Economic Evaluation of the
 Proppsed Interim Primary
 Drinking Water Regulations
FINAL. REPORT
for
U.S. Environmental Protection Agency
Office of Water Supply
Washington, D.C.

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EPA-570/9-75-002
                 ECONOMIC EVALUATION OF THE
     PROPOSED INTERIM PRIMARY DRINKING WATER REGULATIONS
                    CONTRACT # 68-01-2865
                        SUBMITTED TO:

            U,S, ENVIRONMENTAL PROTECTION AGENCY
                   OFFICE OF WATER SUPPLY
                     WASHINGTON, D,C,
                        SUBMITTED BY:

                  ENERGY RESOURCES CO, INC,
                  185 ALEWIFE BROOK PARKWAY
               CAMBRIDGE, MASSACHUSETTS  02138
                       (617) 661-3111

                        OCTOBER 1975

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This report has been reviewed by EPA, and approved
for publication.  Approval does not signify that
the contents necessarily reflect the views and
policies of the Environmental Protection Agency,
nor does mention of trade names or commercial
products constitute endorsement or recommendation
for use.

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                        TABLE OP CONTENTS
CHAPTER ONE
     1.5
EXECUTIVE SUMMARY
Drinking Water Regulations

Constraints to Implementation of the
Interim Primary Drinking Water Regulations
                                                             Page
1.0
1. 1

1.2
1. 2.1
1.2.2
1.3

1.3.1
1.3.2
1.4
Safe Drinking Water Act of 1974
Proposed National Interim Primary Drinking
Water Regulations
Public Water Systems
Background and Definitions
The Water Supply Industry
Costs to Meet the Proposed Interim Primary
Drinking Water Regulations
Monitoring Costs
Treatment Costs
Economic Impact of the Interim Primary
1
1

2
2
5
7

7
11
12
17
1.6
1.7
CHAPTER TWO
2.0
2.1
2.2
CHAPTER THREE
3.0
3.1
3.2
3-3
3.4
3-5
3-6
3.7
Limits of the Analysis
Energy Use
INTRODUCTION
Safe Drinking Water Act of 1974
Interim Primary Drinking Water Regulations
Study Objective
THE WATER SUPPLY INDUSTRY
General Description
History
Organization
Customers
Community Water Systems
Production
Ownership
Public Non-Community Water Supply Systems
19
20

21
22
23

25
26
28
30
31
38
38
42
                              -1-

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                                                             Page
CHAPTER FOUR   DEVELOPMENT OF COSTS
4.0
4.1
4.1.
4.2

4.3


4.4

4.5

4.6

4-7
4.8
4.9
4.10

4.11
4.12

4.13
               Introduction
               Monitoring Costs for Community Water Systems
               Monitoring of Water Systems at Present
               Costs Incurred by Community Water Systems
               When Maximum Contaminant Levels Are  Exceeded
               Special Monitoring Required of Community
               Water Systems When Chemical Contaminants
               Are Pound to be Between 75 and 100 Percent
               of Maximum Levels
               Costs for Monitoring of Water Systems
               Serving Transient Populations (Non-Community
               Systems )
               Costs Incurred by Non-Community Systems
               When Maximum Allowable Limits are Exceeded
               Costs Incurred by Non-Community Systems
               When Contaminant Level is 75 Percent or
               More of Maximum Contaminant Level
               Total Monitoring Costs
               Water Quality Data
               Expansion Factors
               Treatment Costs Incurred by Community
               Water Supply Systems
               National  Treatment Costs
               Treatment Costs for Public Non-Community
               Systems
               Sensitivity of Treatment Costs-
 51
 62
 62

 69
 73
 76

 83

 83
 83
 95
 97
110
CHAPTER FIVE   CONSTRAINTS TO IMPLEMENTATION OF THE INTERIM

5.0
5-1
5.1-
5.1.
5-1.
5.1-
5-2



1
2
3
4

PRIMARY DRINKING WATER REGULATIONS
Introduction
Chemical Constraints
Coagulation
Disinfection
Activated Carbon
Projections
Manpower Constraints

115
116
124
130
132
134
135
                              -ii-

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                                             Page
5.2.1
5.2.2
5.2.3
5.2. 4
5-2.5
5.2.6
5.2.7
5.3
5.4
5.4.1
CHAPTER SIX
6.0
6.1
6.2
6.2.1
6. 2.2
6.2.3
6.3
6.3-1
6.3.2
6.3.3
6.3-4
6.3.5
CHAPTER SEVEN
7.0
7-1
7.2
General
Manpower Availability
Personnel Required to Implement Interim
Primary Drinking Water Regulations
Monitoring and Enforcing
Operation of New and Retrofit Process
Equipment
Program Assistance
Program Administration
Laboratory Constraints
Construction Constraints
Building Materials
FEASIBILITY OF FINANCING COSTS
Introduction
Present Industry Financial Structure
Characteristics of Demand for Water
Trends In Demand
Uses of Treated Water
Elasticity of Demand
Distribution of Costs
General
Annual Monitoring Costs
Annual Capital Costs
Annual Operation and Maintenance Costs
Total Annual Costs
ECONOMIC IMPACT ANALYSIS
Introduction
Monitoring Impacts
Price Impacts - Case Studies of Model
135
138
146
146
147
156
156
156
161
164
165
165
175
175
175
178
180
180
182
182
190
197
205
205
209
Systems
                -111-

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                                                              Page
      7.3
      7.4
 Macroeconomic Effects
 Energy  Use
224
224
 CHAPTER EIGHT   LIMITS  OP  THE  ANALYSIS
      8.0
      8.1
      8.2
      8.3

      8.4
 Introduction                                   225
 Assumptions in Developing Monitoring  Costs     225
 Assumptions in Developing Treatment Costs      226
 Assumptions Inherent in the Constraint         233
 Analysis
 Other Assumptions                              233
 CHAPTER  NINE    EXAMINATION  OP ALTERNATIVES  TO  THE  INTERIM
      9-0
      9-1
      9.2
      9-3
      9.4
      9.5

      9-6
      9-7
 PRIMARY DRINKING WATER REGULATIONS
 Introduction                                   237
 Effect of Changing the Definition of           237
 "Community" Water System
 Monitoring                                     240
 Effect of Alternative Monitoring Options       242
 on Treatment Requirements
 Manpower Requirements                          242
 Potential Manpower Saving for Water Quality    245
 Monitoring from Alterations to Prescribed
 Methods
 Summary of Alternative Monitoring Options      246
 Effects of Changing the CCE Level              248
APPENDIX A

APPENDIX B


APPENDIX C

APPENDIX D
APPENDIX E
PROPOSED INTERIM PRIMARY DRINKING WATER
STANDARDS
QUESTIONNAIRE TO STATE AGENCIES WITH
RESPONSIBILITY FOR DRINKING WATER
REGULATIONS
DESCRIPTION OF PUBLIC NON-COMMUNITY
SYSTEMS BY USE CATEGORY
WATER SUPPLY SYSTEM QUESTIONNAIRES
CONTAMINANT REMOVAL BY CONVENTIONAL WATER
TREATMENT PROCESSES
                                 -iv-

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APPENDIX P     CHEMISTRY OF REMOVAL OF CONTAMINANTS FROM
               DRINKING WATER SYSTEMS
APPENDIX G     DATA BASE AND COST ESTIMATES OF WATER
               TREATMENT
APPENDIX H     WASTES PRODUCED FOR EFFLUENT GUIDELINES
APPENDIX I     UPGRADING PRESENTLY OPERATING WATER
               TREATMENT PLANTS
APPENDIX J     REVISED DRINKING WATER  STANDARDS
APPENDIX K     DESCRIPTION OF ORIGINAL SMSA'S

               BIBLIOGRAPHY
                                  -v-

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                       LIST OP TABLES
CHAPTER ONE

     1-1

     1-2


     1-3
     1-4
     1-5

     1-6



     1-7
                                             Page

EXECUTIVE SUMMARY

•Distribution of Community Water Systems        3

Treatment Processes Employed by Community      4
Water Systems
Community Water Supply Use by Category         5

Total Monitoring Costs Mandated by the        10
Proposed Interim Primary Drinking Water
Regulations

National Costs of Treating Contaminants       13
in Drinking Water

Estimated National Costs of Implementing      l4
the Interim Primary Drinking Water
Regulations for Community Water Supply
Systems

Distribution of Costs for Those Systems       15
Needing Treatment by Size of System for
Pour Size Ranges
CHAPTER TWO
INTRODUCTION
CHAPTER THREE  THE WATER SUPPLY SYSTEM
     3-1
     3-2

     3-3
     3-4


     3-5

     3-6



     3-7
U.S. Total Water Use 1970-1980               26
19th Century Water Utility Growth            27

Community Water Supply Use by Category       30
Available Information on Community           32
Water Supply Systems
Number of Community Water Supply Systems     34
by State
Breakdown of Five Community Water Surveys    35
by Percentage of Systems in Each of Nine
Population Categories
Percentage of Community Water Systems Which  36
Utilize Each of Four Sources of Water for
Five Studies
                               -VI-

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     3-8       Percentage  of Treatment  Processes            37

     3-9       Average  Daily U.S.  Water Production         38
               Per Capita  by EPA Region

     3-10      Number of Systems and Total Daily            39
               Production  for Seven Production
               Categories
     3-11      Publicly-Owned Water System Production      40
               by Size  and Treatment Type
     3-12      Privately-Owned Water System Production     4l
               by Size  and Treatment Type

     3-13      Estimated Number of Public Non-Community     44
               Water Supply Systems by  State
     3-14      Source of Water for 11 Studies  of  Public     46
               Non-Community Water Systems
     3-15      Number of Non-Community  Systems by          48
               Source
CHAPTER FOUR   DEVELOPMENT OF COSTS

     4-1       Summary of Monitoring Requirements           53
               (Except Turbidity)

     4-2       Distribution of Community Water Systems      54
               by Population Class and Source of Water
     4-3       Analysis of Drinking Water Samples:          56
               Typical Charges by  Commercial Laboratories
               for Analyses Specified in Regulations

     4-4       Numbers of Analyses Per Man-Month for        57
               Some Components of  Proposed Interim
               Drinking Water Regulations

     4-5       Monthly Budget for  Analysis of Inorganic     58
               Samples

     4-6       Monthly Budget for  Analysis of              59
               Bacteriological Samples

     4-7       Costs of Routine Monitoring for the          6l
               Community Waterworks

     4-8       Interstate Carrier  Water Suppliers           63
               Which Are Also Community Water Suppliers

     4-9       Coliform Analyses by State                  64

     4-10       Present Costs for Coliform Monitoring        67
               of Interstate Carrier Water Supplies
                              -Vll-

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4-11      Monitoring Requirements When Maximum         68
          Contaminant Level is Exceeded

4-12      Systems Which Exceeded One of More           70
          Maximum Contaminant Level Broken Down
          by Population Served

4-13      Special Monitoring Costs for Coliform        71
          Violations

4-14      Special Monitoring Costs for Chemical        72
          Violations

4-15      Systems Which are Between 75- and 100         74
          Percent of Maximum Contaminant Level
          Broken Down by Population Served
4-16      Special Monitoring Required When             75
          Chemical Contaminant Levels are Pound
          to be Between 75 and 100 Percent
          of Maximum Levels

4-17      Monitoring Costs for Community Systems       76

4-18      Number of Non-Community Systems by           77
          Source

4-19      Costs of Routine Monitoring for Water        78
          Systems Serving Non-Community Populations
          According to the Proposed Interim Primary
          Drinking Water Regulations

4-20      Number of Public Non-Community Systems       79
          Which Exceeded One or More Maximum
          Contaminant Levels as Specified in the
          Interim Primary Drinking Water
          Regulations
4-21      Special Monitoring Costs of Coliform         8l
          Violations (Non-Community Systems)

4-22      Special Monitoring Costs for Chemical        82
          Violations (Non-Community Systems)

4-23      Special Monitoring Required When             84
          Chemical Contaminant Levels are
          Between 75 and 100 Percent of
          Maximum Levels (Non-Community Water
          Systems)
4-24      Total Monitoring Costs Mandated by the       85
          Proposed Interim Primary Drinking
          Regulations
                      -viii-

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                                                       Page


4-25      Summary of Water Quality Data Available       8?
          for Community Water Supply Systems

4-26      Percent of Community Water Systems Which      88
          Utilize Each of Four Sources of Water for
          Five Studies

4-2?      Breakdown of 1969 CWSS Study by Population    90
          Served and Source of Water

4-28      Breakdown of EPA Inventory by Population      91
          Served and Source of Water

4-29      Capital Treatment Costs for Nine              96
          Population Served Groups

4-30      Capital and O&M Costs of Chlorination and     98
          Clarification Unit Processes by Population
          Size Category

4-31      Breakdown of Treatment Costs for Mercury      99
          (Ion Exchange) by Population Served and
          Source of Water

4-32      Breakdown of Treatment Costs for Chromium    100
          (Ion Exchange) by Population Served and
          Source of Water

4-33      Breakdown of Treatment Costs for Barium      101
          (Ion Exchange) by Population Served and
          Source of Water

4-34      Breakdown of Treatment Costs for Lead        102
          (pH Control) by Population Served and
          Source of Water

4-35      Breakdown of Treatment Costs for Arsenic     103
          (Activated Alumina) by Population Served
          and Source of Water

4-36      Breakdown of Treatment Costs for CCE         104
          (Activated Carbon) by Population Served
          and Source of Water
4-37      Breakdown of Treatment Costs for NO^         105
          (Ion Exchange) by Population Served
          and Source of Water
4-38      Breakdown of Treatment Costs for Selenium    106
          (Ion Exchange) by Population Served
          and Source of Water
4-39      Breakdown of Treatment Costs for Cadmium     107
          (Ion Exchange) by Population Served and
          Source of Water
                            -ix-

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                                                           Pag_e_


     4-40      Breakdown of Treatment Costs for Fluoride    108
               (Activated Alumina) by Population Served
               and Source of Water

     4-4l      National Costs of Treating Contaminants      109
               in Drinking Water

     4-42      Labor and Construction Indices by EPA        112
               Region
     4-43      Production Per Capita Per Day for 122        113
               Private Water Companies

     4-44      National Costs of Treating Contaminants      114
               in Drinking Water


CHAPTER FIVE   CONSTRAINTS TO IMPLEMENTATION OF THE
               INTERIM PRIMARY DRINKING WATER REGULATIONS

     5-1       Chemicals Used in Water Treatment            118

     5-2       Constraint Analysis of Key Water Treatment   123
               Chemicals and Supplies

     5-3       Number of Community Systems Which Will       124
               Need Treatment to Meet Proposed Interim
               Primary Drinking Water Regulations

     5-4       Synthetic Organic Polymers Approved for      127
               Water Treatment

     5-5       Coagulants by End Market                     129

     5-6       Water and Wastewater Treatment Chemicals     136

     5-7       Water Utility Personnel Categories           137

     5-8       United States Water Utility Managers         139
               Salary Surveys 1968-1974

     5-9       United States Average Salaries and Wages     140
               (AWWA Surveys) and Percentage Increases
               1968-1974
     5-10      Median Water Utility Manager Salaries        l4l
               Compared to Median Salaries for
               Engineers in Public Utilities

     5-11      Water Utility Employee Benefits,             142
               1974 Survey
     5-12      Comparison of U.S.  Chamber of Commerce       144
               and AWWA Employee Benefits Surveys
                                -x-

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     5-13      Microbiological Staffing Requirements        148
     5-14      Laboratory Manpower Requirements —          149
               Nationwide Monitoring of Community
               Systems
     5-15      Laboratory Manpower Requirements Nation-     150
               wide for Non-Comminity Systems
     5-16      Sanitary Inspectors and Laboratory           151
               Personnel by State
     5-17      Personnel to Operate New and Retrofit.        152
               Process Equipment
     5-18      Average Number of Employees for Different    153
               Treatments Publicly-Owned
     5-19      Summary of Manpower Required to Implement    157
               the Primary Drinking Water Regulations
     5-20      Lab Certification by State                   159
     5-21      Percentage of Total Monitoring Costs by      loO
               State
     5-22      Present Coliform Monitoring to Meet          162
               Effluent Guideline Limitations
     5-23      New Construction Put in Place: Trends        163
               and Projections 1972-75

CHAPTER SIX    FEASIBILITY OF FINANCING COSTS
     6-1       Financial Structure of Investor-Owned        166
               Water Supply and Related Services
     6-2       Capital COST.S for A Model Water System       169
               Serving 250 People
     6-3       Water Sales by Type of Customer              171
     6-4       Projections of Municipal Water               176
               Requirements
     6-5       Community Water Supply Use by Category       177
     6-6       The Relationship Between Price Changes       179
               and Quantities of Water Purchased as a
               Function of Price Elasticity
     6-7       The Relationship Between Revenue and         iSl
               Price Change as a Function of Elasticity
     6-8       Annual Monitoring; Costs                      IS?
                               -XI-

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                                                      Page


6-9       Total Annual Capital Expenditures by        184
          Treatment Process for Publicly-Owned
          Utilities

6-10      Total Annual Capital Expenditures by        185
          Treatment Process for Investor-Owned
          Utilities

6-11      Total Annual Capital Expenditures by        186
          Treatment Process

6-12      Total Annual Capital Expenditures by Size   187
          of System for Publicly-Owned Utilities

6-13      Total Capital Expenditures by Size of       188
          System for Investor-Owned Utilities

6-14      Total Annual Capital Expenditures by Size   189
          of System

6-15      Total Annual O&M Expenditures by            191
          Treatment Process for Publicly-Owned
          Utilities

6-16      Total Annual O&M Expenditures by Treatment  192
          Process for Investor-Owned Utilities

6-17      Total Annual O&M Expenditures by Treatment  193
          Process

6-18      Total Annual O&M Expenditures by Size of    194
          System for Publicly-Owned Utilities

6-19      Total Annual O&M Expenditures by Size of    195
          System for Investor-Owned Utilities

6-20      Total Annual O&M Expenditures by Size of    196
          System

6-21      Total Annualized Total Costs by Treatment   198
          Process for Publicly-Owned Utilities

6-22      Total Annualized Total Costs by Treatment   199
          Process for Investor-Owned Utilities

6-23      Total Annualized Total Costs by Treatment   200
          Process
6-24      Total Annualized Total Costs by Size of     201
          System for Publicly-Owned Utilities

6-25      Total Annualized Total Costs by Size of     202
          System for Investor-Owned Utilities

6-26      Total Annualized Total Costs by Size of     203
          System
                       -xii-

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CHAPTER SEVEN  ECONOMIC IMPACT ANALYSIS
     7-1

     7-2


     7-3
     7-5

     7-6


     7-7

     7-8

     7-9

     7-10
     7-11


     7-12
Chemical Sampling Requirements for           206
Public Water Systems
Analytical Costs Per Person Versus           209
System Size and Type for Community Water
Systems
Per Capita Annualized Capital Costs for      213
a System Serving 100 People
Per Capita Annualized Capital Costs for      214
a System Serving 5,000 People
Per Capita Annualized Capital Costs for      215
a System Serving 1,000 People

Distribution of Costs for Those Systems      216
Needing Treatment by Size of System for
Four Size Ranges
Annualized Costs of Treatment in Model       217
Systems
Probability of Needing Treatment             218
Combinations by System Size
Projected Cost Effects by Treatment          219
Process on Three Sized Water Systems
Water Sales and Revenue by Type of Customer  220
Price Impacts of Representative Treatments   222
Based on Present Average Distribution of
Total Costs
Sample of Water Rates Across the Country     223
CHAPTER EIGHT  LIMITS OF THE ANALYSIS
     8-1
     8-2

     8-3

     8-4
Treatment Technology for MCL

Comparison of Turbidity Control Costs

Capital Treatment Costs for Small Water
Systems Using Current Production Rates

Ion Exchange and Clarification Costs
Assigned to Small Community Systems
227
229

231


235
                           -Xlll-

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                                                           Page

CHAPTER NINE   EXAMINATION OF ALTERNATIVES TO THE INTERIM
               PRIMARY DRINKING WATER REGULATIONS

     9-1       Alternative Monitoring Options               238

     9-2       Costs of Alternative Monitoring Options      239

     9-3       Total Monitoring Costs For Three Sets of     24l
               Monitoring Alternatives

     9-4       Annual Monitoring Costs Per Person for       243
               Three Sets of Monitoring Alternatives

     9-5       Summary of Manpower Requirements to          244
               Implement Three Sets of Alternative
               Monitoring Options

     9-6       Potential Manpower Saving by Substitution    247
               of More Efficient Analytical Techniques

     9-7       Effect of Changing Maximum Level of CCE      249

     9-8       Additional Production of Carbon Per Annum    249
               to Remove CCE Organics from Water

     9-9       Treatment Cost for .CCE                       249
                           -xiv-

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                       LIST OF FIGURES
CHAPTER THREE  THE WATER SUPPLY INDUSTRY
     3-1

     3-2
Public Water Utility Water Needs for the
Years 1900 to 1980
Unit Price of Water in Cents/1,000 Gallons
Page



 29

 43
CHAPTER FOUR   DEVELOPMENT OF COSTS
     4-2
Percentages of Total Monitoring Costs In      50
the United States Versus Percentages of
Population Served and Percentages of
Water Supply Systems
Percentages of Population Served by           52
Community Water Systems Required to Install
Treatment Versus Percentages of Total
Treatment Costs
CHAPTER FIVE   CONSTRAINTS TO IMPLEMENTATION OF THE INTERIM
     5-1
     5-2


     5-3
PRIMARY DRINKING WATER REGULATIONS

Chemicals Used to Treat Drinking Water

Water and Wastewater Treatment Chemical
Sales for Coagulants

Carbon Replacement Costs
 117
 131

 133
CHAPTER SIX
     6-1
FEASIBILITY OF FINANCING COSTS

Unit Price of Water in Cents/1,000 Gallons
 173
CHAPTER SEVEN  ECONOMIC IMPACT ANALYSIS
     7-1

     7-2


     7-3
Annual Per Capita Bacteriological Samples     208
Versus Size of System
Annual Monitoring Costs Per Person --         210
Small Systems
Annual Monitoring Costs Per Person —         211
Large Systems
CHAPTER EIGHT  LIMITS OF THE ANALYSIS
     3-1
Monthly Cost of Wells and Pumping Systems
  234
                              -xv-

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                            CHAPTER ONE


                         EXECUTIVE SUMMARY
1.0  Safe Drinking Water Act of 197^

     The purpose of the Safe Drinking Water Act is to assure
that water supply systems serving the public meet minimum
national standards for the protection of public health.   To
achieve this objective the Congress authorized the Environ-
mental Protection Agency to promulgate national drinking
water regulations.  In addition, the Act provides a mechanism
for the individual states to assume the primary responsibility
for enforcing the regulations by providing general supervisory
aid to the public water systems and Inspecting public water
supplies.

     The objective of the legislation Is to establish standards
which will provide for safe drinking water supplies throughout
the United States.  Prior to passage of the Act, the Environ-
mental Protection Agency was authorized to prescribe Federal
drinking water regulations only for water supplies used  by
Interstate carriers.   Furthermore, these regulations could
only be enforced with respect to contaminants capable of
causing communicable disease.  In contrast, the Safe Drinking
Water Act authorized the Environmental Protection Agency to
establish (1) Federal regulations for the protection of  all
public water systems from all harmful contaminants; and  (2)
a joint Federal-State system to assure compliance with these
regulations and to protect underground sources of drinking
water.
1.1  Proposed National Interim Primary Drinking Water
     Regulations

     The EPA published its Proposed National Interim Primary
Drinking Water Regulations in the Federal Register,  March
14, 1975.  The major provisions of the Proposed Interim
Primary Drinking Water Regulations are:

     1.   Establishment of maximum contaminant levels
          for certain inorganic, organic, and biological
          contaminants, and establishment of maximum
          turbidity levels;
                           -1-

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     2.    Establishment of monitoring frequencies;

     3.    Establishment of a methodology to notify
          consumers of variances,  exemptions, and non-
          compliance with regulations;

     4.    Establishment of reporting requirements for
          systems failing to comply with the regulations.
1.2  Public Water Systems
     1.2.1  Background and Definitions

     The Interim Primary Drinking Water Regulations define
the term "public water system" as a system for the provision
to the public of piped water for human consumption, if such
a system has at least 15 service connections or regularly
serves an average of at least 25 individuals daily at least
three months out of the year-  The term "community water
system" is defined as a public water system which serves a
population of which 70 percent or greater are residents.
There are approximately 40,000 community water supply systems
listed in the EPA Public Water Supply Inventory at the
present time.  For the purposes of this analysis, the EPA
inventory is considered to be representative of the nation's
community water systems in regard to important variables
Including population served, treatment facilities presently
used, and source of water.  Table 1-1 shows the distribution
of community water systems by population served.   Systems
may obtain their water either from surface or ground sources
or can purchase water from other producers.  Generally, most
small systems use ground sources while larger systems tend
to use surface sources.

     The percentage of systems presently employing the
various treatment processes is presented in Table 1-2.

     The available data indicate that the regional distribution
of production is proportional to the regional distribution of
population.   Sixty-eight percent of the systems serve 1,000
or fewer people and account for only 2 percent of the water
produced by community water systems, while 1 percent of
the systems serving the largest populations account for 62
percent of the total production.
                            -2-

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                        TABLE 1-1
        DISTRIBUTION OF COMMUNITY WATER SYSTEMS

POPULATION
SERVED BY
SYSTEM
25-99
100-9,990
10,000-99,999
^100,000
TOTAL

NUMBER OF
WATER SYSTEMS
7,008
30,150
2,599
243
40,000
TOTAL
POPULATION
(OOO's)
420
36,816
61,423
78,800
177,459
PERCENT
OF TOTAL
POPULATION
0.2
20.8
34.6
44.4
100.0
Source:   EPA Inventory of Public Water Systems,  July 1975.

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                      TABLE  1-2


          TREATMENT PROCESSES EMPLOYED BY
             COMMUNITY WATER SYSTEMS3-
TREATMENT                          EPA INVENTORY  (%}

Aeration                                6.6

Prechlorination                         7-8

Coagulation                            11.3

Sedimentation                           8.9

Filtration                             12.8

Softening                               4.9

Taste and Odor Control                  3.4

Iron Removal                            5.7

Ammoniation                             0.9

Fluoride Adjustment                     8.5

Disinfection                           35.2
     Q
      Percentages do not total 100 percent since many
systems have multiple treatments or no treatment.


      Source:  EPA Inventory of Public Water Systems,
July 1975-
                         -4-

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     Of the approximately 40,000 community systems presently
supplying water, the data indicate that 58 percent are
publicly owned and that 42 percent are private, investor
owned.  Eighty-eight percent of total production is from
publicly-owned plants, with private plants contributing only
about 12 percent.

     It is estimated that there are approximately 200,000
public non-community water systems.  This category includes
systems at schools and industries as well as systems found
at service stations, motels, restaurants, rest areas, camp-
grounds, state parks, beaches, national parks, national
forests, dams, reservoirs, and other locations freauented by
the travelling public.  Since data on these systems are
very sparse, only rough cost estimates can be made.
     1.2.2  The Water Supply Industry

     The water supply industry, as previously defined, includes
only those systems which maintain facilities to supply water
primarily for residential, commercial, industrial and municipal
use.  An approximate allocation of water supplied by water
systems to various categories of users is shown in Table 1-3-
Approximately 63 percent of the total water delivered is
used for residential purposes.
                              TABLE 1-3

              COMMUNITY WATER SUPPLY USE BY CATEGORY



           TYPE OF USE                   PERCENTAGE OF  TOTAL


           Residential                            63

           Commercial                             11

           Industrial                             21

           Municipal                               5


           TOTAL                                 100


           Source:   U.S.  Geological Survey  estimates,  1972.

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     The price consumers pay for water is determined, in
general, by costs the utility incurs for monitoring, treatment,
storage, and distribution.  However, some publicly-owned
water systems may have their costs and revenues conglomerated
with the costs of other municipal services, with the result
that the water bill paid by the consumer may not completely
reflect the status of the water system alone.  The type of
rate structure used by a particular water system varies from
system to system, and may also be different for various user
classes within the same system.

     There are four basic types of rate structures in use in
varying degrees around the country.  Systems using a "normal
block" structure charge lower unit costs to those customers
which use higher volumes of water-  "Inverted block" structure
systems charge higher unit costs to customers who use higher
volumes of water-  Under a "flat" rate structure there is
one single charge per unit for all customers, regardless of
use.  Generally, this structure is used for residential
customers only.  The "non-incremental" rate structure charges
unit costs based on the number of units of water consumption
equipment owned by the user.

     Neither  the size nor the ownership of the systems
correlates well with type of rate structure.  Prices charged
for water are usually regulated by a state or local commission
appointed to  evaluate the need for rate hikes.  Any rate
increases necessary to implement these regulations will have
to be approved by the appropriate commissions, but there is
often a large lag time between rate increase requests and
rate increase approvals.

     Most water systems finance large capital investments by
retaining profits and acquiring debt.  Publicly-owned systems
usually have  access to municipal funds and are authorized to
sell either general obligation bonds or revenue bonds.  In
some localities, however, water system finances have not
been kept separate from general municipal funds.  Private,
investor-owned systems may issue stocks and bonds, but
unlike public systems, their credit ratings are dependent on
the profitability of their own operations.

     There does not seem  to be a correlation between present
debt levels and long-term financial soundness in the water
industry.  Although almost one-fourth of the water systems
are presently debt-free,  approximately 85 percent of these
debt-free systems serve communities of less than 5,000
people.  However, many of these small investor-owned systems
do not have positive net  income, while larger water  systems
with high debt-to-book value ratios do have positive net
incomes.
                             -6-

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1.3  Costs to Meet the Proposed Interim Primary Drinking Water
     Regulations
     1.3-1  Monitoring Costs

     The implementation of the Proposed Interim Primary
Drinking Water Regulations will cause all public water
systems to initiate a routine monitoring program to assure
that at least minimum standards of water quality are maintained
The cost associated with this monitoring activity is a
function of both the size of the community and the source(s)
of water.

     Monitoring costs will be incurred by water systems as a
result of the implementation of the Proposed Interim Primary
Drinking Water Regulations In the following categories:

     1.   Routine monitoring costs for community water
          systems;

     2.   Costs incurred by community systems when
          maximum allowable limits are exceeded;

     3.   Costs Incurred by community systems when the
          contaminant level is 75 percent or more of the
          maximum contaminant level;

     4.   Routine monitoring costs Incurred by public
          water systems other than community systems;

     5-   Costs incurred by public non-community systems
          when maximum allowable limits are exceeded;

     6.   Costs incurred by public non-community systems
          when the contaminant level is 75 percent or
          more of the maximum contaminant level.

     The Proposed Interim Primary Drinking Water Regulations
call for the monitoring of four classes of contamination:
inorganic, organic, microbiological, and turbidity.  Turbidity
monitoring is not considered here because these costs  are
considered to be negligible.

     In order to develop a set of monitoring costs it  was
necessary to determine present laboratory analysis costs.
These  laboratory costs were obtained in the following  three
ways :
                             -7-

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     1.    First-hand data from laboratories;

     2.    Data extrapolated from EPA manpower data
          on analysis requirements;

     3.    Actual analysis of cost data gathered from
          a survey of 207 plants which had failed at
          least one of the proposed  mandatory regulations
          during a 1969 study-

     The volume of coliform monitoring called for by the
regulations makes the cost of coliform determination the
most critical component in determining the overall costs of
routine monitoring.

     According to the methodology employed,  the number of
systems requiring routine monitoring is fixed by the number
of ground- and surface-water supply  systems  in each discrete
size range and the monitoring frequency prescribed by the
regulations.  Therefore, the only variable in the cost
equation is the price per analysis,  which is  in turn dependent
on the institutional monitoring arrangements  made by each
system.  In this study, a range of costs is  presented; the
lower monitoring cost is represented by costs incurred by
EPA in its laboratories, and the higher monitoring cost was
calculated from costs which would be charged  by moderately
expensive commercial laboratories.  Using a  range of $5 to
$10 per coliform analysis or plate count, $78 to $188 for a
complete inorganic analysis, and $200 to $312 for a complete
organic analysis, it is concluded that the routine monitoring
costs for the 40,000 community systems would  be between $22
million and $43 million per year.  It is anticipated that
many state laboratories will do the  majority  of the routine
monitoring mandated by the regulations.  If  this is the
case, then the actual national costs will fall on the low
side of the calculated ranges.

     To develop costs which would be incurred by systems to
monitor their water supplies when maximum contaminant levels
(MCL) are exceeded, Information was  needed on the number and
type of analyses to be performed as  well as  on the cost per
analysis.  Again, EPA and commercial laboratory rates were
used to establish cost ranges.  The  regulations state that
when the coliform MCL is exceeded, daily samples shall be
collected and examined from the same sampling point until
at least two consecutive samples yield no positive results.
Likewise, the regulations state that when either an
inorganic or organic MCL is exceeded, a repeat analysis
shall be done within 24 hours.  Repeat analyses shall then

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be made at weekly intervals until the MCL has not been
exceeded in samples taken on two successive weeks or until a
monitoring schedule as a condition to a variance, exemption,
or enforcement action shall become effective.  Using these
sampling criteria as guidance, it is possible to establish
expected maximum and minimum sampling requirements.  Because
of the possibility of spread of contagious disease, it is
extremely important that any coliform violations be corrected
as soon as possible.  For this reason it is expected that
between 7 and 30 special coliform analyses will be performed,
assuming violations will persist for one week to one month.
For organic and inorganic violations it is expected that
between 8 and 52 analyses will be performed, assuming that
violations will continue for 8 to 52 weeks.  Finally, the
proposed regulations state that monthly analyses shall be
made for each contaminant which is found at greater than 75
percent of the maximum contaminant level.

     When the 1969 Community Water Supply Study (CWSS) was
used to determine the number of systems which exceeded one
or more MCL, a national monitoring cost of between $2.0
million and $11.1 million per year was calculated.  It is
important to recognize that the majority of these special
monitoring costs will be incurred within the first two years
after implementation of the regulations, due to the fact
that those systems which are found to exceed an MCL in the
first two years of monitoring will either install a treatment
process or obtain a variance or exemption by the third year.

     The cost components necessary to determine the national
costs of routine monitoring for the 200,000 public non-
community systems are the same as for the community systems.
Calculations show that the nation's 200,000 non-community
systems would require between $^7 million and $92 million
annually to perform routine monitoring.  Special monitoring
costs for the non-community systems would range between $1.6
million and $10.7 million if the same non-compliance criteria
are used for both the community and non-community systems.
The special monitoring costs were assumed to be spread over
a 5-year period as systems are brought into compliance.
Total monitoring costs for the first two years are summarized
in Table 1-4.

     The analysis shows that systems serving small popu-
lations vastly outnumber larger systems; therefore, small
systems assume the greatest share of monitoring costs while
serving an extremely small percentage of the population.

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                            TABLE 1-4

           TOTAL MONITORING COSTS MANDATED BY THE
      PROPOSED INTERIM PRIMARY DRINKING WATER REGULATIONS
                                         FIRST YEAR  SECOND YEAR
                                        ($ million)  ($ million)
Costs of Routine Monitoring for the
40,000 Community Systems

Monitoring Costs for Coliform
Violations for 40,000 Community Systems

Monitoring Costs for Chemical
Violationsa for 40,000 Community
Systems

Monitoring Costs When Between 75 and
100 Percent3- of Maximum for 40,000
Community Systems

Routine Monitoring Costs for
200,000 Public Systems

Monitoring Costs for Coliform
Violations13 for 200,000 Community
Systems

Monitoring Costs for Chemical
Violations13 for 200,000 Public
Systems
Monitoring Costs When Between

                                 and
100 Percent^ of Maximum for 200,000
Public Systems
                                          22.2-42.8   22.2-42.8


                                           0.3-3.2     0.3-3.2
                                           0.2-1.5
                                           0.3-2.1
                                           0.5-6.8
                                           0.8-1.9
0.1-1.5
                                           0.6-1.4     0.6-1.3


                                          47.1-92.0   47.1-92.0
0.3-2.1
0.5-6.1
0.8-1.9
     TOTAL

Present Coliform Monitoring Costs
for 40,000 Community Systems

Present Coliform Monitoring Costs
for 200,000 Public Systems
                                          72.0-151.7  71-9-151.6
                                        (-)7.3-l4.4 (-)7.3-i4.4
                                         ;-)1.2-2.4  (-H.2-2.4
Additional Costs Mandated by
Proposed Regulations
                                          63.5-134.9  63.^-134.
     a
      Assumes violations will be found during first two years
of sampling.

     bAssumes violations will be found during first five  years
of sampling.
                            -10-

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Annual monitoring costs per capita are much higher for small
systems.  For systems serving less than 100 persons, the
average per capita cost varies from about $5 to $10.  Approxi-
mately 7,000 community systems fall in this category.
     1-3-2  Treatment Costs

     Once the monitoring program is initiated, many systems
will find that they exceed one or more MCL and will then be
faced with an additional cost in order to achieve the required
MCL.  There are several alternative routes which a system
can pursue in order to comply with the regulations.  One
option is to install the treatment facilities capable of
reducing the MCL to an acceptable level.  Another option is
to choose to use alternative less-contaminated sources of
water.  Finally, a combination of additional treatment and
judicious management of water sources may achieve compliance
with the regulations. The initial economic analysis assumed
that the installation of treatment facilities would be the
approach used to provide safe drinking water.

     The costs incurred by a community in removing any
contaminants are site-specific and are dependent on many
interrelated factors such as treatment facilities presently
available, age of system, and source of water-  The following
methodology was used to project national treatment costs
mandated under the Interim Primary Drinking Water Regulations
from the data base of 969 systems included in the 1969 CWSS,
the April 1975 Chemical Analysis of Interstate Carrier Water
Supply Systems, and the 197^-75 EPA Public Water Supply
Inventory:

     1.   A cost estimate was made of the capital and
          O&M costs required to supply chlorination to
          27-5 percent of the presently unchlorinated
          systems in the EPA Inventory;

     2.   A cost estimate was made to determine the
          capital and annual O&M costs to clarify
          those water systems in the EPA inventory of
          40,000 systems which have surface water supplies
          and do not clarify.  The O&M and capital costs
          were determined by assuming that direct
          filtration would be the treatment chosen by
          those systems which require clarification;
                            -11-

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     3.    Those systems shown to be having problems with
          a particular contaminant were assigned capital
          and O&M costs for correcting the violation.
          Lead treatment costs were determined using pH
          control as the treatment process; ion exchange
          was the treatment process chosen to treat for
          Cd, Cr, NC>3, Se,  Hg, and Ba.  Activated alumina
          absorption was chosen to remove excess fluoride
          and As, while activated carbon would remove
          CCE organics.

     In each of the above cost projections both the maximum
daily water production and the average daily production, as
calculated from the Public Water Supply Inventory, were used
to project national investment costs.   Using the 1969 CWSS,
projections were made of the number of systems which exceeded
each MCL, except for coliform and turbidity.

     On the basis of the above assumptions a national capital
treatment cost range of approximately  $1.1 billion to $1.8
billion was determined with a related  annual O&M cost of
$264 million (Table 1-5).  The data show that the major
expense would be incurred for clarification units to treat
the nation's surface-water systems.

     Cost estimates for non-community  systems to comply with
the regulations are also shown in Table 1-5-  It was assumed
that approximately 17 percent of all non-community systems
will require chlorination and that all systems using surface
sources will require clarification.  Total investment costs
are estimated to be about $24 million  and annual operation
and maintenance costs will be approximately $18 million.
1.4  Economic Impact of the Interim Primary Drinking Water
     Regulations

     An estimate was made of the annual costs of capital,
operation and maintenance, and monitoring necessary to
comply with the regulations.  Table 1-6 reiterates the costs
for community systems.

     The expenditures required to comply with the Proposed
Interim Primary Regulations will have an impact on all water
users except industrial water users who do not employ potable
water in their production processes.  The entire nation will
feel the impact of monitoring costs to some extent, but the
major costs of both capital and operation and maintenance
                             -12-

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                                            TABLE 1-5
                    NATIONAL COSTS OP TREATING CONTAMINANTS IN DRINKING WATER
uo
I

TREATMENT
TECHNOLOGY
COMMUNITY SYSTEMS
Clarification
Chlorination
Ion Exchange

Activated Alumina
pH Control
Activated Carbon
SUBTOTAL
NON-COMMUNITY SYSTEMS
Clarification
Chlorination
SUBTOTAL
TOTAL
CONTAMINANT

Turbidity
Colif orm
Ba, Cr, Cd
N03, Hg, Se
Fluoride, As
Pb
CCE


Turbidity
Colif orm


CAPITAL COSTS
($ million)

379
170
619

30
2
22
1,071

10
14
24
1,095

.3-682.9
.0-27.4
.2-996.9

.6-52.9
.7-4.2
-5-35.8
.3-1,800.1




.5-1,824.3
ANNUAL O&M
($ million)

188.
7.
52.

10.
0.
4.
263.

1
17
18
28l.

6
2
3

8
1
6
6




6

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                             TABLE 1-6


           ESTIMATED NATIONAL COSTS OP IMPLEMENTING THE
            INTERIM PRIMARY DRINKING WATER REGULATIONS
               FOR COMMUNITY WATER SUPPLY SYSTEMS^
                          ($ million)


     Total Capital Costs              1,071 - 1,800

     Annual Capital Costsb              150 - 252

     Annual O&M Costs                   264 - 264

     Annual Monitoring Costs             22 - 42

          a!975 dollars.

           Assumes 7 percent annual interest on capital costs
     amortized over 15 years.


will be felt in those areas served by water systems not
already meeting the MCL's.  The impact of these costs will
vary with the size of the water system involved.  Table 1-7
summarizes these costs as they affect systems of different
sizes.

     It can be seen from Table 1-7 that the per capita cost
in very small systems could be affected at a rate of up to
seven times that in medium- and large-sized systems.  In the
smallest category, the average annual per capita cost of
capital, O&M, and monitoring is approximately $9 to $56 ($36
to $224 for a family of four).

     Records indicate that per capita consumption of water
tends to decrease following significant increases in water
rates.   Among individual users the decrease would occur in
those uses for which there is high elasticity of demand;
e.g., lawn sprinkling.   The demand of industrial and commercial
users has been shown to be inelastic  in the face of price
increases.  If demand declines sharply after initial rate
hikes,  a second increase may be necessary to cover the
largely fixed costs of treatment.   It is  not certain how
these costs will be financed — either through higher taxes
or higher water rates — but it is certain that the Interim
Drinking Water Regulatons will have the greatest impact on
those served by smaller water systems.   Further study is
under way to determine if financing will  be a serious problem
for large or small systems.
                            -14-

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                                            TABLE 1-7
                    DISTRIBUTION  OF COSTS  FOR THOSE SYSTEMS NEEDING TREATMENT
VJl
I
BY
SIZE OF SYSTEM FOR
FOUR SIZE RANGES


SMALLEST SYSTEMS
(25-99
PEOPLE SERA/ED)
Annual Capital Costs 3.8 - 6.4
( $ million)
Annual O&M Costs ($ million) 2.1
Annual Monitoring Costs 0.5 - 1.0
($ million)
TOTAL ANNUAL COSTS
($ million)
Average Annual Cost per
Capita ($)
Increase in Household
Monthly Water Bill3- ($)
6.4 - 9.5
38 - 56
9.93 - 14.74
SMALL SYSTEMS
(100-9,999
PEOPLE SERVED)
60. 8 - 102.1
51.0
0.9 - 1.8
112.7 - 154.9
11 - 15
2.86 - 3.93
MEDIUM SYSTEMS
(10,000-99,999
PEOPLE SERVED)
53-6 - 90.0
75.7
1.8 - 3.8
131.1 - 169.5
9-12
2.32 - 3.01
LARGE SYSTEMS
(OVER 100,000
PEOPLE SERVED)
31.8 - 53-4
134.6
1.9 - 4.2
168.3 - 192.2
10 - 11
2.46 - 2.91
               Assumes  3.11 persons  per household and all increases in costs passed on
         to  the consumer.

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     Rather than install expensive treatment equipment, it
is anticipated that many small systems would explore the
following options:

     1.    Shift source of water from surface to ground;

     2.    Change groundwater sources;

     3.    Consolidate (merge)  systems;

     4.    Purchase  finished water;

     5.    Examine availability of grant programs such
          as that administered by the  Farmers Home
          Administration;

     6.    Use exemption and variance procedures
          specified in the regulations.

     The impact of  these alternatives  on the projected
national costs is being explored.  Specifically, viable
alternative treatment technologies for small systems are
being evaluated.  In addition, a more  detailed study of the
economic and financial impact  of these regulations is being
made with particular emphasis  given to small systems.  The
study will be based on detailed financial data and operational
information gathered through a survey  of a large sample of
water companies.  On the basis of these studies, an evaluation
of the above alternatives will be made at a later date.

     At the present time EPA believes  that the economic
impact of the construction requirements will be spread over
at least a 4-year period from the date of the promulgation
of the regulations  because the regulations will not result
in immediate compliance.  The  effective date of the regu-
lations will be 18  months after promulgation.  Non-
compliance may not  be discovered until initial sampling has
been completed.  Once the regulations  take effect, the
deadlines for initial sampling of community water supplies
will range from one day for turbidity  to two years for
inorganic samples of groundwater systems.  Therefore, in
some cases, more than three years could elapse after
promulgation before inorganic  violations would be detected
and corrective actions initiated.  In  addition, the use of
the exemption or variance provisions of the regulations
could further prolong compliance for public water systems
unable to comply for economic  or technical reasons.
                             -16-

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     It is estimated that the investor-owned water systems
would pay approximately one-fourth of the total treatment
costs, while the publicly-owned companies would pay the
remainder.  However, since many of the investor-owned
systems serve very small populations, the capital demands on
these systems could be substantial.

     In 1974, the water supply industry spent approximately
$1.5 billion for capital improvements.  The average total
annual capital costs mandated by the interim primary regu-
lations are estimated to be between 13 and 24 percent of
this figure.  It is anticipated that the industry as a whole
would be able to raise the additional necessary capital.
Small firms will, however, encounter difficulty in financing
new treatment facilities, particularly when ion exchange, a
relatively expensive treatment process, is required.  The
implementation of the regulations will force many communities
to allocate economic resources, which might be needed to
provide other services to the community, for the treatment
of their drinking water.

     The macroeconomic effects of the Interim Primary Drinking
Water Regulations are expected to be minimal.  On the average,
the regulations will cause an increase in water rates of 9-5
percent spread over several years.  If this increase occurred
in one year, the resulting increase in the Consumer Price
Index (CPI) would be less than 0.001 percent.  Since the
costs of these regulations will be incurred over several
years, the average annual increase In the CPI will be even
less.  The Chase Econometric Model predicts an estimated
average annual increase in the CPI of less than 0.1 percent
due to all pollution abatement programs.
I.5  Constraints to Implementation of the Interim Primary
     Drinking Water Regulations

     Potential non-economic constraints to the implementation
of the regulations were examined in several broad areas
including:  chemicals and supplies, manpower, laboratories,
and engineering and construction services.
      Chase Econometric Associates, Inc., "The Macroeconomic
Impacts of Federal Pollution Control Programs," prepared for
the Council of Environmental Quality and the Environmental
Protection Agency, January 1975-
                             -17-

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     The implementation of the Proposed National Interim
Primary Drinking Water Regulations within a reasonable time
frame would greatly depend on the availability of key chemicals
and supplies needed in the treatment of drinking water.  In
particular, the interim regulations  will increase demand for
coagulants and disinfecting agents.   It is anticipated that
this increased demand could cause some temporary dislocations
in chemical markets, but that increased demand will result  in
an expansion of supplies in the  long run.

     It is projected that the 1980 demand for ferric chloride
may increase by 15 to 20 percent over the present production
levels, while alum demand will be approximately 15 percent
greater than current production.  There is a general consensus
that organic polyelectrolytes will become the dominant
flocculating agents in the future.  However, there are no
reliable estimates of which polyelectrolyte(s) will be
dominant and when the shift in chemical usage will occur.

     Approximately 180,000 people are currently employed in
the water supply industry.  With the Implementation of the
Interim Primary Drinking Water Regulations approximately
26,000 additional personnel would be needed nationwide.
These personnel would be required to perform such tasks as
monitoring and enforcing the regulations, operating the
required treatment facilities, and performing laboratory
analysis of water samples, program assistance and program
administration.  It is anticipated that water systems may
have difficulty hiring qualified personnel.

     The third potential constraint  is in the availability
of adequate laboratories to perform the required chemical
and biological analyses.  Coliform monitoring is now being
performed at state, local and private laboratories.  In
meeting the coliform monitoring requirements, water suppliers
should not have difficulty finding laboratory facilities.
At the present time there is little  routine monitoring to
measure the heavy metals and organic compounds of concern
in the regulations.  However, there  are adequate numbers of
public and private laboratories capable of performing these
analyses, although state certification of laboratories, as
required by the regulations, could constrain available
laboratory facilities.

     The final area where constraints could occur is in the
design and construction of the required treatment facilities.
Although the annual cost of required new construction repre-
sents less than 0.4 percent of the present total annual new
                           -18-

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construction in the United States, design and construction
of new water treatment plants is a highly specialized
activity.  Some communities., especially those in rural
areas, may have difficulty obtaining these services due to
their expense or unavailability.
1.6  Limits of the Analysis

     In developing the cost estimates used in this study, it
was necessary to use several simplifying assumptions.  This
section explores these assumptions and their overall impact.

     The first assumption is that there are 40,000 community
water supply systems in the nation and that they are repre-
sented accurately by the current EPA inventory of community
water supply systems.  There is some evidence, however, that
when the inventory is completed there will be a total of
50,000 community systems rather than the estimated 40,000.
This increase in systems would cause a concomitant increase
in monitoring costs of about 12 percent and a similar increase
in treatment costs.

     All costs for public non-community systems were based
on the assumption that there are 200,000 of these systems
nationwide.  At the present time there is no accurate inven-
tory of these systems; thus, this number is merely an estimate.
It Is anticipated that the EPA will be performing an inventory
of these systems in the next few years so that these estimates
can be updated.

     Present average daily water production was determined
for nine discrete population groups.  This data base was
developed from the ongoing EPA inventory of community supplies.
Although these average production rates were used to develop
treatment costs, there is no way to determine the number of
systems which would design their treatment capacity to
reflect future growth and reserve capacity rather than
present needs.

     Another major consideration in developing treatment
costs is that many systems may use alternative water management
practices rather than install more costly treatment processes.
For example, groundwater systems might blend water from a
"clean" well with that from a "dirty" well so that the
resultant water would not exceed the MCL.  Similarly, no
estimate is possible to determine the possible benefits
which might result from cascading treatment processes.  For
                            -19-

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example, clarification units might remove enough heavy
metals so that the MCL for metals might not. be exceeded.
These treatment alternatives would vary from site to site so
that it is impossible to quantify the benefits which would
be derived.
1.7  Energy Use

     It is estimated that approximately 21,000 billion Btu's
per year will be required to operate plants and produce
chemicals for the various treatment systems necessary for
the 40,000 community systems to meet the regulations.  This
is about 0.028 percent of the 1973 national energy consumption,
based on data from the 197^ Statistical Abstract.  The actual
increase in energy use will depend on a number of factors,
including whether pollution in surface-water sources is
successfully controlled.   There will be no direct energy
savings from the recommended action.
                            -20-

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                       CHAPTER TWO
                      INTRODUCTION
2.0  Safe Drinking Water Act of 197^

     The objective of the Safe Drinking Water Act is to
provide for the safety of drinking water supplies throughout
the United States through the establishment and enforcement
of national drinking water regulations.  The Congress has
authorized the Environmental Protection Agency to promulgate
national drinking water regulations.  The individual states
will have the primary responsibility for enforcing the
regulations, providing general supervisory aid to the public
water systems, and inspecting all sources of drinking water.

     The major provisions of the Safe Drinking Water Act can
be summarized as follows:

     1.   Establishment of primary regulations for
          the protection of the public health;

     2.   Establishment of secondary regulations
          relating to odor and appearance of drinking
          water;

     3.   Protective measures for underground drinking
          water sources;

     4.   Research and studies regarding health,
          economic, and technological problems associated
          with drinking water supplies are to be under-
          taken.  Studies of viruses in drinking water
          and contamination by cancer-causing chemicals
          are specifically required;

     5-   A survey of rural water supplies to be
          performed;

     6.   Aid to the states in improving drinking water
          programs through technical assistance,
          training of personnel, and grant support.
          A loan guarantee to be provided to assist
          small water systems in meeting regulations
          if other means of financing cannot be
          reasonably found;
                              -21-

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    7.   Citizen suits to be filed against any party
         believed to be in violation of the Act;

    8.   Record-keeping, inspections, issuance
         of regulations, and judicial review;

    9.   A 15-member National Drinking Water
         Advisory Council to advise the Administrator
         of EPA on scientific and other responsibilities
         under the Act;

    10.   A requirement of the Secretary of Health,
         Education, and Welfare to insure that
         the  standards for bottled drinking water
         conform to the primary regulations
         established under the Act or to publish
         reasons for not doing so;

    11.   Authorization of appropriations totalling
         $156 million for fiscal years 1975,  1976,
         and  1977.
2.1  Interim Primary Drinking Water Regulations

     The Congress mandated that  the Environmental Protection
Agency establish the Interim Primary Drinking Water Regu-
lations within six months  after  passage of the Act.  The
major provisions of the Proposed Primary Regulations can be
summarized as follows:

     1.   Establish definitions  of the two types of
          "public" water supply  systems;

     2.   Set range of  applicability and coverage
          of standards;

     3-   Establish monitoring frequencies;

     4.   Establish analyses methodology criteria;

     5-   Establish maximum contaminant levels for
          certain inorganic, organic, and biological
          substances;

     6.   Establish a laboratory certification
          criterion;
                            -22-

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     7-    Establish procedure for notifying consumers
          of variances, exemptions, and non-compliance
          with standards;

     8.    Establish reporting requirements for systems
          failing any standard;

     9-    Establish criteria for locating future
          water supplies;

    10.    Set the effective date to be 18 months after
          promulgation of the standard.

A copy of the Proposed Interim Primary Drinking Water Regulations
as published in the March 14, 1975 Federal Register can be
found in Appendix A.
2.2  Study Objective

     The objective of this study is to provide an analysis
of the effects of implementing the Proposed Interim Drinking
Water Regulations as published in the March 14, 1975 Federal
Register.   The remainder of this study is composed of seven
chapters.   Chapter Three briefly describes the history and
characteristics of the water supply industry as well as
relevant information on the data bases used in this study.

     Chapter Four develops the total national costs for
monitoring the 40,000 community systems and 200,000 public non-
community systems.  This chapter also develops the costs
of treatment for those systems which would exceed one or
more maximum contaminant levels.  Finally, this chapter
explores the sensitivity of these costs and analyzes the key
variables.

     Chapter Five explores those non-economic variables
which might act as constraints to Implementation of the
Proposed Interim Primary Drinking Water Regulations.  In
particular, the study examines the availability of manpower,
key materials, laboratories, and engineering resources.

     Chapter Six predicts the manner in which the monitoring
and treatment costs would be spent over the next 10 years
and examines the feasibility of financing these costs.  The
chapter also examines the financial structure of the industry
and the availability of funding for the Incurred costs.
                            -23-

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     Chapter Seven examines the impact of the monitoring and
treatment costs both separately and cumulatively.  This
chapter shows the distribution of costs among the commercial,
industrial and private sectors.  The impact on both the
private (investor-owned)  sector and the public sector is
also explored, as are the cost effects on different-size
systems (by population served).

     Chapter Eight makes  explicit the major assumptions
underlying this study, explores them in some detail, and
discusses the units of their validity, with the objective of
bringing the overall analysis into perspective.

     Chapter Nine analyzes several alternative policy
decisions for implementing the Primary Drinking Water Regu-
lations.  The impact of these alternatives on costs, manpower,
and chemical constraints  is examined in this chapter.
                            -24-

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                      CHAPTER THREE


                THE WATER SUPPLY INDUSTRY
3.0  General Description

     The water supply industry, classified by the Department
of Commerce as SIC group 49*11, maintains facilities to
supply water primarily for domestic, commercial, and industrial
use.   This classification excludes facilities which provide
water for irrigation.  The present study deals with that
portion of SIC group 4941 providing water for general community
usage.

     The water supply industry produces more tons of finished
goods (approximately 85 million tons daily) than any other
U.S.  industry.  It is estimated that in 1970 public water
supplies delivered over 27 billion gallons of water per day
(bgd), of which about 63 percent was used for residential
purposes.!  iphe needs of public water utilities are expected
to increase to about 33.6 bgd by 1980.  As shown in Table 3-1
this  amount would be roughly 7-6 percent of all water used
in the U.S. at that date.   At the present time there are an
estimated 40,000 community water supply facilities In the
United States serving approximately 177 million people daily.
      C.R. Murray and E.B. Reeves, Estimated Water Use
in the U.S. - 1970, U.S. Geological Survey, Department
of the Interior, 1972.
                            -25-

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                        TABLE 3-1

          U.S.  TOTAL WATER USE 1970-1980  (mgd)'

USE CATEGORY
IRRIGATION
RURAL DOMESTIC
INDUSTRIAL &
MISCELLANEOUS
STEAM ELECTRIC
WATER UTILITIES
TOTAL
aThere are 0
Source: U.S
Water and Related
1970
119,180
4,340
55,950
120,800
27,030
327,300
.00379 m
% of
TOTAL
36.
1.
17-
36.
8.
100.
4
3
1
9
3
0
1980
135,
4,
75,
193,
33,
442,
850
850
030
030
600
360
% of
TOTAL
30.7
1.1
17.0
43.6
7.6
100.0
per gallon.
. Water Resources
Land Resources,"
Council, "
The Nation
The Nation'
' s Water
Resources (Washington,  D.C.:  U.S.  Gov't.  Printing  Office,  1968),
p. 1-18.
3.1  History

     Prior to the start of the 19th century, most water
supply and treatment activity in all parts of the world was
limited to individual applications of rudimentary purification
and clarification processes.  Filtered water was first
supplied to an entire town through pipelines in Glasgow,
Scotland in l80?.i

     In the United States the public water supply industry
is one of the oldest of industries, dating back to a wooden
conduit distribution system built in Boston, Massachusetts
during the mid-l600's.2  The first water distribution system
      J.W. Clark et al., Water Supply and Pollution Control,
International Textbook Co~. (Scranton, Pa. :   Haldon Craftsmen,
Inc., 1971).
     2
      American Water Works Association - Staff Report,  "The
Water Utility Industry In the United States," submitted to
the U.S. Congress, Joint Economic Committee, April 1966.
                             -26-

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to serve an entire town in the United States was constructed
in Pennsylvania almost a century later in 1746.^4  However,
water treatment did not receive wide scale attention until
after the Civil War.

     Public water service was not immediately accepted;
there were only about 16 public water systems in service in
the year 1800 (see Table 3-2).  Early Americans preferred to
take their water from nearby wells.  During the first half
of the 19th century the principal means of supplying water
to cities and towns shifted from pumping small volumes
manually from wells in the community to bringing in abundant
amounts of piped water from larger external sources.2
                        TABLE 3-2

            19th CENTURY WATER UTILITY GROWTH
               YEAR       NUMBER OF UTILITIES


               1800                16

               1825                32

               1850                83

               1875               422

               1890               598

               1900             1,013
               Source:  American Water Works
          Association - Staff Report, 1966.
       American Water Works Association - Staff Report, "The
Water Utility Industry," April, 1966.

      2G.M. Fair et al., Elements of Water Supply and
Wastewater Disposal (New York:  John Wiley and Sons, 1971).
                             -27-

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     The first municipal water purification plant built in
the United States was constructed in Virginia in 1832 and
was the forerunner of several hundred plants built during
the 1800!s.  The evolution of organized public systems in
the 19th century was closely related to the growth of cities
and towns around industrial developments.  Water system
management by private water companies became prevalent and
service was continually improved.  By the end of the
century publicly-operated water utilities were more numerous
and delivered an increasing volume of water to the growing
cities of America.  In 1900 about 22 million people were
being served by public water systems.1

     The development of water utilities during the past 75
years has paralleled that of other essential service
industries.  Water usage in the public water utility
industry for the period 1900-1980 is shown in Figure 3-1.
3.2  Organization

     Although the water supply industry provides a
universally essential product, it is an atypical industry
in many respects.  As it has expanded to keep pace first
with a geographically expanding agrarian society and then
with a growing, more densely populated urban industrial
society, a variety of water utility types has evolved. At
present the industry is composed of:

     1.   Pull service companies that develop,
          store, treat and distribute water;

     2.   Companies that develop water sources
          and maintain storage and treatment
          facilities, but do not own and/or
          manage distribution works;

     3.   Companies that are solely involved
          in the distribution of water supplies.

In many cases public water utilities operate as both full
and partial service companies.  In many regions large
metropolitan area utilities manage all aspects of water
supply to major population centers, and also sell water to
distribution companies servicing smaller, outlying cities
and towns.
      American Water Works Association - Staff Report, "The
Water Utility Industry," April 1966.
                            -28-

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35 -
30 -
25 '
20 -
15
10 -
                            WATER USE
                                      a
                    (billion gallons per day)
    POPULATION

(tens of millions)
 1900  1910  1920  1930   19^0  1950   I960   1970  1930
         There are 0.0037!
                    m
                            3
per gallon.
        Figure 3-1.  This graph illustrates public water
   utility water needs for the years 1900 to 1980.  (CRC
   Handbook of Environmental Control, vol. Ill:  Water
   Supply & Treatment, 1973, P- 131.)  (Population data
   from:  Social Indicators 1973? Office of Management
   and Budget, 1973, p. 233-)
                           -29-

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     Larger metropolitan area water utilities are able to
take advantage of economies of scale in meeting the costs of
facility maintenance, developing new sources to meet growing
demands, and constructing additional treatment facilities.
Smaller public water systems are limited in their ability to
adjust to rising capital needs, so that the consolidation of
smaller utilities into larger water districts or their
outright absorption into larger utilities may occur.  This
is not attributable to market competition between companies
of varying size serving contiguous communities, but is
rather the result of non-competing water utilities adapting
to changing economies of operation by altering management
structures.  For public water systems, the responsibility to
provide wholesome water overrides any regional or local
competitiveness which might exist.
3. 3  Customers

     Water supply systems provide water service for resi-
dential, commerical, industrial and general municipal
purposes.  An approximate allocation of the water supplied
by water utilities to the various categories of users is
shown in Table 3-3-


                        TABLE 3-3

         COMMUNITY WATER SUPPLY USE BY CATEGORY
        TYPE OP USE              PERCENT OF TOTAL


        Residential                    63
        Commercial                     11

        Industrial                     21

        Municipal                       5


        TOTAL                         100


             Source:  U.S. Geological Survey
        estimates, 1972.
     Residential water usage Includes drinking, cooking,
bathing, flushing, cooling, washing, laundering, and lawn
sprinkling.  Water Is supplied to commercial businesses  such
                              -30-

-------
as restaurants, motels, hotels, laundries, florists, etc., for
the same general purposes.  Water supplied by public utilities
is used in all types of industry for both sanitary and
process-related service, and especially in smaller factories
or industries unable to develop and maintain their own water
supplies.  One of the prime considerations in a community's
industrial development is its ability to supply adequate
amounts of water for process and other needs of a variety of
industries.

     The category of general municipal service includes the
public use of water for sprinkling, swimming pools, fountains,
public buildings and fire-fighting.  The provision of fire
protection service represents a major portion of the invest-
ment in water works facilities, especially for smaller
utilities.  The general policy of the American Water Works
Association, an industry trade organization, is that supply
water must (1) be free of undesirable taste, odor, color,
turbidity and corrosiveness; (2) be supplied in quantities
sufficient to ensure sanitary and fire protection service;
(3) be available on an uninterrupted basis without system
pressure fluctuations; and (4) be safe for public consumption.
3•4  Community Water Systems

     Community water systems and public non-community water
systems are treated separately due to the great disparity
between the amount of data available for the two types.

     The Proposed Interim Primary Drinking Water Regulations
define the term "public water system" as a system for the
provision to the public of piped water for human consumption,
if such a system has at least 15 service connections or
regularly serves an average of at least 25 individuals daily,
at least three months out of the year.  The term "community
water system" is defined as a public water system which
serves a population of which 70 percent or greater are
residents.  Table 3-4 synopsizes the information available
on community water supply systems.

     The first issue to be examined concerning community
water supply systems is the number of systems which fall
under the Environmental Protection Agency's definition.  Two
studies which have broadly addressed this issue are the
ongoing Environmental Protection Agency Community Water
Supply Inventory and the 1974 National Sanitation Foundation
(NSP) Report entitled Staffing and Budgetary Guidelines for
State Drinking Water Supply Agencies.
                              -31-

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                           TABLE 3-
              AVAILABLE INFORMATION ON COMMUNITY
                     WATER SUPPLY SYSTEMS
                   NUMBER    QUANTI-  QUALI-
     SOURCE OP   OF SYSTEMS  TATIVE   TATIVE  FINANCIAL TREATMENT
    INFORMATION   IN STUDY    DATA     DATA     DATA      DATA
1.   EPA Community
    Water Supply   39,277J
    Inventory

2.   CWSS of 1969      969

3.   EPA Interstate
    Carrier Water     730
    Supplies (1975)

4.   10 EPA-State
    Water Quality     397
    Evaluations

5.   1970 AWWA
    Statistical       768
    Report

6.   National
    Santitation    49,166
    Foundation
    1974 Report
X
X
X
X
X
X
X
X
X
X
         X
                   X
X
          X
          X
          X
    a
     As of July 15,  1975.
                              -32-

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     The results of these two studies (and a 1975 ERGO
study) are shown in Table 3-5.  The data for the NSF report
were obtained from a survey done in January 1974; 42 states
provided data at that time.  The data on Table 3-5 show that
at present there is no clear breakdown of the number of
community water systems in the nation.  The differences
between the NSF, EPA and ERGO numbers can be explained by
differences in the definitions of a community system employed.
The National Sanitation Foundation report defines a community
water supply system as a public system that provides water
to 10 or more premises not owned or controlled by the supplier
of water or to 40 or more resident individuals.  The ERGO
survey of all 50 states (Appendix B) found that many states
which supplied information to the EPA inventory used defi-
nitions of a community supply which were markedly different
than that given in the Proposed Interim Primary Regulations.
For the purpose of this report, ERGO uses the EPA estimate
of 40,000 community water supply systems as a valid approxi-
mation, although it is quite possible that the EPA will
raise this number when all states adopt the same definition
of a community system.

     Given the estimated 40,000 community systems in the
United States, it is important to characterize the systems
by different variables, since the interim regulations mandate
different monitoring practices depending on the water source
and size of population served.  Table 3-6 separates the EPA
community inventory of water systems, the 1969 Community
Water Supply Systems study (CWSS), the EPA Interstate
Carrier Water Supply survey, the 1970 American Water Works
Statistical Report (AWWA), and the 10 EPA-State water quality
evaluations by the percentage of systems in each population
class.  Table 3-7 breaks the results of these same five
studies into categories based on the percentage of systems
which draw water from either surface3 ground,  mixed,  or
purchased sources.  A final method of distinguishing water
supplies Is by current degree of treatment.  Table 3-8 shows
the percentage of systems which utilize one or more of the
following treatment processes:  aeration, prechlorination,
coagulation, sedimentation, filtration, softening, taste and
odor control, iron removal, ammoniation, fluoride adjustment,
and disinfection.

     For the purpose of this study the ongoing EPA Inventory
of Community Water Supplies is considered to be representative
of the nation as a whole with regard to population served,
treatment facilities, and source of water.
                               •33-

-------
                                   TABLE 3-5
              NUMBERS  OP COMMUNITY WATER  SUPPLY SYSTEMS BY STATE
1974 NSFS STUDY ONGOING EPAb INVENTORY 1975 ERGO SURVEY
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
305
69
1,000
500
3_,200
700
395
139

1,800
3,184
50
274
1,571
550
1,465
669
500
500
200
316
380
1,974
680
2,100
913
221
500
93
325
650
353
2,000
2,387
245
1,765
600
590
5,000
50
920
250
520
3,700
408
350
1,400
1,500
1,000
600
107
489
231
442
461
3,035
561
449
143
8
690
2,099
82
345
1,063
959
929
558
462
554
307
314
419
1,606
527
571
1,243
168
456
201
335
534
116
1,150
2,389
99
3.379
789
479
2,439
110
900
180
454
1,862
268
301
1,088
1,622
633
722
56


1,912

4,100






125
945
1,620
463
822
830


170
810

2,216




460


496
370

2,707
257
1,652
860

4.375
52



6,900
665
371

1,600


4l8
TOTAL 49,166 39,277
      mtional Sanitation Foundation Report,  Staffing and Budgetary Guidelines
for State Drinking Water Agencies,  1974.

     This data is based on inventory as of July 15,  1975 and is  currently
being updated.

     No entry indicates lack of response.

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                               TABLE  3-6
               BREAKDOWN  OP  FIVE  COMMUNITY  WATER  SURVEYS
BY PERCENTAGE^ OP SYSTEMS
IN EACH
OF NINE POPULATION CATEGORIES

EPA
POPULATION COMMUNITY
RANGE INVENTORY
25-99 17-5
100-499 37.8
500-999 13.5
1,000-2,499 12.9
2,500-4,999 6.5
5,000-9,999 4.6
10,000-99,999 6.5
100,000-999,999 0.6
>1, 000, 000 <0.1
TOTAL 100.0




1975 EPA
1969 INTERSTATE
CWSS CARRIER
12.
31.
11.
14.
8.
8.
11.
2.
0.
100.
2
1
1
2
8
6
5
4
1
0
0.
2.
1.
3.
5.
8.
47-
27.
2.
100.
8
4
7
8
2
4
7
8
2
0


10
EPA-STATE
STUDIES
3.
23-
12.
14.
12.
7.
23.
7.
0
100.
9
3
1
8
6
6
3
2

0


1970
AWWA
0.
0
0
0
0
0
77.
20.
1.
100.
1





8
2
9
0
    aBased on percentages  of systems  reporting a population  of
25 or greater.
                                   -35-

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                    TABLE  3-7
PERCENTAGE OF COMMUNITY WATER SYSTEMS WHICH UTILIZE
EACH
OF FOUR SOURCES OF
WATER FOR FIVE STUDIES

SOURCE OP
WATER
Grounda
Surface13
Mixed0
Purchased
TOTAL
EPA
COMMUNITY 1969
INVENTORY CWSS
78.2 75.2
11.5 21.6
3.4 3.2
6.9
100.0 100.0
EPA
INTERSTATE
CARRIER
29-9
48.3
15-6
6.2
100.0
10 EPA-
STATE
STUDIES
60.5
32.6
4.3
2.5
99.9
1970
AWWA
40.4
34.7
14.9
10.0
100.0
  Q
  Includes ground  and  (ground and purchased).


  Includes surface and  (surface and purchased).
   Includes ground and surface and  (ground  and
   e  and purchased).

   Includes purchased only.
                         -36-

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                       TABLE 3-(
          PERCENTAGE OF TREATMENT PROCESSES'

TREATMENT
Aeration
Prechlorination
Coagulation
Sedimentation
Filtration
Softening
Taste and
Odor Control
Iron Removal
Ammoniation
Fluoride Adjustment
Disinfection
EPA
COMMUNITY
INVENTORY
6.6
7.8
11.3
8.9
12.8
4.9
3-4

5-7
0-9
8.5
49.7
1969
cwss
6.
10.
11.
10.
14.
11.
3.

-
0.
4.
40.
2
7
4b
0
2
4b
4


2
9
3
10 EPA-
STATE
STUDIES
4
3
12
13
13
4
2

0
0
7
24
.8
.8
.6
.1
.7
.1
.5

.8
.2
.7
.2
1970
AWWA
-
-
46.3
-
53.0
18.1
36.2

24.5
-
42.9
77.2
     a.
      Percentages are not additive since some systems have
multiple treatments and many systems have no treatment.
     b
      11.4 is total for Coagulation + Softening.
                             -37-

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3.5  Production

     The regional variation in production per capita is
shown in Table 3-9.   This table illustrates the tremendous
variation in per capita daily production reported in each of
the 10 EPA regions.   The number of plants and total daily
production for six size categories are shown in Table 3-10.
This table shows that while 68 percent of the systems are in
the two smallest categories, they contribute only 2.1 percent
of total water production.   In contrast, the largest 1.2
percent of the systems provide almost 62 percent of the
total national community water production.


                     TABLE 3-9

          AVERAGE DAILY U.S. WATER PRODUCTION
                PER CAPITA BY EPA REGION
                              AVERAGE PRODUCTION
          REGION             PER CAPITA (gal/day)a
I
II
III
IV
V
VI
VII
VIII
IX
X
145
159
155
155
176
180
144
219
168
202
              aThere are 0.00378 m3 per gallon,
3•6  Ownership

     Table 3-11 lists the 1970 production figures for
publicly-owned water supply systems by size and treatment
category.  The distribution of production by privately-owned
systems, listed by treatment and size is displayed In Table
3-12.

     Of the 40,000 community systems presently supplying
water, the data indicate that 58 percent are publicly owned
and that 42 percent are privately (investor-) owned.
                              -38-

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                                 TABLE 3-10
                NUMBER OP SYSTEMS AND TOTAL DAILY PRODUCTION
FOR SEVEN PRODUCTION



COMMUNITY
PRODUCTION CATEGORY
(Millions of Gallons Per Day)a NUMBER
<.01
.01-0.1
0.1-1.0
uj 1.0-10.0
VD
1
10. 0-30.0
30.0-50.0
>50. 0
TOTAL
8,875
18,331
9,300
3,036
325
69
64
40,000

CATEGORIES

SYSTEMS
% OP
TOTAL
22
45
23
7
0
0
0
100
.2
.8
.2
.6
.8
.2
.2
.0



PRODUCTION
MILLIONS OF % OF
GALLONS PER DAY TOTAL
43
624
2,957
8,608
5,477
2,232
11,958
31,899
0
2
9
27
17
7
37
100
.1
.0
.1
.0
.2
.0
.6
.0
aThere are 0.00378 m3 per gallon.

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                                           TABLE 3-11
                          PUBLICLY-OWNED WATER SYSTEM PRODUCTION (mgd);
                                 BY SIZE AND TREATMENT TYPE
o
I
             SIZE
Very Small
<0.1 mgd

Small
0.1-10 mgd

Medium
10-30 mgd

Large
>30 mgd
          TOTAL
                TREATED WATER
                      NON-TREATED WATER
  TOTAL
   224  (5,9^6)


 7,321  (7,256)


 3,564    (211)


12,133     (97)
                                       b
                                                 192  (6,420)
416  (12,366)
                                               2,740  (3,252)       10,061  (10,508)
                                               1,007     (6l)        4,571     (272)
                                                 964     (17)       13,097     (114)
              23,242 (13,510)        4,902  (9,750)       28,145  (23,260)
               aThere are 0.00378 m3 per gallon.
                Numbers In parentheses indicate number of plants in each category.

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                                 TABLE 3-12
               PRIVATELY-OWNED WATER SYSTEM' PRODUCTION (mgd);
                        BY SIZE AND TREATMENT TYPE
  SIZE
 TREATED WATER
NON-TREATED WATER
                TOTAL
Very Small
<0.1 mgd

Small
0.1-10 mgd

Medium
10-30 mgd

Large
>30 mgd
   81  (3,301)
                             b
1,028  (1,201)
  769     (36
1,017     (45)
  171  (11,585)
  4i8     (627)
  137      (19)
   77
(2)
  252  (14,i

1,446   (1,828)

  906      (55)

1,094      (47)
TOTAL
2,895  (4,583)
  803  (12,233
            3,698   (16,816)
     aThere are 0.00378 m3 per gallon.
      Numbers in parentheses Indicate number of plants in each category.

-------
     As can be deduced from Tables 3-H and 3-12, 88 percent
of the production Is from publicly-owned systems, with
private (investor-owned) systems contributing about 12
percent.  Investor-owned utilities are self-supporting
enterprises, while public supplies may be either self-
supporting or tax-supported.  Because of greater risk and
the lack of tax-exempt status, the investor-owned companies
have a higher cost of capital.  Thus, they generally charge
higher rates per unit than municipal systems (Figure 3-2).



3.7  Public Non-Community Water Supply Systems

     In general there Is very little information on the
estimated  200,000 public non-community water systems.  Ihis
section summarizes the information available on those  _
supply  systems which  serve  drinking water to the transient
public.  These systems are  found at service stations,
motels, restaurants,  rest areas, campgrounds, state parks,
beaches, national parks, national forests, dams, reservoirs,
and  other  locations daily frequented by the travelling
public.   (Appendix  C  gives  an estimated breakdown of these
200,000 systems by  use  category and population  served.)

      Table 3-13,  Column  1,  shows estimates of the number  of
public  non-community  water  supply systems in each  state as
presented  in  a National  Sanitation Foundation study.1  The
information was  obtained from the following  sources:

      1.    An  NSF  survey  by  questionnaire to  each  state
           In  January  1974.   Forty-two  states responded.
           Some of these  states  gave  no estimate of
           the number  of "Other  Systems."

      2.    An  EPA  Regional  Office  survey by direct
           contact with the  states  in each  region
           in  1970.

      3.    A Conference of  State Sanitary Engineers
           survey conducted with the  assistance  of EPA
           in  January 1973.   Twenty-six states  responded.

      4.    A 1974 NSF estimate of "Other Systems" in
           the seven states which did not respond to
       National Sanitation Foundation, Staffing and Budgetary
 Guidelines for State Drinking Water Supply Agencies (Ann
 Arbor, Michigan, 1974).
                                -42-

-------
  UlO -



  1.30 -



  1.20 -



  1.10



  1.00



    • 90
cti
o
o
o
w
o
CL,

EH
H
S
D
    70



    60
JlO



.30



.20 -



.10



              SHALL
           0,1-10 mgd
              PUBLIC SYSTEMS
              PRIVATE SYSTEMS
                            MEDIUM

                             10-30 mgd
 LARGE
>30 mgd
             a
              There are  0.00378 m3 per  gallon.
              Figure 3-2.  This  figure  shows  the  unit  price  of
         water  inct/1,000 gallons.
                               -43-

-------
                        TABLE  3-13

         ESTIMATED  NUMBER OF  PUBLIC NON-COMMUNITY
WATER SUPPLY SYSTEMS BY
POPULATION
(x!03)
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
VEST VIRGINIA
WISCONSIN
WYOMING
3,444
300
1,770
1^923
19,953
2,207
3,031
548

6,789
4,589
768
712
11,113
5,193
2,824
2,246
3,218
3,641
992
3,992
5,889
8,875
3,804
2,216
4,676
894
I>W1
488
737
7,168
1,016
18,236
5,082
617
10,652
2,559
2,091
11,793
946
2,590
665
3,923
11,196
1,059
444
4,648
3,409
1,744
4,417
332
COLUMN 1
NUMBER
20,000
800
800
1,350
1,900
1,300
1,200
401

2,716
1,394
9
285
1,026
10,185
615
900
2,100
2,000
2,450
1,569
2,276
15,731
2,675
330
8,100
1,700
1,050
779
1,700
5,200
2,000
36,000
4,833
250
20,000
1,000
9,510
23,945
60
1,552
270
1,500
2,100
420
3,300
9,375
2,500
18,010
18,010
600
STATE
COLUMN 2
DATA SOURCE NO. (ERGO SURVEY)

CSSE
CSSE



NSF est


NSF est


NSF est



NSF est



NSF est
NSF est












NFS est





CSSE



CSSE


CSSE


CSSE

N-
N

3,000
N
.


5,000
1,000
N
1,053
4^600
10,000
N
1,220
N

N
4,100
N
16,010



N
N


N
N
N
N
N
19,100
4,000

11,800
N
1,378


10,150
505
3,100
9,400
2,050
210

426
TOTAL
230,387
N is not knowr\
No entry Indicates lack of response.
                           -44-

-------
          any of the above.   This estimate was made
          by assuming one system for each 2,500
          population.  The 2 ,,500 factor was arrived
          at by taking the number of "Other Systems"
          reported for each state in the 1974 NSF
          survey, dividing it into the total population
          for that state, and then averaging the results.

     Because the NSF survey was made in 1974, data from that
questionnaire are used whenever they were available.

     In addition, the results of a survey by ERGO in April
1975 pertinent to this category of public water supply
systems is provided in Column 2 (see Appendix D for the ERGO
survey).   It becomes quite evident upon inspection of this
table (particularly Texas) that accurate data on the number
of non-community public water supply systems have not been
compiled and more extensive state-by-state investigations
will be necessary in this area.

     Table 3-l4 gives a breakdown by source of water for
those systems where extensive data on water quality and
system usage are available,  while Table 3-15 provides a
breakdown by source of water of systems found in the ERGO
state survey.  At the present time, the National Park
Service is completing a national survey of all drinking
water systems maintained by that service; however, it will
be several months before the results of this study are
known.  Until the completion of the Park Service study, this
sparse sample contains the only data which can be utilized
to project national cost trends for the estimated 200,000
systems serving the travelling public.
                              -45-

-------
                             TABLE 3-14




              SOURCE OF WATER FOR 11 STUDIES OF PUBLIC
NON-COMMUNITY WATER SYSTEMS*





SOURCE OF WATER
STUDY
Bureau of
Reclamation
Water Resource
Q
Interstate
Park Service
g
Forest Service
f
Kansas Evaluation
2
Florida Evaluation
Kentucky Evaluation
Tennessee Evaluation
Georgia Evaluation-3
Wyoming Evaluation
TOTAL
SURFACE
28
11
0
6
26
0
0
9
0
0
1
81
GROUND
25
45
114
36
93
37
78
50
64
81
12
635
PURCHASED
5
0
5
0
0
3
0
0
0
0
0
13
TOTAL
58
56
119
42
119
40
78
59
64
81
13
729
*See following page for references.

-------
     Q
      U.S. Environmental Protection Agency. Water Supply Division, A Pilot Study of
Drinking Water Systems at Bureau of Reclamation Developments, EPA-^30/9-73-004,  June 1973

      U.S. Environmental Protection Agency, Office of Water Programs, Sanitary Survey
Of Drinking Water Systems on Federal Water Resource Developments, A Pilot Study,
August 1971.

     CU.S. Environmental Protection Agency, Water Supply Division, Drinking Water
Systems On and Along the National System of Interstate and Defense Highways, A Pilot
Study, 1972.

      U.S. Environmental Protection Agency, Water Supply Division, A Pilot Study of
Drinking Water Systems in the National Park Service System, EPA-520/9-74-016,
December 1974.

      U.S. Environmental Protection Agency, Water Supply Division, A Pilot Study of
Drinking Water Systems in the U.S. Forest Service System, November 1974 -

      U.S. Environmental Protection Agency, Region VII, Water Supply Program,  Evaluation
of the Kansas Water Supply Program, 1972.

     °U.S. Environmental Protection Agency, Region IV, Water Supply Branch, Evaluation
of the Florida Water Supply Program, 1973-

      U.S. Environmental Protection Agency, Region IV, Bureau of Water Hygiene,
Evaluation of the Kentucky Water Supply Program, May 1972.

     1U.S. Environmental Protection Agency, Region IV, Bureau of Water Hygiene,
Evaluation of the Tennessee Water Supply Program, January 1971-

     ^U.S. Environmental Protection Agency, Region IV, Water Supply Branch, Evaluation
of the Georgia Water Supply Program, July 1973-

      U.S. Environmental Protection Agency, Region VIII, Water Supply Branch,
Evaluation of the Wyoming Water Supply Program, December 1972.

-------
                         TABLE 3-15
        NUMBER OF  NON-COMMUNITY SYSTEMS  BY SOURCE
                    SURFACE WATER
                 GROUND WATER
ALABAMA
ALASKA
ARIZONA
ARKANSAS •
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OP COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
• KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
. WISCONSIN
WYOMING

N
N

N
N
N


N
0
N
175
100
N
N
20
N

N
2
N
10



N
0

N
N
N
N
N
N
100
0

0
N
25
2

150
5
100
0
50
N

16

N
N

N
95
N


N
100
N
878
4,SOO
10,000
N
1,200
N

N
4,100
N
16,000



N
N


N
N
N
N
N
19,000
4.000

11,800
N
' 1,^^
600

] 0,000
ROO
^non
q,4oo
2,000
200

410
TOTALS
758
N is not known.
No entry indicates  lack of response
99,136
                         -48-

-------
                      CHAPTER POUR


                  DEVELOPMENT OF COSTS
4. 0  Introduction

     This chapter develops the projected national monitoring
and treatment costs of the proposed regulations.   The first
section in this chapter develops all of the monitoring costs
which would ensue from the implementation of the Proposed
Interim Primary Drinking Water Regulations.  The total
monitoring costs are developed from the following six
components:

     1.   Routine monitoring costs incurred by
          community water systems;

     2.   Costs incurred by community systems when
          maximum allowable limits are exceeded;

     3.   Costs incurred by community systems when
          the contaminant level is 75 percent or more
          of the maximum contaminant level;

     4.   Routine monitoring costs incurred by
          public water systems other than community
          systems;

     5.   Costs incurred by public non-community
          systems when maximum allowable limits
          are exceeded;

     6-.   Costs incurred by public non-community
          systems when the contaminant level is 75
          percent or more of the maximum contaminant
          level.

     The analysis of monitoring costs shows that systems
serving small populations vastly outnumber larger systems,
and therefore assume the greatest share of monitoring costs
while serving a very small percentage of the population.
Figure 4-1 shows that 50 percent of the monitoring costs
will be borne by 9 percent of the population, an indica-
tion that the costs of monitoring might be a burden on many
of these smaller systems, and that some consideration ought to
be given to decreasing their monitoring requirements.
                             -49-

-------



w
p
CO
0
o
bO
£
•H
0
P
•H
£
O
s
H
cd
P
0
EH
O
P
CD
O
?H
CD
P-i
100-
90-
80-



70-


60-



50-


40-


30-

20 •




                   Population
                      Served
                                        Water
                                    Supply Systems
10
 0
       10   20    30    40    50    60    70   80   90   100

Percent of Population Served by Community Water Systems

            Percent  of Water Supply Systems
     Figure 4-1.  This figure shows the percentages of
total monitoring costs in the United States versus the
percentages of population served and the percentages of
the water supply systems.
                       -50-

-------
     The second section in this chapter deals with treatment
costs.   Total treatment costs are developed from the following
two components:

     1.    Treatment costs to be incurred by community
          water supply systems, grouped by treatment
          process and population size;

     2.    Treatment costs to be incurred by public
          non-community water supply systems, grouped
          by treatment process.

     The analysis of treatment costs shows that operation
and maintenance (O&M) and capital costs are spread equitably
over the entire population served (Figure 4-2).  The total
capital costs for treatment would range between $1.1 and
$1.8 billion spread over a 5-year period, while the O&M
treatment costs would rise until an annual rate of $264
million was reached.
4.1  Monitoring Costs for Community Water Systems

     This section develops the anticipated costs of chemical
and biological monitoring for the estimated 40,000 community
water systems in the United States.  The Proposed Interim
Primary Drinking Water Regulations (Federal Register, March
14, 1975)3 were used to establish monitoring frequencies in
formulating these estimates.   These regulations are synop-
sized in Table 4-1.  Table 4-2 shows a breakdown of water
systems by population served and by source of water.

     The proposed regulations call for the monitoring of
four classes of contamination:  inorganic, organic, micro-
biological, and turbidity.  Turbidity monitoring is not
considered since this test must be done on-site and requires
only manpower and a relatively inexpensive turbidimeter.
(The manpower required for turbidity monitoring is considered
in Chapter Five.)  The monitoring frequencies for organics
and inorganics depend on whether a given system derives its
water from surface or ground sources.  The numbers of systems
estimated to be in these two categories are shown in Table
4-2.  The sampling requirement for coliform and plate count
monitoring depends on the size of the community served.
                             -51-

-------
I
U1
r\j
I
                                     Percent of Water
                                      Supply Systems
      co 100-,
  -P
  w

  CO

W >}
-P rH
W a
O &
O 3
  CO
rH
OJ !H
-P CD
O -P
^ Cti

On
O H
  Cti
-P -P
S O
0 EH
O
PH CM
CD O

  -P
  C
  CD
  O
  in
  CD
         80 -
         60 -
         20-
                                                                                          100
                       Percent  of Population Served by  Community Water Systems
                  Figure 4-2.  This figure  shows  the percentages of  population served by
             community water systems versus  percentages of total treatment costs.

-------
                                                          OF  MONITORING  REQUIREMENTS  (EXCE?^ TURBIDITY)
 I
un
uo
 I
SUBSTANCE
Arsenic
Barium
Cad.T.ium
Chromium
Cyanide
Lead
Mercury
Nitrate
Selenium
Silver
Fluoride
Total Organic
Chlordar.e
Endrin
Heptachlcr
Heptachlor Epoxide
Linaane
Methoxychlor
Toxaphene
2,^-D
2,^,5-TP Silvex
CoUfcrm
(Membrane filter)
Coliform
(Fermentation
tube)

Ccllform
(Residual
chlorine)
Standard Plate
Count
y-AXIMUM LEVEL REFERENCE METHCDa
0.05
1.0
0.010
0.05
0.2
0.05
0.002
10.
0.01
0.05
l.H - 2.1)
0.7
0.003
0.0002
0.0001
0.0001
O.OQl)
0.1
0.005
0.1 =
0.01
Av. 1 per
Max. t per
EPA 19714 pp. 95-96
SMWW pp. 210-215
SMWW PP- 210-215
SMWW PP- 210-215
EPA 19711 PP. 110-1)8
SMWW PP- 210-215
EPA 1971) pp. 118-26
SMWW 213 pp. 1)61-1)61)
EPA 1974 PP. ItS
SMWW pp. 210-215
SKV.-W pp. 172-17t
JAWWA 65: 57, 197 (1973)-



EPA 1973



I EPA 1973A
I
.00 :.il SMWW pp. 662-688
100 ml
Max. 10? pos.: SMWW pp. 661-662
10 ml samples
Max. 60? pos . :
100
ml samples
Win. 0.2 rag/1 SMWW pp. 120-132




Max. 500 orgs./ml SMWW pp. 660-662


MONITORING FREQUENCY
Community system supplied by surface water: initial
tests to be performed within one year and repeated
at yearly intervals.
Ccr.-L.nity system supplied by croi.ncwater : ir.itiil
tests v;lt'r:in two years, then repeated at three year
Intervals .
Transient system: initial test within six years,
then repeated at five year intervals.
Any component whose level exceeds 75? of maximum
must be retested at one r.onth intervals. These
retests may be suspended if level remains below
maximum for one year. Any component whose level
exceeds maximum must be retested within 21, hours
then weekly until level falls below maximum.

Community system supplied by surface water: initial
intervals .
Community system supplied by ground water: initial
test within two years, then repeated at three year
intervals .
Transient system: initial test within six years,
then repeated at five year intervals.
Any component exceeding 75? or 100% of maximum to
be retested as for inorganics.



Dumber of sample:; «;o tc tested per rr.or.th b^;ed on
number of customers served. Either membrane filter
or fermentation tube technique may be used. Sources
of non-compliant samples must be retested daily
until compliance achieved.

Daily or more frequent (depending on nuir.ber of
customers served) if substituted for either of the
direct conform methods.
At least equal to 10? of coliform frequency with a
minimum of 1 per month.
                          Abbreviations  for  references:
                           JAV.'WA  =  Journal of  the  American  Water Works  Association
                           SMWW   =  Standards Methods  for  the  Examination  of  Water and  Wastev.-ater,  13th edition,  1971.
                           EPA 1973 =  Methods  for  Determining Organic  Pesticides in  Water and  Wastewater,  EPA,  Cincinnati,  Ohio, 1971.
                           EPA 197t =  Methods  for  Chemical  Analysis  of  Water and Wastes,  EPA,  Office  of Technology Transfer
                                       Washington,  D.C., 1971).
                           EPA 1973A = Method  for  Organochlorine Pesticides  in Industrial Effluents,  MDQARL,  EPA,  Cincinnati,
                                       Ohio, 1973-

-------
                                 TABLE 4-2
               DISTRIBUTION OP COMMUNITY WATER SYSTEMS BY
POPULATION CLASS AND SOURCE OP WATERa




SOURCE OP WATER (NO. OP
POPULATION SURFACE GROUND MIXED
25-99
100-499
500-999
1,000-2,499
f 2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1, 000, 000
TOTAL 4
275
946
548
857
625
468
767
108
5
,599
6,361
12,947
4,278
3,690
1,607
1,079
1,243
63
0
31,268
56
199
144
28l
189
169
274
52
2
1,366

SYSTEMS)
PURCHASED
316
1,021
422
354
184
142
315
13
0
2,767


TOTAL
NUMBER OF POPULATION
SYSTEMS SERVED
7,008
15,113
5,392
5,182
2,605
1,858
2,599
236
7
40,000
420,500
3,778,250
3,774,400
7,773,000
8,857,000
12,634,400
61,423,400
57,277,200
21,523,600
177,470,750

PER CAPITA
DAILY
PRODUCTION
(GAL.)b
99
109
118
132
140
154
158
174
192
165
a
 Based on EPA Survey of Community Water Supplies, as of July 15, 1975.



bThere are 0.00378 m^ per gallon.

-------
     Laboratory costs were obtained in the following three ways

     1.   A telephone survey of commercial laboratories
          in six states.  This sample was further
          augmented by a follow-up written survey of
          commercial laboratories.  The results of this
          survey are listed in Table 4-3;

     2.   A telephone survey of analytical costs
          estimated by the Environmental Protection
          Agency's Water Supply Research Laboratory in
          Cincinnati, Ohio (Tables 4-4, 4-5, and 4-6);

     3-   A survey of 207 plants which had failed at
          least one of the proposed mandatory regulations
          during the 1969 CWSS study.  Of the
          114 respondents to this survey, 23 used
          commercial laboratories for the analysis of
          their water samples (Appendix D).  The rates
          charged these 23 supply systems were comparable
          with those found in Table 4-3.

     According to EPA manpower data (Table 4-4), it would take
approximately 5-1 hours for one man to do a complete inorganic
sample (11 components).  This means that one man can do
approximately 32 complete analyses per month.  If commercial
overhead and G&A rates are applied, then the monthly cost for
inorganic analyses is $4,025, or approximately $125 for a
complete inorganic analysis (Table 4-5).  For bacteriological
analysis (Table 4-6) the monthly cost is $3,512 or $4.38 per
sample.  This $4.38 is exclusive of the cost of collecting
and shipping samples to the laboratory.  These figures are
thus consistent with the range of commercial quotes ($5 to
$20) for these same analyses as shown in Table 4-3-  In
determining government costs, overhead and G&A rates are not
applicable; thus, the government cost for a complete inorganic
analysis is approximately $78 and the cost for a bacterio-
logical analysis is $2.63 exclusive of shipping costs.

     In developing national monitoring cost estimates, the
number of systems requiring routine monitoring is fixed by
the number of ground- and surface-water supply systems in
each size category (Table 4-2) and the monitoring frequency
prescribed by the Regulations (Appendix A).  Therefore, the
only variable in the cost development Is the price per
analysis.  This price Is dependent on the institutional
monitoring arrangements made by each system.  Iri this study,
the lower monitoring cost is represented by the cost which
EPA would incur in its laboratories, and the higher monitoring
cost was calculated from the cost which would be charged by
moderately expensive commercial laboratories.
                           -55-

-------
                                       TABLE  4-3

       ANALYSIS  OP  DRINKING  WATER  SAMPLES:  TYPICAL  CHARGES
BY COMMERCIAL LABORATORIES FOR
ANALYSES
SPECIFIED IN REGULATIONS

LABORATORY :
LOCATION (STATE):
Gross Alpha and Beta
Sf.rontium-89 and 90
Tritium
Iodine-131
Cesium-134 and 137
Potassium-40
Coliform (Membrane filter)
(Fermentation tube)
Plate Count
Total Organic
Chlorinated Hydrocarbons
Or ganophosp hates
Chlorophenoxys
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nitrate
Selenium •
Silver
Fluoride
Inorganics All Components
A
RI
_
_




$20
20
10


210

28
15
10
10
15
10
20
10
55
10
12
195
Ba
FL
_
-
_
_
_
-
$10
_
10
35-50
45e
45e
45e
20
10
15
10
15
10
15
5
20
15
15
155
C
MA

-
-
-

-
$20

20
50
10
40
l|0
12-20
12-20
12-20
12-20
15-25
12-20
12-20
15-25
12-20
12-20
15-25
150-250
D
MA
$15

-
-
-

15, 10, 8d
20, 15, 10d
10, 6, 5d
_
75 75
-75 75
-75 75
15, 10K
15, 10s
15, 10S
15, 10*
35, 15g
15, 10E
20, 15g
15, 12.50g
15, ing
15, 10g
10, 85
185, 120. 50S
Eb F° Ci
NJ NM NJ
$20 $12
80 45
15-20 10
S5
55, 80 65
10
_
_ _
-
$25
, 125f
, 125f -
, 100f
10
15
15
15
35
15
40
23
In
15
23
276

RANGE
$12-20
45-80
10-20

65-155

8-20
10-20
5-20
25-50
40-305
40-180
40-80
10-40
10-20
10-20
10-20
15-35
10-20
12-40
5-25
10-55
10-20
8-25
120-276
 A 5  percent discount on bills over $500.
 A 10 percent discount on bills over $1,000.
 A 15 percent discpunt on bills over $1,500.

 A 30 percent discount for six or more samples.

°Up to 20 percent discount available.

 Highest price is for single sample; middle for 2-10 samples;  lowest for  11 or more  samples.

 Price for scan plus one component analysis.  Price for each additional component is $45.
f
 Higher price is for full analysis; lower  price is for analysis of one specified component.

EHigher price is for single sample; lower  for 2-10 samples.
                                        -56-

-------
                        TABLE 4-4
 NUMBERS OF ANALYSES PER MAN-MONTH FOR SOME COMPONENTS
     OF PROPOSED INTERIM DRINKING WATER REGULATIONS51
COMPONENT
NUMBER OP ANALYSES
TIME FOR ANALYSIS.
   ("man-hours)
ORGANIC SUBSTANCES
Total Organic (CCE)
Chlorinated Hydrocarbons
and Herbicides
TOTAL ORGANIC
INORGANIC SUBSTANCES
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Nitrate
Selenium
Silver
Fluoride
Mercury
TOTAL INORGANIC
60
18
14
400
600
200
600
200
200
600
400
600
600
400
32
2
8
11
0
0
0
0
0
0
0
0
0
0
0
5
.7
.9
.6
.4
.3
.8
-3
.8
.8
.3
.4
-3
.3
.4
.1
     aPersonal communication E. McFarren, EPA, Cincinnati,
Ohio,  June 1975-
                          -57-

-------
                       TABLE 4-5


     MONTHLY BUDGET FOR ANALYSIS OF INORGANIC SAMPLES


7	;	• •-' •	•	'	


Salary                                            $1,000.00

Salary Overhead (100$ of salary)                   1,000.00

Equipment Charge3"                                  l,000.00b

Expendable Supplies                                  500.00
Total Direct Cost                                 $3,500.00
General and Administrative                           525.00
Total Cost                                        $4,025-00
Average Sample Cost0                              $  125.78
     Q
      Equipment includes two atomic absorption spectrometers,
one equipped with a hydride generator, a cold vapor mercury
analyzer, and a colorimeter.


      Five percent of retail figure of $20,000 for a monthly
charge.


      This cost is exclusive of any sampling and shipping
charges and is calculated by dividing the total costs by
32 inorganic analyses per month (Table 4-4).
                          -58-

-------
                       TABLE 4-6
MONTHLY BUDGET FOR ANALYSIS  OF  BACTERIOLOGICAL  SAMPLES51
Salary                                         $1,000.00
Salary Overhead                                 1,000.00
Equipment Charge                                  600.00

Expendable Supplies                               500.00
Total Direct Cost                              $3,100.00
General and Administrative                        412.50
Total Cost                                     $3,512.50
                   p
Average Sample Cost                                 4.38
     aThis budget is based on approximately 9,500 samples
per man-year.

     bFigured at 5 percent per man-month of $10,000 yearly
cost for a one-man microbiological lab.

     °Figured at 800 analyses per man-month.
                           -59-

-------
     The volume of cpllform monitoring called for by the
proposed interim regulations makes the cost of coliform
determination the most critical component in determining the
overall costs of routine monitoring.  The cost range selected
for coliform testing was $5 to $10.  Table 4-7 gives cost
ranges for routine monitoring of the 40,000 community systems.
The costs in Table 4-7 assume no substitution of residual
chlorine monitoring for coliform tests, a subject explored
later in this section.

     Since total monitoring costs are calculated on an annual
basis, costs are divided evenly through the period in cases
where the deadline for initial testing is greater than one
year.  (For example, for the 31,268 systems which are required
to test for organics within 2 years of adoption, 15,634 are
accounted for in the first year and the remaining 15,634 are
put in the second.)  Cases where the subsequent test intervals
are greater than 1 year are handled in a similar manner.

     One major factor which might reduce monitoring costs
would be the substitution of residual chlorine testing for
coliform counts.  The Proposed Interim Primary Drinking
Water Regulations require 30 residual chlorine tests to
replace one coliform count.  If one assumes a cost of $8.00
for each coliform count, then residual chlorine tests would
have to be held below $0.27 to be cost-effective.  Even the
use of field-test kits would not be able to keep the costs
of residual chlorine monitoring at this level.

     In an effort to determine the number of water supply
systems which would use the residual chl-orine option instead
of the coliform density measurement, ERGO surveyed (Appendix
D) the 207 plants from the CWSS study.  Of the 37 respondents
to this question, 18 felt that they would probably use the
residual chlorine option while 19 felt that they would
definitely not use the option.  In another survey of the 50
state water supply directors (Appendix B), ERGO asked if the
states planned to encourage the use of chlorine residual
monitoring to replace the coliform measurements. Of the 38
states responding as of May 22, 1975, 11 felt that they
would encourage chlorine residual monitoring, 20 felt that
they would discourage it, and 7 were undecided.

     The total monitoring costs shown In Table 4-7 do not
reflect the true impact of the Imposition of the Proposed
Interim Primary Drinking Water Regulations since much monitoring
is presently being done under the Interstate Carrier Law and
under existing state monitoring laws and therefore will not
represent additional costs attributable to the proposed
regulations.
                            -60-

-------
                                                                       TABLE  4-7

                                               COSTS OF ROUTINE MONITORING POH  THE COMMUNITY WATERViORXS
DEADLINE
FOR INITIAL
CCY?0?~NT SVS"'EJ' 'pvov TTCTTV*P
Inorganics Surface3 1 yr .
Ground 2 yr.
Master Keter 1 yr.
IN'OROANICS TOTAL
CrgELTlcs Surface 1 yr.
Ground 2 yr.
Xc.scer Meter 1 yr.
3S3AMOS TOTAL
Colircr^:: 25 to 93 persons
100-433
50C-595
1,000-2,459
2,500-4,559 Average 3,500
5,000-5,939 • 6,800
1C, 000-24, 593 " 15,200
25,0:0-43,353 • 34,300
50,000-58,933 " 68,200
100,000-240,993 148,600
250,000-459,959 " 350,100
1 500,000-399,593 735,000
i_j Over 1,000,000 " 3,074,800
| COLI7C.-:-: TOTAL
Plate Count 25 to 99 persons
100-499
50:-933
1,000-2,499
2,5:0-4,993
5,000-9,999
25,000-49,999
50,000-99,999
100,000-2=9,999
350,0;c-i99,999
500,000-939,999
Over 1,000,000
PUTS COUNT TOTAL
TOTAL PROJECTED KO!II7CP.I::3 COSTS: 40,000 SYSTEMS

SUBSEQUENT
TEST
INTERVALS
1 yr.
3 yr.
1 yr.

1 yr.
3 yr.
1 yr.

2/mo.
2/mo.
2/mo .
2/mo.
4/r,o.
8/mo.
17/.T.O.
tO/mo.
75/no.
120/mo.
180/no.
260/30.
450/ir.o.

1/mo.
1/30.
I/TO.
1/mo .
1/mo.
1/mo .
2/rr.o .
I/no.
8/mo.
12/130.
13/mo.
26/mo.
45/mo.



NUMBER
OF
SYSTEMS
5,965
31,268.
2,767
40,000
5,965
.31,268
2,767
40,000
7,003
15,113
5,392
5,182
2,605
1,858
1,597
677
339
155
43
24
7
40 ,000
7,008
15,113
5,392
5,182
2,605
1,658
1, 597
677
339
155
43
24
7
40,000


ASSUMED
COST PER
TEST
$73-188
$73-188
$73-188

$200-312
$200-312
$200-312

$ 5-10
$ 5-10
$ 5-10
$ 5-10
S 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10

J 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10
$ 5-10



FIRST
N
5,965
15,634
2,767
24,366
5,965
15,634
2,767
24,366
163,192
362,712
129,403
124,368
125,040
178,363
325,788
324,960
305,100
223,200
92,800
74,280
37,800
2,472.616
84,096
131,356
64,704
62,184
31,260
22,296
32,456
32,544
22,320
9,283
7,488
3,780
592,140

NUMBER 0? TESTS (N) AN1
1 YEAR SECONT
$ MILLION N
5,965
15,634
2,767
1.9-4.6 24,366
5,965
15,634
2,767
4.9-7.6 24,366
166,192
362,712
129,408
124,363
125,040
178,368
325,788
324,960
305,100
223,200
92,800
74,530
37,800
12.4-24.7 2,472,616
84,096
131,356
64,704
62,134
31,260
22,296
33,323
32,496
32,544
22,320
9,253
7,488
3,780
3. 0-5 . 9 592 140
22.2-42.8
D COSTS (J MILLION) PER YEAR
0 YEAR THIRD S SUBSEQUENT YEAS2
$ MILLION N J KILL::::
5,965
10,423
2,767
1.9-4.6 19,155 1.5-3.6
5,955
10,423
2,767
4.0-7.6 lc,155 3.c-£.:
165,152
362,712
129,408
124,368
125,040
173,3=3
325,733
324,960
305,100
223,200
92, 200
74,380
37,cOC
12.4-24.7 2,172,616 12.1-2^.7
84,095
181,355
64,704
62,184
31,?fO
22,:-;6
33,323
32,456
32,5^4
22,320
?,2S3
7 ^ CO
3,780
3 0-5 9 592 140 ? C 5
22.2-42.8 70 7-in -
1. Additional tests  not  included for substances found to exceed 50J, 75? or  100J  of  allowed  standard limits.
2. Turbid icy rconitorlr.g  not  Included.
3. .'Is allcv.-ar.ee for  the  use  of residual chlorine tests as substitute for coliform tests.
^. Costs cased or. cor.Tierclal rates.
5. Tciif^rn; sar.plir.j  frequency estimated from average size of works in each  population  chart.
6. For initial ctadlines and test intervals greater than 1 year, costs are spread evenly  throughout  Interval.
7. AssLj-.ed cost per  test is  derived  frorr. the range of commercial rates In Table A-3.
S. Ir.eludes r.ixcd syst^^s .

-------
     4.1.1  Monitoring of Water Systems at Present

     A review was made of those interstate water systems
which are also community water supplies, and are. therefore,
currently subject to Federal purview under the interstate
quarantine regulations of the Public Health Act.  The
populations served and water sources of these systems are
shown in Table 4-8.  However, an analysis of the monitoring
practices of these systems showed that only the coliform
measurements are taken at a rate commensurate with the
Proposed Interim Primary Drinking Water Regulations.  Other
aspects of the proposed regulations, such as potential
inorganic contaminants, organic quality of the water, and
plate count measurements, are not presently subject to
control.

     The percentage of statewide coliform analyses performed
in each state was used to determine the percentage of the
required coliform monitoring being performed (Table 4-9).
The average compliance rate for the 24 states responding was
58.7 percent, somewhat higher than the 37-3 percent compliance
found in the 10 state drinking water evaluations.  Included
in this 58.7 percent (of the monitoring) are at least 655,391
samples which are being monitored for the interstate carrier
systems.  If these 6555391 samples are subtracted from the
national total of 1,451,425 samples (2.47 million x 58.7
percent), this means that a total of 796,034 samples are
being analyzed annually for the 34,380 non-interstate carrier
systems.  This is only 44 percent of the total samples which
should be analyzed for these systems.  Since these non-
interstate systems serve mainly small populations, it is
this group which would bear the majority of the additional
monitoring costs.  The estimated costs of the routine coli-
form measurements currently being performed are shown in
Table 4-10.  In this table the number of tests to be performed
for the non-interstate carrier systems is 44 percent of the
total number of expected analyses.
4.2  Costs Incurred by Community Water Systems When
     Maximum Contaminant Levels Are Exceeded

     This section concerns the monitoring costs incurred by
community water systems as a result of violating one or more
of the Proposed Interim Primary Drinking Water Regulations as
published in the Federal Register, March 14, 1975.

     The special monitoring procedures mandated by the
proposed regulations are listed in Table 4-11, while the
                             -62-

-------
                        TABLE  4-8
            INTERSTATE  CARRIER  WATER SUPPLIES
WHICH

POPULATION
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
> 1,000,000
ARE ALSO

SURFACE
1
1
4
6
10
25
138
86
5
COMMUNITY

SOURCE OP
GROUND
5
11
5
11
11
17
67
35
0
WATER

WATER
MIXED
0
1
0
2
3
6
47
42
2
SUPPLIES

PURCHASED
0
0
2
0
3
3
24
3
0

TOTAL
NUMBER OP
SYSTEMS
6
13
11
19
27
51
276
166
7
TOTAL
276
162
103
35
576
                            -63-

-------
                                               TABLE  4-9

                                    COLIFORM  ANALYSES  BY  STATE
STATE
Alabama
Alaska
Arlr.ona
Arkansas
California
Colorado
Connecticut
Delaware
Dist. . of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
lOV.'E.
Kansas
Kc-r.tu;;:y

Louisiana
1
# 0? COMMUN-
ITY SYSTEMS3'
[503]
[69]
[1,9I2+]
[500]
4,100
-
[395]
[139]
-
[1,800]
2,530
12-5+
357
[1,520]
163
S22
830
[500]

L500 j
2
* OP TOTAL
ANALYSES6
IN STATE LABS
-
90
100
-
N. A.
19
N.A.
-
-
N.A.
90
10
93
80 ,
80
50
99
70


# OF ANALYSES15
IN STATE
LABORATORIES
-
N.A.
N.A.
-
13,000
9,800
N.A.
-
-
N.A.
10,000
5,953
7,191
72,000
25,618
10,000
15,619
21,000

~
1
TOTAL # OF
ANALYSES0
IN STATE
-
-
-
-
-
20,000
-
-
-
-
11,111
11,882
7,337
90,000
32,060
80,000
-
30,000

~
5
PROJECTED (K
OF ANALYSES
IN STATE d
-
-
-
-
-
50,100
-
-
-
-
1189,360
9,000
68,901
116,610
33,336
59,181
-
26,000

~
6
% of
COMPLIANCE6
-
-
-
-
-
10
-
-
-
-
23
100 +
11
77
96
100+
-
83

""
% OF SYSTEMS
IN COMPLIANCE
IN STATE
EVALUATIONS
-
-
-
-
-
10
29
-
-
30
15
-
32
-
-
-
18
36

—
     aNur.bers in brackets  from 3.971 Staffing  and Budgetary Guidelines for State  Drinking Water Agencies by the
National  Sanitation Foundation.

     bInformation supplied by states in April 1975 ERCO questionnaire.

     cDeterniined by dividing Column 3 by Column 2.

     Determined by multiplied Column 1 by 72, the national average of colifor-m  tests per system per year.

     eColum-i 1 divided by  Column 5.

-------
                                         TABLE  4-9  (CONT.)


                                   COLIFORM ANALYSES BY  STATE

1 'a i ne
Mary0
170
[790]
2,216
[1971]
[680]
[2,100]
[913]
[221]
160
[93]
[325]
^96
370
1,535
2,707
257
1,^52
[360]
2
% OF TOTAL
ANALYSES13
IN STATE LABS
90
67
N.A.
18
-
-
-
N.A.
70
-
-
N.A.
100
' -
75
<90
90
H6
f OF ANALYSES*3
IN STATE
LABORATORIES
10,000
11,000
N.A.
21,000
-
-
-
N.A.
N.A.
-
-
N.A.
25,000
-
40,000
7,000
15,000
11,000
1
TOTAL # OF
ANALYSES0
IN STATE
11,111
20,895
-
133,333
-
-
-
-
-
-
-
-
25,000 -
-
53,333
7,777
50,000
89,130
5
PROJECTED #
OF ANALYSES
IN STATE0
12,210
56,880
-
112,128
'
-
-
-
-
-
-
-
26,610
-
191,901
18,501
118,911
61,920
6
o*
COMPLIANCE6
91
37
-
91
-
-
-
-
-
-
-
-
•91
-
27
12
12
100 +
% OF SYSTEMS
IN COMPLIANCE
IN STATE
EVALUATION
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
' 33
-
the
per
     d:.'u.T.bers in brackets from 1971 Staffing; and  Budgetary guidelines for State Drinking Water  Agencies by
 le National Sanitation Foundation.                                         ~~          	 '
     "Ir.-ormation supplied by states in April 1975 ERGO questionnaire.

     "Determined by dividing Column 3 by Column 2.
     -;
     "Determined by multiplied Column 1 by 72, the national average of coliform tests per system

     =ar.

     "Column 1 divided  by Column 5-

-------
                                          TABLE  4-9  (CONT.)

                                    COLIFORM ANALYSES  BY STATE


STATE
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
1
# OF COMMUN-
ITY SYSTEKSa'°
[590]
4,375
52
1,270
371
[520]
6,900
665
371
1,353
1,600'
650
[600]
424
2
% OF TOTAL
ANALYSES13
IN STATE LASS
-
N.A.
N.A.
32
90
-
90
60
100
80
40
70
-
99
3
f OF ANALYSES13
IN S^'A^E
LABORATORIES
-
2,609
6,870
50,000
15,000
-
260,322
20,000
20,000
84,520
15,000
N.A.
-
7,575
4
TOTAL f OF
ANALYSES0
IN STATE
-
-
-
156,250
16,667
-
289,246
33,333
20,000
105,650
37,500
-
-
7,651
5
PROJECTED *
OF ANALYSES
IN STATE"
-
-
-
91.440
25,712
-
4 96,!: 00
47, 8 SO
26,712
97,416
115,200
-
-
30,528
6
Cnvpr/rAMC^

-
-
-
100+
62
-
•- D
70
75
100+
33
-
-
.25
T v r(^< 'V — • -• - —
-;-; T; ~i -

i
-
-

-
U6
-
-
-
-
-
-
-
3* '
                                                               1,248,647?   2,127,672
53.7
     aNumbers In brackets from 1974 Staffing  and Budgetary Guidelines for State Drinking Water Agencies by
the National Sanitation  Foundation.

     blnformation supplied by States in April, 1975 ERCO questionnaire.

     °Determined by dividing Column 3 by Column 2.

     dDetermined by multiplying Column 1 by 72, the national average of conform tests per system per year.

     eColumn 4 divided by Column 5.
     f
     No more than 100 percent compliance per state was  counted.

-------
                              TABLE  4-10





PRESENT COSTS FOR COLIPORM MONITORING  OF  INTERSTATE  CARRIER WATER SUPPLIES

COLIFORM:






COLIFORM
COLIFORM
COLIFORM

: 25-99 persons Average
100-499 "
500-999 "
1,000-2,499 "
2,500-4,999
5,000-9,999
10,000-99,999 "
100,000-999,999 "
> 1,000,000 " 3,
TOTAL FOR 576 SYSTEMS
TOTAL FOR 620 SYSTEMS
NUMBER OF
INTERSTATE
SYSTEMS
4? 6
178 13
604 11
1,741 19
4,258 27
6,413 51
43,349 276
449,528 166
074,800 7


TOTAL FOR 39,380 NON- INTERSTATE SYSTEMS
TOTAL PRESENT COLIFORM MONITORING
NUMBER COST PER
OF TESTS YEAR
(N) ($ million)
144
312
264
456
1,620
4,284
165,600
398,400
37,800
608,880 3.0-6.1
655,391 3.3-6.5
796,034 4.0-7-9
7. 3-14. 4

-------
                       TABLE  4-11
          MONITORING REQUIREMENTS WHEN MAXIMUM
            CONTAMINANT LEVEL IS EXCEEDED
CONTAMINANT
Mandated Monitoring Requirements,
COLIPORM
Collect and analyze daily samples from
same sampling point where violation occur-
red until at least two consecutive samples
show no positive coliform results.
INORGANICS
   AND
PESTICIDES
Repeat analysis within 24 hours, then
weekly during the period of time the
maximum contaminant level is exceeded.
To determine compliance of a public water
system with the maximum contaminant levels
either 12 month, 3 month, or 1 month
moving averages shall be used.
ORGANICS
Repeat the analyses within two weeks of
initial analysis.
                           -68-

-------
number of systems found to be in violation of maximum con-
taminant levels in the CWSS survey of 969 systems is shown
in Table 4-12.  In the CWSS study, 90 percent of those
systems in violation served fewer than 5,000 people.

     The costs of special monitoring for coliform violations
are estimated in Table 4-13.  The proposed regulations call
for daily coliform testing in each location where a sample
violation occurs until the violation is corrected.  For
purposes of estimation it is assumed that between 7 and 30
coliform analyses will be performed for each coliform
violation found.  This would allow for finding and correcting
the cause of the violation.  Note that special monitoring
for coliform is required for each sample, not for each
system.

     The costs of special monitoring for chemical violations
are shown in Table 4-l4.  The number of violations shown for
mercury is estimated under the assumption that 2.7 percent
of the systems exceed the standard for mercury.  The proposed
regulations call for weekly testing of each chemical con-
taminant found to be in excess of regulations until such
time as the regulations are met, or until a variance is
granted.  This would reesult in a sampling requirement of
between 8 and 52 samples for each violating system.

     It is important to realize that once the cause of the
violation Is located and treatment commences, no further
special monitoring costs should occur.  One exception,
however, to this rule would be monitoring for coliform
organisms, since these violations can be spurious in nature;
however, it is assumed that a well-run chlorination treatment
will be effective in controlling coliform contamination.
Therefore, It is anticipated that the majority of these
special monitoring costs would be Incurred during the first
few years of Implementation of the Act.  Except in Isolated
instances of small population areas (and major contamination
problems), special monitoring will not prove unduly burdensome
4.3  Special Monitoring Required of Community Water Systems
     When Chemical Contaminants Are Found to Be Between 75
     and 100 Percent of Maximum Levels

     Any water system in which the concentration of a chemical
contaminant Is between 75 and 100 percent of the maximum
contaminant level is required to monitor monthly for that
contaminant for one year.  If none of the 12 readings is
above the maximum contaminant level, the monthly monitoring
may be suspended.

                          -69-

-------
                              TABLE  4-12
             SYSTEMS WHICH  EXCEEDED  ONE  OR  MORE  MAXIMUM CONTAMINANT
LEVEL BROKEN DOWN BY POPULATION SERVEDa

POPULATION
SERVED
25-99
100-499
500-999
i
o 1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
> 1,000,000
TOTAL


As
0
1
2
0
0
0
0
0
0
3


Ba
0
0
0
1
0
0
0
0
0
1


Cd
0
2
0
1
1
0
0
0
0
4


Cr
2
0
0
0
1
0
0
0
0
3


CN
0
0
0
0
0
0
0
0
0
0


Pb
4
6
1
3
0
2
0
0
0
16


N03
5
8
l
2
1
3
1
1
0
22


Se
2
5
1
0
1
0
0
0
0
9


Ag
0
0
0
0
0
0
0
0
0
0


p
5
16
3
3
2
4
1
0
0.
36


CCE
0
0
1
1
1
1
1
0
0
5
a
 From CWSS study.

-------
                         TABLE 4-13


      SPECIAL MONITORING COSTS FOR COLIFORM VIOLATIONS
Number of tests required for each sample             7 ~,n
in violation                                         '
                       o
Estimated cost per test                            $5-$10

Percent of samples in violation,                    0.88%
CWSS survey

Total cost for violations, 40,000               $0.7-$6.5
systems13 ($ million)
     aSame as one used for routine monitoring costs.

      Assumes CWSS analysis results hold nationwide and
that once a violation is found in the system, treatment
will commence and no further violations" will occur in
that system.
                             -71-

-------
                                                        TABLE 4-14
                                     SPECIAL MONITORING COSTS FOR CHEMICAL VIOLATIONS
 I
—J
PERCENT OP NUMBER OF SYSTEMS
CONTAMINANT

Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead

Mercury

Nitrate
Selenium

Silver
Fluoride
CCE6
TOTAL FOR 40
CWSS SYSTEMS PROJECTED TO BE
EXCEEDING
0.42G
0.14G
0.56G
0.42G'
0
0.43G
2.1 S
1.35G
1.35S
3.1 G
1.13G
0.44s
0
5.0G
3.42S
,000 SYSTEMS,
MCLa IN VIOLATION13
131
44
175
131
0
227

483

969
373

0
1,563
158
NATIONWIDE13 ' c
NUMBER OF TESTS COST PER
REQUIRED
(1 Year)
8-52
8-52
8-52
8-52
8-52
8-52

8-52

8-52
8-52

8-52
8-52
8-52

TEST0
($)
7-7-18-5
7-7-18.5
7.7-18.5
5.6-13-5
7-7-18.5
5.6-13-5

11.6-28.0

5-6-13-5
7-7-18.5

5-6-13.5
5-6-13.5
45.0-70

TOTAL
COST
($ thousand)
8.1-126.0
2.7-42.3
10.8-168.3
5-9-92.0
0
10.2-159.4

44.8-703-2

43.4-680.2
23.0-358.8

0
70.0-109.7
56.8-575-1
257.7-3,015.0
                   In CWSS sample of 969 systems based on surface (S)~or  groundwater (G) source.


                  bProJected from CWSS data base by source of water.


                  GLow cost based on EPA laboratory rates, high cost baaed on commercial rates.


                  dNo data In CWSS — number estimated from Interstate carrier and other state data.


                  eCarbon chloroform extract.

-------
     This section deals with the costs of such monitoring
for community systems.   It is assumed that the CWSS survey
contains data representative for the nation and that no
violations (above maximum contaminant levels) were found
(Table 4-15).  The costs of this special monitoring for
chemicals are shown in Table 4-16.  The number of near-
violations for mercury is estimated from 10 state studies,
since the CWSS study did not analyze for mercury.  As in the
previous section, cost ranges were developed from EPA and
commercial laboratory rates.

     The proposed Interim regulations state that if after
one year of monthly monitoring the level of the contaminant
is stable and due to a natural condition of the water source,
the water supplier may reduce the frequency of monitoring to
one analysis per year.   This means that most of the costs
incurred to monitor systems with contaminant levels between
75 and 100 percent of maximum would be borne for one year
only.  Those systems which are found to exceed the maximum
limit would be forced to Implement corrective action to
eliminate the violation.  Table 4-17 shows the relative
magnitude of all monitoring costs for community systems.
4.4  Costs for Monitoring of Water Systems Serving Transient
     Populations (Non-Community Systems)

     This section develops the routine monitoring costs for
one typical water system serving a transient population, and
the results are used to estimate the nationwide costs for
routine monitoring.

     It is assumed that the typical system serves an average
population of between 25 and 2,500 persons daily throughout
the year.  The upper limit ensures that only the minimum
number of coliform tests (2 per month) and plate counts (1 per
month) need be run.  The lower limit ensures that the system
is covered by the regulations.  Year-round use sets the
annual number of coliform samples at 24.  Seasonal shutdown
would decrease the coliform sampling requirement, while a
large water system (serving, for example, a national park or
an airport) would be required to submit more samples.  For
purposes of estimating the routine monitoring costs for the
approximately 200,000 water systems nationwide which serve
transient populations, it is assumed that no system will shut
down as an alternative to routine monitoring.  The cost
figures for the individual tests are the same that were used
                            -73-

-------
                         TABLE  4-15






   SYSTEMS WHICH  ARE  BETWEEN  75 AND  100  PERCENT OP MAXIMUM
CONTAMINANT LEVEL BROKEN DOWN BY POPULATION

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1, 000, 000

As
1
0
0
0
0
0
0
0
0

Ba
0
0
0
0
0
6
0
0
0

Cd
1
2
0
0
0
0
0
0
0

Cr
7
6
5
2
2
3
3
0
0

CN
0
0
0
0
0
0
0
0
0

Pb
7
11
7
6
5
1
6
2
0

N03
0
6
4
1
3
4
3
1
0
SERVED

Se
3
5
6
6
5
0
6
5
0

Ag
0
0
0
0
0
0
0
0
0

p
24
4
7
3
2
2
2
0
0

CCE
0
0
0
2
0
1
1
0
0
TOTAL          1    0    3   28     0    45    22     36    0  44

-------
                                      TABLE it-16
              SPECIAL MONITORING REQUIRED WHEN CHEMICAL CONTAMINANT LEVELS
ARE FOUND TO BE BETWEEN 75 AND 100 PERCENT OF
MAXIMUM LEVELS (COMMUNITY WATER SYSTMES)









PERCENT OF CWSS NUMBER OF SYSTEMS NUMBER OF TESTS COST PER
CONTAMINANT SYSTEMS BETWEEN PROJECTED TO BE REQUIRED TEST0
75/2-100$ OF MCLa 75$-100$ OF MCLb (1 Year) ($)
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead

Mercury

Nitrate
Selenium

Silver
Fluoride
CCEe
TOTAL FOR
0

5
3

it
4
4
4
3
6
10

6
2
40,000 SYSTE
.14G

.0
.9


G 1
G 1

• 35S 1
.9
.0
.0
.1
.6
.6

.2
.7
MS
G
S 1
G
G
S 3
G

G 1
S
, NATIONWIDE,
it 4
0
,563
,219
0
,732

,435

969
,617

0
,939
124
ONE YEAR
12
12
12
12
12
12

12

12
12

12
12
12

7
7
7
5
7
5

11

5
7

5
5


.7-18
.7-18
.7-18
.6-13
.7-18
.6-13

.6-28

.6-13
.7-18

.6-13
.6-13
45-70

.5
.5
.5
-5
• 5
-5

.0

.5
.5

.5
.5





TOTAL
COST
($ thousand)
4

lit it
81

116

199

65
334


130
67
1,143.
.1-9.8
0
.4-347.
.9-197.
0
.4-280.

.7-482.

.1-157.
.2-803.

0
.3-314.
. 0-104 .
1-2,695


0
4

6

2

0
0


1
2
.2
aln CWSS sample of 969 systems based on surface (S) or groundwater (G) source.



bProjacted from CWSS data base by source of water.



°Low cost based on EPA laboratory rates, high cost based on commercial rates.



dNo data in CWSS — number estimated from 10 state drinking water evaluations.



eCarbon chloroform extract.

-------
                       TABLE 4-17

         MONITORING COSTS FOR COMMUNITY SYSTEMS
                      ($ million)
Routine monitoring costs                     22.2 - 42.8

Monitoring for systems                        1.1 -  2.7
75 and 100 percent of maximum
contaminant level

Monitoring for systems which exceed           0.9 -  8.4
the maximum contaminant level
to estimate routine monitoring costs for community systems.
Again, the most critical cost component is that of coliform
monitoring.  Table 4-18 shows the total number of non-
community systems broken down by source.  (Non-community
systems need not monitor for turbidity if their source is
groundwater.)  The costs for routine monitoring are shown in
Table 4-19-

     It is estimated that,   at present,  no more than  5 percent
of the required coliform testing is being performed,  and
virtually no other chemical or biological testing is  taking
place.  This 5 percent coliform testing amounts to between
$1.2 and $2.4 million a year.
4.5  Costs Incurred by Non-Community Systems When Maximum
     Allowable Limits Are Exceeded

     The data on violations used in this analysis were
developed from 11 separate studies of Federal and state "semi-
public" water supply systems which serve the travelling
public.  Using these studies to extrapolate national cost
figures is very difficult, since these Federal systems often
have more treatment facilities than non-Federal systems. In
addition, these systems are not representative of the national
distribution of water by source.  However, since these are
the only water quality data presently available on these
systems, they are used despite the dubious quality of the
extrapolated results.  Table 4-20 lists the number of systems
which exceeded one or more maximum contaminant levels for
public non-community systems, while Tables 4-21 and 4-22
show the costs of monitoring these systems for coliform and
chemical violations.
                           -76-

-------
                         TABLE 4-18
         NUMBER  OF  NON-COMMUNITY WATER SYSTEMS BY SOURCE
                      SURFACE-WATER
                     GROUNDWATER
A]/,BAMA .
ALASKA
AR] XQNA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT' OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA -
MISSISSIPPI
MISSOURI
'MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSIiE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WIST VIRGINIA
WISCONSIN
WYOMING

N
N

N
N
N


N
0
N
175
100
N
N
20
N

N
2
N
10



N
0

N
N
N
N
N
N
100
0

0
N
- 25
2

150
5
100
0
50
N

16

N
N

N
95
N


N
100
N
878
4,500
10rOOO
N
1,200
N

N •
4,100
N
'16 , nnn



N
' N


N
N
N
N
N
19,000
4.000

11,800
N
1,^5^1
600

inform
ROO
?3noo
9 J4 0 0
2,000
200

4io
TOTALS
758
99,136
N is not known.
No entry indicates  lack  of  response.
                         -77-

-------
                                        TABLE 4-19
                  COSTS OF ROUTINE MONITORING FOR WATER SYSTEMS SERVING
oo
I
NON-COMMUNITY POPULATIONS ACCORDING TO THE
PROPOSED INTERIM PRIMARY DRINKING WATER REGULATIONS

COST PER YEAR
CONTAMINANT
Inorganics
Organic s and
Pesticides
Plate Count
Coliform
DEADLINE FOR
INITIAL TESTING
5 years
5 years
1 year
None
SUBSEQUENT
TEST INTERVALS
6 years
6 years
1 per month
2 per month
ASSUMED COST
PER TEST ($)
78-188
200-312
5-10
5-10
FIRST 5
YEARS ($)
15.6-37-6
40.0-62.4
60.0-120.0
120.0-240.0
SUBSEQUENT
YEARS ($)
13.0-31.3
33-3-52.0
60.0-120.0
120.0-240.0
     Monitoring costs  per year- per system


     Monitoring costs  per year, nationwide
     (200,000  systems) ($ million)
235.6-460.0  226.3-443.3


 47.1- 92.0   45.3- 88.7

-------
                                                   TABLE 4-20
                             NUMBER OF PUBLIC NON-COMMUNITY SYSTEMS WHICH EXCEEDED
vo
 I
ONE OR MORE MAXIMUM CONTAMINANT LEVELS AS SPECIFIED
IN THE


INTERIM PRIMARY DRINKING WATER REGULATIONS*










CONTAMINANT
STUDY
Bureau of Reclamatibna
Water Resource
Interstate0
Park Servlced
Forest Service
Kansas
Florida5
Kentucky h
Tennessee
Georgia^
Wyoming
TOTAL
Ag
0
0
0
0
1
0
0
0
0
0
0
1
N03
4
0
3
0
0
2
0
0
0
0
0
9
CR
1
0
0
0
0
0
0
0
0
0
0,
1
Collform
7
14
18
4
24
9
2
21
12
10
4
125
Se
6
0
1
0
0
1
0
0
0
0
0
.8
F
0
0
1
5
11
1
0
0
0
0
0
18
Pb
0
0
1
1
0
4
0
1
0
4
0
11
Hg
0
0
0
2
0
0
0
0
0
0
0
2
Cd
0
0
0
0
0
0
0
0
0
3
0
3
              *See  following page for references.

-------
           •*a
            U.S. Environmental Protection Agency,  Water Supply  Division,  A  Pilot  Study  of
      Drinking Water Systems at Bureau of Reclamation Developments,  EPA-430/9-73-004, June  1973-

            U.S. Environmental Protection Agency,  Office of Water  Programs,  Sanitary  Survey
      Of Drinking Water Systems on Federal Water Resource Developments,  A Pilot Study,
      August 1971-  -

            U.S. Environmental Protection Agency,  Water Supply  Division,  Drinking Water
      Systems On and Along the National System of  Interstate and Defense  Highways,  A  Pilot-
      Study, 1972.

            U.S. Environmental Protection Agency.  Water Supply  Division,  A  Pilot  Study  of
      Drinking Water Systems in the National Park  Service System,  EPA-520/9-74-016,
      December 1974.

           eU.S. Environmental Protection Agency,  Water Supply  Division,  A  Pilot  Study  of
i      Drinking Water Systems in the U.S.  Forest Service System, November 1974.
CO
of.
i            U.S. Environmental Protection Agency.  Region VII, Water  Supply  Program, Evaluation
      of the Kansas  Water Supply Program, 1972.

           ^U.S. Environmental Protection Agency,  Region IV, Water Supply Branch, Evaluation
      of the Florida Water Supply Program, 1973-

            U.S. Environmental Protection Agency.  Region IV, Bureau  of Water Hygiene,
      Evaluation of  the Kentucky Water Supply Program, May 1972.

           """U.S. Environmental Protection Agency,  Region IV, Bureau  of Water Hygiene,
      Evaluation of  the Tennessee Water Supply Program," January 1971-

           '•'U.S. Environmental Protection Agency,  Region IV, Water Supply Branch, Evaluation
      of the Georgia Water Supply Program, July 1973-

           kU.S. Environmental Protection Agency,  Region VIII,  Water Supply Branch,
      Evaluation of  the Wyoming Water Supply Program, .December  1972.

-------
                         TABLE 4-21


            SPECIAL MONITORING COSTS OF COLIFORM
             VIOLATIONS (NON-COMMUNITY SYSTEMS)
Number of tests required per month for                7_^n
system in violation

Estimated cost per test                             $5-$10

Monthly cost per system                           $35-$300

Percent of systems in violation survey                   ^
(125 of 729)                                          '   '°

Resultant number of systems in violation,           _j. „„.-,
nationwide                                            '
                      o
Total cost, nationwide  ($ million)               1.2-10.3
    aAssumes that once a violation is found in the system,
treatment will commence and no further violations will occur
in the system after treatment commences.
                          -81-

-------
                           TABLE 4-22
            SPECIAL MONITORING COSTS FOR CHEMICAL
VIOLATIONS (NON-COMMUNITY SYSTEMS)

CONTAMINANT PERCENT OF NUMBER OF TESTS
VIOLATIONS3 REQUIRED13
(1 Year)
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nitrate
Selenium
Silver
Fluoride
CCEd
Chlorinated Hydro-
carbons (7 compounds)
Chlorophenoxys
(2 compounds)
TOTAL NATIONAL COST FOR
0
0
0.96
0.96
0
5.29
2.68
2.9^
0
0.96
4.48
9.80
c
c
200,000
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
8-52
SYSTEMS., ONE YEAR
COST PER
TEST
($)
7-7-18.5
7-7-18.5
7-7-18.5
5.6-13.5
7-7-18.5
5.6-13.5
11.6-28.0
5.6-13.5
7-7-18.5
5.6-13.5
5-6-13.5
45-70


($ million)
TOTAL COST
ANNUALLY
200,000 SYSTEMS
($ million)
0
0
0.1-1.8
0-1.3
0
0.5-7.4
.0.5-7:8'
0.3-4.1
0
0.1-1.8
0.4-6.3
0.3-3.66
0
0
2.2-34.1
 Based on 208 system sample.



 Assuming no closing of system.



cNo data.



 Carbon chloroform extract.



 Assume only 5 percent surface-water systems,
                              -82-

-------
4. 6  Costs Incurred by Non-Community Systems When
     (Contaminant Level is 75 Percent or More of Maximum
     Contaminant Level

     The costs incurred by non-community systems in monitoring
water where the contaminant level is between 75 and 100 percent
of the maximum are shown in Table 4-23.  When compared to all
other monitoring functions, the costs incurred in this
monitoring activity are minor, with mercury, fluoride and
lead monitoring accounting for approximately 70 percent of the
total costs .
4.7  Total Monitoring Costs

     The costs of monitoring the 200,000 public non-community
systems would account for 70 percent of the total monitoring
costs of from $72 million to $151 million for the first
year; routine monitoring of the 40,000 community systems
would account for the remaining 30 percent (see Table 4-24).
Bacteriological monitoring would account for 69 percent of the
routine monitoring costs for community systems.  In subsequent
years, as violations are corrected, the total monitoring cost's
would decline.  However, the 200,000 non-community systems
would continue to bear the larger proportion of the costs.
4.8  Water Quality Data

     It is essential that the underlying data and assumptions
be explored before developing treatment costs.  This section
relates the characteristics of existing water quality data
bases with the characteristics of the total national supply
system.  In this study, the EPA projection of 40,000 community
water supply systems is assumed to be valid and the ongoing
EPA inventory of community systems is taken to be represen-
tative of the population of supply systems in the country.
Since this is the case, it is possible to compare the
populations of other surveys against this base.

     For every organic and inorganic contaminant, except
mercury, ERGO used the water quality data developed in the
1969 CWSS study to evaluate the impact of implementing the
Proposed Interim Primary Drinking Water Regulations.  However,
it was necessary to supplement the CWSS study with information
from the EPA Interstate Carrier Study and the 10 EPA-State
evaluation studies to obtain data on mercury violations.
                             -83-

-------
                               TABLE 4-23
             SPECIAL MONITORING REQUIRED WHEN  CHEMICAL
CONTAMINANT LEVELS ARE
OF MAXIMUM LEVELS .
BETWEEN 75 AND 100 FEKUEIMT
(NON-COMMUNITY SYSTEMS)

NEAR VIOLATIONS
	 __ — pi
— ' SYSTEMS SAMPLED V!
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nitrate
Selenium
Silver
Fluoride
CCEb
Chlorinated Hydro-
Garbons (7 compounds)
Chlorophenoxys
(2 compounds)
TOTAL NATIONAL COST FOR
0
0
1/208
1/208
0
11/208
10/149
0/170
3/169
0/208
8/134
3/51
a
a
200,000 SYSTEMS,,
TOTAL COST
NUMBER OP TESTS COST PER ANNUALLY
3RCENT OF REQUIRED TEST 200,000 SYSTEMS
IOLATIONS (1 Year) ($) (? million)
P 12
0 12
0.48 12
0.48 12
0 12
5.29 12
6.71 12
0 12
1.78 12
0 12
5.97 ,12
5.88 12
12
12
ONE YEAR ($ million)
7-7-18.5
7-7-18.5
7-7-18.5
5.6-13,5
7.7-18.5-
5.6-13-5
11.6-28.0
5.6-13.5
7.7-18.5
5.6-13.5
5.6-13-5
45-70



0
.0
0..1-0.2
0-0.1
0
0.1-1. 7
1.9-4.5
0
0.3-0.8
0
0.8-1.9
0.3-0.5
0
0.
4.1-9.7
    aNo data.


    Carbon chloroform extract.  This number is inflated due  to large  number
of surface systems.
                                      -84-

-------
                           TABLE 4-24

           TOTAL MONITORING COSTS MANDATED BY  THE
      PROPOSED INTERIM PRIMARY DRINKING WATER  REGULATIONS


                                         FIRST YEAR  SECOND YEAR
                                        ($ million)  ($ million)


Costs of Routine Monitoring for the
40,000 Community Systems                  22.2-42.8   22.2-42.8

Monitoring Costs for Coliform
Violations for 40,000 Community Systems    0-3-3.2     0.3-3.2

Monitoring Costs for Chemical
Violations3- for 40,000 Community
Systems                                    0.2-1.5     0.1-1.5

Monitoring Costs When Between 75 and
100 Percent3- of Maximum for 40,000
Community Systems

Routine Monitoring Costs for
200,000 Public Systems

Monitoring Costs for Coliform
Violations13 for 200,000 Community
Systems                                    0.3-2.1     0.3-2.1

Monitoring Costs for Chemical
Violations13 for 200,000 Public
Systems                                    0.5-6.8     0.5-6.8

Monitoring Costs When Between 75 and
100 Percent*3 of Maximum for 200,000
Public Systems                             0.8-1.9     0.8-1.9
   0.6-1.4     0.6-1.3


  47.1-92.0   47.1-92.0
     TOTAL

Present Coliform Monitoring Costs
for 40,000 Community Systems

Present Coliform Monitoring Costs
for 200,000 Public Systems
  72.0-151.7  71-9-151.-6
(-)7.3-l4.4 (-)7-3-l4.4
(-H.2-2.4  (-)1.2-2.4
Additional Costs Mandated by
Prpposed Regulations
  63.5-134.9  63.4-134.8
     aAssumes violations will be found during first two years
of sampling.

     bAssumes violations will be found during first five  years
of sampling.
                                -85-

-------
Table 4-25 gives a summary of the water quality data presently
available on community water supply systems.  Since all of
these water samples were analyzed using the same methodology,
the results of each study should be comparable.  If multiple
samples were analyzed, the results were averaged to determine
if the system was in violation.

     There are certain inherent  problems in the analyses for
the contaminants shown in Table  4-25 which affect  their inter-
pretation.  Barium was not analyzed if the sulfate concentration
was greater than 2 mg/1, which accounts for the smaller
number of barium analyses in all three studies.  However, if
sulfate is found to be present in this concentration in a
water supply it is highly unlikely that barium will be
present in a soluble form.  It is, therefore, reasonable to
use a value of 0.1 percent of systems in violation rather
than the 2.3 percent which was based on only 43 samples,
since 2.2 percent of the samples have sulfate in the water
in sufficient quantity to precipitate out the barium.

     Because lead is usually found in the distribution
system rather than in the raw water source, it is  essential
that multiple testing in both source and distribution systems
be done for lead contamination.   This was not always done in
the CWSS study.

     Nitrate is mainly a groundwater problem.  This is
apparent in comparing the percentage of systems exceeding
the maximum contaminant level in the CWSS study and the
results of the interstate carrier water study in Table 4-25.
Table 4-26 shows that 75.2 percent of the CWSS systems used
groundwater sources while only 29-9 percent of the interstate
carrier supplies used groundwater.  Conversely, CCE organics,
which are found mainly in surface systems, occur in higher
proportions in the interstate carrier study than they are in
the CWSS study.

     Because of sampling requirements, the data on turbidity
in the CWSS study are invalid.  To be valid, turbidity sampling
should be done in situ.  However, in the CWSS study the samples
were transported to the laboratories, and several days passed
between sampling and analysis.  In addition, since variations
in turbidity can be expected on seasonal as well as on a
diurnal basis, it is assumed for the purposes of these studies
that all systems which use surface-water as a source will need
to provide some form of clarification if none is presently
being used.
                             -86-

-------
                                              TABLE  4-25
                              SUMMARY  OF  WATER  QUALITY  DATA  AVAILABLE  FOR
                                       COMMUNITY  WATER SYSTEMS
Contaminant
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nitrate
Selenium
Silver
Fluoride
CCE-Organic
# of Surface
Systems
Analyzed
228
it
233
233
228
233
-
228
227
233
233
1969 CWSS Study
# of
% of Surface Groundwater
Systems Tested Systems
in Violation Analyzed
0
0
-0
0
0
O.i)3
-
0
0.44
0
0
3.42a
710
37
714
714
710
714
-
710
70J
714
714
% of
Groundwater
Systems Tested
in Violation
0.42
2-7
0.56
0.42
0
2.10
-
3.1
1.13
0
5-0
1975 EPA
Interstate Carrier Study
# of Systems % of Systems
Analyzed in Violation
544
502
587
596
189
591
474
640
483

0
0
0
0
0
0.3
2-7
0
0.24
0

10 EPA State
# of Systems %
Analyzed in
252
147
294
294
164
295
289
249
250
294
189
107
Studies
of Systems
Violation
0
0.7
0-7
0.5
0
1.9
1.9
0.4
2.1
0
6.3
5-6
I
CO
         aBarium was not analyzed in 677 additional groundwater systems  since  they  had >2mg/l SO
     making the presence of soluble Ba unlikely.   Therefore.,  the cost  calculations  were based on
     O.l4 percent groundwater violations.

-------
                 TABLE 4-26
PERCENT OF COMMUNITY WATER SYSTEMS WHICH UTILIZE
EACH
OF FOUR SOURCES OF
WATER FOR FIVE STUDIES

SOURCE OF
WATER
Grounda
Surfaceb
Mixed0
Purchased
TOTAL
EPA
COMMUNITY 1969
INVENTORY CWSS
78.2 75.2
11.5 21.6
3.4 3.2
6.9
100.0 100.0
EPA
INTERSTATE
CARRIER
29-9
48.3
15.6
6.2
100.0
10 EPA-
STATE
STUDIES
60.5
32.6
4.3
2.5
99.9
1970
AWWA
40.4
34-7
14.9
10.0
100.0
 Includes  ground and (ground and purchased).

 Includes  surface and (surface  and purchased).
 Includes  ground and surface  and (ground and
 e and purchased).

 Includes  purchased only.

-------
     Coliform measurements are also a problem due to rapid
variations in the number of organisms found.  The Proposed
Interim Primary Drinking Water Regulations state that numbers
of violations averaged on a monthly and yearly basis should
be used to determine if a system is in violation.  This
procedure was not followed in the three studies shown in
Table 4-25.  However, historical data indicate that approxi-
mately 27 percent of the systems now in operation will need
to install some form of disinfection equipment in the future.

     Since no analysis for mercury was made in the 1969 CWSS
study, it was necessary to utilize the values found in the
chemical analysis of the interstate carrier water supply
systems and the 10 state evaluations to estimate the percen-
tage of systems which would exceed the maximum level of this
contaminant.  A value of 2.7 percent was chosen by dividing
the total number of samples analyzed in the interstate
carrier and state evaluations by the number of samples which
exceeded the maximum contaminant levels.
4 • 9  Expansion Factors

     Since the CWSS data base for which the water quality
data exists represents a different population (Table 4-27)
by source of water and population served than does the EPA
inventory (Table 4-28), it is necessary to apply expansion
factors in order to project national treatment costs from
this small sample.

     The national treatment costs were determined by multi-
plying the percent of MCL exceeders (categorized by source
of water for each contaminant) by the number of systems in
each of the nine size categories.  The number of plants
found in this manner was then multiplied by the cost of
treating the mean-sized plant in each size category.
4.10 Treatment Costs Incurred by Community Water Supply Systems

     The costs incurred by a community in removing any
contaminant are site-specific and are dependent on many exo-
genous factors, such as treatment facilities present, age of
system, availability of alternate sources of water, and many
other interrelated problems.  A theoretical discussion of the
chemistry involved in contaminant removal can be found in
                               -89-

-------
                                          TABLE  4-27
                         BREAKDOWN OP  1969  CWSS STUDY BY POPULATION
O
I
SERVED AND SOURCE OF WATER

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
> 1,000,000
TOTAL

GROUND
10.7
26.9
8.0
8.9
5-7
6.2
7.8
1.0
Qa
75-2

SOURCE OF WATER
SURFACE
1.2
3.8
2.8
4.8
2.4
2.2
3.1
1.2
0.1
21.6

MIXED
0.2
0.4
0.4
0.5
0.6
0.2
0.6
0.3
0
3.2

TOTAL
12.1
31.1
11.2
14.2
8.7
8.6
11.5
2.5
0.1
100.0
                a
                 Zero  (0)  means less than 0.1 percent.

-------
                                           TABLE  4-28
                            BREAKDOWN  OF  EPA INVENTORY BY POPULATION
I
VD
SERVED AND SOURCE OF WATER

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1, 000, 000
TOTAL










SOURCE OF WATER
GROUND
15
32
10
9
4
2
3
0
0
78
.9
.4
.7
.2
.0
.7 '
.1
.2
a
.2
SURFACE
0
2
1
2
1
1
1
0
0
11
.7
.4
.4
. 1
.6
.1
• 9
• 3

• 5
MIXED
0
0
0
0
0
0
0
0
0
3

.5
.4
.8
.5
.4
.7
.1

.4
PURCHASED
0.
2.
1.
0.
0.
0.
0.
0
0
6.
8
5
1
8
5
4
8


9
TOTAL
17-
37.
13-
12.
6.
4.
6.
0.
0
100.
4
8
6
9
6
6
5
6

0
                 Zero (0) means less than 0.1 percent.

-------
Appendices E and F.  Recognizing that each system is a separate
entity, ERGO used the following methodology to develop national
cost estimates for the treatment necessitated by the drinking
water regulations from the data base of 969 plants studied
in the 1969 CWSS study.

     Those systems having problems with a particular contaminant
are assigned capital and O&M costs for correcting the violation.
Lead treatment costs are determined using pH control as the
treatment process; ion exchange is the treatment process
chosen to treat for Cd,  Cr, NOo, Se, Hg, and Ba.  Granulated
activated carbon is chosen as the treatment for CCE: activated
alumina adsorption is chosen to remove excess fluoride and
arsenic.  (All cost functions utilized in forming capital and
O&M costs can be found in Appendix G.)

     A cost estimate is made to determine the capital and
annual O&M costs to clarify those water systems in the EPA
inventory of 40,000 systems which have surface-water supplies
and do not clarify.  The annual and capital costs are determined
by assuming that direct filtration will be used to clarify
those systems in which clarification is necessary.

     In developing capital and O&M costs for disinfection, it
was assumed that 27-5 percent of the systems which do not
presently chlorinate will need to install chlorination
equipment to meet the coliform regulation.

     If a system had an inorganic violation in the CWSS study,
but nonetheless had the correct remedial treatment process,
the violation was attributed to system malfunction and it
was considered unnecessary to calculate additional capital
expenses.

     The cost descriptions used are divided into two main
categories.  The first category is that of cost functions and
estimates for water supply systems that supply more than 1,000
mVday (264,000 gpd) .  The second category describes the
corresponding costs for small systems.  There is a need for
such a distinction because the costs developed for large
supply systems are not valid for systems of smaller capacity.
Consequently, different sets of functions are devised for the
following processes:  (1) clarification (consisting of direct
filtration), (2) chlorination, (3) activated carbon, (4) ion
exchange, (5) pH control, and (6) activated alumina.
                               -92-

-------
     The  assumptions used in developing costs are:

     1.    The quantity of water production is
          estimated using the appropriate production
          figures for each population category
          (Table 4-2);

     2.    Electricity costs 3 cents per kilowatt-hour;

     3-    Land costs $202 per hectare;

     4.    Capital costs include expenses for equipment
          purchase, installation, construction, design,
          engineering study, land, site development
          and construction overhead.  Operating and
          maintenance costs include labor, supplies,
          materials, chemicals, electric utility and
          general maintenance;

     5.    The interest rate is 7 percent;
                                             2
     6.    A 15-year payoff period is assumed.

     The  cost functions for large water supply systems were
generated primarily from the results of the report  by D.
Volkert  & Associates.3  These functions, which have been
compared  favorably with another report,  are summarized in
Appendix  G.  It should be noted that the cost estimates are
      Interest rates are quite variable and show considerable
fluctuation.   Seven percent was the average rate for medium-
risk utilities at the time of writing.
     2
      This payoff period Is considered to be shorter than
average for the industry and would cause the results to be
on the conservative side.
            Volkert & Associates, Monograph of the Effective-
ness and Cost of Water Treatment Processes for Removal of
Specific Contaminants, Vol. 1, Technical Manual (Bethesda,
Maryland:   David Volkert & Associates, 1974).

      I.C. Watson, Resource Studies Group, Control Systems
Research Inc., Study of the Feasibility of Desalting Municipal
Water Supplies in Montana.  Manual for Calculation of Conven-
tional Water Treatment Costs, Supplement to Final Report
(Arlington, Virginia:  GSR Inc. , 1972).  Control Systems
Research Inc. is not known as KAPPA Systems Inc., Arlington,
Virginia.
                              -93-

-------
for individual processes and that cascading them in series may
lead to lower costs.   Moreover, these functions are valid only
for plant capacities  from 1,000 m3/day (264,000 gpd) to 300,000
m^/day (79.2 mgd).   Unless specified, these cost estimates are
in terms of 1975 dollars.

     Cost information for systems producing under 1,000
m3/day was obtained through (1) personal conversation with
several water treatment equipment manufacturers and suppliers,
and (2) a study of conventional water supply costs conducted
by Control Systems Research, Inc. for the Office of Saline
Water, U.S. Department of the Interior.!

     The approach used when cost information was requested from
vendors included the following two steps.  First, each
manufacturer or supplier was queried as to the exact nature of
his business.  This allowed the cost data obtained to be
qualified in terms of actual type of equipment and services
supplied for a stated price.  The various business functions
of the vendors contacted included suppliers of $40 cartridge
filter products for home use, manufacturers of treatment unit
"packages" for commercial/industrial use, suppliers of
complete clarification systems for small municipal systems
and/or industrial use, and suppliers of treatment systems
designed to handle site-specific problems.

      Secondly, each vendor was asked to provide general cost
information  (capital, installation, operation/maintenance) for
equipment  customarily used in water treatment application
within the  flow rate range of interest.  -It is acknowledged
that  facilities and equipment provided in a given application
are determined from several factors including:  (1) raw water
quality,  (2)  desired product water quality, (3) flow rate,
 (4) existing  facilities,  (5) systems and equipment flexibility,
 (6) operation and maintenance needs of equipment, and other
site-specific characteristics.

      Since  site-specific  factors  are not easily quantified on
a general  basis, vendors  were  asked  for  a general indication
of costs.   Responses were  therefore based on  either general
equipment  catalogue costs  or on  actual vendor  experience  in
providing  facilities  for  small  systems.
       I.C.  Watson,  Resource  Studies  Group,  CSR Inc., Manual
 for Calculation  of  Conventional  Water  Treatment  Costs
 (Washington,  B.C.:Office of  Saline Water,  U.S.  Department
 of the Interior,  March  1972).
                                -94-

-------
     The information received from vendors was supplemented
with cost data contained in the aforementioned GSR study,
which is also based largely on equipment cost information
provided by vendors.  The GSR report was prepared with an
emphasis on developing cost curves for systems used in
municipal applications and was designed to provide a means for
estimating the costs of conventional treatment systems for
individual unit operations.  Cost functions derived from GSR
data reflect 1972 prices and are therefore multiplied by the
appropriate factor in order to present results in 1975 dollars.
A 7 percent discount rate was assumed.

     It should be pointed out here that the cost curves for
small and large systems will not produce a continuous
function.  The main reason for this is that each set of
curves was developed independently and perhaps under differing
assumptions.  The cost differences that occur at the small
and large system breakpoint do not materially affect the
overall cost estimates.  In any event, It was not within the
scope of this project to develop a single continuous function
for all system sizes covered by the Act.

     However, because of the tremendous range in system
size, from 25 persons to over 1,000,000 persons, there are
several reasons why it may be difficult to develop a continuous
function for all systems:

     1.   Small systems can employ package plants;

     2.   Small systems generally do not^require
          full-time maintenance;

     3-   Small system treatment package plants may
          not require housing facilities.
^ . 11 National Treatment Costs

     Table 4-29 shows the cost of treatment by process for
the average plant in each of the nine population categories.
The following assumptions were implicit in using these costs
to make national treatment cost projections:

     1.   A system will treat its present supply
          rather than develop an alternative supply;

     2.   There are no retrofit and cascading benefits
          when new treatment processes are added;
                              -95-

-------
 I
vo
0-1
 I
                                                      TABLE 4-29



                             CAPITAL TREATMENT COSTS FOR NINE POPULATION SERVED GROUPSa

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1, 000, 000
DISINFECTION
690
1,200
1,800
2,500
7,500
12,000
30,000
210,000
2 ,300,000
CLARIFICATION
21,000
30,000
41,000
52,000
150,000
270,000
640,000
3,400,000
22 ,000,000
pH
ION EXCHANGE CONTROL
41,000
68,000
100,000
140,000
470,000
810,000
2,000,000
11,000,000
67,000,000
690
1,200
1,800
2,500
7,500
12,000
30,000
210,000
2,300,000
ACTIVATED
- ALUMINA
2,600
6,100
12,000
22,000
37,000
60,000
130,000
620,000
3,300,000
ACTIVATED
CARBON
1,500
4,300
10,000
21,000
64,000
120,000
330,000
2,300,000
21,000,000
            aCosts were determined for average production and average, size plant in each group
       based on EPA Community Inventory as of July 15, 1975 (Table 4-2).

-------
     3-    Advanced treatment is necessary to remove
          all heavy metals.   In many Instances, however,
          filtration may remove enough of the contaminants
          so that the water may meet the standards.
          Alternatively, some systems may "blend" well
          water free of NCU with water which contains N0~
          so that the NO,, will fall below the maximum   ^
          contaminant level;

     4.    The inorganic violations found in this 1969
          study are truly representative of the national
          water supply systems;

     5-    The information on mercury violations found in
          the chemical analysis of the interstate carrier
          water systems is representative of the country's
          water supply systems;

     6.    Chlorination units will be installed in 27-5
          percent of the systems which do riot presently
          disinfect their water supplies;

     7-    All surface water systems will install
          clarification units if they are not presently
          in use;

     8.    The mean-sized plant in each of the nine
          population ranges was used as a model plant
          to develop costs.

     The national treatment costs for ea"ch contaminant and
nine population-served categories are shown in Tables 4-30 to
4-40.  The capital costs to treat for mercury and nitrate
contaminants and turbidity account for almost 79 percent of
the total costs, with O&M costs for clarification accounting
for 69 percent of the total O&M costs (Table 4-41).
4.12 Treatment Costs for Public Non-Community Systems

     With only extremely limited and questionable data
available on public non-community water systems, it is almost
impossible to make accurate predictions about the treatment
techniques which would be required.   Unlike community systems,
it is quite possible that these systems would choose to stop
supplying water rather than install any treatment process.
However,  in this analysis it will be assumed that no systems
                             -97-

-------
                                                               1ABLE  1-30
                                           CAPITAL  AND  O&H  COSTS3  OF  CHLORINATION AND CLABIFICATION
 I
VD
OO
 I
UUIT PROCESSES BY POPULATION SIZE CATEGORY
CHLORINATION
POPULATION NUMBER OF
SIZE CA1EGOR1 PLANTS
25-99 1,526
1CO-499 2,110
500-999 607
1,000-2,199 168
2,500-4,999 211
5,000-9,999 133
10,000-99,999 170
100,000-999,999 12
>1, 000, 000 0
TOTAL 5,557
PROCESS COSTS
POPULATION ($/Thousand)
AFFECTED CAPITAL 0 4 M
95
646,
160
7H5
770
972
1,515
2,663

11, 140
,671 1,052
061 2,692
,177 1,092
,073 1,220
,559 1,562
,619 1,596
,998 5,100
,660 2,520
0 0
,771 17,051
106
457
267
111
113
611
2,720
2,160
0
7,176
NUMBER OF
PLANTS
252
653
293
37b
215
111
195
27
2
2, 126
CLARIFICATION
POPULATION
AFFECTED
13
171,
205
581
735
716
1,759
6,675
5,010
19,103
,13&
669
,200
,121
,165
,112
, 166
,097
,761
,371
PROCESS COSTS
($/Thousand)
CAPITAL 0 4 rl
5,292
19,590
12,013
19,656
32,250
29,970
124,600
91,600
11,000
379,371
47b
1 ,436
732
1 ,020
7,310
7,992
1b,600
64,600
56,000
188,568'
             Clarification includes direct filtration only.

-------
                                          TABLE 4-31
                 BREAKDOWN OF TREATMENT5 COSTS FOR MERCURY (ION EXCHANGE)
BY POPULATION SERVED AND SOURCE

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
vo 2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000


SURFACE
CAPITAL
28?
1 ,428
1,300
2,660
6,580
8,910
34,000
33,000

,000
,000
,000
,000
,000
,000
,000
,000
0

WATER
0 &
20
100
93
188
658
847
2,890
2,820


M
,300
,800
,600
,100
,000
,000
,000
,000
0



GROUND
CAPITAL
5
18
9
10
15
18
54
22

,535
,632
, 100
,920
,980
,630
,000
,000

,000
,000
,000
,000
,000
,000
,000
,000
0
OF WATER

WATER
0
391
1,315
655
772
1,598
1,771
4,590
1,880


& M
,500
,200
,200
,200
,000
,000
,000
,000
0


POPULATION PROJECTED # OF
AFFECTED VIOLATING PLANTS
8,372
73,253
71 ,784
145,027
161 ,340
224,121
990,328
846,174
0
142
295
104
97
48
34
44
5
0
   TOTAL
!,165,000    7,617,800     154,797,000 12,973,100     2,520,399
769
     aThe number of plants affected was calculated by multiplying the 2.11 percent groundwater and
2.20 percent surface-water of mercury MCL exceeders in the EPA Interstate Carrier Study by the total
number of groundwater and surface-water systems in each size category (Table 4-2).  The number of
plants was then multiplied by the cost of treating the mean-sized plant in each size category.

-------
                                                       TABLE 4-32
                              _BREAKDOWN OF TREATMENT5 COSTS FOR CHROMIUM (JION  EXCHANGE)
o
o
I
BY POPULATION SERVED AND SOURCE

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL


GROUND WATER
CAPITAL 0 & M
1,107,000
3,740,000
1 ,800,000
2,240,000
3,290,000
4,050,000
12,000,000
0
0
28,227,000
78,300
264,000
129,600
158,400
329,000
385,000
1,020,000
0
0
2,364,300
OF WATER

POPULATION
AFFECTED
1 ,601
13,472
12,602
23,081
22,728
30,724
115,075
0
0
219,283

PROJECTED # OF
VIOLATING PLANTS
27
55
18
16
7
5
6
0
0
134
                aThe number of plants  affected by calculated by multiplying the  0.42 percent of chromium
           MCL exceeders in the CWSS Study by the total'number of groundwater systems in each size
           category (Table 4-2).   The number of plants was then multiplied by the cost of treating the
           mean-sized plant in each size category.

-------
                                                      TABLE  4-33
                             BREAKDOWN  OF  TREATMENT5  COSTS  FOR  BARIUM  (ION  EXCHANGE)
I
M
O
I—'
I

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL
BY POPULATION

GROUND
CAPITAL
369,000
1 ,292,000
600,000
840,000
1 ,410,000
1 ,620,000
4,000,000
0
0
10,131 ,000
SERVED

WATER
0 &
26,
91,
43,
59,
141,
154,
340,


854,
AND

M
100
200
200
400
000
000
000
0
0
900
SOURCE OF WATER

POPULATION
AFFECTED
533
4,490
4,200
7,693
7,576
10,241
38,358
0
0
73,091

PROJECTED # OF
VIOLATING PLANTS
9
19
6
6
3
2
2
0
0
47
               aThe number of plants affected was calculated by  multiplying  the  O.l4  percent  of  barium
          MCL exceeders in the CWSS Study by the total number of groundwater systems  in  each  category
          (Table 4-2).   The number of plants was then multiplied by the  cost of  treating the  mean-sized
          plant in each size category.

-------
                                                     TABLE 4-
                            BREAKDOWN OF TREATMENT5 COSTS FOR  LEAD  (PH  CONTROL)
I
I—'
o

I
BY POPULATION SERVED AND SOURCE OF WATER

POPULATION
SERVED
25-99
100-400
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL


SURFACE WATER
CAPITAL 0 & M
1,380
6,000
5,400
10,000
22,500
36,000
120,000
0
0
201,280
6
60
114
360
660
1,440
6,800
0
0
9,440


GROUND WATER
CAPITAL 0 & M
92,460
326,400
162,000
195,000
255,000
276,000
810,000
420,000
0
2,536,860
428
3,264
3,420
7,020
7,480
11 ,040
45,900
38,000
0
116,552


POPULATION PROJECTED # OF
AFFECTED VIOLATING PLANTS
8,073
68,451
64,670
121 ,088
122,861
167,258
655,945
342,278
0
1,550,624
136
277
93
82
37
26
31
2
0
684
              aThe  number of plants  affected was  calculated  by  multiplying  the  0.43  percent  surface-water

         and  2.10 percent groundwater of lead MCL exceeders  in' the  CWSS  Study by  the total number of surface-
         and  groundwater systems  in  each size category  (Table  4-2).   The number of plants was  then multiplied

         by the cost  of treating  the mean-sized plant in each  size  category.

-------
                                                     TABLE 4-35
                            BREAKDOWN OF TREATMENT3 COSTS FOR ARSENIC (ACTIVATED ALUMINA)
I
h"
O

I
BY POPULATION SERVED AND SOURCE

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL

GROUND
CAPITAL
70,200
335,500
216,000
352,000
259,000
300,000
780,000
0
0
2,312,700

WATER
0 & M
5,940
34,650
27,000
48,000
77,000
105,000
402,000
0
0
699,590
OF WATER

POPULATION
AFFECTED
1,601
13,472
12,602
23,081
22,728
30,724
115,075
0
0
219,283

PROJECTED # OF
VIOLATING PLANTS
27
55
18
16
7
5
6
0
0
134
              aThe number of plants affected was calculated by- multiplying the 0.42 percent arsenic MCL
         exceeders in the CWSS Study by the total number of groundwater systems in each size category
         (Table 4-2).  The number of plants was then multiplied by the cost of treating the mean-sized
         plant in each size category.

-------
                                                      TABLE 4-36
                              BREAKDOWN OF TREATMENT3 COSTS FOR CCE (ACTIVATED CARBON)
I
I—
o
_Cr
I
BY POPULATION SERVED

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL

SURFACE
CAPITAL
15,000
141 ,900
190,000
630,000
1 ,408,000
2,040,000
8,910,000 1
9,200,000
0
22,534,900 4

WATER
0 & M
38,000
204,600
178,600
390,000
858,000
765,000
,566,000
560,000
0
,560,200
AND SOURCE OF WAT

POPULATION
AFFECTED
503
8,657
13,166
45,192
73,304
108,456
640,801
971 ,604
0
1,861,683
ER

PROJECTED # OF
VIOLATING PLANTS
10
33
19
30
22
17
27
4
0
162
                aThe number of plants affected was calculated by multiplying the 3.42 percent
           of CCE MCL exceeders in the CWSS Study by the total number of community surface-water
           systems in each size category (Table 4-2).  The number of plants was then
           multiplied by the cost of treating the mean-sized plant in each size category.

-------
                                                    TABLE 4-37
                           BREAKDOWN OF TREATMENT5 COSTS FOR NOg (ION EXCHANGE)
o
Ul
I

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL
BY POPULATION

GROUND
CAPITAL
8,118,000
27,336,000
13,300,000
16, 100,000
23,500,000
27,540,000
78,000,000
22,000,000
0
215,894,000
SERVED. AND SOURCE OF

WATER
0 & M
574,200
1,929,600
957,600
1,138,500
2,350,000
2,618,000
6,630,000
1 ,880,000
0
18,077,900
WATER

POPULATION
AFFECTED
11 ,823
99,439
93,020
170,360
167,760
226,774
849,364
324,933
0
1,943,473

PROJECTED # OF
VIOLATING PLANTS
198
402
133
115
50
34
39
2
0
973
             aThe number  of plants  affected was calculated by multiplying the 3-1 percent of NO^ MCL
        exceeders in  the  CWSS Study by the total number of groundwater systems in each size category
        (Table  4-2).  The number of plants was then multipled by the cost of treating the mean-sized
        plant in each size category.

-------
                                            TABLE 4-38
                   BREAKDOWN OF TREATMENT21 COSTS FOR SELENIUM (ION  EXCHANGE)
BY POPULATION SERVED AND SOURCE

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
I
£ 2,500-4,999
1 5,000-9,999
10,000-99,999
100,000-999,999
>1, 000, 000

SURFACE
CAPITAL
82,000
340,000
300,000
560,000
1 ,410,000
2,430,000
8,000,000
0
0

WATER
0 & M
5,800
24,000
21,600
39,600
141 ,000
231 ,000
680,000
0
0

GROUND
CAPITAL
2,952,000
9,996,000
4,900,000
5,880,000
8,930,000
10,530,000
30,000,000
0
0
OF WATER

WATER
0 & M
208,800
705,600
352,800
415,800
893,000
1,001 ,000
2,550,000
0
0


POPULATION PROJECTED # OF
AFFECTED VIOLATING PLANTS
4,375
37,362
,35,602
67,914
70,583
96,617
392,050
0
0
74
152
52
46
22
16
19
0
0
     TOTAL
13,122,000    1,143,000
73,188,000  6,127,000
704,503
361
     aThe number of plants affected was calculated by multiplying the 1.13 percent groundwater and
0 44 percent surface-water of selenium MCL exceeders in the EPA Inventory by the total number of
groundwater and surface-water systems in each size category (Table 4-2).   The number of plants was
then multiplied by the cost of treating the mean-sized plant in each size category.

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                                                     TABLE 4-39
                            BREAKDOWN OF TREATMENT5 COSTS FOR CADMIUM (ION EXCHANGE)
 I
I—
o
^j
 I
BY POPULATION SERVED AND SOURCE

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL


GROUND WATER
CAPITAL 0 & M
1 ,476,000
4,964,000
2,400,000
2,940,000
4,230,000
5,670,000
14,000,000
0
0
35,680,000
104,400
350,400
172,800
207,900
423,000
539,000
1 , 190,000
0
0
2,987,500
OF WATER

POPULATION
AFFECTED
2,135
17,963
16,803
30,774
30,305
40,965
153,433
0
0
292,378

PROJECTED # OF
VIOLATING PLANTS
36
73
24
21
9
7
7
0
0
177
              aThe number of plants affected was calculated by multiplying the 0.56 percent of cadmium
         MCL exceeders in the CWSS Study by the total number of groundwater systems in each size
         category. (Table 4-2).  The number of plants was then multiplied by the cost of treating the
         mean-sized plant in each size category.

-------
                                                      TABLE  4-40
                             BREAKDOWN OF TREATMENT3 COSTS FOR  FLUORIDE  (ACTIVATED ALUMINA)
o
CD
I
BY POPULATION SERVED AND SOURCE OF WATER

POPULATION
SERVED
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL



GROUND WATER
CAPITAL 0
829
3,952
2,568
4,070
2,997
3,240
8,190
2,480

28,327
,400
,800
,000
,000
,000
,000
,000
,000
0
,200
70
408
321
555
891
1,134
4,221
2,480

10,080

& M
,180
,240
,000
,000
,000
,000
,000
,000
0
,420


POPULATION
AFFECTED
19
160
150
274
270
365
1,369
524

3,134
,069
,386
,032
,775
,581
,765
,942
,086
Q
,636

PROJECTED # OF
VIOLATING PLANTS
319
648
214
185
81
54
63
4
0
1,568
               aThe number of plants affected was calculated by multiplying the  5-0  percent  of  fluoride
          MCL exceeders in the CWSS Study by the total number of groundwater systems in each size
          category (Table 4-2).   The number of plants  was  then multiplied by the cost of treating  the
          mean-sized plant in each size category.

-------
                           TABLE 4-41
   NATIONAL COSTS OP TREATING CONTAMINANTS IN DRINKING WATER
                                                            a
PROCESS
Clarification
CCE
NO.,
Chlorination
Mercury
Selenium
Cadmium
Lead
Fluoride
Chromium
Barium
Arsenic
SUB-TOTAL
COMMUNITY
SUB-TOTAL
NON-COMMUNITY
TOTAL
TREATMENT
TECHNIQUE
direct
filtration
activated carbon
ion exchange
disinfection
ion exchange
ion exchange
ion exchange
pH control
activated
alumina
ion exchange
ion exchange
activated alumina



CAPITAL COSTS ANNUAL O&M
($ million) ($ million)
379^3
22.5
215-9
17.0
243.0
86.3
35.7
2.7
28.3
28.2
10.1
2.3
1,071.3
23.6
1,094.9
188
4
18
7
20
7
3
0
10
2
0
0
263
4
267
.6
.6
.1
.2
.6
.2
.0
.1
.1
.4
.8
.7
.4
.4
.8
     aThe number of plants affected was calculated by
multiplying the percentage of violators in each contaminant
category by the total number of systems in each size and
source category.  The number of plants was then multiplied
by the cost of treating the mean-sized plant in each size
category.
                                -109-

-------
will choose to close rather than treat.  In the non-community
system studies 17.1 percent of the systems exceeded the
coliform MCL; this means that approximately- 34,000 systems
nationwide must disinfect.   It is assumed that these 34,000
systems will install feed hypochlorinators at a capital cost
of $400 or a national capital cost of $13.6 million.  Since
the majority of these systems operate for only 3 months of
the year, the O&M is assumed to be $100 per year per plant,
or a national cost of $3.4  million per year.

     The only other major treatment costs encountered by
these non-community systems would be for the clarification of
surface-water systems.   A rapid sand filter can be bought
for about $5,000 for a system delivering 20 gallons per
minute.  It is estimated that less than 1 percent of the
non-community systems use surface water as a source (Appendix
B, Table B-16).  This means that a maximum of 2,000 systems
would need clarification, or $10 million in capital invest-
ment and an annual O&M cost of $1 million.  It is highly
doubtful that a non-community water supply system would
invest a great deal of capital in extensive treatment
systems for inorganic contaminants, although certain systems
might invest a few hundred  dollars in a simple Ion exchange
column.  In general, it appears that the capital and O&M
costs of these non-community systems would be minimal compared
to the costs of community systems.
4.13 Sensitivity of Treatment Costs

     The following variables were used in developing the
capital and O&M requirements for water treatment facilities:

     1.   Construction costs

     2.   Site development costs

     3-   Labor costs

     4.   Land costs

     5-   Plant capacity

     Each of these variables has an input on the local cost
of constructing and running a treatment facility.  Table 4-42
shows the regional variations in wages and construction cost
indices which were found in March of 1975, as well as the
                               -110-

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                              TABLE 4-42
             LABOR AND CONSTRUCTION INDICES BY EPA REGION

March 1975
CPI Index
U.S. Average
Percent
of U.S.
I
2,l?6a

2,128
1.02
II
2,631

2,128
1.24
III
2,374b

2,128
1.12
IV
1,670°

2,128
0.78
V
2,374

2,128
1.12
VI
l,679d

2,128
0-79
VII
2,330

2,128
1.09
VIII
1,705

2,128
0.80
IX
2,309

2,128
1.09
January 1975
BLS Wage se
3.96a  5-00   4.83b  3-50c  5.34   4.72d  4.48   4.80   5-01
U.S.  Average    4.71   4.71   4.71   4.71   4.71   4.71   4.71   4.71   4.71
Percent
of U.S.
January 1975
Handy-Whitman
Index
Source
Pumping
Structure
Pumping
Equipment
Plant - large
- small
Distribution
0.84

385
358
303
355
400
335
1.06

385
358
303
355
400
335
1.03

389
377
303
386
380
338
0.74

389
377
303
386
380
338
1.13

375
379
303
377
364
328
1.00

365
364
303
354
355
324
0.95

371
379
303
374
361
325
1.02

357
335
303
335
333
318
1.06

376
378
303
357
351
322
Pipes
Building
Trades Labor
405    405    421    421    417    387    4l6
409
411
     aBased on Boston Index
     bBased on Cincinnati Index
     cBased on Atlanta Index
      Based on Denver Index
     GFor manufacturing employees
                                    -111-

-------
national average.   In all calculations ERGO used the national
average to compute costs, but regional variations can cause a
difference of at least 20 percent in costs..  Local land costs
vary from site to site, but since land costs comprise only a
very small percentage of total construction costs, the
effect of this variable is minimal.

     The major cost factor is plant  capacity since this
factor controls the amount of construction and material needed
to build a given treatment facility.  Water usage may differ
markedly among cities having similar populations.  For
example, Wheeling, West Virginia and Everett, Washington each
have water systems serving approximately 65,000 people.
Wheeling treats 10 mgd while Everett treats 100 mgd, with
the difference in water usage explained by the presence of
two pulp plants in Everett.  Other factors, such as climate,
local economy, urbanization, water distribution facilities,
cost to consumer, availability and variability of water
sources, and the kinds of commercial and industrial estab-
lishments supplied from the municipal system, all determine-
the quantities of water treated.1

     The national average water production is presently 165
gallons per consumer day (0.62 m3cd), as found in the EPA
water supply inventory.  The production by size category
varies from 99?to 197 gpcd  (0.38 to 0.74 m3/cd) (see Table
4-2).  A study  of 122 private companies (Table 4-43) yields
a national average consumption of 146 gpcd (0.55 m3/cd).
This study also indicates that smaller communities can
.consume considerably less water per consumer than do larger
communities.  Since production is the most important factor
in the price sensitivity analysis, an analysis was performed
using peak day demand production.  The treatment costs
developed for peak day demand and average daily production
are shown in Table 4-44.  Using peak demand production would
put a realistic upper bound on expected treatment costs,
since many systems might decide to build treatment capacity
to meet the expected maximum demand on the systems, rather
than the average daily demand.  Building larger treatment
plants will not cause O&M rates to go up significantly,
however, since most O&M  expenses are related to total gallon
throughput in the system.
      Water Resources Council, The Nation's Water  Resources
 (Washington, D.C., 1968), p. 4-1-2.
      2
      National Association of Water  Companies,  "1973  Financial
 Summary  for Investor-Owned Water Utilities"(Washington,  D.C.,
 1973).
                             -112-

-------
                          TABLE 4-43
              PRODUCTION PER CAPITA PER DAY FOR

NUMBER OF
COMPANIES
12
12
41
8
14
28
7
TOTAL 122
122 PRIVATE WATER

AVERAGE
POPULATION
SERVED
624,339
239,859
79,474
24,885
11,711
4,435
1,166
23,672
COMPANIES^1

GALLONS CONSUMED
PER CUSTOMER
PER DAY
140
147
162
135
142
119
74
146
     aNatlonal Association of Water Companies, "1973
Financial Summary for Investor-Owned Water Utilities,"
Washington, D.C.
                            -113-

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                                         TABLE  4-44
                  NATIONAL  COSTS OP TREATING CONTAMINANTS IN DRINKING WATER
-t=-
i

TREATMENT
TECHNOLOGY
Community Systems
Clarification
Chlorination
Ion Exchange
Activated Alumina
pH Control
Activated Carbon
TOTAL
CONTAMINANT
Turbidity
Coliform
Ba, Cr, Cd,
NO, Hg, Se
As , Fluoride
Pb
CCE

CAPITAL COSTSa
($ million)
379.
17-
619,
30.
2.
22.
1,071.
3 -
0 -
2 -
6 -
7 -
5 -
3 -
682.
27-
996.
52.
4.
35.
9
4
9
7
2
8
1,800.1
ANNUAL O&M
($ million)
188.
7.
52.
10.
0.
4.
263.
6
2
3
8
1
6
6
           aT
            Lower bound assumes treatment plant designed for  average  daily  demand;  upper

      bound assumes treatment plant designed for peak daily demand.

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                      CHAPTER FIVE


          CONSTRAINTS TO IMPLEMENTATION OF THE
      INTERIM PRIMARY DRINKING WATER REGULATIONS



5.0  Introduction

     This chapter explores the non-economic constraints which
may hinder Implementation of the Proposed Interim Primary
Drinking Water Regulations.   The economic factors are examined
in the following two chapters.  An examination of these non-
economic constraints on the  implementation of the interim
regulations reveals that potential problem areas are the
availability of trained manpower and the availability of
some chemicals.

     Chemical shortages might occur for some coagulants,
mainly alum, ferric chloride, and synthetic polymers, as
well as hypochlorites and activated carbon; it is antici-
pated, however, that these shortages would be only short-
term local problems.

     It is anticipated that  a shortage of state certified
laboratory facilities could  delay full implementation of the
water quality monitoring program called for under the Proposed
Interim Primary Drinking Water Regulations.  However, there
are many uncertified laboratories available to perform  all
the routine analyses required.

     This chapter examines those factors which could hinder
the implementation of the Proposed Interim Primary Drinking
Water Regulations. Specifically, the discussion is broken
down into four separate sections, as follows:

     1.   Chemical Constraints

     2.   Manpower Constraints

     3-   Laboratory Constraints

     4.   Construction Constraints
                           -115-

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5.1  Chemical Constraints

     The implementation of the Proposed Interim Primary
Drinking Water Regulations within a reasonable time frame
depends greatly on the availability of key chemicals and
supplies needed in the treatment of drinking water.  The
increased demand for some chemicals would require an increase
in production of several percent over-and-above the quantities
presently being manufactured.

      The  demand  for many  of these  chemicals  would  be  further
 exacerbated  by  the  concurrent  demands  of  other Federally
 mandated  air and water  pollution control  programs.

      Figure  5-1  provides  a general  list of water treatment
 chemicals grouped according to treatment  process.   In
 addition, some  of the more important industrial  characteristics
 of these  chemicals  are  tabulated in Table 5-1.  Most  treatment
 chemicals are manufactured and distributed by the  chemical
 industry, although  the  machine, petroleum, and some other
 industries contribute to  production.   The most often  and most
 widely used  chemicals,  such as alum, polyelectrolytes,  filter
 media, and chlorine products,  are usually manufacturer  and
 distributed  in  bulk quantities.

      The  chemical constraint  analysis  is  based on  the following
 assumptions:

      1.    Twenty-seven  percent of  the  systems which
           presently do  not chlorinate  will install
           chlorination  units;

      2.    All surface-water systems which do not
           presently clarify will do so;

      3-    The numbers and types of  systems which
           exceeded  one  or more maximum contaminant
           levels in the 1969  CWSS  study are
           representative  of the country's 40,000
           community systems;

      4.    No major  treatment  activity  will begin
           until  March 1977 and the  maximum chemical
           demands will  not be  felt  until  two years
           later.

      A critical  evaluation is  made  for those chemicals which
 would require an increase in  production of 5 percent  or more
 due  to implementation of  the  Proposed  Interim Primary Drinking
 Water Regulations.  The current and anticipated  supply and
                             -116-

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^*"*-NV. Treatment
^^^v-^ Proceoo
Chemicals ^"^v.
and ^-"s^
Suppllea ^-N^^^
Aluminum Sulfatc (Bauxite)
Ferrous Sulfate
Purrlc Sulfate
Ferric Chloride
Sodium Aluninate
Hydrated Lime I Quickllne
Aluminum Ammonium Sulfate
AJumlnurc Fotacniura Sulfate
Synthetic Organic Polymers
Bentonlte
Calcium Carbonate
Sodium Silicate
Arjnonla, Anhydrous
Arimoulun Hydroxide
Araionlun Sulfate
Bromine
Chlorine
Chlorine Dioxide (Sodium Chlorite)
Chlorinated Lirae
Hydrochloriten (Calcium, Lithium, Sodium)
Ozone
Silver
Ion Exchange Realn
Sodium Bisulfite
Sodium Sulflte
Sulfur Dioxide
Hydrochloric Acid
Sodium Carbonate (Soda Ash)
Sodium Hydroxide
S-jlfurlc Acid
ArjDonluiE Slllco-Flouride
Fluospar
Hydroflourlc Acid
tiydrofluasUlclc Acid
Sodium Flourlde
Sodium Sllico-Flourlde
Activated Alumina
"Fluo-Carb"
"Pluorei"
HagneBiui Oxidft
Sodium Blsulfste
Poca«oluTi Periranganate
Srdium Tri-polyphosphate
Sodium Kexametaphosphate
Copper Sulfato
opJlum Bichromate
Sodium Chloride
EDTA (Metal Ch-Matlng Agent)
Ferric Hi'droxida
Aluminum Hvdrozida
Ion Exch.ince Daclcwaah 4 Regenerant
Crushed Anthricato
Flno Sand
c
£
1
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u
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/
/
/
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     Figure 5-1.
drinking water.
This figure shows chemicals used to treat
                              -117-

-------
              TABLE 5-1
CHEMICALS  USED  IN WATER TREATMENT
   Chemicals Used in Disinfection and DecMcridating Agents
Chemical Name
and Formula
Ammonium alum-
inum suUate
All SO»(NH*)«
SO. 21 HiO
Ammonium
nlfate
(NHi)«SOi
Anhydrous
ammonia
NHs
Aqua ammonia
NHiOH
Calcium hypo-
chlorite ,
Ca(OCl)«4HiO
Chlorinated
llmeCaO
20aOCb-3 HK>
Chlorine
Ob
Chlorine dioxide
CIO,
Drone Oi
Common or
Trade Name
ammonia alum,
crystal alum
gulf a to of
ammonia
ammonia
ammonia water,
ammonium hy-
drate, ammonium
hydroxide
"HTH" "per-
chloron"
"pittchlor"
bleaching
powder, chlor-
ide of lime
chlorine gas,
liquid chlorine
chlorine dioxide
ozone
Shipping
Containers
Bags, bbls., bulk
100-lb bags
SO-, 100-, 150-lb
cylinder, in bulk
tank cars
and trucks
carboys, 750-lb
drums, 8,000 gal
tank cars or
trucks
5-lb cans, 100—
300, SOO-lb
drums
100-, 300-,
800-lb drums
100-, 150-lb
cylinders; 1-tou
tanks; 16-, 30-,
65-ton tank cart
generated
aiused
generated at site
of application
Suitable Han-
dling Materials
duriron, lead,
rubber, silicon
iron stoneware
ceramics, plastics,
rubber; iron
(dry)
glass, iron, monel
metal, nickel,
steel
glass, iron, monel
metal, nickel,
ste«l
glass, rubber,
stoneware, wood
glass, rubber,
stoneware, wood
dry-black iron,
copper, steel ; wet
gas-glass, hard
rubber, silver
plastics, soft
rubber (avoid
hard rubber)
aluminum,
ceramics, iron,
steel, wood
Available
Forms
lump
nut
pea
powdered
white or
brown
cryctal
colorless
gas
colorless
liquid
white grannie
powder tablet
white powder
liquefied gas
under
pressure
yellow-red gas
colorless
gas
Weight
lo/eu/t
64-68
62
65
60
42.5


52.5
48
91.7

Solubility
lb/ffal
0.3(32'F)
8.3(212'F)
6.3 (68° F)
8.9(B2-F)
3.1(60°F)
1.8(126°F)
complete


0.07(60'F)
0.04(100'F)
0.02 (30mu)
Commercial
Strength
jwr cent
ll(AkO>)
25 (NH,)
99-100
(NHi)
29.4 (NH.)
26"Be
70 (available
CU)
25-37
(available Ob)
99.8 (Cli)
26.3 (avail-
able Cb)
Oharacteriitiei
pH of 1 per cut
Ml. 3.5
cakes In dry feed:
add CaSOi for
free Sow


1-3 (available
Cli solution nied)
deteriorates


Chemical Name
and Formula
Pyro sodium
sulfite

Sodium chlorite
NaClO:
Sodium
hypo chlorite
NaOCl

Sodium sulfito
NaiSOi
Snlfur dioxide
SO,

Common or
Trade Name
sodium metabi-
sulfite

technical sodium
chlorite
sodium
hypochlorite

sulfite
sul/urous acid
anhydride

Shipping
Containers
bags, drums, bbls.

100-lb drums
5-, 13-, 50-gal car-
boys, 1,300-
2000-gal tank
trucks
bags, drums, bbls
steel cylinders,
ton containers,
tank cars.
o- trucks
- Suitable Han-
dling Materials
iron, steel, wood

metals (avoid
cellulose
materials)
ceramics, glass,
plastics, rubber

iron, steel, wood
aluminum, brass,
Durco D-10,
stainless steel 316

Available
Forms
white crystal-
line powder,
clean solv.
light orange
powder, flake
light yellow
liquid

white crystal-
line powder
colorless gas

Weight
Ib/cu ft








Solubility
It/gal
complete in
water




complete in
water
20 per cent at
J2'F, complete
in water

Commercial
Strength
per cent
dry 67 SO,
Sol 33.3
(SO,)
82(NaCiOi)
30 (available
Cli)
12-15 (avail-
able CU)

23(SOa)
99(80.)

Characteristic!
sulf urous odor

generates CIO,
at pH 3.0


sulfurous taste
and odor
irritating gas

                -118-

-------
                   TABLE  5-1




CHEMICALS  USED IN WATER  TREATMENT  (Contd.







   Chemicals Used in Fluoridation and Fluoride Adjustment
Chemical Name
and Formula
Ammonium,
ailico fluoride
(NH.)iSiF.
Calcium
fluoride CaFi

Hydro-
fluosilicic acid
HiSiFd
Hydrogen
fluoride HF

Sodium fluoride
NnF


Sodium
Bilicofluoride
N»zSiF8

Aluminum
oxide
AUOj

Bone
charcoal

Tricolcium
phosphate
High magnesium
liroo

Oommon or
Trade Name
ammonium
fluorsilicate

fluorspar


fluosilicic acid


hydrofluoric
acid

fluoride



sodium
silicofluoride


activated
alumina


"Fluor-carb"


"Fluorex"

dolomitic lime


Shipping
Containers
100-lb and
400-lb drums

bags, drums.
bbls., hopper
cars, trucks
rubber-lined
drums, truck or
railroad tank cars
steel drums,
tank cars

bags, bbls.,
fiber drums,
kegs

bags, bbls..
fiber drums


bags, drums



bags, drums,
bulk

bags, drums.
bulk, bbls.
bags, bbls.,
bulk

Suitable Han-
dling Materials
steel, iron, lead

steel, iron, lead


rubberlined
steel PVC

steel


iron, lead, steel



iron, lead, steel



iron, lead, ateel



wood, iron, steel


iron, Bteel

wood, iron, steel


Available
Forms
white
crystals

powder


liquid


liquid


nilo blue or
white powder
light
dense
nile bluo or
yellowish-
white
powder
powder
granules
(up to lyS in.
in diameter)
granules


granular
technical
lump
pebble
frround
Weight
li/cu/«













50
75
72







variable


variable

50-63


Solubility
Ib/gal
1.7(63"F)

V.S1. col.


approx. 1.2
(68°F)




0.35 (most
temps.)


0,03(32°F)
0.06(72°F)
0.12(140°F)

insoluble






insoluble

slakes slowly


Commercial
Strength
per cent
100

85(CaFa)
less than
5(SiO.)
35 (approx.)


70(HF)


90-95 (NaF)



99(Nat)
(SiF«)


100








58(OaO)
40 (Mg)

Characteristics
white, free-
flowing solid







below 60 per cent
steel cannot be
used
pH of 4 per cent
solution 6.6


pH or 1 per cent
solution 5.3






black : best used
in beds for
persolution
also available as
white powder



    Chemicals Used in Stabilization and Corrosion Control
Chemical Name
»nd Formula
Disodium
phosphate
NMHPO»-12HjO

Sodium hexa-
metolphosphate
Na(POa).

Sodium
hydroxide
N^OH

Sulfuric acid
HiSOi


Tetrasodiura
Pyro-phosphate
N«iPtOi-10 HaO
Trisodium
Phosphate
n'uPOi-12 HaO
—
Common or
Trade Name
basic sodium
phosphate, DSP,
secondary
sodium phosphate
"Calgon"glassy
phosphate
vitreous
phosphate
caustic soda,
soda lye


oil of vitriol,
vitriol


alkaline sodium
pyrophosphate
TSPP
normal sodium
phosphate,
tertiary sodium
phosphate TSP
Shipping
Containers
125-lb kegs,
200-lb bags,
335-Ib bbls.

100-lb bags



100-700-lb
drums ; bulk
(trucks, tank-
cars)
bottlos, carboys,
drums, trucks,
tank cars

125-!b kegs,
200-lb bogs,
300-lb bbls.
125-lb kegs,
200-lb bogs,
326-lb bbls.

Suitable Han-
dling Materials
cast iron, steel



hard rubber,
plastics,
stainless steel

cast iron, rubber.
steel


concentrated
iron, steel ; dilute
glass, lead,
porcelain, rubber
cast iron, steel


cast iron, steel



Available
Forms
crystal



crystal
flake
powder

flake,
lump
liquid

solution



white powder


crystal —
course
medium
standard
Weight
Ut/eu/t
60-64



47







(60-66°)
Be


68



56
58
61
Solubility
Ib/gal
0.4(32°F)
6.4(86°F)


1-4.2



2.4(32°F)
4.4(6»°F)
4.8(104°F)

complete



0.6(80°F)
3.3(212°F)

0.1(32°F)
13.0(158°F)


Commercial
Strength
per cent
19.19
5 (Pads)


66(PaOt
unadjusted)


98.9 (NaOH)
74-76 (NaOa)


60°Be
77.7(H»SOt)
66°Be
93.2(HjeO»)
53(PaOo)


10(P«0»)



Characteristics
precipitates en.
Mg, pH of 1 per
cent solution, 9.1

pH of 0.25 per
cent solution
6.0-8.3

solid hygroscopic
pll of 1 per cent
solution, 12.9

approx. pH of
0.6 per cent
solution, 1.2

pH of 1 per cent
solution, 10.8

pH of 1 per cent
solution, 11.9


                       -119-

-------
        TABLE  5-1




USED  IN ¥ATE'R TREATMENT  (Contd. )
Chemicals Used in Taste and Odor Control
Chemical Nama
and Formula
Activated carbon
0
Chlorine
Cb
Chlorine dioxide
CIO,
Copper Eulfate
OuSOi-SHsO
Ozone
Oi
Potassium
permnnganate
KMnOi
Common or
Trade Name
"Aqua Nuchor1'
"Hydrodarco"
"Herite"
chlorine gas,
liquid chlorine
chlorine
diozide
blue vitriol,
blue stone
ozone
purple
salt
Shipping
Containers
bags, bulk
100-, 150-lb
cylinders ; 1-ton
tanks; 16 30-
55-ton tank cars
generated as used
100-lb bags,
450-lb bbls.
drums
generated at site
of application
bulk, bbls., drums
Suitable Han-
dling Materials
dry iron, steel;
wet rubber, sili-
con, iron, stain-
less steel
dry black iron,
copper, steel ; wet
gas glass, hard
rubber, silver
plastics, soft
rubber (avoid
hard rubber)
asphalt, silicon,
iron, stainless
steel
aluminum,
ceramics, glass
iron, steel wool
Available
Forms
black
granules
powder
liquified
gas under
pressure
yellow-
red gas
crystal
lump
powder
colorless
gas
purple
crystals
Weight
Ib/cuft
15
91.7

75-90
73-80
60-64


Solubility
Ib/gal
insoluble
(suspension
used)
0.07(60°P)
0.04(100"F)
0.02(30 mm)
1.6(32°F)
2.2(68°F)
2.6(86°F)

infinite
Commercial
Strength
•pir cint

99.8(CU)
26.8 (avail-
able Oil)
99(CuSOt)

100
Characteristici





danger of explo-
sion in contact
organic matter*
   Chemicals Used in Softening Process
Chemical Name
and Formula
Calcium oxide
OaO




Sodium
carbonate
NaiCOs



Sodium
chloride
NaCl
Calcium
hydroxide
Ca(OH).
Common or
Trade Name
burnt lime,
chemical lime,
quicklime,
unslaked lime


soda ash



common salt
salt
hydrated lime,
slaked lime
Shipping
Containers
50-lb bags,
100-lb bbls.
bulk (carloads)



bags, bbls., bulk
(carloads),
trucks



bags, bbls., bulk
(carloads)
50-lb bags,
100-lb bbls.
bulk (carloads)
bulk trucks
Suitable Han-
dling Materials
asphalt, cement,
iron, rubber, steel




iron, rubber, steel



bronze, cement,
rubber
asphalt, cement,
iron, rubber, steel
Available
Forms
lump
pebble
granule



white powder
extra light
light
dense


rock
fine
white powder
light
dense
Weight
Ib/cuft





23
35
65




Solubility
Ib/gal
slaked to
form
hydrated
lime


1.5(68°F)
2.3(86°F)



2.9(32°F)
3.0(68°F)
86°F
0.014(68°F)
0.012 (90°F)
Commercial
Strength
percent
75-99 (OaO)




99.4
(NasCOs)
58(Na=0)



98 (NaCl)
85-99
(C»(OH)«)
63-73 (CaO)
Characteristics
pH of saturated
solution, on
detention time
temp, amount of
water critical for
efficient slaking
hopper agitation
required for dry
feed of light and
extra light forms
pH of 1 per cent
solution, 11. 3

hopper ogitation
required for dry
feed of light form
             -120-

-------
                 TABLE  5-1




CHEMICALS USED IN  WATER  TREATMENT (Contd,








           Chemicals Used in Coagulation Process
Chemical Name
and Formula
Aluminum
Bulfate
AMSOth
14ft,0

Ammonium alum-
inum sulfate
Ab(SO«)>
(NH.)a-S04-
24HsO
Bentonite


Ferric chloride
FeCM35 45
per cent solution)


PeOlt-6 H=0


FeOla


Ferric sulfate
FB(SO»)a
BEiO

Ferrous sulfate
FeSOi 7 HiO


Common or
Trade Name
alum, filter alum
sulfate of
alumina


ammonia alum
crystal alum



colloidal clay
volclay
wilkinite
"ferrichlor"
chloride of
iron


crystal ferric
chloride

anhydrous ferric
chloride

"ferrifloc"
ferrisul


copperos,
green vitriol


Shipping
Containers
100-200-lb bags
300-400-lb bbls.
bulk (carloads)
tank truck "
tank car
bags. bbls. bulk




100-lb bags
bulk

5-13-gal carboys,
trucks,
tank cars


SOO-lb bbls.


600-lb casks;
100-300, 400-lb
kegs
100-175-lb bags
400-425-lb
drums

bags, bbls. bulk



Suitable Han-
dling Materials
dry-iron, steel.
solution lead-lined
rubber, silicon '
asphalt, 316
stainless steel
duriron lead
rubber silicon
iron stoneware


iron, steel


glass, rubber,
stoneware,
synthetic
resins







ceramics, lead
plastic rubber
18-8 stainless
steel
asphalt, concrete
lead, tin, wood


Available
Forms
ivory-colored
powder
granule
lump
liquid
lump
nut
pea
powdered

powder
pellet
mixed sizes
dark brown
syrupy liquid



yellow-brown
lump

preen -black
powder

red -brown
powder
70- or
granule 72
green-crystal
granule, lump


Weight
Ib/cvft

38-45
60-63
62^67
10(lb/g)
64-68
62
65
60

60

















63-66



Solubility
Ib/gal
4.2(60°F)




0.3(32°F)
8.3(212°F)



insoluble
(colloidal
sol used)
complete










soluble
in 2-4
parts cold
water




Commercial
Strength
per cent
15-22 (AhO«)



8 (AkOs)
ll(AhOj)







37-47 (FeCb)
20-21 (Fe)



59-61 (FeCU)
20-21 (Fe)

98(FeCU)
34(Fe)

90-94 (Fe)
(SO).
25-26(Fe)

55(FeSo4)
20 (Fe)


Characteristics
pH of 1 per cent
solution 3.4



pH of 1 per cent
solution 3.5








hygroscopic
(store lumps
and powder in
tight container)
no dry feed ;
optimum pH,
4.0-11.0


mildly hygro-
scopic coagulant
atpH 3.5-11.0

hygroscopic;
cakes in storage;
optimum pH
8.6-11.0
Chemical Name
tnd Formula
Potassium alum-
inum Bulfute
KiSO»-AU(SO»)a
24HiO
Sodium
illuminate
NaiO AhOs

Sodium silicate
NaiO SiOi

— -
Common or
Trade Name
potash alum

soda alum

water glass



Shipping
Containers
bags, lead-
lined bulk
(carloads)
100-150-lb bags
250-440-lb
drums, solution

drums, bulk
(tank trucks.
tank cars)

Suitable Han-
dling Materials
lead, lead-lined
rubber,
stoneware
iron, plastics,
rubber, steel

cast iron,
rubber,
steel

Available
Forma
lump
granule
powder
brown powder
liquid
(27°Be)

opaque,
viscous
liquid

Weight
Ib/cu ft
62-67
60-65
60
50-60





Solubility
lb/ffal
0.5(32°F)
1.0(68°F)
1.4(86°F)
3.0(6S'F)
3.3(86°F)

complete



Commercial
Strength
per cent
10-11
(AJsOa)
70-80(Nas)
AlzO* tnin.
32 Na.
AlsOt
88-42°Be



Characteristics

solubility; pH of
1 per cent solu-
tion, 3.5
hopper agitation
required for
dry feed

variable ratio of
NasO to SiOj;
pH of 1 per cent
solution, 12.3
                       -121-

-------
demand factors for alum,  ferric chloride, synthetic polymers,
hypochlorites, and activated carbon are specifically examined
Table 5-2 gives a summary of the findings of" the chemical
constraints analysis.

     Table 5-3 summarizes the number of systems which would
need treatment to reduce  the levels of certain contaminants
below the maximum concentration permitted under the Proposed
Interim Primary Drinking  Water Regulations.
     5.1.1  Coagulation

     One of the most important processes conventionally
utilized in the treatment of supply water is coagulation and
subsequent sedimentation or filtration.   Strictly speaking,
engineers use the term "flocculation" to refer to the chemical
agglomeration of suspended solids and colloidal materials, and
the term "settling" to refer to the gravitational descent of
these particles to the floor of the sedimentation basin.
These concomitant processes have traditionally been important
in water treatment for purposes of clarification, particularly
in turbid waters.  Because of the high incidence of undesirable
turbidity in water supplies throughout the United States,
many existing community supply treatment plants utilize this
process.  It is usually the first of a series of processes
which also includes filtration followed by disinfection.

     Coagulation is particularly important to the implemen-
tation of the Proposed Interim Primary Drinking Water
Regulations in decreasing turbidity and removing contaminants.
The maximum contaminant level of turbidity in drinking water
is not to exceed one turbidity unit; many reservoirs, however,
have turbidities in the tens of turbidity units.  Coagulation
can remove to some degree all of the other contaminants to
which the standards are addressed; i.e., inorganics, organics,
and microbiological pollutants.  Research has already proven
that additional coagulation has the capability of reducing
inorganic contaminants to suitable levels when they exceed the
regulations by a small degree.  In addition, high turbidities
may interfere with the disinfection process.

     Because of changing technologies, prices, and market
requirements, the types of coagulants used are also changing.
Most experts agree that while the use of both alum and ferric
salts will increase over the following decade, the volume of
organic polymers used in coagulation will accelerate even more
significantly.  Municipal water clarification is expected to
account for 25 percent of all coagulant utilization by 1980.
                             -122-

-------
                            TABLE  5-2
 CONSTRAINT  ANALYSIS  OF  KEY  WATER TREATMENT
Chemical
or
Supply
1. Alum
2. Ferric
Chloride
3. Synthetic1"
Polymers
It. Lime
5. Sand
6. Anthracite
7.' Chlorine
8. Hypo-
chlorltes
9. Ion Exchange
Resins
10. Sulfurlc
Acid
11. Sodium
Hydroxide
12. Activated
Carbon
13. Mer.branes
R/0
11. Soda Ash
15. Activated
Alumina
CHEMICALS
Current U.S.
Unit Prod./Yr.
Process Coat
Coagulation $85/ 1,136,000
ton tons (1973)
Coagulation $1007 115,000 ^
ton tons
Coagulation $1.00/
Coagulant }b.
Aids-Filter
Aids
Coagulant $25/ 250,000,000
Aid - pH ton tons
Control -
Calcium Hy-
pochlorite
production
Filtration $1 . 307 Ql 3, 375 ,000
and multi-
media)
Filtration $12/ 7,100,000
(Rapid Sand ton tons
Multi-media)
Disinfection 10(7 12,000,000
Ib. tons
Disinfection $4l/ 150,000
100 Ib tons
Inorganic $60/ styrene
Cation ft3 resins and
Removal copolymers
Nitrate 50Q
Reraoval tons
Ion ex- $53/ 31,590,000
change- ton tons
Regenera-
tion
Ion Ex- $12/ 10,680,000
change 100 Ib tons
Regenera-
tion
Organic *IOi/lb 55,000 ^g
removal tons
Organic 25-"0£/
Removal 1000p;al.
treated
pH control $507 sodium car-
Heavy ton bonate
metal 7,^96,000
rcircval tons
U^fluori- $1V bauxite
d.-itlon 100 Ib. 1,312,000
tons
AND SUPPLIES^
(3980)
Added Oi-Tiand % Current
from ] i'LJW,'"/Yi- ,c Product ' n
<; 185,000 tons 16.3*
25,000 tons ^22?
< 5,000 tons
250,000 tons 1.0*
111,000 tons 0.01?
116,700 tons 1.65J
83,000 tons 0.69J
10,000 tons 6-7$
215,300 ft^ i.^%
initially
68,850 ft3 0.45X
initially
235, ?00 0.755
tons
75,^00 0-71?
tons
/ -J» JpJ 1.97^-3.9*1? ^
Added coot/yr
(ml 1 liono ,of
}974 dollars) Availability Outlook
max. $16 . 2 General ly favor a tile , except
that essentially all alum pro-
duction 1 G d c p f r id t: M t on I ' o :• L- i r n
imports of bauxite. Politically
sensitive .
$ 2.5 The U.S. is self-sufficient In
chloride production, but "lust im-
port 50£ of its iron. ^otn arc
available in more tiian cJ equate
quantities. Cost is hirjh.
max. $10.0 While there are a number of
component monomers in s! orr
supply , this j s not ex pec ted
to create any sicnlficar.t supply
problems .
$6.25 Extremely abundant in U.S.
Improvement s in extract ion and
transport techniques of li'.e-
slone will be necessary to keep
costs of lime low.
$0.15 U.S. Resources are extrcT.e'1y
(assumes abundant on the whole , al Ir.ouc'r
yearly re- local depletions are occurring
placement) near heavily urbanized retro-
poll tan areas .
$1 . 40 While produc tion costs r.ay
(assumes continue to rise, tr.ere will be
yearly no trouble meeting additional
replacement ) demands . All anthracite is
found In the nor theaa tern
sector of Pennsylvania.
416.6 Supply should be adequate.
Sensitive to power industry
and fluctuatlors in elecvric
generation. Su u p 1 y A a s - n ^ -. e q u -. ".
in 1972 due to economic ccr.diti~
$8.2 Production presently at capacity
demand for oool R s tronc . F r j cf
hi kcs f or In coming .
i$13-0 a No prob] cms should occur if the
Initially petroleum industry remains stall
- General inf lat ior.ary trer.ds
£$^.0 a will be reflected in costs of
initially resins .
$12.5 Abundant. Periodic competition
for sulfur fron fertilizer in-
dustry may affect sc-asor.a 1 costs.
$18.1 Tied to chlorine manufactuie.
Prices will rise by late 1975-
, Reserves are abur.dant, ai^. in-
1 . 5~* •' creased produc t ion to meet de-
mand for supply '•••"-i tf-r t r-°a*riC'rit
should not create a r. y r, o r 1 r. J s
problems . !iev/ plants may be-
necessary .
Economically ur.de. j lrabl£ , =i"hc:i
Cellulose acetate not competl tive, may be used In sj:ecii.il c ssfrs of
high organic coricen-, rations.
Cellulose acetate c^n easily be
produced to neet small cemands .
46,000 0.61J
tons
9,590 ft 3 0.28J
of bauxite
production
$2. 2 Abundant .
$1 . 7 See Alum.
aLir.t prlcc-s as of April IB, 1975  for laree lots f.u.b. Kew York.

bSae text for further eiplan.it Ion.

C1PDWS •= Interim Prlmry Drlnkinc  Water Standards.

dKeflccf. clu'r.lc-il -.'jpp'y ItvJu.-.l ry Ir.i'fe.-slons  li'i.-.orl on current u = :jr.e Irenrl:; In the tn I o r
 supply )n.lu.".l.r;;.  If U.ere or,- or.y }:•:•(.:• a.-aJv iechnol,,r.y shifts this outlook vwuKI ~],.,
                              -123-

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                        TABLE 5-3
  NUMBER OF COMMUNITY SYSTEMS WHICH WILL NEED TREATMENT
  	TO MEET PROPOSED INTERIM PRIMARY
              DRINKING WATER REGULATION'S'
                                    PRIMARY
  TREATMENT                      CONTAMINANT(S)   NUMBER OP
                                    TREATED        SYSTEMS
Q
Chlorination
Activated Carbon
Coliform
CCE
5,557
162
Clarification0   Direct
                 Filtration
Ion Exchange
            b,d
Activated Alumina

pH Control13
                 b
Turbidity
Fluoride

Pb, As
2,126
Ba, NO   Cd,     2,481
Cr, Se, Ra, Hg
1,702

  684
     Q
      Assumes 27-5 percent of systems in EPA Community Water
Supply Inventory without disinfection will install chlorina-
tion facilities.

      Based on number of systems violating one or more
maximum contaminant levels in the 1969 CWSS study.

     GAssumes all systems in EPA Community Water Supply
Inventory without clarification will install clarification
facilities.

      Includes 761 systems estimated to violate mercury
standard.
                           -124-

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     Alum is presently the flocculant most widely used in
the water treatment industry.  It is a low-cost material
and its use can be enhanced, as is discussed later, by the
addition of polyelectrolytes.  Alum production in 1973 was
2.27 billion pounds (1,136 million tons), approximately 26.5
percent (640 million pounds) of which was used in the
treatment of supply water.  Projections indicate that a
maximum additional 370 million pounds would be necessary to
meet the new standards, depending on the ability of the
newly developed electrolyte coagulants to displace alum.
Opinions from the manufacturing industry presently indicate
that the future supply of alum to meet this demand should
not be a problem.  Bauxite is the key component of alum.
Its production was 1,812,000 long tons in 1972 and it is
presently viewed as a plentiful resource.  Bauxite is an
extremely abundant material, although the majority of
reserves are located in the less industrialized countries.
As such, it must be transported long distances to conversion
and consumption centers, and its availability is sensitive
to changes in the political climates of some areas.  World
reserves total about 5-8 billion tons, most of which are
found in Guinea and Jamaica.

     World production of bauxite has generally grown at the
rate of 10 percent per year.  U.S. demand for aluminum is
expected to grow annually between 3-5 and 5-8 percent for
non-metallic uses.  While serious shortages of low-grade
bauxite are not expected to develop, the United States will
have to depend on foreign exports for its aluminum compounds
since domestic supplies are small and difficult to mine.
Alum accounts for $20.5 million of current water treatment
costs, and may cost as much as an additional $16.2 million
by 1980, dependent on the factors discussed above.  The
largest producers of filter grade alum are Allied Chemical,
American Cyanamid, DuPont, Essex, Monsanto, Olin, and
Stauffer.

     Ferric salts, and particularly ferric chloride, are a
second group of coagulants which are used in water treat-
ment.  In the past, the use of ferric chloride has been
restricted in water treatment because it is corrosive to
most common metals and consequently to pipes. It is expected
that the advent of new pipe and storage tank materials,
particularly PVC, fiber glass, and plastic- or rubber-lined
pipes and tanks, will allow wider use of ferric chloride.
The advantages of ferric chloride are:
                               -125-

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      1.    Compared to alum,  only one-half to two-thirds
           as much ferric chloride Is required for
           coagulation.   Although it is currently about
           twice the price of alum, its cost is competitive;

      2.    A treatment plant  using ferric chloride can
           be operated on an  optimum pH, rather than at
           low coagulation pH, which is corrosive.  This
           eliminates post-coagulation lime and/or phosphate
           addition, and the  cathodic protection necessary
           in alum treatment  plants;

      3.    Ferric chloride is superior to alum in
           removing undesirable color from water;

      4.    Storage capacity and operation and maintenance
           allocations are reduced when ferric chloride
           is used instead of alum.
     Preliminary estimates show that ferric chloride may
account for 15 to 20 percent of the supply water coagulant
market by 1980, reaching sales of between $2 million and $3
million.   Total production of ferric chloride may reach as
high as 280 million pounds by the same year.  Chloride is
produced by the reaction of metallic iron with recycled
ferric chloride to produce ferrous chloride and then further
reaction with chlorine gas to .produce ferric chloride.  It
is also made by the direct chlorination of waste pickle
liquor from titanium oxide manufacture.  Iron supplies are
presently viewed as "inexhaustible", although the United
States must now import about one-half its supply.  Chlorine
is abundantly produced,  although it can be sensitive to
fluctuations in power generation.  The high price of both
chlorine and scrap iron may put economic stresses on the
production of ferric chloride.  Major producers of ferric
chloride are Allied Chemical, Chem-Met, Conservation Chemical,
Dow Chemical, Pennwalt,  Southern California Chemical, and
Steel Chemical.  Supply is not expected to be a problem.

     The third class of coagulants to be considered are the
organic polyelectrolytes or synthetic organic polymers.
Basically, these polymers are synthesized from monomeric
sub-units, many of which may be toxic to the human body in
certain dosages.  Since all polymers carry a certain amount
of residual monomer, the distribution of these chemicals
must be controlled.  A partial listing of some-U.S. Public
Health Service-approved synthetic polymers is given in Table
5-4.
                             -126-

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                           TABLE  5-4
    SYNTHETIC  ORGANIC  POLYMERS  APPROVED FOR WATER TREATMENT'
  MANUFACTURER
  PRODUCT
                                MAXIMUM
                             CONCENTRATION
                            RECOMMENDED BY
                           MANUFACTURER,  ppm
Allyn Chemical Co.

North American Mogul
  Products Co.
American Cyanamid Co

The Burtonite Co.

Dow Chemical Co.
North American Mogul
  Products Co.
Dearborn Chemical Co.


Key Chemicals,  Inc.



Betz Laboratories, Inc



Drew Chemical Co.


Electric Chemical Co.

Metalene Chemical Co.
Claron                             1.5


Claron #207                        2
(identical to Claron)
Mogul CO-980                       1.5
(identical to Claron #207)

Magnifloc 990                      1

Burtonite #78                      5
Separan NP10 potable water grade   1
Purifloc Nl?                       1


Mogul CO-983                       1
(identical to Separan NP10
 potable water grade)

Aquafloc 422 (identical to         1
Separan NP10 potable water grade)
                                  25
Key-Floc-W
(a 4$ aqueous solution of
 Separan NP10 potable water grade)

Poly-Floe 4D                      25
(a 4% aqueous solution of
 Separan NP10 potable water grade)

Drewfloc                           1.8 alum
                                0.5:10 lime

Ecco Suspension Catalyzer #146     3-5

Metalene Coagulant P-6             5
    ar
     The  names  of more recent approvals may be obtained by
consulting the  current waterworks literature -
                               -127-

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     Basically,  polyelectrolytes may serve three different
functions in supply water treatment:

     1.    As flocculating agents which agglomerate
          suspended and colloidal materials;

     2.    As flocculant aids when used in conjunction
          with inorganic coagulants for the optimum
          reduction of turbidity and removal of
          color and odor;

     3.    As filter aids:  polyelectrolytes produce
          stronger floe than alum or ferric salts,
          and consequently allow increased flow
          through filters.

Some of the monomers used in the production of supply water
treatment polymers are available in copious quantities,
while others appear to be in short supply.  A telephone
survey showed that adequate supplies will be available to
insure that future demands can be met.


     Polymers are advantageous in that they improve perfor-
mance and lower the costs in water clarification and are
generally biodegradable, small in volume, easily incinerated,
and effective under varied pH and temperature conditions.
They appear to be cheaper on the whole than alum or ferric
salts per million gallons of water treated.  Upper bounds on
treatment costs are estimated at $100 per million gallons,
with the range of unit costs at $0.40 to $2.50 per pound of
solid polymer.  Dosages are on the order of 0.1 to 4.0 mg/1
for clarification, as compared to 5 to 4.0 mg/1 alum and
3 to 20 mg/1 ferric chloride.  One source has estimated that
polyelectrolyte coagulants will displace 50 percent of all
other flocculants by 1980, although it seems unlikely that
such a drastic change will be made in such a short amount of
time.  Projections indicate that 10 to 20 million pounds of
polymers will be utilized by the water treatment industry by
1980, at a cost of $10 to $20 million.  Key producers are
American Cyanamid, Dow, Hercules, Merck-Calgon, Nalco,
National Starch, Ruchhold, Rohm and Haas, U.S. Filter, and
Vistron.

     Currently, municipalities use coagulants more than
industries, and coagulants are used more for water clari-
fication than for wastewater treatment.  However, the
increasing use of coagulants to treat industrial wastewater
is expected to change this ratio (Table 5-5).
                           -128-

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                        TABLE 5-5

              COAGULANTS BY END MARKETa'b
     ITEM                              1970       1980
                                        ( ft \         ( a< \
	_____	i. 10 )	( io )

WATER CLARIFICATION
   Municipal                              31          25
   Industrial                             32_          33.
                        TOTAL             63          58
WASTEWATER TREATMENT
   Municipal                              29          30
   Industrial                             8          12
                        TOTAL             37          42
ALL WATER TREATMENT
   Municipal                              60          55
   Industrial                             40          45
                        TOTAL           100        100
     aA.C.  Gross, "Markets for Chemicals Grow and Grow,"
Environmental Science and Technology, 8(5): 415, May 1974
     bNo consideration of Interim Primary Drinking Water
Regulations Implementation, and drinking water effluent
guidelines  in these predictions.
                           -129-

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     The predicted demand curves for coagulants are shown in
Figure 5-2.   These predictions were made before the primary
drinking water regulations were developed and thus do not
reflect an increased demand for coagulants in order to meet
those standards.

     In addition to an increasing demand for polymers as
coagulants,  it is anticipated that in the coming decade
polymers will be in increasing demand for use in advanced
oil recovery.

     All chemical coagulant manufacturers and suppliers
surveyed indicated that there would be essentially no time
lag in the delivery of materials due to a sudden demand
arising from the implementation of the Proposed Interim
Drinking Water Regulations. However, at the time of the
survey most  of the major manufacturers contacted were unaware
of the impact of the Proposed Interim Primary Drinking Water
Regulations.  It is reasonable to assume that a rapid growth
of the water supply industry's demands for certain chemicals
could cause  spot shortages of key chemicals if no advanced
warning is given to the chemical suppliers.  Buying is
generally based on a bidding procedure and award of sales
contract.  One year may pass before the material is actually
sold; however, since It is over two and one-half years
before a treatment system can be designed and constructed,
ample time should be available for treatment plants to
locate suitable chemical suppliers, provided the chemical
industry is  aware of the projected chemical demands.
     5.1.2  Disinfection

     Disinfection is another major treatment process whose
increased use would be required by the Proposed Interim
Primary Drinking Water Regulations.   It is estimated that
approximately 5,557 community systems would require addi-
tional disinfection, and that many of the 200,000 non-
community suppliers would need biocidal treatment.

     Calcium hypochlorite-  sodium hypochlorite, and other
inorganic chlorine compounds should continue to show a fast
growth rate.  They are expected to be ideal biocidal agents
for non-community water supplies because they are easily and
safely handled in cylinders, and pose little threat of rapid
dispersal if injected suddenly.  Hypochlorites also reduce
capital costs.  Olin Chemical, the largest manufacturer
(50,000 to 60,000 tons/year), produces calcium hypochlorite
under the trade name HTH.  It is composed of 70 percent free
                              -130-

-------
1
I--
LO
I—'
I
                $Million
                80
                60
                20
Other inorganics
                                                          Organics
                                                                              Alum
Ferric salts
                    1970
                           1975
           1980
                          Figure 5-2.   Shows water and wastewater treatment chemical
                     sales for coagulants.a>b
             a
              A.C. Gross, "Markets for Chemicals Grow and Grow," Environmental Science
        and Technology, 8_(5): ^15, May

              No consideration of Interim Primary Drinking Water Regulations implementation
        and drinking water effluent guidelines in these predictions.

-------
available chlorine and 30 percent inert salt compounds.
Other major producers are Pennwalt (15,000 to 16,000 tons/
year), and PPG (8,000 to 10,000 tons/year).  Production of
hypochlorite is presently at capacity since there is a
strong demand for its use as a disinfectant in swimming
pools.  There are a total of six plants in the United States
which produce hypochlorite.1  Due to the present supply and
demand balance, price hikes are expected to be forthcoming.
Consumption of hypochlorites may reach 300 million pounds by
1980, but a breakdown by industry was not easily available.
The total cost of hypochlorites for water treatment is
expected to reach an additional $8.2 million by 1980.
Delays may occur until production facilities can be expanded.
However, the industry is presently expanding to keep pace
with anticipated demands.
     5.1.3  Activated Carbon

     Removal of CCE organics from water systems which violate
the Proposed Interim Primary Drinking Water Regulations would
generally involve adsorption treatment using activated
carbon.

     It has been estimated that 3.4 percent of all community
water  systems would need treatment for CCE organics based on
violations found in the CWSS study; this amounts to about
160 plants.  The initial carbon requirement was developed by
assuming a surface application rate of 2 gpm/ft^, a bed
depth  of 2.5 ft, and a density of 25  Ib/ft3.  Using these
assumptions an initial carbon requirement of 2,045 tons was
calculated.  If one assumes that systems serving 5,000 or
more people will regenerate their carbon (losing 5 percent
each regeneration) and regenerations  will occur every other
month, then 1,676 tons of carbon would be required per year.
If regenerations occur monthly, then  3,353 tons would be
required per year.

     Activated carbon can be utilized in either a granular
or powdered form.  The granular form  is most often utilized
in water treatment and is supplied at about 37 to MO cents
per pound  (Figure 5-3).  Westvaco, by far the  largest producer
       Chlorine Institute, North American  Chlor-Alkali  Industry
 Plants  and Production Data Book (New York,  January  1975),
 P.  5.
                            -132-

-------
I
1—•
uo

I
g  20
o
 f
r-i

X
   15
-p
to
8  10
d
         Based on carbon price of
                                               2     35         10
                                                             o
                                                Production (m /day)
          Figure  5-3-   This figure shows the carbon replacement costs.

-------
of activated carbon,  presently produces granular carbon in
quantity and expects  to begin on-line manufacture of
powdered carbon in quantity by mid-June of 1975-  Additional
carbon to meet the standards would cost about $4 million per
year.

     Present production of activated carbon is estimated at
about 85,000 tons/year, most of which is manufactured from
coal or from animal and vegetable chars. The carbon is
activated by treatment with superheated steam or acid to
increase its surface  area-to-weight ratio, which in turn
increases its adsorption capability.  (Bone char is made by
calcining degreased bones in the absence of air.)  Supply of
carbon appears to be  quite adequate-  Reserves are ample for
the future and are of minor concern in production of carbon
for non-fuel uses.

     Activated carbon is used in many pollution control
efforts; competition  for the available activated carbon
could become acute as more pollution abatement takes place.

     Major producers  are Westvaco, followed by American
Norit, Atlas Chemical, Calgon, Barneby-Cheney, National
Carbon, Pittsburgh Chemical, and Witco.  These manufacturers
might need to build several new plants to meet the nearly 6
percent increase in demand which would result from implemen-
tation of the new regulations.  Again, with this chemical it
is necessary that the chemical suppliers be apprised of
potential demand caused by implementation of the proposed
interim regulations so that demand will not outstrip supply.
     5-1.4  Projections

     Implementation of the Proposed Interim Primary Drinking
Water Regulations would place heaviest demands on the coagu-
lant and the disinfectant chemical industries.  Projections
show that production costs for alum, ferric chlorides, and
hypochlorites will be rising in the hear future, and that
new plants will probably have to be constructed to increase
the present near-capacity production of calcium hypochlorite,
It is generally believed that the raw materials necessary
for the manufacture of these chemicals are abundant, and
that U.S. self-sufficiency will abate any major problems in
this area.

     The increasing demand for pollution control chemicals
has caused significant price hikes in the last several years
                           -134-

-------
and there is every evidence that this increasing cost trend
will continue in the next decade.  Table 5-6 shows the
projected growth trend for several categories of water
treatment chemicals.
5 . 2  Manpower Constraints


     5-2.1  General

     Although it provides a universally required product and
is the largest industry in the United States, the water
supply industry is facing serious problems of manpower
competence and availability.  In the present modern, highly
urbanized society, water is collected, treated, and delivered
in an efficient, reliable manner-  This has been made
possible through a high degree of functional specialization
in the industry's work force, estimated to number about
180,000 (exclusive of persons holding similar positions in
consulting engineering, manufacturing, and government).1

     Non-managerial water utility personnel are classified
into 17 categories composed of (.1) the nine most common
office and supervisory positions, and (2) the eight most
common construction, maintenance and service jobs.^  These
categories are further consolidated into five functional
categories as shown in Table 5-7-

     The level of employment in the water utilities field
has been relatively stable for the last 20 years.3  However,
with (1) increased attention on ecological and consumer
issues; (2) more stringent requirements on water product
quality; (3) rising public demands for better quality
water; and (.4) technological improvements in the design and
operation of water supply facilities, the industry is faced
with growing needs for qualified personnel.  In order to
continue to meet its vital responsibilities, the water
     1H.E. Hudson and F. Rodriguez,  "Water Utility Personnel
Statistics," JAWWA, 6^: 8, 1970.

     2American Water Works Association,  "1974 Survey  of Water
Utilities Salaries, Wages, and Employee  Benefits," JAWWA,  67:
7, 1974.

     •^C.M. Schwig,  "Training and Recruiting  of Water  Utility
Personnel," JAWWA,  6(5:  7, 1972*.
                              -135-

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                       TABLE 5-6
       WATER AND WASTEWATER TREATMENT CHEMICALS
                                               a

ITEM
MILLION POUNDS
Coagulants
Filter Media
pH neutralizers and Salt
Biologicals
Internal Preparations
Total Volume
Cents per Pound
MILLION DOLLARS
Coagulants
Filter Media
pH Neutralizers and Salt
Biologicals
Internal Preparations
Total Value
Industrial and municipal
Water Consumption
(Tgal)
Lb/M gal
1970

1,326
556
5,950
993
484
9,309
4.1

56.7
48.0
64.6
71-9
143.0
384.2


95.6
97
ANNUAL
1980 PERCENT CHANGE
1970-80

2,085
926
11,925
4,427
870
20,233
4-7

126.0
115.9
152.8
200.4
348.0
943.1


146
139

4.6
5.2
7.2
16.2
6.1
8.1
1.4

7.6
9.2
9-0
10.8
9.3
9-4


4.3
3-6
Gross National Product
   ($ billion)

Antipollution Chemical
   Sales/$QOO GNP
 974    1,900
0.39
0.50
6.9

2.5
   Gross,  "Markets  for Chemicals  Grow and Grow," 1974.
                          -136-

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                       TABLE 5-7


         WATER UTILITY PERSONNEL CATEGORIES21
  FUNCTIONAL CATEGORY            COMPONENT PERSONNEL
    Production               Plant Operators,  Equipment
                             Operators,  Maintenance
                             Mechanics


    Distribution             Foremen, Pipe Fitters,
                             Laborers, Servicemen


    Consumer Service         Meter Readers, Meter
                             Repairmen


    Financing                Accountants, Bookkeeping
                             Machine Operators,  Cashiers


    Administration           Superintendents,  Clerks,
                             Secretaries, Stenographers,
                             Telephone Operators
     aAWWA, "1974 Survey of Water Utilities Salaries,
Wages, and Employee Benefits."
                      -137-

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supply industry must have the ability to attract and retain
qualified manpower in all functional groups.  Manpower has
been recognized as the most important element in providing
high quality water service.1

     Manpower difficulties in the industry are the result of
growth, automation, and environmental concern.  The manpower
difficulties are compounded since the industry has histori-
cally had trouble attracting personnel due to low wages
salaries, and benefits paid to water utility personnel.2
Tables 5-8, 5-9, 5-10, 5-H, and 5-12 all show that the
wages and benefits paid to water system employees lag behind
that of comparably trained personnel in general.  Competition
for capable personnel is intense in all industries, but is
particularly keen among those employing civil, sanitary, and
chemical engineers.  The history of low-wage policy in the
water supply industry has resulted in an inability to attract
and retain technically trained people in a competitive labor
market.
     5-2.2  Manpower Availability

     New personnel are needed in the water utility industry
for three major reasons:

     1.   Expansion of existing systems and services;

     2.   Establishment of new systems;

     3-   Retirement and turnover of present personnel.

Water utilities vary in size from one-man departments to
those employing hundreds of people; manpower shortages are
therefore selective.  In a general sense, however, water
utility operation is becoming increasingly complex.  The
industry must continually provide water service which is
indicative not only of the technical competence of profes-
sionals in the field, but also of the living standards of
the consumers it serves.   To do this the industry needs more
managers, engineers, chemists, biologists, and other profes-
sional persons to fill technical positions.  In addition,
      G.H. Dyer, "Manpower:   The Important Element in
Providing Quality Water Service," JAWWA, 66:  1974.
     2
      G.H. Dyer, "Recruiting and Holding Good Employees:
Employee Grievance Procedures," JAWWA, 62: 8, 1970
                           -138-

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                      TABLE 5-8

UNITED STATES WATER UTILITY MANAGERS SALARY SURVEYS
                     1968-1974^
AVERAGE ANNUAL SALARIES REPORTED

POPULATION SERVED:
<1,000
>250,000
AVERAGE SALARIES:
All Respondents
Government- Owned
Investor-Owned
(Inv . -Govt . )
Percent Dlff.
(Using Govt. as base)
1968
($)

5,778
70,500

10,5^0
10,364
12,182
(1,818)
18
1974
($)

9,347
76,625

13,818
13,513
16,420
(2,907)
22
Percent
Increase

62
9

31
30
35



 YEAR
     QUESTIONNAIRES
RETURNED         SENT
              PERCENT
 1968

 1974
 1,500

 2,147
3,500
4,800
43
45
    aAW¥A, "1974 Survey of Water Utilities
 Salaries, Wages, and Employee Benefits."
                       -139-

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                         TABLE  5-9


  UNITED STATES AVERAGE SALARIES AND WAgES (AWWA SURVEYS)
           AND PERCENTAGE INCREASES, 196»-1974a
Classification
Average Salary
Period 1968
($)
or Wage
1974
($)
Percentage
Increase
1968-1974°
Manager
Division
Superintendent
Foreman
Accountant
Billing Clerk
Clerk
General Office
Secretary
Stenographer
Telephone
Operator ,
Receptionist
Cashier
Pipe Fitter
Maintenance
Mechanic
Equipment
Operator
Laborer
Serviceman
Meter
Repairman
Plant Operator
Meter Reader
Annual
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Hourly
Hourly
Hourly
Hourly
Hourly
Hourly
Hourly
Hourly
10,540
196
142
142
94
93
110
104
93
91
3.03
3.06
2.91
2.27
2.88
2.91
2.91
2.65
13,818
223
202
206
145
137
152
149
127
127
4.38
4.47
4.33
3.67
4.25
4.23
4.24
3.90
31
14
42
45
54
47
38
43
37
40
45
46
49
62
48
45
46
47
     Q
      AWWA,, "1974 Survey of Water Utilities Salaries Wages
and Employee Benefits."

      In 1957 average manager's salary was $5,960: in 1963
it was $8,457.
     Q
      From 1957 to 1968 increase was 42 percent; from 1963
to 1968 it was  25 percent in manager's salary.
                         -140-

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                       TABLE  5-10


          MEDIAN WATER UTILITY MANAGER SALARIES
        COMPARED TO  MEDIAN SALARIES  FOR ENGINEERS
                    IN PUBLIC UTILITIES
                                  1968           1974
  Water Utility  Managers          9,831         13,803
    Median Salary ($)
  Public  Utilities Engineers    15,952a        19,780b
    Median Salary ($)
  Percent Difference              39             30
     a!969 Median salary as reported in Prof.  Engr.,  42:
2:  10,  February 1972.

     b!973 Median salary as reported in NSPC Survey,  1973
(AWWA Report).
                           -141-

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                          TABLE 5-11
         WATER UTILITY EMPLOYEE BENEFITS, 1974 SURVEY
                                                     a
TYPE OF BENEFIT
               DESCRIPTION
Unionism
Vacation
PERCENT OF UTILITIES HAVING UNION CONTRACTS

  Ownership             1969       1974

  Government (G)         25         33

  Investor (I)           29         40


Trend toward unionization of production,
distribution, and maintenance employees.


PERCENT OF UTILITIES OFFERING NOTED VACATIONS
Number of Weeks Vacation
Number of
Years Employed
1
2
10
15
20
25
Two
G I
62 61
86 94
—
_
_
—
Three
G


67
46


I
_
—
76
46
_
—
Four
G
_
-
-
_
55
49
I




66
45
                    Trend toward longer vacation allowances.
Sick Leave
Fifteen days allowance per year for more than
one year of service is the most accepted
practice by both G and I owned utilities.
Pensions
PERCENT OF UTILITIES PAYING FULL COST OF

Ownership
Government
Investor
PENSION PLAN
1969
15
50

1974
20
60
     a,
     "AWWA, "1974 Survey of Water Utilities Salaries, Wages, and
Employee Benefits."  JAWWA, 6j_: 5, 1974.
                              -142-

-------
                    TABLE 5-11 (Cont.)
TYPE OF BENEFIT
                DESCRIPTION
Pensions (Cont.)
Payment of entire cost of pension plans is
becoming more common; investor-owned utilities
and utilities in large cities are more likely
to pay the entire cost; for utilities having
contributory pension plans, a 50-50 balance
of employer-employee payment is widely used;
private pension plans more common to larger
utilities and more likely to include all
employees.
Retirement
Holidays
PERCENT OF UTILITIES FORCING RETIREMENT AT
Retirement
65
70
GIVEN AGE
Age 1969
47
26
197^
53
21
AVERAGE NUMBER OF PAID HOLIDAYS BY UTILITY SIZE
                      Ownership
                      Government
                      Investor
                      Population Served
                    <1,000       >250,000
                      7.7          10.2
                      6.7          10.2
Overtime
                                                      G

                                                      3


                                                     31
PERCENT OF UTILITIES NOT HAVING AN OVERTIME
               PAY POLICY

For construction, operation
  and maintenance employees

For supervisory and office
  personnel                      31    27

  Percent paying 1.5 times
    regular pay rate             76    83

  Percent paying 2 times
    regular pay rate              1     2

  Percent having guaranteed
    work week for employees      43    33
                              -143-

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                   TABLE 5-12
   COMPARISON OF U.S. CHAMBER OF COMMERCE8" AND
        AWWA EMPLOYEE BENEFITS SURVEYS
AVERAGE COST OP ALL             USCC       AWWA
EMPLOYEE BENEFITS               1973       1974
Percent of Gross Payroll        39-5       33-5


Dollars per Hour Worked          1.876      1.907
     o
      The Chamber of Commerce survey was based
on payroll figures for 1973,  one year prior to
the AWWA survey.
                         -144-

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the level of competence of non-technical personnel must be
Increased through training and advancement incentives.

     Despite high national unemployment rates, the reservoir
of unemployed manpower does not include many people required
by the water supply industry today.1  The industry's
greatest need is for civil, sanitary, and chemical engineers,
who have the lowest incidence of unemployment among
engineers.  Technical people trained in other disciplines
are not attracted by the lower salaries and benefits offered
by water utilities.  Professionally trained engineers are
not needed for every manpower deficit, however.  In fact, a
major element in the solution of manpower problems would be
the utilization of available manpower.  Babcock^ points out
that highly technically trained people are not needed in
some of the middle levels of water supply systems, and that
sources of adequate personnel include (1) junior colleges
and universities,  (2) training schools, (3) transfers from
industry, and (4) in-house advancement.  He further notes
that "...a successful key to any recruiting program is to
campaign at all levels actively, by all people, to bring the
salary levels of personnel to reasonable values."3

     Another aspect of solving the manpower crisis would be
the utilization of training and professional improvement
programs.  Sources of training for water utility personnel
include (1) junior colleges, (2) operators associations, (3)
commercial-development organizations, (4) in-house programs,
and (5) Federal and state programs.  Many utilities support
professional growth by word; few reward it financially 3
The lack of adequately trained personnel in the industry
would be alleviated by industry-wide support of professional
improvement at all levels of employment.

     The owners, customers, and regulatory components of the
water supply industry must recognize that if it is to
provide continued good service, water rates must allow for
improved industry salary and benefit policies to interest
and motivate qualified people.  Reliable and competent
      Dyer, "Manpower:  Important Element in Quality of
Water Service," 1974.

     2R.H. Babcock, "Recruiting - A Proposal for Action,"
JAWWA,  66_: 7, 1974.

     3Babcock, "Recruiting - A Proposal for Action," 197^.

      Schwig, "Training and Recruiting of Personnel," 1974.
                               -145-

-------
personnel are as necessary to the industry as conduits,
impoundments, and treatment facilities.  People of many
different academic and non-academic disciplines would be
needed to allow adequate water service to continue in the
face of rapid growth.   Qualified people can be attracted to
and retained by the water supply industry if it (1) gives
proper attention to publicizing the advantages of water
supply careers; (2) utilizes manpower resources more
effectively; and (3) provides salaries and benefits comparable
to other utilities and industries.1
     5.2.3   Personnel Required to Implement Interim Primary
             Drinking Water Regulations

     This section estimates the manpower necessary to
implement the Proposed Interim Primary Drinking Water
Regulations.  The responsibilities of this implementation
would encompass all levels of government, Federal, state and
local, and many diverse categories of both basic and support
services.  The professional people involved would include
engineers, sanitarians, chemists and microbiologdsts; these
would be supported by technicians, geologists, attorneys,
planners, data processing personnel, system analysts,
information specialists, educators, and clerical personnel.

     For this study, a framework of the activities necessary
for the implementation of the regulations was first chosen.
Many of these could immediately be deduced from the proposed
regulations, while others had to be added based on general
requirements attributable to any successful national program.
An estimation of the average number of man-years was made;
routine task allocations were more easily estimated than
non-routine activities, but these estimates can be modified
as new data become available.  For example, it is difficult
to determine the additional amount of monitoring which
would be required for those plants which exceed a particular
regulation, since it is impossible to predict how long it
would take to locate and rectify the source of the contaminant
     5-2.4  Monitoring and Enforcing

     This section delineates the additional manpower required
to do the routine microbiological, radiological, and chemical
      Dyer, "Manpower:  Important Element in Water Service,"
                               -146-

-------
monitoring and analysis required by the Proposed Interim
Primary Drinking Water Regulations.  The microbiological
manpower requirement is outlined in Table 5-13.  Table 5-14
gives a breakdown of laboratory manpower requirements for
chemical monitoring for community systems, while Table 5-15
gives the same information for non-community systems.  It is
assumed that no manpower is presently performing the chemical
analyses required by the proposed regulations.

     One additional component of the monitoring and surveil-
lance costs is associated with state surveillance of drinking
water systems.  Jeffrey estimates that 4 man-days of field
time per system are required annually to accomplish this task
for community systems, and 1 man-day for each non-community
system.1  This amounts to 360,000 man-days or 1,636.4 man-
years to examine all community drinking water systems.  Table
5-16 gives a breakdown by states of the number of field
personnel presently assigned to accomplish this surveillance.
In addition, Table 5-16 tabulates the number of laboratory
personnel in each state.  Of the 19 states which supplied
information on inspectors, the average was 7.1 inspectors per
state, or a projected national total of 358 surveillance
personnel.  This means that over four times the present number
of surveillance personnel would be necessary to adequately
monitor the interim regulations.
     5.2.5  Operation of New and Retrofit Process Equipment

     Implementation of the regulations would uncover many
systems which require installation of treatment instrumen-
tation and its concomitant requirements of operational
personnel.  The exact requirements of manpower would vary from
system to system, depending on the sophistication of the
equipment and the amount of production.  For example, chlori-
nation units need a minimum of daily surveillance; ion
exchange needs daily surveillance, backwash, and either
regeneration or replacement.  The total estimated manpower
required is 15,969 man-years (Table 5-17).  Table 5-18 shows
the average number of employees presently employed for
different treatment systems by population served.
      E.A. Jeffrey, "Water Supply Training and Manpower Needs,"
Journal of New England Water Works Association (Washington,
D.C. , June 1972) .                     ~~~
                               -147-

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                                             TABLE 5-13
                                MICROBIOLOGICAL STAFFING REQUIREMENTS
oo
I

POPULATION
RANGE
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1, 000, 000
AVERAGE3^
POPULATION
SERVED
60
250
700
1,500
3,400
6,800
23,633
242,700
3,074,800
NUMBER OF
SYSTEMS
7
15
5
5
2
1
2


40
25S 200
ADDITIONAL
,008
,113
,392
,182
,605
,858
,599
236
7
,000
,000
MANPOWER
NUMBER OF MANPOWER
COLIFORM NUMBER OF , REQUIREMENT
ANALYSIS PLATE COUNT (man-years)
. (1,000) (1,000) (220/day/year)
168
363
129
124
125
178
956
391
37
4,800,000 2,
REQUIRED FIRST
84
181
65
62
31
22
103
39
3
400,000
YEAR:
71
154
55
52
44
56
300
d
d
735
2,045
2,781
.6
.5
.1
.8
.3
.8
.8


.9
.5
.4
            aAssumlng present average population in nine population ranges.


             Use required number of analyses per population served.


            °Assume 0.5 man-hours per sample.  This includes sample collection, analysis,

       and reporting.


            dAssume this monitoring is presently being done.

            eFor 200,000 systems serving non-community public — assume operate 12 months

       and only serve 25 people.

-------
                                                            TABLE 5-14


                         LABORATORY MANPOWER REQUIREMENTS — NATIONWIDE MONITORING OF COMMUNITY SYSTEMS
I
I—'
-Cr

a h
ANALYSIS
COMPONENT MAN_YEAR



ANALYSES0 REQUIRED NATIONWIDE
FIRST TWO YEARS

Routine
As
Ba
Cd
Cr
CN
F~
Pb
Hg
NO;
Se3
Ag
CCE
Pesticides
& Herbicides




1,400
6,600
2,200
6,600
2,200
6,600
2,200
4,400
6,600
4,400
6,600
660
198





25
25
25
25
25
25
25
25
25
25
25
25






,100
,100
,100
,100
,100
,100
,100
,100
,100
,100
,100
,100







Violator"3
1,965
660
2,625
1,965
0
23,445
3,930
7,245
14,535
5,595
0
2,370
0





THIRD
YEAR
MAN-YEARS OF ANALYTICAL EFFORT
FIRST SECOND THIRD
Near
Violator


9
7

11
12
10
5
22








270
0
,700
,500
0
,900
,200
,800
,950
,900
0
270
0

Total
Total
Total
Total
Total
27,335
25,760
37,425
34,565
25,100
60,445
41,230
^3,145
45,585
53,595
25,100
27,740
25,100

Metals
F~ + CN~
Organic

Routine
20,200
20,200
20,200
20.-,200
20,200
20,200
20,200
20,200
20,200
20,200
20,200
20,200
20,200


+ NOZ
j


6.2
3-9
17.0
5.2
11.4
9.2
18.7
9-8
6-9
12.2
3-8
42.0
126.8

76.8
27.5
168.8
273-1

6.2
3-9
17.0
5-2
11.4
9.2
18.7
9-8
6.9
12.2
3-8
42.0
126.8

76.8
27-5
168.8 ..
273-1

4.6
3.1
9.2
3.1
9-2
3.1
9.2
4.6
3.1
4.6
3.1
31.0
102.0

41.5
15-4
133.0
189.9
              aPersonal communication E. McFarren and H. Nash, EPA Cincinnatti, June 1975-

              bPersonal communication J. Dice - Denver Board of Water Commissioners, March 1975.

              °Estimates based on 1969 CWSS study.

              ^Assuming an average of 30 analyses for each violation.

-------
                                            TABLE 5-15
                            LABORATORY MANPOWER REQUIREMENTS NATIONWIDE
                                     FOR NON-COMMUNITY SYSTEMS
un
o
I
COMPONENT ANALYSESa'b
MAN- YEAR

As
Ba
Ca
Cr
CN
P~
Pb
Hg
Noq
SeJ
Ag
CCE
Pesticides

4,400
6,600
2,200
6,600
2,200
6,600
2,200
4,400
6,600
4,400
6,600
660
198
ANALYSES0 REQUIRED NATIONWIDE MAN-YEARS OP
EACH OF FIRST SIX YEARS ANALYTICAL EFFORT
Routine
33,333
33,333
33,333
33,333
33,333
33,333
33,333
33,333
33,333
33,333
33,333
33,333
33,333
Violator
17,316
17,316
17,316
17,316
17,316
17,316
17,316
17,316
17,316
17,316
17,316
17,316
17,316
Near
Violators
3,996
3,996
3,996
3,996
3,996
3,996
3,996
3,996
3,996
3,996
3,996
3,996
3,996
Total
54,645
54,645
54,645
54,645
54,645
54,645
54,645
54,645
54,645
54,645
54,645
54,645
54,645
TOTAL ANALYTICAL SERVICES

12.4
8.3
24.8
8.3
24.8
8.3
24.8
12.4
8.3
12.4
8-,
.3
83.0
276.0
512.1
           a
            Personal communication with E.  McFarren and H.  Nash, EPA Cincinnati, June 1975.

            Personal communication with J.  Dice — Denver Board of Water Commissioners,March 1975.

           CAsumming that one-sixth of the  200,000 systems  comply each year and 1 percent
      are found to be between 75 and 100 percent of maximum and therefore must monitor
      monthly.

-------
                             TABLE 5-16


      SANITARY INSPECTORS AND LABORATORY  PERSONNEL BY STATE



                       NUMBER OF INPSECTORS     NUMBER OF LABORATORY PERSONNEL
ALABAMA
ALASKA	N  	N	
ARIZONA	8	N	
ARKANSAS	
CALIFORNIA                     N                         35	
COLORADO                       5                         "5-75	
CONNECTICUT   	3	N	
DELAWARE	
DISTRICT OF  COLUMBIA	 	
FLORIDA                        N                         N
GEORGIA	8                         13	
HAWAII	N	2	
IDAHO                          2                         3
ILLINOIS
INDIANA	2	11
IOWA	12	N
KANSAS	3	2.5
KENTUCKY	N	3.5
LOUISIANA	
MAINE	1	'_	9
MARYLAND	
MASSACHUSETTS	
MICHIGAN	lij_	L_
MINNESOTA	
MISSISSIPPI	^	
MISSOURI	
MONTANA	   N	N
NEBRASKA	3  	2.5
NEVADA		
NEW HAMPSHIRE
NORTH DAKOTA
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
lj
N
N
18
N
N
N
N
OHIO	18	22
OKLAHOMA	
OREGON	
PENNSYLVANIA                   N                          N
RHODE ISLAND                   *l                          9
SOUTH CAROLINA	N	15
SOUTH DAKOTA	
TENNESSEE	'
TEXAS	25	W
UTAH	1	N
VERMONT	
VIRGINIA	N	N
WASHINGTON    	N	N
WEST VIRGINIA	0	2.5
WISCONSIN         	
WYOMING	if	1.5
N is not known.
No entry indicates lack of response.
                                -151-

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                          TABLE 5-17
    PERSONNEL TO OPERATE NEW AND RETROFIT PROCESS EQUIPMENT
NUMBER OF EMPLOYEES
TREATMENT ADDITIONAL PER SYSTEM TOTAL ADDITIONAL
SYSTEMS (man-years) EMPLOYEES NEEDED
Chlorination
Activated Carbon
Clarification
Ion Exchange
Activated
Alumina
pH Control
5,557
162
2,126
2,481
1,702
684
Total additional process personnel
for community systems
Total additional process personnel
public non-community systems
TOTAL

0.5
1
4
1
1
0.5
required
required

2,778.5
162
8,504
2,481
1,702
342
15,969.5
3,409a
19,378.5
     a,
      Assume one-fourth of 200,000 systems require some
minimal treatment of 15 man-days per year.
                              -152-

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                                        TABLE 5-18
                  AVERAGE NUMBER OF EMPLOYEES FOR DIFFERENT TREATMENT
                                                                     a,b
PUBLICLY-OWNED


POPULATION COAG. FILT. DIS. SOFT COR. NONE
CONT.
25-99 - -
100-499 - - -
500-999 - - -
1,000-2,499 - -
2,500-4,999 - - -
5,000-9,999 - - -
10,000-99,999 31-82 29.26 53.86 32.11 27.90 15.32
39. 46 74 12 25 14
100 000-099,999 265.82 244.47 197-15 150.67 244.56
11 14 20 3 10
> 1,000,000 938.83 938.83 1521.22 - 938.83
Average No. of Employees
No. of Systems
Ave. No. Emp.
No. Systems
Ave . No . Emp .
No. Systems
Ave. No. Emp.
Np . Systems
Ave . No , Emp .
No. Systems
Ave. No. Emp.
No. Systems
Ave. No. Emp.
No. Systems
Ave . No . Emp .
No. Systems
Ave. -No. Emp.
No. Systems
American Water Works Association, "Operating for Water Utilities 1970 & 1975."
Fractions occur since part time employees are counted as 0.66 employees.

-------
                                              TABLE  5-18  (cont.)
                        AVERAGE NUMBER OF EMPLOYEES  FOR  DIFFERENT TREATMENT

                                            INVESTOR-OWNED
                                                                          a,b
     POPULATION
                    COAG.   FILT.
         DIS.
          SOFT
COR.
CONT.
NONE
J=r
I
25-99


100-499


500-999


1,000-2,499


2,500-4,999


5,000-9,999


10,000-99,999


100,000-999,999


> 1,000,000
                        21.44
                         3
22.33
 2
                        67.00  156.83
                         1       2
 18.92
  9

126.16
  4
       13.59
        9
                         78.50
                          2
         Average No.  of Employees
         No.  of Systems


         Ave.  No. Emp.
         No.  Systems

         Ave.  No. Emp.
         No.  Systems

         Ave.  No. Emp.
         No.  Systems


         Ave.  No. Emp.
         No.  Systems

         Ave.  No. Emp.
         No.  Systems

         Ave.  No. Emp.
         No.  Systems

         Ave.  No. Emp.
         No.  Systems

         Ave.  No. Emp.
         No.  Systems
     aAmerican Water Works Association,  "Operating for Water Utilities 1970 &1975."

     ^Fractions occur since part time employees are counted as  0.66 employees.

-------
                                              TABLE 5-18  (cont.)
VJl
I
                        AVERAGE NUMBER OF EMPLOYEES FOR DIFFERENT TREATMENT
                                                                           a,b

POPULATION
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
> 1,000,000
' TOTAL0

COAG. FILT. DIS. SOFT COR. NONE
CONT.
— _ _ _
— — _ _ _
— — - — _ _
~ - - - -
- - -
17.81 16.96 14.86 15.12 22 4o
30 57 7 17 16'
31.08 28.97 25-82 31.28 27 91 21 99
42 48 85 12 25 23
249.28 177.47 246.31 150.67 173 79
12 16 24 3 12'
938.83 938.83 1521.22 - 938 83
22 3 2°


Average No. of Employees
No. of Systems
Ave. No. Emp.
No. Systems
Ave. No. Emp.
No. Systems
Ave . No . Emp .
No. Systems
Ave . No , Emp .
No. Systems
Ave. No. Emp.
No. Systems
Ave. No. Emp.
No. Systems
Ave. No. Emp.
No. Systems
Ave. -No. Emp.
No. Systems
     aAmerlcan Water Works Association,  "Operating for Water Utilities 1970  & 1975."

     ^Fractions occur since part time employees are counted as  0.66 employees.

     clncludes not coded plants.

-------
     5.2.6   Program Assistance

     This facet of the overall implementation program would
be necessary to provide adequate training for local utility
managers, sanitarians, and other water supply personnel.
The National Sanitation Foundation estimates that implemen-
tation would require 1.4 man-days/year/system for each of
the community systems and 0.1 man-days/year for the non-
community systems.1
     5.2.7  Program Administration

     Program administration would be the final key element
in effective implementation of the Interim Primary Drinking
Water Regulations.   This segment can be broken down into
management, planning,  and public information.  Table 5-19
shows the total administrative manpower required for
implementation.

     Sixty-six percent of the personnel which would be
required to implement  the regulations are process personnel
who would run the treatment plants at the local level.  It
is expected that the demand for these process employees
would begin in 1979 and that one-fifth of the total number
would be employed each succeeding year for the following 5
years.

     The 14 percent of the personnel involved in monitoring
and 4.4 percent involved in surveillance would be required
by July of 1976; the remaining personnel would be employed
between 1976 and 1984.
5-3  Laboratory Constraints

     One of the factors which would determine the success of
the monitoring required under the Proposed Interim Primary
Drinking Water Regulations is the availability of laboratory
facilities which have been certified by the states.  This
section examines the availability of these facilities, as well
as institutional constraints which would either encourage or
discourage the use of specific laboratories.
      National Sanitation Foundation, Staffing and Budgetary
Guidelines for State Drinking Water Supply Agencies (Ann
Arbor, Michigan, May 1974), p. 17.
                            -156-

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                            TABLE 5-19
             SUMMARY OF MANPOWER REQUIRED TO IMPLEMENT
              THE PRIMARY DRINKING WATER REGULATIONS
FUNCTION
RESPONSIBLE AGENCY
STATE LOCALd FEDERAL
(man-years )
TOTAL
Monitoring
microbiological
o
chemical
turbidity
Surveillance
Process Operation
Program Assistance
Clerical
Program
Administration
TOTAL
2,086
589
0
959
0
282
862
392
5,170
695
196
505
0
19,378
0
694
2,077
23,545
0
0
0
319
0
94
91
41
545
2,781
785
505
1,278
19,378
376
1,647
2,510
29,260
      Assumes state will do three-fourths of the monitoring
and local agency one-fourth.

      Assumes one clerical person for every five non-process
personnel.

     °Assumes one administrator for every-ten non-clerical
employees.

      Local means water system personnel or municipal employee
                              -157-

-------
     Table 5-20 shows the number of laboratories presently
certified to perform organic,  inorganic, bacteriological,
and turbidity analyses on a state-by-state basis.  The
information on this table was  collected from a 1975 ERGO
survey of the states (Appendix B).   (Of the 34 states
responding, only 12 states had one  or more laboratories
certified to do inorganic analyses.   Eight states had one or
more laboratories certified to do organic and pesticide
analyses.  Twenty-six states had one or more laboratories
certified to do bacteriological analyses.  Three states had
a program to certify turbidimeters.)  The results of this
study indicate that at the present  time no state has an
active certification program which  would enable rapid compli-
ance with Section 141.27 of the proposed regulations.  It is
possible, however,  that many states  would be able to certify
enough laboratories by December 1976 to allow monitoring to
proceed.   It is essential that the  states develop rational
reporting and record keeping procedures so that this task will
not become onerous  for the laboratories.

     Tables B-l to  B-10 of Appendix  B show the percentages
of each analysis which are performed in in-house, private,
commercial, municipal and state laboratories in each state,
as well as the capacity and present  usage of the state
laboratories.  These tables indicate that the great majority
of the analyses are done in state laboratories and that the
majority of state laboratories are  presently working at or
near capacity.

     Table 5-21 shows the manner in  which costs for use of
the laboratory facilities are  presently being allocated by
the states.  Twenty of the 25  states responding pay 50
percent or more of  the costs of the  analysis; it is therefore
highly unlikely that municipal facilities would send their
samples to a private laboratory where the municipality would
have to pay the full price of  the analysis.  If the states
continue their present policy  of subsidizing laboratories, it
is apparent that most state laboratory facilities would have
to be expanded at least tenfold if the regulations were
implemented.  The alternatives available to the states
include the following:

     1.   Dropping  the subsidy;

     2.   Doing only partial analyses of each system,
          for example- only inorganic analyses;

     3.   Increasing laboratory facilities;
                            -158-

-------
                                   TABLE  5-20
                          LAB  CERTIFICATION  BY  STATE
                 In-               In-
                House Pri. Mun. St. House Pri. Mun. St.
                   INORGANIC           ORGANIC
 In-
House Pri. Mun.  St.
 BACTERIOLOGICAL
TURBIDITY  RESIDUAL CHLORINE
ALABAMA
AIASKA
ARIZONA
N
N
N
N
N N
N 1
ARKANSAS
CALIFORNIA
101
107
88 1
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OP COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
N
N
1
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N N
N N
N 1
N 1
N N
N N
N 1
N N
N N
LOUISIANA
MAINE
MARYLAND
N
N
N
N
N N
N N
MASSACHUSETTS
MICHIGAN
N
N
N N
MINNESOTA
MISSISSIPPI
MISSOURI
MONLANA - -
NEBRASKA
1
N
3 3
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
N
N
N
N
N N
N 1
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
16
N
2
50
N
N
N
N
2 1
N N
N 1
100 1
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
N
N
11-=!
N
N
1
N N
N N
N 1
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
N
N
N
N
4
N
N N
N 1
N N
VIRGINIA
WASHINGTON
N
N
N N
WEST VIRGINIA
WISCONSIN
WYOMING
N
N
N N

N
N
N
N
N N
N 1

23 1
07
36 2




N
N
1
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N N
N N
N' 1
N 1
N N
N N
N 1
N N
N N

N
N
N
N
N N
N N

N
N
N N



_
N
N
N N


N
N
N
N
N N
N 1

N
N
N
1
N
N
N
N
N 1
N N
N 1
1 N

N
N
N
N
N
N
N N
N N
N N


N
N
N
N
N
N
N N
N 1
N N

N
N
N N


N
N
N N

N N
N N
N
N
N
N

33
160
21




N N
N N
1 N
N 1
15 9
30 17
N 3
5 N
15 3
N
N
N
N
14
3
18
2
4
7
N
4
5
7
N
2
N
2

5 2
10 0
N
0
1
9

107 2
N
4



_
1 N
3
3


33* 31*
N N
9
N
N
1

16 N
3 N
147 22
4 N

80 185
8 5
78 1
2
1
N
4

80
N
N
1
6
22
1

3
3
5


46 N
N 1
N N
N
5
N
26
1
N

5 4
17
1


1 1
1
1

NO
NO

NO




NO
NO
NO
NO
NO
NO
NO
NO
NO

NO
NO

NO



-
NO


NO
NO

NO
NO
YES
NO


NO
YES
NO

NO
NO
YES

NO


NO

NO
NO

NO




NO
NO
NO
NO
NO
NO
NO
NO
NO

YES
NO

YES



-
NO


NO
NO

NO
NO
YES
NO


NO
YES
NO

NO
NO
YES

NO


NO
*0hio "pending"  and have approval in 6 months.
*N.J.   1)6  in-house, private are uncertified.

 N means no answer
                                        -159-

-------
                 TABLE  5-21
PERCENTAGE OF  TOTAL MONITORING COSTS BY STATE

ALABAMA
ALASKA
ARIZONA
LOCAL WATER
SYSTEM

10
90
MUNICIPAL SYSTEM

10

STATE AGENCY

50
10
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
80
N
N
20
N
N
0
N
N
DELAWARE
DISTRICT OP COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
N
0
N
0
13
5
N
40
20

50
0
N
10
N
0
2
0
N
0
10

50
0
N
90
N
100
85
95
N
60
70

0
100
MASSACHUSETTS
MICHIGAN
0
0
100
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
10
N
20
N
70
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
varies with supply
0
N
$15-$64 based on
0
0
0
0
N
sales $15- $6 4
0
0
0
100
N
>50%
100
100
100
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
each pay
5
N
N
their own way
85
N
N

10
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
N is not known.
No entry means
10
10

5
0
0

0
lack of response
0
20

0
0
0

46

90
70

95
100
100

54

                -160-

-------
     4.    Selectively analyzing specific groups of
          systems, for example, only those which
          serve 1,000 or fewer people.

     In an effort to estimate the amount of coliform testing
presently being done in industries other than the drinking
water supply industry, ERGO looked at the compliance schedules
for selected food industries and municipal wastewater treat-
ment facilities.  The monitoring frequencies, number of
plants, and number of coliform analyses presently being
performed are listed in Table 5-22, as is the additional
coliform monitoring required by the Proposed Interim Primary
Drinking Water Regulations.  The additional monitoring
mandated by the regulations is approximately 15 percent of
the monitoring presently being done in these three indus-
tries.  However, it is anticipated that the private sector
could supply ample facilities to handle the increased
laboratory load if economic incentives justify the expansion
of existing facilities.

     ERGO surveyed several major laboratories which specialize
in organic and inorganic water analyses and found one
laboratory which stated that with minimal staff additions it
could perform the entire additional chemical monitoring load
anticipated under the regulations.  Based on this response
it is felt that more than ample facilities are available to
perform all chemical analyses required by the interim drinking
water regulations.

     It appears that the major constraint on laboratories is
the lack of adequate state certification programs.
5. 4  Construction Constraints

     This section explores the capability of construction and
engineering industries to design and build the treatment
facilities which would be required under the regulations.  New
public utilities construction involves many long-term projects
and is expected to continue upward growth.

     Table 5-23 shows the trends in new construction for the
last four years.  The estimated $1.1 to $1.8 billion required
under the regulations to upgrade the nation's drinking water
supply systems would be spread over 5 years and would there-
fore represent an additional outlay of less than 0.2 percent
of the present total annual new construction.
                           -161-

-------
                          TABLE 5-22
             PRESENT COLIFORM MONITORING TO MEET
               EFFLUENT GUIDELINE LIMITATIONS
   INDUSTRY
 SAMPLING
FREQUENCY
NUMBER OP
  PLANTS
NUMBER OP COLIPORM
ANALYSES PRESENTLY
  PERFORMED/YEAR
FOOD PRODUCTS'

   1-10 mgd

  10-50 mgd
one per week    4,000
three times       550
per week
                208,000

                 85,800
WASTEWATER TREATMENT
<0.99 mgd
1-4.99 mgd
5-14.99 mgd

one per month
one per week
five times
weekly
16,200
10,200
3,600

194,400
530,400
936,000

   TOTAL
                           1,954,600
Projected coliform monitoring requirement to
implement Interim Primary Drinking Water
Regulations for community water supplies
Present coliform monitoring being done for
community water supplies

Additional coliform monitoring mandated
by Interim Primary Drinking Water Regulations
                           2,547,397


                           1,961,621


                             585,776
      o
       Marketing Economics Institute, Limited-, Marketing
  Economics Industry Key Plants, 1973; includes plants
  employing over 100 people.
                            -162-

-------
                           TABLE  5-23
                NEW CONSTRUCTION  PUT IN  PLACE:
                TRENDS AND  PROJECTIONS
(In
TYPE OF CONSTRUCTION
Total new construction
Private - total
Public - total
Residential buildings (private
and public)
Nonresidential buildings
(private and public)
Industrial
Commercial
Educational
Hospital
All other
Farm
Public utilities (private
and public)
Telephone
Electric
All other
Highways
Military
Conservation and development
Sewer and water
All other (public and private)
Billions of
1972
124.1°
93.9
30.2
55.2
34.7
5.2
13.5
6.7
4.2
5.1
1.4
13.2
3.3
7.6
2.3
10.4
1.1
2.2
2.8
3.2
1973
135. 4C
102.9
32.6
58.5
39-6
6.8
15.5
7.5
4.2
5.7
2.1
14.7
4.0
8.3
2.4
10.6
1.2
2.3
3.2
3.4
Dollars)
1974b
133.7
98.2
35.5
49-7
43.0
7.8
16.5
7.8
4.4
6.5
1.6
17.0
4.5
9.4
3.1
11.7
1.4
2.4
3.4
3.5
1973-74
PERCENT
CHANGE
-1
-5
9
-15
9
15
6
4
5
14
-24
16
13
13
29
10
17
4
6
3
1975b
149.5
111.5
38.0
58.5
45-7
8.5
17.5
8.4
4.5
6.8
1.6
19.5
5.0
10.5
4.0
12.5
1.5
2.5
4.0
3.7
1974-75
PERCENT
CHANGE
12
14
7
18
6
9
6
8
2
5
0
15
11
12
29
7
7
4
18
6
aBureau of the Census  and Bureau of Domestic Commerce.

bEstimated by Bureau of Domestic Commerce.

cDetail does not add to total due to rounding.
                                -163-

-------
     Since the amount of construction required to upgrade
drinking water systems is small compared to national
expenditures,, it is anticipated that engineering and
construction resources would be sufficient to implement the
regulations.  The building of water supply facilities,
however, requires specialized design and construction
engineering.  A 1972 survey1 showed that there were only
about 940 firms nationwide which were employed in the design
of water and wastewater treatment plants.  These firms
employed approximately 50,000 full- and part-time personnel
and were spread across the country with a low of 37 firms in
EPA Region VIII, and a high of 189 firms in Region V.  Since
this trade is so specialized and the number of firms is
limited, it is possible that some rural communities would
have difficulty locating services on a timely basis.
     5.4.1  Building Materials

     Although construction activity increased, several major
building materials came into short supply during 1974; in
particular, insulation, asphalt, fabricated structural
steel, reinforcing steel, various types of underground pipe,
precast and prestressed concrete, and metal doors and windows.
While many of these spot shortages have been resolved, it is
possible that they could recur.

     Another factor which could influence construction of
needed treatment system facilities would be recurrence of
gasoline and diesel fuel shortages, such as those which
disrupted some construction activity during the latter part
of 1973 and 1974.

     A final construction constraint could be the availability
of cement and concrete.  (There are 50 companies operating
170 Portland cement plants in the United States.)  Since
1972 the industry has been operating at well over 90 percent
of rated capacity, and it is expected that demand will out-
grow capacity increases through the rest of this decade.2
      U.S. Environmental Protection Agency, Office of Water
Programs, by E. Joe Middlebrooks, A National Survey of Manpower
Utilization and Future Needs of Consulting Engineering Firms
Employed in Water Pollution Control (Logan, Utah, 1972), p. 2.
     2
      U.S. Department of Commerce, U.S. Industrial 1975 Outlook
(Washington, B.C., 1975), p. 27.
                             -164-

-------
                       CHAPTER SIX


             FEASIBILITY OP FINANCING COSTS
6.0  Introduction

     Compliance with the proposed interim regulations set by
the EPA under the Safe Drinking Water Act would require
several types of expenditures by suppliers of drinking water.
Expenses for manpower and equipment for monitoring (sampling
and analysis), operation and maintenance, capital costs for
water treatment, and indirect costs including those for
administration would all have to be met in some way by all
water suppliers:  large, small, public (generally, municipally-
owned), and private (investor-owned).  In order to ascertain
who would pay these costs, several aspects of the present
financial situation of water utilities have to be analyzed,
including:   indebtedness through bonds; rates charged for
water sales; and relationships with local, state, and Federal
governments.  This chapter aggregates all costs developed in
previous chapters of this report and explores the financial
effect on the impacted systems.
6.1  Present Industry Financial Structure

     Although a majority of all community water systems today
have debt ratios ranging upward from 40 percent, almost one-
fourth are free of long-term debt.  Approximately 85 percent
of these debt-free systems serve communities of less than
5,000 people.1  However, these debt-free small systems are
not necessarily the most financially sound.  Income tax returns
of water and sanitary systems analyzed in the Almanac of
Business and Industrial Financial Ratios (1975 edition) show
that almost half of the small investor-owned systems failed
to show a positive net income (Table 6-1).

     Many larger water utilities that appear to be saddled
with high debt may actually be slightly better off.  Compared
with other types of utilities, water systems tend to have
high debt ratios (ratios of long-term debt to the book value
of property).  This is not surprising due to the large
     1R.C. Hyle, "Rate Philosophy," JAWWA, 63_, (11): 685,
November 1971-
                            -165-

-------
                           TABLE 6-1
             FINANCIAL  STRUCTURE OF INVESTOR-OWNED
               WATER SUPPLY AND RELATED SERVICES5""
NUMBER
SIZE OF ASSETS OF FIRMS
A TOTAL 6,
B Under $100 4,
C $100 to $250 1»
D $250 to $500
E $500 to $1000
F $1000 to $5000

G $5000 to $10,000
H $10,000 to $25,000
I $25,000 to $50,000
J $50,000 to $100,000
K $100,000 to $250,000
L $250,000 and over

o
Almanac of Business
(1975 Edition) (Enslewood
649
472
157
548
234
182

19
17
6
8
5
1

NUMBER NET PROFIT BEFORE
REPORTING TAX AS PERCENT
NET LOSS OF SALES
2,820
2,160
419
133
39
63

4
2
—
-
—
_

and Industrial
Cliffs,
New Jers
5.4
3-8
2.2
6.1
8.2
Net Loss
for Category
4.5
7-5
10.8
6.5
16.3
Net Loss
for Category
Financial Ratios
;ey: Prentice-
Hall Publishing Company,  1975).
                            -166-

-------
capital expenditures required compared to the low product
cost of water.   Since many areas have statutory limitations
on total indebtedness for public utilities and ceilings on
interest rates,  some water utilities would be able to
absorb only a limited amount of further capital expenditure
if financed by traditional means.

     Matters are further complicated by the existence of
loan covenants,  particularly coverage ratios.  Coverage
ratios for water utilities are generally defined by the
formula:


               Coverage = Net Revenues
                     &    Debt Service


where Debt Service = Interest and Principal Repayments

Unless utilities seeking additional funds are well above
their normally required coverage ratios -- which usually
range near 1.5^ -- they may well be forced to finance with
higher interest loans or more expensive common stock (for
the investor-owned utilities).

     Most utilities, both public and private, finance large
capital investments by retaining profits and acquiring debt.
Government-owned water utilities usually have access to
municipal funds and can sell either general obligation
bonds, to be repaid from general revenues (including property
taxes), or revenue bonds, which are less secure since they
are repaid from water revenues only.

     Investor-owned utilities issue stock as well as bonds,
and their credit ratings are more completely dependent on
the profitability of their own operations.  Unbacked by
governmental guarantees and tax-exempt status of municipal
utilities, their debt — particularly their common stock —
is more risky than the debt issues of government-owned
utilities.  Since interest rates are proportional to risk,
utilities in more secure financial positions can borrow
money more easily and at lower interest rates.   Government-
owned utilities have the advantage that their credit may be
      John D. Wright and Don R. Hassall, "Trends in Water
Financing," in Modern Water Rates (8th edition) edited by
Elroy Spitzer (American City Magazine, 1972).
                             -167-

-------
more highly rated.  At the present time the interest rate on
municipal bonds is 4 to 6 percent while the rate for private
(investor-owned) utilities is 6 to 8 percent.!

     In some localities, the public water system has his-
torically not been 100 percent self-sustaining.  That is,
the utilities do not meet all operating and financing costs
with revenues derived from rates; in certain cases these
costs are met with general tax revenues.  However, because
of the increasing demand for local tax dollars there is a
trend toward self-sustaining water utilities.  Indeed, some
cities and towns have levied general fund assessments against
publicly-owned water utilities, forcing them to assume the
costs of other municipal services.2  Municipal loans to
private corporations and utilities for pollution control and
treatment are allowed in some states, but courts in other
states have ruled that this assistance is unconstitutional.3
These trends have caused water rates to increase in recent
years.


     Capital investments required by the new regulations
would be financed heavily by new bond issues.  For some this
would pose no problem; others, already deeply in debt or
without the necessary credit rating, might have difficulty
in meeting the new costs.  The Safe Drinking Water Act
provides for guaranteed Federal loans up to $50,000 for
"small" public water systems, including both public and
private utilities.  Although the guaranteed loans of $50,000
under the Act ease the transition to full compliance with
the proposed interim primary regulations, they may well
prove to be insufficient alone, particularly for those
systems requiring ion exchange (Table 6-2).  Medium-sized
water utilities might need larger amounts of money and might
not be able to obtain the full amounts through bond issues
and loans not covered by the $50,000 loan guarantee provision.

     In addition to capital investments, other costs would be
incurred to meet the more rigorous drinking water regulations,
especially for increased monitoring and laboratory analysis of
water samples for inorganics, organics, pesticides, and
biological contaminants.  Although many large water utilities
      Personal communication — First National Bank of Boston,
April 1975.

     2Hyle, "Rate Philosophy," p. 68?.

      Public Works, February 1975, p. 116.
                            -168-

-------
                 TABLE  6-2


 CAPITAL COSTS FOR A MODEL WATER SYSTEM
           SERVING 250  PEOPLE



TREATMENT                 CAPITAL COST ($)

Clarification                 30,000

Ion Exchange                  68,000

Activated Carbon               4,300

Activated Alumina              6,100

Chlorination                   1,200
                   -169-

-------
presently have their own laboratory facilities and personnel
for monitoring activities,  analyses would have to be performed
for more contaminants and more frequently.  Many states now
provide laboratory services for water analysis at a subsi-
dized price; if state facilities could not be expanded
rapidly enough to meet the increased needs, private laboratories
might be able to fill the gap.  In any case, new equipment
would be needed for tests which are not now performed; the
water utilities would have to absorb the costs of analysis
into their operating budgets or pass the costs on to the
states through the use of subsidized state and private
laboratories.

     All increased operating costs for monitoring and for
additional treatment, and all increased payments of interest
and principal on (new) loans and bonds, would eventually
have to be met directly through increased revenues,
indirectly through funds from state and local tax revenues,
or from Federal grants (also tax revenues).  Private utilities
might be able to meet increased operating expenses by
retaining more earnings rather than distributing earnings to
investors in the form of dividends; however, this practice
would tend to hurt their financial position by decreasing
the value of their stock. Hence, it is not an appropriate
long-term financial strategy.

     Since the major source of revenue for most water
utilities is the sale of water to customers, the issue of
rates (or prices) is relevant.  Public water systems which
have their own collection facilities but do not sell water,
such as restaurants, hotels, and filling stations, would
probably meet increased costs by raising the prices of other
commodities; in most other cases, increased water rates
would be necessary.

     A National Association of Water Companies (NAWC) study
claims that residential sales account for 6l percent of the
income of the 105 reporting plants (Table 6-3), while a
study by the AWWA2 claims that residential sales account for
only 38 percent of the income of their 768 reporting
      National Association of Water Companies, "1973 Financial
Summary for Investor-Owned Water Utilities" (Washington, D.C.,
1973).
     2
      American Water Works Association, "Operating Data for
Water Utilities:  1970-1975"  (New York).
                            -170-

-------
                                 TABLE  6-3
                     WATER  SALES  BY  TYPE  OP  CUSTOMERa

TYPE OP CUSTOMER
Residential

Industrial

Commercial

Other

TOTAL

NUMBER OP CUSTOMERS
2,458,800
(90.77)?
206,069
(7.61)
16,316
(.60)
27,600
(1.02)
2,708,784
(100.00)
MILLIONS OP GALLONS SOLD
199,507
(44.44)
85,037
(18.94)
122,356
(27-25)
42,049
(9.37)
448,949
(100.00)
REVENUES ( $ ;
182,463,467
(61.85)
56,213,056
(19.05)
24,138,443
(8.18)
32,210,638b
(10.92)
295,025,604
(100.00)
aBased on reports of 105 companies.
blncludes fire protection revenues of $14,923,081 (5-00).
GNumbers in parentheses are percentages.
 Source:  National Association of Water Companies,  1973.

-------
utilities.  These differences in residential income are
presumably due to differences in the sizes of the reporting
systems in the two studies.  Seven of the companies of the
NAWC study serve average populations of under 1,000 people
while none of the systems in the AWWA study serve under
1,000 people.  Many of the 28,500 systems serving under
1,000 people serve only residential customers.

     Because of greater risk, lack of tax-exempt status, and
lack of direct and indirect subsidies, the investor-owned
companies have a higher cost of capital; thus the investor-
owned companies generally charge higher rates per unit than
do public systems (Figure 6-1).  Rates also vary among
systems which have different amounts of treatment.

     Prices to the consumer are determined by rate structures,
which in turn are a function of the institutional status of
the consumer (i.e., industrial, commercial, or residential)
and are also a function of the cost of producing water.
There are basically four types of rate structure:


     1.    Normal block structure

     2.    Inverted block structure

     3.    Plat rate structure

     4.    Non-incremental rate structure

     Normal block structure applies particularly to industrial
consumers and it gives a lower unit cost to the users of
higher volumes.

     The inverted rate structure assigns higher unit costs
to the largest consumers.   The rationale behind this structure
is that it encourages conservation through the economic
incentive of raising prices to larger users.

     Only a small portion of all water supply utilities are
currently using the flat rate structure.  This method utilizes
a single charge per unit for both large and small consumers.

     Non-incremental rate structures are used to charge
consumers when their water is not metered; basically, the
unit cost of water is dependent on the number of taps or of
water consumption units of equipment (i.e., toilets, faucets,
etc.) owned by the user.
                             -172-

-------
cd

 H
 a)
 bO

 O
 o
 O
 «%
 H
 \
 -e-
o
H
EH
H

!=>
UlO -



.1.30 -



1.20 -



1.10 -



1.00



 • 90



 .80



 .70



 .60



 • 50



 JIO



 .30



 .20



 .10
                N\\
              SMALL
           0,1-10 mgd
              PUBLIC SYSTEMS
              PRIVATE  SYSTEMS
             3.
                              MEDIUM
                              10-30 mgd
 LARGE
>30 mgd
              .
              There are  0.00378  nr3  per  gallon.

              Figure  6-1.   
-------
     No significant correlation exists between system size
and rate structure.  Nor does type of ownership — public
vs. private — appear to influence type of rate structure
employed.

     Prices charged for water are usually regulated by a
state or local commission appointed to evaluate the need for
rate hikes.  Investor-owned utilities in all but two states
are under the jurisdiction of state regulatory commissions.
Public utilities are either regulated by local boards or are
unregulated.   Under such- local control, water utilities
formulate rate schedules to provide the gross revenues
approved by the commissions.

     The Eastern states control their water supply utilities
more stringently than do the Western states.  This reflects
the general degree of state government control over commerce
in the country.  Public Utilities Commissions (PUC's) in the
West provide a liaison between the consumers and the utilities
by arranging public hearings for proposed rate hikes; in
general, rate increases are seldom denied in this region of
the nation.

     The situation appears to be quite different in the
East.  A good example is Connecticut, where the PUC reg-
ulates only investor-owned companies.  The Connecticut PUC
is a five-member board, appointed by the governor and
supported by a staff of engineers and technical/clerical
personnel.  They generally approve between 10 and 60 percent
of utility-proposed rate hikes per year for the water supply
industry.

     A common pitfall for many regulatory commissions in the
investigation of proposed water supply utility rate increases
is their historical viewpoint in assessing the validity of
rate requests.  For instance, it is not uncommon for a PUC
to review a private supplier's financial history of the
previous year in determining its profit.  Basically, the
assumption is:

          Revenue - Expenditures = Profit

     If this profit seems unreasonable, relative to other
utilities' profit margins or relative to past margins, the
proposed increase Is not likely to be approved.  Many
utilities are required to submit annual financial reports
for just such purposes.

     Increased public understanding of water quality as a
result of the Safe Drinking Water Act is expected to impress
                             -174-

-------
public regulatory agencies with the need for capital Invest-
ments in the water supply industry.  This process, in turn,
should aid those plants requiring additional funds for
compliance with the effluent guidelines.
6.2  Characteristics of Demand for Water
     6.2.1  Trends in Demand

     Some of the many factors influencing trends in water
use are:  the level of water and sewer service; changes in
customer bills for those services; changes in modes of
living; the growth and nature of business, industry, and
institutional services; annual variations in the local
economy as well as the long-term state of the local economy;
changes in climate; the extent of existing service-area
development and redevelopment; the ability to extend service
to additional areas; and the availability of an adequate
high-quality water supply.1

     Table 6-4 shows projections of the municipal water
requirements by the Water Resources Council; they indicate
that water requirements will double between 1965 and 1980.
     6.2.2  Uses of Treated Water

     Public water supply systems provide water service for
residential, commercial, industrial and general municipal
purposes.  An approximate allocation of the water supplied
by water utilities to various categories of users is shown
in Table 6-5.

     Non-revenue producing water results from the following
practices:

     1.   Ten gallons per 150 gallons on the average
          are lost due to system losses such as
          leakage and evaporation;

     2.   Flushing of fire control systems.
     XW.L. Patterson, "Water Use," JAWWA, 6^:  28?  (Denver,
Colorado, 1973).
                             -175-

-------
 I
M
—3
a\
 I
                                                 TABLE 6-4


                               PROJECTIONS OF  MUNICIPAL WATER REQUIREMENTS51
(Millions of gallons per

North Atlantic
South Atlantic Gulf
Great Lakes
Ohio
Tennessee
Upper Mississippi
Lower Mississippi
Souris-Red Rainy
Missouri
Arkansas-White-Red
Texas Gulf
Rio Grande
Upper Colorado
Lower Colorado
Great Basin
Columbia-North Pacific
California
Alaska
Hawaii
Puerto Rico
TOTAL
1965
905
363
502
230
46
162
175
11
221
241
400
108
14
203
94
182
1,320
7
39
21
5,244
day)
CONSUMPTION
1980 2000
1,210
600
702
300
64
258
238
16
280
496
740
220
30
310
154
219
4,620
24
65
35
10,581
1,750
1,000
953
430
95
403
343
26
339
832
1,200
400
35
515
255
350
7,350
46
106
50
16,478

2020
2,550
1,500
1,304
620
140
580
497
35
397
1,205
1,750
670
50
840
345
537
11,300
75
173
75
24,643
                            aWater Resources Council, "The Nation's Water Resources,"
                        (Washington,. D.C., 1968),  p. 4-1-3-

-------
                TABLE  6-5






COMMUNITY WATER SUPPLY USE BY CATEGORY










TYPE OP USE             PERCENTAGE OF TOTAL







Residential                      63






Commercial                       11






Industrial                       21






Municipal                         5





  TOTAL                         100








Source:  U.S. Geological Survey estimates, 1972
                  -177-

-------
     6.2.3  Elasticity of Demand

     Records indicate that water use per customer tends to
decrease following significant increases in water rates.
Howe and Linaweaver1 estimate the price elasticity of demand
for water at -0.23 for metered, public sewer areas. Gottlieb2
found it to be -0.4 in large cities and -0.65 in smaller
communities.  In an article by the American Water Works
Association3 (AWWA) the implied elasticities are -0.08,
-0.20, -0.22, -0.28, -0.33 and -0.34.  These elasticities
mean that for a given percent price increase, water use will
decrease by a much smaller percentage (Table 6-6).  For
example, if the elasticity is -0.23 and the price of water
increases by 20 percent the use of water will decrease by
only 4.6 percent.   This means that the water companies'
revenue will increase as the elasticity increases.

     The elasticity for water used for lawn sprinkling is
much greater than the elasticity for water in general. Howe
and Linaweaver^ found the sprinkling elasticity to be -0.7
in the arid West and -1.6 in the humid East.  This indicates
that if the price of water increases, people reduce the
amount of sprinkling.  Gottlieb's high elasticity (-0.65)
may be due to sprinkling demands.  This elasticity was
estimated for small towns, which tend to have more space
devoted to lawns and gardens than large,cities.   Thus the
amount of area devoted to lawns and gardens in a utility
district will affect consumer response to price increases.
      Charles W. Howe and P.P.  Linaweaver, Jr., "The Impact
of Price on Residential Water Demand and Its Relation to
System Design and Price Structure," Water Resources
Research, 3.:'!, First Quarter 196?.
     2
      M. Gottlieb, "Urban Domestic Demand for Water:  A
Kansas Case Study,"  Land Economics, May 1968.

      American Water Works Association, Committee of Water
Use, "Water Use Committee Report," JAWWA, May 1973.
     4
      Howe and Linaweaver, "Impact of Price on Demand and
Its Relation to Design and Structure," 1967.
                             -178-

-------
                                             'TABLE 6-6
                  THE RELATIONSHIP  BETWEEN PRICE CHANGES AND QUANTITIES OP WATER
VD
 I


PRICE
ELASTICITY
OP DEMAND
FOR WATER
-0.
-0.
-0.
-0.
-0.
-0.
-0.
-0.
-0.
08
20
22
23
28
33
34
40
65

PURCHASED

AS A FUNCTION OF PRICE ELASTICITY






PERCENT DECREASE IN DEMAND FOR WATER
DUE TO 5 PERCENT DUE TO 20 PERCENT DUE TO 50 PERCENT DUE TO 100 PERCENT
INCREASE IN PRICE INCREASE IN PRICE INCREASE IN PRICE INCREASE IN PRICE
0.
1
1.
1.
1.
1.
1.
2.
3.
4

1
15
4
65
7
0
25
1
4
4
4
5
6
6
8
13
.6
.0
.4
.6
.6
.3
.8
.0
.0
4.
10.
11.
11.
14.
16.
17.
20.
32.
0
0
0
5
0
5
0
0
5
8.
20.
22.
23-
28.
33.
34.
40.
65-
0
0
0
0
0
0
0
0
0

-------
     Technology also plays a role in determining consumption.
The examples that resulted in the AWWA elasticities of -0.20
and -0.34 were instances where the population was able to
convert from water-cooled air conditioners to non-water-
using air conditioners.   Once a price increase causes people
to change their habits and buy water-saving appliances it is
not clear that a further price increase will cause further
reductions of water use.

     Table 6-7 indicates the manner in which revenue will
change as a function of elasticity and price change.  To
determine the change in demand and revenue as a result of a
price increase for a particular utility, several factors must
be considered:

     1.   How much area is devoted to lawns and gardens?

     2.   How prevalent are water-using appliances such
          as water-cooled air conditioners?

     3-   To some extent the total level of cost appears
          to influence water use in all classes of service.
          In areas where the average cost to residential
          customers was $0.60 to $0.70/1,000 gallons, customer
          use averaged approximately 70 percent of use in
          areas where the cost was $0.20 to $0.30/1,000
          gallons.  These figures result in an elasticity
          of -0.28.  Therefore utilities considering moves
          from the lower to higher price range should
          expect an elasticity of -0.28.

     The above factors will determine the relevant elas-
ticity for a utility, and thus the expected demand and
revenue changes.  As Table 6-7 indicates, total revenue
increases everywhere with water price increases, except when
price elasticity is -0.65 and price increases 100 percent or
greater.  This means that if a water company, located in an
area where lawn sprinking is prevalent, doubles its rate
it may actually end up with less revenue than before the
rate increase.
6.3  Distribution of Costs


     6.3-1  General

     This section explores how treatment and monitoring
costs would be distributed over the next 10 years.  This



                              -180-

-------
                  TABLE 6-7
THE RELATIONSHIP BETWEEN REVENUE AND PRICE  CHANGE
AS A FUNCTION OF ELASTICITY

PRICE
ELASTICITY
OF DEMAND
FOR WATER
-0.08
-0.20
i 	 j
£? -0.22
i
-0.23
-0.28
-0.33
-0.34
-0. 40
-0.65





PERCENT INCREASE IN REVENUE
DUE TO 5 PERCENT DUE TO 20 PERCENT DUE TO 50 PERCENT
INCREASE IN PRICE INCREASE IN PRICE INCREASE IN PRICE
4.6
3-95
3-8
3.8
3-5
3.4
3-2
2.9
1.6
18.
15.
14.
14.
13-
12.
11.
10.
4.
1
1
7
5
3
4
8
4
4
44.
35.
33.
32.
29-
25.
24.
20.
1.
0
0
5
7
0
3
5
0
3


DUE TO 100 PERCENT
INCREASE IN PRICE
84.
60.
56.
54.
44.
34.
32.
20.
-30.
0
0
0
0
0
0
0
0
0

-------
cost distribution is displayed by size of system, treatment
facilities and type of ownership.  The underlying assump-
tions used in developing these costs are shown in Chapter
Four, Sections 4.1 and 4.10.
     6.3.2  Annual Monitoring Costs

     The Safe Drinking Water Act mandates the beginning of
water monitoring in July 1976.   The projected annual moni-
toring costs for the first 2 years after implementation
would be approximately $109 million per annum, then drop to
an annual expenditure rate of approximately $100 million
after the fifth year (Table 6-8).

     Non-community systems would account for 69-7 percent of
monitoring costs during the first year, while 43 percent of
the community systems'  monitoring costs would be borne by
systems serving 1,000 or fewer people.
     6.3.3  Annual Capital Costs

     In developing the figures for annual capital expenditure
(Tables 6-9 through 6-14) it is assumed that no construction
will begin until 1978, since it is also assumed that no
treatment facility design will begin until after the finalized
primary regulations are promulgated in March 1977.  In
general, a design period of 1.5 years would be needed
before construction, and construction would take from 1 to 3
years.  It is assumed that the capital costs will be spread
evenly over 5 years.  In all calculations in this chapter
treatment costs are based on average daily production rates.

     Clarification units for surface-water systems would
account for almost 35 percent of the required capital costs,
followed by mercury with 22 percent.  Ion exchange treatment
for nitrate is the next most costly process (Table 6-11).

     The private (investor-owned) segment of the water
supply industry would pay 21.5 percent of the total treat-
ment costs while the public sector would pay 79.5 percent
(Tables 6-9, 6-10 and 6-11).

     Yet this does not necessarily mean that the burden will
fall most heavily on the public sector.  Systems serving
under 100 people — those with relatively high costs of
capital and relatively poor operating records — are
                            -182-

-------
                                                                        TABLE 6-8
                                                                ANNUAL MOIIITC-RING COSTS
 I
I—'
GO
OJ
 I
(Millions of Dollars Unless Otherwise Noted)

POPULATION
NUMBER SERVED
SYSTEM OF MILLION
SIZE SYSTEMS PEOPLE 1976 1977 1978
25-99 7,008 0.4 3.5 3.7 3.1
100-499 15,113 3.8 7.7 8.0 6.9
500-999 5,392 3-8 2.8 2.9 2.5
1,000-2,499 5,182 7.8 2.8 2.9 2.6
2,500-4,999 2,605 8.9 1.9 2.0 1.9
5,000-9,999 1,858 12.6 2.0 2.1 1.9
10,000-99,999 2,599 61.1 8.6 8.8 8.7
100,000-999,999 236 57-3 3-3 3-3 3-3
>1. 000,000 7 21.5 0.3 0.3 0.3
TOTAL
COMMUNITY0 40,000 177-5 32.9 34.0 31.2
TOTAL
NON-COMMUNITY0 200,000 75.8 75.8 75.8
TOTAL0 240,000 108.7 109.8 107.0
Totals are based on mean costs.
Based on 1981 monitoring costs.
cTotals may not add due to rounding.
Assumptions used to partition special monitoring costs by years
1. Surface systems divide special monitoring evenly between
2. Groundwater systems divide special monitoring; 25 percent
3. Pesticides and CCE are found only in surface-water
4. Nitrate, arsenic, barium, cadmium, chromium and fluoride

1979
3-0
6.6
2.4
2.5
1.8
1-9
8.6
3.3
0.3
30.4
75.8
106.2




Year 1 and
in Year 1

are found

1980
3-0
6.6
2.4
2.5
1.8
1.9
8.6
3.3
0.3
30.4
75.8
106.2




Year 2

COST PER
YEAR
1981-1985
3.0
6.6
2.4
2.5
1.8
1.9
8.6
3-3
0.3
30.4
69-5
99-9





, 50 percent in Year 2,

only in
5. Lead, mercury, and selenium are found in both surface- and groundwater in
6. Cyanide and silver are not found in violation.
7. Non-community systems will spread their costs evenly for

the first

5 years

gpoundwater .
a random manner.



AVE. COST AVE. COST
PER YEAR PER YEAR
PER SYSTEM PER CAPITA
123-60 7.42
436.83 1.74
153-24 0.64
474.33 0.32
679.02 0.20
1,048.40 0.15
3,321.53 0.14
13,984.26 0.06
14,939.00 0.01








and 25 percent in Year 3.






-------
                                                            TABLE  6-S
                                       TOTAL ANNUAL CAPITAL EXPENDITURES3 BY TREATMENT  PROCESS
FOR PUBLICLY-OWNED
(Millions
PROCESS
CLARIFICATION
CCE
NO,
CHLORIKATION
KSRCUHY
1 SELENIUM
CO CADMIUM
-t
1 LEAD
FLUORIDE
CHROMIUM
BARIUM
AHSE.NIC
Tai'AL-.COMMUNITY
CAPITAL COSTSC
TOTAL #
OF PLANTS
1,265
96
579
3,306
456
227
105
407
933
60
28
80

TOTAL
POPULATION
AFFECTED
16,390,
1,597,
1 ,667,
9,556,
2, 162,
604,
250,
1,330,
2,669,
186,
62,
188,

692
324
500
782
502
464
860
435
518
145
712
145

1971
62.44
3.71
35.53
7.02
39.99
14.20
5.87
.45
4.66
4.65
1.67
.38
180.56
UTILITIES
of Dollars Unless Otherwise Noted)
I960
62.44
3-71
35.53
7.02
39.99
14.20
5.87
.45
4.66
4.65
1.67
.38
160.56
1961
62.44
3-71
35.53

39.99
14.20
5.67
.45
4.66
4.65
1.67
.36
173-55
1962
62.44
3.71
35.53

39.99
14.20
5-87
.45
4.66
4.65
1.67
.38
173.55
1983
62.44
3.71
35.53

39.99
14.20
5.87
.45
4.66
4.65
1.67
.36
173-55
TOTAL
312.2
18.5
177-7
14.0
199.9
71.0
29.4
2.3
23.3
23.2
6.3
1.9
B8l .8
TOTAL CAPITAL
EXPENDITURES
PER SYSTEM
(DOLLARS)13
246
192
306
4
436
313
276
5
24
291
298
23

,705
,317
,765
,243
,607
,194
,695
,534
,977
,231
,011
,661

TOTAL CAPITAL
EXPENDITURES
PER CAPITA
(DOLLARS)6
19.
11 .
106.
1 .
92.
117.
117.
1 .
6.
123.
132.
10.

05
61
54
47
45
50
04
69
67
46
94
12

     aAssumes:  (1) Debt service pf 11 percent/year; (2) Capital ownership cost of 3 percent
to cover taxes, insurance, etc.

     °3ased on figures from 1983 when treatment is fully implemented.

     °Table may not add due to rounding.

-------
                                                          TABLE  6-10
FOR INVESTOR-OWNED UTILITIES
(Millions of Dollars Unless Otherwise Noted)
PROCESS
CLARIFICATION
CCE
NO
CHLORINATION
1 1-lERC'jRY
00 SELENIUM
VJ1
1 CADMIUM
LEAD
FLUOHIDE
CHROMIUM
BARIUM
ARSENIC
TOTAL CCHXUNITY
CAPITAL COST3C
TOTAL *
OF PLANTS
661
66
394
2,249
311
154
72
277
635
54
19
54

TOTAL
POPULATION
AFFECTED
2,712
264
275
1 ,581
357
100
41
220
445
31
10
31

,679
,359
,973
,9fa9
,697
,039
,518
, 189
,118
,138
,379
,138

1979
13.44
.60
7.65
1.51
8.61
3.06
1.26
. 10
1 .00
1 .00
.36
.06
38.86
19&0
13.44
.60
7.65
1.51
6.61
3.06
1 .26
. 10
1 .00
1 .00
.36
.06
38.66
1961
13.44
.60
7.65

6.61
3.06
1.26
. 10
1 .00
1 .00
.36
.06
37.35
T962
13.44
.60
7.65

6.61
3.06
1.26
. 10
1 .00
1 .00
.36
.06
37-35
1963
13.44
.80
7.65

6.61
3.06
1.26
. 10
1 .00
1 .CO
• 36
.08
37.35
TOTAL
67.2
4.0
38.2
3-0
43.0
15.3
6.3
.5
5.0
5.0
1.8
.4
189-ts
TOTAL PER
PLANT
(DOLLARS)"
76,
60,
97,
1,
136,
99,
66,
1,
7,
92,
94,
7,

072
860
076
343
231
113
195
751
904
162
306
551

TOTAL PER
CAPITA
(DOLLARS)0
24.
15.
136.
1 .
120.
152.
152.
2.
11 .
160.
172.
13-

77
10
55
91
23
60
20
20
27
55
67
15

      Assumes:  (1) Debt service of 11 percent/year;  (2)  Capital  owner-ship  cost  of  3 percent
to cover taxes, insurance, etc.

      Based on figures from 1983 when treatment Is  fully  Irr.plemented.

     cTable may not add due to rounding.

-------
                                                      TABLE 6-11
                                  TOTAL ANNUAL CAPITAL EXPENDITURESa Bl TREATMENT PROCESS
(Millions
PROCESS
CLARIFICATION
CCE
N03
CHLORINATION
MESCURY
1
M SELENIUM
oo
•^ CADMIUM
LEAD
FLUORIDE
CHROMIUM
BARIUM
ARSENIC
TOTAL COMMUNITY
CAPITAL COSTSa
TOTAL *
OF PLANTS
2, 126
162
973
5,557
769
381
177
684
1,566
134
47
134

TOTAL
POPULATION
AFFECTED
19,103,371
1 ,661 ,683
1,943,473
11,140,771
2,520,399
704,503
292,378
1,550,624
3,134,636
219,283
73,091
219,283

1979
75.67
4.51
43. 18
6.53
46.59
17.26
7. 14
.55
5.67
5-65
2.03
.46
219.43
of Dollars Unless Otherwise Noted)
1980
75.67
4.51
43.18
8.53
46.59
17.26
7.14
.55
5.67
5.65
2.03
.46
219.43
1961
75.67
4.51
43. 18

46.59
17-26
7. 14
.55
5.67
5.65
2.03
.46
210.90
1962
75.87
4.51
43.16

48.59
17.26
7.14
.55
5.67
5.65
2.03
.46
210.90
1983
75.67
4.51
43. 16

48.59
17.26
7.14
.55
5.67
5.65
2.03
.46
210.90
TOTALa
379.4
22.5
215.9
17.1
243.0
86.3
35.7
2.7
26.3
28.2
10. 1
2.3
1071.5
TOTAL PER
PLANT
(DOLLARS)
178,
139,
221,
3,
315,
226,
201 ,
4,
18,
210,
215,
17,

444
104
665
069
945
535
562
003
066
649
553
259

TOTAL PER
CAPITA
(DOLLARS)
19.66
12. 10
11 1 .09
1.53
96.40
122.51
122.03
1.77
9.04
126.72
136.61
10.55

Totals may not add due to rounding.

-------
concentrated in the private sector.  Indeed, in this group
of small companies capital expenditures by investor-owned
utilities are three times those of government-owned utilities
(Tables 6-12, 6-13, and 6-14).

     Table 6-11 shows that the most expensive treatment
methodology is ion exchange, when capital costs are calcu-
lated on a per capita basis. Capital costs per capita vary
from $138.61 for barium removal to $1.53 for chlorination.

     Mercury removal is the most expensive capital treatment
on a per plant basis.  The per plant expenditures vary from
$315,9^5 for mercury removal to $3,069 for chlorination.

     Table 6-14 shows that systems serving between 25 and 99
people require an average per capita capital expenditure of
almost $163 to treat their water, while systems serving more
than 1,000,000 people require only $8.78, on the average.
     6.3.4  Annual Operation and Maintenance Costs

     It is assumed that O&M costs will begin concurrently
with capital costs and will aggregate yearly until an
equilibrium is reached at the end of the fifth year.  Tables
6-15, 6-16, and 6-17 show that the major O&M costs would be
for clarification, mercury and nitrate treatment.

     The investor-owned companies would pay an annual O&M
cost of $45.6 million after 5 years (Table 6-16), while the
public utilities would pay $211.8 million in 1983 (Table 6-15!

     Likewise, private rather than public companies must
bear a higher proportion of the bills of O&M costs for the
small water companies.  When all costs are included, the
private sector's portion of the bill for systems serving 100
or fewer persons is over three times that of the public
sector (Tables 6-18, 6-19, and 6-20).

     The most costly O&M treatments on a per plant basis are
for clarification and Ion exchange.  The range in per plant
costs is from $88,700 for clarification to $184 for lead
treatment (Table 6-17).  On a per capita basis the most
expensive treatment is $11.70 for barium, while the cost to
treat for lead is the lowest ($0.08).

     Each person served by systems serving between 25 and 99
people will pay an average of approximately $12.00 per year
                           -187-

-------
                                                                        TABLE 6-12
                                     TOTAL ANNUAL CAPITAL EXPENDITURES BY SIZE OF SYSTEM FOR PUBLICLY-OWNED UTILITIES
oo
oo
I
(Millions of
POPULATION
SIZE
CATEGORY
25-99
100-499
500-999
1 ,000-2,1*99
2,500-4,999
5,000-9,999
10,000-99,999
100,OCC-999,999
>1 ,000,000
TOTAL PUBLICLY-
OWNED COMMUNITY
CAPITAL COSTS3
TOTAL #
OF PLANTS
673
2,645
1 ,206
1,233
624
393
540
46
2
7,566
TOTAL
POPULATION
AFFECTED
41 , 180
739,227
869,941
1,695,474
2,151,027
2,675,272
12,958,226
10,364, 150
5,010,781
36,705,277
1979
1.42
11.14
7.67
11.68
18.65
21 . 10
69.17
30.44
8.80
180.28
Dollars Unless Otherwise Noted)
I960 19&1
1.42 1.29
11.14 10.33
7.67 7.46
11.66 11.17
18.65 17.96
21.10 20.40
69.17 66.91
30.44 29.41
8.60 6.60
1-60.2(1 173.73
1962
1.29
10.33
7.46
11.17
17.96
20.40
66.91
29.41
6.60
173.73
1963
1.29
10.33
7.46
11.17
17.96
20.40
66.91
29.41
8.80
173-73
TOTAL PER
PLANT
TOTAL3 (DOLLARS)
6.7 9,896
53.3 10,725
38.1 31,592
56.9 46,130
91.2 146,213
103.4 263,149
339.1 628,424
149.1 3,275,357
44.0 22,000,000
661.6
TOTAL PER
CAPITA
(DOLLARS)
162.96
72.07
43.61
30.00
42.40
38.65
26. 17
14.39
8.76

                  Totals may not add due to rounding.

-------
                                                                             TABLE  6-13
                                          TOTAL CAPITAL  EXPENDITURES BI  SIZE  OF  SYSTEM  FOR  INVESTOR-OWNED  UTILITIES
 I
h-
oo
VD
 1
(Millions of Dollars Unless Otherwise Noted)
POPULATION
SIZE TOTAL it
CrtlEGO.iY OF PLANTS
25-99 2,078
100-499 2,227
5CO-999 375
1,000-2,1)99 217
2, 500-1), 999 66
5,000-9,999 51
10,000-99,999 69
100,000-999,999 1C
>1 ,000,000
TOTAL INYE3TOR-
OW:;ED COMMUNITY 5, 146
CAPITAL C037Sa
TOTAL TOTAL PER TOTAL PER
POPULATION PLANT CAPITA
AFFECTED 1979 1980 1961 1982 1963 TOTAL3 (DOLLARS) (1JOLLAKS)
126,217 1.35 1.35 3-95 3.95 3-95 20.6 9,898 162.96
578,1466 8.72 8.72 8.08 8.0fc 8.08 11.7 16,725 72.07
270,217 2.45 2.45 2.32 2.32 2.32 11.8 31,592 13.61
380,005 2.31 2.31 2.21 2.21 2.21 11.1 16,130 30.00
301,163 2.61 2.61 2.51 2.51 2.51 12.9 116,213 42.10
347,631 2.71 2.71 2.65 2.65 2.65 13.1 263,119 36.65
1,667,311 6.90 8.90 8.61 8.61 8.61 43.6 626,421 26.17
2,383,602 7.00 7-00 6.77 6.77 6.77 34.3 3,275,357 14.39

6,056,219 39.14 1-,9-H 37.16 37.16 37.16 189.6
                      aTotals may not add due to rounding.

-------
                                                                             TABLE 6-11
                                                         TOTAL ANNUAL CAPITAL EXPENDITURES BY SIZE OF SYSTEM
VD
O
 I
(Millions of Dollars Unless
POPULATION
SIZE
CATEGORY
25-99
100-499
5CO-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999, 999
>1 ,000,000
•TOTAL COMMUNITY
CAPITAL COST3a
TOTAL #
OF PLANTS
2,756
5,072
1 ,561
1,460
712
444
609
56
2
12,712
TOTAL
POPULATION
AFFECTED
167,
1 ,317,
1 , 140,
2,275,
2,455,
3,022,
14,625,
12,743,
5,010,
42,763,
397
695
156
479
510
906
537
032
781
495
1979
5.
19.
10.
14.
21.
23.
78.
37.
8.
219
77
66
32
02
30
85
07
44
60
.43
I960
5.77
19.66
10.32
14.02
2! .30
23.65
7&.07
37.44
0.60
219.43
1981
5.
18.
9.
13.
20.
23.
75.
36.
6.
210
25
42
77
41
50
05
52
18
60
.90
Otherwise Noted)
1962
5.25
16.42
9.77
13.41
20.50
23.05
75-52
36. 16
8.60
210.90
1983
5.
18.
9.
13-
20.
23-
75.
56.
8.
210
25
42
77
41
50
05
52
16
80
.90
TOTAL3
27.3
95.0
49.9
66.3
104. 1
116.6
362.7
163.4
44.0
1071.5
TOTAL PER
PLANT
(DOLLARS)
9,698
16,725
31,592
46, 130
146,213
263, 149
62B.424
3,275,357
22,000,000

TOTAL PER
CAPITA
(DOLLARS)
162.96
72.07
43.61
30.00
42.40
36.65
26. 17
14.39
6.76

                      aTotais may not add due to rounding.

-------
                                                                             TABLE  6-15
                                                        TOTAL ANNUAL  O&M  EXPENDITURES BY TREATMENT PROCESS
 I
h-
MD

 I

TOTAL <*
PROCESS OF PLANTS
CLARIFICATION 1,265
CCE 96
N03 579
CHLCRIMAIIOW 3,306
l-'.ERCUKX 456
S£-ENILM 227
CADMIUM 105
LEAD 40?
FLUORIDE 933
CHROMIUM bO
BARIL'K 26
ARSENIC 80
TOTAL PUBLICLY-OWNED
CCMY.UNITY O&K COST3a
((•
TCTAL
POPULATION
AFFECTED
16,390,692
1,597, 324
1 ,667,500
9,558,7b2
2, 162,502
604,464
250,660
1,330,435
2,689,518
166, 145
62,712
166, 145

FOR
PUBLICLY-OWNED UTILITIES
lillions of Dollars
1979
32.89
.80
3.15
3.13
3-59
1 .27
.52
.02
1.76
.41
. 15
. 12
47.81
I960
65-76
1.59
6.31
6.26
7.18
2.54
1.04
.04
3.52
.02
• 30
.24
95.63
Unless Otherwise I
1961
98.67
2.39
9.46
6.26
10.77
3.60
1.56
.07
5.27
1.24
.45
• 37
140.31
1982
131 .56
3.18
12.61
6.26
14.37
5.07
2.06
.09
7.03
1.65
.60
.49
185.00
Noted)
1963
164.45
3-96
15.77
6.26
17.96
6.34
2.61
. 11
8.79
2.06
.75
.61
229.66

TOTAL PER
PLANT
(DOLLARS)b
130,005
41, 259
27,232
1,694
39,246
27,968
24,739
270
9,423
25,661
26,660
7,652


TOTAL PER
CAPITA
(DOLLARS)b
10.03
2.49
9.45
.66
6. 30
10.49
10.39
.06
3-27
10. -9o
1 1 . 6y
3.24

                      "Totals may not add due to rounding.

                       Based on figures from 1983 when treatment is fully implemented.

-------
                                                                           TABLE 6-16
                                                       TOTAL ANNUAL 04M EXPENDITURES BY TREATMENT PROCESS
vo
ro
 I




FOR
INVESTOR-OWNED UTILITIES
(Millions of Dollars
TOTAL #
PROCESS OF PLANTS
CLARIFICATION
CCh
NO
CHLORINATIOH 2
MERCURY
SELENIUM
CADMIUM
LEAD
FLUORIDE
CHROMIUM
BARIUM
ARSENIC
TOTAL INVESTOR-OWNED
COMMUNITY OAK COSTS3
661
66
594
,251
311
154
72
277
635
54
19
54


TOTAL
POPULATION
AFFECTED
2,712,
254,
275,
1,561,
357,
100,
41,
220,
445,
31,
10,
31,


679
359
973
989
897
039
51b
189
118
136
379
138


1979
4.82
. 12
.46
.46
.53
.19
.08
.00
.26
.06
.02
.02

7.01
I960
9.65
.23
.92
.92
1.05
.37
.15
.01
.52
.12
.04
.04

14.02
Unless Otherwise
1981
14.17
.35
1.39
.92
1.58
.56
.23
.01
.77
.16
.07
.05

20.56
1982
19.29
.47
1.85
.92
2. 11
.74
.31
.01
1.03
.24
.09
.07

27.13
Noted)
1963
24. 12
.58
2.31
.92
2.63
.93
.38
.02
1.29
• 30
. 11
.09

33.68

TOTAL PER
PLANT
(DOLLARS)5
28,01 1
8,690
5,667
40B
8,456
6,026
5,330
58
2,030
5,572
5,744
1,649



TOTAL PER
CAPITA
(DOLLARS)b
6.69
2.21
6.35
.56
7.36
9.29
9.20
.07
2.90
9.71
10.53
2.87


                     Totals may not add due to rounding.


                    b3ased on figures from 1983 when treatment  is  fully  implemented.

-------
                                                      TABLE 6-17
                                  TOTAL ANNUAL O&M EXPENDITURES BY TREATMENT PROCESS
(Millions of Dollars
PROCESS
CLARIFICATION
CCE
NO
CHLORINATION
MERCURY
SELENIUM
CADMIUM
LEAD
FLUORIDE
CHROMIUM
BARIUM
ARSENIC
TOTAL COMMUNITY
O&M COSTSa
TOTAL f
OF PLANTS
2, 126
162
973
5,557
769
381
177
664
1 ,566
134
47
134

TOTAL
POPULATION
AFFECTED
19,103,
1,661 ,
1,943,
11, 140,
2,520,
704,
292,
1,550,
3,134,
219,
73,
219,

371
663
473
771
399
503
378
624
636
283
091
283

1979
37.71
.91
3.62
3.59
4. 12
1.45
.60
.03
2.02
.47
. 17
. 14
54.63
1960
75.43
1.62
7-23
7.18
8.24
2.91
1 . 19
.05
4.03
.95
.34
.28
-.09.65
Unless Otherwise Noted)
1981
113- 11
2.71
10.85
7.16
12.35
1.36
1.79
.08
6.05
1.12
.51
.42
160.69
1982
150.66
3.65
14.46
7.18
16.47
5.82
2.39
. 10
6.06
1.69
.66
.56
212. 13
1963'
168.57
4.56
18.06
7.16
20.59
7.27
2.99
.13
10.06
2.36
.65
.70
263.36
TOTAL PER
PLANT
(DOLLARS)6
86,697
26, 149
16,560
1 ,292
26,776
19,061
16,879
164
6,429
17,611
18,169
5,221

TOTAL PEfi
CAPITA
(DOLLARS)13
9.67
2.15
9-30
.64
6.17
10.32
10.22
.06
3.22
10. 7B
11.70
3-19

aTotals may not add due to rounding.



 Based on figures from 1983 when treatment is fully implemented.

-------
                                                                               TABLE 6-18
                                           TOTAL ANNUAL O&M EXPENDITURES BY SIZE OF SYSTEM FOR PUBLICLY-OWNED UTILITIES
 I
h-
VD
(Millions of Dollars Unless
POPULATION
SIZE
CATEGORY
25-99
100-199
5CO-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL PUBLICLY-
OWNED COMMUNITY
04M COSTSa

TOTAL #
OF PLANTS
676
2,645
1 ,206
1,233
624
393
540
4o
2

7,566
TOTAL

POPULATION
AFFECTED
41
739
669
1,695
2, 151
2,675
12,956
10,364
5,010

36,705
, 180
,227
,941
,474
,027
,272
,226
,150
,781

,277

1979
. 11
.90
.66
1 .01
2.94
3-36
14. 13
12.96
11.60

47.71


I960

1 .
r.
2.
5.
6.
28.
25.
23.

95.
22
80
33
01
68
76
26
97
20

43
Otherwise Noted)


1981

2.
1 .
2.
6.
9.
41.
36.
31.

140
32
57
69
64
63
66
16
06
60

.18

1962
.42
3.3^
2.46
3.68
11.37
12.97
54. 10
50. 16
46.40

164.93


1963

4.
3-
4.
14.
16.
67.
62.
56.

229
52
11
02
51
12
06
03
29
00

.66
TOTAL PER
PLANT
(DOLLARS)b
765
1,444
2,502
3,659
22,641
40,915
124,223
1,366,179
29,000,000


TOTAL PER
CAPITA
(DOLLARS) °
1i.60
5.56
3.17
2.3a
6.56
6.01
5.17
6.01
11 .56


                         Totals may not acid due to rounding.

                         Based on figures  from 1983 when  treatment  is  fully implemented.

-------
                                                                            TABLE  6-19
                                       TOTAL ANNUAL O&M  EXPENDITURES  BY  SIZE  OF  SYSTEH  FOR  INVESTOR-OWNED UTILITIES
VD
Ul
 I

POPULATION
SIZE
CATEGORY
25-99
100-499
500-999
1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99, 999
100,000-999,999
>1 ,000,000
TOTAL IMVESTGR-
O'.'.'NED CO;.;yiUNITY
O&M COSTSa

TOTAL #
OF PLANTS
2,076
2,227
375
247
3tJ
51
69
10

5, 146
IM
illions
TOTAL
POPULATION
AFFECTED
126
57&
270
360
304
347
1,667
2,383

6,058
,217
,468
,217
,005
,463
,634
,311
,6&2

,219
of Dollars Unless Otherwise Noted)
1979 1960 ,1961
.34 .66 .99
.70 1.41 2.01
.21 .41 .59
.20 .40 .57
.42 .63 1.22
.44 .86 1.26
1.82 3.64 5.30
2.99 5.97 6.76

7.11 14.23 20.71
1962
1.29
2.61
.76
.74
1.61
1.69
6.96
1 1 .54

27.20
TOTAL PER
PLAi\T
19&3 (DOLLARS)b
1.59 765
3.22 1,444
.94 2,502
-.90 3,659
2.00 22,641
2.09 40,915
8.62 124,223
11-33 1,366,179

33-69
TOTAL PER
CAPITA
(DOLLARS)b
12.
5.
3.
i.
6.
fa.
5.
6.


60
56
47
36
56
01
17
01


                      Totals may not add due to rounding.

                     °Sased on figures from 1983 when treatment is fully implemented.

-------
                                                                           TABLE 6-20
                                                           TOTAL ANNUAL O&M EXPENDITURES BY SIZE OF SYSTEM
 I
h-1
VD
a\
 I

POPULATION
SIZE
CATEGORY
25-99
100-499
500-999
•1 ,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
>1 ,000,000
TOTAL COMMUNITY
OiM CCSTSa

TOTAL #
OF PLANTS
2,756
5,072
1,561
1,480
712
444
609
56
2
12,712


TOTAL
POPULATION
AFFECTED
16?
1,317
1 , 140
2,275
2,455
3,022
14,625
12,748
5,010
42,763
,397
,695
,158
,479
,510
,906
,537
,032
,781
,495
(Millions
1979
.45
1.60
.67
1.21
3-36
3.62
15.95
15.97
11.60
54.83
of Dollars Unless Otherwise
1980

3.
1 .
2.
6.
7.
31.
31.
23.
109
91
21
74
42
71
63
69
94
20
.65
1981
1.31
4.56
2.48
3.42
9.65
11.14
46.46
46.63
34.60
160.69
1962
1.71
5.95
3.22
4.42
12.96
14.66
61.07
61.73
46.40
212. 13
Noted)
1963
2.
7.
3.
5.
16.
16.
75.
76.
58.
263
11
33
96
42
12
17
65
62
00
.36
TOTAL PEK
PLANT
(DOLLARS)0
765
1,444
2,502
3,659
22,641
40,915
124,223
1,366,179
29,000,000

TOTAL PER
CAPITA
(DOLLARS)5
12.60
5.56
3.47
2.36
6.56
6.01
5.17
6.01
11.56

                     Totals may not add due to rounding.

                     Based on figures from 1983 when treatment is fully implemented.

-------
for O&M expenses,  while systems serving between 100,000 and
one million people will pay an average of $5.84 per capita.
     6.3-5  Total Annual Costs

     The total annual costs are derived as the sum of the
annual operation and maintenance costs, monitoring costs,
and ownership costs.  The annual ownership costs are based
on an annual 11 percent debt service (principal plus interest
and a factor of 3 percent of capital costs to cover land
amortization, insurance, taxes and other ownership costs.

     The total annual costs for each treatment type are
shown in Tables 6-21, 6-22, and 6-23, while the annual costs
for each population served are shown in Tables 6-24, 6-25,
and 6-26.  These total annual costs are paid out each year
for water treatment.  The most expensive contaminants to
treat, on a per capita basis, are barium, chromium, and
selenium, with clarification being the most expensive on a
per plant basis (Table 6-23).

     The systems serving between 25 and 99 people pay an
average of $34.78 per capita for treatment while the systems
serving between 100,000 and one million people would pay
$7-86 per capita per year for treatment.  Systems serving
over one million people pay $12.80 per capita per year
because of the high percentage of plants needing clarifi-
cation compared to other treatments.
                             -197-

-------
                                                           TABU; 6-21
                                       TOTAL ANNUALIZED TOTAL COSTS3 BY TREATMENT PROCESS
FOR Fu&LICLi-OW:
(Millions of Dollar;
PROCESS
CLARIFICATION
CCE
N03
ChLOfilNATION
MERCURY
SELENIUM
1— CADMIUM
VQ
°°; LEAD
FLUORIDE
CHROMIUM
BARIUM
ARSENIC
TOTAL #
OF PLANTS
1,261
110
577
3,296
156
226
105
106
930
79
28
79
TOTAL
POPULATION
AFFECTED
16,390,692
1,820,919
1,667,500
9,558,782
2,162,502
601,161
250,860
1,330,135
2,689,518
188,115
62,712
188,115
1979
11.62
1.32
8.12
1.11
9.18
3.26
1.31
0.08
2.11
1.06
0.38
0.17
1980
83.25
2.61
16.25
8.22
18.37
6.51
2.68
0.17
1.82
2.12
0.77
0.35
liLi UTILITIES
j Unless Otherwise
1981
121.87
3.96
21.37
8.22
27.55
9.77
1.03
0.25
7.21
3.18
1.15
0.52
19&2
166.50
5.28
i(0.6o
8.22
36.71
13.03
5.37
0.33
9.65
1.21
1.51
0.69
Noted)
19&3
208.
6.
18.
8.
15.
16.
6.
0.
12.
5.
1.
0.
13
60
72
22
92
28
71
12
06
30
92
87
TOTAL PER
PLAivT
(DOLLARS)0
161
60
118
2
201
111
127
2
25
131
137
21
,530
,000
,085
,193
,112
,097
,790
,011
,910
,127
,071
,921
TOTAL PER
CAPITA
(DOLLARS)0
12.70
3.63
25.61
0.86
21.21
26.96
26.73
0.31
1.18
28.18
30.95
11.61
         PUBLICLY-
OWNED COMMUNITY
ANNUALIZED TOTAL COSTS
MONITORING
TOTAL COMMUNITY0
73.07   116.11   215.13   281.11   353.08

25.00    25.80    23.70    23.10    23.10
98.07   171.91   238.83   307.21   376.18
       Assunes:   (1) Debt service of 11 percent/year  on  capital;  (2)  Capital  ownership  cost  of 3
 perc-ent to cover taxes, insurance, etc.;  (3) Annual  OSM costs.
      bBased on .figures from 1983 when treatment  is fully inpleirented..
      cTable may not add due to rounding.

-------
                                                           TABLE 6_22
                                       TOTAL ANNUAL12ED TOTAL COSTSa BY TREATMENT PROCESS
FOR INVESTOR-OS
(Millions
TOTAL *
PROCESS OF PLANTS
CLARIFICATION
CCE
NO,
CKLORINATION
MERCURY
SELENIUM
|-J CADMIUM
VD LEAD
1
FLUORIDE
CHROMIUM
BARIUM
ARSENIC
865
75
396
2,261
313
155
72
278
638
55
19
55
TOTAL
POPULATION
AFFECTED "
2,712,679
301,369
275,973
1,581,989
357,897
100,039
1)1,518
220,189
1)1)5,118
31,138
10,379
31,138
SUBTOTAL INVESTOR-OWNED
COMMUNITY ANNUALIZED
TOTAL COSTS °
MOMITCRING
TOTAL COMMUNITY"




1979
6
0
1
0
1
0
0
0
0
0
0
0
12
7
20
.71
.28
.53
.67
.71)
.62
.26
.01
.DO
.20
.07
.03
.H7
.90
.37
of Dollar
I960
13
0
3
1
3
1
0
0
0
0
0
0
21)
8
33
.1)1
.1)6
.07
.35
.H8
.21)
.52
.02
.80
.DO
.ID
.06
.95
.20
.15
'•JED UTILI
s Unless
1961
20.
0.
D.
1.
5.
1.
0.
0.
1.
0.
0.
0.
36.
6.
1)3.
12
70
60
35
21
86
77
03
20
60
21
09
7D
50
21)
litS

Otherwise
'19B2
26
0
1
6
2
1
0
1
0
0
0
1)8
1
55
.82
.93
.35
.95
.H8
.03
.01)
.61
.80
.28
.12
.55
.30
.65
Noted)
1903
33
1
7
1
8
3
1
0
2
1
0
0
60
7
67
.5D
.16
.67
.35
.69
.10
.29
.06
.01
.00
.35
.16
.38
.30
.68
TOTAL PER
PLANT
(DOLLARS)b
38,769
15.DD6
19,366
597
36,761
19,993
17,902
216
3,11)6
18,182
18,526
2,836



TOTAL PER
CAPITA
( DOLLARS;"
12.37
3-85
27.79
0.85
2D. 28
30.99
31. H3
0.27
1.51
32.25
35.20
5.03



     aAssun;es:  (1) Debt service of 11 percent/year on capital; (2) Capital ownership cost of 3
percent to cover taxes, insurance, etc.; (3) Annual O&M costs.

      Based on figures from 1983 when treatment is fully implemented.

     cTable nay not add due to rounding.

-------
                                                           TABLE  6-23
                                        TOTAL  ANKUALIZED TOTAL COSTS 3if TREATMENT PROCESS
(Millions of






1
ro
o
o
1


PROCESS
CLARIFICATION
CCE
K03
ChLORINATION
MERCURY
SELENIUM
CADMIUM
LEAD
FLUORIDE
CHROMIUM
BARIUM
ARSENIC
TOTAL ft
OF PLANTS
2,126
185
973
5,557
769
381
177
681
1,568
131
17
131
TOTAL
POPULATION
AFFECTED
19,103
2,122
1,913
11,110
2,520
701
292
1,550
3,131
219
73
219
,371
,319
,173
,771
,399
,503
,378
,621
,636
,283
,091
,283
1979
18.33
1.51
9.67
1.78
10.92
3.87
1.60
0.11
2.81
1.26
0.15
0.20
Dollars unless Otherwise Noted)
19fcO
96.66
3.08
19-33
9.57
21.81
7.73
3.20
0.21
5.62
2.52
0.91
0.11
1961
115.00
1.62
29.00
9.57
32.77
11.60
1.80
0.32
8.41
3-78
1.36
0.61
19&2
193.33
6.16
38.66
9.57
13-69
15.17
6.10
0.13
11.25
5.01
1.82
0.82
1983
211.66
7.70
18.33
9.57
51.61
19.33
8.00
0.51
11.07
6.30
2.27
1.02
TOTAL PER
PLANT
(DOLLARS)b
113
11
19
1
71
50
15
8
17
18
7
,668
,622
,667
,722
,009
,710
,186
782
,972
,135
,319
,627
TOTAL PER
CAPITA
(DOLLARS)"
12.65
3.63
21.87
0.86
21.81
27.17
27.39
0.31
1.18
28.80
31.10
1.67
SUBTOTAL•COMMUNITY 04M
COSTS AND CAPITAL COSTS
MONITORING
SUBTOTAL N'ON-COKMUNITYL
TOTAL0
 85.55   171.08   251.87   332.61   113.10
                   31.20    30.10    30.10
                  283.07   363.01   113.80
                  107-00   106.20    S9.90
 32.90    31.00
118.15   205.03
108.70   109.80
227.15   311-1
                  390.07   169.21   513.70
        aAssuraes:   (1) Debt service of 11 percent/year on capital; (2) Capital ownership cost of 3
   per&ent to cover taxes, insurance, etc.; (3) Annual OiM costs.
         Based on figures from 1933 when treatment is fully implemented.
        °Table nay not add due to rounding-

-------
                                                           TABLE 6-24
                                           TOTAL ANNUALI2ED TOTAL  COSTS3  BY  SIZE  OF  SYSTEM
r'OK PUbLICL'i-GVv.Ni-D UTILITIES
(Millions of Dollars Unless Otherwise Noted)
POPULATION
SIZE TOTAL *
CATEGORY OF PLANTS
25-99 678
100-499 2,845
500-999 1,206
1,000-2,499 1,233
2,500-4,999 624
1 5,000-9,999 393
ro
0 10,000-99,999 540
'" 100,000-999,999 46
>1,000,000 2
SUBTOTAL COMMUNITY
O&M COSTS AND
CAPITAL COSTS0
MONITORING
TOTAL COMMUNITY0
TOTAL
POPULATION
AFFECTED 1979
41,180 0.
739,227 2.
869,911 1.
1,895,471 2.
2,151,027 5.
2,675,272 6.
12,958,226 23.
10,364,150 17.
5,010,781 12.
72.
25.
97.
31
46
76
65
55
33
81
24
83
95
00
95
1960
0
4
3
5
11
12
47
31
25
145
25
171
.62
.92
.52
.29
.10
.66
.63
.48
.66
.88
.80
.68
1961
0
7
5
7
16
18
69
50
33
214
23
238
-90
.14
.I-'!
-67
-37
.62
.92
.72
.50
.98
.70
.68
1962
1
9
6
10
21
24
92
66
51
284
23
307
.18
.36
.76
.05
.64
.58
.21
.96
.33
.07
.10
.17
TOTAL PER
PLANT
1983 (DOLLARS)5
1.
11.
8.
12.
26.
30.
114.
83.
64.
353.
23.
376.
16 2,153
58 4,070
38 6,948
43 10,081
91 43,119
51 77,720
40 211,842
21 1,808,913
16 32,080,000
07
10
17
10TAL PER
CAPITA
(DOLLARS)5
35.15
15.67
9.64
4.42
12.51
11.12
8.83
8.03
12.81



     aAssumes:  (1) Debt service of 11 percent/year on capital; (2) Capital ownership cost of 3
perc-er.t to cover taxes, insurance, etc.;  (3) Annual O&M costs.
     bBased on figures from 1983 when treatment is fully implemented.
     cTable may not add due to rounding.

-------
                                                                    TABLE. 6-25
                                                    TOTAL ANHUALIZED  TOTAL  COSTSa Bi SIZE OF SYSTEM
I
ro
o
FOR lNVc.STuf<-OVit>
(Millions
POPULATION
SIZE TOTAL t
CATEGORY OF PLANTS
25-99 2,078
100-499 2,227
500-999 375
1,000-2,499 247
2,500-4,999 88
5,000-9,999 51
10,000-99,999 69
100,000-999,999 10
>1 ,000,000
SUBTOTAL COMMUNITY
Oil', COSTS AND
AKN'UALIZED
CAPITAL COSTS
MONITORING
TOTAL COMMUNITY0
TOTAL
POPULATION
AFFECTED 1979
126,217 0
578,468 1
270,217 o
380,005 o
304,483 0
347,634 0
1,667,311 3
2,383,882 3

12
7
20
.95
.92
.55
.53
.79
.82
.07
.97

.59
.90
.49
clj UTILl
of Dollars Unless
I960
1.
3-
1.
1.
1.
1.
6.
7.

25.
8.
33.
90
84
10
06
58
64
14
94

20
20
40
19»1
2.
5.
1.
1.
2.
2.
9.
11.

37.
6.
43.
76
60
60
54
54
42
00
67

13
50
63
TIES

Otherwise Noted)
1962
3
7
2
2
3
3
11
15

49
7
56
.62
.36
.10
.02
.50
.20
.86
.40

.06
-30
.36
TOTAL PER
PLAliT
1963 (DOLLARS)13
4,
9-
2.
2.
4.
3.
14.
19.

61.
7.
67.
48 2,153
12 4,070
59 6,948
50 10,081
52 43,119
97 77,720
72 211,842
13 1,808,913

03
30
33
TOTAL PER
CAPITA
(DOLLARS)15
35.55
15.67
9.64
4.42
12.51
11.42
8.83
8.03




              aAssuaes:   (l).Debt  service  of 11  percent/year  on capital;  (2)  Capital  ownership  cost  of  3
         percent  to  cover taxes, insurance,  etc.;  (3)  Annual  O&M costs.

              bBased on  figures  from 1983  when treatment  is fully implemented.

              °Table nay not  add due to rounding.

-------
                                                          TABLE  6-26
                                           TOTAL  ANNUALIZED TOTAL COSTS BY SIZE OF SYSTEHJ*
(Millions of Dollars Unless Otherwise Noted)
POPULATION
SIZE TOTAL #
CATEGORY OF PLANTS
25-99 2,756
100-499 5,072
500-999 1,581
1,000-2,499 1,480
2,500-4,999 712
5,000-9,999 444
( 10,000-99,999 609
™ 100,000-999,999 56
^ >1, 000,000 2
SUBTOTAL COMMUNITY
O&M COSTS AND
AMNUALIZED
CAPITAL COSTS
MONITORING
SUBTOTAL COMMUNITY0
SUBTOTAL NON-COMMUNITY0
TOTAL0
TOTAL
POPULATION
AFFECTED 1979
167,397 1
1,317,695 4
1,140,158 2
2,275,479 3
2,455,510 6
3,022,906 7
14,625,537 26
12,748,032 21
5,010,781 12
85
32
118
103
227
.26
.38
-31
.17
.34
.16
.88
.21
.83
.55
.90
.45
.70
.15
I960
2
8
4
6
12
14
53
42
25
171
3^i
205
109
314
.52
.76
.62
.34
.68
.32
.76
.42
.66
.08
.00
.08
.80
.88
1981
3.
12.
6.
9.
18.
21.
78.
62.
38.
251.
31.
283.
107.
390.
66
72
74
22
68
04
91
38
50
85
20
05
00
05
1982
4
16
8
12
24
27
104
83
51
333
30
364
106
470
.80
.68
.86
.10
.68
.76
.06
.34
.33
.61
.40
.01
.20
.21
TOTAL PER
PLANT
19H3 (DOLLARS)b
5
20
10
14
30
34
129
104
64
415
30
445
106
552
.94 2,153
.64 4,070
.98 6,948
.98 10,081
.69 43,119
.52 77,720
.23 211,842
.30 1,808,913
.16 32,080,000
.44
.40
.84
.20
.04
TOTAL PER
CAPITA
(DOLLARS)"
35.55
15.67
9.64
4.42
12.51
11.42
8.83
8.03
12.31





     EAssunes:  (1) Debt service of 11 percent/year on capital;  (2) Capital ownership cost of 3
percent to cover taxes, insurance, etc.;  (3) Annual 0&M cost.i.
     bBased on figures from 1983 when treatment is fully implemented.
     °Table may not add due to rounding.

-------
                      CHAPTER SEVEN
                ECONOMIC  IMPACT ANALYSIS
7.0  Introduction

     The previous six chapters developed the aggregate costs
of implementing the Proposed Interim Primary Drinking Water
Regulations.   This chapter examines the impact of the
regulations on the Individual consumer, and it explores the
economic impact on all three classes of water users.  In
developing the treatment costs It has been assumed that
installation of treatment facilities will be the option
chosen by the community systems to meet the interim regula-
tions.  There are several other options available to these
systems, including purchase of water from existing systems,
development of alternative sources, regionalization of
systems, and possible use of exemptions and variances until
solutions to the on-site problems can be found.  It is
possible that these alternatives may be less expensive,
especially for small systems, and they should be examined on
a site-by-site basis.
7 .1  Monitoring Impacts

     The number of samples required per person, as a function
of the size of a given system, must first be determined.
This Is not difficult for chemical monitoring since under
ordinary circumstances the required sampling frequency per
system depends only on the system type (groundwater- vs.
surface-water; community vs. other) and not on the number of
people served.  The requirements for public systems are
summarized in Table 7-1.  Thus, for example, a 32-person
groundwater system must perform 0.015  (0.5 analyses -f 32
people) chemical analyses per person per year in the first
two years after implementation of the  regulations, and
0.0100 (0.33 analyses v 32 people) chemical analyses per
person per year thereafter.  A surface water system serving
one million people must perform 10~° (1 analysis ^ 1,000,000
people) chemical analysis per person per year-

     In the case of ordinary bacteriological monitoring the
sampling requirements of the interim primary regulations are
more complex.  Two coliform samples per month are required
                            -205-

-------
                          TABLE 7-1


               CHEMICAL SAMPLING REQUIREMENTS
                 FOR PUBLIC WATER SYSTEMS
                           COMPLIANCE TIME   TIME INTERVAL
                             POR INITIAL     pOR SUBSEQUENT
         qvqTFM
 TYPE OF SYSTEM                ANALYSIS         ANALYSES
                          (NUMBER OF YEARS) (NUMBER OF YEARS)
Community - surface-water


Community - groundwater


Other - surface
                          -206-

-------
of systems serving under 2,500 people, while tv:o monthly
samples for each 1,000 people are required for systems
serving between 2,500 and 100,000 people.  The required rate
per person falls off for larger systems; e.g., 200 samples
per month for a 100,000 person system and 500 samples per
month for systems serving 5,000,000 or more people.  Plate
counts must be taken once monthly (minimum) or at 10 percent
the rate of conform samples, whichever is greater.

     Since the required number of plate count analyses is a
function of coliform sampling requirements, the numbers of
both analyses can be added as a step in determining costs.
This has been done in the construction of Figure 7-1,
which plots the number of bacteriological samples (coliform
plus plate count) required per person per year against the
size of the water system.

     The monitoring costs per person developed for systems
of representative sizes are shown in Table 7-2.

     The figures for bacteriological samples are taken from
Figure 7-1-  Costs per analysis are calculated assuming a
cost of $7-50 per bacteriological analysis and $400.00 for
complete organic and inorganic chemical analyses (these are
the median monitoring costs developed in Chapter Four).
Thus the maximum cost would be $26.80 per person per year in
a surface water system, serving 25 people.  Costs per person
per year are plotted in Figures 7-2 and 7-3-
7.2  Price Impacts - Case Studies of Model Systems

     The additional treatment necessitated by the Proposed
Interim Primary Drinking Water Regulations would result in
additional treatment costs for water supply systems, costs
which in turn would be passed on to water customers in the
form of higher rates.  In order to demonstrate the impact of
additional treatment costs on water rates, model systems of
three sizes,  based on population served, are analyzed.

     To simplify the analysis of the aggregate impact under
the interim primary regulations, an interest rate of 7 percent
has been designated as the cost of financing for an average
water system.  A second simplifying assumption was that a
15-year payoff period would be used to finance the costs.
As  mentioned  earlier,  small investor-owned facilities are
riskier than  large government-owned operations.  The cost of
money to the  former is correspondingly higher than to the
latter.   Tables 7-3, 7-4, and 7-5 break down the per capita
                             -207-

-------
O
00
I
     cd
     O)
     >H
     CL>
     PH
     O
     ra
     !H
     (U
     PH
     W
     0
     oi
     00
     O
          o.i -
 0.01
     0
     X2
     e
0.001
                          100
                                  1
                               1,000
10,000
100,000
10,000,000
                                 S±ze of System  (Population  Served)
                   Figure 7-1.   This  figure displays the annual per capita bacteriological
               samples versus  size  of water system.

-------
                                                   TABLE  7-2




                           ANALYTICAL  COSTS  PER PERSON VERSUS  SYSTEM SIZE  AND  TYPE
FOR COMMUNITY WATER SYSTEM


System
Size



1,
ro 3 >
0
- 10,
32,
100,
320,
1,000,
3,200,
10,000,
32
100
320
000
200
000
000
000
000
000
000
000



Samples

Per



Person Per Year
Bacteriological Chemical3
1
0
0
0
0
0
0
0
0
0
0
0
-13
.360
.115
.0360
.0154
.0168
.0150
.0132
.0072
.00396
.00190
. 00066
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
032
010
0032
0010
00032
00010
000032
000010
0000032
0000010
00000032
00000010


s



Analysis Costs Per Person Per Year ($)
Chemical Bacteriological
0
0
0
0
0
0
0
0
0
0
0
0
.010
.0032
. 0010
.00032
.00010
. 000032
.000010
.0000032
.0000010
.00000032
.00000010
.000000032
8.
2.
0.
0.
0,
0.
0.
0.
0.
0,
0.
0.
47
70
86
27
,11
,13
. 11
,10
,05
,03
,01
,005
Chemicaia'd
12 . 80
4.00
1.28
0 . -'4 0
0.13
0.04
0.01
0.005
0.001
0
0
0
Chemical0 'd Totala
4.00 21
1.28 6
0 . 4 0 2
0.13 0,
0.04 0
0.01 0
0.005 0
0.001 0,
0 0.
0 0.
0 0.
0 0.
.27
.70
. 14
.67
.24
.17
.12
.11
.05
.03
.01
.005
Totalb
12.47
3.9P
1.26
0.40
0.15
0.14
0.12
0.10
0.05
0.03
0.01
0.005
 For Surface System:   rate - one chemical sample  per year.



DFor Ground System:   rate - one  chemical sample  each 3 years.



^Estimated Cost:   $7-50 per analysis.



Estimated Cost:   $400 per analysis

-------
$35
                      100
1., 000
10,000
                         Size of System
                       (Population Served)
         Figure  7-2.   This figure  shows annual monitoring
     costs per person - small  system.
                         -210-

-------
$.70
   0
   1,000
10,000           100,000        1,000,000


  S-ize of System  (Population Served)
10,000,000
         Figure 7-3-   This  figure shows  annual monitoring
    costs  per person -  large system.
                             -211-

-------
impacts of these different financing costs according to
utility size and treatment process.  Measured only against
the costs of new plant and equipment, financing charges and
pay back period differences are not insignificant (Tables
7_33 7_l|3 and 7-5) when all costs are considered, however,
the per capita impact of different interest rates is less
noticeable (Table 7-6).

     The annual cost of each of six potential treatments was
computed for each model system.  Table 7-7 shows that unit
costs range from $0.003 per thousand gallons for pH control
in a large system to $2.27 per thousand gallons for ion
exchange in a small system.

     While the combination of treatments required depends on
the composition of the impurities requiring treatment, a
probability analysis showed that no more than two types of
treatment would be used within a single system.  The most
common required treatment combinations are listed in Table
7-8; along with the projected percentage of occurrence by
system size.

     Note that clarification alone accounts for nearly two-
thirds of all surface-water treatment in the smaller
regulation category.  Chlorination alone and ion exchange
alone are the most frequently needed treatments for ground-
water systems.

     Costs for each treatment are developed in Tables 7-7
and 7-9-  Ion exchange is generally one order of magnitude
more expensive than Chlorination and systems serving 100
people are by far the most expensive to treat on a per
capita basis (Table 7-9).  Although ion exchange is the most
expensive treatment for all sizes of systems, clarification
costs are also significant.

     According to the National Association of Water Companies,
total revenue from water sales is segregated as follows:  6l
percent residential, 19 percent commercial, 8 percent indus-
trial, 11 percent other (mainly municipalities and other
agencies) (Table 7-10).
      National Association of Water Companies, "1973 Financial
Summary for Investor-Owned Water Utilities" (Washington, D.C.),
p. 2.
                              -212-

-------
                                      TABLE  7-3






         PER CAPITA AimUALIZED CAPITAL  COSTS FOR A SYSTEM SERVING 100 PEOPLE3-

ANNUAL CAPITAL COSTS ($)
CAPITAL10
PROCESS COST C$)
Chlorination 8 10


Clarification 23,500


Ion Exchange 48,000


Activated Alumina 3,400


Activated Carbon 2,100


INTEREST0
RATE
11
9
7
11
9
7
11
9
7
11
9
7
11
9
7

15



Q
J
O
_)
3
7
7
6






PAY
YRS
138
121
113
,910
,567
,241
,987
,286
,619
566
516
469
349
319
290
ANNUAL
PER
BACK PERIOD
20 YRS
121
113
97
3,687
3,243
2,890
7,387
6,624
5,904
523
469
419
323
290
259
25



3
3
2
7
6
5






YRS
119
105
93
,471
,074
,700
,090
,278
,515
502
445
391
310
275
241
15
1
1
1
39
35
32
79
72
66
5
5
4
3
3
2
PAY
YRS
.38
. 21
.13
.10
.67
.41
.87
.86
.19
.66
.16
.69
.49
.19
• 90
CAPITAL
CAPITA
BACK
20
1
1
0
36
32
28
73
66
59
5
4
4
3
2
2
COST
($)
PERIOD
YRS
.21
.13
• 97
.87
.43
-90
.87
.24
.04
.23
.69
.19
.23
.90
• 59
2$ YRS
1.19
1.05
0.93
34.71
30.74
27 .00
70.90
62.78
55.15
5.02
4.45
3-91
3-10
2.75
2.41
r'Ar-;surries only residential use.



°Bar;ed on 109 gallons  (0.412 rn°)  produced per consumer per  day.



°Does riot include  3  percent for Insurance, taxes, etc.

-------
                                      TABLE 7-4
         PER CAPITA ANNUALIZED CAPITAL COSTS FOR A SYSTEM SERVING 5,000 PEOPLE
                                                                              a
CAPITAL13 INTEREST
PROCESS COST ($) RATE
Chlorination 10,000


Clarification 220,000


Ion Exchange 660,000

i
ro
i 	 i
1
"f Activated Alumina 50,000


Activated Carbon 93,000


9
7
6
9
7
6
9
7
6
9
7
6
9
7
6
ANNUAL CAPITAL COSTS
C PAY BACK PERIOD
15 YRS 20 YRS 25
1
1
1
33
30
28
100
91
86
7
6
6
14
12
12
,518
,380
,308
,396
,338
,886
,188
,014
,658
,590
,895
,565
,117
,825
,211
1,379
1,231
1,149
30,360
27,060
25,520
91,030
81,180
76,560
6,900
6,155
5,850
12,834
11,448
10,788
1,
1,
1,
28,
25,
23,
86,
75,
70,
6,
5,
5,
12,
10,
9,
($)
YRS
313
160
074
776
278
628
328
834
884
540
745
370
164
686
988
ANNUAL CAPITAL COST
PER CAPITA ($)
PAY BACK PERIOD
15 YRS 20 YRS 25 YRS
0
0
0
6
6
5
20
18
17
1
1
1
2
2
2
• 30
.28
.26
.68
.08
.78
.04
.20
• 33
• 52
.38
• 31
.82
.56
.44
0
0
0
6
5
5
18
16
15
1
1
1
2
2
2
.27
.25
.23
.08
.41
.10
.20
.24
• 31
• 38
.23
.16
.56
.29
.16
0.26
0.23
0.21
5-75
5.06
4.73
17.27
15.17
14.18
1-31
1.15
1.07
2.43
2.14
2.00
aAssumes only residential use.



bBased on 154 gallons (0.582 m3) produced per consumer per day,



°Does not include 3 percent for Insurance, taxes, etc.

-------
                                             TABLE 7-5
                PER CAPITA ANNUALIZED CAPITAL COSTS FOR A SYSTEM SERVING 100,000 PEOPLE'
I
ro
ANNUAL CAPITAL COSTS ($)
CAPITALb INTEREST0 PAY BACK PERIOD
PROCESS COST ($) RATE 15 YRS 20 YRS 25 YRS
Chlorination 100,000


Clarification 1,900,000


Ion Exchange 5,800,000


Activated Alumina 350,000


Activated Carbon 1,100,000


9
7
6
9
7
6
9
7
6
9
7
6
9
7
6
15
13
10
288
262
249
880
799
761
53
48
45
166
151
144
,180
,800
,080
,420
,010
,470
,440
,820
,540
,130
,265
,955
,980
,690
,430
13,790
12,310
8,490
262,200
233,890
220,400
880,400
713,980
672,800
48,300
43,085
40,600
151,800
135,410
127,600
13
11
7
248
218
204
758
666
622
45
40
37
143
126
118
,130
,600
,740
,520
,310
,060
,640
,420
,920
,780
,615
,590
,880
,390
,140
ANNUAL
PER
PAY
15 YRS
0
0
0
2
2
2
8
8
7
0
0
0
1
1
1
.15
.14
.10
.88
.62
.49
.80
.00
.61
• 53
.48
.46
.67
• 52
.44
CAPITAL COST
CAPITA ($)
BACK PERIOD
20 YRS 25 YRS
0
0
0
2
2
2
8
7
6
0
0
0
1
1
1
.14
.12
.08
.62
• 34
.20
.00
.14
• 72
.48
.43
.41
• 52
-35
.27
0.13
0.12
0.08
2.49
2.18
2.04
7-59
6.66
6.23
0.46
0.40
0.38
1.44
1.26
1.18
         Assumes only residential use.
        bBased on 174 gallons (0.658 m^) produced per consumer per day.


        cDoes not Include 3 percent for Insurance, taxes, etc.

-------
                                              TABLE 7-6
                      DISTRIBUTION OF COSTS FOR THOSE SYSTEMS  NEEDING TREATMENT
                               BY SIZE OP SYSTEM FOR POUR  SIZE  RANGES
i
ro
i—'
cr\
I
                                    SMALLEST SYSTEMS
                                       (25-99
                                     PEOPLE SERVED)
                                             SMALL SYSTEMS
                                              (100-9,999
                                            (PEOPLE SERVED)
               MEDIUM SYSTEMS
               (10,000-99,999
               (PEOPLE SERVED)
          Annual Capital Costs
          ($ million)
                              3.8 -  6.4
Annual O&M  Costs  ($ million)    2.1

Annual Monitoring Costs      0.5 - 1-0
($ million)
60.8 - 102.1
 0.9 - 1.8
53-6 - 90.0
1.8 - 3.
          TOTAL ANNUAL COSTS
          ($ million)
                LARGE SYSTEMS
                (OVER 100,000
                PEOPLE SERVED)
                31.8  - 53-4
                  1.9 -
                              6.4 -  9-5     112.7 - 154.9    131.1  - 169.5   168.3 -  192.2
          Average Cost per  Capita
          per year ($)

          Increase in Household
          Monthly Water
                               38 -  56         11 - 15


                             9.93 _  14.74    2.86 - 3.93
                    9-12


                 2.32 - 3-01
                   10 - 11


                 2.46 - 2.91
               aAssumes 3-11 persons per household and  that  all increases in  costs  are passed
          on to the consumer.

-------
                          TABLE 7-7
     ANNUALIZED COSTS  OF TREATMENT IN MODEL SYSTEMS
                (Dollars per 1,000 Gallons)
PROCESS
                        SYSTEM SIZE (POPULATION SERVED)
                    100L
TOTAL  COST
 ($)   ($)
   5,000
TOTAL   COST
 ($)    ($)
  100,000
TOTAL   COST
 ($)    ($)
Chlorlnatlon
  209  0.05
        0.03     183,800  0.03
Clarification   5,251  1-32    84,338  0.30   1,262,010  0.20


Ion Exchange    9,019  2.27   154,014  0.55   1,299,820  0.20
Activated
Alumina
  779  0.19    22,895  0.
                 318,265  0.05
Activated
Carbon
4,690  1.18    54,825  0.19     243,690  0.04
pH Control
   61  0.02     1,730  0.006     21,700  0.003
      Assumes 7 percent annual interest on capital costs
amorti/.ed over 15 years, plus O&M.

     bAssumes 109 gallons (0.412 m3) per capita day production.

     GAssumes 154 gallons (0.582 m^) per capita day production

     ^Assumes 174 gallons (0.658 m3) per capita day production,
                          -217-

-------
I
ru
I—'
co
I
                                                  TABLE 7-i
                      PROBABILITY OF NEEDING  TREATMENT COMBINATIONS BY SYSTEM SIZE

(Percent of
Systems )

System Size (Population Served)
PROCESS
Mo Treatment
Chlorination Only
Clarification Only
Ion Exchange Only
pH Control Only
Activated Alumina Only
Activated Carbon Only
Chlorination & Ion
Exchange
Chlorination & Activated
Alumina
Chlorination & Clarification
Chlorination & Activated
25 - 99
SURFACE GROUND
1 66
19
72
5
1
4
1
2 2

1

21
3
100 - 9
SURFACE
18
2
65








9
2
,999 10,000 - 99,999 Over 100,000
GROUND SURFACE GROUND SURFACE GROUND
74 28 79 69 81
12 2 6 4 4
59 20
61627
222
4 5 5
1 2
121

1

5 1
2 1
      Carbon
      Clarification & Ion Exchange

-------
                                                       TABLE  7-9
                PROJECTED COSTS  EFFECTS BY  TREATMENT  PROCESS ON THREE SIZED WATER  SYSTEMS
 !
ro
VD
 I

PROCTTCC 100 PEOPLEb 5,000 PEOPLE0 100,000 PEOPLEd
$/l,000 GAL
Chlorination
Clarification
Ion Exchange
Activated
Alumina
Activated
Carbon
pH Control
0.
1.
2.
0.
1.
0.
05
32
27
19
18
02
$/CAPITA
2.
52,
90.
7.
46
0,
,16
.51
.19
.79
.90
.61
$/HOUSEHOLD $/l,000 GAL $/CAPITA
6.72 0.03 1.78
163.31 0.30 16.87
280.49 0.55 30.80
24.23 0.08 4.58
145.86 0.19 10.97
1.87 0.006 0.35
$/HOUSEHOLD $/l,000 GAL $/CAPITA
5.52 0.03 1.
52.46 0.20 12,
95-80 0.20 13,
14.24 0.05 3.
34.10 0.04 2,
1.08 0.003 0.
.79
.62
.00
,18
,44
,02
$/HOUSEHOLD
5.
39.
40.
9.
7.
0.
72
25
43
89
59
07
              Assumes 7  percent interest on capital  costs amortized over 15 years plus O&M costs.

              Assumes 109  gallons (0.412 mj) produced per person per day.

             cAssumes 154  gallons (0.582 m ) produced per person per day.

              Assumes 174  gallons (0.658 m ) produced per person per day.

-------
                    TABLE 7-10
   WATER SALES AND REVENUE BY TYPE OF CUSTOMER3"
                       PERCENT  OP      PERCENT OF
                       TOTAL  USE      TOTAL REVENUE
Residential               44               6l


Commercial                27               19


Industrial                19                8


Other                     10               11




PERCENT OF TOTAL        100                99
     o
      National Association of Water Companies,  "1973
Financial Summary for Investor-Owned Water  Utilities."
                         -220-

-------
     If the present distribution of costs continues, the
additional costs of chlorination and clarification -- the
most frequent treatment processes -- will fall according to
the pattern displayed in Table 7-11.  Should rates align
with usage, then all users in a particular system would pay
the same rate (e.g., 15-5 cents per 1,000 gallons would be
the price increase for residential, commercial, industrial,
and other users in the 100-person chlorination only system).

     Assuming that the current average price for water is
$0.60 per 1,000 gallons, the smallest household increase
indicated on Table 7-11 would represent a 7-0 percent price
hike and the largest would represent a 336 percent price
hike.  Correspondingly, a base price of $0.30 per 1,000
gallons would mean a rate increase of 1^.1 percent at the
low end of the scale and 672 percent at the high end,  Due
to the wide range of base rates across different systems, it
is impossible to develop a realistic "average" rate.  A
range of rates, however, is included in Table 7-12.

     Historically, industrial and commercial water usage has
been inelastic to price increases.^  For residential (house-
hold) customers, water appears price elastic with respect
primarily to lawn sprinkling (see Section 6.2.3).  Yet this
does not necessarily mean that higher treatment costs can be
passed to customers readily in the form of higher rates.  If
price elasticity is -0.65, as Gottlieb believes, and prices
increase 100 percent, as they well may In small systems
requiring expensive treatments, then total revenue to water
suppliers will fall (see Table 6-9).  Total revenues, rather
than rates per se, are the critical figures for water suppliers
As demand falls in the first round of rate hikes, a second
stage increase may be necessary to cover the largely fixed
costs of water treatment.

     Financial implications aside, the political reper-
cussions of increasing water rates dramatically could be
substantial. Unless local customers clearly understand the
reasons behind the interim primary regulations and the
related rate hikes, they may reject both.  The mandatory
notification criteria of the proposed regulations would
serve to Inform the local residents of contaminant problems
associated with their water.
     1Patterson et al., "Water Use," JAWWA, 1973-
                             -221-

-------
                               TABLE  7-11
         PRICE  IMPACTS  OF  REPRESENTATIVE TREATMENTS
   BASED  ON PRESENT AVERAGEDISTRIBUTION OF TOTAL  COSTS
     Chlorlnatlon Only

1.   Increase  in Unit Cost
    (cents/1,000 gal)

2.   Total  Annual Systems Increase
    (dollars)

3.   Increase  in Household Unit
    Cost  (cents/1,000 gal)e

4.   Increase  in Commercial Unit
    Cost  (cents/1,000 gal)f

5.   Increase  in Industrial Unit
    Cost  (cents/1,000 gal)S

6.   Increase  in Other Unit Cost
    (cents/1,000 gal)n
    Clarification Only

1.   Increase  in Unit Cost
    (cents/1,000 gal)

2.   Total  Annual Systems Increase
    (dollars)3

3.   Increase  in Household Unit
    Cost  (cents/1,000 gal)b

4.   Increase  in Commercial Unit
    Cost  (cents/1,000 gal)c

5.   Increase  in Industrial Unit
    Cost  (cents/1,000 gal)d

6.   Increase  in Other Unit Cost
    (cents/1,000 gal)e
       Systems Size
     Population Served

  100b     5,000°   100,000d
            3.48
           3.06
   616
 21.1)6
 10.
  6.52
 17.03
9,780    194,300
 4.82
 2.45
 1.4?
 3.83
 4.24
 2.15
 1.29
 3.37
       Systems  Size
     Population Served

  100b     5,000C    100,000d
142.04
30.33
20.04
 5,651    85,?38   3,27?,510
196.92     42.05
 99-95
 59-81
156.24
21.34
12.77
33-36
          27.78
14.10
 8.44
22.04
         Costs include  annualized capital costs plus O&M plus  monitoring

         Based on 109 gallons  (0.412 m3) per capita day production.

        cBased on 154 gallons  (0.582 m3) per capita day production.

         Based on 174 gallons  (0.658 m3) per capita day production.

         Assumes  residential customers pay 61 percent of total costs
   and use 44  percent of  output.
        f
         Assumes  commercial customers pay 19 percent of total  costs
   and use 27  percent of  output.
        a~
        &Assumes  industrial customers pay 8 percent of total costs
   and use 19  percent of  output.

         Assumes  other  sales pay 11 percent of total costs and use
   10 percent  of  output.
                                -222-

-------
                        TABLE  7-12
          SAMPLE  OP  WATER RATES ACROSS THE COUNTRY
    CITY
POPULATION
  SERVED
RATE PER 1,000 GALLONS
Bradenton,  Fla.       70,000
Wheeling,  W.  Va.      50,000
               804
               724
                                  334
 for first 20,000
 for next  80,000

 for first  1,000
 for next  99,000
Elkhart, Ind.
Carlsbad, N. Mex .
Borf
?;er, Tex.
Honolulu, Hawaii
Tucson, Ariz.
Kinj;
^sport, Term.
Arcadia, Fla.
Lancaster, Pa.
Dayton, Ohio

Source: Elroy
40
25
14
545
284
43
7
150
500
,000
,000
,000
,000
,000
,000
,300
,000
,000
F. Spitzer,
304
184
4504
154
3004
854
374
304
5004
344
804
504
3004
604
604
434
4004
314
for
for
first
next
minimum
for all
minimum
for next
for
for
3
3
0
for
else
for
first
next
minimum
for next
for
for
8
50
350
for
23
first
next
minimum
for next
for
for
f
first
next
minimum
for next
f
9
2
2
or
11
75
925
or
ed . , Modern Water
9
,300
,000
first
first
,000
,000
,000
first
,000
,500
,500
first
,000
,000
,000
first
,000
Rates

3,000
2,000

5,300

4,000

1,000
(8th
 edition), American City Magazine,  publisher  (Pittsfield,
 Mass.:  Buttenheim Publishing  Co.,  1972).

-------
     In 1974 the water industry spent about $1.5 billion on
capital improvements.1  Since the 5-year average total annual
capital expenditures mandated by the proposed interim
regulations are only 13 to 24 percent of this figure, it is
anticipated that the industry as a whole would be able to
raise the additional necessary capital.  As Table 7-6 shows,
however, the financial burden does not fall equally across the
industry.  Small firms may encounter difficulty in financing
new treatment facilities, particularly when ion exchange, a
relatively expensive process, is required (see Section 6.1).
7 . 3  Macroeconomic Effects_

     The macroeconomic effects of the Proposed Interim Primary
Drinking Water Regulations are expected to be minimal.  On the
average, the regulations will cause an increase in water rates
of 9.5 percent spread over several years.  If this Increase
occurred in 1 year, the resulting increase in the Consumer
Price Index (CPI) would be less than 0.003. percent.  Since
the costs of these regulations will be incurred over several
years, the average annual increase in the CPI will be even
less.  The Chase Econometric Model predicts an estimated
average annual increase in the CPI of less than 0.1 percent
due to all pollution abatement programs.2
7 . 4  Energy Use

     It is estimated that approximately 21,200 billion Btu's
per year will be required to operate plants and produce
chemicals for the various treatment systems necessary for
the 40,000 community systems to meet the regulations.  This
is  0.028 percent of the 1973 national energy consumption,
based on the 1974 Statistical Abstract.  The increase in
energy use will depend on a number of factors, including
whether pollution in surface sources of waters Is successfully
controlled.  There will be no direct energy savings from the
recommended action.
      U.S.  Department of Commerce, U.S. Industrial 1970
Outlook (Washington,  D.C.), p.  17!
     2
      Chase Econometric Associates, Inc., "The Macroeconomic
Impacts of Federal Pollution Control Programs," prepared for
the Council of Environmental Quality and the Environmental
Protection Agency, January 1975.
                            -224-

-------
                      CHAPTER  EIGHT


                 LIMITS  OF  THE ANALYSIS
8.0   Introduction

     This  chapter  reviews  the major assumptions of this
report  in  order  to bring the costs developed into proper
perspective.   Further,  the limitations of each assumption
are  explored.
8.1  Assumptions  in Developing Monitoring Costs

     The  dominant assumption used in developing monitoring
costs is  that  the EPA Inventory of Community Water Systems
provided  an accurate description of the population of water
supplies  in the United States.  This report further assumes
that the  EPA projection of 40,000 community water supplies
is valid.   There  is some evidence from an ERGO survey of
state agencies that this estimate is low by a factor of 20
percent,  thereby  causing the projected monitoring costs to
be low by 20 percent as well.

     The  EPA estimate of 200,000 public non-community
systems is also accepted as valid in this study.  No conclu-
sive evidence  has been uncovered which either confirms
or refutes this estimate.

     The  monitoring costs  were developed from the following
assumptions :

     1.   Only the minimal routine monitoring mandated
          by the  Proposed  Interim Primary Drinking
          Water Regulations would be performed;

     2.   A range of between 7 and 30 coliform measurements
          would be made for each coliform violation found;

     3.   A range of between 8 and 52 analyses will be
          performed for each organic and inorganic
          violation found.
                             -225-

-------
It is quite possible that many systems, particularly those
systems with chemical and biological laboratories, will
choose to sample at a more frequent rate than that mandated
by the regulations.  Likewise, it is possible that many
systems will analyze multiple samples to calculate one-
month, three-month or yearly moving averages to determine if
a system is in or out of compliance.  Until a more complete
data base is developed, it is impossible to predict the
number of systems which will perform multiple sampling to
assure compliance with the Interim Primary Drinking Water
Regulations.

     Special monitoring and treatment costs are all developed
from the 1969 CWSS study of 969 water supply plants in nine
regions of the country.  These systems were not chosen
randomly, but rather to represent specific water source
characteristics (see Appendix K).  The CWSS study therefore
has several inherent biases which are magnified in projecting
special national monitoring costs.

     This report made no estimate on the costs of turbidity
monitoring for the 40,000 community systems and the 2,000
to 5,000 public non-community systems which will need to
make turbidity measurements to comply with the Interim
Primary Drinking Water Regulations.  It was assumed that
turbidity sampling Is presently being performed at each
site.  It is useful, however, to examine the costs of this
monitoring activity.  If one assumes that it takes 10 minutes
to collect and analyze each turbidity sample, then 505 man-
years of effort would be required nationally to satisfy the
turbidity monitoring requirement.  Assuming a salary of
$4.00 per hour and an overhead rate of 100 percent, labor
alone would cost $1.33 per turbidity analysis.
8.2  Assumptions In Developing Treatment Costs

     The assumptions regarding the number of systems and the
validity of the CWSS data base, as developed in the previous
section, are equally important in this section.

     In preparing estimates for total national treatment
costs of implementation of the Proposed Interim Primary
Drinking Water Regulations, a set of treatment assumptions
was developed by EPA personnel.  These assumptions can be
summarized as follows:
                             -226-

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     1.    Disinfection equipment will be installed in
          27.5  percent of community surface and ground
          systems which do not presently disinfect.
          This  percentage was arrived at by assuming
          15  percent of the systems analyzed the first
          year  would fail, and 15 percent of the remainder
          would fail during the second year;

     2.    All community surface systems which do not
          presently clarify will be forced to install
          clarification equipment;

     3-    All systems which violated one or more maximum
          contaminant levels (MCL) in the 1969 CWSS
          study will be forced to treat for the MCL;
          furthermore, the systems of the CWSS are
          considered representative of the nation's
          water systems as a whole-

     Once the assumptions were developed to establish which
systems  would need treatment, a treatment technology was
assigned to each MCL.  The technology and MCL are listed in
Table 8-1.

                          TABLE 8-1

                   TREATMENT TECHNOLOGY FOR MCL
     TREATMENT TECHNOLOGY                    MCL


     Clarification (direct filtration)        Turbidity

     Ion Exchange                            Ba, Cd,  Cr,  Hg,
                                             N03, Se,  CN,  Ag

     Chlorination                            Coliform

     Activated Carbon                        CCE

     Activated Alumina                       Fluoride, As

     pH Control                              Lead
     The EPA inventory of water supply systems was then
utilized to determine the number of systems which presently
do not  treat for turbidity and coliform.   It was decided
                            -227-

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that if a surface system has no coagulation unit, then it
would need to install a direct filtration unit to meet the
turbidity requirement of the proposed interim regulations.
Likewise, if a system had no disinfection equipment in the
inventory, it would need to install a chlorinator.

     It is believed that if the treatment technologies are
uniformly applied to the existing 40,000 supply systems,
the goal of safe drinking water will be met.  The $1.1 to
$1.8 billion capital requirement developed represents the
cost of reaching this goal.

     There are several reasons why the $1.1 to $1.8 billion
capital requirement estimated to implement the Proposed
Interim Primary Drinking Water Regulations may not be a
maximum amount.  In calculating the treatment costs for
turbidity control, direct filtration was chosen as the most
suitable technology.  While it Is true that direct filtra-
tion offers a reasonable treatment for those systems with
turbidity under 100 JTU, it is not practical if the turbidity
of the water is consistently above this level.  Therefore,
it is highly likely that many systems might desire to
install the more expensive coagulation, sedimentation, and
filtration technology to insure more uniform quality effluent
during periods of high turbidity.  The capital and annual
O&M expenses calculated for turbidity control using direct
filtration versus coagulation, sedimentation, and filtration
are shown In Table 8-2.

     In developing the national capital cost estimates, no
attempt was made to assign turbidity control costs to the
1,366 mixed surface and ground systems.  If a mixed source
system obtains the majority of its water from a surface
source, then it is probable that some form of clarification
will be required.

     In this study it was assumed that only 27,5 percent of
the water systems presently chlorinating would need to
disinfect their water supplies; this includes both surface
and ground sources of water.  It is possible that more
systems may need some form of disinfection to meet the
coliform standards.

     Likewise, there are several reasons why the projected
capital requirement may be higher than actual requirements.
One important assumption is that all plants which exceed a
maximum contaminant level will use a treatment process to
correct their problem, when in reality a great number of
                            -228-

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              TABLE 8-2
COMPARISON OF TURBIDITY CONTROL COSTS

POPULATION
SERVED
25-99
100-499
500-999
1,000-2,499
2,500-4,999
5,000-9,999
10,000-99,999
100,000-999,999
- 1,000,000
CLARIFICATION COSTS
ASSUMING COAGULATION,
SEDIMENTATION,
FILTRATION
($)
220,000
300,000
370,000
430,000
480,000
530,000
1,400,000
7,200,000
41,000,000
CLARIFICATION COSTS
ASSUMING DIRECT
FILTRATION
($)
21,000
30,000
41,000
52,000
150,000
270,000
640,000
3,400,000
22,000,000
                -229-

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plants will blend water which already meets the standards
with water which exceeds the standards.  Blending would
reduce the costs of those systems which must treat for NO^,
Se, Cd, Cr, As, Hg, and Ba violations, but would not affect
costs associated with chlorination and clarification.  In
the 1975 ERGO survey of 207 water supply systems which
violated one or more maximum contaminant levels in the 1969
CWSS study, ERGO found five systems which treated for NOo
and Se problems subsequent to the 1969 CWSS study (Appendix D,
Table  D-2).   All five of these systems employed blending
rather than the more expensive ion exchange treatment.
Since ion exchange processes account for almost 35 percent
of the total treatment costs this could be an important
consideration.

     The treatment costs developed do not consider any
possible benefits to be derived from the cascading of
treatment processes.  In many cases it is possible to treat
several contaminants simultaneously, thereby reducing
costs.  In particular, coagulation and direct filtration may
remove many contaminants which are associated with turbidity
in the water.  Engineering tests are necessary to establish
the feasibility of this approach.  However, with the limited
data available it is impossible to quantify the benefits to
be derived from cascading.  Likewise, It is Impossible to
quantify any beneficial effects attributable to the retro-
fitting of treatment processes. There are 2,126 water systems
which would install clarification equipment.  These systems
could have large retrofit interactions which could have a
large effect on costs (Appendix I).

     In developing the treatment costs, it became apparent
that considerable attention should be given to the costs
which would be borne by small (under 1,000 population served)
water systems.  Table 8-3 lists the capital costs associated
with each treatment technology for the systems serving 1,000
or fewer people.  When one looks at the capital costs for
clarification and ion exchange for these small systems, it
is apparent that the per capita burden of treatment is too
great for any small community to bear.  It is equally true,
however, that these small systems will need to comply with
the Interim Primary Drinking Water Regulations in the same
manner as will larger systems if these regulations are
accepted in the proposed form.

     The small systems (as well as larger systems) would
probably consider the following options rather than install
expensive treatment processes:
                             -230-

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                                              TABLE 8-3
                          CAPITAL TREATMENT COSTS FOR SMALL WATER SYSTEMS'
                                 USING CURRENT PRODUCTION RATES
i
ro
uo
H
I
            POPULATION
              SERVED    DISINFECTION  CLARIFICATION
              GROUP
  ION      pH    ACTIVATED ACTIVATED
EXCHANGE CONTROL  ALUMINA    CARBON
25-99
100-499
500-999
690
1,200
1,800
21,000
30,000
41,000
41,000
68,000
100,000
400
800
1,200
2,600
6,100
12,000
1,500
4,300
10,000
                  Based on average sized systems in the EPA Inventory of Community Water
             Supply Systems.

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     1.    Shift  source  of water from surface to ground;

     2.    Change groundwater sources;

     3.    Consolidate  (merge systems);

     4.    Purchase  finished water;

     5.    Disband the  community system and go to individual
          well  sources.

     It  is possible to  develop cost data for options 1 and 2.
In both  of these options it is necessary to develop well
costs, which are dependent on the initial cost of structures
and equipment,  the  useful life of structures and equipment,
and the  cost of operation and maintenance.  As in any
engineering project, it is possible to vary the costs of all
three cost factors.  A complete description of well costs
can be  found in Rural  Water Systems Planning and Engineering
Guide by Campbell and  Lehr.1  For purposes of illustration,
the cost will be developed for a 6-inch diameter 80-foot
deep medium high capacity sand well using a 40-gallon per
minute  submersible  turbine pump with 400 feet total lead.
The well cost of $6,177 includes setting up and removing the
drilling equipment, drilling the well (test drilling not
included), all  casings  and liners including construction
casings, grouting and  sealing the annular spaces between
casings  and between casings and the boreholes, well screens
and fittings, gravel pack materials, and placing and con-
ducting  one 8-hour  pumping test.  Not included in this
estimate are preliminary hydraulic tests and site exploration.
The submersible pump would cost $3,921.  It Is anticipated
that the pump will  remain maintenance-free for a period of 5
years before major  repairs would be instituted.  A third
cost associated with the construction of a new water system
is the water transmission cost.  For example, it would cost
$35,000  per mile to lay a 6-inch diameter pipe.  Finally,
any treatment costs associated with the new water source
must be  considered.  Briefly summarizing the results of this
example, it would cost $10,098 to construct the well and
install  a pump, with a cost of $35,000 per mile for trans-
mission  lines.

     If  systems choose options 3 or 4 above, then the primary
cost to  consider is the cost of the transmission lines to
furnish  water to all parts of the system from the new source.
      Michael D. Campbell and Jay H. Lehr, Rural Water
Systems Planning and Engineering Guide, Commission on Rural
Water (Washington, D.C., 1973).
                            -232-

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     Figure 8-1 shows the equivalent monthly cost of operating
a single domestic well.  A typical well would cost $1,200 to
drill-^and the average low capacity pumping system would cost
$980.   It would cost about $22 per month to run a single-
family well.   Presumably, if municipal water costs exceeded
this cost and groundwater sources were available, people
would choose to develop their own water source rather than
purchase water from a community system.

     Table 8-^1 shows the total national costs of applying
the recommended treatment technologies to comply with the
Interim Primary Drinking Water Regulations.  It is apparent
that many of these costs will not be spent on treating these
small systems.  What Is not known, however, Is the number of
systems which will purchase water from existing systems,
thereby increasing treatment costs for those systems.  Until
these two factors can be determined, it appears reasonable
to assign the costs to small systems even though they may
not ultimately treat their present source of water.
8.3  Assumptions Inherent in the Constraint Analysis

     It Is assumed that in the coming decade polyelectrolytes
will largely replace inorganic salts as the predominant
coagulants, thereby increasing the demand for the former
material.

     It is anticipated that manpower needs will follow the
historical patterns, although an increase in monitoring and
reporting functions could cause an increase in the personnel
required to fulfill these functions.
8.4  Other Assumptions

     A 7 percent interest rate is assumed on all capital
financing.  This is somewhat more than a municipality might
have to pay, but less than might be paid by an investor-
owned utility.  A 15-year pay back period was assumed.  In
general, systems may choose larger pay back periods, but the
overall effect of changing pay back periods and interest
      Campbell and Lehr, Rural Water Systems Planning and
Engineering Guide, 1973-
                             -233-

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                                    BASED ON
                              WELL LIFE OF 20 YEARS
                              PUMP LIFE OF 10 YEARS
                              ANNUAL INTEREST RATE
                              COMBINED ANNUAL MAINTENANCE $10
                  800        1200
                     INITIAL WELL COST (W.C.J
                          (dollars)
                                                      2400
      Figure 8-1.   This  figure  displays the monthly
cost  of wells  and pumping systems.   (Michael  D.
Campbell and Jay  H. Lehr, Rural Water Systems
Planning and Engineering Guide, p.  119.)
                       -234-

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                                           TABLE 8-4
                       ION EXCHANGE AND CLARIFICATION COSTS ASSIGNED TO
                                    SMALL COMMUNITY SYSTEMS
,
POPULATION
SERVED
GROUP
25-99
100-499
500-999
CLARIFICATION
COSTS
($ 1,000)
5,292
19,590
12,013
ION EXCHANGE
COSTS
($ 1,000)
22,878
69,728
33,700
SUM OF CLARIFICATION AND
ION EXCHANGE TOTAL COSTS
($ 1,000)
28,170
89,318
45,713



          TOTAL SMALL
          SYSTEM COST
 36,895
126,306
163,201
          TOTAL NATIONAL
          COST TREATMENT
378,338
619,204
997,542
          PERCENT OF TOTAL
          NATIONAL TREATMENT
          COSTS
   9-7
 20.1
 16.4

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rates is not great since the majority of annual expenditures
go into O&M costs rather than financing charges.  No assumption
is made on the rate of inflation which will occur in the
coming decade.  All costs are based on 1975 dollars with no
factor for inflation.
                          -236-

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                         CHAPTER NINE


              EXAMINATION OF ALTERNATIVES TO THE
          INTERIM PRIMARY DRINKING WATER REGULATION
Q
9. 0  Introduction

     The first eight chapters of this report developed the
costs of implementing the Proposed Interim Primary Drinking
Water Regulations,  while this chapter determines the effect
on costs and manpower which would be caused by altering the
Interim Primary Drinking Water Regulations as published in
the Federal Register on March 14, 1975 (see Appendix J).

     In this chapter three sets of alternatives are examined
The major alternatives are summarized in Table 9-1-  These
alternatives are illustrative of possible changes in the
interim regulations which could reduce the impact of the
regulations.  Table 9-2 Illustrates the changes which would
occur upon Implementation of the alternative sets of regu-
lations .
9.1  Effect of Changing the Definition of "Community" Water
     System

     The factors which determine the overall monitoring costs
caused by implementation of any regulations are the laboratory
costs, the source of water, and the number of community and
non-community systems.  The first two factors, laboratory
costs and source of water, were discussed In Chapter Four.
This section will explore the impact of changing definitions
on the number of community and non-community systems, while
the following sections will delineate the effects on overall
monitoring costs caused by superimposing the definition
changes on the other alternative changes.

     The regulations published in the Federal Register define
a "community water system" as a public water system which
serves a population of which 70 percent or greater of the total
are residents.  Using this definition It has been estimated
that there are 40,000 public water systems which meet this
definition, with 200,000 public water systems which would be
classified as non-community systems.
                            -237-

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            TABLE  9-1
ALTERNATIVE MONITORING OPTIONS
                    REGULATIONS
                                     SKI1 2
                                            SET 3
AI.TEliK'ATIVE
I DEl'IWITION 0? CCraiNITY SYSTEM
A) 15 service conneuU "nt; or 2[j residents
B) 15 set-vice connections or serves
non-transient populations
C) 70 percent residents with 15 connections
and ?5 people served
II PLATE COUNT
A) 10 percent of coliform,
1 per month
B) Deleted
III COLT FORM
A) 2 per month for systems serving
under 1,000 people
B) 1 per month for systems serving
under 1,000 people
IV TURBIDITY
A) Daily sampling for all systems
B) Sampling not required for
groundwater sources
V PESTICIDE SAMPLING
A) Monitor surface sources yearly and
groundwater sources at 3-year intervals
B) Monitor surface sources yearly and
groundwater at State discretion
C) Monitor surface sources within 3-year
Intervals and groundwater sources at
State discretion
VI ORGANIC (CCE) SAMPLING
A) Monitor surface sources yearly and
groundwater sources every 3 years
B) Monitor surface sources yearly and
groundwater sources at State
discretion
C) Deleted
VII SPECIAL MONITORING
A) Monthly monitoring for systems between
75 and 100 percent of MCL
B) No special monitoring between 75 and 100
percent of MCL
C) Weekly sampling for exceeding MCL
D) Three check analyses within 1 month
E) Dally sampling for coliform violations
F) Minimum of 2 samples done at State
discretion
VH! NON-COMMUNITY SYSTEMS
A) Monthly coliform sampling required
B) Semi-annual coliform monitoring
required
C) State discretion for coliform
monitoring
D) Quarterly colifoim monitoring
E) Total organic and inorganic analyses
F) State discretion for complete organic
and inorganic analyses
G) NO analysis only at State discretion
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
            -238-

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                 TABLE 9-2
COSTS OF ALTERNATIVE MONITORING OPTIONS
                           REGULATIONS
                                      SET 1
                                              SET 2
                                                      SET 3
ALTERNATIVE
I DEFINITION OF COMMUNITY SYSTEM (,* of systems)
A) 15 service connections or 25 residents
B) 15 service connections or serves
non-transient populations
C) 70 percent residents with 15 connections
and 25 people served
II PIATE COiOT (cost, $ million)
A) 10 percent of collform,
1 per month
B) Deleted
III COLIFORM (cost, $ million)
A) 2 per month for systems serving.
under 1,000 people
B) 1 per month for systems serving
under 1,000 people
IV TURBIDITY
A) Dally sampling for all systems
B) Sampling not required for
groundwater sources
V PESTICIDE BATTLING (cost. $ million)
A) Monitor surface sources yearly and
groundwater sources at 3-year intervals
B) Monitor surface sources yearly and
groundv.'ater sourer- 3t discretion
C) Monitor surface sources within 3-year
Intervals and proundwater sources at
State discretion
VI ORGANIC (CCE) SAMPLING (cost, $ million)
A) Monitor surface sources yearly and
groundwater sources every 3 years
B) Monitor surface sources yearly and
groundwater sources at State
discretion
C) Deleted
VII SPECIAL MONITORING (cost, $ million)
A) Monthly monitoring for systems between
75 and 100 percent of MCL
B) No special monitoring between 75 and 100
percent of MCL
C) Weekly sampling for exceeding MCL
D) Three check analyses within 1 month
E) Daily sampling for collform violations
F) Minimum of 2 samples done at state
discretion
VIII NON-COMMJNTTY SYSTEMS (ft of systems)
A) 2/month colifonn monitoring
required (cost, $ million)
B) Semi-annual colifonn monitoring required
C) State discretion for colifonn monitoring
D) Quarterly coliform monitoring
E) Total organic and Inorganic analyses
F) State discretion for complete organic
and inorganic analyses
Q) NO, analysis only at State discretion
T) t/rnor.tli plate count
40,000
3.0-5.9
3-3-6.6

2.1-1.1
0.8-1.2
1.1-2.7
0.3-3-0
0.1-0.5
200,000
24-48
9-3-16.7
12-24
80,000
0
3-3-6.6
-
4.4-7.1
1.5-2.1
0
0.3-3-0
0.1-0.5
160,000
1.6-3.2
0
36,248
0
0.5-0.9
-
0.9-1.5
0.3-0.4
0
0.3-3-0
0.1-0.5
203,752
0
0
40,000
0
0.7-1-3

0.3-0.5
0
0
.01-0.3
.05-0.2
200,000
4.0-8.0
1.1-2.7
                 -239-

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     The Set 1 alternative definition would define a "community
water system" as a public water system which has at least 15
service connections or which serves a non-transient population.
The term includes public water systems providing water to
residential communities, schools, factories, office buildings
and other facilities in which the same 25 or more people
regularly consume the drinking water-  The term does not
include public water systems which provide water only to gas
stations, restaurants, or campgrounds, or those which are
carriers which convey passengers in interstate commerce.
The net effect of changing the definition of a community
system would be to increase the number of systems in that
category from 40,000 to about 80,000 with a concomitant
decrease in non-community systems from 200,000 to 160,000.
This estimate is based on the distribution of non-community
systems in New York State (Appendix C).

     In the Set 2 alternatives the definition of a "community
system" was changed to mean a public water system that serves
15 service connections and 25 residents regularly throughout
the year.  Implementation of this new definition would serve
to eliminate those systems which do not meet both the population
served and service connection criteria.  A breakdown of the
present EPA inventory of water systems showed 113 surface,
626 ground, and 117 other water systems out of 313000 which
served 24 or fewer residents.  This means that, projected
nationally, 1,104 systems would not meet the population
served criterion.  A random sample of 136 plants from the EPA
data base was used to determine the number of plants which
serve 25 or more residents but have fewer than 15 service
connections.  Using this random sample, it was determined
that 2,648 systems nationally would not meet this criterion.
The costs developed in the remainder of this section were
derived for those 36,248 systems which would be considered as
"community systems" under the new definition.  This would
increase the number of non-community systems to 203,752.

     The Set 3 definition of community systems was similar to
the published version and would mean that the number of
community systems would remain at 40,000.
9-2  Monitoring

     The national costs of implementation of the different
monitoring options for all three sets are shown in Table 9-2,
while the national cost summaries are shown in Table 9-3.
                            -240-

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                                                  TABLE 9-3


                     TOTAL MONITORING COSTS FOR THREE SETS OF  MONITORING  ALTERNATIVES
I
IV)


A.
B.
C.
D.

A.
B.
C.
D.



COMMUNITY SYSTEMS
Costs of Routine Monitoring
Monitoring Costs for
Chemical Violations
Monitoring Costs Due to
Coliform Violations
Monitoring Costs Between
75 to 100 Percent of MCL
NON-COMMUNITY SYSTEMS
Costs of Routine Monitoring
Monitoring Costs for
Chemical Violations
Monitoring Costs Due to
Coliform Violations
Monitoring Costs Between
75 to 100 Percent of MCL
SUBTOTAL COMMUNITY
SUBTOTAL NON-COMMUNITY
TOTAL
REGULATIONS SET 1 SET 2
($ million) ($ million) ($ million)
22

0
0
.2-42.8 24.9-48.0 16.7-32.1
0 0.1-0.4 0.0-0.3
.2-1.5 0.7-5-3 0.2-1.5
.6-1.4 0 0
REGULATIONS SET 1 SET 2
47
0
0
0
23
48
71
.1-92.0 1.8-3.4 2.1-4.2
.3-2.1 0 0.3-2.1
.5-6.8 0 0
.8-1.9 0 0
.0-46.0 25.7-53.7 16.9-33.9
.7-102.8 1.8-3.4 2.4-6.3
.7-148.4 27.5-57,1 19.3-40.2
SET 3
($ million)
13-3-27
0.0-0.
0.0-0.
0
SET 3
4.5-9-
0.3-0.
0
0
13-3-27
4.8-10
18.1-38
.3
2
3


4
8


.8
.2
.0

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     While all monitoring options considered show substantially
less monitoring costs than do the proposed regulations, the
third set of alternatives results in the lowest overall
costs.

     Table 9-4 shows the per capita effects of the three
sets of alternatives and the proposed regulations.  The
costs are based on the monitoring schedule for the third
year in all cases.  For the surface-water systems, full
inorganic surveys are costed at $78 to $188 for the proposed
regulations and Alternative Sets 1 and 2, and costed at $70 to
$170 for Alternative Set 3-  Organic surveys are costed at
$200 to $312 for the proposed regulations and Alternative
Sets 1 and 2, and at $150 to $250 for Alternative Set 3-

     For groundwater systems the cost of an inorganic survey
is the same as for surface-water systems while the cost of
organic surveys varies from $66.67 to $104 for the proposed
regulations and Alternative Set 1, to 0 for Sets 2 and 3-  In
the case where systems purchase finished water, it is assumed
that no chemical monitoring would be needed since the parent
system would satisfy the monitoring requirements.  For each
type of system, the required number of coliform and plate
count tests are assumed and each test is costed at $5 to $10.
9.3  Effect of Alternative Monitoring Options on Treatment
     Requirements

     The only effect on treatment requirements which would be
caused by the alternative sets of monitoring options would
occur in Set 3, when the CCE monitoring requirement is dropped
Since no system would be required to monitor for this MCL,
the costs for treating organic matter in water would no
longer be incurred.  This would lessen the total capital
treatment costs by $22.5 million and the annual O&M costs by
$4.5 million.
9•4  Manpower Requirements

     Table 9-5 delineates the manpower requirements which
would be expected upon implementation of any of the three
sets of options.  It is estimated that personnel require-
ment would total 26,600 to implement the proposed regula-
tions, with 45,600 for Set 2 and 22,700 for Set 3.  The main
                           -242-

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                                                  TABLE 9-4
            ANNUAL MONITORING COSTS PER PERSON FOR  THREE SETS OF MONITORING  ALTERNATIVES
       SYSTEM
        SIZE
    REGULATIONS
SURFACE     GROUND
    ($ million)
  ALTERNATIVE  1
SURFACE    GROUND
    ($  million)
   ALTERNATIVE 2
SURFACE     GROUND
    ($ million)
   ALTERNATIVE  3
SURFACE     GROUND
   ($  million)
i
rv>
UJ
 I
         25
         100
         250
         1,000
         2,500
18.32-34.40  11.57-21.07
 4.58-8.60    2.73-5-27
 1.83-3.44    1.16-2.11
 0.46-0.86    0.27-0.53
 0.21-0.39    0.13-0.23
15.92-29.60  8.51-16.27
 3.98-7.40   2.13-4.07
 1.59-2.96   0.85-1.63
 0.40-0.74   0.21-0.41
 0.18-0.34   0.11-0.21
15.92-29.60  5.84-12.11
 3.98-7.40   1.46-3.02
 1.59-2.96   0.58-1.21
 0.40-0.74   0.15 0.30
 0.18-0.34   0.08-0.17
  7.20-15.05  3-35-7.05
 2.40-3-75   0.85-1.75
 0.72-1.51   0.33-0.70
 0.24-0.38   0.09-0.17
 0.15-0.32   0.08-0.16

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                 TABLE 9-5
SUMMARY OP MANPOWER REQUIREMENTS TO IMPLEMENT
THREE SETS
OF ALTERNAT
IVE MONITORING OPTIONS


TOTAL
PROPOSED
FUNCTION REGULATIONS
MONITORING
microbiological
chemical
turbidity
PROCESS OPERATION
PROGRAM ASSISTANCE
CLERICAL
PROGRAM
ADMINISTRATION
TOTAL

2,800
785
500
19,400
375
340
2,400
26,600
PERSONNEL
ALT.
SET 1

1,100
400
355
38,800
550
325
4,100
45,630
REQUIRED
ALT.
SET 2

500
100
175
19,400
375
150
2,000
22,700
ALT.
SET 3

700
100
175
19,200
375
175
2,050
22,550
                     -244-

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difference in personnel requirements between these two sets
is the change in definition of "community systems," if the
two definitions were the same as in the proposed regulations,
about 23,500 personnel would be required.  The difference in
personnel requirements between Set 2 and Set 3 is due to
dropping both the CCE monitoring and the process operations
for activated carbon treatment.
9.5  Potential Manpower Saving for Water Quality Monitoring
     From Alterations to Prescribed Methods

     All of the three sets of monitoring alternatives allow
for monitoring procedures.  This section will explore some of
the available monitoring procedures which could be imple-
mented to reduce monitoring manpower requirements.

     Manpower data supplied by Earl McParren of EPA, Cincinnati,
show that the most efficient chemical analyses can be performer!
at a rate of about 600 per man-month (30 per man-day, 7,200
per man-year).  This estimate Includes allowances for instru-
ment adjustments, preparation of standards and calibrations
curves, dishwashing, and  (presumably) paperwork.  Chemical
constituents that can be analyzed at this frequency are those
for which the water sample can be assayed directly without
extensive pretreatment.  Barium, chromium, and silver (for
which direct aspiration into the flame of an atomic absorption
(AA) spectrophotometer is suitable), as well as fluoride and
nitrate (for which simple colorimetric methods are prescribed),
all fall into this category.

     Arsenic, selenium and mercury are analysed at a slower
rate of '400 samples per month.  Sample preparation consists
of chemical reduction to the gaseous species AsHn, SeHp,
and mercury vapor.  The AsHo and SeH2 are vented^to a
conventional AA flame; mercury vapor'is analyzed by flameless
AA.  Direct aspiration procedures exist for these metals,
but they lack the necessary sensitivity for drinking water
quality analyses.  There seems to be little potential for
making more efficient analyses for these elements.

     Cyanide can be analyzed according to the prescribed
method at the rate of 200 samples per month.  Sample
preparation (distillation) Is the time-consuming step, but it
     "'"Personal communication - Earl McFarren, EPA, Cincinatti,
Ohio, June 1975-
                             -245-

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is necessary for separating the cyanide ions from complex-
forming metals.   Again, there seems to be no way to expedite
the analyses.

     The most  time-consuming analyses are for chlorinated
hydrocarbons and herbicides.  Here it is necessary to do a
solvent extraction, followed by evaporation (and for the
herbicides, esterification) before the gas chromatographic
analysis can be performed.  Again, there seem to be no time-
saving alternatives.

     Some time savings can be achieved in the analyses of
lead and cadmium without a loss of accuracy.  The standard
method is preconcentration by chelation and extraction,
followed by aspiration of the extract into a flame AA system.
The need for preconcentration slows the rate of analysis by a
factor of three.  However, if the regulations were to permit
the use of a graphite furnace for atomization, direct injection
of samples would be possible, and the analysis rate would be
600 samples per man-month rather than 200.

     There is  potential for substantial savings in monitoring
for overall organics.  This would, however, require a change
in the basis of the standard, presently set at 0.7 nig/1 of
carbon chloroform extractibles.  CCE is taken as an index of
overall organic contamination.  The CCE process is tedious
and the rate of analysis is about 60 samples per man-month.

     If the organic standard were instead based on "total
organic carbon," the analysis rate would increase to an
estimated 600  samples per man-month, or a tenfold increase in
efficiency.  The potential manpower savings are shown in
Table 9-6.
9•6  Summary of Alternative Monitoring Options

     The first set of alternatives would generally cause
reductions in the number of personnel, chemicals, and other
key items.  However, the change in the definition of community
systems would^temper these potential savings since it would
increase the number of community systems from 40,000 to
80,000.  If the definition of community systems was not
changed, then the required manpower would be cut to approxi-
mately one-fourth the laboratory personnel necessary to
implement the proposed interim regulations.  In this short
                            -246-

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                          TABLE 9-6
      POTENTIAL MANPOWER SAVING BY SUBSTITUTION OF MORE
               EFFICIENT ANALYTICAL TECHNIQUES'
CONTAMINANT
MAN-YEAR EFFORT FOR NATIONWIDE
          MONITORING

Lead-standard
Lead-graphite furnace
Manpower saved
Cadmium- standard
Cadmium- graphite
furnace
Manpower saved
Organics-CCE
Organics-TOC
Manpower saved
First
23-
10.
21.
19-

6.
12.
70.
7-
63.
Year
7
9
8
3

4
9
5
1
4
Second
32.
10.
21.
19-

6.
12.
70.
7.
63-
Year
7
9
8
3

4
9
5
1
4
Third
8.
2.
5-
(
8.

2.
5-
28.
2.
25.
Year
4
8
6
4

8
6
0
8
2
TOTAL MANPOWER SAVED
     . 1
                                            .1
36.4
                        -247-

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analysis it is assumed that the monitoring of public non-
community systems will continue at the present rate,, meaning
that no additional costs would be incurred to monitor these
systems.

     Implementation of Alternative Set 2 or 3 would generally
cause a substantial (75 percent) reduction in monitoring
personnel with smaller reductions in auxiliary services.
These sets-of alternatives would reduce the per capita
monitoring burden on smaller community and non-community
systems.
9.7  Effects of Changing the CCE Level

     This section examines the effect of changing the maximum
contaminant level of CCE organics from the published value of
0.7 mg/1 to either 0.5 or 0.15 mg/1.   Table 9-7 shows that
over 30 times as many plants would have to remove CCE organics
if the maximum level were reduced from 0.7 to 0.15 mg/1.

     If the 0.15 mg/1 alterantive CCE level were adopted,
then an additional 12 percent of the  current production of
activated carbon would be required to remove this contaminant
from the 40,000 drinking water systems (Table 9-8).

     Despite the fact that reserves are extremely abundant
(recoverable coal reserves are estimated at 1,500 billion
tons), it would still take several years to build enough
plants to produce the capacity estimated as necessary for
meeting the 0.15 mg/1 standard.

     It would require a capital investment of $509.2 million to
treat for CCE at the 0.15 mg/1 level, while it would cost
$22.5 million at the 0.7 mg/1 level (Table 9-9).
                            -248-

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                       TABLE 9-7
           EFFECT OF CHANGING MAXIMUM LEVEL OF CCE
FOR COMMUNITY SYSTEMS (mg/1)
CCE MAXIMUM LEVEL IMPACTS
     0.15 level impacts
     0.50 level impacts
     0.70 level impacts
  3,666 plants (77.4%
    471 plants (9.95%
    162 plant  (3.42$
                       TABLE 9-8
          ADDITIONAL PRODUCTION OF CARBON PER ANNUM
              TO REMOVE CCE ORGANIGS FROM WATER
MAXIMUM PERCENT OF
LEVEL CCE TOTAL COMMUNITY 40,000
(mg/1) PLANTS IMPACTED PLANTS
0.15
0.50
0.70
3,666
471
162
9.
1.
0.
2
2
4
INITIAL
TONS CARBON
REQUIRED
46,259
5,946
2,044
PERCENT
CURRENT
PROD.a
54.
7.
2.
3
0
4
ADDED
COST/YR
($ mil. )
36.
4.
1.
2
8
6
   a
    Current Production = 85,000 tons/year (1974).
                       TABLE 9-9
                TREATMENT COSTS FOR CCE
                      ($ million)
MAXIMUM
LEVEL (mg/1)
0.70
0.50
0.15
IMPACTED
PLANTS
162
471
3,666
CAPITAL
INVESTMENT
22.5
65-5
509.2
O&M
4.6
13.4
104.1
                          -249-

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                   APPENDIX A
PROPOSED INTERIM PRIMARY DRINKING WATER STANDARDS

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                PROPOSED




INTERIM PRIMARY DRINKING WATER STANDARDS
            WATER SUPPLY DIVISION




  OFFICE OF WATER AND HAZARDOUS MATERIALS




       ENVIRONMENTAL PROTECTION AGENCY
                    A-l

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               ENVIRONMENTAL PROTECTION AGENCY



                   Subchapter D - Water Programs



                         Part 141,  Subpart A



                  Interim Primary Drinking Water Standards






(Authority:  Sections 1412, 1414, 1415 and 1450 of the Safe Drinking



Water Act,  P.L. 93-523)



Section 141.1.  Applicability.



    This sub-part  sets forth the interim primary drinking water



standards required by Section 1412  of the Safe Drinking Water Act



(P. L. 93-523).






Section 141.2.  Definitions.



    As used in this sub-part:



    (a)  "The term 'Act' means the Safe Drinking Water Act,  Public



Law 93-523.



    (b)  "The term 'maximum contaminant level'  means the maximum



permissible level of a contaminant in water which is delivered to the



free flowing outlet  of the ultimate user of a public water system.



    (c)  "The term 'public water system' means a system for the



provision to the public of piped water for human consumption, if



such system has at least fifteen service connections or regularly






                             A-2

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serves an average of at least twenty-five individuals daily at

least three months out of the year.  Such term includes (1) any

collection, treatment,  storage, and distribution facilities under

control of the operator of such system and used primarily in

connection with such system, and (2) any collection or pretreatment

storage facilities not under such control which are used

primarily in connection with  such system.

    (d)  "The term 'supplier of water' means any person who owns

or operates a public water system.

    (e)  "The term 'contaminant' means any physical, chemical,

biological, or radiological substance or matter in water.

    (f)  "The term 'person' means an individual,  corporation,

company, association, partnership, State, municipality, or

Federal agency.

    (g)  "The term 'State' means the agency of the State government

which has jurisdiction over public water systems.   During any period

when a State does not have primary enforcement responsibility,  the

term 'State' means the Regional Administrator, Environmental

Protection Agency.

    (h) "the term 'community water system' means a public water

system which serves a population of which 70% or greater are

residents.
                             A-3

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Section 141.3  Coverage



    The interim primary drinking water standards under this



sub-part shall apply to each public water system in a state;



except that such standards shall not apply to a public water



system -



    (a) which consists only of distribution and storage facilities



(and does not have any collection and treatment facilities);



    (b) which obtains all of its water from,  but is not owned or



operated by, a public water system to which such regulations



apply;



   (c)  which does not sell water to any person; and



    (d) which is not a carrier which conveys passengers in



interstate commerce.
                            A-4

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Sec.  141.11   Maximum Contaminant Levels for Inorganic




Chemicals.






   (a) The following are the maximum contaminant levels for




inorganic chemicals:




            Contaminant                          Level (mg/1)




            Arsenic                               0.05




            Barium                               1.




            Cadmium                             0.010




            Chromium                             0.05




            Cyanide                               0.2




            Lead                                 0.05




            Mercury                              0.002




            Nitrate (as N)                         10.




            Selenium                             0.01




            Silver                                0.05






   (b) When the annual average of the maximum daily air




temperatures for  the location in which the public water




system is situated is the following, the corresponding




concentration of fluoride shall not be exceeded:
                            A-5

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    Temperature (in degrees F)    (degrees C)     Level (mg/1)



       50.0 - 53.7                10.0-12.0          2.4



       53.8 - 58.3                12.1-14.6          2.2



       58.4-63.8                14.7-17.6          2.0



       63.9-70.6                17.7-21.4          1.8



       70.7 - 79.2                21.5-26.2          1.6



       79.3 - 90.5                26.3-32.5          1.4



   The requirements of this paragraph (b) do not apply to



public water supplies serving only educational institutions.






Sec.  141.12  Maximum Contaminant Levels for Organic Chemicals



       The maximum contaminant level for the total concentration



of organic chemicals,  as determined by the carbon chloroform



extract method set forth in sec. 141.24(b), is 0.7 mg/1.
                             A-6

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Sec. 141.13 Maximum Contaminant Levels for Pesticides

    The following are the maximum contaminant levels for

pesticides:

    (a) Chlorinated Hydrocarbons               Level mg/1

       Chlordane  (cis and trans)                   0.003
       (1, 2,4,5, 6, 7, 8, 8-Octachloro-
       3a, 4, 5, 7a-tetrahydro-
       4, 7-methanoindan)

       Endrin                                   0.0002
       (1, 2, 3, 4,10,10-Hexachloro-
       6,7-epoxy-l,4,4a,5,6,7,8,8a-
       octahydro-1, 4-endo, endo-
       5, 8-dimethano naphthalene)

       Heptachlor                               0.0001
       (1, 4,5,6, 7, 8, 8-Heptachloro-
       3a, 4, 7, 7a-tetrahydro
       4, 7-methanoindene)

       Heptachlor Epoxide                        0.0001
       (1, 4, 5, 6, 7, 8, 8, -Heptachloro-
       2, 3-epoxy-3a, 4, 7, 7a-tetrahydro-
       4, 7-methanoindan)

       Lindane                                  0.004
       (1, 2, 3, 4, 5, 6-Hexachloro-
       cyclohexane,  gamma isomer)

       Methoxychlor                             0.1
       (1,1, l-Trichloro-2, 2-bis
       [p-methoxyphenyl] ethane)

       Toxaphene                                0.005
       (C10H,0Cla  - Technical chlorinated
       camphene, 67-69% chlorine)
                            A-7

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(b) Chlorophenoxys

   2,4-D                                     0.1
   (2, 4-Dichlorophenoxyacetic acid)

   2,4,5-TP Silvex                            0.01
   (2, 4, 5-Trichlorophenoxypropionic
   acid)
                         A-8

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Sec. 141.14  Maximum Contaminant Level of Turbidity.



    The maximum contaminant level of turbidity in the drinking




water at a representative entry point(s) to the distribution



system is one turbidity unit (TU), as determined pursuant



to sec. 141.22 of this subpart,  except that no greater than



five turbidity units may be allowed if the supplier of water



can demonstrate to the State that the higher turbidity does



not:



    (a)  interfere with disinfection;



    (b)  prevent maintenance of an effective disinfectant agent




throughout the distribution system;  and



    (c)  interfere with microbiological determinations.
                              A-9

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Section 141.15 Maximum Microbiological Contaminant Levels




   (a) The supplier of water may employ one of two methods to




determine compliance with the coliform maximum contaminant levels,




   (1) When the supplier of water employs the membrane filter




technique  pursuant to sec.  141.21 (a) the  coliform densities




shall not exceed one per 100 milliliters as the arithmetic mean of all




samples examined per month; and either



   (A) four per 100 milliliters in more than one standard




sample when less than 20  are examined per month; or




   (B) four per 100 milliliters in more than five percent of the




standard samples when 20 or more are examined per month.




   (2)(A)  When the supplier of water employs the fermentation tube




method and 10 milliliter standard portions pursuant to sec. 141.21,




coliforms  shall not be present in more than 10 percent of the portions




in any month; and either;




   (i) three or more portions in one sample when less




than 20 samples are examined per month;  or




   (ii) three or more portions in more than five percent




of the samples if 20 or more samples are  examined per  month.




       (B) When the supplier of water employs the fermentation tube




method and 100 milliliter  standard portions pursuant to sec. 141.21 (a)




coliforms  shall not be present in more than 60 percent of the portions




                            A-10

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in any month; and either;




   (i) five or more portions in more than one sample when



less than five samples are examined; or



   (ii) five or more portions in more than 20 percent of the



samples when five samples or more are examined.



   (b) The supplier of water shall provide water in which there



shall be no greater than 500 organisms per one milliliter  as



determined by the standard bacterial plate count provided



in sec. 141.21 (f) of  this subpart.
                             A-ll

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Section 141.16  Substitution of Residual Chlorine Measurement for



Total Coliform Measurement.



    (a) The supplier of water may, with the approval of the State,



substitute the use of chlorine residual monitoring for not more



than 75% of the samples required to be taken by sec.  141.21 (b),



provided that the supplier of water takes chlorine residual samples



at points which are representative of the conditions within the distri-



bution system at the frequency of at least four for each substituted



microbiological sample.  There shall be at least daily determinations



of chlorine residual.  Measurements shall be made in accordance



with Standard Methods, 13th Ed., pp 129-132.  When the supplier



of water  exercises the option provided in this paragraph (a),



he shall maintain no less than 0.2 mg/1 free chlorine in the



public water distribution  system.



    (b) For public  water  systems serving 4900 or fewer persons,



the supplier may, with the  approval of the State, make a total



substitution of chlorine residual measurement for the samples required



to be taken by sec. 141.21  (b) provided that the supplier of water takes



chlorine  residual samples at points which are  representative of the



conditions within the distribution system at the rate of one per day



for each  microbiological  sample required to be taken per month
                             A-12

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under sec. 141.21. When the supplier of water exercises the



option provided by this paragraph (b) he shall maintain no less



than 0.3 mg/1 free chlorine in the public water distribution



system. Measurements shall be made in accordance with



Standard Methods, 13th Ed., pp 129-132.
                             A-13

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Section 141.21  Microbiological Contaminant Sampling and

Analytical Requirements

    a. The supplier of water shall make coliform density

measurements, for the purpose of determining compliance with

sec. 141.15, in accordance with the analytical recommendations

set forth in Standard Methods for the Examination of Water and

Wastewater, American Public Health Association, 13th Edition,

pp 662-688,  except that only a 100 milliliter sample size shall

be employed in the membrane filter technique. The samples

shall be taken at points which are representative  of the con-

ditions within the distribution system.

    b. The supplier of water shall take coliform density  samples

at regular intervals throughout the month, and in number

proportionate to the population served by the public water system.

In no event shall the frequency be less than as set forth below:

                                           Minimum Number of
    Population Served                       Samples Per Month

         25  - 2,500                               2

      2,501-  3,300                               3

      3,301-  4,100                               4

      4,101-  4,900                               5

      4,901-  5,800                               6
                            A-14

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                                     Minimum Number of
Population Served                     Samples Per Month

  5,801 -  6,700                              7

  6,701-  7,600                              8

  7,601 -   8,500                             9

  8,501-   9,400                             10

  9,401 -  10,300                             11

 10,301 -  11,100                             12

 11,101 -  12,000                             13

 12,001 -  12,900                             14

 12,901 -  13,700                             15

 13,701 -  14,600                             16

 14,601 -  15,500                             17

 15,501 -  16,300                             18

 16,301 -  17,200                             19

 17,201 -  18,100                             20

 18,101 -  18,900                             21

 18,901 -  19,800                             22

 19,801 -  20,700                             23

 20,701 -  21,500                             24

 21,501 -  22,300                             25

 22,301 -  23,200                             26
                        A-15

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                                     Minimum Number of
Population Served                      Samples Per Month

 23,201 -  24,000                             27

 24,001 -  24,900                             28

 24,901 -  25,000                             29

 25,001 -   28,000                            30

 28,001-   33,000                            35

 33,001 -   37,000                            40

 37,001-   41,000                            45

 41,001 -   46,000                            50

 46,001 -   50,000                            55

 50,001-   54,000                            60

 54,001 -   59,000                            65

 59,001 -   64,000                            70

 64,001-   70,000                            75

 70,001-   76,000                            80

 76,001 -   83,000                            85

 83,001 -   90,000                            90

 90,001-   96,000                            95

 96,001 -  111,000                            100

111,001 -  130,000                            110

130,001 -  160,000                            120
                        A-16

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                                       Minimum Number of
 Population Served                       Samples Per Month

 160,001 - 190,000                             130

 190,001 - 220,000                             140

 220,001 - 250,000                             150

 250,001 - 290,000                             160

 290,001 - 320,000                             170

 320,001 - 360,000                             180

 360,001 - 410,000                             190

 410,001 - 450,000                             200

 450,001 - 500,000                             210

  500,001 - 550,000                             220

  550,001 - 600,000                             230

  600,001 - 660,000                             240

  660,001 - 720,000                             250

  720,001 - 780,000                             260

  780,001 - 840,000                             270

  840,001 - 910,000                             280

  910,001 - 970,000                             290

  970,001 - 1,050,000                           300

1,050,001 - 1,140,000                           310

1,140,001 - 1,230,000                           320
                          A-l?

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                                         Minimum Number of
    Population Served                      Samples Per Month

 1,230,001 - 1,320,000                             330

 1,320,001 - 1,420,000                             340

 1,420,001 - 1,520,000                             350

 1,520,001 - 1,630,000                             360

 1,630,001 - 1,730,000                             370

 1,730,001 - 1,850,000                            380

 1,850,001 - 1,970,000                            390

 1,970,001 - 2,060,000                            400

 2,060,001 - 2,270,000                            410

 2,270,001 - 2,510,000                            420

 2,510,001 - 2,750,000                            430

 2,750,001 - 3,020,000                            440

 3,020,001 - 3,320,000                            450

 3,320,001- 3,620,000                            460

 3,620,001 - 3,960,000                            470

 3,960,001 - 4,310,000                            480

 4,310,001 - 4,690,000                            490

          ^ 4,690,001                            500

   (c) (1)  When the coliform colonies in a single standard sample

exceed four per 100 milliliters (sec. 141.15  (a) (1) ),  daily


                           A-18

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samples shall be collected and examined from the same sampling




point until the results obtained from at least two consecutive



samples show less than one coliform per 100 milliliters.



    (2) When organisms of the coliform group occur in three



or more 10 ml portions of a single standard sample (sec. 141.15



(a)  (2)), daily samples shall be collected and examined from



the same sampling point until the results obtained from at



least two consecutive samples show no positive tubes.



    (3) When organisms of the coliform group occur in all five



of the 100 ml portions of a single standard sample (Sec.  141.15 (3)),



daily samples shall be collected and examined from the same



sampling point until the results obtained from at least two con-



secutive samples show no positive  tubes.



    (4) The location at which the check sample was taken pursuant



to subparagraphs (1), (2) or (3) must not be eliminated from



future  sampling because of a history of questionable water quality.



Check samples shall not be included in calculating the total



number of samples taken each month to determine compliance




with sec.  141.15.



    (d) When a particular sampling point has been confirmed,
                             A-19

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by the first check sample examined as directed in paragraph



(c)(l),  (2) or (3),  to be in non-compliance with the maximum



contaminant levels set forth in section 141.15, the supplier



of water shall notify the State as prescribed in sec. 141.31.



    (e)  When the maximum contaminant levels set forth in



subparagraphs (1) or (2) of Section 141.15 (a) are exceeded



as confirmed by check samples taken pursuant to paragraph



(c) (1),  (2) or (3), the supplier of water  shall report as



directed in Sec. 141.32 (a).



    (f) When a particular sampling point has been shown to



be in non-compliance with the requirements of sec. 141.16,



water from that location shall be  retested within one hour.



If the non-compliance is confirmed,  the State shall be notified



as prescribed in sec. 141.31. Also, if  the non-compliance



is confirmed, a sample for coliform analysis must be im-



mediately collected from that sampling point and the results of



such analysis reported to the State.



    (g)  Standard bacteria plate count samples shall be analyzed



in accordance with the recommendation  set forth in Standard



Methods for the Examination of Water and Wastewater,  American



Public Health Association,  13th Edition, pp 660-662.  Samples
                            A-20

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taken for the purpose of plate count analysis shall be collected



at points which are representative of conditions within the



distribution system at a frequency at least equal to 10% of



the frequency for coliform analysis as directed in paragraph



(b), with the exception that at least one sample shall be collected



and analyzed monthly.
                             A-21

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Sec. 141.22 Turbidity Sampling and Analytical Requirements




    (a) Samples shall be taken at a representative entry point (s)




to the water distribution system at least once per day,  (at least




once per month for supplies using water obtained from underground




sources) for the purpose of making turbidity measurements to




determine compliance with Sec. 141.14. The measurement




shall be made in accordance with the recommendations set




forth in Standard Methods for  the Examination of Water and




Waste water, American Public Health Association, 13th Edition,




pp. 350-353 (Nephelometric Method).




    (b) In  the event that such measurement indicates that the




maximum  allowable limit has been exceeded, the  sampling and




measurement shall be repeated within one hour.  The results of




the  two measurements shall be averaged, and if the average




confirms that the maximum allowable limit has been exceeded,




this average shall be  reported as directed in Sec. 141.31. If




the  monthly average of all samples exceeds the maximum allow-




able limit, this fact shall be reported as directed in sec. 141.32(a).




(c)  The requirements of this  sec. 141.22 shall not apply to




public water systems other than community water systems




which use  water obtained from underground sources.





                             A-22

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Sec. 141.23 Inorganic Chemical Sampling and Analytical



Requirements




   (a)(l)  To establish an initial  record of water quality, an



analysis of substances for the purpose of determining com-




pliance with sec. 141.11 shall be completed for all community



water systems utilizing surface  water sources within one



year following the effective date of this sub-part. This



analysis shall be repeated at yearly intervals.



    (2) An analysis for community water systems utilizing



ground water sources shall be completed within two years



following the effective  date of this sub-part. This analysis



shall be repeated at three-year intervals.



    (3) Analyses for public water systems other than community



water systems,  whether supplied by surface or ground water



sources, shall be completed within  six years following the



effective date of this sub-part.  These analyses shall be repeated




at five-year intervals.



    (b) If the supplier  of water determines or has been informed



by the State that the level of any contaminant is 75% or more




of the maximum contaminant level,  he shall analyze  for the



presence and quantity of that contaminant  at least once per





                             A-23

-------
month following the initial analysis or information. If,  after



conducting monthly testing for a period of at least one year,



the supplier of water demonstrates to the  satisfaction of the



State that the level of such contaminant is stable and due to a



natural condition of the water source, he may reduce the



frequency of analysis for that contaminant consistent with the



requirements of paragraph (a) of this section.



    (c) If the supplier of water determines or has been informed



by the State that the level of any contaminant  listed in sec.



141.11 exceeds the maximum contaminant level for the substance,



he shall confirm such determination  or information by repeating



the analysis within 24 hours following the initial analysis



or information, and then at least at weekly intervals during



the period of time the maximum contaminant  level for that



substance has been exceeded,  or until a monitoring schedule as



a condition to a variance, exemption or enforcement action



shall become effective.  The results of such repetitive



testing shall be averaged and reported as prescribed in



paragraph (d).




    (d) To judge the  compliance of a public water system with



the maximum contaminant levels listed in sec. 141.11,  averages
                              A-24

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of data shall be used and shall be rounded to the same number




of significant figures as the maximum contaminant level for the




substance in question.  Each average shall be calculated on a



past 12-month moving average basis if less than twelve samples



per year are  analyzed, and on a past three month moving average



basis if twelve or more samples per year are analyzed.  In cases



where the maximum contaminant level has been exceeded in any



one sample, the  average concentration shall be calculated on  a



one-month moving average basis and reported pursuant to



sec. 141.31. If  the mean  of the samples comprising the one



month moving average exceeds the maximum contaminant level,



the supplier of water shall give public notice  pursuant to sec.




141.32(a).



    (e)  The provisions of paragraphs (c) and  (d) notwithstanding,



compliance with  the maximum contaminant level for nitrate



shall be determined on the basis of individual analyses rather



than by  averages.  When a level exceeding the maximum con-




taminant level for nitrate is found, the analyses shall be



repeated within 24 hours,  and if the mean of the two analyses



exceeds the maximum contaminant level,  the supplier of water
                           A-25

-------
shall report his findings pursuant to sections 141.31 and




141.32 (a).




   (f)  Analyses conducted to determine compliance with sec.




141.11 shall be made in accordance with the following methods:




   (1) Arsenic - Atomic  Absorption Method, Methods for Chemical




Analysis of Water and Wastes,  pp.  95-95, Environmental Protection




Agency, Office of Technology Transfer, Washington, D.C.  20460,




1974.




   (2) Barium - Atomic Absorption Method, Standard Methods




for the Examination of Water and Wastewater, 13th Edition,




pp 210-215, or Methods for Chemical Analysis of Water and




Wastes, pp 97-98,  Environmental Protection Agency,  Office of




Technology Transfer, Washington,  D.C. 20460,  1974.




   (3) Cadmium - Atomic Absorption Method, Standard Methods




for the Examination of Water and Wastewater, 13th Edition,




pp.210-215, or Methods for Chemical Analysis of Water and




Wastes, pp 101-103, Environmental Protection Agency,  Office




of Technology  Transfer, Washington, D.C. 20460,  1974.




   (4) Chromium  - Atomic Absorption Method,  Standard Methods




for the Examination of Water and Wastewater, 13th Edition,
                            A-26

-------
pp 210-215, or Methods for Chemical Analysis of Water and




Wastes, pp 105-106,  Environmental Protection Agency, Office




of Technology Transfer, Washington, D.C.  20460, 1974.




    (5) Cyanide-Titration or Colorirnetric Methods,  Methods




for Chemical Analysis of Water and Wastes, pp 40-48,




Environmental Protection Agency,  Office of Technology Transfer,




Washington, D.C.  20460, 1974.




    (6) Lead-Atomic Absorption Method,  Standards Methods for




the Examination of Water and Wastewater, 13th Edition,




pp 210-215,  or Methods for Chemical Analysis of Water and




Wastes, pp 112-113,  Environmental Protection Agency, Office




of Technology Transfer, Washington, D.C.  20460, 1974.




    (7) Mercury-Flameless Atomic Absorption Method, Methods




for Chemical Analysis of Water and Wastes, pp 118-126,




Environmental Protection Agency,  Office of Technology Transfer




Washington, D.C.  20460, 1974.




    (8) Nitrate - Brucine Colormetric Method, Standard Methods




for the Examination of Water  and Wastewater,  13th Edition,




pp 461-464,  or Cadmium Reduction Method, Methods for Chemical




Analysis of Water and Wastes, pp 201-206,  Environmental
                            A-27

-------
Protection Agency, Office of Technology Transfer,  Washington,




D.C. 20460, 1974.




    (9)  Selenium - Atomic Absorption Method, Methods for Chemical




Analysis of Water and Wastes, p.  145, Environmental Protection




Agency, Office of Technology Transfer, Washington,  D.C.




20460,  1974.



    (10) Silver - Atomic Absorption Method, Standard Methods for




the Examination of Water and Wastewater, 13th Edition,




pp 210-215,  or Methods for Chemical Analysis of Water and




Wastes, p 146, Environmental Protection Agency, Office of




Technology Transfer, Washington, D.C. 20460,  1974.




    (11) Fluoride - Electrode Method, Standard Methods for the




Examination of Water and Wastewater, 13th Edition, pp 172-174,




or Methods for Chemical Analysis of Water and Wastes, pp 65-67;




Environmental Protection Agency, Office of Technology Transfer,




Washington, D.C., 20460, 1974, or Colorimetric Method  with




Preliminary Distillation, Standard Methods for the  Examination




of Water and Wastewater, 13th Edition, pp 171-172 and 174-176,




or Methods for Chemical Analysis of Water and Wastes,




pp 59-60,  Environmental Protection Agency, Office of Technology




Transfer,  Washington, D.C. 20460, 1974.






                            A-28

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Sec. 141.24  Pesticide and Organic Chemicals Sampling



and Analytical Requirements



    (a) (1)  To establish an initial record of water quality, an



analysis of substances for the purpose of determining com-



pliance with sections 141.12 and 141.13 shall be completed



for all community water systems utilizing surface water



sources within one year following the effective date of this



sub-part.  This  analysis shall be repeated at yearly intervals.



    (2)  An analysis for community water systems utilizing



ground water sources shall be completed within two years



following the effective  date of this sub-part.  This analysis



shall be repeated at three-year intervals.



    (3)  Analyses for public water systems other than community



water systems,  whether supplied by surface or ground water



sources, shall be completed within six years following the



effective date of this sub-part.  These analyses shall be repeated




at five-year intervals.



    (b)  If the supplier of water determines or has been informed



by the State that the level of any contaminant is 75% or more



or the maximum contaminant level,  he shall analyze for the



presence and quantity of that contaminant at least once per
                            A-29

-------
month following the initial analysis or information.  If, after



conducting monthly testing for a period of at least one



year, the supplier of water demonstrates to the satisfaction



of the State that the level of  such contaminant is stable and due



to a natural condition of the  water  source, he may reduce the



frequency of analysis for that contaminant consistent with



the requirements of paragraph (a)  of this section.



   (c) If the supplier of water determines or has been informed



by the State that the level of contaminants set forth in sec. 141.12



exceeds the maximum contaminant level, he shall confirm such



determination or information be repeating the analyses within



two weeks following the initial analysis or information. The



average of the two analyses, if in excess of the maximum



contaminant level,  shall be reported as directed in sec. 141.31



and 141.32 (a).



   (d) If the supplier of water determines or has been informed



by the State that the level of any contaminant listed in sec. 141.13



exceeds the maximum contaminant level for the substance, he



shall confirm such determination or information by repeating the



analysis  within 24 hours following the initial analysis or infor-



mation, and then at least at weekly intervals during the period
                              A-30

-------
of time the maximum contaminant level for that substance has




been exceeded,  or until a monitoring schedule as a condition to



variance,  exemption or enforcement action shall become



effective.   The  results of such repetitive testing shall be



averaged and reported as prescribed in paragraph (e).



    (e) To judge the compliance of a public water system with the



maximum contaminant levels listed in section 141.13, averages



of data shall be used and shall be rounded to the same number



of significant figures as the maximum contaminant level for



the  substance in question.  Each average shall be calculated



on a past 12-month moving average basis if less than twelve



samples per year are  analyzed, and on a past three month



moving average basis  if twelve or more samples per year are



analyzed.   In cases where the maximum contaminant levels of



sec. 141.13 have been exceeded in any one sample, the average



concentration shall be calculated on  a one-month moving average




basis and  reported pursuant to sec .  141.31.  If the mean of



the  samples comprising the one month moving average exceeds



the  maximum contaminant level, the supplier of water shall give



public notice pursuant to sec. 141.32 (a).



    (f)  Sampling and analyses made  to determine compliance






                            A-31

-------
with sec. 141.12 shall be made in accordance with An Improved



Method for Determining Organics  in Water by Activated Carbon



Absorption and Solvent Extraction, Parts 1 and 2,  Buelow, et.



al.,  Journal of American Water Works Association, 65: 57, 197



(1973).



    (g) Analyses made to determine compliance with sec.



141.13(a) shall be made in accordance with Method for



Organochlorine Pesticides in Industrial Effluents,  MDQARL,



Environmental Protection Agency, Cincinnati, Ohio



Nov. 28, 1973.



    (h) Analyses made to determine compliance with sec.



141.13(b) shall be conducted in accordance with Methods for



Chlorinated Phenoxy Acid Herbicides in Industrial Effluents,



MDQARL, Cincinnati, Ohio, Nov 23, 1973.
                            A-32

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Sec. 141.27 Laboratory Certification



    For the purposes of determining compliance with sees.



141.21 through 141.24,  samples may be considered only if



they have been analyzed by a laboratory approved by the State,



The approval shall be contingent upon maintenance of proper



laboratory methods and technical competence and upon the



retention for inspection at reasonable times of analytical



results. Approved laboratories shall make periodic reports



as required by the State.
                             A-33

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Sec. 141.31 Reporting Requirements



    The supplier of water shall report within 40 days



following a test, measurement or analysis required to be



made by this subpart, the results of that test,  measurement or



analysis, provided that the  supplier of water shall report



within 36 hours the failure to meet any standards  (including



failure to comply with monitoring requirements) set forth



in this subpart.  Reports required to be made by this section



141.31 shall be communicated to the State,  except that Federal



Agencies shall report to the Regional Administrator.

-------
Sec. 141.32  Public Notification of Variances, Exemptions




and Noncompliance with Standards



    (a) The supplier of water shall give notice to the persons



served by the public  water system of any failure on the part of



the system to comply with the requirements (including monitoring



requirements) of this subpart.  The supplier of water shall



give the notice required by this section 141.32 not less than



once every three months during the life of the noncompliance:



    (1) by publication on not less than  three consecutive days



in a newspaper or  newspapers of general circulation serving



the area served by such public water system, which newspaper



or newspapers  shall be approved by the State.  With respect



to the public water systems operated by Federal Agencies,



the newspapers  cited in this paragraph shall be approved by




the Regional Administrator;



    (2) by furnishing a copy thereof to the radio and television



stations  serving such area as soon as practicable but not later



than 36 hours after confirmation of the noncompliance with



respect to which the notice is required; and



    (3) by inclusion  with the water bills of the public water



system at least  once every three months if the  water bills are



issued at least once  every three months, and with every water




                               A-35

-------
bill if they are issued less often.  If water bills are not



issued, other means of notification acceptable to the



State may be used.



    The notice required by this sec. 141.32 shall state at least



that the public water system fails to monitor, operate the system



or provide water which meets all the requirements of this



Part 141, Subpart A,  and shall state with particularity those



requirements for which there  is noncompliance.  If  a quanti-



tive limitation has been exceeded, the notice shall state what



the federal or State limitation is,  and at what level of perfor-



mance the water supply system has been operating.



    (b)  The supplier of water  shall give notice pursuant to the



procedures set forth in paragraph (a) -



    (1)  when his system has received a variance under sec.



1415 (a) (1) or 1415 (a) (2) of the Act,  and shall continue the



notification process at no less than three month intervals



during the life of the variance;



    (2)  when his system has received an exemption  under



sec. 1416 and shall continue the notification process at no less



than three month intervals during the life of the exemption; or



    (3)  when his system has failed to comply with any schedule
                              A-36

-------
or control measure prescribed pursuant to a variance or



exemption and shall continue the notification process at no




less than the three month intervals during the life of the



variance and exemption.
                              A-37

-------
Section 141.41 Siting Requirements




    Before a person may enter into a financial commitment for or




initiate construction of a new public water system or increase




the capacity of an existing public water system,  he shall -




    (a) to the  extent practicable, avoid locating part or all of




the new or expanded facility at a site which:




    (1) is subject to earthquakes, floods,  fires or other man-made




disasters which could cause breakdown of the public water system



or a portion thereof; and




    (2) is within the flooclplain of a 100 year flood;




    (b) Notify the State.
                                 A-38

-------
Section 141.51  Effective Date



   The standards set forth in this subpart A of Part 141




shall take effect 18 months after the date of promulgation
                              A-39

-------
                              APPENDIX B
                QUESTIONNAIRE TO STATE AGENCIES WITH
           RESPONSIBILITY FOR DRINKING WATER STANDARDS
Name and Address of Agency:
                                   Person(s) Filling Out Questionnaire
1.   LABORATORY CERTIFICATION
    a.  Does the state have a program for certification of analytical
       laboratories which monitor the inorganic quality of drinking
       water?
       1)  Local water system in-house labs?            YES	 NO	
       2)  Private commercial labs?                     YES	 NO	
       3)  Municipal labs not operated by water depts?  YES	 NO	
       4)  State labs?                                  YES	 NO	
       How many certified labs are there in each category?
       In-house	 Private	 Municipal	 State	
       Could you please attach a list of such laboratories?
    b.  Does the state have a program for certification of analytical
       laboratories to monitor the organic and pesticide quality of
       drinking water?
       1)  Local water system in-house labs?            YES	 NO	
       2)  Private commercial labs?                     YES	 NO	
       3)  Municipal labs not operated by water depts?  YES	 NO	
       4)  State labs?                                  YES	 NO	

                                  B-l

-------
        How many  certified  labs  are  there  in each category?

        In-House         Private   	   Municipal	 State
        Could  you  please  attach  a  list  of such laboratories?

        Does the  state  have  a  program for certification of analytical

        laboratories  to monitor  the  bacteriological quality of drinking

        water?

        1)  Local  water system in-house labs?             YES_	. NO	

        2)  Private commercial labs?                      YES	 NO	

        3)  Municipal labs not operated by water depts?  YES	 NO	

        4)  State  labs?                                  YES_	 NO	

        How many  certified labs  are  there in each category?

        In-House        Private	Municipal	 State	

        Could  you  please  attach  a  list  of such laboratories?

        Does the  state  certify individual water system to monitor

        turbidity  (yes/no) and residual chlorine (yes/no)?  How many?

                   Turbidity	  Residual Chlorine	
2.   MONITORING

    a.   Who performs  water  qual-ity  analyses?
        (Answer  with  percents  of  total  task work.)
                                     TYPE  OP  LABORATORY
d.
Private
In-House Commercial Municipal State 'TOTAL
Sample Collection
Inorganic Analyses
Organic Analyses
Pesticide Analyses
Coliform Analyses
Plate Count Analyses
Turbidity Analyses
Residual Chlorine
Radiological Analyses




































100
100
100
100
100
100
100
100
100
                                    B-2

-------
b.  Must performing labs be certified?
                                                     YES
NO
d.
    Please supply data on the numbers of different types of
    drinking water systems within the state:
    1)  Number of systems drawing on surface water sourcesa and
        serving communitites
    2)  Number of systems drawing only on ground water sources0
                               ,b
        and serving communities
    3)  Number of systems drawing on surface water sourcesa and
                               d
        serving only transients
    4)   Number  of systems  drawing only on  ground  water  sources0
        and  serving only transients	.
    5)   Number  of systems  drawing only on  suppliers  of  finished
        water	.
    Does the state have  standards for the  frequency  of
    monitoring  for:    (If  no requirement,  answer  "No")
                  Community Systems
           Surface Water     Ground Water
                                                 Transient
                                                  Systems
Inorganics
Organics
Pesticides
Coliform
Plate Count
Turbidity

Every Years
Every Years
Every Years
Samples
i<
ti

Every Years
Every Years
Every Years
Samples
ii
11

Every Years
Every Years
Every Years
Samples
7*1 o T* mn
ii
it

b
d
 May be  supplemented  by  ground  and  finished  waters
 25 or more  permanent residents.
•>
'May be  supplemented  by  finished  waters.

 Average  of  25  or more in  any three month  period.
                              B-3

-------
    e.   Please  supply  data  on  the  work load of state laboratories
        performing  water  quality  analyses:
    Contaminant
How Many Samples Are  How Many Samples Could
 Presently Analyzed   Be Analyzed with Present
     Each Year?       Facilities and Manpower?
    Inorganics
    Organics
    Pesticides
    Coliform
    Plate  Count
    Turbidity
    Radiological
    f.   Who pays for monitoring costs?  (Answer with percentage
        of total costs)
        1)  Local Water  Systems? 	
        2)  Municipal Agency?    	
        3)  State Agency?        	
    g.   If state laboratory does drinking water quality analyses, can
        you supply us with cost data for these analyses? (Annual Basis)
        1)  Direct Labor            	
        2)  Supplies and Equipment	
        3)  Overhead	
        4)  Total Cost	__
        5)  Number of Personnel	_
            (full time equivalent)

3.   ENFORCEMENT
    a.   Does the state enforce any standards for maximum contaminant
        levels in drinking; water?                       YES     NO
                                 B-4

-------
b.   If YES,  do these standards conform to the 1962 PHS Drinking



    Water Standards?                               YES     NO
c.   If enforced standards are substantially different from the



    1962 PHS Standards, please describe the state standards:
d.  How many inspectors does the state employ in its enforcement



    programs? 	



e.  What actions, If any, are taken against systems which violate



    standards?
f.  Please name the state agencies, if any, responsible for



    1)  Enforcement of standards              	
    2)  Recorder of violations
                              B-5

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4.   SAFE DRINKING WATER ACT

    The latest draft of the Proposed Interim Primary Standards calls

    for the following frequencies of monitoring
                                    TYPE OF SYSTEM
                      Community
                                   Transient
Inorganics,
Organics and
Pesticides
Turbidity
Annually
Daily
Every 3 Years
Monthly
Every 6 Years
Daily
Every 6 Years
None
Coliform
2 to 500 Samples Per Month
Based on Number of
Customers Served*
Plate Count
1 to 500 Samples Per Month
Based on Number of
Customers Served
     *1962 PHS, Recommended Sampling Frequencies.


    a.   Do you anticipate any difficulties with this level of

        monitoring in terms of the availability of analytical

        facilities?  (If so, please describe)
    b.  Do you anticipate any diffficulties in funding this level of

        monitoring?  (If so, please describe)                  	
5.  Does the state issue permits for construction of water supply

    systems?                                           YES     NO
                                B-6

-------
6.  Does the state issue permits for construction of additional



   facilities at existing water supply  systems?        YES	 NO
7,  Does your state plan to encourage the use  of residual  chlorine



   monitoring to replace and/or  supplement  coliform density



   measurements?                                       YES	 N0_



8.  Please add any additional  comments.
                                 B-7

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                               TABLE  B-l
   PERCENT OF INORGANIC ANALYSES  DONE BY  FOUR AGENCIES  BY STATE
                      IN-HOUSE
               PRIVATE
             COMMERCIAL
                           MUNICIPAL
           STATE
ALABAMA
ALASKA
   20
                                20
             20
ARIZONA
                                               100
ARKANSAS
CALIFORNIA
    N
                N
 N
 N
COLORADO
   20
               20
             60
CONNECTICUT
    N
                N
 N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
    N
                N
 N
 N
GEORGIA
                                                 0
                                                To"
HAWAII
60
IDAHO
                                               JJQIL
ILLINOIS
INDIANA
   75
                                            .21
IOWA
    N
                N
JL
KANSAS
                                               100
KENTUCKY
   10
LOUISIANA
MAINE
   10
                N
 N
90
MARYLAND
MASSACHUSETTS
MICHIGAN
                                               100
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
    N
                N
 N
 N
NEBRASKA
NEVADA
                                               100
NEW HAMPSHIRE
NEW JERSEY
                   N
                                 N
NEW MEXICO
                  10
                                             90
NEW YORK
NORTH CAROLINA
    N
                N
 N
 N
NORTH DAKOTA
   10
                                             90
   10
                                             90
OHIO
OKLAHOMA
   10
                                             90
OREGON
PENNSYLVANIA
RHODE ISLAND
    N
                N
 N
 N
SOUTH CAROLINA
    N
                N
 N
 N
SOUTH DAKOTA
   50
                                             50
TENNESSEE
TEXAS
                                                97
UTAH
VERMONT
                  30
                                             70
                                               100
VIRGINIA
WASHINGTON
                                               100
WEST VIRGINIA
                 100
                                             90
WISCONSIN
                                                 90
WYOMING
                                               100
N  is  not known.
No  entry indicates
lack  of response.
                                   B-l

-------
                                TABLE B-2
                  STATE LAB WORK LOAD  (INORGANICS)
                       NUMBER  OF SAMPLES
                      PRESENTLY ANALYZED
                                                   POTENTIAL NUMBER OP
                                                    SAMPLES ANALYZED
ALABAMA
ALASKA
                         few  hundred
                                                             N
ARIZONA
                                N
ARKANSAS
CALIFORNIA
                           1,666
                             1.666
COLORADO
                              550
                                550
CONNECTICUT
                                N
                                  N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
                                N
                                  N
GEORGIA
                           9,000
                             9,000
HAWAII
                              669
                             1,000
IDAHO
                              214
                                250
ILLINOIS
INDIANA
                          16,620
                            17,000
IOWA
                         700-900
                                  N
KANSAS
                              300
                             1,500
KENTUCKY	546 (partial)  8  (total)  600  (partial) 10  (total)
LOUISIANA
MAINE
                              500
                               + 25% +
MARYLAND
MASSACHUSETTS
MICHIGAN
                    13 (plus  144  mercury  only)
                                 13
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
                                N
                                  N
NEBRASKA
                              300
                             1,500
NEVADA
NEW HAMPSHIRE
NEW JERSEY
                                N
                                  N
NEW MEXICO
                           7,000
                             7,700
NEW YORK
                                N
                                  N
NORTH CAROLINA
                           4 .000
                             4,000
NORTH DAKOTA
                           3,000
                               + 21
OHIO
                           1,646
                             2,000
OKLAHOMA
OREGON
PENNSYLVANIA
                           2,609
                                  N
RHODE ISLAND
                              592
                                  N
SOUTH CAROLINA
                           2,200
                             2,500
SOUTH DAKOTA
                           5,500
                             6,500
TENNESSEE
                                                         3,500
TEXAS
3,325
UTAH
                           2,000
                           4,000
                             3,000
                             4,000
VERMONT
VIRGINIA
                                                         2,500
WASHINGTON
2,500
WEST VIRGINIA
                           1,000
                             1,000
WISCONSIN
WYOMING
                               60
                                220
N is not  known.
No entry  indicates lack  of  response
                                 B-9

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                           TABLE B-3
    PERCENT OF ORGANIC ANALYSES DONE BY FOUR AGENCIES BY STATE
                  IN-HOUSE
 PRIVATE
COMMERCIAL
MUNICIPAL
STATE
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
5
0

N
10
N
90
0

N
10
N
0
0

N
0
N
5
100

N
80
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
100
N
N
0
0
N
N
0
0
N
N
0
0
N
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
1
N
100
0
N
0
0
0
0
0
0
0
99
99
0
100
LOUISIANA
MINE
N
N
N
N
MARYLAND
MASSACHUSETTS
MICHIGAN
0
0
0
100
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
100
N
0
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
N
N
10
95
0
N
N
N
0
0
0
N
N

0
0
0
N
N

90
100
0
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
N
N
0
N

0
0
0
0

0
N
N
0
N

0
0
0
0

0
N
N
0
N

0
0
0
0

0
N
N
100
N

0
100
0
100

90
WISCONSIN
WYOMING
0
100
0
0
N is not known.
No entry indicates lack of response.
                                  B-10

-------
                            TABLE B-4


                STATE LAB WORK LOAD (ORGANICS)


                     NUMBER OF SAMPLES        POTENTIAL NUMBER OF
                    PRESENTLY ANALYZED         SAMPLES ANALYZED
ALABAMA
ALASKA
ARIZONA
Few
N
N
N
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
1,666
550
N
1,666
550
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
0
214
N
0
0
250
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
38
700-900
0
75
N
40
N
0
N
N
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
13
13
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
N
100
N
0
N
0
N
100
N
0
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
175
N
N
N
175
N
TENNESSEE
TEXAS
UTAH
VERMDNT
VIRGINIA
WASHINGTON
WEST VIRGINIA
0
N
0
30
0
10
0
N
0
N
0
20
WISCONSIN
WYOMING
0
0
N is not known.
No entry indicates lack of response.

                           B-H

-------
                             TABLE B-5
   PERCENT OF PESTICIDE ANALYSES DONE BY FOUR AGENCIES BY STATE
                   IN-HOUSE
 PRIVATE
COMMERCIAL
MUNICIPAL
STATE
ALABAMA
ALASKA
ARIZONA

0
0

50
0

N
0

50
100
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
5
N
N
5
N
N
0
N
N
90
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
90
0
N
0
0
0
N
0
0
0
N
0
100
100
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
0
N
100
0
N
0
N
0
0
N
0
N
0
0
N
100
99
0
100
N
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
0
0
0
100
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
100
N
0
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
N
10
0
0
N
0
N
0
N
0
N
0

0
0
0
N
100

90
100
100
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
0
N
N
N
0
N
N
N
0
N
N
N
100
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
99
100
0
100
100
20
WISCONSIN
WYOMING
0
100
0
0
N is not known.
No entry indicates lack of response.
                               B-12

-------
                            TABLE B-6
                 STATE LAB WORK LOAD PESTICIDES

NUMBER OF SAMPLES
PRESENTLY ANALYZED
POTENTIAL NUMBER OF
SAMPLES ANALYZED
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
0
N
1,666
0
N
N
N
1,666
0
N
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
16
167
N
0
16
200
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
0
700-900
0
20
10
N
0
200
LOUISIANA
MAINE
N
N
MARYLAND
MASSACHUSETTS
MICHIGAN
13
13
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO

N
200
N
under 50
0
300

N
300
N
under 50
0
300
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
184
175
N
N
N
175
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
100
20
0
30
N
20
100
20
0
N
N
20
WISCONSIN
WYOMING
0
0
N is not known.
No entry indicates lack of response
                               B-13

-------
                         TABLE B-7

   PERCENT OF COLIPORM ANALYSES DONE BY FOUR AGENCIES BY STATE

IN-HOUSE
PRIVATE
COMMERCIAL
MUNICIPAL
STATE
ALABAMA
ALASKA
ARIZONA
0
0
10
0
N
0
90
100
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
30
N
N
1
N
N
1
N
N
49 ,
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
60
0
N
0
0
2
N
10
0
0
N
90
40
98
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
15
0
20
20
0
5
0
0
5
45
10
10
80
50
70
70
LOUISIANA
MAINE
10
0
0
90
MARYLAND
MASSACHUSETTS
MICHIGAN
N
82
N
0
N
0
N
18
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
20
N
0
N
10
N
70
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
N
25
10
10
N
0
N
0
0
0
N
0

0
1
0
N
100

75
90
90
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
68
0
N
N
1
0
N
N
N
10
N
N
32
90
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
T? 	 • 	 j 	 1 	
10
25
0
25
10
0

1
0
2
0
0
0
5

0
0
13
0
0
50
25

0
90
60
100
80
40
70

99
  is not known.
No entry indicates
lack of response.
                               B-14

-------
           TABLE B-8




STATE LAB WORK LOAD COLIFOEM

NUMBER OF SAMPLES
PRESENTLY ANALYZED
POTENTIAL NUMBER OF
SAMPLES ANALYZED
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
20,000
N
15.000
9,800
N
N
N
15,000
9,800
N
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
40.000
5,953
7,191
N
40,000
6,000
10,000
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
25,648
40,000
N
21,000
26,000
N
N
21,000
LOUISIANA
MAINE
10,000
12.500
MARYLAND
MASSACHUSETTS
MICHIGAN
N
24,000
N
24,000
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
N
25,000
N
40,000
7,000
45,000

N
25,000
N
40,000
N
45,000

OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
2,609
6,870
50,000
15,000
N
N
70,000
17,000
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
260,322
20,000
20,000
84,520
15,000
N
275,000
40,000
20,000
N
15,000
N
WISCONSIN
WYOMING
N is not known.
No entry indicates
7,575
lack of response.
10,000

                  B-15

-------
                           TABLE B-9
  PERCENT OF PLATE COUNT ANALYSES DONE BY FOUR AGENCIES BY STATE


                               PRIVATE
                  IN-HOUSE    COMMERCIAL     MUNICIPAL     STATE
ALABAMA
ALASKA
ARIZONA
0
0
10
0
0
0
90
100
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
N
N
N
N
N
N
N
N
N
N
N
DELAWARE
DISTRICT OP COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
60
1
N
0
0

N
0
0

N
0
40

ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
5
0
20
100

0
0
0
0
0

0
0
10
10
0

0
95
90
70
0

100
MARYLAND
MASSACHUSETTS
MICHIGAN
N
100
N
0
N
0
N
0
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
20
N
0
N
10
N
70
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
N
N
10
0
N
0
N
N
0
0
N
0
N
N
1
0
N
100
N
N
90
0
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
5
N
N
N
N
N
N
N
N
N
N
N
95
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
0
30
0
85
0
0
0
0
0
10
0
0
100
60
0
15
WASHINGTON
WEST VIRGINIA
0
0
0
100
WISCONSIN
WYOMING
0
100
0
0
N is not known.
No entry indicates lack of response.

                             B-16

-------
                            TABLE B-10

                STATE LAB WORK LOAD PLATE COUNT

NUMBER OF SAMPLES
PRESENTLY ANALYZED
POTENTIAL NUMBER OF
SAMPLES ANALYZED
ALABAMA
ALASKA
ARIZONA
several hundred
N
N
N
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
15.000
0
N
15.000
0
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
1,000
0
N
0
1,000
N
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
0
0
16,000
0
0
0
16,000
0
LOUISIANA
MAINE
400
25$
MARYLAND
MASSACHUSETTS
MICHIGAN
N
few
N
few
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
16,000
N
16,000
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
45
N
0
0
10
N
2,500
N
N

N
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
1.480
3,000
N
N
N
5,000
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
50
2,600
not routinely
42
0
N
300
3,000
analyzed
N
0
N
WISCONSIN
WYOMING
0
0
N Is not known.
No entry indicates lack of response.
                              B-17

-------
                        TABLE B-ll
PERCENT OF TURBIDITY ANALYIS DONE BY FOUR AGENCIES BY STATE
              IN-HOUSE
 PRIVATE
COMMERCIAL
MUNICIPAL
STATE
ALABAMA
ALASKA
ARIZONA
30
0
50
0
10
0
10
100
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
90
N
N
0
N
N
N
N
N
9
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII

N
0
60

N
0
0

N
0
0

N
0
40
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY

95
0
100
50

0
0
0
0

1
20
0
0

H
80
0
50
LOUISIANA
MAINE
20
0
0
80
MARYLAND
MASSACHUSETTS
MICHIGAN
N
99
N
0
N
0
N
1
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
100
N
0
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
100
10
1
5
N
0
0
0
0
0
N
95
0
0
1
0
N
5
0
90
95
95
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
92
N
N
N
0
N
N
N
0
N
N
N
8
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
100
0
0
100
50
0
0
0
0
0
0
0
0
50
0
0
0
0
0
50
100
0
50
60
WISCONSIN
WYOMING
N is not known.
No entry indicates
95
lack
0
of response.
0

5

                         B-18

-------
                           TABLE  B-12


                 STATE  LAB  WORK LOAD TURBIDITY

NUMBER OF SAMPLES
PRESENTLY ANALYZED
POTENTIAL NUMBER OF
SAMPLES ANALYZED
ALABAMA
ALASKA
ARIZONA
few
N
N
N
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
500
N
N
500
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
250
N
N
0
500
N
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
388
700-900
0
546
500
N
1,500
600
LOUISIANA
MAINE
400
+ 25$ +
MARYLAND
MASSACHUSETTS
MICHIGAN
N
450
N
450
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
0
N
1,500
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA

Unknown N
6,000
N
4,000
0
1,646


Unknown N
6,600
N
4,000
N
2,000

OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
1,120
2,200
N
N
N
3,000
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
0
2,000
4,000
728
W/Inorganics figure
500
100
3,000
4,000
N
W/Inorganics figure
500
WISCONSIN
WYOMING
0
0
N is not known.
No entry indicates lack of response.


                            B-19

-------
                         TABLE B-13
   PERCENT OF RADIOLOGICAL ANALYSES DONE BY FOUR AGENCIES BY STATK
                   IN-HOUSE
 PRIVATE
COMMERCIAL
MUNICIPAL
STATE
ALABAMA
ALASKA
ARIZONA
0
0
100
0
0
0
0
100
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
0
N
N
2
N
N
0
N
N
98
N
DELAWARE
DISTRICT OP COLUMBIA
FLORIDA
GEORGIA
HAWAII
N
0
0
N
0
0
N
0
0
N
0
0
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
0
0
100
0
0
0
0
0
0
1
0
0
100
99
0
100
LOUISIANA
MAINE
0
0
0
0
MARYLAND
MASSACHUSETTS
MICHIGAN
N
0
N
0
N
0
N
100
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
100
N
0
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
0
0
0
0
N
100
0
0
0
0
N
0
0
0
0
0
N
0
100
100
100
100
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
N
N
0
N

0
0
0
0
0
0
N
N
0
N

0
0
0
0
0
0
N
N
0
N

0
0
0
0
0
0
N
N
100
N

100
100
0
100
100
100
WISCONSIN
WYOMING
0
0
0
0
N is not known.
No entry indicates lack of response
                             B-20

-------
            TABLE B-14




STATE LAB WORK LOAD RADIOLOGICAL

NUMBER OF SAMPLES
PRESENTLY ANALYZED
POTENTIAL NUMBER OF
SAMPLES ANALYZED
ALABAMA
ALASKA
ARIZONA
0
N
N
0
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
1.000
670
N
1,000
670
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
0
N
N
0
0
N
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
0
700-900
0
4
10
N
0
8
LOUISIANA
MAINE
N
N
MARYLAND
MASSACHUSETTS
MICHIGAN
N
120
N
120
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
0
N
0
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
N
0
N
900
N
0
N
900
NORTH DAKOTA
OHIO
OKLAHOMA
1,690

2,500

OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
54
800
N
N
N
N
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
200
123
0
SO
0
N
250
7,900
0
N
0
N
WISCONSIN
WYOMING
N is not known.
No entry indicates
0
lack of response.
B-21
0


-------
                           TABLE B-15
PERCENT OF RESIDUAL CHLORINE ANALYSES DONE BY FOUR AGENCIES BY STATE
IN-HOUSE
 PRIVATE
COMMERCIAL
MUNICIPAL
                                                            STATE
ALABAMA
ALASKA
ARIZONA
30
0
10
0
50
0
10
100
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
99
N
N
0
N
N
0
N
N
1
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
0
60
0
N
0
0
0
N
0
0
100
N
0
40
0
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
100
80
95
75

100
0
0
0
0

0
0
80
0
25

0
0
20
5
0

0
MARYLAND
MASSACHUSETTS
MICHIGAN
N
100
N
0
N
0
N
0
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
N
95
N
0
N
0
N
5
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
N
0
100
N
100
100
N
0
0
N
0
0
N
95
0
N
0
0
N
5
0
N
0
0
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
N
N
65
N
N
N
0
N
N
N
0
N
N
N
35
N
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
100
0
0
100
95
0
0
0
25
0
0
0
0
100
75
0
5
90
0
0
0
0
0
10
WISCONSIN
WYOMING
N is not known.
No entry indicates
0
lack of resp
0
onse .
90

10

                              B-22

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                               TABLE B-16

                   NUMBER  OF SYSTEMS  BY TYPE &  SOURCE


                         SURFACE      GROUND     SURFACE    GROUND
                         WATER        WATER       WATER     WATER
                       COMMUNITIES  COMMUNITIES TRANSIENTS TRANSIENTS  FINISHED
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
N
12

300
179
N
N
1,900

800
345
N
N
N

N
N
N
N
N

N
95%
N
N
N

N
100
N
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
HAWAII
IDAHO
N
130
50 +
125
N
2,500
75+
820
N
0
N
175
N
100
N
878
N
200
0
12
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
50
54
2
N
393
768
450
N
N
N
0
N
10,000
N
N
N
20
N
8
119
LOUISIANA
MAINE
66
104
N
N
N
MARYLAND
MASSACHUSETTS
MICHIGAN
N
96
N
1,878
N
10
N
16,000
N
242
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA

N
2

N
450

N
0

N
N

N
8
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
46
17
400
169
33
167
N
353
735
2.470
224
1,485
N
N
N
N
N
100
N
N
N
N
N
19,000
N
N
400
68
N
113
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA

500
10
70
20

400
25
133
137
100
170

3,875
31
1,000
350

6,000
600
238
1,166
1,400
360

0
N
25
5

150
5
100
0
50
N

11,800
N
1,353
600

10,000
500
3,000
9,400
2,000
200

N
N
20U
1

500
40
N
50
100
120
WISCONSIN
WYOMING
46
372
16
410
6
N is not  known.
No entry  Indicates  lack of response.

                                 B-23

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                         APPENDIX C

DESCRIPTION OF PUBLIC NON-COMMUNITY SYSTEMS BY USE CATEGORY
     This appendix describes a breakdown of public non-
community supply systems based on use category.  Very few
states have compiled this information, and of those that
have, it appears that the data are still grossly incomplete.
New York State was able to provide their breakdown of known
non-community public water supplies,  which is found in Table
C-l.  This accounts for only 9,634, or approximately 27
percent, of the NSF estimated 36,000 systems for that state.

     Noting that the numbers in the first three categories
(food service establishments, schools, and state institutions)
should be reasonably close to the actual numbers distributed,
an extrapolation was made to estimate the percentage of
systems which belong to the final four categories (industrial,
commercial, condominiums, and miscellaneous).  This was
accomplished by weighting each unknown category according to
its number of known supplies, and distributing the appropriate
percentages among the 82.28 percent of the unknown category
systems.  The results are given in Table C-2 along with a
nationwide breakdown based on these percentages.

     It was difficult to determine the limits and the range
of applicability of these categories due to the lack of
data, and therefore these results should be used with caution.

     However, the figure trends appear to be compatible with
assumptions made for similar estimations by the EPA Water
Supply Division in a study of drinking water systems on and
along interstate highways (Table C-3).

     A further breakdown of the miscellaneous category into
Federally administered components is presented in Table C-4.
These data are presented in publications by the administering
agency responsible for the sub-category given.

     There are a large number of travellers who use small
non-community water systems, although it Is again difficult
to specify quantitative data on populations serviced by the
systems from each category.  The problem is further compli-
cated by the fact that there are quite significant seasonal
variations in the water demand from non-community supply
systems, especially from recreational areas.  The following
assumptions can be made with some confidence:
                           C-l

-------
     1.    Drinking water supplies serving food service
          establishments,  schools, state institutions,
          apartments,  and  industry cater to at least 25
          persons per  day  for 75 percent of the year:

     2.    Drinking water supplies serving recreational
          areas and facilities cater to at least 25 persons
          per day for  35 percent of the year in the northern
          United States and 90 percent of the year in the
          southern United  States;

     3.    Service to commercial business establishments
          is difficult to  generalize due to size and type
          of business, and must be investigated on a
          categorical  and  regional basis.

     Average annual system utilization for Federally adminis-
tered facilities are presented in Table C-5.   No other
concrete results could be  generated.

     Accurate cost analysis cannot yet be made of treatment
methods  for these facilities, since there is a significant
lack of  data in many categories.  It has become quite evident
that little, If any, national effort has been placed in this
area.  Little useful information has been obtained from the
few studies that have  been completed by the joint ventures
of the National Sanitation Foundation and the Conference of
State Sanitary Engineers,  by the EPA.  Future emphasis in
this area will have to proceed at the state-by-state inven-
tory.  In this report, all non-community systems are assumed
to serve an average of 25  people a day for all 12 months of
the year.
                           C-2

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                                                                         APR os
Robert P. Whalen,  M.D.
   COMMISSIONER
                                     TABLE C-l

                                 STATE OF NEW YORK
                               DEPARTMENT OF HEALTH
DIVISION  OF SANITARY ENGINEERING
        ESP - TOWER BUILDING
       FOURTH FLOOR - ROOM 438
         ALBANY,  N.Y. 12237
MEREDITH H. THOMPSON, D. ENG.
   ASSISTANT COMMISSIONER


   BUREAU OF RESIDENTIAL
  ft RECREATION SANITATION


   IRVING GROSSMAN, P.E.
        DIRECTOR
         April  1, 1975

         Mr.  Berry Gahron
         185  Alevjisebrook Parkway
         Cambridge, Massachusetts  02138

         Dear Mr. Gahron:

         Doctor Thompson has asked me to supply you with information regarding
         non-municipal public water supplies in New York State.

         The  table below shows the number of known supplies  by region and
category at this time.
REGIONS
Albany Buffalo Rochester Syracus
Food Service
Establishments
Schools
State Institutions
Industrial
Commercial
Condominiums &
Apt. Complexes
Miscellaneous
Regional Totals
1,145
146
• 35
33
459
62
24
1^904
Statewide
202 422
14 22
3 40
18 89
20 300
2 2
129 336
388 3*6-
Total = -9~i^6<
955
103
12
41
175
5
472
1 ,763

                                        2,994

                                          230

                                           57

                                           71

                                          167

                                          104
                                                                              \-
                                                                           5,7*8
                                                                            515

                                                                            147
                                                                             I7S
        The numbers in the first three categories  should be reasonably close
        to the actual numbers of these establishments.  This cannot be said of
        the remaining categories.  At this  time, no  estimate can be given of
        the total numbers of these establishments.   The reported numbers are
        simply the known supplies.
                                          C-3

-------
                                 - 2 -
The commercial category includes commercial business establishments such
as service stations, stores, shopping centers and grocers.

Examples of some establishments included in the miscellaneous category are
resorts, bathing beaches,  trailer parks, camps, springs and town and county
buildings.

If you have any questions  on these figures or require additional information,
please feel free to contact this office.

Very truly yours,
Dennis J. Corrigan
Sanitary Engineer
Residential Sanitation Section
                                  C-4

-------
                      TABLE C-2
   CATEGORY PERCENTAGE BREAKDOWN BASED ON NEW YORK
                STATE DATA AVAILABLE
     CATEGORY
 PERCENTAGE
 SYSTEMS IN
CATEGORY (%\
ESTIMATED NUMBER
  OP SYSTEMS INp
  UNITED STATES^
1.
2.
3-
i].

5-
6.
7-

Food Service Establishments
Schools
State Institution
Industrial

Commercial'3
Condominiums and Apartments
it
Miscellaneous
TOTAL
15
1
0
6

28
4
43
100
.88
.^3
.41
-37

• 31
.46
.14
.00
36
o

14

65
10
99
230
,582
,294
945
,674

,217
,274
,381
,367
Assumptions:

1.  Categories 4 through 7 based on weight data.   See text.

2.  Nationwide breakdown based on NSF estimates and New
    York data.

3.  Commercial category includes commercial business
    establishments such as service stations, stores,
    shopping  centers and grocers.

4.  MIcellaneous category includes resorts, beaches, parks,
    camps, springs, and town and country buildings.
                        C-5

-------
                          TABLE  C-3
                  DRINKING WATER SYSTEMS ALONG
                       INTERSTATE HIGHWAYS
       SUMMARY OF THE CATEGORIES OF WATER SYSTEMS SURVEYED
System Category
Safety Rest Area
w
;| Service Station
'y t< Restaurant
I °
B 'g Motel
,9 
-------
                           TABLE C-4


             FEDERALLY ADMINISTERED NON-COMMUNITY
                   WATFR SUPPLY SYSTEMS*
                               NUMBER OF       POPULATION
       SUBCATEGORY              SYSTEMS      SERVED ANNUALLY
1.   U.S.  Forest  Service         10,000            71 x 1C^

2.   Interstate Highways          9,115            1250 X 10°

3.   U.S.  Bureau  of Reclamation     2t50            5^ X 10^

4.   U.S.  National Park Service     JJ25            216 X 10r
       aFederally administered supplies account for about 20
   percent of the miscellaneous category in Table C-2.
                             C-7

-------
                     TABLE C-5


        AVERAGE ANNUAL FEDERAL WATER SUPPLY
       UTILIZATION (NOT SEASONALLY ADJUSTED)
    SUBCATEGORY                  USE (PEOPLE/SYSTEM/DAY)


1.   U.S.  Forest Service                    19

2.   Interstate Highways                   137

3.   U.S.  Bureau of Reclamation           580

4.   U.S.  National Park Service         1,390
                        C-8

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                       APPENDIX D

             WATER SUPPLY SYSTEM QUESTIONNAIRES
     A questionnaire (Figure D-l) was sent to the 207 water
supply systems which were found to exceed one or more maximum
contaminant levels, as determined in the 1969 CWSS study.
Of these 207 systems, replies were obtained from 114 systems
(Table D-l), of the remaining 93 systems, 17 no longer
operate, 17 others have consolidated, and 59 could not be
contacted.

     This Initial questionnaire dealt mainly with treatment
and analysis costs and techniques employed.  The responses
concerning analysis are summarized in Table D-2.  This shows
that over 63 percent of the inorganic and 70 percent of the
organic and bacteriological analyses are done by some form
of governmental laboratory.  Another important finding of
the study is that seven out of the eight water supply systems
contacted which distribute purchased water do not analyse
the water in their distribution system.

     The responses to the treatment questions Indicate that
only 15 systems have changed their treatment techniques
since discovering their violation on 1969-  These changes
are listed In Table D-3-

     A second telephone questionnaire (Figure D-2) was
utilized to supplement the financial and cost data infor-
mation of the 11^ respondents listed above.
                         TABLE D-l

  SUMMARY OF RESPONDENTS TO WATER SUPPLY SYSTEM QUESTIONNAIRE

Number sent out                                             207

Systems which no longer operate                              17
Systems which could not be located                           43
Systems which have consolidated and therefore no response    17
Systems which operate seasonally only and no response        16
Municipal (and other governmental agency) systems responding 78
Private systems responding                                   36

          Total                                             207
                          D-l

-------
                         TABLE D-2

 SUMMARY OF RESPONSES FROM WATER SUPPLY SYSTEMS QUESTIONNAIRE

1.    Costs of Analysis                       Range ($)

     1)   Inorganica'b                       0 - 144.00
     2)   Organica'b                         0 -  60.00
     3)   Bacteriological                    0 -  7-50

2.    Analysis Done By:
STATE
1)
2)
3)
Inorganic
Organic
Bacteriological
27
23
27
COUNTY
5
5
7
MUNICIPAL
LAB
8
6
11
PRIVATE
LAB
23
15
18
OTHER
3
3
4
     o
      $0 costs are for those systems where state or other
governmental agency Incurs the cost of analysis.

      The costs for inorganic and organic analyses are for
partial analyses only.
                         TABLE D-3

               CHANGES IN TREATMENT TECHNIQUES
      TO CORRECT FOR VIOLATIONS OF 1969 PHS STANDARDS

     CONTAMINANT                   NEW TREATMENT

     N03                      Blending
     Pb                       pH Control
     Fluoride                 New well
     Turbidity                Coagulation, filtration,
                                sedimentation
     Turbidity                New source
     N03                      Blending
     Se                       Blending
     N03                      Blending
     Fluoride                 Inject less fluoride into system
     Pb                       Change pipes
     Coliform                 Chlorinator
     N03                      Blending
     Pb                       Flush system
     Turbidity                Coagulation, filtration,
                                sedimentation
     Coliform                 Chlorinator

                          D-2

-------
                              FIGURE D-l
                 QUESTIONNAIRE TO WATER SUPPLY  SYSTEMS
1.  NAME OF SUPPLY:

2.  LOCATION:
3.  PERSON FILLING OUT  QUESTIONNAIRE:

4.  PHONE #
5.   POPULATION SERVED:
6.   CURRENT PRODUCTION  (MOD):
7.   TOTAL VOLUME  SUPPLIED  IN 1974
       (SPECIFY UNITS):
    TREATMENT METHODS  USED:   (PLEASE CHECK)

                                                        TREATMENT PROCESS
                                                        ADDED SINCE 1970

                                          YES      NO      YES      NO

    a.  Disinfection	     	    	

    b.  Coagulation	     	    	

    c.  Sand Filter                        	    	     	    	

    d.  Fluoridation                       	    	     	    	

    e.  Taste and  Odor Control            	    	     	    	

    f.  Lime Softening	

    g.  Ion Exchange	    	

    h.  Settling	

    i.  Iron Removal	     	    	

    j.  Other  (Please  List)                	
    k.  Do you  use  zeolite  for:
       1)   Iron  Removal

       2)   Softening


                                  D-3

-------
 9.   ANALYSIS INFORMATION
                                           State Municipal Private
                                            Lab     Lab      Lab   Other
     a.   Inorganic Analysis Done By:         	     	      	    	
     b.   Date of Last Inorganic Analysis:   	
     c.   Cost of Analysis:
     d.   Organic & Pesticide Done By:
     e.   Date of Last Organic Analysis:
     f.   Cost of Analysis:       	
     g.   Bacteriological Analysis Done By:
     h.   Date of Last Bacteriological Analysis:
     i.   Cost of Analysis:
10.   QUALITY OP INFLUENT WATER
     a.   Do you Treat for a Particular Contaminant in the Influent
         Water?  (e.g.,  Lead,  Coliform, CCE, etc.) 	
     b.   How Frequently do you Monitor the Influent Water?
                                        Daily   Monthly   Yearly   Other
11.   QUALITY OF EFFLUENT WATER
     a.   In 1969 you exceeded the 1962 PHS Standard for
         and	.   Please list any corrective actions taken
                 rm
         to rectify this violation.
         (I)
              Capital Cost
              Annual Operating Cost (OVHD & Maint.)
              Total Annual Cost
                                    D-4

-------
    (ii)
         Capital  Cost

         Annual Operating Cost (OVHD & Maint.
         Total Annual  Cost
     b.   Are  you  now in Compliance with These Standards?
     c.   What  are  your Current Concentrations of These Parameters?
     d.   Have  you  have any New Problems with Other Pollutants?

         (If  so,  Please Specify)  	     	 	
12.   CURRENT OVERHEAD AND MAINTENANCE COSTS FOR TREATMENT

                                                   $/Uriit of Time

     a.   Labor                                   	

     b.   Supplies                                	
     c.   Chemicals  (Please List at
           end  of Questionnaire)

     d.   Electric Power

     e.   Total
13.   WHAT  ARE  THE ANNUAL FIXED COSTS OF YOUR PLANT? $_

                                                Year
     HOW  MANY  EMPLOYEES IN WATER SYSTEM:       Full Time    Part Tine
1?.   WHAT  IS  THE  RATE STRUCTURE FOR WATER SALES?
                                               AMOUNT        UNIT
                                                         (Gal., Ou.Ft

-------
16.   METHOD OF CHARGING?        Meters	 Fiat Rate	 Other
17-   PROFITS                          $	Year 	
18.   DEPRECIATION                     $              Year
19.   ESTIMATES ON UPGRADING CURRENT TREATMENT FACILITIES:
     (If you are planning an expansion or change in treatment
      techniques, please specify contaminant you will treat for.)
     a.   Capital Costs
         Land                         $
         Equipment                    $
         Site Development             $
         Total                        $
     b.  O&M Costs
         Labor                        $
         Supplies                     $
         Chemicals                    $
         Electric Power               $
         Other                        $
         Total                        $

20.   CAPITAL FINANCING


     a.  General Obligation Bonds     $
     b.  Revenue Bonds                $
     c.  Debenture Bonds              $
     d.  Mortgage Bonds               $
     e.  Bank Loans                   *
 Amount       Interest or
Realized    Dividend Rate($)
                                D-6

-------
    f.  Preferred  Stock              $
    g.  Common  Stock                 $
    h.  Other                        $


    i.  Total                        $
21.   The  Proposed  Interim Standards  allow for total  substitution
     of  chlorine residual monitoring in  place of  coliform density
     measurements  for  systems  serving 4,900  or fewer persons
     provided  the  system maintains  a residual of  no  less  than
     0.3  mg/1  free chlorine.   If the system  serves more than 4,900
     people, chlorine  residual monitoring may be  substituted for
     not  more  than 75% of the  required coliform measurements if a
     residual  of no less than  0.2 mg/1 free  chlorine is maintained
     in  the public water distribution system.   This  substitution
     would reduce  the  overall  monitoring costs of the Proposed
     Standards considerably.   Do you feel that your  system would
     use  this  chlorine residual option?               YES	 NO	

22.   COMMENTS:
                                D-7

-------
                            FIGURE D-2





                                              CODE;
1- NAME OP WATER  SUPPLY:




•"'• PHONE  #:
 '•>-  PERSON  SUPPLYING  INFO.:
    OWNERSHIP
MUNICIPAL
PRIVATE
OTHER GOV'T
    RATE  STRUCTURE:




 5-  __ dollars  for_ __ units  RESIDENTIAL  or flat rate of $




 ^-  __ dollars  for _ units  COMMERCIAL   or flat rate of $
 7-  _ dollars  for     units  INDUSTRIAL   or flat rate of $
    CURRENT  REVENUES  RAISED FROM:   Answer either in $ or % of total




 S.  	RESIDENTIAL




 0.  	COMMERCIAL




10.  	INDUSTRIAL




I-L.  	TAX REVENUES  Either as SURPLUS (+) or SUBSIDY (-)or




    	TOTAL REVENUE If can't get #'s 8,  9, 10, or 11




    #  OF  CUSTOMERS:




1:..  RESIDENTIAL	




13-  COMMERCIAL 	




11.  INDUSTRIAL
15.  CURRENT  ANNUAL O&M COST INCLUDING:
                       OPERATION & MAINTENANCE  +
        INTEREST ON DEBT IF ANY, (C|  AMOUNT OF MONEY PUT ASIDE TO
    RETIRE  DEBT,  IF ANY:
16.  WHAT  IS  TOTAL PRODUCTION?
17-  WHAT  IS  TOTAL POPULATION SERVED?
        WHO  ARE THE 2 OR 3 LARGEST CUSTOMERS AND HOW MUCH WATER DO




        THEY USE?                        	
                                  D-9

-------
     B   IF  INDUSTRIAL  CONCERN WHAT  DO  THEY PRODUCE?
      C   WHAT  IS  TOTAL  BILL  OF  CONCERN?
19-  WHAT  IS  A  TYPICAL  RESIDENTIAL  BILL?
20.   IS  WATER  SYSTEM  AN  INDEPENDENT  AGENCY  	 OR TIED IN WITH




     OTHER  AGENCIES  (SEWER, ETC.)?	
21.   HOW  DOES  THE  SYSTEM  FINANCE  EXPANSION?  	 BONDS?	LOANS?




     	SHARES?




22.   WHAT IS THE CURRENT  INDEBTEDNESS  OF  THE SYSTEM?
                                  D-10

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                       APPENDIX E

                  CONTAMINANT REMOVAL
       BY CONVENTIONAL WATER TREATMENT PROCESSES


E.I  Removal of Turbidity

     There are a number of conventional water treatments
which are employed, either singly or in combination, for the
removal of turbidity from water intended for human consumption.
Turbidity is imparted to water by suspended solid particles
whose sizes are so small as to constitute a nonsettleable
colloidal suspension.

     High turbidity levels render water unacceptable for
human consumption both for aesthetic and health reasons. The
origins of turbidity particulates are partly mineral
(including possibly toxic heavy metals), partly organic, and
partly microbiological (including possible disease causing
microorganisms).  Moreover, high turbidity interferes with
disinfection and other treatment practices.

     Although filtration by itself sometimes suffices to
reduce turbidity to acceptable levels, chemical treatments
are commonly practiced to induce coagulation and flocculation.
The resulting coalescence into larger particles allows
partial settling and increases filtration efficiency.

     The chemicals most commonly used for coagulation and
flocculation are aluminum sulfate [A12 (8011)3] or alum> and
iron (III) sulfate [Fe2 (S0/| ^] or ferric alum.  Both alum and
ferric alum are water soluble, but at medium to high values
of pH, they react with water to form solid hydroxides in the
form of gelatinous precipitates which incorporate the
turbidity particles into easily filtered or settleable
masses.

     In principle, these "floes" of aluminum and ferric
hydroxides have a potential to absorb dissolved solids
including toxic heavy metals and other inorganics which fall
under the primary standards.  Control of Ba++ by precipitation
as the insoluble sulfate salt is also possible from considerations
of chemical equilibrium.  Studies have been performed on the
following species to determine removal efficiencies through
coagulation, flocculation, and filtration:  organic mercury
                            E-l

-------
         1'2 , inorganic mercury (HgCl2)1>2, Barium  (Ba++)2,
inorganic selenium (IV) , inorganic selenium (VI)23  inorganic
arsenic (III)2j33 inorganic arsenic (V)2j33 and total chromium.^
The results are shown in Table E-l.

     In the studies by Logsdon and Symons, the removal
efficiencies of mercury tended to parallel initial levels of
turbidityl.  The failure of sulfate ion to remove barium was
attributed to supersaturation2; the importance of oxidation
states was noted for selenium and arsenic2 .  It was  observed
that selenium is primarily a ground water problem and that
the reduced state [Se(IV)]  should therefore predominate2.
(Fortunately Se(IV) is the easier of the two to remove.)
Laboratory233and field studies both showed that chlorination
improves the removal efficiency for arsenic, presumably
thorugh oxidation of As(III) to As(V).


E.2  Chlorination

       Chlorination is very widely practiced as a means of
disinfecting public water supplies, and its use in the United
States has reduced the once epidemic incidence of water-borne
disease to almost negligible proportions.
      G.S. Logsdon and J.M. Symons, "Mercury Removal by
Conventional Water Treatment Techniques," J. Am. Water
Works Assn., 65., 554 (1958).
     o
      G.S. Logsdon and J.M. Symons, "Removal of Heavy Metals
by Conventional Treatment," in J.E. Sabadel, editor, "Traces
of Heavy Metals in Water Removal Processes and Monitoring,"
United States Environmental Protection Agency Report
#902/9-7^-001, Region II, 1973, pp. 225-56.
     o
     JY.S. Shen, "Study of Arsenic Removal from Drinking
Water," J. Am. Water Works Assn., 65., 543 (1973).
     4
      G.M. Zemansky, "Removal of Trace Metals During
Conventional Water Treatment," J. Am. Water Works Assn.,
66, 606 (1974).
                           E-2

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                           TABLE E-l
             REMOVAL OF HEAVY METALS BY COAGULATION,
FLOCCULATION AND FILTRATION

SPECIES
Organic
Mercury
Inorganic
Mercury
Barium

APPROXIMATE
ALUM
<30
<30
<30

PERCENT
REMOVAL
FERRIC ALUM
<30
30-60
<30

TYPE OF
STUDY REFERENCE
Jar Test 1,2
Jar Test 1,2
Jar Test 2
Inorganic
Selenium (IV)

Inorganic
Selenium (VI)

Inorganic
Arsenic (III)

Inorganic
Arsenic (V)

Total Arsenica

Total Arsenic
Total Chromium
             <30           60-80


             <30           <30


             <30           50-80


             60-90         90-100

                   50-80

                    100


                    0-60
 Jar Test


 Jar Test


 Jar Test


 Jar Test

 Jar Test
2

3
 Jar Test,    3
Field Survey

Field Survey  4
      a
      d
 Ferric  chloride  coagulation.

'Chlorination followed by ferric chloride coagulation.

;Coagulants  not  specified.

 See  footnotes, preceding page.
                             E-3

-------
When C3-2 dissolves in water at a neutral pH, it
disproportionates:

           C12 + H20  ->   H+ + Cl~ + HC10      (1)


forming hydrochloric acid and hypochlorous acid  (HC10). All
the disinfecting and oxidizing power of "aqueous chlorine"
resides in the hypochlorous acid.  The pH is of  course
lowered.

     Several of the inorganic chemicals listed in the
primary standards are affected by chlorination.  Trivalent
arsenic (As(III)) is oxidized to the pentavalent state
(As(V)). Tetravalent selenium (Se(IV)) does not  oxidize
rapidly in the presence of HC10, but standard oxidation
potentials predict that it should be converted to Se(VI).
Nitrite (NO;?) is oxidized to nitrate (NO^j).  Free cyanide
(CN~) is destroyed, but some cyanide complexes are resistant
to chlorination.  Chlorination can potentially destroy some
organometallic compounds.  (The reaction of HC10 with methyl
mercury should therefore be investigated).

     Aqueous chlorine reacts readily with ammonia.  The
resulting chloramines retain much of the disinfecting power
of chlorine and represent much longer-lasting chlorine
residuals (combined chlorine residual), but are much weaker
oxidizing agents.  Thus,  when ammonia is present in the
water (either naturally or by deliberate addition), under
these conditions, the reactions as cited in the previous
paragraph are not as likely to take place.

     Aqueous chlorine also reacts with organics to produce
chlorinated organics, such as those found in the New Orleans
water supply last year and implicated in the high incidence
of bladder cancer in that city.   One possible benefit of
this reaction, however, is that the chlorinated organics are
probably more completely adsorbed on activated carbon than
are their precursors.
E. 3  Activated Carbon Filtration

     Filtration through activated carbon is a well known,
effective treatment for water with high levels of odor and
color.   This is due to carbon's extraordinary capacity to
                           E-4

-------
 adsorb  organic  molecules  onto its  surface.   It  Is  likely
 that  activated  carbon filtration would constitute  adequate
 treatment  for water with  excessive levels  of total organics
 (as measured  by carbon chloroform  extraction)  and  of pesticides

      Logsdon  and Symons have  investigated  the  removal of
 several trace metal species with activated  carbon.1  Effective
 removals of both organic  and  inorganic mercury  were observed
 with  removal  efficiencies of  up  to 100 percent  using
 granular activated carbon in  columns.   They found  that
 activated  carbon was ineffective against barium, selenium
 and arsenic.   Smith,2 however, has reported that when carbon
 is prepared with a high content  of oxygenated  surface
 groupings,  it functions as an ion  exchange  medium  and is
 therefore  a good adsorber of  ionic species.   Carbon's other
 removal mechanisms include true  adsorption,  precipitation,
 oxidation  or  reduction to insoluble forms,  and  mechanical
 filtration.  Smith's literature survey disclosed  effective
 removals of  Cr,  Pb, Ni, Cd, Zn,  Fe,  Mn,  Ca, Al,  Bi,  Cu,
 Ge, as  well as  the aforementioned  work on  Hg. Suitable
 carbons can be  prepared by heating carbon  in the presence of
 oxygen  or  by  slurrying it with nitric  acid.

      It should  be noted that  activated carbon has  a 100
 percent removal efficiency for chlorine.
 E. i|   Lime  Softening

      In lime  softening,  calcium hydroxide  (Ca(OH)2)  is  used
 as a  base  to  convert  the natural bicarbonate  (HCO-)  content
 of water to carbonate (CO^).   The pH of  course  rises.   As  a
 result,  the Insoluble compounds CaCOo , MgCO-^  and  (In the
 case  of excess  lime softening)  Mg(OH)2 form and fall out of
 solution as precipitates.

      Lime  softening has  many  variations, depending both on
 the composition of  the feed water and  on the  desired quality
 of the  finished water.   In addition to lime,  a  particular
 lime  softening  process may also use C02 , Na2C02>,  or  NaOH.
 Ordinary lime softening  raises  pH to the range  of 8-10; in
 excess  lime softening the  pH  goes over 10  but is  later
 reduced - for  example, by aeration with CO   (a weak acid).
      ^-Logsdon and Symons, "Mercury Removal by Conventional
 Water Treatment Techniques," 1958.

      2S.B.  Smith, "Trace Metals Removal by Activated Carbon,
in J.E.  Sabade, pp. 55-70.


                            E-5

-------
      Lime softening can cause some heavy trace metals to
 precipitate as hydroxides or carbonates^ it can also convert
 species such as HAs02, H2AsOiJ', and HAsO^, which are soluble
 in the presence of Ca   to AsO~ and AsO=  whose calcium
 salts precipitate.

      Hem and Durum ^- have studied the equilibrium solubility
 of lead as a function of carbonate and pH, and concluded
 that a pH of 8 is sufficient to reduce the dissolved lead
 content to a level which is less than 10 percent of the
 maximum value permitted by the primary standards.  Lime
 softened water should therefore satisfy the lead standard,
 and moreover should be incapable of dissolving lead pipes
 and lead joints in water distribution systems.

      Logsdon and Symons2 have studied the effectiveness of
 lime softening on mercury (both organic and inorganic),
 barium, arsenic (III), arsenic (V), selenium  (IV) and
 selenium (VI).  Their results are summarized in Table E-2.  The
 arsenic results parallel those for ferric alum coagulation.
 They found that chlorination of As(III) followed by lime
 softening achieved removal efficiencies characteristic of
 As(V).

                        TABLE E-2

         REMOVAL OP TRACE HEAVY METALS WITH LIME
                              APPROXIMATE PERCENT REMOVAL
     SPECIES	pH 8.5-9-5	pH 10.5-11.5
Organic Mercury
Inorganic
Barium
Inorganic
Inorganic
Inorganic
Inorganic
Mercury

Selenium (IV)
Selenium (VI)
Arsenic (III)
Arsenic (V)
0
20-40
60-90
-x-20
<10
10-20
30-50
0
60-80
80-95
20-50
<10
60-80
90-100
      j.D. Hem and W.H. Durum, "Solubility and Occurrence of
Leak in Surface Water," J. Am. Water Works Assn., 6J5,  562 (1973)
     2
      Logsdon and Symons, "Mercury Removal by Conventional
Water Treatment Techniques," 1958.

                          E-6

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                         APPENDIX F

            CHEMISTRY OF REMOVAL OF CONTAMINANTS
                 PROM DRINKING WATER SYSTEMS
     This section considers the removal of chemical
contamination on a specles-by-species basis.  The discussion
in this section is based solely on theoretical chemical
considerations.  A subsequent section discusses this on a
process-by-process basis.
F.I  Arsenic
     Aqueous arsenic occurs as oxyanions in the III and V
oxidation states.   The degree of_protonation depends on pH,
Arsenite (AsOp) and arsenate (AsOr) are rather basic while
arsenic acid (H^AsO^) is a strong acid.  Arsenite is more
toxic than arsenate.  Arsenate (V state) is easily removed
from water by coagulation, either with alum or ferric
sulfate or by lime softening, especially at excess levels
(pH 10.6-11). Arsenite (III state) Is less well removed,
but chlorination rapidly converts it to arsenate.
F.2  Barium

     Aqueous barium occurs as the ion:  Ba  .   The sulfate
and carbonate are its only important insoluble salts,
     ^General chemical properties obtained from standard
texts such as F.A. Cotton and G. Wilkinson,   Advanced
Inorganic Chemistry,  Interscience, 1962.

     2G.S. Logsdon and J.M. Symons, "Removal of Heavy
Metals by Conventional Treatment," in J.E. Sabadel, editor,
"Traces of Heavy Metals in Water Removal Processes and
Monitoring,"  United States Environmental Protection
Agency Report #902/0-7^-001, Region II, 1973, PP•  225-
56.
                           F-l

-------
however, treatment with sulfate1 (as in alum or ferric
sulfate coagulation) was found to be ineffective for its
removal. The carbonate- however, is well-behaved and can
apparently be precipitated out during lime softening or pH
control at pH 1011.  Cation exchange is also effective in
removal of Ba++.

     CWSS listed one barium violation at 1.55 mg/1;  the
system practices chlorination, coagulation, aeration,
settlement, and rapid sand filtration.

P.3  Cadmium

     Aqueous cadmium occurs in the III oxidation state.
There are not hard data on the removal of cadmium by
standard treatment processes; however, the chemistry of
cadmium parallels that of lead, and since lead can be
controlled by pH control, this technique may also be
effective against cadmium.   However, on a molar basis,
cadmium must be controlled to a residual that is three  times
lower than lead (0.9x10  M. vs. 2.4xlO~°), but the solubility
products^are higher for both the hydroxide (Ksp (Cd(OH)p)  =
2.0x10", Ksp (Pb(OH)2) = 4.0xlO~15)2 an(j the carbonate
(Ksp(CdC03) = 5.2x10-12 , Ksp(PbC03) = 1.0x10—L:i), so it is
not clear that pH control would constitute an adequate
treatment. Cation exchange would be effective in the absence
of another suitable treatment.

     The CWSS data base shows nine systems in violation of
the cadmium standard (0.010 mg/1).   Table F-l  shows the
observed levels and treatment practices in the nine systems.
      Environmental Health Service, Bureau of Water Hygiene,
USPHS, "Community Water Supply Study—Analysis of National
Survey Findings," Department of HEW, July 1970, and data
base thereto.
     2
      Equilibrium constants were obtained from tables in,
A.F. Clifford, Inorganic Chemistry of Qualitative Analysis,
(Englewood Cliffs, N. J.:Prentice-Hall, Inc., 1961).
                          F-2

-------
                          TABLE F-l

                     CADMIUM VIOLATIONS

     LEVEL mg/1               TREATMENTS IN USE

 .Oil mg/1                    Chlorination
 .012                         Chlorination
3-94                          None
 .022                         Chlorination
 .011                         Chlorination, Rapid Sand,
                                Filtration, Fluoridation
 .022                         Chlorination
 .023                         None
 .108                         None
 .012                         Chlorination
F.4  Chromium

     Aqueous cadmium occurs in the^III state as Cr-^ and in
the VI state as chromate Ion (CrO^~).  Chromate is regarded
as the more toxic of the two species.  The only datum on
chromium removal by conventional treatment shows an average
of about 30 percent removal of total chromium (Cr3+and CrO^~
ratio not measured) by lime and alum coagulation, settlement
and filtration.1  Cr^  should be totally removed through
formulation of Cr(OH)3 (Ksp = 10~31) and CrO^~ should be
unaffected.  Cation exchange would similarly remove Cr3+but
not CrOJj .   Unfortunately, it is the latter species that
needs control.  One possibility would be to add NapS or
The sulfide would act to reduce Cr02~ to Cr3+ and then
precipitate Cr(OHK-  The excess sulfide could be subsequently
destroyed by Chlorination.

     The CWSS data base shows nine systems In violation of
the chromium standard (p.05 mg/1).  Details may be found in
Table F-2.
      G.M.  Zemansky, "Removal of Trace Metals During
Conventional Water Treatment," J. Am. Water Works Assn, 66,
606 (1974).
                           F-3

-------
                          TABLE F-;
                     CHROMIUM VIOLATIONS
  LEVEL mg/1
0.051

0.060
0.079

0.074
0.073
0.200
0.079
0.62
0.072
TREATMENTS IN USE

Chlorination, Coagulation,
  Rapid Sand Filtration
None
Aeration, Rapid Sand
  Filtration
Chlorination
None
Chlorination
Chlorination
Chlorination
Chlorination, Rapid Sand
  Filtration
P.5  Cyanide

     Aqueous cyanide occurs as the free ion, CN",, and
complexed with heavy metals (for example, Fe(CN)2~~.   The
free ion is acutely toxic, the complexes generally less so.
However, the complexes can act as precursors of free
cyanide; for example (Fe(CN)g~ releases CN~ under the
influence of sunlight.   Cyanide can be destroyed by
Chlorination or ozonolysis.  Ozonolysis will also destroy the
cyanide content of Fe(CN;i~ and Fe(CN)|~.
                        b            D
F.6  Lead
                                      + 3
     Aqueous lead occurs as the ion Pb'J.  Lead contamination
of drinking water can occur from automobile exhaust and
smelter emissions, industrial discharges of lead contaminated
water, and lead leached from landbearlng rock.  Probably the
most important source Is the lead piping in some older water
distribution systems.  Appreciable corrosion of such pipes
can occur under some conditions of water alkalinity and pH.
According to equilibrium studies,1 the solubility of lead In
      J.D.  Hem and W.H.  Durum, "Solubility and Occurrence
of Lead in Surface Water,"  J. Am. Water Works Assn., 65,
562 (1973).                  	

-------
water is under 10ug/l for high pH (>_8.0) and alkalinity
(100 mg/1 as CaCOo).  Thus, pH control would appear to be an
effective method both for removal of lead at the treatment
plant and for prevention of the corrosion of lead pipes.
Cation exchange would remove lead at the treatment plant,
but would probably enhance lead pipe corrosion through
removal of Ca   and prevention of a protective coating of
CaCOo inside lead pipes.  Coagulation has been found to be
ineffective.

     Of all the heavy metals studies in the CWSS, lead was
responsible for the most violations, i.e. 40.  These are
detailed in Table F-3.
F.7  Mercury

     The aqueous chemistry of mercury is quite complex.  In
addition to the free ions, Hg2   and Hg  , there are complex
ions, such as HgOH+, soluble neutral species such as HgCl2
and Hg(OH)2, and organic mercurials such as CHoHg"1" (methyl
mercury).  The latter is probably the most toxic of the
aqueous species.

     The complexity of the water chemistry of mercury would
make a priori prescriptions of treatment practices both
difficult and unreliable.  Fortunately, there exists a
detailed experimental study of the problem.I?2  in this
study, samples of raw Ohio River water, raw Glendale River
water, Ohio well water, and Cincinnati, Ohio tap water were
spiked either with HgCl  or CH^HgCl and treated in jar-test
procedures. Alum coagulation resulted in up to 60 percent
removal of HgCl  and up to 30 percent removal of CH^HgCl,
the higher percentages corresponding to greater initial
turbidity.
     J-G.S. Logsdon and J.M. Symons, "Removal of Heavy Metals
by Conventional Treatment,"  pp. 225-56.

     2G.S. Logsdon and J.M. Symons, "Mercury Removal by
Conventional Water Treatment Techniques," J. Am. Water
Works Assn. , 65_, 55^ (1973)-
                               P-5

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    TABLE P-3



LEAD VIOLATIONS
Sample Prom
Level Treatments in Use Distribution System
0.075 mg/1
0.081
0.229
0.078
0.088
0.118
0.114
0.05^
0.179
0.386
0.147
0.069
0.644
0.324
0.101
0.074
0.497
0.060
0.128
0.138
0.070
0.078
0.108
0.072
0.320
0.063
0.098
0.052
0.152
0.273
0.130
0.052
0.057
0.096
" 0.074
0.073
0.118
0.076
0.055
None
Chlorination
None
None
Chlorination
Chlorination
None
None
None
None
None
Chlorination
None
Chlorination
Chlorination
None
Chlorination
Chlorination
None
Chlorination, Aeration, Rapid
Sand Filtration
Chlorination, Rapid Sand
Filtration
Chlorination, Aeration,
Coagulation
Chlorination
None
None
Chlorination, Coagulation,
Rapid Sand Filtration, Set-
tlement, Taste and Odor Control
Chlorination, Coagulation
Aeration, Rapid Sand Filtration
Settlement, Taste and Odor
Control
Chlorination
Chlorination, Coagulation,
Aeration, Rapid Sand Filtration,
Settlement
Chlorination
Chlorination
Chlorination
None
None
Chlorination
None
None
Chlorination
None
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
Yes.
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes-
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
      F-6

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       TABLE  F-4
NITRATE  VIOLATIONS
Level (as NO^)
j_
54.9
97.5
1)9.1
1)9.2
48.7
79-5
45-7
50.5
1)8.4
75. 1
47.1)
1)6.2
1)6.0
77-0
46.1
60.6
55-3
49-5
51.1
61.1
97.4
61.7
45.3
46.0
O.Ollmg/1
0.014
0.018
0.018
0.065
0.016
0.061
0.011
0.012
0.017
0.013
Treatments In Use
None
Chlorlnatlon
None
Chlorination
Chlorinatlon
Chlorination
Chlorlnatlon
Chlorination
Chlorination
None
None
None
None
Chlorination, Rapid Sand
Filtration
Chlorination
Chlorination
Chlorination
None
Chlorination
Chlorination
Chlorination, Rapid Sand
Filtration
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
None
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
None
None
None
                            Ground Supply

                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes

                               Partially
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes

                               Yes
                               Yes
                               Yes
                               Yes
                               No
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
                               Yes
      F-7

-------
Ferric sulfate coagulation turned out to be somewhat more
effective, especially for HGClp in low turbidity water.
Lime softening (pH 10.7-11.1) was effective in removing
about 70 percent of the HgCl?, independent of initial
mercury concentrations ranging from 1 to 25 yg/1.  However,
no CH^HgCl was removed.  Activated carbon, in both powdered
and granular forms, was effective in removing both HgCl  and
CH HgCl.  A dosage of powdered carbon of 1 mg/1 for each
O.i yg/1 of mercury was sufficient to reduce mercury to a
final concentration of 2 yg/1.  In all three processes
the removal mechanism seemed to be adsorption.

     There are no data on mercury content in the CWSS.
However, in an EPA survey-"- of 273 water supplies, only three
supplies exceeded the EPA standard of 0.002 mg/1, and 26l
supplies had concentration under 0.001 mg/1.
F.8  Nitrate
     Nitrate occurs in water as the free ion, NOo.   It has
little tendency to form complexes with metal ions,  and all
its salts are appreciably soluble-  Therefore, conventional
water treatment practices would seem to be ineffective in
Its removal.  Chlorination has an effect on its concentration
inasmuch as it will oxidize any NOo (nitrite) that  is present
to nitrate.  Since nitrate is an anion, catonic exchange
will not remove It from solution.

     The CWSS data base shows 24 violations of the  1962
standard (45 mg/1).  This Is equivalent to 10.1 mg/1 NOo as
N, and since the new proposed standard Is 10 mg/1 NOo as N,
these represent essentially the same standard.
F.9  Selenium

     Aqueous selenium occurs, as selenite (SeO~  oxidation
state IV) and selenate (SeOr, oxidation state^IV).  Their
redox reactions have slow rates; the likelihood of converting
one species to the other during water treatment is small. In
      R. J. Hammerstrom, et al.,  "Mercury in Drinking Water
Supplies," J. Am. Water Works Assn., 64, 60 (1972).
                            F-8

-------
jar test studies1 it was found that selenite was best
removed (60-80/&) by ferric sulfate coagulation as pH 7.  Lime
softening (pH=9-l) achieved 20-40 percent removal.  Alum
coagulation and activated carbon were ineffective. None of
these methods were effective in removing selenate.

     The authors observed that selenium is largely a ground
water problem, and since ground waters are usually of a
reducing nature, any selenium found would be in the reduced
(or selenite) form, and would therefore be subject to ferric
sulfate coagulation.

     The CWSS lists 11 selenium violations (selenium  >0.01
mg/1).  These are detailed in Table F-5.
P.10  Silver

     Aqueous silver occurs as the free ion Ag  and as a
number of complexes, the most important of which is
Ag(NEL)p. Assuming chemical equilibrium, a concentration of
chloraae of 10 mg/1 is sufficient to hold the free silver
ion content below the maximum permitted level of 0.15 mg/1.
Chlorination, therefore, would be of some effect in removal
of silver from drinking water, since chlorine gas generates
chloride ions when it is dissolved in water.

     The CWSS lists no violations of the silver standard.


F.ll  Fluoride

     Fluoride ion, F~, occurs as a natural constituent of
drinking water in many parts of the country and is often
added to water supplies where it does not occur naturally.
This has been done as a public health measure, as water
containing approximately 1 mg/1 of F~ has been found to
suppress tooth decay in children.  Substantially higher
concentrations of F~ (>3 mg/1) are disfiguring, however,
giving a brown or black "mottled" appearance, and are thus
not permitted under EPA water quality standards.

     Removal of excess F~ is a difficult problem.  The two
standard water treatments which have some potential for
removal are activated alumina and bone char; even these
     1G.S.  Logsdon  and  J.M.  Symons,  "Removal  of Heavy
Metals by  Conventional Treatment,"  pp.  225-56.

                            F-9

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    TABLE F-5






SELENIUM VIOLATIONS
Level
(mg/1)
0.011
0.014
0.018
0.018
0.065
0.016
0.061
0.011
0.012
0.017
0.013
Treatments in Use
Chlorlnation
Chlorination
None
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
None
None
None
Groundwaters
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
     F-10

-------
treatments do not always work.  The CWSS reports1 that
three water systems attempted to remove fluoride but that
two of those attempts were unsuccessful.

     The CWSS lists 35 systems in violation of the 1963 PHS
standards for fluoride.  The maximum permitted levels range
from 0.8 to 1.7 mg/1, depending on annual average high
temperature.  Details are shown in Table F-6.
F.I2  Carbon Chloroform Extractibles

     Carbon Chloroform Extractibles (CCE) are organic
chemicals with little or no polarity and limited water
solubility. Some examples are benzene, carbon tetrachloride,
polychlorinated biphenyls (PCB's), phenolics, and many
pesticides.  Many problems of color and odor in drinking
water are related to CCE content.  Treatment with activated
carbon seems to be an excellent method for removal of CCE
(activated carbon is used as an agent for the collection of
CCE samples). Treatment by chlorination can have mixed
results.  It is well known that phenol when treated with
limited amounts of chlorine reacts to form chlorinated
phenols with intense disagreeable odors.  Excess chlorine,
however, will decompose these chlorinated phenols, the
products probably including carbon tetrachloride and other
chlorinated hydrocarbons.  The result is a "New Orleans
drinking water problem", in which chlorination has generated
potential carcinogens from more or less innocuous organic
precursors.

     Although these arguments seem to suggest that chlorination
would be avoided where raw waters contain appreciable amounts
of organics,  it is possible that excess chlorination would
promote the subsequent removal of organics by activated
carbon adsorption.  Some of the methyl chloroform found in
the New Orleans water supply may have resulted from the
action of chlorine on ethyl alcohol, a substance not removed
by carbon adsorption; methyl chloroform, however, is removed
by carbon adsorption.  It would therefore be worthwhile to
investigate the effectiveness of the following sequence of
processes for treating raw waters with organic contamination:
1) excess chlorination, 2) carbon filtration, 3) chlorine
disinfection.  (Step 3 Is necessary because carbon adsorption
tends to remove chlorine.)
      Community Water Supply Study, "Analysis of National
Survey Findings,"  pp. 225-56.

                            P-ll

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                         TABLE F-6
                    FLUORIDE VIOLATIONS

Level
(mg/1)
1.98
3-60
2.60
3-10
3.00
2.65
3-70
3.00
2.00
3-70
1.71
4.40
1.90
3.00
1.65
1.90
1.60

Treatments in Use
Chlorination,
Fluoridation
Chlorination
Chlorination,
Fluoridation
None
None
None
Chlorination
None
None
Chlorination
Rapid Sand Fil-
tration, Chlorina-
tion, Aeration
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination ,
Rapid Sand
Filtration
Chlorination

Level
(mg/1
1.52

1.80
1.48
3.60
3.40
4.00
2.20
1.70
1.81
2.43
3.04
2.82
1.90
2.26
2.37
2.00
8.00
1.85
1.72
Treatments in Use
Chlorination,
Coagulation, Rapid
Sand Filtration

Chlorination
None
None
None
Chlorination
Fluoridation
None
Chlorination
None
None
Chlorination
None
Chlorination
None
None
Chlorination
None
None
     The CWSS lists 22 CCE violators of the proposed EPA
standard of 0.7 mg/1.   Although CCE is primarily a surface
water problem as illustrated by these data, some ground
supplies may also be contaminated.   The details are in
Table P-7.
                            F-12

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   TABLE F-7





CCE VIOLATIONS

Level
(mg/1)
0
2
0
1
2
0
0
1
3
0
1
0
0
1
0
0
I
1
2
0
1
.854
.485
.727
.846
.62
.804
.830
.120
.278
.728
.339
.990
.782
.972
.894
.843
.02
.010
.86
-992
.210
Treatments in Use Grouridwater
Hone
None
None
None
None
Chlorlnatlon
Rapid Sand Filtration^
Chlorinatior , Aeration
None
Chlorl nation
Chlorination
Chlorination
Chlorination
None
None
None
Fluoridation
None
Fluoridation
Chlorination
None
Chlorination
No
No
No
No
No
No
No
No
No
No
No
No
Mo
No
No
No
No
No
No
No
No
      F-13

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                           APPENDIX G

         DATA BASE AND COST ESTIMATES OF WATER TREATMENT
     This appendix presents the development of cost functions
for water treatment processes used in this study.  The origins
of the data base utilized are also included.  This description
should provide the necessary background to the cost estimates
for water treatment to meet the Proposed Drinking Water
Regulations.

     The description is divided into two main sections.
Section G.I illustrates the cost functions and estimates for
larger water supply systems (systems that supply more than
1,000 m3/day [264,000 gpd]).  Section G.2 describes the cor-
responding costs for small systems.  The need for such a
distinction stems from the fact that cost functions for large
supply systems are not very valid for systems of smaller
capacity.  Consequently, different sets of functions were
devised for the processes being considered, which include the
following:  (1) clarification (consisting of direct filtration),
(2) chlorination, (3) activated carbon, (4) ion exchange,
(5) lime-soda softening, and (6) activated alumina.

     Prior to the presentation of these cost functions, the
associated assumptions are stated below:

     1.   To estimate the quantity of water production,
          the average daily production shown in Table k-2
          was used for each population category;

     2.   Electricity costs 3 cents per kilowatt-hour;

     3.   Land costs $202 per hectare;

     4.   Capital costs generally included expenses for
          equipment purchase, installation, construction,
          design engineering study, land, site develop-
          ment, and construction overhead.  Operating
          and maintenance costs (O&M) Include labor,
          supplies, materials, chemicals, electric utility,
          and general maintenance;

     5.   The interest rate is 7 percent.
                                G-l

-------
G.1  Large System Costs

     The cost functions for large water supply systems were
generated primarily from the results of the report by D.
Volkert & Associates.1  These functions, which have been
compared favorably with another report,2 are summarized in
Table G-l.  The first column lists the treatment processes.
The second column lists the cost estimates, and the third
column indic-ates the appropriate comments for that process.
It should be noted that the cost estimates are for individual
processes; cascading them in series may lead to lower costs.
Moreover, these functions are only valid for plants with
capacities between 1,000 m3/day (264,000 gpd) and 300,000
m3/day (78 mgd).  For the cost functions, the following
keywords are used:

       C = Construction cost

      OM = Annual O&M costs, excluding labor

       A = Area of land in hectares

      SD = Site developemnt cost

       L = Annual labor cost

     OML = Annual O&M costs, including labor

       Q = Plant capacity in m^/day

Unless specified, these cost estimates are in terms of  1973
dollars.  They have to be adjusted to 1975 dollars using the
discount factor.
      David Volkert & Associates, Monograph of the Effectiveness
and Cost of Water Treatment Processes for the Removal of Specific
Contaminants, Vol. I, Technical Manual  (Bethesda, Maryland:
David Volkert & Associates, 1972).

     2
      I.C. Watson, Study of the Feasibility of Desalting
Municipal Water Supplies in Montana.  Manual for  Calculation
of Conventional Water Treatment Costs,  Supplement to Final
Report  (Arlington, Virginia:  Resources  Studies Group,
1972).
                               G-2

-------
                                             TABLE G-l


                     COST ESTIMATES  OP  TREATMENT PROCESSES FOR LARGE SYSTEMS
TREATMENT
PROCESS
COAGULATION &
SEDIMENTATION
FILTRATION
CHLORIMATION
COST ESTIMATES
C = 45000(Q/1000)°'796
SD = 40000(Q/1000)°'66
L = 6400(Q/1000)
OM = 2700(Q/1000)
A = 0.07MQ/1000)
C = 64000(Q/1000)°-676
SD = 11000(Q/1000)°'761
L = nooo(Qyiooo)°"9i'8
OM = 14149 (Q/1000)°'9i|8
A = 0.026(Q/1000)
Equipment cost = 3700 (Q/1000 ) ° ' 533
Enclosure structure cost
= 800(Q/1000)
Cost of chlorine per year
= ($0.55/kg) x 365 Q x
(dosage in rng/1) x 4.01 x 10~~-Y0.7
COMMENTS
1. Flash water
2. Usually follov/ed by
filtration
1. Rapid sand filter
for a rate of
10 m3/m2/day
1, Use solution feed
2. Assume 4 mg/1 dosage
I
LO

-------
                                         TABLE G-l
                COST ESTIMATES OF TREATMENT PROCESSES FOR LARGE SYSTEMS  (CONT.)
           TREATMENT
            PROCESS
      COST ESTIMATES
        COMMENTS
        ACTIVATED CARBON
C for absorption
  = 23000(Q/1000)
                                             0.849
1.  Granular carbon used.
2.  Three month reolacement
                            C for carbon regeneration
                              = 12000(Q/1000)°-656
                            OML = 21000(Q/1000)
                                               0.146
i
-tr
OM supplies - 9000(Q/1000)
Annual fuel cost
  = 300(Q/1000)°'6°6
Granular carbon replacement
cost per year = 300(Q/1000)
                                                      0.169
        ACTIVATED ALUMINA
C = 22000(Q/1000)°<631
OML = 3200(Q/1000)°'7 5
Chemical cost for each mg/1 of
fluoride removed per year
  = 2300(Q/1000)

-------
                                      TAtiLF, O-l
         COST ESTIMATE."  OF  TREATMENT PROCESSES FOR LARGE SYSTEMS  (GOUT.
  TREATMENT PROCESS
        COST ESTIMATES
   COMME1ITS
I0;i EXCHAJIOE
pH Control
  C = 0.22 x 10JfQ/100)°'70^
 3D = 52000CQ/100Q;0'666
OML = 16000 rq/lOOO)0**17
 OM Supplies = O.OlC
 Resin replacement cost =  0.03C
 Annual power cost
    - 0.03 x 3^0 x 3^5
      z (Q/1000)°-d7
  A - 0.03CQ/1000)
  Annual chemical cost
    = 5 /. 10"5 x 365Q
      x Cpprn reduction)
 Cost of lime = 2
-------
G.2  Small System Costs

     In this study., a small system is considered to be one
producing less than 264,000 gallons (1,000 m3) per day.
Assuming a water requirement of 100 to 150 gallons per
capita per day, the flow rate range of interest is from
about 2,500 gallons per day O 10 m3/day) to about 300,000
gpd (-1,100 m3/day).

     Cost information for small systems was obtained through
(1) personal conversation with several water treatment
equipment manufacturers and suppliers, and (2) a study of
conventional water supply costs conducted by Control Systems
Research, Inc. for the Office of Saline Water, U.S. Department
of the Interior.1

     The approach used In requesting cost information from
vendors was as follows.  First, each manufacturer or supplier
was queried as to the exact nature of his business.  This
allowed obtained cost data to be qualified in terms of
actual type of equipment and services supplied for a stated
price.  The various business functions of the vendors contacted
included suppliers of $40 cartridge filter products for home
use, manufacturers of treatment unit "packages" for commercial/
industrial use, suppliers of complete clarification systems
for small municipal systems and/or industrial use, and
suppliers of treatment systems designed to handle site-
specific problems.  Confidence in survey results was gained
by considering responses only in terms of the vendor categories
from which the responses came.

     Secondly, each vendor was asked to provide general cost
Information (capital, installation, O&M) for equipment
customarily used in water treatment applications within the
flow rate range of interest.  It was acknowledged that
facilities and equipment provided in a given application is
determined from several factors including;  (1) raw water
quality, (2) desired product water quality, (3) flow rate,
(4) existing facilities, (5) system and equipment flexibility,
(6) operation and maintenance needs of equipment, and other
site-specific characteristics.
      I.C. Watson, Resources Studies Group, CSR, Inc.,
Manual  for Calculation of Conventional Water Treatment Costs
(Washington, D.C.:  Office of Saline VJater, U.S. Department
of the Interior, March 1972).
                             G-6

-------
     Since site-specific factors are not easily quantified
on a general basis, vendors were asked for a general indication
of costs.  Responses were therefore based on either general
equipment catalogue costs or actual vendor experience in
providing facilities for small systems.

     Information received from vendors was supplemented with
cost data contained in the aforementioned CSRl study, which
was based largely on equipment cost information provided by
vendors.  The GSR report was prepared with an emphasis on
developing cost curves for systems used in municipal appli-
cation and was designed to provide a means for estimating
the costs of conventional treatment systems on the basis of
individual unit operations.  Cost functions derived from GSR
data reflect 1972 prices and are thus multiplied by the
appropriate factor in order to present results in 1975
dollars.  A 7 percent interest rate was assumed.

     Cost estimating functions for small systems are presented
below in tabular form with appropriate comments regarding the
equipment and services represented by each function.  A list
of vendors contacted is then presented.  The following
nomenclature is used:

       C = Capital equipment cost

       I = Equipment installation costs

     O&M = Equipment operation and maintenance costs, annual

     GPD = Gallons per day

       Q = Plant capacity in cubic meters per day

     GPM = Gallons per minute

      SE = Site and enclosure costs

     IMC = Initial media costs

     It  should be pointed out here that the cost curves for
small and large systems will not produce a continuous function.
The main reason for this is that each set of curves was
developed independently and perhaps under differing assumptions
      Control Systems Research  Inc. is now known as KAPPA
Systems Inc., Arlington, Virginia.
                             G-7

-------
The cost differences that occur at the small and large system
breakpoint do not materially affect the overall cost estimates
In any event, it was not within the scope of this project to
develop a single continuous function for all system sizes
covered by the Act.

     However, because of the tremendous range in system size,
from 25 persons to over 1,000,000, there are several reasons
why it may be difficult to develop a continuous function for
all systems:

     1.  Small systems can employ package plants;

     2.  Small systems generally do not require full-
         time maintenance;

     3-  Small system treatment package plants may not
         require housing facilities.
                             G-i

-------
                                            TABLE G-2

                COST ESTIMATES OF TREATMENT PROCESSES FOR SMALL SYSTEMS (CONT.)
          TREATMENT
           PROCESS
       ACTIVATED CARBON
-i -J
 i
vo
          COST ESTIMATES
C and I = 73-5 X 103[MGD] 0.845
                             = 24.4 X 10-
                          SE = 2.29 X
                                         \io-
                                              0.845
                                              0.571
O&M - [1.8 X 103(MGD)°'37]1.07

                      0.37
    = 11.73 X 10-
                                          \io
                                           COMMENTS
                                  1.  Costs for use of carbon for
                                      taste and odor control with
                                      light organic load.
                                  2.  Carbon replacement cost
                                      assumed to be 1% of annual O&M.
                                  3.  C and I are for rubber lined
                                      pressure filter vessels, piping,
                                      valves etc., but not pumping
                                      equipment.
                                  4.  O&M includes general maintenance,
                                      supplies, power, and carbon
                                      replacement.
       ACTIVATED ALUMINA
C and I - 54 X 103[MGD]°'62

    = 19-3 X


29,401
                                10-
                          0 & M = 3-8 X 103/^\   °'79
                                           \10J7
                                      C and I includes all equipment for
                                      defluoridation system including
                                      tanks piping,  valves., pumping, and
                                      housing.
                                      O&M Includes chemical costs, annual
                                      alumina charge, general repairs,
                                      media replacement.

-------
                                            TABLE  G-2

                      COST  ESTIMATES OP TREATMENT  PROCESSES FOR  SMALL SYSTEMS (CONT.)
         TREATMENT
          PROCESS
      CHLORINATION
o
i
      COST ESTIMATES
  C = (0.386)Q/(10)2'283

    = 0.751Q/(10)°'768
         COMMENTS
1.   For small systems,  solution
    feed hypochlorinators are the
    most feasible kind of disin-
    fection equipment.
2.   O&M includes power and
    chemical costs and normal
    care of hypochlorinator unit.
3.   Assumes 4 ppm Cl.
      CLARIFICATION

      (COAGULATION,

      SEDIMENTATION.,

      FILTRATION)
C and I = 1.5 X 10


    = 4.47 X 10
                                           5  GPD 0.196
                     10
                       3
O&M = 0.06  [C and I]
    C and I cost reflects complete-
    ly Automatic filtration plant
    for use in treating surface
    waters to potability standards.
    Equipment provided includes
    chemical feed,  coagulation,
    floculation, sedimentation,
    filtration, and also building
    with foundation and sanitary
    services.
    Costs reflect a municipal small
    system situation where bids on
    a clarification system would be
    received.
    Added pumping,  piping, drainage
    not provided.
    C and I and O&M estimates
    (Maint. supplies, labor,  chemic-
    al arid power costs) compare
    favorably with GSR data.

-------
                                      TABLE G-2

               ESTIMATES OF TREATMENT PROGE^CE" FOR  "MALL  SYSTEMS  (GOUT.;
    TREATMEIfT
KILT MAT 1011
f.OII K/GHAHGK
                           COST ESTIMATE,"
                                r i     -3 n -I 7
                     C = r rj.277) VUG)J'^ '

                     0 & M = (0. 101)Q/(10) "
G and I = 2 X 10
                         = ? . 5'] 6 7 10
   Gpp 0. 37

   10 3

3  Q   0.37
                                       10J

                     0 & I/I - 0.07  [C and.  I]
                         COMMENT:
                   Gosts are for filtration system
                   used for source of v/ater between
                   0-100 JTU.
                   G and I Includes filter media.
                   and vessel, pumping equipment,
                   piping, and controls for filter
                   system, and erected housing.
                   O&M includes pump power, chemical
                   costs,  rnai nt.  1 ab or .
                                                         Gosts  for unit package designed
                                                         for  industrial applications.
                                                         G  and  I  includes demineralizer
                                                         units  with automatic controls,
                                                         plastic  piping, rinse alarm.
                                                         Pumping  equipment,  pretreatrnent
                                                         equipment, chemical storage
                                                         tanks  not included.
                                                         0  &  M   involves pumping care  and
                                                         power,  chemical tanks and
                                                         chemicals, manual tank filling.

-------
                                           TABLE G-2
                COST ESTIMATES OF TREATMENT PROCESSES FOR SMALL SYSTEMS  (CONT.)
         TREATMENT PROCESS
      COST ESTIMATES
      COMMENTS
     pH CONTROL
Q
I
Cost of lime = 2
-------
                            TABLE G-3
          SMALL SYSTEM EQUIPMENT MANUFACTURERS CONTACTED
  MANUFACTURER

Baker Filtration Co.
Baroid Division, N.L. Industries
Culligan Company
Ecodyne-Craver Water Division
Envirotech, Inc.
General Filter Company
Hayward Filter Company
Hungerford & Terry, Inc.
Lea Manufacturing
Neptune Microfloc
N.Y. Mixing Equipment Co.
North American Carbon, Inc.
Roberts Filter Manufacturing Co.
Wallace & Turnan, Div. of Pennwalt
Wastewater Systems, Inc.
Water Control Equipment Co.
Westcore Associates
  LOCATION
Huntington Beach, CA
Houston, TX
Northbrook, IL
Lenexa, KY
Belmont, MA
Ames, IA
Santa Anna, CA
Clayton, NJ
Waterbury, CT
Corvallis, OR
Wakefield, MA
Columbus, OH
Darby, PA
Belleville, NJ
Chicago, IL
Houston, TX
Salt Lake City, UT
                              G-13

-------
                       APPENDIX H

         WASTES PRODUCED FOR EFFLUENT GUIDELINES


H.1  Wastes Resulting From Water Treatment Operations

     The effluent limitations imposed under PL 92-500 which
require the most sophisticated treatment of wastes resulting
from water treatment serve to Indicate present technological
capabilities for pollutant "handling."  The water treatment
technologies to be applied in meeting drinking water regulations
would produce two main effluent streams:  (1) the finished
product water, and (2) the unfinished byproducts of the
water purification processes.  The resultant water borne
wastes to be discussed are sludges from softening, coagulation,
sedimentation and filtration operations and effluents from
filter system regeneration and backwashing.

     Sludge management In water purification is a costly
activity that affects overall plant efficiency.  As supply
water quality becomes subject to more stringent regulations,
solids management may assume a determining role when choices
between alternative processes must be made.  This section
presents a brief overview of the sources, characteristics,
and methods of treatment and. disposal of water treatment
wastes.


H.2  Water Treatment Wastes:  Characteristics and Treatment

     Raw water constituents which can be removed in water
treatment include components causing objectionable odor,
taste, and color, ions causing hardness, suspended solids,
iron, manganese and colloids.  Waste-producing water
treatment processes include presedimentation, coagulation,
softening, iron and manganese removal, filtration and
dissolved solids removal.  The process or processes to be
used in a given plant are determined by existing raw water
constituents and desired product water constituents.

     Water treatment plant sludges generally have a low
total solids content and wet weight, and a high ratio of
                            H-l

-------
suspended solids.1  Depending upon the sludge producing
processes employed, sludge consists of suspended soil
particles, colloids, microorganisms, inorganic and organic
matter, and precipitates removed in coagulation, softening,
and filtration.   Sludges vary in terms of treatability,
water content, pH, and suspended solids loadings.
H. 3  Coagulation Sludges

     Sludges derived from processes using coagulation have a
very low solids concentration (  2%) which presents a problem
of water removal.  The difficulties of dewatering are
related to the gelatinous consistency of the sludge, which
may be composed of sand, silt, colloidal organic and
inorganic matter, microorganisms, chemicals used for
coagulation, and compounds resulting from chemical reactions
during coagulation.  The volume  of sludge produced by a
coagulation-flocculation plant is on the range of 1 to 5
percent of the water treated.

     Because these sludges are voluminous, thickening of
clarification sludges prior to dewatering is a common
practice.  In addition to reducing sludge volume, thickening
(typically with organic polymers) results in a more concen-
trated slurry for dewatering.  An increase in solids concen-
tration by 1 to 3 percent can result in a reduction of
sludge volume by two-thirds, depending upon the exact nature
of the sludge and the thickening program involved.

     The dewatering of coagulation sludges can be carried
out in lagoons, vacuum filters,  sand drying beds, and filter
presses.  Alum sludges are difficult to dewater in lagoons,
with only a 10 to 15 percent solids content achievable.
Further drying is needed because the dewatered sludges are
not concentrated enough for direct removal to a landfill.
The advantages of low capital costs, maintenance, and energy
use are offset by large land requirements, dependence upon
climatic conditions for effective operation, and sludge
handling expenses.
      J.W. Clark, W. Viessman, Jr., and M.J. Hammer, Water
Supply and Pollution Control, 2nd Edition,  (Scranton, Pa.:
International Textbook Co., 1971.)
                          H-2

-------
     Vacuum filtration for dewatering can achieve a filter
cake solids content of 20 to 30 percent when precoating is
practiced, and a content of 10 to 15 percent when precoating
is not practiced.  The latter allows filter cloth clogging
by metal hydroxide sludge.  Vacuum filtration is most often
used in dewatering softening sludges.

     Dewatering in sand drying beds, with added utilization
of air drying and polymeric conditioning agents, can produce
sludge cake with about 20 percent solids.  The advantages of
low labor, maintenance, power needs, capital costs, and long
useful life might be offset by high land requirements,
dependence upon climatic conditions, and the need for sludge
pretreatment and added drying.

     Filter presses for mechanically dewatering sludges have
not been extensively employed in the past, although this may
change in the future since a filter cake solids content of
40 to 60 percent is achievable.  The advantages of long
useful life, high overload capacity, and low land requirements
must be weighed against high capital costs, moderate maintenance
and energy needs, and high labor needs.  Sludge pre-conditioning
may be required in certain cases.

     Sludges from coagulation-flocculation processes have
been discharged into sanitary sewers in a number of locations,
with a reported increase in the removal of solids, BOD, COD
and phosphorous in sewage treatment primary sedimentation.
In some instances, combined sewage-coagulation sludges are
detrimental to activated sludge processes due to reduced
sludge densities.1  The potential for regionalization of
sludge treatment and a resultant lowering of dewatering
costs (economies of scale) for smaller water-treatment
plants is an important consideration for the future.

     Coagulation sludge dewatering by centrifugation is not
particularly effective, although the use of polyelectrolytes
      U.S.  Environmental Protection Agency, Development
Document for Effluent Limitations Guidelines and Standards
of Performance - On a Study of the Water-Supply Industry
(Draft Final Report):Washington, D.C., March 6, 1975-
SORI-EAS-75-103-
                            H-3

-------
to condition the sludge can improve performance.  A maximum
cake solids concentration of 15 to 16 percent is achievable
under optimum conditions.1


H.4  Chemical Softening Sludges

     The principal component of the sludges resulting from
chemical softening operations is calcium carbonate, which
contributes 80 to 90 percent of the weight of solids in the
sludge.  Other constituents include silt, organics, and
hydrated metal oxides.  The solids content of settled
softening sludges may range from 2 to 30 percent, and
dewatering is generally easier than with coagulation sludges.
Gelatinous solids may reduce the treatability of softening
sludges, which accumulate in volumes of 3 to 5 percent of
the volume of the water treated.  Lime sludges can be thickened
prior to dewatering to more than 35 percent solids.

     Depending upon the type of lagoon used in detwatering,
solids concentrations (by weight) of 20 to 50 percent can be
achieved due to the higher specific gravities of sludge
particles.  In general, however, lagooned sludge must be
further dewatered, with lagoons serving primarily as a
thickening and storage process.  Added sludge handling costs
must be considered.

     Vacuum filtration is best applied in dewatering calcium
carbonate sludges.  Filter cakes containing as much as 80
percent solids have been obtained, although this percentage
decreases as the magnesium hydroxide fraction of the sludge
increases.  For sludge derived from coagulation-softening
processes, cake solids concentrations of over 60 percent
have been achieved.

     Calcium carbonate sludges are so much more amenable to
dewatering than metal hydroxide sludges that sand bed drying
has not been widely used.  For combined coagulation-softening
sludges, sand bed dewatering is more effective as the lime
sludge portion increases.
      U.S. Environmental Protection Agency, Development
Document for Effluent Limitations Guidelines, March 6, 1975.
                           H-4

-------
     Filter press Installations for the dewatering of lime
sludge do not yet exist, but test studies indicate filter
cake solids in the 40 to 50 percent range.  This has been
achieved without pre-conditioning the sludge to enhance
dewatering.  Generally, a high sludge magnesium content
adversely affects the solids' settling success.  For
combined coagulation-softening sludges, preliminary experience
indicates that filter performance is better as the fraction
of softening sludge increases.

     Rapid settling characteristics and the large volumes of
sludge to be handled have created problems whenever softening
sludges have been discharged into sanitary sewer systems.
Problems include sewer system sludges, digester overloads,
and sludge collection mechanism damage.  Centrifugation for
dewatering lime sludges is practiced widely, particularly in
plants having a recalconing cycle.  For combined coagulation-
softening sludges, centrifuge dewatering results in a paste-
like cake having a solids content of 45 to 50 percent.
H.5  Iron and Manganese Removal Sludges

     Iron and manganese removal processes include oxidation
with or without chemical assistance, coagulation-clarification,
aeration with pH adjustment, manganese zeolite filtration,
and ion exchange.  Filtration, either in rapid or slow sand
filters or in pressure or gravity filters, following oxidation
and detention for agglomeration of particles is the preferred
technique.

     Sludges resulting from these processes are highly
colored, and of a gelatinous consistency when the ratio of
iron and manganese to silt (or other easily filtered consti-
tuents) is high.  Hence in addition to precipitate sludge
there is a problem of sludge retainment on the filter
media.   Because of their gelatinous nature^ iron-manganese
sludges can be as difficult to dewater as coagulant sludges.
Pre-conditioning by thickening to up to 6 percent solids
content prior to dewatering is generally practiced.

     The dewatering of metal hydroxide sludges can be
accomplished in precoat vacuum filters or in sand drying beds.
For the latter process the addition of polymers and concurrent
air drying may be needed for production of a disposable
filter cake.  In both processes, filter cake solids concentra-
tions of 20 to 30 percent can be achieved.  Filter press
                            H-5

-------
dewatering of these sludges is not practiced in the United
States since the usually gelatinous larger particulate
components contribute to poor dewatering.

     The discharge of metal hydroxide sludges into sanitary
sewer systems is a common practice.  Despite their differences
in composition, coagulant sludges and metal hydroxide
sludges produce similar effects when combined with sewage
sludge in waste water treatment processes.


H.6  Filter Backwash Water

     Filter backwash water may contain fine particles of
clay and silt, metal hydroxides and oxides, activated
carbon, water treatment chemicals, filter media particles,
and suspended organic materials.  Although washwater volumes
of up to 5 percent of the treated volume are common, flow
equalization is usually practiced since washwater discharges
are intermittent.

     Filter backwash streams are recycled in many instances,
sometimes after combination with supernatants from lagoons.
However, the most  common method utilized in disposing of
these wastes is direct discharge to nearby watercourses.
Where filter washwater streams are treated, lagoons and
settling basins appear to be the only processes employed.
H.7  Other Sludges or Residues

     Additional waste producing processes used in the water
supply industry include zeolite softening and various
fluoridation processes.  Brines resulting from zeolite
softening contain chlorides of magnesium, sodium, and
calcium, while fluoridation brines contain fluorides of
calcium and sodium.

     In the handling of brine wastes, lagoons have been used
with mixed success due to high salt concentrations which
retard evaporation (and which increase as evaporation
proceeds).  When evaporation is successful, residual salts
      American Water Works Research Foundation, Disposal of
Wastes From Water Treatment Plants, New York, August 1969.
                           H-6

-------
must be disposed of.  In addition, brine seepage through
porous soils can result in the mineral contamination of
nearby surface and ground waters.

     Due to the chloride ion component of brine wastes,
direct disposal to streams, lakes, or other water bodies
without significant dilution volumes can result in toxicity
problems for aquatic life, livestock, and agricultural
crops.  Although ionic strength may be increased as a result
of brine discharge to sanitary sewer systems, this disposal
method generally enhances dilution of brine wastes.  Flow
equalization equipment is needed in this case to prevent
"sludge" loading of wastewater plants.  Principal concerns
are the maintenance of the sewage plant's biological balance
and minimization of corrosion effects en plant facilities.


H.8  Additional Waste Handling Processes

     Other treatment and/or disposal processes which have
been proposed for use In the treatment of water plant wastes
include freezing, spray irrigation, land reclamation, sludge
plowing, heat drying, and specialty recovery.  Abandoned
mine as well as ocean dumping has been used as an ultimate
disposal option in some cases. -'•
H.9  Recycling/Recovery Processes

     The discussion above reveals that contemporary technology
for the control and treatment of water plant wastes consists
mainly of solids separation followed by disposal.  These are
carried out In a variety of ways — lagooning, thickening,
dewatering, disposal to sewers, drying in beds, land disposal,
ocean disposal, deep well injection, and dilution (brine
wastes).

     Recovery or recycle processes for several water plant
waste components are currently available.  The recovery of
lime, alum, brines, and some magnesium compounds and the
recycling of filter backwash water are examples of processes
which can reduce waste production as well as chemical costs.
      U.S. Environmental Protection Agency, Development
Document for Effluent. Limitations Guidelines., March 6, 1975

-------
H.10 Filter Backwash Recycling

     Backwash recycle facilities usually include equalization
equipment to keep recycle feed rates below 5 percent of the
plant raw water flow.  When clarification is practiced only the
supernatant is recycled but sludge removal facilities are
needed.  Recycling has only a minimal effect on the net
production of waste solids from a water treatment plant, and
instances of both reduced and increased coagulant requirements
have been reported.1  Odor and taste problems are a concern
when filter backwash is recycled.
H.ll Chemical Recovery

     Alum recovery processes involve sludge thickening,
sulfuric acid addition for recovery of aluminum at low pH,
separation of dissolved aluminium sulfate; aluminium
recycling to raw water, dewatered sludge neutralization
by lime addition, and landfill disposal of neutralized
sludge.  Alum recovery reduces waste solids and increases
the filterability of the residual sludge.

     The principal problems involved are the dissolution of
heavy metals and color-causing materials at low pH (2.0).
Color building in recovered alum has been reported in pilot
plant studies conducted in the United States.  Incineration
of thickened and dewatered sludge (prior to acidification)
to destroy organics has been practiced where recovered alum
is used for color removal.

     The recovery of lime in softening plants allows a great
reduction of the waste solids generated in softening processes
and also results in some cost recovery from the sale of
excess lime.  Also, the carbon dioxide released in calcination
is available for use in finished water stabilization.  The
primary contaminant of interest in lime recovery processes
is magnesium hydroxide, which, if not dissolved by carbonation
prior to calcination, is converted to magnesium oxide and
can build up as an impurity in the recovered lime.
      U.S. Environmental Protection Agency, Development
Document for Effluent Limitations Guidelines7~March 6, 1975.
                           H-8

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     Following carbonation, thickening is provided to
separate the clear magnesium bicarbonate solution and to
concentrate the calcium carbonate.  Following dewatering in
either vacuum filters or centrifuges, the sludge cake is
washed for further removal of magnesium carbonate.  Processes
for lime recovery are:  (1) rotary kiln, (2) multiple hearth
furnace, and (3) fluidized bed calcination.

     Backwash brines from ion exchange processes can be
recovered by conventional lime-soda ash softening, which
precipitates the dissolved magnesium and calcium.  The
resultant insoluble sludge can then be filtered and recycled
for reuse .
                          H-o

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                        APPENDIX I


UPGRADING PRESENTLY OPERATING WATER TREATMENT PLANTS
     The upgrading of existing public supply water treatment
plants to meet the Proposed Interim Primary Drinking Water
Regulations would have a significant impact on the economy
of the supply water industry.  The largest portion of the
immediate costs would arise due to the purchase of land and
equipment, and due to costs associated with retrofit con-
construction.  The problem is one of great magnitude:
estimates presently indicate that at least 65 percent of
existing community public water supply systems would require
chlorination, that nearly all of the estimated 230,000 non-
community supplies would require chlorination, and that
about 5 percent of the community systems would require
additonal treatment for heavy metals and turbidity, primarily
by coagulation and sedimentation.

     There are a number of specific problems which would
result from retrofitting existing plants to meet the
proposed regulations:

     1.    Retrofitting would require a sudden demand
          on raw construction materials used for necessary
          treatment equipment and facilities;

     2.    Retrofitting would require purchase of
          additional right-of-way land to facilitate new
          plant expansion;

     3.    Retrofitting requires extensive qualified
          engineering design services.  The modification
          and/or addition of treatment processes to existing
          plants would encompass problems related to flow
          characteristics, changes in chemical parameters,
          additional power requirements, equipment com-
          patibility,  efficient utilization of floor area,
          and other such problems;

     4.    Addition of  new equipment would require
          additional plant operational and maintenance
          skills and additional process monitoring per-
          sonnel.   It  could also require more extensive
          laboratory capabilities.  For example, ion ex-
          change columns must be monitored frequently to
                           1-1

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          determine percent capacity utilization, and the
          resins must either be regenerated or replaced on
          a regular basis;

     6.    Preliminary studies by the engineer to accurately
          determine those components of the supply water
          that violate the standards would need to be long-
          range;

     7,    Retrofitting equipment could require temporary
          interruption of normal operations of the plant,
          and consequent interruption of water supply;

     8.    Upgrading of plants would have to be approached
          on a case-by-case basis to meaningful.

     It  is doubtful that any state public works department
would be adequately staffed to handle the engineering and
construction responsibilities that would be required to meet
the proposed regulations.  Vermont alone has indicated that
it would need to increase its present staff six to ten times
in order to adequately implement the regulations.  For this
reason,  it is anticipated that professional engineering
consulting firms would be retained to do preliminary studies,
design,  and to oversee construction of retrofitting plants,
particularly for the larger community water supply systems.
Although the pre-engineering costs are included in the
section of this report dealing with unit process costs, a
closer look at this phase of the implementation scheme is
presented here to clarify the components of the total cost
of upgrading each project.

     The engineer retained for each specific plant suspected
of violation of the regulations would have to supply both
basic and special services.  Generally, basic services would
include  preliminary field investigations and data collection
to determine which contaminants could be considered vio-
lations  of the regulations.  In addition, report preparation,
treatment process and equipment designs, drawings, and
specifications would all be required.  Further, basic
services would Include securing bids, awarding contracts,
inspecting construction, testing and approving equipment for
acceptance, and making appraisals.  Special services
provided by the engineer might include studies, tests and
process  determinations performed to establish design criteria,
Other special services might be soils Investigations, mill,
shop and lab inspections of materials and equipment, investi-
gations  involving operation and maintenance, and overhead
                            1-2

-------
expenses, preparation of applications and supporting
documents for projects grants, and preparation of operation
and maintenance manuals.  It is assumed that alterations and
changes in existing structures and facilities would involve
more engineering work than the building of a new plant.

      Qualification and experience are of critical importance
 in the selection of a consulting engineer-  His decisions
 affect costs that influence the economic feasibility of the
 project undertaken.  Retaining a competent design firm might
 require higher compensation initially, but would result in
 substantially lower overall project costs in the end.

      Compensation for the engineering of upgrading water
 supply treatment facilities would most likely be on a cost-
 plus-fixed payment basis.  This method of payment is usually
 performed on projects in which the actual costs and scope of
 the projects cannot be accurately determined.  The preliminary
 studies necessary to determine which contaminants of the
 effluent water violate regulations require that work begin
 before the actual problem is known.  The engineer is re-
 imbursed for the individual elements of salary, overhead,
 and direct non-salary expenses, and in addition receives a
 fixed amount for contingencies and profit.  Up to 40 percent
 of this cost would be for the preliminary studies phase, up
 to 80 percent for the design phase, and up to 10 percent
 would be for overseeing construction.

      The total cost of a retrofit project can initially be
 estimated based on the projected construction costs to be
 incurred.  Typical ranges of categorical costs to the
 project are:
      1.   Estimates of Construction Costs     100

      2.   Contingencies                     10-25

      3.   Engineering Costs  (Basic and
           Special Services)                  6-18

      4.   Legal and Administrative Costs      2-3

      5.   Financing Costs                     1-5

      6.   Interest During Construction        4-8
                            TOTAL             123-159
                            1-3

-------
Non-construction costs are a significant part of total
project costs, but in general the larger projects would show
lower proportions of such non-construction costs.  Consideration
must also be given to costs incurred by delays in material
deliveries and construction start-times. Indices of inflationary
trends are available to evaluate this impact, and can be
found in Engineering News Record's Weekly Index of Construction
Costs, the Handy-Whitman Index, and the BLS-Labor Cost
Index.

     The high cost of upgrading water treatment plants to meet
the proposed regulations points out the need for available
investment contingencies and economizing plans.  The former
would require a dependence on Federal revenues and Federal
cost-sharing programs.  Unfortunately, while Federal grants
have been successful in the past in eliciting investment
response for wastewater treatment facilities, that effectiveness
has steadily declined.  This may be an indication that
grants given to the supply water industry should be based on
a priority basis, with funds directed to the most useful
projects first.  In addition, the states would be responsible
for a share of the costs of upgrading.  Wherever possible,
the states would have to utilize their own personnel for
monitoring, engineering, design, and general implementation
of the projects necessary to insure that regulations are met.

     It may well be necessary for several communities in the
same locale to coordinate their implementation efforts in
order to save money.  Many water supply systems might be
able to retain professional engineering services and
construction services under a single multi-community
contract at a substantial savings to each.  While regional
efforts to establish coordinated river basin organizations
for the purpose of managing water supply quality are not
presently in wide usage, such organizations have great
theoretical advantages and may be worth further exploration.
                            1-4

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          APPENDIX J






REVISED DRINKING WATER STANDARDS

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    PART  141—-NATIONAL IN'
PRIMARY DRINKING WATER Si
Sec.  <	
141.1
141.2
H1.3
141.11
                                     REGULATIONS
                                                                               DRAFT
     Applicability.
     Definitions.
     Coverage.
     Maximum contaminant levels for In-
       organic chemicals.
141.12 Maximum contaminant levels for or-
       ganic chri'Lilcals.
141.10—Maximum—(.unt.iintnant—levcln—for
      Maximum cnn^rnunYrrc
       turbidity^	  ^
      Maximum mlcroblologicaT
                                                    Subpart A   - Maximum  Contaminant  Levels
111.1 ^
       nant levels.
      Substitution of residual
        measurement for  total conform
        measurement.
      Mlcrobioloclcril  contaminant  sam-
        pling and analytical requirements.
      Turbidity sampling  and anr.lytical
        requirements.
      Inorganic chemical  sampling
        analytical requirements.
      Pesticide and organic chemical.- sam-
        pling and anp.lvt.cal requirements.
      Laboratory certification.
                              and
141.21

141.22


141.23

141.24

* A nrr
I 'L 1 .21 f_
141.31  Reporting requirements?
141.32  Public notification of variances, ex-
       emptions and non-compliance with
       standards.
141.41
141.51
      Siting requirements.
      Effective date.
  AUTHORITY: Sees. 1412. H«,-i4i§, 1450 of
 Pub.L. 93-523.                \	
 § 141.1  Applicability.
  This subpart sets forth the interim pri-
 mary drinking water s-tondnrds required.
 by  section 1412 ofv{the__Safe Drinking
 Water Act 'Pub. L. 93-523)~  —	-
 §141.2  Definitions.       	
  As used in this aubpart  the  tenn:
  Q.Ul.27  Alternative analytical techniques.
  'Ul.28
  li|1.29  Monitoring consecutive public water  systems
~f lUl. 33  Record Maintenance
           Variances and  Exemptions^
          and
   (a) "Act" means" the Safe Drinking
 Water Act, Pub. L. 93-523.
                                     regulations
                                    •the Public Health  Service Act, as  amended by


                                     PART
           teu-systeift— which— senres--a -
                                          Public  Health Service Act, as  amended by

                                     (b)  "Community water  system"  means a public water system

   (c) "Contaminant" means any physi- which  has at  least  fifteen service connections  or serves  a
 cal, chemical, biological, or radiological
 substance or matter in water.
                                  non-transient population.   The  term  includes public water

                                  systems  providing water to residential communities, schools,

                                  factories, office buildings and other facilities  in which

                                  the same 25 or more  people  regularly  consume the drinking

                                  water.   The term does not  include public water  systems  which

                                  provide  water only  to gas  stations ,  restaurants,  campgrounds

                                  and those which are carriers which convey  passengers in

                                  interstate commerce.
                                                J-l

-------
  (d)  "Maximum  contaminant level"
means the maximum permissible level of
a contaminant  in water which is deliv-      ,
ered to the f-rcu nowftg-onttet of  the     Service connection
ultimate user of a public  water system.
/(e) "Person" means an individual, cor- ,                                           .       „  ,,         .       ...  ,
poration, company, association, partner-   ~ It  is  anticipated  that  a portion of  the  samples  will be
ship, State,  municipality,  or  Federal

"^"Public water system" means a sys-     taken  from the  consumers taps.
tern for the  provision to  the public of
piped water for human consumption, if
such system has at least  fifteen service
connections or  regularly serves an aver-
age of at  least twenty-five  individuals
daily at least tH*ee  months  out of  the     two
year. Such term includes <1)  any collec-
tion, treatment, storage, and distribution
facilities under  control of the operator
of such system and  used primarily in
connection with such system, and  (2)
any collection  or pretreatmcnt storage
facilities not under such  control which
are used  primarily in  connection with
such system.
  (g)  "State" means the  agency of the
 State government which has jurisdiction
 over public water systems.  During  any
period when  a  State docs not have  pri-
 mary enforcement  responsibility,   the
 term  'State'  means  the  Regional   Ad-
 ministrator,  Environmental  Protection
 Agency.
  (h) "Supplier of  water" means  any
 person who owns  or operates a public
 water system.
 § 141.3  Coverage.
  The interim primary drinking water
etatttlards under this subpart shall apply
 to each public  water system in a State,
 except that such standards shall not ap-
 ply to a public  water system which—
  (»' ConsM.<; only of distribution  and
 storage facilities (and does not have  any
 collection and  treatment facilities);
  (b) Obtains all of its water from, but
 Is not owned or operated by, a public
 water system to which such regulations
 apply;
  (c) Does not sell water  to any person;
 and
  (d) Is not a carrier which conveys pas-
 sengers in interstate commerce.
 §141.11   Maximum  contaminant levels
     for inorganic rlicmical*.
   (a) The following  are  the  maximum
 contaminant levels  for inorganic chem-
 icals:
                               Level
 Contaminant:                    (mg/l)
  Arsenic  	 0.05
  Barium  	 1.
  Cadmium 	  0.010
  Chromium 	  0.05
  Cyanide	 0.2
  Lead	 0.05
  Mercury	 0.002
  Nitrate  (as  N)	 10.
  Selenium 	 0.01
  Stiver			 0.05

  
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responding  concentration  of  fluoride
r.hall not bo exceeded:
                              Li.3 toCU.5
                                     2.4
                                     2.2
                                     2.0
                                     1.8
                                     1.6
                                     1.4
The requirements of this paragraph (b)
do not, apply  to public water supplies
serving only educational institutions.

Ir**)
                               level for
                             anic chem-
                              bon chlo-
                                      in
  The maxim
the total concez
icals, as d
roforjiv
 § }-4^-rt3~  Maximum  contaminant  levels


  The following are the maximum con-
 taminant levels for pcotierde»t-

 (a)  Chlorinated Hydrocarbon:
                               Level mg/l

  Chlordane (cis and trans) (1,2,4,5,-
    6,7,B,8  -  Octachloro   3a,4,5,7a-
    tetrahydro-4,7-niethanoinda.n)    0.003
  Endrin  (1,2,3,4,10,10   Hexachloro-
    6,7    epoxy   1.4,4a,5.6,7.8,8a-
    octahydro-l,4-endo,   e n d O-5.8-
    dUnctha.no naphthalene)	0.0002
  Heptachlor   f 1,4.5,6,7,8,8-H e p ta-
    chloro-3a,4-,7,7a-tctrabydro  4.7-
    niethanolnd^ne) 	0. OG01
  Heptochlor  Lpoxlde   (1,4,5,0,7.8.8-
    Heptachloro - 2,3-cpoxy-3a,4,7,7a-
    tetraliydro-t,7-methanom
-------
  tH Wlicn the supplier  of water  cm-
ploys  tho  membrane  filter  UThruque
pursuant to  § 141.21 (a)  the   coliform
densities  shall not  exceed oiu- per  100
milliliters rus the arithmetic mean of all
samples examined per month; and either
  tH Four  per 100  milliliters  in more
than one  standard  sample \vheri  less
than 20 are examined per month: or
  (yfl  Four per 100  millililers  in more
than five percent  of  the standard sam-
ples when 20  or more are  examined  per
month.
  (2) (H When the supplier of water em-
ploys the fermentation, tube method and
10 milliliter standard portions  pursuant
to § 141.21, conforms shall not be pres-
ent in more than  10  percent of the por-
tions in any month;  and either
  4A*- Three  or more  portions intone"
sample when less  than 20 samples  are
examined per month; or
  (J5*) Three  or more  portions in more
than five percent of the samples if 20 or
more samples are examined per month.
  WW—When the supplier  of water  em-
ploys the fermentation tube method and
100 milliliter standard portions pursu-
ant to  § 141.21 (a> coliforms shall not be
present in  more than 60 percent of  the
portions in any month; and either
   Five or  more portions  in  more
than  one sa.mple  when less  than  five
samples are examined; or
  £B') Five or  more portions  in  more
than  20  percent  of  the samples when
five samples or more are examined.
          supplier of  .water-shaft
vide VrliTer-iiiwhTch there>l*ftTr*be  no
greater than SoTT&i'Sjyjjerrtsper one  mil-
liliter  as  dett««rTc
§ 141.16  Sub&liluliuii of rcsijiul  culo-
    rine measurement for totiil coliform
    measurement.            	
  (a)  The supplier—&f—plater' may, with  "~
the approval of the Statev/substitute the
use of chlorine residual monitoring for
not more than 75 percent of the samples
required to be taken by § 141.21'bi, pro-
vided  that the supplier of  water takes
chlorine residual samples at points which
are representative  of  the  conditions
within  the  distribution system  at the
frequency of at least four for each sub-
stituted  microbiological sample.  There
shall be at least daily determinations of
chlorine residual. Measurements shall be
made  in  accordance  with  ''Standard
Methods," 13th Ed.,  pp 129-132.  When
the supplier  of water exercises the op-
tion provided in this paragraph  iai. he
shall maintain no less than 0.2  mg/1 free
chlorine in the public water distribution
system.
 \H)>  For public  \satcr systems-scr
       fewer persons, the supplie^ftiay,
with  Disapproval of the Stap^make a
total  substitution  of  rhlpXne  residual
measuremenTIqr the saXTples required to
be taken by § 14NjXfT» : Provided. That
the supplier of.X'at'^t.akes chlorine re-
sidual samoJcSat poinLswiiJch are repre-
            thc  conditionsssnthin the
distptfution  system  at the  rans^pf  one
    '*y for each microbiological s?P
                                          supplier  of water  (stet)
                                          and based upon a sanitary survey

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H'U.31. Wht
Civiscs the option ]  :<.>vit.!<.'d by JJ*J lie ?l\-.<\\ i:,;i!>iUurr :'m li-.,s than
O.o mrr/1 free c!i!oi>Jei<-al   roiilniiiiiiant
     sumplinp  anil   mini) liral  rriiiiirr-
     mcnts.                  ___ ^
   (a)  The suw>lwt--trf -wat^iJIhTlMri'ike  --operator  of  a  community water  system
coliform  density nir;u,urcmeiit.s, for the
purpose of clelcrmii'inr, compliance. with       ,      ,
§ 144^45-; in accordance with the annlyti-      -I-4-1 — L4
cal   recoinmencUuo:)s   set   forth  in
"Standard Methods lor the Examination
of Water  and  Wa.stewater,"  Aini'rican
Public Health Association. Kith Kdition,
pp .662-688. exrcpt. that only a 10U uulli-
litcr sample size shall be  employed in
the  membrane  fUt-T  technique.  The
samples shall bo t:il:cn at point*  which
are  represenLative  of  the  conditions
within the distribution system. _____
    The &u^pUtii^^P-*«4<;r4;>haTr" take   ~^ operator  of  a.  community water  system
coliform density samples at regular in-
 tervals  throughout  the month, and in
 number proportionate to the population
 served by the public water system. In no
 event shall the frequency be less than as
 set forLh below:
                       Minimum jiumbcr of
 Populatmn_$err-cd:      samples per niimth _    o^ +Q  1QOO
   •efr..to 2jOO.------.---~- ------------    2_
   2'501 to 3,300~ ________ r-TTV-'---~---.  ~~?    -1001
   3,301 104.1OO ------------------------    4
   4,101 to 4.UOO ________________________    5
   4,901 to 5.800 ________________________    6
   5.801 to 6.700 ________________________    7
   0,701 to 7.600 ________________________    8
   7,601 10 S.SOn ________________________    9
   8.501 to 9,400 _________ ........ __- _____   10
   9.401 to  10.300 _______________________   11
   10.301 to 11.100 ______________________   12
   11,101 to 12,000 _____________________   13
   12,001 to 12,'JOO ______________________   14
   1^.901 to 13.70U ______________________   15
   13,701 to 14.000 ______________________   16
   14.601 to 15,500 ______________________   17
   15.501 to 16.300 _________________ _____   18
   1G.301 to 17.200 ______________________   19
   17,201 to 18,100 ________ ..... _________   20
   18.101 to 18,000 ______________________   21
   18.901 to 19.800 ______________ ...... __   22
   19,801 to 20.700 ______________________   23
   20.701 to 21.500 ______________________   24
   21.501 to 22.300 _______ ..... __________   25
   22.301 to 23,200 __________________ ...   20
   23.201 to 24. QUO ____________________   27
   24,001 to 24.000 ....... _____________   28
   24.901 to 25.000 ____________________   29
   25,001 to 28.000 ____________________   30
   28,001 to 33.000  ____________________   35
   33,001 1037.000 ____________________   40
   37.001 to 41,000 ____________________   45
   41.001 1046.000 ____________________   50
   46.001 to 50,000 ____________________   55
   50.001 to 54,000 __ ..... _____________   60
   54.001 to 59.000 _____________________   65
   59.001 10 64.000 ____________________   70
   64.001 to 70.000 ____________________   75
   "70.0O1 to 76.000 ____________________   80
   76.001 to 83.000 ____________________   85
   83.001 to 90.000 -  __ ________________   90
   90,001 to 96.0UO _________ ___________   95
   96.001 to 111.000 _____________________  100
  111.001 to 130.000 _____________________  no
  130.001 to 100.000 _____________________  120
  1C0.001 to 190,000 ______ ...... _________  130
  190.001 to 220,000 ..... ________________  HO
  220.001 to  250.000 _____________ ...... _.  150
  250.001 to  2SO.OOO __________________ ^_  160
  290.001 to 320.000 _______________ ..... .  170
                                                                     J-5

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                                      	-,  (c)   For public water systems  other  than community

                 Mfnnnum number o/   I
population served:      samples per month     water systems,  the State  shall  establish minimum  sampling
 320,0111 to 300,000	 180
 300,0-01 to 410,000	 190
 4in,oui to 450.000	200  / frequencies.  In prescribing the number  of  samples  to  be

 600001 to 650,000	220

 Kl to 6™:™S::::::::::::::::::: "S  /  taken' the  state sha11 consider, among other factors,  the
 600,001 to 720,000	250

 K "2K::::::::::::::::::: "S    nature and  type °f the water source,  historical  data
 84o',001 to 910,000	280

 nw»i  to ro°5ao0ooV;_V:.:::;:::;:::: 300    characterizing  the water  quality,  vulnerability  of  the
 1,050,001 to 1,140,000	310
 1KO 001 to 1,230,000	320  |
 uso'.ooi  to 1,320.000	 330  i  source to accidental  or deliberate contamination, the
 {320,001 to 1,4^0,000	340
 1420,001  to 1,520,000	350  i
 1,520,001  to 1,630.000	360  |  population  served  by  the  system, the  type of treatment
 1,630,001  to 1,730,000	370  ]
 nao.ooi 'o 1,850,000	 sso  j
 i',85o.roi to 1.970.000	390  •  provided by the system, and  the  level of  the microbiological
 1,910,001 to 2.060,000	400  /                                                                          °
 2',OC0.001 to 2.270.000	 410  '
 2,270,001 to 2,510,000	420;  contaminant which  is  generally  found.

 2/750,001 to 3,020,000	 440  j
 3,020,001 to 3.320.000	 450
 3,320,001 to 3.020.000	 460
 3,020,001 to 3,900,000	470
 3,900,001 to 4,310,000	 480
 4,310,001 to 4,090,000	490  I
  5:4,690,000         	 500

  46) (1) When the conform colonies in a
 single standard sample exceed four per
 100 milliliters (§ i4U5Cai (U).  daily           /•//'./"r (/c_)
 sample:; shall be collected and examined
 from the Same sampling point until the
 results obtained from at least  two con-
 secutive samples show less than one ccli-
 form per 100 milliliters.
  (2) When  organisms of the coliform
 group occur in three or more 10 ml por-
 tions of  a   single  standard  sample          ,/ ,///LW/\
 (§ HWWftXdi-U.)), daily samples shall        / (2) 
-------
li i.; ''.'". '• i • is •••,.'. '.', bo in rf).'i-';c".;i>]'.i':''-i'

ii'..."  :.;:;.'. V. ••:• I* >n  :;h:'l! be  r-'-'-  .. c:
\:\'-'".'..: o i.. '':• .•;'. li' i.M: \\f n-":•;';_  . '• ?
!•; (•.",:•:'".;:• 0,  J.v 3.-- V -il.all be IK I.Uvd
as i'ro.;v.;^--u in 5 K! '  !. Alsu, if  '.:"•
r.o-1-iv..iV'^1 ••'•"•'• i •• co:/1  r.-d. ;-. .•••;•• •.:•'•.•
fc: i .Vii•'••.-..?:  : . •: ly.-'iK >»i-':!. !••  ;-:.!-i •'•;••
 po.--t- of jd'V.c e
 Of ^ ••lldii,io'v'i
 tern  fi.t  10
                              iforai an-
                                 (b) of
 g I 11.7.2  Tif-;,i(]ily :,a ;v,).l in <;  ;
     (a)  fJrit.opVis shall be taken at a repre-
   sentative catiy  poinUs)  to the water
   dhl.ibuliou  system  at least once per
   da;' (at. least cncc per month for sup-
   r-'•'-'• ur'v-o v;ator obtained fiov- i\,!>•?;•-\
   l>\ M'.vd sources)  for the prrjiose oT inuV.-
   i:i£ turbidity ir,c-.asvu'erne!it"s to r1ei.erui.mi;
   co;;'ip)iauce wiih 5 1 'il.-l '£• The mcasr"--
   merit  shall  be   made  in   accord'*. •
   \vith the recommendations  set forth
   ''Sl.andaul Kefhods for the Exi-aiinat
   of  Vv'L't.er and  V.'iistewater," Air:cric-.-i
   Public IleaTii Association, 13th liditlon,
   pp. 350-?i5'J i.],Tep:ielor.ietri!'. Method''.
     (b)  "in JIT- c-veii'. that such meas'jvc-
   inent indie:-tt-s tlial the niaxim'.mi alio\v-
   able limit Iicis been exceeded, the sam-
   pling n.nd uif-cRurcment siwU be. repeated
   v.'it'nii; one hour. The result;; of the Uvo
   mear;uf.:nif;'.is sh.ill be avers feel, and if
   the :•„••;•.••;!pe confirms that Uit: >.r;;'.xi;imin
   allov.'a'ijie .liiiv.t has been  exceeded, tins
   average shall be reported as directed in
   § 141.31. If the monthly average of all \
   samples nxccecls  tbe maxlmiim_allov.'a'.jle J
   lm:it^L!ii> fa i1"  slirdl t>e reported n.s rii-'
   rected in § 1-11.3200 errCb.) *
     (c)  The requirements of this  j 1-11.2:
   sh.all iu>f. iT-'i'ly to public_\yoler svsli''.-.'.'
 .  o'-! r:  ti*ajj connnunity  v,~,tt;-r Rv.itc'nit.
^Q  which use  water, obtained from vincicr-
              „,.   ^	—	'
      if  the  average of two consecutive  samples  taken 1  hr.

( apart  exceeds  5  TU,


9>which  are  not




\fonly


  For  community  water  systems  which use  water only  obtained
                                        [
  (a) rH  To c.itubiish  an initial record
of water quality, an  analyv   -f  sub-
stances for the luiri.iose of d
compliancov.'ith •<_!•',l.lM"sn»-
r>i>itml*nTv -i]l  comnmnity \vi>!
utili;'ins  Fui-fr.cc \vatcr sourer
ono jcar follo'.viiirr  the cllfctivi
this su!.';>:irt. Yin's analysis shall
pouted:'' \P:.'"  intervals.
  (-i  - •  •••.    '.s for coinniMisliy  -. .iler
sjstc:;    :'"!.:\\i ground water s
  from underground  sources,  the State may modify the sampling

  frequency  requirements of subparagraph  (a)  of  this section

      .22.   In prescribing the  number  of samples to be taken,

   'he  State  shall consider,  among  other factors, the nature

  and  type of the water  source, historical data  character-

  izing the  water qulaity,  anticipated variations in water

  quality, vulnerability of  the source to accidental or

  deliberate contamination,  the population served by the

  system,  the type  of treatment provided  by  the  system,  the

  level of turbidity contamination which  is  generally  found,
                                                                 »
  and  the  costs of monitoring  and  analysis.


    •(1) For  all


 'shall be completed
                                                                 J-7

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jhall be completed within two years fol-
lowing the elfcctive date of this subpart.
This analysis shall be repeated at three-
year intervals.  --
 (3) AHuljwsffbr public water systems")
other  than  community  water systems, /   .
whether supplied by  surface or ground I   include  only requirement  for nitrates,  otherwise  - not
wter sources, shall be completed within  j
six  years following  the effective date of  I   ,    , ,,    _
this subpart. These analyses shall be re-  )   nealtn eliect.
peated at five-year intervals.          ^
    If tho supplier of water clutorir    *
or nw been informed  by the State
the Ictel of any contaminant is
cent orNjpre of the maximuin/'fmtam-
inant  levcV he shall analyse  for  the
presence aiioViuantity of  tXat contami-
nant at least oi^ce  per uronth following
tne initial  analyses or information.  If.
after conducting ninthly testing for a
period of at leas/oncSyear, the supplier
of water clemoa^lrates t\ihe satislaction
of  the Stata^iat the  leve\of such con-
taminant/iystablc and due >o a natural
         ' the water source, iWniay re-
       frequency  of analysis  T^j- that
cq/Kfnxinant consistent with the i
  als-of-pirt'iimnh n]  of thio-
  fet If the supplier of water determines
or  has been informed by  the State that
the level of any contaminant listed in
5141.11 exceeds the maximum contam-
inant level for the substance, he shall
confirm such determination or informa-
tion by repeating the analysis within 24
hours following the initial analysis or in-
formation.  and then at  least at weekly
                         tl  fo
 sul)f.tanoo has., boon  oxreociocl, or until a
 monitoring schedule as a condition to a
 variance, exemption or enforcement ac-
 tion shall become effect ivc^The results of~l
 such repetitive testing shall be averaged /
 and reiwrted as prescribed in paragraph  /^
 (d) of this section.
  •KB- To judge the compliance of a pub-
 He water system with the maximum con-
 taminant  levels listed in $ 141.11, aver-
 ages of data shall be used and shall be
 rounded to the same number of signifi-
 cant figures  as the maximum  contam-
 inant level for the substance in question.
 Each average shall be calculated  on a
 past 12-month moving average  basis if
 less than twelve samples per year  are
 analyzed,  and on  a past three month
 moving average ba^is if twelve or  more
 samples per year are analyzed. In  cases
 v;here the maximum  contaminant level
 has been exceeded in any one sample,  the
 average concentration shall be calcu-
 lated on  a  one-month moving  average
 basis and reported  pursuant  to if 141.31.
 If the mean of the samples  comprising
 the one month moving average exceeds
 the maximum contaminant level,  the
 supplier of water shall give. public notice
 pursuant to § I4l.32ia)£! rfa)*
  "to" The provisions  of paragraphs  
 and (d) of this section notwithstanding,
 eompliance with the maximum contami-
 nant level  for nitrate  shall  be deter-
 mined on  the basis of individual analyses
 rather  than  by averages. When a level
 exceeding the maximum contaminant
 level for  nitrate is  found, the analyses
 shall be repeated within 24 hours, and if
 the mean of the two analyses exceeds the
until  the  maximum  contaminant level  is  not  exceeded in

samples taken  on two  successive  weeks,


   whichever  occurs  first.
(d)
                                                                  J-i

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\'maximum  contaminant  level, the sup-
 -plier  of water  shall report his findings
 pursuant to §§ 141.31 and 141.32(a>.
    (f) Analyses conducted to determine
 compliance with  § 141.11 shall be made
 In accordance with the following meth-
 ods:
    (1) Arsenic—Atomic Absorption Meth-
 od, "Methods for  Chemical Analysis  of
 Water and Wastes," pp. 95-96, Environ-
 mental Protection  Agency,   Office   of
 Technology Transfer, Washington, D.C.
 204GO, 1974.
    (2) Barium—Atomic Absorption Meth-
 od, "Standard  Methods  for the Exam-
 ination of Water and Wastewater," 13th
 Edition,  pp. 210-215,  or "Methods  for
 Chemical Analysis of Water and Wastes,"
 pp.  97-98,  Environmental  Protection
 Agency, Office  of  Technology Transfer,
 Washington, D.C. 20460, 1974.
    (3)   Cadmium—Atomic  Absorption
 Method, "Standard Methods for  the Ex-
 •amjnation of Water and Wastewater,''
  13th  Edition, pp.  210-215, or  "Methods
 for  Chemical  Analysis  of  Water  and
 Wastes,"  pp.  101-103,  Environmental
 Protection Agency, Office of Technology
 Transfer, Washington, D.C. 20460, 1974.
    (4)   Chromium—Atomic  Absorption
 Method. "Standard Methods for  the Ex-
 amination of  water  and Wastewater,"
 13th  Edition, pp.  210-215, or  "Methods
 for  Chemical  Analysis  of  Water  and
 Wastes,"  pp.  105-106,  Environmental
 Protection Agency, Office of Technology
 Transfer, Washington, D.C. 20460. 1974.
    (5)  Cyanide—Titration or Colorimet-
 ric  Methods,  "Methods  for  Chemical
 Analysis of Water and Wastes," pp. 40--
 48,  Environmental  Protection  Agency,
 Office of Technology  Transfer, Wash-
 ington, D.C. 20-160, 1974.
    (6) Lend—Atomic Absorption Method,
 "Standards Methods for the Examina-
 tion  of Water  and Wastewater," 13th
 Edition,  pp. 210-215,  or "Methods  for
 Chemical   Analysis   of  Water   and
 Wastes,"  pp.  112-113,  Environmental
 Protection Agency, Office of Technology-
 Transfer. Washington. D.C. 204CO, 1974.
    (7)  Mercury—Flr.meless Atomic  Ab-
 sorption Method. "Methods for Chemical
 Analysis of Water and Wastes," pp. 118-
  126. Environmental Protection  Agency,
 Office of Technology Transfer, Washing-
 ton, D.C. 20460, 1974.
    (8)   Nitrate—Brucine  Colorimetric
 Method. "Standard Methods for  the Ex-
 amination  of Water and Wastewater,"
 13th  Edition,  pp.  451--164. or  Cadmium
 Reduction Method, "Methods for Chemi-
 cal Analysis of Water and Wastes," ppV
 201-206,   Environmental    Protection
 Agency, Office  of  Technology  Transfer,
 Washington, D.C. 20460, 1974.
    (9)   Selenium—Atomic  Absorption
 Method. "Methods for Chemical Analysis
 of Water and Wastes." p. 145, Environ-
 mental  Protection  Agency,   Office   of
 Technology Transfer, Washington, D.C.
 20460, 1974.
    (10) Silver—Atomic Absorption Meth-
 od, "Standard Methods for the Examina-
 tion of Water and Wastewater," 13th
 Edition, pp.  210-215,  or "Methods  for
 Chemical   Analysis  of   Water   and
 Wastes," p. 14G, Environmental  Protec-
                                                                     J-i

-------
tlon Agency, Office of Technology Trans-
fer, Washington, D.C. 20460, 1974.
  (11)   Fluoride—Electrode  Method,
"Standard Methods for the Examination
of Water and Waste-water," 13th Edition,
pp. 172-174, or "Methods for Chemical
Analysis of Water and Wastes," pp. G5-
67, Environmental  Protection  Agency,
Office of Technology Transfer, Washing-
ton.  D.C. 204GO,  1974,  or ColoriniPlric
Method  with Preliminary  Distillation,
"Standard Methods for the Examination
of Water and Waste-water," 13th Edition,
 pp. 171-172 and 174-17G, or "Methods for
Chemical  Analysis   of   Water   and
Wastes," pp. 59-60, Environmental Pro-
 tection Agency,  Office  of   Technology
 Transfer, Washington, D.C. 204GO, 1974.
 § 141.21-  Pi'Miniih'  onil Crpanic  chem-
      icals sampling and analytical require-
     ments.
   (a) fW To establish an initial record of
 water quality, an analysis of substances
 for the purpose of determining compli-
 ance with §§ 141.12

 -teuis /\"uTFlizinisurlace   water souir.es
Kwithln_on_e  year  following  the  effective
       this subpart. This analysis shall
be repeated at yearly intervals.
  (2) An analysis fr>r community water
systems  utilizing ground water sources
shall be  completed within two years fol-
lowing the effective date of this subpart.
This analysis shall be repeated at three-
year intervals.
                              ^ «rts
           community
whether sTffJplicd  bysiu»ft!c"e  or  ground
water sources,j5j5»H^e"completed with-
in six yjenrassfgflowinsttv6ritami-
  nant level\ie shall analyzjj^Tc/r the pres-
  ence and quantity of thAtXontarrunant
  at least once  p^r nipiftic following  the
  initial  analysis oVyiU^fniation. If, after
  conducting montmVtestmg for a peri-
  od of at least ojjle yeS»r, the supplier of
  water  demonsUTites  toShe  satisfaction
  of the  StateXfwt the leveSaf such con-
  taminant>K stable and due oa a natural
          of the water source, mimay re-
          frequency of analysis r^f that
          ant  consistent  with  ch\re-
   -irements ot  paragraph (a) of this
 (l)   For all  community water  systems

-shall be completed
                                               same rationale  as  inorganics  -  not  health  effect
  or hfttbeen informed by the
  the leveXof contaminants set^Trth in
  5 141.12 excX^5 the ma:
  nant level, heNljall confixn" such deter-
  nilnation  or  infoNna*ron  by  repeating
  the analyses wilhya^CTso weeks following
  the initial ana#sis or TtSm-iiiation. The
  average of^tfe two analysesS^f in excess
  of  the-xmaxunurn contammffhi  level.
         reported as directed in §5*H1.31

   Wt If the supplier of water determines
  or has been informed by the State that
  the levcl_p_f_any.  contaminant  listed m
  5 H4rW "exceeds" the maximum contami-
                                                                J-10

-------
nant level for the substance,  he  shall
confirm such detcrminalion or Informa-
tion by repeating the analysis within 24
hours following the initial analysLs or in-
formation, and then at lea-st at we-ckly
maximum — contaminant — iovoi
Sllh^hanr-p bfi<; ltf?n -^vr-ro.-'pH Or Until B.
monitoring  schedule as a condition to
variance, exemption or enforcement ac-
tlon shall become clIective/TTie results
of such repetitive testing shall  be aver-
aged and reported as prescribed in para-
graph (e) of this section.
   (&*• To judse the compliance of a pub-
lic water system with the maximum con-
taminant levels listed in  § lfri.13, aver-
ages of data shall be used and shall be
rounded to  the same number of s;crufi-
cant figures as the maximum contami-
nant level for the substance in question.
Each average shall be calculated  on a
past 12-month moving average basis if
less than twelve  samples per year are
analyzed, and on a past  three month
moving average basis if twelve or  more
samples per year are analyzed. In  cases
•where  the maximum contaminant levels
of § K1J-3 have been exceeded in any one
sample, the average concentration  shall
be calculated on  a one-month moving
average basis and reported  pursuant to
§ 141.31. If the  mean of the samples
comprising  the one month moving aver-
age exceeds the maximum contaminant
level, the supplier of  water shall give
public  notice  pursuant to § 141. 32 (a)
             ts— and— analys
         compliance with §
be made^ts^accordance wijJij^n Im-
proved MethoJNqjDetepwJjKng Organics
in Water by ActnJ^^jPcarbon Absorp-
tion and Solye>fl?xtracft'aqi'' Paris 1 and
2, Buelora^Ct al., JournalOTsAmerican
             Association,

   tfi± Analyses made lo determine com-
pliance with  § Hl.lBta) shall be made
in accordance with "Method for Organo-
chlorine  Pesticides in  Industrial  E5u-
ents," MDQARL,  Environmental Protec-
tion Agency, Cincinnati, Ohio, November
28, 1973.
   (hi Analyses made to determine com-
pliance with  5 M1.43(b) shall  be  con-
ducted in accordance with "Methods for
Chlorinated Phenoxy Acid Herbicides in
Industrial Efiluents," MDQAKL, Cincin-
nati, Ohio,  November 23, 1513.
Cc)
 }¥•/•**-
                                             'T   Alternative analytical techniques


                                             With the written  permission  of the State, a  supplier

                                       of water may employ an alternative  analytical  technique to

                                       those required  by this subpart .    An alternative technique

                                       shall be no  less accurate  than technique required  by  this

                                       subpart.  The use of the alternative  analytical technique

                                       shall not affect the frequency of monitoring required  by

                                       this subpart.
                                                             J-ll

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 Mt.2-7  Laboratory ccrlificution.
 ,Forthe purposes of determining com-
 jlnnce with  §§ 141.21 through 141.2-1,
 |mplcs may be considered only if they
 ave l:cen analyzed by a laboratory ap-
 rovecl by the State. The approval shall
 ( contingent upon  maintenance  of
 roper laboratory methods and technical
 Impotence and upon the retention for
 ispeclion at  reasonable times of  ana-
 iUr.nl  results.  Approved  laboratories
 [all make periodic reports as required
 the State.	

 141.31  Kcporting require merits.	
|The supplier of water shall reporAoth-
•40 days following a lest, measurement
 analysis required to be made by this
1^1.29  Monitoring of  consecutive public water  systems.(new)


When  a public  water  system provides water to another public

water system,  the State may allow the  systems to  share  the

responsibilities for providing safe drinking water.  To  the

extent possible, the State may allow the system which takes


the water from the source to monitor for those  contaminants

which, if present at all, result from  contamination of  at

the  source;  and the  distributive system to monitor for

contaminants which,  if present at all,  result from

contamination  in the distribution system.  The public water

system with  the responsibility for monitoring shall also

have  the duty  to report and to notify,  as required by this

subpart,  with respect to the  contaminant for which it  is

monitoring.
                                  4-c
                                                    J-12

-------
subpart, the results of that test, measure-
ment or analysis: I'ro^idad, That I he sup-
plier of watsr shall report within 36 hours
the failure  to meet  any standards (in-
cluding failure to comply  with monitor-
ing requirements) set forth in this sub-
part. Roporto required *TI hf- mado by this
§ 111.31 chall  Ire commun'rated  to the
     , except thrt
Agencies shall
§ 141.32  Public  notification  of  var-
    - iances,  exemptions and  noncojnpli-
     ancc with standard-*.
  (a) The supplier of— water shall give
notice to the persons served by  the ptw«.
lie  water  system of  any failure on  the
part of the system to comply  with  the
requirements (including  monitoring  re-
quirements) of this subpart. The supplier-
&{ water shall give the notice required by
this § 141.32 not  less  than  once  every
three months during the  life of  the non-
compliance:
  (1) By  publication on not less than
three consecutive  days  in a newspaper
or  newspapers  of general  circulation
serving  the  area served  by such publie-
water system, which newspaper  or news-
papers shall  be  approved by the State.
With IT .p.'f.t. tfl-— thj>_pnhTLr-  •n.-gtr.r- sys_
terns oporatod by—Federal Airrn.eif=,  the
BeyspaiaeES-ci-Led in this paragraph f.hnJ]
be-ftpprored-by the
ter-;-
                  owner  or  operator of a community   \jje~tef   f* <-t $re.,
                  owner  or  operator
                  the  community
                                                        J-13

-------
  (2)  By furnishing  a  copy thereof to
the r.'ulki and television sl.uions serving
such art'.i as soon a- prarticablc but not j
later U;pn 36 hours a ft in- confirmation of ;
the iu.;iC'">;npliance ri',h respect to \vhich
theno'.icv is required; r.nd
  (31 Ky inclusion v. :in the \vater bil?s of \
the|TiinT~!.L \voler syst'.'m  at ka-.t  once"
evciy t::iec months if ;MC water bills are
issued r.t least or.cc C\>TV  three months,
and v.ith every water u:!l  if they are is-
sued le-= often. If v.\ tcr hills a.:? not is-
sued, ether means of ::cfif:cat:ou accept-
able to the .State may be ustd. The notice |
required by this  • I',I 33  s'n '.!l state at i
lcs<;t thr.t the publfr  vai.2i- s;.--:e;r. fails
to mer.ito.-. operate  the sytttm or pro-
vide \vatcr which ineots ;;11 the roqune-
mcnts of tiiis subpan rncl shall rt:.t-e with
particulaiily   those   )cq\i:rent;"its  for
which there Is nonccriipll.ir.ee. 1: a quan-
titivc liniitr.tion  has h^on exceeded, the
notice shall state v.-hat the Federal or
State limitation  is, ana at vha: level of
performance the water supply yvstem has
been o;,, .'gi_mt;	__--__
  •%*,"Tiic supplier of \v:.tcr shall give
notice pursuant to  thc_ jirccccures set,
forth in parasrsph iaN'of tlu.>  ^-ctior,—
  (11 V.'litii  his system has ;eceived  a
variance under  section I415'.i'il)  or
HISiai Oi of the Act. ?iid shaii continue
the nolihcation process at no less than
three month intervals during the life of
the variance;
p
- . community

r- — community

          The State  shall require  by  order or  regulation the

  ovner or  operator of  a public water system  other than a.

  community water  system to  give  notice  to the persons served

 'by  the system of  any  failure on the part of the  system to comply

  v/  the requirement  (including monitoring requirements) of this

  subpart .   The form  and manner of the notice shall be such as

  to  insure that the  public  using the public  water system  is

  informed  that the system  is performing inadequately-
       (b)
  (d)   Any violation  requiring  notification  according to   lUl.32
 /

    shall  be reported  to the State  and  corrective action  shall  be

    immediately initiated  by the supplier of  water.
                                                   J-l-

-------
  (2)  When his system has received an ,
exemption under section 1416 and shall-
continue the notification process at no
less than three month intervals during
the life of the exemption; or
  (3)  When  his system  has failed  to
comply  with any  schedule  or  control
measure  prescribed  pursuant to a vari-
ance or exemption and shall continue the
notification  process  at no  less than tne
three  month intervals curing the life  of
the variance and exemption.      		
§ 141.41  Siting requirements.
  Before a  person may enter into a
financial commitment for  or  initiate
construction of a  new public \vater sys-
tem or increase the capacity of an exist-
ing public water system, he  shall—
  (a)  To thg  extent  practicable,  avoid
locating part or all of the new or ex-
panded facility at a site v-,-nich:
  (1)  Is subject to earthquakes, floods,
fires or other man-made disasters which
could  cause breakdown of  the  public
water system or a portion thereof; and
  (2)  Is within the fioodplain of a. 100
year flood;
  (b)  Notify the State.
§141.51  Eft"cctivo date.
  The  standards set  forth in this  sub-
part shall take effect 18 months  after
the date of promulgation.
  [FR Doc.75-6603 Filed 3-13-75:8:45 am]
    . 33 Record  maintenanca   - John  Co

1 111. 3^1 Variances  and Exemptions  -  Little

            One sentence  only
                                                      J-15

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                    APPENDIX K

          DESCRIPTION OF ORIGINAL SMSA'S
     The following definitions of the SMSA regions used in
the original PHS study are quoted exactly as defined in that
study:

     Region I - State of Vermont:   Vermont was included in
the study at the request of the Commissioner of Health with
concurrence of the Governor.  (Replaced the Initially
selected SMSA In this Region).

     Region II - New York, New York:  This SMSA included
Rockland, Westchester, Nassau, and Suffolk Counties in
addition to the City of New York.   It was selected to
represent those water supplies utilizing surface-water
providing disinfection only for treatment and those utilizing
groundwaters from high population density areas.  It also
represents the highly urbanized (megapolis) areas of the
United States.

     Region III - Charleston, West Virginia:  This SMSA
included Kanawha County.  It was selected to represent those
supplies using surface-waters that receive the wastes from a
highly industrialized area.  The small coal mine town
represent supplies In economically depressed areas of the
northern Appalachian area.

     Region IV - Charleston, South Carolina:  This SMSA
included Berkeley and Charleston Counties.  It was selected
to represent the Atlantic and Gulf coast areas using both
surface- and grounawater.

     Region V1 - Cincinnati, Ohio; Kentucky; Indiana:  This
SMSA included Hamilton, Warren and Clermont Counties, Ohio;
Boone,  Campbell, and Kenton Counties, Kentucky; and Dearborn
County, Indiana.  It was selected to represent those portions
of mid-America using surface-water receiving a considerable
amount of industrial discharge in addition to municipal
wastes and agricultural runoff.
      Region V in original study is in EPA region VI.
                            K-l

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     Region VI  - Kansas City, Missouri; Kansas:  This SMSA
included Cass, Clay, Jackson, and Platte Counties, Missouri
and Johnson and Wyandotte Counties, Kansas.  It is similar
to the Cincinnati SMSA, but was selected to represent
surface-waters with a larger agricultural runoff to industrial
waste ratio.

     Region VII - New Orleans, Louisiana:  This SMSA included
Jefferson, Orleans, St. Bernard, and St. Tammany Parishes,
Louisiana.  It was selected to represent the supplies receiving
surface-water drained from large and varied river basins,
plus some from deep artesian wells.

     Region VIII - Pueblo, Colorado:  This SMSA included
Pueblo County, Colorado.  It was selected to represent the
water supplies of the high plains region of the country that
have a mixture of groundwater and surface-water sources.

     Region IX - San Bernadino, Riverside, Ontario, California:
This SMSA included San Bernadino and Riverside Counties,
California.  It was selected to represent the semi-arid
regions of the west and southwest as well as an area served
primarily by groundwater.
      Region VI in original study is EPA region V.
                               K-2

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