Using DWSRF Funds to Comply with the Long

Term 1 Enhanced Surface Water Treatment Rule

The Drinking Water State Revolving Fund (DWSRF) program was established by the 1996 Safe Drinking Water Act (SDWA)

Amendments and authorizes grants to states to capitalize revolving loan funds. The states provide low-interest loans to eligible

systems for infrastructure improvements needed to ensure compliance with the SDWA and protect public health. The

DWSRF program can play a significant role in helping systems, especially small systems, to meet the challenges of complying

with new drinking water standards.

The Long Term 1 Enhanced Surface Water Treatment Rule (LT1ESWTR), published in January 2002, requires all water

systems serving fewer than 10,000 people and using surface water or ground water under the direct influence of surface water

to improve public health protection through the control of microbial contaminants, particularly Cryptosporidium. These

systems must achieve 2-log (99%) removal of Cryptosporidium by complying with strengthened combined filter effluent (CFE)

turbidity performance requirements, complying with individual filter turbidity requirements, meeting disinfection profiling

and benchmarking requirements, and constructing only covered finished water storage facilities. The LT1ESWTR will impose

a financial burden on some water systems. The DWSRF can provide assistance to systems to help ease this burden, increase

compliance, and protect public health.

WHY DID EPA CREATE THIS RULE?

The 1989 Surface Water Treatment Rule (SWTR) focused on preventing waterborne diseases through filtration and disinfection. In 1998, the Interim Enhanced Surface Water Treatment Rule (IESWTR) strengthened protection from microbial

contaminants for systems serving at least 10,000 people. The requirements of the LT1ESWTR were based on the IESWTR,

but have been modified to reduce the burden on small systems. It is estimated that the LT1ESWTR will reduce the number of

gastrointestinal illnesses from Cryptosporidium and other pathogens through improvements in filtration. The rule will also

reduce the likelihood of endemic illness from Cryptosporidium by an estimated 12,000 to 41,000 cases annually.

TO WHOM DOES THIS RULE APPLY?

The LT1ESWTR applies to all systems that use

surface water or ground water under the direct

influence of surface water (GWUDI) and serve

fewer than 10,000 people. These systems must

comply with all applicable LT1ESWTR provisions

by January 2005.

Source Type System Type Population Type

 









Surface Water < 10,000

Ground Water 10,000 - 100,000

GWUDI > 100,000

CWSs

NTNCWSs

TNCWSs

FOR SYSTEMS FOR STATES

March 15, 2002 Construction of uncovered finished water reservoirs is prohibited.

July 1, 2003

Systems serving between 500 and 9,999 persons must begin developing a disinfection profile, unless system

has shown the state that total trihalomethane (TTHM) levels are # 0.064 mg/L and five haloacetic acid (HAA5)

levels are # 0.048 mg/L.

January 1, 2004 Systems serving fewer than 500 persons must begin developing a disinfection profile, unless system has

shown the state that TTHM levels are # 0.064 mg/L and HAA5 levels are # 0.048 mg/L.

State primacy appliations due, if no extension granted. January 14, 2004

July 1, 2004 Systems serving between 500 and 9,999 persons must complete a disinfection profile (unless the state has

determined it is unnecessary).

January 1, 2005 Systems serving fewer than 500 persons must complete a disinfection profile (unless the state has determined

it is unnecessary).

January 14, 2005

Systems serving fewer than 10,000 people must comply with the applicable LT1ESWTR provisions (e.g.,

turbidity standards, individual filter monitoring, Cryptosporidium removal requirements, updated watershed

control requirements for unfiltered systems).

CRITICAL RULE DEADLINES & REQUIREMENTS
HOW WILL THIS RULE IMPACT SYSTEMS?

The LT1ESWTR provisions will impose significant costs on

small water systems. Total capital costs for investments in

treatment technology and infrastructure are estimated to be $174

million (see Figure 1). In addition, EPA estimates that annual

operation and maintenance (O & M), monitoring, reporting,

profiling, and benchmarking costs will add up to almost $20

million. All of these capital costs will be borne by systems

serving fewer than 10,000 people (see Figure 2).

The two primary methods for treating drinking water for

microbial contaminants are chemical disinfection (inactivation) and physical removal. The main goal of the LT1ESWTR is to

improve the physical removal of microbial contaminants through the enhancement of turbidity treatment processes. Provisions

such as disinfection profiling and benchmarking will help ensure that this increased protection against microbial risks is not

compromised as systems alter their disinfection practices to meet the new disinfection byproduct (DBP) standards.

The provisions of the LT1ESWTR that will generate most of the capital needs are the Cryptosporidium removal provisions

implemented through the CFE turbidity performance standards. Of the 11,411 systems subject to the LT1ESWTR, 8,991

filter their water and will be subject to these turbidity provisions. The EPA estimates that 2,207 of these systems will need to

modify their water treatment process to comply with the new standards. In addition, 2,327 will need to install individual filter

turbidimeters to meet the individual filter effluent turbidity monitoring requirement. An estimated 314 small systems will

need to comply with the covered finished water reservoir provision. Although thousands of systems will need to develop

disinfection profiles and benchmarks, this will not require systems to make capital improvements.

To be in compliance by January 2005, systems will need to make capital investments over the next three years. Most of the

systems that will have to modify treatment serve more than 1,000 people (see Figure 2). Figure 3 shows how much it will cost

systems annually (on average) to modify treatment to meet new turbidity standards. For most systems, the annual O & M

costs imposed by the LT1ESWTR will be at least as significant as the annual capital costs. In order to comply with the rule,

systems will have to make a range of investments, from flocculation basin structural improvements to additional filter media

(see Exhibit 1).

Approximately 6.3 million households are served by water systems subject to the LT1ESWTR provisions. EPA estimates that

99% of these households will see an increase in their bills of less than $10 per month. The increase in costs per household to

meet the LT1ESWTR standards will depend on the size of the water system and the treatment changes needed.

Figure 1: TOTAL LT1ESWTR PRICE TAG

(in millions of 1999 $)

Capital Costs

Total Capital Costs

for Treatment

Modifications by

System Size

< 100

101-500

$7

$11

$32

$47

$173.6

$0.8

$14.5

$5.2

$174.4

$77

501-1,000

1,001-3,300

3,301-10,000

Treatment Modifications

Covered Finished Water Storage

CAPITAL COST GRAND TOTAL

AnnualO&M Costs

Annual Monitoring & Admin Costs

Figure 3: Average Annual Cost per System Needing to

Modify Treatment Practices to Meet New Turbidity

Requirements (in thousands of 1999 $)

0

100

200

300

400

500

600

700

<100 101-500 501-1,000 1,001-

3,300

3,301-

9,999

Population Served

Figure 2: Number of Systems That Will Need to Modify

Treatment Practices to Meet New Turbidity Requirements

$0

$2

$4

$6

$8

$10

$12

$14

$16

$18

<100 101-500 501-1,000 1,001-

3,300

3,301-

9,999

Population Served

O & M Costs

Capital Costs

Note: Capital costs based on total costs amortized over 20 years at a 3% discount rate.
WHAT TYPE OF TREATMENT WILL SYSTEMS HAVE TO PUT IN PLACE?

The LT1ESWTR contains several significant turbidity provisions. The CFE standards apply only to systems that use

filtration and differ based on the type of filtration technology

used (see Figure 4). For conventional and direct filtration

systems, LT1ESWTR requires the turbidity level of a system’s

representative CFE samples to be less than or equal to 0.3

nephelometric turbidity units (NTUs) in at least 95% of the

measurements taken each month and cannot exceed 1 NTU at

any time. Slow sand and diatomaceous earth filtration systems

are presumed to achieve at least 2-log removal of

Cryptosporidium by meeting existing filter performance requirements established in the SWTR. Systems using alternative

filtration (i.e., membrane filtration, cartridge filtration) must

demonstrate to their state that their system achieves 2-log

removal of Cryptosporidium, 3-log removal of Giardia lamblia,

and 4-log removal and/or inactivation of viruses.

The LT1ESWTR also requires systems that use conventional or direct filtration to conduct continuous turbidity monitoring at

each filter. Systems that do not already have turbidimeters at each filter will be required to install them (systems with 2 filters

can conduct continuous monitoring of CFE in place of individual filter monitoring).

Exhibit 1 details the treatment and process modifications that

conventional and direct filtration systems may need to implement to meet the CFE standards of the LT1ESWTR. Very few

systems will need to make all of the listed improvements. The

necessary improvements will depend on the design of the

system, the system’s source water quality, and the skill level of

the system’s operators. For instance, systems with very high

turbidity levels may need to install expensive backwash upgrades.

The costs of the improvements listed in Exhibit 1 are estimates

for a system with an average flow serving the median population

between 1,001 and 3,300 people. Some of these improvements,

like adding additional filter media, are relatively inexpensive.

Other changes, like flocculation improvements and filter media

replacements, can require tens of thousands of dollars in capital

investment. The last column provides an estimate of the total

number of small systems that will need to make each improvement to be in compliance with the LT1ESWTR. For instance,

2,327 systems will need to install individual filter turbidimeters

with recorders at a cost (on average) of $4,700 per system.

In addition to the turbidity provisions, small systems subject to

the LT1ESWTR are required to cover all new finished water

reservoirs, holding tanks, or other storage facilities to protect

finished water from contamination. The cost of covering new

facilities is approximately $2 per square foot. On average,

capital costs to cover new finished water reservoirs range from

$188 for systems serving under 100 people to $10,000 for

systems serving 3,301-9,999 people. Approximately 5% of

systems subject to the LT1ESWTR will construct a new finished

water storage reservoir over the next 20 years.

Potential System Modifications

Example Costs for

Systems Serving

1,001-3,300*

Total Number

of Small

Systems that

Need this

Change**

Total

Capital

Costs

Annual

O & M

Costs

Chemical Addition

c 0 oagulant aid polymer feed capability $ 0 8,00 $ 0 1,90 99

b 0 ackwash water polymer feed $ 0 8,00 $ 1 1,80 29

i 0 nstall pH adjustments $ 0 8,10 $ 0 3,90 74

Coagulation Improvements $ 0 8,000 $ 3 1,90 1,16

Rapid Mixing Improvements

m 0 echanical $ 0 3,20 $ 0 90 74

s 0 tructural $ 0 9,70 $ 2 1,90 23

Flocculation Improvements

m 0 echanical $ 0 28,40 $ 9 1,70 1,00

s 0 tructural $ 0 64,40 $ 1 1,90 29

Settling Improvements

e 0 quipment modification $ 0 6,10 $ 9 1,10 1,00

a 0 dd tube settlers $ 0 69,80 $ 1 1,10 29

Filtration Improvements

f 0 ilter media additions (2-6" typical) $ 0 1,20 $ 3 77

f 0 ilter media replacement $ 0 169,90 $ 2 62

b 0 ackwashing-increase flow/velocity $ 0 65,30 $ 3 5,00 52

b 0 ackwashing-install surface wash $ 0 125,30 $ 2 3,20 97

p 0 ost backwash filter-to-waste $ 0 18,70 $ 1 2,70 29

f 0 ilter control systems $ 0 35,70 $ 6 3,50 94

f 0 ilter turbidimeter installation $ 0 4,70 $ 7 80 2,32

Exhibit 1: Potential System Modifications to Meet

LT1ESWTR Turbidity Provisions (in 1999 $)

0%

20%

40%

60%

80%

100%

<100 101-500 501-1,000 1,001-

3,300

3,301-

9,999

Population Served

Conventional or Direct Filtration Slow Sand or Diatomaceous Earth

Alternative Filtration Do Not Filter

Figure 4: Percentage of Small Systems Subject to CFE

Turbidity Requirements

*Projected costs to meet 0.3 NTU

**Projected total number of systems that serve fewer than 10,000 people that

would modify treatment to meet 0.3 NTU, 1 NTU maximum.
HOW CAN THE DWSRF ASSIST SYSTEMS?

States use DWSRF capitalization grant monies to provide lowinterest loans to publicly- and privately-owned public water

systems for infrastructure improvements needed to continue to

ensure safe drinking water. States may offer principal forgiveness,

reduced interest rates, or extended loan terms to systems identified by the state as serving disadvantaged communities. States

also have the ability to reserve a portion of their grants (i.e., setasides) to finance activities that encourage enhanced water system

management and help to prevent contamination problems

through source water protection measures. Based on the fiscal

year 2002 appropriation of $850 million, capitalization grants

ranged from $8.0 million to $82.4 million per state.

Most capital projects – including adding new technologies and

improving existing facilities – needed to comply with the new

LT1ESWTR requirements are eligible for funding under the

DWSRF (see Exhibit 2). In addition, the construction of covered

finished water storage facilities and the installation of individual

filter turbidimeters are eligible.

States can use set-aside funds from the DWSRF to assist systems

directly as well as to enhance their own program management

activities (see Exhibit 2). A state may use set-asides to make

administrative improvements to the entire drinking water program, which faces increased costs in implementing LT1ESWTR.

States can provide training to small systems on meeting the

requirements of

LT1ESWTR

as well as

technical assistance in identifying appropriate technologies. States can

provide assistance to small systems to cover the costs of project planning

and design for infrastructure improvements. States can also use funds to

support their sanitary survey program.

Since the DWSRF program is managed by states, project and set-aside

funding varies according to the priorities, policies, and laws within each

state. Given that each state administers its own program differently, the

first step in seeking assistance is to contact the state DWSRF representative which can be found on the EPA DWSRF website.

Type of Project/Activity

Eligible Under

Infrastructure Fund

Eligible Under

Set-Asides

Treatment

C s hemical Addition System Y o e N

C s oagulant Improvements Y o e N

R s apid Mixing Improvements Y o e N

F s locculant Improvements Y o e N

S s ettling Improvements Y o e N

F s iltration Improvements Y o e N

P s lanning & Design Activities Y * e Yes

Turbidimeters Y o es N

Covered Finished Water Storage Y o es N

System Administrative Improvements

P o rofiling and Benchmarking N oN

H o ire Staff N oN

S o taff Training N s Ye

P o ublic Outreach N s Ye

M o onitoring N oN

R o ate Increase Process N s Ye

State Administrative Improvements

H o ire Staff N s Ye

S o taff Training N s Ye

P o ublic Outreach N s Ye

C o ompliance Oversight N s Ye

E o nforcement N s Ye

P o ilot Studies N s Ye

S o anitary Surveys N s Ye

*For small systems only.

Exhibit 2: Projects/Activities Eligible for DWSRF

Funding to Comply With LT1ESWTR

A small development in the hills of Idaho faced

difficulties in meeting the Surface Water Treatment

Rule due to a lack of filtration capabilities in its

water system. The 200-lot neighborhood received a

$400,000 DWSRF loan to design and construct a

diatomaceous earth pressure filtration system, a

pipeline chlorine contact chamber, and a new

100,000-gallon storage tank. The subdivision was

able to complete all phases of the project under

budget at a cost of $323,341.

Castle Mountain Creeks

Subdivision, Idaho

Printed on Recycled Paper

FOR MORE INFORMATION...

DWSRF and LT1ESWTR General Information

DWSRF Website:

http://www.epa.gov/safewater/dwsrf.html

LT1ESWTR Website:

http://www.epa.gov/safewater/mdbp/lt1eswtr.html

SDWA Hotline

1-800-426-4791

EPA's Ground Water & Drinking

Water Website:

http://www.epa.gov/safewater/

Office of Ground Water and

Drinking Water (4606M)

EPA 816-F-02-005

June 2002