628.165 J292ex COP. 2 ECONOMIC IMPACT STUDY OF R81-11 TRIHALOMETHANE STANDARDS FOR PUBLIC WATER SUPPLIES DOCUMENT NO. 82/05 Illinois Department of Energy and Natural Resources Printed by Authority of the State of Illinois UNIVERSITY OF ILLINOIS LIBRARY AI URBANA-CHAMP, STACKS DOC. NO. 82/05 FEBRUARY, 1982 ECONOMIC IMPACT STUDY OF R81-11 TRIHALOMETHANE STANDARDS FOR PUBLIC WATER SUPPLIES by Sherry L. Jarrell Project No. 80-254 Michael B. Witte, Director State of Illinois Department on Energy and Natural Resources 309 West Washington Street Chicago, Illinois 60606 NOTE This report has been reviewed by the Department of Energy and Natural Resources and approved for publication. With the exception of the Opinion of the Department's Economic Technical Advisory Committee, views expressed are those of the contractor and do not necessarily reflect the position of the DENR. Printed by Authority of the State of Illinois Date Printed: February, 1982 Quantity Printed: 100 Illinois Department of Energy and Natural Resources 309 West Washington Street Chicago, IL 60606 (312) 793-3870 n Opinion of the Economic Technical Advisory Committee of the Illinois Department of Energy and Natural Resources The Economic Technical Advisory Committee (ETAC) has reviewed the study entitled: The Economic Impact of R81-11 Trihalomethane Standards for Public Water Supplies . The Committee finds the report to be in full compliance with Section 4 of P. A. 80-1218, and recommends that the Illinois Pollution Control Board schedule public hearings on the merits of this study, in CONTENTS 1. Introduction 1 State Regulatory Change Proposed 2 Limitations to Economic Impact Study 4 Report Organization 5 2. Summary 6 3. Background on Public Water Supplies in Illinois 11 Sources of Water in Illinois 11 Size of PWS in Illinois 11 Treatment Requirements for PWS 20 4. Trihalcmethanes—Water Quality and Health Aspects 21 Descripton of Trihalome thanes and Their Formation .... 21 Health Consequences of Trihalomethanes 21 Trihalomethane Occurrence in Illinois 34 5. Compliance Costs of THM Proposal 37 Compliance Costs of Communities Presently in Violation of Proposed Standards 45 Illinois EPA Analytical Costs of THM Proposal 51 Further Cost of Adoption of Federal Regulation 51 6. Benefits of the Total Trihalomethane Proposal 53 7. Economic Impacts of THM Proposal 54 8. Comparison of Costs and Benefits of Proposed Trihalomethane Regulation . 56 Appendix 60 Footnotes 73 IV CHAPTER I INTRODUCTION 1 In 1974, researchers in both this country 2 and the Netherlands 3 discovered that the trihalomethanes (defined on page 3 of this report) chloroform, bromodichloromethane, dibromochloromethane and bromoform, were formed during the chlorination step in drinking water treatment. Nationwide surveys showed that this reaction occurred to some extent in ewery drinking water treatment plant where free chlorine was being used for disinfection. As a result of these findings, an intensive research program was begun here and abroad to study all aspects of this emerging problem. The findings in 1976 by the National Cancer Institute that chloroform was a carcinogen to rats and mice, and the positive associations. between drinking water quality and some human cancer sites in several of 18 retrospective epidemiological studies led the U.S. Environmental Protection Agency (U.S. EPA) to suspect chloroform and other trihalomethanes (THMs) of being human carcinogens. Under the Safe Water Drinking Act provisions, this presumed health effect necessitated regulating the concentration of THM in drinking water. On November 29, 1979, the U.S. EPA promulgated an amendment to the National Interim Primary Drinking Water Regulations establishing a Maximum Contaminant Level (MCL) of 0.10 mg/£ for "Total Trihalomethanes," which is the arithmetic sum of the concentrations of chloroform, bromodichloromethane, dibromochloromethane, and bromoform. That regulation applies to community water systems that add a disinfectant in the treat- ment process and serve a population of greater than 10,000 customers. Compliance with the regulation must be accomplished within two years for communities serving greater than 75,000 customers and within four years for community systems serving between 10,000 and 75,000 customers. State Regulatory Change Proposed The Illinois Environmental Protection Agency (IEPA), pursuant to Sections 1004 (J) and 1028 of the Illinois Environmental Protection Act (111. Rev. Stat., 1979, Chapter 1113s, Pars. 1001 et seq.) has petitioned the Illinois Pollution Control Board (IPCB) to make specific changes to the Public Water Supply Regulations (Chapter 6) contained in the petition docketed R81-11. The petition seeks to adopt amendments to the National Interim Primary Drinking Water Regulations in accordance with the Safe Water Drinking Act (P.L. 93-523). The National Interim Primary Drinking Water Standards have been enforceable against public water supplies in Illinois since June 24, 1977 and adoption of this standard by the IPCB is necessary to avoid conflict in State and Federal standards and will enable the State to maintain primacy enforcement responsibility under the provisions of the above-cited acts. The proposed regulatory changes to ChapterSixof the Public Water Supply Regulation contained in regulatory proposal R81-11 seek to control the concentration of THMs in Illinois' public drinking water. The specific changes and their justification are found in the R81-11 Proposal for Rulemaking in the Appendix at the end of this study. The relevant portions are reported here: Rule 104 Definitions "Halogen" means one of the chemical elements chlorine, bromine or iodine. "Trihalomethane" (THM) means one of the family of organic compounds, named as derivatives of methane, wherein three of the four hydrogen atoms in methane are each substituted by a halogen atom in the molecular structure. "Total trihalomethanes" (TTHM) mean the sum of the concen- tration in milligrams per liter of the trihalomethane compounds trichloromethane (chloroform), dibromochloromethane, bromodi- chloromethane and tribromomethane (bromoform)), rounded to two significant figures. "Maximum Total Trihalomethane Potential (MTP)" means the maximum concentration of total trihalomethanes produced in a given water containing a disinfectant residual after 7 days at a temperature of 25°C or above. "Disinfectant" means any oxidant, including but not limited to chlorine, chlorine dioxide, chloramines, and ozone, added to water in any part of the treatment or distribution process, which is intended to kill or inactivate pathogenic microorganisms. 304 Finished Water Quality A. Bacteriological Quality 2. Total Col i form Limits a. When the membrane filter technique is used, arithmetic mean coliform density of all standard samples examined per month shall not exceed one per 100 milliliters. Any individual standard sample shall not exceed four coliform colonies per 100 milliliters in: (1) more than one standard sample when less than twenty are examined per month; or (2) more than five percent of the standard samples when twenty or more are examined per month. B. Chemical and Physical Quality Table 1 MAXIMUM ALLOWABLE CONCENTRATIONS FINISHED WATER QUALITY Total Trihalomethanes 0.10 TTig/£(e) Community water supplies serving 75,000 or more individuals shall- comply with this standard by November 5, 1981. Community water supplies serving 10,000 to 74,999 individuals shall comply with this standard by November 5, 1983. This standard does not apply to supplies serving less than 10,000 individuals. 309 Frequency of Sampling B. Chemical 1. Community Water Supplies—Surface Water Sources b. Supplies serving over 10,000 individuals shall submit at least four samples per treatment plant per quarter for analysis or analytical results from a certified laboratory for total trihalomethanes to the Agency. After results of four consecutive quarters demonstrate consistent total trihalomethane concentrations below the Maximum Allowable Concentration, and upon written application by the supply the Agency may reduce the sample frequency to one sample per quarter until the Maximum Allowable Concentration is exceeded or until a significant change in source or treatment method is made. 2. Community Water Supplies — Ground Water Sources a. A minimum of one representative sample of the finished water is to be submitted at least ewery three years to the Agency for chemical analysis. b. Supplies serving 10,000 individuals or more shall submit at least one sample per treatment plant for MTP analysis. After written request by the supply and the determination by the Agency that the results of the sample and local conditions indicate that the supply is not likely to approach or exceed the Maximum Allowable Concentration, the supply shall continue to submit one annual sample per treatment plant, or report of analysis by a certified laboratory to the Aqency. If the sample exceeds the Maximum Allowable Concentration or cannot be analyzed for MTP, the supply shall submit samples in accordance with Sec. 309 B 1 b. 3. Significant changes in water sources or treatment methods will require testing in accord with Sec. 309 Bib. Limitations to Economic Impact Study This study seeks to estimate and compare the costs and benefits of R81-11 currently before the IPCB. Quantitative results have been limited due to the lack of available data on the monitoring status of the individual Public Water Supply systems across the state. To date, 11 out of 209 water supplies serving over 10,000 have completed sampling for total trihalomethanes (TTHMs). Two of these communities were found to be out of compliance. During telephone conversations with represen- tatives of these water supply systems, it became clear that although compliance efforts are underway, detailed data on costs of compliance are not yet available. Report Organization The organization of this report begins with a summary of the major findings (Section 2), then continues with more detailed information found under subsections which progress as follows: Section 3 provides background information on public water supply systems in Illinois, including discussions on water sources in Illinois, key population breakdowns on the number and location of surface water users, and a brief overview of the treatment requirements for public water supply (PWS) systems. Section 4 describes the water quality and health aspects of THMs and their occurrence in Illinois' public drinking water. Section 5 estimates the general compliance costs of the THM proposal, while Section 6 assesses the benefits of the proposal in terms of health and retained funding. Section 7 of the report summarizes the economic impact of R81-11 and Section 8 compares the overall costs and benefits of the proposed regulation, CHAPTER II SUMMARY Proposed regulatory changes to Chapter Six of the Illinois Public Water Supply Regulations contained in regulatory proposal R81-11 seek to control the concentration of tr i ha lome thanes (THMs) in Illinois' public drinking water. Trihalomethanes were shown to be associated with cancer in some epidemiological tests which led the U.S. EPA to amend the National Interim Primacy Drinking Water Regulations establish- ing a maximum contaminant level of 0.10 mg/Ji for total trihalomethanes (TTHM). In order for the state to maintain primacy enforcement respon- sibilities and $1.2 million annually in federal funding, all Illinois' public water supplies serving greater than 75,000 people must be con- scientiously approaching compliance by November 5, 1981, while those serving between 10,000 and 75,000 people must be approaching compliance by November 5, 1983. Approximately 85% of the Illinois water supply is from sources which have historically had negligible levels of TTHM: groundwater sources and Lake Michigan. The other 15% will have to be sampled for TTHM to determine whether compliance measures must be undertaken. Forty-three public water supplies (PWS) in the state serve greater than 10,000 people and are thus subject to this regulation. Thus far, 2 of 11 PWS which have completed sampling are in violation of the proposed standard: Rend Lake and E. St. Louis. Both serve populations greater than 75,000 people, and both had TTHM sampling results which showed TTHM levels generally below 0.20 mg/£. (See Table 4-7). The Rock Island PWS was also found to be in violation of the proposed standard in an August, 1981 sample. Rock Island serves between 10,000 and 75,000 people. Estimating the range of compliance costs is made difficult by the lack of detailed data on TTHM sampling results across the state, and on the feasibility and effectiveness of the multitude of possible alterations in water treatment processes. Most water supply authorities have stated that many of the PWS which have to implement changes in their water treatment processes will be able to bring the TTHM level into compliance by changing chlorination points and/or replacing chlorine with another disinfectant. The large capital costs associated with the addition of the carbon adsorption treatment alternative are not expected. The analytical costs will be higher if the regulatory change is not adopted because the TTHM regulation is a Federal requirement. If the proposal is not adopted, TTHM sampling would have to be done in private laboratories at a cost to the PWS of $45.00 per sample, whereas state funds would cover the cost of sampling done in state operated labs ($2?.. 50 per sample) if the proposal is accepted. Given an estimated 1200 TTHM sample sets the first year, and an average of 428 sample sets per year thereafter (see Tables 2-1 and 2-2), accepting the regulatory proposal represents a saving of $27,000 the first year, and an average of $9,622.50 per year thereafter. In addition, if the regulatory proposal is accepted, the state will continue to receive approximately $1.2 million per year in federal 8 funding, which reoresents 61% of the PWS direct budget. The economic impact of this regulatory proposal on the agricul- tural and commercial sectors is negligible. The impact on the manu- facturing sector, most specifically the chemical industry, may involve minor price increases. The health effects of controlling TTHM are indeed important factors. They are, however, irrelevant to this cost-benefit analysis because these health benefits accrue whether the state or the federal government imposes the TTHM standard. The incremental health benefits of adopting the proposal are therefore zero. The comparison of the incremental costs and benefits of the regulatory proposal on trihalomethanes are presented in Tables 2-1 and 2-2. In summary, because the TTHM standard would be enforceable on the Illinois PWS system regardless of whether the state adopted the proposal, the incremental benefits of adopting the measure outweigh the costs by an amount equivalent to the aforementioned federal funding plus any difference in analytical costs. Table 2-1. Comparison of First. Year Incremental Costs and Benefits of Adopting R81-11* Benefits Costs Adopting Regulation Health considerations Analytical requirements Federal funding for state Not Adopting Regulation Health considerations Analytical requirements Federal funding for state Incremental Costs and Benefits of Adopting Regulation Health considerations Analytical requirements Federal funding for state Total first-year incremental costs and benefits of adopting regulation Not quantifiable $1.2 million Not quantifiable $0 $0 a. $1.2 million Not quantifiable $27,000 Not quantifiable $54,000 first year $0 $27,000 first year $1,227 million first year ♦Assumes sampling for maximum total trihalomethane potential is used. 10 1 *-> S "O co Q) CO »— C cn c U ■M to O • t= •T— CO >> a <_> t. >> CM f- r— J- f— C IO Q> CM u +J JO •F- 1_ »— • r— QJ CD VO QJ ro T3 3 c>- ro ro >- •» ■*-> L. 1— a. ■O Q> • 4J "O cn ro qj a> 0) QJ >- C7> C i- G %** 2 O..C M- JZ CO * > CJ O 10 O +J r-l «a: E M- O a. 1 ,_ ■O ^H CZ O 4-» T- • $- jQ OJ r- « •^» 0. 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U U >> fO •«-> JC ro ro O co QJ «— « CM CO ^r «« 3 • OJ ro O ro r- 0> CO OJ <: >- «e co -o co 2: *a 2 0J >>M- CO * 11 CHAPTER III BACKGROUND ON PUBLIC WATER SUPPLIES IN ILLINOIS Sources of Water in Illinois In 1978 the predominant source of water supplies in Illinois was surface waters: of the 1771 million gallons per day (MGD) utilized for potable water, 1313 MGD were attributed to surface water and 458 MGD to ground water supplies. Table 3-1 summarizes the 1978 water consumption pattern for potable and agricultural water supplies. If Lake Michigan and Rend Lake water volumes are subtracted, other lakes and streams in the state account for 265 MGD, or 15% of the total volume. Characteristics of PWS in surface waters in Illinois are provided in Table 3-2. In Illinois there are 265 MGD of potable water supplies drawn from lakes and streams. Of the 163 PWS utilizing surface water, 80 are located on creeks. There are 14 users of Lake Michigan and an additional 10 using reservoirs or lakes. The remaining 59 PWS are located on major streams in Illinois from the Kankakee to the Mississippi River. Size of PWS in Illinois The size of the PWS in Illinois is of primary concern because the proposed regulation affects only those PWS serving over 10,000 people. Table 3-3 provides data on the number and location of surface water users, and Table 3-4 summarizes the number of PWS in terms of those systems serving less than 10,000, greater than 10,000 and less than 75,000, or greater than 75,000. Forty-three systems (those serving greater than 10,000 people) must comply, or be in compliance, with the proposed regulation. 12 Table 3.1 Public Water Supply Sources in Illinois Public Water Supply Source Volume Utilized in 1978, MGD Ground Water 458.2 Surface Water 1312.7 Rend Lake 12.2 Lake Michigan 1035.3 Other sources 265.2 Total utilized 1770.9 SOURCE: Kirk, Jarboe, Sanderson, Water Withdrawal in Illinois , 1978, Circular No. 140, Illinois State Water Surveys, 1979. 13 Table 3-2. Characteristics of Public Water Supplies on Surface Waters Water Source Number of PWS Lakes 24 Creeks 80 Impoundments 3 Mississippi River 15 Little Wabash 8 Vermil ion River 5 Kaskaskia River 9 Ohio River 4 Embarras 3 Kankakee 1 Fox 1 Illinois 1 Big Muddy 3 Wood River 2 Forks of Sal ine 2 Wabash 1 Mi seel 1 Total 163 14 X CD O o J- OJ Xt to c o ro o o c rO c o -t-> rO Q. O a. cd CD u 3 o co 3 J- CD +J 01 CD «4- > I. •^ •r— O J- en i- O pn c CD L. CD f— o S_ > L. 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Surface PWS Population Breakdown with Respect to Proposed Regulation R81-11 Population Served Number of PWS Systems Less than 10,000 93 10,000 to 75,000 34 Greater than 75,000 9 Treatment Requirements for PWS The basic standard for design, operation, and maintenance of public water supply facilities shall be the "Standards" (Recommended Standards for Water Works as adopted by the Great Lakes-Upper Mississippi River Board of State Sanitary Engineers). The extent of water treatment required shall be determined by the Agency in accordance with Technical Policy Statement 307, accepted engineering practices and the Standards. Typical treatment requirements for surface waters in Illinois are coagulation, filtration and chlorination. Ground water supplies also require chlorination prior to distribution. Such potable water treatment requirements reduce the risk associated with surface water utilization. 21 CHAPTER IV TRIHALOMETHANES--WATER QUALITY AND HEALTH ASPECTS Description of Trihalomethanes and Their Formation Generally, 4 * two types of organic substances are found in drinking supplies: those that are manufactured by man and find their way intact into the water source, and those that are formed during the water treatment process in the plant itself. More research is presently being done on the health effects of the former type, and there are presently no promulgated regulations covering these contaminants. THMs are presently the most prominent members of the second class of organic substances. THMs are the members of a group of organic chemicals that contain one carbon atom, one hydrogen atom, and three halogen atoms. The four common THMs are trichloromethane (usually known as chloroform), bromodichloromethane, dibromochloromethane, and tribromomethane (or bromoform). THMs are primarily formed by the reaction of free chlorine with naturally occurring organic compounds, called THM precursors, usually produced from decaying vegetation. The reaction is not instantaneous, but takes place over a period ranging from 1 to 2 hours to several days. It is influenced by temperature, pH, precursor type and concentration, bromide concentration, disinfectant residual type, and possibly disin- fectant residual concentration. Health Consequences of Trihalomethanes The overall goal in water treatment should be to minimize adverse 22 effects, both those related to infectious diseases by adequate disinfection and those related to cancer and other chronic diseases by reducing the level of harmful substances in the water. It is generally agreed 5 that progress toward minimizing potential sources of chronic disease, such as cancer and genetic defects, should not be built on a compromise in the adequacy of disinfection. It is clear that much progress can be made by simply improving the quality of the water before disinfection. Though it is difficult to quantify at this time, improving the overall quality of water supplies, particularly decreasing the load of organics, will yield dividends on improved public health. The two most important potential chronic disease problems related to chlorinated organics are cancer and an increase in genetic defects. Cancer is a wery serious health problem in the U.S., and epidemiological data described below suggest that some part of cancer is due to the organics present in chlorinated water supplies. Since a number of compounds which are carcinogenic in animal model studies are known to be in chlorinated water, concern for minimizing carcinogenic materials has been identified as a real, not just potential, problem in water chlorination. The case studies mentioned above addressed the question "Does chronic ingestion of chlorinated drinking water increase the risk of cancer induction in humans?" Authors of the case studies emphasized that any interpretation of results from epidemiological studies should be made cautiously, for such research is beset by a number of inherent problems: 6 23 1. For many environmental carcinogens an exposure history of 5 to 30 years is necessary before a chemical case of cancer develops. In any epidemiological study of carcinogenesis, therefore, documented exposure to a carcinogen for a decade or longer would be necessary. 2. The water quality data base (the independent variable) is inadequate in most areas in the U.S. because sensitive analytical techniques have only recently been applied to monitor water quality and even now the application of those sophisticated techniques is sporadic. 3. The quality of a particular water supply is likely to change over a time frame of 10 to 20 years. Therefore, water quality measurements at the present time may bear little resemblance to water quality decades earlier when the crucial exposures may have taken place. 4. More than 300 different specific organic chemicals have been identified in the drinking water in the U.S. Most of them have not yet been tested for carcinogenic potential but some are suspected carcinogens. Therefore, a confounding error from any of these chemicals is possible. 5. In the past 30 years, the population in the U.S. has been highly mobile, therefore, for many individuals residence in a particular water district may be for a short duration. Moreover, the predominant place of water consumption for an individual may be at a job or avocation site outside of the water district of a person's usual residence. 6. Concentrations of chloroform found in chlorinated public water supplies to date vary from 0.001 to 0.311 mg/£. These relatively low concentrations, if hazardous, probably produce a small increase in relative risk. Consequently, a very large population must be studied to insure a statistical test of sufficient power. 7. Occupation, socioeconomic class, ethnic group and life style (tobacco use, alcohol use, diet) all have demonstrated an association with cancer induction. A confounding error from any of these variables is also possible. The first case control study, described in a report by Alavanja, Goldstein and Susser, 7 was conducted on all gastrointestinal (GI) and urinary tract (UT) cancer deaths occurring during the period January 1, 24 1968 to December 31, 1970, in seven New York state counties. These counties include Allegany, Cattaraugus, Chautuaqua, Erie, Rensselaer, St. Lawrence and Schenectady. Several independent variables were explored, including residence in an urban or rural area, residence in an area served by chlorinated water or nonchlorinated water, residence in an area served by surface water or groundwater, occupation, age, sex, race, and foreign vs. U.S. place of birth. Cases and controls were matched as closely as possible to isolate statistical relationships between chlorinated water (and its contaminants, such as THM) and the incidence of cancer. The authors qualify their statistical conclusions by referring to the generally inadequate water quality data in the seven counties studied. They limit their conclusions to this statement: Males living in the chlorinated water areas of Erie, Rensselaer and Schenectady counties and females living in the chlorinated water areas of Erie and Schenectady counties are at a greater risk of gastrointestinal and urinary tract cancer mortality than are individuals living in nonchlorinated water areas. Moreover, this excess risk of 61 and UT cancer mortality is not due to a disparity in age, race or ethnic distribution of the population or to an urban/rural factor, hazardous occupation, inorganic carcinogens, or a surface/groundwater difference. Tables 4-1 and 4-2 summarize their findings. The authors further note that the significant relationship between gastrointestinal and urinary tract cancer mortality, and chlor- inated water, can be explained by three theories. First, the process of chlorination is viewed as being directly responsible for GI and UT in 25 s- QJ "O U -f- . -J co 4-> > o co i_ di a»« — J— l_ 4-) to < fl (U >> 3 •<- 1.13-O+J IO Q) C C C-U 3 3 •<- -o o "O ■*-> C r— C fO <_> CO .— C CO fO O fO _5rf C Z QJ i- •i- t. O *-> • - LO CO QJ > i— S ■M (TJ QJ CTJ i-Z ■r- QJ Z3 o -m o: c J_ TO QJ +-> C • > to •!— to QJ o o •—CO *»-x: ion J- -H ^-»l»- ZD I OC O 00 O >,tO CO _Q CM to C O QJ •r- -D 4-> -t- , QJ ■*-> ■o OJ •t— to •f- OJ -t-> S_ ro > =3 .O CO OJ ro Z 3 "- C St . : _ X 7 ~ 7 X c 3 E y. 1 c i 5 - 2; - -3 — I/". - — ~ 3 Z * e * ^ -3 — TJ c c j: c C 3 v. £ - 'w ;c = oc U 3 — c • in in o o OJ • •M o o c V 4-> o 0) o 3 •«- r«" to 0> > 0) CO o. ro jO 26 Table 4-2. Estimated Odds Ratios (OR) of Gastrointestinal and Urinary Tract Cancer Mortality for Residents of Chlorinated vs. Nonchlorinated Areas Listed by Gender and Primary Anatomic Cancer Site (1968-1970, Seven New York State Counties) 3 — __ Piimary Anatomic Site Six Odds Ratio 1 siiphaeus Males and 1 em.iles 2.12 1 ' Males 2.39 1 1 emales 1.28 Sliinut.il Males jnd 1 cnijJes 1.82 d Males 1.67 1 ' 1 email's t -i^n l.are.e Intestine M.iIi"n and 1 cm. ties 1.61 d Males 1.99° 1 emales 1.30 Ki\ lutn Males anil 1 email's 1.93 d M.les 2.33 d 1 emales 1.25 l.ivei .ind kidno Males and 1 emal.'s 2.19 d Males 2.76 d i i null's 1.55 I'ancrea* Males .ind 1 emales 1.97 d Males 2.62 d 1 email's 1.26 Urinjr; lll.iddcr Mali's ami 1 email's l.69 b Mali's 2.02 d 1 i' niali'% 0.82 Total Males and 1 email's 1.79 d Males 2.09 d 1 emales l.44 d a See footnote 5. b P value < 0.025. C P value < 0.05. P value < 0.005 27 chlorinated water areas. It is postulated that chlorine or a substance in the chlorine solution used at the water treatment plant reacts with a substance in the water, possibly humic acid, to form a carcinogen (e.g., THM). The second theory postulates that the process of chlorination is a necessary part of a more complete causal pathway to GI and UT cancer mortality; the chlorine solution and byproduct of chlorination (such as THM) are viewed as a "weak carcinogen" which interact with some other "cofactor" to form the actual carcinogen. The difficulty in testing Theory II is identifying the cofactor. Theory III views the process of chlorination as independent of the causal pathway, but statistically associated with the true causal variable(s) so that statistical tests erroneously depict chlorination and its byproducts as causal factors of increased GI and UT cancer. The second case-control study 8 of gastrointestinal and urinary tract cancer mortality was conducted in Illinois. The purpose of the study was to try to replicate the findings of the New York study, i.e., to determine whether an association exists between cancer and chlorination practices. In this study as opposed to the New York study, cases and controls were classified according to residence in chlorinated or non- chlorinated groundwater communities. Surface waters were not considered in order to avoid the confounding involvement of comparing chlorinated surface waters with nonchlorinated groundwater. Surface waters can contain a variety of chemical compounds from agricultural runoff and/or industrial sewage. Also, studies have reported increased risks of gastrointestinal tract cancers for areas served by surface water supplies 28 as opposed to groundwater. 9 ' 10 Thus, although this study examines the relationship between THMs (and other byproducts of water chlorination) and high cancer rates for only groundwater supplies, which have lower levels of THM precursors than do surface water supplies, it still provides information on the possible carcinogenic effects of THMs. Cases and controls were further classified in much the same way as the New York study, except that it was restricted to whites. The results are found in Tables 4-3 through 4-6. Table 4-3 shows numbers of cancer deaths of the GI and UT in chlorinated vs. nonchlorinated Illinois groundwater communities. Only cancer of the large intestine, total digestive tract (excluding liver) and total gastrointestinal and urinary tract cancers provided an adequate number of cases to test for significant differences between the chlorinated and nonchlorinated communities. Table 4-4 shows relative risk estimates for cancer of specific and grouped sites, adjusted for age, urban/rural and SMSA/non-SMSA, and calculated separately for each sex. Only cancer of the rectum for females demonstrated anappreciable increase (>25%) over unity. Table 4-4 also shows that adjusted relative risks vary little with respect to unadjusted relative risks. Table 4-5 shows that the excess risk in chlorinated communities is concentrated in urban areas, particularly in SMSA counties and not in rural non-SMSA areas. The only other study comparable to the Illinois investigation was the New York study. Table 4-6 compares the results of the two studies, and shows that, other than the finding of an urban effect for GI cancer 29 Table 4-3. Site-Specific Cancer Deaths of the Gastrointestinal and Urinary Tract in Chlorinated vs. Nonchlorinated Ground- water Communities in Illinois, 1973 to 1976 ("■immunity Cl*^* Cancer Site Chlorinated Nnnthliirinited 1 supliacus K J 5tS Slomai li Till 128 Laiyc Intestine 7"" I 4r\fi Keitum I'M |0| Livci .'-J 24 Gallbladder 79 54 Pancreas 1)\ 193 Uladdcr I "?4 110 Other lrinar> Organs 135 95 Tola! Piresiive Tract (Ixcludint Liver) ll>.?9 V98 Total Unnar> 1 rjet ii>y 205 Total (iasirointesiinal and Urinarv Tract l°S| 1227 a The ditfcrcncc to be dote ted is a 50 ditK nn«e U - . relative risk = l.5l tor O 3 0.05 and 0- 0.2(1 An estimate ul 4 22 was in.uk lut die number til cases needed lor each sue- s|M-ii r r ..mcer lo dctc.t a <»f .lilleien.e QJ 30 o C_> o r— (T3 o —• 4-> •— ro oo r-^ v. — I •> c oo O -r- •M T3 ■*- (V C Q. 3 3 E O E s- o o o (T3 O S •r- "O •i- 3 O O ■»-> •<- ro -»-> C fU -r- r- i_ c *-> o «/> z 3 •O • "O to «t > «3- I JO s -a - E o- c c — C '"i &■ &■ * — — c c — — d — r, ccoc?o-» o c a ©■ o- S £ £ P =■ ^ «■• 2 "• »N v. w-> «-. ok e I ^ cc : " ; c -i c — <-- o> w, i ■ c d d ' i j - t» , n 3 s o* o c c — — 'I ^ — io o> ^ * O O C O Ov — d d - _ - c - ; T — C Sj T3 1 C C c • -9 Sf, 3 t. ^ c c u E 3 £ -» C 1 5 — I/-. :■ - X = -3 !■•! o x b e •. U fl V ~ w "3 "3 •• w b rS "3 *r> a. © 5 e < c -i .o 31 Table 4-5. Age-Adjusted Relative Risks of Total Gastrointestinal and Urinary Tract Cancer Mortality for Chlorinated (as of 1963) vs. Nonchlorinated Illinois Groundwater Communities in Various Population Samples, 1973 to 1976 1 \timaird Relative Kisi Study Population Main I'Vmali's Males and I'cmalc* Total 1.01 1 09 1 05 SMSA 1.04 1.2* J l.|4 b Urban 1 HI 1.31 1.13 Rural 1 (IK 1.25 IIS NonSMSA 1 .Oil 99 0.99 Urban 1.00 1.21 1.14 Rural 1191 ii Hit 0.8n b Urban 1 (»r. i :j j l.|4 J Rural (197 09< 0.96 a p<0.025 b p- o. OO 2 a> >» -Q QJ ?>•*= L. to O (O t-«a: 01 u i- C d> « +-> O (O 2 o c 3 to o -* i- co o a: -o a> a) -m > n i- c 4-> t- i— O a> f— u "O c 0) o 4-> 2= E • •f- i/1 •M > I/) T3 O C t- to O i- »/» O iO £ lc o « c n "• : «"< f-i — r^ r4 O •» o > C Si "3 _ = - < 5 y - E 5 I S-H — i/> _J at : cm © E" E 3 S* »VV r> £; .£ | -> a c. — — ' r- I " jo u 33 < mortality among females, the Illinois study failed to confirm the findings of the New York study either in the strength of association or in consistency in the direction of the chlorination effect. The authors further urge cautious interpretation of the results because of the existence of uncontrolled factors such as diet, smoking, population mobility, length of exposure and latency period for site-specific cancers. They conclude that, given the present status of research in this area, chlorination of groundwater does not seem to be a major factor in the etiology of site-specific gastrointestinal and urinary tract cancers. Authors of both studies firmly believe, however, that more epidemiological studies need to be conducted to determine the true level of risk to humans of consuming water containing THMs. The consensus of opinion from the majority of studies reviewed for this Economic Impact Study indicates that the existing body of evidence is consistent enough to warrant limitation of the practice of prechlorination of drinking water supplies which are high in organic precursors. In addition, deliberate efforts should be made to reduce manmade organic contamination of surface water sources or to reduce the concentration of these in community water systems. The other major potential chronic disease problem related to water treatment is an increase in genetic defects. According to cochairmen of the Health Effects Workshop of the Second Conference on Water Chlorin- ation: Environmental Impact and Health Effects, 11 there is now clear evidence that chemicals found in chlorinated waters are mutagenic, at least in bacterial test systems. This means they have mutagenic potential in higher organisms, including humans, and that increased testing in 34 mammalian test systems needs to be done. Tri ha lome thane Occurrence in Illinois Sampling for TTHM has already begun in Illinois in response to R81-11, the proposed change in Chapter 6 of the Public Water Supply Regulation. According to information provided by Mr. Ira Markwood, Manager of the Division of Public Water Supplies, IEPA, 11 of 209 water supplies serving over 10,000 people have completed TTHM sampling to date. The results are shown in Table 4-6. Table 4.6 Illinois TTHM Sampling Results ttum v a i.„ m r,/o Number of Communities TTHM Value, mg/£ over 10j0Q0 Population 0.00-0.025 4 0.026-0.050 4 0.051-0.075 0.076-0.100 1 Over 0.100 2 Those two communities which were found to be in violation of the proposed TTHM level of 0.100 mg/£. are East St. Louis and Rend Lake public water supplies. In addition, the Rock Island (not included in Table 4-6) public water supply was found to have a TTHM value of 0.400 mg/l in an August 27, 1981 sampling. The sampling data for these communities are presented in Table 4-7. 35 Table 4-7. Sampling Results of PWS Currently in Violation of Proposed TTHM Standard PWS Sampling Date TTHM Value 0.109 mg/£ 0.137 mg/£ 0.180 mg/£ 0.130 mg/l 0.176 mg/£ 0.125 mg/£ 0.118 mg/£ 0.271 mg/£ 0.143 mg/£ Rock Island 8/27/81 0.400 mg/£ Illinois American Co. - E. St. Louis Water 5/14/81 4/8/81 7/30/80 4/30/80 Rend Lake 5/12/81 2/4/81 7/18/80 7/14/80 4/9/80 In conversations with representatives of the Rend Lake and E. St. Louis PWS, it was pointed out that higher levels of TTHMS are associated with warmer weather and with unusually heavy rainfall. Warmer weather encourages the generation of THM precursors such as rotting vegetables, 12 and heavy rainfall facilitates their entry into surface water supplies. Given that the sampling is far from complete, other public water supply systems may be found to be in violation of the proposed TTHM standard. In testimony before the IPCB during public hearings held on 36 R81-11, an official from the Division of Public Water Supplies states that on the basis of the data collected thus far, groundwater supplies have very low trihalomethane levels. 13 In addition, groundwater supplies are in general very stable in quality and the temperature remains essentially the same year around. In fact, Federal Regulations currently call for an analysis of groundwater supplies only every three years. Given that there are approximately 1140 groundwater supplies, as opposed to 137 surface water supplies, and that groundwater sources account for 26% of public water supply sources in Illinois while Lake Michigan accounts for another 59%, a large percentage (85%) of the water supply sources in Illinois are not anticipated to have TTHM levels above the proposed regulatory standard of 0.10 mg/£. 37 CHAPTER V COMPLIANCE COSTS OF THM PROPOSAL Compliance alternatives for a public water supply system can be as easy and as inexpensive as changing the point of chlorination appli- cation or as complex and expensive as the installation of THM adsorption equipment. Each supply must conduct an on-site study to determine the most cost-effective compliance option. In conversations with representatives of the Rend Lake and East St. Louis PWS systems, conducted in order to formulate cost ranges for compliance alternatives, it became clear that specific cost estimates were not available at this time. Efforts are still underway to determine effective compliance methods, with the least costly methods being studied first. It also became clear that methods which are successful at one plant may not be effective at another, a fact which increases the difficulty in assessing meaningful cost ranges. Before providing, more precise cost estimates, a technical intro- duction to compliance alternatives will serve to illustrate the range of possible routes a PWS may pursue in meeting the new federal standards. The following overview of treatment techniques is found in the July, 1981 issue of Water/Engineering and Management in an article entitled "Removing Trihalomethanes from Drinking Water," by J. M. Symons, A. A. Stevens, R. M. Clark, E. E. Geldreich, 0. T. Love, Jr., and J. DeMarco. Treatment Evaluation In order to properly evaluate any proposed trihalomethane 38 control scheme, the behavior of three parameters must be well understood. These are: (1) Instantaneous trihalomethane con- centration (InstTHM), or the trihalomethane concentration at the time a sample is collected; (2) terminal trihalomethane concen- tration (TermTHM), or the prediction of some future trihalomethane conentration determined by storing a chlorinated sample for a specified time period under conditions that are equivalent to those encountered in the treatment plant or disribution system under study, and (3) the trihalomethane formation potential concentration (THMFP) or the measure of the trihalomethane precursors that will eventually react with free chlorine to produce trihalomethanes under the selected conditions, calculated as the arithmetic difference between the previously two defined parameters. Treatment Techniques The reaction for the formation of trihalomethanes is: Free Chlorine + Precursors (Humic Substances) + Bromide ► Trihalomethanes + Other By-Products and leads to three approaches for controlling the concentration of trihalomethanes 1n drinking water. Any process must be evaluated in terms of maintaining or improving bacteriological and overall chemical quality. Thus, minimizing the potential for the formation of other disinfection by-products is prudent. Trihalomethane Removal . Three unit processes were studied: oxidation, aeration, and adsorption. Each of these processes has advantages and disadvantages. Of the oxidation processes studied, only ozone combined with ultra-violet radiation was effective for trihalomethane destruction, but the possibility of undesirable oxidation by-products being formed during treatment cannot be neglected. Aeration can be effective for trihalomethane removal and does not produce any by-products. Waters high in the bromine- containing trihalomethanes are difficult to treat by aeration. Further, aeration as a treatment technique has the disadvantage of possibly creating an air pollution problem. Finally, if aeration is contemplated, design factors may have to include an enclosure or some protection from freezing in some climates and include techniques for avoiding entrainment of particulates. Two adsorbents were studied: activated carbon and synthetic resins. Both were much more effective for adsorbing the bromine- containing trihalomethanes than for chloroform; therefore, if these species dominate the trihalomethane mixture in a given location, adsorption might be the most effective approach. Both of the granular adsorbents studied have to be renewed when exhausted and will desorb previously adsorbed contaminants if the influent concentration declines. If powdered activated carbon is used, sludge disposal may be a problem, because adsorbent doses needed for effective treatment may be much higher than commonly used for taste and odor removal. 39 Tri hal omethane Precursor Removal . Of the seven techniques studied (clarification, source control, aeration, oxidation, adsorption, biological degradation and lowering the pH) all but aeration had a significant effect on the trlhal omethane precursor concentration. If Its control 1s desired, the raw water source should be examined to determine if changes are possible that would result 1n a lower concentration of trlhal omethane precursors. Clarification has been shown to be effective for removal of some tri ha 1 omethane precursors. Existing plants should be examined to determine 1f their performance can be Improved by changing the coagulant dose, type or both. Additionally, under certain circumstances, existing plants using source water chlorination may be modified easily by moving the point of chlorination downstream to further reduce tri hal omethane concentrations. These circumstances can be judged a priori by determining the concentrations of trihalomethanes and tri- halomethane precursors (InstTHM, TermTHM and THMFP) at various stages. Chances for successfully lowering tri hal omethane precursor concentrations by moving the chlorination point are better if: (1) under routine operations prior to moving the point of chlorination, a high percentage of tri hal omethane precursors is settled out during clarification and (2) under routine operation prior to moving the point of chlorination, a high percentage of tri hal omethane precursors has reacted with free chlorine to form trihalomethanes during clarification. Another possible alternative is to operate the treatment plant and the distribution system at a lower pH, 1f high pH is the current method of preventing corrosion, or to investigate the use of potassium permanganate. These techniques may be instituted with minor modifications of existing processes. If these relatively simple approaches to tri hal omethane precursor removal are not sufficiently effective to lower the average concentration of total tri hal omethane in the distribution system to meet the total tri hal omethane Maximum Contaminant Level, the designer and operator may try other approaches, such as ozone or chlorine dioxide oxidation, or adsorplon with powdered activated carbon (PAC) or granular activated carbon (6AC). Note, during oxidation by chlorine dioxide, both chlorite and chlorate may be formed. Because of concerns over toxicity, the U.S. EPA has recommended that the sum of the residual concentrations of chlorine dioxide, chlorite, and chlorate in the drinking water should not exceed 0.5 mg/£. Of the alternative treatments noted above, granular activated carbon adsorption is initially the most effective for trlhal omethane precursor removal. When fresh, this adsorbent 1s able to provide almost complete removal of these materials from water. At empty bed contact times (empty bed volume divided by flow rate) of 5 to 10 min., however, this excellent performance is not long-lasting. 40 Use of Alternative Dislnfectants i Although none of the unit processes studied (ozonation, combined chlorlnatlon and treatment by chlorine dioxide) produce trlhalomethanes, each disinfectant has specific advantages and disadvantages beyond the general disadvantage that they all form some organic by- products. Ozone 1s an excellent biocide and the bloddal activity 1s not affected by the pH of the water. Ozone does not produce a disinfectant residual, however, and 1f 1t were used alone, no biocidal agent would be present 1n the distri- bution system. More than 1,000 water treatment plants around the world generate ozone on-site, but the generation equipment is more elaborate than that required when free chlorine 1s used. Finally, reports have Indicated that when ozone 1s used, organics in the water become more biodegradable, and this can result 1n higher microbiological activity in the distribution system. Chloramines (combined chlorine residual) have the advantage of being easy to generate and feed and produce a persistent residual that can be maintained through the distribution system. Chloramines are weaker biocides and the biocidal action is reduced when the pH of the water 1s high because monochloramine formation is favored over dichloramine formation. Two reports in the literature document possible problems with chloramine toxicity. 11 " 15 Chloramines are currently undergoing carcin- ogenesis bioassay at the National Cancer Institute. Chlorine dioxide has several advantages as an alternative disinfectant; it has good biocidal activity over the pH range usually occurring in water treatment, so 1t 1s applicable to most systems. It can be generated and fed readily, although care is needed to maintain a low concentration of chlorine. Also, it produces a residual that can persist through the distribution system. Lastly, chlorine dioxide does not react with ammonia. Therefore, the disinfectant demand for chlorine dioxide may be somewhat less than for free chlorine. A major disadvantage of using chlorine dioxide as an alternative is the formation of chlorite and chlorate. Because of the potential toxicity of chlorite and chlorate, the U.S. EPA has recommended in the Tr 1 ha lome thane Regulation that the sum of the residual concentrations of chlorine dioxide, chlorite and chlorate be limited to 0.5 mg/£ in drinking water. The use of chlorine dioxide may be limited if this recommendation is adopted by Primacy Stotes because many waters in the U.S. have disinfectant demands that would result in a total residual concentration exceeding 0.5 mg/l when adequate chlorine dioxide is applied to meet the demand. Of the three approaches to trihalomethane control, the use of alternate disinfectants appears to be the most effective and the least costly. Theoretically, any utility, with any trihalomethane precursor concentration, could reduce its trihalomethane concentration to almost zero by the use of one of these three disinfectant alternatives to free chlorine. 41 Furthermore, the cost of any of these unit processes* calculated either with or without contact chambers. Is very low. Because of the cost advantage, a water utility requiring tri ha Tome thane control probably would consider the use of alternate disinfectants as the first approach to meeting the tr1 ha lome thane Regulation, but the utility managers and their consultants should also consider the disadvantages of this approach. Alternatively, for the control of tr1 ha lome thanes by removal of trihalomethanes and trihalomethane precursors, Table 4-7 compares the performance and cost of 11 currently available unit processes. The table also describes the behavior of these unit processes with respect to several common areas: the effect on trihalomethane precursor concentrations, the effect on trihalomethane concentrations, the formation of other by-products, and the representative estimated costs. Using data collected at specific utilities studied, these estimated costs were calculated for a single size of treatment plant, 100 mgd, at three levels of treatment success and were based on the cost of chemical dosages and of other operating parameters that achieved specified levels of treatment. These data should be used for comparison purposes of costs for equal treatment and should not be taken as universally applicable. Absolute effectiveness of unit processes and costs will vary among locations. Maintaining Bacteriological Quality Drinking water treatment modifications to reduce trihalomethane precursors must be applied cautiously with careful consideration to the changes that such alternatives may Introduce in the microbial quality of drinking water produced 1n the plant and transmitted through the distribution network. In all of the many field studies examined during this research effort, no overt evidence of microbial deterioration in the finished water leaving the treatment plant occurred. In the trade- off to delay disinfection until near the final stages of the treatment process to obtain lower trihalomethane concentrations, however, some microbial migration deeper Into the treatment train must be accepted. Therefore, greater reliance must be placed on final disinfection, with maintenance of a disinfectant residual in the distribution system to effectively counter low level coliform populations and pathogens that have survived earlier treatment. Microbial penetration of the multiple barriers 1n drinking water treatment is more pronounced during abnormal pollution loads in the source water. Under these situations, normal microbial reductions in early phases of the treatment chain will not be adequate to suppress the residual bacterial population to low levels. This condition places a greater burden on the last in-plant treatment barrier, I.e., disinfection. There- fore, daily bacteriological monitoring of all in-plant processes 42 Q) O O i- O. > T3 cn c c r- C (T3 -r- O I. ■p. o 4J U C t» a. i/) QJ »♦- c O A3 to _e QJ *J £g •M O Qj L. l ?83 an £ - • o i QJ JO o C o 5 -o ■• c o Hill I I* — u M o * If! S3 o ■ -o S o -6 * 2 •» " ? e ff o o E S y c 5 it *• * o 'in J. z £ J .§ c = e . e S »- §5 Ss liii n £ <• *» o I • • u V i> « " * 61s *§ a S 3 g&figs* x fel£*i 1 1 If III • 3 ■ o E « . *8£85f s * « 'el' 43 C c o o i ■.'*> -* I? o a. * .. 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E ID Ift Ift I 3 Ift •ft < * APPENDIX 60 STATE OF ILLINOIS ) ) SS COUNTY OF SANGAMON ) BEFORE THE ILLINOIS POLLUTION CONTROL BOARD PROPOSAL FOR RULEMAKING FOR THE PUBLIC WATER SUPPLY R81-11 REGULATIONS OF THE ILLINOIS POLLUTION CONTROL BOARD SUBMITTED BY: ILLINOIS ENVIRONMENTAL PROTECTION AGENCY PROPOSAL FOR RULEMAKING The Illinois Environmental Protection Agency ("Agency"), pursuant to Sections 1004(j) and 1028 of the Illinois Environmental Protection Act (111. Rev. Stat., 1979, ch. Ill 1/2, pars. 1001 et seq.) hereby requests the Illinois Pollution Control Board ("Board"), to make the following changes to its Public Water Supply Regulations (Chapter Six^* Rule 104 Definitions — Add the following definitions in their respective alphabetically proper positions: (New Language Underlined) "Halogen" means one of the chemical elements chlorine, bromine or iodine. "Trihalomethane" (THM) means one of the family of organic compounds, named as derivatives of methane, wherein three of the four hydrogen atoms in methane are each substituted by a halogen atom 1n the molecular structure. "Total trihalomethanes" (TTHM) means the sum of the concentration in milligrams per liter of the trihalomethane compounds trlchloromethane (chloroform), dibromochloromethane. bromodichlorome thane and trlbromomethane (bromoform)), rounded to two significant figures. 61 "Maximum Total Trihalomethane Potential (MTP)" means the maximum concentration of total trlhalomethanes produced 1n a given water . containing a disinfectant residual after 7 days at a temperature of 2S^ C or above. "Disinfectant" means any oxidant, including but not limited to chlorine, chlorine dioxide, chloramines, and ozone, added to water 1n any part of the treatment or distribution process, which 1s Intended to kill or inactivate pathogenic microorganisms* JUSTIFICATION: The above definitions are required by a recent Amendment to the National Interim Primary Drinking Water Regulations 44 Fed. Reg. 68624 (1979) (to be codified in 40 CFR Sec. 141.2) in accordance with the Safe Drinking Water Act (P.L. 93-523). In order, to avoid inconsistent State and Federal regulations and maintain State primary enforcement responsibility the above definitions are necessary. 304 Finished Water Quality A. Bacteriological Quality 1. Standard Sample The standard sample for the coliform test shall consist of: a. For the membrane filter technique, not less than 100 milliliters. b. For the fermentation tube method, five standard portions of either 10 milliliters or 100 milliliters. 2. Total Coliform Limits The number of organisms of the coliform group present 1n potable water, as indicated by representative samples examined, shall not exceed the following limits: 62 a. When the membrane filter technique 1s used, arithmetic mean coHform density of all standard samples examined per month shall not exceed teur one per 100 milliliters . Any Individual standard sample shall not exceed four collform colonies per 100 milliliters 1n: (1) more than one standard sample when less than twenty are examined per month; or (2) more than five percent of the standard samples when twenty or more are examined per month. JUSTIFICATION: the maximum arithmetic mean density of coliform organisms of one per 100 milliliters is a federal standard (40 C.F.R. Sec. 141.14(a)(1)) which has been enforceable against public water supplies in Illinois due to the Safe Drinking Water Act (P.L. 93-523). Although the Board Order in R73-13 (November 22, 1974) contained language in accord with the federal standard, the text of adopted rules (111. Reg., Vol. 3, Issue 1-3, March 30, 1979, page 241) contains an apparent tyopgraphical error. In order to avoid inconsistent state and federal standards and maintain state primary enforcement authority the proposed amendment 1s necessary. The remaining text of subsection A remains unchanged. B. Chemical and Physical Quality 1. The finished water shall contain no impurity in concentrations that may be hazardous to the health of the consumer or excessively corrosive or otherwise deleterious to the water supply. Drinking water shall contain no impurity which could reasonably be expected to cause offense to the sense of sight, taste, or smell. 63 2. Substances used 1n treatment should not remain 1n the water 1n concentrations greater than required by good practice. Substances which may have a deleterious physiological effect, or for which physiological effects are not known, shall not be used 1n a manner that would permit them to reach the consumer. 3. If the result of an analysis made pursuant to these Rules Indicates that the level of any contaminant listed 1n Table 1 exceeds the maximum allowable concentration, the owner or operator of the public water supply shall report to the Agency within 7 days and initiate three additional analyses at the same sampling point within one month. When the average of four analyses, rounded to the same number of significant figures as the maximum allowable concentration for the substance in questions, exceeds the maximum allowable concentration, the owner or operator of the public water supply shall notify the Agency pursuant to Rule 310 B and give notice to the public pursuant to Rule 313 D of these Rules. Monitoring after public notification shall be at a frequency designated by the Agency and shall continue until the maximum allowable concentration has not been exceeded in two successive samples or until a monitoring schedule as a condition to a variance or enforcement action shall become effective. 4. The concentration of substances listed 1n Table 1 shall not exceed in the finished water the limits listed. 64 TABLE 1 MAXIMUM ALLOWABLE CONCENTRATIONS FINISHED WATER QUALITY Substance Reported As As Ba Cd Cr Cu CN F Fe Pb Mn Hg N Arsenic Barium Cadmium Chromium Copper Cyanide Fluoride Iron Lead Manganese Mercury Nitrate- Nitrogen Organics Total Trihalomethanes Pesticides ~" — Chlorinated Hydrocarbon Insecticides Aldrin Chlordane DDT Dieldrin Endrin Heptachlor Heptachlor Epoxide Lindane Methoxychlor Toxaphene Chlorophenoxy Herbicides 2,4-Dichlorophenoxyacetic acid (2,4-D) 2,4,5-Trichlorophenoxypropionic acid (2,4,5-TP or Silvex) Selenium Silver Turbidity Zinc Se Ag NTU 2n NOTES: Maximum Concentration mg/1 0.05 1. 0.010 0.05 5. 0.2 1.8(d) 1.0(a) 0.05 0.15(a) 0.002 10.(b) 0.10(e) 0.001 0.003 0.05 0.001 0.0002 0.0001 0.0001 0.004 0.1 0.005 0.1 0.01 0.01 0.05 K0(c) 5. a. All non-conmunity water supplies and those community water supplies which serve a population of 1000 or less or 300 service connections 65 or less shall be exempt from the standards for Iron and manganese. All other water supplies shall comply with these standards by July 1, 1981. Iron 1n excess of 1.0 mg/1 and manganese 1n excess of 0.15 mg/1 may be allowed at the discretion of the Agency if sequestration tried on an experimental basis proves to be effective. If sequestering 1s not effective, positive Iron or manganese reduction treatment as applicable must be provided. No experimental use of a sequestering agent may be tried without previous Agency approval. b. The provisions of Rule 304 B 3 notwithstanding, compliance with the maximum allowable concentration for nitrate shall be determined on the basis of the mean of two analyses. When a level exceeding the maximum allowable concentration for nitrate 1s found, a second analysis shall be initiated within 24 hours, and 1f the mean of the two analyses exceeds the maximum allowable concentration, the owner or operator of the public water supply shall report his findings to the State pursuant to Rule 310 B and shall notify the public pursuant to Rule 313 0. c. Turbidity in drinking water shall not exceed one turbidity unit at the point where water enters the distribution system unless it can be demonstrated that a higher turbidity not exceeding 5 NTU does not: (1) interfere with disinfection, or (2) cause tastes and odors upon disinfection, or (3) prevent the maintenance of an effective disinfection agent throughout the distribution system, or (4) result in deposits 1n the distribution system, or (5) cause customers to question the safety of their drinking water. The provisions of Rule 304 B 3 notwithstanding, 1f a turbidity measurement exceeds the maximum allowable concentration, a resample must be taken as soon as practicable, and preferably within one hour. If the check sample confirms that the standard has been exceeded, the Agency must be notified within 48 hours. The value of the check sample shall be the value used in calculating the monthly average. If the monthly average of the daily samples taken 1n accordance with Rule 309 D exceeds the maximum allowable concentration, or 1f the average of two samples taken on consecutive days exceeds 5 NTU, the owner or operator of the public water supply shall report to the Agency and notify the public as directed 1n Rule 310 B and 313 0. JUSTIFICATION: The turbidity standard, measured 1n nephelometric turbidity units (NTU) Is reported to one significant figure. Elimination of the decimal point and zero In Table 1 makes the standard consistent with Note C to Table 1 and to the National Interim Primary Drinking Water Regulations 40 CFR Sec. 141.13. d. Those counties of the State north of and including the counties of Henderson, McDonough, Fulton, Tazewell, McLean, Ford anS Tro^ols snail have a maximum allowable concentration of 2.0 mg/1. ~ C . 0nr !l" 1ty T !! a ?u r su . ppl j e s ser ving 75,000 or more individuals sh all comply with this standar d by Novemb er 5. I9fl1. ConmuM.ly water supplie s serving 10. UUU Eg 797 999 individuals shall nor apply to supplies servi ng less than lu.uQu individu TTsT — 22£1 JUSTIFICATION: The Maximum Allowable Concentration for trihalomethanes is a Federal standard, promulgated as an amendment to the National Interim Primary Drinking Water Regulations 44 Fed. Reg. 68624 (1979) (to be codified in 40 CFR Sec. 141.2 et seq.) in accordance with the provisions of the Safe Drinking Water Act (P.L. 93-523). This amendment consists of a maximum concentration limit 1n drinking water reaching the consumer (40 CFR Sec. 141.12), a sampling and monitoring program to determine whether and to what extent trihalomethanes occur in Illinois drinking water (40 CFR Sec. 141.30), and phased compliance dates, based on the size of the population served by the supply (40 CFR Sec. 141.6). The National Interim Primary Drinking Water Standards have been enforceable against public water supplies 1n Illinois since June 24, 1977 and adoption of this standard by the Illinois Pollution Control Board will avoid conflicting State and Federal standards and will enable the State to maintain primary enforcement responsibility. 67 C. Radiological Quality The text of subsection C remains unchanged. 8 68 309 Frequency of Sampling /L Bacteriological Text of Subsection A remains unchanged. B. Chemical 1. Community Water Supplies — Surface Water Sources a. A minimum of one representative sample each of the raw and finished water 1s to be submitted at least annually to the Agency for chemical analysis. Frem-€enwuR4ty-water-s«pp44e5-wh4€h-Ht444ze-a surfaee-wateF-seuFce* b. Supplies serving over 10,000 individuals shall submit at least four samples per treatment plant per quarter for analysis or analytical results from a certified laboratory for total trlhalomethanes to the Agency. After results of four consecutive quarters demonstrate consistent total trlhalomethane concentrations below the Maximum Allowable Concentration t and upon written application by the supply the Agency may reduce the sample frequency to one sample per quarter until the Maximum Allowable Concentration is exceeded or until a significant change in source or treatment method is made. 2. Community Water Supplies — Ground Water Sources a^ A minimum of one representative sample of the finished water is to be submitted at least every three years to the Agency for chemical analysis. Cemun4ty-wateF-suppUes-wh4€h-ut4)42e-a-gi»eund-watep-seuFee aise-4o-submH-such-samp}es-U-tbe -Agency -at-Jeast-evei*y-twe-yeaiesT JUSTIFICATION: By reducing the sampling frequency for chemical analysis of ground water supplies from two years to every three years, DS Rule 309B2I, formerly Rule 309 B. will conform with the Federal reo.u1re.snts contained 1n 40 CFR 141.23 and 141.24. It Is not necessary that the State's requirements be more stringent than the Federal requirements to protect the health of Illinois citizens. The chemical composition of ground water 1s fairly stable, so that sampling every three years will be sufficient to monitor any changes. Under the proposed language, raw water samples of ground water supplies will no longer be required to be submitted on a regular basis to the Agency. This also conforms with the Federal requirements set out In 40 CFR 141.2(c). Again, because of the chemical stability of a ground water source, it will be sufficient for the Agency to request raw water samples for chemical analysis as necessary. The Agency will establish a schedule, lengthier than every three years, for ground water supplies to routinely submit raw water samples. For those supplies It determines to be less stable, more frequent sampling can and will be required. The Agency already has authority to do so under Sec. 309 B 4. formerly Rule 309 B. ^ su pplies serving 10-000 Individ uals or more shall submit at !...♦ „n, »mnle p ~ *»,tn,,nt' plant for HTP analysis. After written re quest hv the «. T pi» and the de termlnatlgn bv the Agency that the results nf the s - p 1 " »" d 1 °" 1 * -«««.« indicate that the supply 1s „nt Hk.lv to afflroach or exceed the Maximum Allowable Concentration, the .■T piy shall continue to submit o ne -.u.1 sample per treatment plant, or rppnrt of analy^ bv a certifi ed laboratory to the Agency. If the .- pi. exceeds the Maxima! MIowa M * r-r-tritlon or cannot be analyzed , 10 70 for MTP. the supply shall submit samples In accordance with Sec. X9 b 1 JUSTIFICATION: Pursuant to 40 CFR 141.30(b)(1), the federal sampling frequency for supplies utilizing surface water sources or ground water sources 1s four samples per quarter for each treatment plant, at least for the Initial monitoring year. However, this requirement can be relaxed for ground water supplies pursuant to 40 CFR 141.30(c)(1). A minimum of one sample per year is sufficient for ground water sources, even for the Initial monitoring year, so long as this sample meets the analysis requirements for MTP and analysis indicates a maximum potential of less than the total trihalomethane standard. If it does not, quarterly sampling of four samples is required. The language of proposed Sec. 309 B 2 b allows for this. It would be unnecessary and burdensome to require more frequent sampling than the Federal requirement. JL. Significant changes in water sources or treatment methods will require testing in accord with Sec. 309 Bib. JUSTIFICATION: This proposed requirement Is 1n accordance with the federal requirements contained in 40 CFR 141.30(c)(2), All supplies changing water sources or treatment methods will have to comply with the monitoring frequency of four samples each quarter for the first year. If analysis of these samples indicate no potential to exceed the total trihalomethane standard, the Agency may reduce monitoring to one annual sample. It should be noted that this rule applies to ground water and surface water supplies alike. The federal requirements do not provide for reduced monitoring for ground water sources when the supply changes its source or treatment methods. 11 71 4. Sampling for specific parameters may be required by the Agency more frequently whenever there 1s reason to believe that these parameters are or may be 1n excess of the limits listed 1n Table 1 or 1f the presence of other dangerous or potentially dangerous substances 1s suspected. 5. Non-Community water supplies shall submit representative samples of raw and finished water to the Agency laboratory for chemical analysis at frequencies required by the Agency. C. Monitoring Frequency for Radioactivity 1n Coimiunity Water Supplies 1. Monitoring requirements for gross alpha particle activity, radium-226 and radium-228. a. Compliance shall be based on the analysis of an annual composite of four consecutive quarterly samples or the average of the analyses of four samples obtained at quarterly Intervals. (1) A gross alpha particle activity measurement may be substituted for the required radium-226 and radium-228 analysis, provided that the measured gross alpha particle activity does not exceed 5 pCi/1 at a confidence level of 95 percent (l>6i 1.96 here 1s the standard deviation of the net counting rate of the sample). In localities where radium-228 may be present 1n drinking water radium-226 and/ or radium-228 analyses may be required by the Agency when the gross alpha particle activity exceeds 2 pCi/1. JUSTIFICATION: The emission of alpha particles by atoms 1s a random event, therefore the test 1s run several times and the reported result 1s 12 72 a statistical average. In order to conform to the Federal accuracy requirement (40 CFR Sec. 141.25) of 95%, and standard statistical laws, this amendment 1s necessary. The remaining text of this rule remains unchanged. Hird/sp0586C/l-13 13 /J FOOTNOTES 1. The Introduction 1s based on an article entitled "Removing Trl ha Tome thanes from Drinking Water," by James M. Symons, Alan A. Stevens, Robert M. Clark, Edwin Geldreich, 0. Thomas Love, Jr., and Jack DeMarco. The article appeared in Water/Engineering & Management , July, 1981. 2. Bellar, T. A., J. J. Lichtenberg and R. C. Kronder. "The Occur- rence of Organohalides 1n Chlorinated Drinking Water." Journal American Water Works Association , 66 (December, 1974), 703-706. 3. Rook, J. J. "Formation of Haloforms During Chlorinatlon of Natural Water." Water Treatment and Examination , 23, Pa*** 2 (1974), 234-243. 4. Statement made by Mr. Joseph F. Harrison, Chief of Water Supply Branch, Region V Office of the U.S. EPA during the Public Hearing for R81-U held on May 15, 1981; pp. 20-21. 5. Alavanja, M. , I. Goldstein and M. Susser. "A Case-Control Study of Gastrointestinal and Urinary Tract Cancer Mortality and DHr.? r.g Water Chlorination," 1n Water Chlorination: Environmental Impact and Health Effects , Volume 2. R.L. Jolley, H. Gorchev, and D.H.Hamilton, Jr., Eds. (1978), 395-410 . 6. Ibid. 7. Ibid. 8. Brenniman, G. R., J. Vasilomanolakis-Lagos, J., Amsel , T « Namekata and A. H. Wolff. "Case-Control Study of Cancer Deaths in Illinois Communities Served by Chlorinated or Nonchlorinated Water," in Water Chlorination: Environmental Impact and Health Effects, Volume 3. R. L. Jolley, W. A. Brungs and R. B. Curmring, Eds. (1980) 1043-1957. 9. Salg, J. "Cancer Mortality Rates and Drinking Water 1n 346 Counties of the Ohio River Valley Basin," Ph.D. Thesis, University of North Carolina (1977). 10. Kuzma, R. J., C. M. Kuzma and C. R. Buncher. "Ohio Drinking Water Source and Cancer Rates." Am. J. Public Health 67:725-729 (1977). 11. Cunning, R. B., and H. Gorchev. "Health Effects Workshop Summary," In Water Chlorination: Environmental Impact and Health Effects, Volume 2. R. L. Jolley, H. Gorchev, and D. H. Hamilton, tds. (1978) 863-865. \2. Statement made by Mr. Ira M. Marchwood, Division Manager, Division of Public Water Supplies, Illinois EPA, during the Public Hearing for R81-11 held on May 29, 1981; p. 84 of the hearing transcript. 1 3. Statement made by Mr. Charles R. Bell, Jr., Manager of the Field Operations Section for the Division of Public Water Supplies, Illinois EPA during the Public Hearing for R81-11 held on May 29, 1981; pp. 56-64 of the hearing transcript. |4. Shih, K. L. and J. Lederberg. "Choramine Metagenesis 1n Bacillus subtilis." Science , 192 (June 11, 1976) 1141-1143. 1 5. Eaton, J. W. , C. F. Kolpln and H. S. Swofford. "Chlorinated Urban Water: A Cause of Dialysis Induced Hemolytic Anemia." Science , 181 (August 3, 1973) 463-464. |6. MGD refers to million gallons per day. Data for Section 5.1 was supplied by Mr. Ira Markwood of the Illinois EPA and by the respective PWS representatives. 1 7. Source: Conversation with Linda L. Huff, President, Huff 4 Huff Environmental Consultants, Inc. |fl Statement made by Mr. Joseph F. Harrison, Chief of the Water Supply Branch, Region V Office of the U.S. EPA, during the Public Hearing for R81-11 held on May 29, 1981; pg. 58. 1 9. For other proposed changes 1n,the regulation which concerned general monitoring requirements of groundwater supplies, it was projected by Mr. Charles R. Bell, Jr., Manager of the Field Operations Section, Division of Public Water Supplies, IEPA, during testimony at the Public Hearing for R81-11 on May 29, 1981, (pp. 56-64), that, if the proposed regulatory change R81-11 were adopted, the number of required chemical sample sets on groundwater supplies would be reduced from 2070 to 980 sample sets per year, a saving of 1090 complete chemical analyses per year. According to Mr. Bell, this represents a savings to the Division of Laboratories of approximately $3,000 annually, a savings to Division of Public Water Supplies, IEPA, of about $1500 annually, and a savings to the aggregated group of water supplies of about $12,000 per year (the $12,000 representing mailing cost of additional samples and labor for col- lection time). These general costs of monitoring would be Incurred, however, regard- less of whether the state regulatory proposal is adopted, and are therefore not represented in the Incremental cost-benefit analysis. /0. Data provided 1n October 16, 1981 correspondence from Mr. Ira M. Markwood, Division Manager, Division of Public Water Supplies, Illinois EPA. /3 21. Direct quote from correspondence referenced 1n Note 20. 99 <;tnt«i*nt made bv Mr. Joseph F. Harrison, Chief of the Hater Supply BrtncT Region V Off ce ofV U.S. EPA during the Pub 1c Hearings for R81-11 held on May 15. 1981; pp. 19-24 of the hearing transcript. 11 statement made bv Mr. Don Mattox, Chief of the Technical Support "' !ett?o*n" Water 5p& Branch, U.S. EPA Region V during the Public Hearings for R81-11 held on May 15. 1981; pp. 40-41. 24. Harrison; pg. 25. 25. Computation shown 1n Table 8-2 of this report. 26. Assumes annual federal funding of $1.2 million. 6Z8 165 J292EX C002 economlclmp»cl,l odyo , n81 „ trfhjl , om 3 0112 088637779