Technical Memorandum

To: From: Cc: Date: Subject: November 22, 2009 Disinfection Options to Comply with LT2ESWTR Michelle Owen, Baker City HDR Engineering, Inc. (Bryan Black, David Keil and Pepi Ursillo)

1.0 Executive Summary

Baker City operates an unfiltered surface water supply. The Long Term 2 Enhanced Surface Water Treatment Rule (LT2) issued by USEPA requires unfiltered surface water systems to achieve removal or disinfection of Cryptosporidium, an organism that can cause gastrointestinal distress or more severe health impacts for those with compromised immune systems. The existing chlorine disinfection system is not sufficient to provide the required disinfection. This regulation is requiring additional treatment by Baker City, similar to other cities including Walla Walla, Portland, Tacoma, Bremerton, and Seattle. This study reviewed the available treatment alternatives: membrane filtration to remove Cryptosporidium or disinfection to inactivate Cryptosporidium with ultraviolet light, ozone, or chlorine dioxide. The evaluation of alternatives indicates that disinfection with ultraviolet (UV) light is an attractive option to comply with the requirements of LT2. UV is the least expensive option, simple to operate, reliable, and fits well into the gravity flow hydraulics of the existing water system. However, for UV disinfection to be sufficient treatment into the future, the City must maintain its exemption from filtration. This depends on natural water quality, watershed protection, and approvals by Oregon Department of Human Services. Also, UV disinfection provides no protection against degraded water quality resulting from forest fires. Protection against forest fires and maximum reduction in regulatory risk could be achieved by membrane filtration, but at significant additional expense. A new UV disinfection is anticipated to cost in the range of $2.5M to construct and may add in the range of $15,000 per year in operating costs for the City. Compliance is required by October of 2013. To meet this schedule, it is recommended that the City move forward with equipment selection and regulatory coordination in 2010, design in 2011, and construction in 2012. This schedule is intended to allow sufficient operational experience prior to the 2013 compliance deadline.

2.0 Introduction and Objectives

The Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) was promulgated by the United States Environmental Protection Agency (USEPA) in January 2006. The purpose of this technical memorandum is to assist Baker City (City) in selecting the preferred disinfection process for its surface water supply to comply with LT2ESWTR. Once the preferred disinfection process is selected, alternative configurations and locations will be assessed to integrate the new treatment process into the existing system.

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3.0 Compliance Requirements

The Citys water sources include the 210 million gallon Goodrich Reservoir and 11 intake sources from springs and streams. These sources are currently classified as a surface water not requiring filtration (unfiltered). This is a relatively rare regulatory classification and is due to the exceptional water quality and protection afforded the by the Baker City Watershed. This technical memorandum and project assumes that the unfiltered status will be retained. If the unfiltered status is not retained, the City would be required to filter its water supply, and a different set of LT2ESWTR requirements would apply. The LT2ESWTR requires that unfiltered surface water supplies be disinfected to inactivate the protozoan Cryptosporidium. A relevant excerpt from the final rule is included below: The LT2ESWTR requires all unfiltered public water systems (PWSs) to provide at least 2-log (99%) inactivation of Cryptosporidium. Further, under the LT2ESWTR, unfiltered PWSs must achieve their overall inactivation requirements (including Giardia lamblia and virus inactivation as established by earlier regulations) using a minimum of two disinfectants. The Cryptosporidium inactivation requirements are based on a treatment technique with the actual level of inactivation targeted to the risk of occurrence. If the initial source water monitoring reveals that the mean Cryptosporidium concentration is greater than 0.01 oocysts per liter, or if the initial source water monitoring is not performed, then at least 3-log (99.9%) inactivation of Cryptosporidium would be required. The LT2ESWTR contains language that addresses variances and exemptions to the new treatment requirements (see Appendix A). In theory, if it can be demonstrated that an unfiltered surface source has a source water Cryptosporidium concentration that is 3-log lower than the Bin 1 cutoff for filtered surface supplies (i.e., below 0.075 oocysts per 1,000 L), this could support a variance to the need for Cryptosporidium treatment. In practice, however, the USEPA has not identified an approach that is economically or technologically feasible for a water system to demonstrate such a low level of Cryptosporidium to support granting a variance. This is due to the extremely large volume and number of samples that would be necessary to make such a demonstration with confidence.

4.0 Compliance Options

To meet the new Cryptosporidium inactivation requirements for an unfiltered surface water source, a water system must use one or more of the following disinfection technologies:

Chlorine Dioxide Ozone Ultraviolet Light

A filtration process such as membrane, conventional, or direct filtration could also be installed to meet regulatory requirements, but at a significantly higher cost to the City compared with any of the disinfection options. Furthermore, as noted above, unfiltered systems must meet the combined Cryptosporidium, Giardia lamblia, and virus inactivation requirements using a minimum of two disinfectants. Each disinfectant is required to achieve the complete inactivation of at least one of these three pathogen classes. The City currently uses chlorine to provide 3-log Giardia lamblia and 4-log virus inactivation and to maintain a detectable disinfectant residual throughout the distribution system. Chlorine would be retained as the second disinfectant; however, it may be possible to use the new disinfection process to achieve the 3-log Giardia lamblia kill in addition to the Cryptosporidium requirement. The existing chlorine dose rate is set based on maintaining
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minimum target residuals in chlorine contact chamber effluent and throughout the distribution system; therefore, unless booster chlorination facilities are installed within the system, the chlorine dose should not be significantly reduced from current conditions. This will be further considered in the future as part of facility siting. Some background information on the disinfection options is presented below.

Chlorine Dioxide
Chlorine dioxide gas (ClO2) is an oxidizing agent and disinfectant. For water treatment applications, aqueous chlorine dioxide solution (0.1 to 0.5 percent) is typically generated onsite (from the reaction of sodium chlorite and excess chlorine or acid) with commercial generators, as it cannot be safely shipped or stored. The solution is then metered into the water supply where it requires contact time to achieve disinfection. The reaction of chlorine dioxide with various inorganic and organic reductants can lead to the formation of regulated disinfection byproducts, including chlorite (ClO2-) and chlorate (ClO3-). In drinking water, chlorite is the predominant reaction end-product, with 50 to 70 percent of the chlorine dioxide converted to chlorite and 30 percent to chlorate and chloride. Typical chlorine dioxide doses used in drinking water treatment are 0.07 to 2.0 mg/L. Because of the complex reaction chemistry, careful monitoring and dose control is necessary. The Maximum Residual Disinfectant Level (MRDL) for chlorine dioxide is 0.8 mg/L and the Maximum Contaminant Level (MCL) for chlorite is 1.0 mg/L. This means that if the oxidant demand is greater than about 1.4 mg/L, chlorine dioxide may not be used as a disinfectant because the chlorite/chlorate byproducts might exceed the MCL.

Ozone
Ozone gas (O3) is a powerful oxidizing agent and disinfectant. Its typical uses in water treatment include primary disinfection, oxidation, color removal, and breakdown of compounds that contribute to taste and odor. Ozone is typically generated onsite with commercial ozone generators, which provide an electrical charge to high-purity oxygen. Ozone gas is diffused into a closed chamber designed to encourage mass transfer into the water and provide adequate contact time for disinfection. Typical ozone levels used in drinking water treatment are 0.1 to 1.0 mg/L. After the contact period, the residual ozone is stripped out of solution at atmospheric pressure and passed through an ozone destruction unit. Ozone gas can react with natural organic matter (NOM) in the water to produce smaller organic fragments that include aldehydes and organic acids. These byproducts are generally more biodegradable and assimilable by heterotrophic bacteria than the original compounds. Therefore, unless removed, these byproducts may stimulate biological growth within the distribution system. These organic byproducts may also be more reactive precursors in the formation of regulated disinfection byproducts (DBPs), including trihalomethanes (THM) and haloacetic acids (HAA). Ozone can also react with bromide to form bromate, another regulated DBP. While the potential exists for increased THMs and HAAs through the use of ozone, the Citys current THM and HAA concentrations are relatively low at approximately 24% and 35%, respectively, of the EPA maximum contaminant level (MCL). While the presence of NOM can be a precursor to DBPs, DBP formation would not be significant enough where the City would risk approaching the THM and HAA MCLs.

Ultraviolet Light
Irradiation with ultraviolet (UV) light is an effective non-chemical disinfectant and can also be used in the advanced oxidation of emerging environmental contaminants. In drinking water applications, water is passed through a closed (i.e., pressurized) vessel where UV light is
Disinfection Options to Comply with LT2ESWTR Project Number 109551 3 Revised DRAFT November 2009

emitted through a series of lamps. Because of extremely short contact times and a variety of reactor types and configurations (e.g., low pressure-high output versus medium pressure), the reactors have been evaluated, validated and approved for application by the Drinking Water Protection Program of the Oregon Department of Environmental Quality (DEQ). The highenergy UV light is particularly effective against protozoa like Cryptosporidium and Giardia lamblia (at typical doses of 40 mJ/cm2), but much less effective against viruses. The use of UV technology for disinfection does not typically affect the chemical characteristics or taste and odor of the water and does not contribute to DBP formation.

5.0 Evaluation of Compliance Options

An overview of considerations for each of the disinfection options is presented in Table 1. Each option is described and evaluated for cost, water system compatibility, reliability, water quality impacts, and operational complexity. Table 1 also indicates major equipment suppliers and installed locations in the Pacific Northwest.

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Table 1. Overview of Disinfection Options UV Light (UV) DESCRIPTION

Ozone (O3)

Chlorine Dioxide (ClO2)

COST

UV light inactivates Giardia lamblia and Cryptosporidium by penetrating the genetic material and destroying the cells ability to reproduce. UV light is applied in pressurized reactors through low-pressure high output or medium-pressure lamps. $2.3M for 12-mgd treatment (dose 40 mJ/cm2) $13K yearly O&M costs $2.5M present worth cost Does not require separate contact time after application. Can be used in pressurized lines up to 125 psi. No additional pumping required if properly sited. Chlorine would provide virus inactivation and a residual in the distribution system. UV is as effective as ozone for Cryptosporidium inactivation. Disinfection capacity does not depend on temperature Capacity is reduced if the lamps foul (e.g., from hardness or iron), or if the transmittance of the water is low. Reactor validation ensures that short circuiting through the UV reactor is accounted for during design. No adverse impacts No chemicals added to the water

Ozone (O3) is a chemical oxidant that breaks down the cellular material of pathogens. Ozone gas is generated on-site from liquid oxygen or ambient air and is introduced into the water through diffusers in a contact basin. Excess ozone in the gas phase must be collected and destroyed. $4.8M for 12-mgd facility with contact chamber (7 mg/L dose) $89K yearly O&M costs for 7-mg/L dose $5.8M present worth cost Requires chamber to meet contact time and building to house ozone generation equipment Injection point must be at atmospheric pressure since excess ozone gas must be collected, destroyed, and vented. Chlorine would provide virus inactivation and a residual in the distribution system. More effective than chlorine dioxide in Cryptosporidum inactivation. Disinfection capacity depends on temperature and demand and decay characteristics of water Fairly reliable system 600-mgd LA plant in operation for 10 years has been available 97.1 % of the time. Ozone may increase the concentration of assimilable organic carbon, which could stimulate biological growth within the distribution system. Ozone could produce more reactive organic precursors that lead to higher levels of regulated disinfection byproducts in the system. Ozone can remove color and improve taste and odor, but this is not required. Complex system but highly automated and reliable. Maintenance requires skilled technicians. Fuse failures and generator cleaning comprised major maintenance items Ozone is highly corrosive and toxic and requires constant monitoring. Requires cooling system and off-gas destruction system for excess ozone Raw water bromide should be measured if ozone is selected for implementation to ensure that bromate MCL can be met Ozonia, Wedeco Seattle WA, Tacoma WA

Chlorine dioxide (ClO2 ) is a neutral oxidant and disinfectant that breaks down the cellular material of pathogens. Chlorine dioxide is generated on-site from sodium chlorite and chlorine gas or acid and is metered into the water. $12.7M for 12-mgd treatment (1 mg/L dose) and 12 mg contact tank $74K yearly O&M costs for 1 mg/L dose $13.6M present worth cost Requires tank to meet contact time and building to house ClO2 generation equipment and chemicals. Can dose under distribution pressure no additional pumping required. Chlorine would provide secondary disinfection and a residual in the distribution system. Questions regarding reliability to achieve Cryptosporidium inactivation, given downward pressure on concentrations of disinfectant and disinfection byproducts. Disinfection effectiveness decreases significantly as water temperature decreases (decrease from 20C to 10C reduces effectiveness by 40%) ClO2 generation produces disinfection byproducts such as chlorate and chlorite, which have negative health impacts and maximum contaminant levels set by the EPA.

WATER SYSTEM COMPATIBILITY

RELIABILITY

WATER QUALITY

OPERATIONAL COMPLEXITY

NOTES

Automated and relatively simple Requires general training for bulb and ballast replacement Occasional chemical cleaning of the lamps, if auto-wipers are not provided Source water should be tested for UV transmittance and fouling agents to confirm assumptions in cost estimates and support design and regulatory approval. Trojan, Wedeco Richland WA; Seattle WA; Canby OR; Springfield OR

ClO2 generation system is complex and requires constant monitoring to ensure efficient operation and to reduce byproduct generation. Analytical methods for measuring low levels of ClO2 are not as reliable due to interferences from chlorine. Aggressive regulatory monitoring requirements are continually being refined, causing uncertainty and risk. ClO2 can be regenerated in the distribution system from residuals of chlorite and chlorine. Altivia (Vulcan), International Dioxide Skagit PUD #1 in Mount Vernon (but not for Crypto inactivation)

COMMON EQUIPMENT SUPPLIERS NORTHWEST FACILITIES

Disinfection Options to Comply with LT2ESWTR Project Number 109551

Table 2 presents an opinion of probable project costs for the three disinfection options available under the LT2ESWTR as well as the membrane filtration option. The basis for costs are references listed in the notes section of the table, confirmed by recent regional experience on similar projects. The capital costs are based on a design peak hour flow rate of 12 million gallons per day (mgd), while annual operations and maintenance (O&M) costs are based on an average flow rate of approximately 4 mgd. The capital costs presented include an allowance for engineering and construction-phase services (25%), and an estimating contingency (30%). Present worth costs were determined assuming a 6% discount rate and 20-year amortization period.

Table 2. Cost Opinion for LT2ESWTR Compliance Options

Compliance Option UV Ozone Chlorine Dioxide Membrane Filtration Capital ($M) 2.3 4.8 12.7 17.7 O&M ($1,000/yr) 13 89 74 332 Present Worth ($M) 2.5 5.8 13.6 21.5

Notes: 1. Capital Cost includes Engineering and Services During Construction 2. Oxone and Chlorine Dioxide costs from Formation and Control of DBPs in Drinking Water, AWWA 1999. Chlorine Dioxide costs include 12-MG contact tank. 3. UV Costs from UV Disinfection Costs for Inactivating Cryptosporidium, JAWWA June 2001 4. Costs updated to June 2009 dollars using ENR 20-city average construction cost index Assumptions: Average Annual Flow = 4 mgd Plant Capacity = 12 mgd Discount (interest) rate = 6% Amortization Period = 20 yrs Engineering and Services During Construction = 25% Contingency on Capital Costs = 30% Figure 1 provides a graphical representation of this cost information. Capital and present worth costs are shown on the left y-axis and O&M costs are shown on the right y-axis. UV disinfection is projected to be the lowest cost compliance option with a present worth cost of $2.5M. The next lowest cost option is ozone, with a present worth cost of $5.8M. Although a chlorine dioxide generation and feed system would be relatively inexpensive to construct (estimated capital cost of $0.9M), a 12-MG tank would also be required (estimated additional cost $12M) to provide the contact time needed for 2- to 3-log inactivation of Cryptosporidium. Taken together, these costs make chlorine dioxide an expensive compliance option. Finally, membrane filtration is anticipated to be the highest cost compliance solution. Other filtration solutions not presented in this evaluation, such as conventional filtration or rapid sand filtration, are also anticipated to be higher cost solutions than the disinfection solutions.

Disinfection Options to Comply with LT2ESWTR Project Number 109551

Figure 1. Cost Opinion for LT2 Compliance Options

Given the significantly higher costs of filtration, it is recommended that the City consider this option only if the unfiltered status of the source is seriously threatened or intake shutdowns due to high turbidity events prevent the reliable use of this source. If the City water treatment system loses its unfiltered status, filtration will be required. Since membrane filtration requires less footprint space than other filtration systems, space requirements for membrane filtration will be considered in the upcoming facility siting evaluation, in case it needs to be added in the future. The use of ozone would introduce a significant level of treatment complexity to the City at a relatively high cost. With regard to water quality effects, ozone may promote to a small degree the formation of bromate and/or more reactive organic precursors. Given the low levels of THMs and HAAs within the distribution system under existing conditions, and the additional regulation under the Stage 2 DBP Rule, the potential for further DBP increases is a consideration yet it is expected the THM and HAA MCLs would still be met. The use of ozone may be justified only if taste and odor needed to be improved or if color needed to be removed. The City of Seattle incorporated ozone into its Cedar River facility to address taste and odor issues. However, the Cedar River facility also incorporated UV facilities, recognizing that UV is a less expensive option for inactivating Cryptosporidium. Discussions with City staff and review of water quality information indicate that no improvement of taste and odor or color is required for the Citys water supply. Therefore, the higher costs and complexity of ozone do not appear to be justifiable. The installation of a chlorine dioxide generation and feed system would be inexpensive. However, given the MRDL of 0.8 mg/L and required CT (product of residual concentration and contact time) of 858 mg-min/L for 2-log Cryptosporidium inactivation at 5oC, it is estimated that a 12-MG tank would need to be installed to provide the necessary contact time. This would come at a considerable cost to the City. Moreover, adding chlorine dioxide to the Citys water will produce regulated disinfection byproducts (chlorite and chlorate). It is recommended that

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chlorine dioxide not be selected as the preferred compliance option given the high cost and negative water quality impacts. Disinfection by UV light will reliably meet either the 2-log or 3-log Cryptosporidium inactivation requirement and at a present worth cost much lower than the other compliance options. Unlike chlorine dioxide, UV disinfection does not introduce chemicals into the water and does not produce disinfection byproducts. UV disinfection can be operated under pressure, so it can be effectively integrated into the Citys existing hydraulic profile without additional pumping. UV disinfection systems are automated, relatively simple to operate, and have the lowest O&M costs of any of the potential compliance solutions. All factors considered, it is recommended that the City select UV disinfection as the preferred compliance solution given the benefits of UV disinfection and its low cost relative to other compliance options.

6.0 Process Selection

The selection of the preferred compliance solution can be made based on multiple selection criteria. The following list contains suggested selection criteria that have been useful in making treatment process decisions on past projects. However, the City could choose to modify these criteria if desired for this specific project.

Cost: How do the costs compare on a present worth basis? Compatibility: How easily can the treatment process be integrated into existing system operations? Water Quality: Does the treatment process either improve or degrade water quality? Complexity: Which process will be the easiest to operate and have the least potential for mechanical failure? Reliability: Which process will most reliably achieve long-term regulatory compliance?

To use these or other preferred criteria in decision-making, the relative importance of each criterion first needs to be established. Table 3 provides an example of rating the criteria to develop relative importance using a process called pairwise comparison. In this process, each pair of criteria is directly compared to determine which one is more important to the City. In the Table 3 example, the criterion in the first row (cost) is compared in sequence to the criteria in the columns (compatibility, water quality, complexity, and reliability). Scores (from 1 to 5) are assigned based on how important the criterion in the row is relative to the criterion in the column, per the scoring scheme below:

1: (row) criterion is much less important than (column) criterion 2: (row) criterion is slightly less important than (column) criterion 3: (row) criterion is equivalent to (column) criterion 4: (row) criterion is slightly more important than (column) criterion 5: (row) criterion is much more important than (column) criterion

For example, take the first decision in the cost row in Table 3: How important is cost relative to compatibility with the existing water system? In this example, cost and compatibility were judged to be equally important and a score of 3 was entered into this cell. Moving one cell to the right, cost is judged to be slightly less important than water quality, so a score of 2 was assigned. In the next cell to the right, cost and complexity are judged to be equally important (score of 3 was assigned). Finally, cost is judged to be much less important than reliability (score of 1 was assigned). The shaded fields are automatically calculated so that the sum of the shaded field and its complementary field (diagonal) are equal to 6. The rows are summed to yield the criteria weights. In this example, water quality was determined to be the
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most important criterion (highest score), followed by reliability, compatibility, cost, and complexity. The City could chose to adopt the criteria and weights in this example, or could go through the pairwise comparison process to establish new criteria and weights.

Table 3. Example Evaluation Criteria and Weights

Com patib ility Wate r Qu ality Com plexi ty Relia bility

Cost

Weights = = = = = 9 11 17 9 14

Cost Compatibility Water Quality Complexity Reliability 3 4 3 5

2 2

3 3 5

1 3 4 2

4 3 3 1 2

= Self-calculating fields

Evaluating the four candidate compliance options (three disinfection options plus membrane filtration) against the identified criteria can also be accomplished with the pairwise comparison process. Each pair of compliance options are directly compared based on a specific criterion, for example, cost. Table 4 presents an example for the cost criterion. In the example, the treatment process in the first row (UV) is compared in sequence to the treatment processes in the columns (ozone, chlorine dioxide, and membrane filtration). Scores (from 1 to 5) are assigned based on how well the treatment process in the row compares with the treatment process in the column based on the criterion, per the scoring scheme below:

1: (row) treatment process is much worse than (column) treatment process 2: (row) treatment process is slightly worse than (column) treatment process 3: (row) treatment process is equivalent to (column) treatment process 4: (row) treatment process is slightly better than (column) treatment process 5: (row) treatment process is much better than (column) treatment process

For example, take the first decision in Table 4: On a present worth cost basis, how does UV compare with ozone? The cost evaluation presented above in Table 2 indicates that the present worth of UV is $2.5M, while the present worth of ozone is $5.8M. So 5 is entered in this box indicating that UV is much better than ozone on a cost basis. For the decision shown in the next box, the cost of UV is much better than chlorine dioxide, so 5 is entered. Finally, the cost of UV is much better than membrane filtration, so 5 is entered in the last box in the UV row. The rows are summed, multiplied by the criterion weight value of 9 (see Table 3 weighted score for the cost criterion), and then ranked. The ranking shows that UV is the preferred option with respect to cost, followed by ozone, chlorine dioxide, and membrane filtration.

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Table 4. Cost Comparison Matrix

Criterion = Cost - Chlorine Dioxide Membrane Filtration - Ozone

Criterion Weight = UV Ozone Chlorine Dioxide

SUM = = = = 15 10 7 4 => => => =>

Weighted Score

- UV

RANK

5 1 1 1 2 1

5 4

5 5 4

135 90 63 36

1 2 3 4

Membrane Filtration

Table 5 compares the treatment options for compatibility with the existing system, primarily on the basis of hydraulic integration and space. UV is highly compatible since it operates under pressure and could be easily integrated into the hydraulic grade line and would require only a small building to house UV equipment. Ozone and chlorine dioxide are less compatible since they would require construction of large contact structures to be built and integrated with the existing system hydraulics. Membrane filtration may require construction of an additional pump station on either the upstream or downstream side, and would produce filter backwash waste equivalent to about 5% of production that would present a disposal issue. Furthermore, UV would not require additional chemical storage. However, ozone and chlorine dioxide would require storage of at least one additional chemical, and membrane filtration would require storage of at least three additional chemicals. For these reasons, UV is ranked highest for compatibility, followed by chlorine dioxide, ozone and membrane filtration.

Table 5. Compatibility Comparison Matrix

Criterion = Compatibility - Chlorine Dioxide Membrane Filtration - Ozone

Criterion Weight = UV Ozone Chlorine Dioxide

11

SUM = = = = 13 9 9 5 => => => =>

Weighted Score

- UV

RANK

4 2 2 1 3 2

4 3

5 4 4

143 99 99 55

1 2 2 4

Membrane Filtration

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Table 6 compares the treatment options on the basis of water quality. Membrane filtration is judged to produce the best water quality since water could be produced even under elevated raw water turbidity conditions1. UV is judged to be better than ozone and chlorine dioxide because it does not introduce chemicals into the water or contribute to the formation of disinfection byproducts. Ozone was ranked better than chlorine dioxide because, although both may contribute to disinfection byproducts in varying degrees, ozone would improve color, taste, and odor while chlorine dioxide would add chemicals to the water.

Table 6. Water Quality Comparison Matrix

Criterion = Water Quality - Membrane Filtration - Chlorine Dioxide - Ozone

Criterion Weight = UV Ozone Chlorine Dioxide

17

SUM = = = = 11 8 4 13 => => => =>

Weighted Score

- UV

RANK

4 2 1 4 2 4

5 4

2 2 1

187 136 68 221

2 3 4 1

Membrane Filtration

Table 7 compares the treatment options on the basis of complexity of operations. Ultraviolet light is judged to be the least complex of the options. Chlorine dioxide is slightly more complex since it requires on-site generation from sodium chlorite and chlorine gas. On-site generation of chlorine dioxide would need to be consistently optimized to prevent formation of chlorite and chlorate. Ozone is judged to be more complex than UV because it is generated on-site from liquid oxygen. Discussions with operators of Seattles Cedar Plant, which uses both UV and ozone, confirm the conclusion that ozone is more complex to operate. Finally, membrane filtration is judged to be the most complex to operate (although it can be highly automated) because it would require at least three chemical feed systems for membrane cleaning, would produce filtration wastes, and may require additional pumping.

Note that the DEQ and DHS completed a source water assessment of Baker Citys water supply and indicated that the Citys water supply is at moderate to higher risk of turbidity contamination due to soil erosion within the watershed, particularly during snow melt runoff. The assessment also notes though that the watersheds are closed to public access and only a limited amount of helicopter logging occurs in the area.
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Table 7. Complexity Comparison Matrix

Criterion = Complexity - Membrane Filtration - Chlorine Dioxide - Ozone

Criterion Weight = UV Ozone Chlorine Dioxide

SUM = = = = 13 9 9 5 => => => =>

Weighted Score

- UV

RANK

4 2 2 1 3 2

4 3

5 4 4

117 81 81 45

1 2 2 4

Membrane Filtration

Table 8 compares the treatment options on the basis of reliability in meeting future regulatory requirements. Membrane filtration is judged to be the most reliable in meeting all regulations because it provides excellent removal of Cryptosporidium and its effectiveness in meeting regulations does not depend on the City water system retaining its unfiltered status. UV and ozone were determined to be nearly equal. Chlorine dioxide is judged to be the least reliable in meeting regulatory requirements since it is not as effective at inactivating Cryptosporidium, especially at lower temperatures and since there is downward pressure on maximum allowable concentrations due to health concerns.

Table 8. Reliability Comparison Matrix

Criterion = Reliability - Membrane Filtration - Chlorine Dioxide - Ozone

Criterion Weight = UV Ozone Chlorine Dioxide

14

SUM = = = = 9 9 5 13 => => => =>

Weighted Score

- UV

RANK

3 3 2 4 2 4

4 4

2 2 1

126 126 70 182

2 2 4 1

Membrane Filtration

Table 9 presents a summary comparison of the treatment options based on all of the evaluated criteria. UV disinfection is the highest ranked treatment option by a wide margin, followed by membrane filtration and ozone, with chlorine dioxide coming in a distant last. UV disinfection was ranked highest for cost, compatibility, and complexity. UV disinfection was

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ranked second highest for water quality and reliability. Membrane filtration was judged to produce the best water quality and to be the most reliable compliance option since water could be produced during elevated raw water turbidity and since it does not rely on retaining the City water systems unfiltered status. However, membrane filtration is also the most expensive compliance option by a substantial margin. UV disinfection could be installed now with provisions to add membrane filtration later, if filtration becomes required in the future.

Table 9. Summary Comparison of Treatment Options

SUMMARY
atibi li ality ty lexit Com p y Relia b ility

Wate r Qu

Cost

Com p

SCORE = = = = 708 532 381 539 => => => =>

RANK

UV Ozone Chlorine Dioxide Membrane Filtration

135 90 63 36

143 99 99 55

187 136 68 221

117 81 81 45

126 126 70 182

1 3 4 2

Figure 2 is a graphical depiction of the summary information contained in Table 9. The figure shows that UV disinfection is ranked higher than the other treatment options by a wide margin. A sensitivity analysis suggests that the score for UV disinfection would have to be reduced by more than 23 percent for the next best option to be considered.

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Figure 2. Summary Comparison of Treatment Options

800 700 600 500 Score 400 300 200 100 0 UV Ozone Chlorine Dioxide Membrane Filtration

Cost

Compatibility

Water Quality

Complexity

Reliability

7.0 Conclusions
The Citys water supply is currently classified as surface water not requiring filtration (unfiltered). If the unfiltered status is not retained, filtration will be required. To comply with the LT2ESWTR as an unfiltered surface water system, the City will need to provide at least 2-log inactivation of Cryptosporidium for its sources. Disinfection options for unfiltered supplies include UV light, ozone, and/or chlorine dioxide. The City must use a minimum of two disinfectants to comply with the LT2ESWTR and current surface water treatment regulations. Therefore, chlorine will still be required for inactivation of viruses and to provide a residual throughout the distribution system. UV is the lowest cost compliance option. The next lowest cost option, ozone, has a cost more than double of UV disinfection. The cost for chlorine dioxide is high due to the contact time requirement. Membrane filtration is anticipated to be the most costly compliance option. Chlorine dioxide will produce regulated disinfection byproducts and may not offer reliable, long-term compliance with LT2ESWTR requirements due to downward pressure on residual levels and disinfection byproducts. UV disinfection is judged to be the highest ranking treatment option by a wide margin when the cost, compatibility with existing system, water quality, complexity, and reliability for meeting regulatory requirements are considered.

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8.0 Recommendations
Select UV disinfection as the preferred LT2ESWTR compliance solution based on the process described in this memo. Develop alternative configurations of UV disinfection within the existing system to integrate the new facilities into the existing system hydraulics, provide for ease of operations, and reduce costs. Refine the cost estimate based on the preferred configuration of the preferred compliance solution. Develop an implementation plan including disinfectant validation, potential funding mechanisms and an overall implementation schedule.

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Appendix A Excerpt from LT2ESWTR Regarding Variances and Exemptions

DRAFT Disinfection Options to Comply with LT2ESWTR Project Number 32703

Appendix A

Excerpt on Variance and Exemptions from LT2ESWTR (page 728)

40 CFR Parts 9, 141, and 142 National Primary Drinking Water Regulations Long Term 2 Enhanced Surface Water Treatment Rule; Final Rule Published in Federal Register: Thursday, January 5, 2006

M. Variances and Exemptions

SDWA section 1415 allows States to grant variances from national primary drinking water regulations under certain conditions; section 1416 establishes the conditions under which States may grant exemptions to MCL or treatment technique requirements. These conditions and EPAs view on their applicability to the LT2ESWTR are summarized as follows: 1. Variances Section 1415 specifies two provisions under which general variances to treatment technique requirements may be granted: (1) A State that has primacy may grant a variance to a PWS from any requirement to use a specified treatment technique for a contaminant if the PWS demonstrates to the satisfaction of the State that the treatment technique is not necessary to protect public health because of the nature of the PWSs raw water source. EPA may prescribe monitoring and other requirements as conditions of the variance (section 1415(a)(1)(B)). (2) EPA may grant a variance from any treatment technique requirement upon a showing by any person that an alternative treatment technique not included in such requirement is at least as efficient in lowering the level of the contaminant (section 1415(a)(3)). EPA does not believe that the first variance provision is applicable to filtered PWSs under todays rule. Filtered PWSs are required to implement additional treatment under the LT2ESWTR only when source water monitoring demonstrates higher levels of Cryptosporidium contamination. Thus, this treatment technique requirement accounts for the nature of the PWSs raw water source. Unfiltered PWS treatment requirements also account for the nature of a PWSs raw water source with respect to whether 2-or 3-log Cryptosporidium inactivation is required. In theory, the first variance provision could be applied to the requirement that all unfiltered PWSs provide at least 2-log Cryptosporidium inactivation. If an unfiltered PWS could show a raw water Cryptosporidium level 3-log lower than the Bin 1 cutoff for filtered PWSs (i.e., below 0.075 oocysts/1,000 L), this could demonstrate that no treatment for Cryptosporidium is necessary. The unfiltered PWS would already be achieving public health protection against Cryptosporidium equivalent to filtered PWSs due to the nature of the raw water source. In practice, EPA has not identified an approach that is economically or technologically feasible for a PWS to demonstrate such a low level of Cryptosporidium to support granting a variance. This is due to the extremely large volume and number of samples that would be necessary to make such a demonstration with confidence. However, unfiltered PWSs may choose to pursue the development and implementation of monitoring programs to apply for a variance from Cryptosporidium inactivation requirements based on the nature of the raw water source. A sufficient monitoring program may be feasible in site-specific circumstances or with the use of innovative approaches. The second provision for granting a variance is not applicable to the LT2ESWTR because the rule provides broad flexibility in how PWSs achieve the required level of Cryptosporidium reduction through the microbial toolbox. Moreover, the microbial toolbox contains an option for Demonstration of Performance, under which States can award treatment credit based on the demonstrated

Disinfection Options to Comply with LT2ESWTR Project Number 32703

Appendix A

efficiency of a treatment process in reducing Cryptosporidium levels. Thus, there is no need for this type of variance under the LT2ESWTR.

Disinfection Options to Comply with LT2ESWTR Project Number 32703

Appendix A