GUIDANCE MANUAL
                                      FOR
                              COMPLIANCE WITH THE
                   FILTRATION AND DISINFECTION REQUIREMENTS
                                      FOR
                             PUBLIC WATER SYSTEMS
                                     USING
                             SURFACE WATER SOURCES
                                      for
                         Science and Technlogy Branch
                        Criteria and Standards Division
                           Office of Drinking Water
                     U.S. Environmental Protection Agency
                               Washington, D.C.
                            Contract No. 68-01-6989
                                   DRAFT
                                      by
Malcolm Pirnie, Inc.                              CWC-HDR, Inc.
100 Eisenhower Drive                              3461 Robin Lane
Paramus, New Jersey 07653                         Cameron Park, California 95682
                                October 8, 1987

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                               TABLE OF CONTENTS
1.   INTRODUCTION                                                     1-1

2.   GENERAL REQUIREMENTS                                             2-1
     2.1  Application                                                 2-1
          2.1.1  Types of Water Supplies                              2-2
          2.1.2  Applicability of the SWTR to Ground Water            2-3
     2.2  Treatment Requirements                                      2-6
     2.3  Operator Personnel Requirements                             2-7

3.   SYSTEMS NOT FILTERING                                            3-1
     3.1  Source Water Quality Criteria                               3-2
          3.1.1  Coliform Concentrations                              3-2
          3.1.2  Turbidity Levels                                     3-5
     3.2  Disinfection Criteria                                       3-6
          3.2.1  Inactivation Requirements                            3-6
          3.2.2  CT Determination for Multiple Disinfectants          3-12
                   and Multiple Sources
          3.2.3  Demonstration of Maintaining a Residual              3-16
          3.2.4  Disinfection System Redundancy                       3-17
     3.3  Other Criteria                                              3-18
          3.3.1  Watershed Control Program    -                        3-18
          3.3.2  Sanitary Survey                                      3-19
          3.3.3  No Disease Outbreaks                                 3-21
          3.3.4  Long-term Coliform MCL                               3-23
          3.3.5  Total Trihalomethane (TTHM)                           3-24
                   Regulations

4.   CRITERIA FOR DETERMINATION OF FILTRATION AND DISINFECTION        4-1
       TECHNOLOGY TO BE INSTALLED
     4.1  Introduction                                                4-1
     4.2  Selection of Appropriate Filtration Technology              4-1
          4.2.1  General Description                                  4-2
          4.2.2  Capabilities                                         4-3
          4.2.3  Selection                                            4-7
     4.3  Available Filtration Technologies                           4-9
          4.3.1  Introduction                                         4-9
          4.3.2  General                                              4-10
          4.3.3  Conventional Treatment                               4-11
          4.3.4  Direct Filtration                                    4-13
          4.3.5  Slow Sand Filtration                                 4-15
          4.3.6  Diatomaceous Earth Filtration                        4-17
          4.3.7  Alternate Technologies                               4-18
          4.3.8  Other Alternatives                                   4-19
     4.4  Disinfection                                                4-20
          4.4.1  General                                              4-20
          4.4.2  Removal/Inactivation Requirements                    4-20
          4.4.3  Total Trihalomethane (TTHM)  Regulations              4-22
          4.4.4  Oxidant Needs                                        4-22

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                         TABLE OF CONTENTS (Continued)
5.   CRITERIA FOR DETERMINING IF FILTRATION AND DISINFECTION          5-1
       ARE SATISFACTORILY PRACTICED
     5.1  Introduction                                                5~1
     5.2  Turbidity Monitoring Requirements                           5-2
     5.3  Turbidity Performance Criteria                              5-3
     5.4  Disinfection Monitoring Requirements                        5-6
     5.5  Disinfection Performance Criteria                           5-6
     5.6  Other considerations                                        5-13

6.   REPORTING                                                        6-1
     6.1  Reporting Requirements for Public Water Systems             6-1
            Using Surface Hater Sources Not Providing
            Filtration
          6.1.1  Source Water Fecal Coliforms (FC)                     6-1
          6.1.2  Source Water Total Coliforms (TC)                     6-2
          6.1.3  Source Water Turbidity                               6-3
          6.1.4  Disinfection Conditions                              6-3
          6.1.5  Watershed Control Program                            6-5
          6.1.6  Sanitary Survey                                      6-6
          6.1.7  Disease Outbreaks                                    6-6
          6.1.8  Total Trihalomethane (TTHM)  Regulations              6-7
          6.1.9  Long-Term Total Coliform MCL
     6.2  Reporting Requirements for Public Water Systems             6-7
            Using Surface Water Sources that Provide
            Filtration
          6.2.1  Treated Water Turbidity                              6-7
          6.2.2  Disinfectant Conditions                              6-9

7.   COMPLIANCE                                                       7-1
     7.1  Introduction                                                7-1
     7.2  Systems Without Filtration                                  7-2
          7.2.1  Introduction                                         7-2
          7.2.2  Source Water Quality Conditions                      7-2
          7.2.3  Disinfection Conditions                              7-3
          7.2.4  Watershed Control Program                            7-4
          7.2.5  Sanitary Survey                                      7-5
          7.2.6  Disease Outbreaks                                    7-6
          7.2.7  Long-term Total Coliform MCL                         7-6
          7.2.8  Total Trihalomethane (TTHM)  Regulations              7-7
     7.3  Systems Providing Filtration                                7-7
          7.3.1  Introduction                                         7-7
          7.3.2  Systems Using Conventional Treatment,  Direct         7-7
                   Filtration or Technologies Other than Slow
                   Sand and Diatomaceous Earth Filtration
          7.3.3  Systems Using Slow Sand Filtration                   7-8
          7.3.4  Systems Using Diatomaceous Earth Filtration          7-8
          7.3.5  Disinfectant Requirements                            7~9

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                         TABLE OF CONTENTS (Continued)
7.   COMPLIANCE (Continued)
     7.4  Responses for Systems not Meeting the SWTR Criteria
          7.4.1  Introduction
          7.4.2  Systems Not Filtering
          7.4.3  Systems Currently Filtering

8.   PUBLIC NOTIFICATION

9.   EXEMPTIONS
     9.1  Minimum Requirements
     9.2  Compelling Factors
     9.3  Evaluation of Alternate Water Supply Sources
     9.4  Protection of Public Health
     9.5  Schedule of Compliance
     9.6  Notification to EPA
                                LIST OF TABLES


          Description

          Removal Capabilities of Filtration Processes

          Generalized Capability of Filtration Systems to
          Accommodate Raw Water Quality Conditions

          Summary of Total Costs of Treatment

                                LIST OF FIGURES
          Description

          Determination of Inactivetion for Multiple
          Disinfectant Application to a Surface Water Source

          Individually Disinfected Surface Sources Combined
          at a Single Point

          Multiple Combination Points for Individually
          Disinfected Surface Sources

          Flow Sheet for a Typical Conventional Water
          Treatment Plant
4-3
Figure
 No.

3-1
3-2
3-3
4-1
                                                                      7-10
                                                                      7-10
                                                                      7-10
                                                                      7-12

                                                                      8-1

                                                                      9-1
                                                                      9-1
                                                                      9-2
                                                                      9-5
                                                                      9-6
                                                                      9-9
                                                                      9-10
Following
   Page

   4-3

   4-8


   4-9
Following
   Page

   3-14
   3-15
   3-15
   4-11

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                         TABLE OF CONTENTS (Continued)

                          LIST OF FIGURES (Continued)

                                                                   Following
          Description                                                 Page
4-2       Flow Sheet for a Typical Direct Filtration Plant            4-13

4-3       Flow Sheet for a Typical Direct Filtration Plant            4-14
          with Flocculation

4-4       Flow Sheet for a Typical Direct Filtration Plant            4-14
          with a Contact Basin

7-1       Surface Water Treatment Decision Tree                       7-2

                              LIST OF APPENDICES

Appendix  Description                                                 Page

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

   B      Institutional Control of Legionella                          B-l

   C      Tracer Test Procedures                                       C-l

   D      A Survey of the Current Status  of Residual Disinfectant      D-l
          Measurement Methods  for all Chlorine  Species and Ozone

   E      Inactivations Achieved  by Various Disinfectants              E-l

   F      Basis  for CT Values                                          p_l

   G      Protocol  for Demonstrating  Effective  Chlorine-Ammonia        G-l
          Disinfection

   H      Sampling  Frequency for  Total Coliforms in  the
          Distribution System                                          H_l

   I       Maintaining  Redundant Disinfection Capability                1-1

  J      Watershed Control Program                                    j_l

  K      Sanitary Survey                                              K_T

  L      Small System Considerations                                  L-l

  M      Pilot Study Protocol for Alternate Filtration Technology    M-l
  N      Protocol for the Demonstration of Effective Treatment       N-l

  0      Protocols for Point-of-Use Treatment Devices

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                              1.  INTRODUCTION

     This  draft  Guidance  Manual  complements   the  proposed  filtration  and
disinfection  treatment requirements  for public  water systems  using surface
water  sources  (otherwise  known as the  Surface Water  Treatment Requirements
(SWTR)).   in   effect,  it  is  a  proposed  Guidance  Manual,  which  may  be
substantially  changed in response  to  information received  during  the public
comment period  and changes to the proposed rule before its final promulgation.
     The purpose of  this manual would  be to provide  guidance to United States
Environmental  Protection Agency  (USEPA)  Regional Offices,  individual states
and affected  utilities in  the implementation of the SWTR, and to help ensure
that  actions  taken   toward  implementation  are consistent.   This manual  is
advisory in  nature and is meant  to supplement the criteria listed under the
proposed  SWTR.   For  example,  the  SWTR  sets  treatment requirements  which
encompass  a  large  range  of  source  water  conditions.   The  guidance manual
suggests design, operating and performance criteria for specific surface water
quality conditions to provide the  optimum protection  of public health through
multiple barrier treatment.  These recommendations are presented as guidelines
rather than  an extension of the rule.   They are offered to give the Primacy
Agency flexibility in establishing the most  appropriate treatment requirements
for the waters  within their jurisdiction.   In order to  facilitate  the use of
this manual,  it has been  structured  to  follow the framework  of the proposed
SWTR as closely as possible.  In this  manual, the term SWTR will always refer
to the criteria of the proposed requirements.

Section 2
     This  section  provides guidance  for determining  whether a  water supply
source is subject to the requirements of the SWTR; including the determination
of subsurface  sources which are at risk to the presence of Giardia cysts or
other  large  microorganisms.   The overall  treatment  requirements of  the SWTR
are also presented, along with operator personnel requirements.
                                      1-1

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Section 3
     For systems which are  subject  to the requirements of  the  SWTR and which
do not  currently provide filtration,  this section  provides guidance  to the
Primacy Agency for determining if a given sources
       -  Meets the source water quality criteria
       -  Meets the disinfection requirements including:
            -  Maintenance of adequate disinfection
            -  Provision for disinfection system redundancy
       -  Maintains an adequate watershed control program
       -  Meets the sanitary survey requirements
       -  Has not had an identified waterborne disease outbreak
       -  Complies  with  the  revised long-term  colifonn Maximum Contaminant
          Level  (MCL)
       -  Complies with total trihalomethane (TTHM) regulations

Section 4
     This section  pertains  to systems which do  not meet the  requirements of
Section 3 and therefore are required to install filtration.  Guidance is given
for  the selection  of  an appropriate filtration technology based on the source
water quality and the capabilities of the technology in achieving the required
performance criteria.  In addition,  recommended  design and operating criteria
are  provided for the available filtration technologies.

Section 5
     To determine if filtration and disinfection are satisfactorily practiced,
Section 5 presents  guidance to the Primacy Agency  for determining compliance
with the turbidity and  disinfection performance requirements.   This section
includes  the recommended  use of  CT  (disinfectant  residual concentration x
contact time) tables for chlorine, chlorine dioxide, ozone and chloramines.

Section 6
     Section 6 provides guidelines  to the Primacy Agency for establishing the
reporting requirements associated with the SWTR.   The requirements include the
                                      1-2

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report  content  and  frequency,  and are  applicable  to  both  filtering  and
nonfiltering  systems.

Section 7
     This section provides guidance  for determining whether or not systems are
in  compliance with  the requirements of the  SWTR.  Guidance  is included for
monitoring,  raw water quality,  source  protection,  distribution system  and
disinfection  for nonfiltering  system together with the  monitoring, effluent
water quality,  distribution  system and  disinfection conditions for filtration
systems.   Guidance  is  given for  corrective  measures which  can be  taken by
systems which are not in compliance with these  requirements.   Examples  are
included for  actions which may  be taken to remedy conditions which are not in
compliance with the  SWTR requirements.

Section 8
     This  section  of  the manual  presents guidance  on  public  notification.
Included  are  examples  of  occurrences  which  would  require  notification,
language of notices  and the method of notification.

Section 9
     Section 9 provides guidance to  the Primacy Agency for determining whether
or not  a  system is  eligible  for an exemption.  The criteria for eligibility
for exemption include:
       -  Compelling factors  (economic or resource limitations)
       -  No available alternate source
       -  The protection of public health
This section  also covers  an evaluation of the  financial capabilities of  a
water system, the review of the availability of alternate sources and measures
for protecting public health.

Appendices
     The manual  also contains several appendices  which provide  more detailed
guidance in specific areas.   These include:
                                      1-3

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Appendix A - Use of Particulate Analysis
for Source and Water Treatment Evaluation
     A  study involving  150 water  sources  resulted  in the  identification of
particulate  matter  which  is   indicative  of  a  surface  water.   A  paper
summarizing the results of the study is included in this appendix.

Appendix B - Institutional
Control of Legionella	
     Treatment provides protection  from Legionella;  however, it cannot  assure
that  re contamination or regrowth will not occur in the hot water or cooling
systems  of  buildings within the distribution  system.   This appendix provides
guidance  for the monitoring and treatment  which  can be used by institutional
systems  for  the control of Legionella.

Appendix C - Tracer  Test Procedures
      In many cases the determination of contact times  needed to evaluate the
CT maintained  in the system will necessitate the use of tracer studies.  This
appendix provides  guidance for conducting these studies.

Appendix D - A Survey of the Current
Status  of Residual Disinfectant
Measurement Methods  for all Chlorine
Species and Ozone
     This  appendix  is  a copy  of  an  executive  summary  of  a report  on the
analytical methods used  to measure  the residual concentrations of the various
disinfectants.   The  reliability and  limitations of  each  of  the  methods are
also presented.

Appendix E - Inactivations Achieved
by the Various Disinfectants	
     This appendix presents the log inactivations of Giardia cysts and enteric
viruses which are achieved at various CT levels by chlorine, chlorine dioxide,
chloramines and ozone.
                                      1-4

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Appendix F - Basis for CT Values
     This  appendix   provides  the  background  and  rationale   utilized  in
developing  the  CT  values  for  the  various  disinfectants.   Included  is  a
currently unpublished paper by  Clark et al.,  1987,  in which a  mathematical
model was used in the calculation of CT values for  free  chlorine.   The paper
is included in the appendix.

Appendix G - Protocol for Demonstrating
Effective Chlorine-Ammonia Disinfection
     This appendix provides  the recommended  protocol  for demonstrating  the
effectiveness of chloramines as a primary disinfectant.

Appendix H - Sampling Frequency for
Total Coliforms in the Distribution System
     The sampling  frequency required in the proposed total coliform  rule  is
presented in this appendix.

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

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

Appendix K - Sanitary Survey
     This appendix provides guidance  for a comprehensive  sanitary survey of a
supply source, its treatment and delivery to the consumer.  The contents for a
more general annual survey are included in Section 3.
                                      1-5

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

Appendix M - Pilot Study Protocol
for Alternate Filtration Technology
     This appendix presents  pilot study protocols to evaluate the effective-
ness  of  an alternate filtration  technology  in attaining  the  performance
requirements of the SWTR.

Appendix N - Protocol for the
Demonstration of Effective Treatment
     This appendix  provides guidance  for conventional and  direct filtration
plants  to  demonstrate  that effective   filtration   is  being maintained  at
effluent turbidities between 1 Nephelometric Turbidity Unit  (NTU) and 0.5 NTU.

Appendix 0 - Protocol for
Point-of-Use Treatment Devices
     In  some  limited  cases,  it may  be  appropriate  to install point-of-use
(POU)  or point-of-entry  (POE)  treatment devices as an  interim measure  to
provide protection to  the public health.   This appendix provides  a protocol
for evaluating and determining the efficacy of POU/POE treatment devices.
                                     1-6

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                           2.  GENERAL REQUIREMENTS

2.1  Application
     The  SWTR pertains  to  all public water  systems which utilize  a surface
water source.   The  SWTR defines a surface water as  all  waters which are open
to the atmosphere and subject to surface runoff  (e.g., rivers, lakes, streams,
reservoirs,   impoundments)   and  any  subsurface  sources  such  as  springs,
infiltration  galleries,  wells  or other collectors which are  at risk of being
contaminated  by a surface water.  Historically, the  term "surface water" has
generally  meant  "water which  is   located  upon  the surface  of  the earth."
Conversely, all water which existed underground was considered  to  be ground
water.  While  it  has  been known for some time that ground water is subject to
various  forms of natural  and man-made  contamination,  it has  generally been
believed  that  ground  waters  in   subsurface  aquifers  are  free  from  the
pathogenic organisms  that have  been the  traditional concerns  of surface water
supplies.  However, it is now known  that some subsurface waters may be subject
to contamination  from pathogenic organisms through the  direct  influence of a
surface water  (Hoffbuhr, 1986).
     Primarily, only  those subsurface sources which are  at risk to contamina-
tion from  large microorganisms such as  protozoa (specifically Giardia cysts)
will be subject to  the  requirements  of the SWTR.   It is  not the intent of the
SWTR at  this  time  to include subsurface sources  which  are not  at  risk from
Giardia cysts but which may  be  at  risk to contamination  from  enteric viruses.
The  treatment requirements  for  such systems will  be covered under  a future
regulation for ground waters.
     The  Primacy  Agency  has the  responsibility  for stipulating  which water
supplies  must  meet  the  requirements  of  the  SWTR.   However,  it  is  the
responsibility  of the water  supply  system to provide the Primacy Agency with
the  information,  as  requested to  determine whether or  not  the utility  is
subject to the SWTR.  This section provides guidance to the Primacy Agency for
determining which water  supplies are surface  waters or  directly influenced by
a surface water and are thereby subject to the SWTR.
                                      2-1

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     2.1.1  Types of Water Supplies
     Surface water supplies that are often  used as sources of drinking  water
include  two major   classifications,  namely  running  and  quiescent  waters.
Streams,  rivers  and brooks  are subdivisions  of running  water  while  lakes,
reservoirs, impoundments and ponds are subdivisions of quiescent waters.  The
exposure  of surface waters  to  the atmosphere  results  in vulnerability  to
precipitation  events,  surface  water runoff  and  contamination  with  various
parameters  resulting  from activities  in  their  surrounding  areas.   These
sources are subject to the requirements  of the SWTR.
     The  traditional concept  that all  water in  subsurface aquifers  is con-
sidered to  be  free  from pathogenic  organisms is because  soil is an effective
filter  that removes microorganisms  and  other  relatively large particles  by
straining  and  antagonistic  effects  on  the  natural  bacterial  population
(Bouwer,  1978).  The pathogenic bacteria  retained  in the soil  find themselves
in  a  hostile  environment,  are  not able  to  multiply  and  eventually die.
                                              •*
However,  some underground sources of drinking water may  be subject to contam-
ination by  pathogenic  organisms from the direct influence of nearby surface
waters.   A  microbiological analysis  program conducted on  70 water systems in
Colorado  identified several parameters which may indicate the direct influence
of  a surface water  on a water supply.  These parameters  are:  diatoms,  plant
debris,  rotifers,  coccidia,  insect  parts and Giardia  cysts (Hoffbuhr, 1986),
This study  represents the best available information to date and suggests that
          v   J^
the main water  quality  characteristics  that distinguish ground  water from
surface water  are the  existence of  plant matter and certain algae and micro-
biological  organisms in surface water which  normally are  absent  from ground
water (Hoffbuhr, 1986).  A  paper summarizing  the results  of  this  study is
included  in Appendix A.
      A  subsurface source of water should be considered subject to requirements
of  the  SWTR if the  source is  at risk to the introduction of Giardia cysts and
other pathogenic organisms generally larger than 7 micrometers in diameter.
      Section 2.1.2 presents a recommended procedure for determining whether or
not a source will be subject to the requirements of the SWTR.
     1.   Giardia  cysts range  in  size  from  7  to 14  urn.  Therefore,  7 urn
          represents the lower limit of Giardia cyst size.  (Hoffbuhr, 1986)
                                      2-2

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     2.1.2  Applicability of the SWTR
     It  is  the responsibility  of the water  purveyors to supply  the Primacy
Agency with the information requested to determine which water supplies within
its  jurisdiction  would be  subject to  the requirements of  the SWTR.  A two
tiered approach has been developed as  the recommended method  of  determining
whether a water supply source is at risk.     This approach is consistent with
the  intent of  the definition  in the SWTR, which is  to  identify water supply
sources  which  may be  at  risk of  contamination  by Giardia, or  as previously
explained, pathogens greater than 7 micrometers in diameter.
     The two tiers are as follows:
     Tier 1 - Initial evaluation.
     Tier 2  -  A  review of  microbiological/biological analysis  of the source
     water.

Tier 1 - Initial Evaluation
     It  is  recommended that all  water supply  sources  be  evaluated at the
Tier 1 level.  An initial evaluation should be made of the water supply source
and a determination made as to the type of source.  Specifically:
     a.   Sources  which  are  open to the  atmosphere  and  subject  to surface
          runoff meet the definition of a surface water and no further evalua-
          tion is required.
     b.   With the  exception of  wells,  for all  other sources which  are not
          open to the  atmosphere,  or  are not  subject to surface water runoff,
          including springs  and  infiltration  galleries,  the evaluation should
          proceed to Tier 2.
     c.   In the majority of  cases, wells  can be  considered  to not be at risk
          to  contamination  by  Giardia  cysts.    However,  there may be  some
          special cases that  the Primacy Agency is  aware of,  such  as wells in
          Karst  limestone  aquifers,  which  may  be  potentially  at risk  to
          Since the  Primacy Agency will  need to make  this  determination for
          all water supply sources within its jurisdiction within 12 months of
          adoption of  the SWTR,  detailed and exhaustive  evaluations  of each
          water supply source may not  be  feasible.  It is anticipated that the
          majority of  the water  supply  sources  will  require  only a  Tier 1
          evaluation in order to make the determination.
                                      2-3

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          contamination by  Giardia  cysts.   For  these special  cases,  it  is
          recommended that the evaluation proceed to Tier 2.  '
     For many water supply sources  (i.e., known  surface water sources such as
rivers,  lakes,  and streams),  this  evaluation  may  not require  the physical
presence of the Primacy Agency representative.   An alternative for  conducting
a  Tier 1 evaluation is  a mailed  questionnaire  to  the systems.   Only those
systems  which  indicate  that their  source  does not  meet the definition of a
surface  water  and whose  source  is not  a  well would  be required  to move  to
Tier 2.

Tier 2
     Water supplies which have already been determined to be surface waters or
wells will not be evaluated at this level.   This evaluation should be applied
only to  springs,  infiltration  galleries and other supplies  which the Primacy
Agency  feels  may be  at  risk,  and  consists  of a microbiological/biological
analysis of the source water.
     It  is  recommended that this  sampling and  analysis be  conducted during
periods when stream flows and water tables are highest such  as  in the spring
and fall.  This should  cover  the period(s) when contamination by these orga-
nisms would most  likely occur.  The evaluation should  include  a  minimum  of
weekly samples prior to a storm  event and twice weekly  samples  for two weeks
following the storm event.
     A microbiological/biological analysis should be performed on the samples.
Most of these analyses involve filtering the water samples, extracting the
     3.    A study conducted  on 150 water  systems identified that  some wells
          contained  particulate matter  indicative of surface water.   Thereby
          suggesting that the well  were being influenced by a  nearby surface
          water.   (Hoffbuhr,  1986)
                                      2-4

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solids from the  filter and examining them under a microscope for the presence

of the microbiological/biological organisms listed below.(4)

     The  detection of  Giardia cysts, coccidia,  or other  particulate matter

such as  diatoms, rotifers,  plant debris, insect parts  or shells  of diatoms

which require  surface conditions for their survival,  confirm  that the source

is subject  to  the requirements  of  the. SWTR.      If none  of  these parameters

are  detected  during  the  microbiological/biological  investigation,  then  the

source  is not  at risk,  the  SWTR  does  not  apply and  the investigation  is
complete.

     In general,  water supply sources in which the presence of the indicator

organisms has  been confirmed  should be  considered to be subject  to the  re-

quirements of  the SWTR.  However,  in some cases such as  springs,  a detailed

site evaluation may  be appropriate.  Specifically,  the site  evaluation  may

indicate that  the source  is  at risk due  to a  condition or situation which  can

be corrected,  enabling water  quality to meet  the  Tier 2 criteria  to demon-

strate that the SWTR does not apply.
     4.   The test procedures  for microbiological  and biological analyses are
          presented  in  Standard Methods  for the  Examination  of Water  and
          Wastewater,  16th edition,  (Standard Methods)  specifically  methods
          912K, and 1002.

     5.   Coccidia  are host  specific parasites  10-20  micrometers  in  size,
          which  are  found in  animals  and  fish.   Giardia  is  a  protozoan
          pathogen which ranges  in size from 7-14 micrometers, and is excreted
          by a variety of  mammals.   These  organisms are not indigenous to the
          underground environment, and therefore do not generally multiply in
          the  absence of  animal  tissue  and will  eventually  die  in  these
          surroundings.   If these  microorganisms   are  detected  in  a  ground
          water, it may be assumed that they were introduced to the system via
          direct influence of a  surface source.  Several biological parameters
          which  are  indicators  of  surface water  influence  include  diatoms,
          rotifers, plant  debris,  and insect parts.   Diatoms  are a  type of
          algae which contain  silica  in  their cell walls and require sunlight
          for survival.  Undigested  fecal material  from herbivorous mammals,
          such as beavers  and  muskrats,  usually  consist of plant debris which
          is  therefore  an  indicator   of animal  activity.   Rotifers  are
          microscopic  animals,  150-600  micrometers  in  size  which  require
          sunlight.
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      At this  point,  a more detailed visual inspection and review of pertinent
 data (such as construction of  the  source intake) should  be made to identify
 any defects which may allow such  contamination and  to determine corrective
 action  which may be taken to  provide  maximum protection of the source  from
 contamination,  better  enabling the  water  supply  system  to  meet  the  SWTR
 criteria evaluated during  the Tier 2 investigation.

 2.2  Treatment Requirements
      According  to the  proposed SWTR,  all community  and  noncommunity  public
 water systems which use a surface  water source  must  ensure  the consumers'
 safety  from  pathogenic bacteria,  viruses and  protozoan  cysts,  through the
 provision of  treatment which  achieves  a  minimum  of 99.9 percent  (3  log)
 removal and/or  inactivation of Giardia cysts, and a minimum of 99.99 percent
 (4  log)  removal  and/or inactivation  of  enteric  viruses.   Filtration  plus
 disinfection  or  disinfection alone may  be utilized  to  achieve these perfor-
 mance levels,  depending on the source water  quality and site specific  con-
 ditions.   The SWTR establishes  these removal and/or inactivation requirements
 for Giardia and  enteric viruses because  this  level  of treatment  will  also
 provide   protection   from   heterotrophic  plate   count   (HFC)   bacteria  and
 Legionella as required in the SDWA amendments.
      Surface  water   systems which  currently  provide disinfection  alone  must
 either  meet source  water  quality  criteria  and  site  specific  conditions, or
 install  a  currently  accepted  filtration technology or an alternate technology
 which meets the  performance criteria.  The  source water quality criteria and
 the  site  specific  conditions  which are  required  in  the  SWTR  for systems
 providing  disinfection  alone  are presented in Section 3 of  this manual.  The
 purveyor  should  collect and submit the  required  source  water  quality and
 specific site conditions/data to the Primacy Agency for review and determina-
 tion of whether additional treatment is required.  The investigation of  exist-
 ing  conditions may be both time consuming and expensive  and does not  ensure
 that filtration will not be required.  Given the uncertainties involved  in the
 above review,  the system  may  elect to  install  a  filtration  technology as
presented  in Section 4,  rather  than  expend a large amount of time, effort and
 finances to generate the necessary data for the system evaluation.
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     Section 4  of this manual presents design  and  operating criteria for the
filtration technologies  to achieve the finished water quality requirements of
the  SWTR.  The  removal  of  Giardia cysts  and enteric  viruses  achieved by
conventional  treatment,  direct  filtration,  slow  sand filtration  and diato-
maceous  earth  are dependent on the  quality  of  the  water being treated.  Thus
in  addition  to  the  minimum  requirements  of  the  SWTR, Section 4  presents
guidelines for  the effectiveness of  the treatment processes for certain source
water  quality  conditions.   The  removals  achieved by  the different processes
under  these  conditions  are  presented along with guidelines for disinfection
which  is  needed to achieve the overall removal  and/or inactivation of Giardia
and  viruses  required  in  the  SWTR.   Each of  these filtration  processes in
conjunction with the  recommended  disinfection  can  be assumed to  achieve at
least  a  3 log  removal and/or inactivation  of  Giardia  cysts and  at  least  a
4 log  removal and/or inactivation  of enteric viruses.  A system which utilizes
filtration technologies other  than those cited above may follow the guidelines
presented in Section 4.3.7 to  determine whether or not an alternate technology
provides  the  level  of treatment  necessary  to  meet  the requirements  of  the
SWTR.

2.3  Operator Personnel Requirements
     The  SWTR requires that  all  systems must be operated by qualified person-
nel,  and the  Primacy Agency  must  set standards  for the  required  operator
qualifications,  in accordance with the system type and  size.   In  order to
accomplish this,  the Primacy Agency should  develop  a method of  evaluating an
operator's competence  in operating a water treatment system.  States which do
not currently have a certification program are thereby encouraged to implement
such a program.  An operator certification program provides a uniform base for
operator  qualifications  and  an organized  system for evaluating these qualifi-
cations.
     It is recommended that plant  operators have a basic knowledge of science,
mathematics  and  chemistry involved with  water  treatment  and   supply.   The
minimum requirements for an operator should include an understanding of:
       -  The principles of water  treatment and distribution and their charac-
          teristics
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       -  The uses of potable water and variations in its demand

       -  The importance of water quality to public health

       -  The equipment, operation and maintenance of the distribution system

       -  The treatment process equipment utilized, its operational parameters
          and maintenance

       -  The principles of  each process unit  (includes  the  scientific basis
          and purpose  of  the operation and  the mechanical components  of the
          unit)

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

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

       -  The current National Primary Drinking Water  Regulations, the Secon-
          dary  Drinking  Water  Regulations  and   monitoring  and  reporting
          requirements

       -  Methods of sample collection and sample preservation

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

       -  The use of laboratory results to analyze plant efficiency

       -  Record keeping

       -  Customer relations

       -  Budgeting and supervision (where appropriate)

     Training in  the  areas listed above  and others is available through the
American Water Works Association AWWA training  course  series  for water supply
operations.  The course series includes a set of four training manuals and one
reference book as follows:
       -  Introduction to Water Sources and Transmission (Volume 1)

       -  Introduction to Water Treatment (Volume 2)

       -  Introduction to Water Quality Analyses (Volume 4)

       -  Reference Handbook:  Basic  Science Concepts and Applications
                                      2-8

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       -  Instructor Guide and Solutions Manual for Volume 1
       -  Instructor Guide and Solutions Manual for Volume 2
       -  Instructor Guide and Solutions Manual for Volume 4
       -  Introduction  to Water  Distribution  (Volume  3)  and  its  instructor
          guide
     These manuals are available through the American Water Works Association,
6666 West Quincy Avenue, Denver, Colorado 80235 USA, (303) 794-7711.
     The  State of California also  offers  a series  of training manuals  for
water  treatment  plant operators prepared  by the California  State  University
School of Engineering in Sacramento.  The manuals include:
     1.   Water Supply System Operation, 1 Volume
     2.   Water Treatment Plant Operation, 2 Volumes
     3.   Operation of Wastewater Treatment Plants, 3 Volumes
     4.   Operation and Maintenance of Wastewater Collection Systems, 1 Volume
     These  operator  training manuals  are  available  from  California  State
University,  Sacramento,  6000 J Street,  Sacramento,  California 95819,  phone
(916) 454-6142.
     Completion  of an  established  training and  certification program  will
provide the  means of ensuring  that the operators  have received training  in
their  respective  area,  and are qualified  for their position.   The education
and experience requirements for certification should be commensurate with the
size and  the complexity of the treatment  system.   At  the present  time,  some
states have instituted a certification program while others have not.  Follow-
ing is a  summary  of  the basic contents of a certification program, which can
serve as a guide to the Primacy Agency in developing a complete program.
       -  Board of  examiners for  the development  and  implementation  of  the
          program.
       -  Classification  of  treatment  facilities  by grade  according  to  the
          size and technology of the facilities.
       -  Educational and experience requirements for operators of the various
          treatment facilities according to grade.
       -  A written/oral  examination to determine the  knowledge, ability  and
          judgement of the applicants with certification obtained upon receiv-
          ing a passing grade.
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       -  Renewal  program for  the  license  of  certification, including  the
          requirement of additional coursework or participation in workshops.
     The certification program should provide  technically qualified personnel
for the operation of the plant.
     The extensive  responsibility  which is placed on  the operating personnel
warrants the development  of  an  outline of the responsibilities  and authority
of the personnel members  to aid them in the  efficient  operation  of the plant.
The major  responsibilities  which should be  delegated in the outline  of  re-
sponsibilities include:  the normal  day-to-day operations,  preventive mainte-
nance, field engineering,  water  quality monitoring, troubleshooting, emergency
response,  cross-connection  control, implementation of   improvements,  budget
formulation, response  to  complaints and public/press  contact.   A reference
which the  Primacy  Agency may utilize  in developing  the  outline is  "Water
Utility Management Practices"  published by  AWWA.
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                          3.0  SYSTEMS NOT FILTERING


     The  provisions of  the SWTR  require  that filtration  or a  participate

removal technology  as approved by  the Primacy Agency,  must be included in the

treatment  train  unless  certain  criteria   are  met.    These  criteria  are

enumerated in this chapter and include:

     Source Water Quality Conditions

     1.   Coliform concentrations  (total or fecal).
     2.   Turbidity levels.

     Disinfection Criteria

     1.   System maintains at least 99.9 percent Giardia cyst inactivation and
          99.99 percent enteric virus inactivation.

     2.   System maintains  a residual  of  at least 0.2 mg/L at all  times  in
          water entering  the distribution system,  demonstrated by continuous
          monitoring.  System  must have redundant  backup components  with  an
          auxiliary  power  supply, automatic  start-up  and  alarm to  ensure
          continuous disinfection.

     3.   System maintains a disinfectant  residual  in  the distribution system
          of at least 0.2 mg/L in  no  less  than 95 percent of the samples each
          month for any two consecutive months.

     Site Specific Criteria

     1.   System maintains a watershed control program.

     2.   System has  an on-site  sanitary  survey each  year conducted  by the
          Primacy  Agency, or  a  party  approved  by  the  Primacy  Agency,  to
          demonstrate that the system has no sanitary defects.

     3.   System  in  its  current  configuration  has  not had an  identified
          waterborne disease outbreak as determined by State  or local health
          officials.

     4.   Compliance with  the  proposed  total  coliform long-term MCL  for the
          distribution system.

     5.   System serving  more  than  10,000 people  is  in compliance  with the
          Total Trihalomethane (TTHM) regulation.

     The purpose of this section is to provide guidance  to the Primacy Agency

for determining compliance with these provisions.
                                      3-1

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 3.1   Source Hater  Quality Criteria
      The  first step in determining  if filtration is required for a given  sur-
 face  water supply  is to determine if  the supply meets the source water quality
 criteria  as  specified  in the SWTR.   The site  specific criteria pertaining  to
 systems which  do not filter are not applicable unless the source water quality
 criteria  are met or unless the system is eligible for an exemption.
      Sampling  Location
      The  SWTR  requires that  the  source  water  samples  be  collected  at a
 location  just  prior to the point of disinfection where the water is no  longer
 subject to surface  runoff.  When multiple sources are used, sampling should  be
 conducted at  a location just  prior to  the  disinfection  sequence  used for
 calculating the CT. It is  unimportant what is done to the water before  this
 point because  this is  the water which will be treated in accordance with the
 requirements of the SWTR and is, therefore, the source water.
      3.1.1  Coliform Concentrations;   Specifically, the SWTR states that the
 system must demonstrate that  either the fecal coliform concentration is  less
 than  20/100 ml  or  the  total coliform  concentration is  less than 100/100 ml  in
 the water prior to  the  point of  disinfectant  application in 90 percent of the
 samples taken  during any  consecutive six month period.   Where monitoring for
 both  parameters has  been  conducted,  it  is  suggested  that  the  analytical
 results for both  total coliforms and fecal coliforms  should be  reported and
 the source may exceed  the  total coliform  limit but  not the  fecal coliform
 limit.  In addition, it is suggested  that  if  the turbidity of a surface water
 source is greater than  5 NTU and is blended with  a ground water to reduce the
 turbidity, the  high turbidity water  prior  to blending should  meet the fecal
 coliform source water quality criteria.
     Ongoing monitoring is required  to ensure   that  these  requirements  are
 continually met.  The  samples may  be  analyzed using either the multiple tube
fermentation  method or  the membrane filter  test  (MF)  as presented in the 16th
edition of Standard Methods.
     Sampling  Frequency
    Minimum  sampling frequencies are as follows:
                                      3-2

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           Population Served             Samples/Week

                <501        '                  1
                501-3,300                     2
                3,301-10,000                  3
                10,001-25,000                  4
                >25,000                       5

     The  sampling  frequency  must be  increased  to one measurement  every day
 during which  the  turbidity exceeds  1 NTU.

     The minimum  sampling frequency is sufficient  for systems utilizing large,

 quiescent  water bodies  including lakes and  large  reservoirs,  as the source,

 unless  the   watershed  contains  grazing   areas,   in  which  case  additional

 monitoring should be conducted, as stated below.  Systems utilizing ponds and

 streams  which  may be more readily affected by surface water  runoff should

 perform daily monitoring,  for  a  three-day  period  immediately following storm

 and  runoff  events.   To  determine  the additional monitoring  which may  be

 necessary,  a   system  should  review  its   current watershed  activities  and

 historical source water  quality  data  for a  6-month period.   It is suggested

 that for the  existing historical  data:

       -   If  the   historical  data base  available  for  coliform concentrations
           contains less  than four samples per month  or  less  than  1/2  the
           number  of  samples  generated from the  minimum  monitoring program
           previously outlined,  the minimum  sampling program should  be  aug-
           mented  to daily  samples  for a three-day period  following  storm or
           runoff  events.

       -   If  the  data base shows that not  more  than  10 percent of the source
           water samples  have shown the presence  of.  coliforms,  the minimum
           sampling frequency  is adequate.

       -   If  the  data show that  the  coliform levels have  remained  less  than
           100 total coliforms/100 ml or less  than  20 fecal coliforms/100 ml in
           less  than 90 percent  of the  samples during the 6 months, the minimum
           sampling should  be  augmented to  one  sample/day  for  a  three-day
          period  following a  storm  or  runoff  event.

       -  All  systems which  contain  grazing areas in  the  watershed should
           increase  the source water monitoring  to daily  samples  for a three-
          day period  following  a  storm or runoff event.

     Systems which conduct this increased  sampling after  storm events should

review the test  results  to determine  if  the storms are  affecting  the water

quality.   Systems which exhibit  less  than 10 percent  of the  fecal  or total

coliform samples  above 20/100 ml  or 100/100 ml,  respectively, after six storm


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 events,  may resume  minimum monitoring, including  daily monitoring when  tur-
 bidity levels  exceed 1  MTU.
      Following the initial  determination by  the Primacy  Agency based on  either
 historical data  or a  newly generated data base,  systems must  continue to
 conduct  the miniaium sampling to  fulfill the  ongoing requirement  of meeting the
 source water  quality  criteria.   It  is recommended  that in addition to the
 minimum  sampling frequency,  systems be required to conduct daily  sampling for
 a three  day period following at  least one  storm event per season.
      The SWTR  requires the  Primacy  Agency to  determine which systems  must
 install  filtration within 12 months of adopting the regulation.   It is  recog-
 nized that the potential  exists  for the Primacy Agency to be so  inundated  with
 data  within the 12-month  period  that making the determination within  the  time
 constraints of the  SWTR  would not be possible.   To avoid  this,  the Primacy
 Agency is  encouraged to seek ways of  making  the determination within a shorter
 time  span  wherever possible.  To facilitate this determination, the following
 recommendations are  made:
      Utilization of  a Historical Data Base
     Many  systems  already  routinely monitor their source  water for  total
 and/or fecal coliform concentration.   Consequently, this historical data  base
may be sufficient  for the Primacy Agency  to make the determination of whether
or not the system meets the  source  water  quality  criteria.   The historical
data base  is considered sufficient  for making this determination if:
       -   The   raw water  sampling  location  is   upstream of   the point of
           disinfectant  application  as previously defined.
       -   The   samples  represent  at  least  the   minimum sampling frequency
          previously mentioned.
       -   The  sampling  period covers  at least the major  seasonal water quality
           events such as  spring runoff, summer low flow  conditions, etc.
     Generating a  Data  Base
     For systems  which do  not  have  an  adequate historical  data base,  the
determination  can  be made within a  6-month period with the monitoring program
previously  sited,  covering seasonal water quality conditions.   For example, if
it is known that the  poorest water  quality conditions occur  during spring
runoff and summer  low  flow  conditions,  monitoring during  those months  may
                                      3-4

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provide  sufficient  information  to  make  the determination.   The  sampling
frequency for the monitoring program must first be determined.

     3.1.2  Turbidity  Levels;   The SWTR requires  that, prior to disinfection,
the  turbidity  of  the water  must  not  exceed  5 NTU,  unless the  following
conditions are met:
     a.   There are not more than  two periods  in any 12 consecutive months and
          not  more than  five periods  in  any 120 consecutive months  during
          which  the turbidity exceeds  5 NTU.  A  period is  defined  as  any
          number  of   consecutive   days  in  which  at  least  one  turbidity
          measurement  exceeds  5 NTU each day,  and;
     b.   The  Primacy  Agency  determines  that the event or  events leading to
          the period(s) exceeding  5 NTU are unusual or unpredictable, and;
     c.   During  the  periods  when the turbidity exceeds  5 NTU, the  system
          informs its  customers to boil the water before consumption.
     Utilizing  the  same  sampling location  requirements  as  stated in  Sec-
tion 3.1, the determination of compliance is based upon the collection of grab
samples  at  least  every  four  hours.      It  is  recommended  that  the  initial
determination  of  compliance with  the  turbidity  criteria  be based  upon  data
from 6 consecutive  months  or an equivalent period of  sampling  as is required
for the  coliform determination.   As  presented in Section 3.1.1,  the  Primacy
Agency is encouraged to make  the  initial determination of compliance with the
turbidity criteria  in  less than  the  6-month  period wherever  possible.  This
includes the use of a historical data base  wherever possible.
     Any  system which exceeds the  5 NTU  maximum  limit at any  time  should
notify the Primacy Agency at the time of occurrence.
     In order to determine if  the periods in which the turbidity exceeds 5 NTU
are unusual or unpredictable,  it is recommended that in addition to the
          The SWTR  permits the  use of  continuous  turbidity monitoring  as  a
          substitute  for  grab   sample   monitoring  if  the  measurement  is
          validated for  accuracy with grab  sample  measurements on  a regular
          basis as  determined by the Primacy  Agency.   Validation  should be
          performed at least  twice  a week based on the procedure  outlined in
          Part 214A in the 16th Edition of Standard Methods.
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historical  turbidity  data, the water  purveyor should collect  and provide to
the  Primacy Agency  current and  historical  information on  flows,  reservoir
water  levels,  climatologieal conditions,  and any other information that the
Primacy  Agency  deems relevant.   This  information  should  be  evaluated to
determine if the event was unusual or unpredictable.
     If  the period (s) of turbidity greater  than 5 NTU  have  been shown to be
the  result of  unusual or  unpredictable events  such as  hurricanes,  floods,
avalanches  or earthquakes,  the  Primacy Agency may permit  the system to avoid
filtration  if the  system  issues a boiled water notice or the system agrees to
stop the delivery of water which exceeds the source water quality  limits by:
       -  Utilization of  an alternate  source which is not a surface water and
          does not have to meet the requirements of the  SWTR.
       -  Utilization  of  an alternate source  which is  a surface  water and
          which does meet the requirements of the SWTR.
       -  Utilization  of  storage  to  supply the  community until the source
          water quality meet the criteria.

3.2  Disinfection Criteria
     3.2.1  Inactivation Requirements
     The SWTR requires  that systems which do  not  filter must practice disin-
fection  for  the protection  of  public  health.   Systems  which  potentially
contain any sources of human enteric viruses within the watershed must demon-
strate by  ongoing  monitoring  that they are  achieving disinfection conditions
expected to provide a 99.9 percent (3 log) inactivation of Giardia cysts and a
99.99 percent  (4 log)  inactivation of enteric viruses  at  all times  of the
year.   Systems  which contain  no sources  of  enteric  viruses within  their
watershed are only required to  provide a 3 log inactivation of Giardia cysts.
Potential  sources  of  these viruses  include  sewage  discharges,  septic  tank
discharges, swimming, boating,  camping,  fishing, hiking, hunting or any other
human usage or habitation which may result in human waste disposal within the
watershed.
     There   are  a number  of  disinfectants which  can be used.   These  include
ozone,  chlorine, chlorine dioxide and  chloramines.   The SWTR  establishes CT
                                      3-6

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 [residual  concentration   (ng/L)  x  contact  time   (min)]  levels  for  these
disinfectants  which will  achieve  the required inactivation,  as explained in
the following  subsection.
     It  has been  found  through  studies that  Giardia cysts  are ouch more
resistant  to chlorine, chlorine  dioxide and  ozone than are  enteric viruses
 (Hoff, 1986).  Therefore,  for these  disinfectants,  it is sufficient to demon-
strate that a  CT  level which  achieves a 3 log inactivation of Giardia cysts is
being  maintained.   These  CT values  will  provide much  more  than  a  4 log
inactivation of enteric viruses  as required by the SWTR.   In accordance with
this, the  CT requirements presented for  chlorine,  chlorine dioxide and ozone
are for the  3  log inactivation of  Giardia cysts.   The SWTR also requires that
the public be provided  with  protection  from Legionella  as well  as Giardia
cysts  and  enteric  viruses.   Inactivation  levels  have   not  been  set  for
Legionella because the required  inactivation of  Giardia cysts  will provide
protection  from  Legionella.     However, this  level of  disinfection  cannot
assure that all Legionella will be inactivated and that no recontami nation or
regrowth in  recirculating hot water  systems of buildings  or  cooling systems
will occur.   Appendix B provides  guidance for  the monitoring  and treatment
which can be used by institutional systems for the control of Legionella.
     Definition of CT
     The SWTR  defines  CT  as  the residual concentration(s)  in mg/L multiplied
by the respective contact time(s)  in minutes from the point(s) of disinfectant
application to a point prior  to the first customer.  In pipelines, the contact
time is calculated by dividing the internal volume of the pipeline by the peak
          Kuchta et al. (1983) reported a maximum CT requirement of 22.5 for a
          99 percent inactivation of Legionella in a 21 C tap water at a pH of
          7.6-8.0 when using  free  chlorine.  Using  first order  kinetics,  a
          99.9 percent inactivation requires a CT of 33.8.  Table A-5 presents
          the  CTs  needed   for   free   chlorine   to  achieve  a  99.9 percent
          inactivation of Giardia cysts at  20 C.   This table  indicates that
          the  CT  required  for  a  3 log  inactivation  of  Giardia  at  the
          temperature  and pH  of  the Legionella  test ranges  from 67  to  108
          depending on chlorine  residual.   This  is 2 to 3  times  higher than
          that which is needed to achieve a 3 log inactivation of Legionella.
                                      3-7

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hour  flow  rate through  that  pipeline.  Within mixing  basins  and storage
reservoirs,  the contact  time  must  be  determined  by  tracer studies  or an
equivalent  demonstration.  Guidance  for  conducting tracer studies is provided
in  Appendix C.  The  residual disinfectant  concentration is  measured  daily,
during  peak hourly  flow  for each disinfection  sequence  prior  to  the  first
customer  in the distribution system  at -or  immediately following the point at
which the contact time is determined.  Appendix D contains measurement methods
for the various disinfectant residuals.
     Meeting the CT Requirements
     The  SWTR  establishes  CTs  for chlorine,  chlorine  dioxide,  ozone and
chloramines which will  achieve  various inactivations  of Giardia  cysts and
enteric  viruses.   The  CTs established  are presented  in Appendix  E.   For a
system   to   determine  whether  it   is  meeting   the  CT  requirements,  the
disinfectant residual and temperature (and pH for systems using chlorine) must
be  measured daily at peak hourly flow  prior to  the first  customer,  and the
travel  time from  the point of disinfection  to  this  point must be determined.
The CTs actually  obtained for the system  each  day should be  compared to the
values  in the  table  for the pH and  temperature of the water,  to determine if
the CT required has been achieved.
     When using free chlorine as a  disinfectant,  the efficiency of inactiva-
tion is  influenced by the  temperature and pH of the  water.  The SWTR provides
the CT  requirements  for free  chlorine  at various temperatures  and pHs which
may occur in a source water.  These  values  are  presented in Table £-1 through
Table E-7 in  Appendix E.   The basis  for these  values  is  discussed in Appen-
dix F.
     As indicated in Table E-2, at a raw water  temperature of 5 C and a pH of
7.0, a chlorine concentration of 1.4 mg/L would require a CT of 175  to provide
a 3 log inactivation of Giardia cysts.   Therefore, to meet the CT requirement
under those conditions  would require a  contact time of  125 minutes prior to
the first customer.
     For the purpose  of the  SWTR, the pH  of the water is assumed to have an
insignificant  effect  on the disinfection  efficiency of chlorine dioxide and
the only parameter significantly affecting the CT requirements associated with
the use of  chlorine dioxide  is  temperature.   Out of  concern for toxicological
                                      3-8

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effects,  EPA's current  guideline is  that the  sun of residual,  measured as
chlorine dioxide, chlorate  and chlorite be less than 1.0 mg/1 at all consumer
taps.   It is  possible  that  this  guideline may  be  lowered as  more  health
effects  data becomes  available.  These concerns  further subtract  from the
feasibility of  using  chlorine dioxide as a residual for distribution systems.
As a  result  of this, systems  which  use chlorine dioxide  are not required to
measure the pH  of the disinfected water.  Table E-8 in Appendix E presents the
chlorine  dioxide  CT  values required  for  different temperature  ranges.   The
basis for these CT values is discussed  in Appendix F.
     As  indicated in  Tables E-8 and  E-9, the  CT requirements  for chlorine
dioxide  are  substantially  lower  than  those   required   for free  chlorine,
(chlorine  dioxide  is  a  more  effective  primary  disinfectant).   However,
chlorine dioxide  is  not as stable as  free  chlorine or chloramines in a water
system and may  not be capable of providing the disinfectant residual required
throughout the  distribution system.   Therefore,  the use  of  chlorine dioxide
may present the need of applying a residual disinfectant  such as chlorine or
chloramines  that  will  persist  in  the distribution  system  and  provide the
residual protection which is required by the SWTR.
     A third disinfectant which can  be used to inactivate Giardia and viruses
is ozone.  As with chlorine dioxide, it is assumed that ozone's performance is
not  significantly affected  by the  pH of  the  water,  and the SWTR  does not
require  the  measurement  of  the  finished water pH.    This assumption  is
considered reasonable given the basis for the  CT value and the applied safety
factor (see Appendix F).  Tables E-10 and E-ll present the CT  requirements for
ozone at different source water temperatures.
     The CT  for an ozonation  system should be calculated based  on  the ozone
residual  (mg/L) in the contactor effluent multiplied by the detention time of
the contactor.  The ozone residual is  measured  at  the  exit from the contactor
rather than at  the first customer because the ozone degrades quickly in water
                                      3-9

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and no  residual will remain at the first customer.      For systems which add
the ozone in  stages  throughout  the  contactor,  the exiting ozone concentration
and the contact time  are both divided  in half  prior to  calculating  the CT
provided.  This eliminates  giving credit for ozone which  is added just prior
to  the  sample  collection point.  The basis for  the CT values  presented for
ozone are presented in Appendix F.
     The short  life  of ozone  in a water  system presents the need for a system
utilizing ozone as  a  primary disinfectant to  apply a  residual disinfectant
such as chlorine or chloraraines in order to maintain a disinfectant residual
in  the  distribution system.  The residual disinfectant  is to be  added after
the primary   disinfectant.   However,  when  ozone  is in  contact with  either
chlorine or  chloramines,  reaction between  the two  may  result  in  the  mutual
destruction of  the  disinfectants.   In order to prevent  the two disinfectants
from mutually  destroying  each other,  the  residual  disinfectant should  be
applied after the ozone residual has fully dissipated.
     A  fourth disinfectant  which  can be used  for the inactivation of  micro-
organisms is  chloramine.   There are limitations  to its use  as a  primary
disinfectant.    Chloramines  are  less  effective  as primary  disinfectants  than
are free chlorine,  chlorine dioxide and ozone.   In  addition,  chloramines are
less effective  in  inactivating enteric  viruses  than they  are for  Giardia
cysts.    Therefore,   a  utility  which utilizes   chloramines  as the  primary
     3.   The residual  can be  measured using  the Indigo  Method which  is  a
          submitted standard method  (Bader & Hoigne,  1981).  This  method  is
          preferable to current standard methods because of the selectivity of
          the indigo-reagent in the  presence of  most interferences  found  in
          ozonated waters.  Indigo trisulfonate is  the  indicator used in this
          test method.   The  ozone  degrades an  acidic solution  of  indigo
          trisulfonate in  a 1:1  proportion.   The  decrease in  absorbance  is
          linear with increasing  ozone  concentrations  over a wide  range.
          Malonic  acid  can  be  added  to  block  interference from  chlorine.
          Interference  from  permanganese,  produced  by  the  ozonation  of
          manganese,  is  corrected  by  running  a  blank in which  ozone  is
          destroyed prior to addition of the indigo reagent.  The samples can
          be analyzed using  a  spectrophotometer at a 600 run wavelength which
          can detect residuals  as low  as 2 ug/L or a visual color comparison
          method which can measure down to 10 ug/L ozone.
                                     3-10

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disinfectant mist maintain  a CT sufficient to achieve a 4 log inactivation of
viruses, unless  the  system has no potential  sources  of human enteric viruses
within the  watershed.   However, the CTs required  for a 4 log inactivation of
viruses with chloramine  (see Table E-13)  indicate  that the use of chloramines
as a primary disinfectant is impractical for  systems with potential sources of
enteric viruses.  However,  lesser  CTs  may  be provided for a chloramine disin-
fection upon demonstration  of its  effectiveness as presented in Appendix G.
     The effectiveness of chloramine as a disinfectant is dependent on temper-
ature, as are  ozone  and chlorine  dioxide.   Table  E-12 in Appendix E presents
the CT requirements for chloramines to achieve a 3 log inactivation of Giardia
cysts.  The basis for these CT values are presented in Appendix F.
     The  CT values  presented  in  Tables  E-12 and  E-13  were obtained  from
laboratory  testing using preformed chloramines;  that is, ammonia and chlorine
were reacted to form chloramines  before  the addition  of the microorganisms.
Under field conditions,  chlorine  is usually added first  followed  by ammonia
addition further downstream.   Also, even after the  addition  of ammonia,  some
free chlorine  residual may persist for  a long period of time.   Therefore,
there is a time period prior to the formation of chloramines during which free
chlorine is present.  Since this free  chlorine contact time is not duplicated
in the  laboratory  when testing  preformed chloramines,  the slow inactivation
rates obtained by such tests may provide  conservative values  when compared to
those CTs actually obtained in the field.
     It is  anticipated  that many of the systems which do not provide filtra-
tion will have difficulty  in providing the contact  time necessary  to satisfy
the CT requirements  prior  to the  first customer.  For example,  as previously
indicated, a system using free chlorine at a water temperature of 5 C, a pH of
7.0 and a chlorine residual of 1.4 mg/L would require 125 minutes  of contact
time to meet the CT requirement.  Options which are available to these systems
include:
       -  Installation of  storage  facilities that will provide  the required
          contact time under maximum flow conditions.
       -  Use of an  alternate disinfectant such as  ozone or  chlorine dioxide
          which  requires  CT  values  lower  than  those  required  for  free
          chlorine.
                                     3-11

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     For  some  systems,  the  difficulty  in obtaining the required CT values may
 only be a seasonal problem.  A system that has raw water temperatures which
 reach  20  C during the summer months at a pH •= 7,0, may have sufficient  contact
 time  to meet  the CT of 62 at  a chlorine concentration  of 1 mg/L.  However,
 assuming  the same pH and chlorine  concentration,  it may not have sufficient
 contact time to meet the CT requirement at 5 C  (165) or at 0.5 C  (231).  Under
 those  conditions, it may be appropriate  for  such a system to utilize ozone or
 chlorine  dioxide on a seasonal basis, since they are stronger oxidants.
     As indicated in Table E-12, the CT values  for chloramines are high enough
 that  they may be unattainable for most systems.   Systems which currently
 utilize chloramines  as a  primary disinfectant may need to use  either free
 chlorine, chlorine dioxide or ozone  in order to obtain adequate disinfection.
 However,  systems  using chloramines  as  a primary  disinfectant may  chose to
 demonstrate  the  adequacy  of the disinfection.   Appendix G presents  a method
 for making this demonstration.
     3.2.2  CT Determination for Multiple Disinfectants and Multiple Sources
     For  systems  which   apply  disinfectant(s)   in  sequence,   the  total
 inactivation achieved is  the "sum"  of the inactivations between  each of the
 points  of disinfection.  The CT for each section is based  on the travel time
 through that section during peak hourly  flow  and the  residual disinfectant
 concentration, measured during  peak hourly flow, prior  to the  next  point of
 disinfectant application.   The pH and temperature of the water are measured on
 a daily basis  at  the location of the  residual  measurements, and  the CTs are
 calculated daily.  The  inactivation  achieved in each  section is based on the
 CT, the pH and temperature of the water for the respective sections, referring
 to  Tables E-l  through  £-13  in Appendix E.    These  tables  present  the  log
 inactivation of Giardia cysts and  enteric viruses achieved by  CTs at various
water  temperatures and  pHs.  The percent inactivations  corresponding to the
 log inactivations are as follows:
     0.5 log - 68 %
       1 log * 90%
     1.5 log « 96.8%
       2 log - 99%
     2.5 log = 99.7%
       3 log = 99.9%
       4 log = 99.99%
                                     3-12

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     This is determined from the following formula:
          y • 100 - 100                                 (1)
                    10X
     where:    y « % inactivation
               x * log inactivation
     for example:
          x « 2.5 log inactivation
          y - 100 - 100
                    io2'5
          y « 99.7 % inactivation
     Once the  percent inactivation  achieved in each section  has been deter-
mined,   the   overall   percent  inactivation   achieved  by   the  sequential
disinfectant  application  (either the same or  different disinfectants)  is
determined by the formula below:
          Gtn - Gtn-l + Gn
                                100
          where
          n     - number of points of disinfectant application
          G     • the percent inactivation achieved by the nth disinfectant
           n
          G     • the total percent inactivation achieved by the n disinfec-
           ta     tants
          G     » the total percent inactivation achieved by the n-1 disinfec-
           tn'1   tants
          G     « 0 to represent that there is no inactivation prior to the
                  first disinfectant
     The following  is  an example of the  determination of the overall percent
inactivation achieved by sequential disinfection.
     A community of approximately 6,000 people obtains its water supply from a
lake which  is  10 miles from  the city limits.   There are two  1/2 MG storage
tanks located  along the transmission line  to the city.  The water is disin-
fected with chlorine dioxide  at the exit from the lake  and  with chlorine at
                                     3-13

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the  exits  from the first and second  storage  tanks.   The average water demand
of  the community is 1 MGD with  a peak hourly  demand of approximately 2 MGD.
For  the  calculations of the overall percent inactivation, the supply system is
divided  into three sections as shown on Figure  3-1 s
     Section 1 - from the lake to the effluent  from the first storage tank,
     Section 2 - from the effluent from the first storage tank to the effluent
     from the second tank
     Section 3 -  from the effluent of the second  storage tank to the first
     customer
The  overall  inactivation  is   computed   daily  for  the  peak  hourly  flow
conditions.  On the day of this  example calculation, the peak hourly flow was
2 MGD.   The pH,  temperature  and disinfectant residual  of  the   water  were
measured at  the  end of  each  section  just  prior  to  the  next point  of
disinfection and the first customer during the hour of peak demand.  The water
travels  through  the 12-inch  transmission main at  237 ft/min at  2 MGD.   The
detention times of the storage tanks were determined to be 290 min and 285 min
as the result of tracer studies.
     The breakdown of the inactivation calculation is as follows:
                                   Section 1      Section 2      Section 3
     length (ft)                      15,840         26,400         10,560
     contact time (min)
       pipe
       tank
       total
     disinfectant
     residual (mg/L)
     temperature C
     PH
This information is then used in conjunction with the tables in Appendix E to
determine the CT  and the log  Giardia inactivation achieved.  Equation 1  was
then used to determine the percent inactivation.
67
290
357
chlorine
dioxide
0.1
5
8
111
285
396
chlorine

0.2
5
8
45
0
45
chlorine

0
5
8
                                     3-14

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                                             1st CUSTOMEF
"1 STORAGE STORAGE '
/ i
rTANK 1 * TANK 2 '
I
I
CHLORINE CHLORINE CHLORINE
DIOXIDE


SECTION

SECTION

SECTION
s -v






1 2 3
FIGURE 3-1
DETERMINATION OF INACTIVATIOM
  FOR MULTIPLE DISINFECTANT
   APPLICATION TO A SURFACE
        WATER SOURCE

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                                   Section 1      Section 2      Section 3
     CT                               36             79             18
     table                            A-8            A-2            A-2
     log inactivation                 2              1             
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 point of blending;  i.e.,  Sections A, B and  C on Figures 3-2 and  3-3.   It is
 recognized  that  this  is  a  conservative approach  for  determining  the  CT
 provided.  Systems which seek to obtain credit for both the CTs provided prior
 to and following blending must be addressed on a case-by-case basis.
      3.2.3  Demonstration of Maintaining a Residual
      Maintaining a Residual Entering the System
      It is required that a residual  of  at least 0.2 mg/L  is maintained in the
 water entering the distribution system at all times.  Continuous monitoring at
 a point prior to the entrance to the distribution system is required to ensure
 that the residual is provided.  The system must record the lowest disinfectant
 residual measured each  day of the  month  and this  residual must not be less
 than  0.2 mg/L.    Duplicate  residual  monitoring  devices  with  an  automatic
 switchover and alarm in case  of monitor failure should be  provided to  ensure
 that a continuous record of the residual is kept.
      Maintaining a Residual Within the System
      The SWTR requires that  a disinfectant residual  of  at least 0.2 mg/L  be
 maintained throughout the  distribution system,  with measurements taken at a
 minimum frequency equivalent to  that required by the proposed  total coliform
 rule as  in  Appendix H.   The  same  sampling locations  as required for  the
 proposed coliform  regulation  must  be  used   for measuring  the  disinfectant
 residual.
      The rule requires that  for any two  consecutive months the  disinfectant
 residuals must not be less  than 0.2 mg/L in more than 5 percent  of the samples
 for  each of the  months.  A system would not fail this requirement if it  could
 maintain disinfectant residuals of at least 0.2  mg/L in at least 95  percent  of
 the  samples in the second  month, even if  these residual  conditions were not
 met  in  the  first  month.   Disinfectant residual  can be measured as  total
 chlorine,  free  chlorine,  combined  chlorine  or  chlorine  dioxide.   The SWTR
 defines which analytical methods  may be used to make  these  measurements.  For
 example,  there  are several  test methods  which can  be  used to  test for the
 chlorine residual  in  the  water, including amperometric titration, DPD colori-
metric, DPD  ferrous titrimetric method and iodometric method.  The  procedures
                                     3-16

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                                          1st CUSTOMER
         FIGURE 3-2  INDIVIDUALLY DISINFECTED
                    SURFACE SOURCES COMBINED
                        AT A SINGLE POINT
k a 4- c
\ A II
U A ll
f 1
1
1
1
.^
D...— - i • r i
•b d e


j 1 st CUSTOMER
«^~\
DISINFECTANT    FIGURE 3-3 MULTIPLE COMBINATION POINTS
APPLICATION                 FQR INDIVIDUALLY DISINFECTED
COMBINATION POINT                 SURFACE SOURCES
SAMPLING POINTS

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for  these  test  methods  axe  contained  in  the  16th  edition  of  Standard

Methods.      Appendix D provides  a review  and summary  of all  disinfectant
residual measurement techniques which are available.
     Options which  are available to systems  to correct the problem  of being
unable  to  maintain a  disinfectant residual within their  distribution system
include:

       -  Routine  flushing  or cleaning  of the pipes  (either  mechanically by
          pigging or by the addition of chemicals to dissolve the deposits) of
          the distribution  system to  remove accumulated debris which may be
          exerting a disinfectant demand

       -  Flushing and disinfection of the portions of the distribution system
          in which a residual is not maintained

       -  Installation of satellite disinfection field facilities with booster
          chlorinators within the distribution system

     Additional information  is available  in  the  AWWA Manual  of  Water Supply
Practices and Water Chlorination Principles and Practices.
     3.2.4  Disinfection System Redundancy
     In addition  to the aforementioned  disinfection requirements, the water
supply  systems must also be evaluated for disinfection  system redundancy and
for  the   control   of  disinfection  practices.   A   system  which  provides
disinfection  as  the  only  treatment  for  the  water  is  required  to  provide
redundant system components to ensure that continuous disinfection is provided
at all times.  This can be accomplished by providing:
       -  Both a  primary and a  secondary disinfection  system in which all
          components have capacities equal to or greater than design values

       -  Two chemical  supply units of disinfectant which can be  used alter-
          nately  -  e.g.f  two  cylinders  of  chlorine  gas,   two  tanks  of
          hypochlorite solution

       -  Where generation  of  the disinfectant  is needed  (such  as  ozone),
          units capable  of  supplying  the  design  feed rate  should  be on-line
          Also, there  are  portable test kits  available  which can be  used in
          the  field to  detect  residual  upon the  approval  of the  Primacy
          Agency.   These  kits may employ  titration  or  colorimetric  test
          methods.  The colorimetric kits  employ  either  a visual detection of
          a residual through the use of a color wheel, or the detection of the
          residual through the use of a hand held spectrophotometer.
                                     3-17

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          with  a  backup  unit available for down time.  The backup unit  should
          have  a  capacity equal to or greater than that of the unit(s) it will
          replace„
       -  Automatic  switchover  equipment which will change  the  feed fro® one
          storage unit  to   the  other  before  the  first  empties  or becomes
          inoperable
       -  Duplicate feed systems with each system having full design  capacity
       -  An  alternate power  supply  such as  a standby  generator  with  the
          capability of  running all  the electrical  equipment at the  disinfec-
          tion  station.  The generator should be on-site  and functional with
          the capability of  automatic start-up on power failure
       -  An  automatic  shut down  to  prevent  the  undisinfected  water from
          entering the distribution system if there is a system failure
     Appendix I contains more specific  information  for the Primacy Agency for
determining compliance with  this requirement.

3.3  Other Criteria
     In  addition  to meeting source water  quality criteria  and disinfection
criteria,  nonfiltering systems  utilizing  surface  water  supplies must meet
other criteria.   Specifically:
       -  Maintain a watershed control program
       -  Conduct a yearly sanitary survey
       -  Determine that no waterborne disease outbreaks have occurred
       -  Comply  with the revised annual coliform MCL
       -  Comply  with disinfection by-product regulation
     Guidelines for meeting  these other criteria are presented in the follow-
ing sections.
     3.3.1  Watershed Control Program
     A watershed  control program is  a  surveillance  and monitoring program
which is  conducted  to protect the quality of a surface water source.   It is
desirable to  have an  aggressive and detailed  watershed  control  program to
effectively  limit  or eliminate  potential  contamination by  human enteric
viruses.   A watershed program may impact parameters such as turbidity, certain
organic compounds, enteric viruses,  and total and fecal coliforms and areas of
wildlife habitation.   However,  the  program is  expected  to have  little  or no
impact  on  parameters   such as  naturally  occurring  inorganic  chemicals,
                                     3-18

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naturally  occurring organic materials, and  pathogens transmitted by wildlife
with the exception  of preventing animal activity near the source water intake
prior to disinfection.
     It may  be difficult to quantify the effect  of a watershed program since
there  are  many  variables which influence water  quality that  are  beyond the
control or knowledge of  the water supplier.  As a result, the  benefit  of a
watershed  control program or specific  control measures  must in many cases be
based on accumulated  cause and effect data and on the general knowledge of the
impact of  control measures rather than  on actual  quantification.  According to
the SWTR,  a watershed control program should include as  a minimum:
     1.    A  description  of  the watershed   including  its  hydrology  and  land
           ownership
     2.    Identification  and control  of watershed characteristics and activi-
           ties in the watershed  which may have  an adverse effect on the water
           quality
     3.    A  program  to gain  ownership or  control  of  the  land within  the
           watershed,  for  the purpose  of controlling  activities which  will
           adversely affect the biological quality of the water
     Appendix  J  contains a  more detailed  guide  to a comprehensive  watershed
program.
     3.3.2  Sanitary  Survey
     The watershed  control program  and  the  on-site sanitary survey are inter-
related preventive  strategies.   The sanitary  survey is  actually  a program
which includes and  surpasses the requirements of a watershed program.  While
the watershed program is  mainly  concerned with  the water source, the sanitary
survey includes  some  additional  requirements for  source  water quality control
and is  also  concerned with  treatment,  distribution,  monitoring and emergency
contingencies.   As  defined  by  the  USEPA,   a  sanitary  survey  is an on-site
review of  the  water  source,  facilities, equipment, operation and maintenance
of a public  water system for the purpose  of evaluating the  adequacy of such
source, facilities,  equipment,  operation  and maintenance  for  producing and
distributing safe drinking water.
     According to the SWTR, a sanitary  survey is  required to be conducted on a
yearly basis by  the system or by a party approved by the Primacy Agency.  The
survey should be conducted by competent individuals such as sanitary and civil
                                     3-19

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engineers, sanitarians,  and technicians who have experience  and knowledge in
the operation, maintenance, and design of a water system, and who have a sound
understanding of  public  health principles and waterborne  diseases.  Guidance
for the contents of a sanitary survey are included in the following paragraphs
and Appendix K.
     At the onset of  determining whether or not a source  is  to be classified
as a  surface  water,  utilities are required to conduct  a detailed, comprehen-
sive  survey.    Appendix  K  presents  a   comprehensive  list  of  water  system
features that the person conducting  the survey should be  aware of and review
as appropriate.   This initial  investigation  establishes  the quality of  the
water source, its treatment and  delivery  to  the consumer.  Once  this deter-
mination is made,  a  less comprehensive  survey should be conducted  yearly to
ensure that quality of the water and  service is maintained.  The annual survey
should include as a minimum the following:
     A.    Source Evaluation
          1.    Review of  the  effectiveness of the  watershed control  program
               (Appendix  J)
          2.    Review the physical  condition  and  protection  of  the  source
               intake
          3.    Review of  maintenance program  to  insure  that  all  equipment
               (pumps, pipelines and  controls)  is appropriate and has received
               repair as  needed which insures high probability  for prevention
               of system  failure
     B.    Treatment Evaluation
          1.   Review of  improvements  and/or additions  made during the pre-
              vious  year to fulfill  inadequacies detected in earlier surveys
          2.   Review of  equipment for physical deterioration
          3.   Review of  operating procedures
          4.   Review of  data  records  to insure  that all required  tests  are
              being  conducted  and recorded and  disinfection is  effectively
              practiced
          5.   Review coliform data for  plant effluent
          6.   Identification  of  any improvements  which  are needed  in  the
              equipment,  system maintenance and  operation, or data collection
                                     3-20

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     C.   Distribution System Evaluation

          1.   Review of storage facilities for construction condition

          2.   Determination that  sufficient pressure has  been maintained in
               the system throughout the year

          3.   Verification that system equipment has received  regular mainte-
               nance

          4.   Review of  additions/improvements incorporated during  the year
               to correct inadequacies detected in the initial  inspection

          5.   Review of cross connection prevention program, including annual
               testing of backflow prevention devices

          6.   Review of routine flushing program for effectiveness

          7.   Evaluation  of  the corrosion  control  program  and impact  on
               distribution water quality

          8.   Review of  the periodic storage reservoir  flushing program for
               adequacy

     D.   Management/Operation Evaluation

          1.   Review the  operations to insure that  any  difficulties experi-
               enced during the year have been adequately addressed

          2.   Review  to decide  whether  a  reorganization  of  management  is
               needed

          3.   Determine whether the budget is adequate

          4.   Review of  staffing to insure adequate personnel are available
               and they are adequately trained and/or certified

          5.   Verify that a regular maintenance schedule is followed

          6.   Review the  systems  records to verify that  they  are adequately
               maintained

          7.   Review bacteriological  data from  the distribution  system for
               colifonn occurrence, repeat samples and action response

     3.3.3  No Disease Outbreaks

     Under the provisions  of the SWTR, a surface water system  which does not

filter must  not have  had an  identified waterborne  disease outbreak  in its

current configuration which  has been  determined  by the Primacy  Agency to be
                                     3-21

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attributable to a  treatment deficiency.  If an identified  waterborne disease
outbreak has occurred  in  the past and  the  outbreak has been attributed  to a
treatment  deficiency,  then  the  system must  install  filtration unless  the
system has upgraded its treatment system to remedy  the  situation which led to
the outbreak, and the Primacy Agency has determined that the system is satis-
fying this requirement.  The system may not be required to  install filtration
if the disease  outbreak  has been determined by  the Primacy Agency  to be the
result of a distribution  system problem rather  than a treatment deficiency.
     In  order  to determine  whether the  requirement  is being  met,  the  re-
sponsible  federal,  state  and  local health agencies  should be surveyed  to
obtain the current and historical information on waterborne disease outbreaks
which may have  occurred within a given  service  area.  Whether conducted by the
Primacy  Agency  or  submitted  by the water  purveyor  this  information should
include:
     A.   Source of the Information:
          1.    Name  of  agency
          2.    Name  and phone number of person  contacted
     B.   Outbreak Data
          1.    Date  of  inquiry
          2.    Date(s)  of  occurrence(s)
          3.    Known or suspected incidents  of waterborne disease outbreaks
          4.    Type  or  identity of illness
          5.    Number of cases
     C.    Status of Disease Reporting:
           -   Changes  in  regulations;   e.g., giardiasis was not  a  reportable
               disease  until  1985
     D.    If a Disease Outbreak has Occurred:
          1.   Was  the  reason  for the   outbreak  identified; e.g.,  inadequate
              disinfection
          2.   Did  the  outbreak occur   while  the  system was in its  current
              configuration
         3.   Was remedial action taken
         4.   Have there been  any further outbreaks since the remedial action
              was taken
                                    3-22

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     If a  review of  the available information  indicates that the  system or

network for disease  reporting is inadequate within  the  Primacy Agency's area

of responsibility, efforts  should be made to  encourage  the appropriate agen-

cies to upgrade the disease reporting capabilities within the area.
     3.3.4  Long-Term Coliform MCL

     Long-Tenn MCL

     Systems must comply with the long-term coliform MCL on an ongoing basis

in order to avoid filtration.  If the proposed long-term coliform MCL criteria

become promulgated, these requirements would be as follows:
     a.   The  three  test methods  which can be  used within  the distribution
          system are  the membrane  filter test  (MF),  the multiple tube fermen-
          tation test reported in  terms  of the most  probable number (MPN).^or
          the presence of colifonns using the presence-absence test  (P-A),
          The  procedures for  these  test  methods  are  contained in the 16th
          edition of Standard Methods.

     b.   Systems which  analyze  less than 60  samples/year for colifonns must
          maintain coliform-positive results in five percent or less of the 60
          most recent samples, calculated within seven days of the end of each
          month of sampling

     c.   Systems which  analyze  60 or  more samples/year  must maintain coli-
          form-positive  results  in five percent or  less  of  the  samples from
          the most recent  12 months of  sampling, calculated within 7 days of
          the end of each month

     d.   Systems which  have not collected 60 samples by the effective date of
          the  regulation,  must  maintain  fewer than  one coliform-positive
          sample  in   the most recent 39 or  fewer  samples or  two coliform-
          positive samples in the most recent 40-59  samples
     6.   The  P-A  is  a  modification of  the  MPN  method  in which  a single
          culture bottle  is innoculated with a  100 ml sample.  The test method
          is currently  listed as a tenative procedure?  however, past research
          has  indicated that the P-A method has  a  detection efficiency which
          surpasses  that of the MPN test and is  equivalent to that of the MF
          method  (Fujioka et al., 1986).   The  test procedure is  also more
          easily performed than  the aforementioned methods.

     7.   It should be  noted that systems  using  an unfiltered surface supply
          are   required   to  collect   a  minimum  of   5 samples/month  or
          60 samples/year.
                                      3-23

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     e.   Systems which have violated a, b or c remain in noncompliance until
          coliforms are not detected in 5 percent or  less  of the most recent
          20 or more samples
The  culture  medium of each positive sample must be analyzed for fecal coli-
forms and  five repeat samples must  be  collected within 24 hours at the same
sampling location or the next closest sampling point.  If any repeat sample is
total coliform positive  but fecal  colifonn negative, five  additional repeat
samples are to be taken within 24 hours of being notified of the  results.  The
system must repeat this process until either coliforms are not detected in one
set  of five  repeat samples  or  the system determines that the monthly coliform
MCL  has  been exceeded and  notifies  the Primacy  Agency.   The results  of the
repeat sample are to be included in the calculation of the MCL and can be used
to  satisfy the  minimum number  of  monthly colifonn  samples required.   The
frequency of monitoring to  meet  the  above  regulations is population based, as
indicated in Appendix H.
     All systems must  also  analyze one sample near the  first customer on all
days during  which the  turbidity in the source  water exceeds  1 KTU.   These
samples are to be included in the calculation of the percent positive samples.
     Although  a  Maximum  Contaminant  Level  Goal/Maximum  Contaminant  Level
(MCLG/MCL)  for Heterotrophic  Plate  Count  (HPC)  has  not  been  proposed,  the
proposed coliform  rule uses the  HPC to test  for interference  with coliform
analysis.  If  a coliform  sample produces  a turbid culture in the absence of
gas production, using the multiple-tube  fermentation  technique,  or produces a
turbid culture  in  the  absence  of an acid  reaction using the presence-absence
(P/A) test,  or  produces  confluent  growth or  a  colony number  that  is  too
numerous to  count  using the membrane filter technique,  the  system may either
accept the sample  as  coliform-positive  or  declare  the  sample  invalid  and
collect and analyze another water sample.  The second sample is to be analyzed
for both total  coliform and HPC.  The sample  is  considered coliform-positive
if the coliform test  is positive or the HPC count is greater than 500 colo-
nies/ml.
     3.3.5   Total Trihalomethane (TTHM)  Regulations
     As  indicated in the SWTR,  for the system  to  continue  to use disinfection
as the only  treatment  it  must  be in compliance with  the total trihalomethane
                                     3-24

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MCL regulation.   The current regulation  has established an  MCL for trihalo-
methanes  (THM)  of  100 ug/L  for  systems serving  a population  greater  than
10,000.  However,  it is  anticipated that this  level will be  reduced  in the
future and this should be considered when planning disinfectant application.
     It  is  recognized  that  one  alternative  for  utilities to  meet  the  CT
requirements of the  SWTR is to increase  the disinfectant dose.  However, for
many  sources,  this  will  result  in an  increased  production  of  THMs.   Any
increase which results  in THM  levels  greater  than the  0.1 mg/L  limit  is
unacceptable.  However,  considering that more stringent THM requirements are
expected in  the future,  it is recommended that disinfection application which
increases THMs to levels close to  0.1 mg/L should not be  implemented.  In such
cases, it  is recommended that an  alternate  disinfectant which produces fewer
THMs should  be used.  Alternate  disinfectant  applications which  may be  used
include the  use  of ozone  as  a  primary disinfectant  with chlorine or chlora-
mines as a secondary disinfectant, or the application of  chlorine dioxide as a
primary disinfectant with either chlorine or chloramines used  as a secondary
disinfectant.
     It is also  suggested that Primacy Agencies  request systems which change
their disinfection practices to provide evidence of the  impact of such changes
on the THM formation.  This may be simply a  requirement to conduct THM samples
throughout the distribution system after the change  in  disinfection has been
implemented, or it may be a more extensive testing program.
                                      3-25

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                     4.  DESIGN AND OPERATING CRITERIA FOR
                         FILTRATION AND DISINFECTION TECHNOLOGY
4.1  Introduction
     In  accordance with the  SWTR,  public water  systems  must include filtra-
tion,  or  an  approved  particulate removal  technology,  in  their  treatment
process  unless  they are able to satisfy certain conditions.  Those conditions
include  compliance  with  source  water  quality  criteria  and  site-specific
criteria, for which  guidance  is provided in Section 3 of  this manual.  Systems
not  able to satisfy these conditions  will be required to provide particulate
removal  and meet criteria pertaining to operation, design (as specified in the
definitions of technologies in the  SWTR and more  specifically as determined by
the Primacy Agency), and performance.
     This section provides guidance for those water systems which currently do
not have filtration  equipment and must add it.   Guidance is presented both as
minimum  requirements and/or  background information.   Guidance  on additional
alternatives for small  systems is discussed in Appendix L.
     The  scope  of this section includes  items  that must be  considered  by a
water  supply system to install  filtration, or  upgrade  existing filtration
processes.  Guidance is provided on the following topics:
       -  Filtration Technology:  Includes descriptions,  capabilities, design
          criteria  and  operating  requirements  for  each  technology,  and  a
          listing  of  major  factors   to  be  considered  in their  selection,
          including  raw water quality  considerations.
       -  Disinfection:  Includes a description of the most applicable disin-
          fection  technologies  used with  filtration systems,  and  a presenta-
          tion of  the  relative  effectiveness  of  the disinfection technologies
          with respect  to inactivation of bacteria, cysts and enteric viruses.
       -  Alternate  Technologies:   Includes a description of  some  currently
          available alternate filtration technologies.
       -  Other Alternatives:  Includes  a description of  some nontreatment
          alternatives   including  regionalization  and  use of  an  alternate
          source.
4.2  Selection of Appropriate Filtration Technology
     Filtration is generally provided  by passing  water through a bed of sand,
a layer  of  diatomaceous earth,  or  through a  combination of coarse anthracite
                                      4-1

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coal overlaying finer sand.   Filters  are classified and named in  a number of
ways.  For example, based on application rate, sand  filters  can  be classified

as either slow  or rapid;  yet these two  types  of filters differ in many more
characteristics than  just application  rates  they  differ  in their  removal

process, bed material, method of  cleaning,  and operation.   Based  on the type
of  bed material,  filters can  be  classified as sand,  diatomaceous  earth,

dual-media  (coal-sand),  or even  tri-media  in  which  a third  sand layer  is

added.
     4.2.1  General Descriptions
     Definitions of the currently  most  applicable technologies, as contained

in the SWTR are as follows:
     a.   Conventional Treatment:   A series of processes  including  coagu-
          lation,  flocculation,  sedimentation and filtration.

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

     c.   Slow Sand Filtration:   A designed process which involves passage  of
          raw water through a  bed of sand at low  velocity [generally less than
          0.4 meters/hour] resulting  in  particulate removal by physical  and
          biological mechanisms  and changes  in chemical parameters  by biologi-
          cal actions.

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

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

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

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     e.   Alternate Technologies:   The  available  alternate  filtration  tech-
          nologies include, but are not limited to:
            -  Package Plants{1)
            -  Cartridge Filters
     4.2.2  Capabilities
     Filtration processes  provide various  levels  of turbidity  and microbial
contaminant removal.  However,   when  properly designed  and operated and  when
treating  source  waters of  suitable quality,  the  above  filtration processes
(with the exception of cartridge  filters regarding virus removal)  are  capable
of achieving  at least  a 2 log  (99 percent)  removal of  Giardia cysts and  a
1 log  (90 percent) removal  of  enteric viruses without  disinfection (Logsdon,
1987b; USEPA, 1987; Roebeck, 1962).
     A summary of the removal capabilities of the various filtration processes
is presented  in  Table 4-1.   As  indicated,  conventional treatment  without
disinfection is capable  of achieving up to a 3 log removal  of  Giardia  cysts
and up to a 3 log removal of enteric viruses.   Direct  filtration  can  achieve
up to  a  3 log removal of Giardia cysts  and up to a 2  log removal  of  enteric
viruses.   Achieving  the maximum  removal efficiencies  of  those constituents
with  these  treatment  processes  requires  the  raw  water  to  be properly
coagulated  and  filtered.   Factors  which  can   adversely   impact  removal
efficiencies include:
       -  Raw water turbidities less than 1 NTU
       -  Cold water conditions
       -  Non-optimum coagulation
       -  No coagulation
       -  Improper filter operation including:
          Depending upon the  type of  treatment units  in place,  historical
          performance  and/or  pilot  plant  work,  these  plants   could  be
          categorized  as  one  of  the  technologies  in  a-d  above  at  the
          discretion of  the State.   Several studies  have already  indicated
          that some package plants effectively  remove  Giardia cysts.  If such
          plants provided adequate disinfection as  demonstrated by satisfying
          CT  values,  to  achieve  the  minimum  3 log removal/inactivation  of
          Giardia cysts  and 4 log removal/inactivation  of  viruses  by  the
          complete treatment train, use of this technology would satisfy the
          minimum treatment requirements.
                                      4-3

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            -  No filter to waste
            -  Intermittent operation
            -  Sudden rate changes
            -  Poor housekeeping
            -  Operating beyond breakthrough
     Studies of  slow  sand  filtration have shown that this technology  (without
 disinfection)  is capable of providing greater than a 3 log removal of Glardia
 cysts  and greater than  a 3 log removal of enteric viruses.  Factors which can
 adversely impact removal efficiencies include:
       -   Poor source water quality
       -   Cold water conditions
       -   Increases in filtration rates
       -   Decreases in bed depth
       -   Improper sand size
       -   Inadequate ripening
     Also,  as  indicated in Table 4-1, diatomaceous  earth (DE)  filtration can
 achieve greater than a  3 log removal of  Giardia cysts when sufficient precoat
 and  body  feed are used.   However,  turbidity and  total  coliform removals are
 strongly  influenced by the grade of DE employed.  Conversely, DE filtration is
 not  very  effective for  removing  enteric  viruses unless the surface properties
 of the diatomaceous earth  have been altered by pretreatment  of the body feed
 with alum or  a  suitable polymer.   In general, DE  filtration is  assumed to
 achieve   only  a  1 log  removal  of  enteric  viruses  unless  it  has  been
 demonstrated otherwise.  Factors which can affect the removal of Giardia cysts
 and  enteric viruses include:
       -   Precoat thickness
       -  Amount of body feed
       -   Grade of DE
       -   Improper conditioning of septum
     Package plants  can be used to  treat  water supplies  for  communities as
 well as for recreational areas,  state parks,  construction camps, ski resorts,
 remote military installations  and others  where potable water is not available
 from  a municipal  supply.   Operator requirements  vary significantly  with
 specific situations.   Under unfavorable raw water conditions they could demand
 full-time  attention.   Package  plants  are most widely used to treat surface
supplies  for   removal  of turbidity,  color  and coliform organisms prior to
disinfection.   They are available in various capacities up to 6 mgd.  Colorado
                                      4-4

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                                   TABLE 4-1
                REMOVAL CAPABILITIES OF FILTRATION PROCESSES
                                                             (1)
                                            Log Removals
Process

Conventional Treatment

Direct Filtration

Slow Sand Filtration

Diatomaceous Earth
  Filtration
Giardia(2)
 Cysts
 2-3

 2-3
 2-3
 2-3
      (5)
      (5)
Enteric
Viruses
1-3
1-2
1-3
1-2
                    (3)
     (3)
     (4)
     (2)
 Total(2)
Coliform

  >4

 1-3

 1-2


 1-3
Note:
     1.   Without disinfection
     2.   Logsdon, 1987b.
     3.   Roebeck et al 1962
     4.   Poynter and Slade, 1977
     5.   These technologies generally achieve greater than a  3  log removal.

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State  University conducted  a series  of tests  on one  package plant  over a
5-month  period  during the  winter  of  1985-86   (Horn  and Hendricks,  1986).
Existing installations in Colorado had proven effective for turbidity removal,
and  the  tests  at  the  university  were designed to  evaluate the  system's
effectiveness  in  removing  coliform  bacteria  and  Giardia  cysts  from  low
turbidity,  low temperature source waters.   The  test results showed  that the
filtration  system could remove  greater  than 99 percent of Giardia  cysts for
waters which had less  than 1 NTU turbidity and less than 5 C temperatures, as
long  as proper  chemical  treatment  was applied,  and  the  filter  rate  was
10 gpm/ft  or less.  In addition, an alternate water source having a turbidity
ranging  from  3.9 to 4.5  NTU was used  in 12  test runs with  coagulant doses
ranging  from  15  to  45 mg/L.  The effluent  turbidities from these  runs were
consistently less than 0.5 NTU.
     Surveys of existing facilities indicated that while package plants may be
capable of  achieving effective treatment, many  have  not consistently met the
MCL for turbidity, and in some cases,  coliforms were detected in the filtered
water  (Morand  et  al.,  1980;  Morand  and  Young,   1983).   The  performance
difficulties were related to the short  detention time  inherent in the design
of the treatment  units, the  lack of  skilled  operators with sufficient time to
devote to operating the treatment facilities and the wide-ranging variability
in quality of the raw water source.  Raw water turbidity was reported to often
exceeded 100 NTU at one  site.   Later,  improvement  in  operational techniques
and methods resulted  in  substantial  improvement in  effluent  quality.   After
adjustments were made, the  plant was capable  of producing a  filtered water
with turbidities less  than  1 NTU,  even when influent  turbidities  increased
from 17  to  100 NTU within a  2-hour  period as long  as  proper coagulation was
provided.
     One of the  major conclusions of  these surveys  was that  package water
treatment plants manned by competent operators can consistently remove turbid-
ity and  bacteria from  surface waters of  a  fairly uniform  quality.   Package
plants applied where raw water turbidities are variable require a high degree
of  operational   skill  and   nearly   constant   attention  by  the  operators.
Regardless of the quality of  the  raw water source, all package plants require
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 at  least  a  minimum  level  of maintenance  and  operational skill  and proper
 chemical  treatment if they are to produce satisfactory water quality.
     Cartridge  filters  using microporous  filter elements  (ceramic,  paper  or
 fiber)  with  pore  sizes  as  small  as 0.2 urn  may  be suitable  for producing
 potable water from raw water supplies containing moderate levels  of turbidity,
 algae and microbiological contaminants.
     The  advantage  to small  systems of these  cartridge  filters is that, with
 the  exception of disinfection,  no other chemicals  are  required.  The process
 is  one  of strictly physical  removal of small particles by straining as the
 water passes  through  the  porous  cartridge.   Other than occasional cleaning  or
 cartridge replacement,  operational  requirements  are not  complex  and  do not
 require  skilled personnel.   Such a system may  be  suitable  for  some small
 systems   where,  generally,  only  maintenance  personnel  are  available  for
 operating water supply  facilities.   However,  the  use  of  cartridge filters
 should be limited to  low turbidity source waters since  their  use on moderate
 or high turbidity waters will result in rapid headless buildup.
     Long (1983) analyzed the efficacy of a variety of cartridge filters using
 turbidity measurements, particle size analysis, and scanning  electron micro-
 scope analysis.  The  filters  were challenged  with  a solution  of microspheres
 averaging 5.7 urn in diameter (smaller than a Giardia cyst), at a concentration
 of 40,000 to  65,000 spheres per  mL.   Ten of  17 cartridge filters removed over
 99.9 percent of the microspheres.
     In  tests using  live infectious cysts from  a human  source,  cartridge
 filters were  found  to be highly efficient in  removing  Giardia cysts (Hibler,
 1986).   Each test  involved  challenging  a  filter  with  300,000  cysts.   The
 average removal  for five tests  was 99.86 percent,  with removal efficiencies
 ranging from 99.5 percent to 99.99 percent.
     The  application of cartridge filters to small water systems using either
 cleanable  ceramic  or disposable polypropylene  cartridges, appears  to be  a
 feasible method for removing  turbidity and most microbiological contaminants,
 although data are needed regarding the ability of cartridge filters to remove
viruses.   Since disinfection by  itself  could  achieve a  4 log  inactivation  of
viruses,   if the cartridge filter removes greater than  or equal  to 3  logs  of
Giardia,   then the filter  plus disinfection would achieve the  overall minimum
                                      4-6

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requirements.   However,  consideration  should  be given  to  the feasibility of
multiple  barriers of treatment  for each target organism,  i.e.,  some Giardia
and  virus removal  by each  barrier as  a protection  if one  of  the barriers
fails.  The efficiency and economics of the process must be closely evaluated
for  each  application.   Pretreatment in  the  form of  roughing filters (rapid
sand  or multi-media)  or  fine  mesh screens  may be  needed to  remove larger
suspended solids,  which  could result in  the  rapid buildup of headless across
the cartridges.   (USEPA, 1987)
     In   general,   conventional  treatment,   direct   filtration,  slow  sand
filtration and  diatomaceous earth  filtration  can be  designed  and operated to
achieve the  maximum  removal of  those water  quality parameters  of concern.
However, for the purpose of  selecting the appropriate  filtration and disinfec-
tion  technologies  and  for  determining  design  criteria,  these  filtration
processes should be assumed  to  achieve  a 2 log reduction in Giardia cysts and
a 1 log reduction  of  enteric viruses.   This conservative approach will assure
that  the  treatment   facility  has  adequate  capabilities   to  respond  to
non-optimum performance  due to   changes  in raw water quality,  plant upsets,
etc.  The balance  of the required removals  and/or  inactivation  of Giardia
cysts and enteric viruses must therefore be  achieved through the application
of appropriate  disinfection.  The  performance of  alternate technologies such
as cartridge  filters, and possibly package  plants,  depending upon  the unit
under consideration,  however, cannot be  stated with  certainty  at this time.
These performance uncertainties  necessitate the use of. pilot studies in order
to demonstrate their efficacy  for  a given water supply.
     4.2.3  Selection
     For any specific  site and situation, a number of factors will determine
which filtration technology  is most appropriate.  Among  these  are:
       -  Raw Hater Quality  Conditions
       -  Site Specific Factors
       -  Economic Constraints
     Raw Water Quality Conditions
     The number of treatment barriers provided should be commensurate with the
degree of contamination  in the  source  water.   The four  available technologies
vary in their  ability to meet the  performance criteria when  a  wide range of
                                      4-7

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raw water quality is considered.  While numerical  values of raw water quality
that can be  accommodated by  each  of the  four technologies will vary from site
to site, general guidance  can be  provided.  A table  for selecting filtration
processes, based on total coliform  count,  turbidity, and  color  is presented
here as Table 4-2.  It  is  not recommended that filtration  systems other than
those  listed in Table  4-2  be utilized when  the  general  raw water quality
conditions exceed the values listed, unless it has been demonstrated through
pilot testing that  the  technology can meet the performance criteria under the
raw water quality  conditions expected to  occur  at the  site.   The filtration
processes  listed   in  Table   4-1   are  capable  of  achieving  the  required
performance criteria when properly designed  and operated if they are treating
a source water of suitable quality.  One of the  causes of filtration failures
is  the use  of  inappropriate  technology   for  a given  raw  water  quality
(Logsdon,  1987b).
     However, these criteria are general  restrictions and not absolute limits.
Periodic occurrences  of raw  water  coliform,  turbidity or  color levels  in
excess of the values presented in Table 4-2 would not preclude the use  of a
particular filtration  technology.   For example, the following alternatives are
available  for responding to occasional raw water turbidity spikes:
       -  Direct Filtration
            -  Continuous monitoring and  coagulant dose adjustment
            -  More frequent backwash of  filters
            -  Use  of  presedimentation
            -  Use  of  a one hour contact  basin between the rapid mix basin and
               filters12'
       -  Slow Sand Filtration
            -  Use  of  a roughing filter
            -  Use  of  an infiltration gallery
       -  Diatomaceous Earth Filtration
            -  Use  of  a roughing filter
            -  Use  of  excess body  feed
          The contact basin  serves  as a silt  and sand trap and  can increase
          plant  reliability  by  adding  lead  time   to   smooth  out  sudden
          variations in raw  water turbidity.   (USEPA, 1987)  The additional
          contact time can also help to condition the  floe so  that it becomes
          more filterable.
                                      4-8

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                                                TABLE 4-2

                              GENERALIZED CAPABILITY OF FILTRATION SYSTEMS
                              TO ACCOMMODATE RAW WATER QUALITY CONDITIONS
                                                                   General  Restrictions
                                                  Total
                                                Conforms             Turbidity                      Color
Treatment                                        (f/100 ml)              (NTU)                        (CU)

Conventional with  predisinfectlon               (20,000               No restrictions               (75(2*

Conventional without  predi si nf ectlon             (5,000               No restrictions               (75

Direct filtration  with  flocculatlon                (500               (7-14                         (40

Direct filtration  without  flocculatlon             (500               (7-14                         (10

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

Diatomaceous earth filtration                       (50t3)             (5(3)                         (5(3)
Notes:

     1.   Depends on  algae  population,  alum or cationic polymer coagulation — (Cleasby et al.,  1984.)

     2.   USEPA, 1971.

     3.   Letter-man,  1986.

     *.   Bishop et al.,  1980.

     5.   Slezak and  Sims,  1984.

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     For  the above  alternatives,  it is  recommended  that  pilot  testing be
conducted to demonstrate the efficacy of the treatment  alternative.
     The characteristics  of each filtration technology are  a major factor in
the  selection process.   Characteristics  of significance  include performance
capabilities  (contaminant  removal  efficiencies),  design  and  construction
requirements, and  operation and maintenance requirements.  Details regarding
each of the  four filtration technologies are presented in the following sub-
section.
     Site specific factors
     As indicated  in the SWTR, the  selection of appropriate filtration tech-
nology must  include  consideration  of site  specific factors.   These factors
include:
       -  Available land area
       -  Location of treatment plant relative to the source
       -  Sophistication of the technology
     Although consideration  of all  possibilities is beyond  the  scope of this
manual, the  above  factors  must  be included in the evaluation to  select  a
filtration technology.

Economic Constraints
     The costs associated with a  filtration  technology  are recognized to have
a significant impact  on  selection and implementation.   Cost estimates for the
filtration technologies presented in this document can be found in the USEPA
document "Technologies  and Costs  for the Removal of  Microbial Contaminants
from  Potable  Hater  Supplies."   (USEPA,  1987)   A  summary  of  these  cost
estimates are presented in Table 4-3.

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

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     The design criteria for the various filtration technologies  found in the

1982 edition of  the  Recommended Standards for Water  Works (Ten  States Stan-

dards)  are the minimum design criteria that a majority of states are currently

following.     The design criteria contained in the Ten  States  Standards have

not been  duplicated  here.   Rather,  the reader is  referred to the  Ten States

Standards.  The following additions  and/or  changes  are recommended in order to

assure compliance with the performance criteria of  the SWTR.

     4.3.2 General
     The following recommendations should be applied to all filtration plants:

     A.   All filtration plants  should provide continuous turbidity monitoring
          of the effluent turbidity from each individual  filter.   This recomr
          mendation applies to all new and  existing water treatment plants.

     B.   All new  water treatment  plants   should  include the  capability  of
          filter to waste on each filter, and where possible,  existing filtra-
          tion plants should install a filter to waste capability.

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

          a.   Review  the  performance  (effluent  turbidity)   data  for  each
               filter and determine which  filter has  the poorest performance
               historically (highest effluent turbidity).
     3.    Based  upon  the  results  of a survey conducted for the American Water
          Works  Association Research Foundation  (AWWARF),  some 38 states use
          the  Ten  States  Standards  entirely  or in  modified  form  (AWWARF,
          1986).

     4.    Although  this is not part of the  requirements of the  SWTR, it  is
          recommended because of  the possibility that  not all  filters  in  a
          treatment plant will produce the same effluent turbidity.  This may
          be due to a variety of" conditions  that include bed upsets,  failure
          of media  support or underdrain systems, etc.  Although  the combined
          effluent from all the filters may meet  the turbidity  requirements  of
          the  SWTR,   the  turbidity   level   from an  individual   filter  may
          substantially exceed the limits.  This may result in the passage  of
          Giardia cysts,  or other  pathogens.

     5.    For  most high   rate  granular bed filters,  there is   a  period  of
          conditioning, or break-in,  immediately  following backwashing, during
          which  turbidity and particle removal  is at a minimum.  In some cases
          the addition of a suitable  polymer  to the backwash water or starting
          the  filter  at  a low  rate  and  gradually  increasing the  rate may
          reduce the  amount of time required  for  the break-in of a filter.


                                     4-10

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                                                                 TABLE 4-3
                                        SUMMARY OF TOTAL COSTS OF TREATMENT;   t/1.000 GALLONS
                                                                                             (1)
                                                                                       Site Category
                                                                                                     (2)
Treatment
Processes Design Flow
Average Ft on
Filtration13'
Conventional treatment package plants

1
0.026
0.013
944.5
(4)
2
0.068
0.045
277.*

3
0.166
0.133
195.1

*
0.50
0.40
113.6

5
2.50
1.30
72. 8
01 a
6
5.85
3.25
52.4
CO •»
7 8 9 10
11.59 22.86 39.68 109.9
6.75 11.50 20.00 55.5

en a ci e to fc 11 c
11
404
205


12
1,275
650


  backwashing filters
Direct filtration using pressure
  filters
Direct filtration using gravity
  filters preceded by flocculation
Direct filtration using gravity
  filters and contact basins
Diatomaceous earth filtration
Slow-sand filtration
Package ultrafiltration plants
                 322.7   137.2  79.1   48.8   39.2   45.8   36.9   28.2

                        150.2  90.5   58.4   46.8   50.5   39.8   28.6   23.6  2113

                        131.2  80.9   54.7   44.2   48.0   37.5   26.3   21.4  19.1

672.9    227.2   134.7   66.6  43.1   43.1   36.1   48.1   41.7   35.4
377.8
205.1    133.4    54.7  34.3   28.7   25.3
455.6    226.8   179.2   138.4
Notes:

     1.   Costs are in late 1986 dollars.

     2.   Category values, from top to bottom, are number, design flow (mgd),  and average  flow  (mgd).  Population ranges for each
          category arei
          1.   25 - 100       4.   1,001 - 3,300       7.  25,001 - 50,000     10.   100,001 - 500,000
          2.  101 - 500       5.   3,301 - 10,000      8.  50,001 - 75,000     11.   500,001 • 1,000,000
          3.  501 - 1,000     6.  10,001 - 25,000      9.  75,001 - 100,000    12.   M,000,000

     3.   Each process group  includes chemical addition and Individual liquid  and solids handling processes required for operation;
          excluded are raw water pumping, finished water pumping, and disinfection.
     4.    Indicates  that costs are not currently available.

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          b.   Following   backwashing  of   the   filter   with   the   poorest
               performance,  place that filter  into service  and  collect grab
               samples every minute for a period of at least 30 minutes.

          c.   Analyze the grab samples for turbidity and determine  how long
               the  filter  must be in operation before the effluent turbidity
               drops to less than or equal to 0.5 MTU.

          d.   The  filter  to waste period is then defined as the time it takes
               for  the filter  effluent  of  the  worst filter to reach a turbid-
               ity  of  less than or equal to 0.5 NTU  following filter startup
               at the  normal production flow rate.  If the raw water is less
               than 1.0 NTU then at least, 50 percent turbidity removal across
               the  filter  should be achieved before the filter is brought back
               on-line.

          e.   Since not all filters  may be capable of filtering to  waste at
               normal production  flow rates,  an alternative may  be to define
               the quantity of water which must be filtered to waste.

          f.   In addition,  the filter-to-waste period  should be determined
               during  each of  the seasonal  variations  in water  quality  to
               account for their impact on filter performance.

     0.   All  water   treatment  plants  should   increase  filtration  rates
          gradually when   placing  filters back into  service following  back
          washing and/or after the filter-to-waste valve is closed.

     4.3.3  Conventional Treatment
     Conventional treatment  is the most  widely used technology  for  removing

turbidity and microbial contaminants from surface water supplies.   Convention-
al treatment  includes  the pretreatment  steps  of  chemical coagulation,  rapid
mixing, flocculation and   sedimentation followed  by filtration.   The filters

can be  either sand, dual-media,  or multi-media.   Figure 4-1  is  a flow sheet

for a conventional treatment plant.

     Single media rapid sand filters  are  generally designed with a filtration

rate of 2 gpm/ft .  Newer  plants  which use dual- or tri-media filters have a

design  filtration  rate of 4  to  6 gpm/ft .   When properly  operated,  filter
     6.    Continuous  turbidity  monitoring  can  be used  in  place  of  grab
          sampling.
                                     4-11

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plants are generally capable of producing a  low turbidity filtered water that
approaches a value of 0,1 to 0.2 NTU.
     The extent and degree of pretreatment is determined by the quality of the
raw water supply and the type of filter used in the plant.  For example, a raw
water with high turbidity and high concentrations  of coliforms, requires more
pretreatment, prior to filtration than a raw water with low turbidity and low
coliform concentrations.  Site-specific raw water quality conditions influence
the design criteria for each component of a conventional treatment system.
     Design Criteria
     The minimum  design criteria  presented in  the Ten  State  Standards  for
conventional treatment are considered sufficient for the  purposes of the SWTR
except for the following additions:
     a.   A  primary  coagulant must  be  used at  all times  during  which  the
          treatment plant is in operation.
     b.   The criteria  for  sedimentation should be  expanded  to include other
          methods of solids removal  including plate separation, dissolved air
          floatation, and upflow-solids-contact clarifiers.
     Operating Requirements
     The  operation  of  conventional and  direct  filtration  plants is  more
demanding than  for DE or  slow sand filter  plants.  Conventional  and  direct
filtration plants must  be  monitored  carefully because  failure  to maintain
optimum coagulation can result in poor  filter performance and breakthrough of
                   (8)
cysts and viruses.     Although the detention  time provided  by the settling
basins results  in some  margin of safety,  the  loss  of  coagulation control at
the chemical feed and rapid mix  points may not  be noticed  until the  poorly
coagulated water  reaches the  filters and the process has failed.  Failure to
     7.   Dependable removal of Giardia cysts can not be guaranteed if a clear
          water  (raw  water  turbidity  less  than  1  MTU)  is  filtered without
          being properly coagulated (Logsdon, 1987b; Al-Ani et al., 1985).
     8.   As indicated in the preamble to the proposed SWTR, 33 percent of the
          reported cases  of giardiasis  in  waterborne disease  outbreaks were
          attributed to improperly operated filtration plants.
                                     4-12

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        •COAGULANTS
INFLUENT
I

RAPID MIX
i i»c-2 mm
DETENTION


FLOCCULATION
20-45 mm


SEDIMENTATION
1-4 noun

FILTRATION
RAPID SAND- 2 cpm/ll*
I DUAL AND TRl-MlXED
1 MEDIA- 4-6 CS«"H2
        FIGURE 4-1  FLOW SHEET OF A TYPICAL CONVENTIONAL
                           WATER TREATMENT PLANT

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effectively monitor and control filter operation can result in undetected poor

filter performance (Logsdon, 1987a; Logsdon, 1987b).

     Effective operation  of a conventional  treatment plant  requires  careful
monitoring and control of:

       -  Chemical Feed
       -  Rapid Mix
       -  Flocculation
       -  Sedimentation
       -  Filtration

     For the purposes of the SWTR, effective operation of a conventional water

treatment plant can be summarized as follows:

     a.   The  application  of a  primary  coagulant  and  the maintenance  of
          effective coagulation and flocculation at all times when a treatment
          plant is in operation.

     b.   Maintenance  of  effective  filtration.   Unless  terminal  headloss
          occurs  before  the  effluent  turbidity  exceeds 0.5 NTU,  the  filter
          effluent turbidity  should be used  to initiate:  1) the  start  of a
          filter run  at the end of a  filter-to-waste  cycle,  and 2) the start
          of a backwash cycle when filter effluent again rises to 0.5 MTU or a
          lower  set  point  value  which will  ensure that., the plant  finished
          water quality will meet performance criteria.
     4.3.4  Direct Filtration
     A direct filtration plant can include several different pretreatment unit
processes depending upon  the  application.   In  its simplest  form,  the  process
includes only in-line filters (oftentimes pressure units) preceded by chemical
coagulant application and  mixing.   The mixing requirement, particularly  in
pressure filters, can be satisfied by influent pipeline turbulence.  In larger
plants with gravity filters, an open rapid-mix basin with mechanical mixers is
typically used.  Figure 4-2 illustrates the unit processes of a typical direct
filtration plant.
     9.   Some conventional  water  treatment plants which  treat  low turbidity
          source waters  (<1 NTU)  reportedly  discontinue  the application  of
          coagulant(s) during  periods of  low turbidity  since the  raw water
          already meets the  turbidity MCL.  However, studies  have  shown that
          cyst removal  for  low turbidity waters  is the  most  difficult  to
          achieve and requires optimum pretreatment (including coagulation)  to
          achieve effective removals  (Al-Ani et al., 1985).

     10.   As an  exception  to this priority,  filters which were removed from
          service should always be backwashed upon start up.
                                     4-13

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     Another  variation of  the  direct  filtration  process consists  of  the
addition of a coagulant to the raw water followed by rapid mixing and floccu-
lation, as illustrated on Figure 4-3.  The  chemically conditioned and floccu-
lated water is then applied directly to a dual or mixed-media filter.  Floccu-
lation results in better performance of  certain  dual-media filter designs for
specific water supplies (USEPA, 1987).
     Figure 4-4 is  a flow sheet  of a direct  filtration process  utilizing a
1-hour contact basin between the rapid mix  basin and the filter.  The contact
basin should be designed  to  promote low intensity mixing of the destabilized
colloidal  material  and suspended solids  to  increase the  rate  of  particle
encounters  and  the  formation  of  aggregates  which  are  removed  through
filtration.  The  contact  basin  also  increases  plant  reliability by  adding
detention time to smooth-out sudden variations in raw water turbidity.
     Design Criteria
     The  1982  edition  of  Ten  State  Standards requires pilot  studies  to
determine  most  of  the  design  criteria.    The  requirement  is  considered
sufficient for the purposes of the SWTR with the  following exceptions:
     A.   Primary coagulant must be used at all times when the treatment plant
          is in operation.
     Operating Requirements
     Operating considerations  and requirements  for  direct  filtration  plants
are  essentially  identical to  those for conventional treatment plants.   The
major difference is that a direct  filtration plant will not have a clarifier,
and may or may not  have a flocculation or contact basin.   In  addition,  it is
recommended  that  all  direct filtration  plants, both new  and existing,  be
required to initiate a filter to waste  period following backwashing.
     11.  Optimum  coagulation  is   critical  for  effective   turbidity  and
          microbiological  removals  with  direct  filtration  (Al-Ani et  al.,
          1985).
     12.  As  with  conventional  treatment,   direct   filtration  produces  a
          relatively poor quality filtrate at the beginning of filter runs and
          therefore requires a filter-to-waste period (Cleasby et al., 1984).
                                     4-14

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INFLUENT
          -COAGULANTS
RAPID MIX
 s«c • 2 min
DETENTION
DUAL OR MIXED
 MEDIA FILTER
 4-5 gpm/ft2
           FIGURE 4-2  FLOW SHEET FOR A TYPICAL
                        DIRECT FILTRATION PLANT
         rCOAGULANTS
INFLUENT


1

RAPID MIX
c*c - 2 min
DETENTION


FLOCCULATION
15-30 mm


DUAL OR MIXED
MEDIA FILTER
4-6 gpm/tt2
        FIGURE 4-3  FLOW SHEET FOR A TYPICAL DIRECT
                   FILTRATION PLANT WITH FLOCCULATION

-------
INFLUENT
1
-COAGl
' -

JLANTS
RAPID MIX
I stc • 2 mm
DETENTION



1-HR
CONTACT BASIN


>
,

DUAL OR MIXED
MEDIA FILTER
4-5 com/tt2
POLYMER
                                             0.05-0.5 mg/l OR
                                             ACTIVATED SILICA
       FIGURE 4-4 FLOW SHEET FOR A TYPICAL DIRECT
              FILTRATION PLANT WITH A CONTACT BASIN

-------
     As with conventional treatment, the priorities  for  initiating the back-
washing of  a  filter should be  filter effluent turbidity values,  followed by
headless and run time.  Effluent  turbidity  monitoring equipment should be set
to initiate filter backwash at  an effluent  value  lower than 0.5 NTU, in order
to meet finished water quality requirements.
     4.3.5  Slow Sand Filtration
     Slow sand filters differ from single-media rapid-rate filters in a number
of important  characteristics.  In  addition to the  difference of  flow rate,
slow sand filters:
     A.   Function using  biological mechanisms  as well  as physical-chemical
          mechanisms
     B.   Use smaller sand particles
     C.   Are not backwashed, but rather are cleaned  by  removing the surface
          media
     D.   Have much longer run times between cleaning
     E.   Require a ripening period at the beginning of each run
     Although rapid  rate filtration is the  water treatment  technology used
most extensively in the United  States,  its  use  has often proved inappropriate
for small communities since rapid-rate filtration is a technology that requir-
es skilled operation by trained operators.  Slow sand filtration requires very
little control by  an operator.   Consequently,  use of this  technology may be
more appropriate for  small  systems where source  water quality is  within the
guidelines recommended in Section 4.2.3.
     As indicated in  this section,  slow sand filtration may be applicable to
other source water quality  conditions with the addition  of pretreatment such
as a roughing filter or presedimentation.
     Design Criteria
     The minimum design criteria presented in the Ten State Standards for slow
rate gravity filters  are considered  sufficient for the purposes of the SWTR
with the following exceptions:
                                     4-15

-------
     a.   Raw  water quality  limitations  should  be  changed  to reflect  the
          values given in table 4-2.
     b.   The effective sand  size  should be between 0.15mm  and 0.35nm rather
          than the current 0.30 mm to 0.45 mm.
     Operating Requirements
     Maintenance of a  slow sand filter requires two periodic  tasks:  removal
of the  top 2 to 3  cm  of sand  and replacement of the  sand (Bellamy  et al.,
1985).  The  top 2  to  3 cm of the surface of  the  sand bed  should  be removed
when the headloss exceeds 1 to 1.5 m.
     Slow-sand filters produce  poorer  quality filtrate at the  beginning of a
run  (right after scraping), and require a filter-to-waste (or ripening) period
of one  to two  days before being used  to supply the  system.  The ripening
period is an interval  of time immediately after a scraped filter is put back
on-line, when the turbidity or particle count results are significantly higher
than  the  corresponding  values for  the  operating  filter.   Filter  effluent
monitoring should be used  to  determine the  end of the ripening period.   For
example, a turbidimeter  could be  set  at an  NTU  of 1.0  or  less to initiate
start of the  filter run.
     When repeated  scrapings  of the sand have  reduced  the depth of  the sand
bed  to approximately  one  half of  its  design  depth,  the sand  should  be
replaced.   Filter bed depths of less than 0.3 to 0.5 m  (12 to  20 inches)  have
been shown to result in  poor  filter performance (Bellamy et al., 1985).   The
     13.  Without pretreatment,  limitations exist in the quality of water that
          is suitable  for  slow sand  filtration  (Logsdon,  1987b; Cleasby  et
          al.,  1984;  Bellamy et  al., 1985;  Fox et al.,  1983).
     14.  Significant  decreases  in  total  coliform removals  were  shown  at
          effective sand sizes  greater than  0.35 mm (Bellamy et  al.,  1985).
          As defined in  the AWWA Standard  for Filtering Material,  effective
          size  is the  size  opening  that will  pass  10  percent by weight  of a
          sample of filter material.
     15.  Removal of this top layer of the "Schmutzdecke" should  restore the
          filter to its operational  capacity and initial headloss.
                                     4-16

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replacement procedure should include removal of the remaining sand down to the
gravel support, the  addition  of the new sand to one  half of the design depth
and placement of the sand previously removed on top of the new sand.
     The amount of time  for the biological population to mature in a new sand
filter (also called curing) and to provide stable and full treatment was found
to vary.  The World Health Organization.(1980) reported that curing requires a
few weeks to a few months.  Fox et al., (1983) found that "about 30 days* were
required to  bring particle and bacterial effluents  down to a  stable level.
All researchers agree  that a  curing time for a new  filter is required before
the filter operates at its fullest potential  (Bellamy et al., 1985).

     4.3.6  Diatomaceous Earth Filtration
     Diatomaceous earth  (DE)  filtration,  also  known as  precoat or diatomite
filtration, is applicable to direct treatment of surface waters for removal of
relatively low levels of turbidity and microorganisms.
     Diatomite filters consist  of a layer  of DE about  3 mm (1/8 inch)  thick
supported on a septum or filter element.  The thin precoat layer of DE must be
supplemented by a continuous body feed of diatomite, which is used to maintain
the porosity  of the  filter cake.   If no body  feed is  added,  the particles
filtered out will build  up on the surface of the filter cake and cause rapid
increases in headless.  The problems inherent in maintaining a perfect film of
DE on  the  septum have restricted  the  use of diatomite  filters  for municipal
purposes, except  under certain favorable raw water  quality conditions,  i.e.,
low turbidity and good bacteriological quality.
     16.  This procedure results in clean sand being placed in the bottom half
          of  the filter  bed and  biologically  active  sand  in  the  top half
          reducing the amount of time required for the curing period.  It also
          provides  for a  complete exchange  of  sand  over  time,  alleviating
          potential problems  of excessive  silt  accumulation and  clogging of
          the filter bed (Bellamy et al., 1985).
                                     4-17

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

diatomaceous earth  filtration  are considered  sufficient  for the  purposes of

the SWTR with the following exceptions:
     A.   The  recommended  quantity  of precoat  is  1 kg/m   (0.2  pounds  per
          square  foot)  of  filter area,  and  the  minimum  thickness  of  the
          precoat filter cake is 3mm  to 5mm (1/8  to 1/5-inch).

     B.   It is recommended  that  treatment  plants be encouraged to  provide a
          coagulant coating [alum or  suitable polymerJ  of  the body feed.

     Operating Requirements
     Operating requirements specific  to DE filters include:

       -  Preparation of body feed and precoat

       -  Verification that dosages are proper

       -  Periodic backwashing and disposal of  spent filter cake

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

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

     4.3.7 Alternate Technologies
     The SWTR  indicates  that filtration technologies other  than those speci-
fied above,  may be used following demonstration through  the use of  on-site

pilot  studies  that  the alternate technology is at  least  as effective  as
conventional treatment.  Guidance for the  pilot studies  required  to demon-

strate this effectiveness is given in Appendix  M  of this manual.

     Alternate filtration technologies which are  currently available  include:
       -  Package Plants
       -  Cartridge Filters
     17.  Studies have shown that a precoat thickness of 1 kg/m  (0.2 Ibs/ft )
          was most  effective in Giardia cyst  removal  and  that the  precoat
          thickness was more important than  the grade  size in cyst  removal
          (DeWalle et al.,  1964;  Logsdon et al.f 1981; Bellamy et al.,  1984).

     18,  Although enhancement  of  the  DE  is  not  required  for  Giardia cyst
          removal, coagulant coating  of  the  body  feed  has been  found  to
          significantly improve  percent  removals  of viruses,  bacteria  and
          turbidity.   (Brown et  al., 1974;  Bellamy et al., 1984).
                                     4-18

-------
     Package  plants  are not  a  separate  technology in  principle  from the
preceding technologies.  They  are,  however, different enough in design crite-
ria, operation  and maintenance  requirements that they must  be handled as an
alternate technology.  The  exception to this  would be as  previously stated
under  4.2.I.e.   The  package  plant  is   designed   as  a  factory-assembled,
skid-mounted  unit  generally incorporating  a single, or at  the most, several
tanks.  A complete treatment process  typically consists  of chemical coagula-
tion, flocculation, settling and filtration.  Package plants generally can be
applied to flows ranging from  about 25,000 gpd to approximately 6 mgd (USEPA,
1987).
     The application  of cartridge  filters  using either cleanable ceramic or
disposable polypropylene cartridges to small water  systems may be a feasible
method for removing turbidity  and some microbiological contaminants, although
data are needed regarding the  ability of cartridge filters to remove viruses.
As  previously  indicated,   pilot  studies  are  required  to  demonstrate  the
efficacy of   this  technology  for  a  given supply.   If  the  technology  was
demonstrated to be effective through pilot  plant studies at one site, then the
technology could  be  considered  to  be  effective  at  another site  which  had
similar source water  quality conditions.  Pilot plant testing at the new site
might not be necessary.
     Design Criteria
     Upon completion  of  the pilot studies  and  assuming  successful demonstra-
tion of performance, design criteria should be established and approved by the
Primacy  Agency.    Eventually,  a  sufficiently  large  data base  will  become
available to apply the alternate technology on other water supplies of similar
quality.
     Operating Requirements
     Upon completion  of  the pilot studies  and  assuming  successful demonstra-
tion of performance, operating requirements should be established and approved
by the Primacy Agency.
     4.3.8   Other Alternatives
     Under  certain circumstances,  some  systems may have other  alternatives
available.   These alternatives include:
       - Regionalization
       - Alternate sources
                                     4-19

-------
     A feasible option, especially for  small  water systems which must provide
filtration, may be to join with other small or large systems to form a. region-
al water supply system.  Alternative water sources located within a reasonable
distance of  a community  which meet the  requirements of  the SWTR  and other
applicable drinking water regulations may be  developed to provide a satisfac-
tory solution to a community water quality  problem.   Alternative ground water
sources may  be  available  depending upon the  size and location  of the system
and the costs involved.

4.4  Disinfection
     4.4.1  General
     The SWTR requires that disinfection be included as part of the treatment
of water for potable use.  It has already been  recommended that the number of
treatment barriers be commensurate with  the degree of contamination  in the
source water in accordance with Table 4-2.   For example, as indicated in Table
4-2, when the total  coliforms  in the source water are greater than 5,000/100
ml, conventional treatment with predisinfection  is recommended.   However, the
selection of  appropriate  disinfection  requires more  detailed considerations
than those provided in Table 4-2. These considerations include:
       -  Source water quality and the overall removal/inactivation of Giardia
          cysts and enteric viruses
       -  Formation of TTHMs
       -  Need for  an oxidant for purposes  other  than disinfection,  e.g.,
          control of taste and odor,  iron and manganese, color, etc.
     4.4.2  Removal/inactivation Requirements
     The SWTR requires a  minimum 3 log removal/inactivation  of  Giardia cysts
and a  minimum 4 log  removal/inactivation  of  enteric viruses.   For  planning
purposes,  filtration  which  is  operated  to  meet the turbidity  performance
requirements presented in Section 5 should  be assumed to achieve  a minimum 2
log removal  of  Giardia cysts  and  a 1  log  removal of enteric viruses.   Well
operated conventional treatment, diatomaceous earth and slow sand filtration
plants can be expected to achieve a 2.5 to  3  log removal of Giardia cysts and
direct filtration  plants  can  be expected  to  achieve greater  than a  2 log
removal of Giardia cysts.  Nevertheless, it is  still recommended that systems
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provide sufficient disinfection  to achieve a minimum of 1 log inactivation of
Giardia  cysts as  a  margin of  safety.   Depending  upon  circumstances   (e.g.
source  water  less   than  100/100  ml  total  colifonns,  and  disinfection
by-products  or economic  harships are  problems),  systems  using conventional
treatment  slow  sand  filtration  or   diatomaceous  earth  (but  not  direct
filtration) may seek to reduce their disinfection requirements to a minimum of
0.5 log inactivation  if they  are achieving a good filtered water quality on a
source  water  that  contains  low  coliform  levels.   At  no  time should the
disinfection  requirements  be  reduced  to less than is  needed  to  achieve a
0.5 log  inactivation of  Giardia  cysts.   Systems  which  achieved  a  0.5 log
inactivation of Giardia cysts, using free  chlorine,  chlorine dioxide or ozone,
would also in  effect be achieving a 4  log inactivation of viruses.  This same
rule of  thumb could not  be applied to chloramines, which are less effective
for inactivating viruses  than they are  for Giardia cysts.
     Although  the SWTR  requires a minimum of  a 3 log removal/inactivation of
Giardia  cysts  and   a minimum  of  a  4 log  removal/inactivation of  enteric
viruses, greater removals/inactivations may be appropriate depending upon the
degree of  contamination  within  the source  water.   Based upon  the  geometric
mean  of the  raw water   total  coliform  levels,  it  is recommended that for
systems  which  filter,   sufficient   disinfection   be   provided  for   the
. ,,  .    (19)(20)
following:
     19.  These values  are presented here only  as general guidelines.  There
          is  currently little  evidence  which  correlates  the  occurrance  of
          colifonns  with  Giardia  or viruses   in  raw  water  supplies.   The
          assumption is that  source waters with deteriorating microbiological
          quality should  receive increased disinfection.   This assumption is
          consistent with the multiple  barrier  concept.   However,  for water
          supplies which contain significant levels of THM precursors in their
          source water,  strict  reliance on these  disinfection guidelines may
          result in  unacceptable increases  in  their THM  levels.  Therefore,
          utilities which have  difficulty meeting these  guidelines  would be
          encouraged to monitor their source water for Giardia and viruses and
          to adjust these values accordingly.
     20.  An explanation of the geometric mean is provided in the 16th edition
          of Standard Methods.
                                     4-21

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                 Raw water         Giardia eyst    Enteric virus
               Total coliforms     inactivation    inactivation
                 (#/100ml)             dog)
                     <100              1                 3
                     <500              1.5               3.5
                     <1000             2                 4
                     <5000             2.5               4.5
                     <10000            3                 5
     CT tables for each  of the disinfectants for the  various removals listed
in item C above are presented  in Appendix E.   These tables should be reviewed
in order  to determine the  minimum dosage and  contact time  required  for the
selected disinfectant  in preparation for  ascertaining the  chemical  feed and
storage requirements.
     4.4.3  Total Trihalomethane  (TTHM)  Regulations
     In addition  to complying with disinfection  requirements,  systems  must
conform to  the  TTHM regulation.   Currently,  this  regulation  includes  an MCL
for  TTHMs  of 0.1 mg/L for systems  which serve  greater  than 10,000 people.
More stringent regulations are expected to be issued in the near future by the
USEPA,  and  these would also  pertain  to systems  serving  less than  10,000
people.  Therefore,  the  selection of an appropriate disinfectant must include
consideration of current and possible future regulations.
     4.4.4  Oxidant  Needs
     In the treatment of  surface waters, an  oxidant/disinfectant is  often
needed  for  purposes  other  than disinfection.  For example,  preoxidants are
frequently used to help  control taste  and odors, iron and manganese removal,
and to control growth within the treatment plant.   Therefore, the selection of
an appropriate  disinfectant/oxidant must take  these  other  objectives  into
account.
     21.  When  the  disinfectants  chlorine,  chlorine  dioxide  and ozone  are
          used, meeting the CT requirements for  achieving the indicated level
          of Giardia cyst inactivation will easily satisfy the CT requirements
          for achieving the  indicated level of  enteric  viruses inactivation.
          For  these disinfectants,  only  a 0.5 log inactivation of  Giardia
          cysts is needed to achieve a 4 log inactivation of enteric viruses.
                                     4-22

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     Based upon  the above  considerations,  bench  scale studies and/or  pilot

studies are recommended  as  part of the  selection  process  for a disinfectant.

These studies should address, as a minimum:

     a.   Water  quality  objectives(removal   requirements,   taste  and   odor
          control, etc.)

     b.   Points of chemical application

     c.   Dosage requirements

     d.   Mixing requirements

     e.   Impacts  on  other  treatment  processes,   (e.g.,  use  of  alternate
          oxidant may  require the  use of a  filter aid to prevent turbidity
          breakthrough on the filters)

     f.   Impacts on compliance with current and future TTHM regulations

     g.   Ability of  selected disinfectant and  the method of  application to
          meet future regulations                                   -/
                                     4-23

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                5.  CRITERIA FOR DETERMINING IF FILTRATION AND
                    DISINFECTION ARE SATISFACTORILY PRACTICED
5.1  Introduction
     In addition to the design  and operating conditions outlined in Section 4
of this manual, the SWTR requires that new and existing filtration plants meet
specified  performance  criteria  in  order  to  assure  that  filtration  and
disinfection are satisfactorily practiced.  These criteria include:
     Design and Operating Criteria  (presented in Section 4)
     Disinfection Monitoring Requirements
     Turbidity Monitoring Requirements
     Turbidity Performance Criteria
     Disinfection Performance Criteria
     The overall objective of these criteria is to control the following water
quality constituents specified in the SWTR:
       -  Giardia
       -  Enteric viruses
       -  Turbidity
       -  HPC
       -  Legionella
     Filtration which  is  practiced  according  to  the  design  and  operating
criteria presented in Section 4 of this  manual  is very effective in achieving
a 2 to 3 log removal of Giardia cysts.   However,  filtration is  generally less
effective  (1  to 2 log  removals)  in  removing enteric  viruses.   Disinfection
with chlorine, chlorine dioxide,  or ozone provides effective inactivation of
enteric viruses, and  should be considered  the  primary  treatment  barrier for
virus removal.  Chloramines are not effective for inactivation of viruses.
     Based upon these considerations, the purposes of the performance criteria
in the SWTR are to assure high probabilities that:
     a.   Filtration plants are  well operated and  achieve maximum  removal
          efficiencies of the constituents listed above.
     b.   To assure  that  disinfection will  provide adequate inactivation of
          viruses,  HPC  and Legionella,  and  added protection against  Giardia
          cysts.
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5.2  Turbidity Monitoring Requirements
     Sampling Location
     The  SWTR  requires that  the  turbidity samples  be representative  of the
system's  filtered water.  The purposes of  the  proposed turbidity requirements
for systems utilizing filtration are:
     a.   To provide  an indication  of Giardia  cyst and  general particulate
          removal for  conventional treatment,  direct filtration  and general
          particulate removal for diatomaceous earth and slow sand filtration.
     b.   To provide an indication of possible interference with disinfection.
     The  sampling locations which  would  satisfy the requirements  of the SWTR
would include:
     a.   Combined filter effluent prior  to entry into a clearwell
     b.   Clearwell effluent
     c.   Plant effluent or immediately  prior  to entry into  the distribution
          system
     The  selection of one of these three sampling  locations for demonstrating
compliance with  the turbidity  performance criteria may  be left  up  to the
preferrence of the system or,  if appropriate,  specified by the Primacy Agency.
     Sampling Frequency
     The  SWTR  requires  that  the  turbidity of the  filtered  water must  be
determined:
     a.   At least once every four hours  that  the system is in operation, or
     b.   The Primacy Agency may reduce the sampling frequency to once per day
          for systems using slow sand filtration or filtration treatment other
          than conventional treatment, direct  filtration or diatomaceous earth
          filtration.
     A system may substitute  continuous  turbidity monitoring  for grab sample
monitoring if  it  validates  the  continuous  measurement  for  accuracy  on  a
regular  basis  using  a  protocol  approved by  the Primacy  Agency.   It  is
recommended that the calibration of continuous  turbidity monitors be verified
at least twice  per week according to  the  procedures established in Method 214A
of the 16th edition of Standard Methods.
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     Additional Monitoring
     As  indicated  in Section 4.3.2,  it  has been  recommended  that  systems
should  equip   each  filter  with  a  continuous   turbidity  monitor.   This
recommendation is not part of the requirements of the SWTR and is not required
for  establishing compliance.  Rather,  it  is recommended as  a tool  for the
systems to  use  to better monitor their treatment  efficiency and to provide a
method of detecting filter performance deterioration.
     There  are  two basic types  of filter  performance  deterioration that can
occur within the life of a filter:
       -  Those that result from nonroutine operating conditions such as media
          deterioration,  mud  ball  formation,  underdrain  failure,  surface
          cracking and cross-connections, and
       -  Those  where water  quality  deteriorates  under normal  operations,
          i.e.,  turbidity  increases  routinely  observed  at both  ends  of  a
          filter run.
     Routine  monitoring  of  filter  effluent  turbidity  and  observation  of
backwash sequences  under an appropriate  schedule  can  indicate  both forms of
filter performance deterioration.
     If continuous  monitoring  of each filter effluent  cannot be implemented,
then  it is recommended  that at least  the following be  conducted.   On  a
quarterly basis:
       -  Monitor each filter, either  by  grab samples or continuous monitors,
          through  the course  of  a  routine  cycle  of  operation, i.e.,  from
          restart to backwash, and
       -  Visually   inspect  each   filter   for   indications  of   physical
          deterioration of the filter.
     These  are  general suggestions.  The  Primacy  Agencies  are  encouraged to
work with the systems  to determine  the best overall monitoring program(s) for
their particular filtration plants in order to assess the status of the filter
units.

5.3  Turbidity Performance Criteria
     Conventional Treatment or Direct Filtration
     Based  upon  the requirements of the  SWTR,  the  minimum  turbidity perfor-
mance criteria  for  systems  using conventional  treatment or  direct filtration
are:
                                      5-3

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

       -  At the discretion  of the Primacy  Agency, filtered water turbidity
          levels  of  less  than  or  equal  to  1 NTU  in  95  percent  of  the
          measurements taken every month may be  permitted on  a  case-by-case
          basis if  the  system can demonstrate  by  on-site studies  that it is
          achieving effective removal  and/or inactivation of Giardia  lamblia
          cysts, or cyst-sized particles.  For this demonstration, systems are
          allowed to include disinfection in the determination  of the  overall
          performance by the system.

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

     If  conventional and  direct  filtration  treatment  plants  (i.e.,  with
coagulation)  are  operated  to  achieve  the  minimum  turbidity  performance

criteria, it  could be assumed that  they are well operated and  achieving at
least a 2 log removal of Giardia  cysts and a 1 log removal of viruses.      The
balance of the overall 3 and 4 log removal/inactivation requirements should be
achieved through disinfection.
     Although the minimum turbidity performance criterion  was set at 0.5 NTU,
treatment facilities using conventional treatment  or direct  filtration, whose
raw  water  supplies  have  turbidity   levels  of  1 NTU  or  less,  should  be
                                                                           (4)
encouraged to achieve filtered water  turbidity levels of less than 0.2  NTU.
     1.   Recommended  protocol  for   this   demonstration  is  presented   in
          Appendix N.

     2.   The literature indicates that  well operated conventional  treatment
          and direct filtration plants can achieve up to  a  3  log  reduction of
          Giardia cysts and enteric viruses.   (Al-Ani  et al.,  1985;  Logsdon,
          1987b,   Roebeck  et  al.,  1962)  Limiting  the credit to  2 log  for
          Giardia cysts and  1 log for enteric viruses provides  a margin  of
          safety  for those plants  which are  not providing optimum  treatment
          and is  consistent with the multiple barrier concept.

     3.   Some treatment  systems  may  wish  to  demonstrate  that  they  are
          achieving better removals by filtration  in  order  to reduce  their
          chemical disinfection requirements  to avoid a conflict with the TTHM
          regulation.

     4.   Research has  demonstrated  the difficulty in  obtaining  effective
          removals of Giardia  cysts  and  enteric viruses with low  turbidity
          source  waters  (Logsdon, 1987b; Al-Ani et al., 1985).
                                      5-4

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     Slow Sand Filtration
     For systems  using slow  sand filtration,  the turbidity performance  re-
quirements are:
       -  The filtered water turbidity must be  less  than  or equal to 1 NTU in
          95 percent of the measurements for each month.
       -  At the  discretion of the  Primacy  Agency,  a  higher  filter effluent
          turbidity may  be allowed  on  a  case-by-case basis,  if the  filter
          effluent, prior  to disinfection,  consistently  meets  the  long-term
          coliform MCL and the turbidity level never exceeds 5 NTU.
       -  Filtered water turbidity may not exceed 5 NTU at any time.
     Slow  sand  filtration plants,   with  appropriate  design  and  operating
conditions  and which  meet the minimum turbidity  performance  criteria  are
considered  to  be  well operated  and achieving  at least  a 2 log removal of
Giardia cysts  and 1 log removal  of enteric  viruses.      The balance  of  the
overall 3  and  4  log removal/inactivation  requirements should  be achieved by
disinfection.
     Diatomaceous Earth Filtration
     For systems  using diatomaceous  earth filtration, the  turbidity perfor-
mance criteria are:
     a.   The filtered water turbidity must be  less  than  or equal to 1 NTU in
          95 percent of the measurements for each month.
     b.   The turbidity level of representative samples of filtered water must
          at no time exceed 5 NTU.
     Diatomaceous  earth   systems,   with  appropriate   design  and  operating
conditions  and  which meet the minimum turbidity performance criterion are to
be considered well operated and achieving a minimum 2  log removal of Giardia
cysts  and  a  1 log removal  of enteric  viruses prior to  disinfection.   The
balance of  the overall 3/4 log removal/inactivation of  Giardia cysts and 4 log
inactivation of enteric viruses should be achieved by disinfection.
     5.   As indicated in Section 4, pilot studies have shown that with proper
          nurturing of  the  schmutzdecke, operation at a  maximum loading rate
          of 0.2 m/h will provide optimum removal of Giardia cysts and enteric
          viruses  (Logsdon, 1987b; Bellamy et al., 1985).
                                      5-5

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     Other Filtration Technologies
     As specified in the  SWTR,  the  turbidity performance criteria for  filtra-
tion technologies,  other  than the ones  presented above, are  the sane as for
conventional treatment and direct filtration.

So4  Disinfection Monitoring Requirements
     The SWTR requires that each  system  continuously monitor the disinfectant
residual of the water as  it enters  the distribution system.  Each system must
also  measure  and  record  the  lowest  disinfectant  residual  entering  the
distribution system each day and the disinfectant residual in the distribution
system  at  the  same  frequency  and  locations  for  which  total  coliform
measurements are  made  pursuant to  the  requirements in the  revised coliform
rule (proposed at the same time as the SWTR).
     In addition  to these monitoring  requirements, it  is  recommended  that
water supply systems seeking  to  include disinfection prior  to  filtration in
determination  of  CT  values  should  identify   the  type  of  disinfectant,
disinfectant dose, point of application,  and  sampling location being used for
residual measurement.  Continuous monitoring of the  disinfectant residual at
this  point  is   recommended.       An  evaluation   of   different  analytical
techniques for  measuring disinfectant residual is given in Appendix D.

5.5  Disinfection Performance  Criteria
     For systems which  provide filtration,  the disinfection  requirements of
the SWTR arei
     a.    The system must comply  with all  design and  operating requirements
          specified  by the state.
          In addition to the application of disinfectants prior  to entry into
          the  distribution  system,  many  water  treatment   plants  utilize
          chlorine,  chlorine  dioxide  or  ozone as predisinfectants/oxidants,
          and some facilities may have multiple application points within the
          treatment plant.   Depending  upon the  water  quality conditions at the
          point  of   application,   credit  for  CT  may  be   given  for  this
          disinfection step.  A description of these conditions  and guidance
          for giving partial  CT  credit are presented  in Section 5.5  of this
          manual.
                                      5-6

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     b.   The system must demonstrate, by continuous monitoring and recording,
          that  a disinfectant  residual  of at  least 0.2 mg/L  is continually
          maintained in the water delivered to the distribution system.
     c.   The   residual  disinfectant  concentrations  of  samples  from  the
          distribution  system  may  not  be less  than  0.2 mg/L  in more  than
          5 percent of the samples, each month, for two consecutive months.
     The SWTR requires that as  a minimum, the overall treatment must achieve a
3 log removal and/or inactivation of  Giardia cysts and a 4 log removal and/or
inactivation of enteric viruses.  However,  the treatment provided  should be
commensurate with  the  degree of  contamination in the  source water,  which in
some  cases  may  require  greater removals   and/or   inactivation  than  those
specified   as   minimum.    In  Section 4.4.1,  recommended   removals  and/or
inactivation of Giardia cysts  and enteric  viruses  following  filtration are
presented as a  function  of raw  water total coliform levels.  These guidelines
should be used to determine the appropriate disinfection performance criteria.
     As  indicated  in Section 4.4.1  and in  Section 5.3,  filtration  which is
operated  to achieve  the  minimum turbidity  performance  criteria should  be
assumed  to  achieve  a minimum  2 log  removal of  Giardia cysts  and  a  1 log
removal of enteric viruses, with  the  balance of the inactivation requirements
being accomplished through disinfection.
     The purpose of this section is to provide guidance to the Primacy Agency
in  determining the   appropriate  disinfection   performance   criteria.    To
accomplish this, the following information is presented:
       -  Definition and methods of calculating CT values
       -  Recommended CT values for  free  chlorine,   chlorine dioxide, ozone,
          and preformed chloramines for various inactivation rates for Giardia
          cysts and enteric viruses at different pH and temperature values.
     Definition and Methods of Calculating CT Values
     As presented in Section  3.2,  CT is defined as  the residual disinfectant
concentration in mg/L multiplied by the contact time in minutes.  In general,
the contact  time is defined  as the  time  for the water  to move  between the
point of disinfectant application  and the  first customer,  or prior to the
first customer  at  the  downstream  sampling  location  such  as  the  clearwell
effluent which  is  being used to define the  contact  time.   In  pipelines, the
contact time is calculated by dividing  the internal  volume of the pipeline by
                                      5-7

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the peak hourly flow rate through the pipeline each day.  Within mixing basins

and storage reservoirs, the contact time must be  determined by tracer studies
                               (7)
or an equivalent demonstration.
     The  disinfectant concentration  is  generally  defined as  the  residual

disinfectant  concentration  at  a point  near  the  first  customer  or at  the

downstream  location  used in  determining  the  contact  time.  For  filtration

systems  which practice  predisinfection,  and wish to  receive credit  toward

satisfying the overall removal and/or inactivation requirements, the following

recommendations are made:
       -  For predisinfection, if the water to which the disinfectant is being
          applied has a turbidity of less than 5 NTU, then disinfection credit
          for Giardia inactivation can be given for the detention time within
          the plant at maximum flow rate between the application point and the
          point at which the  residual  is measured,  as determined by  tracer
          studies or equivalent demonstration and prior to the application of
          other disinfectants.

       -  For predesinfection credit  for the  inactivation of viruses,  the
          water to which the  disinfectant  is  being applied must be  less than
          1 NTU.  Inactivation credit can then be given for the detention time
          within the plant at maximum flow rate between the application point
          and the point  at  which the residual  is measured, as determined by
          tracer  studies  or  equivalent  demonstration  and  prior  to  the
          application of other disinfectants.
       -  For disinfectants added  to other points  in the  treatment  process,
          e.g.,  post settling/prefiltration, the credit for the detention time
          will be based  on  the measured detention  time between the point of
          application and the  point of application of any  additional disinfec-
          tants.

     Because disinfectant residuals for both ozone and chlorine dioxide  may be
short-lived,  a  sampling location  for residual  measurement upstream of  the
filters may be required.
          Guidance for conducting tracer studies is provided in Appendix C.

          A lower turbidity level is suggested  for  obtaining credit for virus
          inactivation than  that which is  suggested  for achieving  Giardia
          inactivation credit because of the  relative size difference  of  the
          organisms.    Considering  that viruses  are  so  much  smaller  than
          Giardia cysts it is  more  likely  that the  turbidity may interfere
          with  the  inactivation of the  viruses,  resulting  in  the  lower
          turbidity level.
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     The most practical  approach for ozone may be  to measure the residual in
the water  as  it leaves the  contactor.   Consequently, all  credit for contact
tine  would  be  limited  to  the  contact  time  within  the  contactor.   For
multi-phase ozone contactors, in which  ozone  is  applied at sequential stages,
the CT  should be determined based upon one half of the measured residual and
one half of the  contact  time.  The CT is being limited  in this case, because
some  of  the  ozone  residual  which  is  measured  will  have  been  applied
immediately upstream of the point of measurement.
     For chlorine dioxide, sampling and residual analyses at various points in
the treatment process downstream of the point of  application may be necessary
to establish the point  at which no residual  is present.  Subsequent sampling
and residual analyses conducted upstream  of this point  can be  used to deter-
mine the CT credit by utilizing the demonstrated  detention  time between the
point of application  and the sampling  location.   Methods  for  calculating CT
are presented in Section 3.2.
     Recommended CT Values
     In general, systems  with  filtration  plants  should  provide  sufficient
disinfection  to  achieve  the  inactivation  rates  listed   in Section  4.4.1.
Compelling  reasons to  seek reduced  disinfection  requirements  for a  well
operated filtration plant, as noted in Footnote No. 6 in Section 5.4, include:
       -  Conflict with THM MCL or other disinfection by-product regulation
       -  Technical feasibility
       -  Affordability as discussed in Section 9
     If a  system has  demonstrated that it  is achieving greater  than a 3 log
removal of Giardia  cysts  and it has demonstrated the need for  reduced disin-
fection requirements,  the Primacy Agency may permit the disinfection to be
reduced to the  CT requirements  for 0.5 log inactivation of Giardia cysts.  A
0.5  log inactivation  of Giardia  cysts,   as   determined by  CT  values  using
chlorine,   ozone, or  chlorine  dioxide,  would be  able  to  achieve a  4 log
inactivation of viruses.   Factors to be considered for allowing such a minimum
level of disinfection include:
     a.    If the system  uses  conventional  treatment  and achieves  filtered
          water turbidities well below the minimum performance criteria
     b.    System uses slow sand filtration
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     c.   That  the  raw water  total  coliform concentration  is generally  less
          than  100/100 ml or  the fecal  coliform concentration  is generally
          less than 20/100 ml
At no time should the disinfection requirements be reduced below this level.
     The  CT values  for the various inactivation  levels for  free chlorine,
chlorine  dioxide, ozone and  preformed chloramines for  both  Giardia cysts and
for  enteric viruses at various pH  and temperature  values  are  presented in
Appendix E.   These  values  are  given to  permit a  more  accurate  method of
determining the required CT  value  for a well operated plant or for the use of
predisinfection.   In   addition,  these  values  permit   the   assessment  of
appropriate  CT  requirements  for  poor  source  water  quality conditions as
defined in Section 4.4.1.  The basis for  calculating the CT values, presented
here for the various disinfectants, appears in Appendix F.
     When  determining  the   appropriate  CT  value  for  a water  system,  the
applicable  values  for  both  Giardia  cyst   inactivation and  enteric  virus
inactivation should be determined and the higher value should be utilized.
     Free Chlorine
     As previously  indicated in Section  3.2, when using free chlorine  as  a
disinfectant, the efficiency of  inactivation is  influenced by the temperature
and pH of the water.  The inactivation of Giardia  cysts by free  chlorine at
various temperatures  and pHs  are  presented  in  Appendix E  Table E-l  through
Table E-6.  The  CT values  for  the  inactivation of  enteric viruses by  free
chlorine are presented in Table E-7.
     To determine whether a system  is meeting  these requirements, the  free
chlorine residual, pH  and temperature must be measured,  either just prior to
the first customer, or  at the  point  at which contact time is  to be measured.
The contact  time from  the  point  of application of  the disinfectant  to the
first customer should  be measured.  The CTs  actually achieved in  the  system
should then be compared to the values in  the table  for the pH and temperature
of the source water.
     Ozone
     CT values for the inactivation of Giardia cysts by ozone are presented in
Table E-10 for various  temperatures  and inactivation rates.   As  indicated in
this table, the CT requirements  for  ozone are substantially lower  than those
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required for  free  chlorine.   This  reflects the  fact that  ozone  is  a  more
powerful disinfectant.   CT requirements  for inactivation of enteric viruses
using ozone are presented in  Table  £-11.   As a result  of the short  life of
ozone,  the application  of  a persistent disinfectant  such  as  chlorine  or
chloramines is  needed to maintain the required disinfectant  residual  in the
distribution system.
     Chlorine Dioxide
     CT values  for  the  inactivation  of Giardia cysts  by chlorine dioxide are
presented  in  Table £-8  and  the CT  values  for the  inactivation of  enteric
viruses are presented in Table £-9.    The  disinfection efficiency of chlorine
dioxide is not significantly affected  by  the pH of the water.  Therefore, the
only  parameter affecting  the  CT requirements  associated  with the  use  of
chlorine dioxide is temperature.
     Preformed Chloramines
     CT values for  the inactivation  of Giardia cysts  by  preformed chloramines
are presented  in  Table  £-12.  The high CT values associated  with the  use of
preformed chloramines indicate the difficulties involved in attaining adequate
inactivation with  their  use  as  the  primary  disinfectant.   Rather,  chlorine,
ozone,  or  chlorine dioxide  should   be used  for  primary disinfection,  and
chloramines  for  residual  disinfection,  as  necessary.   Systems   may  use
coliphage MS   to indicate  virus inactivation  (see Appendix G)j however,  no
easy method to show Giardia cyst inactivation is available.

5.6  Other Considerations
     Monitoring  for  HPC is  not  required  under   the  SWTR.   However,  such
monitoring nay provide a good operational tool for:
       -  Measuring microbial breakthrough
       -  Evaluating process modifications
       -  Detecting loss of water main integrity
       -  Detecting bacterial regrowth  conditions  within  the  distribution
          system
       -  Determining interference with the coliform measurements (AWWA, 1987)
                                     5-11

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     Therefore, routine monitoring of HPC on the plant effluent and within the
distribution  system  is  recommended  whenever  the  analytical capability  is
available inhouse or nearby.  Systems which do not have this capability should
consider using a semiquantitative bacterial water sampler kit  (dip stick).
     As presented  in the preamble to the SWTR, the EPA believes that  it is
inappropriate  to include  HPC as  a  treatment performance  criterion in the
proposed  rule  since  small  systems would  not   have  in-house  analytical
capability to conduct the measurement, and they would need to send the samples
to a private  laboratory.   Unless the analysis is  conducted rapidly,  HPC may
multiply and the measurement may be misrepresentative.
     It is suggested that an HPC level <10  organisms /ml in the finished water
is easily maintained with proper disinfection  (Geldreich et al, 1987).  It is
also suggested that  levels  greater than 10  organisms/ml  in the distribution
system  indicate  a  microbial regrowth problem which  needs  to  be  resolved
(Geldreich et al, 1987).
     Legionella  is  another  organism which  is not included  as a  treatment
performance criterion.   Inactivation  information  on  Legionella is  limited.
The  available information  indicates  that  the filtration  and  disinfection
requirements  of  the  SWTR will  remove or  inactivate  substantial levels  of
Legionella which  might occur  in source  waters.    Since  these organisms are
similar in size to coliform organisms, removal by filtration should be similar
to  those   reported   for  total   coliforas.    In   addition,   the   available
disinfection information indicates that  the CT requirements  for  inactivation
of Legionella  are  lower  than those  required for the inactivation of Giardia
cysts.<9)
          These treatment requirements  do not guarantee  that  these organisms
          will not  be present  in numbers  sufficient  to colonize  hot water
          systems  within  homes  and  institutions  (Muraca  et  al.,  1986).
          Guidance for control  of Legionella  by institutions  is  provided in
          Appendix B.
                                     5-12

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                                 6.  REPORTING

6.1  Reporting Requirements for Public Water Systems Using
     Surface Water Sources Not Providing Filtration	
     6.1.1  Source Water Fecal Colifonn (FC)
     Introduction
     The source water  quality criteria and required sampling  frequencies  for
fecal coliforms  can be  found in  Section 3.1.1 of  this  manual.  The  source
water must  be analyzed  for either  fecal or  total coliforms.  This  section
outlines the format of the  report  on source water quality for fecal  coliforms
which must be sent  to  the Primacy Agency on a  monthly  basis.   The individual
sample  results  must be  retained  by the  utility  for  a  minimum  of  5 years.
Individual sample results  do not have  to be reported;  however, a summary of
the  results  as  outlined below  must  be  sent  to  the  Primacy Agency  within
10 days of the end of each month,  and  the summary will  then  be used  to deter-
mine whether  compliance  has been  met.  For the  purposes of  this section,  a
6-month period is either  a full six months or  the  equivalent  as explained in
Section 2.
     Monthly Report Format
     1.    Report the number of samples analyzed during the month.
     2.    Report the number of results which are less than or equal to 20 fec-
          al coliform/100 ml.
     3.    Report  the  cumulative  number  of  results since the  start of  the
          6-month compliance period.
     4.    Report  the  cumulative  number  of  months  for which  fecal  coliform
          concentrations  were  determined  since   the   start  of  the  6-month
          compliance period.
     5.    Report  the  cumulative  number  of results less  than or  equal  to
          20 fecal coliforms/100 ml, since the start of the 6-month compliance
          period.
     6.    Report the percentage of passing results, which is (line 5/line 3)  x
          100.
     7.    If the  system is  not  in  compliance  (see Section 7.2.2),  report  a
          source water violation  to the state, within  48  hours of the viola-
          tion.
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     Reporting Frequency
     The preceding results  should be  reported to  the Primacy Agency  on a
monthly basis within 10 days of the end of each month, with violations report-
ed within 48 hours of the occurrence.
     6.1.2  Source Water Total Coliforms (TC)
     Introduction
     The source  water quality  criteria for total coliforms can be  found in
Section 3d = l of  the this  manual along with  required  sampling frequencies.
The source water must be analyzed for either fecal  or  total coliforms.  This
section outlines the  format of the  report on  total coliforms  in  the source
water that must be sent to the Primacy Agency on a monthly basis.  The indivi-
dual sample results must be retained by the utility  for a  minimum of 5 years.
Individual sample  results  do not have  to  be reported;  however,  a  summary of
the results  as outlined below must be  sent  to  the  Primacy  Agency  within
10 days of the end of each month,  which will then be  used to determine whether
compliance has been met.
     Monthly Report Format
     1.   Report the number of samples analyzed during the month.
     2.   Report the number of results which are less than or equal to 100 to-
          tal coliforms/100 ml during the month.
     3.   Report the  cumulative number  of total  coliform results since  the
          start of the 6-month compliance period.
     4.   Report the  cumulative  number of  months for  which total  coliform
          concentrations  were  determined  since  the  start  of  the  6-month
          compliance period.
     5.   Report the  cumulative  number of  results  less  than  or equal  to
          100 total coliforms/100  ml  since  the  start  of  the 6-month compliance
          period.
     6.   Report the percentage of passing results,  which  is (line 5/line 3)
          x 100.
     7.   If the system  is not in compliance  (see  Section 3,1.1), report  a
          source water violation to the state within  48  hours.
                                      6-2

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     Reporting Frequency
     The preceding results should  be reported  to the Primacy  Agency within
10 days of the end of each month, with violations reported within 48 hours of
the occurrence.
     6.1.3  Source Water Turbidity
     Introduction
     The source water quality  criteria and the minimum sampling frequency for
turbidity can be found in Section 3.1.2 of this manual.  This section outlines
the  format  of the report, for  turbidity that  must be  sent to  the  Primacy
Agency on a monthly basis.  The individual sample results must be retained for
a minimum of 5 years.  However, only  a summary of the results must be sent to
the Primacy  Agency,  which will  then  determine whether or  not compliance has
been met.
     Monthly Report Format
     1.   Report  the maximum  instantaneous  turbidity level  for  the  system
          operation during the month.
     2.   Report the date and value of any measurement which exceeds 5 NTU.
     3.   Report the  dates and number of periods during which  the turbidity
          exceeds 5 NTU, as defined in 3.1.2 in the previous 12 months.
     4.   Report the dates  and cumulative number of  periods  during which the
          turbidity  exceeded  5 NTU  in  the  previous  120 months  beginning
          138 months after promulgation of the SWTR.
     5.   Report the  dates during which  the customers were  notified  to boil
          the water being consumed.
     6.   It  is   suggested that  weather  conditions  on  days  the  turbidity
          exceeds 5 NTU, i.e., hurricane, flood, etc. are also reported.
     Reporting Frequency
     1.   If an  instantaneous  turbidity  level  exceeds 5  NTU, report  this to
          the state immediately, and issue a boil water notice.
     2.   A summary of turbidity results, as described above, must be reported
          to the state within 10 days of the end of each month.
     6.1.4  Disinfection Conditions
     Introduction
     The disinfection criteria include requirements for providing a 99.9 per-
cent inactivation of Giardia cysts and a 99.99 percent inactivetion of enteric

                                      6-3

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viruses, as contained in Section 3.2.  This section  outlines the test results
which must  be sent  to  the Primacy  Agency to  be used  to  determine  whether

compliance has been met.  These  results  are to be sent to  the Primacy Agency
within 10 days of the end of each month the system is  in  operation and should

be retained by the utility for a minimum  of 5  years.

     Monthly Report Format
     1.    Report the date and duration of each  instance when the disinfectant
          residual in water supplied  to  the distribution system  is  less than
          0.2 mg/L.

     2.    Report the disinfectant(s)  used and  the sequence of application.

     3.    Report  the  daily disinfectant concentration  at  peak hourly  flow
          prior  to the  first  customer   and  just  prior to  any  points  of
          additional disinfectant application  before  the  first customer.

     4.    Systems using  chlorine must report  the daily pR of  the disinfected
          water at peak hourly flow  just prior  to the next  point of chlorine
          addition for all chlorination points prior  to the first customer.

     5.    Report the daily temperature of the  disinfected  water at peak hourly
          flow for each point of disinfectant application prior  to  the first
          customer.

     6.    Report the daily disinfectant  contact time  at  peak hourly  flow  in
          minutes for each disinfection sequence prior  to  the first customer.

     7.    Report the actual daily CT  value, using the above information,  for
          each  portion  of   the  distribution   system   between  points   of
          disinfection prior to the first customer.

     8.    Systems  with  only  one  disinfection  sequence,  report  the  daily
          determination  of  the  CT  value  for  the  corresponding  daily  pH
          (chlorine only)  and temperature measurements, which  is  necessary  to
          achieve  99.9 percent   inactivation  of Giardia  and  99.99  percent
          inactivation of enteric viruses,  as  determined in Section 3.2.

     9.    Report the date of  each  instance in  which the  actual CT value  is
          less than the required CT  value necessary  to  achieve  99.9  percent
          Giardia cyst and 99.99 percent  enteric virus  inactivation.

    10.    It is suggested that systems with multiple  disinfection  sequences,
          should report the overall percent inactivation of Giardia cysts (for
          ozone,  chlorine dioxide  and chlorine systems)  or enteric  viruses
          (for chloramine systems) as  calculated in Section 3.2.2.
                                      6-4

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    11.   Systems using multiple disinfection  should report days on which the
          3 log  inactivation  of  Giardia cysts  and  4 log  inactivation  of
          enteric viruses is not achieved.

    12.   Report  the  disinfectant  residual   concentration present  in  each
          sample from  the distribution system in which total  coliforms  were
          detected.

    13.   Report the analytical method used to determine the residual.

    14.   Report the total number of samples analyzed for disinfectant residu-
          al.

    15.   Report the total  number  of samples  in  which less than 0.2  mg/L of
          disinfectant residual was detected.

    16.   Report the percent  of  disinfectant residual measurements in  the
          distribution system  which are less  than  0.2 mg/L (line 15/line 14)
          x 100.

     Reporting Frequency

     1.   The CT values  and supporting data  must be  reported  monthly within
          10 days of the end of each month.

     2.   The  results  of the  disinfectant  residual  determinations  in  the
          distribution system  must be reported within 10  days of the  end of
          each month.

     3.   Report to the state  within  48 hours  of  the occurrence each instance
          when  a  residual  is not  present  in  the  water supplied  to  the
          distribution system.

     6.1.5  Watershed Control Program

     Introduction
     According to the SWTR, a  yearly report of the  watershed  control program

conducted in  accordance  with the  program presented in Section 3.3.1  must be

submitted to the Primacy Agency.  The report is to be submitted to the Primacy

Agency within  10 days  of the  end  of each  federal  fiscal  year.  The Primacy

Agency will review the report  to determine whether  or not  compliance has been

met.  This section outlines the report content.

     Report Format

     The report should:

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

     2.   Identify activities or situations of actual and potential concern in
          the watershed(s).
                                      6-5

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     3.   Describe how the utility is proceeding to address them.
     Report Frequency
     The  report must be  submitted to  the Primacy Agency on  a  yearly basis
within 10 days of the end of each fiscal year.
     6.1.6  Sanitary Survey
     Introduction
     Guidelines for a general  sanitary  survey are contained in Section 3.3.2,
and  a  comprehensive sanitary  survey is  presented in Appendix H.   The  SWTR
requires each system to provide  the State with an annual report of the yearly
sanitary survey,  unless  the sanitary survey  is conducted by  the  State.   The
report is  to be  submitted within 10 days  of  the  end of the federal fiscal
year.
     Report Format
     It is suggested that:
     1.   A  report  of  the comprehensive survey  containing the  findings,
          suggested improvements and  dates by  which  to complete improvements
          is to be prepared following the initial system review.
     2.   To lessen the  burden on utilities,  a report containing  results  of
          the general survey can be submitted in subsequent years.
     Reporting Frequency
     The report  is to be  submitted  to the Primacy Agency on  a  yearly basis
within 10 days of the end of each fiscal  year,  unless the survey is conducted
by the Primacy Agency.
     6.1.7  Disease Outbreaks
     Introduction
     The  definition  of  a  waterborne   disease  outbreak  is  contained  in
part 141.2 of  the SWTR.   The  records  of an  outbreak are  to be  maintained
permanently.
     Report Format
     It is suggested that the report of the outbreak contain:
     1.   Date of occurrence
     2.   Type of illness
     3.   Number of cases
     4.   System   conditions   at  the   time   of   the   outbreak,   including
          disinfectant    residuals,    pH,    temperature,   turbidity,    and
          bacteriologicol results.
                                      6-6

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     Report Frequency
     Any disease outbreaks  in the serviced community which  are  linked to the
drinking water oust  be reported by  the  water supplier to the Primacy Agency
within 48 hours.   It is suggested that the public is notified within this tine
frame as well.
     6.1.8  Total Trihalomethane (TTHM) Regulations
     Reporting requirements of the TTHM regulation are to be followed.
     6.1.9  Long-Term Total Coliform MCL
     Reporting requirements  of  the  long-term  total  coliform  MCL  must  be
followed.
6.2  Reporting Requirements for Public
     Hater Systems Using Surface Hater
     Sources that Provide Filtration
     6.2.1  Treated Hater Turbidity
     A.   Systems Using  Conventional Treatment,  Direct Filtration, or  tech-
          nologies other than Slow Sand and Diatomaceous Earth Filtration
     Introduction
     The  effluent  turbidity  criteria and  required sampling  frequencies  for
these technologies  is  contained in Section 5.3 of  this  manual.   This  section
outlines the SHTR required  contents of the report which is  to be sent to the
Primacy Agency within  10 days of the  end of each month.  The Primacy Agency
will then determine whether compliance  has  been met.   These  results are to be
kept on record by the utility for a minimum of five years.
     Report Format
     1.   Report  the  total  number  of  filter  plant  effluent  instantaneous
          turbidity measurements made during the month.
     2.   Report the number of  filtered water  turbidity measurements that are
          less than or  equal  to  0.5 NTU  (or higher  value  up  to 1 NTU as
          approved by  the Primacy Agency following satisfactory demonstration
          of effective treatment by the system).
     3.   Report the percentage of  filter  water turbidity  measurements that
          are less than or equal to 0.5 NTU [(line 2/line 1)  x 100].
     4.   Report the date and value of any turbidity measurements which exceed
          5 NTU.
                                      6-7

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     Reporting Frequency
     The preceding results should be reported  to the Primacy Agency within 10
days of  the  end of the monthly  compliance period.  Any  violations are to be
reported to the Primacy Agency within 48 hours.
     B.   Systems Using Slow Sand Filtration
     Introduction
     The  effluent  turbidity criteria  and required sampling  frequencies  for
these technologies are contained in Section  5.3  of this manual.  This section
outlines the SWTR required contents of the report which  is  to be sent to the
Primacy Agency  within  10  days  of the  end  of each month.  The Primacy Agency
will then determine whether compliance has been  met.  These results are to be
kept on record by the utility for a minimum of five years.
     Monthly Report Format
     1.   Report the   total  number  of  filter  plant  effluent  instantaneous
          turbidity measurements made during the month.
     2.   Report the number of filtered  water  turbidity measurements that are
          less than or equal to 1 NTU,  and the dates of these occurrences.
     3.   Report the percentage  of filter water turbidity  measurements  that
          are less  than or equal to 1  NTU [(line 2/line 1) x 100].
     4.   Systems which  have  less than 95 percent  of  the  filter  effluent
          turbidity levels less than or equal to 1 NTU must report:
          a.    Dates and  results of  total  coliform sampling of  the  filter
               effluent prior to disinfection.  These are to  be  collected at
               the  game frequencies specified in Appendix H.
     5.   Report the date  and value of any turbidity measurements which exceed
          5 NTU.
     Reporting Frequency
     The preceding  results should be reported to the Primacy Agency each month
within 10 days  of the  end of the monthly compliance period.   However,  if  the
filter plant effluent instantaneous turbidity level exceeds 5 NTU at any time,
report the violation to the Primacy Agency within 48 hours.
     C.   Systems Using Diatomaceous Earth Filtration
     Introduction
     The  effluent  turbidity criteria  and required sampling  frequencies  for
this technology is contained  in Section 5.3  of  this  manual.   This  section
                                      6-8

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outlines the contents of the  report  which is to be sent to the Primacy Agency
within 10 days of the end of  each month.   The Primacy Agency will then deter-
mine whether compliance has been met.   These results are to be kept on record
by the utility for a minimum of five years.
     Monthly Reporting Format
     1.   Report  the  total   number  of  filter  plant  effluent  turbidity
          measurements made during the month.
     2.   Report the  number of filter  plant effluent  turbidity measurements
          that are less than or equal to 1 NTU.
     3.   Report   the  percentage   of   filter   plant  effluent   turbidity
          measurements less than 1 MTU which is (line 2/line 1) x 100.
     4.   Report the  date  and value  of  any turbidity  level  which  exceeds
          5 NTU.
     Reporting Frequency
     The preceding results should be reported to the Primacy Agency each month
within 10 days of the end of  the monthly  compliance  period.   Any filter plant
effluent  turbidity  level(s)  which  exceed 5 NTU  should be  reported to  the
Primacy Agency within 48 hours.
     6.2.2  Disinfectant Conditions
     Introduction
     Distribution water quality  criteria  and sampling  frequency can be found
in Section 3.2.3 of  this  manual.  This section outlines the  contents  of  the
report which  is to be sent to the  Primacy  Agency.   These  results  should be
reported  to  the Primacy  Agency  within  10  days  of  the end  of each  month.
Individual results are to be retained for a minimum of one year.  This section
also  recommends data to  be  reported  to  document the  actual CTs  which  are
maintained.  Section 5.5 presents- guidelines for CTs for filtering systems.
     Report Format
     1.   Report the  value of  the  lowest  daily measurement  of disinfectant
          concentration in mg/L  in water  supplied to  the  distribution system
          prior to the first customer.
     2.   Report the date  of  each instance when the  disinfectant residual in
          water  supplied  to  the  distribution system prior  to  the  first
          customer is less than 0.2 mg/L.
                                      6-9

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     3.   Report  the  total  number  of  samples  and  values  of disinfectant
          residual for each sample measured in the distribution  system.

     4.   Report  the  number  of  disinfectant  residual  measurements  in the
          distribution system which are greater than or equal to 0,2 mg/L.

     5.   Report  the percent of  disinfectant  residuals  in  the distribution
          system which are greater than or equal to 0.2 mg/L  (line 4/line 3).

     Recommended Reporting Not Required by the SWTR

     1.   Report the average raw water turbidity.

     2.   Report the average raw water total or fecal coliform levels.

     3.   Report  the  percent  inactivation  of  Giardia  cysts  and  enteric
          viruses, required by the Primacy Agency.

     4.   Report the primary disinfectant used.

     5.   Report  the daily pH  (for  systems  using chlorine)  and temperature
          measurements  for the  disinfected  water  following each  point  of
          disinfection.

     6.   Report dosage and point of application for all disinfectants used.

     7.   Report  sampling  location(s), disinfectant  residual(s) and contact
          time used for determining the CT achieved.

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

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

    10.   Report the percent  inactivation determined prior  to  filtration and
          the data used to make this  determination.

    11.   Report any difference between the measured CT(s) and the CT required
          to  meet   the  overall  minimum  treatment   peformance  requirement
          specified by the Primacy Agency.

     Reporting Frequency

     The preceding  results should be  reported to  the Primacy  Agency within

10 days of  the end  of each  month.   Report each  instance when a  measurable

residual is not maintained at the first customer  to the Primacy Agency within
48 hours of the occurrence.
                                     6-10

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                                 7.   COMPLIANCE

7.1  Introduction
     The SWTR requires the  Primacy  Agency to make a determination on a monthly
basis  that each system  is  in compliance with the  SWTR based on  information
received from the  system.   The purpose of this section  is  to provide guidance
to the Primacy Agency in making  this determination.
     If a  Primacy Agency fails  to  comply with the  schedule for adopting  the
criteria and applying  them to  determine who must filter,  systems would  be
required to comply with the  "objective"  or self-implementing criteria,  i.e.,
the requirements that are clear  on  the  face  of the rule  and do not require  the
judgment of the  Primacy Agency, within 30 months of the promulgation  of this
rule or  install  filtration within  48 months.  As soon  as  the Primacy Agency
adopts the criteria, the  system would have to  comply  with all the  require-
ments.
     The proposed rule  has self-implementing requirements  which  pertain  to
both  unfiltered  and  filtered  water  systems.    These  are  listed  in  para-
graph 141.76(a)(1)(2)(4)(5)(6)   and  141.76(b) (1)(2)(4)(5)(6),   respectively?
they  would  go  into  effect for each  public water system  within  48 months
following the promulgation  of  this  rule (unless the  Primacy Agency has imposed
more stringent requirements).  The  subjective criteria  (such as those pertain-
ing  to watershed  control  and  design  and  operating  conditions),  listed  in
141.76(a)(3) and  (b)(3),  would go  into effect following the establishment  of
these  criteria  by the  Primacy Agency.   Systems  which  are not  in  compliance
with the objective criteria for  avoiding filtration 30 months after promulga-
tion would be  required to  install  filtration and meet the objective  perfor-
mance criteria (listed in paragraph 141.76)  for the  filtration technology they
choose within 48 months after  promulgation.
     Any system  failing  to meet the  criteria  listed  in  141.76(1)(1)(2)   or
(b) (1) (2)  or (b) (1) (2)  within 48 months  following promulgation of  this  rule,
would  be  in violation  of a treatment  technique  requirement.   Any system
failing to meet the  subjective  criteria,  listed in 141.76(a)(3)   or  (b)(3),
following  the  determination  made  by the Primacy Agency,  would  also be  in
violation of a  treatment technique requirement.   Any  system failing  to meet
                                       7-1

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the criteria pertaining to analytical, monitoring, and reporting requirements,
listed in 141.76(a)(4)(5)(6) or 141.76Cb)(4)(5)(6) would.be in violation of a
testing procedure requirement, monitoring requirements,  or reporting require-
ment o
     The  48-month  time  limit is  based  on  the  1986  SDWA  amendments which
require:  (1) Primacy Agencies to adopt criteria for determining which  systems
must filter  within 18 months following  EPA's promulgation  of such criteria;
(2) Primacy  Agencies  to  determine  which  systems must  filter within 12 months
following such  adoption  of  criteria,  and  (3)  systems to  install filtration
within 18 months of the determination that filtration is required.  Figure 7-1
illustrates how to determine whether a system is in compliance with the SWTR.

7.2  Systems Without Filtration
     7.2.1  Introduction
     Systems which do not provide filtration must comply with several require-
ments of the SWTR.  As indicated in Section 141.76 of the SWTR, these include:
       -  Source Water Quality Conditions
       -  Disinfection Criteria
       -  Watershed Control Program
       -  Sanitary Survey
       -  Disease Outbreaks
       -  Total Coliform Occurrence
       -  TTHM Regulation
     If these criteria are not met within 30 months following the promulgation
of the SWTR, the  system would be required to filter.   If the criteria  are not
met within 48 months  following the promulgation of the SWTR, the system would
be in violation of a treatment technique  requirement and subject to the public
notification requirements associated with such a violation.
     7.2.2  Source Water Quality Conditions
     A.  Source Water Fecal Coliform
     Any system which indicates  in its monthly report that more than  10 per-
cent of the raw  water samples for the  previous 6 months  had fecal coliform
levels greater than 20/100  ml will be required to  install filtration  as part
of its treatment  process, within 48 months of the promulgation of the  SWTR or
it will be in violation of a treatment technique requirement.
                                      7-2

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SURFACE WATER TREATMENT
MO

| SYSTEM USES SURFACI
| YE!


, NOT APPLY


FILTRATION N PLACE 7

NO f
t
MEETS SOURCE V\
QUAUTY & SITE-5
CONDCT10NS?
YES
YES
t
fATER MEETS DESIGN. OPERATION
iPECFIC No ^. EXEMPTION «* ™° PERFORMANCE CRTTFR1
CRITERIA SATISFED 7
YES 1
EXEMPTION
(TEMPORARY)
t
INO i
1 NO
I VIOLATION |-^ 	 '
1 YES
NSTALL FILTRATION
OK
MOOFY TREATMENT
-


A
YES

DECISION TREE
FIGURE 7-1

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     B.   Source Water Total Coliforms (TC)
     Any system which indicates  that  for  the previous  6 months, more  than
10 percent of the raw water samples had total  coliform levels greater than or
equal to  100/100 ml  will  be required  to install  filtration as part  of  the
treatment process within 48 months of the promulgation of the SWTR, unless the
system  also  measures  fecal coliforms  and  the  fecal  levels are within  the
acceptable limits.  If the system does  not meet this  criteria it is  in viola-
tion of a treatment technique requirement.
     C.   Source Water Turbidity
     To avoid  filtration,  a system would be  required on an  ongoing  basis to
demonstrate that  the turbidity of  the  water  prior to disinfection  does  not
exceed  5 NTU,  based  on  the collection of  grab  samples  at  least every  four
hours.  Continuous turbidity monitoring could be substituted for  grab sample
monitoring if  this measurement was validated for  accuracy  with  grab sample
measurements on a regular basis,  with a  protocol  approved by  the Primacy
Agency.   If  the public  water  system used  continuous monitoring, the system
would use turbidity values taken every  four hours to  determine whether it met
the turbidity raw water  limit.  A  system would be allowed to exceed the 5 NTU
limit,  no  more  than two  periods  during  twelve consecutive months  or  five
periods during  120 consecutive  months,  provided  that the  system informed its
customers to boil  their water before consumption during the  period  the  tur-
bidity  exceeds  5 NTU and  the  Primacy  Agency  determined that the exceedance
occurred because of unusual or  unpredictable  circumstances.   A "period" would
be defined as  the  number of consecutive days  in  which at least one turbidity
measurement each  day exceeded  5 NTU.   If these  criteria are not met within
30 months of the promulgation of the SWTR, filtration must be  installed within
18 months following the 30-month period, or the system will be in violation of
a treatment technique requirement and public notification is  required.
     7.2.3  Disinfection Conditions
     The utility must demonstrate  that  1) a residual of  at  least 0.2 mg/L is
continually maintained in the water at  the  point  of entry to  the distribution
system,  2) the system achieves a  99.9  percent inactivation  of Giardia cysts
and a 99.99 percent inactivation of viruses each  day  during peak hourly flow,
and 3)  a disinfectant residual  greater  than or equal to  0.2 mg/L is present,
                                      7-3

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in  at least 95 percent  of the monthly  distribution system  samples.   If the
system  does not  meet all of  these requirements,  the  system  must  install
filtration,  within 48 months  of  the promulgation of  the SWTR  or it  is in
violation of a treatment technique.
     7.2.4  Watershed Control Program
     The purpose of a  watershed control program is  to  minimize the potential
for  contamination  of  the  source  water  by  enteric  viruses,  Giardia  lamblia
cysts and  other biological  contaminants.   This objective is  reached  by the
elimination  or control  of  all  activities  which may  adversely  impact the
quality of  the source waters,  and  through  ownership and written agreements
with  land  owners  within the watershed.  Guidelines for  a  watershed  control
program are included in Section 3.3.1 and Appendix J of this manual.
     Conditions of noncompliance  with the requirements  of a watershed control
program include:
     A.    Not having a watershed control program in place.
     B.    The watershed  control program which is  followed is not adequate to
          meet the Primacy Agency's requirements, as suggested below.
     Systems which do not provide  a  watershed control program  must  either
implement a program or install filtration within 48 months of the SWTR or they
will be in violation of a treatment technique.
     The determination of  the adequacy  of a given  watershed control  program
will be subjective in most  cases.   The questions which must  be  answered in
order to determine the adequacy of a given watershed control program according
to the SWTR are:
     A.    Are  the  characteristics  of  the  watershed thoroughly  understood,
          including:
            -  The existing  agreements, ownership patterns,  watershed  loca-
               tion,  hydrology, etc.?
     8.    Have conditions  which may have an adverse effect  on water  quality
          been identified,  such as:
            -  Naturally  occurring  sources,  including  animal  populations,
               effects of precipitation, etc.?
                                      7-4

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            -  Man-made sources of contamination, inclining point and nonpoint
               sources  such  as  sewage   discharge,     .logging,  barnyards,
               grazing, etc.?
     C.    Have the priorities been set to  address  the  impacts of these condi-
          tions or activities?  Are there programs to control these conditions
          or activities and are they effective?  For example,:
            -  Are logging practices acceptable?
            -  Are waste discharges being controlled?
            -  Have grazing activities been limited or removed?
     Additional questions which may be considered include;
     D.    Is there  a regular  patrol of  the  watershed  to review animal  and
          human activity?
            -  Are animal populations adequately controlled?
            -  Is recreation limited?
     E.    Have malfunctioning  septic systems  been identified  and steps taken
          to correct them?
     F.    Is there  an effective  organizational structure for  the  watershed
          control program?

     Section 7.4  addresses  measures  which can  be taken by  the utility  to
attain compliance if some of the requirements of the program are not currently
met.
     7.2.5  Sanitary Survey
     The purpose  of  the  sanitary  survey is  to  identify deficiencies in  a
system which when  corrected may ensure the provision  of safe drinking water.
Each system must provide to the Primacy Agency an  annual report of the yearly
sanitary survey unless the sanitary survey is conducted by the Primacy Agency.
Performing an annual comprehensive survey may not be practical for all systems
because of  the large size  of  the system.  Thus,  it is  suggested that a  de-
tailed comprehensive  survey is conducted  at  the  onset  of the  review  of  the
     1.
Filtration may be  required if sewage  discharges or on-site  disposal systems
are present in the watershed.
                                      7-5

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system  as  presented  in  Appendix I, with  basic surveys  as detailed  in Sec-
tion 3.3.2 of this manual conducted on an annual basis.
     The  basic noncompliance  with  respect  to the  sanitary  survey  is the
failure to make the required improvements  or repairs suggested by the Primacy
Agency  as  a  result  of  the previous  sanitary survey.   The  suggestions may
include repairs  on intake  structures,  pipelines, pumps,  disinfection equip-
ment, etc., or the implementation of certain treatment processes such as the
use of  an alternate  disinfectant,  or a variation  in the  application of the
disinfectant.
     Failure to maintain  compliance with the watershed control program as in
Section 7.2.4  also results  in  a  violation of  a  treatment  technique  with
respect to the sanitary survey, as does failure to maintain adequate treatment
and records  of data  and system  operations as required  in  the SWTR.   If  a
system does not meet the requirements of a sanitary survey, filtration must be
installed within 48 months of the promulgation of the SWTR or the system is in
violation of a treatment technique.
     7.2.6  Disease Outbreaks
   - A  utility  which  has had  a waterborne  disease  outbreak attributed  to  a
treatment deficiency  and  which has not upgraded its  system satisfactorily to
prevent such  further  occurrence must  install filtration within 48 months of
the promulgation  of  the SWTR,  or the system is  in  violation  of a treatment
technique.  If after  the effective date of the SWTR, a system is allowed by
the Primacy  Agency to  operate without  filtration  and  a  waterborne  disease
outbreak  is  attributed to  that  system,  it  is in  violation  of  a treatment
technique  and must  install filtration.   However,  if a  waterborne  disease
outbreak is attributed to a deficiency in  the distribution system, the system
is not in violation of the SWTR.
     7.2.7  Long-term Total Coliform MCL
     Systems which collect  60  or more samples per  year  in  the distribution
system  (all surface water systems which  do not filter are required to collect
at least  60 samples  per year)  and detect total coliforms in  more  than  5
percent of the distribution  system samples  over a  12-month period,  are in
violation of a treatment technique and filtration is required.  In such cases,
                                      7-6

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it is  suggested that the  system disinfection  be  altered to  gain compliance
prior to installing filtration.
     7.2.8  Total Trihalomethane (TTHM) Regulations
     The SWTR requires that  the  system be in compliance with the current TTHM
regulation.  If the yearly running average TTHMs exceed 0.1 ng/L  in  a system
serving more  than 10,000  people,  the  system must install  filtration within
48 months of the promulgation  of the SWTR or the system is  in violation of a
treatment  technique.   Measures which  can be taken  to meet the required THM
levels within 30 months of the promulgation of the SWTR include the removal of
THM precursors,  or the  use  of an  alternate disinfectant which will produce
lower concentrations of THMs.
     It should  be noted that in  the  future,  THM  regulations are likely to
apply  to  all community  systems, including  those  with populations less than
10,000.   Also,   regulations  for  other  disinfection  by-products  are  under
development and will be promulgated before 1991.  Thus, it is recommended that
regardless of  system size,  any  systems  with THM  levels near  0.1 mg/L begin
plans to install filtration.

7.3  Systems Providing Filtration
     7.3.1  Introduction
     Filtration may be  achieved  through  many different  methods which require
different turbidity performance  levels for compliance.  This  section will be
subdivided according to the requirements  for the various technologies.
     7.3.2  Systems Using Conventional Treatment,
            Direct Filtration or Technologies Other
            than Slow Sand and Diatomaceous Earth Filtration
     Utilities which  operate  these  systems  must  maintain a  filter  effluent
turbidity of  less  than or  equal to 0.5NTU.   As indicated in  Section 5.3 of
this manual,  the turbidity  measurements to  satisfy  the requirements  of the
SWTR may  be  taken  at  the combined  filter  effluent  prior to entry  into a
clearwell, at the clearwell  effluent or  at  the  plant  effluent prior  to entry
into the distribution system.  If more than 5 percent  of the monthly effluent
samples contain a turbidity  greater than 0.5 NTU, the system  is in violation
of a treatment requirement.  In  cases  where the Primacy Agency has determined
                                      7-7

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that a  higher turbidity  level  is acceptable  for the  system as  a  result of
on-site  studies  demonstrating  effective  removals/inactivations  of  Giardia
cysts at a filtered water turbidity  level  up to 1 NTU,  the system will not be
in violation unless more  than 5 percent of the monthly effluent samples have
turbidity levels  greater than  1  NTU.   In addition,  if the  turbidity of the
filter  plant  effluent  at any  time  exceeds  5 NTU,  the system is in acute
violation of  a treatment requirement  and is  required  to issue a boil water
notice to the public.   Requirements  presented  in  Section 7.3.5 and 7.3.6 must
also be met.
     7.3.3  Systems Using Slow Sand Filtration
     Utilities using slow sand  filtration  treatment must maintain an effluent
turbidity equal to or less than  1  NTU.   If more than 5 percent of the effluent
samples contain greater than 1  NTU turbidity,  the system is in violation of a
treatment technique  requirement  of  the  SWTR.   In cases  where  the  Primacy
Agency  has  determined  that  a higher  turbidity level  is acceptable  for the
system as a result of on-site studies demonstrating effective removals/inacti-
vations of Giardia cysts at a filtered water turbidity  level up to 5 NTU, the
system will not be in violation unless  an  effluent sample exceeds a turbidity
of 5 NTU.  Systems operating  at a filtered water  turbidity  between 1 NTU and
5 NTU,  must  sample the filter effluent prior  to  disinfection in the  same
manner and frequency as in the  Proposed Total  Coliform  Rule, the results must
comply with the proposed long-term colifonn MCL for one year and the dates and
results of the  sampling are  submitted to the  Primacy Agency.  If a turbidity
greater  than  or equal  to 5 NTU  is  detected  at  any time,  the system  is  in
violation of  a  treatment  technique requirement, and a  boil  water notice must
be issued to  the public.  Requirements presented in Section 7.3.5  and 7.3.6
must also be met.
     7.3.4  Systems Using Diatomaceous Earth (DE)  Filtration
     The SWTR requires  that  systems  using DE  filtration maintain an effluent
turbidity equal to or less than 1 NTU.   If more than 5  percent of the monthly
effluent  samples  contain turbidities  greater  than  1  NTU,  the system  is  in
violation of this requirement.  In addition, if any filter effluent turbidity
exceeds 5 NTU, the system is in acute violation of a treatment technique and a
boil water  notice must be  issued to  the  public.   Requirements presented in
Section 7.3.5 and 7.3.6 must also be met.
                                      7-8

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     7.3.5  Disinfectant Requirements

     For systems which provide filtration:

       -  Failure to continuously maintain a disinfectant residual of at least
          0.2 mg/L in the water entering the distribution system (demonstrated
          by continuous monitoring)  is  in violation of a treatment technique,
          and public notice is required.

       -  Failure  to  maintain  continuous  monitoring  of  the  disinfectant
          residual  entering the  distribution  system is  in  violation  of  a
          monitoring requirement.

       -  Failure to  maintain a  residual of  0.2  or greater  in at  least  95
          percent  of  the  distribution system  samples  each month  for  two
          consecutive months is in violation of a treatment technique.

       -  Failure to  sample the  distribution system  at the  frequencies  and
          locations specified in  the total coliform rule is  a violation  of a
          monitoring requirement.

       -  Failure to  use  an approved  analytical  technique  as  presented  in
          Section 141.74 C is in violation of a monitoring requirement.

     As  presented  in  Section 141.74,  the  approved  analytical  procedures

include:

       -  Amperometric titration method
       -  DPD ferrous titrimetric method
       -  DPD colormetric method
       -  Leuco crystal violet method
       -  Indigo method

     In  addition to  these  minimum  requirements,  Section 5  of this  manual

presented the importance  of maintaining a sufficient disinfectant  dosage  and

contact time to achieve the minimum overall  3 log removal and/or inactivation

of Giardia  cysts and  4 log removal  and/or  inactivation of  enteric  viruses.

Failure to meet these requirements as specified by the Primacy Agency would be

a violation of  a  treatment technique  requirement.  The  SWTR  requires  that

Primacy Agencies  establish design  and operating  regulations to assure  that

systems are achieving a 3 log removal and/or inactivation of Giardia cysts and

a 4 log  removal and/or inactivation of  enteric  viruses.  Unless  the  system

meets these requirements it is in violation  of a  treatment technique.  In the

event that  the  Primacy Agency  does not  adopt these requirements  as part of

their design  and operating conditions  as contained  in  Section 141.72(B)(1),
                                      7-9

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failure  to meet  these requirements  cannot be  considered  a violation  of a

treatment technique.


7.4  Responses for Systems not Meeting the SWTR Criteria

     7.4.1  Introduction
     Systems which presently  fail  to  meet the SWTR  criteria because of their

present  configuration  or operating  condition  may  have  the  capability  of

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

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

may be followed to achieve compliance.
     7.4.2  Systems Kot Filtering

     Systems not filtering can be divided into two categories:

     A.   Those systems not  meeting the  SWTR  criteria before  30  months with
          the ability to upgrade to meet them.

     B.   Those systems failing to meet the SWTR criteria after 30 months and
          filtration is required.   If the installation of  filtration  is  not
          possible within the following 18 months to gain compliance, to avoid
          a violation  to  a  treatment technique requirement, the  system may
          request an exemption and take interim measures to provide reasonably
          safe water.

     Systems in Category A

     Example A - Response  Situation

     Conditions  System is  not meeting  the source  water fecal and/or total
     coliform concentrations but has not  received judgment  on the  adequacy  of
     its watershed control.

     Response Options;

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

       -  Take appropriate action in  the  watershed  to insure  fecal and total
          coliform concentrations are below the criteria,  such as  elimination
          of animal  activity near  the  source water intake.
                                     7-10

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Example B - Response Situation

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

Response Options;

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

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

  -  Apply a more effective disinfectant such as ozone.

Systems in Category B

Example A - Response Situation

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

Response Options;

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

  -  Take  steps to  install  filtration, applying  for  an exemption  as
     presented in Section 9 where appropriate.

Example B

Condition;  The  source water  exceeds a turbidity of 5 NTU for an average
of four periods per year.

Response Options;

  -  During the  periods when  the turbidity exceeds 5 NTU, issue a public
     notice  to  boil all  water  for consumption.  The  utility continues
     sampling the  distribution  system  for  chlorine residual  and total
     coliforms, and initiates measurement of the HPCs in  the distribution
     system.  This data and the  raw water turbidity is used to determine
     when to lift the boil water notice.  The notice  is lifted when;

       -  The historical  (prior  to high turbidity) disinfectant  residual
          concentration is reestablished in the distribution system.
                                7-11

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            -  The total colifonn requirements are met.

            -  The HPC count is  less than 500.

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

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

       -  Take  steps  to  install  filtration,  applying  for  an exemption  as
          presented in Section 9 where appropriate.

     7.4.3  Systems Currently Filtering

     Systems which are currently  filtering must  meet  the SWTR criteria within

48 months of the  SWTR to be in compliance,  after which the  criteria  must  be

continually met for the system to be in compliance.
     Example A - Response Situation

     Condition;  A direct filtration  plant  is treating  a surface  water which
     is not compatible with this treatment process.   The system is not achiev-
     ing its required turbidity performance or disinfection criteria.

     Response. Options;

       -  Increase disinfectant  application  while  monitoring  THM  levels  to
          ensure that the MCL is not exceeded.

       -  Use an alternate disinfectant.

       -  Optimize coagulant dose.

       -  Reduce filter loading rates.

       -  Evaluate the effect  on performance  of installing  flocculation and
          sedimentation ahead of the filters.

     Example B - Response Situation

     Condition:  A filtration plant is using surface water which is compatible
     with its  treatment  system.   The  system is not achieving  disinfection
     performance criteria required by the Primacy  Agency to achieve  a 1 log
     inactivetion of Giardia cysts; however, it is meeting the requirements  of
     the total coliform rule.

     Response Options;

       -  Increase disinfectant dosages.

       -  Add a stronger alternate disinfectant such as ozone.
                                     7-12

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Install storage facilities to increase disinfectant contact time.




Ensure optimum filtration efficiency by:




     Use of a filter aid.




     Reduction in filter loading rates.




     More frequent backwashing of filters.
                            7-13

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                            8.  PUBLIC NOTIFICATION

     The SWTR specifies  that  the  public notification requirements of the Safe
Drinking Water Act  (SDWA) and the implementing regulations of 40 CFR Paragraph
141.32 must  be  followed.   These regulations  divide public  notification  re-
quirements into two tiers.  These tiers are defined as follows:
     1.   Tier 1:
          a.   Failure to comply with MCL
          b.   Failure to comply with prescribed treatment technique
          c.   Failure to comply with a variance or exemption schedule
     2.   Tier 2:
          a.   Failure to comply with monitoring requirements
          b.   Failure  to comply  with a  testing procedure  prescribed by  a
               NPDWR
          c.   Operating under a variance/exemption.  This is not considered a
               violation but public notification is required.
     The SWTR classifies violations of Paragraphs 141.70,  141.71,  141.72  and
141.73 (as specified  in  Paragraph 141.76)  as Tier 1 violations and violations
of Paragraphs 141.74 and 141.75 as Tier 2 violations.  In addition, the public
notification rule classifies  certain  violations  as "acute" Tier 1 violations.
The "acute" Tier 1 violations of the SWTR are:
     1.   When the  turbidity  of the water prior  to  disinfection of an unfil-
          tered supply,  or  the  turbidity of filtered water,  exceeds 5 NTU at
          any time.
     2.   There is  a  failure  to maintain a disinfectant residual  of at least
          0.2 mg/L in the water being delivered to the distribution system.
     There are  certain  general requirements  which all  public notices  must
meet.  All notices must provide a clear and readily understandable explanation
of  the violation,  any  potential adverse  health  effects,  the  population at
risk,  the steps  the system is taking to correct  the violation, the necessity
of seeking alternate water supplies (if any) and any preventative measures the
consumer should take.  The notice must  be  conspicuous,  not contain any unduly
technical language, unduly  small  print or similar problems.   The notice must
include  the  telephone number of the owner or  operator  or designee  of  the
public water  system  as a  source  of additional  information  concerning  the
violation where appropriate.  The notice must be multi-lingual.
                                      8-1

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     In addition,  the public notification  rule requires that  when providing

information on  potential  adverse health effects  in public notices of viola-

tions of MCLs, violations of treatment techniques, notices of granting and the

continued  existence  of  exemptions  and variances from maximum  contaminant

levels and failure to comply with a  variance or exemption schedule, the owner

or operator of a public  water  system must  include certain mandatory health

effects language.  For violations of filtration and disinfection requirements,

the mandatory health effects language is:

     Microbiological Contaminants

     The United States Environmental  Protection Agency (EPA)   sets  drinking
     water treatment  technique  requirements for  microbiological contaminants
     (such as viruses, bacteria, and some  other microorganisms) which are of
     health concern.  To reduce any  potential  risk of  microbial contamination
     of drinking waters,  drinking water  treatment facilities are  required to
     treat drinking water  by  filtering or  disinfecting,  which  removes  or
     destroys  microbiological contaminants.  Violation of the required treat-
     ment technique indicates that the water has been treated  improperly  and
     may expose people who  drink that water  to contaminants which  can  cause
     various   types  of  illness   such as hepatitis, giardiasis,  and  gastro-
     enteritis.   These  illnesses  can  cause  different  symptoms,  including
     diarrhea,  jaundice,  abdominal  cramps,  nausea, headaches, fatigue,  and
     weight loss.

     Further,  the owner or  operator  of a  community water system must give  a
copy of the most  recent  notice  for  any  Tier 1 violations to all  new  billing

units or hookups prior to or at  the time  service begins.
     The medium for performing  public notification and the time period  in
which notification  must  be  sent varies with the  type  of violation  and  is
specified in  141*32.  For Tier 1 violations  (i.e., violations of Paragraphs
141.70,  141.71, 141.72 and  141.73),  the owner  or operator  of  a public  water
system must give notice:

     1.    By publication  in  a local daily newspaper as  soon  as possible but in
          no  case later than 14  days after the violation or failure.   If  the
          area does not have a daily newspaper, then notice shall  be given by
          publication in  a  weekly  newspaper  of  general circulation  in  the
          area.

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

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     If,  however,  the  violation is  an "acute"  Tier 1 violation  as defined
above,  a  copy of  the notice must  be  furnished  to the radio  and television
stations  serving the  area as soon as  possible,  but in no case  later than 72
hours after the violation.
     Following, the initial notice, the owner or operator  must give notice at
least once every three  months by mail  delivery  (either by itself or with the
water bill),  or by hand delivery,  for as long  as the violation  or failure
exists.
     There are two variations  on these requirements.  First,  the  owner or
operator  of  a community water  system in an  area not served  by a  daily or
weekly newspaper must give  notice within 14 days  after the  violation by hand
delivery or continuous posting of a notice of the violation.  The notice must
be in a conspicuous place in the area  served by  the  system and must continue
for as long as the violation exists.  Notice by hand delivery must be repeated
at least every three months for the duration of the violation.
     Secondly, the owner or operator of a noncommunity water system  (i.e., one
serving a transitory population)  may give  notice by hand delivery or continu-
ous posting  of the notice  in conspicuous places  in  the  area  served  by the
system.  Notice must be  given within  14 days after the violation.   If notice
is given  by  posting,  then it must  continue as long  as the violation exists.
Notice given by hand delivery must be repeated at  least every three months for
as long as the violation exists.
     For  Tier 2  violations  (i.e.,  violations of 40  CFR  141.74  and 141.75)
notice must be given within three months after the violation by publication in
a daily newspaper  of  general  circulation,  or if there  is  no daily newspaper,
then in a weekly  newspaper.   In addition, the  owner or  operator  shall give
notice by mail  (either by itself or with the water bill)  or by hand delivery
at least once every three months for  as long as  the violation exists.  Notice
of a variance or exemption  must  be  given every three  months from the date it
is granted for as long as it remains in effect.
     If the area is not served by a daily or weekly newspaper,  the owner or
operator of a community water system must give notice by continuous posting in
conspicuous places in the area served  by  the system.  This must continue as
long as the  violation does  or  the variance  or  exemption remains  in effect.
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Notice by hand delivery  must be repeated at least every three months for the

duration of the violation or the variance of exemption.

     For noncommunity water  systems,, the owner  or operator may give notice by

hand delivery or continuous posting in conspicuous places;  beginning within

3 months of the violation or the variance or exemption.  Posting must continue

for the duration of the violation or variance or  exemption and notice by hand

delivery must be repeated at least every 3 months during this period.

     The state may allow for owner or operator to provide less frequent notice

if EPA has approved the state's substitute requirements.

     To provide further assistance in preparing public notices, a few examples

have been provided.  However, each situation is different and will call for a

variation in the content and tone of the notice.  All notices must comply with

the general requirements specified above.


Example 1 - Acute Tier 1 Violation
     A system which does not apply filtration,  experiences a breakdown in the

chlorine feed systems and  the  switchover system fails  to activate the backup

systems.  This is  an  acute Tier 1 violation which may pose  an  acute risk to

human  health.   A  number  of hours  pass before  the  operator discovers  the

malfunction.

     The operator upon discovery of  the malfunction,  contacts the local tele-
vision and radio stations and announces that the public is receiving untreated

water.  The announcement may read as follows:

     We have just received word from the  local  water supplier that a malfunc-
     tion of the disinfection system has allowed  untreated water to pass into
     the distribution  system.   Thus, the  public  water  system providing your
     drinking water is in violation to a treatment technique requirement.  The
     United States  Environmental  Protection Agency  (EPA)  sets drinking water
     treatment technique requirements  for microbiological  contaminants (such
     as viruses, bacteria, and  some  other  microorganisms)  which are of health
     concern.  To  reduce  any  potential  risk   of  microbial  contamination  of
     drinking waters,  drinking water  treatment  facilities  are  required  to
     treat  drinking water by  filtering  or  disinfecting,  which removes  or
     destroys microbiological contaminants.  Violation of the required treat-
     ment technique indicates  that  the water has been treated improperly and
     may expose  people  who drink that  water  to contaminants  which  can cause
     various  types of  illness such as  hepatitis,  giardiasis,   and gastro-
     enteritis.    These  illnesses can cause   different symptoms,  including
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     diarrhea,  jaundice,  abdominal  cramps,  nausea,  headaches,  fatigue,  and
     weight loss.

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

     In order  to  protect your  personal  health,  all water which is  used  for
     drinking  or cooking must be boiled  at a full rolling  boil  for  1 minute.
     The boiling will kill any  organisms which may be in the water.   You  are
     urged to  continue this treatment for the next three days.  If  you develop
     any of these symptoms, you are advised to contact your physician.

Additional information is available at the  following number:  1-800-235-WATER.

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


Example 2 - Acute Tier 1 Violation

     A system  supplies an unfiltered surface water to its customers.   During  a

period of unusually heavy  rains caused by a  hurricane  in the area,  the tur-

bidity of the  water exceeds 5 NTU.   The turbidity data  during which  the heavy

rains occur is  as follows:
     Day    NTU    Day      NTU    Day     NTU    Day     NTU

     1      0.4            0.5            0.4     5       7.6
            0.4            0.4            0.6             3.1
            0.5            0.4     4      0.7             2.7
            0.7            0.6            7.6             0.7
            1.1     3      0.7          11.3             0.8
            0.9            0.4            9.6             0.5
     2      0.8            0.4            7.2     6       0.5
            0.5            0.5            5.0

     The  following  public notice  was prepared  and  submitted  to the  local

newspaper, television and radio stations within 72 hours of the  first turbid-

ity exceedence  of 5  NTU.
     The occurrence of heavy rains  in  our  watershed is  causing a  rise  in  the
     turbidity  of our drinking  water supply.

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

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

     The  United  States  Environmental  Protection  Agency  (EPA)  sets drinking
     water treatment technique requirements  for  microbiological contaminants
     (such as viruses,  bacteria,  and some other  microorganisms)  which are of
     health concern.  To reduce any  potential risk of microbial  contamination
     of drinking waters,  drinking water treatment  facilities are required to
     treat  drinking water  by  filtering or  disinfecting,  which  removes or
     destroys microbiological  contaminants.   Violation of the required treat-
     ment technique  indicates  that the water has been treated improperly and
     may  expose  people  who drink  that  water to  contaminants which can cause
     various types   of  illness such as  hepatitis,  giardiasis, and gastro-
     enteritis.   These  illnesses can   cause different  symptoms,  including
     diarrhea,  jaundice,  abdominal  cramps, nausea,  headaches,  fatigue,  and
     weight loss.

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

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

     Additional information is available at  the  following number:  1-800-626-
     1BOIL.

     The  utility continues sampling  the  distribution  system  for  chlorine
residual  and total   coliforms,  and initiates measurement  of the HPCs in  the
distribution system.  This data and the raw water turbidity is used to deter-

mine when to lift the boil water notice.  The notice is lifted when:

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

       -  The total  coliform requirements are met.

       -  The HPC count is <500.

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

The  system  enters into a  dialogue  with the Primacy Agency on whether  the

turbidity event was  unusual or unpredictable  and  whether filtration should be
installed.
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Example 3 - Nonacute Tier 1 Violation

     A conventional treatment  plant is treating a surface water.   A malfunc-

tioning  alum feed  system  resulted in  an  increase  of  the filter  effluent

turbidities.  The effluent turbidity was between 0.5 and 1.0 NTU in 20 percent

of the samples for the month.  The utility issued a notice which was published

in a  local  daily newspaper  within  14 days  after  the violation.   The  notice
read as follows:

     During the previous  month,  the water treatment plant  experienced  diffi-
     culties  with  the  chemical  feed  system.  The  malfunctions  caused  an
     effluent turbidity level  above 0.5  NTU in 80 percent of the  samples  for
     the month.   The  current  treatment  standards  require that  the turbidity
     must be  less than 0.5  NTU in  95 percent of  the  monthly  samples.   Our
     drinking water system has thus been in violation to a treatment technique
     requirement.

     The United  States Environmental  Protection Agency  (EPA)   sets  drinking
     water treatment  technique requirements for microbiological contaminants
     (such as viruses, bacteria,  and some other microorganisms) which  are of
     health concern.  To reduce any  potential  risk  of microbial contamination
     of drinking  waters,  drinking water treatment facilities are  required to
     treat  drinking water  by  filtering or  disinfecting,  which   removes  or
     destroys microbiological  contaminants.  Violation of the  required treat-
     ment technique indicates  that  the water has been treated  improperly  and
     may expose people who drink that water to contaminants which can cause
     various  types  of illness  such as  hepatitis, giardiasis, and  gastro-
     enteritis.    These illnesses  can  cause  different  symptoms,  including
     diarrhea,  jaundice,  abdominal  cramps,  nausea, headaches,  fatigue,  and
     weight loss.

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

9.1  Minimum Requirements
     EPA believes that in order to obtain an exemption from the SWTR, a system
should meet  certain  minimum requirements.   These  should  be  applied  before
looking at other factors  such  as affordability.  These  minimum requirements
are listed below.
     Systems which do not provide filtration
       -  Practice disinfection  to achieve at  least a 2 log  inactivation of
          Giardia cysts; or  comply with the disinfection  requirements for the
          distribution system as defined in Section 141.72b of the SWTR.
       -  Comply with both  the  monthly and  long-term  coliform MCL  or issue
          boil water  orders  to  their customers; or  provide  bottled water (or
          another alternate  water source)  or point of use  treatment devices
          for their  customers in which representive samples  comply  with all
          the MCL National Primary Drinking Water Regulations.
     It is recommended that in  order to obtain  an  extension  to  the initial
exemption period,  the  system would need  to be in  compliance with  both the
monthly and  long-term coliform MCL,  satisfy the above disinfection criteria
and not have any evidence  of waterborne disease outbreaks attributable to" the
                                                                          •
system at the end of  that  first exemption period.  If at  any point during the
extended  exemption  period  the  system  did not  meet these  conditions  ,' the
system should be subject to an enforcement action.
     Systems which provide filtration                                     •
       -  Practice disinfection  to achieve at  least a 1 log  inactivation of
          Giardia cysts; or  comply with the disinfection  requirements for the
          distribution system as defined in Section 141.72b of the rule.
       -  Comply with both  the  monthly and  long-term  coliform MCL  or issue
          boil  water  orders or  provide bottled  water  (or  other  alternate
          supply) or point of use treatment devices for their customers; and
       -  Take  all   practical  steps   to   improve   the  performance  of  its
          filtration  system.
     It is recommended that in  order to obtain  an  extension  to  the initial
exemption period,  the  system would need  to be in  compliance with  both the
monthly and  long-term coliform MCL,  satisfy the above disinfection criteria
and not have any evidence  of waterborne disease outbreaks attributable to the
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system at the end  of  that first exemption period.  If at any point during the
extended  exemption period  the system  did not  meet  these conditions  , the
system should be subject to  an enforcement action.   In addition, the  system
must continue to be taking  steps  to  improve the performance of its filtration
system to achieve the criteria specified in the SWTR.
     Once these  minimum requirements are  applied,  the  Primacy  Agency  should
look at the other factors as described in Sections 9.2, 9.3, and 9.4.

9.2  Compelling Factors
     Compelling factors are any conditions which would render compliance with
the requirements of the SWTR impractical.  These problems  or constraints are
associated most  often with small systems, and the major compelling factor is
economic.   It  is  suggested  that  another  compelling  factor  may  be  the
unavailability  of  qualified  operators.    Small systems  may  not  have  any
certified operators within commuting distance  from  the plant.  Also,  it may
not be  practical  for  the system  to  relocate  a  certified operator  within
commuting distance,   since  plant operations  would  not require  a full time
operator.   Additional  considerations  for  small systems  are  presented  in
Appendix L.
     If  system  improvements  necessary  to  comply with  the SWTR  incur  costs
which the Primacy  Agency determines  pose  an  undue  economic hardship,  the
system fulfills  the  criteria of  demonstrating  a  compelling hardship  which
makes it unable to meet the treatment requirements.   The system may obtain an
exemption if the criteria in 9.3 and 9.4 are also met.
     The USEPA document, "Technologies  and Costs  for the Removal of Microbial
Contaminants from  Potable  Water Supplies,"  contains  costs associated with
available treatment alternatives (USEPA, 1987).   Costs found in this document,
or those  generated from  more site  specific  conditions, can be used as the
basis  for  determining   the   ability  of  a  system  to  afford  treatment.
Specifically, in this manual when calculating the total production costs, each
cent per thousand gallons of treated water is equivalent to $1.5 per year per
household, assuming a water usage of 100 gallons per capita per day, and four
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people per household.     The total cost will need to be adjusted according to
water usage for cases where the usage  differs  from 100 gallons per capita per
day, or  for the number  of people per  household if that number  differs from
four.
     The following  examples  are presented to  provide  guidance in determining
whether a system can afford to upgrade its system or install filtration.
     Example 1
     A water  system which  supplies an  average  daily  flow  of 0.05 mgd  to a
small  urban community,  receives  its water  supply from  a lake.   The system
currently provides disinfection with chlorine but does not provide filtration.
The system reviewed  its  source  water quality and found the characteristics to
be as follows:
          Total coliforms          1,000/100 ml
          Turbidity                10 - 13 NTU
          Color                    6 - 9 CU
     Based upon the  criteria  found in the SWTR,  this  source requires filtra-
tion  and a  review  of  the  water  quality  criteria  presented in Table 4-2,
indicates that   the treatment  technique  which  is most  applicable  to these
source conditions is conventional treatment.  A conventional package treatment
     1.   Determined as follows:
          4 persons x 100    gal     x 365 day  • 146,000 	gal
          household       person-day       year           household-year
          146,000 	gal      x      1C      » $1.5/household-year
                  household-year   1,000 gallon
          or   ($1.5/household-year) / (C/1,000 gallons)
                at a usage of  146,000 gal
                              household year
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plant with a capacity of 0.068 MGD may be purchased and put on line at a cost
of $416/household/year not  including the cost of  any pilot studies which may
be required by the state.
     Thus  the  cost estimate  for implementing  filtration  indicates  that the
increase  in  the average annual  household water  bill would  be approximately
§416.  The incomes of people  in  the  community and the current water bills can
be  reviewed by the  Primacy  Agency  along  with  these  estimated costs  to
determine  if  an undue  economic  hardship  is  incurred  by   these treatment
methods.   Upon  determination that  an  economic  hardship is  incurred,  the
Primacy Agency may grant an exemption from filtration, provided that no other
water source meeting the standards is available at a lower cost, and that the
system can assure the protection of  the  health of the community.   However, if
the  water supply  system for a  nearby community meets  the  drinking water
standards  and  there  is the ability  to hook  up to that system, an exemption
would not  be granted  provided the total cost would be  less  than  that of the
above treatment.
     Example 2
     A  large urban  community with  a  median  annual income of  $25,000  per
family,  is supplied  with  water from  lakes  and  reservoirs.   The community
places an  average daily  demand of 3 mgd on the  supply system.  .The watershed
of the  system  is moderately populated and used for farming and grazing.  The
system  currently provides  filtration using diatomaceous earth filtration and
disinfection with ehloramines.
     A review of the source and finished water quality was  conducted to evalu-
ate  the plant's performance.  The source water quality was  determined to be:
          Total coliforms          30 - 40/100 ml
          Turbidity                2-3 NTU
          Color                    1 - 2 CU
     2.   Table VI-3  (USEPA, 1987) lists the total cost as 277.40/1,000 gal
          (277.40/1,000 gal) ($1.5/household-year) c $416/household-year
                             (  0/1,000 gallons  )
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     Diatomaceous  earth  is  therefore  an  acceptable  filtration  method.(3)
However,  review of  the finished water  showed  that a residual  in  the distri-
bution system is only maintained 80 percent of the tine.  In addition to this,
coliforms were  detected in 10 percent  of the samples  taken over  the  twelve
month period.   Inspection  of  the chlorination equipment  showed the equipment
is deteriorated.   Review  of  the monthly reports  showed that  the coliforms
appeared in  the distribution system  shortly after the  chlorinators malfunc-
tioned.  This observation  led to the  conclusion  that  new disinfection facili-
ties were needed.
     The source water quality and  available  contact time  after disinfection
were then used to determine the most  appropriate disinfectant for the system.
As described in Section 5.5,  ozone,  chlorine or chlorine dioxide  can be used
as primary  disinfectants  given  these  conditions.  A  preliminary  review of
costs for applying  the various disinfectants  showed  chlorine to be the most
                                            (4)
economical at a cost  Of $4.2/household/year     (USEPA,  1987).   This cost does
not include backup equipment;  however, even with providing duplicate equipment
doubling this  cost to  $8.4/household/  year,  the improvement  incurs minimal
cost and  it is unlikely   that the  Primacy Agency will  grant  the  system an
exemption based on economic hardship.

9.3  Evaluation of Alternate Water Supply Sources
     Once compelling  factors  are  demonstrated, systems must next demonstrate
that there is  no  reasonable alternate  water  supply available  to  the system.
In order to  show  this,  the system must evaluate  the  possibility of utilizing
an alternate source.  These alternate sources include:
       -  The use of ground water
       -  Connection to a  nearby water purveyor
     3.    As determined from Table 4-2 of Section 4.
     4.    Table VT-12 (USEPA, 1987) lists a total cost of 2.8^/1,000 gal for a plant
          capacity of 5.85 MGD.
          (    2.8C  )  ($1.5/household-year) m $4.2/household-year
          (1,000 gal)  (    C/1,000 gal    )
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       -  Utilization of an alternate surface water supply
     When considering the use of ground water, the purveyor must determine the
capacity  of the  underlying  aquifer  for supplying  the  demand.    The water
quality characteristics  of the  aquifer must be  evaluated to  determine what
treatment may  be needed  to meet  existing standards.   The  cost of the well
construction and  treatment facilities must  then  be determined and converted
into a yearly cost per household.
     The connection to a  nearby purveyor  involves  contacting the  purveyor to
determine their  capacity and willingness to supply  the water.  Once  it has
been determined that the alternate source meets  all applicable drinking water
standards, the cost of the  transmission lines, distribution system, and other
facilities  (e.g.  disinfection,  repumping, etc.)  must then be  determined and
amortized into a yearly cost per household.
     If the  cost  for an alternate source is found by the Primacy Agency to
present an economic hardship, and the purveyor can demonstrate that there will
be no unreasonable risk to health  as  cited in Section 9.4, the Primacy Agency
may grant an exemption to  the SWTR for the purveyor and develop a schedule of
compliance.

9.4  Protection of Public Health
     Systems which apply for exemption from the SWTR must demonstrate  to the
Primacy Agency that the health of the community will not be put at risk by the
granting of  such an  exemption.   A system  will  provide  protection for  the
public  health  by   meeting  the   minimum  suggested  EPA   requirements   in
Section 9.1.  However,  a Primacy  Agency may specify additional measures  or
standards a system  must  meet  to  protect  public health.   These  measures
necessarily  will  depend  on the particular  circumstances and systems  with
currently unfiltered  surface water supplies which fail  to  meet  the  source
water quality criteria will be required to install filtration as part of their
treatment process.   However, it may  take 3 to  5 years  or  more  before  the
filtration system can  be designed,  constructed  and begin operation.   During
this period  interim measures which the system could take  include  one or more
of the following:
     a.   Use of higher disinfectant dosages without exceeding the TTHM MCL
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     b.   Installation  of  a  replacement  or  additional disinfection  system
          which  provides greater  disinfection  efficiency and  which  can  be
          integrated into the new filtration plant
     c.   Increasing the monitoring and reporting to the Primacy Agency
     d.   Increasing protection of the watershed
     e.   Increasing the frequency of sanitary surveys
     f.   Temporarily purchasing water from a nearby water system
     g.   For  small  systems,  temporary installation  of a mobile filtration
          (packaged)  plant
     h.   Increasing contact time by rerouting water through reservoirs
     In some cases systems may be  able  to increase their disinfection dosages
 during the interim period to  provide additional protection against pathogenic
 organisms.  This alternative  should  be  coupled with a requirement for increa-
 sed monitoring for coliforms, HPC and disinfectant residual within the distri-
 bution system.   However,  this alternative is not  recommended  if the increase
 in disinfectant dosage will result in a violation of the TTHM regulation.
     Systems which are planning to install filtration may be able to utilize a
 more efficient disinfectant  that can  later  be  integrated  into the  filter
 plant.  Currently  ozone and  chlorine  dioxide are  considered  to be  the most
 efficient in reducing/inactivating Giardia cysts and enteric viruses.
     For all systems which  do not meet the source  water quality criteria and
 must install filtration,  it is recommended that during the interim period the
 Primacy Agency increase its surveillance of the system and require increased
 monitoring and reporting requirements  to assure  adequate protection  of the
 public health.
     Any  required  increases  in . watershed control   and/or  sanitary  survey
 prerequisites  will  not  alleviate the  need for  more  stringent disinfection
 requirements  and increased  monitoring  of the  effectiveness  of the  system
 employed.   Their purpose would  be  to identify  and  control  all sources  of
 contamination  so that  the  existing  system will  provide water of  the best
possible quality.
     For some  systems, it  may be possible to purchase water  from  a  nearby
system on  a  temporary basis.   This may involve  no  more  than  the use  of
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existing  interconnections or  it may  require  the  installation  of  temporary
connections.
     Trailer mounted filtration units  (package plants) are sometimes  available
from state agencies for emergencies  or may be rented or leased from  equipment
manufacturers.
     Systems may also be required to issue a boil water notice, supply bottled
water  or  install  point-of-entry  (POE)  treatment devices.   For  the reasons
listed below,  these alternatives  should only  be  utilized  if  the previously
mentioned alternatives are not feasible:
       -  There is  no way to  assure that  every consumer will  adhere  to the
          boil water decree.
       -  In many  states  bottled water  is subject only to  the water quality
          requirements of the FDA as a beverage and not to the requirements of
          the Safe Drinking Water Act.
       -  Point-of-entry  treatment  devices  are  not  currently  covered  by
          performance or  certification requirements which would assure their
          effectiveness or performance.
     Should the  installation of POE devices be required,  it  is recommended
that the selection of the appropriate treatment device be based upon  a labora-
tory or  field  scale evaluation  of  the devices.   A guide for  testing  the
effectiveness of POE units in the microbiological purification of contaminated
water is provided in Appendix Q0
     Several  issues  arise  with  the  use of   POE  devices.   These include
establishing who or what agency has the responsibility for ensuring compliance
with standards; retains ownership of the treatment units; performs monitoring,
analyses  and  maintenance;  manages  the  treatment  program  and   maintains
insurance coverage  for damage  and liability.   It  should also  be considered
that there is no significant increase in risk over centrally treated  water.
     These issues should be borne in mind when  POE  as a treatment alternative
is being considered.
     Systems with currently  unfiltered surface  water supplies  which meet the
source water quality  criteria,  but do  not meet one or more  of the other re-
quirements  for watershed  control,  sanitary  survey,  compliance  with  annual
coliform MCL  or disinfection  byproducts regulation(s),  will be  required to
install filtration unless  the  deficiencies are  corrected within  30 months of
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promulgation of the SWTR.  Interim protection measures include those previous-
ly listed.
     Systems with currently  unfiltered surface water supplies which meet the
source water quality criteria and  the  site specific criteria but which do not
meet the  disinfection requirements,  will be  required  to  install filtration
unless the  disinfection  requirements  (adequate CT  and/or disinfection system
redundancy)  can  be met.   During  the  interim  period,  the  available options
include:
     a.   Temporary installation of a mobile treatment plant
     b.   Temporary purchase of water from a nearby purveyor
     c.   Increased monitoring of the system
     d.   Installation of temporary  storage  facilities  to increase the disin-
          fectant contact time
     Currently filtered supplies which fail to meet the turbidity or disinfec-
tion performance criteria presented  in Section  5  will be required to evaluate
and upgrade their treatment  facilities in order to attain compliance.  During
the  interim period the  available options for improving the finished  water
quality include:
     a.   Use of a filter aid to improve filter effluent turbidities
     b.   Increased disinfectant dosages  and/or the  addition of an alternate
          disinfectant such as ozone
     c.   Reduction in filter loading rates with subsequent reduction in plant
          capacity
     d.   Installation of temporary  storage facilities  to  increase disinfec-
          tant contact time

9.5  Schedule of Compliance
     The  granting of an exemption is accompanied by a schedule of action which
is set by the  Primacy  Agency.   The schedule establishes  a  time  frame for the
water system to comply with  the treatment technique requirement  for which the
exemption was  granted.   The  schedule also  includes  the   implementation  of
interim control  measures including  some  which may be  required immediately,
                                      9-9

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until the required treatment facilities can be installed,  guidelines for which
are discussed in Section 9.4.
     The schedule  establishes  the most expeditious  time frame for  compliance
with  the treatment  technique requirements  that  is practical.   The  Primacy
Agency must provide public  notification  and  allow for a public hearing before
a schedule  is  implemented.   The SWTR  is  promulgated under Section  1412(c) of
the  SDWA which states  that  the  schedule  must  require  compliance  within
12 months after the issuance of  the exemption.   The Primacy Agency  may extend
the final date  for compliance  provided in any schedule  for up to three  years
after the  date of the  issuance  of the  exemption if the  public water  system
establishes that:
       -  the  system  cannot meet the  standard  without  capital improvements
          which cannot be completed in the period of the exemption.
       -  the system has entered into agreements to obtain necessary financial
          assistance.
       -  the system has entered  into  an enforceable agreement to become part
          of a regional  supply system and the system  is talcing all practical
          steps to meet the standard.
     Systems serving  less  than 500 customers and need  financial assistance,
may be  granted  an extension  of the  three  year exemption  for one or more
additional  2-year  periods  provided that  the system  establishes that is is
taking all practical steps to meet the schedule.
     As stated in  Section 9.1, EPA  believes  that in order for a system  to be
eligible to receive any extensions to the exemption period(s), the system must
be in compliance with both the monthly  and  long-term coliform  MCL and  there
must be  no  evidence linking the  system to waterborne disease outbreaks.  In
addition, systems which  are providing filtration but  whose filtration  system
does not meet  the  criteria of the  SWTR,  must also be continuing to take all
practical steps to improve  the performance of its  filtration  system in  order
to be eligible for an extension.

9.6  Notification to EPA
     The SDWA  requires  that  each  Primacy Agency  which  grants  an  exemption
shall notify EPA  of the granting of  this exemption.   The notification must
                                     9-10

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contain the  reasons  for the  exemption, including  the  basis for  the finding
that the exemption will not result  in an unreasonable risk to public health
and document  the need  for the  exemption.   The  EPA will  provide additional
details  on  the  reporting requirements  for   the   Primacy Agency   in  later
documents.
                                     9-11

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REFERENCES

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

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

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

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

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

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

Berman, D.;  Hoff,  J.C.  Inactivation of  Simian Rotavirus SA  11 by Chlorine,
Chlorine Dioxide  and  Monochloramine.  Appl.  Environ.  Microbiol,  48:317-323,
1984.

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

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

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

Clark,  R.  M.; Read,  E. J.;  Hoff,  J.  C.  Inactivation  of  Giardia lamblia by
Chlorine:  A  Mathematical  and  Statistical  Analysis.   Unpublished  Report,
EPA/600/X-87/149, DWRD, Cincinnati, OH, 1987.

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

Cotruvo, J. A.;  Vogt,   C.  D.   USEPA  Office  of  Drinking  Water,  Regulatory
Aspects of  Disinfection. AWWA Seminar Proceedings, AWWA Conference, pp. 27-32,
June, 1984.
                                      -1-

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DeWalle, F. B.; Engeset, J.; Lawrence, W.  Removal of Giardia lamblia Cysts by
Drinking  Water   Plants.    EPA-600/52-84-069,  United   States  Environmental
Protection Agency, MERL, Cincinnati, Ohio, May 1984.

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

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

Geldreich,  E.;  Nash, H.;  Reasoner,  D.;  Taylor R.   Necessity  of  Controlling
Bacterial  Populations  in  Potable  Waters:  Community  Water  Supply.   J.AWWA,
64:596-602, 1972.

Geldreich,  E.;  Greenberg,  A.;   Haas,  C.;  Hoff,  R.;  Karlin,  J.;  Means, E.;
Moser, R.;  Regunathan, P.;  Reich,  K.  and  Victoreen,  H.   Microbiological
Considerations  for  Drinking  Water  Regulation  Revisions,  Committee  Report,
Organisms in Water Committee.   JAWWA, 79(5):81, 1987.

Hibler, C. P.  Evaluation  of  the 3M  Filter 124A  in the FS-SR 122 Type 316 S/S
#150 Housing for Removal of Giardia  Cysts. Department of Pathology, Colorado
State University,  Performance Report submitted to 3M Corporation, 1986.

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

Hoff,  J.  C.  Inactivation of  Microbial  Agents by Chemical  Disinfectants.
EPA-600/52-86-067, U.S.  Environmental  Protection  Agency,  Water  Engineering
Research  Laboratory,  Drinking  Water Research  Division,  Cincinnati,  Ohio,
September, 1986.

Horn, J. B.;  Hendricks,  D. W.  Removals of Giardia Cysts  and other Particles
from Low  Turbidity Waters Using the  Culligan Multi-Tech  Filtration  System.
Engineering Research Center, Colorado State University, Unpublished, 1986.

Kelly, Gidley,  Blair  and Wolfe,   Inc.  Guidance  Manual  -  Institutional
Alternatives  for  Small   Water  Systems.   AWWA   Research  Foundation  Con-
tract 79-84, 1986.

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

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

Logsdon, G. S.; Symons, J. M.; Hoye, Jr., R. L.;  Arozarena, M. M.  Alternative
Filtration  Methods  for  Removal of  Giardia  Cysts  and  Cyst  Model.   J.AWWA,
73:111-118, 1981.
                                      -2-

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

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

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

McCabe, L.; Symons, J.;  Lee,  R.;  Robeck, G.   Study  of Community  Water Supply
Systems.  J.AWWA, 62:11:670,  1970.

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

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

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

Payment,  P.;  Trudel,   M.;  Plante, R.   Elimination  of  Viruses and  Indicator
Bacteria at  Each Step of  Treatment  During  Preparation of  Drinking Water at
Seven Water Treatment  Plants.  Appl.  Environ. Microbiol.,  49:1418, 1985.

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

Regli, S.;  Berger, P.,  (eds.).   Workshop on  Filtration,  Disinfection,  and
Microbial  Monitoring,  April  15-17,  1985,  Baltimore, MD.   EPA  570/9-87-001,
Office of Drinking Water, 1987.

Regli, S.;  Amirtharajah,  A.;  Hoff, J.;  Berger,  P.  Treatment for Control of
Waterborne  Pathogens:    How   Safe is  Safe  Enough?  In:   Proceedings,  3rd
Conference  on  Progress   in  Chemical  Disinfection,  G.E.  Janauer  (Editor),
April 3-5, 1986.  State University of New York, Binghampton, NY, in press.

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

Slezak, L. A.; Sims, R.  C.   The  Application and  Effectiveness of  Slow Sand
Filtration in the United States.  J.AWWA, 76(12):38-43, 1984.
                                      -3-

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

U. S. Environmental Protection Agency, Office of Drinking Water.  Technologies
and  Costs  for  the  Removal  of  Microbial  Contaminants  from Potable  Water
Supplies.  AWWA Water Quality Technology Conference,  November 1986.

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

World  Health Organization   Collaborating  Center.  Slow  Sand  Filtration  of
Community Water Supplies in Developing Countries.  Report of an International
Appraiser Meeting, Nagpur, India,  Bulletin  Series 16,  September 15-19, 1980.
                                     -4-

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             APPENDIX A

   USE OF PARTICULATE ANALYSIS FOR
SOURCE AND WATER TREATMENT EVALUATION
                             Reprinted from 1986 Annual
                             Conference Proceedings,  by
                             permission
                             Copyright C 1986,  American
                             Work Works Association

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                    USE OF PARTICULATE ANALYSIS FOR SOURCE
                        AND WATER TREATMENT EVALUATION
                            Jack W. Hoffbuhr, P.E.
                                Deputy Director
                           Water Management Division
                             U.S. E.P.A., Region 8
                          Denver, Colorado 8202-2413

                               John Blair, P.E.
                               District Engineer
                         Colorado Department of Health
                        Grand Junction, Colorado 81501

                               Michael Bartleson
                    Director of Water Treatment Operations
                              City of Broomfield
                          Broomfield, Colorado 80020

                             Richard Karlin, P.E.
                         Chief, Drinking Water Section
                         Colorado Department of Health
                            Denver, Colorado 80220
     Coliform bacteria  and  turbidity  have  been  traditional procedures  for

evaluating the  quality  of  source  waters and  the effectiveness  of treatment
processes.  Many water systems have used  these measures exclusively to deter-

mine  the  microbiological  quality  of  their finished water.   This sense  of

security  has  been severly  diminished  in recent  years  due to  the  increasing

frequency of  reported waterborne  disease outbreaks  where water quality  was

judged  to be  excellent by the traditional  measures.   It  is  evident  that

additional tools  are  needed to  determine the  quality  of source and  treated

waters.   The  recent enactment  of  the  1986  Amendments  to the Safe  Drinking

Water Act (SDWA)  also highlights this  need.


Background

     Giardia Lamblia has become  a  most famous  (or infamous)  parasite  to  the

water utility industry.   Its presence  in source  waters  across the U.S.  and

role in numerous waterborne outbreaks  has:
     1.    Emphasized the importance of  the  multiple barrier  concept  in water
          treatment;
                                   -1-

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     2.   Illustrated  the  need  for  additional  techniques  to  evaluate  the
          quality of water; and
     3.   Caused  a  major  increase  in  sampling  and  analysis  for  Giardia
          lamblia.
     These points  were clearly emphasized  in  epidemiological and  engineering
 studies  conducted  by  the  Colorado Department  of Health  (1).   These  studies
 also  indicated that all  surface waters  are susceptible  to contamination by
 Giardia.  As  a result,  the Department of Health adopted regulations  requiring
 filtration of  all surface water sources.
     Ground water  sources weren't  included since it was  felt  that  they were
 protected by the natural barrier provided by the layers of earth.   However, it
 quickly became apparent that not all ground waters are created equally.  Wells
 and  springs  that  are  properly  sited,  designed  and  constructed  certainly
 provide  a  larger  degree  of  protection from  contamination  due  to  surface
 influences.   However,  many  alluvial  wells  plus wells  and springs  that  are
 poorly constructed don't provide that same  level of protection.
     Infiltration  galleries fall  into  a gray  area  since  they  can  collect
 surface  and ground  water.  In  most cases,  they  are heavily  influenced by
 surface water conditions.
     It was clear  that a  technique was needed to  determine if the  so-called
 ground  waters  were  susceptible  to  surface  water  and,  therefore,  Giardia
 contamination.   Sanitary  surveys  can  identify problem  areas  and  potential
 pathways  of  contamination but  aren't  conclusive  evidence.    Turbidity  and
 coliform results,  as shown by  the previous study  aren't  reliable indicators
 (1).
     Sampling  to determine the presence  of only Giardia  cysts isn't  helpful
 either  since   not  finding  Giardia in  a single sample  doesn't  obviate  the
potential for contamination.  However, the sampling and analysis procedure  for
 Giardia  does   offer  a  useful  alternative.   A variety  of  other  particulate
matter is trapped  on the sampling  filter and  appears on the microscope slide
 along  with  any Giardia  cysts.   These particulates can  be  identified  and
evaluated to provide a valuable insight into the quality of  the water.
     To further explore the usefulness  of this procedure the Colorado  Depart-
ment of Health conducted  a study of 70 water systems in Colorado.  (A  special
                                   -2-

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study examined 10 systems in depth  (2)).   The Region 8 office of the Environ-
mental Protection Agency conducted a  study of 80 systems in Wyoming using the
same procedures  (3).   The  objectives  of  the  studies  were  to  (1) identify
particulate types  that, by their  presence  in water, indicate  surface water
contamination and  (2)  to determine the  efficacy of  water  treatment systems.
This paper discusses  the results obtained pertaining primarily  to  the first
objective.

Methods
     The 150 systems selected  for the studies included surface water sources,
wells, springs and infiltration galleries.  This paper presents the results of
16 systems  representing a cross-section of both  studies.
     Untreated source   water  was  sampled  at each  site  using  a  one micron
cartridge  filter  apparatus  and  the  protocols for pathogenic  protozoans de-
scribed in  the 16th edition of Standard methods  (4).  All samples were shipped
packed in  ice and analyzed within 48 hours.   The Colorado  samples  were an-
alyzed by the Health Department's Parasitology Laboratory.  Split samples were
analyzed by   Dr.  Charles Hibler at  Colorado  State  University  for  quality
control.   The Wyoming samples  were  all analyzed by Dr.  Hibler.   In  all cases
the  particulate  analysis  was  conducted  using  the  zinc  sulfate  flotation
techniques  (4,5).  This procedure  does not produce  100  percent cyst recovery
or precise particulate  analysis, but it  does provide  results which provide
invaluable  information about the quality of the  sampled water.
     The particulate analyses  provided results  for  14 particulate  categories
which have been  summarized into 12 groups for  purposes of  this paper.   The
particulates, except for Giardia, were enumerated using the general quantities
shown in Table 1.   For  Giardia  cysts the  numbers  shown are estimated total
numbers of  cysts  in the samples.

Discussion  of Results
     The particulate categories  shown in Table  2  constitute  a broad spectrum
of what  could be found in  water.   Not all  of them  are good  indicators of
surface water contamination of ground water.   By considering these categories
in detail a more  concise list  of possible indicators can be developed.
                                   -3-

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Sediment  -  Includes all the particulate  matter in a sample.   Since
this group  is so inclusive, it is not a good indicator.

Amorphous Debris  - Consists of  pieces of  silica,  decaying vegeta-
tion,  micro-organisms and  unrecognizable matter  with a  wide size
range.  Since  this material is  non-specific and  ubiquitous in all
water  sources it is not a good indicator.

Algae  - Comprises  a large  group  of  microorganisms which have a wide
variety of  sizes and shapes.   Algae have been found in all  types of
water  sources, therefore, as a group they are not a good indicator.

Diatoms - A particular type of  algae that  contain  silica in  their
cell walls.   Since diatoms require sunlight they are  not  normally
found  in ground water, therefore they are a good indicator.

Plant  Debris -  This category consists of undigested fecal  material
from herbivorous mammals such as beavers and muskrats.  This catego-
ry  should  be  an  excellent indicator of  animal  activity  in the
watershed and of surface water influence.

Giardia  -  This  infamous  protozoan pathogen  ranges  in  size  from
7-14 microns.   The organism  is transported by  beavers,  muskrats,
dogs,  humans and  other mammals.  In  the cyst  form  the organism is
fairly resistant to environmental conditions and chlorine.  Giardia
cysts are excellent indicators of surface water influence.

Free-living and Parasitic  Nematodes - Worm-like microorganisms that
can exist in a  wide variety of  water  environments including filter
beds, infiltration galleries and wells, therefore, they are  not good
indicators.

Coccidia - Host specific parasites  found in animals  and fish.  They
range in size from 10 to 20 microns and make excellent indicators of
surface water influence.

Pollen -  Powder-like material produced  by plants and  found every-
where, therefore not a good indicator.

Protozoa  (other than Giardia cysts)  - Microorganisms which live in a
variety of water sources, therefore they are not good indicators.

Crustacea - Large microorganisms ranging in size from 250 to 500 mi-
crons, with eggs   from  50  to 150 microns.   Since they can  live in
many types of water sources they are  not good indicators of surface
water  influence.    However,  their  presence in finished  water can
indicate poor treatment performance.

Insects - This  category includes insects,  insect  parts,  larvae and
eggs.  Since many  insects live in or  near surface water they can be
good indicators.
                         -4-

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       -  Rotifers  - Microscopic  animals  commonly  found  in  surface waters
          ranging  in size from 150  - 600 microns.   They require sunlight so
          are good indicators of surface water influence.
     Based on these points, the list of  particulate types  that can indicate a
surface water  impact on  ground water are  shown  in Table 3.  A  key  to their
usefulness is that they are the same size or larger  than  Giardia cysts.  If
they are  not  removed by  natural processes in the  earth or by treatment pro-
cesses, Giardia  cysts probably would not be removed either.   Therefore, the
presence  of  these  indicator  particulates  in  wells, springs,  infiltration
galleries or treatment  plant effluents indicates that these water systems are
also at risk of becoming contaminated by Giardia cysts.
     The particulate  data from the studies were reviewed to determine if the
above reasoning  was  valid.  Table 4  shows data  from  16 of the water systems
surveyed.  The symbols used are the same as those in  Table  1.
     The  streams contained  a broad spectrum of  all the  particulate  types
including Giardia  cysts.   The influence of animals  on these  sources is in-
dicated by the presence of plant  debris,  coccidia and Giardia.   It  is clear
that if adequate treatment isn't provided to these  sources  that the respective
water systems would be at risk.
     The infiltration galleries  (except for gallery  5) also contained a wide
range of  particulate matter including plant  debris  and Giardia  cysts.   This
indicates that little filtering action was being accomplished by galleries 6,
7, and 8.  These installations had collection systems  buried from a few inches
to  about six feet  below  the streams.    Gallery 5 had  a   collection system
constructed 10 feet  deep  and  20  feet away from and parallel to  the stream
which allowed for  better  filtration.  Many times  infiltration galleries are
constructed as   low  cost  alternatives  to more  complete  treatment.  It  is
evident that such installations may be providing a  false sense of security.
     The well data indicate a much  different pattern.  The  wells  only con-
tained a few particulate types and, with the exception of well 12, none of the
types indicated  surface water  intrusion.   The characteristics of these wells
are  listed  by Table 5.   Wells 9   and 11  would  have  the  most potential for
contamination (assuming the geologic  formations  are roughly the same and good
construction practices were followed) since they are closest to surface water.
                                   -5-

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Well 12  did exhibit  some plant  debris and  should be  investigated  further.
Well 9  showed  the smallest amount  of particulate matter.   However, a  sample
taken during the  spring runoff  contained plant debris and Giardia  cysts which
illustrate  an  important  consideration.   Since  surface  water  quality can
fluctuate widely, judgments based on one sample can lead  to  serious errors.
     The  springs  showed even  less  particulate  matter  than   the   wells.
Spring 14 did  contain  rotifers and  spring 16  some  plant  debris  indicating
surface  water  influence.  The  sanitary  surveys  revealed  that the  catchment
areas in both cases were not fenced and there was evidence of heavy animal and
human traffic,  illustrating the importance of proper source  protection.
     Overall,  the data  support the  indicators  shown by  Table 3.   The six
particulate types  are present  in surface waters and  absent in properly pro-
tected ground waters.  The results  of these studies indicate that  particulate
analysis can provide an excellent tool in evaluating source  water quality, the
potential for  surface water  contamination of ground water  and the  effective-
ness of infiltration galleries.

Conclusions
     1.   Particulate analysis can provide valuable information for evaluating
          source water quality, the potential  for surface water contamination
          of ground waters and the effectiveness of infiltration galleries.
     2.   Diatoms, rotifers,  coccidia, plant debris,  insect parts  and Giardia
          cysts are valid indicators  of surface water contamination of  ground
          water systems.
     3.   Infiltration galleries  are  providing a  false  sense  of  security in
          many instances  particularly  if the  collection system  is directly
          under the stream.   Infiltration galleries must be carefully  evalu-
          ated to determine if treatment beyond chlorination is needed.
     4.   Sampling for particulate  analysis should be  done seasonally to gain
          an understanding of the fluctuation of surface water  quality and the
          impact on ground water.
     5.   Particulate analysis can also provide  information on the  effective-
          ness  of water treatment processes in removing particulate matter.
Acknowledgements
     The  authors  express their sincere  thanks to  Mr. Kurt Albrecht  of the
Colorado Department of Health's  Laboratory Division and Dr.  Charles Hibler and
                                   -6-

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his staff at Colorado State University's Pathology  Laboratory.   Mr.  Albrecht

spent many  hours  analyzing  the  samples.  Dr. Hibler  and his staff  analyzed

numerous samples and provided expert advice on the studies.


References

     1.    Karlin,  R.V. and Hopkins, R.S., "Engineering Defects Associated With
          Colorado Giardiasis  Outbreaks June 1980  - June 1982."   Proc.  AWWA
          ACE,  Las Vegas, Nev. (June 1983).

     2.    Bartleson, M.E.   "Particulate Indicators  for  Assessing  Protected
          Ground  Water  Sources  and  Water  Treatment  Efficacy."   Report  to
          Colorado Dept. of Health, Denver, Co.  (June 1986).

     3.    Wiley, B.R.,   Barman, D.J.,   and  Benjes, Jr., H.H.    "Survey   and
          Evaluation of 80 Public Water Systems in Wyoming - Project Summary."
          Culp/Wesner/Culp, Denver, Co.  (January 1986).

     4.    Standard Methods for the  Examination of Water  and  Wastewater,  APHA,
          AWWA & WPCF, Washington, D.C.  (16th ed., 1985)-

     5.    Logsdon, G.S.,  et.  al.    "Control  of  Giardia  Cysts By  Filtration:
          The Laboratory's Role."  Proc.  AWWA WgTC,  Norfolk, Va.  (December
          1983).
                                   -7-

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                   TABLE 1




 PARTICULATE ANALYSIS QUANTITY DESIGNATIONS
Symbol
EH
H
M
S
0
R
VR
T
Verbal Rating
Extremely heavy
Heavy
Moderate
Small
Occasional
Rare
Very rare
Trace
Description
4 or more particles per microscope
field
3 particles per microscope field
2 particles per microscope field
1 particle per microscope filed
1 particle every 3 or 4 microscope
fields
2 to 3 particles in entire slide
1 particle in entire slide
Visual observation, typically used
                          only for sediment




None                      Not detected

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                            TABLE 2




                 SUMMARY OF PARTICULATE TYPES







Sediment                                 Coccidia




Large Amorphous Debris                   Pollen




Fine Amorphous Debris                    Protozoa




Algae                                    Crustacea




Diatoms                                  Insect Parts & Larvae




Plant Debris                             Rotifers




Giardia




Free Living & Parasitic Nematodes

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                    TABLE 3




  PARTICIPATE TYPES INDICATING SURFACE WATER







Diatoms                  Plant Debris




Rotifers                 Insect Parts & Larvae




Coccidia                 Giardia

-------
            TABLE 4




RESULTS OF PARTICULATE ANALYSES
Source
Infiltration
Particulate Type

Amorphous Material
Protozoa
Algae
Diatoms
Plant Debris
Nematodes
Rotifers
Crustacea
Coccidia
Insect Parts
Pollen
Giardia Cysts
Streams
1
H
T
T
H
O
T
N
N
T
R
N
4
2
M
T
T
T
O
M
N
T
T
VR
N
20
3
O
R
R
0
H
N
R
R
R
R
N
98
4
0
R
O
O
S
O
R
O
N
O
O
129
Galleries
5
M
T
M
R
0
T
N
N
N
R
N
N
6
M
T
H
H
T
T
N
T
R
H
T
80
7
M
T
EH
T
T
T
R
N
N
N
N
20
8
O
N
R
O
M
0
N
O
O
O
0
71
9
S
N
T
N
N
N
N
N
N
N
N
N
Wells
10
M
R
H
N
N
O
N
N
N
N
N
N
11
S
R
N
N
N
N
N
N
N
N
N
N
12
H
T
N
N
T
N
N
N
N
N
N
N
13
R
R
T
N
N
N
N
N
N
N
N
N
Springs
14
R
N
N
N
N
N
R
N
M
N
N
N
15
O
R
O
N
N
N
M
N
N
N
O
N
16
T
N
N
N
T
T
N
N
N
N
T
N

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       TABLE 5




WELL CHARACTERISTICS
Source
9
10
11
12
Depth, ft.
100
40
60
72
Distance From Stream, ft.
20
300
20
100

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            APPENDIX B
INSTITUTIONAL CONTROL OF LEGIONELLA

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                                  APPENDIX B
                      INSTITUTIONAL CONTROL OF LEGIONELLA

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

Monitoring
     It is suggested that hospitals,  and other institutions with potential for
the  growth  of  Legionella,   conduct  routine monitoring  of   their hot  water
                                      B-l

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

Treatment
     Because  the  primary  route  of   exposure   to  Legionella  is  probably
inhalation,  rather  than  ingestion,  it  is  recommended  that  disinfection
procedures include an initial shock treatment period to disinfect shower heads
and hot water taps where the bacteria  may colonize  and later become airborne.
The  shock treatment  period should  also  include  disinfection of hot  water
tanks.  After this time, a point-of entry treatment system can be installed to
provide continual disinfection of the hot water system.
     Initial Disinfection
     The most  applicable method for the initial disinfection of shower heads
and water  taps is  heat eradication.   The  fittings can be removed and held at
temperatures greater than  60 C for  at least 24 hours.  Disinfection of fit-
tings can also  be achieved  by  soaking  or  rinsing with  a  strong  chlorine
solution.  When  soaking the fittings,  a minimum chlorine strength of 50 mg/L
should be  used for a period of no less than 3 hours.   Rinsing with chlorine
should be performed with more  concentrated solutions.   Care must be taken not
     1.   Monitoring frequency based on the reported rate of Legionella
          regrowth observed during disinfection studies  (USEPA, 1985).
                                      B-2

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to  corrode  the  finished  surface on  the  fittings.   Commercially  available
bleaches,  for example, are typically 5.25 percent chlorine by weight.
     Long-Term Disinfection
     Heat - Numerous studies have shown that increasing the hot water tempera-
ture to  50  -  70  C over  a period  of several  hours may  help to  reduce  and
inhibit Legionella populations.   However, some instances  of  regrowth  after 3
to  6 months  have  been reported.  In  these cases, the authors have concluded
that a periodic schedule of short-term temperature  elevation  in the hot water
may be an effective control against legionellosis (USEPA, 1985; Muraca, 1986).
Disinfection by this  method  also requires periodic  flushing of  faucets  and
shower heads with hot water.  Although heat eradication  is easily implemented
and relatively inexpensive, a disadvantage  is  the potential need for periodic
disinfection.  The potential  for scalding  from the unusually hot  water also
exists (USEPA, 1985;  Muraca, et al.  1986).
     Chlorination   -   Several  studies  have  suggested that  a free  chlorine
residual of  4 mg/L will  eradicate  Legionella  growth.   There is,  however, a
possibility  for  recontamination  in  areas  of  the  system where  the chlorine
residual drops below this  level.  A stringent  monitoring program is therefore
required to  ensure that  the  proper  residual is  maintained throughout  the
system and under varying flow conditions.  It may also be necessary to apply a
large initial chlorine dose to  maintain  the 4 mg/L residual.  This may cause
problems of  pipe  corrosion and,  depending on  water  quality, high  levels of
trihalomethanes (THMs).
     Ozone -   Ozone is  the most  powerful oxidant used in  the  potable water
industry.  One study indicated that  an ozone dosage of 1  to 2 mg/L was suffi-
cient to provide a 5 log reduction of Legionella  (Muraca, et al. 1986).  Ozone
is generated by passing a high voltage current of electricity through a stream
of  dry  air  or oxygen.   The use  of high voltage electricity requires proper
handling to  avoid creating  hazardous conditions.   The  ozone is  applied by
bubbling the  ozone containing  gas  through  the water in a  chamber called a
contactor.
     One of the disadvantages of this system is its complexity.  It requires a
dry air or oxygen  source, a generator, and a contactor sized to provide 2 to 5
minutes of  contact  time  and an  ambient  ozone  monitor.   All  materials in
                                      B-3

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contact with  the ozone  must be constructed  of special  ozone resistant mat-
erials to  prevent leakage.   Leak  detection is  also required  because of the
toxic nature of ozone and possible explosive conditions if pure oxygen is used
for generation.
     Another disadvantage  of ozonation  is the  rapid decomposition of ozone
residuals.  The  half-life  of ozone in drinking water is typically around 10
minutes.   This makes  it  difficult, if not  impossible,  to maintain  a  residual
throughout  the  water system  and may  require  the  use  of  a  supplementary
disinfectant such as  chlorine or heat.   For  these reasons  it is not  thought
that ozonation is viable for institutional applications.
     Ultraviolet Irradiation  -  Ultraviolet  (UV)  light,  in  the 254 nanometer
wavelength range  can be used as a disinfectant.  UV systems typically contain
low-pressure mercury  vapor  lamps  to maximize  output  in  the 254  ran range.
Water entering the unit passes through a  clear cylinder while the lamp is on,
exposing bacteria  to the  UV light.  Because  UV  light  can not  pass through
ordinary window  glass,  special  glass or  quartz sleeves are  used  to assure
adequate exposure.
     The  intensity  of UV  irradiation is measured  in microwatt-seconds  per
square centimeter (uW-s/cm2).  Several studies have  shown a 90 percent reduc-
tion of Legionella with a UV dosage of 1000 -  3000 uW-s/cm2, compared to 2000
to 5000 uW-s/cm2 for E. coli,  Salmonella and Pseudomonas  (USEPA,  1985).   In
another  study,  a  5  log  reduction  of   Legionella was  achieved   at 30,000
uW-s/cm2;  and  the reduction was more rapid than with both ozone and  chlorine
disinfection (Muraca,  et al. 1986).
     The major advantage of UV disinfection is that it  does  not require the
addition of chemicals.  This eliminates the storage  and feed problems associ-
ated with the use of chlorine, chlorine dioxide and chloramines.  In addition,
the only maintenance  required is periodic  cleaning  of the  quartz  sleeve and
replacement of bulbs.   UV monitors  are  available  which  measure  the light
intensity  reaching  the  water  and  provides  a  signal  to   the   user  when
maintenance  is  required.   These  monitors  are  strongly  suggested  for  any
application of UV irradiation for disinfection.   It  should be noted, however,
that these monitors measure light  intensity which may not be directly related
to disinfection  efficiency.  The  UV  lamps should therefore  not be  operated
past the manufacturers use rating even with a continuous UV monitor  installed.
                                      B-4

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     Another disadvantage  of UV  disinfection,  as with  ozonation, is  that a
residual  is not  provided.  A  supplementary disinfectant may  therefore  be
required to provide protection  throughout  the system.   In addition, turbidity
may interfere with  UV disinfection  by  blocking the passage  of light  to the
microorganisms.
     Other Control  Methods - In  addition  to chemical and heat disinfection,
there are system modifications which can be made to inhibit Legionella growth.
Many institutions have large hot water tanks heated by coils located midway in
the tank.  This  type of design may result in areas near the bottom of the tank
which are not hot enough  to  kill Legionella.  Designing  tanks  for more even
distribution of  heat  may  help  limit bacterial  colonization.  In addition,
sediment build-up in  the  bottom of  storage  tanks  provides  a  surface  for
colonization.   Periodic draining and  cleaning  may  therefore  help  control
growth.   Additionally,  other studies have  found  that  hot water systems with
stand-by hot water tanks used for meeting  peak  demands,  still tested positive
for  Legionella  despite  using  elevated  temperature  (55 C)   and chlorination
(2 ppm)   (Fisher-Hoch,  et al. 1984.)   Stringent procedures for  the cleaning,
disinfection and  monitoring  of these  stagnant tanks  should be  set  up  and
followed on a regular basis.
     In  another study,  it  was reported that black rubber washers  and gaskets
supported Legionella  growth  by providing  habitats  protected from heat  and
chlorine.  It was found, after replacement  of  the black  rubber washers with
Proteus  80  compound  washers, that  it was  not  possible   to detect Legionella
from any of the  fixtures (Colbourne, et al. 1984).

Conclusions
     Legionella  bacteria have  been  identified as  the  cause of  the  disease
legionellosis,   of  which  the  most   serious form  is  Legionnaires  Disease.
Although  conventional  water  treatment practices  are sufficient   to  provide
disinfection of  Legionella, regrowth   in  buildings  with   large hot  water
heaters, and especially with recirculating hot water systems,   is a significant
problem.  This  problem  is  of particular concern  to  health care institutions,
such as  hospitals, where patients may be more susceptible to the disease.
                                      B-5

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     This guideline suggests a program of quarterly monitoring for Legionella.
If the monitoring program suggests a potential problem with these organisms, a
two stage disinfection program is suggested consisting of an initial period of
shock treatment followed by long term disinfection.
     Four methods of disinfection for the control of Legionella were presented
in this appendix; heat,  chlorination,  ozonation, and ultraviolet irradiation.
All  four  of  the  methods  have  proven  effective  in  killing  Legionella.
Ultraviolet  irradiation  and  heat eradication  are the  suggested methods  of
disinfection  due,  primarily,  to advantages  in  monitoring and  maintenance.
However, site specific factors may  make chlorination or  ozonation more feas-
ible  for  certain  applications.   In  addition,  it  is  recommended  that  all
outlets, fixtures and shower  heads  be inspected and  all  black rubber washers
and  gaskets  replaced  with materials which  do  not  support the growth  of
Legionella organisms.
     One problem associated with the application  of  point-of-entry  treatment
systems is the lack of an  approved program for certifying performance claims.
However,  the  National  Sanitation   Foundation   (NSF),  Ann  Arbor,   MI  an
unofficial,   non-profit  organization, does  have a  testing program  to verify
disinfection efficiencies and materials of construction.  Certification by the
NSF,  or  other  equivalent  organizations,  is  desirable  when  selecting  a
treatment system.

References
Colbourne,  J.;  Smith,  M.  G.;  Fisher-Hoch, S.  P.  and  Harper,  D.   Source  of
Legionella pneumophila Infection in a  Hospital Hot Water  System:   Materials
Used  in Water  Fittings  Capable of  Supporting L. pneumophila  Growth.   In:
Thornsberry,  C.; Balows,  A.;  Feeley, J. C.  and Jakubowski, W.   Legionella  -
Proceedings  of  the  2nd  International   Symposium.    American   Society  for
Microbiology, pp. 305-307,  1984.
Fisher-Hoch,  S.  P.; Smith,  M.G.; Harper,  D.  and Colbourne,  J.  Source  of
Legionella  pneumonia  in  a   Hospital  Hot  Water   System,   pp. 302-304  in
Thornsberry,  C.;  Balows,  A.;  Feeley,  J.C.  and  Jakubowski,  W.   Legionella
Proceedings  of  the  2nd  International   Symposium,    American   Society  for
Microbiology, pp. 302-304,  1984.
                                      B-6

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Muraca,  P.; Stout,  J.  E.  and Yu, V.  L.   Comparative Assessment  of Chlorine,
Heat,  Ozone, and  UV Light  for  Killing Legionella pneumophila Within  a Model
Plumbing System.   Appl. Environ. Microbiol. 53(2):447-453, 1986.

U.S. Environmental  Protection Agency, Office  of Drinking Water.   Control of
Legionella in Plumbing Systems, Health Advisory  (1985).
                                       B-7

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APPENDIX C

TRACER TEST
PROCEDURES

-------
                                  APPENDIX C
                            TRACER TEST PROCEDURES

Introduction
     The detention time  (T)  used  for  determining the CT in a pipeline can be
calculated theoretically  assuming  plug flow  through the pipe  at  peak hourly
flow.  However,  in mixing basins and storage reservoirs, the contact time must
be  determined  by  tracer  studies.   This  appendix  presents  procedures  for
performing the  required tracer studies in order to determine the contact time.
     Separate tests are  recommended for mixing basins  and  storage reservoirs
because of the  magnitude of difference in detention times between the two, and
because of  the practical difficulties  which may  arise from  simultaneously
operating both units under worst-case  conditions.  Except for  differences in
operating conditions,  the procedures for performing tracer tests in both units
are similar.

Test Frequency
     Because detention time  (T) is  proportional  to flow rate (Q)  it is neces-
sary to develop a  relationship between these parameters which  can  be  used to
determine T  under  peak hourly  flow conditions.   It  is therefore  recommended
that tracer tests  be performed at  several  (at least  4)  flow rates.  The flow
rates tested should be  separated  by  approximately equal intervals with one
point near  average flow, two  greater than  average,  and one  at a  less than
average flow.  The flows should also be selected  so  that it is not necessary
to extrapolate  to more than 110 percent of the highest flow tested.
     Detention  time may also be influenced by differences in water temperature
within the  treatment plant.   For plants with potential for thermal stratifi-
cation, additional tracer studies  are suggested under the  various seasonal
conditions which are likely to occur.
     Similar procedures  should be  used for developing  a Q  vs.  T relationship
in storage tanks,  with  the  additional constraint that  the  water  level in the
tank should  be  maintained at  a near  constant  level during  the  test period.
The  detention  time determined by  the tracer tests will  only be  valid for
                                      C-l

-------
calculating CT  when the  tank  is operating  at water  levels greater than or
equal to the level at which the testing was performed.
     The contact times that  have been determined by the tracer studies under
the various seasonal conditions should remain valid for as long as no physical
changes are made to the mixing basin(s) or storage reservoir(s).

Tracer Selection
     The first  step  in  any tracer test  is  selection  of a chemical  to use as
the  tracer.   The  most  common  tracers used  in  drinking  water plants  are
chloride,  rhodamine  Wt,   and fluoride.  All  of  these chemicals  are readily
available,  conservative (i.e., they are  not consumed  or removed during treat-
ment) , approved for  potable  use, and easily monitored.   Fluoride is probably
the most frequently used tracer for potable water applications.

Tracer Addition
     There  are two common methods of  tracer addition  employed in water treat-
ment evaluations.   They are:
       -  The slug dose method
       -  The step method

     With the slug dose method,  a large  instantaneous  dose of tracer is added
to  the  water and  timed  as  it  passes through  the mixing  basin or storage
reservoir.    A  disadvantage  of  this technique  is   that  very  concentrated
solutions are needed for the dose.  Intensive mixing may therefore be required
to minimize potential  density-current effects.  Alternatively, with the step
method,  which  is discussed  in  this  appendix, tracer addition  is   continued
until the concentration at the desired end point reaches a steady state level,
typically two to three times the theoretical detention time  (Hudson,  1981).
     The tracer should be added at the  same  point in the treatment train as
the disinfectant to be used  in the CT calculations.   If multiple disinfection
points are used, the tracer should be added at the earliest  (farthest up-flow)
application point.   For  testing storage  reservoirs,  the  tracer  should  be
applied as close to  the  tank influent as possible.  In all  cases, the tracer
should be  dosed  in sufficient  concentration  to easily  monitor a residual
throughout the test.
                                      C-2

-------
Data Collection
     Beginning at  time zero  (when tracer  addition begins)  tracer residuals
should be  monitored  at  all points  where  the  disinfectant  residual  will be
measured for CT calculations.   For plants with multiple points of application
for the disinfectant(s),  the  residual should be  monitored just prior to each
application point.  The sampling  frequency  at each point should be sufficient
to adequately define a plot of residual versus time.  Sampling  should continue
until the residual concentration levels off at a constant value.

Data Reduction
     The results of each tracer test  can  be summarized  in a table of time and
residual concentration.   The  residual concentration  (C)  should be normalized
by dividing by the applied  tracer  concentration  (C )  and plotted versus time,
as illustrated on Figure C-l.   The detention time to be used  in calculating CT
is the time corresponding to C/C  = 0.10.  Ninety percent of  the water passing
through the system will  have a detention time greater than  or equal  to this
value (Levenspiel, 1972).
     Detention times  should be  determined by the  above procedure for  each of
the flow rates tested.  The detention times should then be plotted versus flow
rate as shown on Figure C-2.  This plot of Q vs.  T is what should be  used to
determine T for daily compliance with the CT requirements.

References
Hudson,  H.  E.,  Jr.   Water Clarification  Processes;   Practical Design  and
Evaluation, Van Nostrand Reinhold Company, New York, 1981.
Levenspiel, O.  Chemical  Reaction Engineering,  John Wiley & Sons, New  York,
1972.
                                      C-3

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      1.0

      0.8
 C    0.6
Co
      0.4

      0.2
T - 90 MIN
             30    60   90   120  150  180   210  240
                            TIME (MIN)

           FIGURE C-1    TRACER TEST RESULTS

-------
(MIN)
     200,-
      150
      100
      50
           AVERAGE
       MAXIMUM
       EXTRAPOLATION
                        345
                          Q (MGD)
6
8
         FIGURE C-2   DETENTION TIME VS.  FLOW

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                      APPENDIX D

A SURVEY OF THE CURRENT STATUS OF RESIDUAL DISINFECTANT
MEASUREMENT METHODS FOR ALL CHLORINE SPECIES AND OZONE
                                      Copyright ® 1987 by American
                                      Water Works Association
                                      Research Foundation and
                                      American Water Works
                                      Association
                                      Reprinted by permission of
                                      AWWA Research Foundation

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A SURVEY OF THE CURRENT STATUS OF RESIDUAL DISINFECTANT
MEASUREMENT METHODS FOR ALL CHLORINE SPECIES AND OZONE
                          by
                    Gilbert Gordon
                Department of Chemistry
                   Miami University
                   Oxford, OH 45056
                   William J. Cooper
            Drinking Water Research Center
           Florida International University
                 Miami , Florida 33199
                      Rip G. Rice
                  Rice,  Incorporated
                Ashton,  Maryland 20861
                   Gilbert E. Pacey
                Department of Chemistry
                   Miami University
                  Oxford, Ohio 45056
                     Prepared for:

               AWWA Research Foundation
                 6665 W. Quincy Avenue
                   Denver, CO 80235
                     November 1987
   Published by the American Water Works Association

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                          DISCLAIMER
This study was funded by the American Water Works Association
Research Foundation (AWWARF).  AWWARF assumes no responsibil-
ity for the content of the research study reported in this
publication, or for the opinions or statements of fact
expressed in the report.  The mention of tradenames for
commercial products does not represent or imply the approval
or endorsement of AWWARF.  This report is presented solely
for informational purposes.

Although the research described in this document has been
funded in part by the United States Environmental Protection
Agency through a Cooperative Agreement, CR-811335-01, to
AWWARF, it has not been subjected to Agency review and
therefore does not necessarily reflect the views of the
Agency and no official  endorsement should be inferred.
                       Copyright » 1987
                              by
     American  Water Works  Association Research Foundation
                       Printed in U.S.

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                                  FOREWORD
This report is part of the on-going research program of the AWWA Research
Foundation.  The research described in the following pages was funded by
the Foundation in behalf of its members and subscribers in particular and
the water supply industry in general.  Selected for funding by AWWARF's
Board of Trustees, the project was identified as a practical, priority need
of the industry.  It is hoped that this publication will receive wide and
serious attention and that its findings, conclusions, and recommendations
will be applied in communities throughout the United States and Canada.

The Research Foundation was created by the water supply industry as its
center for cooperative research and development.  The Foundation itself
does not conduct research; it functions as a planning and management
agency, awarding contracts to other institutions, such as water utilities,
universities, engineering firms, and other organizations.  The scientific
and technical expertise of the staff is further enhanced by industry
volunteers who serve on Project Advisory Committees and on other standing
committees and councils. -An extensive planning process involves many
hundreds of water professionals in the important task of keeping the
Foundation's program responsive to the practical, operational needs of
local utilities and to the general research and development needs of a
progressive industry.

All .aspects of water supply are served by AWWARF's research agenda:
resources, treatment and operations, distribution and storage, water
quality and analysis, economics and management.  The ultimate purpose of
this effort is to assist local water suppliers to provide the highest
possible quality of water, economically and reliably.  The Foundation's
Trustees are pleased to offer this publication as contribution toward that
end.

This project reviewed all disinfectant residual measurement methods for
free chlorine, chloramines, ozone and chlorine dioxide with special
attention to interferences that could be experienced by the water utility
industry.  Recommendations, practical guidance, and cautions on the
selection of appropriate residual measurement techniques are summarized
(Please see Preface for information on full report).
Je/ome 3. Gi Ibert                     (""Jajpes F. Manwanng, P.E.
Caiman, Board of Trustees           ^-fxecutive Director
AWWA Research Foundation                 AWWA Research Foundation

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                                PREFACE
This document summarizes the AWWA Research Foundation's 816 page
publication "Disinfectant Residual Measurement Methods."  That
publication (Publication Number 90528) can be ordered from the AWWA
Customer Services Department, 6666 W. Quincy Avenue, Denver, CO 80235;
telephone, (303) 794-7711.

The purpose of this summary document is to provide the water utility
laboratory analyst with guidance in selecting disinfectant residual
measurement methods.  Either this document or the full report is
recommended as a companion to Standard Methods for the Examination of
Water and Wastewater.

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                              ACKNOWLEDGEMENTS
The authors wish to express their appreciation to the American Water Works
Association -  Research Foundation for the opportunity to carry out this
detailed review of the literature.

Furthermore, the authors would like to pay tribute to the really important
people — all  those who did the original  work and made this secondary
source of information possible.

Finally, the authors wish to express their appreciation to the members of
the Project Advisory Committee:

   1)   Mark Carter, Ph.D.
       Rocky Mountain Analytical  Laboratories

   2)   J. Donald Johnson, Ph.D.
       University of North Carolina

   3)   Leown A. Moore
       Drinking Water Research Division—EPA

   4)   R. Rhodes Trussell, Ph.D.
       James M. Montgomery Consulting Engineers, Inc.
                                                   G.G.

                                                   W.J.C.

                                                   R.G.R

                                                   G.E.P-

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                              EXECUTIVE SUMMARY
BACKGROUND

    The  objective  of this Report is to review and summarize all disinfectant re-
sidual measurement techniques currently available for free chlorine (along  with
the  various   chloramines),   combined  chlorine, chlorite ion, chlorine dioxide,
chlorate ion,  and  ozone.

    Presently,  both chlorine dioxide and ozone are gaining considerable favor as
alternatives  to chlorine  disinfection (1).  The analytical chemistry  for  these
disinfectants   when compared with chlorine is even more complex and less readily
understood  as  evidenced by various surveys (2-5) and detailed  research  carried
out in various  laboratories  (6-10).

    Chlorine  dioxide is manufactured at the site of its use by reactions involv-
ing sodium  chlorite,  chlorate ion, chlorine gas and/or hypochlorite ion and sul-
furic acid  or hydrochloric acid (11-12).  Consequently, chlorate  ion,  chlorite
ion, hypochlorite  ion and/or hypochlorous acid frequently will be found occur-
ring as  by-products or unreacted starting materials.  These materials are strong
oxidizing agents which are very reactive and behave  in  many  ways  similar  to
chlorine dioxide itself.

    There are more than 2,000 water treatment plants today using ozone, and less
than half of  them  are applying ozone solely for disinfection.  The large  major-
ity  of   water   treatment plants  use ozone as a chemical oxidant.  Many of the
plants applying ozone for disinfection also are using ozone, in the same  plant,
for  chemical   oxidation.   Analyses  for residual ozone in water are applicable
only in  the treatment plant, either  in  the  ozone  contactor(s)  or  at  their
outlets.    Residual  ozone is never present in the distribution system; however,
its by-products may be.

    There have  been numerous attempts to evaluate the  relative  advantages  and
disadvantages  associated with  the  measurement of free and combined chlorine.
Different criteria are frequently used for  the  evaluation  of  the  analytical
•easurements   and   often  suggestions for the improvement of test procedures have
gone largely  ignored.  No comprehensive and objective review of  the  literature
appears   to be available. This Report is aimed at providing such a review along
with guidance and  recommendations as to what criteria water utilities should use
in selecting  residual monitoring techniques based on circumstances by category.
OBJECTIVES
    1.   To review and summarize all residual measurement techniques
        currently available for free chlorine--taking into account
        the roles of chloramines.

    2.   To review and summarize all residual measurement techniques
        currently available for combined chlorine.

-------
    3.  To briefly review the present understanding of the chlorine-
        ammonia chemistry and in particular, in relationship  to  the
        measurement of chlorine and combined chlorine.

    4.  To review and summarize all residual measurement techniques
        currently available for chlorine dioxide, chlorite ion and
        chlorate ion.

    5.  To review and summarize the analytical procedures currently
        used by operating water utilities to control ozone treatment
        processes, considering disinfection as well as the many  oxid-
        ative applications of ozone in water treatment applications.

    6.  To discuss common interferences associated with the measurement
        of each'of the disinfectants/oxidants described above (free
        chlorine, combined chlorine, chlorite ion, chlorine dioxide,
        chlorate ion, and ozone).

    7.  To provide guidance and recommendation for water utilities in
        selecting residual monitoring techniques for each of  the above
        disinfectants/oxidants.

    8.  To recommend future research for development of monitoring and
        analytical methods to improve accuracy, and reduce time  and cost
        requirements for the measurement of the above disinfectants.


    In the full report, we present as complete as possible an examination of the
world-wide body of literature on analytical methods used by   the water  utility
industry  in  order  to elaborate on the various problems, advantages, disadvan-
tages and known interferences for each of the currently used analytical methods.

    Foremost in our objectives has been a better understanding of the  reliabil-
ity of various measurements which have been carried out.  Since  there are inher-
ent limitations in all measurements, it becomes apparent that there are specific
needs  for  some  indication of the reliability of the result, i.e., what is the
precision and accuracy of the reported value, and are these acceptable?

    The volatility of most  of  the  disinfectants  makes  sampling  and  sample
handling  a  major  contributor  to  imprecision  and  inaccuracies.   "Standard
additions" is a questionable technique; it should be avoided if  possible,  since
the pipetting and dilution process causes potential loss of disinfectant.

    The relative usefulness of each method, along  with  descriptions  of  known
interferences such as turbidity, organic matter, ionic materials, solids, color,
buffering  capacity,  as  well  as the nature of the sample and  the time between
collection of the sample and the actual analysis, are described  in this  report.
It  must  be  emphasized,  however,  that  almost invariably each of the methods
described is based on  the  total  oxidizing  capacity  of  the  solution  being
analyzed  and  is  readily  subject  to interferences from the presence of other
potential  oxidizing  agents  and/or  intermediates  from  concomitant  chemical
reactions.   Under  ideal  conditions some of the methods are accurate to better

-------
than ±1%--especially in  the  absence  of  common  interferences--whereas  other
methods   are  almost  semi-quantitative  in  nature  with  many  common  species
interfering with both the precision and accuracy of the measurements.

    We have also included chlorate ion  as  a  residual  species  in  that  only
recently  have  reliable  analytical  methods  begun to appear in the literature
(5,6,10).  -We also report on the chemistry of the  chlorine-ammonia  system  and
the associated breakpoint reactions, because one of the most common inteferences
in the measurement of free chlorine is monochloramine.

    The  most important development for this report has been the decision to  in-
clude a  preliminary  section describing an "idealized" analytical method.  The
need for this section became apparent as our writing progressed describing  each
of the analytical methods for chlorine.  Specific items included in this "ideal-
ized" method  are  accuracy,  precision, reproduciblity, lack of interferences,
ease of  use of the method, lack of false positive values, and so forth.

    The  benefit of the "idealized" analytical method is to allow individual com-
parisons and to allow the choice between various  methods  based  on  individual
method  shortcomings.   For  example, a particular method might have as its only
difficulty interference by manganese and iron.  In many circumstances, this type
of interference might be a major problem.   However,  should  the  water  supply
under consideration not have any manganese or iron, it is quite likely that the
method might be very usable--and as a matter of fact  well  might  be  the  best
method of choice.

    In other cases, speed of analysis rather than  potential  interferences  (or
choice  of  some  other important characteristic) might be the guiding factor in
choosing an analytical method.  In this way rational choices can be  made  based
on potential and/or real difficulties and/or interferences and as compared to an
"idealized" method -- rather than a possibly controversial existing method.

    Table I has been constructed as a quick reference  guide  to  the  available
methods   for  the  determination of water disinfection chemicals and byproducts.
Included are pertinent analytical  characteristics  such  as  detection  limits,
working   range,  interferences,  accuracy  and precision estimates.  The current
status of the method, as gleaned from this  report,  is  given.   The  necessary
operator  skill  level  is  given to aid the laboratory manager in assessing the
manpower  requirements  for  a  particular   method.    Additional   information
concerning the reasons for the current status is contained in the Recommendation
Section  of the Executive Summary and the complete report.

    As each of the methods is described in detail in the full  report,  specific
conclusions  are drawn--along with appropriate recommendations--by comparing the
method against the "idealized" analytical method for that species.

    One  additional benefit of this direct comparison is the possibility of  add-
ing  or  subtracting a method to the list of Standard Methods for the Examination
of Water and Wastewater (13), based on a rational set of  criteria.   It  should
also  be  possible  in  the future to decide on the viability of various methods
based on their meeting specific criteria rather than based only  on  comparisons
between   analytical  laboratories  (and personalized subjective reactions to the
various  methods themselves

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 TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS®

                   Species'      DETECTION  WORKING  EXPECTED   EXPECTED
TYPE OF TEST       MEASURED        LIMIT     RANGE   ACCURACY   PRECISION  SKILL'
 (METHOD)*         DIRECTLY       (mg/L)    (mg/L)      (±  %)     (± %)     LEVEL
FREE CHLORINE

  "Ideal"       C12 + HOC1/OC1-   0.001   0.001-10    0.5       0.1       1

  UV/VISIBLE    C12 + HOC1/OC1-     - 1     1 - 100      NR       NR       3


    Continuous  C12 + HOCl/OCl'     1.5    1.5-300     NR       NR       3


  AMPEROMETRIC TITRATION:

    Forward     C12 + HOCl/OCl"   0.00181     > 10       NF       NF       2
                                0.02 - 0.032  > 10       NF     3-50     2

    Back        C12 + HOC1/OC1-   0.002       > 10     3-50     NF       2

    Continuous  C12 + HOCl/OCl"   0.005       > 10       NR       1.0      2/3


  IODOMETRIC TITRATION:

    Standard   (Total Chlorine)   0.073     0.1-10     NR       NR       2


                                  0.354     0.5-10     NR       NR       2

  DPD

    FAS Tit'n   C12 + HOCl/OGl'   0.004s    0.01-10    NF     2-7      1

                                  0.0114    0.01 - 10    NF     2-7      1

    Color'mtrc  C12 + HOCl/OCl"   0.016     0.01 - 10  1 -  15   1-14     1

    Steadifac   C12 + HOCl/OCl'   0.018     0.01-10    NF       NR      1/2


  LCV

    Black and
      Whittle   C12 + HOC1/OC1-   0.01      0.25-3     NF       NR       1

    Whittle &
      Lapteff   C12 + HOC1/OC1-   0.01      0.25-10    NR     0-10     2

-------
    TABLE  I.   CHARACTERISTICS (confd)
    STABILITY                                     FIELD               CURRENT
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE     TEST   AUTOMATED    STATUS
5 YRS
NA
NA
1-2 yrs
1-2 yrs
1-2 yrs
1-2 yrs
1 yr
1 yr
powder
stable6
powder
stable6
powder
stable6
powder
stable6
months
months
> 1 DAY
NA
NA
NA
NA
NA
NA
10 min
or less
10 min
or less
30 min
30 min
30 min
30 min
NR
NR
NONE
C1NH2 - C13N
backgnd Abs
C1NH2 - C1SN
C1NH2 - C1SN
C1NH2 - C1SN
C1NH2 - C1SN
C1NH2 - C1SN
All oxidizing
species
All oxidizing
species
C1NH2 - CljN
oxid species
C1NH2 - C13N
oxid species
C1NH2 - C13N
oxid species
C1NH2 - C13N
oxid species
C1NH2 - C13N
oxid species
Oxidizing
species
Independent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
pH Dependent
Requires
buffer
Requires
buffer
Requires
buffer
Requires
buffer
Requires
buffer
Buffering
YES
NO
NO
YES
YES
YES
YES
NO
NO
NO
NO
YES
YES
YES
YES
YES
NO
YES
YES
YES
YES
YES
NO
NO
NO
NO
NO
NO
NO
NO
RECOMMENDED
RECOMMENDED
(LAB TEST)
CONT'D STUDY
RECOMMENDED
RECOMMENDED
RECOMMENDED
RECOMMENDED
RECOMMENDED
(LAB TEST)
RECOMMENDED
(LAB TEST)
RECOMMENDED
(LAB TEST)
RECOMMENDED
(LAB TEST)
RECOMMENDED
(FIELD TEST)
RECOMMENDED
(FIELD TEST)
ABANDON
RECOMMENDED
(LAB TEST)

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    TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (cont'd)
TYPE OF TEST
 (METHOD)^
Species*      DETECTION  WORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACCURACY  PRECISION  SKILL0
DIRECTLY       (mg/L)    (mg/L)      (± %)      (±  %)    LEVEL
  FACTS

    Color'mtrc  C12 + HOCl/OCl'   0.1
  METHYL ORANGE C12 + HOC1/OC1"    NR


  0-TOLIDINE    C12 + HOC1/OC1-    NR

  3,3'-DIMETHYLNAPHTHIDINE        ^

                C12 + HOC1/OC1-   0.05


  0-DIANISIDINE C12 + HOCl/OCl"   0.1

  CHEMILUMINESCENCE

    Hydrogen
    Peroxide    C12 + HOC1/OC1"    NR
                         0.25 - 10  5 - 20   1-11
    Spect'photo C12 + HOCl/OCl"   0.012     0.05-10    NF
    Luminol     OCL"


    Lophine     OCL"

  ELECTRODE METHODS

    Membrane   HOCL
               0.0007
               0.14
                             NR
                             NR
                             NR
                             NR
                             NR
    NR
             NR
             NR
             NR
             NR
             NR
NR
0.2 - 20     NR
                                               NR
         NR
         NR
       2 - 6
         NR
         NR
NR
         NR
               0.004     0.04-1     NR      1.6
        2/3
        2/3
    Bare-wire   C12 + HOC1/OC1"   0.1       0.1-3      NR     1-25
    Potent'mtrc C12 + HOC1/OC1'    0.005     0.01-1    1-6   7-10     2
    Agl
    Volt'mtrc   C12 + HOCl/OCr    0.01      0.1-10     NR
                                               NR

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   TABLE I.  CHARACTERISTICS  (confd)
    STABILITY
REAGENT   PRODUCTS    INTERFERENCES    pH RANGE
                                      FIELD               CURRENT
                                      TEST   AUTOMATED    STATUS
 2 years7  30 min      Oxidizing
          at high  C13   species

 2 years7  30 min      Oxidizing
          at high  C12   species
  NF
  NF
NF
NF
Oxidizing
 species

Oxidizing
 species
Buffering
 critical

Buffering
 critical

Buffering
 required

Buffering
 required
                                      YES      NO      RECOMMENDED
                                      YES      NO      RECOMMENDED
YES      NO        ABANDON
YES      NO        ABANDON
  NF     15-20 min   Oxidizing
                      species
  NF     55 min
         Oxidizing
          species
                           NR
                  NR
                             NO
              NO
                       NO
         NO
                   ABANDON
ABANDON
  NR
            sec
         None
               Independent   NO    POSSIBLE     ABANDON
  NR
  NR
            sec
            sec
         Oxidizing
          species

         None
               pH Dependent  NO    POSSIBLE   CONT'D STUDY


               pH Dependent  NO       YES     CONT'D STUDY
  NA
  NA
  NA
NA       Oxidizing
          Gas species

NA       Oxidizing
          species, Cl"
 3 months    NA
         Oxidizing
          species Cl"
NA       Oxidizing
          species, Cl"
               Dependent POSSIBLE  POSSIBLE   CONT'D STUDY
                 on pH

                  NR     POSSIBLE  POSSIBLE   CONT'D STUDY
               pH Dependent  YES      YES     RECOMMENDED


               Buffer    POSSIBLE  POSSIBLE   CONT'D STUDY
                required

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    TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (cont'd)

                   Species*      DETECTION  WORKING   EXPECTED  EXPECTED
TYPE OF TEST       MEASURED        LIMIT     RANGE    ACCURACY  PRECISION  SKILL'
 (METHOD)'         DIRECTLY       (mg/L)    (mg/L)      (± %)     (± %)     LEVEL
TOTAL CHLORINE8

  "Ideal"       C12 + HOC1/OC1-   0.001     0.001-10    0.5     0.1        1
                NH2C1 NHC12 NC13


  AMPEROMETRIC TITRATION:

    Forward     C12 + HOCl/OCl"   0.00181     > 10        NF      NF        2
                NHjCl NHC12 NC1S
                C12 + HOC1/OC1-  0.02 -0.032  > 10        NF    3 -  50       2
                NH2C1 NHC12 NC13

    Back        C12 + HOC1/OC1-   0.002       > 10       3 - 50    NF        2
                NH2C1 NHC12 NC13

    Continuous  C12 + HOC1/OC1'   0.005       > 10        NR     1.0       2/3
                NHjCl NHC12 NCla


  IODOMETRIC TITRATION:

    Standard    C12 + HOCl/OCl"   0.073     0.1-10      NR      NR        2
                NH2C1 NHC12 NC13
                C12 + HOC1/OC1-   0.35*     0.5-100     NR      NR        2
                NH2C1 NHC12 NC13


  DPD

    FAS Tit'n   C12 + HOC1/OC1-   0.004s    0.01-10     NF   2-7        1
                NH2C1 NHC12 NCI,
                C12 + HOC1/OC1-   0.11«     0.01-10     NF   2-7        1
                NH2C1 NHC12 NC13

    Color'mtrc  C12 + HOC1/OC1-   0.0016    0.01-10    1 - 15 1  -  14       1
                NH2C1 NHC12 NC13


  LCV

    Black &
      Whittle   C12 + HOC1/OC1-   0.005     0.25-3      NF   4-10       1
                NH2C1 NHC12 NC13

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    TABLE I.   CHARACTERISTICS (cont'd)
    STABILITY                                   FIELD               CURRENT
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE   TEST   AUTOMATED    STATUS
5 YRS > 1 DAY
1 - 2 yrs NA
1-2 yrs NA
1 - 2 yrs NA
1 - 2 yrs NA
1 yr 10 min
1 yr 10 min
powder 30 min
stable8
powder 30 min
stable6
powder 30 min
stable6
months NR
NONE
Oxidizing
Species
Oxidizing
Species
Oxidizing
Species
Oxidizing
Species
All oxidizing
species
All oxidizing
species
Oxidizing
Species
Oxidizing
Species
Oxidizing
Species
Oxidizing
Species
Independent YES
of pH
pH Dependent YES
pH Dependent YES
pH Dependent YES
pH Dependent YES
pH Dependent NO
pH Dependent NO
Requires NO
buffer
Requires YES
buffer
Requires YES
buffer
Requires YES
buffer
YES RECOMMENDED
YES RECOMMENDED
YES RECOMMENDED
YES RECOMMENDED
YES RECOMMENDED
NO RECOMMENDED
(LAB TEST)
NO RECOMMENDED
(LAB TEST)
NO RECOMMENDED
(LAB TEST)
NO RECOMMENDED
(FIELD TEST)
NO RECOMMENDED
(FIELD TEST)
NO ABANDON

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    TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (cont'd)

                   Speclest      DETECTION  WORKING   EXPECTED  EXPECTED
TYPE OF TEST       MEASURED        LIMIT     RANGE    ACCURACY  PRECISION  SKILL"
 (METHOD)*         DIRECTLY       (mg/L)    (mg/L)      (± %)     (± %)     LEVEL
    Whittle &
      Lapteff   C12 + HOC1/OC1-   0.01      0.25-10      NF   4-10      2
                NH2C1 NHC12 NC1S
  FACTS

    Color'mtrc  C12 + HOCl/OCl"   0.1       0.25-10    5  -  20  1  -  11      1
                NH2C1 NHC12 NC1S


    Spect'photo C12 + HOC1/OC1-   0.012     0.05-10      NF     NR        1
                NH2C1 NHC12 NC1S


  ELECTRODE METHODS

    Pot'metrie  C12 + HOC1/OC1-   0.005     0.01-1     1  -  6   7  -  10      2
                NHjCl NHC12 NC13



MONOCHLORAMINE9

  "Ideal-             NH2C1       0.001     0.001 - 10   0.5    0.1         1


  UV/VISIBLE          NH2C1       - 1       1 . 100        NR      NR         3


  AMPEROMETRIC TITRATION:

    Forward

    Back
  DPD

    FAS Tit'n

    Color'mtrc
NH2C1
NHaCl
NH2C1
NH2C1
NR
NR
NR
NR
> 10
> 10
0.01 - 10
0.01 - 10
NF 0-10
NF NF
NF 2-7
NF 5-75
2
2
1
1
                                      10

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    TABLE I.   CHARACTERISTICS (confd)
    STABILITY                                   FIELD               CURRENT
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE   TEST   AUTOMATED    STATUS
 months     NR
          Oxidizing
           Species
                Buffering    YES
                      NO      RECOMMENDEDD
                               (LAB TEST)
 2 YRS
 2 YRS
30 min
at high
C12

30 min
at high
Cl,
Oxidizing
 Species
Oxidizing
 species
Buffering
 critical
Buffering
 critical
YES      NO      RECOMMENDED
YES      NO      RECOMMENDED
 3 months    NA
          Oxidizing      pH Dependent  YES
           Species, Cl"
                                      YES     RECOMMENDED
 5 YRS    > 1 DAY
              NONE
               Independent   YES
                                                YES
                                                                   RECOMMENDED
  NA
 NA       C12NH - C13N   pH Dependent  NO
           backgnd Abs
                                      NO      RECOMMENDED
                                               (LAB TEST)
  1-2 yrs    NA       C12NH - C1SN   pH Dependent  YES      YES

  1-2 yrs    NA       C12NH - C1SN   pH Dependent  YES      YES
                                                        RECOMMENDED

                                                        RECOMMENDED
 powder
  stable8
 powder
  stable8
30 min
30 min
C1NH2  - C1SN
 oxid species
C1NH2  - C13N
 oxid species
Requires     NO       NO      RECOMMENDED
 buffer                        (LAB TEST)
Requires     YES      NO      RECOMMENDED
 buffer                        (FIELD TEST)
                                      11

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    TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (cont'd)
TYPE OF TEST
 (METHOD)*
Speciest      DETECTION  WORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACCURACY  PRECISION  SKILL0
DIRECTLY       (mg/L)    (mg/L)     (± %)      (± %)    LEVEL
  LCV
    Whittle &
      Lapteff
   NH2C1
 NR
0.25-10     NF    0-43     2
  ELECTRODE METHODS

    Silver iodide
    Voltammetric
   NH2C1
 NR
0.1 - 10      NR      NR
DICHLORAMINE9

  "Ideal"
   NHC1,
0.001     0.001 - 10   0.5     0.1
  UV/VISIBLE
   NHC1,
- 1
1 - 100
NR      NR
  AMPEROMETRIC TITRATION:

    Forward           NHC12

    Back              NHC1,
                NR        > 10         NF      0        2

                NR        > 10        3 - 50   NF       2
  DPD

    FAS Tit'n

    Color'mtrc
   NHC1,
   NHC1,
 NR       0.01 - 10     NF      NF       1

 NR       0.01 - 10     NF     0 - 100   1
  LCV
    Whittle &
      Lapteff
   NHC1,
 NR
0.25 - 10
NF    10 - 150   2
                                      12

-------
    TABLE I.   CHARACTERISTICS (cont'd)
    STABILITY                                   FIELD               CURRENT
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE   TEST   AUTOMATED    STATUS
months      NR       Oxidizing       Requires     YES      NO      RECOMMENDED
                      species         buffer                        (LAB TEST)
  NA
NA       Oxidizing       Requires   POSSIBLE  POSSIBLE CONT'D  STUDY
          species         buffer
 5 YRS    > 1 DAY
  NA
NA
             NONE
C1NH2 & C1SN
 backgnd Abs
               Independent
                  of pH
              YES
pH Dependent  NO
YES     RECOMMENDED
NO      RECOMMENDED
         (LAB TEST)
 1-2 yrs    NA       C1NH2 & C1SN   pH Dependent  YES

 1-2 yrs    NA       CINHj. & C13N   pH Dependent  YES
                                               YES     RECOMMENDED

                                               YES     RECOMMENDED
 powder     30 min
  stable9
 powder     30 min
  stable6
          C1NH2 &   C13N   Requires      NO        NO
           oxid species    buffer
          CINHj &   C1SN   Requires      YES       NO
           oxid species    buffer
                                              RECOMMENDED
                                                (LAB TEST)
                                              RECOMMENDED
                                                (FIELD TEST)
 months
NR
 Oxidizing      Requires     YES      NO      RECOMMENDEDD
  species        buffer                         (LAB TEST)
                                      13

-------
    TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (confd)
TYPE OF TEST
 (METHOD)'
TRXCHLORAMINE9

  •Ideal"


  UV/VISIBLE
Speciest      DETECTION  WORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACCURACY  PRECISION  SKILL'
DIRECTLY       (mg/L)    (mg/L)      (± %)      (±  %)    LEVEL
   NCI,        0.001     0.001 - 10   0.5    0.1
   NCI,
  AMPEROMETRIC TITRATION:

    Forward           NC1S
NR
                NR
  NR
          > 10
NR     NR
              NF   5  -  100
  DPD

    FAS Tit'n

    Color'mtrc


  LCV

    Whittle &
      Lapteff
   NC13

   NCI,
   NCI,
CHLORINE DIOXIDE

  •Ideal-             C103

  IODOMETRIC          C102


  AMPEROMETRIC        CIO,


  DPD

  UV

    Manual            C10S


                      CIO,
NR       0.01 - 10     NR     NR        1

NR       0.01 - 10     NR     NR        1
NR
0.25 - 10     NR     NR
               0.001     0.001 - 10   0.5     0.1       1

               0.002     0.002 - 95  1 - 2   1-2      2


               0.012     0.02 - ??   1 - 15  1 - 15     3


   C102l°-11    0.008     0.008 - 20    10    7-15     2
               0.05
               0.25
         0.05 - 500
         0.25 - 142
                                      14

-------
   TABLE  I.   CHARACTERISTICS (confd)
    STABILITY                                    FIELD               CURRENT
REAGENT    PRODUCTS    INTERFERENCES   pH RANGE   TEST   AUTOMATED    STATUS
 5 YRS     > 1  DAY
               NONE
              Independent   YES
                       YES     RECOMMENDED
  NA
  NA       C1NH2 - C12NH  pH Dependent  NO
            backgnd Abs
            HOC1/OCL-
                                     NO      RECOMMENDED
                                              (LAB TEST)
 1-2 yrs    NA
           C1NH2 - C12NH  pH Dependent  NO
                                     YES     RECOMMENDED
                                              (LAB TEST)
powder     30 min
  stable6
powder     30 min
  stable6
           C1NH2  - C12NH  Requires     NO       NO
            oxid species    buffer
           C1NH2  - C12NH  Requires     YES      NO
            oxid species    buffer
                                             RECOMMENDED
                                               (LAB TEST)
                                             RECOMMENDED
                                               (LAB TEST)
months
  NR
Oxidizing      Requires     YES      NO      RECOMMENDED
 species        buffer                          (LAB TEST)
 5 YRS

 1 YR


 good
> 1 DAY
   NONE
Subject to  Oxidizing
oxidation    species

Subject to  Metal ions &
oxidation    nitrite ion
 solid     < 30 min
 stable6
            Oxidizing
             species
Independent   YES

  2-5       NO


    7         NO


    7         NO
YES     RECOMMENDED

NO    NOT RECOMMENDED


NO    CURRENTLY USED


NO    NOT RECOMMENDED
 none
 none
           none
           none
             Other UV
             absorbers

              none
              Independent   NO       YES
              Independent   NO       YES
                                RECOMMENDED
                                 (LAB TEST)

                                RECOMMENDED
                                 (LAB TEST)
                                      15

-------
 TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (cont'd)
TYPE OF TEST
 (METHOD)*
  ACVK12
  o-TOLIDINE


  INDIGO BLUE

  CHEMILUMINESCENCE

    Luminol

    GDFIA13

  ELECTROCHEM.

    Ft Microelec.

    Vit.  Carbon

    Voltam. Mem.

    Rotating Volt.
    Membrane         C102         0.30       0.30 - 3     NR     6.4      2/3

CHLORITE ION

  "Ideal"            C102-        0.001     0.001 - 10   0.5     0.1       1

  AMPEROMETRIC

    lodometrtc       C102"        0.05      0.05-95    5       5        2

  IODOMETRIC

    Sequential       C102-        0.011        > 1        1       1        3


    Modified         C102-        0.3       0.5 - 20     0.5    1-3      3


  DPD                C102-        0.01      0.01-10    5       5        2
                                      16
Speciest
MEASURED
DIRECTLY
C102
C102
C102
C102
i
C102
C102
C102 + C102-
C102
C102
DETECTION WORKING EXPECTED EXPECTED
LIMIT RANGE ACCURACY PRECISION SKI
(mg/L) (mg/L) (± %) (± %) LEV
0.04
0.003
0.1
0.01
0.3
0.005
1.3
32
0.25
0-25 NR NR
0.003 - 1 10 5
NR NR NR
NR NR 1.5
0.3-1 NR 8
0.005 - 74 2 1
NR 7 NR
NR NR NR
NR NR NR
1
1
1
1
1
1
2/3
3
2

-------
  TABLE I.  CHARACTERISTICS  (confd)
STABILITY
REAGENT
NR
6 months
NR
good
1 DAY
1 DAY
none
none
none
PRODUCTS
NR
NR
NR
good
< 1 sec
< 1 sec
none
none
none
FIELD
INTERFERENCES pH RANGE TEST
minimal
unknown
Oxidizing
species
0, C17
NR
C12
cio2-
cio2-
HOC1
8.1-8.4 NO
7 YES
NR NO
> 4 NO
NR NO
> 12 NO
5-5.5 NO
3.5-7 NO
7.8 NO

CURRENT
AUTOMATED STATUS
NO
NO
NO
NO
NO
YES
NO
NO
NO
CONT'D STUDY
NOT RECOMMENDED
NOT RECOMMENDED
NOT RECOMMENDED
NOT RECOMMENDED
RECOMMENDED
CONT'D STUDY
CONT'D STUDY
CONT'D STUDY
CONT'D STUDY
none
          none
                       HOC1
               5 - 5.5
              NO
NO
CONT'D STUDY
5 YRS     > 1 DAY
 NONE
Independent   YES
YES     RECOMMENDED
1 YR     Subject to   Oxidizing
         oxidation     species
               2 - 5
              NO
NO    NOT RECOMMENDED
good     Subject to   Metal ions &
         oxidation     nitite ion

good     Subject to   Metal ions &
         oxidation     nitite ion
Solid     < 30 min
stable6
Oxidizing
 species
                           NO       NO    RECOMMENDED AT
                                             HIGH CONC.
                           NO
              NO
                       NO
        CONT'D STUDY
NO    NOT RECOMMENDED
                                     17

-------
 TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS® (cont'd)
TYPE OF TEST
 (METHOD)*
CHLORATE ION

  "Ideal"
    FIA


    DPD


OZONE

  "Ideal"

  IODOMETRIC
  ARSENIC BACK
  TITRATION
  FACTS


  DPD

  INDIGO

    Spect'photo
Species*
MEASURED
DIRECTLY
  cio,-
  IODOMETRIC

    Sequential       C103~


    Modified-        C10,'
  cio,-
  cio,-
DETECTION  WORKING  EXPECTED  EXPECTED
  LIMIT     RANGE   ACCURACY  PRECISION  SKILL'
 (mg/L)    (mg/L)     (± %)      (± %)    LEVEL
 0.001     0.001 - 10   0.5     0.1
 0.064      > 1          2     2-5      3


 0.3       0.3-20      1     1-3      3


 0.08      0.08 - 0.8   3.5      1        2


 0.01      0.01  - 10    5       5        2




 0.01      0.01 - 10    0.5     0.1       1

 0.002     0.5-100   1 - 35  1 - 2      2



 0.002     0.5-65    1=5   1-2      2


 0.02      0.5-5     5 - 20  1 - 5      2


 0.1       0.2-2     5-20    5        2



 0.001     0.01 -  .1     1      0.5       1

 0.006     0.05 -  .5     1      0.5       1

 0.1       > 0.3         1      0.5       1
                                      18

-------
    TABLE  I.   CHARACTERISTICS (confd)


    STABILITY
REAGENT    PRODUCTS    INTERFERENCES   pH RANGE
FIELD               CURRENT
TEST   AUTOMATED    STATUS
5 YRS
good
good
1 year
Solid
stable6
5 YRS
1 YR
1 YR
2 YRS
Solid
stable8
good
good
good
> 1 DAY
Subject to
oxidation
Subject to
oxidation
1 day
< 30 min
> 1 DAY
subject to
oxidation
subject to
oxidation
no fading
first 5 min
< 30 min
good
good
good
NONE Independent
Metal ions & 7
nitrite ion
Metal ions & 2
nitrite ion
Oxidizing < 1
species
Oxidizing 7
species
NONE Independent
All ozone < 2
by products
and oxidants
Oxidizing 6.8
species
Oxidizing 6.6
species
Oxidizing 6.4
species
C12, Mn ions 2
Br, I2
C12, Mn ions 2
Br2 I2
C12, Mn ions 2
YES
NO
NO
NO
NO
YES
NO
NO
NO
NO
NO
NO
NO
                                                           YES
                                                           NO
                                                           NO
                 RECOMMENDED
                                                           NO    RECOMMENDED AT
                                                                 HIGH CONC.
                 CONT'D STUDY
                                                           YES   USED AFTER ALL
                                                                 C102 C102- GONE

                                                           NO    NOT RECOMMENDED
                                                           YES     RECOMMENDED

                                                           NO        ABANDON
                 CONT'D STUDY
                                                           NO    NOT RECOMMENDED


                                                           NO    NOT RECOMMENDED



                                                           YES     RECOMMENDED

                                                           YES     RECOMMENDED

                                                           YES     RECOMMENDED
                       Br2 I2
                                      19

-------
TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS®  (cont'd)
Speciest
TE OF TEST MEASURED
.METHOD)* DIRECTLY
INDIGO (cont'd)
Visual 03

GDFIA 03
LCV 03
ACVK 03
o-TOLIDINE 03
BISTERPYRIDINE 0.
DETECTION WORKING EXPECTED EXPECTED
LIMIT RANGE ACCURACY PRECISION SK!
(mg/L) (mg/L) (± %) (± %) LF

0.1 0.01 - 0.1 5 5
> 0.1 5 5
0.03 0.03 - 0.4 1 0.5
other ranges
possible
0.005 NR NR NR
0.25 0.05 - 1 NR NR
NOT QUANTITATIVE NR NR
0.004 0.05 - 20 2.7 2.1

1
1
2
1
1
1
3
 CARMINE INDIGO
< 0.5
NR
NR
NR
 ELECTROCHEM

   Amperometric
   Amperometric
   iodometric
   Bare electrode

   Membrane elect.

   Differential
   Pulse Dropping
   Mercury

   Differential
   Pulse Polar-
   ography

   Potentiometric
Total - 1
oxidants
Total - 0.5
Oxidants
03 0.2
0, 0.062
03 NR
03 0.003
0, NR
NR
NR
NF
NF
NR
NR
NR
5
5
5
5
NR
NR
NR
5
5
5
5
NR
NR
NR
2
2
2
1
3
3
1
                                     20

-------
   TABLE  I.   CHARACTERISTICS (cont'd)
    STABILITY                                     FIELD               CURRENT
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE     TEST   AUTOMATED    STATUS
good

good

good


Stable
NR

NR
Good

good

good

good


Stable
NR

NR
Good

C12 , Mn ions 2
Br2 I2
C12 , Mn ions 2
Br2 I2
C12 at > Img/L 2


52- SO3" Cre* 2
Mn > 1 mg/L 2
C12 > 10 mg/L
Metal ions, NOj" 2
C12 < 7

YES NO

YES NO

NO YES


NO NO
NO NO

YES NO
NO YES

RECOMMENDED

RECOMMENDED

COMPARISON
STUDIES
NEEDED
CONT'D STUDY
CONT'D STUDY

ABANDON
RECOMMENDED
(LAB TEST)
  NR
NR
NR
                                                  NO
                                               NO
        CONT'D STUDY
 none
            NA
         Oxidizing
         species
                         NO       YES     RELATIVE
                                          MONITORING
  1 YR    Subject to  Oxidizing
         oxidation   species
                          4 - 4.5
                         NO
none
none
none
none
none
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
4
NR
NO
NO 1
NO
NO
NO
YES
'OSSIBIJ
NO
NO
YES
NO   NOT RECOMMENDED
                                                                   CONT'D STUDY
                                                                   RESEARCH LAB



                                                                   CONT'D STUDY

                                                                   CONT'D STUDY
                                      21

-------
 TABLE I.  CHARACTERISTICS AND COMPARISONS OF ANALYTICAL METHODS®
TYPE OF TEST
 (METHOD)*
  UV
Species*      DETECTION  WORKING  EXPECTED  EXPECTED
MEASURED        LIMIT     RANGE   ACCURACY  PRECISION  SKILL'
DIRECTLY       (mg/L)    (mg/L)       (± %)     (± %)    LEVEL
                                  0.02
                         > 0.02
0.51*    0.5
  ISOTHERMAL
  PRESSURE CHANGE
             4 x 10-8  4 x 10-6 - 10 0.5
         0.5
OZONE GAS PHASE

  "Ideal"              03

   UV                  Os

  Stripping
  Absorption
  lodometry            0,

  Chemiluminescence    03

  Gas phase titration  03

  Rhodamine B/
  Gallic Acid          03

  Amperometry          03
                1      1 - 50,000     111

               0.5     0.5 - 50,000   2       2.5      1/2
0.002
0.005
0.005
0.001
NR
0.5 - 100
0.005 - 1
0.005 - 30
NR
NR
1 - 35
7
8
NR
NR
1 - 2
5
8.5
5
NR
2
1/2
2
1
1
    *  for page numbers in the full report, refer to the Alphabetical Index
    t  direct determination of the species measured without interferences
    *  Operator Skill Levels:  1 - minimal, 2 - good technician,
                                            3 - experienced chemist
    NA Not applicable
    NR Not reported
    NF Not found
    1  Using research grade electrochemical equipment
    2  Using commercial titrator
    3  Spectrophotometric endpoint detection
    4  Visual endpoint detection.
    5  Using test kit
    6  Liquid reagent is unstable
    7  Stablility is very dependent on the purity of the 2-propanol used
                                      22

-------
    TABLE  I.   CHARACTERISTICS (confd)
    STABILITY
REAGENT   PRODUCTS   INTERFERENCES   pH RANGE
 none
  NA       Other
         Absorber
 none     good
            none
            Independent
            Independent
                FIELD               CURRENT
                TEST   AUTOMATED    STATUS


                NO       YES     ESTABLISH
                               MOLAR ABSORB-
                                 TIVITY

                NO       YES     COMPARISON
                                 STUDY
 none

 none
none

none
none

none
Independent     YES      YES

      NA        YES      YES
RECOMMENDED

RECOMMENDED
 good     good

 stable  < 1  sec

 stable  stable
           S02 N02
            none

            none
                  NA

                  NA

                  NA
                YES      NO        ABANDON

                YES      YES     RECOMMENDED

                YES      NO   NOT RECOMMENDED
problems

 none     none
             NR

             NR
                  NA

                  NA
                YES  POSSIBLE NOT RECOMMENDED

                YES      YES  NOT RECOMMENDED
    8  Total  Chlorine is all chlorine species with +1 oxidation state
    9  Very little actual work has been carried out on selective determination
       of chloramines.   The values reported are from extrapolated studies that
       had objectives other than the selective determination of chloramines.
       Most methods are indirect procedures which are not recommended
   10  Indirect method
   11  1/5 of C102 determined
   12  Acid chrome violet potassium (ACVK)
   13  Gas diffusion flow injection analysis (GDFIA)
   14  Based on current molar absorbtivity and proper sample handling tecniques.
       Current best estimates of molar absorbtivity  of 2900-3300 give a
       possible error of > 10%.
    c  Taken from Gordon, Cooper, Rice, and Pacey, AWWA-RF Review on
       "Disinfectant Residual Measurements Methods" (1987)
                                      23

-------
    Chapter 4 (Indexed Reference Citations) has been included  in  this  report  in
order  to  assist  readers  in  locating  particular papers of interest.  The 48
categories for chlorine, chloramines, and the oxy-chlorine species,  along  with
the  additional  60  categories  for  ozone, should make the task of finding in-
dividual papers of interest considerably less cumbersome.  Papers which describe
several methods have been included in each of the appropriate   categories.   All
together,  the  1,400  references  cited  in Chapters 1-3 number  more  than  2,000
individual citations when distributed in the indexed form of Chapter 4.

    Chapter 5 is an alphabetical listing of the individual references  citations.
Finally, a detailed Index has been  included  in  order  to  assist  readers  in
locating  subjects  of  specific  interest.  We hope the readers  will  find  these
additional chapters as useful as have we in preparing this report.


RECOMMENDATIONS


    General Statements on Comparisons.

    There have been and will continue to be reports of methods comparison.   One
of  the most important considerations for a method is accuracy, i.e. the ability
of the method to determine  the  correct  concentration  of  a disinfectant  in
solution.  An  equally  important consideration is precision,  i.e. how well does
the analytical method reproducibly measure the  same  concentration.   Frequently
experiments  are  conducted to determine the "equivalency" of  the methods.  From
such results, methods may be found to be equivalent,  but  the only  analytical
considerations  tested  were  accuracy,  as  judged  by  a  Referee  Method, and
precision, judged for each method based on the experimental design.

    No considerations were given to specificity or analyst preference.  Yet one
of  the  most  difficult  tasks  in  the area of disinfection  analytical methods
development is comparison  testing.   It  is  recommended  that   a  protocol  be
developed  to  initiate  comparison  of the disinfectants.  This  protocol should
include all of the factors delineated  in  the  "Ideal  Method"   and  should  be
undertaken  in  both  laboratory  controlled  conditions  and  at selected  water
treatment plants around the country.

    Chlorine Chemistry.

    Clearly, the conversion to moles, equivalents, or normality   from  units  of
mg/L  (as  C12)  or  mg/L  (as  other  oxidants)  can  easily  be confused (and
confusing). Our recommendation is that all oxidizing agents be reported in  molar
units (M) and, if necessary, in mg/L of that oxidizing agent as   measured   (i.e.
mg/L  (as C12) or mg/L (as C102") or mg/L (as C10S~).  Furthermore, we recommend
that  oxidizing  equivalents  per  mole  of  oxidant  be  reported  to  minimize
additional  potential  confusion.   For  example, when C102 is reduced to C102',
this corresponds to one equivalent/mole; on the other hand, when  C102  is reduced
to Cl", this corresponds to  five  equivalents/mole.   A  summary of  molecular
weights  and oxidizing equivalents for the various chlorine species, oxychlorine
species and ozone is given in Table II.
                                      24

-------
    TABLE II.  EQUIVALENT WEIGHTS  FOR CALCULATING CONCENTRATIONS ON THE
               BASIS  OF MASS.
Species
Chlorine
Monochloramine
Dichloramine
Trichloranine
Chlorine dioxide
Chlorine dioxide
Chlorite ion
Chlorate ion
Ozone
Ozone
Molecular
Weight
g/mol
70.906
51.476
85.921
120.366
67.452
67.452
67.452
83.451
47.998
47.998
Electrons
Transferred
2
2
4
6
1
5
4
6
2
6
Equivalent
Weight
g/eq
35.453
25.738
21.480
20.061
67.452
13.490
16.863
13.909
23.999
8.000
    Several mechanisms have been proposed for the decomposition of dichloramine,
but the complete mechanism at the breakpoint has not been resolved. Clearly, the
chemistry is complicated and  varies  markedly  with  solution  composition.   A
detailed  understanding  of  the specific reactions involved requires a detailed
knowledge of the concentration of all chloramine species in the system.

    Nitrogen-containing organic compounds may be present in  surface  water  and
ground-water.   Because  of  analytical  complexities, very few detailed studies
have been undertaken to determine  the  individual  compounds  present  and  the
concentration   at  which  they  exist.   Kjeldahl  nitrogen  analysis  is  used
frequently, but this does not provide any detailed information  with  regard  to
individual  compounds.   The  area  of organic nitrogen and the determination of
specific compounds in natural waters is  one  of  the  increasing  interest  and
requires considerably more research in characterization and methods development.

    ultraviolet Methods.

    In general, because the molar absorptivities are quite low for chlorine  and
chloramine  species,  ultraviolet  methods  are not considered useful in routine
monitoring of chlorine residuals.  In addition to the low molar  absorptivities,
there  is often background absorbance that may interfere with the measurement in
various natural waters.  However, these measurements are of use in standardizing
the chlorine species in distilled waters and are often used in experimental work
                                      25

-------
related to chlorine speciation.  This method does  have   considerable  potential
for   the   determination   of   relatively  high  concentrations  of  halogens,
particularly  in  relatively  clean 'water.   This   method  might  find  use  in
monitoring  chlorine  species  in  water  treatment plants.   However,  with a more
elaborate multiwavelength  spectrophotometer  and  computer-controlled  spectral
analysis, it might be possible to analyze several halogens simultaneously.

     It is also possible that additional  methods using permeable membranes  could
be developed for the simultaneous determination of chlorine species  in  aqueous
solution.   Additional  work  is  necessary  in  this  area.   Although the  molar
absorptivities of the species is not of a magnitude  as to lend it to  the routine
determination of the dilute (less than 10"6  M)  chlorine  and  chlorine-ammonia
species,  it is potentially helpful in determining the concentration  of standard
solutions.  Absorption spectrophotometric analysis has and will continue to  be
very  important  in  the  area  of  chlorine  chemistry.    It  can be  used in the
unambiguous determination of relatively high concentrations of  the  species  in
relatively pure water.

     Continuous Amperometric Titration Method.

    Interferences appear to be reduced using the continuous amperometric method
because  the  reagents  are  added  to  the  sample  just  prior to contacting the
indicating electrode. Thus, when compared to  the  amperometric  titration,  the
amount  of  interference  by iodate ion,  bromate ion, copper(II),  iron(III), and
manganese(IV) is reduced by approximately one-tenth.  No  reports  appear to  be
available  in  the  literature  on the determination of mixed  oxidants using the
amperometric method.  Such experiments need to be carried out.  In addition,  few
experiments  have  been  reported  which  clearly demonstrate that the electrodes
remain uncontaminated for drinking water  or waste water systems.   In  the absence
of  such  comparisons,  the  accuracy  of any  electrode   procedure   may  be
questionable.

    However, the amperometric titration determination of   chlorine species  re-
mains  the  standard  for routine laboratory measurements.   Given proper analyst
training and experience, the commercially available  instrumentation is sensitive
and precise.  This method should remain as the method  for  laboratory  use  and
accuracy  comparisons.   It  requires  more analyst  experience than colorimetric
methods, but can be relied on to give very accurate  and   precise  measurements.
It  should  be noted that care must be exercised when using one titrator for the
measurement of both free and combined chlorine.  Small quantities of  iodide  ion
can  lead  to  errors  when  differentiating between free and  combined chlorine.
Careful rinsing with chlorine demand free water (CDFW) is  a  must!    Additional
development  of automated back-titration  equipment with the goal of lowering the
limit of detection and improving the reproducibility would be  highly  beneficial.

    lodometric Titration Method.

    The iodometric titration is useful for determining  high  concentrations  of
total  chlorine.   The most useful range  is 1 mg/L (as C12) or greater.   It is a
common oxidation-reduction titration analytical method and provides a  reference
procedure  for  total  chlorine.   Although not necessarily used routinely, most
laboratories use it as a. reference method and  it  is  not  likely ever to  be
eliminated from use.
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    Colorinetric Methods.

    It  Is  reported in Standard Methods (13) that  nitrogen  trichloride  can  be
measured  using  the  DPD  method; however, the method has not been confirmed by
independent investigations and should be used  only  as  a  qualitative  method.
Additional  research  is  necessary  to  determine  the effectiveness of the DPD
method  for nitrogen  trichloride.   The  effect  of  the  presence  of  mercuric
chloride  in the reagents for minimizing the breakthrough of monochloramine into
the free chlorine reading with the  DPD  method  has  been  shown.  It  is  very
important  that  the  addition of mercuric chloride to the buffer be followed to
minimize the direct reaction of monochloramine with DPD.  This phenomenon is not
thoroughly understood.  This effect should be studied more  thoroughly  and  the
principle may be applicable to all of the colorimetric methods.

    The use of  thioacetamide  was  evaluated  for  monochloramine  (using  DPD-
Steadifac).  It  was  shown  under  these  conditions  to eliminate any positive
inteference in the free residual measurement.  These  results  are  not  as  yet
understood,  but the implication is that the chemistry of oxidation is different
for monochloramine and free chlorine.  These results suggest that more  work  is
necessary  to  better define the reactions involved, and this may lead to a more
usable  analytical procedure. This procedure is recommended  for  use  in  waters
that are suspected to be relatively high in combined chlorine.

    The DPD-Ethyl Acetate Extraction Procedure is  a  modification  of  the  DPD
chemistry.   The  method  is  based  on  the  oxidation  of iodide ion by active
chlorine followed by extraction of the iodine species into ethyl acetate.   This
procedural  modification  may  be  of use in the determination of total residual
chlorine in both the field and laboratory.  Additional work is necessary  before
it  can  be  used  to any great extent.  It does not appear to offer substantial
advantages to  the  already  well  tested  colorimetric  method  for  laboratory
measurements.

    The DPD methods have become the most widely used procedures for the measure-
ment of chlorine.  This is not likely to  change.  The  DPD  color  reagent,  in
liquid form, has been shown to be quite unstable and is not recommended for use.
It  is  sensitive to oxidation by oxygen and thus requires a control measurement.
Clearly, it is better to use dry reagents.

    Leuco Crystal Violet, LCV.

    No studies have been reported that  examine  the  interference  of  chlorine
dioxide  and/or ozone in the LCV method.   It is anticipated that these oxidants
would interfere in the method, and studies should be conducted to quantify these
potential interferents.

    Syringaldazine; FACTS.

    A study using syringaldazine in a continuous method  to  differentiate  free
from combine chlorine has been reported.  It was concluded that it could be used
•nd  was useful in controlling free chlorination.  Further work would have to be
conducted to use this or any colorimetric method in continuous analyzers.
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    Chemiluminescence.

    Several papers have appeared that detail the reaction  of   hydrogen  peroxide
and  hypochlorous  acid  and the resulting chemiluminescence.   The  mechanism has
been relatively well established and the chemiluminescence is  thought  to   occur
as  a  result of the formation of singlet oxygen.  The light emitted is red (635
nm),  and occurs most readily in  alkaline  solution.  This reaction  is  rather
insensitive  to  low concentrations and is not suitable  for the determination of
hypochlorous acid in aqueous solution.  However,  the  studies  that  have been
reported can serve as a guide for those interested in pursuing other methods for
the determination of hypochlorous acid by chemiluminescence. It is  not sensitive
enough to be considered as an analytical method for chlorine in water treatment.

    A study  has  been  reported  that  details  the  use   of   luminol  for the
measurement of hypochlorite ion. The optimum pH for analysis was between 9.0 and
11.0   Luminol  also  has  been used for the determination of  hydrogen peroxide.
4,5,6,7,-tetramethoxyluminol is 30 % more  sensitive  than luminol.   Either  of
these compounds may be more sensitive in the determination of  free  chlorine.  As
these  compounds  have  not  been  tried  it appears that  additional studies are
necessary.  From the limited data available, it appears  that this  reaction has
considerable  promise  as  an  analytical  method.  It may very well be the most
sensitive method to date.

    It is reported that lophine, in a reaction with hypochlorite ion,   produces
light.   Very few details were given in the study for this reaction.   It appears
that lophine also may be good as a chemiluminescence reaction   system  for free
chlorine.   Additional  work  should  be  undertaken  to better characterize the
details of this reaction.

    Luminol and some of its derivatives, or lophine, may be well suited for the
very  sensitive measurements of chlorine species.  Additional  research should be
undertaken to develop the use of chemiluminescence for use in  the  determination
of  chlorine  in  water.   The  potential exists for rapid, simple,  and specific
methods for chlorine and possibly other oxidants.   With  the   advent  of   fiber
optic   sensors   and  their  application  in  chemiluminescence methods,  this
technology will be important in the future.

    Fluorescence.

    The use of rhodamine B has been reported as a low level fluorometric  method
for  the  determination  of  bromine.  This method is qualitatively specific for
bromine, although chlorine will react to decrease the fluorescence.   The advant-
age of this method is that it is capable of determining  oxidants  at  very low
concentrations.   This  method  could  be  applied to chlorine analysis by first
using the free chlorine to oxidize the bromide ion to bromine,   an   irreversible
reaction,  followed  by  the  determination  of  bromine.   This method was not
developed fully and very  little  work  has  been  undertaken   since   the   first
publication.   It does appear to have considerable potential and future research
in the area of methods development should not exclude additional work  on this
fluorometric procedure.
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    Other Electrode Methods.

    Additional studies are required to  better  understand  the  limitations  of
membrane   electrode  methods.    It appears that they may have prominent roles to
play in chlorine residual measurements in the future.

    In a  series of  experiments  carried  out  for  the  determination  of  free
chlorine   in  tap  water,  it  was  observed  that  there  was  a  statistically
significant difference between the results of the amperometric titration and the
•embrane  electrodes.  It was thought to be a problem in the membrane electrodes.
However,  on reconsideration, it is possible that the  electrodes  were  actually
giving a  free  chlorine reading and the amperometric titration was reading the
sum of free and organically combined chlorine.  The study was conducted on water
which is  relatively high in organic nitrogen.  It is possible that  considerable
chlorine   is  present  as  organically  combined  chlorine and interferes in the
amperometric titration procedure, but  does  not  interfere  with  the  membrane
electrode  measurements.   This  question  must be resolved.  Carefully designed
experiments to expicitly resolve these differences would be most appropriate.

    There have been no reports of experiments using bare-electrode  amperometric
analyzers where other oxidants such as chlorine dioxide, chlorite ion,  chlorate
ion  or  ozone have been tested with the bare-electrode.  Additional studies are
required  to expand  these  bare-electrode  amperometric  studies  to  quantitate
interferences  with  oxidants  other  than  those tested, and to expand to other
natural waters.

    Since  the  accuracy  of  the  potentiometric  electrodes  is  affected,  if
temperature  corrections  are  not  used,  it is recommended that temperature be
either controlled or measured simultaneously.  Additional  independent  measure-
ments of  accuracy should be undertaken for the potentiometric electrodes.

    It  appears  that  the  potentiometric  electrode  can  be  used   for   the
determination  of  total  residual  oxidant.   It  is  suitable  for  continuous
measurements and appears to give results that are acceptable  when  compared  to
the amperometric titrator.

    General Summary and Recommendations for Chlorine.

    In comparing all of the methods to the "Ideal Method" we find that none come
very close to our ideal standard.  Continued development of the various  methods
will, however, come closer and closer to the ideal.

    For the present, the  amperometric  titration  techniques  will  remain  the
laboratory  standard  used  for  the  basis  of  comparisons of accuracy.   These
methods,  with proper precautions can differentiate between the common  inorganic
chorine/chlorine  ammonia  species,  and  in  general  suffer from as few inter-
ferences  as any of the methods.

    Of the three common colorimetric procedures, DPD, LCV. and FACTS, the DPD is
by far the most commonly used method.  From the available literature it is clear
that the  DPD procedure has a number of weaknesses.  In particular,  the  colored
product  is  a  free  radical which limits the stability of the colored reaction
product.   The direct reaction with monochloramine, to form a  product  identical
                                      29

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to  the  reaction  with  free chlorine, is also a drawback.  This  problem  can be
reduced by the addition of thioacetamide.  Liquid reagent  instability  precludes
their use in most cases; care should be taken to determine blanks  frequently.

    The present LCV method that appears in Standard Methods  (13) is  outdated and
has been substantially improved upon by Whittle and Lapteff  (14).    This   method
allows  for  the  differentiation  of  the  common  free   and  combined inorganic
chlorine  species.   However,  because  only  one  comparison   study  has   been
conducted, additional collaborative  testing is recommended.

    The FACTS test procedure appears to be very useful for the determination  of
free  chlorine in the presence of relatively high concentrations of  combined in-
organic chlorine.  A severe drawback of the FACTS test procedure is  the insolu-
bility  of the syringaldazine in either 2-propanol or water.   This leads to dif-
ficulties in reagent preparation, and presumably to the color  stability problem
encountered  at  the  higher concentrations of chlorine (greater than 6-8 mg/L
(as C12)).  Although a method for the use of the FACTS test  for total chlorine
has been reported, it should be tested further.

    Electrode  methods have been developed employing several different concepts.
The membrane electrodes appear to have potential as specific methods  for  hypo-
chlorous  acid.   Common  interferences  are  other nonionized molecules such as
chlorine dioxide and ozone.  Fotentiometric electrodes for the determination  of
total  chlorine  are  improving  in  both  detection limit and stability.  These
electrodes appear to have  promise  in  the  area  of  process control.   Their
inclusion as methods for routine use in the laboratory and field is  warranted.

    Both fluorescence and chemiluminescence methods also show   promise for  the
specific determination of free chlorine at very low concentrations.   Within this
area  of  spectrofluorometric  methods,  there  is  considerable   work yet to be
initiated.  Continued development work is  warranted  and  recommended in this
promising area.

    From the review of analytical procedures for the determination  of chlorine
in  aqueous  solution, it is readily apparent that only a  few  of the methods are
used routinely.  Nevertheless, there is certain to be a  continued  interest  in
developing new and better methods of analysis.  We would strongly  recommend that
new  methods  be presented in terms of the "Ideal Method"  and  that whenever pos-
sible, comparisons with real samples and interlaboratory comparisons be made.

    Flow injection analytical techniques are  becoming  very   common.   Continued
development  should lead to the automation of many colorimetrie and  fluorometric
analytical methods for the measurement of free and  combined   chlorine and  its
various  species in water.  With the current emphasis on automation,  the methods
that are to be developed and those already developed can readily exceed present
standards  of  accuracy  and  precision.   Automation will also lead to operator
independent methods and should lead  to  improvements  in  process  control  and
monitoring.

    Chlorine Analytical Methods Comparative Studies.

    The reader is cautioned against accepting the results  of any or  all of  the
above tests without some reservations.  Where possible we  have tried to add com-


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nents,   parenthetically,   based upon our knowledge of the field.  It is very im-
portant  in reviewing data from comparison tests that the analyst be aware of the
objectives of the comparison  testing.   For  example,  a  test  may  be  judged
unacceptable  because of an unacceptable lower limit of detection that is beyond
the need for concern for other investigators.

    In general when testing several test procedures it is important to  identify
the  objective  of  the  testing.  Equally important is the use of the data.  In
reporting the results of the above tests, it should be kept in  mind  that  many
manufacturers  of  chemicals  for  analytical methods and Test Kits change their
procedures as a result of the testing.  The concerned analyst needs to determine
if the results are still valid.  This change is not  necessarily  applicable  to
other  studies  where  the  chemistry  of  an analytical method is examined.  In
general, the more the test studies chemistry and not merely the test procedures,
the more applicable the results are for future reference.

    Another area of confusion concerns precision and  accuracy.   An  analytical
method may be judged acceptable based on the precision of the results, while the
same  method  may give poor accuracy.  These statistical parameters are separate
and must be tested using different experimental designs.  Comparisons  with  the
•Ideal Method" would require that both be at acceptable levels.

     In general, there is a lack of comprehensive studies to  better  understand
the chemistry associated with the individual test procedures.  Investigations of
this nature are necessary on a continuing basis, because of the advances in ana-
lytical  instrumentation and our continued improvements in understanding the de-
tails of the underlying chemistry.

    Chlorine Dioxide Analytical Methods.

    The iodometric method is a questionable method even for carefully controlled
research laboratory chlorine dioxide standards.  In real samples where  a  large
number  of  potential interferences can exist, the method is destined to produce
erroneous results.  Newer, more species specific methods are better choices.

    Any method which determines  concentrations  by  difference  is  potentially
inaccurate  and  subject to large accumulative errors--both in terms of accuracy
and precision.  The subtraction of two large numbers to produce a  small  number
means  that the errors associated with those large numbers are propagated to the
small number.  The result in many cases is that the error  is  larger  than  the
smaller  number,  therefore,  giving  meaningless  information.  Methods such as
this, which obtain values by differences, should be avoided.

    The DPD method uses the difference  method  in  the  evaluation  of  concen-
trations.   The  direct  measurement  of species by means of a more reliable and
accurate method to determine chlorine dioxide is  needed.   The  same  questions
raised about the DPD method for chlorine also apply here.

    Ultraviolet spectrophotometry. utilizing continuous flow automated  methods,
has  a  great  potential  for  accurate  and precise measurements with the added
advantage of ease of operation  and  high  sample  throughput.   Flow  injection
analysis  methods  (FIA)  should be carefully evaluated against existing methods
for accuracy and precision.  The method should be field tested and the potential


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problem of membrane reliability should be evaluated for  long  term operations.

    Additional bench studies using continuous flow methods with chemiluminescent
detection must be carried out.  The superior selectivity of this method needs to
be utilized.  Comparison lab testing and field study should be  carried out.

    Chlorite/Chlorate Ion Analytical Methods.

    The iodometric/amperometric methods are indirect determinations  of  chlorite
ion  and  cannot  be  recommended.  The  DFD  method for chlorite ion can not be
recommended because it is unreliable.

     The iodometric sequential methods appear to be  very  workable   on  samples
containing  greater than 1 mg/L chlorite ion or chlorate ion  with good precision
and accuracy resulting.  The method requires  considerable  operator  skill  and
experience  to  obtain  good  precision and accuracy for samples containing less
than 1 mg/L chlorite ion or chlorate ion.  The method  should  be field tested
with  other  methods  using both high and low ratios of  chlorate ion to chlorite
ion. The method should be used with caution on low  level  samples  of  drinking
water  and/or  wastewater,  although  direct  methods requiring less specialized
skills are preferred.

    Interlaboratory  comparisons  should  be  carried  out  for   the   modified
iodometric method for the direct analysis of chlorite ion and chlorate ion.  The
detailed effects of various potential interferences need to be  evaluated.

    The argentometric titration method is to be recommended only for  relatively
high concentrations of oxy-chlorine species (10-100 mg/L) but may be very useful
in  establishing  inter-laboratory  bench mark comparisons at these  high concen-
tration ranges.  No such comparisons are currently available.

    A highly precise, automated FIA method for low level chlorate ion  needs  to
be developed possibly using various masking agents such  as glycine,  oxalic acid,
malonic  acid,  and  nitrite  ion to initially remove other possible oxy-halogen
interfering species.  The method appears to be very promising in that it can  be
used to directly determine low level chlorate ion concentrations.

Difficulties With Ozone Measurements: Need For Ideal Method.

    As a consequence of the nature of ozone, its continuous   self-decomposition,
volatility  from  solution,  and  the  reaction  of  ozone and  its decomposition
products with many organic and  inorganic  contaminants  in   water,   the deter-
mination of dissolved residual ozone is very difficult.  A detailed  knowledge of
the  mechanism  of  aqueous  ozone  decomposition  and the potential role of the
various highly reactive intermediates, is  imperative  in  order  to  accurately
evaluate  the  analytical methods (15).  In this context it should be noted that
most  ozone  methods  are  modifications  of  chlorine   residual  methods  which
determine  total  oxidants  in  the  solution.   Therefore,   ozone decomposition
products such as hydrogen peroxide and the like are also measured.

    lodometry can be used as an  example  of  the  difficulties  encountered  in
making  aqueous  ozone  measurements  (16).  Iodide ion  is oxidized  to iodine by
ozone in an unbuffered potassium iodide solution.  The pH then  is adjusted to  2


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with  sulfuric acid and the liberated iodine is titrated with sodium thiosulfate
to a starch end point. The ozone/iodine stoichiometry for this reaction has been
found to range from 0.65 to 1.5.  Factors affecting the  stoichiometry  include:
pH, buffer composition, buffer concentration, iodide ion concentration, sampling
techniques,  and  reaction  time.   The  pH  during the initial ozone/iodide  ion
reaction and the pH during the iodine determination have been shown to  markedly
alter  the ozone/iodine stoichiometry.  The formation of iodate ion and hydrogen
peroxide have been implicated specifically as factors affecting the ozone/iodine
stoichiometry (17).  Modifications in the iodine determination  include  changes
in  end  point  detection,  pH,  and  back-titration  .techniques.  None of these
modifications has been demonstrated to be totally satisfactory.

    The biggest difficulty in interpreting the existing ozone literature is that
no one method has been accepted as the Referee  Method.   Therefore,  comparison
between  several  different  methods  can  create  false  conclusions  about  the
accuracy of the methods.  The method most often used for comparative purposes in
the research laboratory is UV measurement of ozone at 260 nm.   Even  with  this
method  there' is  apparent  confusion  over  the molar absorptivity for aqueous
ozone, with the values ranging from 2900 to 3600 M^cm"1 (16).

    All analytical methods reported, particularly those of early vintage, should
be reevaluated, considering the recent information about  oxidative  by-products
from  ozone  decomposition  and  the  ozonation  process  itself.  Some of these
factors may  not  have  been  considered  during  development  of  the  original
analytical  procedures.  Certainly,  more  detailed  information and comparisons
should be available. Because of the  difficulties  of  establishing  a  reliable
Referee  Method  we  propose  that  the  existing and future methods be compared
against an "Ideal Method".  This "Ideal Method" would  incorporate  all  of   the
characteristics  that  are  desired for an ozone method, taking into account  all
other potential interferences, decomposition products, and  samples  originating
from various sources.  Finally, automation, while not an absolute necessity,  can
add to the selectivity and ideal nature of a method for ozone determination.

Ozone Measurement: Gas Phase.

    The many uses of ozonation in the treatment of drinking water are controlled
by monitoring a number of parameters.  Dissolved residual ozone is only  one   of
these parameters, and its measurement controls only disinfection conducted after
filtration,  but before addition of a residual disinfectant for the distribution
system.  However, it is  very  clear  that  the  cost,  efficiency,  safety   and
improvements  in  design  of  ozone  water  purification  systems  is  extremely
dependent  on  the  accurate  determination  of  gas  phase  ozone.   Therefore,
analytical  methods  must be developed that will accurately measure ozone in  the
gas phase and residual  ozone  in  the  aqueous  phase.  At  this  point  it   is
unrealistic to believe that one single method will be acceptable for both sample
matrices.

    lodometry, UV absorption and chemiluminescence are  the  three  most  common
methods employed for gas phase measurements (16). Each of these has been applied
to  determine the amount of ozone present in generator exit gases, when stripped
from solution to the gas phase, or the amount of ozone in  a  contactor  exhaust
gas.
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    These techniques of monitoring concentrations  in contactor  exhaust gases are
quite promising as a method of controlling the production  of  adequate quantities
of ozone. This provides considerable savings  in   electrical  energy  costs  for
ozone generation.  Direct inter-comparisons of the various gas  phase measurement
techniques are needed in order to evaluate accuracy.

    Determination of stripped ozone in the gaseous state   was  reported  in  the
16th   Edition  of Standard Methods (13) for measuring ozone  dissolved in water.
However, in addition to the procedure being subject to the same  limitations  of
UV  absorption and chemiluminescence procedures in aqueous solution,  the  effects
of the gas stripping process itself must be taken  into consideration.

    Although  the  iodometric  stripping/aqueous   absorption  method  has  been
approved  in Standard Methods (13), we question the accuracy  of the  method.  All
evidence would  suggest  that  the  method  is  problematic.    Even   though  the
impurities  are substantially left behind by the stripping, the actual procedure
and the continual decomposition of ozone does introduce inaccuracies  into this
method.   This  method  can  be  used as a relative measure of  ozone for  control
purposes.

    This basic stripping approach followed by  absorption   in  aqueous solution
(and  colorimetric measurement) may deserve to be  studied  further.   However, the
biggest potential problem appears to be that at high concentrations  of ozone the
colorimetric compounds may react by a mechanism different   from  that  used  for
residual  ozone  measurements.   Research should be concentrated on  the reagents
that have already exhibited ozone selectivity.

lodometry (Aqueous Phase).

    If the performance of ozone in a specific treatment application  is not  de-
pendent  only on the ozone, but is instead a collective function of  its reactive
decomposition products as well, then iodometry can give   a   representative  and
reproducible reading of the total oxidants.  For example,  most  European drinking
water  treatment  plants  employing  ozonation as  the primary disinfectant, have
relied  on  iodometric  measurements  as  the  basis   for   insuring  adequate
disinfection,  attaining  a  residual  "ozone"  level  of  0.4  mg/L  in the first
contact chamber and maintaing this level for at least four minutes).

    However, it is now abundantly clear that the 0.4 mg/L  value is a  measure  of
the  amount  of  total  oxidants  present,  and  not  necessarily ozone  alone.
Therefore, either the absolute level of ozone required to  attain the expected
degree  of disinfection is lower than 0.4 mg/L over the required period of time,
or some of the decomposition/oxidation products formed upon ozonation also  have
disinfecting  properties,  or  both.   Clearly,  detailed  experiments need to be
carried out to  demonstrate the efficacy of disinfection   by  the decomposition
products of ozone.  Similar efficacy data for ozone decomposition products could
be developed for other uses of ozone (e.g., chemical oxidation)  when measurement
of  residual  ozone levels must be made to control the process.   Such data would
help to justify the continued use of  iodometry  to  measure  "total   oxidants",
rather than only ozone.

    Historically, iodometry has been used as the   reference   method   for   deter-
mining   ozone,   and  against  which  other  analytical   procedures   have  been


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"standardized".   It is now quite clear that because of its lack of  selectivity,
the   use  of iodometry should be limited to that of only a control procedure.  In
terms of  ozonation processes, measurement-for control purposes-of the production
rate  of ozone  generators and bacterial disinfection/viral  inactivation  may  be
based upon iodometry, provided the user recognizes the many limitations of the
method. The reevaluation of this method must.be carried out  with  the  specific
goal   being to define when the method is reliable and the situations where it is
not accurate.

   Many  authors  have tactfully pointed out the many disadvantages of iodometry,
leaving it to  the reader to decide whether or not to use the  procedure.   In  a
detailed   comparison  of  eight  analytical  methods  for  the  determination of
residual  ozone it was concluded (16):

         "No iodometric method is recommended for the determination
          of ozone in aqueous solution because of the unreliability
          of the  method and because of the difficulty of the com-
          parison of results obtained with minor modifications in
          the  iodometric method itself."

Arsenic(III) Direct Oxidation.

    In the  direct  oxidation  of  arsenic(III),  ozone  reacts  with  inorganic
arsenic(III)  at  pH 4-7, the pH is adjusted to 6.5-7 and the excess arsenic(III)
species is back-titrated with standard iodine to a starch end point.  Values for
residual  ozone determined by the arsenic direct  oxidation  method  and  by  the
indigo method  agreed within 6% of the UV values. The primary advantages of the
arsenic direct oxidation procedure are minimal interferences, good precision  in
the  hands of  experienced operators, and apparently good overall accuracy.  This
procedure continues to be recommended along with the indigo method.   Additional
comparisons of  this method should be made with the indigo method under various
conditions.

Syringaldazine, FACTS.

    The FACTS  procedure, which was developed for the selective determination  of
free  available chlorine (hypochlorous acid  + hypochlorite ion) in the presence
of combined chlorine (chloramines), has been adapted for  the  determination  of
residual   ozone  (19).  In this procedure, an aqueous solution of ozone is added
to a solution  of potassium iodide, and the liberated iodine is  added  to  a  2-
propanol   solution of syringaldazine at pH 6.6.  The resulting color is measured
spectrophotometrically at 530 nm.

    The FACTS  procedure has the major advantage  of  providing  a  spectrophoto-
metric procedure for the determination of ozone.  However, the major limitations
of  the  FACTS  method are still  those of the iodometric procedure.  Due to the
observed  changes  in slope  and  intercept  which  are  problems  caused  by  the
interferences, self-decomposition of ozone, and stoichiometry, this method could
be  reviewed  in  order  to  fully  evaluate its potential usefulness.  However,
considering the   other  colorimetric  methods  that   are   available   further
development of  the  FACTS  method  does  not  seem  to give any promise of the
improved  selectivity that is needed.
                                      35

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N,N-Diethyl-p-phenylenediamine, DPD.

    The DPD procedure is based on the ozone oxidation of  iodide  ion  present  in
excess phosphate buffer at pH 6.4 to produce iodine, which  then  oxidizes  the DPD
cation  to  a  pink  Wurster cation which is measured spectrophotometrically, or
titrated. . The interferences include all oxidants capable   ©f  oxidizing  iodide
ion  to  iodine, including ozone decomposition products, halogens,  and manganese
oxides (20).

    One advantage of the DPD method  is  that  determinations  can  be  made  by
ferrous  ammonium sulfate (FAS) titrimetry, spectrophotometrically  or by  a color
comparator.  Ozone concentrations of less  than  or  equal   to   2   mg/L   can  be
determined  colorimetrically.  Clearly, the procedure requires the  difference of
differences and is limited by the same factors which limit  iodometry,  specific-
ally the presence of materials which can oxidize iodide ion to iodine.

    Although evaluation of this procedure versus the  standard   ultraviolet  and
indigo  procedures  would  seem to be necessary to make a more educated decision
about the continued use or abandonment of this  method,  the recommendation  is
that  other  colorimetric  methods  are  considerably  more reliable than DPD.
Therefore development or testing is neither recommended nor considered necessary
at this time.

Indigo Trisulfonate.

    The indigo method is subject to fewer interferences than most  colorimetric
methods  and  fewer interferences than all iodometric procedures (21-23).  At pH
2, chlorite, chlorate, and  perchlorate  ions,  and  hydrogen  peroxide   do  not
decolorize  Indigo  Reagent  when  observed  within  a  few hours  and when the
concentrations of the interferents are within a factor of   10  of   that   of  the
ozone to be determined.

    Ozone decomposition products and  the  products  of  ozonolysis  of   organic
solutes  do  not appear to interfere.  However, chlorine, bromine,  and iodine do
cause some interference, as do the oxidized forms of manganese.  The  addition of
malonic acid to the samples will mask the interference of chlorine.

    For the Indigo Trisulfonate  Method,  it  should  be  noted  that when  the
ultraviolet  absorption  method is used to standardize the  indigo method  (or anv
method) for ozone, the choice of molar absorptivity is  very critical.   It  is
recommended  that  the  equations  of  Hoigne continue to be used since they are
based on a molar absorptivity of 2950 M'lcnTl.  If and when a   different value
for  molar  absorptivity  is reported and confirmed, the  (calibration) equations
would  have  to  be  appropriately  changed.   In  this  manner,    all    current
measurements using the indigo method would continue to be comparable.

    The advantages of the indigo procedure is that it is based on a  measure  of
discoloration  which  is rapid and stoichiometric.  This analytical procedure is
recommended for use over any other procedure for the determination  of  residual
ozone.   Its  primary  attributes  are  its  sensitivity, selectivity, accuracy,
precision, speed, and simplicity of operation.
                                      36

-------
   The gas diffusion flow injection analysis (GD-FIA) procedure eliminates  the
interference   of oxidized forms of manganese, and markedly reduces the interfer-
ence  of chlorine (24).   Other than interference of chlorine which can be reduced
to zero by addition of malonic acid, there are no  known  interferences  to  the
determination  of ozone by this GD-FIA procedure using the indigo method.

   The  primary  advantages  of  the  GD-FIA  procedure   are   its   accuracy,
selectivity.   lack  of  interferences, reproducibility, and rapidity.  Thus, the
•ethod is well suited  for  laboratory  research  studies  and  for  use  as  an
automated analytical procedure.

   More studies should be  conducted  with  specific  gas-permeable  membranes,
particularly   with respect to repeated and/or continuous exposure to ozone solu-
tions.  The use of FIA equipment in a process control environment also  must  be
evaluated.   The GD-FIA indigo procedure might well be adopted as the analytical
•ethod of choice.

o-Tolidine

   The o-tolidine method (addition of  1-2  drops  of  o-tolidine  solution  to
ozone-containing  water  to develop the yellow color) is very simple, and easily
adapted to field color comparators, suitable for unskilled  analysts.   However,
this  advantage cannot compensate for the lack of quantitation of the method, nor
for  the  carcinogenicity of the reagent (o-tolidine).  The recommendation is to
abandon this method.

Carmine Indigo.

   The carmine indigo procedure has been used in Canadian  water  works  plants
for  the  past 15 years.   The ozone containing water is titrated with a solution
of carmine indigo until a faint blue color persists indicating that all  of  the
ozone has  been destroyed.  Specific interferences are unknown, but any oxidant
capable of decolorizing the carmine indigo dye most likely will interfere.

   Effects of interferents should be determined, as should precision, accuracy,
and effects of reagent storage and pH.  The method should be studied  in  direct
comparison  with  other  methods,  such as the indigo and UV absorption methods.
Automation of  this method could lead to improved selectivity for ozone.

Anperometry.

   Vith bare  electrode amperemeters, either the solution or  the  electrode  is
rotated  to  establish a diffusion layer, and the electrical current measured is
directly proportional to the concentration of dissolved oxidant  (25).   Commer-
cial   amperometric  analyzers  give  satisfactory  results  provided there is no
oxidant other  than ozone present in the sample.  In many situations they provide
adequate monitoring of total  oxidant.   The  bare  electrode  system  has  good
sensitivity,   and  is applicable as a continuous nonselective monitor for ozone.
When  other oxidants such as chlorine, chlorine dioxide, bromine, and iodine  are
present,  the   technique  has  difficulties.   The exact nature and magnitude of
these interferences requires additional research.
                                      37

-------
    Due to the accumulation of surface impurities at  the  electrode surfaces, all
bare amperometric electrode systems are subject  to  loss of sensitivity with use.
Vith uncovered electrode surfaces, fouling has been observed to be a significant
problem as was the case in earlier tests with oxygen  electrodes.    Additionally,
the  response  is influenced by numerous surface*active agents and also halogens
and oxygen.

    An improvement in the development of amperometric methods for ozone analysis
has been the application of gas-permeable membranes for   increasing  selectivity
and  preventing  electrode  fouling  (26-27).    These Teflon membrane electrodes
exhibit less than 2% interference (in terms of current response)   from  bromine,
hypobromous acid, chlorine dioxide, hydrogen peroxide, nitrogen trichloride, and
hypochlorous acid (26-27).

    This type of amperometric membrane sensor  needs  to   be  developed  further
based  on  the  exhibited  selectivities.   The  most  disturbing attribute is the
temperature dependence.  If different membranes  could maintain selectivity while
minimizing the temperature effect, this  type  of   sensor  could  become  highly
recommended.

    The application of positive voltage potentials  and the use of polymeric mem-
branes that are selectively permeable to gases has  enhanced the opportunity  for
selective  measurement  of  ozone.   This is a very significant improvement over
bare amperometric electrodes as well as  most  older  colorimetric/spectrophoto-
metric  and  titrimetric methods.  Vith an applied  voltage of +0.6 V (vs SCE) at
the  cathode,  only  the  most  powerful  oxidizing  agents  can  overcome  the
"resistance" of this anodic voltage and cause electron flow cathodically through
the  electrochemical  circuit.  This general approach should continue to be used
in future electrochemical developments.

Other Electrochemical Methods.

    In the differential pulse  polarography  procedure  (DPP),  a  predetermined
amount  of  phenylarsine  oxide (PAO) is added in excess  to an ozone solution to
reduce the levels of dissolved ozone  present.   Excess   PAO  then  is  measured
quantitatively   by   pulse   polarography.   The   DPP  method may  under some
circumstances be useful in the research laboratory.   The  prospects of its use in
the plant or field are not as promising since a  higher degree of  operator skill
is required.

    Potentiometry involves the  cathodic  reduction  of   dissolved  ozone.   The
diffusion-limiting  current  measured  is  proportional   to the concentration of
ozone in the water.  Further evaluation of  potentiometric  systems  may  be  in
order.    However,  the  fundamental  problems   of  electrode  fouling  must  be
addressed.  Perhaps a combination  of  membranes and potentiometric  detection
would  produce  a promising system for ozone determinations.   The system appears
to have modest potential for development.,

ultraviolet Measurements.

    Ultraviolet absorption measurements also can be used   for  residual  aqueous
ozone   at  258-260  nm.   There  is  uncertainty   with   respect   to  the molar
absorptivity for aqueous ozone.  In the literature, values ranging from 2900  to


                                      38

-------
3600 M^cm'1  are reported.  This uncertainty in the molar absorptivity is
critical   to   the  future  use and calibration uses of the UV methods.  Clearly.
further work  to verify this value is strongly recommended.

   If the molar absorptivity for ozone is known unambigiously, UV absorption is
in principle  an absolute method for the determination of  ozone,  which  is  not
dependent  upon calibration or standardization against other analytical methods.
Therefore, it can be used for calibration of other analytical methods for ozone.
It is  specific to the determination of ozone, and is applicable  to  measurement
in gaseous and aqueous phases.

Physical  Methods.

   The   calorimetric  method  is  based  on  the  enthalpy  of  the   catalyzed
decomposition  of  ozone (AH  - 144.41 KJ/mole).  The calorimetric determination
of ozone  is  calibration-independent.   The  technique  is  specific  to   the
determination  of  molecular ozone, but is applicable to measurement only in the
gas phase. However, the higher the concentration of ozone in the gas phase, the
more  accurate the method appears to be, since a greater  temperature  difference
is observed.   Potential interferents have not been reported.

   The method has been shown to agree with iodometric and  UV  absorption  pro-
cedures,   particularly  for  the measurement of ozone in the gases exiting ozone
generators.  Therefore, the procedure can  be  used  to  monitor  applied  ozone
dosages.    Additional  detailed  interlaboratory  comparisons need to be carried
out.

   The  isothermal differential pressure procedure is based on the generation of
an increased  number of gas molecules during  the  UV  destruction  of  ozone  at
constant   temperature.   When  this  reaction  is  carried out isothermally in  a
closed vessel, the increase in pressure of the contained gas is proportional  to
the  ozone concentration.   In  principle,  this  procedure  achieves a totally
physical  ozone  measurement  without  requiring  calibration  using  a  chemical
method.    Various  automated  instrumental  checks  such  as  the  stored  molar
absorptivity,  the  age  of  the  UV  light  source,  the  zero  point  reading,
measurement of the flow of the test gas and the flushing gas, and the reading of
the diagnostic display are possible.

    No specific comparisons are reported.  However, in principle it appears that
this physical method is the best candidate for calibrating the gas  phase  ozone
instruments  currently being used for ozonation control.  As long as pure oxygen
is used for ozone generation this method would  be  free  of  interferences  and
would  be  subject  only  to strict temperature control of the measurement cell.
Further study of this system would be necessary before it could  be  recommended
for further consideration.


General  Summary and Recommendations for Ozone.


    In comparing all the methods to the "Ideal Method" we find  that  none  come
close  to  our  ideal  standard.  Continued development of the various selective
aethods will, however, come closer and closer to the ideal.
                                      39

-------
    In terms of gas phase measurements, none of   the  existing  methods  can  be
recommended  for  accurate  determinations of  ozone.   If a relative value of the
ozone concentration is needed for control purposes,  most of the methods reported
could be applicable.

    The accurate determination of ozone in the aqueous phase is  complicated  by
the decomposition of ozone, its reactivity to  the other species present,  and the
by-products  of  the  ozonation  reactions.  Most current methods were developed
without a clear knowledge of the associated ozone chemistry.  Therefore most  of
the  methods  are  unacceptable  or  cannot  be   recommended.   In particular, no
iodometric based chemistry is acceptable for the  determination of aqueous ozone.
Indigo trisulfonate and arsenic(III) direct oxidation  are  acceptable  methods.
Amperometery continues to improve -- especially as an automated control method.

    The stripping  techniques  have  some  merit   in  terms  of  improved ozone
selectivity.   However,  automated  chemical   systems  such  as  flow  injection
analysis offer considerably more promise.  The current GD-FIA  indigo  procedure
is superior for residual ozone measurements due to its selectivity for ozone.

    The most important aspect of any potential new or improved ozone  analytical
method  will  be  speed  of analysis and selectivity of the detection system for
only ozone.  As a point of comparison, we strongly recommend that all future and
existing methods be compared against the "Ideal Method".
LITERATURE
 1.     Symons, J.M.; et al  "Ozone, Chlorine Dioxide  and Chloramines as
             Alternatives to Chlorine for Disinfection  of  Drinking  Water*  in
             Water  Chlorination:  Environmental  Impact and Health Effects. Vol.
             2,, Jolley, RoL.; Gorchev, H. and Hamilton,  D.H.,  Jr., Editors, (Ann
             Arbor, MI: Ann Arbor Science Publishers,  Inc.,  1979)    pp.   555-560
             and  Complete  Report  entitled "State  of the Art ..." (Cincinnati,
             OH: U.S. EPA, November. 1977), 84 pp.

 2.     Proceedings of Seminar on "The Design and Operation of Drinking Water
             Facilities Using Ozone or Chlorine Dioxide",   Rice,   R.G.,   Editor,
             (Dedham, MA:  New England Water Works Assoc., 1979).

 3.     Miller, G.W.; Rice, R.G.; Robson, C.M.; Scullin,  R.L.; Kuhn. W. and
             Wolf,  H.,   "An  Assessment  of   Ozone    and   Chlorine   Dioxide
             Technologies  for  Treatment  of  Municipal  Water  Supplies", U.S.
             Environmental Protection Agency,  EPA   Project Report,  EPA-600/2-
             78/018, 1978, 571 pp.

 4.     Miltner, R.J.  "Measurement of Chlorine Dioxide and Related Products",
             in Proceedings  of  the  Water  Quality  Technology]  Conference.
             (Denver, CO: American Water Works Assoc.,  1976),  pp.  1-11.
                                      40

-------
 5.     Gordon, C.  "Improved Methods of Analysis for Chlorate, Chlorite,
            and Hypochlorite Ions at the Sub*mg/L  Level",  U.S.  Environmental
            Protection Agency, EPA Technical Report, EPA-600/4-85/079. October.
            1985, 35 p. and Presented at AUWA WQTC, in Proc. AWUA Water Quality
            Technology Conference. December. Nashville, TN, 1982, pp. 175-189.

 6.     Aieta, E.M.; Roberts, P.V.  "Chlorine Dioxide Chemistry:  Generation
            and Residual  Analysis"  in  Chemistry  in  Water  Reuse.  Vol.  i.
            Cooper,  W.J., Editor (Ann Arbor, MI: Ann Arbor Science Publishers.
            Inc., 1981). pp. 429-452.

 7.     Hoigne, J.; Bader, H. "Bestimmung von Ozon und Chlordioxid in Vasser
            mit der  Indigo-Methode"  ("Determination  of  Ozone  and  Chlorine
            Dioxide  in  Vater With the Indigo Method").  Vom Uasser, 1980, £5_,
            261-280.

 8.     Gilbert, E.; Hoigne, J.   "Messung von Ozon in Vasserwerken; Vergleich
            der DPD- und Indigo-Methode"  ("Ozone Measurement in Vater Treatment
            Plants:  Comparison  of  the  DPD  and   Indigo   Methods").   GFW-
            Vasser/Abvasser. 1983, 124. 527-531.

 9.     Schalekamp, M.  "European Alternatives and Experience" in Proceedings
            of  the  National  (Canadian)   Conference  on  Critical  Issues   in
            Drinking   Water  Quality. (Ottawa, Ontario, Canada:  Federation  of
            Associations on Canadian Environment, 1984), pp. 140-169.

10.     Ikeda, Y.; Tang, T-F.; Gordon, G.  "lodometric Method of Determination
            of Trace Chlorate Ion", Anal. Chem., 1984, !£, 71-73.

11.     Emmenegger F.; Gordon, G.  "The Rapid Interaction between Sodium
            Chlorite and Dissolved Chlorine", Inorg. Chem., 1967, &, 633-635.

12.     Aieta. E.M.; Berg. J.D.   "A Review of Chlorine Dioxide in Drinking
            Water Treatment*. J. Am. Vater  Vorks Assoc.. 1986, IS., 62-72.

13.     Standard Methods for The  Examination of Vater and Vastewater. 16th
            Edition. Greenberg,  A.E.; Trussell, R.R.; Clesceri, L.S.;  Franson,
            M.A.H.,  Editors (Vashington, D.C.:  American Public Health Assoc.,
            1985), 1268 pp. and  15th Edition. Greenberg, A.E.;  Connors,  J.J.;
            Jenkins.  D.;  Franson,  M.A.H., Editors (Vashington, DC:  American
            Public Health Assoc.. 1980). 1134 pp.

14.     Vhittle. G.P.; Lapteff, A., Jr.  "New Analytical Techniques for the
            Study  of  Vater  Disinfection"  in  Chemistry  of  Vater   Supply.
            Treatment,  and  Distribution.  Rubin, A.J., Editor, (Ann Arbor, MI:
            Ann Arbor Sci. Pub., Inc., 1974), pp. 63-88.

15.     Tomiyasu, H.; Fukutomi, H.; Gordon,  G.  "Kinetics and Mechanism of
            Ozone Decomposition  in Basic Aqueous Solution", Inorg. Chem., 1985,
            £4.. 2962-2966.
                                     41

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16.      Grunwell,  J.;  Benga,  J.;  Cohen, H.,  Gordon, C. "A Detailed Comparison
             of Analytical Methods for Residual Ozone Measurement",  Ozone  Sci.
             Eng., 1983.  I. 203-223.

17.      Flamm,  D.L.;  Anderson,  S.A.  "lodate Formation and Decomposition in
             lodometric Analysis  of Ozone",   Environ. Sci.  Technol.,  1975, 2,
          .   660-663.

18.      Rehme.  K.A.;  Puzak, J.C.; Beard, M.E.;  Smith, C.F.; Paur, .R.J.
             "Evaluation of Ozone Calibration  Procedures",  U.S.  Environmental
             Protection   Agency,   EPA   Project   Summary,  EPA-600/S4-80-050,
             February, 1980,  277  pp.

19.      Liebermann, J., Jr.;  Roscher,  N.M.;  Meier, E.P.; Cooper, W.J. Develop-
             ment of the FACTS  Procedure for  Combined  Forms  of  Chlorine  and
             Ozone  in  Aqueous  Solutions",  Environ.  Sci. Technol.. 1980, 14,
             1395-1400.

20.      Palin,  A.T.;  Derreumaux,  A.  "Determination de l'Ozone Residuel dans
             1'eau" ("Determination of  Ozone  Residual  in  Water"),  L'Eau et
             1'lndustrie. 1977, 1£. 57-60.


21.      Bader,  H.; Hoigne, J.  "Colorimetric Method for the Measurement
             of Aqueous Ozone Based on the Decolorization of Indigo
             Derivatives", in Ozonlzation Manual for Water and Wastevater
             Treatment. Masschelein, W.J., Editor, (New York, NY:  John
             Wiley & Sons, 1982), pp.  169-172.

22.      Bader,  H.; Hoigne, J.  "Determination of Ozone in Water by the
             Indigo Method",  Water Research 1981, 15., 449-456.

23.      Bader,  H.; Hoigne, J.  "Determination of Ozone in Water by the Indigo
             Method;  A Submitted Standard  Method",  Ozone:  Science  and  Eng.,
             1982, 4, 169-176.

24.      Straka, M.R.; Gordon, G.; Pacey, G.E.  "Residual Aqueous Ozone Deter-
             mination by Gas Diffusion Flow Injection  Analysis",  Anal.  Chem.,
             1985. 51, 1799-1803.

25.      Masschelein,  W.J.  "Continuous Amperometric Residual Ozone Analysis
             in the Tailfer (Brussels, Belgium) Plant",  in  Ozonization  Manual
             for Water and Wastevater Treatment. Masschelein, W.J., Editor, (New
             York, NY:  John Wiley & Sons, 1982), pp. 187-188.

26.      Stanley, J.H.; Johnson, J.D.  "Amperometric Membrane Electrode for
             Measurement of Ozone in Water", Anal. Chem., 1979, 51. 2144-2147.

27.      Stanley, J.W.; Johnson, J.D.  "Analysis of Ozone in Aqueous Solution",
             in Handbook of Ozone Technology and  Applications.  Vol.  1,  Rice,
             R.G.   and Netzer,  A., Editors (Ann Arbor, MI:  Ann Arbor Sci. Pub.,
             Inc., 1982), pp. 255-276.
                                      42

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A GUIDE FOR EFFICIENT USE OF THIS REPORT (AND A BRIEF GLOSSARY OF TERMS)


    This Report contains a very detailed review  of  all  disinfectant  residual
measurement  methods.  The Executive Summary is intended to give readers a brief
overview of the advantages and disadvantages of each method.  To that end, Table
I (Characteristics and Comparisons of Analytical Methods) has been  included  to
summarize  each  of our findings and to recommend possible directions for future
research.   In  addition,  Table  II   (Equivalent   Weights   for   Calculating
Concentrations on the Basis of Mass) describes the equivalent weights of each of
the  disinfection  species  in  terms  of  the  actual reactions involved in the
disinfection process.

    Each chapter contains individual recommendations following the discussion of
the method.  A summary of all of the recommendations is also given at the end of
each chapter.  Additional help is  given  by  means  of  an  alphabetical  Index
containing  more than 2500 individual terms.  Specific cross referencing for all
recommendations can be found in the Index either under the •recommendation", or,
in terms of the subject of the numbered recommendation itself.

    The term Referee Method is used to  describe  appropriate  comparisons  with
existing  methods  and  Standard  Methods  refers  to a specifically recommended
method.  The Index should be  an  additional  aid  to  finding  the  details  of
specific methods.

    In this context, it should be noted that the individual literature citations
are specific to each individual chapter -• and are either numbered  individually
within chapters 2 and 3, or alphabetically sequenced within chapters 4 and 5.

    Chapter 4 (Indexed Reference Citations) has been included in this report  in
order  to  assist  readers  in  locating  particular papers of interest.  The 48
categories for chlorine, chloramines, and the oxy-chlorine species,  along  with
the  additional  60  categories  for  ozone, should make the task of finding in-
dividual papers of interest considerably less cumbersome.  Papers which describe
several methods have been included in each of the appropriate  categories.   All
together,  the  1,400  references  cited  in Chapters 1-3 number more than 2,000
individual citations when distributed in the indexed form of Chapter 4.

    Chapter 5 is an alphabetical listing of the individual references citations.
Finally, a detailed Index has been  included  in  order  to  assist  readers  in
locating  subjects  of  specific  interest.  We hope the readers will find these
additional chapters as useful as have we in preparing this report.

    A brief Glossary follows on the next page in order to assist readers in  the
various specialized terms and abbreviations used in this report.  For additional
terms, the reader is referred to the Index.
                                      43

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GLOSSARY

    Accuracy -- the ability to determine the correct concentration

    BAKI -- boric acid buffered potassium iodide method for ozone

    Breakpoint -- the inorganic reaction of chlorine with ammonia nitrogen

    CDFW -- chlorine demand free water

    Combined Chlorine -- inorganic and organic chloramines

    Detection Limit --a signal that is 3 times the noise level of the system

    DOC -- dissolved organic carbon

    DPD -- (N,N-diethyl-p-phenylenediamine)

    FACTS •- free available chlorine test with syringaldazine

    FIA -- flow injection analysis, an automated analysis procedure

    Free Chlorine -- the species, C12 + HOC1 + OC1"

    KI •• potassium iodide method for ozone

    LCV -- leuco crystal violet

    mL -- milliliter(s), standard unit of volume

    Molar Absorptivity (e) reported in units of M"lcm"1

    NBKI -- neutral buffered potassium iodide method for ozone

    Precision =- how well the method reproducibly measures the same
                 concentration

    Reactive Intermediate -- species such as 02",  H02~, H0a,  OH. 0,~,  etc.

    Referee Method -- the method aqainst which a working method is compared

    Sensitivity -- the change in signal per unit concentration [i.e.  Amps/mol]

    Standard Methods -- the  book,  Standard  Methods  for  the  Examination of
                 Water and Wastewatcr published by APHA, AWWA, and WPCF

    THM's -- trihalomethanes

    Total Chlorine -- the combination of Free Chlorine  and Combined Chlorine

    TOC -- total organic carbon

    TOX -- total organic halogen


                                      44

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       APPENDIX E

 IKACTIVATIONS ACHIEVED
BY VARIOUS DISINFECTANTS

-------
MBIH
   UJ'U
i.a   1.3
7.3   3.0
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44
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35
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107
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112
114
lit
117
111
121
122
107
113
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1:4
130
134
137
149
142
143
147
141
131
133
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131
143
131
134
140
144
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171
174
174
171
111
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45
47
tl
70
71
72
71
74
75
74
10
14
tl
14
17
100
102
IM
104
IOI
110
III
III
114
107
113
121
124
110
113
134
131
142
144
144
141
130
132
134
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131
137
147
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170
174
177
110
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200
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33
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41
42
43
43
44
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47
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70
74
77
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11
17
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73
10
14
n
11
«
15
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101
102
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105
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3.0
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14
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112
114
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121
121
125
124
121
1*1 luctioitiMi
0.3 1.0









14
19
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10 It
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21
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27
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30
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21
31
37
34
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34
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91
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13
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30
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41
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41
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3.0
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11
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101
107
104
103
107
IN
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tl
13
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100
2.9
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104
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3.0
103
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171
177
111
134
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lit
147
144
144
141
ISO
let Iucti>iti9*t

1
1
10
10
11
11
11
11
17
17
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11
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20
71
21
27
27
71
21
24
24
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29
29
1 ,
14
21
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32
31
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34
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44
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3:
94
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U
70
71
77
73
74
73

-------
        TMIE E-4
    CT V»ltltS rw INACTIVMIW
OF CIMDlt ttSTS IT «EE 00.0*1 IE
         •I 25 C
rnffiTfitTIftM
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0.8
1
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2.4
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3

CR.3MSE
(eg/I)
<0.4
0.4
0.9
1
1.2
1.4
1.4
l.B
2
2.2
2.4
2.4
2.B
3
log

1
1
1
1
1
10
10
10
10
10
1C
11
11
5 11

log
0.1 1.0
7 14
15
14
17
17
18
IB
18
It
10 It
10 11
10 20
10 20
10 20
Inictititior.t

11
12
13
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11
14
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14
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11
14
17
18
11
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11
20
70
71
;i
71
22
22
pH«7.i

11
71
77
77
73
74
24
21
75
74
74
77
77
77


73
25
74
77
78
71
21
30
30
31
Jl
32
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3:

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l.i
21
23
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28
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2.0
28
30
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pH=8.0
7 ^
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13
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77
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14
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100

-------
                TABLE E-7

    CT VALUES FOR GREATER THAN 4 LOG
INACTIVATION OF VIRUSES BY FREE CHLORINE
Temperature (C)
pH 0.5 5 10 15
6.0 31 22 16 11
6.5 38 27 20 14
7.0 47 33 25 17
7.5 56 40 30 20
8.0 67 48 36 24
8.5 80 57 43 28
9.0 93 66 50 33
TABLE E-8
CT VALUES FOR
CHLORINE DIOXIDE INACTIVATION
OF GIARDIA CYSTS pH 6-9
Temperature (C)
Removal 0.5 5 10 15
0.5 log 13 9 7 4.5
1 log 27 18 13 9
1.5 log 40.5 27 20 13.5
2 log 54 36 27 18
2.5 log 67 45 33 22.5
3 log 81 54 40 27
20 25
8 5
10 7
12 8
15 10
19 12
21 14
25 17


20 25
3 2
7 5
10.5 7
14 9
17.5 11.5
21 14

-------
                                   TABLE E-9

                       CT VALUES FOR GREATER THAN 4 LOG
                  INACTIVATION OF VIRUSES BY CHLORINE DIOXIDE

0.5
13

Removal
0.5 log
1 log
1.5 log
2 log
2.5 log
3 log


Temperature (C)
5 10 15 20
8753
TABLE E-10
CT VALUES FOR
OZONE INACTIVATION OF
GIARDIA CYSTS pH 6-9
Temperature (C)
0.5 5 10 15 20
0.8 0.5 0.4 0.4 0.3
1.7 1 0.8 0.7 0.5
2.3 1.5 1.3 1.0 0.8
3.3 2 1.7 1.3 1.0
3.7 2.5 2.1 1.7 1.2
4.5 3 2.5 2 1.5
TABLE E-ll
CT VALUES FOR GREATER THAN 4 LOG
INACTIVATION OF VIRUSES BY OZONE pH 6-9
Temperature (C)

25
2.


25
0.2
0.3
0.5
0.7
0.8
1.0


0.5             5              10             15             20             25

0.8            0.5             0.4            0.4            0.3            0.2

-------
                  TABLE E-12

                 CT VALUES FOR
CHLORAMINE INACTIVATION OF GIARDIA CYSTS pH 6-9
Removal
0.5 log
1 log
1.5 log
2 log
2.5 log
3 log

0.5
>5,000
Temperature (C)
0.5 5 10 15 20
690 363 337 250 181
1,295 737 675 505 366
1,900 1,100 925 750 550
2,590 1,435 1,349 1,009 738
3,154 1,826 1,536 1,245 913
3,800 2,200 1,850 1,500 1,100
TABLE E-13
CT VALUES FOR GREATER THAN 4 LOG
INACTIVATION OF VIRUSES BY CHLORAMINES
Temperature (C)
5 10
>5,000 >5,000

25
130
260
375
532
623
750

15
>5,000

-------
    APPENDIX F
BASIS FOR CT VALUES

-------
                                  APPENDIX F
                              BASIS FOR CT VALUES
                              (from Regli, 1987)

Free Chlorine
     The CT     values  for  free chlorine in  Tables E-l through E-6 are based
           77 • 7
on animal infectivity data by Hibler et al. (1987), and regression analysis of
Hibler's data by Clark  et al.  (1987).  As a  safety factor,  the CT     values
                                                                   yy • y
are defined  as those  needed to  achieve  99.99 percent  (4  log)  inactivation
under experimental conditions.   If this  safety factor were  not  applied,  the
CT     values in the  appendix would be about 25 percent lower.
  77 . 7
     Hibler's data were  developed at temperatures  of  0.5  C  to 5 C,  pH levels
from 6 to 8,  and free chlorine  concentrations between 0.44 mg/L to 4.23 mg/L.
Clark's model equation:
               n 00,1-7 o°-1758  o2-7519 *.   -0.1467
          CT  =  0.9847 C       pH       temp
was applied to  generate CT values for chlorine concentrations from 0.4 mg/L to
3.0 mg/L, pH  concentrations from 6 to 9, and temperatures from 0.5 C to 5 C.
     CT values  for temperatures above  5  C  were estimated assuming  a twofold
decrease for  every 10 C.  CT values for temperatures  at  0.5 C were estimated
assuming a 1.5  times increase to  CT values at 5 C.   This general principle is
supported by  Hoff (1986).
     Application of  Clark's model  to pHs  above 8, up to 9,  was  considered
reasonable because the  model is substantially  sensitive  to pH  (e.g.,  CTs at
pH 9 are over three times greater  than  CTs at pH 6 and over two times greater
than CTs at pH 7) .  At  a  pH of  9 about four  percent of the  hypochlorous acid
fraction of  free chlorine  is  still  present.  Recent data  indicate  that in
terms of HOC1 residuals (versus total free chlorine residuals including HOC1
and ~OC1)  the   CT  products  required for  inactivation of Giardia muris  and
Giardia lamblia cysts decrease  with increasing pH  from 7  to  9 (Leahy et al.,
1987;  Rubin et al., 1987).   However,  with increasing pH,  the fraction of free
chlorine existing as  the weaker oxidant species  (OC1 ) decreases.  In terms of
total free chlorine residuals  (i.e.,  HOC1 and  OCl")  the  CT products required
for inactivation of Giardia muris cysts increase  with  increasing pH from 7 to
9 but less than by a factor of  2  at concentrations of less than 5.0 mg/L  (see
                                      F-l

-------
Table F-l) .   Also,  the  significance  of pH  on  the  value  of  CT products
achieving  99 percent   inactivation  appears  to   decrease  with   decreasing
temperature  and free  chlorine concentration.   The  relative effects  of pH,
temperature, and chlorine concentration, inactivation  of Giardia muris cysts
appears  to  be  the  same  for Giardia  lamblia  cysts  (Rubin et  al.,  1987),
although not as much data for Giardia lamblia cysts as  for Giardia muris cysts
is yet available for high pH and temperature values.
     The CT  values for the various  log removals for free  chlorine in Appen-
dix E were  determined by  extrapolation of CT  99.9 values  using first order
kinetics  (i.e., CTnn  = 1/3 x CTon _) .   This  extrapolation appears  reasonable
                   yu            yy.y
based on comparison with CT   values determined by Jarroll, et al.  (1981).

Chlorine Dioxide and Ozone
     The CT values for chlorine dioxide in Table E-8 are based on disinfection
studies using in vitro excystation of Giardia muris cysts (Leahy, 1985).  CT
values  at 5 C  and pH 7  ranged  from  7 to  18  (disinfectant  concentrations
ranging from 0.1 to  5 mg/L).   The highest CT  value,  18, was  used as a basis
for extrapolation  to  obtain the  CT    and CT     values  in Table E-8.   First
                                    yo       9y.9
order kinetics and a safety factor of 3 were assumed, i.e.,
          CTQQ Q = 3 x CTno x 3 or 3 x 18 x 3 = 81
            99.9   -     99        -

CT values  at 0.5 C and 15 C were  estimated,  based on  the  same  rule of thumb
multipliers assumed for free chlorine, as already discussed.
     The CT  values for ozone in Table E-10 are  based on disinfection studies
using in vitro excystation of Giardia lamblia  (Wickramanayake, G. B., et al.,
1985).   CT9Q values  at  5 C  and  pH 7  for  ozone  ranged from  0.46 to  0.64
(disinfectant concentrations  ranging from 0.11  to 0.48 mg/L).   No  CT  values
were available for other pHs.  The highest CT value, 0.64, was used  as a basis
for extrapolation  to  obtain  the  CT    and  CT     values  applying  the  same
                                     90        99.9
principles as discussed for chlorine dioxide.
     A much larger safety factor was applied to the ozone and chlorine dioxide
data than to the chlorine data because:
     a.   Less data were available  for ozone and  chlorine  dioxide than for
          chlorine;
                                      F-2

-------
                      TABLE F-l
          CT PRODUCTS TO ACHIEVE 99 PERCENT
INACTIVATION OF GIARDIA MURIS CYSTS BY FREE CHLORINE
Temperature
(C)
1
15
1
15
1
15
(Source: Rubin,
0.2-0.5
500
200
510

440
310
et al., 1987)
Concentration
0.5-1.0
760
290
820
220
1,100
420
(mg/L)
1.0-2.0
1,460
360
1,580

1,300
620

2.0-5.0
1,200
290
1,300
320
2,200
760

-------
     b.    Data  available  for  ozone  and  chlorine  dioxide,  because  of  the
          limitations of the  excystation procedure,  only  reflected up  to or
          slightly beyond  99 percent  inactivation.  Data  for  chlorine,  based
          on animal  infectivity studies  rather than  excystation  procedures,
          reflected inactivation of  99.99 percent.  Extrapolation  of  data to
          achieve  CT values  for  99.9 percent  inactivation  with  ozone  and
          chlorine dioxide, versus the direct determination of  CT  values for
          achieving  99.99 percent   inactivation  using   chlorine,   involved
          greater uncertainty;
     c.    The CT values for ozone and chlorine dioxide to achieve 99.9 percent
          inactivation are feasible to achieve; and
     d.    Use of  ozone and  chlorine  dioxide  is likely to  occur within  the
          plant rather  than  in the distribution system (versus chlorine  and
          chloramines which  are  the  likely  disinfectants  for use  in  the
          distribution  system).   Contact time  measurements  within the  plant
          will involve greater uncertainty than measurement of contact time in
          pipelines.
Chloramines
     The CT  values for  chloramines  in Table E-12  are based on disinfection
studies  using preformed chloramines and jln  vitro excystation  of  Giardia muris
(Rubin,   1987}.    Table  F-2  summarizes CT  values  for  achieving  99 percent
inactivation of  Giardia muris  cysts.  The highest  CT  values  for  achieving
99 percent inactivation at 1  C (2,500) and 5 C (1,430) were each multiplied by
1.5  to   estimate  the   CT      values at   0.5 C  and  5 C,  respectively,  in
                         y y • y
Table E-12.  The CT   value  of  970 at 15 C was multiplied by  1.5 to  estimate
the CT     value.  The  highest CT   value  of  1,500  at 15  C and pH 6  was  not
      y y•y                        yy
used because it appeared anomalous to the other data.  Interesting  to note is
that  among  the  data  in  Table F-2   the CT  values   in  the  lower  residual
concentration range  (<2 mg/L)  are higher  than those  in the higher  residual
concentration range (2-10 mg/L).  This is opposite to the relationship between
these variables which  exists for  free  chlorine,  indicating that for  chlora-
mines, within residual concentrations practiced by water utilities  (less than
10 mg/L), residual concentration may  have greater influence than contact time
on the inactivation of  Giardia  cysts.  No safety factor was applied  to these
data  since  chloramination, conducted in the  field,  is  more effective  than
using preformed chloramines.   Also, Giardia muris appears to be more resistant
than Giardia lamblia  to chloramines (Rubin,  1987).
                                      F-3

-------
CT Values for Inactivation of Enteric Viruses
     CT values for achieving  0.5  log  inactivation of Giardia lamblia are used
for indicating greater  than a 4 log  inactivation of enteric viruses for free
chlorine, chlorine dioxide and ozone.   Since  all systems  are recommended to
achieve at  least a 1 log  inactivation  (in some  cases  allowing  for a 0.5 log
inactivation) of Giardia  lamblia,  CT values  to achieve lower  enteric virus
inactivation are not provided.   The  literature  supports that the CT values
provided herein  achieve substantially greater than a  4  log inactivation for
enteric viruses  (generally by  a factor  of greater  than 3), for  which data
exists  (Hoff, 1986;  Payment et al.,  1983; Liu  et al., 1971; Sobsey  et al.,
1987).  The exception to this is  for Coxsachie  B-5  virus,  but this virus has
never been associated with a waterbome disease.
     The following paper presents a mathematical analysis for determining the
inactivation of Giardia lamblia by chlorine.

References
American  Water   Works   Association.    Water   Chlorination  Principles  and
Practices, 1973.
Hibler,  C.  P.;  C. M.  Hancock;  L.  M.  Perger;  J.   G.  Wegrzn;  K. D. Swabby
Inactivation of  Giardia cysts with Chlorine at  0.5  C to 5.0 C American Water
Works Association Research Foundation, In press,  1987.
Hoff,  J.  Co  Inactivation of  Microbial  Agents  by Chemical  Disinfectants,
EPA/600/52-86/067, U.S. Environmental  Protection  Agency.   Water  Engineering
Research Laboratory,  Cincinnati, Ohio, September, 1986.
Jarroll, E.  L.;  A.  K.   Binham;  E. A.  Meyer  Effect of  Chlorine  on  Giardia
lamblia Cyst Viability.   Appl. Environ. Microbiol., 41:483-487, 1981.
Leahy, J. G.;  Rubin,  A.  J.; Sproul, O. J.  Inactivation of Giardia muris Cysts
by Free Chlorine.  Appl. Environ.  Microbiol., July 1987.
Liu, O. C.;   Seraichekas, H. R.;  Akin, E. W.;   Brashear, D. A.;  Katz, E. L.;
Hill, Jr., W. L.   Relative Resistance of Twenty Human Viruses to Free Chlorine
in Potomac Water.  1971.
Payment, P.;  Trudel, M.;  Plante,  P.   Elimination  of  Viruses  and Indicator
Bacteria at Each Step  of  Treatment During  Preparation of  Drinking Water  at
Seven Water Treatment Plants.   Appl. Environ. Microbiol., 49:1418,  1985.
                                      F-4

-------
                                   TABLE F-2

                           CT VALUES FOR 99 PERCENT
            INACTIVATION OF GIARDIA MURIS CYSTS BY MONOCHLORAMINE*
pH

6
(Rubin et al. ,
Temperature
(C)
15
5
1
15
5
1
15
5
1
15
5
1
1987)
Monochloramine
<0.2
1,500
>1,500
>1,500
>970
>970
2,500
1,000
>1,000
>1,000
890
>890
>890
Concentration (mg/L)
2.0-10.0
880
>880
>880
970
1,400
>1,400
530
1,430
1,880
560
>560
>560
*CT values with ">" signs are extrapolated from the known data.

-------
Regli,  S.    USEPA  Disinfection   Regulations.    Presented  at   AWWA  Seminar
Proceedings:   Assurance  of  Adequate Disinfection,  or CT  or  Not CT.   Kansas
City, Missouri,  June  14,  1987.

Rubin,   A.   J.    Factors   Affecting  the  Inactivation  of  Giardia  Cysts  by
Monochloramine   and  Comparison  with other  Disinfectants.  Presented  at  the
DSEPA/AWWARF Conference,  Cincinnati, Ohio, In press, March, 1987.

Sobsey, M D.;  Fuji,  T.;   Shields,  P.  Inactivation  of Hepatitus  A virus  and
Model   Viruses  in  Water  by   Free  Chlorine.   Presented   at   USEPA/AWWARF
Conference,  Cine.,  OH, March, 1987.

Wickramanayake,  G.  B.;  A.   J.  Rubin;  Sproul, O. J.   Effects   of  Ozone  and
Storage Temperature on Giardia Cysts.  J.AWWA, 77(8):74-77, 1985.
                                      F-5

-------
INACTIVATION OF GIARDIA LAMBLIA  BY CHLORINE:

   A MATHEMATICAL AND STATISTICAL ANALYSIS


                      by
               Robert M. Clark
               Eleanor J. Read
                     and
                 John C. Hoff
        DRINKING WATER RESEARCH DIVISION
     WATER ENGINEERING RESEARCH LABORATORY
       OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY

                May 21, 1987

-------
                 INACTIVATION  OF  GIARDIA LAMBLIA BY  CHLORINE:

                  A MATHEMATICAL AND  STATISTICAL ANALYSIS


                                      by


           Robert M. Clark,3  Eleanor J.  Readb  and  John C. Hoffc


                                 INTRODUCTION


     Waterborne  disease in the U.S. has been reduced by the use of sand

filtration, chlorine disinfection, and  the application of Drinking

Vater Standards.*  The annual number  of all reported waterborne disease

outbreaks dropped from 45 per 100,000 in  1938-1940  to 15 per 100,000 in

1966-1970.  The average annual number of  reported outbreaks ceased to fall

around 1951, and has increased slightly for reasons unknown at this time.

     Amendments to the Safe Drinking Water Act  (PL  93-523) highlight the

continuing problea of waterborne disease  by mandating EPA to promulgate

(a) criteria by which filtration will be  required for surface water supplies

and '(b) disinfection requirements for all water supplies in the United

States.  EPA's Office of Drinking Water is proposing to use the C-t (Concen-

tration times Time - disinfectant residual concentration in ng/L multiplied

by the disinfectant concentration contact time in ninutes)  concept as  one

of the criteria for determining when filtration might not  be  required.   In
aDirector,  Drinking Water Research Division, Water Engineering Research
 Laboratory,  26 W. St.  Clair Street, Cincinnati, OH 45268
"Senior Statistician, Computer Sciences Corporation, 26 W.  St. Clair  St.
 Cincinnati,  OH  45268
cMicrobiologist, Drinking Water Research Division, Water Engineering
 Research Laboratory. 26 W.  St. Clair Street,  Cincinnati, OH 45268

-------
 particular,  the Office  of Drinking Water is interested in applying the C«t




 concept  for  determining the  inactivation of Giardia lamblia cysts, as the




 most  resistant organism for  which such data is available.




      Among individual agents,  Giardia ranks number one in causes of waterborne




 illnesses and number four as an etiological agent for waterborne outbreaks,




 even  though  it was first  identified as a causative agent in the mid-1960's.*




 The combination of resistance  and prevalence have caused Giardia to become




 a major  focus in considering criteria for determining when filtration




vould be required.  The Office of Drinking Water  is developing  criteria under




 which a utility would be  required to meet source  water quality  conditions,




 maintain a protected watershed and achieve C't values which provide a




 99.92 inactivation of Giardia  lamblia cysts,  in order to avoid  filtration.




 Variances from these requirements are being developed.   If,  for example,




 a utility in addition to meeting  other requirements,  can demonstrate  that




 through effective disinfection, manifested by  a sufficient  C*t  value, it




 can reduce Giardia levels by 99.9%,  then  it will  be exempted from  surface



 water filtration.




     In this paper the C*t concept  is  applied  to  inactivation of G_. Lamblia




 by.free chlorination of Giardia cysts.  The disinfection data used are the only




 G. Lamblia inactivation data available  that are based on animal infectivity




 rather than in vitro excystation.






                              THE Ot CONCEPT






     In comparing the biocidal effectiveness of disinfectants, the major




 considerations are the  disinfectant concentration and time needed to attain




 inactivation of  a certain proportion of the population exposed under speci-




fied conditions.   The "C't" concept that is in current use is an empirical




                                     2

-------
 equation stemming  from the early work of Watson^ and is more correctly

 expressed as:

     K - C"t                                                         (1)

 where

     K - constant  for  a specific microorganism exposed  under specific
         conditions

     C - disinfectant  concentration

     n - constant, also called  the  "coefficient of  dilution"

     t - the contact time  required  for a fixed percent  inactivation

 It is based on the van't Hoff equation used  for determining  the nature of

 chemical reactions in  which  the value n determines  the  order of the  chemical

 reaction.''*

     The application of  this equation to disinfection studies  requires

 multiple experiments where the  effectiveness of several variables, such

 as pH, temperature, and  the disinfectant concentration are examined  to

 determine how they affect  the inactivation of  raicrobial pathogens.   The

 disinfection concentration (C),  and time (t),  necessary to attain a  soecific

 degree of inactivation  (e.g. 99Z) are  plotted  on double logarithmic  paper.

 Such a plot results in  a straight line  with slope n.^»6  Figure 1  illustrates

 data plotted in this manner and  also  the  significance of the value of n in

 extrapolation of disinfection data.^  When n equals 1, the C*t value remains

 constant regardless of the disinfectant  concentration used, i.e.,  disinfectant

 concentration and exposure time are of  equal importance in determining the

 inactivation rate,  or the C*t product, K.  If n is greater than 1, disinfectant

concentration is the dominant factor in determining the inactivation rate

while if n  is less  than 1,  exposure tice is nore important than disinfectant

-------
   10.000
UJ
i
h-
_j
o
        0.01
100    '1000
                DISINFECTANT CONC., (MG/L)
      Figure 1.  Effect of n Value on  C't Values at Different Disinfectant
                Concentrations  (C't  Values Given in Parentheses)7

-------
 concentration.  Thus,  the  value of ir is a very important  factor in determining

 the degree to which extrapolation of data from disinfection experiments  is
                            Q
 valid.  In addition, Morris0  pointed out that  the  evaluation of n  is valid

 only if the original experimental data follow  Chick's Law which is  normally

 not the case.  Morris8  further  cautioned as  follows:

          "Watson's law must  be regarded as  purely empirical, handy
     for coordination and  interpolation but  dangerous with respect  to
     extrapolation.  Even  the form has no basic justification.   So
     the relation is uninstructive with regard to  mechanisms  of
     germicidal action.  Intuitively a value of (n) equal  to  unity
     seems natural; indeed, in  most instances  where appropriate
     studies of aqueous disinfectants have been made the  values  found
     for (n) fall within the  range 0.8 to 1.2.  For such  cases  the
     deviations from unity seem more likely  to be  the result  of
     experimental aberration  than to be true variations.

          Greater reproducible  deviations are  observed with a nuaber
     of germicide-microbe  systems,  however,  ranging from  0.5 up  to
     2.0.  Nothing is known so  far about the meaning of these values.
     Yet, their occurrence makes  it difficult  practically  to compare
     the relative potencies of  disinfectnats for these will shift
     with concentrations."


 FACTORS AFFECTING C't

     The destruction of pathogens  by chlorinacion  is dependent on a number

 of factors, including water temperature,  pH, disinfectant contact time,

 degree of mixing, turbidity,  presence  of  interfering substances, and con-

 centrations of chlorine available.   The  pH especially, has a significant

 effect on inactivation efficiency because it determines the species of

 chlorine found in solution.

     The impact of temperature on disinfection efficiency is also signifi-

 cant.   For example,  Clarke's^ work in virus destruction by chlorine indicates

 that contact time oust be  increased  two to three tines when the  temperature

 is lowered 10*C.   Disinfection by chlorination can inactivate Ciardia

cysts,  but only under rigorous conditions.  Most recently, Hoff  et  al.

-------
 concluded  that  (1)  these  cysts  are among the most resistant pathogens




 known,  (2)  disinfection at  low  temperatures  is especially difficult, and  (3)




 treatment  processes prior to  disinfection are important.




      Jarroll £t^£l»11 have  shown  that  99.8 percent of Giardia  cysts can be




 killed  by  exposure  to 2.5 mg/L  of chlorine for 10 minutes at IS'C at pH 6,




 or after 60 minutes at  pH 7 or  8.   At  5°C, exposure to 2  mg/L  of chlorine




 killed  99.8 percent of  all  cysts  at pH 6 and 7 after 60 minutes.  While it




 required 8  mg/L to  kill the same  percentage  of cysts at pB 6 and 7 after 10




 minutes, it required 8  mg/L to  inactivate cysts to the same level at pH 8




 after 30 minutes.   C*t  values for  99%  inactivation of Giardia  lamblia by free




 chlorine at different temperatures  and pHs are shown in Table  1. 'Cyst




 viability following  the chlorine contact  time was  determined by in vitro




 excystation.  Inactivation rates decreased at lower temperatures and at




 higher pHs  as indicated by the higher  C-t  values.




            TABLE 1.  C-t VALUES FOR 99Z  INACTIVATION OF GIARDIA
LAMBLIA CYSTS BY FREE CHLORINE3


Temp
(°C)
5


15


25





pH
6
7
8
6
7
8
6
7
8

Disinfectant
Concentration
(mg/1)
1.0-8.0
2.0-8.0
2.0-8.0
2.5-3.0
2.5-3.0
2.J-3.0
1.5
1.5
1.5
Range

Time
(min)
6-47
7-42
72-164
7
6-18
7-?.l
< 6 ~
< 7
< 8



C-t
47-84
56-152
72-164
18-21
18-45
21-52
< 9
<10
<12


Mean
C-t
65
97
110
20
32
37
- < 9
<10
<12


No. of
Exp.
4
3
3
2
2
2
• 1
1
1
Calculated from Jarroll et al.11

-------
     Quantification of  the  combined" effects  of  pH,  temperature and disin-




fectant concentrations  require  special  techniques which take into account the




interaction of these variables  so they  can be described by a single value.




In the following section, cyst  inactivation  data from  animal infectivity




studies conducted by Hibler12 are described  and the  results of statistical




analysis of this data are presented to  show  what effects the interaction of




chlorine concentration, pH  and  temperature have on  the inactivation of Giardia




cysts.






                            ANIMAL INFECTIVITY DATA






     The cysts of G. lanblia are  among  the most resistant  to disinfection and




chlorine is the most frequently used disinfectant in the U.S.   This  has  led




to widespread examination of C*t  values for  Giardia and  chlorine.   One of the




nost important studies  to examine the effect of chlorine on Giardia  cysts was




conducted by Dr. Charles Hibler at  Colorado  State University.*-   Dr. Hibler




acquired G. lamblia isolates fron several  human sources  and  maintained them




by passage in mongolian gerbils.   Cysts obtained from  these  animals were used




to develop C«t values for 99.99 percent inactivation of  Giardia cysts with




chlorine at temperatures of .5, 2.5 and 5*C and at pH values of 6, 7 and 8.




     In these experiments clean G.  lamblia cysts at a concentration of 1.02 x




10^ cysts/nL were exposed to selected chlorine  concentrations at appropriate




pH and temperature.  At specified  time intervals for each temperature and pH




condition, chlorine activity was  stopped by the addition of sodium thio-




sulfate.  The treated cyst suspension was  centrifuged,  the supernatant poured




off and the cysts rcsuspcndcd in  a small volume of  buffer.  Each of 5 gcrblls




was fed 5 x 10^ of the concentrated chlorino exposed cysts.

-------
 Equal numbers of positive control animals were each orally  inoculated with 50




 unchlorinated cysts maintained and buffered at the sane  temperature and nH as




 the chlorine exposed cysts.  After 6-7 days animals were exaained to determine




 the number per group infected.  Since the test animals had  each received a




 dose of 5 x 10* cysts and since infectivity studies with unchlorinated cysts




 showed that approximately 5 cysts usually constituted an infective dose, the




 following assumptions were made depending on the infectivity patterns occurring




 in the animals receiving chlorine exposed cysts.  If all five animals were




 infected, then it was assumed that the C't had produced less than 99.992




 inactivation and if no animals were infected,  then it had produced greater




 than 99.99Z inactivation.   It is impossible to determine the exact level of




 inactivation for these results.  If,  however,  1-4 animals were infected  then




 it  was  assumed that the level of cysts was about 5 per aniaal since soae were




 infected  and  some were not.   The C't  values for this  breakthrough  group  vere




 then  considered  to produce  99.99% inactivation and these data were used  in




 the statistical  analysis.



 STATISTICAL ANALYSIS



      Table  2  summarizes Hibler's data for the  different  experimental conditions




 examined.   Column 1 in Table  2 shows  the  chlorine concentration in ng/L to



 which cysts were exposed before being fed to the  gerbils  and Column 2 shows the




 number  of experiments  at that chlorine concentration which yielded 1-4 infected




 gerbils out of 5.   Column 3 shows  the mean  cyst exposure  time and Column 4




 contains  mean C-t  values that  are  the product  of  the chlorine concentration




 and cyst  exposure  time.




      In order  to analyze these  data a regression  model that  incorporates the




variables of concentration, pH  and temperature was developed.  This nodel is




as follows:




           t - RCa pHb tcnpc                                        (2)



                                       3

-------
      TABLE 2.  C*t VALUES FOR 99.99 PERCENT INACTIVATION




(1 TO k OF 5 GERBILS INFECTED) AT DIFFERENT TEMPERATURES AND pHs


Chlorine
Concentration
(oR/L)

0.56
0.72
0.75
1.12
1.33
1.51
2.09
2.55
2.90
3.08
3.32
3.32
3.56
3.93

0.53
0.81
0.92
1.26
1.84
2.07
2.59
2.84
3.64
3.80

0.44
0.62
0.78
0.98
1.19
1.56
1.87
1.99
2.05
2.15
2.36
2.93
3.01
3.47


Mean
Cyst
Number of Exposure
of
Time
Experiments (minutes)
pH -
1
2
1
1
1
2
2
2
1
. 3
2
2
2
3
PH -
2
1
1
1
1
1
1
2
3
2
pH -
1 -
1
1
1
3
3
1
3
2
3
1
1
3
2
6 Temperature -
300.0
208.5
272.0
157.0
138.0
99.0
• 66.0
85.0
39.0
85.0
42.5
71.0
42.5
58.5
6 Temperature "
222.0
186.0
71.0
112.0
78.0
68.0
82.0
38.5
55.3
17.5
6 Temperature •
287.0
202.0
224.0
128.0
126.0
53.3
35.0
25.0
71.0
73.7
53.0
43.0
52.7
52.0

Keen
C't
from data
(minutes)
0.5'C
166.5
150.1
204.0
175.8
183.5
149.5
137.9
216.8
113.1
- 263.3
141.1
236.1
151.3
229.9
2.5°C
117.7
150.7
65.0
141.1
143.1
140.8
212.4
109.3
201.4
66.5
5'C
124.8
125.2
174.7
125.4
149.9
83.2
65.5
49.8
145.6
158.4
125.1
126.0
153.5
180.4


Predicted
C't
(minutes)

136.1
142.5
143.5
154.0
158.7
162.3
171.8
178.0
182.0
184.0
186.4
186.5
188.7
192.0

106.6
114.9
117.4
124.2
132.6
135.5
140.9
143.2
149.6
150.7

93.0
99.0
103.1
107.3
111.0
116.4
120.2
— 121.5
122.2
123.2
125.2
130.1
130.7
134.0

-------
Table 2 (Cont'd)


Chlorine
Concentration


Mean
Cyst
Number of Exposure
of
Time
(ng/L) Exuerinents (minutes)

0.51
0.52
0.73
0.75
0.82
1.51
1.98
2.14
2.78
3.11
4.00
4.01
4.05

0.64
0.78
1.04
1.08
1.65
2.06
2.09
2.25
2.53
2.98
3.37
3.47
3.81
4.23
-
0.73
1.08
1.36
1.57
2.22
2.51
2.61
2.69
3.00 —
3.14
3.15
3.16
3.31
4.C3
pH -
1
1
1
1
2
1
1
1
1
1
1
1
1
pH -
1
1
1
1
1
1
1
1
1
1
1
1
1
1
pH -
1
1
1
1
1
1
1
1
1
1
1
2
1
1
7 Temperature -
600.0
300.0
400.0
400.0
333.5
200.0
130.0
126.0
109.0
' 93.0
75.0
75.0
75.0
7 Temperature •
350.0
334.0
250.0
244.0
155.0
121.0
127.0
55.0
89.0
93.0
103.0
66.0
58.0
75.0
7 Temperature «
227.0
152.0
106.0
106.0
66.0
67.0
60.0
63.0
54.0
56.0
67.0
47.0
67.0
50.0

Mean
C't
from data
(minutes)
0.5°C
303.6
156.0
292.0
300.0
271.8
302.0
256.8
269.6
303.0
289.?
300.0
300.8
303.8
2.5°C
224.0
260.5
260.0
263.5
255.8
249.3
265.4
123.8
225.2
277.1
347.1
229.0
221.0
317.3
5°C
165.7
164.2
144.2
166.4
146.5
168.2
156.6
169.5
162.0
175.8
211.1
148.5
221.8
204.0
•

Predicted
C-t
(minutes)

204.7
205.7
218.3
219.3
222.6
248.1
260.0
263.7
276.2
281.7
294.4
294.5
295.0
•
168.5
174.4
183.5
184.7
199.7
206.9
207.4
210.1
214.5
220.8
225.6
226.7
230.5
234.8

155.7
166.8
173.7
178.2
189.4
193.5
194.8
195.9
199.6
201.3
201.4
201.5
203.1
210.7
      10

-------
Table 2 (Cont'd)


Chlorine
Concentration


"umber
of
Mean
Cyst
of Exposure
Time
(ms/L) Experiments (minutes)

0.49
0.51
0.75
1.10
1.25
2.05
2.06
2.66
3.03
3.25

0.50
0.66
0.73
1.01
1.15
1.22
1.62
1.90
2.04
2.25
2.59
2.87
3.02
3.24

0.48
0.76
0.95
1.29
1.49
1.81
1.91
2.06
3.00
3.02
3.67
pH -
2
3
2
1
3
2
3
1
2
3
pH - 8
3
2
2
2
1
3
1
1
1
1
1
1
1
1
pH -
1
1
2
2
1
1
1
1
1
3
1
8 Temperature -
593.0
311.0
250.0
395.0
294.0
' 191.0
. 193.7
132.0
173.5
133.3
Temperature • 2
390.3
342.0
431.0
231.0
207.0
212.7
217.0
195.0
128.0
130.0
135.0
126.0
109.0
54.0
8 Temperature •
417.0
263.0
288.0
241.5
235.0
213.0
137.0
180.0
95.0
116.0
95.0

Mean
C't
from data
(minutes)
0.5°C
290.6
158.6
187.5
434.5
367.5
391.6
399.0
351.1
525.7
433.3
.5°C
195.2
225.7
314.6
233.3
238.1
259.5
351.5
370.5
261.1
292.5
349.7
361.6
329.2
175.0
5°C
200.2
199.9
273.6
311.5
350.2
385.5
261.7
370.8
285.0
350.3
348.7


Predicted
C-t
(ninutes)

293.9
296.0
316.7
338.8
346.5
378.0
378.3
395.7
404.9
409.9

232.9
244.6
249.0
263.6
269.7
272.5
286.4
294.5
298.2
303.4
311.0
316.7
319.5
323.5

208.9
226.5
235.5
248.6
254.9
263.8
266.3
269.9
288.3
288.6
298.7
       1!

-------
 where



          t  -  time  to  99.99Z inactivation as determined from animal infectivity




          C  •  concentration of  disinfectant




         pH  •  pH at which  experiment was conducted




       temp  -  temperature  at which experiment was conducted




   R,a,b,c  -  constants determined from regression




 A log  transform of equation 2  yields:




   log (t)  -  log (R) + a  log (C)  + b log 
-------
     Equation  (5)  can be shown to be equivalent  to equation (1)  (Watson's




Law) by dividing both sides  of equation (5)  by "Ca~ which  yields:




     C~a't  -  R pHb  tempc                                           (6)




Assume a constant  pH • pH and  a constant  temp  -  temp




     K - R pHb tempc                                                (7)




     C-a-t - K




where




     -a - n in equation (1)






EXTRAPOLATIONS




     Equation  (5)  should be  used only over the ranges for which it was derived:




0.44 og/L £ C £ 4.23 mg/L; 6 £ pH £ 8;  0.5*C £ temp £ 5*C;  inactivation level




of 99.992.  However  there  are  well  established kinetic principles that can be




applied to the results  from  equation (5). For  example, as indicated by Clarke^,




and Hoff7 the C-t  value  decreases to 1/2  the previous value with every 10*C




increase in temperature.



     Extrapolations  from one C-t  value  at a given Inactivation level to a




different C-t value  at  another inactivation can also be cade based on first




order kinetics.  It  is  a well  known  fact  that the inactivation of micro-




organisms by disinfectants can  be considered as having the characteristics  of




the first order chemical reaction,  the  disinfectant and the oicroorganlsm




constituting the reactants.7  This has  generally been expressed in turns  of




Chick's Law which may be written.as  follows:




     In N/No - -rt                                                  (8)




where N/No is the fraction of the original number of organisms remaining  at




tine t,  and r is  the proportionality constant.   To illustrate the extrapolation




procedures assume an inactivation level of 90% at time  tj.   Using equation  (8)






                                      13

-------
yields:

     In 0.10 - rti                                                    (9)

Assuming another  inaetivation level of 99% at time t2 and using equation

(8) yields:

     In 0.01 - rt2                                                   (10)

If we assume Watson's law with a  value of n - 1 then at tj and t2^

     C'tl - K!                                                       (11)
Making the appropriate substitutions  into equations :(9)  and (10)  yields:

     In 0.10     KI
     - -  —                                                  (13)
     In 0.01     *2


     -2.3026     KT
                                                                     (1A)
     -4.6052     K2

or

     K2 - 2 K!                                                       (15)

A general relationship that relates Ot values at different inaetivation

levels is:

     In (Ni/Nj,)    Ki
     - -- -                                                (16)
     In (Nj/No:    Kj

where N^ is the number of organism left at time tj- and Nj is the number of

organisms left at time tj .  Table 3 summarizes the multiplication factors to

be applied, assuming first order kinetics, to convert a value of K^ to an

equivalent value of K.

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       TABLE 3.  MULTIPLICATION  FACTORS TO CONVERT  C-t VALUES FROM ONE

                 INACTIVATION LEVEL Kj_ TO INACTIVATION LEVEL Kj
    From
    Inactivation
    Level i
to Inactivation
        Level j
Multiplyer for
                                            90
                               99
        99.9
         99.99
                 90
                 99
                 99.9
                 99.99
                        1/2
                        1/3
                        1/4
 2.0

 2/3
 1/2
 3.0
1 1/2

  3/4
 4.0
 2.0
1 1/3
Using these veil established principles it should be possible to fix chlorine

concentrations, pH and teoperature to determine a value for C*t.  Then using

kinetic principles an extrapolated C»t can be calculated for.the desired temp-

erature conditions.  Another extrapolation that can be made is to estimate

the C't levels that would be required for different levels of inactivation,

for a given temperature, pH and concentration.

     For example, if one wishes to use equation (5) to calculate the C*t

values required at a temperature of 5°C, a pH of 6 and a concentration

level of 4.5 mg/L of chlorine at 99 percent inactivation, one could perform

the following calculation:

     In equation (5) if C - 4.5 mg/L, pH - 6 and temp - 5°C

     then  C-t (4.5; 6; 5; 99.99) - 0.9847 (4.50.1758)(62.7519)(5-0.1467)

     or C-t (4.5; 6; 5; 99.99) - 140.3

Assuming first order kinetics the C*t value at 99 percent using Table 3

would be:

     C't (4.5; 6; 5; 99.0) - 1/2 [C't ^4.5; 6; 5; 99.99)]

                - 70.1
                                      15

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      This value is very close to the value expected from Table 1.




      Another example  of extrapolation would be to calculate the Ot value




 for a chlorine  concentration of  1»5  mg/L,  pH of 6,  and a temperature of




 25°C for  an  inactivation level of  99 percent.   Assume  in equation (5)




      C -  1.5 mg/L,  pH - 6 and temp  - 5°C




      then Ot (1.5; 6;  5j 99.99) - 115.6




       From Table 3:




       Ot  (1.5; 6;  5; 99.0)  - 1/2  [Ot (1.5;  6;  5;  99.99)]  -  57.8




 If we  assume  thez for each 10°C increase in  temperature  the Ot decreased by




 1/2  then:




     Ot (1.5; 6; 25; 99.0)  - 1/4  [Ot (1.5; 6;  5;  99.0)] - 14.4  •




Checking Table 1 for this condition yields a Ot less than  9 which is




consistent with the previous calculation.  Table 4  compares the values in




Table 1 with the predicted values usin<; equation (5).






TABLE 4.   COMPARISON OF IN VITRO EXCYSTATION Ot VALUES FOR 99Z INACTIVATION




          OF GIARDIA LAMBLIA CYSTS VERSUS PREDICTIVE EQUATION

Temp
CO .

5


15


25



PH


6
7
8
6
7
8
6
7
8
Mean Disinfectant
Concentration
(=>g/i)

4.5
5.0
5.0
2.75
2.75
2.75
1.5
1.5
1.5
Mean
Ot
(in vitro)

65
98
110
20
32
37
<9
<10
<12
Estimated
C-t
(equation 5)

70.1
109.2
157.7
32.2
49.2
71.0
14.5
22.1
31.9
                                     16

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      From Table A It appears thafC't values derived by equation (5) from the




 animal infectivity data are more conservative than the comparable in_ vitro




 excystation data.






                            SUMMARY AND CONCLUSIONS






      Amendments to the Safe Drinking Water Act clearly spell out Congress'




 intent to require that all surface water suppliers in the U.S. install




 filtration, or practice adequate disinfection to protect the health of




 their customers.   Giardia has been identified as one of the leading causes




 of waterborne disease outbreaks in the U.S.  Giardia is also one of the




 most resistant organisms to disinfection by free chlorine.  Therefore,




 EPA's Office of Drinking Water has adopted the C-t (Concentration tines




 Time) concept to  quantify the inactivation of Giardia cysts by disinfection.




 If a  utility can  assure that a large enough C*t  can be maintained to ensure




 adequate  disinfection then it nay not be required to install filtration.




      In this paper an equation has been  developed that can be used  to




 predict C*t values for inactivation of Giardia by tree chlorine based  on




 the interaction of concentration,  tecperature and pH.   The parameters  for




 this  equation have been derived from a set of animal  infectivity data




 produced  by Dr.   Charles Hibler of Colorado State University.   This  equation




 provides  a systematic mechanism for extrapolating C*t  values  within  the




 temperature ranges of 0.5-5°C at pH levels of 6,  7,  S.  Extrapolations




 outside this range can be  accomplished by  applying well known kinetic




-principles  with caution.   The  predictive equation yielded  values  that




 compared  favorable with the  data in Table  1.
                                       17

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                               ACKNOWLEDGEMENTS






     The authors would like to acknowledge the following:  Huiling Feng




from the Computer Sciences Corporation for her assistance in the analysis




of the data in this paper; Dr. Alfred  Dufour and Mr. Stig Regli of EPA




for their helpful suggestions; and,  Patricia Pierson and Diane Routledge




for their assistance in preparing this oanuscript.
                                    13

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                                  REFERENCES
1.  Craun, G.F.  "Waterborne Outbreaks fron Glardia" In Giardia and giardiasis.
    Editor:  Erlandson Planum Publishing Corporation (In press).

2.  Watson, H. E. 1908. A note on the variation of  the rate of disinfection
    with change in the concentration of the disinfectant. J. Hyg. ^:536-592.

3.  Berg, G., S. L. Chang, and E. K. Harris. 1964.  Devitalization of micro-
    organisms by iodine.  1.  dynamics of the devitalization of enteroviruses
    by elemental iodine.  Virol. 22:469-481.

4.  Fair, G. M., J. C. Geyer, and D. A. Okua.  1968.  Water and Wastewater
    Engineering.  Vol. 2.  Water purification and wastewater treatment and
    disposal.  John Wiley and Sons, Inc., New York, NY.

5.  Fair, G. M., J. C. Morris, and S. L. Chang.  1947.   The dynamics of water
    chlorination.  J.  New Eng. Water Works Assoc. 61:285-301.

6.  Fair, G. M., J. C. Morris, S. L. Chang, II Weil, and R. ?. Burden.  1943.
    The behavior of chlorine as a water disinfectant.  J. Aa.  Water Works
    Assoc. 4£:1051-1061.

7.  Hoff, J. C., "Inactivation of Microbial Agents  b>- Chemical Disinfectants"
    EPA/600/2-86-067.

8.  Morris, J. C.,  1970.  "Disinfectant Chemistry and Biocidal Activities"
    in Proceedings  of  the National Specialty Conference on disinfection,
    American Society of Civil Engineers, New York, NY.

9. " Clarke, N. A.,  G.  Berg,  P. W. Kabler,  and L.  L. Chang.   "Hunan Enteric
    Viruses in Water:  Source, Survival,  and Removability".   International
    Conference on Water Pollution Research,  Landar, September,  1962.

10. Hoff, J. C., E. W. Rice, and F-  W. Schaefer III, "Disinfection and the
    Control of Waterborne Giardiapts", In  proceedings of  the 1984  Specialty
    Conference, Environmental Engineering  Division, ASCE,  June 1984.

11. Jarroll, E. L., A. K. Bingham,  and E.  A.  Meyer.  "Effect of Chlorine  on
    Giardia Lamblia cyst Viability".   Applied and Environcental Microbiology,
    Vol. 41, pp.  483-487, February,  1981.

12. Hibler, C. P.,  Hancock,  C. M.,  Perger,  L.  M., Wegrzn,  J. G. and  Swabby,
    K. D., Inactivation of Giardia  Cysts with Chlorine  at  0.5'C to 5.0°C.
  -  American Water  Works Association Research Foundation,  (in  press).
                                    -19-

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              APPENDIX G

      PROTOCOL FOR DEMONSTRATING
EFFECTIVE CHLORINE-AMMONIA DISINFECTION

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                                  APPENDIX G

                          PROTOCOL FOR DEMONSTRATING
                    EFFECTIVE CHLORINE-AMMONIA DISINFECTION
     The  chloramine CT values presented.in  this  manual are based upon the use
of preformed chloramines.  However, under field  conditions,  chloramination as
a treatment process involves the addition of free chlorine and ammonia either
concurrently,  or  sequentially.   The  order of  addition  and timing  between
adding each component is determined  by needs of the utility.   The relative
effectiveness  will be influenced by  the order  of  addition, the  chlorine to
ammonia ratio  and water  pH and temperature.   As  a  result  of  these  various
methods of application, chloramination, as conducted in the field, may be more
effective  than using preformed  chloramines.    Consequently,  systems  which
currently utilize  chloramines  as a  primary disinfectant  may not be  able to
meet the CT requirements for preformed chloramines yet may wish to demonstrate
their effectiveness under local conditions  rather than switch to an alternate
disinfectant.   This appendix  presents procedures for  demonstrating effective
inactivation of Giardia and viruses by chloramine disinfection.

Giardia Cysts
     Test Procedure
     The tests can be conducted in  a stirred batch reactor.  Use of this type
of  system  rather  than a  flowthrough  pilot  plant makes it possible to reduce
the  number of cysts  used and  simplifies  disposal problems.  The  use  of G_^
lamblia  cysts  is  recommended  because G^  lamblia  is  the pathogen  of direct
concern.  It is not possible to simulate mixing  efficiency of the treatment as
practiced but effective mixing is assumed.
     1.   Taken from information provided by J. Hoff, USEPA.
                                      G-l

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     To  500  ml of  raw source water,  maintained  in  a stirred  beaker at  the
lowest  temperature  experienced  by the  utility,   350,000  G^ lamblia  cysts  '
cleaned by the  method described by Bingham  et al. (1979)  or Sauch  (1984)  are
added.   Following  this,  chlorine  and  ammonia are  added,  the  sequence  and
timing of addition, concentration, and contact time simulating the chloramina-
tion process used by the utility.  At the end  of the  contact time,  sufficient
sodium  thiosulfate  to neutralize  the residual disinfectant is  added to  the
reactor.  The cysts are separated  from the suspending liquid, resuspended in a
small volume, and counted as described by  Hoff, Rice, and Schaefer  (1985).  A
sufficient volume of the concentrated cysts  to provide 50,000 cysts is intro-
duced into each of  5  Mongolian gerbils  by stomach tube.   The volume  that  can
be administered by  this  route is  limited  to  0.5  ml/animal.  The animals  are
held in individual  cages for seven days and fecal specimens are examined  for
the presence  of  cysts daily beginning  on  day four.  The  presence  of  cysts
indicates that  sufficient  viable  cysts  to  initiate  infection  remained  after
disinfectant contact.
     The £._ lamblia cysts used must be from  a  human isolate adapted to infect
Mongolian gerbils.  The cysts  are  produced in  specific pathogen-free  gerbils,
as described  by Hibler, et al.  (in  press).   Cysts  used in  the experiments
should be stored  under refrigeration and  should be  less  than  five days old.
Infectivity of cysts  not exposed to disinfectant  should  be determined either
by inoculating gerbils with low numbers of  cysts as  described  by Hibler  (in
press), or by performing an ID5Q  tritration  as  described by Hoff,  Rice and
Schaefer (1985).  As a disinfectant control, the disinfectant residual remain-
ing at the end of the contact time should be determined in a separate reactor
chloraminated in  the  same  manner  but not  containing cysts.  This  should be
compared with the residual present at  the  end of the contact period in the
operating system and the  two should be the same.
     2.   Excess  cysts  are  included to  allow  for losses  during  laboratory
          manipulation and for counting.
                                      G-2

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     Interpretation of Results
     The  available data indicate that the ID   for G. lamblia cysts is approx-
                                            50     ^~"~ —"*"""""—~^
imately 5 cysts (Rendtorff, 1954; Hibler et al., in press).  Since each animal
is fed 50,000  cysts  previously exposed to  disinfectant,  absence of infection
in all of the  five animals would indicate  that  viable  cysts had been reduced
by 99.99  percent or more.  This is one order of magnitude higher than the 99.9
percent inactivation level  required and thus provides  some margin of safety.
If any of the  animals  fed disinfectant-exposed  cysts become  infected,  the
chloramination process  or  contact  time  should  be altered to provide  more
effective disinfection.   The  test should  be  repeated  at  least  three  times
under the same conditions and  should be performed again and repeated any time
changes are made in  the  disinfection process.   The CT  value should be deter-
mined by  multiplying the contact  time in minutes by the disinfectant residual
(mg/L)  present at  the end  of the  contact time.   For  each 10 C  increase  in
temperature above the minimum the CT value can be reduced to half the previous
value  either  by  reducing  the contact  time  or  disinfectant  concentration,
provided   that;  if  the  disinfectant  concentration is  changed, the  addition
sequence  and the ratio of chlorine to ammonia is not changed.

Enteric Viruses
     Test Procedure
     It is suggested that  bacteriophage MS2 of Escherichia coli be used as a
disinfection model for drinking  water systems which rely  upon  chloramines as
an alternative disinfectant.  The  reasons  for  selecting MS2 phage include its
chemical  and physical similarities  to members  of the  genus Enterovirus,  which
includes  Human enterovirus  72  (hepatitis A virus)  and its lack of pathogenic-
ity.   Also,  published research  data on  members of  the genus  Levivirus,  to
which MS2 belongs,  suggest  that they may be expected  to respond to chlorine-
based disinfection  treatments  in a  manner biochemically similar  to  those of
the genus Enterovirus.   The MS2  bacteriophage can  easily  be prepared in high
titer and the procedure for its assay is both simple and rapid.  The media and
     3.    Taken from information provided by C. Hunt, HERL USEPA.
                                      G-3

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procedures for preparing and assaying bacteriophage  MS2 are listed at the end
of this appendix.  The method  for coliphage assay listed in "Standard Methods"
would  not  be adequate  for this  purpose,  as the  host bacterium  given  is not
suitable for MS2.
     The bench scale  chloramination procedure used  for the virus inactivation
test should be the same  as described for Giardia.   The treatment plant person-
nel  should first  perform this  test  on  a sample  of  unseeded raw water  to
determine  the inactivation  efficiency  for indigenous phages.   On the  same
dates  as this test  is performed, with as  little elapsed time as possible, the
same test  should be performed  on a batch  of raw  water which  has been seeded
with MS2 bacteriophage at an initial  titer of  from  10  to 10  plaque forming
units per mL.  The inactivation efficiency can  then be calculated according to
the following formulas
              (raw seeded - raw unseeded) - (finished seeded - finished unseeded)   .„
% inactivation = 	;	—	——	  x 100
                             (raw seeded -  raw unseeded)
The assay  procedure and bacterial  host  used in titering both  the  seeded MS2
and indigenous bacteriophages  should be  identical.
     Interpretation of Results
     The calculated percent inactivation of viruses can be used for comparison
with the required inactivation efficiency.  As  a  margin of  safety,  the batch
test should yield 99.999 percent inactivation;  one order  of magnitude  greater
than required for compliance.   If this efficiency  is not attained, the chlora-
mination process or contact time should be altered  to  provide more effective
disinfection.  As with  Giardia,  the test  should  be  repeated at least three
times under the same conditions and should be performed again and repeated any
time changes are made in the disinfection procedure.
                                      G-4

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Materials and Assay Method
     A.    Mi croorgani sms

          1.    Bacteriophage  MS2:   Bacteriophaoe   catalog   number 15597-B1,
               American Type Culture Collection.

          2.    Bacterial Host:  Escherichia coli  catalog  number  15597,  Ameri-
               can Type Culture Collection.

     B.    Culture Media

          1.    Growth and Maintenance of Bacterial Host

               a.   TYE(5)  Broth

                    10.0 g  Bacto Tryptone'
                     1.0 g  yeast extract
                     1.0 g  glucose
                     8.0 g  NaCl
                     2.0 ml 1 M CaCl

                    Dissolve in distilled water to  a  total  volume of  1.0  L,
                    then add 0.3 ml of 6 M NaOH.

                    This medium should be sterilized either by autoclaving  or
                    filtration, and then  stored at a temperature of  approxi-
                    mately  4 C.    It  is  used  in  preparing bacterial host
                    suspensions for use in viral assays.

               b.   TYE Agar

                    Same formulation as  for TYE  Broth plus  addition of 15 g
                    microbiological grade agar prior to sterilization.

                    This medium  should  be  sterilized by  autoclaving  (which
                    will also serve to  solubilize the  agar)  and then used  to
                    prepare  slant  tubes  for  maintenance  of bacterial host
                    stock cultures.   Prepared  slant tubes  should  be  stored
                    under refrigeration at a temperature of approximately 4  C.
     4.    American Type Culture Collection,  12301 Parklawn Drive,  Rockville,
          Maryland 20852.

     5.    Tryptone-Yeast Extract.

     6.    Difco Laboratories,  17177  Laurel  Park  Drive,   Levonia, Michigan
          48214.   Bacto and Tryptone  are trade names.   Similar items  may be
          available from other  suppliers.

                                      G-5

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2,   Media and Diluent for Bacteriophage Assays

     a.   Bottom Agar

          10.0 g  Bacto Tryptgne
          15.0 g  Bacto Agar
           2.5 g  NaCl
           2.5 g  KC1
           1.0 ml 1 M CaCl2

          Dissolve in distilled water to a total volume of 1.0 L.

          This medium  should  be  sterilized  by autoclaving  (which
          will also  serve to  solubilize the  agar) ,  then used  for
          pouring into Petri dishes to form a sturdy bottom layer of
          agar medium.   This  bottom  layer serves  as an  anchoring
          substrate for the  top agar layer.  This medium  should  be
          stored at a temperature  of approximately 4 C until used in
          pouring bottom agar  layers in Petri  dishes.   Immediately
          prior to this use the medium would need to be liquified by
          heating.

     b.   Top Agar

          10.0 g  Bacto Tryptone
           1.0 g  yeast extract
           1.0 g  glucose
           6.0 g  Bacto Agar
           8.0 g  NaCl
           1.0 ml 1 M CaCl

          Dissolve in distilled water to a total volume of 1.0 L.

          This medium  should  be  sterilized  by autoclaving  (which
          will also serve  to solubilize the agar).  It  should then
          be  stored  at  a temperature  of  approximately 4 C  until
          needed for use in bacteriophage assays.  Immediately prior
          to use in assays, this medium will need to be liquified  by
          heating, and then  cooled  to and maintained at  a tempera-
          ture of 45 C.

     c.   Salt Diluent for Bacteriophage Samples

          8.5 g  NaCl
          2.0 ml 1 M CaCl
                   ™*"     ^

          Dissolve in distilled water to a total volume of 1.0 L.

          This diluent should be sterilized either by autoclaving  or
          filtration.   It may then be stored at room temperature.
                            G-6

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               This  diluent should  be used  as necessary  for  preparing
               dilutions  of samples containing  bacteriophage  prior  to
               their being assayed.

C.   Growth and Maintenance of Bacterial Host Cultures
     and Bacteriophage Stock Suspensions	

     1.    Preparation of Bacterial Host Stock Cultures

          Host bacteria  are inoculated onto TYE  Agar  slant tubes,  incu-
          bated for  24 hours at  37 C to allow bacterial growth,  and then
          refrigerated at 4 C.   At monthly intervals the cultured bacter-
          ial host  should  be  transferred to  a new TYE Agar slant,  as
          above, so as to maintain adequate viability.

     2.    Bacteriophage Stock Suspensions

          Inoculate  between 5  to 10 Petri  dishes of host  bacteria with
          bacteriophage  as  you would do  for the plaque  assay  procedure
          described  below.   The bacteriophage  suspension  inoculated for
          this technique should  represent a  sufficiently low dilution  so
          as to  yield assay plates  on which  the host  bacterial  "lawn"
          demonstrates nearly  complete lysis  following  6 to 8 hours  of
          post-inoculation incubation at 37 C.

          Following this incubation,  add between 2 to 3 ml of sterile TYE
          Broth to the surface of  the Top Agar layer in each Petri  dish.
          Then, using a sterile rubber spatula, gently scrape off the Top
          Agar layers and  combine  them in a large  centrifuge tube.  Add
          to this pool of  top  agar  layers an amount of  TYE Broth  suffi-
          cient to yield a total  volume  of 40 ml.   To  this  mixture add
          0.2 g of EDTA  (disodium salt) and 0.026 g of lysozyme  (crystal-
          lized, from egg white).  This mixture should  then be  incubated
          at  room temperature,  approximately 23 C,  for  2 hours  with
          occasional vortex mixing.   The entire  mixture should next  be
          centrifuged for 15 minutes at 3000G.  Carefully then remove the
          upper, fluid layer and sterilize it by passage through a filter
          that has first been pretreated by passing a small volume of TYE
          Broth through  it.  Use of  positive pressure  and a 0.22 urn pore
          size filter  for  this  step is  considered important.   The TYE
          Broth used for pretreatment is discarded.   The virus-containing
          filtrate  constitutes  a  viral  stock  suspension  for  use  in
          subsequent testing and assays.  The  viral stock suspension may
          be stored frozen.

D.   Performance of Bacteriophage Assay

     A two-week supply of  Petri  dishes (100 x  15 mm) may be  poured with
     Bottom Agar  ahead  of time  and  refrigerated  at 4 C.   The  amount  of
     Bottom Agar  added  per  dish should  be  approximately  15 ml.   Eigh-
     teen hours  prior to   beginning a  phage  assay,   a bacterial  host
                                 G-7

-------
          suspension should be prepared by  inoculating 5 ml of TYE Broth with
          a small amount of bacteria taken directly from a slant tube culture.
          The broth containing this bacterial inoculum should then be incubat-
          ed overnight  (approximately  18 hours)  at 37 C  immediately prior to
          use in bacteriophage assays  as  described below.   This type of broth
          culture  should be  prepared freshly  for  each day's bacteriophage
          assays.  If necessary, a volume greater than 5 ml can be prepared in
          a similar manner.

          On the day of assay,  a  sufficient amount of Top Agar  should be
          melted  and then  maintained at 45 C  in a waterbath.  Test tubes
          (13 x 100 mm)   should be placed in a rack in  the  same waterbath and
          allowed to warm,  following which  3 ml  of Top Agar  is added to each
          tube.  The test  tubes  containing  Top Agar  are  next inoculated with
          the bacteriophage  samples  (0.5 to  1.0 ml  of sample  per  tube)  plus
          0.1 ml of  the overnight bacterial host suspension.   The  bacterio-
          phage samples  should be diluted appropriately  in  salt diluent prior
          to inoculation.   The  test  tubes containing Top Agar, bacteriophage
          inoculum,  and bacterial host   suspension   should  then be  agitated
          gently on  a  vortex mixer,  and the contents  of each poured  onto a
          hardened Bottom  Agar  layer  contained  in an  appropriately numbered
          dish.  The Petri dishes should  then quickly be rocked to spread the
          added material evenly, and placed on a flat surface at room tempera-
          ture  while the   agar present  in the  added  material  solidifies
          (approximately 15 minutes).  The  dishes should finally be inverted
          and incubated at 37 C for a  minimunr of 6 hours.   The focal areas of
          viral infection which  develop during this incubation are referred to
          as "plaques"   and,  if possible,  should  be enumerated  immediately
          after the incubation.   If necessary, the incubated Petri  dishes can
          be refrigerated at 4 C overnight prior to plaque enumeration.
References
     Adams, H. H.  Bacteriophages.  Interscience Publishers, New York, 1959.

     American Public  Health Association;  American  Water  Works  Association;
     Water Pollution Control Federation.  Standard Methods for the Examination
     of Water and Wastewater, 16th ed., pp. 1033-1036, 1985.

     Bingham, A.  K.;  Jarroll,  E.  L.;  Meyer,  E. A.   Giardia sp.;  Physical
     factors of excystation in-Vitro, and  excystation vs.  eosion  exclusion as
     determinants of viability.  Exp. Parasitol. 47,204-291, 1979.

     Cramer, W. N.; Kawata,  K.,°  Kruse,  C.  W.  Chlorination and iodination of
     poliovirus and f^.   J. Water Poll. Control Fed., 48:61-76, 1976.

     Grabow,  W.  O.  K.;  Gauss-Muller,  V.;   Prozesky, O.  W.;  Deinhardt, F.
     Inactivation of  hepatitis  A virus and  indicator organisms  in  water by
     free chlorine residuals.  Appl. Environ. Microbiol., 46:619-624, 1983.
                                      G-8

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Hibler,  C.  P.,  Hancock,  C.  M.,   Perger,   L.   M.,   Wegrzyn,  J.  G.;
Swabby K. D..   Inactivation  of Giardia  cysts  with chlorine  at 0.5 C to
5.0 C.   American Water  Works Association  Research Foundation Research
Report,  (In press, 1987).

Hoff, J.  C.,  Rice, E.  W. ?  Schaefer,, F.  W.  III.  Comparison  of animal
infectivity and  excystation  as measures of Giardia muris cyst inactiva-
tion by chlorine.  Appl. Environ. Microbiol. 50:1115-1117, 1985.

Hoff, J.  C.  Inactivation  of  microbial agents by chemical disinfectants.
EPA-600152-86-067, U. S. Environmental Protection Agency. Water Engineer-
ing  Research  Laboratory, Drinking  Water Research  Division,  Cincinnati,
Ohio, September, 1986.

Mathews,  R.  E.  F.  Classification  and nomenclature of  viruses.   Inter-
virology, 17:1-199, 1982.

Olivieri, V.  P., Donovan, T. K.; Kawata,  K.   Inactivation  of virus in
sewage.  In:  Proceedings of  the  National  Specialty Conference on Disin-
fection.   American  Society   of  Civil  Engineers,  New   York,  NY,   pp.
265-685, 1971.

Olivieri, V. P.;  Kruse, C. W.; Hsu,  Y.  C.; Griffiths,  A. C.; Kawata, K.
The  comparative mode of action  of  chlorine,  bromine  and iodine  on f
bacterial virus.   In:   Disinfection;   Water and Wastewater.   Johnson, J.
D., ed., Ann Arbor Science, Ann Arbor, MI.  pp. 145-162, 1975.

Rendtorff,  R.   C.   The  experimental  transmission of  human  intestinal
protozoan parasites.  II.  Giardia lamblia  cysts  given  in capsules.  Am.
J. Hyg. 59:209-220, 1954.

Safe Drinking Water Committee.  The  Disinfection  of Drinking  Water.  In:
Drinking  Water  and Health,  National  Academy Press,  Washington,  DC.,
2:5-137, 1980.

Sauch, J. (1984) - already referenced in Guidance Manual.

Shah,  P.  and  McCamish,  J.    Relative  Resistance of  Poliovirus 1  and
Coliphages f  and T2 in Water.  Appl. Microbiol., 24:658-659,  1972.
                                 G-9

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              APPENDIX H

SAMPLING FREQUENCY FOR TOTAL COLIFORMS
      IN THE DISTRIBUTION SYSTEM

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                                  APPENDIX H

                       COLIFORM MONITORING REQUIREMENTS


Surface Water

                                           (1 2)
     With Disinfection Only (No Filtration)   '

          25-500 persons:   5 samples/month

       -  501-3,300 persons:  5 samples/month

       -  over 3,300 persons:   Monitoring frequency specified in Table H-l

     With Filtration and Disinfection

       -  25-500 persons:   5 samples/month OR a sanitary survey every 5 years
          and one sample/month

          501-3,300 persons:  5 samples/month OR a sanitary survey every
          3 years and 3 samples/month

       -  over 3,300 persons:   Monitoring frequency specified in Table H-l


Notes:

     1.   In compliance with 40 CFR Part 141, Subpart H.

     2.   System must collect at least one coliform sample near the first
          customer on each day that a turbidity measurement, as required in
          40 CFR Part 141.74,  exceeds 1 NTU.
                                      H-l

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                                   TABLE H-l

              COLIFORM MONITORING FREQUENCY BY POPULATION SERVED
    Served
    25-  3,300
 3,301-  5,800
 5,801-  6,700
 6,701-  7,600
 7,601-  8,500
 8,501-10,000
10,001-15,000
15,001-20,000
20,001-25,000
25,001-30,000
30,001-35,000
35,001-40,000
40,001-45,000
45,001-50,000
50,001-55,000
55,001-60,000
60,001-65,000
65,001-70,000
70,001-75,000
75,001-80,000
80,001-85,000
Samples/Month
        Served
Note:
      5
      6
      7
      8
      9
     10
     15
     20
     25
     30
     35
     40
     45
     50
     55
     60
     65
     70
     75
     80
     85
                           (1)
   85,001-   90,000
   90,001-   95,000
   95,001-  100,000
  100,001-  200,000
  200,001-  300,000
  300,001-  400,000
  400,001-  500,000
  500,001-  600,000
  600,001-  700,000
  700,001-  800,000
  800,001-  900,000
  900,001-1,000,000
1,000,001-1,200,000
1,200,001-1,400,000
1,400,001-1,600,000
1,600,001-1,800,000
1,800,001-2,000,000
2,000,001-2,500,000
2,500,001-3,000,000
3,000,001-3,500,000
3,500,001-4,000,000
   over 4,000,000
Samples/Month

     90
     95
     100
     130
     160
     180
     200
     220
     240
     260
   .  280
     300
     320
     340
     360
     380
     400
     420
     440
     460
     480
     500
     1.    Unless reduced by the State as provided in 40 CFR 141.21(a).  State
          may permit systems serving 25-300 persons to reduce monitoring to
          1 sample/month and systems serving 301-500 persons to reduce
          monitoring to 3 samples/month if:

          a.   sanitary survey results every 3 years are satisfactory

          b.   system has not had a waterborne disease outbreak

          c.   system has record of compliance with the coliform MCLs and
               monitoring requirements

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      APPENDIX I

 MAINTAINING REDUNDANT
DISINFECTION CAPABILITY

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                                  APPENDIX  I

                       REDUNDANT  DISINFECTION CAPABILITY


     In  reviewing water disinfection facilities for compliance with redundancy

requirements,  the following  items should be checked:


  I.  General

     A.   Are  the capacities of all components of both the primary system  and
         the  redundant system equal to or  greater  than the design  values?

         Some systems  may have two or more units which provide  design  levels
         of the disinfectant when  all  are in operation.   In these cases,  an
         additional  unit is  needed as backup during the  downtime of  any  of
         the  operating units.   The backup must have a capacity equal to  or
         greater than  that  of the largest  on-line  unit.

     B.   Are  adequate  safety  precautions being followed, relative  to  the type
         of disinfectant being used?

     C.   Are  redundant  components  being  exercised  or  alternated with  the
         primary components?

     D.   Are  all components being properly maintained?

     E.   Are  critical  spare parts on hand  to repair disinfection equipment?

     F.   Is   there   duplication   of  components  of  the  system  which   are
         indispensible for  disinfecting the  water?


 II.  Disinfectant Storage
     A minimum of two  storage units capable  of being used alternately  should

be provided.    However, it  is not  necessary for both  systems  to have full

design capacity.

     A.   Chlorine
     Storage   for  gaseous  chlorine  will  normally be  in  150-lb   cylinders,

2,000-lb containers,  or larger on-site storage vessels.
         1.    Is  there  automatic  switchover equipment  if   one  cylinder  or
               container empties  or becomes inoperable?

         2.    Is  the  switching  equipment in good  working  order,  (manually
               tested on a regularly scheduled basis), and are spare  parts  on
               hand?
                                      1-1

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          3.   Are  the  scales   adequate   for  at  least  two  cylinders  or
               containers.
     Bo   Hypochlorite
     Storage  of  calcium  hypochlorite or  sodium hypochlorite  is  normally
provided in drums or other suitable  containers.   Redundancy requirements are
not applicable to these by themselves, so long as the required minimum storage
quantity is on hand at all times.
     C.   Ammonia
     Anhydrous ammonia is usually stored in cylinders as a pressurized liquid.
Aqua ammonia is usually  stored  as a solution of ammonia  and water in a hori-
zontal pressure vessel.
          1.   Is the  design  storage volume  divided  into two  or  more usable
               units?
          2.   Is automatic  switching equipment in  operation  to  change over
               from one unit to another when one is empty or inoperable?
          3.   Are there spare parts for the switching equipment?

III. Generation
     Ozone and  chlorine  dioxide are  not  stored on-site.  Rather,  because  of
their reactivity* they are generated and used immediately.
     It is recommended that for the redundancy requirement for these disinfec-
tants  to  be satisfied that  there  are  two generating  units,  or two  sets  of
units, capable of supplying the  design feed rate.   In  systems  in  which there
is more than  one  generation  system to provide the design capacity, a standby
unit should be available for times  the  on-line units  need repair.   The backup
unit should have a capacity equal to or greater than the units it may replace.
     A.   Chlorine Dioxide
     Chlorine,  sodium  chlorite, or sodium hypochlorite  should be  stored  in
accordance with storage guidelines previously described.
     B.   Ozone
     Are all generation  components  present  and in working order for both the
primary and the redundant units (whether using air or oxygen)?
     C.   Common
     Is switchover equipment and  automatic  start-up  installed and  operable to
change from the primary generating unit(s)  to the redundant unit(s)?
                                      1-2

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 IV.  Feed Systems
     Redundancy in feed systems requires two  separate  units,  or systems,  each
capable of supplying the design feed  rate  of disinfectant.  If more  than one
unit  is used to provide the design feed rate, a third unit should be available
to replace  any  of  the  operating  units  during  times  of malfunction.   The
replacement unit  must,  therefore,  have  a  capacity  equal  to or  greater  than
that  of the  largest  unit which it  may replace.  This requirement  applies to
all disinfection methods,  and  is  best implemented by  housing the primary and
redundant components  in separate rooms, enclosures, or areas, as appropriate.
     In  reviewing these  systems  for  redundancy,   the  following  components
should be checked:
     A.   Chlorine
          1.   Evaporators
          2.   Chlorinators
          3.   Injectors
     B.   Hypochlorite
          1.   Mixing tanks and mixers
          2.   Chemical feed pumps and controls
     C.   Ozone
          1.   Dissolution equipment,  including compressor and delivery piping
               systems
     D.   Chlorine Dioxide
          1.   Chlorine feed equipment
          2.   Sodium chlorite mixing  and metering equipment
          3.   Day tank and mixer
          4.   Metering pumps
          5.   If a package CIO unit  is used, two must be provided
     E.   Chloramination
          1.   Chlorine feed equipment
          2.   Ammonia  feed  equipment,  including   applicable  equipment  for
               either:
               a.  Anhydrous ammonia  (gas)
               b.  Aqua ammonia (solution)
                                      1-3

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  V. Residual Monitoring
     The  surest  method of  checking  the  past  performance of  a disinfection

facility for  continuous operation is by continuous  monitoring and recording.
To  ensure  continuous monitoring,  it is  suggested  that  duplicate continuous
monitors are present for backup in the  event of monitor failure.  However, if

there is a  failure  in the monitoring system for indicating that a continuous

residual  is being  maintained,  this  would  be  a  violation  of  a  monitoring

requirement, not a treatment requirement.

     A.    Chlorine
          1.   Does  the  facility have a   continuous  monitor  for  chlorine
               residual at  the  disinfection  system site  with  an alarm  or
               indicator to  show when  the  monitor  is  not  functioning?   For
               added assurance,  the provision of a  backup  monitoring  unit is
               also recommended.

          2.   Is there instrumentation in place  to  automatically switch  from
               one monitor to the other if the first one fails?

     B.    Hypochlorite

     Same as for chlorine  system.
     C.    Ozone

          1.   Does  the  facility  have  a   continuous  ozone  monitor  with
               automatic switchover capability and alarms?

          2,   Does the facility  have a continuous ozone residual monitor  with
               automatic switchover capability and alarms?

     D.    Chlorine Dioxide

          1.   Does the facility  have a continuous  chlorine  dioxide  monitor
               with automatic switchover capability and alarms?

          2.   Does the facility  have a continuous  chlorine  dioxide  residual
               monitor with  automatic switchover capability and alarms?


     E.    Chloramination

          1.   Does  the  facility have a   continuous  ammonia  monitor  with
               automatic switchover capability and alarm?

          2.   Does the  facility  also have a  continuous chlorine  residual
               monitor  on-site   with  automatic   switchover   capability   and
               alarms?
                                      1-4

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 VI.  Power Supply
     A permanently installed  standby  generator,  capable of  running  all elec-
trical equipment at  the  disinfection station,  and  equipped for  automatic
start-up  on power failure, must be on-site and functional.
     Alternatives to a standby generator,  such as a feed line from a different
power source,  are acceptable if they can be shown to have equal reliability.

VII.  Alarms
     Indicators and alarms, both local and remote, must be capable of promptly
alerting  operating and supervisory personnel of problem conditions.
     A.   Local
     Lights, buzzers, and  horns  should be installed and  functioning  to alert
on-site personnel to problem conditions.
     B.   Remote
     Indications of major problems should also be relayed to a central control
panel which is manned 24 hours per day and whose operators can notify response
personnel instantaneously.
     C.   Problem Conditions
     A minimum  list of  problem  conditions which  should have  indicators  and
alarms, both locally and at a 24-hour per day switchboard, is as follows:
          1.   Disinfectant leak
          2.   Feeder pump failure
          3.   Power outage
          4.   Generator or alternate power source on
          5.   Disinfectant residual less than setpoint value

VIIII. Facility Layout
     Maximum reliability  is ensured when  redundant  units are  separated from
primary units.   The  type of separation should be appropriate to  the  type  of
potential malfunction.  For example,  any  area within a building  subject to a
chlorine  leak should  have primary components separated  from redundant compo-
nents by  an airtight enclosure, i.e., separate rooms of varying sizes.
                                      1-5

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 IX. Separate Facility
     Under certain conditions, such as  location of a disinfection facility in
an  area  of high earthquake  potential,  the most reliable means  of providing
redundant facilities may be  to house them in  a completely separate structure
at a different site.
                                      1-6

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       APPENDIX J
WATERSHED CONTROL PROGRAM

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                                  APPENDIX J

                           WATERSHED CONTROL PROGRAM


     The  following is a guideline for documenting a watershed control program.

All systems are expected to conduct the basic elements of  a  watershed control

program.   However, the scope of the program  should  increase  as  the  complexity

and size  of the watershed/system increases.   The program  could be more or less

comprehensive  than  this outline,  and will  be  determined on a  case-by-case
basis by  the utility and the Primacy Agency.

     A.    Watershed Description

          1.    Geographical location and physical features  of the watershed.

          2.    Location of major  components  of  the water system  in  relation-
               ship to the  watershed.

          3.    Hydrology:   Annual precipitation patterns, stream  flow  charac-
               teristics,  etc.

          4.    Agreements  and delineation of  land use/ownership.

     B.    Identification of the Watershed Characteristics
          and Activities Detrimental to  Water Quality

          1.    Naturally Occurring:

               a.    Effect  of  precipitation, terrain,  soil  types  and  land
                    cover

               b.    Animal  populations  (describe) —  include a discussion of
                    the Giardia contamination potential, any other  microbial
                    contamination transmitted by animals

               c.    Other  -  any  other  activity  which  can  adversely  affect
                    water quality

          2.    Man-Made:

               a.    Point  sources of  contamination  such  as wastewater  treat-
                    ment plant, industrial discharges, barnyard,  feedlots, or
                    private septic systems

               b.    Nonpoint  Source  of Contamination:

                    1)   Road construction -  major highways,  railroads
                                     J-l

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               2)   Pesticide usage

               3)   Logging

               4)   Grazing animals

               5)   Discharge to ground water which recharges the surface
                    source

               6)   Recreation activities

               7)   Potential for unauthorized activity in the watershed

               8)   Describe any  other human  activity in  the  watershed
                    and its potential impact on water quality

          It should be  noted that  grazing  animals in the  watershed may
          lead to the presence  of  Cryptosporidium in the water.  Crypto-
          sporidium is a pathogen which may  result in a disease outbreak
          upon ingestion.  Mo information  is available on its resistance
          to  various  disinfectants,   therefore   grazing  should  not  be
          permitted on watersheds of  non-filtering systems.  The utility
          should set priorities to address  the  impacts in B.I.  and 2.,
          considering   their  health  significance  and  the  ability  to
          control them.
C.   Control of Detrimental Activities/Events

     Depending on the activities occurring within the watershed, various
     techniques  could  be  used to  eliminate or  minimize  their effect.
     Describe what  techniques are  being  used  to control the  effect  of
     activities/events identified in B.I.  and 2. in its yearly report.

     Example:

          Activity;   Logging in the watershed.

          Management Decision;  Logging effects are unacceptable, there-
          fore, do not allow logging in watershed.

          Procedure;  Buy out all logging rights within the watershed.

          Monitoring;  Periodically tour  watershed to  ensure no logging
          is conducted.

     Controlled logging may  sometimes be more  cost effective.  Measures
     should, however, be taken to:

       -  Limit access
                                 J-2

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       -  Ensure cleanup
       -  Control erosion

     Example:

          Activity;  Point sources of discharge within the watershed.

          Management Decision;   Eliminate  those  discharges or  minimize
          their impact.

          Procedures;  Actively  participate in  the review  of  discharge
          permits to alert the reviewing agency of the potential (actual)
          impacts  of  the  discharge  and lobby  for  its elimination  or
          strict control.

          Monitoring;  Conduct special monitoring to ensure conditions of
          the permit  are met  and to document  adverse effects  on  water
          quality.

D.   Monitoring

     1.   Routine:   Minimum specifications for  monitoring several  raw
          water quality  parameters  are listed in  Section 3.1.   Describe
          when, where  and how  these samples  will be  collected.   These
          results will be  used to  evaluate whether the  source  may con-
          tinue to be used without filtration.

     2.   Specific:  Routine monitoring may not provide information about
          all parameters of interest.  For example, it may be valuable to
          conduct special  studies to  measure  contaminants  suspected  of
          being  present  (Giardia,   pesticides,  fuel  products,  enteric
          viruses, etc.).  Frequent presence of either Giardia or enteric
          viruses  in  raw  water samples  prior  to  disinfection  would
          indicate an  inadequate  watershed control program.   Monitoring
          may  also  be  useful  to  assess the  effectiveness of  specific
          control  techniques,  and  to  audit procedures  or  operational
          requirements instituted within the  watershed.   Utilities  are
          encouraged to conduct additional monitoring as necessary to aid
          them in controlling the quality of the source water.

E.   Management/Operations

     1.   Management

          a.   Organizational structure
          b.   Personnel and education/certification requirements

     2.   Operations

          a.   Describe system operations and design flexibility.
                                 J-3

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          b.   The utility should  conduct some form of ongoing review or
               survey in the watershed to identify and react to potential
               impacts on water quality.  The scope of this review should
               be documented and agreed upon by the  utility and Primacy
               Agency on a case-by-case basis.

          c.   Specifically  describe operational  changes  which can  be
               made  to  adjust  for changes  in water  quality.   Examples
               Switching to  alternate sources;  increasing the  level  of
               disinfection;  using settling basins.   Discuss  what trig-
               gers, and who decides to make, those changes.

     3.   Annual Report:   As part of the  watershed program,  an annual
          report should be submitted to the Primacy Agency.  The contents
          of the report should:

          a.   Identify special concerns  that occurred  in the watershed
               and how they were handled  (example:   herbicide usage, new
               construction,  etc.).

          b.   Summarize  other  activities  in  the  watershed  such  as
               logging,  hunting, water quality monitoring, etc.

          c.   Project what adverse  activities are expected to occur  in
               the future and describe how the utility expects to address
               them.

F.   Agreements/Land Ownership

     The goal of a watershed management program is to achieve the highest
     level  of  raw  water  quality practicable.   This  is  particularly
     critical to an unfiltered surface supply,.

     1.   The utility will have maximum opportunity  to realize this goal
          if  they  have complete  ownership  of the watershed.   Describe
          efforts to  obtain  ownership,  such  as  any  special programs  or
          budget.   When  complete   ownership  of the watershed  is  not
          practical,  efforts  should  be  taken  to  gain  ownership  of
          critical  elements,   such as,  reservoir or stream  shoreline,
          highly  erodable  land,  and  access   areas  to  water  system
          facilities.

     2.   Where  ownership  of  land is not  possible,  written  agreements
          should be obtained  recognizing  the watershed  as  part of  a
          public water  supply.   Maximum  flexibility  should be  given  to
          the  utility to  control  land  uses  which  could have  adverse
          effect on the water quality.  Describe such agreements.

     3.   Describe how  the utility  ensures that the  landowner complies
          with these agreements.
                                 J-4

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  APPENDIX K
SANITARY SURVEY

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                                  APPENDIX K

                                SANITARY SURVEY


     The   SWTR requires  that  a  sanitary  survey  be  conducted  each  year.

Section 3  presents  guidelines  for  an •annual survey  which  is  conducted  to

ensure that the quality of the water  and  service  is maintained.   In addition,

it is recommended that a more  comprehensive survey such as contained  in this

appendix be conducted every 3 to 5 years.   This time period is suggested since

the time  and  effort needed  to  conduct  the  comprehensive  survey  makes  it
impractical for it to be  conducted annually.

     The sanitary survey  involves three phases, including planning the  survey,

conducting the survey and compiling  the final report of the survey, as  will  be
presented  in the  following  pages.

     1.   Planning the Survey

          Prior to conducting or scheduling a sanitary survey, there should  be
          a detailed  review of  the water  system's file  to  prepare  for the
          survey.   The review should pay particular attention  to  past sanitary
          survey  reports and  correspondence describing previously identified
          problems and their solutions. These should be noted, and action/in-
          action  regarding those  problems  should  be specifically  verified  in
          the field.   Other information to  review  includes:   any  other corre-
          spondence,  water  system plans, chemical  and microbiological sampling
          results, operating reports,  and  engineering  studies.   This  review
          will aid in the  familiarization  with the system's past  history and
          present conditions,  and  the agency's  past  interactions  with the
          system.

          The initial phase of  the  water quality  review  will be  carried out
          prior to conducting the survey as well,  and will consist of  review-
          ing  the water  system's  monitoring  records.   Records  should  be
          reviewed for compliance with all applicable  microbiological,  inor-
          ganic chemical, organic chemical,  and radiological contaminant MCLs,
          and also for compliance with the monitoring  requirements  for those
          contaminants.   The  survey will  provide  an  opportunity to  review
          these records with the utility,  and  to discuss  solutions to  any MCL
          or monitoring violations.    The  survey will  also provide  an oppor-
          tunity  to review  how and where samples are  collected,  and how field
          measurements (turbidity,  chlorine  residual,  fluoride,  etc.) are
          made.   Points to  cover include:
                                      K-l

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     a.   Is the  system in compliance with  all  applicable MCLs  (organic
          chemical,  inorganic   chemical,   microbiological,  and  radio-
          logical)?

     b.   Is the system in compliance with all monitoring requirements?

     The pre-survey file review  should generate  a list of items to check
     in the  field,  and a  list  of questions  about the  system.   It will
     also  help the  survey  or  plan  the  format  of  the  survey  and  to
     estimate how much  time  it may take.   The  next step is  to make the
     initial contact with  the system management  to  establish the survey
     date(s)  and  time.   Any  records,   files,  or people  that will  be
     referenced during  the  survey should  be mentioned at  the outset.
     Clearly laying out the  intent of the  survey up  front will greatly
     help in managing  the system, and will ensure that the  survey goes
     smoothly without a need for repeat trips.

2.   Conducting the Survey

     The on-site  portion of  the survey  is  the  most important  and will
     involve interviewing those in charge of managing the water system as
     well as the  operators and other technical people.   The  survey will
     also review  all  major system components  from the  source(s)  to the
     distribution system.  A  standard form is frequently used  to ensure
     that all  major components  and  aspects of  each system  are consis-
     tently reviewed.   However, when in the  field, it  is best to have an
     open mind  and focus  most  attention on  the  specifics of  the water
     system, using  the form  only as a  guide.   The  surveyor  should  be
     certain to be on time when beginning the survey.  This consideration
     will help get the  survey started smoothly with the operator and/or
     manager.

     As the survey progresses, any deficiencies that are observed should
     be brought to the  attention of the water system  personnel, and the
     problem and the corrective  measures should be discussed.  It is far
     better  to  clarify  technical  details  and  solutions while  standing
     next to the problem than it is to do so over the  telephone.  Points
     to cover include:

     a.   Is the  operator competent  in performing  the  necessary field
          testing for operational control?

     b.   Are testing facilities and equipment adequate, and  do reagents
          used have an unexpired shelf life?

     c.   Are field and other analytical instruments properly  and regu-
          larly calibrated?

     d.   Are records of field test results and water  quality compliance
          monitoring results being maintained?

     e.   Conduct any sampling which will be part of the survey.
                                 K-2

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Also, detailed  notes of  the findings  and conversations  should  be
taken  so  that  the  report  of  the  survey  will  be  an  accurate
reconstruction of the survey.

Specific  components/features  of  the  system  to  review  and  some
pertinent questions to ask are:

A.   Source Evaluation

     1.   Description:  based  on field observations  and  discussion
          with  the  operator,  a  general  characterization  of  the
          watershed  should  be   made.   Features  which   could  be
          included in the description are:

          a.   Area of watershed or recharge area.

          b.   Stream flow.

          c.   Land  usage   (wilderness,  farmland,  rural  housing,
               recreational, commercial, industrial,  etc.).

          d.   Degree of access by the public to watershed.

          e.   Terrain and soil type.

          f.   Vegetation.

          g.   Other.

     2.   Sources  of contamination in  the watershed or  sensitive
          areas surrounding  wells or  well  fields should be  identi-
          fied.  Not  only should  this  be  determined by  physically
          touring  and  observing the  watershed  and its daily  uses,
          but the  surveyor should also actively question  the  water
          system  manager  about  adverse  and  potentially  adverse
          activities  in  the watershed.   An example of  types  of
          contamination includes:

          a.   Man Made.

               1.   Point  discharges   of  sewage,   stormwater,  and
                    other wastewater.

               2.   On-site sewage disposal systems.

               3.   Recreational   activities    (swimming,   boating,
                    fishing, etc.).

               4.   Human habitation.

               5.   Pesticide usage.
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          6.   Logging.

          7.   Highways or  other roads from  which there might
               be spills.

          8.   Commercial or industrial activity„

          9.   Solid waste or other disposal facilities.

         10,   Barnyards, feed  lots,  turkey  and  chicken farms
               and other concentrated domestic animal activity.

         11.   Agricultural   activities   such   as   grazing,
               tillage,  etc.,   which   affects  soil  erosion,
               fertilizer usage, etc.

         12.   Other.

     b.   Naturally Occurring.

          1.   Animal populations, both domestic and wild.

          2.   Turbidity  fluctuations   (from   precipitation,
               landslides, etc.).

          3.   Fires.

          4.   Inorganic  contaminants  from  parent  materials
               (e.g., asbestos fibers).

          5.   Algae blooms.

          6.   Other.

          This list is by no means all inclusive.   The surveyor
          should  rely  principally  on  his  observations  and
          thorough questioning regarding  the  unique properties
          of  each  watershed  to  completely  describe what  may
          contaminate the source water.

3.   Source Construction.

     a.   Surface Intakes.

          1.   Is the source adequate  in quantity?

          2.   Is the best  quality source or  location  in that
               source being  used?

          3.   Is the intake  protected from  icing  problems if
               appropriate?
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     4.   Is  the  intake  screened  to prevent  entry  of
          debris, and are screens maintained?
     5.   Is animal activity controlled within the immedi-
          ate vicinity of the intake?

     6.   Is there a raw water sampling tap?

b.   Infiltration Galleries.

     1.   Is the source adequate in quantity?

     2.   Is the best quality source being used?

     3.   Is  the  lid  over the  gallery  watertight  and
          locked?

     4.   Is the  collector in  sound condition  and  main-
          tained as necessary?

     5.   Is there a raw water sampling tap?

c.   Springs.

     1.   Is the source adequate in quantity?

     2.   Is there  adequate protection around  the spring
          such as  fencing  to control the area  within 200
          feet?

     3.   Is the  spring constructed  to best capture the
          spring flow and  exclude  surface water infiltra-
          tion?

     4.   Are  there  drains to  divert surface  water  from
          the vicinity of the spring?

     5.   Is the  collection structure of sound construc-
          tion with no leaks or cracks?

     6.   Is there a screened overflow and drain pipe?

     7.   Is the supply intake located above the floor and
          screened?

     8.   Is there a raw water sampling tap?

d.   Catchment and Cistern.

     1.   Is source adequate in quantity?
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          2,   Is the cistern of adequate size?

          3.   Is the  catchment area protected from potential
               contamination?

          4.   Is the catchment drain properly screened?

          5.   Is  the  catchment  area   and  cistern  of  sound
               construction and in good condition?

          6.   Is catchment constructed  of  approved non-toxic,
               non-leaching material?

          7.   Is the  cistern protected from  contamination  —
               manholes, vents, etc?

          8.   Is there a raw water tap?

     e.   Other Surface Sources.

          1.   Is the source adequate in quantity?

          2.   Is the best possible source being used?

          3.   Is the  immediate vicinity  of  the  source  pro-
               tected from contamination?

          4.   Is the structure in good  condition and properly
               constructed?

          5.   Is there a raw water sampling tap?

4.   Pumps, Pumphouses, and Controls,,

     a.   Are all intake pumps, booster  pumps,  and other pumps
          of sufficient capacity?

     b.   Are all pumps and controls operational and maintained
          properly?

     c.   Are check valves, blow off valves, water meters and
          other appurtenances operated and maintained properly?

     d.   Is  emergency power  backup with  automatic  start-up
          provided and does it work (try it)?

     e.   Are  underground   compartments  and   suction   wells
          waterproof?

     f.   Is the interior and exterior of the pumphouse in good
          structural condition and properly maintained?
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     g.   Are there  any safety hazards  (electrical  or mechan-
          ical)  in the pumphouse?

     h.   Is  the  pumphouse  locked  and  otherwise  protected
          against vandalism?

     i.   Are  water  production   records   maintained  at  the
          pumphouse?

5.   Watershed  Management  (controlling  contaminant  sources):
     The goal of the watershed  management  program is to ident-
     ify and control contaminant  sources in the watershed (see
     Section 3.3.1 of  this  document,  "Watershed  Control  Pro-
     gram" ).  Under ideal  conditions  each  source of contamina-
     tion identified in 2  will  already have been identified by
     the utility,  and  some  means  of  control  instituted,  or a
     factual  determination  made  that  its  impact  on  water
     quality is  insignificant.   To assess  the  degree  to which
     the watershed  management program is  achieving its  goal,
     the following types of inquiries could be made:

     a.   If the watershed is not entirely owned  by  the util-
          ity,  have  written  agreements  been  made with  other
          land owners to control land usage to the satisfaction
          of  the utility?   Are appropriate regulations  under
          the contract  of  state/local department  of health  in
          effect?
     b.   Is the  utility  making efforts to obtain  as  complete
          ownership of  the watershed  as possible?  Is  effort
          directed to control critical elements?

     c.   Are there means by which the  watershed  is  regularly
          inspected for new sources of  contamination  or tres-
          passers where access is limited?

     d.   Are there adequately  qualified personnel  employed by
          the  utility  for  identifying  watershed  and  water
          quality -problems and who are given the responsibility
          to correct these problems?

     e.   Are raw water quality records kept to  assess  trends
          and to assess the impact of different activities and
          contaminant control techniques in the watershed?

     f.   Has  the  system  responded  adequately  to  concerns
          expressed  about  the  source  or  watershed  in  past
          sanitary surveys?

     g.   Has the utility  identified problems  in its  yearly
          watershed  control  reports,  and  if  so,  have  these
          problems been adequately addressed?

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               Identify what  other agencies have  control or juris-
               diction in the watershed.   Does the utility actively
               interact  with  these  agencies  to  see  that  their
               policies  or   activities   are  consistent  with  the
               utility's goal of maintaining high raw water quality?
B.   Treatment Evaluation
     1.   Disinfection.
          a.   Is  the   disinfection  equipment   and  disinfectant
               appropriate for the  application (chloramines, chlor-
               ine,  ozone,  and  chlorine  dioxide  are  generally
               accepted disinfectants)?

          b.   Are there back-up disinfection  units on line in case
               of failure, and are they operational?

          c.   Is there  auxiliary power with  automatic  start  up in
               case of power outage?  Is it tested and operated on a
               regular basis, both with and without load?

          d.   Is there an adequate quantity of disinfectant on hand
               and is it properly stored  (e.g.,  are chlorine cylin-
               ders properly labeled and chained)?
          e.   In the case  of gaseous chlorine,  is  there automatic
               switch over equipment when cylinders expire?

          f.   Are critical  spare parts  on hand to  repair  disin-
               fection equipment?

          g.   Is disinfectant feed proportional to water flow?

          h.   Are daily records kept of  disinfectant residual near
               the first customer from which to calculate CTs?

          i.   Are production records  kept from  which  to determine
               CTs?

          j.   Are CTs  acceptable  based  on  the  level  of treatment
               provided  (see  Surface  Water   Treatment  Rule  for
               filtered sources, and Section 3.2.2 of this guidance
               manual  for  unfiltered  sources,  to  determine  the
               appropriate CT)?

          k.   Is  a  disinfectant  residual maintained  in the  dis-
               tribution  system,  and  are records  kept  of  daily
               measurements?
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          1.   If  gas chlorine  is used,  are adequate  safety pre-
               cautions  being  followed   (e.g.,  exhaust  fan  with
               intake within six inches of the floor, self-contained
               breathing apparatus that is regularly tested, regular
               safety training for employees, ammonia bottles and/or
               automatic   chlorine  detectors)?    Is   the   system
               adequate to  ensure  the  safety of both the public and
               the employees in the event of a chlorine leak?

     2.   Other.

          a.   Are  other treatment  processes  appropriate and  are
               they  operated  to  produce consistently  high  water
               quality?

          b.   Are  pumps,   chemical  feeders,  and other  mechanical
               equipment in good condition and properly maintained?

          c.   Are controls and instrumentation and adequate for the
               process, operational, well maintained and calibrated?

          d.   Are  accurate  records  maintained  (volume  of  water
               treated, amount of chemical used, etc.)?

          e.   Are adequate supplies of  chemical on hand and pro-
               perly stored?

          f.   Are adequate safety devices available and precautions
               observed?

          Sections  of  a  sanitary  survey  pertaining  to  systems
          containing  filtration facilities  have been  omitted,  as
          this  section  of  the  guidance  document pertains to  non-
          filtering systems.

C.   Distribution System Evaluation

     After water has  been  treated, water quality must be  protected
     and maintained as  it  flows through  the  distribution  system to
     the customer's  tap.   The  following  questions  pertain to  the
     water purveyor's ability to maintain high water quality during
     storage and distribution.

     1.   Storage.

          a.   Gravity.

               1.   Are  storage reservoirs   covered  and  otherwise
                    constructed to prevent contamination?

               2.   Are all overflow  lines,  vents,  drainlines,  or
                    cleanout pipes turned downward and screened?
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          3o   Are all reservoirs inspected regularly?

          4.   Is the storage capacity adequate for the system?

          5o   Does  the   reservoir  (or  reservoirs)  provide
               sufficient pressure throughout the system?

          6.   Are  surface coatings  within  the reservoir  in
               good  repair and  acceptable  for potable  water
               contact?

          7.   Is the  hatchcover for  the tank  watertight and
               locked?

          8.   Can the reservoir be isolated from the system?

          9.   Is adequate safety equipment (caged ladder, OSHA
               approved  safety  belts,   etc.)   in   place  for
               climbing the tank?

         10.   Is the  site fenced,  locked,  or  otherwise pro-
               tected against vandalism?

         11.   Is  the  storage  reservoir  disinfected  after
               repairs are made?

         12.   Is  there   a   scheduled   program  for  cleaning
               storage reservoir sediments, slime on  floor and
               side walls.

     b„   Hydropneumatic „

          1,   Is the storage capacity adequate for the system?

          2.   Are  instruments,  controls,  and equipment  ade-
               quate, operational,  and maintained?

          3.   Are the  interior and exterior surfaces of the
               pressure tank in good condition?

          4.   Are tank supports structurally sound?

          5.   Does  the  low pressure  cut in  provide adequate
               pressure throughout the entire system?

          6.   Is the pump cycle rate acceptable (not more than
               15 cycles/hour)?

2o   Cross Connections.

     a.   Is  the  system  free  of  known  uncontrolled  cross
          connections?
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          b.   Does  the  utility have  a  cross connection prevention
               program, including annual testing of backflow preven-
               tion devices?

          c.   Are  backflow  prevention  devices   installed  at  all
               appropriate  locations  (wastewater  treatment  plant,
               industrial locations, hospitals, etc.)?

     3.   Other.

          a.   Are  proper  pressures  and  flows maintained  at  all
               times of the year?

          b.   Do all construction materials meet AWWA or equivalent
               standards?

          c.   Are all services metered and are meters read?

          d.   Are plans for the system available and current?

          e.   Does the system have an adequate maintenance program?

                 -  Is there evidence of leakage in the system?

                 -  Is there a pressure testing program?

                    Is there a regular flushing program?

                 -  Are valves and hydrants  regularly  exercised and
                    maintained?

                 -  Are  AWWA  standards   for  disinfection  followed
                    after all repairs?

                 -  Are there  specific bacteriological criteria and
                    limits  prescribed for  new  line  acceptance  or
                    following line repairs?

                 -  Describe the corrosion control program.

                 -  Is the system interconnected with other systems?

D.   Management/Operation

     1.   Is there an organization that is responsible for providing
          the  operation,  maintenance, and  management of  the  water
          system?

     2.   Does  the  utility regularly  summarize  both current  and
          long-term problems identified in their watershed, or other
          parts of the  system,  and define how  they  intend to solve
          the problems i.e.,  is  their planning mechanism effective;
          do they follow through with plans?

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          3.   Is  the  budget  and  financing  satisfactory  to  provide
               continuous  high quality  service,  and  allow for future
               replacements and improvements?

          4.   Are  customers  charged  user  fees  and  are  collections
               satisfactory?

          5.   Are there  sufficient  personnel to operate  and manage the
               system?

          6.   Are personnel  (including management)  adequately trained,
               educated, and/or certified?

          7.   Are operation  and maintenance manuals  and manufacturers
               technical specifications readily available for the system?

          8.   Are routine preventative maintenance schedules established
               and adhered to for all components of the water system?

          9.   Are sufficient  tools,  supplies, and maintenance parts on
               hand?

         10.   Are sufficient operation and maintenance records kept and
               readily available?

         11.   Is an  emergency plan  available and  usable,  and  are em-
               ployees aware of it?

         12.   Are all facilities free from safety defects?

          When  the  survey is  completed,  it  is always  preferable  to
          briefly summarize the  survey with  the  operator(s)  and manage-
          ment.  The  main findings of the survey should be reviewed so it
          is  clear  that  there  are  not  misunderstandings  about  find-
          ings/conclusions.  It  is also  good to  thank the  utility for
          taking part in the survey, arranging interviews with employees,
          gathering and explaining  their records, etc.   The information
          and  help which  the  utility can  provide are invaluable  to  a
          successful  survey, and every attempt should be made to continue
          a positive  relationship with the system.

3.   Reporting the Survey

     A final report of the survey should be completed as soon as possible
     to formally  notify the system and  other agencies of  the  findings.
     There is  no  set or  necessarily  best format  for doing  so,  and the
     length of the report will depend on the findings  of  the survey and
     size of the system.  Since the report may be used for future compli-
     ance  actions and  inspections,  it  should  include  as a minimum:
     1) the date  of  the  survey;  2)  who was  present during  the survey;
     3) the findings  of the survey;  4)  the  recommended  improvements to
     identified problems;  and 5)  the dates for completion of any improve-
     ments.   Any differences  between the   findings  discussed  at the

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conclusion  of  the survey  and what's  included  in the  final  report
should be discussed and  clarified  with the utility prior to sending
out the  final  report.   In other words,  the  utility  should be fully
aware of the contents of the final report before receiving it.
                            K-13

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        APPENDIX L
SMALL SYSTEM CONSIDERATIONS

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                                  APPENDIX L
                          SMALL SYSTEMS CONSIDERATIONS

Introduction
     Under the  provisions of  the  SWTR, systems  with fewer them  500 service
connections may  be eligible for an exemption.  Guidance  on the requirements
for an exemption is provided in Section 9.  For systems which are not eligible
for an  exemption, compliance  with the SWTR  is mandatory.  It  is recognized
that the  majority (approximately  75 percent)  of  people in  the  United States
are served by a relatively small number of large systems.  However, most water
systems in the  United States  are  small.   For small  systems,  compliance with
the various provisions of the  SDWA has traditionally been a problem.  Records
show small  systems  have a  disproportionately higher  incidence  of  drinking
water quality and monitoring difficulties.  The reasons for these difficulties
can generally be broken down into the following three categories:
       -  Economics
       -  Treatment Technologies
       -  Operations (lack of qualified personnel)
     Small water  systems typically face  severe economic  constraints.   Their
lack of operating revenues results in significant limitations on their ability
to respond to the requirements of the SDWA.  These systems cannot benefit from
the economies of scale which are available to larger systems.
     The  second  difficulty  facing the  small systems  has been  the  lack  of
appropriate treatment technologies.  Although methods for removing most of the
contaminants .known  to occur in  drinking water are  available,  many  of  these
technologies have only recently been scaled down for the smaller systems.
     The  third problem which has  traditionally plagued small systems  is the
lack of well  trained operators.   This  deficiency is the  result of  many com-
bined factors.  First  of all,  many of these operators  are employed  only on a
part-time basis  or  if they are  employed on  a full-time  basis they have a
myriad of additional duties.  In addition, the operator's technical background
may be  limited  as well.  This results from  the  low salary of  the  position,
which is uninviting to qualified operators.  Also, in spite of the requirement
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of retaining certified operators upheld-in many states, it seems to be diffi-
cult to enforce this requirement in small  systems.
     The  purpose  of this  appendix is  to  provide  assistance  to  the Primacy
Agency in defining the problems and  potential solutions typically associated
with small  systems.   It is  beyond the scope  of .this  document to  provide an
indepth  dicussion of  the needs  of  small systems.   However,  over  the past
several years the needs of the  small  water systems  have been recognized to be
of primary  concern and numerous workshops, seminars  and committees have been
attempting  to  more clearly  define  workable solutions.  A  partial  listing of
the  papers, reports  and  proceedings which   discuss  problems  and solutions
pertaining  to  small  systems beyond that  which is possible  in  this manual is
presented in the reference list of this appendix.

Economics
     One of the most severe constraints of  small  systems is the small economic
base from which  to draw funds.  Certain  treatment and services must be pro-
vided for a community  regardless  of how few people  are served.  Thus, as the
number of connections to  the  system decrease,  the  cost per  connection  in-
creases.  The  economic limitations of small  utilities makes it difficult to
provide  needed upgrading  of existing  facilities  or  an  adequate salary  to
maintain  the employment  of  a qualified  operator to monitor  and maintain the
system.  Adding to the severity of  the economic hardships of small systems is
the  fact that  many of  the  small water  systems are privately owned,  with
private ownership  increasing as system size decreases.  The  ownership of the
plant presents difficulties  since privately owned systems are subject to rate
controls by the local  public utility commission, are  not  eligible  for public
grants and loans, and may find commercial loans hard to obtain.
     Financing options for  small  systems include; federal  and  state  loan and
grant  programs,   federal  revenue  sharing  and revenue  bonds  (for municipal
systems)  and  loans through  the United  States Small  Business  Administration
(SBA) and use  of industrial  development  bonds or privatization (for private
utilities).  These  options  are explained  in  greater  detail  in the "Guidance
Manual -  Institutional Alternatives  for  Small  Water  Systems" (AWWA, 1986).
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The following paragraphs will explain some existing options which may ease the
hardship of financing small water treatment facilities.
     The major  cause of  small system  difficulties arises  from the  lack of
funds and resources.  It is therefore in the  best interest of small utilities
to expand their economic base  and the  resources available to them, to achieve
the economies of  scale available  to larger  systems.   Regionalization  is the
physical or  operational union of  small systems to  effect this  goal.   This
union can be accomplished through  the physical interconnection of two or more
small systems or  the connection of  a smaller system  to a pre-existing larger
system.  Water  supply  systems can  also join together  for  the purchase of
supplies, materials, engineering services, billing and maintenance.  The union
of the small  systems increases the  population served,  thereby dispersing the
operational costs and decreasing the cost per  consumer.
     The creation of utility satellites  is another form of regionalization.  A
satellite utility  is one  which taps into the resources of an existing larger
facility without being physically connected to, or owned by, the larger facil-
ity.  The  larger  system  may  provide  any  of the  following  for the  smaller
system:
     1.   Varying levels of technical operational, or managerial assistance on
          a contract basis.
     2.   Wholesale treated water with or without additional services.
     3.   Assuming  ownership,  operation  and  maintenance  responsibility  when
          the small system is physically separate with a separate source.
     The  formation  of  a  satellite offers   many  advantages  for  both  the
satellite  and the  parent utility.   These advantages  include:  an  improved
economy  of scale  for satellites,  an  expanded  revenue  base  for the  parent
utility, provisions of  needed resources to satellites,  the  retention  of the
satellites'  local   autonomy,   improved  water   quality   management   of  the
satellite, improved use of public funds  for publicly owned satellites.
     In order to  create a  more definite structure for  the union of resources
of  water  treatment  facilities,  water  districts  may  be  created.   Water
districts are formed by county officials and  provide  for the public ownership
of the utilities.  The utilities in  any given  district would combine resources
and/or physically connect systems  so that  one or two facilities would provide
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water  for  the  entire  district.   The creation  of  water  districts creates
eligibility  for public  monies,  has  the potential  for  economies  of  size,
facilitates the takeover or  contract services with publicly owned non-commun-
ity  systems and small privately owned systems,  and offers  a tax advantage.
Drawbacks include  subjection to politics,  a strong  local  planning  effort is
needed for success, and competition with private enterprises.
     The centralization of utilities can be taken one step  further through the
creation  of county utilities  or even  state  utilities.  The  government will
create a board which may then  act  to acquire, construct, maintain and operate
any public  water  supply  within its district,  the  system may provide water on
its own or purchase water from any municipal corporation.   The board may adopt
and administer rules for the construction,  maintenance, protection and use of
public water supplies and the fixation of reasonable rates  for water supplies.
The  cost of  construction  and/or  upgrading   of  facilities  may be  defrayed
through  the issuance of bonds  and/or property assessment.  As with  all  the
alternatives, the  creation  of government  control of  the  utilities  has  its
advantages  and  disadvantages.   The  advantages   include:   the  creation  of
central  management,  creation of economy  of scale  for  utilities,  eligibility
for public  grants  and  loans, savings  through  centralized purchasing, manage-
ment, consultation, planning and technical  assistance,  and possible provision
for pool of trained operators.   The disadvantages  include the subjectivity to
politics, the slow response  caused  by  bureaucracy, and competition to private
contractors.

Treatment Technologies
     The high cost of  available treatment technologies has limited  their  use
in  small water  supply systems.   Recently  prefabricated package plants  and
individual treatment units have been developed to  lessen these costs.  At  the
present time, the treatment technologies which are available to enable systems
to comply with the Safe Drinking Water Act are identified to be the following!
       -  Package plants
       -  Slow-sand filters
       -  Diatomaceous earth filters
       -  Cartridge filtration
     A brief discussion of each treatment method is provided below.
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     Package Plants
     Clarification and filtration units which  require  minimal assembly in the
field can now be manufactured.   To  minimize required operator skill level and
operational attention, the equipment should be automated.  Continuous effluent
turbidity  and  disinfectant  residual  monitoring  systems  with  alarms  and
emergency shutdown provisions  are  features  that safeguard water  quality and
should be provided for unattended plants.
     Slow-Sand Filters
     Slow-sand filters  are applicable to  small water  supply systems.   Their
proven record of effective removal  of turbidity and Giardia  cysts makes them
suitable for  application  where  operational attention  is minimal.   Since  no
chemicals other than a disinfectant are needed, and no mechanical equipment is
involved, the  required  operator skill level is the lowest of the filtration
alternatives available to small systems.
     Diatomaceous Earth Filters
     Diatomaceous  earth  (DE)  pressure  and vacuum filters  can  be  used  on
relatively low turbidity surface waters  (less  than 1 to 2 NTU) for removal of
turbidity and Giardia cysts.   DE filters can  effectively remove particles as
small as 1 micron, but would require  coagulating chemicals and special filter
aids to provide significant virus removal.
     Cartridge Filters
     Cartridge filters  using  microporous  ceramic  filter elements with pore
sizes  as small  as  0.2 urn  may be  suitable for producing potable water,  in
combination with disinfection,  from  raw water supplies  containing  moderate
levels of turbidity,  algae, protozoa  and bacteria.  The  advantage to a small
system,  is, with the exception of  chlorination,  that no  other  chemicals are
required.  The process is  one  of strictly  physical removal of small particles
by  straining  as  the water passes  through  the porous membranes.   Other than
occasional cleaning or membrane  replacement, operational requirements are not
complex and do not require skilled personnel.
     Selection of a Filtration Technology
     The criteria for selection of a filtration technology for a small commun-
ity are  essentially  the same  as  those  for a  larger community.   That is, the
utility  must  first  screen the  complete  list of  available  alternatives  to
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eliminate  those  which are  either  not technically  suited  to  the existing
conditions  (Table 4-1)  or not affordable by  the utility.  Remaining alterna-
tives  should then  be  evaluated based  on both cost  (capital,  annual,  and
life-cycle)  and non-cost  bases  (operation and maintenance, technical require-
ments versus personnel available; flexibility  regarding  future needs; etc.).
In  these evaluations  it  should be  noted  that even  though automated package
plants are  cost-competitive  with slow sand filters,  their operation require-
ments  to  achieve  optimum  performance  could  be   complicated.   Also,  the
maintenance  requirements  for  package  plants  would  be  mechanically  and
electrically  oriented  and  might  require a  maintenance  agreement with  the
manufacturer.
     During  the process of installing the treatment  system,  interim measures
should be  taken  to  ensure the  delivery of  a reasonably  safe water  to  the
consumers.    In   addition  to  the  available   interim  measures  listed  in
Section 9.3,  temporary  installation  of  mobile  filtration  plants  may  be
possible.   These  trailer-mounted  units  are  sometimes  available  from state
agencies for emergencies, but  more often  may  be  rented  or leased  from an
equipment manufacturer.
     Modification of Existing Filtration Systems
     Small treatment systems that are  already in existence should comply with
the performance  criteria of the  SWTR.  If the systems  are  not  found  to be
performing  satisfactorily,  modifications  to  the  existing  process  may  be
required.  Improvement  in treatment  efficiency  depends on the type of filtra-
tion system  in use.   Operation  of slow sand  filters  could be checked for bed
depth, short-circuiting, excessive hydraulic  loading, and for the need to pre-
treat the  raw water.  Infiltration  galleries,  or sometimes,  roughing filters
ahead of a slow sand filter may provide for better performance by reducing the
solids load  on the  filters.   However,  the design criteria and costs for this
alternative have  not yet been defined.   Site  specific studies may be required
before roughing filters could be used to achieve compliance  with the regula-
tions.   Diatomaceous earth  (DE)  filters  should be  checked  for appropriate
precoat and body  feed application, hydraulic  loading, grade (size) of DE being
used, and possible need for  chemical pretreatment.   Package plants would have
to  be   checked   process-by-process,  similar  to  the   system  used  for  a
                                      L-6

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conventional plant.  Other  filtration processes would have  to  be checked for
hydraulic loading  rate,  appropriateness of  the filter material  (pore size),
and possible need for additional pretreatment.
     Disinfection
     Disinfection  (CT)  requirements for small  systems  can be  met  in several
different  ways.    The   most  obvious   method of  maintaining   a  disinfectant
residual in  the  distribution system  is  to  add disinfectant  at one  or  more
additional locations.   An  alternate  method  is  to increase the  disinfectant
dose at the  existing application point(s).  The  latter  alternative, however,
may increase disinfectant byproducts, including THMs, in the system.
     If it is a relatively short distance between the treatment system and the
first  customer,   additional  contact   time   can   be provided  so  that  the
disinfectant dose  does  not have  to be increased beyond  desirable residuals.
Two  specific  methods   of  increasing  contact  time  for  small  systems  are
1) installing a pressure  vessel or closed storage vessel, baffled to provide
adequate contact time,  or 2)  constructing a looped pipeline,  on  the finished
water line between the  filtration-disinfection  system and the  first customer.
The feasibility of  either of these methods  would depend on system specifics
that include size,  physical conditions, and cost.
     If it is not practical to  provide additional  storage  time to achieve the
desired  CT,  an  alternate,  more  effective  disinfectant may be  used.   An
alternate disinfectant may provide a sufficient CT without altering the system
configuration.

Operations
     Water treatment facilities  need  to  be operated  properly  in  order  to
achieve maximum  treatment efficiencies.   There is  currently  a  lack  of  well
trained operators at many small treatment plants.  The main cause is lack of
awareness of the  importance  of  correct  plant operation,  lack  of training
programs, lack of enforcement of the requirement for employment of a certified
operator and lack of funds to employ such an operator.
     Small systems may wish to implement a circuit rider/operator program.  In
this program a qualified, certified,  experienced  operator  works for several
water supply systems.   The rider  can  either directly operate  the plants,  or
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provide  technical  assistance to  individual plant  operators, by  acting as a
trainer through on-the-job  supervision.   The latter would be preferable since
it could create a pool of well trained operators.
     The main cause of  inadequately trained  operators  is  the lack  of well
established  training  programs.    Until  such  training  programs   are  begun,
systems must depend on other training means, such as seminars and books.  One
resource which may  be  helpful   in  running  the plant is  "Basic Management
Principles  for Small Water  Systems  -  An AWWA  Small-Systems Resource Book",
1982.
     Most  package  plant  manufacturers'  equipment  manuals  include at least
brief  sections  on  operating  principles,  methods  for  establishing  proper
chemical dosages, instructions for operating the equipment,  and troubleshoot-
ing guides.   An  individual  who studies these basic instructions and receives
comprehensive  start-up  training  should  be  able  to  operate   the  equipment
satisfactorily.  These services are  vital to the successful performance of a
package water treatment plant and should be a requirement of the package plant
manufacturer.  The engineer designing a package plant facility should specify
that start-up and training  services be  provided by  the manufacturer, and also
should consider requiring the  manufacturer to visit  the  plant  at 6-month and
1-year intervals after start-up  to  adjust the  equipment,  review operations,
and retrain operating personnel.  Further,  this program should be ongoing and
funds should  be budgeted every year for  at least one  revisit  by  the package
plant manufacturer.
     Another way for small  systems to obtain qualified plant operation would
be to contract the  services of administrativet  operations, and/or maintenance
personnel  from a  larger neighboring  utility,  government  agencies,  service
companies or consulting firms.   These organizations could supply assistance in
financial  and  legal  planning,  engineering,  purchasing  accounting  and collec-
tion  services,  laboratory support,  licensed operators or  operator training,
treatment  and water quality assurance,  regulatory liaison,  and/or emergency
assistance.   Through the contracting of  these  services  the utility provides
for the  resources  needed, improves water quality management and  retains its
autonomy.   However,  if  and when the  contract is  terminated,  the  utility
returns to its original status.
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References

American Water Works Association.  Basic Management Principles for Small Water
Systems, 1982.

American  Water  Works  Association.   Design  and Construction  of Small  Water
Systems, 1984.
Kelly,  Gidley,  Blair  and  Wolfe,  Inc.   Guidance  Manual  -  Institutional
Alternatives  for Small  Water  Systems.   AWWA Research  Foundation  Contract
79-84, 1986.
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            APPENDIX M

       PILOT STUDY PROTOCOL
FOR ALTERNATE FILTRATION TECHNOLOGY

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                                  APPENDIX M

     If a system  desires  to use an  alternate  filtration  technology,  then the
system must demonstrate  through pilot  testing that the  alternate  technology
can  meet the  performance  criteria  for  virus  and Giardia  removal  and/or
inactivation.   However, pilot testing for virus removal is not required if the
water to be disinfected has a turbidity less  than  1 NTU  and  sufficient  CT is
provided to  achieve  4-log virus  inactivation.   Alternate technologies  may
include  demonstrated technologies  operating  outside  the  range of  accepted
design criteria.
     This appendix  provides a  recommended protocol for  evaluating  alternate
filtration methods  through  pilot  testing.    This  protocol  is  divided  into
sections:
       -  Pilot Plant
       -  Testing Program
       -  Monitoring and analyses.

Pilot Plant
     The primary  consideration  in design of the pilot plant  is  to  adequately
simulate the treatment  provided by  the full  scale  facility.  Criteria  which
should be considered in the pilot plant design include but are not  limited to
the parameters in the following list.
     Treatment Process                  Criteria
     Rapid Mix                          Number of Stages
                                        Detention Time
                                        Mixing Intensity
     Flocculation                       Number of Stages
                                        Detention Time
                                        Mixing Intensity(ies)
     Sedimentation                      Unit Type (plate, tube, etc.)
                                        Loading Rates
     Filtration                         Media type and size
                                        Media depth
                                        Loading Rate
                                        Operation Mode (constant rate,
                                          declining rate)
     Chemical  Addition                  Location
                                        Dosage
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Testing Program
     In developing a pilot testing procedure or study to evaluate an alternate
filtration technology, seasonal water quality variations should be reviewed in
order  to  establish  the  annual worst case  water quality  conditions for  an
individual source  water.   The water  quality parameters  which should be  re-
viewed include:
       -  Total and/or Fecal Colifonns
       -  Heterotrophic plate count
       -  Turbidity
       -  Temperature
       -  pH
       -  Color
       -  Chlorine demand

     As a minimum, pilot testing should be  conducted  when the source exhibits

its  worst case  annual  conditions.   However,  it  is preferable  to  perform

testing under all seasonal water quality conditions.
     The  design  of pilot plant studies will depend  on a variety  of factors

including the technology being evaluated and individual site constraints.  Any

pilot study should include consideration of the following (Thompson, 1982)    •

       -  Definition of purpose of study
       -  Identification of end product of study
       -  Collection of available  background information
       -  Acquisition of additional information required
       -  Establishment of size of pilot plant and available space
       -  Determination of who will operate pilot plant
       -  Ascertainment of how it should be operated
       -  Establishment of life of pilot plant
       -  Determination of  frequency and  location of  sample collection  and
          analysis
       -  Modification of pilot plant (if required)
       -  Revision of goals and budget if necessary
       -  Preparation of design and construction of pilot plant based on above
       -  Recording of all pilot plant data
     1.Additional information on  the  design of specific pilot  studies  can be
     found in the following references:
       -  Overview of Pilot Plant Studies.  (Thompson, 1982)

       -  Water Treatment Principles and Design, James M. Montgomery.

       -  Al-Ani, C.SoU.,  Filtration of  Giardia  Cysts and  Other Substances:
          Volume 3.   Rapid Rate Filtration  (EPA/600/2-85/027).
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          Performance of critical data analysis
       -  Reporting of Substantiated Conclusion
Monitoring Requirements
     The purpose  of  the  pilot  testing program  is to  demonstrate that  the
alternate filtration  technology  can meet  the  performance criteria  for  virus
and  Giardia  removal/inactivation  outlined  in  section 5.    The  monitoring
locations and  frequency  should  therefore be  selected  to  comply with  these
requirements.   For example,  filter  effluent  turbidity  should be  monitored
continuously or, at a minimum  every four hours.   Disinfectant residual should
also be monitored as outlined in Section 5.

References
     J. C. Thompson,  "Overview of  Pilot  Plant  Studies  in   Proceedings  AWWA
Seminar on Design of Pilot-Plant Studies," May 16, 1982.
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        APPENDIX N

PROTOCOL FOR DEMONSTRATION
  OF EFFECTIVE TREATMENT

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                                  APPENDIX N

                          PROTOCOL FOR DEMONSTRATION
                            OF EFFECTIVE TREATMENT
     Based upon  the  requirements of  the SWTR, the minimum turbidity perfor-
mance criteria for systems using conventional treatment  or direct filtration
is filtered water turbidity less than or equal to 0.5 NTU in 95 percent of the
measurements taken  each  month.   However,  at the  discretion  of  the Primacy
Agency, filtered water  turbidity levels of less than or  equal  to  1 NTU in 95
percent of the measurements  taken every month may be permitted  on a case-by-
case basis if the system can demonstrate by on-site studies that it is achiev-
ing effective removal and/or inactivation of Giardia lamblia cysts, or removal
of cyst-sized particles.   This appendix presents  a protocol which  can be used
by the Primacy Agency to evaluate these demonstrations.
     There are  two  approaches  which  can  be  taken to demonstrate effective
removal and/or inactivation of Giardia cysts:
       -  Provide sufficient disinfection
       -  Perform pilot filtration tests
     With the first approach it  is  necessary to  provide 3-log  Giardia inacti-
vation through disinfection.   This should be done by satisfying the disinfec-
tion criteria presented in Section 3, including the requirements for disinfec-
tion system redundancy expanded  in Appendix  I.  For example, a system utiliz-
ing ozone disinfection at  pH 7 and  a temperature  of 10  C, should provide a CT
of  at  least 2.5 mg/L-min  (see  Table  E-10).   Auxiliary  ozonation equipment
would also be required  including air preparation units,  ozone  generators and
ozone monitors.   If all of these criteria are satisfied, the Primacy Agency may
choose to  allow the  systems filtered  water turbidities  to  exceed  0.5  NTU.
However,  the turbidity  must still  remain below  1  NTU in  95  percent  of the
samples analyzed each month and must never exceed 5 NTU.
     The second approach to demonstrating  adequate  reduction and/or inactiva-
tion of Giardia is through pilot scale filtration tests.   Prior to performing
the tests it is  necessary to demonstrate  that the pilot facilities simulate
full scale plant performance in  terms  of typical  operating parameters includ-
ing chemical types and dosages,  detention times (confirmed by tracer studies),
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mixing  intensities,  and  loading rates  (filtration and  sedimentation).  The
water quality parameters  which  should be monitored for comparison to the full
scale plant should include turbidity, color, oxidant demand and pH.
     These tests can be performed with particles equivalent in size to Giardia
cysts.  To provide a margin of safety in correlating the pilot and plant scale
results,  the  pilot studies must demonstrate sufficient  reduction that, when
combined  with the  inactivation  provided by  disinfection,  a  99.99  percent
reduction and/or inactivation of Giardia cysts is achieved.  For example, if a
filtration  plant provides  2  log inactivation  of  Giardia through  chlorine
addition  (in  accordance  with the  criteria described in  Section 5)  and pilot
studies  indicate that  treatment  will  remove  99  percent  of  Giardia  sized
particles, the Primacy Agency may  decide that  the effluent turbidity limit of
0.5 NTU  can be  raised  to 1.0  NTU in  95 percent  of  the samples  taken each
month.
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        APPENDIX O

PROTOCOLS FOR POINT-OF-USE
          DEVICES

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             UNITED STATES
    ENVIRONMENTAL PROTECTION AGENCY
         Registration Division
     Office of Pesticide Programs
    Criteria and Standards Division
       Office of Drinking Water
    GUIDE STANDARD AND PROTOCOL FOR
TESTING MICROBIOLOGICAL WATER PURIFIERS
         Report of Task Force
         Submitted April, 1986
          Revised April, 1987

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                                   CONTENTS



                                                                      Page

PREFACE

1.    GENERAL                                                          O-l

2.    PERFORMANCE REQUIREMENTS                                         O-6

3.    MICROBIOLOGICAL WATER PURIFIER TEST PROCEDURES                   O-8

APPENDIX O-l   SUMMARY FOR BASIS OF STANDARDS AND                     O-21
  TEST WATER PARAMETERS

APPENDIX 0-2   LIST OF PARTICIPANTS IN TASK FORCE                     O-29

APPENDIX O-3   RESPONSE BY REVIEW SUBCOMMITTEE TO                     O-31
  PUBLIC COMMENTS

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                                  1.  GENERAL


1.1  Introduction


     The subject of microbiological purification  for  waters  of unknown micro-

biological quality repeatedly presents itself to a variety of governmental and

non-governmental agencies,  consumer  groups, manufacturers and  others.   Exam-

ples of possible application of such purification capabilities include:
       -  Backpackers and campers

       -  Non-standard military requirements

       -  Floods and other natural disasters

       -  Foreign travel and  stations  (however,  not for extreme contamination
          situations outside of the U.S.)

       -  Contaminated individual sources, wells and springs (however, not for
          the conversion of waste water to microbiologically potable water)

       -  Motorhomes and trailers

     Batch methods of water purification based on  chlorine  and iodine disin-

fection or boiling  are well  known,  but  many  situations and  personal  choice

call for  the consideration  of water  treatment  equipment.  Federal  agencies
specifically   involved  in  responding  to  questions and  problems relating  to

microbiological purifier equipment include:
       -  Registration Division, Office  of  Pesticide  Programs  (OPP),  Environ-
          mental Protection Agency  (EPA):  registration  of  microbiological
          purifiers  (using chemicals);

       -  Compliance  Monitoring  Staff,  EPA:    control   of  microbiological
          purifier device  claims  (non-registerable products  such as  ultra-
          violet units,  ozonators, chlorine generators, others);

       -  U.S. Army  Medical Bioengineering Research and Development Laboratory
          (USAMBRDL),  U.S.  Army Natick  Research  and  Development Center  and
          other Army  and  military agencies:   research  and development  for
          possible field applications;

       -  Criteria and  Standards Division,  Office of Drinking Water  (ODW),
          EPA:  Consideration of  point-of-use  technology as  acceptable tech-
          nology  under  the  Primary  Drinking  Water  Regulations;  consumer
          information and service;
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       -  Drinking  Water  Research,  Water  Engineering  Research  Laboratory
          (WERL), EPA? responsible for water treatment technology research;
       -  Microbiology Branch, Health Effects Research Laboratory  (HERL), EPA;
          responsible for  study of  health effects related  to drinking water
          filters.
     A  number of  representatives of  the  above  mentioned  agencies provided
excellent participation  in  the task force  to  develop microbiological testing
protocols for water  purifiers.  Major participation was  also provided by the
following:
       -  A technical representative from the Water Quality Association;
       -  A -technical representative  from the  Environmental  Health Center,
          Department of Health and Welfare of Canada; and
       -  An  associate  professor   (microbiology)   from  the  University  of
          Arizona.
1.2  Basic Principles
     1.2.1  Definition
     As set  forth in EPA Enforcement  Strategy and as supported by a Federal
Trade Commission  (FTC)   decision  (FTC v.  Sibco Products  Co., Inc.,  et al.,
Nov. 22,  1965) ,  a   unit,  in  order  to  be called a  microbiological  water
purifier,  must remove, kill or inactivate all  types of disease-causing micro-
organisms from  the water,  including bacteria, viruses and  protozoan cysts so
as to render the processed water  safe  for drinking.  Therefore, to qualify, a
microbiological water purifier must treat or remove  all types of challenge
organisms to meet specified standards.
     1.2.2  General Guide
     The standard and protocol will be a general guide and, in some cases, may
present only  the minimum  features  and  framework  for  testing.  While  basic
features of the standard and protocol have been tested, it was not feasible to
conduct full-fledged  testing  for  all possible types of  units.  Consequently,
protocol users  should include  pre-testing of their  units in  a testing rig,
including the  sampling  techniques to  be used.  Where  users  of the protocol
find good  reason to alter or add  to the guide  in order to meet specific
operational problems, to use an alternate organism or laboratory procedure, or
to  respond  to  innovative  treatment units without decreasing  the  level  of
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testing or  altering the intent of  the protocol, they should  feel  free to do
so.  For  example, the  OPP  Registration Division might  find  it  necessary to
amend  the guide  somewhat  for  different types  of  treatment  units.   Another
example would  be ultraviolet  (U.V.)  units,  which may have  specific require-
ments in addition to the guide protocol.
     1.2.3  Performance-Based
     The  standard will be  performance-based, utilizing realistic  worst case
challenges and test  conditions  and use of the standard  shall  result in water
quality   equivalent  to  that   of   a  public   water   supply   meeting  the
microbiological requirements and intent of the National Primary Drinking Water
Regulations.
     1.2.4  Exceptions
     A  microbiological water  purifier must  remove, kill  or  inactivate  all
types of pathogenic  organisms  if  claims are  made for any  organism.  However,
an exception  for limited claims  may  be  allowed for units  removing specific
organisms to serve a definable  environmental  need (i.e., cyst reduction units
which can be used on otherwise disinfected and microbiologically safe drinking
water,   such as a disinfected but  unfiltered surface water  containing cysts.
Such units are not to be called microbiological water purifiers and should not
be used as sole treatment for an untreated raw water.)
     1.2.5  Not to Cover Non-Microbiological  Reduction Claims
     The treatment of water to achieve removal of a specific chemical or other
non-microbiological substances from water will not be a part of this standard.
National Sanitation Foundation  (NSF)  Standards 42  (Aesthetic  Effects)  and 53
(Health Effects)  provide partial guides  for  chemical removal and other claims
testing.
     1.2.6  Construction and Information Exclusions
     While the standard recommends  safe, responsible  construction  of units
with non-toxic materials for optimum  operation,  all such items and associated
operational considerations  are excluded as  being  beyond  the  scope  of  the
standard.  Included in the exclusion are materials of construction, electrical
and safety aspects, design and  construction  details, operational instructions
and information,  and mechanical performance testing.
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     1.2.7  Research Needs Excluded
     The  guide  standard and  protocol  must  represent  a practical testing
program and not  include  research recommendations.  For example, consideration
of  mutant organisms  or  differentiation  between  injured and  dead  organisms
would be  research items  at  this time and not appropriate for inclusion in the
standard.
     1.2.8  Not to Consider Sabotage
     Esoteric problems which  could be presented by  a variety of hypothetical
terrorist  (or wartime) situations,  would provide an unnecessary complication,
and are not appropriate for inclusion in the standard.
     1.2.9  Continuity
     The  guide  standard  and protocol  will be  a living  document,  subject to
revision  and updating with  the onset of new technology and knowledge.  It is
recommended that the responsible authorities  for registration  and drinking
water quality  review potential needs  every two to  three years and  reconvene
the task  force upon  need or upon request  from  the water quality industry, to
review and update the standard and testing protocol.

1.3  Treatment Units Coverage
     1.3.1  Universe of Possible Treatment Units
     A review  of treatment  units that might be considered as microbiological
purifiers discloses a number of different types covering treatment principles
ranging  from  filtration and  chemical disinfection  to ultraviolet  light  ra-
diation.
     1.3.2  Coverage of This Standard
     In view of  the  limited technical  data available and in order to expedite
the work  of  the task force,  the initial  coverage is limited, on  a priority
basis,  to three  basic   types  of  microbiological water  purifiers  or active
components with their principal means of action as follows:
     1.3.2.1  Ceramic Filtration Candles or Units  (may or
              may not contain a chemical bacteriostatic agent)
     Filtration,  and adsorption,  and  chemical  anti-microbial activity if  a
chemical is included.
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     1.3.2.2  Halogenated Resins and Units
     Chemical  disinfection  and  possibly  filtration.    (Note:    While  not
included in this guide  standard, halogen products for disinfection or systems
using halogen  addition and  fine  filtration may  be  tested using many  of its
elements, i.e., test water parameters, microbiological challenge and reduction
requirements, analytical techniques and other pertinent elements.)
     1.3.2.3  Ultraviolet  (UV) Units
     UV irradiation with  possible  add-on treatment for adsorption and filtra-
tion (not applicable to UV units for  treating potable water from public water
supply systems).
     1.3.3  Application of Principles to Other Units
     While only three types  of units are covered  in this standard, the princi-
ples and approaches  outlined should provide an  initial  guide for the testing
of any of a number of other  types of units and/or systems for the microbiolog-
ical purification of contaminated water.
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                         2,  PERFORMANCE REQUIREMENTS

2ol  Microbiological Water Purifier
     In  order to make  the claim  of "microbiological water  purifier/" units
must be tested and demonstrated to meet the microbiological reduction require-
ments  of Table 1  according  to  the  test procedures  described  in Section 3
(Appendix O-l) for the specific type of unit involved.

2.2  Chemical Health Limits
     Where silver or  some other pesticidal  chemical is used  in  a unit, that
chemical concentration  in the effluent water must meet  any  National Primary
Drinking Water Maximum Contaminant Level  (MCL),  additional Federal guidelines
or otherwise  be  demonstrated not to  constitute  a threat  to  health from con-
sumption or contact where no MCL exists.

2.3  Stability of Pesticidal Chemical
     Where a pesticidal chemical is  used  in  the  treatment unit, the stability
of the  chemical  for disinfectant  effectiveness  should be  sufficient  for the
potential shelf life and the projected use life  of the unit based on manufac-
turer's  data.   Where stability  cannot be  assured  from  historical data  and
information,  additional tests will be required.

2.4  Performance Limitations
     2.4.1  Effective Lifetime
     The manufacturer must provide an explicit indication or  assurance of the
unit's effective use  lifetime to  warn the  consumer of  potential diminished
treatment capability either through:
     a.   Having the unit terminate discharge of treated water, or
     b.   Sounding  an alarm, or
     c.   Providing simple,  explicit instruction  for  servicing  or replacing
          units within the recommended use life  (measurable in terms of volume
          throughput,  specific time frame  or other appropriate method)„
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                                    TABLE 1

                    MICROBIOLOGICAL REDUCTION REQUIREMENTS
     Klebsiella terrigena, a common coliform, was selected as the challenge
organism to represent the coliform group.  Poliovirus 1 (LSc) and rotavirus
(Wa or SA-11) are common environmental viruses and show resistance to
different treatment processes, thereby providing good challenges for the virus
group.  Giardia was selected as the cyst challenge representative because of
its widespread disease impact and its resistance to chemical disinfection.
The use of 4-6 micron particles or beads for testing the occlusion filtration
of cysts has been demonstrated to be an accurate and practical substitute for
the use of live cyst challenges.  It is included as an option where
disinfection or other active processes are not involved.

                                                                      Minimum
                                                                      Required
                                                                      Reduction
                                          Influent
                                          Challenge*
Organism                                  Challenge*        Log

Bacteria:

  Klebsiella terrigena
  (ATCC-33257)

Virus:
  a.  Poliovirus 1 (LSc)
      (ATCC-VR-59) and,

  b.  Rotavirus (Wa or SA-11)
      (ATCC-VR-899 or VR-2018)

Cyst  (Protozoan):  Giardia***
  a.  Giardia muris or
      Giardia lamblia
      or

  b.  As an option for units or
      components based on occlusion
      filtration:  particles
      or spheres, 4-6 microns

 (Testing according to National Sanitation Foundation Standard  53 for cyst
reduction will be acceptable.
                                          10 /100 ml
                                            1 x  10 /L
                                            1 x  10 /L
                                              106/L
                                              10?/L
99.9999
99.99**
99.99**
99.9
99.9
           The influent challenges may constitute greater concentrations than
           would be anticipated in source waters, but these are necessary to
           properly test,  analyze and quantitatively determine the indicated
           log reductions.

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                                TABLE 1

          MICROBIOLOGICAL REDUCTION REQUIREMENTS (Continued)
**    Virus types are to be mixed in roughly equal 1 x 10 /L
      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.

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     2.4.2  Limitation on Use of Iodine
     EPA policy  initially developed in 1973  and reaffirmed in 1982  (memo  of
March 3, 1982  from J. A. Cotruvo to G. A. Jones,  subject:   "Policy on Iodine
Disinfection")  is  that  iodine  disinfection  is  acceptable for  short-term  or
limited  or emergency  use but  that it  is not  recommended for  long-term  or
routine community water  supply application where iodine-containing  species may
remain in the drinking water.
                                       0-7

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              3=  MICROBIOLOGICAL WATER PURIFIER TEST PROCEDURES

3.1  Purpose
     These tests  are  performed on ceramic  filtration  candles or units, halo-
genated resins  and  units and ultraviolet  (UV)  units in order to substantiate
their microbiological removal  capabilities  over the effective use life of the
purifier as  defined in Table 1 and,  where a pesticidal  chemical  is used, to
determine  that  said  chemical  is  not present  in  the  effluent  at excessive
levels (see Section 3.5.3.4, Appendix 0).

3.2  Apparatus
     Three production  units of a type are to be  tested,  simultaneously, if
feasible;  otherwise, in a manner as similar to that as possible.
     Design of the  testing  rig must  parallel and simulate projected field use
conditions.  For  plumbed-in units a guide  for  design  of the  test  rig may be
taken from "Figure 1:   Test Apparatus-Schematic" (p. A-2 of Standard Number 53
"Drinking  Water  Treatment  Units —  Health  Effects,"  National  Sanitation
Foundation).   Otherwise, the test rig must be  designed to simulate field use
conditions (worst case)  for the unit to be tested.

3.3  Test Waters — Non-Microbiological Parameters
     In addition to the microbiological influent  challenges,  the various test
waters will  be  constituted with chemical and  physical characteristics  as
follows:
     3.3.1  Test Water #1 (General Test Water)
     This water is  intended for the  normal non-stressed (non-challenge)  phase
of testing for  all units  and  shall  have  specific characteristics  which  may
easily be  obtained by  the  adjustment of  many public  system tap  waters,  as
follows:
     a.   It shall be free of any chlorine or other disinfectant residuali
     b.   pH —  6.5 --8.5;
     c.   Total  Organic Carbon  (TOC)  0.1 - 5.0 mg/Lf
     d.   Turbidity 0.1-5 NTU;
                                      O-8

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     e.   Temperature 20 C * 5 C; and
     f.   Total Dissolved Solids  (TDS) 50 - 500 mg/L.
     3-3.2  Test Water #2 (Challenge Test Water/Halogen Disinfection)
     This water is  intended  for  the stressed challenge phase of testing where
units involve halogen disinfectants (halogen resins  or other units)  and shall
have the following specific characteristics:
     a.   Free of chlorine or other disinfectant residual;
     b.   (1)  pH 9.0 * .2, and
          (2)  for  iodine-based  units a pH  of  5.0 "  .2  (current information
          indicates that  the low pH  will be the  most severe test  for virus
          reduction by iodine disinfection);
     c.   Total Organic Carbon (TOC) not less than 10 mg/L;
     d.   Turbidity not less than 30 NTU;
     e.   Temperature 4 C " 1 C;  and
     f.   Total Dissolved Solids  (TDS) 1,500 mg/L * 150 mg/L.
     3.3.3  Test Water #3 (Challenge Test Water/Ceramic Candle
            or Units With or Without Silver Impregnation)	
     This water is  intended for  the  stressed challenge phase of  testing  for
the indicated  units but not  for such units  when  impregnated with  a  halogen
disinfectant (for the latter, use Test Water #2).  It shall have the following
specific characteristics:
     a.   It shall be free of any chlorine or other disinfectant residual;
     b.   pH 9.0 * .2;
     c.   Total Organic Carbon (TOC) — not less than 10 mg/L;
     d.   Turbidity — not less than 30 NTU;
     e.   Temperature 4 C *  1 C;  and
     f.   Total Dissolved Solids   (TDS) — 1,500 jng/L * 150 mg/L.
     3.3.4  Test Water #4 (Challenge Test Water for Ultraviolet Units)
     This water is intended for the stressed phase of testing for UV units and
shall have the following specific characteristics:
                                      0-9

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     a.   Free of chlorine or other disinfectant residual;

     b.   pH 6.5 - 8.5;

     c.   Total Organic Carbon (TOG) •— not less than 10 mg/L;

     d.   Turbidity •— not less than 30 NTU;

     e.   Temperature 4 C * 1C;

     f.   Total Dissolved Solids (TDS)  — 1,500 mg/1 " 150 mg/L;

     g.   Color U.V.  absorption (absorption  at 254  run)  —  Sufficient para-
          hydroxybenzoic acid (PHBH) to be just below the trigger point of the
          warning alarm on the U.V. unit.   (Note that Section 3.5.1.1 provides
          an alternative of adjusting the U.V. lamp electronically, especially
          when the U.V. lamp is preceded by activated carbon treatment.)

     3.3.5  Test Water t5 (Leaching Test Water for Units Containing Silver)
     This water is  intended for stressed  leaching tests of  units containing

silver to assure  that excess levels of silver will  not be  leached  into the
drinking water.  It shall have the  following specific characteristics:

     a.   Free of chlorine or other disinfectant residual;

     b.   pH — 5.0 * 0.2;

     c.   Total Organic Carbon (TOC) —• approximately 1.0 mg/L;

     d.   Turbidity — 0.1 - 5 NTU;

     e.   Temperature — 20 C *  5 C; and

     f.   Total Dissolved Solids (TDS)  — 25 - 100 mg/L.

     3.3.6  Recommended Materials for Adjusting Test Water Characteristics
     a.   pH:  inorganic acids or bases (i.e., HC1, NaOH);

     b.   Total Organic Carbon (TOC):   humic acids;

     c,   Turbidity:  A.C. Fine Test Dust (Park No. 1543094)

               from:     A.C. Spark Plug Division
                         General Motors Corporation
                         1300 North Dort Highway
                         Flint,  Michigan 48556;

     d.   Total Dissolved Solids (TDS):  sea  salts,  Sigma Chemical Co., S9883
          (St. Louis,MO) or another equivalent source of TDS;
                                     0-10

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     e.   Color  U.V.  Absorption:   p-hydroxybenzoic  acid  (grade:    general
          purpose reagent).

3.4  Analytical Methods

     3.4.1  Microbiological Methods

     Methods in this section  are  considered  "state-of-the-art"  at  the  time  of

its preparation and  subsequent  improvements  should be  expected.  Methods  used

for microbiological analyses  should be  compatible with and equal to  or better
than those given below.

     3.4.1.1  Bacterial Tests

     a.   Chosen Organism:  Klebsiella terrigena (ATCC-33257).

     b.   Method of  Production:   Test organism will be prepared by  overnight
          growth in nutrient broth or equivalent to obtain the  organism in the
          stationary  growth  phase   (Reference:   Asburg,  E.D.,   Methods  of
          Testing Sanitizers  and  Bacteriostatic  Substances In:  Disinfection,
          Sterilization and Preservation, Seymour S. Block,  ed., pp. 964-980,
          1983) .  The organism will be  collected by  centrifugation and washed
          three times in phosphate buffered saline before use.   Alternatively,
          the  organisms  may  be grown  overnight on nutrient  agar  slants  or
          equivalent  and washed  from  the  slants  with  phosphate  buffered
          saline.  The suspensions should be filtered  through  sterile  Whatman
          Number 2  filter  paper  (or  equivalent)  to remove  any  bacterial
          clumps.  Mew batches of organisms must be prepared daily for use  in
          challenge testing.

     c.   State of  Organism:   Organisms  in  the  stationary  growth phase and
          suspended in phosphate buffered saline will be used.

     d.   Assay Techniques:    Assay may  be  by the spread plate, pour plate  or
          membrane filter technique on  nutrient  agar,  M.F.C. or m-Endo medium
          (Standard Methods for the Examination  of Water  and Wastewater,  16th
          edition,  1985,  APHA).   Each  sample  dilution  will   be  assayed  in
          triplicate.

     3.4.1.2  Virus Tests
     a.   Chosen Organisms:    Poliovirus type 1  (LSc)   (ATCC-VR-59),  and Rota-
          virus Strain SA-11  (ATCC-VR-899)  or WA (ATCC-VR-2018).

     b.   Method  of Production:   All  stocks   should  be  grown by  a  method
          described by Smith  and  Gerba  (in Methods  in  Environmental  Virology,
          pp. 15-47, 1982)  and purified by the procedure  of Sharp,   et al.
          (Appl. Microbiol.,  29:94-101, 1975),  or similar procedure  (Berman
          and  Hoff,  Appl. Environ.  Microbiol., 48:317-323,  1984),  as these
          methods will produce largely monodispersed virion particles.
                                     O-ll

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c.   State of  the  Organism:   Preparation procedure  will largely produce
     monodispersed particles,

d.   Assay Techniques?  Poliovirus type 1 may be grown in the BGM, MA-104
     or other cell line which will support the growth of this virus.  The
     rotaviruses are  best grown in  the  MA-104  cell line.   Since  both
     viruses can be assayed on the MA-104 cell line, a challenge test may
     consist of  equal amounts  of both viruses  as a mixture  (i.e.,  the
     mixture must contain  at least 1.0 x 10 /mL  of  each virus).  Assays
     may be as plaque forming units  (PFU) or  as immunofluorescence foci
     (IF)  (Smith and Gerba,  In:   Methods  in  Environmental  Virology,
     pp. 15-47, 1982).  Each dilution will be assayed in triplicate.

3.4.1.3  Cyst Tests

a.   Chosen Organism

     1.   Giardia lamblia or the  related  organism, Giardia muris,  may be
          used as the challenge cyst.

     2.   Where filtration is involved, tests  with 4-6  micron spheres or
          particles have been found to be satisfactory and may be used as
          a substitute for tests of occlusion using  live organisms (see
          Table 1).   Spheres  or particles may only be  used  to evaluate
          filtration efficacy.  Disinfection efficacy can only be evalu-
          ated with the use of viable Giardia cysts.

b.   Method of Production:   Giardia muris may be  produced in laboratory
     mice  and  Giardia  lamblia  may  be  produced  in Mongolian  gerbils;
     inactivation  results  based  on  excystation  measurements  correlate
     well with animal infectivity results.

c.   State  of  the  Organisms   Organisms  may  be separated  from  fecal
     material  by  the  procedure  described  by  Sauch   (Appl.  Environ.
     Microbiol., 48:454-455, 1984)   or  by  the   procedure described  by
     Bingham, et al.  (Exp.  Parasitol., 47:284-281, 1979).

d.   Assay Techniques:  Cysts are first reconcentrated  (500 ml., minimum
     sample  size)  according  to the  method  of  Rice, Hoff and Schaefer
     (Appl.  Environ.  Microbiol.,  43:250-251,   1982).   The  excystation
     method described by Schaefer, et al.   (Trans.,  Royal Soc.  of Trop.
     Med.  &  Hyg. 78:795-800,  1984)  shall  be used  to  evaluate Giardia
     muris cyst  viability.  For  Giardia  lamblia  cysts,  the  excystation
     method described by Bingham and Meyer (Nature, 277:301-302, 1979) or
     Rice  and  Schaefer  (J. Clin. Microbiol.,  14:709-710,  1981)  shall be
     used.  Cyst viability  may also  be  determined  by an assay  method
     involving  the counting of  trophozoites  as well  as intact  cysts
     (Bingham,  et al., Exp. Parasitol., 47:284-291, 1979).
                                0-12

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     3.4.2  Chemical and Physical Methods

     All physical and  chemical  analyses  shall be conducted in accordance with
procedures in  Standard Methods  for  the  Examination of Water  and Wastewater,

16th Edition, American Public Health Association, or equivalent.


3.5  Test Procedures

     3.5.1  Procedure - Plumbed-in Units

     a-   1-   Install three production  units of a type as  shown in Figure 1
               and  condition each  unit  prior  to the  start of  the test  in
               accordance with  the  manufacturer's instructions with  the test
               water without the addition  of the test  contaminant.   Measure
               the flow rate through each  unit.  The unit shall  be  tested at
               the maximum  system pressure  of  60 psig  static and  flow rate
               will not be artificially controlled.

          2.   Test waters shall have the defined characteristics continuously
               except  for test  waters 2, 3  and 4 with respect  to turbidity.
               The background non-sampling  turbidity  level will be maintained
               at  0.1-5  NTU  but  the turbidity shall  be  increased to  the
               challenge  level   of   not  less  than  30  NTU  in  the  following
               manner:

                 -  In the "on"  period(s) prior to the sampling "on"  period.

                 -  In the sampling  "on" period when  the  sample actually will
                    be taken.   (Note:  at least 10 unit void volumes  of the 30
                    NTU water   shall  pass  through  the  unit  prior to  actual
                    sampling so as  to  provide adequate  seasoning   and  uni-
                    formity before sample collection.)

     b.   1.   Use appropriate  techniques  of  dilution  and insure  continual
               mixing to prepare a challenge solution containing the bacterial
               contaminant.    Then  spike  test  water continuously  with  the
               influent concentration specified in Table 1.

          2.   Use appropriate  techniques to prepare concentrated virus  and
               Giardia suspensions.  Feed these suspensions  into the influent
               stream so as  to  achieve the  influent  concentrations  specified
               in Table 1 in the following manner:

                 -  In the "on"  period(s) prior to the sampling "on"  period.

                 -  In the sampling  "on" period when  the  sample actually will
                    be taken.   (Note:  at least 10 unit void volumes of seeded
                    water shall pass through  the unit prior  to sampling so as
                    to provide adequate seasoning and uniformity before sample
                    collection.)
                                     0-13

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     c.   Purge the system of  the  uncontaminated water with a sufficient flow
          of contaminated test water.   Start an operating cycle of 10 percent
          on, 90 percent off with a 15 to 40 minute cycle  (Examples  3 minutes
          on, 27 minutes  off)  with the contaminated test  water.   This cycle
          shall be continued for not more than 16 hours per day  (minimum daily
          rest period of 8 hours).  The total program shall extend to 100% of
          estimated volume  capacity for halogenated  resins or  units  and for
          10-1/2 days for ceramic candles or units and U.V. units.

     d.   Sampling:  Samples of  influent and effluent water  at the specified
          sampling points  shall  be collected  as shown below  for  the various
          units; these  are  minimum sampling  plans  which may  be increased in
          number  by the  investigator.   All  samples shall  be collected  in
          duplicate from the flowing water during the sampling "on" portion of
          the cycle and they  shall be one "unit void volume" in quantity (or
          of  appropriate quantity for  analysis)  and  represent  worst  case
          challenge conditions.   Effluent samples shall  usually be collected
          near the  middle of  the  sampling "on"  period  (or the whole volume
          during one "on"  period)  except for  samples following the specified
          "stagnation" periods,  for which sampling shall be  conducted on the
          first water volume  out of the  unit.   Each sample will  be  taken in
          duplicate and shall be  retained  and  appropriately  preserved,  if
          required, for chemical  or  microbiological analysis  in the  event
          verification  is required.   (For units where the  volume  of  a single
          "on" period is insufficient  for the required analysis, samples from
          successive "on" periods may be accumulated until a sufficient volume
          has been collected.)

l(a).  Sampling Plan:   Halogenated Resins or Units (Non-iodine Based)
                                                       Tests
Test Point
(% of Estimated
Capacity)	

Start
  25%
  50%
After 48 hours
  stagnation
               Influent
               Background
General
Active
Agent/
Residual

   X
   X
   X
Microbiological

       X
       X
       X
  60%
  75%
After 48 hours
  stagnation
  100%
Chal-
lenge
PH -
9.0 ' 0.2
   X
   X

   X
   X
       X
       X

       X
       X
                                     0-14

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Kb).  Sampling Plan:  lodinated Resins or Units
Test Point
(% of Estimated
Capacity)	

Start
  25%
  50%
After 48 hours
  stagnation
                                                       Tests
                    General
Influent
Background

     X
Active
Agent/
Residual

   X
   X
   X
Microbiological

       X
       X
       X
  60%
  75%
After 48 hours
  stagnation
                    Chal-
                    lenge
                    PH -
                    9.0 ' 0.2
                  X
                  X
                      X
                      X
  90%
 100%
After 48 hours
  stagnation
                    Chal-
                    lenge
                    pH -
                    5.0 * 0.2
                  X
                  X
                      X
                      X
2.  Sampling Plan:  Ceramic Candles or Units and U.V. Units
                                                       Tests
Test Point
Start
Day 3
Day 6
                              Test
                              Water

                              General
          Influent
          Background
      (middle)
      (middle)
After 48 hours
  stagnation
               Microbiological

                      X
                      X
                      X
Day 7 (middle)
Day 8 (near end)
After 48 hours
  stagnation
Day 10-1/2
                              Chal-
                              lenge
                                     X
                                     X

                                     X
                                     X
(Note:  All days are "running days" and exclude stagnation periods.  When
the units contain silver, a leaching test shall be conducted as shown in
Section 3.5.1.e and silver residual will be measured at each microbiological
sampling point.)
                                     O-15

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          Leaching  Tests  for  Silverized Unitss   Where  the  unit  contains
          silver, additional  tests  utilizing Test Water #5 will  be conducted
          as follows:

                                                  Tests
                                   Influent
Test Point                         Background               Silver/Residual

Start                                  X                          X
Day 2                                                             X
After 48 hours
  stagnation                                                      X
     f.   Alternate Sampling Plans:

          1.   Since some laboratories may  find it inconvenient to  test some
               units on  a 16  hour on/8  hour off  cycle,  two  alternates  are
               recognized:

                 -  Go to a  shorter  operational day but lengthen  the  days of
                    test proportionally

                 -  Use up to  20  percent "on"/80 percent "off" for  a  propor-
                    tionally shorter operational day

          2.   Sampling points must be appropriately adjusted in any alternate
               sampling plan.

     g.   Application  of Test  Waters:   The application  of  test waters  is
          designed to provide information on performance under both normal  and
          stressed conditions?  it should be the  same or  equivalent  to  the
          followings

          1.   a.   Halogenated Resins or Units (Non-iodine based)  —•

                    First 50% of test period:     Test Water 1 (General)
                    Last 50% of test period:      Test Water 2 (Challenge)
                                                  (pH - 9.0 * 0.2)

               b.   lodinated Resins or Units —

                    First 50% of test period:     Test Water 1 (General)
                    Next 25% of test period:      Test Water 2 (Challenge)
                                                  (pH - 9.0 ' 0.2)
                    Last 25% of test period:      Test Water 2 (Challenge)
                                                  (but with pH - 5.0 *  0.2)

          2.   Ceramic Candles or Units —

               First 6 days  of testing:           Test Water 1 (General)
               Last 4-1/2 days of testing:        Test Water 3 (Challenge)
                                     0-16

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     3.   Ultraviolet  (U.V.) Units —

          First 6 days of testing:
          Last 4-1/2 days of testing:

h.   Analyses and monitoring:
Test Water 1 (General)
Test Water 4 (Challenge)
     1.   Microbiological sampling and analysis shall be conducted of the
          specified  influent and  effluent sampling  points during  each
          indicated sampling period.

     2.   Test Water Monitoring:  The specified parameters of the various
          test waters  (see Section  3.3) will  be  measured and recorded at
          each microbiological  sampling  point; the  specified  parameters
          will be  measured at least  once  on non-sampling days  when the
          units are being operated.

     3.   Background chemical  analyses of  influent  water shall  be  con-
          ducted  at least  once at the  start of  each  test  period  to
          determine the  concentration of the U.S. EPA  primary inorganic
          contaminants,  secondary  contaminants  and  routine water  para-
          meters, not otherwise covered in the described test waters.

     4.   In addition, quality  assurance testing shall  be  conducted for
          the seed  bacteria  under  environmental conditions  on the  first
          and last days of testing to make sure that there is no signifi-
          cant change  over the test  day.   Populations will be  measured
          (for example, as dispersed in the supply tank) at the beginning
          and end of the test day to detect  possible  incidental effects
          such as  proliferation,  die-off,  adsorption  to surfaces,  etc.
          Relatively stable  bacterial seed populations  are  essential to
          an acceptable test program.

     5.   When a  unit contains  a  halogen or silver,  the  active  agent
          residual will be measured in the effluent at each microbiologi-
          cal test  (sampling) point.

     6.   Silver will additionally be measured three times  in  the efflu-
          ent as specified in Section 3.5.I.e.

     Neutralization of Disinfection  Activity:   Immediately  after  col-
     lection, each  test sample must  be  treated to neutralize  residual
     disinfectant.  For halogen- and  silver-based  disinfectants  this may
     be  done  by   addition   of thioglycollate-thiosulfate  neutralizer
     solution (Chambers,  et al., J. Amer. Water Works Assoc., 54:208-216,
     1962).   This  solution  should  be prepared  daily.   All results are
     invalid unless samples are neutralized immediately upon collection.
                                0-17

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j=   Special Provisions for Ceramic Candles or Units:

     1.   Provisions  for slow  flow:   Ceramic  units may  be  subject  to
          clogging  and  greatly reduced  flow over  the  test  period.   An
          attempt  should  be  made to maintain  manufacturer rated  or
          claimed  flow  rates,  but even  at reduced  flows the  sampling
          program set forth in Section 3.5.1.d.2 shall be maintained.

     2.   Cleaning  of ceramic  units:   Units should be  cleaned according
          to  manufacturer's  directions.   Two  cleanings  should  occur
          during  the period  of  test  (in  order  to prove   the  unit's
          durability through the cleaning  procedure).  However,  near the
          time  of  microbiological  sampling,  the  units  should  not  be
          cleaned until  after  the sampling.  Further,  no anti-microbial
          chemical  (for  cleaning or  sanitizing)  may be applied to  the
          units during the  test period unless  the manufacturer specifies
          the same as part of routine maintenance.

k.   Halogenated units or U.V.  units with mechanical  filtration processes
     separate from the microbiological disinfection components shall have
     the  mechanical  filtration components replaced or  serviced  when
     significant flow reduction (clogging)  occurs in  accordance with the
     manufacturer's instructions in order to maintain the test flow rate.
     Units with  non-removable  mechanical  filtration  components will  be
     run  until  flow  is  below  that considered  acceptable for  consumer
     convenience.   (If  premature  clogging  presents  a  problem,   some
     specialized units may require a customized test plan.)

1.   Special Provisions for Ultraviolet (U.V.)  Units:

     1.   The units will be  adequately challenged by  the prescribed test
          watersi consequently they will  be operated at  normal intensity.
          However,  where the  U«V0  treatment  component  is preceded  by
          activated carbon treatment,  the  output  of  the U.V.  lamp  shall
          be adjusted electronically, such  as by  reducing  the current  to
          the lamp or other appropriate means,  to be just above the alarm
          point.  This option shall be available for use under other U.V.
          configurations, at the  choice  of the persons responsible  for
          testing,  as an alternative  to the use  of  the U.V.  absorbent,
          p-hydroxybenzoic acid.

     2.   Fail/safe:  Units will provide  and will be tested for fail/safe
          warnings  in  the event of water  quality  changes or equipment
          failures which may interfere with its microbiological purifica-
          tion function.

     3.   Cleaning:   Manufacturer's guidance  with respect to  cleaning
          will be followed.
                                0-18

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     3.5.2   Procedure;   Non-Plumbed Units

     a.   General:   The basic procedures given in Section 3.5.1 shall be used
         with necessary adaptations to allow  for  the specific design of the
         unit.   In  any event, the  testing procedures shall  provide a test
         challenge equivalent to  those for plumbed-in units.

     b.   Test conditions and apparatus should be adapted to reflect  proposed
         or  actual  use  conditions in  consultation with  the manufacturer,
         including flow rate  and  number  of people to be served per  day.  In
         some cases  variable flow  or other  non-standard  conditions may be
         necessary to reflect a worst-case test.

     3.5.3   Acceptance and Records

     3.5.3.1
     To qualify  as  a microbiological  water purifier,  all three  production

units of a  type must continuously meet or exceed the reduction  requirements of

Table 1, within allowable measurement tolerances for not more than ten percent

of influent/effluent sample pairs, defined as follows:


          Virus:         one order of magnitude
          Bacteria:      one order of magnitude
          Cysts:         one/half order of magnitude

     The geometric mean of  all microbiological reductions must meet or exceed

the  requirements of Table 1.  An example is given as  follows:


        -  Unit:  iodinated  resin.

        -  Number of  sample  pairs over  the  completed  test program:
          10  per unit  — 3  units « 30.

        -  Number  of allowable  sample pairs where log  reduction  is insuffi-
          cient:   10%  of 30 = 3 sample pairs.

        -  Allowable  minimum log reductions in  these  3 pairs:

               Bacteria  -   5 log
               Virus     -   3 log
               Cyst      -   2-1/2 log

        -  Conclusion:    If  the  geometric  mean of   all  reductions  meets   or
          exceeds  the  requirements  of  Table 1,  the  indicated  insufficient
          sample pairs will be allowed.
                                      0-19

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     3.5.3.2  Records
     All pertinent procedures and data  shall  be recorded in a standard format
and  retained  for possible review until the  report  of results has  been com-
pletely accepted by review authorities, in no case for less than a year.
     3.5.3.3  Scaling Up or Down
     Where  a  manufacturer  has  several similar  units using  the same  basic
technology  and  parallel  construction  and  operation,  it may  sometimes  be
appropriate to allow  the  test of one unit to be considered representative of
others.   Where any  serious doubt  exists,  all  units of  various  sizes  may
require testing.   A  "rule  of three"  is  suggested  as a matter  of  judgment.
Scaling up to three times larger or on-third, based  on the size  of either the
test unit or of its operative element, may be allowed.  However,  for UV units,
any  size  scale-up must be  accompanied by a parallel increase  in  radiation
dose.
     3.5.3.4
     Where silver or  some other  chemical  is  used in the unit, concentrations
in the effluent  water must  meet any  National Primary Drinking Water  Maximum
Contaminant Level (MCL), additional Federal guidelines,  or otherwise must not
constitute a threat to health where  no MCL exists.
                                     O-20

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                                 APPENDIX O-l

           SUMMARY FOR BASIS OF STANDARDS AND TEST WATER PARAMETERS


A-   Microbiological Reduction Requirements

     1.   Bacteria

               Current  standards  for the  microbiological  safety  of  drinking
          water  are based  on  the  presence  of  colifonn bacteria  of  which
          Klebsiella is  a member.   Members of  the genus Klebsiella  are also
          potential pathogens of man (Vlassof, 1977).  Klebsiella terrigena is
          designated  as  the  test  organism  since it  is commonly  found  in
          surface waters  (Izard, et al., 1981).

               Experience with  the use of  colifonn bacteria to  estimate  the
          presence of  enteric bacterial pathogens in drinking water as per-
          formed over the last  75 years indicates a high degree  of  reliabil-
          ity.  Required  testing  of more than one bacterial  pathogen appears
          unjustified  since  viral  and Giardia   testing  will  be  required.
          Enteric viruses and Giardia are known to be more resistant to common
          disinfectants than enteric bacterial pathogens and  viruses  are more
          resistant  to  removal by  treatments such  as filtration. Thus,  any
          treatment which would give a  good removal  of both virus and Giardia
          pathogens  would most likely  reduce enteric bacteria below  levels
          considered infectious (Jarroll, et al.,  1981; Liu,  et al.,  1971).

               The concentration of coliform bacteria in raw  sewage is approx-
          imately 10 /100 ml.   Concentrations in polluted stream  waters have
          been found to exceed 10  per 100 ml (Gulp, et al.,  1978, Table 10).

               Based on the over  10  /100 ml concentrations observed  in  highly
          polluted stream water and a  target effluent concentration of less
          than 1/100 ml, a 6 log reduction is recommended.

     2.   Virus

               In the United States  concentrations of  enteroviruses  are esti-
          mated to range from 10  -10 /liter in raw sewage  (Farrah and Schaub,
          1971).   Based on  this  observation it  is  estimated  that,  natural
          waters  contaminated  with  raw sewage may  contain   from  10   to  10
          enteric viruses per liter.

               There are currently no standards for viruses  in drinking water
          in the United States.   However,  EPA has proposed  a non-enforceable
          health-based recommended  maximum contaminant  level (RMCL) of zero
          for viruses (EPA,  1985).  Several individuals and organizations have
          developed guidelines  for  the  presence of viruses in drinking water
          and various experts have proposed standards  (WHO, 1979,  1984; Berg,
          1971;  Melnick,   1976).    It   has  generally   been   felt   that
                                     0-21

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     drinking water  should be  free  of infectious  virus since  even one
     virus is potentially infectious and  suggested  standards are largely
     based on technological limits of  our detection methodology„  Guide-
     lines suggested by  the World Health Organization  (1984)  and others
     recommend that  volumes  to be  tested be  in the order  of 100-1,000
     liters and that viruses be absent in these volumes.

          Assuming a target effluent level of  less  than one virus in 100
     liters of water  and a concentration of  10  enteric viruses  in 100
     liters  of  sewage-contaminated  waters,   the  water  purifier  units
     should achieve at least 4 logs of virus removal.

          The relative  resistance of  enteric  viruses to different dis-
     infectants varies greatly  among  the  enteric viruses and  even among
     members of the same group (i.e.,  enteroviruses).  For example, while
     f2 coliphage is one of the most resistant viruses to inactivation by
     chlorine it is one of the  most susceptible to  inactivation by ozone
     (Harakeh and Butler, 1984).  Ionic conditions and pH can also affect
     the  relative resistance  of  different  viruses to  a  disinfectant
     (Engelbrecht, et al., 1980).  On  this  basis  it  is felt  that more
     than one enteric  virus  should be  tested to ensure the efficacy of
     any disinfection system.   Poliovirus type 1  (Strain LSc)  was chosen
     as one of the  test viruses because it has been  extensively used in
     disinfection and  environmental  studies  as representative  of  the
     enterovirus  family.   It  is  recognized  that  it  is   not the  most
     resistant virus to inactivation by chlorine, but is still resistant
     enough to serve as a useful indicator.   Rotavirus is selected as the
     second test enteric  virus  since  it  represents  another group  of
     enteric viruses in nucleic acid composition and  size.   It is also a
     major cause  of  viral gastroenteritis and has  been documented  as  a
     cause of  water borne  gastroenteritis  (Gerba,  et al., 1985).   The
     human rotavirus or the similar Simian  rotavirus may be used  in the
     test procedure.   A net  4-log reduction  for  a  joint  challenge  of
     1 x 10 /L each for poliovirus and rotavirus is  recommended.

3.   Cysts (Protozoan)

          Over the past  several years, giardiasis  has  consistently been
     one of the most frequently reported  waterborne diseases transmitted
     by drinking water  in the  United States  (Craun,   1984).  EPA  has
     proposed a RMCL of zero for Giardia (EPA, 1985).  Its  occurrence has
     generally been associated  with  treatment  deficiencies  including
     either inadequate or  no  filtration.   Giardiasis has not  been known
     to occur  from  drinking water produced  by  well-operated  filtration
     treatment plants.   De Walle,  et al. (1984), in  a study of  filtration
     treatment plant efficiencies, cited percent removals for  Giardia in
     pilot plant tests as follows:

       -  Rapid filtration with coagulation-sedimentation:   96.6-99.9%?

       -  Direct filtration with coagulation:  95.9-99.9%.
                                0-22

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               From  this  research and  from  the lack  of  Giardia  cases  in
          systems where  adequate  filtration  exists,  a 3-log (99.9%)  reduction
          requirement  is  considered  to be  conservative  and to  provide  a
          comparable   level  of   protection   for   water   purifiers   to   a
          well-operated  filtration treatment plant.

               Data  on environmental  levels  for cysts  in natural waters  is
          limited  because  of  the  difficulties of sampling  and  analysis.
          Unpublished data indicate very low levels from less than 1/L to less
          than 10/L.  Here a 3-log reduction would provide an effluent of less
          than 1/100 L,  comparable to the recommended virus reduction require-
          ments .

               Either Giardia lamblia  or the  related organism,  Giardia muris,
          which is reported to  be a  satisfactory test organism (Hoff,  et al.,
          1985) , may be  used as  the  challenge  organism.   Tests will  be  con-
          ducted with  a  challenge of  10   organisms  per  liter  for  a  3-log
          reduction.

               Where the treatment unit or component for cysts is based on the
          principle of occlusion  filtration  alone, testing for  a  3-log reduc-
          tion of 4-6 micron particles or spheres (National Sanitation Founda-
          tion Standard 53, as an example)  is acceptable.  Difficulties in the
          cyst  production  and  measurement  technologies  by  lesser-equipped
          laboratories may require the  use  of  such alternative tests  where
          applicable.

B.   Microbiological Purifier Test Procedures

     1.   Test Waters

          a.   The general test  water  (test  water  #1)  is  designed  for  the
               normal,  non-stressed phase of testing with characteristics that
               may easily be obtained  by the  adjustment  of many public system
               tap waters.

          b.   Test water  #2  is  intended  for the stressed phase of  testing
               where units involve halogen disinfectants.

               1.   Since  the  disinfection  activity of  some halogens  falls
                    with a rising pH,  it  is important  to stress test at  an
                    elevated pH.   The recommended level of  9.0  * 0.2,  while
                    exceeding the recommended secondary  level  (Environmental
                    Protection Agency, 1984)  is still within a range  seen  in
                    some  natural  waters  (Environmental  Protection  Agency,
                    1976).  However, for iodine-based units,  a second stress-
                    ful  condition is  provided  —  a  pH  of 5.0 * 0.2  since
                    current  information  indicates   that   the   disinfection
                    activity of iodine falls with a  low pH (National Research
                    Council, 1980).  While  beneath  the  recommended  secondary
                                     0-23

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          level (Environmental Protection Agency,  1984)  a pH of 5.0
          is not unusual in natural waters (Environmental Protection
          Agency, 1976).

     2o   Organic matter as  total organic carbon  (TOC)  is known to
          interfere with halogen disinfection.   While this  TOC is
          higher than levels  in  many natural waters, the designated
          concentration of  10 mg/L  is cited  as typical  in stream
          waters (Culp/Wesner/Culp, 1978).

     3.   High concentrations of turbidity can shield microorganisms
          and  interfere with disinfection.   While  the  recommended
          level of not less than 30  NTU is in the range of turbidi-
          ties seen in secondary wastewater effluents, this level is
          also  found  in  many   surface  waters,  especially  during
          periods of heavy rainfall and snow melt (Culp/Wesner/Culp,
          1978).

     4.   Studies with  Giardia  cysts have shown decreasing halogen
          disinfection  activity  with  lower   temperatures  (Jarroll,
          et al.,  1980);  4  C,   a common  low  temperature in  many
          natural waters,  is recommended for the stress test.

     5.   The  amount  of  dissolved   solids   (TDS)  may  impact  the
          disinfection effectiveness of units that rely on displace-
          able or exchange  elements  by displacement  of  halogens or
          resins,  or  it may  interfere with  adsorptive  processes.
          While TDS  levels  of 10,000 mg/L are  considered unusable
          for drinking, many supplies with over  2,000 mg/L are used
          for  potable  purposes   (Environmental  Protection  Agency,
          1984).  The recommended  level  of 1,500 mg/L represents a
          realistic stress  challenge.

c.   Test water #3 is intended for the stressed  phase of testing of
     ceramic  filtration candles  or  units  with  or  without  silver
     impregnation.

     1.   Since viruses are typically eluted  from adsorbing media at
          high pHs (Environmental Protection  Agency, 1978) it may be
          concluded that a  high  pH will provide  the most stressful
          testing for  a ceramic-type unit;  consequently,  the  high
          natural water pH  of 9.0 is recommended.

     2.   Expert  opinion  also   holds that  organic  material  will
          interfere with adsorption  of viruses.   Thus, a high total
          organic carbon level  of not less  than 10  mg/L  is recom-
          mended.

     3.   Turbidity  may  enhance  the  entrapment  and  removal  of
          microorganisms  but   it   also  may  stimulate   "short-
          circuiting"  through some  units.   A  turbidity  level  of
                           0-24

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               30 NTU  will provide  stress  at time  of sampling  but the
               non-sampling  level  of 0.1-5  NTU will allow routine opera-
               tion of units.

          4.   Expert  opinion  holds  that low water temperatures and high
               TDS would most  likely  interfere  with virus  reduction by
               adsorption; consequently, a 4 C temperature and 1,500 mg/L
               TDS are recommended.

     d.   Test water #4  is intended  for the stressed phase of testing for
          ultraviolet  (UV) units.

          1.   In general,  high TOC, turbidity  and  TDS  and low tempera-
               ture  are  considered  most stressful  for  UV, and  the in-
               dicated   challenge  levels   are  the  same  as  for  test
               water #2.

          2.   The pH is not critical and may range from 6.5 to 8.5.

          3.   In order  to  test  the UV units at their  most vulnerable
               stage of operation, a color challenge  (light absorption at
               254 nm)  is  to  be  maintained  at a  level  where UV light
               intensity is  just  above the unit's  low intensity  warning
               alarm  point.   However,   an  alternate  to  the  absorption
               challenge is provided through adjusting the light intensi-
               ty  output  of  the UV lamp  electronically  by  reducing
               current to  the  lamp,  or other  appropriate  means,  to be
               just  above  the  alarm  point;  this  approach  would  be
               particularly  necessary where the  UV lamp is  preceded by
               activated carbon treatment.

     e.   Test water #5  is intended  for the stressed leaching tests of
          units containing  silver.  Low  pH, TOC, turbidity,  and  TDS and
          higher temperature are  felt to be  the characteristics  associ-
          ated  with  increased  leachability.   The  recommended  pH  of
          5.0 * .2, while  being beneath the  recommended  secondary range
          of  6.5-8.5   (Environmental  Protection  Agency,  1984)  is  still
          found in some natural waters.

2.   Test Procedures

          The plan for testing and  sampling  is designed to  reveal unit
     performance under both "normal" and "stressed" operating conditions.
     The stressed phase  would  utilize a set of  water quality and opera-
     tions conditions to give the units a realistic worst case challenge.
     Testing plans for a  specific model might  involve  modifications to
     the recommended plan;  more samples could be taken and analyzed; more
     units  could  be studied.   The  principle  of  demonstrating  adequate
     performance even  under realistic  worst  case conditions  should be
     maintained and the  final  selected  test procedures  should  be agreed
     as between investigators and reviewers or regulators.
                                0-25

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     While some aspects of the testing procedures have been utilized
in actual experiments,  the proposed protocol has  not been verified
or utilized  for  the various units  that may be  considered.   Conse-
quently, investigators  and users of this protocol  may find reasons
to alter  some aspects  through  their  practical experience;  needed
changes should be discussed and cleared with  involved reviewers/-
regulators .
                           0-26

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REFERENCES;

Berg, G.   Integrated approach to  the  problem of viruses in water.   J.  ASCE,
Sanit. Eng. Div. 97:867-882, 1971.

Culp/Wesner/Culp.  Guidance  for  planning the location of water supply intakes
downstream from municipal wastewater .treatment facilities.  EPA Report, Office
of Drinking Water.  Washington,  DC, 1978.

Craun, G. F.  1984.  Waterbome  outbreaks of giardiasis:  Current status.  In:
Giardia and  giardiasis.  D. L. Erlandsen and E. A. Meyer Eds.,  Plenum Press,
New York, pp. 243-261,  1984.

DeWalle, F.  B.;  J. Engeset;  Lawrence,  W.  Removal of Giardia  lamblia cyst by
drinking  water  treatment  plants.   Report  No.  EPA-600/52-84-069,  Office  of
Research and Development, Cincinnati, OH, 1984.

Engelbrecht, R. S. , et  al.   Comparative inactivation of viruses  by  chlorine.
Appl. Environ. Microbiol.  40:249-256, 1980.

Environmental Protection Agency.  Quality criteria for water.  Washington, DC,
1976.

Environmental   Protection   Agency.     National   secondary   drinking   water
regulations.  EPA-570/9-76-000, Washington, DC, 1984.

Environmental Protection Agency.  National primary drinking water regulations;
synthetic organic  chemicals,  inorganic  chemicals and microorganisms;  Proposed
rule.  Federal Register, Nov. 13, 1985.

Farrah,  S. R., and S.  A. Schaub.  Viruses in wastewater sludges.   In:  Viral
Pollution of  the Environment, G. Berg,  Ed.   CRC Press, Boca  Raton,  Florida.
pp. 161-163, 1983.

Gerba, C. P.; Rose, J.  B.; Singh,  S. N.   Waterbome  gastroenteritis  and  viral
hepatitis.  CRC Critical Rev. Environ. Contr.  15:213-236, 1985.

Harakeh, M.;  Butler, M.   Inactivation  of  human rotavirus,  SA-11 and  other
enteric viruses in effluent by disinfectants.  J. Hyg. Camb. 93:157-163,  1984.

Hoff, J. C.;  Rice, E.  W.; Schaefer, F.  W.   Comparison  of  animal infectivity
and excystation  as measures of  Giardia muris cyst  inactivation  by  chlorine.
Appl. Environ. Microbiol.  50:1115-1117, 1985.

Izard, D.;  Farragut,  C.;Gavini, F.;  Kersters,  K.;  DeLey. J.;  Leclerc,  H.
Klebsiella terrigena, a new  species from water and  soil.  Intl.  J.  Systematic
Bacteriol.  31:116-127,  1981.
                                     0-27

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Jakubowski, W.  Detection  of Giardia cysts  in drinking water.   In:   Giardia
and  Giardiasis,  Erlandsen,  S.  L.;  Meyer,  E.  A.  Eds.,   Plenum Press,  NY.
pp. 263-286, 1984.

Jarroll, E. L.;  Bingham,   A.  K0;  Meyer,  E,  A.   Giardia  cyst  destructions
Effectiveness of six small-quantity water  disinfection methods.   Am.  J. Trop.
Med.  29:8-11, 1980

Jarroll, E. L,,; Bingham, A.  K.; Meyer,  E.  A.   Effect of chlorine  on Giardia
cyst viability.  Appl.  Environ. Microbiol.   43:483-487, 1981.

Liu, O. C.,  et al.   Relative resistance of  20 human  enteric viruses to free
chlorine in Potomac River water.  Proceedings of 13th Water Quality Conference
Snoeyink, V.; Griffin,  V.  Eds., pp. 171-195, 1971.

Melnick, J. L.   Viruses   in  water.     In:    Viruses  in  Hater   Berg,  G.;
Bodily, H. L.; Lennette,  E.  H.; Melnick,  J. L.;  Metclaf T.  G., Eds.   Amer.
Public Hlth. Assoc., Washington, DE,  pp. 3-11, 1976.

National Research Council.  The disinfection of drinking water,  In:  Drinking
Water and Health, Volume 2.  Washington, DC, pp. 5-137, 1980.

National  Sanitation Foundation.   Drinking  water  treatment  units:    Health
effects.  Standard  53.   Ann Arbor,  MI,  1982.

Vlassoff, L. T.   Klebsiella.    In:     Bacterial   Indicators/Health   Hazards
Associated with Water Hoadley,  A. W.;  Dutka,  B. J., Eds.  American Society for
Testing and Materials,  Philadelphia,  PA. pp. 275-288, 1977.

World  Health  Organization.   Human  Viruses   in Water,   Technical   Support
Series 639, World Health Organization,  Geneva, 1979.

World Health Organization.  Guidelines  for Drinking  Water Quality.  Volume 1.
Recommendations.  World Health Organization,  Geneva,  1984.
                                     0-28

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                                 APPENDIX O-2

     LIST OF PARTICIPANTS;  TASK FORCE ON GUIDE STANDARD AND PROTOCOL FOR
                    TESTING MICROBIOLOGICAL WATER PURIFIERS


Stephen A. Schaub, Chairman — U.S. Army Medical Bioengineering Research and
     Development  Laboratory  (USAMBRDL),  Fort Detrick,  Maryland 21701,  FTS:
     8/935-7207 — Comm:  301/663-7207.

Frank A. Bell, Jr., Secretary — Criteria and Standards Division,  Office of
     Drinking  Water  (WH-550),  Environmental  Protection Agency,  Washington,
     D.C. 20460, Phone:  202/382-3037.

Paul Berger, Ph.D. — Criteria and Standards Division, Office of Drinking
     Water  (WH-550), Environmental Protection Agency,  Washington,  D.C.  20460,
     Phone:  202/382-3039.

Art Castillo — Disinfectants Branch, Office of Pesticide Programs (TS-767CO,
     Environmental Protection Agency, Washington, D.C. 20460, Phone:   703/557-
     3695.

Ruth Douglas — Disinfectants Branch, Office of Pesticide Programs (TS-767C),
     Environmental Protection Agency, Washington, D.C. 20460, Phone:   703/557-
     3675.

Al Dufour — Microbiology Branch, Health Effects Research Laboratory/
     Environmental Protection Agency, 26 W. St. Clair Street, Cincinnati, Ohio
     45268, Phone:  FTS:  8/684-7870 — Comm:  513/569-7870.

Ed Geldreich — Chief, Microbiological Treatment Branch, Water Engineering
     Research  Laboratory,  Environmental  Protection  Agency,  26  W.  St.  Clair
     Street,  Cincinnati,  Ohio  45268,  Phone:   FTS:   8/684-7232  --  Comm:
     513/569-7232.

Charles Gerba — Associate Professor, Department of Microbiology and
     Immunology,  University   of  Arizona,   Tucson,   Arizona  85721,   Phone:
     602/621-6906.

John Hoff — Microbiological Treatment Branch, Water Engineering Research
     Laboratory,  Environmental Protection  Agency*  26 W.  St. Clair  Street,
     Cincinnati, Ohio 45268, Phone:  FTS:  8/684-7331 — Comm:  513/569-7331.

Art Kaplan — Office of Research and Development  (RD-681) Environmental
     Protection Agency, Washington, D.C. 20460, Phone:  202/382-2583.

Bala Krishnan  — Office  of Research  and Development  (RD-681)  Environmental
     Protection Agency, Washington D.C. 20460, Phone:  202/382-2583.
                                     0-29

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John Lee — Disinfectants Branch, Office of Pesticide Programs (TS-767C)
     Environmental   Protection  Agency,   Washington,  D.C.   20460,   Phone;
     703/557-3663.

Dorothy Portner -- Disinfectants Branch, Office of Pesticide Programs
     (TS-767-C),  Environmental  Protection Agency,  Washington,  D.C.  20460,
     Phone:  703/557-0484.

Don Reasoner — Microbiological Treatment Branch, Water Engineering Research
     Laboratory,  Environmental Protection  Agency,  26  W.  St.  Clair  Street,
     Cincinnati, Ohio 45268, Phones   312/654-4000.

P. Reguanthan  (Regu)  ~ Everpure, Inc., 660 N.  Blackhawk Drive,  Westmont,
     Illinois 60559,  Phone:   312/654-4000.

David Stangel — Policy and Analysis Branch, Office of Compliance Monitoring,
     Environmental Protection Agency, Washington, D.C., Phone:  202/382-7845.

Richard Tobin ~ Monitoring and Criteria Division, Environmental Health
     Center, Department  of Health  and Welfare  of  Canada, Tunney's  Pasture,
     Ottawa, Ontario, K1A OL2, Canada, Phone:   613/990-8982.
                                     0-30

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                                 APPENDIX 0-3

    RESPONSE BY REVIEW SUBCOMMITTEE(1) TO PUBLIC COMMENTS ON GUIDE STANDARD
           AND PROTOCOL FOR TESTING MICROBIOLOGICAL WATER PURIFIERS


A.   Recommendation for the use of Giardia lamblia cysts as a replacement for
     Giardia muris cysts as the protozoan cyst test organisms.

Recommendation;

     The subcommittee concurs with the recommendation and further endorses the
     use of  Giardia  lamblia as the preferred cyst  test  for evaluation of all
     treatment units  and devices.  Obviously the use of the protozoan orga-
     nisms  of actual  health  concern  in testing  is most  desirable.   Anyone
     finding  the  Giardia  lamblia  strain  feasible for   testing  and  cost-
     effective  to work  with  is  encouraged to  use  same  instead of  Giardia
     muris.

B.   Substitution of 4-6 micron bead or particle tests  as an alternate option
     instead of the Giardia cysts for evaluating devices that rely strictly on
     occlusion  filtration  for  microbiological  removal:   Several  commenters
     criticized  the  use  of beads  or particles  (e.g.,  A.C.  fine dust)  and
     recommended only use of live Giardia cysts for performance tests.

Discussion;

     The  subcommittee recognizes  and  favors  the  use   of  the natural  human
     parasite, Giardia lamblia, but was not aware of any convincing scientific
     data  which would  disallow the  optional use  of testing with beads  or
     particles for units or devices using only  occlusion filtration to remove
     microorganisms.  Previous development of the National Sanitation Standard
     (NSF)  53  (1982)  requirement for cyst reduction (using 4-6 micron parti-
     cles  as  cyst models)  was based on engineering and scientific opinion and
     experimental  evidence  at  that  time.   Specifically,  Logsdon     used
     radioactive  cyst models   in  the  initial  phase of a study of  removal
     efficiencies for  diatomaceous earth filters? subsequent experiments with
     Giardia  muris cysts  confirmed  the  efficacy  of the  diatomaceous  earth
     filters.   Further studies  by Hendricks     and DeWalle     with  Giardia
     lamblia   cysts   also  showed  comparable   reduction   efficiencies  for
     diatomaceous earth filters.
     l.S.A. Schaub;     F.A.  Bell,  Jr.;     P. Berger;     C. Gerba;    J. Hoff;
     P. Regunathan;  and R. Tobin.   [Includes  additional  revision pursuant to
     Scientific  Advisory  Panel  review  (Federal  Insecticide,  Fungicide,  and
     Rodenticide Act).]
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     Subsequently confirmatory  parallel testing  results have  been developed
     vis-a-vis 4-6  micron  particles  as  compared to  Giardia  lamblia  cysts.
     Specifically,  two. nnits  listed  by  NSF  for cyst  reduction  (using  4-6
     micron particles)     have also been tested and listed for 100% efficiency
     reduction (using Giardia lamblia cysts) by Hibler   :

          1.   Everpure Model QC4-SC
          2.   Royal Boulton Model F303.

     Again we prefer the use of the human  pathogen,  Giardia lamblia;  however,
     no experimental data has been provided regarding  the lack of validity or
     of failure in previous tests utilizing beads or particles of 4-6 microns.
     In most cases the bacterial or viral  challenges to occlusion filters ill
     represent  a  greater  problem  in  terms  of  microbiological  reduction
     requirements  than  will cysts.   Therefore,  without  substantiation  of
     deficiencies, the use  of 4-6  micron beads or particles  is considered to
     be as  feasible  as  the use of live cysts  for routine performance testing
     of water filtration (occlusion)  devices.

Recommendation;

     Recommend retaining the optional  use of 4-6 micron particles or beads for
     cyst reduction testing in occlusion filtration devices only.

References;

          Logsdon, G. S.,  et al.   Alternative Filtration Methods  for Removal
          of Giardia Cysts and Cyst Models, JAWWA, 73(2)111-118, 1981.

          Logsdon, G. S.;  Hendricks,  D.  W., et al.  Control  of Giardia Cysts
          by Filtration;  The Laboratory's  Rose.   Presented at the AWWA Water
          Quality Technology Conference, December, 1983.

          DeWalle, et al.  Removal of Giardia  lamblia  Cysts by Drinking Water
          Treatment  Plants,  Grant No. R806127,  Report  to  Drinking  Water
          Research Division, U.S.  EPA  (ORD/MERL), Cincinnati,  Ohio.
     (4)
          National Sanitation Foundation,  Listing  of Drinking Water Treatment
          Units,  Standard 53.  May, 1986.

          Hibler, C. P.  An  Evaluation  of  Filters  in  the Removal  of Giardia
          lamblia.  Water Technology,  pp. 34-36.   July, 1984.

C.   Alternate assay techniques for cyst tests (Jensen):  Proposed alterations
     in cyst tests include a different method  for separating  cysts from fecal
     material and an assay method involving the counting of  trophozoites as
     well as intact cysts.  Both alterations have been used by Bingham,  et al.
     (Exp. Parasitol.,  47:284-291, 1979).
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Recommendation;

     These alterations appear to be reasonable laboratory procedures, support-
     ed  by a  peer-reviewed article  and will  be included  in the  Report as
     options for possible development and use by  interested laboratories.

D.   The  use  of pour plate techniques as an option  for Klebsiella terrigena
     bacteria analyses.

Recommendation;

     The pour plate  technique adds  a  heat stress factor to the bacteria which
     constitutes a possible deficiency.   However, it is a recognized standard
     method and probably will not adversely affect  the Klebsiella terrigena.
     Consequently, it will be  added  to the Report  as one  of the acceptable
     techniques.

E.   Option of  using Escherichia  coli in lieu  of Klebsiella terrigena for the
     bacterial  tests.

Discussion;

     Appendix O-l, Section  A.I. of  the Guide Standard and Protocol sets forth
     the  basis  for  selection  of  K.  terrigena  as   the  test  bacteria.   The
     selection  was made  along pragmatic line emphasizing the occurrence of K.
     terrigena  in surface  waters  and that  it  would  represent  the  enteric
     bacteria.  It was also pointed out that the tests with virus and Giardia
     were expected to be more severe than the bacterial tests.  For comprehen-
     siveness,  bacterial tests were included in the protocol but were not felt
     to be as crucial as the virus and Giardia tests.

     E.  coli,  or any number  of other generally  accepted  indicator bacteria,
     could  be  used  for the  test  program  if  they  were  shown to  have  good
     testing and survival characteristics  (equivalent to K.  terrigena)  by the
     interested research laboratory.

Recommendation:

     The  intent of  the Guide Standard  and Protocol  is  to provide a baseline
     program subject  to  modification  when properly supported by an interested
     laboratory.  Consequently,  any laboratory could propose  and with proper
     support  (demonstrating challenge and  test equivalency to  K. terrigena)
     use  Escherichia coli  or one of  the  other  enteric bacteria.   This  idea
     will be included in revised working in Section 1.2.2, "General Guide."

F.   Performance requirements for Giardia cysts  and  virus in  relation to the
     EPA-Recommended Maximum Contamination Levels  (RMCLs) of zero.

Discussion;

     The RMCLs  of zero for Giardia and viruses which  have been proposed by EPA
     are health goals.   They are  no enforceable standards since to assure the
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     presence  of  "no  organisms"  would require  an  infinite  sample.   The
     rationale for the recommended performance  requirements for Giardia cysts
     and virus is  set forth in Sections A.2  and A. 3 of Appendix fc.C /We feel
     that these requirements together with the  application of realistic worst
     case test conditions will provide a conservative test for units resulting
     in treated  effluent water equivalent to that of  a public water  supply
     meeting  the iricrobiological  requirements  and  intent  of the  National
     Primary Drinking Water Regulations.

Recommendation;

     Retain recommended performance  (log reduction) requirements  for cyst and
     virus reduction.

G.   Rotavirus and  its  proposed assay:  One  commenter states  that  the rota-
     virus tests are impractical  because Amirtharajah  (J. AWWA,  78 (3):34-49,
     1976)  cites "no satisfactory  culture procedures available for analysis of
     these pathogens and, therefore,  monitoring would not be feasible."

Discussion;

     Section 3.4.1.2, "Virus  Tests"  of  the  Report,  presents means  for cul-
     turing  and  assaying  rotaviruses.   This means  for  doing the  rotavirus
     tests are available and are practical for  application in the laboratory.
     Dr. Amirtharajah was referring to the field collection, identification in
     the presence of  a  wide variety of  microorganisms,  and quantification as
     not being "satisfactory."  Laboratory analysis of  rotaviruses  is practi-
     cal but their field monitoring may not yet be feasible.

     Further, the selection of  both  poliovirus and rotavirus as  test viruses
     was necessitated by the  fact  that  the surface adsorptive properties and
     disinfection resistance of the various enteric viruses have been shown to
     differ significantly by virus group and by strains of a specific  virus.
     While all  enteric  viruses and  their strains could not  be  economically
     tested, it was determined by the task force that at least two distinctly
     different virus types  should be  tested  to achieve  some  idea of  the
     diversity of removal by the various types  of  water purifiers.   Polio and
     rota  viruses  have  distinctly different  physical  and  chemical  charac-
     teristics representative  of  the  viruses  of  concern.   Polioviruses  are
     small single stranded RNA viruses with generally  good adsorptive proper-
     ties  to  surfaces and  filter  media while  rotaviruses are over  twice as
     large, are  double  stranded RNA and in  some  studies  have been  found to
     possess  less  potential  for  adsorption  onto surfaces  or filter  media.
     These two viruses also have been demonstrated to have somewhat different
     disinfection kinetics.

Recommendation;

     Retain the rotavirus test requirements.

H.   Definition  of  microbiological  water  purifier:   One  general  comment
     requested redefinition based  on "lack of  any virus  removal  "requirement
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     in the EPA primary drinking water regulations, so that no virus reduction
     requirement should be included.  Also, it was claimed that the separation
     of purifiers  from non-purifiers would be a  "disservice  to consumers and
     other users."

Discussion;

     Viruses are recognized in the EPA regulations vis-a-vis a proposed recom-
     mended maximum contaminant  level  of zero.   Since virus  monitoring for
     compliance with a possible MCL  is  not yet feasible,  a treatment require-
     ment is necessary.  Virus control will be considered in the Safe Drinking
     Water Act filtration  and  disinfection treatment  regulations.   The reduc-
     tion  of  viruses  by  treatment  is  discussed by  Amirtharajah  (J.  AWWA,
     78:3:34-49, 1986).

     With  respect  to  consumers  and other users,  we  feel  that  the  current
     definition is appropriate  and necessary.  The average consumer cannot be
     expected to know  the difference between viruses,  bacteria and cysts, or
     when a raw water will  or will not  contain  any  of these  organisms.  In
     order to protect  the  average consumer,  the  subject units either alone or
     with  supplementary  treatment,  should be able  to cope  with  all of the
     specified organisms.

Recommendation;

     Retain the current definition for microbiological water purifier.

I.   Coverage of units:   Several comments related to the coverage  of units.
     These questions are addressed individually as follows:

     1.   Ultraviolet units that  are used for  supplemental treatment of  water
          from public  water  system taps would not be  covered.   We agree that
          such  units  are  not  covered  and  parenthetical  language has  been
          included in Section 1.3.2.3 to clarify this point.

     2.   A special  status should be given to units which  remove  Giardia and
          bacteria but not virus.  Specifically,  the meaning of Section 1.2.4,
          "Exceptions," was  addressed.   The  "Exceptions"  section  was  specif-
          ically developed to  relate to  the  problem  of public  water  systems
          having disinfection  but no filtration  on  a  surface  supply.   Cysts
          alone have been found to survive disinfection treatment and could be
          present  in such treated waters.   In  this  case an  effective  cyst
          filter serves  an independent, beneficial purpose and  should not be
          required to  be a microbiological water purifier.  However, such a
          unit should  not  be used as sole treatment  for  untreated raw water.
          Additional parenthetical language has been added to Section 1.2.4.

     3.   The  entire  treatment unit or system should  be  tested,  not just a
          single component.   We  agree  but  believe that  it is  sufficiently
          clear without providing additional language.
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     4.   The protocol should be expanded to  cover units for the reduction of
          TCE, EDB and other chemical pollutants.   We felt that the introduc-
          tion of  non-microbiological claims  to the  standard would  make it
          large,  unwieldy and duplicative of an existing third-party standards
          and testing program (see Section I»2o5)°

J.   Alleged preference  of National  Sanitation.  Foundation  (NSF)  over  other
     laboratories  for  conducting the microbiological water purifier testing
     protocol.  The  comment indicated  that we  were  giving NSF  preferential
     treatment "to the  detriment  of other  laboratories well qualified  to
     perform the  required protocol."

Discussion;

     We have made  appropriate  references to existing  standards  (#42  and #53)
     developed by  the NSF  standards development  process.  Standard 53,  the
     health effects standard, was developed by  a broadly based Drinking Water
     Treatment Units  Committee,  including  representatives from  local,  State
     and Federal  health and environmental agencies, universities,  professional
     and   technical   associations,   as   well   as   water  quality  industry
     representatives.   It  was adopted   in  1982  and   the  only test   from  it
     utilized in our Report has  been substantiated as described  in Part B of
     this "Response."

     Nowhere in our report have we  advocated  NSF (or  any other laboratory)  as
     the prime or only laboratory for implementing "the required protocol."

Recommendation;

     No action needed.

K.   Instruction   concerning effective  lifetime,   One  comment described  an
     alternate means  for  determining   lifetime  where  a  ceramic  unit  is
     "brushed" to  renew  its utility and is gradually  reduced  in  diameter.   A
     gauge is provided to  measure diameter and to  determine when replacement
     is needed.

Recommendation;

     Where a manufacturer provides a satisfactory "other" means of determining
     lifetime, this should be accepted.  Appropriate words have been  added to
     Section 2.4.I.C.

L.   Ceramic  candles   should not   be  cleaned  during testing  because  some
     consumers would  not clean them  and this  would  provide the  "worst case
     test."  One  comment asserted this point.

Discussion;

     There is some truth to this  proposition.   However, the other approach may
     also have validity.  Frequent  brushing may reduce filtration efficiency.
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     In any  event,  where a manufacturer prescribes filter cleaning and how to
     do it,  and provides  a  gauge to determine lifetime,  we  feel the testing
     program is bound to follow  the manufacturer's directions.

Recommendation;

     No change needed.

M.   Scaling up or down.  One comment points  out  that one  or more manufac-
     turers  may  vary size of  treatment units  by  increasing or decreasing the
     number  of  operative  units  rather than the  size of  the operative  unit.
     The comment suggests  allowing scaling based on size "of operative unit.

Recommendation;

     We  agree  with  the  comment and  have added  clarifying  words to  Sec-
     tion 3.5.3.3.

N.   Turbidity level  of "not  less that 30 NTU" for ceramic candles or units.
     One comment states  that "Such levels are  impossible to utilize in testing
     mechanical  filtration devices which will clog  entirely or require such
     frequent  brushing  as  to  render the  test  impossible  as a  practical
     matter."

Discussion;

     We recognized the  potential  "clogging problems"  in Section 3.5.1.a(2)
     where  the  30  NTU   water  is only  to be  applied immediately  before and
     during  each sampling event; the non-sampling turbidity level,  which will
     be applied  over  90% of the "on"  time,  is currently set  at no less than
     10 NTU.

     Turbidity levels  of  30 NTU are  commonly  found  in  surface waters  during
     heavy rainfall or  snow  melt.   Treatment  units  may be  used under  these
     circumstances, so this challenge level  should be retained.  However, most
     usage   will  occur   under  background   conditions  so  the  non-sampling
     turbidity levels should be  0.1-5 NTU.

Recommendations;

     1.   Retain sampling  turbidity level of not less than 30 NTU, and

     2.   Change  non-sampling turbidity  to 0.1-5 NTU.    Appropriate  wording
          changes  have   been  introduced in  Section 3.5.1.a(2)  and  in  Appen-
          dix O-l, Section B.

0.   Chlorine in test water  #5.   One comment  asserts  that chlorine "tends to
     increase silver  ion  leaching  activity" and that a high  chlorine  level
     should  be  included in  the silver leaching  test;  but  no  reference  or
     evidence, however,  is provided to back  this assertion.
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Discussion;

     We have  no compelling evidence  or reason to  expect that  chlorine  will
     enhance the leaching  of  silver.   However, the prescribed  low pH and TDS
     levels will provide a clearly severe test for silver leaching.

Recommendations

     No change needed.

P.   Unnecessary difficulty and  expense of test protocols.   Several comments
     were made  under this general heading.   These  comments  are  outlined and
     discussed as follows:

     1.   Too many  sampling events are required; sampling  of a  few  units at
          start, middle and finish should be  satisfactory:   The committee has
          carefully laid out the standard and protocol and we feel the minimum
          sampling  plan must  be maintained  for the  consumers'   health  pro-
          tection.

     2.   Three units  are too many  to study; parallel  testing  of  two units
          should be satisfactory:  For  consumer protection,  the Disinfectants
          Branch, Office of Pesticide Programs, has traditionally required the
          testing of  three units.   The committee  recognizes  the additional
          cost  involved in testing  a  third  unit  but feels that this  will
          provide a minimum level  of  assurance to prevent  infectious disease
          and recommends retention of the 3-unit requirement.

     3.   The protocol requires large tanks and microbiological reseeding on a
          daily basis s   We  feel  that the  tank  size requirements  are  not
          extreme and can be met by an interested laboratory.  With respect to
          reseeding, it should be pointed out that virus and cyst seeding need
          only be conducted  immediately before and  during the  sampling  "on"
          period (see Section 3.5.1.b(2)), equivalent  to  less that 10% of the
          "on" time.  This "spot" seeding for viruses and cysts recognized the
          expense and  difficulty  of  maintaining large  populations  of these
          organisms.  Continuous seeding was provided  for  bacteria because
          they are easier to grow  and maintain and  might have the capacity to
          grow through some units, given enough time and opportunity.

     4.   Challenge  levels of  contaminants  are  too high  compared  to known
          environmental conditions and the required log reductions exceed Safe
          Drinking  Water  Act  requirements:   As  explained in  a  footnote to
          Table 1,  Section 2,  the  influent challenges may  constitute greater
          concentrations than  would  be anticipated  in source  waters.   These
          levels are  necessary to test properly  for the required log reduc-
          tions  without having  to  utilize   sample  concentration procedures
          which are time/labor  intensive  and  which may,  on  their own, intro-
          duce  quantitative  errors to  the microbiological  assays.   As  men-
          tioned in  Part I of  this  paper, the  log reductions  for bacteria,
          virus  and  Giardia  have  been  suggested  for  public  water  system
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treatment in a paper by Amirtharajah (1986, JAWWA,  78:3:34-49).   The
reductions  in the  microbiological  purifier  standard are  entirely
compatible  with  the  reductions  cited  for  public  water  supply
treatment.
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