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2.8                        CHAPTER TWO
         It is  apparent  that  the EPA  is now  employing treatment  technology  and  other mitigating
         measures  in  addition  to  maximum  contaminant  levels  (MCLs)  for  several  of these  new
         rules.
           Maximum contaminant  level goals (MCLGs)  have been established  for some time for
         most  of,  if not  all, the  proposed  new  standards.  In moving  toward  establishment  means
         that  the  federal  USEPA  believes that  the  technology  is  available  for  treatment  at  a  rea-
         sonable  cost to the  consumer.
           The  trends  in  new  contaminant  additions  to  the  rules,  tightening  of  existing  stan-
         dards,  and  expansion  of regulatory application  should  continue  as new health  issue  and
         treatment  research  indicates  the  need  and  potential  resolutions.  To  make  the  problem
         of producing  acceptable  quality  water  even  more  complicated,  the  treatment  plant  de-
         signer now also has  to contend  with the possibility of unusual  biological and  toxic con-
         taminants  introduced  into the water supply  by terrorist activity. It is apparent  that treat-
         ment facilities now must not only accommodate  changes in regulatory requirements, but
         also continue to handle  changes  in influent raw water quality. As the rules become more
         stringent,  it  will  become  more  difficult to  handle  rapid  changes  in  quality  due  to  nat-
         ural  causes  such  as  intense  rainfall  and  runoff.  It will be  even  more  difficult to  handle
         "introduced"  contaminants  because  of  the  unknown  factor.  Once  it  is  introduced  and
         contaminants  are  discovered,  temporary  shutdown  of treatment  facilities  may  be  nec-
         essary.  The  tightening  rules  and  the  potential  for unexpected  contamination  make  wa-
         ter  quality  monitoring  facilities  even  more  essential  features  of  water  treatment  plan-
         ning  design  and  operation.
           It is emphasized that the primary  purpose  of this brief discussion of the new proposed
         rules  is to  illustrate the  challenge presented  to the  design  engineer in defining treatment
         goals. The established  and proposed water quality rules and  standards  shown in the tables
         should  serve only  as  a  guide to the  water  treatment  planner  or designer.  It is also essen-
         tial that  the  details  of water quality  requirements  be  obtained  from the  appropriate  state,
         provincial, or other agency.


         Regulatory Trends~Treatment Obsolescence

         In  general  terms,  the  goal  of the  SDWA  is  to  produce  the  most  contaminant-free  drink-
         ing  water  that  technology  permits,  limited only  by  the  magnitude  of treatment  costs.  As
         technology has  improved,  particular  MCLs  have become more  stringent.  Since  1970,  for
         instance,  turbidity  limits have been reduced  from  5.0 to  1.0 to 0.5  ntu  and,  under  the In-
         terim Enhanced  Surface Water Treatment Rule, to 0.3  ntu.  Some states  may require even
         lower  limits.  The  first-stage  TTHM  (total  trihalomethane)  and  HAA5  (five  haloacetile
         acids)  limits recently  became effective for average distribution  system  conditions.  In the
         near  future  these  limits  will be  required  for  worst-case  locations  in the  distribution  sys-
         tem.  New  regulatory  requirements  are  continuously  being  added  to the  rules  such  as the
         reduction  of organic  content  in treatment  and  the  reduction  of arsenic  content.
           As  the  regulatory  requirements  become  more  stringent,  currently  accepted  treatment
         processes  can and  will become obsolete.  If, for instance,  turbidity  levels in surface water
         treatment  are reduced  to 0.20 ntu,  there are  several types of filtration that may not be ad-
         equate operating  in currently  acceptable design modes.  Such facilities may have to be re-
         placed or, modified in operation, or supplementary  filtration may have to be added.  Some
        current  filtration  processes  do  not  reduce  organic  content  at  all  or  reduce  organics  to  a
        limited extent.  These  also  may  have  to  be  replaced,  modified,  or  supplemented  in  treat-
        ment. Potential treatment obsolescence must be recognized in treatment  selection to avoid
        costly future  changes.
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