UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C.  20460
 March 9,  1988

Hon. Lee M. Thomas
                                                    SAB-EHC -88-021
                                                                  OFFICE Of
                                                               THS ADMINISTRATOR
U.S. Environmental Protection
  Agency
401 M Street, SW
Washington, IXC,  20460

Dear Mr. Thomas;

     The Drinking Water Subcommittee of the Science Advisory Board's Environ-
mental Health Committee has completed its review of scientific information
supporting EPA's efforts to develop proposed rules for surface water treatment
and coliforms and is pleased to forward its report to you.

     In summary, the Subcommittee ^

     o ftgrees that using total coliforms as the primary standard is reasonable
       and endorses EPA's intent to develop a guidance document for this rule.

     o Reconmends that EPA be more specific regarding the disinfection require-
       ments to be used following filtration.

     o Expresses concern over the adeguacy of the scientific basis for some
       of the requirements and the documentation for the disinfection ocsnponent
       of the rule.

     o Reccmmends that the guidance document accompanying the proposed surface
       water treatment rule stress that raising the concentration of chlorine
       to meet the needed contact time (CT) values may affect the future ability
       of water suppliers to conply with new disinfectant regulations.

     o Concludes that the tracer approach for CT Is generally scientifically
       supportable but suggests certain refinements.

     o Concludes that insufficient data exist to demonstrate that implementation
       of the proposed filtration rule will significantly reduce tegionellosis .

     o Reccnmends additional research in various areas, including the effective-
       ness of the intended treatment techniques for j^ionellosis .

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                                   -2-
     Itie Stifeocnmittee appreciates the opportunity to review the scientific
bases Of tlfese proposed rules.  We request that the Agency officially respond
to the scientific advice presented in the attached report*
                               Sincerely,
                               Norton Nelson, Chairman
                               Executive Committee
                               Richard A. (rieserner, Chairman
                               Environtnental Health Cawnittee
                                              ~
                               Gary^Carlson, Chairwan
                               Erinking Water Subccnmittee

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   Drinking Water SubcoTOittee Review of the Scientific Bases of Proposed
             Rules for Surface Water Treatment and Conforms

     the  ttrinking Water Subcommittee met on August 6 1987 to consider a draft
report prepared lay its Filtration Technology Workgroup following the latter1s
review of scientific information supporting EPA's efforts to develop proposed
rules for surface water treatment and conforms.  Appendix A presents the roster
of the Subcommittee and the Msrkgroup.  The documents under review are listed
in Appendix 8.  Appendix C includes the rationale EPA used in developing the
rules, and Appendix D is a fact sheet provided by the Office of Drinking Water
(OOW) for the two rules.

     The Filtration Technology Workgroup first met on May 22 1987 to identify
the issues for its review and procedures for conducting its evaluation.  It
reconvened on August 5 1987 to further address the hey issues and prepare a
draft report for the full Subcommittee's consideration,  the report, in its
present form, represents the combined efforts of the Workgroup and the Sub-
committee.

I. Colifoim Rule

     Coliforms are the only group of micro-organisms for which enough scientific
data exist to develop an individual standard.  The Subcotmittee agrees with OWs
intent to continue to use total coliforra as a primary standard, and to rely upon
fecal coliforms to ascertain the public health significance of total colifonn
positives.

     Protecting public health by instituting early corrective actions, rather
than only repeat sampling, is reccmnended.  The Subcommittee endorses EPA's
plan to develop a guidance document for this rule.  Guidance on actions such
as boosting disinfectant residual, flushing, more intensive treatment plant
and tapwater disinfectant residual monitoring and cross-connection investiga-
tion should all be addressed in this document*

     The rule proposes the use of random sampling sites rather'than fixed sites.
The Subcommittee recommends that EPA revise and reword this concept because*
as written, it is not clear.  EPA should also develop a strategy for a larger
number of fixed sites for periodic sampling.  The Subecronittee does not endorse
totally random sampling.

     The Subcommittee recommends the use of heterotrophic plate count  (HPC).
Although EPA's rationale justifying its use is interference in colifonn measure-
ments, it has merit on its own as a disinfection performance verification criter-
ion.  The Subcommittee also recommends that the Agency consider other plating
methods (referring specifically to the sixteenth edition of Standards Methods)
and media as alternatives to the pour plate method.  These more sensitive methods
are more stringent but easier to apply.

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                                   -2-
     More thought needs to be given to the practical application of the CT
concept as a regulation,  fts chlorine reacts it changes, for instance, frcm
free to monoqhloramine to organic chloramine.  Measuring a residual at the
end of a time period, therefore, can lead to erroneous CT values.  Many water
utilities now use one disinfectant during treatment, and another subsequently.
The Subcommittee recommends that at least two points of measurement be used at
a minimum:  1) the end of the contact basin or plant, and 2} the first distribu-
tion system sampling point, where CT =
     Research is needed both in the laboratory and in the field on the effect
of confounding variables on the magnitude of CT.  In the laboratory, data are
needed on the CT values for Giardia strain variation.  A further rationale for
laboratory and field data is to identify the effect of micro-organism aggrega-
tion on CT.  The effects of filtration, sedimentation and coagulation on these CT
values are especially important.

     In summary, the Subcommittee:  agrees with the form of the coliform rule;
endorses OWs effort to develop a guidance document to accompany the rule;
recommends that the concept of random sampling should be revised; reconmends
that EPA consider other HPC plating methods that are of equal or greater
stringency; and agrees with the use of CT, but recoiwiends better definition.

II. The Filtration Rule and Guidance Manual

     The proposed filtration rule is needed to protect public health because
of the lack of scientific data on specific micro-organisms that can pose a
significant risk.  Waterborne disease outbreaks persist in the U.S., and
pathogens are not readily detected.  EPA is proposing this general rule
instead of establishing standards for specific contaminants.  'Die specific
filtration requirements are presented in the rule, while an associated
guidance manual discusses other issues not subject to regulation.

     The Subcommittee's ccntnents address four issues:  1) allocation of
microbiological removals between filtration and disinfection processes when
both are provided; 25 regulations for adequate filtration of low turbidity
supplies; 3) possible disagreements between the surface water treatment
rule and the guidance manual} and 4) documentation of the scientific bases
of the rule and the manual.

     The Subcommittee supports the goal of requiring filtration and disin-
fection of all surface water supplies because they will provide consumers
with greater, protect ion from microbiological contamination and with improved
water quality.  Also, it is not clear that a less stringent requirement will
be effective- in preventing waterbome disease.  The Subcommittee recognizes,
however, that not all water consumers are at equal risk fron contamination
and that in the adoption of such a goal other factors needed to be considered
by policy makers, including economic and technological feasibility.  A key
isssue in deciding whether to implement this goal rests upon a definition of
acceptable risk; this issue is chiefly one of a social/value judgement rather
than scientific judgement.

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                                    -3-
     The performance of actual filtration facilities can vary widely, but
well operated plants can achieve substantial (three and four log) removal of
seme micro-organisms.  The key to successful filtration lies in proper
pretreatmentv i*e. coagulant addition, and (usually) flocculation and
sedimentation.

     The surface water treatment rule proposes a filtered water turbidity of
0.5 nephelometrie turbidity units (NTUs).  this is achievable by all well
operated filtration facilities, but it does not guarantee effective treatment
for plants treating low turbidity sources.  The 0.5 NTU requirement should be
supplemented with other criteria, such as per cent removal of turbidity and/or
heterotrophic plate count to better evaluate filtration performance.

     The surface water treatment rule and the guidance manual contain some
conflicts.  For example, the rule requires 99.99 per cent inactivation of
enteric viruses after filtration of clean water, while the manual recommends
only 2 log units.  Also, the rule requires 3 log units removal of Giardia
and 4 log units removal of enteric viruses by a combination of filtration
and disinfection, while the manual recommends these levels be achieved by
disinfection alone after filtration.

     Many filtration and disinfection requirements in the proposed rule and
statements in the guidance manual are not well supported by peer reviewed
scientific documentation,  in some cases/ OEK relies upon presentations,
unpublished papers and unreferenced reports when more authoritative evidence
is available.  This is the case for much of the rule.  For disinfection, some
important studies and analyses have not yet been published and, thus, their
validity remains to be established.  EPA should develop regulations on well
documented peer reviewed data,

III, Issues Related to Contact Time

     A. Need_for Both CT and FiltrajzjLon.  The use of the CT concept provides
valuable support for the filtration rule.  However, more data are needed to
apply it for controlling Giardia.  Also, more attention needs to be given
to the problems encountered in measuring CT because of the large uncertain-
ties.

     Ihe Subcommittee recommends that CT be used as a disinfection control
procedure.  Because of the lack of sufficient scientific measurements, it
does not favor CT to eliminate the need for filtration because of the
utility of the multiple barrier principle.

     The disinfection of well filtered water supplies is easier and more
effective than for unfiltered supplies, and this should be reflected in
the rule and the manual*  Disinfectant requirements, in terras of CT for
filtered supplies, should be stated in the rule, and guidance for their
implementation should be included in the manual.  The guidance should
also reflect the observation that a CT unit of disinfection will provide
a greater micro-organism kill in filtered water than for an unfiltered
supply.

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     B. Values of CT Proposed.  The literature support for the CT values
proposed is based upon a few unpublished reports and theses. ' For Giardia,
the data are based on one study that has not been peer reviewed.  Few data
are available on confounding factors such as strain variation, aggregation
potential and association with particulate matter.  All three are of concern
for viruses* and the fact that CT values in the guidance manual are related
to Gijjrdia, which has substantially greater CT values than viruses, reduces
but does not eliminate the significance of this emission for particle asso-
ciation.  The potential for aggregation of Giardia cysts in the natural en-
vironment and strain variation in sensitivity to disinfection are not address-
ed in the supporting documentation,  The Subcommittee recommends that further
research be conducted to address these issues, but implementation of such
research should not delay or impede issuance of the rule.

     The Subcommittee has several concerns over the major document upon
which the Giardia GTS are based.^  The Clark paper is an analysis of the
data for the only inactivation study based on animal infectivity rather
than in vitro excystation.  The Subcommittee requested an additional review
of this manuscript by Dr. Charles Haas of the Illinois Institute of Tech-
nology.  His concerns correspond with those raised by the Subccnmittee*
The two major concerns include possible problems with the design of the
Hibler study (which cannot be addressed because the raw data are not avail-
able) , and the appropriateness of the Clark paper because of possible non-
linearities in the curves used,  lie Haas evaluation has already been sub-
mitted to the Office of Drinking Water.

     C. Measurement o£_CT.  Measurement of CT at maximum flow has limitations.
In order to determine a more accurate and precise value, the Subcommittee
reccmmends that CT be measured at several flow values to better define the
minimum CT, and not just the minimum T.  Further, the Subccnroittee observes
that the C value is likely to be variable with flow and the point of measurement*
Thus, the Subcommittee recommends that both C and T be measured for minimum,
average and maximum flow at the first distribution system sampling point.
The minimum value of CT (not miminum C times minimum T) should be used.
Tracer studies should be used to measure T, with 10 per cent of dose indicat-
ing the time.

     IV. filtration Rule—Legionella

     The Subcommittee concludes that insufficient data exist to demonstrate that
implementation of the filtration rule will significantly reduce Legionellosis.
It also concludes that this is an important consideration because?

     o The Centers for Disease Control estimates that approximately 50,000-
       100,000- cases of Legionelloeis occur in the U.S. annually,

     o Focdborne outbreaks, or secondary spread, have not been reported.

     o More than 28 million noninstitutionalized individuals in the U.S. have
       risk factors (age 65, iitmuno-ccmprcfnised status) that could predispose
       them to the disease.


1 Unpublished paper by Clark, et al., entitled "Inactivation of Giardia  Lamblia
by Chlorine:  A Mathematical and Statistical Analysis."             ~

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                                   -5-

     Although iggionella should be significantly reduced by filtration and
disinfection, its ability to regrow in the distribution system results in
an offsetting potential threat to the public health,  ihe Subcommittee also
believes that a reliance upon a residual in the distribution system may be
inadequate, -as there is little research to indicate necessary levels of
disinfectant required to eliminate Uegionella at the tap.  Ihe Subcommittee
concludes that there is, at present, no scientific evidence to indicate that
the proposed surface water treatment rule will significantly reduce lagion-
ellosis.

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                                Appendix A

                  Roster of  Drinking Water Subcommittee

Chairman;

Er. Gary Carlson, Department of Pharmacology and Toxicology, School of Pharmacy,
Purdue diversity, Vfest Lafayette, Indiana  47907

Membersand Consultants:

Dr» Julian B. Andelroan, Graduate School ot Public Health, 130 Desoto Street,
Parran Hall—Roan A-711, University of Pittsburgh, Pittsburgh, Pennsylvania
15261

or. Fose Eagirmanjian, Professor, Department of Pharmacology and Tbxicology,
University of DDuisville, touisville, Kentucky  40292

Mr. Jerone B. Gilbert, Manager, East Bay Municipal Utility District, 2130
Adeline Street, Oakland, California  94623

Er, Charles Gerba, Department of Microbiology and Bmunology, Building #90,
University of Arizona, Tucson, Arizona  85721

Er. William Glaze, Director, School of Public Health, University of California
at IDS Angeles, 650 Circle Crive South, tos Angeles, California  90024

Er, J. Donald Johnson, Professor, School of Public Health, University of North
Carolina, Chapel Hill, North Carolina  27514

Er. E. Marshall Johnson, Professor, Department of Anatony, Jefferson Medical
College, 1020 locust Street, Philadelphia, Pennsylvania  19107

Dr. Cavid Kaufman, Department of Pathology, University of North Carolina,
Room 515 Brinkhous-Bullitt, Chapel Hill, North Carolina  27514

Er. Nancy Kim, Director, Bureau of Toxic Substance Assessment, New York Depart-
ment of Health, Roan 359, Tower Building, Empire State Plaza, Albany, New York
12037

Mr. Richard Moser, vice President for Water Quality, American Water Wbrks
Service Confjany, 4001 Greentree Executive Campus, Suite B, Marlton, New
Jersey  08053

Er. Betty Olson, Progran in Social Ecology, University of California, Irvine,
California  92717

Er. Verne Ray, Medical Research Laboratory, Pfitzer, Inc., Groton, Connecticut
06340

Er. Harold Scheehter, Professor, Department of Chemistry, Ctiio State University,
140 Vfest 18th Avenue, Columbus, Chio  43201

Er. Robert Tardiff, Vice Chair, Principal, Environ Corporation, 1000 Potomac
Street, NW, Terrace Level, Washington,  D.C.  20007

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                                   A-2

Or. Thomas Tephly, Professor, Dgpartraent of Pharmacology, The Bower Science
Building, University of Iowa, Iowa City, Iowa  52242

Executive Secretary;

or. C. Richard Cothern, Executive Secretary, Envirormental Health Committee,
Science Mvisory Board (A-101F), U*S» Environmental Protection Agency,
Washington, D.C.  20460

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                                   A-3

                Roster of Filtration Technology workgroup

Co-Chairs'.

Mr. Richard Moser, Vice President for Water Quality, American Water Works
Service Ccnpany, 4001 Greentree Executive Campus, Suite B, Marlton, New
Jersey  08053

Cr, Betty Olson, Pregran in Social Ecology, University of California, Irvine
California  92717

Dr. Charles o'Melia, Professor of Environmental Engineering, Department of
Geography and Environmental Engineering, ihe Johns fibpkins university,
Baltimore, Maryland  21218

Cr. Joan Rose, Department of Microbiology and Inmunology, Building PHM,
#90, Room 201, University of Arizona, lUcson, Arizona  85721

or. Mark Sobsey, ESE-Public Health (201H), University of North Carolina,
Chapel North Carolina  27514

Executive Secretary;

Or, C» Richard Cothern, Executive Secretary, Environmental Health Ccnmittee,
Science Advisory Board, (A-1Q1F), U.S. Environmental Protection Agency,
Washington, D.C,  20460

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                                Appendix B

            Documents Subranitted by the office of trinking Water

 Proposed Rule (Surface Water Treatment Rule):  Water Pollution Control, National
  Primary  Drinking Regulations; Filtration, Disinfection, Turbidity, Giardia
  Laroblia, Viruses, Iggipnella, Heterotrophic Bacteria.  June 25 1987 (and
  earlier drafts dated April 21 and May 22 1987).

 Proposed Rule:  Water Pollution Control, National Primary Drinking Water
  Regulations; Tbtal Coliforras. June 25 1987 (and earlier drafts)

 Guidance Ebcument for the Surface Water Treatment Rule

 Drinking Water Criteria Documents for:

  Total Coliforras» April 16 1984

  Giardia, February 29 1984

  Legionella, March 1985

  Turbidity, September 1 1985

  Viruses, June 1985

  Heterotrophic Bacteria, May 25 1984

Manuscript by M. Brett Borup, "The Determination of Waterborne Pathogen Sampling
  Requirements using Statistical Quality Control Techniques," Tennessee Technical
  University, Clarksville, Tennessee

Manuscript by Robert M. Clark, Eleanor J. Read and John C. Hoff, "Inactivation
  of Giardia by Chlorine:  A Mathematical and Statistical Analysis," U.S.
  EnvTrorniental Protection Agency, Cincinnati, Chio. May 1987*

Manuscript by John C. toff, "Inactivation of Microbial Agents by Chemical
  Disinfectants," U.S."Environmental Protection Agency, Cincinnati, Chio

Manuscript by Stig Regli, Appiah todrthairajah, John C. Hoff and Paul Berger,
  "Treatment for Control of Waterborne Pathogens;  Bow Safe Is Safe Enough?"
  U.S. Environmental Protection Agency, Washington, D.C.

Appiah Amirtharajah, "Variance Analysis and Criteria for Treatment Regulations,"
  Journal of the American Water Works Association (March 19863, pp. 34-49.

 Draft Proceedings, "Workshop on Filtration:  Disinfection and Microbial
  Monitoring," American Water Works Association Research Foundation.

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                                Appendix c

     EPA Rationale for the Proposed Surface Water Treatment Regulations

     the overall purpose of the surface water treatment rule is to control
waterborne disease incidence caused by pathogens in public water systems using
surface water sources.  The rule will serve as minimum criteria which,
for the most part, should be maintained when new disinfection by-product
regulations are promulgated.  The Workgroup recognises that the rule may
affect the criteria contained in future disinfectant by-product regulations.

     The rule also represents EPA's attempt to respond to Congressional
requirements, i.e., to regulate Giardia, viruses, HPC, legionella,
and turbidity, within statutory deadlines, while not creating conflict
with future disinfection by-product regulations.

     EPA intends to set disinfection requirements for ground water at a
later date in conjunction with new disinfection by-product regulations.
In the interim, the total coliform rule, which pertains to both surface and
ground water systems, will identify systems with high risk from pathogen con-
tamination and, thereby, necessitate disinfection treatment.  Also, the coli-
form rule will help identify which ground water systems may be eligible for a
variance to the forthcoming disinfection requirements.

     The following general principles; as written in the preamble to the
proposed rule, form the basis for the criteria:

     1.  The public's best assurance for obtaining drinking water of
consistent good quality is reliance upon a properly designed and operated
public water system.

     2.  Water to be used for human consumption should be obtained fron
the best available source,

     3.  Ml surface water supplies are at risk from pathogen contamination,

     4.  Ml public water systems should practice adequate disinfection,
and detectable residuals of the disinfectant should be measurable in all
parts of the distribution system.

     5.  The level of treatment in public water systems provided should
at least be ccnroensurate with the potential for pathogen contamination in
the source water*  Multiple barriers of treatment, including filtration,
are desirable to provide a consistently high quality water supply.

     6.  to minimize the introduction of unnecessary contaminants during
treatment, public water systems should employ processes that will reduce
the concentration of precursor chemicals prior to the introduction of
disinfectant chemicals,

     7,  Public water systems should employ strong oxidants, including
ozone, chlorine and chlorine dioxide with adequate contact time for
pathogen inactivation before the water enters the distribution system.

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                                  -C-2-

Chloramines are appropriate for maintaining a residual in the distribution
system when stronger oxidants are not feasible.  Ozone, because of its
potency in destroying micro-organisms and its rapid dissipation, is
particularly encouraged for use In clarification processes and as a
disinfectant-*-

     8-  Public water systems should adjust pH levels to optimize
clarification and disinfection processes within the treatment plant and
corrosion control within the distribution system.

     9.  Mequate monitoring, tailored to the particular circumstances,
should be practiced in all public water systems.  This should include
monitoring of microbiological parameters, and physical factors affecting
water quality such as turbidity, pH, and temperature: and disinfectant
residuals.  Raw • water monitoring should be conducted to determine that an
adequate level of treatment is provided,

     10. No detectable concentrations of pathogens should be acceptable
in a properly operated public water system.

     11. The public has a right to be informed of the quality of the
water that is being provided by its public water system and should be
included in the decision processes.

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                                     D

  Fact Sheets for the Surface Water l^atmsnt and Coliform Rules
                       Apncy
          final rul»—E*c«ofc«r is,  19T7
              All pttie*vtw vyvtai mlng try
    «•£•£ BVt d£»iltf»St, TOd My b* S^SliJMd tO fll<
    of MO* for iJiKiiA, vlxiav, tMrtarotrpftdc plit*
                                                  in
            . .. .   mttimm «t l*t*t ff»f ,	
          in*ctiv«tian of Hl&tllJflfiUji cyvta «d 99.99
                   •O^j^uf COC j^^uJHCnEliM^vEC^yQ^^ iQ!C
    AH «y«t*n« nurt te
              by the Strtft.
           tteC to
soacam Hat«r Crlt«ria
        . cDlifoai^OLikJ«ti->Um ajgt not «oMi20/100 »1 or
    	total ooiifoBH ccnomtrvtian vvt not cMOHd 100/1,00
    ml b*form disinfection in mam th»nt«n ptitwrt of tb»



                               £or ftcil or total
        SS9QM SIZE  (p*q?l»)     SAMPUB
               <500                1
          900* 3000                2
        3,301-10,000                3
       10,000-23,000                4
            >25,000                5
         on* coliform a«n«ity twt BMt te Mdft «wy ctay
    the turbidity «09*ids m* JHU,  if rot *lr»«dy ortcta
    und«r abova r»qoir«n«nta.

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    Turbidity lavala mat t» aaaiuxvd *wy flaw bouzv
               or continuou* «ailtar±ng, and can not
Sit*
                navt adiiow at laast a 99.9 and 99,99
    parcarrt imefciwtkn of gJiiSii laafclift and antade,
    viruaaa.  This iiiBt ba d*ocrwtratad by ayBtam
    ncpt vmluM (<*cr* i* tte protet of r«aidual
    uj*j»itiaticn (inj/l) and cxxrtact tiat
    DUlnf«rticn tpttsmi mvt h«v» redundant
    Including alt«E»t» pomr »wLy/  «uttc»Btic alaza and
    •tut-iap to iiwzra oontinaoa di*litf*cticn of tba
          plant
    9ywt«n mwt mairttAin a diainf «ct«nt
                 of no I*M than 0.2»i/l in DO mem than
    f iv* paroattt of tlM «npl«« aach «orth for any
    crraanTtiva «anth«. Sainpla* ut ba titan at-
    Craguani^ M total oolifmM under tte yi.c|juaaJ, oelifiom
    rula.   (Saa Ttola 1 and T*bla 3 of Tbtal Oalifiam tact
    sywtam au*t nalntftin a di«inf actant raaidual
        ntr^ticn at all ti»aa in tha vatar antaring tte
                ayrtam,  damcrwtratad by
   ncnitccrircf.
                                   x
   sywtam nust maintain a vmtttihad ojitaul proijimn
   will minimiza tte potantial for ccntaminaticn by
   antaric vizu*a« and «•»"•«><• IfflfcUa cy»t»,   Syatam
   mitor and ccntzol tte  activitia* in tte vctorated tbat
   nay hav* an advar»a Inpact on wtar.  3y»tam met
   daviwteata through ownarmhip or wrlttan agr*aoanta with
   landownart in tte watar^had, that it i* abla to Unit
   and ecntzol all human activitiaa that «ay hava an adwrM
   iapact upon watar quality. An annual •anitaxy wurvay and
   ripoart mmt ba oonductad \jhich   i« approved by tte
    Syvtam Must not teva a history of any watarborna
    QUtte*ak» in its pi-aaant.' ocrfiguration.
    Sy*tam wt ba in oontimous oaplianoa with tte Icng
    tcm MX raqoimi*nt* for total oolifana.  (
    Coliform fact iteat,}

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                    with filtration aj»t tcMaua at laast
        t».» pacoant and 99, §9 parowtt unDvil/inictivvtiflR of
        Masm *** vtaisas, napactivmy.  stat* dafinav lav»l
        of disinf action vtgoixid, daparriing en tactaology and
        waarm uatar quality.
        Symtam w*t Maintain a dl*inf«ctant
             ntratlon of no lam than 0.2 «5/l In iv» vac* than
        fiv* paggmt of tfaa aavpla* aaA »onm for any
                    aoiths.  SOBMI malt la* takan at th« aa
                                                      ^**- *
        rul«.  (Sat T*bl* 1 and I*bl* 2 of Vbtal Oolif<3rm fact
        Sprtant oust aaintain a disinfectant	
             Ttrmticn at all tivaa in tha wetar entering th*
             !•- i. *    ^^^^^^^^^   •• -    fc-	-»	-* ^^* _-.*_•
                     ayvcaOf uaumatzwcaa 0y
        Tawting and aanpllng wt te in acooBOMiaa with
        Standard* Mathod«,  16th aditior, or Mrthoda afpcowd
        Em for total coliforaa, faeal oplifoea,  titrbldity,
        disinfectant iva^duals, tanparatur*, and fR*
Raoortina
        Monthly raport* to tha stata for all
                 in th» rula. •
        Unf iltarad. ivUr «y«taoB mist also import annually on
        thair watanhad omtiul program and aanitary mmvaya,
        Watar-boma rtliiiiM outtaraaks aist te peportad to tht
        Stat* within 48 hour*.
violation*
                %fith unfiltamd aurfaca mtazr
        •pat aouroa watar quality and «ita ipaicific oenditions
        vithin 4t aoneh* of pronulgaticn.  If thay fail to
        DMt thaa« critaria vithin  30 ncrtha, filtzmtion wsuld
        ba raquirad, but th«y would not ba in violation until
        failing to na*t auch caitaria after 48
        Filtavad «y«tanB oust n**t parfefaanoa critaria and
        monitorinq/riporting zaqtairansnts for tte filtacad and
        disinfection tr*atwnt tachnigu«« within 48 acntha of
        prcraulgation.


 f
                           -4-

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             ar* not applicabl*.
               arm allowed for r^quixwwnt to flltar.
    fymtmm uming «urfao» t*t«r au*t 
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        SURFACE WATER TREATMENT
I SYSTEM USES SURFACE WATER 7
           YES
                             NO
                                   RULE DOCS
                                   NOT APPLY
        F1_TRATONN PLACE?
i
              1
                      YES
MEETS SOURCE 1
QUALITY 4 SfTE-4
commons?
YES
VATER MEETS
jpEcnc m ** EXEMPTION ^ m —
CHTEflfA
YESJ
(TEMPORARY)
^
r
I VIOLATION |~«
1
NSTALLFLTRAT10N
OH 	
MOUFY TREATMENT


D6SWK OPERATION
PEHFOHyWICE CH1ERM
SATBfTO?
" 1
< 	 '

^_ 'ifVIUPI lAMPP ^t 	 " — '
YE!
t______ 	 — ^»> tAJMrUnnwC ^^
             DECISION TREE

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Office of Drinking lister
BwiSGOMnbal Prot*cticn
       1987
                                1, 1987
          Final rul»—D*o«ib«r 19, 1SS7
         contaminant l«v*l goal—z*ro

         contaminant
                     OK*
          ,  rBthtr than d*n«ity.

    Manthly'HBL

    —  No norm than 1 colifoc»ix«itiv» «a^l«/nanth for
                         ftutir than 40 «apl«i/incrTtl\.
    —  No nor* than 5% of saqplM can te csoliforur-
        po«itiv» if •?•&• a^ialyz«8 at l««t 40
   —  HO aoc* than SI of ne*t rtoKit 60 sa^l«i oolifotm-
       pc«itiv« if «y»t«B analyz*« f «MT thin 60
   —  No aorm than si of all «npl« in th*
              fflcntn* eolifen-^ovitivii if »y«t«ii analyze
            than €0
  Mcnitoring fr«qu*ncy

    (•M attached Tabl« I and Tabl« 2 for norc detail)

    For «ywt«« a*rvtng 3,300 parpens or fouvr;

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 — 5 sasplas/acitth, with, lau mctiitoring for syat*n»
    ifciich;

    (4)  filter and disinfect suztac* wwtar, and
         disinfect geound wat*r;  and
     (to)  haw a «nitaty auevty at tha
         sp«cif i«d in tt» prcpoMd regulation.
            monitoring for «y«t«i» »ttving 25 to 500
            «dMn using undi*inf•!>»
    for noUfortt*, but with «nall«r ru±*r of
    pepulaticn
 •~* QM ^Mi^ifltv*! <^"HfrtTB Hnnla M^I day
    tumidity iacMd* CUB HTO for mirfac*
            not Cilt«ring.
 If
 aollct fiv» r^pMt aiapln all on tto« •ana day from
 MBA loc&titin afl orlgijial Mapla/ t •ana aay
      tht iwct MBviiM ccrmactian.
 If any rtp«at «mpl« is colifonn-poaitiv*, syst«
—  Analyz* positive culture nadiun to d«temiim if it
     contairai faeal colifotaa; and
                   -2-

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        Infceswtient
     s*f« DrinteLng Watar
  (800) 426-4791 or (202)  382-5533

                 or
Itul S.B«tg«r, Ht.D.,
   Seiitiot and T*chnaLogy
   crit*ria ard standazdi
 Off lot Of
U.S.  Bnvircnwrrtal  Prot*cticn
          401 K StZ*«t, S.W.
                  O.C. 20460
             202/382*3039

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r
                                              T»bl« 1

                                M3OMM aJLIFQH* MUTTORING RBUUBMEXfTS
            Ha Di»inf»ctloru

            * 25-500 p*r«3tMi  5 MciM/vontA MB a Military «arv«y *v*ry 5 y**r».*

            * 501-3,300 psnonat  5 •aif&es/ttxtth M*D a •anitary «urv*y «v*ry 3
            * owe 3,300 p*r»oti*i  «nitoring fraquncy fp*cifi«d in T*bl« 2 AW) * unitary
                       «v*ry 3
            With Dl«lnf»rtioni

            * 25-500 ptfwantt   S «n3l«»/nDnth OR a wnitary «urv«y
            * 501-3,300 punantt  5 MtplM/vn«h OR a •anitary «urvwy «v«ry S yam «rd
                3
                  3,300 p*r«ocMi  acnitoring fr«qti*ncy ^»cifi«d In T»bl« 2*

                   IPOTR
           With Ditinfaetlon Only (So Filtration**)

           ' 25-500 f*nomt  $ MfflplM/aonWi  wp an anrwal aanitary «urv«y.

           * 501-3,300 pcnonat  S ««i?l«*/Bcrtth WD arvanrajal Mnitary •urv^r,
           * ovwr 3,300 p«r«cn»i  moni Coring £r*qu«ncy specified in Tabl« 2 «P an annual
                sanitary
           With PHtratioi and Di>in£«ction**

           * 25-500 ptranat  5 «aapl««/Honth OR a «anitary »urv«y «vwcy 5 y*ar« and cr»
                •aBtpl«/aonth.                 " "

           * 501-3,300 pBcsomt  5 M»pl««/ncn^ CR a •anitary »urv«y «v*ry 3 ywr* and
                3
           * ov*r 3*300 pwrwMi  nerd, nor ing frequency fptei£l«d in Tabl* 2.
           *Stat-.« vy ptrmit fy»t«« Mivin? 25-300 punonc to r«due« acni taring to
           1 sanpl«/*Dnth and «yvt«H Mcvin§ 301*500 p*r«OM to r«duc« •»! taring to
           3 •aa^l«s/atDnth if 1} manitary »urv«y ra«ult« «v»ry 3 yt«rs «ra »ar.i«tactory,
           2} sytttm baa not had a mt«rborm dlMM* oui-ijr*aX, and 3) ftyvtan na» record
           of aotplianoi *i*3i ch« oolifiom MCL« and ttxii taring rtqui:riiMnr«,
                d«fin«d in 40 CFS 141.73.

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r
                                       TABLE 2

                             Minimum Monitoring Fr«qu*ncy
             Population
            25*3*300
            3,301-5,800
            5,801-6,700
            6,701-7,600
            7,601-8,500
            8,501-10,000
            10,001-19,000
            15,001-20,000
            20,001*25,000
            25,001-30,000
            30,001-35,000
            35,001-40,000
            40,001-41,000
            45,001-10,000
            50,001-11,000
            55,001-60,000
            60,001-65,000
            65,001-70,000
            70,001-75,000
            75,001-10,000
            §0,001-85,000
S*.Tipl«»/month

      5
      €
      ?
      8
      9
     10
     15
     20
     25
     30
     35
     40
     45
     50
     55
     €0
     65
     70
     75
     SO
     85
                 Population
   85,001-90*000
   §0,001*95,000
   95,001-100,000
  100,001-200*000
  200,001-300,000
  300,001-400*000
  400,001-500,000
  500,001-600,000
  600,001-700,000
  700,001-100,000
  800,001*900*000
  900,001-1,000,000
1,000,001-1,209*000
1,200,001-1,400,000
1,400,001-1,600,000
1,600,001-1,100,000
1,100,001-2,000,000
2, 000, 001-2, 500, 000
2,500,001-3,000,000
3,000,001-3,500,000
3, SiO, 001-4, 000, 000
over 4,000,000
S«mt>l««/month

      90
      95
     100
     130
     160
     ISO
     200
     220
     240
     260
     2iO
     300
     340
     360
     330
     400
     420
     440
     460
     4SO
     500

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