National Primary Drinking Water Regulations: Disinfectants and Disinfection Byproducts Notice of Data Availability

Federal RegisterNov 3, 1997

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SUMMARY: In 1994 USEPA proposed a Stage 1 Disinfectants/Disinfection

Byproducts Rule (DBPR) to reduce the level of exposure from

disinfectants and disinfection byproducts (DBPs) in drinking water

(USEPA, 1994b). This Notice of Data Availability summarizes the 1994

proposal; describes new data and information that the Agency has

obtained and analyses that have been developed since the proposal;

provides information concerning recommendations of the Microbial-

Disinfection/Disinfectants Byproducts (M-DBP) Advisory Committee

(chartered in February 1997 under the Federal Advisory Committee Act)

on key issues related to the proposal; and requests comment on these

recommendations as well as on other regulatory implications that flow

from the new data and information. USEPA solicits comment on all

aspects of this Notice and the supporting record. The Agency also

solicits additional data and information that may be relevant to the

issues discussed in the Notice. USEPA is particularly interested in

public comment on the Committee's recommendations and whether the

Agency should reflect these recommendations in the final rule. USEPA

also requests that any information, data or views submitted to the

Agency since the close of the comment period on the 1994 proposal that

members of the public would like the Agency to consider as part of the

final rule development process be resubmitted during this current 90-

day comment period unless already in the underlying record in the

Docket for this Notice.

The Stage 1 DBPR would apply to community water systems and

nontransient noncommunity water systems that treat their water with a

chemical disinfectant for either primary or residual treatment. In

addition, certain requirements for chlorine dioxide would apply to

transient noncommunity water systems because of the short-term health

effects from high levels of chlorine dioxide.

Key issues related to the Stage 1 DBPR that are addressed in this

Notice include the establishment of Maximum Contaminant Levels for

total trihalomethanes, five haloacetic acids, bromate and chlorite;

requirements for enhanced coagulation and enhanced softening;

disinfection credit; health effects information; and analytical

methods.

Today's Federal Register also contains a related Notice of Data

Availability for the Interim Enhanced Surface Water Treatment Rule

(IESWTR). USEPA proposed this rule at the same time as the Stage 1 DBPR

and plans to promulgate it along with the Stage 1 DBPR in November

1998.

DATES: Comments should be postmarked or delivered by hand on or before

February 3, 1998. Comments must be received or post-marked by midnight

February 3, 1998.

ADDRESSES: Send written comments to DBP NODA Docket Clerk, Water Docket

(MC-4101); U.S. Environmental Protection Agency; 401 M Street, SW;

Washington, DC 20460. Please submit an original and three copies of

your comments and enclosures (including references). If you wish to

hand-deliver your comments, please call the Docket between 9:00 a.m.

and 4 p.m., Monday through Friday, excluding legal holidays, to obtain

the room number for the Docket. Comments may be submitted

electronically to [email protected].

FOR FURTHER INFORMATION CONTACT: The Safe Drinking Water Hotline,

Telephone (800) 426-4791. The Safe Drinking Water Hotline is open

Monday through Friday, excluding Federal holidays, from 9:00 am to 5:30

pm Eastern Time. For technical inquiries, contact Thomas Grubbs or

William Hamele, Office of Ground Water and Drinking Water (MC 4607),

U.S. Environmental Protection Agency, 401 M Street SW, Washington DC

20460; telephone (202) 260-7270 (Grubbs) or (202) 260-2584 (Hamele).

Regional Contacts

I. Kevin Reilly, Water Supply Section, JFK Federal Bldg., Room 203,

Boston, MA 02203, (617) 565-3616

II. Michael Lowy, Water Supply Section, 290 Broadway, 24th Floor, New

York, NY 10007-1866, (212) 637-3830

III. Jason Gambatese, Drinking Water Section (3WM41), 841 Chestnut

Building, Philadelphia, PA 19107, (215) 566-5759

IV. David Parker, Water Supply Section, 345 Courtland Street, Atlanta,

GA 30365, (404) 562-9460

V. Kimberly Harris (micro), Miguel Del Toral (DBP), Water Supply

Section, 77 W. Jackson Blvd., Chicago, IL 60604, (312) 886-4239

(Harris), (312) 886-5253 (Del Toral)

VI. Blake L. Atkins, Team Leader, Water Supply Section, 1445 Ross

Avenue, Dallas, TX 75202, (214) 665-2297

VII. Stan Calow, State Programs Section, 726 Minnesota Ave., Kansas

City, KS 66101, (913) 551-7410

VIII. Bob Clement, Public Water Supply Section, (8WM-DW), 999 18th

Street, Suite 500, Denver, CO 80202-2466, (303) 312-6653

IX. Bruce Macler, Water Supply Section, 75 Hawthorne Street, San

Francisco, CA 94105, (415) 744-1884

X. Wendy Marshall, Drinking Water Unit, 1200 Sixth Avenue (OW-136),

Seattle, WA 98101, (206) 553-1890

SUPPLEMENTARY INFORMATION:

Regulated Entities

Entities potentially regulated by the Stage 1 DBPR are public water

systems that add a disinfectant or oxidant. Regulated categories and

entities include:

------------------------------------------------------------------------

Examples of regulated

Category entities

------------------------------------------------------------------------

Public Water System....................... Community water systems that

add disinfectant or

oxidant.

State Governments......................... State government offices

that regulate drinking

water.

------------------------------------------------------------------------

This table is not intended to be exhaustive, but rather provides a

guide for readers regarding entities likely to be regulated by the

Stage 1 DBPR. This table lists the types of entities that EPA is now

aware could potentially be regulated by the rule. Other types of

entities not listed in this table could also be regulated. To determine

whether your facility may be regulated by this action, you should

carefully examine the applicability criteria in Sec. 141.130 of the

proposed rule published on July 29, 1994 at 59 FR 38668 (USEPA, 1994b).

If you have questions regarding the applicability of this action to a

particular entity, contact one of the persons listed in the preceding

FOR FURTHER INFORMATION CONTACT section.

Additional Information for Commenters

The Agency requests that commenters follow the following format:

type or print comments in ink, and cite, where possible, the

paragraph(s) in this Notice to which each comment refers. Commenters

should use a separate paragraph for each method or issue discussed.

Electronic comments must be submitted as a WP5.1 or WP6.1 file or as an

ASCII file avoiding the use of special characters and any form of name

[[Page 59389]]

or title of the Federal Register. Comments and data will also be

accepted on disks in WordPerfect in 5.1 or WP6.1 or ASCII file format.

Electronic comments on this Notice may be filed online at many Federal

Depository Libraries. Commenters who want EPA to acknowledge receipt of

their comments should include a self-addressed, stamped envelope. No

facsimiles (faxes) will be accepted.

Availability of Record

The record for this Notice, which includes supporting documentation

as well as printed, paper versions of electronic comments, is available

for inspection from 9 to 4 p.m., Monday through Friday, excluding legal

holidays at the Water Docket, U.S. EPA Headquarters, 401 M. St., S.W.

Washington, D.C. 20460. For access to docket materials, please call

202/260-3027 to schedule an appointment and obtain the room number.

Copyright Permission

Supporting documentation reprinted in this document from

copyrighted material may be reproduced or republished without

restriction in accordance with 1 CFR 2.6.

Abbreviations Used in This Notice

AOC: Assimilable organic carbon

ASDWA: Association of State Drinking Water Administrators

AWWA: American Water Works Association

AWWARF: AWWA Research Foundation

AWWSCo: American Water Works Service Company

BAC: Biologically active carbon

BAF: Biologically active filtration

BAT: Best Available Technology

BCAA: Bromochloroacetic acid

BDOC: Biodegradable organic carbon

CT: Contact time

CWS: Community Water System

DBP: Disinfection byproducts

D/DBP: Disinfectants and disinfection byproducts

DBPRAM: DBP Regulatory Analysis Model

DOC: Dissolved Organic Carbon

EPA: United States Environmental Protection Agency

ESWTR: Enhanced Surface Water Treatment Rule

FACA: Federal Advisory Committee Act

FY: Fiscal year

GAC: Granular Activated Carbon

GWDR: Ground Water Disinfection Rule

HAA5: Haloacetic acids (five)

IC: Ion chromotography

ICR: Information Collection Rule

ILSI: International Life Sciences Institute

IOC: Inorganic chemical

LOAEL: Lowest observed adverse effect level

MCL: Maximum Contaminant Level (expressed as mg/l, 1,000 micrograms

(g)=1 milligram (mg))

MCLG: Maximum Contaminant Level Goal

M-DBP: Microbial and Disinfectants/Disinfection Byproducts

MDL: Method Detection Limit

mg/dl: Milligrams per deciliter

mg/L: Milligrams per liter

MGD: Million Gallons per Day

MRDL: Maximum Residual Disinfectant Level (as mg/l)

MRDLG: Maximum Residual Disinfectant Level Goal

MWDSC: Metropolitan Water District of Southern California

NCI: National Cancer Institute

NIPDWR: National Interim Primary Drinking Water Regulation

NOAEL: No observed adverse effect level

NOM: Natural Organic Matter

NPDWR: National Primary Drinking Water Regulation

NTNCWS: Nontransient noncommunity water system

O&M: Operations and maintenance

PE: Performance evaluation

PODR: Point of Diminishing Returns

POE: Point-of-Entry Technologies

POU: Point-of-Use Technologies

ppb: Parts per billion

PQL: Practical Quantitation Level

PWS: Public Water System

RIA: Regulatory Impact Analysis

RMCL: Recommended Maximum Contaminant Level

SAB: Science Advisory board

SDWA: Safe Drinking Water Act, or the ``Act,'' as amended in 1986

SUVA: Specific ultraviolet absorbance at 254 nm

SWTR: Surface Water Treatment Rule

TOC: Total organic carbon

TTHM: Total trihalomethanes

TWG: Technical Working Group

UNC: University of North Carolina

VOC: Volatile Synthetic Organic Chemical

WIDB: Water Industry Data Base

WITAF: Water Industry Technical Action Fund

Table of Contents

I. Introduction and Background

A. Existing Regulations

1. Surface Water Treatment Rule

2. Total trihalomethane MCL

3. Total Coliform Rule

4. Information Collection Rule

B. Public Health Concerns to be Addressed

C. Statutory Provisions

1. SDWA and 1986 provisions

2. Changes to initial provisions and new mandates

D. Regulatory Negotiation Process

E. Information Collection Rule

F. Formation of 1997 Federal Advisory Committee

G. Overview of 1994 DBP Proposal

1. MCLGs/MCLs/MRDLGs/MRDLs

2. Best available technologies

3. Treatment technique

4. Preoxidation (predisinfection) credit

5. Analytical methods

6. New information

II. Health Effects

A. Cancer Epidemiology Studies

1. Expert panels recommendations on cancer epidemiology

2. Implementation of expert panel recommendations

a. Improve exposure assessments/geographic identification

studies/classes of DBPs other than THMs

b. Meta-analysis of existing cancer epidemiology data

B. Reproductive and Developmental Epidemiology Studies

1. Improving exposure assessments

2. New studies since proposal

C. Significant New Toxicological Information for Stage 1

Disinfectants and Disinfection Byproducts

1. Chlorite

2. Chlorine dioxide

3. Trihalomethanes

4. Haloacetic acids

5. Chloral hydrate

6. Bromate

D. Summary of Key Observations

E. Request for Public Comments

III. Enhanced Coagulation and Enhanced Softening

A. 1994 Enhanced Coagulation and Enhanced Softening Proposal

B. New Information on Enhanced Coagulation and Softening Since

1994 Proposal

1. New Data on enhanced coagulation

a. UNC Enhanced Coagulation Study

b. Metropolitan Water District of Southern California WDSC/

ColoradoUniversity Enhanced Coagulation Study

c. Malcolm Pirnie, Inc./Colorado University data collection and

analysis

d. Evaluation of current (baseline) TOC removals at full scale

e. Evaluation of ``optimized'' TOC removal

f. ``Case-by-case'' data analyses

2. New data on enhanced softening

a. AWWARF Studies--data on TOC removal

b. Shorney and Coworkers--data on the use of SUVA

c. Malcolm Pirnie, Inc. modeling

d. ICR mail survey

C. Summary of Key Enhanced Coagulation and Enhanced Softening

Observations

D. Request for Public Comment on Enhanced Coagulation and

Enhanced Softening Issues

IV. Predisinfection Credit

A. 1994 Proposal

B. New Information Since 1994 Proposal

1. ICR mail survey--predisinfection practices

2. Summers et al.--Impact of chlorination point on DBP

production

C. Summary of Key Observations

D. Request for Public Comments

V. Analytical Methods

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A. Chlorine Dioxide

B. Haloacetic Acids

C. Total Trihalomethanes (TTHMs)

D. Bromate

E. Chlorite

F. Total Organic Carbon (TOC)

G. Specific Ultraviolet Absorbance (SUVA)

H. Summary of Key Observations

I. Request for Public Comments

VI. MCLs for TTHMs, HAAs, Chlorite, and Bromate

A. 1994 Proposal

B. New Information Since 1994 Proposal

1. TTHM and HAA5 MCLs

2. Bromate

3. Chlorite

VII. Regulatory Compliance Schedule and Other Compliance-related

Issues

A. Regulatory Compliance Schedule

B. Compliance violations and State primacy obligations

C. Compliance with current regulations

VIII. Economic Analysis of the M-DBP Advisory Committee

Recommendations

A. Plant-level DBP Treatment Effectiveness and Cost

B. Decision Tree Analysis--Compliance Forecasts

C. National Cost Estimates

1. System level costs

2. Household costs

3. Monitoring and State implementation costs

D. DBP Exposure Estimates

E. National Benefits Analysis

F. Cost-Effectiveness

G. Summary of Key Observations

H. Request for Public Comments

IX. National Technology Transfer and Advancement Act

X. References

I. Introduction and Background

A. Existing Regulations

1. Surface Water Treatment Rule

Under the Surface Water Treatment Rule (SWTR)(USEPA, 1989a), USEPA

set maximum contaminant level goals of zero for Giardia lamblia,

viruses, and Legionella; and promulgated national primary drinking

water regulations for all public water systems (PWSs) using surface

water sources or ground water sources under the direct influence of

surface water. The SWTR includes treatment technique requirements for

filtered and unfiltered systems that are intended to protect against

the adverse health effects of exposure to Giardia lamblia, viruses, and

Legionella, as well as many other pathogenic organisms. Briefly, those

requirements include (1) removal or inactivation of 3 logs (99.9%) for

Giardia and 4 logs (99.99%) for viruses (2) combined filter effluent

performance of 5 NTU as a maximum and 0.5 NTU at 95th percentile

monthly, based on 4-hour monitoring for treatment plants using

conventional treatment or direct filtration (with separate standards

for other filtration technologies); and (3) watershed protection and

other requirements for unfiltered systems.

2. Total trihalomethane MCL

USEPA set an interim maximum contaminant level (MCL) for total

trihalomethanes (TTHMs) of 0.10 mg/l as an annual average in November

1979 (USEPA, 1979). This standard was based on the need to balance the

requirement for continued disinfection of water to reduce exposure to

pathogenic microorganisms while simultaneously lowering exposure to

disinfection byproducts which might be carcinogenic to humans.

The interim TTHM standard only applies to any PWSs (surface water

and/or ground water) serving at least 10,000 people that add a

disinfectant to the drinking water during any part of the treatment

process. At their discretion, States may extend coverage to smaller

PWSs. However, most States have not exercised this option. About 80

percent of the PWSs, serving populations of less than 10,000, are

served by ground water that is generally low in THM precursor content

(USEPA, 1979) and which would be expected to have low TTHM levels even

if they disinfect.

3. Total Coliform Rule

The Total Coliform Rule (USEPA, 1989b) was revised in June 1989,

and became effective on December 31, 1990. The rule, which applies to

all public water systems, sets compliance with the maximum contaminant

level (MCL) for total coliforms as follows. For systems that collect 40

or more samples per month, no more than 5.0% of the samples may be

total coliform-positives; for those that collect fewer than 40 samples,

only one sample may be total coliform-positive. If a system exceeds the

MCL for a month, it must notify the public using mandatory language

developed by the USEPA. The required monitoring frequency for a system

ranges from 480 samples per month for the largest systems to once

annually for certain of the smallest systems. All systems must have a

written plan identifying where samples are to be collected. In

addition, systems are required to conduct repeat sampling after a

positive sample.

The Total Coliform Rule also requires each system that collects

fewer than five samples per month to have the system inspected every 5

years (10 years for certain types of systems using only protected and

disinfected ground water.) This on-site inspection (referred to as a

sanitary survey) must be performed by the state or by an agent approved

by the state.

4. Information Collection Rule

The Information Collection Rule (ICR) is a monitoring and data

reporting rule that was promulgated on May 14, 1996 (USEPA, 1996b). The

purpose of the ICR is to collect occurrence and treatment information

to evaluate the need for possible changes to the current Surface Water

Treatment Rule and existing microbial treatment practices and to

evaluate the need for future regulation for disinfectants and DBPs. The

ICR will provide USEPA with additional information on the national

occurrence in drinking water of (1) chemical byproducts that form when

disinfectants used for microbial control react with compounds already

present in source water and (2) disease-causing microorganisms,

including Cryptosporidium, Giardia, and viruses. The ICR will also

collect engineering data on how PWSs currently control such

contaminants. This information is being collected because the

regulatory negotiation on disinfectants and DBPs concluded that

additional information was needed to assess the potential health

problem created by the presence of DBPs and pathogens in drinking water

and to assess the extent and severity of risk in order to make sound

regulatory and public health decisions. The ICR will also provide

information to support regulatory impact analyses for various

regulatory options, and to help develop monitoring strategies for cost

effectively implementing regulations.

B. Public Health Concerns To Be Addressed

In 1990, USEPA's Science Advisory Board, an independent panel

established by Congress, cited drinking water contamination as one of

the highest ranking environmental risks. The Science Advisory board

reported that microbiological contaminants (e.g. bacteria, protozoa,

viruses) are likely the greatest remaining health risk management

challenge for drinking water suppliers. The control of microbiological

contaminants is further complicated because commonly-used disinfection

processes themselves may pose health risks. Conventional practices

require the addition of disinfectant chemicals to the water that, while

effective in controlling many harmful microorganisms, combine with

organic matter in the water and form compounds known as disinfection

byproducts (DBPs). One of the most complex questions facing water

supply professionals is how to minimize the risks from these DBPs and

still control microbial contaminants.

Chemical disinfectants (e.g., chlorine, chloramines, chlorine

dioxide) are

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added to drinking water to provide continuous disinfection throughout

the distribution system. There is generally little health concern over

exposure to the levels of the disinfectant residuals commonly found in

finished drinking water. A number of organic DBPs, including some

trihalomethanes (chloroform, bromoform, and bromodichloromethane) and

some haloacetic acids (e.g., dichloroacetic acid) cause cancer in

laboratory animals. Other DBPs cause reproductive or developmental

effects in laboratory animals (e.g., chlorite). Bromate, a byproduct of

ozonation, causes cancer in laboratory animals.

Several epidemiology studies have evaluated the association of

chlorination and chloramination with several adverse outcomes including

cancer, cardiovascular disease, and adverse reproductive outcomes.

Several studies have reported small increases in bladder, colon, and

rectal cancers. In some cases, these effects appeared to be associated

with the duration of exposure and volume of water consumed. Data on

DBPs and cardiovascular disease are inconclusive. Animal studies in the

mid 1980's indicated a potential increase in the serum lipid levels in

animals exposed to chlorinated water. However, in a cross-sectional

epidemiology study in humans, comparing chlorinated and unchlorinated

water supplies with varying water hardness, no adverse effects on serum

lipid levels were found. Recent epidemiology studies have reported

increased incidence of decreased birth weight, premature births,

intrauterine growth retardation, and neural tube defects with

chlorinated water. As with the other reported adverse outcomes from the

epidemiology studies, there is considerable debate in the scientific

community on the significance of these findings (USEPA, 1994a). A

discussion of new health effects information that has become available

since the 1994 proposal appears in Section VI of this Notice.

In order to accurately assess risk from DBPs, it is important to

have information on human exposure to DBPs, information on the toxicity

of the DBPs and an understanding of the mode of action of toxicity. The

preamble to the 1994 proposed DBP rule presented information on the

occurrence and exposure to the Stage 1 DBPs. The information presented

in that preamble was summarized from the document ``Occurrence

Assessment for Disinfectants and Disinfection By-products (Phase 6a) in

Drinking Water'' (USEPA, 1992a) and from information presented as a

part of the 1992 and 1993 Regulatory Negotiation process that led to

the 1994 Stage 1 DBP proposal (see section D below). Since the

proposal, USEPA has updated the document cited above with new

occurrence and exposure information. Copies of the revised document,

entitled ``Occurrence Assessment for Disinfectants and Disinfection

Byproducts in Public Drinking Water Supplies'' (USEPA, 1997a) can be

obtained from the Docket for this Notice. The Information Collection

Rule (ICR) (USEPA, 1996b) will supply additional information on the

occurrence of DBPs for the Stage 2 DBP rule; however, this ICR

information will not be available in time for the Stage 1 DBP rule.

C. Statutory Provisions

1. SDWA and 1986 Provisions

The Safe Drinking Water Act (SDWA or the Act), as amended in 1986,

requires USEPA to publish a ``maximum contaminant level goal'' (MCLG)

for each contaminant which, in the judgement of the USEPA

Administrator, ``may have any adverse effect on the health of persons

and which are known or anticipated to occur in public water systems''

(Section 1412(b)(3)(A)). MCLGs are to be set at a level at which ``no

known or anticipated adverse effect on the health of persons occur and

which allows an adequate margin of safety'' (Section 1412(b)(4)).

The Act also requires that at the same time USEPA publishes an

MCLG, which is a non-enforceable health goal, it also must publish a

National Primary Drinking Water Regulation (NPDWR) that specifies

either a maximum contaminant level (MCL) or treatment technique

(Sections 1401(1) and 1412(a)(3)). USEPA is authorized to promulgate a

NPDWR ``that requires the use of a treatment technique in lieu of

establishing a MCL,'' if the Agency finds that ``it is not economically

or technologically feasible to ascertain the level of the

contaminant''.

Section 1414(c) of the Act requires each owner or operator of a

public water system to give notice to the persons served by the system

of any failure to comply with an MCL or treatment technique requirement

of, or testing procedure prescribed by, a NPDWR and any failure to

perform monitoring required by section 1445 of the Act.

Section 1412(b)(7)(C) of the SDWA requires the USEPA Administrator

to publish a NPDWR ``specifying criteria under which filtration

(including coagulation and sedimentation, as appropriate) is required

as a treatment technique for public water systems supplied by surface

water sources''. In establishing these criteria, USEPA is required to

consider ``the quality of source waters, protection afforded by

watershed management, treatment practices (such as disinfection and

length of water storage) and other factors relevant to protection of

health''. This section of the Act also requires USEPA to promulgate a

NPDWR requiring disinfection as a treatment technique for all public

water systems and a rule specifying criteria by which variances to this

requirement may be granted.

2. Changes to Initial Provisions and New Mandates

In 1996, Congress reauthorized the Safe Drinking Water Act. Several

of the 1986 provisions discussed above were renumbered and augmented

with additional language, while other sections mandate new drinking

water requirements. These modifications, as well as new provisions, are

detailed below.

As part of the 1996 amendments to the Safe Drinking Water Act (the

Amendments), USEPA's general authority to set a MCLG and NPDWR was

modified to apply to contaminants that may ``have an adverse effect on

the health of persons'', that are ``known to occur or there is a

substantial likelihood that the contaminant will occur in public water

systems with a frequency and at levels of public health concern'', and

for which ``in the sole judgement of the Administrator, regulation of

such contaminant presents a meaningful opportunity for health risk

reduction for persons served by public water systems' (1986 SDWA

Section 1412 (b)(3)(A) stricken and amended with 1412(b)(1)(A)).

The Amendments also require that USEPA, when proposing a NPDWR that

includes an MCL or treatment technique, publish and seek public comment

on health risk reduction and cost analyses. The Amendments also require

USEPA to take into consideration the effects of contaminants upon

sensitive subpopulations (i.e. infants, children, pregnant women, the

elderly, and individuals with a history of serious illness), and other

relevant factors. (Section 1412 (b)(3)(C)).

The 1996 Amendments also newly require USEPA to promulgate an

Interim Enhanced SWTR and a Stage I Disinfectants and Disinfection

Byproducts Rule by November 1998. In addition, the 1996 Amendments

require USEPA to promulgate a Final Enhanced SWTR and a Stage 2

Disinfection Byproducts Rule by November 2000 and May 2002,

respectively (Section 1412(b)(2)(C)).

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Under the Amendments of 1996, recordkeeping requirements were

modified to apply to ``every person who is subject to a requirement of

this title or who is a grantee'' (Section 1445 (a)(1)(A)). Such persons

are required to ``establish and maintain such records, make such

reports, conduct such monitoring, and provide such information as the

Administrator may reasonably require by regulation * * *''.

D. Regulatory Negotiation Process

In 1992 USEPA initiated a negotiated rulemaking to develop a

disinfectants/disinfection byproducts rule. The negotiators included

representatives of State and local health and regulatory agencies,

public water systems, elected officials, consumer groups and

environmental groups. The Committee met from November 1992 through June

1993.

Early in the process, the negotiators agreed that large amounts of

information necessary to understand how to optimize the use of

disinfectants to concurrently minimize microbial and DBP risk on a

plant-specific basis were unavailable. Nevertheless, the Committee

agreed that USEPA propose a Disinfectant/Disinfection Byproducts rule

to extend coverage to all community and nontransient noncommunity water

systems that use disinfectants. This rule proposed to reduce the

current TTHM MCL, regulate additional disinfection byproducts, set

limits for the use of disinfectants, and reduce the level of organic

compounds in the source water that may react with disinfectants to form

byproducts.

One of the major goals addressed by the Committee was to develop an

approach that would reduce the level of exposure from disinfectants and

DBPs without undermining the control of microbial pathogens. The

intention was to ensure that drinking water is microbiologically safe

at the limits set for disinfectants and DBPs and that these chemicals

do not pose an unacceptable risk at these limits.

Following months of intensive discussions and technical analysis,

the Committee recommended the development of three sets of rules: a

two-staged Disinfectants/Disinfection Byproduct Rule (proposal: 59 FR

38668, July 29, 1994), an ``interim'' ESWTR (proposal: 59 FR 38832,

July 29, 1994), and an Information Collection rule (proposal: 59 FR

6332, February 10, 1994). The IESWTR would only apply to systems

serving 10,000 people or more. The Committee agreed that a ``long-

term'' ESWTR (LTESWTR) would be needed for systems serving fewer than

10,000 people when the results of more research and water quality

monitoring became available. The LTESWTR could also include additional

refinements for larger systems.

The approach in developing these proposals considered the

constraints of simultaneously treating water to control for both

microbial contaminants and DBPs. As part of this effort, the

Negotiating Committee concluded that the SWTR may need to be revised to

address health risk from high densities of pathogens in poorer quality

source waters and from the protozoan, Cryptosporidium. The Committee

also agreed that the schedules for IESWTR and LTESWTR should be

``linked'' to the schedule for the Stage 1 DBP Rule to assure

simultaneous compliance and a balanced risk-risk based implementation.

The Committee agreed that additional information on health risk,

occurrence, treatment technologies, and analytical methods needed to be

developed in order to better understand the risk-risk tradeoff, and how

to accomplish an overall reduction in risk.

Finally the Negotiating Committee agreed that to develop a

reasonable set of rules and to understand more fully the limitations of

the current SWTR, additional field data were critical. Thus, a key

component of the regulation negotiation agreement was the promulgation

of the Information Collection Rule (ICR) noted above and described in

more detail below.

E. Information Collection Rule

As stated above, the ICR established monitoring and data reporting

requirements for large public water systems serving populations over

100,000. About 350 PWSs operating 500 treatment plants are involved in

the data collection effort. Under the ICR, these PWSs monitor their

source water for bacteria, viruses, and protozoa (surface water sources

only); water quality factors affecting DBP formation; and DBPs within

the treatment plant and in the distribution system. In addition, PWSs

must provide operating data and a description of their treatment plan

design. Finally, a subset of PWSs perform treatment studies, using

either granular activated carbon or membrane processes, to evaluate DBP

precursor removal. Monitoring for treatment study applicability began

in September 1996. The remaining occurrence monitoring began in July

1997.

The initial intent of the ICR was to collect monitoring data and

other information for use in developing the Stage 2 DBPR and IESWTR and

to estimate national costs for various treatment options. However,

because of delays in promulgating the ICR and technical difficulties

associated with laboratory approval and review of facility sampling

plans, most ICR monitoring did not begin until July 1, 1997. As a

result of this delay and the new Stage 1 DBPR and IESWTR deadlines

specified in the 1996 SDWA amendments, ICR data will not be available

for analysis in connection with these rules. In place of the ICR data,

the Agency has worked with stakeholders to identify additional data

developed since 1994 that can be used in components of these rules.

USEPA intends to continue to work with stakeholders in analyzing and

using the comprehensive ICR data and research for developing subsequent

revisions to the SWTR and the Stage 2 DBP Rule.

F. Formation of 1997 Federal Advisory Committee

In May 1996, the Agency initiated a series of public informational

meetings to exchange information on issues related to microbial and

disinfectants/disinfection byproducts regulations. To help meet the

deadlines for the IESWTR and Stage 1 DBPR established by Congress in

the 1996 SDWA Amendments and to maximize stakeholder participation, the

Agency established the Microbial and Disinfectants/Disinfection

Byproducts (M-DBP) Advisory Committee under the Federal Advisory

Committee Act (FACA) on February 12, 1997, to collect, share, and

analyze new information and data, as well as to build consensus on the

regulatory implications of this new information. The Committee consists

of 17 members representing USEPA, State and local public health and

regulatory agencies, local elected officials, drinking water suppliers,

chemical and equipment manufacturers, and public interest groups.

The Committee met five times, in March through July 1997, to

discuss issues related to the IESWTR and Stage 1 DBPR. Technical

support for these discussions was provided by a Technical Work Group

(TWG) established by the Committee at its first meeting in March 1997.

The Committee's activities resulted in the collection, development,

evaluation, and presentation of substantial new data and information

related to key elements of both proposed rules. The Committee reached

agreement on the following major issues discussed in this Notice and

the Notice for the IESWTR published elsewhere in today's Federal

Register: (1) MCLs for TTHMs, HAA5 and bromate; (2) requirements for

enhanced coagulation and enhanced softening (as part of DBP control);

(3) microbial benchmarking/profiling to

[[Page 59393]]

provide a methodology and process by which a PWS and the State, working

together, assure that there will be no significant reduction in

microbial protection as the result of modifying disinfection practices

in order to meet MCLs for TTHM and HAA5; (4) disinfection credit; (5)

turbidity; (6) Cryptosporidium MCLG; (7) removal of Cryptosporidium;

(8) role of Cryptosporidium inactivation as part of a multiple barrier

concept and (9) sanitary surveys. The Committee's recommendations to

USEPA on these issues were set forth in an Agreement In Principle

document dated July 15, 1997. This document is included with this

Notice as Appendix 1.

G. Overview of 1994 DBP Proposal

The proposed Disinfectants and Disinfection Byproducts Stage I Rule

(DBPI) addressed a number of complex and interrelated drinking water

issues. The proposal attempted to balance the control of health risks

from compounds formed during drinking water disinfection against the

risks from microbial organisms (such as Giardia lamblia,

Cryptosporidium, bacteria, and viruses) to be controlled by the IESWTR.

The proposed Stage 1 DBP rule applied to all community water

systems (CWSs) and nontransient noncommunity water systems (NTNCWSs)

that treat their water with a chemical disinfectant for either primary

or residual treatment. In addition, certain requirements for chlorine

dioxide would apply to transient noncommunity water systems because of

the short-term health effects from high levels of chlorine dioxide.

Following is a summary of key components of the 1994 Stage 1 DBPR

proposal.

1. MCLGs/MCLs/MRDLGs/MRDLs

EPA proposed MCLGs of zero for chloroform, bromodichloromethane,

bromoform, bromate, and dichloroacetic acid and MCLGs of 0.06 mg/L for

dibromochloromethane, 0.3 mg/L for trichloroacetic acid, 0.04 mg/L for

chloral hydrate, and 0.08 mg/L for chlorite. In addition, EPA proposed

to lower the MCL for TTHMs from 0.10 to 0.080 mg/L and added an MCL for

five haloacetic acids (i.e., the sum of the concentrations of mono-,

di-, and trichloroacetic acids and mono-and dibromoacetic acids) of

0.060 mg/L. EPA also, for the first time, proposed MCLs for two

inorganic DBPs: 0.010 mg/L for bromate and 1.0 mg/L for chlorite.

In addition to proposing MCLGs and MCLs for several DBPs, EPA

proposed maximum residual disinfectant level goals (MRDLGs) of 4 mg/L

for chlorine and chloramines and 0.3 mg/L for chlorine dioxide. The

Agency also proposed maximum residual disinfectant levels (MRDLs) for

chlorine and chloramines of 4.0 mg/L, and 0.8 mg/L for chlorine

dioxide. MRDLs protect public health by setting limits on the level of

residual disinfectants in the distribution system. MRDLs are similar in

concept to MCLs--MCLs set limits on contaminants and MRDLs set limits

on residual disinfectants in the distribution system. MRDLs, like MCLs,

are enforceable, while MRDLGs, like MCLGs, are not enforceable.

2. Best Available Technologies

EPA identified the best available (BAT) technology for achieving

compliance with the MCLs for both TTHMs and HAA5 as enhanced

coagulation or treatment with granular activated carbon with a ten

minute empty bed contact time and 180 day reactivation frequency

(GAC10), with chlorine as the primary and residual disinfectant. The

BAT for achieving compliance with the MCL for bromate was control of

ozone treatment process to reduce formation of bromate. The BAT for

achieving compliance with the chlorite MCL was control of precursor

removal treatment processes to reduce disinfectant demand, and control

of chlorine dioxide treatment processes to reduce disinfectant levels.

EPA identified BAT for achieving compliance with the MRDL for chlorine,

chloramine, and chlorine dioxide as control of precursor removal

treatment processes to reduce disinfectant demand, and control of

disinfection treatment processes to reduce disinfectant levels.

3. Treatment Technique

EPA proposed a treatment technique that would require surface water

systems and groundwater systems under the direct influence of surface

water that use conventional treatment or precipitative softening to

remove DBP precursors by enhanced coagulation or enhanced softening. A

system would have been required to remove a certain percentage of TOC

(based on raw water quality) prior to the point of continuous

disinfection. EPA also proposed a procedure to be used by a PWS not

able to meet the percent reduction, to allow them to comply with an

alternative minimum TOC removal level. Compliance for systems required

to operate with enhanced coagulation or enhanced softening was based on

a running annual average, computed quarterly, of normalized monthly TOC

percent reductions. A complete discussion of the proposed requirements

is in Section III.A.

4. Preoxidation (Predisinfection) Credit

The proposed rule did not allow PWSs required to use enhanced

coagulation or enhanced softening to take credit for compliance with

disinfection requirements in the SWTR/IESWTR prior to removing required

levels of precursors unless they met specified criteria. These criteria

are explained in Section IV.A.

5. Analytical Methods

EPA proposed nine analytical methods (some of which can be used for

multiple analytes) to ensure compliance with proposed MRDLs for

chlorine, chloramines, and chlorine dioxide. The three disinfectant

residuals were measured and reported as: chlorine as free chlorine

(four methods) or total chlorine (five methods); chloramines as

combined chlorine (three methods) or total chlorine (five methods); and

chlorine dioxide as chlorine dioxide (3 methods). EPA proposed methods

for the analysis of two classes of organic DBPs: TTHMs (three methods)

and HAA5 (2 methods). In addition, EPA proposed one method for

measuring both inorganic DBPs (chlorite and bromate) and two methods

for total organic carbon (TOC).

6. New Information

Since July, 1994, new information has become available in several

key areas related to issues put forth in the DBP Stage 1 proposal. The

key issues where new information has become available since the

proposal include the following: (1) MCLs; (2) Enhanced Coagulation and

Enhanced Softening; (3) Predisinfection Credit; (4) Health Effects

Information; (5) Analytical Methods; and (6) the Regulatory Impact

Analysis (DBP and TOC occurrence, compliance decision tree). This

information and its implications are discussed in more detail below.

II. Health Effects

The preamble to the 1994 proposed rule provided a summary of the

health criteria documents for bromate; chloramines; haloacetic acids

and chloral hydrate; chlorine; chlorine dioxide, chlorite, and

chlorate; and trihalomethanes. The information presented in the

proposal was used to establish MCLGs and MRDLGs for the disinfectants

and DBPs listed above. Since the 1994 proposal, several epidemiology

and toxicology studies have been completed. The study results need to

be considered for the final Stage 1 DBPR. The following section briefly

[[Page 59394]]

discusses the new epidemiological and laboratory toxicology studies. In

addition, USEPA has developed summaries of this new information and

included these documents in the Docket for this action as ``Summaries

of New Health Effects Data'' (USEPA, 1997b).

A. Cancer Epidemiology Studies

The preamble to the proposed rule discussed several cancer

epidemiology studies that had been conducted over the past 20 years on

chlorinated drinking water (see USEPA, 1994b). At the time of the

proposed rule, there was disagreement among the members of the

Negotiating Committee on the conclusions to be drawn from the cancer

epidemiology studies. Some members of the Committee felt that the

cancer epidemiology data, taken in conjunction with the results from

toxicological studies, provide an ample and sufficient weight of

evidence to conclude that exposure to DBPs in drinking water could

result in an increased cancer risk at levels encountered in some public

water supplies. Other members of the Committee concluded that the

degree of resolution in cancer epidemiology studies on the consumption

of chlorinated drinking water to date was insufficient to provide

definitive information for the regulation. USEPA, therefore, agreed to

pursue additional research to reduce the uncertainties associated with

these epidemiology data and to better characterize and project the

potential human cancer risks associated with the consumption of

chlorinated drinking water. To implement this commitment, USEPA

sponsored two expert panel reviews on the state of cancer epidemiology.

Each of these panels recommended short and long-term research for

improving the assessment of risks using cancer epidemiology.

1. Expert Panels Recommendations on Cancer Epidemiology

USEPA conducted an expert panel workshop in July 1994 on the

scientific considerations for conducting cancer epidemiologic studies

for DBPs (USEPA, 1994a). The expert panel presented the following

conclusions.

(A)lthough ecological and analytic epidemiologic studies have

reported associations between chlorinated water and cancer at

various sites, many of the studies have methodologic problems or

systematic biases that limit the interpretation of results.

Moreover, the studies vary according to the amount of information

available on exposure to chlorinated water or DBPs. The panel agrees

that existing epidemiologic data are insufficient to conclude that

the reported associations are causal or provide an accurate estimate

of the magnitude of risk.

This cancer workshop panel also provided several recommendations

for conducting additional research. These included: (1) improving

exposure assessments; (2) conducting a reanalysis of previously

conducted interview-based case control studies using improved exposure

estimates and analytical methods to determine the validity of these

risks and to address confounding factors and bias not adequately

excluded in previous reports such as the meta-analysis completed by

Morris, et al. (1992) discussed in the 1994 proposed rule (USEPA,

1994b, page 38689); (3) conducting feasibility studies to identify

geographic locations with adequate exposure data and appropriate

cohorts for study (including the possibility of using existing cohorts

that are being studied for other potential exposures); and (4)

consideration of several possible designs for full scale studies (i.e.,

cohort, case-control, and case-control nested within a cohort).

In October 1995, the International Life Sciences Institute (ILSI)

sponsored a workshop on ``Disinfection by-products in Drinking Water:

Critical Issues in Health Effects Research'' (ILSI, 1995). One of the

panels at the workshop provided a brief summary of the findings from

cancer epidemiology studies and made recommendations for further

research in this area. The panel concluded that the epidemiological

studies of bladder and colorectal cancer have generally shown an

increased risk associated with the consumption of chlorinated surface

water, although a causal association has not been conclusively

established. The panel made several recommendations for future research

including the need to conduct hypothesis driven cancer epidemiological

studies to examine the risk of classes of DBPs other than THMs and to

support these studies with improved exposure assessments.

2. Implementation of Expert Panel Recommendations

a. Improve Exposure Assessments/Geographic Identification Studies/

Classes of DBPs Other Than THMs. USEPA, in conjunction with other

parties, has begun research to provide the tools needed to improve

exposure assessments for epidemiology studies. USEPA is supporting

studies in Colorado, North Carolina, and New Jersey that will provide

improved tools for conducting exposure assessments for epidemiology

studies. While the results from these studies will not be available for

the final Stage 1 DBP rule, they will be very useful in designing

future epidemiology studies.

In addition to USEPA's research, the Microbial/DBP Research Council

(M/DBP Council) is funding a study on ``Identification of Geographic

Areas for Possible Epidemiological Studies'' and is evaluating several

proposals for a project on ``Development of Methods for Predicting THM

and HAA Concentrations in Exposure Assessment Studies.'' The M/DBP

Council was formed as a joint USEPA and American Water Works

Association Research Foundation (AWWARF) project to identify and fund

critical research. This research, in conjunction with the USEPA

research discussed above, will improve the understanding of risks

associated with the consumption of chlorinated surface water. However,

as with USEPA's work, this research will not be completed in time to

impact the Stage 1 DBPR.

b. Meta-analysis of Existing Cancer Epidemiology Data. The 1994

proposal includes results of a meta-analysis that pooled the relative

risks from 10 cancer epidemiology studies in which there was a presumed

exposure to chlorinated water and its byproducts (Morris et al., 1992).

This meta-analysis estimated that approximately 10,000 cancer cases

each year could be attributed to the consumption of chlorinated

drinking water and its byproducts. As discussed in the preamble to the

proposed rule, this study generated considerable debate among the

members of the Negotiation Committee. An evaluation of the Morris et

al. meta-analysis has been recently completed for USEPA. USEPA is

currently evaluating this report and will provide an opportunity to

comment on EPA's assessment and implications for the regulatory

provisions for the final Stage 1 DBPR.

In addition to the meta-analysis, USEPA has summarized several new

cancer epidemiology studies and included them as part of the

``Summaries of New Health Effects Data'' (USEPA, 1997b) that is

included in the Docket for this Notice. USEPA will be evaluating the

data from the new epidemiology studies and will provide an opportunity

to comment on the potential implications of these new studies for the

regulatory provisions for the final Stage 1 DBPR.

B. Reproductive and Developmental Epidemiology Studies

The preamble to the 1994 proposal discussed several reproductive

epidemiology studies that had been conducted (see USEPA, 1994b, page

38690). It also included a discussion of an USEPA and ILSI expert panel

that reviewed the published epidemiologic and experimental data on

reproductive

[[Page 59395]]

and developmental effects and a strategy developed by the panel for

related short-term and long-term research (USEPA, 1993b). The panel

concluded that the currently available data on the effects of

chlorination byproducts provide an inadequate basis for identifying

DBPs as a reproductive or developmental hazard. Recommendations were

made for refining studies using existing data bases, strengthening

studies designed to collect new data, improving exposure assessments,

investigating selected health endpoints, and developing a stronger link

between animal research and epidemiology studies.

The results from the ILSI expert panel, and additional information

provided since the 1994 proposal, are summarized in Reif et al. (1996).

This paper reviewed the available epidemiological data on the reported

association between the consumption of chlorinated drinking water and

reproductive and developmental effects. The panel reached the following

conclusions. ``The currently available human studies on effects of

chlorination by-products provide an inadequate basis for identifying

DBPs as a reproductive or developmental hazard. Nevertheless,

additional laboratory animal and epidemiological research should be

conducted, employing a coordinated multi disciplinary approach.'' They

also provided recommendations for short-and longer-term research.

1. Improving Exposure Assessments

Many of the exposure assessment projects identified above for

cancer epidemiology are also relevant to improving exposure assessments

for evaluating reproductive and developmental effects. As discussed in

the cancer epidemiology section, while the results from these studies

will not be available for the final Stage 1 DBPR, they will be very

useful in designing future reproductive epidemiology studies.

2. New Studies Since Proposal

Since the proposal, several new reproductive and developmental

epidemiology studies have been published. Additionally, studies in

California and Colorado are nearing completion, but results will not be

available for this NODA. Savitz et al. (1995) used data from a

population-based case-control study to evaluate the potential risk of

miscarriage, preterm delivery and low birth weight in North Carolina

based on water source, amount of water consumed, and TTHM concentration

in water. The authors concluded, ``These data do not indicate a strong

association between chlorinated byproducts and adverse pregnancy

outcome, but given the limited quality of the exposure assessment and

the increased miscarriage risk in the higher exposure group, more

refined evaluation is warranted.''

Kanitz et al. (1996) conducted an epidemiology study in Italy on

the association between somatic parameters (e.g., birthweight, body

length, cranial circumference, and neonatal jaundice) and drinking

water disinfection with chlorine dioxide and/or sodium hypochlorite.

The authors concluded, ``The study provides some new information on the

possible association between some drinking water disinfection

treatments and somatic parameters of infants at birth. Further

investigations will be needed to verify the results of the present

study by rigorous exposure assessments.''

The 1994 proposed rule reported the results of a New Jersey

Department of Health report on the results of a cross-sectional study

evaluating the association between drinking water contaminants with low

birth weight and selected birth defects (Bove et al., 1992a, 1992b).

Since the proposal, an article summarizing the cross-sectional study

has been published by Bove et al. (1995). The results are consistent

with those reported in the proposed Stage 1 DBPR. The authors

concluded, ``By itself, this study cannot resolve whether the drinking

water contaminants caused the adverse birth outcomes; therefore, these

findings should be followed up utilizing available drinking water

contamination databases.''

While the new epidemiology studies add to the database on the

potential reproductive and developmental effects from DBPs, USEPA

believes that the results are inconclusive. A more complete discussion

of the new reproductive and development epidemiology studies can be

found in the ``Summaries of New Health Effects Data'' (USEPA, 1997b).

C. Significant New Toxicological Information for the Stage 1

Disinfectants and Disinfection Byproducts

Since the proposal, new toxicological information has become

available for several of the disinfectants and DBPs. The information

presented below is a summary of the significant new information for

several disinfectants and DBPs. For a more complete discussion of the

new information see the ``Summaries of New Health Effects Data''

(USEPA, 1997b) in the Docket (a summary of the new information for

chlorine and chloramines is not included below, but is included in the

document cited above.)

1. Chlorite

The 1994 proposal included an MCLG of 0.08 mg/L and an MCL of 1.0

mg/L for chlorite. In order to fill an important data gap, the Chemical

Manufacturers Association (CMA) agreed to conduct a two-generation

reproductive effects study of chlorite. The Negotiating Committee

agreed that if the studies indicated that a level of 1.0 mg/L of

chlorite is safe, the MCL would remain at 1.0 mg/L. If the studies

indicate that a level of 1.0 mg/L of chlorite is not safe or, if such a

study is not conducted, the MCL would be re-evaluated.

After the Negotiating Committee agreed to support a proposed MCL of

1.0 mg/L, USEPA selected developmental neurotoxicity hazard as the

critical effect for chlorite (Mobley et al., 1990). Based on this 1990

rat developmental study, an MCLG of 0.08 mg/L was derived for chlorite.

USEPA believed that the MCL of 1.0 mg/L agreed to by the Committee was

not adequate to protect the public from the acute developmental health

effects of chlorite. USEPA decided to propose an MCL of 1.0 mg/L to

honor the agreement of the Committee and requested comment on several

possible approaches for promulgating the final rule.

Since the proposal, a study on the subchronic toxicity of sodium

chlorite in rats (Harrington et al., 1995a) and a developmental

toxicity study in rabbits (Harrington, et al., 1995b) have been

published. Both of these studies reported no adverse toxicological

effects. Other than the two-generation reproductive study cited above,

which USEPA recently received, relevant new literature has not been

found that would alter the assessment for chlorite from the 1994

proposal. USEPA is conducting an external peer review of the CMA two-

generation reproductive study. These peer review comments will be

included in the Docket for this NODA when they become available. USEPA

will evaluate the data from the CMA study, including the peer review,

and will provide an opportunity to comment on the potential

implications for the regulatory provisions for chlorite prior to the

final Stage 1 DBP rule. The CMA study is included in the Docket for

this action (CMA, 1997).

2. Chlorine Dioxide

The proposed Stage 1 DBPR included a MRDLG of 0.3 mg/L and a MRDL

of 0.8 mg/L for chlorine dioxide. The proposed MRDLG for chlorine

dioxide was based on developmental neurotoxicity as the critical effect

(Orme et al., 1985). The Negotiating Committee agreed to the MRDL of

0.8 mg/L for

[[Page 59396]]

chlorine dioxide with certain qualifications and reservations. As cited

above, the Committee agreed that a two-generation reproductive study on

chlorite would be completed for consideration in the final Stage 1

DBPR. Toxicity information on chlorite is considered relevant for

characterizing the toxicity of chlorine dioxide. If the chlorite study

indicated no concern from reproductive effects at 0.8 mg/L, then the

proposed MRDL for chlorine dioxide would remain the same as proposed.

If these new data indicate reproductive or developmental effects, then

the MRDL will need to be re-examined comparing the tradeoffs and

regulatory impacts of a lower chlorine dioxide MRDL and the positive

aspects of using chlorine dioxide as a disinfectant.

Other than the two-generation reproductive study conducted by CMA

for chlorite, there is no new literature that would alter the

assessment for chlorine dioxide from the 1994 proposal. As stated

above, USEPA believes that the results from the chlorite study are

applicable for addressing the toxicity data gaps for chlorine dioxide.

USEPA will evaluate the data from the CMA study, including the peer

review, and will provide an opportunity to comment on the potential

implications for the regulatory provisions for chlorine dioxide prior

to the final Stage 1 DBP rule.

3. Trihalomethanes

The proposed rule includes an MCL for total trihalomethanes (TTHM)

of 0.080 mg/L. MCLGs of zero for chloroform, bromodichloromethane

(BDCM), and bromoform were based on sufficient evidence of

carcinogenicity in animals. The MCLG of 0.060 mg/L for

dibromochloromethane (DBCM) was based on observed liver toxicity from a

subchronic study and possible carcinogenicity. Since the 1994 proposal,

several new studies have been published on the metabolism for BDCM and

chloroform (Testai et al., 1995; Gemma et al., 1996a, 1996b; Gao et

al., 1996; Nakajima et al., 1995). In addition, several new studies

were found concerning the genotoxicity of chloroform, BDCM, and

bromoform (Roldan-Arjona and Pueyo, 1993; LeCurieux et al., 1995;

Pegram et al., 1997; Larson et al., 1994c; Fujie et al., 1993; Shelby

and Witt, 1995; Hayashi et al., 1992; Sofuni et al., 1996; Matsuoka et

al., 1996; Miyagawa et al., 1995; Banerji and Fernandes, 1996; and

Potter et al., 1996). There are considerable new data on cytotoxicity

and regenerative cell proliferation in the liver and kidney of rats and

mice under various conditions (Larson et al., 1993, 1994a, 1994b,

1994c, 1995a, 1995b, 1996; Templin et al., 1996a, 1996b). Many other

studies also examined the mechanism of chloroform carcinogenicity,

including studying the effects on methylation and expression of growth

control genes (Fox et al., 1990, Vorce and Goodman, 1991, Dees and

Travis, 1994, Testai et al., 1995, Sprankle et al., 1996, Chiu et al.,

1996, Gemma et al., 1996a, 1996b). Short-term toxicity studies

(Thorton-Manning et al., 1994; Lilly et al., 1994 and 1996) and chronic

toxicity studies which included reproductive evaluations (Klinefelter

et al., 1995) were found for BDCM.

The new studies on THMs contribute to the weight-of-evidence

conclusions reached in the 1994 proposal. Based on the available new

studies noted above, the proposed MCLGs for BDCM, DBCM, and bromoform

are not anticipated to change.

The International Life Science Institute (ILSI) convened an expert

panel in 1996 to explore the application of the USEPA's 1996 Proposed

Guidelines for Carcinogen Risk Assessment (USEPA, 1996a) to the

available data on the potential carcinogenicity of chloroform and

dichloroacetic acid (DCA); these data include chronic bioassay data and

information on mutagenicity, metabolism, toxicokinetics and mode of

carcinogenic action. USEPA will be evaluating the data from the ILSI

expert panel for chloroform and will provide an opportunity to comment

on the potential implications for the regulatory provisions for

chloroform and the trihalomethanes prior to the final Stage 1 DBP rule.

4. Haloacetic Acids

The proposed rule included an MCL of 0.060 mg/L for the haloacetic

acids (five HAAs-monobromoacetic acid, dibromoacetic acid,

monochloroacetic acid, dichloroacetic acid, and trichloroacetic acid)

with an MCLG of zero for dichloroacetic acid (DCA) based on sufficient

evidence of carcinogenicity in animals, and a MCLG of 0.3 mg/L for

trichloroacetic acid (TCA) based on developmental toxicity and possible

carcinogenicity.

There has been cancer research completed for other HAAs since the

1994 proposal. The 1994 proposal did not include an MCLG for

monochloroacetic acid (MCA) because there were inadequate occurrence

data for MCA. Since the proposal, a few toxicological studies on MCA

have been identified. A recent 2-year carcinogenicity study on MCA and

trichloroacetic acid (TCA) (DeAngelo et al., 1997) demonstrated that

MCA and TCA were not carcinogenic in male rats. This confirms the

results of the NTP (1990) cancer rodent bioassays of MCA. There have

been several recent studies examining the mode of carcinogenic action

for both DCA and TCA (Pereira and Phelps 1996; and Pereira 1996)

including mutagenicity studies (Austin et al., 1996; Mackay et al.,

1995; Fox et al., 1996; Fuscoe et al., 1996; Tao et al., 1996; and

Parrish et al., 1996). As discussed above USEPA will evaluate the

significance of the ILSI panel's report on the risk assessment for DCA

and provide an opportunity to comment on the potential implications for

the regulatory provisions for DCA and the other haloacetic acids prior

to the final Stage 1 DBP rule.

Screening studies have shown the potential of different haloacetic

acids, including DCA and brominated haloacetic acids, to produce

reproductive and developmental effects (Linder et al., 1997c; Hunter et

al., 1996; Richard and Hunter, 1996; Linder et al. 1994, 1995, 1997a,

1997b). At this time, these new studies are not expected to alter the

MCLGs for DCA or TCA in the proposed rule. USEPA continues to believe

that there are inadequate occurrence data to establish MCLGs for MCA,

monobromoacetic acid and dibromoacetic acid.

5. Chloral Hydrate

The proposed rule included an MCLG of 0.04 mg/L for chloral

hydrate. USEPA did not set an MCL for chloral hydrate because it

believed the MCLs for TTHM and HAA5, and the treatment technique

requirements would provide adequate control for chloral hydrate. In the

1994 proposal, chloral hydrate was considered a group C, possible human

carcinogen. Since the 1994 proposal, several new studies have been

published which contribute to the weight of evidence conclusion for the

potential carcinogenicity of chloral hydrate. These include in vitro

cell transformation and genotoxicity studies (Gibson et al., 1995;

Adler, 1996; Allen et al., 1994; Parry et al., 1996; and Ni et al.,

1996). Some screening studies were found concerning the potential of

chloral hydrate to cause reproductive and developmental toxicity

(Klinefelter et al., 1995 and Saillenfait et al., 1995). The available

new studies mentioned above do not indicate a change in the MCLG for

chloral hydrate.

6. Bromate

The proposed rule included an MCL of 0.010 mg/L and an MCLG of zero

for bromate. A major issue in the proposal was that setting an MCL at

0.010 mg/L

[[Page 59397]]

would exceed the theoretical 1 x 10-4 lifetime excess cancer

risk level for bromate of 5 ug/L. Since the proposal, several

toxicology studies have been completed on bromate, including assays for

reproductive and developmental effects (Wolfe and Kaiser, 1996).

USEPA has recently completed a chronic cancer study in male rats

and male mice for bromate. USEPA is evaluating this data and will

provide an opportunity for public comment on the potential implications

for the regulatory provisions for bromate prior to the final rule.

D. Summary of Key Observations

Since the proposal, several epidemiology and toxicology studies

have been completed on the potential health effects associated with

exposure to DBPs. USEPA currently believes the new published data will

not impact the MCLGs for BDCM, CDBM, bromoform, chloral hydrate, or

trichloroacetic acid. However, USEPA is currently evaluating the

results from new toxicology studies for chlorite and bromate and will

evaluate the report from the ILSI expert panel on chloroform and DCA

when it becomes available. USEPA will provide an opportunity to comment

on the potential implications for the regulatory provisions for these

DBPs prior to the final rule.

E. Request for Public Comments

USEPA requests comment on all the new information outlined above

and its potential impacts on the regulatory provisions for the final

Stage 1 DBPR and any additional data on the health effects from DBPs

that need to be considered for the final Stage 1 DBPR.

III. Enhanced Coagulation and Enhanced Softening

A. 1994 Enhanced Coagulation and Enhanced Softening Proposal

As discussed above, the 1994 proposed rule for D/DBPs included

enhanced coagulation/enhanced softening requirements in addition to

maximum contaminant levels (MCLs) for total trihalomethanes (TTHMs) and

the sum of five haloacetic acids (HAA5) (USEPA, 1994b). In that

proposal, Subpart H systems (utilities treating either surface water or

groundwater under the direct influence of surface water) that use

conventional treatment (i.e., coagulation, sedimentation, and

filtration) or precipitative softening would be required to remove DBP

precursors by enhanced coagulation or enhanced softening. The removal

of total organic carbon (TOC) would be used as a performance indicator

for DBP precursor control. The 1994 proposed rule (in ``Step 1'' of the

treatment technique) provided for 20-50 percent TOC removal, depending

on influent water quality (Table III-1).

Table III-1.--1994 Proposed Required Removal of TOC by Enhanced

Coagulation/Enhanced Softening for Surface-Water Systems a Using

Conventional Treatment b

------------------------------------------------------------------------

Source-water alkalinity, mg/L as

CaCO3

Source-water TOC, mg/L --------------------------------------

0-60 >60-120 >120 c

(percent) (percent) (percent)

------------------------------------------------------------------------

>2.0-4.0......................... 40.0 30.0 20.0

>4.0-8.0......................... 45.0 35.0 25.0

>8.0............................. 50.0 40.0 30.0

------------------------------------------------------------------------

a Also applies to utilities that treat groundwater under the influence

of surface water.

b Systems meeting at least one of the conditions in Section

141.135(a)(1)(i)-(iv) of the proposed rule are not required to operate

with enhanced coagulation.

c Systems practicing precipitative softening must meet the TOC removal

requirements in this column.

The 1994 Stage I Federal Register notice proposed that systems

achieve a percent TOC removal based on their influent TOC concentration

and alkalinity. The proposed rule provided for a number of exceptions

to the enhanced coagulation and enhanced softening requirements,

namely: (a) When the system's treated water TOC concentration, prior to

the point of continuous disinfection, is 2.0 mg/L (b) when

the PWS's source water TOC level, prior to any treatment, is 60 mg/L; and these systems are achieving TTHMs

3), except those

that use ion exchange, are not subject to performance criteria for the

removal of TOC.

As part of the enhanced coagulation requirements, the proposed rule

indicated that if a PWS could not meet the prescribed TOC removal

criteria, it must perform a series of jar or pilot-scale tests (``Step

2'') to determine how much TOC removal they can reasonably and

practically achieve. This Step 2 requirement was created to handle the

10 percent of the waters that were not expected to meet the Step 1

criteria, and considerations as to what was practical to achieve

involved a consensus-based balancing of policy and scientific

perspectives.

The proposed jar-testing protocol involves adding regular-grade

alum in 10 mg/L increments (or an equivalent amount of iron coagulant)

until specific depressed pH goals are achieved (this was referred to as

``maximum pH'' in the proposal), which depends on influent alkalinity

and what is practical to achieve. For the alkalinity ranges 0-60, >60-

120, >120-240, and >240 mg/L as calcium carbonate (CaCO3),

the maximum pH values are 5.5, 6.3, 7.0, and 7.5, respectively. The

maximum pH is a target pH goal for step 2 testing. The maximum pH is

the pH value the tested water must be at or below before incremental

coagulant addition is discontinued. The protocol was based on alum, as

more data were available on the use of this coagulant in a wide variety

of waters. However, the proposed rule allows for the use of iron

coagulants in the step 2 jar testing.

The TOC of each jar-treated water is measured, and then the

residual TOC is plotted versus alum dosage. The ``point of diminishing

returns'' (PODR) is determined to be when 10 mg/L of additional alum

(or an equivalent amount of iron coagulant) does not decrease residual

TOC by 0.3 mg/L (i.e., slope of TOC versus alum dosage curve

[0.3 mg/L TOC]/[10 mg/L alum]). These data would be used by

a utility

[[Page 59398]]

to request alternative TOC removal performance criteria from the

primacy agency. However, one of the intents in setting the step 1 TOC

removal percentages at the values chosen was to provide that 90 percent

of the systems would not need to do step 2 testing. This would minimize

transactional costs for the primacy agencies.

If the TOC removal curve never met the slope criterion at any

coagulant dose, such a water would be considered unamenable to enhanced

coagulation and no TOC removal would be required for such a water.

Waters with low TOC and moderate-to-high alkalinity were expected to be

some of the more difficult to treat with enhanced coagulation, so

systems treating such waters were encouraged to explore alternative

technologies (e.g., ozone/chloramines) that could reduce DBP levels

significantly below the proposed Stage 1 MCLs (i.e., 3?

(2) Use of ferrous salts: Can ferrous salts be used at softening pH

levels to further enhance TOC removals?

(3) Step 2: Whether data are available on the use of ferrous salts

in the softening process which can help define a step 2 for softening?

What is the definition of Step 2?

B. New Information on Enhanced Coagulation and Enhanced Softening since

1994 Proposal

Since the 1994 proposal, there has been considerable research on a

number of enhanced coagulation and enhanced softening issues

highlighted above in a wide variety of waters nationwide. A summary of

the results of some of the studies and surveys are included below.

Studies of enhanced coagulation are covered first, followed by

discussion of enhanced softening studies. Note that a number of the

softening studies looked at TOC removal in essentially the same

framework as is used for enhanced coagulation, with emphasis on the

coagulant and lime dose and geared toward finding a similar format for

step 2 enhanced softening as was defined for enhanced coagulation. A

number of these studies focused on the benefits of increased lime or

coagulant doses in removing TOC in softening systems. Results of these

studies generally showed that percent TOC removal is dependent on the

raw water.

1. New Data on Enhanced Coagulation

a. UNC Enhanced Coagulation Study. To address many of the

aforementioned issues, the University of North Carolina (UNC) at Chapel

Hill, with funding from the Water Industry Technical Action Fund

(WITAF), performed an enhanced coagulation study (Singer et al., 1995).

The UNC research team evaluated a wide range of waters nationwide,

which included at least three waters in each box of the 3 x 3 matrix in

Table III-1. Each water was jartested in order to determine the

feasibility of achieving the proposed step 1 TOC percent removal

requirement for each water, as well as to assess the PODR criteria.

In addition, recognizing that coagulation primarily removes the

humic fraction of the natural organic matter (NOM) in water (Owen et

al., 1993), a determination of the percent humic content was made for

each of the waters studied in order to better characterize the

treatability of each water. NOM fractionation was performed on samples

of each raw water and on select coagulated waters using an XAD-8 resin

adsorption procedure (Thurman & Malcolm, 1981). In this procedure, the

hydrophobic fraction of the water, which includes humic substances, was

determined.

Furthermore, Edzwald and Van Benschoten (1990) have found the

specific ultraviolet absorbance (SUVA) of a water to be a good

indicator of the humic content of that water, so SUVA was also

determined in the UNC study. SUVA is defined as the UV (measured in

m-1) divided by the dissolved organic carbon (DOC)

concentration (measured as mg/L). Typically, SUVA values 40 mg/L).

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In the jar tests of the Raleigh water, an alum dose of

35 mg/L resulted in the removal of 47 percent

of the TOC, where the proposed step 1 TOC removal for this water was

predicted to be 45 percent. The PODR, based on the slope criterion of

0.3 mg/L TOC/10 mg/L of alum, was realized at a jar-test alum dose of

39 mg/L, in which 51 percent of the TOC was removed. In order to comply

with a 45-percent TOC removal requirement with a 15-percent safety

factor (Krasner et al, 1996), a system would need to design for a 52-

percent TOC removal.

The results using the Raleigh water appear to address several of

the outstanding issues: namely, that the step 1 TOC removal

requirements for this water is appropriate, the slope criterion did

identify the PODR, and evaluation of the PODR required an examination

of points beyond the threshold coagulant dose. Figure III-3 shows jar

test results for a low-TOC (2.9 mg/L), high-alkalinity (239 mg/L) water

from Indianapolis, IN, from the UNC study (White et al., 1997). The TOC

removal curve never exceeded the 0.3/10 slope criterion, which means

that this water would be exempt from the enhanced coagulation

requirements in the 1994 proposed rule. The step 1 TOC removal

requirement of 20 percent can be achieved, with an alum dose of

65 mg/L required in the jar tests. However, the slope of

the TOC removal curve shows that this water is not very amenable to

enhanced coagulation.

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A summary of the controlling criterion for each of the 31 waters

tested by UNC, based on the 1994 proposed rule criteria, is shown in

Table III-2 (adapted from White et al., 1997). Only 14 of the 31 waters

met the proposed step 1 percent TOC removal requirements or achieved a

settled water TOC concentration 3

Source-water TOC, mg/L -------------------------------------------------------------------------

0-60 >60-120 >120

----------------------------------------------------------------------------------------------------------------

>2.0-4.0.............................. a PODR b N/A c

PODR PODR PODR

PODR STEP 1 d N/A

PODR PODR

PODR

>4.0-8.0.............................. STEP 1 PODR STEP 1

STEP 1 PODR STEP 1

STEP 1 STEP 1 PODR

STEP 1

>8.0.................................. STEP 1 STEP 1 STEP 1

STEP 1 PODR PODR

PDOR STEP 1 PODR

----------------------------------------------------------------------------------------------------------------

a Settled water TOC less than 2.0 mg/L.

b Point of diminishing returns.

c Not amenable to enhanced coagulation.

d Step 1 required percent removal of TOC.

White and co-workers (1997) examined the relationship between the

percent humic (hydrophobic) content of the raw waters in the UNC study

and the maximum percent removal of DOC achieved at the high alum doses

where little additional TOC removal was observed. Figure III-4 shows

that waters with relatively high levels of humic material tended to

exhibit higher degrees of DOC removal than those with low humic

content. Figure III-5 shows that waters that contained high initial

nonhumic (hydrophilic) DOC concentrations tended to have high residual

DOC concentrations following coagulation.

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In the UNC study, the humic carbon content of the raw waters was

reasonably correlated (r\2\=0.74) with their SUVA values (White et al.,

1997). Figure III-6 shows that waters with high initial SUVA values

(i.e., 3.4-5.7 L/mg-m) exhibited significant reductions in SUVA as a

result of coagulation, reflecting substantial removal of the humic (and

other UV-absorbing) components of the overall organic matter, whereas

waters with low initial SUVA values (i.e., 1.5-2.0 L/mg-m) exhibited

relatively low reductions in SUVA. For all of the waters examined, the

residual SUVA (i.e., 2.4 L/mg-m) tended to plateau at high

alum doses, reflecting that the residual DOC was primarily nonhumic

organic matter.

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In the UNC study, for the 14 waters in which the step 1 TOC removal

requirements were met before the PODR was reached, the average raw-

water SUVA was 3.9 L/mg-m, whereas the average raw-water SUVA of the

other 17 waters was 2.6 L/mg-m (White et al., 1997). For most of the 31

waters examined, the PODR was found to occur at alum doses where SUVA

had already reached its plateau. These findings suggested that raw-

water SUVA values might be utilized in redefining the step 1 TOC

removal requirements and that residual SUVA values might be utilized in

defining the PODR. Unlike NOM characterizations with XAD resins in a

research laboratory, SUVA is an easy parameter that can be determined

by laboratories that measure DOC concentrations and UV absorbance.

b. Metropolitan Water District of Southern California/Colorado

University Enhanced Coagulation Study. As noted in the UNC study,

waters with low TOC and high alkalinity were expected to be the more

difficult to treat with enhanced coagulation. Metropolitan Water

District of Southern California (MWDSC) and Colorado University at

Boulder did detailed studies on two low-TOC waters, one with moderate

alkalinity (California State Project Water) and the other with high

alkalinity (Colorado River water). In addition to using an XAD-8 resin

fractionation to quantify the humic (hydrophobic) versus nonhumic

(hydrophilic) content of the NOM, a 1000-dalton (1K) ultrafilter was

used to determine what fraction of the bulk or coagulated water was of

a lower versus higher molecular weight (Amy et al., 1987).

California State Project Water (with 80 mg/L alkalinity) was jar-

treated with incremental alum doses of 622 mg/L (up to a

total of 111 mg/L). Figures III-7 and III-8 show that addition of alum

at 47 mg/L reduced the raw-water bulk DOC concentration from 4.3 mg/L

to 2.6 mg/L (a 39-percent bulk DOC removal); subsequent alum addition

resulted in a plateauing of the DOC removal rate (Krasner et al.,

1995). Throughout the entire range of alum doses evaluated, little of

the low-MW and nonhumic DOC was removed. The high-MW and humic

fractions, however, were well removed with increasing alum dosages,

demonstrating preferential removal of these fractions. The residual DOC

remaining after enhanced coagulation was primarily made up of low-MW

and nonhumic material. The latter NOM fractions represent the part of

the bulk DOC that is not readily amenable to removal by coagulation.

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For this sample of California State Project Water, 52 percent of

the DOC was humic NOM and the SUVA value was 2.5 L/mg-m (Krasner et

al., 1995). Figure III-9 shows that increasing doses of alum reduced

the fraction of humic DOC in the residual DOC to 26 percent. In

addition, the reduction in SUVA closely paralleled the reduction in the

humic content of the residual DOC. SUVA was reduced to 1.7 L/mg-m with

47 mg/L of alum, whereas the addition of 111 mg/L of alum only reduced

the value of SUVA to 1.5 L/mg-m.

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Colorado River water has a greater amount of low-molecular weight

DOC and somewhat more nonhumic DOC than California State Project Water

(Krasner et al., 1995). Nonetheless, increased doses of alum did remove

DOC in Colorado River water, although not to the same extent as in

California State Project Water. Although the alkalinity of Colorado

River water (135 mg/L) is higher than that of California State Project

Water, the difference in treatability was more likely related to the

differences in the NOM characteristics of the two waters. As with

California State Project Water, the residual DOC in the coagulated

Colorado River water was primarily low-molecular weight and nonhumic

NOM (Figures III-10 and III-11). The raw-water Colorado River water had

a SUVA value of 1.1 L/mg-m and 44 percent of the DOC was humic NOM.

After the addition of 114 mg/L of alum, the humic content of the

residual DOC was only reduced to 38 percent and the SUVA value was only

reduced to 1.0 L/mg-m (Figure III-12).

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Cheng and co-workers (1995) studied enhanced coagulation of

California State Project Water and Colorado River water, as well as the

effects of seasonal changes on TOC removal. Several water blends were

tested, including 100-percent California State Project Water and

Colorado River water, as well as 90-, 80-, 70-, 60-, and 50-percent

Colorado River water blends. These blends represent the range of waters

that are treated at MWDSC's plants and may be subject to enhanced

coagulation treatment. The SUVA values for California State Project

Water during this study ranged from 2.8 to 3.8 L/m-mg, whereas the SUVA

values for Colorado River water varied from 1.0 to 1.7 L/m-mg (the

blends of California State Project Water and Colorado River water

contained SUVA values of 8 mg/L)/low alkalinity

(120 mg/L) waters had low-SUVA (median = 1.7).

For the entire 3 x 3 matrix, the cumulative probability distribution

(10th, 50th, and 90th percentile) of SUVA values typically increased

with either increasing TOC or decreasing alkalinity. Because SUVA is an

indication of humic NOM content, and it is the humic fraction that is

most amenable to enhanced coagulation, this SUVA distribution supports

the earlier observation of the UNC research team that step 1 TOC

removals were most readily met in high-TOC waters with low alkalinity.

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From this database, the Colorado University research team (Edwards,

1997; Tseng & Edwards, 1997) developed a model for predicting organic

carbon removal during enhanced coagulation, using as input the

coagulant dose, coagulation pH, raw-water UV absorbance, and raw-water

DOC concentration. The model assumes that all DOC can be divided into

two distinct fractions (Figure III-13): DOC that strongly complexes

hydroxide surfaces formed during coagulation and DOC that does not

(Edwards et al., 1996). Edwards defined these fractions as sorbing and

nonsorbing DOC, respectively. In the model, the relative fraction of

sorbing and nonsorbing NOM is calculated using an empirical relation

based on the value of SUVA (Edwards, 1997).

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In the Colorado University modeling effort (Edwards, 1997), the

best predictive capability was provided by a site-specific approach

using a best-fit sorption constant and nonsorbing DOC fraction for each

water quality and coagulant type (Figure III-14). Assuming a typical

DOC analytical error of either 0.25 mg/L or 5

percent, 81 percent of the model predictions were accurately predicted

within analytical precision.

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The Colorado University DOC/SUVA model was subsequently used to

determine the ``maximum'' TOC removal that can be achieved with

enhanced coagulation. All nine boxes in the 3 x 3 matrix (Table III-3)

were evaluated using the 10th, 50th, and 90th percentile water

qualities. The model was used to determine the amount of sorbable TOC

and to examine removal of 100, 90, 80, 70, 60, and 50 percent of the

sorbable TOC.

Table III-4 summarizes the results from the maximum TOC removal

task. A 10th percentile SUVA value corresponds to a water that is

difficult to treat (relative to other waters in that same box), whereas

a 50th and 90th percentile SUVA value corresponds to waters that are

average and easy to treat, respectively, in that box. The sorbable

amount of TOC represents the maximum amount of TOC that can be removed

using coagulants with no limit on coagulant dosage. Therefore, these

values may not be practical or realistic to achieve. In Table III-4,

the 1994 proposed Step 1 TOC removal requirements are listed, along

with a 15 percent safety factor. For example, in the low-TOC, low

alkalinity box, the current Step 1 TOC removal requirement (40 percent)

with a safety factor is 46 percent. In this box, for an easy to treat

water (90th percentile SUVA of 3.97), 62 percent of the sorbable TOC

would need to be removed to ensure compliance with the proposed

requirement; whereas for a difficult to treat water (10th percentile

SUVA of 2.84), 71 percent of the sorbable TOC would need to be removed.

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The next analyses evaluated what TOC removal is ``practical'' to

achieve in order to better define the 3 x 3 matrix. The data analyses

were aimed at developing an alternative set of percent TOC removal

numbers for step 1 requirements, recognizing that the goal was to

select values that could be ``reasonably'' met by 90 percent of the

systems implementing enhanced coagulation. Using the database compiled

through the Malcolm Pirnie, Inc./AWWA project and summarized in Table

III-3, the following nine equations were developed to predict ``90th-

percentile'' TOC for a given coagulant dose. Figure III-15 illustrates

the shape of the curves for the low-alkalinity waters.

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The significance of the 90th-percentile data point is that 90

percent of systems (represented by the database) will have a lower

residual TOC compared to what is predicted by the equations for a given

coagulant dose.

1. TOC=1.42+2.04 e -7.15

Dose (moles/L) [for low-TOC, low-alkalinity box]

2. TOC=1.37+2.10 e -3.92

Dose (moles/L) [for low-TOC, medium-alkalinity box]

3. TOC=2.10+1.27 e -2.73

Dose (moles/L) [for low-TOC, high-alkalinity box]

4. TOC=1.60+5.38 e -6.29

Dose (moles/L) [for medium-TOC, low-alkalinity box]

5. TOC=2.11+4.41 e -3.47

Dose (moles/L) [for medium-TOC, medium-alkalinity box]

6. TOC=2.64+3.30 e -4.83

Dose (moles/L) [for medium-TOC, high-alkalinity box]

7. TOC=3.22+23.1 e -2.99

Dose (moles/L) [for high-TOC, low-alkalinity box]

8. TOC=4.88+13.8 e -3.33

Dose (moles/L) [for high-TOC, medium-alkalinity box]

9. TOC=6.61+6.44 e -3.57

Dose (moles/L) [for high-TOC, high-alkalinity box]

Based upon the above equations, the coagulant dosages for achieving

the proposed percent TOC removals and the proposed PODR slope criterion

(i.e., 0.3 mg/L TOC per 10 mg/L of alum) were calculated. These

calculations indicated that the low-TOC boxes will be at the proposed

slope criterion at coagulant dosages lower than what would be required

for achieving the proposed step 1 percent TOC removals. The opposite

was true for the high-TOC boxes. For the medium-TOC boxes, the

calculated coagulant dosages were approximately equal for both

criteria. The trends for the different boxes in the matrix are similar

to that observed by the UNC research team (Table III-2). Table III-5

summarizes the controlling criteria.

Table III-5.--Controlling Criterion for Enhanced Coagulation for Waters

Evaluated in Malcolm Pirnie, Inc. Study, Based on Modeling Approach

------------------------------------------------------------------------

Alkalinity mg/L

TOC (mg/L) -----------------------------------------

0-60 >260-120 >120

------------------------------------------------------------------------

>2.0-4.0...................... PODR........ PODR......... PODR

>4.0-8.0...................... Step 1...... PODR......... Step 1

>8.0.......................... Step 1...... Step 1....... Step 1

------------------------------------------------------------------------

Malcolm Pirnie, Inc. next examined SUVA removal curves (Figure III-

16), similar to what was examined by the UNC research team (Figure III-

6).

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The 90th-percentile SUVA curves were observed to reach asymptotic

values with increasing coagulant Dose (Figure III-16 illustrates the

shape of the curves for the low-TOC waters). The following seven

equations were developed to predict the 90th-percentile SUVA for a

given coagulant Dose. The three alkalinity ranges for the high-TOC

waters were collapsed into one group due to lack of sufficient data.

Similar to the TOC equations, the significance of the 90th-percentile

data point is that 90 percent of systems (represented by the database)

will have a lower residual SUVA compared to what is predicted by the

equations for a given coagulant Dose.

a. SUVA=1.8+2.1 e -11.1

Dose (moles/L) [for low-TOC, low-alkalinity box]

b. SUVA=1.8+1. 2 e -7.9

Dose (moles/L) [for low-TOC, medium-alkalinity box]

c. SUVA=1.4+2.2 e -9.5

Dose (moles/L) [for low-TOC, high-alkalinity box]

d. SUVA=1.9+2.8 e -17.5

Dose (moles/L) [for medium-TOC, low-alkalinity box]

e. SUVA=1.8+2.0 e -5.2

Dose (moles/L) [for medium-TOC, medium-alkalinity box]

f. SUVA=2.1+0.95 e -6.0

Dose (moles/L) [for medium-TOC, high-alkalinity box]

g. SUVA=2.5+2.8 e -3.8

Dose (moles/L) [for high-TOC boxes]

From a theoretical viewpoint, the asymptote of the above equations

represents the minimum SUVA that could be achieved for a given data set

(box) of the 3x3 matrix. The dosages for the minimum SUVA are related

to certain maximum percent TOC removals. However, from a practical

standpoint, achieving the minimum SUVA could be extremely difficult. An

alternative approach could be to attempt to reach SUVA values which are

20 or 25 percent above minimum SUVA indicated by the above equations.

Equations 1 through 9 and equations a. through g. were combined to

determine the practical percent TOC removal values that could be

achieved. The results for ``minimum SUVA+25%'' are shown in Table III-

6.

Table III-6.--TOC Removals (%) at ``Minimum SUVA+25%,'' Based on Malcolm

Pirnie, Inc. Modeling Effort

------------------------------------------------------------------------

Alkalinity (mg/L)

TOC (mg/L) ---------------------------

0-60 >60-120 >120

------------------------------------------------------------------------

>2.0-4.0.................................... 35 25 15

>4.0-8.0.................................... 35 45 20

>8.0........................................ 60 55 35

------------------------------------------------------------------------

One limitation of a step 2 based on a settled-water SUVA approach

would be that the utilities would have to determine these SUVA values

in the absence of any oxidant (such as chlorine, permanganate, or

ozone). Addition of oxidant changes the characteristics of the NOM in a

manner that disproportionately affects the UV absorbance compared to

TOC, thus changing the SUVA values without any actual removal of TOC.

d. Evaluation of current (baseline) TOC removals at full-scale.

Full-scale TOC removal data were obtained from 76 treatment plants

(Table III-7). These data were obtained from plants in the American

Water Works Service Company (AWWSCo) system, plants studied by Randtke

et al. (1994), and plants in North Carolina studied by Singer et al.

(1995). Note that these data represent a one-time sampling at each

plant and no specific attempt was made to meet the proposed TOC removal

percentages. Also, the proposed compliance requirements were based on

an annual average. Based on current treatment, 83 percent of the

systems treating moderate-TOC, low-alkalinity water removed an amount

of TOC greater than the proposed step 1 requirement, whereas only 14

percent of the systems treating water with low TOC and high alkalinity

met the proposed step 1 requirement. For the other systems treating

low- or moderate-TOC water, 29-38 percent met the proposed step 1

requirements with existing treatment. Although all of the high-TOC

systems met the proposed TOC removal requirements with current

treatment, the number of systems in this database were insignificant

(1-2 per box).

Table III-7.--TOC Removal at Full-Scale Treatment Plants

----------------------------------------------------------------------------------------------------------------

TOC >2.0-4.0 mg/L Percent of plants that achieve specified TOC removal

----------------------------------------------------------------------------------------------------------------

No. of Step 1 0-10% 10-20% 20-30% 30-40% >40%

Alkalinity (mg/L) Plants TOC% removal removal removal removal removal

----------------------------------------------------------------------------------------------------------------

0-60................................. 14 40 14 14 14 29 *29

>60-120.............................. 11 30 36 0 27 18 18

>120................................. 7 20 57 29 14 0 0

----------------------------------------------------------------------------------------------------------------

TOC >4.0-8.0 mg/L

(4)Percent of plants that achieve

specified TOC removal

--------------------------------------------------------------------------

0-15%

removal 15-25%

removal 25-35%

removal 35-45%

removal >45%

removal

----------------------------------------------------------------------------------------------------------------

0-60................................. 18 45 0 0 11 6 83

>60-120.............................. 8 35 12 25 25 38 0

>120................................. 13 25 31 31 23 15 0

----------------------------------------------------------------------------------------------------------------

TOC >8.0 mg/L

(4)Percent of plants that achieve

specified TOC removal

--------------------------------------------------------------------------

0-20 20-30 30-40 40-50 >50

----------------------------------------------------------------------------------------------------------------

0-60................................. 2 50 0 0 0 0 100

>60-120.............................. 2 40 0 0 0 0 100

>120................................. 1 30 NA NA 100 NA NA

----------------------------------------------------------------------------------------------------------------

*Values in bold represent the percentage of systems that achieved full-scale TOC removal that is greater than

the proposed step 1 requirements.

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e. Evaluation of ``optimized'' TOC removal. An ``optimized''

coagulation database was assembled, utilizing experiments performed by

AWWSCo and by Randtke et al. (1994) (Table III-8). This database

included experiments in which a combination of coagulant and acid was

evaluated. The National Sanitation Foundation (NSF) limit on sulfuric

acid addition (to minimize the introduction of trace impurities present

in the acid) is 50 mg/L. In examining the database, an attempt was made

to limit coagulant doses to 10-20 times the TOC level.

Thus, a water with 3 mg/L TOC might use up to 30-60 mg/L of coagulant

(with or without acid), but would not use 100 mg/L of coagulant full-

scale. However, a water with 10 mg/L TOC could use 100 mg/L or more of

coagulant given the aforementioned 10-20 multiplier for

coagulant dose and TOC. A dose of this magnitude is discouraged because

the NSF limits on aluminum sulfate and ferric chloride are 150 mg/L and

250 mg/L, respectively. Because these experiments were performed

without these acid and coagulant dose limits as constraints, some

waters were evaluated with more realistic chemical doses in the PODR

experiments. A judgment was made in deciding which set of conditions

was the most realistic for each water evaluated. With these elements in

mind, an assessment was made as to which experiment was the most

appropriate (controlling criteria) for each water. In some cases, a

source water was tested more than once. If the identical sample of

water (same TOC, SUVA, alkalinity) was coagulated with different

coagulants, with or without acid, the highest TOC removal for that

water was chosen, as many systems enhancing their coagulation process

are also evaluating switching the type of coagulant.

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f. ``Case-by-case'' data analyses. A decision was made by the TWG,

based on the Malcolm Pirnie, Inc. modeling effort and examination of

the case-by-case data, to segment out raw waters with SUVA

(SUVAr) 120 mg/L) waters in the low

(>2-4 mg/L) and moderate (>4-8 mg/L) TOC boxes have SUVA 2.0 L/mg-m, the

minimum, 25th percentile, 50th percentile, 75th percentile, and maximum

TOC removal for each of the boxes in the 3 x 3 matrix were determined.

This analysis allowed for an analysis of the cumulative probability

distribution of TOC removal for waters that are amenable to enhanced

coagulation.

(3) For example, the high-TOC (>8 mg/L)/low alkalinity (0-60 mg/L)

box had a range of TOC removals from 56 to 76 percent. In order to

comply with a 50 percent TOC removal (the proposed step 1 value for

that box) with a safety factor of 15 percent, a 57 percent TOC removal

would be required. The minimum and 25th percentile TOC removal for that

box is 56 percent. Thus, it is expected that essentially all of the

waters in this box (based on this limited data set and data from other

sources) could comply with the proposed step 1 requirement.

(4) If the step 1 requirement for the high-TOC/low-alkalinity box

was raised, for example, to 60 percent, then systems would need a 69

percent TOC removal to safely meet such a requirement. The 75th

percentile of TOC removal for this box is 69 percent. Thus, raising the

step 1 requirement to 60 percent could potentially drive half or more

of the systems in this box to need to do step 2 testing for possible

alternative performance criteria. Thus, these data suggest that for

this and a number of other boxes (all of the high-TOC boxes and

probably most of the moderate-TOC boxes), the currently proposed step 1

TOC removals are appropriate. Systems that can achieve higher TOC

removals in these boxes will consider doing so in order to more

effectively meet the DBP MCLs that have been proposed.

(5) For the low-TOC boxes, even after excluding the low-SUVA

waters, the proposed step 1 TOC removal levels still appear too high.

In Malcolm Pirnie, Inc.''s modeling of TOC removal at minimum SUVA + 25

percent, it was predicted that the required TOC removals in the low-TOC

boxes would be 35, 25, and 15 percent for low-, moderate-, and high-

alkalinity, respectively. These predicted TOC removal values are in the

range for which the majority of low-TOC waters with SUVA values >2.0 L/

mg-m can achieve. Thus, the TWG recommended to the FACA Negotiating

Committee-based on Malcolm Pirnie, Inc.''s modeling effort and this

case-by-case analysis--a revised set of TOC removal numbers for the

low-TOC boxes, keeping in mind that low-SUVA waters would be excluded

from the requirement.

(6) The TWG also recommended to the FACA Negotiating Committee an

alternative step 2 point of diminishing return (PODR) of settled-water

SUVA 2.0 L/mg-m. This action will also reduce transactional

costs, as presentation of a settled-water SUVA value will be easier

than presenting jar-test data. Nonetheless, the jar-test protocol and

slope criterion will still be needed for evaluating alternative

performance criterion for other waters.

2. New Data on Enhanced Softening

a. AWWARF studies--data on TOC removal. Several studies examined

the relationship between increased coagulant dose and TOC removal

(Shorney and Randtke, 1996; Clark et al. 1994). These studies indicate

that the benefit from increased coagulant dose in TOC removal was

dependent on the raw water. In a study funded by AWWARF, Shorney and

Randtke (1994) indicated that utilities treating source water

relatively low in TOC (i.e., 2.5 to 4 mg/L) and low in turbidity will

have the greatest difficulty in removing TOC (Figure III-17 and III-

18).

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The authors indicate some improved TOC removal from small doses of

iron salts (5 mg/L ferric sulfate), but no additional TOC removal

during softening occurred with increased coagulant addition (up to 25

mg/L dose) as shown in Figures III-17 and III-18.

In limited jar testing and in pilot testing, the City of Austin (a

softening plant) has observed no significant difference in TOC removal

with increasing doses of ferric sulfate beyond a low dose. Table III-9

shows the impact of increasing ferric sulfate doses on the turbidity

and TOC concentration for jar tests in the City of Austin. The results

indicate no significant difference in TOC removal with increasing doses

of ferric coagulants, but did show that varying the coagulant dose did

impact the turbidity removal as measured by NTU.

Table III-9.--Impact of Varying Ferric Coagulant Dose on TOC Removal,

Austin, Texas, 4/9/93, 110 mg/L Lime Dose, Jar Tests

------------------------------------------------------------------------

Treated

water Treated

Ferric sulfate addition (mg/L) turbidity, water TOC

NTU (mg/L)

------------------------------------------------------------------------

3................................................ 16 2.45

6................................................ 15 2.30

9................................................ 12 2.46

12............................................... 12 2.23

18............................................... 5.5 2.31

------------------------------------------------------------------------

Pilot testing confirmed the jar test results by showing that

increasing ferric sulfate doses beyond that required for turbidity

removal proved to have no advantage in additional TOC removal (see

Figure III-19).

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Full-scale plant data from St. Louis County Water Company and

Kansas City, MO Water Services show that water temperature, turbidity,

and raw water TOC levels have direct impact upon the efficiency of lime

softening with iron salt coagulants to improve TOC removal.

Multiple jar tests on various waters done by Singer et al. (1996)

focused on the relationship between use of lime and soda ash and TOC

removal. Using only lime and soda ash (no coagulants), Singer et al.

defined the dosages required to meet TOC removal percentages in the

matrix. He also defined the dosages required to remove 10 mg/L of

magnesium for nine waters that met the alkalinity levels in the right

hand column of the matrix (i.e., >120 mg/L). Results of these jar tests

are shown in Table III-10. Impacts of the proposed rule would be

significant to softening plants if the TOC removal requirements were

required to be met by all plants because the requisite lime and soda

ash doses were higher than existing doses in the plants. Singer et al.

(1996) found the removal of 10 mg/L of magnesium hardness to have less

impact, although using the magnesium criteria would make TOC removal

levels variable and less significant than meeting the removal levels in

the matrix.

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b. Shorney and coworkers--data on use of SUVA. As discussed

previously, SUVA may be a practical method for determining which PWSs

would be required to perform enhanced coagulation and enhanced

softening. SUVA has been found to be a good indicator of humic content

and it is the humic material that is best removed by coagulation.

Shorney et al. (1996) report raw water SUVA values -1) divided by the DOC concentration (mg/L). Typically,

SUVA values 2-4............................................ 11 8

>4-8............................................ 20 17

>8.............................................. 4 3

------------------------------------------------------------------------

The data were analyzed with two goals in mind: to find the

appropriate TOC removal levels for the rule matrix for softening plants

and to determine what would define an appropriate step 2 for softening

systems. To address the first question, the average TOC percent

removals for each TOC group were plotted on a percentile basis and are

shown in Figure III-21 (Clark et al., 1997) for the 2-4 mg/L TOC, and

Figure III-22 for the 4-8 mg/L TOC (Clark et al., 1997).

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To examine the percentage of plants that would meet the proposed

requirements, the survey data were analyzed and the results are shown

in Table III-12. The results in Table III-12 indicate that the relative

impact of meeting the TOC removal requirement in the proposed rule

would be greatest in the low TOC group (>2-4 mg/L) .

Table III-12.--Percentage of Softening Plants Meeting Current Proposed

Requirements

------------------------------------------------------------------------

Proposed

1994 Percentage

Raw TOC (mg/L) required of plants

percent that met

removals requirements

------------------------------------------------------------------------

>2-4........................................... 20 60

>4-8........................................... 25 80

>8............................................. 30 66

------------------------------------------------------------------------

To address the second question regarding Step 2 criteria, the

survey results for percent removal TOC and lime dose were plotted to

examine the relationship between them (see Figure III-23) and to

determine whether a point of diminishing returns can be identified for

lime addition. Figure III-23 indicates that no correlation can be

discerned, the data are highly variable, and no point of diminishing

returns corresponding to a specific lime dose addition can be

identified. The wide variation in water quality (e.g., pH, alkalinity,

type of TOC), as well as the differences in coagulant usage, probably

contributed to data variability.

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Another important issue for softening systems is the pH level used

in the softening process. As the lime dose is increased, the pH of the

softening process increases and the character of the precipitate

changes; as the pH rises above 10, the major precipitate formed changes

from calcium carbonate to magnesium hydroxide. The TOC percent removal

in the survey data was plotted versus the pH of softening and is shown

in Figure III-24 . The data show that at higher softening pH levels,

generally greater percentages of TOC are removed. Also as the lime dose

is increased alkalinity is consumed and if the lime dose is high enough

to deplete the raw water alkalinity, soda ash must be added to maintain

the precipitation process. Crossing either one of these thresholds

(either changing the dominant precipitate from calcium carbonate to

magnesium hydroxide or changing from a lime softening system to a lime/

soda softening system) constitutes a major change in the treatment

process. Magnesium hydroxide floc do not act the same as calcium

carbonate floc either in settling or in sludge treatment and the plant

design for the two precipitates would be significantly different.

Forcing a plant to increase pH to the point of having to add soda ash

would also be a significant treatment change due to pH adjustment

problems and because the precipitate would likely be changing at the

same time. Most softening plants are normally operated without soda ash

addition because of the high cost of soda ash, the additional sludge

production, the increased chemical addition to stabilize the water and

the increased sodium levels in the finished water (Randtke et al., 1994

and Shorney et al., 1996).

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Raising the pH by adding lime can have other impacts such as

depleting alkalinity and potentially causing corrosion problems. To

determine what finished water alkalinity most softening plants produce,

the survey data was plotted for finished water alkalinity and TOC

percent removal (see Figure III-25 (Clark et al., 1997)). With only a

few outliers and regardless of the percent TOC removal, most plants

produce finished water with alkalinity between 30 and 60 mg/L as

CaCO3.

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The survey obtained basic information on disinfection practices in

softening plants. Forty percent of the plants responding predisinfect.

Softening plants predisinfect for the same reasons that conventional

coagulation plants do, that is, to comply with Surface Water Treatment

Rule Disinfection requirements, to oxidize iron and manganese, to

control zebra mussels and Asiatic clams, and to control taste and odor

problems. Disinfectants in use in softening plants are as follows:

28% of plants use free chlorine for both primary and

secondary disinfection.

50% of plants use free chlorine/chloramine.

10% of plants use chloramine.

7% of plants use chlorine dioxide/chloramine.

5% of plants use ozone/chloramine.

In spite of the fact that some 78% of softening plants are using

free chlorine for at least a portion of their disinfection, the

reported yearly average THMs indicate that 90 percent of plants are

currently meeting an 80 g/L level for THMs (see Figure III-26

(Clark et al., 1997)). All reporting softening plants have average HAA5

levels below 60

g/L (see Figure III-27 (Clark et al., 1997)). For the majority

of softening plants, minor adjustments to disinfection practices may

bring them into compliance with the proposed total THM and HAA5 MCLs,

as long as predisinfection credit is allowed. Without predisinfection

credit, these plants could face the major impact of having to provide

disinfection time after sedimentation, and for at least one of the

reporting utilities, that could mean significantly increasing the free

chlorine contact time to get the maximum CT credit by making up for a

shortened detention time. The end result for that system will likely be

an increase in finished water total THMs over what are being produced

using predisinfection credit. However, these site-specific issues will

need to be addressed individually, as removing the precursors by

enhanced softening will also remove some of the chlorine demand

resulting in less disinfectant addition to obtain the necessary

residual.

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C. Summary of Key Enhanced Coagulation and Enhanced Softening

Observations

Based on the data and analysis outlined above, the M/DBP Advisory

Committee has recommended the following revisions to the proposed

enhanced coagulation and softening requirements to address the

outstanding issues on the use of this technology to control DBP

precursors (see Table III-13). The top row has been modified from the

proposal by lowering the values by 5%. Enhanced softening systems are

required to comply with the column for alkalinity > 120 mg/L as

CaCO3.

Table III-13.--1997 Proposed Required Removal of TOC by Enhanced Coagulation/Enhanced Softening for Surface-

Water Systems Using Conventional Treatment

----------------------------------------------------------------------------------------------------------------

Source water alkalinity, mg/L as CaCO3

-----------------------------------------------

Source water TOC, mg/L 0-60a >60-120 a >120 a b

(percent) (percent) (percent)

----------------------------------------------------------------------------------------------------------------

>2.0-4.0........................................................ 35.0 25.0 15.0

>4.0-8.0........................................................ 45.0 35.0 25.0

>8.0............................................................ 50.0 40.0 30.0

----------------------------------------------------------------------------------------------------------------

a Not applicable to waters with raw-water SUVA 2.0 L/mg-m.

b Systems practicing precipitative softening must meet the TOC removal requirements in this column.

For waters with TOC >4.0 mg/L (6 of the 9 boxes in the 3 x 3

matrix), the TWG felt that 90 percent of these waters can meet the 1994

proposed step 1 TOC removal requirements. For waters with TOC >2.0-4.0

mg/L, the Committee recommended that the TOC removal requirements be

35, 25, and 15 percent for low-, moderate-, and high-alkalinity waters,

respectively. For low-TOC waters with raw-water SUVA >2 L/mg-m, the TWG

felt that 90 percent of the systems treating such waters will be able

to comply with the revised step 1 TOC removal levels.

The Committee recommended that waters with raw-water SUVA

2.0 L/mg-m be given an exemption to enhanced coagulation and

enhanced softening. SUVA is an indicator of the humic content of a

water. Coagulation removes humic matter, so waters with low-SUVA values

contain primarily nonhumic matter, which is not amenable to enhanced

coagulation. The use of a raw water SUVA 2.0 L/mg-m. At this point, the

residual TOC is mainly composed of nonhumic matter that is not amenable

to enhanced coagulation; therefore, it is not productive to add

additional coagulant. Because oxidants can destroy UV, but not TOC,

SUVA must be determined on water that has not been exposed to oxidants.

Thus, using a settled-water SUVA 2.0 L/mg-m as a PODR should

be done on jar-tested water (as the slope criterion is done) unless the

full-scale plant is not using preoxidation/predisinfection. The TWG

believes that these revised requirements will result in a limited

amount of transactional costs for the PWSs and their primacy agencies.

The Committee recommended this option to EPA.

Enhanced softening systems that cannot meet the removal percentages

specified in the TOC removal matrix must demonstrate that they have met

alternative performance criteria, e.g., depressed the alkalinity to a

minimum level or lowered settled water SUVA 2.0 L/mg-m.

Also, systems that remove a minimum of 10 mg/L of magnesium hardness

(as CaCO3) from their raw water are exempt for enhanced

softening requirements. Lime softening plants would not be required to

perform lime-soda ash softening, and no softening plant will be

required to lower treated effluent alkalinity below 40 mg/L (as

CaCO3), as part of any Step 2 procedure.

Because the determination of SUVA requires measurement of DOC, the

TWG believed that guidance on this determination is necessary. DOC is

determined on filtered samples, but it is important that the filter

paper does not leach DOC. Protocols and quality assurance measures to

ensure that SUVA is properly measured are discussed in the analytical

methods section.

Another exception to enhanced coagulation in the proposed 1994 rule

was for systems that treated water with 60 mg/L

alkalinity that achieved TTHMs 2/chloramine addition in order to lead to reduction of

DBPs. Four investigators tested the validity of this assumption.

Summers (Summers et al., 1997) summarized the findings of the four

investigators concerning the impact of moving the point of chlorination

during coagulation, flocculation and sedimentation on DBP formation for

a representative range of waters and treatment conditions. In addition,

studies were carried out at the University of Cincinnati under the

sponsorship of EPA, the American Water Works Association (Water Utility

Council-Water Industry Technical Action Fund) and the Chlorine

Chemistry Council (Solarik et al., 1997). The results of these studies

are summarized here.

Sixteen source waters have been evaluated to date. The waters were

selected to proportionately represent the national source water

distribution in the enhanced coagulation 3 x 3 (TOC--alkalinity) matrix

as estimated from AWWA water industry database (WIDB). Waters were

chosen to represent the >2.0-4.0 mg/L and >4.0-8.0 mg/L TOC ranges. For

TOC >8.0 mg/L, prechlorination would generally not be a suitable

option, as experience and computer modeling have shown that

prechlorination of these waters under the conditions of this study is

likely to yield TTHM and HAA5 values that exceed the 0.080 mg/L and

0.060 mg/L proposed MCLs, respectively. WIDB TOC data indicate that

less than 10 percent of the surface waters have TOC concentrations

greater than 8.0 mg/L.

The study was conducted using a bench-scale batch jar testing

procedure with chlorine added at different times to simulate full-scale

continuous flow conditions with chlorine added at different points.

Alum

(Al2(SO4)318H2O)

was used as the coagulant for all waters and two alum doses were

examined for 14 of the 16 waters evaluated. The baseline dose was set

at the level required for turbidity control, while a second increased

dose was set at the level necessary to meet the required percent TOC

removal in the 3 X 3 enhanced coagulation matrix. In three cases, the

required TOC removal was achieved by baseline coagulation. The jar

tests were carried out at ambient laboratory temperature, (22 deg.C).

Chlorine was added to four parallel jars at four different times

during the coagulation, flocculation and sedimentation process for both

the baseline coagulant dose and the increased coagulant dose: 1) 3

minutes before rapid mixing (Pre-RM), (2) at the end of rapid mixing

(Post-RM), (3) in the middle of flocculation (Mid-Floc), and (4) at the

end of sedimentation (Post-Sed). Additionally, the raw uncoagulated

water was adjusted to the settled water pH and chlorinated. The DBP

results from the raw uncoagulated water served as a basis for

comparison. The chlorine doses were chosen to yield a free chlorine

residual of 0.6 0.4 mg/L after 3 hours of total contact

time at ambient pH (6.1-8.1) and laboratory temperature (22 deg.C). The

3 hour reaction time is representative of that of a typical

coagulation, flocculation and sedimentation process train. At the end

of the 3 hour incubation time, the reaction was quenched and DBPs were

assessed. Settled water was also chlorinated under uniform formation

conditions (UFC) (Summers et al., 1996) to represent distribution

system DBP formation. A more detailed experimental approach is

presented elsewhere (Solarik et al., 1997, Summers et al., 1997).

Impact of Point of Chlorination

The impact of moving the point of chlorination downstream for both

baseline and increased dose coagulation is shown in Figures IV.1, IV.2,

and IV.3 for TOX, TTHM, and HAA5 concentrations, respectively. The

distribution of data is shown as box and whisker plots indicating the

mean and median, the 10th, 25th, 75th, and 90th percentiles, and any

data that lies outside the 10th and 90th percentiles. Moving the point

of chlorination further downstream decreased the concentration of DBPs

formed after three hours of contact time with free chlorine. The DBP

concentrations shown in these three figures are not intended to

represent occurrence levels of DBPs in the distribution system, only

those which were formed under the conditions of this study. Figures

IV.4, IV.5, and IV.6 show the percent decrease in DBP formation

relative to that formed in the raw uncoagulated water.

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The decrease in DBP formation was calculated by subtracting the DBP

concentration formed upon chlorination at a given point in the jar test

from that formed upon chlorination of the raw waters. Chlorinating 3

minutes prior to rapid mixing (Pre-RM) led to a median 32, 26 and 17

percent decrease in TOX, TTHM, and HAA5 concentrations, respectively,

relative to those formed upon chlorination of the raw uncoagulated

water. Prechlorinating more than 3 minutes prior to rapid mixing was

shown to increase the DBP formation relative to Pre-RM.

For TOX, TTHM, and HAA5, moving the point of chlorination

downstream in the coagulation, flocculation, and sedimentation process

decreased DBP formation and the chlorine demand by providing additional

time for NOM removal before chlorine could react with the NOM to form

DBPs. While having only a small impact on average for TOX, TTHM, and

HAA5 formation, moving the point of chlorination from Pre-RM to Post-RM

was very beneficial for some waters. As expected, the largest benefit

for all parameters investigated was observed by moving the point of

chlorination to after sedimentation, which resulted in the lowest DBP

formation. On average, the benefit of moving the point of chlorination

downstream was greater for HAA5 than for TOX and TTHM.

The median, 10th and 90th percentile (shown in brackets) decrease

in TOX formation as a result of moving the point of chlorination from

Pre-RM to (1) post-RM was -5.4 percent (-17 and 16 percent); (2) mid-

Floc was 6.1 percent (-6.8 and 19 percent); and (3) post-Sed was 17

percent (4.5 and 34 percent).

The median, 10th and 90th percentile (shown in brackets) decrease

in TTHM formation as a result of moving the point of chlorination from

Pre-RM to (1) post-RM was 1.9 percent (-5.9 and 18 percent); (2) mid-

Floc was 13 percent (0.4 and 28 percent); and (3) post-Sed was 25

percent (6.5 and 43 percent).

The median, 10th and 90th percentile (shown in brackets) decrease

in HAA5 formation as a result of moving the point of chlorination from

Pre-RM to (1) post-RM was 5.3 percent (-11 and 23 percent); (2) mid-

Floc was 19 percent (-5.7 and 53 percent); and (3) post-Sed was 40

percent (26 and 67 percent).

The impact of percent TOC removal and point of chlorination on TOX,

TTHM, and HAA5 formation are shown in Figures IV.7, IV.8, and IV.9,

respectively. Increased TOC removal resulted in decreased DBP

formation. In general, moving the point of chlorination from raw water

to Mid-Floc and Post-Sed resulted in a percent decrease in DBP

formation that was equivalent to or greater than the percent TOC

removal achieved. Thus, in this study, precursor removal was a more

effective DBP control strategy when used in conjunction with delaying

the point of chlorination until Mid-Floc or later.

Impact of Alum Dose

Coagulation conditions of the waters at baseline conditions were

determined based on turbidity control. The median alum dose used for

baseline coagulation conditions was 30 mg/L (10th and 90th percentile

were 15 and 48 mg/L, respectively). Under these conditions, the median

TOC removal was 24 percent (10th and 90th percentiles were 6.5 and 38

percent, respectively). For this study, the alum dose was increased

from the baseline case by a median value of 22 mg/L (the 10th and 90th

percentiles were 15 and 35 mg/L, respectively). Increasing the alum

dose resulted in a median increase in TOC removal to 33 percent (10th

and 90th percentile were 18 and 48 percent, respectively). Thus, at the

higher alum doses, DBP formation was decreased. For nine of the waters

studied, increasing the alum dose from baseline coagulation conditions

resulted in TOC removal equivalent to or greater than those required by

the 3 x 3 enhanced coagulation matrix. This yielded a median increase

in the percent TOC removal of 14 percent. Table IV.1 summarizes the

median benefit associated with moving the point of chlorination

downstream under baseline coagulation and with increasing the alum dose

to achieve enhanced coagulation on DBP formation. DBP formation

resulting from chlorine addition at Pre-RM under baseline coagulation

conditions was used as a point of reference. The data in the table

indicates that even when prechlorination is practiced, TOX, TTHM, and

HAA5 formation can be reduced by moving from conventional to enhanced

coagulation. For TOX and TTHM, the benefits of moving to enhanced

coagulation are greatest when Post-Sed chlorination is used.

Furthermore, the benefits are greater for the control of HAA5 formation

than for the control of TOX and TTHM formation.

Table IV.1.--Impact of Point of Chlorination and Enhanced Coagulation on DBP Formation Using Pre-RM DBP

Formation Under Baseline Coagulation Conditions as Basis for Comparison

----------------------------------------------------------------------------------------------------------------

Median benefit (%)

-----------------------------------------------------------------------------

TOX (n=7) TTHM (n=9) HAA5 (n=6)

-----------------------------------------------------------------------------

Baseline Enhanced Baseline Enhanced Baseline Enhanced

coagulation coagulation coagulation coagulation coagulation coagulation

----------------------------------------------------------------------------------------------------------------

Pre-RM............................ ........... 11 ........... 17 ........... 4.7

Post-RM........................... 0.3 10 1.6 21 5.3 21

Mid-Floc.......................... 3.9 23 8.7 36 14 36

Post-Sed.......................... 11 40 21 48 35 61

----------------------------------------------------------------------------------------------------------------

3-Hour DBP Formation Relative to Distribution System DBP Formation

Chlorination with a 3-hour holding time before quenching the

reaction resulted in a significant formation of DBPs. The 3-hour period

was chosen as it is typical of reaction times in conventional treatment

plants. To get a general sense of short-term DBP formation kinetics,

DBP formation for chlorinated settled water held for 3 hours was

compared to DBP formation of settled water chlorinated under UFC (24

hour holding time). The data indicate that 3-hour chlorination resulted

in a high percentage of DBP formation that would normally be measured

in the distribution system. The median DBP concentrations formed in 3

hours were 61, 44, and 46 percent of distribution system formation for

TOX, TTHM, and HAA5, respectively. This can be thought of as in-plant

DBP formation relative to distribution system formation for systems

with 3-hour post sedimentation contact.

[[Page 59462]]

Summary

The results of this study indicate that enhancing the coagulation

process, while maintaining prechlorination, can result in decreased DBP

formation (especially for TOX and TTHM) with greater benefits being

realized by moving the point of chlorination to post rapid mixing or

further downstream for HAA5 and to mid flocculation or post

sedimentation for TOX and TTHM. Compared to prechlorinating three

minutes before rapid mixing, the greatest DBP reduction was realized by

moving the point of chlorination to post-sedimentation, with a median

decrease of 17, 25, and 40 percent in TOX, TTHM, and HAA5 formation,

respectively. However, operational and regulatory constraints may limit

the extent to which the point of chlorination can be moved downstream

in the process train, since one requirement in the IESWTR may be a

disinfection benchmark; which would require some plants making

significant changes in disinfection practice (including moving the

point of disinfection) to design the change to maintain their level of

Giardia inactivation at or above a site-specific level. This may limit

the degree to which some plants can delay the point of chlorination

without seeking State approval and potentially modifying their

treatment train to make up lost Giardia inactivation later in the

plant.

C. Summary of Key Observations

TWG analyses indicated that most PWSs, using enhanced coagulation

or enhanced softening as required, would be able to meet MCLs of 0.080

mg/L and 0.060 mg/L for TTHM and HAA5, respectively, while maintaining

existing disinfection practice. This analysis also indicated that

significant precursor removal and DBP reduction can still be achieved

with predisinfection left in place. Although in most cases the

reduction in DBP formation is not as great as would be accomplished in

moving the point of disinfection to after enhanced coagulation, the

Advisory Committee recommended balancing the need to maximize precursor

removal against the need to substantially maintain existing levels of

microbial protection that is provided by many plants through

predisinfection. However, as noted above, another key implication of

Summers' work is that some PWSs that only add disinfectant just prior

to coagulant addition (e.g., rapid mix), could achieve significant

additional DBP reduction without sacrificing meaningful disinfection

credit by moving the point of disinfectant addition from just before to

just after the point of coagulant addition.

The Advisory Committee recommended that PWSs continue to receive

credit for compliance with applicable disinfection requirements for

disinfectants applied at any point prior to the first customer

consistent with the existing provisions of the 1989 Surface Water

Treatment Rule.

EPA will develop guidance on the uses and costs of oxidants that

control water quality problems (e.g., Asiatic clams, zebra mussels,

iron, manganese, algae, taste and odor) and whose use will reduce or

eliminate the formation of DBPs of public health concern.

D. Request for Public Comments

EPA requests comment on continued disinfection credit for all

disinfectant use prior to the first customer.

V. Analytical Methods

EPA is requesting comment on the addition, and in one case the

deletion, of analytical methods for the disinfectants and DBPs listed

below. These potential changes are based on information received during

the public comment period or on new information that has become

available since the July 1994 proposed rule.

A. Chlorine Dioxide

The proposed DBP rule included the same three methods for analyzing

chlorine dioxide (ClO2) that are approved under the SWTR and

ICR regulations. Two of these methods, Standard Methods

4500.ClO2 C (APHA 1992) and 4500.ClO2 E (APHA

1992), are amperometric methods. The third method proposed was Standard

Method 4500.ClO2 D (APHA 1992), a colorimetric method using

the color indicator N,N-diethyl-p-phenylenediamine (DPD).

EPA received several comments stating that these methods to

calculate ClO2 concentration are intrinsically inaccurate

because free chlorine, chloramines and chlorite are subtracted from the

measurement, causing a propagation of errors. However, they stated that

the DPD method is sufficiently accurate for monitoring ClO2

residuals in drinking water and is relatively easy to perform.

Method 4500.ClO2 C was cited as an outdated, inaccurate

and time consuming method, subject to interferences from oxidants

commonly found in drinking water (Dietrich, 1992). Significant,

positive interferences have been described by Gates (1988), and

attributed to mono-and dichloramines by Haller and Listek (1948).

Method 4500.ClO2 E is a better method because it utilizes

differences in the physical properties of ClO2, as opposed

to chemical detection of anionic oxychlorocompounds (Aieta et al.,

1984). Therefore, EPA requests comments on omitting Method

4500.ClO2 C from the list of approved methods for the

analysis of chlorine dioxide for compliance with the MRDL for chlorine

dioxide. Comments on omitting it from 40 CFR 141.74 (SWTR analytical

methods) are also requested.

B. Haloacetic Acids

In 1994, EPA proposed two methods for the analysis of five

haloacetic acids--Method 552.1 (USEPA, 1992b) and Standard Method 6233B

(APHA 1992). Both methods use capillary column gas chromatographs

equipped with electron capture detectors. The two methods differ in the

sample preparation steps. Method 552.1 uses solid phase extraction

disks followed by an acidic methanol derivitization. Method 6233B is a

small volume liquid-liquid (micro) extraction with methyl-t-butyl

ether, followed by a diazomethane derivitization. Standard Method 6233B

was revised (and renumbered 6251B (APHA 1995)) to include

bromochloroacetic acid, for which a standard was not commercially

available in 1994. Recognizing these improvements, EPA approved Method

6251B for analysis under the 1996 Information Collection Rule (40 CFR

Part 141 or USEPA, 1996b). Several commenters requested that the

revised and renumbered method, Method 6251B, also be approved for the

analysis of haloacetic acids under the Stage 1 DBP regulations.

In 1995 EPA published a third method for HAAs, Method 552.2 (EPA

1995), and subsequently approved it for HAA analysis under the 1996

Information Collection Rule (40 CFR Part 141 or USEPA, 1996b). Method

552.2 is an improved method, combining the micro extraction procedure

of Standard Method 6233B with the acidic methanol derivitization

procedure of Method 552.1. It is capable of analyzing nine HAAs. EPA

received comments requesting approval of Method 552.2 for HAA5 analyses

required under this section.

EPA requests comment on the technical adequacy of using Methods

552.2 and 6251B (formerly 6233B) for analyzing haloacetic acids. Method

552.1 would continue to be approved for the analysis of haloacetic

acids.

C. Total Trihalomethanes (TTHMs)

Three methods are approved for the analysis of total

trihalomethanes

[[Page 59463]]

(TTHMs) under 40 CFR 141.24(e). These same methods were proposed under

the 1994 Stage I DBP proposal. One of the three methods, EPA Method

551, was revised to Method 551.1, rev. 1.0 (EPA 1995). Method 551.1 is

approved for ICR monitoring under 40 CFR 141.142.

Method 551.1 has several improvements upon Method 551. The use of

sodium sulfate is strongly recommended over sodium chloride for the

MTBE extraction of DBPs. This change was in response to a report

indicating elevated recoveries of some brominated DBPs due bromide

impurities in the sodium chloride (Xie, 1995). EPA's NERL laboratories

confirmed this finding in samples that were not extracted immediately

after the sodium chloride was added.

Other changes to Method 551.1 include a buffer addition to

stabilize chloral hydrate, elimination of the preservative ascorbic

acid, and modification of the extraction procedure to minimize the loss

of volatile analytes. The revised method requires the use of surrogate

and other quality control standards to improve the precision and

accuracy of the method.

D. Bromate

The proposed rule required systems that use ozone to monitor for

bromate ion. EPA proposed Method 300.0 (Determination of Inorganic

Anions by Ion Chromatography)(USEPA, 1993a) for the analysis of bromate

and chlorite ions. Method 300.0 is used in many laboratories because it

can analyze bromide, chloride, fluoride, nitrate, nitrite,

orthophosphate, sulfate, bromate, chlorite and chlorate ions. The cost

of bromate ion analysis was estimated to range from $50 to $100 per

sample.

At the time of the proposal, EPA was aware that Method 300.0 was

not sensitive enough to measure bromate ion concentration at the

proposed MCL of 0.010 mg/L (10 g/L). EPA recognized that

modifications to the method would be necessary to increase the method

sensitivity. Studies at that time indicated that changes to the

injection volume and the eluent chemistry would decrease the detection

limit below the MCL. There was also an issue concerning whether bromate

formation could be reliably controlled to levels below 10 g/L

when ozone is used as part of the treatment process. Most commenters

agreed that Method 300.0 was not sensitive enough to determine

compliance with a MCL of 10 g/L bromate ion, given that MCLs

are set no less than 5 times the MDLs. One commenter did achieve a MDL

for bromate ion in the 1-2 g /L range under research

laboratory conditions.

Since the proposal, EPA has improved Method 300.0 and renumbered it

as Method 300.1. EPA intends to approve this method for use in the

final rule; it is available for review in the Docket. Method 300.1

specifies a new, high capacity ion chromatography (IC) column that is

used for the analysis of all anions listed in method instead of

requiring two different columns as specified in Method 300.0. The new

column has a higher ion exchange capacity that improves chromatographic

resolution and minimizes the potential for chromatographic

interferences from common anions at concentrations typically 10,000

times greater than bromate ion. For example, quantification of 5.0

g/L bromate is feasible in a matrix containing 50 mg/L

chloride. Minimizing the interferences permits the introduction of a

larger sample volume to yield a method detection limit of 2 g/

L. Sample analysis time is approximately 30 minutes per sample.

An IC column's capacity is directly proportional to its operating

back pressure at a given flow rate and the older IC systems may not be

able to tolerate the higher back pressures required when using these

new IC columns. Consequently, in order to perform this analysis, some

laboratories with IC systems over 15 years old may need to upgrade

their instrumentation to current technology. Newer instruments can

easily be operated under these conditions.

As in Method 300.0, Part A of the revised method contains

procedures for measuring the common anions of bromide, nitrate,

nitrite, fluoride, chloride, sulfate and phosphate. Part B contains

procedures for measuring the disinfection byproduct anions of bromate,

chlorite and chlorate. Bromide ion is also included in Part B to

determine its potential presence as a disinfection byproduct precursor.

The anions are split into two distinct parts due to the disparity

in the relative concentrations expected in drinking water. Method 300.1

analyzes mg/L levels of the Part A common anions and g/L

levels of the Part B inorganic disinfection byproducts and bromide ion.

To accommodate this, the recommended sample volume injected for Part A

is 10 L and for Part B is 50 L, when using a 2 mm

diameter column. The lower injected sample volume for Part A is

required to compensate for their higher (mg/L) concentrations. If this

injected volume is not reduced, poor analyte response characteristics

are observed and the integrity of the data is compromised. The higher

injected sample volume for Part B is required to yield low detection

limits for the inorganic disinfection byproducts, specifically bromate.

Analysis for Part A and Part B cannot be concurrent without sacrificing

analytical integrity and therefore a separate 30 minute analysis must

be done for each concentration range.

To preserve samples for chlorite, chlorate, and bromate analyses,

the method requires the addition of ethylenediamine (EDA) at a final

sample concentration of 50 mg/L. EDA is primarily used as a

preservative for chlorite. Chlorite is susceptible to degradation both

through catalytic reactions with dissolved iron salts and reactivity

towards free chlorine which exists as hypochlorous acid/hypochlorite

ion in most drinking water as a residual disinfectant. EDA serves a

dual purpose as a preservative for chlorite by chelating iron as well

as any other catalytically destructive metal cations and removing

hypochlorous acid/hypochlorite ion by forming an organochloramine. EDA

also preserves the integrity of bromate concentrations by binding with

hypobromous acid/hypobromite which is an intermediate formed as a

byproduct of the reaction of ozone or free chlorine with bromide ion.

If hypobromous acid/hypobromite is not removed from the matrix, further

reactions may form bromate ion.

Method 300.1 was validated for the inorganic DBPs and bromide by

conducting nine replicate analyses at two different fortified levels of

seven water matrices including reagent water, simulated high ionic

strength water, untreated surface water, untreated ground water,

chlorinated drinking water, chlorine dioxide treated drinking water,

and ozonated drinking water. Holding time studies have been

incorporated into these validation studies with aliquots of each

fortified matrix currently being stored as unpreserved and EDA

preserved at 4 deg.C. These stored sample matrices will be monitored

out to 30 days to determine appropriate holding times. MDL

determinations have been completed in both reagent water and high ionic

strength water. Results of these validation studies are included in the

method.

With Method 300.1, EPA projects that more laboratories will achieve

lower detection limits for bromate and report data having better

precision and accuracy. Compliance monitoring for low levels of bromate

ion will require an appropriate certification process to ensure that

the measurements are accurate. Although there may be a

[[Page 59464]]

limited number of laboratories that will be qualified to do such

analyses, there should be adequate laboratory capacity for bromate ion

compliance monitoring. EPA estimates that 250 treatment plants

utilizing ozone will be monitored for bromate once per month, for a

total of 3,000 samples per year.

E. Chlorite

The proposed rule required monitoring for the chlorite ion for

those systems using chlorine dioxide for disinfection. The proposed

rule included Method 300.0 (ion chromatography) for chlorite analysis.

Other methods using amperometric and potentiometric techniques were

considered, but EPA decided that only the ion chromatography method

(300.0) would produce results with the precision needed for compliance

determinations. Several commenters suggested that EPA permit other

methods for chlorite.

Since the proposed rule, Method 300.1, which uses ion

chromatography, was developed for bromate ion (as discussed above).

Since Method 300.1 can also be used to analyze for chlorite ion, EPA

requests comment on allowing both Methods 300.0 and 300.1 as approved

methods for the analysis of chlorite ion.

F. Total Organic Carbon (TOC)

The proposed rule included two methods for analyzing TOC: Standard

Method 5310 C and 5310 D (APHA 1992). These methods were selected

because they cite a detection limit 0.5 mg/L and a precision

of 0.1 mg/L TOC. Standard Method 5310 B (18th edition) was

considered, but not proposed because the method had a detection limit

of 1 mg/L. The proposal stated that if planned improvements to the

instrumentation in 5310 B were successful, the next version would be

considered for promulgation.

Improvements were made to method 5310B and were included in a

revised method in the 19th edition of Standard Methods (APHA 1995).

Based on these improvements, method 5310B (19th edition) was approved

for TOC analyses under the Information Collection Rule. Several

commenters requested that Standard Methods 5310B also be approved for

TOC analysis under this rule because the newer instrumentation achieves

a detection limit of 0.5 mg/L TOC.

Since the ICR was promulgated, another revision of 5310 B was

published in the supplement to the Standard Methods 19th Edition (APHA

1996). EPA intends to approve this method for the analysis of TOC. EPA

requests comments on the technical equivalency of Methods 5310 B, C,

and D in the Supplement to Standard Methods 19th Edition and those same

methods in the 19th Edition.

G. Specific Ultraviolet Absorbance (SUVA)

Specific Ultraviolet Absorbance at 254 nm (SUVA) is an indicator of

the humic content of a water. Waters with low SUVA values contain

primarily non-humic matter and are not amenable to enhanced

coagulation. As discussed in section III, systems may demonstrate that

enhanced coagulation or enhanced softening is unnecessary if the raw

water after being filtered through a 0.45 m filter has a SUVA

below 2 L/mg-m.

SUVA is a calculated parameter obtained by dividing a sample's

ultraviolet light absorbance at a wavelength of 254 nm

(UV254), by the dissolved organic carbon (DOC), and

multiplying by 100:

SUVA = 100 (cm/m) [ UV254 (cm-1)/DOC (mg/L)]

Two separate analytical methods are necessary to make this

measurement: 1) UV254 and 2) DOC.

1. UV254. EPA approved Standard Methods 5910 (APHA 1995)

for measuring UV254 under the Information Collection Rule

and intends to approve its use under the disinfection byproducts rule.

EPA requests comments on this and other methods for measuring

UV254.

2. DOC. Standard Methods (19th Edition-Supplement)(APHA 1996)

defines DOC as the fraction of TOC that passes through a 0.45

m-pore-diameter filter. DOC is measured by performing an

analysis for TOC on the sample filtrate. Filtration eliminates

particulate organic matter but may contaminate the sample if carbon-

containing compounds leach from the filter. Standard Methods 5310 B,

5310 C and 5310 D require that filters be rinsed before use and checked

for their contribution to DOC by analyzing a filtered blank. Contact

with organic material such as plastic containers, rubber tubing, etc.

must be kept to a minimum to prevent contamination. EPA requests

comments on the approval of Standard Methods 5310 B, 5310 C and 5310 D

for measuring DOC for the SUVA calculation.

EPA is aware of several issues relating to the measurement of SUVA

that are not addressed in the methods above. In determining SUVA, DOC

and UV254 are both to be measured from the same sample

filtrate, which is prepared by filtering a raw water sample through a

pre-washed 0.45 m filter paper. Standard Methods 5910 (UV)

recommends to wash the filter with 50 mL of organic-free water to avoid

contamination, however, more rinsate may be necessary to eliminate the

DOC.

Because disinfectants/oxidants (chlorine, ozone, chlorine dioxide,

potassium permanganate) can destroy UV but not DOC, SUVA needs to be

determined on water prior to the application of disinfectants/oxidants.

In the raw water, this is usually not a problem. If disinfectants/

oxidants are applied in raw-water transmission lines upstream of the

plant, then raw-water SUVA should be based on a sample collected

upstream of the point of disinfectant/oxidant addition.

For determining settled-water SUVA, if the plant applies

disinfectants/oxidants prior to the settled water sample tap, then

settled-water SUVA should be determined in jar testing. Finally, the

use of iron-base coagulants can interfere with UV measurements, as

dissolved iron can penetrate the filter paper.

To address these issues in more detail, EPA intends to provide

guidance on SUVA measurements in the Guidance Manual for Enhanced

Coagulation (USEPA, 1997d). The manual will include guidance on

sampling, sample preparation, filter type, pH, interferences to UV,

high turbidity waters, quality control, etc. EPA requests comment on

other issues that should be addressed in the guidance, as well as any

recommendations on how the above issues should be addressed.

H. Summary of Key Observations

Since the 1994 proposal, improvements have been made to the

analytical methods for trihalomethanes, haloacetic acids, total organic

carbon, bromate ion and chlorite ion. EPA received comments to include

Method 552.2 and 6251B for HAAs, and Method 5310B for TOC. Commenters

made a general suggestion to approve methods promulgated under the ICR

rule in the Stage 1 DBP rule. EPA intends to approve these methods and

if appropriate, promulgate their most recent versions. EPA also intends

to approve Method 300.1, the revised method for bromate ion, and permit

its use for chlorite ion.

I. Request for Public Comments

1. EPA requests additional comments on omitting Method

4500.ClO2 C from the list of approved methods for the

analysis of chlorine dioxide.

2. EPA requests additional comments on the approval of EPA Method

552.2

[[Page 59465]]

and Standard Method 6251B for analyzing haloacetic acids.

3. EPA requests comment on replacing Method 300.0 with Method 300.1

for the analysis of bromate ion.

4. EPA requests comment on allowing both Method 300.0 and 300.1 as

approved methods for the analysis of chlorite ion.

5. EPA requests comments on the technical equivalency of Methods

5310 B, C and D in the Supplement to Standard Methods, 19th edition and

those same methods in the 19th edition of Standard Methods for

measuring TOC and DOC.

6. EPA requests comments on the methods and filtration procedures

for measuring SUVA.

VI. MCLs for TTHM, HAAs, Chlorite and Bromate

A. 1994 Proposal

The 1994 proposal for Stage 1 of the DBPR included MCLs for total

trihalomethanes (TTHMs), the sum of five haloacetic acids (HAA5),

bromate and chlorite at 0.080, 0.060, 0.010 and 1.0 mg/L, respectively

(EPA, 1994b). In addition to the proposed MCLs, Subpart H systems--

utilities treating either surface water or groundwater under the direct

influence of surface water--that use conventional treatment (i.e.,

coagulation, sedimentation, and filtration) or precipitative softening

would be required to remove DBP precursors by enhanced coagulation or

enhanced softening. The removal of total organic carbon (TOC) would be

used as a performance indicator for DBP precursor control.

As part of the proposed rule, EPA estimated that 17% of PWSs would

need to change their treatment process to alternative disinfectants

(ozone or chlorine dioxide) or advanced precursor removal (GAC or

membranes) in order to comply with the Stage 1 requirements. This

evaluation was important to assist in determining whether the proposed

MCLs were achievable and at what cost. This evaluation required an

understanding of the baseline occurrence for the DBPs and TOC being

considered in the Stage 1 DBPR, an understanding of the baseline

treatment in-place, and an estimation of what treatment technologies

systems would use to comply with the Stage 1 DBPR requirements.

For systems switching to ozone or chlorine dioxide, separate MCLs

were proposed for inorganic DBPs associated with their usage: bromate

and chlorite, respectively. Although the theoretical 10-4

risk level for bromate is 5 g/L, an MCL of 0.010 mg/L (10

g/L) was proposed (because available analytical detection

methods for bromate were reliable only to the projected practical

quantification limit (PQL) of 10 g/L (USEPA, 1994b). For

chlorite, the MCL goal (MCLG) was 0.08 mg/L, due (in part) to data gaps

that required higher uncertainty factors in the MCLG determination. The

Chemical Manufacturer's Association (CMA) agreed to fund new health

effects research on chlorine dioxide and chlorite--with EPA approval of

the experimental plan--to resolve these data gaps.

In the preamble to the proposed rule, EPA requested comment on

several issues related to the MCLs and requested any new information

that may influence the MCLs. For bromate, EPA requested comment on

whether there were ways to set (or achieve) a lower MCL (i.e., 0.005

mg/L [5 g/L]) and whether the PQL for bromate could be lowered

to 5 g/L in order to allow compliance determinations for a

lower MCL in Stage 1 of the proposed rule.

For chlorite, EPA requested comment on the appropriate MCL (i.e.,

at the MCLG, at the proposed MCL, or above the MCLG but below the

proposed MCL), the feasibility of achieving a particular MCL, and

whether there were other benefits to chlorine dioxide disinfection that

should be considered when balancing the health risks associated with

chlorite.

B. New Information Since 1994 Proposal

1. TTHM and HAA5 MCLs

At the direction of the Advisory Committee, the Technologies

Working Group (TWG) reviewed MCL compliance predictions developed for

the 1994 proposal because of concern by several Committee members that

modifications to the rule would result in more PWSs not being able to

meet the TTHM and HAA MCLs without installation of higher cost

technologies such as ozone or GAC. The members were particularly

concerned that allowing disinfection inactivation credit prior to

precursor removal (by enhanced coagulation or enhanced softening) in

order to prevent significant reductions in microbial protection would

result in higher DBP formation and force systems to install alternative

disinfectants, or advanced precursor removal to meet TTHM and HAA5

MCLs. As discussed earlier in today's Notice in Section IV.

(Disinfection Credit), PWSs can achieve significant reduction in DBP

formation through the combination of enhanced coagulation (or enhanced

softening) and moving the point of disinfection downstream from

coagulant addition, while preventing significant reduction in microbial

protection. The TWG's analysis of the cumulative effect of these

changes was that there would be no significant increase in the

percentage of PWSs that would need to install higher cost technologies

to meet TTHM and HAA5 MCLs and no significant reduction in microbial

protection. The TWG estimated that 6.4% (based on WIDB data) to 15%

(bas

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