
hundred RO POU systems in the San Diego area.  I
also tested bottled water cabinet model drinking units.
Essentially,  none  complied  with  this  criteria. If this
regulation were to be  enforced  across the board
today, it would destroy the RO POU industry. In fact,
the only unit on the market today that would meet this
criteria is the nonstorage system;  i.e., the hang-on
faucet unit. I would  suggest a  look  at developing
different  analytical techniques for  determination  of E.
co//  in the presence of other bacteria, if this is the
limitation.

Progress  has  been made  over the  years  in the
technical service area. I would like to  share with you
the record of  one dealer  - Cal Pure in San Diego.
Rgure 10 shows the service call record for the last 20
years  for the  Nimbus N-3A model. This data is  for
several  thousand  rental units.  I use  customer-
months per service call as the criteria of excellence.
This is the average number of months a customer's
unit is  in  operation  between  all  service  calls
regardless  of  nature of the  call. The  original design
objective was  12 customer months per service call.
As you can  see, it started  at around six and gradually
increased to a current level of about 22. If the unit is
owned by the customer rather  than rented, the
customer months per service call tend to be several
months longer. This  is a remarkable performance
record for a unit that is generally installed by unskilled
labor, operates unattended for long periods of  time,
retains a constant reject flow of very small magnitude,
and  has check valves that  seal  under "1" water
pressure over these time periods. I might  note that
the dips in the curve were the result of minor system
design changes. One must be very careful  of design
changes in these systems. If we plotted the cartridge
life in San Diego instead of customer months against
years,  it would add about 10  months  to the vertical
part of this curve.


CONCLUSIONS
• RO  POU is a relatively old concept ~  going  on
  20 years. It has been slow in developing but has
  picked up speed in the last few  years. There are
  around 500,000  units in  use in the U.S. today.

• The economic value in 1987 was about $40 million
  to the system manufacturers and $100  million to
  the dealers and distributors.

* The challenge  of the  immediate  future  in  the
  nonhealth-related areas for RO POU is marketing,
  sales,  and service.  We have   satisfactory
  membranes to cover the needs, and the technical
  aspects are sufficiently in hand.
                                                 68

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            PERFORMANCE AND APPLICATION OF ULTRAVIOLET LIGHT SYSTEMS
                                            Clyde Foust
                                        Ideal Horizons Inc.
                                        Rutland, VTOS701
INTRODUCTION

The increasing  demand  for  high  quality water,
combined with the  reduction in  quality  of  available
water sources,  has  caused  an upsurge in water
treatment technology.  Ultraviolet  (UV)  light as  a
disinfectant was first discovered  in  1847 and  first
commercially  applied in 1901. The effectiveness of
UV as a preferential  microbiological treatment should
be  evident in its choice as the disinfectant in over
2,000 cities in Europe. Ultraviolet light accomplishes
this without using harmful chemicals, some  of which
when used can lead  to the formation  of  harmful
secondary  chemical   products,  such   as
trihalomethanes.  Ultraviolet  light does not impart any
taste  or odor nor  is it possible to  overtreat water
using this  method.  Properly designed units cannot
expose  users to any harmful products. The  effect of
no  measurable residual disinfectant in the water has
been  well studied in Europe and found  to be of no
concern. Maintenance  of  these  systems is usually
limited to annual servicing.

Most  of the  commercially  available units  use  low
pressure mercury  vapor lamps.  Operationally  and
mechanically, these  lamps are very similar to the
fluorescent lighting  with which we are  all  familiar.
Most  units are quite simple in principle because the
mercury vapor  bulb  in conjunction  with a  pressure
reaction chamber is  all that is required.  However, in
application,  the  units  are  considerably more
complicated.  The commercially available units must
also be fitted with  monitors,  flow  controllers,  and
other operational equipment.  To  treat  water  with
ultraviolet light, the  three  parameters necessary to
consider are the organism, dosage, and unit design.


ORGANISMS
The UV spectrum in this article refers to the spectrum
between 200 and 300 nm (7.87 x  10-6 and 1.18 x
10-5 jp). AS  a  point of reference, the entire visible
spectrum is 380 to 700 nm (1.5 x 10-5  in to 2.76 x
1Q-5 in) with the major spectrals between  450 and
600 nm (1.77 x 10-5 jn  and 2.36 x 10-5  in)  The
inactivation  of  organisms  occurs  through
photophysical damage imparted to  the  DNA by the
UV light. The low pressure mercury vapor light emits
most of its energy centered about 254 nm (1 x 10"5
in). This allows  a high  efficiency because  the
germicidal  action  curve  for  most  organisms is
centered  at  about  260 nm (1.02 x 10-5 in).  Since
this high  energy wavelength is readily  absorbed by
DNA,  RNA,  protein, and enzymes  a single photon
strike affects most organisms.

Most common pathogenic microorganisms have been
tested for their sensitivity to UV light, and the results
have been  published in  various publications. £.  coli
will be reduced to a 0.0001 survival  ratio, if treated in
most commercially available units. Giardia lamblia has
a  survival  ratio of 0.1  with  twice  the treatment
available in most commercial units.

The  sensitivity of  organisms is  determined  by
bioassay  methods. Care  should be exercised when
using the data, because  some results are achieved
using various wavelengths for inactivation. Data using
wavelengths other than 254 nm (1 x 10"5 in) may be
used with corrections allowed for effectiveness.


DOSAGE
Photophysical  damage  is time  dependent with
organisms dying in a constant fraction with increasing
increments of time. This is expressed as the survival
ratio. The survival ratio  when  plotted  on  semilog
paper is a straight line. The implications of this effect
are reflected in the sizing of  the  unit  and will be
discussed later. Temperature effect on this process is
negligible. The main factor in  sizing  is  UV dosage.
The. recommended dosage is  at least 16,000 yW-
s/cm2  (103,200 nW-s/sq in) based upon an HEW
1966 policy statement. Presently, most manufacturers
treat with a dosage of 30 to 35,000 iiW-s/cm2 (190
to 225,800 pW-s/psi).  These dosage  rates  are
capable of  a four-log reduction, which  means  that
incoming water would be effectively 99.99 percent
treated. Applying these numbers to the effluent of a
well designed and well  run sewage treatment plant
would result in the treated water meeting the £. coli
standard for drinking water.
                                                 69

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UNIT DESIGN
Application of the available technology is quite simple
and easily quantified. Most commercial units  are
designed  to  operate  when supplied with water  that
meets a  known  specification.  As with all drinking
water supplies,  the water supply must  meet  EPA
nonbiologic standards.

Additionally, the turbidity should be less than 10 NTU.
The  turbidity,   while  not  directly  measuring
transmission  in the wavelengths under examination, is
indicative  of  transmission. The two most commonly
found UV  absorbers are iron and tanin.

Most units  presently  available  are  similar in
construction  as  far  as basics. They  consist of a
cylindrical reaction  chamber with the bulb  mounted
along the  center axis allowing water to flow parallel to
the bulb. The bulb is separated from the water by a
quartz sleeve. To maintain  proper  treatment levels,
some type  of flow  control device  is  necessary.
Beyond these basics  some type of monitoring and/or
shut-off mechanism  is  required.  The minimum
protection would be a visible light metering device to
cause an  alarm  or effect a shut-down in the failure
mode. Utilization of the visible spectrum light for  this
purpose  is  possible  because the  low pressure
mercury discharge tubes emit some of their energy in
the visible range. Obviously, this  device will  not
protect against all modes of failure but is sufficient for
most applications. The next level of protection may be
achieved  by using  a  light sensing device  that
measures  only light in the UV sterilization range,  and
has absolutely no response in any other range.  This
more  sophisticated  unit should  be  provided  with
appropriate time delays and may be slaved to  any
alarm or shut-down device.
APPLICATION
Most waters that do not meet the specifications can
be preconditioned to acceptable levels. However, the
minimum preconditioning  required  is a  5-um
(0.0002-in) prefilter.  This is necessary to  insure
most  particles are removed  that  could allow the
organism's penumbral or umbral shading.

Start-up  and  maintenance of these  units  is  quite
simple.  After  installation  and  any breach  of the
system, the downstream piping  should be sterilized.
Normally the unit  requires annual servicing,  which
consists of cleaning the parts and replacing the bulb.

The NSF presently has no standards  concerning UV
water purification.  Under their proposed Standard 55,
UV equipment will be accepted for the NSF seal. The
proposed  standard is  in its first testing  stages and
should be established in a relatively short time.
                                                 70

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  PRECOAT CARBON FILTERS AS BARRIERS TO INCIDENTAL MICROBIAL CONTAMINATION
                         P. Regunathan, W. H. Beauman, and D. J. Jarog
                                           Everpure, Inc.
                                        Westmont, IL 60559
The  microbiological  characteristics of  point-of-use
(POD) filters  have been a source of concern in the
minds of many in the regulatory, utility, and academic
fields.  These concerns have  centered  around  the
possible growth  of bacteria in  various POL) devices,
particularly carbon filters, and  the probable effect of
such growths on the health of  the consuming public.
It is the objective of this article to investigate the role
of a POU  precoat carbon filter as a final barrier to
microbial  contamination  that  may   otherwise
inadvertently  reach the-consumer. A schematic  view
of such a possible role in the  overall route of water
from source to  use is  shown in  Figure 1, giving the
various acknowledged  barriers that are  traditionally
depended upon  to provide  safe water to  the
consumer. In this article, a POU fine-filtering precoat
carbon filter  has been  specifically examined as  an
added or  final barrier to different types  of microbial
contaminants.

POU  precoat filters belong to  a family of POU  fine-
filtering devices  that  includes, besides precoat filters,
carbon  block filters  made from powdered  carbon,
ceramic  filters  manufactured  with  controlled fine
pores, pleated membrane filters with absolute ratings,
and  reverse  osmosis membrane systems.  All these
devices are usually rated as capable of filtering down
to 1 urn (0.00004 in)  or less.

Figure 2 shows a schematic view of a precoat carbon
filter where the water enters from the top through an
inlet tube and rubber check valve into the bottom of
the filter, making the  dry powdered media there into a
slurry, which is  then evenly deposited  as a precoat
layer  on the surface of a folded septum envelope.
During operation, water intermittently enters the unit,
filters  through  the precoat cake  and  the septum
fabrics, travels through the drainage  grids that are
inside the septum envelope, and reaches the outlet of
the filter. Precoat filter media in precoat carbon filters
include mostly  powdered activated  carbon. Table 1
shows the significance of a precoat carbon filter as a
barrier for different types of contaminants. While there
are  some specific  barrier benefits  for organic,
inorganic,  and  particulate  contaminants, this article
focuses  on microbial  contaminants, which  can  be
properly divided into bacterial pathogens (coliforms as
indicators),  viruses, protozoan cysts or surrogates,
and  heterotrophic  bacteria. In addition, the use of
silver and,  in  some tests  copper also, has  been
studied as bacteriostats in precoat carbon filters.


COLIFORM REMOVAL
A test was set up to  compare the abilities of  filters
with  or  without  silver  or  copper in removing and
inhibiting coliforms. Two standard  precoat carbon
filters, two  containing  copper powder added to  the
filter media, and two containing  silver plated onto a
powder and added to the media, were plumbed  into a
test  module.  The influent water  was softened,
dechlorinated,  and fine-filtered Westmont tap  water
to which  a  nutrient-deprived  suspension   of
Enterobacter  aerogenes  (ATCC 15038) had  been
added  by  a  pump just before  the  module. The
choices  of  organism,  water pretreatment, and  other
precautions in culture preparation and transfer were
designed to promote maximum coliform survival.

All six units were operated at  a 0.06-l/s  (1.0-gpm)
flow  rate, with a 30 seconds  ON-30 seconds OFF
cycle for eight hours  per day, for  several days to
simulate the condition  of used filters being subjected
to accidental contamination. After 3,785  I (1,000  gal)
had  passed  through  each  filter,  samples  were
regularly collected just before and after overnight  and
weekend quiescent periods. All the data  collected
along with  detailed procedures have been reported
elsewhere  (1).  Results  are  shown graphically in
Figures 3 through 6.

Influent  coliform levels increased  from  about
10,000/100 ml (2,960/oz) to more than  100,000/100
ml  (29,600/oz) due to  improvements  in technique.
Effluent levels  in  standard filters  (Figure  3)  were
approximately  99  percent lower. Both  influent  and
effluent  levels generally decreased  during  overnight
and  weekend  quiescent periods. Filters with copper
(Figure  4)  allowed higher running coliform  levels in
the effluents than standard filters,  probably due to
disruption of the  precoat cake  by  heavy metallic
copper  powder, but copper  reduced  these  levels
                                                 71

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 Figure 1.  Barriers to contamination.
                                     Infiltration
                                      through
                                   river banks, etc.
                        Source
                       Protection
                                                                Treatment Plant
                                                     Pre-
                                                  Dlslnfectlon I
H      Coagulation I           I
         &   I— Filtration —I
       Settling |  I      I [
  IPost-
Dlslnfectlon
                                                                   Clear Well
                                                                     8
                                                                Distribution System
                                                                  Management
                                                                       C—*"
                       to User
Figure 2. Prccoat filter design.

                        Sect A-A
                                  Filter Media
                                  when dry
                                                                      Exploded View of
                                                                      Septum Envelope
                                                                      In Operation
                                                                   Drainage
                                                                  ' Grids
                                                                 When powdered
                                                                 carbon is included in the
                                                                 filter media, then it is a
                                                                 precoat carbon filter.
significantly  during quiescent periods.  Silver-
containing filters  (Figure  5) generally reduced the
coliform levels similar to  standard filters, but further
exhibited significant inhibitory effect  during  quiescent
periods. Averaged levels (Figure 6), show the relative
capabilities of these filters with filters containing silver
showing a further 1/2-to-1  log  reduction compared
to the other filters.


VIRUS REMOVAL
Standard precoat  carbon  filters  without  any
bacteriostats have been recently evaluated for their
ability to remove  viruses using a protocol developed
by a U.S. EPA-Army task force (2). Virus reduction
requirements  (along  with  bacterial  and  cyst
reductions) for a unit to achieve purifier status have
been determined by the task force to be  a minimum
of four-log  reduction  of a  mixture  of  107  plaque
forming units  (PFU) of poliovirus 1 and  107 PFU of
rotavirus Wa or SA-11  per liter  (0.26 x  107 PFU of
poliovirus 1  and 0.26 x  107 PFU of rotavirus Wa or
SA-11 per gallon).

This  test  on  the filters  was  conducted  at  the
Department of Microbiology and Immunology of the
University of Arizona, Tuscon  (3).  Three  filters were
tested as per  protocol (2),  plumbed into a test rig
served by large tanks, a pump, bladder tank, solenoid
valves and timer set to  operate  on a cycle of three
                                                    72

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Table 1.  Significance of Contaminant Reduction
 Type of Contaminant
 Significance of Precoat Carbon
      Filter As a Barrier
 Organics
  Taste and Odor-Causing
   Organics
  Volatile Organics

 Other Health-Related Trace
   Organics
 Inorganics

 Particulates
  Turbidity, etc.
 Microbiological
  Bacterial Pathogens or
   indicators
  Viruses
  Protozoan Cysts
  Heterotrophic Plate Count
Significant, but may not be
 health related
Not high enough capacity, low
 amount of carbon
May be significant

Generally no removal, unless
heavy metal in precipitated form


Significant as a barrier

May be significant enough barrier

May be significant enough barrier
May be significant enough barrier
minutes ON and 27 minutes OFF for eight hours per
day.  Influent  (control)  and all  three  effluents were
sampled seven times as per the protocol and were
assayed for PFU. Complete details of procedure and
results have been reported elsewhere  (1,3). Table 2
shows the results of this test.

Influent levels shown in the  table  indicate that the
high  challenge levels of 107  PFU/I  (0.26  x 10?
PFU/gal) were not achieved  in this  effort. In spite of
this  flaw,  the precoat carbon filters appear to have
reduced the virus concentrations of  10^ to 1Q6 PFU/I
(0.26 x 104 to o.26 x 106 PFU/gal) in the influent to a
range of <10 to 104/1 (<2.6 to 0.26 x 104/gal). This
reduction  of approximately 99 percent is significant,
even though  these  filters  cannot  be  said to have
achieved  the  four-log reduction required for  purifier
status. Further efforts are underway to better define
the capabilities in this area.

PROTOZOAN   CYST   SURROGATE
REMOVAL
Protozoan cysts, being inert and having no capacity
for movement or reproduction, can  be  treated  as
particles that  can be removed by filters at the point-
of-use. There is evidence  to  support  the  use  of
surrogate particles  in  lieu of live  cysts in filtration
tests.

National Sanitation Foundation (NSF) Standard 53 (4)
has  detailed  procedures  for  Cyst  and Turbidity
Reduction, and requires a filter to reduce particles in
the range of 4 to 6  urn (0.00016 to 0.00024 in) by at
least 99.9 percent  throughout the  life of the filters.
These  procedures  were followed  to  test standard
precoat carbon  filters  without  any bacteriostats for
their ability to remove such surrogates.

Two filters were installed in a test rig with a system of
solenoid valves and a timer set to  operate the  units
for  1.5 minutes ON  and 13.5 minutes OFF for 16
hours per day, feeding Westmont tap water at 60 psig
fortified with fine test dust to 20 to 30 NTU.  Samples
were taken  at start-up and  at  morning start-up  after
the overnight quiescent periods when the initial flow
rate had been  reduced by  filter  plugging to 75, 50,
and 25  percent.  Samples  were  analyzed with a
particle counter with one channel set to record 4- to
6-um  (0.00016- to  0.00024-in)  particles.

Results in Table 3 show the filters to be effective in
removing the 4-  to 6-um  (0.00016-  to  0.00024-
in)  particles. The  filters  improve in efficacy  as  they
become plugged  up with  fine  dust as  would be
expected of precoat filters.

The size of 4 to 6 um (0.00016 to 0.00024 in) was
chosen  by  NSF with amoebic  and giardial cysts,
which  are two to three times larger, in mind. There
has been some concern about an inadequate factor
of safety in relation  to Cryptosporidium cysts, which
are also 4 to 6 um (0.00016 to 0.00024 in)  (5).  New
data  have  been  gathered recently  in the   NSF
laboratories using  a submicron  detector.   The
procedure  used  in  this  test  is  the  Paniculate
Reduction test described in NSF Standard 42  (6),
which  is similar to  the earlier test. Differences include
the use of 10  minutes ON and  10  minutes  OFF
cycles, collection of samples at the beginning and at
morning start-up after the buildup of pressure  drop
to 277 kPa (40 psi) across the filters, and the analysis
with submicron detector of several size ranges.

Results  in  Table  4  show  the abilities of  filters to
remove  0.5 um (2 x 10"5 in) particles by more than
99.9 percent, indicating the  ability of these  filters to
remove all cysts, including Cryptosporidium cysts.

EFFECT   ON   HETEROTROPHIC
BACTERIA
Scientific studies have addressed concerns regarding
heterotrophic bacterial  growth  in  POU   devices,
notably two funded  by U.S. EPA. One studied  and
quantified the growth in POU products (7,8), and the
other  studied the epidemiologic correlation   of  such
growth with  illness  (9).  Conclusions from  these as
well as other studies can be summarized to say that
average increases in bacterial  populations in  the
effluents of POU  units  compared to influent levels
were around one order of magnitude, but exposure to
such  higher densities was not statistically correlated
with  any increase in acute  symptoms, either
gastrointestinal  or  dermatologic,  compared  to
exposure to unfiltered water.

These studies and results, however, have not abated
the concerns expressed by many  (10-12). In  this
study, further tests have been conducted to provide
additional information on the growth of heterotrophic
plate count  (HPC) organisms in precoat carbon filters
                                                    73

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Table 2.   Virus Removal Tests

               Plaque-Forming Units/Liter*
                                          Average
Time (days)
1
3
6
7
8
10
10
(stagnant)
Influent
717,000
230,000
203,000
257,000
60,000
53,300
13,000
Unit #1
4,200
2,100
330
670
<10
<10
<10
Unit #2 Unit #3
9,000 1,400
6,100 3,300
330 <10
<10 <10
<10 <10
<10 <10
< 10 <10
(percent)
99.32
98.33
99.89
99.91
> 99.98
> 99.92
> 99.92
 * Average of triplicates.
Table 3.   NSF Cyst Reduction Test
Flow
Reduction
(percent)
0
25
50
75
No. of 4-6 urn
Particles/mr
Influent
76,492
158,140
348,223
212,783
Unit#1
76
128
35
20
Unit #2
60
92
40
19
Average Reduction
(percent)**
Unitn
99.90
99.92
99.99
99.99
Unit.#2
99.92
99.94
99.99
99.99
  * Average of triplicates.
  ** Minimum required for acceptance by NSF: 99.9 percent.
Table 4.  NSF Filtration Efficiency Test

Startup



After
40 psig
Ap

Particle
Size
(nm)
0.5-1
1-5
5-15
15-30
0.5-1
1-5
5-15
15-30
Unit #1
Influent
Counts*
282,165
32,595
395
5
357,930
58,640
625
10
Counts*
117
23
1
0
21
2
0
0
%
Red.
99.96
99.93
NS
NS
99.99
99.99
NS
NS
Unit #2
Counts*
245
26
1
0
261
7
0
0
%
Red.
99.91
99.92
NS
NS
99.92
99.99
NS
NS
   * Average of triplicates.
 NS - Influent challenge insufficient for significance.
incubation temperature, and  time  to  the  researcher,
but requires the  conditions to be spelled out along
with the  results.  The more  commonly  utilized
conditions appear to  be R2A  medium,  incubation
temperature of 28°C (82°F),  and  incubation time of
seven  days.  The number and type of  organisms
enumerated under  these conditions  appear to  be
significantly higher and different from those obtained
by SPC procedures.  This factor was investigated in
this study also.                              ;  '
                                               !,
In conjunction with  the  coliform removal studies
discussed earlier, SPC data also were collected in the
same  samples that  were analyzed  for  coliforms.
Figure 7  shows  all  the  results  of the  analyses
indicating no  concrete conclusions, except that
generally the softened, carbon filtered influent waters
had  higher counts  than the  filter  effluents and  that
silver  or  copper did  not  have  any measurable
inhibitory effect on these bacterial levels.
                                                      Figure 7.
           HPC organism in various precoat carbon filter
           effluents.
                                                       S 10.000. ,
                                                       <
                                                                                          Effluent* from Filters

                                                                                         itJndjfd
                                                                                Running  •
                                                                                Ovtrnlgnl 0
                                                                                     Q
                                                            1,000   t.ZOO
                                                                                 l.*oo    1.COO

                                                                             Volume Filtered. Gal
and the  effect of  bacteriostats, specifically silver, on
such growths.

It  is important  to point  out the differences  in  the
presently  used   methodologies   used  in  HPC
procedures. In earlier Standard  Methods  (13), plate
count organisms were termed Standard Plate Count
(SPG)  organisms,  and the  procedures  required  the
use of  plate  count  agar  with   an  incubation
temperature of  35 °C (95 °F) and incubation  time of
two days. Many of the earlier important  studies used
this methodology. The  most recent edition  of
Standard Methods (14) leaves the choice  of  media,
A more  recent test  was  conducted  using  the
Bacteriostatic  Test  Procedures  protocol  in  NSF
Standard  42 (6). Complete details of test procedures
can be found elsewhere (1,6).  Two  standard precoat
carbon filters and  two  similar filters with  silvered
powder added to the filter media were simultaneously
tested using three different types of waters.  Solenoid
valves and timers  were set to  operate on a cycle  of
three minutes ON and 27 minutes OFF for 16 hours
per day. The test was continued for 6670 I (1,762 gal)
filtered through each unit at an operating  pressure  of
415 kPa (60 Ib/psi) as required in the test  procedures.
The results are shown in Table 5.  These SPC data
                                                   75

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Tablo S.
NSF Bacteriostatic Test Data
                                                                             Heterotrophic Plate Counts/mr
Walcr Filtered
(gal)
0
0
1
22
73
319
740
980
1.220
1.220
1.460
1,722
1,762
Type oi Water
Quality"
Regular
Regular
Regular
Low
High
Regular
Regular
Regular
Regular
Regular
Regular
High
Low
Duration of Quiescence Just
Priot to Sampling-Hour
0
60
0
8
8
8
8
8
0
60
8
8
8
Filters w/o Silver
Influent
12
35,000
42
9,000
4,400
1,900
3,900
240
11
23,000
135
11,000
3,200
Unit #1
-
-
2
600
530
1,300
97
36
19
3,500
46
69
1,400
Unit #2
-
-
<1
1
<1
6
11
1
<1
3
<1
<1
430
Filters w/Silver"*
Unit #1
-
-
1
1
1
5
1
1
1
15
1
1
330
Unit #2
-
-
<1
<1
<1 •
1
<1
<1
<1
1
<1
<1
4
     RoQlrfar  -  200-600 ppm TDS, 7.2 + 0.5 pH.
     Low     -  25-100 ppm TDS, 6.2 ±0.5 pH.
     High     -  > 800 ppm TDS, 9.5 ± 0.5 pH.
     Duplicate analyses. 35°C, 48 hr.
     Effluent silver;  1-3 ppb.
indicated that both the units without silver, as well as
those with silver were bacteriostatic filters, according
to NSF Standard  (6) requirements. Silver, however,
does seem  to  provide  some extra assurance  and
capability in providing fairly low counts in the effluents
of both units, while one of the two units without silver
had significantly higher counts than its duplicate unit.

During July 1987 a comprehensive test program  was
initiated  t&  study the  growth  of  SPC  and HPC
organisms in standard precoat carbon filters  with or
without silver as a bacteriostat, and in granular carbon
bed  units. The following were the  pertinent factors
controlled or used in the tests:

•  Three of  each type  of  unit  (standard, w/silver,
   granular) with two influent locations.
•  0.03 l/s (0.5 gpm) through each filter and each
   influent port.
•  Westmont municipal water as supplied.
   Total chlorine content in running samples = 1.0 to
   1.5 mg/I (1.0 to  1.5 ppm)
   Free chlorine content in running samples  = trace
   levels.

•  Three minutes  ON, 27 minutes OFF, eight hours
   per day only during working days.

*  Sampling
   -  Monday AM  at  start-up
   - Wednesday PM during running
   -  Thursday AM at start-up
   -  Friday PM during running
                                           • 1 / (0.26 gal)  sample  (£ minute  run)  collected.
                                             Bacteriological sample from this into sterile bottle
                                             with Chambers' neutralizing  solution.  (Influent
                                             samples always taken before filter effluents.)

                                           • Only R2A medium used in the beginning.  Started
                                             with pour plates, switched to spread plates. Started
                                             with 25°C (77°F) for five days, changed to 28°C
                                             (82°F), seven days.

                                           • Tests started 7/17/87.

                                           • Plate  count Agar, incubation  at 35 °C (95 °F) for
                                             two days routinely  used  from 9/2/87  for  SPC
                                             measurements.

                                           HPC data  collected using R2A media for the influent
                                           samples and the three sets of effluent samples are
                                           graphically shown in Figures 8 through 11. Arithmetic
                                           means of all these separate sets of  data have  been
                                           calculated  and are shown in Table 6. Comparison  of
                                           the data in these figures and table would indicate that
                                           the  use  of silver in precoat carbon  filters  results  in
                                           maintaining the organism  levels at or below the
                                           influent levels for the different types of samples, i.e.,
                                           running,  overnight, and weekend samples. Running
                                           and overnight quiescent  samples  from  standard
                                           precoat carbon filters without silver appear to have 1
                                           to  1-1/2 orders  of magnitude  higher HPC  counts
                                           than influent samples or the effluent samples  from
                                           units with silver.  Granular carbon filter  effluents
                                           yielded generally  1-1/2  orders  of  magnitude higher
                                           counts than influent waters or  precoat units  with
                                           silver, when  running  or  overnight samples were
                                                   76

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     £

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 «   5   i

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-------
compared. Weekend quiescent samples from influent
ports and  granular carbon filters were in the same
order of  magnitude,  while  precoat  units with or
without silver generally yielded 50  percent lower
numbers.
Tablo 6.  Comparison  of Bacteriological Data, Arithmetic
         Mean HPC*, CFU/ml
             Influent
Silver
Standard    Granular
Running
Overnight
Weekend
194
2,510
75,700
260
1,870
27,600
7,040
20,900
37.300
8,730
44,700
87,200
 " R2A media, 25-28'C, 5-7 days.
Table 7.  Comparison of Bacteriological Data, Arithmetic
         Mean SPC*. CFU/ml
             Influent
Silver
Standard    Granular
Running
Overnight
Weekend
33
444
26,700
47
332
7,350 '
23
515
7,240
1,050
4,180
22,600
 * SPC: Pour Plates, 35°C. 2 days.
SPC  data  collected using  plate count  agar  (35 °C
[95°FJ, two  days) for  similar units  are graphically
shown in Figures 12 through 15. Arithmetic mean
values for the separate  sets of data  have  been
calculated and are shown in Table 7. Examination of
these values shows  different conclusions from those
reached  using HPC  data. Unlike earlier  tests, these
data show that precoat filter  units with  and without
silver yield organism counts equal to or lower than
influents  when running water,  overnight quiescent, or
weekend quiescent samples are compared between
themselves. Only granular carbon bed units yield 1 to
1-1/2 orders  of magnitude higher counts in running
and overnight quiescent samples.

Table  8  shows the  direct comparison of  HPC and
SPC  data from  all  the  samples for  which both
analyses were performed. This comparison confirms
earlier stated observations and conclusions. Further, it
shows that R2A media at 28 °C (82 °F) for seven days
yields 1/2 to  1-1/2 orders  of  magnitude higher
counts than those obtained  using plate count agar at
35°C (95°F) for  two days.  The regulatory efforts to
control these organisms at a particular level need to
consider these huge differences in  values obtained
from identical samples.

These comparisons indicate that silver when used in
precoat  carbon  filters  has a  selective effect  on
organisms. Earlier coliform removal tests  showed that
silver  had a measurable  effect on Enterobacter
aerogenes. Silver also  seems to  have a significant
effect on those organisms that grow in R2A media at
28 °C (82 °F),  while it has  no measurable effect on
those organisms  that grow in plate count  agar at
35°C (95°F). Efforts to identify these selective effects
were  not successful, because many of  the colonies
on  the  plates could not be  identified. The  few
identifiable organisms  shown in Table 9  did not yield
enough  useful information. Further efforts are needed
in this area of activity.


CONCLUSIONS
On  the  basis of this study, the following conclusions
can be reached:

• Data  presented show significant and consistent
  reductions by these precoat filters of  coliforms (~
  99 percent), enteric  viruses (~99 percent),  and
  protozoan cyst/surrogates (>99.9 percent).

• Silver in  precoat  carbon filters  lowers coliform
  levels at  least 1  log  more  than the standard
  precoat filters.  Silver .and copper act slowly to
  reduce  coliform levels  in  filters  during non-use
  periods.

« The decision to use R2A agar at 25 to 28 °C (77 to
  82 °F) for  seven day incubation procedures instead
  of SPC agar pour plates at 35 °C (95 °F) for two
  days  is not  trivial.  Not only does the new HPC
  procedure yield 1/2 to 1-1/2 logs higher counts, it
  also favors a different population and thus can  lead
  to different overall conclusions.

» Silver appears to  effectively control. the  filter
  effluent HPC levels that are found growing  in  R2A
  media incubated at 25  to  28 °C (77 to  82 °F).
  Proper comparisons of all data indicated silver as
  bacteriostatic in precoat carbon filters.

• Precoat filters with or without silver appear  to act
  as  barriers  to  incidental  microbial contamination
  because they do confer some measurable level of
  protection  against   incidental   microbial
  contamination of potable  water  supplies that are
  normally safe.


ACKNOWLEDGEMENT
The authors thank Charles Ferrara for producing the
illustrative and  graphic figures, Robert  Gonzalez for
collecting and assembling data, and Pam Menefee for
producing the manuscript.
                                                  78

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Table 8. Direct Comparison of SPC vs. R2A, Arithmetic Mean, CFU/ml

Influent
Running 33
Overnight 444
Weekend 86,700
SPC: Pour Plates, 35°C, 2 days
Silver Standard Granular
47 23 1,050
332 515 4,180
7.350 7,240 22,600
Table 9. Documented Organisms 7.
Influent Standard Silver Granular
Psoudomonas
acidovrans
lutoola
paucimobilis
vcsiculans
slutzori
copacia
I'uofcscons
maltoi
Flavobacterium spp.
Agrobacterium
radiobactcr
Acliromobaclcr spp.

X X
X X X X 8.
X X X X
X X X X
XX X
X x
X
X X X X
XXX
x
HPC: R2A Spread Plates, 25-28 °C, 5-7 days
Influent Silver Standard Granular
331 497 4,880 8,050
3,410 3,130 29,200 60,200
108,000 46,700 34,900 126,000
Criteria and Standards Division, Office of Drinking
Water, U.S. EPA. Fact sheet/update, home water
treatment units contract. July 1980.

Bell, F. A., Perry, D. C., Smith, J. K. and Lynch,
S. C. Studies on home treatment systems.
JAWWA 76:2, 126-130, February 1984.
Calderon, R. L. An epidemiological study on the
bacteria colonizing granular activated carbon
point-of-use filters. In Press: Proceedings of
the Water Quality Association Annual
Conventions. Dallas, TX, March 1987.
Geldreich, E. E. et al. Bacterial colonization of
REFERENCES
1.  Regunathan,   P.  and  Beauman,  W.   H.
    Microbiological  characteristics  of  point-of-use
    precoat carbon filters. JAWWA, 79:10:67, October
    1987.

2.  Gerba,  C. P.  and  Thurman,  R.  Towards
    developing standard  procedures  for testing
    microbiological water purifiers. Proceedings of the
    Third  Conference  on Progress  in Chemical
    Disinfection. Binghamton, NY, April 1986.

3.  Gerba,  C. P. and  Kutz,  S.  M. Evaluation  of
    Everpure 4C cartridge filters for virus removal.
    Unpublished report,  University  of  Arizona,
    Tucson,  May 1987.

4.  National  Sanitation  Foundation. Standard  53:
    drinking  water treatment units  - health effects.
    Ann Arbor, Ml, Rev. June 1982.

5.  Culotta,  N. J. Personal communication. National
    Sanitation Foundation, Ann Arbor, Ml, March  27
    1987.

6.  National  Sanitation  Foundation. Standard  42:
    drinking  water  treatment units  ~ aesthetic
    effects. Ann Arbor, Ml, Rev. June 1982.
   point-of-use  water  treatment devices.  JAWWA
   77:2,  72-80, February  1985.

11. Reasoner,  D.  J,  et  al.  Microbiological
   characteristics of  third-faucet  point-of-use
   devices. JAWWA, 79:10:60, October 1987.

12. Fed. Reg. 50:219, November 13, 1985.

13. Standard methods for  the  examination  of water
   and  wastewater.  APHA,  AWWA, and WPCF.
   Washington, D.C. (15th ed., 1980).

14. Standard methods for  the  examination  of water
   and  wastewater.  APHA,  AWWA, and WPCF.
   Washington, D.C. (16th ed., 1985).
                                               80

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      MICROBIOLOGICAL STUDIES OF GRANULAR ACTIVATED CARBON POINT-OF-USE
                                            SYSTEMS
                                       Donald J. Reasoner
                                Drinking Water Research Division
                            Water Engineering Research Laboratory
                             U.S. Environmental Protection Agency
                                      Cincinnati, OH 45268
INTRODUCTION

Activated carbon, powdered (PAG) or granular (GAG),
has been used in  water treatment for  many years,
primarily to remove tastes and odors. During the past
15 to 20 years, the availability and sales  of small PAC
and  GAG filter  units,  or  point-of-use  (POD)
treatment units, have increased steadily. Much of the
increased demand  for these  units has resulted  from
consumer concerns  over  the  quality of  the water
supplied  by local water utilities. These concerns are
stimulated by  national and  local news  reports  of
organic  and inorganic chemicals in drinking water,
health risks due to long-term ingestion  of potentially
carcinogenic compounds in drinking water, taste and
odor problems in  the local water supply, and other
problems of  treatment and/or  distribution. Other
factors  contributing  to  the use of POU  devices
Include  lack of a  centrally  treated  water supply,
contaminated  ground water supplies,  and ground
water  supplies   containing  naturally  high
concentrations of iron, sulfur, nitrates, or fluorides. An
aspect of GAG POU treatment devices that has  been
of concern to the Drinking Water Research Division,
Water Engineering Research  Laboratory,  U.S.  EPA,
Cincinnati is the long-term microbiological quality of
the product water from such devices.

The  first  phase of studies  on the microbiological
characteristics of carbon POU filters was begun in our
laboratories in 1977.  This phase examined  four
carbon POU filters for variations in bacterial counts,
heterotrophic plate count (HPC), total organic carbon
(TOG),  and chloroform  (CHCIs) levels. In  addition,
one filter was  installed on a low-flow drinking water
fountain, and bacteriological quality and  THM content
of the product water were monitored weekly.  HPC
levels in the  effluents from  the carbon filters  were
always higher than the bacterial levels of the influent
tap water. One of the  test filters had consistently
higher HPC levels than the other three test filters, and
morning  samples generally had higher HPC levels
than  did those in  the afternoon. Free-chlorine
removal for the test carbon filters ranged from about
53 to 65 percent in one run, and 77 to 97 percent in a
second run. Total organic carbon  removal appeared
to be  minimal because influent  TOG levels were
always less than 2 mg/l (2 ppm) and effluent levels
were within 0.1  to  0.3 mg/l  (0.1 to 0.3 ppm) of the
influent levels one day after filter  installation. Two to
four weeks later, effluent levels were  essentially the
same. Chloroform removal effectiveness was directly
related to the amount of carbon in the filter. The initial
percentage  removal  of CHCIa  ranged from 100
percent down to about  55  percent, and decreased
with time over a period of 20 weeks.  By the end of
the  20-week   test  period,   effluent  CHC|3
concentration for three of the test filters exceeded
influent  CHCIa concentration, while the  fourth filter
unit was still removing about 20 percent  of  the
influent
The  second phase examined  four additional GAG
POU filters designed  to  be installed  as stationary
filters under a kitchen sink on the cold water line to a
common mixing faucet. This study examined the HPC
of the  product water from  the POU  filters and  the
potential  colonization of  the test  filters  when
challenged  by  pure culture  suspensions  of
opportunistic and frank bacterial pathogens that might
contaminate  a potable water supply.  This  phase of
the POU study was reported by Geldreich et al.  (1).
Variations in HPC levels in the product water between
morning and afternoon samples from the test filters
were similar to those found during  the  first  phase
study.  Additionally,  it was shown that  stagnation
periods from several hours to several weeks resulted
in significantly increased HPC levels in the test filters.
The  HPC levels  in the  product water could  be
reduced after a stagnation period by simply flushing
the units  thoroughly at  full-flow for two  to three
minutes before using the water.

The  potential for colonization of the test filter units
was, examined by using pure culture suspensions of
Serratia marcescens,  Pseudomonas aeruginosa,
                                                81

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Enterobacter cloacae,  Enterobacter aerogenes,
Escherichia coli, Citrobacter freundii, and Salmonella
typhimurium. £ coli, S. typhimurium, and £ cloacae
did not colonize the filters  and were not detected in
the  product  water  after the initial  sample.  S.
marcescens, P. aeruginosa,  £ aerogenes, and  C.
freundii persisted and were found in the product water
from some or all of the test filters for periods of time
ranging from five days for C.  freundii to 156 days for
S. marcescens and P. aeruginosa.
In addition to following the HPC levels of the  POU
filter units and challenging them with the organisms
above, new filter cartridges were installed, disinfected,
and  the product water monitored for  12 months for
HPC  bacteria.  Bacterial cultures were  periodically
isolated, purified, and identified*The organisms found
during this 12-month period  included C. freundii,  E.
aerogenes, £ cloacae, K. pneumoniae, Alcaligenes
spp., Pseudomonas  cepacia,  P.  fluorescens,  P.
maltophila, S. marcescens, and S. rubidaea. Not  all
of these organisms  were isolated from each of the
filter  units  at  the  same  sampling time,  and no
individual unit yielded isolates of all of the organisms.
Only £ cloacae, Alcaligenes  spp., and P. maltophila
were found  in all the units at some time during the
12-month period,  and none of the  isolates  was
found to be continuously present. Since the POU test
set-up had been disinfected prior to the beginning of
this  12-month study,  the organisms  isolated must
have  been present in the  treated distribution  water
influent to the test system, and were able to survive
and  multiply  to  some extent  in  the  POU filter
cartidges.

The  third phase  of  the  GAG  point-of-use study,
currently  nearing  completion, was  designed  to
examine GAG POU treatment  units  intended to be
installed as  third-faucet units, thus  treating  only
water for drinking  and cooking, not all of the water
going to the main  kitchen faucet. Seven test units
were selected for  this phase. The  test set-up
configuration from the previous two study phases was
retained, but the plumbing was modified to accept the
additional  three test  units. Partial  results from this
phase were reported earlier as technical conference
presentations and  appeared in  the October issue  of
the  Journal of  the  American  Water Works
Association. HPC results from this phase of the POU
study showed several types of variation. POU product
water HPC levels  varied depending on the time  of
sample collection  (morning  versus  afternoon).
Generally, the  afternoon samples contained fewer
HPC bacteria than did the morning samples,  reflecting
the effect of  flushing on wash-out of bacteria during
the daytime simulated use periods. The magnitude of
the difference beween morning and  afternoon HPC
levels varied among the test units. Examination of the
variation in  the  monthly mean  HPG  indicated that
there was no single pattern of HPC results for all the
test units other than the changes that occurred with
flushing between the morning  and afternoon samples.
Some of the variation in HPC monthly means may be
attributed to  the combined  influence of  seasonal
changes  in  water  temperature and changes in
disinfectant residual. HPC levels for  some test  units
clearly decreased as water  temperature decreased
from  September  through December. Peaks in  HPC
levels usually occurred in July, August, or September,
corresponding to peak water temperatures.

Some HPC variation may reflect the influence of unit
design, volume of GAG in the cartridge, and possibly
the material used in the construction  of the cartridge
holder and the  cartridge  itself. Metal  cartridge
housings may contribute to more rapid equilibration of
the water and GAG within those units to  ambient
room temperature  during  nonflow  periods.  Any
increase  in  water and  GAG cartridge temperature
would result in increased growth  of  bacteria on the
GAG, resulting in higher HPC levels in the product
water.

The bacterial  flora  (HPC)  of the dechlorinated tap
water influent to the test  POU units  reflected the
contribution of the GAG dechlorinating filter. This filter
served to remove free chlorine from the  distribution
water and seeded  the  dechlorinated  water  with
bacteria.  Thus,  reasonable worst case  conditions
were  set up  for the tests (i.e., no free  chlorine
residual  and  HPC  levels greater than the treated
distribution  water).  The  mean  HPC  of   the
dechlorinated tap water was generally lower than that
of the water from the best of the POU test units.  POU
test units that included silver as a bacteriostatic agent
were  found to  have HPC levels as  variable as the
nonbacteriostatic  POU test units.  The bacterial  flora
of the bacteriostatic units appeared  to be  different,
both  in colony appearance and  variety,  from  the
bacterial flora of the nonbacteriostatic  POU units. The
silver served as  a selective agent,  allowing silver-
tolerant bacterial strains to grow.

All of the POU test units modified the percentage of
pigmented bacteria  found in the  product  water, as
compared to  the percentage of pigmented  bacteria
found in  the  dechlorinated tapwater. Generally, the
percentage of pigmented bacteria present  in water
from the  bacteriostatic POU test units was lower than
that  of  the   nonbacteriostatic  test units.  The
dechlorinated  tap water usually contained more  than
50  percent  pigmented  bacteria,  whereas   the
pigmented bacterial  content of the  water from  the
POU  units ranged  from  less than  four percent to
about 40 percent depending on whether the samples
were taken in  the morning or afternoon. Old filters (on
line for  several  months) tended  to  show  relatively
stable HPC and pigmented bacterial  levels, whereas
newly installed filters had low initial  HPC levels that
rapidly increased during the first two  to three weeks
of use, and became fairly stable thereafter.

Challenges of test  POU filter units with  specific
bacterial pathogens  (Klebsiella  pneumoniae,
                                                 82

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Aeromonas hydrophila, and  V. enterocolitica) during
this  third  phase  study  showed  that  only  K.
pneumoniae colonized the test filters for an extended
period  of time (2).  Aeromonas hydrophila colonized
the POU filters during a warm water (20° C, October
1984)  experiment but not  during a cooler water
(12°C, February  1986)  period. Recently,  challenge
experiments  with  Leg/one/fa pneumophila  were
concluded. The results of these experiments indicated
that L. pneumophila apparently did not colonize the
POU test filters.  However, recovery methodology for
L. pneumophila is not efficient and lacks sensitivity at
low cell concentrations, and it cannot be stated with
certainty  that this organism  will not colonize GAG
POU treatment units. Cool or cold water temperatures
and the presence of any disinfectant residual (total
chlorine residual) in the water  probably mitigate
against colonization  by this organism.

The general implications of the studies conducted in
our laboratory, as well as other published studies, are
that all GAG  POU  devices  become generators of
bacteria due to the large surface area exposed to the
water,  and  due  to  adsorption of  nutrients from the
water  that  bacteria are able to  use for  growth.
However, the potential  for  adverse  human  health
effects from  ingestion of  large  numbers  of HPC
bacteria in  water appears: to  be low.  To date, there
have been  no verified  reports of waterborne illness
resulting  from consumption of  contaminated water
from GAG or other POU treatment devices.

Practical  recommendations  for users of home POU
treatment devices are as follows:

•  Use the  POU  device  only on  a microbiologically
   safe  water   supply,   unless  specifically
   recommended by the manufacturer for other
   applications as well.

•  Prior to  using the product water  from the POU
   device after a prolonged  quiescent period (several
   hours or overnight), run the water to waste for 30
   seconds or longer at full flow.  Longer flushing is
   desirable after a prolonged nonuse period such as
   a vacation.

«  Change the filter  cartridge(s) at least as frequently
   as   recommended  by  the  manufacturer,  or
   preferably more often.

«  Adhere  to the   manufacturer's maintenance
   recommendations and  specific instructions relative
   to changing the filter cartridge(s).
REFERENCES

1. Geldreich, E. E., Taylor, R. H. Blannon, J. C. and
  Reasoner,  D.  J.  Bacterial colonization  of point-
  of-use water treatment  devices. JAWWA.  77:72-
  80, 1985.

2. Reasoner, D. J., Blannon, J. C. and Geldreich, E.
  E.  Microbiological findings  with  point-of-use,
  third faucet devices. JAWWA. 79, October 1987.
                                                 83

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                   HEALTH STUDIES OF AEROBIC HETEROTROPHIC BACTERIA
                    COLONIZING GRANULAR ACTIVATED CARBON SYSTEMS
                                          Alfred P. Dufpur
                              Toxicology and Microbiology Division
                               Health Effects Research Laboratory
                              U.S. Environmental Protection Agency
                                       Cincinnati, OH 45268
Aerobic heterotrophic bacteria are ubiquitous in the
aquatic environment. Since surface waters frequently
serve as a source for potable water, it is not unusual
to find members of this large heterogeneous group in
drinking  water.  The  types   and  species  of
heterotrophic bacteria found in drinking water  have
been described by various  authors and, in general,
the organisms  are gram negative, nonspore-forming
bacilli. The second column of Table 1 is a composite
list of bacteria isolated from raw and treated drinking
water. This list is for comparison  purposes only, and
does not represent  all  those  heterotrophic bacteria
that are indigenous to drinking  water distribution
systems. These bacteria occur in drinking water at
densities as  high as  several hundred thousand per
milliliter in some cases, and they  provide a constant
seed for devices used to treat potable water at  its
point-of-use. Granular  activated carbon  (GAG)
filters,  in this regard, are of special interest because
of their increased use by the general population and
because they have the capacity  to adsorb bacteria
from water. Once adsorbed on the GAG filter, the
bacteria are able to multiply to even higher densities
than observed in the influent water and they, in turn,
slough off  into the effluent water. The genera and
types of bacteria found on  GAG  filters  are listed in
column 3 of  Table 1, and it is obvious from this list
that the bacteria  isolated  from  filters reflect the
distribution  of bacteria  observed  in drinking  water
systems. Gram  negative  bacteria are  predominant,
just as in the water distribution systems. The density
of bacteria  observed in GAG filter effluents has  been
in the hundreds of thousands, and this  frequently
represents  an increase of many  magnitudes above
the density of  heterotrophic bacteria in the influent
water.

The amplification of heterotrophic bacteria by  GAG
filters has caused some concern  that these bacteria
may pose a health risk to water users. The reason for
this concern  is the  infrequent observation that some
of the heterotrophic bacteria isolated from drinking
water and GAG filter effluents have been associated
Table 1.  Bacterial Isolates Associated with Raw and Treated
        Potable Water, Granular Activated Carbon Filters,
        and Nosocomial Infections

                      Source of Bacterial Isolates
Raw/Treated
Potable Water
Bacterial Type (Ref. 1,2)
Acinetobacter
Aeromonas
Alcaligenes
Citrobacter
Enterobacter
Klebsiella
Moraxella
Pseudomonas
Serratia
Flavobacterium
Staphyloccus
Bacillus
Achromobacter
X
X
X
X
X
X
X
X
X
X
X
X

Granular
Activated
Carbon (Ref. 2)
X

X
X
X
X
X
X

X
X


. Nosocomial
Infection
(Ref. 3-8)
X




X

X
X
X


X
with nosocomial or hospital associated infections and
illnesses. The fourth column of Table 1 is a partial list
of the types of bacteria causing infection  and illness
under hospital  conditions, and which were thought to
be due to contact with  drinking  water.  The water
source,  in most cases, was  some type of amplifier,
which increased the densities of the organism in  the
water that was linked to the  patient's  illness  or
infection.  The  amplifiers  were varied and  included
devices such as humidifiers (3,4),  dialysis machines,
disinfectant bottles, and water reservoirs for pediatric
isolettes (7). The  infections ranged from  septicemia
to pneumonia to peritonitis and, in  some cases, have
been fatal. In most, if not all,  of the cases  the normal
body defense  mechanisms of the patient had been
compromised in some way. The bacterial isolates in
column 4 of Table 1 were obtained from patients who
suffered from  diabetes (5),  bronchitis (6),  had just
                                                 84

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 undergone  open-heart surgery (8), or were on a
 regimen of steroid therapy (4). The patients in two
 cases, were  infants whose immunological  systems
 had not yet matured (3,7). The linkage of nosocomial
 infections to drinking water has been instrumental in
 part  in promoting the concern  about heterotrophic
 bacteria  in  drinking  water and GAC filters.  The
 conclusions  drawn from  nosocomial infections  may,
 however, be very misleading in that they  do  not
 address  the fact that the  patients  were  usually
 compromised in some manner. Infections of this  type
 are usually caused by bacteria that are  avirulent or
 have limited virulence,  and   which  seize  the
 opportunity  offered  by  weakened   defense
 mechanisms  to  inflict damage to  the host. These
 bacteria are called opportunistic pathogens, and  they
 seldom cause illness  in healthy individuals. Although
 the  available  evidence  indicating  that  healthy
 individuals are not at risk from these bacteria appears
 to be strong, there is no empirical data supporting this
 conclusion.   Since the  Environmental  Protection
 Agency (EPA)  may be  placed  in the  position  of
• recommending GAC filters as an alternative  form of
 water  treatment for removing  organic  chemical
 hazards present in drinking water, it is necessary to
 know whether or not that hazard is being replaced by
 another (i.e., heterotrophic bacteria amplified by the
 filter). An epidemiological  study  conducted by  Yale
 University was supported  by the  EPA  in  order to
 determine if  adverse health  effects  are  associated
 with GAC filter use. The results of the Yale study are
 reviewed here to characterize the risks observed in
 healthy  populations  exposed  to  water treated  with
 point-of-use  GAC filters  (9,10).

 The  study  was  conducted at a  large  military
 reservation  in eastern  Connecticut.  Families  with
 children were recruited  for the study from the large
 residental population  of 800  families  at  this naval
 base. A military base population was considered  ideal
 because the study participants had easy access to
 cost-free medical care.  This factor  was critical  since
 a  laboratory  workup  of clinical  specimens obtained
 from  participants  was a requirement for each illness
 or infection where an individual consulted a physician.

 The health  reporting  aspect  of  the study  used  two
 approaches.  The  first approach  used the calendar
 system. Each participating family in this system was
 given a health status calendar form on which  they
 could fill in, on  a daily  basis,  their  health status.
 Symptomatology, such as vomiting, nausea, diarrhea,
 high temperature, skin infections, and rashes, as well
 as visits to a doctor were recorded. This was usually
 done by the mother of  the  family or some  other
 responsible  adult.  The  calendars  were  usually
 collected every  two weeks so that any participants
 who  failed to keep the  calendar  up-to-date could
 be questioned and  their  previous two-week health
 status recorded. The  second  approach  involved
 instructing  each  participating family  to  go to  their
medical facility if  they  experienced gastrointestinal
illness or skin infections!  When a gastrointestinal
illness or skin infection resulted in a clinical bacterial
isolate, the filter associated with the individual from
whom the  isolate  was obtained  would be  replaced
with a new filter and the old GAC filter bed would be
analyzed to determine if a bacterial specie could be
isolated that would match the clinical isolate.

Two types of filters were used in the study. One was
a faucet-type filter that attaches to the tap with a
special adapter. The filter  was activated by turning a
valve  that directed  the water through the GAC  bed.
The second  type  of filter  was a  bypass-type  that
tapped directly to  the cold  water line and delivered
the water through a separate tap attached to the sink.
The source of the  water serving the study population
was the Groton, Connecticut city water supply.  The
water is  obtained  from the Great Brook watershed,
and it is  sand filtered  before being  sent  into the
distribution system.

Two  bacteriological media were  used to assay the
water samples during  the, course  of  the study.
Aerobic  heterotrophs  were  enumerated  using
Standard Plate Count agar (11) and the R2A medium
of Reasoner  and Geldreich (12). A  summary of the
results of the bacterial monitoring is shown in Table
2.

 It is immediately apparent that the R2A agar detected
much higher  densities of  heterotrophic bacteria  than
the Standard Plate  Count  agar. This observation has
been  noted  by others,  and it is thought to occur
because the  two media detect different parts of the
distribution of heterotrophic bacteria.  One other
interesting  result of the monitoring  is the high initial
densities  of  heterotrophs  observed  in  the water
samples  taken from  the  faucet  filter housing units
without carbon. The cause of these high densities is
unknown. It is possible that the  housing  units were
contaminated before installation, however, this effect
did not show  up  in filters with carbon  beds.  The
greatest exposure to heterotrophic bacteria occurred
with the bypass filters. The exposure to heterotrophic
bacteria was, on the average, about 20 times greater
for bypass-filter  users   than  for  control  groups
exposed to  heterotrophic  bacteria  in unfiltered tap
water. The  faucet-type  filter effluents  contained
about 12 times more heterotrophs than were found in
the tap water. However,  the heterotrophic bacterial
densities  in  the  bypass  and faucet-filter  effluents
exceeded that of the blank filter housing  units by
factors of only six and  four, respectively.  Thus, the
exposure  differences were not as  great  when the
faucet housing only  group was used as a control
population, as was the case in this study. The means
of  the heterotroph  densities of  both  the faucet-type
and  bypass-type filters were statistically  significant
from  the mean density of heterotrophs observed in
the blank housing unit effluents.
                                                   85

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Table 2.  Comparison of Bacteria! Densities in Tap Water and GAC Filter Effluents on Standard Plate Count Agar and R2A Agar

                              	  Geometric Mean of Heterotrophic Bacteria" (Ref. 10)	
 Filler Type
SPC Agar
 * Numbers In parentheses indicates number of samples analyzed.
R2A Agar

Bypass
Faucet
Faucet Housing (no carbon)
Tap Water
Initial
0.2 (62)
6.0(10)
85.0 (43)
6.0 (215)
Subsequent
1049 (722)
689 (559)
198 (486)
53(1,776)
Initial
0.4
9.0
98.0
11.0
Subsequent
2,042
1,035
289
92
During the course of the study only a few individuals
reported to the  medical  facility for  treatment.  No
bacterial  specimens  were obtained  from  these
patients and,  therefore, no relationship between
clinical  isolates and isolates from  GAC  could be
established.

A summary of the data collected using the calendar
questionnaire  system  is  shown in Table 3.  This
system  serves  a two-fold  function.  First,  it  may
detect excess  illness  in filter  users  that  might not
have  been  observed clinically and,  second, it  may
detect a decrease in illness  among filter users, if the
filters adsorb  potential nonbacterial  pathogens  that
might occur in the source water. The data in the table
is given in terms of  the  number of  symptomatic
illnesses that occurred per thousand  person years of
filter usage. The total person years of usage was 230
for  the faucet-type filters and 181 for those that did
not use filters. The  data were analyzed statistically,
and no  significant differences in the  rates  of
symptomatic illnesses  were observed  between  the
two user groups and the control group. Thus, even
with the questionnaire data, it could not be shown that
excess  illness  could be linked  to the  use of GAC
filters. Conversely, there was no evidence that the
illness rate was lowered in GAC filter users.
TabloS.   Comparison of Symptomatic Gl  Illness  Rates
         Observed in Study Groups Using  GAC Point-of-
         Use Filters and a Control Group

                     Symptomatic Illness Rate/1,000
                    Person-Years in Groups (Ref. 10)
Symplon
vomiting
Nausea
Diarrhea
Fovor
Body Aches
Skin Rash
Infoctod Wound
Bypass Fifter
32
45
59
58
46
13
1
Faucet Filter
36
51
76
47
46
12
3
None
33
49
74
62
55
10
3
The conclusion that can be drawn from the results of
the  Yale  study  is that  point-of-use  granular
         activated  carbon  treated  water  containing  high
         densities of heterotrophic bacteria is not a risk factor
         for healthy populations.

         The Environmental Protection  Agency  is supporting
         further research on the use of GAC filters and  health
         effects which will be conducted by Yale University.
         The research reviewed here addressed exposure to
         high  densities  of heterotrophic bacteria via  the
         ingestion  route.  Point-of-entry  type  filters  add  a
         new dimension to potential exposures since all  of the
         water entering a  home  is  treated. Amplified
         heterotrophic bacterial densities can be disseminated
         in  aerosols from showerheads  and,  subsequently,
         carried into the body  via the respiratory route. The
         results of  the  continuing study  may  provide  some
         information on the etiology of respiratory illness in the
         United States.


         REFERENCES
         1.  LeChevallier, M. W., Seidler,  R. J.  and Evans, T.
            M. Enumeration and characterization of standard
            plate count bacteria in chlorinated and raw water
            samples. Appl. Environ. Microbiol. 40:922, 1980.

         2.  Parsons, F. Microbial flora of granular  activated
            carbon  columns  used  in  water treatment. In:
            Wood,  P. R., Jackson,  D.  F., Gervers,  J. A.,
            Waddell,  D.  H.  and  Kaplan, L.,  Removing
            Potential Organic  Carcinogens from  Drinking
            Water, Vol.  I. Appendix A,  U.S.  Environmental
            Protection  Agency,  EPA-600/2-80-130a,
            Cincinnati, OH, 1980.

         3.  Foley,  J. F., Gravelle, C.  R., Englehard,  W.  E.
            and  Chin, T. D.'Y. Achromobacter Septicemia -
            fatalities in  prematures. Amer.  J.  Dis.  Children.
            101:279, 1961.

         4.  Smith,  P.  W. and Massanari,  R. M.  Room
            humidifers  as  a  source  of Acinetobacter
            infections. J. Amer. Med. Assoc. 237:795, 1977.

         5.  Berkleman,  R. L.,  Godley,  J., Weber,  J.  A.,
            Anderson, R.  L.,  Lerner, A.  M., Peterson, N. J.
            and Allen, J. R. Pseudomonas cepacia peritonitis
            associated  with  contamination  of automatic
                                                  86

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    peritoneal dialysis machines. Ann.  Int. Med.
    96:456, 1982.

6.   Mertz, J.  J. Scharer, L and McClement,  J. H. A
    hospital outbreak  of Klebsiella pneumonia from
    inhalation  therapy with contaminated aerosol
    solutions.  Amer. Rev. Resp. Dis. 95:454, 1967.

7.   Scheldt, A.,  Drusin, L M.,  Krauss,  A.  N.  and
    Machalek, S. G. Nosocomial outbreak  of resistant
    Serratia in a neonatal intensive care  unit. N.Y.
    State J. Med. 82:1188, 1982.

8.   Herman,  L.  G. and Fournelle.  Flavobacteria: a
    water-borne  potential pathogen.  In: Proceedings
    of  the  Third International  Congress  on
    Chemotherapy,  Stuttgart,  Germany,  July 22-27,
    1964.

9.   Mood,  E.  W.  and  Calderon,  R.  L.   An
    epidemiological study  on  bacteria in point-of-
    use activated  carbon  filters. Draft  Report  to
    Health  Effects  Research  Laboratory,  Cincinnati,
    OH for Cooperative  Agreement  CR-811904,
    1987.

10. Galderon,  R. L. An epidemiological study on  the
    bacteria  colonizing granular activated  carbon
    point-of-use filters. Point-of-Use.  5:1,  1987.

11. Standard  methods for the examination of water
    and wastewater.  Amer. Public  Health  Assoc.,
    Washington, DC, 15th ed, 1981.

12. Reasoner, D.  J.  and  Geldreich,  E.  A.  A  new
    medium for  the enumeration and subculture of
    bacteria  from  potable water.  Appl. Environ.
    Microbiol.  49:1, 1985.
                                                 87

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         ACTIVATED ALUMINA FOR POUlPOE REMOVAL OF FLUORIDE AND ARSENIC

                                          Robert L. Lake
                                   Water Treatment Engineers
                                      Scottsdale, AZ 85257
INTRODUCTION

For the past 14 years, we have been treating  high
fluoride and/or arsenic  water with activated  alumina
(AA) in POU/POE applications. Typical systems are:
1) a unit on each drinking fountain at a school;  2) a
unit  for each home in  a subdivision of  over  300
homes; 3) a dual  system for  a 365-room hotel  in
combination with a  185-unit trailer park; 4) a single
water tap  for a small trailer park; and 5) all potable
water in a restaurant.
Each system may  require a different approach  with
respect to installation,  monitoring, and servicing. We
are currently the certified operator for over 50 water
systems in  Arizona. To  monitor fluoride  reduction
systems, we use a  spectrophotometer and SPADNS
reagent, which  is simple, inexpensive, and  can be
performed in the field. Arsenic  has  no simple  field
test, but fortunately all of our arsenic-bearing waters
also contain fluoride.  We have found that  fluoride
breakthrough occurs before arsenic,  and by testing
for fluoride  we can exchange units  before  arsenic
breakthrough.

ACTIVATED ALUMINA
Activated  alumina is primarily a hydrated  aluminum
oxide  (AlaOa),  which   has  been   heated to  a
temperature of 300  to 700°C (570 to 1,290°F).  It  is
then ground and  screened to  sizes ranging  from
12.7-mm  (0.5-in)  granules to minus  325-mesh
powders. The optimum size for POU  water treatment
applications has been 28 to 48 mesh  (44 to 297 um).
AA particles are very irregular and porous with a very
high surface area  per  unit mass.  AA  is  an ion
exchanger with the capability  of  exchanging  both
anions and  cations. Alumina chromatography  has
been used successfully for separating organic as well
as  inorganic compounds. Acid-treated  AA  is
primarily an anion exchanger with an anion selectivity
sequence as follows:

 OH-,  P03-3,   F-,   Si(OH)30-,  As04-3,
 rFe(CN)6J-4, AsO3-3,  CrO4-2, SO4-2,  Cr207-
 2, NO2'1,  Br-1,   CI-,  NO3-, MnO4-, CI04-,
 CHsCOO-
The anions  are  listed in their decreasing  order of
preference. The  more preferred anions  will tend to
displace on the AA those anions that are lower in the
sequence.  Whereas  in  most  organic anion
exchangers,  the  fluoride  ion  is one of the  least
preferred, the reverse is true for AA.  The OH" ion is
the most preferred and this has been a problem in
POU applications. High alkalinity in  water will reduce
the capacity of AA to remove  fluoride and arsenic.
This problem is  resolved  in central  plant fluoride
reduction by  lowering the pH  of  the  water to  be
treated to  approximately 5.5.  Since such pH
adjustment is not feasible with POU/POE applications,
the lower capacity must be accepted.

Both of the  forms of arsenic (As04-3 arsenate and
AsO3"3  arsenite) found in water are in the  anion
selective sequence preferred  to the  SO4"2 sulfate
ion, and  activated  alumina has been  used
successfully  as a POU/POE method for the removal
of arsenic. Test facilities in  Alaska, Oregon, and New
Hampshire  have determined  that  the activated
alumina systems  were very effective and much  more
economical then reverse osmosis and  others  tested.


PREPARATION
Activated alumina such as ALCOA  F-1  or Kaiser
Chemical A-2   should  be  pretreated  before
incorporation into  a  POU system.  Pretreatment
consists of a thorough backwash  and  acid wash.
Aqueous state AA will have a pH of 9 to 10 and
should  be acid  washed  with a pH  2  sulfuric  acid
solution to a pH of 5 to 6. Backwashing is essential to
remove the dust and fines in the material. If  they are
not removed, the alumina has a tendency to cement
and  destroy  its  adsorption capability.  Activated
alumina  should always  be added to an  excess of
water to dispel! the heat generated,  which  will also
contribute to cementing of the material.


CHEMISTRY
A  simplified explanation of the absorption  reactions
(A = activated alumina particles):
                                               88

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1. Acid pretreatment

        A»H2O + H2SO4
        (aqueous state)
                         A»H2SO4 + H20
                            (acid state)
2. Absorption or ion exchange

       A«H2SO4 + 2NaF -»• A«2HF + Na2S04

3. Regeneration

    A»2HF + 4NaOH -> A»2NaOH + 2NaF + 2H20

4. Neutralization

 A«2NaOH + 2H2SO4 -»• A«H2S04 + Na2S04 + 2H20
    (basic state)


REGENERATION
Several methods of regeneration of activated alumina
have  been  explored  over  the past  15 years.
Inconsistent results from regenerated media were a
problem in many instances.

A regeneration  method  that  gives uniformly  good
results has been  recently developed. The  process
entails allowing  complete replacement of the sorbate
(Fl,  AsO4-3,  etc.)  with   OH"  and complete
neutralization  of the basic state AA with acid. Both of
these reactions are time  dependent,  and  allowing
sufficient time  for  completion is  the  key to  the
success of this  method. It  has also been possible to
greatly reduce  chemical costs  by recirculating  the
NaOH regenerant.  It appears that  the failure  to
completely neutralize the AA accounts for most of the
loss of capacity on the media. In  larger  systems,
where pH control is used,  the continuing injection of
acid is neutralizing  the media well into the treatment
cycle.

The steps in regeneration are:

1. Backwash  - A backwash rate of 19.5 m3/m2/h (8
  gpm/sq ft) gives 100 percent  expansion of  the
  alumina bed,  and the excess material is contained
  in an additional  vessel  (three to four minutes or
  until clear).

2. Upflow  regeneration -  One  percent NaOH  (by
  weight) is injected  while the AA  bed is  still
  expanded.  Regenerant is recycled for 30 minutes
  at 7.3 m3/m2/h (3 gpm/sq ft).

3. Soak - Up to three hours.

4. Neutralization - Rinse with  (pH = 2) dilute sulfuric
  acid until pH  of alumina  bed drops to 4.5-5.
5. Soak - 24 hours or until pH of alumina returns to
  10 +  due to pore migration within  the  alumina
  particles.

Repeat steps 4  and 5  as needed to complete
neutralizing of alumina bed.

6. Final backwash and refill.


CONCLUSION
Although  the EPA  has  determined   that  POU
technology  is unacceptable  for water treatment, we
have successfully protected thousands of people from
the  damage caused by fluoride and  arsenic in their
drinking water. We have shown that POU treatment is
a cost  effective  method  of treatment  in situations
where the cost  of central treatment  would be
prohibitive.


BIBLIOGRAPHY
1. Bellen,  G.E.,  Anderson,  M. and Gottler   R.A.
  Defluoridation  of  Drinking  Water in  Small
  Communities. EPA/600/2-85/112,  Cincinnati,  OH,
  January 1986.

2. Bellack,  E.  1971. Arsenic Removal from Potable
  Water. JAWWA 63:7:454, July 1971.

3. Clifford, D.,  Matson J.,  and Kennedy, R.  Activated
  Alumina: Rediscovered "Adsorbent"  for  Fluoride,
  Humic  Acids  and  Silica.  Industrial Water
  Engineering, December 1978.

4. Harman, J.A. and Kalichman, S.G. Defluoridation of
  Drinking  Water in Southern California.  JAWWA
  57:2:245, February 1965.

5. Kubli, H.  On  the  Separation  of  Anions by
  Adsorption on Alumina.  Helvetia  Chimica  Acta.
  Switzerland 3:453, 1947.

6. Maier,  F.J. Defluoridation of Municipal  Water
  Supplies. JAWWA 45:8:879, August 1953.

7. Savinelli,  E.A. and  Black, A.P. Defluoridation of
  Water with Activated Alumina. JAWWA 50:: 1: 33,
  January 1958.

8. Singh,  G.  and  Clifford,  D.A.  The  Equilibrium
  Fluoride Capacity of  Activated Alumina.  EPA-
  600/S2-81-082,  Cincinnati, OH,  July  1981.
                                                89

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                   MODELLING POINT-OF-ENTRY RADON REMOVAL BYGAC
                                          Jerry D. Lowry
                                       University of Maine
                                         Orono, ME 04469

                                          Sylvia B. Lowry
                                     Lowry Engineering, Inc.
                                       Thorndike, ME 04986
The health  implications  of  airborne 222Rn  in
households  are  well documented  (1-8),  as is the
importance of elevated 222Rn in the water supply and
how it  contributes to the airborne 222Rn (1,2,9-19).

The feasibility of removing 222Rn from household and
small system water supplies with granular activated
carbon (GAG) or aeration devices has been reported
by  various  researchers  (1,20-23)  and a  detailed
report  for public water supplies  has recently  been
prepared  for the  U.S. Environmental Protection
Agency (EPA) (24).

In response to  the  growing concern about airborne
and waterborne 222Rn, research was initiated in 1980
at the  University of  Maine  to identify technologies to
remove 222Rn  from ground water (17,22).  Aeration
and GAG  were  found to be potentially cost effective
treatment  processes for  point-of-entry  applications.
Laboratory testing  of full-scale point-of-entry  GAG
and diffused bubble aeration units showed that both
methods were effective, but GAG appeared to  have
the most  promise  for household  applications.  That
study  and a  previous  one documented  that an
adsorption/decay steady state  is  established with a
GAG bed, allowing it to be virtually maintenance free
for an indefinite but long period of time. These studies
led to laboratory research to model the GAG process
for  municipal application, field research  to develop a
design model  for  point-of-entry application, and
installation and monitoring  of the  GAG technology in
more than 100 households throughout the U.S. This
article reports on the findings of the second and third
aspects of the preceding research.


DEVELOPMENT OF GAC MODEL
Previous research indicated that the adsorption/decay
steady  state performance could be modelled by first-
order kinetics,  allowing the use of the  following
equation to describe and predict removal:
where:

   Ct  = the 222Rn cone, at time t, pCi/l
   GO = the initial 222Rn cone., pCi/l
   Kss = the steady state adsorption/decay constant,
        hr1,  and
   t   = the empty bed detention time (EBDT), hr

This is logical since at steady state, the adsorptive
removal equals the decay  of adsorbed 222Rn at all
points in the bed, and decay kinetics are first order.
The actual  achievement  of  the adsorption/decay
steady state is quite complex. It  involves nonsteady
state adsorption kinetics, which dominate the early
period, followed by an increasingly significant decay
phenomenon  set  up by 222Rn  and its short-lived
progeny. The  result  of these  processes is  the
establishment  of  the  steady state distribution  of
222Rn  and  short-lived progeny  on the GAC.
Although  the establishment of the  steady  state is
complex, the  performance  after  steady  state is
reached can be accurately described by the simple
steady state model.

The use of  the average empty bed detention time (t)
is appropriate since the GAC bed at steady state acts
as a decay storage device. This means that for all
practical purposes, the normal intermittent diurnal flow
experienced in a typical household is not important, in
terms of its effect on the steady state performance.
An analogy  to a chromatographic  column  can be
made, in which the 222Rn travels along the bed at a
relatively  slow  rate compared  to  the  water,  aiad
decays down to the effluent value. The bed is simply
a  concentrating device that stores 222Rn and is
equivalent to a plug flow  storage tank having a much
greater liquid detention time. For example, a GAC bed
giving a 99 percent reduction is equivalent to an ideal
plug flow decay storage tank having a detention  time
                                                90

-------
of 25.3 days. Thus, t should be  calculated  for the
water volume used over two to three weeks because
this  is the  period  to  which  the  GAG bed is
responding. In  a typical household the  three week
flow  average does  not vary significantly,  except
perhaps seasonally in a gradual manner.

To accurately document this  model  and to test the
relative effectiveness of  several  different GAG
products, a field study was designed to  measure the
steady  state  adsorption/decay constant  (Kss).  A
Maine household that  had  an extremely  high 222Rn
concentration in its ground water supply was selected
to demonstrate the general applicability of the model
across a  wide  range  of  222Rn  levels.  The
performance  of three  GAG products  (Table  1)  was
examined using a modified  commercial treatment unit
(Figure 1). Slotted  [(0.30  mm  (0.01 inch)]  laterals
were installed  at  depths  corresponding to 0.007,
0.014, 0.03, 0.04, 0.06 m3 (0.25,  0.5, 1, 1.5, and 2
cu ft) bed volumes to obtain depth  samples. The total
bed  volume was 0.07 m3 (2.5 cu ft).
Table 1.
Carbon
A
B
C
D
Summary of Adsorption/Decay Design Constants
Manufacturer Type Kss (hr1)
American Norit
1CI Americas*
Calgon
Barneby Cheney
Peat (8X20)
HD4000 (12X40)
F-400 (12X40)
299 or 1002
1.35
2.09
1.53
3.02
   Now manufactured by American Norit.
Water samples for 222Rn analysis were taken directly
from  sampling valves with a 10 ml (0.34 oz) syringe,
which was  subsequently discharged directly  into a
previously prepared liquid scintillation vial containing 5
ml (0.17 oz) of fluor.  The  vial was  immediately
capped, and mailed  to  the laboratory  for counting.
The  basic  counting  procedure  used was  one
described by Prichard and Geseli (25), except that a
mineral  oil- rather  than  toluene-based fluor  was
utilized because of postal regulations. Precision of the
222Rn analysis is a  function  of  the level of 222Rn
present,  the counting time,  and the  time elapsed
between  sampling  and  counting. Typical levels of
uncertainty  (2-sigma) for this study  are given  in
Table 2.

The water use at the household  was monitored  by a
standard  16 mm (5/8 in) meter and totalizer readings
were taken  daily. Water  temperature ranged between
6 and 10°C (43 and 50 °F) throughout the study.

The various GAC products were tested  sequentially,
each  by  the same method.  The virgin  carbon was
placed in the pressure vessel over  a gravel support
and commissioned after a backwashing  period  of 15
to 30 minutes  to  remove  fines.  The GAC  bed
Figure 1. Experimental GAC vessel for K.sa determination.


 Raw Water         *V/    ^      **S  2.50 cu ft scnple
 Raw Voter
 Freeboard
   Riser Tube


      GflC Bed
                                                    Basket Distributor

                                                     Support Gravel
	
lor


>


— 1

=^
i~ 	
b
S^ Control Valvi
1 O.25 cu ft sample
| 0.50 cu ft sample
| 1.00 cu ft sample
] 1.50 cu ft sanpla
] 2.00 cu ft sample
                                                     Table 2.   Typical Levels of Uncertainty (Counting) for This
                                                              Study
222Rn Concentration (pCi/1)
800,000
300,000
40,000
2,000
1,000
500
100
60
Uncertainty (percent)
0.5
0.5
1.0
4.5
6.0
15.0
25.0
45.0
remained  in service to allow  a steady state to be
achieved  (approximately three  weeks)  and  was
monitored for an additional three to four week period.
Fourteen sets of samples  (all  ports)  were taken to
determine Kss.

Typical examples of the results of the field  testing are
illustrated  by Figures 2 through 4 for GAC  B.  Figures
2 and  3 show results of the depth removal of 222Rn
and the establishment of the adsorption/decay steady
state.  The exact reason for the  elevated point for
each depth on day 42 was not known, but suspected
to be caused by desorption brought about by possible
extreme  raw water  222Rn  variation  that was not
documented  by sampling the  previous week.  This
particular  well  is subject to  such variations,  and
previous monitoring has documented that  the 222Rn
                                                  91

-------
Figure 2.  Performance for the top portion of the GAG bed for GAC B.

               800
                     O Raw Water
                     A 0.25 cu ft
                     a 0.5 cu ft
                     * I.0 cu ft
          10
                                    — ?"*"' 7"" ^st
                                   15    20    25    30
                                          TIME, days
Figure 3. Performance for the bottom portion of the GAC bed for GAC B.
                15
                14
                13
                12
                II
                10
                 9
                 8
                 7
                 6
                 5
                 A
                 3
                 2
                 1
O 1.0 cu ft
A 1.50 cu  ft
a 2.00 cu  ft
                                    	o	CIDED—ago-—
                              10     15    20    25    30
                                           TIME, dcys
                                        35    40
45
50
                                               92

-------
Figure 4.  First-order steady-state adsorption-decay relation for GAC B, with 95 percent confidence limits indicated.
               14

               13

               12

               11

               10

                9

                8

                7

                6
          Kss  =  -  2.09/hr
                        30
90     120     150
  EBDT.  minutes
180     210     240
Figure 5.  Contrast of the steady-state adsorption-decay relation for test carbons A, B, and C with GAC D.

              100*	
               50.
               20.
               10.-
           Hi
                2.

                1
\
                       o Carbon R
                       A Carbon B
                       a Carbon C
                         Carbon D
                 0      X      60      90     120     150      180    210     240
                                           EBDT.  minutes
                                                   93

-------
variation over a period as short as several days can
be  from 150,000 to over  2,000,000  pCi/l.  For  bed
volumes of greater than  42 I  (1.5  cu  ft),  these
variations in depth are not significant in relation to the
raw water  concentrations because  there  is enough
GAG to provide adequate  dampening.  They  are
apparent in this case  due to the extremely high
average raw water 222Rn.

A semi-ln plot of bulk solution 222Rn (In  vs. EBDT)
yields a linear relationship with a slope equal to Kss.
This relationship is  illustrated in  Figure 5  for one of
the carbons tested.

The analysis of variance (ANOVA) for the data is
summarized in Table 3. Although the deviations from
regression  were  significant statistically,  they were
extremely small  compared  to the variation explained
by  regression. This fact is  reflected by the relatively
narrow confidence limits (95 percent) around the least
squares regression line in Figure 4.
Tablo 3.   Summary of Analysis of Variance for GAC B
 Sourco ol Variation          df     SS    MS     F
Among Groups (EBOT)
Linear Regression
Deviations from Regression
Wiiliin Groups (ports)
5
1
4
78
534.7
530.6
4.1
10.1
106.9
530.6
1.0
0.13
829*
515*
8.0"

   Significant at 0.001 level.

The performance of  carbons  A,  B,  and C is
contrasted to that of carbon D,  which has been
determined  by other  research  (23,26) to have  the
highest Kss value  tested to  date. A summary of the
KSS values for these carbons is given in Table 1.  The
ranking of these carbons bears little relation  to  how
they performed previously by isotherm  testing,  and
shows that isotherms are not  indicators  of  how  a
carbon will perform at steady state (17). This group of
four carbons contains the best and  worst carbons
with respect to 222Rn  removal; it  is clear that  the
type of GAC selected  has significant bearing upon the
performance achieved.  For  example  at 99  percent
removal, the required  carbon volume for GAC  D is 50
percent of that needed using carbon A. For equal  bed
volumes, carbon D achieves a 99 percent reduction
compared to an 88 percent reduction with carbon A.  It
is interesting  to  note that  the bulk densities  for
carbons  A and  D  are  approximately 288  and  513
kg/m3 (18 and 32 Ib/cu ft), respectively, and that on  a
mass, rather than volume, basis all GAC types tested
are much closer in performance. Because the number
and  size  of vessels  required is determined  by  the
volumetric  performance, this  has  little practical
significance.  Of more importance  is the  probable
positive influence  of  decreasing  particle size;
however, no studies have documented the magnitude
of this factor for the 222Rn steady state.
Because of the small flow treated  and the relatively
narrow range of bed sizes required to cover the entire
range of  222Rn encountered  in  point-of-entry
applications, the  long  EBDT is easily  satisfied by
commercially available  pressure vessels. A range of
bed volumes from 28 to 85 I (1 to 3 cu ft) will remove
in excess  of  99 percent of the 222Rn  from any
household  ground water  supply.  In  contrast,  the
relatively long EBDT is  of  importance with  larger
design flows in municipal applications. Compared to
an EBDT of approximately 15  minutes  for organics
removal, the required  EBDT for 222Rn removal is
quite  long.  Although  the GAC will last indefinitely in
the 222Rn  application,  the initial high capital cost for
the GAC makes aeration an attractive alternative for
larger water systems.


FIELD   EXPERIENCE  WITH   GAC
TREATMENT
Since  1981, GAC units  have  been  installed  in a
significant number of households to remove 222Rn
from the water supply and thereby lower the airborne
222Rn levels in homes. The current number of units
that  exist is estimated to be in   excess of  500.
Approximately  100  units have been  installed and
monitored as a part of a data base for future research
on aspects  other than simple removal,  such  as the
resulting gamma exposure rate from 214Pb and 214Bi
and the long term buildup of 210Pb. In each of these
installations the GAC type, the GAC quantity, and the
installation  date  are  known. In  some  of the
installations  the water use is  known and the  radium
and  uranium content of the raw  water has been
documented. This data base is unique in that the
units  are installed over a  widespread  area (Canada
and 12  states  in the U.S) and contain elements that
represent the longest operating GAC units for 222Rn.
In addition, they are installed on water supplies that
cover the entire  documented  range  of 222Rn  in the
world -- from less than 1,000 pCi/l to in excess of
1,000,000 pCi/l.

Although four GAC  types have been  used in these
units, over  85  percent contain carbon D and 10
percent contain carbon C. A summary of the steady
state performance of all installations that  are routinely
monitored  is  presented  in  Figure  6.  With the
exception of three units, the performance level in field
installations  is  very  high. Eighty percent of all units
are in the 0.05 m3 (1.7 cu ft) category,  with remaining
units ranging from 0.03 to 0.08 rr>3 (1 to  3 cu ft). The
average  removal of  222Rn  for  all  units is  96.2
percent.

Elimination  of  three  known  prematurely fouled or
malfunctioning  units and the units containing  carbon
C, yields the histogram summarized in Figure 7. For
these units, the  average removal of 222Rn is 98.9
percent, and it is uncommon to monitor a unit and
find less than 99 percent removal. Although the real
                                                 94

-------
Figure 6.  Histogram of the steady-state performance of 66 GAG treatment units.
                 22
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                 10
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                  6
                  4
                  2
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                         10     20    30     40    50    60    70     80
                                           REMOVRL,  percent
                                                                 90    100
Figure 7.  Histogram of the steady-state performance of properly operating GAG units conatining GAG 0.
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-------
value of theso units lies in future studies involving
222Rn progeny buildup, these data demonstrate the
high  degree  of  removal  possible  with properly
designed and installed systems.

The reason for the three poorly performing units has
not been  determined.  Preliminary  investigation
appears to indicate water quality as a cause, rather
than the GAG. Although only a few  percent of the
existing GAC units exhibit  this phenomenon, the
reason for this possible premature fouling should be
determined.
GAC vs. AERATION
It has been documented that aeration is a feasible
method  for  222Rn  removal  in point-of-entry
applications  (22,27).  But a number of factors  have
kept it from  becoming as popular a method as  GAC
treatment:

• Aeration is performed at atmospheric pressure and,
  therefore  requires re-pressurization  of the water
  supply.

• The initial cost of aeration systems designed for
  222Rn removal is relatively high, partly due to the
  re-pressurization requirement. The installed  cost
  ranges from $1,700 to over  $4,000, compared to
  approximately $650 to $1,200 for GAC.

* Several of the currently available aeration methods
  have limited removal capabilities. A novel  but costly
  spray aeration system was developed by the Maine
  Department of Human Services, Division of Health
  Engineering, and six units are operating in the field.
  These units achieve 90 to 95 percent removal but
  may be limited to wells containing only  10,000 to
  20,000 pCi/l if, for example, the future U.S.  EPA
  maximum  contaminant level (MCL) for 222Rn is set
  at 1,000 pCi/l. Although the MCL would apply only
  to public water supplies, the real 222Rn issue is in
  private  household  supplies  -  in many cases
  lending institutions are already  requiring removal.
  These  institutions  tend to  use the  MCLs as
  guidance for supplies as well.

  Packed-tower  aeration systems  are confined by
  the ceiling height in the cellar or living area and are
  therefore  limited to  about  85 to 90  percent
  removal. Two such devices are  currently available
  for household use. These units cost approximately
  $3,000.

  A  multi-staged  diffused bubble  aeration system
  developed for organics removal (28) has been
  tested on  a  supply that contains 250,000 pCi/I and
  removed  222Rn to below detection,  for virtually
  100 percent removal.  A less expensive version
  designed  specifically for 222Rn removal  has been
   developed that will achieve 99 percent removal. It
   will cost approximately $1,700.

•  Aeration  methods require significant  O&M
   compared  to GAC, which  increases the  cost
   differential over the long term.

Aeration methods  have  two  advantages to  be
considered for  point-of-entry  applications, i.e.,  they
avoid the elevated gamma exposure rate and long
term buildup  of  210Pb  that  is  and  may  be,
respectively, associated with GAC beds. These topics
are currently  the subjects of on-going research  on
GAC treatment and are beyond the scope of this
paper; however, economical  water jacket  shielding
and  proper location can minimize increased gamma
exposure. The buildup of 210Pb in these applications
is  not well documented, but  it  could be a  concern
from a regulatory point of view. Future documentation
and research on this subject will determine the extent
of and solutions to these problems.


CONCLUSIONS
•  A first order model accurately  describes  the
   adsorption/decay steady state  removal of 222Rn by
   GAC.

•  A single design constant, Kss, can be used to rank
   a given GAC type for 222Rn removal. The ranking
   of a carbon for steady state performance does not
   appear to be related to its  ranking according to an
   adsorption isotherm.

•  There is a significant range of the design constant,
   Kss, f°r the  carbons tested to date, making the
   selection of  the correct GAC important.  This is
   especially  true  for  small  public  water supply
   application, where economics are morje sensitive to
   vessel size.

•  More   than  99 percent reduction  of  222Rn is
   possible with an effective GAC.

•  The  progeny of 222Rn  make  it  important  to
   consider the location of and protective shielding for
   a  GAC bed, to  minimize  increased  gamma
   exposure over background levels.

•  Limited data  indicate a possible premature fouling
   of approximately three to five percent of existing
   GAC  units. The reason for this decreased  removal
   in these installations is  unknown  and should  be
   investigated.


ACKNOWLEDGEMENT
This paper is  largely reproduced from  a  previously
published paper in the Journal  AWWA (October
1987).
                                                96

-------
Primary funding for the  field research to  determine
the steady state design  model was provided  by  the
Office  of  Research   and  Development,  U.S.
Environmental Protection Agency (EPA), under Grant
No.  R8108290. The field  monitoring data was
supplied by Lowry Engineering, Inc.


REFERENCES
1.  Castren, O. The contribution of bored wells to
    respiratory radon daughter exposure in Finland.
    Technical  Report, Institute  of  Radiation
    Protection, Helsinki, Finland, 1977.

2.  Hess, C. T. et al. Radon in potable water supplies
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    U.S. Department of the Interior, Washington, DC,
    1979.
3.  Evans,  R.  D.   et al.  Estimate of risk from
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4.  Harley,  N.  H.  Editorial-radon and  lung  cancer
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5.  National Academy of Sciences Committee  on
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    levels of ionizing radiation.  National Academy
    Press, Washington, DC,  1980.

6.  U.S. Environmental Protection Agency. A citizens
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7.  U.S. Environmental  Protection  Agency.  Radon
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8.  Cothern,  R. C.  Estimating  the  health risks of
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9.  Castren,  O. et al.  High  natural  radioactivity of
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    International Congress, Paris, France.

10. Duncan, D. L, Gesell, T. F. and Johnson, R. H.
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    Physics Society, Saratoga Springs, NY, October,
    1976.
11. Hess, C. T. et al. Investigation of Rn-222, Ra-
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   Completion Report B-017-ME, Land and Water
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   Department of the  Interior, Washington,  DC,
   1981.

12. Partridge, J. E., Horton, T. R. and Sensintaffer, E.
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   household activities.  ORP/EERF-79-1,  U.S.
   Environmental  Protection  Agency,  Office of
   Radiation  Programs,  Eastern  Environmental
   Radiation Facility, Montgomery, AL, March, 1979.

13. Weiffenbach, C. V. Radon in air and water: health
   risks and control measures. Technology Transfer
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   University of Maine, June, 1986.

14. Horton, T. R. Methods and results of EPA's study
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   Environmental  Radiation Facility, Montgomery,
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15. Aldrich, L. K., Sasser, M. K.  and Conners,  D. A.
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   January, 1975.

16. Lowry, J. D. and Moreau, E.  Removal of extreme
   radon  and uranium  from  a water supply.
   Proceedings of the 1986 National Conference on
   Environmental  Engineering, Environmental
   Engineering Division,  American Society  of Civil
   Engineers, Cincinnati, OH, July, 1986.

17. Lowry,  J. D.  and Brandow, J.  E.  Removal  of
   radon  from  water  supplies.  Journal of
   Environmental  Engineering, Environmental
   Engineering Division,  American Society  of Civil
   Engineers. Vol.  111, No. 4, August, 1985.

18. Lowry,  J. D. Radon at home. Civil Engineering.
   Vol. 57, No. 2, February, 1987.

19. Prichard,  H.  M. The transfer  of radon from
   domestic  water to  indoor air. Journal of the
   American Water Works Asso. Vol. 79, No.  4,
   April, 1987.

20. Hoather,  R. C.  and  Rackham,  R.  F.  Some
    observations on radon in waters and  its  removal
    by aeration. Proceedings of the Institution of Civil
    Engineers, Great George Street, London, S.W.1.,
    December  7, 1962, pp. 13-22.
                                                 97

-------
21. Smith, B. M. et al. Natural radioactivity in ground
    water supplies  in  Maine  and New  Hampshire.
    Journal  of  the  American  Water  Works
    Association. Vol. 53, No.  1,  January, 1961, pp.
    75-88.

22. Lowry,  J.  D. et  al. Point-of-entry  removal of
    radon from  drinking  water.  Journal of  the
    American Water Works Asso.  Vol.  79, No. 4,
    April, 1987.

23. Lowry, J. D. Extreme levels of Rn-222 and U in
    a private  water  supply.  Proceedings of  the
    Conference  on Radon,  Radium,  and  Other
    Radioactivity in Ground Water: Hydrologic Impact
    and Application to Indoor Airborne Contamination,
    National  Water  Well Asso.,  Somerset, NJ, April
    7-9,  1987.

24. Malcolm Pirnie,  Inc. Technologies and costs for
    the removal of radon from  potable water supplies.
    Draft of  report  to EPA under Contract  No. 68-
    01-6989, January 6, 1987.

25. Pritchard, H.  M. and  Gesell,  T.  F.  Rapid
    measurements of radon-222 concentrations in
    water with a commercial  liquid  scintillation
    counter.  Health  Physics. Vol. 33, 1977, pp. 577-
    581.

26. Pinnette,  J.  M.S.  thesis  in  Civil Engineering,
    University of Maine, Orono, ME, 1985.

27. Hinkley, W. W. Experimental water treatment for a
    drilled well with  the  world's  highest known
    radon-222  levels.  Maine   Oept.  of  Human
    Services, Div.  of Health Engineering,  State
    House, Augusta, ME, 1982.

28. Lowry, J. D.  and  Lowry, S. B.  Restoration of
    gasoline-contaminated household water supplies
    to drinking  water quality. Proceedings of  the
    Eastern  Regional  Ground Water Conference,
    National  Water  Well Asso.,  Portland, ME, July,
    1985.
                                                98

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  POINT-OF-ENTRY ACTIVATED CARBON TREATMENT LAKE CARMEL - PUTNAM COUNTY
                                        George A. Stasko
                           Bureau of Public Water Supply Protection
                                NY State Department of Health
                                        Albany, NY 12237
Lake Carmel is a small lake located approximately 80
km (50  mi)  north  of  New York  City. The hills
surrounding the lake were extensively developed  in
the 1930s with seasonal residences. Since then most
of these residences have been  converted to year
round housing. Lot sizes range from 370 to 1,110 m2
(4,000 to 12,000 sq ft)  and each lot has a well and
septic system (see Figure 1).

In the 1970s, some of the residents complained about
petroleum odors in their water. When  individual action
did not bring  the desired results  they formed  a
Citizens'  Advisory  Committee.  The committee
enlisted the aid of their legislators with the result that
investigations of the  area were  made by the
Department of Transportation, the State Health
Department,  and  the Putnam County  Health
Department.


INVESTIGATION RESULTS
The residents believed  that  the  ground  water
contamination came from a petroleum spill or from a
waste site. However, as a result of the investigations,
it was concluded that the residents had contaminated
their own water supplies by localized  petroleum leaks
and spills,  and by the  chemicals flushed into their
septic  systems.  In  addition,  it  was  discovered that
some  wells had  elevated nitrate levels and high
coliform counts.

BACTERIOLOGICAL QUALITY
Bacteriological test results indicated  widespread
bacterial contamination. Approximately 40 percent  of
the samples were above the standard of 1 coliform
organism per 100 ml (0.3  organism  per oz). Counts
as high as 245 coliform organisms per 100 ml (72 per
oz) were found (see Table 1).

Coliform levels varied considerably from  well to well
and in the same  well over a period of time. In the
Fitzsimmons well} 245 coliform organisms per 100 ml
(72 per oz) were present on February 4, 1982. Two
weeks later the count was  3 per 100 ml (0.9 per oz)
and four weeks  after the  second sample the  count
was 134 per 100 ml (39 per oz). In the Saver well on
February 18,  1982 the  count  was  189  coliform
organisms per 100 ml (56 per oz), and on March 23,
1982 the count was less than 1 coliform organism per
100 ml (0.3 per oz). Because of  this  variability, the
health department concluded that all wells would be
subject to bacterial contamination at some point  in
time and therefore the treatment system must include
disinfection.

ORGANIC CHEMICAL QUALITY

Volatile Organic Chemicals
Detection of volatile organic  chemicals varied from
well to well, and with  the laboratory, performing the
analyses. All the highest results were  obtained from
one laboratory. Other laboratories detected the same
chemicals but at lower levels. Sampling for the three
studies was not coordinated, leaving gaps in the data.

Benzene, toluene, and xylene were  detected at high
levels confirming residents' complaints of petroleum
tastes and  odors. In addition, several  solvents were
found   including  carbon   tetrachloride,
tetrachloroethylene, trichloroethylene,  and  1,1,1-
trichloroethane.  Table  2 summarizes  the results  of
tests for volatile organic chemicals.

Base/Neutral Chemicals
Of the base/neutral organic chemicals tested, only bis
(2-ethylhexyl)  phthalate  was found  in  detectable
quantities (see Table 3).

Pesticides/Herbicides
No pesticides or herbicides were detected.  For the
ch'emicals tested see Table 4.

INORGANIC CHEMICAL QUALITY
The average inorganic water quality  of the  wells
tested  was  soft and  corrosive, but  no chemicals
exceeded standards. Both sodium and nitrates were
significantly  higher than background  levels  in area
ground water, indicating that leachate from the septic
systems was reaching the wells. Only in one instance
did nitrate exceed the standard of 10 mg/l (10 ppm). It
                                                99

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Figure 1.   Location map.
                            LOCATION
MAP
 N.Y.S.D.PW BUREAU OF PROGRAMMING
 U.S.G.S. LAKE CARMEL QUADRANGLE - 7'/2 MIN. SERIES
          SCALE'  I"  = 2000'
                                       100

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Table 1.   Bacteriological Quality of the Ground Water in the
         Lake Camel Project Area*
Table 2.  Organic Chemical Quality of the Ground Water in
        the Lake Carmel Area (Volatile Compounds)
Name Collection
Backer
Baisley
Bao
Behnken
Cuomo
Fitzsimmons
Fitzsimmons
Fitzsimmons
Greco
Laconte
Laconte
Lawton
MacNeil
Madden
Mahoney
Micciche
Nappi
Placek
Porrino
Prisco
Sauer
Sauer
Sheridan
Sutor
Zasso
Zasso
3124182
4/15/82
4/27/82
2/18/82
4/21/82
2/4/82
2/18/82
3/16/82
2/4/82
2/4/82
3/16/82
3/24/82
3/23/82
4/15/82
2/4/82
4/21/82
4/21/82
1/5/82
3/23/82
4/15/82
2/18/82
3/23/82
2/4/82
2/4/82
3/18/82
4/21/82
Total Coliform Above Health
per 100 ml Limits"
57
<1
<1
6
<1
245
3
134
<1
91
17
92
<1
<1
<1
<1
<1
38
<1
<1
189
<1
<1
<1
<1
<1
Yes
No
No
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
No
Yes
No
No
Yes
No
No
No
Yes
No
* All samples were collected by the Putnam County Department'
of Health and analyzed by Sanitary Science & Laboratories,
Inc., Newburgh, New York.
" The NYS Dept. of Health limits total coliforms to 1/100 ml.
Volatile Compound
Acrdein
Acrylonitrile
Benzene
Bromodichlorometriane
Bromoform
Bromomethane
carbon Tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
Dichlorodifluoromethane
1,1-Dichloroethane
1 ,2-Oichloroethane
1,1-Dichloroethylene
Trans-1 ,2-Dichloroethylene
1 ,2-Dichloropropane
1,3-Dichloropropane
Ethylbenzene
Methylene chloride
1 ,1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1 ,1 ,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
Vinyl chloride
Xylene
High Value
(WM
ND
ND
820
4
ND
ND
5.9
ND
ND
ND
ND
14
ND
ND
ND
ND
ND
ND
ND
ND
110
ND
ND
560
320
14.2
ND
13
2
2
490
Mean Value*
±Std. Dev. (jig/l)
ND
ND
67.7 ±176.3 (21)
2.90 + 1.15(3)
ND
ND
4.50 + 1.98 (5)
ND
ND
ND
ND
5.03 ±4.81 (8)
ND
ND
ND
ND
ND
ND
ND
ND
38.3 ±62.1 (3)
ND
ND
100.2 + 215.3(11)
8.5 + 88.0(13)
6.91 ±5.10 (9)
ND
5.48 + 3.86(10)
1.25 ±0.50 (4)
2±0(2)
108.4 ±178.1 (7)
was decided that no treatment was needed to remove
inorganic chemicals. See Table 5 for a summary of
inorganic chemical test results.

Alternate Solutions
As a  result  of  the investigations,  the  health
department recommended that a public water system
be provided  for the  affected area. An  engineering
consultant  was  hired to  conduct a feasibility  study.
The study found that a  public water system  would
cost in excess of $1,200 per year per homeowner.
Expensive  rock cut for the distribution system was the
main  reason  why the public  water  system would be
so costly.  Because the  public water system  was
impractical, it was decided to study the feasibility of a
point-of-entry  solution.

The Citizens' Advisory Committee was able to secure
an imminent threat grant  from the U.S. Department of
Housing and  Urban  Development. They provided
$165,000 to  design,  purchase, and install point-of-
entry  treatment systems.  Because the  Citizens'
Advisory Committee could not receive the money, it
  ND - Not detectable.
  * Numbers in parentheses indicate sample size.
was given to the town of Kent, which in turn hired an
engineering firm to design the treatment systems.

Water Treatment Systems
The  health department worked  closely  with the
consultants to develop a water treatment system that
would adequately treat the water and would satisfy all
regulatory concerns. The design that resulted evolved
from design  criteria  developed by  the health
department's Ad Hoc  Committee on Removal of
Synthetic Organic  Chemicals from Drinking Water,
and published in an interim report, entitled Point-of-
Use Activated Carbon Treatment Systems.

A schematic of the treatment system is  shown in
Figure 2. The treatment  system consists of:

• A  raw water tap located immediately  after the
   homeowner's pressure tank  used  to  collect
   untreated water samples.
                                                 101

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Tablo 3. Organic Chemical Quality of the Ground Water in
the Lake Carmel Area (Base/Neutral Compounds)
High Value Mean Value*
Baso/Noutral Compound
Aconaphthene
Aconaphthylone
Anthracene
Bonzo (a) anthracene
Bonzo (b) fluoroanthene
Bonzo (k) fluoroanthene
Bonzo (a) pyreno
Bonzo (Q.h.O perylone
Bonzidino
Bis (2-chtoroethyl) ether
Bis (2-chtoroelhoxy) methane
Bis (2-elhylhexyl) phthalate
Bis (2-chtoroisopropyl) ether
4-BromophenyI phenyl ether
Butylbonzylphthalate
2-Chtoronaphthatene
4-Chtorophonylphenylether
Chrysone
Dibonzo (a,h) anthracene
Di-N-Butylphthalate
1 ,2-Dtchkx obonzeno
1 ,3-Dtchlorobenzene
1 ,4-Diehtorobenzeno
3.3'-Dichtorobenzidine
Diothylphthalate
DimothylphthafatQ
2.4-Dinitrotoluono
2,6-Dinitrotoluone
Di-octyl-phthalate
1 ,2-Diphonylhydrazine
Fluoroantheno
Fluorono
Hcxachlorobenzcne
Hoxchlorobutadiene
Hoxchtofoe thane
Hoxachtorocyclopentadiene
IncJono (i ,2,3-cd) pyrene
Isophorone
Naphthalono
Nitrobonzone
N-Nitrosodimothylamine
N-Nit/osodi-N-propylamine
N-Nitrosodiphenylamine
Phonan throne
Pyrono
1 ,2.4-Trichlorobenzene
2,3.7,8-Tetrachlorodibenzo-
p-dtoxm

NO • Not detectable.
(ug/l) ±Std.
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
Dev. (ug/l)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
35 23 + 17.0(2)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



* Numbers in parentheses indicate sample size.








• A water meter to measure the amount
processed.





of water

Table 4. Organic Chemical Quality of the Ground Water in
the Lake Carmel Area
High Value Mean Value
Pesticide/Herbicide (ug/l) ± Std. Dev. (ug/l)
Aldrin ND ND
-BHC
-BHC
-BHC
-BHC
Chlordane ND ND
Dieldrin ND ND
-Endosulfan
-Endosulfan
Endosulfan sulfate ND ND
Endrin ND ND
Endrin aldehyde ND ND
Heptachlor ND ND
Heptachlor Epoxide ND ND
4,4'-DDT ND ND
4,4'-DDE ND ND
4,4'-DDD ND ND
PCB 1016 ND ND
PCB 1221 ND ND
PCB 1232 ND ND
PCB 1242 ND ND
PCB 1248 ND ND
PCB 1254 ND ND
PCB 1260 ND ND
Toxaphene ND ND

ND - Not detectable.



• Two 5-pm (0.0002-in) cartridge-type prefilters
in parallel to prevent the activated carbon filters
from clogging due to particulate matter.
Backwashing of the activated carbon filters is not
recommended because of the operational problems
this would cause, due to the difficulty of disposing
of the backwash water and the difficulty in
obtaining enough treated water at adequate
pressure to provide an adequate backwash.

• Two activated carbon filters in series. Each filter
consists of 25.4-cm (10-in) diameter fiberglass
tank containing 18 kg (40 Ib) of virgin activated
carbon. Bed depth is 91 cm (36 in) and each
cylinder has a empty bed contact time of
approximately 2.5 minutes at a flow rate of 0.32 l/s
(5 gpm). The theoretical lifetime of this treatment
system is 36 months based on an influent Benzene
r*nnr*^ntrsitinn r\f *}&&. nn/1 RcnTT'ona at thio lowal
\j\J\ IL*d fllaLHJI I Ul <£*T*T JJ-lj' <• DtSI IZ.t'I It* dl 11 Ho ItJVfc?!
was chosen as the critical design factor because it
will give a 99 percent assurance that the treatment
system would meet any influent organic chemical
challenge encountered during the testing program.
The filters are operated in series with the lead
cylinder changed yearly. This is done, even though
the theoretical lifetime is 18 months, to provide a
factor of safety. When the lead cylinder is removed
102

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Table 5.
Inorganic Chemical Quality of the Ground Water in
the Lake Carmel Area
Element
Aluminum (Al)
Arsenic (As)
Barium (Ba)
Beryllium (Be)
Boron (B)
Cadmium (Cd)
Calcium (Ca)
Chromium (Cr)
Cobalt (Co)
Copper (Cu)
Iron (Fe)
Lead (Pb)
Magnesium (Mg)
Manganese (Mn)
Molybdenum (Mo)
Nickel (Ni)
Phosphorous (P)
Potassium (K)
Selenium (Se)
Silicon (Si)
Silver (Ag)
Sodium (Na)
Vanadium (V)
Zinc (Zn)
Nitrate
High Value
(van)
0.326
0.060
0.290
0
0.849
0
56.81
0.005
0
0.078
0.268
0.030
15.68
0.372
0.014
0.009
0.095
4.29
0
8.12
0
169.7
0
0.068
13.67
Mean Value*
±Std. Dev. (us/1)
0.095 + 0.155(4)
0.015 + 0.030(4)
0.115 + 0.122(4)
0 + 0(4)
0.212 + 0.425(4)
0 + 0(4)
30.27 ±16.04 (12)
0.001 ±0.002 (4)
0±0(4)
0.033+0.039(4)
0.100 + 0.097(12)
0.008 + 0.015(4)
10.47 + 5.45(12)
0.081 ±0.126 (12)
0.005 ±0.007 (4)
0.002 + 0.005(4)
0.063 ±0.043 (4)
2.18 ±2.42 (4)
0±0(4)
4.69 ±2.75 (4)
0 + 0(4)
85.28 + 73.49(4)
0 + 0(4)
0.033 + 0.038 (4)
5.65 ±3.47 (23)
  * Numbers in parentheses indicate sample size.
   the lag cylinder is moved to the lead position and
   the new cylinder is placed in the lag position.

•  A valving  arrangement is provided  to  allow  for
   water use during the cylinder changing procedure.

•  Pressure gauges are provided before and after the
   treatment system to determine head  loss across
   the system.

•  Ultraviolet  light disinfection is  provided after the
   activated  carbon units to destroy  bacteria  that
   break through the filter system.  A light sensor with
   a visual alarm is provided on the ultraviolet  light
   unit  to  inform  the  homeowner  of  proper
   disinfection.
WATER TREATMENT SYSTEM COST
To receive  as  many bids as possible, the engineer
arranged for the system  to be  bid in six separate
contracts. Low bid results are listed in Table 6.
 WATER SYSTEM MANAGEMENT
 The original  concept for management of  the water
 treatment systems'was for the Town of Kent to own
the systems and to be responsible for their operation
and maintenance. This responsibility for maintenance
could be carried out by their own personnel or under
contract by a qualified agent. The County and State
Health  Departments would  provide  technical
assistance and some monitoring and  regulatory
oversight.

However,  the  town turned the  responsibility for
operation and maintenance over to the homeowners.
They formed a not-for-profit corporation, the  Lake
Carmel  Water Quality  Improvement District
(LCWQID). The corporation consists of all the home
owners  who  have  treatment  systems.  The
homeowners elect a  President, Vice-President,
Secretary, Treasurer, and a seven member Board of
Directors.  The  Board of Directors consists  of the
Officers of the Corporation, who were also the active
members  of  the Citizens' Advisory  Committee, in
addition to three maintenance men.

Participation in  the  district is voluntary.  Sixty-seven
of  the  110  eligible homes  received  treatment
systems.


OPERATION AND MAINTENANCE
Operation and maintenance consists of changing one
of the  activated carbon  cylinders each year  and
changing the bulb  on the  ultraviolet unit  every nine
months. At the beginning of each year, the home
owner is given enough  refill  cartridges  for the
prefilters and  is expected  to  change them when
necessary.

Recharge  of  the  activated carbon cylinders is
accomplished by taking the spent cylinder to a town-
provided workshed. The used  activated  carbon is
emptied and the fiberglass cylinder is refilled with a
bed of  sand and 18  kg (40 Ib)  of virgin activated
carbon. The spent carbon is disposed of at a landfill.

Maintenance  men make house calls  to repair  leaks
and to clean the quartz tube on the ultraviolet unit.
They are paid on a flat rate per item basis.


ANNUAL COSTS
For the first four years of operation the  annual cost
for operation, maintenance, and monitoring has been
$250 per  treatment system.  The annual charge has
recently  been  raised  to  $320  per year  paid  on a
quarterly basis. This amounts to a total annual budget
of $20,480 for the district.

WATER    TREATMENT   SYSTEM
PERFORMANCE
Although there  is no legal requirement for the district
to monitor and report the performance of the  water
treatment systems, they have tried to  follow the
                                                 103

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 Figure 2. Water treatment system.
                                                                                   -S-c-fl
                            PRE FILTER .
                                         •f**-1!1—-ty—ir;
                                                                                          >—ULTRAVIOLET
                                                                                         "  DISINFECTION
                                                                                            UNIT
                                                    \
                            3/4"X 5/8
                            WATER METER
                                  ACTIVATED
                                  CARBON UNITS
           REINSTALL EXISTING 	
           WATER SOFTENER UNITS
           (IF ANY) THIS LOCATION
Table 6.
 Item
Water Treatment System Cost
                              Cost ($)
 1 Water Motor
 8 Gale Valves
 i Check Valve
 3 Sampling Taps
 2 Pressure Gaufles
 2 Cartridoe Filter Units
 2 Fiberglass Cylinders
 80 Pounds Activated Carbon @ $0.90/lb
 1 Ultraviolet Disinfection Unit
 Installation
       Total System Cost
                               150.60
                               67.84

                               140.60

                               72.00

                               392.00

                               494.00

                             1,317.04
guidance given them to sample at least 10 percent of
the systems each year.

BACTERIOLOGICAL PERFORMANCE
During the years of 1984, 1985, and 1986, 21 paired
samples were collected and analyzed for coliform
organisms. Of these,  three  untreated  samples had
high coliform  counts and one treated  sample had  a
count of 2 coliform  organisms per 100 ml (0.6 per
02). This is  a great improvement over the original
sampling where 40  percent of  the drinking water
samples had high coliform counts.

ORGANIC PERFORMANCE
The district  has  not  had enough  money  to do
adequate organic  chemical monitoring. In 1984, 10
paired samples were  collected and  analyzed for
benzene, toluene, and xylene. The detection limit was
too high to show system performance, but the sample
results did indicate  that these  chemicals were  not
present in either the untreated or treated water above
the guideline levels of 5 jag/l for benzene, and 50 pg/l
for toluene and xylene.  In 1985, four paired samples
of these  same  chemicals  were analyzed with all
results below 1 pg/l.

In  1986 and 1987,  the New York  State (NYS)
Department of  Transportation collected a series of
volatile organic samples at one  residence because of
a  nearby chemical spill.  On  December  23,  1986,
samples were collected before and after the treatment
system. The results are shown in Table 7.
Table 7.
NYS DOT Volatile Organic Samples: December,
1986
Chemical Before Treatmen AfterTreatmen
(pg/i) (ps/i)
Toluene
Ethylbenzene
p-Xylene
m-Xylene
o-Xylene
n-Propylbenzene
1,3,5 Trimethylbenzene
1,2,4 Trimethylbenzene
Cyclopropylbenzene
Total
5 <1
3 <1
2 <1
6 <1
4 <1
2 <1
4 <1
4 <1
5
35 <1
                                          On February 5, 1987, samples were collected before
                                          and  after the treatment system. The results are
                                          shown in Table 8.

                                          On March 7, 1987, no contaminants were detected in
                                          a treated sample, and on May 8, 1987 and August 12,
                                          1987, no contaminants were detected in samples
                                          collected before and after treatment.
                                                  104

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Table 8. NYS DOT Volatile Organic Samples: February, 1987
Chemical Before Treatmen AfterTreatmen
(ng/i) (ua/i)
Toluene
m-Xylene
o-Xylene
o-Chlorotoluene
p-Chlorotoluene
1 ,3,5 Trimethylbenzene
Cyclopropylbenzene
o Dichlorobenzene
Hexachlorobutadiene
Total
5
2
1
2
1
2
3
5
6
27
5
2
1
2
<1
<1
2
4
<5
16
The results  of all organic samples except one show
removal  of  the  tested  organic chemicals  to  below
detectable levels. In the sample collected on February
5, 1987, contaminants were detected in the treated
water sample  at 5  jig/l (5 ppb) or  less.  The limited
test results are not comprehensive enough to make a
definitive statement  on  the  removal  of  organic
contaminants,  but they do give an indication that the
treatment system is performing satisfactorily.
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       COMMUNITY DEMONSTRATION OF POU SYSTEMS REMOVAL OF ARSENIC AND
                             FLUORIDE: SAN YSIDRO, NEW MEXICO

                                           Karen Rogers
                                    Leedshill-Herkenhoff, Inc.
                                     Albuquerque, NM 87103
San Ysidro is a small, rural village of approximately
200 people located in the north  central  part of the
State of New Mexico, approximately 50 minutes north
of Albuquerque. The village is at least 200 years old.
U was settled by Spanish colonists on a land grant
from  Spain  in  1786. San Ysidro lies  between the
lands of the Zia and Jemez Pueblo Indians along the
Jemez River. Life in the community is  simple  and
relaxed and most residents live there for  exactly that
reason. The mean annual income for families in  San
Ysidro is $13,500.  Fifty-eight percent  of  families
earn less than $10,000 a year.

The village water supply  is collected in an infiltration
gallery into which ground water is drawn. This  local
ground water contains  leachate  from  geothermal
activity in the area's abundant mineral deposits and is
therefore high in mineral content. The ground water
exceeds the standards and/or maximum contaminant
levels  (MCLs) for arsenic, fluoride, iron,  manganese,
chloride, and  total dissolved solids. The contaminants
of concern in the village water supply are arsenic V
and III and fluoride,  which exceed the MCLs by three
to four times (Table 1).
Tablo 1.   Average Water Quality in San Ysidro, New Mexico

               Cone.   Max. Contaminant Level  Avg. After
               (mfl/I)
or Rec. Std. (mg/1)
RO (mg/l)
Iron
Manganese
Cntondo
FkwkJo
Arsonlc V & 111
IDS
2.0
0.2
325.0
5.2
0.22
1,000.0
0.3
0.05
250.0
1.8"
0.05
500.0
0.015
<0.01
12.50
0.40
<0.01
< 180.0
 * RoconlJy revised (o 4.0.


Prior  to discussing  the  point-of-use  (POU)
treatment that is installed in San  Ysidro, a better
understanding of the San Ysidro water system is
necessary, including some general problems which
have a direct bearing on the future success or failure
of the point-of-use devices.

As mentioned before, the village water supply source
is an  infiltration gallery that produces an  average of
27,000 gpd in winter and 36,000 gpd in summer from
the ground water. The infiltration gallery has a storage
capacity of 17,000  gallons. The village currently uses
an average of 30,000 gpd. This equates to about 150
gpd per person. This consumption rate pushes  the
production/storage capacity limits of the gallery.

There is a 20,000-gal  elevated  storage  tank
connected  into the piping  system that  should  be
providing the additional capacity the village needs,  but
it has seldom  been a  functioning unit for several
reasons. First, the pumps that are currently located in
the infiltration gallery do not have adequate  controls
to allow them to operate appropriately to maintain an
adequate supply of water in the system. There is no
remote readout on the status of the pumps or system.
The only way to know there is a problem is when a
faucet is opened and no water comes out. Secondly,
the village does not have one person who knows  the
system and  who has  the  responsibility  to  keep it
operating. A village employee, the major or one of  the
village council usually goes down to turn  the pumps
on when someone calls  to complain about  the low
pressure  or  to report  that they have no  water. The
pumps should be running all night,  but because of
other  problems with  the controls and overheating
pump motors, someone would need to monitor them
all night to insure safe operation; however, this is  not
an acceptable solution.  So, the village has a long
history of water supply problems including low water
pressure,  no water  at  all,  and  quality  problems
including  taste,  color,  clarity, and odor in  addition to
the contaminant levels discussed earlier.

A number  of  alternatives  have  recently been
investigated  by  engineers at Leedshill-Herkenhoff to
aid  the  village  in  obtaining a higher quantity and
quality of water. When the village  first was found to
be in violation of the Safe Drinking Water Act (SDWA)
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for levels of arsenic and fluoride in the water supply,
four deep test wells were drilled to determine if there
was  a better source of water available. The best of
these wells only had  water equal in quality  to  the
water in the infiltration gallery. It was at this point that
treatment  options began to  be  studied.  The
recommendation  for added system capacity  at this
point  was  to increase the  size  of the infiltration
gallery. The village obtained bids to perform this work
but all of them exceeded the available funds because
of the high  costs of  dewatering  the  site  during
construction. The village then decided to add the best
test  well  that had been drilled  previously  to  the
system.  This new  well was  recently developed  at
43,200 gpd and is  being pumped into the infiltration
gallery temporarily  to  supplement the  system. The
new  well will be permanently tied  into the system
under a project which  is currently being reviewed  by
the state for approval. This project will also provide an
automatic control system to regulate pumping from
the well  or the gallery to maintain a beneficial water
level in the village storage tank. This control system
will have remote readouts in the  village office  to
indicate  if  the system  is functioning normally or to
show there is a problem.

A variance from  the SDWA for arsenic and fluoride
was  granted to the' village  while  research  was
performed  by Dennis Clifford of the University  of
Houston  to determine  an economical and  effective
solution to the contaminant problem. The treatment
systems  studied were activated alumina and reverse
osmosis  (RO).  Central  and point-of-use treatment
were considered. Central treatment of the entire water
supply was not considered feasible for many reasons.
First,  there  is  a disposal  problem with both  the
arsenic-contaminated  sludge from activated  alumina
column regeneration  and the  reject brine from  the
reverse osmosis unit.  Secondly, the costs of central
treatment were  considered  to  be higher  than point-
of-use treatment. And  lastly, central treatment was
considered too complicated to  be efficiently operated
in a community the size of San Ysidro. The results of
the study indicated the  best solution to be point-of-
use treatment with reverse osmosis units. A pilot unit,
a Culligan  H-82 with  a spiral-wound  polyamide
membrane,  was installed in the community center to
assure the  effectiveness of the membrane and the
acceptability of the unit to the community. This unit
makes about 5 gpd  of water with a reject  rate of
about  10 to 20  gpd, which  is discharged into the
user's septic tank. That test unit has  now  been in
service for about three years with little maintenance
required.

Since arsenic  and  fluoride are only  considered
harmful  in  water used  for  human consumption,  a
point-of-use  unit for treatment was needed  for only
water used for drinking and cooking. A single large
RO  unit for only  the  drinking and cooking  water
supply for the village  was considered, but there were
still concerns  about disposal of larger  quantities  of
reject water and there was also doubt that the people
would be as willing to use the treated  water if  they
had to travel somewhere to get it. The EPA was also
very interested in trying  point-of-use in a small
town. All of these factors made the decision to try the
units in the individual homes a fairly easy one. It was
decided that the best place to install the treatment
units  would be in the home's kitchen,  preferably
under the kitchen sink with a separate faucet on the
sink for dispensing the treated water and a small tank
under the sink for storing the treated water.

Once it was  determined  that  point-of-use  reverse
osmosis might be  a good solution for the village, a
proposal was made to the  EPA to obtain a grant to
purchase, install, service, and monitor the units and
to  study  the  overall feasibility of  point-of-use
treatment in  a small community.  A  Request for
Proposal for engineering services  was generated and
Leedshill-Herkenhoff was retained by the village  to
oversee the project. A Request for Proposal then was
written  to  obtain  the units  in  addition  to  a
maintenance  contract for a  period  of  14 months.
Culligan was awarded the  job  and  unit installations
began in June 1986.  A public hearing was held in
which the proposal was brought before the villagers to
explain the problem with water quality and to discuss
the procedures needed  to  get the units installed,
maintained and tested during the study  period. An
ordinance was  passed by the village which made the
use of village water contingent upon installation of the
RO unit in  the  home. Each water customer also had
to sign a permission form to allow the village to install
the unit in their home and to allow access to the unit
for testing and  maintenance. A few reluctant villagers
did not  want the units installed in their homes. The
primary  reason given was that they did not think they
needed  them.  After all, people in  the town had been
drinking the water for years and  it did  not seem to
hurt them. Another reason was the permission  they
had to give the village to be able to enter their homes
to install, test,  and maintain the units.  The reluctant
few were  inevitably persuaded, however, when  they
were  informed their water was going to  be shut  off if
they did not comply.  There are still  a few people in
the community who do not drink  the water from the
RO units. They say they do not like the taste of the
treated water and  are either getting  water elsewhere
or drinking the untreated water.

Currently, 70  units are available  for testing on this
project.  There  are a few units in  unoccupied homes
which the  village  has been reluctant  to take the
initiative to remove. The  70 units are  tested  every
other  month  for  arsenic  and  fluoride  and
approximately every three to four months for chloride,
iron,  and manganese. A smaller sample group  of
about 30 units is' being sampled for  bacteria. The
testing  portion of  this project  has  been  difficult at
times because of the  inability to obtain samples when
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homeowners are away. Some residents of San Ysidro
are home only on weekends, and many work during
the day. The sampling has been done by a village
employee.  He has reported that he has trouble from
close to half the residents when  getting  samples.
Most of the complaints are about the inconvenience
of having to let him  in. One resident draws her own
samples because  she  refuses to let the  village
employee in her home despite the permission to enter
that she signed. It usually takes  2-1/2 days to collect
samples from 25 to 30 homes.
Because of the time frame involved, we  have only
been able to obtain 10 bacteria samples during  each
sampling. These are usually  taken on a  weekday
morning. All of the samples are  picked up and taken
to an independent laboratory  in Albuquerque  the
afternoon of the day the bacteria samples are drawn.
There have been occasional problems with  coliform
counts in the RO units. Out of 96 tests that  have
been performed over the last 10 months, there  have
been six positive tests ranging from one to TNTC (too
numerous  to count).  The tests have  also been
differentiating  between  conforms and  noncoliforms.
We have been getting positive noncoliform readings
also, almost always in conjunction with a high coliform
count. Our procedure has been  to have Culligan
replace the filters and  the RO  module and disinfect
the tubing  and tank on  the units that have shown
coliforms in the treated  water.  The EPA  lab  in
Cincinnati will be attempting to identify the species of
coliform we are seeing as soon as we get another
positive  test.  (This was  done recently  and the
coliforms were identified  as E. coli.)  Culligan has
recently  recommended  an alternative disinfection
technique utilizing hydrogen peroxide that will be less
expensive.  The replacement costs of the filters and
membrane  run about $200 (see author's note).

There are  a few possibilities for the source of the
coliforms that we have been trying to  pinpoint. It is
possible that the  low system  pressure  may be
inducing  back  siphonage  from  some  cross-
connections in the individual homes. It was  recently
discerned that many of the units installed in San
Ysidro had not been installed with an air gap on the
discharge line from the RO module. These could very
well  be the  cross-connections  that  have been
causing us to see coliforms in  testing. Discussions
with  the installer  of  the units  revealed some
disinformation  regarding the air gaps. He felt the air
gaps  were  not really necessary  and that it was just
one  more  place for the units  to develop  leaks.  In
further discussion it was explained that without the air
gaps, especially  in  San  Ysidro, where  we have
frequently seen low or  no pressure on the  water
system, the  likelihood  of back  siphonage  is much
greater.  The  installer  is  currently rectifying  this
problem.

It  is  also  possible that the  source  could be
somewhere in the system. The village water supply is
chlorinated  by a  hypochlorination  system  at  the
infiltration gallery, The village has had problems in the
past with the chlorination system. San Ysidro was on
a boil order a few  years ago for a  coliform infraction
prior to the installation of the RO  units. During the
test period we have not had a positive coliform test in
the  system, but  the monthly  system  sample is
obtained very close to the chlorinator.  The  piping
system in the village is arranged  in a three-spoke
system with  the water  supply  at  the  hub and the
pipes  dead-ended at the  edges  of  town.  This
arrangement could encourage bacterial growth in the
stagnant ends  of the  pipe  but the  positive  test
locations do not seem  to support this theory.  The
locations of homes with positive results are not in any
particular location on the system. The  State of New
Mexico Environmental Improvement Division (EID)
has  encouraged the village  to  monitor the chlorine
residual and even provided  them with a  monitoring
device, but they have been uninterested in using  it. If
an adequate chlorine  residual was  maintained  in the
system, it might reduce the coliform  problems in the
units by removing a potential bacteria source. We will
be  recommending to the village  that  they start
monitoring their system chlorine residual especially at
homes that show a positive bacteria count in the RO
unit. The Village should also retest the treated water
and  test the untreated  water at that home after  a
positive test result. In the one home in which we were
able to do this, the test had shown six coliforms  and
three noncoliforms. The  retest showed 0 coliforms
and 0 noncoliforms in the RO treated water and  137
noncoliforms in the regular sink water. These  retests
could prevent some unnecessary maintenance costs.
We will also be recommending to the village that we
continue  testing each unit for bacteria at least every
three months until all of the air gaps are installed
properly  and they have the  new  pumping system
maintaining a minimum system pressure of at least 20
psi, and until they have not had a positive test result
for at  least six months.  After those conditions  are
met, we feel they  should  be able to decrease  testing
to every six months for each unit.

Initial evaluations of the test results  obtained from the
RO units indicate  removal rates  for arsenic, fluoride,
chloride,  iron, and manganese to be consistent with
the manufacturer's data for the  units  despite the low
system pressure  experienced  frequently in  San
Ysidro. The arsenic and  fluoride  testing  seem to
indicate that some membranes may  need  to be
replaced  as  often  as once a year. We had five units
that had fluoride and arsenic tests at or close to the
MCLs in July and August. It appears there will  be two
to three  months'  warning on  these breakthroughs.
The test indicator on the unit was also showing a red
light  on  four of these  units, so this  will help  the
customer to  determine  if his  unit needs servicing.
Since the testing has shown that  fluoride tends to
break  through just prior  to  the  arsenic,  we
recommend  monitoring  fluoride  levels  in  the units
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every three months to determine when the unit needs
servicing.

The most prevalent maintenance problems are leaks.
The most likely place for the leak to occur  is at the
drain  clamp. This problem  is predominant  because
the clamp is located where it is easily bumped and it
is  just tightened  around the pipe rather  than being
attached to it. The second most common problem is
breakage of the faucet handle. San Ysidro anticipates
having their  village maintenance man  trained by
Culligan  so  that they  can take care  of  routine
problems themselves  and thus reduce their future
maintenance costs.

Expenses for the study  period have  been broken
down as follows:

   Initial units               $290.00 per unit
   Installation                 35.50 per unit
   Maintenance                8.60 per unit per month
   Testing                   25.00 per unit per month
   Replacement or New Units  350.00 per unit
The future costs  should run approximately the same
except for the testing  costs. It will  be possible to
virtually  eliminate the  laboratory testing  for arsenic
and fluoride  by  monitoring the conductivity of  the
effluent water. This is the theory behind the  RO test
module currently  installed in each  unit in San Ysidro.
If  the mathematical  correlation between conductivity
and fluoride and arsenic concentration is established,
each  unit can be tested on-the-spot by the village
employee during a  periodic inspection.  Laboratory
testing could be  reduced to random sampling every
six months  to insure continued correlation between
concentration  and conductivity.  This procedure was
discussed with and tentatively accepted by our state
EID representatives. The costs that  we do  not have
information  on as yet  are the  insurance costs for
liability and replacement. However, the reduced costs
of  using  a  village  employee  for  routine  unit
maintenance should  at least offset the insurance
costs. This would  increase  the   user's  bill by
approximately $12 per month  (the current  bill
averages $10  per month). Preliminary  studies by
Dennis  Clifford  indicated costs of  point-of-use  RO
to  be $10 to 15 per  customer per  month  and the
costs of central  RO treatment to be $30 to 40 per
customer  per  month  based  on   the   current
consumption rate (see author's note).

We are  currently working with San Ysidro's  attorney
and  the State  of  New  Mexico  Environmental
Improvement  Division  to develop an  ordinance to
govern the policy on the RO after the grant term is up
and the  village is under the state's jurisdiction again.
We anticipate that the village will continue  to own,
maintain, and test the  units in the future. The village
will also  have to obtain a special liability policy for the
units  for any water damage claims that may be made.
Another  insurance issue that came up  during  the
study period  was damage  to the unit. We  had one
unit destroyed in a house fire and two units needed
various major  parts replaced  because of  freeze
damage. In the future we feel the way to handle these
issue will be  to have the homeowner be responsible
for these costs.

Special provisions  will  be needed for  commercial
establishments. We feel the best way to handle this
issue in the future will be to have the village lease a
properly sized  unit to the business, arrange for  a
maintenance  contract with the manufacturer,  and then
add these  charges to the  business' water  bill. This
should be easier than having the businesses or  the
village purchasing the units outright and  should also
give the village flexibility  with  new  businesses that
may require smaller or larger units.

On the whole, community reception to the units has
been  positive.  Most villagers like the taste  of  the
treated water, especially for coffee and ice. There are
still some residents, primarily those who have lived in
San Ysidro all their lives, who do not like and do not
drink  the treated water.  They still drink the untreated
water. There  are also a couple of  residents who  still
bring  in their drinking water from elsewhere.  There
are a few villagers who  are on  the water system  but
who do not  have indoor plumbing, a sink,  or other
convenient place  to install the  unit.  They have
expressed a desire to obtain the units but have had to
be turned down until they have  a place for the unit to
be installed.  There  are also some  residents who  are
dissatisfied  with  their individual wells  who  are
considering getting on the village  water  system and
are interested  in  the  RO units. Eighty  units were
purchased  initially for the Village and currently 79 are
installed. This  number  has been sufficient for  the
study  period, but a few extra  will be  purchased  so
there will be some spares available in the  near future.

In conclusion, I would like to summarize the  pros and
cons  that I've seen with  this project. First  the negative
issues: sampling  costs can  be  much  higher  for
multiple point testing of  point-of-use  systems than
single point testing of central treatment. With point-
of-use, control of the treatment  process  is dispersed
from a central point to multiple points. To  maintain the
same level of control, more regulating and monitoring
must take  place. Obtaining samples can be  difficult
and time consuming, contributing to higher costs  and
decreased  control  over testing. With a  point-of-use
treatment  system,  another factor  that  must  be
considered is initial  and continuing education of the
consumer.  New members of the community must be
indoctrinated  to  the system, and existing users must
be reminded periodically  of their  responsibilities.
Point-of-use  also inherently generates  more
bookkeeping  for the village clerk. The responsibility
for tracking,  testing, and  maintenance for each  unit
will be a part of the job. Another problem that is an
inherent part  of  point-of-use  treatment  is  do-it-
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yourself plumbers. It is an irresistible urge for some
people to tamper  with or  try  to fix the  units
themselves since the unit is located in an accessible
part of the home.

The positive side of point-of-use  in San Ysidro is
much  more encouraging. The RO  units have very
much improved the aesthetic as well as health quality
of the village's drinking water. The units are simple to
install  and maintain. The units are undoubtedly the
least expensive  solution to  treatment for the village
and its residents. The vast majority (90 to 95 percent)
are happy with the system and the water it produces.

This project has been challenging for the community
of San Ysidro. If the units are  to continue to function
as  part of the  village's treatment system,  the
community will need encouragement and technical
and regulatory  support  from the State  of  New
Mexico's  Environmental Improvement Division. The
village will need to begin recordkeeping on each unit
and diligently  maintain  those  records to insure the
maintenance  and testing continues as required. We
wilt also have to see how the community will respond
to the additional costs on their water bills. The future
success of this project will depend  heavily on the
abilities of the Village of San Ysidro to cope with the
recordkeeping for testing and maintenance of the
units, but this would surely be a problem for central
treatment  as well.  Point-of-use  treatment is  the
best choice for San Ysidro's water system at this time
and will  continue  to  be the  best solution  until
population growth in the village will  support the costs
of a central treatment plant.

Author's Note: This report has been revised to reflect
pertinent  additional  data  and  information obtained
since it was presented.
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                  FLORIDA'S FUNDING FOR CONTAMINATION CORRECTION
                                           Glenn Dykes
                                         State of Florida
                           Department of Environmental Regulation
                                      Tallahassee, FL 32399
For years Florida has had considerable concern for
drinking water quality because of the expanding use
of its ground water resources.  The  potential  for
contaminating these resources is great in view of the
state's rapid  growth and  the  vulnerability of this
valuable  source  of  potable  water. Water quality
problems have been confirmed by extensive analytical
work, and now  these contamination issues must be
addressed.
Consequently,  full evaluation and  correction of all
possible  contamination  would  take considerable
money, time, and effort.  An important aspect of the
use of EDB was the fact that the state, under contract
to the citrus grove owners,  applied the chemical for
nematode  control.  Since  the  state and Federal
agriculture  departments  approved  of the chemical
usage,  it found broad acceptance in the agricultural
community.
DEFINING THE PROBLEM
Over 90 percent of the state's drinking water comes
from  underground  resources.  Included in these
supplies  are approximately  10,000  wells  serving
public  and semi-public facilities along with several
hundred thousand private wells, serving individual
homes. There is a wide disparity in the  quality and
the vulnerability  of  the  ground  water  resources
meeting the demands of these water supply wells.
Many  of  the public  systems  utilize the  deeper
limestone  strata while the private wells primarily tap
the shallower aquifers.  These  two  sources have
different  problems  and  concerns,  but both  are
susceptible to contamination that has been verified by
analytical work on these resources.

Early  in the organic quality testing work by the  U.S.
EPA,   several of Florida's  public  supplies  were
analyzed. The EPA efforts and testing by the state's
own  laboratories  confirmed   suspicions of
contamination of the state's ground water supplies.
From  these early endeavors,  the state developed a
very comprehensive set  of  rules  and  regulations
governing  ground water protection, as well as the first
regulations  in   the nation setting  maximum
contaminant levels  (MCLs) for  volatile  organic
compounds. The driving force for these actions was
the realization that the agricultural chemicals, aldicarb
and ethylene dibromide (EDB), had also  been found
in samples from  many  of  the  private  wells. From
further assessment  of this  problem, it was  also
learned that these chemicals, particularly EDB, had
widespread usage throughout  the  state.
LEGISLATIVE EFFORTS
The  findings  of organic contamination; in both the
public and private  potable water  supplies brought
about vocal  manifestations of  the  electorate's
concerns.  The legislature started looking for ways  to
correct these  problems. In 1983  they  passed the
Water Quality Assurance Act (WQAA), which  was
very broad legislation  addressing  a wide  variety  of
items related to ground water  contamination  and
providing funding for their resolution. This act spelled
out numerous ground water protection issues, which
included requiring public water suppliers to investigate
a broad spectrum of contaminants, studying private
wells, and funding  related  research and emergency
corrective  actions.  Law  makers the following year
provided  $3.1  million  For  solving  the  EDB
contamination  problem  caused by the  state's  own
activities. The 1986 legislature broadened the WQAA
and  provided additional  funding  to  correct  EDB
contamination and other health related water  quality
problems over which the well owners had no control.
This legislature also provided funding  to address
contamination  from  leaking underground petroleum
storage tanks through the establishment of the Inland
Protection Trust  Fund (IPTF).  Backed by  this
authority,  the  Florida  Department  of  Environmental
Regulation  (FDER)  could  restore  or  replace
contaminated private wells (WQAA and IPTF)  and
public wells  (IPTF)  without  waiting for  legal
determinations of responsibility. Funds for  correcting-
problems in public supplies were not available under
WQAA though assistance was provided with the
state-affected EDB monies.
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RESTORATION/REPLACEMENT OF
SUPPLIES
The Ground  Water Contamination Task Force, which
was organized to address EDB and other contaminant
problems, had to evaluate the potential concerns and
how to approach  each one. Initially,  activities  were
directed  at EDB.  The  group determined  that
correction would have to  be provided for the entire
household,  mandating  point-of-entry treatment as
the only approach. Through research funding, data
were developed to  indicate that granular  activated
carbon  (GAG)  would effectively  adsorb  EDB. The
state collaborated  with EPA to  fund a project  to
provide definitive  numbers  for both  packed  tower
aeration and GAG  that would assist in treatment unit
designs. Research funds were also used to evaluate
the viability of  replacing contaminated supplies with
properly constructed wells into the deeper aquifers. In
the final analysis, this approach did not prove feasible
for widespread application.
The use of GAG filters was determined to be the best
alternative  to correct  the numerous private wells
contaminated with  EDB. Since the volume  of water,
usage habits, and other parameters that influence the
effectiveness of GAG were all undefined, a  very
conservative  filter  design was  devised.  A 0.06-m3
(2-cu ft)  GAG filter was  selected  with  a  5-pm
(0.0002-in)  pre-filter,  a  water meter,  and an
ultraviolet (UV)  light included in the standard unit
(Type I). These  units were installed  to handle
contamination up  to 10 ug/l. Higher contamination
warranted additional GAG  filter units (Type  II). If the
expected water consumption was more than 10 gpm,
larger GAG units were provided  to handle increased
flow. Formal  bid proposals were  solicited to obtain a
qualified  supplier, since it was  realized  that a large
number of units would be needed. The proposals also
included operation and maintenance items such as
the planned  replacement every six months of GAG
material and UV lights.

Of the 12,400 wells  analyzed  for  EDB through
October 1987, 1,530 were found to exceed the MCL
of 0.02 pg/l.  Most of these  (~ 1,400) served  private
residences. Where possible, a permanent solution to
correct the problem, such as connections to existing
community supplies, was utilized. At present we have
over 550  Type I and  60  Type  II units  installed on
state-affected wells. There are also 230 Type I and
2  Type II  GAG filters  on non-state:affected wells.
Because of different statutory requirements, records
on each program  are  separately maintained.  The
overall EDB  corrective  effort has also required the
installation of larger units on some of the public and
semi-public  systems.  There are  seven  larger GAG
units  between 50  and  200 gpm capacity and three
municipal systems with capacities up to 3,000 gpm.
Under the state's current contract,  the Type  I
installation cost is $1,000, and the cost of Type II
units  is $1,050. The annual carbon  and UV  light
replacement cost is $890 for the residential type unit.
The overall program is  currently being re-evaluated
to determine if the longevity of the GAG filters can be
extended  past  the  current  six-month  replacement
cycle.  It is estimated that each month's extension
would  save approximately $40,000. If the foregoing
GAG units and maintenance costs are evaluated, one
can easily see that annual outlay is quite large. The
annual maintenance cost for the residential units and
the  aforementioned larger  systems will exceed $1
million when the remaining planned units are installed.

In view of the potential future maintenance cost, the
state  has attempted to evaluate the  economic
feasibility of extending existing  water lines to replace
the residential supply wells. To determine the current
cost of the filter installations  for their lifetime, the
annual replacement cost was projected for io  years
and then returned to present worth using five percent
inflation and  eight percent interest. This  value was
then added to  the installation cost of the filter  to
determine the  most economical  approach;  i.e.,
individual  GAG filters, extension of water  lines, or a
new central system.  Under the current contract, the
calculated  cost for use  in this feasibility  analysis  is
approximately  $8,600.   Since additional organic
sampling  is required  to insure  that  public  health
concerns  are not compromised, an additional annual
cost of $400 should be added.  This would add
approximately $3,400 to the aforementioned present
cost consideration.  With the logical addition  of
sampling cost, $12,000 should  be used to determine
the  economic feasibility  to provide  a permanent
alternative  to the point-of-entry solution.

SUMMARY AND  CONCLUSIONS
Garbon filtration has been found to be a satisfactory
method of removing EDB from contaminated supplies.
The FDER is also utilizing  GAG  filters in correcting
contamination  problems  created  by  leaking
underground petroleum storage tanks under the IPTF
program.  Current testing indicates that  GAG will
remove benzene and other hydrocarbons and thereby
solve  some  of the  problems  related   to  these
contaminants.

The use  of point-of-entry solutions must consider
the  long term cost  in  considering the  economic
viability. The cost  as  shown  in the  foregoing
discussion can be large.  The annual maintenance and
sampling cost must be  given a thorough evaluation
before determining that point-of-entry  devices are
to be placed  on all residences in a community. It  is
always gratifying when a permanent solution can be
found and the utility does not have to worry about the
maintenance  problems that always seem to plague
these small installations. The present projected cost
of $12,000 per house with a Type I  connection would
go a long way  to provide a central system for the
whole community.
                                                112

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                MONITORING AND MAINTENANCE PROGRAMS FOR POUlPOE
                                        Gordon E. Bellen
                                       Thomas G. Stevens
                                National Sanitation Foundation
                                      Ann Arbor, Ml 481 OS
INTRODUCTION

Small  communities with  organic  or inorganic
contaminants in  their drinking  water  supplies often
lack the financial resources to  solve their problems.
Economies of scale prohibit construction of a central
treatment  system for contaminant removal in many
cases.  Construction of an alternate well or connection
to a neighboring water  supply  may not be feasible.
One alternative solution, which has been -receiving
more  attention'  in recent  years,  is treatment  of
contaminated w^ter at  the point-of-use  (POD)  or
point-of-entry (POE).

All  POD  devices are designed to  treat only water
intended  for consumption. Approaches  to POU
treatment  include  batch process treatment,  faucet-
mounted  devices,  in-line devices,  and line-bypass
devices. A batch process device treats one batch of
water at a time, is not connected to  the water supply,
and may  rest on  the  kitchen  countertop.  Faucet-
mounted devices are attached  directly to the faucet.
In-line  devices are installed between the cold water
supply  and the kitchen faucet, and generally treat the
entire  kitchen cold  water supply. With the  line-
bypass approach,  the cold water line is  tapped to
provide influent to a treatment device, which may be
installed under the  kitchen sink, and a separate tap is
provided at the sink for treated water.

POE water  treatment treats all water entering  the
home  and  has  been  proposed  for  contaminant
removal where potential health  risks associated with
skin contact and  inhalation exist (1). Because they
treat all water entering the home, POE devices must
be  much  larger  (in terms  of  volume  treated)  than
POU devices. The length of time in service between
media  replacements however, is typically 25 percent
of that  of POU devices.

The U.S.  EPA has specified when, and under what
conditions, POE  and POU  water treatment can be
used (2).  Although not considered Best Available
Technology (BAT), POE is an acceptable method for
a community water supply to come into compliance
With  the  Drinking  Water Regulations. POU may be
used as  an additional  control  measure  during  the
period of a variance or  exemption, as a condition of
the variance or exemption. If either approach is used,
the EPA has specified conditions that must be met:

•  Central Control  - Regardless of ownership of the
   treatment device, the public water authority will be
   responsible for operating and maintaining all parts
   of the treatment system.

•  Effective Monitoring - A  monitoring plan must be
   approved by the state  before a POU or POE
   system is installed. The plan  must  assure that
   devices provide health  protection equivalent  to
   central water treatment.  Physical  condition  of
   equipment and total volume of  water treated must
   be monitored as well.

•  Application  of Effective Technology - AH  devices
   must have  certified performance (or  rigorous
   design review) and  must pass field testing.

»  Maintenance of Microbiological Safety  -  Control
   techniques such as backwashing, disinfection, and
   monitoring,  are  suggested by the EPA to maintain
   microbiological safety.

•  Protection of All Consumers - Every building must
   have equipment that  is  adequately  installed,
   monitored, and maintained. Responsibilities for this
   equipment  may  transfer  with  ownership of  the
   property.

This paper discusses  each of  these  points and
suggests ways in  which a  community might comply
with  EPA requirements.


CENTRAL CONTROL
It is important that all aspects of POU/POE treatment
come  under  central control to  assure  adequate
protection of public health. If a public water system is
already in place, the existing organization can assume
administration  of the POU/POE district.  If a  public
                                                113

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water system is not in place, a water quality  district
should be formed in a progression of steps similar to
those in Table  1 (3). In  a previous study (4),  total
administrative costs  for operating  a water  quality
district were estimated (1985 dollars) to be $1.23 per
customer per month. These costs included quarterly
monitoring  costs,  administration,   and  distribution
system maintenance (POU maintenance not included)
for reduction of fluoride  in  drinking  water with POU
treatment. Monitoring costs may be  higher for some
contaminants,   but  labor  costs can  be  lower  if
community volunteers are used.
Tfibto 1.   Chronological Steps for Formation of a  Water
          Quality District

	Process Step	

 Development phase
    Identify problem
    Consult regulatory agencies
    Water testing
    Make preliminary plans and maps

  pproyai phase
    Estimate costs
    Hold public hearing
    Property owner petition
    District formed by resolution of county/state supervisors
    Directors appointed
    Agreement with town board and property owners for cost
    recovery

 Operation Phase
    Obtain funding
    Pdot demonstration
    Select equipment
    Equipment installation
    Authorize payments
    Monitoring and maintenance
    Feedback and education
APPLICATION   OF  APPROPRIATE
TECHNOLOGY
To achieve compliance, the EPA stipulates application
of appropriate technology. Table 2 lists  currently
available technologies and the contaminants they are
effective  in  removing.  Selection  of  appropriate
technology from this list is not  straightforward,  since
variable water qualities  may make  one technology
better than another. For example, activated alumina is
effective in fluoride  reduction, but in  the presence of
high  alkalinity  and/or arsenic,  its capacity  may be
reduced (4,5).

Communities  lacking  expertise  should   seek
knowledgeable sources of  information concerning
treatment techniques appropriate  for their water. An
initial  consultation  with  the  local  or  state health
department is a good  first step. Other organizations
that can provide information are listed in Table 3. In
addition  to  those  organizations,  consulting
engineering firms can  be hired.  Regardless of  the
Table 2.  POU/POE Treatment Technologies*
Treatment Type
Reverse Osmosis**







Cation Exchange


Anion Exchange


NIPDWR
Contaminants
Arsenic*", Barium,,
Cadmium, Chromium,
Lead, Mercury, Silver,
Fluoride, Nitrate,
Selenium, Radium,
some organics,
herbicides, and
pesticides
Barium, Cadmium,
Chromium III, Lead,
Mercury, Radium
Nitrate, Selenium VI,
Arsenic III, Arsenic V,
Chromium VI
Other
Contaminants
Total dissolved
solids, Copper,
Chloride,
Sulfate.foaming
agents, corrosion



Copper, Zinc,
Ironf, Manganese

Chloride,
corrosion, Sulfate

 Activated Alumina

 Direct (Mechanical)
 Filtration
 Activated Carbon
 Distillation
         Fluoride,
         Arsenic.Selenium IV
         Turbidity

         Organics, Organic
         Mercury

         Metals, high molecular
         weight organics
Cysts ,

Color, foaming
agents, taste, and
odor
Total dissolved
solids, Chloride,
Sulfate
     Taken from the Statement of the Water Qualify Association
     to the EPA, EPA, December 13, 1983.
     Results of reverse osmosis treatment  may vary  between
     pressurized and nonpressurized units,  membrane type, and
     configuration.
     Arsenic (+3) is poorly removed with reverse osmosis.
     Low levels.
Table 3.
Organizations Providing Water  Treatment
Information or Services
                                                           Organization
                                        Service
 American Water Works Association
 666 West Quincy Avenue
 Denver, CO 80235
 303/794-7711

 National Demonstration Water Project
 1725 DeSales Street, NW - Suite 402
 Washington, DC 20036
 202/659-0661

 National Sanitation Foundation
 3475 Plymouth Road
 Ann Arbor, Ml 48105
 313/769-8010

 National Water Well Assocation
 500 West Wilson Bridge Road
 Worthington, OH 43085
 614/846-9355

 Water Quality Association
 4151 Naperville Road
 Lisle, IL 60532
 312/369-1600
                         Water l3ata Base
                         Educational Materials
                         Technical Information

                         Educational Information
                          Relating to Rural
                          Communities

                         Product Testing/Listing
                         Performance Standards
                         Technical Information
                         Technical Assistance
                         Ground Water
                         Information
                         Lists of Manufacturers
                          and Distributors
                         Technical Information
source used,  professional guidance in the selection of
equipment is important.
                                                      114

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The EPA requires certification  of performance  and
field testing of POU  and POE  devices. Certification
can  be accomplished by the state or a  third-party
acceptable to the state  (2). The  National Sanitation
Foundation (NSF)  has several performance standards
for  POU/POE devices that  address performance for
products  making  contaminant reduction  claims  for
primary and secondary regulated  chemicals, reverse
osmosis equipment, cation exchange water softeners,
and  ultraviolet disinfection equipment.  A standard for
distillation equipment is currently being written. These
standards are in the public  domain and can be used
by anyone as a  basis for product certification. NSF
also conducts a product certification  program. NSF
listings of products are available on hard copy or
through computer access  (see  Table 3 for address
and  phone number of NSF).

Field testing is important. Product certification testing
with standardized test waters  may  not accurately
indicate treatment capability or capacity for the water
a  community  needs  to  treat.  For  treatment
technologies with finite usable capacities (e.g., carbon
and activated alumina),  field tests should be run to
exhaustion to establish the useful life of the device
(useful life  defined  as  volume of water  treated to
breakthrough).  Accelerated  field tests using surface
adsorbents  like carbon  and  activated alumina  will
provide conservative estimates of  useful life. Tests of
devices with media  which  can  be regenerated  will
provide estimates of annual regeneration costs. Other
devices like reverse osmosis and distillation, that do
not  have a  readily  definable  useful life,  can be
evaluated quickly for percent removal of undesirable
contaminants.


EFFECTIVE MONITORING
The EPA requires monitoring to assure protection of
the  public health comparable to central treatment. To
achieve that goal, a monitoring program  should be
established which provides reasonable assurance that
all water provided at the tap is in compliance with the
National  Primary Drinking  Water Regulation.  The
results of field testing should help in that regard. In
addition,  the total  volume  of water treated  and
physical condition of each unit must be monitored (2).

The system  performance monitoring  program will be
influenced  by   field  test  results,  community
experience, and  whether  treatment  is  intended to
achieve compliance.  A rigorous  and conservative
monitoring program, assuming one technology or type
of device is being used, is outlined in Table 4.  This
program  addresses POU/POE  treatment  on a
distribution  system.  Treatment of a  system of
individual wells would require more frequent sampling.
This  monitoring  program  is  intended to  assure
adequate operation  of the POU/POE  treatment
system.  Additional  source water  monitoring  is
required by the EPA. A description follows.
Table 4.   Suggested Minimum Monitoring Program*

 Task	Frequency  	

 Contaminant Monitoring
  First Year              Minimum of seven devices per
                       quarter; if useful life is less than
                       one year, test at each quarter of
                       estimated life.
                       Minimum of seven devices per
                       quarter; select some known high
                       volume users.
                       Minimum of three per quarter. Test
                       minimum of seven units at
                       replacement to reconfirm useful life
                       estimtes.

                       Minimum of seven per quarter or
                       number required by EPA population
                       based monitoring plans, whichever
                       is higher.
                       If positive coliform results
                       obtained.
                       (May be provided by
                         homeowners)
                       25 percent of devices/quarter.
                       10 percent of devices/quarter.
 Second Year
 After Useful Life
 Established
Microbiological Sampling
 Routine Monitoring
  Heterotrophic Plate
  Counts and Conforms

  Fecal Conforms

Treated Volume
 Recordings"
  First Year
  After First Year
    In addition to other system monitoring requirements.
    Volume recorder for treatment unit, not whole house meter.
Field test results should be  used to estimate useful
life  of  component parts  (e.g., media,  cartridges,
prefilters,  etc.),  although  manufacturers  and/or
consultants can also provide guidance. In addition, a
sampling  plan  that  confirms  total  community
compliance is necessary. The plan should provide the
minimum  number of samples to accurately  and
statistically  represent the number of installations.  In
this  example,  seven installations were assumed to be
the  sample size. If the useful  life is one year  or
greater,  sample  quarterly. For  less than  one year,
sample at intervals of 25 percent of useful  life.  At
least seven of the devices should  have effluent
samples  checked immediately  after  installation.
Continue quarterly  sampling  of  seven  of the devices
so that devices  have been  tested  for  treatment
performance throughout the first year of operation.
Quarterly sampling of a minimum  of  seven devices
should be continued  until  the  useful  life  of all
components under normal operating  conditions can
be more precisely defined. Once this more  precise
useful life  has been established, replacement can be
tracked based on the volume of water treated. Actual
performance  sampling  can   then  be  based  on
recommended sampling frequencies for central water
supplies.

If an effluent sample from a device is positive prior to
the  estimated useful life,  resample to  confirm that
breakthrough  has  occurred.  Replace the  treatment
component of a device if breakthrough is verified.
Test an additional seven devices to determine  if early
breakthrough  is occurring throughout the system.
                                                   115

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The  sampling  may  be reduced  as  community
experience increases.  In most cases, it  will be  less
expensive to replace components prematurely than to
sample frequently enough to optimize component life.
Water meters are available with automatic shut-offs,
alarms, and even telemetry. A comprehensive treated
water  volume monitoring system can  be easy  and
economical  to establish  and  operate. User  histories
should be  established to  guide  meter  reading
schedules.

If useful life  is monitored based on gallons  of water
treated, one  of the more important effluent  samples
for the device becomes the sample taken  immediately
after installation. This sample serves two purposes: 1)
it assures that the device is operating, and 2) it can
identify media contamination.  Media contamination is
rare, but has been noted on occasion (6,7).
The  physical condition  of the  device  should be
verified upon installation and an operational check of
the  device  should  be  part of  the   installation
procedure. Most problems  with  faulty  devices or
installations  will  occur  within  the  first few weeks of
operation (4,6,7). After this initial period, spot checks
of installations  coincident with  monitoring and/or
meter readings should suffice.  However, homeowners
should have  access to 24-hour repair service.

MAINTENANCE  OF MICROBIOLOGICAL
SAFETY
The  EPA requires that communities using POU/POE
devices  for  compliance  treatment  assure that  the
treated water is microbiologically  safe. However,
microbiological safety has not  been clearly  defined.
Testing for coliform organisms does not  necessarily
indicate the presence or absence of other pathogens.
Heterotropic plate counts are even more ambiguous.
Heterotrophic bacteria  will  colonize  on   carbon  and
other surfaces, but efforts to colonize pathogens on
carbon  in the presence of competing bacteria have
not been successful (8,9). The infrequent contact of
pathogens in a water supply with a POU/POE device
should  not  result  in  a  colonization  of  pathogens
(4,6,7). Therefore, POU/POE devices may pose no
greater risk of increased pathogens than if they were
not installed. POU/POE devices should not be used
with water of unknown microbiological quality (10,11).

A monitoring program  should  include  heterotrophic
plate  counts and  coliform counts.  The EPA  has
determined that it is important to keep heterotrophic
plate counts below 500 per ml to reduce  interference
with  coliform counts (12). It has been demonstrated
that  flushing (running  water  through) devices  will
reduce heterotrophic counts (4,7,10). Consequently,  it
is important to use standard water sampling methods
for microbiological  analyses. These  methods  include
disinfecting the sample tap and running water for two
minutes prior to sampling (13), which should provide
adequate flushing.
If devices show greater than 500 organisms per ml,
using this procedure, the device or component should
be  replaced. In place disinfection  of a device  or
component  is  not  recommended since  bacteria
colonized  on  carbon are  less  susceptible  to
disinfection (9).

During the  first year of operation,  monitoring should
include  sampling a minimum of seven devices per
quarter for microbial  analyses. More sampling will  be
necessary for  larger communities.  Standard  EPA
community sampling frequencies for conforms based
on population served should be followed (12).

In  addition  to monitoring,  preventive  measures can
also  be taken. Silver-impregnated  devices  may
provide  some protection against coliform organisms,
but they will  not typically reduce hererotrophic  plate
counts  (7,10,14).  The  addition  of  a POU/POE
disinfection device is also an alternative. Table 5 lists
disinfection  technology that can  be applied  with
POU/POE devices (15).
Table 5.  Currently Available Water Disinfection Technology
        Applicable to POE/POU Treatment
 Chlorination
  Liquid Chemical Feeders

 Other Halogens
  Resin Based Brominators
  Resin Based lodinators

 Ozonators
  Electrolytic Generation

 Ultraviolet Light
  Flow Through Irradiation
SUMMARY
Providing water to consumers that meets  the  U.S.
EPA National Primary  Drinking  Water  Regulations
requires  system  organization,  maintenance,  and
monitoring. This is true whether central, POU, or POE
treatment is used. The goals for protection  of health
are the same regardless of the method used to attain
the goals.

While POU and POE technologies are not recognized
as best available technologies in the regulations, they
are considered to be acceptable for use if  specified
conditions  of  system  control,  monitoring,
effectiveness, and   public health protection are
assured.  Effective  and  reasonable monitoring  and
maintenance programs can be developed to  meet the
requirements of the  regulations,  whether within an
existing water system organization or by means of an
organization established specifically for operation and
maintenance of POU/POE systems.
                                                 116

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For water treatment  professionals with experience
only  in  central treatment,  it may,  at first, seem
extremely difficult to achieve  comparable  health
protection with POU  or POE devices. However, as
experience  is gained with  new  approaches to
community treatment,  POU  or POE water treatment
districts  may  offer attractive benefits for some
communities.


REFERENCES
1. Andelman,  J. Non-ingestion  exposures to
   chemicals  in potable  water.  Center  for
   Environmental Epidemiology,  University of
   Pittsburgh, Pittsburgh,  PA, 1984.

2. National primary  drinking  water  regulations;
   synthetic organic chemicals; monitoring  and
   unregulated contaminants. Federal Register  Vol.
   52, No. 130, July 8, 1987.

3. Bellen, G.E.,  Anderson,  M.A and Gottler, R.
   Management  of  point-of-use, drinking water
   treatment  systems.  Final  Report  U.S.  EPA
   Contract R809248010.  National Sanitation
   Foundation, Ann Arbor, Ml, 1985.

4. Bellen, G.E.,  Anderson,  M.A and Gottler, R.
   Defluoridation of Drinking Water  in  Small
   Communities.   U.S.   EPA  Contract  No.
   R809248010. National Sanitation Foundation, Ann
   Arbor, Ml, 1985.

5. Singh,  G.  and   Clifford, O.A. The  equilibrium
   fluoride  capacity  of activated alumina. Project
   summary,  EPA-600/52-81-082.  July  1981.

6. DeFilippi, J.A.  and Baier, J.H.  Point-of-use and
   point-of-entry treatment  on  Long  Island.
   Journal AWWA, Vol. 79,  No. 10. October 1987.

7. Bellen, G.E.,  Anderson,  M.A.  and Gottler, R.
   Point-of-use  reduction  of volatile  halogenated
   organics.  U.S.  EPA  Contract  R809248010.
   National Sanitation Foundation, Ann Arbor, Ml,
   July 1985.

8.  Geldrich,  E.E. et al.  Bacterial  Colonizing of
   point-of-use water treatment devices. Journal
   AWWA,  Vol. 77, No. 2. February 1985.

9.  McFeters, G.A.  et  al. Bacteria attached to
   granular activated carbon in drinking water.  U.S.
    EPA 1600/M-87/003.  Cincinnati, OH.

10. Reasoner,   D.J.  et  al.  Microbiological
   characteristics of third faucet  point-of-use
    devices. Journal AWWA, Vol. 79, No. 10. October
    1987.
11. National  Sanitation Foundation. Standard  53:
   drinking water treatment  units - health effects.
   Ann Arbor, Ml (revised June 1982).

12. National  primary drinking water  regulations;
   filtration  and disinfection:  turbidity,  Giardia
   lamblia, viruses, Legionella,  and heterotrophic
   bacteria; proposed rule. Federal Register Vol. 52,
   No. 212. November 3, 1987.

13. Standard methods  for the examination of water
   and wastewater. 16th edition,  APHA. Washington,
   DC, 1985.

14. Regunathan,  P.   and  Bauman,   W.H.
   Microbiological characteristics  of  point-of-use
   precoat carbon filters. Journal AWWA, Vol. 79,
   No. 10. October 1987.

15. Bellen, G.E.,  Gottler,  R.A. and Dormand-
   Herrera, R.  Survey and  evaluation of currently
   available disinfection  technology  suitable for
   passenger cruise vessel use.  Centers for disease
   control. Contract  No. 200-80-0535.  National
   Sanitation Foundation,  Ann Arbor, Ml. September
   1981.
                                                117

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  PO1NT-OF-USEAND POINT-OF-ENTRY TREATMENT DEVICES USEDATSUPERFUND SITES
                      TO REMEDIATE CONTAMINATED DRINKING WATER
                                        Sheri L Bianchin
                                       U.S. EPA-Region V
                                        Chicago, IL 60604
Hazardous  waste is  one of this nation's greatest
concerns. In  response to that  concern, a law was
enacted to deal with the hazardous waste problem.
This  law is  the  Comprehensive Environmental
Response,  Compensation,  and  Liability Act
(CERCLA), and is referred to as the Superfund Law.
This  law provided broad  Federal  authority and
resources to  investigate  and to respond directly to
releases (or  threatened  releases)  of hazardous
substances that may endanger  human health or the
environment.  Costs for the first  five  years  of the
Superfund program were covered by  a $1.6 billion
Hazardous  Substance  Response  Trust  Fund
established to pay for cleanup  of abandoned  or
uncontrolled hazardous waste sites.  The  law also
authorized  enforcement action  and cost  recovery
from those responsible for the release.

CERCLA was revised in 1986 as the Superfund
Amendments  and Reauthorization Act (SARA). The
purpose of the revision was to renew and strengthen
the Superfund Program. SARA reauthorizes  the
program for five years and increases the size of the
fund to $8.5 billion.

SARA gives  the  United  States  Environmental
Protection Agency (U.S. EPA) the  authority and
responsibility to control the actual or potential release
of hazardous substances that pose a threat to human
health or welfare or the environment. Other Federal
agencies will  provide assistance as necessary during
response. A comprehensive  regulation known as the
National  Contingency Plan  (NCP) describes  the
guidelines and procedures for implementing this law.
The law, SARA,  requires  that  hazardous  waste
cleanups do the following:

* Protect human health and the  environment;

• Provide  for a  cost-effective  solution  with an
  emphasis on treatment and permanent destruction
  over off-site disposal; and

* Compliance with all Applicable or Relevant and
  Appropriate Requirements  (ARAR).,
ARARs are those standards or criteria promulgated
under state or Federal law to specifically address the
abatement of  contamination  by  a hazardous
substance, cleanup standards, or advisories.

Federal ARARs may be derived from the following:
« Safe Drinking Water Act (SDWA);
• Resource Conservation and Recovery Act (RCRA);
• Clean Water Act;
« Clean Air Act;
« Toxic Substances Control Act;
• Federal Insecticide,  Fungicide, and  Rodenticide
  Act; and
« Great Lakes Water Quality Act.

Over  two-thirds of the  Superfund , actions to date,
deal with a contaminated drinking  water supply.
Where SDWA Standards are  applicable to  the
Superfund cleanup,  maximum contaminant levels
(MCLs) are usually used.  A MCL is an enforceable
standard for each contaminant, which  the act directs
U.S.  EPA to set  as close to the  maximum
contaminant level goal (MCLG) as feasible. Decision
on  the level of a MCL that is  "feasible" includes
consideration  of  the best  technology treatment
techniques and laboratory analyses that are available,
taking cost into consideration.

On  the other hand, a MCLG is a nonenforceable
health goal.  It is  a numerical limit  set for each
contaminant at the level at which no  adverse health
effects on persons  can be expected,  with  an
adequate  margin of safety.

MCLGs may be used as cleanup criteria on  a  site-
specific   determination.  One factor  in this
determination  is whether  multiple contaminants or
multiple pathways of exposure exist on  the site.

Also important in determining  the ARARs from  the
SDWA is  the use or potential use  of the water that is
or is likely to may become contaminated.

The NCP lays out three  types  of responses  for
incidents involving hazardous  waste.  These
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responses are immediate removal, planned removal,
and remedial.

A  removal action  is designed  to be a  short-term
action to stabilize or clean  up a hazardous site that
poses an immediate threat to human, health  or  the
environment. Typical  removal actions include
removing tanks or drums of hazardous substances on
the surface,  installing  fencing or  other security
measures, and providing a temporary alternate  source
of drinking water. Removals may be divided into  two
categories: immediate  and planned  removal. U.S.
EPA's policy  has been that in order for U.S. EPA to
initiate  a removal  action for contaminated drinking
water, the level  or concentration of the contaminant
typically should  exceed the 10-day health advisory.
This policy is  expected to become more stringent in
the near future.

An immediate removal or a time-critical removal is a
prompt  response taken to prevent  immediate and
significant harm to human life or the environment. By
statute, the action must be completed within one year
and the cost of the action shall not exceed  $2  million.
Immediate removals are taken to bring a  release of
hazardous  substances under control; they are  not
intended to eliminate  completely every  long-term
problem. Immediate  implementability is  the  major
consideration in choosing a remedy.

The other type of removal is termed a planned or  non
time-critical  removal.  This  type  of  removal  is  an
expedited, but not necessarily immediate,  response.
A  planned removal action is also limited by time  and
monies involved  in the cleanup.

Typically removal actions are completed by  U.S. EPA,
whereby U.S. EPA will subsequently attempt cost
recovery from any identified responsible parties.

A  remedial response entails a long and complicated
process aimed  at identifying  and completing a
permanent  remedy  to remediate  and  abate  the
hazards at a site. A remedial action is designed such
that a thorough study is completed prior to  the design
and construction of a  selected  remedy.  Technical
measures can be selected only after  evaluation of all
feasible  alternatives  on the basis of economic,
engineering,  and environmental factors. Specifically
addressed in a study  are the ability to protect public
health;  technical  feasibility; environmental
effectiveness; ability to meet ARARs; compatibility
with  other   Federal,  state,   and local   laws;
constructibility;  reliability;  cost; and  community
acceptance.  The  intent is to derive the  maximum
benefit  from  Superfund as a whole.  EPA can only
conduct  remedial  responses  to those sites  on  the
National  Priority  List (NPL). The NPL is a list of the
nation's  most  serious hazardous waste   sites.
Typically sites are identified for  listing by the state. A
preliminary assessment is  performed on  each site.
The sites are scored by the Hazard Ranking System
(HRS). The HRS looks at potential pollutant pathways
that  may  reach a  receptor,  like the  ground  and
surface water pathways that may  affect  drinking
water.  Scores greater  than 28.5 are  listed on the
NPL.

After a site is included on the  NPL, a remedial action
is planned in a series of defined steps. These steps
are as follows:
• Remedial Investigation/Feasibility Study (RI/FS);
• Remedy Selection; and
• Remedial Design/Remedial Action (RD/RA).

A RI/FS is utilized to examine the type and  extent of
the contamination,  and identifies and  screens the
possible remedies. Remedies  selected  must strive to
be of a permanent nature. When the  final decision on
a remedial action or an operable unit of a remedy is
reached  in the  remedial  process,  they  are
documented in a Record of Decision (ROD). The last
phase  in the  remedial process, the RD/RA, is the
design and construction of the selected remedy.

A  Superfund  action  is typically  funded   by  two
mechanisms. The  first type  is a Superfund-funded
remediation  where no responsible parties have been
identified,  or no legal agreement for the responsible
parties to conduct  the  work  can be  reached.  The
second  type  is   a  Responsible  Party-funded
remediation, where the  responsible party  pays for the
cleanup, and EPA serves to oversee the action.

The first step in any Superfund action, whether it is a
removal or remedial action, is to identify and confirm
the extent and types of contamination that exist.  Next
the levels identified  are compared with the standards
and  health effects information.  Last, the method  of
correction and time required to finish the project are
determined. The remedy selected will depend upon
whether the action is a removal or a remedial action.

As a short-term response  to  alleviate the immediate
danger of contaminated drinking  water,  bottled water
is  routinely  utilized. This type of response is most
often used in a removal action.

In the interim, the following are commonly considered
alternatives where drinking water is a concern:
• Continue providing bottled water;
• Provide alternative water;
• Installation  of Point-of-Use  (POU)  Treatment
  Devices; and
•  Installation  of Point-of-Entry (POE)  Treatment
  Devices.

These types of  responses may  be  used in either a
removal or remedial action.

A  POU treatment device is one used at the tap to
purge the water of  contamination prior to drinking.  A
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POE treatment device is one used as water enters a
house to purge the water of contamination. A POE or
"whole house"  treatment unit  treats  the entire
household water supply. POU/POE devices typically
involve aeration  (air  stripping), adsorption  (granular
activated carbon), or reverse osmosis.

As a  longer  term response,  or as a  permanent
remedy,  the  following  are  commonly  considered
remedial  alternatives for a  contaminated drinking
water supply:

•  Connect to  a community water system;
•  Provide a new water source (well or surface); and
•  Maintain individual  treatment  unit  previously
   installed.

These types of responses may be used in either a
removal or remedial response. Next discussed will be
case studies at two Superfund sites. The first case
that will be discussed is the Byron Johnson Salvage
yard in Byron, IL. See Figures  1  and 2 for maps of
the Superfund site investigation area.

Byron  Johnson is a 20-acre salvage yard located in
a rural area of northern Illinois.  The site is owned by
three individuals, and it has been determined that
domestic waste and metallic debris were deposited at
the site. It is also suspected that open dumping  has
occurred.  A description of the site  history follows.

In the 1960s, the salvage yard was  operated as  a
Junk yard, where miscellaneous  wastes  and debris
were brought for disposal. In 1970 to 1972, the Illinois
Environmental Protection  Agency (IEPA) conducted
periodic  inspections to  identify  any  operating
deficiencies. In  1972,  IEPA ordered  closure of  the
salvage yard.  The salvage yard ceased operation in
1974. In December 1982, the site was placed onto
the NPL  In May 1983,  under  agreement with U.S.
EPA, the  IEPA  performed a state-lead RI/FS. This
study specifically focused  on contamination directly
on  or  below  the site;  ground  water contamination
potentially  emanating  from  the  site  was   not
addressed.

Through 1984 and 1985, the U.S. EPA, IEPA, and the
Illinois  Department of Public Health (IDPH) continued
to monitor the  contamination levels in residential wells
located nearby  and down-gradient  from the site.
Through  periodic sampling,  off-site  ground water
contamination  by volatile organic compounds (VOCs)
was documented. It was found  that private  wells
contained  trichloroethylene (TCE) in  concentrations
up to 710 ug/l. In June 1984, the IEPA completed a
RI/FS and signed a ROD to remove drums of waste
and contaminated soil from the site. In July 1984,  the
U.S. EPA  placed the residents whose water exceeded
200  ug/I in the Dirk Farm area  (i.e.,  those residents
along Acorn and Razorville Roads) on bottled water
as a temporary measure. Late in 1984, the U.S. EPA
contracted to have a RI/FS performed at the site. In
July 1985, a U.S. EPA action was started to augment
the data collected from the IEPA RI/FS.

In October 1985, U.S. EPA conducted a phased FS
to expand the scope of the study to  the Rock River
Terrace subdivision which is about one and one-half
miles down gradient from the site. The objective of
the study was to investigate the potential health threat
due to the exposure to the contaminated water supply
and evaluation  of alternative   water supply  and
treatment  options  that would ensure a safe water
supply to Rock River  Terrace  residents.  Sampling
results  indicated  that  the ground water  was
contaminated with levels of TCE up to 48  ug/l TCE.
Although the level  detected was below the  10-day
health advisory, it  is above  the  drinking  water
standard of 5  ug/l.  Also, since the  residents  are
located in the direction of the contaminant plume, it
was determined that a planned removal action was
warranted.

In May 1986,  U.S. EPA, by a removal  action, installed
carbon adsorption  POU treatment devices for those
residents on bottled water in the  Dirk Farm area as an
interim measure to remove TCE from the water.

In June  1986,  U.S. EPA completed a study  that
focused on the potential ground water problem  for the
Rock River Terrace. It was determined that both of
the major  aquifers in the  area were contaminated to
some extent by VOCs. This contamination extends to
outlying  locations 0;8 km (1 mi) northwest and 0.8 km
(1  mi)  north  of  the  site.  In  addition,  slight
contamination  by  cyanide and  some   inorganic
compounds exist in the  groundwater beneath  the
salvage  yard.  In addition, the  study  identified  and
evaluated alternatives  for  replacing or treating
contaminated water from  private wells. Based upon
the RI/FS, the  alternatives for treating or replacing
water from Rock River Terrace  wells were narrowed
down to the  three  alternatives  listed below,  and a
detailed  analysis was conducted on each one.

Alternative 1
Connection to the  Byron Municipal  Facility.  This
alternative was estimated  to take one  to two years to
complete,  and was estimated to cost approximately
$900,000.

Alternative 2
Supply bottled  water to  homes with contaminated
wells. This alternative would  not provide  water for
bathing  and  washing. The  annual  cost of  this
alternative was estimated at $91,150.

Alternative 3
Treatment of water from  affected  wells to remove
contaminants  through  carbon  adsorption.  It  was
estimated that it would cost $26,000 to install POU
treatment  devices  and $115,000 to  install  "whole
                                                 120

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Figure 1.  Location of Byron Johnson salvage yard, Byron, IL. investigation area.

                                                  r
                                                T
ToF
                                     PROJEC
                                     LOCATION-
                                           I—South Branch         //if
                                              Woodland Cre«k      ff]
                  II /  //	i ^..J
               BYRON SALVAGE YARD ^l
                                                                       POWER PLANT
                                                            BYRON NUCLEAR
                               IRlt'S  FARM
               SCALE: 1"-4500'
      north
                                          121

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Figure 2.  Supcrfund site investigation area, Byron, IL.
               8UPERFUND STUDY AREA
house"  POE  treatment  devices.  Upon
commencement  of construction,  it  would  take
approximately two to three months to install the units.

The results of the study indicated Alternative 3 to be
the most economically feasible while providing a safe
and reliable drinking  water supply  for  affected
residents. The whole house units would be installed
at Rock River Terrace homes that are occupied on a
year-round  basis. Periodic  monitoring would  be
conducted to ensure  that contaminants are  being
effectively removed. The carbon for these units would
be  replaced when necessary.  Since the  carbon
replacement rate  is dependent on  many factors
including  the  level  of contamination,  water
temperature, pH, chemical makeup of the water, and
water usage,  monitoring  of the  carbon  bed  is
necessary.

In July 1986, U.S.  EPA initiated  a monthly sampling
program for the  residents in the Dirk Farm area to
monitor the efficiency of the POU treatment devices.
The units will be replaced when necessary.

In July 1986,  IEPA signed  a ROD  for design and
construction of a municipal water line to distribute
potable water from  the City of Byron  municipal water
supply to the  residents at Rock River Terrace and
Dirk  Farm  areas (Acorn  and Razorville  Road
residents). This action along with a  monitoring plan
                                                122

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constitutes  the  permanent  remedy  to  the
contaminated water problem.

In September 1986,  U.S. EPA issued a ROD to install
carbon  adsorption POE  "whole house" treatment
devices in the Rock  River Terrace. The POE systems
were either placed in an outdoor insulated shed or in
the basement.  The  units were  engineered  and
installed by North American Aqua, Vandalia, Ml. Each
system  consists of  a 0.5 urn (2 x 10-5 in)  prefilter
followed by two granular activated carbon (GAG) units
in series. Each GAC  contains 50  kg (110  Ib)  of
Calgon carbon.  Each unit is 137 cm (54 in) tall and is
designed for a flow of 0.47 l/s (7.5 gpm). The system
is monitored on a monthly basis before and after each
carbon tank to assure the efficiency is maintained.
Upon breakthrough  the carbon will be  replaced. To
date,  sampling  results  have shown no  breakthrough
of the carbon.

The next Superfund site that will be discussed is the
Main  Street Well Field and  associated  actions  in
Elkhart, IN. See Figures 3,  4, and 5 for maps of the
Superfund site investigation areas.

Elkhart  is located in North Central  Indiana  at the
confluence of the St.  Joseph's and  Elkhart  Rivers.
The  population  of Elkhart  is  approximately  65,000.
The city is diversified in the manufacturing operations
that the city is known for; especially Pharmaceuticals,
band instruments,  recreational  vehicles,  and
injection-molded plastics.

The  surface geology of Elkhart consists of  a typical
glacial deposit created from various types of sand and
gravel,  forming an  extensive outwash   aquifer
permeating up  to 53  m  (175 ft). An intermediate
nonpermeable clay bed confines a deeper aquifer.

To date at least five separate Superfund actions have
been  taken in and around Elkhart,  IN. One  of these
actions  was a  remedial-type  response,  and four  of
the actions  were removal-type responses.  Although
all are referred to as the Main Street Well Field, each
removal is separate and  distinct from the actions  at
the actual North Main Street Well Field Site  listed on
the NPL.

The remedial action is referred to as the North Main
Street Well Field. Through routine monitoring,  ground
water in 9 of the 17 wells at the  Municipal  Facility
were found to be contaminated with approximately 95
ug/l  TCE. The  site was added  to the  NPL on
December 1982. Through  the Superfund  process,
U.S. EPA and  Indiana Department of Environmental
Management (IDEM)  decided to  install packed air
stripping towers at the municipal city water utility  to
meet the drinking water standard.

In the fall of  1987, Calgon  constructed the three 17-
m (55-ft)  air stripping  towers, while  the U.S. Army
Corps of Engineers supervised the construction. Each
concurrent flow tower is 3 m (10 ft) in diameter and
contains 9 m (30 ft) of  polypropylene packing media.
An estimated 19 to 23 million I (5 to 6 million gal) of
water are  treated  per  day.  The total  cost for
construction is $2.5 million. The annual O&M cost is
estimated to be between $81,000 and $106,000.
In addition  to the  remedial  action,  at  least  four
separate  Superfund-related removal  actions  have
been taken. Two of those actions have been referred
to as the East Jackson area and County 1 area.

The contamination in the East Jackson area was first
recognized in the fall of  1984, when  a citizen sampled
his  well  water. Results  of  the sample analysis
exhibited levels of TCE  above 200 ug/l. These levels
exceeded the 10-day health advisory of 200 ug/l.

When the County  Health Department was  contacted
with the information, it initiated an extensive sampling
program. When the  County  Health  Department
confirmed widespread contamination, which  was more
extensive than anticipated, it contacted the U.S. EPA.

In May,  1985,  U.S.  EPA conducted  extensive
sampling of the area whereby over 500 samples were
collected.  The results of the  sampling  program
showed that heavy contamination existed, in the  East
Jackson area where over 80 wells were found to have
ground water  contaminated TCE in excess  of 200
ug/l,  and  15 of these wells contained  levels of TCE
above 1,500 pg/l TCE.

Representatives from the Center  for Disease  Control
(CDC) advised U.S. EPA that  contamination  greater
than 1,500 ug/l  is unfit  for bathing and  other
household  uses  because of the inhalation  and
absorption  dangers. As an  immediate  short-term
remedy to the contaminated water,  U.S.  EPA placed
approximately  800 residents  on bottled  water for
drinking purposes within 36 hours.

U.S. EPA initially decided to extend  the water main to
the  15  homes   with  the  highest  levels of
contamination. However, the U.S.EPA  decided to
blanket the area with an alternative source of water,
due to the  severity  of contamination, its extent, and
direction of ground water flow. In October  1985, the
U.S. EPA  on  scene  coordinators (OSCs),  Jack
Barnette and  Ken  Theisen, were charged with the
responsibility  of  coordinating  the installation of
Additional   footage of  water  main.   In  total,
approximately  4,420 m  (14,500  ft) of water  mains
were provided to the town, and installed at  some 300
homes and businesses. Construction of the  first
group of mains, amounting to 884 m (2,900 ft), was
completed  on December 1985.  However,  since
various delays were experienced,  the project was not
completed until September 1986.

In addition, at 11  homes where  the water exhibited
minor contamination, POU devices were installed
                                                 123

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Figure 5.  Investigation area, Elkhart, IN.
                                                                                     •a
                                                                                     Q.
                                                                             id
                                                        126

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because these homes were not adjacent to the water
main.

Since the area of contamination extends over 3.2 km
(2 mi), it is believed that the contamination originated
from more than one source. It is suspected that one
of the potentially  responsible parties  (PRP) is  the
former  Accra-Pac  site  where  13  underground
storage tanks were removed by U.S. EPA.

The  other removal action near the western end of
Elkhart that  will be discussed  is the County Road  1
area in Osceola.

In June  1986,  a  resident analyzed the water and
found contamination of TCE  at  approximately 800
ug/l, exceeding  the  10-day health  advisory of 200
ug/l,  and contamination of  480  ug/l  of carbon
tetrachloride, exceeding the  10-day health advisory
of 20 ug/l.

During July  and August through extensive sampling,
U.S. EPA tracked the contaminant plume  from  the
County  1  area  to its discharge into the St. Joseph
River. The sampling also indicated levels of TCE as
high as 5,000 iig/l, and levels of carbon tetrachloride
as high as 7,500 ug/l.  As an immediate response to
the  contamination in this  area, U.S  EPA provided
bottled water to all affected  residents,  and advised
them of the risks.  In addition,  the worst homes were
advised not to use their water for any reason.
U.S. EPA decided that it would take too long to hook
these residents to  the municipal water  supply  and
therefore decided to equip the affected residents  with
POE treatment devices. In the County 1 Area, U.S.
EPA installed whole house activated carbon treatment
devices onto 54 homes, and installed  POU treatment
devices  for  22  homes  located   outside  the
contaminant  plume. The last  filter  was installed on
April 3,  1987. All units were engineered and  installed
by North American  Aqua.  U.S. EPA also initiated an
extensive monitoring   program,  whereby the  POU
treatment  devices  are periodically  sampled  and
analysis  of  the water is  performed  to check the
efficiency  of the  treatment devices.  IDEM  has
pledged to sample the affected homes and advise the
homeowners.

It is suspected that  the Conrail  Yard south of the
County  Road  1 area is a potentially responsible party
for  the  source  of contamination. The site  is being
scored for the NPL.

Following are  some of the future developments in the
area  of  POU/POE  treatment  devices used at
Superfund sites.

U.S.  EPA has  funded a pilot project in the East
Jackson area of Elkhart, IN. As a  prototype, two of
the homes  with  contaminated water  were equipped
 with a packed air stripper,  along with two GAG units
 in series. The air stripper was placed in the basement
 with the GAC units and it  is vented outside. The air
 stripper is manufactured by Tykk. The unit has a 40:1
 air to water ratio, and operates at a rate of 0.32 l/s (5
 gpm). The  air stripper is packed with 2.5 cm (1 in)
 diameter polypropylene cylinders.  The cost of the
 POE GAC  unit with air  stripper  is  approximately
 $4,000.  North American Aqua recommends  flushing
 the system  anytime when water has had to stand for
 more than a day without use. U.S. EPA is considering
 putting on  an ultraviolet light for  potential  bacteria
 problems because  it is suspected  that  a  potential
 exists for buildup on the media. Since U.S. EPA is
 still gathering .data on the  system,  no formal results
 are yet available.

 U.S. EPA Hazardous Waste Environmental Research
 Laboratory  (HWERL) has  funded  a 12-month  study
 for the purpose of producing a Guidance Manual for
 OSCs to use POE treatment  devices.  The study is
 expected to consist of first collecting POU/POE data
 from various Superfund sites, and following up with a
 pilot study to fill in the missing information. Frank Bell
 and James Goodrich are  the U.S.  EPA technical
 advisors.

 Another project in the works is the National Register
, for Drinking  Water  Treatment  Technology  (The
 Register).  Working  on  this  project  are James
 Goodrich of U.S. EPA's  Drinking Water Research
 Division, along with  Harry VonHuben  and  Sheri
 Bianchin of U.S.  EPA Region V,  Drinking Water
 Section.  The purpose of the  project is to  create a
 National  Register or  data base  of  nontraditional,
 innovative water treatment systems  which are  being
 utilized to treat contaminated drinking water supplies.
 The majority of these technologies are being used for
 water supplies that have been adversely  affected  by
 Superfund sites. Additionally, Region V will  serve  as
 the test region for the Register's development.

 The  objective of  the project  is  to  systematically
 collect,  organize  and  disseminate  information on
 those  treatment  technologies  which  have  been
 already  implemented on either  a  pilot  or  full-scale
 basis at the  affected  supplies.  The  data  base
 information  will include: manufacturers and designers
 of the units; the design specifications; a  comparison
 of the  design  performance versus  the actual
 performance, capital and operation and maintenance
 costs;  and a follow-up on operation problems and
 benefits, among other items. Presently data collection
 questionaires are being developed. The project then
 entails soliciting data through the U.S. EPA Regional
 offices.  The data  will  be stored on  a  personal
 computer (PC) at the U.S. EPA Research Division,
 Cincinnati.  Additionally,  each region will be provided
 with a  diskette for  its own use  and; the  National
 Technical Information Service  (NTIS) will  have a
 paper copy of information. We  anticipate  that  the
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summary report and the PC diskette will be available
by the close of 1988 for Region V.

In conclusion, the Superfund program is a significant
part of  our national  response to one  of  the major
environmental challenges of the decade. The program
is a coordinated  effort of  Federal, state  and local
governments, private industry and citizens. However,
since the  problems  are widespread  and each  is
unique,  new and existing technology  is needed  to
remediate the hazards. In a field where no clear cut
answers exist, the  use of POU/POE,  an  available
technology, has  gained more acceptance in the
usage and  remediation of  hazards where drinking
water is a problem.
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 NEW DEVELOPMENTS IN POINT-OF-USElPOINT-OF-ENTRYDRINKING WATER TREATMENT
                                          Gary L. Hatch
                                          Ametekjnc.
                                     Sheboygan.WI 53081
INTRODUCTION

Over  the last  several years  the  U.S. EPA  has
promulgated National Primary Drinking  Water
Regulations for  a number of specific drinking water
contaminants, the latest of which is a group of volatile
organic contaminants (VOCs) (1). These regulations,
as established by the Safe Drinking Water Act, have
provided impetus for the development and application
of point-of-use  (POU) and point-of-entry  (POE)
drinking water treatment  technology  to help solve
small community water systems' and individual home
owner's water contamination problems. The  above
referenced action by the EPA actually allows the use
of POE technologies  (with conditions) as acceptable
means of compliance with the VOC regulations. POU
technologies  may also be  used, but  under more
restricted conditions.

BACKGROUND
New developments in POU/POE technology primarily
have been for contaminant-specific applications. For
example, radon has  come to national  attention
recently as being a serious health threat to private
well owners.  This problem is  now being solved by
new  POE systems  that employ  old or well-known
technologies, such as the use of activated carbon and
aeration.  Lowry (2) has conducted many studies to
demonstrate the effectiveness  of granular activated
carbon systems  and  aeration systems  for removing
high levels of radon from drinking water.

Other new  developments  have been in the  area of
water disinfection.  In the last  few years, the well-
known technologies  of ^ultraviolet light and ozonation
have been designed into packaged systems hardware
for POU/POE application  (3-6). Of  these, the  new
POE  ozonation systems  that are becoming
commercially available may be the most promising
from the standpoint of overall treatment capabilities.
POE ozonation systems combine the technologies of
filtration  and adsorption  to provide  for effective
removal of some inorganic and  organic  contaminants
while  at  the same  time  providing  for disinfection
against bacteria, viruses,  and protozoan cysts. Rice
(4-6) has given a detailed description of the use of
ozone and ozonation systems  for POU/POE
applications.

During the last 5 to 10 years, the technology of home
reverse  osmosis  drinking water treatment  systems
has advanced to  become a viable treatment method
for  reducing  certain health-threatening inorganic
contaminants. These systems are most applicable for
reducing nitrate, fluoride, and arsenic. POU reverse
osmosis systems have been  tested successfully for
the  reduction of fluoride and arsenic in  a small New
Mexico community (7). Proper system and -membrane
application  is very  important because  various
membranes (e.g., cellulose  acetate versus thin-film
composite) have different performance characteristics
(8), especially where nitrate reduction is concerned.
In the last 10 to 20 years, a relatively new approach
to using  halogens  for water disinfection has  been
developed.  This technology  is based  on  the
combining of the halogen (in the form  of a polyhalide)
with an ion exchange  resin.  The remainder of this
paper will provide  a detailed look at  the history,
development, and uses of the halogenated resins for
POU/POE water disinfection.

HALOGENATED  RESINS  FOR  WATER
DISINFECTION
H/STORY OF DEVELOPMENT
Initial work (9) in the field of halogenated resins began
in 1957 when simple  ion  association  experiments
were conducted  by adding  bromine and  iodine to
anion exchange resins. This work revealed that these
resins have an unusually high  affinity for  halogens,
especially for iodine. Approximately 10 years later, the
first halogenated resins (10)  were developed to
control  microorganisms in  water.  Since then  a
number of improvements and modifications  have
been  made  in  the   formulations  (11-17)  of
brominated and  iodinated resins  to  enhance  their
chemical characteristics  and  their  anti-
microbiological  performance.

The initial  and primary application of the original resin
systems was to use the resin as a way of  metering
the halogen (e.g., bromine or iodine) into a  stream or
                                               129

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body of water. The halogen,  then, was still used in
the conventional way (as a residual) for  controlling
microorganisms.

A major discovery indicating  the  potential  for using
halogenated  resins   in   point-of-use  water
disinfection was  made by Mills  (11)  in 1969.  This
discovery  was  that   when  microbiologically
contaminated water is passed through a bed of the
halogenated  resin, an instantaneous and complete kill
can  be achieved. Therefore,  a reservoir for holding
the water and the  required contact  time needed for
conventional residual disinfection  action is  not
necessary  when  using  a  properly  designed
halogenated  resin  water disinfection  system.  The
superfluous  halogen  residual  -released by the resin
then  can be removed  or deactivated if desired,
immediately upon emerging from the bed.
Later discoveries fay Lambert and  Fina  (18) have not
only helped  to  explain the unique  mechanism that
provides for  the  instantaneous disinfection,  but have
shown also that  halogen  release by the resin is not
necessary   to   achieve  the  instantaneous
microorganism kill. Their studies with an  insoluble
triiodide resin have shown that kill is achieved through
physical contact of the organism with the resin beads,
and  that  the disinfecting quantities of halogen  are
produced virtually on demand.

HALOGENS
The  halogens  are a  group  of chemical  elements
comprised of fluorine, chlorine, bromine, iodine, and
astatine. Of these, only chlorine, bromine, and iodine
are used in water disinfection, and only bromine and
iodine are capable  of forming the polyhalides, which
bind to  the anion exchange resins. Table 1 illustrates
(he polyhalides formed from bromine and iodine and
how an aqueous triiodide solution is made. The higher
polyiodides ((5" and (7") are made simply by adding
the correct stoichiometric amount of iodine to  the
sodium iodine along with  a very critical and minimal
amount of water).
Tablo 1.   Halogens Most Capable of Forming Polyhalides
 • Bcomino
 • lodino

 Exampto;
ra, Brs". Bf>"
', is'.'/
 I2     •*•     Nal
 lodino   Sodium Iodide
                  H2O
           Na+  +  I3'
        Water Solution of Sodium Triiodide
The corresponding polyhalide  resins are  made by
addition  of  the aqueous polyhalide solution to  the
anion exchange resin (usually in chloride form) under
very carefully controlled conditions.

RESINS
In general, ion exchange resins consist of two main
types - cation exchange  resins (those that exchange
positively charged ions, such as calcium [Ca + 2] for
sodium  [Na + ] in the  water  softening process, as
shown in Figure 1); and anion exchange resins (those
that exchange negatively charged ions,  such as
triiodide  [la"], for chloride [Cl"], as shown in  Figure
2).  These  resins  are usually  made  from  the
polystyrene polymer backbone and differ only by  their
specific functional groups.

The cation  exchange  resin contains the negatively
charged sulfonic  acid  functional  group:  R-SOs",
where  R  is  the polystyrene backbone.  These
negatively charged functional groups attract and  hold
on to  the positively  charged cations. Depending on
their relative  concentrations  and relative affinities for
the sulfonic acid functional site, different cations can
exchange with others, as depicted in Figure 1.

The anion exchange resins used for making the
halogenated resins also usually have the polystyrene
backbone,   but  have  the  positively  charged
quarternary  ammonium  functional  group:  R-
CH2N + (013)3, where  R is, again,  the polystyrene
backbone. Here, the  positively charged functional site
holds the negatively  charged anion. Anion exchange
occurs when the relative affinity for one anion wins
out over another, such as  in Figure 2 where the
resin's affinity for triiodide is much greater than for
chloride.

When  this  triiodide resin is  made properly, virtually
nondetectable levels  of  iodine are found in the post-
column water effluent. Furthermore, when this resin is
challenged with water high in salt content,  such as
with chloride or sulfate,  no triiodide exchange occurs
and only low levels of iodide ion (I") are found in the
effluent (13). Table 2 shows how effective this resin is
against  five  different  kinds  of  bacteria  and  the
polydma  virus (13,19). Other halogenated resins  also
demonstrate  highly effective anti-microbial action as
depicted in Table 3 (11,14,17).

Another  type, of  resin,  polyvinylpyridine,  has been
used  to  make halogenated  resins (12,17).  In  this
resin,  the functional  group  attached  to the  vinyl
polymer  backbone is  the  pyridine  molecule  (see
Figure  3). The unique feature of this resin  is that the
neutral (no ionic charge) functional group has a  high
affinity for the free halogens,  specifically iodine  and
bromine. Therefore, when making halogenated resins
with polyvinylpyridine, the free halogen need only be
used. Use of the halide salt (Br~  or  I*)  to make the
negatively charged polyhalide is not  necessary.  The
halogenated  polyvinylpyridine  resins  exhibit  anti-
microbial action similar  to the halogenated  anion
exchange resins (see Table 3).

LIMITATIONS

Many  of the variables that  adversely affect  the
conventional  water disinfection methods also affect
                                                  130

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Figure 1. Softening process with sodium-form cation exhange resin.
                             -fCH-CH2-)-
                               so:
       Na+
                   Ca
+2
Figure 2. Anion exchange resins used in making halogenated resins.
                              CH2
(CH3) N
    (CH3) Nt
                                              n
+2Na
.+
                             -fCH-CH24-
                                              n
                                            +CI
          Cl
                             U.S. Patent 3,817,860
                                Lambert & Fina
                         131

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Tabto 2. Anti-Bacterial Efficiency of the Trioidide Resin
Organisms per ml
Organism
Salmonella typhtmlurium"
Escherichla coif
Pseudomonas aeniginosa"
Staphylococcus aureusf
Streptococcus faecalisr
Polyoma virus"*
Feed
1 X105
3x105
1.3x105
1.8x104
1.1 X104
1.2x106
Effluent
0
0
0
0
0
0
  * Data from reference 13. 6.5 ml of resin at 20 ml/min flow rate.
  " Data from reference 19.30 ml of resin at 30 ml/min flow rate.
TabloS.  Anti-Bacterial Efficiency of Various Halogenated
         Resins
                            £ co// per ml
 Rosin
 Feed
Eff.
 Halogen
Residual in
 Effluent
 Pofybromida, 5% Btz as Bra""
 Mixed-form, potyiodide""
 Mixed-form, lodine/Bromine-
 polyvinylpyrfcline"~
1 x 10s    0    2 mg/l as Br2
3 x 105    0     1 mg/l as I2
9x105    0    10 mg/l as l2
    * Data from reference 11.50 ml of resin at 57 ml/min.
   "* Data from reference 14.50 ml of resin at 185 ml/min.
   •"* Dala from reference 17.50 ml of resin at 140 ml/min.
the  disinfection process  of the halogenated resins.
Table 4 lists these major limitations as well as some
other concerns of halogenated resins that may  limit
their uses and applications.

In a conventional disinfection  process,  such as a
municipal treatment plant where chlorination is used,
the  water  usually is subjected  to  a  series  of
pretreatment and in  -some  cases, post-treatment
processes.  Many  water treatment plants pretreat the
raw  water  by using methods  such as flocculation,
sedimentation, and/or  filtration. Where necessary, pH
adjustment  can also  be done. These  pretreatment
steps  are necessary  to  insure  that  the optimum
disinfection  conditions are met. If low temperature or
halogen demand dictates, higher levels of disinfectant
can  be  added.

For  halogenated resins, the water  entering the  bed
also must be of a  reasonable  quality such that the
disinfection  process is not jeopardized.  Therefore, a
preapplication  water analysis  must  always  be
conducted so that adequate pretreatment  needs can
be determined.

pW
If high pH is encountered (above 9), a preacidification
step must be incorporated  into the treatment system
to lower the pH to betwen 7 and 8. Figure 4 shows
the effects  of high pH on the triiodide  resin  (20).  At
above pH  9, iodinated  resins begin to release high
levels of iodine that  can diminish  the kill efficiency
and  life  of the resin bed, as  well  as stress and
shorten the  life  of an iodine  scavenger  system.
Lowering the pH to less than 5  is not recommended
because of evidence  that at low pH virucidal activity
of the halogenated resins is diminished (19).


HIGH TDS AND HALOGEN DEMAND
The  potential problem of extremely high TDS (1,000
to 15,000  mg/l or greater) could  be addressed  by
pretreatment with  demineralizing resins or  reverse
osmosis. These high levels of  TDS could  promote
additional ion  exchange of  halide ions and  halogen
which,  again,  would  result  in lowering  the kill
efficiency and life of  the resin.  Similar pretreatment
measures can  be  taken  against  fnorganic
contaminants that create  halogen  demand  (e.g.,
sulfide or sulfite).

TEMPERATURE
Low  operating  temperature   can  reduce the
antimicrobial efficiency of the halogenated resins (21).
However, this is presumed not to be as critical as in
the  conventional  disinfection  process where  the
"concentration X time"  constant must be maintained
to assure adequate disinfection  (22). The  residence
time  within the  resin  bed can  be  increased by
enlarging the bed size  or lowering the flow rate to
assure disinfection. Ideally, any halogenated resin
disinfection system should be designed to  operate at
the anticipated minimum temperature. Unusually high
operating temperatures  such as 90 to 100°F (32 to
38°C), which may be  encountered  in the  tropics,
would most likely enhance the disinfecting action, but
cause a slight increased release  of halogen.

RESIN FOULING
Since the kill  mechanism relies on physical contact
(or very near contact) of the microorganism  with the
resin beads or particles, adequate protection against
resin fouling or coating  of the beads  is a  must. The
effects of resin fouling  are evident  even in a simple
softening or demineralizing process. Resin fouling or
coating by iron floe or  organic  material, will prevent
the dissolved  ions from contacting or entering the
resin beads,  and thereby preclude the softening  or
demineralizing action.  This same phenomenon  would
likewise  preclude  the  disinfecting  action  of the
halogenated resins. Obviously, the potential for resin
fouling is an extremely critical factor that must not be
overlooked when  considering halogenated  resins for
water disinfection.

PROTOZOAN CYSTS
Any  water  disinfection  process  must be  totally and
reliably  effective against  all  disease-causing
organisms. A  major limitation of some halogenated
resins is that they are  not effective  against certain
types of protozoan cysts, specifically Giardia  lambda.
                                                  132

-------
Figure 3.  Most recently developed halogenated resins use neutral (non-charged) resin.
     -fCH-CH24-
                                   n
            O) +  Br2  + I.
              'NT
  Polyvinylpyridine
                         -fCH-CH_)-
                                                       n
                                    \/Brz
                                                   U.S. Patent  4,594,392
                                                              Hatch
Table 4.  Limitations of Halogenated Resins
 pH 9 (max.)
 High TDS (approx. 1,500 mg/1)

 Temperature

 Resin fouling - iron, TOG, turbidity
Halogen demand

Resistance of Giardia or
amoebic cysts
Physiological concerns of
iodine and bromine
Monitoring
Tests on the triiodide  (13") and penta-iodide  (Is")
resins have shown that only the pentaiodide resin is
effective against Giardia (23). Fortunately, since these
organisms are relatively large (typically 7 to  15  nm
[0.0003 to 0.0006 in]),  they  can be  physically
removed  by adequate pre or  post-filtration thereby
precluding total reliance on the halogenated resin for
a cyst kill.
PHYS/Oi-OG/CAL CONCERNS
Since  iodine does have  an effect  on  thyroid
metabolism, it is not recommended  for long-term
continuous use (24). Therefore, the best application
of halogenated resins containing iodine would seem
to be in  portable emergency devices where use is
short-term or intermittent.  Several  such  devices  are
currently on the market.

The U.S. EPA does indicate that iodine could be used
for long-term continuous application if an adequate
post-treatment scavenger  system were employed to
remove any iodine species from  the  water (24).
Physiological concerns  with bromine  are less  than
those with  iodine, but some limitations  on  bromine
levels in drinking water are recommended (25).

MONITORING
Any water treatment device or process that has a
health effects claim  should have  a reliable  and
                      Figure 4. Effect of pH on iodine release from triiodide resin.

                        ppm Iodine
60 -
                         40  -
                         20  -
                                          7    8

                                            PH
                                                        10
                                                             11
                      convenient way  of  letting the user know when
                      exhaustion occurs or servicing is required. This is an
                      obvious understatement  when  dealing  with
                      microbiological purification of water. One  way to
                      accomplish performance indication or lack thereof is
                      to incorporate an  automatic shut-off or  remote
                      sensing  metering device into  the system.  The
                      National Sanitation Foundation Standard No.  53 (26)
                      lists other alternatives.
                                            133

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 SYSTEM APPLICATIONS

 The extremely efficient,  once-through disinfecting
 action of the halogenated resins  make  them ideal
 candidates  for  use  in  small-scale  point-of-use
 water  disinfection systems. Other than previously/
 mentioned portable emergency water disinfection
 devices,  numerous single-tap  applications are
 possible.  Systems or  units  with  replaceable
 cartridge-like containers of the resin could  be used
 where drinking  water is supplied  for transient
 populations, such as for water fountains in parks and
 other entertainment facilities, or public buildings.

 Multi-tap or high  volume drinking water needs could
 be met by employing  the resin in multiple-cartridge
 housings or in a  single tank-type  container such as
 a  softener resin  tank.  As previously  indicated  for
 long-term use, adequate  post-treatment measures
 must be taken to remove  or reduce the halogens to
 an acceptable level.

 Of course,  as cautioned  before,  the  critical  water
 quality parameters must be predetermined to aid in
 system design,  and  most importantly, adequate
 monitoring and servicing is a must.


 CONCLUSIONS
 Use of halogenated resins  in point-of-use  water
 disinfection can offer a unique opportunity  to help
 solve some of the current problems associated with
 conventional  small-scale  chlorination  disinfection
 systems. Some advantages are:

 •  No electrical connections (depending on monitoring
   requirements);

 •  Easy  to  install  and service  - no  handling  or
   storage of chemicals;

 •  Virtually no "down" time;

 *  Minimal space requirements;

 •  More efficient use of disinfectant; and

 *  Potential to integrate well with  other point-of-use
   technology.

 However, even though  these resins have  remarkable
disinfecting  capabilities,  proper design, thorough
testing, and prudent  application  are  absolutely
necessary to assure maximum reliability  of systems in
which  they are used.  Currently available point-of-
use  water treatment technology  can  be properly
combined with halogenated resins to  offer  another
alternative for providing microbiologically safe drinking
water.
All areas of POU/POE water treatment technology are
advancing rapidly. Much of this technology is  based
on newly engineered systems, which by redesigning
existing or well known technologies, can solve almost
any water contamination problem. As revealed  in the
newly passed Safe Drinking Water Act, the U.S. EPA
now  recognizes that  fact. The  accompanying
technologies of monitoring  and serviceability are also
advancing rapidly.  As advances continue,  the
POU/POE  industry  can  meet  the challenge  of
combining reasonable cost, reliability, monitoring,  and
serviceability to provide  safe, reliable, and economical
methods of drinking water treatment for the consumer
who does not have the option of central treatment.


REFERENCES
1.  U.S.  Environmental  Protection Agency. National
    primary drinking  water regulations - synthetic
    organic chemicals;  monitoring for  unregulated
    contaminants; final rule. Federal Register 50:130,
    25690, July8, 1987.

2.  Lowry,  J.  D. et al. Point-of-entry removal  of
    radon  from drinking water. JAWWA. 79:4, 162,
    1987.

3.  Foust, C.  Performance and  application of  UV
    systems.  Proceedings.  Conference on   Point-
    of-Use Treatment  of Drinking Water.  U.S.
    EPA/AWWA,  Cincinnati, OH.  October 6-8,  1987.

4.  Rice,  R.G.  Ozone for point-of-use/point-of-
    entry application, Part I. Water Technology. 10:3,
    22, May 1987.

5.  Rice,  R.G.  Ozone for point-of-use/point-of-
    entry application, Part II. Water Technology. 10:4,
    28, June 1987.

6.  Rice,  R.G.  Ozone for point-of-use/point-of-
   entry application, Part III. Water Technology. 10:5,
   27, August 1987.

7.  Rogers, K.  Community demonstration  of POU
   systems.  Proceedings,  Conference on   Point-
   of-Use Treatment  of Drinking Water.  U.S.
    EPA/AWWA,  Cincinnati, OH.  October 6-8,  1987.

8.  Slovak, J. and Slovak, R.  Developments  in
    membrane technology.  Water Technology, 10:5,
    15, August 1987.

9. Aveston,  J.  and  Everest,   D.A.  Chem. Ind.
    (London).  1238, 1957.

10. Mills, J. F. U.S. Patent 3,316,173. April 25, 1967.

11. Mills, J.F.  U.S.  Patent 3,462,363.  August  19,
    1969.
                                                134

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12. Katchalski,  E. et al.  U.S.  Patent  3,565,872.
   February 23, 1971.

13. Lambert,  J. L. and  Fina,  L.  R. U.S.  Patent
   3,817,860. June 18, 1974.

14. Hatch, G. L. U.S. Patent 4,187,183.  February 5,
   1983.

15. Gartner, W. J. U.S. Patent 4,420,590. December
   13, 1983.

16. Beauman, W.  H.  et al.  U.S. Patent 4,594,361.
   June 10, 1986.

17. Hatch,  G. L. U.S. Patent 4,594,392.  June 10,
   1986.

18. Lambert,  J. L. and Fina, L.  R.  Proceedings,
   Second World Conference,  International Water
   Resources  Association, Vol.  II, pp.  53-59,  New
   Delhi, 1975.

19. Hassouna, N. Doctoral dissertation. Kansas State
   University, 1973.

20. Hatch,  G.  L.  et al. Ind. Eng. Chem. Prod.  Res.
   Dev. 19, 259, 1980.

21. Kao, I.  C. et al. J. Ferment. Techno). 51,  159,
   1973.

22. Regunathan,  P.  and  Beauman,  W.  H.  Fourth
   Domestic  Water Quality  Symposium.  Water
   Quality  Assoc. and  Amer. Soc.  of  Agricultural
   Engineers,  Technical Papers,  p.  54,  Chicago,
   1985.

23. Marchin, G. L. et al., Appl. Envtl. Microbiol.  46:5,
   965-9,  1983.  r

24. Cotruvo,  J.  &.' Policy on iodine disinfection.
   Memorandum to G.A. Jones. March 3, 1982.

25. Drinking Water and Health, Vol. 3, pp. 181-187.
   National Academy Press, Washington, DC, 1980.

26. National Sanitation Foundation  Standard No. 53.
   Drinking water treatment units - health effects,
   N.S.F.,  Ann Arbor, Ml, June 1982.
                                                135

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                                   POUlPOE POINT OF VIEW
                                        Frank A. Bell, Jr.
                                Criteria and Standards Division
                                   Office of Drinking Water
                             U.S. Environmental Protection Agency
                                      Cincinnati, OH 45268
INTRODUCTION

I would like to preface my remarks by saying that I
will  not be addressing  official  Environmental
Protection  Agency  (EPA) policy,  since  that has
already been covered by Steve Clark. My remarks will
also not cover pesticide regulatory programs in EPA,
since that has also been covered by another speaker.

Instead I will address two basic positive options for
handling the broad field of POU/POE water treatment
in terms of claims control and consumer service.

OPTION  #1:  A DIRECT REGULATORY
PROGRAM
From my understanding,  such a  program would
involve a verification of claims being  made  by  the
various industry  segments.  To  be universally
applicable, such a program would have  to identify and
circumscribe acceptable claims and then have units
tested against the claims. This would be an incredibly
complex  operation. It also might be  considered a
restraint of  trade.  Some questions that  it would
present are:

• How would claims be limited?

• Would the direct regulatory program  deal only with
  physically or chemically verifiable claims? If  so,
  would  noncovered  units be  exempted,  such as
  magnetic  treatment units and good-health units
  (ones that treat the  water  to improve its good-
  health qualities without any change in chemistry)?
  If such units are exempted, then a substantial area
  of consumer concern will remain unattended.

• Would nonhealth or esthetic treatment  units  be
  covered? If yes, then  the magnitude  and
  complexity of the program would  become serious
  problems,  since  from  a review  of  water
  conditioning treatment (1)  some  26  possible
  esthetic effects/treatments emerge.
If, on the other  hand, esthetic treatment units  are
excluded,  what will  be done  about  the  incidental
health  effects claims of the esthetic  units?  For
example, a taste and odor activated carbon filter may
also remove 10 to 20 percent of the trihalomethanes
(significant, but  not enough to be considered
adequate from a health standpoint). If the 10 to 20
percent reduction claim is  allowed, how can it be
described so as to inform the consumer properly?

• The  currency question will  provide  further
  enormous problems. Manufacturers are constantly
  changing their products.  How will these changes
  be monitored? How will retests and quality control
  be verified?  Who will certify treatment capabilities
  for the manufacturers'  new  products?  For a
  government agency to attempt to regulate, monitor,
  and control the entire water  quality industry would
  represent  an  enormous  and  continuing
  bureaucratic effort.

CONCLUSION
While a direct  regulatory program  has some appeal
from a simplistic viewpoint, it can introduce a  host of
hard-to-answer questions,  and in  the  end,  provide
more problems than solutions.

OPTION #2: COOPERATIVE INDUSTRY/
GOVERNMENT/THIRD PARTY EFFORT
Historically,  EPA has vigorously supported this
second  option. I have personally participated  in
several productive efforts that have involved many
cooperative parties, including:

• The  Gulf  South Research  Institute's  landmark
  study of over 30 commercially available activated
  carbon  and other units  for organic  chemical
  reduction capabilities  (2).  Before this study,  no
  authentic,  independent  information on unit
  capabilities existed.  Industry cooperated in protocol
  review and development, and in  the conduct and
  review of the  study and its  results. Industry
                                              136

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   technical representatives helped us to avoid doing
   unwise  things  and  in  having  a valid,  widely-
   accepted study result.

 • Establishment of third-party standards and  listing
   program under the National Sanitation Foundation
   (NSF).  NSF has  provided  leadership  Jo  bring
   industry,  government and other interests-together
   for establishment of  a number of drinking water
   treatment  unit standards, with three currently in
   effect: Standard 42 (Esthetics), Standard 53
   (Health), and Standard 58 (Reverse Osmosis), and
   with  two other  standards  nearing .adoption.
   Strengths  of an  NSF  program  include  the
   standards consensus development process (giving
   all interests a chance to be heard) and its testing,
   monitoring, and  control capabilities.  NSF  has  a
   continuing presence  and mechanism to keep up
,   with  new  product  developments  and control of
i   product quality over time.
i
 • Water Quality Association  (WQA) industry  survey
   for use of solvents  in the  manufacture of -water
   treatment  units.  In  response to  EPA's concern
   regarding  possible  solvent  contamination in
   drinking water from,  some home  treatment units,
   WQA conducted  an industry survey and developed
   guidelines for the use of solvents (3). This survey
   and  guideline   development  has  raised  the
   consciousness of the water quality industry  and,  I
   believe, minimized the inadvertent contamination of
   water from home treatment units.

 I could  enumerate other areas of industry/government
 cooperation to  include the microbiological purifier
 guide  standards  project  or the concern  with
 contamination from ion  exchange-resins. However,  I
 believe the cooperative atmosphere is well developed.

 CONCLUSION
 While cooperative efforts may  suffer slightly  by not
 having  regulatory backing, they can sometimes be the
 best solution, particularly if the interests of the parties
 are sufficiently served by  such  efforts. In  this
 situation,  I believe  Option #2  for cooperation  is the
 optimum choice.


 RECOMMENDATIONS
 Additional  steps  need  to  be taken to strengthen
 consumer protection in areasof POU/POE.

 • The  water quality industry needs to continue and
   expand  education  and training efforts  aimed at
   raising the knowledge and professionalism of water
   quality contractors,  salesmen, and  technicians.
   Eventually, the  contributions of the water quality-
   industry will be limited or expanded depending on
   the professionalism and credibility of its personnel.-.
• More- attention needs to be given to the expansion
  and  utilization of the-  third-party standards  and
  certification program. Specifie  areas  for attention.
  are information and education .programs for local
  and state  government personnel  and  for
  consumers  regarding  -the- 1MSF- --programs;  and
  greater  utilization ,«f 4h» •NSFlisting service by
  water- quality- product  manufacturers. The third-
  party program will not  be  truly-effective until  it  is
  more widely recognized and utilized, particularly by
  local and state-regulatory, officials,

• Finally' all Federal,  state,  and local  officials  and
  industry and  other interested  parties need to
  maintain; open channels  of -communication to
  examine areas  where  problems  arise.  Continuing
  the positive  patterns of the past  will  enable us to
  have a productive result in the future/


REFERENCES
1. McGown,  Wes.  Sensitivity:  a  key   water
  conditioning  skill. Water  Technology.
  September/October  1982,  pp.  2-5.

2. Bell, Frank  A. etal.  Studies  on  home water
  treatment systems.  JAWWA. April 1984, pp..  126-
  130,

3. Water Quality Association. Voluntary guidelines for
  the use of solwentSi  July 1987.
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                       AWWA VIEWPOINT ON HOME TREA TMENT UNITS
                                           JonDeBoer
                              American Water Works Association
                                        Denver, CO 80235
INTRODUCTION
In order to  present the viewpoint of the American
Water  Works Association  (AWWA) regarding  point-
of-use  (POU) or  point-of-entry (POE) treatment
units, it is necessary to provide a brief overview of
AWWA.

Many are familiar with  the Journal AWWA,  perhaps
Mainstream, OpFlow, or Water World News.  In many
cases  these publications are  the only perceptions
people have of AWWA. But AWWA is not  just the
efforts  of its staff, it's the efforts  of the people
Involved in  the industry  —  the  engineers  who
design systems,  the people in the field who  install
systems, and those who treat and analyze water.
AWWA is involved not only in drinking water,  but also
water for all  uses. This  includes not only commercial,
industrial, and other city uses, but also many uses
within the home  such as drinking water, water used
for cooking  and  cleaning, and  water  used  for
consumption at  taps other than the kitchen sink.
AWWA is a service organization, and when individuals
have questions, we are available to provide answers.

The organization  is made up of members divided into
sections (regions of the country). Each section elects
a member to the Board of  Directors,  the controlling
body of the organization.  The Board of Directors
internally selects an Executive Committee, which
oversees the entire operation. AWWA is divided into
four councils, the Water Utility  Council,  which is our
newest council, the Technical  and  Professional
Council,  the Standards Council, and  the  General
Policy Council.

THE POINT-OF-USE/ POINT-OF-
ENTRY ISSUE
Each of these councils is  involved  with  POU/POE
issues. The Water Utility Council is involved since this
issue impacts utilities,  particularly from  a legislative
and regulatory  viewpoint.  They  are  primarily
responsible for providing input  to the regulatory and
legislative positions developed  on both  national and
state levels.  The General Policy Council is  involved
because AWWA is in the process of establishing a
policy or position on POU/POE.  The General Policy
Council  is set up only to do this: to oversee the
development and planning of Association policy. The
Technical and  Professional  Council is involved
because  there are technical issues. The Technical
and Professional Council's scope is to deal with the
technical issues in the water industry.  They are not
involved in the development  of  standards; this  is
reserved for the Standards Council.

This  paper  discusses  AWWA's  position  and
viewpoint.  It is necessary to understand that AWWA
has  two types  of statements.  One is a  policy
statement,  the other  a  position statement. The
difference between these two is the  way they are
developed and used. Policy statements have been  in
existence for a  long time;  they are  long-standing
positions, and have been  thoroughly researched.
They are selected by a rigorous process, and they
require Board of Directors' reaffirmation at least every
five years.

Position statements, on the other hand,,are a position
on a specific issue.  They  are  often  developed  in
response  to  regulation  or legislation.  They are
somewhat more fluid,  and rather than  Board  of
Directors approval, they are  considered official policy
once approved by  the Executive  Committee.
However, the Board of Directors reaffirms a  position
statement at its next  meeting, and it  must  be
reviewed annually to ensure that it is still a current
and valid position of the Association.


LEGAL REQUIREMENTS
The primary legal issue, from the AWWA viewpoint,  is
the Safe Drinking Water Act Amendments and the
requirements  the Act contains for improving water
quality. The utilities and the  bulk of our membership
believe that all water should  be treated to acceptable
quality for all  users and for all uses.  Frequently, the
home treatment  industry  believes that it  is more
appropriate  to provide marginally treated  water for
general  use  and provide  independent treatment  of
specific  water  streams  that  have  higher use
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requirements.  We have  seen comments published
where municipally supplied water is described as raw
or untreated water. A POE device might be supplied
to provide treated water for other specific uses  such
as cleaning and laundry.  Finally,  further treatment by
an  under-the-sink  device  might  be  used  to
increase the quality of drinking water. AWWA believes
that all  water  supplied to  a home  should  be
considered drinkable.

By  law, in the development of the  National Primary
Drinking  Water Regulations, the  purveyor is
responsible to the tap. That doesn't mean through the
meter to the connection. It means to the tap, and it
means to every tap within the home. The regulations
are to provide protection  against possible, as  well as
proven, harmful agents, which  expand the number of
contaminants that may or probably will be regulated in
the future.

In addition, EPA is required  to define  acceptable
treatment techniques. Best available technology  does
not  include  point-of-use devices  for  VOCs;   that
question is still open .for regulation in  the future. In
other words, each best available technology will be
defined  based  on  the contaminants  that  are
considered.

In addition, affordability can be taken into account by
the agency in defining best available technology; this
is one criteria that  has been tentatively defined. An
increase in the.  annual  water bill  for removing  a
contaminant  shall be limited to no more than one
percent of the household income, with  a total annual
water bill of no more than  two percent of income.
That doesn't leave  a great deal of money  for either
point-of-use or  central  treatment.  The goal  of the
Safe  Drinking Water Act and  the  objective of the
AWWA is to consistently  meet the  needs  of the
public. We feel that these needs must  be met for all
people, not just selected populations who can afford
to install a treatment system..   ..   .


AWWA'S POSITION
The AWWA position on POU/POE treatment devices
is:  aesthetic treatment of potable water is something
that AWWA has no objection to and never has had.
We commend the  Water Quality Association for its
establishment of Voluntary Guidelines and the use of
the Industry  Review Panel. We  encourage, not only
the manufacturers,  but also the utilities, to  use this
system to ensure that promotion of products is fair
and accurate.. These products  must  be properly
advertised and  must not' condemn municipal  water
supplies.  That kind  of advertising does neither our
industry nor  the  home treatment industry any good.
Advertising is only one form of promotion, the  other is
the actual demonstration  or application of a unit in the
home.  Frequently we hear cases  where  the  term
"snake oil salesman" might apply. These individuals
do not do our industry any good, they do not do the
POU/POE industry  any good, and we don't think
they're appropriate.  •

Treatment for  health  effects  to  meet  current
regulations is another matter. This is where AWWA
has  developed  a  draft position  statement.  The
position statement  development  procedure includes
review  by  numerous  councils,  divisions,  and
committees, based  on their expertise  of  a specific
topic. Following  these reviews,  the General Policy
Council reviews  the entire  position  statement and
develops a final  draft based on  the comments that
have  been received by all  the review  bodies within
the Association.  In  the  final approval process there
may  be  some  modifications  to the  wording and
language,  but  not to  the  specific intent of  the
statement.  The  following will describe  the general
content of the statement without using the specific
words:

AWWA believes that POU/POE  devices  are  not
appropriate alternatives  or  replacements for central
treatment of  drinking water. Central  treatment of
drinking water is the alternative of choice. There are
occasional situations  where  POU/POE  treatment
might be appropriate.  But  the  condition that we
believe  is  necessary  is central control,  although
ownership may  not  be necessary.  Rental/lease
situations may be entirely appropriate for POU/POE
treatment, but the control still has  to be  under the
auspices of the water utility.                       .

In addition, there has to be an  effective  monitoring
program  established.  POU/POE units  have to  be
properly  applied. That  means there has to be  an
engineering and  health review of the  units which
includes  how they  are  going to be installed in the
home. Microbiological safety must be maintained. We
have  to protect all consumers at all points where they
are going to consume  water,  both intentionally  and
inadvertently. We  can't assume that people  aren't
going to  come into  internal  contact with  water simply
because  we didn't design it to be a point of drinking
water. We believe that there should be no increase in
the risk over a centrally treated supply.

A POU/POE device is installed  specifically  for
modification of water  quality  in  a  beneficial  way.
However, there are risks. There are possibilities that,
in addition to the  beneficial modification,  there is a
potential  for adverse, modification of the water.  We
believe that  consumers need  to be  educated to
understand the potential for adverse modification with
POU/POE devices.

This is the basic content of the AWWA draft position
statement. It  has been developed as a consensus of
the entire industry, not restricted to utility input. There
are   numerous  people  such  as  academics,
consultants,  utilities,  and  manufacturers on  the
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committees and councils,  who  have reviewed  this
position statement. It is not a frivolous matter. As
stated earlier, it is  in the final stages of  development
at this point. Once approved,  it will  be  published in
Mainstream. We  hope  that  this discussion  has
brought a better understanding of the AWWA position
on  point-of-use  devices.
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           POUlPOE - POINT OF VIEW - ASSOCIATION OF STATE DRINKING WATER
                                   ADMINISTRATORS (ASDWA)
                                          Barker G. Ham///
                                 Bureau of Safe Drinking Water
                      New Jersey Department of Environmental Protection
                                         Trenton,  NJ 08625
Before I  make my disclaimer about who I  actually
represent, as my function as a Chief of the Bureau of
Safe Drinking Water in  New Jersey, I would like to
comment  on the previously mentioned New  Jersey
study. We are still trying to deal  with the ramifications
of actually having two incidents  within one county in
New  Jersey  where  there  were  installations  of
treatment  units that did  not prove  satisfactory.  We
have not been able to get the county health officials
to allow any installations of home treatment units for
health-related  matters since  then; the consequences
of what happens when  things go wrong  can take a
long time to overcome at the local level. Now that I've
said that, as an official from New Jersey, I would also
like to say that to represent all 50 states is obviously
an impossible task. The views that 1 have are mostly
my own, but I have gone over them  with some of the
people  within  the association.  There  will  be
differences in how the individual  states  react to
point-of-use  treatment,  so  I'm  talking  about things
in a very  general sense in terms of representing the
association.

I've always  been  impressed with  EPA's research
efforts, their speakers,  and the  type of research that
they do. As a state official, I  was very impressed with
the technical presentation by the  point-of-use
treatment  industry at this meeting.  I have not seen
too many presentations by pointof-use  treatment
people before, and I  was  very surprised  by  the
technical  expertise of the  point-of-use  treatment
industry represented at this  meeting. I think this is
something that the state officials need to take back to
their, local people: there is good technical work being
done  within  the point-of-use treatment industry.

The good aspect of having  a large number  of
manufacturers and installers is that it allows for a lot
of attention to local needs. A lot of the needs within
the point-of-use treatment industry are of a  very
localized  nature.  There are  different  needs  for
example,  in  Arizona, New Jersey, or in Florida,  and
it's important to have  different manufacturers and
installers  serve different needs. It was good to  see
how many actual  field  experiences have been a
success, and to have everyone learn from these field
experiences. 1 also think the beginning of concensus
industry standards is a good thing, whether it's for
aesthetic effects  and  performance  characteristics
done  by the Water  Quality Association  (WQA)  or
whether it's the  health related work  of the National
Sanitation  Foundation (NSF).  I  think  its a  good
beginning.

There  is however a need  for what I  consider  the
transfer of  technology.  We need  to  transfer
information about the industry from the  national level
to the local  and individual  level.  This technology
transfer will determine how much  regulation gets
involved in this entire process. We are going to need
to get technical information to the local health officials
because if good things don't happen at the local level,
the response is legislation. To accomplish that, I think
we  need to continue to build on some sort of design
and performance guidelines, both within the WQA and
the NSF or  any third-party  certification  program that
emerges.  I  think  it is a very good idea that  we
consider things like the use of a surrogate  parameter
like chloroform  to see  how design  standards  are
made  useful, and  to look at the  application  of
performance standards. We  will  need  to  apply
performance standards and to  realize that there  still
will be various state standards, not only in what will
be applied, but also variations in what the maximum
contaminant levels are. I  think one  of  the  first
problems that the industry  is going to  have to deal
with is the  various  states'  standards. For  example,
fcom my own experience, for a chemical like 1,1,1-
trichloroethane we are going to wind  up a year from
now with three standards in use. There's going to be
the national  standard, 200 ppb,  which  EPA has
regulated, a standard  in New Jersey that's going to
be 26  ppb; New York is well on its way to having a
standard of 5 ppb. The different local and state health
officials in  those areas will need to have enough
performance information about  GAG units to be able
to make good decisions on what size unit to put in for
what size household. It's going to be important for the
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manufacturers in the industry to develop information
that can be easily understood and transferred  to the
local level for these types of differences in regulatory
efforts.

( want  to discuss the  down side  of having a large
number of  manufacturers -- it  makes  it harder to
get all this done on a consensus basis. It is tougher
to transfer the information,  and it also means that
problems associated with the  introduction  of new
technologies are blown out of proportion. Something
that I see in  the future in terms of New Jersey, is
home  treatment or  point-of-use  units for volatile
organic chemicals, both within private wells and what
I consider  the  new EPA  classification of  water
systems that are non-transient. It's an  area  that
hasn't been talked about a lot during this conference,
but I think that these types of water systems coming
under  new federal  regulation have  more monitoring,
are  going to have  the ability  to  meet  these new
standards, and are going to cause both the states and
industry to address those problems. I think radon will
also continue to be an area where home treatment
units are going to  be  an integral  part of any state
strategy. I think there are some nitrate problems in
New Jersey, and I assume there are other states that
are going to have those problems as well. I also think
lead is an issue  that was not  addressed   here.
Depending upon where EPA goes with its regulations,
there coufd be a need to look very closely at lead
standards and home treatment units, both in terms of
private  individual wells  and in terms of public water
supplies  for  those  spots that  can't be  treated
otherwise.

When  I look  down  the road a  little bit, I  see  four
different options. We could have a huge federal
program or a partial  federal   program  which  has
registration, certification,  design, and  performance
standards. This will go a long way to do certain  things
in terms of assuring public health, but it also  stifles
new innovative designs and  puts a financial burden
on the whole process.

We can have  individual state programs with individual
sets of state  regulations and state registration and
certification programs in some states; in other  states
there won't be many  programs. I'm  not sure  that
people  will  like that. I know that the person from
California didn't say that  their  program started from
the  regulatory effort of the state  officials. It was
started  by the legislature when they had problems in
that state. I  don't  know of many state  regulatory
programs that would initiate a program themselves.
We don't necessarily look for more work to do unless
we feel that there's a huge public health gain.  We're
not sure in these instances whether there is a gain or
whether there isn't.

Third is the direction we seem to be going, which is
consensus guidelines,  third-party  certification,  and
local and state  application  of these  guidelines and
certifications. This has a lot of benefits to it, both from
the industry standpoint and  the state  standpoint. But
it's got to do the job, and it's got to be perceived by
the public, the federal agencies, and  the legislatures
of doing  the job of protecting public health. And if  it
doesn't do that job, then we're going to wind up with
a bigger  regulatory effort since  one of the overriding
principles  is that  the  level  of  regulatory  effort
corresponds to the level of public health  concern.  If
you  have more concern  that things  aren't  working
right, the chances of legislation  and  regulation are
going to increase.

The fourth option  would sort  of  go  backwards  -
not to do anything at the federal and  state level and
let all the local people take care of the problems. It's
a local individual choice. My general belief is that we
have the opportunity to make a good start, and we've
had  a good start at consensus guidelines and third-
party certifications. We are going to have to continue
that effort and make it work. The less that  we make  it
work, the more likely we will get federal regulations or
individual certification programs and  legislation  for
each state.
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                             POUlPOE:AN INDUSTRY PERSPECTIVE
                                           Donna Cirolia
                                    Water Quality Association
                                      Washington. DC 20005
In order for the audience to better understand where
the point-of-use/point-of-entry  (POU/POE) water
quality improvement industry is today, and where it's
going,  it is important to gain a historieal perspective
on where  the  industry  has been. Back in 1976,  the
Water Quality Association  (WQA)  had  only  877
members. Today we have over  2,000  members. At
our convention, which we hold every year in March,
we used to have nearly 100 exhibitors. In the last  five
years,  the number of exhibitors has increased to over
200. Coupled with this expansion, the direction of the
industry has  changed  from  products  dealing solely
with  aesthetics,  to products reducing contaminants.
However,  this  transition into the health arena has led
to a number of new issues and concerns.

WQA  and others  have  developed  programs  to
address these areas, including product validation  and
personnel certification,  which is a  WQA program
designed  to  educate our dealers  who serve  the
consumer.

I certainly agree with some of the other panelists  that
our industry needs to do more in terms of credibility
and accountability for both products and personnel.
However,  we have made great strides.  Today, I may
be preaching to the choir, but it's important that the
industry members in  the audience encourage your
distributors and dealers to become better educated.

We have some  fabulous companies  that  provide
quality products and quality  service. I find it
discouraging to see that some people outside of our
industry  unfairly  judge  the  entire  industry by  the
minority  that  use misleading sales  tactics.  WQA
recognized the  need  to address  the issue of
misleading advertising that occurs in our industry, as
in others,  and developed  the  Water  Quality
Improvement  Industry  Voluntary Product  Promotion
Guidelines. This program is a positive step in the right
direction.

The industry's advertising, products, and services are
constantly improving. Our efforts have been met with
greater recognition by  EPA and  the states,  and  this
seminar proves that.
Where our industry  needs to  do more is in our
relationship with the water utilities. However, they also
need to do a bit more. I  was disappointed that very
few water  utility people  attended  this conference,
particularly  since AWWA was  a co-sponsor. It would
be far better for both industries not to dwell on the
negative  aspects, but rather change with the  times
and adjust  their attitudes  so  that  we  can  both be
partners in  providing quality water. We have  products
that can solve health problems, and also improve the
aesthetic quality of centrally  treated water,  if the
consumer so chooses. This is .based on our system
of free enterprise, where individuals have the right to
choose products of their liking. Utilities should not feel
that the  mere  existence  of the POU/POE industry
undermines the quality of water which they  serve  to
their customers. If a consumer does not like the  taste,
odor,  or color of their water, they have every right to
install a POU device.

Presently,  a few states  are  considering their  own
mandated  product  validation  standard to provide
consumer protection. If WQA  really felt that this was
the answer on  how to provide consumer protection,
we  would  be  out there promoting this  type  of
legislation.  However, we really don't feel that product
validation is the solution. In  every state there are
consumer fraud  laws; the problem is in the lack  of
enforcement.  We encourage  attorneys general and
county consumer  affairs  bureaus  to enforce  their
consumer fraud laws against those  companies that
use misleading  sales  tactics.  Trying  to regulate the
industry  in  terms  of  consumer  protection  through
product validation is not the answer. This will just end
up increasing the cost of the products and services to
the consumer.  The  voluntary standards that  exist
today are in a constant state of flux, being periodically
revised to meet the demands  placed on the  products
in the marketplace. Also, it takes a long time to both
develop   and   revise  consensus  standards.
Realistically, this type of program would  be  very
costly  for  the  states to  implement  and enforce.  I
would rather  see the  marketplace driving our
members to get their products  validated, than the
regulator saying, "Oh, I think we need to protect the
consumer  via  product validation." WQA urges the
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states to use their existing consumer fraud laws, and
if they're not strong enough, then enhance them. This
is a more realistic and  productive  way to provide
consumer protection.

Finally, the industry is at the crossroads of trying to
meet the needs of  many  small systems' and
nontransient,  noncommunity  systems that are facing
the same heavy regulatory  burden  as  other public
water systems.  We're not saying  that point-of-use
and  point-of-entry are the only answers  for these
systems, but they should  be considered as options.
Regionalization may  be cost prohibitive if  the  next
system is many miles away. These systems are going
to be forced  to look  at  new, innovative  solutions
including point-of-use  and  point-of-entry.  The
industry  has made  great  technological strides
concerning  the  monitoring  and  maintenance  of
point-of-use/point-of-entry units.  We do  not have
all the answers but we would certainly look forward to
working with  any state or local government agency
that is interested in the POU/POE option.

In conclusion, WQA realizes that our industry needs
to do more in terms of credibility and accountability.
However, I think this also has to be met by  a greater
willingness, particularly by the water utilities,  to realize
that central treatment is not the only answer. We're
really -partners  in providing  quality water to  the
consumer. That's who we're trying to  please. I just
hope that we'll  have  the opportunity to have more
conferences  such as  this  one  so  that all  the
interested parties including Federal,  state,  and  local
regulators;  water   utilities;   and  POU/POE
manufacturers and dealers can maintain  a continuous
dialogue on these important and  critical issues.  We
are all partners  in, providing  and assuring  safe and
aesthetically pleasing water to the consuming public.
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               POINT-OF-USE TREATMENT OF DRINKING WATER:  COMMENTS
                                           SueLofgren
                                         Tempe.AZ 85282
In three years  on  the National Drinking Water
Advisory Council, as the EPA struggled to implement
the Safe Drinking Water  Act, I could see  that,
particularly as we dealt with public notification, people
were confused and afraid. They would rush out to do
one of two things:  buy bottled water or buy a home
treatment device. It's  a  natural reaction. They didn't
wait  for  the public utility  to come up with a  new
treatment for the contaminant they thought was there.
As a result, I kept  saying to EPA, "This law is going
to give those two industries a license to steal." At that
time there was nothing  to regulate those industries.
Therefore, EPA had a responsibility to do something
to help guide the public  on  as to  the  degree of
effectiveness of these devices.

There  were two items  I bugged EPA  about: point-
of-use and ground  water. At  that time, nobody
thought ground water was a problem. In the 10 years
since that time, I've seen real progress  made in  both
areas. The  industry  has made an immense  drive
forward in terms of trying to police its own, to make
sure that the devices on the market are  effective, that
the advertising is true, and  that manufacturers aren't
resorting to scare tactics.
However, we still have  a long way to  go. What we
have  been talking  about today, and what I think the
New  Jersey  study points out, is that what is still
needed is something for the consumer. I'm  speaking
from  the perspective of the public — the average
person. Where does an individual go to get something
to take care of his concern? If it isn't odor or taste,
smell,  or sight - if it's health concerns, how  does
he know what to get? First of all, he doesn't  really
know what his own  health concern is. What is the
contaminant in the water? What device does he need
to remove that particular contaminant? People call me
in Arizona and think that I am the person that knows
something about  water since  I  seem  to sit on
everybody's committee. But, the state also   gets
called, and they  don't know how to respond. So there
is a real need for something --  somewhere that the
public can  go  to get these  kinds  of questions
answered.

Perhaps the validation of every manufactured device
is the answer in some  form. You can't rely on the
consumer report -  that doesn't give you the kind
of information you need, because there's a diversity
of contaminants out  there. So, I  really think EPA, the
states, and industry have got to come to grips with
this. I  would suggest that  states like New  Jersey,
California, and some of the others who have done
some exploring along the lines of validating or testing,
get together and provide a central repository. EPA or
the  Association   of  State  Drinking  Water
Administrators might be the ones who deal with this.

Once an individual  knows what to buy, he  doesn't
know  how  to  maintain  it.  There are  usually
instructions,  but those instructions  get  lost. How
many people keep all the instructions that come with
anything  they  buy  that  is  mechanical? There  are
filters and cartridges that have to be changed. When
do you change them? Maybe you  remember the first
time, but then maybe you don't. Assuming you even
remember, where do you  go to buy that filter,  that
cartridge?

I'm speaking from personal knowledge. My husband
went out and bought a faucet treatment device while I
was on the council,  and I said "What are you  getting
this for?"  He said,  "Well, in Arizona they dry  up the
canals pnce a year, and when they do,, instead of
surface water, our  utility  provides us  with  ground
water which tastes  bad. " So he wanted something
for taste. I said, "Well, in that case, that's not so bad,
but are you sure it's not one of those that leaches
silver into the  system,  into our water?"  "I don't
know." Well, neither did I to  be truthful. That's the
sort of thing  I'm talking about.

More recently my son called me from Prescott, and I
live in Tempe, that's about 130 miles away. He said,
"I've got a friend who needs to get a cartridge for his
under-the-sink system and he  can't find a  dealer
up here. Where does he go?"  I said, "Look it up  in
the Yellow Pages. If you can't find it there, he'll have
to write  the manufacturer." These  are  the sort of
things that people shouldn't have to deal with.

The water quality  industry also deals with bottled
water.  One  of the  things that we found out on the
Drinking  Water Council  was that the bottled water
                                                 145

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industry  is regulated by FDA. EPA does not have
responsibility or any enforcement ability. All they can
do is set the standards for FDA to enforce. Of course,
FDA had many other concerns  and drinking water
was at the bottom of the totem pole. When we finally
got to talk to the director of FDA who was responsible
for this area, we found out that, not only was it on the
bottom of the totem pole,  it basically never got any
attention.  If you  import  mineral  water, and it says
"mineral  water" — nobody looks  at  it. It was  rather
amazing to us to find out how little attention is paid to
bottled water.

Let me speak from where I am in terms of a person
who is dealing with public involvement programs and.
the needs that I can see out there. I would say that
you  need  to  involve  the  public  more in whatever
you're trying  to  accomplish, whether  you're  an
agency person or industry person. You need to reach
the public with the information.

The future is  going  to call for increased use of the
point-of-use  and  point-of-entry  devices  in  areas
where people are  scattered.  In Arizona for instance,
our  Indian tribes, which  are really  scattered, will
definitely be  looking at  this as  a  potential way to
resolve  some of  their problems. I  urge you as an
industry to continue to look at alternative forms of
treatment because  very few people can handle the
expense of  many  of the conventional  treatment
processes for some of these contaminants. However,
there have to be ways of assuring that those kinds of
treatment devices are monitored and maintained. You
cannot rely on the local  person to be the person to
maintain  the  devices. You  may be  able  to  train
someone, but sooner  or later they're  gone and the
next person  who takes over won't  be trained, and
then you may really have a very bad situation. That is
going to  have  to be one of the  key points, how to
keep something that is effective, in use and properly
maintained.

Finally, I'll just go back to making a pitch for efforts to
increase  the educational level  as  we  deal  with
drinking water and as we discover new contaminants.
And, as we try to explain to the public that they aren't
going to die tomorrow,  that these contaminants, these
MCLs, are based on drinking two liters of water over
a lifetime of 70 years,  that some  of these things are
naturally  occurring, and that the  danger is  not
necessarily immediate, at the same time explain that
one  needs to  do something about  it and to do  it
effectively.
                                                 146
                                                           *U.S. Government Printing Office 1988: 548-158/87002

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