UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                               WSG90
                                                              Date Signed: July 11, 1996

MEMORANDUM

SUBJECT:   Release of Final Alternative Technology Approval Protocol

FROM:      Cynthia C. Dougherty                    Vanessa M. Leiby
             Director                                Executive Director
             Office of Ground Water                  Association of State
              and Drinking Water                      Drinking Water Administrators

TO:          All Interested Parties

       We are pleased to announce completion of the enclosed Stare Alternative Technology
Approval Protocol dated June 1996. This protocol has been developed in a cooperative effort
among EPA, ASDWA, state drinking water program personnel, industry representatives, and
others with a stake in providing streamlined, consistent procedures for use by systems to
facilitate stare acceptance of new drinking water treatment technologies.

       As mentioned in the document's introduction, the generic protocol establishes a basic
framework for approval of technologies. It is not meant to replace current state plan review and
approval processes but sets a common protocol for the type of information to be submitted to
states in order for new technologies to be considered for approval.

       Tne intent of the protocol is to streamline the approval process and to improve the
consistency of response across states by establishing minimum criteria required of all applicants.
It is expected that the use of the protocol will decrease the need for pilot or demonstration
projects over time. A key to this effort will be the development of an appropriate mechanism
that states, water systems, and engineers can use to share data and information about treatment
approvals and effectiveness.

       If you have any questions regarding this document, please contact Vanessa Leiby or
Bridget O'Grady of ASDWA at (202) 293-7655, Steve Clark of EPA Headquarters at (202) 260-
7575, or Marc Parrotta of EPA Headquarters ac (202) 260-3035.

Enclosure

-------
                                                                                WSG90
                    State Alternative Technology Approval Protocol
Introduction
       The purpose of this document is to identify criteria and information required by states to
approve alternative technologies for public water system compliance with drinking water
regulations.  The generic protocol establishes a basic framework for approval of technologies
ranging from point-of-use to centralized treatment for water systems. This does not replace the
current state plan approval process, nor does compliance with the protocol imply automatic
approval of a given technology, but it sets a common protocol for the type of information
required by the state to consider approval of alternative technologies (i.e., those that fall outside
of the realm of state-identified conventional technologies). More specific criteria will be
developed for each drinking water regulation for which alternative technologies may apply.

       States typically take a conservative approach to plan review and approval, relying most
often on well-proven, accepted technologies to ensure  that the rule will be implemented
effectively and that public health will be protected. The dilemma is how to obtain approval for
new or alternative technologies in a state, and how to ensure that, to the greatest extent possible,
approvals transfer from state to state without costly, time consuming, or redundant pilot studies
or other requirements.

       This protocol, which was developed by representatives from the states, United States
Environmental Protection Agency (EPA), manufacturers, third party certifiers,  and other
interested parties attempts to provide general guidelines that will promote consistency among the
states and let manufacturers, suppliers, consulting engineers, and system owners clearly know
what kinds of data will be required before a technology can be approved.

Background

       States regulate over  186,000 public water systems under the Safe Drinking Water Act
(SDWA). Of this total, 56,747 (30%) are community (CWS), 23,639 (13%)  are non-transient
non-community (NTNC), and 106,438 (57%) are transient non-community (NCWS).  Ninety-six
percent of these systems are small (serving less than 3,300 persons).  Eighty-five percent of these
small systems  are considered very small, serving less than 500 persons (30% community and
NTNC water systems and 55% NCWS systems.1) Although these systems serve a relatively
small percentage of the total number of persons served by public water systems, they are
responsible for over 90 percent of the violations. While the  majority of these violations are for
failure to monitor, small systems are increasingly faced with the need to install treatment
technologies. As more drinking water regulations have been promulgated, the requirements have
become much more complex, requiring labor and resource intensive activities in order to
comply.
        U.S. Environmental Protection Agency, FY-94 National Compliance Report

-------
                                                                                 WSG90

       Small systems are typically characterized by having poor economies of scale, inadequate
training on regulations, lack of certified operators, and a general inability to comply. A
relatively recent regulation, the Surface Water Treatment Rule (SWTR), has brought home this
problem very clearly.  The standard technology for compliance with the SWTR is filtration
treatment, including conventional filtration, direct filtration, diatomaceous earth, and slow sand
filtration.  Most small systems, however, are incapable of designing, constructing, funding,
operating and maintainin complex filtration facilities.

       States, EPA, and manufacturers have for several years attempted to promote the
development and approval of "alternative technologies," particularly for small systems, that will
meet the requirements, be affordable to the customers of the system, and be easy to operate and
maintain.

Problem Identification

       The first step in the approval process is to identify the problem for which a technical
solution is  sought.  It may be a need to meet the SWTR or meet a specific drinking water
standard such as arsenic. When evaluating the system's needs, it is important to look not only at
the immediate short-term needs, but also at future needs.  This would include the ease of adding
additional treatment to the current treatment train. It is also important that the state be sure that a
technology installed today will not have a negative impact on other current drinking  water
regulations, permitting requirements, or regulations that will be proposed in the near future
including regulations related to waste disposal.

Determination of Available Alternatives

       All available alternatives including reconstruction of existing wells, locating  new water
sources, connection to other existing systems, or treatment should be evaluated. Where
alternative  treatment is selected as an option, this protocol should be used.

Compatibility with Existing Facilities

       The submittal should address the following: source of water (groundwater or surface
water); water quality characteristics; pumping capacity of source; backwashing capacity; piping
materials; storage facilities (elevated, ground, hydro-pneumatic tank); power availability;
existing treatment units; location of facilities (indoors/outdoors, above grade, accessible by foot
or vehicle); waste disposal facilities; existing monitoring and reporting; other water quality
concerns; and drawings showing existing and proposed facilities.

Determination of Technology Efficacy

       Once a system's problems are identified, the state will determine whether a proposed
technology could be an alternative  solution to the system's problems based on information

-------
                                                                                 WSG90

provided by the applicant. In order for the states to accomplish this task, the water system
should supply the following information and data to the state:

       1)     Objective and verifiable test data that support the treatment system performance
              claims. The information should be sufficient to determine the pathogen removal
              credits (i.e., virus, giardia), if applicable, compliance with the SDWA Maximum
              Contaminant Level(s) of concern, appropriate performance standards, and
              monitoring frequency for the technology.  This information can be obtained from
              the following sources (in order of preference):

              •      Accredited third party verifier or certifier
              •      Recognized third party independent test data
              •      Pilot study data
              •      Approval from other states, countries, or Federal agencies
              •      Manufacturers test data

       2)     Product and Process Technical Information

              Manufacturers' technical information, specifications, and data on
              equipment/process must be  submitted.  This includes (but is not limited to):

              •      Shop drawings
              •      Process schematics and descriptions
              •      Power requirements
              •      Capacity and dimensional data
                    Required auxiliary equipment
              •      Information on conditions for and limitations on process applicability
                    Quality control processes

       3)     Verification  of efficacy under site-specific conditions

              •      Source water quality, considering seasonal variation
              •      Finished water quality requirements
              •      Finished water quality produced, including consistency
              •      Design flow rates
              •      Useful life of treatment unit
              •      External environmental issues
              •      Storage requirements, space requirements, accessibility
              •      Other treatment needs such as pre or post-treatment
              •      Range of field extremes
              •      Worst case/best case adaptability to various raw water qualities
              •      Differential pressure conditions (i.e., 10 psi v. 100 psi)
              •      Reliability of treatment facilities including redundancy of equipment if
                    necessary

-------
                                                                                WSG90

              •      Operational conditions (e.g., stopping and starting)

       4)      Indication of Availability of Technical Support, such as:

              •      Water treatment system manufacturer or supplier support
              •      Water treatment system supplier qualifications
              •      Operator training mechanism
              •      Laboratory services
              •      Independent engineering consultant

Materials Safety

       It is important that the components of the product or technology meet basic materials
safety standards to ensure that they do not introduce harmful chemicals or leachates into the
finished water. This may be accomplished in the following manner:

       1)      Materials safety verification (in order of preference):

       •       Compliance with ANSI/NSF standards
       •       Compliance with appropriate Food  and Drug Administration Title 21 Code of
              Federal Regulations for Food Additives

Operational Efficacy And Cost-Effectiveness

       The state and the supplier will want to know if operational and maintenance requirements
meet the needs and expertise  of the system operator or owner and if the technology is cost-
effective. While overall costs of the technology and its impact on the water supplier and the
consumer are important, affordability may or may not be a prerequisite to approving the
technology or issuing permits. In some cases, a more expensive technology may be more
appropriate in the long run if it is easier to operate and has a longer life expectancy or lower
operation and maintenance (O&M) costs. The following information will be submitted:

       1)      Operation and maintenance requirements

              •      What control systems does the technology have to eliminate operator
                    error, especially if the system is highly automated? Is system operator-
                    friendly?
              •      Reliability features including unit alarms, automatic shutdown, manual
                    operation in the event of automated system failure, etc.
                    Operator expertise required
                    Waste  disposal needs
              •      Pretreatment requirements
              •      Cherilical feed requirements
              •      Basic O&M needs - chemicals, spare parts, labor, instrumentation, energy
                    requirements, ongoing monitoring

-------
                                                                                 WSG90

                    Replacement and maintenance schedule and availability and cost of parts
                    and servicing instrumentation and controls
                    Periodic cleaning/down time
                    Backwashing (frequency, disposal, storage, filter to waste capability)
                    Auxiliary needs (e.g., buildings, roads, re-generate media)
                    Manuals needed (e.g., operation and/or equipment repair)
                    Process flexibility (24 hr/day operation, 8 hr/day, intermittent, seasonal?)
                    Level of oversight - how often will system need to be inspected
                    Monitoring of raw water quality, pretreatment effluent water quality, and
                    finished water quality to verify and ensure assumptions for the design of
                    the treatment equipment are met
                    Finished water storage
                    Response time of equipment supplier, their designee, or other qualified
                    firm, to non-routine service calls
                    Provisions for storage, auxiliary treatment, or bypassing in case of
                    equipment problems.
       2)     Costs
              •      Life cycle costs of the system. This may include facilities and
                    appurtenances as well as component parts that must routinely be replaced
                    such as membranes, filters, cartridges, power consumption, etc.
              •      Total system costs. This may include cost per service connection per
                    month or year,  including amortization of initial capital equipment costs
                    and ongoing O&M costs.  Capital costs may include consultant costs,
                    studies, planning, design, permits, land and easements, construction,
                    additional taxes,  insurance, environmental impact studieslreview
                    (community acceptance public meetings)
              •      Training costs
              •      Administrative costs
              •      Certification costs
              •      Monitoring costs
              •      Regulatory agency fees for technical assistance oversight, operating
                    permits
              •      Service labor costs

Costs presented in italics may be obtained from the engineering consultant, the manufacturer, the
equipment supplier, the water system, or other professional organizations, or, in some cases, the
state.

Technology Approval

       While states would prefer information and data from full scale operational facilities, they
may reduce or eliminate extensive piloting for some technologies if they have credible third
party

-------
                                                                                 WSG90

test data that provides information over a range of source water quality conditions or information
from full scale operation of the technology in other applications. Pilot plants or laboratory data
may be adequate to determine the potential capability of the treatment technology, but are no
guarantee that the technology will perform under real world conditions or be cost-effective for
the water system. Acceptance  of a technology based only on a performance guarantee may or
may not be sufficient.

       Upon receipt and review of the information discussed previously (source water
characteristics, unique system operating conditions, treatment alternatives, pertinent past
treatment performance assessments/verification of the recommended process option,
specifications and technical data of the process, and capital and O&M costs) the state regulatory
agency will make one of the following determination(s):

       1)      The technology application can be accepted without site-specific piloting; or

       2)      The technology application is acceptable, but with conditional approval for an
              established timeframe (i.e. one year, one month, etc.) during which the treatment
              performance can be evaluated through monitoring and operational data; or

       3)      Additional information and data are  needed; or

       4)      Qn-site piloting is still needed due to source water quality or performance
              uncertainties; or

       5)      The technology application is not  appropriate for this particular application.

       Prior to installation or construction of any proposed alternative technology, final plans
and specifications covering the entire project (not just the alternative technology facilities) must
be submitted by a registered professional engineer (if required by the state) to the reviewing
authority for final approval with or without conditions.  This final submittal should address all
aspects of the project (e.g. piping, materials, power, chemical feeds, valving, controls, building
requirements, etc.).

       After the period of operation specified by a conditional approval,  the monitoring results
and the results of operational data will be reviewed by the state and a determination will be made
as to whether to: 1) grant final approval; 2) grant final approval with conditions; 3) continue
conditional approval for another specified time period; or 4) disapprove the technology pending
futher development by the applicant.  The state will supply its rationale for any decision to the
applicant.

       A performance bond, or other guarantee,  or lease arrangement may be required to ensure
that if the installed technology fails, the manufacturer will remove or modify the installed
technology and any ancillary equipment at their own cost, and the water system will be reftmded

-------
                                                                                WSG90

any funds that it put up for purchase, or installation of the technology, consistent with the
contractual agreement between the parties.

Technology Transfer

       In order to ensure that information about the approval and implementation of alternative
technologies receives the widest possible dissemination, states are encouraged to share
information about their experiences with alternative technologies.  One method for
accomplishing this would be to provide information to the database maintained by the National
Drinking Water Clearinghouse, located at West Virginia University. Other methods for sharing
information are encouraged as well.

-------
WSG90

-------