UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Registration Division Office of Pesticide Programs Criteria and Standard! Division Offics of Drinking Water GUIDE STANDARD AND PROTOCOL FOR TESTING MICROBIOLOGICAL HATER PURIFIERS Report of Task Fore* SubBittsd April, 1986 Revised April, 198? ------- CONTENTS PREFACE . . . . . . . . . . . . . . . . . . . . . a . • . 1 S ’tZON 1 : GENERAL . . . . . . . . . , , • • • • • • • • 2 SECTIO&2: PERFORMA 1 EREQUIRERENTS 6 SBTrON 3: t4ICROBZOLOGICAL WATER PURIPZER TEST PROC . ES . . . . . . . . . . . . . . . . . a a 8 APPENDIX A: SUMMARY FOR BASIS OP STANDARDS AND TESTWATERPARAIIETER$ ................ 22 APPENDIX B: LIST OF PARTICIPANTS IN TASX FORCE a a a a • 29 APPENDIX C: RESPONSE BY REVI ( SUBC MITTEE TO PUBLIC COMMENTS a a • . . a a a a • . . a a a a a 31 ------- PREFACE The tails force began deliberations in July, 1984 and submitted its initial report in April, 1986. The task force included a broad multi- disciplinary group of experts representing the interest areas of academic and governmental- research, product evaluation, development and testing, manufacturer's product registration, and governmental enforcement. The report was provided for public comment* in May, 1986. A review subcommittee -as constituted to prepare a response to the public comments and to revise the report, as herewith submitted. Additional revision has been provided in response to review by the Scientific Advisory Panel (Federal Insecticide, Fungicide, and Rodenticide Act). The recommended guide standard and testing protocol was developed to be useful in a number of ways, not only for governmental but also for industrial and consumer purposes* as a basic framework, starting point for the testing and evaluation of microbiological water purifiers for EPA registration* as a guide to the acceptance of water treataent unit* for compliance with Safe Drinking water Act requirements where point of use units nay be needed temporarily to treat a contaminated public water supply or for emergency situations, but not for use in extreme overseas situations or for the conversion of waste water to micro- biologically potable water* as a testing guide to manufacturers wishing to have their unit* considered as microbiological water purifiers, whether registered or not, and for the evaluation of such testing.data; as a guide to consumer* regarding what they can expect from micro- biological water purifiers tested according to this standard and protocol* to assist in th« research and development of microbiological treat- ment units"for possible military applications. I want to thank the expert members of the task force for their participation in this work and particularly the chairmen of three work groups > Charles Gerbai Microbiological Challenge* Richard Tobint Physical, Chemical and Operational Challenges Prank A. Bell, Jr.i Testing Protocol Stephen A. Schaub, Ph.D. Chairman U.S. Army Medical Bioengineering Research and Development laboratory ------- SECTION 1: G IERAL 1.1 Introduction The subject of microbiological purification for waters of unknown microbiological quality repeatedly presents itself to a variety of governmental and non—governmental agencies, consumer groups, manufac- turers and others. Examples of possible application of such purification capabilities include: - backpackers and campers - non—standard military requiraments — floods and other natural disasters — foreign travel and stations (however, not for extreme contamination situations outaid. of the U.S.) — contaminated individual sources, wells and springs (however, not for th. conversion of waste water to aicrobiologically potable water) — motorhomes and trailers Batch methods of water purification based on chlorine and iodine disinfection or boiling are well known, b t many situations and personal choice call, for the consideration of water treatment equipment. Pederal. agencies specifically involvd in responding to questions and problems relating to microbiological purifier equipment include: Registration Division, Of tic. of Pesticide Programs (OPP), Environmental Protection Agency (DA) z r.qistration of microbiological purifiers (using Chemicals); Compliance Monitoring Staff, As control of microbiological purifier device claims (non-registerable products such as ultra- violet units, ceonators, chlorin, generators,. others) US. Army Medical Bioengineerinq Research and Development L.thc- ratory (IJ$A1IBPDL), U.S. Army latick Research and Development Center and othsr Army and military agencies: research and development ‘or possible field applications, Criteria and Standards Division, Office of Drinking Water (OUW), EPA: Consideration of point-of—use technology as acceptable t.chnoioqy under the Primary Drinking Water Regulations, consi er infersmticn and service; Drinking Water Research, Water Engineering Research Laboratory (W L), k , responsible for water treatment technology research; ------- Microbiology Branch, Health Effects Research Laboratory (HERL), EP7 ; r.sporsibl. for study of h•alth .ff.cts related to drinking water fi lt.ri. A nu tb.r of representatiVes of th. above mentioned agencies ptovided .xceli•nt participation in the task force to develop microbiological testing protocols for water purifiers. Major participation was also provided by the folloViflgz — a technical representative from the Water Quality Association; - a technical representative from the Environmental Health Center, Department of Health and Welfare of Canada: and - an associate professor (microbicl.ogy) from the University of Arizona. 1.2 Basic Principles 1.2.1 •Definition As set forth in EPA Enforcement Strategy and as supported by a Federal Trade Commission (FTC) decision (FTC v. Sibco Products Co., Inc., •t ii., Nov. 22, 196S),, a unit, inorder to be called a microbiologicarvatex purifier, must remove kill or inacti- vate all types of disease-causing microorganisms from the water, including bacteria, viruses and protozoan cysts so as to render the processed water safe for drinking. Therefore, to qualify. a micro- biological water purifier must treat or remove all types of challenge organisms to meet specified standards. 1.2.2 General Guidet The standard and protocol will be a general quid . and in some cases, may present only the minimum features and framework for testing. While basic features of the standard and protocol have been tested it ves not feasible to conduct full- fledged testing for all possible types of units. Consequently. protocol users should include pre-t.sting of their units in a tasting rig, inclndl’ q th. sampling techniques to be used. Where users of the protocol find good reason to altar or add to the guide in order to meet specific operational problems. to use an alt.Z!nste organi er laboratory procedure, or to respond to innovative trua’t unit. without decreasing th. level of testing or al erin the intent of the protocol, they should feel free to do so. For example, the OPP Bagistration Division might find it necessary to amend the çaid. somewhat for different types of. treatment units. Mother example would be ultraviolet (U.V.) units, which may have spIcific requirements in addition to the guid. protocol. 1.2.3 Pert oraance—B.sad : The standard will be perforaaricebs$•d. utilizing realistic worst case challenges and test conditions and shall result in water quality equivalent to that of a public water supply meeting the microbiological r.quireaiflts and intent of the National Primary Drinking Water Regulations. ------- A aicrãbioloqical water purifier must remove, kill Or inactivate all types of pathogenic organisms if claims are made for any organism. However, an exception for limited claims may be allowed for unitsrepoving specific organisms to serve a 4sf inabis environmental need (i.e., cyst reduction units which can be used on otherwise d .sinf.cted and microbiologically safe drinking water, such as a disinfected but unfilter.d surfac. water containing cysts. Such u.rtits are ‘tot to be called microbiological water purifiers and should not be used as sole treatment for an untreated raw water.) 1 .25 Not to Cover Non-Microbioloqical Reduction Claims : The treat ment of water to achieve specific chemical removal from water or other non-microbiolOgical claims will. not be a part of this standard. National Sanitation Foundation (NSF) Standards 42 (Aesthetic Effects) and 53 (Health Effects) provide partial guides for chemical removal and. other claims testing. 1.2.6 Construction and tnforaatienal Exclusions : While the standard recommends safe, responsible construction of units with non—toxic materials for optimum operation, all such items and associated opera- tional considerations are excluded as being beyond the scope of the standard. Included in the exclusion are materials of constuction, electrical and safety aspects, design and construction details, operational instructions and information. and mechanical pert ermance testing. I • 2 • 7 R.s.arch Needs Excluded : The guide standard and protocol must represent a practical testing program and not include research rscoa mendations. For exa.ple consideration of mutant organisms or differentiatiOfl between injured and dead organisms would be research items at this time and not appropriate for inclusion in the standard. 1.2.8 Net To Consider Sabotages Isotaric problems which could be pr.- ssnted by a variety of hypothetical terrorist (or wartime) situations, would provide an unnecessary complication. and are net appropriate for inclusion in the standard. 1.2.9 Continuityt The guide standard and protocol will be a living docut, subject to revision and updating with the onset of new tecI noL and knowledge • It is recameended that the responsible authodttee for reVistratiols and drinking water quality review potential needs every two to thre year. and reconven, the task force upon need or upon requmat from the water quality industry, to review and update the standard and testing protocol. 1.3 Treatment Units Covera 1.3.1 Universe of Possible 1reata.rst Units : A review of treatment units that might be considered as microbiolOgicaL purifiers discloses a number of different types covering treatment principles ranging from filtration and chemical disinfection tO ultraviolet tight radiation. ------- 1.3.2 Coverag, of This Standard : In vi•w of the limited technical data available and in order to expedit. th. work of the task force, th. initial coverage is limited, on a priority basis, to three basic types of microbiological, water purifiers or active cem on.nta with their principal means of action as follows 1.3.2.1 Ceramic Filtration Candles or Units (say or may not contain a chemical bacteriostatic agsnt) : filtration, and adsorp- tion, and chemical anti—microbial activity if a chemical is included. 1.3.2.2 Maloqer*at.d Resins and Units: chemical disinfection and possibly filtration. (Not.: While not includ.d in this guide standard, halogen products for disinfection or systems using halogen addition and fin, filtration say be tested using many of its elements, i.e., test water paraa.t.rs, microbiological challenge and reduction requirements, - analytical techniques and other pertinent elements. 3 1.3.2.3 Ultraviolet (UV) Units: W / irradiation with possible add-on treatment for adsorption and filtration (not applicable to WI units for treating potable water from public water supply systua). 1.3.3 Application of Principles to Other Units : While only three types of units are covered in this standard th. principles and approaches outlined should provide an initial quid. for the tasting of arty of a nusber of other types of units and/or systems for the microbiological purification of contaminated water. —5— ------- S! TION 2: PERFORMANCE REQUIRDI ITS 21 Microbiological Water Purifier In order to mak. the claim of micrcbiologica]. water purifi.r, units ust b. tested and demonstrated to mast the microbiological, reduction requirements of Table I according to the test procedures described in Section 3 for the specific type of unit involved. 2.2 C emjcaj. Health Limits Wher, silver or some other pesticida]. chemical is used in a unit. that chemical concentration in the effluent water must meet any N tional Primary Drinking Water Maximum Contaminant Lve I (I4CL) • additional Federal guidelines or otherwise be demonstrated not to constitute a threat to... health from consumption or contact where no MCL exists. 2.3 Stability of P.sticidal Chemical Where a p.sticidal. chemical is used in the tr.a ent unit, the stability of the chemical for disinfectant effectiveness should be sufficient for the potential shelf life and the proj.ct.d use Life of the unit based on manufacturer’s data. Where stability cannot be assured from historical data and information, additional tests will be required. 2.4 Performance Limitations 2.4.1 Effective Lifetime The manufacturer must provide an explicit indication or assurance of the unit’s effective use Lifetime to warn the consumer of potential diminished tr.ataent capability either through: a. Having the unit terminate discharge of treated water, or b. - liowiding an alarm, or C. Providing simple, explicit instructiens for servicing or replacing units within the r.cosaend.d ass life (measurable in t.r of volume throughput, specific time frees or other appropriat, method). 2.4.2 Limitation on Use of Iodine EPA policy initially developed in 1973 and reaffirmed in 1982 (memo of March 3. 1982 from J.A. Cotruvo to G.A. Jones, subject: Policy on Iodine Disinfection) is that iodine distnfectiDfl La acceptable for short-term or’ limited or emergency use but that it is not recommended for long—term or routine coáunity water supply application where iodine-containing species say remain in the drinking water. ------- TABLE 1 MICROBIOLOGICAL P UCTION REQUI RD JTS Klebsis]la t.rrigena , a common e oliform, was selected as the challenge organism to represent the coLifor group. Poliovirus I (LSc) and rotavirus (We or SA—il) are common environmental viruses and show resistance to different trea ant processes, thereby pro- viding good challenges for the virus group. Giardia was sel•ct.d as the cyst challenge representative bcause of its widespread disease impact and its resistanc, to ch.aical disinfection. The use of 4—6 micron particles or beads for testing the occlusion filtration of cysts has been demonstrated to be an accurate and practical substitute for the use of live cyst challenges. It is included as an option where disinfection or other active processes are not involvsd. Miniw.a Influent Required Reduction- Organism challenge* _______ Bacteria: Kiebsiella t.rrig.na 1O /1OO ml 6 99.9999 (ATCC—33257) Virus: a. Polievirus 1 (LSc) I x 10 7 /L (ATCC-VR-59) and, 4 99 99** b. Rotavirus (Wa or sA—Il) 1 x 10 7 /L (&TCC—VR-899 or VR—2018) Cyst (Protozoan): Giardia 0 a. Giardia suns or 10 6 /L 3 99.9 Giardia ] aablia or b. As an option for units or 10 7 /L 3 components based on occlusion filtration: particles or spheres, 4—6 microns (Testing s zdinq to Wationa] Sanitation ?onndation Standard 53 for cyst reduction will be acceptable) The influent challenges say constitute greater concentrations than would be anticipated in source waters, but these are necessary to properly test, analyze and quantitatively detezaine the indicated log reductions. Virus types are to be mixed in roughly equal I x I o It. concentrations and a joint 4 log reduction will be acceptable. *..Zt should bus noted that new data and information with respect to cysts (i.e.. Cryptosporidium or others) may in the.future necessitate a review of the organism of choice and of the challenge and reduction requirements. —7.- ------- S TXoti 3 • I4ICROBIOLOGIC? .L WATER PURIFIER TEST PROCEDURES 3.1 !2E !2. These tests are performed on ceramic filtration candles or units, halogenated resins and units and ultraviolet (rJV) units in order to substantiate their microbiological removal capabilities over the effective use life of the purifier as defined in Table I and, where a pesticide]. chemical is used, to determine that said chemical is not present in the effluent at excessive Levels (see Section 3.5.3.4). 3.2 Apparatus Three production units of a type are to be tasted simultaneously, if feasible; otherwise, in a manner as similar to that as possible. Design of the testing rig must parallel and simulate projected field use conditions. For plumbed—in units a guide for design of the test rig may be taken from Figure 1: Test Apparatus-Sch.matic (p. A-2 of Standard Number 53 Drinking Water Treatment Units -- Health Eff.cts,R National Sanitation Foundation). Otherwise, the test rig must be designed to simulate field use conditions (vorit case) for th. unit to be tested. 3.3 Test Waters —- Non-Microbiological Parameters In addition tO th. microbiological irifl.uent challenges, th. various teat waters will be constituted with ch.mical. and physical characteristics as follows: 3.3.1 Test Water *1 (Gen.ral. Test Water ) This water is intended for th. normal non—stressed (non-chaUenge) phase of testing for aU units and shall have specific characteristics which may easily be obtained by th. adjustment of many publ.ic system tap waters, as fotlows (a) t shall be fr.s of any chlorin, or other disinfectant residual; (b) p1 — 6.5 — 0.5, Cc) Total Organic Carbon (WC) 0.1 - 5.0 mg/La Cd) Turbidity 0.1 — S NTU; Ce) Temperature 20C 5’C; and (f) Total Dissolved Solids CTDS) 50 - 500 mg/I.. —8- ------- I$& UkE %; T1ST APPAM?US SCflU ATIC bick Pres ra ugi &dtor My luttobi. .ct.r L u L a.caI Pot- L. V .Iø at. to b. iu.4 La t..tIa all oits .ioder iho .tnk ot si Ibo .LM. (. Lat kltchsa 1*actS lot .totLoo.ry iatts tagc.t .ttw’° m it . a asallor tMrd to to tot by- p . sits.) 3. Io010t t t ’ soito aM pust lo sails are to b. pl.c.d altar lb. .oi t4. 3 . l. hoe’ .. oi slailar imz . imtta .M - sa. tsac.ts. lisa coo be r .i.eiaiM witb vaiVe piacM oa the •Ulst .4k. 4. L I I ..at.r* I* of cosatXuctLOa be suitab3• tot us. atIb diiakLup wetot. l X • t ou valves oe so Is uaM for X. LI&O flow) • oI.aotd Vaiss Z • ch.cL Valve ------- 3.3.2 Test Water *2 (Challenge Test Water/Halogen Disinfection ) This wats is intended for the stressed challenge phase of testing where units involve halogen disinfactants (halogen resins or other ‘units) and shalt have the following specific characteristics; (a) Free of chlorine or other disinfectant residual; (b) (1) pH 9.0 .2, and (2) for iodine—based units a pH of 5.0 .2 (current thfor atiofl indicates that the Low pH wit], be the most severe test for virus reduction by iodine disinfection); (C) Total Organic Carbon (TOC) not less than 10 ag/Ls (4) Turbidity not less than 30 NTU; Ce) Temperature 4C 1C and (f) Total Dissolved Solids (TDS) 1.500 g/L 150 mg/L. 3.3.3 ‘ Nat Water *3 (Challenge Test Watar/Cersaic Candle or Units With or Without Silver Impregnation ) This water is intended for th. stressed chall.nge phase of test- ing for the indicated units but not for such units when impregnated with a halogen disinfectant (for the latter is. Test Water 02). It shall have the following specific characteristic$ (a) It shalt be free of any chlorine or other disinfectant residual; (b) pH 9.0 * .2: Cc) Total Organic Carbon (TOC) -— not less than 10 eg/L Cd) Turbidity -— not Less than 30 NTUs (a) rs.per*ture 4C *1C; and (f’) Total Dissolved SoUds (‘rOS) -— 1,500 mg/L * 150 mg/L. 3.3.4 Toat water *4 (Challenge Test Water for Ultraviolet Units ) This water is intended for the stressed phase of testing for CJV units and shall have the following specific charactSristiCS (a) Free of chlorine or other disinfectant residuaL; (b) pH 6.5 — 8.5; (c Total. Organic Carbon (TOC) -- not less than 10 ag/Li (4) Turbidity -— not less than 30 NTU; - 0- ------- (e) Tespezature 4°C ± 1°C; (t) Total Dissolved Solids (TDS) —— 1,500 atg/L 150 eq/Li (q) Color u.v.. absorption (absorption at 254 tie) -— Sufficient para- hydroxybetizoic acid (PHBH) to be just below the trigger point of the warning alarm on the U.V. unit. (Note that Section 3.5.1.1.1 provides an alternative of adjusting the (J.V. Lamp electronically, especially when the U.V. lamp is preceded by activated carbon treatment. J 3.3.5 Test Water #5 (L.aching Test Water for (Jnita Containing Silver This water is intended for stressed leaching tests of units containing silver to assure that excess levels of silver will, not be leached into the drinking water. It shall have the following specific characteristics: (a) Free of chlorine or other disinfectant residua]j (b) pH —— 5.0 t 0.2; Cc) Total Organic Carbon (TOC) -- approximateLy 1.0 mg/Li (d) Turbidity —— 0.1 — 5 NTtJ; Ce) Temperatire -- 20°C * 5°Cs and Ct) Total Dissolved SoLids (TOS) —— 25 - 100 eg/L. 3.3.6 Recommended Materials for Adjusting Test Water Characteristics (a) pH: inorganic acids or bases (i.e., Nd, SaOH); (b) Tots]. Organic Carbon ClOd) buaic acids; Cc) Turbidity: A.C. Fine Test Dust (Part No. 1543094) frost A.C. Spark Plug Division General Motors Corporation t300 North Dart Highway Flint, Michigan 48556 Cd) Total Dissolved Solids (TDS): sea salts, Sigma Chemical Co., S9803 (St. Louis, MO) or another equivalent source of TDS; (e) Color U.V. Absorption: p—hydroxybenzoic acid (grade: general purpose reagent). ------- 3.4 Analytical Methods 3.4.1 Microbiological Methods Methods in this section are considered state—of the—art” at the tims of its preparation and subsequent improvements rhould be expected. Methods used fer microbiological analyses should be compat .ble with and equal to or better than those given below. 3.4.1.1 Bacterial Testa a. Chosen Organism: Kiebsiella terrig.na (ATCC—33257). b. Method of Production: The test organism will, be prepared by overnight growth in nutrient broth or equivalent to obtain th. organism in the stationary growth phase tR.ference: Aaburg E.D., 1983, Methods of Testing Sanitisers and Bacteriostatic Substances; in Disinfection, Sterilization and Preservation (Seymour S. 8lock, ed.), pp. 964—980). The organism will be collected by centrifugation and washed three times in phosphate buffered saline before use. Alternatively, the organisms may be grown overnight on nutrient agar slants or equivalent and washed from the slants with phosphat. buffered saline. The suspensions should be filtered through sterile Whatman Number 2 filter paper (or equivalent) to remove any bacterial clues. New batches of organisms must be prepared daily for us. in challenge tasting. c • Stats of Organism: Organisms in the stationary growth phase and suspended in phosphate buffered saline will be used. d • Assay Techniques: Assay may be by the spread plate, pour plate or brane filter technique on nutrient agar, MJ.C. or a. do medium ( standard Methods for the Exa*tnetien of Water sod Wastevater , 16th .dttion, 1985, APHAT. Bach sap e dilution will be assayed in triplicate. 3.4.1.2 Virus Tests: a. c..n Organisms: Polioviru. type 1 (LSc) (ATCC-VP.S9) • &nd Botavtrus Strain 3k—i I (ATCC—VR -899) or WA ( ATCC -VI—201 8). b. Method of Production: All stocks should be grown by a method described by Smith and Gerba (1982, in Methods in viron.ental Virology , pp. 15—47) and purified by th. procedure of Sharp, et c i. (1975, Appi. Nicrobiol., 29:94—101), or similar procedure (Berman and Hoff, 1984, Appi. !nviron. Microbiol., 48:317—323), as these methods will, produce largely senodispersed viriott particles. c. State of the Organism: Preparation procedure will largely produce .onodispsrs.d particles. ------- d. Masy Tchni.quas: Poliovirus type 1 may be grown in the 8GM, —104 ot other cell line which will support the growth of this virus. The rotavirusas are best grown i t t the PiA—104 cell line. Since both viruses can be assayed on theMA—104cell line a challenge test may consist of equal amounts of both viruses as a mixture (i.e.,the mixture must contain at least 1.0 x °7/ x. of each virus). Assays may be as plaque forming units (PFU) or as imrnano— fluorescence foci (I?) (Smith and Gerba, 1982, in Methods in tvironmental Virology , pp. 15—47). Each dilution will be assayed in triplicate. 3.4.1.3 cyst Tests: a. chosen Organism: (1) Giardia lmbtia or the related organism, Giardia suns , may be used as the challenge cyst. (2) Where filtration is involved, tests with 4—6 micron spheres or particles have been found to be satisfactory and may be used as a substitute for tests of occlusion using live organisms (see Table 1). Spheres or par- ticles may only be used to evaluate filtration efficacy. Disinfection efficacy can only be evaluated with the use of viable Giardia cysts. b. Method of Production: Giardia suns may be produced in laboratory sic. and Giardia iambus say be produced i tt Mongolian gerbils, inactivation results based on .xcystation asasuremants correlate well with sniasi infectivity results. c. State of the Organism: Organisms say be separated from fecal material by the procedur. described by Sauch (1984, Appi. vviron. Microbto].., 48:454—455) or by th. procedure described by Singham, et el. (1979, Xp. Parasitol.., 47 284 —291). d. Mely ?sehniques: Cysts are first r.conc.ntrat .d (500 ml., minimum sample size) according to the method of Rice. Hoff nd Schaefer (1982, Appi. viron. Nicrobiol., 43:250—251). The excystation method described by Schaefer, !. (1984, Trans., Royal Soc. of Trop. Med. I Ryg. 78:795—800) shall be used to evaluate Giardia auris cyst viability. Por Giardis iambUs cysts the excystation method described by ainghas end Meyer (1979, Nature. 277:301—302) or Pies end Schaefer (1901, J. din. Microbiol.. 14z709—710) shall be used. Cyst viability may also be determined by an assay sthod involving the counting of t.xophozoite s as wsll. as intact cysts (Ringham , stat., 1979, Exp. Parasitol., 47:264—291). —1 3— ------- 3.4.2 e*ical and Physical Methods LIl physical and chemical analyses shall be conducted in accordance with procedures in Standard Methods for the Exanination of Water and Wastewater , 16th Edition, Axerican Public Health Associ- ation, or equivalent. 3.5 Test Procedures 3.5.1 Procedure - Plumbed—in Units a. (1) Install three production units of a type as shown in Figure 1 and condition each unit prior to th. start of the test in accordance with the manufacturer’s instructions with th. test water without th• addition of the test con- taminant. Measur. the flow rate through each unit. The unit shall be tested at the maximum system pressure of 60 pug static and flow rat. will not be artificially controlled. (2) Test waters shall have the defined characteristics contin- uously except for test waters 2, 3 and 4 with respect to turbidity. Th. background non—sampling turbidity level will be maintained at 0.1-5 NTU but th. turbidity shall be increased to the challenge level of not 1... than 30 NTU in the following manner: - in the ‘on’ period(s) prior to th. sampling ‘on’ period. - in the sampling ‘on’ period when th. sample actually will be taken. (Note: at least 10 unit void volumes of the 30 NTU water shall pass through the unit prior to actual sampling so as to provide ad.quate seasoning and uniformity before sample collection.1 b. (1) 3cc appropriate techniques of dilution and insure continual mixing to prepar. a challeng, solution containing the bacterial, contaminant. Then spike tact water continuously with the influent concentration specified in Table 1. (3) Use appropriat, techniques to prepare concentrated virus and Giardia suspensions. Feed these suspensions into the influent stream so as to achieve the influent concentrations specified in Teble 1 in the following manner: - in the •on ’ period(s) prior to the sampling ‘on’ period. - in th. sampling ‘on’ period when th . sample actually will be taken. (Not.: at least 10 unit void volumes of seeded water shall pass through th. unit prior to sam- pling so as to provide adequat. seasoning and uniformity before sample collsction.1 —‘a— ------- a. Purge th. system of the uncontaminated vae.r with a •uffi jent flow of contaminated test water. Start an operating cycl, of 10 percent on, 90 percent of f with a IS to 40 minute cycle (Example: 3 minutes on, 27 minut.s off) with th. contaminated test water. This cycle shall be continued for not more than 16 hours per day (minimum daily rest period of 8 hours). The total program shall extend to 100% of estimated volume capacity for haloqenat.d resins or units and for 10—1/2 days for ceramic candles or units and for U.V. units. d. Sampling: Sample, of influent and effluent water at the specified sampling points shall be collected as shown below for the various units; these are minimum sampling plans which may be increased in number by th. investigator. All samples shall be collected in duplicat, from the flowing water during the sampling ‘on portion of the cycle and they shall be one unit void volum. in quantity (or of appropriate quantity for analysis) and repre- sent worst case challenge cenditiáns. Effluent samples shall usually be collected near the middle of the sampling on period. (or the whole volume during one on period) except for samples following the specified stagnation* periods, for which sampling shall b. conducted on the first water volume out of the unit. Each sample will be taken in duplicate and shall be retained and appropriately preserved, if required, for chemical or microbio- logical analysis in the event verification is required. (For units where the volume of a single ‘on’ period is insufficient for the required analysis, samples from successive ‘on’ periods may be accumulated until a sufficient volume has been collected.) 1(a). Sampling Plan: $alogenat.d Resins or Units ($on—iodine Based) Test Point (% of Estimated Capacity) . Test Water Tests Active Influent Aqent/ Background Residual Nicrobio] .oqical. Start. 25% 50% After 4$ rs stagnation 60% 75% After 4$ hours stagnation 100% Gnsral chal- lsnqe p — 9.0 0.2 X X X X X x x X X X X x X X X X X —15— ------- 1(b). Sa*pling Plan: todinsted R.sins or Units Test Point Tests Active (% of Es Capacity timated Test ) Water Influent AgerLt/ Background Residual Microbiological Start General X X X 1 25% j X X 50% After 48 hours stagnation X X X X 60% Chil- X X 75% l.nge Alter 48 hour. pH — stagnation 9.0 0.2 X X X X - 90% C l iii — X X 100% Lang. Alter 48 hours pH - stagnation 5.0 0.2 X X X . X 2. Saspting Plan: C.raaic Candles or Units Tests Test Influent Test Point Wa t er Background and U.V. Units Microbiological. Start General X X Day 3 (middle) X Day 6 (middLe) X After 48 hours itagnatiom X a a Day 7 (aiddi.) X Day 8 (near end) Chal— X After 48 hours l.ngs stagnation X Day 10—1/2 X (Note: A lL days are running days and exclude stagnation periods. When th. units contain silver, a L.aching test shall be conducted as shovn in Section 3.51.. and silver residual. vi ii be sasursd at each microbiological saapling point.) —16— ------- •. Leaching Tests for Silverized Units: Wher, the unit contains silver, additional tests utilizing Test Water *5 will be Conducted as follOws: Test Point Tests Influent Background Silver/Residual. Start Day2 After 4$ hours stagnation x x X X f. Alternate Sampling Plans: 1 • Since some laboratories aay find it inconvenient to test s e units on a 16 hour on/B hour off cycle, two alternates are recognized: -- go to a shorter operational day but lengthen the days of test proportionally —- use up to 20 percent on/$0 percent ‘of V for a pro- portional ly shorter operational day 2. Sampling points suet be appropriately adjusted in any alternate sampling plan. g. Application of Test Waters: The application of test waters is designed to provide inforsation on performance under both normal and stressed con- ditions it should be the sane or equivalent to the following: • (a) Ratogenated Resins or Units (Non-iodin, based) -- ?irst 50% of test period: Test Water I (General) Last 50% of test period: Test Water 2 (Challenge) (pH — 9.0 ± 0.2) (b) todtnated Resins or Units -- Pint 50% of test period: Test Water I (General) Next 25% of teat period: Test Water 2 (ChalLenge) (pH — 9.0 ± 0.2) Last 25% of test periods Test Water 2 (Chalt•nge) (but with pH - 5.0 * 0.2) 2. Ceramic Candles or Units -- First 6 days of testing: Test Water I (G.nisrat) Last 4—1/2 days of tasting: Test Water 3 (challenge) —17— ------- 3. Ultraviolet (U.V.) Units —— First 6 days of testing: Test Water I (General.) LaSt 4—1/2 days of testing: Test Water 4 (ChaLlenge) h. Analyses and Monitoring: 1. Microbiological sampling and analysis shall, be conducted of the specified influent and effluent sampling points during each indicated sampling period. 2. Test Water Monitoring: The specified parameters of the various test waters (a.. S•ction 3.3) will be measured and recorded at each microbiological sampling point, the specified parameters will be measured at least once on non—sampling days when the units are being operated. 3. Background chemical analyses of influent vatar shall be conducted at least once at the start of each test period to determine the concentration of the U.S. A primary inorganic contaminants, secondary contaminants and routine water para- meters, not otherwise covered in the described test waters. 4. In addition, quality assurance testing shall be conducted for the seed bacteria under environmental conditions on the first and last days of testing to sake sure that there is no significant change over the test day. Populations will be measured (for example, as dispers.d in th. supply tank) at the beginning and and of the test day to detect possible incid.ntaL effects such as proliferation, die—off, adsorption to surfaces, etc. ReLatively stable bacterial seed popula- tions are essential to an acceptable test program. 5. When a emit contains a halogen or silver, the active agent residual will, be measured in the effluent at each microbio- logical test (sampling) point. 6. SiLver wILL additionally be measured three times in the effluent as specified in Section 3.5.1.e. alizatiob of Disinfection Activity: Immediately after l,lction, each teat sample must be treated to neutralize any rsaidual , disinfectant. For halogen— and silver-based disinfec— tents this say be done by addition of thioq],ycouat.—thiosu]fate neutralizer solution (Chambers. et at., 3. Amer. Water Works Assoc., 54 2O8—216, 1962). This solution should be prepared daily. All results are invalid unless samples are neutralized immediately upon collection. j. Special Provisions for Ceramic Candles or Units: 1 • Provisions for slow flow: Ceramic units may be subject to clogging and greatly reduced flow over the test period. An attempt should be made to maintain, manufacturer rated —18— ------- or claimed flow rates, but even at reduced flows the sampling program s•t forth in Section 3.5 ,I.d.2. shall be maintained. 2. Cleaning of ceramic units: Units should be cleaned according to manufacturer’s dir .:tions. Two cleanings should occur during the period of test (in order to prove th. unit’s dura- bility through the cleaning procedure). However, near the time of microbiological sampling, the units should not be cleaned until after the sampling. Further, no anti—microbial chemical (for cleaning or sanitizing) may be applied to the units during the test period unless the manufacturer specifies the same as part of routine maintenance. k. Halogenated units or U.V. units with mechanical filtration pro— ceases separate from th. microbiological disinfection components shall have the mechanical filtration components replaced or serviced when significant flow reduction (clogging) occurs in accordance with the manufacturer’s instructions in order to maintain th. test flow rat.. Units with non—removable mechanical filtration components viii b run until flow is blow that considered acceptabl. for consumer convertience. (U premature clogging presents a problem, some specialized units may require a customized test plan.) 1. Special Provisions for Ultraviolet (U.V.) Units: 1. Th. units will be adequately challenged by the prescribed test waters consequently they will, be operated at normal intensity. How.v.r where the U.V. treatment component is preceded by activated carbon treatmsnt, th. output of the U.V lamp shall be adjusted electronically, such as by reducing th. current to th. lamp or other appropriate means, to b just above the alarm point. This option shall be availabl, for use under other U.V. configurations, at the choice of the persons responsibl. for testing, as an alter- native to th. us. of the UV. absorbent, p-hydroxyb.nzoic acid. 2. rail/safe: Units Viii provide and will b ’s tested for failI safe warnings in th. event of water quality changes or qui nt failures which may interfere with its sicrobto— logical, purification function. 3. Cleaning: Manufacturer’s guidance with respect to cleaning will be followed. 3.5.2 Procedures Won—Plumbed Units a. General: The basic procedures given in Section 3.5.1 shall be used with n.c.ssary adaptat ons to allow for th. specific design of th. unit. In any event the testing procedures shall provide a test challenge equivalent to those for plumbed—in units. —19- ------- b. Test conditions and apparatus should be adapted to reflect proposed or &ctu*l use conditions in consultation with the aanufactur.r, including flow rate and number of people to be served per day. In some cases variable flow or other non—stan- dard conditions may be necessary to reflect a worst—case test. 3 .5 3 Acceptance and Records 3.5.3.1 To qualify as a microbiological water purifier, three production units of a type must continuously east or exceed the reduction requirements of Table 1, within allowable measurement tolerances for not more than ten percent of influ.nt/sffluent sample pairs, defined as follows Virus: one order of magnitude Mctsria: one order of magnitude Cysts: one/half order of magnitude The geometric mean of all microbiological reductions must meet or exceed the requirements of Table I • An example is given as follows: — Unit: iodinat.d resin. - Number of sample pairs over the completed test program: IOp.runit—— 3unit53 3 . - Number of allowable sample pairs where log reduction is insufficisnt; 10% of 30 s 3 sample pairs. - Allowable minimum log reductions in these 3 pairs: • bacteria - 5 log • Virus — 31oq • Cyst — 2—1/2 log - Conclusions If the geometric mean of all reductions meets or exceeds the requirements of Table 1, th. indicated insufficient sample pairs wi].]. be allowed. 3.5.3.2 Records AU pertinent procedures and data shall be recorded La a standard format and retained for possible review until the report of results has been completely accepted by review authorities, in no case for less than a year. 3.5.3.3 scaling up or downs Where a manufacturer has several similar units using the same basic technology and parallel construction and operation, it may sometimes be appropriate to allow the test of one unit to be considered represent*t.tVS of others. Where any serious doubt exists, aU units of various sizes may require testing. P. rule of thrss s suggested as a matter of udq.ent. Scaling up to three times larger or one—third, based on the size of either the test unit or of its operative element. may be allowed. However,- for UV units any size scale—up must be accompanied by a parallel increase in radiation dose. —20— ------- 3•5•3•4 Wlt•rs gitv.r or some other c1 .micaL is usd in the unit, conc.ntrattons jfl. the elf Ltient water must meet any National Primary Drinking Water Maximum Contaminant Level (HCL), addi- tional Federal guidelines, or otherwise not constitute a threat to health where no MCL exists. —21— ------- APPENDIX A SUMMARY FOR BASIS OF STANDARDS AND TEST WATER PARAMETERS A. M.icrobiol.ogical Reduction Requirements • Bacteria Current standards for the microbiological. safety of drinking water are based on the presenc, of coliferm bacteria of which Klabsiella is a member. 4smbers of the genus Kiebsiella are also potential pathoq.ns of man (Viassof, 1977). Kl.ebsiel.le terrigena is designated as the test organism since it is commonly found in surface waters (Izard, .tal., 1981). Experience with the use of coliferm bacteria to estimate the presence of enteric bacterial pathoqens in drinking water as performed over the last 75 years indicates a high degree of reliability. Required t.sting of more than one bacterial pathogen appears unjustified since viral and Giardia testing will, be required. Ent.ric viruses and Giardia are known to be more resistant to common disinfectants than enteric bacterial pathogsns and viruses are more reuistant to removal by treateenta such as filtration. Thus, any trea ent which would giv, a good removal of both virus and Giardia pathogens would most Likely reduce ent.ric bacteria below levels considered infectious (Jarroll, etal., 1981, Liu, stal., 1971). Th. concentration of coliform bacteria in raw cewage is approximately 109/100 ml. Concentrations in polluted stream waters have been found to exceed iOS par 100 ml (Cul.p, et al., 1978, Table 10). Based en the over 105/100 ml concentrations observed in highly polluted stream water and a target effluent concentration of teas than 1/100 ml, a 6 log reduction is recommended. 2. Virus In the United States concentrations of entrovir’uses are estimated to rang. from 10 3 -10 4 /]itsr in raw s•wags (Parrah and Schaub, 1971 ) • Based on this observation it is estimated that natural waters contaminated with raw sewage may contain from 1 1 to 102 enteric viruses per liter. There are currently no standards for viruses in drinking water in the United States. However, EPA has proposed a non— enforceable health-based recommended maximum contaminant level (RIICL) of zero for viruses (EPA, 1985). Several individuals and organizations have developed guidelines for th. presence of viruses in drinking water and various experts have proposed standards (WHO, 1979, 1984; Berg. 197i Metnick. 1976). It has -22— ------- generally been felt that drinking water should be free of infectious virus since even one virus is potentially infectious and suggested standards are largely based on technological limits of our detection methodology. Guidelines suggested by the world i.alth Organization (1984) and others recommend that volumes to be tested be in the order of 100—1,000 liters and that viruses be absent in these volumes. Msumirtg a target effluent level of less than one virus in 100 liters of water and a concentration of 104 enteric viruses in 100 liters of sewage—contaminated waters, the water purifier units should achieve at least 4 logs of virus removal.. The relative resistanc. of enteric viruses to different disinfectant.a varies greatly among the enteric viruses and even among sembers of the same group (i.e., enteroviruses). For example, while f2 coliphage is one of the most resistant viruses to inactivation b chlorine it is one of the most susceptible to inactivation by ozone (Iiarek.h and Butler, 1984). Ionic conditions and pH can also affect the relative resistance of different viruses to a disinfectant (Engelbrecht, eta]., 1980). On this basis it ii felt that more than one enteric virus should be tested to ensure the efficacy of any disinfection system. Poliovirus type I (Strain LSc) was chosen as one of the test viruses because it has been extensively used in disinfection and environmental studies as representative of the enterovirus family. It is recognized that it is not the most resistant virus to inactivation to chlorine, but is still resistant snough to serve as a useful indicator. Rotavirus is selected as th. second test enteric virus since it represents another group of antaric viruses in nucleic acid composition and size. It is also a major cause of viral gaatro.nt.ritis and has been documented as a cause of waterborns gistxoentsrttis (Gerba, et al., 1985). The human rotaviru. or the similar Simian rotavi a ay be used in the test procedure. A net 4-Log reduction for a joint challenge of 1 x 1 0 7 /L each for poliovirus and rotavirus is recommended. 3. Cysts (Protozoan ) Over the peat several years, giardiasis has consistently been one of the most frequently reported vaterborne diseases smsaitt.d by drinking water in the United States (Crawi, 1904). A has proposed a R$CL of zero for Giardia (EPA, 1985). Its occurrence has generally been associated with treatment deficiencies including either inadequate or no filtration. Giardiasis has not bean kno m to occur from drinking water produced by well—operated filtration treatment plants. Oe Walls, et a]. (1984), in a study of filtration treatment plant effi ie ies, cited percent removals for Giardia in pilot plant tests as follows: - rapid filtration with coaguLation sedimentatiOflZ 96. 6—99 .9% - direct filtration with coagulation: 95.9—99.9%. —23- ------- Pros this research and from the lack of Giardia cases in eystesa where adequate filtration exists a 3—log (99.9%) rduction requirement is considered to be conservative and to provid, a comparable level of protection for water purifiers to a well-operated filtration treatment plant. Data on environmental levels for cysts in natural waters is limited because of the difficulties of sampling and analysis. Unpublished data indicate very low levels from less than I/L to less than tOIL. Here a 3-log reduction would provide an effluent of less than 1/100 I ., comparabl. to the r.cemeendad virus reduction requirements. Either Giardia Lamblia or the related organism, Giardia suns vhi ch is reported to be a satisfactory test organism (Hoff, etal., 1985), may be used as the challenge organism. Tests will, be conducted with a challeng, of 106 organisms p .r liter for a 3—log reduction. Where the trea ent unit or component for cysts is based on the principl, of occlusion filtration alone, tasting for a 3—Log reduction of 4—6 micron particles or spheres (Hational Sanitation Foundation Standard 53, as an example) is acceptable. Diff i- cultie. in the cyst production and seasurement technologies by lesser—equipped laboratories may require the use of such alternative tests where applicable. 8. MicrobiolOgical Purifier Test Procedur I • Test Waters a. The general test water (test water *1) ii designed for the normal, ion—stressed phase of testing with characteristics that say aaily be obtained by the ad us erit of many public system tap waters. b. Test water 02 is intended for th. stressed phase of testing wbere unit. involve haloqen disinfectants. 1) since the disinfection activity of some halogens falls with a rising H , it is important to stress test at an •1svat.d p0. The recommended level of 9.0 * 0.2 while exceeding the r.cosmended secondary level ( viroft*SfltaL Protection Agency, 1984) is still, within a range seen in coma natural waters ( tvironuertt*L Protection Agency. 1976). However, for iodine—based units, a sscond stressful condition is provided -— a pH of 5.0 t 0.2 since curr.nt information indicates that the disinfec- tion activity of iothne falls Mith a Low pH (Wational Research Council. 1980). While beneath the recommended secondary level (Env ronaental protection Aq.ncy 1984) a p11 of 5.0 is not unusual in natural waters (Vwirofl ent.sl Protection Agency, 1976). —24— ------- 2) Organic matter as total organic carbon (Toe) is known to interfere with halogen disinfection. While this TOC is higher than levels in many natural waters, the designated concentration of 10 mg/L is cited as typical in stream waters (Cu Ip/Wesner/Cuip. 1978). 3) High concentrations of turbidity can shield sicroorgartiuts and interfere with disinfection. Whil, the recommended level of not less than 30 NTU is in the range of turbid— ides seen in secondary wastewater effluents, this level is also found in many surface waters especially during periods of heavy rainfall and snow melt (Culp/Wesn.r/Culp , 1978). 4) Studies with Giardie cysts have shown decreasing halogen disinfection activity with lower temperatures (Jarrol.L, etal., 1980), 4’ C, a co on low temperature in many natural waters, is recoan endad for the stress test. 5) The amount of dissolved solids (TDS) may impact the dis- infection effectiveness of units that rely on displaceable or exchange elements by displacement of halogens or resins, or it may interfere with adsorptive processes. While TDS levels of 10,000 sg/L are considered unusable for drinking. many supplies with over 2,000 ag/L at. used for potable purposes (Environmental Protection Agency, 1984) The recommended level of 1,500 mg/L represents a realistic stress chafleng.. c. Test water 03 is intended for the stressed phase of testing of ceramic filtration candles or unita with or without silver impregnation. 1) Since viruses are typically sluted f roe adsorbing media at high p85 (Environmental Protection Agency • 1978) it say be concluded that a high p8 will provide th. most stressful testing for a ceramic-type unit, consequently. the high natural water pH of 9.0 is recommended. 2) Expert opinion also holds that organic material will interfere with adsorption of viruses • Thus, a high total organic carbon Level of not less than 10 mq/L is recommended. 3) Turbidity may enhance the entrapment and removal of microorganisms but it also say stimulate ‘short- circuiting’ through some units. A. turbidity level of 30 NTU will provide stress at time of sampling but the non—sampling level of 0.1—5 NTU will, allow routine operation of units. 4) Expert opinion was that low water temperatures and high TDS would most likely interfere with virus reduc- tion by adsorptioni consequently, a 4’C temperature end 1,500 mg/I TDS are recommended. —25— ------- d. Test water *4 is intended for the stressed phase of testing for ultraviolet (LIV) units. 1) In general, high TOC, turbidity and TOS and low tamperature are considered most stressful for LIV, and the indicated challenge levels are the same as for test water *2. 2) The pH is not critical and may range from 65 to 8.5. 3) In order to test the LIV units at their mast vulnerable stage of operation, a color challenge (Light absorption at 254 ne) is to be maintained at a level where LIV Light intensity is just above th. unit’s Low intensity warning alarm point. However, an alternat, to the absorption challeng, I. provided through adjusting the light intensity output of the LIV lamp electronically by reducing current to the lamp, or other appropriate means, to be just above th. alarm point; this approach would b. particularly necessary where the LIV lamp is preceded by activated carbon txsetment. e. est water *5 is intended for th. stressed leaching tests of units containing silver. Low pa, TOC turbidity, end TOS and higher temperature are felt to be the characteristics associated with increased leachebility. Th. recommended pH of 5.0 .2, while being beneath th. recommended secondary rang, of 6.5—8.5 (Environmental Protection Ag.rtcy, 1984) is stilt found in some natural waters. 2. Test Procedures The plan for testing and sampling is designed to reveal unit performance under both noraal and stresssd operating condi- tions. The stressed phas. would utiliz, a set of water quality and operating conditions to give the units a realistic worst case challenge. Testing plans for a specific model might involve modifications to the recommended plan; more sample. could be taken and analyzed; more units could he studied. The principl, of demonstrating adequate pert ormanca even under rmaU.stic worst case conditions should be maintained and the final selected test procedures should be agreed as between investigators and reviewers or regulators. While some aspects of the testing procedures have been utilized in actual experiments, the proposed protocol has not been verified or utilized for the various units that may be considered. Cons.qu.nt ly, investigators and users of this protocol may find reasons to alter some aspects through their practical experience; needed changes should be discussed and cleared with involved reviewers/regulators. —26- ------- APP 1DIX A REFERENCES : Berg, C. 1971. Integrated approach to the problem of viruses in water. .7. ASCE, Sanit. Eng. Div. 97:867—882. Cu].p/Wesn.r/Culp. 1978. Guidance for planning the location of water supply intakes downstream from municipal wastewater treatment facil- ities. E A Report, Office of Drinking Water. Washington, DC. Craun, G.F. 1984. Waterborne outbreaks of giardiasis: Current status, pp. 243—261. In: D.L. Erlandeen and E.A. Meyer (eds.), Giardia and giardiasie. Plenum Press, New York. DeWalle, F.B., .7. Eng.set and P 1. Lawrence. 1984. RemovaL of Giardia iambus cyst by drinking water tr.a 1snt plants. Report No. A—60O/ 52-84-069, Office of Research and Development, Cincinnati, OH. Engelbrecht, R.S., etal. 1980. Comparative inactivation of viruses by chlorine. AppL. Environ. Microbiol. 40:249-256. Environmental Protection Agency. 1976. Quality criteria for water. Washington, DC. Environmental Protection Agency. 1978. Human viruses in the aquatic environment. Report to Congress. k—57O/9-78—OO6. Environmental Protection Agency. 1984. National secondary drinking water regulations. A—570/9—76—000, Washington, DC. Environmental Protection Agency. 1985. National primary drinking water regulations, synthetic organic chemicals, inorganic chemicals and microorganisesi Proposed rule. Federal Register, Nov. 13, 1985. Farrah, S.R., and S.A. Schaub. 1983. Viruses in wastewater sludges. In: Viral Pollution of the Environment (C. Berg, •d.). CRC Press, Boca Raton, Florida. pp. 161-163. 4 Gerba, C.P., .7.9. Ross and $.N. Singh. 1985. Waterborne gastroentaritis and viral hepatitis. CRC Critical Rev. Environ. Contr. 15:213—236. Harak.h, N., and H. Butler. 1984. Inactivation of human rotavirus. SA—1 1 and other satiric viruses in effluent by disinf.ctants. 3. H . Cub. 93t157—163. Hoff, J.C., LW. Rice and ?.W. Schaefer. 1985. Comparison of animal infectivity and •xcystatton as measures of Giardia suns cyst inactivation by chlorine. ppl. Environ. Microbiol. 50:1115—1117. Izard, D., C. Farnagut, F. Gavini, K. Kersters, 3. DeLay and K. L..clsrc. 1981. Klsbsiella terrigena , a new species from water and soil. Intl. 3. Systematic Bactsriol. 31:116—127. -27— ------- Jakubcwski, ii. 1984. Detection of Giardia cysts in drinking water. Ins Giardia and Giar&iasis (S.L.. Erlandsan and E.A. Meyer, eds.). T.ni Press, NY. pp. 263-286. Jarroll, E.L., A.K. gingham and E.A. Meyer. 1980. Giardia cyst destr ac— tion: Effectiveness of six small—quantity water disinfection methods. Am. 3. Trep. Med. 29:8—11. JarroU, E.L., A.K. Bingham and E.A. Meyer. 1981. Effect of chlorine on Giardia cyst viability. Appt. Environ. Microbiol.. 43s483-487. Liu, O.C., etal. 1971. Relative resistance of 20 h aan .nt.ric viruses to free chlorine in Potomac River water. Proceedings of 1 3th Water Quality Conference (V. Snoeyink and V. Griffin, eds.), pp. 171—195. University of. Illinois. Melnick, J.L. 1976. Viruses in vater. In: Viruses in Water (G. Berg, H.L. Bodily, E.H. Lennette, J.L. Hslnick and T.G. Metcalf, ads.-) Amer. Public HIth. Meoc. Washington, DC. pp. 3—11. National Research Council.. 1980. The disinfection of drinking water, pp. 5-137. In: Drinking Water and Health. VoLuae 2. Washington, DC. National. Sanitation Found*tiOn. 1982. Drinking water trea nt units: Health effects. Standard 53. Ann Arbor, M I. Viassoff, L.T. 1977. iClabsiella . In: Bacterial. Indicators/Health Hazards Associated with Water A.W. Hoadley and B.J. Dutha, •ds.). American Society for Testing and Materials. Philadelphia, PA. pp. 275-280. World Health Organization. 1979. Huaan Viruses in Water, Technical. Support Series 639, World Health Organization, Geneva. woi 1d Health Organization. 1984. Guidelines for Drinking Water Quality. Vo]uae 1 • Recouend&tiefti. World Health Organization, Geneva. —28- ------- APP DIX B L.IST OF PARTICIPANTS: TASK FORCE ON GUIDE STANDARD AND PROTOCOL FOR TESTING MICROBIOLOGICAL WATER PURIFIERS Stephen A. Schaub, Chairman —— U.S. Army P dica]. Bioengine.ring Research and Development Laboratory (USAMBRDL), Fort Detrick, Maryland 21701, FTS: 8/935—7207 —— Coma: 301/663—7207. Frank A. Bell, Jr., Secretary — — Criteria and Standards Division Office of Drinking Water (WH—550), Environmental Protection Agency, Washington, D.C. 20460, Phone: 202/382—3037. Paul aerger, Ph.D. - — Criteria and Standards Division, Office of Drinking Water (WH-550), Environmental Protection Agency, Washington, D;C. 20460, Phone: 202/382—3039. Art Castillo -- Disinfectents Branch, Office of Pesticide Proqrans (TS—767C), Environmental Protection Agency, Washington, D.C. 20460, Phone: 703/557—3965. Ruth Douglas —- Diathf.ctants Branch, Office of Pesticide Programs (TS—767C), Environmental Protection Agency, Washington, D.C. 20460, Phone: 703/557—3675. Al Dufour —— Microbiology Branch, Health Effects Research Laboratory, Environmental Protection Agency, 26 W. St. Cur Street, Cincinnati, Ohio 45268, Phone: PTS: 8/684—7870 —— Coma: 513/569—7870. Ed Geidreich - - Chief, Microbiological Treatment Branch, Water Engineering Research Laboratory, Environmental Protection Agency, 26 W. St. Clair Strict, Cincinnati, Ohio 45268, Phone: FTS: 8/684—7232 —— Com* 513/569—7232. Charles Gerba. - — Associate Professor, Department of Microbiology and Im inology, University of Arizona, Tucson, Arizona 85721, Phonci 602/621—6906. John Hoff — Microbiological Treatment Branch, Water Engineering Research Laboratory, Environmental Protection Agency, 26 W. St. Clair Street, Cincinnati, Ohio 4526$, Phone: S: 8/684—7331 —— Coma: 513/569—7331. Art Kaplan —— U.S. Army, Natick R&D Center, AttA: SrR.NC_TE, Natick, Massachusetts 01760—5020, Phone: 617/651—5525 (5526). Bela Krishna.n -— Office of Research and Development (RD—681) Environmental Protection Agency, Washington, D.C. 20460, Phone: 202/382—2583. John Lee -— Disinfectants Branch, Office of Pesticid* Programs (TS—767C) Environmental Protection Agency, Washington, D.C. 20460, Phone: 703/557—3663. -29- ------- Dorothy Portn.r -- Disinfectanti aranch, Office of pesticide Programs (1$767C), tnvironmefltal Protection Agency, Washington, D.C. 20460, PkOeez 703/557—0484. Don Reasoner -— jcrobiologicaL Treatment ranch, Water Engineering Research L.aboratory. EnvirOnfl ental Protection Agency, 26 W. St. Clair Street, Cincinnati, Ohio 45268, Phone: £rS: 8/684—7234—— Comm: 513/569—7234. P. Regunathan (R.gu) -- Everpure, Inc., 660 N. Blackhawk Drive, Westeont, Illinois 60559, Phone: 312/654-4000. David Stangal —— Policy and Analysis Branch, Offic. of Co*pliance nitoring, Environmental Protection Agency, Washington, D.C., Phon•z 202/382-7845. Richard Tobin -— Monitoring and Criteria Divtston, Environmental Health Center, Department of Halth and Welfare of Canada, 1’unney’s Pasture, Ottawa, Ontario, K1A 0L2, Canada, Phone: 613/990—8982. — 30- ------- APPENDIX C RESPONSE 3! REVIEW SUBCOMI4ITTEE* TO PUBLIC COMMENTS ON GUIDE STANDARD AND TOCOL FOR TESTING MICROBIOLOGICAL WATER PURIFIERS A. Recommendation for the use of Giardia la nblia cyst. as a replacement for Giardia suns cysts as the protozoan cyst test organisms. The subcommittee concurs with the recommendation and further endorses the use of Giardia lamblia as the preferred cyst test for evaluation of all trea ent units and devices. Obviously the use of the proto— zoan organisme of actual health concern in testing is amet desirable. Anyone finding the Giardia lamblia strain feasible for testing and coat-effective to rk with is encouraged to use seas instead of Giardia mtznis . B • Substitution of 4—6 micron bead or particle taste as an alternate option instead of the Giardia cysts for evaluating devices that rely strictly on occlusion filtration for microbiological removal: Several commentens criticized the use of beads or particles (e.g., A.C. fine dust) and recommended only use of live Giardia cysts for performance tests. Discuss ion : The subcommittee recognizes and favors the use of the natural human parasite, Giardia lemblia , but was not aware of any convincing scientific data which would disallow the optional use of tasting with beads or particles for units or devices using on].y occlusion filtration to remove microorganisms. Previous development of the National Sanitation Standard (NSF) 53 (1982) r.quir.asnt for cyst reduction (using 4—6 micron particles as cyst models) was based on engineering and scientific opinion and experimental evidence at that time. Specifically, Logsdon( 1 ) used radioactive cyst models in the initial phas. of a study of removal efficiencies for diatceaceous earth filt.rs, .u squ.nt experiments with Giardia muris cysts con— firmed th. efficacy of the diatoaacsous earth filters. Further studies by l4ricks( 2 ) and DeWalle( 3 ) with Giardia iambus cysts also shoved cospa sb1,. reduction efficiencies for diatomaceous earth filters. Subs usntly confirmatory parallel testing results have been developed vie—a—vie 4—6 micron particles as compared to Giardia lamblia cysts. Specifically, two units listed by NSF for cyst reduction (using 46 nicron pareiclea)( 4 ) have also been tested and listed for 100% efficiency reduction (using Giardia iambus cysts) by Hjb] •r( 5 )g S.A. Schaub; F.A. Bell, Jr.; P. Berger; C. Gerba; 1. hoff; P. Regunathan; and R. robin. [ Includes additional revision pursuant to Scientific Advisory Panel review (Federal Insecticide, Fungicide, and Rodenticide Act)1 —31— ------- (1) Everpura Model 4—SC (2) Royal Doultott Model F303. Again w prefer the use of the human pathogen, Giardia lamblia however, no experi ientaL data has been provided regarding the lack of validity or of failure in previous tests utilizing beads or particles of 4-6 microns. In moat cases the bacterial or viral challenges to occlusion filters will represent a greater problem in terms of microbiological reduction requirements than vii i. cysts. Therefore, without substantiation of deficiencies, the use of 4—6 micron beads or particles is considered to be as feasibl. as the use of live cysts for routine performance tasting of water filtration (occlusion) devices. Recommendation : Recom_mend retaining the optional use of 4—6 micron particles or beads for cyst reduction tasting in occlusion filtration devic s only. References : ( 1 )Logsdon, G.S., at al. Alternative Filtration Methods for Removal of Giardia Cyst and Cyst Models, JAWWA, February, 1981. ( 2 )t.ogsdon . G.S., Hendricks, D.W., etai. Control of Giardia Cysts by Filtration: The Laboratory’s Role, presented AWWA Water Quality Tschnology Conference, December 6, 1983. ( 3 )DeWaUe, etal,. RmmOVai of Giardia lamblia Cysts by Drinking Water Trsa nent Plants, Grant No. R806127, Report to Drinking Water Research Division, US. EPA (ORD/MERL), Cincinnati, Ohio. 4 )Hetional Sanitation Foundation, 1986, Listing of Drinking at.r Trea snt Units, Standard S3. May 21, 1986. 5 Kib1er, C.P. 1984. M Evaluation of Filters in the Removal of Qiardia laeblia . Water Technology, July, 1984, pp. 34—36. C. Alternate amsay techniques for cyst tests (J.naan): Proposed aitsretions in cyst tests include a different method for separating cysts from fecal material and an assay method involving the counting of tro I ozoits as veil as intact cysts. Both alterations have been uied by ain am, •tal. (1979, Exp. Parasito]., 47 284291). Recommendation : These alterations appear to be reasonable laboratory procedures. supported by a peer-reviewed article and wilt be includd in the Report as options for possible development and use by interested Laboratoriss. —32— ------- D. The use of pour plate techniques as an option for Kiebsiella t.rrigefla bacteria analyse 5. RecommendatiOn The pour plate technique adds a heat stress factor to the bacteria which constituteS a possible deficiency. However, it is a recognized standard method and probably will not adversely affect the KIebsiella terrigefla . Consequently, it will be added to the Report the acceptable techniques. E. Option of using Escherichia coil in lieu of Klabii.lla terrigerta for the bacterial tests. Discussion : Appendix A, Section A.1 • of the Guide Standard and Protocol sets forth the basis for selection of K. terrigefta as the tsst bacteria. The selection was made along pragmatic lines emphasizing th. occurrence of K. t.rrigerta in surface waters and that it would represent the enteric bacteria. It was also pointed out that th. tests with virus and Giardia were expected to be more severe than the bacterial tests. Per compreheftsivsflss s bacterial tests were included in th. protocol but were not felt to be as crucial as the virus and Giardia tests. E. coli , or any number of other generally accepted indicator bacteria, could be used for the test program if they were shown to-have good testing and survival characteristics (equivalent to I C. . 3 !na) by the interested research laboratory. Recommendation : Thi intent of the Guide Standard and protocol is to provids a base- line program subject to modific*tion when properly supported bY an interested laboratory. Cona.qusntty, any laboratory could propose and with proper support (demonstrating challenge and test equivalency to K. use Escherichl* colt or one of the other enteric bacteria. This ides wiLl be included in revised wording Lit Section i.i.a, Gen•rai Guids. F • Perfox menCe requirements for Giardia cysts and virus in relation to the D&—I.cos.endSd Msximum Contamination Levels (RMCL) of zero. Discussion : The RZ4CLs of zero for Giardia and viruses which have been proposed by EPA are health goals. They are not enforceable standards since to assure the presence of organusms would require n infinite sample • The rationale for the recommended performance requirements for Giardia cysts and virus is set forth in Sections A.2 and A.3 of Appendix A. We feel that these requirements together with the application of realistic worst case test conditions will provide a —33— ------- conservative ,gt for units resulting in treated effluent water equivalent to that of a public water supply see tirtg the inicrobic— Logical r.quir •nt5 and intent of the National Primary Drinking water Regulations. Recommendation : Retain recommended performance (log reduction) requirements for cyst and virus reduction. G. Rotavirais and its proposed assay: One commsntr states that the rotavirus tests are impractical because Asirtharajah C 1986, J WWA, 78:3:34—49) cites ‘no satisfactory culture procedures available for analysis of these pathog.nc and therefore, monitoring would not be feasible. Discus ci on Section 3.4.1.2, ‘Virus Testa ’ of the Report, presents means for culturing and assaying rctav ruses. The means for doing the rota— virus tests are available and are practical for application in the Laboratory . Dr. Amirtharajah was referring to th. field collection, identification in the presence of a wide variety of. microorganisms, and quantification as not being ‘satisfactory.’ Laboratory analysis of rotaviruses is practical but their field monitoring may not yet be feasible. Further, the selection of both poliovirus and rotavirue as teat viruses was necessitated by the fact that the surface adsorptive properties and disinfection resistance of th. various enteric viruses have been shown to differ significantly by virus group and by strains of a specific virus. 4hil. all •nt.ric viruses and their strains could not be cono.ically tested, it was determined by th. task force that at least two distinctly different virus types should be tested to achiave some idea of the diversity of removal by the various types of water purifiers. Polio and rota viruses have L. . distinctly different physical and chemical characteristics repre- sentative of th. viruses of concern. Polioviruses are small single strandd RItA viruses with generally good adsorptive properties to surface, and filter media while rotavirusas are over twice as large, are double strand.d RNA and in some studies have been found to P°$s $ lass potential for adsorption onto surfaces or filter media. These two viruses also have bean demonstrated to have some ithit different disinfection kinetics. Recommendation : Retain the rotaviru. test requirements. —34— ------- H. Definition of microbiologicaL water purifieri One general comment re v.st.d redefinition based on TM lack of any virus removal 0 require- ment in the EPA primary drinking water regulations, so that no virus reduction requirement should be included. Also, it was claimed that the separatioriof purifiers from non—purifiers would be a 0 disservice to consumers and other users. Discussion : Virus are recognized in the EPA regulations ris—a-vis a proposed recommended maximum contaminant level of zero. Since virus monitoring f or compliance with a possible MCL is not yet feasible, a treatnent requirement is necessary. Virus control will be considered in the Safe Drinking Water Act filtration arid disinfection tr.atnent regu- lations. The reduction of viruses by treatment is discussed by Amirtharajah (1986, JAWWA, 78:3:34—49). With respect to consumers and other users, we feet that the cutrent definition is appropriate arid necessary. The average consumer cannot be expected to know the dift.renc. between viruses, bacteria and cysts, or when a raw water will. oruill. not contain any of thess organisms. In order to protect th. average consumer, the subject units either alone or with supplementary traatnent should be able to cop. with all, of the specified organisms. Recommendations Retain the current definition for microbiological water purifier. I. Coverag, of units: Several comments related to the coverage of units. These question.. are addressed individually as follows: 1. Ultraviolet units that are used for supplemental treatment of water f roe public water system taps should not be covered. We agree that sudt units are not covered and parenthetical Language has been thaluded in Section 1.3.2.3 to clarify this point. 2. & special itatias should be given to units which remove Giardia and ba*tsrta bit not virus. Specifically, the meaning of $ection 1.2.4, ‘Exceptions, was addressed. The ception$ section was specifically developed to relate to the problem of ps blic water system. having disinfection but no filtration on a surfac, supply. Cysts alone have been found to survive disin- fection treatment and could be present in such treated, waters. In this case an effective cyst filter serves art independent, beneficial purpose and should not be required to be a microbio- logical water purifier. However, such a unit should not be used as sole treatment for untreated raw water. Additional. parenthetical language has been added to Section 1.2.4. 3. This entire treatment unit or system should be tested, not )uSt a single component. We agree but believe that it is sufficientlY clear without providing additional language. - —35— ------- 4. The protocol should be expanded to cover units for the reduction of ItS, SOB and other chemical pollutants. We felt that the introduction of non—microbiological claims to the standard would sake it large, unwieldy and duplicative of an existing third-party standards and testing program (see Section 1.2.5). J. Alleged preference of National Sanitation Foundation (NSF) over other laboratories for conducting the microbiological water purifier testing protocol. The comment indicated that we were giving NSF preferential treatment to the detriment of other laboratories well qualified to perform the required protocol. Discussion : We have made appropriate references to existing standards (*42 and #53) developed by the NSF standards development process. Standard 53, the health effects standard, was developed by a broadly based Drinking Water Treatment Units Committee, including representatives from local, State and Federal health and environmental agencies, universities, professional and technical associations, as well as water quality industry representatives. It was adopted in 1982 and the only test from it utilized in our Report has been substantiated as described in Part B of this Response. Nowher, in our report have we advocated NSF (or any other laboratory) as the prim, or only laboratory for implementing th. required protocol. R,coiwa end&tiOXU No action needed. K. Instruction concerning affective lifetime. One comment described an alternate means for determining lifetime where a ceramic unit Is brushed’ to renew its utility and is gradually reduced in diameter. A gauge is provided to measure diameter and to determine when replacement is needed. Recols m ftd tiOftS Where a anufactur.r provides a satisfactory 0 other means of determining lifetime, this should be accepted. Appropriate rds have been added to Section 2.4.1C. L. Ceramic candles should not be cleaned during testing because some consumers would not clean them and this would’provide the worst case teet. One comment asserted this point. —36— ------- Ojscugsjons There is some truth to this proposition. However, the other approach may also have validity. Frequent brushing may reduce filtration efficiency. In any event, where a manufacturer prascribe5 filter cleaning and how to do it, and provides a gauge to determine lifetime, we fee ], the testing program is bound to follow the manufacturer s directions. Recommendation : No change needed. M. Scaling up or down. One comment points out that one or more manu- facturers may vazy size of treati nt units by increasing or decreasing the number of operative units rather than the •iz. of the operative unit. The commet t suggests allowing scaling based on size of - operative unit. Recommendation : We agree with the comment and have added clarifying words to Section 3.5.3.3. N. Turbidity level of not less than 30 NTU for ceramic candles or units. One comment states that Such levels are impossibl. to utilize in testing mechanical filtration devices which will clog entirely or require such frequent brushing as to render the test impossibl, as a practical matter. Discussion : We recognized the potential. clogging probl.ms in Section 3.5.1 .a(2) where the 30 NTU water ii only to be appU.d immediately before and during each •saplinq event; the non—sampling turbidity level, which will be applied ever 90% of the on time, is currently set at not less PKari 10 ?urbtdIty levels, of 30 NTt1 are commonly found in surface waters duriz*q heavy rainfall or snow melt. Treatment units may be used under these circumstances, so this challenge level, should be retained. However, most usage will, occur under background conditions so the non—sampling turbidity levels should be 0.1—5 NTU. R commendationS : (1) Retain sampling turbidity Level of not less than 30 NTU, and (2) ange non-sampling turbidity level 0.1-s NTU. Appropriate wording changes have been introduced in Section 3.S.1.a(2) and in Appendix A, Section B. ------- 0. Ch.Loriz e in test water *5. One comment asserts that chlorine tertds to increas, silver Ofl leaching acti vity and that a high chlorine level should be included in the silver leaching tests but no reference or evidence, however, £5 provided to back this assertion. Discussioru We have no compelling evidence or reason to expect that chlorine will enhance th. leaching of silver. However, the prescribed l i pH and ‘TOS levels will provide, a clearly severe test for silver leaching. Recommendation : No change needed. P. Unnecessary difficulty and expense of test protocols. Several comments were made under this general heading. These coements are outlined and discussed as follows: • ibo many sampling events are required, sampling of a few units at start, middle and finish should be satisfactory’ The committee has carefully Laid out the standard and protocol and we feel the minimum sampLing plan must be maintained for the cons uasrs health protection. 2. Thre. units are too many to st y; parallel testing of two units should be satisfactory: For consumer protection, the Disinfectants Branch, Office of Pesticide Programs, has tradi- tionally required the testing of three units. The committee recognizes the additional cost involved in testing a third unit but feels that this vi ii provide a minimum level of assurance to prevent infectious disease and recommends retention of the 3—unit requirement. 3. The protocol requires larg. tanks and microbiological reseeding on a daily bsis: We feel that the t&nk size requirements are not extreme and can be set by an interested laboratory. With respect to reseeding, it should be pointed out that virus and • cyst seeding need only be conducted immediately before and • during the sampling on• period (see Section 3.5.1.b(2)), equivalent to less than 1 0% of the on time • This spot seeding for viruses and cysts recognized the expense and difficulty of maintaining larg. populations of these organisms. Continuous seeding was provided for bacteria because they are easier to grow and maintain and might have the capacity to grow through come units, given enough time and opportunity’ 4. Challenge levels of contaminants are too high compared to known environmental conditions and the required log reductions exceed Safe Drinking Water Act requirements: As explained in a footnote to Table 1, Section 2, the influent challenges may constitute greater concentrations than would be anticipated in source -38- ------- waters. These levels are necessary to test properly for the rsquir.d Log reductions without having to utilize sample concen- tration procedures which are time/labor intensive and which may, on their own, introduce quantitative errors to the microbio- logical assays. As mentioned in P&rt I of this paper, the lo reductions for bacteria, virus and Giardia have been suggested for public water system trea nent in a paper by Amtrtharajah (1986, JAWWA, 78 :3:34—49). The reductions in the microbiological purifier standard are entirely compatibl. with the reductions cited for public water supply treataent. -39— ------- |